Epstein Secrets

n hearing preparations for Fifth Amendment issues and 750.00/hr Omnibus Motion in Limine; review B. Edwards' 2011 summary judgment filings; review V. Roberts' litigation KBR Prepare for first of three special set hearings on pending motions (J. 12.50 9,375.00 Epstein's Omnibus Motion in Limine, B. Edwar

n proposed Orders and hearing packages; follow up on Objections to exhibits; work on Motion to Compel SJL Meeting with J. Epstein, J. Goldberger, D. Indyke and K. Rockenbach re strategies; work on Pre-Trial Stipulation and Motion for Continuance of Trial; work on preparations for B. Edwards' depositio

75.00 Hafele 750.00/hr 11/7/2017 TLC Work on Motion to Compel; follow up with T. Haddad re production 9.50 2,137.50 issues; communications with D. Indyke re production and status; continue working on assembling exhibits for B. Edwards' deposition; revise R. Critton's Affidavit and prepare Notice of F

Court strategies; work on Motion to Compel B. Edwards to identify Bates numbers of documents produced; work on Motion re filing certified copy of V. Roberts' interview 05/04/18 PVD [No Charge] Continue review of Clerk's Trial Exhibits for compliance 05/04/18 TLC Work on Response to Motion for Sanctio

torneys fees as civil contempt sanctions 05/24/18 TLC Work on Response to Motion for Sanctions; follow up with D. Indyke re review of same; review V. Roberts' interview transcript and changes made by court reporter after a further in-depth review; follow up with court reporter on same; prepare e-mail to

Proceeding; research recovery of attorneys fees as civil contempt sanctions 05/24/18 TLC Work on Response to Motion for Sanctions; follow up with D. Indyke re review of same; review V. Roberts' interview transcript and changes made by court reporter after a further in-depth review; follow up with cour

same (i.e., B. Edwards removed "continuing" from his instructions and is now only focused on Instituting" the litigation); review discrepancies in V. Roberts' transcribed interview, follow up on how to proceed with same 04/11/18 SJL Work on To Do List; telephone conferences with D. Indyke; review S. Ro

re Notice of Filing for same 04/23/18 SJL Work on Response to Motion to Take J. Epstein's 4.50 3,375.00 Deposition; multiple communications with D. Indyke re same; work on Response in Opposition to B. Edwards' Motion for Sanctions; follow up with C. Pugatch re discovery re Intervenors' alleged damag

wards' Motion to to B. Edwards' I< on Motion for In ;e to bankruptcy w up on insurance ounsel; Indyke; review ness binders tiers binder i of V. Roberts' UMC hearings set ange Case prepare Change Case alele re hearing Tig motions; work • •tork on proposed er and package to ng on Motion to •

quest ft edits for i V. Roberts' elineations for cling and e to B. Edwards' cork on Motion for reporter request; to proposed Order ions with D. Indyke no on Fowler .less binders Hours April 6, 2018 Page 29 Amount 2.30 0.00 0.50 375.00 0.40 0.00 9.70 2,182.50 1.20 0.00 7.40 5,550.00