EFTA01102251.pdf

Date: No. 7/30/2012 615 1 Terms Law Office of Tonja Haddad, PA 524 South Andrews Avenue r NET 30 days Suite 200 North Fort Lauderdale. FL 33301 Bill to Darren Indyke Jeffrey Epstein 301 East 66th Street, 10B New York 10065, New York 10065 Project Name Billing Type Rate Rothstein/Edwards Retainer - Hourly 385.00 Amount Total hours: 124.25 29,636.25 Work Hours Date Description Hours 6/27/2012 Finish Researching and Draft Motion to Strike 4.50 Motion to Compel. Review and respond to Communications from client, co-counsels, and opposing counsel. 6/28/2012 Review Initial Complaint. Send letter regarding 2.50 same. Revise letter and send to co-counsels regarding discovery. 6/29/2012 Review and respond to emails from co-counsels. 1.50 Revise and finalize Motion to Strike. Finish Civil Theft Condition Precedent research. 7/3/2012 Research for Summary Judgment. 5th 6.50 Amendment issues and Litigation Privilege. 7/3/2012 Review and respond to emails regarding case. 0.50 7/9/2012 Review Civil Theft Statutes and respond to 0.50 Request to Produce. 7/9/2012 Review Privilege logs and drafts of letter to Scarola 0.50 re: discovery. Revise letter and send same to Darren to review. Page No.1 EFTA01102251 Work Hours Date Description Hours 7/10/2012 Review and revise discovery letters and send 0.50 same. 7/10/2012 Research regarding Civil theft Demands. Draft 2.50 discovery response to request to produce regarding civil theft demand letter and cover letter explaining law regarding same. 7/10/2012 Revise letter to Scarola regarding discovery and 0.30 case evaluation. Send same to client and co- counsels to review. Communications with Darren. 7/11/2012 Revise and send letter requesting emails. 0.20 Teleconference with Darren regardng same. (NO CHARGE) 7/12/2012 Read statement of undisputed facts from Edwards' 3.20 Motion for Summary Judgment. Label and list disputed allegations. 7/13/2012 Review and respond to communications regarding 0.60 hearing date. Review letter from Scarola. Emails regarding same. Teleconference with Darren regarding Summary Judgment. 7/16/2012 Review Referenced Exhibits in file (in our 3.00 possession) from the Statement of Undisputed Facts. Mark issues and send to Darren. 7/17/2012 Conduct research on Motion for Summary 6.25 Judgment issues as presented in statement of undisputed facts. 7/17/2012 Teleconference with Darren lndyke. 0.40 7/17/2012 Teleconference with Jack Goldberger re: Criminal 2.00 plea and Statement of Facts for Summary Judgment. Receive and Review Plea Colloquy and Charging documents for Criminal case, Non-Prosecution Agreement and Addendum to Non-Prosecution Agreement. 7/19/2012 Research regarding dismissal of case and 3.75 prevailing party attorneys fees. 7/20/2012 Continue research regarding dismissal of case and 2.50 attorneys fees under 57.105 Notice. Continue researching legal issues regarding 3.20 7/24/2012 potential dismissal of lawsuit and liability. Legal Research and Writing performed by Debra 70.00 7/24/2012 Fein at reduced rate of S125.00 per hour. See addendum to this bill for specific work and time spent. Prepare for and attend Hearings on Motion to 3.50 7/24/2012 Compel and Motion to Continue. Review documents. Draft Amended Answer and 0.80 7/25/2012 Affirmative Defenses. 1.75 7/25/2012 Revise and finalize Memorandum of law regarding case dismissal. Prepare for and attend meeting with client. 3.00 7/27/2012 (Do not charge for Debbie's time}. Teleconference with Darren. 0.30 7/30/2012 Page No.2 EFTA01102252 Work Hours Date I Description I Hours Revise and finalize Answer and Affitmative Defenses. Total hours: '23.25 Amount 29.636.25 Subtotal 29.636.25 Tax 0.00 Total Due 29,636.25 Page No. 3 EFTA01102253  d by TI-IC) Debra Fein- Epstein July Time on Summary Judgment- Final (edite 7/2/12 2.5 research for summary judgment; 5th amendment THC re same 7/3/12 3 research 5th amendment issue and correspondence with the 7/7/12 3.50 compile material for 5th amendment argument; formulate argument; review the material to see what to include late the 7/8/12 3.5 compile material for 5th amendment argument; formu start writing argument; review the material to see what to include; privilege; Epstein 7/9/12 8.5 write fifth amendment argument; research litigation t issue; add research litigation privilege; review draft of 5th amendmen . factual information from this case and send to THC for review ary judgment 7/10/12 8.75 litigation privilege research for motion for summ summary 7/11/12 7.5 write litigation section of the response to the motion for judgment nse to motion for 7/12/12 8 continue drafting litigation privilege section of respo summary judgment; work on introduction section nce; also standard 7/15/12 6 research issue on 5th amendment and adverse infere on the motion for for summary judgment and trial court's role in ruling summary judgment; write the section and rewrite sections of 7/16/12 5.25 edit inferences section of response motion; edit litigation privilege sections n; research 7/17/12 5 edit litigation privilege section of the response motio additional issues; rewrite sections ion privilege, negative 7/18/12 3.25 put all three written sections together -- litigat and send to THC inference and fifth amendment sword and shield, edit organize research; outline 7/19/12 6.25 abuse of process research; finish research; summary judgment; and start writing this section of the motion for review disk from Fowler White (1hour- do not bill) (reduced by 17 hours)) Total: 70 hours (modified by THC on July 24, 2012 EFTA01102254