📄 Extracted Text (8,898 words)
Deutsche Bank
Wealth Management
Wire Confirmation
The wire transfer request below has been transmitted successfully.
Transmitted: 05/03/2018 12:46:04 PM (ET)
Transmitted By: BELLAKLEIN
Effective Confirmation Approval
Account Template Name Recipient Name Amount Currency
Date Number Status
Jeffrey Epstein - JEE to Link and Link and 142.908.11 USD 05/03/2018 1228598073 1 of I received
NOW - '9691 Rockenbach PA Rockenbach, PA.
EFTA00799106
Link & Rockenbach, PA
1555 Palm Beach Lakes Blvd.
Suite 301
West Palm Beach, FL 33401
561-727-3600
Tax ID No. 82-3083928
May 3, 2018
Jeffrey Epstein 0002
6100 Red Hook Quarter, B3
St. Thomas, USV 00802
Statement
Matter Running
Date Bill Number/Description Bill Amount Paid Amount Balance
0001 - Bradley Edwards
10/24/17 1 49,985.00 49,985.00
10/24/17 Earned Non-Refundable Fee 49,985.00 0.00
11/06/17 32937 / Initial Bill from Time Slips 194,971.50 194,971.50
11/13/17 Payment Inv. No. 32937 from Time Slips 194,971.50 0.00
12/11/17 2 / Initial Bill from Time Slips Bill # 32942 257,198.13 257,198.13
12/11/17 Payment In. No. 32942 from Time Slips 257,198.13 0.00
12/31/17 9 219,076.50 219,076.50
01/09/18 WT / Wire Transfer 150,000.00 69,076.50
01/31/18 Applied to 9. 69,076.50 0.00
02/01/18 84 279,560.88 279,560.88
02/27/18 Wire Transfer Invoice #84 279,560.88 0.00
03/05/18 226 226,888.08 226,688.08
04/03/18 Applied to 226. 226,688.08 0.00
04/06/18 396 392,908.11 392,908.11
04/24/18 180424129069 / Applied to 396. 250,000.00 142,908.11
Matter Balance Due
Total Balance Due
So
EFTA00799107
LINK &
ta ROCKENBACH, ■.
CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301
West Palm Beach, Florida 33401
T 561.727.3600
F 561.727.3801
Wire Transfer Instructions
Wire Transfer to: Wells Fargo Bank, N.A.
Routing No. / ABA No.: 121000248
Address: 420 Montgomery
San Francisco, CA 94104
Beneficiary Account No.:
Beneficiary Name: Link & Rockenbach, P.A.
Address: 1555 Palm Beach lakes, Blvd.
Suite 301
West Palm Beach, FL 33401
Additional Information: Operating Account
EFTA00799108
From: Darren IndykS1
Subject: Fwd: Balance Due
Date: May 3, 2018 1
To: Richard Kahn
Cc: Darren Indyke
Jeffrey said ok to pay this balance on the April Invoice for March
time. Do you have the invoice or shall I send again.
DARREN K. INDYKE
DARREN K. INDYKE, PLLC
575 Lexington Avenue, 4th Floor
New York New York 10
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication
or any part thereof is strictly prohibited and may be unlawful. If you have received this
communication in error, please notify us immediately by return e-mail, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke, PLLC - 2018 Darren K.
Indyke, PLLC — All rights reserved.
Begin forwarded message:
From: "Paul V. DeVito" ‹ >
Subject: Balance Due
Date: May 3, 2018 : : T
To: Darren Indyke < >
Good morning Mr. Indyke. I have attached a copy of Mr. Epstein's Statement showing a
balance due of $142,908.11. I have also attached wire transfer instructions for your
reference. Please let me know if you need any additional information. Thank you very much
for your help.
Paul DeVito
L IR
LINK&
ROCKENBACH, PA
CIVIL TRIAL & APPELLATE LAW
Bookkeeper Billing Coordinator
LINK & ROCKENBACH, PA
1555 Palm Beach Lakes Blvd., Suite 301
West Palm Beach.FL 1
EFTA00799109
LINK& 1555 Palm Beach Lakes Blvd., Suite 301
ILIR ROCKENBACH 9 PA
CIVIL TRIAL & APPELLATE LAW
West Palm Beach, FL 33401
TEL (561) 727-3600 I FAX (561) 727-3601
April 10, 2018
Via Email leevacationegmaitcom
Jeffrey Epstein
6100 Red Hook Quarter, 83
St. Thomas, USVI 00802
Re: Jeffrey Epstein v. Bradley J. Edwards
File No.: 2.0001
Dear Jeffrey:
Attached please find our firm's billing statement for services rendered through March 31,
2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the
amount of $12,190.00 ($100.00 x 121.9 hours). The line items beginning with "No Charge"
reflect an additional reduction in the amount of $20,393.50 making the total reduction
$32,583.50.
Please do not hesitate to call me if you have any questions regarding this bill. Thank you.
Very truly yours,
Scott J. Link
SJL/pvd
Attachment
cc: Darren Indyke w/attachment
EFTA00799110
irt LINK &
ROCKENBACH, P.A.
CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301
Went Palm Beach, Florida 33401
T 561.7273600
F 561.727.3601
Wire Transfer Instructions
Wire Transfer to: Wells Fargo Bank, N.A.
Routing No. / ABA No.: 121000248
Address: 420 Montgomery
San Francisco, CA 94104
Beneficiary Account No.:
Beneficiary Name: Link & Rockenbach, P.A.
Address: 1555 Palm Beach lakes, Blvd.
Suite 301
West Palm Beach, FL 33401
Additional Information: Operating Account
EFTA00799111
Link & Rockenbach, PA
1555 Palm Beach Lakes Blvd.
Suite 301
West Palm Beach, FL 33401
561-727-3600
Tax ID No. 82-3083928
Jeffrey Epstein April 6, 2018
6100 Red Hook Quarter, B3 Invoice # 396
St. Thomas, USV 00802
CLIENT: 0002 - Jeffrey Epstein
Re: 0001 Bradley Edwards
Date Services Hours Amount
03/01/18 RJG Attend team meeting re trial plan 1.00 395.00
03/01/18 RJG Research assertion of constitutional privileges 2.10 829.50
against self-incrimination in civil cases, waiver of
same, assertion of privilege in discovery, in
preparation for drafting Response to Edwards' Motion
to Compel Response to Request for Admissions
03/01/18 RJG Continue drafting/revising Response in Opposition to 2.10 829.50
B. Edwards' Motion to Compel Response to Request
for Admissions
03/01/18 RJG Begin updating research on malicious 1.90 750.50
prosecution/elements and recent case law in
preparation for trial
03/01/18 RJG Review/analyze B. Edwards' Motion for Separate 0.80 316.00
Trials or, in the Alternative to Adjust the Order of
Proof, in preparation for drafting response
03/01/18 RJG Begin researching bifurcation of trial/eleventh-hour 0.60 237.00
request, in preparation for drafting response to B.
Edwards' Motion for Separate Trials
03/01/18 AMP [No Charge] Update hearing transcripts binder and 2.00 0.00
prepare updated index for same
EFTA00799112
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 2
Date Services Hours Amount
03/01/18 SJL Work on issues relating to disclosure of key e-mails; 12.80 9,600.00
work on Notice/Appendix of same; work on Motion for
Court's Permission to Alter Trial Evidence; multiple
telephone conferences and communications with D.
Indyke and J. Epstein re same; follow up on hearing
schedule; trial team meeting with J. Goldberger, M.
Goldberger, J. Caldwell, T. Campbell, R. Glasser and
K. Rockenbach re trial work, hearing preparations
and strategies; work on objections to B. Edwards'
deposition designations
03/01/18 TLC Continue working on itemizing all key emails and 14.80 3,330.00
public records located on witnesses on Clerk's Trial
Exhibit List; work on culling out key emails to disclose
to Court; work on trial exhibits; work on Appendix of
key e-mails; work on confidentiality issues; follow up
with opposing counsel re hearing and production of
audio; work on chronology; begin reviewing new
public records
03/01/18 KBR Prepare objections to B. Edwards' deposition 8.20 6,150.00
designations and consider counter-designations;
attend trial team strategy meeting; prepare/revise
motion to redact names and alter trial exhibits; work
on Response to B. Edwards' Motion to Compel
Response to Request for Admissions re sex offender
registry's authenticity and accuracy; analyze B.
Edwards' proposed Juror Questionnaire and email J.
Scarola for Word version in order to edit; work on
same
03/01/18 PVD [No Charge] Work on preparation of Trial Exhibits 7.50 0.00
03/02/18 RJG Continue researching bifurcation of trial, 11th-hour 3.20 1,264.00
request, bifurcation as waste of judicial resources,
bifurcation where claim and counterclaim are
interrelated and waiver of bifurcation
03/02/18 RJG Research pre-trial stipulations as binding on parties 2.90 1,145.50
and the court and strictly enforced; stipulation to
consolidated trial; order and scope of
proceedings/whether counterclaim can proceed first
03/02/18 RJG Begin drafting Response to B. Edwards' Motion for 3.30 1,303.50
Separate Trials or, in the Alternative to Adjust Order
of Proof
EFTA00799113
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 3
Date Services Hours Amount
03/02/18 KBR Work on trial preparations; work on trial exhibits; 5.50 4,125.00
work on Motions for Permission to Alter Trial
Evidence and Rule of Judicial Administration
03/02/18 TLC Work on summary of all litigation, arrests and sheriff 14.50 3,262.50
reports for S. Rivera, T. Miller and C. Wild to include
In Motion to Alter Evidence; work on same; work on
Notice of Filing Appendix in Support of Response in
Opposition to B. Edwards' Second Supplement to
Motion in Limine Addressing Scope of Admissible
Evidence; work on hearing needs; follow up on V.
Roberts' audio tape; prepare Notice of Cancellation
of Hearing; work on Clerk's Trial Exhibit List to
identify each item individually
03/02/18 SJL Continue working on Notice of Filing Appendix in 12.80 9,600.00
Support of Response in Opposition to B. Edwards'
Second Supplement to Motion in Limine Addressing
Scope of Admissible Evidence; address
confidentiality concerns; multiple communications
with D. Indyke and J. Epstein re same; work on two
Motions to Alter Evidence; communications with
potential jury selection consultants; work on opening
statement; work on trial strategies; follow up on audio
tape of V. Roberts
03/02/18 PVD [No Charge] Work on preparation of Trial Exhibits 7.50 0.00
03/03/18 SJL Work on Response to Motion to B. Edwards' Compel 7.30 5,475.00
re Request for Admissions; strategize re default
against S. Rothstein and options to proceed with trial
or seek to strike trial setting; work on preparations for
special set hearings; work on trial preparations
EFTA00799114
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 4
Date Services Hours Amount
03/03/18 TLC Work on preparations for hearing on all outstanding 10.00 2,250.00
motions: (1) Epstein's Motion for Case Management
Conference, (2) Edwards' Motion for Separate Trials;
(3) Edwards' Second Supplement to Motion in Limine
Addressing Scope of Admissible Evidence, (4)
Edwards' Motion in Limine to Limit Introduction of
Evidence Alleged to Support Epstein's Claims
Against Edwards; (5) Epstein's Motions for
Permission to Alter Evidence; (6) Epstein's Motion for
Protective Order and in Limine of Unrelated
Settlements; (7) Edwards' Second Motion to Lift
Confidentiality; (8) Edwards' Motion for Adverse
Inference; (9) Edwards' Motion in Limine Scope of
Admissible Evidence; (10) Epstein's Motion to Strike
Damages Expert; (11) Edwards' Motion in Limine
Addressing the Admissibility of Edwards' Exhibit 132;
(12) Epstein's Motion in Limine re Sex Offender
Registry; (13) Epstein's Motion in Limine on
Edwards' Newly Disclosed Exhibits; (14) Epstein's
Request for Judicial Notice; and (15) Objections to
Deposition Designations; assemble hearing
notebooks and materials for each; pull authorities and
prepare indices where needed; work on sequence list
of motions; prepare Notice of Hearing and letter to
judge; work on Response to Motion to Compel re
Request for Admissions; work on assembling
unredacted set of evidence and serve same
03/03/18 RJG Review/Analyze B. Edwards' Supplement to Motion 2.90 1,145.50
for Separate Trials or, in the Alternative to Adjust
Order of Proof, and case law cited therein; revise
Response in Opposition to Motion for Separate
Trials, etc., to address Supplement; revise response
per partners' suggested changes
03/03/18 RJG Legal research when case is "at issue" and propriety 1.60 632.00
of clerk's default v. judge's default; revise Response
in Opposition to B. Edwards' Motion for Separate
Trials to Include "at issue" argument
03/03/18 KBR Work on preparations for trial; work on Motion to 7.30 5,475.00
Remove Case from Trial Docket in compliance with
Florida Rule of Civil Procedure 1.440; work on
Response to B. Edwards' Motion to Severe; conduct
legal research on appellate vehicle should the Court
grant B. Edwards' Motion to Severe
EFTA00799115
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 5
Date Services Hours Amount
03/04/18 TLC Continue working on itemized Clerk's Trial Exhibit 9.70 2,182.50
List; work on Objections to Deposition Designations;
prepare Motion for Default and Default Judgment
against S. Rothstein; work on timeline for Response
to Motion to Severe; work on issues relating to
production of disc; work on marking trial exhibits
03/04/18 KBR Continue working on trial preparations; continue 9.00 6,750.00
working on Response to B. Edwards' Motion to
Severe and Motion to Strike from Trial Docket;
conduct further legal research on appellate options
03/04/18 PVD [No Charge] Work on preparation of Trial Exhibits 10.50 0.00
03/05/18 RJG Revise Response in Opposition to Edwards' Motion 1.00 395.00
for Separate Trials per partners' suggested changes;
insert/address timeline
03/05/18 AMP [No Charge] Prepare binder re J. Epstein's Notice of 1.00 0.00
Filing of Redacted Appendix in Support of Response
in Opposition to B. Edwards' Second Supplement to
Motion in Limine Addressing Scope of Admissible
Evidence
03/05/18 AMP [No Charge] Prepare packet regarding J. Epstein's 0.40 0.00
Motion in Limine as to Sex Offender Registry
Information
03/05/18 RJG Research mandamus as proper vehicle to enforce 2.50 987.50
time restrictions for setting of a trial; requirements for
mandamus relief; begin drafting proposed emergency
relief Petition for Writ of Mandamus
03/05/18 TMB (No Charge] Finalize letter to T. Chinaris re packet of 0.10 0.00
exhibits
03/05/18 RJG Review/analyze B. Edwards' Motion in Limine to Limit 2.50 987.50
Introduction of Evidence Alleged to Support J.
Epstein's Claims Against B. Edwards and
accompanying J. Epstein deposition. excerpts;
conduct preliminary research in preparation for
drafting response
EFTA00799116
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 6
Date Services Hours Amount
03/05/18 TLC Work on Clerk's Trial Exhibit List; finalize and file 13.50 3,037.50
same; work on organizing and marking trial exhibits;
work on Motion for Default; work on J. Epstein's
Motion to Remove Case from Trial Docket in Order to
Comply With the Mandate Set Forth in Rule 1.440;
work on Response to B. Edwards' Motion for
Separate Trials; work on Motion for Court to Declare
Relevance and Non-Privileged Nature of Documents
and Request for Additional Limited Discovery,
Evidentiary and Appointment of Special Master; work
on assembling authorities and hearing folder for our
Motion to Remove Case from Trial Docket; telephone
conference with trial support; follow up with D. Vitale
re proposed Order from hearing on our Motion for
Protective Order re settlements; follow up with J.
Scarola's assistant re unilateral setting of hearings
and request for cancellation; work on hearing folder
on our Response to B. Edwards' Motion for Separate
Trials; assemble authorities for same; prepare Notice
of no objection to sealing records until Court makes
determination
03/05/18 SJL Multiple communications with J. Scarola, P. Cassell, 11.20 8,400.00
D. Indyke and J. Epstein re production of emails and
treatment / alleged improperly obtaining privilege
documents; work on Motion to Strike from Trial
Docket; work on Response to B. Edwards' Motion to
Severe; work on Motion for Court to Declare
Relevance and Non-Privileged Nature of Documents,
etc.; work on preparations for special set hearing and
addressing outstanding Order on settlement issues;
work on proposed sequence of Motions
03/06/18 TMB [No Charge] Draft Petition for Writ of Certiorari shell 0.20 0.00
03/06/18 TMB (No Charge] Work on Appendix to Petition for Writ of 0.10 0.00
Certiorari shell
03/06/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00
Treatment per Fourth District Court of Appeal's
Administrative Order
03/06/18 TMB [No Charge) Work on Affidavit for T. Chinaris 0.20 0.00
EFTA00799117
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 7
Date Services Hours Amount
03/06/18 RJG Continue drafting/revising proposed Emergency 5.30 2,093.50
Petition for Writ of Mandamus in preparation for trial
court denying Motion to Strike Case from Docket
03/06/18 RJG Revise proposed Emergency Petition for Writ of 1.90 750.50
Mandamus per partners' suggested changes; verify
all citations
03/06/18 RJG Review pleadings/timeline for statement of facts 1.30 513.50
section of proposed Emergency Petition for Writ of
Mandamus
03/06/18 TLC Work on analysis of Farmer Jaffe Privilege Log; work 14.00 3,150.00
on Notice of No Objection to Sealing Records; work
on Response to B. Edwards' Motion to Strike J.
Epstein's Untimely Supplemental Exhibits; work on
trial exhibits; prepare letter to judge with additional
hearing submissions; work on Notice of Hearing
03/06/18 SJL Work on issues surrounding production of 27,000 13.00 9,750.00
page email disc; multiple communications with P.
Cassell; follow up with client re position; work on
Response to Motion to Strike J. Epstein's Untimely
Supplemental Exhibits; work on Petition for Writ of
Mandamus
03/06/18 KBR Work on Petition for Writ of Mandamus; work on 10.00 7,500.00
Affidavit of T. Chinaris; communica tions with T.
Chinaris re same; work on trial preparations; work on
preparations for special set hearing on all pending
Motions; work on Response to Motion to Strike J.
Epstein's Untimely Supplemental Exhibits
03/06/18 PVD [No Charge] Work on procuring documents 7.50 0.00
considered to be privileged materials at issue in B.
Edwards' Motion to Strike J. Epstein's Untimely
Supplemental Exhibits
03/07/18 RJG Review/analyze/research B. Edwards' Motion in 2.10 829.50
Limine to Limit the Introduction of Evidence Alleged
to Support J. Epstein's Claims Against B.
Edwards;draftlrevise Response to same
03/07/18 TMB [No Charge] Review Fourth District Court of Appeal's 0.20 0.00
emergency treatment procedures in preparation for
Petition Mandamus
EFTA00799118
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 8
Date Services Hours Amount
03/07/18 TMB [No Charge] Review clerk's records regarding 0.30 0.00
hearing on multiple motions on 3/8/18 and Order
Resetting Trial in preparation for Motion to Stay
[No Charge] Review Motion to Stay case - in 0.30 0.00
03/07/18 TMB
preparation for potential appeal
03/07/18 RJG Finalize pending responses for 3/8118 Special Set 6.90 2,725.50
Hearing; conference with partners re proposed
Emergency Petition for Writ of Mandamus and other
"emergency" filings to have in pipline; revise draft
Mandamus Petition accordingly; review all case law
citations in preparation for filing
03/07/18 TLC Work on trial exhibits; work on preparations for 14.50 3,262.50
special set hearing; follow up with trial support; work
on Objections to Deposition Designations; work on
updating trial binders; work on Response to B.
Edwards' Motion to Strike Epstein's Supplemental
Exhibits and to Strike All Exhibits and Any Reference
to Documents Containing Privileged Materials Listed
on B. Edwards' Privilege Log; work on Response in
Opposition to B. Edwards' Motion in Limine to Limit
the Introduction of Evidence Alleged to Support J.
Epstein's Claims Against B. Edwards; prepare
Affidavit of T. Campbell re chain of custody of disc;
prepare Notices of Filing Affidavits of T. Campbell
and T. Chinaris; work on schedule of motions to be
heard; communications with D. Indyke; prepare letter
and package to Judge Hafele re additional hearing
submissions; prepare letter to J. Scarola re delivery
of disc; carefully review redacted appendix to see if
we missed redacting any alleged victims' names as
alleged by P. Cassell
EFTA00799119
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 9
Date Services Hours Amount
03/07/18 SJL Work on Response in Opposition to B. Edwards' 12.30 9,225.00
Motion in Limine to Limit the Introduction of Evidence
Alleged to Support J. Epstein's Claims Against B.
Edwards; work on Affidavit of T. Campbell re chain of
custody of disc; communications with T. Chinaris re
Affidavit; work on Response in Opposition to B.
Edwards' Motion in Limine to Limit the Introduction of
Evidence Alleged to Support J. Epstein's Claims
Against B. Edwards; work on Emergency Motion for
Writ of Mandamus; telephone conferences with P.
Cassell; review Cassell's filings and follow up on
issues raised by same; communications with P.
Cassell and J. Scarola re production of disc;
communications with D. Indyke and J. Epstein
03/07/18 KBR Work on preparation for 3/8/18 hearings on 20+ 6.00 4,500.00
Motions/issues
03/07/18 PVD [No Charge] Work on chronology of privileged 3.50 0.00
materials at issue
03/07/18 PVD [No Charge] Work on procuring transcript of hearing 1.00 0.00
on 8/3/12
03/07/18 PVD [No Charge] Work on analysis of documents 1.00 0.00
produced
03/08/18 TMB (No Charge] Work on Request for Emergency 0.20 0.00
Treatment pursuant to Fourth District Court of
Appeal's instructions
03/08/18 TMB [No Charge] Prepare bookmark Appendix to Petition 0.40 0.00
for Writ of Mandamus
03/08/18 TMB [No Charge] Review and revise Appendix to Petition 0.20 0.00
for Writ of Mandamus
03/08/18 TMB [No Charge] Work on revisions to Appendix to 0.90 0.00
Emergency Petition for Writ of Mandamus and to
Emergency Motion for Review of Order Denying Stay
03/08/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00
Treatment
EFTA00799120
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 10
Date Services Hours Amount
03/08/18 TMB (No Charge] Work on revisions to Index to 0.30 0.00
Emergency Petition for Writ of Mandamus and
Emergency Motion for Review of Order Denying Stay
03/08/18 RJG Attend special set hearing before Judge Hafele re 3.00 1,185.00
pending motions
03/08/18 RJG Draft/revise Emergency Motion for Review of Order 5.10 2,014.50
Denying Stay to be filed in the Fourth District Court of
Appeal
03/08/18 RJG Draft proposed order denying J. Epstein's Motion for 0.10 39.50
Stay of Trial Proceedings
03/08/18 RJG Revise/finalize Emergency Petition for Writ of 2.50 987.50
Mandamus to be filed in the Fourth District Court of
Appeal
03/08/18 SJL Prepare for and argue at all-day special set hearing 12.50 9,375.00
on J. Epstein's Motion to Strike Matter from Trial
Docket, Motion to Sever Trials, Motion to Strike
Expert Dr. Jansen, Edwards' Motion to Strike
Exhibits, and other issues surrounding the 27,000
page disc of e-mails located in Fowler White's files;
follow up with client on outcome of hearing; follow up
with Fowler White re issues surrounding disc; work
on Emergency Petition for Writ of Mandamus and
Emergency Motion for Review of Order Denying Stay
03/08/18 KBR Work on Emergency Petition for Writ of Mandamus 12.50 9,375.00
and Emergency Motion for Review of Order Denying
Stay; work on proposed Orders for hearing; prepare
for and argue at all-day special set hearing on J.
Epstein's Motion to Strike Matter from Trial Docket,
Motion to Sever Trials, Motion to Strike Expert Dr.
Jansen, B. Edwards' Motion to Strike Exhibits and
other issues surrounding the 27,000 page disc of
e-mails located in Fowler White's files
03/08/18 TLC Prepare for and attend all-day special set hearing on 13.00 2,925.00
pending Motions; work on Emergency Petition for
Writ of Mandamus, Emergency Motion for Review of
Order Denying Stay and Appendix to same; prepare
proposed Orders on B. Edwards' Motion to Sever and
J. Epstein's Motion to Strike from Trial Docket; follow
up with trial support
EFTA00799121
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 11
Date Services Hours Amount
03/08/18 PVD [No Charge] Work on hearing binder preparation 2.00 0.00
03/08/18 PVD [No Charge] Work on deposition designations for W. 1.00 0.00
Berger
03/08/18 PVD [No Charge] Work on preparation of Appendix for 4.40 0.00
Emergency Petition for Writ of Mandamus
03/09/18 TMB [No Charge] Review Fourth District Court of Appeal's 0.10 0.00
email and Order on filing fee owed and due in ten
days; review Fourth District Court of Appeal's
Acknowledgment of New Case
03/09/18 CWH [No Charge] Legal research and analysis of Florida 2.30 0.00
authority and case law to determine whether general
release and settlement agreement of a fee dispute
can effectively waive the right to bring a malpractice
claim against prior attorney
03/09/18 RJG Review 3/8/18 hearing transcript in preparation for 0.50 197.50
drafting Emergency Petition for Writ of Certiorari
03/09/18 RJG Research/review/analyze case law on certiorari 1.90 750.50
review and severance and bifurcation orders in
preparation for drafting Emergency Petition for Writ
of Certiorari
03/09/18 RJG Draft/revise Emergency Petition for Writ of Certiorari 4.20 1,659.00
(as to circuit court's severance order)
03/09/18 RJG Draft/rev:se Motion to Consolidate extraordinary writ 0.20 79.00
petitions filed in the Fourth District Court of Appeal
03/09/18 TLC Prepare letter to J. Hurley re evidentiary issues; 11.00 2,475.00
prepare Notice of UMC hearing on Motion for Default
against S. Rothstein; prepare letter and package to
appellate clerk following up on filing of Petition for
Writ of Liandamus; prepare e-mail to M. Nurik re
hearing, on Motion for Default; update calendar re
deadline for Response and Reply; work on reviewing
Fowler ' ' :kris documents for paper trail of
product' . work on Juror Questionnaire; follow up
with K. Tarry re same; prepare proposed Order on
Motion it Amine re Sex Registry; follow up with J.
Scare' s:,ine; work on Order re settlement
inform..niuri
EFTA00799122
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 12
Date Service• Hours Amount
03/09/18 SJL Work or• iror Questionnaire; work on Petition for 10.20 7,650.00
Writ of c rtiorari Review of Order Severing Cases;
work on : °paring for trial; meet with J. Goldberger re
trial str- iies; e-mails communications with J.
Scarola e production and trial issues; review P.
Cassell's proposed orders; e-mail communications
with P. Cassell re orders and his clients' position in
the case; work on opening statement
03/09/18 KBR Work o tition for Writ of Certiorari Review; 8.00 6,000.00
preps — itegy for consolidating with pending
Petit! :Wit of Mandamus; consider strategy for
Petiti, • 'frit of Mandamus and/or Certiorari
regal' aim of privilege for e-mail documents
03/09/18 PVD [No C 4 Work on preparation of submissions to 1.00 0.00
the C Court, Fourth District Court of Appeal for
Eme' • Petition for Writ of Mandamus
03/09/18 PVD [No C' ' Review production seeking billing files 1.80 0.00
for Fr .
03/09/18 PVD [No c Work on updating trial binders 0.30 0.00
03/09/18 PVD [No C Review Farmers' privilege log for emails 1.00 0.00
03/09/18 PVD [No C ' Review production for correspondence 0.40 0.00
in rai , ;:ebruary 2011 re production of disc
03/09/18 PVD [No C f Reorganize files used from production 1.50 0.00
recci n Fowler White
03/10/18 SJL Revi v 8 transcript re rulings on how to treat 5.50 4,125.00
coat zy of documents; multiple e-mails (all day)
with f 'Jell and J. Scarola re same; work on ways
to re agreement; work on Emergency Petition
for C' work on joint letter to court re sealing
recor
EFTA00799123
Client Ref: 0002 - 0001 April 6, 2018
Invoice # 396 Page 13
Date Service. Hours Amount
03/10/18 KBR Legal r •-• rch regarding in camera review and 4.50 3,375.00
Petitio: Nrit of Certiorari; multiple emails with P.
Casse' ' 3carola, clerk of court and A.
Bormai. neral counsel for 15th Judicial Circuit;
review c line 15th circuit docket; review of Fourth
Distric' t of Appeal docket; revise Petition for
Writ of orari regarding grant of B. Edwards'
Motion eparate Trials (severance)
03/10/18 RJG Draft "! wound" section for Petition for Writ of 1.30 513.50
Certior :id revise petition to include trial court's
multip' .rences to J. Epstein's original proceeding
as bei :nesis" for B. Edwards' counterclaim
03/10/18 RJG Revir. s of Judicial Administration re sealing of 0.20 79.00
rector( Jpellate court
03/10/18 RJG Reviev. yze correspondence from non-party 0.20 79.00
intervel. ounsel re failure to caption them In filings
with th nth District Court of Appeal
03/10/18 MLP [No Ct; ' Conduct legal research re computation 0.40 0.00
of firm :ifically analyzing Florida Rule of Judicial
Admin. on 2.514, Florida Rules of Appellate
Procc :nd Florida appellate courts' opinions and
case arding the same in order to determine
the be! rse of action in terms of timing of the
briefin, :dule pursuant to the Fourth District Court
of Api: 3/9/18 order
03/11/18 TLC Work c ;embling documents to seal; prepare 8.50 1,912.50
Notict :npliance, Notice of Filing disc under
seal, . ;ice of Filing Exhibits under seal in order
to pre. Ippeltate record; work on cleaning up
heari: rs; review communications from P.
Casst J. Scarola and our responses; review
3/8/11 Apt
03/11/18 SJL Work :es relating to Stay Order and sealing 5.30 3,975.00
retort.: .k on Notice of Compliance; work on
Petitic ;ertiorari review
03/11/18 KBR Work :es rein:ing to Stay Order and sealing 1.20 900.00
recor 4 : on '-, g.": on for Certiorari review; follow
up w' inar. . , compliance with destruction of
docu ,
EFTA00799124
Client Ref: 0002 - 000' April 6, 2018
Invoice # 396 Page 14
Date Servie' . Hours Amount
03/12/18 RJG Final to Petition for Writ of Certiorari in 1.90 750.50
preps the Fourth District Court of
Appe. n",irence with partners re same
03/12/18 RJG Begin • - 'analysis of B. Edwards' Response to 2.60 1,027.00
emery nandamus petition
03/12/18 RJG Corree ince with opposing counsel re their 0.20 79.00
agree- unopposed motion to consolidate writ
petiti. ie Fourth District Court of Appeal and
revisi '•
03/12/18 RJG Revic , 'I .in D. Indyke re B, Edwards' 0.20 79.00
Respi mar lay ius petition in preparation for
filing i
03/12/18 RJG Revie 8 herring transcript in preparation for 0.30 118.50
draftir • ;0i'. Edwards' Response to mandamus
petit',
03/12/18 TLC Work m•; 'or UMC hearing re sealing 11.30 2,542.50
recor rr 'n's timeline and prepare
sums. roduction dates; prepare e-mail
to J. I mo• work on assembling appendix
items ..on or Certiorari review; work on
Petiti( ari Review and Motion to
Cons• n v 3. Edwards' Response to
Petiti. ;,.1 :ndamus and Motion to Lift Stay;
calct ,idnr deadlines relating to same;
work I tc Motion; prepare letter to Fourth
Distr ;. •' Clerk re same; continue
revie ,'s boxes in order to determine
chaii. ; and production by B.
Edwt- exhibits
03/12/18 SJL Prep. end hearing on proposed Order 9.50 7,125.00
seali 11 !S; follow up with J. Scarola on
prod. s . v, .: lc on Petition for Writ of
Ceri o. 'd Consolidate Petition for Writ
o
ℹ️ Document Details
SHA-256
17356e217620af04b1c1a59b99099f8b1c20b0d44e03af47d27bfb47a6fb40b9
Bates Number
EFTA00799106
Dataset
DataSet-9
Document Type
document
Pages
39
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