Epstein Secrets

B. Edwards' Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; prepare Affidavit of T. Campbell re chain of custody of disc; prepare Notices of Filing Affidavits of T. Campbell and T. Chinaris; work on schedule of motions to be heard; communi

nications with D. Indyke and J. Epstein re same; follow up on hearing schedule; trial team meeting with J. Goldberger, M. Goldberger, J. Caldwell, T. Campbell, R. Glasser and K. Rockenbach re trial work, hearing preparations and strategies; work on objections to B. Edwards' deposition designations 03/01

th opposing counsel re hearing and production of audio; work on chronology; begin reviewing new public records 03/01/18 KBR Prepare objections to B. Edwards' deposition designations and consider counter-designations; attend trial team strategy meeting; prepare/revise motion to redact names and alter tri

ork on Discovery Chart of B. Edwards' discovery requests directed 7.00 1,575.00 to J. Epstein and J. Epstein's responses 225.00/hr LD Work with T. Campbell to assemble a discovery package to be 0.50 112.50 provided to Gunster team 225.00/hr Work on finalizing comprehensive Appendix in support of our

e page/line damage summary re B. Edwards deposition 1.10 434.50 testimony dated March 23, 2010 395.00/hr AMM Prepare page/line damage summary re B. Edwards' deposition 0.80 316.00 testimony dated May 15, 2013 395.00/hr 11/8/2017 TLC Continue working on preparations for B. Edwards' deposition; work

s depositions; communicate with D. Indyke, C. Pugatch and J. Goldberger re same 07/18/18 DMS [No Charge - getting up to speed on case] Work with T. Campbell to obtain case-specific factual and procedural background, in preparation for drafting and preparing Written Opening Statement in connection with

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li

s depositions; communicate with D. Indyke, C. Pugatch and J. Goldberger re same 07/18/18 DMS [No Charge - getting up to speed on case] Work with T. Campbell to obtain case-specific factual and procedural background, in preparation for drafting and preparing Written Opening Statement in connection with

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li