EFTA00804036.pdf

LINK & ROCKENBACH, P.A. CML TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd , Suite 301 West Palm Beach, Fronde 33401 T 561.727 3600 F 561.727 3601 December 1, 2017 Via Email Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 100.001 Dear Jeffrey: Attached please find our firm's billing statement for services rendered through November 29, 2017. Please wire the payment to us per the attached Wire Transfer Instructions. Please do not hesitate to call me if you have any questions regarding this bill. Thank you. Very truly Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00804036  LINK & ROCKENBACH, CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 T 561.727.3600 F 561.727.3601 Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank,. Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: 2785978939 Beneficiary Name: Link & Rockenbach, Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account EFTA00804037 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, FL 33401 Tax ID: 82-3083928 Invoice submitted to: Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 December 1, 2017 In Reference To: Jeffrey Epstein v. Bradley J. Edwards Case No. 50-2009-CA-040800- XXXX-MB File No. 100.001 Invoice #32942 Professional Services HrslRate Amount 11/6/2017 TLC Work on Pre-Trial Stipulation and Motion for Continuance of Trial; 9.50 2,137.50 continue working on exhibits for B. Edwards' deposition; continue 225.00/hr working chart of B. Edwards' responses to J. Epstein's discovery requests; prepare Notice of UMC hearing on Joint Motion to Dispense with Mediation and Motion for Continuance; work on proposed Orders and hearing packages; follow up on Objections to exhibits; work on Motion to Compel SJL Meeting with J. Epstein, J. Goldberger, D. Indyke and K. 11.50 8,625.00 Rockenbach re strategies; work on Pre-Trial Stipulation and Motion 750.00/hr for Continuance of Trial; work on preparations for B. Edwards' deposition; continue working on trial strategies KBR Prepare for conference for compliance with Local Rule No. 4 to 0.50 375.00 confer with opposing counsel before noticing hearing by review of J. 750.00/hr Scarola's proposed Pre-Trial Stipulation and last version of Motion to Continue Trial KBR Telephone call with J. Scarola re J. Epstein's request for continuation 0.20 150.00 of trial and Pre-Trial Stipulation 750.00/hr KBR Meet with trial team, Gunster counsel and J. Epstein at J. 2.60 1,950.00 Goldberger's office to discuss trial strategies, client testifying at trial 750.00/hr and probable cause at commencement of action KBR Analyze case law regarding malicious prosecution and standard for 1.20 900.00 damages v. defamation per se 750.00/hr KBR Analyze prior deposition transcripts for B. Edwards in anticipation of 2.20 1,650.00 Friday's deposition 750.00/hr EFTA00804038 Jeffrey Epstein Page 2 Hrs/Rate Amount 11/6/2017 KBR Analyze motions chart, hearing chart and Motion for Summary 1.60 1,200.00 Judgment evidence identified at 10/3/17 hearing 750.00/hr AMM Analyze transcript of proceedings dated October 3, 2017, Volume II 4.80 1,896.00 (252 pages) re J. Epstein's Motion to Overrule Objections and 395.00/hr Compel B. Edwards to answer questions in preparation of B. Edwards' upcoming deposition AMM Prepare summary of Judge's ruling from the October 3, 2017 hearing 1.90 750.50 re J. Epstein's Motion to Overrule Objections and Compel B. 395.00/hr Edwards to answer questions in preparation of B. Edwards' upcoming deposition KBR Review executed Order Specially Setting Hearing from Judge Donald 0.10 75.00 Hafele 750.00/hr 11/7/2017 TLC Work on Motion to Compel; follow up with T. Haddad re production 9.50 2,137.50 issues; communications with D. Indyke re production and status; 225.00/hr continue working on assembling exhibits for B. Edwards' deposition; revise R. Critton's Affidavit and prepare Notice of Filing same; work on proposed Orders for hearing; work on chronologies SJL Work on preparations for B. Edwards' deposition; work on Motion to 9.20 6,900.00 Compel and Pre-Trial Stipulation; work on preparations for hearing 750.00/hr on Motion to Continue KBR Analyze B. Edwards' Press Releases dated 5/14/13 0.40 300.00 750.00/hr KBR Analyze B. Edwards' website for deposition regarding damages claim 0.30 225.00 750.00/hr KBR Analyze Florida law establishing malicious prosecution as actionable 1.60 1,200.00 per se for damages 750.00/hr KBR Prepare for hearing on Motion to Continue and evaluate all pending 2.40 1,800.00 discovery matters and motions in limine for 11/29/17 hearing 750.001hr KBR Prepare for 11/8/17 hearing on Motion to Bifurcate based on 1.20 900.00 probable cause and overlapping facts of J. Epstein's abuse of 750.00/hr process action against Rothstein in order to remove the "mini-trial" issue AMM Analyze Volume I of II deposition transcript of B. Edwards (147 3.20 1,264.00 pages) dated March 23, 2010 re summary of damages 395.00/hr AMM Analyze Volume II of II deposition transcript of B. Edwards (164 3.40 1,343.00 pages) dated March 23, 2010 re summary of damages 395.00/hr AMM Analyze deposition transcript of B. Edwards (102 pages) dated May 1.90 750.50 15, 2013 re summary of damages 395.00/hr EFTA00804039 Jeffrey Epstein Page 3 Hrs/Rate Amount 11/7/2017 AMM Prepare page/line damage summary re B. Edwards deposition 1.10 434.50 testimony dated March 23, 2010 395.00/hr AMM Prepare page/line damage summary re B. Edwards' deposition 0.80 316.00 testimony dated May 15, 2013 395.00/hr 11/8/2017 TLC Continue working on preparations for B. Edwards' deposition; work 11.20 2,520.00 on timeline of key events; work on background search of B. 225.00/hr Edwards; work on assembling trial exhibits; work on identifier of key people SJL Prepare for and attend uniform motion calendar hearing on Motion 8.80 6,600.00 for Continuance of Trial and Joint Motion to Dispense with Mediation; 750.00/hr work on preparations for B. Edwards' deposition AMM Analyze deposition transcript of B. Edwards (134 pages) dated 3.10 1,224.50 October 10, 2013 re summary of damages 395.00/hr AMM Prepare page/line damage summary re B. Edwards' deposition 0.80 316.00 testimony dated October 10, 2013 395.00/hr 11/9/2017 TLC Work on letter to judge re pending motions; assemble same and 12.50 2,812.50 prepare notebook for judge; continue working on assembling trial 225.00/hr exhibits; prepare letter to J. Scarola re same; continue working on assembling exhibits for B. Edwards' deposition; work on comparison chart of witnesses identified on various lists; prepare timeline of B. Edwards' involvement SJL Meet with D. Indyke; prepare for B. Edwards' deposition 10.50 7,875.00 750.00/hr 11/10/2017 TLC Prepare for and attend deposition of B. Edwards; telephone 11.20 2,520.00 conference with C. Edwards re trial exhibits 225.00/hr SJL Prepare for and conduct deposition of B. Edwards 13.70 10,275.00 750.00/hr KBR Prepare for and attend deposition of B. Edwards; prepare 10.50 7,875.00 Supplement to Motion for Continuance of Trial to address B. 750.00/hr Edwards' Amended Exhibit and Witness Lists AMM Analyze case law in support of our Supplemental Motion for 1.10 434.50 Continuance pursuant to Rule 1.460 of the Florida Rules of Civil 395.00/hr Procedure AMM Conduct research re how do we authenticate website articles and 2.10 829.50 website postings 395.00/hr AMM Prepare memo to K. Rockenbach re how we authenticate website 0.40 158.00 articles and waste postings 395.00/hr EFTA00804040 Jeffrey Epstein Page 4 Hrs/Rate Amount 11/11/2017 SJL Follow up on trial strategies and work on Pre-Trial Stipulation and 4.70 3,525.00 Jury Instructions 750.00/hr KBR Work on Pre-Trial Stipulation, Jury Instructions and Verdict Forms; 3.80 2,850.00 follow up on B. Edwards' deposition 750.00/hr 11/12/2017 TLC Work on deposition designations and organizing all witness files; 10.20 2,295.00 work on updating trial notebooks; work on new Exhibit List; attend 225.00/hr team strategy meeting/call; follow up on issues resulting from same SJL Work on trial strategies and research following B. Edwards' 6.10 4,575.00 deposition; participate in team strategy meeting 750.00/hr KBR Participate in team strategy meeting; continue working on Pre-Trial 5.30 3,975.00 Stipulation and Jury Instructions; continue working on trial strategies; 750.00/hr review pending motions in preparation of hearing 11/13/2017 TLC Work on Request to Produce and Interrogatories to B. Edwards re 13.50 3,037.50 newly disclosed experts; prepare Notice of Production from 225.00/hr Non-Parties and Subpoenas Duces Tecums directed to R. Josefsberg, C. Lichtman, S. Kuvin, T. Leopold, A. Horowitz, I. Garcia, E. Cote and W. Berger; work on Motion to Shorten Time to respond to same; prepare proposed Order; follow up with D. Indyke on Motions to Withdraw by other co-counsel; finalize package to judge on pending Motions; follow up with J. Scarola on setting experts' depositions; work on revised Exhibit List and assembling same; participate in strategic telephone call; follow up on multiple inquiries from Gunster team SJL Work on deposition designations; work on discovery requests and 10.20 7,650.00 Motion to Shorten Time; work on trial strategies; participate in 750.00/hr strategy telephone call; follow up on issues relating to same KBR Work on response to Request for Judicial Notice; work on Pre-Trial 7.60 5,700.00 Stipulation and Jury Instructions; participate in team strategy 750.00/hr conference; work on preparations for hearings on pending Motions; work on judge's package 11/14/2017 SJL Work on deposition designations; work on Pre-Trial Stipulation, Jury 7.80 5,850.00 Instructions and Verdict Form; multiple communications with J. 750.00/hr Scarola re new trial setting; follow up with client and Gunster trial team on new focus group; work on trial and hearing strategies; review pending motions in preparation for upcoming hearing; work on outline of outstanding issues to address TLC Continue working on Amended Exhibit List and assembling items 12.20 2,745.00 listed on same; on-line research of various cases to pull documents; 225.00/hr follow up with team on revisions; work on Amended Witness List; work on list of pending Motions in light of Judge's granting Motion for Continuance; prepare outline of new pre-trial dates; work with Gunster team on various document issues; participate in team telephone conference; work on deposition designations; prepare EFTA00804041 Jeffrey Epstein Page 5 Hrs/Rate Amount Notice of Deposition and Subpoena Duces Tecum for Dr. Jansen; follow up with J. Scarola re same; work on trial notebooks 11/14/2017 KBR Work on response to B. Edwards' Request for Judicial Notice; work 6.50 4,875.00 on Exhibit List; telephone conferences with J. Scarola re special set 750.00/hr hearings; follow up on same; participate in team telephonic strategy meeting in light of Judge's granting Motion for Continuance 11/16/2017 AMM Prepare Response in Opposition to B. Edwards' Unilateral Pre-Trial 1.40 553.00 Stipulation 395.00/hr 11/17/2017 SJL Work on Omnibus Motion in Limine and Appendix; work on 8.40 6,300.00 Response to B. Edwards' Request for Judicial Notice; multiple 750.00/hr communications with Gunster team and clients; telephone conference with J. Scarola re list of pending motions; telephone conference with J. Epstein TLC Work on Response to B. Edwards' Request for Judicial Notice; work 9.80 2,205.00 on comprehensive Omnibus Motion in Limine and Appendix; work on 225.00/hr creating Appendix of documents and locating same; email with D. Vitale re depositions; work on list of pending motions and multiple communications with J. Scarola; follow up with submission to Judge Hafele; work on updating trial binders 11/18/2017 SJL Work on preparation for hearing on all pending motions; work on trial 3.50 2,625.00 plan 750.00/hr TLC Work on trial plan; work on organizing trial exhibits; work on updating 7.00 1,575.00 all trial binders; work on preparation for hearing on all pending 225.00/hr motions; work on locating history of J. Epstein's responses to B. Edwards' Motion for Summary Judgment in order to respond to Motion to Compel 11/20/2017 TLC Continue working on trial plan; continue working on Appendix of 9.50 2,137.50 documents in support of our Revised Omnibus Motion in Limine; 225.00/hr continue working on trial binders and trial exhibits; work on preparations for special set hearing on all pending motions SJL Telephone conferences with D. Indyke and J. Epstein re case plan; 8.60 6,450.00 work on case plan; work on preparations for special set hearing on 750.00/hr all pending motions; work with Gunster on responses to outstanding motions LD Work on Discovery Chart of B. Edwards' discovery requests directed 7.00 1,575.00 to J. Epstein and J. Epstein's responses 225.00/hr LD Work with T. Campbell to assemble a discovery package to be 0.50 112.50 provided to Gunster team 225.00/hr 11/21/2017 TLC Work on finalizing comprehensive Appendix in support of our 11.20 2,520.00 Omnibus Motion in Limine; prepare Request for Judicial Notice; 225.00/hr prepare Notices of Filing B. Edwards' deposition transcripts; prepare proposed Orders for hearing on B. Edwards' Motion to Reconfirm EFTA00804042 Jeffrey Epstein Page 6 Hrs/Rate Amount Pre-Trial Deadlines; work on preparation for hearing; prepare cover letter to Court; follow up with Gunster on hearing logistics; work on locating additional discovery documents for their use in responding to B. Edwards' Motion to Compel; telephone conference with D. Indyke re Orders granting Motions to Withdraw of T. Haddad and F. Haddad; work on proposed Orders; follow up with J. Scarola re entry of Orders; prepare letter to judge re same; work on Proposal for Settlement 11/21/2017 SJL Meet with J. Epstein; work on preparations for special set hearings; 10.20 7,650.00 work on Proposal for Settlement; follow up with D. Indyke; follow up 750.00/hr with Gunster team re responses to outstanding motions; work on same; work on Stipulated Issues of Fact LD Continue working on discovery chart of B. Edwards' discovery 3.70 832.50 requests directed to J. Epstein and J. Epstein's responses 225.00/hr 11/22/2017 TLC Work on Response to B. Edwards' Motion for Protective Order re C. 12.20 2,745.00 Wild; work on Omnibus Response to B. Edwards' Motion to Compel; 225.00/hr work on Response to B. Edwards' Motion in Limine; follow up with D. Indyke re same; work with Gunster on hearing and judge submission logistics; work on letter to court; work on Proposal for Settlement SJL Work on Response to B. Edwards' Motion for Protective Order re C. 12.70 9,525.00 Wild and Response to B. Edwards' Motion in Limine; work on 750.00/hr preparations for special set hearings; communications with D. Indyke and Gunster team; follow up with J. Epstein; work on Proposal for Settlement; review Responses filed by B. Edwards KBR Work on Response to B. Edwards' Motion for Protective Order re C. 10.20 7,650.00 Wild and Response to B. Edwards' Motion in Limine; work on 750.00/hr preparations for special set hearing; work on Request for Judicial Notice and proposed Orders for UMC hearing on B. Edwards' Motion to Reconfirm Pre-Trial Deadlines; work on preparations for same 11/25/2017 TLC Work on demonstratives and timelines for hearing; work on other 5.00 1,125.00 hearing preparations 225.00/hr 11/26/2017 TLC Work on Response to B. Edwards' four Motions to Compel; 5.50 1,237.50 communications with D. Indyke re information needed for hearings; 225.00/hr work on comprehensive timeline and demonstratives for hearings; review documents and transcripts for information to use in same SJL Work on Response to B. Edwards' four Motions to Compel; 6.00 4,500.00 communications with D. Indyke; work on issues related to Proposal 750.00/hr for Settlement; work on demonstratives for hearing; work on hearing preparations KBR Analyze B. Edwards' four Motions to Compel and underlying 7.20 5,400.00 discovery (Interrogatories, Requests for Production and Requests 750.00/hr for Admission) as well as interlocutory orders for in camera in 2013 and confidentiality and rehearing on confidentiality; analyze hearing transcript from 9/16/13 and resulting order dated 11/15/13 to revise EFTA00804043 Jeffrey Epstein Page 7 Hrs/Rate Amount the Response to four Motions to Compel; revise/finalize our Response to four Motions to Compel; analyze B. Edwards' 14 page Response in Opposition to J. Epstein's Revised Omnibus Motion in Limine for first time referencing "burden of proof shifting" argument; analyze case law re elements for malicious prosecution and search for any reported decisions under any circumstances referencing burden of proof shift; legal research/gather jury instructions for malicious prosecution v. defamation to illustrate B. Edwards' attempt to try a defamation action; legal research re impact of confidentiality clause in a release attached to a Proposal for Settlement 11/27/2017 TLC Prepare letter to court re additional hearing submissions; finalize 10.20 2,295.00 Proposal for Settlement for $2 million and serve same; update 225.00/hr calendar re deadline to respond; prepare history of B. Edwards' Renewed Motion for Summary Judgment and filings surrounding it before J. Epstein dismissed claims; review B. Edwards' Deposition Designations for J. Epstein's testimony for 1/5/12 and 3/17/10, and highlight same in preparation of hearing; review history of attempts to take J. Epstein's deposition; work on Stipulated Issues of Fact for Pre-Trial Statement; review B. Edwards' testimony for cites to include in same; work on demonstratives and timelines; work on hearing notebooks; strategize with S. Link K. Rockenbach re hearing; work on summary of discovery of case during RRA SJL Work on preparations for hearing on all outstanding Motions; work 10.50 7,875 00 on finalizing Proposal for Settlement; work on finalizing Response to 750.00/hr B. Edwards' Motions to Compel; multiple telephone conferences with client and D. Indyke re strategies; work on demonstratives and timelines for hearing; review designations of J. Epstein's testimony upon which B. Edwards plans to rely; team meeting with K. Rockenbach and T. Campbell re hearing strategies KBR Prepare for and attend hearing on B. Edwards' Motion to Reconfirm 6.30 4,725.00 Pre-Trial Deadlines; prepare for 11/29/17 hearing on pending 750.00/hr motions; review motions and overview of argument outlined by S. Link; strategize for best argument on the Fifth Amendment; analyze "public record" documents, including U.S. Attorney's Amended Complaints, Razorback Complaints, news articles to support the "probable cause" and reasonable belief component 11/28/2017 TLC Continue working on preparation for hearings on pending motions; 10.30 2,317.50 review B. Edwards' Exhibit List to identify and highlight highly 225.00/hr prejudicial documents for use at hearing; assemble additional items for hearing; work on summary of E.W. case against J. Epstein; work on locating equipment for hearing; prepare Notice of Supplemental Authority to our Objection to B. Edwards' Request for Judicial Notice; review J. Epstein's deposition transcripts and prepare various highlighted scenarios, i.e., questions to which he asserted the Fifth Amendment to and those where he provided substantive answers; review V. Roberts' Complaint for allegations relating to her travel on the plane; review summary judgment filings to determine if B. Edwards ever moved to strike September 2013 Affidavit of J. Epstein; prepare comparison of 2013 and 2017 Affidavits of J. EFTA00804044 Jeffrey Epstein Page 8 Hrs/Rate Amount Epstein; prepare timeline of J. Epstein's testimony follow up with co-counsel's office on hearing logistics 11/28/2017 SJL Communications with client; work on demonstratives for hearing; 11.20 8,400.00 work on hearing preparations for Fifth Amendment issues and 750.00/hr Omnibus Motion in Limine; review B. Edwards' 2011 summary judgment filings; review V. Roberts' litigation KBR Prepare for first of three special set hearings on pending motions (J. 12.50 9,375.00 Epstein's Omnibus Motion in Limine, B. Edwards' Motion in Limine to 750.00/hr Strike the June 30, 2017, Affidavit of J. Epstein, and B. Edwards' Motion in Limine Addressing Scope of Admissible Evidence) 11/29/2017 TLC Update calendar on pending dates and prepare email to D. Indyke re 10.20 2,295.00 same; work on hearing preparations; attend hearing on Fifth 225.00/hr Amendment issues and our Omnibus Motion in Limine SJL Meet with J. Goldberger and D. Indyke in preparation for hearing; 12.50 9,375.00 prepare for and attend hearing on Fifth Amendment issues and our 750.00/hr Omnibus Motion in Limine; follow up on same; telephone conference with J. Epstein re status KBR Meet with J. Goldberger and D. Indyke in preparation for hearing; 11.50 8,625.00 prepare for and attend hearing on Fifth Amendment issues and our 750.00/hr Omnibus Motion in Limine; follow up on same For professional services rendered 479.70 $249,797.50 Additional Charges : 10/26/2017 Palm Beach Copy Inv. No. 130291 1,080.41 11/8/2017 Palm Beach Copy Inv. No. 130500 172.54 Palm Beach Copy Inv. No. 130497 165.32 Palm Beach Copy Inv. No. 130509 137.12 Palm Beach Copy Inv. No. 130512 227.54 Palm Beach Copy Inv. No. 130516 225.07 Parking 5.00 11/10/2017 Trial Project Copying 97.50 11/14/2017 Palm Beach Copy Inv. No. 130600 1,073.32 11/15/2017 B. Edwards' Deposition Trans. 11/10/17 Palm Beach Reporting Services, Inc. 2,068.58 EFTA00804045 Jeffrey Epstein Page 9 Amount 11/16/2017 Trial Supplies 42.79 11/17/2017 Trial Project Copying 107.50 11/18/2017 Trial Project Copying 70.00 11/22/2017 Deposition Video 11/10/17 B. Edwards - Visual Evidence 1,637.94 11/28/2017 Misc. Hearing Equip. Rental - PBC Law Library 100.00 Misc. Hearing Equip Rental - Palm Beach County Law Library 100.00 11/29/2017 11/8/17 Court Reporter Attendance (Hearing Judge Hafele) 90.00 Total costs $7,400.63 Total amount of this bill $257,198.13 Previous balance $194,971.50 11/13/2017 Payment of Invoice No. 32937 ($194,971.50) Total payments and adjustments ($194,971.50) Balance due $257,198.13 EFTA00804046