Stanford 2: May 15, 2009
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SECURITIES AND EXCHANGE COMMISSION,
§ § Plaintiff, § § v. § § STANFORD INTERNATIONAL BANK, LTD., et al., § § Defendants. §
Case No.: 3-09-CV-0298-N
__________________________________________________________________________ APPENDIX TO RECEIVER’S MOTION FOR APPROVAL OF INTERIM FEE APPLICATION AND PROCEDURES FOR FUTURE COMPENSATION OF FEES AND EXPENSES AND BRIEF IN SUPPORT __________________________________________________________________________
BAKER BOTTS L. L.P. One Shell Plaza 910 Louisiana Houston, Texas 77002-4995 (713) 229-1234 (713) 229-1522 (Facsimile)
THOMPSON & KNIGHT LLP 1722 Routh Street Suite 1500 Dallas, Texas 75201 (214) 969-1700 (214) 969-1751 (Facsimile)
ATTORNEYS FOR RECEIVER RALPH S. JANVEY
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Exhibit
Title
Appendix
Exhibit A
Report of the Receiver Dated April 23, 1-58 2009 (Doc. 336)
Exhibit B
Invoice: Krage & Janvey, L.L.P.
59-63.1
Exhibit C
Invoice: Baker Botts L.L.P.
64-80
Exhibit D
Invoice: Thompson & Knight LLP
81-91
Exhibit E
Invoice: FTI Consulting
Exhibit F
Invoice: Ernst & Young
Exhibit G
Invoice: Financial Services, Inc.
Exhibit H
Invoice: Strategic Capital Corporation
108-17
Exhibit I
Invoice: Pierpont Communications, Inc.
118-20
Exhibit J
Invoice: 3-4 South Square
121-40
Exhibit K
Invoice: Roberts & Co.
141-44
Exhibit L
Invoice: Altenburger
145-52
Exhibit M
Invoice: Osler, Hoskin & Harcourt LLP
153-65
Exhibit N
Invoice: Liskow & Lewis
166-75
Exhibit O
Invoice: Dudley, Topper and Feuerzeig, LLP 176-86
Exhibit P
U.S. Department of Justice, United States 187-233 Trustee Program, Preliminary Report on Chapter 7 Asset Cases, 1994-2000, June 2001
Exhibit Q
In re Lehman Brothers Holdings, Inc., et al. 234-37 Chapter 11 Case No. 08-13555(JMP), in the United States Bankruptcy Court for the Southern District of New York
Forensic
and
Industry
Litigation 92-100 101-04 Technical 105-07
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KRAGE & JANVEY, L.L.P. ATTORNEYS AND COUNSELORS AT LAW 2100 ROSS AVE. SUITE 2600 DALLAS, TEXAS 75201 TELEPHONE 214/969-7500 FACSIMILE 214/220-0230
STATEMENT Stanford Financial Group Receivership 5051 Westheimer Houston, Texas 77056 April 10, 2009 ______________________________________________________________________________ For Professional Services Rendered Through April 10, 2009 Previous Balance Total Current Charges Less discounted fees Total Billable Charges
Client Statement Break‐Down of Charges
$0.00 $707,368.38 (130,479.10) $576,889.28
The charges set forth in this invoice result from the efforts of the Receiver to: 1) develop a team to address the Receiver’s responsibilities under the Order of Appointment, as amended (the “Responsibilities”), 2) establish control over the far flung and diverse assets of the individual and corporate defendants as well as all entities they control, 3) identify the types of issues that need to be addressed initially and on an ongoing basis, 4) develop and implement processes for addressing asset identification, asset recovery, asset maintenance and protection, asset liquidation, claim identification, claim classification, and eventual distribution; 5) identify and implement procedures for necessary ongoing communication to employees, vendors, claimants, and the public, 6) develop a team of persons to address management of ongoing operations, 7) develop and implement a plan for closing 45 separate non‐viable business branch operations, Page 1 of 6
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8) ensure chain of custody for records is monitored and appropriately maintained, 9) appropriately coordinate with collateral litigation efforts as they arise, and 10) obtain foreign recognition of the US receivership and its world‐wide obligations as well as develop processes for interaction with domestic and foreign governmental regulators and/or variously appointed foreign liquidators or receivers. The following sets forth categories of activities that have been undertaken by the Receiver and his firm in developing and directing the receivership team. Actions of other professionals to fulfill the Receiver’s Responsibilities are set forth in separate invoices. Development of Receivership Team Developed a receivership team that included: two international law firms; a business restructuring advisor with substantial broker dealer experience; two forensic, accounting and information technology experts; a brokerage operations specialist; a security consulting firm, a coin and bullion expert, and a communications firm. Identification of Assets Subject to Order Developed previously non‐existing (and apparently non‐authorized) comprehensive list of 230+ Stanford entities and affiliates in a vast array of diverse businesses, such as securities brokerage, investment advisory services, gold coins and bullion, trust and fiduciary services, financial planning, merchant banking, venture capital, real estate development (including hotels, clubs and golf courses), investment banking, institutional securities research, securities trading, insurance strategies, commercial banking and alternative investments; Identified accounts that were managed by Stanford controlled entities or persons; Interviewed all known persons with information as to existence, location and value of assets; Identified and worked to release accounts that were not involved in material levels of fraudulent activities (brokerage, fiduciary or adviser related and de minimus accounts); and Developed and implemented process by which investors with frozen accounts could present the case that their account is not subject to estate claims.
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Establishment of Control Over Domestic Receivership Assets Delivered notice of Order of Appointment to 200+ companies, affiliates and suspected asset custodians; Identified major “control” locations throughout the U.S. and took steps to secure at least 45 locations and the assets and business records at those locations, including establishing mail receipt and document protocols, and ceasing operations; Changed the locks at certain Stanford offices, installed security personnel, moved gold coin and bullion to lock boxes in safe locations, and locked down documents and data; Interviewed all known employees suspected of knowledge of existence, location and valuation of assets; Scanned over 300 hard drives of employees with knowledge of assets or claims; Attempted to cease all known transfers of assets while we inventoried estate assets; Froze accounts with suspected activity relating to Stanford CDs; Obtained checks or promises for the return of almost $100,000 in political campaign donations; Requested the return of legal and other retainers from persons and firms previously retained by the defendants and the entities they control; Served more than 70 domestic and international depository institutions with notice of the receivership, ceased electronic transfers from those institutions, and begun arranging for the recovery of Stanford assets in their possession. Establishment of Control Over “Seized” Foreign Assets Worked to obtain foreign recognition of US receivership and claims related to SIBL and other assets located in Antigua as well as other foreign locations; Coordinated with authorities in foreign jurisdictions to secure Latin American locations and identify assets; Gave judicial notice of objection to Vantis appointment in various jurisdictions in which assets are located and worked extensively with regard to relationship with Antiguan receivers; Engaged in ongoing dialogue with East Caribbean Central Bank regarding its takeover of bank of Antigua and sale of such bank;
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Monitored Antiguan Parliament’s actions with regard to attempted seizure of Antiguan real estate assets and took actions to file an objection to such actions as well as place notice of a claim on the real estate records; Worked with Panamanian financial regulator to obtain proceeds from potential sale of bank or release of funds; Analyzed state actions regarding Venezuelan entities; Coordinated with Ecuadorian regulatory bodies regarding status of broker‐dealer; Worked with regulators and bank in connection with liquidation of Mexican broker‐ dealer; and Worked in connection with votes of interest in corporate owner of Colombian bank in various matters relating to liquidation or sale of bank. Identification and Liquidation of Assets Continued to work to trace and lock down estate related assets; Worked to value private equity and real estate assets; Secured appropriate insurance protection over assets; and Established process for liquidating real estate and personal property. Supervision of Ongoing Operations Identified and interviewed key personnel in Stanford’s major operational departments, including treasury, accounting, information technology, human resources, risk management, real estate, building operations, aviation, security, private equity investments, broker‐dealer operations, compliance, legal, and Latin American operations regarding operational needs and priorities; Served over 200 affiliated entities and known control persons worldwide as well as employees with notice of the receivership, and gave instructions about how to proceed until further notice; Developed and implemented plan to address on‐going operational needs; and Closed and vacated 45 non‐viable Stanford branch locations as part of winding down process. Reduction in the Costs of the Estate Terminated most employees in 100+ domestic locations across 16 states; Page 4 of 6
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Worked to close operations in foreign jurisdictions paid from domestic sources Engaged in secondary downsizing resulting from the winding down of the estate; Terminated most employment benefits; Worked to sell non‐operational owned buildings; Terminated unnecessary, periodic office expenses; Began process to reject 45 leases for non‐viable Stanford branches; and Established management structure for supervision of remaining employees and agents. Identification of Claims Against the Estate Reviewed records and worked to generate list of known claims and classify all known claims (including brokerage, employee, equity obligations, leasing, mortgage obligations and other liens, as well as divergent investor‐based claims); Developed and implemented claims notification process; and Began process of developing formal claims notification and objection process. Litigation Management Addressed litigation that was ongoing prior to receivership; Managed post receivership claims against the estate’s assets including priority lien claims by the Internal Revenue Service; and Responded to voluminous attempts by various interested parties (including the IRS) to gain a priority claim on assets over other investors by intervention in SEC’s case or by litigation in other forums. Communication to Victims Established a website with continually updated information as to court filings, decisions affecting employees, vendors, and investors and frequently asked questions regarding the receivership (FAQS); Established an email address so that all communications with estate are: 1) in writing, 2) documented for future reference (if needed) and 3) sent to the appropriate persons so that appropriate responses can be generated; and Increased communications with various members of the press.
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Ben L. Krage Ralph S. Janvey C. Clinton Davis Kristie L. Blumenschein Charles E. Gale Valerie P. Thomas Fees Security Consultants Travel & Hotel Expenses Air Fare Federal Express Equivalent Data (copies) UPS Messenger Service Total Fees and Disbursements
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Hours 1st Month
Hours 2nd Month
Hours Total
Rate
204.9 285.5 186 279.8 194.4 100.7
71.9 190 31.4 172.1 139.1 4
276.8 475.5 217.4 451.9 333.5 104.7
425 425 350 300 300 200
$652,377.50
$1,456.69 $14,191.69 $15,828.74 $3,849.41 $0 $0 $0
$0 $9,655.16 $7,628.70 $1,451.22 $622.26 $238.25 $68.76
$1,456.69 $23,846.85 $23,457.44 $5,300.63 $622.26 $238.25 $68.76 $54,990.88
$707,368.38
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Attorneys At Law P. O. BOX 201626 HOUSTON, TEXAS 77216-1626 TAXPAYER I.D. #74-1195457
Ralph S. Janvey, Receiver 2100 Ross Avenue Suite 2600 Dallas TX 75201 079716.0101
Invoice No. Invoice Date Attorney
1108206 May 5, 2009 J A Cialone, II
Stanford Financial Receivership
For professional services rendered and expenses incurred in connection with the Stanford Financial Receivership matter from February 13, 2009 through April 12, 2009 as described below: General Legal Advice to the Receiver •
Served as day-to-day legal counsel to the Receiver since the Receiver was appointed by the Court, and in preparation for the appointment
•
Assisted in identifying, interviewing and retaining counsel in other jurisdictions and other professionals engaged by the Receiver
•
Reviewed and participated in the negotiation of engagement letters between Receiver and other counsel and professionals
•
Assisted the Receiver in coordinating efforts of other members of his team, including Strategic Capital Corporation, FTI Consulting, Inc., Ernst & Young LLP, Financial Industry Technical Services, Inc., CB Richard Ellis, Frizell Group International LLC, Pierpont Communications Inc. and several law firms
•
Researched and analyzed law applicable to many of the issues listed below, and prepared legal memoranda regarding the same
•
Participated in numerous daily meetings with the Receiver and other members of his team to review findings and analysis regarding the matters listed below, and recommended courses of action regarding same
Litigation •
Assisted/supervised the closing of 15 Stanford offices in 13 cities; interviewed numerous Stanford employees; began gathering selected electronic and paper files and coordinated shipment to Houston
•
Responded to inquiries and demand letters from governmental agencies, employees, vendors, landlords, creditors, and utility companies, and corresponded with them regarding the Receivership and the injunction against proceedings outside the Northern District of Texas
•
Filed section 754 notices in numerous federal district courts in 16 States, the District of Columbia, Puerto Rico and the Virgin Islands
•
Secured agreed stays of numerous state and federal lawsuits filed after the Receivership was instituted; filed motions to stay in numerous other cases
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•
Secured stay of several arbitrations at FINRA, both pending at time of Receivership and filed after institution of Receivership
•
Responded in writing to notices of filing liens against Stanford property, providing notice of Court’s orders and injunction against liens
•
Worked with Stanford in-house counsel to establish Receivership oversight of numerous litigation matters pending at time of the Receivership
•
Prepared for and appeared at two TRO hearings in the Southern District of Texas, at the request of the Judge in that Court, to defend the on-going work of the Receiver
•
Provided notice of the Receivership and injunction against proceedings outside the Northern District of Texas to lawyers in over 20 cases pre-dating the Receivership
•
Prepared and filed responses to more than 65 separate pleadings by more than 390 parties, including motions seeking appointment of examiner, motions seeking leave to proceed in another forum, and more than 50 motions seeking intervention or similar relief
•
Prepared and filed show cause motion to force the return of $3 million to the Receiver
•
Prepared and filed show cause motion to stop litigation against the Receiver in the Southern District of Texas
•
Reviewed and responded to numerous communications (phone calls, emails, faxes, letters) from account holders and their representatives (attorneys, brokers)
•
Coordinated with foreign local counsel concerning litigation in Antigua and Canada
•
Analyzed insurance policies and notified D&O and excess SIPC insurers of possible claims
•
Worked with Receiver to prepare for possible Receiver testimony at two preliminary injunction hearings in the Northern District of Texas
•
Prepared for and appeared at two preliminary injunction hearings in Northern District of Texas
•
Researched and responded to issues raised by Defendant Holt’s Motion to modify Receivership Order
•
Prepared and filed response to Petition for Writ of Mandamus in Fifth Circuit
•
Prepared and served subpoenaes on third parties seeking information concerning Receivership assets
•
Responded to third party subpoena from receiver appointed over a Stanford account holder
•
Prepared and filed Motion to Compel and prepared Reply in support of Motion seeking law firm files relating to work for Stanford entities
•
Prepared and filed motions to •
authorize release of Stanford Group Company customer accounts (three separate motions),
•
approve stipulation between Receiver and Pershing LLC,
•
approve procedures for rejection of real property leases, and
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add relief defendants.
Account Freeze and Account Releases •
Analyzed issues regarding which accounts were to be frozen pursuant to the TRO and coordinated with Pershing and JP Morgan to accomplish shut down
•
Analyzed clearing agreements with Pershing and JP Morgan, and negotiated stipulation with Pershing to release from its custody $10 million of proprietary funds belonging to Stanford
•
Established protocols to allow liquidating orders and other interim measures
•
Analyzed certain mutual fund assets of Stanford clients held outside of Stanford’s custodial arrangements and determined that they should be released from the freeze
•
Developed, with input of consultants and others, criteria by which accounts could be scrutinized and released
•
Worked with other members of the team on identifying, gathering, analyzing and applying information for that purpose, including available databases regarding potential for accounts having a probability of being associated with fraudulent products or activities, as well as lists of management and employees
•
Worked with consultants and Pershing to develop procedures, and detailed customer instructions, for transferring eligible account assets using ACATS process
•
Worked with litigation team to prepare motions and orders for release of two rounds of customer accounts totaling more than 28,000 accounts
•
Developed an account review process to enable owners of the remaining approximately 4,000 Stanford Group Company accounts to provide information to the Receiver that may be relevant to whether their accounts should be released, and filed motion with the Court seeking approval of the process
•
Conducted the same analysis, including gathering and reviewing similar types of information, and assisting the Receiver in making the same decisions, with respect to the accounts at Stanford Trust Company
•
Gathered trust documents from Stanford Trust Company locations and began to review those documents to determine the legal requirements applicable to having a successor trustee appointed under each trust instrument
Reports to and Communication with Governmental and Regulatory Agencies •
Participated in numerous telephone conferences and meetings with governmental and regulatory agency representatives; prepared for and participated in a half-day meeting with such representatives on March 9 to advise the SEC of the Receiver’s work plans and progress to date, and to coordinate regarding numerous issues related to the SEC’s lawsuit and administration of the Receivership
•
Coordinated with the SEC, DOJ, FBI, USPS, DOL and DEA in identifying and gathering relevant documents and information
•
Communicated with FINRA regarding broker dealer activities
•
Established, with the assistance of the SEC and Texas State Securities Board, a weekly call with various state regulatory authorities to respond to their information requests and to provide such regulators with status reports
•
Working with employees in Stanford Capital Management’s compliance department, considered compliance issues related to termination of personnel as well as updating filings related to the Investment Advisors Act of
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1940, the broker-dealer regulations under the Securities Exchange Act of 1934 and applicable FINRA regulation •
Communicated with the Board of Governors of the Federal Reserve System on banking and trust matters
•
Communicated with state banking agencies in Texas, Louisiana, North Carolina and Florida regarding Stanford branches and other offices
•
Communicated with the Secretary of State and staff of various states to discuss issues regarding broker dealer activities and Stanford Trust Company
•
Responded to, and gathered documentation for production relating to, subpoenas and other formal document requests made by various state regulatory agencies
Communications with Customers, Employees and the Public •
Provided advice and assistance regarding communications to customers, employees, the media and the public
•
Drafted public statements by the Receiver and Frequently Asked Questions (FAQs) regarding numerous subjects
•
Established the Receiver’s website using Baker Botts information technology personnel and assisted in maintaining and frequently updating the website, including posting statements by the Receiver, FAQs, court papers and other material information
•
Coordinated and assisted in translating website materials into Spanish
•
Analyzed reports from the Receiver’s communications firm regarding the more than 10,000 emails received from customers, employees, the media, regulatory authorities and others that were sent to the email address listed on Receiver’s website
•
Participated in and often led the process of developing responses to many of those emails, either by generalized response on the website or by individual response in certain cases
•
Coordinated these communications, as well as dealings with the news media, with communications firm and other consultants and experts engaged by the Receiver
Employee Benefits and Labor and Employment •
Reviewed terms and conditions of Stanford employee benefit plans, programs and practices to determine actions required or appropriate in light of duties and responsibilities of Receiver
•
Assisted in process of identifying members of work force, including employers and reporting relationships
•
Determined medical and other insurance coverages
•
Assisted in securing continued medical plan coverage and administration
•
Participated in response to three separate inquiries/investigations from the U.S. Department of Labor
•
Assisted in preparation for and implementation of large layoff, including assisting in identifying critical path employees, assessing federal and state notification requirements, pay/payroll requirements and communications to affected employees, responding to state and local governmental inquiries regarding layoffs and employment obligations
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•
Reviewed benefit plan compliance with applicable law and initiated corrective action, where appropriate, including analyzing impact of recent federal legislation enacted by Congress regarding continuing health coverage under group health plans and the required notice requirements related to the same
•
Prepared amendments and other modifications to benefit plans in light of reduced and discontinued operations
•
Assessed liabilities under employee benefit plans to employees, employee benefit plans and governments
•
Reviewed and assessed employee obligations to Estate under a broker loan program pursuant to numerous loan agreements with varying terms
•
Handled regulatory filings necessitated by termination of employment of registered representatives and financial advisors
•
Prepared and updated a statement regarding employee benefits that addressed health care, COBRA, flexible spending accounts, disability insurance, AD&D insurance, 401(k) plans, personal belongings and severance or bonus contracts
Bank Issues and Amounts on Deposit •
Coordinated communications with approximately 240 banks or bank branches in the US and outside the US holding Stanford cash on deposit to advise them of the TRO, and efforts to protect and obtain access to those deposits
•
Addressed issues regarding, and prevented, setoff and foreclosure related to these accounts
•
Analyzed information regarding those deposits developed by other members of the Receiver’s team, made demands, made claims on U.S. custodians who had received contrary instructions from Antiguan receiver
•
Negotiated with a bank and obtained the return of approximately $17 million in cash held in the name of Stanford entities
•
Negotiated with a bank and obtained the return of approximately $1.3 million in cash collateral related to letters of credit
Stanford Private Label Funds •
Reviewed and analyzed the agreements and private placement memorandums related to these funds regarding the legal rights and obligations of investors, Stanford and third-parties
•
Participated in efforts to develop strategies to facilitate the appointment of a successor general partner for the fund, terminate Stanford’s involvement in the fund and/or recover funds for Stanford’s investments in the fund to the extent possible
•
Analyzed various issues under partnership agreements and applicable law related to investors’ rights for information regarding the private-label investment funds
•
Reviewed and analyzed Financial Services Agreement by and between MadisonGrey Fund Services, LLC and Stanford and other supporting documentation regarding administrative services provided to the private-label investments funds regarding relative rights and obligations of MadisonGrey and Stanford
5
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Broker Dealer Operational Matters •
Provided advice and assistance regarding the possible sale of branch offices or related assets, as well as potential bulk transfer of customer accounts
•
Assisted with regulatory filings necessitated by termination of employment of registered representatives and financial advisors
Real Estate •
Developed comprehensive listings of 54 owned properties and 58 leased properties in 17 U.S. states, Canada, St. Croix, St. Kitts and Europe, with information regarding ownership, encumbrances and value, as well as 49 owned properties in Antigua
•
Led general investigation as to real property of all kinds (leased or owned) by interviewing key Stanford personnel, conducting records searches, reviewing company files, assembling records and coordinating with other members of Receiver’s team concerning information collected and interviews conducted by each
•
Participated in efforts to assess values and markets in an attempt to monetize real estate assets
•
Participated in development of an overall strategy and plan regarding rejection of leased properties, in order to save costs, and prepared motion regarding procedures for rejection of leases and sale of furniture and equipment in leased space
•
Assisted in preparation implementation of the lease rejection process, rejection of leases (subject to execution of termination agreements with landlords whereby the Receiver agreed to quitclaim the personal property in exchange for landlord’s full waiver and release of claims) and negotiations with landlords regarding the amount to be paid as administrative costs for the period of time of the Receiver’s occupancy of the space, credits for furniture and limits on unsecured damage claims
•
Researched landlord’s lien law in several jurisdictions as it relates to the Receiver’s ability to sell the personal property free and clear of liens
•
Worked to determine rights with respect to security deposits and letters of credit in the Receivership in an attempt to free up cash that is tied up as collateral
•
Assisted Receiver in formulating plans to relocate the Receiver’s team, including retained Stanford Houston employees, from rented to owned space so that the lease on the larger leased space can be rejected, in order to save costs; negotiated with the landlord of the Houston headquarters to obtain its cooperation with the relocation process so as to maintain the Receiver’s operations with minimal disruption
•
Collected and responded to multiple default notices and lien notices from landlords and contractors
•
Prepared letters to landlords regarding the effects of the receivership on their ability to exercise remedies
•
Prepared letters to tenants regarding payment of rent
•
Coordinated property tax appraisals, insurance, maintenance and other activities necessary to preserve value of owned properties
•
Coordinated management and leasing activities of Stanford in its capacity as landlord of the St. Croix properties related to the continuing occupancy by building tenants
6
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•
Implemented required procedures to collect back rent from the General Services Administration for office space in St. Croix
•
Developed procedures for sale of real property that is owned by the Estate and prepared motion for approval of these procedures
•
Established brokerage arrangements with CB Richard Ellis to market and sell owned properties in a reasonably expeditious manner while attempting to maximize value
Antigua Matters •
Led the communications with competing receivership of Stanford International Bank Ltd (“SIBL”) and Stanford Trust Company Limited (“STCL”) established by Antiguan authorities, and the attempts to reach agreement on certain principles
•
Analyzed structure and operations of SIBL and STCL and status of deposits and funds
•
Led communications with Eastern Caribbean Central Bank regarding its seizure of Bank of Antigua and established procedures with that bank to divide estate funds from non-estate funds
•
Reviewed and analyzed actions by Antiguan Parliament regarding seizure of Stanford owned land and other assets, updated information and determined constitutional situation
•
Reviewed Antiguan real estate holdings, including registry of lands in Antigua and other evidence of ownership
•
Addressed points significant to the recognition of the Receivership orders, including jurisdiction, scope of operations, control of activities and range of authority in Antigua
•
Developed processes for agreed procedures for cooperative action with competing receiver
•
Coordinated effect of Antigua issues with Latin American situations, including Panama and Columbia
•
Identified proceedings previously undisclosed to the U.S. receiver for the liquidation of Stanford International Bank
•
Communicated with and coordinated matters among counsel active in opposing the proceedings brought by the Antiguan receivers and others to liquidate Stanford International Bank, with expectation that upon liquidation the Antiguan receivers would seek positions that would permit them to obtain possession of funds
•
Coordinated understanding of Antiguan law relevant to the present situations (including banking, insolvency, procedural, constitutional, real estate, corporate and cross-border matters)
Switzerland Matters •
Contacted several Swiss banks regarding Stanford accounts held by those banks
•
Participated in efforts with Swiss directors of Stanford Swiss entity (Stanford Group (Swiss) AG) regarding orderly wind-down of that entity to preserve and monetize assets; efforts included marketing of Zurich office tower currently owned by the entity, handling existing liabilities, addressing leased properties, and resolving liquidity issues
•
Evaluated issues raised by Swiss federal prosecutor's investigation into Stanford activities in Switzerland
•
Retained Swiss counsel to assist in the above efforts
7
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Canada Matters •
Addressed issues that arose from discovery of Antiguan receiver “wiping” IT equipment, including communications with regulators
•
Addressed effect of Antiguan receiver ex parte recognition in Quebec
•
Coordinated Canadian counsel in above affairs
•
Addressed issues from existing and new suits and claims filed in Alberta
England Matters •
Communicated with banks in England to determine amounts on deposit and to obtain information about the accounts; made claims and addressed competing claims being made by Antiguan receivers
•
Coordinated with English counsel in light of expected petition to be made by Antiguan receivers for recognition under English law which could change the nature of those receivers’ claims to asset in England
•
Strategic coordination with English counsel and U.S. authorities to maximize the position of the U.S. receiver in connection with the recovery of assets not yet identified
•
Worked with English counsel on points raised by, and coordination on, U.K. freezes
Litigation - Tax Matters •
Evaluated IRS Motion to Intervene related to $226.6 million of proposed and assessed taxes against Mr. Stanford personally for tax years 1999-2003
•
Negotiated with Department of Justice Tax Division as to manner in which pending Tax Court cases and pending IRS Office of Appeals proceeding against Mr. Stanford personally would be resumed in light of receivership
•
Negotiated with Department of Justice Tax Division as to manner in which the tax audits of Mr. Stanford’s tax years 2004-2007 could be conducted in light of receivership
•
Collected and began evaluating files and records related to proposed and assessed taxes of $226.6 million against Mr. Stanford personally
Insurance Matters •
Performed a comprehensive review of the insurance program that was maintained by the Stanford entities before the receivership, and communicated with brokers and other parties to cancel coverage that is no longer needed in view of the Receiver’s appointment
•
Provided initial and supplemental notices of claims to insurance carriers under policies providing primary and excess directors and officers liability coverage, excess Securities Investor Protection Corporation coverage, Financial Institutions Crime and Professional Indemnity coverage, and Foreign Political Risk coverage
•
Evaluated numerous claims and demands made by various parties relating to the Estate’s insurance policies
•
Discussed ongoing litigation matters and insurance matters with in-house counsel and employees
8
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Gold and Bullion •
Provided advice and assistance with gold coin and bullion company operations
•
Developed protocol for movement of gold and bullion inventory from Stanford facilities to JPMorgan Chase safety deposit boxes
•
Assisted in retention of consultant to assist in wind down of operations
Private Equity •
Developed comprehensive listings of private equity holdings, with information regarding ownership, potential current value and loans outstanding
•
Reviewed information and contracts related to private equity investments and evaluated rights and responsibilities with respect thereto
•
Communications with portfolio companies and counsel regarding status of investments and rights to immediate cash withdrawals where available
•
Evaluated various investment holdings for potential sale to third parties; these efforts have included, with respect to several investments, negotiations with potential interested purchasers
•
Interviewed potential advisors regarding possible engagement to market Stanford’s private equity holdings
•
Negotiated with an investment fund and obtained approximately $10.5 million in cash related to investments held in the name of a Stanford entity
•
Negotiated with escrow agent for pending private equity transaction and obtained the return of $9.7 million in cash to the Estate
•
Negotiated with a hedge fund to obtain $4 million on an early redemption of an interest in the fund, without payment of early redemption fee
Aircraft •
Supervised security and developed protocol for dealing with rights and obligations affecting aircraft and aircraft facilities, including maintenance and insurance issues
•
Reviewed information and contracts related to aircraft title and liens and developed plan for negotiation of issues related to the aircraft
•
Communicated extensively with the lender that holds liens on five of the six Stanford aircraft to obtain two independent fair market value appraisals of the five aircraft, in connection with negotiations concerning orderly sale and/or return of the aircraft to the lender and release of a portion of the substantial cash collateral held by the lender to the Receiver
•
Assisted in arrangements, including retaining aircraft broker, to assist in the sale of the Stanford aircraft
Operations •
Provided advice and assistance with daily operations at company headquarters
9
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•
Developed protocol for the receipt and delivery of mail at Stanford’s headquarters in Houston, as well as implemented plan to coordinate the collection of mail at all domestic and St. Croix offices for forwarding to Houston headquarters
•
Reviewed and coordinated payment of expenses and other obligations of the Receiver as well as prereceivership obligations of Stanford
•
Assisted in development of protocol for removal by employees of personal items from various office locations
10
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2009 Lawyer Summary TIMEKEEPER
POSITION
HOURS
DISCOUNTED RATE
DISCOUNTED TOTAL
Adams, C N
Partner
498.50
$440.00
$219,340.00
Adams, J P
Associate
340.60
$324.00
$110,354.40
Arlington, D T
Special Counsel
403.50
$380.00
$153,330.00
Austin, S W
Special Counsel
223.00
$400.00
$89,200.00
Ayers, S A D
Associate
475.50
$356.00
$169,278.00
Bauman, S C
Associate
27.40
$260.00
$7,124.00
Beech, S E
Associate
98.20
$240.00
$23,568.00
Bodron, M A
Partner
137.30
$460.00
$63,158.00
Brown, M W
Special Counsel
90.80
$324.00
$29,419.20
Partner
10.30
$420.00
$4,326.00
Carrasco, B J
Associate
29.20
$240.00
$7,008.00
Cassak, L D
Special Counsel
23.80
$440.00
$10,472.00
Casseus, S L
Associate
78.60
$240.00
$18,864.00
Cialone, II, J A
Partner
375.50
$555.00
$208,402.50
Cooper, S W
Partner
179.30
$460.00
$82,478.00
Davis, T M
Partner
414.50
$555.00
$230,047.50
Day, B A
Associate
154.80
$260.00
$40,248.00
Dazey, J E
Associate
109.60
$260.00
$28,496.00
Partner
45.20
$460.00
$20,792.00
Associate
54.90
$260.00
$14,274.00
Partner
23.40
$555.00
$12,987.00
Associate
32.10
$212.00
$6,805.20
Duffy, D P
Partner
58.80
$440.00
$25,872.00
Durst, D J
Associate
23.40
$212.00
$4,960.80
Durst, T S
Partner
278.20
$555.00
$154,401.00
Associate
15.20
$332.00
$5,046.40
Foster, J G
Special Counsel
174.90
$380.00
$66,462.00
Gold, M A
Partner
117.20
$460.00
$53,912.00
Grace, J M
Partner
20.30
$420.00
$8,526.00
Greer, J M
Associate
479.70
$276.00
$132,397.20
Gregory, M M
Special Counsel
61.90
$400.00
$24,760.00
Grounds, B G
Associate
102.80
$240.00
$24,672.00
Hamner III, H T
Associate
151.00
$340.00
$51,340.00
Partner
19.20
$500.00
$9,600.00
Higginbothom, W E
Associate
14.10
$212.00
$2,989.20
Hintze, B A
Associate
95.70
$260.00
$24,882.00
Bull, R E
DeMent, James Dolan, M J P Doty, J R Dougherty, R P
Fitzpatrick, B B
Harper, R B
11
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HOURS
DISCOUNTED RATE
Page 81 of 86
DISCOUNTED TOTAL
Hollis, J R
Associate
399.90
$212.00
$84,778.80
Howell, R I
Partner
400.90
$420.00
$168,378.00
Hurd, M C
Associate
116.50
$308.00
$35,882.00
Partner
110.80
$555.00
$61,494.00
Associate
14.70
$212.00
$3,116.40
Jeffress Jr., W H
Partner
14.90
$555.00
$8,269.50
Knight, J R
Partner
39.40
$480.00
$18,912.00
Krishan, D
Associate
73.10
$420.00
$30,702.00
Kujawski, L A
Associate
58.80
$276.00
$16,228.80
Lawrence, J B
Associate
328.10
$260.00
$85,306.00
Le, T T T
Associate
76.10
$212.00
$16,133.20
Leal, S V
Associate
67.60
$240.00
$16,224.00
Leslie, J T
Associate
505.90
$240.00
$121,416.00
Lewis, R C
Associate
43.20
$324.00
$13,996.80
LiCalsi, M B
Associate
88.00
$304.00
$26,752.00
Lin, J A
Associate
52.40
$240.00
$12,576.00
Lobb, J D
Associate
59.80
$240.00
$14,352.00
Lowman, S A
Associate
191.70
$260.00
$49,842.00
Massad, S A
Partner
392.30
$555.00
$217,726.50
McCoy, M D
Associate
66.50
$212.00
$14,098.00
McDowell, C L
Associate
17.10
$324.00
$5,540.40
Miller, C M
Associate
199.80
$212.00
$42,357.60
Mountz, T W
Partner
69.00
$500.00
$34,500.00
Murfee, E A
Associate
26.80
$292.00
$7,825.60
Myers, M G
Associate
461.30
$260.00
$119,938.00
Nelsen, J B
Associate
99.50
$276.00
$27,462.00
Nemetz, L M
Associate
20.00
$380.00
$7,600.00
Pace, J K
Associate
68.60
$276.00
$18,933.60
Poff, J S
Partner
133.00
$500.00
$66,500.00
Preston-Jones, R T
Associate
66.70
$480.00
$32,016.00
Pullin, Z T
Associate
79.30
$212.00
$16,811.60
Raborn, J R
Partner
176.80
$555.00
$98,124.00
Rains, D J
Associate
62.80
$212.00
$13,313.60
Raley, J E
Special Counsel
14.50
$380.00
$5,510.00
Ramos, J M
Associate
57.10
$308.00
$17,586.80
Rancher, C W
Associate
401.80
$212.00
$85,181.60
Roberts, I E
Associate
40.60
$260.00
$10,556.00
Partner
236.10
$400.00
$94,440.00
Husseini, R A Ingram, P R
Robertson, R L
12
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TIMEKEEPER Ross, J L
Document 385
POSITION
Filed 05/15/2009
HOURS
DISCOUNTED RATE
Page 82 of 86
DISCOUNTED TOTAL
Partner
12.70
$480.00
$6,096.00
Associate
94.80
$324.00
$30,715.20
Sadler, K M
Partner
504.80
$555.00
$280,164.00
Sawers, J K
Partner
14.70
$440.00
$6,468.00
Schlanger, K E
Associate
327.30
$308.00
$100,808.40
Scioneaux, M C
Associate
125.50
$240.00
$30,120.00
Scott, M L
Special Counsel
241.40
$380.00
$91,732.00
Shah, R K
Associate
39.20
$212.00
$8,310.40
Slania, A K
Associate
73.70
$260.00
$19,162.00
Soderlund, E A
Associate
353.10
$324.00
$114,404.40
Souder, H M
Associate
24.10
$256.00
$6,169.60
Stewart, J C
Associate
93.60
$240.00
$22,464.00
Stockbridge, A M
Associate
22.80
$240.00
$5,472.00
Stutts, Jr., W F
Partner
423.70
$555.00
$235,153.50
Sulentic, A M
Associate
207.70
$356.00
$73,941.20
Taylor, D W
Partner
13.50
$480.00
$6,480.00
Timmons-Pierce, A M
Associate
16.10
$332.00
$5,345.20
Totaro, M V
Associate
17.40
$280.00
$4,872.00
Tucker, H C
Associate
399.00
$212.00
$84,588.00
Walters, T J
Associate
85.00
$212.00
$18,020.00
Wang, L P
Associate
255.20
$276.00
$70,435.20
Watts, W C
Associate
169.80
$212.00
$35,997.60
Wood, M C
Associate
45.10
$212.00
$9,561.20
Wood, R H
Associate
27.50
$212.00
$5,830.00
Wright, R P
Partner
215.90
$460.00
$99,314.00
York, A F
Associate
111.00
$212.00
$23,532.00
Zabaneh, J P
Associate
175.00
$240.00
$42,000.00
Rubenstein, J B
14,859.40
13
$5,297,329.10
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2009 Non-Lawyer Summary TIMEKEEPER
POSITION
HOURS
DISCOUNTED RATE
DISCOUNTED TOTAL
Burnett, M E
Research Librarian
16.90
$100.00
$1,690.00
Caine, R M
Paralegal
75.30
$148.00
$11,144.40
Chappel, H M
Paralegal Clerk
44.80
$100.00
$4,480.00
Cominsky, C W
Senior Paralegal
309.80
$160.00
$49,568.00
Dodge, L E
Senior Paralegal
45.50
$160.00
$7,280.00
Fitzwater, J S
Paralegal Clerk
193.50
$92.00
$17,802.00
Fluker, L C
Paralegal
65.40
$160.00
$10,464.00
Garcia, V O
Paralegal
16.40
$120.00
$1,968.00
Gaskamp, K L
Paralegal
16.20
$132.00
$2,138.40
George, D L
Senior Paralegal
143.50
$160.00
$22,960.00
Gonzalez Jr., H
Document Review Attorney
76.00
$140.00
$10,640.00
Hinton, K W
Paralegal
247.60
$128.00
$31,692.80
Huddleston, J C
Paralegal
340.00
$148.00
$50,320.00
Jampala, S
Paralegal Clerk
179.50
$100.00
$17,950.00
Kusey, M D
Senior Paralegal
158.40
$160.00
$25,344.00
Moratto Jr., T M
Paralegal Clerk
13.70
$100.00
$1,370.00
O'Quinn, J G
Benefits Professional
27.00
$220.00
$5,940.00
Owens, S M
Paralegal Clerk
174.70
$100.00
$17,470.00
Prudhomme, R J
Paralegal Clerk
37.20
$92.00
$3,422.40
Rohleder, D S
Paralegal Clerk
18.30
$92.00
$1,683.60
Saucier, D L
Senior Paralegal
17.00
$148.00
$2,516.00
Scanlan, K
Paralegal
358.40
$140.00
$50,176.00
Starbuck, N M
Paralegal Clerk
311.70
$100.00
$31,170.00
Thomas, J E
Developer
110.30
$136.00
$15,000.80
Walker, V R
Records Management Staff
16.20
$60.00
$972.00
Whiting, L G
Paralegal Clerk
106.20
$100.00
$10,620.00
3,119.50
14
$405,782.40
77
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SUMMARY Fees at 20% Discount
$5,703,111.50
Expenses
$180,605.27 ________________
Total Amount Due:
$5,883,716.77
15
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Detail for expenses incurred: CAPITOL SERVICES, INC. Stanford Financial Group Company
1,686.64
Locksmith for closing office
188.48
Service of subpoena
100.00
Computer and other research services
93,926.89
Conference room facilities and services
356.99
Delivery and postage service
6,122.14
Photocopying service
19,838.14
Facsimile
4,112.60
Litigation Support Services
436.72
Stationery and supplies
904.72
Telephone calls
1,891.54
Travel expense
50,923.77
Website Hosting fee
116.64
Total Expenses:
$180,605.27
16
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Attorneys At Law P. O. BOX 201626 HOUSTON, TEXAS 77216-1626 TAXPAYER I.D. #74-1195457
REMITTANCE STATEMENT
Matter #
079716.0101
Matter Name
Stanford Financial Receivership
Client Name
JANVEY, RALPH S., RECEIVER
Invoice #
1108206
Billing Attorney
J A Cialone, II
Office
Houston
TOTAL FEES AT 20% DISCOUNT
$5,703,111.50
TOTAL EXPENSES:
$180,605.27
TOTAL INVOICE:
$5,883,716.77
WIRING INSTRUCTIONS
TO ENSURE PROPER APPLICATION OF YOUR PAYMENT, PLEASE RETURN THIS REMITTANCE ADVICE.
17
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION SECURITIES AND EXCHANGE COMMISSION,
§ § Plaintiff, § § v. § § STANFORD INTERNATIONAL BANK, LTD., et al., § § Defendants. §
Case No.: 3-09-CV-0298-N
__________________________________________________________________________ APPENDIX TO RECEIVER’S MOTION FOR APPROVAL OF INTERIM FEE APPLICATION AND PROCEDURES FOR FUTURE COMPENSATION OF FEES AND EXPENSES AND BRIEF IN SUPPORT __________________________________________________________________________
BAKER BOTTS L. L.P. One Shell Plaza 910 Louisiana Houston, Texas 77002-4995 (713) 229-1234 (713) 229-1522 (Facsimile)
THOMPSON & KNIGHT LLP 1722 Routh Street Suite 1500 Dallas, Texas 75201 (214) 969-1700 (214) 969-1751 (Facsimile)
ATTORNEYS FOR RECEIVER RALPH S. JANVEY
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Exhibit
Title
Appendix
Exhibit A
Report of the Receiver Dated April 23, 1-58 2009 (Doc. 336)
Exhibit B
Invoice: Krage & Janvey, L.L.P.
59-63.1
Exhibit C
Invoice: Baker Botts L.L.P.
64-80
Exhibit D
Invoice: Thompson & Knight LLP
81-91
Exhibit E
Invoice: FTI Consulting
Exhibit F
Invoice: Ernst & Young
Exhibit G
Invoice: Financial Services, Inc.
Exhibit H
Invoice: Strategic Capital Corporation
108-17
Exhibit I
Invoice: Pierpont Communications, Inc.
118-20
Exhibit J
Invoice: 3-4 South Square
121-40
Exhibit K
Invoice: Roberts & Co.
141-44
Exhibit L
Invoice: Altenburger
145-52
Exhibit M
Invoice: Osler, Hoskin & Harcourt LLP
153-65
Exhibit N
Invoice: Liskow & Lewis
166-75
Exhibit O
Invoice: Dudley, Topper and Feuerzeig, LLP 176-86
Exhibit P
U.S. Department of Justice, United States 187-233 Trustee Program, Preliminary Report on Chapter 7 Asset Cases, 1994-2000, June 2001
Exhibit Q
In re Lehman Brothers Holdings, Inc., et al. 234-37 Chapter 11 Case No. 08-13555(JMP), in the United States Bankruptcy Court for the Southern District of New York
Forensic
and
Industry
Litigation 92-100 101-04 Technical 105-07
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KRAGE & JANVEY, L.L.P. ATTORNEYS AND COUNSELORS AT LAW 2100 ROSS AVE. SUITE 2600 DALLAS, TEXAS 75201 TELEPHONE 214/969-7500 FACSIMILE 214/220-0230
STATEMENT Stanford Financial Group Receivership 5051 Westheimer Houston, Texas 77056 April 10, 2009 ______________________________________________________________________________ For Professional Services Rendered Through April 10, 2009 Previous Balance Total Current Charges Less discounted fees Total Billable Charges
Client Statement Break‐Down of Charges
$0.00 $707,368.38 (130,479.10) $576,889.28
The charges set forth in this invoice result from the efforts of the Receiver to: 1) develop a team to address the Receiver’s responsibilities under the Order of Appointment, as amended (the “Responsibilities”), 2) establish control over the far flung and diverse assets of the individual and corporate defendants as well as all entities they control, 3) identify the types of issues that need to be addressed initially and on an ongoing basis, 4) develop and implement processes for addressing asset identification, asset recovery, asset maintenance and protection, asset liquidation, claim identification, claim classification, and eventual distribution; 5) identify and implement procedures for necessary ongoing communication to employees, vendors, claimants, and the public, 6) develop a team of persons to address management of ongoing operations, 7) develop and implement a plan for closing 45 separate non‐viable business branch operations, Page 1 of 6
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8) ensure chain of custody for records is monitored and appropriately maintained, 9) appropriately coordinate with collateral litigation efforts as they arise, and 10) obtain foreign recognition of the US receivership and its world‐wide obligations as well as develop processes for interaction with domestic and foreign governmental regulators and/or variously appointed foreign liquidators or receivers. The following sets forth categories of activities that have been undertaken by the Receiver and his firm in developing and directing the receivership team. Actions of other professionals to fulfill the Receiver’s Responsibilities are set forth in separate invoices. Development of Receivership Team Developed a receivership team that included: two international law firms; a business restructuring advisor with substantial broker dealer experience; two forensic, accounting and information technology experts; a brokerage operations specialist; a security consulting firm, a coin and bullion expert, and a communications firm. Identification of Assets Subject to Order Developed previously non‐existing (and apparently non‐authorized) comprehensive list of 230+ Stanford entities and affiliates in a vast array of diverse businesses, such as securities brokerage, investment advisory services, gold coins and bullion, trust and fiduciary services, financial planning, merchant banking, venture capital, real estate development (including hotels, clubs and golf courses), investment banking, institutional securities research, securities trading, insurance strategies, commercial banking and alternative investments; Identified accounts that were managed by Stanford controlled entities or persons; Interviewed all known persons with information as to existence, location and value of assets; Identified and worked to release accounts that were not involved in material levels of fraudulent activities (brokerage, fiduciary or adviser related and de minimus accounts); and Developed and implemented process by which investors with frozen accounts could present the case that their account is not subject to estate claims.
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Establishment of Control Over Domestic Receivership Assets Delivered notice of Order of Appointment to 200+ companies, affiliates and suspected asset custodians; Identified major “control” locations throughout the U.S. and took steps to secure at least 45 locations and the assets and business records at those locations, including establishing mail receipt and document protocols, and ceasing operations; Changed the locks at certain Stanford offices, installed security personnel, moved gold coin and bullion to lock boxes in safe locations, and locked down documents and data; Interviewed all known employees suspected of knowledge of existence, location and valuation of assets; Scanned over 300 hard drives of employees with knowledge of assets or claims; Attempted to cease all known transfers of assets while we inventoried estate assets; Froze accounts with suspected activity relating to Stanford CDs; Obtained checks or promises for the return of almost $100,000 in political campaign donations; Requested the return of legal and other retainers from persons and firms previously retained by the defendants and the entities they control; Served more than 70 domestic and international depository institutions with notice of the receivership, ceased electronic transfers from those institutions, and begun arranging for the recovery of Stanford assets in their possession. Establishment of Control Over “Seized” Foreign Assets Worked to obtain foreign recognition of US receivership and claims related to SIBL and other assets located in Antigua as well as other foreign locations; Coordinated with authorities in foreign jurisdictions to secure Latin American locations and identify assets; Gave judicial notice of objection to Vantis appointment in various jurisdictions in which assets are located and worked extensively with regard to relationship with Antiguan receivers; Engaged in ongoing dialogue with East Caribbean Central Bank regarding its takeover of bank of Antigua and sale of such bank;
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Monitored Antiguan Parliament’s actions with regard to attempted seizure of Antiguan real estate assets and took actions to file an objection to such actions as well as place notice of a claim on the real estate records; Worked with Panamanian financial regulator to obtain proceeds from potential sale of bank or release of funds; Analyzed state actions regarding Venezuelan entities; Coordinated with Ecuadorian regulatory bodies regarding status of broker‐dealer; Worked with regulators and bank in connection with liquidation of Mexican broker‐ dealer; and Worked in connection with votes of interest in corporate owner of Colombian bank in various matters relating to liquidation or sale of bank. Identification and Liquidation of Assets Continued to work to trace and lock down estate related assets; Worked to value private equity and real estate assets; Secured appropriate insurance protection over assets; and Established process for liquidating real estate and personal property. Supervision of Ongoing Operations Identified and interviewed key personnel in Stanford’s major operational departments, including treasury, accounting, information technology, human resources, risk management, real estate, building operations, aviation, security, private equity investments, broker‐dealer operations, compliance, legal, and Latin American operations regarding operational needs and priorities; Served over 200 affiliated entities and known control persons worldwide as well as employees with notice of the receivership, and gave instructions about how to proceed until further notice; Developed and implemented plan to address on‐going operational needs; and Closed and vacated 45 non‐viable Stanford branch locations as part of winding down process. Reduction in the Costs of the Estate Terminated most employees in 100+ domestic locations across 16 states; Page 4 of 6
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Worked to close operations in foreign jurisdictions paid from domestic sources Engaged in secondary downsizing resulting from the winding down of the estate; Terminated most employment benefits; Worked to sell non‐operational owned buildings; Terminated unnecessary, periodic office expenses; Began process to reject 45 leases for non‐viable Stanford branches; and Established management structure for supervision of remaining employees and agents. Identification of Claims Against the Estate Reviewed records and worked to generate list of known claims and classify all known claims (including brokerage, employee, equity obligations, leasing, mortgage obligations and other liens, as well as divergent investor‐based claims); Developed and implemented claims notification process; and Began process of developing formal claims notification and objection process. Litigation Management Addressed litigation that was ongoing prior to receivership; Managed post receivership claims against the estate’s assets including priority lien claims by the Internal Revenue Service; and Responded to voluminous attempts by various interested parties (including the IRS) to gain a priority claim on assets over other investors by intervention in SEC’s case or by litigation in other forums. Communication to Victims Established a website with continually updated information as to court filings, decisions affecting employees, vendors, and investors and frequently asked questions regarding the receivership (FAQS); Established an email address so that all communications with estate are: 1) in writing, 2) documented for future reference (if needed) and 3) sent to the appropriate persons so that appropriate responses can be generated; and Increased communications with various members of the press.
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Ben L. Krage Ralph S. Janvey C. Clinton Davis Kristie L. Blumenschein Charles E. Gale Valerie P. Thomas Fees Security Consultants Travel & Hotel Expenses Air Fare Federal Express Equivalent Data (copies) UPS Messenger Service Total Fees and Disbursements
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Hours 1st Month
Hours 2nd Month
Hours Total
Rate
204.9 285.5 186 279.8 194.4 100.7
71.9 190 31.4 172.1 139.1 4
276.8 475.5 217.4 451.9 333.5 104.7
425 425 350 300 300 200
$652,377.50
$1,456.69 $14,191.69 $15,828.74 $3,849.41 $0 $0 $0
$0 $9,655.16 $7,628.70 $1,451.22 $622.26 $238.25 $68.76
$1,456.69 $23,846.85 $23,457.44 $5,300.63 $622.26 $238.25 $68.76 $54,990.88
$707,368.38
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Attorneys At Law P. O. BOX 201626 HOUSTON, TEXAS 77216-1626 TAXPAYER I.D. #74-1195457
Ralph S. Janvey, Receiver 2100 Ross Avenue Suite 2600 Dallas TX 75201 079716.0101
Invoice No. Invoice Date Attorney
1108206 May 5, 2009 J A Cialone, II
Stanford Financial Receivership
For professional services rendered and expenses incurred in connection with the Stanford Financial Receivership matter from February 13, 2009 through April 12, 2009 as described below: General Legal Advice to the Receiver •
Served as day-to-day legal counsel to the Receiver since the Receiver was appointed by the Court, and in preparation for the appointment
•
Assisted in identifying, interviewing and retaining counsel in other jurisdictions and other professionals engaged by the Receiver
•
Reviewed and participated in the negotiation of engagement letters between Receiver and other counsel and professionals
•
Assisted the Receiver in coordinating efforts of other members of his team, including Strategic Capital Corporation, FTI Consulting, Inc., Ernst & Young LLP, Financial Industry Technical Services, Inc., CB Richard Ellis, Frizell Group International LLC, Pierpont Communications Inc. and several law firms
•
Researched and analyzed law applicable to many of the issues listed below, and prepared legal memoranda regarding the same
•
Participated in numerous daily meetings with the Receiver and other members of his team to review findings and analysis regarding the matters listed below, and recommended courses of action regarding same
Litigation •
Assisted/supervised the closing of 15 Stanford offices in 13 cities; interviewed numerous Stanford employees; began gathering selected electronic and paper files and coordinated shipment to Houston
•
Responded to inquiries and demand letters from governmental agencies, employees, vendors, landlords, creditors, and utility companies, and corresponded with them regarding the Receivership and the injunction against proceedings outside the Northern District of Texas
•
Filed section 754 notices in numerous federal district courts in 16 States, the District of Columbia, Puerto Rico and the Virgin Islands
•
Secured agreed stays of numerous state and federal lawsuits filed after the Receivership was instituted; filed motions to stay in numerous other cases
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•
Secured stay of several arbitrations at FINRA, both pending at time of Receivership and filed after institution of Receivership
•
Responded in writing to notices of filing liens against Stanford property, providing notice of Court’s orders and injunction against liens
•
Worked with Stanford in-house counsel to establish Receivership oversight of numerous litigation matters pending at time of the Receivership
•
Prepared for and appeared at two TRO hearings in the Southern District of Texas, at the request of the Judge in that Court, to defend the on-going work of the Receiver
•
Provided notice of the Receivership and injunction against proceedings outside the Northern District of Texas to lawyers in over 20 cases pre-dating the Receivership
•
Prepared and filed responses to more than 65 separate pleadings by more than 390 parties, including motions seeking appointment of examiner, motions seeking leave to proceed in another forum, and more than 50 motions seeking intervention or similar relief
•
Prepared and filed show cause motion to force the return of $3 million to the Receiver
•
Prepared and filed show cause motion to stop litigation against the Receiver in the Southern District of Texas
•
Reviewed and responded to numerous communications (phone calls, emails, faxes, letters) from account holders and their representatives (attorneys, brokers)
•
Coordinated with foreign local counsel concerning litigation in Antigua and Canada
•
Analyzed insurance policies and notified D&O and excess SIPC insurers of possible claims
•
Worked with Receiver to prepare for possible Receiver testimony at two preliminary injunction hearings in the Northern District of Texas
•
Prepared for and appeared at two preliminary injunction hearings in Northern District of Texas
•
Researched and responded to issues raised by Defendant Holt’s Motion to modify Receivership Order
•
Prepared and filed response to Petition for Writ of Mandamus in Fifth Circuit
•
Prepared and served subpoenaes on third parties seeking information concerning Receivership assets
•
Responded to third party subpoena from receiver appointed over a Stanford account holder
•
Prepared and filed Motion to Compel and prepared Reply in support of Motion seeking law firm files relating to work for Stanford entities
•
Prepared and filed motions to •
authorize release of Stanford Group Company customer accounts (three separate motions),
•
approve stipulation between Receiver and Pershing LLC,
•
approve procedures for rejection of real property leases, and
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add relief defendants.
Account Freeze and Account Releases •
Analyzed issues regarding which accounts were to be frozen pursuant to the TRO and coordinated with Pershing and JP Morgan to accomplish shut down
•
Analyzed clearing agreements with Pershing and JP Morgan, and negotiated stipulation with Pershing to release from its custody $10 million of proprietary funds belonging to Stanford
•
Established protocols to allow liquidating orders and other interim measures
•
Analyzed certain mutual fund assets of Stanford clients held outside of Stanford’s custodial arrangements and determined that they should be released from the freeze
•
Developed, with input of consultants and others, criteria by which accounts could be scrutinized and released
•
Worked with other members of the team on identifying, gathering, analyzing and applying information for that purpose, including available databases regarding potential for accounts having a probability of being associated with fraudulent products or activities, as well as lists of management and employees
•
Worked with consultants and Pershing to develop procedures, and detailed customer instructions, for transferring eligible account assets using ACATS process
•
Worked with litigation team to prepare motions and orders for release of two rounds of customer accounts totaling more than 28,000 accounts
•
Developed an account review process to enable owners of the remaining approximately 4,000 Stanford Group Company accounts to provide information to the Receiver that may be relevant to whether their accounts should be released, and filed motion with the Court seeking approval of the process
•
Conducted the same analysis, including gathering and reviewing similar types of information, and assisting the Receiver in making the same decisions, with respect to the accounts at Stanford Trust Company
•
Gathered trust documents from Stanford Trust Company locations and began to review those documents to determine the legal requirements applicable to having a successor trustee appointed under each trust instrument
Reports to and Communication with Governmental and Regulatory Agencies •
Participated in numerous telephone conferences and meetings with governmental and regulatory agency representatives; prepared for and participated in a half-day meeting with such representatives on March 9 to advise the SEC of the Receiver’s work plans and progress to date, and to coordinate regarding numerous issues related to the SEC’s lawsuit and administration of the Receivership
•
Coordinated with the SEC, DOJ, FBI, USPS, DOL and DEA in identifying and gathering relevant documents and information
•
Communicated with FINRA regarding broker dealer activities
•
Established, with the assistance of the SEC and Texas State Securities Board, a weekly call with various state regulatory authorities to respond to their information requests and to provide such regulators with status reports
•
Working with employees in Stanford Capital Management’s compliance department, considered compliance issues related to termination of personnel as well as updating filings related to the Investment Advisors Act of
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1940, the broker-dealer regulations under the Securities Exchange Act of 1934 and applicable FINRA regulation •
Communicated with the Board of Governors of the Federal Reserve System on banking and trust matters
•
Communicated with state banking agencies in Texas, Louisiana, North Carolina and Florida regarding Stanford branches and other offices
•
Communicated with the Secretary of State and staff of various states to discuss issues regarding broker dealer activities and Stanford Trust Company
•
Responded to, and gathered documentation for production relating to, subpoenas and other formal document requests made by various state regulatory agencies
Communications with Customers, Employees and the Public •
Provided advice and assistance regarding communications to customers, employees, the media and the public
•
Drafted public statements by the Receiver and Frequently Asked Questions (FAQs) regarding numerous subjects
•
Established the Receiver’s website using Baker Botts information technology personnel and assisted in maintaining and frequently updating the website, including posting statements by the Receiver, FAQs, court papers and other material information
•
Coordinated and assisted in translating website materials into Spanish
•
Analyzed reports from the Receiver’s communications firm regarding the more than 10,000 emails received from customers, employees, the media, regulatory authorities and others that were sent to the email address listed on Receiver’s website
•
Participated in and often led the process of developing responses to many of those emails, either by generalized response on the website or by individual response in certain cases
•
Coordinated these communications, as well as dealings with the news media, with communications firm and other consultants and experts engaged by the Receiver
Employee Benefits and Labor and Employment •
Reviewed terms and conditions of Stanford employee benefit plans, programs and practices to determine actions required or appropriate in light of duties and responsibilities of Receiver
•
Assisted in process of identifying members of work force, including employers and reporting relationships
•
Determined medical and other insurance coverages
•
Assisted in securing continued medical plan coverage and administration
•
Participated in response to three separate inquiries/investigations from the U.S. Department of Labor
•
Assisted in preparation for and implementation of large layoff, including assisting in identifying critical path employees, assessing federal and state notification requirements, pay/payroll requirements and communications to affected employees, responding to state and local governmental inquiries regarding layoffs and employment obligations
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•
Reviewed benefit plan compliance with applicable law and initiated corrective action, where appropriate, including analyzing impact of recent federal legislation enacted by Congress regarding continuing health coverage under group health plans and the required notice requirements related to the same
•
Prepared amendments and other modifications to benefit plans in light of reduced and discontinued operations
•
Assessed liabilities under employee benefit plans to employees, employee benefit plans and governments
•
Reviewed and assessed employee obligations to Estate under a broker loan program pursuant to numerous loan agreements with varying terms
•
Handled regulatory filings necessitated by termination of employment of registered representatives and financial advisors
•
Prepared and updated a statement regarding employee benefits that addressed health care, COBRA, flexible spending accounts, disability insurance, AD&D insurance, 401(k) plans, personal belongings and severance or bonus contracts
Bank Issues and Amounts on Deposit •
Coordinated communications with approximately 240 banks or bank branches in the US and outside the US holding Stanford cash on deposit to advise them of the TRO, and efforts to protect and obtain access to those deposits
•
Addressed issues regarding, and prevented, setoff and foreclosure related to these accounts
•
Analyzed information regarding those deposits developed by other members of the Receiver’s team, made demands, made claims on U.S. custodians who had received contrary instructions from Antiguan receiver
•
Negotiated with a bank and obtained the return of approximately $17 million in cash held in the name of Stanford entities
•
Negotiated with a bank and obtained the return of approximately $1.3 million in cash collateral related to letters of credit
Stanford Private Label Funds •
Reviewed and analyzed the agreements and private placement memorandums related to these funds regarding the legal rights and obligations of investors, Stanford and third-parties
•
Participated in efforts to develop strategies to facilitate the appointment of a successor general partner for the fund, terminate Stanford’s involvement in the fund and/or recover funds for Stanford’s investments in the fund to the extent possible
•
Analyzed various issues under partnership agreements and applicable law related to investors’ rights for information regarding the private-label investment funds
•
Reviewed and analyzed Financial Services Agreement by and between MadisonGrey Fund Services, LLC and Stanford and other supporting documentation regarding administrative services provided to the private-label investments funds regarding relative rights and obligations of MadisonGrey and Stanford
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Broker Dealer Operational Matters •
Provided advice and assistance regarding the possible sale of branch offices or related assets, as well as potential bulk transfer of customer accounts
•
Assisted with regulatory filings necessitated by termination of employment of registered representatives and financial advisors
Real Estate •
Developed comprehensive listings of 54 owned properties and 58 leased properties in 17 U.S. states, Canada, St. Croix, St. Kitts and Europe, with information regarding ownership, encumbrances and value, as well as 49 owned properties in Antigua
•
Led general investigation as to real property of all kinds (leased or owned) by interviewing key Stanford personnel, conducting records searches, reviewing company files, assembling records and coordinating with other members of Receiver’s team concerning information collected and interviews conducted by each
•
Participated in efforts to assess values and markets in an attempt to monetize real estate assets
•
Participated in development of an overall strategy and plan regarding rejection of leased properties, in order to save costs, and prepared motion regarding procedures for rejection of leases and sale of furniture and equipment in leased space
•
Assisted in preparation implementation of the lease rejection process, rejection of leases (subject to execution of termination agreements with landlords whereby the Receiver agreed to quitclaim the personal property in exchange for landlord’s full waiver and release of claims) and negotiations with landlords regarding the amount to be paid as administrative costs for the period of time of the Receiver’s occupancy of the space, credits for furniture and limits on unsecured damage claims
•
Researched landlord’s lien law in several jurisdictions as it relates to the Receiver’s ability to sell the personal property free and clear of liens
•
Worked to determine rights with respect to security deposits and letters of credit in the Receivership in an attempt to free up cash that is tied up as collateral
•
Assisted Receiver in formulating plans to relocate the Receiver’s team, including retained Stanford Houston employees, from rented to owned space so that the lease on the larger leased space can be rejected, in order to save costs; negotiated with the landlord of the Houston headquarters to obtain its cooperation with the relocation process so as to maintain the Receiver’s operations with minimal disruption
•
Collected and responded to multiple default notices and lien notices from landlords and contractors
•
Prepared letters to landlords regarding the effects of the receivership on their ability to exercise remedies
•
Prepared letters to tenants regarding payment of rent
•
Coordinated property tax appraisals, insurance, maintenance and other activities necessary to preserve value of owned properties
•
Coordinated management and leasing activities of Stanford in its capacity as landlord of the St. Croix properties related to the continuing occupancy by building tenants
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•
Implemented required procedures to collect back rent from the General Services Administration for office space in St. Croix
•
Developed procedures for sale of real property that is owned by the Estate and prepared motion for approval of these procedures
•
Established brokerage arrangements with CB Richard Ellis to market and sell owned properties in a reasonably expeditious manner while attempting to maximize value
Antigua Matters •
Led the communications with competing receivership of Stanford International Bank Ltd (“SIBL”) and Stanford Trust Company Limited (“STCL”) established by Antiguan authorities, and the attempts to reach agreement on certain principles
•
Analyzed structure and operations of SIBL and STCL and status of deposits and funds
•
Led communications with Eastern Caribbean Central Bank regarding its seizure of Bank of Antigua and established procedures with that bank to divide estate funds from non-estate funds
•
Reviewed and analyzed actions by Antiguan Parliament regarding seizure of Stanford owned land and other assets, updated information and determined constitutional situation
•
Reviewed Antiguan real estate holdings, including registry of lands in Antigua and other evidence of ownership
•
Addressed points significant to the recognition of the Receivership orders, including jurisdiction, scope of operations, control of activities and range of authority in Antigua
•
Developed processes for agreed procedures for cooperative action with competing receiver
•
Coordinated effect of Antigua issues with Latin American situations, including Panama and Columbia
•
Identified proceedings previously undisclosed to the U.S. receiver for the liquidation of Stanford International Bank
•
Communicated with and coordinated matters among counsel active in opposing the proceedings brought by the Antiguan receivers and others to liquidate Stanford International Bank, with expectation that upon liquidation the Antiguan receivers would seek positions that would permit them to obtain possession of funds
•
Coordinated understanding of Antiguan law relevant to the present situations (including banking, insolvency, procedural, constitutional, real estate, corporate and cross-border matters)
Switzerland Matters •
Contacted several Swiss banks regarding Stanford accounts held by those banks
•
Participated in efforts with Swiss directors of Stanford Swiss entity (Stanford Group (Swiss) AG) regarding orderly wind-down of that entity to preserve and monetize assets; efforts included marketing of Zurich office tower currently owned by the entity, handling existing liabilities, addressing leased properties, and resolving liquidity issues
•
Evaluated issues raised by Swiss federal prosecutor's investigation into Stanford activities in Switzerland
•
Retained Swiss counsel to assist in the above efforts
7
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Canada Matters •
Addressed issues that arose from discovery of Antiguan receiver “wiping” IT equipment, including communications with regulators
•
Addressed effect of Antiguan receiver ex parte recognition in Quebec
•
Coordinated Canadian counsel in above affairs
•
Addressed issues from existing and new suits and claims filed in Alberta
England Matters •
Communicated with banks in England to determine amounts on deposit and to obtain information about the accounts; made claims and addressed competing claims being made by Antiguan receivers
•
Coordinated with English counsel in light of expected petition to be made by Antiguan receivers for recognition under English law which could change the nature of those receivers’ claims to asset in England
•
Strategic coordination with English counsel and U.S. authorities to maximize the position of the U.S. receiver in connection with the recovery of assets not yet identified
•
Worked with English counsel on points raised by, and coordination on, U.K. freezes
Litigation - Tax Matters •
Evaluated IRS Motion to Intervene related to $226.6 million of proposed and assessed taxes against Mr. Stanford personally for tax years 1999-2003
•
Negotiated with Department of Justice Tax Division as to manner in which pending Tax Court cases and pending IRS Office of Appeals proceeding against Mr. Stanford personally would be resumed in light of receivership
•
Negotiated with Department of Justice Tax Division as to manner in which the tax audits of Mr. Stanford’s tax years 2004-2007 could be conducted in light of receivership
•
Collected and began evaluating files and records related to proposed and assessed taxes of $226.6 million against Mr. Stanford personally
Insurance Matters •
Performed a comprehensive review of the insurance program that was maintained by the Stanford entities before the receivership, and communicated with brokers and other parties to cancel coverage that is no longer needed in view of the Receiver’s appointment
•
Provided initial and supplemental notices of claims to insurance carriers under policies providing primary and excess directors and officers liability coverage, excess Securities Investor Protection Corporation coverage, Financial Institutions Crime and Professional Indemnity coverage, and Foreign Political Risk coverage
•
Evaluated numerous claims and demands made by various parties relating to the Estate’s insurance policies
•
Discussed ongoing litigation matters and insurance matters with in-house counsel and employees
8
71
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Gold and Bullion •
Provided advice and assistance with gold coin and bullion company operations
•
Developed protocol for movement of gold and bullion inventory from Stanford facilities to JPMorgan Chase safety deposit boxes
•
Assisted in retention of consultant to assist in wind down of operations
Private Equity •
Developed comprehensive listings of private equity holdings, with information regarding ownership, potential current value and loans outstanding
•
Reviewed information and contracts related to private equity investments and evaluated rights and responsibilities with respect thereto
•
Communications with portfolio companies and counsel regarding status of investments and rights to immediate cash withdrawals where available
•
Evaluated various investment holdings for potential sale to third parties; these efforts have included, with respect to several investments, negotiations with potential interested purchasers
•
Interviewed potential advisors regarding possible engagement to market Stanford’s private equity holdings
•
Negotiated with an investment fund and obtained approximately $10.5 million in cash related to investments held in the name of a Stanford entity
•
Negotiated with escrow agent for pending private equity transaction and obtained the return of $9.7 million in cash to the Estate
•
Negotiated with a hedge fund to obtain $4 million on an early redemption of an interest in the fund, without payment of early redemption fee
Aircraft •
Supervised security and developed protocol for dealing with rights and obligations affecting aircraft and aircraft facilities, including maintenance and insurance issues
•
Reviewed information and contracts related to aircraft title and liens and developed plan for negotiation of issues related to the aircraft
•
Communicated extensively with the lender that holds liens on five of the six Stanford aircraft to obtain two independent fair market value appraisals of the five aircraft, in connection with negotiations concerning orderly sale and/or return of the aircraft to the lender and release of a portion of the substantial cash collateral held by the lender to the Receiver
•
Assisted in arrangements, including retaining aircraft broker, to assist in the sale of the Stanford aircraft
Operations •
Provided advice and assistance with daily operations at company headquarters
9
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•
Developed protocol for the receipt and delivery of mail at Stanford’s headquarters in Houston, as well as implemented plan to coordinate the collection of mail at all domestic and St. Croix offices for forwarding to Houston headquarters
•
Reviewed and coordinated payment of expenses and other obligations of the Receiver as well as prereceivership obligations of Stanford
•
Assisted in development of protocol for removal by employees of personal items from various office locations
10
73
Case 3:09-cv-00298-N
Document 385
Filed 05/15/2009
Page 80 of 86
2009 Lawyer Summary TIMEKEEPER
POSITION
HOURS
DISCOUNTED RATE
DISCOUNTED TOTAL
Adams, C N
Partner
498.50
$440.00
$219,340.00
Adams, J P
Associate
340.60
$324.00
$110,354.40
Arlington, D T
Special Counsel
403.50
$380.00
$153,330.00
Austin, S W
Special Counsel
223.00
$400.00
$89,200.00
Ayers, S A D
Associate
475.50
$356.00
$169,278.00
Bauman, S C
Associate
27.40
$260.00
$7,124.00
Beech, S E
Associate
98.20
$240.00
$23,568.00
Bodron, M A
Partner
137.30
$460.00
$63,158.00
Brown, M W
Special Counsel
90.80
$324.00
$29,419.20
Partner
10.30
$420.00
$4,326.00
Carrasco, B J
Associate
29.20
$240.00
$7,008.00
Cassak, L D
Special Counsel
23.80
$440.00
$10,472.00
Casseus, S L
Associate
78.60
$240.00
$18,864.00
Cialone, II, J A
Partner
375.50
$555.00
$208,402.50
Cooper, S W
Partner
179.30
$460.00
$82,478.00
Davis, T M
Partner
414.50
$555.00
$230,047.50
Day, B A
Associate
154.80
$260.00
$40,248.00
Dazey, J E
Associate
109.60
$260.00
$28,496.00
Partner
45.20
$460.00
$20,792.00
Associate
54.90
$260.00
$14,274.00
Partner
23.40
$555.00
$12,987.00
Associate
32.10
$212.00
$6,805.20
Duffy, D P
Partner
58.80
$440.00
$25,872.00
Durst, D J
Associate
23.40
$212.00
$4,960.80
Durst, T S
Partner
278.20
$555.00
$154,401.00
Associate
15.20
$332.00
$5,046.40
Foster, J G
Special Counsel
174.90
$380.00
$66,462.00
Gold, M A
Partner
117.20
$460.00
$53,912.00
Grace, J M
Partner
20.30
$420.00
$8,526.00
Greer, J M
Associate
479.70
$276.00
$132,397.20
Gregory, M M
Special Counsel
61.90
$400.00
$24,760.00
Grounds, B G
Associate
102.80
$240.00
$24,672.00
Hamner III, H T
Associate
151.00
$340.00
$51,340.00
Partner
19.20
$500.00
$9,600.00
Higginbothom, W E
Associate
14.10
$212.00
$2,989.20
Hintze, B A
Associate
95.70
$260.00
$24,882.00
Bull, R E
DeMent, James Dolan, M J P Doty, J R Dougherty, R P
Fitzpatrick, B B
Harper, R B
11
74
Case 3:09-cv-00298-N
TIMEKEEPER
Document 385
POSITION
Filed 05/15/2009
HOURS
DISCOUNTED RATE
Page 81 of 86
DISCOUNTED TOTAL
Hollis, J R
Associate
399.90
$212.00
$84,778.80
Howell, R I
Partner
400.90
$420.00
$168,378.00
Hurd, M C
Associate
116.50
$308.00
$35,882.00
Partner
110.80
$555.00
$61,494.00
Associate
14.70
$212.00
$3,116.40
Jeffress Jr., W H
Partner
14.90
$555.00
$8,269.50
Knight, J R
Partner
39.40
$480.00
$18,912.00
Krishan, D
Associate
73.10
$420.00
$30,702.00
Kujawski, L A
Associate
58.80
$276.00
$16,228.80
Lawrence, J B
Associate
328.10
$260.00
$85,306.00
Le, T T T
Associate
76.10
$212.00
$16,133.20
Leal, S V
Associate
67.60
$240.00
$16,224.00
Leslie, J T
Associate
505.90
$240.00
$121,416.00
Lewis, R C
Associate
43.20
$324.00
$13,996.80
LiCalsi, M B
Associate
88.00
$304.00
$26,752.00
Lin, J A
Associate
52.40
$240.00
$12,576.00
Lobb, J D
Associate
59.80
$240.00
$14,352.00
Lowman, S A
Associate
191.70
$260.00
$49,842.00
Massad, S A
Partner
392.30
$555.00
$217,726.50
McCoy, M D
Associate
66.50
$212.00
$14,098.00
McDowell, C L
Associate
17.10
$324.00
$5,540.40
Miller, C M
Associate
199.80
$212.00
$42,357.60
Mountz, T W
Partner
69.00
$500.00
$34,500.00
Murfee, E A
Associate
26.80
$292.00
$7,825.60
Myers, M G
Associate
461.30
$260.00
$119,938.00
Nelsen, J B
Associate
99.50
$276.00
$27,462.00
Nemetz, L M
Associate
20.00
$380.00
$7,600.00
Pace, J K
Associate
68.60
$276.00
$18,933.60
Poff, J S
Partner
133.00
$500.00
$66,500.00
Preston-Jones, R T
Associate
66.70
$480.00
$32,016.00
Pullin, Z T
Associate
79.30
$212.00
$16,811.60
Raborn, J R
Partner
176.80
$555.00
$98,124.00
Rains, D J
Associate
62.80
$212.00
$13,313.60
Raley, J E
Special Counsel
14.50
$380.00
$5,510.00
Ramos, J M
Associate
57.10
$308.00
$17,586.80
Rancher, C W
Associate
401.80
$212.00
$85,181.60
Roberts, I E
Associate
40.60
$260.00
$10,556.00
Partner
236.10
$400.00
$94,440.00
Husseini, R A Ingram, P R
Robertson, R L
12
75
Case 3:09-cv-00298-N
TIMEKEEPER Ross, J L
Document 385
POSITION
Filed 05/15/2009
HOURS
DISCOUNTED RATE
Page 82 of 86
DISCOUNTED TOTAL
Partner
12.70
$480.00
$6,096.00
Associate
94.80
$324.00
$30,715.20
Sadler, K M
Partner
504.80
$555.00
$280,164.00
Sawers, J K
Partner
14.70
$440.00
$6,468.00
Schlanger, K E
Associate
327.30
$308.00
$100,808.40
Scioneaux, M C
Associate
125.50
$240.00
$30,120.00
Scott, M L
Special Counsel
241.40
$380.00
$91,732.00
Shah, R K
Associate
39.20
$212.00
$8,310.40
Slania, A K
Associate
73.70
$260.00
$19,162.00
Soderlund, E A
Associate
353.10
$324.00
$114,404.40
Souder, H M
Associate
24.10
$256.00
$6,169.60
Stewart, J C
Associate
93.60
$240.00
$22,464.00
Stockbridge, A M
Associate
22.80
$240.00
$5,472.00
Stutts, Jr., W F
Partner
423.70
$555.00
$235,153.50
Sulentic, A M
Associate
207.70
$356.00
$73,941.20
Taylor, D W
Partner
13.50
$480.00
$6,480.00
Timmons-Pierce, A M
Associate
16.10
$332.00
$5,345.20
Totaro, M V
Associate
17.40
$280.00
$4,872.00
Tucker, H C
Associate
399.00
$212.00
$84,588.00
Walters, T J
Associate
85.00
$212.00
$18,020.00
Wang, L P
Associate
255.20
$276.00
$70,435.20
Watts, W C
Associate
169.80
$212.00
$35,997.60
Wood, M C
Associate
45.10
$212.00
$9,561.20
Wood, R H
Associate
27.50
$212.00
$5,830.00
Wright, R P
Partner
215.90
$460.00
$99,314.00
York, A F
Associate
111.00
$212.00
$23,532.00
Zabaneh, J P
Associate
175.00
$240.00
$42,000.00
Rubenstein, J B
14,859.40
13
$5,297,329.10
76
Case 3:09-cv-00298-N
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Filed 05/15/2009
Page 83 of 86
2009 Non-Lawyer Summary TIMEKEEPER
POSITION
HOURS
DISCOUNTED RATE
DISCOUNTED TOTAL
Burnett, M E
Research Librarian
16.90
$100.00
$1,690.00
Caine, R M
Paralegal
75.30
$148.00
$11,144.40
Chappel, H M
Paralegal Clerk
44.80
$100.00
$4,480.00
Cominsky, C W
Senior Paralegal
309.80
$160.00
$49,568.00
Dodge, L E
Senior Paralegal
45.50
$160.00
$7,280.00
Fitzwater, J S
Paralegal Clerk
193.50
$92.00
$17,802.00
Fluker, L C
Paralegal
65.40
$160.00
$10,464.00
Garcia, V O
Paralegal
16.40
$120.00
$1,968.00
Gaskamp, K L
Paralegal
16.20
$132.00
$2,138.40
George, D L
Senior Paralegal
143.50
$160.00
$22,960.00
Gonzalez Jr., H
Document Review Attorney
76.00
$140.00
$10,640.00
Hinton, K W
Paralegal
247.60
$128.00
$31,692.80
Huddleston, J C
Paralegal
340.00
$148.00
$50,320.00
Jampala, S
Paralegal Clerk
179.50
$100.00
$17,950.00
Kusey, M D
Senior Paralegal
158.40
$160.00
$25,344.00
Moratto Jr., T M
Paralegal Clerk
13.70
$100.00
$1,370.00
O'Quinn, J G
Benefits Professional
27.00
$220.00
$5,940.00
Owens, S M
Paralegal Clerk
174.70
$100.00
$17,470.00
Prudhomme, R J
Paralegal Clerk
37.20
$92.00
$3,422.40
Rohleder, D S
Paralegal Clerk
18.30
$92.00
$1,683.60
Saucier, D L
Senior Paralegal
17.00
$148.00
$2,516.00
Scanlan, K
Paralegal
358.40
$140.00
$50,176.00
Starbuck, N M
Paralegal Clerk
311.70
$100.00
$31,170.00
Thomas, J E
Developer
110.30
$136.00
$15,000.80
Walker, V R
Records Management Staff
16.20
$60.00
$972.00
Whiting, L G
Paralegal Clerk
106.20
$100.00
$10,620.00
3,119.50
14
$405,782.40
77
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Page 84 of 86
SUMMARY Fees at 20% Discount
$5,703,111.50
Expenses
$180,605.27 ________________
Total Amount Due:
$5,883,716.77
15
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Page 85 of 86
Detail for expenses incurred: CAPITOL SERVICES, INC. Stanford Financial Group Company
1,686.64
Locksmith for closing office
188.48
Service of subpoena
100.00
Computer and other research services
93,926.89
Conference room facilities and services
356.99
Delivery and postage service
6,122.14
Photocopying service
19,838.14
Facsimile
4,112.60
Litigation Support Services
436.72
Stationery and supplies
904.72
Telephone calls
1,891.54
Travel expense
50,923.77
Website Hosting fee
116.64
Total Expenses:
$180,605.27
16
79
Case 3:09-cv-00298-N
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Page 86 of 86
Attorneys At Law P. O. BOX 201626 HOUSTON, TEXAS 77216-1626 TAXPAYER I.D. #74-1195457
REMITTANCE STATEMENT
Matter #
079716.0101
Matter Name
Stanford Financial Receivership
Client Name
JANVEY, RALPH S., RECEIVER
Invoice #
1108206
Billing Attorney
J A Cialone, II
Office
Houston
TOTAL FEES AT 20% DISCOUNT
$5,703,111.50
TOTAL EXPENSES:
$180,605.27
TOTAL INVOICE:
$5,883,716.77
WIRING INSTRUCTIONS
TO ENSURE PROPER APPLICATION OF YOUR PAYMENT, PLEASE RETURN THIS REMITTANCE ADVICE.
17
80
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