# Profoundd archive — Epstein Files # Bates number: EFTA01118553 # Title: Fowler White Burnett 4, ATTORNEYS AT LAW / # Dataset: 9 # Pages: 12 # Images: 12 detected # Tags: epstein, doj, dataset-9, image-described # Source PDF: https://profoundd.com/epstein-docs/EFTA01118553/download # Doc viewer: https://profoundd.com/epstein-docs/EFTA01118553 # # 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 === Fowler White Burnett 4, ATTORNEYS AT LAW / Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 10065 (5S'0 iimadief ComPkii4 33SP 4. Ptiftidirc — UNA Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards and L.M. Espirito Santo Plaza Fourteenth Floor 1395 Stickel' Avenue Miami, Florida 33131 305.789.9200 main 305.789.9201 fax E.I. No. 59-1303994 vnvw.fowler-white.corn September 8, 2011 Page 1 Ref.: LAS-23869-080743.463407 Total Amount Due for this Invoice $ 106,187.50 Past Due S 83,7 === EXTRACTED TEXT === Fowler White Burnett 4, ATTORNEYS AT LAW / Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 10065 (5S'0 iimadief ComPkii4 33SP 4. Ptiftidirc — UNA Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards and L.M. Espirito Santo Plaza Fourteenth Floor 1395 Stickel' Avenue Miami, Florida 33131 305.789.9200 main 305.789.9201 fax E.I. No. 59-1303994 vnvw.fowler-white.corn September 8, 2011 Page 1 Ref.: LAS-23869-080743.463407 Total Amount Due for this Invoice $ 106,187.50 Past Due S 83,786.25 Total Due S 189,973.75 For Professional Services Through August 31, 2011 Date Description 07/27/11 Multiple e-mail communications with Jeffrey Epstein re: tactics and strategies on amending Complaint; multiple e-mail communications with Martin Weinberg, Esquire re: amending of Complaint, outstanding counterclaim; c-mail communications with Joseph Ackerman, Esquire and Lilly Ann Sanchez, Esquire re: abuse of process counterclaim, affirmative defenses, punitive damages 07/28/11 Receipt, review and analyze the deposition transcript of Mark Epstein, brother of Jeffrey Epstein re: future strategy and impact on case 07/29/11 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' Motion to Dismiss Plaintiff, Jeffrey Epstein's Amended Complaint 07/29/11 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' Motion for Leave to Assert Claim for Punitive Damages 07/29/11 Receipt and review of Order on Plaintiff/Counter-Defendant, Jeffrey Epstein's Motion for Leave to Use Documents Produced Under Confidentiality Agreement 07/29/11 Receipt and review of correspondence from Darren Indyke (x4) re: earliest available date through online scheduling with Judge Crow's division for the hearing on Edwards' Motion for Leave to Amend to Assert a Claim for Punitive Damages; draft correspondence to Darren Indyke (x3) re: sufficient notice for hearing 07/29/11 Receipt and review of correspondence from Brad Edwards rc: language and terms agreed for Settlement and Confidentiality Agreements; draft correspondence to Mr. Edwards re: same 07/29/1 I Receipt and review of Order on Plaintiff/Counter-Defendant, Jeffrey Epstein's Amended Motion for Protective Order Relating to Extra Judicial Statements served on May 2, 2011 07/29/11 Receipt and review of correspondence from Jeffrey Epstein to Brad Edwards (x4) re: edits to correspondence on settlement and offer issues, 57.105 claim; draft correspondence to Mr. Epstein (x4) rc: same; telephone conference with Mr. Epstein re: same 08/01/11 Review and respond to emails; review Orders and forward. 08/01/11 Begin drafting Response in Opposition to Motion for Leave to Amend to Assert a Claim for Punitive Damages. Atty Hours CEK 2.00 CEK 1.25 CEK 0.25 CEK 0.25 ± CEK 0.25 -- CEK 0.50 4. CEK 0.50 CEK 0.25 — CEK 0.50 LAS 0.25 - EI so 1.50 + Fowler White Burnett PA. EFTA01118553 Ref.: LAS-23869.080743-463407 September 8, 2011 Page 2 Date Description 08/01/11 Email from Marty Weinberg regarding Punitive Damage Issues; Emails from Jeffrey Epstein regarding 57.105, Punitive Damage Issues and settlement; Draft letter to Bradley Edwards (4); Work on Motion to Amend; Emails from J. Scarola regarding response to M. Weinberg; Emails to J. Scarola regarding hearing time and Jeffrey Epstein deposition (2); Emails to/from Darren Indyke regarding hearing on Amended Motion to Assert Claim for Punitive Damages (4) 08/01/11 Receipt and review of correspondence from Martin Weinberg re: decision on punitive damages being binding 08/01/11 Receipt and review of Supplement to Bradley Edwards' Proffer in Support of Motion for Leave to Amend to Assert Claim for Punitive Damages 08/02/11 Confer with Darren Indyke; review and forward numerous pleadings and pro hac vice application to Jay Lefkowitz' review and respond to emails; confer with CEK and JLA. 08/02/I 1 Review LM Court file and work on Amended Complaint; Phone call with Darren Indyke regarding new counsel and emails regarding same (11) 08/02/11 Receipt and review of correspondence from Jeffrey Epstein to Brad Edwards re: other edits to correspondence on settlement negotiations and 57.105 claim; draft correspondence to Mr. Epstein re: same 08/02/11 Telephone conference with Darren Indyke re: filing of the Second Amended Complaint; draft correspondence to Mr. Indyke (x4) re: no need for a Jack affidavit, need for Kirkland to file a notice of appearance and Pro Hac Vice motions; receipt and review of correspondence from Mr. Indyke re: motion to continue time to file amended complaint, amended complaint that was dismissed, Second Amended Complaint, Counterclaim by Edwards, and motion for punitive damages; draft correspondence to Mr. Indyke re: same 08/02/11 Telephone conference with Jeffrey Epstein re: bring in Kirkland & Ellis (Jay Lefkowitz) as Co-Counsel in the Rothstein/Edwards case, filing of the Second Amended Complaint, no need fora Jack affidavit, need for Kirkland to file a notice of appearance, Pro Hac Vice motions, motion to continue time to file Second Amended Complaint, Counterclaim by Edwards, and motion for punitive damages 08/02/11 Draft response in opposition to Edwards' motion for leave to assert punitive damages. 08/02/11 Conference call with Jay Lefkowitz re: summary of matter to date. 08/03/11 Review LM Court file for amending complaint (continued); Phone call with Marty Weinberg regarding Scarola/57.105 issues 08/03/I I Continue drafting response in opposition to Edwards' motion for leave to amend counterclaim to add punitive damages. 08/03/11 Work on Complaint amendments; Check status of A.J. Discala documents and emails regarding same (5) 08/03/11 Receipt and review of correspondence from Jonathon Etra re: Conrad Scherer's review and production of Discala documents in the Razorback litigation and getting additional AJ Discala documents; draft correspondence to Mr. Etra re: order to produce same; telephone conference with Mr. Etra re: same 08/04/11 Revise response in opposition to Edwards' motion for leave to amend to add punitive damages. Atty Hours JLA 2.00 + CEK 0.25 4- CEK 0.75 -f - LAS 1.00 — JLA 3:5ft • CEK 0.50 — CEK 0.50 0 CEK 1.00 0 HSG 7.00 t LAS 0.75 JLA 3\.tk 6 HSG JLA fr5 • CEK 0.50 ..-- FISG 4.50+ Fowler White Burnett P.A. EFTA01118554 Ref.: LAS-23869-080743-463407 September 8, 2011 Page 3 Date Description Atty Hqurs 08/04/11 Telephone conference with Jeffrey Epstein re: Second Amended Complaint, changes CEK 40 • and/or additions thereto and hearing on Motion to Dismiss; telephone conference with Mr. Epstein, Marty and Lefkowitz re: same; receipt and review of correspondence from Mr. Epstein re: Scarola tainting brad forever by calling him a crook in open court and the co-conspirator of Rothstein; draft correspondence to Mr. Epstein re: same; receipt and review of correspondence from Mr. Epstein re: A federal appeals court has revived an abuse of process suit against a law firm and lawyer that allegedly used unfair tactics in litigation; draft correspondence to Mr. Epstein re: same 08/04/I I Receipt and review of correspondence from Darren Indyke re: draft response to the CEK 0.25 + motion for punitive damages along with the abuse of process cases within which we could fit an amended complaint; draft correspondence to Mr. lndyke re: same 08/04/11 Emails regarding settlement (17); Discussions/strategies (II); Emails and phone calls JLA 3.50 + from Marty Weinberg and L. Holman regarding Limited Appearance (6); Emails regarding Complaint and Amended Motion to Assert Claim for Punitive Damages (10); Review draft of same; Emails regarding Second Amended Complaint (7) and work on same; Emails from J. Scarola regarding deposition in September; Emails regarding A.J. Discala production (4) 08/04/11 Review and respond to emails; pull documents and forward to Jay Lefkowitz. LAS 1.00 08/05/11 Legal research for draft of Second Amended Complaint; Continue to work on JLA 3,Q0.o Amendments to Complaint; Review Court files (continued) fo Complaint; Emails to/from Darren Indyke (2); Emails to/from regarding Amended Complaint (5); Emails to Darren lndyke, c rey ps cm and Jay Lefkowitz with Amended Complaint; Emails from/to Jeffrey Epstein (s); Motion for Enlargement of Time for Complaint 08/07/11 Emails to/from Jay Lefkowitz regarding Amending Complaint and Motions Directed to JLA kL0 w Counterclaim and Proposal for Settlement (6) 08/08/I 1 Review and advise regarding Second Amended Complaint; review Gen. Refractories HSG i‘.25 case noted in J.E. e-mail and federal proceedin s in connection with same. 08/08/11 Email from Jeffrey Epstein; Emails to/from (4); Emails to/from Jay JLA Lefkowitz (4); Continue to work on Amende omp am and research regarding same; Phone call with Darren Indyke regarding Motion to Extend Time regarding Complaint 08/09/11 E-mail communications with Joseph Ackerman, Esquire re: proposed Motions to file, CEK 0. Amended Complaint and response to Counterclaim 08/09/11 Emails regarding Amended Complaint (3) fr m Da en Ind ke; Review draft correction JLA 08/10/11 Review Critton case files; Conference with regarding same; Prepare JLA and revise Motion for Enlargement of Time regar ing omplaint and Notice of Hearing; Conference with Mike Pike and Bob Critton; To courthouse to review case files; Phone call with Darren Indyke; Email from Darren Indyke 08/11/11 Telephone conference with Jeffrey Epstein re: status of matter CEK i(39 ° 08/11/11 Emails to/from Darren Indyke regarding amending complaint (4); Email from Jack JLA 2.00 Scarola regarding complaint and emails regarding same (2); Reset depositions regarding Wackenhut deponents and emails regarding sa • Pmn Maxine Streeter regarding Discala documents (2); Emails to/ from 08/11/II Continue preparation of new complaint and legal research regarding same JLA \2.25„._• Fowler White Burnett P.A. EFTA01118555 Ref.: LAS-23869-080743-463407 September 8, 2011 Page 4 Date Description Atty urs 08/12/11 Telephone conference with Joseph L. Ackerman, Esquire re: status of Second Amended CEK 300 s Complaint and positions to be taken by Plaintiff; anticipated positions to be taken by Jack Scarola, Esquire; e-mail communications with Joe Ackerman re: Scarola's desire to depose G. Maxwell., H. Rubenstein, A. Cordero and A. Dershowitz; preparation for telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, Esquire, Jay Lekfowitz, Esquire and Roy Black, Esquire 08/12/11 Draft motion for partial summary judgment regarding Counterclaim and review HSG 5.25 — authorities in connection with same. 08/12/11 Prepare memo for conference call; Work on Motion for Partial Summary Judgment JLA 5.25 — regarding Damages and 57.105 motion to Jack Scarola; Work on Motion for Protective Order regarding Ghislaine Maxwell, A. Dershowitz, A. Cordero, and H. Rubenstein depositions Email to Maxine Streeter regarding records; Emails to/from Jack Scarola regarding deposition of G. Maxwell, A. Dershowitz, H. Rubenstein and A. Cordero; Preparation for conference call; Draft report letter 08/13/11 E-mail communications with Darren Indyke, Esquire re: strategies relative to Second CEK 2125 • Amended Complaint, intervening, inquiry as to Marra hearing; preparation for and attendance at telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, Esquire, Roy Black, Esquire and Jay Lefkowitz, Esquire re: filing of Second Amended Complaint, continued allegations to add; e-mail communications with Jeffrey Epstein re: filing of Motion for Summary Judgment, discussion of relevant matters to Second Amended Complaint, denial of Critton's Motion to Dismiss, 08/13/11 Conference call with J. Lefkowitz, Esq., M. Weinberg, Esq., Mr. Epstein and D. Indyke, USG 'NO • Esq. regarding going-forward strategy and pending and proposed motions. 08/13/11 Attend conference call with Chris Knight, Jeffrey Epstein, Jay Lefkowitz, Marty JLA bcC Weinberg and Roy Black; Emails regarding conference call with Jeffrey Epstein (3); Emails to/from Darren Indyke (2) X. 08/13/11 Conference call with JEE and defense team; follow up call with CEK and JLA. LAS 1.50 ° 08/14/11 E-mail communications with Jeffrey Epstein re: legal analysis for Second Amended CEK 040 • Complaint, serving of Proposal for Settlement and filing of Summary Judgment Motion to Counterclaim, discussion of review of Critton files, court files, etc. 08/14/11 Revise report/recommendation latter to Jeffrey Epstein; Emails regarding same (7); JLA 2.25 Prepare response to question of Jay Lelkowitz and Marty Weinberg regarding Abuse of Process Claim 08/14/11 Continue to work on revisions to Amended Complaint and emails to/from Jeffrey JLA '2':25 se Epstein regarding same (2) 08/14/11 Review and advise re: client letter. HSG 0.75 - 08/14/l I Review, revise and finalize letter to JEE re: summary of matter to date and LAS -1-.25 • recommendations. 08/15/11 Review Re-Notices of Wackenhut's depositions (2); Emails regarding research of JLA 1.25 — Abuse of Process Claim (3); Emails and phone calls to/from Maxine Streeter regarding Discala documents (4); Emails to/from Jeffrey Epstein regarding Complaint (3) 08/15/11 Emails regarding G. Maxwell, et al. depositions (3); Review Privilege Log from JI,A 1.75 — Discala; Review Abuse of Process and Litigation Privilege case law for Amending Complaint; Review Daily Business Review article regarding CVRA case 08/15/11 Review authorities re: malicious prosecution; revise memorandum re: abuse of process; HSG 2.75 — rev iew/advise re: on-line DBR article re: AFederal Charges Prepared, Not Filed Against Jeffrey Epstein.it Fowler White Burnett P.A. EFTA01118556 Ref.: LAS-23869-080743-463407 September 8, 2011 Page 5 Date Description 08/15/11 Review results of 3771 hearing and related press article. 08/16/11 Follow up relative to Second Amended Complaint, including discussion of Discala production, Legamaro e-mail and other relevant information; follow up relative to filing of Second Amended Complaint, 57.105 letter, Motions for Partial Summary Judgment and serving of Proposal for Settlement 08/16/11 Review and respond to emails; review case law on abuse of process and summary memorandum; review amended complaint status. from;nested by N. Trom t for J. Ackerman 08/16/1108/16/11 Locate depositio Review Disk Phone call with (2); Prepare JLA '3-.4.k• email/document ond Amended Comp ain •Review Razorback records; Emails to/from Jeffrey Epstein regarding status of Second Amended Complaint (3); Email to client regarding research on Abuse of Process; Continue to work on Second Amended Complaint 08/16/11 Draft i57.105 letter to Scarola and motion for J57.105 attorney's fees. HSG 2.00 08/17/11 Telephone conference with Helaine Goodner, Esquire re: Second Amended Complaint; CEK 1'95 • receipt and review of c-mail communication from Jay Lefkowitz, Esquire re: observations on memo on abuse of process case law; e-mail communications with Jeffrey Epstein re: Second Amended Complaint and cause of action stated for abuse of process; telephone conference with Martin Weinberg, Esquire re: comments and input on Second Amended Complaint; e-mail communications with Jeffrey Epstein re: requesting additional time to file :,. N i 08/17/11 Review and respond to emails; review draft amended complaint; review comments to LAS 345 • same; make suggestions and revisions; confer with CEK and „ILA; review letter from Marty Weinberg. Second Amended Complaint; Hearing preparation; Emails with 08/17/11 Revisions to Second Amended Complaint; Emails from Jeffrey Epstein, J% owitz JLA E00 0 IS ONregarding Second Amended Complaint (4); Legal research regarAr onspracy issues and Abuse of Process issues 08/17/11 Review and advise regarding draft Second Amended Complaint and conference HSG 4'..f.Q • regarding same; further review Florida law regarding civil conspiracy. 08/18/11 Continue review of draft amended complaint; analyze options for conspiracy issue; LAS ,3275 . confer with Helaine Goodner; review and respond to emails; confer with JLA re: result of hearing and extension until Monday@ 5pm; review and respond to emails; review draft Rule 57-105 letter and motion for attorney's fees; review motion for summary judgment of the counterclaim. \ 08/18/11 E-mail communications with Darren 1ndyke, Esquire re: comments and edits to Second CEK th.50 a Amended Complaint, discussion of potential Motion to Dismiss and ruling; e-mail communications with Joseph Ackerman, Esquire re: inquiry from Special Master as to status 08/18/11 Prepare for and attend hearing on Motion for Enlargement of Time for Complaint, JLA Legal research and continue working on Second Amended Complaint and revisions thereto; Emails from Darren I. regarding complaint (2); Emails regarding hearing for Motion re Punitive Damages; Emails from Jeffrey Epstein (2) 08/18/11 Emails from/to Judge Carney (3); Legal research regarding conspiracy; Email from JLA 0.50 — Jack Scarola regarding Carney 08/18/II Work on Proposal for Settlement JLA &75 r 08/18/11 Continued review of authorities regarding civil conspiracy under Florida law in HSG *2,5 . connection with preparation of amended complaint. Atty Hours LAS 0.50 -- CEK NO e LAS 1.00 0 ..z PMR 0.75 — Fowler White Burnett P.A. EFTA01118557 Date Ref.: LAS-23869-080743-463407 September 8, 2011 Page 6 Description Atty Hours 08/18/11 Analyze pleadings and evaluate issues re: terms and conditions of Proposal for MJS 0.50 — Settlement to Plaintiff 08/19/11 E-mail communications with Jeffrey Epstein it: focus on criminal enterprise in Second CEK N/0. Amended Complaint; review of draft of Second Amended Complaint; telephone conference with Lilly Ann Sanchez, Esquire re: Second Amended Complaint, 57.105 letter, 57.105 motions and Motion for Summary Judgment; telephone conference with Joseph Ackerman, Esquire re: revisions to Second Amended Complaint, draft of Motion for Partial Summary Judgment, Proposal for Settlement and finalizing of 57.105 letter and 57.105 motion 08/19/11 Review and respond to emails; continue review of draft amended complaint and comments to same; confer with JLA and CEK. LAS 1.75 ° 08/19/11 Emails from/to Jeffrey Epstein regarding hearing (2); Emails to/from Darren Indyke regarding Rothstein Plea and Revisions to Complaint (2); Work with Helaine Goodner to complete revisions to Complaint, 57.105 letter and Motion, and Motion for Partial JLA 5.50 — Summary Judgment; Review transcripts of Discala, Doc and LM depositions 08/19/11 Emails to/from Jeffrey Epstein regarding Complaint (2) JLA eo, 08/19/11 Revisions to Second Amended Complaint. HSG 115 ° 08/20/11 Review and respond to emails; review JEE email re: facts of matter; confer with CEK and JLA; review draft second amended complaint and forward same; review revised motion for attorneys fees under Rule 57-105; review draft motion for summary judgment on the counterclaim and forward same. LAS „I/75 • 08/20/11 Multiple e-mail communications with Joseph Ackerman, Esquire, Helaine Goodner, CEK 4.00 Esquire and Lilly Ann Sanchez, Esquire re: Second Amended Complaint and comments made by client, including request for rewriting; review and revise of Second Amended Complaint; review and revise of 57.105 letter and multiple e-mail communications with Helaine Goodner re: same; review and review of Motion for Summary Judgment on Counterclaim 08/20/11 Further revisions to Second Amended Complaint, 57.105 motion and letter and motion for summary judgment. IISG 2.00N.6. 08/21/11 Review and respond to emails; confer with Darren Indyke; confer with CEK; coordinate conference call; attend conference call with JEE and defense team; review draft complaint and forward same. LAS 2.15 4 08/21/11 Telephone conference with Jeffrey Epstein, Darren Indyke, Esquire, Martin Weinberg, Esquire, Jay Lelkowitz, Esquire and Lilly Ann Sanchez re: allegations in Second Amended Complaint as presented and potential for Complaint to survive a Motion to Dismiss; telephone conference with Helaine Goodner, Esquire re: Second Amended Complaint and continued revisions; e-mail communications with Marty Weinberg re: CEK Second Amended Complaint; e-mail communications with Jeffrey Epstein re: status of Complaint; c-mail communications with Helaine Goodner and Joseph Ackerman, Esquire re: expansion with more particularity of dates on meetings, filing of Federal Complaint but lack of service on Epstein and abuse of process claim; review and review paragraph 30 of Second Amended Complaint; e-mail communications with Lilly Ann Sanchez, Esquire re: review of revised Complaint and coordination of telephone conference and filing 08/21/11 Further advise and revise Second Amended Complaint. HSG 3.25 ° Fowler White Burnett P.A. EFTA01118558 Ref.: LAS-23869-080743-463407 September 8, 2011 Page 7 Date Description Atty Hours 08/22/11 E-mail communications with Darren Indyke, Esquire re: Second Amended Complaint CEK L75 p and revisions made thereto; e-mail communications with Jeffrey Epstein re: Second Amended Complaint, allegations in Complaint, continued revisions to Complaint and filing of same; multiple e-mail communications with Lilly Ann Sanchez, Esquire, lielaine Goodner, Esquire and Joseph Ackerman, Esquire re: revisions to Second Amended Complaint; e-mail communications with Jeffrey Epstein re: timing of serving of Proposal for Settlement 08/22/11 Numerous phone calls and emails re: second amended complaint; attend conference LAS calls with JEE and defense team; confer with Darren Indyke; confer with Helaine Goodner and CEK; review drafts of complaint. 08/22/11 Review all LM v. Epstein files and on line research for dates regarding same at the PMR 1.00 '— request of H. Goodner 08/22111 Review all deposition transcripts and summaries to confirm date of first investor PMR 1.25 — meeting. 08/22/11 Detailed analysis and evaluation of viability of the dueling abuse of process claims and EEG 1.00 motions for Section 57.105 attorneys' fees. 08/22/11 Research and analyze recent legal authority re: procedural requirements for proposals MJS 0.50— for settlement 08/22/11 Draft Proposal for Settlement to Defendant/Counter-Plaintiff MJS 0.75 08/22/11 Draft proposed General Release to attach to Proposal for Settlement to MJS 0.75— Defendant/Counter-Plaintiff 08/22/11 Draft proposed Stipulation for Dismissal with Prejudice to attach to Proposal for MJS 0.50 - Settlement to Defendant/Counter-Plaintiff 08/22/11 Final revisions to Second Amended Complaint and numerous extended conference calls FISG with client and counsel regarding same. 08/23/11 Review and respond to emails re: scrivener's error; confer with CEK and Helaine LAS 1.50 -4— Goodner re: same; conference call with Marty Weinberg; follow up call re: same; respond to email re: request for September 22 hearing. 08/23/11 Review and revise draft Proposal for Settlement, proposed General Release and CEK 0.50 proposed Stipulation for Dismissal with Prejudice directed only to Edwards' Counterclaim 08/23/11 Preparation for and attendance at conference call with Martin Weinberg, Esquire, CEK Y.75 Helaine Goodner, Esquire and Joseph Ackerman, Esquire re: Second Amended Complaint, Proposal for Settlement, Motion for Partial Summary Judgment and future course of action 08/23/11 Telephone conference with Marty Weinberg; Review revisions to portions of Second JLA % Amended Complaint 08/23/11 Review Epstein indexes PMR 0.50 08/23/11 Draft correspondence to Jeffrey Epstein re: Proposal for Settlement and exhibits thereto MJS ,9.2, 08/23/11 Telephone conference with Marty Weinberg, Esq. regarding revising portion of Second HSG 2.50 • Amended Complaint; revise Second Amended Complaint and prepare Notice of Scrivener's Error. 08/24/11 Review motion to dismiss amended complaint; review and respond to emails; confer LAS \e.,7