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,¶
Plaintiff,¶
v.¶
CASE NO.: 19-CA-014681¶
DAVE ARONBERG, as State Attorney of Beach County, Florida.¶
Defendants.¶
AFFIDAVIT OF ATTORNEYS’ FEES¶
STATE OF FLORIDA COUNTY OF NASSAU¶
BEFORE ME, the undersigned authority appeared Douglas A. Wyler, Esq., who, after being first duly sworn, deposes and says:¶
-
Affiant is a partner of JACOBS, SCHOLZ & WYLER, LLC, counsel for Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, (“Aronberg”), as well as general counsel to the Florida Prosecuting Attorneys Association, (“FPAA”), and makes this Affidavit of his own personal knowledge.
-
Affiant is licensed to practice law in the State of Florida, is an active member of the Florida Bar in good standing and has engaged in the practice of law in the State of Florida since 2015.
-
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 1 of Plaintiff’s Amended Complaint
Party JOINT¶
. • and Plaintiffs October 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the • aboye7captioned lawsuit. See,. Exhibits “A” and qB” attacfreif hereto.. • •¶
• . 4. The total time Affiantil law.firm has expended serVices rendered to date is 74.8 . • hours, however, from the date of Defendant iiicinberg’s 57.105 demand; Affiatit’s law flint expended a total of 421 boors. Of the 42.2 hours. since Defendant Aronbe 57.195 , . • ” • deritendWas served, the Aft-lent¶
. Of the 42.2 hours expended since Defendant Aronberg’ and was.: • . . served, the total time ‘Affiant has expended services rendered to date ’ rs at the rate of • $425.00 per hour. LikeWite,the total time Affianestayi pa has expended services rendered to date is 6.8 hours at the rate of $475.¶
_ • . .’ AcCordingly, since Defendant Aron demand was served, Defendant Aronberg’s counsel, JACOBS, SCHOLZ & W L , has rendered services in the amount of $18,275.00, in conjunction with the d instant action pursuant to § 57.105, Florida Statutes. See, Exhibit “C” attache¶
- Affiant expec additional 4.0 hours at $425.00 an hour in preparing for and attending the hearing o tto eys’ fees. Thus, the total amount of hourly attorneys’ fees the State Attorney is see t6 ’ .2 hours for a total of $19,975.00. Additionally, the State Attorney seeks a rritilf ier of 2. , which when applied makes the grand total attorneys’ fees sought herein $39,9 DaOday of November, 2020.
FURTHER AFFIANISAYETH NOT.¶
STATE OF FLORIDA . COUNTY (*.NASSAU. • • • . • • • • • •• •¶
The foregoing instrument was acknowledged before me this 9th day of November, 2020, by Do . Wyler, Esquire, who is personilly known to rneind who did take an oath. •¶
• •¶
Sign wary Public — State of Florida¶
Name typed, printed or stamped¶
CERTIFICATE OF SERVICE¶
I HEREBrCERTIFY that on this 9th day of Novem a copy of the foregoing has been electronically filed with the Florida E-File Portal on all patties of record herein.¶
O¶
SCHOLZ & WYLER, LLC¶
ugh: A. Wyler¶
Arthur I. Esq. Ha. Bar No.: 10249 • Richard J. Scholz, Esq. Fla. Bar No.: 0021261 Douglas A. Wykr, Esq. Fla. Bar No.: 119979 961687 GateWay Blvd., Suite 201-I Fernandina Beach, Florida 32034 (904)261-3693 (904) 261-7879 Fax Primary: jacobsscholzlaw@comcast.net¶
Attorneys for Defendant. Dave Aronberg¶
EXHIBIT “A”¶
EXHIBIT “A”¶
sawed: SERVICE OF CURT DOCUMENT CASE NO; 1019-CA-014881; CA FLORIDA HOLDINGS, LLC V. DAVE AR0N118RG ET AL. DIM: Monday, June 8, 2020 at3:88:58 PM Eastern Daylight Time Freely To: ‘mendelsohns.gtlaw.cOme, smithleigtlaw.com, fiserviceegtlaw.corp, BoyalianNtbatlaw.Com, riveraal@gtia,coin, GRYGIELMCagtlaw.com Attachments: 2020-06;08 Aronberg 57.105 DeMand and Motion for Attorney? Fees.pdf¶
Court: Case No: Plaintiff: Defendant: Title of Documents Served: …• Sender’s Name and Telephone Number: Circuit Court of the Fifteenth Judicial Circuit, in and for Pairn. Florida • ” Case:No. 2020-CA-014681 CA Florida Holdings, LLC Dave Aronbetg • Fla. Stat.* 57.10S Demand Letter •; Defendant, Dave Aronberg’s Motion Douilas Wyler (904) 261.3693 orneys’ Fees¶
Sincerely,¶
Doug Wyler, Esq. Scholcaleyler, LLC t 961687 Gateway Blvd., STE 201-I Fernandina Beach, FL 32034 904-261-3693 904-261-7879 (fax)¶
Please be advised that this e-ma nd a y files transmitted with It are confidential attorney-client communication or may otherwise rivileged or confidential and are intended solely for the Individual or entity to whom they are sed. If you are not the intended recipient, please do not read, copy or retransmit this Communica t destroy it immediately. Any unauthorizeildissemination, distribution or copying of this co tt unitab is strictly prohibited.¶
SCHOLZ & WYLER, LLC.¶
A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS¶
ATTORNEYS AT LAW¶
GATEWAY TO AMELIA¶
961887 GATEWAY BLVD., SUITE 201-1¶
FERNANDINA BEACH, FLORIDA 32004¶
TELEPHONE (904) 261-3693¶
FAX NO. (904) 261-7879¶
THE LAW OFFICES OF [REDACTED] ASSOCIATES, P.A. ARTHUR I. [REDACTED]¶
RICHARD J. SCHOLZ, P.A. RICHARD J. SCHOLZ¶
DOUGLAS A. WYLER, P.A. DOUGLAS A. WYLER¶
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 al. Palm Beach County, Case No.: 2019-CA-014681¶
Dear Mr. Mendelsohn:¶
As you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach County, Florida, in the above referenced [REDACTED] letter. The purpose of this letter is to demand the voluntary dismissal of your First Amended Complaint, (the “Complaint”), dated January 17, 2020. This demand is made pursuant to section 57.105, Florida Statutes.¶
As you know, Section 57.105 provides:¶
- (1) Upon the court’s initiative or motion of any party, the court shall award a reasonable attorney’s fee, including prejudgment interest, to be paid to the prevailing party in equal amounts by the losing party and the losing party’s attorney on any claim or defense at any time during a civil proceeding or action in which the court finds that the losing party or the losing party’s attorney knew or should have known that a claim or defense when initially presented to the court or at any time before trial:
- a. Was 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 II of the Plaintiff’s Complaint. Pursuant to the Court’s ruling, the Plaintiff’s only remaining cause of action consists of Count I, 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 for declaratory relief fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes, which states:¶
When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil case, it may be disclosed to all parties to the case and to their attorneys and by the latter to their legal associates and employees. However, the grand jury testimony afforded such persons by the court can only be used in the defense or prosecution of the civil or criminal case and for no other purpose whatsoever.¶
Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable to comply with any court order granting disclosure of the requested documents because neither Mr. Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession, custody, or control of the 2006 Epstein grand jury records.¶
Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter, the enclosed Motion for Attorney’s Fees will be filed and we will seek as sanctions, from your client and your firm, recovery of the legal expenses incurred in defending this frivolous action.¶
Please govern yourself accordingly.¶
Douglas A. Wyler, Esq. For the Firm¶
Encl.: Defendant’s Motion for Attorneys’ Fees¶
IN THE CIRCUIT ppuET OF THE FIFTEENTH JUDICIAL CIRCUIT f• . IN AND FOR PAIIIIREACH COUNTY, FLORIDA • , •¶
CA FLORIDA HOLDINGS, LLC, Publisher of the palm BEACH POST,¶
Plaint4¶
•¶
DAVE AEoM3Eag. as State Attorney of OchO Batch Cowl% Florida; SHARON R. BOCIC,is Clerk and Comptroller of Palm Beach’County, Florida.¶
Defendants,¶
DEFENDANT, DAVE ARONBERG’S M ATTORNEYS’FEES¶
Defendant, DAVE ARONBERG, as Sta tSor f Palm Beach County, Florida, by and through the undersigned attorneys, moves ursuant to Florida Statutes, Section 57.105, to award him reasonable attorneys’ ( for S defense of Plaintiffs First Amended Complaint, p (the “Complaint”), and as.gro , would show that on June 1;2020, Plaintiff was served {sup}acopy of this Motion, to the, a letter from the undersigned attorney, in accordance with subsection (4) of the above , demanding disrnissal of the Complaint, at least 71 days prior to the filing of this to . In said letter, Defendant’s attorney advised Plaintiff of the facts which establish t a Complaint is without support of the facts or the law.¶
ORE, Defendant, DAVE ARONBERO, as State Attorney’ of Palm Beach Florida, respectfully requests the Cowl enter an Order requiring Plaintiff and Plaintiff’s atto cys 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 elecirotheally filed via the Florida Portal for electronic service on the parties i;frecord herein.¶
JACOBS SCHOLZ & WYjig, tic ’¶
4.rippyglps A Wper.¶
Arthur:I.. Jacoha, Esquire Fla. Bar No.: 108249 Richard). Seholz, Esquire Fla..0ar NO.: 0021261 Douglas A. Wyl Tie. Bar No.: 961687 Gatewl ., Suite 2014 Ferhapd’ h, Florida 32034 • (904) ( to aw@comcast.net¶
ttbeys for Defendant¶
Gs’¶
EXHIBIT “B”¶
EXHIBIT “B”¶
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,¶
Plaintiff,¶
v.¶
DAVE ARONBERG, as State Attorney of Beach County, Florida,¶
Defendants.¶
PLAINTIFF CA HOLDINGS, LLC’S NOTICE OF DROPPING STATE ATTORNEY, DAVE ARONBERG¶
Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ. P. 1250(b), hereby notifies the parties that it has dropped State Attorney, Dave Aronberg from the above case.¶
Respectfully submitted,¶
GREENBERG TRAURIG, P.A. Attorneys for CA Florida Holdings, LLC, 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 mendelsohns@gtlaw.com smithl@gtlaw.com FLService@gtlaw.com¶
By: /s/ Michael J Grygiel MICHAEL J GRYGIEL (Admitted Pro Hac Vice) 54 State St., 6th Floor Albany, New York 12207 Telephone: (518) 689-1400 Facsimile: (518) 689-1499 grygielm@gtlaw.com¶
By: /s/ Nina D. Boyajian NINA D. BOYAJIAN (Admitted Pro Hac Vice) 1840 Century Park East, Suite 1900 Los Angeles California 90067 Telephone: (310) 586-7700 Facsimile: (310) 586-7800 boyajiann@gtlaw.com riveraal@gtlaw.com¶
CERTIFICATE OF SERVICE¶
I HEREBY CERTIFY that on this 21{sup}st day of October, 2020, a true and correct copy of the foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which will send a notice of electronic service for all parties of record herein¶
/s/ Stephen A. Mendelsohn STEPHEN A. MENDELSOHN¶
ACTIVE 53317341v1¶
EXHIBIT “C”¶
EXHIBIT “C”¶
[REDACTED] Scholz & Wyler, LLC 961687 Gateway Blvd., Suite 2011 Fernandina Beach, FL 32034 United States 904-261-3693¶
Jacobs Scholz & Wyler, LLC¶
Dave Aronberg¶
Balance $32,440.00 Invoice # 00307 Invoice Date November 6, 2020 Payment Terms Due Date¶
Aronberg (SAO15) adv. CA Florida Holdings, LLC¶
Time Entries¶
| Date | EE | Activity | Description | Rate | Hours | Line Total |
|---|---|---|---|---|---|---|
| 11/26/2019 | DW | Review | Initial review of summons and complaint. | $425.00 | 1.5 | $637.50 |
| 11/26/2019 | DW | Review | Reviewed motion for pro hac vice and Judge Hafele’ order granting. | $425.00 | 0.2 | $85.00 |
| 11/26/2019 | DW | Teleconference | Teleconference w/ Client, re: response to lawsuit | $425.00 | 0.5 | $212.50 |
| 11/26/2019 | DW | Draft | Drafted engagement letter and sent to client | $425.00 | 0.3 | $127.50 |
| 11/26/2019 | DW | Review | Reviewed 15th circuit local rules | $425.00 | 1.0 | $425.00 |
| 11/26/2019 | AJ | Review | Initial review of complaint | $475.00 | 1.0 | $475.00 |
| 11/26/2019 | AJ | Meeting | Meeting w/ DAW to discuss lawsuit and strategy | $475.00 | 0.5 | $237.50 |
| 11/26/2019 | DW | Meeting | Meeting w/ AJ to discuss lawsuit and strategy | $425.00 | 0.5 | $212.50 |
| 11/26/2019 | AJ | Teleconference | Teleconference w/ Client, re: response to lawsuit | $475.00 | 0.5 | $237.50 |
| 12/02/2019 | DW | Research & Preparation | Research and prep for Motion to dismiss | $425.00 | 2.0 | $850.00 |
| 12/02/2019 | DW | Draft | 1st Draft motion to dismiss | $425.00 | 1.0 | $425.00 |
| 12/02/2019 | DW | Teleconference | Teleconference w/ Client, re: draft motion to dismiss | $425.00 | 0.5 | $212.50 |
| 12/02/2019 | AJ | Review | Reviewed 1st Draft MTDismiss | $475.00 | 0.3 | $142.50 |
| 12/02/2019 | AJ | Teleconference | Teleconference w/ client, re: draft motion to dismiss | $475.00 | 0.5 | $237.50 |
| 12/03/2019 | AJ | Meeting | Meeting w/ DAW, re: motion to dismiss | $475.00 | 0.2 | $95.00 |
| 12/03/2019 | DW | Meeting | Meeting w/ AJ, re: MTDismiss | $425.00 | 0.2 | $85.00 |
| 12/06/2019 | DW | 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 |
| 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 | Emails w/ Clerk’s counsel, re: PI’s request to continue hearing | $425.00 | 0.2 | $85.00 | |
| 03/19/2020 | DW | 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 | DW | Review | Reviewed order rescheduling hearing on Defs’ MTDismiss | $425.00 | 0.1 | $42.50 |
|---|---|---|---|---|---|---|
| 04/21/2020 | DW | Teleconference | Spoke w/ client, re: order rescheduling MTDismiss hearing for June 3, 2020 | $425.00 | 0.3 | $127.50 |
| 04/21/2020 | AJ | Review | Reviewed Order rescheduling MTDismiss hearing | $475.00 | 0.1 | $47.50 |
| 05/22/2020 | DW | 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 | DW | Review | Reviewed Clerk’s filing: change of atty of record | $425.00 | 0.1 | $42.50 |
| 05/27/2020 | DW | Teleconference | Spoke with Clerk’s new counsel, Nicole Fingerhut | $425.00 | 0.2 | $85.00 |
| 05/28/2020 | DW | Reviewed PI’s email, re: cases and authorities for MTDismiss hearing; responded | $425.00 | 0.1 | $42.50 | |
| 05/29/2020 | DW | Preparation | Began oral argument prep for 6/8 MTDismiss hearing | $425.00 | 1.0 | $425.00 |
| 06/01/2020 | DW | Reviewed email from Judge Marx’s JA and responded | $425.00 | 0.1 | $42.50 | |
| 06/02/2020 | DW | Various | Reviewed PI’s 500+ page binder, re: MTDismiss & prepped for hearing | $425.00 | 3.0 | $1,275.00 |
| 06/02/2020 | DW | Drafted and sent email to client, re: MTD hearing tomorrow | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | DW | Attend Hearing | Prepped for and attended MTDismiss hearing via Zoom | $425.00 | 1.5 | $637.50 |
| 06/03/2020 | DW | Teleconference | Spoke w/ Client, re: debrief MTDismiss hearing | $425.00 | 0.5 | $212.50 |
| 06/03/2020 | DW | Emailed courtesy copies of Aronberg’s Answer and MTDismiss to Judge Marx | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | DW | Reviewed response from Client and replied | $425.00 | 0.1 | $42.50 | |
| 06/03/2020 | AJ | Attend Hearing | Attended MTDismiss hearing via Zoom | $475.00 | 1.0 | $475.00 |
| 06/03/2020 | AJ | Review | Reviewed order granting MTDismiss w/ prejudice | $475.00 | 0.3 | $142.50 |
| 06/08/2020 | DW | Review | Reviewed Court’s Order Granting Defendants MTDismiss Count II w/ Prejudice | $425.00 | 0.5 | $212.50 |
| 06/08/2020 | DW | Various | Shared order w/ Client and spoke w/, re: result and plan going forward, re: 57.105 | $425.00 | 0.5 | $212.50 |
| 06/08/2020 | DW | Various | Researched § 57.105 Fla. Stat.; drafted 57.105 demand letter and proposed motion for attorneys’ fees/sanctions; Served PI’s counsel with demand letter and proposed motion. | $425.00 | 2.0 | $850.00 |
| 06/08/2020 | AJ | Meeting | Meeting w/ DAW, re: Order & 57.105 | $475.00 | 0.3 | $142.50 |
| 06/08/2020 | DW | Meeting | Meeting w/ AJ, re: Order & 57.105 | $425.00 | 0.3 | $127.50 |
| 06/08/2020 | AJ | Review | Reviewed 57.105 demand and proposed motion for sanction | $475.00 | 0.2 | $95.00 |
| 06/10/2020 | DW | Various | Reviewed notice of change of attorney, re: Clerk; called and spoke w/ new counsel Cynthia Guerra | $425.00 | 0.3 | $127.50 |
| 06/23/2020 | DW | Various | Reviewed PI’s letter refusing to voluntarily dismiss amended complaint despite 57.105 demand; called and spoke w/ client, re: PI’s refusal & next steps | $425.00 | 1.0 | $425.00 |
| 06/23/2020 | DW | Sent client copy of PI’s letter refusing to dismiss complaint | $425.00 | 0.1 | $42.50 | |
|---|---|---|---|---|---|---|
| 06/23/2020 | AJJ | Review | Reviewed PI’s letter refusing to dismiss Count I/Am. Compl. | $475.00 | 0.1 | $47.50 |
| 07/01/2020 | DW | Various | Spoke w/ client, re: filing of 57.105 motion for fees/sanctions; filed motion for attorneys’ fees based on PI’s failure to voluntarily dismiss amended complaint count 1 | $425.00 | 0.5 | $212.50 |
| 07/02/2020 | DW | 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 | $297.50 |
| 07/08/2020 | AJJ | Teleconference | Discussed w/ Client drafting and filing Motion for Summary Judgment and MSJ evidence | $475.00 | 0.7 | $332.50 |
| 07/10/2020 | DW | Draft | Created 1st draft of Aronberg Affidavit; shared w/ client | $425.00 | 1.0 | $425.00 |
| 07/10/2020 | AJJ | Various | Reviewed draft affidavit and discussed w/ DAW | $475.00 | 0.3 | $142.50 |
| 07/10/2020 | DW | Meeting | Discussed draft affidavit w/ AJJ | $425.00 | 0.2 | $85.00 |
| 07/13/2020 | DW | Review | Reviewed PI’s Request to Produce, re: Clerk | $425.00 | 0.1 | $42.50 |
| 07/13/2020 | DW | Teleconference | Spoke w/ Clerk’s counsel, re: Request to Produce | $425.00 | 0.2 | $85.00 |
| 07/27/2020 | DW | Review | Reviewed PI’s Amended Request to Produce, re: Clerk. | $425.00 | 0.1 | $42.50 |
| 07/27/2020 | DW | Teleconference | Spoke w/ Clerk’s counsel, re: Amended Request to Produce | $425.00 | 0.1 | $42.50 |
| 07/28/2020 | DW | Draft | Revised Aronberg affidavit | $425.00 | 0.5 | $212.50 |
| 07/29/2020 | DW | Draft | Finalized Aronberg Affidavit and sent to client | $425.00 | 0.5 | $212.50 |
| 07/29/2020 | DW | Research & Preparation | Research and prep for Motion for Summary Judgment | $425.00 | 1.0 | $425.00 |
| 07/30/2020 | DW | Various | Received executed Aronberg Affidavit | $425.00 | 0.1 | $42.50 |
| 07/30/2020 | DW | Draft | Began drafting Motion for Summary Judgment | $425.00 | 2.0 | $850.00 |
| 08/05/2020 | DW | Draft | Continued drafting Motion for Summary Judgment | $425.00 | 1.0 | $425.00 |
| 08/07/2020 | DW | Review | Reviewed email from Plaintiff attempting to set hearing on 57.105 motion for fees/sanctions | $425.00 | 0.1 | $42.50 |
| 08/10/2020 | DW | Sent responsive email to PI’s counsel | $425.00 | 0.1 | $42.50 | |
| 08/17/2020 | DW | Meeting | Discussed draft MSJ w/ AJJ | $425.00 | 0.2 | $85.00 |
| 08/17/2020 | AJJ | Various | Reviewed draft MSJ and met w/ DAW to discuss | $475.00 | 0.5 | $237.50 |
| 08/18/2020 | DW | Draft | Finalized Motion for Summary Judgment; filed 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 |
| 09/01/2020 | DW | Various | Reviewed PI’s email and accepted conference call invite for 9/2/20 | $425.00 | 0.1 | $42.50 |
| 09/02/2020 | DW | Review | Reviewed Clerk’s response to request for production | $425.00 | 0.2 | $85.00 |
| 09/02/2020 | DW | Teleconference | Spoke w/ PI’s counsel, re: dispute as to whether MSJ should be heard before 57.105 fee motion or vis versa - call was unsuccessful | $425.00 | 0.5 | $212.50 |
| 09/02/2020 | AJ | Meeting | Discussed w/ DAW phone call w/ PI’s counsel | $475.00 | 0.2 | $95.00 |
|---|---|---|---|---|---|---|
| 09/02/2020 | DW | Meeting | Discussed w/ AJ phone call w/ PI’s counsel | $425.00 | 0.2 | $85.00 |
| 09/16/2020 | DW | Reviewed email from PI’s counsel requested Aronberg to withdraw sanctions motion w/o prejudice | $425.00 | 0.1 | $42.50 | |
| 09/17/2020 | DW | Meeting | Discussed w/ AJ filing motion for CMC | $425.00 | 0.1 | $42.50 |
| 09/17/2020 | AJ | 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 | Responded to PI’s 9/16/20 email and refused to withdraw 57.105 motion; provided copy of motion to set CMC and available dates for hearing | $425.00 | 0.1 | $42.50 | |
| 09/18/2020 | DW | Reviewed PI’s email insisting that 57.105 motion be withdrawn | $425.00 | 0.1 | $42.50 | |
| 09/18/2020 | DW | Replied to PI’s counsel that the 57.105 motion for sanctions will not be withdrawn and asking for response, re: CMC | $425.00 | 0.1 | $42.50 | |
| 09/18/2020 | DW | Sent client copy of email exchange w/ PI’s counsel; called and spoke w/ Client | $425.00 | 0.5 | $212.50 | |
| 09/22/2020 | DW | Various | Drafted and filed Notice of Hearing on 10/15/20; set up Court Call; spoke w/ client, re: hearing date | $425.00 | 0.7 | $297.50 |
| 10/02/2020 | DW | Review | Reviewed PI’s Memo of Law opposing Aronberg’s 57.105 motion for fees/sanctions | $425.00 | 0.7 | $297.50 |
| 10/02/2020 | DW | Review | Reviewed PI’s Response to Aronberg’s request to schedule 57.105 motion for fees after MSJ | $425.00 | 0.5 | $212.50 |
| 10/02/2020 | DW | Review | Reviewed PI’s Memo of Law opposing 57.105 motion | $475.00 | 0.5 | $237.50 |
| 10/02/2020 | AJ | Review | Reviewed PI’s Response to Aronberg’s request to schedule 57.105 motion after MSJ | $475.00 | 0.4 | $190.00 |
| 10/12/2020 | DW | Research | Research caselaw & statutes, re: response to PI’s Memo of Law | $425.00 | 1.0 | $425.00 |
| 10/13/2020 | DW | Research & Analyze | Continued researching caselaw, re: response to PI’s memo of law | $425.00 | 1.0 | $425.00 |
| 10/13/2020 | DW | Draft | 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/ AJ caselaw and draft response to memo | $425.00 | 0.5 | $212.50 |
| 10/13/2020 | AJ | 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 PI’s Memo of Law | $425.00 | 1.0 | $425.00 |
| 10/14/2020 | DW | Telephone | Spoke w/ client, re: memo of law | $425.00 | 0.2 | $85.00 |
| 10/14/2020 | DW | Telephone | Spoke w/ client again, re: response to memo of law | $425.00 | 0.1 | $42.50 |
| 10/15/2020 | DW | Attend Hearing | Attended hearing, re: Motion to Set CMC; called client to discuss | $425.00 | 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 |
| 10/152020 | OW | Telephone . | Spoke wl Pt’s counsel, re: settlement | $425.00 | 0.1 | $42.50 |
|---|---|---|---|---|---|---|
| 10/152020 | OW | Telephone | Spoke w/dient, re: Prs settlement proposal | $425.00 | 0.2 | $85.00 |
| 10/15/2020 | AU | Various | Attended hearing, re: motion to set CMC; | |||
| $475.00 | 1.0 | tA75.00 | ||||
| 10/15/2020 | AU | Various | Discussed Pt’s settlement proposal w/ DAW and | |||
| then ve/ Cienl | $475.00 | 0.4 | $19000 | |||
| 10/15/2020 | DW | Meeting | Discussed Prs settlement proposal w/ AIJ | $425.00 | 0.2 | 585.00 |
| 10/16/2020 | OW | Various | Drafted and shared Proposed order wl Pea counsel | 3425.00 | 0.5 | $212.50 |
| .10/1602020 | OW | Telephone | Spoke w/ Pt’s counsel, re: settlement | $425.00 | 0.2 | 585.00 |
| 10/16/2020 | DW | Telephone | Spoke w/dient, re: Rs settlement proposal | $425.00 | 0.5 | $212.50 |
| 10/16/2020 | DW | Meeting | Discussed Prs settlement proposal w/ AU | $425.00 | 0.2 | $85.00 |
| 10/16/2020 | AU | Meeting . | Discussed Pt’s settlement proposal ve/ DAW | $475.00 | 02 | $95.00 |
| OW | Various | Uploaded proposed order, re: CMC for Judge | ||||
| Harder | 0.1 | $42.50 | ||||
| 10/19/2020 | DW | Telephone | Spoke client, re: Ins settlement proposal | ”… $42$.00 | 0.2 | $85.00 |
| 10/19/2020 | DW | Telephone | Spoke w/ Rs counsel, re: settlement | / -_..7z.,, - $425.00 | 0.1 | • $42.50 |
| 10/19/2020 | AU | Meeting | Discussed Prs settlement pr | w/ DA y 5475.00 | 0.2 | $95.00 |
| 10/19/2020 | OW | Meeting | Discussed Pt’s settlement propose/OW AD, | ,, \ V $425.00 | 0.2 | $85.00 |
| 10/20/2020 | DW | Various | Reviewed email from PI, re settlehiontlient/copy | |||
| to Client and called to discuSs | ’k.. $425.00 | 0.5 | $212.50 | |||
| 10/20/2020 | OW | Telephone | Spoke w/dient re: settlement | $425.00 | 0.4 | $170.00 |
| 10/20/2020 | OW | Telephone | Spoke w/ Pt’s cmiretipl, re: Seelleenent | $425.00 | 0.1 | $42.50 |
| 10/20/2020 | DW | Telephone | Spoke w/ die*, re: salriment | $425.00 | 0.1 | $42.50 |
| 10/20/2020 | OW | Meeting | ||||
| Discussed Preeettlement proposal w/ AIJ | $425.00 | 0.2 | $85.00 | |||
| 10202020 | AU | Meeting | Distriiesses Prs settlement proposal w/ DAW | $475.00 | 0.2 | $95.00 |
| 1021/2020 | OW | Various | $425.00 | |||
| 1.0 | $425.00 | |||||
| loniano | OW | Review | y -,✓ Reviewed Order, re: CMC unnecessary | $425.00 | 0.1 | $42.50 |
| 1021/2020 | DW | $ephone | ''' Spoke wl client, re: media response | $425.00 | 0.2 | $85.00 |
| 10/21/2020 | OW_ . Telephone | Spoke w/ client, re: media response | $425.00 | 0.1 | $42.50 | |
| 10/21/2920 | OW | Telephone | Spoke w/ client. re: media response | $425.00 | 0.1 | $42.50 |
| 10/21/2020 | OW | Telephone | Spoke w/ client, re: media response | $425.00 | 0.1 | 542.50 |
| 1021/2020- | OW | Telephone | Spoke w/ client, re: media response | $425.00 | 0.1 | $42.50 |
| 10;21/2020 | OW | E•mai | Sent emai w/ Aronbem statement to media | $425.00 | 0.1 | $42.50 |
| 1021/2020 | AL) | Meeting | Discussed media response iv/ DAW | $475.00 | 0.3 | $142.50 |
| 10/21/2020 | OW | Meeting | Discusses) media response w/ AU | $425.00 | 0.3 | - $127.50 |
| 10/22/2020 | OW | Various | ||||
| $425.00 | 0.5 |
| 10/22/2020 | █ | 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 |