EFTA01222222.pdf

LS.J., LLC / LITTLE ST. JAMES / C/O AMERICAN YACHT HARBOR 14573 Hodge & Francois 9/17/2010 50404 • Legal 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 Invoice # 34496 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 S Ir Description Hrs/Rate Amount 08/01/10 DMF Review email from D Indyke and review letter from D Indyke 0.25 75.00 to J Goldberg re specific problems with library cabinetry 300.00/hr 08/06/10 DMF Draft memorandum in support of Defendants motion to 2.00 600.00 dismiss 300.00/hr 08/09/10 DMF Research; draft additional sections to memorandum in 4.00 1,200.00 support of motion to dismiss; forward draft to D Indyke by 300.00/hr email 08/10/10 DMF Research rescission and failure of consideration 0.75 225.00 300.00/hr 08/12/10 DMF Review re draft of memorandum in support of motion to 0.50 150.00 dismiss; confer with MTH re same 300.00/hr 08/13/10 DMF Research for 3d Circuit cases to replace references to 2d 4.00 1,200.00 Circuit; teleconference with D Indyke re suggested changes 300.00/hr 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 08/13/10 DMF Review email from D Indyke along with his revised draft of 0.50 150.00 opposition to motion to dismiss 300.00/hr 08/16/10 DMF Research motion to dismiss; revise most recent draft of 1.50 450.00 motion to dismiss; draft email to D Indyke with most recent 300.00/hr comments on strategy to motion to dismiss 08/16/10 DMF Review email from D Indyke re final revisions; revise and 1.50 450.00 edit memorandum in support of defendants' motion to 300.00/hr dismiss; revise and edit motion to dismiss; file documents electronically; forward electronically filed and served motion and memo to D Indyke 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 25.38 8/24/2010 LD Phone Calls - August 2010 1.98 Total Expenses PG\6 "iv) °. N r" r.... $27.36 Interest on overdue balance li - S .c.'" $176.39 6 4° 9 Total Amount Due This Billing Cycle 4- \ $13,472.50 ' Previous balance 9 $17,307.24 TOTAL BALANCE DUE $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  LS.J., LLC / LITTLE ST. JAMES / CFO AMERICAN YACHT HARBOR 14572 Hodge & Francois 50404 • Legal 9/17/2010 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 Invoice # 34316 6100 Red Hook Qtr - Suite B-3 St Thomas, VI 00802 Attn: Darren Indyke In Reference To: Corporate Matters 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 125.00/hr with D Francois re meeting on LSJ Island and status of cabinets in library as well as additional Exhibit D, Purchase 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 300.00/hr re same 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 300.00/hr for Atelier Fanceli EFTA01222227  Page 2 Jeffrey Epstein Date Lail Description Hrs/Rate Amount 07/30/10 DMF 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 07/30/10 CJ Prepare Exhibits to Complaint 1.00 125.00 125.00/hr Total Hours and Legal Fees 14.00 $2,943.75 Expenses: DaLe Description 7/1/2010 Clerk of Court - Complaint Filing Fee 50.00 7/22/2010 LD Phone Calls - July 2010 4.11 Total Expenses $54.11 Interest on overdue balance $2.87 Total Amount Due This Billing Cycle $3,000.73 Previous balance $281.25 TOTAL BALANCE DUE $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. a \-ciu3D. t. ? el' I- e 425 c" c EFTA01222228  LS.J., LLC / LITTLE ST. JAMES I C/O AMERICAN YACHT HARBOR 14571 Hodge & Francois 9/17/2010 Service rendered for August 2010 1,735.08 50404 • Legal 1,735.08 FirstBank Operating C Invoice #34495 dated 09/01/10 - AUG 2010 • • .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 Invoice # 34495 St. Thomas, VI 00802 Attn: Darren Indyke In Reference To: General Representation For Professional Services Rendered for the Period Ending: August 31, 2010 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 0.25 75.00 Commissioner and CZM director on permit issues 300.00/hr 08/16/10 MTH Telephone call(s) Bob deJongh re CZM permits and client 0.25 75.00 email on meeting with CZM officials re status and guidance 300.00/hr 08/18/10 MTH Telephone call(s) Gary Kearney re status of development 0.25 75.00 plans for LSJ related to CZM permit applications 300.00/hr 08/19/10 MTH Teleconference with client and Indyke re CZM meeting, 0.25 75.00 permit issues, etc. 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 Description 8/9/2010 Westlaw Research - 7/31/10 9.58 8/24/2010 LD Phone Calls - August 2010 0.50 Total Expenses $10.08 Total Amount Due This Billing Cycle $1,735.08 Previous balance $3,663.91 TOTAL BALANCE DUE $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. (I S L. L d `Pcr 1 lc_ P r as P EFTA01222231