, 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

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

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

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 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

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

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