EFTA00799145.pdf

Wire Confirmation The wire transfer request below has been transmitted successfully. Transmitted: 06/08/2018 12:25:37 PM (ET) Transmitted By: BELLAKLEIN Account Template Name Recipient Name Amount Currency Effective Approval Date Number Status Jeffrey Epstein - JEE to Link and Link and 187,219.23 USO 06/08/2018 153892291 1 of 1 received NOW -'9691 Rockenbach PA Rockenbach, P.A. EFTA00799145  LINK& 1555 Palm Beach Lakes, Blvd., Suite 930 la ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW West Palm Beach, FL 33401 TEL: (561) 847-44081FAX: (561) 855-2891 Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank Il Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: Beneficiary Name: Link & Rockenbach, Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account EFTA00799146  LINK& 1555 Palm Beach Lakes, Blvd., Suite 930 la ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW West Palm Beach, FL 33401 TEL: (561) 847-4408 I FAX: (561) 855-2891 May 22, 2018 Via Emai► -frevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, B3 St Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: Attached please find our firm's billing statement for services rendered through April 30, 2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the amount of $800.00 ($100.00 x 8 hours). The line items beginning with "No Charge" reflect an additional reduction in the amount of $7,078.50 making the total reduction $7,878.50. Please do not hesitate to call me if you have any questions regarding this bill. Thank you. Very truly yours, / Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00799147  unn LX rn 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Beach, FL 33401 Jeffrey Epstein May 7, 2018 6100 Red Hook Quarter, B3 Invoice # 559 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services Hours Amount 03/04/18 RJG Discuss drafting of certiorari and mandamus petitions 1.50 592.50 and emergency motion for stay with K. Rockenbach to have in the pipeline, pending outcome of 3/8/18 hearing; review appellate rules of procedure on certiorari and mandamus relief and Fourth District Court of Appeal's Administrative Order re requests for emergency relief 03/04/18 SJL Work on strategies re case not at issues, Petition for 9.50 7,125.00 Certiorari review, moving for default, etc.; work on documents re same; multiple communications with J. Scarola re production issues; follow up with client re same; work on Clerk's Trial Exhibit List 03/19/18 KBR Finalize Reply in support of Petition for Writ of 0.80 600.00 Mandamus 03/23/18 TMB [No Charge] Work on exhibits and finalize Motion to 0.30 0.00 Strike B. Edwards' Notice for Trial and Objection to B. Edwards' Unilaterally Changing Case Style 04/02/18 PVD [No Charge] Work on updating Orders' binder 1.50 0.00 04/02/18 PVD [No Charge] Work on Trial Exhibits 4.40 0.00 04/02/18 TLC Work on hearing folders and packages to Court; work 6.40 1,440.00 on Motion for In Camera Inspection; prepare insurance demand; check Bankruptcy Court docket and follow up on hearing setting of Intervenors' motions; begin working on response to same; work on Response to B. Edwards' Motion for Appellate Attorneys' Fees EFTA00799148  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 2 Date Services Hours Amount 04/02/18 SJL Work on Responses to Farmer Jaffe's and the 7.50 5,625.00 Intervenors' Show Cause Motions in bankruptcy court; follow up on additional hearing settings; follow up with bankruptcy counsel; communications with clients; work on issues relating to in camera review; follow up on insurance policy 04/03/18 RJG Review/analyze Edwards' Motion to Strike improper 2.50 987.50 references to alleged contents of privileged documents from Epstein's filings in the certiorari and mandamus proceedings, review filings and hearing transcripts mentioned in the Motion, and outline Response in Opposition 04/03/18 PVD [No Charge] Work on hearing binder re Farmer 1.50 0.00 l e's Motion to Show Cause, Edwards' Joinder, , E.W. and Jane Doe's Joinder and Motion to ervene 04/03/18 PVD [No Charge] Work on exhibit of comparison of 5.60 0.00 privilege log for in camera inspection; work on Exhibit A re documents from Epstein's 3/5/18 Clerk's Trial Exhibit List Seeking In Camera Review - Compared to Privilege Log 04/03/18 TLC Work on Motion for In Camera Review to incorporate 9.50 2,137.50 D. Indyke's thoughts and comments; work on exhibits to same, including comparison of privilege log to trial exhibit entries; work on insurance policy demand letter, work on proposed Sealing Order and circulate to opposing counsel for review in advance of hearing; work on Response to Farmer Jaffe's Motion to Show Cause in bankruptcwork on Response to Joinder filed by Intervenors ., E.W. and Jane Doe 04/03/18 SJL Work on insurance demand to Fowler White; work on 8.60 6,450.00 Motion for In Camera Review; review proposed Sealing Order, work on preparations for April 4, 2018, UMC hearing on B. Edwards' Motion to Change Case Style and Case Management; review B. Edwards' Motion for Sanctions; work on Response to Motion to Show Cause in Bankruptcy; follow up with bankruptcy counsel and D. Indyke re same; review Motions to Strike filed in appellate proceedings; communications with P. Cassell re proposed sealing order and no authority to add Intervenors to caption EFTA00799149  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 3 Date Services Hours Amount 04/03/18 MLP [No Charge] Work on preparing Exhibit A of J. 3.40 0.00 Epstein's Motion for In Camera Inspection by analyzing B. Edwards' privilege log in order for the court to utilize and compare the privilege log entries with the actual documents they claim to represent in order to emphasize the deficiencies and misrepresentations within the privilege log and the need for an In Camera Inspection of certain documents. 04/04/18 RJG Legal research on Florida procedural rules and case 2.60 1,027.00 law on "captions", "parties" and "limited intervention," to dete# ' e whether caption must be amended to reflect, E.W. and Jane Doe as intervenors; review analyze case law cited by Intervenor's counsel and hearing transcript re trial court's ruling on amending case style; draft memo to partners re same 04/04/18 RJG Draft/revise Motion to Maintain Current Case Style 1.30 513.50 04/04/18 RJG Review trial court's Order on B. Edwards' Motion for 0.10 39.50 Adverse Inference Instruction entered April 4,2018 04/04/18 RJG Discuss strategy for Response in Opposition to B. 2.50 987.50 Edwards' Motion to Strike Alleged Improper References to Contents of Purportedly Privileged Documents; draft/revise Response 04/04/18 PVD [No Charge] Continue work on hearing binder for 4.70 0.00 Motion to Show Cause, B. Edwards' Joinder, E.W. and Jane Doe's Joinder and M., E.W. an iii, 4/13/18 Bankruptcy Court hearing re Farmer Jaffe's Jane Doe's Motion to Intervene 04/04/18 PVD [No Charge] Review Motion for In Camera Review for 2.70 0.00 filing; work on finalizing Exhibit A to Motion for filing EFTA00799150 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 4 Date Services Hours Amount 04/04/18 TLC Work on finalizing Motion for In Camera Review; 8.00 1,800.00 work on Exhibit A to same which compares 47 e-mails (proposed trial exhibit privilege log entries; work on Response to ., E.W. and Jane Doe's Joinder in bankruptcy Motion to Show Cause; work on Response to Farmer Jaffe's Motion to Show Cause; work on proposed Order Sealing disc and exhibits; circulate it to opposing counsel and address additional comments; follow up with opposing counsel on cancellation of UMC hearing on 4/5/18; work on Motion to Maintain Case Style; send draft to D. Indyke; work on preparations for Case Management hearing; update dates and motions list 04/04/18 SJL Work on finalizing Motion for In Camera Review; 6.50 4,875.00 work on Re nses to Farmer Jaffe's Motion to Show Cause and E.W. and Jane Doe's Joinder in bankruptcy Motion to Show Cause; communications with client and D. Indyke; review new authorities re waiver of work product; prepare for UMC hearing on case management; communications with D. Vitale re proposed sealing order, work on Motion to Maintain Case Style; follow up with J. lanno re Fowler White's Insurance policy 04/04/18 KBR Prepare e-mail to D. Vitale se style and 0.90 675.00 dismissal with prejudice of in 2010; analyze case law re case style change in preparation for UMC hearing on B. Edwards' Motion to Change Case Style; revise Motion to Maintain Current Case Style 04/05/18 RJG Review/analyze 3/23/18 decision from the Eleventh 1.30 513.50 Circuit (Drummond v. Conrad & Scherer), and draft Notice of Supplemental Authority in support of J. Epstein's Motion for In Camera Review 04/05/18 RJG Revise Notice of Supplemental Authority In support of 0.70 276.50 Motion for In Camera Review 04/05/18 RJG Legal research on federal case law for proposition 2.00 790.00 that a client cannot be sanctioned or held responsible for a law firm's violation of a court order when the client knew nothing about it; draft memo re same 04/05/18 RJG Review Fourth District Court of Appeal Order denying 0.10 39.50 B. Edwards April 3, 2018 Motion to Strike EFTA00799151  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 5 Date Services Hours Amount 04/05/18 PVD [No Charge] Continue work on hearing binder for 3.40 0.00 4/13/18 Bankruptcy Court hearing re combined Table of Authorities 04/05/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 1.00 0.00 for compliance 04/05/18 SJL Attend case management UMC hearing; follow up 9.30 6,975.00 with D. indyke and J. Epstein re same; work on Response to show cause filings in Bankruptcy Court; meet with J. lanno re disc; work on Response to Farmer Jaffe's Motion for Order to Show Cause; work on Response to Intervenor's Joinder; communications with client and D. Indyke 04/05/18 TLC Prepare letter and package to Judge Hafele re 7.80 1,755.00 Agreed Order Directing Clerk to Seal Filings; prepare Notice of Cancellation of UMC hearing; meet with J. lanno re disc; work on Response to Farmer Jaffe's Motion for Order to Show Cause; work on Response to Intervenor's Joinder; work on schedule of hearings to submit to judge 04/05/18 KBR Prepare for and attend case management 0.90 675.00 conference 04/06/18 PVD (No Charge] Continue review of Clerk's Trial Exhibits 2.20 0.00 for compliance 04/06/18 PVD [No Charge] Review J. Epstein's Response In 1.50 0.00 Opposition to Farmer Jaffe's Motion to Show Cause 04/06/18 PVD [No Charge] Resume work on hearing binder for April 0.30 0.00 13th Bankruptcy Court hearing re Table of Authorities re Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause 04/06/18 SJL Telephone conferences and e-mails with D. Indyke; 8.30 6,225.00 work on Response to bankruptcy filings by Farmer Jaffe, B. Edwards and the Intervenors; work on hearing schedule; follow up with J. Epstein re bankruptcy response EFTA00799152 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 6 Date Services Hours Amount 04/06/18 TLC Work on assembling exhibits and preparing index to 7.80 1,755.00 same for our Response to Farmer Jaffe's Motion for Order to Show Cause and B. Edwards' Joinder; work on Response to incorporate D. lndyke's suggested changes and comments; follow up on D. Indyke's questions in Response (amount paid to Special Master and location of disc within production); review Bankruptcy Court rules re appearance of non-registered users; follow up with D. Indyke on C. Pugatch's fee agreement; telephone conference with C. Pugatch re filing logistics; work on motion chart; prepare e-mail to counsel to follow up on same 04/08/18 SJL Communications with client; work on Responses in 3.50 2,625.00 Bankruptcy Court; work on preparations for hearing on same 04/09/18 TLC Prepare letter and package to Clerk re filing under 9.80 2,205.00 seal; work on Response to Farmer Jaffe's Motion for Order to Show Cause and B. Edwards' Joinder; work on Response to Intervenors' Joinder; check Bankruptcy Court docket; work on motions chart; follow up with D. Vitale re same 04/09/18 SJL Work on Response to Farmer Jaffe's Motion for 5.60 4,200.00 Order to Show Cause and B. Edwards' Joinder; work on Response to Intervenors' Joinder; telephone conferences with D. Indyke re same; communications with J. Epstein re bankruptcy responses and responding to Law360 reporter; prepare response to Law360 reporter, work on list of outstanding motions requested by court; communications with D. Vitale re same 04/10/18 PVD [No Charge] Update hearing binder for 4/13/18 5.80 0.00 Bankruptcy Court hearing re J. Epstein's Response In Opposition to Farmer, Jaffe's Motion for Order to Show Cause and Table of Authorities 04/10/18 PVD [No Charge] Update Orders binders; update hearing 6.60 0.00 binder for 4/13/18 bankruptcy hearing re docket entry cites referenced in filing; finalize Table of Authorities 04/10/18 KBR Work on Response to Intervenors' Joinder 0.50 375.00 EFTA00799153 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 7 Date Services Hours Amount 04/10/18 TLC Review Law360 website re article on bankruptcy 7.20 1,620.00 motions practice; work on preparations for UMC hearing on S. Rothstein's default; work on Response to Intervenors' Joinder; multiple communications with bankruptcy counsel on logistics, hearing and filing; follow up with opposing counsel on motions chart; work on to do list 04/10/18 SJL Work on Response to Intervenors' Joinder, 3.50 2,625.00 communications with D. Indyke and client; work on preparations for bankruptcy hearing 04/11/18 RJG Research trial court's failure to enter a default when 1.00 395.00 all conditions are satisfied; mandatory nature of default rule; mandamus as available remedy 04/11/18 PVD [No Charge] Review Clerk's Trial Exhibits for 0.50 0.00 compliance 04/11/18 TLC Work on To Do List; work on Response to B. 8.20 1,845.00 Edwards' Motion for Sanctions; review 3/8/18, hearing transcript for quotes to refer in same; review rules re using electronic filing credentials to file on behalf of others; review changes in B. Edwards' 3/9/18, Jury Instructions of those instructions we adopted and prepare summary of changes of same (i.e., B. Edwards removed "continuing" from his instructions and is now only focused on Instituting" the litigation); review discrepancies in V. Roberts' transcribed interview, follow up on how to proceed with same 04/11/18 SJL Work on To Do List; telephone conferences with D. 8.50 6,375.00 Indyke; review S. Rothstein's Motion to Dismiss; follow up with client re strategies relating to same; review rules re using electronic filing credentials and being bound by same; follow up with opposing counsel re position; telephone conference with Fowler White's counsel; communications with J. Goldberger; review Fowler White's Response to Farmer Jaffe's Motion to Show Cause in Bankruptcy Court; review changes in B. Edwards' Jury Instructions; work on preparations for bankruptcy hearing EFTA00799154 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 8 Date Services Hours Amount 04/11/18 KBR Prepare for and attend (waft per Judge Hafele for 2.30 1,725.00 attendance by M. Nurik) J. Epstein's Motion for Judicial Default Against S. Rothstein; prepare recap of UMC hearing and court's discussion/ruling 04/12/18 SJL Work on Motion for Leave to Amend Exhibit Lists; 6.20 4,650.00 work on preparations for bankruptcy hearing; strategize with D. Indyke and C. Pugatch (bankruptcy counsel); review B. Edwards' and Intervenors' late-filed Replies; consider options to move to strike; review bankruptcy rules re same; communications with client 04/12/18 TLC Check judge's availability for hearing on S. 7.80 1,755.00 Rothstein's Motion to Dismiss; continue reviewing rules re use of attorneys' electronic filing credentials; work on Response to B. Edwards' Motion for Sanctions; work on Motion for Leave to Amend Exhibit Lists; follow up with bankruptcy counsel re hearing; review B. Edwards' and Intervenors' late filed Replies in Bankruptcy Court; work on updating budget; work on motions list to submit to Court; prepare letter to Judge Hafele re same 04/13/18 TLC Work on updating budget; work on final preparations 5.20 1,170.00 for bankruptcy hearing; check Bankruptcy Docket to determine if any additional filings; work on Motion re leave to Amend Exhibit List 04/13/18 SJL Work on budget and To Do List; work on 9.60 7,200.00 preparations for hearing in Bankruptcy Court on Farmer Jaffe's Motion to Show Cause, B. Edward's Joinder and the Intervenors' Joinder; meet with C. Pugatch before hearing; attend and argue hearing; telephone conferences with J. Epstein and D. Indyke re outcome of same; follow up with P. Cassell re his proposed Order on intervention 04/16/18 RJG Review/analyze B. Edwards' Motion to Permit B. 1.10 434.50 Edwards to take the Limited Deposition of J. Epstein; begin researching whether ordering someone to appear for deposition means they are not subject to service for any other purpose EFTA00799155  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 9 Date Services Hours Amount 04/16/18 TLC Work on Motion to Strike Certain Witnesses and to 6.00 1,350.00 Compel B. Edwards to Identify Who Will be Called at Trial; follow up on ordering transcript of bankruptcy hearing; work on To Do List; review Motion to Compel J. Epstein's deposition 04/16/18 SJL Work on follow up to rulings made by Bankruptcy 7.50 5,625.00 Court; communications with C. Pugatch re same; review B. Edwards' Motion to allow J. Epstein's deposition; follow up with D. Indyke and J. Epstein re same; work on strategies; work on Motion to allow us to amend Exhibit List 04/17/18 RJG Legal research whether a party, If compelled by court 1.90 750.50 order to come to a jurisdiction, can be served with process for another purpose 04/17/18 TLC Follow up on bankruptcy evidentiary hearing 8.20 1,845.00 scheduling; work on Motion to Strike Certain of B. Edwards' Witnesses and to Compel Him to Identify Who Will be Called at Trial; review November 29, December 5 and December 7 hearing transcripts in order to cite Court's rulings relating to same; review B. Edwards' Witness Lists and discovery responses in order to cite to same; research trial by ambush and Florida Statutes re witness testimony 04/17/18 SJL Follow up on Bankruptcy Court setting evidentiary 5.20 3,900.00 hearing; multiple communications with C. Pugatch; work on Motion to Strike Certain of B. Edwards' Witnesses, etc.; work on Response to Motion for Sanctions; work on trial strategies; communications with client 04/18/18 MLP [No Charge] Work on analysis and comparison 4.30 0.00 between V. Roberts' recorded telephone conversation with B. Edwards and J. Scarola (recorded 4/7/11) and the transcript filed by B. Edwards in order to prepare and submit a corrected and accurate transcript of the conversation 04/18/18 TLC Review bankruptcy transcript; work on bankruptcy 0.60 135.00 hearing logistics; check bankruptcy docket EFTA00799156 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 10 Date Services Hours Amount 04/18/18 SJL Work on bankruptcy hearing logistics; 6.20 4,650.00 communications with C. Pugatch and counsel for the parties; review bankruptcy hearing transcript; follow up with client re same; respond to D. Indyke's inquiry about B. Edwards re-noticing matter for trial; work on adverse inference jury instruction; follow up with D. Indyke and J. Epstein re same; work on Response to Motion for Sanctions 04/19/18 TMB [No Charge) Review clerk's records regarding status 0.10 0.00 of mandamus case 04/19/18 RJG Legal research in preparation for drafting legal 3.90 1,540.50 argument in Motion to Compel B. Edwards to Identify His Trial Witnesses and Motion to Strike V. Guiffre as a Witness 04/19/18 RJG Review facts re B. Edwards' Witness Lists and trial 1.90 750.50 court rulings re limitation of testimony (to keep focus on malicious prosecution claim) in preparation for drafting argument section of Motion to Compel B. Edwards to Identify His Trial Witnesses and Motion to Strike V. Guiffre as a Witness 04/19/18 RJG Begin drafting/revising argument section of Motion to 1.90 750.50 Compel B. Edwards to Identify His Trial Witnesses 04/19/18 SJL Review Fourth District Court of Appeal's Order 4.20 3,150.00 denying Petition for Writ of Certiorari; follow up with D. Indyke and J. Epstein re same; follow up with D. Vitale re setting hearing on B. Edwards' Motion to Take J. Epstein's Deposition; work on Response to same; work on Motion to Allow Late Disclosure of S. Smith 04/19/18 TLC Work on Motion to Allow S. Smith to Testify at Trial; 7.20 1,620.00 review Fourth District Court of Appeal's Order denying Petition for Writ of Certiorari; work on Response to B. Edwards' Motion to Permit to Take the Limited Deposition of J. Epstein; review Farmer Jaffe's Motion in the Bankruptcy Court and the Bankruptcy Court hearing transcript for cites to reference in same EFTA00799157 Client Ref: 0002 - 0001 May 7, 2018 InvoiceI/559 Page 11 Date Services Hours Amount 04/20/18 RJG Continue drafting/revising Motion to Compel B. 3.90 1,540.50 Edwards to Identify His Trial Witnesses, Motion to Strike V. Guiffre as a Witness, and Motion for Leave to Disclose Expert Witness and supplemental research for inclusion in same 04/20/18 RJG Review/analyze Order to Show Cause Issued by 3.10 1,224.50 Bankruptcy Court and research proper procedure for a court's Order to Show Cause; review/edit draft Response to B. Edwards' Motion to Depose J. Epstein 04/20/18 PVD [No Charge] Review V. Guiffre's audio interview for 1.00 0.00 final edits 04/20/18 TLC Work on Response in Opposition to B. Edwards' 7.00 1,575.00 Motion to Be Permitted to Take J. Epstein's Limited Deposition; review Bankruptcy Court's Order to Show Cause; update calendar re deadlines set forth therein; begin research to see other Show Cause Orders entered by Judge Ray; participate in telephone conference with S. Link, C. Pugatch and D. Indyke re Order and strategies going forward; communications with D. Vitale re hearing 04/20/18 SJL Work on Response in Opposition to B. Edwards' 9.50 7,125.00 Motion to be Permitted to Take His Limited Deposition; review Order to Show Cause Why Fowler White and J. Epstein Should Not be Held in Contempt and Scheduling Evidentiary Show Cause Hearing; telephone conferences with D. Indyke and C. Pugatch re analysis, options and strategies relating to same; work on Motion to Allow S. Smith to Testify at Trial; work on Response to Motion for Sanctions 04/20/18 KBR Work on Response in Opposition to B. Edwards' 2.00 1,500.00 Motion to be Permitted to Take J. Epstein's Limited Deposition; work on Response to Motion for Sanctions in state court 04/21/18 TLC Work on analysis of Bankruptcy Court's Order, 4.50 1,012.50 hearing transcript, and next steps; research other Show Cause Orders entered by Judge Ray EFTA00799158 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 12 Date Services Hours Amount 04/21/18 SJL Work on analysis of Court's Order to Show Cause; 2.50 1,875.00 telephone conference with J. Epstein re same; work on Response to Motion for Sanctions 04/23/18 RJG Review pertinent portions of record in preparation for 1.20 474.00 drafting/revising Motion to Allow Amendment to Exhibit List 04/23/18 RJG Legal research in preparation for drafting/revising 2.90 1,145.50 Motion to Allow Amendment to Exhibit List 04/23/18 RJG Draft/revise Motion to Allow Amendment to Exhibit 3.90 1,540.50 List 04/23/18 TLC Research Federal Rules of Civil Procedure, Federal 9.80 2,205.00 Rules of Bankruptcy Procedure, Southern District of Florida Bankruptcy Court Local Rules and Florida Rules of Civil Procedure re instructing witness not to answer; work on Response to Motion to Take J. Epstein's Deposition; work on Response in Opposition to B. Edwards' Motion for Sanctions for Violation of Court Order and the Intervenors' Joinder; work on Motion to Compel B. Edwards to Identify his Trial Witnesses and Motion to strike V. Giuffre as a Witness; work on Renewed Motion for Leave to Disclose Expert Witness; work on Adverse Inference Jury Instruction and prepare Notice of Filing for same 04/23/18 SJL Work on Response to Motion to Take J. Epstein's 4.50 3,375.00 Deposition; multiple communications with D. Indyke re same; work on Response in Opposition to B. Edwards' Motion for Sanctions; follow up with C. Pugatch re discovery re Intervenors' alleged damages 04/23/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 1.00 0.00 for compliance 04/24/18 TLC Work on Motion for Leave to Amend Exhibit List; 9.00 2,025.00 prepare letter and package to Court re submission for 4/26/18, hearing on B. Edwards' Motion to Permit J. Epstein's deposition; work on Response to Motion to Depose J. Epstein; work on Response In Opposition to B. Edwards' Motion for Sanctions; work on Amended Jury Instructions EFTA00799159 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 13 Date Services Hours Amount 04/24/18 SJL Work on Response to Motion to Take J. Epstein's 8.80 6,600.00 Deposition; multiple communications with D. Indyke re same; follow up with J. Epstein re review of same; work on letter to Court; work on Response in Opposition to B. Edwards' Motion for Sanctions; work on Motion for Leave to Amend Exhibit List; telephone conference with D. Vitale re hearing 04/24/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 6.50 0.00 for compliance 04/25/18 TLC Work on Response in Opposition to B. Edwards' 5.50 1,237.50 Motion for Sanctions; work on Motion to Allow Amendment to Exhibit List; work on Motion for Leave to Disclose Expert Witness; follow up on deposition dates for J. Epstein 04/25/18 SJL Work on Response in Opposition to B. Edwards' 5.20 3,900.00 Motion for Sanctions; work on Motion to Mow Amendment to Exhibit List; work on Motion for Leave to Disclose Expert Witness; communications with C. Pugatch re strategies for bankruptcy proceeding; follow up with J. Scarola re J. Epstein's deposition; work on dates for same; communications with D. Indyke and J. Epstein re same 04/25/18 PVC/ [No Charge] Continue review of Clerk's Trial Exhibits 4.40 0.00 for compliance 04/26/18 TLC Work on Amended Jury Instructions; work on Motion 4.20 945.00 to Amend Exhibit List and Motion to Disclose Expert Witness; forward drafts to D. Indyke for review, follow up with opposing counsel on setting J. Epstein's deposition; multiple telephone conferences with Fowler White's counsel, J. Goldberger and J. Scarola's assistant 04/26/18 SJL Work on Motion to Amend Exhibit List; work on 7.20 5,400.00 Motion to Disclose Expert Witness; work on issues relating to setting J. Epstein's deposition; communications with D. Indyke and J. Epstein 04/26/18 KBR Work on Motion to Allow Amendment of Exhibit List; 0.60 450.00 work on Renewed Motion for Leave to Disclose Expert EFTA00799160  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 14 Date Services Hours Amount 04/26/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 1.10 0.00 for compliance 04/27/18 RJG Review Fourth District Court of Appeal Order on 0.10 39.50 Petition for Writ of Mandamus and Motions for Fees 04/27/18 TLC Work on Motion for Leave to Amend Exhibit List to 6.20 1,395.00 review p's incorporate D. lndyke's thoughts and comments; transcript re testimony; follow up with Florida urt Reporting re instructions to transcribe V. Roberts' interview and prepare comparison; prepare follow-up e-mail detailing same; review Fourth District Court of Appeal's Order removing stay; review Florida Rule of Civil Procedure when case can be reset 04/27/18 SJL Work on Motion for Leave to Amend Exhibit List; 7.20 5,400.00 communications with D. Indyke and J. Epstein; review Fourth District Court of Appeal 's Order removing stay and denying Petition for Writ of Mandamus; work on strategies going forward; work on Motion re witnesses 04/27/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 0.50 0.00 for compliance 04/29/18 TLC Work on Motion to Compel B. Edwards to Identify his 7.50 1,687.50 Trial Witnesses; forward same to D. Indyke for review; work on Motion to Use Certified Transcript of V. Roberts' April 2011 telephonic interview at trial; review all communications that was stricken compared to charts of privilege and produced documents and identify all communications that were produced on our Amended Exhibit List; review public records for Jane Doe,pli. and E.W. to reduce number of exhibits; u a e Amended Exhibit List re same; update witness binders with same 04/29/18 SJL Work on Motion to Compel B. Edwards to Identify his 3.50 2,625.00 Trial Witnesses; work on Motion to Use Certified Transcript of V. Roberts' April 2011 telephonic interview; meet with J. Epstein re trial strategies 04/30/18 PVD [No Charge] Review Fowler White production for 2.20 0.00 additional exhibits listed on Amended Exhibit List to be filed EFTA00799161  Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 15 Date Services Hours Amount 04/30/18 TLC Work on Amended Exhibit List; work on assembling 7.50 1,687.50 documents identified for Amended Exhibit List; work on Motion to Limit Witnesses; work on chart for status conference hearing; work on preparations for same 04/30/18 SJL Work on review of trial exhibits to narrow down those 7.50 5,625.00 to be used at trial; work on Motion to Limit Exhibits; communications with D. Indyke and client; work on trial strategies in light of case being at issue; review Jury Instructions to determine modifications needed Recapitulation Rate Hours Amount TMB Troy M. Bermudez 225.00 0.40 0.00 TLC Tina L. Campbell 225.00 160.90 36,202.50 PVD Debi J. Mackey 90.00 58.40 0.00 RJG Rachel J. Glasser 395.00 41.40 16,353.00 SJL Scott J Link 750.00 165.60 124,200.00 MLP Maggie L Powers 225.00 7.70 0.00 KBR Kara Berard Rockenbach 750.00 8.00 6,000.00 Sub Total 182,755.50 Courtesy Discount -800.00 For Current Services Rendered 442.40 $181,955.50 Expenses and Advances Date Expenses Amount 02/01/18 Courier /Delivery Fee 2/2/18 #7415 to Judge Hafele - Coastal 25.00 Messenger Service, Inc. 02/01/18 Courier/Delivery Fee 2/2/18 #7417 to J. Scarola - Coastal Messenger 25.00 Service, Inc. 02/01/18 Courier /Delivery Fee 2/13/18 #7754 to Judge Hafele - Coastal 25.00 Messenger Service, Inc. 02/01/18 Courier /Delivery Fee 2/20/18 #7776 to PBSO - Coastal Messenger 25.00 Service, Inc. 02/01/18 Courier/Delivery Fee 2/27/18 #7807 to Judge Hafele - Coastal 25.00 Messenger Service, Inc. 02/06/18 Court Reporter 1/31/18 Hearing before Judge Hafele - Palm Beach 80.00 Reporting Services, Inc. 03/20/18 Hearing / Trial Transcript 4/16/18 Hearing before Judge Crow - Orange 531.00 Legal, Inc 03/22/18 Travel Expense Baggage Fee - SJL 25.00 03/22/18 Travel Expense Baggage Fee - KBR 25.00 03/22/18 Travel Expense Airfare WPB/NYC - KBR 374.62 EFTA00799162 Client Ref: 0002 - 0001 May 7, 2018 Invoice # 559 Page 16 Expenses and Advances Date Expenses Amount 03/22/18 Travel Expense Airfare NYC/WPB - KBR 613.30 03/22/18 Travel Expense Cab Fare - NYC 13.55 03/22/18 Travel Expense Cab Fare - NYC 11.16 03/22/18 Travel Expense Cab Fare -NYC 40.87 03/22/18 Travel Expense Meals - NYC 90.67 03/23/18 Travel Expense Cab Fare - NYC 9.95 03/28/18 Court Reporter 3/26/18 Hearing before Judge Hafele - Palm Beach 80.00 Reporting Services, Inc. 03/28/18 Transcript Fee 3/26/18 Hearing Transcript-Judge Hafele - Palm Beach 52.80 Reporting Services, Inc. 04/01/18 Westlaw Research 3/1/18 - 3/31/18 1,157.10 04/01/18 Courier /Delivery Fee Misc. Deliveries to Judge and Opposing Counsel 360.00 (14 trips) - Coastal Messenger Service, Inc. 04/06/18 Court Reporter 4/5/18 Hearing before Judge Hafele - Palm Beach 80.00 Reporting Services, Inc. 04/16/18 Travel Expense Airfare FTL to NYC - SJL 441.20 04/16/18 Travel Expense Airfare FTL to NYC - KBR 441.20 04/17/18 Travel Expense Share of Car Rental in Tallahassee - Seamy Denney 53.11 Scarola Barnhart & Shipley, 04/18/18 Travel Expense Airport Parking 42.00 Copy Charge through 04/30/18 61