EFTA00614402.pdf

LAW OFFICES OF BURMAN, CRITTON, LUTTIER & COLEMAN, LIP 515 NORTH FLAGLER DRIVE SUITE 400 WEST PALM BEACH, FLORIDA 33401 April 06, 2009 Darren K. Indyke, Esq. 301 East 66th Street, Ste. 10B New York, NY 10085 INVOICE Matter ID: 2008-029 Client ID: 3371 EPSTEIN, JEFFREY Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/01/2009 RDC Read e-mails re: Bob J. and sent e-malls; prepare for conference and conference 320 hr $1,600.00 with JE 03/02/2009 JMB Review Non-Prosecution Agreement and related documents; review Josefberg 1.00 hr $500.00 letter and all related e-mails regarding settlement, payment, etc. 03/02/2009 RDC Review and send e-mails 0.30 hr $150.00 03/02/2009 RDC Prepare for two hearings - Yellow Cab A.C. and Interrogatory #19 - 1.10hr $550.00 03/02/2009 RDC Revise Response to Request for Production 1.40 hr $700.00 03/02/2009 RDC Review e-mails and to do 0.30 hr $150.00 03/02/2009 BM Receipt of Second Amended Complaints from Clerk's office for Doe #2 through 7; 1.10hr $137.50 print attachments; e-mails to and from RHB; diary deadlines to respond: pull and pdf Motion for Extension: note to RHB 03/03/2009 MJP Meeting with R. Budnyk regarding RICO 0.30 hr $90.00 03/03/2009 JMB Conference with Robert Critton a40 iv $200.00 03/03/2009 RDC Attend two hearings and A.G.); conference with Sid 1.60 hr $800.00 iM 03/03/2009 RDC Memo to all 0.40 hr $200.00 03/0312009 RDC Conference with JMB and Rita re: new Complaints x6 plus court ruling plus new 0.90hr $450.00 Motions to Compel to JE, etc. 03/03/2009 RDC Telephone conference; revise motion 0.30 hr $150.00 03/03/2009 RHB Review multiple e-mail correspondence from client and counsel 0.40 hr $120.00 03/03/2009 RHB Respond/forward e-mails re: Federal Motion for Stay 0.20 hr $60.00 03/03/2009 RHB Conference(s) with RDC and JMB re: case status, priorities and strategy 0.30 hr $90.00 03/03/2009 RHB Conference(s) with legal assistant re: Amended Complaints in Jane Does 2-7: 0.30 hr $90.00 Motion to Compel, deadlines 03/03/2009 RI-IB Draft Motion for Extension of Time to file Motion to Compel Jane (S.R.) 0.25hr $75.00 03/03/2009 RHB Review Motion for Rehearing re: discovery, employment history; legal research; 1.20 hr $360.00 revise otion 03/03/2009 RHB Conference(s) with RDC re: discovery, Motions to Dismiss 0.25 hr $75.00 03/03/2009 RHB Review correspondence in Federal cases re: discovery 0.50 hr $150.00 03/03/2009 RHB CMA. begin preparing; legal research re: Motion to Dismiss 1st Amended 0.60hr $180.00 Complaint 03/03/2009 BM Conference with RHB; copy Amended and Second Amended Complaints In #2 2.30 hr $287.50 through 7 for RDC and RI-IB; scan and pdf Amended and Second Amended Page 1 EFTA00614402 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: Complaints and e-mail to JG, JE and DI; receipt of Notice of Striking Docket Entry 17 in Doe #6; print attachment; receipt of e-mails from Clerk's office with Motions to Compel with attachments in #2 through 5; print all docket entries; copy Motions only for RHB; note to RDC re: copies; scan and pdf Motions to Compel In #2 through 5; e-mail to JO, JE and DI; notes to Lisa 03/03/2009 LG Review Plaintiffs family records for evidence of child custody; memo to file; review 5.00 hr $250.00 correspondence and pleadings; search county and federal records for document numbers; update pleading file indexes and file pleadings and correspondence 03/03/2009 RDC Receipt and review AC and CMA Notice of Cancelling Epstein's deposition 0.20 hr $0.00 03/04/2009 BM Conference with RHB re: Motions for Extension to file response to Amended 2.25 hr $281.25 Complaints in Doe #2 through 7; check local for time to file issues; conference with RDC re: fax from DI; e-mails to and from DI; prepare six Motions for Extension #2 through 7; note to RDC re: calling Hermelstein; conference with RHB on Orders; prepare 6 Orders 03/04/2009 JMB Conference with Robert Critton regarding case strategy, discovery, etc. 0.20 hr $100.00 03/04/2009 JMB Review discovery responses of additional plaintiffs 1.50 hr $750.00 03/04/2009 BM Conference with RDC; add Local Rule 7.1 language to six Motions for Extension in 2.60 hr $325.00 #2 through 6; scan and save pdf six motions and orders; scan and save pdf Motion for Extension and Order in Doe (SR) re: discovery issues; receipt of seven e-mails from Clerk's office; print all confirmations and attachments; update deadlines on task list; conference with RDC re: Opinions on 2 through 7; pull and copy; note to Lisa re: filings; note to JMB re: meeting with JE; search for Statute of Limitations memo; pull research on offers for settlement/offers of Judgment for RDC to review; scan, pdf and send Statute of Limitations memo to JE, JG and DI 03/04/2009 RDC Telephone conference with Stuart re: extensions on JD 2-7; review motions 0.30 hr $150.00 03/04/2009 RDC Conference with JMB 0.20 hr $100.00 03/04/2009 RDC Telephone conference with Jack; organize to do and sort through 3 days of faxes, 2.80 Iv $1,400.00 mail, pleadings 03/04/2009 RDC Begin preparing for hearings on EW and LM 0.90 hr $450.00 03/04/2009 RI-IB Conference(s) with legal assistant re: Amended Complaints; Jane Doe 2-7; draft 0.40 hr $120.00 Motion for Extension of Time re: good cause 03/04/2009 RHB Conference(s) with re: RDC re: CMA, Statute 2255 0.20 hr $60.00 03/04/2009 RHB Review e-mail correspondence 0.10hr $30.00 03/04/2009 RHB Legal research; draft Motion to Dismiss Amended Complaint - CMA 1.20 hr $360.00 03/04/2009 RHB Jane Doe 2.7, continue work on Motions to Compel 1.30 hr $390.00 03/04/2009 RI-IB Review numerous e-mail correspondence on Statute 2255 0.50 hr $150.00 03/04/2009 RDC Receipt and review Re-notice of Epstein's deposition on March 19, 2009 0.10hr $0.00 03/05/2009 BM E-mails from Story and Jessica; print attachments for RDC to review; index and 0.90 hr $112.50 open file on discovery from Garcia-Doe II; copy Chapter 95 from Statutes for RDC 03/05/2009 JMB Conference with Robert Critton and Rita Budnyk regarding 2255 issues, etc. 1.00hr $500.00 03/05/2009 JMB Review statutes and law regarding 2255 Issues 1.00 hr $500.00 03/05/2009 JMB Conference with Robert Critton regarding Proposals for Settlement; claim 1.00hr $500.00 analysis, etc. 03/05/2009 JMB Conference with client and Goldberger 2.00hr $1,000.00 03/05/2009 BM Conference with RHB; prepare Motions for Extension to Respond to Motions to 2.30hr $287.50 Compel #2 through 5; prepare proposed Orders; conference with RDC; search #6 and 7 for discovery; memo to Lisa; update task list 03/05/2009 MJP Meeting with R. Critton, Esq., and J. M. Burman, Esq., regarding proposals and 0.90 hr $270.00 confer regarding research regarding proposals for settlement Page 2 EFTA00614403 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/05/2009 RDC Many e-mails re: 2255; Conference with Rita and Mike on same 2.10 hr $1,050.00 03/05/2009 RDC Telephone conference with Dr. Caddy and letter re: video 0.50 hr $250.00 03/05/2009 RDC Letter re: depos 0.20 hr $100.00 03/05/2009 RDC Conference with Rita re: SOL, 2422 and 2255 issues 0.50 hr $250.00 03/05/2009 RDC Finish SG documents; prepare for conference with JE; conference with JMB; 4.50 hr $2,250.00 conference with client 03/05/2009 RI-IB Conference(s) with RDC re: CMA Statute 2255 Issues (multiple conferences) 0.60hr $180.00 03/05/2009 RI-IB Telephone call to and telephone calls from Adam Horowitz re: Jane Doe 2-5; • 0.20 hr $60.00 extension Motions to Compel 03/05/2009 RHB E-mail correspondence to Horowitz (7.1) 0.20 hr $60.00 03/05/2009 RHB Draft Motions for Extension of Tune; respond to Motion to Compel Jane Doe 2-5 0.40 hr $120.00 03/05/2009 RHB Review e-mail correspondence re: Statute 2255 arguments 0.30 hr $90.00 03/05/2009 RHB Review CMA 1st Amended Complaint re: analysis for Motion to Dismiss 0.70 hr $210.00 03/05/2009 RHB Legal research and review case law on 18 U.S.C. Statute 2265 1.00 hr $300.00 03/05/2009 RHB Begin draft of Motion to Dismiss CMA's 1st Amended Complaint 1.10 hr $330.00 03/05/2009 RDC Prepare for hearing in LM & EW; read plaintiffs response and cases re: EW & LM 1.80 hr $900.00 for hearing 03/05/2009 LG Review correspondence, e•mails and pleadings; search county and federal court 5.00 hr $250.00 records for correct docket numbers; update pleading indexes; file documents; confer with RDC re; interrogatories, Amended Complaints; review and compare complaints with Amended Complaints; mark discrepancies; memo to file 03/05/2009 MJP Research and analysis of case law regarding state proposals for settlement and 4.70 hr $1,410.00 particularity requirements, research and analysis of case law regarding attached Releases to Proposals for Settlement, meeting with R., Critton, Esq., regarding upcoming hearing on Motion to Dismiss 03/06/2009 JMB Review NPA Orders, etc. 0.40 hr $200.00 03/06/2009 RDC Finish prep for hearing on RICO; e-mails and conference regarding LM & EW 2.80hr $1,400.00 03/06/2009 RDC 2 Proposed Orders; letter re: motions; letter to Brad re: depo and special sets 0.70 hr $350.00 03/06/2009 RDC Motion to Compel Video for Caddy; e-malls 0.50 hr $250.00 03/08/2009 RHB Continue legal research and draft of Motion to Dismiss CMA 1st Amended 4.25 hr $1.275.00 Complaint 03/06/2009 BM Scan and pdf Motions for Extension to Respond to Motions to Compel and Orders 1.20 hr $150.00 in #2 through 5; conference with RHB; file Motions and Orders electronically with Clerk; receipt of four e-mails from Clerk; print attachments 03/06/2009 BM Go through mall and update tasks prior to providing to Llsa 0.50 hr $62.50 03/06/2009 RDC Receipt and review EW and LM Edward's letter to Judge French: AC- Plaintiffs 0.30 hr $150.00 Amended Response to Request to Produce and AC - Plaintiffs Amended Answers to Interrogatories 03/08/2009 RI-1B Continue legal research and draft of Motion to Dismiss CMA 1st Amended 1.75 hr $525.00 Complaint 03/09/2009 MJP Research regarding Federal and State proposals for settlement, review areas of 2.50 hr $760.00 conflict, review issues concerning validity, confer with Critton regarding same 03/09/2009 JMB Conference with Robert Critton; conference with Rita Budnyk; review draft of 1.00 hr $500.00 Motion to Dismiss CMA First Amended Complaint 03/09/2009 RDC Revise all proposals and letters to all (x 13) 1.90 hr $950.00 03/09/2009 ROC Telephone conference with Jack Hill 0.10hr $50.00 Telephone call from Caddy Page 3 EFTA00614404  Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/09/2009 ROC 0.80 hr $400.00 03/09/2009 RDC Telephone call from Jack G. 0.20hr $100.00 03/09/2009 RHB Complete first draft of Motion to Dismiss CMA's 1st Amended Complaint 2.60 hr $780.00 03/09/2009 RHB Review e-mail correspondence from client 0.10 hr $30.00 03/09/2009 RHB Draft memo on const. law arguments 0.25 hr $75.00 03/09/2009 LG Review Opinion and Orders on Motion to Dismiss and compare; memo to file; 5.00 hr $250.00 review Motions to Compel and mark discrepancies; memo to file; review correspondence, pleadings and e-mails; file correspondence and a-mails 03/10/2009 RDC Telephone call from Sid and e-mail 0.30 hr $150.00 03/10/2009 RDC Review AC and EW motions/responses re: 5th Amendment 0.50 hr $250.00 03/10/2009 RDC Complete Motion for Videotape (AC) and Caddy Affidavit 0.80 hr $400.00 03/10/2009 RDC Motion for Additional Time to Complete Examination (AC); prepare additional 0.90 hr $450.00 Affidavit for Caddy 03/10/2009 JMB E-mail to Jack Goldberger, Esq. 0.10 hr $50.00 03/10/2009 RDC Review CMA Motion plus suggestions; conference with JMB and Rita re: thoughts 0.80 hr $400.00 03/10/2009 RHB Conference(s) with RDC and JMB re: CMA's Motion to Dismiss 0.40 hr $120.03 03/10/2009 RHB Review CMA Motion to Dismiss (per RDC) 0.30hr $90.00 03/10/2009 RHB Draft e-mail correspondence to counsel and clients with attachments (C.M.A.) 0.30 hr $90.00 03/10/2009 RHB Review of Motions to Compel in Jane Does 2-5 0.75 hr $225.00 03/10/2009 RI-IB Legal research and draft response to Motions to Compel (Jane Doe 2-5) 2.10 hr $630.00 03/10/2009 JMB Review brief drafts, e-malls regarding same, statutes, conference with Rita 1.80 hr $900.00 Budnyk and Robert Critton regarding Motion to Dismiss CMA Amended Complaint 03/10/2009 RDC Revise Saige closing documents; letter to Spencer; telephone conference with 0.60 hr $300.00 Robson's attorney: e-mall 03/10/2009 RDC Receipt and review AC - Jack Hill's March 6 letter that Plaintiff will not produce 0.10 hr $50.00 video 03/11/2009 RDC E-mails and re-read NPA re: Sid Issues 0.30 hr $150.00 03/11/2009 RHB Telephone conference with Ami Sheth, Martin Weinberg; review and follow-up on 1.50 hr $450.00 numerous e-mails re: C.MA. Motion to Dismiss 03/11/2009 RHB Conference(s) with JMB and RDC re: Motion to Dismiss C.M.A. Complaint 0.60 hr $180.00 03/11/2009 RI-IB Draft and legal research re: Motion to Dismiss 1st Amended C.M.A. Complaint 4.30 hr $1.290.00 (includes review of case and statute law) 03/11/2009 JMB Review additional memos, cases and Statutes; conference with Rita Budnyk 1.60 hr $800.00 regarding discovery Issues 03/11/2009 BM Review filing prior to providing to Lisa; diary deadlines for proposals for settlement 0.60 hr $75.00 03/12/2009 RDC Telephone conference with Rita, Jack; read e-mails; read and revise 2255 CMA 1.70hr $850.00 memo 03/12/2009 RDC Revise template subpoena for work. med and school; review JD #2 -7 Marra 0.80 hr $400.00 orders 03/12/2009 RDC Finalize Motion for Viewo and Motion for Addition& Time; review cases re: work 0.90 hr $450.00 product 03/12/2009 RDC Review A.C. Amended Answers and Responses 0.30 hr $150.00 03/12/2009 RDC Notes to Rita re: Motion to Compel to JE re: JD #2.6; review memos and our 0.80 hr $400.00 objections 03/12/2009 WP Research regarding discoverability of CME's and confer with R. Critton, review 3.30 hr $990.00 and analysis of case law regarding discoverability of tapes, photos and videos Page 4 EFTA00614405 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: outside of the CME realm, confer with R. Critton, Esq., regarding same, review Fla. Bar articles re: same 03/12/2009 BM Revisions to Subpoena to Employer and Subpoena to Board of Education; print 1.40 hr $175.00 prior Subpoenas for RDC to review, conference with RHB re: Motion to file; call to RHB re: Subpoena Confidentiality language; scan and pdf Motion to Dismiss In CMA case; file with Clerk; receipt of e-mail from Clerk; print attachments 03/12/2009 BM Conference with RDC on procedures for Subpoenas; revisions to Subpoenas; 0.40 hr $50.00 copy for each case; call to RHB re: instructions; pull Doe #2 pleadings; research Pacer for Orders on Doe #2-5 re: Motions to Compel; confirm task deadline with RDC 03/12/2009 RHB Conterence(s) with JMB and RDC re: finalizing C.M.A. Motion to Dismiss 0.75 hr $225.00 03/12/2009 RHB Finalize and revise Motion to Dismiss C.M.A. 1st Amended Complaint (add case 2.25 hr $675.00 and statute law) 03/12/2009 RHB Telephone call to Attorney Marty Weinbert re: Statute 2259 Mandatory restitution 0.20 hr $60.00 provision 03/12/2009 RHB Telephone call from Anil Sheth 0.10hr $30.00 03/12/2009 JMB Review final draft of Motion to Dismiss and Brief; conference with Rita Budnyk 1.10hr $550.00 03/12/2009 LG Scan Motions to Compel; e-mail to counsel; search federal and county court 5.50hr $275.00 records; update pleading indexes; file correspondence and e-malls; open files and experts 03/12/2009 RDC Receipt and review Hill's March 11 letter to Judge Garrison re: 5/05/09 hearing 0.10 hr $50.00 03/13/2009 BM Receipt of several e-mails from Clerk's office; scan and pdf three Orders to JG, JE 0.60hr $75.00 and Dl; copy School, Employment and Medical Subpoenas into all 13 cases for editing 03/13/2009 RDC Conference with Rita; work on Motions and discovery 1.40 hr $700.00 03/13/2009 RDC Order re: Rico; letter; reviewed transcript 0.20 hr $100.00 03/13/2009 RHB Draft and legal research re: response in opposition to Motion to Compel Jane 3.20 hr $960.00 Does 205 03/15/2009 MJP Weekend strategy meeting with Ft Critton, Esq., regarding discovery, Motions to 2.00 hr $600.00 Transfer. 5th Amendment and getting up to speed with files 03/15/2009 MJP Review and analysis of EWs Motion to Quash 0.40 hr $120.00 03/15/2009 MJP Review and analysis of AC's Motion in Limine and case law cited therein 0.60hr $180.00 03/15/2009 BM Conference with RDC and MJP on several Issues 3.50 hr $437.50 03/15/2009 BM Copy Memos for MJP to review, pull AC pleadings for MJP to review; update 0.60 hr $75.00 deadlines schedule; e-mail Goldberger re: depositions 03/16/2009 BM Conference with RHB, MJP and RDC; prepare deposition charts; call from 2.75 hr $343.75 Goldberger's office re: depositions; prepare list of deadlines on court filings and hearings; conference with RHB re: CMA extension; check SR file to confirm extension; calls to and from Hills office; calls to VVililits' office; conference with RDC re: BB hearing; on-line search for standing orders on Circuit Judges; prepare letters to Judge Hafele and Judge French to obtain standing orders 03/16/2009 BM E-mail from RHB; finalize Motion for Extension on CMA; prepare Order on 0.60 hr $75.00 Extension; scan and pdf Motion and Order; file electronically with Southern District Clerk; receipt of e-mail from Clerk print attachment 03/16/2009 MJP Telephone conference with J. Hill, Esq. 0.10 hr $30.00 03/16/2009 RDC Prepare for hearing with Bobble and Pike re: Motions, discovery, etc. and meeting 2.30 hr $1,150.00 03/16/2009 RDC Review and revisions to transfer motions; conference with Pike 0.30 hr $150.00 03/16/2009 ROC Telephone conference with Jury Consultant - Joe; Conference with JMB 0.60 hr $300.00 03/16/2009 RDC Receipt and review Order Specially setting Hearing on April 24 0.10 hr $50.00 Page 5 EFTA00614406 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/16/2009 MJP Getting up to speed on files as per RDC and meeting with R. Critton, Esq., B. 4.40 hr $1.320.00 McKenna and R. Budnyk 03/16/2009 RHB Legal research re: 5th Amended indentification of witnesses 0.75 hr $225.00 03/16/2009 RHB Draft responses to Motion to Compel discovery Janes Does 2-5 2.40 hr $720.00 03/16/2009 RHB Conference(s) with Attorney Pike re: Motion to Transfer Issues; 5th Amended 0.25 hr $75.00 Issues, background 03/16/2009 RHB Conference with RDC. MJP and legal assistant re: status of pending matters, 0.40 hr $120.00 deadlines, strategy 03/16/2009 BM Pull and copy AC, CMA and Doe II complaints for MJP; list dates and attorneys 1.90 hr $237.50 with phone numbers on depo charts; begin calling all counsel re: scheduling depositions; calls from Mermelsteln; receipt of fax from Mermelsteln; call from Edwards; calls from Jack Hill and Richard Willits; coordinate dates of availability; conference with RDC; send letters with return envelopes to Judges 03/16/2009 MJP Research and analysis of law and Administrative Orders regarding Transfer of 0.40 hr $120.00 cases 03/16/2009 MJP Draft Motions to Transfer four cases and review and revise same, E.W, L.M.. Jane 1.20 hr $360.00 Doe II, and A.C., confer with R. Critton, Esq., regarding same 03/17/2009 RDC Revise Orders 0.10hr $0.00 03/17/2009 RDC Review revised Affidavit signed by Caddy and revise motions (2) 0.60 hr $300.00 03/17/2009 RDC Letter and telephone conference with Jack re: CMA; conference with Rita re: 0.70 hr $350.00 Motion CMA and responses to JD #2-5 to JE 03/17/2009 RDC 5 letters to attorneys re: discovery 0.30 hr $150.00 03/17/2009 RDC Telephone call from Jack; conference with team re: 11 deadline issues in 13 cases 0.90 hr $450.00 03/17/2009 RDC E-mails: additions to all transfer motions 0.30 hr $150.00 03/17/2009 RDC Conference with JMB re: Joe G and schedule/mock, etc.; telephone conference 0.90 hr $450.00 with Jack 03/17/2009 JMB Conference with Robert Critton regarding mock jury; commence outline mock jury 1.80 hr $900.00 thoughts and ideas; review all current e-mails, etc. 03/17/2009 BM Conference with RDC: call to Mermelstein's office; pull Doe #3 and 4 Answers to 3.10 hr $387.50 Interrogatories to obtain addresses; search Internet for additional addresses; print results; prepare Notice of Deposition for Doe #3; prepare Subpoena for Doe #3; prepare Notice of Deposition for Doe #4; prepare Subpoena for Doe #4; note to Lisa re: opening depo files; pull and copy Administrative Rule for MJP to attach to Motions to Transfer; call from Jack Hill's office; fax Notice of Depositions to counsel; receipt of fax from Mermelstein; scan and pdf Notice of Depositions to JG, JE and DI; call to Process Server with instructions; provide list of addresses to Process Server; call to U.S. Legal to schedule depos; diary 03/17/2009 RDC Receipt and review CMA Hill's March 13 letter re: mediator's names 0.10hr $50.00 03/17/2009 RHB Review e-mail correspondence 0.10hr $0.00 03/17/2009 RHB Draft of Responses to Motions to Compel Jane Doe 2-5 1.80 hr $540.00 03/17/2009 RHB Review case and statutory law cited Plaintiffs Motion to Compel (Jane Doe 2-5); 1.70 hr $510.00 legal research 03/17/2009 LG Review e-mails, correspondence and pleadings; file; search federal and county 5.00 hr $250.00 court for document numbers; update pleading Indexes; open files re: research and police and incident report; update master file index 03/18/2009 MJP Review and analysis of Fifth Amendment Priviledge Information 0.90 hr $270.00 03/18/2009 RDC Conference with JMB and Pike re: status; memo; conference with Pike re: stay 1.40 hr $700.00 03/18/2009 RDC Telephone conference with Willits and JE 0.30 hr $150.00 03/18/2009 BM Conference with ROC: conference with MJP re: adding to chart; update Deadlines 3.20 hr $400.00 Page 6 EFTA00614407 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: on Court Filings and Hearings Chart; print for MJP, RDC and JMB; pull Plaintiffs Motion to Compel in Doe #2; scan and pdf Motion, Response and Memo to JG. JE and DI; calls to Horowitz re: Motions to Exceed Page Limitation; e-mail Horowitz Motion to Exceed; finalize Motion to Exceed Page Limitation in Doe #2; prepare Motions to Exceed Page Limitation in Doe #3, 4 & 5; prepare Orders on Motions to Exceed for #2 through 5; e-mail from Horowitz re: Motion 03/18/2009 JMB Commence review of investigative materials 2.10hr $1,050.00 03/18/2009 JMB E-mail to Jack Goldberger 0.10hr $50.00 03/18/2009 JMB Conference with Robert Critton regarding status; various issues 0.80 hr $400.00 03/18/2009 RHB Continue draft of Responses to Plaintiffs Motion to Compel (Jane Doe 2-5) 2.25 hr $675.00 03/18/2009 RI-IB Legal research re: HIPAA, Federal Rule 408, 410, Florida Statute 90.410; case 2.10 hr $630.00 law in Plaintiffs motion 03/18/2009 BM Conference with MJP re: signing Motions; scan and pdf Doe #2 through 5 Motions 1.10hr $137.50 and proposed Orders; file Motions and Orders electronically with Southern District Clerk; forward e-mail from Horowitz to RHB for review; scan and pdf Motion and Order on Doe #2 only to JG, JE and DI; e-malls from Clerk of Court on Doe #2 through 5: print attachments 03/19/2009 BM Conference with RDC and Lisa re: scheduling depositions; prepare Federal and 4.20 hr $525.00 State subpoena forms for Llsa to use; prepare Notice of Dpeos on school records custodians for depos on all cases; conference with RHB on filings in #2 through 5: receipt of e-mails from Clerk's office; e-mail from DI; conference with MJP on several issues; on-line search for CMA docket entries prior to our appearance; call to Court Reporter 03/19/2009 MJP Research and analysis of case law regarding 5th Amendment in preparation for 8.80 hr $2,640.00 drafting Motion to Stay in CMA, review and analysis of all relevant cases, confer with R. Critton, Esq., regarding same and J. Goldberger, Esq. 03/19/2009 BM E-mail from Clerk's office; print attached Order Setting Hearing; diary hearing; 0.50 hr $62.50 open hearing folder; conference with RDC re: conflict 03/19/2009 RDC Telephone conference with Jack; conference with Pike re: stay and Rita - Motions 1.20 hr $600.00 to Compel; conference with JMB re: dry run and e-mails 03/19/2009 JMB Continued review of investigative materials 4.50hr $2,250.00 03/19/2009 RHB Draft Response to Motion to Compel (J.D. 2-5) - address additional objections; 3.60hr $1,080.00 legal research additional grounds raised 03/19/2009 RHB Conference with MJP regarding 5th Am. issues 0.20 hr $60.00 03/19/2009 RHB Review e-mail correspondence 0.30 hr $90.00 03/19/2009 LG Review e-mails, correspondence and pleadings; file same; search federal and 6.50 hr $325.00 county court for document numbers; update pleading indexes; open deposition files; confer with RDC re: subpoena school, employment and medical records; review files for Plaintiffs DOB and SS number; conference 03/20/2009 BM Conference with JMB and RDC re: mock deposition; e-mail to JE and JG; scan 4.10hr $512.50 and pdf Doe's 3 through 5 Motions to Exceed Page Limitation; e-mail Motions to DI; continue working on Subpoenas and NODS; e-mail to JG and JE re: mock deposition; call to Court Reporter; call from RHB; e-mail from DI; e-mail from JE re: depo; e-mail from RHB; print attachments; e-mails from Clerk's office; print attachments 03/20/2009 RDC Review and send e-mails: pull and read cases for Mondays hearings 0.80hr $400.00 03/20/2009 RDC Letter to Willits re: CMA 0.10hr $50.00 03/20/2009 MJP Finalize research on 5th Amendment, review case law and finalize Motion for Stay 2.80 hr $840.00 which will be converted for all cases, e-mail to counsel 03/20/2009 MJP Review and analysis of Okra notes regarding Motion to Compel 0.10hr $30.00 03/20/2009 ROC Receipt and review McIntosh letter re: Haley 0.10hr $0.00 Page 7 EFTA00614408 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/20/2009 RHB Legal research Fed. Rule 408, 410, Evid. Statute 90.410, Fla, Evid. 1.20 hr $360.00 03/20/2009 RHB Legal research constitutional right of privacy 0.75 hr $225.00 03/20/2009 RHB Complete 1st Draft of Response to Motion to Compel (J.D. 2-5) 0.90hr $270.00 03/20/2009 RHB Telephone call from MJP regarding 5th Am.. Motion to Stay 020 hr $60.00 03/20/2009 RHB E-mail correspondence to RDC & MJP 0.20 hr $60.00 03/20/2009 RHB Review multiple e-mail correspondence 0.40 hr $120.00 03/22/2009 RDC Prepare for two hearings in A.C. re: Caddy; read cases 1.10 hr $550.00 03/22/2009 RDC Review motion re: stay and responses 0.90 hr $450.00 03/23/2009 MJP Meeting with R. Budnyk, Esq., regarding the 5th Amendment 0.30 hr $90.00 03/23/2009 MJP Review and analysis of additional case law regarding 5th Amendment Priviledge 4.30 hr $1,290.00 in preparation for incorporating same into various motions for stay 03/23/2009 BM Conference with Lisa; conference with RHB re: preparing #3 through 5 Responses 3.70 hr $462.50 to Motions to Compel; call to Kuvin's office re: scheduling print all subpoenas on EW, LM Jane Doe and BB; finalize Responses to #3 through 5; e-mails to and from JG, JE and DI; pull and copy Exhibits A through Composite C for all Responses; pull and copy Affidavit of Goldberger for MJP 03/23/2009 MJP Meeting with R. Craton, Esq., and Rita Budnyk regarding motions, upcoming 1.00 hr $300.00 deadlines and strategy 03/23/2009 MJP Receive and review email from J. Goldberger, Esq., and confer with R. Budnyk 0.30 hr $90.00 03/23/2009 RDC Attended two hearings in A.C. 1.10hr $550.00 03/23/2009 RDC Review e-mails and responses; telephone conference with Darren 0.90 hr $450.00 03/23/2009 RDC Conference with Pike and Rita re: their motions; e-mails and faxes; telephone 1.80 hr $900.00 conference from Horowitz and letter to same 03/23/2009 RDC Telephone conference from Jack and JE 0.20 hr 5100.00 03/23/2009 RDC Letter to Adam and Stuart re: 2-7 0.20 hr $100.00 03/23/2009 RDC Read Rita's current motion 0.70 hr $350.00 03/23/2009 RDC Drafted Answer and Affirmative Defenses for JD #2-7 1.50 hr $750.00 03/23/2009 JMB Conference with RDC regarding status and outstanding discovery issues 0.40 hr $200.00 03/23/2009 RDC Receipt and review LM and EWs Order on Defendant Epstein's Motion to 0.60 hr $300.00 Dismiss, LM 's First Interrogatories, First Request to Produce and First Expert Interrogatories; First Request for Admissions; Signed Settlement of Robson 03/23/2009 RHB Review e-mail correspondence on Response to Motion to Compel (J.D. 2-5) 0.30 hr $90.00 03/23/2009 RHB Follow-up on M. Welnbgerg's e-mail - case law and legal principles referenced; 1.80hr $540.00 legal research 03/23/2009 RHB Legal research; review case law on exception to adverse interest rule 1.20 hr $360.00 03/23/2009 RHB Draft and review Response to Motion to Compel (J.D. 2-5) 1.60 hr $480.00 03/23/2009 RHB Conference with RDC & MJP regarding outstanding issues, response (J.D. 2-5); 1.00 hr $300.00 Motion for Stay; deadlines 03/23/2009 LG Prepare subpoena for school records; research on-line for correct addresses; 5.00 hr $250.00 prepare subpoenas for medical records; set depositions; confer with BM re: deposition schedule 03/23/2009 BM Call from Process Server; conference with RDC; print hearing and deadlines chart 3.75 hr $468.75 for MJP and RHB; e-malls from and to Story; conference with RHB on several matters; scan and pdf Order on Doe to JG. JE and DI: e-mail to JG, JE and DI re: service on Doe #4; update deposition chart; revisions to NODs as to time; note to Lisa re: Duces Tecum; review Subpoenas prior to providing to RDC Page 8 EFTA00614409 Matter ID: 2008-029 Invoice # 29675 Federal ID # 59-2827481 For Professional Services Rendered: 03/2412009 MJP Reasearch regarding subpoenas to facebook and myspace, contact companies, 1.10 hr $330.00 confer regarding subpoena compliance, review terms and conditions of privacy regarding subpoena compliance 03/24/2009 BM Scan and pdf Exhibits A through Composite C to attach to filing Response 0.70 hr $87.50 tomorrow; e-mail to RHB re: finalized Responses 03/24/2009 RDC Receipt and review CMA - Amended Answer to Interrogatory #3, AC and CMA - 0.30 hr $150.00 Hill's March 23 lobjection re: acquisition of medical records 03/24/2009 RHB Incorporate RDC's revisions to response (J.D. 2-5); finalize 1.80hr $540.00 03/24/2009 RHB Review Garrison Order and Request for Production (A.G.), incorporate into 0.80 hr $180.00 Response (J.D. 2-5) 03/24/2009 RHB Prepare Exhibits to Responses (J.D. 2-5) 0.40 hr $120.00 03/24/2009 RHB Conference with legal assistant regarding finalizing J.D. 2-5, exhibits, filing 0.40 hr $120.00 03/24/2009 RHB Review e-mail correspondence 0.10hr $0.00 03/24/2009 RHB Review 2nd Amended Complaints (Jane Does 2-7); incorporate different 1.00 hr $300.00 allegations into Responses to Motion to Compel (2-5) 03/24/2009 LG Review Answers to Interrogatories; confer with BM re: employers of Plaintiffs; 5.00 hr $250.00 review memo regarding subpoena; prepare Subpoenas for all employment records; check on-line for correct address of employers; memo to file 03/24/2009 MJP Finalize review and analysis of 5th Amendment Case law as it applies of stays, 3.30 hr $990.00 revise Motion for Stay and confer with R. Budnyk regarding same 03/24/2009 BM Conference with MJP re: CMA; scan and pdf Exhblts and Motion for Stay in CMA 2.60 hr $325.00 case; file electronically with Clerk of Southern District; receipt of e-mail from Clerk: print docketed attachment; prepare 15 NODs Duces Tecum on several cases, state and federal; conference with RDC on filings, Subpoenas and Notices 03/25/2009 MJP Confer with R. Budnyk and review case law on stays, revise and file Motion for 0.80 hr $240.00 Stay in AL., review file and prior filings by counsel 03/25/2009 RDC Prepare for and attend hearing re: transfer - AL.; e-mail, telephone conference 1.10 hr $550.00 from Jack 03/25/2009 RDC E-mails and conference with JMB 0.60 hr $300.00 03/25/2009 RDC Conference with Pike and Bobbie re: subpoena and stays and Motion to Compel 0.60 hr $300.00 03/25/2009 RDC Receipt and review Edwards letter re: request client's name do not appear in court 0.30 hr $150.00 filing; BB - Re-Notice of Epstein's deposition, Notice of Production from Non-Parly,Yellow Cab 03/25/2009 MJP Review and analysis of case law regarding Staying Actions, meeting with R. 4.70 hr $1,410.00 Critton, Esq., regarding same, revise Motions for Stay in Jane Doe 2-7 and review all files and court orders in Jane Doe 2-7 prior to filing stays to ensure continuity with court's prior rulings 03/25/2009 MJP Review Judge's procedures regarding upcoming Motion to Dismiss. telephone 0.60 hr $180.00 conference with Judge's Clerics regarding Notice of Supplemental Authority 03/25/2009 RHB Finalize Jane Does 3-5 Response to Motions to Compel; incorporate specific 1.20 hr $360.00 factual allegations from 2nd Amended Complaint 03/25/2009 RHB Conference with paralegal regarding filing of Jane Doe's 2-5 Responses to 0.10 hr $30.00 Motions to Compel 03/25/2009 RHB Review Jane Doe's 2-7 2nd Amended Complaints for viable c/a, Count III 0.75 hr $225.00 03/25/2009 RHB Draft memo to RDC with thoughts on 2nd Amended Complaints 0.60 hr $180.00 03/25/2009 RHB Legal research 2422 as a predicate act under 2255; state statutes referenced in 1.20 hr $360.00 2nd Amended Complaints 03/25/2009 RHB Draft Motion to Compel, Interrogatories 0.50 hr $150.00 03/25/2009 RHB Review Lewis transcript