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

or Rehearing of 4th DCA Order denying appellate fees in Case No.18-087 05/04/18 SJL Work on Response to Motion for Sanctions; communications with D. Vitale re setting hearing on Motion to Extend Scope of J. Epstein's deposition; follow up with clients re same; review pending motions and strategize on

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

rporate D. Indyke's suggested edits; follow up with client and counsel on our side re same; prepare email to M. McCann re dates; prepare e-mail to D. Vitale re proposed Order 06/01/18 SJL Work on proposed order re J. Epstein's deposition to incorporate D. Indyke's suggestions; review hearing transcrip

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

tions with client and D. Indyke; review new authorities re waiver of work product; prepare for UMC hearing on case management; communications with D. Vitale re proposed sealing order, work on Motion to Maintain Case Style; follow up with J. lanno re Fowler White's Insurance policy 04/04/18 KBR Prepar

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

rporate D. Indyke's suggested edits; follow up with client and counsel on our side re same; prepare email to M. McCann re dates; prepare e-mail to D. Vitale re proposed Order 06/01/18 SJL Work on proposed order re J. Epstein's deposition to incorporate D. Indyke's suggestions; review hearing transcrip

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 •

assembling authorities and hearing folder for our Motion to Remove Case from Trial Docket; telephone conference with trial support; follow up with D. Vitale re proposed Order from hearing on our Motion for Protective Order re settlements; follow up with J. Scarola's assistant re unilateral setting of h