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

ork on Request to Produce and Interrogatories to B. Edwards re newly disclosed experts; prepare Notice of Production from Non-Parties and Subpoenas Duces Tecums directed to R. Josefsberg, C. Lichtman, S. Kuvin, T. Leopold, A. Horowitz, I. Garcia, E. Cote and W. Berger; work on Motion to Shorten Time to resp

on S. Rothstein's Motion to Dismiss; work on hearing folder; prepare Notice of Hearing, proposed Order and letter to Judge; work on redactions to V. Roberts' transcript (i.e., info required by rules to be redacted); work on Motion to Use Certified Transcript; work on updating To Do List 06/04/18 SJL Wo

, to Conduct Limited Deposition Discovery to incorporate additional suggestions by D. Indyke; work on Motion for Protective Order and Objection to Duces Tecums 06/20/18 TLC Work on preparations for two-day hearing on all pending motions; update hearing folders for same; follow up on new date for J. Epste

on S. Rothstein's Motion to Dismiss; work on hearing folder; prepare Notice of Hearing, proposed Order and letter to Judge; work on redactions to V. Roberts' transcript (i.e., info required by rules to be redacted); work on Motion to Use Certified Transcript; work on updating To Do List 06/04/18 SJL Wo

, to Conduct Limited Deposition Discovery to incorporate additional suggestions by D. Indyke; work on Motion for Protective Order and Objection to Duces Tecums 06/20/18 TLC Work on preparations for two-day hearing on all pending motions; update hearing folders for same; follow up on new date for J. Epste