EFTA00597394Set 9
2014-05-066p1,714w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
with the Clerk ... parties are charged with good faith
cooperation in this regard. The Pre-Trial Stipulation shall contain in separately numbered
paragraphs:
1. a list of all pending motions. including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00597394.pdf
EFTA00804036Set 9
2017-12-0111p3,394w
File No. 100.001
Invoice #32942
Professional Services
HrslRate Amount
11/6/2017 TLC Work on Pre-Trial Stipulation and Motion for Continuance of Trial; 9.50 2,137.50
continue working on exhibits ... Goldberger, D. Indyke and K. 11.50 8,625.00
Rockenbach re strategies; work on Pre-Trial Stipulation and Motion 750.00/hr
for Continuance of Trial; work on preparations for B. Edwards ... counsel before noticing hearing by review of J. 750.00/hr
Scarola's proposed Pre-Trial Stipulation and last version of Motion to
Continue Trial
KBR Telephone call with J. Scarola
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804036.pdf
EFTA00614368Set 9
2010-12-174p1,600w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
with the Clerk ... parties are charged
with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately
numbered paragraphs:
I. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614368.pdf
EFTA01126529Set 9
2014-06-105p1,623w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits.
EFTA01126529 ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
with the Clerk ... parties are charged with good faith
cooperation in this regard. The Pre-Trial Stipulation shall contain in separately numbered
paragraphs:
1. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA01126529.pdf
EFTA01123157Set 9
2013-10-284p1,606w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
with the Clerk ... parties are charged
with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately
numbered paragraphs:
I. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA01123157.pdf
EFTA00597471Set 9
2017-07-066p1,737w
writing, as to as many facts and issues as
possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties,
and filed with the Clerk ... parties are charged with good faith cooperation in this regard. The Pre-Trial
Stipulation shall contain in separately numbered paragraphs:
I. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00597471.pdf
EFTA00809163Set 9
2018-12-046p1,785w
writing, as to as many facts and issues as
possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties,
and filed with the Clerk ... parties are charged with good faith cooperation in this regard.
The Pre-Trial Stipulation shall contain in separately numbered paragraphs:
I. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809163.pdf
EFTA01107653Set 9
2013-10-1819p4,223w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
--7PlaintitTto see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties,
and filed
with the Clerk ... parties are charged
with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately
numbered paragraphs:
1. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107653.pdf
EFTA00724077Set 9
2010-12-174p1,598w
writing, as to as many facts and
issues as possible;
3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. list all objections to trial exhibits ... shall be the duty of counsel for the
Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
with the Clerk ... parties are charged
with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately
numbered paragraphs:
I. a list of all pending motions including MOTIONS
https://www.justice.gov/epstein/files/DataSet%209/EFTA00724077.pdf
EFTA00808455Set 9
2010-09-0816p3,535w
Ponzi scheme could not be more interrelated.
Edwards Cannot Escape the Binding Pre-Trial Stipulation in Which He
Contracted that His Counterclaim Against Epstein Would Be tried With (and
following ... action and in that order when his
counsel signed a binding and unambiguous pre-trial stipulation just three months
ago on December 22, 2017, in which Edwards expressly and clearly ... italicized emphasis added).
6
EFTA00808461
have signed the binding pre-trial stipulation and should have requested severance
at that time, which he chose not to do. Three months before trial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808455.pdf
EFTA00801256Set 9
2017-11-069p2,451w
Epstein and J. Epstein's responses 225.00/hr
SJL Work on Pre-trial Stipulation, Motion for Continuance of Trial, 4.20 3,150.00
Affidavit of R. Critton, Motion to Amend Answer ... requests 225.00/hr
SJL Continue working on Motion to Compel; work on Pre-Trial Stipulation 2.80 2,100.00
750.00/hr
For professional services rendered 348.30 $194,821.50
EFTA00801263
Jeffrey Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801256.pdf
EFTA00702990Set 9
2017-10-253p690w
settlement, simplify the issues, stipulate in
writing to facts and issues, prepare a Pre-Trial Stipulation and list objections to exhibits
[30 days prior to trial]
11/10/17 DEPO: Bradley Edwards ... Mediation; Mediation Statement
11/12/17 DEADLINE: Bradley Edwards to appear for deposition
11/15/17 DUE: Pre-Trial Stipulation, Deposition Designations, Proposed Jury Instructions and
Verdict Form; DEADLINE: To have Daubert Motions heard
https://www.justice.gov/epstein/files/DataSet%209/EFTA00702990.pdf