Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 1 of 377
EXHIBIT B
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 2 of 377
Attorneys At Law
P. O. BOX 201626
HOUSTON, TEXAS 77216-1626
TAXPAYER I.D. #74-1195457
Stanford Financial Group Receivership Invoice No. 1134163
ATTN: Mr. Ralph S. Janvey, Receiver Invoice Date September 23, 2009
2100 Ross Avenue
Suite 2600 Attorney J A Cialone, II
Dallas TX 75201
079716.0102 Cross Border Receivership Matters
Hours Description
06/01/09 R I Howell 1.00 Correspondence with English counsel and with Karyl Van
Tassel regarding REDACTED
.
06/01/09 R T Preston-Jone 7.00 Perusing draft affidavits and preparing exhibits; preparing letter
for service and arranging service of evidence; arranging
copying of court bundles for counsel.
06/01/09 E A Soderlund 1.80 Review and revise memo of T. Walters regarding REDACTED
effects on receivership estate and send same to J.
Cialone and T. Davis.
06/01/09 W F Stutts, Jr. 1.10 Reviewed REDACTED affidavit and communication with
Mark Russell on REDACTED ; brief
communications with Bob Howell regarding the scope.
06/01/09 W F Stutts, Jr. .40 Communications with Clare Roberts regarding admission
application for Stuart Isaacs and other status points in Antigua.
06/01/09 W F Stutts, Jr. 1.80 Reviewed information and draft filing from Walker McLeod
and commented on same; participated in call regarding timing
of proceedings in various provinces; reviewed information
from Mr. Hendy regarding Quebec and Ontario relationship.
06/02/09 M E Burnett 1.20 Searched for foreign bankruptcy recognition translations in
English for Bill Stutts.
06/02/09 J A Cialone, II .50 Counsel about Vantis proposal.
69
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 3 of 377
Page 2
Hours Description
06/02/09 R I Howell 4.50 Worked on REDACTED for the Chapter 15
response.
06/02/09 T M Moratto Jr. .50 Per K. Hinton, provided copies of second affidavits and
exhibits of Janvey, Van Tassel and Westbrook.
06/02/09 R T Preston-Jone 6.80 Preparing bundles for use at hearing; telephone call from clerk
to David Joseph (for Stanford) and reporting same to team;
conferring with Cameron McKenna by phone re bundle;
preparing list of authorities and printing same for sending to
Stuart Isaacs QC (barrister) and Felicity Toube (barrister);
conferring with US colleagues as to further authorities; letter
received from Cameron McKenna and discussing same with
team; preparing response and circulating.
06/02/09 W F Stutts, Jr. .90 Reviewed changes in Canada with George Hendy and reviewed
communication from Sonja Bjorkquist regarding
REDACTED ;
related additional communications with Mr. Howell regarding
same.
06/02/09 W F Stutts, Jr. .30 Reviewed recent issues with English counsel for Antiguan
liquidators regarding REDACTED .
06/03/09 J A Cialone, II 1.50 Calls and emails about Antiguan liquidators; attention to
bankruptcy emails and authorities in connection with
bankruptcy motion.
06/03/09 V O Garcia 2.00 Per B. Howell, prepare cover letter to Dick DeGuerin enclosing
Second Affidavits with Exhibits and jetpack same to Houston
for hand delivery; receive delivery confirmation regarding
Nickens Keeton and forward same to B. Howell and file;
correspond with B. Cominsky regarding hand delivery of
additional documents (2.0)
06/03/09 R I Howell 2.00 Commented on skeleton argument in English action.
06/03/09 R T Preston-Jone 5.10 Preparing affidavit re service and conferring with Felicity
Toube (barrister) as to contents; sending letter to Addleshaws
(solicitors for Stanford); letter to Cameron McKenna re Order
of Registrar Jaques; conferring with Nabarro re hearing;
conferring with Bob Howell re serving further evidence on
Stanford's US lawyers; receiving skeleton argument from
Stuart Isaacs QC (barrister) and reviewing and commenting.
06/03/09 W F Stutts, Jr. .70 Report from Mr. Preston-Jones regarding developments in
English proceeding (moving toward hearing); documents;
reviewed draft skeleton and commented on same.
06/03/09 W F Stutts, Jr. .90 Report to Mr. Janvey regarding Ontario and Quebec and
communications with Mr. Howell on REDACTED ;
70
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 4 of 377
Page 3
Hours Description
telephone conferences with Walker McLeod and information
on the Canadian Plaintiff; several communications with Mr.
Arevalo regarding funds.
06/04/09 J A Cialone, II .50 Attention to bankruptcy issues.
06/04/09 V O Garcia .20 Receive and forward delivery confirmation regarding Dick
DeGuerin; (.2)
06/04/09 R I Howell 8.00 Worked on REDACTED
and circulated a draft; worked on REDACTED
; conference call with Canadian counsel to
get their recommendation regarding REDACTED
; reviewed order served by
Nabarros on UK counsel and correspondence with UK counsel
regarding meaning of same REDACTED
; asked UK counsel to seek additional
information REDACTED
06/04/09 R T Preston-Jone 5.30 Receiving and watching DVDs of Stanford corporate video and
seminar; swearing and filing affidavit of service; providing
copies of DVDs to barristers; commenting on draft skeleton
argument; receiving and perusing MLAT affidavit and
documents form Nabarro; conferring with Nabarros by phone
and email; receiving other sides' skeletons and reviewing same.
06/04/09 W F Stutts, Jr. 1.10 Communications with Robin Preston-Jones, Bob Howell and
Alberto Arevalo regarding communication received today from
Nabarro and English skeleton arguments.
06/04/09 W F Stutts, Jr. .60 Brief review of information and affidavits relating to Chapter
15 motion.
06/04/09 W F Stutts, Jr. .90 Left word for Clare Roberts regarding property and regarding
REDACTED compensation; related communications
with Ms. Blumenschein and Mr. Janvey.
06/05/09 R I Howell 6.00 Worked on Janvey affidavit.
06/05/09 M S Kontopoulos .60 Updating bundles of documents
06/05/09 R T Preston-Jone 4.80 Conferring with Cameron McKenna re missing pages from
bundles and providing repaginated copies of same to barristers;
further communicating with Nabarro re MLAT by email;
obtaining article from Westlaw for Felicity Toube (barrister);
conferring with Addleshaws by phone to notify of hearing;
receiving further affidavit evidence from Cameron McKenna
and agreeing inclusion in bundle; conferring with Stuart Isaacs
QC (barrister) and Felicity Toube (barrister) re additional
evidence;
71
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 5 of 377
Page 4
Hours Description
06/05/09 W F Stutts, Jr. 2.90 Inquiry for Karyl Van Tassel regarding investors and worked
on information for evidence, and coordination of skeleton
argument for same ; consulted with Bob Howell regarding
English proceedings REDACTED
; several communications on the
evidence and related argument points with Mr. Howell, Mr.
Preston-Jones, Ms. Toube, Mr. Isaacs; raised inquiry to Mr.
Reece regarding delivery of copy of order referred to in
correspondence.
06/05/09 W F Stutts, Jr. 1.30 Reviewed general information related to REDACTED and
reviewed proposed letter to Ms. Hime from counsel, all
.
regarding the points of concern about REDACTED
06/06/09 J A Cialone, II .60 Reviewed FTI affidavit REDACTED .
06/06/09 R I Howell 6.50 Reviewed and revised the response to Vantis's Chapter 15
motion.
06/07/09 J A Cialone, II .50 Reviewed draft Janvey affidavit in Chapter 15 proceeding;
calls and emails about same.
06/07/09 R I Howell 10.00 Worked on the Van Tassel and Janvey declarations in support
of the response to Vantis's Chapter 15 response; conference
call with Karyl Van Tassel regarding same.
06/08/09 T M Davis .80 Read chapter 15 materials.
06/08/09 R I Howell 10.00 Revised Ch. 15 response and affidavits and worked to pull
together exhibits for the affidavits; drove to Houston and
caught flight to London for UK hearing.
06/08/09 R T Preston-Jone 3.10 Telephone call from Dylan Playfoot re TF article; conferring
with Nabarros re hearing date and MLAT; finishing reading
Cameron McKenna's skeleton; receiving and Perusing skeleton
for Allen Stanford; receiving fourth affidavit of Hamilton
Smith and circulating; conferring with Bob Howell by email as
to contents of bundle; conferring with team as to Clare Roberts
update.
06/08/09 W F Stutts, Jr. 3.90 Worked on preparation and delivery of affidavits in English
proceeding; related information exchanged with Mr. Preston-
Jones and Mr. Howell regarding points in preparation for
hearing and assignment of administrative responsibilities for
court determinations and filings.
06/08/09 W F Stutts, Jr. .40 Information from Sir Clare Roberts regarding application for
leave to appeal and developments in Antigua, including
litigation related to REDACTED .
72
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 6 of 377
Page 5
Hours Description
06/08/09 W F Stutts, Jr. .80 (Canada) Worked on additional information for Canada;
responded to inquiry from Mr. Hendy regarding
REDACTED ; information from Mr.
Arevalo regarding Attorney General position and Department
of Justice position.
06/09/09 J A Cialone, II .30 Reviewed Chapter 15 papers; attention to UK issues raised by
Stutts.
06/09/09 R I Howell 8.00 Flight to London; went to London office of Baker Botts to
continue work on Ch. 15 response.
06/09/09 R T Preston-Jone 2.50 Preparing for hearing including finalization of bundles;
Perusing further evidence served.
06/09/09 W F Stutts, Jr. .90 Regarding Canada: Alberta litigation: Worked in Houston on
points for REDACTED
.
06/09/09 W F Stutts, Jr. .90 Reviewed information form Mr. Howell regarding hearing in
London and provided input and information for him as
necessary from Houston information not available in court.
06/09/09 W F Stutts, Jr. .70 Developed outline for proposal for REDACTED
and related communications with Ms.
Blumenschein and Mr. Cialone.
06/09/09 W F Stutts, Jr. .60 Regarding Canada and Ontario proceeding: updated
information on status and funds from Ms. Bjorkquist.
06/10/09 J A Cialone, II .40 Continued discussions about Chapter 15 issues and documents.
06/10/09 R I Howell 7.00 Met with UK lawyers in advance of the hearing and attended
the first day of hearing.
06/10/09 S Jampala 3.80 Checked over Dan Rohleder's Stanford work; Antigua folder
added to the shared drive; corresponded with Dan Rohleder
about status of case.
06/10/09 M S Kontopoulos 1.20 Pre-trial preparation of files; assisting R.Preston-Jones with
transport of documents to court
06/10/09 R T Preston-Jone 7.50 Preparing for, traveling to and attending at hearing of
Application for recognition under the Cross-Border Insolvency
Regulations.
06/10/09 W F Stutts, Jr. 1.90 Canada: Quebec: provided additional information to Canadian
counsel regarding US and other proceedings and updated the
information available to Canada.
06/10/09 W F Stutts, Jr. 1.60 Extended conversation with Mr. Arevalo regarding points of
information regarding status of proceedings and checked at his
request general information about a particular account of Julius
73
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 7 of 377
Page 6
Hours Description
Baer; examined information on declarations and other
evidence.
06/10/09 W F Stutts, Jr. .30 Received additional information from Mr. Howell regarding
English proceedings and their status.
06/11/09 M E Burnett .30 Provided electronic copies of pleadings for Bill Stutts.
06/11/09 M E Burnett .20 Provided electronic copy of case for David Arlington.
06/11/09 R I Howell 7.00 Attended second day of hearing and sent update to Bill Stutts.
06/11/09 R T Preston-Jone 7.50 Preparing for, traveling to and attending at hearing of
Application for recognition under the Cross-Border Insolvency
Regulations.
06/11/09 W F Stutts, Jr. 1.80 Provided Julius Baer information to Mr. Arevalo's office;
reviewed information regarding skeleton arguments and
English court filings; report from Mr. Howell on trial
information; reviewed inquiry from Ms. Ayers regarding SEC
evidence and responded with the information requested.
06/12/09 R I Howell 2.70 Attended the final day of hearing.
06/12/09 R T Preston-Jone 4.00 Preparing for, traveling to and attending at hearing of
Application for recognition under the Cross-Border Insolvency
Regulations.
06/12/09 W F Stutts, Jr. .20 Report from court proceeding in London.
06/12/09 W F Stutts, Jr. 1.60 Canada: reviewed information form Mr. Hendy regarding
affidavits and declarations and provided additional information
for him.
06/12/09 W F Stutts, Jr. .70 Participated in conference call to provide status on foreign
matters and to obtain answers on particular questions regarding
insurance and progress in particular jurisdictions.
06/13/09 W F Stutts, Jr. .40 Telephone conferences with Clare Roberts on REDACTED
and requesting clarification on status
in proceeding.
06/15/09 S W Austin .70 Telephone consultation with Bill Stutts regarding
REDACTED ; sent e-mail
message to Wes Watts requesting draft lis pendens. outlining
facts and forwarding charge papers.
06/15/09 R I Howell 9.00 Return travel from UK hearing.
06/15/09 R T Preston-Jone 3.20 Considering emails relating to appearance in Court of Appeal
in Caribbean; conferring with Bill Stutts as to REDACTED
Stuart Isaacs QC (barrister); providing review of
SEC freezing order proceedings.
74
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 8 of 377
Page 7
Hours Description
06/15/09 W F Stutts, Jr. 2.20 Reviewed information from Ms. Blumenschein impacting
REDACTED ; reviewed information
regarding Canadian hearing for July 22; several communication
with Mr. Isaac regarding current situation in England.
06/16/09 R I Howell 5.80 Reviewed and commented on draft reply; office conference
with Bill Stutts to review the status of the different foreign
proceedings; review email correspondence from English and
Canadian counsel.
06/16/09 W F Stutts, Jr. .30 Telephone conference with David Reece regarding our request
to receive copy of April 7 order in England; related
communication with Mr. Howell on English proceeding points.
06/17/09 J A Cialone, II .80 Attention to bankruptcy issues.
06/17/09 R I Howell 6.60 Conference call with Bill Stutts and Rose Romero regarding
the various foreign proceedings; conference call with Bill
Stutts and Sam Cooper regarding Swiss issues; worked on
update to Ralph Janvey on the foreign proceedings.
06/17/09 W F Stutts, Jr. .80 Reviewed information on Canadian proceedings and prepared
for communications with Mr. Hendy for June 18.
06/17/09 W F Stutts, Jr. 1.10 Worked on June update for non-U S proceedings for Mr.
Janvey.
06/17/09 W F Stutts, Jr. .20 CANADA: Ontario: reviewed form of order for status
positioning in Ontario case and communications with Mr.
Bjorkquist regarding same.
06/18/09 S W Austin 1.90 Reviewed charge on Antiguan real estate filed by Allen
Stanford; office consultation with Wes Watts regarding same
and regarding results of his research REDACTED ;
reviewed e-mail message from Wes Watts summarizing results
of research; sent e-mail message to Craig Adams requesting
information on status of entities and status of directors in
entities REDACTED .
06/18/09 J A Cialone, II .50 Attention to bankruptcy and related issues.
06/18/09 R I Howell 3.50 Conference call with Ralph Janvey, Kristie Blumenschein and
others regarding foreign proceedings.
06/18/09 W F Stutts, Jr. 1.70 Updated Mr. Janvey and SEC regarding foreign proceedings;
Reviewed information from Mr. Hendy regarding new
affidavits for Mr. Janvey and Ms. Van Tassel; reviewed with
Mr. Howell draft Ontario order and comments.
06/19/09 R I Howell 2.30 Reviewed Stanford indictment and forwarded same to foreign
counsel and asked them to REDACTED
; telephone conference with
75
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 9 of 377
Page 8
Hours Description
Kristie Blumenschein regarding REDACTED
consent decree for Ontario stay and need for filing fee in
Swiss action; reviewed correspondence from Swiss counsel and
sent Swiss counsel our Chapter 15 response for her possible
use.
06/19/09 R T Preston-Jone 3.40 Email received from Stuart Isaacs QC (barrister) re travel
arrangements and conferring with Bob Howell by email; email
exchanges with Bob Howell and barristers re second amended
complaint and REDACTED ; Perusing second
amended complaint and other US filings.
06/21/09 S W Austin .20 Reviewed reply from Mike Myers regarding entities
REDACTED .
REDACTED
06/22/09 S W Austin 1.10 Forwarded information regarding
entities to Wes Watts; office consultation with Wes Watts
regarding REDACTED alternatives; office consultation
with Bob Howell regarding ruling and possible impact
.
06/22/09 S A D Ayers 1.00 Conducted research regarding U.S. courts consideration of
foreign judgments REDACTED .
06/22/09 J A Cialone, II 1.20 Attention to UK proceedings and expected judgment and
related calls and emails; reviewed UK judgment materials;
attention to Chapter 15 papers and issues.
06/22/09 R I Howell 7.50 Reviewed materials relating to Bank of Antigua request for
release of frozen funds; reviewed English draft judgment;
conference call with UK counsel regarding same; sent memo
regarding same to Ralph Janvey, and corresponded with team
members regarding same; telephone conference with Canadian
counsel regarding status of Canadian proceeding; corresponded
with Swiss counsel regarding the outcome of the English case
and requested a conference call.
06/22/09 R T Preston-Jone 4.80 Receiving and considering draft judgment; preparing letter to
Cameron McKenna re letter to Judge; preparing letter to Judge;
preparing for and participating in conference call re judgment;
researching and explaining confidentiality obligations re draft
judgments;
06/22/09 K Scanlan 1.50 Review request for materials from Austin; telephone
conference with District Clerk to request materials; office
conference with clerk regarding certifications; prepare
materials for Houston; prepare international package and
forward certified copies to Swiss counsel.
06/22/09 W C Watts .90 Reviewed Antiguan statutes regarding REDACTED
; reviewed places of incorporation of certain Stanford
76
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 10 of 377
Page 9
Hours Description
entities; met with Shelley Austin.
06/23/09 S W Austin .10 E-mail message from Mike Meyers with additional information
regarding entities REDACTED ; replied.
06/23/09 J A Cialone, II 1.00 Calls and emails about UK decision and next steps.
06/23/09 R I Howell 6.00 Further analysis of UK judgment; conference call with Ralph
Janvey, Kristie Blumenschein and others regarding same;
began work on brief to be filed when UK judgment is
submitted to the US court; telephone conference with Albert
Arevalo and Yoko Matsuhashi regarding status of SEC's freeze
efforts in foreign jurisdictions and sent memo regarding same
to Ralph Janvey and others.
06/23/09 S A Massad 1.00 Participated in conference call regarding UK decision and
related matters.
06/24/09 R I Howell 5.50 Conference call with UK counsel; email correspondence with
Alberto Arevalo of the SEC; further work on brief regarding
UK judgment.
06/24/09 R T Preston-Jone 3.90 Considering letter received from Cameron McKenna and email
to Addleshaws; preparing folder of cases and sending to Bob
Howell as requested; conference call and preparing letter to
Karen Denny and sending.
06/24/09 E A Soderlund 4.10 Prepare for and participate in call with T. Davis and J. Cialone
regarding strategic issues REDACTED , and follow up
work regarding same; call with R. Janvey. R. Campbell, R.
Roper, T. Davis, and J. Cialone regarding chapter 15 and
bankruptcy issues relating to receivership REDACTED
, and follow up research regarding same.
06/24/09 J C Stewart 1.10 Research and analyze statutes and caselaw addressing
REDACTED
.
06/24/09 W F Stutts, Jr. .30 Report from Mr. Howell regarding his conversations with Mr.
Arevalo and Ms. Mitshuashi.
06/24/09 W F Stutts, Jr. .40 Reviewed updated information from Mr. MacLeod regarding
Alberta litigation.
06/25/09 S W Austin .20 Sent e-mail message to WFS outlining alternatives regarding
Antiguan real estate charge.
06/25/09 S A D Ayers 1.50 Analyzed and summarized for Kevin Sadler the reply filed by
Antiguan Liquidators.
06/25/09 J A Cialone, II .80 Reviewed emails and papers related to the Chapter 15 issues;
calls and emails about dealings with Vantis.
77
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 11 of 377
Page 10
Hours Description
06/25/09 R I Howell 6.00 Further research for memo to Ralph Janvey on cross-border
insolvency issues.
06/25/09 E A Soderlund 2.80 Research REDACTED and other bankruptcy-related issues;
call with T. Davis regarding same.
06/25/09 J C Stewart 1.80 Receive research instructions from E. Soderlund regarding
REDACTED
; review and analyze
caselaw in connection with same.
06/25/09 W F Stutts, Jr. 1.40 Reviewed land charge information and instructions to Ms.
Austin regarding preparation of form of same; reviewed
England draft judgment with Mr. Howell; communications
with Michael Moore and provided information to him
regarding meeting in Miami scheduled for end of July;
reviewed information from Canada regarding Alberta court
decision.
06/26/09 S W Austin .90 Reviewed and marked-up Wes Watts's draft Antiguan charge
and sent comments.
06/26/09 R I Howell 4.40 Further work on Ch. 15 issues and REDACTED UK
judgment.
06/26/09 J C Stewart 6.80 Review and analyze caselaw and treatises addressing
REDACTED
and email summary of research to E.
Soderlund.
06/26/09 W F Stutts, Jr. .90 Telephone conference with Alberto Arevalo and report on
same to Mr. Howell and Mr. Janvey; prepared draft agenda for
Mr. Janvey and transmitted same to him REDACTED
.
06/27/09 J C Stewart 1.50 Continue researching issue of REDACTED
and numerous emails with E. Soderlund
regarding same.
06/27/09 W F Stutts, Jr. .30 Communication with Robert Plotkin regarding TD matters
involving Canada and Alberta decision and impact of Alberta
on Ontario proceeding.
06/28/09 R I Howell 3.30 Further work on memo (precursor to brief) on Ch. 15 issues;
email correspondence to team on Ch. 15 issues; finalized draft
of letter to Rose Romero and circulated to team for comment.
06/28/09 J C Stewart 2.00 Continue researching whether REDACTED
and review
and comment on internal memorandum regarding same.
06/29/09 J A Cialone, II .50 Calls and emails about bankruptcy issues; reviewed memos and
78
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 12 of 377
Page 11
Hours Description
other materials on bankruptcy.
06/29/09 R I Howell 4.00 Further research relating to REDACTED and other
issues relevant to the U.K. judgment.
06/29/09 R T Preston-Jone 2.90 Preparing letter to Judge and letter to Addleshaws re further
documents; email exchanges re submission of further
documents; considering first draft Grounds of appeal.
06/29/09 W F Stutts, Jr. 3.70 Reviewed letter draft to SEC regarding
REDACTED ; reviewed
developments related to contents of accounts at TD and
provided information on those accounts to Mr. Howell;
reviewed records in Stanford warehouse and examined
potentially relevant contacts and communications by certain
broker/dealers.
06/29/09 W F Stutts, Jr. .90 Reviewed information regarding offer to purchase office
furniture in Montreal ;premises and communications with Mr.
Hendy regarding same.
06/30/09 J A Cialone, II .80 Attention to bankruptcy memos and materials; related calls and
emails.
06/30/09 R I Howell 5.20 Drafted substance of REDACTED affidavit; further work
on memo and brief explaining U.K. judgment.
06/30/09 R T Preston-Jone 2.70 Preparing further draft letters inc to Cameron McKenna;
revising earlier draft letters; sending letters; press search re
MLAT and informing legal team; receiving letter from
Cameron McKenna and circulating.
06/30/09 W F Stutts, Jr. .70 Reviewed and considered with Mr. Howell the REDACTED comments
on draft UK judgment.
07/01/09 M E Burnett .20 Searched for and provided copy of case for Bill Stutts.
07/01/09 R I Howell 3.70 Conference call with Alberto Arevalo; further work on brief to
the U.S. court regarding U.K. court judgment.
07/01/09 R T Preston-Jone 3.30 Preparing UK style version of affidavit for Karyl Van Tassel;
arranging conference call to discuss hearing on judgment;
attending to barristers' expenses reclaims; considering draft
note for US court.
07/01/09 W F Stutts, Jr. 3.90 Reviewed information from Stuart Isaac regarding our brief to
US court; reviewed new information regarding affidavit
REDACTED
(on new facts); preparation for conference call on 7/2; worked
on administration on S Isaacs matters related to affidavit.;
several communications with Mr. Howell; reviewed
information regarding grounds for appeal revisions.
79
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 13 of 377
Page 12
Hours Description
07/02/09 S W Austin .40 Attention to emails from Bill Stutts regarding
REDACTED to be filed by receiver; e-mail message to
Wes Watts regarding same;
07/02/09 J A Cialone, II 1.20 Attention to memo and other correspondence related to the UK
ruling; calls and emails about the UK rulings and its
consequences; calls and emails about bankruptcy meeting at
Receiver's office before and after.
07/02/09 R I Howell 5.20 Conference call with U.K. lawyers regarding tomorrow's
hearing on the form of the court's order; further work on brief
to file with the U.S. court regarding the U.K. judgment;
reviewed and commented on U.K. counsel's argument outline.
07/02/09 R T Preston-Jone 5.20 Receiving third affidavit of KVT and serving; arranging copies
of correspondence for Stuart Isaacs QC (barrister) and Felicity
Toube (barrister); conferring with Karen Denny; receiving
papers form Addleshaws and circulating to team; preparing for
and participating in conference call; receiving further affidavit
evidence from Cameron McKenna and considering.
07/02/09 E A Soderlund 1.30 Meet with R. Janvey, B. Krage, and counsel for putative
intervenors regarding bankruptcy-related issues.
07/02/09 W F Stutts, Jr. 3.10 Addressed points related to terms of ruling, points of appeal,
description of that ruling and information on website,
additional evidence, mechanics of trial order and judgments in
UK; communications from Antiguan liquidators lawyer;
conference call on status; examined REDACTED jurisprudence.
07/02/09 W F Stutts, Jr. .20 Placed additional inquiries to CRK regarding status of
REDACTED .
07/03/09 J A Cialone, II .60 Attention to committee proposal from New York bankruptcy
counsel.
07/03/09 R T Preston-Jone 6.50 Preparing for and attending court for judgment; conferring with
Karen Denny; receiving summary assessment schedule from
Addleshaws and researching current rates recoverable in court;
preparing letter to Cameron McKenna re affidavit; conferring
with Cameron McKenna by phone.
07/03/09 W F Stutts, Jr. 2.90 ENGLAND: Extended review, discussion and analysis and
comment on matters related to judgment proposed in English
recognition case.
07/03/09 W F Stutts, Jr. .90 CANADA conference call regarding status and developments
in Quebec regarding positions taken by Antiguan liquidators
and telephone conferences with RIH regarding those issues and
communications regarding Montreal furnishings.
80
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 14 of 377
Page 13
Hours Description
07/03/09 W F Stutts, Jr. .60 ANTIGUA Reviewed information and draft notification for
restriction on the lands; commented on the form provided.
07/04/09 J A Cialone, II .60 Calls and emails about committee proposal.
07/04/09 R I Howell 5.50 Worked on brief to U.S. Court explaining and distinguishing
the U.K. judgment.
07/04/09 W F Stutts, Jr. 3.20 ENGLAND: reviewed order/judgment developments, bases,
actions to be taken; communications with England on the
points necessary on next steps and several communications
with Bob Howell regarding the points.
07/04/09 W F Stutts, Jr. 1.80 ENGLAND: Communicated copies of ruling to SEC, with
extended discussion of provisions of the order; related
additional information sent to Houston and Dallas lawyers;
several communications with Mr. Howell regarding
distinguishing characteristics of ruling and appeals related to
errors of law.
07/04/09 W F Stutts, Jr. .30 CANADA reviewed and responded to Mr. Hendy's inquiries
related to Montreal offices.
07/04/09 W C Watts .70 Revised draft of application for restriction of Antiguan
properties.
07/05/09 W F Stutts, Jr. 1.10 Continued work on analysis of order in England; transmitted
Vantis's report of February 26 to Mr. Hendy ; communications
with Mr. Hendy regarding UK judgment.
07/06/09 J A Cialone, II .90 Further emails about bankruptcy committee; reviewed
proposed letter to SEC about UK and Vantis issues.
07/06/09 R I Howell 6.20 Worked on memorandum brief and, in that connection,
reviewed comments by U.K. counsel and by Jay Westbrook;
participated in conference call with Ralph Janvey and others
regarding pending items, including cross-border issues.
07/06/09 R T Preston-Jone 2.90 Considering draft order from Antiguan Liquidators; conferring
with Felicity Toube (barrister) by email as to Stanford's
permission to appeal; providing note relating to time for
making an application for permission to appeal; email to Bob
Howell attaching cited cases in judgment.
07/06/09 W F Stutts, Jr. 1.50 ENGLAND: Reviewed draft order and consulted with Ms.
Toube as to appeal status and party positions and related
communications with Mr. Howell.
07/06/09 W F Stutts, Jr. .30 Worked and commented on proposed letter from RSJ to Rose
Romero.
07/06/09 W F Stutts, Jr. 1.40 ENGLAND: Communications with Professor Westbrook
81
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 15 of 377
Page 14
Hours Description
regarding status of matters in England; worked on matters on
particular issues in brief in English appeal and communications
with Mr. Howell regarding same.
07/06/09 W F Stutts, Jr. .50 Further inquiry from SEC regarding meeting in Miami and
agenda; reviewed information related to meeting with AMF as
provided by Canadian counsel; effect of facts alleged in Willis
class action.
07/07/09 R I Howell 8.30 Worked all day on memorandum brief to Judge Godbey
regarding the U.K. judgment.
07/07/09 R T Preston-Jone .90 Perusing emails between barristers and Judge re permission to
appeal; conferring with Stuart Isaacs QC (barrister) by email as
to expenses.
07/07/09 W F Stutts, Jr. .90 ENGLAND: Reviewed arguments on permission to appeal and
administrative elements of appeal.
07/08/09 J A Cialone, II .60 Attention to Chapter 15 documents and issues; related calls and
emails; calls and emails about UK proceeding; emails about
Vantis issues.
07/08/09 R I Howell 10.50 Worked on brief regarding U.K. judgment.
07/08/09 R T Preston-Jone 2.90 Considering in depth draft memorandum brief re UK
proceedings and commenting to Bob Howell; receiving draft
affidavit for use in Antigua and organizing exhibits.
07/08/09 W F Stutts, Jr. 4.70 Worked on overall appeal points, costs of claims,
communications with Mr. Preston-Jones, Ms. Toube and Mr.
Isaacs; reviewed issues related to appeal; examined issues
particularly significant to overall points and specific points for
raising to court of appeal.
07/09/09 M E Burnett .90 Provided copies of cases for Bill Stutts.
07/09/09 R I Howell 7.70 Finalized memorandum brief on U.K. judgment's COMI
conclusion; met with Jay Westbrook and Bill Stutts on Prof.
Westbrook's supplemental Canadian affidavit.
07/09/09 R T Preston-Jone .40 Considering revised memorandum brief; email received from
Stuart Isaacs QC (barrister) re SFO barrister communication.
07/09/09 W F Stutts, Jr. 4.90 CANADA: Reviewed with Mr. Hendy the development of
issues in Canada and brief review of status of proceedings in
Alberta; reviewed Canadian statute and case law citation
information for consistency with non-Canadian proceedings.
07/09/09 W F Stutts, Jr. .80 ENGLAND: Communications with Mr. Arevalo as to status of
developments in England with related examination of influence
on other points; additional confirmations from Mr. Arevalo as
82
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 16 of 377
Page 15
Hours Description
to his understanding of status of REDACTED .
07/10/09 J A Cialone, II 1.00 Attention to Chapter 15 issues and related calls and emails,
07/10/09 R I Howell 2.70 Reviewed and revised Janvey affidavit for Quebec; worked on
motion for leave to file supplemental evidence in the U.S.
Chapter 15 proceeding.
07/10/09 W F Stutts, Jr. 3.70 CANADA: Reviewed affidavits filed and communications with
Mr. Howell regarding same.
07/10/09 W F Stutts, Jr. 1.10 ENGLAND: Communications with Mr. Howell, Ms. Toube,
Mr. Preston-Jones and examined principles of REDACTED
07/10/09 W F Stutts, Jr. .60 Communication with Mr. Arevalo regarding requesting copy of
April 7 order; related report to Mr. Arevalo regarding Bank of
Antigua accounts and obtained his view as to SEC position.
07/11/09 W F Stutts, Jr. .80 CANADIAN filings:Reviewed new Canadian filings and
several communications with Osler regarding status of U.S.
proceedings; notation to Ms. Ayers regarding information in
U.S. that affects Canada.
07/12/09 S A D Ayers 1.00 Responded to inquiries from Osler firm regarding motions,
declarations and evidence filed in chapter 15 action.
07/12/09 R I Howell 1.50 Reviewed and commented on the U.K. trial team's U.K. appeal
points.
07/12/09 W F Stutts, Jr. 3.30 ENGLAND: Prepared for call with reporter and
communications with Mr. Cialone regarding same; work
through issues on English appeal.
07/13/09 J A Cialone, II 1.00 Attention to bankruptcy issues including consideration of
REDACTED .
07/13/09 R I Howell 5.50 Participated in call with Houston Chronicle reporter; finalized
motion for leave to file supplemental evidence; worked on
motion for clarification of receivership order.
07/13/09 R T Preston-Jone 3.70 Email received from Bill Stutts relating to evidence filed in the
UK; checking through evidence and preparing email to Bill
Stutts; commenting on draft grounds of appeal;
07/13/09 W F Stutts, Jr. 1.10 Reviewed draft motion from Mr. Hendy regarding affidavits
and related examination of documents provided to Mr. Hendy
regarding other proceedings.
07/13/09 W F Stutts, Jr. .90 England: Prepared for and participated in call with reporter
from Houston Chronicle.
07/14/09 S A D Ayers .50 Telephone conference with Osler law firm regarding lawyers
83
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 17 of 377
Page 16
Hours Description
representing parties and proper method for service of process.
07/14/09 R I Howell 4.20 Worked on motion for clarification of receivership order and
conducted research relating thereto.
07/14/09 R T Preston-Jone 1.90 Email received from Nabarro and responding; conferring with
Felicity Toube (barrister) and further emails to and from
Nabarro; considering filing in US by Antiguans.
07/14/09 W F Stutts, Jr. 2.70 ENGLAND: Reviewed Antigua appeal documents.
07/15/09 R I Howell 6.40 Reviewed draft skeleton argument and began working on edits
and comments to same.
07/15/09 M S Kontopoulos .60 Discussion with R.Preston-Jones; emails to and from Houston
office; preparing documents for scanning
07/15/09 R T Preston-Jone 3.10 Email exchanges re Appeal in Antigua; starting to prepare
Bundle for Court of Appeal; preparing Appellant's Notice and
emailing to Felicity Toube (barrister).
07/15/09 W F Stutts, Jr. .50 CKR regarding land issues in Antigua.
07/15/09 W F Stutts, Jr. .60 CANADA: Communications with Osler and Mr. Howell
regarding new filing by Dynasty furniture in Ontario.
07/15/09 W F Stutts, Jr. .50 ANTIGUA: Reviewed Antigua appeal documents.
07/15/09 W F Stutts, Jr. 1.90 ANTIGUA AND ENGLAND: Continued communications
with England regarding points to be raised in Antiguan appeal.
07/16/09 J A Cialone, II .80 Reviewed UK materials.
07/16/09 R I Howell 6.80 Further work on U.K. grounds of appeal and skeleton argument
for appeal; conference call with U.K. counsel regarding
skeleton argument for appeal; further work on motion to clarify
receivership order.
07/16/09 M S Kontopoulos 3.50 Scanning bundles for Houston office
07/16/09 R T Preston-Jone 3.90 Conferring with Stuart Isaacs QC (barrister) re permission to
appeal and the stay; telephone call to Court of Appeal; email
received from Nabarro attaching letter from Cameron
McKenna; conferring with Nabarro and email to team; email to
Sir Clare re affidavit; discussion as to deponents to affidavit;
preparing draft index to appeal bundle; discussion as to
authorities and the bundle; considering skeleton argument;
preparing bundle.
07/16/09 W F Stutts, Jr. 2.20 ENGLAND: Conference call on England and Antigua appellate
matters; reviewed case law and comparative rules among
jurisdictions and impact of appeal in other jurisdictions.
07/16/09 W F Stutts, Jr. .70 Antigua appeal briefs.
84
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 18 of 377
Page 17
Hours Description
07/17/09 R I Howell .90 Further work on motion to clarify.
07/17/09 M S Kontopoulos 1.60 Scanning bundles and sending to Houston office
07/17/09 R T Preston-Jone 6.10 Receiving sealed orders and finalizing bundle; receiving
Cameron McKenna application to vary criminal freeze;
discussion as to appearance at hearing and perusing evidence
served.
07/17/09 N M Starbuck .90 Provided B. Stutts with Bank of Antigua Account Statements
received from FITS.
07/17/09 W F Stutts, Jr. .40 Ontario application by dynasty and communications from Ms.
Bjorkquist.
07/18/09 W F Stutts, Jr. 1.70 ENGLAND: Reviewed information regarding criminal freeze;
reviewed POCA to develop information as to REDACTED
and the potential impact of the freeze in
different situations.
07/19/09 J A Cialone, II 1.30 Attention to UK freeze order and related calls and emails.
07/19/09 W F Stutts, Jr. .80 Reviewed information and questions related to appellate
documents.
07/20/09 S W Austin .60 Reviewed e-mail message from Bill Stutts regarding sale
REDACTED ; replied.
07/20/09 R I Howell 7.30 Further work on motion to clarify the receivership order.
07/20/09 R T Preston-Jone 5.10 Finalizing and sending bundles to Felicity Toube (barrister);
letter received from Cameron McKenna re Restraint Order
hearing; email to Nabarro; preparing letter to Central Criminal
Court and sending same; researching permission to appeal in
criminal matters; receiving Cameron McKenna's application to
discharge civil freezing order; large number of emails
exchanged re REDACTED civil freeze and appearance/stance to
take.
07/20/09 W F Stutts, Jr. 1.80 Reviewed additional communications regarding developments
in England regarding modification of order and several
communications with Mr. Isaacs, Ms. Toube and Mr. Howell.
07/20/09 W F Stutts, Jr. 1.10 ENGLAND: Further exploration of possible sources of
REDACTED and potential impact REDACTED
.
07/21/09 R I Howell 5.20 Further work on motion to clarify and sent same to U.K.
counsel for comment.
07/21/09 M S Kontopoulos .90 Scanning documents; emails to and from Austin office re court
bundles
85
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 19 of 377
Page 18
Hours Description
07/21/09 R T Preston-Jone 6.90 Preparing letter to Court of Appeal re application for a stay;
attending court to file appeal bundles; attending Chambers of
Felicity Toube (barrister) to revise Appellant's Notice;
preparing letter to Cameron McKenna re civil freeze; serving
appeals on Cameron McKenna and Addleshaws; conferring
with Nabarro and receiving court papers from them; telephone
call from Court of Appeal office and email to Court of Appeal.
07/21/09 W F Stutts, Jr. 1.10 Reviewed information on effect of ruling on discharge of civil
freeze and the basis for the discharge.
07/22/09 R I Howell 3.30 Incorporated U.K. counsel's changes into motion to clarify
receivership order; email correspondence with U.K. counsel
regarding successfully obtaining leave to appeal adverse
Antiguan ruling.
07/22/09 M S Kontopoulos 1.70 Attending Court of Appeal Registry to make amendments to
bundles
07/22/09 R T Preston-Jone 3.80 Receiving Note from Lloyd LJ and circulating; preparing
response; sending Note to Cameron McKenna and
Nabarro/SFO; long chain of emails re Felicity Toube (barrister)
participating in call with DoJ counsel; 2 letters from Cameron
McKenna re civil freeze and criminal freeze discharge apps;
receiving Cameron McKenna letters re stay and their
undertaking; receiving update on Antigua from Stuart Isaacs
QC (barrister).
07/22/09 W F Stutts, Jr. .90 ENGLAND: civil discharge; information in from Court of
Appeals.
07/22/09 W C Watts .40 Reviewed International Banking Corporations Act with respect
to REDACTED
; discussed same with Bill
Stutts.
07/23/09 S W Austin .50 E-mail message from Bill Stutts regarding receivership
REDACTED ; located materials regarding
same; located statutes; sent Stenger materials and statutes
references to Bob Howell per Bill Stutts's request.
07/23/09 R I Howell 1.00 Incorporated additional comments from U.K. counsel into
Motion to Clarify Receivership Order.
07/23/09 M S Kontopoulos .40 Scanning and sending documents to Austin office
07/23/09 R T Preston-Jone 2.80 Preparing updates to Court of Appeal bundles and conferring
with paralegal; reviewing redraft of letter to Lloyd LJ;
receiving bundle of legislation for use in court and sending to
Felicity Toube (barrister).
86
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 20 of 377
Page 19
Hours Description
07/23/09 W F Stutts, Jr. 1.90 ANTIGUA information on court of appeal and preparation for
hearing and status information.
07/24/09 J A Cialone, II .80 Reviewed memo and related materials on UK litigation, and
considered Receiver's options.
07/24/09 R I Howell 2.50 Finalized proposed motion for reconsideration; reviewed
correspondence from Canadian counsel regarding AMF
intervention; email correspondence with U.K. counsel
regarding REDACTED .
07/24/09 R T Preston-Jone 7.50 Preparing for and appearing at Central Criminal Court;
appearing at Freezing Order hearing; conferring with Felicity
Toube (barrister); finalizing and sending letter to the Court of
Appeal replying to Lord Justice Lloyd.
07/24/09 W F Stutts, Jr. 2.90 ENGLAND AND ANTIGUA: Reviewed reports from England
regarding England and Antigua and timing, relationships,
different issues presented.
07/27/09 R I Howell 3.50 Telephone with Jack DeKluiver regarding info needed to get
Stanford served with Canadian suit papers; commented on
proposed court filings from UK counsel; conference call with
UK counsel regarding various topics, including status of UK
and Antiguan proceedings; conference call with UK counsel
and Antiguan counsel regarding procedural deadlines in
Antiguan appeal.
07/27/09 M S Kontopoulos 1.10 Liaising with Court of Appeal registry and preparing
documentation and amended index for updating/paginating
bundle tomorrow
07/27/09 R T Preston-Jone 7.40 Preparing for and appearing at Central Criminal Court,
receiving 2 affidavits from Cameron McKenna and considering
same; preparing letter to Cameron McKenna; participating in
conference call; dealing with 2 letters from Court of Appeal
and conferring with paralegal.
REDACTED
07/27/09 W F Stutts, Jr. 1.80 ENGLAND: Analyzed the effect of
by the Antiguan appointed
liquidators.
07/27/09 W F Stutts, Jr. .80 CANADA: Reviewed information on service related to Quebec
materials and telephone conferences with Mr. Howell related to
the same; reviewed inquiries from Mr. Hendy's office
regarding same.
07/28/09 R I Howell 1.50 Reviewed materials filed by SFO in the U.K. criminal restraint
case; reviewed report from Felicity Toube regarding that
proceeding; compiled Quebec materials and instructed
secretary to mail them to Stanford in Conroe detention center.
87
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 21 of 377
Page 20
Hours Description
07/28/09 M S Kontopoulos 6.50 Attending court to paginate bundles
07/28/09 R T Preston-Jone 7.30 Attending court at Old Bailey; reviewing emails relating to
further evidence used by DoJ in criminal case; conferring with
Felicity Toube (barrister) re Antiguans' claims
REDACTED and preparing letter to
Cameron McKenna; finalizing and sending letter to Court of
Appeal; preparing forms for Court of Appeal.
07/28/09 W F Stutts, Jr. .90 Telephone conferences with CKR regarding REDACTED
worked on same and related points.
07/28/09 W F Stutts, Jr. 2.60 ENGLAND criminal freeze hearing and Howell and Toube and
Preston Jones.
07/29/09 R I Howell .70 Email correspondence regarding potential meeting with SEC
and DOJ regarding foreign assets; reviewed correspondence
and court filings concerning UK proceedings.
07/29/09 M S Kontopoulos 3.10 Attending Court of Appeal to replace index in bundles;
pagination of duplicate bundle
07/29/09 R T Preston-Jone 4.70 Preparing for and attending at judgment hearing in Old Bailey;
letter received from Cameron McKenna and conferring with
Felicity Toube (barrister); email to Cameron McKenna; email
received from Court of Appeal; preparing and sending letter to
Court of Appeal re Stay; email received from Cameron
McKenna re Stay; perusing emails from Stuart Isaacs QC
(barrister) and Sir Clare re Antigua; conferring with paralegal
re bundles.
07/30/09 R I Howell 2.70 Reviewed SFO appeal documents; revised report to Ralph
Janvey.
07/30/09 R T Preston-Jone 8.80 Considering letter received from Cameron McKenna re 6 April
application in Antigua; conferring with Stuart Isaacs QC
(barrister) by email; email to Sir Clare; letter received from
Cameron McKenna re expedited criminal appeal; telephone
call from Court of Appeal confirming urgent hearing for
directions tomorrow; conferring with Stuart Isaacs QC
(barrister); urgent preparation of bundle for use in court; travel
to chambers of Stuart Isaacs QC (barrister) for short
consultation as regards tomorrow.
07/30/09 W F Stutts, Jr. 2.90 Questions regarding filing of recognition applications in
Antigua; related questions for appeals; SFO position in
England and English appeal; several communications with Mr.
Howell regarding the issues.
07/31/09 R I Howell .70 Reviewed correspondence from UK lawyers regarding hearing
outcome and proposed order; reviewed correspondence from
88
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 22 of 377
Page 21
Hours Description
Canadian counsel and located requested exhibits; reviewed
correspondence regarding hearing in Dallas and comment made
regarding foreign proceedings.
07/31/09 M S Kontopoulos 1.00 Delivering bundle of documents to court of appeal
07/31/09 R T Preston-Jone 6.50 Preparing for and attending Court of Appeal hearing; preparing
further bundles for Court of Appeal; preparing letter to
Cameron McKenna re recognition Application; receiving
Criminal Appeal notice.
07/31/09 W F Stutts, Jr. .80 Effect of statements: Received information from US
REDACTED
trial team describing remarks of Ms. Romero in court and
REDACTED
; several communications with Mr. Howell on
same.
08/02/09 W F Stutts, Jr. 3.30 Reviewed information and commentary related to impact of
proceedings of 7/31 on non-US proceedings in general; related
finalization of memo to Ralph Janvey regarding status and
developments; several communications with Mr. Howell and
Mr. Durst on same.
08/03/09 R I Howell 3.60 Revised update to Ralph Janvey on foreign proceedings,
reviewed transcript of hearing; worked with Bill Stutts on
script for Cialone's call to DOJ; reviewed correspondence from
UK attorneys.
08/05/09 W F Stutts, Jr. .90 Participated in several communications with Mr. Janvey and
Mr. Cialone regarding meetings and ways forward in light of
REDACTED .
08/18/09 W F Stutts, Jr. 3.90 Worked on presentation and summary and outline for Mr.
Janvey for meeting August 19 and compared and obtained
information on bank accounts and harmonized same.
08/19/09 W F Stutts, Jr. 4.30 Prepared for and participated in meeting with Department of
Justice and SEC personnel; several communications with
counsel; preparation and review of information from banking
information and other statements.
08/23/09 W F Stutts, Jr. 2.20 Reviewed information and prepared report on accruals and
related information.
REDACTED
08/23/09 R H Wood 4.10 Researched ;
researched U.S. civil and criminal forfeiture law; researched
receiver standing issues; researched relevant case-law
REDACTED
.
08/24/09 R H Wood 3.50 Continued to research relevant law regarding
REDACTED ; spoke with M. Wood regarding the
89
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 23 of 377
Page 22
Hours Description
issue and discovered cases REDACTED
; wrote an outline of important cases and citations
for memo.
REDACTED
08/26/09 R H Wood 1.90 Researched civil forfeiture
clause.
08/28/09 R H Wood 1.20 Researched issues surrounding REDACTED
; communicated with B. Stutts regarding the
same.
Matter Total 661.00
079716.0103 Aviation Matters
Hours Description
REDACTED
06/01/09 S W Austin 1.80 Replied to Malcolm Lovett regarding and
insurance; continued review and mark-up of Voluntary
Surrender Agreement adding REDACTED ; revised
Used Aircraft Special Warranty Conveyance.
06/02/09 S W Austin 4.90 Finalized Bill of Sale form and sent to Weil; reviewed
Settlement Agreement; sent e-mail message regarding
problematic provisions to Kevin Sadler; arranged for call with
Weil to discuss points; sent e-mail message to Doug Hubener
regarding projected aircraft delivery; replied to Harrison
Tucker regarding Comerica Bank counsel's contact; sent e-mail
message to Craig Adams regarding wire transfer instructions
for settlement amount; replied to Jeannette Day and Craig
Tucker regarding same; commenced mark-up of Settlement
Agreement.
06/03/09 S W Austin 4.90 Continued mark-up of Settlement Agreement and circulated to
Kevin Sadler, Bill Stutts, Richard Husseini, and Renn Neilson
for input; replied to Kevin Sadler's question regarding
REDACTED ; e-mail message from Jeannette Day regarding GE
invoices regarding aircraft loans and replied; analyzed potential
liens and sent to Kevin Sadler; sent e-mail message to Craig
Adams regarding REDACTED , e-
mail message from Kevin Sadler regarding judicial sale and
liens.
06/03/09 R A Husseini .80 Attention to aircraft settlement agreement.
06/03/09 W F Stutts, Jr. .20 Briefly reviewed current settlement agreement form.
06/03/09 J J Wellington 1.60 Settlement Agreement - review and comments.
06/04/09 S W Austin 6.30 Replied to Kevin Sadler regarding REDACTED
motion
and order; replied to Fred Fram regarding description of
90
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 24 of 377
Page 23
Hours Description
Hawker Siddeley for insurance; compiled all three aircraft
broker bids and estimates of value; drafted e-mail message to
Malcolm Lovett outlining the three alternatives; revised aircraft
brokerage agreement; telephone consultation with and e-mail
messages with Jay Madrid regarding Comerica Bank letters of
credit and notice of non-renewal; sent e-mail message to Kevin
Sadler summarizing contacts with Jay Madrid; sent e-mail
message to Jay Madrid requesting information on other
charges; telephone consultation with Weil regarding non-
renewal notice; telephone consultation with Harry Driscoll
regarding brokerage arrangement and hangaring aircraft at
Spring, Texas and insurance; sent e-mail message to Malcolm
Lovett and Fred Fram summarizing call with Harry Driscoll;
reviewed e-mail message from Kevin Sadler regarding cutting
off liens; sent aircraft broker recommendation to Malcolm
Lovett; reviewed Stipulation forwarded by Jay Madrid;
forwarded and sent comments to Kevin Sadler; request
information internally on Comerica Bank CD's; sent summary
to Kevin Sadler regarding REDACTED ;
replied to Renn Neilson's questions regarding tax issues in
Weil's draft Settlement Agreement; continued revisions to
voluntary surrender agreement.
06/04/09 J J Wellington .90 Settlement Agreement - review and comments.
06/05/09 S W Austin 6.00 Reviewed Motion and Order draft from Margaret Allen at Weil
and circulated to Kevin Sadler et al; replied to Renn Neilson
regarding his tax questions; telephone consultation with Renn
Neilson regarding same and regarding need for resale
certificate; sent e-mail message to Weil regarding same; sent e-
mail message to Bill Stutts regarding bankruptcy indemnity;
telephone consultation with Kevin Sadler regarding
REDACTED ; sent e-mail
message to Jay Madrid confirming no objection to notice of
non-renewal; sent e-mail message to Weil regarding need for
resale certificate and for call between Anthony DeVito and
Renn Neilson; several e-mail messages from Weil regarding
same; requested Renn Neilson to prepare mark-up of
Settlement Agreement with his tax comments; office
consultation with Bill Stutts regarding bankruptcy indemnity;
drafted bankruptcy blow-up provision and circulated to Bill
Stutts; reviewed comments to tax section from Jon Wellington;
revised Settlement Agreement; incorporated tax comments;
circulated to Michelle Hartmann and Margaret Allen and to
Kevin Sadler, Richard Husseini, Renn Neilson and Bill Stutts.
06/05/09 J J Wellington 5.10 Review of Settlement Agreement and proposed changes
relating to tax terms.
91
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 25 of 377
Page 24
Hours Description
06/06/09 S W Austin .10 Replied to Kevin Sadler regarding Weil Motion and Order.
06/07/09 S W Austin .10 Considered additional changes need in Stipulation with
Comerica Bank.
06/08/09 C N Adams 1.10 Telephone conference with broker regarding sale of aircraft
equipment; correspondence with Malcolm Lovett regarding
same.
06/08/09 S W Austin 4.10 Voice mail from Jay Madrid regarding Comerica Bank LOC's;
sent e-mail message to Kevin Sadler regarding same and
regarding REDACTED ;
circulated newest draft Settlement Agreement; sent e-mail
message to Katherine Hinton and Sue Ayers regarding lien
release demands; sent e-mail message to Craig Adams
regarding no bankruptcy indemnity; reviewed latest draft
Settlement Agreement and sent summary of open points to
Kevin Sadler; circulated Settlement Agreement to tax lawyers;
sent e-mail message to Tracy Perez regarding aviation subs as
Delaware LLCs; located lien release demands and sent to Sue
Ayers; continued revisions to voluntary surrender agreement
and sent to tax lawyers; e-mail message exchanges with Tracy
Perez regarding LLC status; replied to Craig Adams regarding
surviving obligations; revised Tomball Jet Center brokerage
agreement and sent to Harry Driscoll; sent e-mail message to
Weil scheduling call on open points.
06/08/09 R A Husseini .30 Attention to aviation settlement agreement.
06/08/09 J J Wellington 3.10 Review of voluntary surrender agreement and opposing
counsel's changes to the settlement agreement.
06/09/09 S W Austin 6.40 Finalized aircraft delivery receipt and voluntary surrender
agreement and trip lease; circulated to Weil; sent e-mail
message to Craig Adams regarding REDACTED
; numerous e-mail messages with Doug
Hubener regarding timing of aircraft delivery, operational
control after surrender, navigation database download; Canal
Air, LLC, anticipated aircraft delivery date, last work done;
telephone consultation with Michelle Hartmann and Margaret
Allen regarding final Settlement Agreement points; sent e-mail
message to John Greer regarding REDACTED
and need for it ; circulated to Kevin Sadler; sent e-mail
REDACTED
message to Sabine Casseus regarding appraisal confidentiality
agreements; telephone consultation with Kevin Sadler and
David Arlington regarding joint submission and two
declarations with appraisals; replied to Malcolm Lovett
regarding insurance; sent insurance extension information to
Kevin Sadler; provided input by e-mail message to Michelle
92
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 26 of 377
Page 25
Hours Description
Hartmann and Margaret Allen by e-mail message on open
points in Settlement Agreement; forwarded to Kevin Sadler;
sent additional limitation on lien obligation to Weil; gave input
to David Arlington on Motion and Order draft of Weil; e-mail
message from Weil regarding offer to split insurance cost; sent
e-mail message to Kevin Sadler regarding same; sent e-mail
message to Malcolm Lovett and John Greer requesting
insurance premium information.
06/10/09 S W Austin 6.40 Reviewed Kevin Sadler's reply to litigator team regarding
Stanford attorney's request for aircraft information; sent e-mail
message to same regarding amount of cash collateral; located
and forwarded all aircraft appraisals to Marisa Hurd et al;
reviewed latest draft Settlement Agreement; coordinated call
with Weil for discussion of litigation plan and pleadings; sent
e-mail message to Doug Hubener regarding anticipated aircraft
delivery dates; revised and forwarded aircraft brokerage
agreement to Harry Driscoll; requested Sue Ayers follow-up
regarding lien demand releases; office consultation with Cherie
Painter, President of Tomball Jet Center and Harry Driscoll
regarding contract; revised contract further based on discussion
and circulated to Ms. Painter and Harry Driscoll; e-mail
message to Weil regarding inaccurate blackline; forwarded
settlement agreement to Jon Wellington regarding question
about Canal serving as VFS agent and impact on resale
certificates; numerous emails with Jon Wellington and Renn
Neilson on this issue; replied to David Arlington regarding
information for Receiver Declaration filing; circulated
appraisals to David Arlington; conference call with Kevin
Sadler, David Arlington, Michelle Hartmann, and Margaret
Allen regarding litigation plan and pleadings; sent e-mail
message to Malcolm Lovett requesting data regarding costs of
maintaining aircraft and leaving aviation dept in place;
requested resale certificate from Weil.
06/10/09 J J Wellington 2.50 Analysis of agency issue as it relates to resale certificates;
review of Settlement Agreement.
06/11/09 S W Austin 6.50 Replied to Craig Adams regarding timing on final settlement
agreement to receiver; sent several e-mail messages to Jon
Wellington regarding REDACTED
; sent e-mail message to Malcolm Lovett regarding
insurance requirements and lender's's request and regarding the
6th aircraft; circulated payoff letters to David Arlington
regarding REDACTED ; forwarded recent
information received from appraiser to David Arlington;
requested resale certificates again; reviewed AIG insurance
93
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 27 of 377
Page 26
Hours Description
quotation; sent comments to Malcolm Lovett; locate and sent
receiver personal property sale statute to Margaret Allen;
replied to Margaret Allen regarding form of resale certificate;
reviewed and marked-up latest draft Settlement Agreement and
sent to Michelle Hartmann and Margaret Allen; sent e-mail
message to Doug Hubener regarding 6th aircraft and Tomball
Jet Center; replied to Renn Neilson regarding action of Canal
as agent; reviewed Renn Neilson's e-mail message; replied to
David Arlington regarding statute; reviewed and circulated
aviation dept data to David Arlington and Kevin Sadler
prepared by FTI.
06/11/09 J J Wellington 2.80 Analysis of agency issue REDACTED ;
review of Settlement Agreement.
06/12/09 S W Austin 5.20 Office consultation with Weil regarding change in structure,
regarding no voluntary surrender to Canal Air; sent e-mail
message to Renn Neilson regarding same; circulated latest
revised Settlement Agreement; reviewed; sent e-mail message
to Kevin Sadler and David Arlington regarding latest
developments; reviewed 2d turn of Settlement Agreement
today from Weil; circulated to tax lawyers; reviewed comment
from Jon Wellington; replied to Weil regarding IDERA;
reviewed newest premium quote; circulate it to Margaret Allen;
attention to confidentiality agreement in VFS appraisal;
telephone consultation with Malcolm Lovett regarding
insurance premium payment arrangement; e-mail message
from him confirming arrangement; gathered information for
Receiver's Declaration; circulated to David Arlington;
commence preparation of outline of secured debt calculation
and aircraft valuation; drafted e-memo to David Arlington
regarding same.
06/12/09 J J Wellington 1.30 Analysis of agency issue REDACTED ;
review of Settlement Agreement.
06/13/09 S W Austin 7.80 Reviewed e-mail message from Margaret Allen regarding
agreement to pay insurance and forwarded lien releases to
Kevin Sadler and David Arlington; reviewed e-mail message
from Margaret Allen regarding her research into standard for
review and other questions regarding process; numerous e-mail
messages with Kevin Sadler and David Arlington regarding
REDACTED and court approval and
treatment of REDACTED ; continued work on, and finalized
aircraft valuations for Janvey Declaration and forwarded to
Kevin Sadler and David Arlington; completed secured debt
calculation and circulated to David Arlington; reviewed latest
turn of Settlement Agreement, revised, and circulated to
Michelle Hartmann and Margaret Allen at Weil; revised
94
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 28 of 377
Page 27
Hours Description
Aircraft Delivery Receipt regarding no Canal involvement and
circulated to Weil; revised Used Aircraft Sale Conveyance and
circulated to Weil; sent e-mail message to Jon Wellington
regarding question on addresses for resale certificates.
06/14/09 S W Austin 6.80 Reviewed draft Janvey Declaration, Joint Submission,
Stipulation, and Affidavit of GE representative; sent e-memo of
overall comments to David Arlington and Kevin Sadler;
reviewed latest turn of Settlement Agreement and sent
conditional approval to Weil; reviewed revised Used Aircraft
Conveyance and revised; prepared draft rationale on Used
Aircraft Conveyance mark-up; marked up and sent comments
to David Arlington on Joint Submission, Stipulation, and
Janvey Declaration.
06/15/09 S W Austin 8.80 Replied to Kevin Sadler regarding owner of aviation subs;
replied to Margaret Allen regarding status of various exhibits;
finalized comments to bill of sale and circulated to Margaret
Allen and Michelle Hartmann with commentary; forwarded
address information for certificates to Margaret Allen;
reviewed latest draft pleadings circulated by Weil and sent
comments to Kevin Sadler and David Arlington; sent e-mail
messages to Jon Wellington regarding review of resale
certificates; sent e-mail message to Sue Ayers regarding fuel
liens; reviewed her reply and replied; sent e-mail message
regarding alternative strategies for addressing fuel liens to
Kevin Sadler et al; reviewed GE resolution; reviewed VFS lien
releases and sent comments to Margaret Allen; reviewed latest
Joint Submission and other pleadings and sent mark-ups to
David Arlington; replied to Kevin Sadler regarding
Declaration; worked on getting final Settlement Agreement and
all exhibits final for presentation to Receiver; sent e-mail
message to Jay Madrid to arrange a call; telephone consultation
with Jay Madrid regarding settlement with VFS and Comerica
Letters of Credit; reviewed newest turn of Settlement
Agreement; forwarded resale certificates to Jon Wellington for
review; reviewed particulars of same; raised issue of VFS's
address with Margaret Allen; reviewed next round of changes
to Stipulation; sent comment regarding lien language to Kevin
Sadler and David Arlington; e-mail message to Margaret Allen
regarding not signing or dating resale certificates; report on call
with Jay Madrid to Kevin Sadler and David Arlington; revised
Jay Madrid's Stipulation and sent to David Arlington and
Kevin Sadler.
06/15/09 J J Wellington 2.30 Review of resale certificate issues; discussions with
Comptroller's's Office regarding VFS status.
95
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 29 of 377
Page 28
Hours Description
06/16/09 S W Austin .10 Replied to Margaret Allen's's e-mail message and requested
feedback from aircraft title counsel and blackline of Settlement
Agreement.
06/17/09 S W Austin 2.90 Numerous emails regarding timing and expedition of motion
with David Arlington and impact of court's order regarding
responses deadline; office consultation with Kevin Sadler
regarding Reuters requested interview; to Kristie Blumenschein
regarding same; telephone consultation with J. Gilbennus at
Piercom regarding interview prepared for interview; located
court filing and all background information for Piercom and
forwarded to J. Gilbennus; participated in interview.
06/18/09 S W Austin .50 E-mail message to Weil regarding responsibility for drafting
bills of sale and aircraft delivery receipt; sent e-mail message
to Doug Hubener regarding court's ruling expediting responses
and regarding timetable for aircraft delivery; reviewed
Stipulation sent to Comerica counsel; sent questions to Kevin
Sadler and David Arlington regarding same.
06/19/09 S W Austin .80 Reviewed Comerica Stipulation revisions from Jay Madrid and
Release.
06/22/09 S W Austin 6.60 Prepared mark-up of Comerica Stipulation and Release and
circulated to David Arlington and Kevin Sadler; drafted all
Bills of Sale and Aircraft Delivery Receipts and forwarded
drafts to Weil; reviewed title memoranda to confirm
descriptions; prepared blacklines of all drafts and circulated to
Weil; e-mail message from Margaret Allen at Weil regarding
advance access to aircraft; sent e-mail message to Kevin Sadler
regarding same with recommendation; outlined ground rules
for prior access; sent e-mail message to Kevin Sadler and
David Arlington regarding whether any responses were filed;
input from David Arlington on Comerica Stipulation and
Release; revised further and circulated to Jay Madrid.
06/23/09 S W Austin 6.40 E-mail message to Kevin Sadler regarding status of objections
to aircraft deal; sent e-mail message to Doug Hubener outlining
ground rules for VFS access, id's and credentials required;
replied to Doug Hubener's question and request for successive
departures; sent email to Margaret Allen at Weil regarding
ground rules for access and regarding credentials and role of
each person with access; e-mail message from Jay Madrid
approve revised Stipulation and Release; arranged for
execution; e-mail message to Sue Ayers regarding same;
telephone consultation with Kevin Sadler regarding objection;
responded to Sue Ayers' questions; sent email to Brenda Cobb
and Becki Wichert, Stanford's administrator on International
Registry regarding closing this week and any requirements;
96
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 30 of 377
Page 29
Hours Description
forwarded signed and filed Stipulation to Jay Madrid; sent e-
mail message to Jeanette Day confirming wire transfer
instructions; reviewed revised Order with revisions made by
Court; telephone consultation with Kevin Sadler regarding
same; replied to Weil our approval reviewed Response and
Objection filed by RAS attorneys; sent e-mail message to
Jeanette Day regarding interest to be sent by Comerica Bank;
telephone consultation with Margaret Allen regarding
Objection by RAS; sent e-mail message to Kevin Sadler et al
regarding the RAS Objection and our position.
06/23/09 S A D Ayers .20 Filed stipulation regarding letters of credit;
06/24/09 S W Austin 7.30 Replied to Jeannette Day and Craig Adams regarding RAS
Objection just filed and delay in wires receipt; sent e-mail
message to Bob Howell regarding point raised in Objection;
replied to Kevin Sadler REDACTED ;
telephone consultation with Michelle Hartmann and Margaret
Allen regarding approval by Court and closing matters;
circulated approval signed by Court to Kevin Sadler and David
Arlington; sent e-mail message to Jay Madrid forwarding
Order and alerting Comerica Bank about VFS pulling LOC's;
sent e-mail message to Bob Howell regarding court approval;
replied to Becki Wichert at IATS regarding missing IR
Authorization; forwarded Joint Submission and Court Order to
Becki Wichert; sent e-mail message to Doug Hubener
regarding court approval and closing this week; sent wire
transfer instructions to Comerica Bank's's counsel, Jay Madrid;
e-mail message to Kevin Sadler about REDACTED ; sent
e-mail message with wire transfer instructions for Escrow
Agreement; sent e-mail message to Doug Hubener with copies
of Conveyances showing what is being conveyed; telephone
consultation with Malcolm Lovett regarding brokerage
agreement on 6th aircraft; sent e-mail message to Craig Adams
regarding whether brokerage agreement needs court approval;
reviewed aircraft title counsel's comments to Conveyances;
arranged for incorporation of changes; reviewed drafts;
prepared execution originals of Conveyances; telephone
consultation with Amy Rhodes and Margaret Allen regarding
closing; forwarded title memoranda to Amy Rhodes; sent
Dennis Blackburn's name to Doug Hubener; forwarded Doug
Hubener's contact information to VFS; prepared transmittal
escrow letter to accompany signed conveyances; sent e-mail
message to Sue Ayers regarding discrepancy in case style;
reviewed her response; replied to Doug Hubener's questions;
circulated execution Conveyances to Kristie Blumenschein
with transmittal letter and execution instructions; telephone
consultation with Amy Rhodes and Mark Peregrin regarding
97
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 31 of 377
Page 30
Hours Description
proper Honeywell engine description; telephone consultation
with Margaret Allen regarding closing matters and pink copies;
revised Conveyances to correct engine descriptions; reviewed
and revised Escrow Agreement and circulated to Margaret
Allen and Michelle Hartmann.
06/24/09 J A Cialone, II .80 Reviewed documents on aircraft settlement.
06/25/09 S W Austin 8.20 Sent replacement pages to aircraft title counsel for two
Conveyances with corrected engine descriptions; sent e-mail
message to Jeanette Day regarding whether interest from
Comerica Bank received; sent e-mail message to Jay Madrid
about Receiver wire not received; sent e-mail message to Sue
Ayers regarding mechanics liens to be released; replied to Sue
Ayers questions regarding same; sent pilot list to Doug
Hubener; reviewed response and addressed his questions;
forwarded aircraft and lien descriptions to Sue Ayers; revised
aircraft delivery receipts and sent blacklines to Margaret Allen;
e-mail message to Doug Hubener regarding capability to
receive and sign aircraft delivery receipts at closing; reviewed
aircraft title counsels changes to Escrow Agreement; telephone
consultation with Margaret Allen regarding same; telephone
consultation with Margaret Allen, and Mark Peregrin, escrow
agent regarding changes; reviewed his signature page;
forwarded Jay Madrid's reply with amount of Comerica wire to
Jeanette Day; reviewed International Registry authorizations
and sent comments to Becky Wichert; requested VFS's
signature page; forwarded IR authorizations corrections to
Becki Wichert; replied to Doug Hubener regarding pink slips
and closing timing; prepared execution originals and
instructions to Kristie Blumenschein for execution of Escrow
Agreement and IR Authorizations; reviewed status updates
from Doug Hubener regarding VFSs representative's's
inspection of the aircraft; e-mail message to Margaret Allen
regarding timing of pre-closing call; sent e-mail message to
Doug Hubener regarding Aircraft Delivery Receipts; sent e-
mail message to Renn Neilson regarding GE's proposal for
signing aircraft delivery receipts Allen; reviewed response; sent
e-mail message to Margaret Allen regarding same; confirmed
funds received in escrow and notified Kevin Sadler et al; sent
Stanford hangar address to Margaret Allen; replied to Renn
Neilson and outlined signing process; reviewed newest title run
showing lien releases and forwarded to Sue Ayers; sent
replacement pilot name to Doug Hubener and reviewed his
response; continued review of lien releases and other
documents to be in escrow; alert Doug Hubener to two
overnight packages; circulated aircraft delivery receipts for
execution.
98
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 32 of 377
Page 31
Hours Description
06/25/09 J J Wellington .80 Finalizing sales tax matters relating to VFS aircraft acquisition.
06/26/09 S W Austin 4.50 E-mail message regarding preparation of blacklined Aircraft
Delivery Receipts; sent e-mail message to Kristie
Blumenschein regarding signing and dated IR Authorizations
and sending by pdf; requested confirmation of my authority to
release Conveyances in closing call; reviewed confirmation
received from Ralph Janvey; sent e-mail message to Jeanette
Day regarding anticipated wire receipt today and need
confirmation during closing call; requested copies of all
documents in escrow from escrow agent; reviewed same; sent
e-mail message to Doug Hubener regarding RAS personal
effects; circulated Escrow Agreement signature page from
Receiver to Margaret Allen and Michelle Hartmann; circulated
signed IR Authorizations to Becki Wichert at IATS; sent e-mail
message to Doug Hubener regarding whether parts and pink
copies received and pilots showed; requested copies of
escrowed Aircraft Delivery Receipts for review; telephone
consultation with Michelle Hartmann and Margaret Allen
regarding readiness to close; e-mail message to Margaret Allen
regarding fueling request and fuel receipts; participated in
closing conference call; circulated reviewed Hawker aircraft
delivery receipts with corrected engine description and
received copies of newly signed ones; confirmed wire received
by Receiver; notified Doug Hubener that wire received;
attention to resale certificates; sent e-mail message to Jeanette
Day and Bill Stutts regarding risk management policies;
reviewed replies; sent e-mail message to Doug Hubener
confirming possession and title transfer and regarding no more
restriction of access to aircraft; sent e-mail message to Kevin
Sadler et al regarding closing completed; several e-mail
messages with Doug Hubener regarding Global Express
grounding due to routine electrical issue; sent e-mail message
to Kevin Sadler regarding same; telephone consultation with
Harry Driscoll regarding brokerage agreement for 7th aircraft;
sent e-mail message to Houston Executive Air with questions
regarding hangar arrangements; sent e-mail message to
Malcolm Lovett regarding Houston Executive Airport;
received fuel receipts.
06/29/09 S W Austin .10 Replied to Jeannette Day regarding sales taxes.
06/30/09 S A D Ayers .50 Telephone conference with Solapp Aviation regarding liens.
07/03/09 S W Austin .10 Replied to Sue Ayers regarding REDACTED
.
07/07/09 S W Austin 1.90 Revised Brokerage Agreement form provided by Harry
Driscoll; forwarded comments to Harry Driscoll; forwarded
99
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 33 of 377
Page 32
Hours Description
terms of payment at Houston Executive Airport to Malcolm
Lovett with questions; reviewed his reply.
07/08/09 S W Austin .70 Replied to Harry Driscoll regarding brokerage agreement
execution; draft transmittal letter to Kristie Blumenschein with
other aircraft documents, including registrations; replied to
Jeanette Day's e-mail message regarding her request for copies
of V FS settlement agreement and bills of sale; considered
Jeanette Day's question regarding insurance premium refund;
replied regarding VFS's payment at closing.
07/09/09 S W Austin .90 Compiled certain closing documents to send to Jeanette Day.
07/09/09 S W Austin .80 Prepared description for information to court and Mr. Janvey.
07/10/09 S W Austin 3.80 Replied to Doug Hubener regarding movement of Hawker
Siddeley; telephone consultation with Andrew Perry at
Houston Executive Airport regarding rental amount and other
issues; compiled information on Solapp Aviation lien and send
to Wes Watts, together with title memoranda, with instructions
for drafting Release of Lien; reviewed precedential hangar
leases; forwarded demand letter sent to Solapp to Wes Watts;
sent e-mail message to Jay Madrid regarding exchange of
release; reviewed insurance application forwarded by Andrew
Perry; requested HEAS's insurance certificate from Andrew
Perry ; continues revisions to letter agreement; forwarded
drafting letter agreement to Andrew Perry; sent e-mail message
to Harry Driscoll regarding signed brokerage agreement.
07/10/09 W C Watts .50 Reviewed Solapp demand letter and began drafting release of
lien.
07/13/09 S W Austin .70 Sent e-mail message to Doug Hubener regarding Harry
Driscoll as broker for Hawker Siddeley and regarding his
access to aircraft; replied to Harry Driscoll regarding same and
regarding Amstat and JetNet marketing services; sent e-mail
messages to Amstat and JetNet confirming Driscoll as broker;
sent e-mail message to Wes Watts regarding Duncan, Solapp,
and World Fuel aircraft liens.
07/13/09 S A D Ayers .50 Reviewed draft release of lien for service on Solapp aviation.
07/13/09 J A Cialone, II .80 Attention to airplane hangar personnel and asset issues.
07/13/09 W C Watts 6.50 Reviewed liens filed against Stanford aircraft and tied each of
them to corresponding releases; drafted releases for those liens
that were not released previously.
07/14/09 S W Austin 1.20 Replied regarding Solapp Release; e-mail message exchange
with Jeanette Day regarding hangar space; sent e-mail message
regarding Solapp release of lien filing; reviewed and revised
100
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 34 of 377
Page 33
Hours Description
draft World Fuel Disclaimer; requested copy of form of
Release of Lien World Fuel used for recorded liens; prepared
transmittal to Mark Peregrin requesting approval of form.
07/14/09 S A D Ayers .50 Communicating with Solapp Aviation regarding lien release.
07/15/09 S W Austin 2.40 E-mail message from Kevin Sadler regarding REDACTED
; sent e-mail message to Doug Hubener
regarding same; reviewed Mark Peregrin's reply regarding
REDACTED ; sent
questions and reviewed his reply and changes to Disclaimer;
reviewed form of hangar agreement sent by Andrew Perry of
Houston Executive Aircraft; telephone consultation with
Andrew Perry regarding same; revised our form letter
confirmation of rental terms; reviewed Andrew Perry's e-mail
message confirming rental terms and prepared reply.
07/15/09 S W Austin 1.00 Reviewed Motion and gave input to Sue Ayers; prepared mark-
up.
07/16/09 S W Austin 1.90 Replied to Doug Hubener regarding aircraft acquisition dates
and to his amendment e-mail message; forward aircraft
acquisition dates to Kevin Sadler; replied to Andrew Perry of
Houston Executive Airport regarding his confirmation of rental
details; telephone consultation with Malcolm Lovett regarding
next steps for moving last aircraft; sent e-mail message
regarding engines runs to Malcolm Lovett; e-mail message
exchanges with Jeanette Day regarding check for hangar rental;
forwarded changes to World Fuel disclaimer form sent by
VFS's aircraft title counsel; forwarded to Wes Watts and
requested he send to World Fuel's counsel with request to sign
and file.
07/16/09 W C Watts .40 Drafted Release and Disclaimer.
07/17/09 S W Austin .20 Replied to Malcolm Lovett and Jeanette Day regarding engine
runs and taxiing operations for aircraft to be hangared at
Houston Executive Airport.
07/17/09 W C Watts .70 Drafted Release and Disclaimer; prepared documents to be
included to World Fuel Services' counsel.
07/20/09 S W Austin .80 Reviewed letter from Honeywell regarding maintenance
contracts default; circulated to Kevin Sadler and Bill Stutts;
replied to Doug Hubener regarding same.
07/21/09 S W Austin .40 E-mail message to Harry Driscoll regarding Power by the
Hour; briefly reviewed Power by Hour materials forwarded by
Jeanette Day.
07/22/09 S W Austin 1.80 Reviewed provisions of settlement agreement regarding
101
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 35 of 377
Page 34
Hours Description
Honeywell maintenance contracts; prepared draft e-mail
message to Honeywell for Kevin's review; forwarded analysis
and draft e-mail message to Kevin Sadler and Bill Stutts; sent
e-mail message to Margaret Allen requesting canceled notes.
07/23/09 S W Austin .10 E-mail message to Doug Hubener regarding relocation of
Hawker Siddeley.
07/24/09 S W Austin .20 Sent e-mail message to Jeanette Day regarding relocation to
Houston Executive Airport; sent e-mail message to Andrew
Perry at Airport regarding postponed relocation of Hawker
Siddeley and contact information.
08/01/09 S W Austin .10 Replied to Bill Stutts regarding Antiguan aviation employee.
08/02/09 W F Stutts, Jr. .30 Reviewed information from Ms. Austin regarding aviation
employees in Antigua and communication of same to Mr.
Lovett.
08/03/09 S W Austin .20 Reviewed e-mail message from Bill Stutts; sent questions and
comments to Bill Stutts regarding Antiguan hangar and
employee
08/03/09 J A Cialone, II .40 Attention to aviation issues.
08/04/09 S W Austin .30 Reviewed e-mail message from Margaret Allen regarding
status of liens; replied to Margaret Allen regarding same; sent
e-mail message to Wes Watts regarding contact with World
Fuel counsel.
08/06/09 S W Austin 1.70 E-mail message to Andrew Perry regarding repositioning
Hawker Siddeley next week; reviewed his response; numerous
emails to Jeanette Day, Harry Driscoll, Doug Hubener
regarding best place for log books and spare parts and whether
spare parts will increase value of sale.
08/07/09 S W Austin .40 Sent e-mail message to Mark Peregrin regarding lien releases;
e-mail message exchanges with Doug Hubener regarding pilots
for repositioning flights; sent e-mail message to Andy Perry
regarding availability of storage space for spare parts and
logbooks.
08/10/09 S W Austin 1.70 Attention to repositioning Hawker Siddeley from Sugar Land
to Houston Executive Airport; numerous emails to Andrew
Perry and Scott Andre at HEA and to Jeanette Day, Doug
Hubener and Harry Driscoll regarding timing, regarding access
list and rent, and regarding keys; telephone consultation with
Harry Driscoll regarding buyer interest.
08/10/09 W C Watts .50 Corresponded with counsel for World Fuel regarding
unrecorded liens against Stanford aircraft.
102
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 36 of 377
Page 35
Hours Description
08/11/09 S W Austin .40 Repositioned aircraft to Houston Executive Airport; e-mail
message exchanges with Jeanette Day and HEA and Doug
Hubener regarding same.
08/12/09 S W Austin 1.20 Replied to Mark Peregrin regarding title search on World Fuel
Disclaimer; sent e-mail messages to and from Jeanette Day and
Fred Fram regarding FAA address for notice, regarding space
for logbooks and spare parts, and regarding mechanics for
engine runs; sent e-mail message to Scott Andre at Houston
Executive Airport regarding same; reviewed World Fuel
release sent by Mark Peregrin; replied; sent e-mail message to
Wes Watts regarding contacting World Fuel's counsel.
08/12/09 W C Watts .80 Reviewed lien filings and correspondence related thereto;
drafted correspondence to World Fuel summarizing
shortcomings in previously filed release and disclaimer and
requesting execution of release provided by BB.
08/13/09 S W Austin .70 Sent e-mail message to Houston Executive airport regarding
spare parts delivery; e-mail message to Margaret Allen
regarding receipt of canceled note; sent e-mail message
regarding access to aircraft to Jeanette Day.
08/24/09 S W Austin .40 E-mail message from Margaret Allen regarding World Fuel
liens; forwarded to Wes Watts; reviewed Settlement
Agreement regarding unreleased liens; reviewed Wes Watt's
reply; sent reply to Margaret Allen regarding anticipated
release timing.
08/24/09 W C Watts .60 Spoke to and corresponded with World Fuel counsel regarding
release and disclaimer of liens on Stanford aircraft.
08/25/09 W C Watts .80 Reviewed correspondence from counsel from World Fuel;
drafted correspondence to Mark Peregrin and sent Disclaimer
and Release of unrecorded liens overnight.
08/26/09 S W Austin .20 E-mail message from Wes Watts regarding World Fuel liens;
replied with questions for aircraft title counsel's office.
08/26/09 W C Watts .50 Corresponded via email and spoke on the phone with aircraft
counsel regarding releases of unrecorded liens filed by World
Fuel; requested copies of all.
08/31/09 S W Austin .50 Revised aviation summary and sent to Craig Adams.
Matter Total 178.30
079716.0104 Banking Matters
103
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 37 of 377
Page 36
Hours Description
06/01/09 H T Hamner III .50 Reviewed revised agreement between Oasis Bank and Receiver
relating to return of cashier's check to remitter, provided
comments on same.
06/02/09 H T Hamner III 1.60 Call with FTI team regarding REDACTED , follow-
up email to K. Wolfe regarding data discrepancies, additional
data request; correspondence with B. Stutts regarding TD data
production; attention to other banking matters.
06/03/09 H T Hamner III .50 Attention to finalizing agreement regarding Oasis Bank
cashier's check; attention to data requests.
06/04/09 H T Hamner III .60 Attention to finalization of Oasis Bank direction agreement;
communications with D. Arlington regarding REDACTED
.
06/05/09 H T Hamner III .70 Call with R. Plotkin to discuss issues with TD Bank providing
additional data related to Stanford accounts, follow-up
communication with FTI team regarding same.
06/08/09 H T Hamner III 1.10 Call with J. Ferguson regarding issues with TD Bank data
production; call to R. Plotkin; attention to finalization of Oasis
Bank direction letter.
06/09/09 H T Hamner III .70 Finalized letter to J. Hamilton regarding new draw under
Schwab letter of credit, return of cash collateral; call to J.
Hamilton regarding same.
06/10/09 H T Hamner III 2.70 Conference with B. Stutts regarding Bank of Antigua matters,
follow-up work on same; call with R. Plotkin, representatives
of TD Bank and FTI regarding REDACTED
, follow up call with FTI regarding same.
06/10/09 W F Stutts, Jr. 1.60 Obtained from Mr. Hamner information regarding Bank of
Antigua accounts and reviewed same; reviewed questions
regarding Julius Baer accounts and statements.
06/11/09 H T Hamner III 2.30 Correspondence regarding proposal from Bank of America to
assess banking fees on Stanford accounts; drafted letter
responding to request from Eastern Caribbean Central Bank
relating to unfreezing of accounts.
06/11/09 W F Stutts, Jr. 1.40 Reviewed information from Mr. Hamner regarding points on
Bank of Antigua service charges and commented on Mr.
Hamner draft letter to ECCB regarding their most questions
about accounts.
06/12/09 H T Hamner III .10 Emails relating to data requests.
06/15/09 H T Hamner III .80 Conference with J. Ferguson, K. Blake, C. Kolodjeski
regarding requests for additional data from Toronto Dominion.
104
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 38 of 377
Page 37
Hours Description
06/16/09 H T Hamner III .80 Prepared request for supplemental data to be produced by
Toronto Dominion, sent same to R. Plotkin; emails regarding
other banking matters.
06/18/09 H T Hamner III .40 Email to R. Janvey regarding REDACTED
.
06/20/09 H T Hamner III .10 Located correspondence regarding REDACTED
per request of B.
Howell.
06/24/09 W F Stutts, Jr. .30 Reviewed information form and communication with Mr.
Hamner regarding REDACTED
.
06/25/09 H T Hamner III .20 Responded to emails relating to Bank of America matters.
06/26/09 H T Hamner III .20 Responded to questions from B. Stutts.
06/26/09 W F Stutts, Jr. .40 Reviewed letter draft from Hearing Hamner to ECCB and
commented on same.
06/27/09 H T Hamner III .10 Attention to emails.
06/29/09 W F Stutts, Jr. .30 Letter to ECCB.
06/29/09 J P Zabaneh .90 Correspondent banking at BofA issues.
06/30/09 W F Stutts, Jr. 1.90 Reviewed information, status and location of bank account
holdings and securities REDACTED
and updated that information with further questions
related to sources of certain funds in accounts not in the U.S.
06/30/09 J P Zabaneh 1.10 Correspondent banking at Bank of America; wire transfers.
07/01/09 H T Hamner III .50 Attention to data production by Toronto Dominion; emails
regarding same.
07/02/09 H T Hamner III .30 Reviewed letters from Bank of Antigua regarding frozen funds;
reviewed reply letter prepared by J. Zabaneh.
07/06/09 H T Hamner III .20 Attention to Bank of Antigua requests.
07/06/09 W F Stutts, Jr. .90 Attention to Bank of Antigua wire issues.
07/07/09 H T Hamner III 1.80 Call to A. Narin of Mellon United regarding transfer of funds;
drafted funds transfer direction letter, sent to A. Narin; call
with K. Schlanger regarding sale of property REDACTED
; emails to J. Zabaneh regarding various
matters; calls with J. Hamilton regarding providing additional
bank statements for Bank of Houston accounts.
07/07/09 W F Stutts, Jr. .80 Personal accounts questions and reviewed information
regarding Bank of Antigua accounts.
105
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 39 of 377
Page 38
Hours Description
07/08/09 H T Hamner III 2.40 Conference with J. Zabaneh regarding various follow-up items
on banking matters; responded to requests from B. Stutts;
follow-up with Mellon United Bank regarding transfers;
attention to other banking-related matters.
07/08/09 W F Stutts, Jr. 1.60 Bank of Antigua accounts and information.
07/08/09 J P Zabaneh 6.90 Drafted requests for wire transfers; correspondence with FTI;
Researched DKR issues; Researched Bank of Antigua accounts
and amounts.
07/09/09 H T Hamner III .80 Attention to wire of funds from Mellon United to Receiver's
account; follow up on open items regarding transfers of funds
to Receiver's account; attention to other banking matters.
07/09/09 J P Zabaneh .50 Wire transfers instruction letters.
07/10/09 H T Hamner III .10 Attention to Bank of Houston account statements.
07/10/09 J P Zabaneh .30 Trustmark commission issues.
07/13/09 H T Hamner III .30 Responded to questions from B. Stutts.
07/13/09 W F Stutts, Jr. .80 Reviewed information from Mr. Hamner regarding
REDACTED and telephone conferences with Mr.
Reece and Mr. DeKluiver's office regarding Bank of Antigua
accounts and responded to inquiry from Mr. Kenney Byron and
further work on letter related to funds and release of same.
07/14/09 H T Hamner III .40 Attention to transfer of funds from Barclays account being held
at Bank of New York.
07/15/09 H T Hamner III .80 Correspondence with Barclays, Bank of New York and FTI
regarding wires that were supposed to have been sent to
Receiver's account.
07/15/09 J P Zabaneh .50 Commissions payable to Stanford.
07/16/09 H T Hamner III .80 Attention to transfer of funds from Barclays being held at Bank
of New York; call with attorney for DKR Capital; call with B.
Stutts; attention to other banking matters.
07/17/09 W F Stutts, Jr. 1.90 Worked on information regarding bank of Antigua and location
and amounts of funds in various accounts.
07/18/09 W F Stutts, Jr. .90 Bank of Antigua also information mollica regarding amounts at
Pershing.
07/19/09 H T Hamner III .40 Email to lawyer for Trustmark regarding request for account
data.
07/20/09 H T Hamner III 1.50 Attention to bank account data requests; attention to transfer of
funds from Cane Capital, Barclays; attention to Paradigm Fund
106
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 40 of 377
Page 39
Hours Description
issues.
07/20/09 W F Stutts, Jr. 1.10 Communications to C. Kolodjeski at FTI and with Herschel
Hamner regarding issues regarding REDACTED and
reviewed information on hand regarding the same; continued
development.
07/20/09 W F Stutts, Jr. .30 Information from Mr. Hamner regarding
REDACTED .
07/21/09 H T Hamner III .40 Attention to questions from FTI regarding transfers of funds,
Trustmark account data.
07/21/09 J P Zabaneh .40 Citi account research.
07/22/09 H T Hamner III .60 Attention to issues with Cane Global delivery of funds to
Receiver; follow up emails with C. Kolodjeski.
07/23/09 H T Hamner III 2.70 Participated in call with B. Stutts, J. Ferguson, C. Kolodjeski
regarding Bank of Antigua matters; call with counsel to Cane
Capital regarding return of Stanford investment funds; follow
up emails to various financial institutions regarding wiring
funds.
07/23/09 W F Stutts, Jr. 1.80 Information from Mr. Kolodjeski regarding Trustmark and
other accounts and ; reviewed information at hand for
REDACTED
account information; reviewed information from FTI and
telephone conferences with Jeff Ferguson and Craig Kolodski.
07/23/09 J P Zabaneh .70 Correspondence regarding outstanding balances and wire
transfers; private equity.
07/24/09 H T Hamner III 1.10 Attention to preparing documentation to authorize transfer of
funds held in Barclays accounts to Receiver's account; drafted
letter regarding Paradigm Fund, sent to M. LoPresti; email
regarding proposal for transferring remaining amounts at Cane
Global.
07/24/09 J P Zabaneh 3.30 Discussion regarding outstanding balances; correspondence
with Barclays Wealth regarding wire transfer authorization.
07/27/09 W F Stutts, Jr. .60 Telephone conferences with Patty Melamed of Bank of
America regarding document information and delivery and
timing on receipt of that information all regarding Bank of
Antigua accounts at Bank of America.
07/27/09 W F Stutts, Jr. 2.80 Reviewed with Mr. Howell issues related to Bank of Antigua;
telephone conferences Jack DeKluiver regarding question on
DOJ position regarding Bank of America; several comments
with Mr. Howell; telephone conferences with Michael Moore
on the SEC position on same; extended questions regarding
actions to be taken and information relevant to the decisions.
107
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 41 of 377
Page 40
Hours Description
07/27/09 J P Zabaneh 1.00 Prepared letters to Barclays for liquidation of assets.
07/28/09 W F Stutts, Jr. 1.80 Telephone conference with RSJ and Michael Moore regarding
letters received today from ECCB regarding sale of Bank of
Antigua and related preparation of memo regarding open
points; initial assembly of information on same.
07/30/09 W F Stutts, Jr. 1.10 Prepared letter to Governor Venner and worked on underlying
information for the same; several communications related to
account information and reviewed information from Bank of
America.
07/31/09 W F Stutts, Jr. 1.10 Bank of Antigua.
07/31/09 J P Zabaneh .30 Correspondence regarding closing of certain accounts.
08/02/09 W F Stutts, Jr. 1.10 Continued work on letter to Dwight Venner and transmittal of
same regarding draft for Ralph Janvey; additional
communication with Herschel Hamner regarding points on
Bank of America account information.
08/03/09 H T Hamner III .90 Responded to emails from B. Stutts; attention to outstanding
transfer requests; attention to other banking matters.
08/03/09 W F Stutts, Jr. .60 Reviewed with Mr. Hamner the needs for information
REDACTED and telephone conferences
with Patty Melamed of Bank of America regarding same.
08/03/09 J P Zabaneh 1.00 Correspondence regarding accounts held at Barclays;
Trustmark accounts.
08/04/09 H T Hamner III 2.90 Drafted agreement between Receiver and Cane Capital relating
to transfer of certain proceeds of liquidation of investment to
Receiver's account, settlement of claims by Cane against
Stanford Financial Group.
08/04/09 H Lok 2.10 Review check images for Bank of Antigua account at Bank of
America.
08/04/09 W F Stutts, Jr. 1.40 Made arrangements for junior associate to conduct review in
NY of Bank of America information; several points of
instruction on the scope and related facts for Ms. Wilm and Ms.
Lok; related information to Mr. Hamner on points for data
retrieval.
08/05/09 J C Akalski 6.30 Stanford receivership document review.
08/05/09 H T Hamner III .50 Revisions to agreement with Cane Capital; sent draft of same
to counsel to Cane.
08/05/09 H Lok 6.50 Review check images for Bank of Antigua account at Bank of
America.
108
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 42 of 377
Page 41
Hours Description
08/05/09 W F Stutts, Jr. .70 Reviewed with Mr. Janvey REDACTED
and
related revision of same and worked on materials to be
submitted with that.
08/06/09 J C Akalski 8.50 Stanford receivership document review.
08/06/09 H T Hamner III 1.00 Call with Paradigm Fund lawyer, Bank of New York, counsel
to fund in which Paradigm invested relating to release of funds
owing to Paradigm Fund; revised letter relating to Paradigm
Fund and redistributed same; responded to requests from B.
Stutts relating to Bank of Antigua.
08/06/09 H Lok 8.80 Review check images for Bank of Antigua account at Bank of
America.
08/06/09 W F Stutts, Jr. .90 Worked on letter to Governor Venner regarding Bank of
Antigua and incorporated findings from Bank of America
work.
08/06/09 J P Zabaneh 2.20 Research regarding correspondent banking at Trustmark, TD,
Bank of America and Credit Suisse.
08/07/09 J C Akalski 2.50 Review documents related to Stanford / Bank of Antigua, at
bank of America offices.
08/07/09 H T Hamner III .20 Responded to questions/requests of B. Stutts relating to Bank
of Antigua.
08/07/09 H Lok 4.80 Review check images for Bank of Antigua account at Bank of
America.
08/07/09 W F Stutts, Jr. 1.10 Reviewed input on letter to Governor Venner including
verification of deposit amounts from Mr. Zabaneh and related
information from other sources; revisions to and updating of
response and reviewed additional information from Bank of
America
08/07/09 J P Zabaneh 4.20 Research regarding Bank of Antigua correspondent banking
and account balances.
08/09/09 H T Hamner III .30 Responded to questions from D. Arlington regarding letter of
credit issued by Trustmark to Cisco.
08/10/09 H Lok .30 Correspondence with Bank of America regarding check images
for Bank of Antigua account at Bank of America.
08/10/09 J P Zabaneh 1.00 ECCB-related matters.
08/11/09 H T Hamner III .20 Responded to requests of B. Stutts.
08/11/09 J P Zabaneh 3.70 Correspondence with FTI; prepared spreadsheet with account
detail and balance information for every account, of every
entity, in every country (other than US).
109
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 43 of 377
Page 42
Hours Description
08/12/09 H T Hamner III .50 Reviewed letter to Gov. Venner per request of B. Stutts;
provided comments on same.
08/13/09 H M Chappel 1.30 Compiled debit and credit amounts from Stanford Int'l Bank
Debits/Credits in preparation for attorney review.
08/14/09 W F Stutts, Jr. .40 Letter to ECCB and coordination of information for inclusion
08/17/09 H T Hamner III .80 Responded to questions from D. Arlington regarding Paradigm
fund issues; attention to request from counsel to Trustmark.
08/17/09 H Lok .20 Correspondence with Bank of America regarding check images
for Bank of Antigua account at Bank of America.
08/18/09 H T Hamner III .50 Call with D. McMahon (counsel to Cane Capital) regarding
agreement relating to withdrawal of investment from Cane
Global Macro fund; revised agreement, sent to D. McMahon
for review; sent final agreement for all parties to sign.
08/24/09 H T Hamner III .20 Finalized agreement with Cane Capital relating to withdrawal
of investment, circulated executed version to all parties.
08/25/09 H T Hamner III .20 Attention to transfers of funds to Receiver's account at Chase.
08/31/09 K W Hinton .60 Reviewed BOA Production and created folder on shared drive
for same; supervised and assisted with uploading production to
shared drive.
08/31/09 D S Rohleder .50 Uploaded Production Content from Bank of America CDs to
our Shared Drive per K Hinton;
08/31/09 W F Stutts, Jr. .20 Reviewed and commented on response from ECCB regarding
earlier communication regarding Bank of Antigua
Matter Total 136.90
079716.0105 Brokerage and Trust Matters
Hours Description
06/01/09 C N Adams .40 Telephone conference with Malcolm Lovett regarding account
review process.
06/01/09 D T Arlington 5.80 Worked on account reviews; telephone conferences with
account holders; conferences and email exchanges with team
regarding account review issues.
06/01/09 B A Day 1.00 Reviewed and analyzed documents for creation of stipulations
for a partial release of funds in account holders' Pershing
accounts.
06/01/09 V O Garcia .50 Meeting with A. York, D. Arlington and K. Hinton regarding
account holder stipulations and procedures for filing; review
110
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 44 of 377
Page 43
Hours Description
Stanford deadlines .
06/01/09 M A Gold 1.80 Attention to Stanford investor questions and document
production; attention to issues regarding Beta.
06/01/09 M G Myers 8.30 Attention to matters relating to account release of accounts
containing de minimis amounts of proceeds from Stanford
International Bank certificates of deposits; drafted documents
for website updates; researched and discussed assignment
instrument to be used to evidence certificate of deposit claim
for Stanford Trust Company investors; attention to various
other matters relating to account transfers of Stanford Trust
Company.
06/01/09 A F York 9.80 Prepared stipulations for partial account releases; office
conference with D. Arlington regarding same; conference calls
with V. Kurylak regarding same; various calls and emails with
FTI, FITS, and Stanford regarding same; calls with J. Epstein
regarding same; reviewed and revised list of outstanding
releases; circulated instructions to FTI/FITS/Stanford regarding
same; coordinated pickup of leased equipment from Stanford
Austin office space.
06/02/09 D T Arlington 6.20 Worked on account reviews and stipulations; telephone
conferences with account holders and their counsel;
conferences and email exchanges with team regarding account
review issues; reviewed recent filings.
06/02/09 J A Cialone, II .80 Calls and emails about account release process; calls and
emails about trust accounts and issues related thereto.
06/02/09 T M Davis 1.30 Stanford brokerage call with account release team, M. Lovett,
and K. Sadler; read emails regarding Examiner question.
06/02/09 B A Day 1.00 Reviewed and analyzed documents for creation of stipulations
for a partial release of funds in account holders' Pershing
accounts.
06/02/09 V O Garcia 2.50 Meet with K. Hinton regarding Stanford tasks and ongoing
projects; file Stipulation Regarding Release of Accounts
(Painter) with the Northern District and send same for share
drive and create index to track same and send to D. Rohleder.
06/02/09 M A Gold 3.00 Correspondence with investors and call with B. Lawrence
regarding successor general practice issues; attention to
responding to question/issues and correspondence; draft
memorandum regarding contacts.
06/02/09 J C Huddleston 4.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
111
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 45 of 377
Page 44
Hours Description
review; reviewed and compiled list of outstanding accounts.
06/02/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding account release issues, STC issues, etc.
06/02/09 M G Myers 9.10 Attention to various inquires from Stanford Trust Company
customers, edited and revised documents for website updates
and documents to be sent to all Stanford Trust Company
customers; conference call with Bill Stutts, Maggie Brown and
Jim Raborn to discuss REDACTED
; working with FITS, Inc. to handle
various matters relating to Stanford Trust Company.
06/02/09 N M Starbuck 3.20 Assisted in the release of U.S. Pershing Accounts designated
by FTI as eligible for Stipulated Partial Release.
06/02/09 W F Stutts, Jr. .90 Reviewed with M Myers and Maggie Brown and J Raborn the
form of declaration of assignment and comments on same after
comparison with terms and conditions; reviewed revised form;
cleared form with KLB; reviewed mechanics of delivery;
related documentation information.
06/02/09 A F York 7.60 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; office
conference with D. Arlington regarding same; conference calls
with V. Kurylak regarding same; various calls and emails with
FTI, FITS, and Stanford regarding same; calls with J. Epstein
regarding same; reviewed and revised list of outstanding
releases; circulated instructions to FTI/FITS/Stanford regarding
same.
06/03/09 D T Arlington 3.40 Worked on account reviews and stipulations; telephone
conferences with account holders and their counsel;
conferences and email exchanges with team regarding account
review issues.
06/03/09 T M Davis 2.20 Meet with R. Janvey to discuss account review processes.
06/03/09 B A Day 7.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/03/09 M A Gold 1.50 Follow-up with B. Lawrence and attention to issues; attention
to investor questions and issues and responses; review
successor general practice material.
06/03/09 H T Hamner III .80 Reviewed revisions to account transfer agreement;
communication with lawyer for account holder regarding same;
reviewed securities account control agreement to which STC is
a party; email regarding same.
112
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 46 of 377
Page 45
Hours Description
06/03/09 J C Huddleston 4.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/03/09 S A Massad .70 Various telephone conferences and email regarding STC and
account release issues.
06/03/09 M G Myers 7.80 Attention to matters relating to the transfer of accounts to
Oppenheimer and trying to speed the process up; attention to
various matters relating to release and transfer of Stanford
Trust Company accounts and how to deal with accounts
remaining frozen; weekly conference call with various state
regulatory agencies.
06/03/09 N M Starbuck 4.00 Assisted with the release of frozen, partial release, and STC
related U.S. Pershing Accounts; At the request of A. York
uploaded SPR summaries to share drive.
06/03/09 W F Stutts, Jr. .40 Reviewed communication from Ms. Blumenschein and
responded to same regarding REDACTED
.
06/04/09 D T Arlington 4.30 Worked on account reviews and stipulations; conferences and
email exchanges with team regarding account review issues.
06/04/09 B A Day 6.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/04/09 V O Garcia .50 File Stipulation Regarding Release of Accounts (the Vaughns)
with Northern District and forward same to D. Rohleder for
tracking; review updated SEC deadline chart.
06/04/09 M A Gold 3.50 Attention to issues related to successor general practice and
attention to investor issues; review successor general practice
diligence materials.
06/04/09 H T Hamner III 1.10 Attention to finalization of transfer agreement providing for
transfer of pledged account at Stanford Trust Company to
Charles Schwab; drafted additional language for agreement
regarding termination of account control agreement.
06/04/09 J C Huddleston 4.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/04/09 S A Massad 1.30 Various telephone conferences and e-mail correspondence
regarding STC and account release issues.
06/04/09 M G Myers 7.30 Gathered contact info for Stanford Trust Company account
holders who have released accounts but have not contacted the
113
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 47 of 377
Page 46
Hours Description
Receiver to transfer their account; called Stanford Trust
Company account holders to inform them that their account
had been released and the transfer procedures; calls with
Oppenheimer to try to speed up transfer of accounts; attention
to various matters relating to release and transfer of Stanford
Trust Company accounts.
06/04/09 N M Starbuck 3.40 Assisted with the release of frozen, partial release, and STC
related U.S. Pershing Accounts; Uploaded SPR summaries to
Austin share drive at the request of A. York.
06/04/09 A F York 6.80 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
emails to account holders regarding same; various calls and
emails with FTI, FITS, and Stanford regarding same; reviewed
candidates for de minimis release; prepared protocol for
transfers from IRA accounts to Receiver.
06/05/09 D T Arlington 5.60 Addressed account review issues; communicated with account
holders' counsel regarding same; conferences and email
exchanges with team regarding same.
06/05/09 T M Davis 2.10 Read emails regarding the review process; review proposed
responses; call with R. Janvey et al. re same.
06/05/09 B A Day 6.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/05/09 T S Durst .40 Attention to issues regarding account releases and
communications with attorneys for investors regarding same.
06/05/09 V O Garcia .20 File Stipulation Regarding Release of Accounts (Moran) with
Northern District and forward same to D. Rohleder for
tracking.
06/05/09 M A Gold .90 Correspondence with C. Shapely and K. Williams, Jr.
regarding successor general practice; negotiation of
Confidentiality Agreement and correspondence regarding the
same; attention to issues regarding successor general practices.
06/05/09 J C Huddleston 3.80 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/05/09 S A Massad .70 Various telephone conferences and e-mail correspondence
regarding account release issues.
06/05/09 M G Myers 6.90 Finalized second phase of released Stanford Trust Company
accounts and account analysis; assisted in Response to
Examiner; looking up contact info and calling Stanford Trust
Company account holders who have released accounts but that
114
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 48 of 377
Page 47
Hours Description
have not released their account; attention to miscellaneous
matters relating to release and transfer of Stanford Trust
Company accounts.
06/05/09 N M Starbuck 3.80 Assisted in the release of U.S. Pershing Accounts designated
by FTI as eligible for Stipulated Partial Release; Assisted A.
York with ensuring accessibility of Pershing account
statements on Austin share drive.
06/05/09 A F York 6.60 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; office
conference with D. Arlington and B. Day regarding same;
various calls and emails with FTI, FITS, and Stanford
regarding same.
06/06/09 D T Arlington .90 Addressed account release issues; communicated with team
regarding same; reviewed status of Schwab motion; reviewed
recent filings
06/07/09 D T Arlington .60 Addressed account release issues; communicated with team
regarding same; reviewed status of Schwab motion
06/08/09 D T Arlington 4.50 Worked on account reviews and stipulations; telephone
conferences with account holders and their counsel;
conferences and email exchanges with team regarding account
review issues.
06/08/09 B A Day 10.30 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/08/09 M A Gold 2.00 Discussion with F. Quinlan regarding successors, general
practices and considerations; draft memo; briefing discussions;
attention to responses and correspondence regarding same.
06/08/09 J C Huddleston 4.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/08/09 S A Massad .30 Attention to account release issues.
06/08/09 M G Myers 5.20 Attention to matters relating to removal of Stanford Trust
Company as trustee in different states; gathered information
necessary for Complaint REDACTED
; attention to matters relating to the release
and transfer of Stanford Trust Company accounts.
06/08/09 N M Starbuck 2.90 Assisted in the release of U.S. Pershing Accounts designated
by FTI as eligible for Stipulated Partial Release.
06/08/09 A F York 6.00 Reviewed and analyzed account release applications and
115
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 49 of 377
Page 48
Hours Description
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; calls with
V. Kurylak regarding same; office conference with B. Day
regarding same; various calls and emails with FTI, FITS, and
Stanford regarding same.
06/09/09 D T Arlington 9.10 Worked on account reviews and stipulations; telephone
conferences with account holders and their counsel;
conferences and email exchanges with team regarding account
review issues; reviewed declaration of Ralph Janvey; worked
on relief defendant complaint
06/09/09 T M Davis .80 Review revised Pershing stipulation and discuss with V.
Kurylak.
06/09/09 B A Day 11.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/09/09 J C Huddleston 2.60 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/09/09 S A Massad .50 Various telephone conferences and e-mail correspondence
regarding account release issues.
06/09/09 M G Myers 3.10 Attention to matters relating to removal of Stanford Trust
Company as trustee in different states; attention to matters
relating to the release and transfer of Stanford Trust Company
accounts.
06/09/09 N M Starbuck 3.30 Assisted in the release of U.S. Pershing Accounts designated
by FTI as eligible for Stipulated Partial Release; Uploaded SPR
summaries to Austin share drive.
06/09/09 A F York 7.50 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; calls with
V. Kurylak regarding same; office conference with B. Day
regarding same; various calls and emails with FTI, FITS, and
Stanford regarding same.
06/10/09 J A Cialone, II .80 Attention to daily release report and related issues; calls and
emails about account release processes.
06/10/09 T M Davis .80 Read emails regarding process; telephone conferences with K.
Sadler and J. Cialone re same.
06/10/09 B A Day 8.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/10/09 M A Gold 1.20 Attention to successor general practice issues and
116
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 50 of 377
Page 49
Hours Description
correspondence regarding the same.
06/10/09 J C Huddleston 6.70 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
AR'S reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/10/09 S A Massad .30 E-mail correspondence regarding account release issues.
06/10/09 M G Myers 2.90 Attention to matters relating to removal of Stanford Trust
Company as trustee in different states; attention to matters
relating to the release and transfer of Stanford Trust Company
accounts.
06/10/09 N M Starbuck 1.90 Assisted in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Uploaded SPR information to
Austin share drive at the request of B. Day.
06/10/09 A F York 4.50 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
06/11/09 D T Arlington 3.40 Worked on account reviews and stipulations; communicated
with account holders and their counsel; conferences and email
exchanges with team regarding account review issues.
06/11/09 B A Day 8.20 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/11/09 J C Huddleston 4.30 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts;
reviewed and uploaded account information submitted via
compact disc.
06/11/09 M G Myers 4.70 Conference call with the Louisiana Office of Financial
Institutions; attention to various matters relating to the release
of Stanford Trust Company accounts and brokerage accounts;
gathered and sorted data to be used in the stipulation process
for release of Stanford Trust Company accounts.
06/11/09 N M Starbuck 4.10 Assisted in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Uploaded SPR information to
Austin share drive.
06/11/09 A F York 8.50 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
117
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 51 of 377
Page 50
Hours Description
06/12/09 J A Cialone, II 2.00 Calls, meetings and emails with Receiver and Receiver's team
throughout the day concerning REDACTED
.
06/12/09 T M Davis .30 Exchange emails with K. Sadler regarding account review.
06/12/09 B A Day 8.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/12/09 J C Huddleston 3.70 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/12/09 M G Myers 3.40 Attention to various matters relating to the release of Stanford
Trust Company accounts and brokerage accounts; gathered and
sorted data to be used in the stipulation process for release of
Stanford Trust Company accounts.
06/12/09 N M Starbuck 3.50 Compiled list of outstanding account statements necessary for
release of frozen Pershing accounts; Aided in the release of
U.S. Pershing Accounts eligible for Stipulated Partial Release
06/12/09 A F York 6.20 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
06/13/09 D T Arlington 3.70 Addressed account release issues; communicated with team
regarding de minimis releases.
06/14/09 B A Day 6.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/15/09 J A Cialone, II .80 Attention to new draft of SIPC FAQ; attention to various
account review issues and related emails.
06/15/09 B A Day 5.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/15/09 V O Garcia .20 Efile Stipulation Regarding Release of Accounts (Wenitsky)
and Stipulation Regarding Release of Accounts (Hausladen);
and forward same to D. Rohleder for tracking.
06/15/09 J C Huddleston 7.70 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review.
06/15/09 M G Myers 1.10 Attention to matters relating to the release of trust company
accounts.
118
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 52 of 377
Page 51
Hours Description
06/15/09 N M Starbuck 3.50 Assisted in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Uploaded SPR and account
information to Austin share drive.
06/16/09 D T Arlington 2.10 Coordinated with account holders and opposing counsel
regarding stipulations and related issues.
06/16/09 T M Davis .30 Exchange emails with M. Lovett regarding status.
06/16/09 B A Day 9.00 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/16/09 V O Garcia .30 Efile Stipulation Regarding Release of Accounts (Epstein) and
forward same to D. Rohleder for tracking.
06/16/09 J C Huddleston 7.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts;
corresponded with FITs regarding same.
06/16/09 M G Myers 4.60 Attention to matters relating to release and transfer of Stanford
Trust Company customer accounts. Reviewed release and
transfer documents and other miscellaneous items.
06/16/09 N M Starbuck 3.20 Aided in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Compiled list of outstanding
account statements.
06/16/09 A F York 8.20 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
06/17/09 D T Arlington 1.80 Worked on account release issues and stipulations;
communicated with account holders and their counsel
regarding account release issues.
06/17/09 B A Day 8.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/17/09 J R Hollis 1.40 Research for bulk account transfer.
06/17/09 J C Huddleston 3.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review.
06/17/09 M G Myers 3.60 Conference call with state regulatory agencies; attention to
matters relating to release and transfer of Stanford Trust
Company accounts.
119
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 53 of 377
Page 52
Hours Description
06/17/09 N M Starbuck 3.40 Aided in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Compiled list of outstanding
account statements.
06/17/09 A F York 5.00 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
06/18/09 D T Arlington 6.20 Addressed account release issues and inquiries from examiner;
coordinated with team regarding same; communicated with
account holders and their counsel.
06/18/09 J A Cialone, II .60 Attention to cash status and prognosis.
06/18/09 B A Day 13.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/18/09 M A Gold .60 Attention to correspondence with investor and F. Quinton;
follow-up with V. Kurylak.
06/18/09 J C Huddleston 2.60 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review.
06/18/09 M G Myers 3.90 Conference call with LA AG, email respond, IRA issues
06/18/09 N M Starbuck 3.20 Assisted in the release of U.S. Pershing Accounts eligible for
Stipulated Partial Release; Uploaded SPR and account
information to Austin share drive.
06/19/09 D T Arlington 3.20 Addressed account release issues; communicated with account
holders and their counsel regarding account release issues;
conferred with team regarding same.
06/19/09 B A Day 8.60 Created stipulations for a partial release of funds in account
holders' Pershing accounts.
06/19/09 J R Hollis 5.90 Research of broker-dealer regulation, including treatise review;
email correspondence with BB lawyers; correspondence with
Vic Kurylak regarding details of proposed transaction; began
drafting Agreement.
06/19/09 J C Huddleston 5.10 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review.
06/19/09 M G Myers 4.20 Attention to matters relating to the release and transfer of
Stanford Trust Company accounts; assisted in various tasks
relating to transfer of brokerage accounts.
120
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 54 of 377
Page 53
Hours Description
06/19/09 J E Raley .20 Office conference with Maggie Brown regarding questions
regarding trust matter.
06/19/09 N M Starbuck 3.40 At the request of B. Day provided account holder information
to aid in the release of frozen accounts; Uploaded SPR
information to Austin share drive.
06/20/09 D T Arlington .30 Reviewed account release reports; reviewed and researched
examiner inquiry regarding same
06/20/09 T M Davis .70 Read and respond to emails regarding process; discuss the
same with M. Lovett.
06/21/09 D T Arlington .30 Reviewed account release reports; exchanged email with team
regarding same.
06/21/09 J A Cialone, II .50 Attention to release of accounts process and emails.
06/22/09 D T Arlington 1.40 Worked on account release issues; communicated with team
regarding same.
06/22/09 T M Davis .30 Call regarding review process.
06/22/09 B A Day 12.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
for such stipulations.
06/22/09 J R Hollis 8.10 Research and initial draft of Agreement to Transfer Accounts.
06/22/09 M G Myers 3.80 Conference call with the Securities and Exchange Commission;
attention to matters relating to the release and transfer of
Stanford Trust Company and brokerage accounts.
06/22/09 N M Starbuck 3.00 At the request of B. Day provided applications and information
for account holders to aid in the release of frozen accounts;
Uploaded SPR information provided by FTI to Austin share
drive.
06/22/09 A F York 9.50 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same;
travel to Houston.
06/23/09 D T Arlington 3.30 Worked on account release issues; coordinated with team
regarding same; communicated with account holders and their
counsel.
06/23/09 J A Cialone, II .80 Attention to broker claims.
06/23/09 B A Day 12.70 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
for such stipulations.
121
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 55 of 377
Page 54
Hours Description
06/23/09 J R Hollis 7.80 Call with Vic Kurylak and Mike Myers regarding Agreement;
revisions to Agreement.
06/23/09 J C Huddleston 1.30 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review.
06/23/09 M G Myers 5.30 Attention to matters relating to release and transfer of Stanford
Trust Company and brokerage accounts; assisted FITS with
issues relating to REDACTED and responded
to multiple inquiries; reviewed draft of bulk transfer agreement
and searched for precedent to begin new draft of same.
06/23/09 N M Starbuck 2.60 Assisted in the release of frozen accounts eligible for stipulated
release; scanned and uploaded SPR information for L. Brown's
frozen accounts.
06/23/09 A F York 12.00 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
06/24/09 J A Cialone, II .90 Attention to foreign accounts issues and related emails.
06/24/09 B A Day 14.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations.
06/24/09 M A Gold 2.10 Attention to Confidentiality Agreement requests and investor
requests; attention to general practice replacement issues and
C. Shapley correspondence.
06/24/09 J R Hollis 6.30 Final draft of Agreement; comments from Mike Myers and Vic
Kurylak.
06/24/09 J C Huddleston .70 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review.
06/24/09 M G Myers 11.20 Researched issues related to, and prepared draft of,
REDACTED
; attention to other matters relating to the release
and transfer of Stanford Trust Company accounts and
brokerage accounts.
06/24/09 N M Starbuck 1.30 Assisted in the unfreezing of U.S. Pershing Accounts eligible
for stipulated partial release.
06/24/09 A F York 12.90 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
122
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 56 of 377
Page 55
Hours Description
account releases; calls and emails to account holders regarding
same.
06/25/09 D T Arlington 5.00 Coordinated with team regarding STC account release issues;
addressed Pershing account release issues and coordinated with
team regarding same; communicated with account holders and
their representatives.
06/25/09 J R Hollis 1.20 Review of draft Agreement by Mike Myers.
06/25/09 M G Myers 10.60 Revised account transfer agreement to be used in transfer of
accounts from Pershing LLC to Dominic and Dominic LLC;
discussed same with FITS and Reuben Kopel; drafted
statement to be sent to Stanford Trust Company customers
whose accounts will remain frozen pending outcome of the
clawback claims; attention to various other matters relating to
the transfer and release of Stanford Trust Company and
Stanford Group Company customer accounts.
06/25/09 N M Starbuck 2.10 Uploaded SPR summaries and Pershing account information to
Austin share drive to assist in the release of frozen accounts.
06/25/09 A F York 12.80 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
06/26/09 D T Arlington .70 Addressed account release issues; coordinated with team
regarding same.
06/26/09 T M Davis 1.20 Call to discuss Monday call with Court; read Campbell memo
and discuss with E. Söderlund; exchange emails re same.
06/26/09 B A Day 13.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations.
06/26/09 M A Gold 1.80 Attention to replacement general practice issues; review and
analyze correspondence.
06/26/09 J C Huddleston 5.10 Updated account holder information Stipulated Partial Release
Summary information for attorney review.
06/26/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding account release report; reviewed and commented on
same.
06/26/09 M G Myers 1.30 Attention to various matters relating to release and transfer of
Stanford Trust Company and Stanford Group Company
customer accounts; assisted in various matters relating to
123
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 57 of 377
Page 56
Hours Description
inquires in connection with individual retirement accounts held
at Stanford Trust Company.
06/26/09 J E Raley 3.10 Office conference with Maggie Brown regarding questions
regarding trust agreement; office conference with Ms. Brown
regarding review of additional trust agreements; research
regarding matter; review trust agreements.
06/26/09 E A Soderlund .30 Respond to email question regarding replacement of SCM
general partner and powers granted under receivership order.
06/26/09 N M Starbuck 1.70 Assisted in the unfreezing of U.S. Pershing frozen accounts
eligible for release.
06/26/09 A F York 9.50 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
06/27/09 T M Davis .50 Review schedule sent by M. Lovett.
06/27/09 S A Massad .70 Reviewed and commented on draft report regarding account
release.
06/28/09 D T Arlington .40 Exchanged email with team regarding account release issues
and upcoming hearing.
06/28/09 J A Cialone, II .90 Attention to SIPC issues and FAQ; attention to account status
report; related calls and emails.
06/28/09 T M Davis 1.20 Review revised schedules; conference call re same; review new
SIPC theory.
06/28/09 B A Day 6.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations; provided Kevin Sadler with status update in
preparation for status conference on Monday, June 29, 2009.
06/28/09 K W Hinton 1.50 Researched stipulations filed by receiver and stipulations filed
under seal and provided summary to attorneys; reviewed,
prepared and e-filed interim report and appendix.
06/28/09 S A Massad 2.00 Reviewed and commented on draft report regarding account
release and related filing with court; conference calls with
group regarding same.
06/29/09 D T Arlington 1.00 Addressed account release issues and communicated with team
regarding same.
06/29/09 J A Cialone, II .80 Reviewed emails and reports on account freeze and review
process, and related calls.
124
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 58 of 377
Page 57
Hours Description
06/29/09 T M Davis .40 Call re hearing with court concerning accounts.
06/29/09 B A Day 12.40 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations.
06/29/09 J C Huddleston 1.30 Maintained and updated account holder Stipulated Partial
Release Summary and account holder information for attorney
review.
06/29/09 S A Massad 1.80 Attention to account freeze issues, new Court order and
proposed letters to customers.
06/29/09 M G Myers 3.40 Attention to matters relating to release and transfer of Stanford
Trust Company and Stanford Group Company customer
accounts; drafted responses to be used in connection with
individual retirement account inquiries and worked on bulk
transfer agreement to be used in connection with the transfer of
certain Stanford Group Company accounts held at Pershing to
another broker dealer.
06/29/09 J E Raley 3.80 Continued review of various trust documents; office conference
with Maggie Brown regarding same; telephone conference with
Sophia Lewis regarding same; correspondence regarding same.
06/29/09 N M Starbuck 2.00 Assisted in the release of accounts held frozen and eligible for
stipulated partial release.
06/29/09 A F York 10.20 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
06/30/09 J A Cialone, II 1.20 Worked on plan for August 3 deadline; related calls and emails
throughout the day.
06/30/09 B A Day 11.50 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations.
06/30/09 J R Hollis 1.20 Review and comments on Account Transfer Agreement.
06/30/09 J C Huddleston 1.40 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review.
06/30/09 S A Massad .70 Reviewed and commented on draft contract for bulk transfer of
accounts; various e-mail correspondence regarding same.
06/30/09 M G Myers 5.30 Attention to matters relating to release and transfer of Stanford
125
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 59 of 377
Page 58
Hours Description
Trust Company and Stanford Group Company customer
accounts; drafted responses to be used in connection with
individual retirement account inquiries and worked on bulk
transfer agreement to be used in connection with the transfer of
certain Stanford Group Company accounts held at Pershing to
another broker dealer.
06/30/09 J E Raley .70 Left message for Christy Lambertus regarding Farquhar trust;
listened to message regarding same; correspondence with
Sophia Lewis regarding Leverich trusts; continued review of
documents.
06/30/09 E A Soderlund .20 Review account transfer agreement and respond to email
regarding same.
06/30/09 N M Starbuck 2.30 Uploaded SPR summaries and Pershing account information to
Austin share drive to assist in the release of frozen accounts.
06/30/09 A F York 10.70 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
07/01/09 D T Arlington 3.20 Addressed account release issues; reviewed account holder
inquiries; communicated with counsel for account holders;
coordinated with team regarding account release issues.
07/01/09 T M Davis 1.10 Review email from V. Kurylak regarding priorities for account
review; telephone conference with M. Lovett, V. Kurylak, and
FTI; email to K. Sadler.
07/01/09 B A Day 10.50 Reviewed account holders' accounts for partial, full, or de
minimis releases; created stipulations for a partial release of
funds in account holders' accounts; reviewed and analyzed
documents and conferred with financial team members to
create such stipulations.
07/01/09 M A Gold 4.40 Draft memorandum to M. Lovett regarding successor general
practice issues; analyze succession issues and correspondence
with group regarding same; attention to open issue on investor
vote; telephone conference with General Quinlan and report to
working group.
07/01/09 M G Myers 1.80 Attention to matters relating to release and transfer of Stanford
Trust Company accounts. Weekly conference call with state
regulators.
07/01/09 J E Raley .70 Listened to message from Vanguard representative regarding
Lufkin/Leveridge matter; review trust agreement and missing
information; further review regarding issues raised regarding
126
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 60 of 377
Page 59
Hours Description
Farquahar trust agreement.
07/01/09 N M Starbuck 2.80 At the request of B. Day prepared proposed stipulation for wire
transfer and letter of authorization for transmittal to account
holder Aubery Clement; Assisted with the release of Pershing
accounts held for stipulated partial release
07/01/09 A F York 9.00 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same.
07/02/09 D T Arlington 1.80 Addressed account release issues; reviewed account holder
inquiries; communicated with team regarding same.
07/02/09 S A D Ayers .50 Telephone conference Keri Brown regarding
REDACTED
.
07/02/09 B A Day 10.50 Reviewed account holders' accounts for partial, full, or de
minimis releases; created stipulations for a partial release of
funds in account holders' accounts; reviewed and analyzed
documents and conferred with financial team members to
create such stipulations.
07/02/09 M A Gold 5.30 Draft/finalize 1st draft of memorandum to M. Lovett regarding
succession GP issues; attention to open issues on shareholder
vote; correspondence regarding same.
07/02/09 H T Hamner III .20 Conference with M. Myers regarding agreement for STC to
sign relating to transfer of accounts.
07/02/09 J C Huddleston 1.80 Met with translator and notarized preliminary Agreed
Stipulations translation certificates.
07/02/09 M G Myers 3.60 Attention to matters relating to transfer of Stanford Trust
Company accounts; worked on finalizing the bulk account
transfer agreement to be used in bulk transfer of account from
Pershing.
07/02/09 J E Raley .70 Telephone conference with Vanguard representative regarding
Lufkin matter; communications with Sophia Lewis regarding
same; listened to message from Christy Lambertus regarding
Farquhar matter; review documents regarding questions raised;
left message for Ms. Lambertus; office conference with Maggie
Brown regarding various matters.
07/02/09 N M Starbuck 3.10 Assisted with the release of Pershing accounts held for
stipulated partial release; At the request of B. Day prepared
proposed stipulation for wire transfer and letter of authorization
for transmittal to account holder Saul Litvinoff; At the request
127
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 61 of 377
Page 60
Hours Description
of B. Day and A. York requested Spanish translations for
Stipulations Regarding Release of Accounts.
07/02/09 A F York 10.70 Worked directly with FITS, FTI, and Stanford teams on
account release process; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; calls and emails to account holders regarding
same; return travel to Austin.
07/03/09 J A Cialone, II 1.50 Reviewed UK judgment and participated in related conference
calls; other calls and emails about same.
07/03/09 B A Day .50 Created stipulations for a partial release of funds in account
holders' accounts; reviewed and analyzed documents and
conferred with financial team members to create such
stipulations.
07/03/09 M G Myers .60 Responding to various emails relating to Stanford Trust
Company accounts.
07/04/09 M G Myers .40 Responded to various emails/inquiries relating to the Stanford
Trust Company.
07/05/09 B A Day 1.50 Reviewed account holders' accounts for partial, full, or de
minimis releases; created stipulations for a partial release of
funds in account holders' accounts; reviewed and analyzed
documents and conferred with financial team members to
create such stipulations.
07/06/09 D T Arlington 3.20 Addressed account release issues; coordinated with team
regarding same; communicated with account holders and their
counsel.
07/06/09 J A Cialone, II .80 Reviewed SIPC emails and materials.
07/06/09 B A Day 6.40 Reviewed account holders' accounts for partial, full, or de
minimis releases; created a stipulation for a partial release of
funds in an account holders' account; reviewed and analyzed
documents and conferred with financial team.
07/06/09 M G Myers 1.10 Responded to various emails and other inquiries relating to
status of Stanford Trust Company accounts.
07/06/09 J E Raley .50 Review correspondence from Christie Lambertus regarding
matter; review documents regarding same; office conference
with Maggie Brown regarding same.
07/06/09 N M Starbuck .70 Assisted with the release of Pershing accounts held for
stipulated partial release
07/06/09 W F Stutts, Jr. .30 Reviewed communication from trust company customer
received from Ms. Blumenschein and developed response.
128
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 62 of 377
Page 61
Hours Description
07/06/09 A F York 6.20 Worked directly with FITS, FTI, and Stanford teams on
account release process; calls and emails to account holders
regarding same; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases.
07/07/09 D T Arlington .80 Exchanged email with team regarding scope of account freeze.
07/07/09 D T Arlington 1.00 Addressed account release issues; coordinated with team
regarding same; exchanged email with account holders and
counsel regarding same.
07/07/09 T M Davis .50 Read emails regarding general partner election.
07/07/09 B A Day 4.40 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team.
07/07/09 M A Gold 4.60 Revise and review memorandum to M. Lovett regarding AI
and Beta; attention to comments from T. Davis and V.
Kurylak; correspondence with C. Shapely regarding open
issues REDACTED and follow-up on issues; calculation
of shareholder vote.
07/07/09 M G Myers .30 Responded to various emails and other inquiries relating to
status of Stanford Trust Company accounts, including matters
relating to release and pledge agreement for certain Stanford
Trust Company accounts.
07/07/09 J E Raley .50 Review correspondence from Christie Lambertus; review
document; office conference with Maggie Brown regarding
same.
07/07/09 A F York 4.50 Worked directly with FITS, FTI, and Stanford teams on
account release process; calls and emails to account holders
regarding same; reviewed and analyzed account release
applications and summaries.
07/08/09 D T Arlington 2.20 Addressed account release issues; coordinated with team
regarding same.
07/08/09 J A Cialone, II .80 Reviewed memo on SIPC issues and considered possible
strategies.
07/08/09 B A Day 4.40 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team.
07/08/09 M A Gold 1.40 Attention to finalizing draft of memo to M. Lovett; attention to
T. Davis question, issue; attention to correspondence with C.
Shapely and G. Quinlan regarding status and open issues.
129
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 63 of 377
Page 62
Hours Description
07/08/09 M G Myers .20 Attention to matters relating to Stanford Trust Company
release of accounts and information relating to Louisiana
investigation.
07/08/09 N M Starbuck 2.00 Processed frozen account holder information to Austin shared
drive at the request of B. Day and V. Kurylak.
07/08/09 A F York 4.10 Worked directly with FITS, FTI, and Stanford teams on
account release process; calls and emails to account holders
regarding same; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases.
07/09/09 D T Arlington 3.70 Addressed account release issues; coordinated with team
regarding same; telephone conferences with counsel for
investors regarding same.
07/09/09 J A Cialone, II .80 Attention to SIPC issues.
07/09/09 T M Davis .50 Read S. Massad analysis re SIPC issue.
07/09/09 M A Gold 4.10 Summarize REDACTED for receiver;
revise receiver memorandum regarding AI and Beta; attention
to report to court; correspondence regarding issues related to
SCM GP resignation; finalize memorandum.
07/09/09 M G Myers 1.10 Conference call with Louisiana Attorney General's office to
discuss matters relating to investigation of Stanford Trust
Company; matters relating to Stanford Trust Company release
of accounts, including responding to email inquiries regarding
same.
07/09/09 J E Raley 1.30 Correspondence from Vanguard regarding Lufkin trusts;
research Florida law regarding same; correspondence with
Sophia Lewis regarding matter; office conference with Maggie
Brown regarding same.
07/09/09 N M Starbuck .60 Assisted with the release of Pershing accounts held for
stipulated partial release
07/10/09 D T Arlington 2.20 Coordinated regarding account stipulations; addressed other
account release issues.
07/10/09 J A Cialone, II 1.00 Reviewed extensive documentation received from Lovett about
accounts; related calls and emails.
07/10/09 T M Davis .20 Read invoice regarding Pershing fees.
07/10/09 B A Day 9.00 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team; drafted
stipulation for partial release of accounts and sent same to
130
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 64 of 377
Page 63
Hours Description
account holder.
07/10/09 M A Gold 1.30 Follow-up on final memorandum and communication with
investors and F. Quinlan.
07/10/09 H T Hamner III .90 Attention to request to transfer account maintained at Stanford
Trust Company to Oppenheimer; conference with H. Tucker
regarding REDACTED
.
07/10/09 M G Myers .60 Attention to matters relating to information summaries of status
of Stanford Trust Company accounts; responded to various
emails relating to Stanford Trust Company and status of all
accounts and accounts containing proceeds REDACTED
.
07/10/09 J E Raley 3.40 Review various trust agreements; office conference with
Maggie Brown regarding legal and factual issues regarding
REDACTED ; research regarding Florida
statutes regarding same; left message for Sophia Lewis
regarding same; listened to message from Ms. Lewis; telephone
conference with John Coker regarding information needed
REDACTED .
07/10/09 H C Tucker 2.90 Researched liability issues REDACTED ; drafted an
account transfer agreement.
07/10/09 A F York 8.50 Worked directly with FITS, FTI, and Stanford teams on
account release process; calls and emails to account holders
regarding same; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; return travel to Austin.
07/11/09 M G Myers .30 Responded to various emails relating to account status of
Stanford Trust Company accounts. Call with FITS regarding
same.
07/12/09 M G Myers .20 Attention to matters relating to release and status report of
Stanford Trust Company accounts.
07/13/09 D T Arlington 2.10 Conference calls with FTI regarding account release status and
analysis issues; addressed other account release issues.
07/13/09 T M Davis 1.90 Exchange emails regarding SIPC issues; email re Bukrinsky
issues; discuss bulk transfer issues with M. Myers.
07/13/09 B A Day 8.20 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team.
07/13/09 H T Hamner III 1.80 Drafted transfer agreement governing transfer of assets in
account at Stanford Trust Company to another brokerage
131
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 65 of 377
Page 64
Hours Description
company, termination of account control agreement to which
STC is a party; call with J. Coker regarding same.
07/13/09 S A Massad .50 Various e-mail correspondence regarding SIPC.
07/13/09 M G Myers 5.90 Attention to matters relating to REDACTED
; conference call with Reuben Kopel
and Tony Davis regarding same; participation in interview of
certain Stanford Trust Company employees with the Attorney
General's's office from the state of Louisiana; attention to
matters relating to the transfer of Stanford Trust Company
accounts.
07/13/09 J E Raley .40 Listened to message from Michael Cor regarding matter;
review documents; left message for Mr. Cor.
07/13/09 H C Tucker 1.50 Revised trust account transfer agreement; incorporated
additional information and clauses into the agreement.
07/13/09 A F York 6.00 Calls and emails with account holders and FTI/FITS/Stanford
Eagle regarding account releases; review REDACTED document
production; conference call and office conference regarding
account review and release timing; preparations for main
complaint; reviewed issues with 754 filings.
07/14/09 D T Arlington 1.90 Reviewed additional account release issues and worked on
same.
07/14/09 D T Arlington .50 Communicated with counsel for Milan regarding stipulation.
07/14/09 M W Brown .50 Further attention to Murray, Verner trust documents per
questions by S. Lewis and J. Coker.
07/14/09 T M Davis 1.50 Emails re SIPC issues and study Bishop claim summary;
conference call with R. Janvey et al. re same.
07/14/09 B A Day 4.50 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team.
07/14/09 S A Massad 1.00 Participated in a conference call with group regarding SIPC
matters; prepared for and followed up regarding same.
07/14/09 M G Myers 4.30 Attention to matters relating to release and transfer of customer
accounts; revised and redrafted transfer agreement for use in
bulk transfer of accounts from Stanford Group Company to
another broker dealer.
07/14/09 J E Raley .20 Review notes; left message for Christie Lambertus regarding
same.
07/14/09 A F York 3.70 Calls and emails with account holders and FTI/FITS/Stanford
Eagle regarding account releases.
132
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 66 of 377
Page 65
Hours Description
07/15/09 D T Arlington 3.60 Reviewed further account analysis by FTI; addressed account
release issues; addressed Pershing release issues.
07/15/09 B A Day 4.90 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team; revised
REDACTED subpoena.
07/15/09 J R Hollis .80 Review of agreement; attention to correspondence.
07/15/09 M G Myers 1.40 Conference call with Dominick and Dominick to discuss
account bulk transfer agreement; attention to matters regarding
same.
07/15/09 J E Raley .30 Telephone conference with Christie Lambertus regarding
issues regarding Farquhar trust.
07/16/09 D T Arlington 2.60 Addressed account release issues; communicated with team
regarding same.
07/16/09 J A Cialone, II 1.20 Reviewed materials related to account review process and
possible REDACTED strategy.
07/16/09 T M Davis 1.70 Review materials regarding Bishop claim; review bulk transfer
agreement and emails re same; read W. Mollica report re Latin
America accounts.
07/16/09 B A Day 7.90 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same; reviewed documentation necessary for subpoenas
REDACTED ; drafted motion
for release of accounts in the name of Stanford Casa de
Valores, S.A., Stanford Group Peru S.A.B., and Stanford Bolsa
y Banca S.A.
07/16/09 M G Myers 2.20 Call with Kim Garber of the Securities and Exchange
Commission to discuss status of certain Stanford Trust
Company accounts; attention to matters relating to
investigation of the Louisiana Attorney General into the
Stanford Trust Company.
07/16/09 J E Raley .90 Correspondence with Michael Cors regarding matter; review
document provided and comment regarding same; review
finalized version; communicate with John Coker regarding
same.
07/17/09 B A Day 7.50 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same; reviewed documentation necessary for subpoenas
133
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 67 of 377
Page 66
Hours Description
REDACTED
; drafted motion
for release of accounts in the name of Stanford Casa de
Valores, S.A., Stanford Group Peru S.A.B., and Stanford Bolsa
y Banca S.A.
07/17/09 M G Myers 4.70 Attention to matters relating to the account transfer agreement
REDACTED
; attention to matters relating to investigations into
Stanford Trust Company by state regulatory agencies; attention
to other miscellaneous matters.
07/20/09 B A Day 5.20 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
07/20/09 M A Gold 1.20 Correspondence with investors and attention to questions
regarding GP succession.
07/20/09 N M Starbuck 1.60 Provided B. Day with account information to assist in the
unfreezing of STC accounts.
07/21/09 J A Cialone, II .50 Reviewed account release reports.
07/21/09 B A Day 8.30 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
07/21/09 M G Myers 5.50 Attention to matters relating to the Louisiana Attorney
General's's office criminal investigation into Stanford Trust
Company and its employees; conference call with the
Securities and Exchange Commission to discuss status of
Individual Retirement Accounts at Stanford Trust Company
that will be distributed out to Stanford Trust Company
customers; responded to various Stanford Trust Company
customer inquiries made to the Receivership; attention to
various other matters relating to the Stanford Trust Company,
including assisting with gathering of information to be used in
Amended Complaint seeking clawback and other related forms
of relief.
07/22/09 T M Davis .70 Read emails from V. Kurylak regarding Bishop claim; discuss
with M. McCoy.
07/22/09 B A Day 9.60 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
134
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 68 of 377
Page 67
Hours Description
07/22/09 M A Gold 1.10 Attention to private label fund GP successor transfer;
correspondence and phone calls with investors; attention to
next steps; attention to Havell Municipal fund invoices and
responsibility issues.
07/22/09 M G Myers 5.10 Attention to matters relating to the bulk transfer of accounts
REDACTED
; attention to matters relating to the Louisiana
Attorney General's's office criminal investigation into Stanford
Trust Company and its employees and various other matters
relating to the Stanford Trust Company.
07/23/09 T M Davis .30 Review account report.
07/23/09 B A Day 9.80 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
07/23/09 M A Gold 5.20 Follow-up on REDACTED issues; attention to Havell fund
issues; review Havell invoices and related information; draft
memorandum on Havell; attention to Havell related issues and
recommendations.
07/23/09 S A Massad 2.50 Drafted letter to SIPC; reviewed materials regarding claims.
07/23/09 M G Myers 2.20 Attention to matters relating to requests from the Securities and
Exchange Commission for information relating to Individual
Retirement Accounts to be distributed out to customers of
Stanford Trust Company; attention to matters relating the
Account Transfer Agreement REDACTED
; conference call with general counsel of
Dominick & Dominick to discuss same.
07/23/09 J E Raley .80 Communications with Sophia Lewis regarding
Lufkin/Leveridge matter; review materials prepared by Maggie
Brown regarding Murray trusts; comments regarding same.
07/23/09 A F York 14.10 Travel to Houston; worked directly with FTI to prepare, revise,
and finalize all schedules and supporting declaration for relief
defendant complaint; coordinated same with FITS and Baker
Botts team; reviewed conflicts.
07/24/09 T M Davis 1.60 Telephone conference with M. Lovett re status; review Bishop
materials; review S. Massad letter; telephone conference with
S. Massad re same; draft email regarding Bishop claim.
07/24/09 B A Day 12.80 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
135
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 69 of 377
Page 68
Hours Description
same.
07/24/09 M A Gold 3.80 Draft and revise memorandum regarding Havell; attention to
comments from V. Kurylak; attention to REDACTED fund
transfer issues; review Beta and AI fund LP agreements and
related documents and attention to next steps; correspondence
with F. Quinlan and V. Kurylak.
07/24/09 J C Huddleston 3.40 Attention to coordinating translations for stipulated release of
accounts.
07/24/09 S A Massad 3.70 Drafted letter to SIPC and circulated; reviewed related
materials; various telephone conferences and e-mail
correspondence.
07/24/09 M G Myers 1.10 Attention to matters relating to requests from the Securities and
Exchange Commission with regard to Stanford Trust Company
customers.
07/24/09 J E Raley .20 Telephone conference with Sophia Lewis regarding
Leveridge/Lufkin trusts.
07/25/09 B A Day 12.60 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
07/25/09 M A Gold .40 Attention to V. Kurylak comments on Havell memorandum;
attention to correspondence.
07/25/09 M G Myers .80 Responded to emails and other inquires relating to Stanford
Trust Company customer accounts to be closed and transferred.
07/27/09 M A Gold 4.50 Attention to Havell correspondence and issues related to Havell
expenses; correspondence with V. Kurylak regarding same and
attention to issues raised; review Havell agreements and
invoices regarding same.
07/27/09 M G Myers 1.20 Attention to matters relating to the transfer of Stanford Trust
Company customer accounts.
07/28/09 M A Gold 5.10 Drafting resignation letters for Stanford GP; attention to issues
related to letters with C. Shipley and F. Quinlan;
correspondence with working group regarding same; revisions
to Havell memorandum regarding correspondence with Havell;
consider Havell documents and rights.
07/28/09 M G Myers 5.60 Attention to matters relating to the closing and transfer of
Stanford Trust Company customer accounts and matters
relating to the state of Louisiana's investigation into the
Stanford Trust Company.
136
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 70 of 377
Page 69
Hours Description
07/29/09 B A Day 6.00 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same.
07/29/09 M A Gold 1.20 Attention to GP resignation letter follow-up; correspondence
with working group regarding same.
07/29/09 M G Myers 3.90 Responded to inquiries made by Stanford Trust Company
customers; attention to matters relating to the closing and
transfer of Stanford Trust Company accounts and matters
relating to the bulk transfer of Stanford Group Company
customer accounts; conference call with the Securities and
Exchange Commission to discuss status of Stanford Trust
Company accounts.
07/30/09 T M Davis .30 Call with M. Lovett and V. Kurylak regarding account transfer
matter.
07/30/09 M A Gold 1.00 Attention to resignation letters and comments regarding same.
07/30/09 S A Massad 1.50 Revised draft letter to SIPC; reviewed related materials.
07/30/09 M G Myers 8.80 Conference with Malcolm Lovett and Tony Davis to discuss
REDACTED
; responded to inquiries from
Stanford Trust Company customers and Louisiana state
regulatory agencies; drafted letters to be sent to Stanford Trust
Company account holders; conference call with Kim Garber of
the SEC to discuss issues with regard to individual retirement
accounts at Stanford Trust Company to be closed and
transferred; attention to various matters relating to the closing
of customer accounts and distribution of account assets.
07/30/09 J E Raley 2.80 Office conference with Maggie Brown regarding matter;
research regarding North Carolina law and uniform trust law
regarding matter; review documents regarding same.
07/31/09 M A Gold 3.70 Correspondence with V. Kurylak, F. Quinlan regarding GP
resignations and finalization of resignation letters.
07/31/09 S A Massad 1.00 Revised SIPC letter and circulated to group.
07/31/09 M G Myers 8.40 Responded to inquiries from Stanford Trust Company
customers and Louisiana state regulatory agencies; drafted
letters to be sent to Stanford Trust Company account holders;
follow-up conference call with Kim Garber of the SEC to
discuss issues with regard to individual retirement accounts at
Stanford Trust Company to be closed and transferred; attention
to various matters relating to the closing of customer accounts
and distribution of account assets.
137
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 71 of 377
Page 70
Hours Description
07/31/09 J E Raley 2.50 Continued research regarding issue relating to
REDACTED ; office conference with Maggie Brown to
discuss findings and alternatives; review correspondence
regarding same.
08/03/09 M G Myers 7.30 Attention to various matters relating to Stanford Trust
Company and the brokerage accounts, including responding to
customer inquiries, responding to FINRA requests, insurance
matters relating to Stanford Trust Company and the Louisiana
Office of Financial Institutions and matters related to the
drafting motion to be filed in connection with
REDACTED
; conference with Bill Mollica regarding
issues related to Pershing and the transfer in bulk of customer
brokerage accounts.
08/04/09 M G Myers 8.60 Attention to matters relating to the transfer in bulk of accounts
REDACTED
; conference call with Mr. Kevin McKay, general counsel
of Dominick & Dominick LLC; conference with Mr. Kurylak
and Mr. Mollica of FITS, Inc. and Mr. F. Fram of Stanford
REDACTED ; attention to
miscellaneous production and other matters relating to the
Stanford Trust Company.
08/04/09 J E Raley .60 Review correspondence from Christy Lambertus regarding
matter; correspondence regarding same; office conference with
Maggie Brown regarding same; research regarding matter.
08/05/09 M W Brown 1.00 Conference with Jeff Raley regarding Farquhar trust and
Christy Lambertus' email; attention to response to Ms.
Lambertus; telephone conference with Sophia Lewis; telephone
conference with Tony Nardo regarding Dietz Domanski trust.
08/05/09 M A Gold 1.20 Attention to next steps on resignation and LP representation
letters; correspondence with working group regarding same.
08/05/09 M G Myers 7.80 Attention to matters relating to the transfer in bulk of accounts
REDACTED
; responded to inquiries from Stanford Trust Company
customers; responded to requests for documents and other
information from FINRA; responded to multiple requests for
documents and other information regarding Stanford Trust
Company from the Louisiana state attorney General's's office.
08/05/09 J E Raley 1.40 Continued work on Farquhar trust matter; review Florida law
regarding same; office conference with Maggie Brown
regarding suggested language involving parties; draft
correspondence to Christy Lambertus regarding matter; office
conference with Maggie Brown regarding comments regarding
138
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 72 of 377
Page 71
Hours Description
same; review and revise correspondence per comments.
08/06/09 M W Brown .50 Attention to Kilmer and Spencer Terry Trusts document status;
telephone conference with Keri Brown regarding Order
Appointing Successor Trustee for Deanna Kilmer Trust;
telephone conference with Sophia Lewis regarding Kilmer
trusts' successor trustee proceedings.
08/06/09 M G Myers 8.10 Prepared and worked on draft of motion to be filed with the
Court in connection with the bulk transfer of accounts
REDACTED ;
responded to Stanford Trust Company customer inquiries and
requests for documents and other information.
08/06/09 J E Raley .30 Correspondence with Christy Lambertus regarding Farquhar
trust matter.
08/07/09 M W Brown 5.00 Conference with Mike Myers regarding REDACTED
; attention to
revisions to separate versions of correspondence and related
correspondence regarding assignment of certificates of deposit
and related claims; worked on same, with several conferences
with Mike Myers; attention to Notice of Withholding and
Election regarding same for IRA cash distributions; discussed
and emails related to same with Mike Myers.
08/07/09 M G Myers 8.40 Attention to matters relating to the release of Stanford Trust
Company accounts and to the bulk transfer of accounts from
Stanford Group Company to another brokerage firm; finalized
account transfer agreement and the motion to be filed with the
court regarding same, and sent such documents to Ralph
Janvey and Kristie Blumenschein for review and final
approval; attention to various matters with FITS, Inc. relating
to the bulk account transfer and closing of Stanford Trust
Company accounts.
08/10/09 M W Brown 4.50 Attention to IRA questions, particularly with respect to
reporting and distribution matters; telephone conference with
John Coker; conference with Mike Myers; worked on
correspondence to account holders subject to withholding and
discussed same with Mike Myers, then emailed same to him;
telephone conference with Mike Myers and attention to his
emails; telephone conference with Sophia Lewis regarding
revised Order appointing successor trustee to Kilmer trust, and
attention to same by email; prepared email to Christy
Lambertus regarding Farquhar trust and service of process
question.
08/10/09 M G Myers 9.90 Attention to matters relating to the closing of Stanford Trust
Company accounts; finalized documents to be sent to
139
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 73 of 377
Page 72
Hours Description
customers and sent such documents to Kristie Blumenschein
for review and final approval; conference call with Mr. Lovett
to address closing of accounts; attention to various matters with
FITS relating to the bulk account transfer and closing of
Stanford Trust Company accounts.
08/11/09 M W Brown 6.00 Attention to email from Christy Lambertus regarding service of
process on Receiver, and responded to same; discussed
Farquhar matter with Stephanie Loomis-Price; attention to
Hazel Mearns Trust for William Klopman and related
appointment documents; attention to Mearns Will and related
probate filings; attention to Charitable Remainder Unitrust for
Anne L. Klopman; attention to North Carolina statutory law;
telephone conference with Sophia Lewis discussing Klopman
trust appointment questions; telephone conference with John
Coker regarding Selib trust account and attention to questions
in related email.
08/11/09 J C Huddleston .40 Assistance to Mike Myers on Motion to Transfer accounts as
requested.
08/11/09 M G Myers 9.60 Attention to matters relating to gathering of certain information
for the hearing to be held in Louisiana on August 17, 2009;
responded to inquiries made by Stanford Trust Company
customers; attention to matters relating to the transfer in bulk
of accounts REDACTED
, including gathering of information related to
costs savings related to transfer of accounts; updated
information to be sent and posted in relation to closing of
Stanford Trust Company accounts; responded to inquiries from
state regulators relating to brokerage and trust business and
various other matters.
08/12/09 C N Adams 1.40 Attention to Havell Capital Management issues; attention to
STC account transfer issues; reviewing documents regarding
same.
08/12/09 M W Brown 3.50 Telephone call to Bryan Calabrese of RBC Trust Company and
attention to Dietz Will trustee appointment provisions;
telephone conference with Charlene Francis regarding Bush
estate and regarding final income tax return for Bush charitable
remainder trust; telephone call to Bryan Calabrese; prepared
email to Bryan Calabrese regarding Dietz Domanski trust
provisions regarding appointment of successor trustees;
attention to email from Tony Nardo and discussed same with
Sophia Lewis.
08/12/09 M A Gold .80 Attention to correspondence regarding Stanford Havell matter;
attention to follow-up and questions from Havell attorneys.
140
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 74 of 377
Page 73
Hours Description
08/12/09 S A Massad 1.50 Attended to SIPC letter, STC issues, customer issues; various
telephone conferences and e-mail correspondence.
08/12/09 M G Myers 1.70 Attention to matters relating to closing of Stanford Trust
Company accounts and distribution of individual retirement
account assets; attention to inquiries and requests for
documents from various state agencies.
08/13/09 M W Brown 6.70 Attention to Peter B. Durham Marital Trust draft Beneficiaries'
Agreement and made notes regarding same; telephone
conference with S. Kornblitt reviewing same; attention to
Sherman trust document and related trustee appointment
documents; discussed with Sophia Lewis; arranged for
conference call with Tony Nardo and RBC Trust Company;
attention to Bush Charitable Remainder Trust questions and
telephone conference with Amy Kincaid regarding same;
attention to questions regarding Domanski successor trustee
appointment; reviewed Stanford acceptance documents
regarding original appointment; discussed same with Stephanie
Loomis-Price; telephone conference with Sophia Lewis;
telephone call to Tony Nardo; telephone conference with S.
Kornblitt and further attention to Beneficiaries' Agreement for
Peter B. Durham Marital Trust; attention to trust agreement for
Earle N. Cutler III Revocable Trust and related successor
trustee appointment documents.
08/13/09 M G Myers .60 Responded to Stanford Trust Company customer inquiries;
conference with Mr. Coker of FITS to discuss status of transfer
and closing of Stanford Trust Company customer accounts.
08/14/09 M W Brown 2.30 Telephone conference with Tony Nardo at RBC Trust
Company regarding Dietz Domanski Trust; two telephone
conferences with Elizabeth Fry, and sent email to Ms. Fry
regarding same; attention to questions regarding Bush
charitable remainder unitrust and prepared email to Amy
Kincaid regarding approval of appointment of successor
trustee; telephone conference with Amy Kincaid; telephone
conference with Tony Nardo regarding Margaret Domanski.
08/14/09 M G Myers 1.60 Responded to Stanford Trust Company customer inquiries;
conference call with Ms. Kim Garber of the Securities and
Exchange Commission; attention to various matters relating to
customer accounts.
08/15/09 M G Myers .60 Attention to matters relating to production of documents to the
Securities and Exchange Commission and other regulatory
agencies.
08/17/09 M W Brown 2.30 Telephone conference with Sophia Lewis; attention to new
Page trust documents; prepared email to Sophia Lewis
141
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 75 of 377
Page 74
Hours Description
regarding same; prepared email to Elizabeth Fry regarding
Dietz Domanski trust documents; attention to email from B.
Welch regarding Page trust; telephone conference with Sophia
Lewis.
08/17/09 M A Gold 2.50 Attention to Havell issues; call to Havell attorney;
correspondence with V. Kurylak and working group.
08/17/09 S A Massad .70 Reviewed SIPC letter; various telephone conferences and e-
mail correspondence regarding same.
08/17/09 M G Myers 2.90 Communicated with the Louisiana Attorney General's's office
and the Office of Financial Regulation for the State of Florida
regarding state investigations into Stanford Trust Company;
attention to general litigation matters relating to Stanford Trust
Company and suit filed in state of Louisiana; produced
documents for state of Louisiana investigators; attention to
matters relating to the closing of Stanford Trust Company
accounts.
08/18/09 M W Brown 3.70 Attention to new Bush documents received; telephone
conference with Sophia Lewis regarding same; telephone
conference with Betty Welch at Fifth Third Bank; telephone
conference with Rita Bishop regarding Peter B. Durham
Marital Trust and Encore Bank's's appointment as successor
trustee; telephone conference with Sophia Lewis regarding
third Klopman trust; attention to documents pertaining to Hazel
Mearns testamentary trust for William Klopman and telephone
conference with Edward Griggs regarding same; telephone
conference with Liz Fry regarding Dietz Domanski trust;
telephone conference with Sophia Lewis regarding Dietz
Domanski trust; reviewed file documentation and prepared
email to Liz Fry.
08/18/09 M A Gold .90 Discuss Havell issues with Havell counsel; attention to
correspondence.
08/18/09 M G Myers 3.40 Attention to matters relating to the transfer in bulk of Stanford
Group Company accounts and the related Negative Consent
letter; attention to matters relating to Stanford Trust Company
and state requests for information.
08/19/09 M W Brown 1.50 Telephone conference with Sophia Lewis regarding Page trust
documents; receipt and reviewed revised waiver/consent
document regarding Page trust; prepared email to Page parties
regarding same; telephone conference with Sophia Lewis;
attention to revised IRA correspondence and Receiver's
comments regarding same; discussed with Mike Myers.
08/19/09 S A Massad .50 Various e-mail correspondence regarding STC.
142
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 76 of 377
Page 75
Hours Description
08/19/09 M G Myers 6.10 Attention to matters relating to closing and distribution of
Stanford Trust Company individual retirement accounts;
drafted documents to be sent to customers in connection with
the closing of their accounts; worked on matters relating to the
brokerage accounts; responded to inquiries from various
regulatory agencies and Stanford Trust Company customers.
08/20/09 M W Brown 7.00 Worked on IRA Notice of Withholding and related Election, in
response to Receiver's comments to same; attention to related
tax regulations; discussed all of same with Mike Myers;
attention to new Russell Forrest trust documents, regarding
Maxine Miller Francis Forrest GST Nonexempt Trust fbo
Russell Hobson Forrest and Russell Hobson Forrest Irrevocable
Trust; telephone conference with Linda Walden in Whit Wilk's
office.
08/20/09 M G Myers 5.30 Attention to matters relating to closing and distribution of
Stanford Trust Company individual retirement accounts;
drafted documents to be sent to customers in connection with
the closing of their accounts; worked on matters relating to the
brokerage accounts; responded to inquiries from various
regulatory agencies and Stanford Trust Company customers.
08/21/09 M W Brown 1.00 Attention to email from attorney for Sandy Newland regarding
Cheyanne Newland trust; telephone conference with Sophia
Lewis and John Coker regarding Newland trust, Russell Forrest
trust, and Peter B. Durham Marital Trust matters.
08/21/09 M G Myers 6.70 Drafted form of negative consent letter to be sent to Stanford
Group Company customers in connection with the bulk transfer
of Stanford Group Company accounts; attention to other
matters relating to closing and distribution of Stanford Trust
Company individual retirement accounts; worked on matters
relating to the brokerage accounts; responded to inquiries from
various regulatory agencies and Stanford Trust Company
customers; discussions with the state of Louisiana (Attorney
General's's office and the Office of Financial Institutions)
regarding Stanford Trust Company; coordinated gathering of
documentation in response to subpoenas.
08/24/09 M W Brown 5.20 Telephone conference with Matt Larson regarding state
withholding matters; email exchanges with Mike Myers
regarding Withholding Notice and related Election form;
worked on matters, with related document review, regarding
Klopman, Newland and Russell H. Forrest trusts; telephone
conference with Edward Griggs; prepared email to Jo Brooks;
telephone conference with Elizabeth Gallagher; prepared email
to Elizabeth Gallagher regarding Newland trust; attention to
North Carolina statutes regarding REDACTED
;
143
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 77 of 377
Page 76
Hours Description
attention to Klopman trust questions; attention to Forrest trust
questions.
08/24/09 M G Myers 2.10 Finalized process by which documents will be sent to Stanford
Trust Company account holders to notify them of the closing of
their individual retirement accounts; conference with Mr.
Coker and Ms. Lewis of FITS to review final process and
documentation; attention to other matters relating to the closing
and transfer of customer accounts; gathered information for
Mr. Stutts relating to information produced to various Canadian
agencies.
08/25/09 M W Brown 3.50 Attention to appointment documents for the three Klopman
trusts, and attention to questions under applicable state law;
email exchanges with Edward Griggs addressing questions;
email to Jo Brooks; email to Sophia Lewis; several telephone
conferences with Sophia Lewis regarding numerous pending
matters; attention to IRA questions and discussed same with
John Coker.
08/25/09 M A Gold 1.80 Attention to correspondence with C. Shipley and working
group; attention to F. Quinlan executed version of documents.
08/25/09 M D Kusey 2.50 Researched and obtained mail from Receiver's correspondence
file REDACTED
; office conference with Mike Myers regarding
same.
08/25/09 M G Myers 2.60 Attention to matters relating to production of documents for
subpoena from the Florida Office of Financial Regulations;
responded to inquiries from Mr. John Little; reviewed and
gathered agreements between Stanford Trust Company and SEI
Private Trust Company in connection with recent litigation
naming Stanford Trust Company and SEI Private Trust
Company as defendants; revised documents to be sent to
customers whose accounts will be closed; attention to various
other matters relating to the release and closing of Stanford
Trust Company customer accounts.
08/26/09 M W Brown 1.50 Attention to questions regarding three Selib trusts, with related
document review for each.
08/26/09 M G Myers 4.30 Conference with the Florida Office of Financial Regulation
regarding subpoena production of documents; attention to
matters relating to the bulk transfer of accounts from Stanford
Group Company to Dominick and Dominick LLC, including
revisions to the Motion to Transfer Accounts and the Account
Transfer Agreement; responded to inquiries from Ms.
Blumenschein regarding the bulk transfer and related
documents; responded to inquiries from Mr. Little, the court-
144
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 78 of 377
Page 77
Hours Description
appointed Examiner; responded to inquiries from Stanford
Trust Company customers; communicated with Mr. McKay,
general counsel for Dominick and Dominick LLC, to discuss
the transfer of Stanford Group Company accounts.
08/27/09 M W Brown 5.50 Attention to Herbert J. Selib Trust documents (including
original revocable trust agreements, six amendments, and
amended and restated trust agreement), Dorothy M. Selib Trust
documents (including amended and restated trust agreement),
and Herbert J. Selib and Dorothy M. Selib Charitable
Remainder Unitrust trust agreement, related petition and court
orders regarding appointment of successor trustee, and
Oppenheimer acceptance instrument; telephone conference
with Rose-Ann Frano's office regarding questions; telephone
conferences and emails with Sophia Lewis regarding same;
discussed same with Stephanie Loomis-Price.
08/27/09 M A Gold .70 Attention to Havell question and correspondence.
08/27/09 M G Myers 2.30 Responded to inquiries from Mr. John Little, the court-
appointed examiner; revised Motion to Transfer Accounts to be
filed in connection with the bulk transfer of accounts from
Stanford Group Company to Dominick & Dominick LLC;
attention to various matters relating to the transfer of trust
accounts and individual retirement accounts at Stanford Trust
Company to successor trustees/custodians.
08/28/09 M G Myers 4.60 Responded to inquiries from Stanford Trust Company
customers regarding the closing of their individual retirement
accounts; attention to matters relating to document and other
information requests from the Louisiana Attorney General's's
office in connection with their criminal investigation into
Stanford Trust Company and its employees; attention to
matters relating to the filing of the Motion to Transfer
Accounts; conference with Mr. Dominick's (general counsel for
Dominick and Dominick) regarding the bulk transfer of
accounts.
08/29/09 M G Myers .70 Responded to inquiries relating to the release and transfer of
closed Stanford Trust Company accounts.
08/31/09 M W Brown 7.00 Attention to Eames trust questions; telephone conference with
Mike Myers; attention to judicial documents regarding the
three Selib trusts; two telephone conferences with Sophia
Lewis; conference with Mike Myers regarding IRA questions;
attention to Bernstein, Friedstein and Simon trust document
review; telephone conference with Rose-Ann Frano's office
regarding Selib trusts; prepared email to Mike Myers in
response to questions.
145
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 79 of 377
Page 78
Hours Description
08/31/09 M A Gold 2.20 Attention to negative consent letter issue; attention to
correspondence regarding same.
08/31/09 M G Myers 7.60 Conference call with the Louisiana Office of Financial
Institutions to discuss status of Stanford Trust Company;
conference call with Mr. McKay, general counsel of Dominick
& Dominick LLC, to discuss status of bulk transfer of accounts
from Stanford Group Company to Dominick & Dominick
LLC; responded to inquiries from Stanford Trust Company
customers and state regulatory agencies regarding customer
accounts; drafted and revised negative response letter REDACTED
; prepared responses to
multiple requests for information from Mr. Little, the court-
appointed Examiner, regarding the bulk transfer and negative
response letter; researched FINRA regulations REDACTED
Matter Total 1,409.10
079716.0106 Coin and Bullion Operations
Hours Description
06/01/09 M E Burnett .10 Searched for and provided corporate record for Stanford Coins
and Bullion at the request of David Arlington.
06/01/09 J T Leslie .30 Attended to development of the protocol process; telephone
conference with Craig Adams regarding the Protocol
Memorandum.
06/02/09 C N Adams .60 Reviewing coin and bullion protocol memorandum.
06/02/09 J A Cialone, II .50 Reviewed draft memos on Coins and Bullion.
06/02/09 J T Leslie .40 Attended to coin and bullion matters.
06/03/09 J T Leslie .40 Attended to coin and bullion matters.
06/04/09 J T Leslie 1.10 Telephone conference with Paul Montgomery regarding
disposition of estate coins and bullion; telephone conference
with Amy Kneeppel of FTI regarding REDACTED
; attended to other issues involving coins
and bullion.
06/05/09 J T Leslie .70 Revised the Protocol Memorandum; coordinated coins and
bullion protocol with FTI.
06/08/09 C N Adams .30 Reviewing coin and bullion customer claim.
06/08/09 J T Leslie .60 Telephone conference with Amy Kneeppel regarding coins and
bullion claims; telephone conference with Kevin Blake
146
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 80 of 377
Page 79
Hours Description
regarding .
REDACTED
06/09/09 C N Adams .20 Call with customer regarding coin and bullion claim.
06/09/09 J T Leslie .40 Telephone conference with Paul Montgomery regarding
.
REDACTED
06/10/09 J T Leslie .20 Coordinated for the coin and bullion protocol.
06/11/09 J T Leslie .20 Attended to coin and bullion coordination.
06/12/09 J T Leslie .30 Telephone conferences with Paul Montgomery and Craig
Adams regarding REDACTED .
06/15/09 J A Cialone, II .60 Reviewed coins and bullion memos in draft form; prepared for
coins meeting.
06/15/09 J T Leslie .60 Telephone conference with Paul Montgomery regarding the
coin and bullion protocol; reviewed the issues list from Kristie
Blumenschein regarding coins and bullion.
06/16/09 J T Leslie 1.80 Reviewed follow-up questions posed by Kristie Blumenschein
with respect to the Protocol Memorandum; conducted
additional research with respect to such follow-up questions;
attended to other coordination involving coins and bullion.
06/16/09 M G Myers .20 Coordination with coin and bullion team REDACTED
06/16/09 H C Tucker 3.40 Researched the ability of coin and bullion holders REDACTED
06/17/09 C N Adams .30 Telephone conference with Kevin Sadler regarding coin and
bullion protocol.
06/17/09 J A Cialone, II .80 Attention to coins matters.
06/17/09 J T Leslie .20 Reviewed correspondence related to claims and demands for
coins and bullion.
06/18/09 J T Leslie .50 Telephone conference with Craig Adams regarding coins and
bullion; attended to other coordination involving coins and
bullion.
06/18/09 M G Myers .10 Discussed status of coin operations with Paul Montgomery
REDACTED
06/19/09 M G Myers .10 Discussed status of coin operations with Paul Montgomery
REDACTED
147
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 81 of 377
Page 80
Hours Description
06/21/09 C N Adams 1.00 Reviewing coin and bullion protocol; preparing for meeting to
discuss same.
06/22/09 C N Adams 2.50 Reviewing coin and bullion protocol; telephone conference
with working group regarding issues relating to same;
researching issues regarding same; telephone conference with
Kevin Sadler regarding coin and bullion issues.
06/22/09 J A Cialone, II .40 Reviewed coin and bullion FAQ.
06/22/09 T M Davis .60 Conference call regarding coin and bullion dispositions.
06/22/09 J T Leslie 3.80 Telephone conference with the working group regarding coins
and bullion; telephone conference with Craig Adams and
Kevin Sadler regarding REDACTED
; telephone conference with Paul Montgomery
regarding the coins and bullion protocol.
06/23/09 C N Adams 1.10 Reviewing coin protocol response; telephone conference with
coin customer regarding claim; telephone conference with Tom
Leslie regarding coin protocol.
06/23/09 J T Leslie 1.80 Reviewed and revised the coin and bullion protocol proposed
by Kristie Blumenschein and Kevin Sadler; telephone
conference with Craig Adams regarding the coin and bullion
protocol.
06/24/09 C N Adams 1.70 Telephone conference with Tom Leslie regarding coin and
bullion protocol; revising memorandum regarding same;
telephone conference with SCB client regarding claim.
06/24/09 J A Cialone, II 1.20 Reviewed protocol for handling coins and bullion.
06/24/09 J T Leslie 1.90 Telephone conferences with Craig Adams regarding the coin
and bullion protocol.
06/25/09 C N Adams .40 Reviewing coin and bullion issues.
06/25/09 J A Cialone, II 1.00 Calls and emails about coins and bullion.
06/25/09 J T Leslie 1.60 Reviewed Kristie Blumenschein's draft of the protocol
summary; telephone conference with Paul Montgomery
regarding the sales practices of Stanford Coins and Bullion;
REDACTED
.
06/26/09 C N Adams .60 Telephone conference with working group regarding coin and
bullion protocol.
06/26/09 T M Davis .30 Call regarding protocol for coins.
06/26/09 J T Leslie 1.40 Telephone conference with Paul Montgomery REDACTED
.
148
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 82 of 377
Page 81
Hours Description
06/27/09 C N Adams .60 Telephone conference with Malcolm Lovett, Paul Montgomery
and Tom Leslie regarding issues regarding coin and bullion
sales.
06/27/09 J T Leslie .50 Telephone conference with Craig Adams, Malcolm Lovett and
Paul Montgomery REDACTED
06/29/09 J T Leslie .80 Coordinated for responses to coin and bullion demands and
requests for information; telephone conferences with Paul
Montgomery regarding demands and information requests;
telephone conference with Lori Kujawski regarding REDACTED
; telephone
conference with Kevin Blake regarding REDACTED .
06/30/09 C N Adams .50 Telephone conference with David Arlington and Tom Leslie
regarding coin and bullion litigation issues.
06/30/09 J T Leslie 1.60 Telephone conference with Loren Beck, counsel to SCB
customer, regarding coins and bullion; coordinated fact-finding
related to other coin and bullion demands and information
requests; telephone conference with Craig Adams and David
Arlington regarding litigation matters.
07/01/09 J T Leslie .20 Attended to coin and bullion matters.
07/02/09 C N Adams .30 Telephone conference with Malcolm Lovett regarding coin and
bullion protocol.
07/02/09 J T Leslie .30 Coordination for the Garciaparra request for information.
07/06/09 J A Cialone, II .90 Attention to coins and bullion issues.
07/06/09 J T Leslie 3.40 Coordinated the Garciaparra requests for information;
telephone conference with Paul Montgomery REDACTED
; revised the Protocol Memorandum and the
summary thereof; drafted a summary chart of the disposition of
Stanford Coins and Bullion.
07/07/09 C N Adams 1.90 Reviewing coin and bullion protocol; conference with Ralph
Janvey, Kristie Blumenschein and John Little regarding same;
reviewing research regarding same.
07/07/09 J A Cialone, II 1.20 Calls and emails about coins and bullion meeting both before
and after.
07/07/09 T M Davis 1.50 Prepare for call with R. Janvey and J. Little; call with R.
Janvey and J. Little.
07/07/09 J T Leslie 4.50 Revised the summary of SCB categories for submission to John
Little and the working group; REDACTED
; telephone conference with Paul Montgomery
regarding coins and bullion; telephone conference with John
149
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 83 of 377
Page 82
Hours Description
Little, Ralph Janvey and other members of the working group
with respect to the disposition of coins and bullion.
07/08/09 J T Leslie .50 Telephone conference with Paul Montgomery regarding SCB;
coordination for the order to release coins and bullion.
07/09/09 C N Adams .30 Telephone conference with coin customer regarding claim.
07/09/09 J T Leslie 4.40 Telephone conference with David Arlington regarding the
Release Order; drafted the Release Order; telephone conference
with Paul Montgomery REDACTED .
07/10/09 J T Leslie 5.60 Telephone conference with Paul Montgomery REDACTED
; telephone conference with Kristie
Blumenschein regarding the Release Order; drafted the Release
Order.
07/13/09 J T Leslie 6.90 Coordination for the REDACTED ; drafted the
Release Motion; telephone conferences with Craig Adams and
Kristie Blumenschein regarding the Release Motion.
07/14/09 J T Leslie 4.40 Drafted the Release Order; telephone conference with David
Arlington regarding the Release Motion.
07/15/09 J T Leslie .30 Review of claims related to coins and bullion; review of the
Release Motion.
07/16/09 C N Adams .70 Reviewing draft coin and bullion motion; telephone conference
with Tom Leslie regarding same.
07/16/09 J T Leslie 2.00 Drafted the Release Motion.
07/17/09 C N Adams .30 Reviewing issues regarding coin and bullion motion.
07/17/09 J T Leslie 1.40 Drafted the Release Motion;
07/17/09 N M Starbuck .70 Spoke with P. Montgomery REDACTED
.
07/19/09 J T Leslie 3.60 Drafted the Release Motion.
07/20/09 C N Adams .40 Reviewing revisions to coin and bullion motion.
07/20/09 J T Leslie 1.00 Coordination of coins and bullion demands; drafted letter to the
New Mexico Attorney General regarding coin and bullion
claims; reviewed comments to the Release Motion.
07/21/09 C N Adams .30 Reviewing revised coin and bullion motion.
07/21/09 J T Leslie 4.50 Drafted the Release Motion; coordination with respect to New
Mexico Attorney General claim.
07/22/09 J T Leslie 1.60 Review of coin and bullion demands; coordination for the
Release Motion; drafted the Release Motion.
150
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 84 of 377
Page 83
Hours Description
07/23/09 C N Adams .30 Reviewing revised motion.
07/23/09 J A Cialone, II 1.30 Attention to coins an bullion issues, including draft motion, and
related calls and emails.
07/23/09 J T Leslie 1.70 Drafted the Release Motion; telephone conference with Kristie
Blumenschein.
07/24/09 C N Adams .40 Reviewing revisions to motion.
07/24/09 J T Leslie 1.80 Drafted the Release Motion.
07/25/09 J T Leslie 1.50 Drafted the Release Motion.
07/26/09 J T Leslie 1.70 Drafted and revised the Declaration of Paul Montgomery as
related to the Release Motion.
07/27/09 J T Leslie 1.50 Drafted the Release Motion and the Declaration of Paul
Montgomery; telephone conference with Paul Montgomery
with respect to the Release Motion.
07/28/09 J T Leslie 1.50 Drafted the Release Motion; telephone conferences with Paul
Montgomery and Kristie Blumenschein with respect to the
Release Motion and special data requested by the Examiner;
telephone conferences with David Arlington and Andrew York
regarding the Release Motion.
07/29/09 J T Leslie 6.00 Telephone conferences with Paul Montgomery and Kristie
Blumenschein regarding Release Motion; drafted the Release
Motion; conducted fact-finding and drafted the report for the
Examiner regarding individuals in each coin category;
coordination for filing of the Release Motion.
07/30/09 J T Leslie .90 Telephone conference with Paul Montgomery regarding coins
and bullion and their release; telephone conference with Loren
Beck, counsel to the Garciaparras, regarding coins and bullion
claims; attended to other coin and bullion matters.
08/04/09 C N Adams .50 Telephone conference with client regarding coin and bullion
claim.
08/05/09 C N Adams .50 Reviewing coin and bullion claims.
08/06/09 C N Adams .60 Reviewing claim regarding coins and bullion; telephone
conference with claimant's counsel regarding same.
08/07/09 C N Adams .60 Telephone conference with coin customer regarding claim;
telephone conference with Tom Leslie regarding same.
08/07/09 J T Leslie .30 Telephone conference with Paul Montgomery regarding release
of coins and protocols therefore.
08/10/09 C N Adams .40 Reviewing client inquiries regarding coin claims.
151
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 85 of 377
Page 84
Hours Description
08/10/09 J T Leslie .30 Telephone conferences with David Arlington and Karina
Vargas with respect to motions filed by Benton and
Mothershead.
08/11/09 C N Adams .40 Reviewing inquiries regarding coin claims; attention to motion.
08/11/09 J T Leslie .40 Review of Dillon Gage production request and interrogatories;
telephone conference with David Arlington regarding the
production requests.
08/12/09 J T Leslie .90 Telephone conferences with David Arlington and Paul
Montgomery regarding Dillon Gage litigation.
08/13/09 J T Leslie .20 Responded to Release Motion inquiries.
08/14/09 C N Adams .90 Telephone conference with Charlie Baker regarding customer
claim regarding coins; telephone conference with Wanda
Peterson regarding coin claim.
08/14/09 J T Leslie .40 Research and email response to Release Motion inquiries.
08/16/09 J A Cialone, II .20 Emails about coins and bullion motion.
08/17/09 C N Adams .80 Telephone conference with Paul Montgomery regarding
outstanding customer claims.
08/17/09 J T Leslie .40 Drafted a response to Release Motion inquiries; telephone
conference with Paul Montgomery REDACTED
08/19/09 C N Adams .60 Reviewing claims presented by coin customers; reviewing
motion analysis regarding same.
08/19/09 J A Cialone, II .80 Attention to coins issues.
08/19/09 J T Leslie .10 Responses to Release Motion inquiries.
08/21/09 C N Adams .40 Reviewing Joe Frisard correspondence and related issues.
08/21/09 J T Leslie 1.20 Telephone conference with Paul Montgomery regarding
REDACTED ; responded to Release
Motion Inquiries.
08/22/09 C N Adams .40 Reviewing examiner questions regarding coin and bullion
claims.
08/24/09 C N Adams .40 Reviewing claims regarding coins and bullion.
08/24/09 J T Leslie .30 Responded to Release Motion inquiries.
08/25/09 J T Leslie .30 Responded to Release Motion Inquiries.
08/27/09 J T Leslie .20 Responded to Release Motion Requests.
08/28/09 J T Leslie .10 Responded to Release Motion inquiries.
152
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 86 of 377
Page 85
Hours Description
08/31/09 C N Adams .50 Telephone conference with Tom Leslie regarding coin and
bullion claims; reviewing materials regarding same.
08/31/09 J A Cialone, II .90 Reviewed emails and drafted letter related to coins and bullion;
related calls and emails.
08/31/09 J T Leslie .40 Research and responses with respect to Release Motion
inquiries.
Matter Total 126.30
079716.0107 Document Production Matters
Hours Description
06/01/09 C N Adams .40 Telephone conference with Chad Nunez regarding DOJ
requests.
06/01/09 M C Hurd 9.50 Drafted and revised production letters to FBI and DOJ tax
division; reviewed prior FBI and SEC productions for
document provided by FTI to Bob Howell; coordinated
preparation and production of documents and information for
FBI production; phone call and corresponded with Craig
Adams and corresponded with Kevin Sadler, Richard Husseini,
and Gail Foster regarding upcoming production to DOJ tax
division; phone calls and corresponded with Mark Schwartz in
litigation support regarding same; coordinated preparation of
documents and information for DOJ production; reviewed
reports of files processed and unable to be processed from
Failing CDs; corresponded with Gary Osborn regarding DOJ
criminal fraud division request; revised and updated FBI
production worksheet.
06/01/09 J T Leslie .70 Telephone conference with Malcolm Lovett regarding
document storage; telephone conference with Todd Grey
regarding document storage.
06/01/09 N M Starbuck 1.80 Prepared memo re: REDACTED
;
revised production log.
06/01/09 N M Starbuck 2.20 Reviewed and indexed SFG TPC presentations to facilitate FBI
request.
06/02/09 C N Adams 1.30 Telephone conference with DOJ production issues; telephone
conference with Karyl Van Tassel regarding same; conference
with Tom Keltner regarding witness interviews.
06/02/09 J A Cialone, II .50 Calls and emails about DOJ requests for access to FTI
personnel and materials.
153
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 87 of 377
Page 86
Hours Description
06/02/09 J G Foster 1.20 Attention to preparation of electronic data production to DOJ,
format and associated costs; reviewed and responded to
communications regarding employee missing laptop issues.
06/02/09 M C Hurd 4.30 Drafted and revised production letter to DOJ tax division;
coordinated preparation of documents and information for DOJ
production; corresponded with Craig Adams, phone call with
Mark Kusey, and office conferences with Gail Foster regarding
same; revised and updated government entities' production log;
corresponded with Juan Martinez regarding additional contact
information for Stanford employee missing computer letter;
corresponded with Craig Adams regarding context for other
Stanford employee's missing computer.
06/02/09 N M Starbuck 4.20 Reviewed and indexed SFG TPC presentations to facilitate FBI
request
06/03/09 C N Adams .50 Telephone conference with Allan Medina regarding DOJ
requests.
06/03/09 M C Hurd 6.90 Drafted and revised production letter to FBI; coordinated
preparation and production of electronic materials for FBI
production; office conference with Gary Osborn regarding DOJ
request; revised and updated government entities' production
log; reviewed correspondence regarding address for Stanford
employee missing computer letter; revised and updated FBI
production work sheet; office conference with Chad Nunez
regarding FBI and DOJ productions recently sent by email;
corresponded and phone call with Craig Adams regarding
documents for DOJ production; reviewed report REDACTED
; coordinated preparation of same documents for
IRS audit team on behalf of DOJ request; revised and
circulated list of and notes on outstanding government entities'
requests; corresponded with Craig Adams and Jim Scarazzo
regarding calendar documents for FBI request.
06/03/09 J T Leslie .30 Telephone conference with counsel to Iron Mountain REDACTED
.
06/03/09 N M Starbuck 2.80 Assisted Marisa Hurd with preparing production materials for
Chad Nunez (FBI).
06/04/09 C N Adams .70 Telephone conference with DOJ regarding victim's assistance
issues; reviewing broker calendar for production.
06/04/09 J C Huddleston 3.40 Assembled and prepared documents for production to the FBI.
06/04/09 M C Hurd 8.20 Coordinated preparation of documents and electronic materials
for DOJ production; reviewed password-protected documents
from Harry Failing production; corresponded with Failing's
154
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 88 of 377
Page 87
Hours Description
attorney regarding additional files missing passwords;
coordinated preparation of same documents for IRS audit team
on behalf of DOJ request; office conferences with Jeff
Ferguson, Mark Russell, and Shawn Giles regarding recent FBI
requests; reviewed production set and file for same; worked
with Russell and Giles regarding document search;
corresponded with Craig Adams, Karyl Van Tassel, Ferguson,
and Russell regarding recent FBI requests; reviewed calendar
documents provided by Jim Scarazzo for FBI request; office
conference with Mike Myers regarding receiver
correspondence issue; reviewed production set for recent
correspondence from Andrea Stoelker's counsel to receiver.
06/04/09 J T Leslie .40 Coordination for FBI document production requests.
06/04/09 N M Starbuck 3.90 Prepared Jason Green's exchange email calendar for production
to the FBI; prepared J. Davis emails for production to FBI and
DOJ; assisted M. Hurd with locating materials requested by C.
Nunez, FBI.
06/04/09 N M Starbuck .50 Updated production log and receivership file.
06/05/09 C N Adams .80 Telephone conference with FBI regarding document
production requests; reviewing materials regarding same.
06/05/09 J G Foster .90 Attention to handling of certain electronic data, media and
equipment held by FTI, and conferred with C. Adams
regarding same; prepared email memo to C. Adams regarding
plan and coordination with FTI.
06/05/09 J C Huddleston 4.10 Assembled and prepared documents for production to the FBI.
06/05/09 M C Hurd 6.90 Drafted and revised production letter to DOJ tax division;
coordinated preparation and production of documents and
electronic materials for DOJ production; prepared password-
protected documents from Harry Failing production and
circulated to IRS audit team on behalf of DOJ; reviewed
documents provided by Mark Russell for FBI request;
corresponded with Karyl Van Tassel, Jeff Ferguson, and
Russell regarding FBI request; reviewed calendar documents
provided by Jim Scarazzo for FBI request; corresponded with
IRA audit team on behalf of DOJ regarding DOJ production;
corresponded with Richard Husseini, Kevin Sadler, and Craig
Adams regarding status of Harry Failing documents and
availability for outside review; coordinated preparation of same
for review.
06/05/09 M D Kusey .50 Prepared scan of Failing documents for production and sent the
same to Marisa Hurd.
06/05/09 N M Starbuck 4.10 Produced to the DOJ items scanned by IRS Audit team from
155
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 89 of 377
Page 88
Hours Description
Harry Failing boxes; prepared RAS exchange e-mail calendar
for production to FBI/DOJ; bates and FOIA labeled cash
reports and SIBL statements in response to FBI request.
06/05/09 N M Starbuck .70 Updated Receivership file and production log.
06/06/09 C N Adams .40 Telephone conference with Chad Nunez regarding production
issues.
06/07/09 J A Cialone, II .80 Attention to Stanford subpoena and related issues; other
document production calls and emails.
06/08/09 C N Adams .30 Attention to FBI production request.
06/08/09 J G Foster .50 Conferred with C. Adams regarding proposal for handling
media and computer equipment; conferred with J.
Scarazzo/FTI regarding status of various media and computer
equipment held by FTI and plans for handling same.
06/08/09 J C Huddleston 3.70 Assembled and prepared documents for production to the FBI.
06/08/09 M C Hurd 7.30 Prepared password-protected documents from Harry Failing
production and recirculated to IRS audit team on behalf of
DOJ; reviewed calendar documents provided by Jim Scarazzo
for FBI request; corresponded with Richard Husseini, Kevin
Sadler, and Craig Adams regarding status of Harry Failing
documents and availability for outside review; coordinated
preparation of same for review; phone call and corresponded
with Harrison Tucker and Adams regarding FBI request;
reviewed corporate books for FBI request; coordinated
preparation of documents and information for FBI production;
corresponded with Tim Durst regarding revising draft response
to Stanford's motion to compel.
06/08/09 M D Kusey 1.70 Reviewed Failing boxes; office conference with Marisa Hurd
regarding the same.
06/08/09 J T Leslie .40 Drafted and submitted a summary of efforts regarding FBI
document request to Craig Adams.
06/08/09 N M Starbuck 3.70 Prepared Jason Green's calendar for production to FBI; at the
request of C. Adams reviewed content of SIBL board minutes
and prepared for production to FBI.
06/08/09 N M Starbuck 2.10 Reviewed and indexed SFG media presentations for
compliance with FBI request.
06/09/09 J G Foster .70 Prepared memo to J. Scarazzo/FTI regarding handling of
certain media and computer equipment.
06/09/09 J C Huddleston 5.40 Reviewed previously produced documents and logs at the
direction of Marisa Hurd in connection with R. Allen Stanford
156
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 90 of 377
Page 89
Hours Description
requests.
06/09/09 M C Hurd 11.30 Reviewed Stanford's motion to compel; coordinated review of
all produced documents and file for documents responsive to
Stanford's requests for production; office conferences with Jeff
Ferguson and Gary Osborn regarding responsive documents for
same; reviewed and revised draft response to Stanford's motion
to compel and circulated same to team; drafted and revised
spreadsheet detailing potential responses to Stanford's requests
for production; phone call and corresponded with Postal
Inspector Clayton Gerber regarding information provided in
DOJ production; reviewed and corresponded with Adams
regarding latest FBI request letter.
06/09/09 N M Starbuck 5.90 Assisted M. Hurd with facilitating RAS attorney request by
locating requested materials, drafting response log, and
organizing exhibits.
06/10/09 C N Adams .50 Telephone conference with Chad Nunez regarding potential
claims.
06/10/09 J A Cialone, II .40 Calls and emails about document production protocol and
processes.
06/10/09 J G Foster .50 Reviewed S. Lindstrom email and warehouse equipment
insurance coverage documentation; conferred with S.
Lindstrom regarding media and computer equipment to be
delivered by FTI for storage at Houston warehouse.
06/10/09 M C Hurd 7.00 Coordinated review and preparation of documents and
electronic materials responsive to Stanford's requests for
production; office conferences with Jeff Ferguson and Shawn
Giles regarding responsive documents for same; reviewed and
revised draft response to Stanford's motion to compel and
circulated same to team; revised spreadsheet REDACTED
; reviewed and
corresponded with Craig Adams regarding latest FBI request
letter; corresponded and office conferences with Benie George
regarding FBI requests.
06/10/09 J T Leslie .90 Drafted letter of release for documents being stored at Iron
Mountain; coordinated for release of documents being stored at
Iron Mountain.
06/10/09 N M Starbuck 4.10 Assisted M. Hurd with facilitating RAS attorney request by
analyzing previously produced materials and preparing
productions for duplication; prepared redbook financial
statements for production to FBI.
06/11/09 J A Cialone, II 1.00 Attention to draft response to Motion to Compel; related calls
and emails; reviewed documents and considered alternative
157
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 91 of 377
Page 90
Hours Description
strategies to document production fights.
06/11/09 J C Huddleston .70 Reviewed Redbooks at the direction of Marisa Hurd for FBI
request.
06/11/09 M C Hurd 5.10 Drafted and revised production letter to FBI; coordinated
preparation of documents and information for FBI production;
corresponded with team regarding response to Stanford's
motion to compel; phone call and corresponded with Tim Durst
and Jennifer Adams regarding same and categories of
documents available for review; drafted and revised
documents-related section of response to Stanford's motion to
compel.
06/11/09 N M Starbuck 4.40 Prepared cash summary reports, Memphis analyst's weekly
reports, and SIBL meeting minutes for production to FBI; bates
and FOIA labeled redbook financial statements for production
to FBI; located most current financial statements at the request
of the FBI.
06/11/09 N M Starbuck .50 Re-filed FBI requested items into Receivership log.
06/12/09 J G Foster .10 Conferred with C. Adams regarding status of warehouse
equipment insurance coverage.
06/12/09 M C Hurd 3.00 Drafted and revised production letter to FBI; coordinated
preparation of documents and information for FBI production;
corresponded with Craig Adams regarding FBI requests;
coordinated preparation of St. Croix items for turnover to
Stanford's counsel; reviewed file for documents to assist New
York firm involved in private equity investment management;
revised and updated log REDACTED
06/12/09 J T Leslie .10 Coordination for FBI production request.
06/15/09 C N Adams .30 Reviewing production request.
06/15/09 J G Foster .30 Follow up with J. Scarazzo/FTI regarding status of research
and handling of computer equipment and media.
06/15/09 M C Hurd 1.10 Corresponded with IRS audit team on behalf of DOJ;
performed inquiry into certain non-viewable files from Harry
Failing production CD; corresponded with litigation support
regarding same; corresponded with Craig Adams regarding
Stanford employees' responses to Receiver's request for their
missing laptops.
06/15/09 N M Starbuck .90 Reviewed SGC media materials to facilitate FBI request.
06/16/09 M C Hurd 2.10 Corresponded with IRS audit team on behalf of DOJ;
performed inquiry into certain nonviewable files from Harry
158
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 92 of 377
Page 91
Hours Description
Failing production CD; corresponded with litigation support
regarding same; corresponded with Craig Adams regarding FBI
request; drafted and revised production letter to FBI;
coordinated preparation of documents and information for FBI
production; reviewed update from Tom Leslie regarding FBI
request.
06/16/09 J T Leslie 1.10 Telephone conference with Steve Lindstrom regarding the FBI
document production request; coordinated final release of the
Iron Mountain documents; researched and compiled the status
of a response to an FBI document production request and
submitted to Craig Adams.
06/16/09 N M Starbuck 1.70 Assisted FTI in preparation for meeting with DOJ.
06/17/09 C N Adams 1.60 Telephone conference with Karyl Van Tassel and Jeff
Ferguson regarding DOJ testimony issues; reviewing materials
for production.
06/17/09 M C Hurd 1.50 Reviewed calendar documents for FBI request; drafted and
revised production letter for FBI; coordinated preparation of
documents and information for FBI production; corresponded
with Jeff Ferguson regarding DOJ/FBI meeting.
06/17/09 J T Leslie .20 Coordinate release of Iron Mountain documents.
06/17/09 N M Starbuck 2.00 Prepared Jason Green's email exchange calendar for production
to FBI.
06/18/09 C N Adams 2.30 Telephone conference with Louisiana Attorney General
regarding document production issues; reviewing DOJ
production requests; telephone conference with Chad Nunez
regarding pending requests.
06/18/09 J A Cialone, II .80 Meetings, calls and emails throughout the day with Receiver
and various team members concerning document protocol and
production.
06/18/09 M C Hurd 1.70 Drafted and revised production letter to FBI; coordinated
preparation and production of documents and information to
FBI; phone call with Chad Nunez regarding FBI requests;
phone calls and corresponded with Jeff Ferguson and Karyl
Van Tassel regarding FBI requests and production status of
documents to FBI and SEC; corresponded with Shawn Giles
and reviewed voicemail from Mark Russell regarding FBI
requests.
06/18/09 J T Leslie .20 Coordinated Iron Mountain document retrieval.
06/18/09 M G Myers .20 Attention to matters relating to response to state regulatory
subpoenas and production of documents.
159
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 93 of 377
Page 92
Hours Description
06/18/09 N M Starbuck 4.30 Produced redbook financial statements, SIBL Board of
Director meeting minutes, and weekly statements for SIB,
Bank of Antigua, and Panama to FBI; assisted C. Nunez with
preparation for meeting with DOJ.
06/19/09 C N Adams 1.00 Reviewing document production requests; telephone
conference with government regarding outstanding request.
06/20/09 J A Cialone, II 1.10 Calls and emails about FTI's responses to requests from
government; considered same.
06/22/09 C N Adams .30 Attention to SEC request for email production.
06/22/09 M C Hurd 3.30 Corresponded with litigation support regarding password-
protected files from Harry Failing production for request from
IRS audit team on behalf of DOJ; coordinated preparation of
information and documents for FBI production; drafted FBI
production worksheet; revised and updated FBI production log;
drafted and revised production letters for FBI.
06/22/09 N M Starbuck 4.00 Prepared June 2008 Foreign and Domestic Redbooks for
production to the FBI; updated production log.
06/23/09 J G Foster .30 Conferred with J. Scarazzo regarding status of computer
equipment and media delivery for long term storage.
06/23/09 J C Huddleston 8.70 Assembled and prepared documents for production to the states
of Massachusetts and Pennsylvania in connection with
requests.
06/23/09 M C Hurd 2.30 Coordinated preparation of documents and information for
state requests and productions; reviewed and revised
government production log.
06/23/09 M G Myers 4.10 Attention to matters relating to response to state regulatory
subpoenas and production of documents.
06/23/09 N M Starbuck 6.60 Prepared SIBL marketing materials, SFGC policy and
procedure manuals, and account holder information for frozen
accounts for production to Massachusetts and Pennsylvania.
06/24/09 C N Adams 1.90 Telephone conference with Chad Nunez regarding document
requests; attention to FBI and SEC production issues;
reviewing production materials.
06/24/09 J G Foster .70 Reviewed materials from Stanford Dallas office delivered by
Thompson & Knight and conferred with C. Adams regarding
same; forwarded materials to C. Adams for review.
06/24/09 J C Huddleston 5.90 Assembled and prepared documents for production to the states
of Massachusetts and Pennsylvania in connection with
requests; quality-checked same.
160
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 94 of 377
Page 93
Hours Description
06/24/09 M C Hurd .80 Reviewed document provided by Gail Foster for possible
production to FBI and SEC; office conference with Foster
regarding documents located in Dallas office closure.
06/24/09 J T Leslie .30 Attended to issues involving the Iron Mountain documents;
telephone conference with Gail Foster regarding additional
documents from the Dallas office.
06/24/09 N M Starbuck 4.30 Prepared account statements and policy manuals for production
to Massachusetts and Pennsylvania; prepared SAS account
statements for production to Massachusetts.
06/25/09 C N Adams 1.50 Attention to SEC email production request; telephone
conference with Chad Nunez regarding additional FBI
requests; attention to same.
06/25/09 J C Huddleston 4.10 Assembled and prepared documents for production to the state
of Louisiana; updated and/or managed state of Pennsylvania
and Oklahoma production files.
06/25/09 M C Hurd 1.30 Coordinated preparation of documents and information for FBI
production; coordinated preparation and production of
documents for SEC production; drafted and revised production
letters to FBI and SEC; corresponded with Craig Adams
regarding production issues.
06/25/09 J T Leslie .60 Office conference with John Greer regarding documents from
Columbia; coordinated to receive and to file documents from
Columbia.
06/25/09 J T Leslie .20 Telephone conference with Craig Adams regarding passports
and other documents requested by Stanford Defendants and
affiliates.
06/25/09 N M Starbuck 4.00 Prepared 2006 SGC Wire Transfer Log for production to FBI
and SEC; Located foreign and domestic redbooks to facilitate
FBI request; quality-checked Pennsylvania production request;
at the request of M. Myers prepared documents for production
to Pennsylvania, Massachusetts, Louisiana, and Oklahoma;
prepared redbook for production to FBI.
06/26/09 C N Adams .90 Telephone conference with Tom Leslie regarding passports;
telephone conference with Steve Lindstrom regarding same.
06/26/09 C N Adams .40 Telephone conference with Chad Nunez regarding FBI
production requests.
06/26/09 J G Foster .20 Attention to emails regarding handling of materials received
from Stanford Bogota office.
06/26/09 M C Hurd 2.90 Drafted and revised production letters to DOJ and SEC;
coordinated preparation of electronic materials for SEC
161
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 95 of 377
Page 94
Hours Description
production; corresponded with Craig Adams, Jeff Ferguson,
and Karyl Van Tassel regarding DOJ request; corresponded
with Jim Scarazzo regarding SEC request; corresponded with
Adams regarding production issues.
06/26/09 J T Leslie 3.10 Coordinate Iron Mountain document release; telephone
conferences with Craig Adams with respect to the Stanford
Defendants passports; coordination and fact-finding with
respect to the Stanford Defendants passports.
06/26/09 N M Starbuck 3.30 Prepared evidence of recent productions for transmittal to
Securities and Exchange Commission FOIA officer; prepared
most recent completed redbooks for production to the FBI;
prepared FA Commission Structure manual for production to
Pennsylvania.
06/29/09 C N Adams .30 Reviewing production to SEC of financial advisor emails.
06/29/09 J G Foster .90 Conferred with M. Hurd regarding Dallas office delivery;
conferred with J. Scarazzo/FTI regarding status of computer
equipment and media; conferred with M. Lovett and R. Davis
regarding REDACTED
.
06/29/09 J C Huddleston 5.50 Assembled and prepared documents for production to
Pennsylvania and Massachusetts.
06/29/09 M C Hurd 4.60 Coordinated production of electronic materials to SEC; updated
and revised government production worksheets; corresponded
with Jeff Ferguson regarding DOJ request; corresponded with
Adams regarding items of interest; corresponded with Ferguson
regarding wire transfer document produced; office conferences
with Mike Myers regarding procedure for production of
electronic materials; drafted and revised production letters to
FBI; corresponded with Gail Foster regarding chain of custody
of Dallas office closure documents.
06/29/09 J T Leslie .20 Coordinated for documents to be delivered to Stanford
Defendants and affiliates.
06/29/09 M G Myers 6.70 Attention to matters relating to response to state regulatory
subpoenas and production of documents.
06/29/09 N M Starbuck 5.40 Prepared supervisory, compliance, and policy manuals for
production to Pennsylvania; logged and filed PST emails for
custodian L. Schaufele; prepared redbooks for production to
FBI.
06/30/09 J G Foster .80 Conferred with C. Adams regarding additional documents for
review, and attention to same; conferred with R. Davis
162
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 96 of 377
Page 95
Hours Description
regarding status of boxes for Baker Botts review, and arranged
for H. Tucker review.
06/30/09 J C Huddleston 5.00 Assembled and prepared documents for production to
Pennsylvania and Massachusetts; quality-checked documents
for production to Pennsylvania and Massachusetts.
06/30/09 M C Hurd 5.00 Coordinated preparation of information and documents for FBI
production; drafted and revised production letters to FBI;
reviewed documents provided by Jeff Ferguson and Shawn
Giles for DOJ request; corresponded with Giles regarding DOJ
request; updated and revised log of REDACTED
; updated and revised
government production log; updated and revised list of
outstanding government requests.
06/30/09 M G Myers 1.10 Attention to matters relating to response to state regulatory
subpoenas and production of documents.
06/30/09 N M Starbuck 5.00 Quality-checked Pennsylvania production request; at the
request of M. Myers prepared account statements and SFGC
policy and procedure manuals for production to Pennsylvania.
07/01/09 C N Adams .80 Attention to production of identification materials.
07/01/09 M C Hurd 1.80 Coordinated preparation of information and documents for FBI
production and DOJ criminal division production; drafted and
revised production letters to FBI and DOJ; reviewed
documents provided by Shawn Giles for DOJ request;
corresponded with Giles regarding DOJ request; phone calls
and corresponded with Craig Adams and Tom Leslie regarding
file issues.
07/01/09 N M Starbuck 1.00 Prepared documents for production to Oklahoma Department
of Securities.
07/02/09 J G Foster 1.80 Reviewed report from J. Scarazzo/FTI regarding status of
computer hardware and electronic media being maintained by
FTI, and transfer of certain items to long term storage;
reviewed and confirmed transfer documentation provided by J.
Scarazzo; reviewed additional spreadsheet reports provided by
J. Scarazzo vis a vis additional items, and forwarded to C.
Adams for review.
07/02/09 M C Hurd .90 Coordinated preparation of information and documents for FBI
production and DOJ criminal division production; drafted and
revised production letters to FBI and DOJ.
07/02/09 J T Leslie .40 Coordinate the release of Iron Mountain documents and other
document storage matters.
163
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 97 of 377
Page 96
Hours Description
07/02/09 M G Myers 2.90 Attention to matters relating to production of documents
pursuant to various state subpoenas and document requests.
07/02/09 N M Starbuck 2.70 Prepared R. Allen Stanford's Antigua and Barbados Diplomatic
Passport and REDACTED
for production to the FBI and DOJ.
07/04/09 J A Cialone, II .60 Attention to DOJ request for information.
07/06/09 C N Adams .40 Telephone conference with David Fraser regarding review of
compliance records; reviewing materials regarding same.
07/06/09 M C Hurd 10.90 Corresponded with Craig Adams regarding FBI request;
corresponded with Chad Nunez regarding status of FBI/DOJ
productions; coordinated preparation and production of
information and documents to DOJ and FBI; reviewed RAS
and Stoelker St. Croix boxes to determine additional boxes to
release; phone call with Adams and office conferences and
corresponded with Steve Lindstrom regarding same; office
conferences with Paul Montgomery regarding jewelry items
from same; coordinated preparation of chains of custodies and
inventories for released boxes.
07/06/09 J T Leslie .60 Coordinated storage of documents held by Forefront and other
storage and production issues; telephone conference with John
Greer regarding Forefront documents.
07/06/09 M G Myers .80 Responded to emails from and communicated with various
state regulatory agencies regarding document and information
requests.
07/06/09 N M Starbuck 1.10 Provided to C. Nunez items requested for production by the
FBI and DOJ.
07/07/09 C N Adams .30 Telephone conference with Malcolm Lovett regarding
compliance records for SEC review.
07/07/09 M G Myers .80 Responded to emails from and communicated with various
state regulatory agencies regarding document and information
requests.
07/07/09 N M Starbuck 2.10 Requested employee directories for Stanford Group Company
and Stanford Trust Company to facilitate the production
request of the Louisiana DOJ Special Prosecutions Unit;
coordinated production of documents requested by the State of
Louisiana.
07/08/09 C N Adams 1.50 Reviewing organization charts for production to SEC and
Louisiana Attorney General's's office; reviewing issues
regarding production of passports; telephone conference with
Joe Cialone regarding same; telephone conference with David
164
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 98 of 377
Page 97
Hours Description
Fraser and Malcolm Lovett regarding review of compliance
records.
07/08/09 J G Foster .30 Reviewed H. Tucker report regarding review of Y. Suarez
boxes and specified documents.
07/08/09 M C Hurd 4.80 Coordinated preparation and production of information and
documents to FBI and SEC; corresponded with Craig Adams
and Mike Myers regarding documents for SEC request and LA
attorney general request; corresponded with Adams, Myers,
and Jim Scarazzo regarding MS Secretary of State electronic
data request; phone call with Chad Nunez and corresponded
with Adams and Scarazzo regarding FBI electronic data
request.
07/08/09 J T Leslie .10 Coordinate collection of employee computers.
07/08/09 M G Myers 2.70 Discussions with the Attorney General for the state of
Louisiana regarding investigation into Stanford Trust Company
and document requests relating to same; attention to matters
relating to document production for Louisiana attorney general
and other state agencies.
07/08/09 N M Starbuck 6.00 Searched Receivership file for organization charts and
produced to FBI and Louisiana Department of Justice;
coordinated obtaining Louisiana and Texas Stanford employee
information pursuant to State of Louisiana production request;
attention to remaining Louisiana production requests.
07/09/09 C N Adams .50 Telephone conference with Joe Cialone regarding SEC
production requests; telephone conference with Louisiana
Attorney General regarding investigation.
07/09/09 M C Hurd .30 Corresponded with Alison Sulentic and Kevin Blake regarding
DOL request; corresponded with Tom Leslie regarding
treatment of missing employee computers.
07/09/09 J T Leslie .60 Coordinate release of Iron Mountain documents; telephone
conference with John Greer and Hugh Howser (Forefront
counsel) regarding Forefront documents.
07/10/09 C N Adams .60 Telephone conference with Karyl Van Tassel regarding
electronic evidence; telephone conference with Jim Scarazzo
regarding same.
07/10/09 M C Hurd .60 Phone call with Richard Husseini regarding status of password-
protected files in Harry Failing documents; corresponded with
Jim Scarazzo regarding FBI and Mississippi Secretary of State
requests; corresponded with Alison Sulentic regarding DOL
request.
165
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 99 of 377
Page 98
Hours Description
07/10/09 J T Leslie .30 Coordinate Iron Mountain documents.
07/10/09 M G Myers .10 Emailed Nadia Starbuck with various requests related to
document production for state agencies.
07/10/09 N M Starbuck 3.80 Prepared documents for production to the Criminal Division
and Special Prosecutions Unit of Louisiana Department of
Justice.
07/13/09 C N Adams 2.90 Conference with Joe Cialone and Karyl Van Tassel regarding
document production issues; conference with Kevin
Edmundson, Michael King, Joe Cialone and Karyl Van Tassel
regarding same.
07/13/09 J C Huddleston 4.20 Assembled and prepared documents for production to
Louisiana and the SEC.
07/13/09 M C Hurd 3.40 Corresponded with Craig Adams regarding SEC requests;
corresponded with Alison Sulentic and Kevin Blake regarding
DOL request; corresponded with Tom Leslie, Dave Schulte,
and Steve Lindstrom regarding FBI request; corresponded with
Mike Myers regarding coordination and preparation of
electronic materials for Mississippi production; coordinated
preparation and production of documents and information to
SEC; drafted and revised production letters to SEC and FBI;
coordinated preparation of electronic materials for FBI
production.
07/13/09 J T Leslie .20 Coordinated response to FBI information request.
07/13/09 M G Myers 2.20 Attention to matters relating to document production for
various state regulatory agencies in response to subpoenas and
document requests.
07/13/09 N M Starbuck 4.00 Produced documents to the Louisiana DOJ; produced broker-
dealer account statements to SEC; prepared SGC Financial
Statements and Baton Rogue Audit Reviews for production to
Louisiana; prepared hard drive data for Ft. Lauderdale
employees for production to the FBI; prepared employee email
data for production to Mississippi.
07/14/09 C N Adams 1.30 Reviewing materials for production to the SEC; telephone
conference with Karyl Van Tassel regarding same; telephone
conference with Allen Medina regarding DOJ victim's's
assistance.
07/14/09 J G Foster .40 Conferred with M. Hurd regarding SEC request for Stanford
office moving documentation; reviewed documentation and
discussed production issues.
07/14/09 J C Huddleston 7.70 Attention to SEC and state document production requests.
166
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 100 of 377
Page 99
Hours Description
07/14/09 M C Hurd 7.70 Coordinated preparation and production of documents and
information for SEC production; corresponded with Craig
Adams and Tom Leslie regarding SEC request; phone call and
corresponded with Gail Foster regarding SEC request; phone
call and corresponded with Dave Schulte regarding FBI
request; corresponded with Kim Schlanger and Staci Lowman
regarding FBI request; office conferences with Shawn Giles
regarding FBI request; reviewed legal files from concourse for
FBI request; corresponded with Chad Nunez and Adams
regarding FBI requests; corresponded with Mark Russell and
Karyl Van Tassel regarding SEC and FBI request; office
conference with SEC team reviewing documents at 5050
Westheimer.
07/14/09 J T Leslie .50 Telephone conference with John Greer regarding Forefront
documents; coordination of FBI information request.
07/14/09 M G Myers 3.10 Attention to matters relating to production of documents and
responses to various email inquiries from state regulatory
agencies.
07/14/09 N M Starbuck 5.20 Prepared production to Louisiana Department of Justice;
processed real estate closing documents to comply with FBI
request.
07/14/09 N M Starbuck .40 Prepared Stanford-issued laptop computer for custodian
Josephine Millward for transmittal to FTI.
07/15/09 C N Adams .80 Preparing website information regarding victim notification.
07/15/09 J G Foster .30 Reviewed C. Adams email regarding Forefront data/document
preservation issues and conferred with him regarding same.
07/15/09 J C Huddleston 5.70 Assembled and prepared documents for production to the
Secretary of States of Iowa and Maine.
07/15/09 M C Hurd 2.00 Corresponded with Dave Schulte regarding FBI request;
corresponded with Chad Nunez and Craig Adams regarding
FBI requests; coordinated preparation of documents and
electronic materials for FBI production; drafted and revised
production letters to FBI.
07/15/09 J T Leslie 2.10 Coordination of Forefront documents; coordination of return of
employee laptops; telephone conferences with Con Massey
regarding return of company owned laptop.
07/15/09 M G Myers 6.10 Worked on filling document requests from various state
agencies and supplementing requests that had already been
partially produced; conference call with Florida state regulators
to discuss and address investigation needs.
167
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 101 of 377
Page 100
Hours Description
07/15/09 N M Starbuck 8.30 Prepared listing of STC Customers for production to State of
Texas Department of Banking; produced documents requested
by Louisiana Department of Justice; received and processed for
production to the FBI photos of SFG's Ft. Lauderdale office;
begin preparation of marketing materials for production to
Mississippi.
07/16/09 J C Huddleston 7.70 Assembled and prepared documents for production to the
Secretary of States of Iowa and Maine; quality-checked
documents for production for same.
07/16/09 M C Hurd 1.30 Coordinated preparation of documents and electronic materials
for FBI production; phone call and corresponded with Chad
Nunez regarding registered mail issue; corresponded with
Clayton Gerber and Craig Adams regarding same;
corresponded with Kim Schlanger and Staci Lowman regarding
FBI request.
07/16/09 J T Leslie .90 Coordination of return of computers by employees; telephone
conference with Jan Wald regarding return of his computer;
office conference with John Greer regarding Forefront
documents; telephone conference with Louis Ginn of A-1
Freeman regarding warehouse website.
07/16/09 M G Myers 1.70 Filling document requests from various state agencies and
supplementing requests that had already been partially
produced.
07/16/09 N M Starbuck 7.00 Prepared production to the State of Mississippi; prepared
account opening documents for production to State of Florida
Office of Financial Regulation.
07/17/09 J C Huddleston 7.70 Assembled and prepared documents for production to the
Secretary of State of Florida; quality-checked documents for
same; investigated Stanford outgoing mail delivery to New
Iberia, Louisiana.
07/17/09 M C Hurd 2.00 Phone call to Clayton Gerber and corresponded with Gerber
and Chad Nunez regarding registered mail issue; corresponded
with Nunez regarding FBI production; drafted and revised
production letters to FBI and SEC; coordinated preparation and
production of SEC production.
07/17/09 J T Leslie .10 Coordinate return of employee laptops.
07/17/09 N M Starbuck 6.80 Produced account information to Maine Department of
Professional and Financial Regulation and Iowa Insurance
Enforcement Bureau; produced account applications and
agreements to State of Florida Department of Financial
Regulation; prepared electronic evidence reports created by M.
Russell of FTI for production to FBI; produced documents
168
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 102 of 377
Page 101
Hours Description
requested by D. Fraser of the SEC; produced SIB Due
Diligence power point presentation to Louisiana Department of
Justice.
07/20/09 J C Huddleston 3.30 Prepared transmittal of information to FBI in connection with
FBI production; quality-checked materials for production to the
FBI.
07/20/09 M C Hurd 2.70 Coordinated preparation and production of documents and
electronic materials for FBI production; drafted and revised
production letter to FBI; worked with paralegals regarding
source of proposed exhibits REDACTED ;
corresponded with Craig Adams and Bill Stutts regarding
findings on same.
07/20/09 M G Myers 8.20 Attention to document production requests and other requests
from state regulatory agencies and the Securities and Exchange
Commission.
07/20/09 N M Starbuck 4.70 Produced Fort Lauderdale evidence files and Real Estate
Documents for Antigua Islands to C. Nunez of the FBI; at the
request of M. Myers produced information to Securities and
Exchange Commission Division of Enforcement.
07/21/09 C N Adams .70 Reviewing request for documents for King extradition hearing;
telephone conference with Chad Nunez regarding same.
07/21/09 J G Foster .20 Reviewed email from R. Davis regarding proposed compliance
protocol for handling certain departmental documents.
07/21/09 M C Hurd 2.50 Drafted and revised production letters to DOL; corresponded
with Alison Sulentic regarding preparation of DOL production;
corresponded with Chad Nunez and Jim Scarazzo regarding
FBI electronic materials request; phone call with Craig Adams
and Nunez regarding source of proposed exhibits to Leroy
King extradition affidavit and FBI requests; corresponded with
Adams regarding same; corresponded with Scarazzo regarding
FBI request.
07/21/09 M G Myers 2.40 Attention to document production requests and other requests
from state regulatory agencies and the Securities and Exchange
Commission.
07/22/09 J G Foster .30 Reviewed R. Davis email regarding handling of documents
retrieved from warehouse for production pursuant to
government request, and attention to same.
07/22/09 M C Hurd 2.40 Phone call with Simon Strong regarding FBI request; reviewed
memorandum provided by Strong related to FBI request;
corresponded with Chad Nunez regarding FBI request; office
conference with Gail Foster regarding document handling and
169
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 103 of 377
Page 102
Hours Description
inventory issues; phone call with Rhonda Davis regarding
same.
07/22/09 J T Leslie .10 Coordination of Louisiana Attorney General production
request.
07/22/09 N M Starbuck 4.50 Produced statements to State of Kentucky; produced materials
requested by Mississippi Secretary of State; at the request of A.
Sultenic produced letter containing SIBL Account Information
for LCM Trust to the US Department of Labor.
07/22/09 N M Starbuck 1.40 Assisted in providing support for R. Janvey's AFFIDAVIT
REDACTED
.
07/23/09 J G Foster .20 Reviewed email and listing provided by J. Scarazzo regarding
data/document productions to date.
07/23/09 J C Huddleston 7.70 Reconciled Baker Botts production log to FTI production log.
07/23/09 M C Hurd .30 Reviewed email and spreadsheet from Jim Scarazzo regarding
electronic data gathering; coordinated review of spreadsheet
against government production logs.
07/23/09 J T Leslie .20 Telephone conference with Hugh Howser regarding Forefront
documents.
07/23/09 N M Starbuck 2.40 Prepared documents for production to FBI and SEC.
07/24/09 C N Adams 1.00 Telephone conference with Matt Klecka regarding Antiguan
extradition hearing; reviewing materials regarding same;
reviewing SEC request regarding production of documents.
07/24/09 J A Cialone, II 1.50 Attention to DOJ request for affidavit related to certain
documents.
07/24/09 J C Huddleston 4.30 Attention to chain of custody of specified Tupelo/Baldwyn
documents.
07/24/09 M C Hurd 1.90 Corresponded with Rhonda Davis and Craig Adams regarding
procedures for handling client document requests; reviewed
proposed exhibits to Receiver's draft affidavit for location and
source; coordinated verification and corresponded with Adams
and John Greer regarding same; corresponded with Steve
Lindstrom and Adams regarding SEC warehouse document
review; corresponded with Adams and Chad Nunez regarding
FBI requests.
07/24/09 J T Leslie .10 Telephone conference with Forefront regarding Iron Mountain
documents.
07/24/09 N M Starbuck 7.30 Review and comparison of production records for
electronically stored information to confirm agreement with
170
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 104 of 377
Page 103
Hours Description
FTI database; Maintained Receivership file and records.
07/25/09 C N Adams 1.10 Reviewing DOJ affidavit; telephone conference with Chad
Nunez and Marisa Hurd regarding same.
07/25/09 M C Hurd 2.90 Corresponded with Kristie Blumenschein, Joe Cialone, and
Craig Adams REDACTED
; phone call and
corresponded with Adams and Chad Nunez regarding same and
FBI requests; reviewed production log for FBI request;
corresponded with Simon Strong regarding FBI request;
corresponded with Jim Scarazzo regarding electronic
production issue; corresponded with Gail Foster regarding FBI
request.
07/26/09 M C Hurd .30 Corresponded with Jim Scarazzo regarding electronic
production issue; corresponded with Craig Adams regarding
status of RAS and Stoelker's personal belongings.
07/27/09 J G Foster .30 Reviewed email regarding DOJ request for Ft. Lauderdale
shredded material and conferred with M. Hurd regarding
handling same.
07/27/09 J C Huddleston 5.00 Reviewed client file documents at the direction of Marisa Hurd
pursuant to SEC production request.
07/27/09 M C Hurd 3.70 Corresponded with Chad Nunez regarding electronic
production issue, prior FBI electronic production, and FBI
request; coordinated and corresponded with Steve Lindstrom
regarding SEC warehouse document review; drafted and
revised production letter to FBI; corresponded with Simon
Strong regarding and coordinated preparation of items for FBI
production; phone call with Clayton Gerber regarding Receiver
actions with regard to certain real estate and vehicles;
corresponded with Lindstrom and Rhonda Davis regarding FBI
request.
07/27/09 M G Myers 1.60 Attention to matters relating to the production of documents to
the Securities and Exchange Commission and other regulatory
agencies.
07/27/09 N M Starbuck 7.30 Reviewed Financial Advisor materials to comply with FBI's
request for SIBL customer accounts; at the request of M. Myers
produced STC IRA Report to SEC.
07/28/09 J A Cialone, II .80 Attention to DOJ email request and developed response.
07/28/09 J C Huddleston 7.70 Reviewed client file documents at the direction of Marisa Hurd
pursuant to SEC production request.
07/28/09 M C Hurd 1.70 Reviewed production logs for SEC electronic request and
corresponded with Craig Adams and Jim Scarazzo regarding
171
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 105 of 377
Page 104
Hours Description
same; corresponded with Adams regarding question on prior
FBI productions; phone call with paralegals and Rhonda David
regarding records requested for FBI request; sent Davis client
list spreadsheet regarding same.
07/28/09 N M Starbuck 7.50 Prepared STFG customer's BGC Partners, Inc allocated shares
information for production to FINRA; Reviewed broker-dealer
files to comply with FBI request; Assisted in SEC warehouse
document review.
07/29/09 C N Adams .40 Telephone conference with Ralph Janvey regarding document
production and privilege issues.
07/29/09 J A Cialone, II .60 Conference call with Receiver and others about DOJ request
for certain Miami information.
07/29/09 J C Huddleston 7.70 Reviewed client file documents at the direction of Marisa Hurd
pursuant to SEC production request.
07/29/09 M C Hurd 2.10 Corresponded with Clayton Gerber regarding updates on
Receiver action with regard to certain real estate and vehicles;
phone call and corresponded with Charlie Gale regarding
Receiver action with regard to certain vehicles; corresponded
with Dave Schulte regarding FBI interview; corresponded with
Jim Scarazzo regarding electronic production issue and
coordination of electronic materials for SEC production.
07/29/09 J T Leslie .20 Coordination regarding Iron Mountain documents;
coordination for document warehouse.
07/29/09 N M Starbuck 7.30 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC warehouse document review.
07/30/09 C N Adams .60 Attention to SEC request for compliance data and email; emails
with Malcolm Lovett and Marisa Hurd regarding same.
07/30/09 J A Cialone, II .50 Attention to SEC's lengthy list of email files requested and cost
for responding to same.
07/30/09 J C Huddleston 7.70 Reviewed client file documents at the direction of Marisa Hurd
pursuant to SEC production request.
07/30/09 M C Hurd 9.70 Coordinated review of and reviewed broker files at warehouse
for FBI request; corresponded with Alison Sulentic regarding
DOL production issue; corresponded with Craig Adams and
David Fraser regarding SEC requests, including for electronic
data; drafted and revised production letters to SEC.
07/30/09 N M Starbuck 7.30 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC warehouse document review.
07/31/09 J C Huddleston 7.70 Assembled and prepared documents for production to the SEC;
reviewed client file documents at the direction of Marisa Hurd
172
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 106 of 377
Page 105
Hours Description
pursuant to SEC production request.
07/31/09 M C Hurd 2.70 Coordinated preparation and production of documents and
information for SEC production; reviewed correspondence
from Charlie Gale regarding DOJ request for information on
Stanford vehicle; coordinated preparation of documents and
information for FBI production; corresponded with Craig
Adams and David Fraser regarding SEC warehouse document
review.
07/31/09 J T Leslie .10 Coordinate Iron Mountain documents.
07/31/09 N M Starbuck 7.70 Produced to the SEC documents pulled by A. Conders from
custodian Bernie Young's boxes; Traveled to Stanford
Receivership warehouse and reviewed Financial Advisor
materials to comply with FBI's request for SIBL customer
account information.
08/03/09 J A Cialone, II .80 Prepared for call with DOJ.
08/03/09 M C Hurd 8.90 Coordinated review of and reviewed broker files at warehouse
for FBI request; corresponded with Alison Sulentic regarding
DOL production; coordinated preparation and production of
information for SEC production; drafted and revised
production letters to SEC; conference call with Mike Myers
regarding FINRA request; office conferences with David
Fraser regarding SEC warehouse document review.
08/03/09 K L Karp 7.70 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/03/09 N M Starbuck 7.30 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/04/09 C N Adams .80 Telephone conference with Marisa Hurd regarding FBI and
SEC document production requests; telephone conference with
Chad Nunez REDACTED
08/04/09 J A Cialone, II .80 Conference call with TK about FBI interview.
08/04/09 J A Cialone, II .30 Reviewed agenda draft for DOJ meeting.
08/04/09 M C Hurd 8.20 Coordinated review of and reviewed broker files at warehouse
for FBI request; coordinated preparation and production of
documents and information for DOL production; corresponded
with Alison Sulentic regarding same; drafted and revised
production letters to DOL; office conferences with David
Fraser regarding SEC warehouse document review; phone call
with Craig Adams and Chad Nunez regarding FBI requests and
interview with Dave Schulte; corresponded with Adams and
Malcolm Lovett regarding FBI request; phone call and
corresponded with Adams regarding SEC warehouse document
173
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 107 of 377
Page 106
Hours Description
review procedure and materials withheld from RAS and
Stoelker St. Croix boxes; coordinated preparation of documents
and information for supplement to FBI production.
08/04/09 K L Karp 7.30 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/04/09 N M Starbuck 7.80 Prepared information for production to FINRA; reviewed
broker-dealer files to comply with FBI request; assisted in SEC
document review at Receivership warehouse.
08/05/09 C N Adams .70 Telephone conference with Dave Schulte, Richard Roper and
Joe Cialone REDACTED ; reviewing
information regarding same.
08/05/09 J A Cialone, II 1.40 Prepared for and participated in extended conference call with
DOJ lawyers about meeting on August 19 and related matters.
08/05/09 M C Hurd 8.60 Coordinated review of and reviewed broker files at warehouse
for FBI request; corresponded with David Fraser regarding
SEC warehouse document review; conference call with Joe
Cialone, Craig Adams, Dave Schulte, and Richard Roper
regarding FBI/DOJ interview issues; corresponded with Chad
Nunez regarding FBI request; corresponded with Malcolm
Lovett regarding FBI request; revised and formatted
spreadsheet for FBI request; reviewed receipts and
documentation regarding materials withheld from RAS and
Stoelker St. Croix boxes; drafted letter to Stoelker's counsel
regarding same; corresponded with Simon Strong regarding
FBI request; drafted and revised production letter to FBI;
coordinated production of items for FBI production;
coordinated preparation of documents and information for
supplement to FBI production.
08/05/09 K L Karp 7.40 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/05/09 N M Starbuck 6.70 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/06/09 C N Adams .50 Reviewing production request and related materials from Fort
Lauderdale office.
08/06/09 J C Huddleston 1.20 Attention to preparation and assembly of documents in
connection with SEC warehouse production request.
08/06/09 M C Hurd 6.90 Coordinated review of and reviewed broker files at warehouse
for FBI request; coordinated preparation of documents and
information for supplement to FBI production; corresponded
with Malcolm Lovett and Charlene McDougal regarding FBI
request; reviewed correspondence from Craig Adams regarding
174
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 108 of 377
Page 107
Hours Description
additional missing or withheld items from RAS and Stoelker's
St. Croix boxes; revised and formatted spreadsheet for FBI
request; phone call with Jeff Ferguson regarding SIBL
document issues.
08/06/09 K L Karp 7.80 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/06/09 N M Starbuck 7.50 Reviewed broker-dealer files to comply with FBI request; at
the request of M. Myers prepared documents for production to
Louisiana Department of Justice.
08/07/09 C N Adams .60 Attention to SEC request for emails; correspondence with Jim
Scarazzo regarding same.
08/07/09 J C Huddleston .80 Attention to assembly of documents for production to the FBI.
08/07/09 M C Hurd 8.50 Coordinated review of and reviewed broker files at warehouse
for FBI request; reviewed materials from produced and
unproduced broker fields for request for SIBL documents from
Jeff Ferguson; corresponded with Ferguson regarding update of
same; coordinated preparation of documents and information
for supplement to FBI production; corresponded with Craig
Adams and Steve Lindstrom regarding additional missing or
withheld items from RAS and Stoelker's St. Croix boxes;
corresponded with Adams regarding additional warehouse
document request; revised and formatted spreadsheet for FBI
request; coordinated preparation of documents and information
for SEC production; drafted and revised production letters to
SEC and FBI.
08/07/09 K L Karp 7.50 Reviewed broker-dealer files to comply with FBI request;
assisted in SEC document review at Receivership warehouse.
08/07/09 N M Starbuck 7.30 Reviewed broker-dealer files to comply with FBI request;
quality-checked production of broker-dealer files and
documents requested by D. Fraser of the SEC.
08/10/09 C N Adams .70 Attention to production of data from Fort Lauderdale office;
preparing same.
08/10/09 J C Huddleston 4.00 Attention to assembly of materials for production to the State
of Mississippi and general assistance to Mike Myers in relation
to same; quality-checked materials reproduced by vendor in
connection to SEC warehouse review; produced corrected
copies as indicated; Assembled and prepared documents for
production to the FBI in connection with production request;
quality-checked documents for production to the FBI for
production request.
08/10/09 M C Hurd 8.00 Coordinated preparation of documents and information for
175
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 109 of 377
Page 108
Hours Description
supplement to FBI production; revised and formatted
spreadsheet for FBI request; coordinated preparation and
production of documents for supplement to FBI production;
coordinated preparation and production of documents and
information for SEC production; drafted and revised
production letters to SEC and FBI; corresponded with Chad
Nunez regarding production issues; reviewed correspondence
from Craig Adams regarding FBI request and interview of
Simon Strong.
08/10/09 N M Starbuck 4.00 Produced to the SEC documents pulled by David Fraser from
Receivership warehouse boxes; inventoried and prepared
broker affiliations and broker files for designated clients for
production to the FBI; prepared Mississippi Pershing Accounts
for production to the State of Mississippi.
08/11/09 C N Adams .70 Reviewing Fort Lauderdale information; telephone conference
with Chad Nunez regarding same.
08/11/09 J C Huddleston 6.70 Updated and managed SEC production-related files with
inclusion of production materials; quality checked St. Croix
box contents to prepared inventory; revised inventory as
appropriate.
08/11/09 M C Hurd 7.40 Coordinated preparation and production of documents and
information for supplement to FBI production; drafted and
revised production letter to FBI; coordinated inventory process
of items withheld from RAS and Stoelker St. Croix shipment;
corresponded with Chad Nunez regarding production issues;
reviewed correspondence from Craig Adams and Jim Scarazzo
regarding FBI request; reviewed and compared electronic
production file against FTI electronic evidence spreadsheet;
revised and edited such spreadsheet.
08/11/09 N M Starbuck 4.30 Produced to the FBI broker affiliations and broker files for
SFG clients and client files pulled by M. Barnhart from
Stanford database.
08/12/09 C N Adams .50 Attention to Fort Lauderdale production; telephone conference
with Jim Scarazzo regarding same.
08/12/09 J C Huddleston 7.50 Attention to RAS and AMS St. Croix inventory with focus on
retention of copies of specified documents; quality checked
same; revised inventories as appropriate.
08/12/09 M C Hurd 9.50 Coordinated inventory process of items withheld from RAS
and Stoelker St. Croix shipment; reviewed items from St. Croix
boxes to be released/copied/kept; reviewed and compared
electronic production file against FTI electronic evidence
spreadsheet; revised and edited such spreadsheet; revised and
176
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 110 of 377
Page 109
Hours Description
updated logs for FBI production.
08/12/09 N M Starbuck 2.40 Produced to the FBI Contact Information for employees at the
Ft. Lauderdale office; prepared documents for production to
US State Agencies.
08/13/09 C N Adams .90 Telephone conference with Chad Nunez regarding document
production issues.
08/13/09 J G Foster .40 Reviewed FTI production spreadsheet and comments regarding
same;
08/13/09 J C Huddleston 5.30 Attention to retention of specified documents from the St.
Croix belongings of RAS and AMS at the direction of Marisa
Hurd.
08/13/09 M C Hurd 7.00 Coordinated inventory process of items withheld from RAS
and Stoelker St. Croix shipment; reviewed items from St. Croix
boxes to be released/copied/kept; reviewed and compared
electronic production file against FTI electronic evidence
spreadsheet; revised and edited such spreadsheet; sent
spreadsheet to Jim Scarazzo and Gail Foster for their review;
coordinated reproduction of electronic information from FBI
production; corresponded and office conference with Chad
Nunez and Vanessa Walther regarding same and FBI requests;
revised and updated list of outstanding government requests;
corresponded with Craig Adams regarding FBI requests;
drafted and revised production letter to FBI.
08/13/09 N M Starbuck 2.10 Produced to C. Nunez, FBI, additional copy of cd containing
email from the Ft. Lauderdale office; assisted in the review of
FTI's Production Records of Electronically Stored Information;
determined status of production for Ft. Lauderdale shredded
materials.
08/14/09 C N Adams 1.30 Telephone conference with Marshall Gandy regarding FINRA
review of emails; reviewing congressional hearing request;
reviewing production logs; comparing to FINRA request.
08/14/09 J A Cialone, II 1.80 Calls and emails about SEC request for defaulted account
information over weekend; attention to FTI subpoena; calls and
emails about DOJ requests for documents related to Florida
case.
08/14/09 J G Foster .40 Conferred with M. Hurd regarding SEC data and document
requests.
08/14/09 J G Foster .20 Conferred with R. Davis regarding Suarez document location
issues.
08/14/09 J C Huddleston 5.00 Attention to RAS and AMS St. Croix inventory with focus on
retention of copies of specified documents; quality checked
177
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 111 of 377
Page 110
Hours Description
same.
08/14/09 M C Hurd 7.90 Coordinated inventory process of items withheld from RAS
and Stoelker St. Croix shipment; reviewed items from St. Croix
boxes to be released/copied/kept; sent Craig Adams update on
same and requested views on certain items; corresponded with
Adams regarding and drafted list of custodian emails produced
to FBI and SEC; office conference with Gail Foster regarding
same; phone call with Jim Scarazzo and left message for Erik
Post regarding same; phone call with Scarazzo regarding edited
spreadsheet of electronic evidence; corresponded with Adams
regarding REDACTED .
08/17/09 J G Foster .20 Reviewed and replied to email from Rhonda Davis regarding
Y. Suarez document location.
08/17/09 M C Hurd 2.10 Reviewed markup of and answered questions related to RAS
and Stoelker St. Croix shipment inventory from Craig Adams;
corresponded with Adams regarding same; corresponded with
Adams, John Greer, Mike Myers, and Tom Leslie regarding
file and document retrieval issues; coordinated provision of key
documents from St. Croix shipment to FTI, real estate, and
banking teams for review.
08/17/09 N M Starbuck 2.90 Prepared SIBL Reference and Policies and Procedures manuals
and SIB Due Diligence PPT for production to State of Florida.
08/18/09 C N Adams 1.70 Telephone conference with Michael King regarding conference
call with DOJ; reviewing production issues relating to IRS
request; REDACTED .
08/18/09 J A Cialone, II .60 Reviewed emails and materials related to Florida shredding
case.
08/18/09 M C Hurd 1.90 Corresponded with Craig Adams and Sue Ayers regarding
upcoming production to DOJ Tax Division; reviewed prior
productions and requests to update Adams and Ayers on same;
provided documents produced in DOJ production to Ayers for
comparison to documents responsive to current request.
08/18/09 J B Nelsen .30 Correspondence to Sue Ayers regarding document production
to the Department of Justice; conference with Richard Husseini
regarding the same.
08/19/09 C N Adams .80 Attention to extradition request and related issues.
08/19/09 M C Hurd .30 Corresponded with Craig Adams regarding SEC electronic data
request.
08/20/09 C N Adams .30 Attention to SEC e-data request.
08/20/09 M C Hurd 2.40 Compiled list of Stanford employee email produced to
178
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 112 of 377
Page 111
Hours Description
government entities for David Arlington and Craig Adams;
phone call with Arlington and Adams regarding document and
electronic data request for defendant brokers; reviewed
appendix to amended complaint naming relief defendants and
prepared list for use in warehouse document request.
08/21/09 C N Adams .30 Attention to SEC request for broker files.
08/21/09 J G Foster .40 Attention to issues regarding handling of Forefront documents
and files.
08/21/09 M C Hurd 7.80 Compiled list of Stanford employee hard drives produced to
government entities for David Arlington and Craig Adams;
reviewed list of relief defendants REDACTED
; coordinated
preparation of spreadsheet including all electronic data
produced to relief defendants, comparing against production
log; phone call with Adams regarding release of personal items
from RAS and Stoelker St. Croix shipment; coordinated and
prepared such release; reviewed production letter to DOJ;
reviewed and coordinated preparation and production of
documents and information for DOJ production; corresponded
with Adams and Sue Ayers regarding same; corresponded with
Adams and Lindstrom regarding SEC warehouse document
request; reviewed Adams' edits and revised draft letter to
Stoelker's attorney regarding withheld jewelry items;
corresponded with Adams regarding FSRC documents;
coordinated review of Holt's RFPs and comparison against
production log.
08/21/09 K L Karp 2.00 Prepared documents relied on for REDACTED
for production to Nancy Grammel of the IRS.
08/21/09 N M Starbuck 2.00 Prepared documents relied on for REDACTED
for production to Nancy Grammel of the IRS.
08/22/09 C N Adams .30 Reviewing Leroy King document for production to the FBI.
08/22/09 M C Hurd .30 Reviewed correspondence from Bill Stutts and Bob Howell
regarding FSRC documents; corresponded with Craig Adams
regarding production of same.
08/24/09 C N Adams .40 Attention to governmental requests for document production.
08/24/09 J G Foster .30 Reviewed updated information regarding Forefront document
status.
08/24/09 M C Hurd 1.90 Corresponded with Craig Adams, Malcolm Lovett, and Char
McDougal regarding FBI request; phone call with McDougal
and corresponded with Adams and Clayton Gerber regarding
same; coordinated preparation and production of documents
179
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 113 of 377
Page 112
Hours Description
and information for supplement to FBI production; drafted and
revised production letter to FBI; corresponded with David
Fraser regarding SEC warehouse document review;
corresponded with Adams regarding release of RAS and
Stoelker personal DVDs from Sea Eagle shipment.
08/24/09 K L Karp 1.80 Produced FSRC documents from St. Croix to FBI; reviewed
production file for documents produced to Canadian
authorities.
08/24/09 J T Leslie .80 Coordination of retention of Forefront documents.
08/24/09 N M Starbuck 3.50 Produced FSRC documents from St. Croix to FBI; at the
request of M. Myers reviewed production file for documents
produced to Canadian Authorities.
08/25/09 C N Adams .20 Attention to SEC document production request.
08/25/09 M C Hurd .90 Phone call with Clayton Gerber regarding FBI request; phone
call and corresponded with Steve Lindstrom and Rhonda Davis
REDACTED
; corresponded with
Craig Adams regarding status of SEC warehouse document
review; corresponded with David Arlington and Lynne Dodge
regarding status of warehouse document request.
08/25/09 N M Starbuck 7.30 Assisted in SEC document review at Receivership warehouse;
reviewed Receivership Database to comply with L. Pendergest-
Holt's attorney production request.
08/26/09 J A Cialone, II .80 Calls and emails with Washington partners about further
government inquirers and communications.
08/26/09 K L Karp 6.00 Assisted in SEC document review at Receivership warehouse;
prepared documents flagged by D. Fraser for production to the
SEC.
08/26/09 N M Starbuck 6.10 Assisted in SEC document review at Receivership warehouse;
prepared documents flagged by D. Fraser for production to the
SEC.
08/27/09 C N Adams .20 Reviewing Mauricio Alvarado file inventory for production.
08/27/09 M C Hurd 3.30 Drafted and revised production letters to FBI; coordinated
preparation and production of information for FBI production;
phone call and corresponded with Steve Lindstrom and Rhonda
Davis, and corresponded with David Arlington REDACTED
;
corresponded with Andrew York regarding same; corresponded
with Craig Adams regarding status of FBI production; revised
and updated spreadsheet including all electronic data produced
180
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 114 of 377
Page 113
Hours Description
to relief defendants, comparing against production log.
08/27/09 K L Karp 6.20 Assisted in SEC document review at Receivership warehouse;
prepared materials flagged by D. Fraser for production to the
SEC.
08/27/09 N M Starbuck 5.90 Assisted in SEC document review at Receivership warehouse;
prepared materials flagged by D. Fraser for production to the
SEC.
08/28/09 C N Adams .40 Attention to SEC production request.
08/28/09 J A Cialone, II 3.20 Reviewed and considered responses to the subpoena in the
Florida case; emails with DOJ concerning subpoena; calls and
emails concerning appropriate response to government for
electronic data and other assistance, and attempt to coordinate
same in cost-effective manner.
08/28/09 M C Hurd .30 Reviewed correspondence regarding FBI productions related to
Fort Lauderdale shredding incident.
08/28/09 K L Karp 4.10 Assisted in SEC document review at Receivership warehouse;
prepared materials flagged by D. Fraser for production to the
SEC.
08/28/09 N M Starbuck 7.30 Assisted in SEC document review at Receivership warehouse;
prepared materials flagged by D. Fraser for production to the
SEC.
08/30/09 J A Cialone, II 2.40 Emails about Florida subpoena and upcoming trial and
appropriate responses to government for assistance;
consolidated file materials in preparation for call with DOJ
concerning Florida and Davis.
08/31/09 C N Adams .30 Attention to Fort Lauderdale production.
08/31/09 M C Hurd 1.80 Coordinated preparation of electronic data and documents for
supplement 1 to SEC production 37; drafted and revised
production letters to SEC; reviewed production log for
requested document for FBI request; corresponded with Craig
Adams regarding status of production of same to FBI.
08/31/09 K L Karp 1.00 Emailed Nadia Starbuck bates labeled production flagged by D.
Fraser for production to the SEC.
08/31/09 N M Starbuck 7.30 Quality-checked and prepared documents flagged by D. Fraser
for production to the SEC; prepared Ft. Lauderdale materials
for production to the FBI; reviewed correspondence for
litigation notices REDACTED
.
Matter Total 905.00
181
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 115 of 377
Page 114
079716.0108 Disclosure and Communications
Hours Description
06/02/09 S A Massad 1.50 Reviewed and commented on website disclosures; various
telephone conferences and e-mail correspondence.
06/02/09 J E Thomas .50 Updates to Receivership website
06/03/09 S A Massad 1.50 Revised SIPC disclosure; prepared disclosure REDACTED
; other e-mail correspondence regarding
media questions.
06/03/09 E A Soderlund .30 Review and comment on update to web site.
06/04/09 S A Massad 1.30 Finalized disclosure regarding REDACTED
; attention to other website updates; various e-mail
correspondence.
06/04/09 J E Thomas .50 Updates to Receivership website
06/05/09 S A Massad 1.30 Reviewed and commented on website disclosure regarding
Stanford Trust accounts.
06/05/09 J E Thomas 1.00 Updates to Receivership website
06/06/09 J A Cialone, II .80 Attention to disclosure and media issues.
06/06/09 J E Thomas .50 Updates to Receivership website
06/08/09 S A Massad .50 Attention to various website and communications issues.
06/09/09 S A Massad .50 Various e-mail correspondence regarding disclosure issues.
06/10/09 S A Massad 2.30 Prepared disclosure regarding real estate motions and Swiss
building sale; received comments and revised disclosure;
various telephone conferences and e-mail correspondence
regarding same.
06/10/09 E A Soderlund .30 Review and comment on updates to Receiver's web site (0.3).
06/11/09 S A Massad 1.50 Various telephone conferences and e-mail correspondence
regarding disclosure REDACTED
; revised same; attention to responses to other website
issues and changes.
06/12/09 S A Massad .30 E-mail correspondence regarding Swiss disclosure; revised
same.
06/15/09 S A Massad .70 Made revisions to website homepage.
06/17/09 J A Cialone, II 1.10 Reviewed draft press statement; calls and emails about press
issues.
06/17/09 S A Massad .80 Made revisions to website homepage; various telephone
conferences and e-mail correspondence regarding same.
182
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 116 of 377
Page 115
Hours Description
06/18/09 J A Cialone, II .80 Attention to media and other disclosure issues.
06/19/09 J A Cialone, II .60 Reviewed media reports and emails relating to criminal case
and considered responses and implications.
06/22/09 S A Massad 3.00 Revisions to website materials; various telephone conferences
and e-mail correspondence regarding account release data for
website.
06/23/09 S A Massad .80 Attention to website disclosures; various e-mail
correspondence.
06/24/09 S A Massad 1.70 Various telephone conferences and e-mail correspondence;
attention to disclosure issues.
06/25/09 S A Massad 1.30 Attention to various website issues; various e-mail
correspondence.
06/26/09 S A Massad 1.00 Attention to new website postings; various telephone
conferences and e-mail correspondence.
06/29/09 S A Massad 1.80 Drafted website disclosure regarding Court order and account
status report.
06/30/09 S A Massad 1.30 Finalized website materials and arrange for posting.
06/30/09 J E Thomas 1.00 Updates to Receivership website
07/01/09 S A Massad 1.50 Attended to website postings regarding new developments;
various telephone conferences and e-mail correspondence
regarding same.
07/01/09 J E Thomas 1.00 Updates to Receivership website
07/02/09 J A Cialone, II .60 Attention to press issues.
07/02/09 S A Massad 3.50 Attention to website postings; numerous e-mail correspondence
and telephone conversations, etc.
07/03/09 S A Massad .70 Attention to website posting regarding UK order; various e-
mail correspondence.
07/03/09 J E Thomas 1.00 Updates to Stanford Receivership website
07/06/09 S A Massad .50 Various e-mail correspondence regarding pending issues.
07/08/09 S A Massad 1.00 Attended to miscellaneous website and other issues.
07/09/09 S A Massad .50 Miscellaneous e-mail correspondence and telephone
conversations.
07/10/09 S A Massad .80 Posted new report regarding accounts; various telephone
conferences and e-mail correspondence regarding same.
07/13/09 J A Cialone, II .40 Attention to press issues and meeting about same.
183
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 117 of 377
Page 116
Hours Description
07/13/09 W F Stutts, Jr. 1.90 Telephone conference with Mr. Cialone, Mr. Howell, Ms. Sims
and Mr. Steffy and preparation related to the same.
07/13/09 J E Thomas 1.00 Updates to Spanish Receivership page
07/14/09 N M Starbuck 1.40 Met with N. Sims of Pierpont Communications and A. Shapiro
of Fox Business News re: tour and news segment of SFG
Houston office.
07/15/09 J E Thomas 1.00 Updates to Receivership website
07/16/09 J E Thomas 1.00 Updates To Spanish page of Receivership website
07/17/09 C N Adams .80 Telephone conference with media advisors regarding private
equity investment valuation.
07/20/09 J E Thomas 1.00 Updates to Spanish page on Receivership website
07/24/09 J A Cialone, II 1.00 Attention to disclosure issues.
07/27/09 J A Cialone, II .80 Attention to draft press statement in connection with filing.
07/27/09 S A Massad .50 Attention to e-mail correspondence regarding press statement,
etc.
07/28/09 S A Massad 3.70 Drafted and revised press statement REDACTED ;
various telephone conferences and e-mail correspondence.
07/29/09 J A Cialone, II .50 Attention to disclosure issues.
07/29/09 S A Massad 2.50 Finalized description of clawback filings and post on website;
various telephone conferences and e-mail correspondence.
07/29/09 J E Thomas 1.00 Updates to Receivership website
07/30/09 J E Thomas .50 Updates to Spanish Receivership webpage
07/31/09 J A Cialone, II .60 Attention to media inquiries and other disclosure matters.
07/31/09 S A Massad .50 Various e-mail correspondence regarding website posting and
statement regarding hearing.
07/31/09 J E Thomas 1.00 Updates to Spanish Receivership webpage
08/01/09 S A Massad .70 Various telephone conferences and e-mail correspondence
regarding website posting and statement regarding hearing.
08/03/09 S A Massad 1.00 Attended to miscellaneous website and communications issues;
various e-mail correspondence.
08/04/09 S A Massad .80 Various e-mail correspondence regarding website and
communications issues.
08/05/09 S A Massad 1.00 Attention to website postings, etc.; various e-mail
correspondence.
184
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 118 of 377
Page 117
Hours Description
08/05/09 J E Thomas 1.00 Updates to Stanford Receivership website
08/06/09 S A Massad 1.50 Attended to website postings; various e-mail correspondence;
telephone conference with Victims Coalition; attended to
political campaign contributions.
08/07/09 S A Massad 1.70 New website postings; various e-mail correspondence.
08/07/09 J E Thomas .50 Update to Receivership website
08/10/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding disclosure issues; posted new material.
08/10/09 J E Thomas 1.00 Updates to Receivership website
08/11/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence;
attention to website questions.
08/11/09 J E Thomas .50 Update to Receivership website
08/12/09 J E Thomas .50 Update to Spanish version of Receivership website
08/13/09 C N Adams .80 Reviewing and responding to emails regarding response to
reporter inquiry.
08/13/09 S A Massad 1.50 Attended to miscellaneous website and communications issues;
reviewed and commented on Janvey testimony to Senate
hearing; various telephone conferences and e-mail
correspondence.
08/14/09 S A Massad 1.30 Attended to various communications issues; various telephone
conferences and e-mail correspondence.
08/17/09 S A Massad 1.00 Prepared description of SIPC letter for website; various
telephone conferences and e-mail correspondence regarding
Senate hearing and communications issues; attention to press
inquiries.
08/17/09 J E Thomas 1.50 Updates to Receivership website
08/18/09 S A Massad 1.50 Conference call regarding various communications issues;
attention to SIPC posting; various telephone conferences and e-
mail correspondence.
08/19/09 S A Massad 1.20 Various telephone conferences and e-mail correspondence, etc.
08/20/09 S A Massad 1.30 Drafted section for report; conference call regarding status of
various matters; attention to communication issues.
08/20/09 J E Thomas 1.00 Added content to Spanish version of Receivership website
08/21/09 S A Massad .50 Various telephone conferences and e-mail correspondence
regarding communications issues; prepared draft section for
report.
185
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 119 of 377
Page 118
Hours Description
08/24/09 S A Massad .50 Various telephone conferences and e-mail correspondence.
08/25/09 S A Massad .70 Various telephone conferences and e-mail correspondence
regarding media issues, etc.
08/26/09 S A Massad 1.00 Conference call regarding communications matter; reviewed
materials.
08/26/09 J E Thomas .50 Update to Spanish version of Receivership website
08/27/09 J E Thomas .50 Update to Stanford Receivership website.
08/28/09 J A Cialone, II .60 Attention to media requests for comments, information.
08/31/09 S A Massad .50 Various telephone conferences and e-mail correspondence.
Matter Total 90.80
079716.0109 Insurance Matters
Hours Description
06/02/09 J A Cialone, II .50 Attention to insurance issues.
06/02/09 J M Greer .30 Reviewed and made comments to draft correspondence to
several insurance carriers with regard to cancellation notices
the Receivership Estate received.
06/02/09 C W Rancher 2.20 Reviewed cancellation notices for insurance policies; drafted
letters to insurance companies.
06/03/09 T W Mountz .40 Review of correspondence between customer and insurance
broker; email to K. Sadler and J. Cialone re correspondence.
06/03/09 C W Rancher 1.20 Drafted and revised letters to insurance companies regarding
cancellation of coverage.
06/10/09 T J Walters 3.20 Researching real property insurance matters.
06/19/09 J A Cialone, II .80 Worked on insurance issues and calls related thereto.
06/25/09 C N Adams .60 Telephone conference with Joe Cialone and Tim Mountz
regarding insurance issues.
06/25/09 T W Mountz 2.60 Telephone conference with D. White and B. Banowsky re
insurance matter; review of letter from Akin Gump; legal
research re D&O issues; conferences with J. Cialone, C.
Adams and J. Ross re D&O matters.
06/26/09 T W Mountz 1.70 Legal research re D&O issues; email to J. Cialone re issues;
review of D&O policy.
06/27/09 C N Adams .40 Reviewing issues related to D&O insurance proceeds; emails
regarding same.
186
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 120 of 377
Page 119
Hours Description
06/27/09 J A Cialone, II 2.50 Reviewed policies, materials and correspondence, as well as
legal authorities relating to insurance under the present
circumstances.
06/27/09 T M Davis .70 Read emails regarding insurance proceeds.
06/27/09 T W Mountz .40 Review of emails re D&O policy proceeds; emails to J. Cialone
and T. Davis re insurance issues.
06/28/09 J A Cialone, II .80 Continued work on insurance strategies.
06/30/09 T W Mountz 4.50 Emails to T. Durst re insurance issues and Pendergest-Holt
motion; telephone conference with T. Davis and J. Ross re
legal issues; emails to R. Janvey and J. Cialone re insurance
issues; review of D&O policy and legal research re issues;
conference with M. Suddath re issues.
06/30/09 E A Soderlund .70 Participate in conference call regarding insurance policies and
rights to proceeds thereunder.
07/01/09 J A Cialone, II 1.50 Calls and emails about D&O insurance; reviewed D&O
insurance correspondence and file materials; reviewed
insurance cases.
07/01/09 T W Mountz 4.80 Review of motion and filings by Pendergest-Holt in support of
D&O position; review of various cases re D&O issues;
conferences with J. Cialone and M. Sudderth re insurance
matters; conferences with T. Durst and emails to Baker Botts
lawyers re D&O issues; telephone conference with D. White at
Thompson Knight re D&O matters.
07/02/09 J A Cialone, II 2.20 Prepared for and participated in meeting with lawyers for
criminal defendants concerning their claims for D&O
insurance; related calls and emails with Receiver's team;
reviewed D&O insurance documents and correspondence.
07/02/09 J B Lawrence .70 Research response to Holt's motion regarding D&O insurance.
07/02/09 T W Mountz 1.80 Consideration to insurance issues; conference with J. Lawrence
re Pendergest-Holt motion; email to J. Cialone re potential
resolution of insurance issues; review of various insurance
policies.
07/03/09 J A Cialone, II 1.50 Continued review and analysis of D&O insurance situation,
and numerous calls, meetings, and emails about same; internal
conference call about insurance.
07/03/09 J B Lawrence 5.50 Continue research for response to Holt's D&O insurance
motion.
07/03/09 T W Mountz 1.90 Review of Stanford insurance policy; conference with J.
Cialone and T. Durst re insurance issues; email to J.
187
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 121 of 377
Page 120
Hours Description
Rubenstein and K. Scanlan re supplemental notice letter.
07/05/09 J A Cialone, II .80 Continued analysis of insurance issues.
07/05/09 T W Mountz .40 Conference with J. Lawrence re brief in response to D&O
motion; emails to J. Cialone re insurance issues.
07/06/09 J A Cialone, II .90 Prepared for and participated in extended meeting with counsel
for criminal defendants concerning insurance; related calls and
emails.
07/06/09 J B Lawrence 13.70 Outline and draft response to Holt motion regarding D&O
policy proceeds.
07/06/09 T W Mountz 2.90 Emails to J. Cialone re insurance issues; telephone conference
with R. Roper and B. Banowsky re insurance matters;
participation in conference call with defense counsel re
insurance matters; review of talking points outline re insurance
matters; conference with T. Durst re insurance issues.
07/07/09 J A Cialone, II .60 Continued work on D&O insurance issues.
07/07/09 J B Lawrence 5.20 Edit and revise response to Holt D&O insurance motion.
07/07/09 T W Mountz 3.30 Conference with J. Lawrence and K. Scanlan re claims; review
of Stanford filings on D&O issue; email to D. White re
insurance issue; conferences with J. Cialone and T. Durst re
insurance matters; review of initial draft of response brief.
07/08/09 J A Cialone, II .50 Calls and emails about TK memo analyzing the insurance
issues.
07/08/09 J B Lawrence 4.40 Perform additional research related to response to Holt D&O
insurance motion; research cases filed against entities that will
implicate the D&O Policy; review memorandum drafted by TK
regarding issues relevant to D&O response and research issues
raised by memo.
07/08/09 T W Mountz 2.30 Review of TK memo re D&O proceeds; emails to J. Cialone
and others re insurance issues; review of Stanford filing re
D&O issues in criminal case; conference with T. Durst re D&O
issues; conferences with J. Lawrence re pending claims and
D&O policy.
07/09/09 J A Cialone, II 2.10 Worked on D&O insurance issues; calls and emails throughout
the day regarding same; calls and emails with Roper about
insurance; worked through insurance issues with Mountz and
Durst; related calls throughout the day.
07/09/09 J B Lawrence 2.80 Review cases filed against Receivership Entities to determine
impact on D&O Policy, for response to Holt motion; research
case law for response to Holt D&O motion.
188
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 122 of 377
Page 121
Hours Description
07/09/09 T W Mountz 5.20 Conferences with J. Cialone and T. Durst re insurance issues;
emails to J. Cialone re insurance questions; telephone
conference with R. Roper and Thompson Knight lawyers re
D&O issues.
07/10/09 J A Cialone, II 1.00 Calls and emails with counsel for criminal defendants about
insurance.
07/10/09 J A Cialone, II 1.40 Prepared for and participated in extended conference call about
insurance; attention to Stein issues related to insurance; calls
and emails about insurance.
07/10/09 J B Lawrence 5.90 Continue researching and drafting response to Holt D&O
insurance motion.
07/10/09 T W Mountz 4.10 Telephone conference with B. Chasnoff re call; conference call
with R. Janvey and Thompson Knight re insurance issues;
conference call with Akin Gump re insurance issues;
conferences with J. Cialone and T. Durst re insurance; review
of Maldonado filing; conference with J. Lawrence re response
brief; legal research re bankruptcy D&O cases.
07/11/09 J A Cialone, II 1.10 Calls and emails about insurance including communications
with Akin Gump, counsel to insurers.
07/11/09 J B Lawrence 6.70 Continue researching, drafting, and revising response to Holt
D&O motion.
07/11/09 T W Mountz 4.30 Review of Louisiana cases; email to J. Cialone re Louisiana
cases; conferences with J. Lawrence re response to D&O
motion; review of and revisions to motion.
07/12/09 J A Cialone, II 2.40 Calls and emails related to insurance; reviewed draft insurance
brief.
07/12/09 J B Lawrence 2.70 Continue drafting response to D&O motion.
07/12/09 T W Mountz 5.80 Drafting brief in response to motion for access to D&O
proceeds; conferences with J. Lawrence re brief and legal
research.
07/13/09 J B Lawrence 1.90 Continue drafting response to D&O motion.
07/13/09 T W Mountz 4.90 Email to R. Janvey re call with insurance carriers counsel;
review of draft response from Thompson Knight; conferences
with J. Cialone, T. Durst and J. Lawrence re response; drafting
response brief and proposed order; conference with K. Scanlan
re Louisiana cases.
07/14/09 J A Cialone, II .80 Attention to insurance brief.
07/14/09 T W Mountz 3.90 Conference with T. Durst re D&O brief; conference with J.
Cialone re brief; revisions to draft brief; email to R. Roper re
189
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 123 of 377
Page 122
Hours Description
brief.
07/15/09 J A Cialone, II .80 Attention to insurance issues.
07/15/09 T W Mountz 2.20 Telephone conferences with T. McCormick and B. Banowsky;
conferences with J. Cialone and T. Durst re revisions to brief;
review of and revisions to response brief.
07/16/09 J A Cialone, II 1.80 Attention to insurance brief and related calls.
07/16/09 J B Lawrence 1.00 Edit and revise response to D&O motions; prepare same for
filing.
07/16/09 T W Mountz .80 Emails to R. Janvey and Thompson Knight re D&O response
brief; conferences with J. Lawrence and K. Scanlan re brief.
07/17/09 J A Cialone, II 1.00 Attention to insurance issues; delivered insurance brief to USA.
07/21/09 C N Adams .40 Attention to director and officer indemnification issues.
07/21/09 J A Cialone, II 1.00 Conference call on insurance issues and strategies.
07/21/09 T W Mountz .50 Participation in call with Patton Boggs re insurance issues;
conference with J. Cialone re call; review of emails regarding
insurance issues from J. Tillotson.
07/22/09 J A Cialone, II .40 Calls and emails related to insurance.
07/22/09 T W Mountz .80 Telephone conference with B. Shriner (counsel for J.
Tarentino) re D&O insurance issues; email to J. Cialone and T.
Durst re call; conference with J. Rubenstein re correspondence
regarding excess SIPC policy.
07/23/09 T W Mountz .10 Review of additional motion to intervene in connection with
D&O policy motion.
07/25/09 J A Cialone, II .60 Reviewed insurance materials.
07/26/09 J A Cialone, II .40 Attention to insurance issues.
07/26/09 T W Mountz .20 Review of email from J. Rubenstein re SIPC policy; review of
policy and email to J. Rubenstein re additional research.
07/27/09 J A Cialone, II .80 Attention to insurance correspondence and responses.
07/27/09 T W Mountz .20 Telephone conference with R. Zuckerman re D&O status.
07/28/09 J A Cialone, II .80 Reviewed and considered response to Akin Gump
correspondence about insurance.
07/28/09 T W Mountz .70 Drafting letter in reply to Akin Gump letter; conference with J.
Cialone and telephone conference with D. White re letter;
telephone conference with R. Zuckerman re meeting.
07/29/09 J A Cialone, II .60 Attention to insurance issues and related calls.
190
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 124 of 377
Page 123
Hours Description
07/29/09 T W Mountz .50 Emails to M. Myers re insurance policies; review of order re
D&O policy; conference with J. Fitzwater re D&O policy.
07/30/09 J A Cialone, II 1.00 Reviewed and considered response to brief of Defendant Holt
regarding insurance; calls and emails about insurance.
07/30/09 T W Mountz 3.40 Review of Holt D&O reply brief; conference with J. Lawrence
re reply brief; emails to J. Cialone, K. Sadler, and T. Durst re
reply brief.
07/31/09 J A Cialone, II .60 Worked on insurance issues.
07/31/09 T W Mountz 1.00 Telephone conference with D. White at Thompson Knight re
D&O policies and Holt reply brief; review of insurance
policies.
08/01/09 T W Mountz 1.20 Email to J. Cialone re current D&O issues; email to J.
Rubenstein re notice of circumstances letter.
08/02/09 J A Cialone, II .90 Attention to D&O insurance issues and materials; related
emails.
08/03/09 T W Mountz 1.40 Review of hearing transcript; conference with M. Scott re
insurance issues and letter to D&O carriers; review of Stanford
D&O reply brief; telephone conference with M. Myers re
insurance coverage issues.
08/03/09 K Scanlan .80 Office conference regarding insurance submissions; pull copies
of previously submitted notice letters and support and forward
to Mary Scott.
08/03/09 M L Scott 1.00 Meeting with Tim Mountz about sending facts and
circumstances notice to D&O and professional liability
carriers; emails with Kevin Scanlon about file; reviewing
February notice letter to the D&O carrier; teleconference with
Kevin Scanlon about insurance file; giving instructions to
James Fitzwater about lawsuits filed against Stanford entities
and former employees.
08/04/09 J S Fitzwater .90 Continuing to assist Kevin Scanlan and Mary Scott regarding
submission to D&O professional indemnity insurance carriers.
08/04/09 T W Mountz 1.70 Review of additional brief filed on D&O issues; meeting with
R. Zuckerman and M. Orwig re insurance issues; conference
with J. Cialone and T. Durst re insurance matters; emails to D.
White at Thompson Knight re insurance correspondence;
telephone conference with D. White re correspondence;
conference with M. Scott re correspondence.
08/04/09 K Scanlan 3.20 Office conference with Mary Scott regarding insurance matters
and pull copies of additional materials relating to same;
respond to request for information from Tim Mountz and
191
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 125 of 377
Page 124
Hours Description
provide requested materials; office conference with Mary Scott
concerning various charts that show interventions and related
claims and preparation for meeting and additional needed
materials; pull materials requested by Mary Scott for meeting
and update charts as needed.
08/04/09 M L Scott .50 Reviewing insurance notices; conference with Tim Mountz
about same; giving Ginger Williford instructions about same;
emails with T. Mountz about same.
08/05/09 J S Fitzwater 1.40 Continuing to assist Kevin Scanlan and Mary Scott regarding
submission to D&O insurance and professional indemnity
carriers.
08/05/09 K Scanlan 5.20 Continue to pull materials for Mary Scott; copy pleadings in
cases where intervention or complaint raises claim against
broker or Stanford entity regarding claim which may be
covered by policies; update charts with information specifically
requested; prepare for and attend meeting to go over pending
motions, interventions and separate suits; work with Mary
Scott on compiling data for D&O insurance submission.
08/05/09 M L Scott 4.80 Working on insurance notice letter; reviewing complaints,
petitions, and miscellaneous claims for same; meeting with
Kevin Scanlan about same; conferences with K. Scanlan about
same.
08/06/09 J S Fitzwater .90 Continuing to assist Kevin Scanlan and Mary Scott regarding
submission to D&O insurance carrier.
08/06/09 T W Mountz .40 Telephone conference with R. Zuckerman; email to J. Cialone
and T. Durst re meeting schedule.
08/06/09 K Scanlan 3.50 Continue to pull pleadings from various cases and claims for
Mary Scott review.
08/06/09 M L Scott 3.50 Working on notice of claims letter; emails with Kevin Scanlan
about same; conference with K. Scanlan about same;
conference with John Lawrence about claims and lawsuits;
reviewing spreadsheet and claims from J. Lawrence.
08/07/09 J A Cialone, II .80 Calls and emails about policy analysis and other insurance
issues.
08/07/09 J S Fitzwater 1.10 Continuing to assist Kevin Scanlan and Mary Scott regarding
submission to D&O insurance carrier.
08/07/09 T W Mountz .20 Review of joinders in D&O motion; emails to and from J.
Cialone and T. Durst re meeting.
08/07/09 K Scanlan 4.90 Office conference with Mary Scott concerning D&O
submissions; office conference with Mary Scott on follow-up
192
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 126 of 377
Page 125
Hours Description
direction for specific matters to be highlighted for review;
provide copies of interventions and state and federal cases
REDACTED
; review all
interventions and update chart of claims made by new
intervenors and plaintiffs as needed for review; prepare counsel
list for broker related cases to assist in review; prepare
notebooks for Mary Scott with requested cases and supporting
materials.
08/08/09 J A Cialone, II 1.20 Analyzed insurance policies in
REDACTED
.
08/08/09 T W Mountz 4.10 Review of D&O and indemnity insurance policies; conference
with M. Scott re insurance correspondence; email to J. Cialone
re analysis of policy coverage.
08/08/09 K Scanlan 5.50 Continue to work on insurance submission and invoice review.
08/08/09 M L Scott .30 Conference with Tim Mountz about D&O and Professional
Indemnity policies.
08/09/09 K Scanlan 9.50 Continue to review and highlight invoices for various subjects
and prepare summary.
08/10/09 J A Cialone, II .80 Calls and emails about insurance.
08/10/09 J B Lawrence 7.20 Research law regarding interpretation of certain provisions of
D&O and related insurance policies.
08/10/09 T W Mountz 2.60 Conference with J. Lawrence re legal research on policy issues;
conference with M. Scott re notice of circumstances letter;
review of and revisions to notice of circumstances letter;
telephone conference with R. Zuckerman re insurance meeting;
conference with J. Cialone re insurance issues; email to D.
White re letter to carriers.
08/10/09 K Scanlan 9.50 Numerous office conferences with Mary Scott concerning
insurance submissions; review D&O data and highlight per
Mary Scott direction; prepare notebook of all pleadings relating
to claim against brokers and Stanford entities; provide
highlighted version of data and summary; continue to review
and highlight bills for various issues and prepare summaries;
office conference with James Fitzwater to provide guidance on
invoice review.
08/10/09 M L Scott 4.20 Drafting and revising notice of claims; conference with Tim
Mountz about same.
08/11/09 J A Cialone, II 1.20 Attention to insurance issues including notice letter and policy
interpretation.
193
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 127 of 377
Page 126
Hours Description
08/11/09 J S Fitzwater 1.60 Continuing to assist Kevin Scanlan to identify records related
to various scopes of work in the D&O insurance claims
process.
08/11/09 J B Lawrence 6.10 Continue research on law regarding interpretation of certain
provisions of D&O and related insurance policies.
08/11/09 T W Mountz 1.40 Conferences with M. Scott re insurance letter; conference with
J. Lawrence re insurance coverage issues; review of email from
R. Zuckerman.
08/11/09 K Scanlan 9.50 Prepare spreadsheet of all highlighted descriptions and costs
for both broker related claims and for FBI and SEC document
productions; office conference with Mary Scott concerning
refinement of spreadsheets and reduction to Excel; office
conference with James Fitzwater concerning creating
spreadsheets as summaries of all selected entries by matter
number and by subject; provide Mary Scott with various
pleadings and documents as needed for insurance review and
case analysis regarding coverage issues.
08/11/09 M L Scott 3.00 Conferences with Tim Mountz regarding insurance notice;
teleconference with David White regarding same; revising
insurance notice letter; conferences with James Fitzwater and
Kevin Scanlan regarding insurance notice and submission.
08/12/09 J A Cialone, II 1.80 Reviewed insurance policies and prepared for insurance
meeting.
08/12/09 J S Fitzwater 3.90 Office conference with Kevin Scanlan regarding the adaptation
of categories into XLS spreadsheet form for D&O insurance
submission; assembling revised data for brokerage claims;
continue assembling XLS spreadsheets containing data for
various scopes of work.
08/12/09 J B Lawrence 1.70 Continue research on law regarding interpretation of certain
provisions of D&O and related insurance policies.
08/12/09 T W Mountz 1.60 Review of and revisions to insurance notice letter; conferences
with M. Scott re letter; telephone conference with D. White and
conference with J. Cialone re letter; telephone conferences with
R. Zuckerman and emails re meeting.
08/12/09 K Scanlan 7.50 Total all time and costs for each matter number; create
summaries; office conference with James Fitzwater regarding
redaction and means for consistent marking; brief office
conference with Mary Scott regarding summaries.
08/12/09 M L Scott 5.10 Working on insurance notice letter and finalizing same;
conference with Tim Mountz about same; conference with Tim
Mountz and Joe Cialone about same; emails and conference
194
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 128 of 377
Page 127
Hours Description
with David White about same; emails to insurance carriers and
counsel regarding notice of circumstances letter; conferences
with John Lawrence about same; and reviewing letters from
carriers.
08/13/09 J A Cialone, II 4.10 Prepared for and participated in extended meeting regarding
insurance and related matters; reviewed insurance materials.
08/13/09 T S Durst 2.90 Meeting with opposing counsel regarding insurance issues and
coverage matters; analysis of issues and options regarding
same; conference with Mr. Cialone, Mr. White and Mr. Mountz
regarding same.
08/13/09 T W Mountz 2.40 Meeting with R. Zuckerman and counsel re insurance issues;
conferences with D. White, T. Durst and J. Cialone re meeting.
08/13/09 K Scanlan 1.50 Pull copies of all insurance submissions and add to insurance
file; update charts; revise summaries as needed.
08/14/09 J A Cialone, II .40 Attention to Latin American insurance notices.
08/14/09 M L Scott 3.70 Working on additional notice of claims letter; reviewing claims
regarding same; conference with Tim Mountz about same;
emails with D. White about letter from Thompson & Knight;
reviewing same; working on protocol for allocations to the
different insurance policies.
08/17/09 T W Mountz .30 Telephone conferences with R. Zuckerman and D. White re
insurance issues.
08/17/09 W F Stutts, Jr. .40 Reviewed inquiry from Mr. Fram regarding insurance premium
payment and communicated with Mr. Adams on the topic;
REDACTED
.
08/18/09 J A Cialone, II .80 Attention to insurance issues.
08/18/09 T S Durst .80 Attention to insurance matters; communications with opposing
and co-counsel; analysis of matters regarding criminal
defendants.
08/19/09 J A Cialone, II .90 Calls, meetings and emails about insurance.
08/20/09 J A Cialone, II 3.60 Worked on insurance issues and strategies; related calls and
emails; reviewed insurance file; call with Roper about
insurance; reviewed and discussed discovery requests related to
insurance.
08/20/09 T W Mountz 1.20 Participation in BB call re insurance and other matters;
telephone conference with J. Cialone and R. Roper re insurance
issues.
08/21/09 J A Cialone, II 2.40 Prepared for and participated in an extended conference call
195
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 129 of 377
Page 128
Hours Description
with Akin Gump REDACTED
.
08/21/09 T W Mountz 1.00 Arrangements for call with Akin Gump; conference call with
B. Chasnoff, M. Lane, and J. Cialone re insurance matters;
email to K. Sadler and J. Cialone re Akin Gump call.
08/21/09 M L Scott 1.20 Working on insurance protocol and allocation between
insurance policies.
08/23/09 J A Cialone, II 1.20 Emails to and from team about an interim deal on insurance
REDACTED ;
considered alternative strategies.
08/23/09 T W Mountz .30 Email to J. Cialone and K. Sadler re insurance issues.
08/25/09 J A Cialone, II .80 Reviewed docket entry from Judge Hittner directing Receiver
to make a filing respecting D&O insurance.
08/25/09 J A Cialone, II .80 Reviewed filings by Lopez and Holt related to insurance.
08/25/09 J A Cialone, II .50 Calls and emails related to insurance strategy and attempts to
secure insurance for the estate.
08/25/09 T S Durst .70 Attention to insurance filings and notice from Judge Hittner;
review of matters regarding discovery on same; conference
with team regarding filings and go-forward action plan.
08/25/09 T W Mountz 5.30 Review of filings in Southern District case by Holt and Lopez;
email to R. Janvey and others summarizing filings; review of
correspondence from clerk re request for filing; conferences
with K. Sadler, J. Cialone and T. Durst re insurance issues;
telephone conference with R. Zuckerman re insurance.
08/25/09 M L Scott 4.60 Studying insurance policies and reviewing complaints/petitions
for protocol for submission.
08/26/09 J A Cialone, II .80 Calls to and from Zuchevman about insurance strategy, and
related emails with team; calls and emails with Roper about
responses to Hittner's questions.
08/26/09 T S Durst .30 Attention to issues regarding insurance, including document
production matters and report to Judge Hittner.
08/26/09 T W Mountz 1.80 Telephone conference with R. Zuckerman and emails with J.
Cialone re meeting; drafting letter to J. Tillotson and internal
email re insurance correspondence; review of emails from K.
Sadler, T. Durst and J. Cialone re correspondence; conference
with M. Scott re insurance coverage issues.
08/26/09 M L Scott 5.40 Working on protocol for submission; studying insurance
policies; reviewing complaints/petitions; conference with Tim
Mountz about same.
196
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 130 of 377
Page 129
Hours Description
08/27/09 J A Cialone, II 2.60 Continued work on discovery requests related to insurance;
attention to insurance strategies REDACTED
; related calls and emails.
08/27/09 M L Scott 2.30 Working on insurance issues relating to claims.
08/28/09 T S Durst .50 Attention to issues regarding insurance, matters regarding
defense counsel, and discovery matters with Ms. Holt's
counsel; communications with team regarding related pending
items.
08/31/09 J A Cialone, II 1.70 Prepared for insurance meeting and/or call with Akin Gump
and others.
Matter Total 341.80
079716.0110 Labor and Employment Matters
Hours Description
06/01/09 C N Adams .30 Reviewing letter regarding COLI policies.
06/01/09 M W Brown 7.00 Conference with Mike Myers regarding trust and IRA matters;
attention to Forrest/Francis family trust documents and related
questions regarding appointment documents; telephone
conference with Sophia Lewis regarding same; attention to
questions regarding Dietz trust and prepared email to Hunt
Worth regarding same; attention to questions regarding
distribution of certificates of deposit and related claims held in
IRA accounts; further attention to Forrest/Francis family trusts
and related discussion with Sophia Lewis regarding same.
06/01/09 J R Raborn .50 Responded to requests for information.
06/02/09 C N Adams .50 Revising FAQs regarding employee payments.
06/02/09 M W Brown 4.70 Attention to IRA questions; various conferences with Mike
Myers; telephone conference with Bill Stutts, Jim Raborn and
Mike Myers regarding certificates of deposit held in IRA
accounts; worked on Declaration of Assignment of Claims
regarding to certificates of deposit; attention to Newland trust
questions and prepared email to Sophia Lewis regarding same.
06/02/09 J R Raborn 2.20 Reviewed COLI issues and meeting with Maggie Brown and
Mike Myers on disposition of Stanford Trust Company
accounts; prepared memorandum REDACTED .
06/02/09 A M Sulentic 1.90 Office conference with Jim Raborn regarding update on
Department of Labor audits; telephone conference with Mark
Bodron regarding record-keeping agreement; review of record-
keeping agreement and preparation of email memorandum
197
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 131 of 377
Page 130
Hours Description
regarding same.
06/03/09 C N Adams .40 Attention to employee claims issues; attention to employee
claims FAQs.
06/03/09 M W Brown 7.00 Worked on revisions and further drafting of FAQs regarding
IRA and tax matters; telephone discussions with Mike Myers
(several) regarding same; reviewed and attention to Hughes,
Farquhar and Verner trust documents and related questions.
06/03/09 J R Raborn .80 Addressed responsibility for termination of plans and periodic
reporting and telephone conference with Malcolm Lovett.
06/04/09 C N Adams .40 Attention to employee issues.
06/04/09 M W Brown 7.00 Attention to Cobb, McKenzie, Hughes, Verner, Durham, Dietz
and Mary Elizabeth Puette Francis trust documents and related
appointment questions; telephone conferences with Sophia
Lewis discussing same and pending matters.
06/04/09 J R Raborn .60 Telephone conference with Malcolm Lovett regarding plan and
staffing windows.
06/05/09 M W Brown 5.70 Reviewed and attention to Brugh trust documents and related
questions; discussed same with Sophia Lewis; reviewed and
attention to Page trust documents and related questions, and
discussed same with Sophia Lewis; prepared email to Hunt
Worth regarding comments; telephone conference with John
Dunham regarding FIMC trust questions and attention to same.
06/06/09 J A Cialone, II .60 Attention to employee benefit plans issues; related calls.
06/08/09 M W Brown 2.10 Attention to email from Margaret Dietz Domanski regarding
Dietz trust; telephone conference with Stephen Melcer
regarding transfer of Melcer trust accounts to Oppenheimer;
telephone conferences with Sophia Lewis regarding pending
matters; attention to Cobb trust documents and related
questions; telephone discussions with Sophia Lewis regarding
transfer of trust accounts.
06/08/09 J R Raborn .70 Followed up on COLI proceeds; telephone conference with
Malcolm Lovett and prepared for meeting on Tuesday.
06/09/09 M A Bodron 2.00 Office conference with Jim Raborn
REDACTED
; office conference with Alison Sulentic
concerning same.
06/09/09 M W Brown 4.40 Attention to FIMC trust questions; telephone conference with
John Dunham at FIMC regarding Comerica's appointment as
successor trustee; attention to questions regarding the Klopman
trusts; telephone conference with Sophia Lewis regarding
198
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 132 of 377
Page 131
Hours Description
Klopman trust matter; telephone conference with Edmund
Griggs REDACTED
; telephone conference with John Dunham and reviewed
email from him regarding FIMC trust matter; attention to email
from Edmund Griggs.
06/09/09 J G O'Quinn 1.40 Office conference with Alison Sulentic REDACTED
and gathered information regarding same for
Alison Sulentic to prepare timeline; REDACTED
.
06/09/09 J R Raborn 1.30 Office conference with Malcolm Lovett; reviewed emails from
Pam Ward; telephone conference with Joe Cialone.
06/09/09 A M Sulentic 2.20 Office conference with Mark Bodron REDACTED
; office conference with Jeannene O'Quinn
regarding same; office conference with Jim Raborn regarding
preparation of letter requesting restitution of amounts paid to
contractor; attention to same.
06/10/09 M A Bodron .50 Reviewed demand letter from Don Wood; office conference
with Alison Sulentic REDACTED
.
06/10/09 M W Brown 2.30 Attention to Tellar trust documents; attention to Wides trust
documents; attention to Klopman trust questions; attention to
Kilmer trust documents; attention to Melcer trust questions;
telephone discussion with Mike Myers regarding pending and
IRA matters; telephone conference with Steve Melcer
regarding appointment of successor trustee for his family's
trusts; telephone conference with Sophia Lewis regarding Peter
Durham Marital Trust.
06/10/09 J G O'Quinn 1.30 Continued working on REDACTED
.
06/10/09 J R Raborn 1.40 Responded to inquiry on status of officers and directors and
related insurance and indemnity; reviewed letter to receiver
regarding pay matters.
06/10/09 A M Sulentic 1.20 Research regarding and preparation of summary of steps to be
taken REDACTED .
06/11/09 M W Brown 7.00 Attention to McArthur trust documents, and related trustee
appointment; attention to Brugh trust documents, and related
trustee appointments; two telephone conferences with Steven
Melcer regarding Melcer trustee appointment; reviewed new
FIMC trust agreement with Comerica, and noted questions;
several telephone conferences with Sophia Lewis; telephone
conference with Steven Spiegel regarding FIMC trust
questions.
199
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 133 of 377
Page 132
Hours Description
06/11/09 J R Raborn .40 Responded to questions about 401(k) plan issues.
06/12/09 M A Bodron 1.00 Reviewed 401(k) Plan record-keeping agreement with Alison
Sulentic; forwarded issues related to same to Newport, the
record-keeper; REDACTED ;
reviewed employee demand letter with Jim Raborn.
06/12/09 M W Brown 3.50 Attention to FIMC trustee appointment questions, and related
documentation; attention to IRA reporting and valuation
questions; attention to McArthur trust questions.
06/12/09 J G O'Quinn .90 Continued working on IRS application REDACTED
06/12/09 A M Sulentic 4.60 Review of Newport record-keeping agreement; office
conference with Mark Bodron regarding same; review of
Endorsement Agreement and related amendments regarding
licensing agreement; preparation of correspondence regarding
same.
06/13/09 J R Raborn 1.20 Reviewed communications from Susan Skarness and pulled
materials on plans termination issues.
06/14/09 J R Raborn .40 Reviewed emails regarding REDACTED
emails from Pam Ward and Susan Skarness.
06/15/09 M A Bodron .60 Reviewed outstanding welfare plan documents; office
conference with Alison Sulentic concerning same; telephone
conference with Jim Raborn and Alison Sulentic concerning
same.
06/15/09 M W Brown 4.00 Telephone conference with Sophia Lewis regarding M.
Fishman's trusts and other pending trust matters and work
related to same; telephone conference with Steven Spiegel
regarding FIMC successor trustee appointment; attention to
requested email; attention to questions regarding Fishman's
unitrust and reviewed related trust documents.
06/15/09 J R Raborn .90 Telephone conference with Mark Bodron and Alison Sulentic
regarding actions to termination plans and prior responses to
the DOL.
06/15/09 W F Stutts, Jr. .40 Reviewed information received from Alison Sulentic regarding
VJ Singh questions and commented on draft proposal;
communications with and reviewed information from John
Greer and Tucker Harrison.
06/15/09 A M Sulentic 4.20 Telephone conference with Jim Raborn regarding termination
of endorsement agreement; drafting of letter from Receiver
regarding termination of endorsement agreement; office
conference with Jim Raborn and Mark Bodron regarding Pam
200
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 134 of 377
Page 133
Hours Description
Ward's questions concerning audit requirements for flexible
benefits plan; research regarding same.
06/16/09 M A Bodron .40 Office conference with Alison Sulentic concerning status of
401(k) Plan issues; reviewed same.
06/16/09 M W Brown 7.00 Attention to IRA questions per discussions with John Coker;
telephone conference with John Coker and Sophia Lewis;
arranged for conference call; attention to Causey's IRA
question and telephone conference with John Coker regarding
tax questions related to same; attention to questions regarding
Klopman trusts; telephone conference with Mike Myers;
telephone conference with Eric Soderlund; office conference
with Jim Raborn, John Coker and Sophia Lewis; attention to
research regarding IRA withholding and reporting
requirements REDACTED ;
telephone conference with John Coker regarding same.
06/16/09 J R Raborn 1.40 Telephone conference with Maggie Brown, Mike Myers and
FTI regarding IRAs; emails regarding request from politician
regarding employees.
06/16/09 A M Stockbridge .90 Researched REDACTED
.
06/16/09 A M Sulentic 2.40 Research and review of documents and preparation of list of
action items REDACTED ;
preparation of correspondence regarding termination of
endorsement agreement for Vijay Singh.
06/17/09 M W Brown 6.70 Further attention to Causey tax questions and regarding IRA
withholding questions; discussed same with John Coker;
attention to McArthur trust documents and related questions
regarding appointment of successor trustee; telephone
conference with Sophia Lewis; attention to Margaret Verner
and Hugh Verner trust documents and related questions
regarding appointment of successor trustee; discussed same
with Sophia Lewis; attention to March 12, 2009 Order and
application questions regarding appointment of successor
trustee for Klopman trusts, per questions by Klopman attorney;
two telephone conferences with Sophia Lewis.
06/17/09 A M Stockbridge 5.10 Continued to research IRA REDACTED and rules
regarding REDACTED .
06/17/09 W F Stutts, Jr. .20 Reviewed information from Ms. Sulentic regarding termination
of VJ Singh agreement.
06/17/09 A M Sulentic 1.00 Continued preparation of list of action items relative to
REDACTED ; telephone conference with Jim
Raborn regarding correspondence concerning termination of
201
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 135 of 377
Page 134
Hours Description
endorsement agreement with Vijay Singh; revision of same.
06/18/09 M W Brown 1.50 Attention to IRA tax reporting questions relating to 5498s and
1099-Rs.
06/18/09 J G O'Quinn 1.60 Continued preparing IRS application to REDACTED
.
06/18/09 J R Raborn .50 Reviewed letter to employee regarding 401(k) plan.
06/18/09 A M Sulentic 1.40 Review and analysis of plan documents in connection with
REDACTED .
06/19/09 M A Bodron 2.50 Attention to outstanding 401(k) plan issues and disposition of
same; reviewed researched prepared by Alison Sulentic
concerning same; office conference with Alison Sulentic
concerning same; reviewed status of other employee benefits;
telephone conference with Jim Raborn concerning same
06/19/09 M W Brown 1.30 Attention to emailed questions from Mike Myers regarding
IRA matters; telephone conference with Mike Myers
discussing 5498 questions; discussed IRA tax questions with
Angela Stockbridge and attention to same; prepared email
regarding questions to be addressed.
06/19/09 J G O'Quinn .70 Office conference with Alison Sulentic regarding action needed
REDACTED and reviewed checklist and plan
documents regarding same.
06/19/09 J R Raborn 1.70 Responded to requests from Malcolm Lovett regarding DOL
investigations and certain plans; emails from Pam Ward
regarding plan actions and payment of interest on
contributions.
06/19/09 A M Stockbridge 1.70 Researched valuation of assets in an IRA distribution;
researched 1099-R and Form 5498 requirements.
06/19/09 A M Sulentic 3.10 Office conference with Jeannene O'Quinn regarding plan
termination procedures; office conference with Mark Bodron
regarding same; revision of list of action items based on review
of plan documents and supporting administrative services
agreement.
06/20/09 J R Raborn 1.50 Reviewed list of 401(k) items and information from Charlene
McDougal regarding employee communications.
06/21/09 A M Stockbridge 3.10 Researched valuation of assets in an IRA distribution;
researched 1099-R and Form 5498 requirements.
06/22/09 M W Brown 5.50 Attention to IRA-related emails; attention to tax research by
Angela Stockbridge regarding reporting and disclosure issues,
and withholding questions; discussed same with Jim Raborn;
conference call with John Coker and Jim Raborn; attention to
202
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 136 of 377
Page 135
Hours Description
emailed questions from Mike Myers; prepared attachment
regarding valuation matters for Forms 5498; prepared email to
Edmund Griggs responding to questions regarding the
Klopman trusts; telephone conference with Sophia Lewis.
06/22/09 J R Raborn 1.50 Telephone conference with Alison Sulentic regarding REDACTED
; responded to questions regarding treatment of STC
accounts and valuations of assets for Form 5498 filing; office
conference with Maggie Brown.
06/22/09 A M Sulentic 7.20 Research regarding Form 5500 filing requirements and
Delinquent Filer Voluntary Compliance Program with regard to
REDACTED .
06/23/09 M W Brown 5.60 Attention to Brugh trust documents and questions related to
appointment of successor trustee; attention to Hughes trust
documents and questions related to appointment of successor
trustee; telephone conference with Sophia Lewis regarding
Brugh and Hughes matters; attention to Melcer trust documents
and questions related to appointment of successor trustee;
attention to assignment of partnership interests in Melcer trusts
to successor trustee, and discussed same with Sophia Lewis;
telephone conference with Edmund Griggs regarding REDACTED
06/23/09 J R Raborn 1.10 Worked on issue for welfare plans annual reports and telephone
conference with Susan Skarness.
06/23/09 A M Sulentic 4.30 Office conference with Jim Raborn regarding Form 5500
compliance issues relating to welfare plans; research regarding
same.
06/24/09 M W Brown 6.50 Attention to questions regarding G. Reid Murray trust and
James Hornaday Murray, Jr. trust, and reviewed related trust
documents; attention to removal of Stanford Trust Company as
Co-Executor of Estate of Mary Ann K. Bush; reviewed
additional Brugh trust documents; telephone conference with
T. Austin at First Citizens; telephone conference with Amy
Kincaid regarding Bush estate; attention to email from Troy
Lillie; attention to email from John Coker regarding IRA
questions and responded to same by email; conference with
Mike Myers regarding Troy Lillie email and other ExxonMobil
IRA accounts.
06/24/09 J R Raborn 1.00 Responded to Susan Skarness' request for information on
proper administration; telephone conference with Alison
Sulentic.
06/24/09 A M Stockbridge 1.20 Researched notice of election not to withhold for IRA
nonperiodic distribution.
203
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 137 of 377
Page 136
Hours Description
06/24/09 A M Sulentic 1.20 Review of matters pertaining to Form 5500 filing for welfare
benefit plans.
06/25/09 M W Brown 6.00 Telephone conference with Amy Kincaid regarding accounting
obligations for Bush estate; attention to Melcer Assignments of
Limited Partnership Interest to successor trustee; telephone
conference with Mike Myers regarding same; telephone
conference with Sophia Lewis; telephone conference with
Christy Lambertus regarding issues regarding Farquhar trust
appointment of successor trustee; telephone conference with
Michelle Goldberg regarding Kilmer trusts; conference with
Stephanie Loomis-Price regarding Kilmer trusts; prepared
email to Michelle Goldberg; telephone conference with Sophia
Lewis; attention to Farquhar trustee appointment questions and
related Florida statutes.
06/25/09 J R Raborn 1.80 Followed up REDACTED information required to
shut down claims and administration runoff.
06/25/09 A M Stockbridge 1.20 Drafted and revised notice of election not to withhold for IRA
nonperiodic distribution.
06/25/09 A M Sulentic 4.70 Review of documents pertaining to group welfare benefits
arrangements; research regarding Form 5500 filing; preparation
of e-mail memorandum to Jim Raborn regarding same; office
conference with Jim Raborn regarding same.
06/26/09 M W Brown 5.20 Attention to FIMC Non-Insured Claims Trust appointment of
successor trustee; attention to petitions filed for Kilmer trusts
and discussed same with Keri Brown; attention to emails to and
from Michelle Goldberg regarding Kilmer trusts; worked on
IRA Notice of Withholding and related election form; attention
to questions regarding FIMC trust; attention to question
regarding appointment of successor trustee for Newland trust;
conference with Jeff Raley regarding Leverich trust; telephone
conference with Sophia Lewis discussing all of same;
telephone conference with Sophia Lewis regarding LeBlanc
pledged account.
06/26/09 M C Hurd .20 Office conference with Keri Brown regarding strategy for
answer in STC matter.
06/29/09 M W Brown 3.00 Attention to Josephine Crosby estate documents; telephone
conference with Sophia Lewis discussing Crosby, FIMC, and
Leverich trust and estate matters; met with Jeff Raley to
discuss Leverich and other pending trust matters.
06/29/09 J T Leslie .10 Coordinated for employee pay matters.
06/30/09 M A Bodron .50 Office conference with Alison Sulentic concerning status of
401(k) plan record-keeping agreement REDACTED ;
204
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 138 of 377
Page 137
Hours Description
reviewed researched concerning same.
06/30/09 M W Brown 4.70 Attention to questions regarding the two Murray trusts and
prepared email to Sophia Lewis regarding same; attention to
Leverich trust matter; prepared email to John Coker regarding
IRA questions; attention to LeBlanc pledged account and
information from Mike Myers regarding same; attention to IRA
questions for John Coker.
06/30/09 A M Sulentic .30 Office conference with Mark Bodron regarding update on
activities REDACTED and Form 5500
issues.
07/01/09 M W Brown 6.00 Discussed matters regarding Bush estate and accounting
requirements with Sophia Lewis; attention to North Carolina
accounting requirements; telephone conference with K.
Hutchison, Guilford County Estate Section Clerk, regarding
Order and accounting; follow-up telephone conference with
Sophia Lewis; attention to IRA questions and worked on same;
prepared email to John Coker; attention to Peter B. Durham
Trust documents and appointment questions.
07/02/09 M W Brown 4.00 Discussed Kilmer trusts and lawsuits related to same with Keri
Brown; attention to IRA questions; attention to Golden Age
Retirement trust documents for five related trusts, and
questions regarding same.
07/06/09 M W Brown 6.20 Attention to questions regarding appointment provisions under
James Hornaday Murray, Jr. Irrevocable Trust; attention to
Teller IRA account email; attention to Golden Age Retirement
Plan trust documents (Deferred Compensation Plan and Trust
Basic Plan Document, Joinder Agreement, Amendment to Plan
and Trust, and Notice, and other documentation relating to five
separates trusts); attention to 1/5/2000 Amendment, and Order
removing Stanford Trust Company as Trustee, and related
correspondence.
07/07/09 M W Brown 6.70 Attention to Golden Age Retirement trust and plan documents;
discussed with Jim Raborn; attention to email from Christy
Lambertus regarding termination of Farquhar trust and
discussed issues with Jeff Raley; attention to email from Amy
Kincaid regarding Bush estate accounting and emailed Sophia
Lewis regarding same; attention to questions regarding
Josephine Ruth Crosby estate; attention to questions regarding
Fishman pledged account, with related review of loan
transaction documentation; telephone conference with Sophia
Lewis regarding status of pending matters and above accounts;
conference with Jeff Raley regarding Leveridge trusts;
telephone conference with Hunt Worth regarding trust
provisions regarding James Hornaday Murray, Jr. Trust;
205
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 139 of 377
Page 138
Hours Description
telephone conference with Sophia Lewis REDACTED
07/07/09 A M Sulentic .50 Attention to status of issues relating to welfare plan's Form
5500 obligations and REDACTED .
07/08/09 M W Brown 7.00 Telephone conference with Sophia Lewis; telephone
conference with Hunt Worth regarding James Hornaday
Murray, Jr. trust documentation and regarding release of
pledged Fishman trust account; worked on Bush estate
accounting and prepared draft; telephone conference with Hunt
Worth further discussing Murray trust documentation;
telephone conference with Ed Griggs regarding Klopman trust
documentation; telephone conference with Sophia Lewis
regarding various trusts; further telephone conference with Ed
Griggs responding to his questions; telephone conference with
Sophia Lewis regarding Fishman trust pledged account;
telephone conference with Tony Davis regarding Fishman trust
pledged account and REDACTED
; telephone conference with Mary
Gregory; REDACTED
Bush estate accounting.
07/09/09 M W Brown 6.80 Prepared email to Sophia Lewis; further attention to questions
regarding REDACTED
and worked on accounting matters for Bush
estate; attention to Fishman loan transaction documents;
telephone conference with Sophia Lewis regarding Bush estate
and other pending trust accounts; worked on draft of Bush
accounting and emailed same to Amy Kincaid for review and
comments; attention to email from Amy Kincaid and
responded to same; prepared email to Sophia Lewis
summarizing pertinent loan transaction documents regarding
Fishman pledged account, to be sent to Hunt Worth; telephone
conference with Sophia Lewis regarding same.
07/09/09 J R Raborn 1.20 Telephone conference with Malcolm Lovett and Char
McDougal regarding REDACTED
07/09/09 A M Sulentic .70 Office conference with Jim Raborn regarding request for
information from Department of Labor; e-mail correspondence
regarding same.
07/10/09 M W Brown 6.00 Conference with Jeff Raley discussing Murray trust
documentation, Leveridge trust documentation and questions
regarding REDACTED ,
and Bush accounting; attention to Bush accounting and
206
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 140 of 377
Page 139
Hours Description
telephone conference with Amy Kincaid regarding same;
attention to email from Amy Kincaid; attention to Fishman
trust loan transaction documents; telephone conferences with
Sophia Lewis regarding pending matters; exchanged emails
with Tony Davis and Mike Myers regarding Fishman pledged
account; conference with Herschel Hamner regarding release
documentation for Fishman pledged account, and transmitted
loan transaction documents to him; second conference with
Herschel Hamner; attention to Fishman Revocable Trust
documents per questions from Herschel Hamner.
07/10/09 J G O'Quinn 1.80 Office conference with Alison Sulentic regarding REDACTED
; drafted Board resolutions REDACTED
07/10/09 J R Raborn 1.50 Conference call with Malcolm Lovett and reviewed issues
regarding plan shutdowns and contributions needed to satisfy
the DOL.
07/10/09 A M Sulentic .90 Office conference with Jim Raborn regarding REDACTED
; office conference with Jeannene O'Quinn
regarding preparation of resolutions and amendment regarding
same; e-mail correspondence with Mark Bodron and Jeannene
O'Quinn regarding same; attention to response to Department
of Labor's request for information regarding accounts with
Stanford International Bank Limited.
07/12/09 J R Raborn 1.20 Reviewed documents and emails to Mark Bodron.
07/13/09 M A Bodron 2.00 Reviewed and revised draft resolutions and REDACTED
; office conference with Jeannene
O'Quinn concerning same; reviewed status of DOL requests for
SIBL information.
07/13/09 M W Brown 4.70 Attention to questions regarding Antiguan plan per John Coker;
telephone conference with John Coker regarding status of
same; attention to question regarding distribution of Bush
estate assets; attention to questions regarding James Hornaday
Murray, Jr. trust and prepared analysis of provisions in that
trust and in sister's trust; discussed matter with John Coker.
07/13/09 J G O'Quinn 3.90 Began reviewing 401(k) Plan REDACTED
; office conferences with Mark Bodron
regarding questions relating to plan termination; revised Board
resolutions; reviewed summary of benefits work.
07/13/09 J R Raborn .70 Followed up on DOL requests for data.
07/14/09 M A Bodron 1.00 Reviewed and revised REDACTED amendment and
approving resolutions; office conferences with Jeannene
207
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 141 of 377
Page 140
Hours Description
O'Quinn and Jim Raborn concerning same.
07/14/09 J G O'Quinn .90 Office conference with Mark Bodron regarding Board
resolutions REDACTED and
revised amendment.
07/14/09 J R Raborn .50 Prepared communications to the DOL with results of inquiries.
07/14/09 A M Stockbridge .50 Research standard terms of promissory notes between
employees and company; research current federal interest rates.
07/16/09 J R Raborn .60 Sent resolutions regarding plan actions to Malcolm Lovett.
07/17/09 J R Raborn .80 Attention to 401(k) plan and DOL investigation.
07/20/09 M W Brown 3.00 Attention to questions asked regarding IRA accounts, and
related review of prototype IRA and Roth IRA agreements;
attention to IRS revenue ruling and revenue procedure;
telephone conference with Sophia Lewis regarding Brugh
charitable unitrust.
07/21/09 M A Bodron 1.40 Reviewed DOL correction issue for 401(k) plan; office
conference with Alison Sulentic concerning same; reviewed
status of 401(k) record-keeping agreement and 2008 census
report for 401(k) plan population and testing.
07/21/09 M W Brown 3.00 Attention to Nichole Gould's email regarding Golden Age
Home Care plan documents and related attention to five sets of
documents; telephone conference with Sophia Lewis regarding
same.
07/21/09 J R Raborn 1.40 Responded to questions about 401(k) plans, including audits
and report filings.
07/21/09 A M Sulentic 4.30 Office conference with Mark Bodron regarding status of 401(k)
plan issues; review of Keyashia Barkins' data concerning
prohibited transactions due to late transmission of deferrals;
calculation of lost earnings and interest attributable to
prohibited transactions.
07/22/09 M A Bodron .80 Reviewed DOL issues and "calculator" for late contributions;
office conference with Alison Sulentic concerning same;
reviewed DOL rules concerning same.
07/22/09 M W Brown 3.20 Attention to Brugh Charitable Remainder Unitrust documents,
received in five separate emails; discussed same with Sophia
Lewis; telephone conference with Hunt Worth regarding Brugh
and Murray accounts.
07/22/09 J R Raborn 1.70 Telephone conference with Rebecca Hank with the DOL Wage
and Hour Division; responded to the DOL's requests from
criminal investigation.
208
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 142 of 377
Page 141
Hours Description
07/22/09 A M Sulentic 1.80 Continued attention to calculation of lost earning and interest
on prohibited transactions relating to 401(k) Plan.
07/23/09 M A Bodron .50 Reviewed 401(k) plan late contribution corrections; REDACTED
07/23/09 M W Brown 7.00 Attention to trust agreement creating James Hornaday Murray,
Jr. Irrevocable Trust, with particular attention and analysis of
provisions addressing appointment of successor trustee, given
grant of joint powers, and beneficiary being under the age of 21
years; prepared memorandum of analysis of trust provisions;
attention to two emails regarding I. J. Sherman Irrevocable
Trust; attention to voicemail message from Hunt Worth
regarding Murray trust and Brugh charitable remainder unitrust
remainder beneficiary, and responded by email to his
questions.
07/23/09 J R Raborn .80 Reviewed calculations regarding delinquent contributions;
telephone conference with Joe Cialone.
07/23/09 A M Sulentic 5.80 Attention to issues pertaining to voluntary fiduciary corrections
program online calculator and Form 5330.
07/24/09 M A Bodron 1.50 Reviewed final DOL "calculator" results for late 401(k)
contributions; office conferences with Jim Raborn and Alison
Sulentic concerning same and related Form 5330 excise tax
return; Telephone conference with Malcolm Lovett concerning
same and termination status of 401(k) plan; forwarded data
concerning same to Mr. Lovett for review; office conference
with Jeannene O'Quinn concerning status of Form 5310
REDACTED .
07/24/09 M W Brown 2.00 Attention to Spencer Terry Testamentary Trust documents and
appointment of successor trustee; telephone conference with
Sophia Lewis discussing same; attention to trust agreements
creating trusts for Daniel and Alexandra Bernstein.
07/24/09 J G O'Quinn 1.20 Office conference with Alison Sulentic and reviewed
calculation of lost earnings and interest in connection with late
payments under the 401(k) Plan.
07/24/09 A M Sulentic 6.70 Finalized e-mail memorandum and calculations relating to
voluntary fiduciary compliance program and Form 5330.
07/27/09 M A Bodron 1.50 Office conference with Jim Raborn REDACTED
; office conference with Alison Sulentic
concerning DOL interest calculator and late contributions and
Form 5330 for 401(k) plan; reviewed Newport 5330 draft
materials; telephone conference with Malcolm Lovett
concerning same.
209
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 143 of 377
Page 142
Hours Description
07/27/09 M W Brown 5.20 Attention to correspondence from Hunt Worth regarding Brugh
charitable unitrust and determination of remainder charitable
beneficiary; worked on Bush estate accounting, with related
further attention to Bush estate account statements, Bush
charitable remainder unitrust account statements, Bush
revocable management trust account statements, Bush Will and
probate order.
07/27/09 A M Sulentic 1.10 Attention to calculation of lost earnings and interest owed to
401(k) plan; review of Form 5330 prepared by Newport; office
conference with Mark Bodron regarding same.
07/28/09 M A Bodron 1.50 Continued attention REDACTED and
related employee communications.
07/28/09 M W Brown 7.00 Attention to Peter B. Durham Marital Trust: Mediated Rule 11
and Settlement Agreement, and related pleadings and
correspondence regarding appointment of successor trustee;
reviewed Will and two codicils; telephone conference with
Sophia Lewis discussing all of same; telephone conference
with Mary Beth Todd; prepared email to Sophia Lewis;
telephone conference with Charlene Dykes regarding Bush
estate; reviewed additional Bernstein family trust agreements.
07/28/09 A M Sulentic 2.10 Telephone conference with Char McDougal relating to
payment of lost earnings and interest to 401(k) plan; office
conference with Mark Bodron regarding same; research
regarding Form 5330 and payment of excise taxes.
07/29/09 M A Bodron 1.40 Telephone conference with Jim Raborn and Malcolm Lovett
concerning REDACTED ;
reviewed Newport materials; forwarded information to Alison
Sulentic concerning same; reviewed telephone conference with
Malcolm Lovett concerning filing issues.
07/29/09 M W Brown 5.50 Attention to email from Mary Beth Todd regarding Durham
trust; attention to draft Agreement of Beneficiaries; telephone
conference with Rita Bishop at Encore Bank regarding Durham
trust; attention to trust related documents and agreements;
attention to new correspondence and related documents
received regarding the Margaret Dietz Domanski trust;
conference call with Susie Kornblitt and Rita Bishop regarding
Durham trust REDACTED
; telephone conference with Sophia
Lewis; telephone call to Bryan Calabrese at RBC Trust
Company.
07/29/09 J R Raborn .80 Telephone conference with Malcolm Lovett REDACTED
; responded to payroll inquiry.
210
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 144 of 377
Page 143
Hours Description
07/30/09 M A Bodron 2.00 Attention to IRS filings and REDACTED ;
office conferences with Jim Raborn and Alison Sulentic
concerning same; telephone conference with Malcolm Lovett
concerning filing issues.
07/30/09 M W Brown 4.60 Telephone conference with Sophia Lewis reviewing and
discussing pending status of 16 accounts; attention to email
from Jimmy Murray and to email from Mike Myers; telephone
conference with Sophia Lewis regarding Murray attorney's's
questions; telephone conference with Mike Myers regarding
Murray communications; attention to email from Amy Klass.
07/30/09 A M Sulentic 1.00 Attention to REDACTED
07/31/09 M A Bodron 1.20 Office conferences with Jim Raborn and Alison Sulentic
forfeitures and IRS filings; reviewed IRS Form 5500 filing
extension request for welfare plans; reviewed comments from
Newport concerning REDACTED
; office conference with Alison
Sulentic concerning same.
07/31/09 M W Brown 2.50 Attention to email from Amy Klass; discussed North Carolina
Trust Code statutes regarding appointment of successor trustee
and parent acting on behalf of qualified beneficiary in context
of Murray trust agreement; prepared email REDACTED
; telephone
conference with Mike Myers; telephone conference with Amy
Klass.
07/31/09 J G O'Quinn 1.10 Office conference with Jim Raborn, Mark Bodron and Alison
Sulentic regarding filing Form 5558 for welfare plan and
401(k) Plan; prepared Forms 5558 and drafted transmittal letter
regarding same.
07/31/09 J R Raborn 2.10 Telephone conference with Malcolm Lovett and worked with
Char McDougal and Mark Bodron regarding filings and
forfeitures.
07/31/09 A M Sulentic 1.00 Attention to REDACTED .
08/03/09 M A Bodron .30 Office conference with Alison Sulentic REDACTED
issues and project/time-line for same and other
outstanding issues.
08/03/09 M W Brown .70 Telephone conference with Sophia Lewis regarding LeBlanc
account and attention to related email; second telephone
conference with Sophia Lewis.
08/03/09 A M Sulentic 1.10 Telephone conference with Char McDougal REDACTED
211
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 145 of 377
Page 144
Hours Description
REDACTED ; attention to same.
08/04/09 M A Bodron 2.00 Reviewed and revised project list; office conference with
Alison Sulentic and Jim Raborn concerning same; telephone
conference with Char McDougal concerning same.
08/04/09 J G O'Quinn .60 Office conference with Alison Sulentic and office conference
with Mark Bodron REDACTED
08/04/09 J R Raborn .60 Sent information to the DOL regarding audit of 401(k) plans
and compliance.
08/04/09 A M Sulentic 2.30 Telephone conference with Mark Bodron and Char McDougal
regarding 401(k) plan issues; office conference with Jim
Raborn and Mark Bodron regarding 401(k) plan issues;
telephone conference with Char McDougal REDACTED
; attention to PAR and SERP
plan issues.
08/05/09 M A Bodron 1.50 Continued attention to REDACTED ; office
conferences with Jim Raborn and Alison Sulentic concerning
same; reviewed and revised documents related to same.
08/05/09 J G O'Quinn 1.30 Conference call with Alison Sulentic and Newport
representative REDACTED ; follow up
meeting with Mark Bodron and Alison Sulentic regarding
same; file research for information to include in Form 5310.
08/05/09 J R Raborn .60 Telephone conference with Mark Bodron and reviewed issues
regarding employee communications.
08/05/09 A M Sulentic 5.70 Continued attention to REDACTED ;
telephone conference with Carol Gore and Jeannene O'Quinn
REDACTED ; telephone conference with Char
McDougal regarding various Section 401(k) plan issues; office
conference with Mark Bodron regarding employee benefits
issues chart REDACTED .
08/06/09 M A Bodron 4.00 Attention to REDACTED and other
outstanding benefit matters; office conferences with Alison
Sulentic concerning same; reviewed and revised draft
documents and IRS forms.
08/06/09 J G O'Quinn 3.40 Office conference with Mark Bodron regarding questions
relating to IRS Form 5310 REDACTED
; revised Form 5310; prepared email to
record-keeper requesting additional information in order to
complete Form 5310; office conference with Alison Sulentic
REDACTED ; drafted Notice to
Interested Parties REDACTED .
212
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 146 of 377
Page 145
Hours Description
08/06/09 J R Raborn .50 Reviewed project list.
08/06/09 A M Sulentic 3.80 Office conference with Mark Bodron REDACTED
; review of plan documents REDACTED
; research regarding
Department of Labor safe harbor notice of plan termination;
drafting of notice of plan termination; revision of employee
benefits issues status chart REDACTED
.
08/07/09 M A Bodron 2.50 Reviewed REDACTED and Stanford
employee benefits chart; office conference with Alison Sulentic
concerning comments to same.
08/07/09 J R Raborn .60 Attention to email to Joe Cialone and reviewed issues
regarding tax refunds as possible source of recovery by
receiver.
08/07/09 A M Sulentic 6.00 Office conference with Mark Bodron REDACTED
; office conference with Mark
Bodron regarding status of employee benefits issues; review of
draft Form 5310; REDACTED
.
08/10/09 M A Bodron 3.00 Researched issues REDACTED ; telephone
conferences with Alison Sulentic, Jim Raborn and Char
McDougal concerning same.
08/10/09 J R Raborn .90 Attention to REDACTED and distributions of IRA
funds.
08/10/09 A M Sulentic 4.70 Attention to REDACTED ; office
conference with Mark Bodron regarding same; REDACTED
office conference with
Mark Bodron and Jim Raborn regarding same.
08/11/09 M A Bodron 2.40 Continued attention benefits issues; reviewed summary of
tasks; telephone conference with Char McDougal and Malcolm
Lovett.
08/11/09 A M Sulentic 2.70 Attention to REDACTED ; office
conference with Mark Bodron regarding same.
08/12/09 M A Bodron 5.90 Continued attention REDACTED and other
benefit issues.
08/12/09 J R Raborn .80 Followed up on IRA withholding and payroll matters.
08/12/09 A M Sulentic 1.50 Office conference with Jim Raborn and Mark Bodron
regarding status of various issues pertaining to Stanford
employee benefit plans; office conference with Mark Bodron
213
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 147 of 377
Page 146
Hours Description
REDACTED ; telephone
conference with Mark Bodron, Char McDougal and Carol Gore
REDACTED ; office
conference with Mark Bodron and Char McDougal regarding
various issues pertaining to Stanford employee benefit plans.
08/13/09 M A Bodron .60 Reviewed status of employee benefit outstanding issues.
08/14/09 M A Bodron 1.50 Telephone conference with Craig Adams concerning COBRA
notice issues and related claims; office conference with Alison
Sulentic concerning same; reviewed file materials concerning
same.
08/14/09 A M Sulentic 4.20 Attention to issues raised by terminated employee with respect
to COBRA benefits; office conference with Mark Bodron
regarding same; telephone conference with Char McDougal
regarding same.
08/16/09 A M Sulentic .20 E-mail correspondence with Carol Gore REDACTED
.
08/17/09 M A Bodron 2.20 Research Cobra claim issue; telephone conference with Craig
Adams concerning same; reviewed matter with Alison
Sulentic; REDACTED
08/17/09 A M Sulentic 5.50 Research regarding regulatory requirements pertaining to
REDACTED ;
research regarding COBRA notification obligations; office
conference with Mark Bodron and Tracee Lewis regarding
same.
08/18/09 J R Raborn .40 Attention to emails regarding plan COBRA notices and
terminations.
08/18/09 A M Sulentic 1.80 Attention to claim by former employee relating to COBRA
coverage; office conference with Mark Bodron regarding same;
attention to Section 401(k) nondiscrimination testing results for
2008.
08/19/09 M A Bodron .40 Office conference with Alison Sulentic concerning 401(k) Plan
testing results for 2008 plan year; reviewed same.
08/19/09 J G O'Quinn 2.50 Began preparing Forms 5330 for tax years 2006-2009
regarding excise taxes on late contributions to 401(k) Plan and
office conference with Alison Sulentic regarding same.
08/19/09 A M Sulentic 4.00 Analysis of and preparation of e-mail memorandum regarding
Section 401(k) nondiscrimination testing results for 2008;
office conference with Mark Bodron regarding same; office
conference with Jeannene O'Quinn regarding preparation of
214
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 148 of 377
Page 147
Hours Description
Form 5330.
08/20/09 M A Bodron 1.30 Reviewed REDACTED with Alison
Sulentic; researched issues related to same; office conference
with Jim Raborn concerning same.
08/20/09 J G O'Quinn 3.80 Continued preparing Forms 5330 and attachments and drafted
transmittal letter to IRS regarding same and office conference
with Mark Bodron regarding same.
08/20/09 J R Raborn .20 Attention to tax withholding issues.
08/20/09 A M Sulentic .20 Attention REDACTED
08/21/09 M A Bodron 3.00 Reviewed Form 5330 late contribution excise tax filing for
401(k) plan; office conference with Jeannene O'Quinn
concerning same; reviewed draft court filing regarding status of
employee benefit issues; forwarded comment to same to Craig
Adams.
08/21/09 J G O'Quinn 1.80 Revised Forms 5330 and office conference with Mark Bodron
regarding same.
08/21/09 J R Raborn .80 Attention to Form 5330 preparation and calculations.
08/21/09 J R Raborn .50 Attention to filing Forms 5330; attention to emails to Mark
Bodron.
08/21/09 A M Sulentic .70 Review of Form 5330 as prepared by Jeannene O'Quinn.
08/24/09 A M Sulentic 1.20 Office conference with Mark Bodron regarding Form 5330;
revision of same and transmission to Char McDougal.
08/25/09 J R Raborn .50 Reviewed labor and employment document.
08/26/09 M A Bodron .70 Office conference with Jim Raborn concerning same; office
conference with Alison Sulentic concerning Form 5330 filing
for the 401(k) plan; reviewed email from Char McDougal
concerning came.
08/26/09 A M Sulentic .90 Attention to Form 5330 filing regarding excise tax on late
contributions to plan.
08/27/09 J R Raborn .40 Responded to questions regarding loans.
08/27/09 A M Sulentic 2.50 Attention to various employee benefits issues, including filing
of Form 5330 and nondiscrimination testing for 2008 plan year;
office conference with Mark Bodron regarding
nondiscrimination testing; telephone conference with Carol
Gore of Newport regarding nondiscrimination testing.
08/28/09 M A Bodron .50 Reviewed 2008 testing materials for 401(k) and
correspondence to Char McDougal and authorization to
Newport regarding implementation of correction process.
215
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 149 of 377
Page 148
Matter Total 453.60
079716.0111 Latin American Matters
Hours Description
06/01/09 C N Adams .60 Telephone conference with working group regarding holdings
of Latin American investors.
06/02/09 W F Stutts, Jr. 1.30 Reviewed with R. Roper and V. Kurylak and M. Lovett the
proposal related to Peru and Panama and related points for fund
review and transfer either to receivership or to purchaser in
case of Panama; related status information on Mexico;
reviewed information and status on same with K.
Blumenschein.
06/03/09 W F Stutts, Jr. .40 Reviewed with Richard Roper points related to Panama sale
and changes in position taken by the Panamanian securities
commissioner.
06/04/09 W F Stutts, Jr. .90 Reviewed developing information regarding investment
banking consultants possibilities; communications with
Richard Roper regarding information needed for responses to
regulators; brief updates to Mr. Arevalo regarding same.
06/05/09 W F Stutts, Jr. .80 Reviewed with Richard Roper status in Peru and Colombia;
conference call with Mr. Roper and Mr. Sadler and Mr. Janvey
and Ms. Blumenschein.
06/10/09 W F Stutts, Jr. 1.10 Reviewed information from Mr. Hernandez REDACTED
;
reviewed and responded to status regarding CNBV request and
provided additional input to Mr. Roper on same.
06/11/09 W F Stutts, Jr. .60 Placed inquiry to Mr. Roper regarding Mexican client
information to ensure he has information necessary to respond
to questions pending from regulators.
06/12/09 J A Cialone, II .80 Calls regarding Roper's Latin American efforts.
06/12/09 W F Stutts, Jr. .40 Consulted with Mr. Roper on Panama bank sale including
questions of mechanic and scope of approvals necessary.
06/25/09 W F Stutts, Jr. .60 Reviewed information and status with Richard Roper regarding
Panama.
06/30/09 W F Stutts, Jr. 1.30 Communications with Mr. Myers regarding Panamanian
brokerage clients and related communications with Mr.
Hernandez and several communications with David Arlington
regarding status of motion; additional inquiries to Mr. Lovett
regarding information on the motions.
07/01/09 W F Stutts, Jr. .30 Inquired of J. Ecklund (TK) regarding documents on possible
216
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 150 of 377
Page 149
Hours Description
Panama sale and reviewed same from her.
07/06/09 W F Stutts, Jr. 1.10 PANAMA and proposal regarding sale of bank and examined
issues on process with Mr. Roper.
07/08/09 W F Stutts, Jr. 1.10 PANAMA and i bankers rio: Communications with prospective
advisor and several communications with Mr. Janvey and Mr.
Roper.
07/09/09 W F Stutts, Jr. .90 Panama: Reviewed information from Mr. Roper on Panama.
07/10/09 W F Stutts, Jr. 1.20 Panama valuation; telephone conferences with Richard Roper;
valuations reviews.
07/11/09 W F Stutts, Jr. 1.10 PANAMA and i bankers: Reviewed options and communicated
same with Mr. Roper.
07/12/09 W F Stutts, Jr. .60 PANAMA Maldonado agreement: Reviewed comments.
07/13/09 W F Stutts, Jr. 1.40 Prepared for and participated in call with Mr. Janvey, Mr.
Roper, Mr, Hernandez, Ms. Blumenschein regarding Panama
sale; related telephone conferences with Mr. Reece and Mr.
Arevalo; examined valuations of the bank and brokerage firm;
related review of information and documentation related to the
proposed purchaser.
07/13/09 W F Stutts, Jr. 1.10 PANAMA: Matters related to competing bids for bank and
account transfer timing.
07/14/09 W F Stutts, Jr. 1.30 Reviewed with Richard Roper REDACTED
07/15/09 J C Huddleston 2.00 Attention to location of documentation requested by Vincent
Hernandez of Stanford in connection with proposed sale of
Stanford International Bank Panama; met with Roman Beccera
regarding same.
07/16/09 W F Stutts, Jr. 1.30 Panama: Reviewed valuation questions and proposals; several
communications with Victor Hernandez and Richard Roper.
07/16/09 W F Stutts, Jr. .80 Reviewed and analyzed Maldonado agreement and terms
provided commentary in particular areas; several
communications with MR. Roper and Mr. Hernandez.
07/17/09 W F Stutts, Jr. 1.10 Documentation and comments--Maldonado; Roper and
Hernandez.
07/20/09 W F Stutts, Jr. .90 Reviewed status of Panama accounts and details with Richard
Roper and information to him regarding scope; additional
information on status; communications with Swiss counsel.
07/29/09 W F Stutts, Jr. .90 Panama and new outline for Transactions (Sale).
217
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 151 of 377
Page 150
Hours Description
08/03/09 W F Stutts, Jr. .80 PANAMA: Reviewed and coordinated with Mr. Hernandez
and Mr. Roper for information appropriate for release of
brokerage accounts and related additional work in connection
with proposed sale of SBP.
08/05/09 W F Stutts, Jr. .70 Reviewed heads of agreement (translated) and updated
information from Mr. Roper and responses to inquiries to
Switzerland.
08/06/09 W F Stutts, Jr. .90 Conference call related to release of brokerage accounts and
need to release additional accounts from other jurisdictions;
several communications with Mr. Roper regarding those topics
and timing requirements.
08/07/09 W F Stutts, Jr. .20 Report from Mr. Roper on Panamanian bank progress.
08/10/09 W F Stutts, Jr. 2.10 PANAMA: Reviewed with Mr. Roper the status of movement
of European funds and worked on methods to resolve
ambiguities caused by SEC freeze and DOJ MLAT.
08/11/09 W F Stutts, Jr. 2.40 PANAMA: Analyzed with Swiss and English counsel
possibilities regarding resolution of issues from SEC freezes.
08/12/09 D Krishan 4.10 Correspondence with barristers and internal team regarding
Stanford Bank Panama funds; organizing documents for
hearing.
08/12/09 W F Stutts, Jr. 1.30 PANAMA: Worked with Mr. Roper to identify scope of
needed relief.
08/13/09 D Krishan 4.30 Correspondence with Georgina Peters, Stuart Isaacs and Robin
Preston-Jones regarding hearing and Stanford Panama;
preparing documents for filing.
08/13/09 W F Stutts, Jr. 2.30 PANAMA: Additional coordination on English issues and
communications with English counsel.
08/14/09 D Krishan 10.90 Preparing REDACTED re
Stanford Bank Panama; liaising with Georgina Peters on the
hearing, documents and SBP application; correspondence with
Karen Denny regarding SEC's position on SBP funds;
conference with internal counsel regarding SBP funds.
08/14/09 W F Stutts, Jr. 3.20 PANAMA: Reviewed question regarding sale status and terms;
extended conversations with Mr. Roper, Mr. Arevalo, Mr.
Reece and English lawyers.
08/15/09 W F Stutts, Jr. 2.20 PANAMA: Worked on ways to accommodate newly described
position of SEC regarding notice and limits on scope; several
communications with Mr. Roper.
08/16/09 W F Stutts, Jr. 2.80 PANAMA: Telephone conference with Mr. Reece and with
218
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 152 of 377
Page 151
Hours Description
English counsel and Mr. Roper; worked on resolution of issues.
08/17/09 W F Stutts, Jr. .40 Worked with Richard Roper on request for release of funds
from London (CS/L).
08/18/09 D Krishan 5.30 Attendance at hearing; writing report on hearing; responding to
queries by Bob Howell and Bill Stutts; correspondence re SBP
witness statement.
08/19/09 W F Stutts, Jr. 1.40 Reviewed status of information regarding Panama;
communications with Mr. Isaacs and Ms. Peters regarding calls
for tomorrow regarding Panama; reviewed outstanding issues
and related communications with Mr. Roper.
08/20/09 W F Stutts, Jr. 1.40 Extended communications with Mr. Reece, Mr. Arevalo, Mr.
Roper, Mr. Isaacs, and Ms. Peters regarding Panamanian
deposits in Switzerland and England and other locations.
08/20/09 W F Stutts, Jr. 1.70 Extended communications with Mr. De Kluiver and Mr.
Arevalo and Mr. Roper on points related to Latin American and
other assets and upshot from discussion earlier.
08/25/09 W F Stutts, Jr. .30 Telephone conference with Mr. De Kluiver on points related to
interpretations from SFO; reviewed information from Mr.
Janvey on points related to Panama and examined pending
questions from Ms. Pastore on the points.
08/26/09 W F Stutts, Jr. .40 Reviewed information and questions related to Panama stock
holdings and also about requirements of Swiss FPO regarding
release of funds.
08/27/09 W F Stutts, Jr. .40 Reviewed information from Mr. Roper regarding progress on
sale related to SBP and information related to release of funds
in Switzerland and UK.
08/28/09 W F Stutts, Jr. .20 Reviewed Panama situation with Mr. Arevalo.
08/29/09 W F Stutts, Jr. .90 Consulted with Richard Roper and reviewed and analyzed
information related to UK release and Switzerland release.
08/30/09 J A Cialone, II 1.40 Several calls and emails concerning Bank of Panama issues
among Roper and other team members; reviewed related
relevant documents and correspondence and provided counsel.
08/30/09 W F Stutts, Jr. .80 Switzerland funds analysis and reviewed information related to
the request for same; reviewed questions related to possible
Swiss charges against funds in connection with repatriation.
08/31/09 W F Stutts, Jr. .30 Reviewed information from Mr. Arevalo and communications
with Mr. Roper on England funds.
Matter Total 79.00
219
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 153 of 377
Page 152
079716.0112 Private Equity Matters
Hours Description
06/01/09 C N Adams 1.00 Reviewing NDAs; preparing assessment of proposed sales;
telephone conference with Kristie Blumenschein regarding
same; reviewing open issues.
06/01/09 J M Greer 2.20 Phone calls with Chuck Weiser, Ozzie Pi and Craig Adams to
discuss outstanding private equity matters; phone call with
Brad Freels of Midway CC Hotel Partners to discuss an
upcoming capital call; phone call with Gary Stevenson of
Memphis Biomed Ventures II; correspondence with the
working group regarding SCM Alternative Income.
06/01/09 H C Tucker .70 Researched DGSE filings.
06/02/09 C N Adams 1.70 Telephone conference with Kristie Blumenschein and Malcolm
Lovett regarding private equity investments; reviewing letter to
eLandia; reviewing Midway capital call; reviewing issues
regarding advisor engagement.
06/02/09 S W Cooper .40 Telephone conference with Michael Ah Koy regarding E -
landia offer; emailed with John Greer and Craig Adams
regarding same.
06/02/09 J M Greer 1.20 Finalized and circulated a letter from Ralph S. Janvey to
Elandia clarifying Stanford's relationship with Elandia; phone
call with Chuck Weiser and Ozzie Pi with regard to
outstanding private equity matters; correspondence with the
general partner of Robro Royalty Partners.
06/03/09 C N Adams 2.10 Call with Coller Capital regarding possible acquisition of
private equity investments; telephone conference with Greg
Leekly regarding OFN and proposal to convert debt; telephone
conference with Park Hill regarding private equity investment
update.
06/03/09 J M Greer 5.60 Phone call with representatives of Coller Capital to discuss
possible interest in Stanford's private equity portfolio;
participated on a conference call with Keel Point to discuss the
status of the subordination agreement regarding Phoenix Bay;
prepared and drafted a summary of the Phoenix Bay conference
call; reviewed summary prepared by Chuck Weiser and Ozzie
Pi regarding Stanford's investment in Golden Financial
Mortgage.
06/04/09 C N Adams 1.70 Review of Coller Capital NDA; reviewing credentials for Latin
American advisor; attention to motion to approve advisor;
reviewing details of private equity investment; reviewing
private equity summaries.
220
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 154 of 377
Page 153
Hours Description
06/04/09 S W Cooper .20 Emailed with Michael Ah Koy on E-landia issues.
06/04/09 J M Greer 5.00 Participated on a conference call with representatives of the
Park Hill Group regarding Stanford's private equity portfolio;
reviewed and made comments to the form of non-disclosure
agreement circulated by Coller Capital; correspondence with
Chuck Weiser and Ozzie Pi regarding private equity matters.
06/05/09 C N Adams 1.30 Telephone conference with Greg Leekley regarding conversion
of Phoenix Bay notes; telephone conference with John Greer
regarding Israel Opportunity Fund issues; reviewing materials
regarding same.
06/05/09 J M Greer 3.70 Conversation with representatives of Phoenix Bay and its
senior note holders regarding a proposed option to convert debt
to preferred equity; conversation with Park Hill regarding
Stanford's investment in the Israel Opportunity Fund;
correspondence with Martin Mann of Foley Lardner regarding
Stanford's investment in the Israel Opportunity Fund.
06/08/09 C N Adams 2.80 Telephone conference with Tal Kimmel and Park Hill
regarding Israel Opportunity Fund; telephone conference with
Ritt Webb regarding advisory role; telephone conference with
Bob Morris regarding private equity portfolio; telephone
conference with Chuck Wesier regarding proposals; reviewing
updated proposals; telephone conference with Park Hill
regarding engagement.
06/08/09 J M Greer 1.50 Conference call with representatives of the Park Hill Group and
the Israel Opportunity Fund; correspondence with Chuck
Weiser and Ozzie Pi regarding private equity matters;
correspondence with Stefan Peller regarding Stanford's
investment in Mountain Partners AG; conference call with
representatives of the Park Hill Group to discuss Stanford's
private equity portfolio.
06/09/09 C N Adams .70 Reviewing offers to purchase private equity investments.
06/09/09 J M Greer 4.20 Conference call with John Ryder REDACTED
; phone call with Sandy Climan to
discuss available marketing efforts for Stanford's investment
position in four movies; correspondence with Chuck Weiser
and Ozzie Pi with regard to the private equity portfolio;
conversation and correspondence with Adrian Millan to discuss
certain investments in Stanford's private equity portfolio.
06/10/09 C N Adams 1.60 Telephone conference with Park Hill regarding private equity
issues; reviewing OFN subordination issues; reviewing Oasis
offer.
221
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 155 of 377
Page 154
Hours Description
06/10/09 J M Greer 2.40 Participated on a call with Midway CC Hotel Partners, LP and
Park Hill to discuss a capital call issued by Midway; phone call
with Martin Mann to discuss Stanford's investment in the Israel
Opportunity Fund; phone call with Adrian Millan to discuss
matters related to the private equity portfolio; correspondence
with Chuck Weiser and Ozzie Pi concerning private equity
matters.
06/11/09 C N Adams .70 Telephone conference with Park Hill regarding outstanding
private equity investments; telephone conference with Kristie
Blumenschein regarding same.
06/11/09 J M Greer 2.10 Prepared and drafted acceptance letters to Israel Opportunity
Fund and Midway CC Hotel Partners, LP; reviewed
correspondence to prepare for the meeting with representatives
of the Park Hill Group; phone call with Keel Point to discuss
the proposed subordination agreement related to Stanford's
investment in Phoenix Bay.
06/12/09 C N Adams 1.30 Telephone conference with Park Hill regarding offers for
investments; reviewing offers; telephone conference with
Ralph Janvey and Kristie Blumenschein regarding same.
06/12/09 S W Cooper .50 Worked on issues regarding approval motions.
06/12/09 J M Greer 6.70 Met with representatives of the Park Hill Group to review
transaction documents related to Stanford's private equity
portfolio; correspondence with Craig Adams and Kristie
Blumenschein related to Stanford's investment in the Israel
Opportunity Fund and Midway CC Hotel Partners, LP; revised
correspondence to Israel Opportunity Fund and Midway CC
Hotel Partners, LP; phone call with Clark Thompson, Midway
CC Hotel Partners, LP's outside counsel; phone call with
Chuck Weiser regarding Stanford's investment in Oasis Bank.
06/12/09 J C Huddleston 7.80 Compiled and transmitted private equity binders and related
corporate and financial information to Park Hill Group.
06/12/09 N M Starbuck 3.40 Compiled private equity information for Park Hill Group.
06/14/09 C N Adams .90 Telephone conference with Doug Cardoni regarding private
equity issues.
06/15/09 S W Cooper 3.30 Telephone conference with counsel for Israel Opportunity
Fund; telephone conference with counsel for Midway
Investors; telephone conference with John Greer; reviewed
relevant documentation regarding same; worked on motion for
approval of Park Hill Group.
06/15/09 J M Greer 4.30 Drafted a summary of a proposed transaction for Phoenix Bay,
Inc.; phone calls with Martin Mann regarding Stanford's
222
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 156 of 377
Page 155
Hours Description
investment in the Israel Opportunity Fund; circulated
correspondence to representatives of Israel Opportunity Fund
and Midway CC Hotel Partners, L.P. tentatively accepting
offers to purchase Stanford's respective limited partner
interests; correspondence with working group members related
to private equity matters; phone call with Chuck Weiser
regarding Oasis Bank.
06/16/09 C N Adams 1.20 Telephone conference with Park Hill regarding private equity
matters; reviewing IOF correspondence; telephone conference
with John Greer regarding open issues.
06/16/09 J M Greer 6.90 Update call with representatives of Park Hill Group; prepared
and drafted a letter regarding Park Hill Group's authority to act
as a representative of the Receiver; reviewed and made
comments to a draft Motion to Appoint Private Equity Advisor;
responded to correspondence related to the private equity
portfolio.
06/17/09 C N Adams .40 Telephone conference with Kristie Blumenschein regarding
Phoenix Bay subordination agreement.
06/17/09 S W Cooper 1.10 Worked on private equity motion; telephone conference with
Russell Lewis regarding same; telephone conference with
counsel for Israel Opportunity Fund; reviewed correspondence
and documents regarding same.
06/17/09 J M Greer 5.10 Reviewed and made comments to a draft Purchase and Sale
Agreement regarding Stanford's investment position in the
Israel Opportunity Fund; reviewed and made comments to a
draft Motion to Appoint Private Equity Advisor; prepared
exhibits to the Motion to Appoint Private Equity Advisor;
phone calls with representatives of Park Hill Group;
correspondence with Keel Point regarding Phoenix Bay.
06/18/09 C N Adams .30 Telephone conference with John Greer regarding outstanding
private equity investments.
06/18/09 S W Cooper .80 Worked on issues regarding private equity motions.
06/18/09 J M Greer 3.20 Phone calls with Adrian Millan of Park Hill Group regarding
certain investments in the private equity portfolio;
correspondence with FTI regarding certain assets in the private
equity portfolio; prepared and drafted a timeline of negotiations
with Oasis Bank; phone call with Martin Mann regarding the
draft Israel Opportunity Fund Purchase Agreement;
correspondence with Kim Schlanger regarding Golden
Financial and Spring Creek.
06/18/09 J C Huddleston .70 Reviewed Puerto Rican property descriptions and located local
title company to perform title searches on same; corresponded
223
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 157 of 377
Page 156
Hours Description
with company to obtain estimate for services.
06/19/09 C N Adams .50 Reviewing Memphis Bio-Med offer.
06/19/09 S W Cooper .80 Worked on issues regarding Park Hill and deal approvals;
telephone conference with Russell Lewis regarding same.
06/19/09 J M Greer 2.60 Prepared and drafted a letter to the Shelby County Retirement
Board; phone call with Adrian Millan regarding Stanford's
investment in Memphis Biomed Ventures II, L.P.;
correspondence with Midway CC Hotel Partners, L.P.'s outside
counsel regarding the status of transaction documents;
correspondence with Park Hill regarding the proposed Motion
to Appoint Private Equity Advisor.
06/19/09 J C Huddleston .90 Corresponded with Iliana Rivera of the Title and Security
Group in San Juan in conjunction with coordinating title search
of properties on behalf of Park Hill Group; prepared Spring
Creek Partners materials for transmittal to Park Hill Group.
06/19/09 N M Starbuck 2.10 Prepared transaction binders and financial information for
Spring Creek/Trail Partners entities for transmittal to Larry
Thuet of Park Hill Group.
06/20/09 C N Adams .40 Reviewing draft letter to Park Hill.
06/21/09 C N Adams .70 Reviewing draft letter regarding Park Hill engagement;
reviewing draft purchase agreement for Israel Opportunity
Fund.
06/22/09 J M Greer 2.10 Correspondence and phone calls with Israel Opportunity Fund's
counsel regarding draft Purchase Agreement and related
Motion; correspondence with Shelby County Retirement
Board's counsel regarding Memphis Biomed Ventures II, L.P.
06/23/09 C N Adams 1.60 Telephone conference with John Greer regarding private equity
issues; reviewing Park Hill letter; telephone conference with
Bob Howell regarding sale of SIBL interests; telephone
conference with Joe Cialone regarding same.
06/23/09 S W Cooper .80 Worked with Russell Lewis and John Greer on approval
motions and issues regarding same.
06/23/09 J M Greer 7.00 Reviewed and made comments to the Park Hill Engagement
Letter; phone calls with Craig Adams to discuss the sale of
Stanford's interest in the Israel Opportunity Fund; reviewed and
made comments to draft Purchase and Sale Agreement related
to Stanford's limited partner interest in Midway CC Hotel
Partners, L.P.; phone call with Russell Lewis regarding various
motions to be filed with the Court; phone calls with Martin
Mann regarding the Israel Opportunity Fund.
224
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 158 of 377
Page 157
Hours Description
06/23/09 J C Huddleston .70 Corresponded with Iliana Rivera of the Title and Security
Group in San Juan and Jeannette Day of FTI Consulting in
conjunction with coordinating title search of Maricao
properties on behalf of Park Hill Group.
06/24/09 C N Adams 1.60 Telephone conference with John Greer and Bob Howell
regarding private equity investment in Israel Opportunity
Funds; telephone conference with Martin Mann and John Greer
regarding same; reviewing IOF offer; telephone conference
with John Greer regarding same.
06/24/09 S W Cooper 1.60 Worked on Park Hill and private equity approval motions;
telephone conference with John Greer and Russell Lewis
regarding same; telephone conference with John Greer on
Swiss asset sale.
06/24/09 J M Greer 4.80 Correspondence with Park Hill Group and Jaime Huddleston
related to Golden Financial Services; phone calls with Park Hill
Group related to certain items in the private equity portfolio;
reviewed and made comments to the Midway CC Hotel
Partners, L.P. purchase agreement; reviewed correspondence
related to The Ultimate Gift.
06/24/09 J C Huddleston 1.10 Corresponded with Iliana Rivera of the Title and Security
Group in San Juan and Jeannette Day of FTI Consulting in
conjunction with coordinating title search of Fajardo property
on behalf of Park Hill Group; reviewed file for requested stock
certificate information to be reviewed by attorney.
06/24/09 N M Starbuck .80 Searched Receivership file for stock certificates.
06/25/09 C N Adams 2.10 Telephone conference with Park Hill regarding portfolio
investments; reviewing engagement letter; reviewing IOF
purchase agreement; telephone conference with Marty Mann
and John Greer regarding Israel Opportunity Fund sale.
06/25/09 S W Cooper 1.60 Worked on private equity motions; telephone conferences with
John Greer and Russell Lewis; emailed with Kevin Sadler on
expedited consideration issues.
06/25/09 J M Greer 6.40 Conference call with Park Hill Group to discuss the status of
the private equity portfolio; phone call with Marty Mann to
discuss the Israel Opportunity Fund Purchase Agreement;
phone call with representatives of The Ultimate Gift to discuss
certain matters related to the management of the asset; phone
call with Craig Adams to discuss the Israel Opportunity Fund
and the related Purchase Agreement; internal correspondence
with the litigation team related to the proposed motion for
Stanford's sale of its interest in the Israel Opportunity Fund.
225
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 159 of 377
Page 158
Hours Description
06/25/09 J C Huddleston 4.00 Maintained and updated account holder Stipulated Partial
Release Summary information for attorney review; prepared
ARS reports and account holder confirmations for attorney
review; reviewed and compiled list of outstanding accounts.
06/25/09 N M Starbuck .80 Searched file for Trustmark Corporation stock certificate.
06/26/09 C N Adams 1.10 Telephone conference regarding bankruptcy issues with respect
to Israel Opportunity Fund sale; telephone conference with
Park Hill regarding issues relating to same; reviewing revisions
to purchase agreement.
06/26/09 S W Cooper 2.30 Telephone conferences with counsel for IOF; worked on issues
regarding transaction approvals; telephone conference with
Russell Lewis and John Greer regarding same; reviewed
reasonably equivalent value material.
06/26/09 J M Greer 1.70 Correspondence related to Stanford's proposed sale of its
interests in Israel Opportunity Fund I and II; phone calls with
Park Hill Group regarding the private equity portfolio.
06/26/09 Z T Pullin 5.00 Reviewed Stanford files for Notes and related materials.
06/26/09 E A Soderlund 1.80 Discussion with J. Ross followed by call with S. Cooper and R.
Lewis regarding "reasonably equivalent value" term in
contract, research and follow up email summarizing the law
regarding same.
06/28/09 C N Adams .40 Reviewing draft purchase agreement for Midway investment.
06/29/09 J A Cialone, II .50 Reviewed various private equity emails and materials; related
calls.
06/29/09 S W Cooper 1.30 Telephone conference with counsel for IOF; worked on
Midway motion; reviewed default notice.
06/29/09 J M Greer 1.10 Correspondence related to Stanford's investment in the Israel
Opportunity Fund; correspondence with Park Hill Group
regarding Stanford's investments in ACON-related funds.
06/29/09 J C Huddleston 1.30 Attention to Puerto Rican property searches in connection with
private equity investments.
06/30/09 C N Adams .90 Telephone conference with Park Hill regarding Israel
Opportunity Fund; telephone conference with counsel
regarding Forefront issues.
06/30/09 S W Cooper 1.80 Telephone conference with Park Hill regarding REV issue;
worked on Midway motion; drafted response letter to IOF
default notice; telephone conferences with John Greer.
06/30/09 J M Greer 3.30 Conference call with representatives of Baker Botts and Park
Hill Group regarding Israel Opportunity Fund; conference call
226
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 160 of 377
Page 159
Hours Description
and correspondence with Senesco's management regarding a
proposed equity raise and Stanford's right of first refusal;
reviewed correspondence related to Stanford's investment in
Golden Financial Services; reviewed and made comments to
draft Midway CC Hotel Partners, L.P. motion.
07/01/09 C N Adams .60 Reviewing response regarding IOF default notice; reviewing
Park Hill engagement letter.
07/01/09 S W Austin 1.90 Reviewed Motion regarding Israel Opportunity Fund; drafted
letter to Wes Loegering; circulated to Bill Stutts; sent e-mail
message to John Greer with questions.
07/01/09 S W Cooper 1.40 Worked on issues regarding approach to Jones Day on private
equity deals; finalized letter to IOF; emailed with IOF counsel
regarding default issue; revised Midway approval motion.
07/01/09 J M Greer 2.70 Phone call with Craig Adams to discuss private equity matters;
phone calls and correspondence with Park Hill Group
regarding Senesco, Israel Opportunity Fund and other matters
related to Stanford's private equity portfolio; correspondence
with Ernst & Young related to REDACTED
.
07/01/09 W F Stutts, Jr. .80 Reviewed question with Craig Adams regarding transfer of SIB
private equity interest and examined some underlying facts and
questions.
07/02/09 C N Adams .30 Telephone conference with John Greer regarding engagement
letter terms.
07/02/09 J M Greer 1.30 Phone calls with Park Hill Group to discuss its proposed
engagement letter and Stanford's investment in Israel
Opportunity Funds; reviewed and made comments to Park Hill
Group's proposed engagement letter.
07/03/09 C N Adams .50 Reviewing Midway purchase agreement.
07/03/09 S W Austin .30 Replied to successive questions from Bill Stutts regarding sale
of IOF I and IOF II securities.
07/03/09 J M Greer 1.80 Reviewed and made comments to the draft Midway CC Hotel
Partners, L.P. Sale and Purchase Agreement and form of
Assignment; correspondence with Bracewell & Giuliani
regarding the proposed Midway transaction.
07/05/09 C N Adams .40 Reviewing draft motion regarding sale of Midway interest.
07/06/09 J M Greer 1.70 Correspondence with ForeFront Holdings regarding its
document retention policy; correspondence with counsel for
Israel Opportunity Fund regarding draft Purchase Agreements;
phone calls and correspondence with Park Hill Group
227
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 161 of 377
Page 160
Hours Description
regarding its engagements letter and motion.
07/07/09 C N Adams 1.20 Conference with Larry Thuet regarding open private equity
matters; telephone conference with John Greer regarding same;
reviewing draft Midway purchase agreement.
07/07/09 J M Greer 2.60 Reviewed and made comments to a draft Purchase Agreement
regarding Stanford's investment in Memphis Biomed Ventures
II, L.P.; conference calls with Park Hill Group regarding
private equity matters; correspondence regarding
REDACTED ; correspondence
regarding Spring Creek with Ernst & Young.
07/08/09 C N Adams .60 Telephone conference with John Greer regarding comments to
Midway and IOF purchase agreements; reviewing comments to
Park Hill motion.
07/08/09 S W Austin 2.40 Revised letter to Jones Day regarding Israel Opportunity Fund;
circulated to John Greer, Craig Adams and Bill Stutts;
reviewed John Greer's comments and incorporated; further
changes to letter.
07/08/09 S W Cooper .30 Telephone conference with John Greer regarding private equity
issues; attended to Park Hill and IOF matters.
07/08/09 J M Greer 7.40 Correspondence with Senesco's management; reviewed and
made comments to a proposed letter to Jones Day regarding
Stanford's sale of its interest in Israel Opportunity Fund I, L.P.;
correspondence with counsel to Israel Opportunity Fund; phone
call and correspondence with Park Hill Group regarding the
private equity portfolio.
07/09/09 C N Adams 1.20 Telephone conference with Adrian Millan and John Greer
regarding Park Hill engagement letter; reviewing issues
regarding The Ultimate Gift; reviewing revised IOF purchase
agreement.
07/09/09 S W Austin .90 Revised letter further; briefly reviewed organizational
agreement for IOF I and sent e-mail message to John Greer
regarding more thorough review.
07/09/09 S W Cooper .30 Telephone conference with Michael Ah Koy; office conference
with John Greer on deal issues.
07/09/09 J M Greer 6.70 Reviewed correspondence related to the private equity
portfolio; participated on a conference call with Park Hill
Group regarding its engagement letter; reviewed and made
comments to proposed correspondence to Jones Day regarding
the proposed sale of Stanford's interest in Israel Opportunity
Fund I, L.P.; reviewed and made comments to the draft
Purchase Agreement for Memphis Biomed Ventures II, L.P.;
228
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 162 of 377
Page 161
Hours Description
conference call with Hugh Howser of ForeFront Holdings, Inc.
regarding the status of its wind-down.
07/09/09 W F Stutts, Jr. .40 Respond to inquiries from Ms. Austin regarding scope of
offered actions.
07/10/09 C N Adams 1.10 Telephone conference with Patria regarding investment
banking operations in Latin America to assist in bank sale;
reviewing revised IOF purchase agreement; reviewing Park
Hill motion and engagement letter.
07/10/09 S W Austin 1.20 E-mail message exchanges with John Greer regarding results of
his review of Purchase Agreement; revised letter further;
attention to issue of IOF I manager unable to send Purchase
Agreement; reviewed e-mail messages between Kristie
Blumenschein and Craig Adams regarding letter; sent e-mail
message to Craig Adams and Bill Stutts regarding alternatives.
07/10/09 S W Cooper .50 Revised IOF motion; office conference with Russell Lewis.
07/10/09 J M Greer .80 Conference call related to the Park Hill engagement letter;
finalized the Israel Opportunity Fund Purchase Agreements.
07/13/09 C N Adams .90 Telephone conference with Larry Thuet regarding private
equity issues; reviewing changes to IOF motion.
07/13/09 S W Cooper .40 Attended to IOF and Park Hill motions; office conference with
John Greer.
07/13/09 J M Greer 1.70 Phone calls and correspondence with Park Hill Group
regarding private equity matters; correspondence with Marty
Mann regarding Israel Opportunity Fund, LLC; correspondence
and phone calls with representatives of Midway CC Hotel
Partners, L.P.
07/14/09 C N Adams 1.50 Telephone conference with working group regarding proposed
sales; telephone conference with Kristie Blumenschein
regarding Park Hill engagement; telephone conference with
Park Hill regarding motion to approve advisor and approve
Israel Opportunity Fund; reviewing revised motion.
07/14/09 S W Austin 2.00 Reviewed materials in preparation for call regarding Israel
Opportunity Fund; participated in call with Ralph Janvey, Joe
Cialone, Kristie Blumenschein, Craig Adams, Bill Stutts and
others regarding two proposed Israel Opportunity Fund equity
sales.
07/14/09 J A Cialone, II .80 Attention to private equity emails and materials.
07/14/09 S W Cooper 4.10 Worked on revisions to Park Hill motion; worked on IOF
motion; telephone conferences with John Greer regarding
potential changes to motion; worked on consultation issues.
229
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 163 of 377
Page 162
Hours Description
07/14/09 J M Greer 4.20 Conference call with members of the working group to discuss
the proposed disposition of Stanford's interest in Israel
Opportunity Fund I, L.P.; conference call with Park Hill Group
to discuss matters related to the private equity portfolio;
correspondence with ForeFront Holdings and its counsel
concerning its efforts to wind down operations.
07/15/09 C N Adams 2.60 Telephone conference with Park Hill regarding
REDACTED ; telephone conference
with John Greer regarding related issues; reviewing revised
Midway purchase agreement; telephone conference with Hugh
Howser regarding Forefront issues.
07/15/09 S W Cooper 1.50 Responded to requests for further detail on motions; attended to
issues regarding Midway transaction.
07/15/09 J M Greer 4.50 Participated on a conference call with Park Hill Group to
discuss its recommendations with regard to several companies
in the private equity portfolio; correspondence with
representatives of The Ultimate Gift with regard to outstanding
invoices; correspondence with regard to filing the Motion to
Appoint Private Equity Advisor.
07/16/09 C N Adams .90 Telephone conference with Park Hill and Ralph Janvey
regarding recommended sales.
07/16/09 S W Cooper .40 Attended to issues regarding IOF and Midway filings.
07/16/09 J M Greer 1.10 Participated on a conference call with Park Hill Group, Ralph
Janvey, Kristie Blumenschein and others with regard to the
proposed disposition of several investments in the private
equity portfolio.
07/17/09 C N Adams 2.70 Reviewing Midway purchase agreement changes; reviewing
media reports regarding private equity portfolio valuation;
revising IOF motion to address; telephone conference with
John Greer regarding IOF; reviewing Midway motion.
07/17/09 J A Cialone, II .70 Attention to private equity issues.
07/17/09 S W Cooper 2.40 Finalized Midway motion; attended to issues regarding IOF
filing; emailed with Kevin Sadler regarding private equity
issues; telephone conference with David Reece at SEC.
07/17/09 J M Greer 3.20 Participated on phone calls with regard to the Park Hill Group
motion; reviewed correspondence and participated on phone
calls with regard to the proposed Israel Opportunity Fund and
Midway CC Hotel Partners motions; finalized the Purchase and
Sale Agreement with Midway T&C Land Investors, LLC.
07/20/09 C N Adams .70 Reviewing comments to Park Hill motion; telephone
230
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 164 of 377
Page 163
Hours Description
conference with Sam Cooper regarding same.
07/20/09 S W Cooper .70 Worked on IOF motion issues; office conference with John
Greer regarding same.
07/20/09 J M Greer 4.60 Finalized the Purchase and Sale Agreement with Midway CC
Hotel Partners, L.P.; revised motion regarding the Receiver's
proposed sale of the Receivership Estate's interest in Israel
Opportunity Fund I, L.P. and Israel Opportunity Fund II, L.P.;
participated on conference calls with regard to the Israel
Opportunity Funds; phone call with Park Hill Group regarding
Senesco and several other portfolio companies.
07/21/09 C N Adams 1.20 Reviewing revised IOF and Midway motions; telephone
conference with John Greer regarding same.
07/21/09 S W Cooper 1.70 Attended to further revisions to IOF and Midway motions;
attended to responses from other counsel regarding same;
communicated with SEC regarding same; office conference
with Russell Lewis regarding next steps.
07/21/09 J M Greer 4.10 Finalized motion regarding the Estate's proposed sale of its
interest in Midway CC Hotel Partners, L.P.; reviewed and
made comments to a proposed Letter of Intent submitted by
interested parties in Senesco Technologies, Inc.; phone calls
and correspondence with Park Hill Group related to the private
equity portfolio; reviewed correspondence related to the Israel
Opportunity Fund motion.
07/21/09 J T Leslie .20 Telephone conference with John Greer regarding Dallas Gold
and Silver Exchange.
07/22/09 C N Adams .40 Reviewing REDACTED purchase agreement.
07/22/09 S W Cooper .50 Attended to consultation issues on Midway motion; emailed
with David Reece (SEC) regarding same.
07/22/09 J M Greer 2.00 Phone calls with Park Hill Group regarding certain portfolio
companies; prepared and drafted acceptance letters
REDACTED ; reviewed
correspondence and participated on phone calls regarding the
proposed motion to sell the Estate's interest in Midway CC
Hotel Partners, L.P.
07/22/09 J T Leslie .70 Review of DGSE materials.
07/23/09 C N Adams .70 Reviewing Senesco LOI; telephone conference with John Greer
regarding same; reviewing acceptance letter.
REDACTED
07/23/09 J M Greer 3.50 Prepared and drafted a Purchase and Sale Agreement
REDACTED
; correspondence with Health Systems
231
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 165 of 377
Page 164
Hours Description
Solutions; phone calls and correspondence with Park Hill
Group regarding portfolio companies; correspondence related
to Senesco Technologies, Inc.
07/23/09 J T Leslie 1.30 Telephone conference with Paul Montgomery regarding
DGSE; office conferences with Adora Asoyne regarding
REDACTED .
07/24/09 C N Adams .40 Reviewing comments to REDACTED purchase agreement.
07/24/09 S W Cooper .80 Reviewed oppositions to private equity motions; reviewed
examiner's comments; emailed regarding same.
07/24/09 J M Greer 3.80 Revised a Letter of Intent REDACTED
to reflect internal comments; reviewed correspondence and
motions opposing the proposed sale of the Estate's interest in
the Israel Opportunity Funds; prepared and drafted acceptance
letters related to the Estate's investments in Insound Medical
and REDACTED ; phone calls and
correspondence with Park Hill Group regarding private equity
matters.
07/24/09 J T Leslie .40 Telephone conference and office conference with Adora
Asoyne regarding REDACTED .
07/24/09 C W Rancher 1.20 Drafted purchase and sale agreement for sale REDACTED
by Stanford International Bank, Ltd.
07/26/09 J M Greer 1.00 Prepared and drafted a Purchase and Sale Agreement
REDACTED .
07/27/09 S W Cooper 1.10 Attended to issues regarding comments from John Little;
attended to request for expedited relief; reviewed opposition
filings on PHG and IOF motions.
07/27/09 J M Greer 1.90 Prepared and drafted acceptance letters for Insound Medical,
Inc. REDACTED ; participated on phone
calls with Park Hill Group regarding the private equity
portfolio; phone call with Bruce Galton of Senesco
Technologies, Inc.; reviewed the Antiguan receiver's
opposition to the Receiver's motion to appoint Park Hill Group
as private equity advisor.
07/27/09 J T Leslie .10 Office conference with John Greer regarding DGSE.
07/28/09 C N Adams .40 Reviewing Senesco documents.
07/28/09 S W Cooper 2.10 Telephone conference with John Little; office conference with
John Greer on response to requests; reviewed additional
information from PHG on IOF transaction; attended to issues
raised by next set of potential sales.
232
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 166 of 377
Page 165
Hours Description
07/28/09 J M Greer 2.10 Circulated draft Purchase and Sale Agreements to the Shelby
Country Retirement Board and Senesco Technologies, Inc;
phone calls with Park Hill Group with regard to private equity
matters; phone call with John Little to discuss the Israel
Opportunity Fund and Midway CC Hotel Partners motions.
07/28/09 C W Rancher 1.90 Drafted purchase and sale agreement for preferred shares of
Insound Medical, Inc.
07/29/09 S W Cooper 2.00 Telephone conference with PHG; worked on issues arising out
of impact of clawback motion on IOF transaction; office
conference with Kevin Sadler regarding same.
07/29/09 J M Greer 3.70 Phone call with Park Hill Group regarding private equity
matters; reviewed correspondence regarding the Israel
Opportunity Fund; reviewed REDACTED analysis regarding the
Estate's investment in Health Systems Solutions; prepared and
drafted a Purchase and Sale Agreement for Insound Medical,
Inc.
07/29/09 J T Leslie 1.40 Reviewed corporate documents of DGSE for change of control
and transfer restriction provisions.
07/30/09 C N Adams .70 Reviewing draft REDACTED Insound purchase agreements.
07/30/09 S W Cooper .20 Telephone conference with Park Hill regarding IOF issues.
07/30/09 J M Greer 1.20 Conference call to discuss the status of the Israel Opportunity
Fund transaction and the effect of the clawback claim; phone
call with Clark Thompson regarding the status of the Receiver's
motion to sell the Estate's interest in Midway CC Hotel
Partners, L.P.; phone call with Park Hill Group to discuss
private equity matters; prepared and drafted Purchase and Sale
Agreements' for Insound Medical, Inc. REDACTED
.
07/30/09 J T Leslie 3.70 Reviewed DGSE corporate documents to find transfer
restrictions; compiled a summary of transfer restrictions and
submitted to John Greer.
07/31/09 S W Cooper .80 Worked on issues regarding upcoming transactions.
07/31/09 J M Greer .20 Phone call with representatives of Health Systems Solutions,
Inc. and Park Hill Group to discuss the draft Purchase and Sale
Agreement.
08/03/09 S W Cooper .70 Attended to issues regarding IOF and upcoming transactions.
08/03/09 J M Greer 1.10 Reviewed comments to the draft Purchase and Sale
Agreements REDACTED
; phone call with Park Hill Group regarding
the status of the portfolio companies; correspondence with
233
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 167 of 377
Page 166
Hours Description
representatives of Midway CC Hotel Partners regarding the
status of the court motion.
08/03/09 J T Leslie .10 Coordination with respect to DGSE document review.
08/04/09 C N Adams 1.20 Reviewing Senesco and HSS agreements; telephone conference
with Sam Cooper regarding Midway and IOF sales; telephone
conference with John Greer regarding private equity issues.
08/04/09 S W Cooper 1.00 Telephone conference with Craig Adams regarding IOF
transaction; telephone conference with Kevin Sadler regarding
same; telephone conference with John Greer; telephone
conference with Adrian Millan at Park Hill.
08/04/09 J M Greer 1.40 Conference call with Park Hill regarding private equity
matters; correspondence with management of several portfolio
companies; phone call with Sam Cooper to discuss Israel
Opportunity Fund.
08/05/09 C N Adams .40 Reviewing Memphis Bio-Med agreement; reviewing TUG cash
flow; reviewing DGSE offer.
08/05/09 S W Cooper .70 Worked on upcoming transactions.
08/05/09 J M Greer 1.30 Reviewed correspondence regarding The Ultimate Gift LLC;
reviewed Park Hill Group's summary of Stanford's investment
in Dallas Gold & Silver Exchange; correspondence with John
Ryder regarding Stanford's interest in Memphis Biomed
Ventures II, L.P.; phone call with Park Hill Group to discuss
private equity matters.
08/06/09 C N Adams .90 Telephone conference with John Greer regarding Senesco
purchase agreement; reviewing same; Park Hill update call.
08/06/09 S W Cooper 1.60 Reviewed Park Hill data sheets on new deals; commented on
same; office conference with John Greer; telephone conference
with Park Hill regarding process matters.
08/06/09 J M Greer 2.10 Phone call with Senesco's counsel regarding the proposed
Purchase and Sale Agreement; reviewed a motion opposing the
appointment of Park Hill Group; phone call with Park Hill
Group to discuss support for upcoming motions;
correspondence with Health Systems Solutions regarding the
status of the Purchase and Sale Agreement; phone call with
Ralph Janvey and Park Hill Group to discuss
REDACTED ; attended to
miscellaneous projects.
08/06/09 R C Lewis 1.20 Reviewed information on additional equity divestments in
anticipation of drafting motion on same; conference with John
Greer regarding same.
234
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 168 of 377
Page 167
Hours Description
08/07/09 C N Adams .50 Reviewing draft SSM letter; telephone conference with John
Greer regarding same.
08/07/09 S W Cooper 2.20 Worked on issues regarding upcoming private equity deals;
office conference with Kevin Sadler regarding same; reviewed
oppositions on IOF and Park Hill motions.
08/07/09 J M Greer 2.40 Phone call with Park Hill Group to discuss back-up
information; phone call and correspondence with the litigation
group regarding a motion to sell certain assets in the private
equity portfolio; prepared and drafted an acceptance letter for
REDACTED .; prepared and drafted a
Purchase and Sale Agreement for REDACTED
; attended to miscellaneous projects.
08/07/09 R C Lewis 5.20 Reviewed additional information on pending financial
transactions; began drafting motion to approve Memphis
Biomed and InSound transactions.
08/09/09 S W Cooper .30 Attended to issues regarding Memphis Biomed and InSound
investments.
08/09/09 R C Lewis 2.30 Drafted motion to approve sale of InSound and Memphis
Biomed investments.
08/10/09 C N Adams .80 Reviewing SSM summary; telephone conference with Larry
Thuet regarding private equity issues.
08/10/09 S W Cooper 1.60 Telephone conference with Adrian Millan; worked on private
equity issues for potential upcoming sales; telephone
conference with Kevin Sadler.
08/10/09 J M Greer 2.40 Phone calls with Park Hill Group regarding back-up material
and the status of certain transactions; phone calls with Sam
Cooper and Russell Lewis to discuss draft motions for the
proposed sale of Stanford's interest in certain portfolio
companies; phone call with Craig Adams to discuss Insound
Medical, Inc.; reviewed comments from SightLine Partners
with regard to its proposed purchase of Stanford's interest in
Insound Medical, Inc.
08/10/09 R C Lewis 2.20 Drafted motion to approve InSound and Memphis Biomed
investments; conferences with Sam Cooper and John Greer
regarding same.
08/11/09 C N Adams .40 Reviewing HSS correspondence; telephone conference with
John Greer regarding same; reviewing lease information
regarding Forefront.
08/11/09 S W Cooper .60 Reviewed Memphis Biomed material; office conference with
John Greer and Russell Lewis regarding upcoming deals.
235
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 169 of 377
Page 168
Hours Description
08/11/09 J M Greer .40 Phone call with John Houston regarding Sightline Partners
proposed purchase of Stanford's interest in Insound Medical;
phone call with Park Hill Group regarding Memphis Biomed.
08/11/09 R C Lewis 2.30 Drafted Motion to Approve Sale; reviewed new information
received from Park Hill Group regarding potential investments;
conference with Sam Cooper regarding same; revised and
prepared Motion for Extension for filing.
08/12/09 C N Adams .50 Reviewing InSound and REDACTED purchase agreements.
08/12/09 S W Cooper .90 Telephone conference with Adrian Millan on material to
support private equity motions; office conference with John
Greer regarding same; telephone conference with Marty Mann
on IOF motion.
08/12/09 J M Greer 1.50 Reviewed Park Hill Group's Memphis Biomed write-up; phone
call with Sam Cooper regarding Park Hill Group;
correspondence with Craig Adams regarding private equity
matters; attended to miscellaneous projects.
08/12/09 R C Lewis 1.50 Drafted and revised Motion for Sale of InSound and Memphis
Biomed based on new Park Hill comments.
08/13/09 C N Adams .80 Reviewing private equity transactions with Ralph Janvey.
08/13/09 S W Cooper .20 Office conference with Russell Lewis on Memphis Biomed
issues.
08/13/09 J M Greer 1.10 Phone call with Craig Adams and Ralph Janvey regarding
private equity matters and draft Purchase and Sale Agreements;
phone call with Park Hill Group regarding private equity
matters; correspondence with the litigation team regarding
motions seeking the Court's approval for sale of certain private
equity interests.
08/13/09 R C Lewis 2.00 Reviewed additional information sent from Park Hill Group on
private equity interests; conference with John Greer regarding
same.
08/14/09 C N Adams .40 Teleconference with Stan Lipman regarding Reignmaker
investment; reviewing documents regarding same.
08/14/09 J M Greer .60 Phone call with Park Hill Group regarding private equity
matters; phone call with representatives of Health Systems
Solutions regarding the Purchase and Sale Agreement.
08/14/09 R C Lewis 5.60 Reviewed information from Park Hill; drafted Motion for Sale
of Memphis Biomed; began drafting reply to Stanford's
Opposition to Appointment of Park Hill; reviewed briefing in
anticipation of same.
236
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 170 of 377
Page 169
Hours Description
08/15/09 S W Cooper .50 Reviewed and revised response draft to opposition to Park Hill
motion; office conference with Russell Lewis regarding same.
08/16/09 C N Adams .30 Reviewing background of eLandia investment; reviewing
Panama loan issue.
08/17/09 C N Adams .50 Reviewing reply to Park Hill objection; telephone conference
with team regarding pending private equity motions.
08/17/09 J A Cialone, II 1.00 Calls and emails about Park Hill.
08/17/09 S W Cooper 1.20 Attended to issues regarding Park Hill filing; telephone
conference with Marty Mann regarding IOF filing; reviewed
material on Catalyst investment.
08/17/09 J M Greer 2.10 Discussions with Park Hill Group regarding status of motions
and purchase and sale agreements and Luminex; reviewed and
made comments to a draft Assignment Agreement regarding
REDACTED ; phone call with Brad
Freels of Midway CC Hotel Partners, L.P. regarding the status
of the motion filed with the Court and the outstanding capital
call; attended to miscellaneous projects.
08/18/09 C N Adams .50 Telephone conference with John Greer regarding private equity
issues; attention to Memphis Bio-Med offer; telephone
conference with Kristie Blumenschein regarding outstanding
offers.
08/18/09 S W Cooper .30 Telephone conference with Adrian Millan at Park Hill Group.
08/18/09 J M Greer 1.20 Prepared and drafted a table summarizing private equity offers
the Receivership Estate has received to date; phone calls with
Park Hill Group regarding the status of the
REDACTED InSound Medical's
respective Purchase and Sale Agreement.
08/18/09 R C Lewis 4.20 Reviewed new filings in SEC matter; drafted motions to sell
private equity interests; reviewed new information from Park
Hill Group regarding same.
08/19/09 C N Adams 1.10 Reviewing Senesco purchase agreement; reviewing status of
pending private equity deals; reviewing draft reply brief;
telephone conference with Sam Cooper regarding same.
08/19/09 S W Cooper 1.70 Worked on Park Hill response; emailed with Kristie
Blumenschein regarding same; worked on Memphis Biomed
and In Sound motions.
08/19/09 J M Greer 2.30 Phone calls and e-mail correspondence with Park Hill Group
regarding REDACTED and
InSound Medical; revised Purchase and Sale Agreements for
and InSound
237
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 171 of 377
Page 170
Hours Description
Medical to reflect comments from Kristie Blumenschein;
attended to miscellaneous projects.
08/20/09 C N Adams 2.60 Telephone conference with John Greer regarding comments to
purchase agreements; telephone conference with Kristie
Blumenschein regarding same; telephone conference with Park
Hill and Ralph Janvey regarding pending private equity deals;
reviewing terms for proposed sales.
08/20/09 S W Cooper 3.10 Worked on InSound and Memphis Biomed motions; telephone
conference with Adrian Millan regarding same; participated in
call with PHG on upcoming deals; reviewed REDACTED
agreement language.
08/20/09 J M Greer 7.80 Revised draft Purchase and Sale Agreements for
REDACTED and InSound Medical;
circulated draft Purchase and Sale Agreements to prospective
buyers; conference call with representatives of InSound
Medical to review the Purchase and Sale Agreement; phone
call with Michael Levine of Health Systems Solutions to
review the Purchase and Sale Agreement; phone call with Park
Hill Group to discuss private equity matters; attended to
miscellaneous projects.
08/20/09 R C Lewis 2.80 Phone conference with Park Hill group regarding status of
private equity investments; revised motions for sale of private
equity interests to include comments from same; prepared and
filed Reply to Opposition to Appoint Private Equity Advisor.
08/21/09 C N Adams .90 Telephone conference with John Greer regarding comments to
purchase agreements; telephone conference with Richard
Roper regarding eLandia investment.
08/21/09 S W Cooper .80 Attended to issues regarding Midway default issue.
08/21/09 J M Greer 1.10 Phone call with Charles Jewell to discuss the REDACTED
draft Purchase and Sale Agreement; reviewed
draft private equity schedule; reviewed and made comments to
draft Purchase and Sale Agreement for REDACTED ;
attended to miscellaneous projects.
08/21/09 C W Rancher 3.10 Drafted Purchase and Sale Agreements for REDACTED
.
08/22/09 C N Adams .70 Reviewing motion to approve InSound and Memphis Bio-Med
deals; reviewing private equity schedule for production to SEC.
08/22/09 S W Cooper .20 Emailed with Kevin Sadler on Midway issue.
08/23/09 S W Cooper .50 Drafted talking points on Midway issue.
238
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 172 of 377
Page 171
Hours Description
08/23/09 R C Lewis 4.50 Reviewed additional information from Park Hill Group
concerning private equity investments; began drafting motion
for sale of HSS investments.
08/24/09 C N Adams 3.20 Telephone conference with Ralph Janvey, Richard Roper and
Park Hill regarding eLandia issues; reviewing SEC filings
regarding same; telephone conference with Kristie
Blumenschein regarding same; telephone conference with Sam
Cooper regarding status of private equity motions; telephone
conference with Senesco counsel regarding changes to
purchase agreement; reviewing same; reviewing draft motion
for sale of private equity interests; telephone conference with
Kristie Blumenschein regarding schedule of private equity
interests.
08/24/09 S W Cooper .90 Office conferences with Kevin Sadler on Midway and IOF
issues; revised talking points; office conference with Craig
Adams regarding same.
08/24/09 J M Greer 1.30 Prepared and drafted a Purchase and Sale Agreement for
REDACTED .
08/24/09 R C Lewis .60 Revised motion for sale of InSound and MBV to include
additional comments.
08/25/09 C N Adams .60 Reviewing draft purchase agreement for REDACTED ;
reviewing New Dominion purchase agreement; reviewing
eLandia materials.
08/25/09 S W Cooper .70 Worked on HSS issues; telephone conference with Park Hill
regarding same; telephone conference with Kevin Sadler
regarding Midway and IOF.
08/25/09 J M Greer 2.60 Prepared and drafted Purchase and Sale Agreements for
REDACTED ; correspondence with
Memphis Biomed regarding the Purchase and Sale Agreement
with Shelby County.
08/26/09 C N Adams .80 Reviewing orders regarding Midway and IOF; preparing for
closing of Midway sale.
08/26/09 S W Cooper 1.00 Worked on Memphis Biomed and InSound issues.
08/27/09 C N Adams 1.50 Telephone conference with Larry Thuet and Adrian Millan
regarding eLandia investment; reviewing Midway closing
documents; telephone conference with counsel regarding same;
reviewing Spring Creek purchase agreement.
08/27/09 S W Cooper 1.60 Telephone conference with Park Hill; reviewed and
commented on material on HSS; telephone conference with
Craig Adams on IOF and Senesco; attended to revisions to
239
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 173 of 377
Page 172
Hours Description
Memphis Biomed and In Sound.
08/27/09 J M Greer 2.80 Prepared and drafted a Purchase and Sale Agreement for
REDACTED ; revised the REDACTED
Purchase and Sale Agreement to reflect the terms of the Letter
of Intent; correspondence with Park Hill Group regarding
private equity matters.
08/28/09 C N Adams .50 Attention to Midway closing; correspondence with Kristie
Blumenschein regarding InSound transaction.
08/28/09 S W Cooper .50 Attended to HSS issues.
08/29/09 C N Adams .80 Reviewing InSound and Memphis Bio-Med motion.
08/30/09 C N Adams .30 Reviewing Midway closing documents.
08/31/09 C N Adams .60 Attention to Midway closing and agreement; telephone
REDACTED
conference with John Greer regarding open issues.
08/31/09 S W Cooper 1.00 Reviewed and revised motions on InSound, , and MBV;
REDACTED
telephone conferences with Marty Mann regarding open IOF
issues.
08/31/09 J M Greer 3.90 Prepared and drafted a Purchase and Sale Agreement for
REDACTED ; phone call with Park Hill
Group regarding private equity matters; correspondence with
Memphis Biomed and its counsel regarding the draft Purchase
and Sale Agreement; reviewed and made comments to the
REDACTED draft motion; correspondence with
Craig Adams regarding private equity matters; attended to
miscellaneous projects.
Matter Total 411.10
079716.0113 Receivership Corporate Matters
Hours Description
06/01/09 C N Adams 1.30 Attention to office closure issues; coordinating transfer of legal
files and other materials to Houston; attention to claims issues;
telephone conference with Malcolm Lovett regarding same.
06/01/09 J T Leslie 1.40 Telephone conferences with Craig Adams regarding the St.
Croix shipment; coordination for the St. Croix shipment;
attended to project coordination and tasks.
06/01/09 N M Starbuck 3.50 Assisted in the preparation for shipment of St. Croix
documents.
06/01/09 W F Stutts, Jr. .30 Reviewed information on claims on web side and reviewed
information from J. Thomas regarding that status and the
240
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 174 of 377
Page 173
Hours Description
information provided and received.
06/02/09 C N Adams 2.80 Telephone conference with working group regarding claims
processes; emails with claimants regarding receivership claims;
attention to delivery of St. Croix properties; telephone
conference with Stanford counsel regarding same; attention to
cash management issues.
06/02/09 J A Cialone, II .50 Attention to cash and account reports; calls with Stanford's
lawyers about personal effects and St. Croix properties;
attention to Vijay Singh issues and payments.
06/02/09 J T Leslie .60 Coordinated for the Tupelo office closing.
06/02/09 C W Rancher .90 Corresponded with J. Day of FTI and A. Galioto of Bank of
New York Mellon to release a wire payment held by the Bank
of New York Mellon's legal department.
06/03/09 C N Adams .80 Attention to files shipped from St. Croix; telephone conference
with Steve Lindstrom regarding same; receiving settlement
agreement; attention to suite lease.
06/03/09 J A Cialone, II 2.00 Prepared for and participated in extended meetings at
Receiver's office to cover multiple issues; attention to Houston
Rockets contract and Examiner questions; reviewed E&Y
financial statements, and emails related thereto.
06/03/09 J T Leslie .70 Telephone conference with Charlie Gale regarding Tupelo
office closure.
06/03/09 N M Starbuck 1.60 Updated receivership log to include employee responses to
requests for information; forwarded receivership
correspondence to C. Adams and R. Janvey.
06/04/09 C N Adams 2.90 Telephone conference with Joe Cialone regarding
REDACTED ; telephone conference with Steve
Lindstrom, Fred Fram and others regarding shipment of items;
telephone conference with Stanford counsel regarding
shipment of items; telephone conference with Jeanette Day
regarding claims; attention to payables.
06/04/09 J A Cialone, II 1.40 Planned meetings with Stanford lawyers to address personal
effects issues and other issues related to St. Croix.
06/04/09 J T Leslie .10 Attended to issues involving the Tupelo office closure.
06/04/09 N M Starbuck .60 Located correspondence re: Andrea Stoelker's counsel.
06/05/09 C N Adams 2.40 Telephone conference with bank regarding possible funds
available; attention to St. Croix shipment; reviewing invoices
for shipment; attention to agreement regarding return of wire
sent after receivership; reviewing contracts for Receiver's
signature; reviewing emails to receiver regarding claims;
241
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 175 of 377
Page 174
Hours Description
reviewing issues regarding office closures.
06/05/09 J A Cialone, II 1.70 Prepared for and participated in extended conference call with
team regarding various administrative and litigation issues;
attention to FTI imagining questions and control of work,
expenses; responding to lawyers for Andrea Stoelker
throughout the day; attention to asset sales complaints and
procedures; related calls and emails; calls and emails with
E&Y about financial statement preparation and ongoing work,
and efforts to control expenses.
06/05/09 J T Leslie 2.10 Telephone conference with Charlie Gale regarding the Tupelo
office closure; coordinated for receivership financial records;
coordinated for the Tupelo office closure.
06/07/09 C N Adams 1.30 Reviewing email claims; correspondence with Malcolm Lovett
regarding same.
06/08/09 C N Adams 2.30 Attention to cash management issues; reviewing materials
regarding American Express claims; attention to St. Croix
shipment issues.
06/08/09 J A Cialone, II 1.60 Extended call with Receiver about various routine and some
material topics related to the running of the Receivership;
emails from Examiner requesting additional work by Receiver
team, and considered appropriate responses thereto.
06/08/09 J T Leslie .40 Coordinated the Tupelo office closure.
06/09/09 C N Adams 2.20 Attention St. Croix property issues; reviewing St. Croix
shipping charges; reviewing claims regarding employee
bounced checks; reviewing payables; reviewing claims.
06/09/09 J A Cialone, II 1.50 Reviewed current drafts of FTI, Receiver, and other
declarations and papers; attended meeting with Davis and
Lovett; calls and emails about potential affirmative claims;
attention to St. Croix property issues.
06/09/09 J T Leslie .20 Coordinated the Tupelo office closure.
06/10/09 C N Adams 2.70 Telephone conference with EY regarding task list; revising St.
Croix inventory; reviewing property insurance issues;
reviewing claims issues; telephone conference with Malcolm
Lovett regarding outstanding receivership issues; reviewing
issues regarding yachts.
06/10/09 J A Cialone, II 1.90 Attention to TK input and communications; attention to
FINRA issues and prepared for conference call.
06/10/09 J T Leslie .60 Coordinated the Tupelo office closure; attended to other project
tasks.
242
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 176 of 377
Page 175
Hours Description
06/10/09 N M Starbuck 1.80 Forwarded correspondence to designated individuals/entities at
the guidance of J. Greer.
06/10/09 H C Tucker .50 Drafted a letter to REDACTED
.
06/11/09 C N Adams 3.10 Attention to St. Croix issues; revising letter to counsel for
Stanford; telephone conference with Joe Cialone regarding
same; reviewing invoices; reviewing asset sale protocol issues.
06/11/09 J A Cialone, II 1.50 Attention to Stanford demands for personal assets, including
calls and emails; attention to asset sales issues and procedures;
calls and emails with Doty about various issues.
06/11/09 J T Leslie .30 Telephone conference with Malcolm Lovett regarding project
coordination.
06/12/09 C N Adams 2.40 Reviewing custody forms for St. Croix materials; telephone
conference with Kristie Blumenschein regarding same;
reviewing inventory; telephone conference with Malcolm
Lovett regarding payable issue; reviewing claims against
receivership.
06/12/09 J A Cialone, II 1.20 Attention to Receiver matters.
06/12/09 S Jampala .50 Checked extranet and shared drive.
06/12/09 N M Starbuck 3.60 Assembled chain of custody reports for items received from
RAS' St. Croix residence; sorted correspondence in preparation
for delivery to designated parties.
06/14/09 J A Cialone, II 1.10 Assembled and organized materials for use in asset sales
process; reviewed cash report and prognosis for additional cash
and assets based on alternative scenarios.
06/15/09 C N Adams 2.20 Reviewing payable issues; telephone conference with Jeanette
Day regarding same; telephone conference with Malcolm
Lovett regarding open issues; reviewing correspondence to
receiver; reviewing asset sale protocols.
06/15/09 J A Cialone, II 1.60 Attention to requests for employee lists and developed a
response.
06/15/09 J T Leslie .20 Attended to project coordination.
06/15/09 N M Starbuck 2.90 Forwarded correspondence to designated individuals/entities at
the request of C. Adams.
06/15/09 H C Tucker .30 Assisted with drafting a letter to Mr. Singh.
06/16/09 C N Adams 3.00 Attention to liquidation of assets; reviewing asset sale protocol;
attention to St. Croix shipment issues; telephone conference
with Malcolm Lovett regarding open issues; telephone
243
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 177 of 377
Page 176
Hours Description
conference with Kristie Blumenschein regarding receivership
issues; reviewing hanger offer letters; reviewing claims;
reviewing payables.
06/16/09 J A Cialone, II 1.30 Attention to Stanford's various demands; meetings, calls and
emails throughout the day with Receiver and team.
06/16/09 J T Leslie 2.20 Reviewed claims and demands in connection with the office
closures; coordinated claims and demands; reviewed
documents related to the Tupelo office closure; completed
other project tasks.
06/16/09 N M Starbuck 2.40 Forwarded correspondence to designated individuals/entities at
the request of C. Adams; reviewed SGC media for RAS
speeches and SIBL information.
06/17/09 C N Adams 2.70 Reviewing claims correspondence to receiver; reviewing offers
to purchase yachts; reviewing issues regarding asset sales;
attention to information to be posted on website; reviewing
press release; telephone conference with Pierpont regarding
same.
06/17/09 J A Cialone, II 1.50 Worked on scheduling and staffing issues; reviewed budget
and plan of work; worked with Receiver on various
management issues; attention to Stanford's counsel changes
and considered consequences to schedule and asset deliveries
and dispositions.
06/17/09 J T Leslie .40 Reviewed documents related to the Tupelo office closures.
06/18/09 C N Adams 2.70 Reviewing insurance issues; reviewing issues regarding St.
Croix security; reviewing payables issues; telephone
conference with Malcolm Lovett regarding receivership claims;
reviewing employee accounts for release.
06/18/09 J A Cialone, II .30 Meetings, calls and emails throughout the day with Receiver
and various team members concerning document protocol and
production; attention to bankruptcy and related issues; attention
to media and other disclosure issues; attention to affirmative
claims asserted in lawsuits; attention to cash status and
prognosis; attention to account release and protocol; reviewed
Little's email requests and discussed handling.
06/19/09 C N Adams 1.50 Reviewing claims issues; telephone conference with Malcolm
Lovett regarding same.
06/19/09 J A Cialone, II 1.70 Worked on staffing and budgeting issues; reviewed emails
relating to asset collection and disposal efforts.
06/19/09 N M Starbuck 1.80 Updated production log and Receivership file index.
06/20/09 C N Adams .70 Reviewing FTI data regarding cash and asset identification.
244
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 178 of 377
Page 177
Hours Description
06/20/09 J A Cialone, II 1.10 Attention to EY and FTI issues.
06/21/09 C N Adams .40 Reviewing claims against the estate.
06/21/09 J A Cialone, II .50 Worked on various issues related to Stanford's demand for
return of or access to personal property.
06/22/09 C N Adams 3.60 Reviewing asset sale issues; telephone conference with
working group regarding same; telephone conferences with
Jeanette Day regarding payable issues.
06/22/09 J A Cialone, II .70 Calls and emails about routine receivership business.
06/22/09 J T Leslie .50 Attended to security matters with the Frizell Group; provided
information regarding Stanford entities to Craig Adams and
Shelley Austin; completed other project tasks.
06/22/09 N M Starbuck .90 Logged additional items obtained for Receivership file;
updated index for Receivership correspondence.
06/23/09 C N Adams .90 Reviewing claims issues; telephone conference with Malcolm
Lovett regarding same; telephone conference with Jeanette Day
regarding same.
06/23/09 J A Cialone, II .60 Emails and calls about criminal issues.
06/23/09 J C Huddleston .10 Attention to Stanford Financial Receivership mail distribution.
06/23/09 N M Starbuck 1.80 Communicated with S. Vidal Pope, SFGC Miami, re:
REDACTED
; revised Receivership production log; updated
document log to include additional correspondence and SIBL
financial information.
06/24/09 C N Adams .80 Reviewing payables for receivership; review of claims issues.
06/24/09 J A Cialone, II .80 Reviewed V.J. Singh issues.
06/24/09 J M Greer .20 Reviewed correspondence related to the receivership.
06/24/09 J T Leslie .20 Telephone conference with Susie Strong of the Frizell Group
regarding security invoices.
06/24/09 N M Starbuck .90 Filed correspondence and delivered to designated individuals.
06/25/09 C N Adams 1.10 Telephone conference with Jeanette Day regarding payable
issues; reviewing outstanding claims; telephone conference
with Steve Lindstrom regarding security issues.
06/25/09 J A Cialone, II .90 Various routine calls and emails with Receiver team.
06/25/09 J C Huddleston .70 Attention to mail received from Miami office; communicated
new address for communications to Javier Bermerdez in
Columbia.
245
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 179 of 377
Page 178
Hours Description
06/25/09 N M Starbuck 1.50 Prepared chain of custodies and received and processed
correspondence received from S. Pope of SFGC Miami;
contacted J. Bermerdez re: Colombian correspondence.
06/26/09 J A Cialone, II 1.80 Calls and emails throughout the day with Receiver and team
related to coins, accounts, litigation and other routine matters.
06/26/09 J C Huddleston 1.80 Reviewed secure room contents for James Davis passports.
06/26/09 M C Hurd .90 Corresponded with Adams and Tom Leslie regarding
REDACTED ; reviewed Stanford
production requests for any related to St. Croix shipment.
06/26/09 N M Starbuck 2.30 Prepared chain of custody and coordinated for delivery of
materials from A. Stoelker's St. Croix office; assisted in
conveyance of Stanley Melcer Irrevocable Trusts; prepped
correspondence for delivery to designated recipients.
06/27/09 J A Cialone, II 1.50 Considered various alternative strategies to maximize return to
receivership estate; related calls and emails.
06/27/09 Z T Pullin 6.00 Organized Stanford material concerning respecting
intercompany loans.
06/28/09 J A Cialone, II 1.10 Reviewed and considered affirmative claims.
06/29/09 C N Adams 1.10 Reviewing claims issues; reviewing offers for estate assets;
telephone conference with Malcolm Lovett regarding insurance
coverage issues; reviewing payables.
06/29/09 J A Cialone, II 1.40 Reviewed pinata slide and considered sources of funds and
assets.
06/29/09 M C Hurd 3.20 Corresponded with Craig Adams and Steve Lindstrom
regarding REDACTED ;
reviewed documents in St. Croix shipment and coordinated
preparation for shipment pickup; reviewed documents received
from closure of Dallas office.
06/29/09 S A Massad 1.00 Reviewed and commented on memorandum regarding 510(b)
issue; conference call and e-mail correspondence regarding
same.
06/29/09 Z T Pullin 10.20 Organizing binders on Stanford matter.
06/29/09 N M Starbuck 2.00 Duplicated items from A. Stoelker's St. Croix office; drafted
inventory and chain of custody, and prepared for transmittal to
representatives; prepared correspondence for review by Baker
Botts attorneys; forwarded correspondence to designated
parties/individuals.
06/30/09 C N Adams .30 Reviewing claims issue.
246
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 180 of 377
Page 179
Hours Description
06/30/09 J A Cialone, II 1.30 Several conference calls with team; worked on various routine
matters for Receiver.
06/30/09 J M Greer .80 Reviewed correspondence related to the Receivership Estate.
06/30/09 J C Huddleston 1.40 Reviewed A. Stoelker St. Croix box for chain of custody and
pick up.
06/30/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding status of several issues.
06/30/09 H C Tucker .30 Discussed certain sales tax revenue accounts with the
Mississippi Tax Commission; drafted a response to the
Mississippi Tax Commission's inquiry.
07/01/09 C N Adams .70 Telephone conference with Johanna Myers regarding Andrea
Stoelker property; telephone conference with Malcolm Lovett
regarding claims.
07/01/09 J A Cialone, II 1.20 Attention to budgeting and staffing issues to assist Receiver;
attention to ongoing operations plan; reviewed operating
statement; reviewed related Madoff materials as precedent.
07/01/09 J C Huddleston 7.70 Updated shared drive information to shared drive; sorted mail
for distribution; coordinated delivery of expired US passports
to Joe Cialone; reviewed Baker Botts' file for Antiguan
diplomatic passports; met with Johanna Myers in connection
with transfer of A. Stoelker fedex box from her St. Croix
office.
07/01/09 J T Leslie 1.40 Telephone conferences with Sue Robinson and Marisa Hurd
regarding paralegal staffing and file relocation; coordination
with respect to file relocation.
07/01/09 N M Starbuck 3.50 Prepared documents received from A. Stoelker's St. Croix
office for transmittal to J. Myers; updated Receivership file to
include documents from Latin America and the Eastern
Caribbean Bank; located RAS passport and prepared for
delivery to legal counsel.
07/02/09 C N Adams 1.60 Telephone conference with Joe Cialone regarding Stanford
passport; reviewing materials regarding same; telephone
conference with Malcolm Lovett regarding compliance issues;
reviewing payables; telephone conference with Jeanette Day
regarding obligations.
07/02/09 J A Cialone, II 1.20 Attention to issues related to expired passport; calls and emails
related to passport issues; attention to St. Croix asset issues;
calls with Doty.
07/02/09 J C Huddleston 6.00 Updated account holder information to shared drive; sorted
mail for distribution; reviewed Lodis room materials in
247
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 181 of 377
Page 180
Hours Description
connection with upcoming pickup.
07/02/09 M C Hurd .90 Phone call with Craig Adams regarding RAS and Stoelker St.
Croix boxes; reviewed inventory list of same; coordinated
review of same to additional items to be released.
07/02/09 C W Rancher 6.90 Reviewed the contents of six boxes of documents received
from Y. Suarez.
07/02/09 N M Starbuck 2.10 Met with S. Lindstrom re: transmittal and storage of documents
and belongings from St. Croix; at the request of FITS
determined whereabouts of correspondence relating to
Northern Trust.
07/02/09 H C Tucker 5.90 Reviewed files sent to Houston by Yolanda Suarez.
07/05/09 J A Cialone, II .70 Considered and formulated agenda for Monday status call.
07/05/09 M C Hurd .30 Reviewed correspondence from Craig Adams regarding
releasing additional St. Croix boxes to RAS and Stoelker.
07/06/09 C N Adams .90 Attention to St. Croix property; telephone conference with
Marisa Hurd regarding same.
07/06/09 J A Cialone, II 1.90 Prepared for and participated in extended conference call with
Receiver team; calls and emails about SEC proposal.
07/06/09 J C Huddleston 9.50 Attention to chain of custody and inventory to St. Croix II
boxes; updated account holder information to shared drive.
07/06/09 J T Leslie .40 Reviewed Allen Stanford American Express issues; completed
other project tasks.
07/06/09 N M Starbuck 7.90 Reviewed for potential release, prepared chain of custodies,
and inventoried twenty-four boxes of items obtained from RAS
personal residence.
07/06/09 H C Tucker .20 Instructed paralegals on what documents needed to be scanned
from the files of Yolanda Suarez.
07/07/09 C N Adams .60 Telephone conference with Malcolm Lovett regarding staffing
issues; reviewing payables; reviewing transfer of property
information.
07/07/09 J A Cialone, II .90 Several calls and emails with Receiver and team.
07/07/09 J C Huddleston 5.00 Updated account holder information to shared drive; researched
Polk County, Florida property indices for information relating
to Stanford International Bank mortgages; created electronic
backups of flagged Stanford email correspondence on behalf of
H. Tucker and C. Rancher.
07/07/09 M C Hurd .60 Corresponded with Steve Lindstrom regarding and coordinated
release of RAS and Stoelker St. Croix boxes; reviewed and
248
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 182 of 377
Page 181
Hours Description
updated inventory of St. Croix boxes.
07/07/09 N M Starbuck 5.40 Scanned and mailed flagged items from the email of custodians
Y. Suarez, D. Vitrian, and J. Tirado; assisted with the
transmittal of items from RAS St. Croix residence to J. Meyers;
forwarded correspondence to individuals designated by C.
Adams.
07/07/09 H C Tucker .20 Added claims to the claim log.
07/08/09 C N Adams .40 Telephone conference with Malcolm Lovett regarding issues
regarding asset sales.
07/08/09 J C Huddleston 7.30 Coordinated obtaining Louisiana and Texas Stanford employee
information pursuant to State of Louisiana production request;
attention to remaining Louisiana production requests;
processed account holder information to shared drive.
07/08/09 M C Hurd .70 Corresponded with paralegals and Adams regarding
REDACTED .
07/08/09 J T Leslie .10 Telephone conference with Bill Cominksy regarding staffing
matters; telephone conference with Clint Rancher regarding
claims.
07/08/09 C W Rancher 1.20 Corresponded with A. Galioto and J. Day regarding a missing
Stanford wire; discussed outstanding claims with K. Scanlan
and produced current log; performed project tasks.
07/08/09 H C Tucker 1.40 Compiled relevant documents from Yolanda Suarez's files for
further review.
07/09/09 C N Adams .80 Telephone conference with Fred Fram, Malcolm Lovett and
Rhonda Davis regarding compliance and personnel issues.
07/09/09 J C Huddleston 6.80 Performed detailed inventory of St. Croix II boxes; coordinated
custody transfer of Stanford jewelry to Paul Montgomery;
coordinated mail transfer to Houston Baker Botts' office.
07/09/09 M C Hurd .20 Corresponded with Craig Adams and paralegals regarding
REDACTED
.
07/09/09 J T Leslie .30 Coordinated consolidation of remaining office space.
07/09/09 N M Starbuck 8.30 Performed detailed inventory of items confiscated to RAS St.
Croix residence; coordinated transfer of A. Stoelker jewelry to
Paul Montgomery; coordinated for mail and computer
materials to Houston Baker Botts office.
07/10/09 C N Adams .90 Telephone conference with Malcolm Lovett regarding
operational issues.
249
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 183 of 377
Page 182
Hours Description
07/10/09 J M Greer .60 Reviewed legal correspondence related to the Receivership
Estate.
07/10/09 J C Huddleston 7.70 Performed detailed inventory of held St. Croix II boxes;
updated account holder information to shared drive; collected
and coordinated technology equipment return to Baker Botts
Houston office.
07/10/09 M C Hurd .20 Reviewed inventory of jewelry held from RAS and Stoelker St.
Croix boxes and corresponded with Craig Adams regarding
appraisal issue.
07/10/09 J T Leslie .10 Coordination of office consolidation.
07/10/09 C W Rancher .30 Drafted email to USPS regarding mail forwarding.
07/10/09 N M Starbuck 3.60 Continued in detailed inventory of items obtained from
Christiansted, St. Croix; prepared for the arrival of media
personal to document SFG Houston office.
07/11/09 J A Cialone, II 1.10 Organized file materials and reviewed same.
07/13/09 C N Adams 3.90 Conference with Malcolm Lovett regarding receivership
operating issues; reviewing pledge release agreement;
reviewing correspondence regarding claims against estate;
reviewing boat sale documentation; reviewing expense
reimbursement issues; reviewing St. Croix file issues.
07/13/09 J A Cialone, II .80 Attention to coins and bullion issues; calls and emails to assist
Receiver in administering Receiver business.
07/13/09 J C Huddleston 3.00 Completed inventory of St. Croix II boxes.
07/13/09 J T Leslie .50 Telephone conference with Steve Lindstrom regarding office
consolidation.
07/13/09 N M Starbuck 5.00 Inventoried items from St. Croix and scanned and duplicated
items flagged by M. Hurd; forwarded correspondence to
persons designated by C. Adams.
07/14/09 J A Cialone, II .70 Prepared for and participated in extended conference call with
team about various ongoing matters.
07/14/09 J T Leslie .30 Telephone conference with Nadia Starbuck and Marisa Hurd
regarding office consolidation; coordination regarding office
consolidation.
07/14/09 N M Starbuck 1.00 Assisted in the execution of Pledge Release for custodian K.
Leblanc.
07/15/09 C N Adams .70 Telephone conference with Malcolm Lovett regarding
American Express reimbursement issues; attention to 5050
Westheimer logistical issues; telephone conference with
250
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 184 of 377
Page 183
Hours Description
Malcolm Lovett regarding personnel issues.
07/15/09 J A Cialone, II 1.20 Attention to VNS; Calls and emails throughout the day related
to insurance, IRS and Examiner requests and communications.
07/15/09 J T Leslie .40 Review and coordination of open issues with respect to office
closures.
07/15/09 R K Shah .20 Communicated with Jim Grace concerning
REDACTED ;
spoke with representative of Democratic Governor's
Association to coordinate return of Stanford related
contribution, per request of Craig Adams.
07/16/09 C N Adams 1.40 Telephone conference with Jeanette Day regarding outstanding
invoices and issues regarding American Express balances;
telephone conference with Malcolm Lovett regarding
outstanding receivership issues; reviewing receivership
invoices.
07/16/09 N M Starbuck .30 Forwarded correspondence to individuals designated by C.
Adams.
07/17/09 C N Adams .70 Reviewing pledge releases; conference with Ralph Janvey
regarding same; reviewing FedEx and certified mail deliveries
to receiver.
07/17/09 J A Cialone, II .70 Calls and emails with Receiver about routine matters.
07/19/09 R K Shah .10 Communicated with Jim Grace concerning
REDACTED
.
07/20/09 C N Adams 1.20 Telephone conference with Kristie Blumenschein regarding St.
Croix shipments; telephone conference with Sam Cooper
regarding employee interviews; reviewing operational issues;
reviewing office stacking plan; reviewing claims issues.
07/20/09 J M Greer 1.50 Participated in an interview of Richard LaMothe.
07/20/09 J C Huddleston 4.40 Attention to reproduction of Stanford corporate files at the
direction of Harrison Tucker and Client Rancher; processed
incoming mail and boxes for delivery to A-1 Freeman
warehouse.
07/20/09 J T Leslie .30 Coordination of furniture liquidation; attended to other project
tasks.
07/20/09 R K Shah 1.10 Communicated with Jim Grace regarding
REDACTED ; spoke with Pamela
Sederholm at request of Jim Grace and discussed
REDACTED
251
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 185 of 377
Page 184
Hours Description
.
07/20/09 N M Starbuck 1.60 Distributed mail; prepared boxes for warehouse.
07/21/09 C N Adams 1.80 Telephone conference with Malcolm Lovett regarding
operational issues; reviewing claims against estate; reviewing
St. Croix file issues; reviewing payables.
07/21/09 N M Starbuck 4.50 Updated Receivership file to include chain of custodies and
documents received from C. Adams.
07/22/09 C N Adams .70 Reviewing offers to purchase assets; reviewing memorandum
regarding replacement of general partner.
07/22/09 J R Hollis .50 Inquiry into possible sale of miscellaneous equipment
07/22/09 J C Huddleston 7.70 Processed incoming mail; attention to boxes to be sent into
storage at A-1 Freeman Kirkton location.
07/23/09 C N Adams 1.10 Telephone conference with Malcolm Lovett regarding general
partner substitution issues; reviewing memorandum regarding
same; reviewing claims issues.
07/23/09 T M Davis .30 Exchange emails with B. Krage regarding vessel sale.
07/23/09 N M Starbuck 4.90 Received and reviewed Receivership correspondence;
maintained production log and Receivership file.
07/24/09 C N Adams 1.50 Telephone conference with Ben Krage and others regarding
REDACTED ; reviewing claims invoices; telephone
conference with Jeanette Day regarding payables issues.
07/24/09 J A Cialone, II .90 Call from defendant's lawyer; calls and emails throughout the
day related to Receiver duties.
07/24/09 T M Davis .70 Call with R. Janvey and B. Krage regarding vessel sale.
07/26/09 C N Adams .30 Reviewing open logistical issues regarding Houston and Miami
space.
07/26/09 J M Greer .20 Reviewed legal correspondence related to the Receivership
Estate.
07/27/09 C N Adams .40 Reviewing emails regarding claims and sales of assets.
07/28/09 C N Adams 1.00 Telephone conference with Ralph Janvey, Kristie
Blumenschein and Malcolm Lovett regarding lease and other
operational issues; reviewing emails regarding claims issues.
07/29/09 J T Leslie .20 Coordination of furniture liquidation; telephone conference
with Sue Robinson regarding staffing matters.
07/30/09 J A Cialone, II .50 Several calls with Receiver about routine receivership matters;
other routine work.
252
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 186 of 377
Page 185
Hours Description
07/30/09 T M Davis .60 Exchange emails regarding vessel sale.
07/30/09 J T Leslie .10 Coordination of furniture liquidation.
07/31/09 R K Shah .10 Communicated with Jim Grace concerning
REDACTED
.
08/03/09 J A Cialone, II .40 Reviewed draft status report on foreign accounts.
08/03/09 R K Shah .20 Communicated with Jim Grace regarding latest updates on
Pamela Sederholm and Stanford Financial PAC.
08/04/09 C N Adams 2.70 Attention to Stanford political action committee contributions;
telephone conference with Karyl Van Tassel regarding
Stanford operations; reviewing claims to website; attention to
same; telephone conference with vendors regarding assets;
reviewing St. Croix property issues; reviewing asset sale
protocol; telephone conference with Malcolm Lovett regarding
same; reviewing pending insurance matters; reviewing
payables; telephone conference with Jeanette Day regarding
same.
08/04/09 J A Cialone, II .40 Attention to political contributions issues; routine calls.
08/04/09 J T Leslie .80 Telephone conference with Jeff Hollis regarding REDACTED
; telephone conference with Craig Adams regarding
project issues.
08/04/09 R H Wood .60 Updated list of politicians who have returned Stanford
donations; created list of politicians and PACs that we have
contacted who have yet to return Stanford donations;
forwarded the same to S. Massad, J. Grace, J. Cialone, and R.
Shah; communicated with R. Shah and J. Grace regarding the
same.
08/05/09 C N Adams 1.90 Reviewing insurance renewal and cancellation materials;
attention to Stanford fund issues; attention to vendors regarding
equipment; attention to St. Croix trailers; reviewing payables
issues; reviewing political action committee contributions and
returns.
08/05/09 J M Greer .50 Reviewed legal correspondence related to the Receivership
Estate.
08/05/09 J R Hollis .40 Correspondence and follow-up regarding corporate matter.
08/05/09 J T Leslie .30 Office conference with Harrison Tucker with respect to
demand letters.
08/05/09 H C Tucker .40 Discussed and began drafting a demand letter to the Bellagio.
253
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 187 of 377
Page 186
Hours Description
08/06/09 C N Adams 1.10 Reviewing political action committee contribution information;
reviewing correspondence from counsel to Allen Stanford
regarding return of property; attention to payable and claims
issues.
08/06/09 J T Leslie .10 Coordination for document signatures.
08/07/09 C N Adams .80 Attention to return of Allen Stanford property; reviewing
employee expense reimbursement request data.
08/07/09 J A Cialone, II .40 Attention to political contribution returns.
08/07/09 J C Huddleston .20 Corresponded with Raul Interiano regarding outstanding
translation work.
08/08/09 J A Cialone, II .50 Prepared for meeting related to foreign accounts.
08/09/09 J A Cialone, II .70 Reviewed draft report and agenda for DOJ meeting August 19;
related calls and emails.
08/10/09 C N Adams 1.40 Telephone conference with Malcolm Lovett regarding
operations issues; reviewing account transfer release issues;
reviewing documents regarding same.
08/10/09 J A Cialone, II 1.20 Extended calls about REDACTED
; reviewed background materials; reviewed Senator
Dodd letter; reviewed draft agenda and related materials in
preparation for meeting with DOJ next week.
08/10/09 J C Huddleston 4.20 Corresponded with Raul Interiano regarding outstanding
translations; distributed Stanford mail as indicated;
corresponded with Steve Lindstrom regarding transmittal of
files and materials to warehouse; processed additional files for
return to warehouse storage.
08/10/09 N M Starbuck 4.10 Coordinated transfer of personal files and employee office
materials to Receivership warehouse; forwarded
correspondence to individuals designated by C. Adams;
Updated production log and document filing system.
08/10/09 H C Tucker .50 Drafted a demand letter to the Bellagio.
08/11/09 C N Adams 1.40 Telephone conference with Andy Beakley and Gary Osborne
regarding tax filings; reviewing materials regarding same;
reviewing St. Croix inventory; reviewing trailer lease.
08/11/09 J A Cialone, II 1.30 Worked on letter to Senator Dodd; calls and emails throughout
the day with DC lawyers and client concerning REDACTED
.
08/11/09 J C Huddleston .40 Corresponded with Raul Interiano and Ashleigh Brown in
regards to translation services.
254
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 188 of 377
Page 187
Hours Description
08/11/09 R K Shah .30 Reviewed, analyzed, and drafted response regarding
REDACTED ; communicated
with Jim Grace regarding indemnification issue.
08/11/09 N M Starbuck 3.10 Drafted inventory of items withheld from RAS and A. Stoelker
St. Croix residence.
08/12/09 C N Adams 1.30 Reviewing claims website; reviewing issues regarding St.
Croix trailer lease; reviewing inquiry regarding claim;
reviewing expense issues;attention to issue regarding Havell
fund.
08/12/09 J A Cialone, II 1.00 Worked on draft testimony for Senate Committee hearing;
numerous calls about testimony and attendance; worked on
letter to Dodd.
08/12/09 J T Leslie .60 Reviewed letter to Bellagio with respect to assets of Allen
Stanford; email response to inquiry by Charlie Gale regarding
computers and assets sales; attended to other emails.
08/12/09 R K Shah .10 Communicated with Jim Grace regarding REDACTED
.
08/12/09 N M Starbuck 5.90 Drafted inventory of items withheld from RAS and A. Stoelker
St. Croix residence; duplicated items designated by M. Hurd as
returnable from St. Croix shipment.
08/13/09 C N Adams 2.60 Review of Ken Weeden expense reimbursement issue;
reviewing yacht expenses; attention to STC transfer issues;
reviewing employee expense reimbursement issues.
08/13/09 J A Cialone, II 1.10 Worked on Senate Committee testimony; related calls and
emails throughout the day.
08/13/09 J C Huddleston 1.20 Corresponded with Transperfect translation regarding services;
reviewed previous translation provided by Raul Interiano in
conjunction with new translation (Grovemill) from
Transperfect; communicated change of translation service to
Transperfect given product delivery issues due to size and
staffing issues with Mr. Interiano's business.
08/13/09 N M Starbuck 6.10 Prepared chain of custodies and inventory reports for 8 boxes
of items retained from RAS/ A. Stoelker's St. Croix residence;
At the request of M. Hurd duplicated items designated as
eligible to be returned to A. Stoelker's attorney.
08/14/09 C N Adams 1.60 Telephone conference with Malcolm Lovett regarding
operational issues; reviewing cash management issues;
reviewing claims issues.
08/14/09 J A Cialone, II 1.30 Reviewed witness list and proposed testimony at Baton Rouge
hearing; worked on Janvey testimony.
255
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 189 of 377
Page 188
Hours Description
08/14/09 J C Huddleston .50 Reviewed revised Stipulated Release translation and
certification from Transperfect.
08/14/09 C W Rancher .60 Reviewed incoming Stanford mail for distribution.
08/14/09 N M Starbuck 7.30 Assisted M. Hurd with inventory, duplication, and preparation
for delivery to A. Stoelker's attorney items received from
RAS's St. Croix residence.
08/15/09 J A Cialone, II .50 Worked on hearing issues; related emails about witnesses and
what testimony is needed.
08/16/09 C N Adams .80 Attention to issues regarding closure of Westheimer location;
reviewing payable issues.
08/17/09 C N Adams .70 Reviewing invoices for Sea Eagle; telephone conference with
Malcolm Lovett regarding operational issues.
08/17/09 J R Hollis .70 Follow-up with Fred Fram regarding Thompson-Reuters issue.
08/17/09 J T Leslie .30 Reviewed project documents.
08/17/09 C W Rancher 1.00 Reviewed and routed receivership mail to appropriate parties.
08/17/09 N M Starbuck 5.30 At the request of C. Adams forwarded to FTI and Baker Botts
attorneys documents retained by Receivership from RAS/A.
Stoelker's St. Croix residence; Re-drafted inventory of items
from St. Croix.
08/18/09 C N Adams 2.80 Telephone conference with Johanna Myers regarding R.
Stanford and A. Stoelker possessions; reviewing data regarding
same; telephone conference with Ken Weeden regarding
employee claims; emails with Jeanette Day regarding invoice
issues; reviewing Cane Global agreement; reviewing updated
cash flow information; reviewing outstanding payables.
08/18/09 J A Cialone, II .60 Various calls and emails in preparation for DOJ meeting
tomorrow; reviewed background information.
08/18/09 J R Doty 2.50 Conference with Van Tine, Cialone, et al.; attention to hearing
and next steps.
08/18/09 K L Karp 5.90 Filed additional documents within the Stanford receivership
records database; assisted M. Hurd with duplication and
preparation for delivery to A. Stoelker's attorney items received
from RAS's St. Croix residence.
08/18/09 N M Starbuck 7.40 Filed additional documents within the Stanford Receivership
records database; Assisted M. Hurd with duplication and
preparation for delivery to A. Stoelker's attorney items received
from RAS's St. Croix residence; Assisted B. Stutts with
relocation of files; Reviewed contents of filing systems for
256
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 190 of 377
Page 189
Hours Description
subpoenas and affidavits re: ADT vs. Alert 24.
08/18/09 H C Tucker .50 Drafted demand letter regarding account information for R.
Allen Stanford.
08/19/09 C N Adams .90 Conference with Ralph Janvey and Kristie Blumenschein
regarding open receivership issues; attention to same.
08/19/09 J A Cialone, II 1.60 Prepared for and participated in video conference with DOJ
and SEC representatives.
08/19/09 K L Karp 5.30 Assembled office files per C. Adams; prepared chain of
custodies and inventories of items withheld from RAS and A.
Stoelker St. Croix residence.
08/19/09 C W Rancher .20 Responded to project correspondence.
08/19/09 N M Starbuck 7.30 Assembled office files per C. Adams; Updated Receivership
log to include additional documents; Prepared contents of St.
Croix boxes for return to A. Stoelker's attorney.
08/20/09 C N Adams 2.20 Internal working group call regarding open issues; reviewing
open receivership issues; telephone conference with Malcolm
Lovett regarding same; reviewing payable issues; reviewing
correspondence to receivership.
08/20/09 J R Doty 2.00 Attention to next steps and relevant materials; conferences
thereon.
08/20/09 K L Karp 5.20 Prepared attorney materials for relocation within the SFG
Houston Office; quality-checked inventory of
materials/documents from St. Croix.
08/20/09 N M Starbuck 7.30 Prepared attorney materials for relocation within the SFG
Houston Office; quality-checked inventory of
materials/documents from St. Croix.
08/20/09 W F Stutts, Jr. .70 Reviewed inquiries related to insurance related to the Antiguan
operations and properties.
08/21/09 C N Adams 3.50 Preparing interim report of receiver; correspondence with team
regarding same; reviewing operations issues.
08/21/09 K L Karp 5.00 Conference call with M. Hurd regarding St. Croix materials;
conference with S. Lindstrom, M. Bader, and R. Davis re:
relocation of files and personnel; reviewed and prepared A.
Stoelker's St. Croix materials for delivery to J. Myers.
08/21/09 J T Leslie .30 Attended to project emails and letters.
08/21/09 N M Starbuck 5.10 Conference call with M. Hurd regarding St. Croix materials;
Conference with S. Lindstrom, M. Bader, and R. Davis re:
Relocation of files and personnel; Reviewed and prepared A.
257
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 191 of 377
Page 190
Hours Description
Stoelkers' St. Croix materials for delivery to J. Myers.
08/22/09 C N Adams .40 Preparing interim report.
08/23/09 C N Adams 1.10 Preparing draft of receiver report.
08/24/09 C N Adams 2.90 Preparing draft report of receiver; various calls with
professional regarding information for report; reviewing claims
made against receivership report; telephone conference with
Andy Beakley regarding accounting and tax issues; telephone
conference with Malcolm Lovett regarding operational issues;
reviewing account payable issues; reviewing issue regarding
property insurance of Antiguan entities.
08/24/09 J A Cialone, II 1.30 Telephone conference with Bill Jeffress about various criminal
procedure issues affecting the Estate; calls and emails about
claims against Barnes.
08/24/09 J T Leslie .20 Coordination for gathering of information with respect to the
Receiver's report to the court.
08/24/09 N M Starbuck 1.10 Coordinated with A-1 Freeman personnel re: Review of
Warehouse materials by D. Fraser.
08/25/09 C N Adams 2.20 Telephone conference with Kristie Blumenschein regarding St.
Croix issues; reviewing documents regarding same; reviewing
payable issues.
08/25/09 J A Cialone, II .30 Worked on Media Plan to provide updated information to
investors.
08/25/09 J T Leslie .20 Telephone conference with Jan Nestor of CBRE regarding
information for the court report; responded to project emails.
08/26/09 C N Adams 1.40 Preparing draft report of receiver; reviewing data regarding
return of PAC contributions; reviewing payables;
teleconference with vendor regarding claim.
08/26/09 J T Leslie .60 Fact gathering for the Receiver's report to the court; drafted
part of the Receiver's report to the court.
08/27/09 C N Adams 1.50 Preparing draft of receivers report; teleconference with Tom
Leslie regarding office closure issues; reviewing list of
employees who contributed to PAC; teleconference with
Malcolm Lovett regarding same.
08/27/09 J A Cialone, II .50 Calls and emails about follow-up work with Davis to find
assets and accounts.
08/27/09 J T Leslie 1.30 Drafted the office closure summary with respect to the
Receiver's report to the court; telephone conference with Steve
Lindstrom and Rhonda Davis regarding office closure data;
reviewed project documents; attended to project emails.
258
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 192 of 377
Page 191
Hours Description
08/28/09 C N Adams 1.40 Reviewing documents for Ralph Janvey's review and signature;
attention to claims.
08/30/09 C N Adams .50 Attention to interim report.
08/31/09 C N Adams 4.80 Preparing draft report of receiver; teleconference with Jeanette
Day regarding cash management and payables issues;
reviewing outstanding claims.
08/31/09 J T Leslie .20 Drafted demand letter regarding RAS accounts.
Matter Total 478.90
079716.0114 Real Estate Matters
Hours Description
06/01/09 S W Austin .10 Replied to Kim Schlanger regarding plans/specs for hangar.
06/01/09 K E Schlanger 7.80 Finalized settlement agreements with Boston landlord, Orlando
landlord, Jackson landlord and Schwab; Reviewed Sugar Land
hangar ground lease; Email correspondence with CBRE
regarding Sugar Land hangar ground lease; Correspondence
regarding response to Memphis landlord's administrative claim;
Follow up regarding property taxes for 20 Casuarina; Prepared
real estate issues/task list; Drafted settlement agreement for
Houston warehouse.
06/01/09 T R Swearingen 3.20 Drafting Form of Purchase and Sale Agreement for real
property assets.
06/01/09 R P Wright .80 Correspondence with Joe Cialone; Malcolm Lovett regarding
airport; office conference with Kim Schlanger regarding
general status of all issues.
06/02/09 S W Austin .20 Replied to Kim Schlanger regarding Doug Hubener; replied to
Kim Schlanger regarding CBRE; sent e-mail message to Doug
Hubener regarding same.
06/02/09 H T Hamner III .30 Emails to B. Govett, J. Hamilton regarding
REDACTED
06/02/09 K E Schlanger 7.20 Correspondence regarding Atlanta administrative claim;
Correspondence regarding Sugar Land hangar;
Negotiated/finalized Boston settlement agreement; Finalized
San Francisco settlement agreement; Follow up with Herschel
Hamner and David Arlington regarding Trustmark L/C
benefitting 330 Madison; Tracked down information on
Nashville rugs; Reviewed Davis Holdings properties in
Baldwyn, MS; Discussed insurance issues with Bob Wright;
259
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 193 of 377
Page 192
Hours Description
Correspondence regarding repairs of Bastrop condos; Marked
up Orlando settlement agreement.
06/02/09 E A Soderlund .30 Call with K. Schlanger regarding REDACTED
.
06/02/09 T R Swearingen 3.40 Drafting form of Purchase and Sale Agreement for real
property assets.
06/02/09 R P Wright .40 Communications with Malcolm Lovett, Charles Gordon
regarding Sugarland hangar; communications with Kim
Schlanger regarding insurance.
06/03/09 H T Hamner III 2.30 Drafted letter to Bank of Houston regarding
REDACTED
; sent same
to M. Lovett for review.
06/03/09 J T Leslie .10 Coordination for closure of the Memphis storage units.
06/03/09 K E Schlanger 4.00 Worked on reconciliation of furniture liquidations; Reviewed
response to Atlanta landlord's proposed administrative claim;
Reviewed Trustmark's motion to intervene; Call with Michael
Palmer regarding Sugar Land hangar; Reviewed FTI's property
list; Determined which properties the Receiver should insure;
Correspondence regarding Atlanta landlord eviction request.
06/03/09 T R Swearingen 5.10 Drafting form of Purchase and Sale Agreement for real
property assets; drafting letter to Atlanta landlord regarding
administrative claim.
06/03/09 R P Wright 1.30 Communications with Kim Schlanger regarding Florida
appraisal; Malcolm Lovett regarding Sugarland hangar
appraisal; attention to landlord responses on administrative
costs; attention to appraisal contract for Houston buildings;
telephone conference with Roger Williams, Craig Adams.
06/04/09 K E Schlanger 2.20 Drafted email summarizing insurance recommendations; Call
with Jeanette Day to discuss assets and liabilities; Reviewed
Atlanta landlord's order seeking eviction; Email
correspondence regarding Trustmark payment of 330 Madison
letter of credit; Call with Michael Palmer regarding Sugar Land
hangar; Finalized Orlando settlement agreement.
06/04/09 T R Swearingen 2.70 Finalizing letter to Atlanta landlord; drafting form of Purchase
and Sale Agreement for real property assets.
06/04/09 T J Walters .70 Research custodian issues under 543.
06/04/09 R P Wright 1.30 Attention to Trustmark filing; Atlanta landlord issues; Holly
Springs insurance issues; Hill St. improvements claims; 505
260
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 194 of 377
Page 193
Hours Description
Bastrop insurance work issues; correspondence with Kevin
Sadler, Clint Davis, Craig Adams, Kim Schlanger, Malcolm
.
Lovett regarding REDACTED
06/05/09 J C Huddleston .30 Reviewed concourse level files at 5050 Westheimer to obtain
Stanford Development Company's tax id number.
06/05/09 K E Schlanger 4.00 Call with Charlie Gale regarding Baldwyn properties; Call with
Ethan Nanni regarding Baldwyn properties; Call with John
Haynes regarding Forefront Golf facility; Call with Craig
Lundrum regarding Farmers and Merchants Bank mortgages;
Email correspondence with Malcolm Lovett regarding asset
sales in Tupelo and Denver; Email correspondence with
Michael Palmer regarding Sugar Land hangar documents; Call
with Amegy regarding mortgage on 5476 Holly Springs; Email
correspondence regarding property taxes for 20 Casuarina.
06/05/09 R P Wright .70 Obtain and forward tax consulting agreement to Roger
Williams; attention to property insurance issues.
06/07/09 K E Schlanger 3.00 Updated lease rejection and fixed asset disposition memo and
prepared for meeting regarding real property insurance and
maintenance.
06/08/09 H T Hamner III .70 Revised letter to J. Hamilton regarding new draw by Schwab
under letter of credit per comments from B. Govett; reviewed
new draw request from Schwab, provided comments on same.
06/08/09 K E Schlanger 8.00 Meeting with Malcolm Lovett, Jeanette Day, Kerry Jackson,
Fred Fram, Steve Lindstrom, Rhonda Davis and Bob Wright to
discuss real property insurance and maintenance issues;
Discussed REDACTED with
Jeanette Day; Read water well maintenance agreement for
Forefront facility; Email correspondence with Bob Wright and
Michael Palmer regarding appraisals of Sugar Land hangar;
Email correspondence with Charlie Gale regarding utility bills
for Baldwyn properties; Organized settlement and termination
agreements with landlords; Email correspondence with Day
Pitney regarding Boston settlement agreement; Follow up
regarding payment of Trail Partners property taxes; Follow up
regarding real property sales motion; Reviewed Atlanta
landlord's eviction motion.
06/08/09 T R Swearingen 3.50 Finalizing initial draft of form of Purchase and Sale Agreement
for real property assets.
06/08/09 R P Wright 3.50 Attend meeting at Stanford with accountants, Malcolm Lovett,
Kim Schlanger regarding taxes, insurance, maintenance and
other issues regarding fee-owned properties; email
correspondence with Kim Schlanger, Kevin Sadler regarding
261
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 195 of 377
Page 194
Hours Description
REDACTED .
06/09/09 J A Cialone, II .40 Attention to Swiss real estate issues.
06/09/09 T M Davis .80 Read objection to Real Estate sale motion (.6); discuss with M.
Lovett (.2).
06/09/09 K E Schlanger 6.80 Follow up regarding St. Croix hangar; Call with Michael
Palmer regarding Sugarland hangar; Distributed signature
pages to Boston and Orlando settlement agreements; Follow up
with landlord's counsel regarding administrative claim for 1399
New York Avenue; Follow up with landlord's counsel
regarding McLean termination agreement; Organized
settlement agreements; Provided Jeanette Day with backup
information for lease liabilities; Sent payment requests to
Jeanette Day; Email correspondence regarding insurance for
Antigua properties; Email correspondence regarding insurance
for Baldwyn properties; Reviewed St. Croix leases regarding
utilities questions; Revised order regarding Atlanta premises;
Call with Larry Richards regarding St. Croix hangar; Call
regarding Forefront property; Email correspondence regarding
Schwab/Bank of Houston letter of credit; Reviewed request for
production.
06/09/09 T R Swearingen 3.10 Finalizing draft of Purchase and Sale Agreement for real
property assets.
06/09/09 T J Walters 2.40 Researching 543 turnover issues.
06/09/09 R P Wright 1.10 Attention to responses to real estate motion; Casuarina property
tax consultant and tax contest, and telephone conference with
Renn Neilson, Jon Wellington; email correspondence to
Malcolm Lovett regarding same.
06/10/09 C N Adams .30 Reviewing property disposition issue.
06/10/09 J A Cialone, II .50 Calls and emails about real estate and other issues involving
Swiss assets.
06/10/09 T M Davis .80 Read emails regarding real estate summaries (.6); telephone
conference with B. Wright re same (.2).
06/10/09 K E Schlanger 8.00 Read Examiner's Motion in Response to Real Property Sales
Motion; Call with Eric Soderlund and Bob Wright to discuss
response to Examiner's Motion; Reviewed memo regarding
lease dispositions; Prepared chart for lease dispositions; Email
correspondence regarding property insurance in St. Croix and
U.S.; Email correspondence regarding St. Kitts property; Email
correspondence regarding disposition of steel in St. Croix;
Email correspondence regarding Sugar Land hangar;
262
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 196 of 377
Page 195
Hours Description
Responded to inquiries regarding Comanche law suit in St.
Croix;; Reviewed Bob Wright's comments to CBRE listing
agreement.
06/10/09 E A Soderlund 1.20 Outline proposed response to Examiner's brief regarding real
estate sale procedures motion and distribute same to team (1.2).
06/10/09 E A Soderlund .20 Email exchanges with B. Wright and K. Schlanger regarding
legal characterization of certain property on leased land, and
effect on potential landlord claims (0.2).
06/10/09 R P Wright 6.10 Communications with Joe Cialone, Malcolm Lovett regarding
responses to questions on furniture sales; communications with
Kim Schlanger, Eric Soderlund regarding examiner's response;
attention to development of additional information on real
property issues; attention to insurance arrangement
recommendations and communications with Craig Adams, et
al. regarding same; attention to proposed website information;
attention to sale of St. Croix hangar steel and trailers.
06/11/09 K E Schlanger 4.00 Call with Malcolm Lovett to discuss REDACTED
; Call with Jeanette Day regarding leased property
matrix; Revised leased property matrix; Met with Bob Wright
to discuss REDACTED
;
Call with Russell Lewis regarding St. Croix litigation; Call
with Basil Umari regarding Sugar Land hangar lease; Email
correspondence with Charlie Gale regarding property
insurance.
06/11/09 T R Swearingen 2.20 Attention to master lease chart and summarizing lease status.
06/11/09 T J Walters 3.50 Investigating insurance practice for under secured real assets.
06/11/09 R P Wright 4.40 Attention to development of lease spreadsheet; insurance
summary; office conferences with Kim Schlanger regarding
lease value added; St. Croix hangar; St. Croix steel; insurance
generally and with specific property contexts; communications
with Kim Schlanger, Eric Soderlund regarding same.
06/12/09 K E Schlanger 3.00 Prepared revised list of owned properties; Contacted banks to
find out balances of outstanding mortgages on owned
properties; Revised leased property matrix; Call with Jeanette
Day regarding lease property matrix; Reviewed revised
McLean termination agreement.
06/12/09 R P Wright 2.40 Attention to issues list; response to Examiner's objection;
telephone conference with Malcolm Lovett; conference with
Charles Gordon; attention to appraisal issues.
263
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 197 of 377
Page 196
Hours Description
06/14/09 J A Cialone, II .40 Reviewed real estate spreadsheet.
06/15/09 T M Davis .80 Exchange many emails regarding Atlanta lease claim.
06/15/09 K E Schlanger 3.50 Email correspondence regarding Atlanta landlord's
administrative claim; Call with Tim Swearingen regarding
potential purchaser of St. Croix property; Call with Doug
Hubener regarding disposition of St. Croix steel and Sugarland
hangar; Call with Chad Hammons regarding Davis Holdings
properties; Email correspondence with Charlie Gale regarding
114 W. Main in Baldwyn; Drafted termination agreements with
storage companies; Email correspondence regarding 5100
Westheimer security deposit; Coordinated site inspection of
5050 Westheimer;.
06/15/09 E A Soderlund 9.20 Draft reply to examiner's brief in response to motion to approve
real property sales procedures.
06/15/09 T R Swearingen 1.10 Call with Bruce Brandon to discuss interest in St. Croix
residence; creating chart regarding interested buyers.
06/15/09 R P Wright .30 Attention to St. Croix purchase offer; sublease at 5050
Westheimer.
06/16/09 J A Cialone, II 1.70 Worked on real estate issues, including document review and
related calls and emails.
06/16/09 K E Schlanger 7.00 Reviewed and revised chart of landlords' claims;
Correspondence with Jeanette Day and Tim Swearingen
regarding landlords' claims chart; Reviewed emails regarding
furniture disposition; Reviewed reply to Examiner's brief in
response to real property sales motion; Read press release
regarding sales of assets; Reviewed revised McLean
termination agreement.
06/16/09 E A Soderlund 8.40 Review and prepare replies to multiple responses to real
property sale procedures motion.
06/16/09 T R Swearingen 5.30 Reviewing master lease chart and providing comments.
06/16/09 W C Watts 1.20 Reviewed Stanford Antiguan filings with respect to real estate
holdings; created precedent for use in filing motions in Antigua
with respect to same.
06/16/09 R P Wright 1.40 Attention to real estate sales issues; appraisal estimates.
06/17/09 T M Davis .20 Discuss Atlanta issues with B. Wright.
06/17/09 K E Schlanger 7.80 Meeting with Jeanette Day to discuss leased property matrix;
Revised leased property matrix; Email correspondence
regarding Sugar Land hangar; Email correspondence regarding
valuation of 5050 Westheimer; Email correspondence with
264
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 198 of 377
Page 197
Hours Description
BNY Mellon regarding Coral Gables property; Call with Bob
Wright and Kristie Blumenschein regarding asset sale press
release; Revised asset sale press release.
06/17/09 W C Watts 4.50 Reviewed Stanford filings with respect to lands in Antigua;
reviewed numerous provisions of relevant Antiguan
constitutional law, the registered land act, the non-citizens land
holding act, and the land acquisition act.
06/17/09 R P Wright 2.00 Attention to hangar sale; Atlanta landlord administrative fee
negotiations; correspondence with Malcolm Lovett; telephone
conference with Tony Davis; attention to article and telephone
conference with Kristie Blumenschein and Kim Schlanger
regarding same.
06/18/09 T M Davis .40 Review and comment on response to Real Estate Sale
Objection.
06/18/09 K E Schlanger 5.70 Reviewed offer for Sugar Land hangar; Reviewed offer for
generator in St. Croix; Prepared exhibit to reply to motion to
approve real property sale procedures; Revised leased property
matrix; Followed up regarding title to property owned by
Developers of America; Revised REDACTED
; Drafted confidentiality agreement
for potential purchasers of Sugar Land hangar.
06/18/09 W C Watts 3.70 Conducted research with respect to non-citizens land holding
act and the land registration act; reviewed filings by Stanford
attorneys; drafted brief memo regarding REDACTED
.
06/19/09 T M Davis 1.10 Read and respond to emails regarding process.
06/19/09 K E Schlanger 4.50 Revised lease rejection memorandum; Reviewed and
commented on reply to responses to real property sales motion;
Email correspondence with Property Tax Matters regarding
5050 Westheimer; Email correspondence regarding rejection
claim for Richmond permanent lease; Call with landlord's
lawyer regarding leased equipment in 5051 Westheimer.
06/19/09 E A Soderlund 5.40 Draft, revise, and edit consolidated reply to responses to real
property sale motion.
06/19/09 T R Swearingen 1.80 Reviewing leases for damage and default provisions.
06/19/09 R P Wright .50 Attention to response to real property sales motion; rejection of
Richmond lease; property taxes.
06/20/09 T M Davis .60 Read and comment on draft response.
06/21/09 K E Schlanger .80 Reviewed and commented on response to real property sales
265
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 199 of 377
Page 198
Hours Description
motion.
06/22/09 J A Cialone, II .50 Prepared for and participate in real estate conference call.
06/22/09 T M Davis 2.20 Call regarding sales of all assets.
06/22/09 K E Schlanger 4.80 Prepared agenda for real estate call; Revised lease rejection
chart; Real estate call; Revised reply to response to real estate
motion; Email correspondence regarding offers for trailers
located on St. Croix ground lease.
06/22/09 E A Soderlund 1.80 Revise and edit consolidated reply to responses to real property
sale procedures motion.
06/22/09 T R Swearingen 1.20 Call to discuss lease provisions regarding damages; calls to
discuss process for handling unsolicited offers on owned real
property.
06/22/09 T J Walters .70 Researching real estate lease damages for non-commenced
leases.
06/22/09 R P Wright 4.40 Attention to St. Croix property inquiries; communications with
Charles Gordon regarding sales procedures; telephone
conference with Craig Adams, Kevin Sadler, Joe Cialone,
Malcolm Lovett, Tony Davis, Ralph Janvey, et al. regarding
real estate issues; draft motion language.
06/23/09 S A D Ayers 2.00 Drafted subpoenas to Becki Stanford, purchaser of Florida
home and attorneys who prepared deed; drafted motion to
compel;
06/23/09 J A Cialone, II .80 Reviewed real estate materials and related calls and emails.
06/23/09 J C Huddleston .20 Reviewed Stanford files in 5050 Westheimer concourse level
for Sugar Land lease exhibits; transmitted same to attorney for
review.
06/23/09 K E Schlanger 3.60 Reviewed and revised reply to responses to real property sales
motion; Email correspondence regarding sale of St. Croix
hangar; Email correspondence with Micheal Palmer at CBRE
regarding Sugar Land hangar; Email correspondence regarding
Baldwyn properties insurance and rent payments; Revised
CBRE listing agreement.
06/23/09 E A Soderlund 2.80 Revise and edit consolidated reply to conform to changes
suggested by reviewing partners and client; prepare and direct
the filing service of same (2.8)
06/23/09 T R Swearingen 2.00 Attention to lease default provisions and coordinating review;
attention to emails regarding unsolicited offers of owned real
property.
06/23/09 R P Wright 2.10 Attention to real estate motion response; drafting;
266
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 200 of 377
Page 199
Hours Description
communications with Kristie Blumenschein, Eric Soderlund,
Kim Schlanger, Malcolm Lovett, Charles Gordon regarding
same.
06/24/09 S A D Ayers .50 Attention to sale of Florida house by Becki Stanford.
06/24/09 K E Schlanger 2.50 Revised and distributed CBRE listing agreement; Email
correspondence regarding Miami personal property taxes;
Email correspondence regarding REDACTED
; Email correspondence
regarding REDACTED ; Follow up regarding
mortgage payments for 5050 Westheimer.
06/24/09 T R Swearingen 1.10 Calls to discuss lease default provisions and offer on St. Croix
residence; call from Bruce Brandon to discuss timing of offer
and details.
06/24/09 R P Wright 3.90 Attention to response to real estate motion; commission
agreement with CBRE; telephone conference with Malcolm
Lovett, Charles Gordon regarding same; office conference with
Kim Schlanger regarding same and regarding furniture tax lien
claims.
06/25/09 S A D Ayers .50 Attention to Houston condominium.
06/25/09 K E Schlanger 2.00 Email correspondence regarding maintenance issues at Anchor
Inn; Call with Kristian Nielsen at CBRE to discuss fees; Email
correspondence regarding Miami personal property taxes; Call
with Jeanette Day regarding REDACTED .
06/25/09 W C Watts 2.20 Drafted application to Antiguan registrar of lands for restriction
on Stanford lands.
06/26/09 K E Schlanger 1.70 Reviewed CBRE Consulting Agreement; Call with Jeanette
Day regarding lease rejection memo and chart; Call with Tony
Davis regarding landlord claims resolution and sale procedures;
Email correspondence with Matt Wood regarding eviction of
Randi Stanford; Email correspondence with Sue Ayers
regarding Collierville condo; Email correspondence regarding
Forefront facility maintenance; Email correspondence with
Wiles & Wiles regarding settlement with Atlanta landlord.
06/26/09 W C Watts .40 Revised Application for restriction on Antiguan lands.
06/26/09 R P Wright .40 Attention to email correspondence regarding land sales.
06/28/09 K E Schlanger .80 Email correspondence with Craig Adams regarding list of
owned properties; Reviewed CBRE consulting agreement.
06/29/09 S A D Ayers 1.00 Reviewed and edited motion for contempt against Randi
Stanford.
267
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 201 of 377
Page 200
Hours Description
06/29/09 K E Schlanger 3.00 Marked up CBRE consulting agreement; Email correspondence
with Steve Lindstrom regarding status of equipment lease
rejection letters; Reviewed offers for 5050 Westheimer and
Sugar Land hangar to determine whether they included
furniture; Coordinated settlement of administrative claims with
Dallas and Orlando landlords; Reviewed revised lease rejection
chart; Reviewed correspondence relating to dissolution of
Spring Creek LLC and Old Bull LLC.
06/30/09 K E Schlanger 1.30 Reviewed Kristie Blumenschein's comments to CBRE listing
agreement; Coordinated settlement of administrative claim
with Orlando landlord; Email correspondence regarding
Trustmark motion.
07/01/09 K E Schlanger 2.70 Email correspondence with David Arlington regarding
Trustmark motion; Follow up regarding personal property taxes
for Miami FF&E; Reviewed memo on fully settled landlord
claims; Email correspondence with David Arlington and Kevin
Sadler regarding Farmers & Merchants Bank's's motion to
intervene; Revised CBRE agreements; Email correspondence
with Jon Herbert regarding Kings Alley property.
07/02/09 K E Schlanger 3.00 Prepared for call with Farmers & Merchants Bank's's attorney;
Call with Farmers & Merchants Bank's's attorney regarding
motion to intervene; Revised CBRE listing agreement and
consulting agreement.
07/02/09 R P Wright 1.00 Communications with Kim Schlanger regarding motion by
Farmers and Merchants Bank; CBRE contracts.
07/03/09 S A D Ayers .80 Edited motion for contempt against Randi Stanford
REDACTED
.
07/04/09 S A D Ayers .70 Edited motion and order for contempt against Randi Stanford.
07/05/09 S A D Ayers .50 Edited and finalized motion for contempt against Randi
Stanford for presentation to the Receiver.
07/06/09 K E Schlanger 5.50 Reviewed draft of leased property matrix and lease rejection
memo; Call with Jeanette Day to discuss leased property matrix
and memo; Revised lease rejection memo; Email
correspondence with Jeanette Day regarding
REDACTED
; Reviewed motion regarding eviction of Randi
Stanford from Huntington condo; Email correspondence with
Kathy Wetmore regarding Huntington condo; Organized
termination agreements; Email correspondence with Kevin
Sadler regarding REDACTED .
268
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 202 of 377
Page 201
Hours Description
07/06/09 R P Wright 1.30 Attention to email correspondence; Randi Stafford petition; St.
Croix and Huntington assets and Jim Davis utility costs;
communications with Kim Schlanger, Kevin Sadler.
07/07/09 K E Schlanger 2.00 Revised lease rejection memo; Email correspondence regarding
St. Croix rent payments; Email correspondence regarding
Miami personal property taxes; Email correspondence
regarding Spring Creek property taxes; Call with Herschel
Hamner regarding mortgage on 20 Casuarina Concourse; Email
correspondence regarding REDACTED
.
07/08/09 J A Cialone, II .80 Attention to real estate issues including appraisals.
07/08/09 K E Schlanger 1.90 Reviewed invoices for outside counsel relating to litigation;
Email correspondence regarding appraisals of Baldwyn
properties; Reviewed and revised lease rejection memo.
07/09/09 K E Schlanger 2.40 Revised memo regarding disposition of personal property and
settlement of landlord claims; Reviewed and discussed Kristie
Blumenschein's comments to CBRE agreements; Revised
CBRE listing and consulting agreements; Email
correspondence regarding REDACTED
; Email correspondence regarding REDACTED
; Email correspondence with Tim
Swearingen regarding letters to St. Croix tenants regarding rent
payments.
07/09/09 T R Swearingen .60 Reviewing documentation regarding delinquent tenants;
reviewing form letter for rent delinquencies.
07/09/09 R P Wright .30 Attention to emails regarding Huntington and St. Croix
matters.
07/10/09 K E Schlanger 4.80 Revised memo regarding disposition of personal property and
settlement of landlord claims; Reviewed and commented on
leased property matrix; Revised CBRE listing and consulting
agreements; Call with Brandon Clarke to discuss CBRE listing
agreement; Email correspondence regarding timing of sale of
owned properties.
07/10/09 R P Wright 1.00 Correspondence with Kristi Blumenschein, Charles Gordon,
Kim Schlanger regarding hold vs. sell issues.
07/13/09 K E Schlanger 3.90 Email correspondence regarding appraisals of Baldwyn
properties; Reviewed and revised CBRE Listing Agreement
and Consulting Agreement; Call with Kristian Nielsen at
CBRE to discuss REDACTED
;Reviewed motion
and proposed order for contempt with regard to Randi
Stanford; Email correspondence regarding REDACTED
269
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 203 of 377
Page 202
Hours Description
; Email correspondence with Anita
Baron and Cynthia Arnold regarding REDACTED
; Gathered information regarding operating costs of
owned properties for memo on disposition of owned real
property.
07/13/09 T R Swearingen 3.10 Attention to letters notifying tenants of failure to pay rent and
delinquency.
07/14/09 K E Schlanger 1.50 Call with Yasmin Atasi at Winstead regarding LNR/Wells
Fargo's objection to the real property sales motion; Follow up
correspondence regarding LNR's opposition; Responded to
Marisa Hurd's email regarding FBI document request; Email
correspondence with CBRE regarding Sugar Land hangar
offer; Gathered and reviewed information about operating costs
for owned properties.
07/15/09 K E Schlanger .50 Email correspondence regarding offer for Sugar Land hangar;
Email correspondence regarding property insurance premium
amounts.
07/16/09 K E Schlanger 2.50 Researched memo regarding timing of real property sales; Call
with Jeanette Day to discuss holding costs of real property.
07/16/09 R P Wright 1.00 Review email correspondence on intervention by 5050 lender,
sales of assets generally.
07/17/09 K E Schlanger 6.30 Drafted memo regarding disposition of owned real property;
Email correspondence with Kevin Sadler and David Arlington
regarding Wells Fargo motion in opposition of proposed real
property sale procedures; Reviewed Farmers & Merchants
Bank motion; Email correspondence regarding 5050
Westheimer operating costs; Email correspondence regarding
Sugar Land hangar offer; Call with Jim McCormick regarding
leased properties; Email correspondence with Kristian Nielsen
regarding CBRE listing/consulting agreements.
07/17/09 T R Swearingen 1.00 Attention to review of lease documents regarding default
provisions.
07/20/09 K E Schlanger 2.50 Read motion filed by Farmers & Merchants Bank and motion
filed by Wells Fargo in response to motion to approve real
property sale procedures; Email correspondence with David
Arlington regarding motions; Email correspondence with
Charlie Gale regarding Forefront building; Email
correspondence with Jason Baker and Jeanette Day regarding
settlement of Atlanta landlord's administrative claim.
07/21/09 K E Schlanger 3.20 Email correspondence with David Arlington and Eric
Soderlund regarding responses to F&M Bank and Wells Fargo
motions; Call with David Arlington and Eric Soderlund
270
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 204 of 377
Page 203
Hours Description
regarding F&M Bank and Wells Fargo motions; Drafted email
outlining proposed responses to F&M Bank and Wells Fargo
motions; Email correspondence regarding Hassell motion.
07/21/09 E A Soderlund .70 Conference call with K. Schlanger and D. Arlington regarding
formulating strategy and response to objections to real property
sales motion.
07/22/09 K E Schlanger 1.00 Revised real property sales memo; Call with Charles Gordon to
discuss real property sales memo; Email correspondence with
Steve Lindstrom regarding REDACTED .
07/23/09 K E Schlanger 1.30 Read motion regarding sale of Holt land; Call with Park Hill
regarding St. Kitts building and follow up regarding St. Kitts
building; Revised real property sales memo; Reviewed and
commented on revised exhibits to CBRE consulting and listing
agreements.
07/23/09 T R Swearingen 1.50 Multiple calls with Bruce Brandon regarding purchase of St.
Croix residence; calls with Kim Schlanger to discuss
REDACTED ; researching outstanding debt
payment secured by St. Croix residence.
07/23/09 R P Wright 1.00 Attention to foreign real estate sale requirements and telephone
conference with Richard Roper regarding same; attention to
James Holt petition to sell NC property and communications
with Craig Adams regarding same.
07/24/09 K E Schlanger .70 Email correspondence regarding extension for response to
Wells Fargo motion; Email correspondence with Bob Wright
regarding appendices to CBRE agreements; Email
correspondence regarding potential purchaser for 5050
Westheimer.
07/24/09 R P Wright 1.50 Attention to broker agreements; discussion of motions
regarding real estate; communications with Tony Davis, Kim
Schlanger; attention to real estate market memo.
07/27/09 K E Schlanger 2.00 Revised real property sales memorandum; Reviewed
documents for Baldwyn properties and compared them to
CBRE appendices; Call with Adrian Millan regarding Golden
Financial.
07/28/09 T M Davis .50 Meet with B. Wright and K. Schlanger regarding sale order.
07/28/09 K E Schlanger 3.70 Prepared for call regarding REDACTED
; Call with Tony Davis, Bob Wright and
Eric Soderlund to discuss REDACTED
; Drafted REDACTED
; Distributed real property sales memo;
Reviewed Miami landlord's calculation of administrative claim;
271
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 205 of 377
Page 204
Hours Description
Email correspondence with Miami landlord's attorney
regarding administrative claim; Email correspondence with
Charlie Gale regarding Forefront facility; Email
correspondence with Kristian Nielsen regarding parcel
numbers and addresses of Baldwyn properties; Coordinated
showing of Tupelo building.
07/28/09 E A Soderlund .70 Call with T. Davis, B. Wright, and K. Schlanger re:
REDACTED
.
07/28/09 R P Wright 1.20 Attention to emails of property inquiries; review motions and
other communications regarding real estate motions; office
conference with Tony Davis, Eric Soderlund, Kim Schlanger
regarding same.
07/29/09 K E Schlanger 1.70 Drafted and revised REDACTED
;
Revised CBRE consulting and listing agreements and
appendices; Email correspondence with Steve Lindstrom
regarding Huntington condo and appraisal of 5050
Westheimer.
07/29/09 R P Wright 2.00 Attention to stipulation for lien holders; provide comments to
Kim Schlanger regarding same; attention to email on other
motion-related matters; communications with Charles Gordon
regarding 5050 Westheimer appraisal.
07/30/09 K E Schlanger 4.30 Call with Yasmin Atasi regarding Wells Fargo motion; Call
with Chad Hammons regarding F&M Bank motion; Calls and
email correspondence with David Arlington and Andrew York
regarding stipulations; Revised CBRE listing and consulting
agreements; Email correspondence regarding appraisal of 5050
Westheimer; Email correspondence regarding hotel investment
of SVCH; Email correspondence regarding repairs in GSA
leased premises in St. Croix; Email correspondence regarding
signature pages to termination statements; Drafted real estate
task list.
07/30/09 R P Wright 1.20 Communications with Charles Gordon, Kim Schlanger;
attention to private equity issues and buyer inquiries.
07/31/09 K E Schlanger 2.70 Reviewed document regarding government acquisition of
Antiguan property; Prepared real estate action items list;
Coordinated extensions of deadlines for filing responses to
Wells Fargo and Farmers and Merchants motions; Reviewed
5050 Westheimer offer.
08/03/09 K E Schlanger 1.20 Revised and distributed real estate action items list; Email
correspondence regarding St. Croix residential property
insurance; Email correspondence regarding status of 5051
272
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 206 of 377
Page 205
Hours Description
landlord's lien claim.
08/03/09 K E Schlanger .50 Email correspondence with Kristian Nielsen regarding
REDACTED .
08/03/09 R P Wright .40 Communications with Ralph Janvey; Kim Schlanger; attention
to list of real estate action items.
08/04/09 K E Schlanger 1.60 Reviewed mortgage information for Baldwyn properties and
emailed information to Kristian Nielsen; Email correspondence
regarding REDACTED ; Email
correspondence regarding REDACTED ; Email
correspondence with Jeff Hollis regarding sale of trailers on
Mt. Recovery; Email regarding REDACTED
.
08/05/09 K E Schlanger 3.20 Drafted REDACTED ; Email
correspondence with Charlie Gale regarding REDACTED
; Email correspondence regarding insurance on Baldwyn
properties; Call with John Haynes regarding Forefront building
and insurance on Baldwyn properties; Email correspondence
regarding Sugar Land hangar.
08/06/09 K E Schlanger 1.00 Drafted letter agreement extending Dynamic Brands lease of
Forefront Building; Follow up with Kristie Blumenschein
regarding real estate action items list; Email correspondence
regarding Sugar Land hangar.
08/07/09 K E Schlanger .30 Call with Captain Jack LLC regarding Stanford assets.
08/07/09 T R Swearingen .40 Reviewing email from Bruce Brandon regarding St. Croix
residence.
08/10/09 K E Schlanger 2.20 Email correspondence regarding second Baldwyn theft and
insurance coverage; Email correspondence with Emily
Donahue regarding calculation of Miami landlord's
administrative claim; Email correspondence with Kristian
Nielsen regarding Baldwyn broker opinions of value and offer
for Forefront Building; Email correspondence regarding review
and approval of CBRE agreements; Revised and distributed
letters to delinquent St. Croix tenants; Email correspondence
with Andrew York regarding responses to F&M Bank and
Wells Fargo motions; Email correspondence regarding
potential purchaser of 5050 Westheimer.
08/11/09 K E Schlanger 2.00 Call with Charlie Gale regarding insurance for Davis
residences; Follow up with Linda Leal and Jeanette Day
regarding insurance of Davis' residence; Email correspondence
with Mercer Dye regarding St. Croix hangar; Follow up with
Winstead regarding proposed stipulation in response to Wells
Fargo's response to real property sales motion; Email
273
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 207 of 377
Page 206
Hours Description
correspondence regarding Randi Stanford eviction; Email
correspondence regarding offer for Forefront facility; Call with
Gerald Williams regarding Forefront facility; Email
correspondence with Kristian Nielsen regarding Baldwyn
BOV's.
08/11/09 R P Wright .60 Attention to MS property appraisals and insurance questions;
correspondence with Kristie Blumenschein.
08/12/09 K E Schlanger 2.00 Email correspondence regarding REDACTED
; Email correspondence with David Arlington and
Andrew York regarding REDACTED
; Email correspondence regarding Randi Stanford
contempt action; Email correspondence with Brent Boland
regarding Memphis landlord's administrative claim; Email
correspondence with Linda Leal regarding insurance of St.
Croix properties; Prepared list of current open real estate items.
08/12/09 T R Swearingen .30 Call with Bruce Brandon regarding purchase of St. Croix
residence.
08/13/09 K E Schlanger 2.00 Email correspondence with Linda Leal and Anita Baron
regarding insurance on St. Croix residential properties; Email
correspondence with Linda Leal regarding insurance on
Baldwyn residence; Prepared list of open real estate items.
08/13/09 R P Wright .50 Attention to insurance issues and review related
correspondence; attention to court responses; communications
with Sue Ayres, Sam Cooper regarding same.
08/14/09 R P Wright .40 Attention to real estate motions and list of outstanding items.
08/17/09 C N Adams .50 Researching property ownership issue; emails regarding same.
08/17/09 K E Schlanger 1.70 Email correspondence with Anita Baron and Linda Leal
regarding insurance for St. Croix residential properties; Email
correspondence with Jim Hamilton (Bank of Houston's lawyer)
regarding St. Croix insurance; Email correspondence with
Bruce Brandon regarding Chase McCarthy house; Follow-up
regarding information on St. Croix hangar; Email
correspondence with Chad Hammon regarding Farmer &
Merchants Bank collateral; Email correspondence regarding
Susan Stanford's house in Frisco; Email correspondence
regarding Memphis landlord's admin claim.
08/18/09 K E Schlanger 3.00 Follow up with Anita Baron regarding St. Croix residential
properties; Email correspondence with Jim Hamilton regarding
St. Croix residential properties; Email correspondence
regarding Susan Stanford's house in Frisco; Email
correspondence with David Arlington and Chad Hammons
regarding F&M Bank's's motion; Call with Michael Alphonse
274
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 208 of 377
Page 207
Hours Description
regarding delinquent rent; Email correspondence with Charlie
Gale regarding Hassell note; Office conference with Bob
Wright regarding general status and 5051 Westheimer;
Responded to inquiries from Craig Adams in preparation for
SEC/DOJ call; Email correspondence with Kristian Nielsen
regarding BOVs for Baldwyn properties.
08/18/09 R P Wright 1.20 Office conference with Kim Schlanger regarding 5051 claims
and general status of issues; telephone conference with Sam
Cooper re: 5051 claims.
08/19/09 K E Schlanger 1.20 Email correspondence with Craig Adams regarding owned real
properties for preparation for DOJ call; Call with Jim Hamilton
to discuss Bank of Houston mortgages on St. Croix properties;
Email correspondence with Linda Leal regarding St. Croix
property insurance; Email correspondence regarding offer for
St. Croix trailers; Email correspondence with Kristian Nielsen
regarding Baldwyn BOVs.
08/19/09 R P Wright .30 Attention to Sam Cooper Walton motion.
08/20/09 K E Schlanger 1.20 Call with Chad Hammons to discuss Farmers and Merchant
Bank's's opposition to real property sales motion; follow up
with Charlie Gale regarding insurance on stolen tractor.
08/20/09 R P Wright .50 Attention to St. Croix bank request to sell properties and
correspondence with Kim Schlanger regarding same;
correspondence with Tim Durst regarding Casuarina property.
08/21/09 K E Schlanger 1.00 Email correspondence with Kristie Blumenschein regarding
SIBL real estate assets; Email correspondence with Andrew
York regarding REDACTED ; Email correspondence
regarding settlement of Miami landlord's admin claim.
08/24/09 K E Schlanger 1.50 Follow up with Kristain Nielsen regarding Baldwyn broker
opinions of value; Email correspondence with Cynthia Arnold
regarding St. Croix maintenance issues; Call with St. Croix
tenant; Reviewed F&M Bank loan secured by stolen tractor;
Email correspondence regarding REDACTED
; Follow up with
Kristie Blumenschein regarding CBRE agreements.
08/24/09 R P Wright .30 Attention to Memphis settlement and other real estate matters.
08/25/09 C N Adams .90 Reviewing corporate records regarding Casuarina 20 LLC;
telephone conference with Gary Osborne regarding same.
08/25/09 K E Schlanger 1.60 Call with Cynthia Arnold and Anita Baron to discuss Royal
Strand issues; Coordinated payment of Memphis landlord's
administrative claim; Confirmed ownership of 20 Casuarina
Concourse LLC; Email correspondence with Anita Baron
275
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 209 of 377
Page 208
Hours Description
regarding St. Croix hangar; Reviewed Baldwyn BOVs; Call
with Andrew York to discuss REDACTED
.
08/25/09 R P Wright .70 Attention to inquiry regarding 20 Casaurina property; office
conference with Kim Schlanger; telephone conference Craig
Adams regarding same.
08/26/09 K E Schlanger .80 Reviewed Baldwyn BOVs; Call with Kristian Nielsen to
discuss Baldwyn BOVs.
08/27/09 K E Schlanger 1.10 Prepared chart of values of Baldwyn properties; Drafted email
regarding Baldwyn properties; Call with broker regarding 5050
Westheimer.
08/28/09 K E Schlanger .50 Email correspondence with Steve Lindstrom regarding
REDACTED ; Email correspondence regarding
REDACTED ; Responded
to question regarding Miami hangar.
08/31/09 K E Schlanger 1.50 Email correspondence with Anita Baron and Cynthia Arnold
regarding responses of St. Croix tenants to default notices;
Summarized proposal in response to F&M Bank's's motion;
Call with Larry Brewster regarding Stanford assets and follow
up.
Matter Total 368.60
079716.0115 Tax Matters
Hours Description
06/04/09 R A Husseini 1.20 Discussion with Elizabeth Johnson on path forward; analysis of
tax strategy.
06/05/09 J A Cialone, II .60 Calls and emails about REDACTED
.
06/05/09 R A Husseini .80 Attention to IRS Appeals tax strategy; discussion of issues with
team.
06/09/09 R A Husseini 1.30 Attention to tax strategy; discussion with Joe Cialone.
06/09/09 J J Wellington 2.90 Florida property tax issues; review of issue, obtain additional
information and recommendation for property tax protester
06/11/09 J A Cialone, II .80 Attention to IRS issues; related calls and emails.
06/11/09 R A Husseini .50 Attention to tax strategy issues.
06/15/09 R A Husseini .80 Attention to tax strategic issues; discussed same with Joe
Cialone.
276
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 210 of 377
Page 209
Hours Description
06/16/09 R A Husseini .30 Discussion with Elizabeth Johnson on CDP hearing.
06/24/09 R A Husseini .80 Attention to tax strategy.
06/26/09 R A Husseini 7.40 Preparation for IRS CDP; conversation with Appeals officer;
attention to tax strategy.
06/26/09 J B Nelsen 3.20 Reviewed and distributed CDP hearing related materials;
conference with Richard Husseini regarding the same.
06/27/09 R A Husseini 3.20 Preparation for CDP hearing.
06/27/09 J B Nelsen 3.90 Drafted notes regarding CDP issues and reviewed documents
relating to SIBL advances to affiliated entities.
06/28/09 R A Husseini 3.40 Preparation for CDP hearing.
06/28/09 J D Lobb 2.50 Reviewed tax litigation issues.
06/29/09 R A Husseini 7.80 Attention to CDP hearing.
06/29/09 J D Lobb 7.50 Discussed research issues with Jon Nelsen; reviewed
documents; collected relevant documents.
06/29/09 J B Nelsen 11.20 Researched and drafted memorandum regarding
characterization of SIBL advances.
06/30/09 R A Husseini 7.10 Preparation for CDP hearing.
06/30/09 M D Kusey 4.00 Revised index to binder "Stanford CDP Materials" per Jon
Lobb and Jon Nelsen; prepared documents for binding;
distributed the same.
06/30/09 J D Lobb 8.70 Reviewed documents; researched management fee issues.
06/30/09 J B Nelsen 8.10 Drafted memorandum regarding REDACTED
.
06/30/09 Z T Pullin 9.20 Compiled binder; researched SDC issue; began drafting memo
on same.
06/30/09 A M Stockbridge 7.00 Reviewed Harry Failing files.
07/01/09 R A Husseini 7.40 Preparation for CDP hearing; discussions with team; discussion
with Elizabeth Johnson; discussion with Larry Sherlock.
07/01/09 M D Kusey .80 Added documents to "Stanford CDP Materials" binders;
updated index for same.
07/01/09 J D Lobb 11.60 Researched management fee issues; began drafting
memorandum summarizing research.
07/01/09 J B Nelsen 9.80 Research and drafted memorandum regarding REDACTED
; conferences with Jon Lobb regarding management fee
issue in 2002 and 2003; conference with Richard Husseini
277
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 211 of 377
Page 210
Hours Description
regarding status of CDP hearing.
07/01/09 Z T Pullin 8.50 Continued researching issues, including facts and law.
07/01/09 A M Stockbridge 8.00 Reviewed Harry Failing files.
07/02/09 R A Husseini 5.80 Preparation for CDP hearing.
07/02/09 J D Lobb 4.70 Researched certificate of deposit issue.
07/02/09 J B Nelsen .60 Conferences with Jon Lobb and Richard Husseini regarding
status of the CDP hearing issues; reviewed memoranda form
Jon Lobb and Zackary Pullin regarding CDP hearing issues.
07/02/09 Z T Pullin 9.00 Finished memo on SDC issue; began reviewing accounting
files; began researching receivership filings.
07/02/09 A M Stockbridge 7.50 Reviewed Harry Failing files.
07/03/09 R A Husseini 2.10 Preparation for CDP hearing.
07/03/09 R A Husseini 4.60 Preparation for CDP hearing.
07/03/09 J B Nelsen 8.80 Researched and drafted memorandum analyzing
REDACTED
.
07/03/09 Z T Pullin 4.00 Reviewed receivership court filings; researched 482 issues.
07/04/09 J D Lobb 6.70 Researched certificate of deposit issue; began drafting
memorandum summarizing research.
07/04/09 J B Nelsen .50 Correspondence to Jon Lobb and Zack Pullin regarding appeals
submissions.
07/05/09 R A Husseini 4.70 Preparation for CDP hearing.
07/05/09 J B Nelsen 3.00 Researched and drafted memorandum analyzing
REDACTED
.
07/05/09 Z T Pullin 5.00 Updates binders; reviewed receivership filings; reviewed 482
issues.
07/06/09 R A Husseini 7.80 Preparation for CDP hearing.
07/06/09 J D Lobb 10.00 Researched certificate of deposit issue; drafted memorandum to
file summarizing research; updated binder of CDP materials;
reviewed IRS positions regarding tax penalties; began drafting
memorandum to file summarizing penalties issues.
07/06/09 J B Nelsen 7.90 Researched and drafted CDP submission regarding character of
advances from SIBL to SFGC; conferences with Job Lobb
regarding lien priority issue; drafted notes regarding the same.
278
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 212 of 377
Page 211
Hours Description
07/06/09 Z T Pullin 7.50 Updated binders; reviewed court filings; researched law on
interest income issue.
07/06/09 A M Stockbridge 7.40 Review Harry Failing files.
07/07/09 R A Husseini 7.20 Preparation for CDP hearing; meetings with team.
07/07/09 J D Lobb 8.10 Finished drafting memorandum regarding penalties issues;
reviewed IRS revenue procedure; began reviewing tax returns.
07/07/09 J B Nelsen 5.60 Drafted memorandum regarding lien priority issue; drafted
submission to CDP regarding characterization of advances
from SIBL to SFGC.
07/07/09 Z T Pullin 9.40 Reviewed boxes; researched 482 issues; researched Federal tax
lien issues; researched REDACTED .
07/07/09 A M Stockbridge 4.50 Review Harry Failing files.
07/08/09 R A Husseini 3.80 Preparation for CDP hearing.
07/08/09 J D Lobb 7.70 Reviewed tax returns; researched section 482 issues;
researched deduction issues.
07/08/09 J B Nelsen 3.00 Drafted submission for CDP hearing regarding characterization
of advances from SIBL to SFGC.
07/08/09 Z T Pullin 11.20 Continued research and drafting for REDACTED memo;
reviewed documents in Failing's boxes marked by Angela
Stockbridge; conference with various team members on
Stanford project.
07/09/09 R A Husseini 4.30 Prepared for IRS CDP hearing.
07/09/09 J D Lobb 9.30 Drafted submission regarding management fee issue; reviewed
revenue procedure; drafted email to Jon Nelsen summarizing
revenue procedure.
07/09/09 J B Nelsen 1.20 Drafted submission on characterization of advances from SIBL
to SFGC for CDP hearing.
07/09/09 Z T Pullin 10.50 Drafted memo on tax liens; drafted memo on CDP issue;
reviewed boxes.
07/10/09 R A Husseini 6.80 Attention to CDP hearing; preparation for same.
07/10/09 J D Lobb 4.20 Finished draft of CDP submission; continued reviewing
documents.
07/10/09 J B Nelsen .30 Conferences with Jon Lobb and Zack Pullin to discuss status of
reviewing files for CDP hearing.
07/10/09 Z T Pullin 8.20 Researched REDACTED in Texas; researched 482 issues;
finished REDACTED .
279
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 213 of 377
Page 212
Hours Description
07/11/09 R A Husseini 3.10 Preparation for CDP hearing; attention to submission on same.
07/12/09 R A Husseini 7.10 Preparation for CDP hearing; attention to submission on same.
07/12/09 Z T Pullin 1.00 Researched REDACTED .
07/13/09 R A Husseini 6.60 Attention to IRS CDP submission; discussion with Jon Nelsen
and Kevin Sadler on same.
07/13/09 J D Lobb 1.80 Researched entities to obtain tax information; created
organizational chart of Stanford entities.
07/13/09 J B Nelsen 9.30 Drafted CDP submission; conferences with Richard Husseini,
Kevin Sadler, and Job Lobb regarding the same.
07/13/09 Z T Pullin 7.80 Researched REDACTED
; researched
REDACTED ; revised memo on same.
07/14/09 R A Husseini 8.60 Preparation for CDP hearing; discussions with Kevin Sadler on
same.
07/14/09 J D Lobb 1.70 Reviewed CDP submission; discussed edits with Jon Nelsen.
07/14/09 J B Nelsen 4.20 Drafted CDP submission; conference with Richard Husseini
regarding the same.
07/14/09 Z T Pullin 7.20 Finished creating binders; sent IRS submission binder to be
bound; researched reverse piercing; researched other matters.
07/15/09 R A Husseini 5.10 Attention to CDP hearing; discussions with Kevin Sadler and
Manuel Lena on same.
07/15/09 J D Lobb 1.00 Reviewed IRS submission; discussed edits with Jon Nelsen.
07/15/09 J B Nelsen 6.80 Drafted CDP submission; conferences with Richard Husseini
and Kevin Sadler regarding the same; conference call with
Baker Botts attorneys, IRS attorneys, and DOJ attorney's's
regarding status of the case.
07/15/09 Z T Pullin 3.00 Researched REDACTED .
07/15/09 K M Sadler 1.80 Reviewed and revised draft brief on CDP issues; conferences
with Husseini regarding same; conference with counsel for IRS
and Husseini regarding CDP issues
07/16/09 R A Husseini 3.20 Finalized CDP submission.
07/16/09 J B Nelsen .70 Prepared CDP hearing submission; conference with Richard
Husseini regarding the same.
07/16/09 K M Sadler 1.00 Conference with IRS/DOJ regarding CDP; conference with
Husseini regarding strategy
07/17/09 R A Husseini 8.10 Preparation for CDP hearing; discussions with Kevin Sadler
and Manuel Lena relating to hearing.
280
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 214 of 377
Page 213
Hours Description
07/17/09 K M Sadler 1.00 Reviewed proposals from IRS/DOJ regarding CDP;
conferences with Husseini regarding strategy; reviewed emails
regarding documents requested by IRS/DOJ from FTI
07/18/09 R A Husseini 1.20 Attention to CDP hearing issues.
07/20/09 R A Husseini 1.20 Discussions with Manuel Lena, Kevin Sadler and Elizabeth
Johnson regarding postponed CDP hearing.
07/21/09 J B Nelsen .80 Reviewed and drafted email to Richard Husseini regarding
REDACTED
.
07/27/09 R A Husseini .30 Discussed tax issues with Tony Davis.
08/14/09 R A Husseini .20 Attention to Harry Failing issues.
08/17/09 R A Husseini .60 Attention to discovery issues related to income tax matters.
08/18/09 R A Husseini .40 Attention to discovery issues related to income tax matters.
08/21/09 R A Husseini 1.30 Developed tax summary for receiver report; attention to
discovery issues.
08/26/09 R A Husseini .30 Provided IRS position on tax treatment to investors to Craig
Adams.
Matter Total 459.60
079716.0116 Litigation - General
Hours Description
06/01/09 D T Arlington 2.60 Prepared motion to abate Gagosian Gallery lawsuit; telephone
conference with Kevin Sadler regarding REDACTED
; prepared email to Richard Roper regarding same;
prepared and finalized documents regarding REDACTED
06/01/09 T M Davis 2.00 Work on Bukrinsky response; read M. Lovett emails re process
and send emails re same; telephone conference with K.
Blumenschein re Bukrinsky response; read additional emails re
same; read TK comments.
06/01/09 K W Hinton 8.50 Reviewed cases and updated case statuses and deadlines in
chart; reviewed, edited motion, prepared, e-filed and drafted
email to court with courtesy copy of motion to abate, order and
appendix; met with S. Ayers regarding AmEx subpoena;
drafted subpoena and request for production to AmEx; met
with D. Arlington and A. York regarding stipulations; met with
V. Garcia regarding Stanford case background, tasks and
coverage; reviewed AmEx subpoena and exhibit and drafted
281
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 215 of 377
Page 214
Hours Description
email with service of same; calendared response for subpoena;
met with S. Ayers regarding pleadings and Stanford coverage;
coordinated coverage for cite checks; coordinated coverage for
pulling cases for brief.
06/01/09 S A Massad 2.00 Reviewed and commented on response to Bukrinsky motion;
various telephone conferences, office conferences and e-mail
correspondence regarding same and other issues.
06/01/09 D S Rohleder .60 Updated Filed Documents on the Shared Drive for the Stanford
Main Suit and Federal Cases related to Stanford;
06/01/09 K M Sadler 1.30 Reviewed pleadings and issues regarding Trustmark/Cisco/HP
V litigation; reviewed SPR issue
06/02/09 D T Arlington .50 Conference with Kevin Sadler regarding Dillon Gage/Gagosian
Gallery filings; reviewed materials relating to lead plaintiff
motion in Hernandez case
06/02/09 J A Cialone, II .40 Attention to clawback issues.
06/02/09 S W Cooper .30 Attended to issues regarding USVI suits.
06/02/09 K W Hinton 8.00 Met with L. Fluker, V. Garcia and E. Reeder regarding cite
checks; met with V. Garcia, D. Rohleder and S. Jampala
regarding Stanford case background, tasks and coverage;
prepared Affidavits and sent same to Nickens Keeton;
supervised and assisted with pulling cases; supervised and
assisted with citations in brief; quality-checked affidavits;
drafted letter to Nickens Keeton; reviewed DVDs, drafted letter
and sent DVDs to Preston-Jones; supervised and assisted with
records check; reviewed appeals record and discussed same
and deadlines with S. Ayers; call to Appeals clerk regarding
record and deadlines; met with S. Ayers regarding same;
drafted and exchanged emails with Appeals clerk; reviewed
Response to Examiner's Report and coordinated cite check.
06/02/09 S Jampala 6.30 Reviewed and updated federal and state cases and main suit;,
saved documents onto the share drive; worked and uploaded
necessary documents to the extranet; quality checked D.
Rohleder's work while I was out; fixed share drive as needed;
reviewed D. Rohleder boxes index for A. York's review.
06/02/09 R C Lewis 1.20 Received and reviewed updates on USVI pre-receiver matters;
analyzed files and drafted correspondence regarding proposed
action items related to same.
06/02/09 S A Massad .50 Reviewed various filings.
06/02/09 D S Rohleder 5.00 Updated the Response to Examiner's Report with appropriate
case law pinpoint references; Updated Stipulation Log;
Performed Records Check for the Response to Examiner's
282
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 216 of 377
Page 215
Hours Description
Report;
06/03/09 S W Cooper .80 Telephone conference with Kevin Sadler regarding Galleria
case; telephone conference with Sean Gorman regarding same.
06/03/09 T M Davis 2.70 Meeting with Receiver to discuss fraudulent transfer and relief
defendant matters.
06/03/09 R I Howell 5.50 Worked on REDACTED for Ch. 15 response.
06/03/09 S Jampala 3.00 Reviewed and updated federal and state cases and main suit;,
saved documents onto the share drive; uploaded necessary
documents to the extranet; quality checked D. Rohleder's index
for A. York.
06/03/09 D S Rohleder .50 Updated filed documents on the shared drive for all federal
cases relating to Stanford;
06/03/09 W F Stutts, Jr. .60 Reviewed with Mr. Sadler and Mr. Howell and others
REDACTED
; extended communications with Mr. Soderlund
and reviewed his information.
06/04/09 D T Arlington .90 Telephone conferences with Trustmark counsel regarding letter
of credit settlement issues; exchanged email with team and
counsel for Trustmark regarding same
06/04/09 S W Cooper .40 Attended to issues on Westridge stay; emailed with counsel for
Antigua receiver.
06/04/09 S Jampala 6.50 Reviewed and updated federal and state cases and main suit;,
uploaded necessary documents to the extranet; quality checked
extranet for any discrepancies; sent last six boxes indexed to A.
York for review; sent financial documents to the file per K.
Hinton's request; corresponded with V. Garcia about sending
documents to the file and saving documents to the shared drive.
06/04/09 V R Walker 4.00 Assembled and organized court papers, source materials and
correspondence.
06/05/09 D T Arlington .20 Reviewed correspondence from Trustmark regarding letters of
credit
06/05/09 S W Cooper .60 Attended to issues regarding FINRA subpoena in Morgan
Keegan matter; attended to response from plaintiffs in
Westridge matter; emailed with Jones Day attorney regarding
same.
06/05/09 R A Husseini .50 Attention to motion to compel.
06/05/09 D S Rohleder 1.00 Updated shared drive for documents in all relevant federal
cases;
283
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 217 of 377
Page 216
Hours Description
06/06/09 W F Stutts, Jr. 3.90 Worked on Janvey declaration for US Chapter 15 motion and
commentary on Vantis submissions.
06/07/09 J A Cialone, II 1.00 Reviewed and commented on FTI affidavit to be sued in
various proceedings.
06/07/09 R C Lewis 2.60 Reviewed new information on USVI claims; drafted and sent
correspondence to local counsel related to same; drafted
witness interview summaries.
06/07/09 W F Stutts, Jr. 2.40 Reviewed commentary on Vantis position; response on Chapter
15 memorandum; evidence in opposition; also commented on
Janvey affidavit.
06/08/09 S W Cooper .60 Attended to litigation issues regarding Stanford correspondence
and private equity approval process; call with FTI regarding
contingent liability approval process; office conference with
Russell Lewis regarding same.
06/08/09 R A Husseini .40 Attention to motion to compel.
06/08/09 S Jampala 2.30 Reviewed and updated federal and state cases and main suit;
uploaded necessary documents to the extranet; quality checked
shared drive; sent last seven boxes to A. York for review; sent
Financial documents to the file per K. Hinton's request.
06/08/09 W F Stutts, Jr. 2.10 Reviewed and commented on and provided information and
identified evidence regarding Chapter 15 REDACTED .
06/09/09 S W Cooper 1.20 Attended to issues regarding new foreclosure litigation in
Florida and trustee suit in Texas; attended to issues regarding
Galleria lawsuit assessment.
06/09/09 S Jampala 1.80 Reviewed and updated federal and state cases and main suit;
uploaded necessary documents to the extranet.
06/09/09 R C Lewis 2.60 Phone conference with Joel Holt, local counsel, regarding
USVI matters; reviewed information forwarded related to same
to provide recommendation on handling; drafted summaries of
same and circulated to team members; reviewed new
information related to Polk County foreclosure action;
conference with Sam Cooper regarding same.
06/09/09 S A Massad 1.30 Reviewed and commented on final drafts of brief and
declarations in response to Vantis.
06/10/09 S W Cooper .80 Worked on USVI issues; worked on Galleria lawsuit issues.
06/10/09 D S Rohleder 1.00 Updated Shared drive for documents relating the Stanford case;
06/11/09 D T Arlington 1.50 Worked on motion to abate in HP/Trustmark suit.
06/11/09 S W Cooper 2.40 Worked on issues regarding USVI lawsuits including King
284
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 218 of 377
Page 217
Hours Description
Cross Street and 55 King Street; office conference with Sean
Gorman on Galleria case; worked with Russell Lewis on filing
issues; reviewed SDC reply brief.
06/11/09 D S Rohleder 1.00 Updated Shared drive for documents relating the Stanford case;
06/12/09 D T Arlington 1.40 Finalized preparation of motions to abate Trustmark lawsuits;
communicated with opposing counsel regarding same
06/12/09 S W Cooper .60 Worked on issues regarding Galleria lawsuit.
06/12/09 R C Lewis 1.00 Phone call with local counsel regarding status of USVI matters;
drafted correspondence regarding same.
06/12/09 D S Rohleder 1.00 Updated Shared Drive with all filed documents relating to the
Stanford matter;
06/12/09 H C Tucker 1.90 Researched the ownership of Stanford Corporate Services
(Venezuela), C.A. for a memo.
06/15/09 S W Cooper .80 Reviewed and commented on Galleria lawsuit material;
telephone conference with Sean Gorman regarding same;
worked on stay for cases related to Westview suit.
06/15/09 D S Rohleder 1.30 Updated Shared Drive for all Relevant Cases Relating to
Stanford;
06/15/09 E A Soderlund .60 Review INX reclamation motion and assign R. DeLaune to
assist in research and drafting of response to same.
06/16/09 S W Cooper 1.10 Revised motion on Park Hill Group approval; attended to
issues regarding Coins and Bullion matter.
06/16/09 K W Hinton 9.50 Reviewed liens and drafted notice to Letsos Co.; reviewed
correspondence from T. McCarthy and drafted notice regarding
same; reviewed Complaint and drafted notice to Hillard and
Rogers; reviewed correspondence from T. Brown and drafted
notice regarding same; prepared and e-filed stipulation;
reviewed various emails regarding Stanford cases; supervised
and assisted with updating deadlines chart; assisted with
Sanchez notice; reviewed list of financial advisors and chart
with attorney information; drafted email to S. Ayers regarding
same; met with V. Garcia regarding coverage and Stanford
case status.
06/16/09 D S Rohleder 3.00 Added new cases to the Shared Drive in matters relating to the
Stanford case; Updated all files and documents on shared drive;
06/16/09 E A Soderlund 1.40 Review case law and other legal authorities concerning
REDACTED , confer with colleague regarding
REDACTED , and outline response to INX reclamation motion.
06/17/09 S W Cooper .30 Worked on issues regarding Galleria lawsuit.
285
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 219 of 377
Page 218
Hours Description
06/17/09 K W Hinton 9.50 Supervised and assisted with shared drive; drafted Motion to
Abate and Order for Westridge case; reviewed Motion to
Disqualify Baker Botts and related articles, forwarded same
article to S. Ayers; met with S. Ayers regarding serving relief
defendants in related case; researched form letter for financial
advisors without counsel; prepared and e-filed stipulations;
quality-checked shared drive and charts, drafted emails to D.
Rohleder regarding same; coordinated run to Travis Co.
regarding related cases, reviewed pleadings and drafted email
to S. Ayers regarding same; updated deadlines chart; reviewed
Ben Barnes production.
06/17/09 D S Rohleder 2.50 Updated Shared Drive with all relevant documents to cases
relating to Stanford; Added new cases to track to the Shared
Drive; Performed run to the Travis County Court House to
obtain documents pertaining to related Stanford cases;
06/17/09 E A Soderlund 6.70 Prepare draft of consolidate reply to multiple responses in
opposition to real property sale procedures motion.
06/18/09 D S Rohleder 5.00 Performed Records check for impending Motion; Pulled Case
law from Westlaw and saved to shared drive for K Hinton;
Check PACER and updated all documents on our shared drive
and extranet that were related to the Stanford matter; Assisted
Attny S Ayers with misc. projects relating to impending
Motion;
06/18/09 E A Soderlund 8.90 Prepare draft of consolidate reply to multiple responses in
opposition to real property sale procedures motion.
06/19/09 D S Rohleder 3.50 Performed a Records cite check for an impending Motion to be
filed; Checked PACER for all recently filed documents relating
to the Stanford matter and updated them on our system and the
extranet.;
06/19/09 E A Soderlund 1.90 Review cases regarding reclamation issues and direct R.
DeLaune in drafting response to INX motion for reclamation.
06/22/09 J A Cialone, II .70 Attention to affirmative action lawsuits; reviewed claims
possibilities related to brokers.
06/22/09 S W Cooper 1.40 Drafted memorandum regarding Galleria matter; telephone
conference with Sean Gorman regarding same.
06/22/09 K W Hinton 7.50 Supervised and assisted with shared drive; prepared documents
for certification and coordinated certification of same;
researched appellate record and met with S. Ayers regarding
same; updated tracking chart for stipulations; researched
stipulations filed under seal, met with D. Arlington regarding
same; reviewed, prepared and e-filed first supplemental
complaint against additional relief defendants; updated shared
286
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 220 of 377
Page 219
Hours Description
drive.
06/22/09 D S Rohleder 2.00 Updated Shared Drive for related cases;
06/22/09 E A Soderlund 2.20 Participate in conference call regarding numerous real estate
issues.
06/23/09 M E Burnett .30 Searched for broker and title company information in sale of
property at the request of Katherine Hinton.
06/23/09 J A Cialone, II .80 Reviewed Louisiana court papers and considered implications
of Louisiana activities.
06/23/09 S W Cooper .70 Telephone conference with Kevin Sadler regarding house sale
issue; telephone conference with Sue Ayers regarding same.
06/23/09 K W Hinton 8.80 Researched individual who received correspondence from,
regarding account holder; drafted email to S. Ayers regarding
findings on individual; drafted notice letter to individual;
reviewed liens and drafted notice to Letsos Co.; researched sale
of Beki Reeves house; obtained warranty deed and property
transaction history and met with S. Ayers regarding same;
researched appellate record; drafted subpoenas and request for
production to attorneys, seller and buyers involved with sale of
Beki Reeves home; assisted D. Arlington with pleadings.
06/23/09 D S Rohleder 2.50 Updated Shared Drive with all relevant filings related to the
Stanford case;
06/23/09 E A Soderlund 2.20 Review, revise, and edit draft of response to INX motion for
reclamation (2.2).
06/24/09 S W Cooper 1.40 Worked on Florida house sale issues; drafted letter to counsel
regarding same; reviewed material from Sue Ayers; attended to
disposition of BVI cases.
06/24/09 K W Hinton 9.80 Drafted email to R. Lewis and S. Cooper attaching Beki
Reeves home warranty deed and property transaction history;
reviewed Ben Barnes production; drafted emails to R. Lewis
and S. Cooper with 754 filing and Motions to Show Cause;
prepared and e-filed stipulations; researched correspondence
from Priovolos and provided same to R. Lewis; researched case
statuses and updated post-receiver case deadlines chart;
obtained filings in Harris Co.; drafted emails to S. Ayers with
updates on Ben Barnes production review.
06/24/09 D S Rohleder 2.50 Updated Shared Drive with all relevant filings related to the
Stanford case; Scanned selected documents for K Hinton
regarding Ben Barnes Production;
06/24/09 E A Soderlund 1.60 Work on draft of response to INX motion for reclamation and
direct R. DeLaune to revise same in accordance with my
287
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 221 of 377
Page 220
Hours Description
direction.
06/25/09 S W Cooper .70 Telephone conferences with counsel for Reeves-Stanford;
attended to issues regarding disposition of house proceeds.
06/25/09 K W Hinton 8.00 Assisted B. Howell with pleadings; reviewed Ben Barnes
production; drafted emails to S. Ayers with updates on Ben
Barnes production review; met with D. Arlington regarding
service of relief defendants; communicated with process server
regarding service of relief defendants; assisted D. Arlington
with pleadings; provided copies of all examiner report briefing
to team per the request of S. Ayers; communicated with S.
Ayers regarding Orders; reviewed, prepared and e-filed second
supplemental complaint against additional relief defendants;
prepared and e-filed stipulations.
06/25/09 R C Lewis 7.20 Drafted motion for emergency relief as to funds held by
Rebecca Reeves-Stanford; conference call with opposing
counsel regarding same; began drafting motion for sale of IOM
investment proceeds.
06/25/09 T M Moratto Jr. .50 Assisted with scanning and saving of B. Barnes Production
Documents for K. Hinton.
06/25/09 D S Rohleder 3.00 Updated Shared Drive with all relevant filings related to the
Stanford case; Scanned selected documents for K Hinton
regarding Ben Barnes Production;
06/25/09 E A Soderlund 3.10 Revise, edit, and distribute for comment response to INX
motion for reclamation (3.1).
06/26/09 S W Cooper .30 Telephone conference with counsel for Reeves-Stanford.
06/26/09 K W Hinton 6.30 Reviewed Ben Barnes production; drafted emails to S. Ayers
with updates on Ben Barnes production review; drafted
Summons for relief defendants; reviewed case information and
statuses and updated post-receiver tracking chart.
06/26/09 R C Lewis 2.40 Drafted motions to approve sales of IOM and Midway
interests; reviewed material in anticipation of same; prepared
for and participated in conference call with opposing counsel
regarding IOM deal.
06/26/09 D S Rohleder 2.00 Updated Shared Drive with all relevant filings related to the
Stanford case; Scanned selected documents for K Hinton
regarding Ben Barnes Production;
06/26/09 E A Soderlund .70 Revise and edit, and finalize for filing response to INX
reclamation motion (0.7).
06/29/09 S W Cooper 2.40 Telephone conference with Kevin Sadler on Galleria and
Florida house sales issues; telephone conference with counsel
288
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 222 of 377
Page 221
Hours Description
for Reeves-Stanford; reviewed correspondence and documents
regarding same; revised Galleria memorandum; attended to
D&O payment issue.
06/29/09 K W Hinton 5.50 Reviewed and finalized summons for relief defendants;
researched issuing summons electronically in Northern District
Texas; coordinated having summons issued with K. Scanlan;
researched stipulations filed under seal; call with A. York
regarding same; provided update to J. Fitzwater regarding
same; supervised and assisted with updating shared drive;
assisted S. Ayers with review of Ben Barnes production;
communicated with process server regarding service of
summons.
06/29/09 V R Walker 1.50 Assembled and organized court papers.
06/30/09 S W Cooper 1.10 Telephone conferences with Ben Krage regarding Galleria suit;
telephone conference with Sean Gorman regarding open issue;
attended to issue regarding Florida house sale.
06/30/09 T M Moratto Jr. 1.00 Assisted with case pull of Stanford's Receiver Response (6/30)
for E. Reeder.
06/30/09 D S Rohleder 2.30 Updated Shared Drive with all relevant filings related to the
Stanford case; Assisted with Case Pull for E Reeder;
06/30/09 V R Walker 4.50 Assembled and organized court papers.
07/01/09 M E Burnett .20 Provided copies of cases for Bill Stutts.
07/01/09 S W Cooper .30 Reviewed material on USVI lawsuits.
07/01/09 D S Rohleder 1.00 Updated Shared Drive with all relevant filings related to the
Stanford case;
07/02/09 S A D Ayers 1.00 Telephone conference with office of Michael Quilling
regarding proposed settlement and response due Monday;
reviewed motion to extend deadline and approved for filing;
reviewed letter offer of settlement.
07/02/09 M E Burnett 2.10 Searched for cases and case commentary for Bill Stutts.
07/02/09 S W Cooper .80 Attended to issues regarding proposed Walton counterclaims;
emailed with opposing counsel on Reeves-Stanford issues.
07/02/09 K W Hinton 3.50 Met with S. Ayers regarding case status, freeze order, account
releases and appeal; drafted Motion and Order for Extension of
Time; reviewed update from process server on service of
financial advisors and updated chart tracking same; call with
process server regarding service issues; drafted email with
update on service to D. Arlington.
07/02/09 D S Rohleder 1.00 Updated Shared Drive with all relevant filings related to the
289
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 223 of 377
Page 222
Hours Description
Stanford case;
07/03/09 D S Rohleder .60 Updated Shared Drive with all relevant filings related to the
Stanford case.
07/03/09 R K Shah 2.70 Communicated with Sue Ayers concerning jurisdiction
research project; reviewed and analyzed personal jurisdiction
cases sent by Sue Ayers; conducted preliminary research on
question of in rem jurisdiction.
REDACTED
07/04/09 R K Shah 3.70 Conducted research on question of
.
07/05/09 R K Shah 9.40 Communicated with Sue Ayers concerning additional research
questions related to receivership statutes and jurisdictional
requirements; reviewed cases sent by Matt Wood on SEC
receivership as it relates to jurisdiction; continued research to
REDACTED
.
07/06/09 K W Hinton 6.70 Supervised and assisted with updating shared drive; researched
tax courts and drafted email to D. Rohleder regarding same;
communicated with process server regarding service of relief
defendants; researched alternative addresses for relief
defendants; prepared and e-filed Notice of UK Judgment and
Appendix in Support; managed staff and projects and provided
instructions on same; drafted email to D. Arlington with
summary of service on relief defendants.
07/06/09 D S Rohleder 1.00 Updated Shared Drive with all relevant filings related to the
Stanford case;
07/06/09 R K Shah 8.40 Researched and wrote memorandum on REDACTED
; wrote additional section on REDACTED
.
07/07/09 M E Burnett .20 Searched for updated addresses for specified individuals at the
request of Katherine Hinton.
07/07/09 S W Cooper .40 Attended to issues regarding Galleria case.
07/07/09 K W Hinton 3.80 Drafted summons for Rocky Roys and coordinated issuing of
same with K. Scanlan; researched alternative addresses for
financial advisors; reviewed case and updated status chart;
drafted email to S. Ayers regarding same.
07/07/09 D S Rohleder 1.00 Updated Shared Drive with all relevant filings related to the
Stanford case;
290
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 224 of 377
Page 223
Hours Description
07/07/09 R K Shah 3.10 Made changes to memorandum on jurisdiction as requested by
Sue Ayers; read, analyzed and provided highlighted cases on
jurisdiction as requested by Sue Ayers.
07/08/09 S A D Ayers 2.00 For filing in chapter 15 action, edited motion regarding U.K.
judgment.
07/08/09 R C Lewis .40 Reviewed new material sent regarding Antigua cases.
07/08/09 T M Moratto Jr. .40 Per K. Hinton, assisted in the preparation of the summons.
07/08/09 D S Rohleder 1.10 Updated Shared Drive with all relevant filings related to the
Stanford case.
07/09/09 S W Cooper .10 Attended to insurance policy payment issues.
07/09/09 T M Moratto Jr. 1.30 Per K. Hinton, assisted with case law pull for shared drive and
use in cite checking (0.5); Per K. Hinton, assisted in
preparation of summons (0.3); Per K. Hinton, created 754
Notice list spreadsheet for review (0.5).
07/09/09 D S Rohleder 3.50 Updated Shared Drive with all relevant filings related to the
Stanford case; Consolidated exhibits for specific document for
in the Hamilton-Smith case for K Hinton;
07/10/09 S W Cooper .60 Attended to Coins & Bullion matter; attended to Stanford
Condominium Owners motion; office conference with Russell
Lewis regarding same.
07/10/09 T M Moratto Jr. 2.00 Updated 754 Notice list for K. Hinton.
07/10/09 D S Rohleder 2.00 Updated Shared Drive with all relevant filings related to the
Stanford case.
07/11/09 J A Cialone, II .40 Calls and emails about deposition subpoena and schedule.
07/12/09 J A Cialone, II .40 Continued calls and emails related to deposition strategies.
07/13/09 S A D Ayers 1.00 Drafted motion and order to dismiss Sanchez employment case
in NYC; edited motion to dismiss Adams class action in SD
Texas at request of plaintiffs' lawyer.
07/13/09 J A Cialone, II .40 Attention to new class action suit against Antigua and
considered consequences.
07/13/09 S W Cooper .50 Attended to employee lawsuit issues; attended to Galleria
lawsuit concerns.
07/13/09 K W Hinton 10.00 Managed and supervised staff regarding various projects;
reviewed zip code and federal district information and drafted
email to M. Wood regarding same; prepared documents to send
to process server; drafted letter and prepared CDs for Osler;
assisted attorneys with shared drive and pleadings; reviewed
documents from foreign proceedings and provided instructions
291
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 225 of 377
Page 224
Hours Description
to D. Rohleder regarding same; assisted M. Wood with 754
notice filings; supervised and assisted with redactions; met
with S. Ayers regarding Sanchez case and hearing; coordinated
assistance with Sanchez case in New York; researched case
filed against Antigua and provided Complaint to S. Ayers;
assisted with preparing Appendix to Motion to File
Supplemental Evidence; prepared, e-filed and drafted email to
clerk with Motion to Extend Time to Respond to Haddads and
Singapore Puntamitas Motions and Proposed Order; provided
list of districts to file additional 754 notices to S. Ayers and L.
Medrano; researched issue with 754 notice filing in New York.
07/13/09 D S Rohleder 3.00 Updated Shared Drive with all relevant filings related to the
Stanford case; Assisted Attny S Ayers with creation of
Appendix; Created new folders on Shared Drive for new cases
to track;
07/14/09 S A D Ayers .50 Attention to filing court paper to stay Sanchez case in NY.
07/14/09 S W Cooper .40 Reviewed new documents regarding Florida litigation; emailed
with Kevin Sadler regarding same; attended to issues regarding
Galleria case.
07/14/09 K W Hinton 7.60 Reviewed information of Southern District Texas website
regarding transcript orders, drafted letter, completed form and
submitted to court; reviewed minutes from hearing and call to
court regarding same; exchanged emails with attorneys
regarding bank subpoenas and assisted with same; drafted
subpoenas for banks; assisted M. Wood with 754 notice filings;
supervised and assisted with updating shared drive; met with S.
Ayers regarding foreign proceedings; coordinated with
attorneys regarding foreign proceedings, reviewed documents
and updated shared drive with same.
07/14/09 D S Rohleder 6.00 Created folder for the Criminal Case against Stanford, and
uploaded all filings to Shared Drive; Found information
regarding United States District Clerk of Courts for Attny M
Wood; Updated Shared Drive with all relevant filings related to
the Stanford case;
07/15/09 S W Cooper .30 Telephone conference with Sean Gorman; reviewed
correspondence on Florida house issue.
07/15/09 K W Hinton 6.00 Drafted emails and communicated with various counsel
regarding foreign proceeding filings; researched charges on
invoices and drafted emails to S. Ayers regarding same;
reviewed documents received from Osler; supervised and
provided instructions to D. Rohleder regarding foreign
proceeding documents; researched e-filing new complaint and
coordinated with S. Ayers and B. Martin regarding same;
292
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 226 of 377
Page 225
Hours Description
prepared civil cover sheet and certificate of interested persons
for new complaint; prepared Receiver's Motion to Appoint
Private Equity Advisor for e-filing.
07/15/09 D S Rohleder 5.50 Updated Shared Drive with all relevant filings related to the
Stanford case; Organized correspondence of emails and
documents from K Hinton onto Shared Drive for general access
of case relevant information
07/15/09 D S Rohleder 2.00 Updated Shared Drive with all relevant filings related to the
Stanford case; Organized correspondence of emails and
documents from K Hinton onto Shared Drive for general access
of case relevant information;
07/15/09 V R Walker 3.00 Assembled and organized court papers and correspondence.
07/16/09 S W Cooper .30 Telephone conference with Katherine Roland regarding mater;
reviewed draft motion on Florida house sale.
07/16/09 K W Hinton 2.60 Called clerk regarding issue with new complaint and issues
with filing; drafted email to S. Ayers and B. Martin regarding
corrections required to fix complaint; coordinated and
exchanged emails with T. Moratto regarding request for
Stanford arraignment hearing; call with court reporters
regarding hearing transcript request; reviewed foreign
proceedings and drafted emails to D. Rohleder with
instructions for same.
07/16/09 T M Moratto Jr. 1.00 Per K. Hinton, contacted Southern District of Texas Clerk's
office to inquire on transcript order for 6/25/2009 hearing
transcript.
07/16/09 D S Rohleder 3.50 Updated Shared Drive with all relevant filings related to the
Stanford case; Organized correspondence of emails and
documents from K Hinton onto Shared Drive for general access
of case relevant information
07/17/09 S W Cooper .80 Worked on Florida motion.
07/17/09 T M Davis .70 Review relief defendant drafts.
07/17/09 K W Hinton 7.10 Reviewed foreign proceedings and drafted emails to D.
Rohleder with instructions for same; coordinated with London
office regarding foreign proceeding filings.
07/17/09 D S Rohleder 9.00 Updated Shared Drive with all relevant filings related to the
Stanford case; Organized correspondence of emails and
documents from K Hinton onto Shared Drive for general access
of case relevant information.
07/20/09 H M Chappel .50 Reviewed list of Stanford Financial Advisors and compared it
to "Receiver's Complaint Naming Stanford Financial Group
293
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 227 of 377
Page 226
Hours Description
Advisors as Relief Defendants" per S. Ayers's request.
07/20/09 S W Cooper 3.30 Interviewed Richard LaMothe; office conference with Craig
Adams regarding same; worked on motion on Florida house
sale.
07/20/09 K W Hinton 8.80 Reviewed and prepared files for Janvey notebooks; coordinated
same with K. Scanlan; OCR'ed documents for Janvey CDs;
supervised and assisted T. Moratto with searches for Federal
Districts and updating chart for 754 notice filings; supervised
and managed staff on various projects; researched case
statuses; updated shared drive; reviewed correspondence and
drafted notice to Carter-Ruck.
07/20/09 R C Lewis 1.00 Reviewed new information regarding USVI claims;
correspondence with local counsel regarding same.
07/20/09 T M Moratto Jr. .50 Per K. Hinton, updated 754 Notice list for attorney review.
07/20/09 C W Rancher 7.00 Reviewed corporate minute books for indemnity provisions;
drafted summary memorandum; selected documents for Dallas
review.
07/20/09 D S Rohleder 5.50 Updated Shared Drive with all relevant filings related to the
Stanford case; Assisted Attny S Ayers with data collection
regarding pending lawsuits related to Stanford;
07/20/09 N M Starbuck .40 Provided R. Dougherty with incorporation documents for SFG
entities.
07/21/09 M E Burnett .40 Searched for contact information for Manuel Malvaez at the
request of Katherine Hinton.
07/21/09 J A Cialone, II .50 Worked on affirmative claims issues.
07/21/09 S W Cooper 1.10 Telephone conference with Kevin Sadler regarding interview
material; reviewed relevant material; worked on Florida issues.
07/21/09 T M Davis .90 Review relief defendant pleadings (.4); read and respond to
emails regarding same (.5).
07/21/09 K W Hinton 4.60 Reviewed and prepared files for Janvey notebooks; coordinated
same with K. Scanlan; ocr'ed documents for Janvey CDs;
attended to issues with service of summonses; drafted motion
for extension of time to respond and order; reviewed
documents received regarding UK matter and assisted D.
Rohleder with updating shared drive; prepared and e-filed
stipulations.
07/21/09 J C Huddleston 7.70 Attention to reproduction of Stanford corporate files at the
direction of Harrison Tucker and Client Rancher.
07/21/09 C W Rancher 10.30 Reviewed corporate minute books for indemnity provisions;
294
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 228 of 377
Page 227
Hours Description
drafted summary memorandum.
07/21/09 D S Rohleder 2.50 Updated Shared Drive with all relevant filings related to the
Stanford case;
07/21/09 R K Shah 2.70 Cleared conflict checks as requested by Brendan Day;
coordinated and communicated with several Partners to
determine if individuals and entities created a conflict of
interest.
07/21/09 N M Starbuck 1.50 At the request of C. Rancher provided R. Dougherty with SFG
entities Incorporation documents.
07/21/09 H C Tucker 7.80 Reviewed indemnification provisions within the charter
documents for all Stanford entities with records at the Houston
office.
07/22/09 S W Cooper 1.40 Office conference with Russell Lewis regarding USVI matter;
telephone conference to potential witness; reviewed and
responded to email on opposing counsel's filing; telephone
conference with Sean Gorman regarding Galleria matter;
telephone conference with David Gerger regarding Maricio
Alvarado.
07/22/09 T M Davis 1.70 Read additional briefing; telephone conferences with J. Cialone
and K. Sadler.
07/22/09 K W Hinton 6.80 Prepared and e-filed Midway Motion and Appendix and served
same; drafted Letsos motion and order; assisted B. Stutts with
pleadings; reviewed documents and researched letters and sent
example letters and documents to R. Lewis for notice to
parties; updated calendar reminders; researched issue with
videos sent to Canadian counsel and responded regarding
same; prepared and ocr'ed documents for Janvey.
07/22/09 R C Lewis 1.50 Reviewed new material regarding USVI claims; drafted letter
regarding same.
07/22/09 C W Rancher 8.50 Reviewed corporate minute books for indemnity provisions;
drafted summary memorandum.
07/22/09 D S Rohleder 1.00 Updated Shared Drive with all relevant filings related to the
Stanford case;
07/22/09 R K Shah 3.20 Continued conflicts checks as requested by Brendan Day;
continued following up with Partners from across the law firm
in order to check on conflicts related issues.
07/22/09 N M Starbuck 1.40 Processed SFG entities Incorporation documents for review by
C. Adams and R. Dougherty.
07/22/09 H C Tucker 9.10 Completed review of indemnification provisions; drafted a
295
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 229 of 377
Page 228
Hours Description
memo summarizing the various provisions.
07/23/09 H M Chappel .80 Compiled and prepared recently filed court documents in
preparation for attorney review.
07/23/09 S W Cooper 1.00 Worked on motion regarding Florida house sale.
07/23/09 K W Hinton 5.80 Drafted email to D. Arlington regarding counsel and service
issues with financial advisors; met with D. Arlington regarding
issues with amended complaint; managed and coordinated staff
for upcoming filings; reviewed and prepared files for Janvey
notebooks; coordinated same with K. Scanlan; ocr'ed
documents for Janvey CDs; researched issues with e-filing
amended complaint and drafted email to S. Ayers and D.
Arlington summarizing same.
07/23/09 R K Shah 1.80 Completed additional conflicts checks as requested by Brendan
Day; continued follow up.
07/24/09 M E Burnett .10 Searched for contact information for Manuel Malvaez for
Katherine Hinton.
07/24/09 H M Chappel .50 Compiled and prepared recently filed court documents in
preparation for attorney review.
07/24/09 S W Cooper .50 Reviewed and revised response to Condo Association motion.
07/24/09 K W Hinton 8.30 Met with D. Arlington regarding amended complaint and
motions; managed and coordinated staff for upcoming filings
and cite checks; reviewed motions and amended complaint;
supervised case pulls; reviewed pleadings and sent same
requested to D. Arlington; drafted motion for extension of time
and e-filed and served same; drafted email to counsel regarding
agreement on motion for extension of time; prepared appendix
for response; revised appendix; prepared and e-filed response
and appendix.
07/24/09 R C Lewis 3.40 Drafted and revised Receiver's Response to SCOA's Motion for
Hearing.
07/24/09 R K Shah 3.10 Continued conflicts checks as sent by Brendan Day; met with
David Arlington to discuss and clear additional conflicts;
followed up with various firm Partners to clear potential
conflicts; conducted additional searches to clear conflicts.
07/25/09 K W Hinton 1.00 Reviewed SEC evidence for email documentation, per the
request of B. Day.
07/25/09 R K Shah 2.40 Followed up with Brendan Day on conflicts checks; performed
and cleared additional conflicts checks by conducting searches
and contacting Partners to investigate potential conflicts of
interest.
296
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 230 of 377
Page 229
Hours Description
07/26/09 K W Hinton 9.30 Coordinated and assisted with cite check of motion to freeze;
pulled cases and cite-checked motion for summary proceedings
and amended complaint; record-checked both motions and
amended complaint; prepared appendices; communicated with
D. Arlington regarding Monday filings.
07/26/09 R K Shah 3.60 Completed additional conflicts checks as requested by Brendan
Day; followed up with various Partners and communicated
results of conflicts checks to Brendan Day.
07/27/09 M E Burnett 1.10 Searched for contact information for specified companies and
individuals.
07/27/09 S W Cooper 2.60 Worked on Florida motion; telephone conference with potential
witness's counsel; reviewed Galleria Walton filing.
07/27/09 K W Hinton 6.20 Coordinated and assisted with checking cite check changes and
additions to motion to freeze; checked and researched cite and
records check changes and additions to motion for summary
proceedings and amended complaint; prepared appendices;
reviewed redlines to motions and amended complaint;
communicated with D. Arlington regarding filings; researched
local rules and drafted emails to D. Arlington and B. Day
regarding same; researched means of service for defendants
and communicated with B. Day and D. Arlington regarding
same.
07/27/09 T M Moratto Jr. 1.80 Per K. Hinton:Created exhibit cover pages for Motion to
Freeze Assets filing. Prepared Appendices to Motion to Amend
Complaint and Motion for Order to Freeze.
07/27/09 R K Shah 1.40 Conducted final conflicts checks for Brendan day.
07/27/09 R K Shah 7.80 Conducted emergency research for Kevin Sadler and David
Arlington regarding REDACTED
; reviewed and analyzed motions and
memorandum we prepared regarding disgorgement and relief
defendants; researched all US case law REDACTED
; prepared brief memorandum
analyzing law on disgorgement and receivership for review by
Kevin Sadler and David Arlington.
07/27/09 V R Walker 3.00 Assembled and organized court papers.
07/28/09 M E Burnett 1.20 Searched for contact information for specified companies and
individuals for Brendan Day.
07/28/09 H M Chappel 3.50 Compiled and prepared list of names of all Financial Advisors
per B. Day's request.
297
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 231 of 377
Page 230
Hours Description
07/28/09 S W Cooper 1.80 Finalized response to condo association motion for filing;
attended to issues raised by Polk County case; office
conference with Russell Lewis regarding same.
07/28/09 K W Hinton 10.10 Checked cite and records check changes and additions to
motions and amended complaint; prepared appendices;
reviewed redlines to motions and amended complaint; assisted
attorneys with review of motions and amended complaint;
revised motions and amended complaint; reviewed table of
authorities and table of contents, compared to motion to freeze
and revised same; prepared documents for filing; coordinated
with K. Scanlan notebooks for court; called court regarding
filings; drafted emails to clerk with orders and courtesy copies
of filings; e-filed freeze motion, orders and appendices; e-filed
Letsos motion, orders and appendices; reviewed amended
complaint and compared to information on attorneys for
account holders and updated spreadsheet; prepared and e-filed.
07/28/09 R C Lewis 2.90 Reviewed new information regarding claims in USVI and other
Caribbean jurisdictions; received and reviewed new
information regarding Polk County foreclosure proceeding;
conference with Sam Cooper regarding same; phone call with
plaintiffs' counsel regarding status of foreclosure proceeding
and default judgment; drafted correspondence regarding same.
07/28/09 D S Rohleder 1.00 Updated the Shared Drive for all relevant documents related to
the Stanford Case;
07/28/09 V R Walker 2.00 Assembled and organized court papers.
07/29/09 M E Burnett 1.30 Searched for contact information for list of specified
companies and individuals.
07/29/09 S W Cooper .40 Telephone conference with Sean Gorman; telephone call to Jim
Mutchnik on Galleria case; telephone conference with Bob
Wright regarding matter.
07/29/09 K W Hinton 11.30 Coordinated and communicated regarding service of relief
defendants; supervised and assisted D. Rohleder with updating
chart with attorney information for financial advisors;
communicated with B. Day regarding call from U.S. Marshalls;
communicated with attorneys regarding amended complaint,
summonses and service issues; updated notice letter to Carter-
Ruck and drafted email with service of same and AOR;
supervised and assisted D. Rohleder with preparing notebooks
for hearing and case law; reviewed same; updated summons
and addresses chart for service of amended complaint and
motions; reviewed joint motion for release of coins and bullion
and revised formatting and form for citations; prepared
appendix for same motion; reviewed stipulations and updated
298
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 232 of 377
Page 231
Hours Description
summons and addresses chart for service to same; prepared and
e-filed joint motion for release of coins and bullion and
appendix and served same.
07/29/09 D S Rohleder 1.00 Updated Shared Drive with relevant documents relating to the
Stanford case;
07/30/09 S W Cooper .80 Attended to issues regarding MDL filing; telephone conference
with CSC regarding service issues; telephone conference with
Ben Krage.
07/30/09 K W Hinton 9.30 Created index for case law notebook; revised index and
updated notebooks per the request of K. Sadler; supervised and
assisted T. Moratto with searches for Federal Districts and
updating chart for 754 notice filings; drafted emails with
service of amended complaint and motions to SEI and
Pershing; assisted M. Myers with inquiries regarding proof of
service; created list of attorneys to serve and provided same to
B. Day; supervised and assisted D. Rohleder with creating
chart for service of KVT-6 people/entities; coordinated
personal service of KVT-6; reviewed and quality-checked list
of new federal districts; communicated with M. Wood
regarding same; assisted attorneys with preparing for hearing
and coordinated same with K. Scanlan; drafted email to process
server with summons, documents and instructions for service
of same; created document for service by email.
07/30/09 T M Moratto Jr. 2.80 Per K. Hinton, Updated 754 Notice list with Relief Defendant's
tab.
07/31/09 S W Cooper 1.40 Telephone conference with James Mutchnik; telephone
conference with Sean Gorman; worked on issues regarding
Polk County case; reviewed MDL petition and related
materials.
07/31/09 K W Hinton 8.50 Created document for service by email; checked parties for
email service to those named in complaint; quality-checked list
for email service; checked email contact information in
attorney notes chart and compared same to list of defendants,
email list and updated email list with any named defendants not
listed; quality-checked same; researched issues with email
service; communicated with B. Day regarding service issues;
revised bank subpoenas and sent same to A. York; updated
chart regarding service of named relief defendants; prepared
and e-filed unopposed motions to extend deadline; reviewed
charts and provided requested information to D. Arlington
regarding stats on service; communicated with B. Day
regarding same.
07/31/09 R C Lewis 2.40 Drafted correspondence to counsel in foreclosure action
299
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 233 of 377
Page 232
Hours Description
regarding default judgment; phone call regarding same;
reviewed additional information regarding claims pending in
USVI.
08/03/09 M E Burnett .30 Searched for contact information for James Fontenot at the
request of Katherine Hinton.
08/03/09 S W Cooper 1.40 Attended to MDL and Galleria suit issues; telephone
conference with David Isaak; reviewed insurance material.
08/03/09 D S Rohleder 1.80 Updated Shared Drive for all relevant documents regarding the
Stanford Case; Pulled Case Law onto Shared Drive for K
Hinton;
08/04/09 S W Cooper 3.40 Worked on response to Galleria intervention motion; worked
on issues regarding Florida house sale; telephone conference
with Kevin Sadler on Galleria witness issues; reviewed
material on setting aside Florida judgment.
08/04/09 R C Lewis .40 Reviewed Motion to Vacate Default Judgment in Polk County,
Florida case; phone call with counsel for Resorts Construction
regarding same.
08/04/09 D S Rohleder 1.00 Updated Shared Drive for all relevant documents regarding the
Stanford case;
08/05/09 M E Burnett 1.30 Searched for contact information for list of specified
individuals and companies at the request of Katherine Hinton.
08/05/09 S W Cooper 1.80 Worked on REDACTED worked on REDACTED .
08/05/09 K W Hinton 5.00 Reviewed addresses and research and met with M. Burnett
regarding research for alternative addresses for service of
amended complaint; communicated with B. Day regarding
reviewed production from Hunton Williams; coordinated
REDACTED
and communicated with IT and lit support regarding
REDACTED researched and assisted
attorneys with REDACTED updated charts
regarding service.
08/05/09 D S Rohleder 1.50 Updated Shared drive for all relevant documents relating to the
Stanford matter;
08/05/09 R K Shah 2.70 Prepared final conflicts reports on several hundred individuals
as requested by Brendan Day.
08/05/09 V R Walker 3.50 Assembled and organized court papers and correspondence.
08/06/09 M E Burnett .20 Searched for contact information for Manuel Malvaez at the
request of Katherine Hinton.
08/06/09 H M Chappel .50 Compiled and prepared recently filed court documents in
preparation for attorney review.
300
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 234 of 377
Page 233
Hours Description
08/06/09 S W Cooper 2.20 Reviewed new discovery in Galleria matter; worked on
REDACTED attended to REDACTED
telephone conference with CSC regarding
REDACTED
08/06/09 K L Gaskamp 3.00 Organized materials relating to pending litigation and
conference with Sam Cooper regarding received
REDACTED
correspondence regarding West Villas foreclosure matter;
researched status of motion to REDACTED
08/06/09 K W Hinton 5.70 Researched issues with service and exchanged emails with B.
Day regarding researched and assisted with service of
REDACTED
appeal documents; prepared and e-filed appeal notices; called
court regarding appeal procedures; reviewed northern district
website regarding appeal procedures; communicated with D.
Arlington regarding reviewed instructions for transcript
REDACTED
order and coordinated same; researched service of Barnes
subpoena and drafted email to A. York with REDACTED
08/06/09 D S Rohleder .50 Updated Shared drive for all relevant documents relating to the
Stanford matter;
08/07/09 S W Cooper 1.30 Worked on REDACTED worked on REDACTED
08/07/09 K L Gaskamp 6.30 Prepared exhibits in support of Receiver's motion for order to
show cause why Reeves-Stanford, Melida Viera, and John
Priovolos should not be held in contempt.
08/07/09 K W Hinton 8.00 Researched rules regarding proof of service and drafted email
to B. Day regarding coordinated and communicated with
REDACTED
C. Sapp and A. York regarding REDACTED
; researched certificate of service for appeals and
drafted same for Letsos and Alguire appeals; reviewed docket
and pleadings and updated deadlines chart; assisted M. Scott
with unredacted invoices; coordinated and communicated
regarding cite check.
08/07/09 D S Rohleder 1.00 Updated Shared drive for all relevant documents relating to the
Stanford matter;
08/10/09 S W Cooper .80 Worked on REDACTED related to REDACTED
;
worked on REDACTED
08/10/09 K L Gaskamp 4.30 Cite checked brief in support of Reeves motion; prepared
exhibits for filing with the Court; prepared motions calendar.
08/10/09 D S Rohleder 1.00 Updated the Shared Drive for all relevant filings related to the
Stanford Matter;
301
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 235 of 377
Page 234
Hours Description
08/10/09 R K Shah .30 Assisted Brendan Day in locating relevant cases for broker
dealer clawback research.
08/11/09 S W Cooper 1.50 Worked on REDACTED
; drafted stipulation for
extension of time to respond.
08/11/09 L A Kujawski 1.30 Research REDACTED
08/11/09 D S Rohleder 1.60 Updated the Shared Drive for all relevant filings related to the
Stanford Matter; Obtained DM#'s for select Baker Botts filings
for Attny B Day.
08/12/09 S W Cooper 3.50 Worked on finalizing Reeves motion; worked on issues
regarding REDACTED ; worked on issues
regarding REDACTED
08/12/09 K L Gaskamp 1.50 Researched REDACTED
REDACTED
; prepared motions deadline
chart.
08/12/09 L A Kujawski 2.30 Research REDACTED
08/12/09 D S Rohleder 1.80 Updated the Shared Drive for all relevant documents relating to
the Stanford Case; Saved Correspondence emails sent from K
Hinton to the Shared Drive in matters relating to the English
Case.
08/13/09 S W Cooper 7.20 Drafted email to consult on Rebecca Reeves motion; telephone
conference with David Reece regarding same; emailed and
telephone conference with Melida Viera regarding motion;
emails and telephone conferences with counsel for Reeves
regarding motion; emails and telephone conferences with
counsel for Priovolos regarding motion; prepared for and
participated in REDACTED ; drafted
REDACTED ; reviewed REDACTED
; attended
to follow-up on Reeves issues.
08/13/09 K L Gaskamp 3.50 Prepared exhibits to Receiver's motion to show cause; drafted
Sam Cooper's declaration to same.
08/13/09 D S Rohleder 1.50 Updated the Shared Drive for all relevant documents relating to
the Stanford Case; Saved Correspondence emails sent from K
Hinton to the Shared Drive in matters relating to the English
Case.
08/14/09 S W Cooper 5.70 Telephone conference with Joan Schwartz at Pershing; worked
on REDACTED ; telephone conference with Ben
Krage regarding REDACTED telephone conference with
Kevin Sadler; emailed with Rebecca Stanford's counsel;
reviewed material from Melida Viera.
302
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 236 of 377
Page 235
Hours Description
08/14/09 K L Gaskamp .10 Received and reviewed representation letter from counsel for
John Priovolos.
08/14/09 D S Rohleder 2.00 Updated the Shared Drive for all relevant documents relating to
the Stanford Case; Redacted and Bates Numbered Appendix
for pending Motion for K Hinton; Saved Correspondence
emails sent from K. Hinton to the Shared Drive in matters
relating to the English Case.
08/15/09 S W Cooper 2.50 Worked on REDACTED
08/15/09 R K Shah 7.70 Researched question for Bill Stutts regarding REDACTED
08/16/09 R K Shah 1.60 Researched
REDACTED
, at request of Bill Stutts; communicated with Bill Stutts
regarding
08/17/09 S W Cooper 3.40 Worked on REDACTED ; correspondence with Melida Viera
regarding REDACTED ; worked on REDACTED
; telephone conference with John Lawrence on REDACTED
08/17/09 L A Kujawski 1.60 Draft insert regarding REDACTED ; correspond with S.
Cooper regarding REDACTED
08/17/09 D S Rohleder 2.40 Updated Shared Drive with all relevant Documents from cases
relating to the Stanford Matter; Applied Bates Labels for
pending Motion for K Hinton; Added new Cases to the Case
Lists and created folders for them on the Stanford Janvey
shared drive and Extranet.
08/17/09 V R Walker 3.00 Assembled and organized court papers and correspondence.
08/18/09 H M Chappel .50 Reviewed all tasks associated with compiling and preparing
recently filed court documents in preparation for attorney
review.
08/18/09 S W Cooper 2.70 Worked on REDACTED
; reviewed Walton letter
on purported privilege waiver; telephone conference with Chris
Lacy regarding same; correspondence with counsel for
Rebecca Stanford; finalized REDACTED .
08/18/09 M D Kusey 1.30 Researched and obtained copy of "Subpoena for Production of
Documents regarding "ADT Security Services S.A. de C.V. v.
Albert 24 Security, LLC et al from Receiver's correspondence
file and sent the same to Sue Ayers, Craig Adams and Kevin
Sadler.
08/18/09 D S Rohleder 1.00 Updated Shared Drive for all relevant documents related to
303
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 237 of 377
Page 236
Hours Description
Stanford case and similar cases; Applied bates labels to
Appendix for K Hinton.
08/18/09 V R Walker 3.00 Assembled and organized court papers and correspondence.
08/19/09 S W Cooper 2.90 Drafted court paper on REDACTED ; telephone
conference with Sean Gorman and David Berg on REDACTED ;
emailed with Ben Krage regarding ; emailed with
REDACTED
Walton attorneys on various issues; reviewed REDACTED
08/19/09 K L Gaskamp .10 Received order granting extension in Galleria matter; revised
pending motions calendar.
08/19/09 K W Hinton 7.80 Researched attorney information and drafted email to B. Day
regarding same; met with L. Dodge regarding financial advisor
documentation and supplemental complaint; researched and
assisted with representation questions per S. Ayers request;
researched appeal docket and assisted S. Ayers with same; met
with S. Ayers regarding REDACTED
reviewed dockets for 721, 724 and 1329 cases and created
deadlines chart; reviewed case statuses in post-receiver
litigation and updated deadlines chart.
08/19/09 M D Kusey .30 Organized the Receiver's correspondence storage area.
08/19/09 D S Rohleder 1.00 Updated Shared Drive for all relevant documents related to
Stanford case and similar cases.
08/20/09 S W Cooper 2.50 Telephone conference with Ralph Janvey and Ben Krage on
REDACTED ; worked on REDACTED ;
telephone conference with Chris Lacy regarding REDACTED
08/20/09 K W Hinton 8.80 Reviewed deadlines chart, revised and created new chart for
past due and moot briefing; researched who to address letter
regarding supplementing appeal records; drafted letter to clerk
regarding supplementing appeal records, revised same per the
request of S. Ayers; researched and assisted J. Knight with
appeal pleadings; assisted with inquiries regarding service;
created combined service and attorney information list;
prepared and e-filed pleadings; supervised and assisted with
updating shared drive; researched and assisted with questions
regarding information on financial advisors and original
complaint against relief defendants; exchanged emails
regarding deadlines tracking.
08/20/09 M D Kusey 3.50 Cite checked for Sam Cooper; office conference with
REDACTED
Sheila Bickel regarding REDACTED
08/20/09 R C Lewis .40 Reviewed new correspondence regarding REDACTED
reviewed background materials regarding REDACTED
304
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 238 of 377
Page 237
Hours Description
08/20/09 D S Rohleder 2.00 Updated Shared Drive for all relevant documents related to
Stanford case and similar cases.
08/21/09 S W Cooper 3.50 Revised and finalized REDACTED ; reviewed
REDACTED attended to REDACTED ;
emailed with attorney for John Priovolos.
08/21/09 K L Gaskamp 2.00 Received and reviewed correspondence regarding
REDACTED
; revised pending deadlines calendar; drafted
REDACTED assisted in
preparation of REDACTED
08/21/09 K W Hinton 6.50 Assisted with and coordinated preparation of IRS production;
drafted letter to N. Graml and coordinated service of
production; updated deadlines chart, pending motions ripe for
consideration and no responses chart; reviewed table of
contents and table of authorities and revised REDACTED
prepared and e-filed response and appendix;
created deadlines chart for related cases; drafted email to
attorneys with REDACTED
08/21/09 J B Lawrence 4.40 Research and REDACTED
08/21/09 D S Rohleder 2.00 Updated Shared Drive for all relevant information regarding
the related Stanford Cases; Organized and added select
documents to the Shared Drive for Attny S Ayers and K
Hinton;
08/24/09 S W Cooper 2.20 Worked on REDACTED
; reviewed
REDACTED
; reviewed REDACTED ; reviewed
REDACTED
08/24/09 K L Gaskamp .20 Updated Stanford matters pending deadlines calendar.
08/24/09 K W Hinton 6.00 Updated service charts; updated deadlines chart, pending
motions ripe for consideration and no responses chart;
coordinated and communicated with process server regarding
service of financial advisors; assisted B. Day with service
issues; researched new case in Harris Co. and communicated
with A. York regarding communicated with attorneys
REDACTED
and L. Dodge regarding REDACTED
08/24/09 D S Rohleder 1.20 Updates Shared Drive for all relevant case information
regarding the Stanford Matter;
08/25/09 S W Cooper 4.80 Reviewed filings by John Priovolos; worked on REDACTED
; telephone conference with Sean Gorman and
David Berg; reviewed REDACTED ; worked on REDACTED
305
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 239 of 377
Page 238
Hours Description
08/25/09 D S Rohleder 2.50 Updates the Shared Drive for all relevant documents relating to
the Stanford Matter; Pulled Case Law for K Hinton;
08/26/09 S W Cooper 2.90 Worked on REDACTED ; worked on REDACTED
reviewed REDACTED ; telephone conference with Sean
Gorman; attended to REDACTED .
08/26/09 K W Hinton 5.80 Researched REDACTED and drafted email to K. Sadler
regarding supervised and assisted with updating shared
REDACTED
drive; coordinated with L. Dodge regarding service;
coordinated with process server regarding service; reviewed
and reconciled missing documents from appellate record;
drafted email to S. Ayers regarding same; prepared and e-filed
Supplemental Complaint, Appendix and Response to Motion to
Modify Order; coordinated with B. Day regarding filings and
service; updated deadlines chart; coordinated with Dallas
regarding appeal record.
08/26/09 M D Kusey .80 Printed correspondence log; cross-referenced logged
correspondence to corresponding storage boxes.
08/26/09 D S Rohleder 3.30 Updated Shared Drive for all relevant filings regarding related
Cases in the Stanford Matter;
08/27/09 S W Cooper 2.00 Worked on issues regarding REDACTED ; worked on
issues regarding REDACTED
08/27/09 K L Gaskamp .20 Researched status of order on motion to set aside default in
West Villa foreclosure matter.
08/27/09 D S Rohleder 1.00 Updated Shared Drive for all Relevant Documents relating to
the Stanford Matter;
08/28/09 S W Cooper 1.60 Attended to issues regarding REDACTED ; reviewed
correspondence from Walton on Galleria case; finalized
REDACTED
; finalized REDACTED ; attended to
REDACTED ; attended to REDACTED
08/28/09 K L Gaskamp .40 Provided Walton's discovery requests in Galleria matter to Sam
Cooper; received Pershing LLC's notice of removal.
08/28/09 D S Rohleder 1.20 Updated Shared Drive for all Relevant Documents relating to
the Stanford Matter; Corrected and Organized Select
Documents on the Shared Drive for Attny Sue Ayers;
08/29/09 S W Cooper .30 Reviewed REDACTED .
REDACTED
08/31/09 S W Cooper 2.10 Reviewed filing on ;
telephone conference with Kevin Sadler on REDACTED ;
finalized REDACTED ; reviewed REDACTED
306
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 240 of 377
Page 239
Hours Description
08/31/09 K L Gaskamp 1.70 Obtained certified copies of criminal records in James Davis
criminal matter; researched obtaining arraignment hearing
transcript.
08/31/09 K W Hinton 4.00 Call with process server regarding asap service; prepared
documents and drafted email to process server regarding
instructions for service; call with process server regarding
service issue; revised service list for supplemental complaint;
updated SEC v. Stanford tracking and deadlines charts;
prepared and e-filed Reply to Joint Coins and Bullion Motion.
08/31/09 D S Rohleder 1.20 Updated the Shared Drive for Relevant Cases regarding the
Stanford Matter;
Matter Total 835.70
079716.0117 Litigation - SEC vs. SIB, et al
Hours Description
06/01/09 D T Arlington 1.10 Exchanged email with team regarding REDACTED
06/01/09 S A D Ayers 6.00 Telephone conference with Pershing regarding Louisiana law
suit; telephone conference with American Express regarding
corporate accounts; conducted research and drafted
REDACTED telephone
conference with Virgin Islands lawyer regarding liens and
claims made on behalf of his clients; reviewed daily court
filings.
06/01/09 S A D Ayers 5.00 Antiguan Liquidators: conducted research and drafted
REDACTED
06/01/09 T S Durst 1.30 Follow-up on REDACTED ; attention to communications
REDACTED
with opposing counsel and team regarding pending items;
attention to REDACTED
06/01/09 J S Fitzwater 3.80 Assisting Eric Soderlund to REDACTED
;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Pleadings Pad; updating the searchable text of
filings entered on the Extranet; updating support files for the
litigation team.
06/01/09 L C Fluker 1.90 Downloaded email communications to update correspondence
file and organized hard copies of correspondence to update
correspondence file; updated Excel tracking chart with
307
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 241 of 377
Page 240
Hours Description
information on recent communications; conferred with
Katharine Hinton regarding availability to cite check upcoming
filings.
06/01/09 K M Sadler 5.80 Reviewed and revised REDACTED ;
reviewed and revised REDACTED ; reviewed issues
regarding REDACTED ; reviewed REDACTED
; revised cases regarding
REDACTED ; reviewed issues
regarding REDACTED conference with D. Reece of
SEC regarding Bukrinsky response
06/01/09 K Scanlan 4.50 Numerous arrangements and coordination for Houston and
Austin staff to attend meetings and preparation sessions; assist
in preparing response to intervention for filing, assist in filing
response.
06/01/09 E A Soderlund 8.00 Revise, finalize, prepare for filing, and direct K. Scanlan to file
electronically and serve the Receiver's response to the
Bukrinsky motion to intervene to file involuntary bankruptcy
petition.
06/01/09 W F Stutts, Jr. .90 Commented on REDACTED
addressed
REDACTED
from Ms. Blumenschein.
06/01/09 M C Wood 3.00 Compiled cases for UK counsel in preparation of REDACTED
; Researched REDACTED
Drafted REDACTED
06/01/09 R H Wood 11.60 Corresponded with Matt Wood, Sue Ayers, and Kevin Sadler;
performed research regarding REDACTED
researched
REDACTED
researched
REDACTED
researched REDACTED
06/02/09 S A D Ayers 3.80 Antiguan Liquidators: conducted research and drafted
REDACTED
06/02/09 M E Burnett .20 Provided electronic copy of Norton Annual Survey of
Bankruptcy Law section for Matt Wood.
06/02/09 T S Durst .30 Attention to issues regarding REDACTED
06/02/09 J S Fitzwater 3.00 Continuing to organize support files for the litigation team;
308
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 242 of 377
Page 241
Hours Description
updating tracking chart of filings entered by the parties;
updating the Pleadings Pad; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; and continuing to update searchable text
for pleadings for the Extranet website.
06/02/09 K M Sadler 8.30 Reviewed REDACTED ; conferences
with Ayers, Howell and Arlington regarding REDACTED ;
reviewed pleadings filed by Vantis; reviewed pleadings filed;
reviewed issues regarding REDACTED ; reviewed
issues regarding REDACTED
reviewed issues regarding REDACTED
reviewed issues regarding REDACTED ; reviewed
correspondence regarding ; reviewed REDACTED
in preparation for client meeting; correspondence with Pershing
counsel
06/02/09 K Scanlan 4.50 Assist in meeting preparation and coordination; distribute new
filings and upload materials to extranet site; update deadlines
chart; update interventions chart to show recent withdrawals
and new interventions; update notebook; review new
Trustmark matters in SEC case and in separate cases; set up
files for new cases; add new materials to charts and upload to
extranet site; review request from Sue Ayers regarding
REDACTED ; numerous telephone conferences with
clerk to coordinate receipt of record.
06/02/09 E A Soderlund 2.70 Research issues relating to REDACTED
06/02/09 W F Stutts, Jr. 1.10 Reviewed REDACTED with Mr. Howell
and responded to REDACTED
from Ms.
Ayers; reviewed REDACTED
reviewed REDACTED
REDACTED
reviewed
06/02/09 R H Wood 2.40 Researched Texas Uniform Fraudulent Transfers Act and
specifically Quilling v. 3D Marketing REDACTED
06/03/09 C N Adams 5.60 Conference with Joe Cialone, Kevin Sadler and Tony Davis
regarding REDACTED ; preparing for meeting with Ralph
Janvey regarding conference with Ralph Janvey and
REDACTED
team regarding REDACTED
06/03/09 D T Arlington 3.40 Reviewed REDACTED and
communicated with team regarding REDACTED researched regarding
309
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 243 of 377
Page 242
Hours Description
REDACTED ; reviewed materials relating
to REDACTED and exchanged email with team
regarding REDACTED
06/03/09 S A D Ayers 4.00 Conducted research and drafted REDACTED
; telephone conference with
expert regarding REDACTED .
06/03/09 S A D Ayers 4.50 Drafted REDACTED
conducted research and drafted REDACTED
; provided cases and annotations
for REDACTED
06/03/09 T S Durst .50 Attention to issues regarding REDACTED ; consideration
of matters regarding REDACTED communications with
team regarding
06/03/09 J S Fitzwater 2.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
continuing to update searchable text for pleadings and related
litigation for the Extranet website; and continuing to update
support files for the litigation team.
06/03/09 L C Fluker 2.80 Downloaded email communications to update correspondence
file and organized hard copies of correspondence to update
correspondence file; updated Excel tracking chart with
information on recent communications; reviewed Response to
determine if accurate long and short citation forms have been
applied; conferred with Ellen Reeder regarding additional tasks
to be completed before filing of Response.
06/03/09 K M Sadler 10.80 Consultations with client ; conference with Ayers regarding
REDACTED ; conference with Arlington regarding
; reviewed communications from Examiner;
REDACTED
conference with Davis, Cialone and Adams regarding
REDACTED reviewed information from Lovett regarding
REDACTED ; reviewed correspondence from Stanford
counsel; reviewed information regarding REDACTED
REDACTED conference with Cooper regarding
REDACTED ; reviewed issues with Arlington and
Ayers regarding REDACTED
06/03/09 E A Soderlund 2.40 Prepare response to list of questions from W. Stutts regarding
REDACTED , call with W. Stutts regarding
and distribute email to working group with REDACTED
REDACTED
06/03/09 M C Wood 1.60 Added final citations to REDACTED ; Compiled cases
for REDACTED .
06/03/09 R H Wood 6.40 Researched case law where REDACTED
310
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 244 of 377
Page 243
Hours Description
researched relief defendant cases REDACTED
; researched the
duties of a trustee in bankruptcy in comparison to the duties of
a receiver under receivership law; provided guidance and
pinpoint cites to Ellen Reeder as she cite-checked the response
to the Examiner.
06/03/09 A F York 6.80 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; office
conference with D. Arlington and B. Day regarding REDACTED
various calls and emails with FTI, FITS, and Stanford
regarding call with Mike Myers regarding REDACTED
REDACTED
06/04/09 D T Arlington 1.70 Further reviewed intervention filings from Trustmark and HP.
06/04/09 S A D Ayers 5.00 Conducted research and drafted REDACTED
06/04/09 M E Burnett .50 Searched for and provided background information on
specified account holders at the request of David Arlington.
06/04/09 M E Burnett .50 Searched for REDACTED at the request of Bill
Stutts.
06/04/09 T S Durst 1.00 Communications with client and opposing counsel regarding
pending items; analysis of REDACTED ; work
on REDACTED ;
communications with and directions to team regarding REDACTED
06/04/09 J S Fitzwater 1.80 Organizing support files for the litigation team; monitoring
court filings and assisting attorney team to coordinate reception
of filings to appropriate members; and updating pleadings for
the Extranet website.
06/04/09 L C Fluker 2.80 Downloaded email communications to update correspondence
file and organized hard copies of correspondence to update
correspondence file; updated Excel tracking chart with
information on recent communications.
06/04/09 K M Sadler 5.80 Reviewed and revised REDACTED
reviewed REDACTED
reviewed account release information REDACTED
reviewed issues regarding REDACTED ; reviewed issues
regarding REDACTED
06/04/09 K Scanlan 3.50 Brief office conference with Tim Durst regarding REDACTED
prepare short memo regarding responses; update SEC
REDACTED
main case deadlines chart and incorporate related REDACTED
311
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 245 of 377
Page 244
Hours Description
into the deadlines chart; brief telephone conference with
Austin regarding REDACTED assist in forwarding
materials to team; prepare memo to Kristie Blumenschein
regarding REDACTED
06/04/09 V R Walker .50 Assembled and organized court papers and correspondence.
06/04/09 R H Wood 1.10 Helped Ellen Reeder and Lawrence Fluker with cite-check
questions; researched relevant pin-point citations for
REDACTED
06/05/09 D T Arlington .70 Addressed issues relating to REDACTED
06/05/09 S A D Ayers 6.00 Antiguan Liquidators: Conducted research and drafted
REDACTED
06/05/09 J A Cialone, II .70 Reviewed and commented on REDACTED
06/05/09 T S Durst .30 Review and advise on REDACTED
06/05/09 E D Reeder 3.80 Reviewed and proofread response for accuracy of citations;
made revisions regarding same; reported to David Arlington.
06/05/09 K M Sadler 8.50 Reviewed and revised REDACTED ; reviewed
account release issues; consultations with client; reviewed
pleadings filed regarding REDACTED ; reviewed status of
briefing on REDACTED ; conference with
Arlington regarding REDACTED ; reviewed account
review issues and information from Lovett; reviewed and
commented on REDACTED
06/05/09 K Scanlan 2.20 Forward new documents to team; update charts and deadlines
memo; prepare chart for new cases; draft memo regarding mail
issues and update mail file.
06/05/09 R H Wood .90 Read case law for REDACTED
06/06/09 S A D Ayers 7.60 Antiguan Liquidators: Conducted research, drafted,
incorporated suggested changes from team into
REDACTED
06/06/09 K M Sadler 3.50 Reviewed issues regarding evidence for REDACTED
; reviewed REDACTED
reviewed issues regarding REDACTED
reviewed issues regarding REDACTED
06/07/09 J A Cialone, II .70 Attention to REDACTED and related calls.
06/07/09 T S Durst 2.00 Review and comment on REDACTED
attention to REDACTED
312
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 246 of 377
Page 245
Hours Description
06/07/09 K M Sadler 4.50 Reviewed and provided comments on REDACTED
, and draft REDACTED ;
emails to/from Ayers and Howell regarding REDACTED ;
reviewed issues regarding REDACTED ;
reviewed REDACTED ; reviewed draft REDACTED
06/07/09 E A Soderlund 2.70 Draft REDACTED and
distribute for review and comment.
06/07/09 R H Wood 2.60 Researched REDACTED
06/08/09 D T Arlington 3.50 Exchanged email with team regarding REDACTED
worked on relief defendant complaint against baseball
player investors.
06/08/09 S A D Ayers 11.40 Conducted research and drafted
REDACTED
telephone conference and drafted REDACTED
REDACTED
06/08/09 J A Cialone, II .80 Reviewed draft and discussed
same with trial team; continued focus and attention to
REDACTED
06/08/09 T S Durst 2.30 Review and comment on REDACTED
consideration of matters regarding Holt
and Stanford issues; communications with and directions to
team regarding REDACTED
06/08/09 J S Fitzwater 2.80 Assisting Kevin Scanlan regarding the charting outstanding
motions; updating tracking chart of filings entered by the
parties; updating the Pleadings Pad; updating tracking chart of
filings entered by the intervenors; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; and continuing to update searchable text
for pleadings for the Extranet website.
06/08/09 L C Fluker 2.90 Checked cites in designated portion of Response to Petition,
including reviewed opinions to confirm that all quotes and
references are correct; conferred with Ellen Reeder and
Vanessa Garcia regarding additional tasks necessary to finalize
Response for filing on 06/09/09.
06/08/09 V O Garcia 6.00 Correspond with case team and organize help for case pull and
cite check and create share drive folder for same; review and
cite check Response and Objections to Petition for Recognition
313
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 247 of 377
Page 246
Hours Description
of Foreign Main Proceeding; per S. Ayers, prepare exhibits and
slip sheets; correspond with K. Scanlan regarding filing in the
Blount v. Deragon and Morgan matter and ask T. Moratto to
obtain court copies of docket sheet and filings from Travis
County Court; correspond with D. Arlington and A. York
regarding filing of Stipulation (Epstein).
06/08/09 S Jampala 1.00 Pulled cases and saved to the shared drive for reference.
06/08/09 J B Lawrence 6.40 Continue researching and drafting REDACTED
06/08/09 R C Lewis .40 Phone conference with Craig Adams regarding
REDACTED ;
reviewed material related to same.
06/08/09 S A Massad 2.50 Reviewed and commented on draft of response to Vantis
motion and related drafts; various telephone conferences and e-
mail correspondence regarding same.
06/08/09 T M Moratto Jr. 2.80 Per V. Garcia, pulled case law for Stanford's Response and
Objections to Petition for Recognition; Per V. Garcia, assisted
with quality check of response with regard to citations to
Janvey Affidavit exhibits.
06/08/09 E D Reeder 4.10 Office conference with paralegals regarding cite-checking of
response; verified all legal authorities cited and/or quoted in
assigned portion of response; located additional authorities.
06/08/09 K M Sadler 6.40 Reviewed and commented on draft response to Vantis petition
and draft declarations; reviewed issues regarding
REDACTED reviewed issues regarding
clawback claims analysis; reviewed issues regarding
REDACTED ; reviewed account release
issues
06/08/09 K Scanlan 4.50 Continue to prepare appellate record for scanning; office
conference with John Lawrence regarding REDACTED ; pull
materials requested by John Lawrence relating to
REDACTED ; work on chart of
outstanding motions; assist in preparation of response; pull
materials and prepare for Austin and forward to Bill Stutts.
06/08/09 E A Soderlund .30 Revise and edit answer after receiving comments.
06/08/09 M C Wood 2.00 Researched REDACTED
06/09/09 S A D Ayers 17.60 Conducted research, drafted, selected exhibits for filing:
response to petition for recognition pursuant to chapter 15 of
Bankruptcy Code and declarations in support, appendix,
314
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 248 of 377
Page 247
Hours Description
motion to exceed page limits, and answer.
06/09/09 T S Durst .60 Review and comment on Antigua papers, communications with
team regarding REDACTED
06/09/09 J S Fitzwater 4.60 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
continuing to update searchable text for pleadings and related
litigation for the Extranet website; assisting Kevin Scanlan in
coordinating with the Clerk of the Court's office regarding
copies of orders with apostil; updating tracking chart of filings
entered by the parties and the intervenors; updating support
files for the litigation team; and updating the Pleadings Pad.
06/09/09 L C Fluker 4.20 Assisted in finalizing and filing Response to Petition, including
divided pdfs containing Appendix exhibits into smaller sized
pdfs, organized Appendix exhibits, proofread appendix index
and made necessary revisions; relabeled exhibits as necessary;
conferred with Vanessa Garcia, Barbara Martin and Ellen
Reeder regarding electronic filing.
06/09/09 V O Garcia 10.30 Correspond with case team; continue review and cite check
Response and Objections to Petition for Recognition of Foreign
Main Proceeding; update and prepare corresponding exhibits
and correspond with E. Reeder, S. Ayers, and L. Flukier
regarding same; work with secretary to convert excel exhibit;
update Response with cite check corrections; review exhibits
and update Appendix to Response; confirm website citation,
update and follow up with S. Ayers regarding same; efile
Stipulation Regarding Release of Accounts (Wenitsky) and
Stipulation Regarding Release of Accounts (Hausladen); and
forward same to D. Rohleder for tracking; follow up with K.
Scanlan regarding request for proof of filing Blount v. Deragon
and Morgan matter and forward docket sheet and petition; efile
Response and Objections to Petition for Recognition of Foreign
Main Proceeding and corresponding appendix and exhibits;
(10.25)
06/09/09 J B Lawrence .90 Draft and revise REDACTED
06/09/09 T M Moratto Jr. .50 Researched associated parties in Cause no. D-1-GN-09-000987
and returned docket sheet and original petition to V. Garcia.
06/09/09 E D Reeder 11.90 Verified citations and quotations in section of response; located
additional authorities cited in same; reviewed declarations of
Janvey and Van Tassel; added citations to same to response;
coordinated with paralegal team regarding e-filing
requirements and exhibits; reported to Sue Ayers regarding
REDACTED
315
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 249 of 377
Page 248
Hours Description
06/09/09 K M Sadler 7.50 Reviewed and commented on draft brief in response to Vantis
petition; reviewed Janvey and KVT declarations; consultations
with receiver regarding REDACTED reviewed Rule 12 draft
response; reviewed issue with Ayers regarding REDACTED
reviewed pleadings received regarding pending motions;
conference with S. Austin regarding REDACTED
; reviewed issues regarding account release
process with D. Arlington; reviewed issues regarding
REDACTED ; reviewed issues regarding
clawbacks claims analysis
06/09/09 K Scanlan 9.50 Complete review and separation of entire appellate record and
forward to copy service; draft memo regarding problems with
numbering of record; review document requests from Austin;
request certified copies of orders with apostil for use overseas
pursuant to Hague Convention; receive and prepare materials;
correspondence with Austin regarding orders; forward
materials to Switzerland; draft proposed motion for leave to file
brief in excess of page limits and proposed order and forward
to Sue Ayers for review and revisions; review materials
forwarded from Austin regarding REDACTED
; update chart for Jennifer Adams; pull
requested materials relating to the motion for approval of
procedures for sale of real property and forward all related
pleadings to William Stutts; continue to work on charts for
Kevin Sadler concerning orders and pending motions.
06/09/09 E A Soderlund .60 Revise, edit, and prepare answer for filing and send to S. Ayers
to file with brief opposing chapter 15 petition for recognition.
06/09/09 W F Stutts, Jr. .50 Provided input into answer/response on Chapter 15 petition.
06/09/09 R H Wood .30 Helped Ellen Reeder with pinpoint citations for response to
Antiguan receivers.
06/10/09 D T Arlington 1.50 Worked on account release issues; conferences with team
regarding same; reviewed materials relating to aircraft
settlement; telephone conference with GE counsel regarding
same; worked on relief defendant complaints and coordinated
with team regarding same.
06/10/09 T S Durst .50 Attention to matters regarding REDACTED
communications with team
regarding same.
06/10/09 J S Fitzwater 6.00 Assembling notebooks of filings entered in the '721 matter for
the Receiver; monitoring court filings and assisting attorney
team to coordinate reception of filings to appropriate members;
continuing to update searchable text for pleadings and related
litigation for the Extranet website; continuing to update
316
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 250 of 377
Page 249
Hours Description
tracking chart of filings entered by the parties; and updating the
Pleadings Pad.
06/10/09 V O Garcia 1.30 Update and continue efiling corresponding exhibits to
Response and Objections to Petition for Recognition of Foreign
Main Proceeding; per S. Ayers, prepare index of the 6/9/09
filing listed in order as they should be organized and forward
same to K. Scanlan (1.25)
06/10/09 V O Garcia .70 Follow up with Court clerk regarding filing of Response and
send email to case team to provide update regarding same; per
S. Ayers forward copies of Response, Declaration of Ralph S.
Janvey and Declaration of Karyl Van Tassel to S. Massad.
06/10/09 E D Reeder 5.50 Reviewed efiling procedures and telephone conference with
court regarding same; reviewed PACER for verification of
June 9 filing of response; located documents for Sue Ayers;
drafted REDACTED
06/10/09 K M Sadler 7.80 Reviewed draft claw-back claim complaints; reviewed issues
regarding Pershing accounts and stipulations; reviewed issues
regarding broker complaints; reviewed issues regarding
REDACTED conference with Arlington regarding account
issues; reviewed issues regarding real estate procedures motion
and reply regarding objections filed; reviewed investor account
holdback issue; reviewed issues regarding REDACTED
REDACTED reviewed order from Examiner regarding
account release stipulation
06/10/09 K Scanlan 3.50 Begin preparing materials for Mr. Janvey; review
correspondence from Austin office concerning various
exhibits; review e-mail from Kevin Sadler; update charts,
locate additional information and forward to team and to Mr.
Sadler; correspondence with counsel for Hunton parties
regarding appellate record; correspondence with Kristie
Blumenschein regarding REDACTED .
06/10/09 W F Stutts, Jr. .40 Reviewed information provide by Ms. Van Tassel and Ms.
Blumenschein regarding REDACTED
06/11/09 D T Arlington 4.20 Worked on relief defendant complaints and communicated with
team regarding same; communicated with team regarding
REDACTED ; reviewed documents relating to
REDACTED ; exchanged email with counsel for Gagosian Gallery;
communicated with Richard Roper regarding REDACTED
reviewed recent filings.
06/11/09 D T Arlington .80 Researched and addressed questions raised by examiner.
06/11/09 T S Durst 2.30 Review and revise REDACTED , and attention to
REDACTED ; review of new pleadings regarding intervenors
317
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 251 of 377
Page 250
Hours Description
and reconsideration; attention to REDACTED and
communications with and directions to Mr. Lawrence
regarding REDACTED ; communications with team
regarding REDACTED
06/11/09 J S Fitzwater 1.30 Updating support files; updating hard-copy correspondence;
tracking chart of filings entered by the parties; updating
tracking chart of filings entered by the intervenors; monitoring
court filings and assisting attorney team to coordinate reception
of filings to appropriate members; updating pleadings for the
Extranet website; and updating the Pleadings Pad.
06/11/09 V O Garcia .90 Stipulation Regarding Release of Accounts (Landry); and
forward same to D. Rohleder for tracking.
06/11/09 R C Lewis 2.50 Reviewed new materials related to REDACTED
; began drafting motion regarding REDACTED
06/11/09 K M Sadler 8.80 Reviewed issues regarding relief defendant claims; reviewed
account release issues; reviewed Pershing stipulations and
emails to/from Pershing counsel and questions from Receiver;
reviewed issues regarding de minimus releases; conference
with KVT regarding REDACTED ; conference with
Durst regarding REDACTED ; reviewed pleadings
received; correspondence to RAS counsel regarding motion to
compel response and tax documents
06/11/09 K Scanlan 3.00 Review e-mail from Sue Ayers regarding transcript citations
needed; review hearing transcripts and locate requested section;
cut transcripts and highlight selected sections and forward to
Austin; correspondence with Bob Howell regarding
REDACTED assist in finalizing response and prepare
for filing; complete filing and distribute to trial team; add new
pleadings to extranet site.
06/11/09 W F Stutts, Jr. 1.40 Provided organizational and identification of
REDACTED
06/12/09 C N Adams .60 Telephone conference with Ralph Janvey regarding
REDACTED
06/12/09 D T Arlington 6.50 Prepared email to counsel for HP regarding underlying dispute;
addressed de minimis account release issues; telephone
conference with counsel for GE regarding settlement
submission; further worked on submission regarding aircraft
settlement; worked on account reviews and stipulations;
communicated with account holders and their counsel;
conferences and email exchanges with team regarding account
review issues; reviewed recent filings.
318
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 252 of 377
Page 251
Hours Description
06/12/09 T S Durst .50 Work on REDACTED ; communications
with team regarding REDACTED .
06/12/09 J S Fitzwater 2.60 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
continuing to update pleadings for the Extranet website;
updating tracking chart of filings entered by the parties;
updating support files for the litigation team; and updating the
Pleadings Pad.
06/12/09 R C Lewis 2.10 Reviewed additional information from REDACTED ; drafted
REDACTED .
06/12/09 K M Sadler 10.70 Conference with FTI regarding REDACTED
conferences with Arlington regarding REDACTED
reviewed issues related to Pershing stipulation and wire
transfer; consultations with client and Cialone regarding
REDACTED ; consultations with client and
representatives of FNRA regarding investigation; reviewed
issues regarding investors represented by Sonnenschein
regarding finalizing proceeds transfer and stipulations;
consultations with client regarding REDACTED
reviewed draft relief defendant complaints; reviewed
supplemental brief filed by Examiner; reviewed
correspondence from Cox/Smith regarding investor account
freeze; emails to Arlington and Lovett regarding same
06/12/09 K Scanlan 2.20 Update files and charts; review filings in Trustmark matters
and set up new files and chart for tracking deadlines; per Kevin
Sadler review filings and orders granted and begin preparation
of chart to track matters currently before the court.
06/12/09 V R Walker .30 Assembled and organized correspondence.
06/13/09 D T Arlington 2.40 Worked on REDACTED
coordinated with team regarding REDACTED
06/13/09 T S Durst 1.80 Review and comment on upcoming filings; consideration of
REDACTED and review of REDACTED
; communications with team regarding
REDACTED
.
06/13/09 R C Lewis 1.50 Drafted REDACTED
;
reviewed materials related to REDACTED
06/13/09 K M Sadler 3.30 Reviewed issues regarding REDACTED
joint motion and
settlement documents; reviewed and responded to emails from
VFS counsel; reviewed FTI information regarding REDACTED
reviewed account release issues
319
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 253 of 377
Page 252
Hours Description
06/13/09 W F Stutts, Jr. .40 Reviewed motion in US for sale of property and compared and
detailed REDACTED
06/14/09 D T Arlington 6.30 Continued working on and revising affidavit in support of
aircraft settlement submission; coordinated with team and with
GE counsel regarding same; reviewed draft joint submission to
court regarding settlement; communicated with GE counsel
regarding same
06/14/09 T S Durst 1.30 Analysis of issues regarding upcoming filings; telephone
conference with team regarding REDACTED
06/14/09 J B Lawrence 5.50 Review Susan Stanford Motion to Intervene; research case law
relevant to REDACTED
06/14/09 K M Sadler 5.40 Reviewed and commented on aircraft settlement pleadings and
settlement documents; reviewed and responded to numerous
emails from VFS counsel regarding same; reviewed issues
regarding REDACTED ; reviewed issues regarding motion
responses due; reviewed and responded to correspondence
from investor attorney regarding account freeze
06/15/09 D T Arlington 6.10 Worked on and finalized aircraft settlement submission;
coordinated with Receiver and counsel for VFS regarding
same; worked on account review and release issues;
coordinated with team regarding same; conferred with other
counsel regarding aircraft settlement submission.
06/15/09 T S Durst 1.80 Work on REDACTED ;
attention to other pending items and upcoming deadlines;
communications with and directions to team regarding REDACTED
06/15/09 J S Fitzwater 3.60 Updating support files for the Litigation team; updating
tracking chart of filings entered by the parties; updating hard-
copy correspondence; updating the Pleadings Pad index;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members; and
updating the Extranet website, as well as hosted filings
regarding searchable text.
06/15/09 J B Lawrence 8.40 Draft and revise REDACTED
06/15/09 K M Sadler 10.20 Reviewed correspondence from RAS counsel; reviewed
account release issues; reviewed issues regarding broker
claims; reviewed investor complaints and emails from client
regarding reviewed issues regarding REDACTED
REDACTED
; reviewed and commented on pleadings and
settlement documents regarding aircraft settlement; conference
320
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 254 of 377
Page 253
Hours Description
with VFS counsel; reviewed issues regarding REDACTED
; communications with counsel
regarding aircraft settlement; reviewed issues regarding inquiry
by state authorities regarding RAS/Stanford; reviewed emails
regarding Pershing wire transfer; reviewed draft pleadings
06/15/09 K Scanlan 1.70 Update files; review request for materials relating to non-SEC
case deadlines and motions; locate information, organize by
case and by date and forward.
06/15/09 W F Stutts, Jr. .70 Worked on Chapter 15 motion reply.
06/15/09 A F York 6.50 Reviewed and analyzed account release applications and
summaries; prepared stipulations for partial account releases;
calls and emails to account holders regarding same; various
calls and emails with FTI, FITS, and Stanford regarding same.
06/16/09 D T Arlington 3.80 Exchanged email with counsel for HP regarding claim support
and motion response; addressed account review issues;
reviewed status of account wire transfers; coordinated with
opposing counsel regarding aircraft settlement submission to
court; telephone conference with court regarding same;
exchanged email with examiner regarding aircraft settlement;
coordinated with counsel for Comerica regarding aircraft
settlement issues and letter of credit stipulation; addressed
issues relating to STC accounts
06/16/09 S A D Ayers 3.80 Corresponded with various lawyers regarding newly filed liens
and lawsuits against the Estate; drafted REDACTED
analysis of REDACTED .
06/16/09 T S Durst 1.10 Work on response briefs due on pending motions; attention to
other pending matters and conference with team regarding
same.
06/16/09 J S Fitzwater 2.80 Continuing to update support files for the Litigation team;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Pleadings Pad index; updating tracking chart of
filings entered by the parties; and updating the Extranet
website, as well as hosted filings regarding searchable text.
06/16/09 M D Kusey 3.50 Logged in mail in correspondence and claims logs.
06/16/09 J B Lawrence 2.70 Edit and revise response to Susan Stanford motion to intervene;
finalize same for filing.
06/16/09 E D Reeder 1.90 Made revisions to joint motion to abate in Westin lawsuit.
06/16/09 K M Sadler 9.30 Reviewed data and issues regarding broker claims; reviewed
issues regarding investor claims; reviewed correspondence
from RAS counsel; conference with RAS counsel; reviewed
321
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 255 of 377
Page 254
Hours Description
issues regarding aircraft settlement; conferences with VFS
counsel regarding settlement and hearing; reviewed and
commented on Comerica stipulation; conferences with Ayers
regarding REDACTED ; reviewed reply filed by Bukrinsky
intervenors regarding bankruptcy issues; reviewed other
pleadings received; conference with Ayers regarding
REDACTED conference with
Arlington regarding REDACTED
; reviewed
information regarding Peck accounts and email to Examiner
regarding same
06/16/09 K Scanlan 3.50 Update deadlines chart and forward to team; review materials
from John Lawrence and format response for filing; handle
filing of Response to Susan Stanford's motion and distribute to
team; assist in finalizing additional filing and formatting for
NDTX; file stipulation and distribute; revise deadlines chart to
reflect day's filings; update outstanding matters chart; respond
to requests for information from Austin office.
06/16/09 W F Stutts, Jr. .40 Reviewed REDACTED and noted
observations on REDACTED .
06/17/09 C N Adams .60 Reviewing response; reviewing cash data for same.
06/17/09 D T Arlington 4.70 Reviewed motions to intervene by HP and Trustmark;
reviewed motion to compel release of coins; coordinated
regarding responses to motions to intervene and motion to
compel release of coins; exchanged email with Comerica
counsel regarding aircraft settlement issues; reviewed inquiries
from examiner; prepared stipulation regarding response to HP
and Trustmark's motions to intervene; coordinated with
opposing counsel regarding same.
06/17/09 J L Cafferty 2.10 Reviewed HP and Trustmark's motions to intervene and drafted
responses to same.
06/17/09 J A Cialone, II .60 Attention to REDACTED
06/17/09 T S Durst .50 Review and revise response brief on intervention motion.
06/17/09 J S Fitzwater 3.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Pleadings Pad index; assisting Craig Adams
regarding Joint VFS filings (Dkt. Nos. 472, 473); updating
litigation support files; updating tracking chart of filings
entered by the parties; and updating the Extranet website.
06/17/09 M D Kusey 4.80 Logged in mail in correspondence and claims logs.
06/17/09 J B Lawrence 4.60 Continue research related to REDACTED
322
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 256 of 377
Page 255
Hours Description
06/17/09 R C Lewis 4.80 Reviewed information regarding
REDACTED began drafting REDACTED
06/17/09 K M Sadler 11.30 Reviewed motion responses (Stanford/Blount); conference with
opposing counsel regarding motion; reviewed issues related to
RAS motion to disqualify; reviewed account release issues;
reviewed information regarding broker and investor claims;
reviewed issues regarding assets sales needing court approval;
conference with B. Krage regarding REDACTED ; reviewed
issues regarding Comerica stipulation regarding aircraft LOC's;
reviewed other aircraft settlement issues; reviewed and
responded to emails from investor; conference with Cooper
regarding REDACTED ; reviewed
pleadings received by Bukrinsky; reviewed issues regarding
motion regarding coins and bullions
06/17/09 K Scanlan 4.50 Telephone conference with Eric Soderlund on
REDACTED
update and revise deadlines chart per Kevin Sadler direction;
telephone conference with John Lawrence regarding filing;
update non-SEC main case chart assist in the distribution of
new filings to the trial team and upload new matters to the
extranet site.
06/18/09 D T Arlington 4.20 Prepared letters to brokers and their counsel regarding relief
defendant suit; coordinated with Gene Besen regarding relief
defendant complaint.
06/18/09 J L Cafferty 2.30 Drafted response to HP and Trustmark's motion to intervene.
06/18/09 J A Cialone, II .60 Attention to affirmative claims asserted in lawsuits.
06/18/09 T S Durst .80 Work on response briefs to be filed regarding proceeding in
other jurisdictions; attention to new filings and upcoming
response deadlines.
06/18/09 J S Fitzwater 1.00 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating pleadings for the Extranet website; updating tracking
chart of filings entered by the parties and the intervenors; and
updating the Pleadings Pad Index.
06/18/09 K W Hinton 7.40 Coordinated record cite check, supervised and assisted with
same; quality-checked record cite check of Reply; pulled and
reviewed cases and cite-checked reply; assisted B. Howell with
pleadings; assisted B. Day with stipulations; assisted with
letters to financial advisors; assisted with 5th Circuit
appearances; prepared and e-filed stipulations; reviewed 5th
Circuit deadlines and calendared same for appeal team.
323
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 257 of 377
Page 256
Hours Description
06/18/09 J R Knight .40 Assessed REDACTED
06/18/09 M D Kusey 4.00 Logged in mail in correspondence and claims logs.
06/18/09 R C Lewis 7.60 Researched issues in preparation for REDACTED
conference with John Greer
regarding began drafting
REDACTED REDACTED
06/18/09 K M Sadler 9.60 Reviewed issues regarding investor and broker complaints;
conferences with counsel for investors and brokers regarding
relief defendant complaints; reviewed account release issues;
reviewed motion deadlines and responses; conference with La.
officials regarding criminal investigation; conferences with
Adams and Cialone regarding REDACTED
conferences with Arlington regarding REDACTED
06/18/09 K Scanlan .70 Assist in distributing incoming materials; update file.
06/18/09 E A Young 5.80 Discussed REDACTED
with S. Ayers; reviewed appellate
rules; called Fifth Circuit clerk's office to discuss request to be
able to file two briefs; drafted motion seeking leave to file two
separate briefs; discussed REDACTED with
S. Ayers; discussed REDACTED
with D. Arlington.
06/19/09 D T Arlington 5.90 Researched regarding inquiries from examiner; telephone
conference with Gene Besen regarding relief defendant
complaint; worked on response to motion to compel release of
coins; prepared email to Michael Stanley regarding claims
against brokers; further researched and responded to examiner
inquiries.
06/19/09 J L Cafferty 3.60 Drafted response to HP and Trustmark's motions to intervene.
06/19/09 J A Cialone, II .60 Attention to various drafts of court papers.
06/19/09 J S Fitzwater 4.80 Updating the Extranet website, as well as hosted filings
regarding searchable text; updating support files for the
Litigation team; monitoring court filings and assisting attorney
team to coordinate reception of filings to appropriate members;
office conference with Kevin Scanlan regarding SEC's Motion
to File an Amended Complaint and the Receiver's stipulations
regarding individual investors' accounts; updating the
Pleadings Pad; and updating the tracking chart of filings
entered by the parties.
06/19/09 K W Hinton 5.60 Assisted B. Howell with pleadings; prepared and e-field
stipulations; reviewed Stanford indictment and related article;
324
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 258 of 377
Page 257
Hours Description
reviewed and assisted with notices for 5th Circuit; drafted letter
to clerk of 5th Circuit and assisted with service of same.
06/19/09 J R Knight 2.00 Analyzed appellate record in anticipation of appellee's response
to Stanford's and Hunton's appeals.
06/19/09 M D Kusey 3.70 Logged in mail in correspondence and claims logs.
06/19/09 J B Lawrence 4.70 Continue researching law related to response to motion to
disqualify Baker Botts; outline and begin drafting response.
06/19/09 R C Lewis 3.50 Prepared and drafted REDACTED
conferences with Sam Cooper regarding
06/19/09 K M Sadler 7.80 Reviewed account release issues; reviewed complaint
regarding investor clawbacks; conferences with broker and
investor counsel regarding claims; reviewed issues regarding
pending appeal; consultations with client regarding REDACTED
06/19/09 K Scanlan 1.80 Review e-mails regarding requested documents; pull
documents as requested and organize and prepare notebook;
update interventions chart.
06/19/09 E A Young 2.00 Reviewed background materials relevant to the motion to
release coins and bullion; reviewed and annotated the motion
itself.
06/20/09 K Scanlan 2.50 Work on record index.
06/20/09 E A Young 2.00 Reviewed and annotated summary memorandum describing
REDACTED
reviewed and annotated REDACTED
06/21/09 D T Arlington .30 Exchanged email regarding response to motion to compel
release of coins.
06/21/09 S A D Ayers .60 Provided select record evidence and select court papers to Joe
Knight for use drafting appellate brief.
06/21/09 J A Cialone, II .50 Organized court papers and correspondence, including email,
and responded as appropriate.
06/21/09 K Scanlan 1.50 Update charts; review and update all extranet sites; add new
materials to notebooks; respond to request for documents from
Eric Soderlund.
06/21/09 E A Young 6.20 Completed review of REDACTED
REDACTED reviewed the motions and briefs
relevant to the Receiver's motion requiring Dillon Gage to
325
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 259 of 377
Page 258
Hours Description
show cause; REDACTED
REDACTED ; exchanged e-mails with D.
Arlington.
06/22/09 D T Arlington 8.80 Participated in conference call with team regarding coin
analysis issues; reviewed motion to compel release of coins;
researched regarding holdings relating to Turner and Equus;
exchanged email with counsel for HP regarding data request;
reviewed evidentiary materials relating to HP motion;
coordinated regarding service on financial advisors; finalized
and served complaint against investors; coordinated with Gene
Besen regarding same; prepared analysis regarding Turner and
Equus holdings and transactions; reviewed inquiries from
financial advisor relating to multiple accounts; reviewed draft
stipulation from Comerica relating to aircraft settlement.
06/22/09 S A D Ayers 4.70 Correspondence with lawyers who have filed liens and lawsuits
in violation of Amended Order Appointing Receiver; review
Hunton parties' appellate brief to 5th Circuit; reviewed Cox
motion to intervene; analyzed Stanford's motion to dismiss
fraud claims.
06/22/09 J L Cafferty 6.30 Drafted response to HP and Trustmark's motion to intervene.
06/22/09 T S Durst .40 Attention to new filings and plan/schedule for response to
same.
06/22/09 J S Fitzwater 4.80 Corresponding with Katherine Hinton regarding the
acquirement of copies of sealed stipulations (Dkt. Nos. 432,
447, 449, 458 and 467); updating the Pleadings Pad; updating
the Appearances from Attorneys for the Intervenors notebook;
updating tracking chart of filings entered by the parties and
intervenors; updating support files for the Litigation Team;
office conference with Information Technology to troubleshoot
problems associated with the firm's reception of filings;
updating hard-copy correspondence; monitoring court filings
and assisting attorney team to coordinate reception of filings to
appropriate members; and updating the Extranet website.
06/22/09 J R Knight 6.00 Analyzed REDACTED
in connection with Hunton appeal and performed initial
analysis of the Hunton parties' appellate brief.
06/22/09 M D Kusey 2.60 Logged in mail in correspondence and claims logs.
06/22/09 J B Lawrence 3.10 Research related to REDACTED
06/22/09 K M Sadler 11.80 Reviewed memos regarding REDACTED
; consultations with client regarding
reviewed REDACTED
and consultations with client regarding reviewed investor
REDACTED
326
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 260 of 377
Page 259
Hours Description
communications regarding account freeze; reviewed account
release issues; reviewed appellate pleadings received;
conference with Arlington regarding REDACTED ;
reviewed motion regarding coin/bullion account of
Turner/Equus; reviewed information regarding accounts;
reviewed issues regarding relief defendant complaint against
Maddux et. al; reviewed issues regarding Vantis proceedings in
UK; reviewed RAS motion regarding fraud claims; reviewed
Comerica stipulation and issues regarding aircraft settlement;
conference with financial team regarding REDACTED
emails to/from Turner counsel regarding
follow up questions
06/22/09 K Scanlan 4.50 Continue work on index of record; telephone conference with
Kevin Sadler regarding deadlines; update deadlines charts;
forward incoming pleadings to the litigation team.
06/22/09 E A Young 6.50 Reviewed Dillon Gage's filing in response to Gagosian
Gallery/Pre-War Art; began drafting outline of response to
motion; discussed REDACTED
with D. Arlington.
06/23/09 D T Arlington 4.30 Worked on additional relief defendant complaint; coordinated
regarding service on relief defendants; reviewed further
inquiries from examiner; prepared letter to counsel for Dillon
Gage.
06/23/09 S A D Ayers 2.30 Provided information to Joe Knight for use in drafting appellate
brief to Fifth Circuit; attention to new liens filed on real and
personal property.
06/23/09 J L Cafferty 4.20 Drafted response to HP and Trustmark's motions to intervene
06/23/09 T S Durst .40 Work on REDACTED
06/23/09 J S Fitzwater 7.50 Continuing to update litigation support files; continuing to
update the Pleadings pads; continuing to update tracking chart
of filings entered by the parties and intervenors; continuing to
update hard-copy correspondence; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; office conference with Kevin Scanlan
regarding R. Allen Stanford's Motion to Substitute Counsel
(with an Amended Certificate of Service); assisting Eric
Soderlund to prepare and file the Receiver's Consolidated
Reply To Responses To Motion to Approve Real Property
Sales Procedures (Dkt. No. 510); and updating the Extranet
website, as well as hosted filings regarding searchable text..
06/23/09 J R Knight 5.20 Analyzed the Huntons' appellate brief; analyzed
REDACTED made notes for
REDACTED
327
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 261 of 377
Page 260
Hours Description
06/23/09 M D Kusey 2.00 Logged in mail into claims and correspondence logs.
06/23/09 J B Lawrence 7.00 Continue researching and drafting REDACTED
; review draft of response to motion to disqualify
Baker Botts.
06/23/09 R C Lewis 1.00 Reviewed information regarding Beki Stanford assets; phone
conference with Sam Cooper and Sue Ayers regarding
REDACTED conference with John Greer regarding REDACTED
06/23/09 K M Sadler 10.70 Consultations with receiver regarding REDACTED
reviewed memos from Howell regarding conference with
REDACTED
FTI regarding REDACTED
emails to/from Arlington regarding communications
with counsel for various brokers; reviewed pleadings regarding
Hernandez case; reviewed issues regarding account release and
review; conference with counsel for investor regarding partial
release and motion to lift freeze; conference with Arlington
regarding REDACTED ; reviewed issues
regarding motion for release of accounts; reviewed issues
regarding Hunton appeal; reviewed issues regarding aircraft
settlement; reviewed RAS objections; conference with VFS
counsel and Court regarding form of Order; conference with
VFS counsel; conference with S. Austin and D. Arlington
regarding REDACTED ;
reviewed issues regarding Ostrow and other accounts; reviewed
and commented on draft communication regarding REDACTED
coins/bullion issues; reviewed issues regarding
REDACTED
06/23/09 K Scanlan 4.10 Assist in forwarding new filings; prepare documents for filing
and file; update motions deadlines chart; respond to request for
information from Kevin Sadler; forward requested materials to
Mr. Sadler; continue to work on record index.
06/23/09 E A Young 5.50 Reviewed Receiver's Motion to Abate (12 June 2009); added
relevant legal points to draft response; reviewed cases
concerning REDACTED
06/24/09 D T Arlington 9.20 Exchanged email with HP counsel regarding data request;
worked on response to HP and Trustmark motions to intervene;
continued working on relief defendant complaint; reviewed
additional data regarding Hunton accounts; prepared further
response to letter from counsel for Dillon Gage; coordinated
regarding REDACTED ; addressed account
release issues; coordinated with team regarding same;
328
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 262 of 377
Page 261
Hours Description
corresponded with account holders and their counsel; reviewed
objections to settlement submission; reviewed status of data
request to Toronto Dominion.
06/24/09 S A D Ayers 2.20 Responded to inquiries from Joe Knight for REDACTED
; attention to
REDACTED ; attention to REDACTED
06/24/09 J L Cafferty 4.70 Drafted response to HP and Trustmark's motions to intervene;
researched issues related to REDACTED
06/24/09 J A Cialone, II .80 Reviewed Stanford's Motion to Dismiss and considered
implications, together with related calls and emails.
06/24/09 T M Davis 2.40 Study materials regarding REDACTED ; call with J. Cialone
and E. Söderlund re call with R. Janvey, Thompson and
REDACTED
Knight re call re
REDACTED
with E. Söderlund.
REDACTED
06/24/09 J S Fitzwater 4.30 Updating support files for the Litigation team; updating the
Pleadings pads; updating the tracking chart of filings entered
by the parties and intervenors; updating filings entered on the
Extranet website, as well as filings containing searchable text;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members; and
assisting Bob Howell and Kristie Blumenschein regarding
REDACTED
06/24/09 J R Knight 5.60 Analyzed case law and worked on appellee's brief.
06/24/09 M D Kusey 4.50 Logged in mail into claims and correspondence logs.
06/24/09 J B Lawrence 5.00 Draft and revise REDACTED .
06/24/09 R C Lewis 5.70 Received and reviewed new information on Rebecca Stanford;
drafted letter to attorneys for same regarding recovery of funds;
began drafting REDACTED .
06/24/09 T M Moratto Jr. .40 Assisted with case pull for M. Wood.
06/24/09 K M Sadler 7.80 Conference with J. Cialone regarding REDACTED ;
conference with Arlington regarding
REDACTED ; reviewed account release issues; conference with
Knight regarding REDACTED ; reviewed issues regarding
investor complaints; reviewed and responded to emails from
investor counsel regarding coin/bullion issues; reviewed issues
regarding REDACTED ; conference with court staff
regarding scheduling matter; conference with M. Lovett
regarding REDACTED .
329
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 263 of 377
Page 262
Hours Description
06/24/09 K Scanlan 3.50 Work with Jennifer Adams to finalize joint motion; update
deadlines charts; prepare and forward short memo on deadlines
and responses; respond to requests for opposing parties' various
opposition responses; prepare memo for attorneys regarding
SEC case and non-SEC case deadlines.
06/24/09 M C Wood 7.20 Researched REDACTED
Researched REDACTED
; Reviewed letter from Randi Stanford's counsel giving
legal arguments in support of her ownership of the condo;
Reviewed correspondence between Receiver and Randi
regarding the condo; Reviewed prior court orders to determine
REDACTED
06/24/09 E A Young 6.50 Continued drafting response to motion to compel release of
coins and bullion; ensured accuracy of legal statements;
referred to case documents as necessary.
06/25/09 D T Arlington 5.00 Worked on report to examiner; coordinated with team
regarding same; reviewed inquiry from coin customer;
reviewed draft response to Trustmark and HP motions to
intervene; reviewed research regarding REDACTED
reviewed and analyzed data relating to Hunton appellants;
prepared report regarding same; gathered information in
preparation for hearing on claw back claims.
06/25/09 S A D Ayers 1.40 Reviewed motion and conferred with Bukrinsky movants;
telephone conference David Finn's office regarding auto issues;
attention to newly filed liens; attention to analysis of data
regarding frozen accounts.
06/25/09 J A Cialone, II .80 Attention to draft court papers.
06/25/09 B A Day 13.30 Created stipulations for a partial release of funds in account
holders' Pershing accounts; reviewed and analyzed documents
and conferred with financial team members to create such
stipulations.
06/25/09 J S Fitzwater 3.00 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Pleadings pads; assisting Kristie Blumenschein
regarding REDACTED ; updating the
tracking chart of filings entered by the parties and intervenors;
updating the Extranet website, as well as hosted filings
regarding searchable text; and assisting Stephen Massad to
330
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 264 of 377
Page 263
Hours Description
update the "Court Papers" section of the Receiver's website.
06/25/09 J R Knight 6.30 Analyzed case law; drafted standard of review and statement of
fact sections of the brief.
06/25/09 M D Kusey 4.80 Logged in mail into claims and correspondence logs.
06/25/09 J B Lawrence 1.10 Edit and cite check REDACTED .
06/25/09 K M Sadler 10.40 Reviewed issues regarding clawback claims; conferences with
Arlington; reviewed issues regarding Hunton appeal and
analysis of accounts; reviewed issues regarding Examiner
reports; conferences with Ayers; conference with Court staff
regarding status conference with the Judge and counsel; emails
to client regarding REDACTED ; reviewed and commented on
several draft motion responses; reviewed pleadings received;
correspondence with broker counsel; conference with M.
Lovett regarding REDACTED ; reviewed draft report on
account analysis and review; conference with Arlington
regarding REDACTED
06/25/09 W F Stutts, Jr. .40 Reviewed and commented on liquidators consolidated reply in
support of Chapter 15 ; updated information from Mr. Howell
and reviewed declaration from RSJ and information on new
filings.
06/25/09 V R Walker .40 Assembled and organized court papers and correspondence.
06/25/09 M C Wood 4.50 Continued researching REDACTED
; Researched
REDACTED
Met with Sue Ayers to discuss REDACTED
Began
drafting brief in support of motion to show cause against Randi
Stanford.
06/25/09 E A Young 5.20 Finished drafting response to motion to compel release of coins
and bullion; edited draft; gave draft to, REDACTED
D. Arlington.
06/26/09 C N Adams .70 Telephone conference with internal team regarding REDACTED
06/26/09 D T Arlington .80 Reviewed revised draft of response to HP and Trustmark
motions to intervene; coordinated regarding service on relief
defendants.
06/26/09 S A D Ayers 8.30 Drafted REDACTED
attention to account release
information for drafting interim status report; communications
with Examiner transmitting complaints against relief
defendants, Thompson Knight regarding REDACTED
331
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 265 of 377
Page 264
Hours Description
06/26/09 J L Cafferty 2.30 Revised response to HP and Trustmark's motions to intervene.
06/26/09 T S Durst .50 Work on issues regarding REDACTED
communications with and directions to team regarding REDACTED
06/26/09 J S Fitzwater 1.80 Updating support files for the Litigation team; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; updating the Pleadings pads
indices; updating the tracking chart of filings entered by the
parties and intervenors; and updating filings entered on the
Extranet website.
06/26/09 L C Fluker 1.70 Downloaded email communications with interested parties
from June and updated Excel tracking chart with relevant
information.
06/26/09 J R Knight 2.80 Worked on appellate brief.
06/26/09 M D Kusey 1.30 Logged in mail into correspondence and claims logs.
06/26/09 K M Sadler 9.70 Reviewed issues regarding REDACTED
; reviewed
issues regarding REDACTED
conference with Court staff; consultations with client; reviewed
issues regarding Hunton accounts; reviewed issues regarding
coin and bullion motion by Turner/Equus; reviewed and
commented on draft responses to pending motions; reviewed
issues regarding revised account review/status report; reviewed
and revised correspondence to Romero; consultations with
client regarding reviewed issues regarding investor
REDACTED
clawback complaints; reviewed memo and case regarding
REDACTED emails to Mountz and Cialone
regarding reviewed information regarding REDACTED
REDACTED
06/26/09 K Scanlan 2.50 Update charts; pull materials requested for upcoming motion
responses; proof response and cite check all references; locate
key insurance notice letters and related materials and forward
to Tim Mountz.
06/26/09 E A Soderlund 6.60 Research regarding REDACTED
for memo to client and legal team regarding REDACTED
06/26/09 W F Stutts, Jr. 1.90 Examined and reviewed REDACTED
06/26/09 M C Wood 5.00 Continued drafting brief in support of contempt against Randi
Stanford; Drafted Motion for show cause order against Randi
332
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 266 of 377
Page 265
Hours Description
Stanford; Drafted proposed order to accompany the motion
against Randi Stanford.
06/27/09 S A D Ayers 2.60 Drafted and edited Status Report on Account Release;
reviewed Stanford's motion to compel and cases cited therein.
06/27/09 T S Durst .60 Review of issues regarding REDACTED
communications with Mr. Lawrence
regarding REDACTED
06/27/09 L C Fluker .50 Reviewed correspondence file and reorganized when necessary
to correspond to Excel log of communications with interested
parties.
06/27/09 K M Sadler 8.30 Reviewed REDACTED
REDACTED conference with FTI and others
regarding REDACTED reviewed and revised chart and
report
06/27/09 E A Soderlund 4.50 Read cases regarding REDACTED
and work on memo regarding
REDACTED
06/28/09 C N Adams 1.90 Telephone conferences with working group regarding
REDACTED reviewing draft report of the receiver;
reviewing summary of accounts.
06/28/09 S A D Ayers 6.40 Drafted and edited Status Report on Account Review Process
and appendix thereto; edited REDACTED
edited
REDACTED ; supervised research conducted on REDACTED
06/28/09 T M Davis 1.50 Read E. Söderlund's memo regarding REDACTED ; discuss
with E. Söderlund; read emails regarding REDACTED
06/28/09 L C Fluker 1.50 Reviewed hard copies of correspondence from mid to late June
to confirm that appropriate entries have been made on Excel
tracking chart (through review of emails); organized hard
copies for correspondence file update.
06/28/09 J R Knight 5.80 Worked on appellee's brief.
06/28/09 K M Sadler 7.50 Reviewed and edited REDACTED
; reviewed cases; reviewed and revised Interim
report and chart; conferences with FTI and others to
REDACTED
06/28/09 K Scanlan 3.50 Update all files; review correspondence and update with key e-
mails; update insurance notice letters; update appeals files.
06/28/09 E A Soderlund 5.50 Research REDACTED
prepare draft of memo regarding REDACTED and distribute to
333
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 267 of 377
Page 266
Hours Description
working team; make revisions and answer emails regarding
REDACTED
06/28/09 W F Stutts, Jr. 1.70 Reviewed and commented on memo on REDACTED
06/28/09 M C Wood 3.70 Downloaded and forwarded REDACTED to Kevin
Sadler as requested; Performed case law research
REDACTED
Drafted memo describing REDACTED
06/29/09 C N Adams .50 Reviewing information regarding clawback issue.
06/29/09 D T Arlington 1.00 Coordinated with team regarding REDACTED
reviewed emails relating to hearing;
reviewed order from Court on claw back claims;
communicated with account team regarding same; addressed
inquiry from coins customer; coordinated with counsel for
Ulloa regarding settlement offer and service.
06/29/09 S A D Ayers 5.50 Attended hearing; delivered Fifth Circuit order dismissing
Stanford appeal to Donna Hocker; analyzed data on accounts
that remain frozen; conducted research on REDACTED
REDACTED reviewed motion for contempt
against Randi Stanford.
06/29/09 J A Cialone, II .80 Calls before and after telephone hearing with judge.
06/29/09 T M Davis 3.20 Exchange emails regarding REDACTED discuss with E.
REDACTED
Söderlund; call with J. Cialone, S. Massad, and E. Söderlund re
read REDACTED
REDACTED
and exchange emails with E.
Söderlund re REDACTED
06/29/09 T S Durst 3.80 Review and finalize REDACTED ; conference with court
regarding pending issues; follow-up on same; communications
with counsel for Holt; follow-up regarding order on account
freeze and communications with opposing counsel regarding
same.
06/29/09 J S Fitzwater 2.80 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the tracking chart of filings entered by the parties and
intervenors; updating the Extranet website, as well as hosted
filings regarding searchable text; and updating the Pleadings
pads indices.
06/29/09 J R Knight 6.80 Worked on appellee's brief; analyzed supplemental report of
the receiver and new court orders; analyzed REDACTED
; drafted
334
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 268 of 377
Page 267
Hours Description
response to intervention arguments.
06/29/09 M D Kusey 4.10 Logged in mail into correspondence and claims logs.
06/29/09 T M Moratto Jr. .40 Per K. Hinton, assisted with saving Court Papers to the shared
drive.
06/29/09 K M Sadler 7.80 Reviewed account release and review issues; reviewed
REDACTED
conference with FTI regarding REDACTED ;
reviewed correspondence and research regarding
REDACTED reviewed legal research memo regarding
REDACTED ; emails to client and Ayers regarding
REDACTED participated in phone conference with Court;
reviewed Orders issued by Court; conference with Cooper
regarding REDACTED
reviewed case law research regarding claw back issues;
reviewed and commented on REDACTED
06/29/09 K Scanlan 7.50 Update deadlines chart; review e-mails from attorneys
requesting filing information and respond; office conference
with district clerk to obtain 11 summons for broker action;
prepare scan to Austin of completed summons and package of
originals; finalize and format Denison response and file and
distribute to team; finalize and format INX response and
prepare for filing; file with court and distribute file marked
copies to team; update deadlines chart to reflect new filings;
forward requested materials to Sue Ayers; additional work on
record index.
06/29/09 E A Soderlund 5.60 Revise and edit memo on REDACTED
06/29/09 W F Stutts, Jr. 1.10 Prepared and presented comments and observations related to
REDACTED
06/29/09 M C Wood 2.50 Amended memo REDACTED
Sent a
second email memo to Kevin Sadler.
06/29/09 R H Wood 2.90 Researched the REDACTED
drafted REDACTED
335
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 269 of 377
Page 268
Hours Description
06/30/09 D T Arlington 14.40 Addressed account release issues; communicated with team
regarding REDACTED reviewed account information relating to
Hunton appellants and prepared analysis regarding same;
reviewed additional data relating to Turner and Equus motion
to compel release of coins; communicated with team regarding
same; prepared draft agreement relating to same; prepared
REDACTED to inquiries from examiner; worked on consolidated
response to HP's and Trustmark's motions to intervene;
reviewed draft statement regarding relief defendant complaints.
06/30/09 S A D Ayers 3.30 Reviewed court papers and telephone conference with Pershing
regarding Wampold case; telephone conference with SEC
regarding impact of court order on Hunton appeal to 5th
Circuit.
06/30/09 T M Davis .90 Discuss REDACTED with E. Söderlund; review REDACTED
and discuss the with T. Mountz and E. Söderlund.
REDACTED
06/30/09 T S Durst 2.80 Analysis of issues regarding insurance coverage and Holt
demand; communications with opposing counsel regarding
same; work on issues regarding REDACTED
review of matters regarding account freeze and
timing on relief defendant filings.
06/30/09 J S Fitzwater 2.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Pleadings pads; updating the tracking chart of
filings entered by the parties and intervenors; updating the
Extranet website, as well as hosted filings regarding searchable
text; and updating hard-copy correspondence.
06/30/09 L C Fluker 3.30 Cited checked portion of Receiver's Response to Motions to
Intervene (including confirmed accuracy of quoted language)
and noted necessary revisions.
06/30/09 K W Hinton 5.50 Supervised and assisted with case pull and records cite check;
reviewed and checked case citations for form and accuracy;
assisted D. Arlington with pleadings; reviewed and prepared
Summons and Complaints for service, sent same to process
server and communicated regarding same; reviewed, prepared
and e-filed stipulations.
06/30/09 J R Knight 1.40 Performed preliminary analysis of Hunton Parties' accounts
and assessed REDACTED ; telephone
consultation with counsel for the SEC regarding same.
06/30/09 J R Knight 4.10 Worked on appellee's brief.
06/30/09 M D Kusey 2.00 Logged in mail into correspondence and claims logs.
06/30/09 J B Lawrence 5.70 Research case law cited in Stanford's reply in support of
336
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 270 of 377
Page 269
Hours Description
motion to compel; edit and revise motion for leave to file under
seal; edit and revise response to disqualify Baker Botts; prepare
documents for filing.
06/30/09 E D Reeder 3.00 Direction from David Arlington; reviewed consolidated
response to motions to intervene; coordinated with paralegals
regarding cite-checking of same; verified citations and
quotations in assigned section of the response.
06/30/09 K M Sadler 3.80 Reviewed REDACTED ; reviewed
issues regarding resolving motion to release coins held at SCB;
reviewed issues regarding examiner inquiries; reviewed
account release issues; reviewed issues regarding Court's Order
to end Freeze; reviewed issues regarding SEC request for
information; reviewed inquiries from investors regarding
account status; reviewed emails regarding insurance dispute;
06/30/09 E A Soderlund .60 Revise, edit, and distribute memo on REDACTED
06/30/09 W F Stutts, Jr. 1.40 Communications with Mr. Howell, Mr. Cialone, Ms.
Blumenschein, Mr. Massad, Ms. Ayers regarding
REDACTED
06/30/09 R H Wood 2.00 Researched REDACTED
drafted REDACTED
06/30/09 E A Young .20 Discussed with D. Arlington REDACTED
07/01/09 D T Arlington 1.90 Revised letter agreement with Michael Quilling regarding coins
motion; communicated with team regarding reviewed
REDACTED
inquiries from examiner; coordinated regarding service on
relief defendants; addressed inquiry from coins account holder.
07/01/09 S A D Ayers 6.00 Telephone conference Gene Wilshire regarding Hunton appeal
to Fifth Circuit; edited and filed response to motion to
intervene by HP and Trustmark.
07/01/09 J A Cialone, II .20 Emails about court papers.
07/01/09 T S Durst 4.40 Analysis of insurance issues and motion filed by Holt;
conference with SEC regarding same; communications with
client regarding work on
REDACTED REDACTED
conference with court
regarding pending matters.
07/01/09 J S Fitzwater 5.50 Updating the Pleadings pad; updating the Extranet website, as
well as hosted filings regarding searchable text; assisting Sue
Ayers and Katherine Hinton to construct a profile of
intervening motions; monitoring court filings and assisting
337
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 271 of 377
Page 270
Hours Description
attorney team to coordinate reception of filings to appropriate
members; updating the tracking charts of filings entered by the
parties, intervenors and the intervenors' attorney appearances;
organizing case material for attorney review; and assisting Tim
Mountz and Jonathan Rubenstein in researching REDACTED
07/01/09 L C Fluker 1.90 Reviewed portion of Receiver's Response to Motions to
Intervene to determine any additional cites; checked additional
sites (including confirmed accuracy of quoted language) and
noted necessary revisions; conferred with Ellen Reeder and
Katherine Hinton to coordinate document revision; revise
response as necessary.
07/01/09 K W Hinton 5.00 Reviewed and quality-checked record citations; revised
response to motions to intervene; reviewed, supervised and
assisted with preparing Appendices to Motion to Show Cause
and Response to Motions to Intervene; updated deadlines chart;
prepared and e-filed stipulations; communicated with process
server regarding service of complaint to relief defendants;
communicated with D. Arlington regarding same; reviewed
chart on motions to intervene and provided numbers for
response per the request of S. Ayers.
07/01/09 J R Knight 1.30 Negotiated with counsel for the Hunton Parties regarding
possible dismissal or postponement of the appeal or of the
briefing schedule in light of the June 29 order; follow up with
counsel for the SEC and suggested revisions to draft motion.
07/01/09 J R Knight 2.80 Continued working on the appellee's brief, including
REDACTED
07/01/09 M D Kusey 1.00 Logged in mail into correspondence and claims logs.
07/01/09 J B Lawrence 1.60 Draft REDACTED ; edit and revise
07/01/09 E D Reeder 3.50 Completed legal cite-checking of portion of consolidated
response; reviewed entire document for long and short form
citations; input revisions; coordinated with K. Hinton and L.
Fluker regarding completing the cite check.
07/01/09 K M Sadler 3.10 Reviewed issues regarding REDACTED
; reviewed
issues regarding coins release; reviewed and responded to
email from FITS regarding REDACTED ; reviewed
issues regarding REDACTED
; reviewed response to motion to stay; reviewed data
from FTI regarding claims analysis
07/01/09 K Scanlan 2.20 Update deadlines chart; forward new chart; telephone
338
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 272 of 377
Page 271
Hours Description
conference regarding deadlines and related issues and adding
specific filing deadlines from non-SEC case to the SEC
deadlines chart when the matters are related; update master
calendar; update Tim Durst calendar.
07/01/09 M C Wood 9.00 Researched REDACTED
Revised REDACTED per Sue Ayers's comments; Assembled
REDACTED ; Began researching REDACTED
07/01/09 R H Wood .90 Researched REDACTED
07/02/09 D T Arlington 2.30 Finalized and forwarded agreement to Quilling regarding coins
motion; followed up regarding same; telephone conferences
with counsel for secured creditor regarding sale of property and
related motion; reviewed and addressed inquiry from counsel
regarding coins account; coordinated regarding service of
financial advisors; reviewed email regarding REDACTED
reviewed terms of agreement with Hunton
appellants; reviewed status of obtaining account data from
Toronto Dominion
07/02/09 S A D Ayers 2.40 Telephone conference with Pershing and outside counsel
regarding Wampold case; telephone conference with members
of receiver's team regarding REDACTED
telephone conference with counsel to Allen
Stanford and review of motion to amend Receivership Order;
telephone conference with clerk at Fifth Circuit regarding join
motion to abate.
07/02/09 T S Durst 1.60 Analysis of issues regarding REDACTED
;
review, revise and finalize REDACTED
07/02/09 J S Fitzwater 3.30 Organizing case material for attorney review; updating
litigation pleadings pads for related Stanford matters;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Extranet website, as well as hosted filings
regarding searchable text; assisting John Lawrence to prepare
the Receiver's Response to Stanford's Motion to Stay
Receivership Proceedings (Dkt. No. 554) for filing; updating
the tracking charts of filings entered by the parties, intervenors
and the intervenors' attorney appearances; and updating the
Pleadings pad.
07/02/09 J R Knight 2.10 Negotiated agreement with counsel for the Hunton Parties and
for the SEC to request postponement of Fifth Circuit briefing
339
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 273 of 377
Page 272
Hours Description
schedule in light of the June 29 order and possible changes in
the freeze with respect to the Hunton Parties; revised and
executed joint motion.
07/02/09 J R Knight 2.20 Continued work on appellee's brief; REDACTED
.
07/02/09 M D Kusey 4.30 Researched and obtained original correspondence from
Northern Trust and sent the same to Bill Cominsky to be
forward to FITS; logged in mail into correspondence and
claims logs.
07/02/09 K M Sadler 3.80 Reviewed information from FTI regarding account analysis
regarding clawback claims; reviewed issues regarding investor
accounts; reviewed issues regarding resolution of motion to
release coins held at SCB; conference with M. Lovett and
financial team and Arlington, Ayers regarding REDACTED
; reviewed
REDACTED
emails to Ayers
regarding ; reviewed issues regarding TD bank data
REDACTED
production; reviewed letters from FNRA regarding requests for
information
07/02/09 M C Wood 7.50 Located REDACTED
; Researched REDACTED
; Researched REDACTED
.
07/03/09 S A D Ayers 2.10 Responded to inquires from Joe Knight in regard to
REDACTED ; supervised research conducted on
REDACTED
; responded to
correspondence (mail and email) on a
REDACTED
, inquiries from lawyers for account holders
regarding the procedure for filing a claim.
07/03/09 B A Day .50 Reviewed documents filed by the SEC for
REDACTED
; reviewed
account holders' accounts for partial, full, or de minimis
releases.
07/03/09 T S Durst 2.90 Further analysis of insurance issues; call with opposing counsel
and team regarding same; work on REDACTED
; follow-up analysis on
Stanford motion to compel.
07/03/09 J R Knight 5.20 Worked on the appellee's brief REDACTED
340
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 274 of 377
Page 273
Hours Description
REDACTED .
07/03/09 W F Stutts, Jr. .80 Worked on REDACTED
briefly communicated with Ms. Ayers.
07/03/09 M C Wood 5.00 Researched REDACTED
Began reviewing REDACTED
07/04/09 S A D Ayers .50 Located pleadings in Troice case, reviewed and circulated to
trial attorney at request of Kevin Sadler.
07/04/09 W F Stutts, Jr. .80 Reviewed information related to REDACTED
07/04/09 M C Wood 6.40 Continued researching REDACTED
Began researching REDACTED
Searched
REDACTED Began drafting a memo REDACTED
07/05/09 D T Arlington .70 Reviewed and addressed proposal regarding resolution of
Bukrinsky motion
07/05/09 S A D Ayers 3.00 Analyzed proposal from Bukrinsky movants' attorney;
responded to email inquiries from Kevin Sadler on REDACTED
; supervised research
on claims against relief defendants REDACTED
07/05/09 B A Day 1.50 Reviewed documents filed by the SEC for REDACTED
07/05/09 J R Knight 4.00 Drafted argument that REDACTED
07/05/09 K M Sadler 2.80 Reviewed issues regarding Bukrinsky motion and proposal
regarding creditors committee; reviewed issues regarding
Hunton appeal; reviewed issues regarding pending motions and
responses due; reviewed issues regarding show cause motion
regarding property dispute; reviewed issues regarding
complaint against insurance brokerage firm
07/05/09 E A Soderlund 1.40 Review proposal from P. Morgenstern regarding Bukrinsky
motion, report and comment on same, and REDACTED
with K. Sadler, S. Ayers, T. Davis, and D.
341
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 275 of 377
Page 274
Hours Description
Arlington for REDACTED
07/05/09 M C Wood 8.90 Continued researching REDACTED
Researched REDACTED
Researched REDACTED
Continued drafting a memo
containing REDACTED Researched REDACTED
07/06/09 C N Adams 1.80 Telephone conference with working group regarding litigation
issues with respect to Vantis; reviewing REDACTED
telephone conference with group
regarding REDACTED
07/06/09 D T Arlington 4.90 Finalized agreement with Michael Quilling regarding motion to
compel release of coins; coordinated regarding service on relief
defendants; prepared response to coin customer inquiry;
reviewed recent filings; addressed issues relating to Latin
American accounts; addressed analysis of claw back claims
07/06/09 S A D Ayers 7.60 Analyzed data on CD redemptions, RD claims
REDACTED edited contempt motion regarding
Randi Stanford; conducted research regarding REDACTED
07/06/09 M E Burnett 2.30 Searched for and provided REDACTED
for Sue Ayers.
07/06/09 B A Day 6.30 Reviewed documents filed by the SEC for REDACTED
07/06/09 T S Durst 4.70 Attention to issues regarding motions by Davis and Stanford to
join Holt motion on insurance proceeds; several telephone
conferences with opposing counsel regarding same and
communications with team regarding analysis of
REDACTED
REDACTED and communications
with Mr. Sadler regarding attention to issues regarding
REDACTED
REDACTED
07/06/09 J S Fitzwater 7.80 Organizing case material for attorney review; updating the
Pleadings pad and pleadings indices in the Stanford matter;
updating the Extranet website, as well as hosted filings
regarding searchable text; assembling pleadings pads for
related litigation; updating hard and electronic correspondence;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
342
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 276 of 377
Page 275
Hours Description
updating support files for the litigation team; updating (non-
pleading) intercorrelating discovery; and updating the tracking
charts of filings entered by the parties, intervenors and the
intervenors' attorney appearances.
07/06/09 J R Knight 2.40 Completed and circulated first draft of the appellee's brief;
began revising draft REDACTED
07/06/09 J R Knight .30 Analyzed REDACTED
07/06/09 T M Moratto Jr. .80 Per K. Hinton, for S. Ayers, searched REDACTED
07/06/09 K M Sadler 7.80 Consultations with Receiver regarding REDACTED
conferences with BB team regarding REDACTED ; reviewed
issues regarding investor claims; reviewed issues regarding
Examiner inquiries; reviewed Hunton appeal brief; emails
to/from Knight and Ayers regarding reviewed
REDACTED
information from FTI; conference with M. Lovett regarding
REDACTED reviewed pleadings received;
emails to Scanlan regarding REDACTED reviewed issues
regarding secured creditor motion regarding Davis; emails
to/from Durst regarding REDACTED ; reviewed issues
regarding REDACTED
emails to/from K. Schlanger regarding REDACTED
reviewed and revised REDACTED
07/06/09 K Scanlan 6.00 Office conference with John Lawrence regarding
REDACTED
update litigation chart; REDACTED
office conference with
Jonathan Rubenstein regarding REDACTED
pull
REDACTED for Tim Mountz; brief office conference
with Tim Mountz regarding REDACTED
07/06/09 M C Wood 9.00 Researched REDACTED
Researched REDACTED
Researched REDACTED
REDACTED
Researched
Researched
REDACTED
343
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 277 of 377
Page 276
Hours Description
Updated REDACTED
memo to reflect research findings
on REDACTED ; Drafted an introduction to the memo REDACTED
07/06/09 R H Wood 3.90 Researched REDACTED
; researched REDACTED
.
07/06/09 A F York 2.60 Reviewed evidence supporting SEC complaint
REDACTED
07/07/09 D T Arlington 4.00 Corresponded with counsel for Turner/Equus regarding
withdrawal of motion; coordinated with team regarding
REDACTED coordinated regarding service
on relief defendants; reviewed research regarding REDACTED
07/07/09 S A D Ayers 8.10 Conducted research and data for new complaint and motion
against relief defendants on REDACTED
attention to U.S. suit in rem against coin and
cash.
07/07/09 J A Cialone, II .50 Attention to draft and filed court papers; attention to Stanford's
motion for release of funds for defense; related calls.
07/07/09 B A Day 6.20 Reviewed documents filed by the SEC for REDACTED
07/07/09 T S Durst 1.70 Work on response to insurance motion and conference with
team and opposing counsel regarding same; attention to issues
regarding coins and bullion and necessary filings; attention to
upcoming deadlines and filings.
07/07/09 J S Fitzwater 8.50 Continuing to organize case material for attorney review;
continuing to update the Pleadings pad and pleadings indices in
the Stanford matter; continuing to update the Extranet website,
as well as hosted filings regarding searchable text; continuing
to assemble pleadings pads for related litigation; continuing to
update hard and electronic correspondence; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; continuing to update support
files for the litigation team; assisting Kristie Blumenschein
regarding REDACTED ; continuing to
update (non-pleading) intercorrelating discovery; and
continuing to update the tracking charts of filings entered by
344
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 278 of 377
Page 277
Hours Description
the parties, intervenors and the intervenors' attorney
appearances.
07/07/09 J R Knight 2.00 Analyzed REDACTED and began revising draft brief.
07/07/09 J R Knight 1.40 Analyzed letter from the Fifth Circuit, negotiated with counsel
for the Hunton Parties and for the SEC, revised and agreed to
joint response.
07/07/09 J R Knight .80 Analyzed June 29 order and assessed REDACTED
07/07/09 K M Sadler 3.20 Reviewed issues regarding Hunton appeal; reviewed joint brief;
reviewed letter from Court regarding supplemental briefing;
reviewed communications from counsel for brokers
07/07/09 K Scanlan 7.50 Continue to review all lawsuits and all claims charts to
REDACTED ; office conference with John
Lawrence concerning REDACTED
expand various charts to REDACTED
; update charts; create new chart to simplify claims by
party; receiver various summons from Austin and have
stamped, signed and sealed by District Clerk; scan copies for
Austin to file on ECF and forward to defendant's counsel;
prepare package for Austin with originals for file; update
deadlines chart; REDACTED for John Lawrence.
07/07/09 M C Wood 3.70 Finished drafting REDACTED memo for Kevin Sadler; Meeting
with Sue Ayers to discuss REDACTED
Sent email to Ayers
discussing REDACTED
07/07/09 R H Wood 6.60 Researched REDACTED
researched
REDACTED
researched REDACTED
wrote
up analysis on these issues and forwarded it to Bob Howell.
07/07/09 A F York 4.50 Prepared stipulations for partial account releases; reviewed
evidence supporting SEC complaint for REDACTED
07/08/09 D T Arlington 5.90 Addressed issues relating to REDACTED
conferences with team regarding coordinated regarding
REDACTED
service on relief defendants; reviewed materials relating to coin
forfeiture case; telephone conference with investor counsel
regarding motion to intervene; reviewed research and emails
345
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 279 of 377
Page 278
Hours Description
regarding REDACTED ; coordinated with team
regarding REDACTED ; prepared REDACTED
07/08/09 S A D Ayers 6.30 Drafted REDACTED
; analyzed data
regarding claims against relief defendants.
07/08/09 B A Day 7.10 Reviewed documents filed by the SEC for REDACTED
07/08/09 T S Durst 1.40 Work on brief regarding REDACTED
; follow-on issues
regarding REDACTED conference with co-counsel
regarding pending items.
07/08/09 J S Fitzwater 3.80 Updating tracking charts of filings entered by the parties and
intervenors; updating the Pleadings pad; updating the Extranet
website, as well as hosted filings regarding searchable text;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members; and
organizing case material for attorney review.
07/08/09 K W Hinton 6.10 Drafted summonses for baseball players and financial advisors;
coordinated issuing of summonses with K. Scanlan; researched
fees for summons; reviewed REDACTED
and
responded to M. Myers request regarding quality-
REDACTED
checked redactions; drafted emails to D. Arlington with
REDACTED .
07/08/09 J R Knight 1.20 Performed enough work on the brief to REDACTED
07/08/09 R C Lewis .60 Reviewed and commented on REDACTED ; phone
conference with John Greer regarding REDACTED
07/08/09 K M Sadler 9.80 Reviewed REDACTED ;
conference with financial team regarding REDACTED
conference with FTI regarding
REDACTED ; reviewed motions received; reviewed and
revised REDACTED ; reviewed
account analysis reports; reviewed issues regarding REDACTED
REDACTED ; reviewed letter from counsel for investor; reviewed
brief filed by Examiner regarding Chap 15 issues; conference
with Arlington and Ayers regarding REDACTED
; reviewed correspondence from attorney
for brokers; reviewed REDACTED and email to M. Lena
and K. Van Tassel regarding reviewed issues regarding
REDACTED
REDACTED
07/08/09 K Scanlan 5.80 Review e-mail from Austin regarding summons for various
346
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 280 of 377
Page 279
Hours Description
financial advisors and other relief defendants; coordinate with
clerk's office to get summons signed and sealed; review e-mail
regarding status and relevant dates of replies in opposition to
various real estate related motions; pull REDACTED
and prepare REDACTED format and distribute
REDACTED to team; review e-mail from John Lawrence
regarding REDACTED
as requested by John Lawrence; office conference with John
Lawrence to REDACTED
; review second set
of summons from Austin and prepare for district clerk;
coordinate getting signatures on all summons; scan summons
and forward scans to Austin; prepare package of summons set
1 and summons set 2 and send to Austin.
07/08/09 E A Soderlund .60 Prepare and distribute internally a REDACTED
07/08/09 M C Wood 3.00 Began drafting motion to freeze assets of relief defendants;
Reviewed REDACTED to include in
the motion.
07/08/09 A F York 2.40 Reviewed evidence supporting SEC complaint for
REDACTED
07/09/09 D T Arlington 4.10 Prepared acceptances of service for multiple relief defendants;
coordinated regarding preparation of motion relating to release
of coins and bullion; addressed warrant relating to coin seizure;
conference with account team regarding reports to examiner;
telephone conferences with counsel for investors regarding
same; worked on additional relief defendant complaints;
coordinated with team regarding REDACTED
07/09/09 S A D Ayers 5.60 Analyzed data regarding CD proceeds for new complaint and
motion for freeze; finalized and served letter in Wampold case
regarding removal and transfer.
07/09/09 J A Cialone, II 1.10 Extended call with Edmunson at SEC; call with Romero at
SEC; considered REDACTED
07/09/09 B A Day 11.00 Reviewed documents filed by the SEC for REDACTED
drafted memo
containing results of such review; reviewed account holders'
accounts for partial, full, or de minimis releases; reviewed and
analyzed documents relating to such releases and conferred
with financial team.
07/09/09 T S Durst 4.80 Review and revise REDACTED and attention to issues
347
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 281 of 377
Page 280
Hours Description
regarding REDACTED ; outlining
REDACTED and conference with team and co-counsel;
communications with opposing counsel.
07/09/09 J S Fitzwater 5.00 Assembling pleadings pads for related litigation; updating the
tracking charts of filings entered by the parties and the
Pleadings pad in the Stanford matter; updating the Extranet
website, as well as hosted filings regarding searchable text;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
organizing case material for attorney review; updating hard and
electronic correspondence; and updating (non-pleading)
intercorrelating discovery.
07/09/09 J R Knight 1.70 Analyzed REDACTED analyzed the
ruling and completed existing work REDACTED
; assisted with REDACTED
07/09/09 R C Lewis .30 Phone call with John Greer regarding REDACTED
reviewed comments related to REDACTED
07/09/09 K M Sadler 10.40 Reviewed issues regarding REDACTED
reviewed issues regarding broker claim (Ulloa);
reviewed draft reports regarding account release and review;
reviewed cases and memo regarding REDACTED ; reviewed
letter brief to court regarding LA. case involving Pershing;
reviewed issues regarding REDACTED
conference with Ayers and Arlington
regarding REDACTED conference with court
staff regarding pending motion to amend OAR; reviewed status
of tasks under way at FTI; reviewed and revised
REDACTED
separate conferences with Cialone and Howell
regarding REDACTEDconference with financial team; conference
with regarding REDACTED
reviewed issues with Arlington and Roper
regarding REDACTED ; reviewed draft
pleading received from Little
07/09/09 K Scanlan 3.90 Office conference with John Lawrence regarding REDACTED
review REDACTED from
John Lawrence and pull REDACTED
; update charts with revisions.
07/09/09 M C Wood 6.20 Continued drafting REDACTED
Researched REDACTED
07/09/09 A F York 7.80 Worked directly with FITS, FTI, and Stanford teams on
account release process; calls and emails to account holders
348
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 282 of 377
Page 281
Hours Description
regarding same; reviewed and analyzed account release
applications and summaries; prepared stipulations for partial
account releases; reviewed evidence supporting SEC complaint
for REDACTED
prepared memo regarding REDACTED
07/10/09 D T Arlington 4.90 Reviewed examiner's fee application; prepared relief defendant
complaint against Hunton parties; reviewed background
materials relating to REDACTED ; participated
in update call with FTI; addressed media inquiry; further
addressed coin forfeiture action; telephone conference with
U.S. attorneys' office regarding same; addressed issues relating
to discovery from Hunton & Williams; prepared email to
counsel for Singapore and Haddad.
07/10/09 S A D Ayers 6.80 Analyzed data regarding CD proceeds; telephone conference
with Patton Boggs regarding motion to amend Receivership
Order; edited complaint in Janvey v. Letsos; edited motion for
freeze order against relief defendants; attention to requests for
information from Receiver.
07/10/09 J A Cialone, II .40 Emails with SEC about meeting next week.
07/10/09 T S Durst 2.50 Work on REDACTED ; attention to examiner fee
request; review of new filings and consideration of responses to
same; conference with client, co-counsel and team regarding
REDACTED ; call to opposing counsel.
07/10/09 J S Fitzwater 5.50 Completing assembly and updating of pleadings pads for
related litigation; updating the Pleadings pad and pleadings
indices in the Stanford matter; updating tracking charts of
filings entered by the parties and intervenors; updating support
files for the litigation team; office conference with Kevin
Scanlan regarding forthcoming pleadings and filings; updating
the Extranet website, as well as hosted filings regarding
searchable text; and monitoring court filings and assisting
attorney team to coordinate reception of filings to appropriate
members.
07/10/09 K W Hinton 7.80 Supervised and assisted with searches regarding 754 notices;
reviewed case information and updated chart regarding same;
supervised and assisted updating shared drive; met with S.
Ayers regarding REDACTED ; reviewed and assessed
foreign filings; drafted email to S. Ayers with REDACTED
07/10/09 J R Knight .40 Assisted with REDACTED
07/10/09 R C Lewis 2.80 Conference with Sam Cooper regarding REDACTED
; revised REDACTED ; reviewed and
349
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 283 of 377
Page 282
Hours Description
revised REDACTED ; phone conference
with John Greer concerning REDACTED
07/10/09 K M Sadler 9.80 Reviewed fee application filed by examiner; consultations with
receiver; conference with Examiner; reviewed issues regarding
coin and Bullion release motion; reviewed issues regarding
account release and review; conference with FTI regarding
REDACTED ; conference with Arlington regarding
REDACTED reviewed issues regarding
REDACTED ; emails to Receiver regarding
reviewed issues regarding SEI accounts; reviewed
REDACTED
pleadings received; reviewed issues regarding RAS request for
conference on pending motion; reviewed subpoena and notice
of deposition; reviewed issues regarding Coins and Bullion
lawsuit
07/10/09 K Scanlan 3.50 Review e-mail from Kevin Sadler and forward requested
information; update deadlines chart and forward to all team
members; update pending matters chart; review Trustmark
matters and calendar all Trustmark deadlines in all cases and
add to SEC deadlines chart; update interventions chart; assist in
filing and updating the non-SEC case files.
07/10/09 M C Wood 3.00 Finished drafting and proofreading motion for order freezing
assets of relief defendants.
07/11/09 D T Arlington 1.50 Prepared for and participated in call with Karyl Van Tassel
regarding REDACTED
07/11/09 S A D Ayers 3.80 Responded to miscellaneous inquiries from Kevin Sadler
regarding REDACTED
07/11/09 K M Sadler 2.30 Reviewed FTI data; reviewed pleadings and correspondence
received regarding various issues
07/12/09 D T Arlington 2.10 Reviewed draft motion to freeze; reviewed information
regarding Hunton agreement; reviewed other data for filings;
worked on REDACTED
07/12/09 S A D Ayers 4.20 Reviewed motion for new freeze regarding relief defendants'
accounts.
07/12/09 T S Durst .80 Further analysis of REDACTED and work on REDACTED
07/13/09 D T Arlington 9.90 Corresponded with counsel for Singapore and Milan regarding
response to motion to intervene; prepared response to motion;
exchanged email with counsel for Cisco assignee regarding
party substitution; worked on REDACTED addressed
Examiner inquiries; addressed relief defendant service issues;
prepared email to SEC regarding Hunton complaint; reviewed
350
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 284 of 377
Page 283
Hours Description
motion regarding coins and bullion; prepared and
communicated comments to same.
07/13/09 S A D Ayers 5.50 Communications regarding REDACTED ;
communications with attorney for Randi Stanford to confer
regarding condominium; attention to new lawsuit filed against
Antigua; reviewing conflicts reports on relief defendants and
banks; attention to subpoenas for information regarding CD
proceeds.
07/13/09 J L Cafferty .30 Researched issues related to REDACTED
07/13/09 J A Cialone, II 1.80 Prepared for and participated in extended meeting with SEC at
company offices; various follow-up calls and emails.
07/13/09 T S Durst .70 Work on REDACTED ; communications with
client, co-counsel and team regarding REDACTED
07/13/09 J S Fitzwater 5.80 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Extranet website, as well as hosted filings
regarding searchable text; updating pleadings pads for the '298
Stanford matter; updating pleadings pads for litigation related
to the Receiver and the Stanford parties; assembling case
material for attorney review; and updating tracking charts of
filings entered by the Parties and intervenors.
07/13/09 K M Sadler 10.20 Reviewed issues regarding response to investor motion
(Singapore/Milan); reviewed communications from client
regarding reviewed and finalized Hunton (Letsos) RD
REDACTED
complaint; drafted memo to client regarding REDACTED
reviewed pleadings regarding Trustmark Intervention;
reviewed class action complaint; reviewed issues related to
REDACTED ; SIPC issues; FTI work related to RD
complaints; response to FNRA letters; reviewed information
regarding proposed motion to sell boats; conference with
Examiner regarding SIPC issues; reviewed REDACTED
; reviewed issues regarding CDP
submission; reviewed issues regarding account review and
release status; reviewed and commented on draft letter to
Bukrinsky movants counsel; reviewed issues regarding status
of SEI accounts.
07/13/09 E A Soderlund 2.40 Revise and edit REDACTED
07/13/09 M C Wood 6.10 Conferences with Katherine Hinton and Thomas Moratto
regarding new 754 filings in district courts; Gathered
information about how to making 754 filings in district courts
351
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 285 of 377
Page 284
Hours Description
around the country.
07/14/09 D T Arlington 9.80 Worked on motion regarding coins and bullion; reviewed
information regarding sale of Little Eagle; addressed Hunton
account release issues; addressed inquiry from recipient of
political contributions from Stanford; addressed relief
defendant service issues; telephone conference with team
regarding REDACTED worked on REDACTED
07/14/09 S A D Ayers 7.00 Finalized, conferred and filed motion for contempt against
Randi Stanford; analyzed CD proceeds data; reviewed
REDACTED reviewed conflicts reports on relief
defendants and bank.
07/14/09 M E Burnett .50 Searched for and provided copies of filings for Sue Ayers.
07/14/09 M E Burnett .30 Provided list of registered agents for specified companies for
Andrew York.
07/14/09 B A Day 4.50 Discussed background factual information with David
Arlington and Ben Krage for
REDACTED revised REDACTED
07/14/09 T S Durst 2.00 Analysis of REDACTED
comments on brief; analysis of REDACTED
communications with co-counsel, team and client
regarding attention to issues regarding other pending
REDACTED
motions.
07/14/09 J S Fitzwater 1.20 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating hosted filings on the Extranet website; and updating
pleadings indices in the '298 Stanford matter.
07/14/09 R C Lewis .60 Conference regarding REDACTED
revised REDACTED
07/14/09 K M Sadler 10.40 Reviewed and commented on motion and order regarding RD
issues; reviewed information from FTI; conference with FTI
regarding REDACTED ; reviewed
information from REDACTED
; reviewed and provided comments on
REDACTED ; reviewed issues regarding
REDACTED
reviewed issues regarding response to motion to release
accounts filed by Singapore/Milan; consultations with client
regarding REDACTED ; reviewed and commented on
REDACTED ; reviewed issues regarding motion for
contempt regarding Randi Stanford property; conference with
352
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 286 of 377
Page 285
Hours Description
Patton Boggs regarding motion to extend reply date; reviewed
correspondence regarding REDACTED ; reviewed issues
regarding REDACTED
07/14/09 K Scanlan 1.60 Review e-mail from Austin and provide requested documents;
update various charts; create new files for new Federal cases.
07/14/09 M C Wood 6.00 Prepared for the upcoming filing of receivership paperwork in
20 district courts by drafting cover letters to each court,
completing new case forms, and drafting email instructions to
the process servers.
07/14/09 A F York 4.40 Reviewed bank transfer data from FTI; prepared
REDACTED
review of REDACTED
preparations for REDACTED further review of issues with
754 filings.
07/15/09 D T Arlington 7.70 Continued working on REDACTED ; telephone conference
with FTI regarding REDACTED worked on Hunton complaint;
addressed REDACTED ; reviewed HP reply brief; addressed
relief defendant service issues.
07/15/09 S A D Ayers 5.80 Edited and filed complaint in Janvey v. Letsos; reviewed James
Davis plea agreement; reviewed, conferred and filed motion to
retain private equity consultant; edited motion and order for
freeze on assets of relief defendants.
07/15/09 J A Cialone, II .80 Reviewed draft court papers.
07/15/09 T S Durst 1.50 Work on REDACTED
attention to
new filings and needed responses to same.
07/15/09 J S Fitzwater 1.80 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating hosted filings on the Extranet website; and updating
pleadings indices in the '298 Stanford matter.
07/15/09 R C Lewis .50 Revised REDACTED
prepared REDACTED
07/15/09 K M Sadler 9.30 Reviewed CD proceeds information from FTI; reviewed and
revised draft motion to impose freeze; reviewed pleadings
received; reviewed and revised draft Order, reviewed issues
regarding RD complaint and brief; reviewed REDACTED
with Arlington; reviewed pleadings received;
conference with counsel for class action lead plaintiff motion;
reviewed pleadings received
07/15/09 V R Walker .60 Assembled and organized court papers, vital documents and
353
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 287 of 377
Page 286
Hours Description
correspondence.
07/15/09 M C Wood 2.00 Finished contacting district courts and preparing paperwork for
our upcoming filings pursuant to 28 USC 754; Contacted the
New York district court to determine whether our previous 754
paperwork had been properly filed.
07/15/09 A F York 6.70 Reviewed bank transfer data from FTI; prepared
REDACTED
calls and emails with account holders and
FTI/FITS/Stanford Eagle regarding account releases; reviewed
REDACTED
07/16/09 D T Arlington 5.70 Worked on REDACTED reviewed REDACTED
addressed motion regarding release of Latin
American accounts; reviewed inquires from account holder
counsel; worked on relief defendant service issues; addressed
coin motion; responded to inquiry from state regulator.
07/16/09 S A D Ayers 6.30 REDACTED for memorandum to
Receiver; edited REDACTED drafted
supplemental relief defendant complaint; filed motion to hire
private equity advisor; telephone conference Jackie Scott,
counsel to Hunton parties.
07/16/09 T S Durst .80 Review and comment on REDACTED
attention to clawback pleadings.
07/16/09 J S Fitzwater 1.50 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating hosted filings on the Extranet website; and updating
pleadings indices in the '298 Stanford matter.
07/16/09 R C Lewis 1.90 Conference with Katherine Roland regarding REDACTED
reviewed and revised reviewed and revised
REDACTED
REDACTED
07/16/09 K M Sadler 8.80 Reviewed draft motions regarding REDACTED
reviewed and revised pleadings regarding RD complaints;
reviewed information from FTI; reviewed account
review/release issues; consultations with client; reviewed
issues regarding REDACTED
reviewed letter regarding REDACTED
reviewed issues regarding service of Hunton
(Letsos) complaint; conference with Arlington regarding
REDACTED
07/16/09 K Scanlan 4.20 Pull requested materials for review and prepare notebook;
update charts; review e-mail from Tim Mountz and pull
REDACTED review REDACTED
and draft memo on REDACTED
354
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 288 of 377
Page 287
Hours Description
07/16/09 A F York 9.00 Discussed and reviewed REDACTED
prepared
REDACTED calls and emails with account holders and
FTI/FITS/Stanford Eagle regarding account releases; reviewed
REDACTED preparations for REDACTED
reviewed REDACTED
07/17/09 D T Arlington 7.90 Reviewed and worked on REDACTED
reviewed and addressed issues relating to coin
release motion; reviewed DOJ motion to stay; coordinated with
team regarding REDACTED conference call
with FTI regarding REDACTED
07/17/09 S A D Ayers 5.80 Edited complaint, motion and order relating to relief
defendants; edited REDACTED
communicated with Gene Wilshire regarding service in Janvey
v. Letsos.
07/17/09 J A Cialone, II 1.40 Prepared for meeting on Monday at Receiver's office regarding
REDACTED numerous calls and emails
about meeting on Monday.
07/17/09 T S Durst 1.10 Attention to issues regarding Holt's proposed motion and
discovery; follow-up on REDACTED communications with
team regarding REDACTED
07/17/09 J S Fitzwater 2.50 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating hosted filings on the Extranet website; updating
tracking charts of filings entered by the Parties and intervenors;
and updating pleadings pads and indices in the '298 (Stanford
v. SEC) and '1329 (Janvey v. Letsos) matters.
07/17/09 M D Kusey 4.00 Logged in mail into correspondence and claims logs.
07/17/09 R C Lewis 1.50 Reviewed and revised REDACTED drafted
REDACTED reviewed and revised REDACTED
07/17/09 K M Sadler 9.40 Reviewed issues regarding reply brief on disqualification and
communications with opposing counsel; reviewed and revised
various pleadings regarding RD complaint; drafted email to
client regarding conference with FTI regarding
REDACTED
conference with M. Lovett regarding
REDACTED conference with counsel for creditor regarding
intervention and opposition to sales procedure motion;
reviewed coins motion; reviewed emails from Examiner and K.
Blumenschein regarding coins motion timetable; conferences
with Ayers and Arlington regarding REDACTED
355
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 289 of 377
Page 288
Hours Description
REDACTED reviewed pleadings; correspondence with opposing
counsel (Tillotson) regarding discovery and insurance issues
07/17/09 K Scanlan 1.80 Update charts; review Pacer for deadlines and double check
that all motions removed from list have been cleared by the
court.
07/17/09 A F York 4.50 Discussed REDACTED with FTI and FITS and
reviewed REDACTED
reviewed REDACTED calls with
FTI regarding REDACTED emails with account holders
and FTI/FITS/Stanford Eagle regarding account releases;
reviewed REDACTED
07/18/09 D T Arlington 2.30 Worked on relief defendant complaint.
07/18/09 J A Cialone, II 1.20 Calls and emails throughout the day about REDACTED
07/19/09 D T Arlington 1.50 Worked on relief defendant complaint; addressed Latin
American accounts issue.
07/19/09 S A D Ayers 4.30 Drafted letter to former employee regarding Receivership and
litigation stay; reviewed REDACTED
reviewed
transcript of bond hearing for Allen Stanford; attention to filing
754 notices in districts where relief defendants reside; attention
to REDACTED
07/19/09 J A Cialone, II 1.30 Further preparation for Monday meeting.
07/19/09 K Scanlan 3.20 Locate requested materials on extranet and forward; work on
chart of all pending motions, reply and response dates and days
that each matter has been ripe for decision under Northern
District Rules.
07/19/09 M C Wood 6.10 Reviewed case law regarding REDACTED
Researched
REDACTED ; Began
drafting REDACTED
07/20/09 C N Adams 4.90 Conference with Joe Cialone and Kevin Sadler regarding
REDACTED conference with Ralph Janvey and team
regarding REDACTED reviewing
07/20/09 D T Arlington 6.30 Continued working on amended relief defendant complaint;
worked on motion regarding release of accounts;
communicated with team regarding addressed other
REDACTED
account release issues; coordinated regarding service on relief
defendants; reviewed motion filed by SEC.
356
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 290 of 377
Page 289
Hours Description
07/20/09 S A D Ayers 6.50 Drafting relief defendants complaints, motion to freeze account
held in names of relief defendants and proposed order,
communicating with FTI regarding REDACTED
attention to service on relief defendants in Janvey v. Letsos;
attention to correspondence with outside counsel for Stanford
Development Co.; attention to request from Receiver for
REDACTED
; analyzed SEC's motion to amend Receivership
Order; attention to discovery requests from Laura Holt.
07/20/09 J A Cialone, II 2.80 Prepared for and participated in extended meeting in Receiver's
office with REDACTED
; attention to Patton Boggs motion
and allegations; calls and emails about foregoing.
07/20/09 B A Day 2.20 Coordinated review of conflict-check reports for potential relief
defendants.
07/20/09 J S Fitzwater 5.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating pleadings pads for the '298 Stanford matter and
related litigation; updating the tracking charts of filings entered
by the parties and intervenors; updating support files for the
litigation team and organizing case material for attorney
review; updating hard and electronic correspondence; and
updating the Extranet website, as well as hosted filings
regarding searchable text.
07/20/09 M D Kusey 6.80 Logged in mail into correspondence and claims logs.
07/20/09 J B Lawrence .20 Review Stanford's reply in support of motion to disqualify
Baker Botts.
07/20/09 K M Sadler 9.70 Reviewed issues regarding RD claims; consultations with
Receiver and TK regarding REDACTED ; reviewed
and revised draft pleadings; reviewed account release/review
information; reviewed hearing transcript regarding testimony
by FTI; reviewed draft SEC motion; conference with Receiver
and K. Edmundson of SEC regarding motion; reviewed task
list and motion response deadlines; reviewed motion to
dismiss; reviewed correspondence from investor counsel;
reviewed correspondence from insurer counsel
07/20/09 K Scanlan 9.50 Telephone conference with Kevin Sadler regarding
REDACTED assist in preparation for
Receiver meeting; telephone conference with Katherine Hinton
regarding REDACTED begin downloading
and printing copies of all pleadings in the 09-cv-721 cause of
action and the Canadian proceedings; work on creating
notebooks for Mr. Janvey for REDACTED
357
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 291 of 377
Page 290
Hours Description
office conference with Kevin Sadler regarding
REDACTED continue work on
new chart for all matters before the court and dates of all
responses and replies and status under the NDTX rules..
07/20/09 N M Starbuck 1.00 Searched production files for REDACTED
07/20/09 M C Wood 9.80 Researched the court's local rules on briefing; Researched
REDACTED ;
Researched REDACTED
Continued drafting REDACTED
Reviewed REDACTED
Conference with Sue
Ayers regarding REDACTED
07/21/09 D T Arlington 7.30 Reviewed motion filed by examiner and related email;
continued working on pleadings relating to claw-back claims;
prepared analysis of Examiner's filing; telephone conference
with FTI regarding REDACTED ; worked on REDACTED
; addressed account release issues; reviewed issues
relating to coins motion; addressed issues relating to property
sale motions; telephone conference with Kim Schlanger and
Eric Soderland regarding reviewed status of Turner coins
REDACTED
account; coordinated regarding REDACTED ;
addressed relief defendant service issues; telephone conference
with Kevin Sadler regarding REDACTED
07/21/09 S A D Ayers 8.00 Drafted relief defendant complaint; conferred and file motion
to sell private equity; analyzed SEC and Examiner motions
regarding claw back claims.
07/21/09 J A Cialone, II 1.00 Reviewed REDACTED ; related internal
calls and emails; reviewed and considered
REDACTED conference call with BB
team.
07/21/09 B A Day 2.10 Coordinated review of conflict-check reports for potential relief
defendants; reviewed same.
07/21/09 T S Durst .50 Review and respond to correspondence from team/client on
REDACTED
07/21/09 J S Fitzwater 4.30 Continuing to update support files for the litigation team and
organizing case material for attorney review; updating the
Extranet website, as well as hosted filings regarding searchable
text; updating (non-pleading) intercorrelating discovery and
organizing case material for attorney review; updating
pleadings indices in the '298 (Stanford v. SEC) matter;
updating the pleadings pad in the '1329 (Janvey v. Letsos)
358
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 292 of 377
Page 291
Hours Description
matter; monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Appearances from Attorneys for the Intervenors
notebook; and updating the tracking charts of filings entered by
the parties and intervenors.
07/21/09 L C Fluker 1.50 Reviewed Excel spreadsheet tracking communications to locate
all Stanford customers (including account holders, gold bullion
purchasers) who have indicated retention of counsel; created
chart containing customer name, counsel name and address;
provided chart to secretary for use in preparing complaint
against relief defendants.
07/21/09 K M Sadler 10.40 Conference with officials at FNRA; reviewed correspondence
from FNRA; conference with Cialone and opposing counsel
regarding D&O coverage; reviewed REDACTED
reviewed information
regarding REDACTED and forwarded same to
Cooper; reviewed pleadings received; reviewed filing by
Examiner and Motion to Dismiss (Singapore); consultations
with client regarding REDACTED reviewed issues
regarding REDACTED
correspondence with investor counsel (Quilling) regarding
motions filed; reviewed FTI information regarding Coins and
Bullion issues; reviewed draft declaration of KVT
07/21/09 K Scanlan 5.50 Continue preparing materials for Mr. Janvey relating to
REDACTED
07/21/09 M C Wood 2.50 Finished drafting and proofreading motion for summary
proceedings; Drafted a proposed order to attach to the motion.
07/21/09 R H Wood 2.10 Reviewed conflict checks of proposed relief defendants;
performed analysis on same and cleared proposed lists.
07/21/09 A F York 4.50 Reviewed conflicts for relief defendant complaint; analyze and
respond to account holder inquiries; calls with Stanford Eagle
and FITS regarding account holder issues; call with account
holder in Spanish; preparations for relief defendant complaint.
07/22/09 D T Arlington 12.70 Reviewed SEC motion, Examiner's response and motion to
dismiss filed by Milan and Singapore; researched regarding
responses to same; prepared REDACTED
; telephone conferences with team
regarding REDACTED prepared REDACTED
07/22/09 S A D Ayers 4.60 Conference with Ralph Janvey regarding REDACTED
drafted relief defendant complaint; analyzed evidence in
support thereof.
07/22/09 M E Burnett .30 Provided copies of filings for David Arlington.
359
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 293 of 377
Page 292
Hours Description
07/22/09 J A Cialone, II 1.40 Prepared for meeting in Dallas tomorrow to discuss
REDACTED
07/22/09 B A Day 4.40 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
to Karyl Van Tassel's declaration.
07/22/09 J S Fitzwater 5.80 Updating the pleadings pads and indices for all filings entered
in the '298 Stanford matter; updating the Extranet website, as
well as hosted filings regarding searchable text; assembling
pleadings pads for related litigation; office conference with
Kevin Scanlan regarding distribution of correspondence and
filings to litigation team; monitoring court filings and assisting
attorney team to coordinate reception of filings to appropriate
members; continuing to update (non-pleading) intercorrelating
discovery; continuing to update support files for the litigation
team and organize case material for attorney review; and
updating the tracking charts of filings entered by the parties,
intervenors and the intervenors' attorney appearances.
07/22/09 J R Knight .40 Consulted with Kevin Sadler regarding REDACTED
07/22/09 M D Kusey 4.00 Logged in mail into correspondence and claims logs.
07/22/09 R C Lewis 1.00 Reviewed REDACTED reviewed and
commented on REDACTED
07/22/09 K M Sadler 11.30 Consultations with Receiver; reviewed and revised draft
pleadings; reviewed REDACTED
reviewed information from FTI regarding account analysis;
conferences with Ayers and Arlington regarding REDACTED
REDACTED ; reviewed information regarding
coin customer with account frozen at Pershing; reviewed draft
motion from Holt counsel; email to Cooper regarding
REDACTED
reviewed cases cited in draft pleadings; reviewed
litigation strategy; reviewed pleadings received; reviewed
issues regarding REDACTED
correspondence with client regarding REDACTED
07/22/09 K Scanlan 6.80 Continue to REDACTED
and create
for Ralph Janvey; prepare REDACTED
and deliver REDACTED to Mr. Janvey's office; brief office
conference with Kristi Blumenschein regarding REDACTED
360
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 294 of 377
Page 293
Hours Description
07/22/09 M C Wood 3.50 Reviewed conflict check reports; Researched REDACTED
Drafted email memo to Sue Ayers
regarding REDACTED
07/22/09 R H Wood 4.10 Reviewed conflicts checks of proposed relief defendants;
cleared lists and passed them on; communicated with S. Ayers
regarding REDACTED prepared REDACTED
07/22/09 A F York 10.20 Reviewed conflict checks for relief defendant complaint;
emails with Stanford Eagle regarding account holders;
reviewed attorney inquiries from account holders; reviewed
REDACTED researched, reviewed, and
summarized REDACTED
located and analyzed REDACTED
per
Sadler; reviewed and made recommendations regarding
REDACTED
07/23/09 C N Adams .50 Reviewing pleadings regarding broker lawsuit.
07/23/09 D T Arlington 10.60 Finalized REDACTED ;
reviewed research relating to REDACTED
coordinated with FTI and team regarding REDACTED
worked on REDACTED worked on amended complaint
and related motions; coordinated with team regarding
REDACTED
07/23/09 S A D Ayers 10.60 Attended meeting in Dallas with Ralph Janvey and Thompson
Knight regarding REDACTED ; drafted complaint, motion
for freeze and summary judgment and proposed orders.
07/23/09 J A Cialone, II 1.20 Prepared for and participated in extended meeting in Dallas
with TK and Receiver about REDACTED .
07/23/09 B A Day 5.70 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
to Karyl Van Tassel's declaration.
07/23/09 J S Fitzwater 1.00 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members, and
updating hosted filings on the Extranet website.
07/23/09 M D Kusey 4.50 Logged in mail into correspondence and claims logs.
07/23/09 R C Lewis 1.60 Reviewed material in anticipation of drafting Response to
SCOA Motion for Hearing; drafted same.
07/23/09 K M Sadler 10.60 Reviewed numerous pleadings received ; consultations with
Receiver and TK; reviewed draft pleadings; reviewed pending
361
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 295 of 377
Page 294
Hours Description
motions and task list; conference with FTI regarding REDACTED ;
reviewed draft motion and issues regarding coin and bullion;
reviewed and revised REDACTED
; reviewed cases cited in motion to dismiss
(Singapore); reviewed REDACTED
07/23/09 K Scanlan 5.20 Continue REDACTED for Mr. Janvey; reformat
REDACTED for downloading
for Mr. Janvey; update deadlines chart; brief telephone
conference regarding REDACTED ; forward requested
materials to John Lawrence; office conference with Jonathan
Rubenstein regarding REDACTED ; continue work
on pending matters chart.
07/23/09 M C Wood 2.30 Reviewed conflicts reports on relief defendants in anticipation
of filing complaints; Revised motion for asset freeze against
relief defendants to add motion for summary judgment.
07/23/09 R H Wood 5.20 Researched case law regarding REDACTED
communicated with D. Arlington regarding REDACTED;
continued to review conflicts checks of proposed relief
defendants; communicated with B. Day regarding REDACTED
07/24/09 D T Arlington 10.80 Worked on amended complaint; coordinated regarding multiple
motion responses; worked on motion to establish summary
proceedings; worked on REDACTED ; conferences with
FTI regarding addressed account release issues;
REDACTED
communicated with team regarding REDACTED
07/24/09 S A D Ayers 13.70 Drafted and filed response to motion for Stanford to certify
annual returns for Antiguan corporations; drafted relief
defendant complaint, freeze motion and summary judgment
and proposed orders.
07/24/09 H M Chappel 1.50 Compiled case law cited in Receiver's Amended Complaint
Naming Relief Defendants and Receiver's Motion for Order
Freezing Assets Held in the Names of Certain Relief
Defendants and Brief in Support Thereof and for Summary
Judgment and Brief in Support Thereof in preparation for cite
check and filing with the court.
07/24/09 J A Cialone, II 1.00 Attention to court papers filed by Stanford opposing sale of
assets.
07/24/09 B A Day 3.20 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
to Karyl Van Tassel's declaration.
07/24/09 T S Durst .80 Review and respond to correspondence from team/client on
362
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 296 of 377
Page 295
Hours Description
REDACTED attention to matters regarding REDACTED
and communications with and directions to
team regarding REDACTED
07/24/09 J S Fitzwater 3.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating hosted filings on the Extranet website; updating
tracking charts of filings entered by the Parties and intervenors;
assisting Russell Lewis to construct a profile of intervening
motions; and updating pleadings indices in the '298 Stanford
and related litigation matters.
07/24/09 L C Fluker .40 Conferred with Katherine Hinton and Ellen Reeder about cite
check of Motion for Order Freezing Assets; reviewing motion
briefly and sent email to Ellen Reeder dividing motion for
review by multiple paralegals.
07/24/09 M D Kusey 2.00 Logged in mail into correspondence and claims logs.
07/24/09 E D Reeder 1.80 Began verifying citations and quotations to legal authorities in
motion to freeze assets.
07/24/09 K M Sadler 11.20 Reviewed pleadings received; reviewed REDACTED
and conference with Ayers regarding
REDACTED conference with FTI regarding REDACTED
conferences with Arlington and others regarding on-going
work; reviewed and commented on complaint; and motions;
conference with Court staff regarding filing; reviewed task list
and pending motions for response; reviewed draft
REDACTED reviewed issues regarding
REDACTED ; correspondence with proposed class action
counsel regarding MDL motion; reviewed pleading regarding
Pershing
07/24/09 K Scanlan 3.50 Update deadlines charts; telephone conference regarding
REDACTED ; additional deadlines
chart updating per meeting; assist in finalizing letter response
to the court regarding response to Stanford motion; hand
deliver response to Judge Godbey.
07/24/09 R H Wood 1.10 Reviewed conflicts checks of proposed relief defendants;
communicated with B. Day regarding the same.
07/24/09 A F York 14.80 Worked directly with FTI in Houston to prepare, revise, and
finalize all schedules and supporting declaration for relief
defendant complaint.
07/25/09 C N Adams .40 Reviewing draft REDACTED
; preparing email
regarding REDACTED
07/25/09 D T Arlington 3.60 Worked on relief defendant complaint and related filings and
363
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 297 of 377
Page 296
Hours Description
motions; conferences with team regarding REDACTED
07/25/09 S A D Ayers 10.40 Edited Complaint, freeze motion and proposed orders
REDACTED responded to
correspondence; drafted letter to clerk for Northern District of
Texas regarding Amended complaint and issuing summonses.
07/25/09 J A Cialone, II 1.20 Reviewed and commented on draft court papers; considered
REDACTED
related calls and emails.
07/25/09 B A Day 3.90 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
to Karyl Van Tassel's declaration.
07/25/09 S A Massad .50 Reviewed and commented on draft clawback filings.
07/25/09 K M Sadler 7.60 Reviewed and revised complaint and motions; reviewed
information from FTI; reviewed declaration; conferences with
Ayers and Arlington regarding REDACTED
07/25/09 K Scanlan 3.50 Review all filed motions and disposition and add to chart; track
all motions with responses and replies and dates motions
became ripe for court review; update charts to include
numerous new motions.
07/25/09 M C Wood 8.30 Checked accuracy of citations in motion for disgorgement;
Searched for REDACTED
drafted cite for the motion for disgorgement.
07/25/09 R H Wood .90 Reviewed conflicts checks of proposed relief defendants;
communicated with B. Day regarding the same.
07/25/09 A F York 12.20 Worked directly with FTI to prepare, revise, and finalize all
schedules and supporting declaration for relief defendant
complaint.
07/26/09 D T Arlington 13.20 Worked on relief defendant complaint and related motions and
filings; reviewed FTI analysis and schedules; conferences with
team regarding REDACTED ; addressed account release
issues.
07/26/09 S A D Ayers .60 Attention to relief defendant complaint; filing 754 notices;
REDACTED
07/26/09 J A Cialone, II 1.30 Reviewed proposed revisions to draft court papers; calls and
emails throughout the day related to REDACTED
07/26/09 B A Day 15.00 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
364
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 298 of 377
Page 297
Hours Description
to Karyl Van Tassel's declaration.
07/26/09 L C Fluker 4.90 Checked cites in assigned section of Motion for Order Freezing
Assets for accuracy and form; conferred with Katherine Hinton
about status of checks; downloaded case law newly added to
motion onto firm's shared drive for future reference; revised
cites in assigned section of motion as necessary; conferred with
Katherine Hinton regarding additional revisions to motion;
checked motion to confirm accuracy of long and short citation,
and made necessary revisions to motion; conferred with Ellen
Reeder and Katherine Hinton about additional revisions to be
completed; provided David Arlington with revision notes.
07/26/09 J B Lawrence 3.50 Analyze SEC motion to modify receivership order, Examiner's
response in support of SEC motion, investors' motion to stay
proceedings, and Singapore/Milan motion to dismiss; research
REDACTED
07/26/09 S A Massad .50 Various e-mail correspondence regarding REDACTED
07/26/09 E D Reeder 3.80 Verified legal citations and quotations in motion for order to
freeze assets; located and pulled additional authorities; reported
to David Arlington.
07/26/09 K M Sadler 9.30 Reviewed and revised complaint, and motions;
communications with client; conferences with Arlington
regarding REDACTED ;
reviewed cases cited in motions; reviewed issues regarding
REDACTED
correspondence to Tillotson regarding issues raised in motion
07/26/09 M C Wood 2.50 Reviewed conflicts reports.
07/26/09 A F York 13.60 Worked directly with FTI to prepare, revise, and finalize all
schedules and supporting declaration for relief defendant
complaint; coordinated same with FITS and Baker Botts team.
07/27/09 D T Arlington 14.70 Worked on relief defendant complaint and related motions and
filings; reviewed FTI analysis and schedules; conferences with
team regarding REDACTED addressed account release
issues; coordinated regarding research issues.
07/27/09 J A Cialone, II .40 Calls and emails related to REDACTED
07/27/09 B A Day 13.00 Coordinated review of conflict-check reports for potential relief
defendants and reviewed same; reviewed and analyzed
documents and data to assist in the creation of draft schedules
to Karyl Van Tassel's declaration; revised Amended
Complaint; coordinated service of filings.
365
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 299 of 377
Page 298
Hours Description
07/27/09 J S Fitzwater 5.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the tracking charts of filings entered by the Parties,
intervenors and the intervenors' attorney appearances; updating
pleadings pads for the '298 (Stanford v. SEC) matter; updating
the Extranet website, as well as hosted filings regarding
searchable text; updating the Appearances from Attorneys for
the Intervenors notebook; and assembling pleadings pads for
related state and federal litigation.
07/27/09 J R Knight .90 Reviewed and suggested revisions to motion to continue freeze
and to adopt summary procedures.
07/27/09 J B Lawrence 8.40 Research, outline, and draft REDACTED
07/27/09 S A Massad 1.50 Reviewed and commented on clawback filings.
07/27/09 E D Reeder 2.70 Finalized assigned portion of legal cite-checking in motion to
freeze assets.
07/27/09 D S Rohleder 1.30 Updated the Shared Drive for all relevant filings related to the
Stanford Matter; Organized and Saved Select documents
relating to State Cases to the Austin Shared Drive for K
Hinton;
07/27/09 K M Sadler 11.40 Reviewed and revised complaint and motions; conference with
Arlington regarding REDACTED ; conference with Court staff
regarding scheduling; reviewed account release/review
information regarding motion; conferences with opposing
counsel regarding motions; reviewed issues regarding Coin &
Bullion motion; conferences with Examiner and counsel for
SEC regarding motions; reviewed FTI data regarding KVT
declaration; reviewed issues regarding responses to SEC and
Examiner motions; reviewed petition regarding Florida case
against Pershing and conference with counsel for plaintiff
07/27/09 K Scanlan 4.50 Review comments to new charts; update pending motions
chart; update 724 pending matters chart; brief memo regarding
REDACTED work on REDACTED
07/27/09 M C Wood 3.10 Reviewed conflict-check reports; Ensured that a report had
been run for every potential relief defendant; Researched
REDACTED
Drafted email memo REDACTED
07/27/09 R H Wood 4.10 Reviewed motions and memo regarding REDACTED
researched case law on
REDACTED
366
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 300 of 377
Page 299
Hours Description
07/27/09 A F York 17.50 Worked directly with FTI to prepare, revise, and finalize all
schedules and supporting declaration for relief defendant
complaint; coordinated same with FITS and Baker Botts team.
07/28/09 D T Arlington 8.80 Worked on relief defendant complaint and related motions and
filings; reviewed FTI analysis and schedules; conferences with
team regarding REDACTED coordinated regarding
filing and service; addressed coin motion issues; addressed
various motion response issues.
07/28/09 J A Cialone, II 1.00 Calls and emails about REDACTED
reviewed clawback documents; reviewed related draft court
papers; reviewed relevant legal authorities.
07/28/09 B A Day 10.00 Reviewed and analyzed documents and data to assist in the
finalization of draft schedules to Karyl Van Tassel's
declaration; revised Amended Complaint; coordinated filings
and service of filings.
07/28/09 T S Durst 1.50 Review of status on REDACTED
communications with team regarding REDACTED
review and revise drafts regarding REDACTED attention to issues
regarding REDACTED
07/28/09 J S Fitzwater 5.50 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating support files for the litigation team; continuing to
assemble pleadings pads for related litigation; updating the
tracking charts of filings entered by the Parties and intervenors;
updating pleadings indices for the '298 (Stanford v. SEC)
matter; updating the pleadings pad in the '1329 (Janvey v.
Letsos) matter; updating the Extranet website; updating hard
and electronic correspondence.
07/28/09 J B Lawrence 5.70 Draft and revise REDACTED
07/28/09 R C Lewis 1.00 Revised REDACTED prepared
REDACTED
07/28/09 S A Massad .70 Reviewed and commented on draft clawback filings.
07/28/09 T M Moratto Jr. .50 Per B. Day, prepared spreadsheet concerning Financial Advisor
sums.
07/28/09 T M Moratto Jr. 1.00 Per K. Hinton, prepared appendix to Receiver's Motion for
Order to Freeze filing.
07/28/09 E D Reeder .30 Assisted Andrew York with formatting of pleadings.
367
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 301 of 377
Page 300
Hours Description
07/28/09 D S Rohleder 5.50 Compared a select list of possible Stanford defendants against
separate lists labeled KVT-4, KVT-5, and KVT-6 for K
Hinton;
07/28/09 K M Sadler 10.80 Reviewed and revised response to SEC Motion and related
Motions; reviewed motions and amended complaint to finalize
for filing; reviewed issues regarding FTI data supporting
complaint; reviewed issues regarding REDACTED
reviewed issues regarding coins &
bullion motion; reviewed correspondence from counsel for
investor RD; reviewed motion for consolidation; reviewed
issue regarding REDACTED ; reviewed information from
FTI related to REDACTED ; reviewed draft response
to motion for hearing; reviewed results of research regarding
REDACTED
07/28/09 K Scanlan 7.50 Review e-mails from Kevin Sadler and David Arlington
concerning REDACTED ; update
charts; prepare short special chart for immediate deadlines;
forward to Austin; review request for materials fro David
Arlington and locate and forward requested materials; draft
REDACTED
; update pending motions chart; forward chart to
Austin for additional review and revisions; office conference
with Tim Durst regarding REDACTED
prepare notebook for Judge Godbey for amended petition in
clawback litigation and additional new pleadings; add Letsos
materials to notebooks; revise REDACTED per David
Arlington's direction; finalize and format for filing; finalize
notebooks for Judge Godbey and hand deliver to chambers; file
motion for extension
07/28/09 M C Wood 1.20 Emails with Kevin Sadler and David Arlington about
REDACTED email memo to same
REDACTED
07/28/09 A F York 3.00 Reviewed and edited joint motion with examiner regarding
SCB; conferred with counsel regarding same; prepared order
adopting same.
07/29/09 D T Arlington 6.70 Addressed issues relating to relief defendant claim filings;
addressed service issues; worked on coin motion and proposed
order; communicated with Examiner regarding same;
addressed Latin American account issues; reviewed response to
SEC motion; addressed web site posting; addressed further
analysis to be performed by FTI; prepared for upcoming
hearing.
368
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 302 of 377
Page 301
Hours Description
07/29/09 J A Cialone, II 2.00 Meetings, calls and emails throughout the afternoon and
evening about the Friday hearing and the preparations
therefore.
07/29/09 J A Cialone, II .50 Worked on brief in response to SEC motion to amend order;
calls and emails throughout the day about REDACTED ;
reviewed drafts of court papers.
07/29/09 B A Day 2.00 Requested issuance of summons from Cathy Woods at the
Northern District of Texas; coordinated service of filings and
summonses.
07/29/09 T S Durst 2.30 Review and revise REDACTED
attention to issues regarding Friday hearing;
communications with and directions to team regarding
REDACTED
07/29/09 J S Fitzwater 5.00 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating pleadings indices for the '298 (Stanford v. SEC)
matter; updating the pleadings pad in the '724 (Janvey v.
Alguire) matter; updating the Extranet website, as well as
hosted filings regarding searchable text; updating the tracking
charts of filings entered by the Parties and intervenors;
updating support files for the litigation team and organizing
case material for attorney review; and updating hard and
electronic correspondence, as well as (non-pleading)
intercorrelating discovery.
07/29/09 J B Lawrence 6.20 Continue researching, editing, and revising REDACTED
07/29/09 S A Massad 1.90 Reviewed and commented on reply brief to SEC; reviewed
clawback filings; numerous telephone conferences and e-mail
correspondence regarding REDACTED
07/29/09 D S Rohleder 4.60 Creating Hearing binder; Created Case Law Binder; Obtained
attorney information for various parties from their respective
Summons.
07/29/09 K M Sadler 11.60 Consultations with Receiver; conferences with Court staff
regarding filings and hearing; emails to/from Cialone regarding
REDACTED reviewed
information from FTI; reviewed draft response to SEC Motion;
reviewed responses to Receiver Motions; reviewed legal
research regarding REDACTED reviewed issues regarding
REDACTED
conference with Cooper REDACTED
; reviewed issues regarding Coin & Bullion Motion;
reviewed memo regarding REDACTED ; reviewed Motion
regarding FA account freeze; reviewed task list and motions
369
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 303 of 377
Page 302
Hours Description
responses due; reviewed pleadings and analysis regarding
REDACTED
07/29/09 K Scanlan 6.80 Travel to Courthouse for hand deliver of notebook of new
filings; copy authorities cited by SEC as directed and prepare
notebook of same with clean copies; prepare notebook of
materials relating to relief defendants for Tim Durst; update
deadlines and pending motions charts and forward; assist in
REDACTED ; brief office
conference with John Lawrence regarding REDACTED ;
prepare final draft and format for filing; file and serve with
court; update notebooks per Tim Durst request; assist in
compiling statistics regarding cases and motions and responses.
07/29/09 M C Wood 2.00 Gathered cases for Kevin Sadler's review; Drafted email memo
to Kevin Sadler explaining REDACTED
07/29/09 A F York 5.30 Revised and finalized SCB motion; prepared same for filing;
prepared REDACTED
; reviewed summons procedure; gathered cases for hearing
notebook; reviewed REDACTED
; responded
REDACTED ; reviewed account holder records for
REDACTED
REDACTED .
07/30/09 D T Arlington 11.60 Addressed issues relating to relief defendant claim filings;
addressed service issues; addressed further analysis to be
performed by FTI; reviewed research; prepared for upcoming
hearing; conferences with creditor counsel regarding property
sale motion; prepared research outline.
07/30/09 J A Cialone, II 1.50 Calls, meetings and emails related to REDACTED
07/30/09 B A Day 6.00 Coordinated service of filings and summonses; reviewed
account holders' accounts for partial, full, or de minimis
releases; reviewed and analyzed documents relating to such
releases and conferred with financial team regarding same;
prepared for hearing before Judge Godbey regarding motions
to freeze, disgorge, and for summary proceedings.
07/30/09 J S Fitzwater 4.80 Assembling pleadings pads for related state litigation and
organizing case material for attorney review; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; updating the Extranet website,
as well as hosted filings regarding searchable text; updating
pleadings indices for the '298 (Stanford v. SEC) matter;
updating the pleadings pad in the '724 (Janvey v. Alguire)
matter; and updating the tracking charts of filings entered by
the Parties.
370
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 304 of 377
Page 303
Hours Description
07/30/09 J R Knight .40 Consulted with Kevin Sadler regarding REDACTED
07/30/09 J B Lawrence 4.10 Edit and revise REDACTED
analyze issues REDACTED
07/30/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding REDACTED
07/30/09 D S Rohleder 5.50 Created new spreadsheet consolidating address information
from KVT-6 and Summons Names and Addresses Spreadsheet
for K Hinton; Updated Hearing Notebooks belonging to K
Sadler, D Arlington, and K Hinton;
07/30/09 K M Sadler 11.60 Continued preparation for hearing; reviewed and revised
REDACTED reviewed oppositions to motions filed;
reviewed information from FTI regarding funds flow; reviewed
issues regarding Hunton appeal; reviewed and finalized
response to SEC motion; reviewed MDL filing; emails to
Cooper regarding consultations with Receiver; reviewed
REDACTED
cases regarding freeze and attachment; reviewed data from FTI
regarding history of CD proceeds payments; reviewed issues
regarding REDACTED
07/30/09 K Scanlan 6.50 Review requests for materials to be compiled for hearing; begin
preparation of notebooks for Tim Durst; review additional
requests from David Arlington and prepare materials;
coordinate all services needed for pre-hearing meetings; pull
cases and other materials as requested; telephone conference
with courthouse staff concerning logistics of post 5 PM
hearing; update files and review Letsos materials; create new
section on extranet for Letsos matters and assist in uploading
all new matters; review extranet to determine if any non-SEC
cases need updating and add any missing documents; create
new notebook for Tim Durst regarding Letsos and other relief
defendants; update Tim Durst calendar; assist in distributing
materials to litigation team.
07/30/09 M C Wood 4.20 Drafted email memo to Kevin Sadler and David Arlington
explaining REDACTED
Forwarded cases to KS and DA regarding REDACTED
Assembled cases REDACTED
Assembled cases REDACTED
07/30/09 A F York 10.30 Reviewed with FTI issue REDACTED
office meetings with Sadler regarding REDACTED emails with FITS
and Stanford Eagle regarding REDACTED
371
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 305 of 377
Page 304
Hours Description
responses to REDACTED reviewed and summarized REDACTED
outlined REDACTED ; prepared
REDACTED reviewed
REDACTED ; meeting regarding REDACTED calls with K.
Schlanger and D. Arlington regarding REDACTED
07/31/09 D T Arlington 15.20 Prepared for and participated in hearing.
07/31/09 J A Cialone, II 1.80 Attended meetings related to REDACTED
07/31/09 B A Day 4.00 Coordinated service of filings and summonses; reviewed
account holders' accounts for partial, full, or de minimis
releases; reviewed and analyzed documents relating to such
releases and conferred with financial team regarding same;
prepared for hearing before Judge Godbey regarding motions
to freeze, disgorge, and for summary proceedings; drafted
order granting in part and denying in part Receiver's motion to
freeze; drafted order denying the SEC's emergency motion to
modifying receivership order.
07/31/09 T S Durst 6.40 Analysis of clawback issues; preparation for hearing and
conference with Mr. Janvey and others; hearing and follow-up
on same regarding appeal.
07/31/09 J S Fitzwater 4.50 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Extranet website; continuing to assemble
pleadings pads for related state and federal litigation, including
updating pleadings pads in the '298 (Stanford v. SEC) matter,
'1329 (Janvey v. Letsos) matter, and the '724 (Janvey v.
Alguire) matter; and updating the tracking charts of filings
entered by the Parties, intervenors and the intervenors' attorney
appearances.
07/31/09 J R Knight .30 Consulted with Kevin Sadler regarding REDACTED
07/31/09 J B Lawrence 2.50 Research related to REDACTED
07/31/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
related to REDACTED
07/31/09 K M Sadler 12.30 Continued preparation for motions hearing; reviewed cases and
pleadings; reviewed response to motions; consultations with
Receiver; conferences with Arlington; reviewed information
from FTI; attendance in court for hearing; reviewed notes
regarding preparation of Order
07/31/09 K Scanlan 11.50 Assist in hearing preparation; prepare notebooks for David
Arlington and Kevin Sadler; update authorities notebooks;
372
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 306 of 377
Page 305
Hours Description
continue to revise notebooks with new cases and other
materials; create orders notebook for Mr. Arlington; complete
hearing notebook for Tim Durst with all motions pending in
three cause numbers and all matters likely to be raised and
related materials and background information on non-SEC case
motions; generally assist in hearing preparation; transport all
counsel and Mr. Janvey to Courthouse and return trip to office;
handle all post hearing needs; copy materials as requested;
deliver all attorneys to Love Field for return to various offices;
assist with coordination of court reporter needs to assure fast
delivery of transcript.
07/31/09 A F York 4.00 Briefed Sadler REDACTED ; reviewed REDACTED
and reported to Sadler; prepared motions for extension of
deadlines in real estate sale matter; conferred with counsel
regarding same; reviewed REDACTED and reported to
Sadler; preparation REDACTED .
08/01/09 D T Arlington 2.70 Prepared and circulated proposed orders regarding motion to
freeze and SEC motion; revised web site statements; reviewed
FTI analysis; addressed relief defendant service issues.
08/01/09 J A Cialone, II 1.20 Emails about court order; emails about appeal issues.
08/01/09 J R Knight 1.10 Consulted with Kevin Sadler regarding REDACTED
; reviewed and provided suggestions on draft
order.
08/01/09 K Scanlan 1.50 Brief telephone conference regarding transcript from hearing;
format and forward REDACTED to specific team members; update
chart.
08/01/09 A F York 5.60 Reviewed and summarized REDACTED
; prepared for REDACTED
08/02/09 D T Arlington 3.00 Continued working on and coordinating regarding draft orders;
addressed account release and draw down issues;
communicated with relief defendant counsel.
08/02/09 J A Cialone, II .70 Reviewed transcript of Friday hearing; other emails to and
from team about REDACTED .
08/02/09 T S Durst 1.80 Work on draft orders from hearing; attention to appeal matters;
review and comment on REDACTED
08/02/09 J R Knight 1.30 Assisted in drafting orders from July 31 hearing and analyzed
REDACTED
08/02/09 J B Lawrence 5.50 Research and draft REDACTED
373
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 307 of 377
Page 306
Hours Description
08/02/09 K M Sadler 8.50 Continued work on form of orders; correspondence with
Examiner and opposing counsel regarding
objections/negotiations over forms of orders; conferences with
Arlington and Knight regarding REDACTED
; reviewed issues regarding REDACTED
;
reviewed issues regarding REDACTED ; reviewed draft motion
regarding receivership Order; reviewed case law regarding
freeze orders; reviewed analysis from FTI regarding REDACTED
08/02/09 A F York 3.70 Revised proposed orders per Sadler and counsel's comments;
reviewed counsel's comments to same; prepared REDACTED
08/03/09 D T Arlington 9.00 Worked on draft orders; conferred with opposing counsel
regarding same; communicated with court regarding same;
addressed account release issues; communicated with counsel
for investors; telephone conference with Victor Kurylak.
08/03/09 S A D Ayers 1.50 Drafted and mailed notices to law firms and California Labor
Commission regarding receivership and injunction; received
pleadings in new suits against Pershing; received case files
from Hunton & Williams on CD; reviewed response filed by
Randi Stanford.
08/03/09 J A Cialone, II 1.20 Reviewed materials forwarded by Kevin Sadler related to
REDACTED
08/03/09 B A Day 8.10 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same; further revised order granting in part and denying in part
Receiver's motion to freeze; researched REDACTED
08/03/09 T S Durst 1.30 Work on proposed order and other upcoming filings;
communications with opposing counsel and team regarding
same; analysis of REDACTED
08/03/09 J S Fitzwater 4.80 Updating the Extranet website; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; assisting Mary Scott regarding
REDACTED
updating pleadings pads in the '724 (Janvey v.
Alguire), '1329 (Janvey v. Letsos) and '298 (Stanford v. SEC)
matters; updating Appearances from Attorneys for the
Intervenors notebook; updating the tracking charts of filings
entered by the Parties and intervenors; and updating hard and
electronic correspondence.
374
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 308 of 377
Page 307
Hours Description
08/03/09 K W Hinton 3.30 Reviewed documents regarding wage claim and drafted notice
letters regarding same; coordinated and assisted with service of
same; researched address for James Fontenot for service of
amended complaint; exchanged emails with B. Day regarding
REDACTED
08/03/09 J R Knight 1.10 Discussions with counsel for the SEC and for the Hunton
parties regarding status of Fifth Circuit appeal; drafted,
finalized and filed joint motion to dismiss; telephone
consultation with court clerk regarding same.
08/03/09 J R Knight 3.40 Analyzed hearing transcript; assisted with draft orders; began
working on motion for stay.
08/03/09 J B Lawrence 6.60 Research and draft brief regarding REDACTED
08/03/09 S A Massad 1.00 Reviewed transcript of hearing; various e-mail correspondence.
08/03/09 K M Sadler 10.70 Reviewed and revised proposed Orders; correspondence with
opposing counsel and examiner regarding objections to Orders;
conference with FTI regarding REDACTED ; reviewed
transcript of hearing; reviewed issues regarding status of
claims; reviewed issues regarding Hunton/Letsos appeal;
reviewed draft Motion to Dismiss; reviewed pleadings and
objections received; conferences with Arlington regarding
REDACTED reviewed report
on REDACTED correspondence with SEC
regarding form of Order; reviewed REDACTED
conference with Durst and Arlington regarding REDACTED
08/03/09 K Scanlan 1.50 Pull motions as requested for working on response brief and
prepare notebook; update chart with latest filings; office
conference regarding REDACTED
08/03/09 M C Wood 1.60 Assembled cases for Kevin Sadler regarding REDACTED
Researched REDACTED
08/03/09 A F York 6.70 Finalized REDACTED
; calls with FITS regarding
REDACTED
responded to account holder inquiries; reviewed and
analyzed REDACTED
; reviewed REDACTED
08/04/09 D T Arlington 8.20 Worked on reply to objections to proposed orders;
communicated with relief defendants; addressed account
release issues; communicated with account holder counsel
regarding account release and related issues; reviewed
settlement offer regarding letter of credit; addressed relief
375
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 309 of 377
Page 308
Hours Description
defendant inquiries; coordinated regarding and worked on
discovery responses to Gagosian Gallery; reviewed additional
objections to orders; coordinated regarding REDACTED
reviewed report regarding
REDACTED
08/04/09 S A D Ayers .60 Responded to requests for REDACTED from Mary Scott to
REDACTED
08/04/09 B A Day 7.40 Reviewed account holders' accounts for partial, full, or de
minimis releases; reviewed and analyzed documents relating to
such releases and conferred with financial team regarding
same; researched REDACTED
researched answers to Examiner's
questions regarding specific account holders.
08/04/09 T S Durst 1.60 Analysis of insurance issues; meet with opposing counsel
regarding same; review of issues regarding proposed order
from hearing and objections to same.
08/04/09 J S Fitzwater 2.90 Continuing to update hard and electronic correspondence;
updating pleadings pads in the '298 (Stanford v. SEC) matter,
as well as the Extranet website; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; assisting Stephen Massad regarding
REDACTED ; and updating the
tracking charts of filings entered by the Parties and intervenors.
08/04/09 K W Hinton 4.90 Calculated deadlines and researched questions regarding Pacer
docket; reviewed case status information and updated post-
receiver deadlines chart; researched REDACTED
and drafted email and attached documents to
M. Scott regarding researched orders and exchanged
REDACTED
emails with B. Stutts regarding REDACTED
08/04/09 J R Knight 4.80 Analyzed transcript and competing versions of the order;
worked on motion for stay in the court of appeals.
08/04/09 K M Sadler 11.20 Reviewed issues and correspondence regarding Objections to
forms of Order regarding hearing; correspondence and
communications with opposing counsel; reviewed data analysis
from FTI; reviewed issues regarding investor account inquiries;
reviewed issues regarding Whit Wilks account status; reviewed
pleadings regarding REDACTED ; reviewed issues regarding
REDACTED ; conference with B. Day
regarding REDACTED
; reviewed Objections filed to Order submission;
correspondence with Examiner regarding various issues;
conference with Cooper regarding REDACTED ; reviewed
motion regarding REDACTED
376
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 310 of 377
Page 309
Hours Description
REDACTED ; reviewed legal research regarding
REDACTED .
08/04/09 K Scanlan 2.80 Update the pending matters chart and update the dates and time
particular matters have been ripe for ruling; update additional
charts; review intervenor pleadings to identify open
interventions by type of claim made.
08/04/09 A F York 4.50 Responded to examiner and account holder inquiries; calls with
FITS regarding ; reviewed REDACTED
REDACTED
; circulated memo regarding ; reviewed
REDACTED
REDACTED ; circulated memo
regarding .
REDACTED
08/05/09 D T Arlington 2.40 Addressed motion response deadlines; coordinated with team
regarding account release and draw down issues; reviewed
orders from court; addressed issues relating to Gagosian
Gallery's discovery requests to Receiver; telephone conference
with FTI regarding analysis issues.
08/05/09 S A D Ayers .50 Conferred on broker's motion to join Holts regarding D&O
policies; responded to questions from Baker Botts lawyers
regarding service of process on brokers, scope of the order
appointing receiver and response filed by Randi Stanford.
08/05/09 J A Cialone, II .60 Attention to court papers.
08/05/09 B A Day 7.00 Reviewed account holders' accounts for REDACTED
and analyzed documents
REDACTED and conferred with financial team regarding
same; researched the requirements for Receiver's claims
REDACTED
08/05/09 J S Fitzwater 4.10 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the tracking charts of filings entered by the Parties
and intervenors; office conference with Kevin Scanlan
regarding updating the Deadlines to Motions chart; updating
pleadings pads REDACTED
; updating the Extranet website, as
well as hosted filings regarding searchable text; organizing
case material for attorney review; and updating the Deadlines
to Motions chart.
08/05/09 J R Knight 3.90 Analyzed written order; worked on motion for stay; circulated
first draft.
08/05/09 J B Lawrence 1.50 Review impact of court order on pending motion responses;
begin formulating response to financial advisors' motion to
modify receivership order; draft response to DOJ motion to
intervene and stay discovery; begin outlining response to
377
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 311 of 377
Page 310
Hours Description
motion to compel arbitration.
08/05/09 R C Lewis .10 Phone call with Sam Cooper regarding upcoming motions.
08/05/09 K M Sadler 10.50 Reviewed and revised motion to stay; reviewed notice of
appeal; reviewed draft responses to motions; reviewed
pleadings received; reviewed motion to compel arbitration and
issues for response; conference with Cooper regarding pending
motions; consultations with Receiver; reviewed pending
motions list and task assignments; reviewed status of work by
FTI; reviewed draft motion for contempt; reviewed Orders
received; reviewed various investor account issues in response
to Examiner inquiries; reviewed issues REDACTED
08/05/09 M C Wood 1.50 Researched the Fifth Circuit's standard REDACTED
; Drafted memo to Joe Knight explaining same.
08/05/09 A F York 3.20 Responded to account holder inquiries and examiner inquiries
regarding timing of SIB withdrawals and available SIB data;
discussed release and drawdown protocol with FITS.
08/06/09 D T Arlington 11.70 Reviewed court orders; coordinated regarding motion response
deadlines; reviewed research relating to pro rata distributions;
addressed account release issues; communicated with account
holder counsel regarding same; reviewed further analysis from
FTI; worked on motion to extend injunction; addressed
inquiries from relief defendants; addressed issues relating to
appeal; communicated with Pershing regarding account issues.
08/06/09 S A D Ayers 4.90 Drafted two filing letters, edited motion to extend injunction,
and prepared appendices for appeals to Fifth Circuit; telephone
conference with Fifth Circuit; filed and served appendices for
appeals; conferred with Andrew York on arguments for reply
to Randi Stanford on contempt motion; selected documents for
Bill Stutts for delivery to foreign counsel and to John Lawrence
for reply to motion to compel arbitration.
08/06/09 J A Cialone, II 1.20 Reviewed appeal papers; attention to other court papers.
REDACTED
08/06/09 B A Day 11.70 Reviewed account holders' accounts for
; reviewed and analyzed documents relating to
REDACTED and conferred with financial team regarding
same; researched the requirements REDACTED
; discussed with financial team the
breakout of principal versus interest, as well as reinvested
proceeds.
08/06/09 T S Durst 1.90 Attention to issues regarding stay of relief defendants answer
obligations and communications with opposing counsel
regarding same; review and comment on draft appeal papers
378
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 312 of 377
Page 311
Hours Description
REDACTED .
08/06/09 J S Fitzwater 3.60 Continuing to organize case material for attorney review;
updating the Extranet website, as well as hosted filings
regarding searchable text; updating (non-pleading)
intercorrelating discovery; updating pleadings indices in the
'298 (Stanford v. SEC) matter; assisting Tim Durst to research
appearances made by relief defendants; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; and updating the tracking
charts of filings entered by the parties and intervenors.
08/06/09 J R Knight .40 Prepared and arranged for filing of notices of appeal in both
relief defendant cases.
08/06/09 J R Knight 5.50 Revised and completed draft motion for stay; reviewed and
inserted record cites; circulated draft and incorporated
comments from others.
08/06/09 J B Lawrence 9.60 Research, draft, and revise response to REDACTED motion to compel
arbitration.
08/06/09 K M Sadler 11.80 Reviewed and revised motions to extend injunction; reviewed
cases; conferences with Knight and Arlington regarding
motions; reviewed pleadings received; reviewed issues
regarding broker claims; reviewed FT analysis; conferences
with opposing counsel regarding RD claims; reviewed inquiry
from investor group; reviewed pending motions list; reviewed
information regarding investor claims regarding KVT-4.
08/06/09 M C Wood 1.00 Revised draft of motion to stay in light of Joe Knight's
comments.
08/06/09 A F York 5.50 Responded to account holder/examiner inquiries; prepared
Barnes Group demand REDACTED
and responded to Randi Stanford contempt briefing.
08/07/09 D T Arlington 2.80 Worked on motion to extend injunction and related appellate
issues; addressed various motion responses; coordinated with
FTI regarding status of analysis; addressed account release
issues; reviewed status of Cisco dispute; coordinated regarding
service on relief defendants; addressed Dillon Gage discovery;
communicated with counsel for relief defendants.
08/07/09 S A D Ayers 5.90 Edited motions and certificates of interested persons,
supervised cite check, finalized Tables; filed and served same
in Fifth Circuit on appeal; drafted email to Randi Stanford's
attorney REDACTED
.
08/07/09 H M Chappel .80 Compiled cases cited in Motion to Extend Injunction Pending
379
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 313 of 377
Page 312
Hours Description
Appeal in preparation for cite check and filing with the court.
08/07/09 B A Day 8.00 Researched the requirements for Receiver's claims REDACTED
; discussed with financial team the calculation
of principal and interest for the purpose of clawbacks.
08/07/09 T S Durst .50 Work on insurance matters, including review of intervention
papers; communications with opposing counsel regarding relief
defendant proceedings.
08/07/09 J S Fitzwater 5.20 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating pleadings pads in the '724 (Janvey v. Alguire), '1329
(Janvey v. Letsos) and '298 (Stanford v. SEC) matters;
updating the Extranet website, as well as hosted filings
regarding searchable text; updating the tracking charts of
filings entered by the parties and intervenors; updating support
files for the litigation team and continuing to assist Tim Durst
in researching appearances made by relief defendants; updating
hard and electronic correspondence.
08/07/09 L C Fluker 3.60 Conferred with Katherine Hinton regarding appeal motions to
be cite checked; compared Motions to Extend Injunction
Pending Appeal from both District Court cases to confirm that
all legal citations are identical; worked with Katherine Hinton
and Hillari Chappell to download all case law from motions not
previously downloaded during cite check of earlier motions
onto firm's shared drive; checked cites, made necessary
revisions to two motions and saved revisions as new versions;
conferred with Sue Ayers regarding extent of checks; conferred
with Kevin Sadler regarding expected completion time of
checks; confirmed that motions were timely filed.
08/07/09 J R Knight 1.20 Final review and revisions to motion for stay and assistance in
finalizing.
08/07/09 M D Kusey 2.00 Prepared and sent Stanford related correspondence to Richard
Roper; logged in same and additional correspondence in claims
and correspondence logs.
08/07/09 J B Lawrence 5.20 Edit and revise response to Sasser motion to compel
arbitration; draft and revise response to R.A. Stanford motion
for oral hearing and request for sequence of consideration of
related motions.
08/07/09 K M Sadler 9.60 Reviewed and revised motions for relief in 5th circuit;
conferences with Ayers and Arlington regarding same;
reviewed pleadings received; reviewed draft response to RAS
motion; reviewed FTI analysis issues; reviewed investor related
correspondence; reviewed cases for cites in motions.
380
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 314 of 377
Page 313
Hours Description
08/07/09 M C Wood .70 Conference with Brendan Day regarding conflict reports;
Reviewed and signed off on final batch of conflicts reports.
08/07/09 A F York 4.20 Researched and drafted reply in support of Randi Stanford
contempt motion; responded to account holder and Stanford
Eagle/FITS inquiries.
08/08/09 D T Arlington 2.20 Conference call with FTI regarding analysis; coordinated
regarding same; addressed coin motion issues; addressed relief
defendant service issues.
08/08/09 B A Day 1.00 Discussed with financial team the REDACTED
.
08/09/09 D T Arlington .20 Further reviewed FTI analysis.
08/09/09 B A Day 1.60 Reviewed financial advisors' motion for release of accounts
and brief in support of same; researched the requirements for
Receiver's claims REDACTED ; discussed with
financial team the calculation of principal and interest
REDACTED .
08/10/09 D T Arlington 4.90 Addressed coin motion issues; coordinated regarding Dillon
Gage discovery; addressed account release issues; reviewed
response to motion to extend injunction; reviewed other filings;
addressed motion deadlines; coordinated with FTI regarding
status of analysis.
08/10/09 S A D Ayers .80 Assisted Brendan Day with research on claims against brokers
by REDACTED ; corresponded
with Kevin Sadler and Sam Cooper regarding new lawsuit filed
in Florida against Pershing.
08/10/09 S M Benhoff 3.00 Discussion
REDACTED
. Debrief K. Van Tine regarding calls.
Summarize situation in e-mail and send to Van Tine.
Additional calls REDACTED
.
08/10/09 J A Cialone, II .80 Reviewed court papers.
08/10/09 B A Day 10.50 Reviewed financial advisors' motion for release of accounts
and brief in support; conducted research for response to same;
researched the requirements for Receiver's claims REDACTED
; researched Receiver's standing to
REDACTED
.
08/10/09 T S Durst .30 Follow-up on issues regarding pending response items and
schedule; communications with team and client regarding
381
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 315 of 377
Page 314
Hours Description
pending matters.
08/10/09 J S Fitzwater 5.20 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
organizing material for attorney review; updating the Extranet
website; updating pleadings indices for the '298 Stanford
matter and related litigation; updating Appearances from
Attorneys for the Intervenors notebook; updating the tracking
charts of filings entered by the parties and intervenors.
08/10/09 J R Knight 1.30 Began analyzing responses to the motion to extend injunction
and consulted with Kevin Sadler regarding strategy.
08/10/09 M D Kusey 1.00 Assisted Kasey Gascamp with cite checking brief.
08/10/09 K M Sadler 9.80 Reviewed issues regarding Florida class action and MDL;
reviewed oppositions regarding motion to freeze; reviewed
issues REDACTED ; reviewed
legal research regarding broker claims; reviewed issues
regarding motions to release coins/bullion by Quilling clients;
reviewed and revised response to RAS motion regarding
hearing; reviewed issues regarding proposed motion to transfer
bulk accounts; reviewed appeal issues; reviewed information
from FTI; reviewed issues regarding FA claims.
08/10/09 K Scanlan 1.20 Office conference with Tim Durst regarding outstanding
motions; update trial deadlines chart for SEC main case; update
notebooks per Tim Durst direction.
08/10/09 K K Van Tine 1.00 Call from S. McColley to discuss Dodd letter re hearing in
Baton Rouge; reviewing emails re hearing; outlining response
08/10/09 V R Walker .70 Assembled and organized court papers and correspondence.
08/10/09 M C Wood .60 Conference with Brendan Day REDACTED
; Emailed Joe Knight explaining
REDACTED .
08/10/09 R H Wood .40 Corresponded with B. Day regarding previous research
REDACTED ; e-mailed B.
Day regarding research on this subject.
08/10/09 A F York 6.00 Outlined reply in support of Randy Stanford contempt motion;
reviewed account holder inquiries; prepared motion for
extension of time in real estate matter and conferred with
counsel regarding same.
08/11/09 C N Adams 1.40 Preparing announcement and posting regarding Fifth Circuit
appeal; attention to inquiry regarding 754 filings; attention to
court filings.
08/11/09 D T Arlington 8.20 Reviewed recent filings; addressed motion deadlines; worked
382
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 316 of 377
Page 315
Hours Description
on reply regarding motion to extend injunction; reviewed 5th
Circuit order; responded to Examiner inquiries; responded to
relief defendant inquiries; reviewed Janvey declarations;
worked on discovery responses; addressed account release
issues.
08/11/09 S A D Ayers 1.00 Responded to inquiries regarding district where 754 notices
were filed, REDACTED exhibits motion for contempt
against Randi Stanford, and lawsuits filed against Pershing.
08/11/09 S M Benhoff 7.00 Attention to request from Chairman Dodd REDACTED
. Review draft response to invitation letter. Read
SEC Inspector General report. Coordination with Senate staff
regarding request. Debrief Baker Botts team REDACTED
.
08/11/09 B A Day 11.60 Drafted response to financial advisors' motion and brief for
release of accounts; coordinated research of the requirements
REDACTED and Receiver's
standing to assert such claims.
08/11/09 J S Fitzwater 4.90 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
assisting John Lawrence to file the Receiver's Opposition to
Stanford's Motion for Oral Hearing (Dkt. No. 695); updating
support files for the litigation team; updating the tracking
charts of filings entered by the Parties and intervenors;
updating pleadings indices for the '298 (Stanford v. SEC),
'1329 (Janvey v. Letsos) and '724 (Janvey v. Alguire) matters;
updating the Extranet website; updating hard and electronic
correspondence; and beginning to assemble XLS spreadsheets
REDACTED .
08/11/09 K W Hinton 7.30 Reviewed docket sheet and updated deadlines chart; reviewed
new case information and provided instructions to D. Rohleder;
researched and assisted with service issues; summarized 754
notice filings for D. Arlington; researched and prepared Janvey
affidavits and sent same to D. Arlington; assisted with
pleadings per the request of B. Day; researched correspondence
regarding Randi Stanford.
08/11/09 J R Knight 3.40 Analyzed responses to motion to extend injunction and began
drafting reply; analyzed court order and consulted with Kevin
Sadler regarding strategy.
08/11/09 K M Sadler 11.60 Reviewed bulk account transfer motion and provided
comments to M. Myers; reviewed appeal issues with Knight;
reviewed draft motion for contempt; reviewed issues regarding
request for testimony; reviewed and edited response to RAS
motion for hearing; reviewed issues regarding inquiries from
383
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 317 of 377
Page 316
Hours Description
investor and RD counsel; reviewed oppositions to motion to
extend injunction; conferences with clerk's office at 5th Cir.;
reviewed and revised draft reply; conferences with Cialone
regarding Order; consultations with Receiver regarding Order
from 5th Cir.; conference with Knight and Edmundson of SEC
regarding litigation issues; conference with VanTine and
Cialone REDACTED ;
reviewed issues regarding response to examiner on RD claims;
drafted and revised response; reviewed issues regarding
Pershing lawsuit in Florida.
08/11/09 K Scanlan 1.80 Review e-mails from Tim Durst regarding requests by John
Volney regarding mail and car title issues; contact Charlie Gale
at Mr. Janvey's office regarding request for new release of mail
from Baldwyn Post Master; e-mail with follow-up to Tim Durst
regarding mail; review e-mail from Austin regarding requested
documents and forward; update intervenors chart for Tim
Durst's notebook.
08/11/09 K K Van Tine 9.10 Drafting and revising response letter to Chairman Dodd;
analyzing issues and outlining strategy for response;
conference calls to discuss issues
08/11/09 M C Wood .40 Conference with Brendan Day REDACTED
; Reviewed case summaries prepared by BD
regarding same.
08/11/09 R H Wood 2.90 Researched issues regarding
REDACTED
; began writing memo regarding same.
08/11/09 A F York 6.80 Outlined and researched reply in support of Randi Stanford
contempt motion; responded to examiner inquiries re: timing
and drawdowns; emails and calls with FTI/FITS; calls and
emails with K. Schlanger re: real estate filings.
08/12/09 D T Arlington 7.80 Telephone conference with Gordon Russell regarding Cisco
and Trustmark; reviewed account transfer motion; addressed
account release and draw down issues; coordinated regarding
Farmer & Merchant motion; worked on responses to Dillon
Gage and Gallery discovery; addressed inquiries regarding coin
accounts; telephone conference with counsel regarding motion
to compel arbitration; addressed relief defendant inquiries;
reviewed analysis from FTI; reviewed motion to dismiss filed
by Ulloa.
08/12/09 S M Benhoff 3.00 Read final response to REDACTED
Conference call with J. Cialone and K. Van Tine to discuss
384
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 318 of 377
Page 317
Hours Description
REDACTED .
08/12/09 M E Burnett .90 Searched for cases involving specified judges in the 5th Circuit
for Matt Wood.
08/12/09 B A Day 9.00 Drafted response to financial advisors' motion and brief for
release of accounts; coordinated research
REDACTED
.
08/12/09 J S Fitzwater 4.40 Updating the Extranet website, as well as hosted filings
regarding searchable text; monitoring court filings and assisting
attorney team to coordinate reception of filings to appropriate
members.
08/12/09 L C Fluker .40 Reviewed tracking chart of third-party communications to
determine any communications with Randi Stanford, Joe
Kendall or Randy Burton; sent advisory email to team
members.
08/12/09 K W Hinton 7.20 Reviewed, prepared, e-filed and served pleadings; reviewed
filings and provided instructions regarding same; supervised
and assisted with updating shared drive; reviewed file
regarding Dillon Gage documents and exchanged emails with
D. Arlington regarding same; assisted D. Arlington with
responses to Dillon Gage and Pre-War Art; reviewed appeal
filings and provided instructions to D. Rohleder regarding
same; coordinated set up for reviewing documents per the
request of D. Arlington.
08/12/09 M D Kusey 3.30 Logged in mail into correspondence and claims logs.
08/12/09 R C Lewis 2.20 Reviewed Motion to Show Cause as to Rebecca Reeves; began
preparing same for filing; conference with Sam Cooper
regarding same.
08/12/09 K M Sadler 10.20 Reviewed issues regarding requested testimony; revised letter;
conferences with Van Tine and Cialone; conference with M.
Gandy of FNRA; reviewed issues regarding proposed motion
to compel arbitration; reviewed correspondence from opposing
counsel; reviewed appeal issues; reviewed outline of reply to
response to contempt motion; reviewed issues regarding FT
claim regarding Barnes; reviewed issues regarding Citigroup
inquiry; reviewed issues regarding Galleria litigation;
conferences with Court staff regarding letter to Sen Dodd
regarding request for testimony.
08/12/09 K Scanlan .50 Work with James Fitzwater on incoming filings.
REDACTED
08/12/09 K K Van Tine 8.20 Analyzing issues and outlining response ;
preparing and revising letter response REDACTED
385
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 319 of 377
Page 318
Hours Description
; conference calls with client and J. Cialone;
conference REDACTED ; transmitting response
letter; reporting on conference calls REDACTED
08/12/09 M C Wood 7.50 Continued researching REDACTED
; Continued drafting memo
regarding same; Gathered and emailed to Kevin Sadler cases
REDACTED ;
Arranged for Margaret Burnett to compile Fifth Circuit cases
REDACTED .
08/12/09 R H Wood 10.00 Researched issues regarding receivership standing
REDACTED
; continued writing memo regarding same.
08/12/09 A F York 7.30 Completed outline and drafted Reply in support of Randi
Stanford contempt motion; conferred with counsel regarding
real estate extensions; drafted same; reviewed caselaw
REDACTED
; responded to account holder and claimant inquires;
calls and email with FITS re: same.
08/13/09 D T Arlington 10.80 Worked on responses to Dillon Gage and Gallery discovery
requests; addressed relief defendant inquiries; addressed coin
account inquiries; worked on response to broker motion to
unfreeze accounts; addressed account release issues; reviewed
Holt discovery.
08/13/09 S M Benhoff 2.40 Prepare opening to written testimony. Review final testimony.
08/13/09 B A Day 8.70 Finalized response to financial advisors' motion and brief for
release of accounts; coordinated research REDACTED
and Receiver's
standing REDACTED .
08/13/09 J S Fitzwater 3.30 Organizing case material for attorney review; updating the
Extranet website, as well as hosted filings regarding searchable
text; monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
assisting Kevin Sadler regarding transcript versions from the
July 31st hearing; updating the tracking charts of filings
entered by the parties, intervenors and the intervenors' attorney
appearances; and updating the ('298) SEC v. Stanford and
('724) Janvey v. Alguire pleadings indices.
08/13/09 K W Hinton 8.80 Coordinated set up for reviewing documents and
communicated with IT regarding same per the request of D.
Arlington; reviewed, prepared, e-filed and served pleadings;
supervised and assisted with updating shared drive; reviewed
386
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 320 of 377
Page 319
Hours Description
financial information and provided instructions to H. Chappel
regarding chart of same; reviewed chart and drafted email to B.
Stutts regarding same; researched pleadings and provided same
to B. Wright; reviewed information and prepared transcript
appeal request forms.
08/13/09 J R Knight 2.60 Began working on record request and Appellant's's brief.
08/13/09 M D Kusey 5.50 Logged in mail into correspondence and claims logs.
08/13/09 R C Lewis 4.60 Reviewed and Revised Declaration for Motion for Contempt;
prepared Exhibit and Appendix for same; reviewed and revised
Motion and Brief in Support; prepared for and participated in
phone conference with Rebecca Reeves former lawyers
regarding same; prepared and filed Motion, Brief in Support,
Appendix, and Order related to same.
08/13/09 K M Sadler 5.40 Reviewed pleadings received; reviewed issues
REDACTED ; reviewed
correspondence from opposing counsel regarding broker and
investor issues; reviewed email from SEC regarding FA issue;
reviewed legal research REDACTED ;
reviewed issues regarding motions for contempt; conference
with Arlington regarding DG discovery.
08/13/09 K Scanlan 1.50 Update deadlines charts and pending motions charts; office
conference with James Fitzwater regarding various charts and
matters to supervise in my absence.
08/13/09 K Scanlan 2.20 Attend to package from post master; contact John Volney
regarding review of Ms. Holt's mail; office conference with
John Volney to review 6 weeks of mail; sort and review all
mail by category; office conference with James Fitzwater
regarding copying mail and providing copies to John Volney.
08/13/09 K K Van Tine 5.40 Preparing and revising written testimony REDACTED
08/13/09 M C Wood 2.00 Reviewed Fifth Circuit case law for REDACTED
; Conference with Radney Wood
REDACTED .
08/13/09 R H Wood 7.80 Researched issues regarding receivership standing
REDACTED
; finished memo regarding the same; corresponded with
K. Sadler, S. Ayers, B. Day, D. Arlington, M. Wood, and A.
York regarding the same.
08/13/09 A F York 6.50 Revised and finalized reply in support of Randi Stanford
contempt motion; reviewed SCB/Dillon Gage documents for
387
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 321 of 377
Page 320
Hours Description
production; investigated and responded to SCB inquiries;
reviewed Hunton & Williams REDACTED ;
emails with Sadler and Ayers REDACTED
.
08/14/09 D T Arlington 8.40 Worked on responses to Dillon Gage and Gallery discovery
requests; addressed Holt discovery deadline; addressed claims
against brokers; reviewed FTI analysis; reviewed documents
for discovery responses.
08/14/09 S M Benhoff .30 Research witnesses REDACTED
and prepare
list to send to K. Van Tine.
08/14/09 J A Cialone, II .80 Attention to discovery requests made by Holt.
08/14/09 B A Day 7.20 Strategy and status meeting with Kevin Sadler, David
Arlington, and Andrew York; discussed the review and
analysis of financial advisors' and REDACTED
; coordinated REDACTED
; reviewed and analyzed documents relating to
partial releases and conferred with financial team regarding
same; drafted and filed unopposed motion for extension of time
to respond to ten financial advisors' motion to unfreeze assets;
drafted letter agreement regarding extension of time to reply to
Defendant Laura Pendergest-Holt's requests for production and
admissions.
08/14/09 T S Durst .30 Review of communications from Court regarding new filings
and consideration of response matters.
08/14/09 J S Fitzwater 5.50 Updating the Extranet website, as well as hosted filings
regarding searchable text; updating support files for the
Litigation team; monitoring court filings and assisting attorney
team to coordinate reception of filings to appropriate members;
assembly of defendant Laura Holt's mail for transmittance to
John Volney and for submission to the case file; updating the
('298) SEC v. Stanford pleadings indices; updating tracking
charts for the parties; updating discovery involving Stanford-
related litigation; and updating hard and electronic
correspondence.
08/14/09 K W Hinton 8.50 Researched and communicated with B. Stutts regarding orders;
updated information for account holders; reviewed docket sheet
and updated deadlines chart; researched and reviewed emails
and file regarding discovery requests and exchanged emails
with D. Arlington regarding same; assisted with responses to
Dillon Gage and Pre-War Art discovery requests; assisted with
and prepared production in response to same; researched
related litigation and exchanged emails with M. Scott regarding
same; drafted motion to extend response deadline and proposed
388
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 322 of 377
Page 321
Hours Description
order; assisted with service of production and discovery
request; reviewed, prepared, e-filed and served pleadings;
calculated deadlines.
08/14/09 J R Knight .70 Analyzed strategy for appeal, cross appeals and the Examiner's
motion to intervene.
08/14/09 M D Kusey 4.50 Logged in mail into correspondence and claims logs.
08/14/09 J B Lawrence 4.40 Research regarding applicability REDACTED
exemption REDACTED .
08/14/09 K M Sadler 10.10 Conference with Myers regarding SEC request; consultations
with client and Cialone; reviewed pleadings received; reviewed
issues regarding broker claims; reviewed discovery regarding
DG claims; reviewed FTI data analysis; conference with
Cooper regarding various issues; emails to opposing counsel
regarding motions; reviewed written testimony draft REDACTED
; reviewed issues regarding broker arbitration;
reviewed documents regarding Barnes claim; conference with
Caperton regarding Barnes; reviewed draft pleadings regarding
Randi Stanford motion; reviewed research.
REDACTED
08/14/09 K K Van Tine 4.80 Reviewing and responding to emails re hearing statement;
preparing statement for filing; preparing transmittal letter;
transmitting statement to Senate Banking Committee
08/14/09 M C Wood 6.00 Continued researching various grounds REDACTED
; Drafted memo regarding same;
Conference with Brendan Day regarding same; Conference
with Radney Wood REDACTED
.
08/14/09 R H Wood 2.70 Researched issues REDACTED
; wrote
memo regarding same; corresponded with B. Day, K. Sadler,
A. York, M. Wood, S. Ayers, D. Arlington regarding the same.
08/14/09 A F York 6.10 Analyzed fraudulent transfer claim issues; prepared for
complaint against Ben Barnes Group; reviewed documents
regarding same; calls with FITS and conference with Arlington
regarding account holder proceeds issues; conference with
Sadler and Arlington regarding broker and Barnes fraudulent
transfer claims; circulated Randi Stanford contempt Reply.
08/15/09 D T Arlington 4.50 Reviewed inquiry from SEC and worked on response to same;
worked on responses to Dillon Gage's discovery requests;
reviewed reply brief regarding contempt motion and worked on
same.
08/15/09 B A Day .50 Coordinated research with Ruchit Shah regarding
389
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 323 of 377
Page 322
Hours Description
REDACTED
08/15/09 R C Lewis 3.10 Drafted Reply to Defendant's Opposition to Motion to Appoint
Private Equity Advisor; circulated same to group.
08/15/09 K K Van Tine .40 Attention to issues re Field Hearing
08/15/09 R H Wood 1.30 Researched REDACTED
claims in REDACTED
;
researched issues surrounding which state's REDACTED statute will
apply to a specific cause of action.
08/16/09 D T Arlington 1.10 Addressed issues relating to Dillon Gage discovery; addressed
account review issues; addressed status of equity investment
fund; researched coin customer inquiry.
08/16/09 J A Cialone, II .30 Reviewed fifth circuit cases.
08/16/09 B A Day .50 Revised response to ten financial advisors' motion to unfreeze
assets; distributed same to Ralph Janvey and Kristie
Blumenschein.
08/16/09 K M Sadler 4.30 Conference with Cialone regarding hearing; reviewed Randi
Stanford reply brief; reviewed response to broker motion to
modify receivership order; reviewed SCB issues; emails to
from EY regarding SCB; reviewed investor correspondence
regarding coin motion; emails to T. Leslie regarding same.
08/16/09 K K Van Tine .30 Attention to issues re field hearing
08/16/09 R H Wood 3.50 Researched UFTA claims REDACTED
;
corresponded with B. Day about the same.
08/17/09 D T Arlington 2.20 Addressed account release issues; addressed appellate record
issues; addressed inquiries from relief defendants; reviewed
revisions to contempt motion reply; addressed motion
regarding sale of Little Eagle; coordinated regarding responses
to Dillon Gage's interrogatories; addressed Trustmark inquiries.
08/17/09 S A D Ayers .50 Responded to inquiry from Manuel Lena with IRS regarding
document request for items relied on by Karyl Van Tassel.
08/17/09 S M Benhoff .30 Research news of Senate Banking Committee hearing. Forward
articles to K. Van Tine.
08/17/09 H M Chappel .50 Compiled case law cited in Response to Motion to Modify
Receivership Order to Release Accounts of Former Financial
Advisors and Brief in Support in preparation for cite check and
filing with the court.
390
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 324 of 377
Page 323
Hours Description
08/17/09 B A Day 5.00 Drafted discovery requests to former financial advisors;
reviewed and analyzed documents relating to partial releases
and conferred with financial team regarding same.
08/17/09 J S Fitzwater 5.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating searchable text in hosted filings on the Extranet
website; organizing support files for the Litigation team;
continuing to update discovery involving Stanford-related
litigation; updating pleadings pads in the ('724) Janvey v.
Alguire, ('1329) Janvey v. Letsos, and ('298) SEC v. Stanford
matters; and updating the tracking charts of filings entered by
the parties and intervenors.
08/17/09 K W Hinton 6.00 Reviewed pleadings and supervised and assisted with case pull;
revised appeal transcript forms and communicated with D.
Arlington and J. Knight regarding same; prepared and e-filed
transcript order forms; researched correspondence regarding
Causarina 20 and drafted email to A. York regarding same;
assisted with preparing and service of responses to Dillon Gage
interrogatories; researched service issues and drafted email to
B. Day regarding same.
08/17/09 J R Knight .40 Reviewed draft of Examiner's motion to intervene and
consulted with Kevin Sadler regarding terms
REDACTED .
08/17/09 J R Knight .50 Analyzed requirements for appellate record.
08/17/09 J R Knight 2.80 Analyzed motion filed on the district court and the cited cases
in preparation for drafting Appellant's's brief.
08/17/09 J B Lawrence 7.60 Continue research on REDACTED
; draft analysis of same;
research REDACTED
.
08/17/09 K M Sadler 8.30 Reviewed issues regarding IRS/DOJ request for documents
regarding KVT declaration; reviewed documents; reviewed
issues regarding investor CD claim; reviewed pleadings
received; reviewed information from FTI; reviewed issues
regarding Park Hill motion; reviewed issues regarding Randi
Stanford motion; reviewed issues regarding request to FTI for
data; reviewed issues regarding DG discovery; reviewed draft
motion to intervene by examiner; conference with counsel for
examiner; reviewed subpoena issues; reviewed SIPC
correspondence; reviewed correspondence regarding Florida
real estate.
08/17/09 K K Van Tine 5.30 Attention to issues re Field Hearing; confirming receipt of
391
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 325 of 377
Page 324
Hours Description
written testimony; reviewing legal issues
REDACTED
08/17/09 R H Wood 9.80 Researched and wrote memo regarding how courts interpret
REDACTED
.
08/17/09 A F York 5.80 Reviewed and revised objections and responses to document
requests from Gallery; reviewed correspondence regarding 20
Casaurina LLC; research on fraudulent transfer claims
REDACTED ; revised and finalized Randi
Stanford reply; prepared exhibits for same and filed Reply.
08/18/09 C N Adams 1.00 Preparing for call regarding international litigation issues;
telephone conference with Joe Cialone regarding same.
08/18/09 D T Arlington 6.20 Addressed account analysis issues; telephone conference with
Kenneth Johnston regarding Trustmark issues; coordinated
with counsel for financial advisors regarding briefing
schedules; reviewed Examiner motions to intervene in appeal;
reviewed motion to withdraw and substitute for financial
advisor; addressed discovery related to relief defendants and
other parties; addressed account release questions; reviewed
MDL order; telephone conference with FTI regarding analysis;
reviewed answer and counterclaim by relief defendant;
reviewed letter regarding insurance issues; telephone
conference with Jason Graham regarding broker motion;
reviewed status of Davis plea; addressed appellate record
issues; reviewed comments to contempt motion reply;
addressed coin motion response; addressed inquiry regarding
coin & bullion customer inquiry; coordinated regarding call
with Farmers & Merchants counsel; reviewed financial advisor
schedule; reviewed status of broker claims; reviewed status of
frozen accounts.
08/18/09 S A D Ayers .60 Reviewed filings in relief defendants actions to draft request to
include additional documents and evidence in the appellate
record that are filed in the SEC's main case.
08/18/09 S M Benhoff 2.00 Collect and summarize witness testimony from Senate Banking
Committee hearing.
08/18/09 J A Cialone, II .80 Attention to court papers.
08/18/09 B A Day 6.00 Drafted requests for production from former financial advisors;
drafted supplemental complaint against former financial
advisors and conferred with FTI regarding total amounts of
commissions, loans, bonuses, and PARS payments to such
financial advisors; reviewed and analyzed documents
REDACTED
392
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 326 of 377
Page 325
Hours Description
08/18/09 J S Fitzwater 3.50 Completing organization of support files for the Litigation
team; updating correspondence involving Stanford-related
litigation; updating pleadings pads in the ('724) Janvey v.
Alguire and ('298) SEC v. Stanford matters; updating the
tracking charts of filings entered by the parties and intervenors;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members; and
updating hosted filings on the Extranet website.
08/18/09 L C Fluker .30 Reviewed correspondence file to locate certified mail return
receipt card for Randy Burton; scanned card and emailed to
Katherine Hinton for use in appendix to motion.
08/18/09 K W Hinton 9.50 Reviewed docket sheet and updated deadlines chart; reviewed
docket sheet and created list of pending motions ripe for
consideration; exchanged emails regarding IRS production;
prepared and e-filed pleadings, served same; researched service
issues and exchanged emails with B. Day regarding same;
researched and reviewed file for correspondence regarding
service to Randy Burton; exchanged emails with S. Ayers
regarding appeal record.
08/18/09 J R Knight .30 Analyzed the Examiner's motion to intervene in the appeal.
08/18/09 J R Knight 3.00 Worked on Appellant's's brief.
08/18/09 J B Lawrence 4.50 Research legal issues REDACTED
.
08/18/09 K M Sadler 7.30 Conference with Arlington regarding broker claims and
strategy; reviewed and commented on response to Galleria
motion; reviewed data from FTI; reviewed pleadings received;
reviewed issues regarding MDL motion; reviewed reply brief
regarding Randi Stanford contempt motion; reviewed issues
REDACTED ; reviewed task list and
issues regarding pending motions.
08/18/09 K K Van Tine 4.30 REDACTED
; reviewing
hearing transcript; discussing legal issues with J. Doty;
analyzing congressional hearing issues; reviewing Dallas court
hearing transcript; REDACTED
08/18/09 M C Wood 2.80 Began reviewing documents supporting our motion to sell one
of Stanford's yachts; Began drafting motion seeking court
approval of the sale of the yacht.
08/18/09 R H Wood 1.90 Researched and wrote memo regarding how courts interpret
REDACTED
;
393
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 327 of 377
Page 326
Hours Description
corresponded with B. Day regarding the same.
08/18/09 A F York 5.90 Reviewed and responded to account holder inquiries; discussed
same with FITS and Arlington; reviewed SCB motions; sought
extension of deadlines for same; filed unopposed motions
regarding same; reviewed and responded to inquiries from
financial advisors; researched fraudulent transfer claims
REDACTED .
08/19/09 C N Adams 3.40 Conference with Ralph Janvey and team regarding
international issues; participation in meeting with DOJ and
SEC regarding same.
08/19/09 D T Arlington 2.60 Addressed discovery issues relating to broker claims; reviewed
other broker claim issues; addressed relief defendant inquiries;
coordinated with financial advisor counsel regarding service
and briefing schedule; reviewed FTI analysis; addressed Holt
discovery deadline; addressed motion deadlines; reviewed
communications regarding appellate motion.
08/19/09 S A D Ayers 4.60 Analyzed issues REDACTED
; telephone conference with
Fifth Circuit regarding relationship between two appeals and
drafted motion to consolidate after conferring with all parties
listed on docket in district and appellate courts in Alguire and
Letsos; conferred with Kevin Sadler, Jim Doty and Kirk Van
Tine REDACTED .
08/19/09 S M Benhoff .80 Review transcript of District Court proceeding.
08/19/09 B A Day 8.50 Drafted requests for production from and interrogatories for
former financial advisors; drafted supplemental complaint
against former financial advisors; reviewed and analyzed
documents relating to partial releases and conferred with
financial team regarding same.
08/19/09 L E Dodge 4.50 Analyzed financial adviser commission data received from
FTI; reviewed client supplemental complaint against financial
advisers.
08/19/09 J R Doty 1.50 Attention to court papers with Kevin Sadler.
08/19/09 T S Durst .80 Further analysis of insurance issues; review of matters
regarding communications to opposing counsel; consideration
of issues regarding contact to carrier.
08/19/09 J S Fitzwater 2.30 Updating pleadings pads in the ('724) Janvey v. Alguire and
('298) SEC v. Stanford matters; updating the tracking charts of
filings entered by the parties; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; updating hosted filings on the Extranet
394
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 328 of 377
Page 327
Hours Description
website; and updating Response Deadlines chart.
08/19/09 L C Fluker .20 Reviewed Excel tracking chart and correspondence file to
locate any relevant documents and name of counsel for Hank
Mills.
08/19/09 J R Knight 2.80 Analyzed cases and drafted standard of review section of the
Appellant's's brief; worked on statement of facts.
08/19/09 J B Lawrence 2.50 Research
REDACTED
; draft analysis of same.
08/19/09 R C Lewis 2.40 Drafted motions for sale of private equity investments;
prepared supplement to Motion to Show Cause and filed same;
conference with Sam Cooper regarding upcoming motions.
08/19/09 K M Sadler 9.80 Reviewed issues regarding KVT declaration requested by DOJ;
reviewed issues regarding Galleria case; reviewed issues
regarding Equity advisor and related motions; reviewed issues
regarding broker and investor claims; conference with Van
Tine and Doty regarding SEC; consultations with Receiver
regarding various issues; reviewed pleadings received;
reviewed and edited pleading regarding Stanford spouse
contempt motion; reviewed affidavit of attorney; reviewed
investor inquiries regarding coin motion; reviewed issues
regarding Holt discovery; reviewed correspondence from
Mendes Mount; reviewed updated data analysis from FTI;
reviewed issues regarding MDL proceedings.
08/19/09 K K Van Tine 2.60 Reviewing arguments REDACTED
; conference call with J. Doty and K. Sadler
REDACTED
08/19/09 M C Wood 2.10 Finished drafting motion and proposed order seeking court
approval of sale of Stanford yacht.
08/19/09 R H Wood .20 Spoke with A. York REDACTED
; forwarded A.
York memo REDACTED .
08/19/09 A F York 4.20 Researched law on fraudulent transfer claims
REDACTED
; reviewed and responded to account
holder inquiries; analyzed and provided comments
REDACTED
gathering efforts regarding same.
08/20/09 C N Adams 1.00 Telephone conference with group regarding follow up
information for SEC; preparing same.
08/20/09 D T Arlington 7.00 Addressed issues relating to equipment insurance and Farmers
& Merchants motion; telephone conference with opposing
395
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 329 of 377
Page 328
Hours Description
counsel regarding same; participated in team meeting regarding
pending matters and claims; addressed financial advisor
investigation and discovery issues; reviewed affidavit of Karyl
Van Tassel; telephone conference with FTI regarding status of
analysis; addressed account release issues; addressed issues
relating to Holt discovery requests; addressed briefing schedule
issues with counsel for relief defendants.
08/20/09 S A D Ayers 4.60 Drafted and conferred with the parties on motion for
supplemental record on appeal in Alguire and Letsos; attention
to deadlines for responses and replies to pending motions;
attention to draft of appellate brief in support of Joe Knight;
telephone conference with lawyer for relief defendant's
attorney regarding answer date; responding to requests from
Florida Bar for information regarding motion against Beki
Reeves; attention to request for discovery from Laura Holt.
08/20/09 S M Benhoff 1.10 Research federal database.
08/20/09 B A Day 4.00 Attended status/strategy meeting with Kevin Sadler, David
Arlington, Sue Ayers, and Andrew York; drafted supplemental
complaint against former financial advisors; reviewed and
analyzed documents relating to partial releases and conferred
with financial team regarding same; coordinated research
project with Radney Wood REDACTED
.
08/20/09 L E Dodge 6.00 Prepared appendix for supplemental complaint against
financial advisers; reviewed summary received from FTI of
electronic data available for financial advisers; met with D.
Arlington to discuss financial adviser issues.
08/20/09 T S Durst 1.20 Analysis of issues court filings on insurance issues and related
pending litigation; conference with team regarding pending
matters.
08/20/09 J S Fitzwater 5.80 Assisting Tim Durst to research pleadings and correspondence
involving the D&O Insurance policy; monitoring court filings
and assisting attorney team to coordinate reception of filings to
appropriate members; updating hosted filings on the Extranet
website; updating correspondence involving Stanford-related
litigation; continuing to update the Response Deadlines chart;
assisting John Lawrence to research pleadings related to (2005-
72230) Stanford Group Holdings v. Walton Houston Gallery
Office; updating the tracking charts of filings entered by the
parties; and updating pleadings pads in the ('10761) Janvey v.
Alguire, ('10765) Janvey v. Letsos and ('298) SEC v. Stanford
matters.
08/20/09 J R Knight 3.70 Drafted introduction to the argument section and analyzed Fifth
396
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 330 of 377
Page 329
Hours Description
Circuit authority for the Appellant's's brief.
08/20/09 T W Mountz 1.20 Conference with D. Arlington re discovery requests; review of
discovery requests from Holt; emails to J. Cialone re discovery
requests.
08/20/09 K M Sadler 9.70 Reviewed Holt discovery issues and responses; reviewed data
from FTI; conference with litigation team regarding tasks and
assignments; conference with FTI regarding data analysis;
conference with Knight regarding appellate issues; reviewed
D&O issues; conference with Cooper regarding various issues;
reviewed issues regarding Provence investor accounts;
reviewed issues regarding broker claims; reviewed legal
research REDACTED ; conference with FTI
regarding declaration for DOJ.
08/20/09 K K Van Tine 1.90 Conference call to review status of pending issues; reviewing
briefs; outlining agenda and policy issues for discussion
08/20/09 M C Wood .30 Emailed David Arlington forwarding him a draft motion to sell
the Little Eagle yacht.
08/20/09 R H Wood 2.80 Researched issues REDACTED
08/20/09 A F York 4.20 Conference with Sadler, Arlington, Ayers, regarding broker
claims, Barnes claim, pending motions, and open issues;
prepared request for information to Ben Barnes Group;
reviewed Barnes Group's initial document production; analyzed
and responded to account holder inquiries.
08/21/09 C N Adams .40 Attention to Holt RFPs.
08/21/09 D T Arlington 4.80 Worked on discovery responses to Holt; reviewed Paradigm
information; addressed account release and draw down issues;
addressed Barnes request.
08/21/09 S A D Ayers 5.30 Responding to inquiries from American Express regarding
reimbursement of employee expenses; finalized, conferred and
filed motion to consolidate appeals; finalized, conferred and
filed motion to supplement record; drafted summary of U.S.
Receivership events on request from Osler firm; reviewed and
produced documents to Internal Revenue Service; telephone
conference with clerk for Northern District of Texas and
arranged for pick up of appellate record and delivery to
Examiner; communicated with Karyl Van Tassel regarding
documents for production to Internal Revenue Service.
08/21/09 J A Cialone, II .80 Calls and emails about responses to Holt discovery requests.
08/21/09 B A Day 9.10 Finished draft supplemental complaint
REDACTED ; reviewed and analyzed
397
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 331 of 377
Page 330
Hours Description
documents relating to partial releases and conferred with
financial team regarding same.
08/21/09 T S Durst .40 Attention to issues regarding filings on insurance issues and
status, including consideration of needed additional filings.
08/21/09 J S Fitzwater 6.50 Retrieving appellate records for the ('724) Janvey v. Alguire
and ('1329) Janvey v. Letsos matters, assembling a copy of the
records for Joe Knight of the Austin office, and preparing
original records for transmittance to John Little and Eugene
Wilshire; updating hard and electronic correspondence
involving Stanford-related litigation; monitoring court filings
and assisting attorney team to coordinate reception of filings to
appropriate members; updating pleadings pads in the ('298)
SEC v. Stanford, ('10761) Janvey v. Alguire and ('10765)
Janvey v. Letsos matters; updating the tracking charts of filings
entered by the parties and intervenors; and updating hosted
filings on the Extranet website, including searchable text.
08/21/09 K L Karp .80 Begin draft of response log to L. Pendergest-Holts' discovery
requests.
08/21/09 J R Knight .60 Reviewed and suggested revisions to motion to consolidate and
motion to supplement the record.
08/21/09 J R Knight 2.90 Worked on Appellant's's brief.
08/21/09 R C Lewis 3.20 Researched issues REDACTED
; reviewed and
commented on Walton for Relief from Receivership Order;
reviewed and revised appendix and declarations related to same
and prepared for filing; phone call with John Greer regarding
status of private equity investments.
08/21/09 T W Mountz 1.80 Telephone conference with D. White at Thompson Knight re
responses to Holt discovery requests; email to D. White re
requests; conference with D. Arlington re responses to
requests; review of draft responses to RFAs.
08/21/09 K M Sadler 9.90 Reviewed issues regarding response to Holt discovery requests;
reviewed issues regarding pending motion regarding Midway
investments; reviewed correspondence from RD counsel;
reviewed correspondence from Hunton & Williams; reviewed
issues regarding response to Galleria motion and strategy
related to Galleria claim; reviewed issues regarding Citigroup
inquiry on paradigm fund; reviewed case research and cases on
UFTA claims and related discovery issues; reviewed issues
regarding Florida real estate; reviewed correspondence and
related research regarding insurance issues.
08/21/09 N M Starbuck 1.20 Begin draft of response log to L. Pendergest-Holts' discovery
398
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 332 of 377
Page 331
Hours Description
requests.
08/21/09 R H Wood 2.10 Corresponded with B. Stutts regarding assets in Canada;
researched issues surrounding REDACTED
08/21/09 A F York 2.60 Prepared request for information to Ben Barnes Group;
responded to account holder inquiries; discussed same with
FITS and Stanford Eagle team; conferred with opposing
counsel regarding response deadlines and extensions; reviewed
mail forwarded from Stanford real estate LLC.
08/22/09 D T Arlington 6.90 Worked on responses to Holt's discovery requests and
coordinated with team regarding same.
08/22/09 J A Cialone, II 1.00 Considered and discussed with team by emails various
discovery questions including privilege and work product
claims.
08/22/09 B A Day .80 Incorporated Kevin Sadler's comments into the supplemental
complaint against former financial advisors; researched claims
asserted by the SEC REDACTED .
08/22/09 T W Mountz 2.50 Review of emails re requests for admissions and requests for
production from Holt; emails to Kristie Blumenschein and D.
Arlington re responses to RFAs; emails to J. Cialone and K.
Sadler re privilege issues and responses to discovery requests.
08/22/09 K M Sadler 3.20 Reviewed issues regarding holt discovery; reviewed issues
regarding examiner inquiries; reviewed issues regarding
clawback claims in Madoff case; reviewed issues regarding
pending motions; reviewed information from FTI.
08/22/09 K K Van Tine .30 Reviewing reports re SEC action against investor in Madoff
cases
08/22/09 A F York 1.90 Analyzed Holt RFA objections and responses and reviewed
comments to same; reviewed Receiver's prior filings to ensure
consistency with objections and responses.
08/23/09 C N Adams .40 Reviewing requests for production.
08/23/09 D T Arlington 1.50 Revised discovery responses to Holt and communicated with
team regarding same; reviewed FTI analysis.
08/23/09 S A D Ayers 1.50 Analyzed and edited Supplemental Complaint against Financial
Advisors; Analyzed and edited Response to Requests for
Admission and Requests for Production from Laura Holt.
08/23/09 B A Day .80 Incorporated Sue Ayers's comments into the supplemental
complaint against former financial advisors; drafted transmittal
e-mail for Supplemental Complaint and sent same to Kevin
399
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 333 of 377
Page 332
Hours Description
Sadler.
08/23/09 T W Mountz .40 Review of responses to Holt production requests.
08/24/09 C N Adams .80 Attention to discovery issues regarding broker litigation.
08/24/09 D T Arlington 4.50 Addressed relief defendant service issues; worked on and
finalized discovery responses to Holt; prepared draft response
to Examiner regarding multiple issues; addressed issues
relating to financial advisor analysis; REDACTED
; conferences with team regarding relief
defendant issues; addressed account release issues; reviewed
supplemental complaint; reviewed recent filings.
08/24/09 S A D Ayers 3.40 Attention to deadlines for responses and replies to motions;
attention to correspondence from various stakeholders;
attention to appeal (locating documents/facts in the record for
briefing and procedures for citing to unpublished cases);
addressed comments to Supplemental Complaint from Kristie
Blumenschein; attention to responses in opposition to real
estate motion.
08/24/09 B A Day 6.50 Revised response to financial advisors' motion to unfreeze
accounts; reviewed Kristie Blumenschein's comments to the
Supplemental Complaint against Stanford Financial Group
Advisors and drafted responses regarding such comments;
revised Supplemental Complaint; reviewed and analyzed
documents relating to partial releases and conferred with
financial team regarding same.
08/24/09 L E Dodge 9.00 Revised and supplemented financial adviser database; revised
and supplemented appendix to supplemental complaint against
financial advisers; summarized financial adviser address and
attorney information.
08/24/09 T S Durst 1.40 Analysis of issues regarding discovery, stay and related
insurance matters for the Court's attention; review of new
filings regarding same; communications with team regarding
same and needed response/strategy.
08/24/09 J S Fitzwater 4.80 Updating hosted filings on the Extranet website; updating the
tracking charts of filings entered by the parties and intervenors;
monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating discovery involving Stanford-related litigation;
updating hard and electronic correspondence involving
Stanford-related litigation; organizing support files for the
Litigation team; updating the Response Deadlines chart; and
updating pleadings pads in the ('298) SEC v. Stanford matter.
08/24/09 M A Gold .50 Attention to report to court.
400
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 334 of 377
Page 333
Hours Description
08/24/09 K L Karp 5.00 Begin draft of response log to L. Pendergest-Holts' discovery
requests.
08/24/09 J R Knight 3.70 Worked on Appellant's's brief.
08/24/09 T W Mountz 1.60 Review of responses to Holt discovery requests; conferences
with D. Arlington re requests; conference with J. Cialone re
discovery requests.
08/24/09 K M Sadler 11.20 Reviewed issues regarding supplemental complaint; reviewed
and revised complaint; consultations with Receiver regarding
various issues; conferences with FTI regarding data analysis;
reviewed issues regarding STC; reviewed issues regarding
information for examiner; reviewed pleadings received;
reviewed equity motions; conference with Court staff;
conferences with Cooper regarding motions; reviewed issues
regarding investor complaints; reviewed data analysis
regarding brokers; reviewed issues regarding appeal; reviewed
cases regarding UFTA.
08/24/09 K Scanlan 3.50 Review request for specific case materials from Mary Scott;
on-line research concerning Mississippi litigation; telephone
conference with clerk regarding suit and to request copies of
suit; review request for materials from John Lawrence and
locate and forward materials as requested; update filing and
review numerous filings and update charts.
08/24/09 N M Starbuck 4.10 Drafted response log to L. Pendergest-Holts' discovery
requests; Reviewed production files REDACTED
08/24/09 K K Van Tine .80 Outlining issues in preparation for potential hearing
08/24/09 M C Wood .50 Conference with Radney Wood REDACTED
08/24/09 R H Wood 2.20 Researched REDACTED
; began writing memo on the same.
08/24/09 A F York 4.80 Finalized and sent request for information to Barnes Group;
prepared and filed motions for extension in real estate matters;
reviewed court papers and prepared to respond to Hassell
motions regarding real estate liens; locate petition in new bank
lawsuit; responded to account holder inquiries.
08/25/09 C N Adams .50 Reviewing broker issue regarding pending claim.
08/25/09 D T Arlington 5.80 Addressed property motion response; telephone conference
with SEC; worked on supplemental complaint and issues
related to same; addressed inquiries from relief defendants;
addressed investigation relating to broker records; reviewed
401
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 335 of 377
Page 334
Hours Description
FTI analysis; reviewed insurance issues; telephone conference
with FTI regarding analysis issues.
08/25/09 S A D Ayers 7.10 Drafted correspondence for Receiver's signature; reviewed
documents filed by other parties today in SEC v. Stanford;
attention to appeal, locating documents in record for citation in
Appellant's's brief; attention to Supplemental Complaint and
request for summons from the clerk; edited response to motion
to unfreeze accounts held by financial advisors.
08/25/09 S M Benhoff 2.50 Review District Court briefs REDACTED
.
08/25/09 J A Cialone, II .80 Reviewed court of appeals papers; reviewed bank lawsuit
papers filed in Houston.
08/25/09 B A Day 9.10 Revised response to financial advisors' motion to unfreeze
accounts; finalized appendix in support of same; revised
Supplemental Complaint; finalized appendix in support of
same; reviewed and analyzed documents relating to partial
releases and conferred with financial team regarding same.
08/25/09 L E Dodge 6.50 Supplemented financial adviser database; revised and
supplemented appendix to supplemental complaint against
financial advisers; researched summarized financial adviser
address and attorney information.
08/25/09 J S Fitzwater 1.80 Assisting John Lawrence regarding pleadings profiling in the
('298) SEC v. Stanford matter; monitoring court filings and
assisting attorney team to coordinate reception of filings to
appropriate members; updating hosted filings on the Extranet
website; and assisting Tim Mountz regarding Pendergest-Holt's
motion for payment of fees in the ('342) USA v. Stanford
matter.
08/25/09 L C Fluker .30 Reviewed correspondence file to locate examples of
Receivership's letterhead; provided information on letterhead to
Valencia Walker.
08/25/09 K W Hinton 7.50 Reviewed and cite-checked legal cites in the Supplemental
Complaint and Response to Motion to Modify Receivership
Order; supervised and assisted with records cite check;
prepared and revised Appendix; met with B. Day regarding
Appendix documents; revised service lists and assisted with
service of supplemental complaint; proofed and revised
complaint and response; prepared and e-filed motion to extend
deadline; coordinated with B. Day regarding summonses and
personal service.
08/25/09 J R Knight 3.10 Consultations with Kevin Sadler and Sue Ayers regarding
strategy; analyzed record and worked on brief.
402
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 336 of 377
Page 335
Hours Description
08/25/09 J B Lawrence 5.00 Research whether documents shared or communications made
REDACTED .
08/25/09 K M Sadler 9.20 Reviewed and revised correspondence to court; reviewed issues
REDACTED ; reviewed
issues regarding insurance dispute and filings in criminal case;
reviewed issues regarding correspondence from FA regarding
claim and loan; reviewed and revised supplemental complaint
and reviewed data regarding same from FTI; consultations with
client regarding broker claims; reviewed claims filed against
third party banks; reviewed issues regarding Florida property;
reviewed issues regarding responses and objections to Holt
discovery requests; reviewed issues regarding appeal and draft
brief.
08/25/09 K Scanlan 1.30 Pull materials relating to appeals and related motions in SEC
main case; prepare notebook.
08/25/09 K K Van Tine 1.90 Drafting and revising outline of issues in preparation for
anticipated hearings
08/25/09 M C Wood 1.50 Reviewed conflicts reports; Contacted attorneys to clear
potential conflicts.
08/25/09 R H Wood 3.20 Researched REDACTED ;
wrote memo regarding the same.
08/25/09 A F York 4.50 Research with Westlaw rep REDACTED
; reviewed Hassell
filings; sought extension and filed motion regarding same;
reviewed and responded to account holder and FA inquiries;
emails with FTI, FITS, and Stanford Eagle regarding same;
conferred with K. Schlanger regarding real estate issues.
08/26/09 C N Adams .70 Telephone conference with ACA Compliance regarding
subpoena and privilege issues.
08/26/09 D T Arlington 7.30 Worked on and addressed issues relating to supplemental
complaint against financial advisors; telephone conference with
counsel for Trustmark; reviewed complaint against Trustmark;
worked on Little Eagle sale motion; reviewed scheduling
proposal from counsel for financial advisors; addressed
inquiries from financial advisors, other relief defendants and
Examiner; addressed account release issues; addressed
discovery issues.
08/26/09 S A D Ayers 5.90 Drafted correspondence for Receiver's signature; reviewed all
court papers filed by other parties today; attention to appellate
record, securing second volume and locating documents to cite
in Appellant's's brief; attention to supplemental complaint,
choice of law, conflicts check and telephone conference with
403
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 337 of 377
Page 336
Hours Description
clerk's office regarding leave to file it; attention to bankruptcy
bar in Amended Order Appointing Receiver; investigated
inquiry by former employee regarding final paycheck; supplied
all briefing on D&O policy to Kevin Sadler and select court
papers and federal rules to Osler for hearing.
08/26/09 M E Burnett .80 Searched Choicepoint for information on Marina Feldman and
Jon Hanna.
08/26/09 J A Cialone, II 1.00 Calls and emails about responses to discovery requests from
Holt's lawyers; reviewed related court papers.
08/26/09 B A Day 4.50 Reviewed and coordinated review of conflicts checks
REDACTED ; finalized and filed response to financial
advisors' motion to unfreeze accounts and appendix in support
of same; finalized and filed Supplemental Complaint and
appendix in support of same.
08/26/09 L E Dodge 7.00 Supplemented financial adviser database; revised appendix to
supplemental complaint against financial advisers; researched
and summarized address and attorney information for financial
advisers.
08/26/09 J S Fitzwater 5.80 Retrieving the second volume of the appellate record in the
('724) Janvey v. Alguire matter and assembling a copy of the
record for Katherine Hinton of the Austin office; assisting Tim
Durst regarding D&O Insurance policy pleadings; updating
pleadings pads in the ('724) Janvey v. Alguire and ('298) SEC
v. Stanford matters; updating discovery involving Stanford-
related litigation; continuing to update the Response Deadlines
chart; organizing case material for attorney review; updating
the tracking charts of filings entered by the parties and
intervenors; updating electronic correspondence involving
Stanford-related litigation; updating hosted filings on the
Extranet website, as well as searchable text; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; and updating the Appearances
from Attorneys for the Intervenors notebook.
08/26/09 J R Knight 2.80 Continued working on Appellant's's brief; finalized statement
of facts.
08/26/09 J B Lawrence 1.60 Continue researching insurer-insured privilege issues;
conference with T. Mountz regarding same.
08/26/09 T W Mountz .30 Conference with J. Lawrence re research on privilege issues.
08/26/09 K M Sadler 10.70 Reviewed issues regarding account release and draw down;
reviewed issues regarding bankruptcy litigation stay in AOAR;
reviewed broker communications regarding complaint;
reviewed issues regarding document production requests from
404
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 338 of 377
Page 337
Hours Description
Holt; reviewed issues regarding appeal, appellate record and
Order regarding new deadlines; reviewed pleadings received;
reviewed issues regarding creditor inquiry concerning claims;
reviewed issues regarding service of supplemental complaint;
reviewed and revised correspondence; conference with Court
staff regarding request for hearing; reviewed legal research
regarding FT claims; reviewed issues regarding briefing
agreement among counsel for brokers; reviewed issues SEC
and DOJ; reviewed issues regarding private equity holdings;
reviewed FTI data analysis regarding brokers' compensation;
reviewed issues regarding Davis plea proceedings; conference
with Court staff regarding Orders on pending motions;
conference with Mountz regarding insurance issues; reviewed
issues regarding documents requested by brokers.
08/26/09 K Scanlan .80 Assist in pulling requested materials for use as exhibits in
upcoming motion response; revise memo to Tim Durst.
08/26/09 K K Van Tine 1.80 Conference with J. Doty re SEC issues; attention to issues for
anticipated hearings
08/26/09 M C Wood 1.60 Reviewed more conflict reports REDACTED
; Contacted attorneys to clear conflicts.
08/26/09 R H Wood 1.80 Researched and wrote memo REDACTED ;
corresponded with B. Day, K. Sadler, and S. Cooper regarding
the same.
08/26/09 A F York 3.00 Reviewed and responded to account holder inquires; emails
with FTI regarding same; reviewed FTI workups; researched
fraudulent transfer claims REDACTED
;
reviewed memo REDACTED .
08/27/09 C N Adams .40 Preparing posting regarding broker lawsuit.
08/27/09 D T Arlington 9.10 Reviewed recent filings; reviewed FTI analysis; addressed
account release and draw down issues; reviewed and
researched Examiner inquiries; reviewed materials relating to
Davis plea; reviewed drafts of motion to approve yacht sale;
worked on statement regarding supplemental complaint;
worked on summary judgment motion; addressed broker
discovery and investigation issues; researched relief defendant
inquiries; reviewed bulk transfer motion.
08/27/09 S A D Ayers 3.20 Reviewed all pleadings filed today; attention to inquiry from
former employee regarding final paycheck; edited motion to
make bulk transfer of released accounts; attention to new
lawsuits filed in four jurisdictions; reviewed and analyzed plea
agreement by James Davis.
08/27/09 B A Day 2.00 Attended conference call with FTI regarding the analysis of
405
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 339 of 377
Page 338
Hours Description
interest and principal amounts from SIB CDs; reviewed and
analyzed documents relating to partial releases and conferred
with financial team regarding same; coordinated research of
standing of Receiver to bring claims against law firm.
08/27/09 J S Fitzwater 1.80 Updating support files for the Litigation team; monitoring court
filings and assisting attorney team to coordinate reception of
filings to appropriate members; and preparing original record
of the second volume of the appellate record in the ('724)
Janvey v. Alguire matter for transmittance to John Little.
08/27/09 K W Hinton 9.00 Prepared summons for supplemental complaint; reviewed and
edited service list for supplemental complaint; communicated
with process server regarding cost of service and options;
communicated with B. Day regarding same; drafted emails to
B. Day, S. Ayers and D. Arlington regarding cost of service
and options; supervised and assisted with updating shared
drive; reviewed filings for missing certificate of service per
notice from court; exchanged emails with S. Ayers regarding
same; call to court regarding same; created certificate of
service for Appendix, prepared and e-filed same; drafted email
to team regarding certificate of service requirement; prepared
appendix for sale of little eagle motion; updated SEC v.
Stanford tracking and deadlines charts; reviewed cases and
correspondence regarding new case; exchanged emails with S.
Ayers regarding post-receiver deadlines chart; drafted email to
L. Dodge with instructions for updating post-receiver deadlines
chart.
08/27/09 R C Lewis 5.30 Attended hearing related to arraignment of James Davis;
drafted summaries of same; prepared for and participated in
two conference calls with Park Hill Group regarding private
equity deals; reviewed and commented on information related
to same received by Park Hill; revised and circulated new draft
of Motion for Sale of InSound and Memphis Biomed.
08/27/09 K M Sadler 9.60 Reviewed issues and information regarding Davis plea
proceedings; reviewed issues regarding Pershing litigation;
reviewed issues regarding FTI data analysis; reviewed issues
regarding broker claims; reviewed investor inquiry regarding
account release; reviewed pleadings in class action case;
reviewed issues regarding IOF motion and claim; reviewed
pleadings received; reviewed communications from attorneys
regarding claims against law firm; reviewed issues regarding
bulk transfer motion; conference with Court staff regarding
hearing; reviewed Orders received regarding private equity
sales; reviewed issues regarding requests for information;
conference with FTI regarding data analysis; conference with
406
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 340 of 377
Page 339
Hours Description
Mountz regarding insurance issues.
08/27/09 K Scanlan 3.10 Work with James Fitzwater to update various files; review new
filings and being review of deadlines chart for updating and
double-checking accuracy and completeness of all deadlines
charts; pull materials relating to pending motions to intervene
and prepare small notebook for same.
08/27/09 M C Wood 2.80 Revised Little Eagle motion in light of David Arlington's
comments and new evidence; Conference with Brendan Day to
discuss facts REDACTED .
08/27/09 R H Wood 2.30 Researched and wrote memo on receivership standing to
REDACTED
; corresponded with B. Day, K. Sadler,
S. Cooper, S. Ayers, and A. York regarding the same.
08/27/09 A F York 5.20 Researched fraudulent transfer claims; reviewed and responded
to account holder inquiries; emails with FTI and Stanford Eagle
regarding same; prepared for FA document and data review in
Houston; conference with FTI regarding proceeds issues;
08/28/09 C N Adams .30 Attention to posting regarding broker litigation.
08/28/09 D T Arlington 3.50 Finalized filing relating to Little Eagle; addressed inquiries
from Examiner; addressed inquiries from relief defendants;
coordinated with opposing counsel regarding briefing schedule;
reviewed FTI analysis; telephone conference with FTI
regarding same; addressed relief defendant service issues.
08/28/09 S A D Ayers 2.00 Edited, finalized, conferred with opposing counsel and filed
Bulk Transfer motion and motion for sale of Little Eagle;
telephone conference with attorneys for financial advisor relief
defendants; telephone conference and delivered copies of
filings to Pierpont.
08/28/09 J A Cialone, II 1.00 Attention to letter from Holt's lawyer challenging privilege
claims; attention to privilege claims.
08/28/09 B A Day 5.10 Attended conference call with FTI regarding the analysis of
interest and principal amounts from SIB CDs; reviewed and
analyzed documents REDACTED and conferred
with financial team regarding same; revised and filed motion to
approve sale of the Little Eagle yacht.
08/28/09 J S Fitzwater 6.30 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating the Response Deadlines chart; updating support files
for the litigation team and for attorney review; assisting Kevin
Scanlan regarding Pendergest-Holt's First Request for
407
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 341 of 377
Page 340
Hours Description
Production; updating hard and electronic correspondence;
updating pleadings pads in the ('10761, '724) Janvey v. Alguire,
('10765) Janvey v. Letsos and ('298) SEC v. Stanford matters;
updating the tracking charts of filings entered by the Parties;
updating the Appearances from Attorneys for the Intervenors
notebook; and updating hosted filings on the Extranet website,
as well as searchable text.
08/28/09 J R Knight 1.60 Completed first draft of the main argument sections.
08/28/09 K M Sadler 10.40 Reviewed strategy issues REDACTED ;
reviewed strategy issues REDACTED ;
reviewed issues regarding FTI analysis; communications to
client regarding same; reviewed issues regarding Galleria
litigation; reviewed issues regarding REDACTED
; reviewed data from FTI;
reviewed pleadings received; reviewed issues regarding
communications with investors at STC; reviewed
communications from broker counsel; reviewed issues
regarding briefing on broker claims; consultations with client;
reviewed issues regarding property motions regarding Davis;
reviewed bulk transfer motion; reviewed asset sale motion
regarding boats; reviewed communications from attorney for
financial advisors.
08/28/09 K Scanlan 2.50 Work with James Fitzwater to update materials; office
conference with Tim Durst regarding correspondence from
Holt's counsel regarding responses to discovery requests; pull
materials for Tim Durst to review regarding same; prepare
transmittal letter to Charlie Gale returning mail for Mr. Davis
that was accidentally caught by Post master in Baldwyn
Mississippi in the Holt mail; pull additional pleadings and
review correspondence for Tim Durst.
08/28/09 M C Wood 1.10 Made two more rounds of revisions to the Little Eagle
documents to reflect David Arlington's and Brendan Day's
comments; Prepared the documents for filing.
08/28/09 A F York 4.10 Conference call with FTI and Arlington regarding document
and data review; conference call with FTI, Arlington, Day
regarding proceeds issues; reviewed and responded to account
holder inquiries; emails with FTI and Stanford Eagle regarding
same and proceeds issues; reviewed real estate issues regarding
Baldwyn properties; numerous emails regarding same;
reviewed correspondence with Stanford Trust account holders.
08/29/09 D T Arlington .30 Reviewed potential summary judgment grounds.
08/30/09 D T Arlington 1.30 Reviewed potential summary judgment issues; addressed
account release issue; reviewed FTI analysis issues; researched
408
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 342 of 377
Page 341
Hours Description
regarding Examiner inquiries.
08/30/09 B A Day 1.00 Drafted brief memo to David Arlington
REDACTED
.
08/30/09 R C Lewis 4.60 Drafted and revised motion for sale of HSS investment based
on new information from Park Hill Group; revised motion for
sale of InSound and Memphis Biomed Investment; reviewed
new filings in SEC main case.
08/30/09 R H Wood 1.40 Researched whether or not Receiver has standing
REDACTED ;
corresponded with B. Day and K. Sadler regarding the same.
08/31/09 D T Arlington 4.70 Reviewed issues relating to bulk transfer motion; reviewed
materials relating to STC account closures; addressed Farmers
negotiation; researched regarding relief defendants; addressed
relief defendant inquiries; addressed Examiner inquiries;
telephone conference with FITS regarding same; addressed
coin company issues; addressed account release issues;
coordinated with team regarding broker discovery and
document review.
08/31/09 B A Day 4.80 Drafted motion for summary judgment REDACTED
.
08/31/09 L E Dodge 1.50 Supplemented financial adviser database.
08/31/09 T S Durst .60 Attention to issues regarding upcoming hearing and matters for
report to court; consideration of issues regarding new lawsuits.
08/31/09 J S Fitzwater 2.50 Monitoring court filings and assisting attorney team to
coordinate reception of filings to appropriate members;
updating pleadings indices in the ('298) SEC v. Stanford
matter; updating hosted filings on the Extranet website;
updating the tracking charts of filings entered by the parties;
and organizing support files for the litigation team.
08/31/09 J R Knight 3.90 Worked on Appellant's's brief; drafted arguments regarding
REDACTED ; drafted arguments regarding
other elements of injunction claim.
08/31/09 R C Lewis 2.40 Revised motions for sale of private equity interests, including
HSS, Memphis Biomed, and InSound; circulated same to
working group; conference with John Greer regarding status of
REDACTED deals; reviewed plea agreement
and orders entered at Davis arraignment hearing.
08/31/09 K M Sadler 9.30 Consultations with client; conference with Cooper regarding
Galleria case; conferences with Arlington regarding FTI data
409
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 343 of 377
Page 342
Hours Description
and pleadings strategy; conference with Ayers regarding
pending motions; reviewed communications from investor
counsel; reviewed pleadings received; reviewed draft motion
REDACTED ; reviewed issues regarding examination of broker
files; reviewed draft communications to investors; reviewed
issues regarding REDACTED bulk transfer motion; reviewed
issues regarding 5th circuit appeal; reviewed issues
REDACTED ; reviewed information regarding asset
sales; conference with SCC regarding asset inventory and
related issues; reviewed issues and strategy regarding broker
claims; reviewed issues regarding Ft. Lauderdale subpoena
08/31/09 K Scanlan 1.90 Office conference with Tim Durst regarding upcoming filings;
pull materials relating to new suit filed inn Northern District
regarding insurance filed by Pulman attorney group; prepare
materials regarding specific new motions and suits filed
recently for Tim Durst; review request for materials from Mary
Scott; locate materials requested, download, format and
forward to Mary Scott.
08/31/09 A F York 5.00 Conference with Arlington and L. Dodge regarding document
and data review; preparation for same; reviewed broker
complaint; prepared and filed Reply in support of joint motion
regarding coin and bullion; responded to account holder
inquiries; discussed same with FITS and Stanford Eagle;
emails regarding Baldwyn properties; reviewed docket sheet
and upcoming deadlines; finalized research on fraudulent
transfer claims.
Matter Total 3,862.90
079716.0118 Switzerland Matters
Hours Description
06/02/09 W F Stutts, Jr. .40 Reviewed status of question from Florence Pastore regarding
position to be taken with K. Blumenschein for response and
prepared response for Ms. Pastore; related communications
with Ms. Blumenschein regarding status in Switzerland.
06/03/09 W F Stutts, Jr. .80 Reviewed with Ms. Pastore (Altenburger) updated information
on progress of Swiss proceeding in FINMA and issues raised;
communications with Mr. Cooper on the FINMA impacts.
06/04/09 S W Cooper .20 Reviewed material to be filed on receivership authorization.
06/04/09 W F Stutts, Jr. 1.90 Communication regarding developments with Ms. Sambeth
Glasner and Ms. Pastore; reviewed draft opposition submitted
by Ms. Pastore; communications with her regarding same;
410
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 344 of 377
Page 343
Hours Description
transmittal of comments on same.
06/05/09 W F Stutts, Jr. 1.40 Communication of comments and questions to Swiss counsel
regarding FINMA application.
06/09/09 S W Cooper 1.00 Attended to issues regarding building sale.
06/09/09 W F Stutts, Jr. 2.20 REDACTED
;
communications with Ms. Peregrina and provision of
information on case status in other than her jurisdictions;
addressed facts to clarity procedures and status on property sale
by Swiss liquidators of Swiss subsidiary.
06/10/09 S W Cooper 1.40 Worked with Steve Massad REDACTED ;
telephone conference with Bill Stutts on receiver recognition
issues.
06/10/09 W F Stutts, Jr. .90 Prepared statement explaining sale of Swiss property by Swiss
liquidators of Swiss subsidiary; reviewed information
regarding Swiss financial statements.
06/11/09 S W Cooper .40 Attended to issues regarding building sale.
06/16/09 S W Cooper .30 Worked on issues regarding recognition filings in Switzerland.
06/16/09 W F Stutts, Jr. 1.10 Information from Ms. Pastore on FINMA letter received today;
reviewed status and open issues and points to be covered to
respond to questions from regulator.
06/17/09 S W Cooper 1.20 Telephone conference with Bill Stutts regarding status of Swiss
issues; attended to issues regarding receivership recognition;
attended to issues regarding building sale.
06/17/09 W F Stutts, Jr. .40 Additional communications with Altenburger on FINMA
requirements and questions including status and time frames.
06/18/09 S W Cooper .40 Telephone conference with Swiss counsel regarding status of
matters.
06/18/09 W F Stutts, Jr. .40 Several communication with Ms. Sambeth Glasner regarding
status of proceedings in CH reviewed and translated and
distributed information from Ms. Pastore on FINMA
procedures.
06/19/09 S W Cooper .40 Exchanged email with Bob Howell regarding additional
material to supply Swiss counsel REDACTED .
06/19/09 W F Stutts, Jr. 1.20 Reviewed additional information and provisions regarding
Swiss letter from Ms. Pastore and additional points for
inclusions in filing; addenda to transmittal and information
regarding indictment; worked on transmittal of documents
related to receiver response to Chapter 15 motion.
411
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 345 of 377
Page 344
Hours Description
06/22/09 S W Cooper .20 Attended to developments regarding recognition motion.
06/24/09 W F Stutts, Jr. .30 Reviewed new information from Switzerland regarding
proceedings before FINMA.
06/26/09 W F Stutts, Jr. .30 Additional information received from CH regarding extension
for filing of observation regarding Antiguan liquidators
statement.
07/08/09 S W Cooper .20 Attended to Swiss receiver recognition issues.
07/13/09 W F Stutts, Jr. .80 Arrangements for documentation to Swiss counsel to
encourage fuller presentation of issues.
07/13/09 W F Stutts, Jr. .80 Reviewed and analyzed issue raised by Mrs. Sabati of Swiss
FINMA and instructed Mr. A. Turner REDACTED
07/14/09 W F Stutts, Jr. 2.20 SWITZERLAND Pastore.
07/14/09 A S Turner 1.20 Researching U.S. insolvency regimes
REDACTED
; drafting
memorandums in connection with same.
07/15/09 S W Cooper .40 Revised proxy for shareholder meeting; reviewed material from
Swiss counsel.
07/15/09 A S Turner 5.90 Researching REDACTED
; drafting
memorandums in connection with same.
07/16/09 J A Cialone, II .80 Attention to Swiss asset developments; related calls and emails.
07/16/09 W F Stutts, Jr. 1.70 Switzerland; fp and Bob Howell; reviewed information
regarding shareholder meeting and consent to information
receipt; obtained same.
07/16/09 W F Stutts, Jr. .80 Reviewed information from Mr. Turner REDACTED
.
07/16/09 A S Turner 5.20 Researching REDACTED
; drafting
memorandums in connection with same.
07/17/09 M E Burnett .70 Obtained manual on foreign bank branches issued by the OCC
for Bill Stutts.
07/17/09 W F Stutts, Jr. 1.30 Proxy; from Pastore regarding question from FINMA;
412
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 346 of 377
Page 345
Hours Description
instructions to Aaron Turner; outline of issue; communications
with Lisa Villarreal on position of Fed.
07/17/09 W F Stutts, Jr. .30 Communications with Ms. Pastore regarding request from Mr.
Lamon (at the CH federal prosecutor's office).
07/17/09 A S Turner 1.30 REDACTED
; drafting
memorandums in connection with same.
07/20/09 W F Stutts, Jr. 2.40 Reviewed issues requested by FINMA and addressed questions
REDACTED ; telephone conferences
with Ralph Janvey and Kristie Blumenschein regarding same;
brief communications with Mr. Cialone and Mr. Howell
regarding documentation, status, and issues to be covered;
communications with Ms. Pastore regarding same.
07/20/09 W F Stutts, Jr. 2.40 Communications with Mr. Janvey and leaders in representation
regarding status and specific positions being taken in Swiss
recognition proceedings.
07/21/09 M E Burnett .20 Searched for OCC manual for Bill Stutts.
07/21/09 J A Cialone, II 1.00 Attention to Swiss developments and related emails
07/21/09 W F Stutts, Jr. .40 Communications with Ms. Pastore.
07/21/09 A S Turner .70 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
.
07/22/09 W F Stutts, Jr. 4.80 Description of U.S.> insolvency processes and distribution
REDACTED .
07/22/09 A S Turner 1.50 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
413
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 347 of 377
Page 346
Hours Description
07/23/09 A S Turner 1.20 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
07/24/09 W F Stutts, Jr. 1.90 Instructions to Aaron Turner regarding analysis and worked on
background information for analysis to FINMA.
07/24/09 W F Stutts, Jr. .80 Reviewed and compared priorities in insolvency in CH and
communications with Ms. Pastore regarding same; continued
review of the three statutes REDACTED
.
07/24/09 A S Turner 1.50 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
07/27/09 A S Turner 1.80 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
07/28/09 A S Turner 3.10 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
414
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 348 of 377
Page 347
Hours Description
07/29/09 W F Stutts, Jr. 1.80 Analyse studied Notice of Allowance, reporting on a broad
allowed claim, consideration to a possible divisional
application and description; Aaron Turner.
07/29/09 A S Turner 1.10 Researching, drafting and revising two memos and one letter
addressed to FINMA relating to: REDACTED
07/31/09 W F Stutts, Jr. 2.20 Effect of 7 31 statements; worked on analysis.
08/01/09 W F Stutts, Jr. .60 Reviewed with Ms. Blumenschein status of proceedings in
Switzerland and scope of open issues as to asset freezes in light
of statements from SEC that there is no US DOJ freeze in
Switzerland.
08/02/09 A S Turner 4.90 Researching, drafting and revising two memos and one letter
addressed to FINMA relating REDACTED
08/03/09 W F Stutts, Jr. 3.70 Communications with Ms. Sambeth Glasner regarding
observations as to state of affairs in Switzerland and
comparison with reports from Switzerland; instructions to Mr.
Turner regarding responses to FINMA REDACTED
;reviewed with Mr. Janvey and Mr.
Cialone the report as to recent activities and information in
Switzerland.
08/04/09 W F Stutts, Jr. 3.90 Reviewed and commented on documentation and cases
provided and discussion prepared to submit to FINMA; several
instructions to Mr. Turner regarding same; telephone
conference with Mr. Arevalo and Mr. Romero and related
communications with Mr. Janvey.
08/04/09 A S Turner 2.70 Researching, drafting and revising two memos and one letter
addressed to FINMA REDACTED
415
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 349 of 377
Page 348
Hours Description
08/05/09 M E Burnett .70 Searched for decisions under the UNCITRAL model law
REDACTED
request of Bill Stutts.
08/05/09 S W Cooper .20 Attended to Swiss issues regarding issues for recognition
proceedings.
08/05/09 W F Stutts, Jr. 2.80 Reviewed information for additional response to FINMA per
the request from them and instructed Mr. Turner on additional
information and discussions in documents regarding bank
insolvency, coordination, Ch 15 recognition.
08/05/09 W F Stutts, Jr. .90 Reviewed information from Swiss counsel regarding status of
funds, interpretation of Swiss laws relevant to the proceeding
and relevant to the questions posed by FINMA.
08/05/09 A S Turner 2.40 Researching, drafting and revising two memos and one letter
addressed to FINMA REDACTED
08/06/09 R I Howell .40 Reviewed correspondence from Swiss counsel.
08/06/09 W F Stutts, Jr. 2.60 Instructed Mr. Turner on points related to discussion of points
in US law section on submission and related inquiry into
question of additional accounts that may be in Switzerland;
reviewed underlying cases and information REDACTED
08/06/09 A S Turner 3.40 Researching, drafting and revising two memos and one letter
addressed to FINMA REDACTED
08/08/09 W F Stutts, Jr. 5.20 Worked with Mr. Turner on points related to foreign banks and
branch/agency in U.S. (for FINMA submission) and reviewed
authorities and legislative history materials in regulatory
context; SIPC information for responses to Mrs. Sabeti
08/09/09 W F Stutts, Jr. 4.60 Reviewed new matters related to pleadings in Switzerland and
communications with Mr. Turner and Ms. Pastore re those
issues.
08/10/09 W F Stutts, Jr. 3.90 Wrote submission to FINMA regarding U.S. law.
08/10/09 A S Turner 4.80 Researching, drafting and revising two memos and one letter
416
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 350 of 377
Page 349
Hours Description
addressed to FINMA REDACTED
08/11/09 W F Stutts, Jr. 3.90 Analyzed issues (first impression) regarding scope of Chapter
15 and other bank resolutions procedures.
08/12/09 W F Stutts, Jr. 3.40 Reviewed status of matters in Switzerland and
REDACTED .
08/12/09 A S Turner 5.90 Drafting and revising the letter to FINMA based on comments
from Mr. Stutts and Altenberger; compiling footnote
attachments and reviewing for substance; responding to
questions posed by Altenberger related to initial drafts of the
letter.
08/13/09 R I Howell 1.80 Reviewed Bill Stutts' proposed submission to the FNMA in
Switzerland and suggested changes in same.
08/13/09 W F Stutts, Jr. 2.90 Reviewed new information related to accounts and Swiss
position regarding them.
08/14/09 W F Stutts, Jr. 3.90 Analyzed issues for REDACTED
; extended communications with Mr. Turne on
analysis, review of relevant provisions of 12 USC and
regulatory policy in the U.S. states and federal levels.
08/14/09 A S Turner 2.80 Drafting and revising the letter to FINMA based on comments
from Mr. Stutts and Altenberger; researching additional case
law REDACTED
08/15/09 W F Stutts, Jr. 3.20 Communications from Mr. Turner and Ms. Pastore; addressed
issues of limited effect of known freezes.
08/15/09 A S Turner 3.80 Drafting and revising the letter to FINMA based on comments
from Mr. Stutts and Altenberger; researching additional
substantive matters as necessary based on comments.
08/16/09 W F Stutts, Jr. 5.80 Report from Ms. Pastore regarding status.
08/16/09 A S Turner 4.00 Drafting and revising the letter to FINMA based on comments
from Mr. Stutts and Altenberger; reviewing and summarizing
class action complaint filed in Antigua; researching
REDACTED
08/17/09 W F Stutts, Jr. 3.30 Memorandum/brief to FINMA; related instructions to Mr.
Turner; several communications with Ms. Pastore on terms and
language particular attention to issues related to legislative
417
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 351 of 377
Page 350
Hours Description
intent and drafting understanding of bank regulatory structure;
reviewed SIPC response and information because Mrs. Sabeti
had specifically asked about its availability; related telephone
conferences with Mr. Janvey on the SIPC ruling.
08/20/09 W F Stutts, Jr. .80 Communications with Ms. Pastore regarding upcoming
meetings and discussions with SFP and related
communications with Mr. Howell.
08/22/09 W F Stutts, Jr. .40 Reviewed background information at request of receiver and
Ms. Romero.
08/26/09 W F Stutts, Jr. .60 Reviewed with Birgit Sambeth Glasner points related to
meeting August 25 with FPO and reviewed information from
Ms. Pastore regarding same.
08/27/09 S W Cooper .20 Reviewed update on Swiss issues.
08/27/09 W F Stutts, Jr. .60 Reviewed information regarding Davis plea and worked to
obtain information REDACTED
08/31/09 W F Stutts, Jr. .90 Reviewed information with Ms. Sambeth Glasner regarding
new information received from governmental agencies and
interpretation of their commentary x
Matter Total 165.10
079716.0121 Examiner Issues
Hours Description
06/01/09 T M Davis .90 Read response to Examiner report; read emails re same.
06/01/09 S A Massad 4.00 Reviewed and commented on response to Examiner report;
various telephone conferences and e-mail correspondence
regarding same; reviewed cases.
06/02/09 D T Arlington 1.90 Conferences with team regarding response to Examiner's report
and worked on same.
06/02/09 S A D Ayers 4.00 Conducted research and drafted Response to Examiner's Report
and Recommendation No. 1.
06/02/09 H M Chappel 4.00 Compiled and prepared case law cited in Receiver's Response
to Examiner's Report and Recommendation No. 1 in
preparation for cite check and filing with the court.
06/02/09 J A Cialone, II .50 Attention to response to examiner report.
06/02/09 L C Fluker 2.80 Attending meeting with Katherine Hinton regarding cite
checks; began checking cites in portion of Response to
Examiner's Report and Recommendation No. 1, including
418
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 352 of 377
Page 351
Hours Description
reviewed opinions to confirm that quotes are correct;
downloaded email communications to update correspondence
file and organized hard copies of correspondence to update
correspondence file; updated Excel tracking chart with
information on recent communications.
06/02/09 S A Massad 3.00 Reviewed and commented on response to Examiner report;
reviewed Examiner filing; reviewed other filings.
06/02/09 E D Reeder 1.60 Attended meeting to discuss cite-check of response to
examiner's report and recommendation; began reviewing the
document in preparation for cite check.
06/02/09 K M Sadler 1.20 Reviewed communications from Examiner regarding various
matters affecting/concerning account release/review process
issues
06/02/09 R H Wood 1.70 Researched and provided proper pinpoint citations for the
response to the examiner.
06/03/09 D T Arlington .80 Worked on response to Examiner's report.
06/03/09 L C Fluker 1.10 Completed checking cites in portion of Response to Examiner's
Report and Recommendation No. 1, including reviewed
opinions to confirm that quotes are correct.
06/03/09 S A Massad 3.50 Participated in conference call regarding response to Examiner;
drafting regarding same.
06/03/09 E D Reeder 7.30 Continued verifying citations and quotations to legal authorities
in response to examiner's report and recommendation;
reviewed Dan Rohleder's and Lawrence Fluker's revisions to
same; direction from Radney Wood; made revisions to the
document.
06/04/09 D T Arlington 1.70 Worked on response to Examiner's report; reviewed financial
data for same; exchanged email with team regarding response.
06/04/09 S A D Ayers 1.80 Conducted research and drafted Response to Examiner's Report
and Recommendation No. 1.
06/04/09 J A Cialone, II .80 Attention to draft filing related to examiner report.
06/04/09 L C Fluker 1.80 Completed checking cites in portion of Response to Examiner's
Report and Recommendation No. 1, including reviewed
opinions to confirm that quotes are correct; continued
reviewing Response to determine if accurate long and short
citation forms have been applied; conferred with Ellen Reeder
regarding additional tasks to be completed before filing of
Response; conferred with David Arlington regarding final
revisions to Response.
419
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 353 of 377
Page 352
Hours Description
06/04/09 S A Massad .70 Reviewed and commented on draft response to Examiner
report.
06/04/09 E D Reeder 2.20 Continued verifying citations and quotations in response to
receiver's report and recommendation.
06/05/09 D T Arlington 1.70 Worked on, finalized and coordinated filing of response to
examiner's report.
06/05/09 S A D Ayers 1.90 Edited, finalized and filed Response to Examiner's Report and
Recommendation No. 1.
06/05/09 T S Durst .30 Work on matters regarding response to examiners report.
06/05/09 L C Fluker 3.60 Assisted in finalizing and filing Response to Examiner's Report
and Recommendation No. 1, including completed review of
final draft to confirm that accurate long and short citation
forms have been applied, made revisions to citations in portion
of Response; advised Ellen Reeder of which portions have been
revised; conferred with David Arlington regarding availability
of document to be finalized; made final proofread of Response
to confirm that all cites are complete and all necessary data has
been added; prepared Appendix cover page; worked with Dan
Rohleder to scan and label appendix materials; provided
Appendix to Barbara Martin for filing; conferred with Barbara
Martin and Sue Ayers regarding creation of table of authorities
and table of contents.
06/05/09 S A Massad 1.50 Finalized review and comments on response to Examiner.
06/05/09 K M Sadler .50 Reviewed inquiries from examiner and information related to
responses
06/08/09 C N Adams 1.10 Telephone conference with working group regarding issues
raised by examiner; reviewing materials regarding same.
06/08/09 J A Cialone, II .80 Calls and emails related to the upcoming meeting with the
Examiner.
06/08/09 J A Cialone, II .80 Other calls and emails in preparation for meeting with
Examiner; meeting to prepare for Examiner meeting Tuesday.
06/08/09 T M Davis 1.10 Reed emails re responses to Examiner inquiries.
06/08/09 S A Massad .50 Participated in portion of conference call to prepare for meeting
with Examiner.
06/09/09 C N Adams 3.10 Call to discuss issues for examiner call; conference with
examiner regarding outstanding issues.
06/09/09 J A Cialone, II 1.80 Reviewed Examiner's response to Receiver's real estate motion;
calls and emails about this and other Examiner issues and
activities; call with team in advance of and call following
420
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 354 of 377
Page 353
Hours Description
Receiver's meeting with Examiner in Dallas; considered
responses to demands made by Examiner and the costs of
doing all he has demanded.
06/09/09 T M Davis 2.60 Pre-call with R. Janvey et al.; call with Examiner; discuss call
with M. Lovett and J. Cialone.
06/09/09 S A Massad .30 Participated in portion of conference call to prepare for
Examiner meeting.
06/09/09 K M Sadler 3.50 Reviewed documents and issues in preparation for conference
with Examiner; consultations with Receiver; conference with
Examiner
06/11/09 J A Cialone, II .50 Drafted response to Examiner and SEC.
06/11/09 T M Davis .30 Coordinate reply to Receiver's questions regarding Pershing
stipulation.
06/12/09 J A Cialone, II .80 Attention to Examiner issues and court papers.
06/13/09 J A Cialone, II 1.20 Reviewed Examiner's reply to Receiver's response to
Examiner's report; related calls and emails.
06/15/09 J A Cialone, II .80 Reviewed Examiner comments regarding Receiver's SIPC
proposed website FAQ; related calls and emails.
06/17/09 C N Adams .80 Reviewing issues identified by the examiner.
06/18/09 J A Cialone, II .60 Reviewed Little's email requests and discussed handling.
06/18/09 K M Sadler 1.40 Reviewed emails from examiner and reviewed issues and
information regarding responses; reviewed and responded to
several emails from examiner regarding account release issues;
conference with Lovett regarding examiner inquiry; conference
with Arlington regarding account review process issues
06/19/09 J A Cialone, II .80 Reviewed Examiner's questions about accounts and coins and
responses thereto.
06/19/09 K M Sadler 1.60 Reviewed and revised draft memorandum to Examiner
responding to various issues and inquiries received concerning
account freeze and review; reviewed account information
regarding examiner inquiries
06/20/09 K M Sadler 1.00 Reviewed issues regarding Examiner inquiries regarding
account review and release; email to Examiner; reviewed
related information from M. Lovett; reviewed issues regarding
Coin and Bullion matters regarding Examiner inquiry regarding
status of protocol
06/21/09 K M Sadler 1.00 Reviewed examiner inquiry regarding Causey account;
reviewed emails to/from account review team regarding
421
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 355 of 377
Page 354
Hours Description
background and status; reviewed other account release issues
and information
06/25/09 S A D Ayers 1.00 Prepared outline for hearing on Examiner's Report and
Recommendation No. 1.
06/26/09 S A Massad 1.00 Reviewed and responded to Examiner questions regarding
SIPC.
06/27/09 S A D Ayers .50 Prepared correspondence to John Little in response to questions
regarding frozen accounts.
06/27/09 K M Sadler .20 Reviewed and responded to email correspondence from
Examiner regarding investor and FA accounts; emails to
Arlington and financial team regarding inquiries
06/29/09 J A Cialone, II 1.00 Reviewed and considered emails from Examiner demanding
various reports and other information, and related cost-benefit
analysis of responding to Examiner rather than working on
account review process.
06/29/09 S A Massad 1.20 Further study on SIPC issues; e-mail correspondence regarding
same.
06/30/09 S A Massad 3.00 Further study on SIPC issue; drafted memorandum regarding
same; office conference with Justin Mogford to explain issue
and direct research.
07/01/09 S A Massad .70 Further study on SIPC issues; various telephone conferences
regarding same.
07/02/09 S A Massad 3.30 Worked on SIPC issues in response to Examiner's e-mail
correspondence; reviewed cases; revised memorandum.
07/03/09 J A Cialone, II .80 Reviewed and responded to Examiner's extensive questions by
email.
07/06/09 J A Cialone, II .80 Attention to Examiner issues.
07/07/09 S A Massad 1.30 Revised memorandum regarding SIPC issues; various e-mail
correspondence regarding same.
07/08/09 J A Cialone, II 1.10 Attention to Examiner issues.
07/09/09 J A Cialone, II 1.80 Attention to Examiner issues and emails.
07/09/09 S A Massad .30 Attention to SIPC memorandum.
07/10/09 J A Cialone, II 1.00 Calls and emails about Examiner Reports.
07/10/09 J A Cialone, II .40 Reviewed Examiner's first fee application and related emails.
07/10/09 S A Massad 2.00 Revised SIPC memorandum; talked to SIPC personnel; e-mail
correspondence to Examiner.
422
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 356 of 377
Page 355
Hours Description
07/21/09 K M Sadler 1.10 Reviewed account status inquiries; correspondence to client
regarding examiner inquiries; conferences with Lovett
regarding examiner inquiries on various issues
07/23/09 J A Cialone, II .70 Attention to SIPC issues and responses to Examiner's
questions.
07/30/09 J A Cialone, II .80 Attention to examiner issues and communications.
08/02/09 J A Cialone, II .90 Attention to Examiner email requests.
08/26/09 J A Cialone, II .80 Attention to requests from Examiner.
08/27/09 K M Sadler .50 Reviewed issues regarding inquiries by examiner; emails to
legal and financial team members regarding examiner
questions and responses
Matter Total 109.40
079716.0122 Motion to Disqualify
Hours Description
06/16/09 S A Massad 1.00 Various telephone conferences and e-mail correspondence
regarding motion to disqualify Baker Botts.
06/17/09 S A Massad 1.00 Attended to disclosure regarding motion to disqualify Baker
Botts; various telephone conferences and e-mail
correspondence regarding same.
06/18/09 J B Lawrence 5.70 Research related to response to motion to disqualify Receiver's
counsel.
06/20/09 J B Lawrence 2.50 Continue researching and drafting response to motion to
disqualify Baker Botts.
06/21/09 J B Lawrence 2.00 Continue researching and drafting motion to disqualify Baker
Botts.
06/23/09 S A Massad .70 Reviewed draft; various telephone conferences.
06/24/09 S A Massad .40 Various telephone conferences and e-mail correspondence
regarding issues and status.
06/25/09 T S Durst 1.00 Review of draft brief in response to motion to disqualify and
conference with Mr. Cialone and Mr. Lamb regarding same.
06/25/09 J B Lawrence 1.10 Research related to response to motion to disqualify Baker
Botts.
06/26/09 C N Adams .80 Reviewing motion to disqualify.
06/26/09 S A Massad .50 Reviewed and commented on draft motion.
423
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 357 of 377
Page 356
Hours Description
06/27/09 T S Durst .80 Review and comment upon draft response to motion to
disqualify; communications with team regarding same.
06/27/09 S A Massad .50 Reviewed and commented on draft opinion.
06/27/09 K M Sadler 1.00 Reviewed and provided comments on draft motion; reviewed
briefing from other cases regarding legal issues
06/29/09 S A D Ayers 1.00 Conducted research for recent cases REDACTED
06/29/09 S A D Ayers 1.00 Conducted research for recent cases REDACTED
06/29/09 T S Durst 2.10 Work on response to Stanford disqualification motion;
conference with Mr. Lamb regarding same; attention to issues
regarding filing under seal.
06/29/09 J B Lawrence 8.20 Research law related to response to motion to disqualify Baker
Botts; edit response to Denison motion to reconsider and
prepare same for filing; draft motion for leave to file response
REDACTED , along with
accompanying appendix and proposed order.
06/29/09 S A Massad 1.00 Reviewed and commented on new draft; various telephone
conferences and e-mail correspondence.
06/29/09 K M Sadler 1.00 Conference with ayers regarding case research; emails to
cialone and lamb; reviewed and commented on response to
motion; conference with Cialone, Lamb and Durst regarding
motion response
06/30/09 T S Durst 1.40 Work on response to motion to disqualify Baker Botts.
06/30/09 S A Massad 1.00 Reviewed and commented on draft brief; various telephone
conferences and e-mail correspondence.
07/01/09 T S Durst .60 Work on issues regarding response to motion to disqualify;
preparation of revised order regarding same and conference
with court.
07/11/09 T S Durst .50 Call with team to discuss issues regarding Nunes deposition.
07/11/09 K M Sadler .50 Reviewed issues regarding discovery sought by RAS in support
of motion; reviewed issues regarding disqualification briefing
07/17/09 S A Massad .70 Reviewed filing by Allen Stanford; various e-mail
correspondence regarding same.
07/20/09 C N Adams .60 Telephone conference regarding motion to disqualify.
07/20/09 K M Sadler .80 Reviewed redacted reply brief; correspondence to opposing
counsel; conference with J. Cialone and G. Lamb
424
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 358 of 377
Page 357
Hours Description
07/21/09 S A Massad .30 Various e-mail correspondence.
07/22/09 C N Adams .40 Call with working group regarding motion to disqualify.
07/22/09 S A Massad 1.00 Participated in conference call regarding reply to
disqualification motion; reviewed e-mail correspondence.
07/22/09 K M Sadler .50 Reviewed outline of issues for letter brief; conference with
Lamb and Cialone regarding issues to be briefed to the Court
07/23/09 C N Adams .80 Conference with Joe Cialone and Kevin Sadler regarding
motion to disqualify; revising response regarding same.
07/23/09 K M Sadler .80 Reviewed and commented on letter brief to the court;
conferences with Lamb and Cialone regarding letter brief
07/24/09 C N Adams .60 Reviewing letter regarding motion to disqualify; telephone
conference with Kevin Sadler regarding same.
07/26/09 S A Massad .30 Various e-mail correspondence regarding disqualification
motion.
07/26/09 K M Sadler .30 Correspondence with counsel concerning proposed motion to
supplement; reviewed motion; emails to Lamb and Cialone
07/27/09 K M Sadler .40 Reviewed issues regarding further reply brief filed by RAS
counsel regarding Guardian file
08/31/09 K Scanlan .60 Pull copies of filings relating to Stanford's motion to disqualify
to provide Tim Durst with needed information.
Matter Total 45.40
079716.0123 Canada Litigation Matters
Hours Description
08/01/09 W F Stutts, Jr. .50 Reviewed with Ms. Blumenschein status of proceedings in
Canada and scope of stated open questions from ONtario court
and Ontario AG.
08/03/09 W F Stutts, Jr. .90 Reviewed with Mr. Hendy points related to Vantis opposition
of AMF intervention and worked on related strategy; reviewed
with Mr. Janvey and Mr. Cialone the report as to recent
activities and information in Canada.
08/04/09 W F Stutts, Jr. .80 Reviewed proposed REDACTED
; several communication
with Ms. Khalaf regarding same and questions on use to which
agreements will be put in hearing.
08/05/09 W F Stutts, Jr. 1.90 CANADA Reviewed information from George Hendy
regarding developments in Quebec proceeding and response on
425
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 359 of 377
Page 358
Hours Description
points related to the deliverables from that hearing; reviewed
information in the pleading filed and additional points for
clarification and addressed developments; reviewed
information from Sonia Bjorkquist regarding Ontario and status
of funds and orders in Ontario.
08/06/09 W F Stutts, Jr. 1.70 Information from Mr. Hendy regarding changes in admission
and initial questions regarding ownership of additional servers;
reviewed affidavit of Sebastian Garon and posed questions
related to specific scope of certain statements; several
communications with Ms. Kahlaf regarding Vantis admissions;
additional points from Mr. Hendy on filings and requests for
agreement from Vantis lawyer.
08/07/09 R I Howell 3.50 Reviewed update from Canadian counsel and read Canadian
proceeds of crime case law provided; reviewed REDACTED
; reviewed 5th Circuit case; reviewed Vantis's
brief in U.K. criminal freeze appeal.
08/07/09 W F Stutts, Jr. .90 Information from Mr. Howell regarding forfeiture in Canada,
MLAT and transcription notes and impact in Canada.
08/13/09 R I Howell .70 Reviewed email from Canadian counsel regarding Alberta
proceeding.
08/17/09 R I Howell .40 Telephone conference with Tris Mallett, lead Canadian
counsel; reviewed various items of correspondence regarding
foreign assets.
08/18/09 R I Howell .70 Reviewed new Hamilton-Smith and Glosband affidavits
submitted by Vantis in the Canadian action.
08/19/09 R I Howell 4.00 Telephone conference with Karyl Van Tassel and others at FTI
regarding new Hamilton-Smith affidavit; conference call with
Canadian lawyers regarding same; conference call with
Canadian lawyers and Karyl Van Tassel regarding same;
telephone conference with Bill Stutts regarding meeting on
status of foreign matters.
08/19/09 W F Stutts, Jr. .90 CANADA: Communications with Osler regarding upcoming
hearings in Montreal and additional evidence and
communications with Mr. Howell regarding same.
08/20/09 R I Howell 3.40 Drafted Karyl Van Tassel affidavit for Canadian action;
reviewed email correspondence from FTI for use in same;
reviewed material from Canadian counsel.
08/20/09 W F Stutts, Jr. .70 CANADA: Reviewed details of hearings and changes proposed
related to same and proposals from judge for summaries.
08/20/09 W F Stutts, Jr. .70 CANADA: Worked on definitional and scope information from
cases REDACTED
426
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 360 of 377
Page 359
Hours Description
.
08/21/09 R I Howell 6.70 Worked on Karyl Van Tassel affidavit for Canadian action and
commented on Canadian brief; telephone conferences with
Karyl Van Tassel and others at FTI and with George Hendy
regarding the affidavit.
08/22/09 R I Howell 2.80 Reviewed more Leroy King correspondence to Stanford found
in St. Croix; drafted arguments for Canadian counsel's use in
rebutting new Glosband affidavit filed by the Antiguan
Liquidators.
08/22/09 W F Stutts, Jr. 1.40 Reviewed scope of proceedings, statutory information;
background information at request of receiver and Ms.
Romero.
08/22/09 R H Wood .30 Spoke with B. Stutts regarding Canada seizure of Stanford
funds; discussed receiver's ability to "represent" investors.
08/23/09 W F Stutts, Jr. 3.30 CANADA: Reviewed information for current dispute on
information for customers and identified prior disclosures to
the Vantis liquidators; reviewed draft presentation and
provided comments on same; several communications with Mr.
Hendy and Mr. Howell related to that; reviewed additional
elements of proceeding in Canada including prior affidavits
and new information; reviewed commentary related to Antigua
data secrecy laws.
08/24/09 R I Howell .20 Reviewed correspondence regarding Canadian proceeding.
08/24/09 W F Stutts, Jr. 12.20 Worked on trial preparation with Mr. Hendy, Mr. Nadeau
Ouellett, Mr. Derosiers; reviewed new information and
arguments written and developed responses and commentary
on same; examined positions taken by Antiguan liquidators and
responses to same.
08/25/09 R I Howell .40 Reviewed correspondence regarding the Canadian proceeding;
telephone conference with Bill Stutts and Martin Derosiers
regarding scope of the stay in the U.S. Receivership order.
08/25/09 W F Stutts, Jr. 4.60 Participated in hearing in Superior Court on
REDACTED
reviewed
with Mr. Hendy and assistance points related to COMI
particularly as seen in other jurisdictions; presented
information on other foreign proceedings; developed and
provided descriptions of status, issues, and information related
to the situation in Quebec.
427
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 361 of 377
Page 360
Hours Description
08/26/09 R I Howell 1.80 Obtained various information needed by counsel trying the
Canadian case.
08/26/09 W F Stutts, Jr. 7.70 Participated in hearing in Montreal (issues involved
particularly status of U.S. proceeding motion, U.S. cases as to
COMI, U.S. cases as to recognition of receivers); advised Mr.
Hendy and Mr. Des rosier REDACTED
, factual information from various affidavits and other
matters in preparation for hearing on August 27.
08/27/09 W F Stutts, Jr. 2.80 Examined matters related to Canadian rules on recognition and
provided information and assistance on same to Mr. Des rosier
and Mr. Nadeau Ouellett on those issues; additional
information to Mr. Hendy on status of matters in U.S. and U.S.
jurisprudence; report from Mr. Hendy and Mr. Des rosier
regarding directions of hearing and conclusion; examined
questions of coordination and different rulings; report to group
on present status; reviewed information about recent
developments in U.S. cases possibly affecting Canada case.
08/28/09 R I Howell .40 Office conference with Bill Stutts regarding Canadian
proceeding; reviewed email correspondence regarding same.
08/28/09 W F Stutts, Jr. .90 Provided information to Mr. Nadeau Ouellett related to judicial
discretion in US recognition proceedings and provided
information related to the same
08/28/09 W F Stutts, Jr. .40 Reviewed information from Mr. Thomas regarding new claim
against TD (dynasty furniture)
08/29/09 R H Wood .10 Spoke with B. Stutts regarding Canadian litigation.
08/30/09 R H Wood .20 Spoke with B. Stutts regarding research REDACTED
.
08/31/09 W F Stutts, Jr. 1.10 Provided input to Mr. Nadeau Ouellett regarding 1506 and
related information on US judicata discretion; additional
information from Mr. Thomas regarding Dynasty claim; related
communication with Mr. Howell regarding that claim and
possible additional claims.
08/31/09 R H Wood 4.90 Reviewed Ontario Attorney General's's seizure order; reviewed
REDACTED
; researched and
reviewed Canadian case law REDACTED
; research U.S. case law REDACTED
.
Matter Total 74.00
428
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 362 of 377
Page 361
079716.0124 UK Litigation Matters
Hours Description
08/01/09 J A Cialone, II .50 Several email exchanges with team about European account
situation.
08/01/09 R I Howell .40 Email correspondence regarding the proposed Motion to
Clarify Receivership order and regarding strategy relative to
the foreign funds.
08/01/09 W F Stutts, Jr. .40 Reviewed with Ms. Blumenschein status of proceedings in UK
and scope of open questions in proceedings in light of courts'
approach to discharge (lift) US government sponsored freezes
08/02/09 R I Howell .60 Further email regarding the proposed Motion to Clarify
Receivership order and regarding strategy relative to the
foreign funds.
08/03/09 R T Preston-Jone .80 Finalizing and sending letter to Cameron McKenna; email
received from Stuart Isaacs QC (barrister) re Court of Appeal
bundle and responding; email received from Bill Stutts Stutts
and Responding, including analysing Judgment of Kramer.
08/03/09 W F Stutts, Jr. 1.10 Reviewed with Mr. Janvey and Mr. Cialone the report as to
recent activities and information in UK; information exchanged
with Mr. Isaacs regarding reports of scope of protection in UK
and comparison against state of facts there.
08/04/09 R I Howell .50 Reviewed U.K. criminal restraint in connection with Bill Stutts'
question REDACTED
.
08/04/09 R I Howell 2.00 Reviewed U.K. criminal freeze judgment; reviewed and
commented on U.K. court of appeal draft skeleton argument;
correspondence with Ralph Janvey, et al.
08/04/09 D Krishan .60 Conference with Robin Preston-Jones re hearing on 18 August
2009 and submission of skeleton arguments.
08/04/09 R T Preston-Jone 4.10 Letter received from Cameron McKenna re Recognition
application in Antigua; circulating to team and conferring by
email; discussion with Bob Howell re restraint order and
sending same by email; receiving transcript of Kramer
judgment and circulating to team; conferring with Stuart Isaacs
QC (barrister) by email as to bundles for Court of Appeal;
email to Cameron McKenna re bundles; conferring with Bill
Stutts and Bob Howell re appointment of Georgina Peters;
telephone call from Nabarro re insurance policies and email to
Bill Stutts and Bob Howell re the same; Conferring with Dev
Krishnan as to representation.
429
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 363 of 377
Page 362
Hours Description
08/04/09 W F Stutts, Jr. .90 Worked on matters related to Restraint order in UK and several
communication with Mr. Preston-Jones and Mr. Howell;
communications regarding staffing and approvals.
08/05/09 J A Cialone, II .80 Several calls with Stutts and client about foreign accounts.
08/05/09 M S Kontopoulos 1.20 Delivering letter to Court of Appeal registry.
08/05/09 R T Preston-Jone 1.80 Considering and revising draft skeleton argument for Court of
Appeal; email received from Cameron McKenna regarding
bundle; preparing letter to Court of Appeal and completing
form.
08/06/09 R I Howell 3.90 Reviewed materials REDACTED
and
correspondence with U.K. counsel regarding same.
08/06/09 M S Kontopoulos .10 Taking instructions from R.Preston-Jones regarding
amendments to skeleton argument.
08/06/09 D Krishan 1.60 Finalising skeleton argument and preparing authorities and
pagination.
08/06/09 R T Preston-Jone 3.00 Email received from Cameron McKenna re bundle and
conferring with Stuart Isaacs QC (barrister) by email;
conferring with Dev Krishnan and paralegal regarding
bundling.
08/06/09 W F Stutts, Jr. .50 With Mr. Howell, examined POCA provisions
REDACTED .
08/07/09 M S Kontopoulos .50 Receipt of updated bundles; inserting new references into
skeleton arguments.
08/07/09 D Krishan 4.10 Liaising with barristers and counsel regarding bundles;
correspondence with Camerons regarding authorities and
finalising core bundles.
08/07/09 W F Stutts, Jr. .70 Reviewed with Mr. Howell developments in US.
08/10/09 R I Howell 6.00 Revised bullets for meeting with DOJ and SEC; reviewed
correspondence from U.K. counsel.
08/10/09 D Krishan 2.10 Liasing with barristers and answering queries regarding
authorities, bundle documents and correspondence.
08/10/09 W C Watts .50 Conducted research for Bill Stutts and Bob Howell regarding
cases involving cross border freezes of assets.
08/11/09 R I Howell 1.00 Sent Bill Stutts various documents concerning the U.K. freeze
proceedings; reviewed correspondence regarding the U.K.
proceedings and upcoming meeting with DOJ and SEC.
430
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 364 of 377
Page 363
Hours Description
08/11/09 D Krishan 1.80 Updating bundle after receiving additional documents from
Camerons; correspondence with barristers.
08/11/09 W C Watts 4.20 REDACTED
08/12/09 R I Howell .80 Telephone conference with investor/relief defendant; office
conference with Bill Stutts regarding U.K. and Swiss issues;
reviewed correspondence from U.K. counsel.
08/13/09 R I Howell 2.20 Reviewed SFO's brief in the U.K. appeal and sent observations
to Bill Stutts regarding same.
08/14/09 R I Howell 2.10 Correspondence with English counsel regarding lifting the SEC
freezing order to permit the transfer of SBP funds; sent Bill
Stutts proposed addition to letter to FNMA REDACTED
08/15/09 R I Howell 2.00 Worked on report on foreign proceedings, reviewed
correspondence on U.K. civil freeze issue.
08/17/09 R I Howell .40 Reviewed skeleton brief filed by Allen Stanford in U.K. action.
08/17/09 D Krishan 9.60 Preparing documents for hearing; liaising with Georgina Peters
and Stuart Isaacs; reviewing and finalising skeleton arguments
and bundles.
08/17/09 W F Stutts, Jr. .50 Participated in discussion regarding proposed ordering
paragraphs of order and provided suggestions for coordination
of responses.
08/18/09 R I Howell .30 Reviewed summary of English hearing in the SFO case.
08/18/09 W F Stutts, Jr. .80 Report from Mr. Isaacs regarding results of CA hearing and
continued erosion of SFO freeze in UK.
08/22/09 W F Stutts, Jr. .40 Reviewed background information at request of receiver and
Ms. Romero.
08/24/09 R T Preston-Jone 10.00 Reviewing emails and documents, including various telephone
calls, conference calls and emails sent and received.
08/25/09 R T Preston-Jone 1.40 Letter received from Addleshaws and telephone call to
Nabarro; email to Bill Stutts; email received from Stuart Isaacs
QC (barrister); budget received.
08/25/09 W F Stutts, Jr. .30 Responded to information and inquiry from Mr. Isaacs and
information from Mr. Preston-Jones.
08/26/09 R T Preston-Jone .60 Perusing various emails relating to Credit Suisse and
considering the same.
431
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 365 of 377
Page 364
Hours Description
08/27/09 R T Preston-Jone 3.30 Receiving and reviewing email received from Court of Appeal
attaching Order; marking calendar entries for deadlines; email
received from Cameron McKenna attaching affidavit of NHS
and considering same; email to team re affidavit; reviewing
Orders made in US proceedings.
08/27/09 W F Stutts, Jr. .30 Responded to SI and FI and Robin Preston-Jones regarding
developments and provided information to them related to new
information in U.S. cases.
08/28/09 R T Preston-Jone .70 Email received from Stuart Isaacs QC (barrister) re NHS
affidavit; email to Sir Clare Roberts re advice on Antiguan law.
08/28/09 W F Stutts, Jr. 1.30 Provided information REDACTED
to England; provided
information to England related to Davis plea agreement
Matter Total 82.70
079716.0125 Antigua Litigation Matters
Hours Description
08/02/09 J A Cialone, II .30 Attention to Antiguan real estate issues.
08/03/09 W F Stutts, Jr. .90 Provided to Clare Roberts status information and obtained from
him clearance; submitted information to Mr. Janvey for
execution and attended to transmittal of same to Antigua for
filing.
08/19/09 S W Austin .80 E-mail message from Bill Stutts regarding research
REDACTED ; sent e-mail message to Wes
Watts regarding same; reviewed REDACTED
to Bob Howell and Bill Stutts; reviewed Bob
Howell's reply.
08/19/09 W C Watts .80 Researched and provided written description
REDACTED .
08/22/09 W F Stutts, Jr. .40 Reviewed background information at request of receiver and
Ms. Romero.
08/25/09 W F Stutts, Jr. .40 Reviewed communication from Sir Clare Roberts and
developed and communicated questions regarding his status
and related points regarding filing of restriction on land.
08/26/09 W F Stutts, Jr. .30 Reviewed and commented on matters related to pending
litigation and counsel.
08/27/09 W F Stutts, Jr. .40 Reviewed inquiry from Clare Roberts and responded to him by
e-mail message and telephone with additional copies of RAS
432
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 366 of 377
Page 365
Hours Description
restrictions filed in Antigua.
Matter Total 4.30
433
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 367 of 377
Page 366
Lawyer Summary
TIMEKEEPER HOURS RATE TOTAL
Adams, C N 281.90 440.00 124,036.00
Akalski, J C 17.30 200.00 3,460.00
Arlington, D T 570.00 380.00 216,600.00
Austin, S W 156.60 400.00 62,640.00
Ayers, S A D 339.30 356.00 120,790.80
Bodron, M A 54.10 460.00 24,886.00
Brown, M W 267.00 324.00 86,508.00
Cafferty, J L 25.80 276.00 7,120.80
Cialone, II, J A 276.30 555.00 153,346.50
Cooper, S W 166.90 460.00 76,774.00
Davis, T M 56.20 555.00 31,191.00
Day, B A 628.10 260.00 163,306.00
Doty, J R 6.00 555.00 3,330.00
Durst, T S 94.20 555.00 52,281.00
Foster, J G 12.80 380.00 4,864.00
Gold, M A 77.30 460.00 35,558.00
Greer, J M 194.40 276.00 53,654.40
Hamner III, H T 44.80 340.00 15,232.00
Hollis, J R 34.30 212.00 7,271.60
Howell, R I 303.80 420.00 127,596.00
Hurd, M C 275.80 308.00 84,946.40
Husseini, R A 138.40 555.00 76,812.00
Knight, J R 139.00 480.00 66,720.00
Krishan, D 44.40 420.00 18,648.00
Kujawski, L A 5.20 276.00 1,435.20
Lawrence, J B 230.70 260.00 59,982.00
Leslie, J T 130.80 240.00 31,392.00
Lewis, R C 132.60 324.00 42,962.40
Lobb, J D 85.50 240.00 20,520.00
Lok, H 22.70 308.00 6,991.60
Massad, S A 134.50 555.00 74,647.50
Mountz, T W 100.30 500.00 50,150.00
Myers, M G 346.20 260.00 90,012.00
Nelsen, J B 89.20 276.00 24,619.20
Preston-Jones, R T 201.80 480.00 96,864.00
Pullin, Z T 122.70 212.00 26,012.40
Raborn, J R 41.00 555.00 22,755.00
Raley, J E 25.30 380.00 9,614.00
Rancher, C W 46.50 212.00 9,858.00
Sadler, K M 696.70 555.00 386,668.50
Schlanger, K E 198.20 308.00 61,045.60
Scott, M L 39.60 380.00 15,048.00
Shah, R K 67.70 212.00 14,352.40
Soderlund, E A 117.50 324.00 38,070.00
434
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 368 of 377
Page 367
Stewart, J C 13.20 240.00 3,168.00
Stockbridge, A M 48.10 240.00 11,544.00
Stutts, Jr., W F 391.40 555.00 217,227.00
Sulentic, A M 114.60 356.00 40,797.60
Swearingen, T R 42.60 260.00 11,076.00
Tucker, H C 37.50 212.00 7,950.00
Turner, A S 59.20 212.00 12,550.40
Van Tine, K K 48.10 600.00 28,860.00
Walters, T J 10.50 212.00 2,226.00
Watts, W C 30.80 212.00 6,529.60
Wellington, J J 23.30 276.00 6,430.80
Wood, M C 184.80 212.00 39,177.60
Wood, R H 133.90 212.00 28,386.80
Wright, R P 53.40 460.00 24,564.00
York, A F 489.00 212.00 103,668.00
Young, E A 39.90 332.00 13,246.80
Zabaneh, J P 28.00 240.00 6,720.00
Lawyer Totals: 8,787.70 $3,264,694.90
Non-Lawyer Summary
TIMEKEEPER HOURS RATE TOTAL
Benhoff, S M 22.40 380.00 8,512.00
Burnett, M E 19.50 100.00 1,950.00
Chappel, H M 14.40 100.00 1,440.00
Dodge, L E 34.50 160.00 5,520.00
Fitzwater, J S 267.30 92.00 24,591.60
Fluker, L C 44.40 160.00 7,104.00
Garcia, V O 25.60 120.00 3,072.00
Gaskamp, K L 23.30 132.00 3,075.60
Hinton, K W 387.80 128.00 49,638.40
Huddleston, J C 341.30 148.00 50,512.40
Jampala, S 25.20 100.00 2,520.00
Karp, K L 86.00 132.00 11,352.00
Kontopoulos, M S 24.00 180.00 4,320.00
Kusey, M D 95.60 160.00 15,296.00
Moratto Jr., T M 18.20 100.00 1,820.00
O'Quinn, J G 28.20 220.00 6,204.00
Reeder, E D 53.40 140.00 7,476.00
Rohleder, D S 140.80 92.00 12,953.60
Scanlan, K 278.50 140.00 38,990.00
Starbuck, N M 507.90 100.00 50,790.00
Thomas, J E 19.00 136.00 2,584.00
Walker, V R 30.00 60.00 1,800.00
Non-Lawyer Totals: 2,487.30 $311,521.60
435
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 369 of 377
Page 368
For expenses incurred:
STUTTS, JR., WILLIAM F. -Client meetings / attorney discussions - 176.00
during dates of 6/9/2009 - 6/11/2009
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Client meetings / 374.32
attorney discussions - during dates of 6/9/2009 - 6/11/2009
HOWELL, ROBERT I. -Trip to London for hearing - during dates of 1,398.69
6/1/2009 - 6/16/2009
STUTTS, JR., WILLIAM F. -Attend meetings in Houston July 8 - 189.20
during dates of 7/8/2009 - 7/9/2009
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Attend meetings in 187.16
Houston July 8 - during dates of 7/8/2009 - 7/9/2009
HMCS Court fee - Appeal fee 600.00
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Client Meetings in 285.70
Dallas - during dates of 7/24/2009 - 7/24/2009
STUTTS, JR., WILLIAM F. -Client Meetings in Dallas - during dates 121.00
of 7/24/2009 - 7/24/2009
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Attend Meetings in 843.41
Houston and Dallas - during dates of 8/18/2009 - 8/20/2009
DAVIS, TONY M. -Trip to Dallas to meet with R. Janvey to discuss 179.10
account review processes and to discuss fraudulent transfer and
relief defendant matters. - during dates of 6/3/2009 - 6/3/2009
TRANSPERFECT TRANSLATIONS Transcribing Stipulation regarding 175.00
release of accounts from English to Spanish
KARP, KIMBERLY L. -Mileage to Stanford warehouse off of 290 - 136.95
during dates of 8/4/2009 - 8/8/2009
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Client meetings / 281.70
attorney discussions - during dates of 6/30/2009 - 6/30/2009
STUTTS, JR., WILLIAM F. -Client meetings / attorney discussions - 56.00
during dates of 6/30/2009 - 6/30/2009
CIALONE, II, JOSEPH A. -Traveled to Dallas, Ft. Worth to attend 304.20
meetings with client. - during dates of 6/3/2009 - 6/3/2009
436
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 370 of 377
Page 369
ADAMS, CRAIG N. -Travel to Houston for Stanford - during dates of 15.00
7/13/2009 - 7/13/2009
AMERICAN EXPRESS - ADAMS, CRAIG N. -Travel to Houston for 436.20
Stanford - during dates of 7/13/2009 - 7/13/2009
CIALONE, II, JOSEPH A. -Traveled to Dallas, Texas for client 345.20
meetings. - during dates of 7/20/2009 - 7/20/2009
CIALONE, II, JOSEPH A. -Traveled to Dallas, Texas for client 325.20
meetings. - during dates of 7/23/2009 - 7/23/2009
CIALONE, II, JOSEPH A. -Traveled to Dallas, Texas to attend 376.20
client meetings. - during dates of 8/19/2009 - 8/19/2009
KARP, KIMBERLY L. -Mileage to and from Stanford office and 110.55
warehouse. - during dates of 8/18/2009 - 8/29/2009
CIALONE, II, JOSEPH A. -Traveled to Dallas, TX to attend client 325.20
meetings. - during dates of 7/31/2009 - 8/31/2009
DAVIS, TONY M. -Trip to Dallas to meet with R. Janvey to discuss 168.10
account review processes and to discuss fraudulent transfer and
relief defendant matters. - during dates of 6/3/2009 - 6/3/2009
County Clerk - Queens County (33621) 95.00
County Clerk - Queens County (33621) 45.00
HINTON, KATHERINE WYNELL -Reimburse for transcript of Stanford's 265.20
arraignment - during dates of 7/16/2009 - 7/16/2009
AMERICAN EXPRESS - HINTON, KATHERINE WYNELL -Filings fees for two 910.00
appeals - during dates of 8/6/2009 - 8/6/2009
CHOICEPOINT PUBLIC RECORDS, Searches for current address 98.00
information on various names per request from Katherine Hinton
SADLER, KEVIN M. -Travel to Dallas to attend meeting with Janvey 320.70
- during dates of 6/3/2009 - 6/3/2009
PREMIER TRANSPORTATION Sadler's transportation from Love Field to 68.86
BB Dallas office
PREMIER TRANSPORTATION Sadler's transportation from BB Dallas 68.86
office to Love Field
Check: American Express Travel Related Services. Check date: (254.20)
5/7/09. Unused airfare for D Arlington
437
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 371 of 377
Page 370
AMERICAN EXPRESS - YORK, ANDREW F. -Travel to Houston re Stanford 882.56
matter - during dates of 6/22/2009 - 6/26/2009
AMERICAN EXPRESS - DAY, BRENDAN ALAN -In Houston for Stanford 40.00
document review - during dates of 6/22/2009 - 7/26/2009
AMERICAN EXPRESS - DAY, BRENDAN ALAN -Stanford Document Review - 2,153.46
during dates of 6/22/2009 - 7/2/2009
YORK, ANDREW F. -Travel to Houston re Stanford - during dates of 176.00
6/22/2009 - 7/2/2009
AMERICAN EXPRESS - YORK, ANDREW F. -Travel to Houston re Stanford 1,202.29
- during dates of 6/22/2009 - 7/2/2009
DAY, BRENDAN ALAN -Stanford Document Review - during dates of 534.60
6/22/2009 - 7/2/2009
YORK, ANDREW F. -Hotel in Houston 7-5 through 7-10 re Stanford - 1,025.90
during dates of 7/5/2009 - 7/10/2009
YORK, ANDREW F. -Travel to/from Houston re Stanford - during 176.00
dates of 7/5/2009 - 7/10/2009
AMERICAN EXPRESS - DAY, BRENDAN ALAN -Work on Stanford Account 1,456.65
Releases - during dates of 7/2/2009 - 7/10/2009
SADLER, KEVIN M. -Travel to Dallas for meeting with Ralph Janvey 328.14
- during dates of 7/20/2009 - 7/20/2009
SADLER, KEVIN M. -Travel to Dallas for meeting with Ralph Janvey 491.50
- during dates of 7/23/2009 - 7/23/2009
AYERS, SUSAN ANN DILLON -Stanford Meeting with Receiver Ralph S. 333.70
Janvey and attorneys, Dallas, Texas - during dates of 7/23/2009 -
7/23/2009
AMERICAN EXPRESS - DAY, BRENDAN ALAN -Travel to Houston for 506.06
review of accounts for releases - during dates of 7/23/2009 -
7/26/2009
YORK, ANDREW F. -Travel to Houston re Stanford - during dates of 176.00
7/23/2009 - 7/27/2009
DAY, BRENDAN ALAN -Travel to Houston for review of accounts for 178.20
releases - during dates of 7/23/2009 - 7/26/2009
AMERICAN EXPRESS - YORK, ANDREW F. -Travel to Houston re Stanford 993.37
438
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 372 of 377
Page 371
- during dates of 7/23/2009 - 7/27/2009
AMERICAN EXPRESS - David Arlington - Travel from San Antonio 313.70
to Dallas - during dates of 7/31/2009 - 7/31/2009
AMERICAN EXPRESS - ARLINGTON, DAVID T. -Hearing in Dallas 7/31/09 22.00
- during dates of 7/31/2009 - 7/31/2009
SADLER, KEVIN M. -Traveled to Dallas for hearing. - during dates 491.50
of 7/31/2009 - 7/31/2009
THOMAS PROCESS Service of Subpoena on Ben Barnes 80.00
CHOICEPOINT PUBLIC RECORDS, Searches for current address 25.00
information on Jon Hanna and Marina Feldman at request of Lynne
Dodge.
DEBRA LYNN GROOM D/B/A Runner checked out two books from Tarlton 24.50
Law Library
SADLER, KEVIN M. -Travel to Dallas for meeting with Examiner and 487.50
Receiver. - during dates of 6/9/2009 - 6/9/2009
STUTTS, JR., WILLIAM F. -Attend Hearings & Meetings in Canada - 2,001.55
during dates of 8/23/2009 - 8/28/2009
AMERICAN EXPRESS - STUTTS, JR., WILLIAM F. -Attend Hearings & 1,155.70
Meetings in Canada - during dates of 8/23/2009 - 8/28/2009
Cab fare for Baker Botts personnel 705.57
Computer research services 52,544.98
Continental Ct. Reporters, Inc. 8,296.98
Delivery services 22,857.31
Electronic Court Records 2,802.48
Facsimile 254.20
Legalease Secretary of State Filings 2.00
Litigation Support Services 2,376.74
Parking expense 18.00
Photocopying service 52,674.93
439
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 373 of 377
Page 372
Postage 691.83
Stationery and supplies 270.30
Telephone calls 2,519.12
_______________
Total Expenses $170,297.82
Fees: $3,576,216.50
Expenses: $170,297.82
Total Amount Due: $3,746,514.32
440
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 374 of 377
Attorneys At Law
P. O. BOX 201626
HOUSTON, TEXAS 77216-1626
TAXPAYER I.D. #74-1195457
Stanford Financial Group Receivership Invoice No. 1134163
ATTN: Mr. Ralph S. Janvey, Receiver Invoice Date September 23, 2009
2100 Ross Avenue
Suite 2600 Attorney J A Cialone, II
Dallas TX 75201
CLIENT SUMMARY
FEES
079716.0102 293,858.40
Cross Border Receivership Matters
079716.0103 67,193.20
Aviation Matters
079716.0104 46,441.40
Banking Matters
079716.0105 387,559.40
Brokerage and Trust Matters
079716.0106 38,295.80
Coin and Bullion Operations
079716.0107 192,128.50
Document Production Matters
079716.0108 41,473.40
Disclosure and Communications
079716.0109 126,002.40
Insurance Matters
441
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 375 of 377
079716.0110 163,797.40
Labor and Employment Matters
079716.0111 39,641.00
Latin American Matters
079716.0112 135,315.40
Private Equity Matters
079716.0113 128,531.50
Receivership Corporate Matters
079716.0114 121,885.50
Real Estate Matters
079716.0115 154,986.80
Tax Matters
079716.0116 170,860.80
Litigation - General
079716.0117 1,259,818.10
Litigation - SEC vs. SIB, et al
079716.0118 69,682.40
Switzerland Matters
079716.0121 46,560.60
Examiner Issues
079716.0122 18,429.50
Motion to Disqualify
079716.0123 35,753.00
Canada Litigation Matters
079716.0124 36,013.90
UK Litigation Matters
079716.0125 1,988.10
Antigua Litigation Matters
TOTAL FEES $3,576,216.50*
TOTAL EXPENSES $170,297.82
TOTAL AMOUNT DUE $3,746,514.32*
* Reflects a 20% discount off gross fees.
442
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 376 of 377
Attorneys At Law
P. O. BOX 201626
HOUSTON, TEXAS 77216-1626
TAXPAYER I.D. #74-1195457
Stanford Financial Group Receivership Invoice No. 1134163
ATTN: Mr. Ralph S. Janvey, Receiver Invoice Date September 23, 2009
2100 Ross Avenue
Suite 2600 Attorney J A Cialone, II
Dallas TX 75201
REMITTANCE ADVICE
FEES
079716.0102 293,858.40
Cross Border Receivership Matters
079716.0103 67,193.20
Aviation Matters
079716.0104 46,441.40
Banking Matters
079716.0105 387,559.40
Brokerage and Trust Matters
079716.0106 38,295.80
Coin and Bullion Operations
079716.0107 192,128.50
Document Production Matters
079716.0108 41,473.40
Disclosure and Communications
079716.0109 126,002.40
Insurance Matters
TO ENSURE PROPER APPLICATION OF YOUR PAYMENT,
PLEASE RETURN THIS REMITTANCE ADVICE.
443
Case 3:09-cv-00298-N Document 821-3 Filed 10/02/2009 Page 377 of 377
079716.0110 163,797.40
Labor and Employment Matters
079716.0111 39,641.00
Latin American Matters
079716.0112 135,315.40
Private Equity Matters
079716.0113 128,531.50
Receivership Corporate Matters
079716.0114 121,885.50
Real Estate Matters
079716.0115 154,986.80
Tax Matters
079716.0116 170,860.80
Litigation - General
079716.0117 1,259,818.10
Litigation - SEC vs. SIB, et al
079716.0118 69,682.40
Switzerland Matters
079716.0121 46,560.60
Examiner Issues
079716.0122 18,429.50
Motion to Disqualify
079716.0123 35,753.00
Canada Litigation Matters
079716.0124 36,013.90
UK Litigation Matters
079716.0125 1,988.10
Antigua Litigation Matters
TOTAL FEES $3,576,216.50*
TOTAL EXPENSES $170,297.82
TOTAL AMOUNT DUE $3,746,514.32*
* Reflects a 20% discount off gross fees.
TO ENSURE PROPER APPLICATION OF YOUR PAYMENT,
PLEASE RETURN THIS REMITTANCE ADVICE.
444