EFTA01102373.pdf

Copy Invoice Invoice Date: Invoice No. 9/30/2013 698 Terms Due Date Law Office of Tonja Haddad, PA NET 20 days 10/20/2013 315 SE 7th Street Fort Lauderdale. FL 33301 954.467.1223 Bill to Darren Indyke Jeffrey Epstein 575 Lexington Avenue New York 10022, New York 10022 Matter Name Billing Type Rate Rothstein/Edwards Hourly billing 425.00 Amount Total hours: 217.25 75,956.25 Work Hours Date Description Hours 8/29/2013 Read Goldberger Motion to Disqualify and begin 3.50 research on our Motion to Disqualify Brad. 8/29/2013 Finalie and send 57.105 Letter and Motion. 1.30 Review Motion to Disqualify. Review Darren's comments to Motion to Compel. 8/30/2013 Review documents and review witness list- send to 0.40 co-counsels. 9/3/2013 Review and respond to multiple communications 5.30 from client and co-counsels. Continue drafting Motion to Disqualify Brad Edwards as co-counsel and send to Darren. Review Federal Indictments re: Rothstein. 9/4/2013 Hours worked by law clerk/paralegal for August- 10.20 10.2 hours at $50.00 per hour. 9/4/2013 Read brief to 11th circuit re: US case. 1.20 Review case law regarding recusal when attorney as client. 9/6/2013 File Response to negative Inference Motion. 1.50 9/8/2013 Prepare for and attend meeting with client. 4.20 Page No.1 No tax has been charged EFTA01102373 Work Hours Date Description Hours 9/9/2013 Finalize and file Motion to disqualify Edwards. 7.80 Research and draft Motion for Leave to assert Advice of Counsel as Affirmative Defense. 9/9/2013 Review trial and exhibit list and draft letter to 2.00 Scarola. 9/10/2013 Review Amended Exhibit list and compare to 2.20 original exhibit list. Send same to clients. Revise Motion re: Affirmative Defenses to conform with evidence and send to co-counsels for erview. 9/10/2013 Review letter from Scarola regarding 4.50 disqualification. Draft Agreed Order re: Motion to Disqualify Edwards. Review Darren's comments to Motion to Amend Affirmative Defenses and Amended Affirmative Defenses, and revise same.Teleconference with DKI regarding same. 9/11/2013 Review and respond to multiple communications 1.50 from opposing counsel. Review discovery requests, subpoenas and motions from Scarola. 9/11/2013 Revise and send Motion for Leave to Amend. 2.50 Proposed Amended Answer, and Proposed Agreed Order regarding same. Review Motion to Continue from Fred Haddad. Send letter to co-counsels regarding Motion to Compel and Motion. 9/12/2013 Conduct additional discovery for Motion for 3.50 Summary Judgment 9/12/2013 Contnue research for Summary Judgment for 4.50 facts. 9/12/2013 Begin Drafting Motion for Summary Judgment. 6.50 9/13/2013 Multiple communications with Darren and co- 5.50 counsels and client regarding case. Review communications from Scarola. Review Motion to continue trial. Revise Motion for Leave to amend and file- hearing September 17. 9/15/2013 Revise and continue researching Summary 5.50 Judgment Motion. 9/16/2013 Conduct additional research for hearing. 1.50 9/16/2013 Attend hearings on Motion for Leave to Amend and 4.50 Motion for Adverse Inference and Evidence Preclusion. 9/16/2013 Multiple communications with Darren and co- 1.50 counsel regarding hearings and advice of counsel. 9/16/2013 Review Reply Motion filed by Scarola. Review and 1.50 respond to multiple communications regarding same. Teleconference with Darren regarding communicaitons. 9/17/2013 Teleconferences with Darren and Jeffrey regarding 1.50 cases. 9/17/2013 Research regarding deposition and adverse 4.50 inference and 5th amendment re: Scarola's Motion. Page No.2 No tax has been charged EFTA01102374 Work Hours Date Description Hours 9/18/2013 Research and draft Objection to Subpoenas. 4.50 9/18/2013 Revise Summary Judgment. 3.50 9/18/2013 Review and respond to communications. Revise 2.80 trial objections to exhibits. 9/19/2013 Revise discovery responses and Summary 1.50 Judgment. Send to Darren. 9/19/2013 Read Court Pleadings and depositions for facts for 5.20 Motion for Summary Judgment. Revise Motion for Summary Judgment. 9/19/2013 Revise and send Objection to Subppenas to non- 2.50 party witnesses. Revise Trial exhibit objections. 9/20/2013 Review request to produce and send to client. 3.50 Review multiple communications from Scarola. Respond to same. Review Scarola's objections to Epstein's exhibit and witness lists. 9/21/2013 Research, draft, and file Motion to Quash and for 6.50 Sanctions. Review and respond to multiple communications from client and co-counsels. 9/22/2013 Read Epstein Deposition. Revise and continue 8.60 research on Summary Judgment. Review and repsond to multiple communications from opposing counsel, co-counsels, and Darren. 9/23/2013 Revise Summary Judgment and send to co- 6.20 counsels. Review Pre-Trial Stipulation; make changes and send to co-counsels. 9/24/2013 Communications with Darren. 3.75 Revise Summary Judgment. 9/24/2013 Revise and finalize Motion for Summary Judgment. 6.40 9/25/2013 Finalize and send Summary Judgment. 3.75 Complete Exhibit List. 9/25/2013 Revise Motion to Compel. 5.50 9/25/2013 Review and revise Jeffrey affidavit. 1.75 Communications with Darren. 9/25/2013 Communications with Roy Black's office regarding 0.50 subpoenas and case. 9/25/2013 Revise Motion to Compel and Pre-Trial Stipulation. 4.20 9/25/2013 Revise and file documents. 2.20 Communications with Jeffrey and co-counsels regarding Stay. 9/26/2013 Research and draft Motions in Limine. 9.30 Revise Pre-Trial Stipulation, review Scarola's changes, and revise again. Communications with client and co-counsels. 9/27/2013 Review ermails from co-counsels and opposing 4.50 counsels. Review documents filed by opposing counsel. Teleconference with co-counsels. Finalize and File Deposition Designation and Motion in Limine. 9/30/2013 Work performed by Debra Fein- 32 Hours at 32.00 Page No.3 No tax has been charged EFTA01102375 Work Hours Date Description I Hours 150.00 per hour (see attached timesheet). 9/30/2013 Work performed by Law Clerk in September- 10 10.00 hours at $50.00 per hour. Total hours: 217.25 Expenses Date Description 9/9/2013 Overnight mail to judge for September 16 hearing. 15.00 9/12/2013 Fed Ex Order to Judge re: Edwards Disqualification 23.45 9/30/2013 Copies for Summary Judgment Motion. 1406 351.50 pages at .25 per page. Total expenses: Subtotal 389.95 Amount 75,956.25 Subtotal 76,346.20 Tax 0.00 Previous Retainer Balance 10,000.00 Total Due 66,346.20 Page No.4 No tax has been charged EFTA01102376