Marshall Spiegel

Opinion

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Dated: June 3, 2024 ~_S- — ‘Timothy A. Barnes, Judge United States Bankruptcy Court

EXHIBIT A 09/19/23 HLA Email exchange with M. Desmond, counsel to debtor, regarding motion for 0.30 hrs appointment of trustee, chapter 11 case, and upcoming meeting; send papers of (1)Lumping settlement offers send pleadings. 09/19/23 NRD Confer with HLA re his correspondence with M. Desmond on potential 0.40 hrs resolution to case; thereafter locate and forward settlement letters as requested. 09/20/23 HLA Preparation for and participation in conference with M. Desmond, co-counsel 1.40 hrs to debtor, regarding history of case, settlement efforts, motion to convert, motion to appoint trustee, ratification of improprieties, and resolution. 09/20/23 HLA Review, analyze and respond to emails relating to UST's motion to appoint 0.20 hrs trustee, and briefing schedules. 09/20/23 NRD Preparation for and attendance at hearing relating to two motions both (1) 1.60 hrs concerning ReadyCap transaction. 09/20/23 NRD Telephone conference with G. Silver re reactions to hearing, comparison of 0.40 hrs notes, government shutdown risk, and handling of briefing. 09/20/23 NRD Confer with HLA re debrief from hearing and bringing him up to speed. 0.20 hrs 09/20/23 NRD Exchange emails with HLA regarding requests from M. Desmond. 0.10 hrs 09/21/23 NRD Review of emails from UST serving motion for chapter 11 trustee on lender 0.10 hrs and mortgage broker. 09/26/23 NRD Telephone conference with N. Rugg re approach to hearing tomorrow on new 0.40 hrs motion to disband Committee. 09/27/23 HLA Attendance at office conference with NRD regarding outcome of hearing on 0.30 hrs motion to reconstitute the committee, findings of fact and conclusions of law relating to Matthew Spiegel's claim, discovery on motion to convert, and likely revised plan. 09/27/23 NRD Preparation for and appearance at hearing in case, primarily on 1.90 hrs (1) Matthew/Debtor's new motion to disband, which was withdrawn, then including discussion of Debtor's new plan and confirmation process; argue Committee's position where appropriate. 09/27/23 NRD Confer with HLA re debrief from hearing, explaining good result. 0.10 hrs 09/27/23 NRD Draft email to counsel to Insurance company providing summary of hearing. 0.10 hrs 09/28/23 NRD Telephone conference with G. Silver re reaction to hearing yesterday and path 0.40 hrs forward. 10/02/23 NRD Confer with HLA re tasks for week in case, briefing deadlines, and approach 0.20 hrs to discovery. 10/02/23 NRD Review and analysis of Debtor's motion for retroactive 363 relief, flagging 0.50 hrs issues in margins, and generally brainstorming response to same. 10/02/23 NRD Conduct legal research in connection with 363 motion, specifically pulling 0.80 hrs cases cited therein and distinguishing for response. 10/02/23 NRD Commence general outlining of response to Debtor's 363 motion. 0.60 hrs 10/03/23 NRD Commence drafting response to Debtor's motion for retroactive 363 relief. 2.70 hrs 10/04/23 NRD Telephone conference in the morning with N. Rugg regarding approach to 0.10 hrs hearing. 10/04/23 NRD Telephone conference with G. Silver regarding approach to hearing. 0.30 hrs 10/04/23 NRD Appear and participate in hearing in case on numerous issues, including plan 1.80 hrs balloting procedures and initial presentment of fee application. 10/05/23 NRD Continue work on drafting response to Debtor's 363 motion. 2.40 hrs 10/05/23 NRD In connection with response to 363 motion draft, conduct legal research 0.90 hrs relevant to same. 10/09/23 NRD Conduct extensive legal research in connection with drafting of objection to 2.80 hrs EXHIBIT B 10/25/23 NRD Review and analysis of B. Hall email on summary of hearing. 0.20 hrs 10/26/23 NRD Short telephone conference with B. Hall re continuation of trial. 0.10 hrs 10/27/23 NRD Telephone conference with B. Hall re request of Debtor's various attorneys to 0.80 hrs delay trial and response to same. 11/07/23 HLA Review, analyze and respond to more than five emails from creditors 0.20 hrs committee representatives regarding discovery, trial exhibits and privilege issues. 11/07/23 SR Save 2 filed documents (Dkt. 1093 and 1094) to system and upload to sharefile 0.20 hrs folder for docket items, per NRD. 11/09/23 HLA Review, analyze and respond where necessary to numerous emails from 0.20 hrs committee members and emails to committee members regarding trial preparation, exhibits, witnesses, and responses to expert. 11/09/23 NRD Exchange emails with Committee members re attendance at trial logistics. 0.20 hrs 11/10/23 HLA Review, analyze and respond to emails from creditors committee 0.20 hrs representatives regarding trial preparation, trial issues and exhibits. 11/20/23 NRD Exchange emails with Committee members re setting meeting. 0.20 hrs 11/21/23 NRD Draft email to Committee members re update on trial and setting time for 0.30 hrs meeting. 11/27/23 NRD Exchange emails with Committee members re timing of meeting. 0.20 hrs 12/03/23 NRD Draft email to Committee members re scheduling of Committee meeting and 0.20 hrs circulating draft of PFFACL for their review and approval to file. (2) 12/04/23 NRD Draft email to Committee members requesting authority file reply in support 0.10 hrs Defending of fee application. Fee App 12/05/23 HLA Preparation for and participation in lengthy meeting with creditors committee 1.30 hrs regarding agenda of items including Matthew Spiegel claim, confirmation, motion to convert, motion for appointment of trustee, continued discovery, and trial. 12/05/23 NRD Exchange emails with Committee members re meeting logistics and review 0.30 hrs and analysis of minutes and agenda relating to meeting prepared by members. 12/05/23 NRD Draft email to Committee members circulating draft settlement proposal for 0.10 hrs discussion at meeting. 12/05/23 NRD Attend Committee meeting to discuss debrief from part one of trial, strategy 1.40 hrs for part 2 of trial, and approach to settlement proposal. 12/06/23 HLA Review and analysis of emails from committee members regarding settlement; 0.30 hrs review settlement letter. 12/06/23 NRD Exchange numerous emails with Committee members answering questions 0.40 hrs about draft settlement proposal. 12/06/23 NRD Draft email to Committee attaching revised settlement letter and explaining 0.20 hrs same. 12/07/23 HLA Review and analyze email communications from creditors committee members 0.20 hrs regarding settlement. 12/07/23 NRD Telephone conference with B. Hall re thoughts on response to settlement 0.10 hrs proposal and confirmation of authority to send. 12/07/23 NRD Draft comprehensive responsive email to Committee member comments on 0.30 hrs settlement response. 12/09/23 NRD Exchange emails with Committee members re settlement compromise sent to 0.10 hrs Debtor. 01/16/24 NRD Draft responsive email to Committee chair re logistics of his testimony and his 0.20 hrs expenses relating to testimony. EXHIBIT C CHICAGO, ILLINOIS 60604 312-435-1050 FAX 312-435-1059 FEIN 36-3382789 February 28, 2024 James L. Waite Invoice No: 18501 HLA Official Committee of Unsecured Client No: 2592 00004 Creditors for Marshall Spiegel Billing through: 01/31/24 1618 Sheridan Road, Unit 8 Wilmette, IL 60091 RE: :Plan and Disclosure Statement Services Rendered 09/29/23 NRD Exchange emails with S. DeRousse re dates for confirmation procedures and 0.20 hrs fee application. 10/03/23 HLA Commence review and analysis of seventh amended plan and sixth amended 0.80 hrs disclosure statement; identify issues for discussion with committee. 10/03/23 NRD Telephone conference with N. Rugg re thoughts on mechanics of new plan and 0.50 hrs general preparation for hearing in the morning and need to confer with G. Silver. 10/03/23 NRD After call with N. Rugg, continue review of Plan and also balloting procedures 0.40 hrs in connection therewith to understand who votes. 10/03/23 NRD Conduct initial review and analysis of Seventh Amended Plan and Sixth 0.70 hrs Amended Disclosure Statement. 10/03/23 NRD Telephone conference with N. Rugg regarding thoughts on mechanics of new 0.50 hrs (3) plan and general preparation for hearing in the morning and need to confer Duplication of Services with G. Silver. 10/03/23 NRD After call with N. Rugg, continue review of Plan and also balloting procedures 0.40 hrs (3) in connection therewith to understand who votes. 10/04/23 NRD Review and approve proposed order to follow on balloting procedures. 0.10 hrs 10/11/23 NRD Continue review and analysis of Plan and Disclosure Statement and gaming 0.70 hrs out/outlining objection to same. 10/12/23 NRD Confer briefly with HLA re approach to objection to plan. 0.10 hrs 10/13/23 NRD Continue to analyze Plan and Disclosure Statement and identify and 0.90 hrs understand new components. 10/13/23 NRD Review and analysis of prior plan objections to identify stale arguments and 0.70 hrs arguments that remain ripe. 10/13/23 NRD Continue to brainstorm and outline objection to new Plan and Disclosure 1.10 hrs Statement. 10/16/23 NRD Continue outlining of objection to Plan and Disclosure Statement, 1.30 hrs contemporaneously with review of Plan and Disclosure Statement. 10/17/23 NRD Continued review and analysis of Debtor's seventh amended plan and sixth 1.10 hrs amended disclosure statement to understand structure, mechanisms, and prospects of good faith and feasibility. 10/17/23 NRD Review and analysis of Debtor's motion to establish confirmation procedures 1.30 hrs and procedures themselves appended as exhibits as critical component of procedures. 10/17/23 NRD Throughout the day, conduct legal research on myriad issues relating to plan 1.20 hrs (1) and confirmation. 10/17/23 NRD Confer with HLA re review of plan mechanics and strategize approach to 0.70 hrs objection. 10/17/23 NRD Exchange emails with N. Rugg re setting time for zoom on plan objections. 0.10 hrs 10/17/23 NRD Two back to back telephone conferences with N. Rugg re Plan objection. 0.30 hrs 10/18/23 HLA Preparation for and participation in conference call with N. Rugg and A. Berk 0.80 hrs (1) regarding plan objections, witnesses, confirmation process, motion to convert, and motion for appointment of trustee. 10/18/23 NRD Continue drafting objection to Plan, building on prior objections. 2.80 hrs 10/18/23 NRD Continue legal research in connection with objection to Plan. 1.50 hrs 10/18/23 NRD Zoom conference with N. Rugg, A. Berk, and HLA re Plan objections. 0.70 hrs 10/19/23 HLA Continue review and analysis of seventh plan submitted by debtor and 0.60 hrs disclosure materials; consider and formulate objections to plan. 10/19/23 HLA Attendance at office conference with NRD regarding basis for objection to 0.50 hrs plan including feasibility, good faith gerrymandering classes, artificial impairment, and not fair and equitable; discuss approach and factual basis for each objection. 10/19/23 NRD Intermittently throughout the day, confer with HLA re status and his thoughts 0.30 hrs (1) on approach to plan objection. 10/19/23 NRD In support of drafting of objection to plan, conduct legal research on myriad of 0.90 hrs issues. 10/19/23 NRD In connection with drafting of objection to same, review and analyze Plan and 1.20 hrs Disclosure statement. 10/19/23 NRD Telephone conference with N. Rugg re thoughts on balloting and whether it is 0.20 hrs even possible to get enough votes. 10/19/23 NRD Telephone conference with G. Silver re balloting logistics in connection with 0.20 hrs drafting objection to Plan. 10/19/23 NRD Continue throughout the day further drafting of objection to Plan and 4.10 hrs Disclosure Statement. 10/20/23 HLA Review and revise objection to plan for a myriad of reasons including bad faith 0.40 hrs artificial impairment, gerrymandering, lack of finality, and no non-insider class. 10/20/23 HLA Review and analysis of objection filed by UST to plan and objection of 0.30 hrs individual creditors to plan; identify issues for argument and inclusion in committee's brief. 10/20/23 NRD Complete drafting of objection to plan and disclosure statement. 1.50 hrs 10/20/23 NRD Draft changes to objection to disclosure statement to incorporate occupants of 0.40 hrs class 6 and supplement argument on insider status. 10/20/23 NRD Conduct further review, proof, and revisions to objection to plan and 2.70 hrs disclosure statement. 10/20/23 NRD Telephone conference with M. Desmond re pending question on who is in 0.10 hrs class 6. 10/20/23 NRD Confer with HLA re page turn of objection to plan and final preparations for 0.20 hrs filing. 10/20/23 NRD Review and analysis of UST objection to Plan. 0.20 hrs 10/20/23 NRD Review and analysis of Association objection to plan. 0.40 hrs 10/20/23 NRD Coordinate with staff re further revisions to objection to plan and filing 0.30 hrs 10/27/23 HLA Continue review and analysis of 7th plan and related disclosure statement for 0.40 hrs objections and witnesses to contradict good faith of plan; commence outline for deposition of debtor on lack of good faith. 10/30/23 HLA Identify inaccuracies in disclosure statement and plan relating to Greenleaf 0.30 hrs loan and backdating of operating agreement replacing Marshall Spiegel with Matthew Spiegel. 10/31/23 HLA Continue review and analysis of seventh amended plan and applicable 0.50 hrs (1) disclosure statement for objections; review and analysis of objection filed by committee; develop trial strategy relating to good faith and lack of compliance with 1129. 10/31/23 NRD Telephone conference with N. Rugg re feasibility issues. 0.30 hrs 10/31/23 NRD Telephone conference with G. Silver re feasibility. 0.30 hrs 11/01/23 HLA Calculate universe of administrative expenses for confirmation purposes and 0.20 hrs feasibility purposes. 11/01/23 NRD Confer with HLA re findings of review of Greenleaf documents and 0.50 hrs availability of cash to fund plan--resultant feasibility issues. 11/01/23 NRD Telephone conference with N. Rugg re feasibility issues identified in review of 0.40 hrs Greenleaf bank statements. 11/01/23 NRD Telephone conference with G. Silver re numerous trial issues, including 0.30 hrs specifically, feasibility. 11/02/23 HLA Continue review and analysis of seventh amended plan and related disclosure 1.30 hrs statement and continue to identify topics for questioning at hearing relating to good faith, backdating, violation of rules, and misrepresenting assets and liabilities. 11/06/23 HLA Review and analysis of reply in support of Plan filed by debtor; identify points 0.30 hrs for rebuttal and examination of witnesses. 11/06/23 NRD Gather unbilled time for October; circulate estimate of unbilled time to 0.20 hrs Debtor's counsel and request estimate of Debtor's professionals for feasibility question. 11/06/23 NRD Review and analysis of Debtor's replies in support of Plan and Disclosure 0.90 hrs Statement. 11/07/23 HLA Attendance at office conference with NRD regarding administrative expense 0.30 hrs calculation, funds available to Greenleaf, confirmation issues, and trial strategy. 11/07/23 HLA Review and analysis of reply filed by debtor; identify issues to cover in closing 0.30 hrs arguments and during trial. 11/08/23 HLA Continue review and analysis of reply filed by debtor, plan and disclosure 0.30 hrs statement for trial, exhibit preparation and trial preparation. 11/10/23 HLA Review and analyze debtors' motion to estimate administrative claims; identify 0.20 hrs issues to discuss with NRD regarding confirmation hearing. 11/10/23 HLA Continue review and analysis of information regarding administrative claims 0.20 hrs and inability of debtor to have funds to pay claims on confirmation; continue to calculate administrative claims. Adelman, Howard L. 8.20 hrs 525 /hr $4,305.00 Dwayne, Nicholas R 36.10 hrs 315 /hr $11,371.50 ————— Total fees for this matter 44.30 hrs $15,676.50 EXHIBIT D CHICAGO, ILLINOIS 60604 312-435-1050 FAX 312-435-1059 FEIN 36-3382789 February 28, 2024 James L. Waite Invoice No: 18497 HLA Official Committee of Unsecured Client No: 2592 00012 Creditors for Marshall Spiegel Billing through: 01/31/24 1618 Sheridan Road, Unit 8 Wilmette, IL 60091 RE: Claims Adjudication Services Rendered 09/01/23 NRD Commence drafting trial outline for Matthew Claim trial, identifying evidence 2.90 hrs needed, splitting into interrogation Marshall and Matthew. 09/02/23 NRD Continue work on trial outline over the weekend. 0.80 hrs 09/04/23 NRD Continue trial preparation in connection with Matthew Claim trial, reviewing 3.30 hrs exhibits, building outline, drafting questions. 09/05/23 HLA Attendance at office conference with NRD regarding trial preparation 0.80 hrs including review of exhibits, review outline, and discussion of strategy and burden of proof. 09/05/23 NRD Throughout the day continue work on trial preparation and outlining. 2.80 hrs (1) 09/05/23 NRD Telephone and email exchanges with court and opposing counsel re double 0.30 hrs sided exhibit binders. 09/05/23 NRD Throughout the day work to compile exhibit binders for delivery to court, 2.60 hrs (1) pulling all PDF exhibits, working with staff to make binders and zip drive with PDFs. 09/06/23 HLA Review and analysis of joint pretrial statement and trial outline regarding 0.30 hrs objection to claim of Matthew Spiegel. 09/06/23 HLA Attendance at office conference with NRD regarding revisions to trial outline 0.50 hrs and trial strategy. 09/06/23 NRD Exchange morning emails with W. Factor re various issues to be addressed at 0.50 hrs pretrial hearing. 09/06/23 NRD Preparation for pretrial hearing, review of pretrial statement and exhibits in 1.10 hrs connection with same. 09/06/23 NRD Confer with HLA re pre-trial hearing and his attendance at the same (off 0.20 hrs screen). 09/06/23 NRD Attend pre-trial hearing in court, cover objections to exhibits and other 2.70 hrs logistics for trial. 09/06/23 NRD Work throughout the day with staff to complete courtesy binders of exhibits 1.50 hrs (1) and deliver same to court. 09/06/23 NRD Continue general trial preparation and outlining throughout the day, reviewing 2.70 hrs (1) exhibits, gaming out examination. 09/07/23 HLA Attendance at lengthy office conferences with NRD regarding trial preparation 0.80 hrs and formulating questions strategy for Marshall and Matthew; discuss utilization of exhibits and summary. 09/07/23 NRD Continue working on trial outline and general trial preparation throughout the 2.90 hrs (1) day including review and flagging of exhibit binder. 09/07/23 NRD Confer with HLA regarding proposed outline for opening statement as well as 0.60 hrs some of interrogation of Marshall. 09/07/23 NRD Review and analysis of exhibits produced by W. Factor for trial; confirm 0.70 hrs identity of previously unidentified exhibits. 09/07/23 NRD Confer with HLA regarding proposed outline for opening statement as well as 0.60 hrs some of interrogation of Marshall. 09/07/23 NRD Review and analysis of exhibits produced by W. Factor for trial; confirm 0.70 hrs identity of previously unidentified exhibits. 09/08/23 HLA Attendance at three (3) separate office conferences with NRD regarding trial 1.20 hrs (1) preparation, each of which discussed direct testimony and cross-examination of Marshall Spiegel, direct and cross-examination of Matthew Spiegel, dealing with objections, absence of proof, how to prove the absence of documents, and cross-examine the witness on the failure to produce documents supporting the May 2018 bank statements. 09/08/23 HLA Review and analysis of pretrial order and other orders entered by the court for 0.40 hrs upcoming court hearing. 09/08/23 NRD Continue throughout the day (final office day prior to trial) comprehensive 4.90 hrs (1) preparation for trial, finalizing exhibit binder with all necessary highlighting and tabs, complete and review of trial outline, run through questioning, and get comfortable with rules of evidence for trial to proceed. 09/08/23 NRD Exchange emails with W. Factor re lack of receipt of deposition transcripts and 0.20 hrs other exhibit logistics. 09/08/23 NRD Confer multiple times throughout the day with HLA re trial preparation. 0.70 hrs 09/09/23 NRD Continue outline of opening statement. 0.80 hrs 09/09/23 NRD Exchange morning emails and then confer via telephone with B. Factor re 0.30 hrs potential settlement of claim objection in advance of trial. 09/09/23 NRD Confer with APS re brainstorming on settlement and Factor offer. 0.20 hrs 09/09/23 NRD Telephone conference with B. Hall, Committee Chair, re offer from 0.40 hrs Matthew/Factor to settle case, need for email to all members, and meeting re same. 09/09/23 NRD Continue comprehensive trial preparation, outlining, drafting questions, 3.20 hrs studying exhibits. 09/09/23 NRD Complete comprehensive review of deposition of Marshall Spiegel - part 1, 1.60 hrs highlighting all likely opportunities for impeachment at trial. 09/09/23 NRD Complete drafting of opening statement script/outline. 1.20 hrs 09/09/23 NRD Continue trial preparation specifically by reviewing and practicing outline as 2.10 hrs well as opening statement. 09/10/23 NRD Continue to prepare for trial, reviewing outline and exhibits and practicing 2.80 hrs questioning. 09/10/23 NRD Continue to practice opening statement--refining over time. 1.10 hrs 09/11/23 HLA Attendance at office conference with NRD regarding trial preparation and 1.20 hrs review trial outline, depositions, amended pretrial statement; prepare for trial with NRD. 09/11/23 HLA Participation in contested hearing of proof of claim of Matthew Spiegel which 7.00 hrs (1) is scheduled to last all week; assist NRD in examination of Marshall Spiegel and preparation for Matthew Spiegel. 09/11/23 NRD Confer throughout the morning with HLA re final trial preparation, practicing 1.20 hrs (1) one examination of Marshall Spiegel, plus various logistics. 09/11/23 NRD Throughout the evening, review notes from trial, exhibits, outline, and 1.80 hrs generally prepare for day two. 09/11/23 NRD Telephone conference with G. Silver re reaction to trial and various other case 0.40 hrs logistics. 09/12/23 HLA Attend conference with NRD to go over trial testimony, cross-examination and 0.70 hrs trial strategy. 09/12/23 HLA Participate in all day trial session including examination of Marshall Spiegel. 6.00 hrs 09/12/23 HLA Participate in office conference with NRD after trial in preparation for 0.60 hrs examination of Matthew and strategy with recross of Marshall. 09/12/23 NRD Continuing morning real time preparation for trial, specifically reviewing 1.10 hrs outline on continued examination of Marshall Spiegel to begin in day 2. 09/12/23 NRD Participate in all day trial--specifically examination of Marshall Spiegel, 6.00 hrs Matthew Spiegel, and discussion of various logistics in connection with same. 09/12/23 NRD In the evening, review and analysis of trial notes and prepare for cross 2.30 hrs examination of Marshall Spiegel to begin tomorrow. 09/13/23 HLA Preparation for and participation in all day trial of Matthew Spiegel proof of 6.30 hrs claim. 09/13/23 NRD Exchange emails with G. Silver re trial progress. 0.10 hrs 09/13/23 NRD In the morning, continue trial preparation--review of notes, exhibits, outline in 2.30 hrs preparation for examination of Matthew Spiegel. 09/13/23 NRD Participate in afternoon trial in connection with Matthew Claim--primarily 4.10 hrs interrogate Marshall Spiegel. 09/13/23 NRD Evening work on trial preparation--review of notes and exhibits covered, 1.50 hrs brainstorm impeachment and additional evidence needed. 09/13/23 NRD Commence work on closing statement. 0.60 hrs 09/14/23 HLA Attendance at office conference with NRD regarding preparation for 0.90 hrs cross-examination of Matthew and Marshall. 09/14/23 HLA Review documents and assist in preparation of timeline for impeachment 0.20 hrs exhibit of Matthew relating to nondisclosure of claim. 09/14/23 HLA Research in connection with the admissibility of deposition of party under 0.40 hrs (1) rules 32 and 801; prepare for argument; review applicable FRCP and FRE. 09/14/23 HLA Participation in trial for proof of claim relating to Matthew Spiegel. 2.80 hrs 09/14/23 NRD In the early morning from home, continue trial preparation, analysis, and 0.80 hrs (1) brainstorming; draft multiple emails to HLA and staff re impeachment ideas and documents needed printed for trial. 09/14/23 NRD In office in the morning continue comprehensive trial preparation, review of 2.40 hrs notes, outline, exhibits, brainstorm additional interrogation and cross. 09/14/23 NRD Confer with HLA re further trial preparation and cross of Matthew. 0.90 hrs 09/14/23 NRD Attend and participate in afternoon trial in connection with Matthew Claim. 2.70 hrs 09/14/23 NRD In the evening continue contemporaneous trial preparation focusing on further 2.30 hrs cross of Marshall for tomorrow and closing statement/summary. 09/14/23 NRD Draft timeline of events to be potentially used as demonstrative illustrating 0.30 hrs delay in schedule amendment. 09/15/23 HLA Preparation for trial on cross-examination of Marshall, direct testimony of 1.00 hrs Matthew, cross-examination of Matthew, and closing arguments. 09/15/23 HLA Participate in trial on proof of claim of Matthew Spiegel commencing at 9 AM 7.20 hrs and concluding around 4 pm. 09/15/23 NRD Conduct final preparations for trial, including completion of outline/script of 1.30 hrs Marshall, closing, and discussion of various post-trial logistics. 09/15/23 NRD Post-trial telephone conference with B. Hall re debrief from same and next 0.50 hrs steps. 09/18/23 NRD Confer with HLA re approach to dep designations and proposed findings of 0.40 hrs fact and conclusions of law. 09/18/23 NRD Commence organizing trial materials and general preparation for post-trial 0.80 hrs tasks. 09/19/23 NRD Continue efforts to organize trial notes and outline post-trial procedures. 0.50 hrs 09/19/23 NRD Commence review and analysis of deposition transcripts preliminarily 0.60 hrs designating same for distribution to W. Factor. 09/20/23 HLA Attendance at office conference with NRD regarding proposed findings of 0.30 hrs fact, conclusions of law and deposition designations for testimony of Matthew to show inconsistency and lack of credibility. 09/20/23 NRD Work on dep designation of Matthew Spiegel transcript. 1.40 hrs 09/21/23 NRD Work on and substantially complete dep designations for transcript of Matthew 2.70 hrs Spiegel deposition as well as part 1 of Debtor's deposition. 09/22/23 HLA Attendance at office conference with NRD regarding strategy on findings of 0.20 hrs fact and conclusions of law, and relationship with deposition designations under federal rules and use in findings. 09/22/23 HLA Review and analysis of designations of deposition of Matthew. 0.30 hrs 09/22/23 NRD Complete hand designations of deposition transcript of Marshall Spiegel 1.30 hrs volume 2. 09/26/23 HLA Review and analysis of deposition designations for trial and admissions of 0.30 hrs Matthew Spiegel. 09/26/23 HLA Attendance at office conference with NRD regarding details and strategy on 0.20 hrs findings of fact and conclusions of law regarding Matthew Spiegel admissions. 09/26/23 NRD Exchange numerous emails with W. Factor re logistics of post-trial deadlines, 0.20 hrs dep designations, and transcripts. 10/02/23 NRD Exchange emails with W. Factor re delivery of dep designations and extension 0.10 hrs of time for him to remit same. 10/02/23 NRD Exchange emails with W. Factor regarding delivery of dep designations and 0.10 hrs (3) extension of time for him to remit same. 10/03/23 NRD Confer briefly with HLA re initial research findings on joint bank accounts. 0.10 hrs 10/03/23 NRD Commence legal research on joint bank accounts for use in connection with 1.10 hrs proposed findings of fact and conclusions of law for trial. 10/06/23 NRD Review and analysis of Matthew Spiegel counter designations on deposition. 0.50 hrs 10/06/23 NRD Review and analysis of trial notes, exhibits, and other papers in effort to 1.30 hrs organize and outline proposed findings of fact and conclusions of law. 10/16/23 NRD Telephone conference with W. Factor re timing of transcripts and due date for 0.10 hrs findings of fact and conclusions of law; review emails re same. 10/18/23 NRD Receipt and begin preliminary review and analysis of trial transcripts. 1.10 hrs 10/23/23 NRD Continue review and highlighting of trial transcripts in connection with 1.20 hrs drafting proposed findings of fact and conclusions of law. 10/24/23 NRD Telephone conference with new law clerk to explain background of case and 0.70 hrs specifically background relevant to claim objections, and assign research task on joint bank accounts. 10/24/23 NRD Begin drafting proposed findings of fact and conclusions of law with respect to 3.50 hrs Matthew Claim trial. 10/24/23 AK Call with NRD regarding Spiegel and joint account issues. 0.70 hrs 10/25/23 NRD Draft email to B. Freud re two factual questions on liquidation of collateral 0.20 hrs CDs. 10/25/23 NRD Continue to review and analyze trial transcript in connection with drafting 0.80 hrs proposed findings of fact and conclusions of law. 10/25/23 NRD Draft email to B. Factor re deadline for proposed findings of fact and 0.10 hrs conclusions of law and need to address same with judge. 10/25/23 NRD Continue work on proposed findings of fact and conclusions of law with 1.20 hrs respect to Matthew Claim trial. 10/25/23 AK Research and analysis of case law regarding joint account. 1.70 hrs 11/20/23 NRD Review and analysis of complete trial transcript for Matthew Claim trial, 2.40 hrs making highlighting and notations in same in preparation for drafting of proposed findings of fact and conclusions of law. 11/21/23 NRD Additionally, re-review of deposition transcripts with highlighting for use in 1.90 hrs proposed findings of fact and conclusions of law, as well as Matthew 2004 transcript, admitted into evidence as Exhibit 3. 11/21/23 NRD Review of docket and emails to determine what happened with order on 0.40 hrs deadline for proposed findings; exchange emails with W. Factor re getting order entered. 11/21/23 NRD Pick back up and continue work on proposed findings of fact and conclusions 2.80 hrs of law re Matthew claim trial. 11/21/23 NRD Continue targeted review and analysis of trial transcript in support of drafting 1.30 hrs of proposed findings of fact and conclusions of law. 11/22/23 NRD Continue work on proposed findings of fact and conclusions of law. 1.30 hrs 11/23/23 NRD Conduct interim proof of current draft of proposed findings of fact and 0.70 hrs conclusions of law. 11/24/23 NRD Continue drafting proposed findings of fact and conclusions of law. 1.30 hrs 11/25/23 NRD Continue drafting proposed findings of fact and conclusions of law. 1.60 hrs 11/26/23 NRD Exchange emails and telephone conference with A. Klimowicz re further 0.40 hrs research needed on proposed findings of fact and conclusions of law. 11/26/23 NRD Continue drafting proposed findings of fact and conclusions of law. 1.40 hrs 11/26/23 AK Confer with NRD regarding joint bank account issue; research and draft email 1.50 hrs (1) regarding same. 11/27/23 HLA Commence review and analysis of transcripts from hearing relating to claim of 0.40 hrs Matthew Spiegel; identify admissions supporting fraudulent transfers, lack of connections between accounts, and money held by Matthew Spiegel. 11/27/23 NRD Confer with HLA re status on proposed findings of fact and conclusions of law 0.20 hrs and refining of arguments therein. 11/27/23 NRD Telephone conference with T. Ratts, law clerk, re research project in support 0.30 hrs of drafting proposed findings of fact and conclusions of law. 11/27/23 NRD Continue work on proposed findings of fact and conclusions of law. 1.10 hrs 11/27/23 TAR Conducted legal research regarding invalid claims against the bankruptcy 1.20 hrs estate under Illinois contract law, regarding Illinois contract law and joint bank account transfers, regarding bankruptcy procedure for filing of claim. 11/28/23 HLA Continue working with NRD in preparation of proposed findings of fact and 0.60 hrs conclusions of law relating to claim of Matthew Spiegel; assist in drafting findings and conclusions. 11/28/23 NRD In conjunction with work on proposed findings of fact and conclusions of law, 2.80 hrs review and extraction of trial transcript for portions to be included in proposed findings. EXHIBIT E CHICAGO, ILLINOIS 60604 312-435-1050 FAX 312-435-1059 FEIN 36-3382789 February 28, 2024 James L. Waite Invoice No: 18498 HLA Official Committee of Unsecured Client No: 2592 00011 Creditors for Marshall Spiegel Billing through: 01/31/24 1618 Sheridan Road, Unit 8 Wilmette, IL 60091 RE: Conversion Services Rendered 09/01/23 NRD Continue comprehensive review and analysis of M&M deposition transcript, 1.40 hrs highlighting portions for use in conversion trial. 09/07/23 NRD Telephone conference with M. Lango regarding delivery of deposition 0.10 hrs transcript for D. Giannakopolous. 09/07/23 NRD Telephone conference with M. Lango regarding delivery of deposition 0.10 hrs (3) transcript for D. Giannakopolous. 09/08/23 NRD Draft detailed email to M. Lango at ARDC reporting Xydakis and discharging 0.70 hrs Himmel obligation. 10/02/23 NRD Telephone conference and subsequent email exchange with M. Lango, counsel 0.20 hrs at ARDC, re status of pending complaint against Xydakis and intent to amend same. 10/04/23 NRD Receipt of email from M. Desmond requesting full Marcus and Millichap 0.10 hrs production; in response attempt to locate previously circulated sharefile link. 10/05/23 NRD Telephone call and follow up email exchanges with M. Desmond re access to 0.20 hrs Marcus and Millichap discovery. 10/05/23 NRD Draft four (4) document requests, substantially contemporaneously in 2.70 hrs connection with trial on conversion. 10/06/23 HLA Attendance at office conference with NRD regarding discovery to be initiated 0.30 hrs in connection with motion to convert, confirmation, and proposed findings of fact in connection with motion to convert. 10/06/23 NRD In connection with review of trial notes on claim, begin to develop trial outline 1.10 hrs for conversion, identifying facts already in via claim trial. 10/06/23 NRD Draft email to Spiegel counsel re dep dates. 0.10 hrs 10/06/23 NRD Confer with HLA re discovery calendar for October and who should take deps. 0.20 hrs 10/06/23 NRD Review and analysis of Debtor's discovery to UST. 0.10 hrs 10/12/23 NRD Draft email to counsel to various Spiegel parties serving subpoenas; exchange 0.10 hrs follow up emails re logistics. 10/12/23 NRD Draft three subpoenas in connection with conversion. 0.90 hrs 10/12/23 NRD Proof, revise, and finalize document request riders for three subpoenas. 0.60 hrs 10/12/23 NRD Draft two subpoena exhibits re 30(b)(6) topics. 0.70 hrs 10/12/23 NRD Conduct research re Nick Dallas law firm, registered agent, and service 0.20 hrs address in connection with subpoena. completed in connection with attorney-client privilege issues and need for further work on same. 10/30/23 NRD Telephone conference with T. Ratts, other law clerk, on background on 0.50 hrs Spiegel case and need for legal research on conversion/bad faith issues. 10/30/23 NRD Continue work on trial outline, focusing on broad topics and narrowing to 2.30 hrs pointed issues. 10/30/23 NRD Telephone conference with G. Silver re trial logistics and length of her case, 0.50 hrs plus ordering. 10/30/23 NRD Confer with HLA re need to subpoena D. Lloyd. 0.10 hrs 10/30/23 NRD Draft trial subpoena to D. Lloyd, and work to get served. 0.20 hrs 10/30/23 NRD Telephone conference and email exchange with counsel to N. Dallas re 0.30 hrs subpoena. 10/30/23 NRD Confer throughout the day, repeatedly with HLA re trial prep and topics to 0.60 hrs (1) cover. 10/30/23 AK Continued research and analysis of case law regarding privilege issue and draft 5.40 hrs email regarding same. 10/30/23 AK Call with NRD regarding attorney client privilege issue. 0.60 hrs 10/31/23 HLA Attendance at office conference with NRD regarding development of trial 0.40 hrs strategy, deposition of ReadyCap, trial outline, and timing of cross-examination. 10/31/23 NRD Draft email to Committee re need for documents on mediation and valuation of 0.10 hrs Residence. 10/31/23 NRD Receive and commence review and analysis of Greenleaf bank statements. 0.70 hrs 10/31/23 NRD Attendance at meet and confer Zoom conference with Spiegel counsel re 2.50 hrs ordering of trial, logistics, and presentation for court tomorrow. 10/31/23 NRD Draft email to parties re suggestion to get live court reporter for trial. 0.20 hrs 10/31/23 NRD Draft email to counsel to N. Dallas re new trial dates. 0.10 hrs 10/31/23 NRD Exchange emails with G. Silver re exhibits. 0.10 hrs 10/31/23 NRD Exchange emails with all parties re dep dates. 0.10 hrs 10/31/23 NRD Continue general trial prep including outlining. 1.60 hrs 10/31/23 NRD Continue to review documents and mark exhibits for trial. 1.40 hrs 10/31/23 NRD Draft detailed email to all parties re judicial notice of docket and stipulated 0.40 hrs facts. 10/31/23 NRD Confer throughout the day numerous times with HLA re trial preparation. 0.50 hrs (1) 10/31/23 AK Continued research and analysis of case law regarding privilege issue and 1.70 hrs email regarding same. 11/01/23 HLA Review and analysis of production of documents by Greenleaf; identify cash 0.20 hrs components and cash position of Greenleaf for feasibility issues. 11/01/23 HLA Continue review and analysis of transcripts of deposition of M&M 0.40 hrs representative; develop questions for cross-examination of Spiegel and M&M representative regarding backdating. 11/01/23 NRD Exchange emails with G. Silver re various trial logistics. 0.20 hrs 11/01/23 NRD Continue preparation for depositions of Debtor and Greenleaf, refining outline, 1.60 hrs flagging exhibits to use. 11/01/23 NRD Post-hearing conference with HLA re debrief and updating on new trial 0.20 hrs schedule. 11/01/23 NRD Exchange emails with parties re live court reporter logistics. 0.20 hrs 11/01/23 NRD Exchange email with Committee members re valuation of condo issues. 0.20 hrs 11/01/23 NRD Exchange emails with D. Welch re Greenleaf production and deposition. 0.10 hrs 11/01/23 NRD Draft detailed email to Spiegel parties re stipulations of facts including, 0.40 hrs specifically, Greenleaf cash, admin claims, and feasibility. 11/01/23 NRD Preparation for and appearance at hearing in case discussing primarily trial 1.80 hrs logistics, setting new calendar for same. 11/01/23 NRD Draft email to M. Meyer re follow up from hearing and effect on N. Dallas 0.20 hrs subpoena. 11/01/23 NRD Telephone conference with A. Klimowicz, law clerk, re research task needed. 0.30 hrs 11/01/23 NRD Continue work on trial outline in conjunction with deposition outline. 0.90 hrs 11/01/23 AK Telephone call with NRD regarding status. 0.20 hrs 11/01/23 AK Continued research and case law regarding privilege issue and draft email 1.40 hrs regarding same. 11/02/23 HLA Continue review and analysis of article on backdating; research on the 1.20 hrs (1) legitimacy of backdating and comparing memorializing with fabricating and commission of fraud when an agreement is backdated and given to a party to rely on the agreement; review articles and Seventh Circuit cases. 11/02/23 HLA Preparation of email to G.Silver regarding transcript of 341 meeting and 0.20 hrs testimony of debtor he was manager of Greenleaf. 11/02/23 HLA Review and analysis of transcript of 341 meeting; review rules for 0.20 hrs (1) admissibility of a sworn meeting from tape recorder. 11/02/23 NRD Throughout the day, continue trial preparation, including further work on 3.30 hrs (1) outline of same and pulling exhibits to be premarked. 11/02/23 NRD Telephone conference with G. Silver re further thoughts on trial and to answer 0.30 hrs question on possibility of settlement. 11/02/23 NRD Exchange emails with D. Welch re further documents and deposition logistics. 0.20 hrs 11/02/23 NRD Review and analysis of further Greenleaf-produced documents. 0.30 hrs 11/02/23 NRD Contemporaneously with trial preparation, prepare for depositions as well, 3.10 hrs working on both dep outline and binder with exhibits. 11/03/23 HLA Attendance at office conference with NRD regarding trial outline, dealing with 0.40 hrs unorthodox order of hearings, Greenleaf cash position, administrative expenses, and insider issues. 11/03/23 HLA Continue review and analysis of depositions of Matthew Spiegel and Marshall 0.70 hrs Spiegel from claim trial; continue working on deposition outlines, trial testimony, and examination of accountant. 11/03/23 NRD Draft further email follow up to M. Meyer, counsel to N. Dallas re subpoena 0.20 hrs and explaining new trial logistics. 11/03/23 NRD Exchange emails with numerous association-related parties re copy of order to 0.20 hrs be used as trial exhibit. 11/03/23 NRD Draft email follow ups to parties re various trial logistics. 0.20 hrs 11/03/23 NRD Review and analysis of newest Greenleaf documents. 0.20 hrs 11/03/23 NRD Draft email to D. Lloyd re subpoena and trial logistics. 0.20 hrs 11/03/23 NRD Continue work on deposition binder with exhibits, flagging, highlighting and 2.30 hrs margin notes. 11/03/23 NRD On a parallel track with other prep, work on deposition outline for deposition 1.60 hrs of Debtor and Greenleaf. 11/03/23 NRD Continue trial preparation, refining outline and pre-marking exhibits. 1.80 hrs 11/03/23 SR Add new documents and bates stamp same to LLC document production 0.20 hrs batch. 11/04/23 NRD Conduct initial review and analysis of Debtor-produced documents in order to 0.70 hrs understand nature and scope of production. 11/04/23 NRD Continue work on Debtor deposition outline. 0.80 hrs 11/05/23 NRD Continue and substantially complete review of Debtor-produced documents 2.90 hrs and pulling of exhibits to be used in deposition. 11/05/23 NRD Continue and substantially complete deposition outline for deposition of 1.40 hrs Debtor and Greenleaf. 11/05/23 NRD Continue and substantially complete compiling of deposition binder with 0.90 hrs highlighting and flags. 11/05/23 NRD Exchange numerous emails with M. Desmond re privilege log and resultant 0.40 hrs delay in deposition; also email court reporter to cancel dep last minute. 11/05/23 AK Continued research and analysis of case law regarding privilege issue and draft 1.20 hrs email regarding same. 11/06/23 HLA Continue working on trial preparation for questions of Marshall Spiegel 0.60 hrs relating to good faith, purpose for filing case, efforts to rehabilitate, litigation initiated, and plan proposed. 11/06/23 HLA Attendance at office conference with NRD regarding trial strategy, order of 0.50 hrs witnesses, examination of Marshall Spiegel, privilege log issues, and admission of backdating. 11/06/23 HLA Commence review and analysis of voluminous Freddie Mac loan agreement; 0.90 hrs identify breaches by Greenleaf relating to reps and warranties, purpose of loan, covenants, and involvement of Matthew Spiegel. 11/06/23 NRD Exchange further emails with Debtor's counsel re date to exchange exhibits. 0.10 hrs 11/06/23 NRD Throughout the day, continue to pre-mark exhibits for trial and update exhibit 2.20 hrs (1) list document. 11/06/23 NRD Continue to refine deposition outline in light of continuance. 1.10 hrs 11/06/23 NRD Throughout the day, continue to refine and update trial outline. 1.60 hrs (1) 11/06/23 NRD Receipt and review of further documents from Greenleaf, bates stamp, and 0.20 hrs circulate to working group. 11/06/23 NRD Receipt and initial review and analysis of Debtor's privilege log. 0.50 hrs 11/06/23 NRD Draft email to Debtor's counsel re privilege log and new date for deposition. 0.10 hrs 11/06/23 NRD Telephone conference with G. Silver re deposition and trial logistics. 0.70 hrs 11/06/23 SR Add bates stamps to a new batch of documents for LLC production. 0.20 hrs 11/06/23 AK Continued research and case law analysis regarding privilege issue and draft 0.80 hrs email regarding same. 11/07/23 HLA Commence review and analysis of document production by debtor and 1.60 hrs (1) Greenleaf; integrate with document production by Marcus and Millichap; continue painful review and analysis of emails relating to ReadyCap and Freddie Mac; identify emails and documents for trial exhibits and information for trial questions. 11/07/23 HLA Attendance at second office conference of the day with NRD regarding motion 0.40 hrs to compel, deposition questions for Marshall Spiegel and Matthew Spiegel, deposition questions for accountant and J. Xydakis, and trial preparation. 11/07/23 NRD Exchange numerous emails with counsel to Debtor re rescheduling deposition, 0.80 hrs arguing about federal rules and entitlements to time. 11/07/23 NRD Confer with HLA re Debtor's refusal to sit for full dep and what to do about it. 0.20 hrs 11/07/23 NRD Commence and substantially complete motion to compel compliance with 4.20 hrs discovery. 11/07/23 NRD Telephone conference and email exchange with Chambers on how to handle 0.20 hrs emergency motion to compel. 11/07/23 NRD Commence drafting application to have motion to compel heard on emergency 0.60 hrs 11/07/23 NRD Telephone conference with G. Silver re Motion to compel and plan for 0.10 hrs compact depositions tomorrow. 11/07/23 NRD Exchange emails with parties re zoom access to deposition tomorrow. 0.10 hrs 11/07/23 NRD Conduct preparation for deposition tomorrow, which will be short. Preparation 1.30 hrs includes narrowing outline to focus on most important topics given Debtor's refusal to sit for full 7 hours. 11/07/23 NRD Draft email to Debtor parties re further request to stipulate to admin fees. 0.10 hrs 11/07/23 NRD Complete drafting application to have motion to compel heard on emergency 0.60 hrs basis. 11/08/23 HLA Continue review and analysis of trial exhibits and supplement list of trial 0.40 hrs exhibits with NRD. 11/08/23 HLA Review and analysis of court order denying motion but setting briefing 0.30 hrs (1) schedule on motion in ordinary course; consider strategy for trial and impeachment of debtor relating to use of emails and failure to produce emails under 2004 exam. 11/08/23 HLA Continue review and analysis of documents produced by ReadyCap including 0.80 hrs lengthy loan agreements and ancillary documents; identify representations in loan agreement for cross-examination. 11/08/23 HLA Review and revise motion to compel re: emails; determination of common 0.40 hrs defense privilege. 11/08/23 NRD Draft demonstrative chart re admin claims for use at trial. 0.30 hrs 11/08/23 NRD Engage in final proof, edit, and preparation for filing of application to hear 0.70 hrs motion to compel as emergency. 11/08/23 NRD Continue and complete drafting motion to compel compliance with discovery. 0.70 hrs 11/08/23 NRD Confer with HLA re his review of motion to compel and OK to file. 0.10 hrs 11/08/23 NRD Conduct further preparation in advance of deposition, including setting up 0.80 hrs room, ensuring copies of all exhibits are available, and last-minute review and analysis of outline. 11/08/23 NRD Engage in pre-deposition logistics, including greeting court reporter and 0.40 hrs setting up room, starting zoom. 11/08/23 NRD Depose Debtor and Greenleaf over four-hour period, with less than that on the 4.10 hrs record. 11/08/23 NRD Telephone conference with chambers re order to come on emergency 0.10 hrs application. 11/08/23 NRD Review and analysis of entered order on emergency application and exchange 0.20 hrs texts with HLA re reaction to same. 11/09/23 HLA Review and analysis of order entered by court; consider further discovery and 0.20 hrs motions. 11/09/23 HLA Commence review and analysis of expert report regarding ReadyCap loan, and 0.40 hrs process determined weaknesses and areas to contest. 11/09/23 HLA Research in connection with latest cases applying Daubert standard; consider 0.50 hrs Daubert motion; review applicable rules. 11/09/23 HLA Attendance at office conference with NRD regarding response to motion to 0.30 hrs compel, expert report, and trial preparation. 11/09/23 HLA Continue review and analysis of trial outline, exhibits and pleadings for trial 0.70 hrs preparation. 11/09/23 NRD Throughout the day, confer with HLA re various trial topics and how to 0.70 hrs (1) approach in questioning. 11/09/23 NRD Telephone conference with G. Silver re Xydakis ARDC complaint and other 0.40 hrs Matthew Spiegel. 11/11/23 HLA Continue review and analysis of exhibits of Debtor and UST. 1.40 hrs 11/11/23 NRD Continue to review and analyze deposition transcript of Matthew Spiegel and 1.70 hrs Debtor for impeachment opportunities at trial. 11/11/23 NRD Continue to review and refine trial outline. 0.90 hrs 11/12/23 HLA Preparation for and attendance at lengthy afternoon conference with NRD 2.40 hrs regarding trial preparation, cross-examination of Marshall Spiegel, motion to bar testimony, introduction of deposition exhibits, and trial strategy. 11/12/23 HLA Continue to review and analyze evidentiary basis for admission of numerous 1.30 hrs exhibits of the debtor and plan appropriate objections through NRD on certain topics where personal knowledge is lacking, and contradictions abound. 11/12/23 NRD Continue review of deposition transcripts, highlighting and noting 1.10 hrs impeachment topics. 11/12/23 NRD Complete final revisions to trial outline and study same in anticipation of start 1.80 hrs tomorrow. 11/12/23 NRD Draft outline of opening statement for trial tomorrow. 1.10 hrs 11/13/23 HLA Morning trial preparation, including conferences with NRD re final thoughts 1.10 hrs (1) on approach and ordering; compile trial binders and boxes; travel to court. ; 11/13/23 HLA After trial day 1, confer with NRD re debrief from day 1 and plan for day 2. 0.90 hrs 11/13/23 HLA Participation in trial, including openings, working lunch, and conferences with 4.70 hrs co and opposing counsel. 11/13/23 NRD Conduct further trial preparation in the morning, review of outline, exhibits, 1.10 hrs and opening notes, additionally confer with HLA re approach.. 11/13/23 NRD In the evening, study trial notes and refine outline based on openings. 0.60 hrs 11/13/23 NRD Continue reviewing trial outline in preparation for start of evidence. 1.30 hrs 11/13/23 NRD After trial day, confer with HLA re debrief and preparation for continuation 0.90 hrs tomorrow. 11/13/23 NRD Participate in trial including numerous discussions with court and parties on 4.70 hrs logistical issues, observe and take notes on opening statements and give Committee opening-including lunch break wherein trial strategy was discussed. 11/13/23 NRD Telephone conference with N. Rugg re debrief from trial so far. 0.20 hrs 11/13/23 NRD In the morning, continue revising outline for opening and practice same. 0.80 hrs 11/14/23 HLA Conduct further trial prep in the morning via conferences with NRD and 1.20 hrs compiling of further impeachment documents to be used if necessary; continue to study and refine outline. 11/14/23 HLA Participation in trial day 2 including observing direct examination of debtor by 4.80 hrs counsel, taking notes, and formulating cross examination in real time. 11/14/23 HLA Confer with NRD in afternoon re postmortem on day 2 and preparation for day 1.50 hrs 3. 11/14/23 NRD Continue morning trial preparation, review of outline, notes on opening, and 1.20 hrs exhibits; confer periodically with HLA in office. 11/14/23 NRD In the evening, continue review of trial outline and trial notes in preparation 1.40 hrs for next day. 11/14/23 NRD Participate in trial day 2 including primarily direct examination of Debtor; 4.80 hrs contemplate cross examination in real time. 11/14/23 NRD Post-trial debrief with HLA re thoughts on direct and topics to cover on cross; 1.50 hrs go over each of our respective notes and develop outline for cross. 11/15/23 HLA Confer with NRD in the morning re further thoughts on topics to cover in cross 1.00 hrs testimony. 01/15/24 NRD Draft update email to counsel on N. Dallas availability. 0.10 hrs 01/15/24 NRD Draft email update to members of Committee re developments relating to trial 0.20 hrs concerning covid and impromptu hearing re same. 01/15/24 NRD Attend zoom chambers conference with judge and staff re discussion of 0.80 hrs re-ordering of trial in light of covid diagnosis. 01/15/24 NRD Exchange further emails with counsel to N. Dallas re timing of testimony. 0.10 hrs 01/15/24 NRD Exchange further emails with Debtor's counsel re Debtor's negative covid test 0.10 hrs and proceeding with trial. 01/15/24 NRD Continue review and analysis of week 1 trial notes and transcript to identify 1.60 hrs testimony that is in and/or impeachment opportunities. 01/15/24 NRD Continue to review and analyze N. Dallas deposition transcript to aid in tax 1.10 hrs issues for trial prep. 01/15/24 NRD Continue to review, highlight, and flag exhibits for use in examination to now 0.80 hrs commence sooner than thought. 01/16/24 HLA Attendance at office conference with NRD regarding preparation for trial and 0.50 hrs questioning of Marshall Spiegel and Matthew Spiegel. 01/16/24 HLA Attendance at trial in Marshall Spiegel chapter 11 case regarding conversion, 6.00 hrs motion for appointment of trustee, and confirmation. 01/16/24 HLA Attendance at office conference with NRD after trial regarding further 0.50 hrs testimony of Marshall Spiegel and Matthew Spiegel, and strategy for N. Dallas. 01/16/24 NRD In the evening, continue to review and analyze trial outline and prepare for 0.70 hrs ongoing trial. 01/16/24 NRD Conduct further morning preparation for trial including review of exhibits and 0.80 hrs outline, as well as conferring from time to time with HLA. 01/16/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 5.90 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/16/24 NRD Afternoon telephone conference with G. Silver re debrief from trial day. 0.30 hrs 01/16/24 NRD Confer with HLA re debrief from day one and thoughts, plus strategy for 0.50 hrs tomorrow. 01/16/24 NRD Exchange emails with S. DeRousse re transcript of deposition of B. Hall. 0.10 hrs 01/17/24 HLA Attendance at office conference with NRD regarding preparation for trial and 0.50 hrs questioning of Marshall Spiegel and Matthew Spiegel. 01/17/24 HLA Attendance at trial in Marshall Spiegel chapter 11 case regarding conversion, 6.00 hrs motion for appointment of trustee, and confirmation. 01/17/24 HLA Attendance at office conference with NRD after trial regarding further 0.50 hrs testimony of Marshall Spiegel and Matthew Spiegel, and strategy for N. Dallas. 01/17/24 NRD Prior to hearing continue trial preparation including review of notes, outline, 0.70 hrs and exhibits, and intermittent conferences with HLA re same. 01/17/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 6.20 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/17/24 NRD In the evening, continue review of outline and trial notes to stay current for 1.10 hrs continued day 3 tomorrow. 01/17/24 NRD Confer with HLA after day 2 of trial on debrief and plan for tomorrow. 0.50 hrs 01/18/24 HLA Attend conference with NRD regarding examination and cross-examination of 0.50 hrs 01/18/24 HLA Attendance at conference with NRD after trial on Thursday to discuss outcome 0.50 hrs of Matthew Spiegel testimony, need to supplement, and examination in connection with appointment of trustee in conversion. 01/18/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 8.80 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/18/24 NRD Conduct evening review of trial notes and outline in preparation for continued 0.70 hrs trial tomorrow. 01/18/24 NRD Continue to prepare for trial in the morning via review of outline, notes, and 0.90 hrs exhibits and intermittent conferences with HLA. 01/18/24 NRD Two evening telephone conferences with G. Silver (back to back) re debrief 0.50 hrs from day of trial. 01/19/24 HLA Continue preparation for examination of N. Dallas, accountant for debtor, 0.60 hrs regarding preparation of backdated operating agreement, tax returns, and particular attention to claiming Matthew Spiegel as dependant. 01/19/24 HLA Participate in Spiegel conversion, appointment of trustee, and confirmation 8.50 hrs trial. 01/19/24 HLA Attendance at post trial conference with NRD regarding preparation for next 0.50 hrs stage of trial and examination of Matthew Spiegel, D. Giannakopoulos and Novy. 01/19/24 NRD In the morning, review and analyze N. Dallas deposition transcript and outline 0.90 hrs with respect to his trial testimony in preparation for another full day of trial; additionally in connection with same confer intermittently with HLA re same. 01/19/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 8.60 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/19/24 NRD Telephone conference with G. Silver re thoughts on trial day. 0.50 hrs 01/20/24 NRD Brief review and analysis of trial notes from week one and outline in 0.30 hrs preparation for week 2. 01/21/24 NRD Review and analysis of supplemental production from Debtor during ongoing 0.40 hrs trial, including primarily a loan commitment letter. 01/21/24 NRD Begin to outline new questions and topics for Debtor/Greenleaf relating to new 0.80 hrs loan commitment just produced. 01/21/24 NRD Review and analysis of C. Novy expert report; identify areas of interrogation 1.30 hrs and impeachment. 01/21/24 NRD Outline topics of inquiry/impeachment for Debtor's purported expert, C. Novy. 0.50 hrs 01/22/24 HLA Preparation for and participation in all day trial regarding three contested 8.50 hrs matters. 01/22/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 8.60 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/22/24 NRD Conduct morning trial prep, including conferring with HLA re strategies, 0.70 hrs pulling additionally flagged impeachment exhibits, and reviewing trial notes and outline. 01/22/24 NRD Continue review and analysis of expert report and continue outline cross of 0.60 hrs expert. 01/22/24 NRD Telephone conference with G. Silver re trial strategy. 0.30 hrs 01/22/24 NRD Confer with HLA post-trial day re debrief and strategy for next day. 0.50 hrs 01/22/24 NRD In the evening, conduct legal research re motion in limine under Daubert for 0.70 hrs 01/23/24 HLA Preparation for and participation in all day trial regarding three contested 8.50 hrs matters. 01/23/24 HLA Research in connection with scope of cross-examination when interrogating 0.40 hrs party is cross-examining its own witness as a result of the witness being called on direct examination by an opponent. 01/23/24 NRD In the morning, continue preparation for trial day including conferences with 0.80 hrs HLA. 01/23/24 NRD Participation in continued trial on conversion/confirmation/trustee, including 8.70 hrs (1) all on the record time, breaks, working lunch, discussions with opposing and co counsel during same, and travel to and from court house. 01/23/24 NRD Telephone conference with B. Hall re debrief from his view of trial testimony. 0.30 hrs 01/23/24 NRD Draft email to S. DeRousse re delivery of B. Hall deposition transcript. 0.10 hrs 01/23/24 AK Research and analyze adverse witness case law and draft email to NRD 1.20 hrs regarding same. 01/24/24 HLA Preparation for and participation in trial of three contested matters. 3.00 hrs (1) 01/24/24 HLA Attendance at office conference with NRD regarding cross-examination of 0.40 hrs Marshall Spiegel and Matthew Spiegel, results of expert testimony, and results of D. Giannakopoulos of Marcus and Millichap. 01/24/24 NRD Review and analysis of B. Hall deposition transcript in preparation for his 1.30 hrs anticipated testimony this afternoon. 01/24/24 NRD Confer in the morning with HLA re debrief from previous day of trial and 0.30 hrs preview of Hall testimony and motion in limine. 01/24/24 NRD Attend continued trial, including examination of W. Hall as Committee 3.90 hrs (1) designee, as well as various discussions on and off the record, and travel to and from court. 01/24/24 NRD In the evening, continue review and analysis of trial outline and notes in 1.40 hrs preparation for second to last day tomorrow, which will include Matthew testimony. 01/24/24 AK Confer with NRD regarding conforming pleadings and analyze case law re 3.30 hrs Rule 15. 01/25/24 HLA Attendance at office conference with NRD regarding trial preparation for 0.50 hrs examination of Marshall Spiegel and Matthew Spiegel. 01/25/24 HLA Participation in trial of three contested matters. 4.50 hrs 01/25/24 HLA Attendance at office conference with NRD after court; develop testimony for 0.40 hrs Friday and upcoming testimony of Matthew Spiegel and Marshall Spiegel. 01/25/24 NRD Review and analysis of Debtor-produced documents (including recent 1.20 hrs productions as well as land trust file) in order to identify impeachment documents for Matthew testimony that day. 01/25/24 NRD Continue review and analysis of trial outline in preparation for Matthew 1.10 hrs testimony. 01/25/24 NRD Attendance and participation in continued trial day, including on the record 5.30 hrs (1) time, breaks, conferences, and travel to and from court house. 01/25/24 AK Research qualifying dependent case law and statutory provision. 1.20 hrs 01/25/24 AK Research conforming pleadings case law and draft memo regarding same. 1.10 hrs 01/26/24 HLA Preparation for and participation in trial on three contested matters 6.50 hrs (1) commencing at 9am and concluding at 2:30pm. 01/26/24 HLA Morning preparation for court hearing and cross-examination of Matthew 0.70 hrs Spiegel and Marshall Spiegel. 01/26/24 HLA Attendance at office conference with NRD regarding organization of files for 0.30 hrs Debtor as well as Greenleaf, and various discussions on and off the record with counsel and court, and working lunch--travel to and from court house as well. 01/26/24 NRD Continue drafting closing statement/summation in morning at home/on train/in 0.90 hrs office early prior to trial. 01/26/24 NRD Confer with HLA after trial upon return to office about tasks for 1.5 months 0.20 hrs until continuation of trial. 01/26/24 AK Research and analyze case law re conforming pleadings. 0.70 hrs 01/27/24 NRD Telephone conference with N. Rugg re debrief from conversion trial, 0.30 hrs assessment of claim trial opinion as it relates to likely judgment on conversion. 01/29/24 NRD Commence efforts to review transcript to identify exhibits admitted into 0.30 hrs evidence, largely assisted by staff, but providing overview and guidance. 01/29/24 NRD Review and analysis of trial notes and other documents; organize same in 1.60 hrs preparation for final days of trial to come. 01/29/24 AK Research and draft memo regarding conforming pleadings. 1.70 hrs 01/30/24 HLA Attendance at office conference with NRD regarding strategy on additional 0.40 hrs trial dates, lending transaction from Greenleaf, and structure of any kind of settlement. 01/30/24 NRD Review and analysis of trial notes and begin to refine outline for any further 0.70 hrs testimony needed for March dates. 01/30/24 NRD Continue work on summation. 0.50 hrs Adelman, Howard L. 137.20 hrs 525 /hr $72,030.00 Dwayne, Nicholas R 339.60 hrs 315 /hr $106,974.00 Klimowicz, Alec 27.90 hrs 125 /hr $3,487.50 Rodela, Sandra 1.10 hrs 125 /hr $137.50 ————— Total fees for this matter 505.80 hrs $182,629.00 Billing Summary Total Fees 505.80 hrs $182,629.00 ————— TOTAL CHARGES FOR THIS BILL $182,629.00 ACH/WIRE TRANSFER INSTRUCTIONS Wintrust Bank Adelman & Gettleman, Ltd. - General Account 231 S. LaSalle St., 2nd Floor Account Number: 3805304288 Chicago, IL 60604 ABA Routing Number: 071925444 Reference: 18498 We encourage ACH or Wire Transfer Payments