Epstein Secrets

e-mail to M. Nurik re setting UMC hearing on S. Rothstein's Motion to 4.80 1,080.00 Dismiss; prepare Not

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

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/CO

ds must show that Epstein's filing of his abuse of process claim against him — which is the gravamen of Edwards' abuse of EFTA00582880 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Response in Opposition to Edwards' M/Dismiss Amended Complaint process claim against Epste

plaint. Until Epstein files a new complaint, there is simply no predicate for seeking punitive damages based upon Epstein's abuse of process claim. B. Edwards' Proffer Lacks the Requisite "Reasonable Basis" for Punitive Damages - 7 - EFTA00582886 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800

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

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

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

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

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

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

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

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