# IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC, Publisher of the PALM BEACH POST,


v. CASE NO.: 19-C 14681

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida.


STATE OF FLORIDA COUNTY OF NASSAU CO S

# AFFIDAVIT OF ATTOR1c9
BEFORE ME, the undersigned aut ( lc ' ared Douglas A. Wyler, Esq., who, after being first duly sworn, deposes and sa 77

- I. Affiant is a pa er f SCHOLZ & WYLER, LLC, counsel for Defendant, DAVE ARONB G, aj to Attorney of Palm Beach County, Florida, ("Aronberg"), as well as general cou to the Florida Prosecuting Attorneys Association, ("FPAA"), and makes this Affidavit o own rsonal knowledge.
- 2. i t is licensed to practice law in the State of Florida, is an active member of the Flora in good standing and has engaged in the practice of law in the State of Florida since 2015.
- 3. As detailed herein, the services rendered by Affiant and his firm pertain to Affiant's demand letter and motion for attorneys' fees sent to Plaintiff's counsel pursuant to § 57.105, Florida Statutes, on June 8, 2020, in defending against Count I of Plaintiff's Amended Complaint

and Plaintiff's October 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the above-captioned lawsuit. See, Exhibits "A" and "B" attached hereto.

4. The total time Affiant's law firm has expended services rendered to date is 74.8 hours, however, from the date of Defendant Aronberg's 57.105 demand, Affiant's law firm has demand was served, the Affiant expended a total of 42.2 hours. Of the 42.2 hours expended since Defendant Aronberg's 57.105 Asseic

5. Of the 42.2 hours expended since Defendant Aronberg' demand was served, the total time Affiant has expended services rendered to dates S. hours at the rate of \$425.00 per hour. Likewise, the total time Affiant's law partn rt . M, has expended services rendered to date is 6.8 hours at the rate of \$475.0

6. Accordingly, since Defendant Aronbe, demand was served, Defendant Aronberg's counsel, la SCHOLZ & WYLE)<ILC, has rendered services in the amount of \$18,275.00, in conjunction with the de f the instant action pursuant to § 57.105, Florida Statutes. See, Exhibit "C" attache

7. Affiant expect tb i J r additional 4.0 hours at \$425.00 an hour in preparing for and attending the hearing on eys' fees. Thus, the total amount of hourly attorneys' fees the State Attorney is seeking is 46.2 hours for a total of \$19,975.00. Additionally, the State Attorney seeks a multiplier of 2.0, which when applied makes the grand total attorneys' fees sought herein \$39,950.01).

Dated this 9th day of November, 2020.

FURTHER AFFIANT SAYETH NOT.

Douglas AJ Wyler, Esq., Fla. B No. 119979

# STATE OF FLORIDA COUNTY OF NASSAU
The foregoing instrument was acknowledged before me this 9th day of November, 2020, by Do . Wyler, Esquire, who is personally known to me and who did take an oath.

Sig f otary Public — State of Florida

4itraN R. CacKson Name typed, printed or stamped



CERTIFICATE OF SERVICE +6s SCHOLZ & WYLER, LLC ?S S y Douglas A. Wyler Arthur I. Esq. Fla. Bar No.: 10249 Richard J. Scholz. Esq. Fla. Bar No.: 0021261 Douglas A. Wyler, Esq. Fla. Bar No.: 119979 961687 Gateway Blvd., Suite 2014 Fernandina Beach, Florida 32034 (904) 261-3693 (904) 261-7879 Fax Primary: jacobsscholzlaw@comcast.net Attorneys for Defendant Dave Aronberg

I HEREBY CERTIFY that on this 9th day of Novem been electronically filed with the Florida E-File Portal , a copy of the foregoing has on all parties of record herein.

**EXHIBIT "A"**


**EXHIBIT "A"**

Subject: SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V. DAVE ARONBERG ET AL. Date: Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time From: Douglas Wyler To: imendelsohns@gtlaw.com, smithl@gtlaw.com, flservice@gtlaw.com, BoyajianN@gtlaw.com, riveraal@gtlaw.com, GRYGIELM@gtlaw.com

Attachments: 2020-06-08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf

Court: Florida Case No: Case No. 2020-CA-014681 Plaintiff: CA Florida Holdings, LLC Defendant: Dave Aronberg Title of Documents • Fla. Stat. § 57.105 Demand Letter Served: • Defendant, Dave Aronberg's Motion tto Fees Sender's Name and Douglas Wyler Telephone Number: (904) 261-3693 Circuit Court of the Fifteenth Judicial Circuit, in and for Palm Beach Cnunty,

S )

Sincerely,

Doug Wyler, Esq. Scholz & Wyler, LLC 961687 Gateway Blvd., STE 201-I Fernandina Beach, FL 32034 904-261-3693 904-261-7879 (fax)

Please be advised that this e-mail and any files transmitted with it are confidential attorney-client communication or may otherwise be privileged or confidential and are intended solely for the individual or entity to whom they are addressed. If you are not the intended recipient, please do not read, copy or retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or copying of this coreNation is strictly prohibited.



# SCHOLZ 8c WYLER, LLC.
THE Lao OnICCS co ASSOCIATES. PA. ARTHUR

A UMITED LIABIUTY COMPANY OF PROFESSIONAL ASSOCIATIONS

ATTORNEYS AT LAW

GATEWAY TO AmELIA

961457 GATEWAY BLVD.. SUITE 201.1

FERNANDLYA BEACH, FLORIDA 32034

TELEPHONE (904) 261.3693

FAx NO 1904) 261.78710

June 8, 2020

# VIA ELECTRONIC & U.S. MAIL
Stephen A. Mendelsohn, Esq.

Greenburg Traurig, P.A.

5100 Town Center Circle, Suite 400

Boca Raton, FL 33486

RE: CA Florida Holdings, LLC v. Dave Aronberg et a Palm Beach County, Case No.: 2019-CA- 1468

Dear Mr. Mendelsohn:

As you are aware our firm represents the interes County. Florida, in the above referenced ma dismissal of your First Amended Complai is made pursuant to section 57.105, Flo • \ e ronberg, as State Attorney of Palm Beach rpose of this letter is to demand the voluntary plaint"), dated January 17, 2020. This demand

As you know, Section 57.

RICHARD J, SCHOLZ. A. RicHARO J. SCHOLZ

DOUGLAS A. WYLER, PA. DOUGLASA. %TYLER

- (I) Upon the court' 0or motion of any party, the court shall award a reasonable atto ee, including prejudgment interest, to be paid to the prevailing party in I amounts by the losing party and the losing party's attorney on any cl r defense at any time during a civil proceeding or action in which the court r t the losing party or the losing party's attorney knew or should ha known t a claim or defense when initially presented to the court or at any fore trial:
  - a. as not supported by the material facts necessary to establish the claim or defense; or
  - b. Would not be supported by the application of then-existing law to those material facts.

Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count 11 of the Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action consists of Count 1, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to establish the claims asserted, and that your claims are not supported by the application of current law to said material facts.

First and foremost, the Complaint is not supported by the material facts necessary to establish the claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein. Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to this action because no matter what, he and his office do not have possession, custody, or control of the requested materials.

In addition to the foregoing material facts that negate the claims asserted in the Complaint your claims are also not supported by the application of current law. Specifically, your action ford tory relief fails based on the clear, unambiguous statutory language found in Section 905.27(2) Statutes, which states:

When such disclosure is ordered by a court pursuant to subsection ( a civil case, it may be disclosed to all parties to the case and to their atto the latter to their legal associates and employees. However, the grand Iry te. •nv afforded such persons by the court can only be used in the defense firer ecut n of the civil or criminal case and for no other purpose whatsoever.

Moreover, even if the Plaintiff were to prevail in the decla to comply with any court order granting disclosure of Aronberg nor The Office of the State Attorney for custody, or control of the 2006 Epstein grand jury . Mr. Aronberg would be unable documents because neither Mr. th Judicial Circuit have possession,

Based on the foregoing, if the Complaint is the enclosed Motion for Attorney's Fees and your firm, recovery of the legal ex within 21 days of the service of this letter, and we will seek as sanctions, from your client d in defending this frivolous action.

Please govern yourself according

4

Douglas A. Wyler, Est. er For the Firm

End.: Defer {sup}`s`Mo n for Attorneys' Fees

# IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CA FLORIDA HOLDINGS, LLC, Publisher of the PALM BEACH POST,


v. CASE NO.: 19-CA-014681

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida.


# DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
\ / ti\i{sup}`t` Nc Defendant, DAVE ARONBERG, as Sta {sup}`t` 'A ono y of Palm Beach County, Florida, by and through the undersigned attorneys, moves ( {sup}`S` {sup}`e` n, pursuant to Florida Statutes, Section 57.105, to award him reasonable attorneys' for t defense of Plaintiff's First Amended Complaint, (the "Complaint"), and as go't {sup}`e`r, would show that on June 8, 2020, Plaintiff was served {sup}`a`copy of this Motion, together wi aletter from the undersigned attorney, in accordance with \a.) subsection (4) of the- ve Statute, demanding dismissal of the Complaint, at least 21 days prior to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which establish,that the Complaint is without support of the facts or the law.

NWHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.

**CERTIFICATE OF SERVICE**

I hereby certify that on this \_\_\_\_ day \_\_\_\_\_, 2020, the foregoing was electronically filed via the Florida E-File Portal for electronic service on the parties of record herein.

**[REDACTED] SCHOLZ & WYLER, LLC**

*/s/ Douglas A. Wyler*

---

Arthur I. [REDACTED] Esquire

Fla. Bar No.: 108249

Richard J. Scholz, Esquire

Fla. Bar No.: 0021261

Douglas A. Wyler, Esquire

Fla. Bar No.: 119979

961687 Gateway Blvd., Suite 201-I

Fernandina Beach, Florida 32034

(904) 261-3693

(904) 261-7879

jacobsscholzlaw@comcast.net

*Attorneys for Defendant*

NOTA CERTIFICATE

# EXHIBIT "B"
# EXHIBIT "B"
CA FLORIDA HOLDINGS, LW, Publisher of THE PALAIBEACHPOST,


v.

DAVE ARONBERG, as State Attorney of Palm Beach County, Florida; SHARON R. BOCK, as Clerk and Comptroller of Palm Beach County, Florida,


IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

CASE NO.: 50-2019-CA-014681-XXXX-MB

DIVISION: AG .

# PLAINTIFF CA HOLDINGS' ,LC e NOTICE OF DROPPING STATE ATTO IrT,A E ARONBERG • V
Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. i . 0(b), hereby notifies the parties that ..X it has dropped State Attorney, Dave Aronber < /ros s," n tlybove i case.

+6s

Respectfully submitted,

GREENBERG TRALIRIG, P.A. Attorneys for CA Florida Holdings. LW. Publisher of The Palm Beach Post

Stephen A. Mendelsohn. Esq. 401 East Las Olas Boulevard Suite 2000 Boca Raton, Florida 33486 Telephone: (561) 955-7629 Facsimile: (561) 338-7099

By: /s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN Florida Bar No. 849324 mendelsohnslittlay..com sm FLServiceVislaw.com

By: 4/Michael/Gm/el MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grvaielm@rrtlaw.com

By: 1st Nina D. Bovedian NINA D. BOYAJ1AN (Admitted Pro Hat Vice) 1840 Century Park East, Suit Los Angeles California 9006 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 ) bovajiannegtlaw coin riv

# CERTIFICATE
I HEREBY CERTIFY that on this 21' 1ber, 2020, a true and correct copy of the foregoing has been filed with the Clerk of ng the State of Florida e-filing system, which will send a notice of electronic semi all ies of record herein w

is/ Sievhen A. Mendelsohn STEPHEN A. MENDELSOHN

**EXHIBIT "C"**


**EXHIBIT "C"**

# Time Entries
Fp Scholz & Wyler, LLC Gateway Blvd., Suite 2011 Femandina Beach, FL 32034 United States 904-261-3693

Dave Aronberg

# Aronberg (SAO15) adv. CA Florida Holdings, LLC
|  |  |  |  | Z .:4Q |  |  |
| ---------------------- | -------- | ---------------- | -------------------------------------------------------- | ---------- | ------- | ------------ |
| Date | EE | Activity | Description | Rate | Hours | Line Total |
| 11/26/2019 | OW | Review | Initial review of summons doom | \$425.00 | 1.5 | \$637.50 |
| 11/26/2019 | DW | Review | Reviewed motion for pro hac vIce_and Judge |  |  |  |
|  |  |  |  | \$425.00 | 0.2 | \$45.00 |
| 11/26/2019 | OW | Teleconference | TeleconferewV/ Client, re: response to lawsuit | \$425.00 | 0.5 | \$212.50 |
| 11/26:2019 | DW | Draft | Draftedyarinentletter and sent to client | \$425.00 | 03 | \$127.50 |
| 11/26/2019 | DW | Review | RevieWedt5th ckcuit local rules | \$425.00 | 1.0 | \$425.00 |
| 11/26/2019 | AU | Review | Initial review of complaint | 5475.00 | 1.0 | \$475.00 |
| 11/26/2019 | AU | Meeting | Meeting'w/ DAW to discuss lawsuit and strategy | 5475.00 | 0.5 | \$237.50 |
| 11/26/2019 | DW | Meeting | ,,,iwicr |  |  |  |
|  |  |  | Meeting WI AU to discuss lawsuit and strategy | \$425.00 | 0.5 | \$212.50 |
| 11/26/2019 | AU | Teleconferenc( | Teleconference w/ Client, re: response to lawsuit | \$475.00 | 0.5 | \$237.50 |
| 12/02/2019 | OW | Renton & |  |  |  |  |
|  |  | PreparatiOn | Research and prep for Motion to dismiss | \$425.00 | 2.0 | \$850.00 |
| 12/02/2019 | OW c.. | Draft | 1st Draft motion to dismiss | \$425.00 | 1.0 | \$425.00 |
| 12/022019 AT DOVA\i' |  | , |  |  |  |  |
|  |  | Teleconference | Tel |  |  |  |
|  |  |  |  | \$425.00 | 0.5 | \$212.50 |
| 12/02/2019 | AIS | Review | Reviewed 1st Draft MTDismiss | \$475.00 | 0.3 | \$142.50 |
| 12/02/2019 | AU | Teleconference | Teleconference w/ client, re: draft motion to |  |  |  |
|  |  |  | dismiss | \$475.00 | 0.5 | \$237.50 |
| 12/03/2019 | AU | Meeting | Meeting w/ DAW, re: motion to dismiss | \$475.00 | 0.2 | \$95.00 |
| 12/03/2019 | DW | Meeting | Meeting w/ AIJ, re: MTDisrniss | \$425.00 | 0.2 | \$85.00 |
| 12/06/2019 | OW | Draft | Completed final draft of motion to dismiss; filed with |  |  |  |
|  |  |  | Court | \$425.00 | 0.7 | \$297.50 |
| 12/06/2019 | DW | Teleconference | Spoke w/ client, re: final draft of motion to dismiss | \$425.00 | 0.5 | \$212.50 |

Scholz & Wyler, LLC

Balance Invoice # Invoice Date Payment Term Due Date \$32,440.00 00307 Rcnber 6, 2020

| 12/06/2019 | DW | Teleconference | Spoke with Clerk's attorney, re: response | \$425.00 | 0.5 | \$212.50 |
| ------------ | ----- | ------------------ | ------------------------------------------------------------------------------------- | ---------- | ----- | ---------- |
| 12/06/2019 | AJJ | Review | Reviewed final draft MTDismiss | \$475.00 | 0.2 | \$95.00 |
| 12/06/2019 | AJJ | Review | Reviewed Clerk's MTDismiss | \$475.00 | 0.2 | \$95.00 |
| 12/13/2019 | DW | Review | Reviewed Clerk's Motion to Dismiss | \$425.00 | 0.5 | \$212.50 |
| 01/16/2020 | DW | Review | Reviewed Order Setting Hearing on Defendants' MTDismiss | \$425.00 | 0.1 | \$42.50 |
| 01/16/2020 | DW | Review | Reviewed motion for pro hac vice | \$425.00 | 0.1 | \$42.50 |
| 01/17/2020 | DW | Review | Reviewed PI's Amended Complaint | \$425.00 | 1.0 | \$425.00 |
| 01/17/2020 | DW | Teleconference | Spoke with client, re: Amended Complaint | \$425.00 | 0.5 | \$212.50 |
| 01/17/2020 | DW | Review | Reviewed PI's notice of filing | \$425.00 | 0.1 | \$42.50 |
| 01/20/2020 | AJJ | Review | Reviewed PI's Am. Compl | \$475.00 | 0.3 | \$142.50 |
| 01/21/2020 | DW | Review | Reviewed Judge Marx's Order Cancelling MTDismiss Hearing | \$425.00 | 0.1 | \$42.50 |
| 01/21/2020 | DW | Review | Reviewed PI's Objection to Defendants' MTDismiss | \$425.00 | 0.2 | \$85.00 |
| 01/21/2020 | DW | Teleconference | Spoke with client, re: Amended complaint | \$425.00 | 0.5 | \$212.50 |
| 01/21/2020 | AJJ | Meeting | Meeting w/ DAW, re: response to Am. Compl. | \$475.00 | 0.2 | \$95.00 |
| 01/21/2020 | DW | Meeting | Meeting w/ AJJ, re: response to Am. Compl. | \$425.00 | 0.2 | \$85.00 |
| 01/22/2020 | DW | Review | Reviewed Order granting pro hac vice admission | \$425.00 | 0.1 | \$42.50 |
| 01/22/2020 | DW | Research & Draft | Researched and drafted response to Amended Complaint | \$425.00 | 1.0 | \$425.00 |
| 01/23/2020 | DW | Teleconference | Spoke with Clerk's attorney, re: response to amended complaint | \$425.00 | 0.2 | \$85.00 |
| 01/24/2020 | DW | Various | Completed Answer/MTDismiss Amended Complaint; filed with Court; sent copy to Client | \$425.00 | 1.0 | \$425.00 |
| 01/24/2020 | DW | Draft | Drafted and filed Notice of Unavailability | \$425.00 | 0.4 | \$170.00 |
| 01/24/2020 | AJJ | Review | Reviewed final Answer/MTDismiss | \$475.00 | 0.2 | \$95.00 |
| 01/27/2020 | DW | Review | Reviewed Clerk's Answer/MTDismiss | \$425.00 | 0.3 | \$127.50 |
| 02/03/2020 | DW | Review | Reviewed Order setting hearing on Defs' MTDismiss | \$425.00 | 0.1 | \$42.50 |
| 02/03/2020 | DW | Teleconference | Spoke w/ client, re: order setting MTDismiss hearing for March 24, 2020 | \$425.00 | 0.5 | \$212.50 |
| 03/13/2020 | DW | Review | Reviewed PI's Opposition to Aronberg MTDismiss & Clerk's MTDismiss | \$425.00 | 1.5 | \$637.50 |
| 03/13/2020 | AJJ | Review | Reviewed PI's Opposition to Aronberg MTDismiss & Clerk's MTDismiss | \$475.00 | 0.7 | \$332.50 |
| 03/18/2020 | DW | Teleconference | Reviewed email from PI's counsel, re: motion to continue hearing | \$425.00 | 0.1 | \$42.50 |
| 03/18/2020 | DW | Review | Reviewed PI's unopposed motion for continuance | \$425.00 | 0.1 | \$42.50 |
| 03/18/2020 | DW | E-mail | Emails w/ Clerk's counsel, re: PI's request to continue hearing | \$425.00 | 0.2 | \$85.00 |
| 03/19/2020 | DW | E-mail | Reviewed email from PI, re: agreed order & responded | \$425.00 | 0.1 | \$42.50 |
| 03/20/2020 | DW | Review | Reviewed Court's agreed order continuing hearing | \$425.00 | 0.1 | \$42.50 |

| 04/21/2020 04/21/2020 | DW DW | Review Teleconference | Reviewed order rescheduling hearing on Dels' MTDismiss | \$425.00 |  | 0.1 | \$42.50 |
| ----------------------- | ------- | ----------------------- | ------------------------------------------------------------------------------- | ------------------------------------------------------------ | ------- | ----- | ------------ |
|  |  |  | hearing for June 3, 2020 | 5425.00 |  | 0.3 | \$127.50 |
| 04/21/2020 | AU | Review | Reviewed Order rescheduling MTDismiss hearing | \$475.00 |  | 0.1 | \$47.50 |
| 05/2212020 | OW | Review | Reviewed order setting Zoom hearing, re: |  |  |  |  |
|  |  |  | MTDismiss | \$425.00 |  | 0.1 | \$42.50 |
| 05/22/2020 | DW | Teleconference | Spoke w/ client, re: hearing will be via Zoom | \$425.00 |  | 0.2 | \$85.00 |
| 05/27/2020 | OW | Review | Reviewed Glories ling: change of any of record | \$425.00 |  | 0.1 | \$42.50 |
| 05/27/2020 | DW | Teleconference | Spoke with Clerk's new counsel. Nicole Fingerhut | \$425.00 | i | 0.2 | \$85.00 |
| 05/28/2020 | DW | E-mail | Reviewed Pt's email, re: cases and authorities for |  |  |  |  |
|  |  |  |  | \$425.04n | altS1 |  | \$42.50 |
| 05/29/2020 | DW | Preparation | Began oral argument prep for 6/8 MTDismiss MTDismiss hearing; responded | e2N. |  | 1.0 | \$425.00 |
| 06/01/2020 | DW | E-mail | Reviewed email from Judge Marx's JA and |  |  |  |  |
|  |  |  | responded | L\$425.00 ) |  | 0.1 | \$42.50 |
| 06/02/2020 | DW | Various | Reviewed Prs 500+ page binder, re: MT • |  |  |  |  |
|  |  |  | prepped for hearing | \$425.00 |  | 3.0 | \$1,275.00 |
| 06:02/2020 | DW | E-mail | Drafted and sent email to client, re. a |  |  |  |  |
|  |  |  | tomorrow A |  |  |  |  |
|  |  |  |  | \$425.00 |  | 0.1 | \$42.50 |
| 06/03/2020 | DW | Attend Hearing | Prepped for and attended ON 'I ng via |  |  |  |  |
|  |  |  | Zoom A |  |  |  |  |
|  |  |  |  | \$425.00 |  | 1.5 | \$637.50 |
| 06/03/2020 | DW | Teleconference | Spoke w/ Client, re. 1814ciffsmiss hearing | \$425.00 |  | 0.5 | \$212.50 |
| 06/03/2020 | DW | E-mail | Emailed courses co of Aronberg's Answer and |  |  |  |  |
|  |  |  | MTDismiss. ge |  |  |  |  |
|  |  |  |  | \$425.00 |  | 0.1 | \$42.50 |
| 06/03/2020 | DW | E-mail | Reviewed re se from Client and replied | \$425.00 |  | 0.1 | \$42.50 |
| 06/03/2020 | AU | Attend Hearing | Alleuxlik‘MtaisMiss hearing via Zoom | \$475.00 |  | 1.0 | \$475.00 |
| 06/03/2020 | AU | Review | Reviewed order granting MTDismiss w/ prejudice | 3475.00 |  | 0.3 | \$142.50 |
| 06/08/2020 | DW | Review | Rei4Sed Courts Order Granting Defendants |  |  |  |  |
|  |  |  | MTDismiss Count II w/ Prejudice | \$425.00 |  | 0.5 | \$212.50 |
| 06/08/2020 | DW | VanOis | Shared order w/ Client and Spoke w/, result and |  |  |  |  |
|  | II |  | plan going forward, re: 57.105 Researched § 57.105 Fla. Stat.: drafted 57.105 | \$425.00 |  | 0.5 | \$212.50 |
|  | OW • | Varibus |  |  |  |  |  |
| 06/08/2020 |  | __ ., | letter and proposed motion. | \$425.00 |  | 2.0 | \$850.00 |
| 06/08/2020 | AU | Meeting | Meeting wi DAW, re: Order & 57.105 | \$475.00 |  | 0.3 | \$142.50 |
| 06/08/2020 | DW | Meeting | Meeting w/ AU. re: Order 8. 57.105 | \$425.00 |  | 0.3 | \$127.50 |
| 06/08/2020 | AIJ | Review | Reviewed 57.105 demand and proposed motion for |  |  |  |  |
|  |  |  | sanction | \$475.00 |  | 0.2 | \$95.00 |
| 06/10/2020 | DW | Various |  | \$425.00 Reviewed notice of change of attorney, re: Clerk: |  |  |  |
|  |  |  | called and spoke w/ new counsel Cynthia Guerra |  |  | 0.3 | \$127.50 |
| 0623/2020 | DW | Various |  |  |  |  |  |
|  |  |  |  | \$425.00 |  | 1.0 | \$425.00 |

| 06/23/2020 | DW | E-mail | Sent client copy of PCs letter refusing to dismiss |  |  |  |
| ------------ | ------- | ---------------- | ---------------------------------------------------- | -------------- | ----- | ---------- |
|  |  |  | complaint | \$425.00 | 0.1 | \$42.50 |
| 06/23/2020 | AU | Review | Reviewed Fts letter refusing to dismiss Count VAm. |  |  |  |
|  |  |  | Cornpl. | \$47600 | 0.1 | \$47.50 |
| 07/01/2020 | DW | Various |  |  |  |  |
|  |  |  |  | \$425.00 | 0.5 | \$212.50 |
| 07/02/2020 | OW | E-mail | Email to client re: affidavit and summary judgment | \$425.00 | 0.1 | \$42.50 |
| 07/08/2020 | DW | Teleconference | Discussed w/ Client drafting and filing Motion for |  |  |  |
|  |  |  | Summary Judgment and MSJ evidence | \$425.00 | 0.7 |  |
| 07A58/2020 | AU | Teleconference | Discussed w/ Client drafting and Ming Motion for |  |  |  |
|  |  |  | Summary Judgment and MSJ evidence | \$475.00 |  |  |
| 07/10/2020 | DW | Draft | Created 1st draft of Aronberg Affidavit: shared w/ |  |  |  |
|  |  |  |  |  | 1.0 | \$425.00 |
| 07/10/2020 | AU | Various | Reviewed draft affidavit and discussed w/ DAW | — 75.00I | 0.3 | \$142.50 |
| 07/10/2020 | DW | Meeting | Discussed draft affidavit w/ AU II | \$425.00 | 0.2 | \$85.00 |
| 07/13/2020 | DW | Review | Reviewed Pl's Request to Produce, re: Genic/N | ‘ ---5425.00 | 0.1 | \$42.50 |
| 07/13/2020 | OW | Teleconference | Spoke w/ Clerk's counsel, re: Requestt6Prod ,I | \$425.00 | 0.2 | \$85.00 |
| 07/27/2020 | DW | Review | Reviewed PCs Amended Request Sci/Produce. re: |  |  |  |
|  |  |  | Clerk | \$425.00 | 0.1 | \$42.50 |
| 07/27/2020 | OW | Teleconference |  |  |  |  |
|  |  |  | Spoke w/ Clerk's counsel, need Request to |  |  |  |
|  |  |  | Produce | \$425.00 | 0.1 | \$42.50 |
| 07/28/2020 | DW | Draft | Revised Aronberii,Cfidavi 7 | \$425.00 | 0.5 | \$212.50 |
| 07/29/2020 | DW | Draft | Finaized Aro rg ralvit and sent to client | \$425.00 | 0.5 | \$212.50 |
| 07)29/2020 | OW | Research 8 |  |  |  |  |
|  |  |  | Research Motion for Summary |  |  |  |
|  |  |  |  | \$425.00 | 1.0 | \$425.00 |
| 07/30/2020 | DW | Various | FtereeiviiizAted Aronberg Affidavit | \$425.00 | 0.1 | \$42.50 |
| 07/30/2020 | OW | Draft | E' agan drafting Motion for Summary Judgment | \$425.00 | 2.0 | \$850.00 |
| 08/05/2020 | OW | Draft | Continued drafting Motion for Summary Judgment | \$425.00 | 1.0 | \$425.00 |
| 08/07/2020 | OW | Review / |  |  |  |  |
|  |  |  | hearing on 57.105 motion for fees/sanctions | \$425.00 | 0.1 | \$42.50 |
| 08/102020 | OW | E-mail | Sent responsive email to PIS counsel | \$425.00 | 0.1 | \$42.50 |
| 08/17/2020 | OW if | Meebng ' | Discussed draft M5,1w/ AU | \$425.00 | 0.2 | \$85.00 |
| 08/17/2020 | Au., | Various | Reviewed draft MSJ and met w/ DAW to discuss | \$475.00 | 0.5 | \$237.50 |
| 08/18/2020 | OW | Draft | Finalized Motion for Summary Judgment; tiled w/ |  |  |  |
|  |  |  | court along with Aronberg affidavit | \$425.00 | 2.0 | \$850.00 |
| 08/27/2020 | DW | Teleconference | Spoke w/ Clerk's counsel, re: request to produce | \$425.00 | 0.1 | \$42.50 |
| 09101/2020 | OW | Various | Reviewed Fts email and accepted conference call |  |  |  |
|  |  |  | invite for 9/2/20 | 5425.00 | 0.1 | \$42.50 |
| 09/02/2020 | DW | Review | Reviewed genes response to request for |  |  |  |
|  |  |  | production | \$425.00 | 0.2 | \$85.00 |
| 09/02/2020 | DW | Teleconference |  |  |  |  |
|  |  |  |  | \$425.00 | 0.5 | \$212.50 |

| 09/02/2020 | AU | Meeting | Discussed w/ DAW phone call w/ F1's counsel | \$475.00 | 0.2 | \$95.00 |
| ------------ | ---- | -------------------- | ---------------------------------------------------- | --------------- | ------- | ------------ |
| 09/02/2020 | OW | Meeting | Discussed WI AU phone cal w/ Prs counsel | \$425.00 | 0.2 | \$85.00 |
| 09/16/2020 | DW | E-mail |  |  |  |  |
|  |  |  |  | \$425.00 | 0.1 | \$42.50 |
| 09/17/2020 | OW | Meeting | Discussed w/ AU filing motion for CMC | \$425.00 | 0.1 | \$42.50 |
| 09/17/2020 | AU | Meeting | Discussed w/ DAW filing motion for CMC | \$475.00 | 0.1 | \$47.50 |
| 09/18/2020 | DW | Various | Drafted and filed motion to set case management |  |  |  |
|  |  |  | conference; re: MSJ 1st or Fee hearing 1st | \$425.00 | 0.5 | \$212.50 |
| 09/18/2020 | DW | E-mail |  |  |  |  |
|  |  |  |  | \$425.00 A0.1 |  | \$42.50 |
| 09/182020 | OW | E-mail | Reviewed Prs email insisting that 57.105 motion be |  |  |  |
|  |  |  | withdrawn | \$425c | , 0.1 | \$42.50 |
| 09/18/2020 | DW | E-mail |  |  |  |  |
|  |  |  |  | ( 14/ | 0.1 | \$42.50 |
| 0918/2020 | DW | E-mail | Sent client copy of email exchange w/ Prs |  |  |  |
|  |  |  |  | \$425.00 | 0.5 | \$212.50 |
| 09/22/2020 | OW | Various | Drafted and filed Notice of Hearing 1 |  |  |  |
|  |  |  |  | \$425.00 | 0.7 | \$297.50 |
| 10/02/2020 | OW | Review | Reviewed Fts Memo of Law, nberg's |  |  |  |
|  |  |  | 57.105 motion for fees/ | \$425.00 | 0.7 | \$297.50 |
| 10/02/2020 | OW | Review | Reviewed Pt's R Ar rg's request to |  |  |  |
|  |  |  | schedule 57.105 fo after MSJ | \$425.00 | 0.5 | \$212.50 |
| 10;02/2020 | AU | Review | Reviewed ' limo 0 opposing 57.105 |  |  |  |
|  |  |  | motion | 3475.00 | 0.5 | \$237.50 |
| 10/02/2020 | AU | Review | pt's nse to Aronberg's request to |  |  |  |
|  |  |  | schedeili<S7.)05 motion after MSJ | \$475.00 | 0.4 | \$190.00 |
| 10/12/2020 | DW | Research | Research caselaw & statutes. re: response to Prs |  |  |  |
|  |  |  | litemoOf Law | \$425.00 | 1.0 | \$425.00 |
| 10113/2020 | DW | Research a '-',, , |  |  |  |  |
|  |  |  |  | \$425.00 | 1.0 | \$425.00 |
| 10113/2020 | OW | Oraft | Created 1st draft of Response to PI'S Memo of Law |  |  |  |
|  |  |  | and shared w/ Client | \$425.00 | 4.0 | \$1,700.00 |
| 10/13/2020 | DW | Meeting | Discussed w/ AIJ caselaw and draft response to |  |  |  |
|  |  |  |  | \$425.00 | 0.5 | \$212.50 |
| 10/13/2020 | AU | Various | Reviewed draft MSJ, discussed draft w/ DAW and |  |  |  |
|  |  |  | caselaw | \$475.00 | 0.7 | \$332.50 |
| 10/14/2020 | DW | Draft | Finalized and filed Response to Prs Memo of Law | \$425.00 | 1.0 | \$425.00 |
| 10/14/2020 | DW | Telephone | Spoke wr client, re: memo of law | \$425.00 | 0.2 | \$85.00 |
| 10/14/2020 | OW | Telephone | Spoke wr client again, re: response to memo of law | \$425.00 | 0.1 | \$42.50 |
| 10/15/2020 | OW | Attend Hearing | Attended hearing, re: Motion to Set CMG: called |  |  |  |
|  |  |  | client to discuss | \$42540 | 1.5 | \$637.50 |
| 10/15/2020 | DW | Various | Reviewed email and letter from PI, re: settlement. |  |  |  |
|  |  |  | Sent copy to Client and called to discuss. | \$425.00 | 0.5 | \$212.50 |

| 10/15/2020 | DW | Telephone | Spoke w/ PI's counsel, re: settlement | \$425.00 | 0.1 | \$42.50 |
| ------------ | ---- | ----------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------- | ----- | ---------- |
| 10/15/2020 | DW | Telephone | Spoke w/ client, re: PI's settlement proposal | \$425.00 | 0.2 | \$85.00 |
| 10/15/2020 | AJ | Various | Attended hearing, re: motion to set CMC; discussed w/ client | \$475.00 | 1.0 | \$475.00 |
| 10/15/2020 | AJ | Various | Discussed PI's settlement proposal w/ DAW and then w/ Client | \$475.00 | 0.4 | \$190.00 |
| 10/15/2020 | DW | Meeting | Discussed PI's settlement proposal w/ AJ | \$425.00 | 0.2 | \$85.00 |
| 10/16/2020 | DW | Various | Drafted and shared proposed order w/ PI's counsel | \$425.00 | 0.5 | \$212.50 |
| 10/16/2020 | DW | Telephone | Spoke w/ PI's counsel, re: settlement | \$425.00 | 0.2 | \$85.00 |
| 10/16/2020 | DW | Telephone | Spoke w/ client, re: PI's settlement proposal | \$425.00 | 0.5 | \$212.50 |
| 10/16/2020 | DW | Meeting | Discussed PI's settlement proposal w/ AJ | \$425.00 | 0.2 | \$85.00 |
| 10/16/2020 | AJ | Meeting | Discussed PI's settlement proposal w/ DAW | \$475.00 | 0.2 | \$95.00 |
| 10/19/2020 | DW | Various | Uploaded proposed order, re: CMC for Judge Hafele | \$425.00 | 0.1 | \$42.50 |
| 10/19/2020 | DW | Telephone | Spoke w/ client, re: PI's settlement proposal | \$425.00 | 0.2 | \$85.00 |
| 10/19/2020 | DW | Telephone | Spoke w/ PI's counsel, re: settlement | \$425.00 | 0.1 | \$42.50 |
| 10/19/2020 | AJ | Meeting | Discussed PI's settlement proposal w/ DAW | \$475.00 | 0.2 | \$95.00 |
| 10/19/2020 | DW | Meeting | Discussed PI's settlement proposal w/ AJ | \$425.00 | 0.2 | \$85.00 |
| 10/20/2020 | DW | Various | Reviewed email from PI, re: settlement; sent copy to Client and called to discuss | \$425.00 | 0.5 | \$212.50 |
| 10/20/2020 | DW | Telephone | Spoke w/ client, re: settlement | \$425.00 | 0.4 | \$170.00 |
| 10/20/2020 | DW | Telephone | Spoke w/ PI's counsel, re: settlement | \$425.00 | 0.1 | \$42.50 |
| 10/20/2020 | DW | Telephone | Spoke w/ client, re: settlement | \$425.00 | 0.1 | \$42.50 |
| 10/20/2020 | DW | Meeting | Discussed PI's settlement proposal w/ AJ | \$425.00 | 0.2 | \$85.00 |
| 10/20/2020 | AJ | Meeting | Discussed PI's settlement proposal w/ DAW | \$475.00 | 0.2 | \$95.00 |
| 10/21/2020 | DW | Various | Drafted and filed Motion to Set Hearing on Aronberg MSJ; drafted proposed order granting motion to set; checked court availability; emailed PI's counsel, re: choose date for hearing | \$425.00 | 1.0 | \$425.00 |
| 10/21/2020 | DW | Review | Reviewed Order, re: CMC unnecessary | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | \$425.00 | 0.2 | \$85.00 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | DW | Telephone | Spoke w/ client, re: media response | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | DW | E-mail | Sent email w/ Aronberg statement to media | \$425.00 | 0.1 | \$42.50 |
| 10/21/2020 | AJ | Meeting | Discussed media response w/ DAW | \$475.00 | 0.3 | \$142.50 |
| 10/21/2020 | DW | Meeting | Discussed media response w/ AJ | \$425.00 | 0.3 | \$127.50 |
| 10/22/2020 | DW | Various | Reviewed PI's Notice of Dropping Aronberg as party; spoke w/ Client and AJ, re: notice and next steps | \$425.00 | 0.5 | \$212.50 |

| 10/22/2020 | AJJ | Various | Reviewed PI's Notice of Dropping Aronberg as party; spoke w/ Client and DAW, re: notice and next steps | \$475.00 | 0.5 | \$237.50 |
| ------------ | ----- | --------- | -------------------------------------------------------------------------------------------------------- | ---------- | ----- | ---------- |
| ------------ | ----- | --------- | -------------------------------------------------------------------------------------------------------- | ---------- | ----- | ---------- |

Totals: 74.8      \$32,440.00

| Time Entry Sub-Total: | \$32,440.00 |
| ----------------------- | -------------------- |
| **Sub-Total:** | \$32,440.00 |
| **Total:** | \$32,440.00 |
| **Amount Paid:** | \$0.00 |
| **Balance Due:** | **\$32,440.00** |