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efta-efta01102255DOJ Data Set 9Other

DS9 Document EFTA01102255

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DOJ Data Set 9
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EFTA Disclosure
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Copy Invoice Law Office of Tonja Haddad, PA 315 SE 7th Street Fort Bill to Darren Indyke Jeffrey Epstein 575 Lexington Avenue New York 10022, New York 10022 Invoice Date: Invoice No. 4/30/2013 665 Terms Due Date 5/20/2013 1 NET 20 days Matter Name Billing Type Rate Rothstein/Edwards Hourly billing 425.00 Amount Work Hours Date Description Total hours: 80.26 Hours 4/8/2013 4/9/2013 4/10/2013 4/10/2013 4/11/2013 4/15/2013 4/16/2013 4/16/2013 Receive and review Order from Court. Receive, review, and respond to multiple communications from Scarola regarding new hearings and Motions. Prepare for hearing. Pull all Motions and Orders related to Privilege and Discovery in Counterclaim. Attend specially set hearing on Discovery Order. Review Motion, Notice, and letter from Scarola regarding Admissions. Send same to client. Review and respond to communications from co- counsel and opposing counsel. Review letter and hearing notice and discovery objections from Scarola. Read Motions filed by Scarola. Begin Drafting Memorandum of Law for Judge. Review multiple communications from opposing counsel and co-counsels. Revise Memorandum of Law re: privilege log. 1.50 2.00 2.50 0.50 0.50 0.30 2.00 3.20 21,691.50 EFTA01102255 Work Hours Date Description Hours 4/17/2013 Review transcript from April 10 hearing. 0.40 4/17/2013 Teleconference with co-counsels. 1.20 Review case law from Scarola. 4/18/2013 4/20/2013 Communications with co-counsels regarding case and hearing on Monday, Conduct additional research for Hearing on 0.50 2.75 4/22/2013 Privilege issues, Prepare for and attend hearing on Privilege Log and Motion to Deem Admissions admitted, Communications with co-counsel regarding case. 3.75 4/22/2013 Review pleadings and draft a "Schedule A" for deposition of Brad Edwards. 1.50 4/23/2013 Conference with Fred Haddad. Draft Outline of 0.75 Damages for Deposition prep. 4/23/2013 Review trial order and make schedule to send to co-counsels. 0.50 4/25/2013 Review and respond to emails from Scarola's 0.95 Office. Review Motion for Protective Order. Review and respond to communications from co- counsels. 4/26/2013 Begin researching and drafting opposition to protective Order. 3.75 4/27/2013 Draft Memorandum of opposition to protective 2.50 Order. Revise Memorandum. 4/28/2013 Finalize memorandum and prepare for hearing. 1.50 4/29/2013 Attend hearing for setting hearing on Motion for 2.25 Protective Order. 4/30/2013 April work performed by Debra Fein as reduced by 45.16 THC (invoice attached). 45.16 hours at $150.00 per hour. Total hours: 80.26 Expenses Date Description 4/23/2013 Federal Express to Judge 16.03 Total expenses: Subtotal 16.03 Amount 21,691.50 Subtotal 21,707.53 Tax 0.00 Previous Retainer Balance 10,000.00 Total Due 11,707.53 EFTA01102256 Epstein Billing: April 2013 Debra Fein Date Time Description 4/9/13 3.00 Prepare for hearing; print documents; print cases; (-1.2) arrange; prepare blank orders and envelopes 4/10/13 2.00 Hearing in WPB 4/12/13 4.00 Research for memorandum of law: discovery for punitive damages issues 4/13/13 10.00 Research and draft memorandum of law for hearing (-3.5) Monday 4/22/13 4/14/13 8.00 Continue to research and draft the memorandum of law (3.0) 4/17/13 4.50 Continue to research and draft memorandum of law; review Scarola's document in advance of the hearing and prepare response 4/18/13 6.00 Continue to research and draft memorandum of law (-1.50) 4/18/13 2.50 Research 5th amendment issue and privilege logs 4/19/13 6.00 Continue to draft the memorandum for the hearing (-4.0) Monday 4/20/13 2.00 Draft summary of argument for hearing Monday 4/21/13 4.50 Prepare question by question response from Request for Production and Interrogatories based upon privilege log and prevailing case law for argument regarding the asserted privileges and the fifth amendment 4/22/13 3.00 Hearing (-1.0) 4/22/13 0.25 File and serve additional cases sited during oral arguments; print; make copies; scan; efile and eserve; fedex to Judge Crow 4/23/13 0.17 Electronically servere notice of deposition for Bradley Edwards with duces tecum "Schedule A" 4/27/13 0.34 Review THC's memorandum of law in opposition to Bradley Edwards's MPO 4/29/13 2.00 Hearing in Palm Beach on Edwards's Motion for a one hour hearing Total 58.26 At 150.00 per hour =$8739.00 Reduced 45.16 At 150.00 per hour = $6774.00 Hours (total billed) EFTA01102257

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