I. MICHAEL BURMAN. P.A.'

I. MICHAEL BURMAN. P.A.' GREGORY W. COLEMAN, PA. ROBERT D. CRITTON, IR., PA) BERNARD LEBEDEKER MARK T. LUTHER, PA. JEFFREY C. PEPIN MICHAEL I. PIKE HEATHER Mr..NAMARA RUDA I FLORIDA BOARD LERIIII ED CIVIL TRIAL LAWYER Sent by E-mail Only Jeffrey Epstein Dear Jeffrey: BURMAN, CRITTON, LUTTIER & COLEMAN LLP A LIMITED LIABILITY PARTNERSHIP May 8, 2009 ADELQUI J. BENAVENIE PARALEGAL I INVESTIGATOR BARBARA M. McKENNA ASHLIE STOKEN-BARING DEITY STOKES PARALFGLIG 5 RITA H. BUDNIfIC or COUNSEL As per our discussion on April 20, 2009 and as we discussed, I am enclosing a revised fee agreement. The agreement Is changed to encompass all matters that have been filed against you, and as well has the "ever green provision" wherein we will keep $150,000 in our trust account at all times against our final bill. If you would like, I will send you a copy of the Trust Statement each month reflecting the monies being held. That is up to you. As we also discussed, I expect to be paid within two weeks of sending our bill. You correctly noted that our bills do not necessarily come within the first of every month. If you have questions about the bills, the time spent or any other aspect of the representation, give me a call and we can discuss it and resolve it quickly. With regard to Lisa, as I advised you, we do have some costs with Lisa being here and therefore as your accountant duly noted, we pay her $40 and charge her at $50 rather than $125 which we otherwise would charge for a paralegal. I use her to reduce costs to you, not as a profit center. I will probably need to keep her working in that all of Jessica's time would be eaten up with filing/indexing. Lisa also does subpoenas for us if she has time. We have many cases. You said we can have some fun and I agree. Cordially Roberto. Critton, Jr. RDC/clz Enclosures I•A•W• lf •E•R•S 515 N. FLAGU3R DRIVE I SUITE 400 / WEST PALM BEACH, FLORIDA 33401 TELEPHONE (561) 842-2820 FAX (561) 844-6929 mailebelclaw.com EFTA00602002 AMENDED REPRESENTATION AGREEMENT The law firm of Burman, Critton, Luttier & Coleman, LLP (hereinafter "Firm") will provide multiple representation of Jeffrey Epstein (hereinafter "client" or "you") in the following matter(s) or proceeding(s): cases or threatened lawsuits, claims against Jeffrey Epstein and the Firm and client agree to the following: Retainer Required From Client The client shall deposit $150,000.00 in the Firm's trust account, which amount shall remain in that account and used against final billing. If the bill exceeds the amount, the client shall pay the additional amount and if the bill is less than the amount in trust, the balance shall be returned to the client. Fees for which the Client is Responsible As reasonable attorney fees, the client agrees to pay the following sums: ■ $500 per hour for senior partners' time; ■ $300 per hour for senior associates' time; ■ $200-$250 per hour for junior associates' time; • $125 per hour for paralegal and investigator time. You will be charged for all attomey and paralegal time expended in connection with our representation of you, including but not limited to conferences, telephone calls, discovery, trial preparation, trial, review and drafting of documents, negotiations, research, court time and travel time. As well, you will be charged for any attorney and paralegal time expended to collect any funds, including fees and costs, from any other party. The hourly rates contained herein are subject to review and increase on an annual basis. In some instances, the Firm may be entitled to a Court awarded fee. Accordingly, you agree to pay a reasonable attorney fee as determined in accordance with this agreement or as awarded by the Court, whichever is greater. Costs for Which Client is Responsible In addition to the fees, it is agreed that you will be responsible for all court costs, investigation expenses, and any other costs or expenses incurred in the preparation and trial of your case. Such costs include, but are not limited to, filing fees, Sheriffs service and any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS when necessary, investigative costs, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs. The EFTA00602003 necessity of an expert shall be determined at our sole discretion. As well, you will be charged for any costs incurred if necessary to collect any funds, including fees and costs, from any other party. Monthly Billing Statement Sent to Client The client will be sent an itemized monthly billing statement which will include fees and costs for legal services rendered. The only way that we can provide you with legal services is for you to pay your fees and cost charges in a timely manner after receipt of your monthly billing statement. Any statement for services which remains outstanding for greater than thirty days from the date it is sent, shall accrue interest at the rate of 1.5% per month as to the outstanding balance. YOU AGREE TO CAREFULLY READ ALL BILLING STATEMENTS AND PROMPTLY NOTIFY US, IN WRITING, OF ANY CLAIMED ERRORS OR DISCREPANCIES, WITHIN FIFTEEN (15) DAYS FROM THE DATE OF THE STATEMENT. IF WE DO NOT HEAR FROM YOU IN WRITING, IT IS PRESUMED THAT YOU AGREE WITH THE CORRECTNESS, ACCURACY, FAIRNESS, NECESSITY AND REASONABLENESS OF THE BILLING AND SERVICES RENDERED. Right to Withdrawal; Fees Earned and Costs Expended Nonrefundable In fairness to all our clients, who are current, no lawyer in our office may continue working on a file in the event the previous billing statement has not been paid; and, in this event, we reserve the right to cease legal work and withdraw from the case, and the client hereby consents to said withdrawal. Funds which have been earned for legal services or which have been expended for costs are not refundable. Recovery of Settlement. Judgment or Otherwise on Your Behalf The Firm may receive money on your behalf from a settlement, judgment or otherwise. In such event, you authorize the Firm to deduct and retain from such monies any balance due the Firm for unpaid attorney fees and costs before disbursing the remainder of such monies to you. You will receive a full accounting, (or a "Closing Statement"), reflecting how the money received by the Firm was applied. Recovery of Fees and Costs from Other Party In the event the court requires the other party to pay attorney's fees and costs, this will not affect the amount you contract to pay pursuant to this agreement. In the event that money for attorney's fees and costs are actually paid to this firm by the other party, such sums will 2 EFTA00602004 first be applied to any amount owed by you and any balance will be reimbursed to you for amounts you previously paid to this firm. Legal Action to Collect Unpaid Fees & Costs In the event it becomes necessary to take any legal action, including any lien proceedings, to coiled fees and costs owed by you to this firm, you are agreeing to be responsible for reasonable attorney's fees and court costs, incurred in collecting same, including appellate fees, and you are also agreeing that Venue and Jurisdiction shall be the Fifteenth Judicial Circuit of Florida, in and for Palm Beach County, and the laws of the State of Florida shall apply. Entitlement to Charging & Retaining Lien for Unpaid Fees & Costs The client agrees that the Firm is entitled to a charging lien for attorney's fees and costs incurred, but not yet paid, by the client relating to any monies or property, real or personal, received through settlement, judgment or otherwise as result of the representation. As well, the client agrees that the Firm is entitled to a retaining lien for fees and costs due and owing in any other matter for which the client has retained the Firm for representation on any monies or property, real or personal, received through settlement, judgment or otherwise. The client further agrees that the Firm is entitled to retain from any such funds or property, reasonable attorney's fees and costs which may be incurred to assert and pursue its charging or retaining lien and to coiled on same. Right of Either Party to Terminate Agreement Either party may terminate this agreement at any time; however, if there are any outstanding fees or costs due this firm as of the date of the desired termination, said balance due shall be paid in full by the undersigned client forthwith. Upon full payment, the file will be transferred to the client or to an attorney of the client's choice. Modifications. Amendments. Deletions; Validitx Any deletions, modifications or amendments to this agreement must be in writing, and dated and signed by the client and the Firm. Deletions or modifications or amendments may be made to the document itself as long as such change is dated and initialed by the client and Firm. The invalidity or unenforceability of any provision or provisions of this agreement shall not affect the validity or enforceability of any other provision of this agreement, which shall remain in full force and effect. Miscellaneous Although this agreement may seem lengthy and detailed, experience shows that the lawyer and client relationship is enhanced when there is a clear understanding of the financial arrangements at the beginning of the relationship. 3 EFTA00602005 You acknowledge by the execution of this agreement that you are aware of the uncertainty concerning the outcome of litigation and that the Firm has made no guarantees in the disposition of any phase of this matter. All expressions relative to this matter are only expressions of the Finn's opinion and are not guarantees. * * r r* * * I understand and agree to the above terms and do hereby employ your services in accordance with said terms. 7$ id) DATED this g of , 2009. Jeffrey Epstein The employment is accepted in accordance with the above terms. Robert D. C ' ton, Jr. BURMAN, ITTON, LUTTIER & COLEMAN, LLP 4 EFTA00602006 Page 1 of I Connie Zaguirre From: Connie Zaguirre Sent: Friday, May 08, 2009 3:09 PM To: 'Jeffrey Epstein'; 'Darren Indyke' Cc: Robert D. Critton Jr. Subject: Epstein Matter - BCLC Invoice dated May 8, 2009 Attachments: 20090508150207001.pdf Enclosed please find BCLC Invoice #29879 dated May 8, 2009. Gonnzji. Zaguirre, CP, FRP Certi Paralegal Florida Registered Paralegal Assistant to Robert D. Critton, Jr. Burman, Critton, Luttier & Coleman, LLP 515 North Flagler Drive, Suite 400 West Palm Beach, FL 33401 561-842-2820 Phone 561-515-3148 Fax czacluirreAbdclaw.com 5/8/2009 EFTA00602007 LAW OFFICES OF BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 515 NORTH FLAGLER DRIVE SUITE 400 WEST PALM BEACH, FLORIDA 33401 May 08, 2009 Darren K. Indyke, Esq. 301 East 66th Street, Ste. 10B New York, NY 10065 INVOICE Matter ID: 2008-029 Client ID: 3371 EPSTEIN, JEFFREY Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 03/26/2009 LG Prepare remaining Subpoena for Deposition Duces Tecum for medical providers and Notices for Depositions; research online correct addresses for medical providers; memo to file 4.00 hr $200.00 03/29/2009 LG Prepare Notices and Subpoenas for Deposition Duces Tecum for employment records; research online for correct employer addresses; schedule depositions; review correspondence and e-mails; file same 3.00 hr $150.00 03/30/2009 LG Scan and e-mail Motions to Compel Answers to Plaintiffs Interrogatories; memo to counsel; scan and e-mall Defendant's Motion to Stay; memo to counsel; review and organize pleadings; update pleadings file indexes; open 3rd volume pleadings files; file pleadings; memo to BM 5.00 hr $250.00 04/01/2009 RDC Continued preparation for hearing 3.00 hr $1,500.00 04/01/2009 RDC Telephone conference with Jack G re: Bob J 0.20 hr $100.00 04/01/2009 RDC Hearing with Marra; conference with Brad; conference with Jack 2.10 hr $1,050.00 04/01/2009 RDC Conference with Pike and JMB re: discovery; telephone conference with Joe G; e-mails 1.10 hr $550.00 04/01/2009 RDC Telephone conference with Sid re: hearing 0.10hr $50.00 04/01/2009 RDC Tolling Agreement and e-mails 0.70 hr $350.00 04/01/2009 RDC Receipt and review BB - Request for Copies 0.10hr $50.00 04/01/2009 MJP Prepare for and attend hearing on Motion to Dismiss, finalize case law and research cases excluding personal injury damages under RICO 4.20 hr $1,260.00 04/01/2009 BM Receipt of fax from Garcia on new filing of Doe II; prepare letter to Garcia; fax; call to Garcia's office; online search of Pacer; print Complaint, Subpoenas. two 5.75hr $718.75 Orders, pull Interrogatory Answers and copy as Exhibits to Motions to Compel on Doe #2 through 7; finalize Motions to Compel Responses to Request to Produce and Answers to interrogatories in Doe #2 through 7; put in specific language from Responses and Answers 04/01/2009 MJP Drafting Motion to Compel Better Answer to Interrogatories served on Jane Doe 1.20hr $360.00 04/01/2009 RHB Draft letters to Mermelstein • tax returns - (JD No.5-7) 0.30hr $90.00 04/01/2009 RHB Telephone call to Attorney Jack Hill (CMA) regarding Rule 7.1; conference to work out discovery Issues 0.30hr $90.00 04/01/2009 RHB Draft Motions (2) to Compel directed to 1st Request to Produce and 1st Set of 4.40hr $1,320.00 Interrogatories 04/01/2009 JMB Review all recent e-malls; conference with Robert Critton 0.50hr $250.00 04/01/2009 BM Calls from and to School Board Palm Beach County and provide additional information on several Plaintiffs; call from Spearmint Rhino; call from Dr. Jorge; 2.10hr $262.50 Page 1 EFTA00602008 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: call from Quartell; call from Cheetah; receipt of fax from Dr. Jorge re: BB; receipt of fax from WPB Hospitality re: EW employment at Spearmint Rhino; receipt of medical records from Quartell Chiro on BB; update charts of records received per subpoenas 04/02/2009 RDC Hearing on Transfer and conference with Sid rell.; e-mail 1.20 hr $600.00 04/02/2009 RDC Conference with Rita re: Motions to Compel; review Motions (x7); review Order re: hearing; e-mails re: tolling 1.10 hr $550.00 04/02/2009 RDC Complete Answers in JD 2-7 0.80 hr $400.00 04/02/2009 RDC Draft Answers to EW & LM 0.90 hr $450.00 04/02/2009 RDC Continued work re: cases and what is outstanding and responses needed 1.10 hr $550.00 04/02/2009 RDC Letter re: Sid #2; Motion for Sanctions re: discovery 0.70 hr $350.00 04/02/2009 RDC Letter to Sid re: new Federal and directions; to do 0.40 hr $200.00 04/02/2009 RDC Telephone conference with Jack Hill re: Caddy and demand; letter to Jack and letter to Caddy re: video 0.60 hr $300.00 04/02/2009 RDC Telephone conference with Bob J. re: Agreement and settlement of Skye; e-mails 0.50 hr $250.00 04/02/2009 RDC Receipt and review Hill's April 1 letter enclosing Dr. Caddy's video 0.10hr $0.00 04/02/2009 BM Scan and pdf Motions to Compel Answers to Interrogs and Response to RTP with attachments in Doe v. Epstein; file electronically with Clerk of Southern District; conference with RHB and RDC re: Motions to Compel directed to Doe #2 through 6.80 hr $850.00 7 and CMA; scan and pdf 13 Motions to Compel; pull and copy Exhibits to attach; scan and pdf all Exhibits to 13 Motions to Compel; file all Motions electronically with Clerk of Southern District; conference with RDC re: Motions for Protective Order; search Southern District docket sheets for Motions for Protective Order; print; scan and pdf Motions for Protective Order to JG, JE and DI; receipt of 16 e-mails from Southern District Cleric's office; print all attachments 04/02/2009 ROC Conference with Joe G. 0.60 hr $300.00 04/02/2009 RHB Conference with legal assistant regarding filing of Federal Court Motions to 0.25 hr $75.00 Compel and Exhibits 04/02/2009 RHB Review correspondence from Mermelstein (JD Nos. 2-7) regarding tax returns 0.10 hr $30.00 04/02/2009 RHB Review Plaintiffs Response to Motion to Quash based on 5th Amendment (E.W.) 0.50 hr $150.00 04/02/2009 RHB Review Motion to Quash (EW) 0.20 hr $60.00 04/02/2009 RHB Draft memo/e-mail cover regarding issues to address in EW Response to Motion to Quash 0.20 hr $60.00 04/02/2009 JMB Continue analysis and review of investigative materials 2.50 hr $1,250.00 04/03/2009 RDC E-mails re: Saige 0.20 hr $100.00 04/03/2009 RDC Prepare for and conference with Joe G, client, etc. 4.50hr $2,250.00 04/03/2009 RDC Memo and list re: punitive damage issues 0.80 hr $400.00 04/03/2009 RDC Review and sign Tolling Agreement 0.10 hr $50.00 04/03/2009 RDC E-mails and review documents from Jack Hill and review re: Stip and depo 0.90hr $450.00 04/03/2009 RDC Receipt and review BB medical records 0.10 hr $50.00 04/03/2009 BM Receipt of six e-mails from Clerk of Southern District; print attachments; scan and pdf new Complaint for JDII in Federal; scan and pdf JDII Order on Scheduling 2.25hr $281.25 Report and Discovery; diary dates; send Complaint and Order to JO, JE and DI; pull and copy several documents for Guastaferro 04/03/2009 BM E-mail all Motions to Compel and Exhbits to JG, JE and DI 0.50 hr $62.50 04/03/2009 BM Update deadlines chart; copy for RDC. RHB, JMB and Lisa 0.40 hr $50.00 Call to Palm Beach Copy Service with instructions; request checks from Page 2 EFTA00602009 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/03/2009 BM bookkeeping; receipt of letter from Abiding Hearts; receipt of letter from Diamond Entertainment; calls from and to Solid Gold; fax letter to Caddy and Goldberger, receipt of DVDs from Copy Service; send DVDs to Caddy and Goldberger; conference with RDC re: AC; call to Caddy's office; confirm ACs CME for 4110/09 at Caddy's office; receipt of fax from Podhurst; fax Tolling Agreement to Josefsberg and Goldberger; open several files 04/03/2009 JMB Conference with Robert Critton; review materials for Gustaferro; prepare for conference 04/03/2009 JMB Conference with client, Robed Critton, Jack Goldberger and Gustaferro 04/05/2009 RDC Review research and notes re: punitive; read portions of treatise re: sexual assault 04/06/2009 RDC E-mails re: # of topics 04/06/2009 RDC Conference re: motions (x4) and revise answers in EW and LM 04/0612009 RDC Review dosing papers with Patrick and revise subpoena and letter to Bob J 04/062009 RDC Receipt and review Josephsberg April 3rd letter with signed Tolling Agreement;BB- Kuvin's April 3rd letter and Notice of Hearing; AC.CMA - Hills' April 2 letter with Stipulation re: Epstein de . -Notice of Change of Firm and address; Bethesda's April 2 letter re: 04/06/2009 BM Receipt of four Unopposed Motions for Enlargement; diary deadlines; conference with RDC on several issues; calls from Cheetah and Spearmint Rhino; receipt of medicals from Dr. Ira Warshaw on BB; receipt of check from Dr. Jorge; void check; telephone call from Dr. Toufanian re: destroying records; cell to Parent-Child Center re: Jane Doe; fax from Abiding Hearts re: Jane Doe; calls from and to Solid Gold re: EW; letter from Diamond Dolls re: EW; conference with MJP re: Motions for Extension; pull and copy Judge Lewis Order, update hearing folders for tomorrow 04/0612009 MJP Meeting with R. Griffon, Esq. regarding upcoming motions 04/06/2009 MJP Draft Four Motions for Extension of Time in Federal Cases, telephone conference with opposing counsel regarding same 04/06/2009 BM Scan and pdf Tolling Agreement to JO, JE and DI; revise General Release; add Josefsberg's clients to chart; additional call from Parent-Child Center; call from Sally's Beauty Supply re: EW records in Texas; update records chart; copy settlement; scan and pdf Doe #2, 3. 4 & 7 Motions for Extension to Respond to Protective Orders; file Motions for Extension electronically with Southern District Clerk; e-mails from Clerk; print attachments; note to Lisa 04/06/2009 JMB Conference with Robert Craton 04/06/2009 JMB Review updated victim chart, all current e-mails and motions, and current deposition schedule 04/08/2009 JMB Commence review of punitive damage issues 04/07/2009 RDC Prepare for and attend 2 hearings; talked with Edwards re: settlement issues and discovery 04/07/2009 RDC E-mails 04/07/2009 RDC To do; conference with Pike re: motions/responses; conference with JMB re: punitive; Motion to Transfer cases 04/07/2009 RDC Conference with JE 04/07/2009 MJP Drafting Motions to Compel in LM regarding Better Answers to Interrogatories and Requests for Production, confer with R. Critton, Esq.. regarding same, letter to B. Edwards regarding same, and memo to file regarding specially set hearings 04/07/2009 BM Receipt of four e-mails from Southern District Clerk; print Orders; go through filing and notes to Lisa; update charts; several e-mails from Court Reporter confirming depositions; send Joe G. deadllines Chad 04/07/2009 BM Prepare and fax letter to Brad Edwards re: depositions of EW, LM and Jane Doe; 2.75hr $343.75 1.80 hr $900.00 2.50 hr $1,250.00 1.80 hr $900.00 0.40 hr $200.00 0.90 hr $450.00 0.70 hr $350.00 0.70hr $0.00 3.60 hr $450.00 0.20 hr $60.00 1.20 hr $360.00 2.10 hr $262.50 0.50 hr $250.00 0.50 hr $250.00 1.00 hr $500.00 1.30 hr $650.00 0.30 hr $150.00 1.701w $850.00 1.50 hr $750.00 5.80 hr $1,740.00 1.25 hr $156.25 2.20 hr $275.00 Page 3 EFTA00602010 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: go over lists with RDC; several e-mails to and from Guastaferro with attachments; receipt of records from Duffy's; receipt of records fun Wellington Regional; receipt of records from Mary Littlefield; receipt of fax from Sally's Beauty Supply; request payment from bookkeeping to Wellington Regional 04/07/2009 JMB Review Statutes; Rules, Briefs, Cases, etc., regarding punitive damages 04/07/2009 JMB Initial draft of outline/guidelines regarding defense of punitive damages 04/08/2009 BL legal research re: punitive damages and net worth discovery in federal court 04/0812009 RDC Telephone conference from Jack Hill; a-mails re: A.0 and Judge Hafele; conference with Pike re: motions 04/08/2009 BM Call from RDC; conference with MJP; prepare letter to Josefsberg; fax Josefsberg and Goldberger; pull and copy Exhibit A to Motion to Compel; Westlaw research for case; print; fax Motion to Compel Better Answers to Interrogs with attachments In LM to counsel; scan and pdf Motion to Compel and send to JG, JE and DI; scan and pdf letter to Josefsberg and send to JO, JE and DI; conference with Lisa re: filing and opening files; several e-mails to and from Guastaferro; copy Motion and Exhibits for hearing folder, file original Motion with Clerk 04/08/2009 MJp Telephone conference with S. Kuvin 04/08/2009 MJP Telephone conference with R. Critton, Esq., regarding 04/08/2009 MJP Drafting Motion to interrogatories in LM and Motion to Compel Request to produce 04/08/2009 1.0 Review e-mails; review correspondence and pleadings; conference with B.M.; file correspondence and e-mails; review and organize pleadings; update pleading Indexes; open Deposition Duces Tecum files 04/08/2009 JMB Conference with Bernard Lebedeker; review additional research on the punitive damage issue 04/08/2009 JMB Final draft of punitive damage memo 04/08/2009 JMB Conference with Robed Critton 04/08/2009 MJP Drafting Motion to Interrogatories in BB and Motion to Compel Request to Produce 04/08/2009 MJP Drafting Motion to Interrogatories in EW and Motion to Compel Request to Produce 04/08/2009 MJP Meeting with R. Critton, Esq., regarding case and upcoming motions 04/08/2009 MJP Meeting with M. Burman regarding case and punitive damages 04/08/2009 BM Pull and copy Exhibits to attach to Motion to Compel Responses to RTP in LM; fax counsel; scan and pdf Motion to JG, JE and DI; pull and copy Exhibits to attach to Motion to Compel Answers to Interrogs and Motion to Compel Responses to RTP in EW; prepare letters for both Motions; fax letters and Motions counsel; scan and pdf letters and Motions to JG, JE and Dl; pull and copy Exhibits to attach to Motion to Compel Answers to Interrogs to BB; prepare letter to counsel; fax letter and Motions counsel; scan and pdf letters Motion to JG, JE and Dl; receipt of fax from Dr. Hearing on BB; receipt of e-mail from Southern District Clerk; print Order on Doe v. Epstein hearing; request check for Dr. Hearing records 04/09/2009 RDC Telephone conference with Hill re: AC and CMA; Affidavit; a-mails 04/09/2009 RDC Work on summary - pending and to do; conference re: Motion for Protective Order/consolidate depo 4/13 04/09/2009 RDC Motion for Protective Order/Quash re: Yellow Cab -BB 04/09/2009 RDC Read Gustaferro's e-mail 04109/2009 RDC Conference with JE 04/09/2009 RDC Conference with Jack Hill re: resolution Saige 04/09/2009 RDC Letter/memo to Marty re: Saige release 04/09/2009 RDC Receipt and review Order Specially Setting earing on June 26 - BB 3.00hr $1,500.00 1.50 hr $750.00 2.00 hr $590.00 0.60 hr $300.00 2.10 hr $262.50 0.20 hr $60.00 0.20 hr $60.00 1.50hr $450.00 6.00 hr $300.00 1.00 hr $500.00 0.40 hr $200.00 0.50 hr $250.00 1.50hr $450.00 1.50hr $450.00 0.201w $60.00 0.20 hr $60.00 5.60 hr $700.00 1.10hr $550.00 0.90 hr $450.00 0.50 hr $250.00 0.30 hr $150.00 1.30 hr $650.00 0.20 hr $100.00 0.10 hr $50.00 0.10 hr $0.00 Page 4 EFTA00602011 Matter ID: 2008.029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/09/2009 BM 04/09/2009 JMB 04/09/2009 RDC 04/09/2009 RDC 04/09/2009 Le 04109/2009 WP 04/09/2009 BM 04/10/2009 BM 04/10/2009 RDC 04/10/2009 RDC 04/10/2009 RDC 04/10/2009 RDC 04/10/2009 RDC 04/10/2009 RDC 04/10/2009 MJP 04/12/2009 04/12/2009 04/12/2009 04/13/2009 RDC RDC RDC BM 04/13/2009 MJP 04/13/2009 MJP Conference voith RDC; pull and copy e-mails, letters and settlement documents; conference with JMB; organize and re-file documents from JMB; pull and copy Exhibits to attach to Motion to Compel directed to RTP in BB; prepare letter to Kuvin re: Motion; file Motion with Clerk; fax counsel; scan and pdf Motion with attachments to JG, JE and DI; receipt of letter from Bethesda Memorial Hospital; call from and to Kuvin's office; receipt of Request for Copies from Kuvin: prepare Notice of Compliance with Request for Copies on BB Conference with RDC Letter from and to Spicer Review Marty's e-mail re: Saige and releases Review and update pleading files and indexes: search online for correct document numbers Confer regarding supplement to RICO Motion to Dismiss, review same Receipt of five e-malls from Southern District Clerk; print attachments; diary new deadline dates; receipt of records from Dr. Rothman; scan and pdf Settlement Agreement and General Releease; prepare e-mail to Weinberg with copies to JG, JE and DI; receipt of fax from Cheetah Palm Beach; update records from non-parties Chart; receipt of fax from Spicer; conference with RDC; give Lisa several files to open and pleadings to index Conference with MJP; pull RHBs Motion to Compel for MJP to review; prepare Notices of Filing in Support of Motions to Compel in Jane Doe, BB, LM and EW; pull and copy documents to attach as Exhibits; pull six Motions to Compel for MJP to review on Joe, BB, LM and EW; scan and pdf Amended Motions for Extension to Respond to Motion for Protective Order in Doe 2, 3. 4 and 7; file Amended Motions for Extension with Clerk of Southern District; receipt of four e-mails from Southern District Clerk; print attachments E-mails; memo re: articles; pull info from Interrogatories re: Response to Motions and review motions; conference with Pike re: how to respond Memo to JE re: pending; memo re: book/article; letter to Jack Hill Review letter and notice from Kuvin and response re: BB Letter to Stuart M. re: Subpoena and his Motions Review faxes from. re: Sanctions Motion; Proposal for Settlement from.. Receipt and review Plaintiffs Renotice of Hearing on April 20; Hill's April 9 letter, Notice of Filing Acceptance of Proposal; Butchers April 8 letter re: SR and CW not employee of Platinum Gold Drafting Motions for Extension of Time and reviewing Discovery Responses and Orders from Judge Lewis in preparation for filing a Notice of Supplement, confer with B. Mckenna Revise/add to objection re: Yellow Cab with case Revise letter to Stuart M re: depos and notices E-mails to JE; review proposal and letter re: proposal Receipt of four e-mails from Southern District Clerk; print attachments; scan and pdf Amended Motions to JG, JE and DI; documents from RDC for filing; notes to Lisa; send deadlines Chart to JG, JE and DI; confrence with MJP re: discovery; call to RHB re: Motions to Compel; pull prior discovery requests and Orders to compare with BB, LM and EW Motions to Compel; finalize Notices of Filing in Support of Motions to compel in BB, LM and EW, e-mails from Court Reporter; print attachments Review outstanding discovery, review Orders and rulings and revise Notices of Supplemental Authority Research case law and Jane Doe 2's Motion for Protective Order and Motion to 2.80hr $350.00 0.40 hr $200.00 0.20 hr $100.00 0.10hr $50.00 4.50 hr $225.00 0.30 hr $90.00 2.10 hr $262.50 3.20 hr $400.00 1.60 hr $800.00 1.20 hr $600.00 0.20 hr 5100.00 0.30 hr $150.00 0.50hr $250.00 0.50 hr $250.00 1.00 hr $300.00 0.30 hr $150.00 0.30 hr $150.00 0.80 hr $400.00 3.25 hr $406.25 0.60 hr $180.00 0.80 hr $240.00 Page 5 EFTA00602012 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: ash 04/13/2009 MJP Research case law and Jane Doe rs Motion for Protective Order and Motion to Quash 04/131'2009 MJP Research case law and Jane Doe 4's Motion for Protective Order and Motion to Quash 04/13/2009 MJP Research case law and Jane Doe Ts Motion for Protective Order and Motion to Quash 04/1312009 MJP Review and update case law in preparation for Motion to Dismiss in B.B. and draft Notice of supplemental authority 04/13/2009 ASB Legal research case law 04/13/2009 BM Fax BB Notice of Filing to counsel; fax LM and EW Notice of Filing to counsel; file originals with Cleric; call from RHB; scan and pdf BB, LM and EW Notices; e-mail Notices to JG, JE and DI; receipt of records/notes from Platinum Showgirls, Solid Gold, Vegas Cabaret and Pure Platinum: receipt 2 e-mails from Clerk on Doe #2; e-mail from Clerk on CMA; scan and pdf CMA Notice re: Mediator to JG, JE and DI; receipt of Order on Motion for Extension; forward e-mails from Clerk to JG, JE and Di; scan and pdf Motion to Strike References to Non-Prosecution Agreement in Doe to JO, JE and DI; scan and pdf Plaintiffs Response in Opposition to Motion to Stay to JG, JE and Di 04/13/2009 RDC Telephone conference from HI re: Buckstein - ok 04/13/2009 RDC Letter to Sid re: discovery 04/13/2009 RDC E-mail to Joe G. answering his questions 04/13/2009 RDC Review Marty's comments re: Motion to Quash set for next week 04/13/2009 RDC E-mail re: depo and Kuvin 04/13/2009 RDC Letters (x10) re: preserving data, facebook, etc. 04/13/2009 RDC Telephone conference with Jack 0: conference with Pike re: Response to Motion to Consolidate and Protective Order 04/13/2009 EM Receipt of six e-mails from Southem District Clerk in #2 through 7; print attachments; scan and pdf six Unopposed Motions for Enlargement of Time to file Memorandum in Opposition to Motions to Stay in #2 through 7 to JG, JE and DI; diary new dates for Doe #2, 3, 4 & 7 deadline; forward a-malls from Clerk to JG, JE and Dl; note to Lisa; copy Endorsed Order for cases #2, 3, 4 & 7 to index 04/13/2009 RDC Receipt and review on BB- Kuvin's April 10 letters (3) on Epsteln's deposition is going, re: Motion to Compel Answers to Interrogatories and Request to Produce; 4th Re-Notice of Epstein's depo; on EW and LM - Order on Motion to Transfer, Spicer's April 9 letter re: bring him to speed on cases; Doe II - Clerk's Notice of Reassignment 04/13/2009 RDC Receipt and review Doe ll's offer of settlement 04/13/2009 MJP Review and analysis of Jane Doe's Response in Opposition to Motion to Slay 04/14/2009 RDC E-mails; review motions/responses re: Pacer on #2-7; Response to Stay 04/14/2009 RDC Conference with Pike re: Response to JD 2-7 Motion to Compel 04/14/2009 ROC Conference with Rita re: Response to Quash in S.R. 0441412009 RDC E-mail re: status to Jack, 08 and JE re: depos of JE 04/14/2009 RDC Telephone call from Brad Edwards; extensions on LM and SR; letter re: extension 04/14/2009 RDC Telephone call from Sandy; Motion for Substitution of Counsel in. 04/14/2009 RDC Exchange e-mails with Story re: billing 04/14/2009 RDC Revise letter (x10) for Josephsberg re: electronic data 04/14/2009 RDC E-mails re: Stip in CMA 0.80 hr $240.00 0.80 hr $240.00 0.80 hr $240.00 1.10hr $330.00 0.10 hr $12.50 4.20 hr $525.00 0.10 hr $50.00 0.20 hr $100.00 0.40 hr $200.00 0.30 hr $150.00 0.20 hr $100.00 0.60 hr $300.00 0.50 hr $250.00 1.30 hr $162.50 0.30 hr $150.00 0.10 hr $0.00 0.30 hr $90.00 0.30hr $150.00 0.20 hr $100.00 0.10 hr $50.00 0.30 hr $150.00 0.30hr $150.00 0.10 hr $50.00 0.20 hr $100.00 0.30hr $150.00 0.10hr $50.00 Page 6 EFTA00602013 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/14/2009 RDC 04/142009 BM 04/14/2009 BM 04/14/2009 RDC 04/14/2009 LG 04/1412009 MJP 04/14/2009 MJP 04/14/2009 MJP 04/14/2009 MJP 04/15/2009 MJP 04/15/2009 BM 04/15/2009 MJP 04/15/2009 RDC 04/15/2009 RDC 04/15/2009 RDC 04/15/2009 RDC Telephone call from Caddy re: AC Receipt of Plaintiffs Memorandum in Response to Motion to Dismiss Amended Complaint in CMA; scan and pdf Memorandum to JG, JE and DI: copies for RDC and RHB: diary reply deadline; receipt of second e-mail from Clerk on CMA Notice of Filing Correction to Memorandum; scan and pdf to JG, JE and DI; call to Spicer's office to obtain information; prepare two Stipulations for Substitution of Counsel and Order Approving in Doe II State and Federal cases E-mail Stipulation for Substitution to Sandy at Spicer's office with copies to JG and JE; pull Doe #2, 3, 4 and 7; make list of Counts from Complaints for MJP; go through records received from non-parties and update chart; review returns of service to obtain names of parties served; begin calling non-parties served to obtain additional records; e-mails from Sandy; update depo chart; several e-mails from Lesley at Darren's office; forward nine e-mails to Lesley with all attachments: pull AC and Doe #1 files and box up; open several deposition files; re-organize and file folders from WP; print Spicer's signature on Stipulation; e-mail from Clerk on Endorsed Orders on Does #2 through 7; scan and pdf Orders; send to JO, JE and DI; diary all deadline dates Telephone conference and e-mail re: Ezell (Skye) Open files regarding Josefsberg cases and expert witnesses; confer with B.M. regarding status of file maintenance; update pleadings indexes and file pleadings; open depositoin files for records; file correspondence and e-malls Drafting Response In Opposition to Motion for Protective Order and Motion to Consolidate Cases and Limit Depositions, research and analysis of case law regarding same Jane Doe 2 Drafting Response in Opposition to Motion for Protective Order and Motion to Consolidate Cases and Limit Depositions, research and analysis of case law regarding same Jane Doe 3 Drafting Response in Opposition to Motion for Protective Order and Motion to Consolidate Cases and Limit Depositions, research and analysis of case law regarding same Jane Doe 4 Drafting Response in Opposition to Motion for Protective Order and Motion to Consolidate Cases and Limit Depositions, research and analysis of case law regarding same Jane Doe 7 Draft Supplemental Motion to Compel in Jane Doe, finalize same, confer with R. Critton, Esq. Conference with RDC re: subpoenas and records received; go over chart w/ RDC; receipt of records from Dr. Schiller on BB; send check to Dr. Hearing for records on BB; request checks from bookkeeping for hearing transcripts; send draft Reply to Plaintiffs Response to Motion to Quash on EW to JG, Weinberg and Spicer; scan and pdf Amended Cmplalnt on BB to JG. JE and DI; e-mail chart of records received on BB to Kuvin; call to Brad Edwards' office to obtain new e-mail address; e-mail charts of records received on Doe, EW and LM to Brad; copy e-mails for hearing folder-, copy letters from Kuvin on BB for Spicer, copy records chart for Spicer; update deadline dates on CMA and Doe; pull and copy Batas case, Orders and transcript to attach as Exhibits to Supplemental Motion to Compel on Doe: file Motion and Exhibits electronically with Clerk Revise Response to Motion to Protective Order in Jane Doe 2 Revise Response re: dopos and consolidation in 4 cases of State Many e-mails to all re: hearing and Amended Complaint: telephone conference with Kuvin re: BB Telephone conference with Kuvin re: BB; review Amended Complaint and proposed Order in BB E-mails to and from Kuvin re: Saige and $ and hearing 0.10hr $50.00 1.40 hr $175.00 4.75 hr $593.75 0.10hr $50.00 5.00 hr $250.00 1.70hr $510.00 1.70 hr $510.00 1.70 hr $510.00 1.70hr $510.00 0.80hr $180.00 4.25 hr $531.25 0.30 hr $90.00 0.80 hr $400.00 0.40hr $200.00 0.40hr $200.00 0.20 hr $100.00 Page 7 EFTA00602014 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/15/2009 RDC Telephone conference from Brad in LM, EW and SR re: depos on Friday; conference with Bobbie re: depos on Friday - on off - and records 0.60 hr $300.00 04/15/2009 RDC E-mail and response re: release with AC 0.20hr $100.00 04/15/2009 RDC E-mails from and responses to Ezell 0.20 hr $100.00 04/15/2009 RDC Telephone call from Spencer re: Saige Issues and Spicer 0.10 hr $50.00 04/15/2009 RDC Telephone call from Spicer 0.50 hr $250.00 04/15/2009 RDC E-mails from and telephone conference with Kuvin re: Saige 0.20 hr $100.00 04/15/2009 BM Receipt of e-mail from Clerk's office; print attachments: scan and pdf 0.75 hr $93.75 Supplemental Motion to Compel with Exhibits and send to JG, JE and DI; note to Lisa; documents from RDC to file; conference with RHB on EW; e-mail from Lesley at DI's office; pull and copy Order on LM; scan and pdf Order to Lesley; e-mail to Lesley 04/15/2009 RHB EW - review e-mail correspondence regarding reply in support of Motion to Quash 0.40 hr $120.00 04/15/2009 RHB Legal research regarding case law in Plaintiffs Response to Motion to Quash 1.10hr $330.00 04/15/2009 RHB EW - Review Amended Complaint regarding criminal allegations 0.50 hr $150.00 04/15/2009 RHB EW - Draft Reply to Response to Motion to Quash 2.30 hr $690.00 04/152009 BM Receipt of e-mails from Clerk's office; print attachments; scan and pdf Opposition to Motion to Compel re: Tax Records on Doe; scan and pdf Opposition to Motion to Compel Response to Interrogatories; send to JG, JE and DI; diary new deadlines for Doe replies and response 0.40 hr $50.00 04/15/2009 BM Receipt of fax from Pure Platinum with attachment; e-mail reply to Pure Platinum 0.20 hr $25.00 04/15/2009 MJP Draft Motions for Extension of Time in JD1, 2, 4 and 7 0.20 re $60.00 04/16/2009 RDC Review e-mails 0.10hr $50.00 04/16/2009 RDC E-mail from, to Darren re: BB 0.20hr $100.00 04/16/2009 RDC Review Marty's memo on CMA reply; e-mail re: who to reply 0.30 hr $150.00 04/16/2009 RDC Revision to Rita's reply to EWs Motion to Quash; add Garrison material; conference with Rita 0.60 hr $300.00 04/16/2009 RDC Prepare "to do" for Spicer 0.50 hr $250.00 04/16/2009 RDC Telephone call from Caddy re: videos 0.10 hr $50.00 04/16/2009 RDC Conference with JE re: # of issues 0.40 hr $200.00 04/16/2009 RDC Telephone call from PB County Atty, Leo St. James 0.30 hr $150.00 04/16/2009 RDC Conference with Bobbie re: depos for Friday and e-malls 0.40 hr $200.00 04/16/2009 RDC Receipt and review BB - Kuvin's letter to Judge Hafele re: Agreed Order 0.10hr $0.00 04/16/2009 RDC Receipt and review on Doe II - Order on Motion for Protective Order 0.10 hr $50.00 04/16/2009 RI-IB Conference(s) with RDC re: outstanding matters; (E.W.) reply to Response to 0.20hr $60.00 Motion to Quash 04/16/2009 RHB Prepare enclousres; case law for E.W. Hearing (to Judge)(April 24 hearing) 0.20 hr $60.00 04/16/2009 RI-1B Finalize and Incorporate exhibits; reply to E.W.'s Response to Motion to Quash 0.60 hr $180.00 04/16/2009 RHB Review CMA re: Response to Motion to Dismiss 0.50 hr $150.00 04/16/2009 RHB Review e-mail correspondence from M.W. on CMA re: Response to Motion to 0.20 hr $60.00 Dismiss 04/16/2009 BM Cali to Ts Lounge and The Body Shop re: EW; calls from and to IHOP and Flash 4.25hr $531.25 Dance re: Doe; call to court reporter to cancel depositions; e-mail and call to Brad Edwards to cancel depositions; receipt of records from School Board on EW, LM Doe and BB; intemet search for phone number of Dr. Randee Spectate; call to Page 8 EFTA00602015 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/17/2009 MJP 04/17/2009 RDC 04/17/2009 RDC 04/17/2009 RDC 04/17/2009 RDC 04/17/2009 BM 04/17/2009 LG 04/17/2009 04/17/2009 04/17/2009 04/17/2009 04/17/2009 04/17/2009 04/17/2009 MJP MJP MJP MJP MJP MJP MJP 04/17/2009 BM 04/19/2009 RDC 04/20/2009 RDC 04/20/2009 RDC 04/20/2009 RDC 04/20/2009 RDC Sexual Assault Department at Courthouse re: Randee Special° records for Doe and EW; call from records custodian for Sexual Assault Department; update records chart scan and pdf Amended Motions for Extension to file response to Motions for Protective Order In #2, 3, 4 and 7; file electronically with Clerk; receipt of 4 e-mails from Clerk; print attachments; scan and pdf docketed Motion for Extension to JG, JE and Di; call to Spencer to cancel depos; e-mail confirmations of cancellation of depos from Court Reporters; put updated deadlines for responses on tasks for #2, 3, 4 and 7 Confer with ROC and J. Hill regarding Motion for Extension of Time in CMA Review motions for Monday hearings in BB Read CMA response to our Motion to Dismiss along with Martys comments; notes for Rita E-mails and letter from Kuvin re: discovery Prepare for and office conference with Spicer, Darren, etc. Print three charts for Spicer; copy several documents for Spicer; pull Answers to Interrogatories on #2, 3, 4, 5, 6 and 7 for MJP to review; copy Doe #3 Answers to Redact and attach as exhibit to Responses; scan and pdf Response to Plaintiffs Motions for Protective Order with attachments in Doe #2, 3, 4 and 7; file Responses electronically with Clerk; diary reply dates on tasks; e-mails from Cleric; print attached Responses with docketed information; scan and pdf Responses and e-mail to JG, JE and Dl; prepare Motion for Extension to reply to Plaintiffs Response to Defendant's Motion to Dismiss in CMA; scan and pdf; file electronically with Clerk; e-mail from Clerk; print attached docketed Motion; scan and pdf Motion for Extension and e-mail to JG, JE and DI; conference with RDC re: videos on AC; receipt of documents from Dr. Specials on EW; receipt of DBD Management on EW; receipt of four Orders from Clerk; note to Lisa re: Orders Open files for Deposition Duces Tecum records; organize pleadings; check County and Federal Courthouse records for correct document numbers; update pleading indexes and file pleadings Revise Response in Opposition to Jane Doe 2 Revise Response In Opposition to Jane Doe 4 Revise Response in Opposition Jane Doe 4 Revise Response in Opposition Jane Doe 7 Revise Motion for Extension of Time and confer with J. Telephone conference with S. Merrnelstein and S. Kuvin, Esq. Review Discovery Responses in Jane Doe numbers 2-7 to determine witnesses that are Plaintiffs in other Diary CMA's reply date on tasks; e-mails from Clerk's office on # 2 through 7; print Motions for Extension to filo Oppositions to Motions to Compel in Doe #2 through 7; scan and pdf Motions for Extension; e-mail to JG, JE and DI; diary new dates for responses from Plaintiffs; e-mail Clerk on Doe; print attachment; scan and pdf First Amended Complaint with attachment on Doe; e-mail to JG, JE and Di; dairy new date for Answer to First Amended Complaint on tasks; organize and re-file discovery from MJP on #2 through 7; conference with RDC; e-mails to Sandy with attachments Prepare for hearing on LM and EW transfer Prepare for hearing re: BB on Yellow Cab Hearing on BB - Yellow Cab Hearing on Transfer -LM Conference with Jack G, JMB, and Pike re: status and staying in 0.10 hr $30.00 0.20 hr $100.00 1.20 hr $600.00 0.20 hr $100.00 4.30 hr $2.150.00 4.25 hr $531.25 5.50 hr $275.00 0.20 hr $60.00 0.20M $60.00 0.20 hr $60.00 0.20 hr $60.00 0.201w $60.00 0.20 hr $60.00 0.30 hr $90.00 2.60 hr $325.00 0.20 hr $100.00 0.30 hr $150.00 1.00 hr $500.00 0.60 hr $300.00 1.50 hr $750.00 Page 9 EFTA00602016 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/20/2009 RDC Conference with JE 1.00hr $500.00 04/20/2009 RDC Receipt and review Josefsberg's April 17 letter to have no contact with his clients; another April 17 letter regarding acceptance of Summons and Complaint; 0.30 hr $150.00 Summons and Complaint on Doe 101 v. Epstein 04/20/2009 RHB Review e-mail correspondence from M. Weinberg re: CMA reply to Motion to 0.10 hr $30.00 Dismiss 04/20/2009 RHB Review case law referenced In M. Weinberg e-mail, rule of levity 0.40 hr $120.00 04/20/2009 RHB Begin preparation for reply to CMA's Response to Defendant's Motion to Dismiss; re-review Motion and Response and outline 1.20 hr $380.00 04/202009 RHB Legal research re: application of 2003 version of Statute, constitutional arguments 1.30 hr $390.00 "expost facto" 04/20/2009 BM Receipt of records from Dr. Lisa Hearing on BB; receipt of records from IHOP on 0.80 hr $75.00 Doe; call to Judge Hafele's JA to cancel hearing; call from JA; organize and re-file hearing folders from RDC; update records from non-parties chart 04/20/2009 LG Organize e-mails, correspondence and pleadings; file same; upated pleadings 4.50hr $225.00 Indexes and files 04202009 MJP Meeting with JMB and R. Critton, Esq. 0.30 hr $90.00 04/20/2009 JMB Multiple conferences with Robed Critton regarding case status, continuation, utilization of personnel; divisions of effort, etc. 1.30 hr $650.00 04/21/2009 BM Receipt of seven e-mails from Clerk; print Order Granting Defendant's Extension to Reply to Plaintiffs Response to Motion to Dismiss on CMA; print Order granting 0.70hr $87.50 Defendant's Extension to Respond to Motion for Protective Order; diary duo dates in Doe 3; print Reply Memos supporting Motions to Compel discovery in Doe 2, 3, 4 and 5; print Plaintiffs Response to Motion to Compel CMA to respond to discovery; conference with MJP; note to RDC 04/21/2009 RDC Receipt and review BB - Order on Amended Objection to Yellow Cab; BB - Agreed 0.30hr $0.00 Order Granting Defendant's Motion to Dismiss; Doe v. State - Order on Motion to Transfer 04/21/2009 JMB Conference with client 0.80hr $400.00 04/21/2009 BM Conference with MJP; call to Brad Edwards; e-mail to Brad Edwards re: our reply to Plaintiff's Response in Opposition to Motion to Stay 0.25hr $31.25 04/21/2009 RHB CMA legal research; review legislative history, house reports on 18 USC Statute 1.40hr $420.00 2255 (ex post facto, retroactive argument) 04/21/2009 RHB Legal research re: case law prohibition against retroactivity, ex post facto clause, new 2255 case, CMA 1.60hr $480.00 04/21/2009 BM E-mail from Lesley at DI's office; re-send attachment to Lesley 0.20hr $25.00 04/21/2009 BM Organize and separate records received from non-parties; pull and copy 0.60hr $75.00 Subpoena on BB to Dr. Toufamian to add note from office; revise Notice of Compliance on BB; call to KuvIn's office re: copies; call and left message with Copy Service 04/21/2009 JMB Update case status with Rita Budnyk and Mike Pike; prepare for client meeting 0.80hr $400.00 04/21/2009 JMB Review research regarding disclosure of victim names for subpoenas, etc.; conference with Mike Pike 0.40hr $200.00 04/22/2009 RDC Review e-mails; conference with Rita re: CMA reply 0.50 hr $250.00 0422/2009 RDC Conference with JMB; review e-malls and discussion re: ill #2 0.30 hr $150.00 04/22/2009 RDC Conference re: JD 101 0.20hr $100.00 04/22/2009 RDC Telephone conference with Jessica 0.40 hr $200.00 04/22/2009 RDC Telephone call from Spencer and Blanton; e-mails re: Saige 0.20 hr $100.00 0422/2009 RDC Telephone conference with Spencer; letter and Motion for Protective Order 0.80 hr $400.00 Page 10 EFTA00602017 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/22/2009 RDC Telephone conference with Brad Edwards; letter to Brad with documents re: LM 04/22/2009 RDC E-mails and review Motion re: Amicus 04/22/2009 RDC Receipt and review BB - Amended Complaint ; CMA - Hill's April 20 letter re: name of AL 04/22/2009 JMB Conference with Robert Clifton regarding case status and staffing 04/22/2009 JMB Telephone conference with Jack Goldberger 04/22/2009 JMB Conference with paralegal and Michael Pike regarding additional information request for review ASAP 04/22/2009 JMB Conference with paralegal regarding Internet research and retrieval of victim record 04/22/2009 BM Conference with RDC: schedule conference; call from Palm Beach Copy Service; receipt of records from copy service; prepare letter lo Kuvin with enclosures; request check from bookeeping; copy Doe 101 complaint for RDC and RHB; copy Podhurst for RDC, JMB and RHB; conference with JMB; pull and copy Doe II (Federal) complaint for RHB and RDC; update tasks; scan and pdf Podhurst letters and new complaint to JG, JE and DI; schedule conference with team; scan and pdf letter to Kuvin and Notice on BB to JO, JE and Di 04/22/2009 ASB Office conference with Attorney Burman regarding victums and Interrogatories for upcoming depositions; Internet research with Attorney Burman regarding Facebook 04/22/2009 BM E-mail to Edwards; call to Edwards; prepare Motion for Extension to Reply to Plaintiffs Response to Motion to Stay; conference with MJP re: extension; e-mail from Edwards; revise Motion for Extension; scan and pdf Motion; file Motion electronically with Clerk; receipt of e-mail from Clerk; print Motion with docketed information: scan and pdf Motion to JO, JE and DI 04/22/2009 LG Open files re: new possible plaintiffs; open files for new plaintiff; organize pleadings; file same; check on line for correct County and Federal document numbers; update pleadings indexes; conference with B.M. 04/22/2009 RHB Draft CMA reply 2003 version of Statute 2255 application; legal argument 04/22/2009 RHB Review House bills/reports and history on 18 USC Statute 2255; legal research 04/22/2009 RHB Incorporate into Reply to CMA Response 04/22/2009 Rip Research and analysis of case law, the sexual assault/shield statutes, and case law regarding identification of alleged Jane Doe victims in court proceedings and documents 04/22/2009 BM Send payments to U.S. Legal for hearing transcripts 04/22/2009 BM Receipt of e-mail from Clerk on CMA; print attachments; conference with RDC; copy Motion to file Brief for JMB, ROC, MJP and RHB; change time of team meeting on RDC and JMB diaries 04/23/2009 RDC Receipt and review SpIcer's April 21 letter ; A.C. - Hill's letter to Judge Garrison regarding settlement; AC - Notice of Cancellation of Hearing 04/23/2009 JMB Review all recent e-mails and pleadings regarding case status 04/23/2009 RDC E-mails re: Amicus 04/23/2009 RDC Conference re: Motion to I.D. and get records 04/23/2009 MJP Research and analysis of case law regarding constitutional kmltations on proceedings anonymously for Jane Doe 2-7 04/24/2009 BM Team meeting: calls to and from Goldberger; instructions to runner; copy several documents for JMB, RHB and MJP; conference with Ashile; receipt of check from Goldberger's office; begin working on subpoenas; pull Caddy file for MJP; update tasks list; diary meetings every Friday; review of copies of records from Palm Beach Copy Service; prepare letter to DI; prepare Fed Ex package to DI; deliver package to Fed Ex box 0.80 hr $300.00 0.20 hr $100.00 0.20 hr $100.00 0.80 hr $300.00 0.10 hr $50.00 0.30 hr 5150.00 0.80 hr $300.00 1.80 hr $225.00 0.20 hr $25.00 2.10hr $262.50 4.50 hr $225.00 1.20 hr $360.00 1.50hr $450.00 0.60hr $180.00 3.10 hr $930.00 0.10hr $1250 0.25hr $31.25 0.30hr $150.00 0.70 hr $350.00 0.30 hr $150.00 0.10hr $50.00 4.30 hr $1,290.00 3.70 hr $462.50 Page 11 EFTA00602018 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/24/2009 ASB Office conference with Attorney Burman; draft e-mail to parties 04/24/2009 BM Call to Jack re: SG money; conference with RUC; e-mail to Jack; receipt of e-mail from Clerk on Motion for Extension on Doe; print attachment; diary new deadline date on tasks; receipt of six e-mails from clerk on #2 through 7; print attachments of Responses to our Motions to Stay; copy for MJP; scan and pdf Responses to JG, JE and DI; go over tasks with MJP; update tasks; copy for JMB, RDC, MJP and RI-IB; e-mall to RHB re: team meeting tomorrow; print RDC calendar for May through July 04/24/2009 JMB Conference with litigation team regarding pleadings, discovery and status of all cases, etc. 04/24/2009 JMB Conference with Ashlie Stoicen-Baring regarding Internet Face Book, My Page, etc., regarding research on victims 04/24/2009 RDC Review and respond to e-mails 04/24/2009 RDC Prepare for and conference with team re: Motions/discovery; depos; Caddy, etc. 04/24/2009 RHB Conference with RDC, JMB, paralegal, MJP (portion) re: strategy, pending matters; issues (in all cases) 04/24/2009 RHB Review Jane Doe 101 Motion to File Omicus brief 04/24/2009 RHB Review Jane Doe 101 Complaint in Federal Court 04/24/2009 RHB Draft e-mail correspondence to RDC re: thoughts on Jane Doe 101 Amicus Brief 04/24/2009 RI-IB Review BB Complaint 04/24/2009 RHB Jane Doe 101 e-mail memo to JMB re: possible Rule 11 sanctions/allegations 04/24/2009 RHB Memo to JMB re: NPA agreement, key provision 04/24/2009 RHB Legal research re: ex post facto clause re: criminal v civil proceeding; Mendoza and progeny CMA 04/24/2009 BM Receipt of e-mail from Clerk; print attachment; scan and pdf Plaintiffs Response to Defendants Motion to Slay to JG, JE and DI; scan and pdf letter from State Attorney to JG, JE and DI re: EW and Doe; copies of Response to MJP and RHB; note to RDC 04/25/2009 RHB Review and respond to e-mail correspondence re: CMA response issues Statue 2255 04/25/2009 RHB Legal research and draft reply to CMA response re: Statute 2255 retroactivity, issues, civil v. criminal analysis 04/27/2009 BM Receipt of six e-mails from Clerk; print attachments; update tasks with deadlines on orders; conference with Lisa re: subpoenas; receipt of seven additional e-mails from Clerk; print attachments; call to Brad Edwards' office re: extensions; e-mail Brad Edwards; conference with RHB; calls to Jack Hill re: Motion to File Excess Pages in CMA; scan and pdf Unopposed Motion; file electronically with Clerk; call to St. Mary's Medical Center for records on Doe and EW; call to JFK Medical Center for records on EW; call to CARP re: EW records; receipt of fax from CARP; call to Flash Dance re: Doe records; receipt of records from Sally's Beauty School on EW; scan and pdf several documents on several cases to JG, JE and DI 04/27/2009 RDC Receipt and review BB - Notice of Deposition to Yellow Cab; EW - Request for Copies; Doe (State) - Notice of Hearing on 4/30 and Motion to Enforce Settlement 04/27/2009 ASB Draft e-mails to parties regarding meeting 04/27/2009 JMB Conference with Robert Critton regarding status and staffing; conference with Gustaferro regarding mock trial and focus groups 04/27/2009 BM Call from Brad Edwards' office re: extensions; conference with MJP; prepare two Motions for Extension to file Replies In Doe; scan and pdf Motion to JG, JE and DI; e-mail from Lesley; scan and pdf Acceptance of Proposal in AC; e-mail to Lesley; scan and pdf two Motions for Extension; file electronically with Clerk; e-mails from Clerk; print docketed information; conference with JMB on inventory 0.30 hr $37.50 2.75 hr $343.75 2.50hr $1,250.00 0.40 hr $200.00 0.60 hr $300.00 3.10hr $1,550.00 2.00 hr $600.00 0.20 hr $60.00 0.40hr $120.00 0.20 hr $60.00 0.30 hr $90.00 0.10hr $30.00 0.20 hr $60.00 0.80 hr $240.00 0.50hr $62.50 0.40 hr $120.00 2.60 hr $780.00 4.60 hr $575.00 0.40 hr 5200.00 0.10hr $12.50 0.80 hr $400.00 3.20 hr $400.00 Page 12 EFTA00602019 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: of items seized; pull and copy documents for JMB; receipt of fax from Brad Edwards re: extensions; draft letter to ssend to Josefsberg for RDC to review 04/27/2009 RDC E-mails; conference with Pike, JMB and Rita 1.10hr $550.00 04/27/2009 LG File subpoenaed records received; organize pleadings, e-mails and correspondence; updated pleadings indexes; search court records in on the for correct document numbers 5.00 hr $250.00 04272009 RHB CMA; draft Motion to Exceed Page Limitation for Reply to CMA Response 0.30hr $90.00 04/27/2009 RHB CMA; legal research re: Mendoza/Ward analysis; Landgraf analysis against retroactivity 2.10hr $830.00 04/27/2009 RHB Continue draft of reply to CMA Response to Motion to Dismiss re: constitutional arguments against retroactivity; applicable version of 2255 1.90hr $570.00 04/27/2009 MJP Finalize research and draft Motion to Identify Jane Doe in CMA, to be converted to 7.20 hr $2,160.00 Jane Does 2-7 as well and time spilt evenly 04/28/2009 ASB Begin Internet research on Facebook regarding all Plaintiffs 3.00 hr $375.00 04/28/2009 JMB Conference with Joe Gustaferro and Robert Critton (part of conf.) 0.90 hr $450.00 04/28/2009 MJP Research regarding consent as a defense 0.80 hr $240.00 04/28/2009 JMB Gustaferro issues/Mock Trial; review Jane Doe 101 Complaint and analysis; prepare for J.E. deposition 3.50 hr $1,750.00 04/28/2009 RI-IB Review Jane Doe II federal case 0.20 hr $60.00 04/28f2009 RHB Jane Doe II - legal research splitting causes of action; actions pending in state and federal courts; subj. matter, jurisdiction, exclusive or concurrent 2.10hr $630.00 04/28/2009 RHB Draft e-mail memo to RDC & JMB on Jane Doe II issues - jurisdiction, splitting c/a 0.25 hr $75.00 04/28/2009 RHB Draft letter and Motion to Mermelstein/Horowitz - case style, Rule 10(a) 0.40 hr $120.00 04/28/2009 RHB Continue drafts of Reply to CMA Response, Non-Constitutional Arguments, multiple violations 0.50 hr $150.00 04/28/2009 LG Review e-mails; open files for subpoenaed records; update pleadings indexes: file pleadings; file correspondence and e-mails; review Answers to Interrogatories to 5.00 hr $250.00 Subpoena Employment and Medical Records 04/28/2009 RDC Letter re: B.B. 0.20 hr $100.00 04/28/2009 RDC Telephone conference with Reeder; documents for him to review 0.20 hr $100.00 04/28/2009 RDC Telephone conference with Jack re: JD 101 020 hr $100.00 04/28/2009 RDC Finalize AC and Saige settlements; conference with Spencer 0.40 hr $200.00 04/28/2009 RDC Revise CMA Motion re: Anon and subpoena 0.90 hr $450.00 04/28/2009 RDC Conference with Joe Gustaferro 2.10 hr $1,050.00 04/28/2009 RDC Telephone call from Jack G. 0.10 hr $50.00 04/28/2009 RDC Review consent issue 0.30hr $150.00 04/28/2009 RDC To do 1.40 hr $700.00 04/28/2009 RDC Review Statute of Limitations issues 0.50 hr $250.00 04/28/2009 BM Receipt of e-mails from Clerk on Doe 3; print attachments: pull all EW records received from providers in response to Subponeas; call to Edwards office re: 4.80 hr $575.00 copying records; update EW chart; conference with Ashlie re: photographs; conference with Lisa re: povider records; finalize letter to Mamie!stein; finalize Motion to separate Does 2 through 7 as not consolidated: fax letter and motion to Mermelstein: go through task list with MJP; conference with JMB; pull and copy several documents for JMB; pull letters from RDC stacks to copy for EW case; prepare letter to Josefsberg; put copies of ROCs notes, etc. in Joe G file; pull CMA and BB pleadings; scan and pdf docuemnts to Martin Reeder, conference with RDC re: depos in Garcia case and Edwards cases; call to Edwards office re: Page 13 EFTA00602020 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: extensions, letter and depos; pull statutes book for RDC; copy statutes; print list of research files for RDC to review, prepare Notice of Compliance in EW case; call to Copy Service with instructions 04/28/2009 MJP Meeting with R. Grillo!), Esq. 0.30 hr $90.00 04/28/2009 MJP Research regarding Motion to Strike in Jane Doe 1.00 hr $300.00 04/28/2009 MJP Research and revising Motion to Identify and Motion to Dismiss S. Sponte, review 5.70 hr $1,710.00 Responses to Interrogatories, meeting regarding same, and confer with R. Budnyk 04/29/2009 JMB Conference with client, etc. 2.80 hr $1,400.00 04/29/2009 MJp Meeting with RDC and JMB regarding consent and damages, research regarding same 1.00 hr $300.00 04/29/2009 MJP Finalize Motion to Identify, review court's Orders on Consolidation, drafting Reply to Opposition to Motion to Compel Records in C.M.A., research and drafting 7.30 hr $2,190.00 Response to Motion to Strike in Jane Doe 04/29/2009 ASB Continue internet research on Facebook and Myspace regarding all Plaintiff's: 5.50 hr $687.50 Mock Trial preparation with Attorney Burman 04/29/2009 RHB Telephone call from RDC regarding Jane Doe No. 101, Jane Doe II (fed) 0.10 hr $30.00 04/29/2009 RDC Revise letters re: JD 101 0.10 hr $50.00 04/29/2009 RDC Letter re: various issues 0.20 hr $100.00 04/29/2009 RDC Letter to Sid re: Depo of JE 0.20 hr $100.00 04/292009 RDC Prepare for conference with JElto do 1.50 hr $750.00 04/29/2009 RDC Letter to Stuart JD 2-7 re: mediators 0.10 hr $50.00 04/29/2009 RDC E-malls and letters to Ritson re: EW 0.20 hr $100.00 04/29/2009 RDC Review Responses to Stay in CMA 0.10 hr $50.00 04/29/2009 RDC Review Responses to Stay - JD 2-7 0.30 hr $150.00 04/29/2009 RDC Review Responses to Slay S.R. 0.50 hr $250.00 04/29/2009 RDC Revise Template on Motion to I.D. in CMA and JD 2-7 0.60 hr $300.00 04/29/2009 RDC Receipt and review Ezell's April 28th letter regarding [REDACTED]; Doe - Federal - 0.20 hr $100.00 Request for Copies 04/29/2009 RDC Telephone conference with Martin re: his memo 0.10 hr $50.00 04/29/2009 RDC Review Amicus e-mails re: 101 0.60 hr $300.00 04/29/2009 RDC Telephone conference with Ezell; e-mails Jay Lefoko re: Bob J., eta 0.80 hr $300.00 04/29/2009 RDC Read Complaint 101 0.40 hr $200.00 04/29/2009 RDC Read Complaint BB 0.20 hr $100.00 04/29/2009 RDC Read Complaint"' - 2 re: CMA's reply; read Hill's response 0.30 hr $150.00 04/29/2009 RDC Prepare for conference with JE; conference with JMB • 1.70 hr $850.00 04/29/2009 RDC Conference with JE, JMB, RDC, Jack 2.50 hr $1,250.00 04/29/2009 RDC Telephone call from Kuvin, re: Yellow Cab - BB 0.10 hr $50.00 04/30/2009 ASB Office conference with Attorney Burman regarding Plaintiffs; continue research on 0.75hr $93.75 Myspace regarding Plaintiffs 04/30/2009 JMB Depo of client in E.W. "1"1".); conference with client and Goldberger 5.30 hr $2,850.00 04/30/2009 JMB Telephone conference with Gustafero; conference with ASB, RDC, etc. regarding depos, staffing, Motion to Disclose Identity and for Protective Order and Mock Trial 1.80 hr $900.00 Issues 04/30/2009 MJP Meeting with R. Budnyk regarding legal Issues, expost facto, NPA and strategy 0.80 hr $240.00 Page 14 EFTA00602021 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services Rendered: 04/3012009 MJP Drafting and research in connection with Reply to CMA's Opposition Motion to Motion to Compel Discovery, review exhibits and file same 04/30/2009 MJP Continue research regarding consent In civil and criminal cases 04/30/2009 RHB Review multiple e-mail correspondece from defendant's counsel Stat. 2255 issues, constitutional issues 04/30/2009 RHB Legal research concurrent jurisdiction. comity, Jane Doe II, state/federal actions, Colorado River abstention 04/30/2009 RHB Draft Motion to Dismiss Jane Doe II (federal) 04/30/2009 RDC Receipt and review EW, LM, Doe -Federal - Edwards April 28th letter re: extensions to respond; BB - KuvIn's 4/28th letter re: deposition For Disbursements Incurred: 2.90 hr $870.00 2.401v 5720.00 0.40 hr $120.00 1.80hr $540.00 1.70hr $510.00 0.20 hr $100.00 Total Professional Services: $115,515.00 03/20/2009 Void Check # 66779 ($75.00) 03/26/2009 Void Check # 66844 ($9.50) 03/26/2009 Void Check It 66866 ($18.00) 03/26/2009 Void Check # 66871 ($45.00) 03/26/2009 Void Check # 66865 ($18.00) 04/01/2009 Cheek # 66940 PLATINUM SHOWGIRL; Disbursement for WITNESS FEES $20.00 04/01/2009 Check # 66941 PLATINUM SHOWGIRL; Disbursement for WITNESS FEE 08-029 $20.00 04/01/2009 Check # 66942 HEALTHY FAMILIES, P,A.; Disbursement for WITNESS FEE $15.00 08-029 04/01/2009 Void Check # 68940 ($20.00) 04/01/2009 Void Check # 66941 ($20.00) 04/06/2009 Check # 66951 Disbursement for WITNESS FEE 08-029 $11.00 04/06/2009 Check # 66952 Disbursement for WITNESS FEE $11.00 08-029 04/06/2009 Check # 66953 ANTHONY FIGUEROA; Disbursement for WITNESS FEE 08-029 $11.00 04/06/2009 Void Check # 66952 ($11.00) 04/06/2009 Void Check # 66953 ($11.00) 04/07/2009 Pacer Research $3.68 04/14/2009 Check # 67038 PALM BEACH COPY SERVICE, INC.; Disbursement for $127.37 INV.#78426 04/14/2009 Check # 67040 EDWARD D. CAMERON; Disbursement for SERVICE OF $50.00 PROCESS 04/14/2009 Check # 67041 SEARCY DENNEY SCAROLA. ET AL; Disbursement for COPIES $83.90 OF DVD'S 08-029 041/14/2009 Check # 67042 INFOCOPY; Disbursement for MEDICAL RECORDS JANE DOE $55.82 INV.#22116WRI 04114/2009 Check # 67043 LISA R. HEARING, MD., PA; Disbursement for MEDICAL $65.00 RECORDS BB 08-029 04/17/2009 Pacer Research $2.24 04/22/2009 Check # 67096 U.S. LEGAL SUPPORT, INC.; Disbursement for INV. 662433, $183.90 657990, 657467, 657669, 657673, 654767 04/2212009 Check # 67097 U.S. LEGAL SUPPORT, INC.; Disbursement for INV. 655632 $75.00 Page 15 EFTA00602022 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Disbursements Incurred: 04/23/2009 04/29/2009 04/29/2009 Fax Usage charge Check # 67128 EDWARD D. CAMERON; Disbursement for SERVICE OF PROCESS Check # 67129 JOSEPH RICH. C.P.S.; Disbursement for INV. 2009001982 $823.00 $1.490.00 $60.00 04/29/2009 Check # 67131 PALM BEACH COPY SERVICE, INC.; Disbursement for INV. $109.89 78798 04/29/2009 Pacer Research $0.84 04/29/2009 Research $5.55 04/29/2009 Research $3.70 04/29/2009 Research $9.25 04/29/2009 Research $97.82 04/29/2009 Research $430.14 04/29/2009 Research $504.21 04/29/2009 Research $39.26 04/29/2009 Research $12.50 04/29/2009 Research $6.06 04/29/2009 Research $4.13 04/29/2009 Research $158.49 04/30/2009 Postage $88.50 04/30/2009 Photocopy expense $1,864.45 04/30/2009 Color copies $3.00 04/30/2009 Pacer research $1.06 Total Disbursements Incurred: $6,199.26 INVOICE SUMMARY Producer Bak Hours Amount JMB $500.00 39.70 $19,850.00 RDC $0.00 1.40 $0.00 RDC $500.00 89.80 $44,900.00 RHB $300.00 40.50 $12,150.00 BM $125.00 103.05 $12,88125 BL $295.00 2.00 $590.00 MJP $300.00 71.00 $21,300.00 ASB $125.00 9.95 $1,243.75 LG $50.00 52.00 $2,600.00 Page 16 EFTA00602023 Matter ID: 2008-029 Invoice # 29879 Federal ID # 59-2827481 For Professional Services: 409.40 Hours $115,515.00 For Disbursements Incurred: $6,199.26 New Charges this Invoice: $121,714.26 Previous Balance: $153,216.29 Less Payment and Credits Received: $153,216.29 OutMandIng Balance: too Plus New Charges this Invoice: $121,714.26 Total Duo: $121,714.28 Balance in Trust: $0.00 Balance in Retainer: $0.00 Page 17 EFTA00602024