la CIVIL TRIAL & APPELLATE LAW

la CIVIL TRIAL & APPELLATE LAW LINK& ROCKEN BACH, PA July 9, 2018 Via Email leevacationOgmaitcom 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: Attached please find our firm's billing statement for services rendered through June 30, 2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the amount of $440.00. Please do not hesitate to call me if you have any questions regarding this bill. Thank you. SJL/pvd Attachment cc: Darren Indyke w/attachment Scott J. Link EFTA00801412 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Bcach FL 33401 Tax ID No. Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 06/01/18 TLC Work on scheduling J. Epstein's deposition; work on dates for same; multiple communications with client, C. Pugatch, D. Indyke and J. Goldberger re availability; work on proposed Order on J. Epstein's deposition to incorporate D. Indyke's suggested edits; follow up with client and counsel on our side re same; prepare email to M. McCann re dates; prepare e-mail to D. Vitale re proposed Order 06/01/18 SJL Work on proposed order re J. Epstein's deposition to incorporate D. Indyke's suggestions; review hearing transcript re same; follow up on J. Epstein's deposition dates; work on Motion re V. Roberts' testimony; review court reporter's "corrections" and final transcript; communications with client 06/02/18 SJL Continue working on Motion to Strike requested relief in bankruptcy proceeding 06/04/18 TLC Work on proposed Order re J. Epstein's deposition; prepare cover letter to Judge Hafele; e-mail communications with D. Indkye re same; follow up on setting UMC hearing on S. Rothstein's Motion to Dismiss; work on hearing folder; prepare Notice of Hearing, proposed Order and letter to Judge; work on redactions to V. Roberts' transcript (i.e., info required by rules to be redacted); work on Motion to Use Certified Transcript; work on updating To Do List 06/04/18 SJL Work on letter to Judge re submission of proposed Order re J. Epstein's deposition; work on proposed Order; multiple communications with D. Indyke and J. Epstein re same; follow up on setting hearing on Motion to Dismiss July 6, 2018 Invoice # 824 Hours Amount 3.20 720.00 5.20 3,900.00 2.50 1,875.00 6.50 1,462.50 3.50 2,625.00 EFTA00801413 Client Ref: 0002 - 0001 Invoice # 824 Date Services 06/05/18 MS Conduct detailed research of Florida case law on the specific issue of whether a general release will include claims that were unknown at the time of execution and had not yet accrued 06/05/18 MS Prepare in-depth addition to previously drafted memorandum on the issue of release agreements, this time analyzing the instant release agreement and applying Florida case law to the specific language contained therein 06/05/18 TLC Communications with opposing counsel on proposed order re J. Epstein's deposition; finalize package to Judge Hafele and submit same; follow up on trial setting issues; communications with opposing counsel re same 06/05/18 SJL Review D. Indyke's edits to Response to Motion for Sanctions; work on revision to same; communications with opposing counsel re trial setting; work on trial strategies; meet with R. Glasser re Motion to Strike Requested Relief in bankruptcy proceeding; work on same 06/06/18 TLC Work on Response in Opposition to B. Edwards' Motion for Sanctions; follow up on Response to Motion to Dismiss; work on preparations for upcoming hearings 06/06/18 SJL Work on multiple rounds of revision to our Response to B. Edwards' Motion for Sanctions; multiple communications with D. Indyke and J. Epstein re same; follow up on schedule of outstanding hearings and trial setting 06/06/18 RJG Review B. Edwards' Summary of Damages, related pleading concerning Bankruptcy Court's Order to Show Cause, and case law re compensatory sanctions for civil contempt, in preparation for drafting opposition to B. Edwards' Summary of Damages Hours July 6, 2018 Page 2 Amount 2.00 790.00 1.20 474.00 0.80 180.00 5.40 4,050.00 3.20 720.00 5.20 3,900.00 4.50 1,777.50 EFTA00801414 Client Ref: 0002 Invoice # 824 Date - 0001 Services Hours July 6, 2018 Page 3 Amount 06/07/18 TLC Work on preparations for hearing on all pending 3.80 855.00 Motions; review and update previous hearing folders and identify additional items needed; prepare e-mail to M. Nurik re changing UMC hearing on S. Rothstein's Motion to Dismiss; prepare Re-Notice of Hearing; finalize Response to Motion for Sanctions and file same 06/07/18 SJL Finalize Response to Motion for Sanctions; multiple communications with client; work on Response to 4.30 3,225.00 Motion to Dismiss; begin reviewing hearing folders in anticipation of upcoming two-day hearing 06/08/18 RJG Outline and begin drafting Response in Opposition to 3.30 1,303.50 B. Edwards' Summary of Damages in bankruptcy proceeding 06/08/18 RJG Supplemental research on sanctions for contempt and entitlement to attorneys fees in preparation for drafting Response in Opposition to B. Edwards' 1.90 750.50 Summary of Damages in bankruptcy proceeding 06/08/18 SJL Review May 3, 2018, hearing transcript on Case 5.20 3,900.00 Management Conference hearing re Court's trial setting status; follow up on same; work on Motion to Strike Intervenors' Request for Relief; follow up with D. Indyke and J. Epstein 06/11/18 RJG Finish drafting Response in Opposition to B. 1.20 474.00 Edwards' Summary of Damages in bankruptcy proceeding 06/11/18 SJL Work on bankruptcy issues; work on sanctions motion; work on deposition of J. Epstein 5.20 3,900.00 06/11/18 KBR Legal research/case law re civil contempt, actual damages and self-creating harm; revise Response to 1.00 750.00 Strike B. Edwards' damage summary in Bankruptcy Court 06/12/18 SJL Work on bankruptcy issues; work on sanctions motion; work on deposition for J. Epstein 4.50 3,375.00 06/13/18 SJL Work on bankruptcy response to B. Edwards' damages summary; work on deposition issues for J. 4.80 3,600.00 Epstein EFTA00801415 Client Ref: 0002 - 0001 Invoice # 824 Date Services 06/14/18 SJL Work on comprehensive summary to do list; work on Motion to Strike Intervenors' Damages 06/15/18 RJG Review Bankruptcy Court's Order to Show Cause re J. Epstein's deposition; research federal and local rules re (1) proper notice/service of deposition on non-party deponent; (2) whether subpoena is required; and (3) federal rules re good faith attempt to resolve dispute before filing motion for protective order 06/15/18 SJL Work on Response to S. Rothstein's Motion to Dismiss; follow up with J. Goldberger re hearing; review Duces Tecum in J. Epstein's Notice of Deposition; strategize on responding to same; communications with C. Pugatch, J. Epstein and D. Indyke re same 06/18/18 RJG Review research with K. Rockenbach re notice of deposition duces tecum in federal court, requirement of subpoena on non-party deponent, and federal and local rules of procedure re objecting to notice in preparation for drafting motion for protective order re B. Edwards' Notice of J. Epstein's Deposition in Bankruptcy Court 06/18/18 RJG Research elements of abuse of process cause of action to include in Response to S. Rothstein's Motion to Dismiss 06/18/18 TLC Work on Response in Opposition to B. Edwards' Summary of Damages; review Bankruptcy Court Federal and Local Rules re deadline to object to discovery; update Master Calendar re same; follow up with M. Nurik re changing date of hearing on S. Rothstein's Motion to Dismiss; prepare Re-Notice of Hearing; work on Motion to Strike Intervenors' List of Requested Relief in bankruptcy proceeding; prepare timeline to insert into Response to Motion to Dismiss; follow up with D. Indyke re drafts Hours July 6, 2018 Page 4 Amount 5.50 4,125.00 1.50 592.50 6.20 4,650.00 0.50 197.50 0.10 39.50 5.20 1,170.00 EFTA00801416 Client Ref: 0002 Invoice # 824 Date - 0001 Services Hours July 6, 2018 Page 5 Amount 06/18/18 KBR Analyze Notice of Taking Deposition Duces Tecum of 3.20 2,400.00 J. Epstein and cross-reference with ruling by bankruptcy court re scope and subject matter of deposition; legal research re bankruptcy rules regarding timing and any additional rules referencing federal rules; legal research Federal Rules of Court, local federal rules for the Southern District Court re good faith, motion for protective order, and service of subpoena for deposition on non-party; prepare email to C. Pugatch re concerns of service of notice of taking deposition and proposed response to J. Scarola; revise Response to S. Rothstein's Motion to Dismiss 06/18/18 SJL Work on Response in Opposition to B. Edwards' 5.00 3,750.00 Summary of Damages in Bankruptcy Proceeding; work on Motion to Strike Intervenors' Requested Relief; work on deposition issues; follow up with J. Epstein and D. Indyke re same; work on objection to duces tecum; work on Response to S. Rothstein's Motion to Dismiss; communications with J. lanno re Fowler White's insurance information 06/19/18 RJG Review Notice and Re-Notice of taking Video 1.90 750.50 Deposition Duces Tecum of J. Epstein, Bankruptcy Court's Order to Show Cause and Federal Rules of Civil Procedure re scope of discovery in preparation for drafting Objections and Motion for Protective Order 06/19/18 RJG Begin drafting Objections to Re-Notice of Taking J. 2.20 869.00 Epstein's Video Deposition Duces Tecum and Motion for Protective Order 06/19/18 RJG Begin researching Judge Ray's rulings on overbroad discovery requests and case law from 11th Circuit 1.30 513.50 Court re protective orders 06/19/18 TLC Work on Motion to Strike Intervenors' Requested 3.80 855.00 Relief to address D. Indyke's comments; work on Response in Opposition to B. Edwards' Summary of Damages; follow up with C. Pugatch and J. Goldberger re potential new date for J. Epstein's deposition; work on Motion to Compel B. Edwards to Identify Bates Numbers of Documents Produced EFTA00801417 Client Ref: 0002 - 0001 Invoice # 824 Date Services 06/19/18 SJL Work on Motion to Compel B. Edwards to Identify Bates Number of Documents Produced; work on Motion to Strike Intervenors' Requested Relief to address D. Indyke's comments; work on Response in Opposition to B. Edwards' Summary of Damages; communications with D. Indyke 06/19/18 KBR Review 4th DCA Order (1) discharging its 3/29/18 Order regarding trial; (2) denying Petitioner's Motion for Appellate Attorney's Fees and Costs; (3) denying request for Oral Argument; (4) denying respondent's Motion for Appellate Attorney's Fees; and (5) denying Petitioner's Motion for Rehearing of denial of Petitioner's Motion for Appellate Attorney's Fees and Costs; analyze same 06/20/18 RJG Supplemental research on requirements of rule 26 re discovery/work product privilege and attorney-client privilege; continue drafting/revising Objections to Re-Notice of Taking Video Deposition Duces Tecum of J. Epstein and Motion for Protective Order 06/20/18 RJG Review Notice of Taking Video Deposition Duces Tecum of J. Epstein (State Court) and hearing transcript on B. Edwards' Motion to Permit Limited Deposition of J. Epstein in preparation for drafting Objections to Notice 06/20/18 SJL Work on Motion to Use V. Roberts' Interview; work on Motion to Strike Intervenors' List of Requested Relief or, in the Alternative, to Conduct Limited Deposition Discovery to incorporate additional suggestions by D. Indyke; work on Motion for Protective Order and Objection to Duces Tecums 06/20/18 TLC Work on preparations for two-day hearing on all pending motions; update hearing folders for same; follow up on new date for J. Epstein's deposition; e-mails with co-counsel and opposing counsel re same; work on Motion to Use V. Roberts' Interview; work on Motion to Strike Intervenors' List of Requested Relief; work on Motion for Protective Order Hours July 6, 2018 Page 6 Amount 6.40 4,800.00 0.20 150.00 4.10 1,619.50 0.90 355.50 7.50 5,625.00 8.90 2,002.50 EFTA00801418 Client Ref: 0002 - 0001 Invoice # 824 Date Services 06/20/18 AAS Conduct detailed research of Florida case law to ascertain whether releases of "known and unknown claims" include those claims based on facts that were unknown to the party/parties at the time of the execution of the release 06/20/18 AAS Draft detailed addendum to previously drafted memorandum analyzing whether releases of "known and unknown claims" include those claims based on facts that were unknown to the party/parties at the time of the execution of the release 06/21/18 TLC Continue working on preparations for calendar call to special set hearing on outstanding motions; work on Motion to Use April 7, 2011, Interview of V. Roberts Giuffre at Trial; work on Objections to Duces Tecums in Bankruptcy Proceeding; work on Response to B. Edwards' Summary of Damages; finalize and file Motion to Compel Bates Numbers; follow up with D. Indyke re status of work; prepare Affidavit of J. Epstein 06/21/18 SJL Work on Motion to Use April 7, 2011, Interview of V. Roberts Giuffre at Trial; work on Objection to Duces Tecums in Bankruptcy Proceeding; work on Response to B. Edwards' Summary of Damages; prepare for calendar call on outstanding motions; review hearing transcripts 06/21/18 RJG Review Motion to Permit B. Edwards to Take Limited Deposition of J. Epstein and proposed orders granting B. Edwards' motion in preparation for drafting Responses and Objections to J. Edwards' Notice of Taking Video Deposition Duces Tecum 06/22/18 TLC Work on Objection to Notices of Taking Deposition Duces Tecum in Bankruptcy Court action; work on Affidavit of J. Epstein in support; work on Response in Opposition to B. Edwards' Summary of Damages in Bankruptcy Court action; send drafts to D. Indyke for his review of same Hours July 6, 2018 Page 7 Amount 1.20 474.00 0.80 316.00 7.80 1,755.00 8.50 6,375.00 0.90 355.50 2.80 630.00 EFTA00801419 Client Ref: 0002 Invoice # 824 Date - 0001 Services Hours July 6, 2018 Page 8 Amount 06/22/18 SJL Prepare for and attend calendar call to special set outstanding motions for hearing; work on Objection to 7.30 5,475.00 Notices of Taking Deposition Duces Tecum in Bankruptcy Court action; work on Affidavit of J. Epstein in support; work on Response in Opposition to B. Edwards' Summary of Damages in Bankruptcy Court action; communications with D. Indyke 06/24/18 SJL Continue working on Response to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried in order to interview jurors; research Farmer Jaffe's attorneys and corporation formation to determine status 06/25/18 SJL Work on Response to Farmer Jaffe's Summary of 7.80 5,850.00 Damages; review all outstanding draft documents; telephone conference with D. Indyke re same 06/26/18 RJG Draft/revise (State Court) Responses and Objections to the Notice of Taking Video Deposition Duces 4.30 1,698.50 Tecum of J. Epstein 06/26/18 RJG Supplemental research for draft Responses and 2.10 829.50 Objections to Notice of Taking Video Deposition Duces Tecum of Epstein (State Court): work product privilege/during litigation; proponent of discovery has burden to show relevancy; scope of permissible discovery; access to deponent's computer systems and electronic devices 06/26/18 TLC Work on Response to Farmer Jaffe's and B. 7.80 1,755.00 Edwards' Summaries of Damages in the Bankruptcy Proceeding; prepare demonstratives to illustrate B. Edwards' affiliation with Farmer Jaffe; work on Motion to use V. Roberts' Interview; forward draft Affidavit of J. Epstein to J. Goldberger and M. Weinberg for review; follow up with D. Indyke re Objection to Duces Tecum in Bankruptcy Proceeding; work on Response to S. Rothstein's Motion to Dismiss EFTA00801420 Client Ref: 0002 Invoice # 824 Date - 0001 Services Hours July 6, 2018 Page 9 Amount 06/26/18 SJL Work on Response to Farmer Jaffe's and B. 8.30 6,225.00 Edwards' Summaries of Damages in the Bankruptcy Proceeding; work on Response to S. Rothstein's Motion to Dismiss; follow up on draft Affidavit of J. Epstein; communications with D. Indyke; communications with J. Epstein 06/27/18 TLC Work on updating hearing folders and judge's package in preparation of upcoming two-day hearings on pending Motions; work on Response to 4.80 1,080.00 B. Edwards' and Farmer Jaffe's Summary of Damages; forward same to D. Indyke for review; work on Response to S. Rothstein's Motion to Dismiss; work on proposed Orders for upcoming hearings 06/27/18 SJL Work on Response to B. Edwards' and Farmer 8.20 6,150.00 Jaffe's Summary of Damages; work on Response to S. Rothstein's Motion to Dismiss; work on proposed Orders for upcoming hearings; follow up with M. Weinberg and J. Goldberg re Affidavit; communications with client and D. Indyke; work on strategies for upcoming deposition and bankruptcy hearing 06/28/18 TLC Work on Response to S. Rothstein's Motion to 5.50 1,237.50 Dismiss; work on Affidavit of J. Epstein; follow up with C. Pugatch re Objection to Duces Tecum in bankruptcy proceeding; work on same; follow up D. Indyke re same; follow up with J. Epstein re Affidavit 06/28/18 SJL Lengthy telephone conference with M. Weinberg and 5.80 4,350.00 J. Goldberger re status of litigation, J. Epstein's upcoming deposition testimony, bankruptcy proceeding and draft Affidavit; work on Affidavit; follow up with D. Indkye re response to summaries of damages; work on Response to S. Rothstein's Motion to Dismiss 06/28/18 DAN Research Florida case law re whether an allegation of general damages is sufficient to withstand a motion to dismiss 1.30 513.50 EFTA00801421 Client Ref: 0002 - 0001 Invoice # 824 Date 06/29/18 TLC 06/29/18 SJL Services Work on Response and Objection to Duces Tecums in Bankruptcy proceeding to restructure to remove references to J. Epstein's Affidavit and to incorporate D. Indyke's thoughts and suggestions; assemble exhibits to same and finalize for filing; work with C. Pugatch's office re filing; follow up with D. Indyke re drafts; work on preparations for upcoming hearing in state court action Work on finalizing Response and Objection to Duces Tecums in Bankruptcy proceedings; communications with D. Indyke and J. Epstein re same; work on Response to Motion to Dismiss; work on preparations for J. Epstein's deposition Recapitulation Hours 6.50 6.20 July 6, 2018 Page 10 Amount 1,462.50 4,650.00 Rate Hours Amount TLC Tina L. Campbell 225.00 76.80 17,280.00 RJG Rachel J. Glasser 395.00 30.70 12,126.50 SJL Scott J Link 750.00 133.00 99,750.00 DAN David A. Noel 395.00 1.30 513.50 KBR Kara Berard Rockenbach 750.00 4.40 3,300.00 MS Andrew A. Steadman 395.00 5.20 2,054.00 Sub Total 135,024.00 Courtesy Discount -440.00 For Current Services Rendered 251.40 $134,584.00 Expenses and Advances Date Expenses 05/01/18 Courier /Delivery Fee 5/1/18 to Judge Hafele - Coastal Messenger Service, Inc. 05/31/18 Westlaw Research 06/11/18 Transcript Fee 5/3/18 Hearing Transcript Judge Hafele - Palm Beach Reporting Services, Inc. 06/30/18 Westlaw Research Copy Charge through 06/30/18 Total Expenses and Advances $910.53 Amount 25.00 587.58 72.60 186.35 39.00 EFTA00801422 Client Ref: 0002 - 0001 July 6, 2018 Invoice # 824 Page 11 Sub Total $135,934.53 Courtesy Discount -440.00 Total Current Work $135,494.53 Past Due Balance $117,991.44 Balance Due $253,485.97 Trust Funds Balance: $41,394.86 EFTA00801423 Please return this page with remittance to Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West Palm Beach, FL 33401 Invoice # 824 Bill Date: July 6, 2018 Client Code: 0002 Client Name: Jeffrey Epstein Matter Code: 0001 Matter Name: Bradley Edwards $135,934.53 Courtesy Discount -440.00 Total Current Work $135,494.53 Past Due Balance $117,991.44 Balance Due $253,485.97 Trust Funds Balance: $41,394.86 Amount enclosed: EFTA00801424