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Hodge & Francois
9/17/2010
50404 • Legal
14573
Molyneux
14,679.94
FirstBank Operating C Molyneux
14,679.94
•
554217 (450)
L
•
EFTA01222222
Law Offices of Hodge & Francois
1340 Taarneberg
St Thomas, VI 00802
340-774-6845
September 01, 2010
Tax ID: 66-0473483
Jeffrey Epstein
Go The Epstein Companies
6100 Red Hook Qtr - Suite 8-3
St Thomas, VI 00802
Attn: Darren Indyke
In Reference To: Molyneux v Epstein, et al.
For Professional Services Rendered for the Period Ending: August 31, 2010
IrS
08/01/10 DMF
08/06/10 DMF
08/09/10 DMF
08/10/10 DMF
08/12/10 DMF
08/13/10 DMF
08/13/10 DMF
08/16/10 DMF
08/16/10 DMF
Description
Review email from D Indyke and review letter from D Indyke
to J Goldberg re specific problems with library cabinetry
Draft memorandum in support of Defendants motion to
dismiss
Research; draft additional sections to memorandum in
support of motion to dismiss; forward draft to D Indyke by
email
Research rescission and failure of consideration
Review re draft of memorandum in support of motion to
dismiss; confer with MTH re same
Research for 3d Circuit cases to replace references to 2d
Circuit; teleconference with D Indyke re suggested changes
to his draft of motion to dismiss; confer with MTH re same;
revise and edit Darren's draft of motion to dismiss; draft
email to D Indyke on suggested changes to his draft of
motion to dismiss
Review email from D Indyke along with his revised draft of
opposition to motion to dismiss
Research motion to dismiss; revise most recent draft of
motion to dismiss; draft email to D Indyke with most recent
comments on strategy to motion to dismiss
Review email from D Indyke re final revisions; revise and
edit memorandum in support of defendants' motion to
dismiss; revise and edit motion to dismiss; file documents
electronically; forward electronically filed and served motion
and memo to D Indyke
Invoice # 34496
Hrs/Rate
Amount
0.25
75.00
300.00/hr
2.00
600.00
300.00/hr
4.00
1,200.00
300.00/hr
0.75
225.00
300.00/hr
0.50
150.00
300.00/hr
4.00
1,200.00
300.00/hr
0.50
150.00
300.00/hr
1.50
450.00
300.00/hr
1.50
450.00
300.00/hr
EFTA01222223
Page 2
Jeffrey Epstein
Date
Ink_
Description
Hrs/Rate
Amount
08/18/10 DMF Research re complaint against Molyneux
0.50
150.00
300.00/hr
08/19/10 GV
Research settlement agreement recisision, fraud, mistake,
3.50
787.50
joint agreement, liquidated damages; office conference;
225.00/hr
review pleadings
08/19/10 DMF Teleconference with associate attorney G Vogel re research
0.25
75.00
to set aside settlement agreement and design services
300.00/hr
agreement
08/20/10 DMF Review Scheduling Order entered by Magistrate Judge
0.25
75.00
Miller; calendar same; forward same to D Indyke; confer
300.00/hr
with MTH re attendance of same if D Francois' criminal trial
conflicts
08/23/10 DMF Review email from D Indyke re latest communication from
0.25
75.00
Molyneux's attorneys; Teleconference with D Indyke re
300.00/hr
Molyneux will be amending his complaint again as permitted
by Fed R Civ P 15
08/23/10 DMF Research Rule 15; draft email to D Indyke and client re
1.00
300.00
relevant motion response times
300.00/hr
08/23/10 GV
Draft (start) memo on fraud and recind contract, recind
4.75
1,068.75
settlment agreement, elements of rescision. Research
225.00/hr
elements.
08/24/10 GV
Research gist of the action and damages, settlement
5.75
1,293.75
agreement and funds paid rescion, finish drafting memo
225.00/hr
08/25/10 GV
Research if liquidated damages clauses can limit recovery
2.75
618.75
of attorney fee's and costs, edit memo on damages, office
225.00/hr
conference with DF
08/25/10 DMF Review emails from Rosh D Alger re first Jay Goldberg
0.50
150.00
would listen in on status conference and then he would not;
300.00/hr
draft emails to D Indyke re same
08/25/10 DMF Conference with G Vogel re results of her research on
0.25
75.00
rescission of settlement agreement and liquidated damages
300.00/hr
and re attorney's fees and costs are not covered by
liquidated damages
08/26/10 CJ
Review and organize Plaintiff's Memorandum in Support of
0.25
31.25
Defendants' Motion to Dismiss Amended Complaint,
125.00/hr
Exhibits and Affidavit in Support.
08/26/10 GV
Research grounds to strike exhibits in a response brief to a
5.25
1,181.25
motion to dismiss, review response to our motion to
225.00/hr
dismiss; research Court of Appeals Third Circuit Cir
elements of a dec action, research cases cited in motion to
dismiss, review dismissal pleadings, draft summary of
cases cited & if counterclaim or state court action was
dispositive in rejection dec action
08/26/10 DMF Review defendant's opposition and research re same;
3.00
900.00
conference with G Vogel re research on Declaratory
300.00/hr
Judgment
EFTA01222224
Page 3
Jeffrey Epstein
if ale
Init.
Description
Hrs/Rate
Amount
08/27/10 GV
Research declaratory action, review third circuit opinions on
4.25
956.25
dec actions, draft case summary sheet, review motion for
225.00/hr
areas of great concern
08/27/10 DMF Review and compare Molyneux' amended opposition
0.75
225.00
memorandum and amended affidavit to the memo and
300.00/hr
affidavit filed previously in order to discern the difference;
teleconference with D Indyke re same
08/27/10 DMF Review email from B Moskowitz and final signed affidavit of
0.25
75.00
process server
300.00/hr
08/27/10 CJ
Review additional pleadings filed by opposing counsel and
1.00
125.00
organize same; conference with D Francois re same; review
125.00/hr
Court Docket and discuss with D Francois
08/27/10 CJ
Research Court Docket and pleadings; update client's e-file
1.25
156.25
re same
125.00/hr
08/27/10 DMF Research permitted parameters of Molyneux's opposition
1.00
300.00
300.00/hr
08/27/10 DMF Review email from E Hill of J Goldberg's office
0.25
75.00
300.00/hr
08/31/10 DMF Review email from D Indyke re recent filings by Molyneux
0.25
75.00
compared to actual amended complaint filed
300.00/hr
Total Hours and Legal Fees
52.25
$13,268.75
Expenses:
Da e
Description
8/12/2010
Federal Express - Darren Indyke 7/28/10
-
A
8/24/2010
LD Phone Calls - August 2010
PG\6 "iv) r.... N r"
°.
Total Expenses
Interest on overdue balance
li
S
.c.'"
6 4° 9
4-
Total Amount Due This Billing Cycle
\
'
Previous balance
9
25.38
1.98
$27.36
$176.39
$13,472.50
$17,307.24
$30,779.74
We appreciate your business. Please make your check payable to Hodge & Francois and include
Invoice # on payment. Terms - Due Upon Receipt. An interest charge of 1% per month is
automatically generated on all balances in excess of thirty (30) days.
EFTA01222225
Hodge & Francois
9/17/2010
50404 • Legal
14572
Service rendered for July 2010
3,281.98
FirstBank Operating C Invoice #34316 dated 08/01/10 - JUL 2010
3,281.98
•
584217 (4/08)
•
EFTA01222226
Law Offices of Hodge & Francois
1340 Taarneberg
St Thomas, VI 00802
340-774-6845
August 01, 2010
Tax ID: 66-0473483
Jeffrey Epstein
do The Epstein Companies
6100 Red Hook Qtr - Suite B-3
St Thomas, VI 00802
Attn: Darren Indyke
In Reference To: Corporate Matters
Invoice # 34316
For Professional Services Rendered for the Period Ending: July 31, 2010
PS
lit
Description
Hrs/Rate
Amount
07/01/10 CJ
Prepare Complaint, Exhibits, Civil Cover Sheet and
4.00
500.00
Summonses for preparation of filing; review Epstein v.
125.00/hr
Molyneaux Books to find Purchase Order for Exhibit; email
to Darren Indyke re Complaint and exhibits to same;
conferences with Denise Francois re same
07/01/10 CJ
Conferences with Darren Indyke re Complaint revisions and
0.25
31.25
officers of Fancelli Paneling, Inc.
125.00/hr
07/01/10 DMF Review revised complaint; confer with paralegal re exhibits
0.50
150.00
300.00/hr
07/01/10 CJ
Review documents for additional Exhibits to Complaint;
1.50
187.50
telephone conferences with D Indyke re same; conference
with D Francois re meeting on LSJ Island and status of
cabinets in library as well as additional Exhibit D, Purchase
125.00/hr
Order
07/02/10 GV
Research service of process in France
1.00
225.00
225.00/hr
07/02/10 DMF Research on line for more information on Fancelli Paneling;
1.50
450.00
conference with MTH re allegations against both Atelier
300.00/hr
Fancelli in France and Fancelli Paneling in New York; revise
and edit complaint against Fancelli entities
07/02/10 DMF Review email from D Indyke re naming Atelier Fancelli in
0.25
75.00
France as an additional defendant; draft email to D Indyke
re same
300.00/hr
07/02/10 DMF Revise and edit complaint against Fancelli; review
0.75
225.00
settlement agreement to confirm it does not include
300.00/hr
Fancelli; draft email to D Indyke re same
07/03/10 DMF Review email from D Indyke and review information on
0.25
75.00
Mercure which seems to be French company or legal entity
for Atelier Fanceli
300.00/hr
EFTA01222227
Jeffrey Epstein
Date
Lail
07/30/10 DMF
07/30/10 CJ
Description
Page 2
Hrs/Rate
Amount
Several teleconferences with D Indyke re filing complaint;
3.00
900.00
conference with staff re same; finalize complaint for filing;
300.00/hr
revise and edit complaint; conference with staff re correct
identification of exhibits and filing of complaint
Prepare Exhibits to Complaint
Total Hours and Legal Fees
Expenses:
DaLe
Description
Clerk of Court - Complaint Filing Fee
LD Phone Calls - July 2010
7/1/2010
7/22/2010
Total Expenses
Interest on overdue balance
Total Amount Due This Billing Cycle
Previous balance
1.00
125.00
125.00/hr
14.00
$2,943.75
50.00
4.11
$54.11
$2.87
$3,000.73
$281.25
$3,281.98
We appreciate your business. Please make your check payable to Hodge 8. Francois and include
Invoice # on payment. Terms - Due Upon Receipt. An interest charge of 1% per month is
automatically generated on all balances in excess of thirty (30) days.
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EFTA01222228
50404 • Legal
Hodge & Francois
9/17/2010
Service rendered for August 2010
1,735.08
14571
FirstBank Operating C Invoice #34495 dated 09/01/10 - AUG 2010
1,735.08
•
•
.934217
EFTA01222229
Law Offices of Hodge & Francois
1340 Taarneberg
St Thomas, VI 00802
340.774.6845
September 01, 2010
Tax ID: 66-0473483
LSJ, LLC
6500 Red Hook Qtr., Suite B-3
St. Thomas, VI 00802
Attn: Darren Indyke
In Reference To: General Representation
For Professional Services Rendered for the Period Ending: August 31, 2010
Invoice # 34495
Date
Init.
Description
Hrs/Rate
Amount
08/03/10 MTH Telephone call(s) deJongh re plans to amend submission
0.25
75.00
on parcel A to include spa, appropriate communication with
300.00/hr
CZM re same in advance of filing
08/03/10 MTH Telephone call(s) and draft email to CZM legal counsel
0.50
150.00
requesting discussion of issue of notice requirement for
300.00/hr
advocacy groups re pending permit applications; draft email
to Indyke re Parcel A proposed revision; telephone call,
Indyke, re mooring permit, Parcel A land permit, etc;
telephone call, Anthony Richards at CZM re same l/w
08/11/10 MTH Telephone call(s) Anthony Richards, re status of CZM
0.25
75.00
applications; telephone call, JP Oriole and Bob deJongh re
300.00/hr
same 1/w
08/12/10 MTH Research VI law (statutes and regulations) on deadlines for
1.25
375.00
CZM to raise any objections to completeness of application,
300.00/hr
deadline to act on application, when deemed complete and
when deemed approved without action; Draft email to
Indyke re same with recommendations
08/13/10 MTH Review email from Indyke re new litigation in BVI filed by
1.00
300.00
OBM Limited; draft email response with comments and
300.00/hr
preliminary advice; telephone call, Indyke, re same;
preliminary review of summons and complaint received by
email
08/13/10 MTH Review email from client with summary of meeting with
Commissioner and CZM director on permit issues
08/16/10 MTH Telephone call(s) Bob deJongh re CZM permits and client
email on meeting with CZM officials re status and guidance
08/18/10 MTH Telephone call(s) Gary Kearney re status of development
plans for LSJ related to CZM permit applications
08/19/10 MTH Teleconference with client and Indyke re CZM meeting,
permit issues, etc.
0.25
75.00
300.00/hr
0.25
75.00
300.00/hr
0.25
75.00
300.00/hr
0.25
75.00
300.00/hr
EFTA01222230
Page 2
LSJ, LLC
Date
Init.
Description
Hrs/Rate
Amount
08/24/10 MTH Telephone call(s) Gary Kearney re preparation for filing
0.50
150.00
amendment to major CZM permit for dock, moorings, etc;
300.00/hr
telephone call, representative of deJongh, re plan revision
for new application for minor permit for spa
08/26/10 MTH Research legal requirements and forms for application to
1.00
300.00
modify major CZM permit; telephone call, Oriole, re same
300.00/hr
l/w; begin draft of letter of application for modification;
review ACOE letter rejecting previous after the fact
application to approve after the fact dock permit
Total Hours and Legal Fees
5.75
$1,725.00
Expenses:
Date
8/9/2010
8/24/2010
Total Expenses
Description
Westlaw Research - 7/31/10
9.58
LD Phone Calls - August 2010
0.50
Total Amount Due This Billing Cycle
Previous balance
$10.08
$1,735.08
$3,663.91
$5,398.99
We appreciate your business. Please make your check payable to Hodge & Francois and include
Invoice # on payment. Terms - Due Upon Receipt. An interest charge of 1% per month is
automatically generated on all balances in excess of thirty (30) days.
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EFTA01222231