FILED¶
CLERK OF THE COURT¶
Government Exhibit 2¶
| dr | ||||||||
|---|---|---|---|---|---|---|---|---|
| r | r | r | r | r | r | r | r | |
| 1 | 01/31/20 | Representation of Estate | Further drafting supp. brief, and opp. to intervention brief and conferences same. | $630.00 hr | 6.4 | 6.4 | $4,032.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) |
| 2 | 02/02/20 | Representation of Estate | Correspondence re corrected briefs re intervention and supplemental in support of program and related correspondence. | $630.00 hr | 2.1 | 2.1 | $1,323.00 | Vague; block billing - amount of time spent on each activity not specified |
Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene)¶
Unrelated Activity (“program” appears to be reference to victims compensation fund) | | 3 | 02/08/21 | Representation of Estate | Review motion papers, research same and correspondence reply to emergency motion freeze assets | $660.00 hr | 4.3 | 4.3 | $2,838.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) | | 4 | 02/09/21 | Representation of Estate | Strategize on opposition to AG motion to freeze assets and standard and research same and related advice to clients | $660.00 hr | 5.9 | 5.9 | $3,894.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) | | | | | r r dr | | 18.7 | 18.7 | $12,087.00 | | | | | | r dr | | | | $0 | $0.00 | | | | | r dr | | | | $12,087.00 | | | r | | | | | | | | | | r | | r | r | r | r | r | r | r | | 5 | 01/23/20 | Representation of Estate | Review Motion for Intervention and Opposition to Claims Program, research re the same, and strategize response. | $500.00 hr | 2.8 | 2.8 | $1,400.00 | Unrelated Activity (Opposition to Claims Program) Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) | | 6 | 01/29/20 | Representation of Estate | Review / edit Opposition to Motion for Intervention. | $500.00 hr | 1.6 | 1.6 | $800.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) |¶
| 7 | 01/30/20 | Representation of Estate | Preparation for hearing including proposed agenda, proposed witnesses, and hearing binders, and review of quarterly accounting and edit of the same. | $500.00 hr | 2.9 | 2.9 | $1,450.00 | Vague; block billing - unclear to which “hearing” the entry refers and amount of time spent on each activity not specified¶
Unrelated Activity (quarterly accounting; 2/4/20 hearing (if, in fact, that is the hearing being referenced) related to multiple motions - not just the Government’s Motion to Intervene and Government’s Motion to Freeze Assets) | | ---- | ---------- | -------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------- | ----- | ----- | ------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 8 | 01/31/20 | Representation of Estate | Incorporation of final edits to Opposition to Motion to Intervene, Supplemental Brief, and Reply to Opposition to Motion for claims Program. | $500.00 hr | 4.8 | 4.8 | $2,400.00 | Clerical (hearing binders)¶
Vague; block billing - amount of time spent on each activity not specified¶
Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene)¶
Unrelated Activity (“Opposition to Motion for claims program appears to be reference to victims compensation fund) | | 9 | 02/03/20 | Representation of Estate | Preparation for hearing. | $500.00 hr | 4.5 | 4.5 | $2,250.00 | Vague - unclear to which hearing this entry refers¶
Unrelated Activity (2/4/20 hearing (if, in fact, that is the hearing being referenced) related to multiple motions - not just the Government’s Motion to Intervene and Government’s Motion to Freeze Assets) | | 10 | 02/04/20 | Representation of Estate | Appearance at hearing for Estate. | $500.00 hr | 4.5 | 4.5 | $2,250.00 | Vague - unclear to which hearing this entry refers¶
Unrelated Activity (2/4/20 hearing (if, in fact, that is the hearing being referenced) related to multiple motions - not just the Government’s Motion to Intervene and Government’s Motion to Freeze Assets) | | 11 | 02/04/21 | Representation of Estate | Review Motion to Freeze assets filled by AG and consider response to the same. | $500.00 hr | 0.3 | 0.3 | $150.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) | | 12 | 02/08/21 | Representation of Estate | Edits to opposition to A.G. Motion for Emergency Relief (including related research). | $500.00 hr | 7.4 | 7.4 | $3,700.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) | | 13 | 02/09/21 | Representation of Estate | Review revised Opposition to Motion to Freeze Assets and final version for filing the same. | $500.00 hr | 0.7 | 0.7 | $350.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) | | 14 | 02/18/21 | Representation of Estate | Preparation for in camera hearing. | $500.00 hr | 1.6 | 1.6 | $800.00 | Vague - unclear to which hearing this entry refers¶
Unrelated Activity (Presumably this relates to Hearing Re EVC Fund and GVI Motion listed in entry below; EVC fund not related to Government’s Motion to Intervene or Government’s Motion to Freeze Assets) | | 15 | 02/19/21 | Representation of Estate | Appearance at in camera hearing re EVC fund and GVI Motion | $500.00 hr | 1.6 | 1.6 | $800.00 | Vague - unclear to which “GVI Motion” this entry refers (presumably the Government’s Motion to Freeze Assets)¶
Unrelated Activity (Hearing Re EVC Fund) |¶
| Review Notice of Appeal and 351.41 | billed for n.-viewsng drallmg and Or editing lesptelsi to | |||
|---|---|---|---|---|
| 16 0311821 Representation of Estate | ||||
| with !eV…lading to the same. Review draft respome to notice of appeal and comments regarding the same as well as review of filing | 350011 | 0.5 | 0.5 | 5250 0) the Governments Notice of Appeal) billed for reviewing. dulling and or editing response to the ( imannicas Notice of Appal) |
| 17 03/23/21 Ropey-saltation of Estate | ||||
| deadline issue. Renew finalized response to With of | $50011 | 0.5 | 0.5 | 5250.00 billed ter rev loving. drafting ander editing response to |
| IS 032921 | ||||
| appeal foe filing. | $50011 | 0.2 | 0.2 | $10000 |
| R same atm ion of Estate Renew of Order disposing of Gaveromales appeal of orders of | the Government% Notice of Appeal) | |||
| 19 02/0722 Representation of Estate | ||||
| intervention and to flow assets. | $50011 | 0.3 | 0.3 | 515000 |
| f I r | r r | 34.2 | 34.2 | $17.100.00 |
| I r | ||||
| f | $0 | WOO | ||
| f f r | r | 517.10000 |
NI r r¶
| r | r | r Researched intervention In probate matter, and mks ant Virgin blonds | r | r | r | r r | |
|---|---|---|---|---|---|---|---|
| 20 | 011420 | Representation of Estate | |||||
| odes and Stank,. R wsln4 law relating to opposition to Government’s Motion to Inten enc. inchahng whelk, Estate may he named as party and whether Gov ern mem may | 5360.001r | 2.2 | 2.2 | $792.00 | |||
| 21 | 012620 | Representation of Estate | intervene in probate proceeding Continued drafting memorandum on | 5360.00 hr | 4.3 | 4.3 | 31,541C 00 Duplication (Attorneys Weiner. I leymann- Kroh! in. Whalen. and Andrade all hill time to shafting andor editing opposition to the Government’s Motion to |
| 22 | 0127/20 | ||||||
| Government’s Motion to Inknene. | 5360.00 hr | 0.9 | 0.9 | $324.00 | |||
| Iti.nsss tabors of Estate | Researched ease law for opposition to | Intervene) | |||||
| 23 | 0 1 4mo | Representation of Estate | |||||
| Government’s Motion to Went-no. Drafted Opposition to Motion to | 516000 hr | 1.1 | 1.1 | 3396.00 Duplication (Attorneys Weiner. Ilminann. K noth in. Whalen. and Andra& all bill time to drafting antler | |||
| 24 | 012120 | Representation of Estate | |||||
| Intervene. Began to prepare exhibits for February | 5160.00 hr | 5 | 5 | 5F10000 Intervene) Unrelated Activity (2.4.10 hearing related to multiple motions . outlast the Government’s Motion to Intervene and f :on:rams-nes Motion to Freeze Assets) | |||
| 25 | al 28 -20 | Representatain of Estate | |||||
| 4 hearing. Reviewed Opposition to Government’s | 5360.0011 | 0.2 | 02 | $7209 Clerical Work Duplication (Attorneys Weiner. Heymann. Krobl in. Whalen. and Andrade all bill time to drafting anil’or editing opposition to the Government’s Motion to | |||
| 26 | (II _2970 | Representation Representatwm ofF state | |||||
| Motion to Intervene. | $360.00 hr | 0,5 | 0.5 | SI Sri 00 Intervene) |
| Renewed and tensed Opposition to | Duplication (Auer-nays Weiner, I lernann, KmMin. Whalen. and Andrade all bill time to drafting andor editing opposition to the Government’s Motion to | |||
|---|---|---|---|---|
| 27 01/29/20 Represrntatian of Estate | ||||
| Motion to Intervene. Edits to Opposition to Gmernmenes | $360.00 hr | 0.9 | 0.9 | 5324.00 Intenrnel Duplication (Attorneys Weiner, Ile)liankKmblin. Whalen, and Andrade all bill time to drafting mutat editing opposition to the(iovernment’s Motion to |
| 214 01/3020 Renrcsentation of Estate | ||||
| Motion to linemen.. Prepared binders for February 4 | 5360.001w | 0.5 | 0.5 | SUMO) Intereenel Unrelated Activny42:420 hearing related to multiple motions . not just the Government’s Motion to Intervene and Government’s Motion to Freeze Assets) |
| 29 02/01120 ReprnelitaliOn of Estate | ||||
| hearing. Renewed citation in Aas emergency | 3360.00 hr | 5 | 5 | $1.800.00 Clerical Work Duplication (Attorneys Weiner. Heymann. Kroblin. |
| 30 02/0821 Representation of Estate | ||||
| motion to title IS. ‘9CetiOn | 34nor and | |||
| Code. | $360.001w | 0.6 | 0.6 | 5216.1x0 |
| minted title 15 of the Virgin Islands | andor editing opposition In the Gosernmenes Minion to Freeze Assets/ | |||
| r rM r | r | 21.2 | 21.2 | $7 632 00 |
| rM r | r | $0 | 5000 | |
| r M r r | 57.623.00 |
| r | ||||||||
|---|---|---|---|---|---|---|---|---|
| r | ||||||||
| 31 | 01/31/20 | Representation of Estate | Further Revised Opposition to Motion to Intervene | $400 hr | 1.2 | 1.2 | $480.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) |
| 32 | 02/01/20 | Representation of Estate | Corrected Opposition to GVI’s Motion to Intervene; revised proposed agenda for February 3, 2020; reviewed pending motions | $400 hr | 2.2 | 2.2 | $880.00 | Vague; block billing -unclear to which “pending motions” this entry refers and amount of time spent on each activity not specified |
| 33 | 02/04/21 | Representation of Estate | Calendared deadline for response to GVI’s emergency motion; tried to gain access to court website for docket; called clerk’s office to determine when GVI emergency motion was filed; communication w/team re strategy. | $400 hr | 1.8 | 1.8 | $720.00 | Vague; block billing - unclear what is meant by “communication w/team re strategy” and amount of time spent on each activity not specified |
| 34 | 02/08/21 | Representation of Estate | Researched re other probate cases and requests for injunctive relief; Reviewed Feb. 4 hearing transcript re AG’s standing in probate for inclusion in opposition | $400 hr | 3.1 | 3.1 | $1,240.00 | Clerical Work (calendared deadline; tried to gain access to court website for docket; called clerk’s office) |
| 35 | 02/10/21 | Representation of Estate | Calendared in camera conference w/judge re GVI’s Emergency Motion to Freeze Estate’s Assets | $400 hr | 0.2 | 0.2 | $80.00 | Clerical Work |
|---|---|---|---|---|---|---|---|---|
| 36 | 02/12/21 | Representation of Estate | Reviewed government’s notice of complaint filing related to emergency motion to immediately freeze all estate assets and cash on hand. | $400 hr | 0.2 | 0.2 | $80.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to reviewing, drafting, and/or editing opposition to the Government’s Motion to Freeze Assets) |
| 37 | 03/12/21 | Representation of Estate | Reviewed docket and Order denying GVI’s motion to intervene | $400 hr | 0.2 | 0.2 | $80.00 | |
| 38 | 03/23/21 | Representation of Estate | Researched computation of time for response to appeal; reviewed court docket; reviewed and commented on draft response to notice of appeal. | $400 hr | 1.2 | 1.2 | $480.00 | Duplication (attorneys Weiner, Kroblin, and Andrade all billed for reviewing and drafting and/or editing response to the Government’s Petition for Review) |
| 39 | 04/07/21 | Representation of Estate | Reviewed and circulated to clients clerk’s notice re docketed appeal; email communication to clerk of court re impact of notice and already filed Estate’s response to notice of appeal; communication w/clients and legal team re judicial assignment | $400 hr | 0.6 | 0.6 | $240.00 | |
| $\tau \quad \tau \quad \tau \quad dr \quad d$ | 10.7 | 10.7 | $4,280.00 | |||||
| $\tau \quad \tau \quad dr \quad d$ | $0 | $0.00 | ||||||
| $\tau \quad \tau \quad dr \quad d$ | $4,280.00 | |||||||
| $\tau$ | $\tau$ | $\tau$ | $\tau$ | $\tau$ | $\tau$ | $\tau$ | $\tau$ | Vague; block billing - amount of time spent on each activity not specified |
| 40 | 01/31/20 | Representation of Estate | Proofread/edit Supplemental Brief, Opposition to Motion to Intervene and Reply to Opposition to Claims Program; prepare same and First Quarter Account for filing with the Probate Court; hand deliver same; prepare mailing of all to Government; hand deliver to Post Office. | $135.00 hr | 2.5 | 2.5 | $337.50 | Unrelated Activity (Reply to Opposition to Claims Program; prepare same and First Quarter Account for filing with the Probate Court; hand deliver same; prepare mailing of all to Government; hand deliver to Post Office.” |
| 41 | 02/03/20 | Representation of Estate | Proofread/edit/prepare Opposition to Claimants’ Motion to Intervene and corrected Opposition to GVI’s Motion to Intervene for filing with the Probate Court; hand deliver same to Probate Court; prepare mailings to counsel; receipt and review date stamped same. | $135.00 hr | 2 | 2 | $270.00 | Clerical Work (hand delivering documents to court and mailing documents to counsel) |
| 42 | 02/04/20 | Representation of Estate | Assist with copies for hearing | $135.00 hr | 0.5 | 0.5 | $67.50 | Clerical Work |
| 43 | 02/28/20 | Representation of Estate | Receipt and review original GVI’s Opposition to Emergency Motion for Order Releasing Funds; file in Client file folder. | $135.00 hr | 0.2 | 0.2 | $27.00 | Vague; block billing - amount of time spent on each activity not specified |
| Unrelated Activity (Motion for Order Releasing Funds) |
| Receipt, review, placed in file GVT’s Emergency Motion to Immediately Freeze Assets. | Vague; block billing - amount of time spent on each activity not specified | |||||||
|---|---|---|---|---|---|---|---|---|
| 44 | 02/09/21 | Representation of Estate | $135.00 hr | 0.2 | 0.2 | $27.00 | Clerical Work (filing documents) | |
| 45 | 02/10/21 | Representation of Estate | Proofread/edit/prepare/e-file Opposition to AG’s Emergency Motion to Freeze Assets. | $135.00 hr | 1.1 | 1.1 | $148.50 | Clerical Work (proofreading; filing) |
| 46 | 02/17/21 | Representation of Estate | Receipt, review, and place in file date $135.00 hr stamped Opposition to Emergency Motion. | $135.00 hr | 0.3 | 0.3 | $40.50 | Vague; block billing - amount of time spent on each activity not specified |
| 47 | 03/18/21 | Representation of Estate | Receipt, review, and place in file AG’s Notice of Appeal and Petition for Review. | $135.00 hr | 0.3 | 0.3 | $40.50 | Clerical Work (filing documents) |
| 48 | 03/29/21 | Representation of Estate | Proofread/edit/prepare/e-file Opposition to Notice of Appeal. | $135.00 hr | 1 | 1 | $135.00 | Clerical Work (proofreading; filing) |
| 49 | 03/31/21 | Representation of Estate | Receipt, review, and place in file date stamped Response to Government’s Notice of Appeal. | $135.00 hr | 0.4 | 0.4 | $54.00 | Vague; block billing - amount of time spent on each activity not specified |
| r r | 8.5 | 8.5 | $1,147.50 | |||||
| r | $0.00 | $0.00 | ||||||
| r | $1,147.50 | |||||||
| r r | ||||||||
| r r | $42,246.50 | |||||||
| r d | r | 93.3 | 93.3 | $42,246.50 | ||||
| r d | r | |||||||
| r r d | M | d | ||||||
| r | r | r | r | r | ||||
| 50 | 01/28/20 | Communications with client group re February 4 hearing (.4); review draft opposition to AG’s motion to intervene (1.1). | 1,315.00 | 1.50 | 1,972.50 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) | ||
| 51 | 01/29/20 | Revise draft opposition to USVI AG’s motion to intervene. | 1,315.00 | 2.70 | 3,550.50 | Unrelated Activity (February 4 hearing involved multiple motions - not just the Government’s Motion to Intervene and Government’s Motion to Freeze Assets) | ||
| 52 | 1/30/20 | Revise draft opposition to USVI AG’s motion to intervene. | 1,315.00 | 1.80 | 2,367.00 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) | ||
| 53 | 1/31/20 | Revise opposition to USVI AG’s motion to intervene. | 1,315.00 | 0.9 | 1,183.50 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) | ||
| 54 | 2/2/20 | Revise draft opposition to claimants’ motion to intervene in USVI proceeding. | 1,315.00 | 2.3 | 3,024.50 | Duplication (Attorneys Weiner, Heymann, Kroblin, Whalen, and Andrade all bill time to drafting and/or editing opposition to the Government’s Motion to Intervene) |
| Prepare (or and attend USVI probate | Unrelated Activity (2.4.20 hearing related to multiple motions - not psi the Govern:ernes Motion to Intervene | ||||
|---|---|---|---|---|---|
| 55 | 2420 | ||||
| court hcazin Draft response to USVI AG’s | 1.315.80 | 5.1 | 6.706.50 | ||
| 56 | 2/5/21 | ||||
| ententency motion. Draft and mese opposition to USVI | 1251.00 | 4.4 | 5.504.40 | ||
| 57 | 2/6121 | ||||
| 1,251.00 | 5.9 | 7.380.90 | |||
| AG’s emnanwY motion Draft and revise opposition to USVI | Freeze Assets) | ||||
| 58 | 22/21 | ||||
| , Mrs cincrecneY motion Communications with USVI counsel and revise daft response to USVI AG’s emergency motion to freeze assets and | 1251.00 | 6.2 | 7,756.20 | ||
| 59 | 24021 | ||||
| ex s. Resist draft response to emergency | 1,251.00 | 4.8 | 6.004.80 | ||
| 60 | 2/921 | ||||
| ration. Communications with R. Kahn. D. Indyte re opposition to USVI | 1,251.00 | 5.1 | 6.380.10 | ||
| 61 | 2/1021 | ||||
| am h. …; Prepare (or and participate in USV1 Probate Court conference re EVCP | 1.00 | 1301.20 | |||
| 62 | 201921 | ||||
| ftrnding. mid report to chats re same. Renew appeal filed by USVI AG sod | 1.251.00 | 4.4 | 5.504.40 Unrelated Actisity (confaawe relating to EVCP funding) | ||
| 63 | 3/1821 | ||||
| communicatiom re tome. Draft response to USVI AG’ appeals | 1,251.00 | 0.5 | 625.50 | ||
| 64 | 321/21 | ||||
| from Magistrate Judges ordaw Resist drift response to USVI AG’s | 1.251.00 | 3.8 | 4.‘5 | ||
| 65 | 0322/21 | ||||
| appeal. Resist draft response to USVI AG appeal. and communications with client | 1.251.00 | 1.40 | 1.751.40 | ||
| 66 | oaten | ||||
| team. ISVI counsel re same. Resist draft response to USVI Airs appeal. and communications with client | 1.251.00 | 0.110 | 1.000.80 | ||
| 67 | 03/2521 | ||||
| team. USVI counsel re same Resist draft response IO USVI AG’S | 1251.00 | 1.10 | 1.376.10 | ||
| 6a | 01_26_11 | ||||
| counsel re sane | 1.251.00 | 0.70 | 875.70 | ||
| appeal. and communications with USVI Respond to client expiry re draft response to USVI AG appeal (.20): communications with USVI contact re | billed for reviewing. &Amp and editing response to | ||||
| 69 | 01.2721 | ||||
| same 1.10). | 1.251.00 | 0.30 | 375.10 |
| 70 | 03/29/21 | | Communications with USVI counsel re opposition to USVI AG’s appeal. | 1,251.00 | 0.30 | | | Vague - unclear whether USVI counsel is Estate’s local counsel or counsel for the Government¶
Duplication (if USVI counsel refers to Estate’s local counsel and there was a meeting with only attorneys for the Estate in attendance) | | ---- | ---------- | — | --------------------------------------------------------------------- | ---------- | ------ | — | — | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | | | | | | r | | | |¶