What this page does and does not contain
This page is about a working law firm and the lawyer who ran it. Hodge & Francois was a two-partner practice at 1340 Taarneberg in St. Thomas. Its principal, Maria Tankenson Hodge, was Jeffrey Epstein’s Virgin Islands lawyer. Neither she nor anyone else named here is a complainant, a survivor or an accused person, and nothing on this page suggests otherwise.
This is not a mention population, and this page says what it is. The firm’s name and its principal’s name reach 419 documents of this release. At least 47 of those were written by the firm itself, over a lawyer’s or a member of staff’s signature, and the act was established in every case by reading the signature rather than by trusting a database field. That is a floor, not a ceiling, and the method is set out at the foot of this page.12
The firm’s work for Epstein is documented in its own itemised bills, and one of those bills ties exactly to a bank wire. The invoice total outstanding at the end of August 2012 was $16,012.03, and on 1 October 2012 Darren Indyke signed an instruction to wire $16,012.03 to the firm’s trustee account. Both sheets were read at the page image.34
Eleven wire instructions to that trustee account are located, totalling $100,100.93. No account number, routing number, taxpayer identification number or any other identifier of that class is reproduced, described or located anywhere on this page, and this page makes no statement of any kind about how any producing party has treated anything on any sheet.5
Nothing any complainant or survivor said appears here in any form. Six documents in this population are refused outright: nothing from any of them is quoted, summarised, characterised or counted, and their identifiers are not listed.6
No telephone number, fax number or electronic address is reproduced here, the firm’s own included.
| Named on the documents as | HODGE & FRANCOIS and LAW OFFICES OF HODGE & FRANCOIS on its letterhead; HODGE AND FRANCOIS in its own court signature block; Law Offices of Hodge & Francois on its invoices; and, from 2015, HODGE & HODGE at the same street over the same principal’s signature78910 |
| Business address as printed | 1340 TAARNEBERG / ST. THOMAS, VI 00802. Read at the page image, where the letterhead sets it under the firm name7 |
| The lawyers its own letterhead names | MARIA TANKENSON HODGE, P.C. and DENISE FRANCOIS, P.C. in the left column; MARK HODGE and GAYLIN VOGEL in the right. Read at the page image, which corrects the released text’s GATLIN VOGEL7 |
| What the principal was to Epstein | A single-sheet contact list in his files gives one line: Virgin Islands Legal Counsel and local contact: Maria Hodge, against NY Legal counsel: Darren Indyke11 |
| Earliest contact located | A FedEx International Priority envelope from Darren Indyke at Epstein’s New York office, delivered to MARIA HODGE / HODGE FRANCOIS on 18 August 200212 |
| The hardest financial fact | A 2006 Form 1099-MISC from Epstein’s Financial Trust Company, Inc. to HODGE & FRANCOIS, box 7 nonemployee compensation, $796.64, printed on the same sheet directly above a 1099 from the same company to Marjorie Rawls Roberts for $22,373.16. Read at the page image13 |
| What it did, in its own billing words | CZM NOVA and Settlement, Mooring Permit, Communications with Army Corps; VI SORA Issues - Mtg. and Letters with AG; Fancelli – Motions re Mediation, Mediation brief, Mediation, Discovery, Post mediation conference. Read at the page image3 |
| Its billing rate, where the sheet gives one | 325.00/hr9 |
| The office it held for Epstein’s companies | Resident agent for service of process in the U.S. Virgin Islands, from a Jeepers, Inc. board resolution of June 2005 until June 20131415 |
| The legislative work | In June 2012 Maria Tankenson Hodge drafted and circulated amendments to Bill No. 29-0239, the territory’s sex-offender registration bill, to a Legislature lawyer, to a senator and to the Attorney General’s counsel, with Epstein’s address in the copy line16 |
| Response | None located. No statement by the firm, by Maria Tankenson Hodge or by anyone on their behalf about any document on this page has been found, and no request for one was made from here17 |
| Not established here | That the firm knew of any conduct by its client beyond what the documents it wrote describe; that any payment located here was for any particular matter except where a sheet says so; that the firm drafted the legislation for Epstein rather than for registrants generally; or that any sequence on this page is a causal one18 |
Hodge & Francois was a small law firm on a St. Thomas hillside street, and for at least eleven years it was the Virgin Islands end of Jeffrey Epstein’s affairs. Its principal, Maria Tankenson Hodge, was the registered agent for his territorial companies, the attorney-in-fact who signed his coastal-zone permits, the lawyer who asked the Virgin Islands to take over his Florida probation, the lawyer who told him whether he could vote, the lawyer who went with him to the Department of Justice to renew his sex-offender registration, and the lawyer who wrote the amendments to the territory’s sex-offender travel law and then negotiated his exemption under the law that passed.14192091621
That is not an inference from a mention count. It is what the firm’s own letters, memoranda, invoices and court filings say, and this page is built on those.
The two names on the door
The letterhead is the first evidence, and it was read at the page image because the released text
of it is damaged. Under the words LAW OFFICES OF it reads HODGE & FRANCOIS, then the street
and the town. Down the left margin stand MARIA TANKENSON HODGE, P.C. and DENISE FRANCOIS, P.C.;
down the right, MARK HODGE and GAYLIN VOGEL. The released text renders the fourth name
GATLIN VOGEL and the street 1340 TAARNEDERG; the paper reads GAYLIN VOGEL and 1340 TAARNEBERG, and the paper governs.7
The record shows two of the three besides the principal doing work. A Superior Court order of July 2013 says so in
a footnote of its own: Denise Francois, Esq., is a partner in Hodge & Francois.22 Gaylin
Vogel signed a legal opinion for the firm in October 2011.23 No document read for this
page says who Mark Hodge is or what he did, and this page does not supply an answer.18
The firm signs its court work as the firm. The 2010 complaint that opened Epstein’s
construction case against a millwork supplier closes with HODGE AND FRANCOIS, and lower on the
same block with By: Denise Francois and a Virgin Islands bar number.8 Its invoices are headed Law Offices of Hodge & Francois and initialled by the lawyer who did the work, MTH for Maria Tankenson Hodge
and DMF for Denise M. Francois, at 325.00/hr.9
One of those billing lines is worth reading beside the agency refusal set out below. On
16 March 2011 Denise Francois billed a quarter of an hour for a
Teleconference with D Indyke re George Levin; research VI EDC beneficiaries re same; draft email to D Indyke re same. Read at the page image. Four months later a reporter asked the territorial
development authority to list the Economic Development Commission beneficiary companies this firm
represented, and the agency’s drafted answer was that doing so would be too much work. No
document read for this page names a single such client, and this page names none.924
2002 to 2007: the registered agent
The earliest trace of the relationship located here is a courier record, four years older than
the oldest payment. On
18 August 2002 a FedEx International Priority envelope sent by Darren Indyke from Epstein’s New
York office was delivered to MARIA HODGE / HODGE FRANCOIS in St. Thomas. A second envelope,
this one sent in Epstein’s own name from the same address, was delivered on 27 January
2005.12
On 23 June 2005 the board of Jeepers, Inc. resolved to appoint her. The certificate is signed by Jeffrey Epstein as President and attested by Cecile de Jongh as Secretary, and the resolution reads:
RESOLVED, that Maria Tankenson Hodge, 1340 Taarneberg, St. Thomas, Virgin Islands,
and, lower in the same resolution, that she
is duly appointed to serve as resident agent for service of legal process in the U.S. Virgin Islands with full authority to accept the service of legal process on behalf of the Corporation.14
Three printings of that certificate are in this release and they do not agree on the year. Two give the board’s consent as 23 June 2005 and one renders it 23 June 2003; the companion unanimous written consent of the same board gives June 2005. This page follows the two printings and the companion instrument, records the conflict, and does not harmonise it.14
The appointment was not a one-company arrangement. The IGO Company, LLC operating agreement of
January 2007 provides that the agent for service of process shall be Maria Tankenson Hodge, who is a resident of the United States Vi rgin Islands, and a 2011 annual report filed with the
Lieutenant Governor gives her name and her street in the two fields for the agent.2526
2009: bringing the probation home
The earliest of the firm’s own letters for Epstein in this release concerns an attempt to move his criminal supervision from Florida to the Virgin Islands. It is not the earliest work: the registered agency had by then run for four years.14
On 4 May 2009 Maria Tankenson Hodge wrote on the firm’s letterhead to Jack Goldberger, the West Palm Beach lawyer who had handled Epstein’s plea, and in identical terms the same day to Darren Indyke in New York. Read at the released text, the letter is a status report on a conversation with a territorial official:
I spoke today to Mrs. Arlene Swan, the Interstate Compact Administrator for the Virgin Islands, following delivery to her of my letter detailing the terms of the one year of enhanced probation, i.e., “community control”, to which Mr. Epstein will be subject under the terms of his sentence.19
She reported that the Administrator was supportive of requests for Virgin Islands residents to return home under the Compact, that the formalities had to begin from Florida, and that
It was my clear understanding that she is prepared to consent to this request, provided the proper formalities are followed.19
Two drafts of the underlying letter to the Administrator are also in the release, both signed Maria Tankenson Hodge. They set out the case for the transfer:
My client, Jeffrey Epstein, is and has been a full-time resident of the Virgin Islands for over 10 years.
and, in the same letter:
On June 30, 2008, Mr. Epstein agreed to plead guilty in a Florida state court to two non-violent felony counts relating to prostitution.
and:
As you will note, Mr. Epstein is required, at least under Florida law, to register as a sex offender. His state charge was a non-violent sex offense, i.e. procuring a minor for prostitution.27
The words “non-violent” are the firm’s, twice, and they are advocacy rather than record. The
same letter recites that Epstein’s supervision was to begin on July 22, 2009 and asks for
a confirmatory letter at your earliest convenience. One of the two drafts carries an unresolved
query to the client’s New York lawyer inside the text itself, asking whether a figure about
Virgin Islands employees is correct, which is how this page knows it is a draft.27
No document read for this page records whether the transfer was granted, and none is asserted here.18
The permit practice, and a regulator’s complaint
Much of the firm’s work in this release went on construction permits for
Little St. James, though not most of its money. Both billing
records this page quotes put litigation ahead of permits: across July and August 2012 the
Fancelli items total $9,131.92 against $2,281.11 for the coastal-zone work, and in the two months
of invoices Cecile de Jongh tabulated in February 2011 the Fancelli and Molyneux columns together
come to $14,356.60 against $9,168.43 for general Little St. James work. Those sums are this
page’s arithmetic over the two sheets.328 In August and September 2009 Maria Tankenson
Hodge wrote to J.P. Oriol of the territorial Coastal Zone Management division and twice to the
Antilles Regulatory Section of the U.S. Army Corps of Engineers, enclosing the Corps letter
directing our client, LSJ, LLC, to undertake certain remediation actions to resolve a pending enfor cement matter.29
On 21 October 2009 Darren Indyke wrote a memorandum to Epstein recording what she had told him by telephone, and it is the clearest surviving account of how she worked:
Maria said that she also told Cedeno and Oriol that the Client wanted to be respectful and compliant and also did not want to do things that ACOE or CZM thought unnecessary or improper.30
By March 2011 the regulator had a complaint of his own, and he addressed it to her. A fax of
17 March 2011 from Jean-Pierre L. Oriol of the Department of Planning
and Natural Resources is headed to Ms. Maria Tankenson Hodge, Attorney and Designated Agent,
LSJ, LLC, 1340 Taarneberg, and opens:
I am very concerned that major development is occurring on Little St. James Island through the processing of a series of minor CZM permit applications by LSJ, LLC.31
That sentence is a government officer telling Epstein’s lawyer that her client’s permit strategy
was defeating the permit system. She continued to act. In May 2011 she wrote to Commissioner
Designee Alicia V. Barnes asking for a modification, and a Coastal Zone Management permit in
this release carries her signature over the line Attorney-in-fact for LSJ, LLC.3233
A DPNR notice of violation concerning Nautilus, Inc. in February 2012 was served, the settlement
agreement records, on Maria T. Hodge, attorney-in-fact for Nautilus, Inc.34
The advice: voting, firearms, and a schedule of lawsuits
Three documents record the firm answering questions put to it by the client’s New York lawyer, and the first two of them arise from the conviction.
On 25 October 2010, eight days before a territorial election, Darren Indyke wrote to Epstein
under the subject Voting in November 2, 2010 Election:
After speaking with Attorney Maria Hodge, it is my understanding that Section 263(a) is inapplicable because it was intended to apply to repeat offenders and not simply to an offender who happened to be convicted of two distinct felonies at the same time.
and, further down:
After speaking with Attorney Hodge, it is my understanding that it is her view that the “date of his discharge” refers to the date that you are discharged from the entirety of your sentence, including the community control portion of your sentence, ended on July 21, 2010.20
The conclusion Indyke drew from her advice was that Epstein was debarred from voting until one year after the conclusion of your community control or July 20, 2011, and therefore need not be present on St. Thomas for, the upcoming election.20
On 25 October 2011 the firm answered a second question of the same family. Gaylin Vogel wrote to
Indyke on the firm’s letterhead under the subject Firearm ownership by L.S.J., LLC employee residing on Little St. James Island, concluding that such an employee can possess a firearm and not be in violation of 18 U.S.C. § 922(h) as long as the firearm is for the employee's personal use only.23
The same day, Denise Francois sent Indyke a third. Her memorandum answers a
Request for information with respect to all Civil Lawsuits of which JE, FTC or LSJ or Lafayette were named as defendants in the past 10 years and tabulates five, with courts, docket numbers and
dispositions. Read at the page image. No document read for this page says who wanted that
schedule or what it was for, and this page does not supply an answer.3518
2012: the registration law, written and then worked
This is the sequence the timeline makes visible, and it is the heart of this page.
In June 2012 the Legislature of the Virgin Islands was considering Bill No. 29-0239, which became
Act No. 7372 and which changed the territory’s sex-offender registration and notification law.
The Attorney General’s own letter calls Epstein a registrant on the Virgin Islands Sex Offender Registry, and the firm’s letter of 26 July dates his registration to March 2010.2136
On 19 June 2012 Maria Tankenson Hodge wrote to a lawyer at the Legislature. Her message, which Darren Indyke forwarded to Epstein the same afternoon, reads in part:
Dear Attorney Ayala: Thank you so much for your call about this l islation. As promised, I attach a copy of my notes on the amendments to the ball understand Senator
The damaged characters are on the face of the sheet and are not mended. She went on:
I would greatly appreciate a copy of the draft amendment when it is ready, so that I can be sure I know what I’m talking about when I speak to the Senator about this and the specific amendments.16
On 22 June she wrote to the Attorney General’s office, having already sent a compromise draft to the senator who had offered the original legislation:
For many reasons. I believe the current version of the amendment as offered (which I had originally requested —and the AG had originally approved) is both more practical and fairer than the revised version the news reports indicate the AG proposed at the hearing.37
Her argument was pitched at registrants generally, not at her client. She wrote that the
Department’s proposal would be just impractical to give prior notice for short trips. such as short trips (shopping. family visits, etc.) to Puerto Rico or the BVI, that people working on ferry boats. airlines. cargo vessels. etc. would have to give written notice every day in order to keep their jobs, and that There also should be an exemption for emergencies. The amendment she had
drafted required 24 hours notice where the Department wanted 72.37
On 25 June, with the Attorney General’s counterproposal in hand, she wrote to Senator Ronald Russell at the Legislature, marked High importance, with Epstein’s address in the copy line:
Senator: 1 have spoken today to the AG’s assistant, attorney Carbon, and also to Asst. AG and they shared with at their counter-proposal language, which !still believe has a number of problems.
and closed:
T hope you will offer this language rather than the draft the DOJ prepared. I will plan to be there if you have any questions. Maria Hodge38
The Act passed. The firm then worked the Act. On 16 July 2012 it wrote to Attorney General Vincent F. Frazer seeking clarification of the new travel-notice provisions on Epstein’s behalf. On 25 July Frazer answered, and granted a waiver:
Your letter is accepted as a request pursuant to the new provisions of Act No. 7372, for the Attorney General to waive the 21 day prior notice requirement to the Department of Justice for Mr. Epstein, when travelling out of the Virgin Islands.
He granted it on six conditions, among them 72 hours’ notice, notice given by Epstein personally,
and disclosure of identifying information of the temporary lodging location, including addresses.21
The firm objected within a day. Its letter of 26 July survives in a draft headed
[TO BE PRINTED ON HODGE & FRANCOIS LETTERHEAD), and the quotations that follow are from that
draft. It argues that the conditions would have an
unduly restrictive effect on Mr. Epstein’s right to travel and conduct his legitimate business and professional activities
and that this was contrary to what the Attorney General and the senator had said at the committee hearing:
As clearly stated by both Senator Russell and Your Honor during the consideration of Act 7372, and particularly the travel notification provisions thereof, at the Rules and Judiciary Committee hearing on June 21, 2012, the travel notification requirements of this Act were specifically not intended to be penal in nature.36
A second letter went on the letterhead itself on 30 July. It makes the same argument in its own
words, saying that both the Attorney General and the senator acknowledged that this was meant to be a notice provision, nothing more, and that the conditions would impede the client’s activities
in a manner that would indeed, be penal in nature, the comma being the sheet’s.36
The draft also made a claim about the client’s record that the sent letter does not carry:
From the beginning of Mr. Epstein’s registration in March 2010, Mr. Epstein has a demonstrated history of frequent travel and a flawless record of fully compliant travel notification to your office.36
The Attorney General moved. On 14 August 2012 Frazer wrote again, and the firm’s reply of August
2012 opens Thank you for your letter of August 14 confirming your decision. What the released
copies of the 14 August letter say is that the earlier conditions were modified and that
All other conditions stated in my letter of July 25, 2012 are in full force and affect, the
spelling being the sheet’s.39
This page states the sequence and does not state a cause. The lawyer who drafted the amendments to the bill, and who asked the senator to carry her language rather than the Department’s, was the lawyer who then asked the Attorney General to waive the resulting notice requirement for her client, and who objected when the conditions attached to the waiver were tighter than she wanted. Whether the drafting and the waiver were connected in anyone’s mind is not recorded in anything located here.18
The money: an itemised bill, and the wire that matches it
One undated sheet in this release is the firm’s bill, broken out by matter. It was read at the page
image, and the paper corrected the released text. It is headed OUTSTANDING HODGE AND FRANCOIS BILLS and runs:
JULY CHARGES – INVOICE DATE JULY 31, 2012
CZM NOVA and Settlement, Mooring Permit, Communications with Army Corps $1,512.61
VI SORA Issues - Mtg. and Letters with AG $3,688.32
Fancelli – Motions re Mediation, Mediation brief, Mediation, Discovery, Post mediation conference $7,813.82
July Total Billed at end of July $13,014.753
VI SORA is the Virgin Islands Sex Offender Registry Act, and $3,688.32 is what meeting and
corresponding with the Attorney General about it cost in one month. The August block bills a
further $ 910.68 for VI SORA Issues – emails to AG, Confirmatory Letter in Response to final AG letter, and the sheet closes TOTAL OUTSTANDING $16,012.03.3
The three July items sum to $13,014.75 and the three August items to $2,997.28, and the two
monthly totals sum to $16,012.03. Every figure on the sheet is internally consistent. It was the
arithmetic that exposed the text layer: the released text gives the July litigation line as
$7.811.87, which does not sum, and the paper reads $7,813.82, which does.3
On 1 October 2012 Darren Indyke signed a memorandum to Epstein’s bank. It was read at the page image, and it carries his wet signature:
Please wire Sixteen Thousand Twelve Dollars and 03/100 ($16,012.03) from the above account to:
The beneficiary is given as Hodge & Francois Trustee Account, for further credit to
FirstBank, Virgin Islands through FirstBank, Puerto Rico, whose address the sheet prints over
two lines as 1519 Ponce de Leon Avenue and Santurce PR 00908, and the reference reads Invoice 38291, 38292, 39293, 38419, 38420 & 38421.
The third of those six numbers breaks the sequence on the paper itself and is not mended
here.4
That is a documented join between a bill and a payment. What each invoice was for beyond the three headings the bill gives is not recorded in anything located.18
Eleven such instructions are located, between 26 January 2012 and 21 June 2013, and together they
total $100,100.93. Seven are memoranda on Epstein’s own letterhead signed by Harry Beller or
by Darren Indyke; four are J.P. Morgan funds-transfer request forms.
Most were transmitted to the bank by Richard Kahn of
HBRK Associates Inc., and one by
Bella Klein under the subject JEE WT Hodge & Francois.5
Four of the eleven were read at the page image, and on three of those the paper corrected the
released text. The sheet the text layer gives as 5112.50 reads $412.50; the sheet it gives as
52,979.81 reads $2,979.61; and a principal the text layer renders k172,62 reads
$172.62.5
The payments did not begin in 2012. On 18 February 2011 Cecile de Jongh wrote to Epstein under
the subject Check we are holding for Maria Hodge, enclosing a table of invoices for December 2010
and January 2011 broken out across four matters, FT Real estate, LSJ General, Fancelli and
Molyneux, with a total of $24,930.03. The table’s rows and its columns both sum to that
figure. Six days later she confirmed I am releasing the below listed checks to Hodge-Francois.28
And the oldest payment located is a small one. The 2006 Form 1099-MISC from Financial Trust
Company, Inc. to HODGE & FRANCOIS reports $796.64 in box 7, nonemployee compensation. Two
later payments on this page are smaller: a wire of $172.62 in May 2013 and a cheque for $162.50 in
May 2015. Read at
the page image, which also settles that the box is 7 and not box 1. Printed on the same sheet,
directly below it, is a second 2006 Form 1099-MISC from the same company to MARJORIE RAWLS ROBERTS
for $22,373.16.13
Those are the two firms the reporter Wayne Barrett asked the territorial development authority
about five years later, and the agency’s drafted answer about this one was See above, pointing
back to the answer it had given about the other: Overly burdensome and possibly will not be accurate as beneficiaries may have changed lawyers since our last record. That refusal is set out
in full at Marjorie Rawls Roberts and is not repeated
here.24
June to August 2013: the agency moves, and a judge steps aside
In June 2013 Epstein’s companies took the registered agency away from Maria Tankenson Hodge.
Certificates of change of principal office and resident agent were executed that month for Island Grounds, Inc., Jeepers, Inc. and FT Real Estate, Inc. Each recites that
the name and address of the Corporation’s current agent for service of process is Maria Tankenson Hodge, 1340 Taameberg, St. Thomas, U.S. Virgin Islands 00802
the spelling of the street being the released text’s, and each resolves to appoint Business Basics VI, LLC at 9100 Port of Sale Mall in its place. The Island Grounds certificate is executed by Darren K. Indyke as President and Richard Kahn as Secretary; the signature blocks of the other two were not read for this page and no signatory is asserted for them.15
It was a coordinated move across the group, not three isolated filings. On 20 June 2013 Indyke sent Lesley Groff four further documents to print, and the attachment names are the record: change-of-agent papers for FSF, LLC, IGO Company, LLC and Thomas World Air, LLC, and a board consent for the JEVI Foundation, Inc.15
Six weeks later, a Superior Court judge recused himself from Epstein’s case. The order of 2 August 2013 reads:
THIS MATTER is before the Court sua sponte.’ Due to the recent = ouncement that Attorney Denise Francois will be succeeding the undersigned as an A .. :te Judge of the Superior Court of the Virgin Islands, the undersigned believes that his continued handling of a matter in which Attorney Francois is counsel of record creates a conflict of interest.
The damaged characters are on the face of the sheet. The judge cancelled the post-mediation status
conference and returned the file to the Clerk for reassignment, and a footnote to his own order
records that Denise Francois, Esq. represents Plaintiffs Jeffrey Epstein and L.S.J., LLC.40
He raised the same conflict twice that month, and the second time the firm’s appearance was the
other partner’s. An order of July 2013 in an unrelated insurance suit records that, because of the
same announcement, the Court wishes to give the parties an opportunity to voice any conflict of interest concerns regarding the undersigned's continued handling of this case. In that case the
firm appeared by Maria Hodge, and that order is also where this page takes the full title
Associate Judge of the Superior Court of the Virgin Islands, which the Epstein order’s own sheet
renders in a damaged form.2240
Both things happened in the same summer. No document read for this page connects them, and this page does not connect them. What the record holds is a sequence: the agency for at least seven Epstein entities moved off the firm’s principal in June 2013; the last located payment to the firm’s trustee account was made on 21 June 2013; and in August 2013 the firm’s other name partner was announced as a judge of the court in which she was then acting for Epstein.15540
Hodge & Hodge
A second firm name in this release is the same practice, and this page says so with the evidence rather than assuming it.
On 20 November 2015 a letter went to Christopher Kroblin of
Kellerhals Ferguson Kroblin PLLC, the other St. Thomas firm
in these files, about a suit over the sale of Great St. James. It is signed Maria Tankenson
Hodge. Read at the page image, its heading is HODGE & HODGE, and its footer reads
ATTORNEYS AT LAW / 1340 TAARNEBERG, ST. THOMAS, VIRGIN ISLANDS. The street is the same and the
telephone number printed on it is digit-for-digit the one printed on the Hodge & Francois
letterhead, which this page has read at the image and does not reproduce.107
Two further documents settle it independently. A cheque dated 5/19/2015 carries
PAY TO THE ORDER OF above Law Offices of Hodge & Hodge, the sum written out as
One Hundred Sixty-Two and 50/100, and prints the payee’s address over three lines as Law Offices of Hodge & Hodge, 1340 Estate Taarneberg, St. Thomas, VI 00802. It was read at the page image, and it is drawn by
Southern Financial LLC at 6100 RED HOOK QUARTER, B3, the same St. Thomas address as Epstein’s
other territorial companies, on a New York bank. And a litigation search-term list prepared in the
Epstein matters groups the two names in a single block, alongside both partners’ names and the
firm’s mail domain.10
What the record supports is that by November 2015 the practice at 1340 Taarneberg was writing as Hodge & Hodge over Maria Tankenson Hodge’s signature, and was still being paid by Epstein interests. Whether that was a renaming, a reconstitution or a separate legal person is not stated by any document read for this page, and none is asserted. The firm’s letterhead names a Mark Hodge among its lawyers; no document read here says that he is the second Hodge, and this page does not say it.10718
What this page does not establish
- That the firm knew anything about its client’s conduct beyond what its own documents describe. No document read for this page records the firm being told of, asked about, or responding to any allegation against Epstein.18
- That any payment located here was for any particular matter, except where the sheet itself allocates it. Three of the eleven wires carry invoice references and no description at all.5
- That the firm drafted the registration amendments for Epstein rather than for registrants generally. Her own letters argue the general case, and name ferry crews, airline staff and people facing medical emergencies. What the record shows is that Epstein’s address was in the copy line and that his New York lawyer forwarded the drafts to him.163718
- That the Interstate Compact transfer was granted. The record holds the request and stops.18
- That any sequence on this page is a causal one. The June 2013 change of agent, the last payment and the August 2013 recusal are set out in order and are not joined.18
- That the firm’s engagement had any particular terms. No retainer, engagement letter or fee agreement between the firm and Epstein or any Epstein entity has been located.18
- It makes no allegation and records none.
Timeline
| Date | Event | Source |
|---|---|---|
| 18 Aug 2002 | FedEx envelope from Darren Indyke at Epstein’s New York office delivered to MARIA HODGE / HODGE FRANCOIS, St. Thomas | EFTA0021774412 |
| 27 Jan 2005 | Second FedEx envelope, sent in Epstein’s name, delivered to the same recipient | EFTA0022031612 |
| 23 Jun 2005 | Jeepers, Inc. board appoints Maria Tankenson Hodge resident agent for service of process | EFTA0134436514 |
| tax year 2006 | Financial Trust Company, Inc. Form 1099-MISC to HODGE & FRANCOIS, box 7, $796.64; a 1099 to Marjorie Rawls Roberts for $22,373.16 is printed on the same sheet | EFTA0133817513 |
| 2 Jan 2007 | IGO Company, LLC operating agreement names her agent for service of process | EFTA0031293025 |
| 4 May 2009 | Firm letter to Jack Goldberger and to Darren Indyke on transferring Epstein’s Florida supervision to the Virgin Islands | EFTA0060282619 |
| 2009 (undated draft) | Letter to the Interstate Compact Administrator, signed Maria Tankenson Hodge: His state charge was a non-violent sex offense | EFTA0072798627 |
| 18–19 Aug 2009 | Firm letters to J.P. Oriol enclosing the Army Corps remediation directive to LSJ | EFTA0072578129 |
| 21 Oct 2009 | Indyke memorandum recording her account of calls with the Army Corps and CZM | EFTA0072800430 |
| 30 Jul 2010 | Complaint filed for Epstein and L.S.J., LLC, signed for HODGE AND FRANCOIS by Denise Francois | EFTA007312098 |
| 25 Oct 2010 | Indyke memorandum: her advice that Epstein was debarred from voting until 20 July 2011 | EFTA0072545920 |
| 20 Dec 2010 | Firm letter to the DPNR Commissioner on three minor CZM permits | EFTA0059554341 |
| 18 Feb 2011 | Check we are holding for Maria Hodge: invoices for two months across four matters, total $24,930.03 | EFTA0090475828 |
| 17 Mar 2011 | Jean-Pierre Oriol to her: I am very concerned that major development is occurring on Little St. James Island through the processing of a series of minor CZM permit applications by LSJ, LLC. | EFTA0111444031 |
| 28 Mar 2011 | The firm’s time ledger: meet with client at DOJ to complete renewal of registration | EFTA011034319 |
| 1 Apr 2011 | Three firm invoices for the quarter, at 325.00/hr | EFTA011034399 |
| 2 May 2011 | Firm letter to Commissioner Designee Alicia V. Barnes seeking a permit modification | EFTA0058705532 |
| 25 Oct 2011 | Two firm memoranda to Indyke: a schedule of ten years of civil suits, and an opinion on firearms on Little St. James | EFTA003070813523 |
| 26 Jan 2012 | First located wire to the Hodge & Francois Trustee Account: $9,387.67 | EFTA015808295 |
| 3 Apr 2012 | She visits Little St. James to inspect for CZM purposes; Epstein: yes perfect | EFTA0041668842 |
| 19 Jun 2012 | She sends her amendments to Bill 29-0239 to a Legislature lawyer; Indyke forwards to Epstein | EFTA0281574516 |
| 22 Jun 2012 | She writes to the Attorney General’s office defending the current version of the amendment as offered | EFTA0281575637 |
| 25 Jun 2012 | She sends Senator Ronald Russell a compromise draft, Epstein’s address in the copy line | EFTA0281557238 |
| 13 Jul 2012 | Fancelli mediation held at the firm’s offices, 1340 Taarneberg | EFTA0216438443 |
| 25 Jul 2012 | Attorney General Frazer grants the Act 7372 travel-notice waiver on six conditions | EFTA0118516321 |
| 26 and 30 Jul 2012 | The firm objects that the conditions are penal in nature | EFTA0110012636 |
| 31 Jul 2012 | Invoice: VI SORA Issues - Mtg. and Letters with AG $3,688.32 | EFTA011221953 |
| 14 Aug 2012 | Frazer modifies the waiver conditions | EFTA0061078339 |
| 16 Aug 2012 | Indyke asks that clean PDF copies of Epstein’s two passports be sent to Maria Hodge | EFTA0040659744 |
| 1 Oct 2012 | Indyke signs a wire instruction for $16,012.03, the exact total outstanding on the two invoices | EFTA015805404 |
| 8 Jan 2013 | Firm letter to Indyke enclosing an executed subpoena in the Fancelli case | EFTA0031289545 |
| Jun 2013 | Certificates remove her as resident agent for at least seven Epstein entities, appointing Business Basics VI, LLC | EFTA0029614615 |
| 21 Jun 2013 | Last located payment to the trustee account: $412.50, invoice 39687 | EFTA015802105 |
| 2 Aug 2013 | Judge recuses himself from Epstein’s case because Denise Francois will succeed him on the Superior Court | EFTA0111438740 |
| 19 May 2015 | Cheque for $162.50 drawn by Southern Financial LLC to Law Offices of Hodge & Hodge, 1340 Estate Taarneberg | EFTA0134786010 |
| 20 Nov 2015 | HODGE & HODGE letter signed Maria Tankenson Hodge, same street, same telephone | EFTA0106923410 |
Two gaps in this sequence are worth naming. Between the 2006 information return and the May 2009 probation letters the only dated items located are corporate: a January 2007 operating agreement naming the firm’s principal as agent and a May 2007 certification from the Lieutenant Governor’s office. No letter, invoice or payment is located across those three years, although the courier records of 2002 and 2005 and the 2006 information return show the relationship already existed. And after June 2013 the file holds only the 2015 items, with no document recording why the work stopped or whether it did.18
How this page is scoped
Measured against the released files on 5 November 2026. The index’s size on disk was compared
against its recorded value of 10,982,875,136 bytes and the comparison was printed before every run;
it matched on every run. Every return code was read and no empty result was converted into a zero.
Controls printed and read in the same invocations as the counts: richard m berman returned
371 documents / 885 sheets, matching this project’s standing figure; a token generated for the
test returned 0; and jeevacation, a known-positive, returned 752,295 sheets.1
The union is 419 documents and it is reported as a floor. Thirty-one printed forms of the firm’s name and its principal’s name were tested; eighteen returned something and are listed in the scope note with their counts and their exclusive increments. Four documents reached by one of those forms were read and rejected as other people, and the form that reached them contributes nothing to the union.1
The pruning mattered more than the widening in one case, and it cuts both ways. The form
maria hodges, which looks like the subject’s own name in the possessive, returns 32 documents.
The great majority are not her: an American Express concierge agent of that name writing to
Epstein’s office about tickets and cards. At least five, however, are her. On those the
possessive reading is the right one, and one of them sets the firm’s own street beside the name.
At least three of those five are reached by no other form tested here, so they fall outside the
union below. The form is not used for any factual claim on this page, and this is one of the
reasons the union is reported as a floor.1
A middle name the brief for this page did not carry added 29 documents. maria tankenson hodge
returns 84 documents and tankenson hodge 87, and those two sets overlap the plain maria hodge set
in only 36 and 38 documents respectively. A page scoped on maria hodge alone would have missed
roughly a third of her own filings, including the resident-agent certificates.1
Hodge & Hodge was bearer-checked rather than assumed, in both directions, and the result is set
out above. The bare surname hodge returns 1,301 documents and was never used, because it is a
common surname in this territory and in this corpus.1
Act counting was done by reading signatures, not by reading a database field. A census of the
sender field across the 419 returns 278 blank and names Maria Hodge four times; that is a fact
about a field and not about the firm’s output, and every attribution on this page was made at the
sheet. An automatic letterhead screen proposed 160 candidates; reading them by hand removed a large
part of its proposal, because the phrase Hodge & Francois Trustee Account on a bank wire and the
phrase the Law Office of Hodge & Francois in a calendar reminder both contain the firm’s name and
neither is an act of the firm. At least 47 documents survived that reading as firm-authored, an
act fraction of at least 11.2 per cent of the 419, or 11.4 per cent of the 413 that are not
refused. Both figures are floors and both are this page’s own estimate.2
The population is replicated and this page counts copies once. Across the union the matching-sheet to document ratio is 1.51, and a fuzzy text-identity measure groups the 414 documents whose text was read into about 253 families, a deflation of roughly 1.6 to 1. The worst families are specific and were handled by hand: eighteen documents carry eleven distinct wire instructions, fourteen carry one mediation appointment, seven carry one settlement agreement, and four and three respectively carry the two Attorney General letters of July and August 2012.1
Eleven sheets were read at the page image, and two further sheets were opened from which
nothing is taken because what was wanted from them is not legible at the resolution they are served
at. Each was fetched read-only from the site’s own per-document path, one request at a time, and
every batch carried a negative control, which returned HTTP 404 at 7,470 bytes of HTML while
every target returned HTTP 200 and a file beginning %PDF-. All are served at a native
96 pixels per inch as pdfimages -list reports it, and every reading is taken from that raster;
nothing was upsampled and no render was made with any other tool.1
The paper corrected or settled the released text in eleven places that matter here, and this page
follows the paper in all eleven. A bill line the text layer gives as $7.811.87 reads
$7,813.82, which is the only value that makes the sheet’s own total correct. Three wire principals
given as 5112.50, 52,979.81 and an unreadable string read $412.50, $2,979.61 and
$172.62. The letterhead’s GATLIN VOGEL reads GAYLIN VOGEL and its TAARNEDERG reads
TAARNEBERG. An invoice line the text layer gives as Telephone califs) reads Telephone call(s),
and the same invoice’s Taameberg reads Taarneberg. A resident-agent certificate’s Tiumrebcrg
reads Taarneberg, and the year its text layer leaves in dispute between printings is written on
that paper by hand as 2005. And on the 1099 the figure stands in box 7 and not in box 1.
Eleven is a floor, and no claim is made that the released text of these sheets is accurate
anywhere else.1
The native-attachment class was tested and this population does not touch it. The marker family
returns 26 documents and 44 sheets across four spellings, of which sixteen are EFTA identifiers.
The intersection of this page’s union with all 26, and with the sixteen, is zero in both
cases.1
Related
- Marjorie Rawls Roberts, the other St. Thomas tax lawyer whose 2006 information return from Epstein’s Financial Trust Company is printed on the same sheet as this firm’s, and about whose practice the same reporter asked the same agency the same question
- Darren Indyke, Epstein’s New York lawyer, who instructed this firm, signed the wires to its trustee account and executed the 2013 certificates that replaced it
- Cecile de Jongh, who held and released the firm’s cheques from Epstein’s St. Thomas office and attested the 2005 resident-agent certificate
- Richard Kahn, who transmitted most of the wire instructions to the bank and signed the 2013 certificates as Secretary
- Harry Beller, who signed seven of the eleven wire memoranda
- Lesley Groff, who handled most of the correspondence between Epstein’s office and the firm
- Jean-Pierre Oriol, the coastal-zone officer who wrote to the firm’s principal that major development was being processed through a series of minor permits
- Financial Trust Company, the Epstein company that issued the 2006 information return to the firm
- Little St. James, the island whose permits and construction disputes account for most of the firm’s located work
- Jeepers, Inc. and Thomas World Air, two of the Epstein entities for which the firm’s principal was registered agent until 2013
- Great St. James, the subject of the 2015 litigation in which the practice appears under its later name
- Kellerhals Ferguson Kroblin, the St. Thomas firm on the other side of that 2015 correspondence, which also acted for Epstein entities
- Jack Goldberger, Epstein’s Florida counsel, to whom the firm reported on the probation transfer in May 2009
- HBRK Associates Inc., the New York firm through which the wire instructions were sent
- Stacey Plaskett, and the territorial investigations and forfeitures, for the agency context in which this firm was asked about and not described
- Jeffrey Epstein, the client
Notes
Footnotes
-
Measured against the released files on 5 November 2026. Document counts are distinct identifiers in this project’s full-text index; sheet counts are index rows. The index’s size on disk was compared against its recorded value of 10,982,875,136 bytes and the comparison printed before every run; it matched on every run, and a second file of the same name elsewhere on this machine is 0 bytes and was not used. Controls printed and read in the same invocations:
richard m berman371 documents / 885 sheets;jeevacation752,295 sheets;zzqnotarealtoken77hf, a token confirmed to return nothing before it was used, 0. Forms tried, in documents:hodge & francois208 ·hodge francois208 ·hodge+francois208 ·hodge/francois208 ·hodge and francois61 ·maria hodge166 ·maria tankenson hodge84 ·tankenson hodge87 ·tankenson93 ·hodge & hodge41 ·hodge hodge41 ·attorney hodge29 ·attorney maria hodge22 ·maria hodge esq20 ·francois hodge19 ·hodge & francois trustee18 ·hodgefrancois13 ·hodgefrancois.com12 ·maria t hodge8 ·maria t. hodge8 ·m hodge4 ·m. hodge4 ·hodge, maria4 ·mark hodge3 ·hodge & francios2 ·law offices of hodge & hodge2 ·marla hodge1 ·hodge law1 ·hodge & francois esq1 ·hodge, maria tankenson1 ·mackay & hodge1. Returning nothing:law offices of maria hodge,hodge & francois, p.c.,the hodge law firm,hodge francois p.c.,hodge francois pc,hodge and francois p.c.,hodge & francois llp,hodge & francois llc,hodge and francois, p.c.,hodge & franco,hodge franeois,hodge frangois,hodge francols,hodge franqois,hodge & francois inc,hodges & francois,hodge & fran cois,maria hodgc,maria hodgo,mana hodge,maria hodse,hodge firm,the hodge firm,hodge & associates,m t hodge,hodge & francois p c,hodge francois com,hodge & hodge attorneys,hodge hodge law,denise francois judge,judge francois. Set equivalence tested, never assumed:hodge & francoisandhodge francoisreturn the identical 208-document set, because stops are discarded within a token boundary; the same test onhodge & francoisagainsthodge and francoisreports a symmetric difference of 251 documents, which is how the test was shown able to report one. The union: the firm-name and principal-name forms give 418; four documents were read and rejected as other bearers; the five documents reached only byhodge & hodgewere read and admitted; 419 is the result and it is a floor. The four rejected: two are a 2012 news item and its duplicate about an Anguillian pilot of the surname Hodge whose aircraft was lost at sea; one is a later message about an aircraft on a tarmac in which the name is broken across a soft line break and cannot be assigned, and which is therefore excluded rather than claimed; and one is a 318-sheet commercial public-records compilation in which four other people of the surname appear in a list. Nothing from any of the four is counted or described anywhere on this page. Themaria hodgesscreen: 32 documents. The great majority are not her, being an American Express concierge agent of that name writing to Epstein’s office, and two of those are long compilations that this page refuses. But at least five are her, the string being her own name in the possessive; at least three of those five are reached by no other form tested here and therefore fall outside the 419, which is one of the reasons the union is reported as a floor. The form is not used for any factual claim on this page, and nothing on this page is taken from any document it alone reaches. Partner-name forms were measured and not folded in:denise francoisreaches 94 documents, 27 of them outside this union;gaylin vogel17, 15 outside, and those fifteen are service lists of a different firm she had joined by 2019;mark hodge3, one outside. Individual documents from that measured set are cited on this page where they were read and verified, and they are not counted in the 419; the bound is that at most 43 further documents reach this firm through its partners’ names alone and were not worked. Replication: 631 matching sheets across the 419, a ratio of 1.51; an exact-text measure over the 414 documents whose text was read finds 19 families covering 46 documents, and a fuzzy 6-gram containment measure at 0.60 groups them into about 253 families, a deflation of roughly 1.6 to 1. The fuzzy measure chains through shared mail disclaimers and its largest family is an artefact of that chaining, so 1.6 is an estimate and the exact measure’s 1.07 is a floor. Page images: eleven sheets, each fetched read-only one request at a time from the site’s own per-document path, every batch carrying a negative control that returned HTTP 404 at 7,470 bytes oftext/htmlwhile every target returned HTTP 200 and a file beginning%PDF-;pdfimages -listreports every one at a native 96 pixels per inch, and every reading is taken from that raster. For the 1099 sheet the served file’s 80 pages match this project’s 80 rows exactly. Native attachments: the marker family returnsNative XLS10 documents,Native XLSX11,Native CSV4,Native TXT1, andNative DOC,DOCXandPPTnothing, a union of 26 documents / 44 sheets of which 16 areEFTAidentifiers, against a null marker returning 0. The intersection of this page’s 419 with all 26 is zero, and with the sixteen is zero. Unmeasured, and therefore not stated as a negative: whether the firm appears under a client name, a matter name or a damaged spelling no form here reaches; and what the 43 partner-name documents not worked contain. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 -
The act count, its denominator and its method. Denominator: the 419 documents of the union, or 413 if the six refused are set aside; both figures are given because a wrong denominator is the commonest arithmetic fault on this desk. At least 47 documents are acts of the firm, meaning the firm, one of its lawyers or a member of its staff authored the document as produced. Every one was established by reading the letterhead and the signature, not by any database field. They are: twenty letters and memoranda on the firm’s letterhead or over a firm lawyer’s signature; five invoices and time ledgers; ten court filings and enclosures signed for the firm; nine messages whose sender is a firm lawyer; and three sent by a member of the firm’s staff over her own name as secretary to a partner. This is a floor and an estimate, not a census. An automatic screen for the firm’s letterhead or a firm sender proposed 160 candidates and each was read; the screen’s aim control was that it had to reach four letters already known to be the firm’s, which it did, and its failure mode was over-firing, which it also did: it classified the Attorney General’s letters to the firm, a bank’s wire memorandum naming the
Hodge & Francois Trustee Account, and fourteen calendar reminders about a mediation held at the firm’s office as firm documents, and the hand reading removed them. A reader who counted a staff member’s covering email differently, or who counted the three printings of one letter as three acts rather than one, would get a different number. The sender field, for completeness and not for weight: across the 419 it is blank in 278 and carries Lesley Groff 31, Jeffrey Epstein 21, Darren Indyke 15, Cecile de Jongh 12, Richard Kahn 9, Google Calendar 7, Gary Kerney 5, Maria Hodge 4, Harry Beller 3 and Stephen Caplinger 3. Four sender rows for Maria Hodge against at least 47 firm-authored documents is the measure of how far that field is from an act count. The project’s own classification labels, quoted as labels and relied on for nothing:email.header175,financial.bank_statement40,court.filing38,memo32,court.filing_state19,financial.invoice17,image.scan11,letter11,legal.contract9,court.plea_agreement9,travel.itinerary7, and twenty further labels in ones and twos. The labels are wrong often here: the seven documents labelled travel itineraries include the corporate certificates that removed the firm as registered agent, and the nine labelled plea agreements are seven printings of an environmental settlement and two copies of an architect’s contract. ↩ ↩2 -
An undated single sheet headed
OUTSTANDING HODGE AND FRANCOIS BILLS. EFTA01122195 p. 1 of 1. Read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes in the same call; one served page against this project’s one row. From this sheet this page takes the heading, the two invoice-date lines, all six itemised entries with their figures, the two monthly totals and the total outstanding. The paper corrected the released text in one place and it is the material one: the released text gives the July litigation line as$7.811.87, which does not sum with the other two July items to the sheet’s own$13,014.75; the paper reads$7,813.82, which does. The August items$ 768.50,$ 910.68and$1,318.10sum exactly to the sheet’s$2,997.28in the released text as well as on the paper, which is how the method was shown able to detect an error at all. The two monthly totals sum exactly to the sheet’s$16,012.03. The item descriptions are set across several indented lines on the sheet and are quoted here across those line wraps; the dashes inJULY CHARGES – INVOICE DATEandFancelli – Motionsare the sheet’s own and stand inside quotation. The sheet carries no addressee, no author and no signature, and none is supplied here. This page does not say who prepared it, only that it is a schedule of this firm’s bills. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 -
Darren K. Indyke to Epstein’s bank,
Date: October 1, 2012, on theJEFFREY E. EPSTEIN Memorandumform. EFTA01580540 p. 1 of 1. Read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes in the same call. From this sheet this page takes the date, the sender’s typed name and the fact that a signature is written beside it in ink, the instruction sentence quoted whole, the beneficiary nameHodge & Francois Trustee Account, the two bank names and the bank’s street and city as printed, and the reference line quoted whole. The reference readsInvoice 38291, 38292, 39293, 38419, 38420 & 38421on the paper, and the third number breaks the run of the other five on the paper itself; it is not mended here and no inference is drawn from it. No account number, routing number or any identifier of that class is reproduced, described or located from this sheet. A second printing of the same instruction is at EFTA01590303 printed p. 2; it was not read at the page image and no comparison between printings was made or is reported. The equality between this amount and the total on 3 is an arithmetical fact about two sheets. No document read for this page states that the wire paid that bill, and this page does not say that it did; what it says is that the two figures are the same to the cent. ↩ ↩2 ↩3 -
Eleven wire instructions to the
Hodge & Francois Trustee Account, located across eighteen documents, 26 January 2012 to 21 June 2013. In order, with the signing or authorising hand where the sheet gives one: 26 Jan 2012, Harry Beller, $9,387.67,Invoice 37142, EFTA01580829; 15 Feb 2012, Darren Indyke, $12,042.05,Invoice 37307, 37308 & 37309, EFTA01580810; 7 May 2012, Harry Beller, $13,574.12,Invoice 37451, 37452, 37453, 37617, 37618, 37619 & 37143, EFTA01580712; 23 May 2012, Harry Beller, $6,940.33,Invoice 37793,37794, 37795 &'37796, EFTA01580686; 27 Jul 2012, Darren K Indyke, $21,407.52,InvOice 38108, 38109, 79545, 79547, 38110, EFTA01590407, forwarded to the bank by Bella Klein under the subjectJEE WT Hodge & Francois; 1 Oct 2012, Darren K Indyke, $16,012.03, see 4; 15–16 Oct 2012, Harry Beller, $3,428.04,Invoice 38560, 38561 & 38559, EFTA01580803; 17 Jan 2013, $13,744.44,Invoice #: 38816, 38817, 38818, 38932, 38933 & 38934, EFTA01590058; 15 Feb 2013, $2,979.61,Invoice #: 39076 & 39077, EFTA01580384; 15 May 2013, $172.62,Invoice #: 39552 & 39553, EFTA01580253; 21 Jun 2013, $412.50,Invoice #: 39687, EFTA01580210. The eleven sum to $100,100.93, and that sum is this page’s arithmetic over the eleven sheets, not a figure printed anywhere. Four were read at the page image at the served files’ native 96 pixels per inch, each fetched with a negative control returning HTTP 404 at 7,470 bytes in the same call: EFTA01580210, EFTA01580253, EFTA01580384 and EFTA01580540. On three of the four the paper corrected the released text:5112.50reads$412.50;52,979.81reads$2,979.61; and a principal the released text rendersk172,62reads$172.62. A fifth sheet carrying that last instruction was opened and its principal is not legible at the resolution it is served at; no figure is taken from it. From every one of these sheets this page takes only the date, the amount, the invoice reference, the beneficiary name as printed, the receiving bank’s name and city, and the signing hand where one is legible. No account number, routing number, debit account, intermediary code or identifier of any class from any of these sheets is reproduced, described, partially reproduced, masked or located, and this page makes no statement of any kind about how any producing party has treated anything on any of them. Further printings of several of these instructions are in the release and are not enumerated here. Every date, amount and invoice reference on this page is taken from the sheet cited for it and from no other, and no value of any kind is carried onto this page from one sheet to another. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 -
What was refused, and why. Six documents in this population are refused entirely. Nothing from any of them is quoted, summarised, characterised or counted anywhere on this page, their identifiers are not listed, and no conclusion here depends on any of them. The refusal was decided by measurement before anything was written. A status-predication screen with a nought-to-three adjective slot, proved to fire on planted examples at nought, one, two and three adjectives and to be silent at four, and silent on three designed negatives, was run over every sheet of every document whose text was read. It returned 362 hits in 42 documents. Most of those 42 are false positives of one kind: the word
minorinminor coastal zone management permit, which is the firm’s whole permit practice, and the wordcomplainantnaming a government department as the complainant in an environmental enforcement action. Each of the 42 was read, and six were refused. A separate screen for the binding-exclusion names returned 174 hits in 20 documents, all of which fall inside the six or inside filings this page does not cite. A bare-forename screen was built separately, because every other screen on this desk is blind to a forename standing alone, and it was run over the whole population; outside the refused documents it returned 15 hits and every one was read: four are the optical reading of the monthJuneas a name, eight are a woodwork line item in a construction ledger, one is the optical garbling of a corporate defendant’s name, and the rest are donors in a 2008 campaign-pledge roll. None is a complainant, a survivor or a protected forename. The forenameMariacollides with a binding-exclusion name in this corpus, and that was checked rather than assumed: every one of its appearances across the population was read to its bearer, and all are this firm’s principal, with one exception that is the name of a parcel of land in a deed. ↩ -
The firm’s memorandum of 25 October 2011 from Denise Francois to Darren K. Indyke. EFTA00307081 p. 1 of 2. Read at the page image at the served file’s native 96 pixels per inch, fetched read-only with a negative control returning HTTP 404 at 7,470 bytes of HTML in the same call; the served file’s two pages match this project’s two rows. From this sheet this page takes the letterhead in full: the words
LAW OFFICES OFaboveHODGE & FRANCOIS, the street and town beneath, and the four lawyers’ names in their two columns. The paper corrects the released text in two places:GATLIN VOGELreadsGAYLIN VOGELand1340 TAARNEDERGreads1340 TAARNEBERG. No telephone number, fax number or electronic address from this sheet is reproduced, described or located, and this page makes no statement about how any producing party has treated anything on it. The memorandum is initialled by hand beside the sender’s name. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 -
Complaint, Jeffrey Epstein and L.S.J., LLC v. Fancelli Paneling, Inc. and Atelier Fancelli, Superior Court of the Virgin Islands, Division of St. Thomas and St. John. EFTA00731209 printed p. 8. Released text only; this sheet was not read at the page image. From it this page takes only the firm’s signature block, in which
HODGE AND FRANCOIS,By: Denise Francois, a Virgin Islands bar number, the firm’s street and the lineAttorneys for Jeffrey Epstein and L.S.J., LLCstand on successive lines; a dated line stands between the first two, and the quoted strings are not joined here into one. Nothing is taken from the body of the complaint. No telephone, fax or electronic address from this sheet is reproduced. ↩ ↩2 ↩3 -
The firm’s invoices and time ledgers. EFTA01103431 pp. 1–2, to Jeffrey Epstein c/o The Epstein Companies, attention Darren Indyke,
In Reference To: General Representation, period ending 31 March 2011, total balance due$1,462.65; EFTA01103439 pp. 1–2, to FT Real Estate, Inc., twelve timed entries at325.00/hr, total balance due$3,713.86; EFTA01103441 p. 1, to IGO Company LLC,$81.25; EFTA00299079 p. 1, to LSJ, LLC, dated 1 November 2011; and EFTA01222222, an invoice of 1 September 2010 bound with a cheque-register page. The first was read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes of HTML in the same call; its two served pages match this project’s two rows. The paper corrected the released text of that sheet in two places: the street reads1340 Taarnebergwhere the released text givesTaameberg, and the timed entry of 28 March 2011 readsTelephone call(s)where the released text givesTelephone califs). The paper also gives the invoice number,35607, the hours against each entry, and a total of2.00hours and$650.00in fees, none of which the released text carries legibly. The remaining four are released text only and were not read at the page image. From them this page takes the firm’s invoice heading, the two sets of initials used for the fee-earners, the hourly rate, the four balances, and five of the timed entries on the first. The five entries quoted or relied on are those of 16, 24, 25, 28 and 29 March 2011; the remaining entries on these invoices describe a property closing and are not reproduced here. The entry of 28 March 2011 reads, at the image,Telephone call(s) Ms. Greene to confirm changed appointment; draft email to Indyke re same and telephone call to confirm; meet with client at DOJ to complete renewal of registration, billed at0.75hours and243.75. The entry of 16 March 2011 readsTeleconference with D Indyke re George Levin; research VI EDC beneficiaries re same; draft email to D Indyke re same. No taxpayer identification number, invoice-payment instruction or contact value from any of these sheets is reproduced, described or located, and this page makes no statement about how any producing party has treated anything on them. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 -
The later firm name. EFTA01069234 pp. 1–2, a letter of 20 November 2015 to Christopher Kroblin of Kellerhals Ferguson Kroblin PLLC, headed
HODGE & HODGE, footedATTORNEYS AT LAW/1340 TAARNEBERG, ST. THOMAS, VIRGIN ISLANDSand signedMaria Tankenson Hodge. Printed p. 1 read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes in the same call; two served pages against this project’s two rows. From this sheet this page takes the heading, the footer’s first two lines, the signature, and the fact that the telephone figures printed in the footer are digit for digit those printed on the Hodge & Francois letterhead at 7. Neither number is reproduced, described or located. The subject matter of the letter is a settlement-confidentiality agreement in a Virgin Islands suit over the sale of an island, and nothing is taken from its substance beyond the case name and the court number. Two further documents: EFTA01347860 p. 1 of 1, an image of a cheque dated5/19/2015, drawn bySOUTHERN FINANCIAL LLCof6100 RED HOOK QUARTER, B3on a New York bank,PAY TO THE ORDER OFLaw Offices of Hodge & Hodge, the sum written out asOne Hundred Sixty-Two and 50/100and set in figures as162.50, the payee’s address printed over three lines, and an authorised signature written by hand. Read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes of HTML in the same call; one served page against this project’s one row. From this sheet this page takes the date, the drawer, the drawer’s address, the bank, the payee, the payee’s three address lines and the amount, and nothing else. No account number, routing number, cheque number, magnetic-ink character line or any identifier of that class is reproduced, described or located, and this page makes no statement of any kind about how any producing party has treated anything on this sheet or on any other printing of it. A second printing is at EFTA01294714 printed p. 19; it was not read at the page image, nothing here rests on it, and no comparison between printings was made or is reported. Further: EFTA00101080 printed p. 2, a litigation search-term list in which"Hodge & Hodge", the firm’s mail domain,Maria w/2 HodgeandDenise w/2 Francoisstand together in one block, released text only. This page asserts no corporate relationship between the two firm names beyond what the street, the signature and the telephone number establish, and it does not say who the second Hodge is. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 -
A single-sheet contact list. EFTA00724796 p. 1 of 1. Released text only; this sheet was not read at the page image. From it this page takes two of its five lines,
Virgin Islands Legal Counsel and local contact: Maria HodgeandNY Legal counsel: Darren Indyke, and nothing else. No contact value of any kind on this sheet is reproduced, described or located, and no statement is made about how any producing party has treated anything on it. No document read for this page says whose list this is or when it was made, and neither is supplied here. ↩ -
FedEx shipment detail inside two account invoices. EFTA00217744 printed p. 2, invoice dated 23 August 2002, recording an International Priority envelope from
DARREN INDYKEat Epstein’s New York office toMARIA HODGE/HODGE FRANCOIS,Delivered Aug 18. 2002; and EFTA00220316 printed p. 2, invoice dated 31 January 2005, recording a second envelope sent in Epstein’s own name to the same recipient,Delivered Jan 27. 2005 16:32. Second printings of each are at EFTA01313622 and EFTA01319825. Released text only; none was read at the page image, and no comparison between printings was made or is reported. From them this page takes the direction of each shipment, the delivery dates and the two names. No account number, tracking identifier or street address from these sheets is reproduced, described or located. ↩ ↩2 ↩3 ↩4 -
Two printings of the same 2006 Form 1099-MISC. EFTA01338175 printed p. 67 of 80 and EFTA00175998 printed p. 46 of 76. The first was read at the page image at the served file’s native 96 pixels per inch, fetched read-only with a negative control returning HTTP 404 at 7,470 bytes of HTML in the same call; the served file’s 80 pages match this project’s 80 rows. From this sheet this page takes four things only, for each of the two forms printed on it: the payer’s name, the recipient’s name, the tax year, and the box 7 figure. The box number was verified at the image by this page and not inherited: the upper form’s
$ 796.64stands in box 7,Nonemployee compensation, and box 1,Rents, is empty; the lower form’s$ 22,373.16stands in box 7 likewise. The upper form is the one toHODGE & FRANCOISand the lower is the one toMARJORIE RAWLS ROBERTS, which agrees with that page’s reading that the firm’s form is printed directly above hers. No identification number, account number, street address or post box from either sheet is reproduced, described or located, and this page makes no statement of any kind about how any producing party has treated anything on either sheet. ↩ ↩2 ↩3 -
The Jeepers, Inc. resident-agent appointment. EFTA01344365 p. 1 of 1, EFTA01480425 p. 1 and EFTA01355708 p. 1, three printings of one certificate; and EFTA01355709 p. 1, the companion
UNANIMOUS CONSENT OF BOARD OF DIRECTORSto the same effect. The printing at EFTA01480425 was read at the page image at the served file’s native 96 pixels per inch, negative control HTTP 404 at 7,470 bytes of HTML in the same call; one served page against this project’s one row. Both quoted fragments are taken from that sheet and from no other, and they are not joined; a span of the resolution stands between them and is not reproduced here. The paper corrected the released text of that sheet, which renders the street1340 Tiumrebcrg; the paper reads1340 Taarneberg. The paper also settles a conflict between the printings: the released text of EFTA01355708 renders the year of the board’s consent as 2003 where the other two render it 2005, and on the paper the day and the year are written in by hand as June 23, 2005, which the companion board consent also gives. This page therefore uses June 2005. The instrument is signed Jeffrey Epstein as President and attested Cecile DeJongh as Secretary, both by hand on the paper. No telephone number appearing in any printing of this resolution is reproduced, described or located, and this page makes no statement of any kind about how any producing party has treated anything on any of these sheets. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 -
The June 2013 change of registered agent. Certificates of change of principal office and resident agent for Island Grounds, Inc. at EFTA00296146 pp. 1–2, for Jeepers, Inc. at EFTA00296150 p. 1 and EFTA00296373 p. 1, and for FT Real Estate, Inc. at EFTA00296156 p. 1 and EFTA00296369 p. 1. Released text only; none was read at the page image. From them this page takes the recital naming the current agent, quoted whole, the resolution appointing the new agent, and the month of execution. The two signatories’ roles are taken from the Island Grounds certificate alone, whose released text carries them; the signature blocks of the others were not read and no signatory is asserted for them. The recital is quoted from the Island Grounds certificate; the street is rendered
Taamebergin the released text of that sheet and this page reproduces that rendering inside the quotation rather than mending it. The certificates are undated as to the day: each readsas of thisfollowed by a blank,day of June, 2013, and no day is asserted here. The fourth and further entities are established from EFTA00388861 p. 1, Darren Indyke to Lesley Groff,Thu, 20 Jun 2013 17:50:05 +0000, whose attachment filenames name change-of-agent documents for three further entities and a board consent for a fourth. From that message this page takes the date, the sender, the instructionPlease print the attachments and give to mein substance, and the four filenames’ identification of the entities. “At least seven” is therefore a floor: it counts the three certificates in hand and the four entities the filenames name, and it does not claim that no others moved. No document read for this page states why the agency was moved or who decided it. ↩ ↩2 ↩3 ↩4 ↩5 -
Maria Tankenson Hodge to a lawyer at the Legislature of the Virgin Islands,
Date: June 19, 2012 12:31:45 PM EDT, subjectBill 29-0239 Amendment, forwarded by Darren Indyke to Jeffrey Epstein the same afternoon and filed as an exhibit in later litigation. EFTA02815745 printed pp. 2–3 of 3. Released text only; this sheet was not read at the page image. From it this page takes two quoted passages and the sender’s signature block, which readsMaria Tankenson HodgeoverHodge & Francois. The damaged characters in the quoted passages are on the face of the sheet and are not mended. The sheet lists four attachment filenames and this page takes from them only that one is described as a draft amendment and one as excerpts from the bill marked at the locations of the proposed amendments. A senator’s name stands in the body of the quoted passage in a state this page will not complete, and the senator this page does name is named from the firm’s own letter of 26 July 2012 at 36, where the name is printed in full. No electronic address from this sheet is reproduced, described or located beyond the Legislature’s own public domain where the sheet prints it as the addressee, and no statement is made about how any producing party has treated anything on it. ↩ ↩2 ↩3 ↩4 ↩5 -
No response from Hodge & Francois, from Hodge & Hodge, from Maria Tankenson Hodge or from anyone on their behalf about any document on this page has been located. No statement, denial, comment or explanation has been found in this release. A response is not recorded as absent because anyone declined to give one. No request was made from here; the finding is only that none has been located. ↩
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Statements of absence on this page are scoped to the documents read and returned for it, and to a search of the released files run on 5 November 2026 under the forms listed at 1. They are not claims about what the release holds and they are not claims about the world. In each case the control that shows the query could have found the thing is named at 1: the firing control returning 371 documents and 885 sheets; the null token returning 0; the set-equivalence test shown able to report a difference of 251 documents; the bearer screens that rejected four documents and thirty-one others; and the native-attachment marker family measured across four spellings against a null marker returning 0. Specifically: no retainer, engagement letter or fee agreement between this firm and Jeffrey Epstein or any Epstein entity was located; no document recording whether the Interstate Compact transfer was granted was located; no document stating who requested the October 2011 schedule of civil suits, or what became of it, was located; no document connecting the June 2013 change of registered agent to anything else was located; no document stating why the firm’s work for Epstein interests appears to stop in 2013 was located; no document recording any response by the firm to anything on this page was located; and no document read for this page records the firm being told of, asked about or responding to any allegation against its client. Unmeasured, and therefore not stated as a negative: what the forty-three documents reached only through the partners’ names contain; whether the firm appears under a client name, a matter name or a damaged spelling that no form tested here reaches; and what the six refused documents contain. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13
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Two letters of 4 May 2009 on the firm’s letterhead, in identical terms, signed
Maria Tankenson Hodge. EFTA00602826 p. 1 of 1, to Jack Goldberger of Atterbury Goldberger & Weiss, West Palm Beach; and EFTA00727361 p. 1 of 1, to Darren Indyke in New York. Released text only; neither was read at the page image. From them this page takes the subject line, the opening paragraph quoted whole, two further quoted clauses, and the signature. The telefax number to which the Goldberger letter was sent is printed on the sheet and is not reproduced, described or located, nor is any number in the letterhead footer. Neither letter says what became of the request, and nothing is supplied here. ↩ ↩2 ↩3 ↩4 -
Darren K. Indyke to Jeffrey Epstein,
DATE: October 25, 2010, subjectVoting in November 2, 2010 Election. EFTA00725459 p. 1 of 1. Released text only; this sheet was not read at the page image. From it this page takes three quoted passages and the memorandum’s closing conclusion. The quoted statute text and the Attorney General’s opinion the memorandum relies on are not reproduced beyond the words quoted. The memorandum is Indyke’s; the advice it reports is attributed to Maria Hodge in his words, twice, and this page attributes it accordingly and does not quote her directly from it. The sheet’sUune 30, 2008is an optical rendering of a date and is quoted here only inside the quotation that carries it. ↩ ↩2 ↩3 ↩4 -
Attorney General Vincent F. Frazer to Maria Hodge at the firm, 25 July 2012, subject
Implementation of Act No.7372, (Bill No. 29-023%; International travel Notice request, the damaged character being the sheet’s. EFTA01185163 pp. 1–2, with further printings at EFTA00610785, EFTA00298095 and, as a litigation exhibit, EFTA02813952. Released text only; none was read at the page image, and no comparison between printings was made or is reported. From this letter this page takes the date, the addressee, the sentence recording that the firm’s letter of 16 July 2012 was written on Epstein’s behalf, the statement that he is a registrant on the Virgin Islands Sex Offender Registry, the sentence granting the waiver quoted whole, and the substance of the six conditions with one clause of condition 4 quoted. The remaining text of the conditions is not reproduced in full. The four printings are counted once in every figure on this page. No contact value from any printing is reproduced. ↩ ↩2 ↩3 ↩4 -
Order of the Superior Court of the Virgin Islands in Guardian Insurance Company v. Estate of Valerie Knight-David and others, Civil No. ST-08-CV-189. EFTA01108387 p. 1 of 1, an order dated July 2013. Released text only; not read at the page image. From it this page takes four things only: that
Maria Hodge, Esq., of Hodge & Francois, appears on behalf of Plaintiff Guardian Insurance Company; the footnoteDenise Francois, Esq., is a partner in Hodge & Francois.; the quoted clause about the parties voicing conflict-of-interest concerns; and the full form of the judicial title, which this sheet spells out where the Epstein order’s sheet does not. The day of the month is damaged on this sheet and is not asserted here. This is not an Epstein matter and nothing else from it is reproduced, summarised or characterised here; the other parties are named on the sheet and are not named here. A second non-Epstein matter establishes the same practice: a published District Court opinion in Addie v. Kjaer namesMaria T. Hodge, Esq.as counsel for one defendant, at EFTA00727606 p. 1. A third, a published opinion in Epstein’s own suit against a bank, setsMaria Tankenson Hodge, Esq.,Hodge & FrancoisandSt. Thomas, U.S.V.I.on three successive lines of the counsel block, above the lineFor the plaintiffs, at EFTA01726507 p. 1; the four strings stand on their own lines on the sheet and are not joined here into one; and a bound volume of federal reports carries the same counsel line in two further matters and, separately, a commercial attorney profile giving her legal education, at EFTA00187391 printed pp. 12, 74 and 89. Released text only for all four. A different lawyer of a similar surname,Gregory H. Hodgesof another St. Thomas firm, appears as opposing counsel in two of these and is not this firm. ↩ ↩2 -
Memorandum on the firm’s letterhead,
October 25, 2011,TO: Darien K Indyke, Esquir,FROM: Gaylin Vogel, Esquire, subjectFirearm ownership by L.S.J., LLC employee residing on Little St. James Island. EFTA01112132 pp. 1–3. Released text only; not read at the page image. From it this page takes the date, the sender, the subject line and the concluding clause quoted whole. The reasoning of the opinion is not reproduced, and no employee is named, described or identified here in any way. The damaged rendering of the addressee’s name is the sheet’s and is quoted as it stands. ↩ ↩2 ↩3 -
Stacey Plaskett to Economic Development Authority staff, 19 July 2011, circulating a reporter’s requests with the agency’s drafted answers typed beside them. EFTA00598040 printed p. 2. Released text only; this sheet was not read at the page image for this page. From it this page takes only the two-word answer typed beside the request about this firm and the longer answer it points back to. The request itself, the reporter’s name, the full text of both answers and the surrounding thread are set out at Marjorie Rawls Roberts, which read the sheet at the page image, and are not repeated here. This page does not say that the agency refused because of anything about this firm. A memorandum of a meeting at the same agency on 7 September 2011 records the line
Specifically asked for info about MRR and Hodge & Francois; it is at EFTA01088636 p. 1 and is likewise set out on that page. The pattern this page records is only that a territorial agency, asked in July 2011 to list the beneficiary companies this firm represented, answered that doing so would be too much work. ↩ ↩2 -
IGO COMPANY, LLC OPERATING AGREEMENT, effective 2 January 2007. EFTA00312930 printed p. 4. Released text only; not read at the page image. From it this page takes one clause only, that the agent in the United States Virgin Islands for service of process shall be Maria Tankenson Hodge. Nothing else in the agreement is reproduced, summarised or characterised. ↩ ↩2 -
An annual report and computation of filing fee filed with the Office of the Lieutenant Governor, Division of Corporations and Trademarks. EFTA00310685. Released text only; not read at the page image. From it this page takes two fields only, the name and the physical address of the agent for service of process in the Virgin Islands. This document is typed in this project’s index as a travel itinerary, which it is not. ↩
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Two drafts of a letter from the firm to the Virgin Islands Interstate Compact Administrator, both signed
Maria Tankenson Hodge. EFTA00727986 pp. 1–2, addressedDear Ms. Swan; and EFTA00722270 pp. 1–2, an earlier state of the same letter addressed to the office rather than the officer. Released text only; neither was read at the page image. From them this page takes three quoted sentences, the sentence recording the date supervision was to begin, and the closing request. The second of the two carries unresolved editing marks and an unanswered query addressed to the client’s New York lawyer inside the body of the text, which is how this page identifies both as drafts; the query itself is not reproduced beyond saying that it concerns a figure about Virgin Islands employees. Neither draft is dated on its face and neither bears a filing or receipt mark; no date for either is asserted here beyond the May 2009 of the covering letters at 19, with which they share their subject. The phraseprocuring a minor for prostitutionis the firm’s own characterisation of the charge its client pleaded to. It names, describes and identifies no person, and nothing about any individual is taken from either sheet. No other passage of either letter, including its account of the client’s employees and philanthropy, is relied on for any factual claim on this page. ↩ ↩2 ↩3 -
Cecile de Jongh to Jeffrey Epstein,
Date: Fri, 18 Feb 2011 15:40:23 +0000, subjectCheck we are holding for Maria Hodge. EFTA00904758 p. 1 of 1, and her message of 24 February 2011 quoted inside his reply at EFTA00696659 p. 1. Released text only; neither was read at the page image. From them this page takes the subject line, the opening sentence, the four matter columns by name, the two row totals, the grand total and the sentenceI am releasing the below listed checks to Hodge-Francois. The table’s two rows sum to $24,930.03 and its four columns sum to $24,930.03 independently; both sums are this page’s arithmetic and both agree with the figure the sheet prints. A third message of the same week, EFTA00642638 p. 1, records that she was preparinga schedule of what is owed to Maria Hodge for Franchelli, Molyneux, LSJ (permit work) and FTC Real Estate, the spelling of the first matter being the sheet’s. The personal column of the table carries a figure that the sheet’s own note says no cheque yet existed for, and it is not included in any total on this page. ↩ ↩2 ↩3 -
Two letters on the firm’s letterhead to J.P. Oriol of the Division of Coastal Zone Management, 18 and 19 August 2009, and two to the Antilles Regulatory Section of the U.S. Army Corps of Engineers, both 22 September 2009. EFTA00725781 p. 1, EFTA00725782 p. 1, EFTA00725786 pp. 1–2 and EFTA00725788 pp. 1–2. Released text only; none was read at the page image. From them this page takes the dates, the addressees’ offices, one quoted clause, and the signatures, which read
MTHon the first andMaria Tankenson Hodgeon the others. The individual officer addressed in the Army Corps letters is not named on this page, because the sheets’ rendering of the name is damaged and this page does not complete a name from a damaged rendering. No contact value from any of these sheets is reproduced. ↩ ↩2 -
Darren K Indyke to Jeffrey Epstein,
DATE: October 21, 2009, subjectTelephone Call with Maria Hodge, Esq. Re ACOE and CZM. EFTA00728004 p. 1 of 3. Released text only; this sheet was not read at the page image. From it this page takes one quoted sentence and the fact that the memorandum records her account of calls she had made the previous day to named officers of the Army Corps and of Coastal Zone Management. The remaining numbered paragraphs concern the technical course of a permit and remediation dispute and are not reproduced, summarised or characterised here. The memorandum is Indyke’s and the words quoted are his report of hers; this page attributes them accordingly and does not quote her directly from it. ↩ ↩2 -
A facsimile of 17 March 2011 from Jean-Pierre L. Oriol, Division of Coastal Zone Management, Department of Planning and Natural Resources. EFTA01114440 printed p. 2, and a second printing at EFTA00589957 printed p. 2. Released text only; neither was read at the page image, and no comparison between printings was made or is reported. From them this page takes the date, the sender’s office, the addressee block’s three descriptive lines and the opening sentence quoted whole. This page quotes the three descriptive lines of the addressee block rather than the name line, and takes the addressee’s name from the body’s salutation,
Dear Attorney Hodge. No fax number, telephone number or electronic address from either sheet is reproduced, described or located. Nothing further from the body of the letter is reproduced, summarised or characterised here. ↩ ↩2 -
Letter on the firm’s letterhead to Alicia V. Barnes, Commissioner Designee, Department of Planning and Natural Resources, 2 May 2011, signed
Maria Tankenson Hodge. EFTA00587055 pp. 1–2. Released text only; not read at the page image. From it this page takes the date, the addressee, the subject line’s identification of the permit, and the signature. Nothing from the body is quoted. ↩ ↩2 -
MAJOR COASTAL ZONE MANAGEMENT PERMIT NO. CZT- 5-99(W) modified. EFTA00310784 printed p. 6, the same execution block recurring at printed pp. 7, 14, 15, 22 and 23. Released text only; not read at the page image. From it this page takes one line of the execution block only, in which the nameMaria Tankenson Hodgestands above the lineAttorney-in-fact for LSJ, LLCopposite the permittee’s designation. No term or condition of the permit is reproduced, summarised or characterised here, and this page makes no statement about what the permit allowed. ↩ -
SETTLEMENT AGREEMENT BETWEEN THE GOVERNMENT OF THE VIRGIN ISLANDS DEPARTMENT OF PLANNING AND NATURAL RESOURCES AND NAUTILUS, INC.EFTA00300146 printed p. 2 of 6. Released text only; not read at the page image. From it this page takes one recital only, that a notice of violation issued on 24 February 2012 was served onMaria T. Hodge, attorney-in-fact for Nautilus, Inc.on 8 March 2012. The wordComplainanton this sheet names the Department of Planning and Natural Resources and nobody else. Seven printings of this agreement are in the population and they are counted once in every figure on this page. No term of the settlement is reproduced, summarised or characterised here. ↩ -
The memorandum at 7, read at the page image. From its body this page takes only the subject line quoted whole and the fact that five suits are tabulated with their courts, docket numbers and dispositions. Neither the parties to those suits nor the suits themselves are set out here beyond the one named in the body of this page, which the memorandum lists first. No document read for this page states who requested the schedule, for what purpose, or what was done with it. ↩ ↩2
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The firm’s objection to the waiver conditions, in two states. EFTA01100126 printed pp. 1 and 2, dated 26 July 2012 and headed
[TO BE PRINTED ON HODGE & FRANCOIS LETTERHEAD), the bracket mismatch being the sheet’s; and EFTA00312818 p. 1, dated 30 July 2012 and printed on the letterhead itself. Released text only; neither was read at the page image. From the draft this page takes three quoted passages: two from its printed p. 1 and the sentence beginningFrom the beginningfrom its printed p. 2. From the letter as sent it takes two further quoted passages, both from its printed p. 1. The two letters make the same argument in different words and this page does not treat a passage of one as a passage of the other; the sentence about the client’s travel record appears in the draft and not in the sent letter. Both print the senator’s name in full in the body, which is where this page takes it from. The first is a draft and is identified as one by its own bracketed instruction; the document that carries the letter as sent also carries the Attorney General’s reply. Nothing from the remainder of either letter’s argument is reproduced beyond the passages quoted. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 -
Maria Tankenson Hodge to the Office of the Attorney General,
Sent: Friday, June 22, 2012 5:28 PM, subjectBill 29-0239, carried inside a forward from Jeffrey Epstein to Cecile de Jongh of 25 June 2012 and filed as an exhibit in later litigation. EFTA02815756 printed pp. 3–4 of 5. Released text only; this sheet was not read at the page image. From it this page takes four quoted passages and the signature. The full stops standing where commas would be expected are the sheet’s own optical rendering and are reproduced rather than mended. The same document carries, at printed p. 2, a message of 25 June 2012 from counsel to the Attorney General transmitting a counterproposal; from that message this page takes only the fact of the counterproposal and the sender’s office. A mobile number offered in the body of the quoted message is not reproduced, described or located. The names of the Assistant Attorney General and of one further correspondent are withheld or damaged on this sheet and are not supplied, named or characterised here. ↩ ↩2 ↩3 ↩4 -
Maria Hodge to Senator Ronald Russell,
6/25/2C12 4:37:23 PM, subjectBill 29-0239 Amendments, markedImportance: High, with Jeffrey Epstein’s address in the copy line; filed as an exhibit in later litigation. EFTA02815572 printed p. 2 of 2. Released text only; this sheet was not read at the page image. From it this page takes two quoted passages, the subject line, the importance marking, the attachment’s description as a draft amendment with revisions of that date, and the signature, which readsMaria Tankenson HodgeoverHodge & Francois. The sheet’s header renders the sender’s forenameMarie; the signature block beneath renders itMaria, and this page follows the signature. The damaged characters in the quoted passages are on the face of the sheet and are not mended. The senator’s own electronic address is printed on this sheet and is not reproduced, described or located, and the senator is named from the firm’s letter at 36 as well as from this sheet. No statement is made about how any producing party has treated anything on this sheet. ↩ ↩2 -
Attorney General Vincent F. Frazer to Maria Tankenson Hodge at the firm, 14 August 2012, subject
Wavier Request for Travel Notice for I. Epstein, the spellings being the sheet’s. EFTA00610783 pp. 1–2, with further printings at EFTA01110955 and EFTA01185161. Released text only; none was read at the page image. From them this page takes the date, the addressee, the subject line and the closing sentence quoted whole. The substance of the modification is not reproduced here. The firm’s reply of August 2012 is at EFTA00584520 pp. 1–2, on the letterhead, and from it this page takes its opening clause only. That reply is undated on its face: the sheet printsAugust __, 2012with the day left blank, and no day is supplied here. The three printings of the 14 August letter are counted once in every figure on this page. ↩ ↩2 -
Order of the Superior Court of the Virgin Islands, Division of St. Thomas and St. John, in Jeffrey Epstein and L.S.J., LLC v. Fancelli Paneling, Inc. and J.P. Molyneux Studio, Ltd., dated 2 August 2013 and entered 5 August 2013. EFTA01114387 printed p. 2 of 2. Released text only; this sheet was not read at the page image. From it this page takes the order’s opening passage quoted whole, the two operative paragraphs in substance, and the footnote identifying counsel. The damaged characters in the quoted passage are on the face of the sheet and are not mended;
A .. :te Judgeis the sheet’s rendering of a title this page does not complete inside the quotation. The title is given in the surrounding prose asAssociate Judge of the Superior Court of the Virgin Islands, and that is taken not from this sheet but from a separate order of the same judge in an unrelated case, EFTA01108387 p. 1, which spells it in full. The judge is named on the sheet and is not named here, because nothing on this page turns on which judge it was and the order’s force is the same without it. A later filing in a different matter prints the same lawyer’s name above the lineJudge of the Superior Court of the Virgin Islands, at EFTA00805272 printed p. 56; it was not read at the page image and nothing further is taken from it. No document read for this page connects the recusal to the change of registered agent two months earlier, and this page does not connect them. ↩ ↩2 ↩3 ↩4 -
Letter on the firm’s letterhead to Commissioner Robert S. Mathes, Department of Planning and Natural Resources, 20 December 2010, concerning three minor Coastal Zone Management permits. EFTA00595543 p. 1, and its second printing EFTA01110966 p. 1. Released text only; neither was read at the page image. From them this page takes the date, the addressee and the subject line’s identification of the three permits. Nothing from the body is quoted. ↩
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The arrangements for a site visit of 3 April 2012. EFTA00416688 p. 1, Jeffrey Epstein to Lesley Groff,
Date: Fri, 30 Mar 2012 17:39:55 +0000, answeringyes perfectto the question whether Maria Hodge might come to the island; and EFTA00416693 p. 1, Daphne Wallace to Maria Hodge and others,Date: Fri, 30 Mar 2012 18:42:12 +0000, subjectRe: Inspecting LSJ re CZM, confirming the visit. Released text only; neither was read at the page image. From them this page takes the two dates, the subject line, Epstein’s two words and the purpose the subject line states. No document read for this page records what was seen or said on that visit. A further message of the same thread records a 1pm appointment the same day with a different lawyer, and nothing is taken from it here. ↩ -
Calendar reminders in Epstein’s office for a mediation of 13 July 2012
at the Law Office of Hodge & Francois, 1340 Taarneberg. EFTA02164384 p. 1 is cited as representative. Released text only; none was read at the page image. Fourteen documents in this population carry this one appointment and they are counted once in every figure on this page. From them this page takes the date, the time and the venue only. A message of 12 July 2012 records Epstein’s own instruction,tomororw morning i need to be at maria hodge office at 930, the spelling being the sheet’s; it is at EFTA00939550 p. 1. No document read for this page records what happened at the mediation. ↩ -
Lesley Groff to the firm,
Date: Thu, 16 Aug 2012 20:26:46 +0000, subjectJE's Main and 2nd Passport, copying Darren Indyke. EFTA00406597 p. 1 of 1, with the instruction that prompted it at EFTA00406579 p. 1,Darren is requesting that you please send clean, perfect PDF copies of JE's Main and Second Passport (Signed) to Maria Hodge. Released text only; neither was read at the page image. From them this page takes the date, the subject line, the instruction’s substance and the addressee. No passport number, document image, electronic address or other identifier from either sheet is reproduced, described or located. No document read for this page says why the firm needed them, and none is supplied here. The member of Epstein’s staff asked to send them is identified on these sheets by a forename only and is not named, described or characterised here in any way. ↩ -
Letter on the firm’s letterhead to Darren Indyke, dated
January• 8, 2013on the sheet, marked[VIA FEDERAL EXPRESS], enclosing an executed subpoena in the Fancelli matter. EFTA00312895 p. 1 of 9. Released text only; not read at the page image. From it this page takes the date, the addressee, the subject line’s identification of the case and the fact of the enclosure. The witness named in the subject line is a party’s principal in a commercial dispute and is not further described here. ↩