DS9 Document EFTA01102251

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