Rosebud Farm, Inc.

Opinion

ONITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: ) ) Case No. 18bk24763 ROSEBUD FARM, INC. ) ) Chapter 7 Debtor. ) ). Honorable Timothy A. Barnes FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO MOGLIA ADVISORS, FINANCIAL ADVISORS FOR CHAPTER 7 TRUSTEE, FOR ALLOWANCE AND PAYMENT OF FIRST INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES TOTAL FEES REQUESTED: $32,190.00 TOTAL COSTS REQUESTED: $188.22 TOTAL FEES REDUCED: $ 6,370.00 TOTAL COSTS REDUCED: $ 188.22 TOTAL FEES ALLOWED: $ 25,820.00 TOTAL COSTS ALLOWED: $ 0.00 TOTAL FEES AND COSTS ALLOWED: $ 25,820.00 The attached time and expense entries have been highlighted 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 highlighted entry. The numerical notations correspond to the enumerated paragraphs below. (1) Unauthorized Work —- TOTAL of disallowed amounts $ 500.00 The Court denies the allowance of compensation for work done prior to the authorization of retention. In re Spanjer Bros., Inc, 203 B.R. 85, 94 (Bankr. N.D. Til. 1996) (Squires, J.) (“The Court will not retrospectively allow any of the time expended prior to the time of the authorized retention because to do so would be to reward any delay ot tardiness in promptly seeking retention. To allow bootstrapping of objected to fees paid at the expense of unsecured creditors undermines the policy in favor of prompt application for retention by professionals who will be seeking compensation from the bankruptcy estate. See generally 11 U.S.C. § 327 (prerequisite to the allowance of any fees or expenses that professional be employed); In re Peoples Sav. Corp., 114 B.R. 151, 154 (Bankr. N.D. IIL 1990) (‘In the absence of a court order approving the Applicant’s employment, there is no statutory basis upon which the Court can make a fee award.’)”). In this case, the Applicant sought retention only retroactive to November 1, 2018 and the disallowed amounts represent charges prior to the approved effective retention. ‘This reduction is final and will not be available for challenge on a final application. (2) Lumping — TOTAL of disallowed amounts (10% of affected entries): $ 120.00 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. Hl. 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.”). (3) Trustee Work Can Not Be Compensated As Professional Services — TOTAL of disallowed amounts: $ 2,750.00 “The Trustee cannot effectively expand the maximum limits of Section 326(a) by hiring other people to perform his duties for him, whether they are paralegals, attorneys, accountants or other professional persons, and utilize the potentially unlimited scope of Section 330 as a basis for award of reasonable compensation.” Boldt v. United States Trustee (In re Jenkins), 130 F.3d 1335, 1341 (9th Cir. 1997) (quoting In re Prame Cent. Ry. Co., 87 B.R. 952, 959 (Bankr. N.D. IIL. 1988) (Squires, J.}). As noted by the court, the Trustee cannot employ himself in any other capacity other than attorney or accountant according to 11 U.S.C. § 327(d). Additionally, where the Trustee is working with another professional and both are charging for the time, the Trustee is deemed to have done so in his capacity as a Trustee working with a client. (4) Unreasonable Travel Rate —'TOTAL of disalowed amounts (50% of affected entries): $ 3,000.00 The Court dentes the allowance in part of compensation for travel time or entries that are lumped with travel time, where compensation at the normal hourly rate (not the customary one-half discounted rate) is sought without explanation. In re Planter, Case No. 08 B 16883, 2009 WL 1393691 (Bankr. N.D. Ill. May 18, 2009) (Barbosa, J.) (“this Court has routinely held that time spent traveling to and from a location typically shall be compensated at one-half of the attorneys’ or other professionals’ hourly rate.”); In re McKeeman, 236 B.R. 667 (B.A.P. 8th Cit.1999); In re Spanjer Bros., 191 BR. 738, 755 (Bankr. N.D. ILL. 1996) (Squires, J.). (5) Reimbursement Limited to Actual, Necessary Expenses ~ TOTAL of disallowed amounts: $ 188.22 The Court denies the allowance of reimbursement for expenses that were not actually and necessarily incurred by the applicant. See 11 U.S.C. §§ 330(a)(1)(B) & 331. The fee application fails to demonstrate that the requested expenses for in-town travel were beyond the scope of the daily, ordinary expenses incurred in going to work or overhead of a firm. Absent explanation, such expenses ate not reimbursed in this court. fs,

Dated: August 21, 2019 a NES hu Timed ny Baimes > United States Bankruptcy Judge

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Invoice submitted to: Rosebud M.A.

August 6, 2019 PRIVILEGED AND CONFIDENTIAL

Invoice #12467 Terms: Due on receipt Professional Services Urs/Rate Amount REVI 0.10. 50.00 ADM tract search that may affect saleability and price as part of our duties as financial §00.00/hr. 4¢visors and consultants, and specifically, to pursue sale of the real estate □□ 0.90 450.00 ADM —_Lauren Newman and Ryan Nelson re building information needed; market rate for 600.00/hr. monthly rate (.4); send lease to Ryan and Lauren; keys for bullding; have codes; appraisal, market value vs. agreeable price? (.4) Ryan needs tour of property; Survey? co Ryan and Lauren; Friday visit and follow up notes (.1); all above affect price and saleability of the. real estate and other assets: per our duties to pursue the sale of assets 11/6/2018 Review 1.00 400.00 JG Rosebud BK Filing for background and requirements for work of Moglia Advisors 400.00/hr ("Mogtia") which includes, but not limited to, preference and fraudulent transfer analyses, sell the real estate, trace cash, analyze real estate lease, sale of equipment and pursue causes of action, as stated and defined in retention motion and order 11/7/2018 Review 1.45 580.00 JG lease and lease amendment; understand funds flow and possible rationale for 400.00/hr adjusting rent charges as part of Moglia's duties to analyzeleases

1325 Remington Road, Suite H, Schaumburg, IL 60173 (847) 884-8282 Fax: (847) 884-1188

Rosebud VA. Page 2

Hrs/Rate Amoun' 11/7/2018. teow 1.00 400.0! JG Lauren Newman Re: status of case, assets to be sold, lease terms and 400.00/nr adjustments to perform Moglia's duties as stated and defined in the previous time entry above tic wi 0.75 300.06 JG Norm Brucer, re: receipt of mail, trustee bank account information; otherassets 400.00/hr that are part of estate, and all previous tasks per Moglia's duties as stated above 11/8/2018 Research 0.50 □□□□□ JG realestate taxes for coston lease amendment to determine financial reasonability 400.00/nr of rent charges as part of Moglia's duties to analyze leases t/c's w/ 1.40 560.00 JG (3) Norm Brucer re: Billofsale on assets to Kingdom, trailer sales, request for 400.00/hr fixed asset register; condition of remaining trailers, location and contents of US mail, ieaseamendmentnegotiations, allperour duties □□□□□□□□□□□□□□□□□□□□□□ consultants Prepare 2,50 □□□□□□□□ JG action item memo and status of various issues re sale and assets tobe 400.00/nr addressed by Moglia Advisors for real estate management and decisions, real estate sale, asset recoveries, etc; all as part of Moglia's duties per order of court tic w/ 0.50 200.00 JG Steve Stabiner, Heath Industrial re: value oftrailers, potential methods of asset 400.00/hr sale; descriptions ofassets; maximize net recovery for creditors, all per our duties as financial advisors and consultants 11/9/2018 Conference w/ 1.25 500.00 JG trustee and counsel re: status on asset valuation; visit with appraiser, pre-petition 400.00/hr sales of assets; search for possible fraudulent transfers as part of Moglia's duties to pursue real estate, equipment and other asset sales Review 1.50 600.00 JG bank statements and selected items fordocument request from bank for 400.00/hr preference and fraudulent transfer analyses as part of Moglia's duties tic wi 0.25 100.00 JG Trustee re: lease amendment, conversation with Brucer re: same todetermine if 400,00/hr the lease terms were reasonable and not detrimental to the creditors as part of Moglia’s duties to analyze the leases and pursue any causes of action debtortaxretum; trustee fo eventually file tax returns; sentemailtotrustee and 400.00/hr counsel re: AIR and inventory as part of Moglia's financial and consulting duties

Rosebud M.A. Page □

Hrs/Rate Amour OWE 1:00. 00.01 Lauren Newman and Jim Gallo re asset recovery (such 48 possible voldable 500.00/hr transfers) and disposition of assets as part of Moglia's duties to purse Duties preferences and fraudulent transfers, trace funds and pursue causes of Action 11/12/2018 Report Prep 4.70 680.06 JG updated action Item list having to do with protection and sale of assets, recovery 400.00/hr of any voidable transfers, preparations of information for prospective buyers, etc and distributed to trustee and counsel all as part of Moglia's duties per order of court ive wi 0.30 □□□□□□ JG Kieran Moran (current tenant) re: Wednesday visit, bills of sale on assets 400.00/hr purchased by Moran from Rosebud as part of Moglia's duties on analyzing possible fraudulent transfers te wi 0.20 80.00 JG Kieran Moran re: second request for insurance coverage and additional 400.00/hr certifications as the trustee is still renting the facility and we need to insure that prospective buyers are covered by insurance, as part of Moglia’s duties in helping the trustee to seil theassets Review 0.70 280.00 JG correspondence from Lauren Newman, counsel, re: time frame to accept/reject 400.00/hr tenant lease, responded to same, to enhance cash flow and address with prospective buyers; validity of purchases of assets, as part of Moglia’s duties to analyze real estate lease and provide financial advice to trustee re asset sales Review 0.10 40.00 JG correspondence from counsel re: insurance, trustee named as loss payee, 400.00/hr additional insurance certificates for safety reasons and to protect buyers who visit site, as part of Moglia's duties as financial advisors and consultants

JG Rosebud facility. Met appraiser there and walked through all buildings, took . 400.00/hr pictures of various assets; met with tenant; met with debtor principal; retrieved Rate traller titles as part of Mogiia's duties to help sell the assets. 11/15/2018 te wi 0.50 200.00 JG Lauren Newman re: 2004 request, visit to facilities, conversations with tenant: lack 400.00/hr of insurance certificates as part of Moglia's duties to assist in the sale of assets Yo wi 0.20 80.00 JG Kiernan Moran, lessee, re: insurance certificates for asset preservation and 400.00/hr protection, and safety reasons as part of assisting the trustee to sell the assets

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Hrs/Rate Amoun 11/15/2018 Review 0.20 80.01 correspondence from appraiser re: value ofassets on premises trailers as 400.00/hr part of Moglia's duties to sell the assets 11/16/2018 vow! 0.30 120.06 JG insurance agent policy in place, deadline forlessor, Sq footage of various parts 400.00/hr of building as part of due diligence by Moglia to pursue sales of assets JG porrespondence with insurance agenton Rosebud real estate, sq footage, % 400-00/nr being leased, replacement costto rebuild. Researched building sizesand tesponded to questions as part of our duties to pursue the sale of the assets:

ping Review 0.20 80.00 JG lease, researched square feetof Rosebud building as part of our duties help 400.00/hr sell the realestate Sent 0.20 80.00 JG electronic correspondence to insurance agentre: need for coverage ofbuildings 400.00/hnr liability insurance and for workers comp of tenant as Trustee does not want possible liability as Moglia assists the trustee as consultant and inthe sale ofthe assets Review 0.20 80.00 JG coverages supplied by tenant's insurance agent. Sentcorrespondence to agent 400.00/hr requesting revisions to "additional insured section" to ensure that the Trustee and others are covered to protect the interests of trustee and of prospective buyers visiting the site as part of Moglia's duty to sell the assets 11/19/2018 Review 0.20 80.00 JG correspondence from agentre: additionalinsured section contractors. Replied 400.00/hr to same as part of providing consulting services to trustee and selling assets for the trustee Review 0.10 40.00 JG Motion employ Moglia Advisors for, among otherservices, preference and 400.00/nr fraudulent conveyance fieldwork, assist on financial, operational and asset sales considerations of Trustee to ensure that Moglia fulfills its duties to the trustee per previous order of court 11/20/2018 Review 0.10 40.00 JG correspondence todebtor counsel re: bills of sales and other evidence ofasset 400.00/hr sales for purposes of researching proceeds as part of Moglia's investigation of possible fraudulent transfers

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Hrs/Rate Amount 11/21/2018 Review 0.10 40.00 JG correspondence with counsel re: investigating preferences and potential 400.00/hr fraudulent conveyances to seek fo recover funds forcreditors as partof Moglia's utles te wil 0.30 □□□□□□ JG Ryan Nelson re: strategies on move forward with tenant-rejectiease, amend 400.00/hr lease, etc.; value of the building; availability of refrigerated buildings; and other considerations tomaximize the recovery by selling to users orinvestors as partof Moglia's duties to analyze and amend the real estate lease and sell assets Meet 0.80 320.00 JG with Trustee re: status of action items list, insurance, real estate appraisal; lease 400.00/hr accept / reject, asset sale discovery methods to maximize net recovery as part of Moglia's duties to provide consulting to trustee; analyze leases and sell assets Review 0.50 200,00 JG Broker's appraisal of value of Rosebud property, methods, of appraising, etc to 400.00/hr maximize net recovery as part of Moglia's duties to pursue sales of the real estate and equipment 11/26/2018 Review 0.20 80.00 JG lawsuit judgment by Mr Smith. Exchanged correspondence with trustee counsel 400.00/nr re; same and of priority claim and analyzing its financial impact on other creditors per our duties as financial advisors and consultants 11/28/2018 Review 0.40 160.00 JG correspondence from trustee counsel on 2004 exam, requests to bank for 400.00/hr documents for fraudulent and preference transfer analyses as part of Mogiia's duties as stated above 11/29/2018 Review 0.10 40.00 JG correspondence from counsel re: not/ce of lawsuit filed pre-petition for event that 400.00/hr occurred pre-petition re analyzing and consulting services to be provided by Moglia per order of court Review 0.10 40.00 JG correspondence from real estate broker re: meeting with tenant and listing the 400.00/hr property for sale as part of Moglia's duties as stated above Review 0.10 40.00 iG correspondence from insurance agent confirming coverage, policy dates, and 400.00/hr confirmation premiums have been paid for financial and safety considerations as part of Moglia's financial and consulting duties as stated above te wl 0.70 280.00 JG trustee counsel re: status on 2004 exam, real estate marketing, and auctioneer to 400.00/hr be hired to sell personal property as part of Moglia's duties as stated above

Rosebud M.A. Page 6 trs/Rate Amoun 11/29/2018 Review 0.10 40.06 JG correspondence from counsel re: time line of judgments, appeals, and filings of 400.00/hr bankruptcy for expediting administration of case and minimizing financial impact and as part of Moglia's duties as stated above ADM Jim Gallo and Lauren Newman re real estate sale; lease: prefiling asset sales; §00.00/hr ies _ T00Ms as part of Moglia's duties as stated above Duties 12/2/2018 Prepare 0.20 80.00 JG request for proposal for Heath Industrial to auction the assets of Rosebud. Sent 400.00/hr request to Steve Stabiner, of Heath industrial, as part of Moglia’s duties to pursue sales of assets 12/3/2018 te wi 0.10 40.00 JG Steve Stabiner, auctioneer re: limiting clean up costs and scheduling auction as 400.00/hr part of Moglia's duties to pursue asset sales Review 0,10 40.00 JG correspondence from attorney re: tenant's offer to buy the real estate as part of 400,00/hr Moglia’s duties to pursue asset sales Review 0.20 80.00 dG revision to proposal to auction off assets and send confirmation of acceptance as 400.00/hr part of Moglia's duty fo pursue asset sales Review 0.20 80.00 JG auctioneer proposal as part of Moglia's duties to pursue asset sales 400.00/hr 12/5/2018 Review 0.50 200.00 JG correspondence re: revised offer and counter offer to purchase building by current 400.00/nr tenant as part of Mogjia’s duties to pursue asset sales ve wi 0.30 7420.00 JG Moglia re: auction proposal and possible abandonment of unsold assets options: 400.00/hr keys for auctioneer, access to store as part of Moglia's duties to pursue asset sales 12/12/2018 Meet 1.00 400.00 JG at Moglia's office. Conference cail with counsel and broker re strategy on counter 400.00/hr offer, timing of sale process, possible 363 sale to sell real estate as part of Moglia's duty to pursue asset sales 12/17/2018 Review 0.40 460.00 JG correspondence from Lauren Newman and Trustee's Response and Objection ta 400.00/hr Judgment Creditor's Motion for Relief from Automat/c Stay as part of Moglia's consuiting services to trustee re financial impact on the estate

1 NO

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irs/Rate Amoun 12/18/2018 Review 0.30 120.00 JG numerous electronic correspondence re: Longo motions and claim and financial 400,00/hr effect on estate and creditors given the lengthening and costs of case administration as part of our financial and consulting services to the trustee 12/20/2018 Review 0,20 80.0C JG correspondence with trustee counsel re: deposits in non-operating account: also 400.00/hr re: motion for hiring auctioneer as part of our duties of financial advisory and consulting and pursuing asset sales Review 1,00 400.00 JG bank statements on Rosebud non-operating account as start of preference 400.00/hr analysis work as part of our duties to do a preference analysis Howe gosushcgey monger 0.40: 200.00 ADM. Lauren Newman te possible market value will be set by market; possible rejection 500.00/br of lease; will provide Mr, Longo with real estate update as part of our duties re the Duties estate. lease and pursuing sale of real estate JG feal estate broker's revised appraisal of the value, challenges, benefits of _ 400.00/hr property; also review of numerous emails between trustee, counsel, and broker re marketing the property as part of our duties to pursue the Sale of the real estate REVIEW peep epee these ob oe oe obo 41,30 □□□□□□□ ADM humerous emails te sale of real estate, assets and preference analysis for 500.00/hr Duties Purposes of maximizing. net proceeds as part of our duties to the trustee 1/2/2019 = Review 0.20 80.00 JG marketing brochure from broker and reviewed correspondence re: new offer from 400,00/hr Kingdom Farms, and proof of funds as part of our duties to pursue the saie of the real estate Review 0.10 40,00 JG wire transfer backup for wires related to Debtor paying legai fees as part of our 400.00/hr analysis of possible fraudulent transfers Correspondence 0.10 40.00 JG exchange with Trustee correspondence re: dates of bills of sale vs dates of 400.00/hr deposits on asset sales for possible fraudulent transfers as part of our duties to the trustee Review 0.30 120.00 JG sales documents, bilis of sale, etc for company vehicles, and trallers for possible 400.00/hr fraudulent transfers as part of our duties in analyzing possible fraudulent transfers to the trustee

M.A. Page 8

Hrs/Rate □□□□□□ 4/3/2019 Review 0.10 40.01 JG correspondence between appraiser and counsel re: value ofassets that may be 400.00/hr included in Martinez real estate offer as part of our duties to pursue the sales of the real estate and other assets te wl 4.50 1,800.0 JG Trustee re: records retrieved, preference testing schedule per ourduties tothe 400.00/hr trustee Visit 1,50 600.0€ JG office, reviewed files forcash disbursements and receipts records, asset 400.00/nr valuations for possible fraudulent transfers as part of our duties to the trustee Review 0.20 80.00 JG new real estate offer. Call with trustee re: offer including other assets and possible 400.00/nr conflict with planned auction per our duties to pursue the sale of the real estate Rosebud. Metwith Norm Brucer and reviewed bank reporting, pre-petition and 400,00/hr post petition AIR collections and cash disbursements for possible fraudulent transfers as part of our duties to the trustee: Rate Review 1.00 400.00 dG fixed asset listing and asset sale schedules provided by Rich Zondor, debtor's 400.00/hr outside accounting firm, for informing prospective asset buyers as part of our duties to pursue sales of assets 1/4/2019 Review 0.20 80.00 JG correspondence and new offer from Kingdom for realestate. Sent 400.00/hr correspondence to trustee and counsel re: ability to allow buyers to bid after not/ce has been provided as part of our duties to pursue the sale of the real estate 16/2019 Mest 3,00 4,200.00 JG with Norm BruceratRosebud to collect cash receipts and cash disbursement 400,00/nr. 1 Rat records for preference testing as part of our duties to the trustee Rate 1/7/2019 Review 0.50 200.00 JG motion of unsecured creditor to dismiss bankruptcy as part of our financial 400.CO/hr advisory and consulting to thetrustee Prepare 0.20 80.00 JG correspondencere: meritofLongo motions and reviewed counsel's 400.00/nr correspondence re: same re financial impact per our duties as financial advisors and consultants to the trustee te wi 0.36 120.00 JG Trustee Counsel re: Longe filings and their possible financial effects on estate and 400.00/nr creditors per our duties as financial advisors and consultants to the trustee

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Hrs/Rate Amount 1/7/2019 — tleonf. w/ 0.30 120.00 JG Trustee and Counsel re: Longo filings and Trustee response reimpacton 400.00/hr finances ofestate per our duties as financial advisors and consultants tothe trustee Review 0.50 200.00 JG reply toresponse to judgment creditor's motion for relief from automat/c stay and 400.00/hr possible financial impact on estate as part ofour financial and consulting services to the trustee Review 0.10 40.00 JG Debtor's Statement of Assets and Liabilities to identify saleable assets per our 400.00/hr duty to pursue asset sales ticw/ 0.30 120.00 JG Trustee re: records in storage and the need for certain reports of cash 400,00/hr disbursements and receipts for possible voidable transfers per our duties to the trustee 1/8/2019 tlconf. w/ 0.30 120.00 JG trustee, counsel, and counsel for party making offer on real estate per ourduties 400.00/hr to purse sale of the real estate to wi 0.70 280.00 JG trustee and counsel re: assets for sale that may go with building, response to 400.00/hr Longo motions of sale per our duties to pursue sale of the real estate Prepare 1.00 400.00 JG memo to Trustee and counsel re: review of Longo motions and potential financial 400.00/hr effects on other creditors per our duties as financial advisors and consultants to the trustee 1/9/2019 tewl 0.40 460.00 JG trustee re: conversation with Brucer re: old lease vs new lease; alsoret memo on 400.00/hr Longo points to assist trustee and legal counsel for response per our duties as financial advisors and consultants to the trustee Prepare 0.20 80.00 JG amended memo on Longo points to reflect new information onlease and financial 400.00/hr impact to assist trustee and legal counsel for response per our financial and consulting services for the trustee Yo wi 0.30 420.00 JG Jerry Brucer re: differences in lease, annual utility costs, insurance cost, and 400.00/hr history of repairs for informing real estate broker and prospective buyers for our duties to pursue the sale of the real estate

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Hrs/Rate Amoun 1/9/2019 Prepare 0.30 120.0( JG amended memo □□ Longo points toreflect newinformation onleaseand financial 400.00/hr impactto assist trustee and legal counsel for response per our duties as financial advisors and consultants to thetrustee Review 0.10 40.00 JG correspondencefrom trustee counsel re: herconversation with debtor attorney 400.00/hr about administration ofcase and appearance in courton 1/23 to provide sale of assets information tothe trustee, the Court and any other parties present 1/11/2019 tic wi 0.30 120.00 JG Steve Stabiner, Heath, re: all non real estate assets, valuations, etc per □□□ duty 400.00/hr to pursue sales of assets Review 0.30 120.00 JG correspondence between real estate broker, trustee, counsel, etc re: combining 400.00/hr equipment with real estate and possibly breaking them up into separate bids / transactions as part of our duties to pursue real estate and other assets sales tic wi 0,10 40.00 JG Trustee re: response to Longo’s objections to sale and effect on creditors' 400.00/hr interests by possible delay of sale and case administrationas partof our financial and consulting advisory to trustee Review 0.90 360.00 JG response letter to Longo and sent comments to trustee and counsel on financial 400.00/hr impact as part of our financial and consulting advisory to trustee 1/12/2019 Review 0.20 80.00 JG correspondence from counsel re: my comments on Longo letter and responded 400.00/hr re: same as to financial impact on other claimants as part of our financial and consulting services to trustee □ 1/13/2019 Review 0.20 80.00 JG Trustee's proposed amendments to response to Longo letter on motion todismiss 400,00/hr 4s part of our financial and consulting services to trustee Review 0.40 160.00 JG revised letter to Longo re: response to motion to dismiss and possible financial 400.00/hr impact. Sent correspondence to Trustee re: same as part of our financial and consulting services fo the trustee 1/16/2019 Review 0.40 160.00 JG Longo amended motion to dismiss bankruptcy. Sent correspondence to trustee 400.00/hr and counsel re: Longo's assertions of late creditor invoices and other unsecured creditors as part of our financial and consulting services to the trustee

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Hrs/Rate Amount Review 0.30 120.00 JG emails between trustee, broker and attorney re: revised offer of second buyer, 400.00/hr deciding whowould bestalking horse, increments for future bidding, terms under which next bids must abide per our duty to pursue sales assets 1/18/2019 to wi 0.20 80.00 JG Jerry Brucer re: tax returns for 2018 and Longo motion to dismiss as part of our 400,00/hr financial and consulting services to the trustee Sent 0.10 40.00 JG correspondence to trustee and counsel re: possible motion to hire professional to 400.00/hr file tax return as part of our financial and consulting services to the trustee ABCD eee pgs neaense coats see 250° □□□□□□□ Court appearance on motion to dismiss as part of our financial and consulting © 400.00/hr: vel Rate services ta the trustee in case financial impact and asset sale questions arose 1/25/2019 Sent 0.10 40.00 JG correspondence to trustee re: need for tax return preparation (or not) as part of 400.00/hr our financial and consulting services to trustee Sent 0.10 40.00 JG request for quote for tax return to Rosebud former accounting firm to determine 400.00/hr cost and timing of preparation as part of our financial and consulting services to trustee fe wi 0.10 40.00 JG Jerry Brucer re: 2018 tax return; told him that owners are free to pay for 2018 tax 400.00/hr returns, as part of our financial and consulting services to trustee Review 0.30 120.00 JG Zondor quote for 2018 tax return. Exchanged correspondence re: extent of 400.00/hr activity in 2018, records with trustee, and lack of complexity in preparation of return by debtor's CPA, as part of our financial and consulting services to trustee 1/26/2019 Review 0.50 200.00 JG correspondence between broker, counsel and trustee re: selection of stalking 400.00/hr horse bidder and pros/cons of same. Sent correspondence to all re: possibly selecting 2nd bidder as stalking horse per our duty to pursue sale of real estate Review 0.10 40.00 JG correspondence from counsel re: my recommendation on stalking horse given 400.00/hr financial considerations per our duty to pursue sale of real estate 2/2/2019 Review 1.00 400.00 JG latest Longo motion and counsel's response to the motion. Also reviewed 400.00/hnr Trustee comments re: same. Sent proposed amendments to trustee and counsel

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Hrs/Rate Amoun' and sent additional questions re: same: ail above re financial implications per our duty to provide financial and consulting services to trustee 2/5/2019 tlcanf. wi 7.00 400.00 JG broker, trustee, trustee counsel re: selection of Stalking horse bidder, treatment of 400.00/nr personal property, auction process, break up fee, and bid increments per our pursuit of saie of the real! estate Prepare 0.20 80.00 JG correspondence to all re: confirmation of decisions from conference call re 400.00/hr sélection of stalking horse and back up bidder Per OUr pursuit of sale of the rea! estate 2/6/2019 Correspondence 0.20 80.00 JG exchange with Rich Zondor, CPA re: 2018 tax returns and that the trustee will not 400.00/hr sign Zondor's engagement letter, per our financial advisory and consulting to the trustee ROVE songs genon ng dept eget 0:20 400.00 ADM Gallo's summary of our discussion with counsel re selection of stalking horse per. 900.00/hr: OM duties to pursue the sale of the real estate Duties 2/17/2019 Review 0,50 200.00 JG lease termination agreement and latest draft of contract. Prepared 400.00/hr correspondence to trustee and counsel re: comments, per our duties re the real estate lease Review 0.20 80.00 JG new offer for real estate (over the stalking horse) and sent correspondence to 400.00/hr counsel re: process where bidder can out-bid stalking horse per our duty to pursue sale of real estate Review 0.50 200.00 JG correspondence from counsel re: Longo. Reviewed Longo fee application (in 400.00/hr district court case) as basis for his proof of claim and Judge Dow's objection to Longo's fee rate and hours, for purposes of trustee's claims review, per our financial and consulting services performed for the trustee 2/13/2019 Review 0.30 120.00 JG Trustee's counsel's response to Motion to Dismiss and sent correspondence re: 400.00/hr same as to financial impact and reasonability of economic considerations per our duties to provide financial and consulting services to the trustee 2/14/2019 Review 0.30 120.00 JG Stalking horse request to increase break Up fee; prepared correspondence to 400.00/hr counsel and trustee re: disallowing increase in break up fee; per our duty to pursue the sale of the real estate

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Rosebud M.A. Page 13

Hrs/Rate Amoun 2/14/2019 Review 0.10 40.00 JG trustee's correspondence to stalking horse counsel re: not increasing break up fee 400.00/hr and timing of survey per our duty to pursue the sale of the real estate 2/15/2019 Review 0.40 160.00 JG stalking horse contract changes. Prepared correspondence to counsel re: not 400.00/hr terminating lease until after closing: hoiding break up fee, confirming tenant has paid ali taxes per our duty to pursue the sale of the real estate 2/19/2019 Review 0.40 160.00 JG lease termination agreement. Sent correspondence to counsei re: not executing 400.00/hr agreement until after confirmation of ail taxes paid, and real estate sale has closed per our duty to pursue the sale of the real estate Review 0.10 40.00 JG correspondence with bidder counsel re: changes to real estate contract and 400.00/hr termination agreement per our duty to pursue the sale of the real estate Review 0.30 120.00 JG correspondence from counsel re: requested reimbursements by bidder for various 400.00/hr clauses in real estate contract. Sent correspondence to counsel and trustee re: possibly denying reimbursement for tenant improvements because of offset in lease reduction per our duty to pursue the sale of the real estate 2/20/2019 Review 0.70 40.00 JG correspondence from counsel! re: agreements/disagreements on real estate 400.00/hr contract changes with stalking horse bidder per our duty to pursue sale of the real estate Correspondence 6.20 80.00 JG exchange with Jim Inendino re: changes to real estate contract and timing of 400.00/hr termination of lease agreement per our duty to pursue sale of the real estate Review 0.50 200.00 JG Longo's Reply and Motion to Stay. Prepared correspondence to trustee counsei 400.00/hr re: same about financial implications per our financial and consulting services to the trustee Review 1.00 400.00 JG trustee counsel's comments on Creditor's Reply to Trustee Response. Exchanged 400.60/hr correspondence with counsel and trustee re: same per our financiai and consuiting services to the trustee Correspondence 0.10 40.00 JG exchange with Newman re: hiring accounting firm to file 2018 taxes per our 400.00/hr financial and consulting duties to the trustee

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Rosebud M.A, Page 1

Hrs/Rate Amour 2/21/2019 Yew! 0.70 □□□□□ JG Lauren Newman re: stalking horse bidder's request to close within 15 days of 400.0G/hr auction; also re: need for expedited sale of assets; not terminating lease until after real estate close; and Longo's threat of appeal as a cause of further unnecessary delays and costs per our duty to pursue sale of assets 2/22/2019 Email 0.30 □□□□□□ JG exchange with Steve Stabiner and trustee counsel re: personal property, asset 400.0¢/hr listings and valuations per our duty to pursue sale ofassets Correspondence 0.10 40.0C JG exchange with Rich Zonder, CPA, re: 2018 tax returns as most information 400.0G/hr Zondor can get from debtor, per our financlal and consulting advisory to trustee

2/24/2019 Correspondence 0.20 80.00 JG exchange witrustee and counsel and reviewed correspondence from debtor and 400.00/hr accounting firm re: need for 2018 returns and responsibility to do them per our financial and consulting advisory to trustee 2/26/2019 Review 0.20 80.00 JG correspondence re; 2/27 court appearance and next steps on asset sales and 400.0G/hr existence of possible fraudulent transfers per our financial and consulting advisory to the trustee

ADM —_exchange Te’ phase Il analysis of environmental conditions (for effecton buyers) 500.00/hiF ... afd modification. of breakup fee; per our duty to pursue sale of real estate stee Duties 3/16/2019 Review 9.20 80.00 JG correspondence re: environmental issues at real estate and increase ofbreak up 400.00/hr fee to cover cost of Phase llas possible financial deterrent to buyers, per our duty to pursue sale of real estate ADM draft fee application for financial and operational services per ourfinancial and 500.00/hr sonsulting services to trustee: Duties 4/5/2019 Email 0.20 80.00 JG exchange with counsel re: last minute appeal filed by secured creditor's counsel 400.00/hr on staying of sale and effects on sale process per our duty to pursue sale of the real estate 4/18/2019 Review 0.20 80.00 JG ad for publishing on auction/sale of property; responded to trustee and counsel re: 400.00/hr need for price and escrow, all per our duty to pursue sale of the real estate

Rosebud M.A. Page 15

Hrs/Rate Amount 4/16/2019 Review 0.50 200.00 JG Longo filing to stay bankruptcy case. Sent comments to trustee and counsel on 400.00/hr effects on sale process, per our duly toe pursue sale of the real estate 4/29/2019 Review 0.10 40.00 JG counsel's emails re: phase [| environmental considerations and possible effects 400.00/hr on sale process and price, per our duty to pursue sale of the real estate Review 0.50 200.00 JG environmental report. Sent correspondence to trustee re: same as to saleabillty of 400.00/hr property and possible effects on sale process and price, per our duty to pursue sale of the realestate

For professional services rendered 78.80 $32,190.00 Additional Charges: 11/14/2018 SMileage 58.32 JG $Milleage. 62:06 JG 4/23/2019 Parking 40,00 JG $Mileage 27.84 JG

Total additional charges. $188.22 Total amount of this bill $32,378.22 Balance due $32,378.22