# Profoundd archive — Epstein Files # Bates number: EFTA00799106 # Title: Deutsche Bank # Dataset: 9 # Pages: 39 # Images: 39 detected # Tags: epstein, doj, dataset-9, image-described # Source PDF: https://profoundd.com/epstein-docs/EFTA00799106/download # Doc viewer: https://profoundd.com/epstein-docs/EFTA00799106 # # Text below is what Profoundd has extracted from the source PDF. # 'ocr-enriched' tag means OCR was applied to scan-only pages. # Image descriptions are AI-generated factual captions (llava:13b). #---------------------------------------------------------------------- === SUMMARY === Deutsche Bank Wealth Management Wire Confirmation The wire transfer request below has been transmitted successfully. Transmitted: 05/03/2018 12:46:04 PM (ET) Transmitted By: BELLAKLEIN Account Template Name Recipient Name Amount Currency Effective Date Confirmation Number Approval Status Jeffrey Epstein - NOW - '9691 JEE to Link and Rockenbach PA Link and Rockenbach, PA. 142.908.11 USD 05/03/2018 1228598073 1 of I received EFTA00799106 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00 === EXTRACTED TEXT === Deutsche Bank Wealth Management Wire Confirmation The wire transfer request below has been transmitted successfully. Transmitted: 05/03/2018 12:46:04 PM (ET) Transmitted By: BELLAKLEIN Account Template Name Recipient Name Amount Currency Effective Date Confirmation Number Approval Status Jeffrey Epstein - NOW - '9691 JEE to Link and Rockenbach PA Link and Rockenbach, PA. 142.908.11 USD 05/03/2018 1228598073 1 of I received EFTA00799106 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 Matter Date Bill Number/Description 0001 - Bradley Edwards 10/24/17 1 49,985.00 49,985.00 10/24/17 Earned Non-Refundable Fee 49,985.00 0.00 11/06/17 32937 / Initial Bill from Time Slips 194,971.50 194,971.50 11/13/17 Payment Inv. No. 32937 from Time Slips 194,971.50 0.00 12/11/17 2 / Initial Bill from Time Slips Bill # 32942 257,198.13 257,198.13 12/11/17 Payment In. No. 32942 from Time Slips 257,198.13 0.00 12/31/17 9 219,076.50 219,076.50 01/09/18 WT / Wire Transfer 150,000.00 69,076.50 01/31/18 Applied to 9. 69,076.50 0.00 02/01/18 84 279,560.88 279,560.88 02/27/18 Wire Transfer Invoice #84 279,560.88 0.00 03/05/18 226 226,888.08 226,688.08 04/03/18 Applied to 226. 226,688.08 0.00 04/06/18 396 392,908.11 392,908.11 04/24/18 180424129069 / Applied to 396. 250,000.00 142,908.11 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, FL 33401 561-727-3600 Tax ID No. 82-3083928 May 3, 2018 Statement Bill Amount Paid Amount 0002 Running Balance Matter Balance Due Total Balance Due So EFTA00799107 taLINK & ROCKENBACH, ■. CIVIL TRIAL & APPELLATE LAW Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank, N.A. Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: Beneficiary Name: Link & Rockenbach, P.A. Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 T 561.727.3600 F 561.727.3801 EFTA00799108 From: Darren IndykS1 Subject: Fwd: Balance Due Date: May 3, 2018 1 To: Richard Kahn Cc: Darren Indyke Jeffrey said ok to pay this balance on the April Invoice for March time. Do you have the invoice or shall I send again. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York New York 10 The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - 2018 Darren K. Indyke, PLLC — All rights reserved. Begin forwarded message: From: "Paul V. DeVito" ‹ > Subject: Balance Due Date: May 3, 2018 : : T To: Darren Indyke < > Good morning Mr. Indyke. I have attached a copy of Mr. Epstein's Statement showing a balance due of $142,908.11. I have also attached wire transfer instructions for your reference. Please let me know if you need any additional information. Thank you very much for your help. LIR CIVIL TRIAL & APPELLATE LAW LINK& ROCKENBACH, PA Paul DeVito Bookkeeper Billing Coordinator LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach.FL 1 EFTA00799109 ILIRCIVIL TRIAL & APPELLATE LAW LINK& ROCKENBACH 9 PA April 10, 2018 Via Email leevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, 83 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 TEL (561) 727-3600 I FAX (561) 727-3601 Attached please find our firm's billing statement for services rendered through March 31, 2018. I have carefully reviewed this statement and as a courtesy to you, I reduced the bill in the amount of $12,190.00 ($100.00 x 121.9 hours). The line items beginning with "No Charge" reflect an additional reduction in the amount of $20,393.50 making the total reduction $32,583.50. Please do not hesitate to call me if you have any questions regarding this bill. Thank you. Very truly yours, Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment EFTA00799110 irt LINK & ROCKENBACH, P.A. CIVIL TRIAL & APPELLATE LAW Wire Transfer Instructions Wire Transfer to: Wells Fargo Bank, N.A. Routing No. / ABA No.: 121000248 Address: 420 Montgomery San Francisco, CA 94104 Beneficiary Account No.: Beneficiary Name: Link & Rockenbach, P.A. Address: 1555 Palm Beach lakes, Blvd. Suite 301 West Palm Beach, FL 33401 Additional Information: Operating Account 1555 Palm Beach Lakes Blvd., Suite 301 Went Palm Beach, Florida 33401 T 561.7273600 F 561.727.3601 EFTA00799111 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, FL 33401 561-727-3600 Tax ID No. 82-3083928 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services Hours April 6, 2018 Invoice # 396 Amount 03/01/18 RJG Attend team meeting re trial plan 1.00 395.00 03/01/18 RJG Research assertion of constitutional privileges against self-incrimination in civil cases, waiver of same, assertion of privilege in discovery, in preparation for drafting Response to Edwards' Motion to Compel Response to Request for Admissions 2.10 829.50 03/01/18 RJG Continue drafting/revising Response in Opposition to 2.10 829.50 B. Edwards' Motion to Compel Response to Request for Admissions 03/01/18 RJG Begin updating research on malicious prosecution/elements and recent case law in preparation for trial 1.90 750.50 03/01/18 RJG Review/analyze B. Edwards' Motion for Separate 0.80 316.00 Trials or, in the Alternative to Adjust the Order of Proof, in preparation for drafting response 03/01/18 RJG Begin researching bifurcation of trial/eleventh-hour request, in preparation for drafting response to B. 0.60 237.00 Edwards' Motion for Separate Trials 03/01/18 AMP [No Charge] Update hearing transcripts binder and prepare updated index for same 2.00 0.00 EFTA00799112 Client Ref: 0002 - 0001 Invoice # 396 Date 03/01/18 SJL Services Work on issues relating to disclosure of key e-mails; work on Notice/Appendix of same; work on Motion for Court's Permission to Alter Trial Evidence; multiple telephone conferences and communications 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 03/01/18 TLC Continue working on itemizing all key emails and public records located on witnesses on Clerk's Trial Exhibit List; work on culling out key emails to disclose to Court; work on trial exhibits; work on Appendix of key e-mails; work on confidentiality issues; follow up with 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 trial exhibits; work on Response to B. Edwards' Motion to Compel Response to Request for Admissions re sex offender registry's authenticity and accuracy; analyze B. Edwards' proposed Juror Questionnaire and email J. Scarola for Word version in order to edit; work on same 03/01/18 PVD [No Charge] Work on preparation of Trial Exhibits 03/02/18 RJG Continue researching bifurcation of trial, 11th-hour request, bifurcation as waste of judicial resources, bifurcation where claim and counterclaim are interrelated and waiver of bifurcation 03/02/18 RJG Research pre-trial stipulations as binding on parties and the court and strictly enforced; stipulation to consolidated trial; order and scope of proceedings/whether counterclaim can proceed first 03/02/18 RJG Begin drafting Response to B. Edwards' Motion for Separate Trials or, in the Alternative to Adjust Order of Proof Hours April 6, 2018 Page 2 Amount 12.80 9,600.00 14.80 3,330.00 8.20 6,150.00 7.50 0.00 3.20 1,264.00 2.90 1,145.50 3.30 1,303.50 EFTA00799113 Client Ref: 0002 Invoice # 396 Date - 0001 Services Hours April 6, 2018 Page 3 Amount 03/02/18 KBR Work on trial preparations; work on trial exhibits; work on Motions for Permission to Alter Trial 5.50 4,125.00 Evidence and Rule of Judicial Administration 03/02/18 TLC Work on summary of all litigation, arrests and sheriff reports for S. Rivera, T. Miller and C. Wild to include 14.50 3,262.50 In Motion to Alter Evidence; work on same; work on Notice of Filing Appendix in Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence; work on hearing needs; follow up on V. Roberts' audio tape; prepare Notice of Cancellation of Hearing; work on Clerk's Trial Exhibit List to identify each item individually 03/02/18 SJL Continue working on Notice of Filing Appendix in 12.80 9,600.00 Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence; address confidentiality concerns; multiple communications with D. Indyke and J. Epstein re same; work on two Motions to Alter Evidence; communications with potential jury selection consultants; work on opening statement; work on trial strategies; follow up on audio tape of V. Roberts 03/02/18 PVD [No Charge] Work on preparation of 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 5,475.00 EFTA00799114 Client Ref: 0002 - 0001 Invoice # 396 Date 03/03/18 TLC Services Hours Work on preparations for hearing on all outstanding 10.00 motions: (1) Epstein's Motion for Case Management Conference, (2) Edwards' Motion for Separate Trials; (3) Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence, (4) Edwards' Motion in Limine to Limit Introduction of Evidence Alleged to Support Epstein's Claims Against Edwards; (5) Epstein's Motions for Permission to Alter Evidence; (6) Epstein's Motion for Protective Order and in Limine of Unrelated Settlements; (7) Edwards' Second Motion to Lift Confidentiality; (8) Edwards' Motion for Adverse Inference; (9) Edwards' Motion in Limine Scope of Admissible Evidence; (10) Epstein's Motion to Strike Damages Expert; (11) Edwards' Motion in Limine Addressing the Admissibility of Edwards' Exhibit 132; (12) Epstein's Motion in Limine re Sex Offender Registry; (13) Epstein's Motion in Limine on Edwards' Newly Disclosed Exhibits; (14) Epstein's Request for Judicial Notice; and (15) Objections to Deposition Designations; assemble hearing notebooks and materials for each; pull authorities and prepare indices where needed; work on sequence list of motions; prepare Notice of Hearing and letter to judge; work on Response to Motion to Compel re Request for Admissions; work on assembling unredacted set of evidence and serve same 03/03/18 RJG Review/Analyze B. Edwards' Supplement to Motion 2.90 for Separate Trials or, in the Alternative to Adjust Order of Proof, and case law cited therein; revise Response in Opposition to Motion for Separate Trials, etc., to address Supplement; revise response per partners' suggested changes 03/03/18 RJG Legal research when case is "at issue" and propriety 1.60 of clerk's default v. judge's default; revise Response in Opposition to B. Edwards' Motion for Separate Trials to Include "at issue" argument 03/03/18 KBR Work on preparations for trial; work on Motion to 7.30 Remove Case from Trial Docket in compliance with Florida Rule of Civil Procedure 1.440; work on Response to B. Edwards' Motion to Severe; conduct legal research on appellate vehicle should the Court grant B. Edwards' Motion to Severe April 6, 2018 Page 4 Amount 2,250.00 1,145.50 632.00 5,475.00 EFTA00799115 Client Ref: 0002 - 0001 Invoice # 396 Date Services 03/04/18 TLC Continue working on itemized Clerk's Trial Exhibit List; work on Objections to Deposition Designations; prepare Motion for Default and Default Judgment against S. Rothstein; work on timeline for Response to Motion to Severe; work on issues relating to production of disc; work on marking trial exhibits 03/04/18 KBR Continue working on trial preparations; continue working on Response to B. Edwards' Motion to Severe and Motion to Strike from Trial Docket; conduct further legal research on appellate options 03/04/18 PVD [No Charge] Work on preparation of Trial Exhibits 03/05/18 RJG Revise Response in Opposition to Edwards' Motion for Separate Trials per partners' suggested changes; insert/address timeline 03/05/18 AMP [No Charge] Prepare binder re J. Epstein's Notice of Filing of Redacted Appendix in Support of Response in Opposition to B. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence 03/05/18 AMP [No Charge] Prepare packet regarding J. Epstein's Motion in Limine as to Sex Offender Registry Information 03/05/18 RJG Research mandamus as proper vehicle to enforce time restrictions for setting of a trial; requirements for mandamus relief; begin drafting proposed emergency relief Petition for Writ of Mandamus 03/05/18 TMB (No Charge] Finalize letter to T. Chinaris re packet of exhibits 03/05/18 RJG Review/analyze B. Edwards' Motion in Limine to Limit Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards and accompanying J. Epstein deposition. excerpts; conduct preliminary research in preparation for drafting response Hours April 6, 2018 Page 5 Amount 9.70 2,182.50 9.00 6,750.00 10.50 0.00 1.00 395.00 1.00 0.00 0.40 0.00 2.50 987.50 0.10 0.00 2.50 987.50 EFTA00799116 Client Ref: 0002 - 0001 Invoice # 396 Date Services Hours April 6, 2018 Page 6 Amount 03/05/18 TLC Work on Clerk's Trial Exhibit List; finalize and file same; work on organizing and marking trial exhibits; work on Motion for Default; work on J. Epstein's 13.50 3,037.50 Motion to Remove Case from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440; work on Response to B. Edwards' Motion for Separate Trials; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special Master; work on assembling authorities and hearing folder for our Motion to Remove Case from Trial Docket; telephone conference with trial support; follow up with D. Vitale re proposed Order from hearing on our Motion for Protective Order re settlements; follow up with J. Scarola's assistant re unilateral setting of hearings and request for cancellation; work on hearing folder on our Response to B. Edwards' Motion for Separate Trials; assemble authorities for same; prepare Notice of no objection to sealing records until Court makes determination 03/05/18 SJL Multiple communications with J. Scarola, P. Cassell, 11.20 8,400.00 D. Indyke and J. Epstein re production of emails and treatment / alleged improperly obtaining privilege documents; work on Motion to Strike from Trial Docket; work on Response to B. Edwards' Motion to Severe; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, etc.; work on preparations for special set hearing and addressing outstanding Order on settlement issues; work on proposed sequence of Motions 03/06/18 TMB [No Charge] Draft Petition for Writ of Certiorari shell 0.20 0.00 03/06/18 TMB (No Charge] Work on Appendix to Petition for Writ of 0.10 0.00 Certiorari shell 03/06/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00 Treatment per Fourth District Court of Appeal's Administrative Order 03/06/18 TMB [No Charge) Work on Affidavit for T. Chinaris 0.20 0.00 EFTA00799117 Client Ref: 0002 Invoice # 396 Date - 0001 Services Hours April 6, 2018 Page 7 Amount 03/06/18 RJG Continue drafting/revising proposed Emergency 5.30 2,093.50 Petition for Writ of Mandamus in preparation for trial court denying Motion to Strike Case from Docket 03/06/18 RJG Revise proposed Emergency Petition for Writ of 1.90 750.50 Mandamus per partners' suggested changes; verify all citations 03/06/18 RJG Review pleadings/timeline for statement of facts section of proposed Emergency Petition for Writ of 1.30 513.50 Mandamus 03/06/18 TLC Work on analysis of Farmer Jaffe Privilege Log; work on Notice of No Objection to Sealing Records; work on Response to B. Edwards' Motion to Strike J. 14.00 3,150.00 Epstein's Untimely Supplemental Exhibits; work on trial exhibits; prepare letter to judge with additional hearing submissions; work on Notice of Hearing 03/06/18 SJL Work on issues surrounding production of 27,000 page email disc; multiple communications with P. 13.00 9,750.00 Cassell; follow up with client re position; work on Response to Motion to Strike J. Epstein's Untimely Supplemental Exhibits; work on Petition for Writ of Mandamus 03/06/18 KBR Work on Petition for Writ of Mandamus; work on 10.00 7,500.00 Affidavit of T. Chinaris; communications with T. Chinaris re same; work on trial preparations; work on preparations for special set hearing on all pending Motions; work on Response to Motion to Strike J. Epstein's Untimely Supplemental Exhibits 03/06/18 PVD [No Charge] Work on procuring documents considered to be privileged materials at issue in B. 7.50 0.00 Edwards' Motion to Strike J. Epstein's Untimely Supplemental Exhibits 03/07/18 RJG Review/analyze/research B. Edwards' Motion in 2.10 829.50 Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards;draftlrevise Response to same 03/07/18 TMB [No Charge] Review Fourth District Court of Appeal's emergency treatment procedures in preparation for 0.20 0.00 Petition Mandamus EFTA00799118 Client Ref: 0002 - 0001 Invoice # 396 Date Services 03/07/18 TMB [No Charge] Review clerk's records regarding hearing on multiple motions on 3/8/18 and Order Resetting Trial in preparation for Motion to Stay 03/07/18 TMB [No Charge] Review Motion to Stay case - in preparation for potential appeal 03/07/18 RJG Finalize pending responses for 3/8118 Special Set Hearing; conference with partners re proposed Emergency Petition for Writ of Mandamus and other "emergency" filings to have in pipline; revise draft Mandamus Petition accordingly; review all case law citations in preparation for filing 03/07/18 TLC Work on trial exhibits; work on preparations for special set hearing; follow up with trial support; work on Objections to Deposition Designations; work on updating trial binders; work on Response to B. Edwards' Motion to Strike Epstein's Supplemental Exhibits and to Strike All Exhibits and Any Reference to Documents Containing Privileged Materials Listed on B. Edwards' Privilege Log; work on Response in Opposition to 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; communications with D. Indyke; prepare letter and package to Judge Hafele re additional hearing submissions; prepare letter to J. Scarola re delivery of disc; carefully review redacted appendix to see if we missed redacting any alleged victims' names as alleged by P. Cassell Hours April 6, 2018 Page 8 Amount 0.30 0.00 0.30 0.00 6.90 2,725.50 14.50 3,262.50 EFTA00799119 Client Ref: 0002 - 0001 April 6, 2018 Invoice # 396 Page 9 Date Services Hours Amount 03/07/18 SJL Work on Response in Opposition to B. Edwards' 12.30 9,225.00 Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; work on Affidavit of T. Campbell re chain of custody of disc; communications with T. Chinaris re Affidavit; work on Response in Opposition to B. Edwards' Motion in Limine to Limit the Introduction of Evidence Alleged to Support J. Epstein's Claims Against B. Edwards; work on Emergency Motion for Writ of Mandamus; telephone conferences with P. Cassell; review Cassell's filings and follow up on issues raised by same; communications with P. Cassell and J. Scarola re production of disc; communications with D. Indyke and J. Epstein 03/07/18 KBR Work on preparation for 3/8/18 hearings on 20+ 6.00 4,500.00 Motions/issues 03/07/18 PVD [No Charge] Work on chronology of privileged materials at issue 3.50 0.00 03/07/18 PVD [No Charge] Work on procuring transcript of hearing on 8/3/12 1.00 0.00 03/07/18 PVD [No Charge] Work on analysis of documents produced 1.00 0.00 03/08/18 TMB (No Charge] Work on Request for Emergency 0.20 0.00 Treatment pursuant to Fourth District Court of Appeal's instructions 03/08/18 TMB [No Charge] Prepare bookmark Appendix to Petition for Writ of Mandamus 0.40 0.00 03/08/18 TMB [No Charge] Review and revise Appendix to Petition for Writ of Mandamus 0.20 0.00 03/08/18 TMB [No Charge] Work on revisions to Appendix to 0.90 0.00 Emergency Petition for Writ of Mandamus and to Emergency Motion for Review of Order Denying Stay 03/08/18 TMB [No Charge] Work on Request for Emergency 0.20 0.00 Treatment EFTA00799120 Client Ref: 0002 - 0001 Invoice # 396 Date Services 03/08/18 TMB (No Charge] Work on revisions to Index to Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay 03/08/18 RJG Attend special set hearing before Judge Hafele re pending motions 03/08/18 RJG Draft/revise Emergency Motion for Review of Order Denying Stay to be filed in the Fourth District Court of Appeal 03/08/18 RJG Draft proposed order denying J. Epstein's Motion for Stay of Trial Proceedings 03/08/18 RJG Revise/finalize Emergency Petition for Writ of Mandamus to be filed in the Fourth District Court of Appeal 03/08/18 SJL Prepare for and argue at all-day special set hearing on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, Edwards' Motion to Strike Exhibits, and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files; follow up with client on outcome of hearing; follow up with Fowler White re issues surrounding disc; work on Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay 03/08/18 KBR Work on Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay; work on proposed Orders for hearing; prepare for and argue at all-day special set hearing on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, B. Edwards' Motion to Strike Exhibits and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files 03/08/18 TLC Prepare for and attend all-day special set hearing on pending Motions; work on Emergency Petition for Writ of Mandamus, Emergency Motion for Review of Order Denying Stay and Appendix to same; prepare proposed Orders on B. Edwards' Motion to Sever and J. Epstein's Motion to Strike from Trial Docket; follow up with trial support Hours April 6, 2018 Page 10 Amount 0.30 0.00 3.00 1,185.00 5.10 2,014.50 0.10 39.50 2.50 987.50 12.50 9,375.00 12.50 9,375.00 13.00 2,925.00 EFTA00799121 Client Ref: 0002 - 0001 Invoice # 396 Date Services 03/08/18 PVD [No Charge] Work on hearing binder preparation 03/08/18 PVD [No Charge] Work on deposition designations for W. Berger 03/08/18 PVD [No Charge] Work on preparation of Appendix for Emergency Petition for Writ of Mandamus 03/09/18 TMB [No Charge] Review Fourth District Court of Appeal's email and Order on filing fee owed and due in ten days; review Fourth District Court of Appeal's Acknowledgment of New Case 03/09/18 CWH [No Charge] Legal research and analysis of Florida authority and case law to determine whether general release and settlement agreement of a fee dispute can effectively waive the right to bring a malpractice claim against prior attorney 03/09/18 RJG Review 3/8/18 hearing transcript in preparation for drafting Emergency Petition for Writ of Certiorari 03/09/18 RJG Research/review/analyze case law on certiorari review and severance and bifurcation orders in preparation for drafting Emergency Petition for Writ of Certiorari 03/09/18 RJG Draft/revise Emergency Petition for Writ of Certiorari (as to circuit court's severance order) 03/09/18 RJG Draft/rev:se Motion to Consolidate extraordinary writ petitions filed in the Fourth District Court of Appeal 03/09/18 TLC Prepare letter to J. Hurley re evidentiary issues; prepare Notice of UMC hearing on Motion for Default against S. Rothstein; prepare letter and package to appellate clerk following up on filing of Petition for Writ of Liandamus; prepare e-mail to M. Nurik re hearing, on Motion for Default; update calendar re deadline for Response and Reply; work on reviewing Fowler ' ' :kris documents for paper trail of product' . work on Juror Questionnaire; follow up with K. Tarry re same; prepare proposed Order on Motion it Amine re Sex Registry; follow up with J. Scare' s:,ine; work on Order re settlement inform..niuri Hours April 6, 2018 Page 11 Amount 2.00 0.00 1.00 0.00 4.40 0.00 0.10 0.00 2.30 0.00 0.50 197.50 1.90 750.50 4.20 1,659.00 0.20 79.00 11.00 2,475.00 EFTA00799122 Client Ref: 0002 - 0001 Invoice # 396 Date Service• 03/09/18 SJL Work or• iror Questionnaire; work on Petition for Writ of c rtiorari Review of Order Severing Cases; work on : °paring for trial; meet with J. Goldberger re trial str- iies; e-mails communications with J. Scarola e production and trial issues; review P. Cassell's proposed orders; e-mail communications with P. Cassell re orders and his clients' position in the case; work on opening statement 03/09/18 KBR Work o tition for Writ of Certiorari Review; preps — itegy for consolidating with pending Petit! :Wit of Mandamus; consider strategy for Petiti, • 'frit of Mandamus and/or Certiorari regal' aim of privilege for e-mail documents 03/09/18 PVD [No C 4 Work on preparation of submissions to the C Court, Fourth District Court of Appeal for Eme' • Petition for Writ of Mandamus 03/09/18 PVD [No C' ' Review production seeking billing files for Fr . 03/09/18 PVD [No c Work on updating trial binders 03/09/18 PVD [No C Review Farmers' privilege log for emails 03/09/18 PVD [No C ' Review production for correspondence in rai , ;:ebruary 2011 re production of disc 03/09/18 PVD [No C f Reorganize files used from production recci n Fowler White 03/10/18 SJL Revi v 8 transcript re rulings on how to treat coat zy of documents; multiple e-mails (all day) with f 'Jell and J. Scarola re same; work on ways to re agreement; work on Emergency Petition for C' work on joint letter to court re sealing recor Hours April 6, 2018 Page 12 Amount 10.20 7,650.00 8.00 6,000.00 1.00 0.00 1.80 0.00 0.30 0.00 1.00 0.00 0.40 0.00 1.50 0.00 5.50 4,125.00 EFTA00799123 Client Ref: 0002 - 0001 Invoice # 396 Date Service. 03/10/18 KBR Legal r •-• rch regarding in camera review and Petitio: Nrit of Certiorari; multiple emails with P. Casse' ' 3carola, clerk of court and A. Bormai. neral counsel for 15th Judicial Circuit; review c line 15th circuit docket; review of Fourth Distric' t of Appeal docket; revise Petition for Writ of orari regarding grant of B. Edwards' Motion eparate Trials (severance) 03/10/18 RJG Draft "! wound" section for Petition for Writ of Certior :id revise petition to include trial court's multip' .rences to J. Epstein's original proceeding as bei :nesis" for B. Edwards' counterclaim 03/10/18 RJG Revir. s of Judicial Administration re sealing of rector( Jpellate court 03/10/18 RJG Reviev. yze correspondence from non-party intervel. ounsel re failure to caption them In filings with th nth District Court of Appeal 03/10/18 MLP [No Ct; ' Conduct legal research re computation of firm :ifically analyzing Florida Rule of Judicial Admin. on 2.514, Florida Rules of Appellate Procc :nd Florida appellate courts' opinions and case arding the same in order to determine the be! rse of action in terms of timing of the briefin, :dule pursuant to the Fourth District Court of Api: 3/9/18 order 03/11/18 TLC Work c ;embling documents to seal; prepare Notict :npliance, Notice of Filing disc under seal, . ;ice of Filing Exhibits under seal in order to pre. Ippeltate record; work on cleaning up heari: rs; review communications from P. Casst J. Scarola and our responses; review 3/8/11 Apt 03/11/18 SJL Work :es relating to Stay Order and sealing retort.: .k on Notice of Compliance; work on Petitic ;ertiorari review 03/11/18 KBR Work :es rein:ing to Stay Order and sealing recor 4 : on '-,g.": on for Certiorari review; follow up w' inar. . , compliance with destruction of docu , Hours April 6, 2018 Page 13 Amount 4.50 3,375.00 1.30 513.50 0.20 79.00 0.20 79.00 0.40 0.00 8.50 1,912.50 5.30 3,975.00 1.20 900.00 EFTA00799124 Client Ref: 0002 - 000' Invoice # 396 Date Servie' . 03/12/18 RJG Final preps Appe. 03/12/18 RJG Begin • - emery 03/12/18 RJG Corree agree- petiti. revisi 03/12/18 RJG Revic Respi filing i 03/12/18 RJG Revie draftir petit', 03/12/18 TLC Work recor sums. to J. I items Petiti( Cons• n v 3. Edwards' Response to Petiti. ;,.1:ndamus and Motion to Lift Stay; calct ,idnr deadlines relating to same; work I tc Motion; prepare letter to Fourth Distr ;. •' Clerk re same; continue revie ,'s boxes in order to determine chaii. ; and production by B. Edwt- exhibits Hours April 6, 2018 Page 14 Amount to Petition for Writ of Certiorari in the Fourth District Court of n",irence with partners re same 'analysis of B. Edwards' Response to nandamus petition ince with opposing counsel re their unopposed motion to consolidate writ ie Fourth District Court of Appeal and ' • , 'I .in D. Indyke re B, Edwards' mar lay ius petition in preparation for 1.90 2.60 0.20 0.20 750.50 1,027.00 79.00 79.00 8 herring transcript in preparation for 0.30 118.50 • ;0i'. Edwards' Response to mandamus m•; 'or UMC hearing re sealing rr 'n's timeline and prepare roduction dates; prepare e-mail mo• work on assembling appendix ..on or Certiorari review; work on ari Review and Motion to 11.30 2,542.50 03/12/18 SJL Prep. end hearing on proposed Order 9.50 7,125.00 seali 11 !S; follow up with J. Scarola on prod. s . v, .:lc on Petition for Writ of Ceri o. 'd Consolidate Petition for Writ of M I ;ion for Writ of Certiorari; revii ' 17 monse to our Petition for Man to Lift Stay; follow up with D. Indy Jo reviewing Fowler White's recur .;duction; follow up with J. Hurl( EFTA00799125 Client Ref: 0002 - 000 Invoice # 396 Date Servi 03/12/18 KBR Prep, •ten I hearing on proposed Order sealir orc ; nunc pro tune to 3/8/18; work on fin m f r Writ of Certiorari; work on Motio 'at( Petition for Writ of Mandamus and F rit c 1 Certiorari; follow up with P. Burlin .1osilion as to the consolidation; revik. ;s' Response to our Petition for Manr •otio.) to Lift Stay; work on Resp . km- ds' Motion 03/12/18 MLP [No' or .malysis of B. Edwards' privi.. zc in a workable format in order to co. ;st ed production in the case 03/12/18 PVD [No ( on )reparation of itemized log of em: m ;in Fowler White re "for alto. iy" 03/13/18 RJG Cor la: ;is of B. Edwards' Response to Petit M. ;Iamus and begin drafting Rep' 03/13/18 RJG Leg et. crime-fraud exception appf )ck t protection 03/13/18 RJG Cot el\ 19 Reply to Response to ma; element of case and facts) 03/13/18 TMB [No ot ppendix to Response in Opt •ar ' lotion for Partial Relief from Sta. 03/13/18 RJG Bec: III t section in Reply to B. Edt. . :e ! , mandamus petition 03/13/18 RJG Les. . ) 'p' ition that appellate courts dis. , ' c !'s written order simply states "for • .at( : on the record" 03/13/18 TLC Co. s f F ler White's boxes to cletun • rail c production of disc; work on Resp #ivw !s' Motion for Partial Relief froc ' )Ic mendix items; work on prii.. , an :-i Hours April 6, 2018 Page 15 Amount 5.30 3,975.00 6.00 0.00 5.70 0.00 3.40 1,343.00 0.70 276.50 1.60 632.00 0.40 0.00 2.30 908.50 1.00 395.00 12.50 2,812.50 EFTA00799126 Client Ref: 0002 - 00(` Invoice # 396 Date Servi( , - 03/13/18 KBR Work l nse to B. Edwards' Motion for Emery: ief from Stay, conduct legal research re Ho. ; of Judicial Administration 2.330 regard : al disqualification and timing 03/13/18 SJL Wor nse to B. Edwards' Motion for Partial Rei, /; work on document issues; multiple corn ; with client and opposing counsel; work Ise to Petition for Writ of Mandamus 03/13/18 MLP [No CI )rk on analysis and comparison of B. Edwa: • .ge log and assumed production in the case . ) deten.iine If any documents pro, conta••md on the privilege log 03/13/18 PVD [No ork on nreparation of Itemized log of em, ction 1; iin Fowler White re "for atto only" 03/13/18 PVD [No C :)rk on preparation of itemized log of env'''. ...;tion from Fowler White re "irrelevant em 03/13/18 PVD [No 'ork or. .paration of itemized log of ern:- • tespon.• a to Order Produced 5-7 03/14/18 RJG Co:- ' ng/revising Reply to Response to Em . %. ndamus Petition (argument section) 03/14/18 RJG Re . Di C 03/26/18 RJG R E C H in ,si 03/26/18 PVD (1% C 03/26/18 PVD int Hours April 6, 2018 Page 26 Amount : scripts binder 0.50 0.00 nrerences with Clerk of 0.30 0.00 Iccuments delivered to is' audio of telephone we with transcription for with D. lndyke, J. nberg; review B. 5.00 11.00 0.00 8,250.00 ' Order to Show nera Review; work jtion for Writ of spection; follow up 2.50 1,875.00 . preparations for -> lion for Status .2 'I District Court of 0.30 0.00 . :fix to Motion for t,sts ix to Second 0.20 0.00 .1 for Writ of ) Motion to Strike B. 0.30 118.50 'ection to B. ; -Ise Style; Motion to and Re-Notice of ,ion of scope of stay °eel for UMC hearing re 0.50 0.00 :dward's Motion for Roberts' audio m transcript; 4.80 0.00 EFTA00799137 Client Ref: 0002 - Invoice # 396 Date 03/26/18 TLC Sc IR( se Mc pn Or we C E W( Ai O 03/26/18 KBR Pi COS • Pt:n of J rt:: wet • )urt Ft, c ;MC he c. in to F on , :rt. • 3 I i. ....,.• .16 S t', lc! on ca Pc t 11 C. it • to 03/26/18 SJL Pi fu cc sr 9( rr S 03/27/18 RJG R O C 03/27/18 RJG C in 03/27/18 RJG R S S p 'Iministration re osed Order on our wifidential; work on 'ware proposed Inge Case Caption; if Petition for Writ of :mental Appendix; is and Costs and rk on proposed on B. Edwards' I the proposed [tempted to change .her support of < on Motion for In element to Motion id 3/6/18) ing on B. Edwards' irk on Reply in of Certiorari; id J. Epstein re work on strategies In Camera Review; How up with J. and rgument section of ')n for Order to ..:Id Not Be Held reshold for probable tion cases for review nce of Oorder to end J. Epstein _f Court (and case ackground in section of Hours April 6, 2018 Page 27 Amount 9.80 2,205.00 4.90 3,675.00 10.20 7,650.00 4.10 1,619.50 0.20 79.00 2.30 908.50 EFTA00799138 Client Ref: 0002 - Invoice # 396 Date Sr 03/27/18 PVD [N co In: 11,` "1 Jf draft inserts for • ' of V. Roberts' April 6, 2018 Page 28 Hours Amount 2.80 0.00 03/27/18 PVD [N rr . .'e se' to Judge Hafele re 0.20 0.00 Er c :esr .Vrit of Certiorari, St [: ,r n,.:ndix ', Motion for Al ' it•: , :.:.'s' Fee ppendix to Motion for Ar ays' Fec 03/27/18 PVD [N la,n Or: —ent binder for 0.50 0.00 R if :sponse; update at. .11 03/27/18 TLC W . 0 z! . Edwards' Motion to 8.80 1,980.00 S. .,. .erse Inference; th r ,c, .-e same; work on hr . t. and to J. Scarola's in ... _:.,: 1 for In Camera In on I .: ,,Idress Scheduling 8! III i sponse to B. Er It , Style 03/27/18 KBR W view to incorporate 3.30 2,475.00 D its; prepare Motion to .sionalism standards w expectations 03/27/18 SJL Al pr In Li! E Ispection; multiple 8.30 6,225.00 e inappropriate Motion to Jnalism; review Motion re Adverse 21 Exhibits; follow insurance policy; .idyke and J. 'rinse 03/28/18 RJG D .lition to Farmer 2.30 908.50 J. der to show cause - C ceding 03/28/18 PVD (N . , feting Oral 2.00 0.00 A. it of Certiorari re R .s re same EFTA00799139 Client Ref: 0002 Invoice # 396 - Date Sr 03/28/18 PVD [N ye pr ,r. -1. 03/28/18 KBR W ;.. Pr Mt ;≤. !I e ) 03/28/18 PVD [N bi 03/28/18 TLC W Ac RE Cf fill.• :: t), al ‘r. 03/28/18 PVD [N CC in J o 03/28/18 SJL V.' Pi M In fo Or a' V. 03/29/18 PVD [N. roduction chart to ry appear on duction uling and ie to B. Edwards' wring transcript )rk on Motion to nalism; work on ) Change Case nera Inspection; .1/44otion to Show for any further drafts; provide equest 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 0.70 0.00 EFTA00799140 Client === IMAGE DESCRIPTIONS === [Image 1] The image shows a document that appears to be a bill or invoice. It contains a list of items or services with corresponding dates, descriptions, and amounts. There are handwritten signatures at the bottom, indicating that the document has been reviewed or authorized by individuals. The visible text includes names, dates, and numerical figures, but the specific details are not clear due to the reso [Image 2] The image is a scanned document, specifically a receipt or invoice. It lists various expenses with corresponding dates, descriptions, and amounts. The document includes a header with the date and a footer with the total amount due. The visible text includes names, dates, and descriptions of the expenses, but the specific details are not clear due to the resolution of the image. [Image 3] The image appears to be a scanned document, specifically an invoice or bill. It contains a list of items or services with corresponding prices and totals. The document is structured with columns for dates, descriptions, quantities, unit prices, and total amounts. The visible text includes names, dates, and numerical figures, but no specific details about the content of the document are provided. T [Image 4] The image is a photograph of a printed document, which appears to be a financial or billing statement. The document contains a list of items or services with corresponding dates, descriptions, and monetary amounts. The visible text includes names, dates, and numerical figures, but the specific details are not clear enough to provide a precise description. The document is structured in a tabular fo [Image 5] The image shows a document that appears to be a financial statement or invoice. It lists various items with their respective dates, descriptions, and monetary values. The document includes columns for "Date," "Description," and "Amount." There are entries for different types of expenses, such as "Telephone," "Postage," "Travel," and "Miscellaneous," among others. The amounts are listed in a curren [Image 6] The image shows a document with a table of expenses. The table lists various expenses with dates, descriptions, and amounts in a currency that appears to be the Euro. The document is a financial statement or report, possibly related to a business or organization. The expenses are categorized into different types, such as "Travel," "Accommodation," "Food," and "Other." The amounts are listed in a c