Epstein Secrets

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 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

re same; follow up on setting UMC hearing on S. Rothstein's Motion to Dismiss; work on hearing folder; pre

, 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

re same; follow up on setting UMC hearing on S. Rothstein's Motion to Dismiss; work on hearing folder; pre

, 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