Joseph J Porada, Jr.
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Opinion
UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: ) ) Case No, 17bk36268 JOSEPH J. PORADA, ) ) Chapter 11 Debtor. ) ). Honorable Tumothy A. Barnes FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO FOX ROTHSCHILD LLP, ATTORNEYS FOR DEBTOR, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $119,609.87 TOTAL COSTS REQUESTED: $917.09 TOTAL FEES REDUCED: $ 9,056.00 TOTAL COSTS REDUCED: $ 8.00 TOTAL FEES ALLOWED: $110,553.87 TOTAL COSTS ALLOWED: $ 909.09 TOTAL FEES AND COSTS ALLOWED: $ 111,462.96 Pursuant to the court’s comments at the hearing on December 18, 2019 on the Final Application of Fox Rothschild LLP for Allowance and Payment of Compensation and Reimbursement of Expenses and for Related Relief [Dkt. No. 127] (the “Application”); the court having heard from Fox Rothschild LLP (“Fex”) and the Debtor and having considered the Debtor’s Objection to the Application [Dkt. No. 131] (the “Objection”) and all related filings to the Application and the Objection; the Objection further only being germane to the Application and not to the prior services previously and finally approved in the absence of an objection; THE COURT HEREBY FINDS AND ORDERS THAT: Attached to this Order is an annotated copy of the invoices submitted by Fox in support of the Application. Where an entry is not annotated, the court finds that the entry meets the requirements for reimbutsement under 11 U.S.C. § 330. Where the attached time and expense entries have been underlined, such annotations reflect disallowance in whole or in part. The basis for cach disallowance is reflected by numerical notations that appear on the right of each underlined entry. The numerical notations correspond to the enumerated paragraphs below.
No party objected to the previous applications of counsel, which were filed by Shaw Fishman Glantz & Towbin LLC (“Shaw’’} and Fox, successor to Shaw via merger. Nonetheless, the court has reviewed and determined the propriety of all prior applications and reduced them in accordance with the applicable standards and practices of this court. See Findings of Fact and Conclusions of Law and Order Granting Compensation for Shaw Fishman Glantz & ‘Towbin LLC, Debtor's Attorney [Dkt. No. 64]; Findings of Fact and Conclusions of Law and Order Granting Compensation for Fox Rothschild LLP, Debtor's Attorney [Dkt. No. 87}.
(1) Unreasonable Time -- TOTAL of disallowed amounts: $ 3,234.00 The majority’ of the Objection concerns the reasonableness of Fox’s discretion in billing the bankruptcy estate for certain tasks performed. The court always examines applications before it for reasonableness and denies compensation for a task to the extent that a professional or paraprofessional expended an unreasonable amount of time on the task in hight of the nature of the task, the experience and knowledge of the professional performing the task, and the amount of time previously expended by the professional or another on the task. Iv re Pettibone, 74 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, }.) (“The Court will determine what is the reasonable amount of tme an attorney should have to spend on a given project... An attorney should not be rewarded for inefficiency. Similarly, attorneys will not be fully compensated for spending an unreasonable number of hours on activities of little benefit to the estate.”); Ia re Wildman, 72 BUR. 700, 713 (Banks. N.D. Ill. 1987) (Schmetterer, J.) (same). Here, the Debtor argues that many tasks should have been billed or performed at a lower cost based on the outcome or current status of the task performed. There are many ways the court examines applications for compensation and the court has repeatedly informed those that practice in front of the court that the court sometimes, absent an objection, is focused on the trees and not the forest—meaning the court looks for issues with respect to individual time entries or categories under the standards applied in this court (lumping, unallowable costs, time increments, etc.). This is due to the nature of interim versus final applications and the ability of the court to use hindsight in the final application. Hindsight and the knowledge of outcome, however, are not always a great determiner of reasonableness of attorney’s compensation. A court must not attempt to determine the reasonableness of time spent by an attorney by looking at the matter solely in hindsight or determining reasonableness by the outcome of the issue or matter. Brandt v. Schal Associates, fue, 131 FR.D. 485, 493 on reconsideration in part, 131 F.R.D. 512 (N.D. Ill. 1990) aff'd, 960 F.2d 640 (7th Cir. 1992) ({I]t would be entirely inappropriate for this Court to hold that the expenditure of time by defense counsel in this area was unreasonable based on any such retrospective and result-oriented approach.”); Koval v. PaineWebber Hous. ¢» Healthcare Funding, Inc, 128 F.R.D. 654, 657 (N.D. IL 1989) (“No court, however experienced in the law practice the judge may have been before taking the bench, can feel comfortable with trying to reconstruct the reasonableness of fees viewed from the outside and in hindsight.”); Hamer v. Lake Cuty., 819 F.2d 1362, 1367 (7th Cit. 1987) (“[]]t ts important that a district court resist the understandable temptation to engage in post hoc reasoning by concluding that, because a plaintiff did not ultimately prevail, his action must have been unreasonable or without foundation. This kind of hindsight logic could discourage all but the most airtight claims, for seldom can a prospective plaintiff be sure of ultimate success.”); Iv re Drexe/ Burnhara Lambert Group, Inc, 133 B.R. 13, 23 (Bankr. $.D.N.Y. 1991) (In determining reasonableness, “the Court must not penalize attommeys by viewing the efforts of counsel with the benefit of ‘20/20 hindsight.’...[H]ours for an activity or project should be disallowed only where a Court is convinced
2 The Objection and the reply in support thereof [Dkt. No. 128] (the “Reply”}, oudine many arguments, but some of the arguments are actually more commentary which the court need not address. For this reason, the court will not consider the Debtor’s arguments considering the frugality of the Debtor, the discussion about the Debtor’s personality and view on lawyers /litigation and the Debtor’s discussion of the view of other parties’ concerning the Application because no other parties have objected to the Application.
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it is readily apparent that no reasonable attorney should have undertaken that activity or project or where the time devoted was excessive.”). In this case, the Objection focuses on three tasks that the Debtor views as unreasonable. The court has examined the Application in its entirety and in hght of the Objection, and the coutt will address each of the tasks, in turn: i Operating Reports: In the Application, Fox seeks $7,286.00 for the filing of operating reports. 10 operating reports were filed by Fox during the Application period for an average of $728.60/ operating report. The Debtor argues that Fox’s fees for pteparation of operating reports ate not reasonable and that Fox, as a larger firm than Debtor’s current counsel, should have used better discretion in billing a smaller amount for this task. Further, Debtor's current counsel argues that he is charging only $200.00 per report. In fact, many of the Debtor’s arguments are attacks on Fox’s billing practices predicated on the allegations of the Debtor’s current counsel that he could have performed the work in a less expensive manner. However, Fox and the Debtot’s current counsel’s firm ate two very different sized firms and charge different rates for their work performed.
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UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: ) ) Case No, 17bk36268 JOSEPH J. PORADA, ) ) Chapter 11 Debtor. ) ). Honorable Tumothy A. Barnes FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO FOX ROTHSCHILD LLP, ATTORNEYS FOR DEBTOR, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $119,609.87 TOTAL COSTS REQUESTED: $917.09 TOTAL FEES REDUCED: $ 9,056.00 TOTAL COSTS REDUCED: $ 8.00 TOTAL FEES ALLOWED: $110,553.87 TOTAL COSTS ALLOWED: $ 909.09 TOTAL FEES AND COSTS ALLOWED: $ 111,462.96 Pursuant to the court’s comments at the hearing on December 18, 2019 on the Final Application of Fox Rothschild LLP for Allowance and Payment of Compensation and Reimbursement of Expenses and for Related Relief [Dkt. No. 127] (the “Application”); the court having heard from Fox Rothschild LLP (“Fex”) and the Debtor and having considered the Debtor’s Objection to the Application [Dkt. No. 131] (the “Objection”) and all related filings to the Application and the Objection; the Objection further only being germane to the Application and not to the prior services previously and finally approved in the absence of an objection; THE COURT HEREBY FINDS AND ORDERS THAT: Attached to this Order is an annotated copy of the invoices submitted by Fox in support of the Application. Where an entry is not annotated, the court finds that the entry meets the requirements for reimbutsement under 11 U.S.C. § 330. Where the attached time and expense entries have been underlined, such annotations reflect disallowance in whole or in part. The basis for cach disallowance is reflected by numerical notations that appear on the right of each underlined entry. The numerical notations correspond to the enumerated paragraphs below.
No party objected to the previous applications of counsel, which were filed by Shaw Fishman Glantz & Towbin LLC (“Shaw’’} and Fox, successor to Shaw via merger. Nonetheless, the court has reviewed and determined the propriety of all prior applications and reduced them in accordance with the applicable standards and practices of this court. See Findings of Fact and Conclusions of Law and Order Granting Compensation for Shaw Fishman Glantz & ‘Towbin LLC, Debtor's Attorney [Dkt. No. 64]; Findings of Fact and Conclusions of Law and Order Granting Compensation for Fox Rothschild LLP, Debtor's Attorney [Dkt. No. 87}.
(1) Unreasonable Time -- TOTAL of disallowed amounts: $ 3,234.00 The majority’ of the Objection concerns the reasonableness of Fox’s discretion in billing the bankruptcy estate for certain tasks performed. The court always examines applications before it for reasonableness and denies compensation for a task to the extent that a professional or paraprofessional expended an unreasonable amount of time on the task in hight of the nature of the task, the experience and knowledge of the professional performing the task, and the amount of time previously expended by the professional or another on the task. Iv re Pettibone, 74 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, }.) (“The Court will determine what is the reasonable amount of tme an attorney should have to spend on a given project... An attorney should not be rewarded for inefficiency. Similarly, attorneys will not be fully compensated for spending an unreasonable number of hours on activities of little benefit to the estate.”); Ia re Wildman, 72 BUR. 700, 713 (Banks. N.D. Ill. 1987) (Schmetterer, J.) (same). Here, the Debtor argues that many tasks should have been billed or performed at a lower cost based on the outcome or current status of the task performed. There are many ways the court examines applications for compensation and the court has repeatedly informed those that practice in front of the court that the court sometimes, absent an objection, is focused on the trees and not the forest—meaning the court looks for issues with respect to individual time entries or categories under the standards applied in this court (lumping, unallowable costs, time increments, etc.). This is due to the nature of interim versus final applications and the ability of the court to use hindsight in the final application. Hindsight and the knowledge of outcome, however, are not always a great determiner of reasonableness of attorney’s compensation. A court must not attempt to determine the reasonableness of time spent by an attorney by looking at the matter solely in hindsight or determining reasonableness by the outcome of the issue or matter. Brandt v. Schal Associates, fue, 131 FR.D. 485, 493 on reconsideration in part, 131 F.R.D. 512 (N.D. Ill. 1990) aff'd, 960 F.2d 640 (7th Cir. 1992) ({I]t would be entirely inappropriate for this Court to hold that the expenditure of time by defense counsel in this area was unreasonable based on any such retrospective and result-oriented approach.”); Koval v. PaineWebber Hous. ¢» Healthcare Funding, Inc, 128 F.R.D. 654, 657 (N.D. IL 1989) (“No court, however experienced in the law practice the judge may have been before taking the bench, can feel comfortable with trying to reconstruct the reasonableness of fees viewed from the outside and in hindsight.”); Hamer v. Lake Cuty., 819 F.2d 1362, 1367 (7th Cit. 1987) (“[]]t ts important that a district court resist the understandable temptation to engage in post hoc reasoning by concluding that, because a plaintiff did not ultimately prevail, his action must have been unreasonable or without foundation. This kind of hindsight logic could discourage all but the most airtight claims, for seldom can a prospective plaintiff be sure of ultimate success.”); Iv re Drexe/ Burnhara Lambert Group, Inc, 133 B.R. 13, 23 (Bankr. $.D.N.Y. 1991) (In determining reasonableness, “the Court must not penalize attommeys by viewing the efforts of counsel with the benefit of ‘20/20 hindsight.’...[H]ours for an activity or project should be disallowed only where a Court is convinced
2 The Objection and the reply in support thereof [Dkt. No. 128] (the “Reply”}, oudine many arguments, but some of the arguments are actually more commentary which the court need not address. For this reason, the court will not consider the Debtor’s arguments considering the frugality of the Debtor, the discussion about the Debtor’s personality and view on lawyers /litigation and the Debtor’s discussion of the view of other parties’ concerning the Application because no other parties have objected to the Application.
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it is readily apparent that no reasonable attorney should have undertaken that activity or project or where the time devoted was excessive.”). In this case, the Objection focuses on three tasks that the Debtor views as unreasonable. The court has examined the Application in its entirety and in hght of the Objection, and the coutt will address each of the tasks, in turn: i Operating Reports: In the Application, Fox seeks $7,286.00 for the filing of operating reports. 10 operating reports were filed by Fox during the Application period for an average of $728.60/ operating report. The Debtor argues that Fox’s fees for pteparation of operating reports ate not reasonable and that Fox, as a larger firm than Debtor’s current counsel, should have used better discretion in billing a smaller amount for this task. Further, Debtor's current counsel argues that he is charging only $200.00 per report. In fact, many of the Debtor’s arguments are attacks on Fox’s billing practices predicated on the allegations of the Debtor’s current counsel that he could have performed the work in a less expensive manner. However, Fox and the Debtot’s current counsel’s firm ate two very different sized firms and charge different rates for their work performed. This part of the Objection appears, in large part, to be an attempt to re-trade on the Debtor’s choice of Shaw and then Fox to represent him. The Debtor should not be permitted to avail himself of the services of a firm of Shaw’s and Fox’s nature and then later bargain down the cost of such services to the rates of a smaller firm. The Debtor chose Shaw and continued to work with counsel when Shaw merged into Fox. The Debtor did not object to any of the prior applications of Shaw or Fox and was aware through those applications and the biling of Shaw prior to the commencement of this case of the costs that followed the Debtor’s choice. That the Debtor’s current counsel may charge less does not mean that the amounts billed by Fox for work performed are unreasonable. The court does not view the cost of $728.60 per report for the Application period as unreasonable. Counsel has a duty to ensure the accuracy and completeness of the reports and the propriety of the disclosures contained therein’ before filing them, and has a duty to advise clients regarding the same. The amount sought per report equates to 2-4 hours per report (2+ for partner rates and 4 for associate rates in this case), which seems appropriate in light of the complexity of this case to complete such review and communications with the Debtor. For these reasons, the amounts charged by Fox in preparing operating reports are reasonable amounts and the court will not reduce the Application on this basis. i. ‘The Debtor’s adversary against Robert Fisher: In the Application, Fox seeks $37,064.50 for work done in connection with the Debtor's adversary proceeding 3 The need to review such reports is underscored by the operating report filed by Debtor’s current counsel. Tt contains a bank statement of the Debtor which contains personal information. More time spent reviewing the operating report would likely have helped avoid this inadvertent disclosure and the cost associated with fixing this issue through a motion to redact, which the court expects counsel to file forthwith.
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against Robert Fisher (the “Fisher Adversary”). ‘The Fisher Adversary seeks to recover funds allegedly owed to the Debtor via alleged interests in real property. Fox argues that it was required to research whether the alleged notes that the Debtor held against Fisher were able to be foreclosed on as “there is no mortgage or any document containing a granting clause whereby Mr. Fisher expressly granted a lien to the Debtor.” Therefore, Fox argues it had to research whether the notes would qualify as a mortgage under IL law. Fox states that it received permission from the Debtor to do the required research before filing the adversary complaint. In his Reply, the Debtor again argues that because of the size of Fox, someone should have known the law in this area and no research should have been done more than to “freshen up” their knowledge. This is an unreasonable position. No matter the size of a firm, there is no guarantee that the firm will have an expert well versed in every nuance of every law. Absent a well-founded reason to consider otherwise, the court considers research into applicable law a category for which compensation may be sought in this context. The question remains whether the time spent is reasonable. The court reviewed the time entries in question and does not find any unreasonable work or research performed under the facts of this case and in light of the arguments of the patties. The court therefore declines to reduce the Application for work performed by Fox on the Fisher Adversary as unreasonable. in. = The sale of the Debtor’s condominium: The Debtor’s only postpetition recovery from liquidation of assets is the $125,000.00 sale of a condominium that is owned by a trust to which the Debtor is the sole beneficiary. The Debtor abandoned the condominiutn almost 20 years ago and the condominium association has been in possession and managed it since June 1999. Shaw and Fox worked through the unwinding of the rights of the Debtor and the condominium association with respect to the condominium and in February 2019, during the period of work that the Application seeks compensation for, the Debtor sold the condo for $125,000.00. The Debtor also recovered $45,000.00 from funds held by the condominium association for the time it managed the condominium. In the Application, Fox seeks $25,380.50 for its work done to close the sale, In supporting the compensation sought for this task, Fox argues that much more work had to be done to close the sale of the condominium than a normal sale {or more than the Debtor remembers) because the condominium association continued to assert legal fees in this case, including in the closing sale statements, and that this threatened the sale, causing much more negotiations to occur. Further, Fox claims that the Debtor was not responding to the court-approved broker and thus Fox continually had to contact the Debtor and act ask as an intermediary in order to close the sale. Fox did not charge for all of these “intermediary” communications, but some were charged as they were due to the Debtor’s failure to respond to the broker, Last, Fox argues that the Debtor was to unresponsive to Fox as well, causing many more communications to occur than necessary.
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The Debtor argues that Fox, as a large firm, and “whose bankruptcy section should not have been re-inventing the wheel to prepare for and bring a small value condominium transaction to closing, ... should not be awarded fees so wholly out of touch with the condominium closing market.” ‘The Debtor, however, points to no time entries are unreasonable on their face, only that the total amount charged is too high in relation to the recovery. Ultimately, the Debtor argues that the fees seem unreasonable in the Debtor’s current counsel’s opinion, but that it is the court’s opinion that counts. The court agrees that the amount sought by Fox for the sale of the condominium are high in relation to the recovery, but cautions that any recovery at all given the Debtor’s abandonment is a benefit to the estate. The court has examined the Application with respect to the Debtor’s arguments about communication with the Debtor and the court declines to reduce the Application for this portion of the condominium sale task because the comments from Fox regarding the Debtor’s communication, or lack thereof, are supported by the record of this case. The Debtor’s failure to communicate with the broker and to selectively respond to certain parties at Fox caused needless layers of communication and those layers compound fees. Having reviewed all of the billing by Fox in this category, the court finds only one area of the condominium sale task where Fox’s fees appear unreasonable. For the work done in the actual writing and filing of the motion to sale—not considering any other work such as negotiations with the Debtor, the condominium association and the buyer or the investigation of the rights of the preceding——Fox seeks $6,468.00. This is extraordinary even in light of the challenges of this particular transaction. For this reason, the court reduces all entries for the drafting and resolution of the motion to sell by 50%. This results in a $3,234.00 reduction in the Application. (2) Computational or Typographical Virror — TOTAL of disallowed amounts: $ 2,447.00 The court denies the allowance of compensation for the following tasks because the amount of fees appears to be a computational or typogtaphical error. Also, where there are two identical entries (same day, same tasks, same time billed), the court will consider one of the entries to be a typographical error. The court finds one entry that appears to be a duplicate and many entries where, without explanation, different counsel billed different times for attending the same conferences. In such instances, the court always reduces all inconsistent time entries to the lowest time billed for the conference and has done so here. (3) Local Travel ~ TOTAL of disallowed amounts: $ 1,617.00 in compensation and $8.00 in expenses As the court has done in previous applications in this case, the court declines to compensate counsel for the time it travels to the court for hearings. The court will not allow the $1,617.00
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sought by Mr. Banich for such time at his full rate and will again caution him that seeking compensation for local, in town travel time to court is not permissible in this coutt. As the Court also denies the allowance of reimbursement for expenses that were not actually and necessarily incurred by the applicant, see 11 U.S.C. §§ 330(a)(1)(B) & 331, the court also denies the costs for such travel as no support was offered to demonstrate the necessity for taking paid transportation under the circumstances (bringing exhibits to court, weather, etc.). As the Application did not state any such circumstances, the $8.00 for a local taxi is not allowed. (4) No Benefit to the Estate - TOTAL of disallowed amounts: $ 637.00 The court also denies requests for fees relating to services that do not benefit the estate or that are not necessary to the administration of the case. 11 U.S.C. § 330(a}(4)(A). In this circumstance and throughout cases before this court, the court does not approve expenses for counsel reconciling their fees with their client or in taking actions solely with respect to their own compensation. Such js a benefit to the counsel, not the bankruptcy estate. Baker Botts LLP. », ASARCO LLC, 135 S. Ct. 2158, 2167 (2015). (5) Overhead Costs are Non-Compensable — TOTAL of disallowed amounts: $ 271.00 The Court denies reimbursement for fees or expenses that are overhead costs. The determination of who would cover a hearing is a business task and is incidental to the personnel and management of a business. The bankruptcy estate should not be required to pay for counsel to manage their schedules. (6) Insufficient Description — TOTAL of disallowed amounts: $ 850.00 The Court denies the allowance of compensation for the indicated task(s) as the description of each task fails to identify in a reasonable manner the service rendered. In se Pettibone, 74 BR. 293, 301 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“A proper fee application must list each activity, its date, the attorney who performed the work, a description of the nature and substance of the work performed, and the time spent on the work. [Citation omitted] Records which give no explanation of the activities performed are not compensable.”); fa re Wildman, 72 B.R. 700, 708-09 (Bankr. N.D. IH. 1987) (Schmetterer, J.) (same). In this case, generic time entry regarding closing matters do not provide the detail required to allow the court to determine what was done to benefit the bankruptcy estate. WB Dated: December 23, 2019 ne eo — Timothy A. Barnés United States Bankruptcy Judge
Fox Rothschi Id up ATTORNEYS AT LAW 321 N. Clark St., Suite 1606, Chicago, fl. 60654 Tel 342.647.9200 Fax 312.517.9201 www.foxrothschild.com
AX LD. NO. 23-1404723 FS gene AX 1D, NO. 23-1404723 JOSEPH PORADA, M.D. invoice Number 2443160 640 W. 57TH ST. Invoice Date 10/18/19 CLARENDON HILLS, IL 60525 Client Number 250172 Matter Number 00001 RE: CHAPTER 11 BANKRULPTCY FOR PROFESSIONAL SERVICES RENDERED THROUGH 09/30/19: tt Date Timekeeper Description Hours Amount nr COMMUNICATIONS WITH US TRUSTEE 01/31/19 TGB REVIEWED CORRESPONDENCE FROM S. 0.1 $49.00 WOLFE RE COMMENTS TO BAR-DATE MOTION (1); DISCUSSED SAME WITH A. GUON (NIC). 02/05/19 TGB TELEPHONE CONFERENCE WITH S, WOLEE 0.2 $98.00 RE BAR-DATE MOTION AND MOTION TO SELL CONDO AND TERMS OF SAME, 03/13/19 TGB TELEPHONE CONFERENCE WITH S. WOLFE 0.3 $147.00 RE COMMENTS TO FEE APPLICATION. 05/30/19 TGB REVIEWED AND EXCHANGED 0.1 $49.00 CORRESPONDENCE RE OUTSTANDING UST FEES, TGB TELEPHONE CONFERENCE WITH S. WOLFE 6.2 $103.00 RE REQUESTED EXTENSION OF TIME TO FILE PLAN AND DISCLOSURE STATEMENT. TGB DRAFTED CORRESPONDENCE TO S. WOLFE 0.1 $51.50 RE AMENDED MOTION TO EXTEND THE. TGB TELEPHONE CONFERENCE WITH S. WOLFE 0.4 $206.00 RE AMENDED MOTION TO EXTEND TIME AND BASIS FOR SAME. 08/20/19 TGB REVIEWED CORRESPONDENCE FROM US 0.1 $51.50 TRUSTEE'S OFFICE RE FIRST MIDWEST BANK ACCOUNT, TGB TELEPHONE CONFERENCE WITH S, WOLFE 0.2 $103.00 OF US TRUSTEE'S OFFICE RE DEBTOR'S TERMINATION OF REPRESENTATION. SUBTOTAL: COMMUNICATIONS WITH US TRUSTEE 1.7 $858.00
IIR EE □ ' En Date Timekeeper Description Hours Amount rr tT COMMUNICATIONS/MEETINGS WITH DEBTOR 01/02/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 RE UPDATE RE CONDO WORK. 01/03/19 TGB REVIEWED MESSAGE FROM J. PORADA., 0.4 $49.00 01/04/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 02 $98.00 RE CONDO, SUGGESTED LIST PRICE AND PAYMENT OF CONTRACTORS. TGB TELEPHONE CONFERENCE WITH J. PORADA 0.8 $294.00 RE FISHER ADVERSARY AND MEETING TO DISCUSS SAME AND PLAN PROCESS. 01/08/19 TGB DRAFTED LENGTHY CORRESPONDENCE AND 0.8 $392.00 ANALYSIS TO J. PORADA RE POTENTIAL FORECLOSURE CLAIM AND SUMMARIZE TELEPHONE CONFERENCE WITH FISHER'S LAWYER. 01/09/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.1 $49.00 PORADA RE JANUARY 12 STRATEGY MEETING. 01/40/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 RE AGENDA FOR JANUARY 12 MEETING. 01/11/49 TGB EXCHANGED CORRESPONDENCE WITH J. 0.8 $392.00 PORADA RE JANUARY 12 MEETING (1): DRAFTED CORRESPONDENCE TO J. PORADA RE FISHER SETTLEMENT OFFER (2), PREPARED FOR JANUARY 12 MEETING J. PORADA (.5). 01/12/19 TGB CONTINUED PREPARING FOR JANUARY 12 2.5 $1,225.00 MEETING J. PORADA (.5); MET WITH J. PORADA RE CHAPTER 11 PLAN PROCESS GOING FORWARD AND RELATED MATTERS (2.0). 01/15/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.3 $147.00 RE CONDO OFFER AND RELATED MATTERS, 01/16/19 TGB DRAFTED LENGTHY EXPLANATORY 11 $539.00 CORRESPONDENCE TO J. PORADA RE AMENDED FISHER COMPLAINT AND STRATEGIES IN CONNECTION WITH SAME. TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 RE ESTIMATED VALUE OF FISHER PROPERTY. PF PHONE CALL AND CONFIRMATION EMAIL TO 0.5 $115.00 DR. PORADA REGARDING NEED FOR RESPONSE TO OFFER AND EMAIL TO CONFIRM HIS COUNTER OFFER ON CONDO SALE (.4). CONFER WITH DR. PORADA REGARDING NEED FOR APPROVAL OF DECEMBER OPERATING REPORT (.1). 01/18/49 TGB TELEPHONE CONFERENCE WITH M. ORTEGA 04 $196.00 RE CONDO COUNTEROFFER AND TELEPHONE CONFERENCE WITH J. PORADA RE SAME. Page 2
IIR EE : TT TT □□□ re Date Timekeeper Description Hours Amount rr 01/22/19 TGB DRAFTED LENGTHY EXPLANATORY 0.6 $294.00 CORRESPONDENCE TO J. PORADA RE AMENDED FISHER COMPLAINT AND STRATEGIES RE SAME. 01/23/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.1 349.00 PORADA RE FISHER REAL ESTATE HOLDINGS IN WISCONSIN, 01/24/19 TGB DRAFTED ANALYSIS OF RFREINV, LLC ISSUES 0.7 $343.00 AND POTENTIAL STRATEGIES VIS A VIS FISHER LITIGATION TO J. PORADA. 01/25/19 TGB TELEPHONE CONFERENCES WITH J. PORADA 0.7 $343.00 RE CONDO SALE NEGOTIATIONS AND RELATED MATTERS (.4); EXCHANGED CORRESPONDENCE WITH J. PORADA RE NEW FISHER SETTLEMENT OFFER (2); EXCHANGED CORRESPONDENCE WITH J. PORADA RE ANALYSIS OF RFREINV, LLC REAL ESTATE HOLDINGS iN WISCONSIN (.1). 01/28/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.8 $392.00 ATTACHING LATEST INVOICES FROM COUNTRY ACRES (.1); DRAFTED CORRESPONDENCE TO J. PORADA RE FILED BAR DATE MOTION (.2); REVIEWED AND EXCHANGED CORRESPONDENCE WITH J. PORADA RE COUNTY ACRES’ IMPOSITION OF ITS LEGAL FEES ON HIM AND OBJECTING TO SAME (.5). 01/29/19 TGB REVIEWED TRANSCRIPT OF COUNTRY 15 $735.00 ACRES' 2004 EXAMINATION RE ASSESSMENT OF LEGAL FEES TO J. PORADA AND DRAFTED ANALYSIS OF SAME TO J. PORADA (.9); DRAFTED CORRESPONDENCE TO J. PORADA RE LEGAL FEES ASSESSED BY CONDO ASSOCIATION (.1); TELEPHONE CONFERENCE WITH J. PORADA RE CONDO SALE, SALE MOTION, COUNTY ACRES LEGAL FEES ASSESSMENT DISPUTE, FISHER LITIGATION AND PLAN PROCESS (.5). TGB DRAFTED CORRESPONDENCE TO J. PORADA 01 NO CHARGE REQUESTING APPROVAL OF DRAFT SALE MOTION AND RELATED MATTERS (N/C); 02/01/19 TGB REVIEWED CORRESPONDENCE FROM J. 1.3 $637.00 PORADA RE CONDO SALE AND DISCUSSION WITH M. ORTEGA (.2); DRAFTED CORRESPONDENCE TO J. PORADA RESPONDING TO SAME AND REQUESTING APPROVAL OF SALE MOTION (.8); DRAFTED CORRESPONDENCE TO J. PORADA RE FISHER LITIGATION UPDATE/STRATEGIES, AND VIS PENDENS RECORDATION (2); DRAFTED CORRESPONDENCE TO J. PORADA RE SALE MOTION (.1). 02/04/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.6 $294.00 RE SAME AND SUGGESTED STRATEGIES WITH REGARD TO COUNTRY ACRES FEE Page 3
OO EEE a ‘ Lt rr A Date Timekeeper Description Hours Amount DISPUTE. TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.4 $196.00 RE ATTORNEY REVIEW LETTER FROM CONDO BUYER AND NEXT STEPS (.2); REVIEWED CORRESPONDENCE FROM J. GOLDSTONE TO J. PORADA RE ISSUES NEEDING RESPONSES FOR RESPONSE TO ATTORNEY REVIEW LETTER (.2). O2/07/19 JLG DRAFT RESPONSE COMMENTS AND EMAIL TO 0.5 $212.56 CLIENT RE: RESPONSE TO ATTORNEY REVIEW AND INSPECTION ISSUES. 02/08/19 JLG TC TO DR. PORADA TO REVIEW ATTORNEY 0.4 $42.50 REVIEW ISSUES AND BUYER'S INSPECTION REQUESTS. 02/41/19 TGB REVIEWED J. GOLDSTONE 0.9 $441.00 CORRESPONDENCE TO J. PORADA RE SAME (.2); DRAFTED CORRESPONDENCE TO J. PORADA RE UPDATES AND NEXT STEPS IN BANKRUPTCY CASE (.7). 02/11/19 JLG TELEPHONE CONFERENCE TO DR, PORADA 0.1 $42.50 RE: ATTORNEY REVIEW LETTER. LEFT VOICEMAIL 02/11/19 JLG DRAFT AND SEND EMAIL TO DR. PORADA RE: 0.2 $85.00 ATTORNEY REVIEW LETTER RESPONSES. TGB REVIEWED J. GOLDSTONE'S 0.1 $49.60 CORRESPONDENCE TO J. PORADA RE ATTORNEY REVIEW LETTER. 02/14/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.3 $147.00 RE UPDATES RE CONDO SALE ORDER AND FISHER ADVERSARY. 02/20/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.2 $98.00 ANALYZING FISHER SETTLEMENT DISCUSSIONS AND REQUESTING INSTRUCTIONS RE SAME, 02/22/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 REQUESTING THOUGHTS ON J. SHIMOTAKE'S EMAIL RE FISHER ADVERSARY/SETTLEMENT DISCUSSIONS. 02/24/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.1 $49.00 PORADA RE J. SHIMOTAKE'S EMAIL RE FISHER ADVERSARY/SETTLEMENT DISCUSSIONS. 02/26/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 1.6 $490.00 RE SUGGESTED RESOLUTION OF DISPUTE WITH CACHA RE PASSED THROUGH LEGAL FEES ON PAID ASSESSMENT LETTER (.5}: REVIEWED J. PORADA'S RESPONSE THERETO (1); DRAFTED RESPONSE TO J. PORADA'S EMAIL SUGGESTING STRATEGIES WITH REGARD TO CACHA ASSERTED LEGAL FEES (4). 02/27/19 TELEPHONE CONFERENCE WITH J. PORADA 0.7 $343.00 Page 4
OEE EEO a rt tt tt Date Timekeeper Description Hours Amount RE SUGGESTED RESOLUTION OF DISPUTE WITH CACHA RE PASSED THROUGH LEGAL FEES ON PAID ASSESSMENT LETTER AND RE STRATEGIES IN FISHER ADVERSARY PROCEEDING (.6); DRAFTED CORRESPONDENCE TO J. PORADA CONFIRMING DECISIONS WITH REGARD TO CACHA ASSERTED LEGAL FEES AND FISHER ADVERSARY (.1}, 03/04/19 TGB REVIEWED CORRESPONDENCE FROM J. 1.0 $490.00 PORADA RE VARIOUS MATTERS (.2}; DRAFTED CORRESPONDENCE TO J. PORADA RE POINTS IN EARLIER EMAIL AND ATTACHING INVOICE AND DRAFT FEE APPLICATION (.8}. 03/08/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.5 $245.00 PORADA AND J. GOLDSTONE RE CLOSING DATE (.2); DRAFTED CORRESPONDENCE TO J. PORADA RE UPDATES (.3). 03/14/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.3 $147.00 RE ANALYSIS, SUGGESTED NEXT STEPS OF FISHER'S ANSWER TO AMENDED COMPLAINT AND SETTLEMENT OFFER RECEIVED. 03/15/19 TGB TELEPHONE CONFERENCE WITH J. PORADA 0.7 $343.00 RE STATUS AND STRATEGIES FOR CHAPTER 11 CASE, CONDO SALE, FISHER ADVERSARY, FEE APPLICATION AND PLAN PROCESS. 03/18/19 TGB TELEPHONE CONFERENCE WITH J. PORADA 1.0 $490.00 RE CONDO SALE PROCEEDS, FEE APPLICATION RESOLUTION AND FISHER ADVERSARY PROCEEDING (.7); DRAFTED CORRESPONDENCE TO J. PORADA CONFIRMING AGREEMENTS RE SAME (.3). 03/19/19 TGB REVIEWED CORRESPONDENCE FROM J. 04 $49.00 PORADA RE FISHER ADVERSARY. 03/22/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.5 $245.00 RE FEES PAYABLE TO FIRM AND AMOUNT REFUNDABLE TO HIM FOLLOWING CONDO SALE, AND CALCULATION OF SAME. 04/03/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.4 $49.00 PORADA RE VARIOUS MATTERS AND NEXT STEPS. 04/05/19 TGB TELEPHONE CONFERENCE WITH J. PORADA 0.8 $392.00 RE STATUS OF VARIOUS MATTERS. 04/12/19 TGB TELEPHONE CONFERENCE WITH J. PORADA O45 $245.00 RE VARIOUS MATTERS AND NEXT STEPS. 04/15/19 TGB TELEPHONE CONFERENCE WITH J. PORADA 0.2 $98.00 RE TAX ISSUES AND FISHER ADVERSARY, 04/26/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 RE FISHER ADVERSARY. 05/13/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $49.00 REQUESTING DIRECTION RE FISHER Page 5
RE a Date Timekeeper Description Hours Amount ADVERSARY IN ADVANCE OF STATUS HEARING. 05/14/19 TGB TELEPHONE CONFERENCE WITH J. PORADA 0.3 $147.00 RE FISHER ADVERSARY, STRATEGIES AND NEXT STEPS. 05/21/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.6 $294.00 RE MAY 25 HEARING (.2); DRAFTED CORRESPONDENCE TO J. PORADA RE RESULTS OF HEARING AND DEADLINES SET BY COURT (.2); TELEPHONE CONFERENCE WITH J. PORADA RE SAME (.2). 05/25/19 SBT MEETING IN NORTHBROOK OFFICE WITH 15 $1,125.00 CLIENT AND T. BANICH TO REVIEW CLIENT OPTION OF CONVERTING CASE TO CHAPTER 7 OR PROCEEDING TO TRY AND CONFIRM PLAN AND TO DISCUSS COSTS, BURDENS AND BENEFITS OF EACH COURSE OF ACTION. 05/25/19 TGB MET WITH J. PORADA AND S. TOWBIN RE 15 $735.00 POTENTIAL CHAPTER 11 PLAN AND STRATEGIES GOING FORWARD. 06/02/19 TGB REVIEWED AND EXCHANGED 0.2 $103.00 CORRESPONDENCE RE FURTHER STRATEGY MEETING WITH J. PORADA. 06/11/19 TGB § MET WITH J. PORADA AND S. TOWBIN RE 17 $875.50 (2) Typo PLAN CONCEPTS, STRATEGIES AND TASKS. 06/12/19 SBT PARTICIPATE IN CLIENT MEETING TO 1.3 $1,040.00 Towbin DISCUSS PLAN AND RELATED ISSUES. time for 06/12/19 TGB DRAFTED SUMMARY OF SETTLEMENT POINTS 0.9 $463.50 □□□ RE FISHER ADVERSARY FOR J. PORADA'S □□□□□□□□□ REVIEW AND APPROVAL. 06/18/19 TGB DRAFTED RESPONSE TO J. PORADA RE 0.9 $463.50 FISHER SETTLEMENT ANALYSIS. 06/19/19 TGB DRAFTED ANALYSIS FOR J. PORADA OF 0.6 $309.00 FISHER SETTLEMENT TERMS IN LIGHT OF TERMS OF ASSIGNMENT INSTRUMENT, AND REVIEWED J. PORADA'S RESPONSE TO SAME. 06/25/19 TGB REVIEWED CORRESPONDENCE FROM J. 3.4 $1,751.00 PORADA ASKING VARIOUS QUESTIONS (5): REVIEWED DRAFT INVOICE AND PRIOR CORRESPONDENCE WITH J. PORADA TO PREPARE ANSWERS TO SAME (.6): DRAFTED LENGTHY RESPONSE TO J. PORADA'S EMAIL OF JUNE 23 (1.5); REVIEWED RFREINV, LLC OPERATING AGREEMENT AND AMENDMENT THERETO IN PREPARATION FOR DRAFTING RESPONSE TO J. PORADA EMAIL OF JUNE 19 RE FISHER SETTLEMENT TERMS (.3); DRAFTED RESPONSE TO J. PORADA EMAIL OF JUNE 19 RE FISHER SETTLEMENT TERMS (4); REVIEWED J. PORADA'S RESPONSE THERETO AND CONSIDERED NEXT STEPS (.1). 06/26/19 TGB DRAFTED AND EXCHANGED 0.5 $257.50 CORRESPONDENCE WITH J. GOLDSTONE RE Page 6
IIR EE a I Date Timekeeper Description Hours Amount ANSWERS TO J. PORADA'S QUESTIONS RE CERTAIN LINE ITEMS ON CLOSING STATEMENT FOR CONDO (.2): DRAFTED CORRESPONDENCE TO J. PORADA RE SAME (1), DRAFTED CORRESPONDENCE TO J. PORADA ACKNOWLEDGING HIS DIRECTION TO CONVEY SETTLEMENT TERMS TOR. FISHER (.1}; DRAFTED CORRESPONDENCE TO J. PORADA FORWARDING SETTLEMENT CORRESPONDENCE TO R. FISHER'S COUNSEL (.1). TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.1 $51.50 REQUESTING UPDATE RE SECTION 1429(A)(15) CALCULATIONS. TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.4 $206.00 RE STATUS OF FISHER SETTLEMENT DISCUSSIONS (.1}; DRAFTED CORRESPONDENCE TO J. PORADA RE DRAFT CHAPTER 11 PLAN (.3), O7/11/19 TGB DRAFTED AND EXCHANGED 0.4 $206.00 CORRESPONDENCE WITH J. PORADA RE FILED MOTION TO EXTEND TIME, IMPORTANCE OF FILING THOSE PAPERS WITHIN THE COURT-ORDERED DEADLINE AND FISHER LITIGATION. O7/12/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.3 $154.50 RE DISCUSSIONS WITH J. WORTHEN RE TAX ISSUES. TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.4 $206.00 RE SURGERY AND REQUEST FOR 60-DAY EXTENSION OF TIME (.3); DRAFTED CORRESPONDENCE TO J. PORADA RE MOTION FOR EXTENSION OF TIME (.1). O7/47/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.6 $309.66 RE RESULTS OF HEARING. TGB DRAFTED CORRESPONDENCE TO J. PORADA 02 $103.00 REQUESTING COMMENTS/DIRECTION RE PLAN AND DISCLOSURE STATEMENT. 09/03/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.8 $412.00 PORADA RE PLAN AND DISCLOSURE STATEMENT ISSUES (.3}; DRAFTED LENGTH RESPONSES TO SAME (.5). 09/10/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.7 $360.50 PORADA TERMINATING REPRESENTATION (.1); DRAFTED CORRESPONDENCE TO J. PORADA RE TRANSITION OF REPRESENTATION (.6). SUBTOTAL: COMMUNICATIONS/MEETINGS WITH DEBTOR 42.0 $21,438.00 COUNTRY ACRES MATTERS 01/02/19 TGB TELEPHONE CONFERENCE WITH M. ORTEGA 0.5 $245.00 RE CONDO REFRESH/REPAIR/SALE (.3): EXCHANGED CORRESPONDENCE WITH M. Page 7
IIR EE a : A I Date Timekeeper Description Hours Amount 01/04/19 TGB REVIEWED 3D TOUR OF REFRESHED CONDO. 0.1 $49.00 TGB REVIEWED CONDO LISTING DOCUMENTS (.6); 1.6 $784.00 REVIEWED DETAILED UPDATE CORRESPONDENCE FROM M. ORTEGA (,3); LENGTHY TELEPHONE CONFERENCE WITH M. ORTEGA RE SAME, POTENTIAL BUYER AND MARKETING STRATEGIES (.7}. 01/08/19 TGB REVIEWED LENGTHY REPORT FROM M. 0.3 $147.00 ORTEGA RE MARKETING OF CONDO AND REVIEWED ATTACHED CONSTRUCTION INVOICES FOR REFRESH WORK. TGB TELEPHONE CONFERENCE WITH M. ORTEGA 0.3 $147.00 RE CONDO MARKETING AND POTENTIAL NEW OFFER. 01/14/19 TGB DRAFTED LETTER TO M. ORTEGA ENCLOSING 0.2 $98.00 CHECK FOR CONSTRUCTION WORK. O1/15/19 TGB REVIEWED COUNTRY ACRES’ 2018 ANNUAL 0.4 $196.00 REPORT (.1}); TELEPHONE CONFERENCE WITH M. ORTEGA RE OFFER RECEIVED FOR CONDO AND RELATED MATTERS (.3). TGB CONFERRED WITH P. FREDERICKS RE HER 0.9 $441.00 DISCUSSIONS WITH J. PORADA RE CONDO COUNTEROFFER (.2); TELEPHONE CONFERENCE WITH M. ORTEGA RE POTENTIAL NEW OFFER FOR CONDO (3): REVIEWED M. ORTEGA'S CORRESPONDENCE TO J. PORADA RE CONDO OFFERS (.2); REVIEWED AND EDITED P. FREDERICKS' CORRESPONDENCE TO J. PORADA RE AUTHORITY TO NEGOTIATE FOR SALE OF CONDO (.2), PF MANY CONVERSATIONS WITH T. BANICH 0.4 $92.00 REGARDING OFFER RECEIVED ON CONDO AND NEED FOR RESPONSE FROM DR. PORADA. 01/18/19 TGB REVIEWED CORRESPONDENCE FROM M. 0.1 $49.06 ORTEGA RE BUYERS’ RESPONSE TO J. PORADA'S COUNTEROFFER, AND ADVICE RE RESPONSE TO SAME. 01/18/19 PF REVIEW EMAIL FROM T. BANICH REGARDING 0.2 $46.06 RESPONSE TO CONDO OFFER BY DR. PORADA (.1) RESPOND TO SAME (.1). 01/2419 FGB TELEPHONE CONFERENCE WITH M. ORTEGA 04 $49.00 RE STATUS OF NEGOTIATIONS WITH POTENTIAL CONDO BUYER. 01/22/79 TGB TELEPHONE CONFERENCE WITH M. ORTEGA 0.3 $147.00 RE STATUS OF NEGOTIATIONS WITH POTENTIAL CONDO BUYER. 01/22/19 PF CONFER WITH T. BANICH REGARDING OFFER 0.2 $46.00 ON CONDO.
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IIR EE a tt ers Date Timekeeper Description Hours Amount rr re rl □ 01/23/19 TGB MULTIPLE TELEPHONE CONFERENCES WITH 0.4 $196.00 M. ORTEGA RE STATUS OF NEGOTIATIONS WITH CONDO BUYER.. 01/23/19 PF PHONE CONFERENCE WITH CHICAGO TITLE 0.5 $115.00 REGARDING DIFFERENCE IN LEGAL DESCRIPTION (.2) AND REVIEW VESTING DEED FOR SAME (.1). CONFER WITH T. BANICH REGARDING OFFER TO PURCHASE CONDO (.2) 01/24/19 TGB MULTIPLE TELEPHONE CONFERENCES WITH 0.6 $294.00 M. ORTEGA RE CONDO PURCHASE NEGOTIATIONS AND HIS DISCUSSIONS WITH J. PORADA RE SAME. 01/24/19 PF CONFER WITH T. BANICH REGARDING LATEST 0.2 $46.00 OFFER FOR PURCHASE OF CONDO. 01/25/19 TGB MULTIPLE TELEPHONE CONFERENCES WITH 0.6 $294.00 M. ORTEGA RE CONDO SALE NEGOTIATIONS. 01/26/19 TGB REVIEWED M. ORTEGA CORRESPONDENCE 0.3 $147.00 WITH J. PORADA RE J. PORADA'S DECISION TO ACCEPT BUYER'S COUNTEROFFER AND COMPLETION OF PAPERWORK FOR SALE TRANSACTION (.1); TELEPHONE CONFERENCE WITH M. ORTEGA RE SAME (.2). 01/29/19 TSB DRAFTED CORRESPONDENCE WITH OUTSIDE 2.1 $1,029.00 COUNSEL TO COUNTRY ACRES RE OBJECTION TO ASSESSMENT OF LEGAL FEES TO Jj. PORADA (1); REVIEWED RESPONSE TO SAME FROM OUTSIDE COUNSEL TO COUNTRY ACRES (.1); REVIEWED SECTION 9.2(B) OF CONDOMINIUM PROPERTY ACT AND CONSIDER RESPONSE BASED ON SAME (8); DRAFTED CORRESPONDENCE TO OUTSIDE COUNSEL TO COUNTRY ACRES OBJECTING TO ASSESSMENT OF LEGAL FEES AGAINST J. PORADA AND CHALLENGING LEGAL BASIS FOR SAME (1.1); TELEPHONE CONFERENCE WITH M. ORTEGA RE DISCUSSION WITH J. PORADA RE CONDO SALE (N/C); 01/31/19 TGB REVIEWED FINAL EXECUTED DOCUMENTS 1.1 $539.00 FOR CONDO SALE. PF REVIEW EMAILS FROM REALTOR 04 $23.00 CONCERNING SALE OF CONDO. 02/01/19 TGB DRAFTED CORRESPONDENCE TO COUNTRY 0.3 $147.00 ACRES OUTSIDE AND CORPORATE SECRETARY ATTACHING FILED MOTION TO SELL CONDO (.2); DRAFTED CORRESPONDENCE TO M. ORTEGA ATTACHING FILED MOTION TO SELL CONDO (4). 02/04/19 TGB REVIEWED CACHA INVOICES FOR LEGAL 11 $539.00 FEES ASSESSED TO J. PORADA (7); EXCHANGED CORRESPONDENCE WITH S. KAHN AND J. STUBBLEFIELD RE SAME (.4}. Page 9
OO EEE a A TT tN rn Date Timekeeper Description Hours Amount eS OUT 02/06/19 TGB REVIEWED LETTER FROM BUYER'S 0.6 $294.00 ATTORNEY RE INSPECTION REQUEST (.4): TELEPHONE CONFERENCE WITH J. GOLDSTONE RE SAME (.2). 02/07/19 TGB TELEPHONE CONFERENCE WITH J. 0.5 $245.00 (2) Typo - GOLDSTONE RE BACKGROUND, REAL reduced te ESTATE TRANSACTION, ATTORNEY REVIEW 0.1 per LETTER, INSPECTION REPORT AND NEXT Goldstone STEPS (3); REVIEWED REVISED ATTORNEY time for REVIEW LETTER FROM CONDO BUYER (.2). same 02/07/19 JLG TELEPHONE CONFERENCE WITH TERRY 0.3 $127.50 □□□□□□□□□ BANICH RE: CONTRACT (1); CASE AND ATTORNEY REVIEW PROCESS (.3). 02/07/19 JLG TELEPHONE CONFERENCE WITH MAX 0.5 $212.50 ORTEGA RE: INSPECTION ITEMS AND OUR RESPONSE. 02/07/19 JLG EMAIL WITH BUYER'S ATTORNEY RE: CONDO 0.2 $85.00 DOCUMENTS 02/07/19 RD INTAKE AS WELL AS INITIAL PROCESSING 0.3 $60.00 AND REVIEW OF REAL ESTATE SALES CONTRACT FOR PROPERTY AT 640 MURRAY LANE UNIT 312 IN DES PLAINES. 02/07/19 RD ORDER TITLE POLICY FOR SALE OF 04 $20.00 PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES THROUGH CHICAGO TITLE. 02/07/19 RD CORRESPONDENCE VIA EMAIL WITH THE 0.2 $40.00 ASSOCIATION PROPERTY MANAGER FOR PURPOSES OF GATHERING ASSOCIATION SALES DOCUMENT MATERIALS REGARDING SALE OF THE PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. RD INTER-OFFICE FILE COMMUNICATION VIA 0.1 $20.00 EMAIL REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/08/19 TGB REVIEWED CORRESPONDENCE RE 0.2 $98.00 INSPECTION ITEMS FOR CONDO SALE BETWEEN J. GOLDSTONE AND M. ORTEGA AND M. ORTEGA'S ANNOTATIONS/COMMENTS TO INSPECTION REPORT. 02/08/19 RD EMAIL CORRESPONDENCE WITH BUYER SIDE 0.4 $20.00 ATTORNEY REGARDING SET UP OF MEETING FOR BUYER WITH CONDO ASSOCIATION IN SALE OF 640 MURRAY #312. 02/08/19 RD REVIEW LAND TRUST DOCUMENTATION THAT 0.3 $60.00 NEEDS COMPLETION THROUGH PARKWAY BANK FOR SALE OF 640 MURRAY #312. REQUEST INFORMATION FROM PARKWAY BANK REGARDING LAND TRUST DETAILS. 02/08/19 RD EMAIL CORRESPONDENCE WITH CHICAGO 0.1 $20.00 TITLE UNDERWRITER FOR PURPOSES OF ORDERING TITLE FOR SALE OF 646 MURRAY #312. Page 10
OEE EEO a RH Date Timekeeper Description Hours Amount rn i 02/11/19 TGB TELEPHONE CONFERENCE AND EXCHANGED 0.3 $147.00 CORRESPONDENCE WITH J. GOLDSTONE RE RESPONSE TO ATTORNEY REVIEW LETTER. 02/11/19 JLG TELEPHONE CONFERENCE WITH TERRY 0.1 $42.50 BANICH RE: ATTORNEY REVIEW LETTER RESPONSES. 02/11/19 JLG DRAFT AND SEND EMAIL TO PROPERTY 0.1 $42.50 MANAGER RE: INSURANCE CLAIMS FOR UNIT AND WORK COMPLETED IN UNIT BY ASSOCIATION 02/1/19 RD FOLLOW UP WITH PARKWAY BANK 0.1 $20.00 REGARDING LAND TRUST PROCEDURES FOR SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/12/19 TGB TELEPHONE CONFERENCE WITH J. 0.4 $196.00 GOLDSTONE RE RESPONSE TO ATTORNEY REVIEW LETTER AND FEBRUARY 13 HEARING ON CONDO SALE MOTION (.2); REVIEWED CACHA'S SECTION 22.4 DISCLOSURE AND CORRESPONDENCE RELATED TO SAME (.1): REVIEWED DRAFT RESPONSE TO BUYER'S ATTORNEY REVIEW LETTER (.1). JLG DRAFT RESPONSE LETTER 0.7 $297 50 022/19 JLG TELEPHONE CONFERENCE WITH TERRY 0.2 $85,00 BANICH RE: RESPONSE AND ATTEMPTS TO CALL AND EMAIL DR. PORADA 02/12/19 JLG TELEPHONE CONFERENCE WITH BUYERS 0.3 $127.50 ATTORNEY RE: REASON FOR DELAY IN RESPONSE 02/2/19 RD FORMAT AND PREPARE MODIFICATION 0.1 $20.00 RESPONSE LETTER FOR REVIEW REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/12/19 RD CORRESPONDENCE WITH PARKWAY BANK 0.1 $20.00 REGARDING LAND TRUST DOCUMENTATION RELEASE PROCEDURES REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/12/19 RD REVIEW ASSOCIATION 22.1 DISCLOSURE AND 01 $20.00 CIRCULATE TO BUYER SIDE ATTORNEY REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 62/12/19 RD INTER-OFFICE EMAIL CORRESPONDENCE 0.4 $20.00 REGARDING STATUS OF THE TITLE DOCUMENTATION ORDER WITH CHICAGO TITLE REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. O2/12/19 RD CONVEY HOW PAYMENT WILL BE MADE TO 0.1 $20.00 THE ASSOCIATION REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/13/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.5 $245.00 Page 11
IIR EE a 4 tt Date Timekeeper Description Hours Amount GOLDSTONE RE RESPONSE TO ATTORNEY REVIEW LETTER RE CONDO SALE (.2). REVIEWED RESPONSE LETTER (.2); ATTEMPT TO REACH J. PORADA RE SAME (1). 02/13/19 JLG FINALIZE RESPONSE LETTER AND 0.5 $212.50 INSPECTION RESPONSE 02/43/19 RD FOLLOW UP WITH PARKWAY BANK 0.1 $20.06 REGARDING WHETHER WE NEED THE ORIGINAL DIRECTION TO CONVEY TO RELEASE THE DEED OUT OF THE TRUST FOR THE SALE OF 640 MURRAY UNIT 342 IN DES PLAINES. 02/13/19 RDB CHECK WHICH CHICAGO TITLE FOR STATUS 0.3 $60.00 OF THE TITLE COMMITMENT BEING READY REGARDING THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. FURTHER EMAIL CORRESPONDENCE AS WELL AS A CALL REGARDING THE SAME WITH UNDERWRITER MARK PARKINSON. 02/13/19 RD FURTHER RESEARCH OF THE MUNICIPAL 0.4 $20.00 REQUIREMENTS FOR THE CITY OF DES PLAINES REGARDING OBTAINING MUNICIPAL TRANSFER STAMPS FOR THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/49 TGB DRAFTED AND REVIEWED 0.7 $343.00 CORRESPONDENCE RE 22.1 DISCLOSURE AND DES PLAINES TRANSFER STAMP PROCEDURES (2); REVIEWED BUYERS' LETTER REQUESTING CREDITS (.1); EXCHANGED CORRESPONDENCE WITH J. GOLDSTONE AND TELEPHONE CONFERENCE WITH M. ORTEGA RE SAME (.4). 02/1419 RD COMPLETE DES PLAINES TRANSFER TAX 0.1 $20.00 FORM FOR THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/14/19 RD COORDINATE WITH SELLER SIDE REALTOR 0.1 $20.00 REGARDING VILLAGE INSPECTION COMPLETION FOR THE SALE Of 640 MURRAY UNIT 312 IN DES PLAINES. 02/14/19 RDB INTER-OFFICE COMMUNICATION REGARDING 0.1 $20.00 HOW TO PAY FOR AND CLOSE LAND TRUST WITH LATE FEES DUE AS WELL AS PAY THE TRANSFER STAMPS. 02/14/19 RD CORRESPONDENCE WITH PARKWAY BANK 0.1 $20.00 LAND TRUST REGARDING HOW TO GET THE DEED OUT OF THE LAND TRUST. 02/15/19 TGB REVIEWED J. GOLDSTONE LETTER TO 0.2 $98.00 BUYER'S ATTORNEY (.1); EXCHANGED CORRESPONDENCE WITH M. ORTEGA RE BUYER'S RESPONSE TO SAME (1). 02/15/19 JLG REVIEW AND REVISE ATTORNEY REVIEW 0.2 $85.00 RESPONSE LETTER TO BUYER'S ATTORNEY (.1} SENT UPDATED RESPONSE AND Page 12
OEE EEO I 1 LL I tT TS Date Timekeeper Description Hours Amount INSPECTION REPAIR LIST TO BUYER'S ATTORNEY (.1) 02/4519 RD COORDINATE WITH THE CITY OF DES 0.3 $60.00 PLAINES TO GET THE UNIT INSPECTION DONE AND SEND TRANSFER TAX FORM OVER TO THEM AS WELL AS CALL WITH CITY REGARDING THE SAME FOR THE SALE OF THE PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/1549 RD REVIEW TITLE COMMITMENT AND INVOICE 0.2 $40.00 FOR THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/15/19 RD GET CHECK READY TO PAY CITY OF DES 04 $20.00 PLAINES FOR THE REQUIRED INSPECTION FEE FOR THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/19/19 RD FILL OUT DIRECTION TO CONVEY 0.2 $40.00 PAPERWORK IN ORDER TO GET THE DEED OUT OF THE LAND TRUST REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/20/19 TGB REVIEWED BUYER'S FINAL ATTORNEY 0.4 $196.00 REVIEW LETTER AND EXCHANGED CORRESPONDENCE WITH J. GOLDSTONE RE SAME (.3); REVIEWED CORRESPONDENCE FROM M. ORTEGA RE MUNICIPAL INSPECTION OF CONDO IN CONNECTION WITH SALE (1). 02/20/19 RD INTER-OFFICE EMAIL CORRESPONDENCE 0.1 $20.00 REGARDING COMPLETION OF ATTORNEY REVIEW AND INSPECTION PERIOD AS WELL AS FINAL MODIFICATION LETTER REVIEW FOR SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/21/19 TGB REVIEWED CORRESPONDENCE RE CONDO 0.1 $49.00 SALE TRANSACTION. 02/21/19 RD INTERNAL OFFICE CALL REGARDING 0.4 $80.00 PROCESS FOR CLOSING OUT LAND TRUST AS WELL AS GETTING FEES FOR CLOSING LAND TRUST PROCESSED. CALL ALSO COVERED THE PROCEDURE FOR CLOSING THE PROPERTY AND REMAINING STEPS TO ENSURE PROPERTY IS READY TO SELL RE SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/21/19 RD INTEROFFICE EMAIL COMMUNICATION 0.2 $40.00 REGARDING PARKWAY BANK ALLOWING US TO AVOID CERTAIN HURDLES FOR RELEASING THE PROPERTY OUT OF THE LAND TRUST REGARDING SALE OF 646 MURRAY UNIT 312 IN DES PLAINES. 02/22/19 TGB REVIEWED AND EXCHANGED 0.1 $49.00 CORRESPONDENCE RE STATUS OF CONDO SALE TRANSACTION.
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IIR EE a : I I errr Date Timekeeper Description Hours Amount rt 02/22/19 JLG TELEPHONE CONFERENCE WITH COUNSEL 0.3 $127.50 FOR PARKWAY BANK RE: LAND TRUST DIRECTION TO CONVEY AND PAYMENT OF PAST DUE TRUST FEES O2/22/19 RD DRAFT MYDEC ILLINOIS AND COOK COUNTY 0.2 $40.00 TRANSFER TAX PAPERWORK FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/22/19 RD BUYER LENDER CORRESPONDENCE 0.1 $20.00 REGARDING TITLE UPDATES AND LENDER TITLE REQUIREMENTS FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/22/19 RDB REVIEW UPDATED TITLE DOCUMENTATION 0.1 $20.00 FROM CHICAGO TITLE TO ENSURE BUYER LENDER CHANGES WERE PROPERLY IMPLEMENTED REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES, 02/22/19 RD REQUEST TITLE UPDATES FROM CHICAGO 0.1 $20.00 TITLE UNDERWRITERS PER SPECIFICATIONS FROM THE BUYER SIDE LENDER ON SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/22/19 RD INTEROFFICE CORRESPONDENCE VIA EMAIL 0.1 $20.00 REGARDING EXECUTION COORDINATION OF LAND TRUST DIRECTION TO CONVEY AT PARKWAY BANK FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/25/19 TGB REVIEWED CORRESPONDENCE RE CONDO 0.9 $441.00 SALE (.2); REVIEWED CACHA'S PAID ASSESSMENT LETTER AND LEGAL FEES CHARGED THROUGH, AND CONSIDERED ISSUES WITH SAME (7). 02/25/19 RD REQUEST COMMISSION STATEMENT FROM 0.4 $20.00 REAL ESTATE AGENT MAX ORTEGA FOR SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. 02/25/19 RD REVIEW PAID ASSESSMENT LETTER AND 0.2 340.00 OTHER FINAL CLOSING PAPERWORK FROM THE ASSOCIATION MANAGEMENT COMPANY REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/25/19 RD DRAFT CLOSING DOCUMENT PACKAGE (BILL 1.0 $200.00 OF SALE AFFIDAVIT OF TITLE 1099 FORM FIRPTA FORM ALTA FORM POWER OF ATTORNEY) FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/26/19 RD CHECK ON STATUS OF DISCUSSION WITH 0.1 $20.00 PARKWAY BANK ATTORNEY FOR CLOSING DOCUMENT EXECUTION REGARDING POWER OF ATTORNEY RULES FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/27/19 RD INTER-OFFICE EMAIL REGARDING STATUS OF 0.4 $20.00 SALE PROGRESS ON SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. Page 14
IIR EE a A tI Date Timekeeper Description Hours Amount i 02/27/19 RD CIRCULATE DRAFT CLOSING 0.1 $20.00 DOCUMENTATION PACKAGE TO OFFICE FOR REVIEW AND UPDATING, 02/28/19 TGB REVIEWED CORRESPONDENCE RE STATUS 0.1 $49.00 OF BUYER'S LOAN APPROVAL AND APPRAISAL, AND EXCHANGED CORRESPONDENCE WITH J. GOLDSTONE RE SAME. 02/28/19 TGB TELEPHONE CONFERENCE WITH S. KAHN RE 0.5 $245.00 CACHA LEGAL FEES CHARGED THROUGH TO DEBTOR ON PAID ASSESSMENT LETTER. 02/28/19 JLG TELEPHONE CONFERENCE TO PARKWAY 0.4 $170.00 BANK COUNSEL RE: DIRECTION TO CONVEY (2): REVIEW DRAFT CLOSING DOCUMENTS (.2). 02/28/19 RD DISCUSS PROCEDURE FOR PAYING THE PAID 0.1 $20.00 ASSESSMENT LETTER ATTORNEY FEES CHARGED BY THE ASSOCIATION TO ENSURE COVERAGE FOR THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/28/19 RDB UPDATE CLOSING DOCUMENT PACKAGE TO 0.3 $60.06 ENSURE PROPER VESTING INFORMATION AND CALL WITH JENNIFER GOLDSTONE REGARDING THE SAME FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/28/19 RD DISCUSS CONTENTS OF PAID ASSESSMENT 0.1 $20.00 LETTER WITH JENNIFER GOLDSTONE AND TERRY BANICH FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 02/28/19 RD CALL WITH LISTING BROKER MAXIMILIAN 0.1 320.00 ORTEGA REGARDING PREPARATION AND STATUS OF COMMISSION STATEMENT FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/01/49 TGB REVIEWED AND EXECUTED DIRECTION TO 0.1 $49.00 CONVEY FOR CONDO SALE. 03/01/19 JLG TELEPHONE CONFERENCE WITH COUNSEL 1.0 $425.00 FOR PARKWAY BANK RE: LAND TRUST REQUIREMENTS (2); DRAFT LETTER RE: SAME (.7); TELEPHONE CONFERENCE WITH TERRY BANICH RE: SAME (.1). 03/01/19 RD PREPARE TRANSFER STAMP PACKAGE FOR 0.3 $60.00 DES PLAINES REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/01/19 RD DRAFT LETTER TO PARKWAY BANK 0.2 $40.00 ATTORNEY FOR PURPOSES OF GETTING PROPER LAND TRUST RELEASE REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/01/19 RD CALLS WITH JENNIFER GOLDSTONE 0.4 $80.00 REGARDING PARKWAY BANK ACCEPTANCE OF OUR PROCEDURE FOR DEED RELEASE AND EXECUTIONS AS WELL AS SCHEDULE Page 15
IIR EE Date Timekeeper Description Hours Amount COORDINATION OF RELEASE AND DELIVERY OF DEED FOR SALE OF 640 MURRAY UNIT 3412 IN DES PLAINES. 03/01/19 RD UPDATE CLOSING PACKAGE WITH NEW 0.2 $40.00 PROPER VESTING AFTER DISCUSSING PARTICULAR CHANGES FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/01/19 RD CALL WITH VILLAGE OF DES PLAINES 0.3 $60.00 FINANCE DEPARTMENT TO IRON CUT AND COORDINATE FINAL DETAILS FOR GETTING TRANSFER STAMPS iSSUED ON SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/01/49 RB MEETING WITH TERRY BANICH TO EXECUTE 0.2 $40.00 AND NOTARIZE THE DIRECTION TO CONVEY FOR LAND TRUST DEED RELEASE REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/04/19 TGB REVIEWED DRAFT COMMISSION STATEMENT 0.2 $98.60 FOR CONDO SALE. 03/04/19 RD CONFIRM CLOSING DOCUMENT 0.2 $40.00 PREPARATION IS CORRECT WITH CHICAGO TITLE UNDERWRITERS FOR SALE OF PROPERTY AT 640 MURRAY UNIT 312 PLAINES. 03/04/19 RD REVIEW COMMISSION STATEMENT AND 0.4 $20.00 HOME DEPOT RECEIPTS FROM REAL ESTATE AGENT FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/05/19 TGB REVIEWED CORRESPONDENCE BETWEEN 0.4 $196.00 REAL ESTATE LAWYERS AND TITLE COMPANY RE APPARENT TYPO IN 1979 DEED AND STRATEGIES FOR DEALING WITH SAME (.2); REVIEWED AND EXCHANGED CORRESPONDENCE RE PAYING FOR REAL ESTATE TRANSFER TAX STAMP (.2). 03/0519 RD SEARCH PROPERTY RECORDS FOR 08 $160.00 ADDRESS ERROR IN THE LAND TRUST RECORDS DISCREPANCY ON SALE OF 640 MURRAY UNIT 312 IN DES PLAINES (.2). PARKWAY BANK CORRESPONDENCE VIA EMAIL AND ANSWERING QUESTIONS OF THEIRS FOR OUR PROPERTY REGARDING SAME (.2). CALL WITH JENNIFER GOLDSTONE REGARDING SAME (.2). EMAIL CORRESPONDENCE WITH CHICAGO TITLE REGARDING SAME (.2). 03/05/19 RD CALL WITH CITY OF DES PLAINES FOR 02 $40.00 TRANSFER STAMP FINAL CONFIRMATION AND COORDINATING REGARDING SALE OF PROPERTY AT 6406 MURRAY UNIT 312 IN DES PLAINES. 03/05/19 RD COORDINATE WITH BROKER MAX ORTEGA 0.2 $40.00 REGARDING PICKUP OF TRANSFER STAMPS FROM DES PLAINS FOR SALE OF PROPERTY Page 15
IIR EE a i A Date Timekeeper Description Hours Amount AT 640 MURRAY UNIT 312 IN DES PLAINES. 03/05/19 RD INTER OFFICE CORRESPONDENCE VIA EMAIL 0.4 $20.00 REGARDING FILE STATUS FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/05/19 RD REVIEW THE DEED OUT OF TRUST AND 04 $20.00 PROCEEDS LETTER FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/06/19 TGB REVIEWED AND EXECUTED VARIOUS 0.3 $147.00 CLOSING DOCUMENTS FOR CONDO SALE (.2); DISCUSSED SAME WITH R. DAMON (.1). 03/06/19 RD EXECUTE CLOSING PACKAGE 0.4 $80.00 DOCUMENTATION WITH TERENCE BANICH REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/06/19 RD EMAIL CORRESPONDENCE WITH MAXIMILIAN 0.1 $20.00 ORTEGA REGARDING CLOSING STATUS FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/06/19 RD INTER OFFICE FILE COMMUNICATION VIA 0.1 $20.00 EMAIL FOR CHECKING ON THE STATUS OF CLOSING AFTER HEARING STATUS OF BUYER LOAN PROCESS FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/06/19 RD CIRCULATE CLOSING DOCUMENTATION TO 0.1 $20.00 BUYER SIDE ATTORNEY FOR REVIEW ON SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/06/19 RD CORRESPONDENCE VIA EMAIL WITH CITY OF 0.1 $20.00 DES PLAINES FINANCE DEPARTMENT LETTING US KNOW THE STAMPS ARE READY FOR PICKUP FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/07/19 TGB EXCHANGED CORRESPONDENCE RE 0.4 $196.00 UPDATED CLOSING DATE (.1); REVIEWED DRAFT CLOSING STATEMENT FOR CONDO SALE AND EXCHANGED CORRESPONDENCE WITH J. GOLDSTONE AND R. DAMON RE SAME (.3). 03/07/19 JLS TELEPHONE CONFERENCE WITH PARKWAY 0.8 $340.00 BANK COUNSEL RE: ORIGINAL DEED (.3); PREPARE PRELIM CLOSING FIGURES (.3): EMAIL WITH BUYER'S ATTORNEY ABOUT SCHEDULING (.2) 03/07/19 RD UPDATE CLOSING FIGURES FOR THE TITLE 0.3 $60.00 COMPANY ON OUR FIRM DRAFT CLOSING STATEMENT MULTIPLE TIMES REGARDING SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES. RD REVIEW MORTGAGE AND CLOSING DATE 0.1 $20.00 EXTENSION REQUEST FROM BUYER SIDE ATTORNEY FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. Page 17
IIR EE i I I i Date Timekeeper Description Hours Amount rt tn 03/07/19 RD COORDINATE GETTING EXECUTED LAND 0.2 $40.00 TRUST DEED TO OUR OFFICE FROM PARKWAY ATTORNEY OFFICE FOR SALE OF PROPERTY AT 640 MURRAY UNIT 312 IN DES PLAINES, 03/08/19 RB CIRCULATE CONTRACT DISCLOSURES TO 0.1 $20.00 LENDER REGARDING SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/08/19 RD CALL WITH BROKER MAX ORTEGA 0.1 $20.00 REGARDING TRANSFER STAMP DELIVERY TO OUR OFFICES FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/08/19 RD RECEIVE AND REVIEW EXECUTED DEED 0.1 $20.00 ORIGINALS FROM PARKWAY BANK FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES, 03/08/19 RD INTER OFFICE COMMUNICATION FOR 0.1 $20.06 PURPOSES OF COORDINATING THE CLOSING FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/11/19 RD UPDATE THE ASSOCIATION MANAGEMENT 0.1 $20.00 COMPANY VIA EMAIL OF THE NEW CONTRACT CLOSING DATE FOR SALE OF 640 MURRAY UNIT 342 IN DES PLAINES. 03/17/19 RD INTER-OFFICE EMAILS REGARDING FINAL 0.1 $20.00 CLOSING COORDINATION AND STATUS OF CLEAR TO CLOSE WITH BUYER LENDER FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/11/19 RD COORDINATE DELIVERY OF CLOSING 0.4 $20.00 DOCUMENTATION TO THE TITLE COMPANY FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES, 03/12/19 TGB REVIEWED AND EXCHANGED 02 $98.66 CORRESPONDENCE WITH J. GOLDSTONE RE EXTENSION OF CLOSING DATE FOR CONDO SALE. 03/12/19 RD CORRESPONDENCE WITH BUYER LENDER 0.1 $20.00 REGARDING CLOSING STATUS AND CLEAR TO CLOSE PROGRESS FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/42/19 RD CONFIRM CLOSING DETAILS WITH TITLE 0.1 $20.00 COMPANY AND ADD RELEVANT DETAILS TO OFFICE SCHEDULE FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/13/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.3 $147.00 GOLDSTONE RE CONDO CLOSING ON MARCH 15 (.1), TELEPHONE CONFERENCE WITH BUYER FOR CONDO RE CLOSING ISSUES (.2). 03/13/19 RD REVIEW CHICAGO TITLE UPDATED CLOSING 0.2 $40.00 FIGURES FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/14/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.1 $49.00 Page 18
IIR EE a . . Date Timekeeper Description Hours Amount GOLDSTONE RE FINAL ARRANGEMENTS FOR CONDO SALE CLOSING. 03/14/19 JLG TELEPHONE CONFERENCE WITH CHICAGO 0.2 $85.00 TITLE RE: CLOSING DETAILS 03/14/19 RD SEND CLOSING FIGURES AND SUPPORTING 0.1 $20.00 DOCUMENTATION TO CHICAGO TITLE ADMINISTRATORS FOR PREPARING THE FINAL CLOSING STATEMENT ON THE SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/14/19 RD CALLS WITH REALTOR MAXIMILIAN ORTEGA 0.2 $40.06 TO COORDINATE DELIVERY OF TRANSFER STAMPS TO THE CLOSING FOR SALE OF 640 MURRAY UNIT 312 IN DES PLAINES. 03/15/19 TGB REVIEWED AND EXECUTED FINAL CLOSING 0.6 $294.00 DOCUMENTS FOR CONDO SALE PER COURT ORDER (.5); TELEPHONE CONFERENCE WITH J. GOLDSTONE RE SAME (.1). 03/15/19 JLG ATTEND TO CLOSING MATTERS 2G $850.09 (6) Insufficien SUBTOTAL: COUNTRY ACRES MATTERS 41.9 $15,809.00 Descriptio CREDITOR CLAIMSICOMMUNICATIONS 02/05/19 TGB REVIEWED AND EXCHANGED 0.2 $98.00 CORRESPONDENCE WITH T. DESAI RE ITEMS ON DECEMBER 2018 OPERATING REPORT, 03/08/19 TGB EXCHANGED CORRESPONDENCE WITH T. 0.1 $49.00 DESAI RE HER ASSISTANCE WITH PARKWAY BANK IN CONDO SALE. 03/13/19 TGB CONSIDERED POTENTIAL CLAIM ASSERTED 0.5 $245.00 BY RFREINV, LLC AGAINST ESTATE (.3): DRAFTED CERTIFICATE OF SERVICE OF BAR DATE ORDER FOR SAME (.2). 04/04/19 TGB REVIEWED PROOFS OF CLAIM FILED BY M. 0.6 $294.00 REZAI, ESTATE OF HEATH AND ILLINOIS DEPARTMENT OF REVENUE. TGB REVIEWED AMENDED PROOF OF CLAIM FILED 0.8 $392.00 BY REZA] AND AMENDED PROOF OF CLAIM FILED BY HEATH (.6); REVIEWED PROOF OF CLAIM FILED BY FISHER (.2}. O7/11/19 TGB TELEPHONE CONFERENCES WITH T. DESAI 0.1 $51.50 RE REQUESTED EXTENSION OF TIME TO FILE PLAN AND DISCLOSURE STATEMENT, 07/15/19 TGB TELEPHONE CONFERENCE WITH T. DESAI RE 0.3 $154.50 AMENDED MOTION TO EXTEND TIME. TGB CONFERRED WITH J. SHIMOTAKE AND T. 0.2 $103.00 DESAI RE CASE STATUS. 09/10/19 TGB TELEPHONE CONFERENCE WITH T. DESAI, 0.2 $103.06 COUNSEL FOR CREDITORS REZA! AND HEATH, RE SAME. SUBTOTAL: CREDITOR CLAIMS/COMMUNICATIONS 3.0 $74,490.00 Page 19
RE a Date Timekeeper Description Hours Amount ot US Amount FEE APPLICATIONS 02/27/19 TGB REVIEWED AND EDITED FOX ROTHSCHILD 25 $1,225.00 INVOICES FOR JUNE-DECEMBER 2018 TIME, CLASSIFIED TIME INTO TASK CATEGORIES AND ANALYZED TIME DISTRIBUTION BY CATEGORY IN SPREADSHEET. 02/28/19 TGB REVIEWED AND EDITED FOX ROTHSCHILD 2.0 $980.00 INVOICES FOR JUNE-DECEMBER 2018 TIME, CLASSIFIED TIME INTO TASK CATEGORIES AND ANALYZED TIME DISTRIBUTION BY CATEGORY IN SPREADSHEET. 03/01/19 TGB REVIEWED AND EDITED FOX ROTHSCHILD 5.8 $2,842.00 (9) Typo- INVOICES FOR JUNE-DECEMBER 2018 TIME, appears CLASSIFIED TIME INTO TASK CATEGORIES □□□□□□ ate AND ANALYZED TIME DISTRIBUTION BY b p CATEGORY IN SPREADSHEET (2.9); DRAFTED □□□ tx AND EDITED FIRST INTERIM FEE Same las APPLICATION FOR FOX ROTHSCHILD LLP FOR for same JUNE 2018 TO DECEMBER 2018 (2.9). □□□□ □ 03/04/19 TGB CONTINUED EDITING FOX ROTHSCHILD FEE 0.1 NOCHARGE same day APPLICATION FOR JUNE-DECEMBER 2018 (1.5 -- NO CHARGE); REVIEWED AND EDITED FOX ROTHSCHILD JUNE-DECEMBER 2018 INVOICE (1.5 NO CHARGE): 03/08/19 TGB FINALIZED FOX ROTHSCHILD FIRST INTERIM 0.1 NO CHARGE FEE APPLICATION (.3 - - NO CHARGE): DRAFTED PROPOSED ORDER IN CONNECTION WITH SAME (.3 - - NO CHARGE) TGB REVIEWED INVOICE FOR JANUARY- 1.5 $772.50 SEPTEMBER 2019 TIME AND BEGIN TO PREPARE FINAL FEE APPLICATION FOR FOX ROTHSCHILD. 10/14/19 TGB DRAFTED AND EDITED FINAL FEE 3.1 $1,596.50 APPLICATION FOR FOX ROTHSCHILD. 10/15/19 TGB DRAFTED AND EDITED FINAL FEE 15 $772.50 APPLICATION FOR FOX ROTHSCHILD. 10/16/19 TGB MADE FINAL EDITS FEE APPLICATION FOR 06 $309.00 FOX ROTHSCHILD (.3); DRAFTED PROPOSED ORDER ON SAME (.3). SUBTOTAL: FEE APPLICATIONS 17.2 $8,497.50 FISHER ADVERSARY 01/04/19 TGB REVIEWED FISHER'S ANSWER TO COMPLAINT 44 $2,156.00 AND CONSIDERED FACTS TO INVESTIGATE AND POTENTIAL MOTION TO STRIKE AFFIRMATIVE DEFENSES (8): LEGAL RESEARCH RE POTENTIAL DEFECTS IN AFFIRMATIVE DEFENSES (1.5); DRAFTED LENGTHY ANALYSIS TO J. PORADA OF FISHER'S ANSWER AND SUGGESTED STRATEGIES RE SAME (2.1). Page 20
RE a Date Timekeeper Description Hours Amount rn US AMOUNT 01/04/19 JLD DISCUSS FORECLOSURE QUESTION WITHT, 2.2 $803.00 BANICH (.1); RESEARCH SAME (2.1). O1/07/19 TGB REVIEWED LEGAL RESEARCH REGARDING 1.5 $735.00 FORECLOSURE OF UNRECORDED MORTGAGE. 01/07/19 JLD CONTINUE RESEARCH INTO LOAN 2.4 $876.00 FORECLOSURE QUESTION AND PREPARE BRIEF SUMMARY OF SAME. 01/08/19 RWG CONFER WITH J. DEVROYE RE MORTGAGE 0.3 $165.00 (2) □□□□□ ENFORCEMENT ISSUES reduced t 01/08/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.6 $294.00 □□□□□□□ DEVROYE RE FURTHER RESEARCH RE time for POTENTIAL FORECLOSURE OF FISHER same NOTES AND WHETHER THEY ARE conferenc EQUIVALENT TO MORTGAGES (.1); TELEPHONE CONFERENCE WITH ATTORNEY FOR FISHER RE BACKGROUND AND JANUARY 9 HEARING (.3); REVIEWED J. DEVROYE'S ANALYSIS OF WHETHER NOTES CONSTITUTED MORTGAGES (.2). 01/08/19 JLD RESEARCH BANKRUPTCY COURT 24 $876.00 ADJUDICATION OF FORECLOSURE SUIT PER T. BANICH (.2); RESEARCH ENFORCEABILITY OF MORTGAGE (1.8); DISCUSS SAME WITH R. GLANTZ (.2); ADDITIONAL RESEARCH RE GRANTING LANGUAGE (.2). 01/09/19 TGB TELEPHONE CONFERENCE WITH AND 1.0 $490.00 EXCHANGED CORRESPONDENCE WITH J. DEVROYE WHETHER FISHER NOTES ARE "MORTGAGES" UNDER THE MORTGAGE FORECLOSURE LAW (.2); LEGAL RESEARCH RE SAME (.7); CONFERRED WITH COUNSEL FOR FISHER RE SEARCH FOR FINANCIAL RECORDS AND POTENTIAL SETTLEMENT (.1). 01/10/19 IGB CONFERRED WITH J. DEVROYE RE WHETHER 05 $245.00 (2) Typo - NOTES ARE MORTGAGES UNDER THE reduced to MORTGAGE FORECLOSURE LAW AND 0.2 per BANKRUPTCY COURT JURISDICTION TO Devroye CONSIDER CLAIMS. time for 01/10/19 JLD CONTINUE RESEARCH INTO LOAN 3.4 $1,241.00 Same FORECLOSURE QUESTION AND PREPARE conference FURTHER SUMMARY TO T. BANICH OF SAME (3.2); DISCUSS POTENTIAL VENUE FOR FORECLOSURE CLAIM WITH T. BANICH (.2). TGB REVIEWED SETTLEMENT OFFER FROM 0.1 $49.00 FISHER'S COUNSEL. 01/14/19 JLD CONTINUE RESEARCH INTO LOAN 61 $2,226.50 FORECLOSURE QUESTION AND PREPARE FURTHER SUMMARY TO T. BANICH OF SAME. 01/14/19 TGB CONFERRED WITH J. DEVROYE RE 6.2 $3,038.00 (2) Typo - FORECLOSURE ON FISHER NOTES AND reduced to JURISDICTION ISSUES WITH REGARD TO 0.2 per SAME (.8); MULTIPLE CONFERENCES WITH P. Devroye time for Page 21 same conference
OO EEE a tt Date Timekeeper Description Hours Amount FREDERICKS RE RECORDING FISHER NOTES AND TITLE SEARCH ON FISHER PROPERTIES IN WISCONSIN (.3): LEGAL RESEARCH RE MORTGAGE FORECLOSURE PRINCIPLES (3.3); DRAFTED AMENDED COMPLAINT AGAINST FISHER TO ADD ALLEGATIONS RE SECURITY INTERESTS AND RELATED MATTERS (1.8). 01/14/19 JLD DISCUSS FORECLOSURE ADVERSARY CASE 1.4 $401.50 RESEARCH WITH T. BANICH (.2): RESEARCH ANY STATUTE OF REPOSE OR LIMITATIONS FOR MORTGAGE FORECLOSURE ACTION (.9). 01/149 PF CONFER WITH T. BANICH REGARDING NOTES 3.2 $736.00 (2) Typo - TO BE RECORDED AGAINST MINOOKA sum of all PROPERTY(.2). REVIEW SAME.(.1) PHONE □□□□□□□□□□ CALL TO KENDALL COUNTY RECORDER To reduced to DETERMINE IF COPIES OF NOTES CAN BE 0.3 per RECORDED AND INSTRUCTIONS AND COST Bani ch tim FOR RECORDING 6 NOTES (.4). FOLLOW UP for same CONFERENCE WITH T. BANICH REGARDING INFORMATION OBTAINED FOR SAME.(.2). □□□□□□□□□□ CONFER WITH T. BANICH REGARDING 3 PROPERTIES IN HAYWARD, Wi. AND NEED TO DETERMINE CURRENT OWNERSHIP OF SAME (2). REVIEW OPERATING AGREEMENT FOR PINS AND LEGAL DESCRIPTIONS OF PROPERTY (.2). SEARCH SAWYER COUNTY RECORDERS WEBSITE TO TRY TO OBTAIN LATEST VESTING DEED FOR EACH PROPERTY (.4}. OBTAIN COPIES OF CURRENT TAX BILLS FOR EACH PROPERTY (2). SEARCH REAL QUEST DATA BASE AND REVIEW PROPERTY DETAIL REPORTS OBTAINED FROM SAME FOR EACH PROPERTY (.9) AND CONFER WITH T. BANICH REGARDING NEED FOR TRACT SEARCH FOR SAME(.2}. REQUEST ESTIMATE FOR TRACT SEARCH (.2). TGB CONTINUED DRAFTING AMENDED 74 $3,479.00 COMPLAINT VS. FISHER (2.5): LEGAL RESEARCH RE SAME AND OTHER POTENTIAL CLAIMS (2.6); MULTIPLE CONFERENCES WITH P, FREDERICKS RE RECORDING NOTES AND NOTICE OF FORECLOSURE (.5); EDITED NOTICES TO RECORD WITH SIX NOTES (3); DRAFTED AND EDITED NOTICE OF FORECLOSURE TO BE RECORDED (1 .2). 01/15/19 PF PREPARE COVER PAGES FOR RECORDING 6 1.5 $345.00 PROMISSORY NOTES AND CONFER WITH T. BANICH REGARDING SAME (8). LOCATE SAMPLE LIS PENDENS AND FORWARD TO T. BANICH (.2). REVIEW EMAIL REGARDING OFFER TO PURCHASE CONDO AND CONFER WITH T. BANICH REGARDING SAME AND REQUEST THAT ORDER AUTHORIZING SALE OF SAME BE FINAL iF WE ARE TO MEET CLOSING DEADLINE BY BUYER (.3). CONFIRM ORDER OF TRACT SEARCHES ON WISCONSIN PROPERTIES (.2). Page 22
IIR EE a Date Timekeeper Description Hours Amount tn IO 01/16/19 RWG CONFER WITH T. BANICH RE FISHER LOAN 0.3 $165.00 DISPUTE ISSUES 01/16/19 TGB REVIEWED AND APPROVED FISHER NOTES 6.3 $3,087.00 FOR RECORDING WITH KENDALL COUNTY RECORDER OF DEEDS (.1); REVIEWED LAND RECORDS FOR FISHER'S KENDALL COUNTY PROPERTY (.3); REVIEWED HEARTLAND BANK MORTGAGE AND MORTGAGE MODIFICATION DOCUMENTS (.7)}: CONSIDER RELATIVE LIEN PRIORITIES AND WHETHER HEARTLAND BANK MUST BE NAMED AS A FORECLOSURE DEFENDANT (.5}; CONFERRED WITH R. GLANTZ RE FORECLOSURE PROCEDURE AND LIEN PRIORITY (.3); LEGAL RESEARCH RE EQUITABLE LIEN CLAIM AND CONSIDERED OTHER POTENTIAL CAUSES OF ACTION (9); DRAFTED AND EDITED AMENDED COMPLAINT TO ADD EQUITABLE LIEN CLAIM (2.9): FURTHER CONFERENCE WITH R. GLANTZ RE LIEN FORECLOSURE PROCEDURES (.3): CONFERENCES WITH P. FREDERICKS RE ESTIMATED MARKET VALUE OF FISHER PROPERTY (.3). 01/16/19 PFE PREPARE LETTER TO RECORDER WITH 2.5 $575.00 (2) Typo - PROMISSORY NOTES ON KENDALL COUNTY reduced t PROPERTY(.3) ASSEMBLE DOCUMENTS (.3) 0.3 per AND ARRANGE FOR SAME TO BE SENT BY Banich OVERNIGHT DELIVERY (.2). CONFER WITH T. entry for BANICH REGARDING MORTGAGE ON same PROPERTY AND REVIEW RESULTS OF TRACT conferenc SEARCH FOR SAME (.4), RESEARCH VALUE OF KENDALL COUNTY PROPERTY (1.3). TGB TELEPHONE CONFERENCE WITH M. ORTEGA 0.5 $245.00 RE ESTIMATED VALUE OF FISHER PROPERTY (1); MULTIPLE CONFERENCES WITH P. FREDERICKS RE HER DISCUSSIONS WITH KENDALL COUNTY RECORDER RE RECORDING FISHER NOTES (.3); EDITED NOTICE OF FORECLOSURE TO REFLECT RECORDATION OF NOTES (.1). PF PHONE CALL TO KENDALL COUNTY 1.3 $299.00 RECORDER TO DETERMINE IF THEY RECEIVED PROMISSORY NOTES FOR RECORDING AND THEIR CLAIM THAT SAME MUST BE NOTARIZED (4). CONFER WITH T. BANICH REGARDING SAME (.2). CONFER | AGAIN WITH COUNTY TO REQUEST EVIDENCE OF NOTARY REQUIREMENT AND CONFIRM THAT ALL WILL BE RECORDED WITH TODAYS DATE WITH REQUIRED MODIFICATION TO SAME (.3) REVISE SAME AND FAX TO COUNTY FOR RECORDING (.3). FORWARD RECORDED FIRST PAGES TO T. BANICH (1). 04/18/19 TGB REVIEWED TRACT SEARCH RESULTS FOR 02 $98.00 FISHER PROPERTIES IN WISCONSIN. 01/22/19 TGB EDITED, FINALIZED AND FILED AMENDED 2.0 $980.00 Page 23
OO EEE a TT Date Timekeeper Description Hours Amount COMPLAINT VS. FISHER (1.5); DRAFTED AND FILED CERTIFICATE OF SERVICE FOR AMENDED COMPLAINT (.2); DRAFTED CORRESPONDENCE TO J. SHIMOTAKE, COUNSEL FOR R. FISHER, RE AMENDED COMPLAINT AND SETTLEMENT DISCUSSIONS (3). 01/23/19 TGB REVIEWED AND ANALYZED TRACT SEARCH 0.7 $343.00 FOR FISHER'S WISCONSIN PROPERTIES C5) DISCUSSED SAME WITH P. FREDERICKS (2). 01/23/19 PF REVIEW RESULTS OF TRACT SEARCH FOR 0.3 $69.00 HAYWARD PROPERTY AND COMPARE LEGAL DESCRIPTION IN SAME TO THAT IN OPERATING AGREEMENT. TGB REVIEWED TRACT SEARCH RESULTS AND 0.5 $245.00 VESTING DEED FOR RFREINV, LLC PROPERTIES. PF REVIEW ADDITIONAL INFORMATION 6.3 $69.00 RECEIVED FROM TITLE COMPANY REGARDING HAYWARD TRACT SEARCHES (.2) FORWARD VESTING DEED TO T. BANICH(.1}. 01/25/19 TGB REVIEWED CORRESPONDENCE FROM 0.1 $49.00 FISHER'S COUNSEL RE NEW SETTLEMENT OFFER. 01/3149 TGB CONFERRED WITH P. FREDERICKS RE 6.2 $98.00 RECORDATION OF LIS PENDENS AGAINST FISHER PROPERTY AND REVIEWED SAME. PF SCAN AND FORWARD RECORDED PAGE OF G.2 346.00 LIS PENDENS. 02/06/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.1 $49.00 SHIMOTAKE RE FISHER ADVERSARY, 02/14/19 TGB REVIEWED SCHEDULING ORDER IN FISHER 0.1 $49.00 ADVERSARY. 02/20/19 TGB REVIEWED AND EXCHANGED 6.3 $147.00 CORRESPONDENCE WITH J. SHIMOTAKE RE FISHER SETTLEMENT DISCUSSIONS. 02/22/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.2 $98.00 SHIMOTAKE RE FISHER SETTLEMENT DISCUSSIONS. 03/04/19 PF REVIEW FAX OF OPERATING AGREEMENT 0.2 $46.00 FOR RFREINV LLC AND CONFER WITH T. BANICH REGARDING SAME. 03/13/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.2 $98.00 SHIMOTAKE RE NEW SETTLEMENT OFFER. 03/14/19 TGB REVIEWED FISHER'S ANSWER TO AMENDED 0.9 $441.00 COMPLAINT AND CONSIDERED POTENTIAL RESPONSES THERETO. 03/21/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.1 $49.00 SHIMOTAKE RE MOTION TO WITHDRAW JURY DEMAND.
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IIR EE a Date Timekeeper Description Hours Amount et tt 03/25/19 TGB REVIEWED ORDER RE FISHER'S JURY 0.4 $196.00 DEMAND (.1); REVIEWED FISHER'S MOTION TO WITHDRAW JURY DEMAND PER ORDER OF MARCH 25 (.2); EXCHANGED CORRESPONDENCE WITH J. SHIMOTAKE RE SAME (.1), 04/02/19 TGB EXCHANGED CORRESPONDENCE WITH C. 0.4 $49.00 SANFELIPPO RE RESULTS OF HEARING IN FISHER ADVERSARY. 04/02/19 CMS ATTENDED HEARING ON DEFENDANT 1.0 $290.00 ROBERT FISHER'S MOTION TO WITHDRAW JURY DEMAND. 04/03/19 PF SCAN AND SAVE RECORDED PROMISSORY 0.3 369.00 NOTES. 04/04/19 TGB REVIEWED CORRESPONDENCE FROM J. 0.2 $98.00 SHIMOTAKE AND PROPOSED ORDER STRIKING JURY DEMAND. 04/05/19 TGB TELEPHONE CONFERENCE WITH J. 0.2 $98.00 SHIMOTAKE RE PROPOSED ORDER STRIKING FISHER'S JURY DEMAND (.1); REVIEWED CORRESPONDENCE TO COURT FROM J. SHIMOTAKE RE SAME AND DRAFT ORDER SUBMITTED TO COURT (.1). 06/42/19 TGB REVIEWED RFREINV, LLC'S OPERATING 1.8 $927.00 AGREEMENT IN CONNECTION WITH FORMULATING SETTLEMENT AGREEMENT (3), REVIEWED NOTES AND DETERMINED AMOUNTS CURRENTLY DUE THEREUNDER (.7}; REVIEWED INVOICES AND UNBILLED TIME TO DETERMINE AMOUNT OF ATTORNEY'S FEES ASSOCIATED WITH ENFORCEMENT OF FISHER NOTES (.8). TGB REVIEWED CORRESPONDENCE FROM J. 0.2 $103.00 SHIMOTAKE RE INQUIRY RE SETTLEMENT POSITION (.1); DRAFTED CORRESPONDENCE TO 4. PORADA RE SAME ({,1), 06/18/19 SBT REVIEW CLIENT EMAILS FROM FISHER 1.5 $1,200.00 SETTLEMENT (.3); CONFER WITH T. BANICH REGARDING SAME AND REVIEW RESPONSE TO CLIENT ISSUES (1.2). 06/18/19 TGB DRAFTED CORRESPONDENCE TO J. 1.6 $824.00 SHIMOTAKE RE FORTHCOMING SETTLEMENT PROPOSAL (.1); REVIEWED J. PORADA'S COMMENTS/ANALYSIS OF FISHER SETTLEMENT POINTS (.2); CONFERRED WITH 3S. TOWBIN RE SAME AND POINTS TO MAKE IN RESPONSE (.3); REVIEWED RFREINV, LLC OPERATING AGREEMENT AND AMENDMENT THERETO IN CONNECTION WITH FISHER SETTLEMENT AND J. PORADA’S QUESTIONS RE SAME (.7); TELEPHONE CONFERENCE WITH T. ELLIOTT RE INSTRUMENT CONVEYING J. PORADA’S MEMBERSHIP INTEREST IN RFREINV, LLC (.2); TELEPHONE Page 25
OEE EEO a : Tet Date Timekeeper Description Hours Amount CONFERENCE WITH J. PORADA RE SAME (.1}. 06/19/19 TGB REVIEWED J. PORADA'S RESPONSE TO EMAIL 0.6 $309.00 RE FISHER SETTLEMENT TERMS (.2): CONFERRED WITH J. SHIMOTAKE RE SETTLEMENT CONCEPTS (.2): REVIEWED INSTRUMENT ASSIGNING INTEREST IN RFREINYV, LLC (2). 06/26/19 TGB DRAFTED DETAILED AND LENGTHY 41 $566.50 CORRESPONDENCE TO J. SHIMOTAKE RE SETTLEMENT PROPOSAL AND MATERIAL TERMS OF SAME, 07/01/19 TGB REVIEWED J. SHIMOTAKE'S RESPONSE TO 1.4 $721.00 FISHER'S SETTLEMENT OFFER (3): DRAFTED CORRESPONDENCE TO J. PORADA RE SAME (.5), TELEPHONE CONFERENCE WITH J. SHIMOTAKE RE CLARIFICATION OF SETTLEMENT OFFER (.3}; DRAFTED FURTHER CORRESPONDENCE TO J. PORADA RE SAME (.3). TGB REVIEWED CORRESPONDENCE FROM J. 0.1 $51.50 SHIMOTAKE REQUESTING STATUS UPDATE RE SETTLEMENT NEGOTIATIONS. SUBTOTAL: FISHER ADVERSARY 72.0 $31,003.00 OPERATING REPORTS 01/02/19 TGB REVIEWED DRAFT NOVEMBER OPERATING 0.5 $245.00 REPORT. 01/02/19 PF REVISE AND ASSEMBLE OPERATING REPORT. 0.4 $92.00 FORWARD EXECUTED COPY TO T. BANICH. 01/14/19 TGB FINALIZED AND FILED NOVEMBER 2018 1.0 $490.00 OPERATING REPORT (.5); REVIEWED DRAFT DECEMBER 2018 OPERATING REPORT (,5). 01/15/19 PF PREPARE DECEMBER 2018 OPERATING 1.9 $437.00 REPORT. 01/22/19 PF ASSEMBLE AND FORWARD DECEMBER 6.3 $69.00 OPERATING REPORT, 01/24/19 TGB REVIEWED DRAFT DECEMBER 2018 0.8 $392.00 OPERATING REPORT AND MULTIPLE CONFERENCES WITH P. FREDERICKS RE SAME AND CERTAIN TRANSACTIONS IN OPERATING BANK ACCOUNT. 01/24/19 PF CONFER WITH T. BANICH REGARDING 0.3 $69.00 DECEMBER OPERATING REPORT AND REVIEW BANK STATEMENTS TO BE SURE FEES DiD NOT CLEAR DURING REPORTING PERIOD. 01/26/19 TGB REVIEWED FINAL DECEMBER 2018 0.5 $245.00 OPERATING REPORT AND FILED SAME.. 02/11/19 TGB REVIEWED DRAFT JANUARY OPERATING 0.5 $245.00 REPORT.
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IIR EE I A Date Timekeeper Description Hours Amount rn TE 02/42/19 PF REVIEW EMAIL FROM T. BANICH REGARDING 0.3 $69.00 MONTHLY OPERATING REPORT INFORMATION(. 1) REVIEW SAME (,2). 02/13/19 PF REVISE OPERATING REPORT AND CIRCULATE 0.5 $115.00 SAME. 02/19/19 TGB REVIEWED DRAFT JANUARY OPERATING 0.5 $245.00 REPORT. 02/19/19 PF ASSEMBLE EXECUTED OPERATING REPORT 0.3 $69.00 AND FORWARD SAME TO T. BANICH FOR REVIEW. 02/2019 TGB REVIEWED FINAL JANUARY OPERATING 0.2 $98.00 REPORT. 02/20/19 PF CONFER WITH T. BANICH REGARDING 0.3 $69.00 JANUARY OPERATING REPORT (.1). FILE SAME. (.2). 03/04/19 PF PREPARE FEBRUARY OPERATING REPORT. 0.9 $207.00 03/05/19 PF REVISE (.3) AND EMAIL FEBRUARY 0.5 $115.00 OPERATING TO J. PORADA FOR REVIEW AND SIGNATURE (.2}. 03/1149 TGB REVIEWED DRAFT FEBRUARY OPERATING 0.5 $245.00 REPORT. 03/17/19 PF ASSEMBLE OPERATING REPORT (.1} AND 0.5 $115.00 FORWARD TO T. BANICH FOR REVIEW (.1). CONFER WITH T. BANICH REGARDING REPORT (.1). FILE AND SAVE SAME (,2} 04/08/19 PF PREPARE MARCH OPERATING REPORT. 1.9 $437.00 04/16/49 PF CONFER WITH T. BANICH REGARDING MARCH 0.2 $46.00 SIGNED OPERATING REPORT (.1). EMAIL DR. PORADA WITH REQUEST FOR SAME. (.1). 04/22/19 PF ASSEMBLE OPERATING REPORT AND EMAIL 0.4 $92.00 TOT. BANICH FOR REVIEW AND FILING. 04/23/19 PF FOLLOW UP WITH T. BANICH REGARDING 0.2 $46.00 REVIEW AND FILING OF MARCH OPERATING REPORT, 04/25/19 PF CONFER WITH T. BANICH REGARDING FILING 0.4 $92.00 OPERATING REPORT (.1) FILE SAME. (.3). 05/07/19 PF REVISE AND FORWARD APRIL OPERATING TO 04 $92.00 DR. PORADA. 05/15/19 PF RESEND OPERATING REPORT TO DR. 0.2 $46.06 PORADA FOR REVIEW AND SIGNATURE. 08/21/19 TGB CONFERRED WITH P. FREDERICKS RE 0.2 $98.00 STATUS OF APRIL OPERATING REPORT. 05/21/19 PF REVIEW UPDATED INFORMATION FOR 0.8 $184.00 OPERATING REPORT(.1). REVISE SAME, (.5). EMAIL TO DR. PORADA FOR REVIEW AND SIGNATURE (.2). 05/28/19 PF CONFER WITH T. BANICH REGARDING 0.2 $46.00 OPERATING REPORT. Page 27
IIR EE a ‘ a 2 . Date Timekeeper Description Hours Amount OT tt ORE 05/30/19 PF PHONE DR. PORADA REGARDING NEED FOR 0.2 $46.00 APPROVAL TO FILE OPERATING REPORT, 06/04/19 PF CONFER WITH T. BANICH REGARDING 0.3 $75.00 OPERATING REPORT AND AN WHEN PROCEEDS FROM SALE OF CONDO WILL BE REFLECTED. 06/05/19 PF FILE APRIL 2019 OPERATING REPORT AND 1.2 $300.00 CIRCULATE FILED STAMPED COPY OF SAME (.5). CONFER WITH T. BANICH AND ACCOUNTING DEPARTMENT REGARDING CHECK FOR PROCEEDS FROM SALE OF CONDO AND EMAIL DR. PORADA REGARDING SAME (.7} TGB REVIEWED MONTHLY OPERATING REPORT 0.2 $103.00 AND DISCUSSED SAME WITH P. FREDERICKS. PF DRAFT MAY OPERATING REPORT (1.8). EMAIL 2.3 $575.00 SAME TO DR. PORADA FOR REVIEW AND SIGNATURE (.2). REVIEW RESPONSE FROM DR. PORADA REGARDING UNCASHED CHECK FOR PROCEEDS FROM SALE OF CONDO (1). CONFER WITH T. BANICH REGARDING SAME (.2). 06/18/19 PF CONFER WITH T. BANICH REGARDING 0.2 $50.00 REVIEW AND FILING OF MAY OPERATING REPORT. PF PREPARE JUNE OPERATING REPORT. 1.9 $475.00 PF CONFER WITH T. BANICH REGARDING JUNE 0.6 $150.00 OPERATING REPORT (.2). REVISE SAME (.3). EMAIL SAME TO J. PORADA FOR REVIEW AND SIGNATURE (1). PF REVIEW SIGNED OPERATING REPORT AND 0.3 $75.00 FORWARD SAME TO T. BANICH FOR REVIEW. 07/23/19 PF CONFER WITH T. BANICH REGARDING 0.5 $125.00 OPERATING REPORT (.2). FILE SAME (.3). 08/08/19 PF DRAFT JULY OPERATING REPORT (1.5) AND 1.6 $400.00 FORWARD SAME TO J. PORADA FOR REVIEW AND SIGNATURE (.1}. 08/14/19 PF ASSEMBLE JULY OPERATING REPORT AND 0.3 $75.00 FORWARD TOT. BANICH FOR REVIEW. 08/15/19 PF FILE OPERATING REPORT, 0.4 $100.00 09/09/19 PF PREPARE AUGUST OPERATING REPORT. 1.6 $400.00 EMAIL SAME TO J. PORADA FOR REVIEW AND SIGNATURE, 09/12/19 PF ASSEMBLE AND FILE AUGUST OPERATING 0.4 $100.00 REPORT. SUBTOTAL: OPERATING REPORTS 27.6 $7,859.00 PLAN AND DISCLOSURE STATEMENT 01/14/19 TGB CONFERRED WITH S. TOWBIN RE PLAN 0.3 $147.00 Page 28
RE IE I Pn art Date Timekeeper Description Hours Amount CONCEPTS. 01/15/19 AJG CONFERENCE WITH T. BANICH RE: CHAPTER 0.3 $147.00 11 PLAN. TGB CONFERRED WITH A. GUON RE PLAN 0.3 $147.00 CONCEPTS AND ALTERNATIVES FOR CONFIRMATION, 01/18/19 AJG REVIEWED SCHEDULES FOR PLAN. 0.6 $294.00 01/21/19 AJG REVIEWED SCHEDULES AND STARTED 26 $1,274.00 PREPARATION OF PLAN (1.4); ANALYSIS OF PAYMENT OPTIONS FOR POTENTIAL PLAN (1.4); CONFERENCE WITH T. BANICH RE: SAME (.1). 01/21/19 IGB TELEPHONE CONFERENCE WITH A. GUON RE 0.3 $147.00 (2) □□□□ PLAN CONCEPTS. □□□ per 01/21/19 DRD = CONFER WITH GUON REGARDING PLAN 0.2 $74.00 Guon ent PROVISIONS AND CHAPTER 11 for same CONFIRMATION REQUIREMENTS. conferenc 03/20/19 TGB CONFERRED WITH S. TOWBIN RE PLAN 0.3 $147.00 CONCEPTS VS. POTENTIAL CONVERSION TO CHAPTER 7. 05/24/19 TGB —- REVIEWED CLAIMS DOCKET AND 25 $1,225.00 CONSIDERED STRUCTURE OF CHAPTER 11 PLAN IN PREPARATION FOR MAY 25 MEETING WITH J. PORADA AND S. TOWBIN. 06/11/19 TGB CONFERENCES WITH 8. TOWBIN RE PLAN 4.2 $618.00 CONCEPTS IN PREPARATION FOR MEETING WITH J. PORADA (.2); REVIEWED CODE SECTIONS AND FORMS APPLICABLE TO CALCULATION OF DISPOSABLE INCOME FOR PURPOSES OF SECTION 1129(A)(15) (1.0): 06/12/19 DRD —- CONFER WITH T. BANICH REGARDING 0.3 $118.50 DRAFTING OF CHAPTER 11 PLAN, CURRENT STATUS OF CASE, LIKELY PLAN PROVISIONS, AND POSSIBLE SETTLEMENT OF ADVERSARY PROCEEDING. 07/01/19 AJG CONFERENCE WITH T. BANICH RE: PLAN 1.8 $936.00 PAYMENT TERMS (.4); BEGAN DRAFTING PLAN (4.3). 07/02/19 AJG REVISED AND FINALIZED FIRST DRAFT OF 2.3 $1,196.00 PLAN OF REORGANIZATION FOR CLIENT, 07/08/19 TGB REVIEWED AND EDITED PROPOSED CHAPTER 14 $566.50 11 PLAN (.8); CONFERRED WITH A. GUON RE SAME (.3). 07/09/19 AJG REVISED PLAN OF REORGANIZATION (.8): 45 $2,340.00 CONFERENCE WITH T. BANICH RE: REVISED TERMS AND DISCHARGE (.2): CONFERENCE WITH S, TOWBIN RE: DISCHARGE ISSUES (2): PREPARED DISCLOSURE STATEMENT INCLUDING REVIEW OF SCHEDULES (3.1): CONFERENCE WITH T. BANICH RE: SAME (2). 07/09/19 SBT CONFER WITH A. GUON REGARDING PLAN 0.3 $240.00 Page 29
OE IEE EO a te Date Timekeeper Description Hours Amount ISSUES. TGB REVIEWED FURTHER DRAFT OF PLAN AND 0.7 3360.50 CONFERENCES WITH A. GUON RE EDITS To SAME, CREDITOR BODY AND FILED CLAIMS. O7/10/19 AJG REVIEWED AND COMMENTED ON REVISIONS 0.3 $156.00 TO DISCLOSURE STATEMENT. TGB DRAFTED AND EDITED INSERT TO 2.0 $1,030.00 DISCLOSURE STATEMENT (1.5): CONFERRED WITH A. GUON RE SAME (.3); DRAFTED CORRESPONDENCE TO J. PORADA RE SAME (2). AJG REVIEWED REQUEST FOR INFORMATION 0.4 $52.00 FROM CLIENT AND DISCUSSED SAME WITH T. BANICH. 09/03/19 SBT EMAIL EXCHANGE WITH T. BANICH 0.4 $320.00 REGARDING DR. PORADA PLAN COMMENTS AND REVIEW SAME. 09/04/19 AIG CONFERENCES (2) WITH T. BANICH RE: 3.9 $2,028.00 REVISIONS TO PLAN AND DISCLOSURE STATEMENT AND LIQUIDATION ANALYSIS (.2): REVIEWED SCHEDULES AND PREPARED LIQUIDATION ANALYSIS (2.6); REVISED PLAN AND DISCLOSURE STATEMENT (.3); EMAIL TO CLIENT RE: SAME (.5}; REVIEWED INCOME STATEMENT AND UPDATED PLAN TO REFLECT ADDITIONAL INCOME (.3). 09/04/19 TGB MULTIPLE TELEPHONE CONFERENCES WITH 14 $566.50 A. GUON RE PLAN AND LIQUIDATION ANALYSIS (4); REVIEWED LIQUIDATION ANALYSIS (.2); REVIEWED A. GUON'S CORRESPONDENCE TO J. PORADA RE PLAN, LIQUIDATION ANALYSIS AND OPTIONS GOING FORWARD (.3); REVIEWED FAX FROM J. PORADA RE UPDATED INCOME PROJECTIONS (.2). 09/09/19 TGB DRAFTED CORRESPONDENCE TO J. PORADA 0.3 $154.50 RE STATUS OF TAX ANALYSIS FOR DISCLOSURE STATEMENT/LIQUIDATION ANALYSIS (.1); CONFERRED WITH A. GUON RE LAST CONVERSATION WITH J. PORADA RE QUESTIONS/COMMENTS TO DRAFT PLAN AND EXPECTED FAXED COMMENTS/EDITS FROM J. PORADA RE SAME (.2). SUBTOTAL: PLAN AND DISCLOSURE STATEMENT 27.7 $14,284.50 PREPETITION LITIGATION 01/03/19 TGB EXCHANGED CORRESPONDENCE WITH J. 0.2 $98.00 WORTHEN AND T. ELLIOTT RE TASKS MOVING FORWARD IN LIGHT OF APPEAL DECISION. 01/25/19 TGB TELEPHONE CONFERENCE WITH T. ELLIOTT 06 $294.00 RE APPEAL STRATEGIES AND PLAN PROCESS GOING FORWARD.
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RR a . Date Timekeeper Description Hours Amount Amour 03/49/19 TGB TELEPHONE CONFERENCE WITH T. ELLIOTT 03 $147.00 RE STATE COURT PROCEEDINGS UPDATE. 03/21/19 TGB REVIEWED CORRESPONDENCE AND 0.3 $147.00 STIPULATION IN STATE COURT LITIGATION RE ADDITIONAL APPELLATE FEES (1): TELEPHONE CONFERENCE WITH T. ELLIOTT RE SAME (.2). 05/30/19 TGB TELEPHONE CONFERENCE WITH T. ELLIOTT 0.3 $147.00 RE DUPAGE COUNTY LITIGATION INVOLVING THE DEBTOR AND STATUS OF PLAN PROCESS. SUBTOTAL: PREPETITION LITIGATION 4.7 $833.00 PROCEDURAL MOTIONS/STATUS HEARINGS 01/09/19 TGB ATTENDED STATUS HEARING IN FISHER 0.3 $147.00 ADVERSARY PROCEEDING. 01/24/19 TGB BEGAN DRAFTING MOTION FOR AUTHORITY 0.7 $343.00(1) Unreasonab TO SELL CONDO. reduced by 50% 01/25/19 AJG PREPARED AND REVISED MOTION TO FIX BAR 12 $588.00 DATE INCLUDING PROPOSED BAR DATE NOTICE AND PROPOSED ORDER. 01/25/19 TGB CONFERRED WITH A. GUON RE 6.0 $2,940.00(1) Unreasonebl BACKGROUND FOR CLAIMS BAR DATE reduced by 50% MOTION (.3); CONTINUED DRAFTING, EDITING AND RESEARCHING MOTION TO APPROVE SALE OF CONDO FREE AND CLEAR AND FOR RELATED RELIEF (5.7). 01/28/19 TGB EDITED DRAFTED MOTION TO SET CLAIMS 3.9 $1,911.00 BAR DATE, NOTICE OF BAR DATE AND PROPOSED ORDER SETTING CLAIMS BAR DATE (3.7); TELEPHONE CONFERENCE WITH A. GUON RE BAR DATE MOTION (.2). 01/29/19 TGB CONTINUED DRAFTING AND EDITING MOTION 3.3 $1,617.00(1) □□□□□□□□□□□□ TO SELL CONDO (1.2); DRAFTED AND EDITED reduced by 50% PROPOSED ORDER GRANTING MOTION TO SELL CONDO (2.1). 01/31/19 TGB EDITED SALE MOTION AND PROPOSED 24 $1,029.00(1) Unreasonable ORDER TO PROVIDE FORMS OF ADDITIONAL reduced by 50% RELIEF (1.2); LEGAL RESEARCH RE SCOPE OF RULE 70(A) IN CONNECTION WITH GLOSING DOCUMENT EXECUTION (9). 02/01/19 TGB EDITED, FINALIZED AND FILED MOTION TO 12 $588.00(1) Unreasonable SELL CONDO FREE AND CLEAR. reduced by 50% 02/04/19 TGB DRAFTED AND FILED AMENDED PROOF OF 0.2 $98.00(1) Unreasonable SERVICE OF CONDO CASE MOTION. reduced by 50% 02/05/19 TGB REVIEWED BAR DATE MOTION, NOTICE OF 1.7 $833.00 (3) Local BAR DATE AND PROPOSED ORDER IN Travel PREPARATION FOR HEARING ON MOTION (.6): ATTEND HEARING ON BAR-DATE MOTION (.1): TRAVEL TO/FROM COURT TO ATTEND HEARING ON BAR-DATE MOTION (6): PER Page 31
OO EEE a - - Date Timekeeper Description Hours Amount COURT ORDER, DRAFTED REVISED ORDER SETTING BAR DATE (.1); DRAFTED CORRESPONDENCE TO COURT SUBMITTING SAME (.3). 02/08/19 TGB REVIEWED ENTERED BAR-DATE ORDER. 0.1 $49.60 02419 TGB WORKED ON SERVICE OF BAR-DATE ORDER 0.3 $147.00 ON ALL CREDITORS. 02/12/19 TGB REVIEWED AND EDITED CERTIFICATE OF 0.2 $98.00 SERVICE OF BAR-DATE ORDER. 02/13/19 TGB REVIEWED SALE MOTION AND PREPARED 1.6 $784.00 FOR HEARING ON SAME (.6): APPEARED IN COURT ON MOTION TO SELL CONDO AND STATUS iN FISHER ADVERSARY (4); EDITED SALE ORDER PER COURT DIRECTIVE AT HEARING AND DRAFTED CORRESPONDENCE TO COURT SUBMITTING SAME (6). 02/14/19 TGB REVIEWED ENTERED ORDER GRANTING 0.2 $98.00 MOTION TO SELL CONDO. 03/20/19 TGB REVIEWED FEE APPLICATION IN 41 $539.00 (4) No PREPARATION FOR HEARING ON SAME (.8):; Benefit to ATTENDED HEARING ON FEE APPLICATION Estate AND STATUS IN FISHER ADVERSARY. 03/24/19 TGB REVIEWED FINDINGS OF FACT AND O5 $245.00 (4) No CONCLUSIONS OF LAW RE FEE APPLICATION Benefit to AND CALCULATED AMOUNTS PAYABLE TO Estate FIRM AND REFUNDABLE TO J. PORADA. 03/26/19 BRD COMMUNICATIONS WITH BANICH REGARDING 0.1 $37.00 {5} COVERAGE OF HEARING. Overhead 04/01/19 TGB DRAFTED CORRESPONDENCE TO Cc. 0.4 $49.00 (5) SANFELIPPO RE HEARING IN FISHER Overhead ADVERSARY ON APRIL 2. 64/01/19 DRD COMMUNICATIONS WITH C. SANFELIPPO, T. 05 $485.00 □□□□□ BANICH AND A. GUON REGARDING COVERAGE ISSUES. 05/14/19 TGB PREPARED FOR HEARING IN FISHER 1.2 $588.00 □□□□□□□□ ADVERSARY (.5); ATTENDED SAME (2) Travel TRAVEL TO/FROM COURT FOR HEARING (5). 05/21/19 TGB ATTENDED STATUS HEARING ON CHAPTER 71 6.9 $444.00 (3) Local CASE, AND CONFERRED WITH COUNSEL FOR Travel US TRUSTEE AND CHING/HEATH CREDITORS RE SAME AND TIMING OF FILING DISCLOSURE STATEMENT/PLAN (.3}: TRAVELED TO/FROM COURT FOR HEARING (.6). 06/06/19 TGB DRAFTED PROPOSED ORDER ON PLAN AND 0.4 $206.00 DISCLOSURE STATEMENT DEADLINE (2); DRAFTED CORRESPONDENCE TO COURT ATTACHING SAME, PER COURT'S DRAFT ORDER TO FOLLOW PROCEDURES (2). 06/07/19 TGB REVIEWED ENTERED SCHEDULING ORDER. 0.1 $51.50 06/19/19 TGB ATTENDED STATUS HEARING IN FISHER 1.0 $515.00 (3) Local ADVERSARY (.2); TRAVELED TO/FROM COURT Travel Page 32
IIR EE a 1 I TR tr rr Date Timekeeper Description Hours Amount FOR HEARING IN FISHER ADVERSARY (8). TGB DRAFTED AND EDITED MOTION TO EXTEND 0.8 $412.00 TIME TO FILE PLAN AND DISCLOSURE STATEMENT, AND PROPOSED ORDER ON SAME. O7/15/19 TGB DRAFTED, EDITED AND FILED AMENDED 0.9 $463.50 MOTION FOR EXTENSION OF TIME TO FILE PLAN/DISCLOSURE STATEMENT DUE TO SURGERY. TGB ATTENDED HEARING ON MOTION TO EXTEND 1.4 $566.50 = (3) Loca’ TIME TO FILE PLAN AND DISCLOSURE Travel STATEMENT AND STATUS IN FISHER ADVERSARY (.3); TRAVEL TO/FROM COURT FOR HEARING (8). 07/18/19 TGB REVIEWED ORDER GRANTING MOTION TO 0.2 $103.06 EXTEND TIME (.1}); DRAFTED CORRESPONDENCE TO J. PORADA RE SAME (1). 09/10/19 TGB DRAFTED AND EDITED MOTION TO 2.1 $1,081.50 WITHDRAW AS COUNSEL AND PROPOSED ORDER FOR SAME (.8); DRAFTED AND EDITED MOTION FOR EXTENSION OF TIME TO FILE PLAN AND DISCLOSURE STATEMENT AND PROPOSED ORDER FOR SAME (.8); EXCHANGED CORRESPONDENCE WITH K, MORGAN RE TRANSITION OF REPRESENTATION AND MOTIONS TO WITHDRAW AND EXTENSION OF TIME (.1}; DRAFTED AND FILED AMENDED PROOFS OF SERVICE FOR BOTH MOTIONS (.4). 09/18/19 SBT ATTEND HEARING ON MOTION TO EXTEND 1.5 $1,200.06 TIME TO FILE PLAN AND MOTION TO WITHDRAW, SUBTOTAL: PROCEDURAL MOTIONS/STATUS HEARINGS 35.5 $17,953.00 TAX ANB FINANCIAL MATTERS TGB EXCHANGED CORRESPONDENCE WITH J. 6.4 349.00 WORTHEN RE CHAPTER 41 NEXT STEPS. 01/25/19 TGB TELEPHONE CONFERENCE WITH J. WORTHEN 0.6 $294.00 RE FINANCIAL MATTERS RE ESTATE. 04/04/19 TGB REVIEWED CORRESPONDENCE FROM R. 0.3 $147.00 LYNCH WITH ILLINOIS DEPARTMENT OF REVENUE RE CLAIM AND STATUS OF RETURNS FILED FOR PRIOR TAX YEARS (.1); DRAFTED CORRESPONDENCE TO J. WORTHEN RE SAME (.1); REVIEWED CORRESPONDENCE FROM J. PORADA AND J. WORTHEN RE SAME (1). 04/15/19 TGB REVIEWED AND EXCHANGED 04 $196.00 CORRESPONDENCE WITH J. WORTHEN RE RECENT TAX INQUIRIES (.2): REVIEWED IRC SECTION 1398 IN CONNECTION WITH J. WORTHEN TAX INQUIRIES (.2}. Page 33
IIR EE □□ tr fer Date Timekeeper Description Hours Amount a 04/22/19 TGB REVIEWED CORRESPONDENCE FROM IL 0.3 $147.00 DEPARTMENT OF REVENUE RE UNFILED TAX RETURNS (.1); REVIEWED AND DRAFTED CORRESPONDENCE WITH J. PORADA AND J. WORTHEN RE SAME (2). TGB TELEPHONE CONFERENCE WITH J. WORTHEN 1.2 $618.00 RE TAX LIABILITY/REFUND FOR PURPOSES OF DISCLOSURE STATEMENT AND CLAIMS ANALYSIS (.6); DRAFTED LENGTHY SUMMARY OF CALL WITH J. WORTHEN TO S. TOWBIN AND A. GUON (.6). TGB TELEPHONE CONFERENCE WITH J. WORTHEN 0.7 $360.50 RE TAX ISSUES. SUBTOTAL: TAX AND FINANCIAL MATTERS 3.6 $1,811.50 TOTAL 273.9 $121,836.50 TASK SUMMARY: Task Description Hours Totai ni ee COMMUNICATIONS WITH US TRUSTEE 1.7 $858.00 COMMUNICATIONS/MEETINGS WITH DEBTOR 42.0 $21,438.00 COUNTRY ACRES MATTERS 41.9 $15,809.00 CREDITOR CLAIMS/COMMUNICATIONS 3.0 $1,490.06 FEE APPLICATIONS 7.2 $8,497.50 FISHER ADVERSARY 72.0 $31,003.00 OPERATING REPORTS 27.6 $7,859.00 PLAN AND DISCLOSURE STATEMENT 277 $14,284.50 PREPETITION LITIGATION V7 $833.00 PROCEDURAL MOTIONS/STATUS HEARINGS 35.5 $17,953.00 TAX AND FINANCIAL MATTERS 36 $1,811.50
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IIR EE a TIMEKEEPER TIME SUMMARY: Timekeeper Title Hours Rate Total T.G. BANICH PARTNER 42.5 $515.00 $21,887.50 T.G. BANICH PARTNER 130.3 $490.00 $63,847.60 T.G. BANICH PARTNER 0.3 $0.00 $0.00 R.W. GLANTZ PARTNER 06 $550.00 $330.00 TOWBIN PARTNER 5.0 $800.00 $4,000.00 S.B. TOWBIN PARTNER 1.5 $750.00 $1,125.00 J.L. GOLDSTONE PARTNER 8.7 $425.00 $3,697.50 A.J. GUON PARTNER 12.9 $520.00 $6,708.00 A.J. GUON PARTNER 47 $490.00 $2,303.00 J.L. DEVROYE ASSOCIATE 17.6 $365.00 $6,424.00 D.R. DOYLE ASSOCIATE 0.3 $395.00 $118.50 D.R. DOYLE ASSOCIATE 0.8 $370.00 $296.00 C.M. SANFELIPPO ASSOCIATE 1.0 $290.00 $290.00 R. DAMON PARALEGAL 13.1 $200.00 $2,620.00 P. FREDERICKS PARALEGAL 11.6 $250.00 $2,900.00 P. FREDERICKS PARALEGAL 23.0 $230.00 $5,290.00 TOTAL 273.9 $121,836.50 TOTAL PROFESSIONAL SERVICES $121,836.50
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COSTS ADVANCED AND EXPENSES INCURRED: EXPENSE DETAIL: Date Description Amount tg RECORD MORTGAGE KENDALL COUNTY RECORDER $49.00 01/16/19 RECORD MORTGAGE KENDALL COUNTY RECORDER $49.00 O116/19 RECORD MORTGAGE KENDALL COUNTY RECORDER $49.00 01/16/19 RECORD MORTGAGE KENDALL COUNTY RECORDER $49.00 01/16/19 RECORD MORTGAGE KENDALL COUNTY RECORDER $49.00 RECORD MORTGAGE KENDALL COUNTY RECORDER $51.00 01/6/19 POSTAGE CHARGES $2.26 01/16/49 POSTAGE CHARGES $1.21 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $30.17 643470970 Paid to: Fedex per 5333 Ship Ta: Maximilian Ortega Ship Dt: 01/14/19 Airbill: 784960185129 01/23/19 MISCELLANEOUS OUTSIDE SERVICES KENDALL $49.00 COUNTY RECORDER This check is needed to record a lis pendens with the Kendail County Recorder. 01/23/19 TITLE SEARCH CHICAGO TITLE COMPANY LLC $7150.00 04/23/19 POSTAGE CHARGES $0.94 01/25/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $28.54 644119917 Paid to: Fedex per 5352 Ship To: Ship Dt: 01/16/19 Airbil: 785007339001 01/28/19 POSTAGE CHARGES $13.50 02/01/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $28.89 644823040 Paid to: Fedex per 5352 Ship To: Ship Dt: 01/23/19 Airbil: 785101666225 02/01/19 POSTAGE CHARGES $13.50 02/01/19 COURT FILINGS WELLS FARGO CC DEBTORS MOTION $181.00 TO AUTHORIZE SALE OF COUNTRY ACRES CONDOMINIUM OUTSIDE THE ORDINAR Y COURSE OF BUSIENSS, TO SHORTEN NOTICE AND FOR RELATED RELIEF. 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $34.28 645502089 Paid to: Fedex per 5352 Ship To: Jim Stubblefield, Secretary Ship Dt: 02/04/19 Airbilf: 785275199835 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $45.62 645502089 Paid to: Fedex per 5352 Ship To: c o Sandra T Kahn Ship Dt: 02/04/19 Airbill: 785275179580 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $34.28 645502089 Paid to: Fedex per 5352 Ship To: Joseph J Porada, Jr Ship Dt: 02/04/19 Airbill: 785275220731 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $29.62 645502089 Paid to: Fedex per 5352 Ship To: Attn Goran Utvic Ship Dt: 02/04/19 Airbill: 785275242909 Page 36
OO EEE a 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $29.62 645502089 Paid to: Fedex per 5352 Ship To: Attn President, Managing Agen Ship Dt 02/04/19 Airbill: 785275271490 02/08/19 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $29.62 645502089 Paid to: Fedex per 5352 Ship To: Law Department Ship Dt: 02/04/19 Airbill: 785275285327 02/11/49 POSTAGE CHARGES $16.00 02/15/19 PROFESSIONAL SERVICES CITY OF DES PLAINES $25.00 02/15/19 POSTAGE CHARGES $1.15 03/08/19 POSTAGE CHARGES $1.60 03/08/19 POSTAGE CHARGES $13.50 03/43/19 POSTAGE CHARGES $1.00 MESSENGER SERVICE/FEDERAL EXPRESS Invoice No: $11.66 649169922 Paid to: Fedex per 99999 Ship To: JENNIFER LA MELL GOLSDSTONE Ship Dt: 03/07/19 Airbilk: 774649519754 03/25/19 POSTAGE CHARGES $7.45 03/26/19 POSTAGE CHARGES $1.00 03/31/19 PUBLICATION/RESEARCH WEST PAYMENT CENTER $33.70 Westlaw KM #205 04/24/19 COSTS ADVANCED-FEDEX #0003469691 ($126.73) 05/30/19 MESSENGER SERVICE/FEDERAL EXPRESS-FEDEX ($41.11) #0003510 05/30/19 MESSENGER SERVICE/FEDERAL EXPRESS-FEDEX ($11.11) #0003510 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($11.11) #00036 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($414.14) #00036 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($11.57) #36433 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($11.57) #36433 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($11.57) #36433 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($11.57) #36433 06/18/19 MESSENGER SERVICE/FEDERAL EXPRESS- FEDEX- ($14.57) #36433 07/14/19 POSTAGE CHARGES $14.00 POSTAGE CHARGES $14.00 09/19/19 TAXIVUBER - LOCAL TRAVEL EXPENSE STEVEN 8. $8.00 (3) Locai Trave! TOWBIN 9/18 ATTEND COURT
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IIR EE "EXPENSE SUMMARY: Description Amount COURT FILINGS $181.06 MESSENGER SERVICE/FEDERAL EXPRESS $200.01 MISCELLANEOUS OUTSIDE SERVICES $49.00 POSTAGE CHARGES $101.11 PROFESSIONAL SERVICES $25.00 PUBLICATION/RESEARCH $33.70 RECORD MORTGAGE $296.00 TAXVUBER - LOCAL TRAVEL EXPENSE $8.00 TITLE SEARCH $150.00 COSTS ADVANCED ($126.73) TOTAL EXPENSES $917.09 TOTAL BALANCE DUE UPON RECEIPT ___$122,753.59
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