The opinion
UNITED 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 LAUREN NEWMAN AND THOMPSON COBURN LLP, COUNSEL FOR
CHAPTER 7 TRUSTEE, FOR ALLOWANCE AND PAYMENT OF FIRST INTERIM
COMPENSATION AND REIMBURSEMENT OF EXPENSES
TOTAL FEES REQUESTED: $126,460.00 TOTAL COSTSREQUESTED: $ 636.50
TOTAL FEES REDUCED: $ 4,658.75 TOTAL COSTS REDUCED: $ 0.00
TOTAL FEES ALLOWED: $121,801.25 TOTAL COSTS ALLOWED: $ 636.50
TOTAL FEES AND COSTS ALLOWED: $ 122,437.75
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) Improper Allocation of Professional Resources — TOTAL of disallowed amounts $ 3,110.50
The Court denies the allowance in part of compensation for the indicated task(s) as a
professional with a lower level of skill and experience or a paraprofessional could have performed
the task(s). Jw re Peftebone, 74 B.R. 293, 303 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (‘Senior partner
tates will be paid only for work that warrants the attention of a senior parmer. A senior partner who
spends time reviewing documents or doing research a beginning associate could do will be paid at a
rate of a beginning associate. [Citation omitted]. Similarly, non-legal work performed by a lawyer
which could have been performed by less costly non-legal employees should command a lesser
rate.”); In re Wildman, 72 B.R. 700, 710 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (same); Iz 1 Alberto,
121 B.R. 531, 535 (Bankr. N.D. Ill. 1990) (Squires, J.) (determining use of partner appropriate where
attendant complex legal issues warrant highly experienced practitioner).
In this case, the entries reduced under this category have been allowed at the associate rate
for research assignments that could have been delegated to an associate.
(2) Unreasonable Time — TOTAL of disallowed amounts: $ 892.00
The Court denies the allowance in part of compensation for the indicated task(s) since the
professional or paraprofessional expended an unreasonable amount of time on the task(s) in light of
the nature of the task(s), the experience and knowledge of the professional performing the task(s),
and the amount of time previously expended by the professional or another on the task(s). In re
Pettibone, 74 BR. 293, 306 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) (“The Court will determine what
is the reasonable amount of time an attorney should have to spend on a given project... An attorney
should not be rewarded for inefficiency. Similarly, attorneys will not be fully compensated for
spending an unreasonable number of hours on activities of little benefit to the estate.”); In re
Wildman, 72 B.R. 700, 713 (Bankr. N.D. Il. 1987) (Schmetterer, J.) (same).
In this case, any time charged for attending hearings where the matter has been granted in
chambers will not be tolerated.
Additionally, the court cautions counsel that the time entries for hearings in general were
almost an hour beyond the hearing time. Counsel cannot bill for commute time to the court and
such entries will be strictly scrutinized going forward.
(3) Unreasonable Travel Rate — TOTAL of disallowed amounts (50% of affected entries):
$656.25
The Court denies the allowance in part of compensation for travel time or entries that are
lumped with travel time, where compensation at the normal houtly rate (not the customary one-half
discounted rate) is sought without explanation. In 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.”); Ia re McKeeman, 236 B.R. 667 (B.A.P. 8th Cir.1999); In re § panjer Bros.,
191 B.R. 738, 755 (Banke. N.D. Ill. 1996) (Squires, J.). ©
Dated: August 21, 2019 NSS J)
Timothy. Bates AH
United States Bankruptcy Judge
EXHIBIT A
FEES
Case Administration:
Paralegal
Lauren reviewing bankruptcy court docket $525.00
Lauren trustee, re equipment sales by debtor $525.00
Lauren statement of financial affairs $525.00
Addis determine status of encumbrances against the | $435.00
teal estate
10/01/18 | Newman, Review and analyze the district court docket 1.50 $787.50
Lauren and pleadings in discrimination case against $525.00
debtor, the opinion of the seventh circuit
ruling against the debtor and the judgment
against the debtor
A. searches against Rosebud Farm, Inc. §215.00
10/01/18 | Newman, Communication to 8. Walsh, Chicago Title, ta 0.20 $105.00
Lauren order lian search on debtor's real! estate $525.00
Lauren on debtor's real estate $525.00
Lauren copies of liens from recorder of deeds re liens | $525.00
on debtor's real estate and advise on same
Lauren $525.00
Lauren $525.00
Lauren debtor's real property $525.00
10/03/18 ) Newman, Communication to J. Lango, counsel for 0.20 $105.00
Lauren judgment creditor, for introduction and to $525.00
advise against additional liens against debtar’s
property
A. forward same to L. Newman $215.00
Lauren for judgment creditor, to respond to questions | $525.00
on lease and other matters
Lauren results of UCC and judgment lien searches for | $525.00
debtor
Paralegal
| 10/08/18 Review and analyze results of UCC and $262.50
Lauren judgment lien searches for debtor $525.00
10/17/18 | Newman, Review district court docket, citation pleadings 0.80 $420.00
Lauren and court orders for citatians to discover $525.00
assets, in order to ascertain post-petition liens
by judgment creditor
10/17/18 | Newman, Detailed communication to A. Moglia, trustee, 0.40 $210.00
Lauren to advise on status of citation liens filed by $525.00
judgment creditor and whether assets remain
in estate
Lauren debtor's assets, including Quade decision $525.00;
10/19/18 | Newman, Communications to and from A. Moglia, 0.20 $105.00
Lauren trustee, to plan strategy re possible lease
fe” ernment
10/23/18 | Newman, Review schedules and prepare questions for 1.20 $630.00
Lauren upcoming continued 341 meeting of creditars | $525.00
10/23/18 | Buckley Jr., Review schedules and SOFA in preparation for 0.80 $496.00
Francis X. investigation of asset disposition by principals | $620.00
10/24/18 | Buckley Jr., Meeting with D. Brown, attorney far debtor, 0.80 5496.00
Franc’ _|rebetrounoeestors dost stots [S009]
10/24/18 | Newman, Communication te J. Longo, counsef to R. 0.20 5105.00
Lauren Smith, judgment creditor, to advise that $525.00
automatic stay prevents any further
perfection of liens and trustee will move for
contempt if he files liens post-petition
16/24/18 | Newman, Cammunication to J. Longa, counsel to R. 0,20 $105.00
Lauren Smith, judgment crediter, to advise that $525.00
fees automatic stay prevents appeal of his fee ee
award in district court litigation
10/24/18 | Newman, Communication to J. Longa, counsel to R. 0.20 $105.00
Lauren Smith, re cost considerations of extensive $525.00
litigation against Debtor
10/24/18 | Newman, Communication ta J, Longo, counsel to R. 0.20 $105.00
Smith, re debtor's pre-petition liquidatian of seo)
its assets
10/24/18 | Newman, Review motion to lift stay by R. Collum,
Lauren personal injury claimant, to pursue insurance | $525.00
10/24/18 | Newman, Review outcome of creditors meeting and
Lauren analyze possible asset recove $525.00
10/24/18 | Newman, Appear at continued meeting of creditors 2.20
Lauren along with the trustee, and assist trustee in $525.00
questioning the representative of the debtor
Pe
Paralegal
Newman, | Communication to 0. Brawn re receipt of copy | 0.10 $52.50
Lauren of lease on Debtor’s premises $525.00
10/31/18 | Newman, Correspondence from M. Teich, counsel to R. 0.20 $105.00
Lauren Cullam, personal injury claimant, to advise $525.00
Trustee has no objection to relief fram stay
against insurance proceeds only
Lauren behalf of A. Moglia, trustee $525.00
11/06/18 | Newman, Review amendment te lease and 0.20 $105.00
Lauren communicate to 4. Moglia, trustee, re $525.00
termination date for lease
11/07/18 |} Newman, Communication ta J. Gallo, Moglia Advisors, to 0.20 $105.00
Gguren”” __|Seutopyotes and emeromentrotese | $52500| "|
Lauren Gallo’s rale in case and to plan strategy $525.00
11/07/18 | Newman, Telephone call with J. Gallo, , to advise on 1.00 $525.00
rem eran [ute]
and other issues in case
Lauren debtor to plan strategy $525.00
Lauren Gallo’s role in case 5525.00
11/07/18 | Newman, Draft memorandum to A. Moglia, trustee, and 2.50 | $1,312.50
ees a
case, and to olan for upcoming conference call
Lauren conference cail with trustee $525.00
41/09/18 | Newman, Legal research timing of trustee’s right to 1.80| $945.00.
ees |
including issues under 365(h)
11/09/18 | Newman, Telephone conference with 4. Mostia, trustee, 1.30 $682.50
Lauren te plan strategy re recavery of assets, sale of $525.00
property, review pre-petition actions by
debtor and other matters
11/12/18 | Newman, Communication to J. Longo, counsel for 0.20 $105.00
pe fe [eenciteaneeeane |)
appearance in bankruptcy case to get
pleadings and notices
Lauren amended schedules $525.00
41/12/18 | Newman, Detailed communication and legal 0.40 §210.00
Lauren memorandum to A. Moglia, trustee, re $525.00
acne, [=]
debtor is lessor
Attorney/ Description
Paralegal
| 11/12/18 | Newman, Review results of research an assumption and 0.50| $262.50
Lauren rejection of lease where debtor is lessor: $525.00
Newman, Draft motion for 2004 exam on Providence 1.50 $787.50
Lauren Bank & Trust $525.00
41/15/18 | Newman, Communications to and from A. Moglia, 0.20 $105.00
Lauren trustee, and J. Gallo, re proof of sales by $525.00
debtor
11/16/18 | Newman, Continue to draft motion for 2004 exam on 1.50 $787.50
Lauren Providence Bank and draft subpoena for §525.00
documents
11/19/18 | Newman, Communication to A. Moglia, trustee, with 0.20 $105.00
Lauren draft of motion for 2004 exam on Providence | $525.00
Bank
11/19/18 | Newman, Detailed memorandum to J. Gallo at Moglia 0.40 $210.00
lauren Advisors re timeline of litigation against the $525.00
debtor
11/20/18 | Newman, Communication to D. Brown, counse! for 0.30 $157.50
Lauren debtor, to request all documents concerning $525.00
pre-petition sales of equipment, trucks and
trailers by debtor, including appraisals
11/20/18 | Newman, Communications to and from A. Moglia, 0.20 $105.00
Lauren trustee, re filing 2004 motion and motion to $525.00
employ
11/26/18 | Newman, Communications with D. Brown, counsel for 0,10 $52.50
. Lauren Debtor, re no receipts for equipment sales $525.00
11/26/18 | Newman, Communication to A, Moglia, trustee, and J, 0.20 $105.00
Lauren Gallo, re counsel for debtor confirming no $525.00
documentation of equipment sales
11/26/18 | Newman, Communication to J. Gallo, Moglia Advisors, re 0.20 $105.00
Lauren upcaming motion for 2004 exam an $525.00
Providence Bank
11/27/18 | Newman, Review and analyze correspondence from 0.20 $105.00
Lauren another personal injury claimant against the $525.00
59/28/18 | Newman, Appear in court far motion for 2004 0.80| $420.00
11/28/18 | Newman, Communication to A. Mogtia, trustee, to send 0.20 $105.00
ee teen copy of order granting motion for 2004 exam saa]
on Providence Bank
11/28/18 | Newman, Communications to and from J. Gallo at 0.20 $105.00
Lauren Moglia Advisors re 2004 exam on Providence | $525.00
Bank
11/28/18 | Newman, Draft motion for extension of time to assume 3.20} $1,680.00
BASE Lauren or reject real property lease, prepare $525.00
[Pate | Atormey Description Amount
Paralegal
proposed order and prepare motion for
extension of time for filing
11/29/18 | Newman, Telephone call with A. Moglia and J. Gallo to 0.70 $367.50
Lauren plan strategy re sale of real estate, plan for $525.00
fraudulent transfer analysis, and to review
other issues In the case
11/29/18 | O'Keefe, Julie L. | Transmit to and communicate with special 0.40 $102.00
process server re subpoena for rule 2004 $255.00
examination to Providence Bank & Trust
Detailed communication to D. Nemeraov, 0,30 $157.50
Lauren personal injury counsel, to advise of automatic | $525.00
stay and to take no further action against
debtor
11/29/18 | Newman, Communications to and fram A. Moglia to 0.20 $105.00
Lauren schedule a conference call to plan next steps $525.00
12/03/18 | Newman, Communication to C, Conner, Providence 0.20 $105.00
Neon Bank, to send copy of order authorizing 2004 saa)
exam on the Bank and to call with questions
12/03/18 | Newman, Telephone call with C. Conner, Providence 0.20 $105.00
Lauren Bank, re compliance with discovery for trustee | $525.00
on the Bank
12/04/18 | Newman, Communication to A. Mogiia re continued 0,10 $52.50
Lauren hearing on mation ta retain Mogliia Advisors $525.00
and to extend deadiine to assume or reject
lease
12/04/18 | Newman, Communication to A. Moglia, trustee, to 0.20 $105.00
eee seen | advise debtor is requesting direction on ss)
preparation of tax return
Communication to J. Gallo re subpoena
Lauren response from Providence Bank $525.00
12/04/18 | Newman, Communications ta and fram D. Brown, 0.10 $52.50
eee ie counsei for debtor, re preparing and filing sean]
2018 taxes
Review successful service of subpoena on
Lauren Providence Bank $525.00
12/11/18 | Newman, Review multiple communications from C. 0.40 $210.00
Lauren Conner with debtor's bank account $525.00
documents, and forward same to J. Gallo at
Moglia Advisors
Telephone call with C, Conner, Providence
Lauren Bank, re compliance with trustee’s subpoena $525.00
for documents on debtor's accounts
Lauren Advisors, from Providence Bank with $525.00
documents for the 2004 production
Attorney/ Description
Paralegal
12/14/18 | Newman, Communications to and from C. Conner at 0.20 $105.00
Lauren Providence Bank re production of documents {| $525.00
12/14/18 | Newman, Multiple communications to J. Gallo, Moglia 0.30 $157.50
lauren Advisors, with production of decuments from | $525.00
Providence Bank
Communication to A. Moglia, trustee, to 0.20} $105.00
Lauren advise on outcome of court hearing and next | $525.00
court date
12/20/18 | Newman, Multiple communications to J. Gallo, Moglia 0.30 $157.50
Lauren Advisors, with documents from Providence $525.00
Bank with deposit statements from debtor’s
accounts
Newman, Review multiple emails from Providence Bank 0.30] $157.50
Lauren with deposit statements from debtor's $525.00
accounts
12/21/18 | Newman, Review multiple communications from 0,30 $157.50
eee ie | Providence Bank with documents for debtar’s sce)
accounts
12/21/18 | Newman, Multiple communications to J. Gallo, Moglia 0.20 $105.00
Lauren Advisors, with documents from Providence $525.00
Bank
12/21/18 | Newman, Communications to and from R. Nelson, real 0.20 $105.00
Lauren estate broker, re updates on marketing the $525.00
property and preparing marketing summary
for J. Langa
12/21/18 | Newman, Communication to J. Longo, judgment 0,20 $105.00
ee seen creditor, to advise real estate has been listed aaa] OP"
with broker
12/27/18 | Newman, Communication to C. Conner from Providence 0.10 $52.50
Lauren Bank confirming additional documents $525.00
01/02/19 | Newman, Review and forward multiple communications 0.50 $277.50
Lauren with documents from Providence Bank re $555.00
Debtor’s bank accounts to J. Gallo, Moglia
Advisors
Newman, Multiple communications with additional
Lauren documents from Providence Bank re debtor’s | $555.00
bank accounts to J. Gallo, Moglia Advisors
01/02/19 | Newman, Communications to and from J. Gallo, Moglia 0.20 $111.00
(ES [aun [enone tangopymamtseacor | 3sssa0|
01/02/19 | Newman, Communication to A. Moglia, trustee, with re $55.50
lauren” | oertorsauteatee nyesien | ssean
01/02/19 | Newman, Communication te and from J, Brown, counsel 0.10 $55.50
Lauren for debtor, re invoices for sale of trailers $555.00
Date Attorney/ Description
||
01/07/19 | Newman, Multiple communications to J. Gallo, Moglia 0,30 $166.50
Lauren Advisors, with documents from debtor’s bank | $555.00
accounts at Providence Bank
01/11/19 | Newman, Multiple communications to J. Gallo, Moglia 0.40 $222.00
Lauren Advisors, to send documents from Providence | $555.00
Bank with debtar’s bank account information
01/25/19 | Newman, Communications to and from J. Gallo, Moglia 0.20 $111.00
Lauren Advisors, re retaining accounts te file tax $555.00
returns on behalf of Debtor
Multiple communications with documents
Lauren from Providence Bank to J. Gallo, Moglia $555.00
Advisors, for review and analysis
01/31/19 | Newman, Communications to and from A. Moglia, 0.20 §111.00
Lauren trustee, re second personal injury claimant $555.00
and contact from defense counsel
Communication to A. Moglia, trustee, to 0.10 $55.50
Lauren advise J. Longo filed a proof of claim $555.00
02/06/19 | Newman, Communication to A. Kazaz, counsel for 0.20 $111.00
Lauren insurance company defending Rosebud Farm | $555.00
in personal injury case re notice to tenant of
pending litigation
02/06/19 | Newman, Telephone call with A. Kazaz, counsel for 0.20 $111.00
Lauren insurance company defending Rosebud Farm | $555.00
in personal injury case re maintaining the
premises
Newman, Communication to A. Moglia, trustee, re hiring $55.50
Lauren accountants te file debtor’s tax returns $555.00
Communications to and from A. Moglia,
Lauren trustee, re communicating directly with R. $555.00
Smith, secured creditor
Newman, Communication to J, Longo, re locating and $55.50
Lauren communicating with R. Smith, secured $555.00
creditor
03/08/19 | Newman, Communications to and from A. Moglia, 0.20 $111.00
Lauren trustee, re locating and communicating with §555.00
R. Smith, secured creditor
03/28/19 | Newman, Communication to A. Mogtia, trustee, to 0.20 $111.00
Lauren advise on upcoming deadline for motion to $555.00
__|_ assume or reject lease
03/28/19 | Newman, Draft motion to extend deadline for motion to 2.50 | $1,387.50
Lauren assume or reject lease, prepare draft order $555.00
and prepare for filing
03/28/19 | Newman, Communication to A. Mogtla, trustee, with 0.20 $111.00
Lauren copy of court filed motion to extend deadline | $555.00
Date Attorney/ Description Hours Amount
Paralegal
for motion to assume or reject lease, and to
advise of court date
04/04/19 | Newman, Review and analyze notice from insurance 0.20 $111.06
Lauren company re proxy request for shareholder $555.00
vote
04/04/19 | Newman, Communication to D. Brown, counsel for 0.20 $111.00
Lauren debtor, re notice from insurance company re {| $555.00
proxy request and to turn over shareholder
information
04/05/19 | Newman, Communications te and from D. Brown, 0.20 $111.00
Lauren counsel for debtor, re shares in insurance $555.00
compan
04/05/19 | Newman, Communication to A. Moglia, trustee, re 0.20 $111.00
ee icuen” __[aautrssresinipue commen) [asssc0|
4/16/19 | Newman, Appear in court for trustee’s motion to extend 1.30 $721.50
Lauren time to accept or reject lease with Kingdom $555.00
Farms
4/18/19 | Newman, Communication to A. Moglia, trustee, with 0.20 $111.00
Lauren copy of order extending deadline to assume or | $555.00
reject lease with Kingdom Farms
reat Charges [550 | $57 35450 |
EXHIBIT B
Retention:
Paralegal
09/24/18 | Newman, Draft motion to employ L. Newman and 2.20 | $1,155.00
Lauren Thompson Coburn as counsel, draft affidavit in | $525.00
support of motion and draft proposed order
employing L. Newman, F. Buckley and
Thompson Coburn, LLP as counsel far Trustee
Newman, Communication to A. Mogtia, trustee,
Lauren preparing retention motion and clearing $525.00
conflicts
09/28/18 | Newman, Arrange for filing motion to employ L. 0.10 $52.50
Lauren Newman and Thompson Coburn.as counsel $525.00
Newman, | Communication to A. Moglia, trustee, to send 0.20 §105.00
Lauren draft of motion to employ L. Newman and $525.00
Thompson Coburn as counsel
09/28/18 | Newman, Communications to and from A. Magiia, 0.20 $105.00
one Lauren | trustee, re scheduling on motion to employ san)
Thompson Coburn as counsel for trustee
09/28/18 | Newman, Revise and finalize motion to authorize trustee 0.20 §105.00
Lauren | to employ L. Newman and Thompson Coburn | $525.00
as counsel for Trustee
| Newman, Appear in court for motion authorize trustee 0:90 | $472.50
grante ‘lauren ‘taemployL. Newman and Thompson Cobum |$525.00;
as counsel:for trustee □□
| 10/10/18 | Newman, Communication to A. Moglia, trustee, with 0.20 $105.00
Lauren order granting motion to authorize trustee ta | $525.00
employ L. Newman and Thompson Coburn as
counsel for trustee
Lauren broker, to request information on Foresite $525.00
Reaity for application to employ real estate
broker
40/15/18 | Newman, Communication to R. Nelson, real estate 0.20 $105.00
Lauren | broker, to request professional credentials for | $525.00
employment application
10/16/18 | Newman, Telephone conference with A. Moglia, 0.30 §157.50
Lauren trustee, re retaining a broker and sight visit to | $525.00
debtor's property to inspect premises
10/16/18 | Newman, Communication ta A. Moglia, trustee, re 0,20 $105.00
Lauren | timing of motion to employ R. Nelson as $525.00
broker
10/16/18 | Newman, | Cammunicatians to and from R. Nelson, real 0.20 $105.00
Lauren estate broker, re preparing the exclusive rights | $525.00
listing agreement with the trustee
Description Hours Amount
Paralegal
10/16/18 | Newman, Draft motion to authorize employment by 2.50 | $1,312.50
Lauren trustee to hire R. Nelson as real estate broker {| $525.00
and Foresite Realty, and draft affidavit of
disinterestedness
10/22/18 | Newman, Begin to review and revise real estate broker's 0.70 $367.50
Lauren exclusive right listing agreement $525.00
10/23/18 | Newman, Continue to proof read and revise exclusive 0.50 $262.50
Lauren rights broker’s listing agreement to comply $525.00
with bankruptcy procedure and create a
redlined version
10/23/18 | Newman, Communication to R. Nelson, real estate 0.20 $105.00
late broker, with affidavit of disinterestedness, for
mation to employ broker
10/23/18 | Newman, Draft motion to authorize employment of R. 1.70 $892.50
Lauren Nelson, real estate broker, draft affidavit in $525.00
support of motion and prepare draft order .
10/23/18 | Newman, Cammunication to R. Nelson, real estate 0.20 $105.00
Lauren broker, to confirm agreed upon commission $525.00
10/23/18 | Newman, Communication A. Mogiia, trustee, with draft 0.20 $105.00
Lauren of motion to employ real estate broker for his | $525.00
review
10/23/18 | Newman, Communication A, Moglia, trustee, re amount 0.10 $52.50
IES Tawar | sfemmisontornotesse ator (sso)?
10/23/18 | Newman, Detailed communication to R. Nelson, real 0.30 $157.50
Lauren estate broker, with draft of exclusive rights $525.00
ee broker’s listing agreement, along with redlined ee
version, and explanation of proposed changes
10/25/18 | Newman, Review and revise motion to employ real 1.50 $787.50
Lauren estate broker, revise proposed order, organize | $525.00
exhibits and prepare for filing
10/29/18 | Newman, Communication to R. Netson, broker, to send 0.20 $105.00
Lauren copy of court-filed motion to retain real estate | $525.00
broker
11/01/18 | Newman, Communication to J. Longo, counsel to R. 0.20 $105.00
Lauren Smith, judgment creditor, to respond to $525.00
inquiry on motion to employ real estate
broker
11/06/18 | Newman, Communication to A. Moglia, trustee, to 0.20 $105.00
Lauren advise on outcome of motion for authority to =
employ R. Nelson and Foresite Realty as
broker
11/06/18 | Newman, Appear in court for Trustee’s motion for 1.60 $840.00
Lauren authority to employ R. Nelson and Foresite $525.00
Date Attarney/ Description Amount
Pee lamest [eB me
Realty as broker and on Cullom’s mation for
relief fram automatic stay re insurance policy
Lauren preparing retention mation for Maglia $525.00
Advisors
Lauren rates of Moglia Advisors $525.00
Lauren Moglia Advisors $525,00
11/19/18 | Newman, Draft motion to employ Moglia Advisors as 2.301 $1,207.50
Pes er | generate ae
order
11/26/18 | Newman, Proof read and revise motion to employ 0.70 $367.50
Lauren Mogtia Advisors as financial consultants to the | 5525.00
trustee
11/26/18 | Newman, Review and revise affidavit in support of 0.40 $210.00
Lauren retention mation for Moglia Advisors $525.00
11/26/18 | Newman, Communication to A. Magtia, trustee, with 0.20 $105.00
pee (seer |e] =
Moglia Advisors, for signature
11/27/18 | Newman, Prepare mation of trustee to employ Maglia
ee ouen”—— [noisorstorting MO
Lauren a court filed copy of application te employ $525.00
Moglia Advisors
12/12/18 | Newman, Communication to A. Moglia, trustee, with 0.10 $52.50
Pi ees [ae]
auctioneer, for his review
12/12/18 | Newman, Cammunicatians to and from S. Stabiner at 0.20 $105.00
Lauren Heath Industrial, re reviewing and executing $525.00
the affidavit of disinterestedness
12/12/18 | Newman, Communication to A. Mogiia, trustee, ta 0.20 $105.00
Lauren advise the court granted his matian to §525.00
authorize employment of Mogtia Advisors and
motion to extend deadline to assume or reject
debtor's lease
12/12/18 | Newman, Appear in court for Trustee’s mation to 1.30 $682.50
Lauren authorize employment of Moglia Advisors and | $525.00
motion to extend deadline to assume or reject
debtor's iease
Lauren auctioneer, draft proposed order, and affidavit | $525.00
of disinterestedness
Paralegal [Hows] Amount
12/20/18 | Newman, Proof read and finalize motion to retain Heath 0.30 $157.50
Lauren Advisors as auctioneer, and arrange for filing $525.00
with court
01/03/19 | Newman, Communications with A. Moglia, trustee, re 0.10 $55.50
Lauren retaining auctioneer even though one offer $555.00
includes purchase of debt's equipment
01/09/19 | Newman, Communication to S. Staber of Heath 0.20 $111.00
Lauren Industrial and A. Moglia, trustee, to advise $555.00
court granted motion for trustee to retain
Heath as auctioneer of debtor’s personal
property business assets
Appear in court for motion to retain Heath 1.20 $666.00
Lauren industrial as auctioneer of debtor’s business $555.00
assets
Total Charges [27.20 | $14,325.00 |
EXHIBIT C
Sale of Property:
Date Attorney/ Description Amount
Paralegal
09/20/18 | Newman, Lauren Telephone call with A. Moglia, trustee, to plan 0.20 $105.00
strategy re possible sale of building $525.00
10/12/18 | Newman, Lauren Communications to and from A. Moglia, 0.10 $52.50
trustee, to schedule a conference call to $525.00
discuss sale of the debtor’s real estate
10/12/18 | Newman, Lauren Review and analyze offer to purchase 0.40 $210.00
Debtor's real estate, and comparables sales $525.00
from trustee
Newman, Lauren Communications to and from A. Moglia, 0.20
trustee, to comment on offer to purchase $525.00
from tenant and amount of existing judgment
10/15/18 | Newman, Lauren Communication to A. Moglia, trustee, and R. 0.20 $105.00
Nelson, real estate broker, to advise that the $525.00
Debtor had the 130th Street property
appraised back in 2015
10/15/18 | Newman, Lauren Communication to R. Nelson, real estate 0.20 $105.00
broker, to send a copy of the title report for $525.00
the 130th Street property
10/15/18 | Newman, Lauren Detailed communication to D. Brown, counsel 0.20 $105.00
a for Debtor, to request information on the
130th Street property
10/15/18 | Newman, Lauren Prepare for conference call with trustee by 0.30 $157.50
ens [Newman ren | Teveung compare sss wonton” | snso0|
10/15/18 | Newman, Lauren Telephone conference with A. Moglia, 0.50 $262.50
trustee, and R. Nelson, real estate broker, to $525.00
plan strategy re sale of the 130th Street
property
10/18/18 | Newman, Lauren Multiple communications to and from A. 0.30 $157.50
Moglia, trustee’s office re site visit to debtor's satan)
premises and obtaining copy of appraisal
10/19/18 | Newman, Lauren Communication to A. Moglia, trustee, report 0.20 $105.00
“os on site visit to debtor’s premises at 130th jsaao)
Street
Chicago, with real estate broker and to $825.00
inspect premises and equipment
10/23/18 | Newman, Lauren Communication to A. Moglia, trustee, with 0.20 $105.00
copy of appraisal from Debtor from 2015 for
eee | geri
10/31/18 | Newman, Lauren Review correspondence from M. Teich, 0.20 $105.00
counsel to R. Cullom, personal injury 5525.00
claimant, re preserving premises and
inspection of same
Paralegal
Newman, Lauren Telephone call with A. Moglia, trustee, to plan $105.00
strategy re sale of property $525.00
11/07/18 | Newman, Lauren Communication to R. Nelson, real estate 0.20 $105.00
broker, with copy of court order and court $525.00
approved listing agreement _
Analysis of Debtor's sale of trucks and trailers
pre-bankruptcy 5525.00
11/08/18 | Newman, Lauren Telephone call with R. Nelson, real estate 0.50 $262.50
broker, to analyze market values and discuss $525.00
possible listing price for property of the
estate ,
11/15/18 | Newman, Lauren Telephone call with J. Gallo, Moglia Advisors, 0.50 $262.50
eee to plan strategy re pre-petition sales of assets
by debtor
12/03/18 | Newman, Lauren Telephone call with D. Goris, counsel to 0.10 $52.50
Kingdom Farms, re offer to purchase Debtor's | $525.00
real property
12/03/18 | Newman, Lauren Communications to and from J. Gallo at 0.20 $105.00
pe ee Moglla Advisors re timing for auction of
equipment
12/03/18 | Newman, Lauren Communication to A. Moglia, trustee, re 0.20 §105.00
conversation with D. Goris, counsel to §525.00
Kingdom Farms, re offer to purchase debtor's
real property
12/10/18 | Newman, Lauren Communication to and from R. Nelson, real 0.10 $52.50
aye estate broker, re offer to purchase property seco]
from tenant
12/13/18 | Newman, Lauren Telephone call with A. Moglia, trustee, and R. 0.90 $472.50
ae ene Nelson, real estate broker, to analyze offer jsasao)
and plan strategy re sale of real estate
12/20/18 | Newman, Lauren Communication to R. Nelson, real estate 0.10 $52.50
enemies broker, to request conference call with J. sean]
Longo, creditor of debtor
12/20/18 | Newman, Lauren Communication to J. Longo, judgment 0.20 $105.00
oe creditor, to request a conference call to jsasaa)
discuss the real estate sale
12/24/18 | Newman, Lauren | Communication to D. Brown, counsel for
TRAPS Meme cure | utr reconactng romectve prenser_| $529.00
12/27/18 | Newman, Lauren Communication to A, Moglia, trustee, to 0.20 $105.00
advise real estate contract needs to be $525.00
prepared by counsel due to subject to court
approval and 363 auction sale
Multiple communications to and from J.
Inendino, real estate counsel, re drafting a $525.00
real estate contract for K. Moran of Kingdom
Attorney/ Description
Paralegal
Farms to be contract purchaser and stalking
horse for 363 sale
12/28/18 | inendino, James V. | Communications to and from Lauren 0,50 $255.00
Newman re drafting contract (.3); review $510
title/letter report (.2)
12/28/18 | Newman, Lauren Communication to A. Moglia, trustee, to 0.10 $52.50
introduce J. Inendino, who will be assisting $525.00
with real estate sale
Communication to A. Moglia, trustee, to $111.00
comment on letter of intent from Martinez $555.00
Produce to purchase real estate
01/03/19 | Newman, Lauren Review and analyze letter of intent from K. 0.30 $166.50
Kauffman, counsel to Martinez Produce, re $555.00
offer to purchase real estate
Communications to and from S, Stabner from $111.00
Heath Industrial, re value of personal $555.00
property assets
01/03/19 | Newman, Lauren Communication to S$. Stabner of Heath 0.20 $111.00
Industria], to advise to put auction sale of $555.00
equipment on hold while trustee pursues one
of the offers
Communication to and from S. Stabner of 0.10 $55.50
Heath Industrial, re value of debtor’s personal | $555.00
property and equipment
Draft Purchase and Sale Agreement
$510
Newman, Lauren Communications to and from J. inendino, real 0.30 $166.50
estate counsel, re preparing real estate $555.00
contract for sale motion
01/04/19 | Newman, Lauren Communications to and from R. Neilson, real 0.20 $111.00
eae eee estate broker, re another offer on the real setao
property
01/05/19 | Newman, Lauren Communication to A. Mogiia, trustee and R. 0.30 $166.50
Nelson, broker, to plan and prepare for a 363 seasao) OP
sale and the stalking horse bidder
01/07/19 | Newman, Lauren Correspondence to K. Kauffman, counsel for 0.30 $166.50
Martinez Seafood, re letter of intent and 5555.00
potential purchase of debtor's real property,
and to schedule a conference call with trustee
and broker
01/07/19 | Inendino, James V. | Communication to and from L. Newman re 0.30 $162.00
conference call with trustee and potential saan)
purchaser's counsel
01/07/19 | Newman, Lauren Correspondence to R. Nelson, broker, and J. 0.10 $55.50
is [Meveanaee | anna revit couenemnirene_| sssz00)
Paralegal
call with trustee and potential purchaser’s
| eg ees
01/08/19 | Inendino, James V. | Review LOls (.5); prepare for conference call 1.50 $810.00
with trustee and purchaser (.5); telephone $540.00
conference call A. Moglia, trustee, regarding
Sale and Purchase Agreement (.5)
01/08/19 | Newman, Lauren Telephone conference with K. Kauffman, 0.50 $277.50
counsel te Martinez Seafood, R. Nelson, $555.00
broker, and A. Moglia, trustee, to review
letter of intent and to discuss sale process
with potential purchaser
Inendino, James V. | Conference with L. Newman re: bankruptcy $162.00
staulking horse issues $540,00 | $262.00)
01/11/19 | Newman, Lauren Communication to A. Moglia, trustee, to 0.20 $111.00
comment on buyers including equipmentinto | $555.00
bids on real property
Communication to J. Gallo re factoring in sale
of equipment into sale of real estate $555.00
01/11/19 | Newman, Lauren Telephone call with A. Moglia, trustee, to 0.20 $111.00
review offers to purchase real property and to | $555.00
plan strategy
Newman, Lauren | Telephone calf with K. Kauffman, counsel for $111.00
Martinez Seafood, re offer to purchase real $555.00
property
Newman, Lauren | Communication to R. Nelson, broker, to $111.00
follow up on offers to purchase debtor's real $555.00
property
01/17/19 | Newman, Lauren Telephone call with K. Kauffman, counsel for 0.20 $111.00
Martinez Seafood, to discuss revised offer to $555.00
purchase debtor's real estate
01/17/19 | Newman, Lauren Telephone call with R. Nelson, real estate 0.20 $111.00
broker, to review competing offers to $555.00
purchase debtor's real estate and to plan how
to proceed
01/17/19 | Newman, Lauren Telephone cail with A. Moglia, trustee, to plan 0.20 $111.00
es rena response to multiple offers to purchase satan)
property
01/17/19 | Newman, Lauren Communication to R. Nelson, real estate 0.10 $55.50
broker, to request a conference call on $555.00
competing offers to purchase debtor's real
estate
01/17/19 | Newman, Lauren Communication to K. Kauffman, counsel for 0,20 $111.00
Martinez Seafood, to request revised offerto | $555.00
purchase debtor's real estate be put in
writing in a LOI
Date Attorney/ Description Amount
oe lpnaog [een ees int
01/17/19 | Newman, Lauren Detailed communication to A. Moglia, 0.30 $166.50
trustee, and J. Gallo, re recommendations by | $555.00
R. Nelson re proceeding with bids on real
estate
. 01/17/19 | Newman, Lauren Telephone cail with A, Moglia, trustee, to 0.10 $55.50
advise on revised offer from Martinez $555.00
Seafood
01/21/19 | Newman, Lauren Communication to S. Stabner from Heath 0.10 $55.50
Industrial to respond to inquiry on status of $555.00
auction
01/24/19 | Inendino, James V. | Conference with Lauren Newman re 0.20 $108.00
deen eee nN eaactoruaasganeen” | gsaca| =
01/24/19 | Newman, Lauren Communication to K, Kaufman, counsel for 0.20 $111.00
Martinez Seafood, re procedure for bidding $555.00
on property
01/25/19 | Newman, Lauren Communications to and from R. Nelson, 0.30 5166.50
broker, re terms and conditions of sale to be $555.00
conveyed to potential purchaser K. Moran,
including increase in down payment
Newman, Lauren Telephone call with A. Mogiia, trustee, to plan 0.70 $388.50
strategy re auction sale of real property $555.00
01/25/19 | Newman, Lauren Communications to and from K. Kaufman, 0.20 $111.00
counsel to Martinez Seafood, re decision by $555.00
Trustee on stalking horse bidder
01/25/19 | Newman, Lauren Communication to R. Nelson, real estate 0.20 $111.00
broker, re requesting an updated LOI from K. | $555.00
Moran re latest offer to purchase real
property
01/25/19 | Newman, Lauren | Review and revise purchase and sale $222.00
agreement for real estate $555.00
01/29/19 | Newman, Lauren Communication to A. Moglia, trustee to 0.20 $111.00
advise on cail with K. Kaufman, counsel for §555,00
Martinez Seafood, and possible contract
terms and sale process
01/29/19 | Newman, Lauren Telephone call with K. Kaufman, counsel for 0.20 $111.00
Martinez Seafood, to advise on terms for $555.00
bidding at sale and possible contract terms
02/01/19 | Newman, Lauren | Communication to R. Nelson, broker, and A. §111.00
Moglia, trustee, re revised offer and increased | $555.00
down payment from one of the purchasers
02/01/19 | Newman, Lauren Communications to and from K. Kaufman,
counsel for Martinez, re decision on offer $555.00
02/05/19 |} inendino, James V. | Conference with L. Newman and review $162.00
emails regarding contract $540.00
Paralegal
Begin to review and revise purchase and sale $832.50
agreement and sale notice $555.00
02/05/19 | Newman, Lauren Telephone conference with A, Moglia, 0.90 $499.50
trustee, J, Gallo, Moglia Advisors, and R. $555.00
Nelson, real estate broker, to select stalking
horse bidder and to plan bidding procedures
Draft Contract, Lease Termination Agreement $2,430.00
(4.2); email to Lauren Newman re same (.3) $540.00
02/08/19 | Newman, Lauren Communication on A. Moglia, trustee, with 0.20 $111.00
draft of purchase and sale agreement and $555.00
lease termination agreement for his review
and approval
02/08/19 Review draft of purchase and sale agreement 0.50
92/08/38 and lease termination agreement $555.00
02/08/19 | Newman, Lauren Telephone call with K. Kaufman, counsel to 0.20 $111.00
Martinez, to advise that Martinez will not be $555.00
stalking horse but to come to auction
02/10/19 | Inendino, James V. | Communications to and from L. Newman re 0.40 $216.00
comments and changes to draft Purchase $540.00
Agreement
02/11/19 | Inendino, James V. | Communications to and from title company 0.70 $378.00
regarding new order (.5); conference with $540.00
Lauren Newman re contract issues {.2)
02/11/19 | Newman, Lauren Communication to B. Liston, counsel to K, 0.30 $166.50
Moran, to send draft of the Purchase and Sale | $555.00
Agreement and Lease Termination
02/11/19 | Newman, Lauren Telephone call with 8. Liston, counsel for K. 0.30 $166.50
Moran, to review auction sale process, and §555.00
rejection of iease if K. Moran is not successful
bidder
Telephone call with A. Moglia, trustee, to plan
strategy re sale of assets $555.00
Telephone call with K, Moran, to advise on
sale procedures for debtor's real property $555.00
02/12/19 | Newman, Lauren Communication to B. Liston, counsel to K. 0.20 $111.00
Moran, to advise on telephone conference $555.00
ee with Moran and sale procedures for debtor's a
real property
02/12/19 Communication to B. Liston and T. Goodwyn,
counsel to K. Moran, re comments to contract | $555.00
02/12/19 | Newman, Lauren | Communication to A. Moglia, trustee, re
updated offer on debtor’s real property $555.00
Pate Attorney/ Description Hours | Amount
Paralegal
02/12/19 | Inendino, James V. | Conference with Lauren Newman regarding 0.40 $216.00
stalking horse bid offer and lease termination | $540.00
issues
02/12/19 | Newman, Lauren Communication to K. Kaufman, counsel to 0.10 $55.50
potential purchaser, re updated offer on $555.00
debtor’s real property
02/13/19 | Newman, Lauren Telephone call with T. Goodwyn, counse} for 0.10 $55.50
K. Moran, to follow up on comments to draft | $555.00
purchase agreement
Emails with A. Moglia, trustee, re Stalking $270.00
Horse Contract and emails with T. Goodwyn, $540.00
counsel for purchaser, re same
02/14/19 | Newman, Lauren Telephone call with T. Goodwyn, counsel for 0.30 $166.50
K. Moran, to discuss points in purchase $555.00
agreement and negotiate amount of breakup
fee
02/14/19 | Newman, Lauren Review comments and proposed changes 0.30 $166.50
from T. Goodwyn, counsel for K. Moran, to $555.00
purchase agreement
02/14/19 | Newman, Lauren Communication to T. Goodwyn, counsel for K. 0.20 $111.00
Moran, to advise on Trustee’s position on $555.00
proposed changes to draft purchase and sale
agreement
02/14/19 | Newman, Lauren Communication to T. Goodwyn, counsel for K. 0,10 $55.50
Moran, to request comments to purchase $555.00
en [garner | sto]
02/15/19 | Newman, Lauren Review recent revisions and comments to 0.20 $111.00
oe purchase agreement from counsel for satan)
purchaser
02/15/19 | Inendino, James V. | Revise Stalking Horse Bid contract and memo 1.50 $810.00
to client and Lauren Newman re same (1.3); $540.00
review various emails to and from A. Moglia,
J. Gallo re Stalking Horse Bid contract (.2)
02/15/19 | Newman, Lauren Communication to J. Inendino, real estate 0.20 $111.00
counsel, to comment on recent revisions and $555.00
comments to purchase agreement from
counsel for purchaser
Newman, Lauren | Continue to draft sale motion and procedures
notice of sale $555.00
02/18/19 | Newman, Lauren | Plan strategy re revisions to draft purchase
eece eee pene
02/18/19 | Newman, Lauren | Communication to T. Goodwyn, counsel! for K.
Moran, to negotiate purchase agreement $555.00
Attorney/ Description
Paralegal
02/18/19 j Inendino, James V. | Communications to and from T. Goodwyn, 0.50 $270.00
Buyer's counsel, re changes to purchase and $540.00
sale agreement
02/19/19 | Inendino, James V. | Telephone conference with A. Moglia, L. 0.80 $432.00
Newman and T. Goodwyn, Buyer's Counsel, re | $540.00
purchase and sale agreement
02/19/19 | Newman, Lauren Communication to T. Goodwyn, counsel for K. 0.20 $111.00
Moran, re proposed changes to the purchase | $555.00
and sale agreement and to request a
conference call
Newman, Lauren | Communications to and from J. Gallo, Moglia 0.30] $166.50
Advisors, re list of equipment included in $555.00
asset sale
02/19/19 | Newman, Lauren Communications to and from R. Nelson, real 0.20 $111.00
estate broker, re status of contract $555.00
negotiations
02/19/19 | Newman, Lauren Telephone conference with A. Moglia, J. 0.80 $444,00
Inendino and T. Goodwyn, counsel for $555.00
purchaser, to negotiate PSA and proposed
changes to the purchase and sale agreement
02/19/19 | Newman, Lauren Telephone conference with T. Goodwyn, 0.60 $333.00
counsel for K. Moran, to negotiate changes to | $555.00
the purchase and sale agreement
Newman, Lauren Draft proposed order setting auction, bidding 1.50 $832.50
procedures and approving sale $555.00
02/20/15 | tnendino, James V. | Revise Purchase Contract (.7}; memo to L. 0.90 $486.00
Newman re same (.1}; communication to $540.00
Goodwyn, Purchaser's counsel, with draft
Agreement {.1)
02/20/19 | Newman, Lauren Telephone calf with A. Moglia, trustee, to plan 0.20 $111.00
strategy in contract negotiations with K.
Moran's counsel
02/20/19 | Newman, Lauren Detailed communication to A. Mogiia, 0.30 $166.50
trustee, and J. Gallo, Moglia Advisors, re $555.00
points in contract negotiations with K.
Moran’s counsel
| 94/24/19 | Newman, tauren | Legal research for sale motion re cases on ~-250| $882.50
break-up fees and other issues citecase | $555.00
faw.in sale motion
02/21/19 | Inendino, James | Review K. Moran's comments to purchase 0.40 $216.00
and sale agreement and lease termination $540.00
agreement {.3); memo to L, Newman re same
(.1)
02/21/19 | Newman, Lauren Telephone call with J. Gallo, Moglia Advisors, 0.70 $388.50
NE [Tere aun | chen aren reaisatn | gosto P=]
Pate | Attorney/ Description Amount
Paralegal
02/21/19 | Newman, Lauren Review and revise purchase agreement, and 0.30 $166.50
create a redlined version re additional $555.00
contract provisions for bankruptcy sale
Continue to draft motion by trustee to sell 1.50/ $832.50
assets of bankruptcy estate $555.00
02/21/19 | Newman, Lauren Communication to T, Goodwin, counsel for K. 0,20 $111.00
Moran, with revise purchase agreement, and | $555.00
along with a redlined version re additional
contract provisions
Communication to A. Moglia, trustee, with $166.50
additional proposed changes to contract and $555.00
comments on same
Telephone call with A. Moglia, trustee, re
additional contract provisions $555.00
Continue to draft and revise motion to sell $2,497.50
assets, draft order and notice of bidding $555.00
procedures
| 02/22/38 | Newman, Lauren | Legalresearch to cite case law insalemotion | 1.50] $832.50
on break-up fees, on business judgmentrule | $555.00
and other issues in support of trustee’s _
motion to sell assets, including good faith
Telephone call with A. Moglia, trustee, to plan $111.00
strategy re sale $555.00
02/25/19 | Newman, Lauren Receive and review executed purchase 0.20 $111.00
agreement from T. Goodwyn, counsel for K. $555.00
Moran, and communicate to acknowledge
same
02/25/19 | Newman, Lauren Communication to A. Moglia, trustee, to send 0.20 $111.00
draft of trustee’s motion to sell assets, set $555.00
bidding procedures, schedule an auction, and
proposed sale order for his review
Review and analyze Title Commitment and
send memo to L. Newman re title status $540.00
02/25/19 | Newman, Lauren Continue to draft and revise trustee’s motion 3.70 | $2,053.50
to sell assets, set bidding procedures, $555.00
schedule an auction, and revise proposed sale
order
02/26/15 | Inendino, James V. | Review emails regarding signed contract; 0.40 $216.00
eee penne memo to Stalking Horse Buyer counsel re ssea0)
same
02/26/19 | Newman, Lauren Communication to A. Moglia, trustee, to send 0.20 $111.00
court filad copy of sale motion and to plan for | $555.00
court hearing
Pate | Attorney/ Description Hours
Paralegal
02/26/19 | Newman, Lauren Continue to draft and proof read sale motion, 2.30 | $1,276.50
organize exhibits and prepare for filing with $555.00
court
02/27/19 | Inendino, James V. | Telephone conference with T. Goodwyn, 0.60 $324.00
purchaser's counsel, re changes to the $540.00
purchase and sale agreement (.3);
communication to T. Goodwyn confirming
changes to contract (.2)
02/27/19 | Newman, Lauren Communication to T. Goodwyn, counsel! to K. 0.20 $111.00
Moran, to advise on court hearing and delay $555.00
of sale motion and auction
02/27/19 | Newman, Lauren Communications to and from T. Goodwyn, 0.20 $111.00
as Pen counsel to K. Moran, to consider possible
timing issues on the sale
02/27/19 | Newman, Lauren Revise and prepare amended motion to sell 1.20 $666.00
assets, notice of order and bid procedures, $555.00
proposed sale order and amended notice of
motion
02/28/19 | Inendino, James V. | Conference with Near North Title re proposed 0.50 $270.00
sale (.2); telephone conference with T. $540.00
Goodwyn, purchaser's counsel regarding
earnest money deposit and strict joint order
_instructions (.3)
02/28/19 | Newman, Lauren Communication to K. Kaufman, counsel for 0.20 $111.00
Martinez Seafood, re delay in hearing of $555.00
motion to sell assets, and to explain amended sa
motion and amended notice
03/01/19 | Newman, Lauren | Communications to and from J. Inendino re $111.00
wire of deposit to title company escrow $555.00
03/01/19 | Inendino, James V. | Communications to and from title company 0.20 $108.00
and to A. Moglia, trustee, regarding earnest $540.00
money deposit
Inendino, James V. { Review contract and critical dates for closing
$540.00
03/07/19 | Inendino, James V. | Communication to and from Liz Zydel re 0.30
OS [lendnorlnery | Mauerceresteand cos mates | ssane|
03/08/19 | Inendino, James V. | Communication to and from E. Zydel and 0,30 $162.00
Buyer's counsel re: water certificate and somo)
eee
03/08/19 | Zydel, Elizabeth B. | Review communication from J, Inendino 0.70 $175.00
including the purchase and sale agreement, $250.00
title and other title documents (.3) ; prepare
full payment water certificate application (.2);
prepare communication to R, DeGraff of
MGR attaching full payment water certificate
Paralegal
and executed purchase and sale agreement
for processing {.2)
03/13/19 | Newman, Lauren Telephone call with A. Moglia, trustee to plan 0.30 $166.50
strategy and consider environmental issues at {| $555.00
property and purchaser's request for
extension of due diligence
03/13/19 | Inendino, James V. | Review and respond to communications from 0,30 $162.00
T. Goodwyn, purchaser's attorney, regarding $540.00
due diligence extension request and
environmental matters with respect to the
property
03/13/19 | Newman, Lauren Communications to A. Moglia, trustee re 0,10 $55.50
request for extension of due diligence from T. | $555.00
Goodwyn, counsel for purchaser, for a phase
lf environmental report
03/13/19 | Newman, Lauren Communications to and from T, Goodwyn, 0.20 $111.00
counsel for purchaser, re request for $555.00
extension of time on due diligence and to do
a phase ji
Communication to R. Nelson, broker, re 0.20 $111.00
request for extension from purchaser ondue j{ $555.00
diligence
Newman, Lauren {| Communication to A. Moglia, trustee, re $55.50
property inspection by personal injury $555.00
claimant and insurance defense counsel
Review buyer's request for due diligence $108,00
extension $540.00
Inendino, James V. | Memo to buyer's counsel regarding due 0.30} $162.00
diligence extension request response $540.00
03/15/19 Communication to A. Moglia, trustee, to send
request by purchaser's counsel for extension | $555.00
of due diligence
Newman, Lauren Communications to and from J. Brucer re $55.50
selling debtor’s trademark and tradename $555.00
03/18/19 | inendino, James V. | Review emails regarding due diligence
CRAPS [nein ames | arson mates for tenet contact |
Newman, Lauren | Review sale motion and prepare for upcoming
court hearing §555.00
03/19/19 | Newman, Lauren Review amendment to purchase agreement 6.20 $111.00
extending due diligence for environmental $555.00
report
Attorney/ Description Hours | Amount
Paralegal
03/19/19 | Newman, Lauren Communication to A. Moglia, trustee, 0,20 $111,00
amendment to purchase agreement $555.00
extending due diligence will push out date of
auction
Communication to A. Moglia, trustee,
transmitting first amendment to contract $540.00
Conference with L. Newman regarding first
amendment to contract $540.00
03/19/19 | Zydel, Elizabeth B. | Receive notice from Sandy at MGR advising 0.20 $50.00
that there is an open balance due in order to $250.00
certify the full payment water certificate (.1);
prepare communication to J. Inendino
advising of same and forwarding notification
{.1)
Draft and revise first amendment to contract $594.00
$540.00
Appear in court on Trustee’s motion to $777.00
approve auction sale bidding procedures $555.00
03/20/19 | Newman, Lauren Respond to communication from D. Brown, 0.10 555.50
counsel for debtor, to advise on outcome of $555.00
court hearing on sale motion
Communication to T. Goodwyn, counsel for K. 0.20
Moran, to comment on court hearing for $555.00
motion te approve sale procedures
03/20/19 | Inendino, James V. | Communication to T. Goodwyne, counsel for 0.30 $162.00
“ purchaser, transmitting first amendment to $540.00
contract
03/20/19 | Newman, Lauren Respond to communication from G. Silver, 0.20 $111.00
counsel for U.S. Trustee, to advise on $555.00
outcome of court hearing on sale motion
Correspondence to Clerk of Judge Barnes with
proposed draft of sale procedures order $555.00
03/28/19 | Newman, Lauren Revise and update proposed order 0.40 $222.00
authorizing trustee to sell assets by auction 5555.00
and allowing for sale procedures and break-
up fee
03/29/19 | Newman, Lauren Communications with bankruptcy judge’s 0.10 $55.50
clerk re resubmitting proposed sale $555.00
procedures order with no references to sale
motion
03/29/15 | Newman, Lauren Draft and revise sale procedures order to 1.20 $666.00
include all bidding terms and instructions, $555.00
along with ail conditions of participating in
auction sale
08/35/45 | Newman, tauren | Revise notice of sale procedures ‘| __0.60| $333.00]
[Pate Attorney/ Description
Paralegal
sn
Communication to L. Hiller, law clerk, with
revised proposed sale procedures order $555.00
04/01/19 | Newman, Lauren Continue to revise proposed sale procedures 0.50 $277.50
order and notice of entry of order, and $555.00
prepare for filing
Communication to A. Moglia, trustee, with 0.10 $55.50
copy of notice of sale and procedures $555.00
Communication to A. Moglia, trustee, with
entered sale procedures order $555.00
Newman, Lauren Communications to A, Moglia, trustee, re $111.00
strategy on sale and possible appeal by J. $555.00
Longo
Newman, Lauren Prepare notice of sale procedures and $222.00
certificate of filing and service $555.00
Communications to and from T. Goodwyn,
counsel for K. Moran, re bidding procedures $555.00
04/11/19 | Newman, Lauren Communications to and from K. Kaufman, 0,10 $55.50
counsel for Martinez, to prepare for $555.00
upcoming sale
04/11/19 | Newman, Lauren Telephone conference with A. Mogiia, 0.10 $55.50
US [even [ □□□ to prepare or pmoning arionante | gsss0|
Newman, Lauren | Communication to A. Moglia, trustee, to $111.00
advise on sale developments $555.00
Draft notice of publication of sale
$555.00
04/15/19 | Newman, Lauren Communications to and from J, Gallo, Moglia 0.20 $111.00
“we Advisors, re possible changes to draft of
Notice of Publication of the Sale
04/15/19 Proof read and revise Notice of Publication of $111.00
Ow8A8 the Sale $555.00
04/15/19 | Newman, Lauren Communication to A. Moglia, trustee, re 0.20 $111.00
status of sale and inclusion of potential $555.00
pn en [geeereeeemncoeenl | sin
04/15/19 | Newman, Lauren | Revise Notice of Publication of the Sale as per
directions of trustee, to include sale amounts | $555.00
pee ene | Sceearcee meen
04/15/19 | Newman, Lauren Communication to A, Moglia, trustee, with 0.20 $111.00
IE [Hern awn | □□□□□□□□□□□□□□□□□□□□□□□□□ | ssseo|
04/16/19 Communication to A. Moglia, trustee, with
oa/ashas revised notice of publication $555.00
Telephone call with potential purchaser from $111.00
ad for auction sale $555.00
$555.00
Pate | Attorney/ Description [Hours | Amount |
Paralegal
04/25/19 | Newman, Lauren Communication to A. Moglia, trustee, re 0.10 $55.50
ea nen een einen ee Tnees | | 5850,
04/25/19 | Newman, Lauren Communication to R. Nelson, rea! estate 0.20 $111.06
broker, to send copy of notice sale of auction | $555.00
sale
04/25/19 | Newman, Lauren Telephone call with R. Nelson, rea! estate $222.00
broker, re progress of sale of real estate and $555.00
bidding process
Newman, Lauren | Communications to and from C. Angelo, 0.20 $111.00
potential purchaser of equipment, re sale $555.00
04/29/19 1 Newman, Lauren Communications to C. Angelo, potential 0.10 $55.50
“oe purchaser of equipment, to advise on sale of
assets
04/29/19 | Newman, Lauren Telephone call with A. Moglia, trustee, to 0.30 $166.50
consider offer from C. Angelo, potential 5555.00
purchaser of equipment, re sale
04/30/19 | Newman, Lauren Communication to T. Goodwyn, counsel for 0.20 $111.00
purchaser re phase {| environmental report $555.00
and to advise that the trustee will not
remediate any environmental issues
04/30/19 | Newman, Lauren Analysis of phase i! environmental report 0.30 $166.50
ee Lene en ein sumeatondedianes’ | gseeaa| a)
pT Total Charges | 88.40 | $48,124.50
EXHIBIT D
Relief from Stay by J. Longo, creditor:
Attorney/ Description Hours
Paralegal
12/11/18 | Newman, Review and analyze motion to for relief from 0.30 $157.50
Lauren automatic stay filed by J. Longo, judgment $525.00
creditor, to pursue appeal of attorneys’ fee
award by district court
12/11/18 | Newman, Communications ta and from A. Mogiia, 0.20 $105.00
Lauren trustee, re motion to lift stay filed by J. $525.00
Longo, Judgment creditor, of district court's
attorneys’ fee award
12/11/18 | Newman, Communication to A. Mosglia, trustee, to 0,20 $105.00
Lauren plan strategy re to lift stay filed by J. Longo $525.00
for attorneys’ fees
12/12/18 | Moore, Dremain | Legal research cases on relief from stay by 1.50 $502.50
T. creditor to pursue appeal of a judgment $335.00
after Chapter 7 filing
12/12/18 | Moore, Dremain | Research cases cited in motion to lift stay, 1.50 $502.50
T. and analyze same $335.00
12/13/18 | Newman, Review results of legal research on judgment 0.80 $420.00
Lauren creditor's motion for relief fram automatic $525.00
stay
12/17/18 | Newman, Begin to draft response and objection to J. 1.50 $787.50
Lauren Longo’s motion for relief from stay $525.00
P Lauren law.cited by judgment creditor J. Longo’s $525.00.
‘mation for relief from stay:
12/18/18 | Newman, Draft and revise Trustee's response to J, 2.80 $630.00
Lauren Longo’s motion for relief from automatic $525.00
stay to pursue appeal of attorneys’ fee
award
12/19/18 | Newman, Communication to J. Longo, judgment 0.10 $52.50
Lauren creditor, to request conference call $525.00
12/19/18 | Newman, Detailed communication to J, Longo, 0.20 $105.00
Lauren judgment creditor, re expending assets of $525.00
estate to defend an appeal reduces amount
to creditors
12/19/18 | Newman, Telephone call A. Moglia, trustee, to plan 0.80 $420.00
Lauren Strategy re judgment creditor J. Lango’s $525.00
motion for relief from stay
Date Attorney/ Description Hours | Amount
Paralegal
12/19/18 | Newman, Telephone call with J. Longo, judgment 0.40 $210.00
Lauren creditor, to review impact of an appeal of his | $525.00
attorneys’ fees, which increases expenses to
creditors
12/19/18 | Newman, Appear in court for judgment creditor J. 1.30 $682.50
Lauren Longo’s motion for relief from stay $525.00
12/20/18 | Newman, Communication to J. Longa, judgment 0.20 $105.00
Lauren creditor, to request a meeting with the $525.00
trustee
12/27/18 | Newman, Communication to A. Mogtia, trustee, to 0.10 $52.50
Lauren advise J. Longo had not responded to $525.00
invitation to meet and confer
01/03/19 | Newman, Communications to J. Longo, judgment 0.10 $55.50
Lauren creditor, on Longo's declining a settlement $555.00
conference with trustee
01/03/19 | Newman, Communication to J. Longo, judgment 0.40 $222.00
Lauren creditor, to advise on status of sale, progress | $555.00
of liquidation of assets, and invite Longo toa
conference with Trustee
01/04/19 | Newman, Communication to A. Moglia, trustee, to 0.10 $55.50
Lauren advise that J. Longo does not wish to meet $555.00
with trustee for settlement discussion
dE Total Hours and Charges 13.70 $6,640.50
CL TOTAL Hours and Fees | 235.30 | $126,460.00
EXHIBIT E
Motion to Dismiss and Appeal:
Date Attorney/ Description Amount
Paralegal
01/07/19 | Newman, Telephone call with J. Gallo, Moglia Advisors, 0.20 $111.00
Lauren to review motion to dismiss filed by J. Longo, $555.00
judgment creditor
01/07/19 | Newman, Telephone conference with A. Moglia, trustee, 0.20 $111.00
Lauren and J. Gallo, Moglia Advisors, to analyze $555.00
motion to dismiss filed by J. Longo
01/07/19 | Newman, Review and analyze mation to dismiss 0.30 $166.50
Lauren bankruptcy case filed by J. Longo, judgment $555.00
creditor
01/07/19 | Newman, Communications to and from A. Mogiia, 0.30 $166.50
Lauren trustee, and J. Gallo, Mogiia Advisors, to $555.00
comment Gn motion to dismiss filed by J.
Longo, judgment creditor
01/08/19 | Newman, Analysis of motion to dismiss filed by J. Longo, 0.40 $222.00
Lauren Judgment creditor $555.00
01/08/19 | Newman, Communication to D. Brown, counsel for 0.20 $111.00
Lauren debtor, to request conference call on J. $555.00
Longo’s motion to dismiss
01/08/19 | Newman, Communication to J. Gallo, Moglia Advisors, to 0.10 $55.50
Lauren comment on analysis of motion to dismiss and | $555.00
progress of bankruptcy case
01/08/19 | Newman, Review and analyze memorandum from J. 0.20 $111.00
Lauren Gallo, Moglia Advisors, re analysis of motion $555.00
to dismiss and progress of bankruptcy case
01/08/19 | Newman, Telephone conference with A. Moglia, trustee, 0.40 $222.00
Lauren to review and analyze motion to dismiss and $555.00
to plan strategy
01/09/19 | O'Keefe, julie L. | Obtain, compile and organize law cited in J. 1.10 $308.00
Longo's motion to dismiss bankruptcy case, in | $555.00
preparation for response to same
01/09/19 | Newman, Telephone call with D. Brown, counsel for 0.40 $222.00
Lauren debtor, to review and analyze Longo’s motion {| $555.00
to dismiss and plan for upcoming hearing
01/09/19 | Newman, Telephone call with A. Moglia, trustee, to 0,30 $166.50
Lauren advise on telephone conference with D. $555.00
Brown, caunsel for debtor, and consider
trustee’s position on motion to dismiss
Attorney/ Description Hours Amount
Paralegal
01/09/19 | Newman, Communications to and from D. Brown, 0.20 $111.00
lauren counsel for debtor, re motion to dismiss $555.00
bankruptcy case filed by J. Longo, judgment
creditor
01/09/19 | Newman, Communication to A. Moglia, trustee, re 0.30 $166.50
Lauren motion to dismiss bankruptcy case filed by J. $555.00
Longo, judgment creditor
Lauren corporate Chapter 7 for substantial abuse: $555.00
01/11/19 | Newman, Detailed, formal written correspondence to J. 1.90 $1,054.50
Lauren Longo, judgment creditor, to advise on $555.00
trustee’s activities, sale of assets and trustee's
settlement position
01/14/19 | Newman, Revise correspondence to J, Longo, judgment 2.20! $1,221.00
Lauren creditor, to advise on activities of trustee and | $555.00
request withdrawal of motion to dismiss
01/16/19 | Newman, Communication to A. Moglia, trustee, and J. 0.20 $111.00
Lauren Gallo, Moglia Advisors, to send and comment | $555.00
on supplemental brief filed by J. Longo,
judgment creditor, to motion to dismiss
01/16/19 | Newman, Communications to and from J, Galio, Moglia 0.30 $166.50
Lauren Advisors, to analyze to motion to dismiss $555.00
01/16/19 | Newman, Review and analyze supplemental brief filed 0.40 $222.00
Lauren by J, Longo, judgment creditor, to motion to $555.00
dismiss and prepare response to same
01/22/19 | Newman, Draft response to motion to J. Longo’s dismiss 3.201 $1,776.00
Lauren bankruptcy case $555.00
01/22/19 | Newman, Communication to A. Moglia, trustee, re 0.30 $166.50
Lauren Strategy on motion to dismiss and to plan for | $555.00
upcoming hearing
01/22/19 | Newman, Communication with D. Brown, counsel for 0.20 $111.00 |
Lauren debtor, re appearing at hearing on motionto =| $555.00
dismiss
01/23/19 | Newman, Appear in court for J. Longo, judgment 1.40 $777.00
Lauren creditor, for hearing on motion for relief from | $555.00
automatic stay and motion to dismiss
bankruptcy case
01/23/19 | Newman, Prepare for court argument by reviewing filed 0.30 $166.50
Lauren pleadings $555.00
Attorney/ Description Hours Amount
Paralegal
01/24/19 | Newman, Communication to A. Moglia, trustee, to send 0.40 5222.00
Lauren copy of order and to comment on judge’s $555.00
remarks from court hearing
01/24/19 | Newman, Review order denying motion for relief from 0.10 $55.50
Lauren stay $555.00
01/29/19 | Newman, Communication to A, Mogila, trustee re 0.10 $55.50
Lauren responding to J. Longo’s email requesting $555.00
dismissal
01/29/19 | Newman, Communication to J. Longo, judgment 0,10 $55.50
Lauren creditor, to advise Trustee wil! not join in $555.00
dismissal of case
01/31/19 | Newman, Communication to A, Mogtia with J. Longo’s 0.20 $111.00
Lauren motion to stay Trustee’s work on case $555.00
01/31/19 | Newman, Communications to and from A. Moglia to 0.20 $111.00
Lauren plan for J. Longo’s motion to stay case pending | $555.00
appeal
01/31/19 | Newman, Review and analyze J. Longo’s motion for a 0.20 $111.00
Lauren stay pending appeal $555.00
| 02/01/15 | Newman, legal research for trustee’sresponseand | 480| $882.50
tauren objection toJ. Longo's motion for stay before | $555.00
motion to. dismiss is determined
02/01/19 | Newman, Communications to and from A. Moglia, 0.20 $111.00
Lauren trustee, to plan strategy re motion for stay $555.00
02/04/19 | Newman, Continue to draft and revise response and 2.50} $1,387.50
Lauren objection to J. Longo, judgment creditor, $555.00
motion for stay, and prepare for filing
02/05/19 | Newman, Communication to A. Moglia, trustee, to 0.20 $111.00
Lauren advise on notice of withdrawal of notice of $555.00
motion for a stay
02/05/19 | Newman, Review notice of withdrawal of notice of 0.20 $111.00
Lauren motion for a stay $555.00
tauren motion to dismiss and review and analyze $555.00
cases cited in motion
02/12/19 | Newman, Draft response brief to motion to dismiss by 3.00 | $1,665.00
Lauren judgment creditor Longo $555.00
02/13/19 | Newman, Continue to draft and revise trustee’s 4.50 | $2,497.50
Lauren response brief to judgment creditor Longo’s $555.00
motion to dismiss bankruptcy case, and
arrange far filing of final draft of brief
Date Attorney/ Description
Paralegal
02/13/19 | Newman, Communication to A. Moglia, trustee, with 0.20 $111.00
Lauren court filed copy of trustee’s response briefto | $555.00
judgment creditor Longo’s motion to dismiss
bankruptcy case
02/20/19 | Newman, Detailed communication to A. Moglia, trustee, 0.30 $166.50
Lauren and J. Gallo, Moglia Advisors, to send copy of | $555.00
reply brief to motion to dismiss bankruptcy
case filed by J. Longo, and to comment on
same
02/20/19 | Newman, Review and analyze reply to response to 0.30 $166.50
Lauren Longo’s motion to dismiss bankruptcy case $555.00
02/27/19 | Newman, Appear in court for hearing for motion for a 1.40 $777.00
Lauren stay and status on motion to dismiss $555.00
02/27/19 | Newman, Prepare for court hearing by reviewing motion 0.50 $277.50
Lauren for stay, trustee’s response and motion to 5555.00
dismiss pleadings
02/27/19 | Newman, Telephone calf with A. Moglia, trustee, to 0.30 $166.50
Lauren review outcome of court hearing and to plan $555.00
strategy
03/19/19 |] Newman, Review and analyze order and opinion from 0.30 $166.50
Lauren Judge Barnes denying J. Longo’s motion to $555.00
dismiss bankruptcy case
03/19/19 | Newman, Multiple communications to and from A. 0.30 $166.50
Lauren Moglia, trustee, to review and analyze Judge $555.00
Barnes denying J, Longo’s motion to dismiss
bankruptcy case
03/19/19 | Newman, Communication to A. Moglia, trustee, to send 0.20 $111.00
Lauren copy of Judge Barnes denying J. Longo’s $555.00
motion to dismiss bankruptcy case and
comment on same
03/27/19 | Newman, Communication to J. Longo to respond to 0.20 $111.00
Lauren questions about outcome of last court hearing | $555.00
04/02/19 | Newman, Communication to and from A. Moglia, 0.30 5166.50
Lauren trustee, re notice of appeal filed by creditor J. | $555.00
Longo
04/02/19 | Newman, Review notice of appeal filed by creditor 0,20 $111.00
Lauren Longo re denial of motion to dismiss case $555.00
Lauren: appeal.and required documents with notice $555.00
Attorney/ Description
Paralegal
04/03/19 | Newman, Review notice of appeal and motion for leave 0.50 $277.50
Lauren to appeal, and analyze same $555.00
04/05/19 | Newman, Communication to D. Farrell, bankruptcy 0.20 $111.00
Lauren partner, with notice of appeal and motion to $555.00
appeal, for preparing response
04/05/19 | Newman, Review and analyze motion for leave to 050] $277.50
we gg terip tang cage
Lauren appeal, and perform legal research Into $555.00
bankruptey rules on same
04/05/19 | Farrell, David D. | Analysis of denial of dismissal order Is a "final" 0.20 $124.00
order for purposes of appeal and opposing $620.00
Longo’s motion for interlocutory appeal
| 94/10/19 | Farrel, David D. "| Researchin connection with responseln | 1.50 $830.00
appeal of denial of dismissal motion (1.4);
review underlying bankruptcy court pleadings
(.4)
04/15/19 | Farrell, David D. | Draft response in opposition to judgment 2.50} $1,550.00
creditor J. Longo's motion for leave to pursue | $620.00
interlocutory appeal of denial of dismissal
motion due to lack of jurisdiction
04/16/19 | Newman, Arrange for filings in District Court to respond 0.20 $111.00
Lauren to appeal by Longo of deniai of dismissal $555.00
04/16/19 | Newman, Communication to A. Moglia, trustee, to 0.20 $111.00
Lauren advise J. Longo filed a mation for a stay $555.00
pending appeal
04/16/19 | Newman, Communication to A. Moglia, trustee, with 0.20 $111.00
Lauren copy of response and opposition to Longo’s $555.00
motion for leave to appeal order denying
motion to dismiss
04/16/19 | Newman, Communication to J. Gallo, Moglia Advisors, re 0.20 $111.00
Lauren Strategy on pending appeal $555.00
04/16/19 | Newman, Draft appearance for District Court appeal by 0.30 $166.50
Lauren judgment creditor J. Longo $555.00
04/16/19 | Newman, Review and revise response and opposition to 1.80 $999.00
Lauren Longo’s motion for leave to appeal order $555.00
denying motion to dismiss
04/16/19 | Newman, Review notice of motion for a stay pending 0.20 $111.00
Lauren appeal $555.00
Date Attorney/ Description Hours
Paralegal
04/16/19 | Farrell, David D. | Plan strategy re issues relating to response in 0.30 $186.00
apposition to J. Longo's mation for leave to $620.00
file intertocutory appeal and J. Longo's motion
for stay pending appeal
roper | 04/23/15 | Newman, Legal research cases cited by J. Longo in 0.50[ $277.50]
on Lauren. motion for a stay pending appeal. $555.00
04/26/19 | Newman, Draft response and objection to J. Longo’s 6.50 | $3,607.50
Lauren motion for a stay pending appeal $555.00
04/29/19 | Newman, Communication to A. Moglia, trustee, to send 0.20 $111.00
Lauren copy of court filed trustee’ response to $555.00
judgment creditor's motion for a stay pending
appeal
04/29/19 | Newman, Continue to draft and revise response and 2.50 | $1,387.50
lauren objection to judgment creditor's motion fora | $555.00
stay pending appeal
04/29/19 | Newman, Finalize response and objection te judgment 0.20 $111.00
Lauren creditor’s motion for a stay pending appeal $555.00
and arrange for filing with the court
| lr Total Charges { 54.10 | $30,015.50
EXHIBIT F
EXPENSES
For title search for property located at 525 E. 130th Street, Chicago, $75.00
iL 60628; VENDOR: Chicago Title Company, LLC; INVOICE#:
18010547S-1
10/03/18 For UCC and tax lien judgment search for Iilinois regarding Rosebud $492.50
Farm, Inc.; VENDOR: Cogency Global / National Corporate Research;
INVOICE#: B098595-02
12/07/28 For service of subpoena on Providence Bank & Trust; VENDOR: ATG $69.00
ROMS [tezatone, nes RWOICERSesse are ONATS [S00
po Tota Charges} $636.50 |