EFTA00794045.pdf

Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 W•• • • 7 01 Jeffrey Epstein June 12, 2018 6100 Red Hook Quarter, B3 Invoice # 797 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services Hours Amount 05/01/18 TLC Work on Motion to Compel B. Edwards to Identify 9.20 2,070.00 Witnesses who will be called at trial to incorporate D. Indyke's suggested thoughts and comments; update list of pending Motions; prepare Response to B. Edwards' Motion for Case Management; prepare letter and package to Judge Hafele re UMC hearing on case management; work on Response to B. Edwards' Motion for Sanctions to incorporate D. Indyke's suggested thoughts and comments; work on updated Amended Exhibit List 05/01/18 SJL Work on Response to B. Edwards' Motion for Case 6.40 4,800.00 Management Conference; review list of pending issues; review excluded trial exhibits to narrow down on Amended Exhibit List; work on Motion to Compel B. Edwards to Identify Witnesses; work on Response to Motion for Sanctions 05/02/18 PVD [No Charge] Proof Motion to Compel B. Edwards to 6.70 0.00 Identify Witnesses prior to filing; continue review of Clerk's Trial Exhibits for compliance; work on Amended Exhibit List cross referencing exhibits previously marked 05/02/18 TLC Work on scheduling J. Epstein's deposition in 9.80 2,205.00 bankruptcy proceeding; prepare e-mail to counsel re same; work on Motion to Compel B. Edwards to Identify his Trial Witnesses; work on assembling exhibits to mimic Amended Exhibit List; continue working on Amended Exhibit List; work on Response to Motion for Sanctions; prepare Motion to Compel B. Edwards to identify Bates stamp numbers of documents produced EFTA00794045 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 2 Date Services Hours Amount 05/02/18 SJL Work on Motion to Compel B. Edwards to Identify his 8.40 6,300.00 Trial Witnesses; work on Response to Motion for Sanctions; review Amended Exhibit List and review potential trial exhibits; follow up with J. Epstein on deposition dates; communications with D. Indyke re strategies and purpose of case management conference; work on Motion to Compel re Bates documents 05/03/18 PVD [No Charge] Continue work on Amended Exhibit List 6.50 0.00 cross referencing exhibits previously marked 05/03/18 KBR Prepare for and attend status conference hearing 1.50 1,125.00 05/03/18 SJL Follow up with J. Scarola re trial setting; prepare for 8.30 6,225.00 and attend status conference hearing; follow up with J. Epstein and D. Indyke re same; review Court's Order following hearing; work on Bankruptcy Court strategies; work on Motion to Compel B. Edwards to identify Bates numbers of documents produced; work on Motion re filing certified copy of V. Roberts' interview 05/04/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits 4.20 0.00 for compliance 05/04/18 TLC Work on Response to Motion for Sanctions to 4.50 1,012.50 incorporate D. Indyke's thoughts and comments; work on Motion to Compel documents re Bates number identification; work on Motion re V. Roberts' transcript 05/04/18 RJG Review B. Edwards' Motion for Rehearing of 4th DCA 0.20 79.00 Order denying appellate fees in Case No.18-087 05/04/18 SJL Work on Response to Motion for Sanctions; 6.50 4,875.00 communications with D. Vitale re setting hearing on Motion to Extend Scope of J. Epstein's deposition; follow up with clients re same; review pending motions and strategize on how to proceed on same; work on Motion re transcript of V. Roberts' 2011 telephonic interview EFTA00794046 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 3 Date Services Hours Amount 05/07/18 SJL Communications with D. Indyke to strategize; work 2.50 1,875.00 on bankruptcy court issues; review Pre-Trial Stipulation and Jury Instructions re potential amendments 05/08/18 SJL Work on Response to B. Edwards' Motion for 3.00 2,250.00 Rehearing; work on Response to Motion for Sanctions; communications with D. Indyke and J. Epstein 05/09/18 RJG Research for possible argument in response to B. 0.90 355.50 Edwards' Motion for Rehearing of 4th DCA denial of appellate attorneys fees; whether a denial of writ petition without prejudice to appeal from final order Is a favorable disposition 05/09/18 KBR Conduct legal research re B. Edwards' citation to two 2.00 1,500.00 cases as basis for conditional fee entitlement in certiorari proceeding; key cite cases and broaden search re 9.400 fee entitlement on interlocutory appeals 05/09/18 SJL Work on Response to B. Edwards' Motion for 3.20 2,400.00 Rehearing; follow up on deposition schedule of J. Epstein; communications with D. Indyke and J. Epstein; work on trial strategies; work on Motion re V. Roberts' transcript 05/10/18 RJG Review 4th DCA Order dismissing Petition for Writ of 3.10 1,224.50 Mandamus as moot; research entitlement to prevailing party fees where court dismisses case/appeal as moot in preparation for drafting Motion for Rehearing of denial of appellate fees 05/10/18 RJG Review draft Response to B. Edwards' Motion for 1.60 632.00 Rehearing re Fee Entitlement and draft/revise Motion for Rehearing of Denial of Appellate Fees In mandamus proceeding EFTA00794047 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 4 Date Services Hours Amount 05/10/18 KBR Analyze timing and language used in related orders 5.20 3,900.00 from 4th DCA (April 19, 2018 denying Writ of Certiorari and both parties' fees and April 27, 2018, dismissing mandamus petition as moot and denying both parties' fees); work on Response to B. Edwards' Motion for Hearing and Order denying B. Edwards' conditional entitlement to appellate fees; telephone conference with D. Indyke re Response, discussion re 9.400, discretion of appellate court, good-faith argument based on consolidation and intertwined nature of two extraordinary writ proceedings and J. Epstein prevailing on mandamus proceeding by virtue of stay/passage of time; perform additional legal research broadening 9.400 and discretion of appellate courts to deny conditional appellate attorneys' fees in Section 768.79, Rule 1.442 context; revise Response to incorporate same following discussions with D. Indyke and additional research 05/10/18 SJL Strategize re seeking rehearing on Order denying our 3.00 2,250.00 fees and Response to B. Edwards' Motion for Rehearing denying his fees; work on Response to B. Edwards' Motion for Rehearing; telephone conferences with D. Indyke and J. Epstein 05/10/18 TLC Work on updating key document notebooks; work on 2.50 562.50 Response to B. Edwards' Motion for Rehearing; follow up on outstanding Motions 05/14/18 TMB [No Charge) Prepare Appendix to Response to B. 0.30 0.00 Edwards' Motion for Rehearing Regarding Appellate Fees 05/14/18 SJL Work on Motion for Rehearing of Denial of Epstein's 4.50 3,375.00 Motion for Appellate Attorneys' Fees and Costs and Response to Edwards' Motion for Rehearing Regarding Appellate Fees; review B. Edwards' "damages" filed in Bankruptcy Court proceeding; follow up with C. Pugatch, D. Indyke and J. Epstein re same EFTA00794048 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 5 Date Services Hours Amount 05/14/18 TLC Work on Motion for Rehearing of Denial of J. 1.40 315.00 Epstein's Motion for Appellate Attorneys' Fees and Costs (4D18-0762); work on Response to B. Edwards' Motion for Rehearing Regarding Appellate Fees and Appendix to same (4D18-0787); prepare for e-service; review damages filing in Bankruptcy Court 05/15/18 SJL Review damage summaries filed by Farmer Jaffe and 6.20 4,650.00 the Intervenors and work on strategies responding to same; work on Motion re V. Roberts' transcript; communications with client and D. Indyke; work on Response to Motion for Sanctions 05/16/18 TLC Work on Motion to Use April 7, 2011, Interview of V. 2.50 562.50 Roberts; follow up with D. Indyke and C. Pugatch re telephone conference; prepare proposed Order for May 23, 2018, UMC hearing; work on updating binders 05/17/18 KBR Review 4th DCA's Order denying Respondent's May 0.10 75.00 4, 2018 Motion for Rehearing 05/17/18 SJL Attend telephone conference with C. Pugatch and D. 6.20 4,650.00 Indyke re strategies in bankruptcy proceedings; work on same; work on Motion to Strike the Intervenors' List of Requested Relief 05/17/18 TLC Work on Motion to Strike Intervenors' List of 2.80 630.00 Requested Relief or, in the Alternative, to Conduct Limited Discovery 05/18/18 SJL Continue working on Motion to Strike the Intervenors' 4.60 3,450.00 List of Requested Relief; communications with client; work on Response to Motion for Sanctions 05/20/18 SJL Work on trial strategies; work on addressing 2.20 1,650.00 Bankruptcy Court issues 05/21/18 TLC Work on preparations for UMC hearing on B. 1.00 225.00 Edwards' Motion to depose J. Epstein; work on Motion to Strike Intervenors' List of Requested Relief EFTA00794049 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 6 Date Services Hours Amount 05/21/18 SJL Continue working on Motion to Strike Intervenors' List 5.20 3,900.00 of Requested Relief; work on preparations for UMC hearing; follow up on trial and sanction strategies; work on Motion re V. Roberts' transcript 05/22/18 RJG Begin researching proof of actual damages re 2.10 829.50 contempt proceedings in preparation for drafting Motion to Strike Intervenors' List of Requested Relief 05/22/18 RJG In Bankruptcy Proceedings, review/analyze (1) 3.50 1,382.50 Farmer Jaffe's Motion for Order to Show Cause-Contempt; (2) Intervenors' Joinder in Motion for Order to Show Cause; (3) Court's Order to Show Cause-Contempt; and (4) Intervenors' Requested Relief, in preparation for drafting Motions to Strike Farmer Jaffe's and Intervenors' damages claims 05/22/18 SJL Work on preparations for UMC hearing on B. 4.20 3,150.00 Edwards' Motion to Take J. Epstein's deposition; review March 8, 2018 transcript, the two certifications of compliance we prepared and the Courts orders on sealing; work on proposed Order; work on Response to B. Edwards' Motion for Sanctions; work on trial strategies; work on Bankruptcy Court issues 05/22/18 TLC Work on Motion to Strike Intervenors' List of 0.80 180.00 Requested Relief; work on Response to B. Edwards' Motion for Sanctions 05/22/18 KBR Prepare for UMC hearing on B. Edwards' Motion to 0.60 450.00 Allow Limited Deposition of J. Epstein re disc/documents 05/23/18 TLC Telephone conferences with court reporter re V. 1.40 315.00 Roberts' transcription; follow up on outstanding motions; work on Response to Motion for Sanctions 05/23/18 KBR Prepare for and attend UMC hearing on B. Edwards' 1.00 750.00 Motion to Allow Limited Deposition of J. Epstein re disc/documents EFTA00794050 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 7 Date Services Hours Amount 05/23/18 SJL Attend UMC hearing on B. Edwards' Motion to Take 5.50 4,125.00 J. Epstein's deposition; follow up with client and D. Indyke re outcome of same; explore options on how to respond to Court's Order, work on Response to Motion for Sanctions; work with R. Glasser on Motion to Strike damages claims in bankruptcy proceeding 05/23/18 RJG Research on: (1) compensatory v. coercive sanctions 2.10 829.50 for contempt and (2) requirements for recovery of damages for emotional distress, in preparation for drafting Motion to Strike Intervenors' List of Requested Relief Sought in this Case/Alternative Request to Depose Intervenors in Bankruptcy Proceeding 05/23/18 RJG Begin drafting Motion to Strike Intervenors' List of 2.30 908.50 Requested Relief or, in the Alternative, to Conduct Limited Discovery in Bankruptcy Proceeding 05/24/18 RJG Continue to revise Motion to Strike Intervenors' List of 3.10 1,224.50 Requested Relief or, in the Alternative, to Conduct Limited Discovery in Bankruptcy Proceeding 05/24/18 RJG Supplemental research for Motion to Strike 2.20 869.00 Intervenors' List of Requested Relief or, in the Alternative, to Conduct Limited Discovery in Bankruptcy Proceeding; research recovery of attorneys fees as civil contempt sanctions 05/24/18 TLC Work on Response to Motion for Sanctions; follow up 4.80 1,080.00 with D. Indyke re review of same; review V. Roberts' interview transcript and changes made by court reporter after a further in-depth review; follow up with court reporter on same; prepare e-mail to M. Nurik re setting UMC hearing on S. Rothstein's Motion to Dismiss; prepare Notice of Hearing on outstanding Motions 05/24/18 SJL Work on Response to Motion for Sanctions; work on 5.00 3,750.00 list of pending Motions; review Notice of Hearing for submission to opposing counsel; work on Motion to Strike Intervenors' List of Requested Relief; follow up with D. Indyke re same EFTA00794051 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 8 Date Services Hours Amount 05/25/18 RJG Review D. Indyke's suggested revisions to draft 1.90 750.50 Motion to Strike Intervenors' List of Requested Relief and revise draft accordingly 05/25/18 TLC Communications with D. Vitale re proposed Order; 5.80 1,305.00 follow up on transcript of hearing; review same for Court's ruling; work on revisions to proposed Order re J. Epstein's limited deposition; follow up with D. Indyke and J. Goldberger re review of same; work on Motion to Strike; finalize Notice of Hearing for trial docket 05/25/18 RJG Initial review of S. Rothstein's Motion to Dismiss 1.50 592.50 Second Amended Complaint with Prejudice 05/25/18 RJG Legal research viability of conspiracy count/viability of 2.30 908.50 underlying tort in preparation for drafting response to S. Rothstein's Motion to Dismiss 05/25/18 SJL Work on Motion to Strike Intervenors' List of 6.50 4,875.00 Requested Relief; meet with K. Rockenbach and R. Glasser re same; review hearing transcript, B. Edwards' Motion seeking permission to take J. Epstein's limited deposition and B. Edwards' proposed Order, work on edits to same; follow up with D. Indyke, M. Weinberg and J. Goldberger 05/26/18 SJL Communications with D. Indyke; work on Motion to 2.50 1,875.00 Strike Intervenors' List of Requested Relief 05/29/18 AAS Draft detailed Memorandum of Law analyzing the 1.00 395.00 issue of whether a general release between a client and a law firm will bar claims for issues that were unknown at the time of the execution of the release 05/29/18 RJG Supplemental research for (1) Response in 3.10 1,224.50 Opposition to S. Rothstein's Motion to Dismiss (rules and general principles re motions to dismiss; (2) stating a cause of action for conspiracy to commit abuse of process; (3) failure to identify other co-conspirator(s) as fatal; (4) pleading adequate damages; and (5) when dismissal with prejudice is warranted 05/29/18 RJG Discuss strategy for response to S. Rothstein's 0.50 197.50 Motion to Dismiss with K. Rockenbach EFTA00794052 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 9 Date Services Hours Amount 05/29/18 RJG Outline and begin drafting Response in Opposition to 2.30 908.50 S. Rothstein's Motion to Dismiss 05/29/18 SJL Work with A. Steadman on research project re 5.60 4,200.00 general releases barring claims for unknown issues; review memo on his findings; follow up with D. Indyke re same; communications with D. Indyke and J. Epstein re moving forward; work on strategies; review B. Edwards' Response to our Motion for Rehearing on attorneys' fees issue in appellate court; follow up on proposed Order re J. Epstein's deposition and Response to Motion for Sanctions; work on Motion to Strike Intervenors' Request for Relief 05/30/18 TLC Follow up with J. Goldberger re proposed order on J. 0.80 180.00 Epstein's deposition; work on changes to same; follow up with D. Vitale re our proposed changes; follow up with M. Nurik re hearing on Motion to Dismiss 05/30/18 SJL Work on proposed Order re J. Epstein's deposition; 4.90 3,675.00 communications with D. Indyke and J. Epstein; review revised transcript prepared by court reporter of V. Roberts' telephonic interview, work on Motion re same 05/31/18 TLC Work on proposed Order re J. Epstein's deposition; 3.20 720.00 review entire transcript of hearing on B. Edwards' Motion to Take J. Epstein's Limited Deposition; prepare draft e-mail to D. Vitale re our position on same; send our revised Order and proposed e-mail to D. Indyke to comment on same; work on Notice of UMC Hearing on S. Rothstein's Motion to Dismiss; follow up with M. Nurik re hearing 05/31/18 SJL Communicate with M. Nurik in compliance with Local 7.50 5,625.00 Rule 4 before setting UMC hearing on S. Rothstein's Motion to Dismiss; work on proposed Order re J. Epstein's deposition and draft email to D. Vitale; review hearing transcript; continue working on Response to S. Rothstein's Motion to Dismiss Recapitulation Rate Hours Amount TMB Troy M. Bermudez 225.00 0.30 0.00 TLC Tina L. Campbell 225.00 50.50 11,362.50 EFTA00794053 Client Ref: 0002 - 0001 June 12, 2018 Invoice # 797 Page 10 Recapitulation Rate Hours Amount PVD Paul V. DeVito 90.00 17.40 0.00 RJG Rachel J. Glasser 395.00 32.70 12,916.50 SJL Scott J Link 750.00 111.90 83,925.00 KBR Kara Berard Rockenbach 750.00 10.40 7,800.00 AAS Andrew A. Steadman 395.00 1.00 395.00 Sub Total 116,399.00 Courtesy Discount -1,040.00 For Current Services Rendered 224.20 $115,359.00 Expenses and Advances Date Expenses Amount 04/01/18 Courier /Delivery Fee Misc. Courier Charges - Coastal Messenger 170.00 Service, Inc. 04/30/18 Westlaw Research On Line Research 4/1/18 - 4/30/18 833.34 05/04/18 Court Reporter 5/3/18 Hearing Attendance - Palm Beach Reporting 80.00 Services, Inc. 05/04/18 Deposition transcripts 4/7/11 Phone Interview Recording - V. Giuffre - 1,058.50 Florida Court Reporting 05/29/18 Miscellaneous Research and Transcript Comparison for Corrections - 347.00 Florida Court Reporting 05/30/18 Transcript Fee 5/23/18 Copy of Transcript Excerpt - Palm Beach 46.80 Reporting Services, Inc. 05/31/18 Transcript Fee 5/23/18 Hearing Transcript - Palm Beach Reporting 96.80 Services, Inc. Total Expenses and Advances $2,632.44 Sub Total $119,031.44 Courtesy Discount -1,040.00 Total Current Work $117,991.44 Trust Funds Balance: $41,394.86 EFTA00794054  Please return this page with remittance to Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Beach, FL 33401 Invoice # 797 Bill Date: June 12, 2018 Client Code: 0002 Client Name: Jeffrey Epstein Matter Code: 0001 Matter Name: Bradley Edwards $119,031.44 Courtesy Discount -1,040.00 Total Current Work $117,991.44 Trust Funds Balance: $41,394.86 Amount enclosed: EFTA00794055