Epstein Secrets

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

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

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

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

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

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

up on scheduling of deposition of Fowler White and Link & Rockenbach 07/06/18 SJL Work on Objections to Duces Tecum; multiple communication with D. Indyke 4.50 3,375.00 07/08/18 SJL Work on Response to S. Rothstein's Motion to 2.80 2,100.00 Dismiss; work on Objections to state court Duces Tecum

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

to B. Edwards' and Farmer Jaffe's Summaries of Damages; work on Response and Objections to Duces Tecum in state court action; communications with D. Indyke Continue working on Response to B. Edwards' and 3.50 787.50 Farmer Jaffe's Summaries of Damages to incorporate D. Indyke's thoughts and suggeste

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