EFTA00800960.pdf

LINK& I-Fir ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes, Blvd., Suite 930 West Palm Beach, Pt, 33401 TEL: August 14, 2018 Via Email leevacationagmait com 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 July 31, 2018. I have carefully reviewed this statement and as a courtesy to you, I reduced Kara's billings in the amount of $1,100.00. In addition, I reduced Daniel Schwarz's time by $3,199.50 to allow him to get up to speed on the case. Finally, in light of our ongoing working relationship I have reduced the bill by an additional 10% bringing the total reduction to $14,274.50. Please do not hesitate to call me if you yl v R estions regarding this bill. Thank you. VeVz rs, Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00800960  Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Beach, FL 33401 561-847-4408 Tax ID No. 82-3083928 Jeffrey Epstein August 7, 2018 6100 Red Hook Quarter, 63 Invoice # 1034 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Dato Services Hours Amount 07/02/18 TLC Follow up with D. Indyke re status of drafting; working 3.20 720.00 on hearing folders for over twenty pending matters in preparation for upcoming hearing; work on draft Joint Response to summary of damages filed by B. Edwards and Farmer Jaffe 07/02/18 SJL Follow up on outstanding drafting; address setting of 4.80 3,600.00 Fowler White's and Link & Rockenbach's representative's depositions; work on Objection to Duce Tecum in state court action; communications with client 07/03/18 SJL Work on bankruptcy plan; work on Responses to 5.60 4,200.00 Summary of Damages; work on Response to S. Rothstein's Motion to Dismiss; work on strategies 07/05/18 TLC Work on Response to S. Rothstein's Motion to 5.20 1,170.00 Dismiss to incorporate D. Indyke's big picture comments/concepts and line edits; work on hearing folder; follow up on scheduling of deposition of Fowler White and Link & Rockenbach 07/06/18 SJL Work on Objections to Duces Tecum; multiple 4.50 3,375.00 communication with D. Indyke 07/08/18 SJL Work on Response to S. Rothstein's Motion to 2.80 2,100.00 Dismiss; work on Objections to state court Duces Tecum EFTA00800961 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 2 Date Services Hours Amount 07/09/18 TLC Work on Response to S. Rothstein's Motion to 5.00 1,125.00 Dismiss; follow up with D. Indyke re same; follow up with J. Goldberger and C. Pugatch re deposition of Fowler White's and Link & Rockenbach's representatives; work on dates for same; work on Response in Opposition to B. Edwards' and Farmer Jaffe's Summaries of Damages; work on Response and Objection to Duces Tecum in state court action; prepare email to J. Scarola's assistant re depositions of Fowler White and Link & Rockenbach 07/09/18 SJL Work on Response to S. Rothstein's Motion to 5.30 3,975.00 Dismiss; work on Response in Opposition to B. Edwards' and Farmer Jaffe's Summaries of Damages; work on Response and Objections to Duces Tecum in state court action; communications with D. Indyke 07/10/18 TLC Continue working on Response to B. Edwards' and 3.50 787.50 Farmer Jaffe's Summaries of Damages to incorporate D. Indyke's thoughts and suggested revisions; review March 23, 2018, hearing transcript and prepare Notice about J. Epstein's testimony at trial; work on Response to S. Rothstein's Motion to Dismiss 07/10/18 SJL Continue working on Response to B. Edwards' and 4.80 3,600.00 Farmer Jaffe's Summaries of Damages to incorporate D. Indyke's thoughts and suggested revisions; work on Notice about J. Epstein's testimony at trial; follow up with D. Indyke and J. Epstein re same 07/11/18 TLC Continue working on Response to S. Rothstein's 3.80 855.00 Motion to Dismiss; work on Response in Opposition to B. Edwards' and Farmer Jaffe's Summaries of Damages; send draft to D. Indyke for review; work on Notice re J. Epstein's trial testimony; work on new dates for J. Epstein's deposition; follow up with J. Goldberger, D. Indyke and C. Pugatch re proposed new dates EFTA00800962 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 3 Date Services Hours Amount 07/11/18 SJL Telephone conference with J. Epstein and D. Indyke 5.50 4,125.00 re Notice re testimony; work on same; work on Response in Opposition to S. Rothstein's Motion to Dismiss; work on Response to B. Edwards' and Farmer Jaffe's damage summaries; communications with J. Epstein re his request to change date of his deposition; work on strategies for bankruptcy proceeding 07/12/18 TLC Work on Response to S. Rothstein's Motion to 3.80 855.00 Dismiss; forward same to D. Indyke for review; work on incorporating D. Indyke's comments into Objections to state court Duces Tecum to J. Epstein; final review of Motion to Strike Intervenors' Requested Relief in Bankruptcy Proceeding and Response to B. Edwards' and Farmer Jaffe's Summaries of Damages; assemble all exhibits to Response and prepare Appendix; communications with C. Pugatch re filing; forward filed versions to D. Indyke 07/12/18 SJL Work on finalizing Motion to Strike Intervenors' 7.20 5,400.00 Requested Relief; work on Response to B. Edwards' and Farmer Jaffe's damage summaries; work on issues relating to rescheduling J. Epstein's deposition; communications with J. Scarola re same; follow up with clients; work on bankruptcy hearing preparations 07/13/18 TLC Work on rescheduling J. Epstein's deposition; follow 2.40 540.00 up with D. Indyke re same; work on preparations for Bankruptcy Court hearing; work on hearing binder; work on Response to Duces Tecum 07/13/18 SJL Follow up on rescheduling J. Epstein's deposition; 6.50 4,875.00 communications with D. Indyke; work on strategies for upcoming two-day hearing on all outstanding motions; review hearing folders of same; work on Response to Duces Tecum; review Fowler White's response to document discovery 07/15/18 SJL Continue working on strategies for upcoming two-day 2.50 1,875.00 hearing on pending motions and preparing for same EFTA00800963 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 4 Date Services Hours Amount 07/16/18 TLC Work on Response and Objections to Bankruptcy 6.20 1,395.00 duces tecum directed to Link & Rockenbach; work on finalizing Response to S. Rothstein's Motion to Dismiss; file same; work on hearing folder and letter to judge; follow up with D. Indyke re upcoming schedule; review Court's trial docket re our upcoming two-day hearings; follow up on J. Epstein's deposition rescheduling; work on preparations for depositions; prepare outline of upcoming deadlines 07/16/18 SJL Work on Response and Objections to Duces Tecum 5.60 4,200.00 directed to Link & Rockenbach in Bankruptcy Proceeding; work on Response and Objections to Duces Tecum directed to J. Epstein in state court action; work on bankruptcy strategies; communications with J. Epstein and D. Indyke; follow up on J. Epstein's deposition rescheduling 07/17/18 TLC Review D. Indyke's big picture edits to Response and 3.70 832.50 Objection to Duces Tecum directed to Link & Rockenbach; review April 13, 2018, bankruptcy transcript, March 8, 2018, state court transcript, and show cause filings by the movants for additional information to include in the Response and Objection; forward same to D. Indyke for review 07/17/18 SJL Work on Response and Objections to Duces Tecum 5.80 4,350.00 directed to Link & Rockenbach; multiple communications with D. Indyke and J. Epstein; telephone conferences with jurors in Vero Beach case J. Scarola recently tried 07/18/18 DMS [No Charge - getting up to speed on case] Review, 3.50 0.00 analyze, and scrutinize multiple relevant case documents, including lengthy transcript of the Mach 8, 2018 hearing involving Fowler White disk issue, Counter-Plaintiff's Motion for Order to Show Cause in bankruptcy court and Bankruptcy Court's Order to Show Cause, pertinent Complaints filed in Circuit Court case and prior-submitted Joint Pretrial Stipulation, in preparation for drafting Written Opening Statement in connection with Show Cause hearing in bankruptcy case EFTA00800964 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 5 Date Services Hours Amount 07/18/18 TLC Review bankruptcy docket; follow up with C. Pugatch 3.50 787.50 re court setting hearing on our Motion to Strike Intervenors' Damages and for Limited Discovery; work on Response and Objection to Duces Tecum directed to Fowler White; finalize Response and Objections to Duces Tecum directed to J. Epstein in state court proceeding; file same; forward to D. Indyke; follow up on new dates for J. Epstein's, Fowler White's and Link & Rockenbach's depositions; communicate with D. lndyke, C. Pugatch and J. Goldberger re same 07/18/18 DMS [No Charge - getting up to speed on case] Work with 0.80 0.00 T. Campbell to obtain case-specific factual and procedural background, in preparation for drafting and preparing Written Opening Statement in connection with Show Cause Hearing in U.S. Bankruptcy Court. 07/18/18 SJL Follow up on hearing on Motion to Strike Intervenors' 4.90 3,675.00 Damages; follow up on resetting depositions; work on preparations for upcoming hearings 07/19/18 DMS [No Charge - getting up to speed on case] Continued 3.80 0.00 preparation for drafting Written Opening Statement in connection with the show cause proceeding in Bankruptcy Court, continue review, analysis, and scrutinization of extensive materials associated with the issue of the CD containing the allegedly privileged documents located at Fowler White, including transcript of the April 2018 initial show cause hearing before the bankruptcy court, Epstein's Circuit Court Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Appointment of Special Master and Supplement thereto, Epstein's Response in Opposition to Farmer Jaffe's Motion for Issuance of Order to Show Cause, and bankruptcy orders leading up to the November 2010 order at issue EFTA00800965 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 6 Date Services Hours Amount 07/19/18 DMS Begin drafting and preparing J. Epstein's "Written 1.20 474.00 Opening Statement" to be filed in connection with evidentiary show cause hearing ordered by the bankruptcy court, including excerpts of the "Introduction" section setting forth material factual background of the firm's discovery of the CD at issue, inter-weaving explanations of J. Epstein's innocence vis-a-vis any alleged violation of the November 2010 bankruptcy court order and outlining sub-headings therein concerning what we expect the evidence to show as to lack of wrongdoing as well as lack of any cognizable damages or losses by Farmer Jaffe, B. Edwards, or Intervenors 07/19/18 SJL Work on preparations for upcoming two-day hearing 4.50 3,375.00 on more than twenty motions; review Motion to Strike filed by Intervenors in Bankruptcy Court proceeding; review B. Edwards' Responses to our Motion to Amend Exhibit List and our Motion to Compel Edwards to Identify Witnesses; follow up on J. Scarola's communications with court on same; communications with J. Indyke and J. Epstein; follow up on deposition schedule; work on preparations for bankruptcy court hearing 07/20/18 TLC Finalize Objections and Responses to Duces Tecums 4.20 945.00 directed to Link & Rockenbach and Fowler White; communications with co-counsel re filing of same; multiple communications concerning the rescheduling of J. Epstein's, Link & Rockenbach's and Fowler White's depositions; work on Motion for Permission to Unseal Disc and 47 Exhibits to use at bankruptcy evidentiary hearing; provide filings to D. Indyke and J. Epstein 07/20/18 SJL Review B. Edwards' Response to our Motion to Allow 4.80 3,600.00 Disclosure of Expert Witness; work on Show Cause requirements; follow up with D. Indyke and J. Epstein; work on deposition schedule; work on finalizing Objections to Duces Tecum to Link & Rockenbach and Fowler White; follow up with Fowler White re depositions EFTA00800966 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 7 Date Services Hours Amount 07/22/18 SJL Work on preparations and strategies for upcoming 3.50 2,625.00 two-day hearing in state court matters; work on Opening Statement in Bankruptcy proceeding; follow up on Declarations to use in Bankruptcy Court 07/23/18 TLC Follow up with J. Scarola's assistant re deposition 1.50 337.50 schedule; prepare Amended Notice of Hearing to add Motion to Compel Bates Number to August hearing time; telephone conference with judicial assistant re hearing; work on preparations for same 07/23/18 SJL Continue working on preparations for August 2-3 5.80 4,350.00 two-day hearing on all pending Motions (22 Motions) in state court action; work on Bankruptcy Court strategies; communications with client 07/24/18 DMS Prepare first draft of J. Epstein's Sworn Declaration 1.50 592.50 of Fact to be used as an exhibit at the Bankruptcy Court's Show Cause Hearing setting forth factual allegations material to J. Epstein's lack of knowledge of CD at issue or documents contained thereon and destruction of select emails after receipt of same in 2018, while using Response in Opposition to Issuance of Order to Show Cause as a guide to the pertinent facts 07/24/18 DMS Review J. Epstein's Response in Opposition to 0.80 316.00 Farmer Jaffe's Issuance of an Order to Show Cause why Fowler White and J. Epstein Should not be Held in Contempt, and the exhibits thereto, for purposes of and as needed to prepare Sworn Declaration of Fact of S. Link, Esq. 07/24/18 DMS Review B. Edwards' Motion to Strike J. Epstein's 0.70 276.50 Untimely Supplemental Exhibits and to Strike All Exhibits and Reference to Documents Containing Privileged Materials, and Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, for purposes of drafting Sworn Declaration of Fact of Scott J. Link, as part of Bankruptcy Court show cause hearings 07/24/18 DMS Prepare first draft of Sworn Declaration of Fact of 2.00 790.00 Scott J. Link, Esq., as required by Show Cause Order in preparation for Bankruptcy Court hearing EFTA00800967 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 8 Date Services Hours Amount 07/24/18 TLC Telephone conference with Judicial assistant re 3.80 855.00 hearing; work on hearing folders for 22 motions to be addressed at August 2 and 3 hearings; prepare letter to Judge Hafele sending banker box of filings for hearing; follow up with D. Indyke re hearing submissions 07/24/18 SJL Continue working on preparations for August 2-3 4.50 3,375.00 hearings on all pending Motions; telephone conference with D. Indyke re same; work on preparations for August 1 hearing on Epsteln's Motion to Strike Intervenors' Requested Relief in Bankruptcy Proceeding; work on submissions for Bankruptcy Court 07/25/18 DMS Review Fowler White's Response to Motion for 0.50 197.50 Issuance of Order to Show Cause, for purposes of drafting J. Epstein's Written Opening Statement 07/25/18 DMS Work on J. Epstein's Written Opening statement, by 2.00 790.00 editing and revising existing Introductory explaining events that occurred from November 1, 2017 through March 8, 2018 and thereafter, and framing the arguments as to what the evidence will show into two subsections: (a) that J. Epstein did not violate the November 30, 2010 Order, and (b) that Farmer Jaffe, Edwards, and Intervenors have sustained no actual, compensatory losses, encompassing 07/25/18 SJL Work on preparation for two-day hearing in front of 4.80 3,600.00 Judge Hafele; work on attorney-client work product issues relating to emails; telephone conference with J. Epstein re upcoming hearings and position to take regarding emails 07/25/18 TLC Finalize package to Court; prepare e-mail transmittal 0.50 112.50 to counsel re same; communications with client group EFTA00800968 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 9 Date Services Hours Amount 07/26/18 DMS Conduct legal research, analyze large quantity of 2.20 869.00 Florida and out-of-state case law, and prepare detailed correspondences to S. Link, on the issue of when a party waives the attorney-client and work-product privileges as a result of disclosure to an adversary, including in the case of when there is a confidentiality agreement, and the extent to which such a waiver constitutes same as to third-parties, in preparation for telephone conference with J. Epstein and J. Goldberger, as well as August 2018 hearings in connection with our efforts to use B. Edwards' e-mails for which privileges are claimed, at trial 07/26/18 DMS Communicate with J. Epstein, J. Goldberger and D. 0.50 197.50 Indyke, along with S. Link via telephone conference, to discuss strategy in connection with upcoming show cause proceedings in the bankruptcy court and upcoming state court hearings concerning our efforts to use certain e-mails of B. Edwards for which a privilege is claimed, at trial 07/26/18 DMS Revise, edit, and proofread draft of J. Epstein's 1.20 474.00 Written Opening Statement to be filed with the Bankruptcy Court in connection with the show cause proceeding, prior to providing first draft to S. Link, for his review and comment 07/26/18 KBR Review B. Edwards' Response in Opposition to J. 0.50 375.00 Epstein's Motion to Compel B. Edwards to Identify Bates Numbers of Documents Produced (e-served 7/26/18) 07/26/18 KBR Review B. Edwards' Objection to J. Epstein's 0.50 375.00 Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' 0.30 118.50 Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Limited Discovery, Evidentiary Hearing, and Appointment of Special Master, served July 26, 2018, as assisting counsel, in furtherance of strategizing as to our arguments to use and/or obtain in camera inspection of e-mails at issue EFTA00800969 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 10 Date Services Hours Amount 07/26/18 SJL Work on bankruptcy opening statement; work on 8.50 6,375.00 Declaration of S. Link; work on Declaration of J. Epstein; telephone conference with J. Epstein, J. Goldberger and D. Indyke; work on arguments for upcoming hearing; review multiple Responses filed by B. Edwards and follow up with client and D. Indyke re same 07/27/18 SJL Continue working on preparations for upcoming 7.20 5,400.00 two-day hearing on 22 pending matters; communications with D. Indyke and J. Epstein re same; work on strategies and demonstratives; review Motions and Responses; work on bankruptcy preparations 07/29/18 SJL Work on preparations for upcoming two-day hearing 6.50 4,875.00 on 22 pending matters 07/29/18 KBR Begin review hearing folders in preparation for 4.50 3,375.00 two-day hearing on 22 pending matters; work on strategies/arguments for same 07/3W18 DMS Continue review and analysis of transcript of hearing 0.30 118.50 held April 13, 2018 in bankruptcy court on Motion for Order to Show Cause, for purposes of revising and editing Written Opening Statement and Sworn Declarations of S. Link and J. Epstein 07/30/18 DMS Attend and participate in conference call with S. 1.90 750.50 Link„ K. Rockenbach, T. Campbell and D. Indyke regarding strategy in connection with upcoming August 2, 2018 and August 3, 2018 state court hearings, including obtaining specific instructions re legal research needed and for what purposes EFTA00800970 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 11 Date Services Hours Amount 07/30/18 1LC Provide J. Goldberger with upcoming schedule; meet 8.30 1,867.50 with S. Link, K. Rockenbach and D. Schwarz, with D. Indyke attending by phone, to discuss hearing strategies and demonstratives; follow up with J. Scarola's office re setting hearing on our Objection to Duces Tecum; cull through bankruptcy filings to pull out pertinent documents to use at hearing re waiver / Conrad Scherer; review bankruptcy hearing transcripts; cull out and review docket for all Orders Setting Trial and prepare detailed timeline to use as demonstrative at hearing; begin reviewing box of attorneys' eyes only documents to cull out examples to use at two-day hearing 07/30/18 KBR Work on preparations for two-day hearing, including 5.50 4,125.00 specific preparations relating to J. Epstein's Motion for Protective Order and Motion in Limine of Unrelated Settlements, Edwards' Motion in Limine re Admissibility of Exhibit No. 132 and deposition designations; team meeting with S. Link, D. Schwarz and T. Campbell, with D. Indyke attending a portion by phone, to strategize for hearing and discuss demonstratives and presentation 07/30/18 DMS Research Florida case law on the issue of a trial 0.30 118.50 court's authority and obligation to allow amendments to exhibit lists, enter a pre-trial order and allow a party's late disclosed exhibits in preparation for August 2, 2018 and August 3, 2018 state court hearings 07/30/18 DMS Review Florida case law (5 cases) on the issue of a 1.00 395.00 trial court's authority and obligation to enter a pre-trial order, allow amendments to an exhibit list and allow a party to use late disclosed exhibits in preparation for August 2, 2018 and August 3, 2018 state court hearings 07/30/18 DMS Research case law on the "common interest" 0.30 118.50 exception to the general rule that attorney-client privilege is waived based on voluntary disclosure of the privileged material to another in preparation for August 2, 2018 and August 3, 2018 state court hearings EFTA00800971 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 12 Date Services Hours Amount 07/30/18 DMS Review case law on the "common interest" exception 1.20 474.00 to the general rule of waiver of attorney-client and work-product privilege based on voluntary disclosure of privileged information to another in preparation for August 2, 2018 and August 3, 2018 state court hearings [12 cases, 2 secondary sources (treatises)] 07/30/18 DMS Prepare detailed memoranda to the file for use by S. 0.50 197.50 Link in preparation for August 2, 2018 and August 3, 2018 state court hearings, with applicable and favorable law on the issues of limitations on the trial court's authority to exclude otherwise untimely trial exhibits, and the "common interest" exception to the general rule of waiver of attorney-client privilege based on voluntary disclosure to another 07/30/18 SJL Work on preparations for two-day hearing before 8.20 6,150.00 Judge Hafele and August 1 hearing before bankruptcy court; work on demonstratives and strategies; team meeting and telephone conference with D. Indyke re same; review B. Edwards' filings and work on review of record to dispute same; work on Bankruptcy Court Opening Statement and Declarations; review research re amendments to trial orders, amendments to exhibit and witness lists, and common interest doctrine EFTA00800972 Client Ret: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 13 Date Services Hours Amount 07/31/18 TLC Prepare detailed chart of Trial Orders and calculate 11.20 2,520.00 all exhibit and witness list exchange deadlines set forth in same and prepare analysis compared to what the parties filed in response Including an analysis of everything late filed and the changes (number of witnesses and exhibits) from each; check citing history of Debrincat v. Fischer; compare email exhibits used at B. Edwards' October 2013 deposition to charts to determine if any of the documents came from the attorneys' eyes only production; follow up with M. Nurik re August 1, 2018, hearing on S. Rothstein's Motion to Dismiss; telephone conference with J. Goldberger re materials for two-day hearing; review Bankruptcy Court docket and hearing transcripts to locate pertinent documents relating to Razorback's Subpoena to Trustee and positions taken regarding B. Edwards as an adversary; telephone conference with D. Indyke re August 1 hearings; follow up with e-mail to same; work on Bankruptcy Court Opening Statement and Declarations of S. Link and J. Epstein; prepare demonstrative to show waiver issues; review CVRA docket and documents for information to include on same; review privilege log to determine designations for 47 exhibits (i.e., work product, attorney-client, relevance); follow up with C. Pugatch re necessity of renewing Response to Duces Tecum in light of re-notice; telephone conference with D. Indyke re positions taken by B. Edwards' regarding net worth discovery; research positions taken In case re same and forward to J. Goldberger; review B. Edwards' March 23, 2010, May 15, 2013, October 10, 13, and November 10, 2017, deposition transcripts and extrapolate testimony regarding communications/meetings with S. Rothstein to use to show B. Edwards may have been withholding information; review B. Edwards' filings and outlines for disclosure of number of pages produced in case; prepare outline of same to use at hearing EFTA00800973 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 14 Date Services Hours Amount 07/31/18 DMS Work on Sworn Declaration of S. Link, Sworn 1.30 513.50 Declaration of J. Epstein, and J. Epstein's Written Opening Statement to be filed with the bankruptcy court, to Incorporate changes and revisions directed by S. Link, and limit arguments and facts set forth in same to eliminate excess references to J. Epstein's possession of emails in state court proceedings based on Judge's limitation of deposition to not include conduct in state court proceedings 07/31/18 SJL Review Bankruptcy Court records re positions taken 9.50 7,125.00 by Razorback; review detailed production timeline; review attorneys' eyes only production to cull out sampling to use at hearing to show judge type of work product documents withheld were similar to the documents listed on the privilege log; work on waiver demonstrative; work on preparations for two-day hearing; work on preparations for August 1, 2018, bankruptcy court hearing on J. Epstein's Motion to Strike the Intervenors' request for relief; communications with C. Pugatch re same; multiple communications with D. Indyke and J. Epstein; work on strategies 07/31/18 DMS Research case law on the "joint prosecution" doctrine 0.50 197.50 to determine if this has different elements from the 'common Interest" and/or 'joint defense" doctrines 07/31/18 DMS Prepare Memoranda to the file on "joint prosecution" 0.20 79.00 doctrine, summarizing conclusion that same is not meaningfully distinct from 'common interest" and/or 'joint defense" doctrines regarding non-waiver of attorney-client privilege, In preparation of August 2, 2018 and August 3, 2018 state court hearings EFTA00800974 Client Ref: 0002 - 0001 August 7. 2018 Invoice # 1034 Page 15 Date Services Hours Amount 07/31/18 DMS Review Florida and federal case law cited in J. 1.00 395.00 Epstein's Motion for Court to Declare Relevance and Privileged Nature of Documents and with Specific Request for In Camera Review to Determine Relevance, Inapplicability, and Waiver, Plaintiffs Response thereto, and our Supplement thereto on the issues of "issue injection" and "Implied waiver" as bases for finding a waiver of attorney-client or work product privileges; conduct additional legal research of case law on these doctrines, in preparation for August 2, 2018 and August 3, 2018 state court hearings 07/31/18 DMS Prepare Memorandum to the file for use by S. Link at 0.60 237.00 August 2, 2018 and August 3, 2018 state court hearings, containing summary of the law and favorable propositions concerning the "at issue" and "implied waiver" doctrines as bases for finding a waiver of attorney-client and work product privileges Recapitulation Rate Hours Amount TLC Tina L. Campbell 225.00 69.80 15,705.00 SJL Scott J Link 750.00 133.60 100,200.00 KBR Kara Berard Rockenbach 750.00 11.00 8,250.00 DMS Daniel M Schwarz 395.00 30.10 8,690.00 Sub Total 132,845.00 Courtesy Discount -14,274.50 For Current Services Rendered 244.50 $118,570.50 Expenses and Advances Date Expenses Amount 06/01/18 Courier /Delivery Fee 6/5/18 to PBC Courthouse - Judge Hafele - 25.00 Coastal Messenger Service, Inc. 07/10/18 Outside Copy Charge Hearing Materials (2 day hearing on all pending 1,087.61 motions) - Palm Beach Copy Service, Inc. 07/31/18 Westiaw Research 139.53 Total Expenses and Advances $1,252.14 EFTA00800975 Client Ref: 0002 - 0001 August 7, 2018 Invoice # 1034 Page 16 Sub Total $134,097.14 Courtesy Discount -14,274.50 Total Current Work $119,822.64 Trust Funds Balance: $41,394.86 EFTA00800976  Please return this page with remittance to Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Beach, FL 33401 Invoice ii 1034 Bill Date: August 7, 2018 Client Code: 0002 Client Name: Jeffrey Epstein Matter Code: 0001 Matter Name: Bradley Edwards $134,097.14 Courtesy Discount -14,274.50 Total Current Work $119,822.64 Trust Funds Balance: $41,394.86 Amount enclosed: EFTA00800977