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Home / Epstein Files / Court Records / CA Florida Holdings, LLC, Publisher of the Palm Beach Post v. Aronberg, No. 50-2019-CA-014681-XXXX-MB (Fla. 15th Cir. Ct. 2019)
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CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 and Plaintiff 2s October Notice of Dropping State Attorney Dave Aronberg from the above-captioned lawsuit See Exhibits and attached hereto The total time Affiant 2s law firm has expended services rendered to date is hours however from the date.of Defendant Aronberg 2s demand Affiant 2s law firm has expended a total of hours Of the hours expended since Defendant Aronberg 2s demand was served the Affiant Of the hours expended since Defendant Aronberg 2s demand was served the total time Affiant has expended services rendered to date is hours at the rate of per hour Likewise the total time Affiant 2s law partner Arthur I Jacobs has expended services rendered to date is hours at the rate of per hour Accordingly since Defendant Aronberg 2s demand was served Defendant Aronberg 2s counsel JACOBS SCHOLZ WYLER LLC has rendered services in the amount of in conjunction with the defense of the instant action pursuant to Florida Statutes See Exhibit attached hereto Affiant expects to incur an additional hours at an hour in preparing for and attending the hearing on attorneys fees Thus the total amount of hourly attorneys fees the State Attorney is seeking is hours for a total of Additionally the State Attorney seeks a multiplier of which when applied makes the grand total attorneys fees sought herein Dated this 9th day of November FURTHER AFFIANT arid Plai"ntiffs tober Notice of Dr pping State A or ey Dave Aronb tg frnrri the above a tloned lawsuit See Exhibif A and attached hereto A 267The totalfone Affiantslaw firm ha expended services ren 260dered _to date is ho!lrs however from the date of Defen4ant i-onbergs demand Affiants law firm"hci:s expended totai hours Of the urs expended since Defendant Aronbergs dern nd served the Affiaht Of the hoursexp nded since Defendant Aronbergs demand was serv the total time Affiant has expended se_rvices rendered to date is hours at the rate of per hour Like,vise the total time Affiants iaw partner Arthur I Jacobs has expended servi es rendered to date is hours at the rate of per.hour A cordingly since Defendant Aron bergs I dematici was served Defendant Aronbergs counsel JACOBS SCHOLZ WYLER LLC has rende ed services in the amount of in conjunction with the defense of the instant action pursuant to Florida Statutes See Exhibit attached hereto Affiant expects to incur an additional hours at an hour in preparing for and attending the hearing on attorneys fees Thus the total amount of hourly attorneys fees the State Attorney is seeking is hours for a total of Additionally the State Attorney seeks a rri ltiplier of which when applied makes the grand total attorneys fees sought herein Dated this 9th day of November FURTHER AFFIANT_SA STATE OF FLORIDA COUNTY OF NASSAU The foregoing instrument was acknowledged before me this 9th day of November by Douglas A Wyler Esquire who is personally known to me and who did take an oath Sign tuj Notary Public State of Florida i Taran jackson Notary Public State of Florid Commission GG My Comm..Expires Aug Bonded through National Notary Assn Name typed printed or stamped CERTIFICATE OF SERVICE HEREBY CERTIFY that on this 9th day of November a copy of the foregoing has been electronically filed with the Florida E-File Portal for e-service on all parties of record herein JACOBS SCHOLZ WYLER LLC s/Douglas A Wyler Arthur I Jacobs Esq Fla Bar No Richard Scholz Esq Fla Bar No Douglas A Wyler Esq Fla Bar No Gateway Blvd Suite Fernandina Beach Florida Fax Pri mary jacobsscho lzlaw comcast.net Attorneys for Defendant Dave Aronberg CA/AroFte 256pP03jNl BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM STATE QF FLORIDA COUNTY Of NASSAU i I The foregoinginstru ent was ackn wledged before this 9th ofNo ember by Dou A Wyler Esquire who ts personally known to me and wh9 did take oath Name typed printed or stamped i TARAN JACKSON No ary Publi.c Staie of Fl ndi Wj Commis5ion II GG My Conini u:pire5 Aug Bonded through Natio al Notary IJ CERTIFICATE OF SERVICE I HEREBYCERTIFY that on this 9th day of November a copy of the foregoi has been electronically filed with the Florida File Portal fore-service on all patties of record herein JACOBS SCHOLZ WYLER LLC Isl Doug/asA Wyler Arthur I Jacobs Esq Fla Bar No I Richard Scholz Esq Fla Bar No Douglas A Wyler Esq Fla Bar No Gat viay Blvd Suite Fernandina Beach Florida Fax Primary jacobsscholzlaw comcast.net Attorneys for Defendant Dave Aronberg CA/ArofltrnEg OP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHlBlT EXHJBIT CA/AroFteEJ BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM __ EXHIBIT A I I I I I I I CA/AroFl OP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Friday September at Eastern Daylight Time Subject SERVICE OF COURT DOCUMENT CASE CA FLORIDA HOLDINGS LLC DAVEARONBERG Fi-ida September at Ea Daylight me Subject srnvicE oi couRT DOCUMENT CASE No cf FLQRIDA HOLDINGS iLc DAVE ARON BERG THE LAW OFFICES OF JACOBS ASSOCIATES P.A ARTHUR I JACOBS Jacobs Scholz Wyler ijlc A LIMITED LIABILITY COMPANY Op PROFESSIONAL ASSOCIATIONS ATTORNEYS AT LAW GATEWAY TO AMELIA GATEWAY BLVD SUITE Fernandina Beach Florida TELEPHONE FAX NO RICHARD SCHOLZ P.A RICH ARD SCHOLZ DOUGLAS A.-WYLER P.A DOUGLAS A WYLER June VTA ELECTRONIC U.S MAIL Stephen A Mendelsohn Esq Greenburg Traurig P.A Town Center Circle Suite Boca Raton FL RE CA Florida Holdings LLC Daye Aronberg et al Palm Beach County Case No 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 matter The purpose of this letter is to demand the voluntary dismissal of your First Amended Complaint the 223Complaint dated January This demand is made pursuant to section Florida Statutes As you know Section provides I Upon the court 2s initiative or motion of any party the court shall award a reasonable attorney 2s fee including prejudgment interest to be paid to the prevailing party in equal amounts by the losing party arid the losing party 2s 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 2s 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 Would not be supported by the application of then-existing law to those material facts Today Judge Marx granted with prejudice Defendant Aronberg 2s Motion to Dismiss Count II of the Plaintiffs Complaint Pursuant to the Court 2s ruling the Plaintiffs only remaining cause of action consists of Count I for Declaratory Relief Accordingly we believe that the Complaint filed herein arid 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 CA/AroBtiapOO03M BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ft JAcons ScHoriz WhER uc A_ LIMITED BILITY COMPANY OF PROF IONAL ASS9CIATIONS 267ATTORNEYS AT"I..AW 267GATDIAY i-o AMELIA LAW pfF"ICES OF"_ JACOBS_ ASSOCIATES P.A ARTHUR I JACOBS Vo 267sulTE FERNA.IDINA BEACH Fl.oRIDA VIA ELECTRONIC U.S MAIL StephenA Mendelsohn Esq Greenb1_.1rgTrating Center Circle Suite Boca Raton FL TELEPHONE FAX NO RE CA Florida Holdings Ll..C Dave Aron berg et.al Palm Beach County Case No Dear Mr Mendelsohn RICHA_R:o SCHOLZ P.A R1c4 CHOLZ DO GLAs P.A DOUGLAS A WYLER As you are aware our tinn rep esents the interests of Dave Aronberg as State Attorney of Palm Beach County Florida in the above referenced matter The purpose ofthis letter is to demand the voluntary dismissal of your First Amended Complaint the Complaint dated January This demand is made pursuant to section Florida Statutes As you know Section provider I Upon the courts initiative or motion of any party the court shall award a reasonable attorneys fee inclu9ing prejudgment interest to be paid to the prevailing party in equal amounts by the losing party aiid_the losing partys 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 partys attorney kn 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 riecessary to establish the claim or defense or 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 Plaintiffs Complaint Pursuant to the Courts ruling the Plaintiffs only remaining cause of action co11s,ists of Counil for Declaratory Relief Accordingly we believe thatthe Complaint filed herein and its sole remaining Count for Declaratory Relief is not supported by the material facts necess ry to establish the claims asserted and that your claims are not supported by the applicadon of current law Said-.iT Bte i-faCts __ __ CA/Arofl BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM 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 forthe Fifteenth Judicial Circuit is in custody or control of the 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 hot 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 Edition 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 Florida Statutes which states When such disclosure is ordered.by a court pursuant to subsection 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 Epstein grand jury records Based on the foregoing if the Complaint is not dismissed within days of the service of this letter the enclosed Motion for Attorney 2s 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 2s Motion for Attorneys Fees CA/AroFfi BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i First and foremo:t tile Compiaint is not supported by the mat ial facts necessary to establish the claims asserteq because neither Defendant Aron berg nor The Office of the State Attom for the Fifteenth iudicial_-Circuit is in custody or control of the grand jury Tlat_erials sought therein Simply put the dedaratory relief sought by the Plaintiff seeks records I from my ciient that are impossible for him or his office to produce Accordingly Defendant Aronbe:rg is not a proper party to this action because no mattet what he and his office do not have possession custody or 267controi of the requested materials __ a li i to foreg ing material facts tha_t negate the claims asserted_in_the Compl int,your laims are also not supported by the application of current iaw Specifically your action for declaratory relief fails based on the clear unambiguous statutory language found in Section Florida Statutes which states When such disclosure is"ordered by a court pu suant _subsection I for use in a civi I case it may be disclosed to all parties to the case and to their attorneys and by the latter to their legal associates and empl9yees HO Vever the grand jury leslimony afforded such persons by the court can onlybe used in the defense or prosecution othe 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 Epstein grand jury records Based on the foregoing ifthe Complaint is not dismissed within days of the service of this letter the enclosed Motion for Attorneys 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 Plea7;:-r.acc Douglas A Wyler Esq For the Firm _Encl Defendants Motion for Attorneys Fees I I I CA/Arof1f:Is:IEgJ 9P BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM IN THE CIRCUIT COURT OF THE FIFTEEN THJUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CA FLORIDA HOLDINGS LLC Publisher of the PALM BEACH POST Plaintiff CASE NO DAVE ARONBERG as State Attorney of Palm Beach County Florida SHARON BOCK as Clerk and Comptroller of Palm Beach County Florida Defendants DEFENDANT DAVE ARONBERG 2S MOTION FOR ATTORNEYS FEES Defendant DAVE ARONBERG as State Attorney of Palm Beach County Florida by and through the.undersigned attorneys moves the Court pursuant to Florida Statutes Section to award him reasonable attorneys fees for the defense of Plaintiffs First Amended Complaint the 223Complaint and as grounds therefor would show that on June Plaintiff was served a copy of this Motion together with a letter from the undersigned attorney in accordance with subsection of the above Statute demanding dismissal of the Complaint at least days prior to the filing of this Motion In said letter Defendant 2s attorney advised Plaintiff of the facts which establish that the Complaint is without support of the facts or the law WHEREFORE Defendant DAVE ARONBERG as State Attorney of Palm Beach County Florida respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff attorneys to pay said Defendant 2s attorneys fees incurred herein after service of this Motion i i I I CA/AropteH pp93 BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM __ IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT iN AND FOR PAIJ BEACH COUNTY FLORIDA CA FLORIDA HOLDINGS,LLC Publisher of the PALM BEA CH POST Plaintiff DA VE AAONBERG as State Attorney of Pal Beach Comity Florida SHARON BOCK as Clerk and Co ptroller of Palm Beach County Florida Defe dants CASENO.:l9 DEFENDANT DAVE ARONBERGS MOTION FOR ATTORNEYS FEES Defendan DAVE ARONBERG as State Attorney of Palm Beach County Florida by and through the.undersigned attorneys moves the Court pursuant to Florida Statutes Section to award him reason ble attorneys fees for the fense of Plaintiffs First Amended Complaint the Complaint and as grounds therefor would show that on June Plaintiff was served a copy of this Motion together with a letter fro!l the undersigned attorney in accordance with subsection of the above Statute demanding dismissal of the Complaint at least days prim to the filing of this Motion In said letter Defendants attorney advised Plaintiff of the facts which establish that the Complaint is without support of the facts cir the law WHEREFORE Defendant DA VE ARONBERG as State Attorney of Palm Beach County Florida respectfully requests the Court 267enter an Order requiring Plaintiff and Plaintiffs attorneys fo pay said Defendants attorneys fees incurred herein after service of this Motion i CA/AroFlf:rnEl!D9P BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM i I I CERTIFICATE OF SERVICE I hereby certify that on this day the foregoing was electronically filed via the Florida E-File Portal for electronic service on the parties of record herein JACOBS SCHOLZ WYLER LLC Douglas A Wyler Arthurl Jacobs Esquire Fla Bar No Richard Scholz Esquire Fla Bar No Douglas A Wyler Esquire Fla Bar No Gateway Blvd Suite Fernandina Beach Florida jacobsscholzlaw comcast.net Attorneys for Defendant CA/AropiiagDOPQOa BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM CERTIFiCATE OF SERVICE I hereby cert:ify that on this __ day the fo;egoini was elect onically filed via the Florida E-File Portal for electronic service on the parties ofrecordherein JAco scaoLz WYLER ic Isl Dbuglas A Wyler Arthur Jacobs Esquire Fla Bar No Richard Sch.ok Esqufr Fla Bar No Douglas A Wyler Esqui Fla Bai No Gateway ci Suite Fernandina Beach Florida jacobsscholzlaw comcast.net Attorneys for Defendant CA/Aroflm 245.QDPP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT EXHIBIT I CA/AroptKE 256OPQaM BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT EXHIBIT __ I I I CA/AroflruHDOP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Filing PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CA FLORIDA HOLDINGS LLC CASENO Publisher of THE PALMBEACH POST DIVISION AG Plaintiff DAVE ARONBERG as State Attorney of Palm Beach County Florida SHARON BOCK as Clerk and Comptroller of Palm Beach County Florida Defendants PLAINTIFF CA HOLDINGS LLC 2S NOTICE OF DROPPING STATE ATTORNEY DAVE ARONBERG Plaintiff CA HOLDINGS LLC pursuant to Fla Civ 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 East Las Olas Boulevard Suite Boca Raton Florida Telephone Facsimile By s/Stephen A Mendelsohn STEPHEN A MENDELSOHN Florida Bar No mendelsohns utlaw 2com smiihl utlaw.eom FLService etlaw.com CA/AroFt 256EgDOPQa?B BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Filing If E-Fii.ed PM __ I I I IN THE CIRCUJT QlJK OF THE FIFTEENTI-1 JUIJICIAL CJRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CAFLORIDA HOLDiNGS LLC CASE NO X-MB DIVISION AG Publisher of THE PALM Bf.A CH POST 267.Plaintiff DAVE ARONBERG as Stat Attorney of Palm Beach County Florida SHARON BOCK Clerk and Comptroller of Palm Beach County Florida Defendants PLAINTIFF CA HOLDINGS LLCS NOTICE DROPPING STATE ATTORNEY DA VE ARONBERG Plaintiff CA HOLDINGS LLC pursuant to Fla Civ hereby notifies the parfies that it has dropped State Attorney Dave Aron berg from the above case Respectfully submitted GREENBERG TRAURIG P.A Attorneys for CA Florida Hoidings LLC Publisher of The Palm Beach Po Stephen A Mendelsohn Esq East Las Olas Boulevard Suite Boca Raton Florida Telephone Facsimile By Stephen A Mendelsohn STEPHEN A MENDELSOHN Florida Bar No mendelsohns gtlaw:com srriithl!tl,gtlaw conl FLService gtlaw:com CA/AroFlruEDOi BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM By Id Michael Grygiel MICHAEL GRYGIEL Admitted Pro Hac Vice State St 6th Floor Albany New York Telephone Facsimile grv2ielm gtlaw;c6fn By Id Nina Bovaiian NINA BOYAJIAN Admitted Pro Hac Vice Century Park East Suite Los Angeles California Telephone Facsimile boyaj iann gtla w.cbm riveraal 2tiaw.cbm CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this day of October 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 Stephen A Mendelsohn_ STEPHEN A MENDELSOHN ACTIVE CA/Aromafjjoa beach county fl Joseph abruzzo clerk pm i I I By Michael Grygiel MICHAEL GRYGIEL Ad jriedPro Ha Vice 267state St 6th locir Aibany,New York Tetej,hone sis 4ob Facsimile gi-vgie1!11ta2gt1aw;corn By Isl Nina Boya/idn NINA BOY AJiAN AdrrtittedProH Vic i Century Park East Suite Los Angeles California Telephone Facsimile bovajiann ro.gtlaw.coin riveraal gtia com CERTIFICATE OF SERVICE I HEREBY ERTIFY that on this day of October a true and correct copy of the regciing has been filed ith the Clerk of the Couit using the State ofFlorida e-tiling sy tem which will send a notice of electrcmic service for all parties of record herein Isl Stephen A Mendelsohn STEPHEN A MENDELSOHN ACTIVE CA/ArOflaE!D PP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT EXHIBIT CA/AroFteJ pP0 BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM EXHIBIT I I CA/Arofl.ruEIDPP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM Jacobs Scholz Wyler LLC Gateway Blvd Suite Fernandina Beach FL United States Jacobs Scholz Wyler LLC Dave Aronberg Balance Invoice Invoice Date November Payment Terms Due Date Aronberg SAO15 adv CA Florida Holdings LLC Time Entries Date EE Activity Description Rate Hours Une Total DW Review Initial review of summons and complaint DW Review Reviewed motion for pro hac vice and Judge Hafele order granting DW Teleconference Teleconference Client re response to lawsuit DW Draft Drafted engagement letter and sent to client DW Review Reviewed 15th circuit local rules AU Review Initial review of complaint AU Meeting Meeting DAW to discuss lawsuit and strategy DW Meeting Meeting AU to discuss lawsuit and strategy AU Teleconference Teleconference Client re response to lawsuit DW Research Preparation Research and prep for Motion to dismiss DW Draft st Draft motion to dismiss DW Teleconference Teleconference Client re draft motion to dismiss AU Review Reviewed 1st Draft MTDismiss AU Teleconference Teleconference client re draft motion to dismiss AU Meeting Meeting DAW re motion to dismiss dw Meeting_ Meeting AU fe MTDismiss DW Draft Completed final draft of motion to dismiss filed with Court DW Teleconference Spoke client re final draft of motion to dismiss CA/ArontwjopMaa beach county fl Joseph abruzzo clerk pm __ Jac bs ho 8t Wyler,LLC i Gateway s1v 267,suite Jc1cobs h?lz yler LLC Fernandina Beach FL United States _f Dav Aronberg lance Invoice lnvoi eDate Pay en Terms Due.Date ronberg adv CA Florida Holdings LLC Time Entries Date--_ EE Activity Description Rate OW Review Initial review of summons:and complaint DW Review Reviewed motion forpro hac vice and Judge Hafele order granting DW Teleconference Teieconference wt6ient re response to lawsuit DW Draft Drafted engagement letter and sent to client Reviewed 15ih circuit locai rule DW Rel!iew AIJ Review lnitiaireview of complaint AIJ MeeUng Meeting DAW to discuss lawsuit and strategy DW MeeUng Meeting AIJ to discuss laws it_and strategy AIJ Teleconference T_eleconference Client re response to lawsuit DW Research Research and prep for Motion to dis_miss Preparation DW Draft 1st Draft motion to dismiss DW Teleconference Te_leconference Client re d_raft motion to dismiss Al,,I Review Reviewed 1slDraft MTDismiss AIJ Teleconference Teieconference wt client re draft motion to dismiss AIJ lvleeting Meeting DA0J_ re motion to-dismiss Novembers Hours Urie Total ow __ Meetjng_ __ ting A M:rP!!;l l_ __ bW Draft Completed finai draft of motion to dismiss filed with Court DW Teleconference Spoke client fir1:a1 dr ft-cif motion to dismiss i I CA/AroflaE PP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I DW Teleconference Spoke with Clerks attorney re response AU Review Reviewed final draft MTDismiss AU Review Reviewed Clerks MTDismiss DW Review Reviewed Clerks Motion to Dismiss DW Review Reviewed Order Setting Hearing on Defendants MTDismiss DW Review Reviewed motion for pro hac vice DW Review Reviewed Pls Amended Complaint DW Teleconference Spoke with client re:.Amended Complaint DW Review Reviewed Pls notice of filing AIJ Review Reviewed Pis Am Compl DW Review Reviewed Judge Marxs Order Cancelling MTDismiss Hearing DW Review Reviewed Pls Objection to Defendants MTDismiss DW Teleconference Spoke with client re Amended complaint AIJ Meeting Meeting DAW re response to Am Compl DW Meeting Meeting AU re response to Am Compl DW Review Reviewed Order granting pro hac vice admission DW Research Draft Researched and drafted response to Amended Complaint DW Teleconference Spoke with Clerks attorney re response to amended complaint DW Various Completed Answer/MTDismiss Amended Complaint filed with Court sent copy to Client i:o DW Draft Drafted and filed Notice of Unavailability AIJ Review Reviewed final Answer/MTDismiss DW Review Reviewed Clerks Answer/MTDismiss DW Review Reviewed Order setting hearing on Defs MTDismiss DW Teleconference Spoke client re order setting MTDismiss hearing for March DW Review Reviewed Pls Opposition to Aronberg MTDismiss Clerks MTDismiss AU Review Reviewed Pls Opposition to Aronberg MTDismiss Clerks MTDismiss DW Teleconference Reviewed email from Pls counsel re motion to continue hearing DW Review Reviewed Pls unopposed motion for continuance DW E-mail Emails Clerks counsel re Pls request to continue hearing DW E-mail Reviewed email from PI re agreed order responded DW Review Reviewed Courts agreed order continuing hearing I CA/ArcfWf BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I _I I ow Teleconference po_ke with,Clerk attor ey re response __ Reviewed final draft MTDismiss AIJ Review _9 AIJ Review Reyiewed Qlerks MTDisrniss OW_ Review Revie._.;;ed Clerks Motion to Dis iss I Re ie ed Order Setting Hearing on Defe da ts ow Review MT Dismiss ow Review Reviewed motion for pro hac vice ReVie R_ev/ewed flls Amended Complaint o,w leconfe e11ce 9Po_ t!ieni re:.Amended C::Omplaint ow ow Review Reviewlld Pl 247notice of filing Reviewed PrsAm.6onipl AIJ Review Revie eo Jud.ge Marxs Order Cancelling bw Review MTDismiss Hearing ow Review Reviewed Pls Objection to Defendants MTpismiss ow Teleconference Spoke with client re Amended complaint AIJ Meeiing Meeting _I DAW re response to Am Corripl ow Meeting Meeting AIJ re response to Am Comp ow _Review Reviewed Order granting pro hac vice admission ow Research Draft Researched and drafted response to Amended Complaini ow Teleconference pqke with Clerks attorney re response to amended complaint ow Various Completed-Answer/MTDismiss Amended Complaint Iii with Court sen_t copy to Client ow 267Draft Drafted and filed Notice of Unavailability AIJ Review Reviewed final Answer/MTDismiss ow Review Reviewed Clerks Answer/MTDismiss ow Review Reviewed Order setting hearing on Deis MTDismiss ow Tele_conference Spoke wt client re order setting MTDismiss hearing for March ow Review Reviewe Pls Opposjtion to Aronberg MTDismiss Clerks MTDismiss AIJ 267Review Reviewed Pls Opposition to Aronberg MTDismiss Clerk MTDismiss ow Teleconference Reviewed 267mail from Pls counsel re motion to continue hearing ow Review Reviewed Prs unopposed motion for continuance Emails _Yf Clerks counsel re Pls request lei ow 267e-mail coniinue fiearing DW mail Reviewed email from Pl re agr ed _ord responded ow 267Review Reviewed Courts agreed order corilinuing hearing CA/Ar0fl.a PJ BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM DW Review Reviewed order rescheduling hearing on Dets MTDismiss I pw Teleconference Spoke w/client re order rescheduling MTDisrhiss hearing for June AU Review Reviewed Order rescheduling MTDismiss hearing pw Review Reviewed order setting Zoorn hearing re MTDismiss DW Teleconference Spoke client re hearing will be via Zoom pw Review Reviewed Clerks filing change of atty of record oi DW Teleconference Spoke with Clerks new counsel Nicole Fingerhut DW E-mail Reviewed Pls email re cases and authorities for MTDismiss hearing responded Preparation Began oral argument prep for MTDismiss hearing dw E-mail Reviewed email from Judge Marx 2s JA and responded DW Various Reviewed Pls page binder re MTDismiss prepped for hearing pw E-mail Drafted and sent email to client re MTD hearing tomorrow DW Attend Hearing Prepped for and attended MTDismiss hearing via Zoom DW Teleconference Spoke Client re debrief MTDismiss hearing pw E-mail Emailed courtesy copies of Aronberg 2s Answer and MTDisffiiss to Judge Marx DW E-mail Reviewed response from Client and replied AU Attend Hearing Attended MTDismiss hearing via Zoom AU Review Reviewed order granting MTDismiss prejudice DW Review Reviewed Courts Order Granting Defendants MTDismiss Count II Prejudice DW Various Shared order Client and spoke re result and plan going forward re DW Various Researched Fla Stat drafted demand letter and proposed motion for attorneys fees/sanctions Served Pl 2s counsel with demand letter and proposed motion AU Meeting Meeting DAW re Order DW Meeting Meeting w/AU re Order AU Review Reviewed demand and proposed motion for sanction DW Various Reviewed notice of change of attorney re Clerk called and spoke new couhsel Cyrithia Guerra pw Various Reviewed Pls letter refusing to voluntarily dismiss amended corhplaint despite demand called and spoke client re Pl 2s refusal next steps CA/AroFtJWOP03a4l BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ow Te ec::onference ow Review Tel_ecoi1ference Review bW Teleconference ow E-mail ow Preparation ow E-mail ow Various ow E-maii ow Attend Hearing ow Teleconference ow E-mail ow E-mail AIJ Attend Hearing AIJ Review ow Review ow Various ow Various AIJ Meeting ow Meetjng AIJ Review ow Various l!eviewed order reschedtJHng hearing ori Defs MTDisnii Spoke client re order rescheduiin MTDismiss tiearing for Jurie RevieYfed Order ci1eduling MTDismiss hea_ring Revi ed order setting Zoort1 he 267ari re MTDismiss Spoke wiclierit re hearing will be via Zoom Re;ie ed Clerks filing cha ge cif atty of rei::o;d Reviewed Pls email re case_s and authorities for MTDis_miss hearing responded Began oral argument prep for sis MTDismiss heariri1 Revi ed email from Judge Marxs JA and re ponded viewed Pls page binder re MTDismik prepped for hearing D_rafted af1 sent email to client re MTD hearing tomorrow Prepped for and attended MTDismiss hearing via Zoom Spoke Client re debrief MTDismiss hearing 267Emai!ed c:ourtesy copies of Aro.nbergs.Arisw and MTDisfiliss ici Judge Marx eviewed response from Client and replied _Attenj:ied MTDisiniss hearing via Zoom 267Reviewed der graritirig MTDisr:niss wt prejudice Reviewed Co_urt;s Order Granting Defendants MTDismiss Count II Prejudice Shared order Client and spoke re result and plan going forward re Researched Fla Stat drafted demand letter and proposed motion for attorneys fees/sanctions Served Pls counsel with demand letter and proposed motion Meeting DAW re Order Meeting AIJ re Order 267Revie ed demand and proposed 267otion for iianciion I as.cio ci.2 Reviewed notice of change ci atforney re Cler cailed ahd spoke w/riew couriseLCyithia Gueria __ Re iewed Pls letter refusi to volunirily dis iss OW Various amended complaint despiie 5:c:teniand called and spoke client ie Pls 225refusal riexi ieps CA/Arofl.ru:fIDOP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM I i i DW E-mail Sent client copy of Pl 2s letter refusing to dismiss complaint i AU Review Reviewed Pl 2s letter refusing to dismiss Count l/Am Compl DW Various Spoke w/client re filing Of motion for fees/sanctions filed motion for attorneys fees based on Pls failure to voluntarily dismiss amended complaint count i DW E-mail Email to client re affidavit and summary Judgment DW Teleconference Discussed Client drafting and filing Motion for Summary Judgment and MSJ evidence AU Teleconference Discussed Client drafting and filing Motion for Summary Judgment and MSJ evidence DW Draft Created 1st draft of Aronberg Affidavit shared client AU Various Reviewed draft affidavit and discussed DAW DW Meeting Discussed draft affidavit AU DW Review Reviewed Pis Request to Produce re Clerk DW Teleconference Spoke Clerk 2s counsel re Request to Produce DW Review Reviewed Pls Amended Request to Produce re Clerk DW Teleconference Spoke Clerks counsel re Amerided Request to Produce o.i DW Draft Revised Aronberg affidavit DW Draft Finalized Aronberg Affidavit and sent to client DW Research Preparation Research and prep for Motion for Summary Judgment DW Various Received executed Aronberg Affidavit DW Draft Began drafting Motion for Summary Judgment DW Draft Continued drafting Motion for Summary Judgment DW Review Reviewed email from Plaintiff attempting to set hearing bn motion for fees/sanctions DW E-mail Sent responsive email to Pis counsel DW Meeting Discussed draft MSJ w/AU AU Various Reviewed draft MSJ and met DAW to discuss DW Draft Finalized Motion for Summary Judgment filed court along with Aronberg affidavit DW Teleconference Spoke Clerks counsel re request to produce DW Various Reviewed Pls email and accepted conference call invite for DW Review Reviewed Clerks response to request for DW Teleconference Spoke Pls counsel re dispute as to whether MSJ should be heard before fee motion or vis versa call was unsuccessful BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM AIJ Review ow Various E-mail OW Tel ference AIJ Teleconfef nce ow Draft AIJ Various OW Meeti OW Review OW Teleconference OW Review ow ow ow ow ow ow ow ow ow AIJ ow ow ow ow Teleconference Draft Draft Research_ Preparation Various Draft Draft Review E-mail Meeting Various Draft Teleconference Various Review OW Teleconle ence Sentcjient copy of Pls lettenefusiilg to dlsmi Pr i0 Re iewed pj letter iefusing to dismiss Count I Am inpl Spoke clien re fili gdf 57.105hiotion for feesisanctloils filed rT19iio for attorneys fees bai;ed oii Pi;s failure to voluntarily dismiss a ended compiaint Emrul io iie re affldavit and summary judgment Discussed i-Clie aftingand filing Motion for summary Jucigmeni arid MSJ eviciencil Discussed Voit Client alting and _filing Motion for Summary Judgment and MSJ evidence Created i st dri ft of Aronberg Affida it shared client ReVJewed cira"ft affidavit a discussed DAW Discussed drati affidavit AIJ RevieweC ls Requ_esi to Produce re Clerk Spoke _wtGierks counsel re Request to Produce Revjewed Pls Amended Request to Produce re Clerk_ Spoke Clerks counsel re Amended Request to Produce Revised Aroiib rg affidavit Finalized Aronberg AffidaVlt and_ s_ent to client Research and prep for Motion for Summary Judg1 nt Received executed Aronberg Affidavit Began drafting Motion for Summary Judgment_ Continued drafting Motion for Summary Judgment Reviewed email from Plaintiff attempting to set hearing i inptioi for fees/sanctions Sent responsive em to Pls counsel Discussed draft.MSJ wi AIJ Reviewed draft MSJ and met DAW to discuss Finalized Motion for Summary Judgm_ent filed court along with Aronberg affidavit Spoke I Clerks counsel re request to produce Re iewed Pls email and accepied conference cali invite for ct I I __ Reviewed Clerks response to request for production Spoke Pls counsel re dispute as io whether MSJ shou.ld be heard before fee motion or vis sa call was unsuccessful o:t o.i sswoci 0_ CA/ArCfltlsIEIDOP.Pi BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM AU Meeting Discussedw DAW.phone call w/.PIs counsel pw Meeting Discussed AU phone call Pl 2s counsel DW E-mail Reviewed email from Pls counsel requested Arqnberg to withdraw sanctions.motion w/o prejudice DW Meeting Discussed Ai filing motion for CMC AU Meeting Discussed DAW filing motion for CMC DW Various Drafted and filed motion toset case management conference re MSJ 1st or Fee hearing 1st DW E-mail Responded to Pi 2s email and refused to withdraw motion provided copy of motion to set CMC and available dates for hearing DW E-mail Reviewed Pls email insisting that motion be withdrawn DW E-mail Replied to Pls counsel that the motion for sanctions will not be withdrawn and asking for response re CMC DW E-mail Sent client copy of email exchange w/.PIs counsel called and spoke Client DW Various Drafted and filed Notice of Hearing on set up Court Call spoke client re hearing date DW Review Reviewed Pls Memo of Law opposing Aronbergs motion for fees/sanctions DW Review Reviewed Pis Response to Aronbergs request to schedule motion for fees after MSJ AU Review Reviewed Pls Memo of Law opposing motion AU Review Reviewed Pis Response to Aronbergs request to schedule motion after MSJ DW Research Research caselaw statutes re response to Pis Memo of Law DW Research Analyze Continued researching caselaw re response to Pls memo.of law DW Draft Created 1st draft of Response to Pl 2s Memo of Law and shared Client DW Meeting Discussed AU caselaw and draft response to memo AU Various Reviewed draft MSJ discussed draft DAW and caselaw DW Draft Finalized and filed Response to Pls Memo of Law DW Telephone Spoke client re memo of law DW Telephone Spoke client again re response to memo of law Qi DW Attend Hearing Attended hearing re Motion to Set CMC called2 client to discuss DW Various Reviewed email and letter from PI re settlement Sent copy to Client and called to discuss CA/Aropi pp038Q BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM AIJ Meeting PW Mee ng ow ow AIJ ow ow ow ow ow ow ow ow A IJ AIJ ow ow ow ow AIJ ow ow ow E-mail Meeting Meeting Various mail E-mail E-mail Various Review Review Review Review Research Research Analyze Draft Meeting Various Draft Telephone Telephone Discussed AIJ phone call Pls co 265nsel Re iei.ved email ficiin Pls counsel request Arontierg to withdr sanctions motion wlo prejudice Discussed AiJ filing motioll pr CMG isciiss wl DAW _filing otion for CMC Drafted and filed rriotiori to set management ci fererice re MSJ 1st or F.1ie hEl_arlng 1st Resp inded to PJs email and refused to withdra motion ided PY of motion to set MC and avaiiable dates for heari11g Reviewed Pls email insisting that 267motion be wAhd 2wn Replied to Pl;s counsel ttiai the motion for sanctions will not be withdrawn and asking for response ie CMC Sent die_nt copy of email exchange w/.Pls counsel caU!:!d and spoke w/Client Dratted and fil Notice of He ring on set up Couri Call spoke client re hearing date Re iew PJs Memo oi Law 267opposing Aronbergs motion for iees/sanctions Reviewed PJs Response to Aro.nbergs request to 267sched Je motion for fees fter MSJ Re i wed PJ.s Memo of Law 267pposing moti_ori Reviewed PJs Response to Aronbergs request to scheoule motion after MSJ Research caselaw statutes re response to Pls Memo of Law Continued researching i::aselaw re response to PJs mem law Created 1st draft of Response to PJs Memo of Law and shared Client Discussed AIJ caselaw an draft response to memo Reviewed draft MSJ discussed draft DAW and caselaw Finalized and filed Res_pons to _Pls Memo of Law Spokll client re me.mo of law poke dient again response memo of law Atie ed hearing re Motion to Set CMC called lO/l Atten_df-ie rl cliJnt_todiscuss ow Various Reviewed email and letter fro P1 re settlement Sent copy to Client and called to discus __ CA/Aroflt:IfilIDPP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM DW Telephone Spoke Pls counsel re settlement o.i DW Telephone Spoke client re Pis settlement proposal AU Various Attended hearing re motion to set CMC discussed w/client AU Various Discussed Pls settlement proposal DAW and then Client DW Meeting Discussed Pls settlement proposal AU DW Various Drafted and shared proposed order Pls counsel DW Telephone Spoke w/Pls counsel re settlement DW Telephone Spoke client re Pls settlement proposal DW Meeting Discussed Pl 2s settlement proposal AU AU Meeting Discussed Pls settlement proposal DAW DW Various Uploaded proposed order re CMC for Judge Hafele DW Telephone Spoke client re Pls settlement proposal DW Telephone Spoke Pls counsel re settlement AU Meeting Discussed Pls settlement proposal DAW DW Meeting Discussed Pl 2s settlement proposal AU DW Various Reviewed email from Pl re settlement sent copy to Client and called to discuss DW Telephone Spoke client re settlement DW Telephone Spoke Pls counsel re settlement DW Telephone Spoke client re settlement DW Meeting Discussed Pls settlement proposal AU AU Meeting Discussed Pl 2s settlement proposal DAW DW Various Drafted and filed Motion to Set Hearing oh Aronberg MSJ drafted proposed order granting motion to set checked court availability emailed Pls counsel re choose date for hearing DW Review Reviewed Order re CMC unnecessary DW telephone Spoke client re media response DW Telephone Spoke client re media response DW Telephone Spoke client re media response DW Telephone Spoke client re riiedia response DW Telephone Spoke client re media response DW E-mail Sent email Aronberg statement to media AU Meeting Discussed media response DAW DW Meeting Discussed media response AU DW Various Reviewed Pls Notice of DrpingAronberg as party spoke Client and AU re notice and next steps i CA/Aropt BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM ow Tel phone Spoke ls counsel re settle_rneiit 42s:oo Telephone Spo wl client re Pl.s settlement proposal ow Attended hearing re motion to set CMC i AIJ Various discussed wl client AIJ Various Discussed Pls settlement proposal DAW and then Client ow Meeting D_iscussed Pls settlement proposal AIJ Drafted and shared propos _order Pls couri el ow Various Telephone ow Spoke Pls counsel settlement ow Telephone Spoke client re Pls settlement propo ow Meeting Discussed Pls_ settlemeht proposal wi AIJ AIJ Meeting DiSCUS Pls settlement proposal DAW ow Various Uploaded proposed order re CMC for Judge Hafele ow Telephone Spoke client re Pis settlement proposal ow Telephone Spoke Pls counsel re seitlement AIJ Meeting Discussed Pls settlement proposal DAW ow Meeting Discussed Pls settlement proposal AIJ ow Various Reviewed email from Pl re settlement sent copy to Client and called to discuss ow Telephone Spoke client re settlement ow Telephone Spoke Pls counsel re settlement ow Telephone_ Spoke client re settlement ow Meeting Discussed Pls settlement proposal AIJ AIJ Meeting Discu 267ssed Pls settlemen_t proposal DAW Drafted and filed Motion to Set Hearing ori ow Various Aronberg MSJ drafted proposed order granting motion to set checked court availability emailed Pls counsel re choose date for hearing ow Review Reviewed Order re CMC unnecessary ow Telephone Spoke client re media _response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow Telephone Spoke client re media response ow E,mail Se_rit_ e_mail Aronberg statement to media AIJ Meeti.ng Discussed media response wt DAW ow Meeting Discussed media response AIJ Reviewed Pl_s Notice of Dropping 267Aronberg ow Various party spoke Client and AIJ re n_otice and next i steps CA/Arofl OP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM AU Various Reviewed Pls Notice of Dropping Aronberg.as party spoke Client and DAW re notice and next steps Totals Time Entry Sub-Total Sub-Total total Amount Paid Balance Due C/VArontEW0pM86l BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM AIJ Various Revie;;.;ed Pl.s Notice oJ ppilg Ar9nberg.?S party;spo CUerit ani bAyJ;,re riotfcearid next oo steps Totals Ti try Sub-Total Sub Total Total Amount P.aid Bai nce 267oue CA/AroFltlaE9J PP BEACH COUNTY FL JOSEPH ABRUZZO CLERK PM
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