EFTA00601040.pdf

INVOICE August 1, 2009 Invoice No. 335 Matter: Epstein Date 7/1/09 7/2/09 7/4/09 7/6/09 Matter No. 30608 General a a 30608 General 30608 General 30608 General Susan E. Bennett, Esq. 10420 SW 139th Street Miami, Florida 33176 (305) 510-4705 Description of Service Review email from Ms. Ederi to team attaching JIMINNIM telephone conferences with Ms. Ederi re: meeting with Defendant and Mr. Critton today with Ms. Eden and Mr. Josefsberg and re: other miscellaneous issues; review email from Ms. Ederi re: and attaching revisions to my notes of June 17, 2009 meeting with Defendant and his counsel; text Ms. Eden re: ISS telephone conference with Ms. Ederi re: same. Review email from collateral to Ms. Ederi and Mr. Josefsberg re: morning's hearing; review reply from Ms. Eden; telephone conference with Ms. Ederi re: same and re: client's situation. Review email from Ms. Estrada rc: dinaialtyp review email from Ms. Estrada 01.0S/y; review email re: illitaikipie; review email from Ms. Ederi re: availability over next ten days; review email from Ms. Ederi to Mr. Critton re: availability for August 5 meeting; review email from Mr. Josefsberg re: Mr. Eden's work on case over next ten days; reply; telephone conferences with Ms. Ederi re: July 1 meeting between Ms. Ederi, Mr. Josefsberg, Mr. Critton, and Defendant. Review email from Ms. Sheehan re: awe it: re: • 4 review reply from Ms. Eden. Review email reply from Ms. Ezell to Ms. Sheehan re: new case law; review text from Ms. Eden re: conference call later today; reply ; review text from Ms. Ederi re: note-taking for conference call; reply; Time Amount 1.2 420.00 .2 70.00 1.3 455.00 .2 70.00 1.2 420.00 EFTA00601040 August 1, 2009 Invoice No. 335 Matter: Epstein telephone conference text Ms. Ederi re: same and re: notes of same; prepare draft of notes; email team re: and attaching same. 7/7/09 7/8/09 30608 General Review email from Ms. Ederi re: draft notes of telephone conference with reply; review email from Ms. Ederi re: June 12 hearing transcript an re: settlement and/or ereply; review reply from Ms. Ederi; review email from Ms. Ederi re: new case law; send replies; review replies from Ms. Ederi; review email from Ms. Ederi to Ms. Sheehan re: same. 30608 Review email from Ms. Sheehan re: new case citation; General retrieve new case re:e; email team re: and attaching same; email Ms. Ederi re: June 12 hearing transcript and fees; review transcript; prepare notes re: same; email team re: notes and including same; review email from Ms. Ezell remml... ,review email from Ms. Ezell re: and attaching addition to notes of June 17 meeting with Defendant and his counsel; review notes; send reply to Ms. Ezell re: same; review reply from Ms. Ezell; review email from Ms. Estrada re: Ms. Ezell's message to Se MO re: Sling NPA under seal for in camera inspection per J. Mane's July 6 order, reply exchange emails with Ms. Ezell re: June 17 meeting with Defendant and his counsel; review email a Oa re: in camera inspection of NPA; review email from Mr. Tropin re: and attaching discovery requests to review and revise; reply; review reply from Mr. Tropin.. 10309 Review email from Ms. Ezell to client re: court's granting extension for Defendant to respond to complaint to August 20; review email from Ms. Ezell to Mr. Doddo re: transcript and issues of breach and a review email from Mr. Doddo to Ms. Ezell re: SIMS send email to Mr. Tropin and Ms. Ezell re: same; review replies from Ms. Ezell; review reply from Mr. Doddo; review email from Ms. Ezell re: notes ofelliftSft; review email from Mr. Doddo re: same; reply; review email from Ms. Ezell 1.1 3.5 1.4 385.00 1,225.00 490.00 2 EFTA00601041 August 1, 2009 Invoice No. 335 Matter: Epstein forwarding email from client re: date of settlement meeting with Defendant and due date of Defendant's response to complaint. 7/9/09 7/10/09 7/: 3/09 7/14/09 30608 General 30608 General 30608 General 30608 General Review email from Ms. Estrada attaching order re: in camera inspection of NPA; review email from legal assistant from Mr. Mennelstein and Mr. Horowitz's firm attaching notice of depositions. Review notes from Ms. Ezell and Ms. Ederi of June 17 meeting with defense counsel; revise my notes of same and send to Ms. Ezell; review reply from Ms. Ezell; review email from Mr. Edwards re: Defendant's invoking the 5th Amendment; review reply from Mr. Kuvin; review reply from Mr. Horowitz; review replies from Mr. Edwards; review reply from Mr. Horowitz; review email from Ms. Ezell re: and attaching proposed agreement for review same; reply; review email from Ms. Eden it: and attaching revisions to my notes on July 6 telephone conference Me review email from Ms. Ezell to Mr. Crifton re: revisions to agreed order attempt on preservation of evidence. Send email reply to Ms. Ezell re: proposed agreement fore send email to Ms. Ederi re: revisions to July 6 telephone conference notes; review email from Ms. Sheehan re: new case re: a reply; review reply from Ms. Eden; review email from Ms. Eden re: same. Review email from Ms. Sheehan re: new case law; review email from Ms. Ezell re: deponents in general; reply; review reply from Ms. Ezell; review email from Ms. Ezell re: motions to compel, etc. in other cases; review email reply from Ms. Ezell re: proposed agreement fore" reply; review reply from Ms. Ezell; email Ms. Ezell re: reviewing case law sent by Ms. Sheehan; review reply; review email reply from Ms. Eden re: revisions to notes re: July atelephone conference; reply; review packet of materials sent from Podhurst; email Ms. Ezell re: interrogatories; review email replies from Ms. Ezell; send email replies to Ms. Ezell; review emails from .6 1.6 .7 2.7 210.00 560.00 245,00 945.00 3 EFTA00601042 August 1, 2009 Invoice No. 335 Matter: Epstein Mr. Tropin re: same. 7/] 5/09 7/16/09 30608 General 30608 General Telephone conference with Ms. Eden re: proposed agreement fee: attorney's fees and re: July meeting with Defendant and his counsel; telephone conference with Ms. Eden re: S and al ellINNIMIOR; review email from Ms. Yarzabal re: preservation of evidence and attaching clients' information; review email from Ms. Ederi to at Josefsberg and Ms. Ezell re: comments to proposed agreement fordlit review email from Ms. Ederi re: today's conference call; telephone conference with team and evaluator re: past and upcoming meetings with Defendant and his counsel and re: other miscellaneous issues; telephone conference with Ms. Eden re: same. Review email from Ms. Ederi to Ms. Yarzabal re: client information for preservation of evidence and attaching chart; review attachment; review Palm Beach Post article re: Mr. Edwards' motion to appoint receiver to secure Defendant's assets; review email from Ms. Ezell re: and attaching order on motion to stay; reply; review email from Ms. Sheehan re: same and re: victims' rights act and releasing information to defendants; review email from Ms. Ezell re: and attaching porposed agreement for , review email from Ms. Ezell re: entailed order; review and revise proposed agreement for S; draft email re: and attaching same to team; telephone conference with Ms. Ederi re: stay; review email from Ms. Sheehan re: order on motion to stay; reply; review email from Ms. Ederi re: Palm Beach Post articles on Defendant; review email from Ms. Ederi re: meetings with clients for preservation information; reply; review email from Ms. Eden re: draft; reply; review reply from Ms. Eden; text replies; review text reply from Ms. Ederi; email Mr. Tropin re: interrogatories; review reply from Mr. Tropin; review email from Mr. Tropin attaching interrogatories and request for production of documents (RPD); review and revise attachments; email Ms. Ezell, Mr. Tropin, and Ms. Ederi re: and attaching revisions to interrogatories and RPD; review reply from Ms. Ezell. 2.8 6.0 980.00 2,100.00 4 EFTA00601043 August 1, 2009 Invoice No. 335 Matter. Epstein 7/17/09 in SID 30608 General Review emails from Ms. Ezell re: and attaching l i t 1 andie and SSreview plan; review email from Mr. Josefsberg re: hearing. Review Palm Beach Post July 15 article re: lawsuit; email same to team. - , Review email from Ms. Ederi re: SM agreement reply review email from Ms. Sheehan re: order denying motion to stay; review order; review reply from Ms. Ezell; review email from Ms. Sheehan re: and attaching same; reply; review order, review email from Ms. Ezell re: my edits to SM agreement; review email from Ms. Ezell re: name of deponent; review email from Ms. Ederi re: order on motion to stay; review email from Ms. Edeti re: SM agreement; email Ms. Ezell re: same; review reply from Ms. Ezell; review reply from Ms. Ederi; reply; review email from Ms. Ezell re: deponents; review email from Ms. Ederi re: same; reply; review email from Ms. Ederi re: SM agreement and re: Mute meeting with Defendant and Mr. Critton; review email from Ms. Ezell re: taking depositions; reply; review reply from Ms. Ezell; review email reply from Mr. Josefsberg to Ms. Ezell; review replies from Ms. Ezell; telephone conference with Ms. Ederi re: revisions to SM agreement; prepare notes re: same; email Ms. Ezell re: same; review string of team entails re: possible deponents; reply ; review reply from Ms. Yarzabal; reply; revise SM agreement; email team re: and sending same to team; review emails from Ms. Eden re: SM agreement revisions; review email from Ms. Rasco re: and attaching draft of request for admissions (RFA); text Ms. Ederi re: same; telephone conference with Ms. Ederi re: Ms. Rasco's email re: RFA; send text to Ms. Eden re: same; review email from Ms. Estrada re: and attaching cross-notice of videotaped deposition; review same; review email from Ms. Ezell forwarding email from Mr. Critton re: request for extension on joint . preservation order until July 24. Review email from Ms. Eden re: contacting client. Review email from Ms. Ezell toed vice versa re: release; review email from Ms. Ezell to .2 70.00 .2 70.00 5.4 1,890.00 .2 35.00 70.00 5 EFTA00601044 August 1, 2009 Invoice No. 335 Mailer: Epstein 7/18/09 7/19/09 7t20/09 a 30608 General S IIMI S SSD a 30608 General a a 30608 General r S Sand Sit re: S and ilammaltlie; review email from Ms. Ezell re: callingat re:IW; Review email from Ms. Ezell re: client's facts. Review client interview notes Slat; draft emails to team re: same. Review email from Ms. Ederi re: deponent and review email from Ms. Ederi re: SM changes still needed and attaching same. Review email from Ms. Ederi re: contacting client and Review email from Ms. Ederi re: contacting client. Review emails between Ms. Ezell and collateral re: client's situation; review emails between Ms. Ezell and Ms. Ederi re: same. Review email from Ms. Ederi re: contacting client and SIPSWERSOWe Telephone conference with Ms. Eden re: SM agreement. Review email from Mr. Lombana re: hearing. Research re: Defendant; review email from Ms. Ezell re: same; telephone conference with Ms. Eden re: same; review and prepare notes re: same; telephone conferences with Ms. Eden re: revision to same; review email from Ms. Ezell forwarding email from Ms. Patton re: anonymous telephone call; research re: same; review email from Ms. Ezell reeand ; review email tom Ms. Ezell attaching SM agreement and opinion of Mr. Critton; review reply from Ms. Ederi attaching revised version. Review emails between Ms. Yarzabal and client re: information on preservation of evidence; reply to team; review emails from Ms. Yarzabal re: preservation; reply; review replies from Ms. Ezell. Review email re: cancellation of hearing for July 21. .1 35.00 .6 210.00 .2 70.00 .2 70.00 .1 35.00 .3 105.00 .3 105 00 .1 35.00 .1 35.00 2.8 980.00 .6 210.00 .1 35.00 6 EFTA00601045 August 1, 2009 Invoice No. 335 Matter: Epstein a 7;21/09 30608 General 7/22/09 80608 General Review email from Mr. Tropin re: articles and reports on Defendant and attaching links; review links; reply to team re: same; review email from Ms. Ederi re: same; review email from Ms. Eder re: Defendant's NY address; reply; review reply from Ms. Eden; review email from Ms. Ederi forwarding email from Mr. Tropin re: articles re: Defendant.; review same; review email from Ms. Ederi re: issues surrounding Defendant's impending release; reply; review email from Mr. Josefsberg re: upcoming team telephone conference, etc.; review email from Ms. Eden re: same. Review email from Ms. Eden re: diagnosis, etc.; reply. Telephone conference with Ms. Eden re„® anwfmnias, SM agreement, depositions, and Defendant's release; research re: as ; review email from Ms. Eden re: Defendant's release; review same and TV report re: same; email team re: same and re: noticing depositions; review articles re: Defendant; send email to team re: same; review email from Ms. Eden re: contacting clients; review email from Ms. Eden et reply; email Mr. Josefsberg re: telephone conference; review email from Ms. Eden; exchange emails re: telephone conference; review email from Mr. Horowitz re: deposition of Mr. Rodriguez; review reply from Mr. Kuvin; review email from Mr. Josefsberg re: deposition; review email from Ms. Estrada re: telephone conference; review ail from Ms. Eden to Ms. Rasco re: Defendant's NY address; email Ms. Ederi and team re: article on Defendant and re: depositions; review reply from Mr. Tropin; reply; review reply from Mr. Tropin; review reply from Ms. Ezell; review reply form Mr. Josefsberg; review emails from Ms. Ezell to Mr. Tropin re: same; reply to Ms. Ezell; email team re: another article og visitors in jail; review reply form Mr. Tropin; review email from Mr. Tropin re: latest articles; review email from Ms. Ederi re: depositions and eimggiS Defendant; email team re: Bear Steams mention in 2.0 7.3 700.00 70.00 2,555.00 7 EFTA00601046 August 1, 2009 Invoice No. 335 Matter: Epstein 7/23/09 7/24/09 • 30608 General 30608 General wand re: question about photograph; review reply form Ms. Eden; email Ms. Ezell and team re: attending depositions; review reply from Ms. Ezell; telephone conference with Ms. Eden re:Solpir agargagerfflarmand re: speaking with clients; review email from Ms. Rasco re: RFA; reply; email Ms. Rasco, Ms. Ezell, Mr. Tropin, and Ms. Eden re: same; review reply from Ms. Ezell; review emails from Ms. Ezell re: and attaching revised preservation order; review and revise same; telephone conference with Ms. Ezell re: and revising same; email Ms. Ezell re: and attaching edited and clean versions of same; review email from Ms. Ezell to Mr. Critton re: and attaching same; telephone conference with Ms. Ederi re: preservation order.. Review email from Ms. Ezell re: client's status. Review email from Ms. Ederi re: telephone conference and siessinlevinitibi SS -review email from Ms. Ederi re: speaking with clients; email Ms. Ederi re: Mr. Rodriguez's deposition; review reply from Ms. Ederi; review email from Mr. Tropin sending links to recent articles re: Defendant's release; review same; review email from Ms. Ezell email Ms. Ezell re: Mr. Rodriguez's deposition; review email from Ms. Ezell re: transcript of Ms. Miller's deposition sent by Mr. Mermelstein; review email from Ms. Ederi re: no-show of Mr. Rodriguez at deposition and re: conversation with Mr. Edwards re: Defendibt, etc.; review email from Ms. Ezell re: and attaching Defendant's answers to interrogatories in other case; review email from Mr. Josefsberg re: meeting with MIMES reply; review reply; review email from Ms. Ederi to Ms. Rasco re: RFA; review email from Ms. Ezell re: extension on proposed order on preservation at Mr. Critton's request revittw reply from Mr. Critton. Review email from Ms. Ezell re: meeting-' OP; reply; review email from Mr. Tropin attaching 2.5 2.8 35.00 875.00 980.00 8 EFTA00601047 August 1, 2009 Invoice No. 335 Matter: Epstein latest articles on Defendant; review same; email team re: same; review email from Ms. Ederi re: article on Defendant; reply; review email from Ms. Ederi re: IIMOS, S and photos; review email re: and attaching notice of deposition oKMr. Rodriguez from Mr. Mermelstein's office; &view email from Ms. Ezell to Ms. Ederi re: istalla reply; review reply; review email from Ms. Ezell re: NY depositions; review email from Mr. Tropin re: notable points from articles on Defendant; review email re: defense counsel's available dates for depositions; review reply et; review reply from Ms. Ezell; review repl review email from Ms. Ezell 7/25/09 7/27/09 41111P r a r 30608 General 30608 General email Ms. Ezell re: AMES more names, and video; review email from Ms. EzellS; review reply from Ms. Ezell; review email from Mr. Tropi review email from Ms. Ezell re: contacting clients re: Defendant's release. Review email from Ms. Ezell to client re: preservation of evidence, names, Defendant's release, collateral interviews, etc. Review emails from Ms. Ezell and collateral re: client's status; review emails from. Ms. Ezell re: client's status. Review entail from Ms. Eden re: status of client; review email from Ms. Ezell re: same. Review email from Ms. Eden re: status of client; reply. Email Ms. Eden re: contacting client; review email from Ms. Ezell to client re: names and Defendant's release; reply; review reply. Review email from Mr. Josefsberg to Ms. Ezell re: initial; review email from Ms. Eden affalle and coverage of depositions of Ms. Maxwell, Mr. Dubin, and Mr. Wexner. . Review email from Mr. Tropin re: newest articles on Defendant; review same; review reply from Ms. Ezell to Ms. Eden re: clients' identification of names, new .2 .2 .3 .2 .5 .3 .6 70.00 70.00 105.00 70.00 175.00 105.00 210.00 9 EFTA00601048 August 1, 2009 Invoice No. 335 Matter: Epstein client interview, video of search, and anonymous caller. 7/28/09 30608 Email team with link to website to General review reply from Mr. Josefsberg; review email attaching notice of depositions in NY and Ohio; review reply 1111Me, review email from Ms. Ezell to team re: same; review email from Ms. Ezell to Mr. Doddo re: link to find liens; send emails to team and Mr. Doddo re: pdf of document re: maggang review email from Mr. Edwards' office attaching notice of taking deposition of Mr. Weznepin Ohio; reply; review reply; reply review emails from Ms. Ederi re: depositiggs; email team re: same; review email from Mr. Doddo re: search MOOS review email from Mr. Josefsberg re: NY and Ohio depositions; review email from Mr. Josefsberg to Ms. Patton re: telephone conference with team before NY and Ohio depositions review email from Ms. Ezell re: ISOIROSONIIMMIIIINSit review email from Ms. Ezell re: tomorrow's deposition of Mr. Rodriguez; review email from Ms. Ezell rem 4MMININF, review reply from Ms. Ederi to Ms. Ezell re: miscellaneous; review email from Ms. Ederi re: preparation for deposition of Mr. Rodriguez; review email from Ms. Eden re: SIRS ass, review email from Ms. Eden rear SS review email from Mr. Doddo re: same; review email from Mr. Josefsberg S email Ms. Ezell and Mr. Tropin re: and attaching revisions to interrogatories and request for production of documents (RPD); review reply; reply; review email from Ms. Eden re: RFA; reply; review email from Ms. Ederi to Ms. Rasco re: RFA; review reply from Ms. Rasco; review email from Ms. Ederi re: interrogatories, RPD, and RFA; revise RFA; email Ms. Eden re: RFA revisions; review reply; send revised RFA to Ms. Ederi; review email re: preservation of evidence and attaching defense counsel's revisions; reply; review email from Ms. Ezell re: same; review reply from Mr. Josefsberg. Review email from Ms. Ezell forwarding email from collateral re: her status. 5.6 1 960 00 10 EFTA00601049 August 1, 2009 Invoice No. 335 Matter: Epstein 7/29/09 7/30/09 7/31/09 r 30608 General 30608 General IOW a r 30608 General Email client re: contacting us; review reply from Ms. Eden; review email from Ms. Ederi to client re: same. Email Mr. Josefsberg re: future telephone conference; review reply from Ms. Ezell; review entails from Ms. Patton re: same; review email from Mr. Doddo re: and providing link; research re: witnesses Ann Sh email team re: same; review; email Mr. Tropin re: interrogatories and RPD revisions; review reply; reply. Review email from Ms. Yarzabal re: missing information; reply; review files re: same; email Ms. Yarzabal re: same. Review email from client re: contacting us and update; review ettntiffrom Ms. Ezell to client re: same; telephone conference with client re: names and update; review interview notes; email team re: conversation. Telephone conference with Ms. Eden re: depositions; review email from Ms. Yarzabal re: alrnallIlla a; review reply from Ms. Ezell; review email from Mr. Josefsberg forwarding email from Mr. Critton it: upcoming meeting with Defendant, etc.; review email re:eSeptember 1 deposition; review fie reply; review Mr. Scarola's reply; review reply; review Mr. Ezell's email re: witnesses; reply; review email from Ms. Ezell reisigsSMINISSI); review reply from Mr. Josefsberg; review email from Ms. Ezell re: deposition of Mr. Rodriguez; review reply from Mr. Josefsberg; telephone conference with Ms. Ederi re: revisions to RFA; review email from Mr. Tropin attaching updated RFP and interrogatories; reply ; review reply; email team re: discovery andSIS Review email from Ms. Eden re: client's contact information. Telephone conference with Ms. Eden re: conversation with client. Review email from Ms. Rasco re: pending issues to resolve; review email from Ms. Yarzabal re: and .4 1.5 .5 1.4 2.2 .1 .1 .4 140.00 525.00 175.00 490.0' 770.00 35.00 35.00 140.00 11 EFTA00601050 August 1, 2009 Invoice No. 335 Matter Epstein S a TOTAL attaching list of persons; review email from Ms. Ezell through Ms. Patton to all Plaintiffs' attorneys attaching notice of continuing videotaped deposition of Mr. Rodriguez; review email from Ms. Ederi re: SIM Review email reply from Mr. Josefsberg re: discovery and reply; review email replies from Mr. Ezell; review email from Ms. Ezell re: court's granting our no-contact motion; review reply from Mr. Josefsberg; reply; review reply from Mr. Tropin. Review email reply from Mr. Josefsberg re: discovery ands; reply; review email replies from Mr. Ezell; review email from Ms. Ezell re: court's granting our no-contact motion; review reply from Mr. Josefsberg; reply; review reply from Mr. Tropin. 66.6 hours @ $350.00 per hour .5 .5 175.00 175.00 $23,310.00 12 EFTA00601051