Case File
efta-efta00799145DOJ Data Set 9OtherWire Confirmation
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DOJ Data Set 9
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efta-efta00799145
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Wire Confirmation
The wire transfer request below has been transmitted successfully.
Transmitted:
06/08/2018 12:25:37 PM (ET)
Transmitted By: BELLAKLEIN
Account
Template Name
Recipient Name
Amount Currency Effective
Date
Number
Approval
Status
Jeffrey Epstein -
NOW -'9691
JEE to Link and
Rockenbach PA
Link and
Rockenbach, P.A.
187,219.23 USO
06/08/2018 153892291
1 of 1 received
EFTA00799145
la CIVIL TRIAL & APPELLATE LAW
LINK&
ROCKENBACH, PA
Wire Transfer Instructions
Wire Transfer to:
Wells Fargo Bank Il
Routing No. / ABA No.:
121000248
Address:
420 Montgomery
San Francisco, CA 94104
1555 Palm Beach Lakes, Blvd., Suite 930
West Palm Beach, FL 33401
TEL: (561) 847-44081 FAX: (561) 855-2891
Beneficiary Account No.:
Beneficiary Name:
Link & Rockenbach,
Address:
1555 Palm Beach lakes, Blvd.
Suite 301
West Palm Beach, FL 33401
Additional Information:
Operating Account
EFTA00799146
la CIVIL TRIAL & APPELLATE LAW
LINK&
ROCKEN BACH, PA
May 22, 2018
Via Emai► -frevacationegmaitcom
Jeffrey Epstein
6100 Red Hook Quarter, B3
St Thomas, USVI 00802
Re:
Jeffrey Epstein v. Bradley J. Edwards
File No.: 2.0001
Dear Jeffrey:
1555 Palm Beach Lakes, Blvd., Suite 930
West Palm Beach, FL 33401
TEL: (561) 847-4408 I FAX: (561) 855-2891
Attached please find our firm's billing statement for services rendered through April 30,
2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the
amount of $800.00 ($100.00 x 8 hours). The line items beginning with "No Charge" reflect an
additional reduction in the amount of $7,078.50 making the total reduction $7,878.50.
Please do not hesitate to call me if you have any questions regarding this bill. Thank you.
Very truly yours,
/
SJL/pvd
Attachment
cc: Darren Indyke w/attachment
Scott J. Link
EFTA00799147
unn LX
rn
1555 Palm Beach Lakes Blvd.
Suite 930
West Palm Beach, FL 33401
Jeffrey Epstein
6100 Red Hook Quarter, B3
St. Thomas, USV 00802
CLIENT: 0002 - Jeffrey Epstein
Re:
0001 Bradley Edwards
Date
Services
03/04/18 RJG
Discuss drafting of certiorari and mandamus petitions
and emergency motion for stay with K. Rockenbach
to have in the pipeline, pending outcome of 3/8/18
hearing; review appellate rules of procedure on
certiorari and mandamus relief and Fourth District
Court of Appeal's Administrative Order re requests
for emergency relief
03/04/18 SJL
Work on strategies re case not at issues, Petition for
Certiorari review, moving for default, etc.; work on
documents re same; multiple communications with J.
Scarola re production issues; follow up with client re
same; work on Clerk's Trial Exhibit List
03/19/18 KBR
Finalize Reply in support of Petition for Writ of
Mandamus
03/23/18 TMB
[No Charge] Work on exhibits and finalize Motion to
Strike B. Edwards' Notice for Trial and Objection to B.
Edwards' Unilaterally Changing Case Style
04/02/18 PVD
[No Charge] Work on updating Orders' binder
04/02/18 PVD
[No Charge] Work on Trial Exhibits
04/02/18 TLC
Work on hearing folders and packages to Court; work
on Motion for In Camera Inspection; prepare
insurance demand; check Bankruptcy Court docket
and follow up on hearing setting of Intervenors'
motions; begin working on response to same; work
on Response to B. Edwards' Motion for Appellate
Attorneys' Fees
May 7, 2018
Invoice # 559
Hours
Amount
1.50
592.50
9.50
7,125.00
0.80
600.00
0.30
0.00
1.50
0.00
4.40
0.00
6.40
1,440.00
EFTA00799148
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/02/18 SJL
Work on Responses to Farmer Jaffe's and the
Intervenors' Show Cause Motions in bankruptcy
court; follow up on additional hearing settings; follow
up with bankruptcy counsel; communications with
clients; work on issues relating to in camera review;
follow up on insurance policy
04/03/18 RJG
Review/analyze Edwards' Motion to Strike improper
references to alleged contents of privileged
documents from Epstein's filings in the certiorari and
mandamus proceedings, review filings and hearing
transcripts mentioned in the Motion, and outline
Response in Opposition
04/03/18 PVD
[No Charge] Work on hearing binder re Farmer
l
e 's Motion to Show Cause, Edwards' Joinder,
, E.W. and Jane Doe's Joinder and Motion to
ervene
04/03/18 PVD
[No Charge] Work on exhibit of comparison of
privilege log for in camera inspection; work on Exhibit
A re documents from Epstein's 3/5/18 Clerk's Trial
Exhibit List Seeking In Camera Review - Compared
to Privilege Log
04/03/18 TLC
Work on Motion for In Camera Review to incorporate
D. Indyke's thoughts and comments; work on exhibits
to same, including comparison of privilege log to trial
exhibit entries; work on insurance policy demand
letter, work on proposed Sealing Order and circulate
to opposing counsel for review in advance of hearing;
work on Response to Farmer Jaffe's Motion to Show
Cause in bankruptcwork on Response to Joinder
filed by Intervenors
., E.W. and Jane Doe
04/03/18 SJL
Work on insurance demand to Fowler White; work on
Motion for In Camera Review; review proposed
Sealing Order, work on preparations for April 4, 2018,
UMC hearing on B. Edwards' Motion to Change Case
Style and Case Management; review B. Edwards'
Motion for Sanctions; work on Response to Motion to
Show Cause in Bankruptcy; follow up with bankruptcy
counsel and D. Indyke re same; review Motions to
Strike filed in appellate proceedings; communications
with P. Cassell re proposed sealing order and no
authority to add Intervenors to caption
Hours
May 7, 2018
Page 2
Amount
7.50
5,625.00
2.50
987.50
1.50
0.00
5.60
0.00
9.50
2,137.50
8.60
6,450.00
EFTA00799149
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/03/18 MLP
[No Charge] Work on preparing Exhibit A of J.
Epstein's Motion for In Camera Inspection by
analyzing B. Edwards' privilege log in order for the
court to utilize and compare the privilege log entries
with the actual documents they claim to represent in
order to emphasize the deficiencies and
misrepresentations within the privilege log and the
need for an In Camera Inspection of certain
documents.
04/04/18 RJG
Legal research on Florida procedural rules and case
law on "captions", "parties" and "limited intervention,"
#
to dete ' e whether caption must be amended to
reflect, E.W. and Jane Doe as intervenors;
review analyze case law cited by Intervenor's counsel
and hearing transcript re trial court's ruling on
amending case style; draft memo to partners re same
04/04/18 RJG
Draft/revise Motion to Maintain Current Case Style
04/04/18 RJG
Review trial court's Order on B. Edwards' Motion for
Adverse Inference Instruction entered April 4,2018
04/04/18 RJG
Discuss strategy for Response in Opposition to B.
Edwards' Motion to Strike Alleged Improper
References to Contents of Purportedly Privileged
Documents; draft/revise Response
04/04/18 PVD
[No Charge] Continue work on hearing binder for
4/13/18 Bankruptcy Court hearing re Farmer Jaffe's
Motion to Show Cause, B. Edwards' Joinder, iii,
E.W. and Jane Doe's Joinder and M., E.W. an
Jane Doe's Motion to Intervene
04/04/18 PVD
[No Charge] Review Motion for In Camera Review for
filing; work on finalizing Exhibit A to Motion for filing
Hours
May 7, 2018
Page 3
Amount
3.40
0.00
2.60
1,027.00
1.30
513.50
0.10
39.50
2.50
987.50
4.70
0.00
2.70
0.00
EFTA00799150
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/04/18 TLC
Work on finalizing Motion for In Camera Review;
work on Exhibit A to same which compares 47
e-mails (proposed trial exhibit privilege log
entries; work on Response to
., E.W. and Jane
Doe's Joinder in bankruptcy Motion to Show Cause;
work on Response to Farmer Jaffe's Motion to Show
Cause; work on proposed Order Sealing disc and
exhibits; circulate it to opposing counsel and address
additional comments; follow up with opposing counsel
on cancellation of UMC hearing on 4/5/18; work on
Motion to Maintain Case Style; send draft to D.
Indyke; work on preparations for Case Management
hearing; update dates and motions list
04/04/18 SJL
Work on finalizing Motion for In Camera Review;
work on Re
nses to Farmer Jaffe's Motion to Show
Cause and
E.W. and Jane Doe's Joinder in
bankruptcy Motion to Show Cause; communications
with client and D. Indyke; review new authorities re
waiver of work product; prepare for UMC hearing on
case management; communications with D. Vitale re
proposed sealing order, work on Motion to Maintain
Case Style; follow up with J. lanno re Fowler White's
Insurance policy
04/04/18 KBR
Prepare e-mail to D. Vitale
se style and
dismissal with prejudice of
in 2010; analyze case
law re case style change in preparation for UMC
hearing on B. Edwards' Motion to Change Case
Style; revise Motion to Maintain Current Case Style
04/05/18 RJG
Review/analyze 3/23/18 decision from the Eleventh
Circuit (Drummond v. Conrad & Scherer), and draft
Notice of Supplemental Authority in support of J.
Epstein's Motion for In Camera Review
04/05/18 RJG
Revise Notice of Supplemental Authority In support of
Motion for In Camera Review
04/05/18 RJG
Legal research on federal case law for proposition
that a client cannot be sanctioned or held responsible
for a law firm's violation of a court order when the
client knew nothing about it; draft memo re same
04/05/18 RJG
Review Fourth District Court of Appeal Order denying
B. Edwards April 3, 2018 Motion to Strike
Hours
May 7, 2018
Page 4
Amount
8.00
1,800.00
6.50
4,875.00
0.90
675.00
1.30
513.50
0.70
276.50
2.00
790.00
0.10
39.50
EFTA00799151
Client Ref:
0002 - 0001
May 7, 2018
Invoice # 559
Page 5
Date
Services
Hours
Amount
04/05/18 PVD
[No Charge] Continue work on hearing binder for
3.40
0.00
4/13/18 Bankruptcy Court hearing re combined Table
of Authorities
04/05/18 PVD
[No Charge] Continue review of Clerk's Trial Exhibits
1.00
0.00
for compliance
04/05/18 SJL
Attend case management UMC hearing; follow up
9.30
6,975.00
with D. indyke and J. Epstein re same; work on
Response to show cause filings in Bankruptcy Court;
meet with J. lanno re disc; work on Response to
Farmer Jaffe's Motion for Order to Show Cause; work
on Response to Intervenor's Joinder;
communications with client and D. Indyke
04/05/18 TLC
Prepare letter and package to Judge Hafele re
Agreed Order Directing Clerk to Seal Filings; prepare
Notice of Cancellation of UMC hearing; meet with J.
lanno re disc; work on Response to Farmer Jaffe's
Motion for Order to Show Cause; work on Response
to Intervenor's Joinder; work on schedule of hearings
to submit to judge
7.80
1,755.00
04/05/18 KBR
Prepare for and attend case management
0.90
675.00
conference
04/06/18 PVD
(No Charge] Continue review of Clerk's Trial Exhibits
2.20
0.00
for compliance
04/06/18 PVD
[No Charge] Review J. Epstein's Response In
1.50
0.00
Opposition to Farmer Jaffe's Motion to Show Cause
04/06/18 PVD
[No Charge] Resume work on hearing binder for April
0.30
0.00
13th Bankruptcy Court hearing re Table of Authorities
re Epstein's Response in Opposition to Farmer
Jaffe's Motion to Show Cause
04/06/18 SJL
Telephone conferences and e-mails with D. Indyke;
8.30
6,225.00
work on Response to bankruptcy filings by Farmer
Jaffe, B. Edwards and the Intervenors; work on
hearing schedule; follow up with J. Epstein re
bankruptcy response
EFTA00799152
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/06/18 TLC
Work on assembling exhibits and preparing index to
same for our Response to Farmer Jaffe's Motion for
Order to Show Cause and B. Edwards' Joinder; work
on Response to incorporate D. lndyke's suggested
changes and comments; follow up on D. Indyke's
questions in Response (amount paid to Special
Master and location of disc within production); review
Bankruptcy Court rules re appearance of
non-registered users; follow up with D. Indyke on C.
Pugatch's fee agreement; telephone conference with
C. Pugatch re filing logistics; work on motion chart;
prepare e-mail to counsel to follow up on same
04/08/18 SJL
Communications with client; work on Responses in
Bankruptcy Court; work on preparations for hearing
on same
04/09/18 TLC
Prepare letter and package to Clerk re filing under
seal; work on Response to Farmer Jaffe's Motion for
Order to Show Cause and B. Edwards' Joinder; work
on Response to Intervenors' Joinder; check
Bankruptcy Court docket; work on motions chart;
follow up with D. Vitale re same
04/09/18 SJL
Work on Response to Farmer Jaffe's Motion for
Order to Show Cause and B. Edwards' Joinder; work
on Response to Intervenors' Joinder; telephone
conferences with D. Indyke re same; communications
with J. Epstein re bankruptcy responses and
responding to Law360 reporter; prepare response to
Law360 reporter, work on list of outstanding motions
requested by court; communications with D. Vitale re
same
04/10/18 PVD
[No Charge] Update hearing binder for 4/13/18
Bankruptcy Court hearing re J. Epstein's Response In
Opposition to Farmer, Jaffe's Motion for Order to
Show Cause and Table of Authorities
04/10/18 PVD
[No Charge] Update Orders binders; update hearing
binder for 4/13/18 bankruptcy hearing re docket entry
cites referenced in filing; finalize Table of Authorities
04/10/18 KBR
Work on Response to Intervenors' Joinder
Hours
May 7, 2018
Page 6
Amount
7.80
1,755.00
3.50
2,625.00
9.80
2,205.00
5.60
4,200.00
5.80
0.00
6.60
0.00
0.50
375.00
EFTA00799153
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/10/18 TLC
Review Law360 website re article on bankruptcy
motions practice; work on preparations for UMC
hearing on S. Rothstein's default; work on Response
to Intervenors' Joinder; multiple communications with
bankruptcy counsel on logistics, hearing and filing;
follow up with opposing counsel on motions chart;
work on to do list
04/10/18 SJL
Work on Response to Intervenors' Joinder,
communications with D. Indyke and client; work on
preparations for bankruptcy hearing
04/11/18 RJG
Research trial court's failure to enter a default when
all conditions are satisfied; mandatory nature of
default rule; mandamus as available remedy
04/11/18 PVD
[No Charge] Review Clerk's Trial Exhibits for
compliance
04/11/18 TLC
Work on To Do List; work on Response to B.
Edwards' Motion for Sanctions; review 3/8/18,
hearing transcript for quotes to refer in same; review
rules re using electronic filing credentials to file on
behalf of others; review changes in B. Edwards'
3/9/18, Jury Instructions of those instructions we
adopted and prepare summary of changes of same
(i.e., B. Edwards removed "continuing" from his
instructions and is now only focused on Instituting"
the litigation); review discrepancies in V. Roberts'
transcribed interview, follow up on how to proceed
with same
04/11/18 SJL
Work on To Do List; telephone conferences with D.
Indyke; review S. Rothstein's Motion to Dismiss;
follow up with client re strategies relating to same;
review rules re using electronic filing credentials and
being bound by same; follow up with opposing
counsel re position; telephone conference with
Fowler White's counsel; communications with J.
Goldberger; review Fowler White's Response to
Farmer Jaffe's Motion to Show Cause in Bankruptcy
Court; review changes in B. Edwards' Jury
Instructions; work on preparations for bankruptcy
hearing
Hours
May 7, 2018
Page 7
Amount
7.20
1,620.00
3.50
2,625.00
1.00
395.00
0.50
0.00
8.20
1,845.00
8.50
6,375.00
EFTA00799154
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/11/18 KBR
Prepare for and attend (waft per Judge Hafele for
attendance by M. Nurik) J. Epstein's Motion for
Judicial Default Against S. Rothstein; prepare recap
of UMC hearing and court's discussion/ruling
04/12/18 SJL
Work on Motion for Leave to Amend Exhibit Lists;
work on preparations for bankruptcy hearing;
strategize with D. Indyke and C. Pugatch (bankruptcy
counsel); review B. Edwards' and Intervenors'
late-filed Replies; consider options to move to strike;
review bankruptcy rules re same; communications
with client
04/12/18 TLC
Check judge's availability for hearing on S.
Rothstein's Motion to Dismiss; continue reviewing
rules re use of attorneys' electronic filing credentials;
work on Response to B. Edwards' Motion for
Sanctions; work on Motion for Leave to Amend
Exhibit Lists; follow up with bankruptcy counsel re
hearing; review B. Edwards' and Intervenors' late
filed Replies in Bankruptcy Court; work on updating
budget; work on motions list to submit to Court;
prepare letter to Judge Hafele re same
04/13/18 TLC
Work on updating budget; work on final preparations
for bankruptcy hearing; check Bankruptcy Docket to
determine if any additional filings; work on Motion re
leave to Amend Exhibit List
04/13/18 SJL
Work on budget and To Do List; work on
preparations for hearing in Bankruptcy Court on
Farmer Jaffe's Motion to Show Cause, B. Edward's
Joinder and the Intervenors' Joinder; meet with C.
Pugatch before hearing; attend and argue hearing;
telephone conferences with J. Epstein and D. Indyke
re outcome of same; follow up with P. Cassell re his
proposed Order on intervention
04/16/18 RJG
Review/analyze B. Edwards' Motion to Permit B.
Edwards to take the Limited Deposition of J. Epstein;
begin researching whether ordering someone to
appear for deposition means they are not subject to
service for any other purpose
Hours
May 7, 2018
Page 8
Amount
2.30
1,725.00
6.20
4,650.00
7.80
1,755.00
5.20
1,170.00
9.60
7,200.00
1.10
434.50
EFTA00799155
Client Ref:
0002 - 0001
Invoice # 559
Date
04/16/18 TLC
04/16/18 SJL
Services
Work on Motion to Strike Certain Witnesses and to
Compel B. Edwards to Identify Who Will be Called at
Trial; follow up on ordering transcript of bankruptcy
hearing; work on To Do List; review Motion to Compel
J. Epstein's deposition
Work on follow up to rulings made by Bankruptcy
Court; communications with C. Pugatch re same;
review B. Edwards' Motion to allow J. Epstein's
deposition; follow up with D. Indyke and J. Epstein re
same; work on strategies; work on Motion to allow us
to amend Exhibit List
04/17/18 RJG
Legal research whether a party, If compelled by court
order to come to a jurisdiction, can be served with
process for another purpose
04/17/18 TLC
04/17/18 SJL
Follow up on bankruptcy evidentiary hearing
scheduling; work on Motion to Strike Certain of B.
Edwards' Witnesses and to Compel Him to Identify
Who Will be Called at Trial; review November 29,
December 5 and December 7 hearing transcripts in
order to cite Court's rulings relating to same; review
B. Edwards' Witness Lists and discovery responses
in order to cite to same; research trial by ambush and
Florida Statutes re witness testimony
Follow up on Bankruptcy Court setting evidentiary
hearing; multiple communications with C. Pugatch;
work on Motion to Strike Certain of B. Edwards'
Witnesses, etc.; work on Response to Motion for
Sanctions; work on trial strategies; communications
with client
04/18/18 MLP
[No Charge] Work on analysis and comparison
between V. Roberts' recorded telephone
conversation with B. Edwards and J. Scarola
(recorded 4/7/11) and the transcript filed by B.
Edwards in order to prepare and submit a corrected
and accurate transcript of the conversation
04/18/18 TLC
Review bankruptcy transcript; work on bankruptcy
hearing logistics; check bankruptcy docket
Hours
May 7, 2018
Page 9
Amount
6.00
1,350.00
7.50
5,625.00
1.90
750.50
8.20
1,845.00
5.20
3,900.00
4.30
0.00
0.60
135.00
EFTA00799156
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/18/18 SJL
Work on bankruptcy hearing logistics;
communications with C. Pugatch and counsel for the
parties; review bankruptcy hearing transcript; follow
up with client re same; respond to D. Indyke's inquiry
about B. Edwards re-noticing matter for trial; work on
adverse inference jury instruction; follow up with D.
Indyke and J. Epstein re same; work on Response to
Motion for Sanctions
04/19/18 TMB
[No Charge) Review clerk's records regarding status
of mandamus case
04/19/18 RJG
Legal research in preparation for drafting legal
argument in Motion to Compel B. Edwards to Identify
His Trial Witnesses and Motion to Strike V. Guiffre as
a Witness
04/19/18 RJG
Review facts re B. Edwards' Witness Lists and trial
court rulings re limitation of testimony (to keep focus
on malicious prosecution claim) in preparation for
drafting argument section of Motion to Compel B.
Edwards to Identify His Trial Witnesses and Motion to
Strike V. Guiffre as a Witness
04/19/18 RJG
Begin drafting/revising argument section of Motion to
Compel B. Edwards to Identify His Trial Witnesses
04/19/18 SJL
Review Fourth District Court of Appeal's Order
denying Petition for Writ of Certiorari; follow up with
D. Indyke and J. Epstein re same; follow up with D.
Vitale re setting hearing on B. Edwards' Motion to
Take J. Epstein's Deposition; work on Response to
same; work on Motion to Allow Late Disclosure of S.
Smith
04/19/18 TLC
Work on Motion to Allow S. Smith to Testify at Trial;
review Fourth District Court of Appeal's Order
denying Petition for Writ of Certiorari; work on
Response to B. Edwards' Motion to Permit to Take
the Limited Deposition of J. Epstein; review Farmer
Jaffe's Motion in the Bankruptcy Court and the
Bankruptcy Court hearing transcript for cites to
reference in same
Hours
May 7, 2018
Page 10
Amount
6.20
4,650.00
0.10
0.00
3.90
1,540.50
1.90
750.50
1.90
750.50
4.20
3,150.00
7.20
1,620.00
EFTA00799157
Client Ref:
0002 - 0001
May 7, 2018
InvoiceI/559
Page 11
Date
Services
Hours
Amount
04/20/18 RJG
Continue drafting/revising Motion to Compel B.
3.90
1,540.50
Edwards to Identify His Trial Witnesses, Motion to
Strike V. Guiffre as a Witness, and Motion for Leave
to Disclose Expert Witness and supplemental
research for inclusion in same
04/20/18 RJG
Review/analyze Order to Show Cause Issued by
Bankruptcy Court and research proper procedure for
a court's Order to Show Cause; review/edit draft
Response to B. Edwards' Motion to Depose J.
Epstein
3.10
1,224.50
04/20/18 PVD
[No Charge] Review V. Guiffre's audio interview for
1.00
0.00
final edits
04/20/18 TLC
Work on Response in Opposition to B. Edwards'
7.00
1,575.00
Motion to Be Permitted to Take J. Epstein's Limited
Deposition; review Bankruptcy Court's Order to Show
Cause; update calendar re deadlines set forth
therein; begin research to see other Show Cause
Orders entered by Judge Ray; participate in
telephone conference with S. Link, C. Pugatch and D.
Indyke re Order and strategies going forward;
communications with D. Vitale re hearing
04/20/18 SJL
Work on Response in Opposition to B. Edwards'
9.50
7,125.00
Motion to be Permitted to Take His Limited
Deposition; review Order to Show Cause Why Fowler
White and J. Epstein Should Not be Held in
Contempt and Scheduling Evidentiary Show Cause
Hearing; telephone conferences with D. Indyke and
C. Pugatch re analysis, options and strategies
relating to same; work on Motion to Allow S. Smith to
Testify at Trial; work on Response to Motion for
Sanctions
04/20/18 KBR
Work on Response in Opposition to B. Edwards'
2.00
1,500.00
Motion to be Permitted to Take J. Epstein's Limited
Deposition; work on Response to Motion for
Sanctions in state court
04/21/18 TLC
Work on analysis of Bankruptcy Court's Order,
hearing transcript, and next steps; research other
Show Cause Orders entered by Judge Ray
4.50
1,012.50
EFTA00799158
Client Ref:
0002 - 0001
May 7, 2018
Invoice # 559
Page 12
Date
Services
Hours
Amount
04/21/18 SJL
Work on analysis of Court's Order to Show Cause;
2.50
1,875.00
telephone conference with J. Epstein re same; work
on Response to Motion for Sanctions
04/23/18 RJG
Review pertinent portions of record in preparation for
1.20
474.00
drafting/revising Motion to Allow Amendment to
Exhibit List
04/23/18 RJG
Legal research in preparation for drafting/revising
2.90
1,145.50
Motion to Allow Amendment to Exhibit List
04/23/18 RJG
Draft/revise Motion to Allow Amendment to Exhibit
3.90
1,540.50
List
04/23/18 TLC
Research Federal Rules of Civil Procedure, Federal
9.80
2,205.00
Rules of Bankruptcy Procedure, Southern District of
Florida Bankruptcy Court Local Rules and Florida
Rules of Civil Procedure re instructing witness not to
answer; work on Response to Motion to Take J.
Epstein's Deposition; work on Response in
Opposition to B. Edwards' Motion for Sanctions for
Violation of Court Order and the Intervenors' Joinder;
work on Motion to Compel B. Edwards to Identify his
Trial Witnesses and Motion to strike V. Giuffre as a
Witness; work on Renewed Motion for Leave to
Disclose Expert Witness; work on Adverse Inference
Jury Instruction and prepare Notice of Filing for same
04/23/18 SJL
Work on Response to Motion to Take J. Epstein's
4.50
3,375.00
Deposition; multiple communications with D. Indyke
re same; work on Response in Opposition to B.
Edwards' Motion for Sanctions; follow up with C.
Pugatch re discovery re Intervenors' alleged
damages
04/23/18 PVD
[No Charge] Continue review of Clerk's Trial Exhibits
1.00
0.00
for compliance
04/24/18 TLC
Work on Motion for Leave to Amend Exhibit List;
9.00
2,025.00
prepare letter and package to Court re submission for
4/26/18, hearing on B. Edwards' Motion to Permit J.
Epstein's deposition; work on Response to Motion to
Depose J. Epstein; work on Response In Opposition
to B. Edwards' Motion for Sanctions; work on
Amended Jury Instructions
EFTA00799159
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/24/18 SJL
Work on Response to Motion to Take J. Epstein's
Deposition; multiple communications with D. Indyke
re same; follow up with J. Epstein re review of same;
work on letter to Court; work on Response in
Opposition to B. Edwards' Motion for Sanctions; work
on Motion for Leave to Amend Exhibit List; telephone
conference with D. Vitale re hearing
04/24/18 PVD
[No Charge] Continue review of Clerk's Trial Exhibits
for compliance
04/25/18 TLC
Work on Response in Opposition to B. Edwards'
Motion for Sanctions; work on Motion to Allow
Amendment to Exhibit List; work on Motion for Leave
to Disclose Expert Witness; follow up on deposition
dates for J. Epstein
04/25/18 SJL
Work on Response in Opposition to B. Edwards'
Motion for Sanctions; work on Motion to Mow
Amendment to Exhibit List; work on Motion for Leave
to Disclose Expert Witness; communications with C.
Pugatch re strategies for bankruptcy proceeding;
follow up with J. Scarola re J. Epstein's deposition;
work on dates for same; communications with D.
Indyke and J. Epstein re same
04/25/18 PVC/
[No Charge] Continue review of Clerk's Trial Exhibits
for compliance
04/26/18 TLC
Work on Amended Jury Instructions; work on Motion
to Amend Exhibit List and Motion to Disclose Expert
Witness; forward drafts to D. Indyke for review, follow
up with opposing counsel on setting J. Epstein's
deposition; multiple telephone conferences with
Fowler White's counsel, J. Goldberger and J.
Scarola's assistant
04/26/18 SJL
Work on Motion to Amend Exhibit List; work on
Motion to Disclose Expert Witness; work on issues
relating to setting J. Epstein's deposition;
communications with D. Indyke and J. Epstein
04/26/18 KBR
Work on Motion to Allow Amendment of Exhibit List;
work on Renewed Motion for Leave to Disclose
Expert
Hours
May 7, 2018
Page 13
Amount
8.80
6,600.00
6.50
0.00
5.50
1,237.50
5.20
3,900.00
4.40
0.00
4.20
945.00
7.20
5,400.00
0.60
450.00
EFTA00799160
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/26/18 PVD
[No Charge] Continue review of Clerk's Trial Exhibits
for compliance
04/27/18 RJG
Review Fourth District Court of Appeal Order on
Petition for Writ of Mandamus and Motions for Fees
04/27/18 TLC
Work on Motion for Leave to Amend Exhibit List to
incorporate D. lndyke's thoughts and comments;
review p's transcript re testimony; follow up with
Florida
urt Reporting re instructions to transcribe
V. Roberts' interview and prepare comparison;
prepare follow-up e-mail detailing same; review
Fourth District Court of Appeal's Order removing
stay; review Florida Rule of Civil Procedure when
case can be reset
04/27/18 SJL
Work on Motion for Leave to Amend Exhibit List;
communications with D. Indyke and J. Epstein;
review Fourth District Court of Appeal 's Order
removing stay and denying Petition for Writ of
Mandamus; work on strategies going forward; work
on Motion re witnesses
04/27/18 PVD
[No Charge] Continue review of Clerk's Trial Exhibits
for compliance
04/29/18 TLC
Work on Motion to Compel B. Edwards to Identify his
Trial Witnesses; forward same to D. Indyke for
review; work on Motion to Use Certified Transcript of
V. Roberts' April 2011 telephonic interview at trial;
review all communications that was stricken
compared to charts of privilege and produced
documents and identify all communications that were
produced on our Amended Exhibit List; review public
records for Jane Doe,pli. and E.W. to reduce
number of exhibits; u a e Amended Exhibit List re
same; update witness binders with same
04/29/18 SJL
Work on Motion to Compel B. Edwards to Identify his
Trial Witnesses; work on Motion to Use Certified
Transcript of V. Roberts' April 2011 telephonic
interview; meet with J. Epstein re trial strategies
04/30/18 PVD
[No Charge] Review Fowler White production for
additional exhibits listed on Amended Exhibit List to
be filed
Hours
May 7, 2018
Page 14
Amount
1.10
0.00
0.10
39.50
6.20
1,395.00
7.20
5,400.00
0.50
0.00
7.50
1,687.50
3.50
2,625.00
2.20
0.00
EFTA00799161
Client Ref:
0002 - 0001
Invoice # 559
Date
Services
04/30/18 TLC
Work on Amended Exhibit List; work on assembling
documents identified for Amended Exhibit List; work
on Motion to Limit Witnesses; work on chart for
status conference hearing; work on preparations for
same
04/30/18 SJL
Hours
7.50
Work on review of trial exhibits to narrow down those
7.50
to be used at trial; work on Motion to Limit Exhibits;
communications with D. Indyke and client; work on
trial strategies in light of case being at issue; review
Jury Instructions to determine modifications needed
Recapitulation
May 7, 2018
Page 15
Amount
1,687.50
5,625.00
Rate
Hours
Amount
TMB
Troy M. Bermudez
225.00
0.40
0.00
TLC
Tina L. Campbell
225.00
160.90
36,202.50
PVD
Debi J. Mackey
90.00
58.40
0.00
RJG
Rachel J. Glasser
395.00
41.40
16,353.00
SJL
Scott J Link
750.00
165.60
124,200.00
MLP
Maggie L Powers
225.00
7.70
0.00
KBR
Kara Berard Rockenbach
750.00
8.00
6,000.00
Sub Total
182,755.50
Courtesy Discount
-800.00
For Current Services Rendered
442.40 $181,955.50
Expenses and Advances
Date
Expenses
02/01/18 Courier /Delivery Fee 2/2/18 #7415 to Judge Hafele - Coastal
Messenger Service, Inc.
02/01/18 Courier/Delivery Fee 2/2/18 #7417 to J. Scarola - Coastal Messenger
Service, Inc.
02/01/18 Courier /Delivery Fee 2/13/18 #7754 to Judge Hafele - Coastal
Messenger Service, Inc.
02/01/18 Courier /Delivery Fee 2/20/18 #7776 to PBSO - Coastal Messenger
Service, Inc.
02/01/18 Courier/Delivery Fee 2/27/18 #7807 to Judge Hafele - Coastal
Messenger Service, Inc.
02/06/18 Court Reporter 1/31/18 Hearing before Judge Hafele - Palm Beach
Reporting Services, Inc.
03/20/18 Hearing / Trial Transcript 4/16/18 Hearing before Judge Crow - Orange
Legal, Inc
03/22/18 Travel Expense Baggage Fee - SJL
03/22/18 Travel Expense Baggage Fee - KBR
03/22/18 Travel Expense Airfare WPB/NYC - KBR
Amount
25.00
25.00
25.00
25.00
25.00
80.00
531.00
25.00
25.00
374.62
EFTA00799162
Client Ref:
0002 - 0001
May 7, 2018
Invoice # 559
Page 16
Expenses and Advances
Date
Expenses
Amount
03/22/18 Travel Expense Airfare NYC/WPB - KBR
613.30
03/22/18 Travel Expense Cab Fare - NYC
13.55
03/22/18 Travel Expense Cab Fare - NYC
11.16
03/22/18 Travel Expense Cab Fare -NYC
40.87
03/22/18 Travel Expense Meals - NYC
90.67
03/23/18 Travel Expense Cab Fare - NYC
9.95
03/28/18 Court Reporter 3/26/18 Hearing before Judge Hafele - Palm Beach
80.00
Reporting Services, Inc.
03/28/18 Transcript Fee 3/26/18 Hearing Transcript-Judge Hafele - Palm Beach
52.80
Reporting Services, Inc.
04/01/18 Westlaw Research 3/1/18 - 3/31/18
1,157.10
04/01/18 Courier /Delivery Fee Misc. Deliveries to Judge and Opposing Counsel
360.00
(14 trips) - Coastal Messenger Service, Inc.
04/06/18 Court Reporter 4/5/18 Hearing before Judge Hafele - Palm Beach
80.00
Reporting Services, Inc.
04/16/18 Travel Expense Airfare FTL to NYC - SJL
441.20
04/16/18 Travel Expense Airfare FTL to NYC - KBR
441.20
04/17/18 Travel Expense Share of Car Rental in Tallahassee - Seamy Denney
53.11
Scarola Barnhart & Shipley,
04/18/18 Travel Expense Airport Parking
42.00
Copy Charge through 04/30/18
616.20
Total Expenses and Advances
$5,263.73
Sub Total
$188,019.23
Courtesy Discount
Total Current Work
Trust Funds Balance: $41,394.86 19
o4/29/9
EFTA00799163
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FAX: (561) 855-2891Phone
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12p
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5p
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