Epstein Secrets

0 10/20/2020 AU Meeting Discussed Pl's settlement proposal w/ DAW $475:00 0.2 $95.00 10/21/2020 DW Various Drafted and filed Motion to Set Hearing on Aronberg MSJ; drafted proposed order granting motion to set; checked.court availability; emailed Pl’s counsel,,re: choose date for hearing $425.00 i.O $425.00 10/

as State Attorney of Palm Beach County, Florida: SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida. Defendants. - ' / DEFENDANT, DAVE ARONBERG’S MOTION FOR ATTORNEYS’ FEES Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and through the undersigned attorneys, moves

ingent, wherein obfaining a fee was conditioned upon prevailing and obtaining a:n orderawardingf ees. JUSTIFICA TIONFORMUL TIPLIER 30. Defendant Aronbergwas able to proceed with this.liti$ation only if counsel would receive a court cm!er a.ward1ng contmgency ba.s.ecl ~ltwneys' fees upon achi_e:ye111_ept

ieffromito2.5. Standard Guaranty Insurance Co. V. Quanstrom, 555 So. 2d 828. 834 (Fla. 1990). ThuSj based upon all ofthe; foregoingfactors, Defendant Aronbergrespectfully submits that amultiplier of2.0 isappropriatcforthisrcprcscntaiion. CERTIFICATIONOFGOODFAHHEFFORTTORESOLVE The undersigned certifies that a good faith

lleto £Palm BeachC01.infy,Floricia .. Defendants·. CASEJ-.r.0.: 19-CA-0.14681 j DEFENDANT,DAVEARONBERG'SMOTiONFORA TIOR.t~YS'FEES Defendant, DA VE ARONBERG,-as State Attorney o'f Palin Bea.ch Gounty1 Fforida1 by and through the undersigned atforneys, moves the Court, pursuant to Florida Statutes, Section 57

cution ofthecivil or criminal case and for no otherpurpose whatsoever. Moreover, even ifthe Plaintiff were to prevail in the declaratory’ action, Mr. Aronbergwould be unable to comply with any court order granting disclosure of the requested documents because neither Mr. Aronberg nor The Office of the State Atto

: me-dia response Spoke wi client, re: media response Spoke w/client, re: rnedia response Spoke ,w/'client, re: _media response· Sent e111c1il w/ Aronberg siaterrient to media D_i$Ct1~e.d media.re~ponsew/ DAW Di~~ssed media,respo11se w/ AIJ ... ·: $425:oo .. ; . ~ • . ! $475.06 $425.00 ,. :-.·.· $425.00

etting MTDismiss he<!rir'lg for fylarch 24,. 2020 Revie~ied Pl's Opposition to Aronberg MTDismiss & Glerk's MTDismiss .Reviewed ~rs Opposition to Aronberg MT Dismiss & Clerk's MTDi.smiss 'Reviewed ·e·mail. from Pl;s counsel, re: rTiotf9n io continue hearing Review.ed Pl's unopposed motion for continuance ... ,

; or b. Would hot be supported by the application of then-existing law to those material facts. Today, Judge Marx granted, with prejudice.. Defendant Aronbergps Motion to Dismiss Count II of the Plaintiff’s Complaint; Pursuant to the Court’s ruling, the Plaintiffs only remaining cause of action consists of Co

)thcfee,orratcoflee, customarilychargcdinthc localityforlcgalscrviccs bfacdrilparableofsimilar nature The base fees consisting of $425.00/hour forMr, Wyler’s services and $475.00/hour for Mr, Jacobs’ services are reasonable. for lawyers in their respective communities, possessing equal expcricnccandskill

F THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CA FLORIDA HOLDINGS, LLC, I Publisher of the PALM BEACH POST, Plaintiff, V. DA VE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida. Defendants. I -------

POST, in the amount of $39,950.00. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing Defendant, Dave Aronberg’s Amended Motion for Attorneys’ Fees has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein. 11 CA/

0 10/20/2020 AU Meeting Discussed Pl's settlement proposal w/ DAW $475.00 0.2 $95.00 10/21/2020 DW Various Drafted and filed Motion to Set Hearing on Aronberg MSJ; drafted proposed order granting motion to set; checked court availability; emailed Pl’s counsel, re: choose date for hearing $425.00 1.0 $425.00 10/

020 DW Review Reviewed Pl's Opposition to Aronberg MTDismiss & Clerk’s MTDismiss $425.00 1.5 $637.50 03/13/2020 AU Review Reviewed Pl's Opposition to Aronberg MTDismiss & Clerk’s MTDismiss $475.00 0.7 $332.50: 03/18/2020 DW Teleconference Reviewed email from Pl’s counsel, re: motion to continue hearing $425.00 0.1 $4

nference Spoke w/ client, re: order setting MTDismiss hearing for March 24, 2020 $425.00 0.5 $212.50 03/13/2020 DW Review Reviewed Pl's Opposition to Aronberg MTDismiss & Clerk’s MTDismiss $425.00 1.5 $637.50 03/13/2020 AU Review Reviewed Pl's Opposition to Aronberg MTDismiss & Clerk’s MTDismiss $475.00 0.7

ate of fee, customarily charged in the locality for legal services of a comparable or similar nature The base fees consisting of $425.00/hour for Mr. Wyler’s services and $475.00/hour for Mr. Jacobs’ services are reasonable for lawyers in their respective communities possessing equal experience and skill

June 23, 2020 Douglas A. Wyler Jacob Scholz & Wyler, LLC 961687 Gateway Blvd Suite 201-1 Fernandina Beach, Fl. 32034 Re: CA Florida Holdings, LLC v. Dave Aronberg et al. Case No, 2019-CA-014681 Dear Mr. Wyler: We are in receipt ofyour letter ofJune 8,2020 with your proposed Fla. Stat, section 57.105 motion. In

LLC 961687 Gateway Blvd Suite 201-1 Fernandina Beach, Fl. 32034 Re: CA Florida Holdings, LLC v. Dave Aronberg et al. Case No, 2019-CA-014681 Dear Mr. Wyler: We are in receipt ofyour letter ofJune 8,2020 with your proposed Fla. Stat, section 57.105 motion. In your letter and your proposed motion, you asse

IEENTH JUDICIAL CIRCUIT • • IN~ FOR PALM BEACH COUNTY, FLORIDA:. • CA FLORIDA HOLDINGS, LLC, Publisher ·Of THE PALM BEACH POST, Plaintiff, \!. DA VE ARONBERG, as Stat~ Attom~y o.f Palm Beach County, Florida, SHARON R BOCK, as Clerk & Comptroller, Palm Beach County, Florida, Defendants. ______________

has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein. JACOBS SCHOLZ & WYLER, LLC /s/Douglas A, Wyler Arthur I. Jacobs, Esq. Fla. Bar No,: 10249 Richard J. Scholz, Esq. Fla. Bar No.: 0021261 Douglas A. Wyler, Esq. Fla. Bar No.: 119979 961687 Gateway B