EFTA00801256.pdf

LiR LINK & ROCKENBACH, P.A. CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 F November 6, 2017 Via Email leevacationOginaitcom 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 5, 2017. Please wire the payment to us per the attached Wire Transfer Instructions. Please do not hesitate to call me if you have a tons r garding this bill. Thank you. Ver Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00801256  LINK & ROCKENBACH, CIVIL TRIAL & APPELLATE LAW 1655 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 T 661.727.3600 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 EFTA00801257 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 November 6, 2017 In Reference To: Jeffrey Epstein v. Bradley J. Edwards Case No. 50-2009 -CA-040800 - XXXX-MB File No. 100.001 Invoice #32937 Professional Services Hrs/Rate Amount 10/12/2017 SJL Work on review of court filings and transcripts; multiple 3.50 2,625.00 communications with D. Indyke 750.00/hr TLC Work on retainer agreement; Review Complaint and other trial 2.10 472.50 related documents; organize same 225.00/hr 10/13/2017 SJL Continue review of court filings and transcripts; multiple 6.80 5,100.00 communications with D. Indyke 750.00/hr TLC Work on assembling materials for S. Link's review, work on retainer 0.60 135.00 agreement 225.00/hr 10/14/2017 SJL Continue review of court filings and transcripts; work on strategies; 2.50 1,875.00 multiple communications with D. Indyke 750.00/hr 10/16/2017 SJL Telephone conference with co-counsel and D. Indyke; work on 5.20 3,900.00 mediator selection; work on trial strategies; work on review of court 750.00/hr filings and transcripts; review witness lists and stratagize over additional rebuttal witnesses to identify, if any; work on mediation issues and mediator selection TLC Work on assembling documents for S. Link's review; follow up with 1.00 225.00 co-counsel re mediation 225.00/hr 10/17/2017 TLC Calculate deadline to serve Proposal for Settlement; review docket to 4.20 945.00 determine if any protective orders in case governing documents 225.00/hr deemed confidential; work on Proposal for Settlement, Release and Stipulation and Order of Dismissal; work on chronology and key documents EFTA00801258 Jeffrey Epstein Page 2 HrslRate Amount 10/17/2017 SJL Work on Proposal for Settlement issues; multiple communications 3.20 2,400.00 with client group and co-counsel; review court filings; work on 750.00/hr strategies KBR Work on Proposal for Settlement in compliance with Florida Law 0.80 600.00 750.00/hr 10/18/2017 SJL Work on mediators and mediation dates; work on Proposal for 8.40 6,300.00 Settlement; work on preparations for UMC hearings; work on 750.00/hr strategies with Gunster team 10/19/2017 SJL Attend UMC hearing on Motion to special set hearing on pending 9.20 6,900.00 motions; follow up with J. Scarola on his client's settlement position; 750.00/hr share same with client group; work on Proposal for Settlement; multiple communications with Gunster team, co-counsel and client group; prepare for team meeting with Gunster; work on detailed agenda TLC Work on Proposal for Settlement; communications with Gunster 6.80 1,530.00 team and D. Indyke re same; work on comprehensive chart of 225.00/hr motions to determine court rulings, outstanding issues, etc.; work on key documents binders of same; work on obtaining court documents KBR Work on agenda items; conference with Gunster team 3.50 2,625.00 750.00/hr 10/20/2017 SJL Review Edwards' expert's report; continue reviewing court filings and 10.20 7,650.00 transcripts; prepare for and attend strategy meeting with Gunster 750.00/hr team; work on agenda for meeting; multiple telephone conferences with D. Indyke; work on Proposal for Settlement; follow up on service of same TLC Work on agenda; continue working on motions and pleadings 6.40 1,440.00 binders to assemble pertinent documents for team's review; prepare 225.00/hr for and attend strategic team meeting with Gunster; follow up with co-counsel re obtaining files; follow up on service of Proposal for Settlement; calculate response deadline KBR Work on agenda; review court filings and orders; prepare for and 7.20 5,400.00 attend strategic meeting with Gunster team; work on follow up 750.00/hr 10/21/2017 SJL Continue reviewing court filings and transcripts; work on startegies 7.50 5,625.00 and review of research; communications with Gunster team re 750.00/hr strategies and research; work on agenda for first team meeting with Gunster, co-counsel and client group TLC Continue working on comprehensive agenda and following up with 2.00 450.00 trial team on strategies/research 225.00/hr 10/22/2017 SJL Continue reviewing court filings and transcripts; work on strategies 6.80 5,100.00 and review of research; work on agenda for team meeting with 750.00/hr Gunster, co-counsel and client group; multiple communications with Gunster team and client group; follow up with co-counsel to obtain EFTA00801259 Jeffrey Epstein Page 3 Hrs/Rate Amount files; communications with D. Walbolt at Best Evidence re focus group 10/22/2017 TLC Work on comprehensive to do list and agenda; prepare analysis of 8.50 1,912.50 client's counsel representation in case; continue working on review 225.00/hr and organization of documents; send D. Walbolt key pleadings for focus group; work on discovery charts, including detailed chart of requests directed to B. Edwards and B. Edwards' responses 10/23/2017 SJL Prepare for and attend strategy meeting with Gunster team; work on 10.40 7,800.00 comprehensive to do list; continue working on review of documents 750.00/hr and research; follow up on setting B. Edwards' deposition TLC Continue working on comprehensive to do list; continue working on 9.20 2,070.00 review and organization of documents; attend strategy meeting with 225.00/hr Gunster team; work on discovery charts, including detailed chart of requests directed to B. Edwards and B. Edwards' responses; begin reviewing federal court action; research Dershowitz case; prepare for and attend meeting with Gunster team KBR Prepare for and attend strategy meeting with Gunster team; 6.20 4,650.00 complete to do items 750.00/hr 10/24/2017 SJL Prepare for and attend team meeting with co-counsel and client 8.20 6,150.00 group; work on to do items; work on follow up to meeting; work on 750.00/hr preparations for focus group; continue review of court documents and transcripts TLC Work on discovery charts, to do list and assembling key documents; 9.50 2,137.50 prepare for and attend team meeting with all counsel and client 225.00/hr representatives; follow up on obtaining documents from co-counsel KBR Attend team meeting with co-counsel and client group; work on focus 6.90 5,175.00 group preparation 750.00/hr 10/25/2017 SJL Continue review of research and analysis and working strategies; 6.50 4,875.00 multiple communications with trial team 750.00/hr TLC Work on chronology of all orders; follow up with co-counsel on 3.10 697.50 documents and discovery issues; prepare follow-up to do tasks from 225.00/hr team meetings; work with Gunster on document management issues 10/26/2017 SJL Continue review of research and analysis and working strategies; 5.60 4,200.00 multiple communications with trial team; work on dates for hearing 750.00/hr on pending motions TLC Review documents received from C. Brewer and cull out key 9.30 2,092.50 documents attorneys need to review; work with Gunster on uploading 225.00/hr to One Note system; work on updating key document binders; continue working on order chronology; follow up with J. Scarola's office re hearing on all pending motions; work on coordinating same EFTA00801260 Jeffrey Epstein Page 4 Hrs/Rate Amount 10/27/2017 SJL Multiple telephone conferences with Gunster team and D. Indyke; 9.30 6,975.00 work on strategies; review J. Epstein's and B. Edwards' deposition 750.00/hr transcripts for focus group designations; follow up with D. Walbot re focus group; prepare for and attend telephone conference with J. Goldberger, R. Critton and D. Indyke; work on focus group summary TLC Continue working on chronology of all orders in case; distribute to 8.50 1,912.50 trial team; begin working on chronology of past requests for removal 225.00/hr from trial docket in anticipation of new Motion; follow up with J. Scarola on hearing on pending motions and proposed order; update calendar re related deadlines; continue working on obtaining documents from co•counsel; attend telephone conference with J. Goldberger, R. Critton, S. Link and D. Indyke; work on tracking down videos of J. Epstein's deposition to use at focus group; work on line designations of same; follow up with D. Walbot at Best Evidence re focus group KBR Attend telephone conference with J. Goldberger, R. Critton, D. 0.50 375.00 Indyke and S. Link 750.00/hr 10/28/2017 SJL Work on preparation for focus group; communications with Gunster 6.20 4,650.00 team and clients; work with Best Evidence; work on summary for 750.00/hr focus group TLC Prepare Notices of Appearance for S. Link and K. Rockenbach 0.30 67.50 225.00/hr KBR Analyze pleadings; review case law on malicious prosecution and 5.30 3,975.00 defamation (defamation per se) and libel to determine whether 750.00/hr Edwards' damages expert can testify KBR Analyze hearing transcripts, including 10/3/17 with Judge Hafele 0.80 600.00 comments regarding counsel 750.00/hr KBR Legal research - history of this litigation to 4th District Court of 1.20 900.00 Appeal; history of and docket for federal court action as basis for 750.00/hr abuse of process complaint 10/29/2017 SJL Work on preparations for focus group; communications with Gunster 3.50 2,625.00 team and clients; work with Best Evidence; work on summary for 750.00/hr focus group; work on review of allegations in Edwards' victims' cases; work on Jury Instructions and Verdict Forms TLC Follow up with D. Walbolt re focus group logistics; review Complaint 4.30 967.50 in Edwards' victims cases and prepare summary of same; work on 225.00/hr budget; work on Affidavit of R. Critton KBR Work on and coordinate preparations for focus group with S. Link; 5.50 4,125.00 communications with Gunster team re themes for trial and focus 750.00/hr group; work on review of allegations in Edwards' victims' cases; work on Jury Instructions and Verdict Forms EFTA00801261 Jeffrey Epstein Page 5 Hrs/Rate Amount 10/30/2017 SJL Work on preparations for focus group; telephone conference with D. 8.60 6,450.00 Indyke and D. Walbolt re same; prepare for and attend meeting with 750.00/hr Gunster team to strategize on Motion for Continuance of Trial; work on follow up TLC Continue working on chronology relating to continuance of trial 7.30 1,642.50 requests; circulate to team; work with C. Brinson on One Note 225.00/hr uploads; work on chart of J. Edwards' discovery responses; update discovery response notebook with additional items located in co-counsel's files; prepare for and attend meeting with Gunster team to strategize on Motion for Continuance of Trial; follow up with D. Radkey re Motion to Compel and discovery issues; work on focus group preparations; communications with D. Walbolt re same; follow up with court reporter in an attempt to secure ASCII or text transcripts KBR Attend Gunster team meeting; work on follow up items from to do list 5.50 4,125.00 750.00/hr 10/31/2017 SJL Continue working on strategies with client group and co-counsel; 8.20 6,150.00 work on mediation and mock presentations/preparations 750.00/hr TLC Continue working on chronologies and mediation/mock work; follow 1.50 337.50 up with D. Walbolt re same 225.00/hr KBR Analyze court filings and transcripts to obtain overview of case history 6.80 5,100.00 750.00/hr 11/1/2017 KBR Continue review of court filings and transcripts; work on strategies 2.50 1,875.00 750.00/hr SJL Work on Motion for Continuance of Trial; work on preparations for 9.20 6,900.00 focus group; multiple communications with trial team and D. Indyke; 750.00/hr follow up with D. Walbolt re focus group; work on trial matters TLC Work on preparations for focus group; work on updating to do list; 4.20 945.00 work on addressing upcoming trial deadlines; prepare Notice of 225.00/hr Appearance of A. Many 11/2/2017 LD Work on discovery chart of B. Edwards' discovery requests directed 1.80 405.00 to J. Epstein and J. Epstein's responses 225.00/hr KBR Legal research and analysis on mal pros count pled in counterclaim; 6.50 4,875.00 multiple communications with trial team 750.00/hr SJL Follow up with J. Scarola and mediator on mediation; meeting with D. 10.30 7,725.00 Atkinson and D. Indyke re trial strategies; prepare for and attend 750.00/hr focus group; work on Motion for Continuance of Trial; work on Motion to Amend Answer and Affirmative Defenses TLC Follow up with J. Scarola re outstanding matters (mediation, trial 8.50 1,912.50 exhibits, deposition, etc.); prepare for and attend meeting with D. 225.00/hr Indyke and D. Atkinson; begin reviewing and organizing documents provided by T. Haddad; work on binder of discovery served upon EFTA00801262 Jeffrey Epstein Page 6 Hrs/Rate Amount Edwards; work on witness binder; begin assembling documents for J. Edwards' deposition; work on Motion to Amend Answer and Affirmative Defenses and amended pleading; work on Mption for Continuance 11/2/2017 AMM Analyze Complaints, Answers and Counter Claim 2.50 987.50 395.00/hr AMM Attend Pre-Focus Group meeting with D. Indyke 2.10 829.50 395.00/hr AMM Attend Focus Group 2.50 987.50 395.00/hr 11/3/2017 LD Work on discovery chart of B. Edwards' discovery requests directed 3.70 832.50 to J. Epstein and J. Epstein's responses 225.00/hr SJL Work on Pre-trial Stipulation, Motion for Continuance of Trial, 4.20 3,150.00 Affidavit of R. Critton, Motion to Amend Answer and Affirmative 750.00/hr Defenses, Amended Defenses and Joint Motion to Dispense with Mediation; follow up with mediator on canceling mediation; review video of jury deliberation; multiple communications with trial team TLC Work on Motion for Continuance of Trial, Affidavit of R. Critton, 8.30 1,867.50 Motion to Amend Answer and Affirmative Defenses, Amended 225.00/hr Defenses, and Joint Motion to Dispense with Mediation; work on preparations for J. Edwards' deposition; work on assembling exhibits for same; continue review and organization of documents from T. Haddad's files AMM Analyze hearing transcript from 10/3/17 to determine scope of 1.60 632.00 upcoming deposition of B. Edwards 395.00/hr 11/4/2017 TLC Work on Joint Motion to Dispense with Mediation; prepare proposed 5.00 1,125.00 Orders for same; review Judge Hafele's instructions for uniform 225.00Ihr motion calendar hearings; work on Motion for Continuance of Trial; prepare Motions to Withdraw as Counsel and proposed Orders for (1) T. Haddad; (2) F. Haddad; and (3) C. Brewer; work on updating trial binder SJL Work on Motion to Compel; work on substitution of counsel issues; 3.50 2,625.00 work on strategy for postponing trial 750.00/hr 11/5/2017 TLC Work on assembling exhibits for B. Edwards' deposition; work on 4.50 1,012.50 chart of B. Edwards' responses to J. Epstein's requests 225.00/hr SJL Continue working on Motion to Compel; work on Pre-Trial Stipulation 2.80 2,100.00 750.00/hr For professional services rendered 348.30 $194,821.50 EFTA00801263 Jeffrey Epstein Page 7 Additional Charges : Amount 11/3/2017 Copying 150.00 Total costs $150.00 Total amount of this bill $194,971.50 Balance due $194,971.50 EFTA00801264