In re: Lynda Fay Layton

Opinion

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

In re: ) ) Case No. 25bk5385 ; ) Lynda Fay Layton, ) Chapter 11 Debtor. ) . ) Judge Timothy A. Barnes

FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO GREGORY K. STERN, MONICAL C. O’BRIEN, DENNIS E. QUAID AND RACHEL S. SANDLER, ATTORNEYS FOR DEBTOR, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $41,525.00 TOTAL COSTS REQUESTED: — $1,738.00 TOTAL FEES REDUCED: $ 1,808.00 TOTAL COSTS REDUCED: $ 0.00 TOTAL FEES ALLOWED: $39,717.00 ‘TOTAL COSTS ALLOWED: $ 1,783.00 TOTAL FEES AND COSTS ALLOWED: $ 41,500.00 THIS CAUSE COMING ON TO BE HEARD on Debtor’s Attorneys’ Application for Allowance of Final Compensation and Reimbursement of Costs and Expenses [Dkt. No. 56] (the “Application”); TT IS HEREBY ORDERED THAT: 1. ‘The Application is granted, as set forth herein. 2. Gregory K. Stern, Monica C. O'Brien, Dennis E. Quaid and Rachel S. Sandler (the “Attorneys”’) are allowed final compensation of $39,717.00 and reimbursement of costs of $1,738.00 for services rendered. 3. The Attorneys are authorized to apply any remaining amount of the retainer or funds previously received from the Debtor to the unpaid balance of the total fees and costs allowed. 4, ‘The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by alphabetical notations that appear on the left of each underlined entry. ‘The alphabetical notations correspond to the paragraphs below. (A) = Lumping — TOTAL of disallowed amounts (10% of affected entries): $ 88.00 ‘The Court may impose a ten percent penalty on entries that appear to be “lumping.” ‘The Court will reduce each entry marked as such per the penalty. I” re Wildman, 72 B.R. 700, 709

(Bankr. N.D. Ill. 1987) (Schmetterer, J.) (‘Applicants may not circumvent the minimum time requirement or any of the requirements of detail by “lumping” a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.”’). (B) Duplication of Services — TOTAL of disallowed amounts: $ 1,720.00 The Court denies the allowance of compensation for services that duplicate those of another professional or paraprofessional. See 11 U.S.C. § 330(a)(4)(A)(@). Reduction in fees is warranted if multiple attorneys from the same firm appear in court on a motion or argument or for a conference, unless counsel adequately demonstrates that each attorney present contributed in some meaningful way. I” re Pettibone, 74 B.R. 293, 307 (Bankr. N.D. IIL 1987) (Schmetterer, J.) (‘A debtor’s estate should not bear the burden of duplication of services. If found in the record, such duplication shall be disallowed by the court as unnecessary.”). It 1s also an accepted principle that generally no more than one attorney may bill for time spent in an intra-office conference or meeting absent an adequate explanation. See In re Adventist Living Cirs., Inc.. 137 B.R. 701, 716 (Bankr. N.D. IIL 1991) (Sonderby, J.); In re Pettibone, 74 B.R. at 303; Bat see In re MEP Infrastructure Sols., Inc., 654 B.R. 922, 925 (Bankr. N.D. Ill. 2023) (Goldgar, J.) Gncorrectly citing In re Stainless Sales Corp., Case No. 17 B 3148, 2017 WL 2829675, at *2 (Bankr. N.D. IIL June 27, 2017) (Barnes, J.) for the proposition that intra- office meetings between multiple lawyers are never compensable when S/ainless cites to Pettibone for the foregoing—that an application must “adequately demonstrate[| that each attorney present contributed in some meaningful way” and thus satisfy 11 U.S.C. § 330(a)(3)(D) by demonstrating that the meeting is “necessary” or “beneficial” and must have taken a “reasonable amount of time.”).

ENTERED: > CS Dated: September 3, 2025 — = ‘Timothy A. Barnes, Judge United States Bankruptcy Court

53 West Jackson Boulevard Suite 1442 Chicago, Illinois 60604 (312)-427-1558 Statement Date: August 5, 2025 Linda Layton Statement No. 1 Account No. Layton.Admin Page: 1

Fees . Hours rrech 11 filing, real property, debt, income isc., review UST | " Cram, subvT and including retainer in projections . □ RDS Call with B Handler re ch 11 filing and income/expenses and cash collateral. 0.20 é RDS Email to LL requesting P&L for Sub V Trustee. 0.10 □ RDS Review file and call with LL re DIP account, insurance, and IDI. 0.30 12 RDS _ Update filing letter and email to LL re same with attachments. RDS Review P&L and 2024 expenses and email to LL re same. 0.20 ‘ GKS_ Telephone conference with LL prepping for ID] and discussing sd(s) - meeting with RSS re discussions with LL (.2) Review LL email and 2024 and 2025 ytd p&l(s) and email to LL re same and revisions needed (.2) 0.40 2€ RDS Review P&L 0.10 RDS Meeting with GKS re security deposits and discussion with LL in preparation of IDI 0.10 □□□ □ Representation at IDI 0.60 24 RDS _ Review email from LL with insurance declarations. 0.10 4 RDS Discussion with LL re Kathy Bellas lawsuit and Twin Property Management (.3); Review email from LL with Kathy Bellas lawsuit and court order (.1) 0.40 □□ RDS _ Review Cook County Treasurer for yearly taxes on properties and estimated monthly tax withholdings for same (.5) Multiple email exchanges with LL re

Layton-/ Statement No:

Hours

A & B and finalize May operating report. gExt are Expt ogo MCO_ Telephone conference with Kathy Bellas and Bob Jones re: stay violation with proceeding with state court lawsuit, explanation of the rules re: a creditors obligation to cease all actions after the bk filing; advised that must either place matter on the bankruptcy calendar or dismiss the action with leave to reinstate; confirming deadline of July 8 to take action to stop all activity in state court action 0.30 1 MCO_ Email to Kathy Bellas confirming conversation and need for proof that state court action stopped before July 9, 2025. 0.10 MCO_ Review email and attachments from Kathy Bellas (.10); prepare response advising that filing pleadings in the Bk court not sufficient to cure stay violation (.10); email and telephone conference with GKS re: documents and information to prepare motion for sanctions for stay violations (.20). 0.40 2: GKS_ Review LL and MCO bellas emails and telephone conference with MCO re bellas and drafting stay violation motion 0.20 1 MCO Multiple emails from and to Kathy Ballas re: her continued stay violations, advising of steps to cease such violations and deadline for same . 0.30 □ GKS_ Reviewing file, bellas communications, 5th amended complaint and exhibit, bk notice of ch 11 case and drafting stay violation motion 1.30 8 MCO_ Telephone conference with Kathy Ballads re: pending status in state court case and advising of options to ensure that no further stay violations. 0.20 1 MCO_ Email to LL re: filing of Motion for Sanctions against Kathy Bellas and status hearing to be held in Bellas' state court case. 0.10 MCO_ Telephone conference with LL re: appearing at hearing on Kathy Bellas’ Motion for Relief and filing Motion for Sanctions against her. 0.20 41 MCO_ Court - Representation of Debtor at hearing on Kathy Bellas' Motion for Relief From the Automatic Stay. 0.60 3. RDS _ Draft Motion to Withdraw as Attorneys and Proposed Order. 0.50 2: RDS Email to LL re status of approval for plan, operating report and rent roll. 0.10 ‘ GKS_ Review and consider LL objection to GKS motion to wd (.2) email to LL re objection to motion to wd, need to file plan before wednesday hearing (.1) 0.30 1! GKS Prepare for court hearing - review Court 7/23/25 calendar, review scheduled motions, review case docket re sanctions motion cont'd to 7/30/25 0.30 1! GKS_ emails to LL scheduling conference call to discuss case status, plan and 6/25 MOR 0.10 ( RDS Review email from LL with June operating report, review operating report and attachments, email to LL re same and possible violation of cash collateral

53 West Jackson Boulevard Suite 1442 Chicago, Illinois 60604 (312)-427-1558 Statement Date: August 5, 2025 Linda Layton Statement No. 14 Account No. Layton.CC Page: b

RE: Cash Collateral

Fees Hours RDS Multiple exchanges with LL re budget and proper expenses (.2); Meeting with MCO re budget (.1); Email to TJ with April/May budget for review/approval (.1) 0.40 1 Review TJ proposal for Cash Collateral and budget, reply re same, 4 vacant rentals to be repaired to lease and then cash flowing for payments to lender in June. 0.20 □ RDS _ Review response from TJ re $4300 monthly payments, call to TJ re same - left message. 0.10 MCO_ Review foreclosure complaint and attachments (.20); draft Motion for Use of Cash Collateral (.80). 1.00 5!

and personal items. sion of repars oaot GKS__ Reviewing draft of cc motion and budget - telephone conferences with RSS and MCO re cc motion and budget - email to LL re cc budget, expenses, vacancies, Prins documents 0.50 32 RDS _ Review email from GKS re budget, Prins and Assignment of Rents (.1); Review recorder of deeds for assignments, note and mortgage (.3). 0.40 1 RDS Email exchange with LL re May budget 0.10 GKS_ Meeting with RSS reviewing and discussing draft plan term sheet and revisions needed including various scenarios for First Secure mortgage term and interest rate, including operating and personal expenses 0.50 32 Revise budget and email to LL re 511 & 612 Budget 0.20 □ RDS _ Email to LL re contact at Prins, and need to discuss budget, repairs to units and plan moving forward 0.10 4

Laytc Statement No: Cash Collateral

Hours GKS_ Review RSS and LL emails re cc budget - real estate tax prorations and payments 0.20 1 RDS Multiple email exchanges with LL re May Budget, updates and revisions to same 0.50 2 RDS _ Review updated May budget 0.10 RDS Email exchange with TJ re cash collateral order, May budget and adequate protection payment to First Secure 0.10 □□□ Call with LL re cc hearing, budget, taxes and Kathy Bellas lawsuit. 0.50 2: GKS__ Telephone conference with RSS re status of discussions with 1st Secure attorney, negotiated adequate protection payment and Bellas appearance at court hearing (.2) Court - Representation of LL at hearing on cash collateral motion (.4) 0.60 3 GKS__ Review and revise draft cc order (.2) Meeting with MCO and RSS re draft order (.1) 0.30 1! RDS _ Review email from TJ re interest only payment, and reply re same (.1); Discussion with GKS re same and court hearing (.2) Court - Representation at hearing on Motion for CC (.6). 0.90 4A RDS Meeting with MCO re updated CC Order and Budget (.1); Email to all parties re same, solicit approval (.1); Email to Court with DOFT procedure (.1) 0.30 1 (B) MCO_ Update draft of order authorizing use of cash collateral to include Prins lender (30); meeting with RSS re: same (10) 0402 RDS _ Email to LL re May cash collateral budget and order and discussion that monies can only be spent per budget/order. 0.10 □ RDS_ Review email from LL Re June budget, reply advising to prepare and send a copy of same. 0.10 RDS Email exchange with LL re June budget. 0.10 RDS _ Review June budget and prepare second interim cash collateral order (.3); Circulate to all parties re approval of same (.1) 0.40 1é RDS _ Review email from Tina Jacobs re First Secure payment and June CC and reply to same. 0.10 RDS Review email from TJ re appraisals and email exchange re same and adding. ae language to CC order. RDS Email to Joe at Prins re agreement with CC Order. 0.10 RDS _ Multiple emails and call with GKS and LL re cash collateral order and appraisals 0.20 ¢ Davia hankl attarnaisia Aamail ra an hii AAAt And antaniiata nrntantinn naimant _

Laytc Statement No: Cash Collateral

Hours email to RSS and LL re same (.1) 0.10

□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ INSpections/appralsals - conference call with RSS and LL re same - Co a

RDS Review email from TJ agreeing to CC order with appraisal language in order. 0.10 □ RDS _ Follow up email to Joe at Prins re June CC budget and order. 0.10 RDS Emails to and from GKS and LL re cont'd use of cash collateral and inspection requirements (.2); Call with GKS and LL re same (.2); Court - Representation at continued hearing on use of cc (.4) 0.90 4 RDS Email to LL re P&L and bank statements needed for Sub V Trustee to sign off on CC order. 0.10 RDS _ Forward bank statements to BHandler for review. 0.10 RDS Email exchange with LL re cash collateral order and need to provide Trustee documentation prior to sign off. 0.10 RDS _ Call to Robert Handler re April operating report needs additional time/work to prepare and that P&L and bank statements were sent, RH advised he would not object to entry of June CC order/budget. 0.20 RDS Email to LL re July budget for Community and complete July budget and money for taxes needed by the end of July. 0.10 RDS Review July budget and circulate to parties in advance of cc hearing at the end of the month. 0.10 □ MCO_ Email from JP confirming no objection to July CC order (.10); email to and from Joe DeGroot confirming no objection to July CC order (.10) 0.20 1 Review August budget, updated cash collateral order and circulate same to parties. 0.30 1. Review email from TJ, JDG, UST and RH re no objection to August CC. 0.10 é GKS_ Review UST's email re approving cc budget and ?g case status - forwarding email to LL and advising of case status and need to file plan 0.20 □ For Current Services Rendered 12.30 6,3

53 West Jackson Boulevard Suite 1442 Chicago, Illinois 60604 (312)-427-1558 Statement Date: August 5, 2025 Linda Layton Statement No. 1 Account No. Layton.Plan Page.

Fees

Hours GKS_ Meeting with RSS re plan terms - different scenarios & options (.3) Review RSS email to LL and spreadsheet re plan scenarios/spreadsheet (.1) 0.40 2 RDS Meeting with GKS and LL re plan payments including mortgage, current and past due taxes and feasibility of same. 0.50 2: GKS_ Meeting with LL discussing case status, restructuring mortgage debt and various restructuring scenarios, income/expenses, plan payments/projection , (.7)- Meeting with LL and RSS discussing plan possibilities, income/expenses, projections (.6) , 1.30 8 (B) projections (. □ RDS _ Review projections from LL and create cash flow summary with expenses and estimated plan payments (1.2); Email exchange with LL re same and her understanding of a consensual/non-consensual plan (.3) 1.50 6 RDS Begin draft of Plan of Reorganization (.4); Email to LL re same and need for her cash projections (.1). 0.50 2: □□□ □ Continue drafting Plan of Reorganization. 0.80 3¢ MCO Meeting with GKS and RDS re: Plan terms, claim classification, feasibility problems and possible alternatives, compliance with all provision of Sec. 1129. 0.40 23 MCO Meeting with RDS re: issues with Debtor proposal for repayment of creditors and possible alternatives for repayment that do not run afoul of provision of Sec. 1129 of the Code. 0.30 1 GKS_ Meeting with MCO and RSS re case status, plan term sheet and projections and reviewing projections and LL comments (.4) Reviewing RSS and LL

Laytor Statement No:

Hours emails and LL 1st updated projections showing 105g shortfall and 2d updated projections - reviewing/comparing 3 versions of projections and LL revisions (4) 0.80 5 () "OS fRovemsan poo tena □□□□□□□□□□□□□□□□□□□□□□□ RDS_ Continue drafting plan. 1.90 8 RDS _ Review, revise and update cash flow projections. 0.60 2 RDS _ Update draft of plan. 0.50 2 (B) RDS Meeting with MCO re: issues with Debtor proposed pian repaymentand alternatives that comply wi e Code □ RDS _ Multiple email exchanges with LL re plan projections and options for feasible plan 0.20 RDS _ Review updated cash flow projections from LL (.2); Draft email to LL re plan options, term sheet provided at the end of April and LL not provided any feasible alternative options compliant with code (.2) 0.40 1 RDS _ Review updated cash flow projections from LL (.2) and email to LL with detailed explanation as to how her numbers are not feasible and not within the bankruptcy rules, discussion of past due taxes and how same must be repaid, and options that we have proposed, and discussion if LL is unable to provide a feasible plan First Secure will come in on a Motion to Convert or Dismiss (.3) 0.50 2: RDS Email to TJ re plan treatment for First Secure and duplicate POCs 0.10 □ RDS Meeting with MCO re: treament options and responses to Debtor restructuring proposals. 0.40 1 GKS_ Review RSS emails to LL re LL plan projections and LL reply emails - emails to LL re plan, sale of property, option 1 and ? option 2 0.40 2 MCO_ Meeting with RDS re: treament options and responses to Debtor restructuring proposals. 0.40 2: RDS_ Review multiple emails between LL and GKS as to how she wants to structure plan of repayment 0.20 RDS _ Continue to review and revise cash flow projections playing with sale of property and/or taking social security benefits 1.20 5 □□□ Continue drafting and revising the plan 1.30 5 Create liquidation analysis 0.30 1: RDS _ Update tenant rent roll with lease and security deposit 0.20 ‘ RDS Email to LL with draft of plan, liquidation analysis and cash flow projections, and why LL's plan ideas are not feasible, difference between a Chapter 11 and 42 nrnvinddiinan athar nntinne far nlan inclridinn ||] nattinga \AJO amninvmant or call

Laytor Statement No:

. Hours a property 0.30 1 RDS Review multiple emails from LL re her plan and creditor treatment, reply email to LL re same and that she should provide positive cash flow projections by Monday and be prepared to come into the office to discuss same. 0.50 2 RDS Review email from LL and reply re plan, liquidation analysis, SBA, explanation as to why plan is 100% repayments, why past due taxes cannot be interest only payments, First Secure interest rate, plan and payments are all based on cash flow projections, and LL to provide cash flow projections for plan LL creates 0.40 1 RDS _ Review email from LL re appraisals and reply that will forward upon receipt of same, but appraisals are not relevant to cash flow projections, and continued email exchange re appraised values of properties 0.30 1 GKS_ Review and consider LL emails re plan, eid! loan and reply email to LL ?g and requesting eidl research, communications with SBA - emails to and from BH re draft of plan, LL proposed plan and need to schedule meeting for Monday to discuss plans under considerations 0.30 1 RDS _ Review email from LL re SBA and GKS advised for LL to contact SBA to get agreement 0.10 ‘ GKS___ Review LL email re proposed plan - reply email to LL requesting she forward draft for review and consideration (.1) emails to and from BH requesting la and projections in excel format and scheduling teams meeting (.2) Telephone conference with re BH request and waiting for LL plan projections (.1) 0.40 □ RDS Email to BH re cash flow projections and liquidation analysis with reminder for LL to send her cash flow projections prior to meeting 0.10 GKS__ Preparing for meeting with LL and Sub v T - reviewing and considering LL proposed plan projections, calculating LL proposed payments to taxes - comparing LL projections to RSS projections (.7) Meeting with RSS re LL projections, reviewing tax poc no. 1, noting discrepancies in LL plan projections relating to payment of taxes, RSS to revise draft projections to provide for correct interest rates 9% and 18% depending upon years owed (.5) Meeting with DEQ confirming standards for commercial real estate loan as marketplace terms and discussing extended repayment of unsecured debt (.2) 1.40 9 RDS_ Review LL plan projections and calculations (.3); (B) □□□ ce SS Le ee Gee mS RDS Discussion with Bob Handler re calculations for drafted plan projections and rates and LL's competition projections. 0.20 RDS _ Revise plan calculations for past due taxes based on individual parcel and different rates of interest, update cash flow projections re same 0.70 3 (8) DS Meeting with LL, BH and GKS re LL plan projections and feasibly issues. «140, GKS Team meeting with LL, RSS and SubV T discussing attorney and LL plan projections, plan terms and confirmation process and telephone conference santa 1 nem aban Hianreemimmecjvnteh Cad AS oT 11 nannnank «af nian: mantimi unc

Laytor Statement No:

Hours attorney representation and filing of motion to extend time to file plan and possible motion to allow attorney withdrawal (1.4) Meeting with RSS re discussions with LL, revising plan projections to attempt to provide for increased payment to mortgagee after initial 5 year term to provide for payment in full, drafting motion to extend time to file plan (.2) email to LL re case status, plan terms, attorney representation and filing of motions (.2) 1.80 1,1 RDS _ Meeting with GKS re discussions with LL, revising plan projections for increase payment to mortgagee after past due taxes and motion to extend time to file plan. 0.20 RDS Draft Motion to Extend Time to File Plan, proposed order and notice of motion. 0.60 2 GKS___ Reviewing and considering LL projections, notes from meeting re LL concept of plan, calculating mortgage repayment scenarios and refining terms - reviewing, revising and updating draft of plan to conform to LL vision of plan terms - email to LL and RSS re same 2.30 1,4 RDS Draft plan as articulate by LL with updated tax payments 1.00 4 [2025 GKS_ Reviewing LL email commenting on updated revised draft of plan and LL need to communicate with SBA and Treasurer (.1) Telephone conference with RSS re updated revised draft of plan, updating projections to conform to draft and need to flush out terms of SBA treatment (.2) Review, test and consider RSS updated plan projections and consider future updates in treatment of ist Secure and SBA claims (.3) Review SBA poc, note and security agreement - update draft of treatment of SBA claim (.4) Meeting with RSS re SBA note, updated draft of terms, modification of 1st Secure and SBA treatment to increase payments, plan projections and updating draft consistent with same (.4) 1.30 8. GKS_ Review LL email and response to revised draft of plan (.1) Telephone conference with RSS re same and updating draft of plan to incorporate amount and terms of repayment for tax claim and SBA (.2) Review, test and consider RSS updated draft of projections (.3) Review RSS updated draft of SBA treament (.3) 0.90 □ B) RDS Meeting with GKS re SBA note, updated draft of terms, modification of st. GKS_ Review LL emails 3:41 am, 5:47 am and comments/corrections of amended plan - RSS and LL emails 4:22 pm through 6:49 and reply email to LL at 7:02 pm (.4) Review and reply to LL 7:09 pm email (.1) 0.50 3: RDS_ Review email from LL with corrections for plan (.1); Update Plan per LL's comments (.2); Reply email to LL in response to her questions with explanation for tax payments and spreadsheet for the same (.2) 0.50 2: □□□ Email to LL re need for her cash flow projections and updated lease spreadsheet 0.10 GKS_ Review LL emails re plan and reply 0.20 1. RDS _ Review email exchange between GKS and LL re plan. 0.10 é nea Daviavs!l | amaile ra attarnays ranrnacnantatinn and nian etatirc ranhs amaile tn

Laytor Statement No:

Hours LL re same 0.30 1 GKS_ Review LL email re LL plan and reply (.2) Review LL responsive email (.1) 0.30 1 RDS _ Review emails between GKS and LL re plan, and why LL's proposal is not in compliance with BK code. 0.20 RDS_ Call to TJacobs ("TJ") to discuss First Secure treatment under plan - left message. 0.10 RDS Continue updating Plan per LL comments/changes. 0.30 1 RDS _ Call with Tina Jacobs discussing First Secure treatment in plan, advised First Secure will not extend loan and wants a 3-5 year maturity or to sell property. 0.20 RDS _ Review email from LL re SBA treatment and update plan re same. 0.30 1 RDS_ Follow up email to TJ request copies of the appraisals. 0.10 GKS_ Meeting with RSS re updated draft of plan per LL comments and instructions - review and revise draft of email to LL transmitting updated draft 0.30 1 (B) RDS Meeting with GKS re updated draft of plan per LL comments and instructions (2); Draft email to LL re same and discussion with First Secure (.1) 0.30 1 Review multiple emails from LL and reply email to LL re same 0.30 1 [2025 RDS Call with Robert Handler re LL plan, discussion of feasibility and hearing 0.20 RDS _ Email to LL re plan, LL need to review, update and sign for filing, discussion of tenant rent roll and operating report (.1); Call with LL re same (.4). 0.50 2 GKS___ Telephone conference with BH re case status, updated draft of plan, feasibility, best interests and confirmation standards 0.60 3 GKS_ Review RSS email to LL re plan status (.1) email to LL re case/plan status, GKS motion to wd and need to file plan (.1) 0.20 1 GKS__ Review RSS email to LL re plan, June MOR and other matters 0.10 □ GKS_ Court - Representation at hearing on debtor's motion to extend time to file plan and GKS motion to withdraw as attorneys for debtor 0.70 4! For Current Services Rendered 38.20 20,2