Epstein Secrets

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

whether a denial of writ petition without prejudice to appeal from final order Is a favorable disposition 05/09/18 KBR Conduct legal research re B. Edwards' citation to two cases as basis for conditional fee entitlement in certiorari proceeding; key cite cases and broaden search re 9.400 fee entitlemen

, 2018, dismissing mandamus petition as moot and denying both parties' fees); work on Response to B. Edwards' Motion for Hearing and Order denying B. Edwards' conditional entitlement to appellate fees; telephone conference with D. Indyke re Response, discussion re 9.400, discretion of appellate court, go

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

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

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 •

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