UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: ) ) Case No. 17bk36268 JOSEPH J PORADA, JR. ) ) Chapter 11 Debtor. ) ). Honorable Timothy A. Barnes FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO RATHJE & WOODWARD, LLC, SPECIAL COUNSEL FOR JOSEPH J PORADA, JR., FOR ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $63,543.00 =TOTALCOSTS REQUESTED: $72.55 TOTAL FEES REDUCED: $ 1,001.00 TOTAL COSTS REDUCED: $ 0.00 TOTAL FEES ALLOWED: $ 62,542.00 TOTAL COSTS ALLOWED: $72.55 TOTAL FEES AND COSTS ALLOWED: $62,614.55 ‘The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by numerical notations that appear on the left of each underlined entry. The numerical notations correspond to the enumerated paragraphs below. (1) Lumping — TOTAL of disallowed amounts (10% of affected entries): $ 871.00 ‘The Court may impose a ten percent penalty on entries that appear to be “lumping.” ‘The Court will reduce each entry marked as such per the penalty. In re Wildman, 72 B.R. 700, 709 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“Applicants may not circumvent the minimum time requirement or any of the requirements of detail by “lumping” a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.”’). (2) Unreasonable Time — TOTAL of disallowed amounts: $ 130.00 The Court denies the allowance in part of compensation for the indicated task(s) since the professional or paraprofessional expended an unreasonable amount of time on the task(s) in hght of the nature of the task(s), the experience and knowledge of the professional performing the task(s), and the amount of time previously expended by the professional or another on the task(s). In re Pettibone, 74 B.R. 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“The Court will determine what is the reasonable amount of time 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.’’); In re Wildman, 72 B.R. 700, 713 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (same). As to the time devoted to the preparation of the fee application itself, the Court denies the allowance of compensation that is disproportionate to the total hours in the main case. In re
Wildman, 72 B.R. 700, 711 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“In the absence of unusual circumstances, the hours allowed by this Court for preparing and litigating the attorney fee application should not exceed three percent of the total hours in the main case.’”); In re Spanjer Bros., Inc, 203 B.R. 85, 93 (Bankr. N.D. Ill. 1996) Squires, J.) (compensation limited to 5%); see also In re Pettibone Corp., 74 B.R. 293, 304 (Bankr. N.D. IIL. 1987) (Schmetterer, J.) (ting Coulter v. State of Tennessee, 805 F.2d 146, 151 (6th Cir. 1986) (in nonbankruptcy cases, compensation for preparation and litigation of fee petitions limited to 3-5% of the hours of the main case)).
S> C.D. Dated: December 14, 2020 Se Timothy Bares United States Bankruptcy Judge
300 Roosevelt Road Suite 300 Wheaton, IL 60187 USA Ph: 630-668-8500 Fax:630-668-9218 JosephPorada November 4,2020 P.O. Box 31232 Chicago,IL File#: JSW17373 60631-0232 Inv#: Settle RE: State Court Litigation/Appeal/ Bankruptcy Case No.17-36268 DATE DESCRIPTION HOURS AMOUNT LAWYER Oct-09-18 Draft motion to file reply brief instanter. 0.30 78.00 DPH Oct-18-18 Confer with T. Elliott and D. Hollander (.30); cite 4.50 675.00 NW check brief (3.10); format, finalize and efile same (.90); serve on opposing counsel (.20). Nov-26-18 Prepare for hearing on Rathje application for 0.80 260.00 CLP compensation; review case filings regarding same. Nov-27-18 Prepare for and participate in hearing on Rathje 1.10 357.50 CLP application for compensation. Mar-08-19 Review fee petition. 0.30 97.50 TDE Mar-19-19 Review fee petition; telephone conference with 0.50 162.50 TDE opposing counsel re same. Apr-03-19 Review fee petition; telephone conference with client 0.60 195.00 TDE re same; execute stipulation. May-14-19 Review documents for production. 0.90 292.50 TDE May 20-19 Review documents for production and prepare for 0.80 260.00 TDE production. Jun-06-19 Review document demand; forward same to client. 0.20 65.00 TDE Jun-19-19 Correspondence with T. Banich; locate and review 0.20 65.00 TDE assignment documents. Jun-21-19 Draft response to R. Minetz. 0.40 130.00 TDE Jul-15-19 Tax matters and Tax liability estimates review with 0.40 130.00 JSW T. Banich and J. Porada. Sep-05-19 Review documents for production. 0.30 97.50 TDE DISBURSEMENTS Oct-18-18 UPS –Delivery to Clerk of Appellate Court 22.24 Oct-31-18 Westlaw –Online Research 3.48 Westlaw –Online Research 24.33 Nov-06-18 Pacer Research 0.50 Nov-19-18 Pacer Research 2.20 Nov-26-18 Pacer Research 4.20 Dec-12-18 Pacer Research 8.10 Jan-16-19 Pacer Research 0.90 Aug-12-19 Pacer Research 2.30
Totals $68.25 Total Fee & Disbursements for all charges on this $2,933.75 matter TAX ID Number 36-2705396 300RSouoistee v3e0l0t Road Wheaton, IL 60187 USA Ph: 630-668-8500 Fax:630-668-9218 JosephPorada November 4,2020 P.O. Box 31232 Chicago,IL File#: jsw18318 60631-0232 Inv#: Settle RE: General DATE DESCRIPTION HOURS AMOUNT LAWYER Oct-14-19 Perform title search of PINS 16-29-100-001 and 002; 0.30 45.00 DDJ review Trustee’s Deed conveying 6339-47 W. Cermak Road property to CBN Partners, LTD and JJPRidgelandKKJJ, LLC; review and respond to email from J. Worthen attaching trustee’s deed. Apr-16-20 Review FP documents research re: spendthrift 1.30 422.50 JSW clauses; ecommunications to K. Morgan, J. Porada regarding same. Apr-17-20 Further research regarding spendthrift clauses and 2.20 715.00 JSW revocable trust legal status; ecommunications to K. Morgan regarding same. Apr-20-20 Florence Porada matters related to Bankruptcy Estate 1.50 487.50 JSW assets and liabilities; ecommunications to K. Morgan regarding memorandum. Apr-21-20 General research, document review and related due 1.60 520.00 JSW diligence in connection with general trust law, Illinois Trust Code. (1) Lumping Reduced 10%/$52 Apr-22-20 Continued general research, and related due diligence 2.20 715.00 JSW in connection with general trust law, Illinois Trust Code; draft of conflict memorandum. (1) Lumping Reduced 10%/$71.5 Apr-23-20 Continued general research, and related due diligence 1.80 585.00 JSW in connection with general trust law, Illinois Trust Code; finalization of Conflict Memorandum and (1) Lumping reviews with T. Elliott Reduced Code Secs 108/1017 tax attribute reductions, and related planning. (1) Lumping Reduced 10%/97.5 Apr-28-20 Review of draft settlement agreement and ordering of 5.50 1,787.50 JSW structural matters; memorandum regarding same preparation and ecommunication (2.80) delivery to K. Morgan, J. Porada (2.70). Review Supreme Court Rule 23 Order. 0.30 45.00 CC Apr-29-20 Reviews of draft settlement and related tax matters, 1.40 455.00 JSW and RFREINV status with K. Morgan, J. Porada. Call with Chancery Division; request copy of 0.40 60.00 CC Opinion Order. Apr-30-20 Review (1.80) and revisions (2.80) to draft settlement 4.80 1,560.00 JSW agreement; ecomm delivery of same to K. Morgan (0.20). May-05-20 Continued revisions to draft settlement agreement 7.30 2,372.50 JSW (3.40); Ecomm delivery of same to K. Morgan (0.30); tax research regarding discharge and court- approved plan definitions for Code Sec 108 (2.40); telephone conferences with K. Morgan, J. Porada, and K. Morgan and D.
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UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: ) ) Case No. 17bk36268 JOSEPH J PORADA, JR. ) ) Chapter 11 Debtor. ) ). Honorable Timothy A. Barnes FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO RATHJE & WOODWARD, LLC, SPECIAL COUNSEL FOR JOSEPH J PORADA, JR., FOR ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $63,543.00 =TOTALCOSTS REQUESTED: $72.55 TOTAL FEES REDUCED: $ 1,001.00 TOTAL COSTS REDUCED: $ 0.00 TOTAL FEES ALLOWED: $ 62,542.00 TOTAL COSTS ALLOWED: $72.55 TOTAL FEES AND COSTS ALLOWED: $62,614.55 ‘The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by numerical notations that appear on the left of each underlined entry. The numerical notations correspond to the enumerated paragraphs below. (1) Lumping — TOTAL of disallowed amounts (10% of affected entries): $ 871.00 ‘The Court may impose a ten percent penalty on entries that appear to be “lumping.” ‘The Court will reduce each entry marked as such per the penalty. In re Wildman, 72 B.R. 700, 709 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“Applicants may not circumvent the minimum time requirement or any of the requirements of detail by “lumping” a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.”’). (2) Unreasonable Time — TOTAL of disallowed amounts: $ 130.00 The Court denies the allowance in part of compensation for the indicated task(s) since the professional or paraprofessional expended an unreasonable amount of time on the task(s) in hght of the nature of the task(s), the experience and knowledge of the professional performing the task(s), and the amount of time previously expended by the professional or another on the task(s). In re Pettibone, 74 B.R. 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“The Court will determine what is the reasonable amount of time 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.’’); In re Wildman, 72 B.R. 700, 713 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (same). As to the time devoted to the preparation of the fee application itself, the Court denies the allowance of compensation that is disproportionate to the total hours in the main case. In re
Wildman, 72 B.R. 700, 711 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“In the absence of unusual circumstances, the hours allowed by this Court for preparing and litigating the attorney fee application should not exceed three percent of the total hours in the main case.’”); In re Spanjer Bros., Inc, 203 B.R. 85, 93 (Bankr. N.D. Ill. 1996) Squires, J.) (compensation limited to 5%); see also In re Pettibone Corp., 74 B.R. 293, 304 (Bankr. N.D. IIL. 1987) (Schmetterer, J.) (ting Coulter v. State of Tennessee, 805 F.2d 146, 151 (6th Cir. 1986) (in nonbankruptcy cases, compensation for preparation and litigation of fee petitions limited to 3-5% of the hours of the main case)).
S> C.D. Dated: December 14, 2020 Se Timothy Bares United States Bankruptcy Judge
300 Roosevelt Road Suite 300 Wheaton, IL 60187 USA Ph: 630-668-8500 Fax:630-668-9218 JosephPorada November 4,2020 P.O. Box 31232 Chicago,IL File#: JSW17373 60631-0232 Inv#: Settle RE: State Court Litigation/Appeal/ Bankruptcy Case No.17-36268 DATE DESCRIPTION HOURS AMOUNT LAWYER Oct-09-18 Draft motion to file reply brief instanter. 0.30 78.00 DPH Oct-18-18 Confer with T. Elliott and D. Hollander (.30); cite 4.50 675.00 NW check brief (3.10); format, finalize and efile same (.90); serve on opposing counsel (.20). Nov-26-18 Prepare for hearing on Rathje application for 0.80 260.00 CLP compensation; review case filings regarding same. Nov-27-18 Prepare for and participate in hearing on Rathje 1.10 357.50 CLP application for compensation. Mar-08-19 Review fee petition. 0.30 97.50 TDE Mar-19-19 Review fee petition; telephone conference with 0.50 162.50 TDE opposing counsel re same. Apr-03-19 Review fee petition; telephone conference with client 0.60 195.00 TDE re same; execute stipulation. May-14-19 Review documents for production. 0.90 292.50 TDE May 20-19 Review documents for production and prepare for 0.80 260.00 TDE production. Jun-06-19 Review document demand; forward same to client. 0.20 65.00 TDE Jun-19-19 Correspondence with T. Banich; locate and review 0.20 65.00 TDE assignment documents. Jun-21-19 Draft response to R. Minetz. 0.40 130.00 TDE Jul-15-19 Tax matters and Tax liability estimates review with 0.40 130.00 JSW T. Banich and J. Porada. Sep-05-19 Review documents for production. 0.30 97.50 TDE DISBURSEMENTS Oct-18-18 UPS –Delivery to Clerk of Appellate Court 22.24 Oct-31-18 Westlaw –Online Research 3.48 Westlaw –Online Research 24.33 Nov-06-18 Pacer Research 0.50 Nov-19-18 Pacer Research 2.20 Nov-26-18 Pacer Research 4.20 Dec-12-18 Pacer Research 8.10 Jan-16-19 Pacer Research 0.90 Aug-12-19 Pacer Research 2.30
Totals $68.25 Total Fee & Disbursements for all charges on this $2,933.75 matter TAX ID Number 36-2705396 300RSouoistee v3e0l0t Road Wheaton, IL 60187 USA Ph: 630-668-8500 Fax:630-668-9218 JosephPorada November 4,2020 P.O. Box 31232 Chicago,IL File#: jsw18318 60631-0232 Inv#: Settle RE: General DATE DESCRIPTION HOURS AMOUNT LAWYER Oct-14-19 Perform title search of PINS 16-29-100-001 and 002; 0.30 45.00 DDJ review Trustee’s Deed conveying 6339-47 W. Cermak Road property to CBN Partners, LTD and JJPRidgelandKKJJ, LLC; review and respond to email from J. Worthen attaching trustee’s deed. Apr-16-20 Review FP documents research re: spendthrift 1.30 422.50 JSW clauses; ecommunications to K. Morgan, J. Porada regarding same. Apr-17-20 Further research regarding spendthrift clauses and 2.20 715.00 JSW revocable trust legal status; ecommunications to K. Morgan regarding same. Apr-20-20 Florence Porada matters related to Bankruptcy Estate 1.50 487.50 JSW assets and liabilities; ecommunications to K. Morgan regarding memorandum. Apr-21-20 General research, document review and related due 1.60 520.00 JSW diligence in connection with general trust law, Illinois Trust Code. (1) Lumping Reduced 10%/$52 Apr-22-20 Continued general research, and related due diligence 2.20 715.00 JSW in connection with general trust law, Illinois Trust Code; draft of conflict memorandum. (1) Lumping Reduced 10%/$71.5 Apr-23-20 Continued general research, and related due diligence 1.80 585.00 JSW in connection with general trust law, Illinois Trust Code; finalization of Conflict Memorandum and (1) Lumping reviews with T. Elliott Reduced Code Secs 108/1017 tax attribute reductions, and related planning. (1) Lumping Reduced 10%/97.5 Apr-28-20 Review of draft settlement agreement and ordering of 5.50 1,787.50 JSW structural matters; memorandum regarding same preparation and ecommunication (2.80) delivery to K. Morgan, J. Porada (2.70). Review Supreme Court Rule 23 Order. 0.30 45.00 CC Apr-29-20 Reviews of draft settlement and related tax matters, 1.40 455.00 JSW and RFREINV status with K. Morgan, J. Porada. Call with Chancery Division; request copy of 0.40 60.00 CC Opinion Order. Apr-30-20 Review (1.80) and revisions (2.80) to draft settlement 4.80 1,560.00 JSW agreement; ecomm delivery of same to K. Morgan (0.20). May-05-20 Continued revisions to draft settlement agreement 7.30 2,372.50 JSW (3.40); Ecomm delivery of same to K. Morgan (0.30); tax research regarding discharge and court- approved plan definitions for Code Sec 108 (2.40); telephone conferences with K. Morgan, J. Porada, and K. Morgan and D. Devit regarding closing and funding structure issues and related matters (1.20). May-06-20 Review of settlement agreement release scope, 0.70 227.50 JSW closing order and structure and related tax matters with J. Porada; title insurance matters review with K. Morgan. (1) Lumping Reduced 10%/22.75 May-11-20 Review of Berwyn title commitment in connection 0.50 162.50 JSW with Settlement Agreement due diligence; comments to K. Morgan. May-12-20 Settlement virtual conference with attorneys to 2.30 747.50 JSW review settlement agreement, and tax compliance and related indemnity issues, and preparationtherefor. Correspondence with Cook County Chancery 0.50 75.00 CC regarding Opinion. May-13-20 Tax matters related to 2017 transfers of investment 3.50 1,137.50 JSW interests to Claimants (0.80), related review of court record for decisions as to valuation methods (1.50), and related ecomms (0.50), telephone conference with C. Cain (0.30), K. Morgan (0.50), T. Elliott re same. Review and forward documents regarding Cook 1.70 255.00 CC County case to JSW. May-14-20 Continued review of Court record and related 6.40 2,080.00 JSW document retrieval matters in connection with valuation of investment interests for tax reporting purposes (3.40); telephone conference with Don Devit regarding Settlement Agreement tax issues and related matters, and preparation therefore (3.00). Review Settlement Documents. 2.00 300.00 CC May-15-20 Preparation of Tax Memo file (2.30); ecomm to JJP, 4.40 1,430.00 JSW K. Morgan including proposed order of events prior to settlement and closing execution, and tax compliance matters (1.80); request to R. Minetz regarding Heath Trust and Estate matters (0.30). May-20-20 Review of Bankruptcy Plan implications related to 1.50 487.50 JSW calculation of tax liability as of 12-6-2017 (0.70); recommended Settlement Agreement terms for income tax matters , preparation and delivery to J. Porada (0.80). May-21-20 Telephone conference with J. Porada and K. Morgan 3.80 1,235.00 JSW to review client concerns with Settlement Agreement and related matters (2.00); telephone conference with J. Porada to review legal fee matters and related tax considerations, and to review restructure of Settlement transactions by assigning rights to purchase Ciebien interests in Berwyn property to JJP Ridgeland KKJJ, LLC (1.00); review of cash flows for proposed transactions (0.80). May-22-20 Preparation of detailed Sources and Applications of 2.50 812.50 JSW Funds and Cash Transfer schedule for review by client and bankruptcy counsel in connection with restructuring of Settlement. Jun-13-20 Porada Settlement Agreement closing order escrow 0.50 162.50 JSW instructions review and transmittal to K. Morgan. Jun-18-20 Porada Settlement Agreement closing order escrow 0.50 162.50 JSW instructions review and transmittal to J. Porada. Jun-22-20 Pre-petition tax liability matter review with K. 0.40 130.00 JSW Morgan. Jun-23-20 Review of Health probate court records and request 2.40 780.00 JSW for assignments evidencing transfer and related information from C. Latimer (0.60); review of adjusted settlement payment amounts with D. Devitt (0.40); proposed closing structure and steps preparation and transmittal to parties (1.40). Jun-24-20 Review of settlement agreement draft and revisions 3.80 1,235.00 JSW thereto in accord with proposed transaction structure and required closing steps (2.50); e-comms with D. Devitt and K. Morgan regarding same (1.00); delivery of draft to Sellers (0.30). Jun-25-20 Revisions to Settlement Agreement Escrow 3.80 1,235.00 JSW Instructions (1.20); transmittal to all attorneys of proposed accounting for Escrow Fund shares (0.40); Jun-26-20 Review of draft agreement with D. Devitt, and 2.60 845.00 JSW preparation therefor; preparation and transmittal of escrow instruction Accounting to D. Devitt. (1) Lumping Reduced 10%/$84.5 Jun-29-20 Review of tax claim matters and defenses thereto 0.60 195.00 JSW with K. Morgan; e-comm regarding same. Jun-30-20 Tax claim matter review and counterclaim matters. 0.40 130.00 JSW Jul-01-20 Computation and reconciliation of tax liabilities, 6.50 2,112.50 JSW penalties and interests on related to Seller 2017-19 JJP Ridgeland KKJJ LLC income shares in connection with settlement proposal for calendar years 2017 (2.2), 2018 (2.2), and 2019 (.80); various e-communications to Bob Minetz, Saskia Brian, and Keevan Morgan, in connection with partnership tax accounting matters; e-comm to J. Porada/K. Morgan regarding approach to offer (1.3). July-03-20 Development of alternative structures for Ciebien- 4.10 1,332.50 JSW Ching buyout in light of disputes with Rezai and Heath (1.80); financial transaction analyses preparation (1.70) and transmittal to JJP, KM (0.60). July-05-20 Preparation of 2017 and prior year J. Porada tax 2.40 780.00 JSW liability estimates for bankruptcy (2.10) and transmittal to K. Morgan (0.30). July-06-20 Request for Ridgeland Plaza Management Report 0.20 65.00 JSW from Joe Porada. July-09-20 Review of Devitt changes and revisions for tax claim 3.70 1,202.50 JSW settlement and related matters. Transmittal of draft to K. Morgan. July-10-20 Revisions to Escrow Instructions/Escrow 3.30 1,072.50 JSW Accounting, and related revisions to Draft Agreement; transmittal of draft to K. Morgan, J. Porada. (1) Lumping Reduced 10%/$107. 25 Jul-12-20 Tax settlement provisions and general review and 5.10 1,657.50 JSW revisions to Settlement Agreement (1.4); telephone conference with K. Morgan and J. Porada (1.5); further revisions to Agreement, ecomm transmittal of draft to all attorneys and client; revisions to Escrow Reduced Accounting and roll-forward of LLC estimated tax 10%/$71.5 (1) Lumping income for 2020 (2.2). transmittal to K. Morgan and J. Porada. Calls with J. Porada and K. Morgan re: tax matters and settlement of tax claim for 2020. (1) Lumping Reduced 10%/$58.5 July-16-20 Review of Settlement Agreement status and related 0.40 130.00 JSW matters with K. Morgan. July-17-20 Review and thoughts on Rezai-Heath counter 1.60 520.00 JSW offer and related matters with K. Morgan, J. Porada; tax language prep and transmittal to K. Morgan. July-22-20 Preparation of proposed tax changes to 3.40 1,105.00 JSW Settlement Agreement and transmittal to K. Morgan; review with JJP of economics of options to settlement globally v. only Ciebien- Ching. (1) Lumping Reduced 10%/$110. 5 July-23-20 Final review and transmittal of Proposed Tax 1.30 422.50 JSW Revisions to Settlement Agreement to all attorneys. July-24-20 Further review with JJP of economics of options 0.40 130.00 JSW to settlement globally v. only Ciebien-Ching. July-28-20 Review and response to KM, JJP re: Saskia 0.50 162.50 JSW Bryan remaining concerns on JSW Tax Proposals; review with KM regarding same. July-30-20 Further analysis of legal considerations of Stage 2.40 780.00 JSW Settlement and preparation of comparative financial analysis for 2017 bankruptcy filing, Global Settlement, and Stage Settlement; sent same to JJP; review and responses to JJP settlement agreement points toJJP and KM. (1) Lumping Reduced 10%/$78 July-31-20 Review of closing status with K. Morgan; review of 1.20 390.00 JSW Fee Petition. Aug-01-20 Conference call with K. D. Morgan and J. J. 1.60 520.00 JSW Porada to review settlement options and related tax adjustment provisions, and preparation therefor. Aug-07-20 Drafting comments to J. Porada; K. Morgan 1.20 390.00 JSW regarding further assurances provision and Mid America real estate valuation matters review with J. Porada. found in (1) JSW 7-30-2020 email to client clearing his points, (2) S. Bryan 7-3-20 email to K. Morgan, and (3) the August 5-20 emails to K. Morgan from R. Minetz. Aug-10-20 Review with K. Morgan client authorities as to 0.50 162.50 JSW issues regarding (1) avoiding real estate transfer taxes, (2) "further assurances" provision resolution with carve-out for post-closing “legal counseling” costs, and (3) elimination of Mid- America Asset Management release. Aug-11-20 Review with D. Devitt of document open points, 1.80 585.00 JSW including Mid-America release; escrow accounting revisions. Revisions to Settlement Agreement for tax settlement provisions ; Porada joint liability with JJP Ridgeland clarification. (1) Lumping Reduced 10%/$58.5 Aug-12-20 Agreement draft status matters. 0.40 130.00 JSW Aug-17-20 Preliminary review of client revisions to 1.50 487.50 JSW Settlement Agreement. Aug-18-20 Review of payment funding source matters with 0.50 162.50 JSW K. Morgan. Aug-21-20 Valuation and discount matter review with K. 0.40 130.00 JSW Morgan. Aug-26-20 Review and comment to client and K. Morgan 1.60 520.00 JSW re: client's proposed revisions; Mid-America release matters review with client and K. Morgan. Aug-27-20 Review and response to K. Morgan draft 1.20 390.00 JSW comments. Aug-28-20 Review of JJP settlement agreement points, 1.80 585.00 JSW development of responses thereto and related tax research. Aug-29-20 Review and resolution conference with J. Porada 2.80 910.00 JSW and K. Morgan regarding settlement agreement, and preparation of client instructions based on discussions for remaining negotiations and finalization of settlement agreement. Aug-30-20 Preparation for Devitt-Morgan-JSW negotiation; 0.60 195.00 JSW open points. Aug-31-20 Negotiation conference with K. Morgan and D. 1.70 552.50 JSW Devitt to review and resolve remaining open points; status report to J. Porada. Sept-01-20 Review of K. Morgan report to JJP on Ciebien 0.70 227.50 JSW response to real estate tax adjustment (0.4); review of JJP proposed adjustment to tax settlement formula tax rate (0.3). (0.8); preliminary review of Ridgeland Plaza July 2020 report (0.7); Review and revisions to Notice of Debtor's Motion to Approve Settlement Agreement (1.5), and delivery of proposed revisions to K.D. Morgan (0.3). Sept-08-20 Summary of proposed revisions and status of 1.60 520.00 JSW Devitt 8-21-20 agreement draft (1.2) and reviews with K. Morgan (0.4). Sept-11-20 Request to C. Syperski as to status of collections 1.10 357.50 JSW on 2016 judgment against Ciebien (0.5); review of 2016 judgment matters with K. Morgan (0.2); planning review with J. Porada as to using children trust as purchaser of JJP Ridgeland KKJJ, LLC membership interests under claimant settlement (0.4). (2) Unreas. Time Reduced .4/ $130 Sept-13-20 Confirmation of client instructions in connection with proposing adjustments to D. Devitt for seller credits regarding real estate tax proration, Ciebien release from Mid-America, and satisfaction of release 2016 judgment (0.8); assignment of purchaser rights to membership 1.20 390.00 JSW interests to KKJJ Irrevocable Trust (0.4). Sept-15-20 Delivery of 2016 judgement to D. Devitt and 1.30 422.50 JSW review status of its satisfaction (0.4); conversation with D. Devitt re: judgment satisfaction (0.4); review of real estate proration proposal with K. Morgan (0.5). Sept-16-20 Review and analysis of staged settlements (buy 2.50 812.50 JSW Ciebien now, buy Rezai, et al. later) with J. Porada (1.2); preparation of client direction confirmation memo for client (1.3). Sept-17-20 Confirmation of Client directions to K. Morgan 3.70 1,202.50 JSW (0.3); review of status of 2016 Judgment satisfaction evidence and remaining amount outstanding with K. Morgan ((0.4); research re: interest rate for partner advances (1.2); calculation of pre and post judgment interest due for excess contributions made by J. Porada to Ridgeland Joint Venture (1.8). Sept-18-20 Delivery of Ciebien response to proposed credits 0.60 195.00 JSW to J. Porada (0.3); proposal for resolution of 2106 unsatisfied judgment interest to J. Porada Sept-20-20 Review of settlement economic issues with J. 0.80 260.00 JSW Porada. Sept-21-20 Review of resolution for 2016 Ciebien 0.50 162.50 JSW Settlement matter with D. Devitt (0.3); request for confirmation of resolution to J. Porada (0.2). Sept-23-20 Reconciliation of pending transaction to real 2.20 715.00 JSW estate appraisals and cash at 12-31-2019 (1.9) and delivery to J. Porada and K. Morgan (0.3). Sept-25-20 Revisions to Settlement Agreement and Escrow 2.50 812.50 JSW Accounting for Ciebien credit and other revised numbers (2.2); transmittal to J. Porada (0.3). Sept-26-20 Review of revised agreement with J. Porada, and 1.80 585.00 JSW preparation therefor (1.1); transmittal of request for confirmation of approval regarding same (0.3); draft agreement to all attorneys (0.4). Sept-28-20 Revisions of Settlement Agreement Escrow 1.60 520.00 JSW Accounting for September RJV report (1.0); transmittal of revised report to all attorneys (0.3); transmittal of 2016 Judgment interest due to D. Devitt (0.3). Totals 161.8 $51,675.00 DISBURSEMENTS Mar-01-20 Pacer Research on 2/14/20 4.30 Totals $4.30 Total Fee & Disbursements for all charges on this $51,679.30 matter TAX ID Number 36-2705396 Rathje Woodward LLC 300 Roosevelt Road Suite 300 Wheaton, IL 60187 USA Ph: 630-668-8500 Fax:630-668-9218 JosephPorada November 4,2020 P.O. Box 31232 Chicago,IL File#: jsw18319 60631-0232 Inv#: Settle RE: Tax &Financial DATE DESCRIPTION HOURS AMOUNT LAWYER Dec-31-18 Review of status of payments in ordinary course of 0.60 195.00 JSW bankruptcy estate with T. Banich and related liquidation matters. Jan-03-19 Review of Bankruptcy status and outstanding admin 0.50 162.50 JSW payment matters with T. Banich; call to J. Porada re: same. Jan-05-19 Review of Bankruptcy status and outstanding admin 0.40 130.00 JSW payment matters with T. Banich; call and email to J. Porada re: same and liquidation of disputes. Mar-06-19 Review of J. Porada 2017 tax matters and Laura J. 1.60 520.00 JSW Porada 2009 Irrevocable Trust with J. Porada (0.80) and preparation therefor (0.80). Apr-04-19 Review of J. Porada unfiled 2015-17 federal and 0.40 130.00 JSW Illinois income tax return matters with T. Banich. Apr-11-19 Preparation of J. Porada 2015 income tax returns. 2.30 747.50 JSW Apr-12-19 Continued preparation of 2015 income tax returns. 1.80 585.00 JSW Apr-13-19 Finalization of J. Porada 2015 income tax returns. 2.10 682.50 JSW Apr-14-19 Preliminary research and review of Bankruptcy estate 1.40 455.00 JSW income complaint rules(1.10, and review with J. Porada (0.30). Jun-04-19 Review of federal and Illinois income tax return 0.40 130.00 JSW matters with T. Banich. Jun-11-19 Response to T. Banich regarding tax exemptions 0.30 97.50 JSW status. Sep-04-19 Further review of unfiled 2015-17 J. Porada Federal 0.40 130.00 JSW and Illinois income tax return matters with T. Banich. Oct-09-19 Preparation of J. Porada 2017 Federal and Illinois 2.40 780.00 JSW Income Tax returns (1.80) and determination of bankruptcy Estate tax liabilities (0.60). Oct-10-19 Revisions and review of J. Porada 2016 Federal and 1.40 455.00 JSW Illinois Income Tax returns (0.90) and determination of Bankruptcy Estate tax liabilities (0.30); transmittal to J. Porada for review (0.20). Revisions and review of J. Porada 2017 Federal and 1.30 422.50 JSW Illinois Income Tax returns (0.80) and determination of Estate tax liabilities (0.30); transmittal to J. Porada for review (0.20). Jan-20-20 Preparation of IRS Power of Attorney for 2015-2018 0.50 162.50 JSW and transmittal to J. Porada. Feb-10-20 Review of 2017 J. Porada tax liabilities with K. 0.40 130.00 JSW Morgan. Mar-29-20 Review and revisions for 2017 J. Porada tax returns 2.30 747.50 JSW final draft to client (2.00) and transmittal (0.30). Mar-31-20 Review and response to taxpayer comments 0.30 97.50 JSW regarding J. Porada 2016 tax return. Apr-05-20 Final review of J. Porada 2016 tax returns open 0.80 260.00 JSW points delivered to JJP for clearance. Apr-06-20 Finalization and delivery to JJP of 2016 personal 1.30 422.50 JSW income tax returns (0.60), and responses to follow up questions with respect thereto (0.70). May-20-20 Calculation of investment valuation estimates for 3.40 1,105.00 JSW 2017 transfers 1.00); revisions to 2017 tax returns for capital transactions (1.00); tax summary preparation and e-delivery to J. Porada (1.40). Jun-02-20 Reviews of Kathleen Heath Living Trust matters 0.50 162.50 JSW with Cary Latimer. Jun-24-20 Tax return collection and transmittal to K. Morgan 0.50 162.50 JSW regarding tax liabilities for IRS, IDOR. Jun-26-20 Preliminary review of Seller claim for reimbursement 0.40 130.00 JSW of 2017-2019 Seller taxes. Totals 27.70 $9,002.50 Total Fee & Disbursements for all charges on this $9002.50 matter TAX ID Number 36-2705396