Epstein Secrets

Trial Exhibits 7.50 0.00 03/03/18 SJL Work on Response to Motion to B. Edwards' Compel re Request for Admissions; strategize re default against S. Rothstein and options to proceed with trial or seek to strike trial setting; work on preparations for special set hearings; work on trial preparations 7.30

B. Edwards' Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; prepare Affidavit of T. Campbell re chain of custody of disc; prepare Notices of Filing Affidavits of T. Campbell and T. Chinaris; work on schedule of motions to be heard; communi

nications with D. Indyke and J. Epstein re same; follow up on hearing schedule; trial team meeting with J. Goldberger, M. Goldberger, J. Caldwell, T. Campbell, R. Glasser and K. Rockenbach re trial work, hearing preparations and strategies; work on objections to B. Edwards' deposition designations 03/01

11/8/17 hearing on Motion to Bifurcate based on 1.20 900.00 probable cause and overlapping facts of J. Epstein's abuse of process action against Rothstein in order to remove the "mini-trial" issue 750.00/hr AMM Analyze Volume I of II deposition transcript of B. Edwards (147 3.20 1,264.00 pages) da

ork on Discovery Chart of B. Edwards' discovery requests directed 7.00 1,575.00 to J. Epstein and J. Epstein's responses 225.00/hr LD Work with T. Campbell to assemble a discovery package to be 0.50 112.50 provided to Gunster team 225.00/hr Work on finalizing comprehensive Appendix in support of our

0.00 Summary of Damages; work on Response to S. Rothstein's Motion to Dismiss; work on strategies 07/05/18

s depositions; communicate with D. Indyke, C. Pugatch and J. Goldberger re same 07/18/18 DMS [No Charge - getting up to speed on case] Work with T. Campbell to obtain case-specific factual and procedural background, in preparation for drafting and preparing Written Opening Statement in connection with

2010, May 15, 2013, October 10, 13, and November 10, 2017, deposition transcripts and extrapolate testimony regarding communications/meetings with S. Rothstein to use to show B. Edwards may have been withholding information; review B. Edwards' filings and outlines for disclosure of number of pages produce

s depositions; communicate with D. Indyke, C. Pugatch and J. Goldberger re same 07/18/18 DMS [No Charge - getting up to speed on case] Work with T. Campbell to obtain case-specific factual and procedural background, in preparation for drafting and preparing Written Opening Statement in connection with