EFTA00602002.pdf

BURMAN, CRITTON, LUTTIER & COLEMAN LLP I. MICHAEL BURMAN. P.A.' A LIMITED LIABILITY PARTNERSHIP ADELQUI J. BENAVENIE GREGORY W. COLEMAN, PA. PARALEGAL I INVESTIGATOR ROBERT D. CRITTON, IR., PA) BERNARD LEBEDEKER BARBARA M. McKENNA MARK T. LUTHER, PA. ASHLIE STOKEN-BARING JEFFREY C. PEPIN DEITY STOKES MICHAELI. PIKE PARALFGLIG 5 HEATHER Mr..NAMARA RUDA May 8, 2009 RITA H. BUDNIfIC I FLORIDA BOARD LERIIII ED or COUNSEL CIVIL TRIAL LAWYER Sent by E-mail Only Jeffrey Epstein Dear Jeffrey: As per our discussion on April 20, 2009 and as we discussed, I am enclosing a revised fee agreement. The agreement Is changed to encompass all matters that have been filed against you, and as well has the "ever green provision" wherein we will keep $150,000 in our trust account at all times against our final bill. If you would like, I will send you a copy of the Trust Statement each month reflecting the monies being held. That is up to you. As we also discussed, I expect to be paid within two weeks of sending our bill. You correctly noted that our bills do not necessarily come within the first of every month. If you have questions about the bills, the time spent or any other aspect of the representation, give me a call and we can discuss it and resolve it quickly. With regard to Lisa, as I advised you, we do have some costs with Lisa being here and therefore as your accountant duly noted, we pay her $40 and charge her at $50 rather than $125 which we otherwise would charge for a paralegal. I use her to reduce costs to you, not as a profit center. I will probably need to keep her working in that all of Jessica's time would be eaten up with filing/indexing. Lisa also does subpoenas for us if she has time. We have many cases. You said we can have some fun and I agree. Cordially Roberto. Critton, Jr. RDC/clz Enclosures I•A•W• lf •E•R•S 515 N. FLAGU3R DRIVE I SUITE 400 / WEST PALM BEACH, FLORIDA 33401 TELEPHONE (561) 842-2820 FAX (561) 844-6929 mailebelclaw.com EFTA00602002  AMENDED REPRESENTATION AGREEMENT The law firm of Burman, Critton, Luttier & Coleman, LLP (hereinafter "Firm") will provide multiple representation of Jeffrey Epstein (hereinafter "client" or "you") in the following matter(s) or proceeding(s): cases or threatened lawsuits, claims against Jeffrey Epstein and the Firm and client agree to the following: Retainer Required From Client The client shall deposit $150,000.00 in the Firm's trust account, which amount shall remain in that account and used against final billing. If the bill exceeds the amount, the client shall pay the additional amount and if the bill is less than the amount in trust, the balance shall be returned to the client. Fees for which the Client is Responsible As reasonable attorney fees, the client agrees to pay the following sums: ■ $500 per hour for senior partners' time; ■ $300 per hour for senior associates' time; ■ $200-$250 per hour for junior associates' time; • $125 per hour for paralegal and investigator time. You will be charged for all attomey and paralegal time expended in connection with our representation of you, including but not limited to conferences, telephone calls, discovery, trial preparation, trial, review and drafting of documents, negotiations, research, court time and travel time. As well, you will be charged for any attorney and paralegal time expended to collect any funds, including fees and costs, from any other party. The hourly rates contained herein are subject to review and increase on an annual basis. In some instances, the Firm may be entitled to a Court awarded fee. Accordingly, you agree to pay a reasonable attorney fee as determined in accordance with this agreement or as awarded by the Court, whichever is greater. Costs for Which Client is Responsible In addition to the fees, it is agreed that you will be responsible for all court costs, investigation expenses, and any other costs or expenses incurred in the preparation and trial of your case. Such costs include, but are not limited to, filing fees, Sheriffs service and any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS when necessary, investigative costs, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs. The EFTA00602003 necessity of an expert shall be determined at our sole discretion. As well, you will be charged for any costs incurred if necessary to collect any funds, including fees and costs, from any other party. Monthly Billing Statement Sent to Client The client will be sent an itemized monthly billing statement which will include fees and costs for legal services rendered. The only way that we can provide you with legal services is for you to pay your fees and cost charges in a timely manner after receipt of your monthly billing statement. Any statement for services which remains outstanding for greater than thirty days from the date it is sent, shall accrue interest at the rate of 1.5% per month as to the outstanding balance. YOU AGREE TO CAREFULLY READ ALL BILLING STATEMENTS AND PROMPTLY NOTIFY US, IN WRITING, OF ANY CLAIMED ERRORS OR DISCREPANCIES, WITHIN FIFTEEN (15) DAYS FROM THE DATE OF THE STATEMENT. IF WE DO NOT HEAR FROM YOU IN WRITING, IT IS PRESUMED THAT YOU AGREE WITH THE CORRECTNESS, ACCURACY, FAIRNESS, NECESSITY AND REASONABLENESS OF THE BILLING AND SERVICES RENDERED. Right to Withdrawal; Fees Earned and Costs Expended Nonrefundable In fairness to all our clients, who are current, no lawyer in our office may continue working on a file in the event the previous billing statement has not been paid; and, in this event, we reserve the right to cease legal work and withdraw from the case, and the client hereby consents to said withdrawal. Funds which have been earned for legal services or which have been expended for costs are not refundable. Recovery of Settlement. Judgment or Otherwise on Your Behalf The Firm may receive money on your behalf from a settlement, judgment or otherwise. In such event, you authorize the Firm to deduct and retain from such monies any balance due the Firm for unpaid attorney fees and costs before disbursing the remainder of such monies to you. You will receive a full accounting, (or a "Closing Statement"), reflecting how the money received by the Firm was applied. Recovery of Fees and Costs from Other Party In the event the court requires the other party to pay attorney's fees and costs, this will not affect the amount you contract to pay pursuant to this agreement. In the event that money for attorney's fees and costs are actually paid to this firm by the other party, such sums will 2 EFTA00602004 first be applied to any amount owed by you and any balance will be reimbursed to you for amounts you previously paid to this firm. Legal Action to Collect Unpaid Fees & Costs In the event it becomes necessary to take any legal action, including any lien proceedings, to coiled fees and costs owed by you to this firm, you are agreeing to be responsible for reasonable attorney's fees and court costs, incurred in collecting same, including appellate fees, and you are also agreeing that Venue and Jurisdiction shall be the Fifteenth Judicial Circuit of Florida, in and for Palm Beach County, and the laws of the State of Florida shall apply. Entitlement to Charging & Retaining Lien for Unpaid Fees & Costs The client agrees that the Firm is entitled to a charging lien for attorney's fees and costs incurred, but not yet paid, by the client relating to any monies or property, real or personal, received through settlement, judgment or otherwise as result of the representation. As well, the client agrees that the Firm is entitled to a retaining lien for fees and costs due and owing in any other matter for which the client has retained the Firm for representation on any monies or property, real or personal, received through settlement, judgment or otherwise. The client further agrees that the Firm is entitled to retain from any such funds or property, reasonable attorney's fees and costs which may be incurred to assert and pursue its charging or retaining lien and to coiled on same. Right of Either Party to Terminate Agreement Either party may terminate this agreement at any time; however, if there are any outstanding fees or costs due this firm as of the date of the desired termination, said balance due shall be paid in full by the undersigned client forthwith. Upon full payment, the file will be transferred to the client or to an attorney of the client's choice. Modifications. Amendments. Deletions; Validitx Any deletions, modifications or amendments to this agreement must be in writing, and dated and signed by the client and the Firm. Deletions or modifications or amendments may be made to the document itself as long as such change is dated and initialed by the client and Firm. The invalidity or unenforceability of any provision or provisions of this agreement shall not affect the validity or enforceability of any other provision of this agreement, which shall remain in full force and effect. Miscellaneous Although this agreement may seem lengthy and detailed, experience shows that the lawyer and client relationship is enhanced when there is a clear understanding of the financial arrangements at the beginning of the relationship. 3 EFTA00602005 You acknowledge by the execution of this agreement that you are aware of the uncertainty concerning the outcome of litigation and that the Firm has made no guarantees in the disposition of any phase of this matter. All expressions relative to this matter are only expressions of the Finn's opinion and are not guarantees. * * r r* * * I understand and agree to the above terms and do hereby employ your services in accordance with said terms. id) 7$ DATED this g of , 2009. Jeffrey Epstein The employment is accepted in accordance with the above terms. Robert D. C ' ton, Jr. BURMAN, ITTON, LUTTIER & COLEMAN, LLP 4 EFTA00602006  Page 1 of I Connie Zaguirre From: Connie Zaguirre Sent: Friday, May 08, 2009 3:09 PM To: 'Jeffrey Epstein'; 'Darren Indyke' Cc: Robert D. Critton Jr. Subject: Epstein Matter - BCLC Invoice dated May 8, 2009 Attachments: 20090508150207001.pdf Enclosed please find BCLC Invoice #29879 dated May 8, 2009. Gonnzji. Zaguirre, CP, FRP Certi Paralegal Florida Registered Paralegal Assistant to Robert D. Critton, Jr. Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 561-842-2820 Phone 561-515-3148 Fax czacluirreAbdclaw.com 5/8/2009 EFTA00602007  LAW OFFICES OF BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 NORTH FLAGLER DRIVE SUITE 400 WEST PALM BEAC H, FLORIDA 33401 May 08, 2009 Darren K. Indyke, Esq. 301 East 66th Street, Ste. 10B New York, NY 10065 INVOICE Matter ID: 2008-029 Client ID: 3371 EPSTEIN, JEFFREY Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: for medical providers 4.00 hr $200.00 03/26/2009 LG Prepare remaining Subpoena for Deposition Duces Tecum ch online correc t addres ses for medical and Notices for Depositions; resear provid ers; memo to file Tecum for employment 3.00 hr $150.00 03/29/2009 LG Prepare Notices and Subpoenas for Deposition Duces yer addres ses; schedule depositions; records; research online for correct emplo review corresponde nce and e-mail s; file same ffs Interrogatories; memo to 5.00 hr $250.00 03/30/2009 LG Scan and e-mail Motions to Compel Answers to Plainti to counsel; review to Stay; memo counsel; scan and e-mall Defendant's Motion pleadin gs l fi e indexe s; open 3rd volume pleadings and organize pleadings; update files; file pleadings; memo to BM 3.00 hr $1,500.00 04/01/2009 RDC Continued preparation for hearing 0.20 hr $100.00 04/01/2009 RDC Telephone conference with Jack G re: Bob J with Jack 2.10 hr $1,050.00 04/01/2009 RDC Hearing with Marra; conference with Brad; conference conference with Joe G; 1.10 hr $550.00 04/01/2009 RDC Conference with Pike and JMB re: discovery; telephone e-mails 0.10hr $50.00 04/01/2009 RDC Telephone conference with Sid re: hearing 0.70 hr $350.00 04/01/2009 RDC Tolling Agreement and e-mails 0.10hr $50.00 04/01/2009 RDC Receipt and review BB - Request for Copies finalize case law and 4.20 hr $1,260.00 04/01/2009 MJP Prepare for and attend hearing on Motion to Dismiss, research cases excluding personal injury damag es under RICO prepar letter to Garcia; fax; call e 5.75hr $718.75 04/01/2009 BM Receipt of fax from Garcia on new filing of Doe II; to Garcia's office; online search of Pacer; print Compl aint, Subpoenas. two Interro gatory Answe rs and copy as Exhibi ts to Motions to Compel on Orders, pull Doe #2 through 7; finalize Motion s to Compe l Respo nses to Request to Produce put in specific language from and Answers to interrogatories in Doe #2 through 7; Responses and Answers served on Jane Doe 1.20hr $360.00 04/01/2009 MJP Drafting Motion to Compel Better Answer to Interrogatories ) 0.30hr $90.00 04/01/2009 RHB Draft letters to Mermelstein • tax returns - (JD No.5-7 7.1; conference to work 0.30hr $90.00 04/01/2009 RHB Telephone call to Attorney Jack Hill (CMA) regarding Rule out discovery Issues Produce and 1st Set of 4.40hr $1,320.00 04/01/2009 RHB Draft Motions (2) to Compel directed to 1st Request to Interrogatories Critton 0.50hr $250.00 04/01/2009 JMB Review all recent e-malls; conference with Robert e additional 2.10hr $262.50 04/01/2009 BM Calls from and to School Board Palm Beach County and provid from Dr. Jorge; Spearm int Rhino; call information on several Plaintiffs; call from Page 1 EFTA00602008 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: Dr. Jorge re: BB; receipt call from Quartell; call from Cheetah; receipt of fax from ality re: EW employ ment at Spearm int Rhino; receipt of of fax from WPB Hospit of records received per update charts medical records from Quartell Chiro on BB; subpoenas $600.00 e-mail 1.20 hr 04/02/2009 RDC Hearing on Transfer and conference with Sid rell.; Motions (x7); review Order re: 1.10 hr $550.00 04/02/2009 RDC Conference with Rita re: Motions to Compel; review hearing; e-mails re: tolling 0.80 hr $400.00 04/02/2009 RDC Complete Answers in JD 2-7 0.90 hr $450.00 04/02/2009 RDC Draft Answers to EW & LM and responses needed 1.10 hr $550.00 04/02/2009 RDC Continued work re: cases and what is outstanding 0.70 hr $350.00 04/02/2009 RDC Letter re: Sid #2; Motion for Sanctions re: discovery 0.40 hr $200.00 04/02/2009 RDC Letter to Sid re: new Federal and directions; to do letter to Jack and 0.60 hr $300.00 04/02/2009 RDC Telephone conference with Jack Hill re: Caddy and demand; letter to Caddy re: video settlement of Skye; e-mails 0.50 hr $250.00 04/02/2009 RDC Telephone conference with Bob J. re: Agreement and 's video 0.10hr $0.00 04/02/2009 RDC Receipt and review Hill's April 1 letter enclosing Dr. Caddy gs and Response to RTP with 6.80 hr $850.00 04/02/2009 BM Scan and pdf Motions to Compel Answers to Interro of Southern District; attachments in Doe v. Epstei n; file electro nically with Clerk l directe d to Doe #2 through conference with RHB and RDC re: Motions to Compe Exhibits to attach; 13 Motion s to Compe l; pull and copy 7 and CMA; scan and pdf s electronically scan and pdf all Exhibits to 13 Motions to Compe l; file all Motion Distric t; confer ence with RDC re: Motion s for Protective with Clerk of Southern for Protec tive Order; for Motion s Order; search Southern District docket sheets receip t of 16 s for Protec tive Order to JG, JE and DI; print; scan and pdf Motion ments e-mails from Southern District Cleric's office; print all attach 0.60 hr $300.00 04/02/2009 ROC Conference with Joe G. l Court Motions to 0.25 hr $75.00 04/02/2009 RHB Conference with legal assistant regarding filing of Federa Compel and Exhibits regarding tax returns 0.10 hr $30.00 04/02/2009 RHB Review correspondence from Mermelstein (JD Nos. 2-7) on 5th Amendment (E.W.) 0.50 hr $150.00 04/02/2009 RHB Review Plaintiffs Response to Motion to Quash based 0.20 hr $60.00 04/02/2009 RHB Review Motion to Quash (EW) in EW Response to Motion 0.20 hr $60.00 04/02/2009 RHB Draft memo/e-mail cover regarding issues to address to Quash 2.50 hr $1,250.00 04/02/2009 JMB Continue analysis and review of investigative materials 0.20 hr $100.00 04/03/2009 RDC E-mails re: Saige 4.50hr $2,250.00 04/03/2009 RDC Prepare for and conference with Joe G, client, etc. 0.80 hr $400.00 04/03/2009 RDC Memo and list re: punitive damage issues 0.10 hr $50.00 04/03/2009 RDC Review and sign Tolling Agreement Stip and depo 0.90hr $450.00 04/03/2009 RDC E-mails and review documents from Jack Hill and review re: 0.10 hr $50.00 04/03/2009 RDC Receipt and review BB medical records print attachments; scan and 2.25hr $281.25 04/03/2009 BM Receipt of six e-mails from Clerk of Southern District; for JDII in Federa l; scan and pdf JDII Order on Scheduling pdf new Complaint Compl aint and Order to JO, JE and DI; Report and Discovery; diary dates; send pull and copy severa l docum ents for Guasta ferro 0.50 hr $62.50 04/03/2009 BM E-mail all Motions to Compel and Exhbits to JG, JE and DI 0.40 hr $50.00 04/03/2009 BM Update deadlines chart; copy for RDC. RHB, JMB and Lisa t checks from Call to Palm Beach Copy Service with instructions; reques Page 2 EFTA00602009 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: of letter from Diamond 2.75hr $343.75 04/03/2009 BM bookkeeping; receipt of letter from Abiding Hearts; receipt and Goldberger, Gold; fax letter to Caddy Entertainment; calls from and to Solid Goldbe rger; from Copy Servic e; send DVDs to Caddy and receipt of DVDs CME for 4110/09 to Caddy 's office; confirm ACs conference with RDC re: AC; call ent to receip t of fax from Podhu rst; fax Tolling Agreem at Caddy's office; Josefsberg and Goldberger; open several files Gustaferro; prepare for 1.80 hr $900.00 04/03/2009 JMB Conference with Robert Critton; review materials for conference and Gustaferro 2.50 hr $1,250.00 04/03/2009 JMB Conference with client, Robed Critton, Jack Goldberger of treatise re: sexual assault 1.80 hr $900.00 04/05/2009 RDC Review research and notes re: punitive; read portions 0.40 hr $200.00 04/06/2009 RDC E-mails re: # of topics and LM 0.90 hr $450.00 04/06/2009 RDC Conference re: motions (x4) and revise answers in EW na and letter to Bob J 0.70 hr $350.00 04/0612009 RDC Review dosing papers with Patrick and revise subpoe Tolling 0.70hr $0.00 04/062009 RDC Receipt and review Josephsberg April 3rd letter with signed g; AC.CMA - Hills' April Agreement;BB- Kuvin's April 3rd letter and Notice of Hearin Change of Firm and -Notice of 2 letter with Stipulation re: Epstein de . address; Bethesda's April 2 letter re: deadlines; conference 3.60 hr $450.00 04/06/2009 BM Receipt of four Unopposed Motions for Enlargement; diary int Rhino; receipt of with RDC on several issues ; calls from Cheeta h and Spearm from Dr. Jorge; void medicals from Dr. Ira Warshaw on BB; receipt of check Dr. Toufan ian re: destro ying records; cell to check; telephone call from g Hearts re: Jane Doe; calls Parent-Child Center re: Jane Doe; fax from Abidin EW; conference with EW; letter from Diamo nd Dolls re: from and to Solid Gold re: update hearing Lewis Order, MJP re: Motions for Extension; pull and copy Judge folders for tomorrow s 0.20 hr $60.00 04/0612009 MJP Meeting with R. Griffon, Esq. regarding upcoming motion , telephone conference 1.20 hr $360.00 04/06/2009 MJP Draft Four Motions for Extension of Time in Federal Cases with opposing counsel regarding same General Release; add 2.10 hr $262.50 04/06/2009 BM Scan and pdf Tolling Agreement to JO, JE and DI; revise nal call from Parent -Child Center; call from Josefsberg's clients to chart; additio Supply re: EW record s in Texas; update record s chart; copy Sally's Beauty to Respond to 3. 4 & 7 Motion s for Extens ion settlement; scan and pdf Doe #2, Southern District Orders ; file Motion s for Extens ion electro nically with Protective Clerk; e-mails from Clerk; print attachments; note to Lisa 0.50 hr $250.00 04/06/2009 JMB Conference with Robert Craton motions, and current 0.50 hr $250.00 04/06/2009 JMB Review updated victim chart, all current e-mails and deposition schedule 1.00 hr $500.00 04/08/2009 JMB Commence review of punitive damage issues ds re: settlement issues and 1.30 hr $650.00 04/07/2009 RDC Prepare for and attend 2 hearings; talked with Edwar discovery $150.00 0.30 hr 04/07/2009 RDC E-mails conference with JMB re: 1.701w $850.00 04/07/2009 RDC To do; conference with Pike re: motions/responses; punitive; Motion to Transfer cases 1.50 hr $750.00 04/07/2009 RDC Conference with JE rs to Interrogatories and 5.80 hr $1,740.00 04/07/2009 MJP Drafting Motions to Compel in LM regarding Better Answe with R. Critton , Esq.. regard ing same, letter to B. Requests for Production, confer lly set hearings ing specia Edwards regarding same, and memo to file regard Orders; go through filing 1.25 hr $156.25 04/07/2009 BM Receipt of four e-mails from Southern District Clerk; print Reporter confirming ; severa l e-mails from Court and notes to Lisa; update charts depositions; send Joe G. deadllines Chad $275.00 of EW, LM and Jane Doe; 2.20 hr 04/07/2009 BM Prepare and fax letter to Brad Edwards re: depositions Page 3 EFTA00602010 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: ferro with attachments; go over lists with RDC; several e-mails to and from Guasta Duffy's ; receipt of record s fun Wellin gton Regional; receipt receipt of records from Supply; request from Sally's Beauty of records from Mary Littlefield; receipt of fax payment from bookke eping to Welling ton Region al punitive damages 3.00hr $1,500.00 04/07/2009 JMB Review Statutes; Rules, Briefs, Cases, etc., regarding e damages 1.50 hr $750.00 04/07/2009 JMB Initial draft of outline/guidelines regarding defense of punitiv ery in federal court 2.00 hr $590.00 04/08/2009 BL legal research re: punitive damages and net worth discov Hafele; 0.60 hr $300.00 04/0812009 RDC Telephone conference from Jack Hill; a-mails re: A.0 and Judge conference with Pike re: motion s Josefsberg; fax Josefsberg 2.10 hr $262.50 04/08/2009 BM Call from RDC; conference with MJP; prepare letter to l; Westlaw research and Goldberger; pull and copy Exhibit A to Motion to Compe Compe l Better Answe rs to Interro gs with attachments for case; print; fax Motion to send to JG, JE and DI; scan In LM to counsel; scan and pdf Motion to Compel and send to JO, JE and DI; confer ence with Lisa re: and pdf letter to Josefsberg and ferro; copy Motion and filing and opening files; several e-mails to and from Guasta Exhibits for hearing folder, fil e origina l Motion with Clerk 0.20 hr $60.00 04/08/2009 MJp Telephone conference with S. Kuvin 0.20 hr $60.00 04/08/2009 MJP Telephone conference with R. Critton, Esq., regarding Compel Request to produce 1.50hr $450.00 04/08/2009 MJP Drafting Motion to interrogatories in LM and Motion to ence with B.M.; file 6.00 hr $300.00 04/08/2009 1.0 Review e-mails; review correspondence and pleadings; confer pleading mails; review and organi ze pleadin gs; update correspondence and e- Indexes; open Deposition Duces Tecum files research on the punitive 1.00 hr $500.00 04/08/2009 JMB Conference with Bernard Lebedeker; review additional damage issue 0.40 hr $200.00 04/08/2009 JMB Final draft of punitive damage memo 0.50 hr $250.00 04/08/2009 JMB Conference with Robed Critton Compel Request to Produce 1.50hr $450.00 04/08/2009 MJP Drafting Motion to Interrogatories in BB and Motion to Compel Request to Produce 1.50hr $450.00 04/08/2009 MJP Drafting Motion to Interrogatories in EW and Motion to ing motions 0.201w $60.00 04/08/2009 MJP Meeting with R. Critton, Esq., regarding case and upcom es 0.20 hr $60.00 04/08/2009 MJP Meeting with M. Burman regarding case and punitive damag nses to RTP in LM; fax 5.60 hr $700.00 04/08/2009 BM Pull and copy Exhibits to attach to Motion to Compel Respo pull and copy Exhibits to attach to counsel; scan and pdf Motion to JG, JE and DI; Answe rs to Interro gs and Motion to Compe l Responses to RTP Motion to Compel counsel; scan and and Motion s in EW; prepare letters for both Motions; fax letters to attach to Motion s to JG, JE and Dl; pull and copy Exhibi ts pdf letters and Motion l; fax letter and to Compel Answers to Interrogs to BB; prepar e letter to counse scan and pdf letters Motion to JG, JE and Dl; receip t of fax from Motions counsel; Clerk; print Order on Dr. Hearing on BB; receipt of e-mail from Southe rn Distric t g; reques t check for Dr. Hearin g record s Doe v. Epstein hearin Affidavit; a-mails 1.10hr $550.00 04/09/2009 RDC Telephone conference with Hill re: AC and CMA; Motion for Protective 0.90 hr $450.00 04/09/2009 RDC Work on summary - pending and to do; conference re: Order/consolidate depo 4/13 -BB 0.50 hr $250.00 04/09/2009 RDC Motion for Protective Order/Quash re: Yellow Cab 0.30 hr $150.00 04/09/2009 RDC Read Gustaferro's e-mail 1.30 hr $650.00 04109/2009 RDC Conference with JE 0.20 hr $100.00 04/09/2009 RDC Conference with Jack Hill re: resolution Saige 0.10 hr $50.00 04/09/2009 RDC Letter/memo to Marty re: Saige release June 26 - BB 0.10 hr $0.00 04/09/2009 RDC Receipt and review Order Specially Setting earing on Page 4 EFTA00602011 Matter ID: 2008.029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: settlement documents; 2.80hr $350.00 04/09