EFTA01075090.pdf

Fowler White Burnett ) 0 ATTORNEYS AT LAW Espirito Santo Plaza Fourteenth Floor 1395 BrIckell Avenue 1 1131 ain fax E.I. . . 0.59.1303994 www.fowler-white.com Mr. Jeffrey Epstein September 8, 2011 301 East 66th Street Page 1 Suite 10 B New York, NY 10065 Ref.: LAS-23869-080743-463407 Jeffrey Epstein vs. Scott Rothstein. Bradley Edwards and L.M. INVOICE Total Amount Due for this Invoice $ '06,187.50 Past Due $ 83,786.25 Total Due $ 189,973.75 For Professional Services Through August 31, 2011 Date Description Atty Hours 07/27/11 Multiple e-mail communications with Jeffrey Epstein re: tactics and strategies on CEK 2.00 amending Complaint; multiple e-mail communications with Martin Weinberg, Esquire re: amending of Complaint, outstanding counterclaim; e-mail communications with Joseph Ackerman, Esquire and Lilly Ann Sanchez, Esquire re: abuse of process counterclaim, affirmative defenses, punitive damages 07/28/11 Receipt, review and analyze the deposition transcript of Mark Epstein, brother of CEK 1.25 Jeffrey Epstein re: future strategy and impact on case 07/29/1 1 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25 Motion to Dismiss Plaintiff, Jeffrey Epstein's Amended Complaint 07/29/1 1 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25 Motion for Leave to Assert Claim for Punitive Damages 07/29/1 I Receipt and review of Order on Plaintiff/Counter-Defendant, Jeffrey Epstein's Motion CEK 0.25 for Leave to Use Documents Produced Under Confidentiality Agreement 07/29/1 1 Receipt and review of correspondence from Darren Indyke (x4) re: earliest available CEK 0.50 date through online scheduling with Judge Crow's division for the hearing on Edwards' Motion for Leave to Amend to Assert a Claim for Punitive Damages; draft correspondence to Darren lndyke (x3) re: sufficient notice for hearing 07/29/11 Receipt and review of correspondence from Brad Edwards re: language and terms CEK 0.50 agreed for Settlement and Confidentiality Agreements; draft correspondence to Mr. Edwards re: same 07/29/11 Receipt and review of Order on Plaintiff/Counter-Defendant, Jeffrey Epstein's CEK 0.25 Amended Motion for Protective Order Relating to Extra Judicial Statements served on May 2, 2011 07/29/11 Receipt and review of correspondence from Jeffrey Epstein to Brad Edwards (x4) re: CEK 0.50 edits to correspondence on settlement and offer issues, 57.105 claim; draft correspondence to Mr. Epstein (x4) re: same; telephone conference with Mr. Epstein re: same 08/0I /11 Review and respond to emails; review Orders and forward. LAS 0.25 08/01/11 Begin drafting Response in Opposition to Motion for Leave to Amend to Assert a HSG 1.50 Claim for Punitive Damages. Fowler White Burnett P.A. EFTA01075090  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 2 Date Description Atty Hours 08/01/11 Email from Marty Weinberg regarding Punitive Damage Issues; Emails from Jeffrey JLA 2.00 Epstein regarding 57.105, Punitive Damage Issues and settlement; Draft letter to Bradley Edwards (4); Work on Motion to Amend; Emails from J. Scarola regarding response to M. Weinberg; Emails to J. Scarola regarding hearing time and Jeffrey Epstein deposition (2); Emails to/from Darren Indyke regarding hearing on Amended Motion to Assert Claim for Punitive Damages (4) 08/01/1 1 Receipt and review of correspondence from Martin Weinberg re: decision on punitive CEK 0.25 damages being binding 08/01/11 Receipt and review of Supplement to Bradley Edwards' Proffer in Support of Motion CEK 0.75 for Leave to Amend to Assert Claim for Punitive Damages 08/02/11 Confer with Darren Indyke; review and forward numerous pleadings and pro hac vice LAS 1.00 application to Jay Lefkowitz' review and respond to emails; confer with CEK and JLA. 08/02/11 Review LM Court file and work on Amended Complaint; Phone call with Darren JLA 3.50 Indyke regarding new counsel and emails regarding same (11) 08/02/11 Receipt and review of correspondence from Jeffrey Epstein to Brad Edwards re: other CEK 0.50 edits to correspondence on settlement negotiations and 57.105 claim; draft correspondence to Mr. Epstein re: same 08/02/11 Telephone conference with Darren lndyke re: filing of the Second Amended CEK 0.50 Complaint; draft correspondence to Mr. Indyke (x4) re: no need for a Jack affidavit, need for Kirkland to file a notice of appearance and Pro Hac Vice motions; receipt and review of correspondence from Mr. Indyke re: motion to continue time to file amended complaint, amended complaint that was dismissed, Second Amended Complaint, Counterclaim by Edwards, and motion for punitive damages; draft correspondence to Mr. Indyke re: same 08/02/11 Telephone conference with Jeffrey Epstein re: bring in Kirkland & Ellis (Jay CEK 1.00 Lefkowitz) as Co-Counsel in the Rothstein/Edwards case, filing of the Second Amended Complaint, no need for a Jack affidavit, need for Kirkland to file a notice of appearance, Pro Hac Vice motions, motion to continue time to file Second Amended Complaint, Counterclaim by Edwards, and motion for punitive damages 08/02/11 Draft response in opposition to Edwards' motion for leave to assert punitive damages. HSG 7.00 08/02/11 Conference call with Jay Lefkowitz re: summary of matter to date. LAS 0.75 08/03/11 Review LM Court file for amending complaint (continued); Phone call with Marty JLA 3.00 Weinberg regarding Scarola/57.105 issues 08/03/11 Continue drafting response in opposition to Edwards' motion for leave to amend HSG 5.00 counterclaim to add punitive damages. 08/03/11 Work on Complaint amendments; Check status of A.J. Discala documents and emails JLA 3.25 regarding same (5) 08/03/11 Receipt and review of correspondence from Jonathon Etra re: Conrad Scherer's review CEK 0.50 and production of Discala documents in the Razorback litigation and getting additional Al Discala documents; draft correspondence to Mr. Etra re: order to produce same; telephone conference with Mr. Etra re: same 08/04/11 Revise response in opposition to Edwards' motion for leave to amend to add punitive HSG 4.50 damages. Fowler White Burnett P.A. EFTA01075091  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 3 Date Description Atty Hours 08/04/11 Telephone conference with Jeffrey Epstein re: Second Amended Complaint, changes CEK 2.00 and/or additions thereto and hearing on Motion to Dismiss; telephone conference with Mr. Epstein, Marty and Lefkowitz re: same; receipt and review of correspondence from Mr. Epstein re: Scarola tainting brad forever by calling him a crook in open court and the co-conspirator ofRothstein; draft correspondence to Mr. Epstein re: same; receipt and review of correspondence from Mr. Epstein re: A federal appeals court has revived an abuse of process suit against a law firm and lawyer that allegedly used unfair tactics in litigation; draft correspondence to Mr. Epstein re: same 08/04/11 Receipt and review of correspondence from Darren Indyke re: draft response to the CEK 0.25 motion for punitive damages along with the abuse of process cases within which we could fit an amended complaint; draft correspondence to Mr. Indyke re: same 08/04/11 Emails regarding settlement (17); Discussions/strategies (11); Emails and phone calls JLA 3.50 from Marty Weinberg and L. Holman regarding Limited Appearance (6); Emails regarding Complaint and Amended Motion to Assert Claim for Punitive Damages (10); Review draft of same; Emails regarding Second Amended Complaint (7) and work on same; Emails from J. Scarola regarding deposition in September; Emails regarding A.J. Discala production (4) 08/04/11 Review and respond to emails; pull documents and forward to Jay Lefkowitz. LAS 1.00 08/05/11 Legal research for draft of Second Amended Complaint; Continue to work on JLA 5.00 Amendments to Complaint; Review Court files (continued) fo Complaint; Emails to/from Darren Indyke (2); Emails to/from regarding Amended Complaint (5); Emails to Darren Indyke,Jeffrey pstein and Jay Lefkowitz with Amended Complaint; Emails from/to Jeffrey Epstein (s); Motion for Enlargement of Time for Complaint 08/07/11 Emails to/from Jay Lefkowitz regarding Amending Complaint and Motions Directed to JLA 0.50 Counterclaim and Proposal for Settlement (6) 08/08/11 Review and advise regarding Second Amended Complaint; review Gen. Refractories HSG 2.25 case noted in J.E. e-mail and federal proceedin in connection with same. 08/08/11 Email from Jeffrey Epstein; Emails to/from (4); Emails to/from Jay JLA 1.75 Lefkowitz (4); Continue to work on Amend mp aint and research regarding same; Phone call with Darren Indyke regarding Motion to Extend Time regarding Complaint 08/09/11 E-mail communications with Joseph Ackerman, Esquire re: proposed Motions to file, CEK 0.50 Amended Complaint and response to Counterclaim 08/09/11 Emails regarding Amended Complaint (3) from Darren Ind ke; Review draft correction JLA 0.50 08/10/11 Review Critton case files; Conference with regarding same; Prepare JLA 5.25 and revise Motion for Enlargement of Time regarding omplaint and Notice of Hearing; Conference with Mike Pike and Bob Critton; To courthouse to review case files; Phone call with Darren Indyke; Email from Darren Indyke 08/11/11 Telephone conference with Jeffrey Epstein re: status of matter CEK 0.50 08/11/11 Emails to/from Darren Indyke regarding amending complaint (4); Email from Jack JLA 2.00 Scarola regarding complaint and emails regarding same (2); Reset depositions regarding Wackenhut deponents and emails regarding sa • F.ma Maxine Streeter regarding Discala documents (2); Emails to/from 08/11/11 Continue preparation of new complaint and legal research regarding same JLA 2.25 Fowler White Burnett P.A. EFTA01075092  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 4 Date Description Atty Hours 08/12/11 Telephone conference with Joseph L. Ackerman, Esquire re: status of Second Amended CEK 3.00 Complaint and positions to be taken by Plaintiff; anticipated positions to be taken by Jack Scarola, Esquire; e-mail communications with Joe Ackerman re: Scarola's desire to depose G. Maxwell., H. Rubenstein, A. Cordero and A. Dershowitz; preparation for telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, Esquire, Jay Lekfowitz, Esquire and Roy Black, Esquire 08/12/11 Draft motion for partial summary judgment regarding Counterclaim and review HSG 5.25 authorities in connection with same. 08/12/11 Prepare memo for conference call; Work on Motion for Partial Summary Judgment JLA 5.25 regarding Damages and 57.105 motion to Jack Scarola; Work on Motion for Protective Order regarding Ghislaine Maxwell, A. Dershowitz, A. Cordero, and H. Rubenstein depositions Email to Maxine Streeter regarding records; Emails to/from Jack Scarola regarding deposition of G. Maxwell, A. Dershowitz, H. Rubenstein and A. Cordero; Preparation for conference call; Draft report letter 08/13/11 E-mail communications with Darren Indyke, Esquire re: strategies relative to Second CEK 2.25 Amended Complaint, intervening, inquiry as to Marra hearing; preparation for and attendance at telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, Esquire, Roy Black, Esquire and Jay Lefkowitz, Esquire re: filing of Second Amended Complaint, continued allegations to add; e-mail communications with Jeffrey Epstein re: filing ofMotion for Summary Judgment, discussion of relevant matters to Second Amended Complaint, denial of Critton's Motion to Dismiss, 08/13/I I Conference call with J. Lefkowitz, Esq., M. Weinberg, Esq., Mr. Epstein and D. Indyke, HSG 1.00 Esq. regarding going-forward strategy and pending and proposed motions. 08/13/11 Attend conference call with Chris Knight, Jeffrey Epstein, Jay Lefkowitz, Marty JLA 1.50 Weinberg and Roy Black; Emails regarding conference call with Jeffrey Epstein (3); Emails to/from Darren lndyke (2) 08/13/11 Conference call with JEE and defense team; follow up call with CEK and JLA. LAS 1.50 08/14/1I E-mail communications with Jeffrey Epstein re: legal analysis for Second Amended CEK 0.50 Complaint, serving ofProposal for Settlement and filing of Summary Judgment Motion to Counterclaim, discussion of review of Critton files, court files, etc. 08/14/11 Revise report/recommendation latter to Jeffrey Epstein; Emails regarding same (7); JLA 2.25 Prepare response to question of Jay Lefkowitz and Marty Weinberg regarding Abuse of Process Claim 08/14/11 Continue to work on revisions to Amended Complaint and emails to/from Jeffrey JLA 2.25 Epstein regarding same (2) 08/14/11 Review and advise re: client letter. HSG 0.75 08/14/11 Review, revise and finalize letter to JEE re: summary of matter to date and LAS 1.25 recommendations. 08/15/11 Review Re-Notices of Wackenhut's depositions (2); Emails regarding research of JLA 1.25 Abuse of Process Claim (3); Emails and phone calls to/from Maxine Streeter regarding Discala documents (4); Emails to/from Jeffrey Epstein regarding Complaint (3) 08/15/11 Emails regarding G. Maxwell, et al. depositions (3); Review Privilege Log from JLA 1.75 Discala; Review Abuse of Process and Litigation Privilege case law for Amending Complaint; Review Daily Business Review article regarding CVRA case 08/15/11 Review authorities re: malicious prosecution; revise memorandum re: abuse of process; HSG 2.75 review/advise re: on-line DBR article re: AFederal Charges Prepared, Not Filed Against Jeffrey Epstein.v Fowler White Burnett P.A. EFTA01075093  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 5 Date Description Atty Hours 08/15/11 Review results of 3771 hearing and related press article. LAS 0.50 08/16/11 Follow up relative to Second Amended Complaint, including discussion of Discala CEK 1.00 production, Legamaro e-mail and other relevant information; follow up relative to filing of Second Amended Complaint, 57.105 letter, Motions for Partial Summary Judgment and serving of Proposal for Settlement 08/16/11 Review and respond to emails; review case law on abuse of process and summary LAS 1.00 memorandum; review amended complaint status. 08/16/11 Locate deposition summaries as uested by N. from t for J. Ackerman PMR 0.75 08/16/11 Review Disk from Phone call with (2); Prepare JLA 8.50 email/document chronology or econd Amended Comp aint; eview Razorback records; Emails to/from Jeffrey Epstein regarding status of Second Amended Complaint (3); Email to client regarding research on Abuse ofProcess; Continue to work on Second Amended Complaint 08/16/11 Draft J57.105 letter to Scarola and motion for J57.105 attorney's fees. HSG 2.00 08/17/11 Telephone conference with Helaine Goodner, Esquire re: Second Amended Complaint; CEK 1.25 receipt and review of e-mail communication from Jay Lefkowitz, Esquire re: observations on memo on abuse of process case law; e-mail communications with Jeffrey Epstein re: Second Amended Complaint and cause of action stated for abuse of process; telephone conference with Martin Weinberg, Esquire re: comments and input on Second Amended Complaint; e-mail communications with Jeffrey Epstein re: requesting additional time to file 08/17/11 Review and respond to emails; review draft amended complaint; review comments to LAS 3.75 same; make suggestions and revisions; confer with CEK and JLA; review letter from Many Weinberg. 08/17/11 Revisions to Second Amended Complaint; Emails from Jeffrey Epstein, J iggio witz !LA 8.00 • Second Amended Complaint; Hearing preparation; Emails with regarding Second Amended Complaint (4); Legal research regarding onspiracy issues and Abuse ofProcess issues 08/17/11 Review and advise regarding draft Second Amended Complaint and conference HSG 4.00 regarding same; further review Florida law regarding civil conspiracy. 08/18/11 Continue review of draft amended complaint; analyze options for conspiracy issue; LAS 3.75 confer with Helaine Goodner; review and respond to emails; confer with JLA re: result ofhearing and extension until Monday® 5pm; review and respond to emails; review draft Rule 57-105 letter and motion for attorney's fees; review motion for summary judgment of the counterclaim. 08/18/11 E-mail communications with Darren Indyke, Esquire re: comments and edits to Second CEK 0.50 Amended Complaint, discussion of potential Motion to Dismiss and ruling; e-mail communications with Joseph Ackerman, Esquire re: inquiry from Special Master as to status 08/18/11 Prepare for and attend hearing on Motion for Enlargement of Time for Complaint, JLA 3.25 Legal research and continue working on Second Amended Complaint and revisions thereto; Emails from Darren I. regarding complaint (2); Emails regarding hearing for Motion re Punitive Damages; Emails from Jeffrey Epstein (2) 08/18/1 1 Emails from/to Judge Carney (3); Legal research regarding conspiracy; Email from JLA 0.50 Jack Scarola regarding Carney 08/18/11 Work on Proposal for Settlement JLA 0.75 08/18/11 Continued review of authorities regarding civil conspiracy under Florida law in IISG 4.25 connection with preparation of amended complaint. Fowler White Burnett P.A. EFTA01075094  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 6 Date Description Any Hours 08/18/11 Analyze pleadings and evaluate issues re: terms and conditions ofProposal for MJS 0.50 Settlement to Plaintiff 08/19/11 E-mail communications with Jeffrey Epstein re: focus on criminal enterprise in Second CEK 2.00 Amended Complaint; review of draft of Second Amended Complaint; telephone conference with Lilly Ann Sanchez, Esquire re: Second Amended Complaint, 57.105 letter, 57.105 motions and Motion for Summary Judgment; telephone conference with Joseph Ackerman, Esquire re: revisions to Second Amended Complaint, draft of Motion for Partial Summary Judgment, Proposal for Settlement and finalizing of 57.105 letter and 57.105 motion 08/19/11 Review and respond to emails; continue review of draft amended complaint and LAS 1.75 comments to same; confer with JLA and CEK. 08/19/11 Emails from/to Jeffrey Epstein regarding hearing (2); Emails to/from Darren lndyke ILA 5.50 regarding Rothstein Plea and Revisions to Complaint (2); Work with Helaine Goodner to complete revisions to Complaint, 57.105 letter and Motion, and Motion for Partial Summary Judgment; Review transcripts ofDiscala, Doe and LM depositions 08/19/11 Emails to/from Jeffrey Epstein regarding Complaint (2) JLA 0.50 08/19/11 Revisions to Second Amended Complaint. HSG 3.25 08/20/11 Review and respond to emails; review JEE email re: facts of matter; confer with CEK LAS 1.75 and JLA; review draft second amended complaint and forward same; review revised motion for attorneys fees under Rule 57-105; review draft motion for summary judgment on the counterclaim and forward same. 08/20/11 Multiple e-mail communications with Joseph Ackerman, Esquire, Helaine Goodner, CEK 4.00 Esquire and Lilly Ann Sanchez, Esquire it: Second Amended Complaint and comments made by client, including request for rewriting; review and revise of Second Amended Complaint; review and revise of 57.105 letter and multiple e-mail communications with Helaine Goodner re: same; review and review ofMotion for Summary Judgment on Counterclaim 08/20/11 Further revisions to Second Amended Complaint, 57.105 motion and letter and motion HSG 2.00 for summary judgment. 08/21/1 1 Review and respond to emails; confer with Darren 1ndyke; confer with CEK; LAS 2.75 coordinate conference call; attend conference call with JEE and defense team; review draft complaint and forward same. 08/21/11 Telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, CEK 4.00 Esquire, Jay Le&owitz, Esquire and Lilly Ann Sanchez re: allegations in Second Amended Complaint as presented and potential for Complaint to survive a Motion to Dismiss; telephone conference with Helaine Goodner, Esquire re: Second Amended Complaint and continued revisions; e-mail communications with Marty Weinberg re: Second Amended Complaint; e-mail communications with Jeffrey Epstein re: status of Complaint; e-mail communications with Helaine Goodner and Joseph Ackerman, Esquire re: expansion with more particularity of dates on meetings, filing ofFederal Complaint but lack of service on Epstein and abuse ofprocess claim; review and review paragraph 30 of Second Amended Complaint; e-mail communications with Lilly Ann Sanchez, Esquire re: review of revised Complaint and coordination of telephone conference and filing 08/21/11 Further advise and revise Second Amended Complaint. HSG 3.25 Fowler White Burnett P.A. EFTA01075095  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 7 Date Description Atty Hours 08/22/11 E-mail communications with Darren Indyke, Esquire re: Second Amended Complaint CEK 1.75 and revisions made thereto; e-mail communications with Jeffrey Epstein re: Second Amended Complaint, allegations in Complaint, continued revisions to Complaint and filing of same; multiple e-mail communications with Lilly Ann Sanchez, Esquire, Helaine Goodner, Esquire and Joseph Ackerman, Esquire re: revisions to Second Amended Complaint; e-mail communications with Jeffrey Epstein re: timing of serving of Proposal for Settlement 08/22/11 Numerous phone calls and emails re: second amended complaint; attend conference LAS 3.50 calls with JEE and defense team; confer with Darren Indyke; confer with Helaine Goodner and CEK; review drafts of complaint. 08/22/11 Review all LM v. Epstein files and on line research for dates regarding same at the PMR 1.00 request ofH. Goodner 08/22/11 Review all deposition transcripts and summaries to confirm date of first investor PMR 1.25 meeting. 08/22/11 Detailed analysis and evaluation of viability of the dueling abuse of process claims and EEG 1.00 motions for Section 57.105 attorneys' fees. 08/22/11 Research and analyze recent legal authority re: procedural requirements for proposals MJS 0.50 for settlement 08/22/11 Draft Proposal for Settlement to Defendant/Counter-Plaintiff MJS 0.75 08/22/11 Draft proposed General Release to attach to Proposal for Settlement to MJS 0.75 Defendant/Counter-Plaintiff 08/22/1 1 Draft proposed Stipulation for Dismissal with Prejudice to attach to Proposal for MIS 0.50 Settlement to Defendant/Counter-Plaintiff 08/22/11 Final revisions to Second Amended Complaint and numerous extended conference calls HSG 5.25 with client and counsel regarding same. 08/23/11 Review and respond to emails re: scrivener's error; confer with CEK and Helaine LAS 1.50 Goodner re: same; conference call with Marty Weinberg; follow up call re: same; respond to email re: request for September 22 hearing. 08/23/11 Review and revise draft Proposal for Settlement, proposed General Release and CEK 0.50 proposed Stipulation for Dismissal with Prejudice directed only to Edwards' Counterclaim 08/23/I I Preparation for and attendance at conference call with Martin Weinberg, Esquire, CEK 1.75 Helaine Goodner, Esquire and Joseph Ackerman, Esquire re: Second Amended Complaint, Proposal for Settlement, Motion for Partial Summary Judgment and future course of action 08/23/11 Telephone conference with Many Weinberg; Review revisions to portions of Second JLA 2.00 Amended Complaint 08/23/11 Review Epstein indexes PMR 0.50 08/23/11 Draft correspondence to Jeffrey Epstein re: Proposal for Settlement and exhibits thereto MJS 0.25 08/23/11 Telephone conference with Marty Weinberg, Esq. regarding revising portion of Second HSG 2.50 Amended Complaint; revise Second Amended Complaint and prepare Notice of Scrivener's Error. 08/24/11 Review motion to dismiss amended complaint; review and respond to emails; confer LAS 0.75 with JLA and CEK. 08/24/11 Follow up relative to filing ofNotice of Scriveners' Errors and Corrected Second CEK 0.75 Amended Complaint; e-mail communications with Darren Indyke, Esquire re: service ofProposal for Settlement and Florida law 08/24/11 Review 2d amended complaint SA 0.50 Fowler White Burnett P.A. EFTA01075096  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 8 Date Description Any Hours 08/24/11 Research and analyze legal authority re: whether counterclaim may be subject of MJS 1.00 proposal for settlement without disposition of main claim 08/24/11 Research and analyze legal authority re: enforceability of proposal for settlement MJS 0.75 directed to less than all claims 08/24/11 Evaluate issues re: enforceability ofproposal for settlement directed only to MJS 0.50 counterclaim 08/24/11 Revise/address issues regarding Notice of Scrivener's Error regarding Second Amended HSG 1.50 Complaint. 08/25/11 Review and respond to emails. LAS 0.25 08/25/11 Supplement and revise Proposal for Settlement to Defendant/Counter-Plaintiff to cover MJS 0.50 all claims asserted by both Plaintiff and Defendant 08/25/11 Supplement and revise Stipulation for Dismissal with Prejudice to attach to Proposal MJS 0.25 for Settlement to Defendant/Counter-Plaintiff to cover all claims asserted by both Plaintiff and Defendant 08/25/11 Draft proposed General Release to attach to Proposal for Settlement to MJS 0.25 Defendant/Counter-Plaintiff to cover all claims asserted by both Plaintiff and Defendant 08/26/11 E-mail communications with Lilly Ann Sanchez, Esquire re: strategies on Proposal for CEK 0.75 Settlement on Counterclaim, Proposal for Settlement on Epstein lawsuit against Edwards; e-mail communications with Jeffrey Epstein re: Motion to Dismiss Second Amended Complaint; e-mail communications with Joseph Ackerman, Esquire re: coordination of response to Motion to Dismiss and finalize response to Motion for Punitive Damages 08/26/11 Draft Plaintiff/Counter-Defendant Jeffrey Epstein's Notice of Serving Proposal for MJS 0.25 Settlement to Defendant/Counter-Plaintiff Bradley J. Edwards, Individually 08/26/11 Review and advise regarding J57.105 motion/letter to J. Scarola and revisions to same. HSG 1.00 08/29/11 Review pleadings file din the 3771 matter; review and respond to emails re: scheduling LAS 1.00 issues; confer with JLA and CEK re: same; review Supplement to Edwardsr Motion to Dismiss and Motion for Leave to Amend to Assert Claim for Punitive Damages; forward same; review motion to withdraw Marty Weinberg requests to file; 08/29/11 Telephone conferences with Jack Scarola regarding hearing dates for his Motion to JMC 0.50 Dismiss the Second Amended Complaint and Motion to Amend to add a claim for punitive damages and draft correspondence to him regarding the same 08/29/11 Review and revise Epstein's Motion for Partial Summary Judgment; receipt and review CEK 0.75 of Edwards' Supplement to Motion to Dismiss and Motion for Leave to Amend to Assert Claim for Punitive Damages; e-mail communications with Lilly Ann Sanchez, Esquire re: follow up on client comment relative to Motion for Summary Judgment on Counterclaim; e-mail communications with Joseph Ackerman, Esquire and Lilly Ann Sanchez re: unilateral hearing set by Jack Scarola, Esquire 08/29/11 Review and revise Marty Weinberg's Motion to Withdraw and emails to/from Marty JLA 2.50 Weinberg regarding same (5); Emails with Jack Scarola regarding hearing (5); Review amended motions from Jack Scarola and work on response 08/29/11 Review Edwards' supplement to motion to assert punitive damages claim and begin HSG 1.50 drafting response to same. Fowler White Burnett P.A. EFTA01075097  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 9 Date Description Atty Hours 08/30/11 E-mail communications with Darren Indyke, Esquire re: Response to Motion to CEK 1.75 Dismiss; e-mail communications with Helaine Goodner, Esquire and Lilly Ann Sanchez, Esquire re: Response to Motion to Dismiss; receipt and review of Edwards' Notice of Servin; Proposal for Settlement and Proposal; analysis ofProposal for settlement; e-mail communications with Lilly Ann Sanchez, Esquire re: proposed hearing dates before Judge Crow and availability in October; e-mail communications with Esther Galicia, Esquire re: Response in Opposition to Edwards' Motion to Dismiss Second Amended Complaint; e-mail communications with Lilly Ann Sanchez, Helaine Goodner and Esther Galicia re: comments on Response to Motion to Dismiss; telephone conference with Jeremy Colvin, Esquire re: offering ofhearing dates before Judge Crow 08/30/11 Review and respond to emails; confer with Darren Indyke re: scheduling hearing; LAS 1.50 review Edwards proposal for settlement and forward same; confer with CEK re: same; prepare Jeremy Colvin for hearing. 08/30/11 Review, study and analysis ofDefendant/Counter-Plaintiff's Motion to Dismiss Second EEG 0.25 Amended Complaint (for purposes of preparing Response in Opposition to Motion to Dismiss). 08/30/11 Detailed review, study and analysis of Corrected Second Amended Complaint plus EEG 2.00 cross-referencing with Defendant's Motion to Dismiss (for purposes of preparing Response in Opposition to Motion to Dismiss). 08/30/11 Analysis for and outlining, drafting and preparation of Response in Opposition to EEG 1.50 Defendant's Motion to Dismiss Corrected Second Amended Complaint. 08/30/11 Review various pleadings and correspondence in preparation for hearing on Defendant JMC 1.75 Edwards' Motion to Schedule Hearing on his Motion to Dismiss the Second Amended Complaint before Judge Crow and reviewed various correspondence regarding the availability of legal team for a hearing on the Motion 08/30/11 Draft correspondence to members of legal team regarding punitive damage claim and JMC 0.25 review responses regarding the same 08/30/11 Continue drafting response in opposition to motion for leave to assert punitive HSG 4.50 damages. 08/30/11 Analyze Defendant/Counter-Plaintiff's Proposal for Settlement Pursuant to Rule 1.442, MJS 0.50 Florida Rules of Civil Procedure and Sect. 768.79, Florida Statutes and evaluate issues re: validity of same for purposes of determining entitlement to attorney's fees 08/31/11 Review results of hearing ; confer with CEk; review and respond to emails re: hearing LAS 1.25 dates; confer with Darren Indyke; review draft response to motion to dismiss; review suggestions revisions to draft motion for summary judgment; confer with Helaine Goodner. 08/31/11 E-mail communications with Helaine Goodner, Esquire, Esther Galicia, Esquire and CEK 0.50 Lilly Ann Sanchez, Esquire re: filin4 of Motion for Summary Judgment and deadline for same; e-mail communications with Joseph Ackerman, Esquire re: response to punitive damages motion; 08/31/11 Telephone conferences with counsel for Defendant Edwards regarding hearing on JMC 0.50 Motion to Dismiss Second Amended Complaint and scheduling issues and draft correspondence to him regarding the same 08/31/11 Attend hearing on Defendant's Motion to Set Hearing on his Motion to Dismiss the JMC 1.50 Second Amended Complaint before Judge Crow 08/31/11 Review and respond to various correspondence regarding hearing before Judge Crow JMC 0.50 on Defendant Edwards' Motion to Schedule Hearing on his Motion to Dismiss the Second Amended Complaint and Motion to Amend to Add Punitive Damages Fowler White Burnett P.A. EFTA01075098  Ref.: LAS-23869-080743-463407 September 8, 2011 Page 10 Date Description Atty Hours 08/31/11 Review, study and analysis of legal precedent regarding allegation of damages required EEG 1.50 to state a cause of action for abuse ofprocess. 08/31/11 Detailed analysis for and revising and supplementing of Epstein's Response in EEG 2.50 Opposition to Edward's Motion to Dismiss the Corrected Second Amended Complaint (several drafts). 08/31/11 Prepare response re: Edwards' motion for leave to assert punitive damages; review K & HSG 4.50 E assessment re: motion for partial summary judgment and advise re: same. 08/31/11 Address and evaluate parameters of recoverable damages as to abuse of process claim, JGH 2.75 in particular with respect to party defendant/attomey's lost professional time/fees for time spent defending the action; commence research re: same 08/31/11 Address and advise re: procedural propriety of motion for summary judgment and/or JGH 1.50 judgment on the pleadings with respect to independent counterclaim notwithstanding open pleadings regarding main claim; related research and analysis Fees for Professional Services S 106,187.50 Summary of Timekeeper Fees Timekeeper Hours Rate/Hour Dollars Christopher E. Knight 39.50 525.00 20,737.50 (CEK) Lilly Ann Sanchez (LAS) 30.75 525.00 16,143.75 Joseph L. Ackerman (JLA) 78.25 450.00 35,212.50 H. Aprill (SA) 0.50 450.00 225.00 Esther E. Galicia (EEG) 8.75 375.00 3,281.25 Helaine S. Goodner (HSG) 69.50 375.00 26,062.50 June G. Hoffman (JGH) 4.25 375.00 1,593.75 Jeremy M. Colvin (JMC) 5.00 255.00 1,275.00 Marc J. Schleier (MJS) 7.25 185.00 1,341.25 Paula Rescia (PMR) 3.50 90.00 315.00 TOTAL 247.25 $ 106,187.50 Fowler White Burnett P.A. EFTA01075099  Ref.: LAS-23869-080743-463407 September 8, 2011 Page II Totals for This Matter Fees for Professional Services S 106,187.50 Reimbursable Costs 0.00 NET CURRENT BILLING FOR THIS MATTER $ 106,187.50 Balance Brought Forward $ 83,786.25 TOTAL AMOUNT DUE FOR THIS INVOICE $ 189,973.75 TERMS: DUE UPON RECEIPT Please make checks payable to: FOWLER WHITE BURNETT Please reference 23869-080743-463407 when making payment. Fowler White Burnett P.A. EFTA01075100 Fowler White Burnett ATTORNEYS AT LAW ; Espirito Santo Plaza Fourteenth Floor 1395 Brickell Avenue MI 3131 ain fax www.fowler-white.corn September 8, 201 1 Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 10065 Detail of Balance Brought Forward Prior outstanding billing on our Matter No. 080743 Entitled: Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards and L.M. Last Payment Date: 05/20/11 Original Invoice Invoice Invoice Payments Invoice Number Date Amount and Credits Balance Due 460830 07/13/1I $28,331.25 $0.00 $28,331.25 461717 08/03/11 55,455.00 0.00 55,455.00 Balance Brought Forward $83,786.25 For Total Amount Due, See Previous Page Fowler White Burnett P.A. EFTA01075101