Affidavit of defense counsel seeking $39,950 in fees from the Palm Beach Post's publisher

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.
1. 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.
1. 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.¶

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
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
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
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”¶

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}sMo 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}er, would show that on June 8, 2020, Plaintiff was served {sup}acopy 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”¶

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”¶

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

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Affidavit of defense counsel seeking $39,950 in fees from the Palm Beach Post's publisher

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

AFFIDAVIT OF ATTOR1c9¶

STATE OF FLORIDA COUNTY OF NASSAU¶

SCHOLZ 8c WYLER, LLC.¶

VIA ELECTRONIC & U.S. MAIL¶

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

DEFENDANT, DAVE ARONBERG’S MOTION FOR ATTORNEYS’ FEES¶

EXHIBIT “B”¶

EXHIBIT “B”¶

PLAINTIFF CA HOLDINGS’ ,LC e NOTICE OF DROPPING STATE ATTO IrT,A E ARONBERG • V¶

CERTIFICATE¶

Time Entries¶

Aronberg (SAO15) adv. CA Florida Holdings, LLC¶