Download - Fee App Fifth Interim
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
1SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Leonard M. Shulman – Bar No. 126349 Melissa Davis Lowe – Bar No. 245521 SHULMAN HODGES & BASTIAN LLP 8105 Irvine Center Drive, Suite 600 Irvine, California 92618 Telephone: (949) 340-3400 Facsimile: (949) 340-3000 Email: [email protected]; [email protected] General Counsel for the Official Committee of Unsecured Creditors for the bankruptcy estate of Ezri Namvar and Special Claims Counsel to R. Todd Neilson, Chapter 11 Trustee
UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA, LOS ANGELES DIVISION
In re EZRI NAMVAR, Debtor.
Case No. 2:08-bk-32349-BR Chapter 11 FIFTH INTERIM APPLICATION FOR APPROVAL OF FEES AND REIMBURSEMENT OF EXPENSES BY SHULMAN HODGES & BASTIAN LLP, ATTORNEYS FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS; AND SECOND INTERIM APPLICATION FOR APPROVAL OF FEES AND REIMBURSEMENT OF EXPENSES OF SHULMAN HODGES & BASTIAN LLP, SPECIAL CLAIMS COUNSEL FOR R. TODD NEILSON, CHAPTER 11 TRUSTEE; DECLARATION OF LEONARD M. SHULMAN IN SUPPORT THEREOF Date: October 22, 2013 Time: 2:00 p.m. Place: Courtroom 1668 Edward R. Roybal Federal Building and Courthouse 255 E. Temple Street Los Angeles, CA 90012
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
2SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
TABLE OF CONTENTS
Page
I. INTRODUCTION ............................................................................................................... 4
II. FEE APPLICATION ........................................................................................................... 4
A. Case Background Information ................................................................................. 4
B. Employment of the Firm by the Namvar Committee .............................................. 5
C. Employment of the Firm by the Namvar Trustee .................................................... 6
D. Summary of Prior Fee Applications ........................................................................ 7
1. As Counsel for the Namvar Committee ....................................................... 7
2. As Special Claims Counsel for the Namvar Trustee ................................... 7
E. Summary of Fees and Expenses Requested Herein ................................................. 8
F. Estimated Accrued Administration Expenses .......................................................... 8
G. Funds on Hand ......................................................................................................... 8
H. Overview of Necessary and Valuable Services Rendered by the Firm as General Counsel to the Namvar Committee ............................................................ 9
I. Overview of Necessary and Valuable Services Rendered by the Firm as Special Claims Counsel to the Namvar Trustee .................................................... 10
J. Billing Records ...................................................................................................... 12
1. General Counsel to the Namvar Committee .............................................. 12
2. Special Claims Counsel to the Namvar Trustee ........................................ 13
3. Billing Record Exhibits and Firm Biography Exhibits .............................. 14
III. NARRATIVE SUMMARY OF SERVICES PERFORMED BY PROJECT CATEGORY AS COUNSEL TO THE NAMVAR COMMITTEE .................................. 16
A. Estate Analysis ....................................................................................................... 16
B. Asset Disposition ................................................................................................... 17
C. Business Matters (Errors and Omissions Insurance/Management of DIP Debtors).................................................................................................................. 19
D. Case Administration ............................................................................................... 20
E. Claims Administration/Objections......................................................................... 21
F. Fee Application ...................................................................................................... 22
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
3SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
G. Fee/Employment Objections .................................................................................. 23
H. Meetings of Creditors ............................................................................................ 23
I. Plan and Disclosure Statement............................................................................... 24
J. Employment ........................................................................................................... 28
K. Trade Creditor Avoidance Litigation ..................................................................... 29
L. Litigation – Insider Avoidance .............................................................................. 29
M. Litigation - Discharge ............................................................................................ 30
N. Settlement of Various Disputes/Litigation ............................................................. 30
IV. NARRATIVE SUMMARY OF SERVICES PERFORMED BY PROJECT CATEGORY AS SPECIAL CLAIMS COUNSEL TO THE NAMVAR TRUSTEE .......................................................................................................................... 33
A. Claims Administration/Objections......................................................................... 33
B. Employment ........................................................................................................... 36
V. CLIENT COMMENTS ON THE FEE APPLICATION ................................................... 36
VI. THE FEE APPLICATION COMPLIES WITH LOCAL BANKRUPTCY RULES ........ 36
VII. CONCLUSION .................................................................................................................. 37
DECLARATION OF LEONARD M. SHULMAN ....................................................................... 38
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
4SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
TO THE HONORABLE BARRY RUSSELL, UNITED STATES BANKRUPTCY JUDGE:
I. INTRODUCTION
Pursuant to the provisions of Bankruptcy Code Sections 330 and 331, Rule 2016 of the
Federal Rules of Bankruptcy Procedure and Local Bankruptcy Rule 2016-1, Shulman Hodges &
Bastian LLP (“Firm”) applies to this Court for an order allowing fees and costs as set forth in this
Fifth Interim Application for Approval of Fees and Reimbursement of Expenses by Shulman
Hodges & Bastian LLP, Attorneys for the Official Committee of Unsecured Creditors; and
Second Interim Application for Approval of Fees and Reimbursement of Expenses of Shulman
Hodges & Bastian LLP, Special Claims Counsel for R. Todd Neilson, Chapter 11 Trustee (“Fee
Application”); and directing the bankruptcy estate (“Estate”) of Ezri Namvar (“Debtor”) to pay
the Firm on account of such allowance.
II. FEE APPLICATION
A. Case Background Information
On December 22, 2008 (“Petition Date”), involuntary chapter 11 petitions were filed
against Namco Capital Group, Inc. (“Namco”) and the Debtor. Namco is a California
corporation of which the Debtor is the President, Chief Financial Officer, sole director and sole
shareholder.
On February 13, 2009, the Office of the United States Trustee (“OUST”) appointed the
Official Committee of Unsecured Creditors for the Debtor’s Estate (“Namvar Committee”) and
the Official Committee of Unsecured Creditors for the bankruptcy estate of In re Namco Capital
Group, Inc. (“Namco Committee”) (together, referred to as “Committees”).
Pursuant to Order entered March 11, 2009, R. Todd Neilson (“Namvar Trustee”) was
appointed as the Chapter 11 trustee for the Debtor’s Estate.
On May 8, 2009, the Court entered an order approving the appointment of Bradley D.
Sharp as the chapter 11 trustee for the Namco bankruptcy estate (“Namco Trustee” and
collectively with the Namvar Trustee, the “Chapter 11 Trustees”).
On June 19, 2009, involuntary petitions were filed against Beshmada, LLC
(“Beshmada”), Beshmada of Delaware, LLC (“Beshmada DE”) and Dimes, LLC (“Dimes”) by
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
5SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
the Namco Trustee. (Beshmda, Beshmada DE and Dimes are collectively referred to herein as
the “DIP Debtors”). Namco is the largest creditor of each of the DIP Debtors.
Pursuant to stipulations between each of the DIP Debtors and the Namco Trustee, on
July 1, 2010 (with respect to Beshmada), and July 2, 2010 (with respect to the other DIP
Debtors), Orders for Relief were entered in each of the cases of the DIP Debtors. Although each
DIP Debtor remains in possession and control of its assets as debtor in possession, the manager
of each DIP Debtor is Louis A. Cicalese, who was appointed as the successor manager of each
DIP Debtor on or about July 2, 2009 (pursuant to a stipulation among the Chapter 11 Trustee and
the Debtor), which stipulation was approved by the Court.
The Court has approved the adequacy of a Joint Disclosure Statement (discussed below)
(docket 1574). The Court has also entered a “Solicitation Procedures Order” (docket number
1573) pursuant to which the Court, among other things, set various plan confirmation related
dates. A hearing on approval of the Joint Plan is scheduled for October 10-11, 2013. By the
time of hearing on this Fee Application, it believed that the Joint Plan will have been confirmed
by the Court.
Further information regarding the status of administration of the case will be provided in
the interim application for fees and reimbursement of expenses by Danning, Gill, Diamond &
Kollitz, LLP (“DGD&K”), general counsel to the Namvar Trustee (“DGD&K Application”) and
is incorporated herein by reference pursuant to Local Bankruptcy Rule 2016-1(a)(1)(A)(iv).
B. Employment of the Firm by the Namvar Committee
Upon the application of the Namvar Committee and pursuant to an Order entered on
April 7, 2009, the Firm was authorized to be employed as the Namvar Committee’s counsel in
this case effective as of February 20, 2009 to render professionals services to the Namvar
Committee which may include, without limitation:
Advise the Namvar Committee with respect to its rights, powers, duties and
obligations as the official committee of creditors holding unsecured claims of the Debtor’s
bankruptcy case.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
6SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Prepare pleadings, applications and conduct examinations incidental to
administration of this case and to protect the interests of the unsecured creditors of this Estate.
Advise and represent the Namvar Committee in its connection with all
applications, motions or complaints filed during the course of the administration of this case.
Develop the relationship of the Namvar Committee with the Debtor in this
bankruptcy proceeding.
Advise and assist the Namvar Committee in presentation of a plan of
reorganization by the Debtor or other entity pursuant to Chapter 11 of the Bankruptcy Code and
concerning any and all matters relating thereto.
Advise and assist the Namvar Committee in providing access to information to all
unsecured creditors, soliciting and receiving comments from unsecured creditors, and to disclose
any information to unsecured creditors as required by the Court in compliance with Bankruptcy
Code section 1102.
Perform any and all other legal services incident and necessary herein for the
smooth administration of this bankruptcy case.
C. Employment of the Firm by the Namvar Trustee
Pursuant to an Order entered August 20, 2012 (docket number 1298), the Firm was
authorized to be employed as the Namvar Trustee’s special claims counsel in this case to render
professionals services to the Namvar Trustee which may include, without limitation:
Review and analysis of the proofs of claim that have been filed against the
Namvar estate and consult with the Namvar Trustee concerning the administration of the claims
filed in the bankruptcy case.
Preparation of any documents and pleadings necessary to object to claims.
Perform any and all other legal services incident and necessary herein related to
claims administration.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
7SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
D. Summary of Prior Fee Applications
1. As Counsel for the Namvar Committee
The Firm has previously applied for and been awarded and paid fees and reimbursement
of expenses for services performed on behalf of the Namvar Committee as follows:
Time Period Fees
AllowedExpenses Allowed
Totals
As Counsel for the Namvar CommitteeFebruary 20, 2009 to September 30, 2009 Fees Requested: $120,749.00 (includes discount of $5,574.50) Expenses Requested: $7,433.75 Order entered November 11, 2009
$120,749.00 $7,433.75 $128,182.75
As Counsel for the Namvar CommitteeOctober 1, 2009 to September 30, 2010 Fees Requested: $141,209.50 (less discount of $3,730.65) Expenses Requested: $10,062.87 Order entered November 23, 2010
$141,209.50 $9,357.22 $150,566.72
As Counsel for the Namvar CommitteeOctober 1, 2010 to August 31, 2011 Fees Requested: $149,128.00 Expenses Requested: $3,831.74 Order entered November 7, 2011
$149,128.00 $3,831.74 $152,959.74
As Counsel for the Namvar CommitteeSeptember 1, 2011 to September 14, 2012 Fees Requested: $185,242.50 Expenses Requested: $2,635.08 Order entered October 29, 2012
$185,242.50 $2,635.08 $187,877.58
Total Allowed Fees and Expenses $596,329.00 $23,257.79 $619,586.79Less Payments Received on Prior Awards ($399,713.51) ($20,622.71) ($420,336.22)
Balance Due on Prior Awards $196,615.49 $2,635.08 $199,250.57
2. As Special Claims Counsel for the Namvar Trustee
The Firm has previously applied for and been awarded and paid fees and reimbursement
of expenses for services performed on behalf of the Namvar Trustee as follows:
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
8SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Time Period Fees Allowed
Expenses Allowed
Totals
Special Claims Counsel for Namvar Trustee March 14, 2012 to September 14, 2012 Fees Requested: $21,529.50 Expenses Requested: $1,066.88 Order entered October 29, 2013
$21,529.50 $1,066.88 $22,596.38
Total Allowed Fees and Expenses $21,529.50 $1,066.88 $22,596.38Less Payments Received on Prior Awards ($.00) ($.00) ($.00)
Balance Due on Prior Awards $21,529.50 $1,066.88 $22,596.38
E. Summary of Fees and Expenses Requested Herein
By this Fee Application and as set forth in more detail below, the Firm is seeking an
allowance and payment of fees and reimbursement of expenses as follows:
Capacity/Time Period Fees Expenses
Fifth Interim Fee Application As Counsel for the Namvar Committee September 15, 2012 to September 25, 2013
$78,287.50 $1,221.50
Second Interim Fee Application As Special Claims Counsel for the Namvar Trustee September 15, 2012 to September 25, 2013
$96,505.50 $3,201.18
Total $174,793.00 $4,422.68
F. Estimated Accrued Administration Expenses
A discussion of the estimated accrued administrative expenses in this case will be set
forth in the DGD&K Application to be filed and heard concurrent with the Firm’s Fee
Application and is incorporated herein by this reference pursuant Local Bankruptcy Rule 2016-
1(a)(1)(A)(iv).
The work in this case has not concluded and the Firm will be seeking additional fees and
expenses in in amounts that are to be determined.
G. Funds on Hand
A discussion of the estimated amount of funds on hand and available for distribution to
professionals will be set forth in the DGD&K Application to be filed and heard concurrent with
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
9SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
the Firm’s Fee Application and is incorporated herein by this reference pursuant Local
Bankruptcy Rule 2016-1(a)(1)(A)(iv).
H. Overview of Necessary and Valuable Services Rendered by the Firm as General
Counsel to the Namvar Committee
The services rendered by the Firm were necessary and valuable and have assisted the
Namvar Committee in performing its duties under the Bankruptcy Code. On a continuing basis,
and to the exclusion of other matters, the Firm has worked to investigate assets of the Estate,
investigate claims against the Estate, explore alternative strategies regarding the resolution of
this case, and investigate and address matters including, but not limited to, motions requesting
approval of numerous sales of assets and compromises, disposition of estate assets, issues
regarding the effectiveness of the management of the five bankruptcy estates, issues regarding
disputed claims, and development of and obtaining Court approval of a disclosure statement and
a plan of reorganization.
Throughout the administration of this case, the Firm has at all times attempted to work
closely with all parties to these active related cases with the common goal of working
cooperatively toward proposing a consensual plan of reorganization. Initially, the Committees
and the Chapter 11 Trustees were not able to reach an agreement and the Committees elected to
jointly propose their own plan and disclosure statement. Thereafter, through the efforts of the
Firm on the Namvar Committee’s behalf, the Chapter 11 Trustees and the Debtors were able to
reach an agreement and a consensual Joint Plan and Joint Disclosure Statement was filed
(proposed by the Chapter 11 Trustees and the Debtors and consented to by the Namvar
Committee). This consensual Joint Plan was the result of many, many months of negotiations
and the culmination of extensive investigation concerning the financial affairs and operations of
the five related debtors and efforts to address claims by and among the five estates in real estate,
litigation recoveries and other assets involving a labyrinth of approximately 400 limited liability
companies and a complex web of ownership structures created by the Debtor. The five estates’
assets include real property and real property related assets and other non-cash assets, including
litigation rights (including litigation rights to recover property not within the confines of the
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
10SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
United States). Unfortunately, after the Joint Plan and Disclosure Statement were filed,
negotiations broke down, the Committees could no longer support the Joint Plan and Disclosure
Statement, and the Joint Disclosure Statement was never approved.
Instead, the Chapter 11 Trustees filed their own Plan and Disclosure Statement. The
Court has approved the adequacy of the Disclosure Statement (docket 1574). The Court has also
entered a “Solicitation Procedures Order” (docket number 1573) pursuant to which the Court,
among other things, set various plan confirmation related dates. A hearing on approval of the
Plan is scheduled for October 10-11, 2013. By the time of hearing on this Fee Application, it
believed that the Plan will have been confirmed by the Court.
In summary, the Firm has undertaken this case to the exclusion of other matters, has
performed valuable services that have been tailored to resolve this case and multiple disputes in
the most beneficial, efficient and cost effective manner. In connection therewith, the Firm has
been in constant communication with the Namvar Committee, the Chapter 11 Trustees, general
counsel for the Chapter 11 Trustees, counsel for the DIP Debtors, creditors of the multiple
bankruptcy estates and their counsel, and interested parties to resolve as many issues as possible
prior to filing documents and/or lodging orders with the Court. In light of the active issues in the
case and the results achieved so far, the Firm’s fees are reasonable and should be approved.
I. Overview of Necessary and Valuable Services Rendered by the Firm as Special
Claims Counsel to the Namvar Trustee
The Firm has expended time assisting the Namvar Trustee in the analysis and objections
to claims against the Debtor’s Estate. This has not been an easy task due to the number of claims
filed and the extent and nature of the Debtor’s financial affairs. 1
1 For more than twenty years, Namco solicited loans from third parties (primarily
individuals) and loaned these funds to other third parties. During the ten years that preceded the filing of the bankruptcy cases, substantially all of Namco’s loans were made to entities controlled by the Debtor and/or members of the Debtor’s family. When the Debtor’s financial network collapsed in 2008, Namco owed over $650 million to approximately 230 creditor-lenders. At the time the involuntary petition was filed, many of the assets acquired with Namco's funds were in the process of being foreclosed upon, or were in financial distress. There have been approximately 250 proofs of claim filed just in the Debtor’s bankruptcy case, many of which are based on the Debtor’s alleged personal guaranties of loans to Namco.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
11SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
In addition, objecting to late filed claims was not a routine matter as the Debtor never
filed Bankruptcy Schedules and given the large nature of the case, the Namvar Trustee was
aware that he might not know about all possible creditors of the Estate and/or have proper
contact information for creditors to serve them with notice of a deadline for filing claims. As
such, in efforts to advise creditors of the deadline for filing claims, advertisements were placed
in late October 2009 in the Los Angeles Times and in Sobh Iran to advise potential creditors of
the deadline for filing claims. This out of the ordinary process gave rise to oppositions being
filed to the Namvar Trustee’s objections to certain late filed claims, which required services by
the Firm to respond to the oppositions.
Objecting to duplicate claims was not an easy task as well. The numerous claims filed in
the case had to be scrutinized for amounts alleged to be owed by different entities but for which
the claims were identical to other filed claims, with the only difference being the name of the
disputed claimant. For example, there have been seven claims filed by different entities totaling
$70,000,000 which are based on an underlying action pending in the Los Angeles Superior
Court, Case No. LC086520 (“State Court Action”). Specifically, the claims are each based on a
Cross-Complaint filed by the claimants against the Debtor for damages, injunctive relief,
rescission, reformation and cancellation. The Cross-Complaint alleges multiple causes of action
against the Debtor, including breach of fiduciary duty, fraud, misrepresentation, and breach of
contract relating to multiple business transactions between the claimants and the Debtor in his
capacity as owner and Chairman of Security Pacific Bank. The claims made in the State Court
Action are mere conjecture and there has been no determination of liability on behalf of the
Debtor. It does not appear that the disputed claimants have obtained a judgment against the
Debtor in the State Court Action and in fact, it appears the Cross-Complaint has been dismissed.
A hearing on this Omnibus Motion objecting to the seven disputed claims is scheduled for
hearing on October 15, 2013.
Despite the difficulties in the case, the Firm has assisted the Namvar Trustee to
successfully file and prosecute several Motions objecting to numerous claims and has achieved
the following beneficial results: (1) reduce claims against Estate by over $43,000,000, (2)
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
12SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
reclassify $740,000 of alleged priority claims to non-priority general unsecured claims, (3) by
the time of hearing on this Fee Application, it is anticipated that the Firm will have assisted the
Namvar Trustee to reduce claims against the Estate by an additional $70,000,000, and (4) it is
anticipated that the Firm will file a Motion objecting to several alleged secured claims totaling
approximately $36,716,130.74 to request such disputed claims be reclassified as non-priority
general unsecured claims against the Estate.
In summary, the services rendered by the Firm have assisted the Namvar Trustee in
performing his fiduciary duties to the Estate and its creditors under the Bankruptcy Code. The
Firm has been successful in assisting the Namvar Trustee to substantially reduce claims against
the Estate (by over $43,000,000 to date), thereby greatly benefiting the Estate and its unsecured
creditors. In light of the issues addressed and results achieved, the Firm’s fees herein are
reasonable and should be approved.
J. Billing Records
The Firm’s time records are billed in tenth of an hour increments and are kept on a
computer system. As set forth below, the Firm has classified it services into separate project
categories. The Firm has placed each service performed in the applicable project category that it
best relates. However, because certain services may relate to one or more project categories,
some similar tasks may have been placed different project categories.
In the normal course of business, the Firm maintains records of the expenses incurred on
behalf of its clients. The Firm charges twenty cents per page for photocopies and charges for
postage when there are multiple envelopes mailed at one time. Records for messenger services
are kept as they are incurred and input on the computer system. Messenger services are only
used when it is crucial that document delivery be made immediately or by the next day. The
Firm charges fifty cents per page for facsimile transmissions and keeps a daily log of the same
which is input on the computer system.
1. General Counsel to the Namvar Committee
The computer records show that the Firm has expended 200.30 hours in providing
services as general counsel to the Namvar Committee during the period from
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13SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
September 15, 2012 through September 25, 2013, for total fees of $78,287.50, at a blended
hourly rate of $390.85.
The billing records indicate that the Firm has incurred expenses on behalf of the Namvar
Committee totaling $1,221.50 as follows:
Expense Total Attorney/Messenger Service $16.00 Federal Express $106.46 PACER charges $511.08 Photocopy $395.80 Parking Expense for Court Appearances $40Postage $133.36 Computer Research $18.80 Total $1,221.50
2. Special Claims Counsel to the Namvar Trustee
The computer records show that the Firm has expended 342.20 hours in providing
services as special claims counsel to the Namvar Trustee during the period from September 15,
2012 through September 25, 2013, for total fees of $96,505.50, at a blended hourly rate of
$282.01.
The billing records indicate that the Firm has incurred expenses on behalf of the Namvar
Trustee totaling $3,201.18 as follows:
Expense Total PACER charges $216.48 Attorney and Messenger Service $72Photocopy $2,466.60 Postage $283.71 Federal Express $8.32 Parking Expense for Court Appearances $8.00 Computer Research $146.07 Total $3,201.18
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
14SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
3. Billing Record Exhibits and Firm Biography Exhibits
In compliance with LBR 2016-1, attached hereto as Exhibit 1, 2 and 3 to the Declaration
of Leonard M. Shulman (“Shulman Declaration”) are the Firm’s time and billing statements and
biographical information as follows:
Exhibit 1: Time and expense records as counsel for the Namvar Committee for the
period of September 25, 2012 through September 25, 2013. Four attorneys and two paralegals
have performed services in connection with this case at their usual hourly rates as shown on
Exhibit 1. The summary of fees by task and the summary of fees by month for each
professional are set forth on Exhibit 1 at pages 37 through 44. The hourly rates in effect, the
total hours and the total fees by each professional is as follows:
Professional Name HourlyRate
Time Period in the Fee Application
Total Hours
Total Fees
Leonard M. Shulman Attorney
$525 Entire Reporting Period 90.90 $47,722.50
Ronald S. Hodges Attorney
$525 Entire Reporting Period .80 $420
Melissa Davis Lowe Attorney
$325 Through 12/31/2012 15.70 $5,102.50
Melissa Davis Lowe Attorney
$375 Effective 1/1/2013 37.90 $14,212.50
Rika M. Kido Attorney
$300 Effective 1/1/2013 1.00 $300
Erlanna Lohayza Paralegal
$195 Entire Reporting Period 33.20 $6,474
Lorre Clapp Paralegal
$195 Entire Reporting Period 20.80 $4,056
Totals 200.30 $78,287.50
The detail of expenses incurred by the Firm on behalf of the Namvar Committee is shown on
Exhibit 1 at pages 30 through 36. The summary of expenses by each category and the summary
of expenses by month are included on Exhibit 1 at pages 45 through 47.
Exhibit 2: Time and expense records as counsel for the Namvar Trustee for the
period of September 15, 2012 through September 25, 2013. Four attorneys and three paralegals
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
15SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
have performed services in connection with the services for the Namvar Trustee at their usual
hourly rates as shown on Exhibit 2. The summary of fees by task and the summary of fees by
month for each professional are set forth on Exhibit 2 at pages 56 through 61. The hourly rates
in effect, the total hours and the total fees by each professional is as follows:
Professional Name Hourly
RateTime Period in the Fee Application
Total Hours
Total Fees
Leonard M. Shulman Attorney
$525 Entire Reporting Period 19.60 $10,290
Melissa Davis Lowe Attorney
$325 Through 12/31/2012 10.60 $3,445
Melissa Davis Lowe Attorney
$375 Effective 1/31/2013 23.80 $8,925
Rika M. Kido Attorney
$250 Through 12/31/2012 13.30 $3,325
Rika M. Kido Attorney
$300 Effective 1/31/2013 145.60 $43,680
Michelle ChoiAttorney
$195 Through 12/31/2012 3.40 $663
Michelle ChoiAttorney
$225 Effective 1/31/2013 63.50 $14,287.50
Erlanna Lohayza Paralegal
$195 Entire Reporting Period 48.50 $9,457.50
Steven Swartzell Paralegal
$175 Entire Reporting Period 5.70 $997.50
Ann Marie Vernon Paralegal
$175 Entire Reporting Period 8.20 $1,435
Totals 342.20 $96,505.50
The detail of expenses incurred by the Firm on behalf of the Namvar Trustee is shown on
Exhibit 2 at pages 50 through 55. The summary of expenses by each category and the summary
of expenses by month are included on Exhibit 2 at pages 62 through 65.
Exhibit 3: A brief biography of each professional of the Firm who has expended
time on this case.
The Firm is a professional law firm comprised of attorneys duly licensed to practice in
the State of California and various United States District Courts, including the Central District of
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
16SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
California. The Firm specializes in bankruptcy reorganization and insolvency law. All services
for which compensation are sought were rendered by the Firm. No agreement has been made by
any member of the Firm or by any employee thereof, directly or indirectly, and no understanding
exists for a division of fees prayed for herein with any other person. The Firm has not entered
into any agreement, written or oral, express or implied, with any other party or party in interest in
the above-entitled case for the purpose of fixing the amount of any fees or compensation to be
paid from the assets of the Debtor’s estate.
III. NARRATIVE SUMMARY OF SERVICES PERFORMED BY PROJECT
CATEGORY AS COUNSEL TO THE NAMVAR COMMITTEE
A. Estate Analysis
A summary of the hours and fees incurred by the Firm throughout the administration of
this case in connection with the project category of Estate Analysis is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
15.60 $6,100.00 $ 391.03
Second Fee Application Fees previously requested
32.60 $12,038.50 $ 369.28
Third Fee Application Fees previously requested
15.30 $6,056.50 $ 395.85
Fourth Fee Application Fees previously requested
3.20 $1,247.50 $ 389.84
Fifth Fee Application Fees not previously requested
.00 $.00 Not Applicable
Totals 66.70 $25,442.50 $ 381.45
Throughout the administration of this case, the Firm has provided services to the Namvar
Committee related to the determination of the value of assets in the Estate, potential recoveries
from other sources and the investigation of potential avoidance actions. In these efforts, the Firm
has reviewed documents and has provided analysis of various issues for the Namvar
Committee’s benefit. The Firm has worked closely with all parties to this active case and their
counsel to discuss asset issues and strategy with respect to joint ownership situations between the
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
17SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
estates. During this current period, the Firm has not incurred additional fees in this project
category.
B. Asset Disposition
A summary of the hours and fees incurred by the Firm in the category of Asset
Disposition is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
8.00 $2,360.00 $ 295.00
Second Fee Application Fees previously requested
111.30 $36,867.50 $ 331.24
Third Fee Application Fees previously requested
13.00 $5,731.50 $ 440.88
Fourth Fee Application Fees previously requested
108.90 $46,687.00 $ 428.71
Fifth Fee Application Fees not previously requested Exhibit 1, pages 2 through 5
32.10 $15,617.50 $ 486.53
Total 273.3 $107,263.50 $ 392.48
During the period of time encompassed by this Fee Application, the Firm has reviewed
and evaluated numerous pleadings and documents related to the disposition of assets and has
provided recommendations to the Namvar Committee. In connection with the category of Asset
Disposition, the Firm has provided services to the Estate which have included, but have not been
limited to the following:
Review and analyze the Motion for Order Authorizing (A) Disputed Secured
Claim Reserves to be Held in Non-Interest Bearing Accounts; and (B) Trustee to Hold Parox
Member Reserves for Parox LLC; Memorandum of Points and Authorities and the Declarations
of (1) Mandana Yedidsion, (2) Nicholas R. Troszak and (3) R. Todd Neilson in Support.
Analysis of issues regarding possible interest bearing accounts to be used for the
disputed secured claims reserved.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
18SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Review and analysis of the Order Authorizing (A) Disputed Secured Claim
Reserves to be Held in Ezri Trustee and Beshmada in Non-Interest Bearing Accounts; and (B)
Erri Trustee to Hold Reserves of Parox LLC for its Members.
Review and analyze the Motion of Beshmada, LLC for Order Establishing
Procedures for the sale of Tenant in Common Interest in Property (116.47 Acres of “Pappas
Ranch”); Memorandum of Points and Authorities and the Declaration of Louis A. Cicalese in
Support (“Pistachio Farms Sale Motion”). Numerous communications with the Namvar
Committee, counsel for Beshmada and others interested parties regarding the Pistachio Farms
Sale Motion and bidding procedures to be utilized.
Review and analysis of an appraisal of the Pappas Ranch property and
communications with the Namvar Committee regarding same.
Communications with potential overbidders on the Pappas Ranch property and
provide summary of bidding procedures for the Pappas Ranch property for review by possible
overbidder.
Multiple communications with the Namvar Committee members and other
interested parties regarding possible objections to the Pappas Ranch sale.
Review and analyze order approving bidding procedures and setting sale hearing
on sale of Pappas Ranch and communications with the Namvar Committee regarding same.
Review and analyze issues regarding the Stipulation of the Building TICS and
Neilson: (1) In Lieu of Neilson Having the Sole Authority to Seek Recovery of the FIRPTA
Fund From the Taxing Authorities as Established in the Prior Order Entered on July 15, 2011,
the Individual Taxpayers Who Have the Ultimate Beneficial Interests in the Building TICS Will
Have Authority in Accordance with Thos Percentages Established by the Prior Order Entered on
September 20, 2011 and (2) for Determination of the Dispute Regarding Whether Recovered
FIRPTA Funds Should be Paid to the Building TICS According to Their Respective Interests
Therein (“FIRPTA Funds Stipulation”).
Communications with the Namvar Committee regarding the FIRPTA Funds
Stipulation.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
19SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Review and analysis of the Responding Brief of Wilshire Bundy Holdings, LLC
and Wilbun 7, LLC Concerning Turnover Dispute Regarding Recovery and Allocation of
FIRPTA Funds.
Review and analysis of the Namvar Trustee’s Responding Brief in Connection
with Hearing on the FIRPTA Funds Stipulation.
Meeting with potential buyers to study assets available for sale. Multiple
communications with the Namvar Trustee’s counsel re issues related to the marketing and sale of
assets. Review and analyze a report of real estate assets. Communications with interested
parties re proposed sales of remaining assets.
In summary, all of the Firm’s services in connection with this project category were
aimed toward assisting the Namvar Committee in its fiduciary duties to the unsecured creditors
of the Estate.
C. Business Matters (Errors and Omissions Insurance/Management of DIP Debtors)
A summary of the hours and fees incurred by the Firm related to the Business Matters
(Errors and Omissions Insurance Policy and Management of the DIP Debtors) is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
9.20 $2,354.50 $ 255.92
Second Fee Application Fees previously requested
7.80 $1,773.00 $ 227.31
Third Fee Application Fees previously requested
.80 $240.00 $ 300.00
Fourth Fee Application Fees previously requested
1.10 $457.50 $ 415.91
Fifth Fee Application Fees not previously requested Exhibit 1, page 6
1.20 $495 $ 412.50
Total 20.10 $5,320 $ 264.68
A small amount of time was incurred by the Firm related to insurance issues such as
renewing the errors and omissions policy for the Namvar Committee, and discussions of such
issues with the Namvar Committee and others. In addition, the Firm expended time on matters
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
20SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
addressing issues regarding the extended contract for Louis A. Cicalese as the manager of each
of the DIP Debtors.
D. Case Administration
A summary of the hours and fees incurred by the Firm in the category of Case
Administration is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
51.40 $14,641.50 $ 284.85
Second Fee Application Fees previously requested
51.90 $12,382.00 $ 238.57
Third Fee Application Fees previously requested
19.20 $6,092.00 $ 317.29
Fourth Fee Application Fees previously requested
10.70 $3,619.00 $ 338.22
Fifth Fee Application Fees not previously requested Exhibit 1, pages 7 through 11
18.30 $6,892.50 $ 376.64
Total 151.50 $43,627 $ 287.97
Throughout the administration of this case, the Firm has responded to concerns of and
conferred with creditors and other interested parties, including the Namvar Committee members
and attorneys and agents of creditors, addressing concerns about the status of the case and
general informational inquiries. At all times, the Firm has strived to keep the Namvar
Committee well informed both through written correspondence and telephonic conferences as to
the status of the case. In connection with the category of Case Administration, the Firm has
provided services to the Namvar Committee which have included, but have not been limited to
the following:
On an ongoing basis, the Firm has advised the Namvar Committee regarding its
statutory duties to the Estate and unsecured creditors.
Numerous and ongoing communications with creditors to provide information
regarding the status of the case.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
21SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Prepare and maintain a list of creditors and interested parties for service of notices
pursuant to Federal Rule of Bankruptcy Procedure 2002.
Respond to creditor inquiries regarding procedures to change address information
with the Court.
Prepare weekly updates to and maintain a website for creditors to access
regarding the status of the Namvar Case.
Review and analyze status reports provided by the Chapter 11 Trustees.
Review and analyze monthly operating reports.
Discussions with Namvar Committee and other parties regarding miscellaneous
case matters that have arisen during the administration of this case.
In summary, all of the Firm’s services related to Case Administration were aimed toward
the smooth administration of the Namvar case and were necessary in order for the Firm to assist
the Namvar Committee to comply with the Bankruptcy Code, the Federal Rules of Bankruptcy
Procedure and the Local Bankruptcy Rules regarding the administration of the Estate and were
necessary to assist the Namvar Committee in the fulfillment of its fiduciary duties to the Estate
and creditors.
E. Claims Administration/Objections
A summary of the hours and fees incurred by the Firm in the category of Claims
Administration/Objections is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
13.00 $3,788.00 $ 291.38
Second Fee Application Fees previously requested
29.80 $6,765.00 $ 227.01
Third Fee Application Fees previously requested
5.40 $1,674.50 $ 310.09
Fourth Fee Application Fees previously requested
3.80 $1,626.50 $ 428.03
Fifth Fee Application Fees not previously requested
.00 $.00 Not Applicable
Total 52 $13,854.00 $ 266.42
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
22SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
During this current reporting period, the Firm has not performed any services on behalf
of the Namvar Committee related to Claims Administration/Objections. Services related to
Claims Administration/Objections during this current period were performed on behalf of the
Namvar Trustee behalf and are discussed below,
F. Fee Application
A summary of the hours and fees incurred by the Firm in the category of Fee Application
is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
3.50 $710 $ 202.86
Second Fee Application Fees previously requested
25.00 $5,341 $ 213.64
Third Fee Application Fees previously requested
38.40 $8,598 $ 223.91
Fourth Fee Application Fees previously requested
27.40 $7,422.50 $ 270.89
Fifth Fee Application Fees not previously requested Exhibit 1, pages 12 through 15
47.60 $10,489 $ 220.36
Total 141.90 $32,560.50 $ 229.46
During this reporting period, the Firm expended time completing the Firm’s prior Fee
Application and commenced work on this current Fee Application. In preparing the Fee
Applications in this case, the Firm was required to expend time complying with the Local
Bankruptcy Rule 2016-1. The Firm prepared for and attended a hearing on the prior Fee
Application.
All of the fees incurred in connection with this category were necessary and were
incurred in compliance with the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure,
and the Local Bankruptcy Rules. In light of the requirements, the Firm believes the fees
requested are very reasonable.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
23SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
G. Fee/Employment Objections
A summary of the hours and fees incurred by the Firm in the category of
Fee/Employment Objections is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
6.10 $2,155.00 $ 353.28
Second Fee Application Fees previously requested
17.00 $3,950.50 $ 232.38
Third Fee Application Fees previously requested
8.70 $2,870.50 $ 329.94
Fourth Fee Application Fees previously requested
.80 $156.00 $ 195.00
Fifth Fee Application Fees not previously requested Exhibit 1, page 16
3.30 $1,407.50 $ 426.52
Total 35.90 $10,539.50 $ 293.58
The Firm has expended time in the review and analysis of the request for fees filed by
other professionals employed by the Estate and communicated with the Namvar Committee
regarding same. The Firm also prepared a Notice of Reservation of Rights to Object Fee
Applications of Professionals.
All of the services rendered by the Firm in connection with the Employment and Fee
Application Objections have been aimed toward assisting the Namvar Committee in its fiduciary
duty to the Estate and its unsecured creditors.
H. Meetings of Creditors
A summary of the hours and fees incurred by the Firm in the category of Meetings of
Creditors is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
80.90 $29,652.50 $ 366.53
Second Fee Application Fees previously requested
118.00 $36,262.00 $ 307.31
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
24SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Hours Fees Blended Hourly Rate Third Fee Application Fees previously requested
36.90 $16,847.00 $ 456.56
Fourth Fee Application Fees previously requested
17.60 $8,780.00 $ 498.86
Fifth Fee Application Fees not previously requested Exhibit 1, pages 17 through 18
13.30 $6,682.50 $ 502.44
Total 266.70 $98,224 $ 368.29
During the time period encompassed by this Fee Application, the Firm has met with the
Namvar Trustee and the Namvar Committee (at times on a weekly basis) about the status of the
case and the course of action to be taken with regard to various motions that have been filed in
the Debtor’s case as well as the Namco case. As needed between meetings, the Firm participates
in conference calls with members of the Namvar Committee and others to discuss issues that
arose throughout the case and issues that require immediate attention. The Firm has also
prepared minutes of all meetings conducted, and circulated the minutes to the Namvar Trustee
and the Namvar Committee for review and comment.
In summary, all of the services rendered by the Firm in connection with the Meetings of
Creditors were aimed toward assisting the Namvar Committee in understanding these cases and
in resolving this case as quickly as possible and in the most efficient and cost effective manner.
Throughout this case, the Firm has assisted the Namvar Committee to exist as a strong force in
the Debtor’s bankruptcy case and the administration thereof. All of the Firm’s valuable services
were necessary in order to assist the Namvar Committee in its fiduciary duty to the unsecured
creditors of the Estate.
I. Plan and Disclosure Statement
A summary of the hours and fees incurred by the Firm in the category of Plan and
Disclosure Statement is as follows:
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
25SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
2.10 $817.50 $ 389.29
Second Fee Application Fees previously requested
21.60 $7,563.50 $ 350.16
Third Fee Application Fees previously requested
226.20 $94,785.00 $ 419.03
Fourth Fee Application Fees previously requested
234.10 $105,555.00 $ 450.90
Fifth Fee Application Fees not previously requested Exhibit 1, pages 19 through 24
61.50 $25,803.50 $ 419.57
Total 545.50 $234,524.50 $ 429.93
Throughout the administration of this case, the Firm has at all times attempted to work
closely with all parties to these active related cases with the common goal of working
cooperatively toward proposing a consensual plan of reorganization. Initially, the Committees
and the Chapter 11 Trustees, were not able to reach an agreement and the Committees elected to
jointly propose their own plan and disclosure statement. Thereafter, through the efforts of the
Firm on the Committee’s behalf, the Chapter 11 Trustees and the five related Debtors were able
to reach an agreement and a consensual Joint Plan and Joint Disclosure Statement was filed
(proposed by the Chapter 11 Trustees and the Debtors and consented to by the Committees).
This consensual Joint Plan was the result of many, many months of negotiations and the
culmination of extensive investigation concerning the financial affairs and operations of the five
related debtors and efforts to address claims by and among the five estates in real estate,
litigation recoveries and other assets involving a labyrinth of approximately 400 limited liability
companies and a complex web of ownership structures created by the Debtor.
Unfortunately, after the Joint Plan and Disclosure Statement were filed, negotiations
broke down, the Committees could no longer support the Joint Plan and Disclosure Statement,
and the Joint Disclosure Statement was never approved.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
26SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Instead, the Chapter 11 Trustees along with the DIP Debtors proposed their own Plan and
Disclosure Statement. The Court has approved the adequacy of the Disclosure Statement (docket
1574). The Court has also entered a “Solicitation Procedures Order” (docket number 1573)
pursuant to which the Court, among other things, set various plan confirmation related dates. A
hearing on approval of the Plan is scheduled for October 10-11, 2013. By the time of hearing on
this Fee Application, it believed that the Plan will have been confirmed by the Court.
In connection with the category of Plan and Disclosure Statement, the Firm has provided
services to the Estate which have included, but have not been limited to the following:
Numerous communications via telephone and written correspondence with the
Namvar Committee and the Chapter 11 Trustees regarding plan strategies and alternatives.
Analysis of issues regarding the disclosure statement approval hearings and
continuance of the hearings; analysis of stipulations and pleadings to reschedule the hearings.
Review and analysis of issues regarding competing reorganization plans.
Review and analysis of issues and communications with the Namvar Committee
regarding plan funding issues.
Review and analysis of status reports on plan confirmation proceedings.
Review and analysis of Objection of U.S. Bank to the disclosure statement.
Review and analysis of the Chapter 11 Trustees’ Amended Chapter 11 Plan and
all changes to the Amended Chapter 11 Plan.
Prepare an executive summary of the Chapter 11 Trustee’s Amended Chapter 11
Plan; communications with the Namvar Committee regarding same; work on possible objections
to the amended plan; prepare for and meet with the Namvar Committee on plan issues.
Review and analysis of Joint Motion of Trustees and DIP Debtors for Order
Approving Solicitation and Voting Procedures With Respect to First Amended Joint Chapter 11
Plan for Namco Capital Group, Inc., Ezri Namvar, Beshmada, LLC, Beshmada of Delaware,
LLC and Dimes, LLC Proposed by the Chapter 11 Trustees and DIP Debtors and
communications with the Namvar Committee regarding same.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
27SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Communications with counsel for the Chapter 11 Trustees regarding potential
changes to plan voting procedures.
Review and analysis of objections to the Chapter 11 Trustee’s Amended Plan
filed by Mousa Namvar and communications with the Namvar Committee and counsel for the
Chapter 11 Trustees regarding same.
Communications with counsel for the Chapter 11 Trustees regarding the Namvar
Committee’s position on the Amended Chapter 11 Plan as revised.
Review of the Order approving the Chapter 11 Trustees’ Disclosure Statement.
Review and analysis of (A) Notice of (I) Approval of Disclosure Statement; (II)
Hearing to Consider Confirmation of Second Amended Joint Chapter 11 Plan for Namco Capital
Group, Inc., Ezri Namvar, Beshmada, LLC, Beshmada of Delaware, LLC and Dimes, LLC
Proposed by the Chapter 11 Trustees and DIP Debtors; (Ill) Summary of Plan Treatment; and
(IV) Deadline and Procedures for Filing Objections to Confirmation of Plan; (B) Second
Amended Disclosure Statement with Respect to Second Amended Joint Chapter 11 Liquidating
Plan for Namco Capital Group, Inc., Ezri Namvar, Beshmada, LLC, Beshmada of Delaware,
LLC and Dimes, LLC, Proposed by the Chapter 11 Trustees and DIP Debtors; (C) Second
Amended Joint Chapter 11 Liquidating Plan for Namco Capital Group, LLC, Ezri Namvar,
Beshmada, LLC, Beshmada of Delaware, LLC and Dimes, LLC, Proposed by the Chapter 11
Trustees and DIP Debtors; (D) Order Approving Solicitation and Voting Procedures with
Respect to Second Amended Joint Chapter 11 Plan for Namco Capital Group, Inc., Ezri Namvar,
Beshmada, LLC, Beshmada of Delaware, LLC, Proposed by the Chapter 11 Trustees and DIP
Debtors.
Prepare letter to be sent to creditors regarding the Chapter 11 Trustees’ Amended
Chapter 11 Plan in connection with plan solicitation packages.
Respond to numerous creditor inquiries regarding plan solicitation and voting
issues.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
28SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Review and analysis of Notice of Filing and Service of Plan Supplement: (1) List
of Debtor-Related Interests; (2) Assumption List; (3) Rejection List; and (4) Forms of
Liquidating Trust Agreements.
Review and analysis of Memorandum of Points and Authorities Submitted by
Trustees and DIP Debtors in Support of Confirmation of the Second Amended Joint Chapter 11
Liquidating Plan For Namco Capital Group, Inc., Ezri Namvar, Beshmada, LLC, Beshmada Of
Delaware, LLC, and Dimes, LLC, Proposed By The Chapter 11 Trustees and DIP Debtors and
the Declaration of R. Todd Neilson in support.
All of the Firm’s services in the category of Plan and Disclosure Statement have been
aimed toward assisting the Namvar Committee in its fiduciary duty to general unsecured
creditors to resolve this case in the most efficient manner that will provide for the beneficial
treatment of all parties. The Firm has attempted at all times to keep fees to a minimum. Given
the nature of the case and the significant amount of creditor inquires regarding the terms of the
proposed plan, the Firm believes that the fees incurred in this project category are reasonable.
J. Employment
A summary of the hours and fees incurred by the Firm in the category of Employment is
as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
16.20 $4,279.00 $ 264.14
Second Fee Application Fees previously requested
23.20 $5,656.50 $ 243.81
Third Fee Application Fees previously requested
9.50 $2,875.00 $ 302.63
Fourth Fee Application Fees previously requested
4.30 $1,261.50 $ 293.37
Fifth Fee Application Fees not previously requested
.00 $.00 Not Applicable
Total 53.20 $14,072 $ 264.51
During this current reporting period, the Firm has not incurred any fees related to
Employment Applications.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
29SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
K. Trade Creditor Avoidance Litigation
A summary of the hours and fees incurred by the Firm in the category of Trade Creditor
Avoidance Litigation is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
4.70 $1,205.50 $ 256.49
Second Fee Application Fees previously requested
0.00 $0.00 Not Applicable
Third Fee Application Fees previously requested
5.30 $2,297.50 $ 433.49
Fourth Fee Application Fees previously requested
10.10 $4,332.50 $ 428.96
Fifth Fee Application Fees not previously requested Exhibit 1, page 25
.10 $32.50 $ 325.00
Total 20.20 $7,868 $ 389.50
The Firm has incurred a small amount of fees in this project category related to the
monitoring of avoidance litigation that has been filed by the Namvar Trustee and communicating
with the Namvar Committee and other interested parties regarding same.
L. Litigation – Insider Avoidance
A summary of the hours and fees incurred by the Firm in the category of Litigation –
Insider Avoidance is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
.00 $.00 Not Applicable
Second Fee Application Fees previously requested
.00 $.00 Not Applicable
Third Fee Application Fees previously requested
.00 $.00 Not Applicable
Fourth Fee Application Fees previously requested
5.10 $2,477.50 $ 485.78
Fifth Fee Application Fees not previously requested Exhibit 1, page 26
.40 $210 $ 525.00
Total 5.50 $2,687.50 $ 488.64
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
30SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
The Firm has incurred a small amount of fees related to the monitoring of litigation that
has been filed against insiders of the Estate and communicating with the Namvar Committee and
other interested parties regarding same.
M. Litigation - Discharge
A summary of the hours and fees incurred by the Firm in the category of Litigation –
Discharge is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
3.60 $1,305.00 $ 362.50
Second Fee Application Fees previously requested
1.00 $347.50 $ 347.50
Third Fee Application Fees previously requested
1.70 $687.50 $ 404.41
Fourth Fee Application Fees previously requested
3.90 $1,620.00 $ 415.38
Fifth Fee Application Fees not previously requested
.00 $.00 Not Applicable
Total 10.20 $3,960 $ 388.24
The Firm has incurred a nominal amount of fees on matters related to the objection to
discharge filed by the Namvar Trustee and has communicated with the Namvar Committee and
other interested parties regarding same.
N. Settlement of Various Disputes/Litigation
A summary of the hours and fees incurred by the Firm in the category of Settlement of
Various Disputes/Litigation is as follows:2
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
.00 $.00 Not Applicable
Second Fee Application Fees previously requested
.00 $.00 Not Applicable
2 In the Firm’s prior Fee Applications, services related to settlements of disputes and
litigation had been included in the category of Asset Disposition but have been separately categorized herein.
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
31SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Third Fee Application Fees previously requested
.00 $.00 Not Applicable
Fourth Fee Application Fees previously requested
.00 $.00 Not Applicable
Fifth Fee Application Fees not previously requested Exhibit 1, pages 27 through 29
22.50 $10,657.50 $ 473.67
Total 22.50 $10,657.50 $ 473.67
In connection with the category of Settlement of Various Disputes/Litigation, the Firm
has provided services to the Estate which have included, but have not been limited to the
following:
Review and analysis of Motion of Chapter 11 Trustee for Order Approving
Settlement Agreement between the Trustee and TN Management LLC; TN Management, Inc.;
Light Source Management, LLC; and Homayoun (Tony) Namvar; Memorandum of Points and
Authorities; Declaration of R. Todd Neilson the Request for Judicial Notice in support thereof.
Review and analysis of the Order Approving Settlement Agreement between the
Trustee and TN Management LLC; TN Management, Inc.; Light Source Management, LLC; and
Homayoun (Tony) Namvar; communications with the Namvar Committee regarding same.
Review and analysis of issues regarding the Motion of Chapter 11 Trustee for
Approval of Compromise Between the Namvar Trustee, Namco Trustee and Wells Fargo Bank,
N.A. and communications with the Namvar Committee regarding same.
Review and analysis of the Motion of Chapter 11 Trustee for Order Approving
Settlement Agreement Between the Namvar Trustee, Namco Trustee, PNC Bank, National
Association, Successor by Merger to Midland Loan Services, Inc., Eloy R, LLC, as Successor In
Interest to Interests Originally Held by Hartford Life Insurance Company and Assigned to
Hartford Life, Inc., and Hartford Life Insurance Company; Memorandum of Points and
Authorities; Declaration of R. Todd Neilson and the Request for Judicial Notice in support
thereof; communications with the Namvar Committee regarding same.
Analysis of issues regarding the Motion of Chapter 11 Trustee for Order
Approving Settlement Agreement Between the Namvar Trustee, Namco Trustee, Town &
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32SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Country Bank, and Burbank, LLC and communications with the Namvar Committee regarding
same.
Review and analysis of the Motion Pursuant to Federal Rule of Bankruptcy
Procedure 9019 for Approval of Compromise with Princeton Holdings, LLC; and Declaration Of
R. Todd Neilson; communications with the Namvar Committee regarding same.
Review and analysis of the Motion Pursuant to Federal Rule of Bankruptcy
Procedure 9019 for Approval of Compromise with Starpoint Properties, LLC; Blackhawk
Properties, LLC; Mill Avenue Properties, LLC; Mill Avenue Properties, II, LLC; Mill Avenue
Properties III, LLC; Mill Avenue Properties IV, LLC; 450 Roxbury Properties, LLC; 450
Roxbury Properties II, LLC; 450 Roxbury Properties III, LLC; 450 Roxbury Properties IV, LLC;
450 Roxbury Properties V, LLC; 450 Roxbury Properties VI, LLC; Colfax Properties, LLC;
Foothill Ridge Properties, LLC; Jennifer Greenhut; and Virgil Avenue Properties, LLC; And
Declaration Of R. Todd Neilson; communications with the Namvar Committee regarding same.
Review and analysis of the Motion of Chapter 11 Trustee for Order Approving
Settlement Between the Trustee and Defendant Woodman Partners, LLC; Declaration of R. Todd
Neilson; and the Request for Judicial Notice in support; communications with the Namvar
Committee regarding same.
Review and analysis of Motion of Chapter 11 Trustee for Order Approving
Settlement Between the Trustee and Defendant the Paul and Judith Laska Family Trust;
Declaration of R. Todd Neilson and Request For Judicial Notice in support; communications
with the Namvar Committee regarding same.
Review and analysis of the Motion of Chapter 11 Trustee for Order Approving
Settlement Between the Trustee and Defendant Mobil 601 Plaza, LLC; Declaration of R. Todd
Neilson and Request for Judicial Notice in support; communications with the Namvar
Committee regarding same.
Review and analysis of the Joint Motion of Bradley D. Sharp, Chapter 11 Trustee
for Namco Capital Group, Inc., R. Todd Neilson, Chapter 11 Trustee For Ezri Namvar,
Beshmada, LLC, Beshmada Of Delaware, LLC And Dimes, LLC, Each a Debtor and Debtor in
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
33SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Possession, for an Order Approving and Authorizing the Execution of and Performance Under
the Settlement Agreement Between the Estates of Namco Capital Group, Inc., Ezri Namvar,
Beshmada, LLC, Beshmada of Delaware, LLC, Dimes, LLC, and the Kohan Parties;
Memorandum o Points and Authorities; and Declarations of Bradley D. Sharp, R. Todd Neilson
and Louis A. Cicalese in support; communications with the Namvar Committee regarding same.
All of the services rendered by the Firm in this project category were aimed toward
assisting the Namvar Committee in understanding these settlements and compromises and to
resolve disputes as quickly as possible and in the most efficient and cost effective manner. All of
the Firm’s valuable services were necessary in order to assist the Namvar Committee in its
fiduciary duty to the unsecured creditors of the Estate.
IV. NARRATIVE SUMMARY OF SERVICES PERFORMED BY PROJECT
CATEGORY AS SPECIAL CLAIMS COUNSEL TO THE NAMVAR TRUSTEE
A. Claims Administration/Objections
A summary of the hours and fees incurred by the Firm as special claims counsel to the
Namvar Trustee in the category of Claims Administration/Objections is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
63.50 $19,409.00 $ 305.65
Second Fee Application Fees not previously requested Exhibit 2, pages 2 through 49
342.20 $96,505.50 $ 282.01
Total 405.70 $115,914.50 $ 285.71
The other professionals employed by the Namvar Trustee in this case include LECG,
LLC as his accountants and consultants and DGD&K as his general counsel. LECG, LLC has
been involved in the analysis of claims filed in the case and the DGD&K has analyzed proofs of
claim filed by financial institutions. Where appropriate, the Namvar Trustee has asked DGD&K
to prepare objections to the financial institution claims. While the Firm has worked closely with
the Namvar Trustee and his professionals in identifying objectionable claims and bringing
multiple claims objections Motions, none of the services performed by Firm in this case have
duplicated the services performed by other professional in the case.
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34SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
In connection with the category of Claims Administration/Objections, the Firm has
provided services to the Estate which have included, but have not been limited to the following:
The Firm prepared a Motion objecting to four claims totaling approximately
$822,520 that had failed to provide evidence to support the alleged amounts owed. In addition to
reviewing and analyzing the disputed claims, prior to filing the Motion, the Firm communicated
with the claimants to request that they provide documentation to support the alleged amounts
owed. The Firm prepared the Declaration and a Request for Judicial Notice in support of the
Motion and prepared four separate Notices of Objection to Claim. The Firm also appeared at the
hearing on the Motion which was granted pursuant to Court order entered on July 15, 2013
(docket number 1563).
The Firm prepared a Motion objecting to eight duplicate claims totaling
approximately $11,755,046.98. The Firm reviewed and analyzed the disputed claims, prepared
the Declaration in support of the Motion and prepared eight separate Notices of Objection to
Claim. The Firm also appeared at the hearing on the Motion, which was granted pursuant to
Court order entered on October 18, 2012 (docket number 1348).
The Firm prepared a Motion objecting to twelve late filed claims totaling
approximately $22,698,641.02. In addition to reviewing and analyzing the disputed claims, the
Firm prepared the Declaration and a Request for Judicial Notice in support of the Motion as well
as twelve separate Notices of Objection to Claim. The Firm reviewed and analyzed the
oppositions filed to this Motion and prepared the Namvar Trustee’s reply to the oppositions. The
Firm also appeared at the hearing on the Motion which was granted in part pursuant to Court
order entered on October 18, 2012 (docket number 1349) whereby claims were disallowed as
late filed in the total amount of approximately $16,886,105.80.
The Firm prepared a Motion objecting to two alleged priority claims. In addition
to reviewing and analyzing the disputed claims, the Firm prepared the Declaration in support of
the Motion and two Notices of Objection to Claims. The Firm also appeared at the hearing on
this Motion which was granted pursuant to Court order entered on May 7, 2013 (docket number
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35SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
1477), whereby alleged priority claims totaling approximately $740,000 were reclassified as
non-priority general unsecured claims.
The Firm prepared six Motions objecting to at least twenty-four claims filed
against the Debtor based on obligations owed by entities affiliated with the Debtor but which
disputed claims provided no documentation to support a claim against the Debtor individually.
The Firm prepared each of the Declarations and the Requests for Judicial Notices in support of
the Motions and twenty-four Notices of Objection to Claim. The Firm appeared at the Court
hearings on these Motions which were granted pursuant to Court orders entered on May 17, 2013
(docket numbers 1482, 1483); and July 29, 2013 (docket numbers 1617, 1618, 1621, 1622). The
granting of these Motions has reduced claims against the Estate by approximately
$13,901,599.40.
The Firm has prepared a Motion objecting to seven claims totaling approximately
$70,000,000, which are duplicate of one another except for the name of the claimants and which
are contingent and unliquidated claims against the Debtor for which no liability has been
determined. The Firm has prepared a Declaration in support of this Motion, a Request for
Judicial Notice and seven Notices of Objection to Claim. A hearing on this Motion is scheduled
for hearing on October 15, 2013.
The Firm is currently preparing a Motion to object to several alleged secured
claims totaling approximately $36,716,130.74 to request such alleged secured claims be
reclassified as non-priority general unsecured claims. Each of the alleged secured claims has not
provided evidence that the amounts alleged to be owed are secured by property of the Debtor’s
Estate. It is anticipated that Motion will be filed in the next thirty days.
In summary, the services rendered by the Firm have been aimed toward providing a
meaningful recovery for the Estate’s unsecured creditors. The Firm has assisted the Namvar
Trustee to (1) reduce claims against Estate by over $43,000,000, (2) reclassify $740,000 of
alleged priority claims to non-priority general unsecured claims, (3) by the time of hearing on
this Fee Application, it is anticipated that the Firm will have assisted the Namvar Trustee to
reduce claims against the Estate by an additional $70,000,000, and (4) it is anticipated that a
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
36SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
Motion will be filed objecting to several alleged secured claims totaling approximately
$36,716,130.74 to request such disputed claims be reclassified as non-priority general unsecured
claims. The fees incurred by the Firm are reasonable and the services rendered were necessary
to assist the Namvar Trustee in his fiduciary duties to the Estate and its creditors. Moreover, the
amount of time billed to this category of services was not excessive given the nature of the case
and the beneficial results achieved.
B. Employment
A summary of the hours and fees incurred by the Firm as special claims counsel to the
Namvar Trustee in the category of Employment is as follows:
Hours Fees Blended Hourly Rate First Fee Application Fees previously requested
9.70 $2,120.50 $ 218.61
Second Fee Application Fees not previously requested
.00 $.00 Not Applicable
Total 9.70 $2,120.50 $ 218.61
During this current reporting period, the Firm has not incurred any fees on behalf of the
Namvar Trustee related to Employment Applications.
V. CLIENT COMMENTS ON THE FEE APPLICATION
The Firm has provided a copy of this Fee Application to the Namvar Committee and the
Namvar Trustee requesting their comments to the fees and expenses being sought. Upon receipt
of the comments, the Firm will provide the United States Trustee with a copy and file the
comments with the Court.
VI. THE FEE APPLICATION COMPLIES WITH LOCAL BANKRUPTCY RULES
The Firm has reviewed the requirements of LBR 2016-1 regarding compensation of
professionals and the Fee Application complies with LBR 2016-1.
////
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
37SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
VII. CONCLUSION
WHEREFORE, based on the time spent on this matter, the difficulty and complexity of
the issues involved, the frequent need for devoting substantial amounts of time on short notice to
the exclusion of other matters, the skill required, and the fact that the Firm’s fees are well in line
with comparable law firms, the Firm requests that this Court approve the fees and reimbursement
of expenses as follows:
Capacity/Time Period Fees Expenses
Fifth Interim Fee Application As Counsel for the Namvar Committee September 15, 2012 to September 25, 2013
$78,287.50 $1,221.50
Second Interim Fee Application As Special Claims Counsel for the Namvar Trustee September 15, 2012 to September 25, 2013
$96,505.50 $3,201.18
Total $174,793.00 $4,422.68
The Firm further requests that this Court order these amounts be paid from Estate and for such
other and further relief as the Court may deem just and proper.
Dated: September 26, 2013 SHULMAN HODGES & BASTIAN LLP
/s/ Leonard M. Shulman ___________________________________________ Leonard M. Shulman Melissa Davis Lowe Attorneys for Official Committee of Unsecured Creditors for the Estate of Ezri Namvar and Special Claims Counsel to R. Todd Neilson, Chapter 11 trustee
DECLARATION
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
38SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
DECLARATION OF LEONARD M. SHULMAN
I, Leonard M. Shulman, declare as follows:
1. I am the managing partner of Shulman Hodges & Bastian LLP (“Firm”), attorneys
for the Official Committee of Unsecured Creditors for the bankruptcy estate of Ezri Namvar
(“Namvar Committee”) and also special claims counsel to R. Todd Neilson (“Trustee”), the
Chapter 11 trustee of the bankruptcy estate of Ezri Namvar. I am a member of the California
State Bar, and am thus entitled to practice before all Courts in the State of California, including
the United States Bankruptcy Court for the Central District of California. I make this declaration
in support of the Fifth Interim Application for Approval of Fees and Reimbursement of Expenses
by Shulman Hodges & Bastian LLP, Attorneys for the Official Committee of Unsecured
Creditors and Second Interim Application for Approval of Fees and Reimbursement of Expenses
of Shulman Hodges & Bastian LLP, Special Claims Counsel for R. Todd Neilson, Chapter 11
Trustee (“Fee Application”). All capitalized terms not otherwise defined herein shall have the
meaning set forth in the Fee Application.
2. I have read the Fee Application and I am familiar with the requirements of Local
Bankruptcy Rule (“LBR”) 2016-1 regarding compensation of professionals. The Fee
Application complies with the requirements of the Court, the Local Bankruptcy Rules, including
LBR 2016-1, and the requirements of the Office of the United States Trustee. The Fee
Application accurately sets forth the terms of the employment of the Firm and the services
rendered by the Firm in this case.
3. The Firm has classified into categories all services performed which
compensation is sought for the period from September 15, 2012 through September 25, 2013.
The Firm attempted to place each service performed in the category that best relates to such
service. However, because certain services may relate to one or more categories, services
pertaining to one category may in fact be included in another category.
4. In compliance with the requirements, attached hereto as Exhibits 1, 2 and 3 are
the Firm’s time and billing statements and biographical information as follows:
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Fee App Fifth Interim - Namvar.doc 3985-000\EXP. 26
39SHULMAN HODGES & BASTIAN LLP
8105 Irvine Center Drive Suite 600
Irvine, CA 92618
a. Exhibit 1: Time and expense records as attorneys for the Namvar Committee
for the period of September 15, 2012 through September 25, 2013.
b. Exhibit 2: Time and expense records as attorneys for the Trustee for the
period of September 15, 2012 through September 25, 2103.
c. Exhibit 3: A brief biography of each professional of the Firm who has
expended time on this case.
5. No agreement has been made by any member of the Firm or by any employee
thereof, directly or indirectly, and no understanding exists for a division or sharing of the fees
requested by the firm as set forth in the Fee Application, with any other person. The Firm has
not entered into any agreement, written or oral, express or implied, with any other party or party
in interest in the above-entitled case for the purpose of fixing the amount of any fees or
compensation to be paid from the assets of Debtor’s bankruptcy estate.
6. The Firm has provided a copy of the Fee Application to the Namvar Committee
and the Namvar Trustee and has requested comments to the fees and expenses being sought.
Upon receipt of the comments, the Firm will provide the United States Trustee with a copy and
file the comments with the Court.
I declare under penalty of perjury under the laws of the United States of America that the
facts set forth in the Fee Application are true and correct.
Executed at Irvine, California on September 26, 2013.
/s/ Leonard M. Shulman Leonard M. Shulman
EXHIBIT 1
Billing Records as General Counsel to the Namvar Committee
September 26, 2013
Marc Asheghian3430 Alana DriveSherman Oaks, CA 91403
ID: 3985-000 - LMSRe: In re Ezri Namvar/ 11 Creditor Committee
Invoice 70323
For Services Rendered Through September 25, 2013
Current Fees 78,287.50Current Costs 1,221.50
Fee RecapRate/Hour AmountHours
Lorre E. Clapp 4,056.0020.80 195.00ParalegalErlanna L. Lohayza 6,474.0033.20 195.00ParalegalLeonard M. Shulman 47,722.5090.90 525.00PartnerRonald S. Hodges 420.000.80 525.00PartnerRika M. Kido 300.001.00 300.00Associate AttorneyMelissa R. Davis 5,102.5015.70 325.00Associate AttorneyMelissa R. Davis 14,212.5037.90 375.00Associate Attorney
8105 Irvine Center Drive Suite 600 Irvine, California 92618 Telephone : 949/340-3400
Exhibit 1, Page 1
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 2
Fees Grouped by TaskDate Description AmountAtty Hours
**Asset Disposition**
Review and analyze trustee's motion to hold proceeds from Parox sale; send e-mail to committee re same.
10/20/12 130.00MRD 0.40
Initial review of pleadings re Parox sales proceeds; prepare comments.10/22/12 262.50LMS 0.50Email to and from B. Efraim re possible interest bearing accounts to use by trustees.
10/22/12 32.50MRD 0.10
Communications with Beshmada counsel re intent to file two sales motions; prepare comments.
11/06/12 210.00LMS 0.40
Review and analyze motion in Beshmada case to approve bidding procedures for sale of Pistachio Farm.
11/06/12 65.00MRD 0.20
Review and analyze motion to approve sale of Pistachio Farms.11/08/12 65.00MRD 0.20Further review and discussions with interested parties re Pappas Ranch sale.
11/12/12 315.00LMS 0.60
Review and analyze correspondence from D. Meadows re proposed settlement of Beshmada with Tranmar; emails with committee re same.
11/13/12 97.50MRD 0.30
Call with Chair and prepare instructions re Pistachio Farm sale.11/13/12 157.50LMS 0.30Initial review of Pappas Ranch appraisal; prepare comments for Committee.
11/13/12 315.00LMS 0.60
Multiple communications with Committee members re proposed sale of Pistachio Farm.
11/15/12 315.00LMS 0.60
Telephone conference with D. Meadows re proposed sale of Pistachio Farms.
11/15/12 65.00MRD 0.20
Multiple communications with creditors' committee re possible sale of Pistachio Farms.
11/15/12 65.00MRD 0.20
Continued discussions with clients re Pappas Ranch bid procedures.11/16/12 210.00LMS 0.40Multiple communications with noteholders re Beshmada's proposed sale of Pistachio Farms.
11/18/12 32.50MRD 0.10
Further communications with committee re Pappas Ranch sale. 11/18/12 315.00LMS 0.60Communications with clients and prepare instructions re proposed opposition to Pappas Ranch sale.
11/19/12 315.00LMS 0.60
Review and analyze communications from multiple parties re proposed sale of pistachio farms.
11/19/12 97.50MRD 0.30
Discuss overbid issues with interested parties re Pappas settlement and sale.
11/20/12 210.00LMS 0.40
Multiple communications re Beshmada's proposed sales of properties.11/21/12 32.50MRD 0.10Communications with committee members re bidding procedures to purchase Pistachio Farms.
11/21/12 65.00MRD 0.20
Review and analyze issues re Sullivan property sale; prepare instructions. 11/21/12 315.00LMS 0.60
Exhibit 1, Page 2
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 3
Date Description AmountAtty HoursCommunications with potential overbidders on Pappas Ranch.11/26/12 210.00LMS 0.40Review and analyze correspondence from D. Meadows re further information on proposed sale of Pistachio Farm.
11/26/12 32.50MRD 0.10
Telephone conference with M. Asheghian re status of sale of Pistachio Farms and when overbids will be accepted.
11/26/12 32.50MRD 0.10
Calls with potential overbidder on Pappas Ranch; prepare comments and instructions.
11/27/12 420.00LMS 0.80
Provide summary of bidding procedures for Pappas Ranch for review by possible overbidder.
11/27/12 162.50MRD 0.50
Multiple communications with Committee members re interposing obj to Pappas Ranch sale.
11/28/12 367.50LMS 0.70
Communications with D. Meadows and committee members re upcoming proposed sale of Pappas Ranch.
11/29/12 65.00MRD 0.20
Continued discussions with interested parties and clients re sale of Pappas Ranch.
11/29/12 315.00LMS 0.60
Communications with committee members re possible objection to sale of Pappas Ranch.
11/29/12 65.00MRD 0.20
Communications with Namco committee counsel re developing objection to Pappas Ranch sale.
11/30/12 315.00LMS 0.60
Work with Namco Committee counsel on objection to Sullivan Canyon sale.
12/04/12 262.50LMS 0.50
Multiple communications with clients and Namco committee members re various sales and settlements and proposed action; prepare instructions.
12/04/12 367.50LMS 0.70
Review and analyze multiple communications with committee members re possible objections to sale of Pistachio Farms and sale and compromise of Sullivan Canyon.
12/04/12 65.00MRD 0.20
Review and analyze multiple communications re opposing settlement and sale of Sullivan Canyon and request to continue committees.
12/05/12 32.50MRD 0.10
Continued discussions with interested parties re developing objection to Sullivan Ranch sale.
12/05/12 210.00LMS 0.40
Multiple communications re possible response by committees to sale motions in Beshmada case.
12/06/12 32.50MRD 0.10
Communications with clients and co counsel re developing objections to proposed sale/settlement actions.
12/07/12 735.00LMS 1.40
Review and analyze multiple communications re committee's opposition to sale motions in Beshmada case.
12/07/12 97.50MRD 0.30
Initial review of settlement with T. Mousa and related entities; prepare instructions for handling.
12/07/12 210.00LMS 0.40
Review draft declaration for committee members to oppose sale and settlement of Sullivan Canyon.
12/10/12 32.50MRD 0.10
Review and revise declaration of Chair in opposition to sale of Ranch.12/10/12 367.50LMS 0.70Prepare declaration of M. Asheghian in opposition to settlement and sale 12/10/12 65.00MRD 0.20
Exhibit 1, Page 3
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 4
Date Description AmountAtty Hoursof Sullivan Canyon.Review and analyze order approving bidding procedures and setting sale hearing on sale of Pappas Ranch; send e-mail to committee re same.
12/11/12 65.00MRD 0.20
Communications with Committee members re interposing objection to Pappas Ranch sale.
12/11/12 210.00LMS 0.40
Communications with M. Asheghian re opposition to sale and settlement of Sullivan Canyon.
12/12/12 32.50MRD 0.10
Discussions with Chair re responses to pending sales; prepare instructions.12/12/12 210.00LMS 0.40Review and analyze multiple correspondence regarding motion to approve sale of Pappas Ranch.
12/18/12 32.50MRD 0.10
Call with Chair re status of proposed sales; proposed interim distribution.12/19/12 262.50LMS 0.50Multiple communications re response of committees to possible opposition to motion to sell Pappas Ranch.
12/21/12 32.50MRD 0.10
Further extensive communications with Chair re pending sales and proposed interim distributions.
12/26/12 262.50LMS 0.50
Numerous communications with Committee members re preparation for hearing on sales.
01/12/13 367.50LMS 0.70
Review and analyze reply of Beshmada to motion for sale of Pappas Ranch interest.
01/15/13 37.50MRD 0.10
Review and analyze reply briefs filed by Trustees to declarations opposing two proposed sales; prepare comments.
01/16/13 262.50LMS 0.50
Continued discussions with interested parties re settlements with PNC and related parties.
02/08/13 315.00LMS 0.60
Continued communication with interested parties re proposed settlements with PNC and Town & Country.
02/11/13 315.00LMS 0.60
Communications with Chair re possible interim distributions.02/11/13 157.50LMS 0.30Meet with Chair re asset disposition and management issues.02/12/13 525.00LMS 1.00Review and analyze stipulation of trustees re payment to Wilshire Bundy TICs.
03/29/13 37.50MRD 0.10
Review and analyze stipulation re release and allocation of FRPTA funds; prepare comments and instructions.
04/02/13 315.00LMS 0.60
Meeting with potential buyers to study Realco assets available for sale. 05/10/13 735.00LMS 1.40Multiple communications with Trustee counsel re marketing and sale of asset issues.
06/05/13 210.00LMS 0.40
Review and analyze report of real estate assets.06/18/13 37.50MRD 0.10Briefly review pleadings filed re carving up FIRPTA; prepare comments.06/19/13 315.00LMS 0.60Review and analyze briefs re resolution of issues re previous stipulation re FIRPTA funds; send correspondence to committee re same.
06/19/13 262.50MRD 0.70
Lengthy call with interested parties re assets for sale; prepare comments for Chair.
06/19/13 577.50LMS 1.10
Review and revise memo to clients re WB proceed distribution fight.06/20/13 157.50LMS 0.30
Exhibit 1, Page 4
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 5
Date Description AmountAtty HoursWorked on asset acquisition issues with interested parties; communicate with LC.
07/01/13 315.00LMS 0.60
Briefly review additional pleadings re briefing concerning split of funds re WB; prepare comments.
07/02/13 315.00LMS 0.60
Review and analyze brief of T. Neilson re treatment of FIRPTA funds; send e-mail to committee re same.
07/03/13 150.00MRD 0.40
Review and analyze reply of Wilbun 7 and Wilshire Holdings re FIRPTA stipulation.
07/08/13 37.50MRD 0.10
Initial review of Canyon Springs settlement; prepare comments. 08/08/13 315.00LMS 0.60Review and analyze trustee additional briefs re WB funds and their disposition; discuss with Chair.
08/13/13 315.00LMS 0.60
E-mail to and from U. Raanan re hearing on FIRPTA funds.08/14/13 37.50MRD 0.10Communications with interested parties re proposed sales of remaining assets.
08/14/13 210.00LMS 0.40
Review and analyze correspondence from J. Hunter re order on FIRPTA funds and stipulation.
08/15/13 37.50MRD 0.10
Subtotal 32.10 15,617.50
Exhibit 1, Page 5
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 6
Date Description AmountAtty Hours**Business Operations**
Initial review of pleadings extending contract of Cicalese; prepare comments.
02/06/13 157.50LMS 0.30
Multiple correspondence with committee re extension of contract of L. Cicalese.
02/07/13 37.50MRD 0.10
Telephone conference with D. Poitras re contract of L. Cicalese; send correspondence to committee re same.
02/11/13 112.50MRD 0.30
Review and analyze issues re insurance for committee.06/07/13 37.50MRD 0.10Review and analyze correspondence re renewal of insurance policy.06/21/13 37.50MRD 0.10Prepare insurance renewal application and correspondence re same.06/24/13 75.00MRD 0.20Email to and from Frenkel re renewal of insurance policy.06/27/13 37.50MRD 0.10
Subtotal 1.20 495.00
Exhibit 1, Page 6
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 7
Date Description AmountAtty Hours**Case Administration**
Review and analyze monthly operating report for August.09/19/12 65.00MRD 0.20Prepare weekly updates to unsecured creditors website.09/20/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.09/27/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.10/04/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.10/11/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.10/18/12 32.50MRD 0.10Review mail (Order Granting Motion and Disallowing Duplicate Claims) addressed to Ernesto and Socorro Vasquez c/o Ralph W. and Orlyn Ann Crawford (Chatsworth PO Box address) and returned as undeliverable; update master mailing matrix for Rule 2002 notices re same.
10/22/12 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.10/25/12 32.50MRD 0.10Review and analyze monthly operating report for debtor for September 2012.
10/31/12 65.00MRD 0.20
Communicating by and among Committee members re disbandment of Committee.
11/01/12 315.00LMS 0.60
Prepare weekly updates to unsecured creditors website.11/01/12 32.50MRD 0.10Review email correspondence from A. Tehan at David White & Associates re updated address information for the Crawfords and Vasquez'; review mailing matrix and prepare memorandum to M. Lowe re creditors of Namco.
11/08/12 39.00ELL 0.20
Prepare weekly updates to unsecured creditors website.11/12/12 32.50MRD 0.10Review email from A. Tehan at D. White's office re Notice of Change of Address filed on behalf of the Crawfords and the Vasquez' and lack of service; research case docket for the Debtor's case to determine if a request for special notice was filed; confirm that address information is correct on master mailing matrix for Rule 2002 notices; prepare memorandum to M. Lowe re suggested course of action.
11/12/12 97.50ELL 0.50
Communications with Chair re developing status report for creditors.11/13/12 210.00LMS 0.40Review and provide revisions to letter to United States Trustee responding to request to disband committee; discuss same with S. Koenig.
11/16/12 195.00MRD 0.60
Prepare weekly updates to unsecured creditors website.11/21/12 32.50MRD 0.10Review and analyze multiple communications re response letter to finalize to send to United States Trustee.
11/21/12 32.50MRD 0.10
Review and analyze multiple communications re finalizing response letter to United States Trustee.
11/27/12 32.50MRD 0.10
Review correspondence from C. Ketter re request to add creditor Anthony Mirzaie to creditor listing; research to determine whether he is a creditor of the Namco estate; update master mailing matrix for F.R.B.P. 2002 notices re same.
12/04/12 39.00ELL 0.20
Prepare weekly updates to unsecured creditors website.12/06/12 32.50MRD 0.10
Exhibit 1, Page 7
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 8
Date Description AmountAtty HoursReview and analyze debtor's monthly operating report for November 2012; send correspondence to committee members re same.
12/12/12 65.00MRD 0.20
Prepare weekly updates to unsecured creditors website.12/13/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.12/20/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.12/27/12 32.50MRD 0.10Review and analyze trustees' correspondence re possible disbanding of committees.
01/02/13 37.50MRD 0.10
Prepare weekly updates to unsecured creditors website.01/03/13 37.50MRD 0.10Review and analyze monthly operating report for November 2012; send e-mail to committee re same.
01/09/13 75.00MRD 0.20
Prepare weekly updates to unsecured creditors website.01/10/13 37.50MRD 0.10Briefly review recently filed MORs; prepare comments.01/10/13 315.00LMS 0.60Prepare weekly updates to unsecured creditors website.01/17/13 37.50MRD 0.10Analysis of issues related to whether or not the Debtor filed Schedules and Statement of Financial Affairs.
01/17/13 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.01/24/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.01/31/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.02/07/13 37.50MRD 0.10Review and analyze debtor's monthly operating report for December 2012.
02/07/13 75.00MRD 0.20
Review Substitution of Attorney filed by M. Tavakoli, new attorney for Shaw Blackstone, LLC and update master mailing matrix for Rule 2002 notices re same.
02/13/13 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.02/14/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.02/21/13 37.50MRD 0.10Review mail (letter addressed to Mr. Tavakoli re Claim No. 100 filed by Shaw Blackstone, LLC) and returned as undeliverable; update master mailing matrix for F.R.B.P. 2002 notices.
02/22/13 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.02/28/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.03/07/13 37.50MRD 0.10Review and analyze debtor's monthly operating report for January 2013.03/08/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.03/14/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.03/21/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.03/29/13 37.50MRD 0.10Email to and from B. Mahjoubi re status of case and distributions to creditors.
03/29/13 37.50MRD 0.10
Review and analyze monthly operating report for February 2013.04/02/13 75.00MRD 0.20Initial review of Feb MORs; prepare comments.04/02/13 157.50LMS 0.30Prepare weekly updates to unsecured creditors website.04/04/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.04/11/13 37.50MRD 0.10
Exhibit 1, Page 8
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 9
Date Description AmountAtty HoursPrepare weekly updates to unsecured creditors website.04/18/13 37.50MRD 0.10Review and analyze monthly operating report for March 2013. 04/25/13 37.50MRD 0.10Briefly review March MORs; prepare comments.04/26/13 157.50LMS 0.30Prepare weekly updates to unsecured creditors website.05/02/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website. 05/10/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.05/16/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.05/24/13 37.50MRD 0.10Review and analyze monthly operating report for April 2013.05/29/13 37.50MRD 0.10Briefly review April monthly operating reports; prepare comments. 05/29/13 210.00LMS 0.40Prepare weekly updates to unsecured creditors website.05/30/13 75.00MRD 0.20Review Wells Fargo Bank, N.A.'s Amended Request for Special Notice and update the master mailing matrix for Rule 2002 notices re same.
06/03/13 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.06/06/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.06/13/13 37.50MRD 0.10Review and analyze debtor's monthly operating report. 06/14/13 37.50MRD 0.10Briefly review May's monthly operating report. 06/14/13 210.00LMS 0.40Review mail (Notices of Withdrawal of Claims) addressed to E. Namvar and returned as undeliverable; update master mailing matrix for F.R.B.P. 2002 notices re same and prepare Notices for forwarding to new address.
06/18/13 39.00ELL 0.20
Prepare weekly updates to unsecured creditors website.06/20/13 37.50MRD 0.10Communications with Committee members re status of litigation and fees expended.
06/21/13 210.00LMS 0.40
Prepare weekly updates to unsecured creditors website.06/27/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.07/03/13 75.00MRD 0.20Prepare weekly updates to unsecured creditors website.07/11/13 75.00MRD 0.20Prepare weekly updates to unsecured creditors website.07/18/13 37.50MRD 0.10Prepare weekly updates to unsecured creditors website.07/25/13 37.50MRD 0.10Communications with Committee members re update on status. 07/30/13 157.50LMS 0.30Review and analyze debtor's monthly operating report and send to committee for review.
07/31/13 75.00MRD 0.20
Briefly review June monthly operating report; discuss with clients. 07/31/13 157.50LMS 0.30Prepare weekly updates to unsecured creditors website.08/01/13 75.00MRD 0.20Prepare weekly updates to unsecured creditors website.08/08/13 75.00MRD 0.20Communications with clients re professional fee reviews.08/12/13 315.00LMS 0.60Continued communications with interested parties re fee review matters. 08/13/13 315.00LMS 0.60Prepare weekly updates to unsecured creditors website.08/15/13 37.50MRD 0.10Review mail (Plan Summary) addressed to B. Kianmahd and M. Namvar and returned as undeliverable; update master mailing matrix for F.R.B.P. 2002 notices re same; prepare mail for forwarding to M. Namvar at new
08/15/13 39.00ELL 0.20
Exhibit 1, Page 9
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 10
Date Description AmountAtty Hoursaddress.Review mail (Plan Summary) addressed to D. Pourbaba and S. Khadavi and returned as undeliverable; brief review of case information to verify if any new address; update master mailing matrix for F.R.B.P. 2002 notices re same.
08/16/13 39.00ELL 0.20
Review and analysis of issues related to service of plan packages on creditors, specifically Paul and Judith Laska; review mailing matrix and Proof of Service of Plan packages; advise L. Verstegen re same.
08/16/13 58.50ELL 0.30
Review mail (Plan Summary) addressed to M. Jalil, JHB Inc. and JHB Inc. International, SC Development, LLC, BankFirst and PES Family Trust and returned as undeliverable; brief review of case information to verify if any new address; update master mailing matrix for F.R.B.P. 2002 notices re same.
08/19/13 78.00ELL 0.40
Review mail (Plan Summary) addressed to D. Selki and returned as undeliverable; brief review of case information to verify if any new address; review State Bar website re new address; update master mailing matrix for F.R.B.P. 2002 notices re same.
08/19/13 39.00ELL 0.20
Review mail (Plan Summary) addressed to Daimler Trust Successor to DCFS Trust and returned as undeliverable; brief review of case information to verify if any new address; update master mailing matrix for F.R.B.P. 2002 notices re same.
08/20/13 19.50ELL 0.10
Review mail (Plan Summary) addressed to Sunnylane Partners LLC c/o Louis Esbin, Esq. and returned as undeliverable; brief review of case information to verify if any new address; review State Bar website re new address; update master mailing matrix for F.R.B.P. 2002 notices re same and prepare for forwarding to new address.
08/20/13 39.00ELL 0.20
Prepare weekly updates to unsecured creditors website.08/22/13 37.50MRD 0.10Briefly review additional pleadings re Canyon Spring settlement; prepare instructions.
08/22/13 210.00LMS 0.40
Review and analyze debtor's July monthly operating report. 08/27/13 37.50MRD 0.10Review Notice of Change of Address for Saeed Anavim, Sharona Anavim and Said Anavim; update master mailing matrix for Rule 2002 notices re same.
08/27/13 19.50ELL 0.10
Briefly review July month operating reports; prepare comments. 08/28/13 157.50LMS 0.30Review mail (Plan solicitation letter) addressed to D. Zarabi, Cushman & Wakefield of Washington, D.C., Eloy R. LLC, P. and J. Laska and Shaw Blackstone LLC and returned as undeliverable; research new address for Shaw Blackstone LLC and prepare for forwarding; update master mailing matrix for F.R.B.P. 2002 notices re same.
08/28/13 78.00ELL 0.40
Prepare weekly updates to unsecured creditors website.08/29/13 37.50MRD 0.10Review Notice of Change of Address for Paul and Judith Laska; updated master mailing matrix for Rule 2002 notices re same.
09/06/13 19.50ELL 0.10
Review mail (Plan solicitation letter) addressed to Bunherst LLC (c/o B. 09/09/13 19.50ELL 0.10
Exhibit 1, Page 10
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 11
Date Description AmountAtty HoursDavidoff) and returned as undeliverable; research new address for B. Davidoff and update master mailing matrix for F.R.B.P. 2002 notices re same.Prepare weekly updates to unsecured creditors website.09/12/13 37.50MRD 0.10Review mail (Plan solicitation letter) addressed to Boyle Avenue LLC and returned as undeliverable; update master mailing matrix for F.R.B.P. 2002 notices re same.
09/12/13 19.50ELL 0.10
Prepare weekly updates to unsecured creditors website.09/19/13 37.50MRD 0.10Review and analyze debtor's monthly operating report. 09/25/13 37.50MRD 0.10
Subtotal 18.30 6,892.50
Exhibit 1, Page 11
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 12
Date Description AmountAtty Hours** Fee Application**
Commence review of reconciliation from T. Neilson re disbursements to professionals and brief review of accounting records for Shulman Hodges & Bastian regarding same.
09/17/12 58.50ELL 0.30
Review and analyze emails re status of fee payments to professionals in case.
09/18/12 32.50MRD 0.10
Further review and analysis of spreadsheet provided by T. Neilson related to fees of professionals and schedule related to allocation and payment of same; review the Firm's accounting records to confirm all numbers match; prepare memorandum to L. Shulman and M. Lowe re observations and timing of next payment.
09/18/12 195.00ELL 1.00
Prepare email correspondence to U. Raanan re fees and expenses to be requested by the Firm for the period September 1, 2011 through September 14, 2012.
09/18/12 19.50ELL 0.10
Review draft of global Notice of Hearing on Fee Applications to confirm numbers are correct; prepare memorandum to M. Lowe re same.
09/21/12 19.50ELL 0.10
Emails with T. Neilson re fee applications to file.09/21/12 32.50MRD 0.10Prepare instructions to E. Lohayza re interim fee application for Shulman Hodges & Bastian LLP.
09/21/12 65.00MRD 0.20
Continue review of voluminous time records and continue to work on categorizing for tasks performed in the case to identify project categories for Fee Application; work on the billing record exhibits for the Fourth Interim Fee Application for Shulman Hodges & Bastian LLP in conformance with the U.S. Trustee requirements.
09/21/12 546.00ELL 2.80
Review of files and case docket and commence draft of the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP; work on identifying the project categories and summary of services previously rendered for each category.
09/21/12 292.50ELL 1.50
Brief review of Fee Applications filed by other professionals for information related to administrative expenses and cash on hand to incorporate into Fourth Interim Fee Application.
09/24/12 78.00ELL 0.40
Work on the billing record exhibits for the First Interim Fee Application for Shulman Hodges & Bastian LLP as Special Claims Counsel to the Trustee in conformance with the U.S. Trustee requirements; instructions to K. Fletcher re same.
09/24/12 97.50ELL 0.50
Continue review of case files and continue work on the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP and First Interim Fee Application as Special Claims Counsel to the Chapter 11 Trustee; work on narrative of events, issues addressed and results achieved; work on summarizing services for the project categories of Estate Analysis, Asset Disposition, Case Administration, Meeting of Creditors, Claims Administration/Objections, Errors and Omissions Policy, Employment Applications, Fee Applications, Fee and Employment Objections, Trade
09/24/12 1,267.50ELL 6.50
Exhibit 1, Page 12
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 13
Date Description AmountAtty HoursCreditor Avoidance Litigation, Insider Litigation and Discharge Litigation; draft Declaration of L. Shulman in support. Review and revise fourth interim fee application of Shulman Hodges & Bastian LLP.
09/25/12 292.50MRD 0.90
Further work on the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP as Committee Counsel and First Interim Fee Application as Special Claims Counsel to the Chapter 11 Trustee; work on summarizing services for the project category of Plan and Disclosure Statement.
09/25/12 195.00ELL 1.00
Prepare final of the billing record exhibits for the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP as Committee Counsel and First Interim Fee Application as Special Claims Counsel to the Chapter 11 Trustee.
09/25/12 136.50ELL 0.70
Review and revise Fourth Interim Application for Approval of Fees and Reimbursement of Expenses by Shulman Hodges & Bastian LLP as Committee Counsel and First Interim Application for Approval of Fees and Reimbursement of Expenses of Shulman Hodges & Bastian LLP as Special Claims Counsel for R. Todd Neilson; calculate blended hourly rate for each category of service and include in Fee Application; prepare Fee Application for final.
09/25/12 312.00ELL 1.60
Prepare correspondence to M. Asheghian re his review and comments to the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP; compile final.
09/25/12 58.50ELL 0.30
Prepare correspondence to R. Todd Neilson re his review and comments to the First Interim Fee Application of Shulman Hodges & Bastian LLP; compile final.
09/25/12 58.50ELL 0.30
Prepare for service the Fourth Interim Application for Approval of Fees and Reimbursement of Expenses by Shulman Hodges & Bastian LLP, Attorneys for the Official Committee of Unsecured Creditors; and First Interim Application for Approval of Fees and Reimbursement of Expenses of Shulman Hodges & Bastian LLP, Special Claims Counsel for R. Todd Neilson, Chapter 11 Trustee; prepare for electronic filing with the Court; prepare Judge's copy pursuant to Local Rules.
09/25/12 117.00ELL 0.60
Review and approve for final the Fourth Interim Fee Application. 09/25/12 157.50LMS 0.30Telephone conference from assistance at T. Nielson's office re his comments to the First Interim Fee Application of Shulman Hodges & Bastian LLP as Special Claims Counsel.
09/26/12 19.50ELL 0.10
Receipt of Trustee comments to the First Interim Application for Approval of Fees and Reimbursement of Expenses of Shulman Hodges & Bastian LLP, Special Claims Counsel; prepare the Local Rule 9013-3.1 Certificate; prepare for service and electronic filing with the Court; prepare Judge's copy for submission to Chambers as required by Local Rules.
09/27/12 78.00ELL 0.40
Analysis of issues re Committee's intent to oppose Fee Applications of 10/01/12 19.50ELL 0.10
Exhibit 1, Page 13
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 14
Date Description AmountAtty Hoursprofessionals; prepare memorandum to M. Lowe re same.Review and analyze correspondence re fee applications.10/01/12 32.50MRD 0.10Investigate status of comments from the Committee to the Fourth Interim Fee Application of Shulman Hodges & Bastian LLP.
10/10/12 19.50ELL 0.10
Review and analyze issues and prepare instructions for fee hearing. 10/15/12 210.00LMS 0.40Prepare for and attend hearing on motions for approval of professional fees.
10/16/12 1,332.50MRD 4.10
Review and analyze results of fee hearings; prepare comments for order.10/17/12 157.50LMS 0.30Review draft of Global Fee Order to confirm dates and amounts are correct; prepare memorandum to M. Lowe re separating amounts awarded to the Firm as counsel to the Committee and special claims counsel to the Chapter 11 Trustee.
10/17/12 39.00ELL 0.20
Review ECF email and obtain the Order on Interim Applications of Chapter 11 Trustees and Professionals for Approval and Payment of Interim Compensation and Reimbursement of Expenses; update electronic case file re same.
10/30/12 19.50ELL 0.10
Review spreadsheet reflecting professional fees incurred to date; prepare memorandum to M. Lowe re same.
11/13/12 19.50ELL 0.10
Review and edit and categorize time entries per the Fee Guides of the U.S. Trustee.
12/04/12 39.00ELL 0.20
Review and analyze notice re interim fee applications.09/03/13 37.50MRD 0.10Review of the Court docket for the Notice to Professionals of Intended Hearing Date on Fee Applications, review of the Notice and calculate deadlines, prepare memo to Calendar regarding same.
09/04/13 39.00LEC 0.20
Initial review of files and time records to determine project categories for the Shulman Hodges & Bastian LLP Fee Application and for addressing services for the Trustee as the Committee.
09/04/13 78.00LEC 0.40
Review and analysis of issues re time records and categories for Fee Application.
09/04/13 78.00ELL 0.40
Begin review of time records and categorize services per the requirements of the Court and the U.S. Trustee, work on the billing record exhibits for the Shulman Hodges & Bastian LLP Fee Application in compliance with the extensive requirements.
09/10/13 97.50LEC 0.50
Review of time records and categorize services per the requirements of the Court and the U.S. Trustee, work on the billing record exhibits for the Shulman Hodges & Bastian LLP Fee Application in compliance with the extensive requirements.
09/11/13 585.00LEC 3.00
Review of files and facts and background and draft the Interim Fee Application by Shulman Hodges & Bastian LLP, work on the narrative of events, issues addressed and results achieved, draft the Declaration in support; work on the narrative of tasks related to the case project categories.
09/11/13 1,053.00LEC 5.40
Work on the accounting of prior fee applications, requests, awards and 09/11/13 136.50LEC 0.70
Exhibit 1, Page 14
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 15
Date Description AmountAtty Hourspayments and update the Shulman Hodges & Bastian LLP Fee Application regarding same. Continued review of files and facts and background and continue drafting the Fee Application by Shulman Hodges & Bastian LLP, work on the narrative of events, issues addressed and results achieved, work on the narrative of tasks related to the case project categories.
09/13/13 1,267.50LEC 6.50
Review of additional billing records and categorize services per the requirements of the Court and the U.S. Trustee, work on the billing record exhibits for the Shulman Hodges & Bastian LLP Fee Application in compliance with the extensive requirements; work on the expense records exhibits.
09/13/13 78.00LEC 0.40
Continue review of files for facts and background and drafting the Shulman Hodges & Bastian LLP Fee Application, update the narrative of events, issues addressed and results achieved, update the narrative of tasks related to the case project categories.
09/16/13 565.50LEC 2.90
Work on the billing record exhibits for the Shulman Hodges & Bastian LLP Fee Application.
09/16/13 78.00LEC 0.40
Review and revise fifth interim fee application as counsel to committee and second interim fee application as special claims counsel to trustee.
09/16/13 300.00MRD 0.80
Update the billing record exhibits for the Shulman Hodges & Bastian LLP Fee Application.
09/17/13 78.00LEC 0.40
Subtotal 47.60 10,489.00
Exhibit 1, Page 15
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 16
Date Description AmountAtty Hours**Fee and Employment Objections**
Review ECF email and obtain Fee Applications that have been filed by other professionals; update electronic case file re same.
09/24/12 78.00ELL 0.40
Prepare notice of objection and reservation of rights to object to fee applications of professionals; prepare instructions to L. Verstegen re filing.
10/01/12 130.00MRD 0.40
Call with Chair and communicate with other Committee members re objections to fee applications.
10/01/12 315.00LMS 0.60
Review and revise reservation of rights to object to fee applications.10/01/12 210.00LMS 0.40Review ECF email and obtain the Omnibus Objection to Fee Applications filed by the Namco Committee; update electronic case file re same.
10/02/12 19.50ELL 0.10
Review and analyze reply by trustees to objection to fee applications.10/09/12 32.50MRD 0.10Discuss options with chair re fee challenges. 05/17/13 210.00LMS 0.40Review and analyze multiple correspondence re payments to professionals in light of possible lack of distribution to creditors.
05/17/13 37.50MRD 0.10
Review and analyze new guidelines re fee applications re possible fee examiner.
08/12/13 112.50MRD 0.30
Communications with Chair re retention of fee examiner.08/21/13 262.50LMS 0.50
Subtotal 3.30 1,407.50
Exhibit 1, Page 16
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 17
Date Description AmountAtty Hours**Meeting of Creditors**
Review and analyze detailed letter from trustees requested Committees to be disbanded.
10/30/12 210.00LMS 0.40
Review and analyze correspondence from trustees re disbanding of committees.
10/30/12 65.00MRD 0.20
Telephone conference with S. Koenig re response to letter to disband committees.
10/31/12 65.00MRD 0.20
Call with Namco committee counsel and advise Committee re proposed abandonment.
10/31/12 262.50LMS 0.50
Multiple communications with Committee members re potential disbandment.
11/04/12 315.00LMS 0.60
Call with Chair re disbandment of Committee issues.11/05/12 157.50LMS 0.30Continued discussions with interested parties re Committee disbandment. 11/06/12 210.00LMS 0.40Review and analyze correspondence from committee members re possible disbanding of committee.
11/06/12 32.50MRD 0.10
Continued discussions by and among Committee members re crafting response to Trustees' request to disband Committees.
11/15/12 315.00LMS 0.60
Review and revise draft letter to UST in response to Trustees' request to disband committees.
11/16/12 315.00LMS 0.60
Review and analyze multiple communications re response to letter from OUST re disbanding of committees.
11/19/12 97.50MRD 0.30
Continued discussions with interested parties and Committee members re issues with disbandment and related matters.
11/21/12 367.50LMS 0.70
Final review and approval of letter to the United States Trustee re Committees.
11/21/12 210.00LMS 0.40
Review revised letter responding to letter from United States Trustee to disband committees.
11/26/12 32.50MRD 0.10
Review and approve proposed draft letter with further revisions to UST re Committee disbandment.
11/26/12 157.50LMS 0.30
Continued work on refining submittal to UST re Committee disbandment; numerous communications with clients.
11/27/12 682.50LMS 1.30
Communications with Chair re Committee disbanding issues. 12/05/12 210.00LMS 0.40Communications with co counsel and the US Trustee re Committee disbandment; review reply letter Trustee.
01/02/13 315.00LMS 0.60
Multiple communications with Committee members re developing response to Trustee to reply re Committee disbandment.
01/10/13 367.50LMS 0.70
Review and analyze multiple correspondence from committee members re responding to UST's correspondence of whether to disband committee.
01/10/13 37.50MRD 0.10
Review and analyze multiple correspondence from committee members re UST.
01/11/13 37.50MRD 0.10
Review and revise response letter to OUST re possible dissolution of 01/11/13 75.00MRD 0.20
Exhibit 1, Page 17
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 18
Date Description AmountAtty Hourscommittee.Continued discussions with Committee members re formulation issues.01/14/13 315.00LMS 0.60Review and approve for final responsive letter re Committee disbandment.01/15/13 157.50LMS 0.30Multiple emails re response to OUST to most recent letter of trustees. 01/15/13 37.50MRD 0.10Review and analyze response from United States Trustee re disbandment of committee; discuss with committee.
01/22/13 37.50MRD 0.10
Review letter from UST and discuss with clients continuing role of Committees.
01/23/13 315.00LMS 0.60
Continued work on status memo to clients. 05/16/13 210.00LMS 0.40Communications with Namvar committee members re requested status information from Trustees; prepare instructions.
05/29/13 210.00LMS 0.40
Communications with interested parties re insurance for Committees. 06/10/13 157.50LMS 0.30Review and analyze property valuations and proposed action prepared by LC; prepare comments for Chair.
06/19/13 420.00LMS 0.80
Prepare email to committee members re fees incurred in litigation by trustees and status of objections to claims.
06/21/13 75.00MRD 0.20
Continued communications with Committee re claims administration and litigation issues and status.
06/24/13 210.00LMS 0.40
Subtotal 13.30 6,682.50
Exhibit 1, Page 18
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 19
Date Description AmountAtty Hours**Plan and Disclosure Statement**
Review and analyze communications by and between Committee and Trustees re plan support.
09/17/12 157.50LMS 0.30
Review and analyze results of Committee meeting with Trustees; prepare comments for Chair.
09/19/12 210.00LMS 0.40
Telephone conference with Chair and follow up with Namco Committee counsel re results of mtg with trustees.
09/21/12 315.00LMS 0.60
Review and execute stipulation to continue hearing on disclosure statement.
09/26/12 32.50MRD 0.10
Review and approve stipulation to continue hearing on disclosure statement.
09/26/12 105.00LMS 0.20
Review and analyze correspondence from committee members re decision to not support plan.
10/01/12 65.00MRD 0.20
Continued communications with interested parties re Committee non support for plan.
10/02/12 210.00LMS 0.40
Telephone conference with S. Koenig re status of disclosure statement and claims objections.
10/04/12 32.50MRD 0.10
Multiple communications with interested parties re resurrecting joint plan deal.
11/13/12 262.50LMS 0.50
Emails with counsel re possible settlement to approve plan.11/13/12 32.50MRD 0.10Review and analyze various pleadings rescheduling disclosure statement approval hearings.
12/06/12 105.00LMS 0.20
Communications with clients re need for continued management. 02/08/13 157.50LMS 0.30Communications with interested parties re fund management issues.02/11/13 210.00LMS 0.40Review and analyze multiple correspondence re status of plan of trustees.03/15/13 37.50MRD 0.10Communications with multiple parties re status of revised plan documents.03/18/13 315.00LMS 0.60Review and analyze status report of US Bank on objection to disclosure statement.
04/10/13 37.50MRD 0.10
Initial review of disclosure statement status report; prepare instructions.04/11/13 157.50LMS 0.30Initial review of revised plan; prepare instructions.04/25/13 577.50LMS 1.10Review and analyze multiple correspondence re revised disclosure statement.
04/25/13 37.50MRD 0.10
Communications with trustees' counsel re plan reformulation and issues with interim distributions; discuss with Chair.
04/26/13 315.00LMS 0.60
Review and analyze trustee's amended Chapter 11 plan.04/29/13 150.00MRD 0.40Continue review of revised Chapter 11 plan to be proposed by trustees.04/30/13 450.00MRD 1.20Prepare memorandum re review and analysis of amended Chapter 11 plan.
04/30/13 262.50MRD 0.70
Review and revise memorandum discussing proposed amended Chapter 11 plan of trustees.
05/01/13 225.00MRD 0.60
Exhibit 1, Page 19
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 20
Date Description AmountAtty HoursReview and analyze executive summary of revised plan; prepare comments and instructions.
05/01/13 315.00LMS 0.60
Discuss with S. Koenig possible objections to disclosure statement.05/02/13 37.50MRD 0.10Final revisions to memo re revised plan summary.05/06/13 210.00LMS 0.40Discuss revised plan provisions with Namco Committee counsel and Chair.
05/07/13 315.00LMS 0.60
Review and analyze correspondence from S. Koenig re terms of amended plan proposed by trustee.
05/07/13 37.50MRD 0.10
Follow up meeting with Chair re status of case and plan prospects. 05/10/13 2,205.00LMS 4.20Review and analyze results of meeting with trustees and their counsel; prepare instructions.
05/13/13 315.00LMS 0.60
Prepare for and attend call with Namco committee counsel re plan revision issues.
05/15/13 315.00LMS 0.60
Work with Trustee counsel on status report re plan and litigation to be sent to Committee.
05/15/13 210.00LMS 0.40
Initial review of revised and modified disclosure statement; prepare instructions.
05/21/13 420.00LMS 0.80
Review and analyze trustees' first amended disclosure statement.05/23/13 75.00MRD 0.20Initial review of modified plan document; prepare instructions for needed review and dissemination.
05/28/13 420.00LMS 0.80
Review and analyze debtor's revised proposed disclosure statement and related documents; send correspondence to committee re same.
05/28/13 112.50MRD 0.30
Review and analyze motion to approve first amended disclosure statement.
05/28/13 112.50MRD 0.30
Email to and from D. Poitras re questions on status of estates.06/05/13 37.50MRD 0.10Review and analyze motion to set voting procedures on plan.06/12/13 300.00MRD 0.80Prepare email to M. Pagay re comments and requests to changes of voting and solicitation procedures.
06/12/13 75.00MRD 0.20
Briefly review Trustee pleadings re plan solicitation and voting; prepare comments and instructions.
06/12/13 315.00LMS 0.60
Telephone conference with D. Poitras re proposed changes to voting procedures.
06/12/13 37.50MRD 0.10
Telephone conference with D. Meadows re issues on proposed voting and balloting procedure; discuss same with S. Koenig.
06/17/13 112.50MRD 0.30
Review and analyze issues re voting procedures; prepare comments and instructions.
06/18/13 210.00LMS 0.40
Review and analyze multiple correspondence from committee members re requests for information from trustees.
06/20/13 75.00MRD 0.20
Review and analyze objection to amended disclosure statement filed by M. Namvar.
06/24/13 112.50MRD 0.30
Prepare email to committee re objection to disclosure statement filed by 06/25/13 75.00MRD 0.20
Exhibit 1, Page 20
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 21
Date Description AmountAtty HoursM. Namvar.Initial review of Mousa's objection to disclosure statement; prepare comments.
06/25/13 210.00LMS 0.40
Review and analyze filing with minor amendments to disclosure statement; send email to committee re same.
06/26/13 112.50MRD 0.30
Review and analyze proposed revisions to disclosure statement by Trustees; prepare comments.
06/27/13 315.00LMS 0.60
Review and analyze reply to objection of M. Namvar to disclosure statement.
06/28/13 75.00MRD 0.20
Initial review of Trustee response to Mousa objection to disclosure statement.
06/29/13 210.00LMS 0.40
Prepare for and attend hearing on approval of trustees' proposed disclosure statement.
07/02/13 1,237.50MRD 3.30
Telephone conference with D. Poitras re committee's position on approval of disclosure statement.
07/02/13 37.50MRD 0.10
Prepare email to committee re approval of disclosure statement and plan confirmation deadlines.
07/03/13 75.00MRD 0.20
Review and analyze results of hearing on disclosure statement; prepare comments and instructions.
07/03/13 210.00LMS 0.40
Briefly review amended plan and disclosure statement documents; prepare comments.
07/12/13 262.50LMS 0.50
Review and analyze redlined amended disclosure statement.07/12/13 75.00MRD 0.20Review and analyze order approving disclosure statement.07/22/13 37.50MRD 0.10Prepare email to committees re communication with creditors re proposed plan; review responses re same.
08/01/13 75.00MRD 0.20
Draft letter to creditors re plan proposed by trustees.08/01/13 300.00MRD 0.80Review and analyze issues and prepare instructions re possible plan summary to constituents in light of solicitation packages.
08/01/13 315.00LMS 0.60
Telephone conference with J. Griffith re terms of plan and estimate for timing of payments; discuss same with U. Raanan.
08/01/13 75.00MRD 0.20
Review and revise plan summary letter to send to constituents. 08/02/13 157.50LMS 0.30Communications with client re plan solicitation issues. 08/04/13 315.00LMS 0.60Email to and from Committee members re letter to creditors re plan.08/05/13 37.50MRD 0.10Telephone conference with E. Dennis re voting on proposed plan.08/05/13 37.50MRD 0.10Finalize letter to creditors re explanation of plan and voting process; prepare instructions to L. Verstegen re service on creditors.
08/06/13 112.50MRD 0.30
Field questions from interested parties re plan solicitation and voting issues.
08/06/13 420.00LMS 0.80
Analysis of issues related to plan solicitation; review case information and work on updating the master mailing matrix to be used for generating database for solicitation letters; research case files for email addresses
08/06/13 507.00ELL 2.60
Exhibit 1, Page 21
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 22
Date Description AmountAtty Hoursfor creditors to receive solicitation letter.Email to and from J. Farhadian re voting for plan and requirements for confirmation.
08/06/13 37.50MRD 0.10
Email to and from D. Paris re distributions to be made on claims filed in both Namvar and Namco cases.
08/06/13 37.50MRD 0.10
Access Pacer and obtain various documents related to “plan packages” including Proofs of Service filed on August 1, 2013; review Proofs of Service and compare with the service list downloaded from Pacer and with service list maintained by Shulman Hodges & Bastian LLP and work on updating database for solicitation letters; continue research of files for email addresses; identify parties to be served with solicitation letter via mail and via email.
08/07/13 1,014.00ELL 5.20
Telephone conference with A. Javahery re procedure for voting on plan.08/07/13 37.50MRD 0.10Email to and from B. Isaac re procedure for voting on plan.08/07/13 37.50MRD 0.10E-mail to and from K. Doron re plan and disclosure statement.08/07/13 37.50MRD 0.10Finalize database for service list for Plan solicitation letters and work on preparing same for mailing.
08/08/13 97.50ELL 0.50
Review rejected emails related to Plan solicitation letter and research new and/or updated contact information for recipients; update master mailing matrix re same.
08/08/13 195.00ELL 1.00
Review and analyze correspondence re claim of F. Mahjoubi and whether entitled to vote.
08/09/13 37.50MRD 0.10
Telephone conference with Masoud re voting for plan; send e-mail re same.
08/09/13 75.00MRD 0.20
Telephone conference with Akravan re voting on plan.08/09/13 37.50MRD 0.10Review and analyze correspondence from committee members re creditors' confusion with plan and possible meeting with trustees.
08/12/13 75.00MRD 0.20
Multiple communications with clients re issues with plan voting. 08/12/13 367.50LMS 0.70Review and analyze notice of filing of plan supplements; send e-mail to committee re same.
08/13/13 150.00MRD 0.40
Prepare for and call with committee members to discuss voting on plan and confusion of creditors in doing so; send e-mail to committee members re same.
08/13/13 187.50MRD 0.50
Initial review of plan supplements filed by Trustees; prepare comments and instructions.
08/13/13 315.00LMS 0.60
Prepare for and attend call with Committee members re plan support.08/13/13 262.50LMS 0.50Draft communication to creditors from committee re plan.08/13/13 75.00MRD 0.20Review and revise proposed letter to creditor constituents. 08/13/13 105.00LMS 0.20Telephone conference with D. Hagani re voting on plan.08/13/13 37.50MRD 0.10Review and analyze status of claims filed by E. Vasquez and whether entitled to vote on plan.
08/13/13 112.50MRD 0.30
Exhibit 1, Page 22
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 23
Date Description AmountAtty HoursTelephone call from M. Radfar re order approving objection to claim, claim filed in Namco and ballot received.
08/13/13 180.00RMK 0.60
Telephone conference with M. Naim re voting on plan.08/13/13 37.50MRD 0.10Review and revise letter to creditors from committees re plan; communication with committees re same; provide instructions to L. Verstegen re sending to creditors.
08/14/13 187.50MRD 0.50
Email to and from M. Eshmoili re voting on plan.08/14/13 37.50MRD 0.10Telephone conference with F. Pakravan re voting on plan.08/14/13 75.00MRD 0.20Further communications with clients re needed letter re plan position. 08/14/13 210.00LMS 0.40Work with committee on plan reasons re letter. 08/14/13 210.00LMS 0.40Telephone conference with H. Amini re correct ballot for voting on plan; send e-mail to U. Raanan re same.
08/14/13 75.00MRD 0.20
Email to and from U. Raanan re ballot for H. Yamini.08/15/13 37.50MRD 0.10Emails with multiple creditors re voting on plan.08/15/13 75.00MRD 0.20Review and analyze multiple correspondence from creditors re voting on plan and possible fee examiner; respond re same.
08/15/13 112.50MRD 0.30
Numerous communications with creditors re plan issues. 08/15/13 420.00LMS 0.80Telephone conference with J. Griffith re voting on Namvar plan.08/19/13 37.50MRD 0.10Telephone conference with M. Basarian re questions on voting on plan.08/19/13 37.50MRD 0.10Telephone conference with B. Brookhim re questions on voting on plan; e-mails re same.
08/19/13 75.00MRD 0.20
Prepare email to G. Haroonian re explanation of plan supplement.08/19/13 37.50MRD 0.10Review and analyze issues re creditor meeting to discuss terms of plan; send e-mail to creditors re same.
08/19/13 75.00MRD 0.20
Email to and from N. Cowen re voting on plan.08/19/13 37.50MRD 0.10Multiple correspondence re creditors meeting to discuss plan.08/20/13 112.50MRD 0.30Review and reply to communication from N. Cowen re execution of ballots for her children's claims in her capacity as trustee for those claims.
08/20/13 60.00RMK 0.20
Numerous communications with clients, creditors and interested parties re voting and plan confirmation issues.
08/21/13 945.00LMS 1.80
Further correspondence with committee re possible meeting to discuss proposed plan.
08/21/13 37.50MRD 0.10
Telephone call from M. Radfar re receipt of ballot.08/21/13 30.00RMK 0.10Telephone conference with M. Parkravan re voting on plan.08/22/13 37.50MRD 0.10Telephone conference with F. Nazarian re voting on plan.08/22/13 37.50MRD 0.10Multiple correspondence with creditors re voting on plan.08/23/13 112.50MRD 0.30Multiple correspondence with M. Torbati re ballot needed for voting on plan.
08/26/13 37.50MRD 0.10
Multiple correspondence with L. Moreh re explanation re voting on plan.08/26/13 75.00MRD 0.20Telephone conference with Mona re voting on plan.08/26/13 37.50MRD 0.10
Exhibit 1, Page 23
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 24
Date Description AmountAtty HoursTelephone conference with M. Behfarian re voting on plan.08/26/13 75.00MRD 0.20Telephone conference with D. Faridooni re voting on plan.08/27/13 37.50MRD 0.10Telephone call to M. Radfar re ballot for plan confirmation.08/27/13 30.00RMK 0.10Review and analyze multiple correspondence from creditors re meeting re plan.
09/02/13 37.50MRD 0.10
Numerous communications with Committee and creditors re plan reactions.
09/03/13 577.50LMS 1.10
Review and analyze brief re confirmation of plan submitted by trustees.09/04/13 225.00MRD 0.60Brief review of plan confirmation pleadings filed by Trustees; advise clients.
09/04/13 420.00LMS 0.80
Telephone conference with Linda re status of plan and remaining assets.09/10/13 75.00MRD 0.20Prepare email to committee re plan confirmation documents.09/12/13 37.50MRD 0.10Communications with committee members in preparation for plan conference hearing.
09/12/13 262.50LMS 0.50
Initial review of Pension Benefit Guaranty Corporation settlement; prepare comments and recommendations.
09/12/13 262.50LMS 0.50
Email to and from committee re voting by creditors on plan.09/16/13 37.50MRD 0.10Review and analyze objection to confirmation of plan; send email to committee re same.
09/20/13 112.50MRD 0.30
Review and analyze pleadings opposing plan confirmation; prepare comments.
09/20/13 420.00LMS 0.80
Communications with clients in preparation for plan confirmation hearing. 09/23/13 262.50LMS 0.50
Subtotal 61.50 25,803.50
Exhibit 1, Page 24
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 25
Date Description AmountAtty Hours**Trade Creditor Avoidance Litigation**
Emails with L. Wang Ekvall re status of litigation in Exchange case.10/24/12 32.50MRD 0.10
Subtotal 0.10 32.50
Exhibit 1, Page 25
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 26
Date Description AmountAtty Hours**Insider Avoidance Litigation**
Communications with interested parties re status of family litigation.05/21/13 210.00LMS 0.40
Subtotal 0.40 210.00
Exhibit 1, Page 26
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 27
Date Description AmountAtty Hours**Litigation - 001**
Initial review of pleadings re Wells Fargo Bank settlement; prepare comment and recommendations.
09/28/12 315.00LMS 0.60
Review and analyze issue re statute of limitations; review code and draft reply.
10/24/12 420.00RSH 0.80
Initial review and discussions with Meadows re Tranmar settlement; prepare comments and instructions.
11/13/12 262.50LMS 0.50
Review and analyze motion to approve settlement between Beshmada and White Water Funding.
11/20/12 32.50MRD 0.10
Review and analyze motion to approve settlement between Beshmada and White Water Funding.
11/20/12 65.00MRD 0.20
Review and analyze motion to approve settlement with TN Managment and T. Namvar; send email to committee re same.
12/07/12 97.50MRD 0.30
Review and analyze reply of trustees to opposition to motion to approve Tranmar settlement.
01/16/13 37.50MRD 0.10
Review and analyze multiple correspondence re settlement with M. Namvar.
02/01/13 37.50MRD 0.10
Review and analyze motion to approve compromise with Town and Country Bank; send email to committee re same.
02/06/13 112.50MRD 0.30
Initial review of proposed settlement with Town &Country; prepare comments and instructions.
02/06/13 210.00LMS 0.40
Review and analyze motion to approve settlement with PNC Bank; send e-mail to committee re same.
02/06/13 75.00MRD 0.20
Initial review of proposed settlement of PNC claim litigation; prepare instructions for further evaluation.
02/07/13 315.00LMS 0.60
Telephone conference with U. Raanan re reason for settlements; send email to committee re same.
02/07/13 150.00MRD 0.40
Telephone conference with R. Sokyl re settlements with PNC Bank and Town and Country Bank; send email to committee re same.
02/11/13 112.50MRD 0.30
Review and analyze motion to approve settlement with Cathay Bank; send email to committee re same.
02/27/13 150.00MRD 0.40
Telephone conference with R. Sokol re settlement with Cathay Bank.02/27/13 37.50MRD 0.10Continued communications with clients and prepare instructions re response to Cathay Bank settlement.
03/06/13 157.50LMS 0.30
Review and analyze motion to approve settlement with Princeton, LLC; send email to committee re same.
03/16/13 112.50MRD 0.30
Review and analyze motion to approve settlement with Starpoint, 450 Roxbury, etc; send email to committee re same.
03/16/13 112.50MRD 0.30
Telephone conference with W. Oetzell re settlements with Princeton and Starpoint; update correspondence with committee re same.
03/18/13 150.00MRD 0.40
Initial review of pleadings re settlements with Princeton and Stairpoints; 03/20/13 577.50LMS 1.10
Exhibit 1, Page 27
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 28
Date Description AmountAtty Hoursprepare comments and instructions after speaking to Chair.Review and analyze stipulation between Trustee, Opus and I. Namvar.03/22/13 37.50MRD 0.10Appear at hearing on approval of settlements with Starpoint parties and Princeton Holdings.
04/10/13 150.00MRD 0.40
Review and analyze motion to approve settlement with Woodman Partners; send correspondence to committee re same.
04/29/13 75.00MRD 0.20
Initial review of Woodman settlement pleadings; prepare instructions. 04/30/13 210.00LMS 0.40Review and analyze correspondence from W. Oetzell re further information on settlement with Woodman Partners.
05/01/13 37.50MRD 0.10
Communications with Namco committee counsel and reach out to Trustee's counsel re problematic litigation findings.
05/03/13 315.00LMS 0.60
Numerous communications with interested parties to organize meeting to discuss litigation issues.
05/06/13 315.00LMS 0.60
Review and analyze correspondence re status of multiple litigation in both Namvar and Namco cases.
05/10/13 37.50MRD 0.10
Preparation for and attend meeting with Trustees and counsel re litigation status report.
05/10/13 2,992.50LMS 5.70
Review and provide comments re memo to committees re status of litigation by trustees.
05/15/13 37.50MRD 0.10
Email to and from H. Babajoni re status of litigation brought by trustees.05/20/13 37.50MRD 0.10Email to and from D. Poitras re further information on judgments obtained by trustees.
05/22/13 37.50MRD 0.10
Review and analyze status report by Trustees re litigation; comments for client.
05/23/13 262.50LMS 0.50
Prepare email to D. Poitras re further questions on pending litigation by trustees.
05/28/13 37.50MRD 0.10
Multiple communications with committee members re case and litigation status issues.
05/28/13 315.00LMS 0.60
Review and analyze motion to approve settlement with Laska Trust.05/29/13 112.50MRD 0.30Prepare and send e-mail to committee re proposed settlement with Laskas.
05/30/13 37.50MRD 0.10
Email to and from W. Oetzell re attorneys' fees incurred on Laska settlement.
05/30/13 37.50MRD 0.10
Initial review of Laska settlement; prepare instructions. 05/30/13 210.00LMS 0.40Review and analyze motion to approve settlement with 601 Mobil.06/14/13 112.50MRD 0.30Initial review of pleadings re proposed settlement with Mobil; prepare comments and instructions.
06/14/13 262.50LMS 0.50
Communications with clients re issues with Ponzi scheme designation. 06/21/13 210.00LMS 0.40Review and analyze correspondence from D. Meadows re questions on Raestagar settlement.
06/21/13 37.50MRD 0.10
Continued communications with Trustee counsel re status of various 06/24/13 210.00LMS 0.40
Exhibit 1, Page 28
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 29
Date Description AmountAtty Hourslitigation matters. Review and analyze motion to approve settlement with T. Kohan; send email to committee re same.
07/03/13 150.00MRD 0.40
Initial review of settlement with Kohan parties; prepare comments. 07/03/13 315.00LMS 0.60Review and analyze motion to approve settlement with Canyon Springs; send email to committee re same.
08/08/13 225.00MRD 0.60
Review and analyze motion to approve compromise with pension plan; send email to committee re same.
09/12/13 300.00MRD 0.80
Subtotal 22.50 10,657.50
Total Fees 200.30 78,287.50
Exhibit 1, Page 29
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 30
CostsDate Description Amount09/19/12 8.00Parking; Parking expense on 7/24/12; Len Shulman09/20/12 3.60Access and review PACER database for; Docket Report09/25/12 2.16Access and review PACER database for; Docket Report09/25/12 75.80Photocopy; Fee Application-Notice09/25/12 5.80Postage09/26/12 18.95Postage09/27/12 3.60Access and review PACER database for; Docket Report09/27/12 10.80Photocopy; Fee Application-Notice09/27/12 0.90Postage09/30/12 18.80Computer Research; Inv. 1209015533;9/30/12;Computer Research ; Lexis Nexis10/02/12 11.00Photocopy; Motion10/04/12 3.60Access and review PACER database for; Docket Report10/04/12 3.60Access and review PACER database for; Docket Report10/04/12 0.84Access and review PACER database for; Image1332-010/04/12 0.72Access and review PACER database for; Deadline/Schedule10/04/12 0.48Access and review PACER database for; Docket Report10/04/12 0.12Access and review PACER database for; All Court Types Case Search10/04/12 0.12Access and review PACER database for; All Court Types Case Search10/05/12 8.00Attorney and Messenger Service; Inv.5031769;10/03/2012;File and return conformed
copies of Joinder re Oppo x210/10/12 10.48Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 9/27/12 to L. Fairgin,
Los Angeles ; Federal Express10/10/12 7.97Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 9/27/12 to R. Baum,
Los Angeles ; Federal Express10/10/12 10.48Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 9/27/12 to S.
Alyeshmerni, Los Angeles ; Federal Express10/10/12 7.97Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 9/27/12 to D. Haghani,
Santa Monica; Federal Express10/10/12 10.67Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 10/3/12 to L. Faigin, Los
Angeles; Federal Express10/10/12 8.12Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 10/3/12 to R. Baum,
Los Angeles ; Federal Express10/10/12 10.67Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 10/3/12 to S.
Alyeshmerni, Los Angeles ; Federal Express10/10/12 8.12Federal Express; Inv. 2-040-26452;10/5/12;Overnight delivery on 10/3/12 to D. Haghani,
Santa Monica ; Federal Express10/10/12 7.40Federal Express; Inv. 2-040-26452;10/5/12;Overnight return delivery on 10/2/12 to A.
Exhibit 1, Page 30
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 31
Date Description AmountUdo, Irvine; Federal Express
10/11/12 3.60Access and review PACER database for; Docket Report10/12/12 8.00Attorney and Messenger Service; Inv.5031903;10/09/2012;File and return conformed
copies of Order x210/16/12 3.60Access and review PACER database for; Docket Report10/16/12 3.60Access and review PACER database for; Image167-010/16/12 3.60Access and review PACER database for; Image167-110/18/12 9.12Access and review PACER database for; Docket Report10/19/12 59.20Photocopy; Motion10/19/12 15.60Postage10/25/12 3.60Access and review PACER database for; Docket Report10/31/12 8.00Parking; Parking expense at hearing on 10/3/12; Melissa Lowe10/31/12 8.00Parking; Parking expense at hearing on 10/16/12; Melissa Lowe11/01/12 5.64Access and review PACER database for; Docket Report11/12/12 3.60Access and review PACER database for; Docket Report11/12/12 3.60Access and review PACER database for; Docket Report11/21/12 3.48Access and review PACER database for; Docket Report11/29/12 3.48Access and review PACER database for; Docket Report12/06/12 3.60Access and review PACER database for; Docket Report12/13/12 3.60Access and review PACER database for; Docket Report12/13/12 2.16Access and review PACER database for; Image2114-012/13/12 3.60Access and review PACER database for; Docket Report12/20/12 5.64Access and review PACER database for; Docket Report12/27/12 3.60Access and review PACER database for; Docket Report01/03/13 1.08Access and review PACER database for; Docket Report01/03/13 0.72Access and review PACER database for; Image1379-001/03/13 1.08Access and review PACER database for; Docket Report01/03/13 0.84Access and review PACER database for; Image1369-001/10/13 4.20Access and review PACER database for; Docket Report01/10/13 3.60Access and review PACER database for; Docket Report01/10/13 1.32Access and review PACER database for; Image1-001/15/13 3.60Access and review PACER database for; Docket Report01/17/13 3.48Access and review PACER database for; Docket Report01/22/13 2.25Postage01/23/13 0.24Access and review PACER database for; Docket Report01/23/13 0.48Access and review PACER database for; Image15-001/23/13 7.20Access and review PACER database for; Docket Report01/23/13 1.32Access and review PACER database for; Image1156-0
Exhibit 1, Page 31
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 32
Date Description Amount01/23/13 3.84Access and review PACER database for; Docket Report01/23/13 2.25Postage01/24/13 8.55Postage01/25/13 3.60Access and review PACER database for; Docket Report01/28/13 1.32Access and review PACER database for; Image150-001/30/13 3.60Access and review PACER database for; Docket Report01/30/13 3.60Access and review PACER database for; Image1388-001/30/13 3.44Postage01/31/13 3.48Access and review PACER database for; Docket Report01/31/13 3.60Access and review PACER database for; Docket Report01/31/13 3.60Access and review PACER database for; Image902-002/05/13 3.60Access and review PACER database for; Docket Report02/05/13 3.60Access and review PACER database for; Image770-002/05/13 3.60Access and review PACER database for; Image770-102/05/13 3.60Access and review PACER database for; Image770-202/05/13 0.96Access and review PACER database for; Image795-002/05/13 3.60Access and review PACER database for; Docket Report02/05/13 1.84Postage02/06/13 0.46Postage02/06/13 0.46Postage02/13/13 3.60Access and review PACER database for; Docket Report02/13/13 1.80Access and review PACER database for; Image930-002/13/13 0.24Access and review PACER database for; Docket Report02/13/13 0.96Access and review PACER database for; Image13-002/13/13 0.84Access and review PACER database for; Image14-002/13/13 5.88Access and review PACER database for; Docket Report02/13/13 1.92Access and review PACER database for; Image218-002/13/13 3.60Access and review PACER database for; Docket Report02/13/13 0.96Access and review PACER database for; Image906-002/13/13 6.48Access and review PACER database for; Docket Report02/14/13 5.28Access and review PACER database for; Docket Report02/14/13 1.38Postage02/21/13 3.60Access and review PACER database for; Docket Report02/21/13 0.46Postage02/22/13 0.46Postage02/27/13 1.44Access and review PACER database for; Docket Report02/27/13 3.60Access and review PACER database for; Image2178-002/28/13 3.60Access and review PACER database for; Docket Report
Exhibit 1, Page 32
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 33
Date Description Amount02/28/13 3.60Access and review PACER database for; Docket Report03/07/13 3.36Access and review PACER database for; Docket Report03/13/13 2.16Access and review PACER database for; Image30251422-003/13/13 3.60Access and review PACER database for; Docket Report03/13/13 1.44Access and review PACER database for; Creditor Mailing Matrix03/13/13 1.44Access and review PACER database for; Creditor Mailing Matrix03/14/13 3.36Access and review PACER database for; Docket Report03/15/13 1.38Postage03/18/13 3.60Access and review PACER database for; Image237-003/18/13 3.60Access and review PACER database for; Image433-003/18/13 3.60Access and review PACER database for; Image431-003/18/13 0.36Access and review PACER database for; Image86-003/18/13 0.96Access and review PACER database for; Docket Report03/21/13 3.48Access and review PACER database for; Docket Report03/22/13 7.20Access and review PACER database for; Docket Report03/22/13 3.24Access and review PACER database for; Image1430-003/22/13 0.46Postage03/27/13 12.24Access and review PACER database for; Docket Report03/27/13 2.64Access and review PACER database for; Image903-003/27/13 0.96Access and review PACER database for; Image1925-003/27/13 0.96Access and review PACER database for; Image1926-003/27/13 1.68Access and review PACER database for; IMage2028-003/27/13 2.16Access and review PACER database for; Image2114-003/29/13 3.60Access and review PACER database for; Docket Report04/02/13 12.00Postage04/02/13 6.60Postage04/02/13 13.50Postage04/02/13 9.75Postage04/02/13 6.60Postage04/02/13 7.45Postage04/03/13 3.60Access and review PACER database for; Docket Report04/03/13 0.84Access and review PACER database for; Image1391-004/04/13 3.60Access and review PACER database for; Docket Report04/11/13 3.60Access and review PACER database for; Docket Report04/18/13 3.60Access and review PACER database for; Docket Report04/18/13 1.32Access and review PACER database for; Docket Report04/25/13 3.60Access and review PACER database for; Docket Report04/30/13 8.00Parking; Parking expense at hearing on 4/3/13; Michelle Choi
Exhibit 1, Page 33
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 34
Date Description Amount05/02/13 1.92Access and review PACER database for; Docket Report05/02/13 3.60Access and review PACER database for; Image1466-005/02/13 0.48Access and review PACER database for; Image24587638-005/02/13 0.48Access and review PACER database for; Image24587924-005/02/13 3.60Access and review PACER database for; Docket Report05/03/13 1.92Postage05/11/13 3.60Access and review PACER database for; Docket Report05/16/13 3.60Access and review PACER database for; Docket Report05/20/13 0.84Access and review PACER database for; Image1482-005/21/13 3.60Access and review PACER database for; Docket Report05/21/13 0.84Access and review PACER database for; Image1435-005/21/13 0.36Access and review PACER database for; Associated Cases05/24/13 3.36Access and review PACER database for; Docket Report05/29/13 8.00Parking; Parking expense at hearing on 5/8/13; Rika Kido05/30/13 3.60Access and review PACER database for; Docket Report06/06/13 3.60Access and review PACER database for; Docket Report06/10/13 3.60Access and review PACER database for; Docket Report06/11/13 0.96Access and review PACER database for; Image1387-006/13/13 3.60Access and review PACER database for; Docket Report06/18/13 0.66Postage06/19/13 2.40Access and review PACER database for; Docket Report06/19/13 1.68Access and review PACER database for; Image1523-006/20/13 3.60Access and review PACER database for; Docket Report06/24/13 2.28Access and review PACER database for; Docket Report06/24/13 2.04Access and review PACER database for; Image1501-006/27/13 3.48Access and review PACER database for; Docket Report07/02/13 2.88Access and review PACER database for; Docket Report07/03/13 3.60Access and review PACER database for; Image1535-007/03/13 2.28Access and review PACER database for; Docket Report07/03/13 3.60Access and review PACER database for; Docket Report07/08/13 3.60Access and review PACER database for; Docket Report07/08/13 0.24Access and review PACER database for; Image1537-107/08/13 0.24Access and review PACER database for; Image1537-207/09/13 2.40Access and review PACER database for; Docket Report07/09/13 2.40Access and review PACER database for; Docket Report07/09/13 1.68Access and review PACER database for; Image1537-007/09/13 2.40Access and review PACER database for; Docket Report07/11/13 3.60Access and review PACER database for; Docket Report
Exhibit 1, Page 34
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 35
Date Description Amount07/15/13 4.08Access and review PACER database for; Docket Report07/15/13 0.36Access and review PACER database for; Image59-007/15/13 0.36Access and review PACER database for; Image77-007/15/13 3.60Access and review PACER database for; Docket Report07/15/13 3.48Access and review PACER database for; Image1555-007/15/13 0.36Access and review PACER database for; Associated Cases07/15/13 0.60Access and review PACER database for; Docket Report07/15/13 0.48Access and review PACER database for; Image44-007/17/13 0.36Access and review PACER database for; Image25366115-007/17/13 0.36Access and review PACER database for; Image24874665-007/17/13 0.36Access and review PACER database for; Image29257663-007/17/13 0.60Access and review PACER database for; Image292563970-007/18/13 3.60Access and review PACER database for; Docket Report07/22/13 3.48Access and review PACER database for; Docket Report07/23/13 3.60Access and review PACER database for; Image30686786-007/23/13 3.60Access and review PACER database for; Image30686519-007/25/13 3.60Access and review PACER database for; Docket Report07/25/13 3.60Access and review PACER database for; Image30505252-007/25/13 3.60Access and review PACER database for; Docket Report07/25/13 3.60Access and review PACER database for; Docket Report07/25/13 1.68Access and review PACER database for; Image1594-007/25/13 3.24Access and review PACER database for; Image1593-007/25/13 0.72Access and review PACER database for; Image1592-007/25/13 0.96Access and review PACER database for; Image1577-207/25/13 3.60Access and review PACER database for; Image1577-007/25/13 3.60Access and review PACER database for; Image1577-107/25/13 0.72Access and review PACER database for; Image1578-007/25/13 0.12Access and review PACER database for; Bankruptcy Case Search08/01/13 3.60Access and review PACER database for; Docket Report08/06/13 3.12Access and review PACER database for; List of Creditors08/06/13 7.20Access and review PACER database for; List of Creditors08/07/13 13.59Federal Express; Inv. 2-356-27429;8/2/13;Overnight delivery on 7/29/13 to E. Namvar,
Los Angeles ; Federal Express08/07/13 10.99Federal Express; Inv. 2-356-27429;8/2/13;Overnight delivery on 7/29/13 to T. Thielemann,
Santa Barbara ; Federal Express08/08/13 3.60Access and review PACER database for; Docket Report08/08/13 3.60Access and review PACER database for; Image1641-008/08/13 3.60Access and review PACER database for; Docket Report
Exhibit 1, Page 35
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 36
Date Description Amount08/08/13 3.60Access and review PACER database for; Image2356-008/08/13 3.60Access and review PACER database for; Image2357-008/08/13 29.00Photocopy; Letter08/09/13 2.40Photocopy; Motion08/12/13 0.48Access and review PACER database for; Image24587638-008/12/13 132.80Photocopy; Motion08/12/13 6.60Postage08/13/13 3.60Access and review PACER database for; Image1274-008/13/13 0.84Access and review PACER database for; Image1506-008/13/13 1.08Access and review PACER database for; Image1348-008/13/13 0.48Access and review PACER database for; Image30588577-008/13/13 1.08Access and review PACER database for; Image1349-008/16/13 3.60Access and review PACER database for; Docket Report08/22/13 3.60Access and review PACER database for; Docket Report08/29/13 3.60Access and review PACER database for; Docket Report09/03/13 3.12Access and review PACER database for; Docket Report09/03/13 0.72Access and review PACER database for; Image1674-009/03/13 0.72Access and review PACER database for; Image1678-009/03/13 3.24Access and review PACER database for; Docket report09/03/13 0.84Access and review PACER database for; Image1684-009/03/13 30.60Photocopy; Motion09/04/13 10.80Photocopy; Complaint09/04/13 0.66Postage09/04/13 2.32Postage09/10/13 4.68Access and review PACER database for; List of Creditors09/12/13 3.60Access and review PACER database for; Docket Report09/16/13 0.66Postage09/17/13 33.40Photocopy; Fee Application-Notice09/19/13 3.60Access and review PACER database for; Docket Report
Total Disbursements 1,221.50
Exhibit 1, Page 36
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 37
Fee Recap by Task Code**Asset Disposition**
Melissa R. Davis 6.60 375.00 2,230.00Leonard M. Shulman 25.50 525.00 13,387.50
15,617.50Subtotal
**Business Operations**
Melissa R. Davis 0.90 375.00 337.50Leonard M. Shulman 0.30 525.00 157.50
495.00Subtotal
**Case Administration**
Melissa R. Davis 8.40 375.00 3,015.00Erlanna L. Lohayza 4.00 195.00 780.00Leonard M. Shulman 5.90 525.00 3,097.50
6,892.50Subtotal
** Fee Application**
Melissa R. Davis 6.40 375.00 2,125.00Lorre E. Clapp 20.80 195.00 4,056.00Erlanna L. Lohayza 19.40 195.00 3,783.00Leonard M. Shulman 1.00 525.00 525.00
10,489.00Subtotal
**Fee and Employment Objections**
Melissa R. Davis 0.90 375.00 312.50Erlanna L. Lohayza 0.50 195.00 97.50Leonard M. Shulman 1.90 525.00 997.50
1,407.50Subtotal
**Meeting of Creditors**
Melissa R. Davis 1.70 375.00 592.50Leonard M. Shulman 11.60 525.00 6,090.00
6,682.50Subtotal
**Plan and Disclosure Statement**
Rika M. Kido 1.00 300.00 300.00Melissa R. Davis 21.10 375.00 7,887.50Erlanna L. Lohayza 9.30 195.00 1,813.50
Exhibit 1, Page 37
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 38
Leonard M. Shulman 30.10 525.00 15,802.5025,803.50Subtotal
**Trade Creditor Avoidance Litigation**
Melissa R. Davis 0.10 325.00 32.5032.50Subtotal
**Insider Avoidance Litigation**
Leonard M. Shulman 0.40 525.00 210.00210.00Subtotal
**Litigation - 001**
Melissa R. Davis 7.50 375.00 2,782.50Leonard M. Shulman 14.20 525.00 7,455.00Ronald S. Hodges 0.80 525.00 420.00
10,657.50Subtotal
78,287.50
Exhibit 1, Page 38
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 39
Fees by Month
9/1/2012Davis, Melissa R. 1.80 585.00Lohayza, Erlanna L. 18.60 3,627.00Shulman, Leonard M. 2.40 1,260.00
Subtotal 5,472.00
10/1/2012Davis, Melissa R. 6.60 2,145.00Hodges, Ronald S. 0.80 420.00Lohayza, Erlanna L. 0.70 136.50Shulman, Leonard M. 3.50 1,837.50
Subtotal 4,539.00
11/1/2012Davis, Melissa R. 4.90 1,592.50Lohayza, Erlanna L. 0.80 156.00Shulman, Leonard M. 15.40 8,085.00
Subtotal 9,833.50
12/1/2012Davis, Melissa R. 2.40 780.00Lohayza, Erlanna L. 0.40 78.00Shulman, Leonard M. 6.50 3,412.50
Subtotal 4,270.50
1/1/2013Davis, Melissa R. 1.60 600.00Lohayza, Erlanna L. 0.10 19.50Shulman, Leonard M. 4.60 2,415.00
Subtotal 3,034.50
2/1/2013Davis, Melissa R. 2.80 1,050.00Lohayza, Erlanna L. 0.20 39.00Shulman, Leonard M. 4.50 2,362.50
Exhibit 1, Page 39
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 40
Subtotal 3,451.50
3/1/2013Davis, Melissa R. 1.90 712.50Shulman, Leonard M. 2.00 1,050.00
Subtotal 1,762.50
4/1/2013Davis, Melissa R. 3.70 1,387.50Shulman, Leonard M. 3.60 1,890.00
Subtotal 3,277.50
5/1/2013Davis, Melissa R. 3.50 1,312.50Shulman, Leonard M. 20.80 10,920.00
Subtotal 12,232.50
6/1/2013Davis, Melissa R. 5.10 1,912.50Lohayza, Erlanna L. 0.30 58.50Shulman, Leonard M. 8.40 4,410.00
Subtotal 6,381.00
7/1/2013Davis, Melissa R. 5.60 2,100.00Shulman, Leonard M. 3.30 1,732.50
Subtotal 3,832.50
8/1/2013Davis, Melissa R. 10.30 3,862.50Kido, Rika M. 1.00 300.00Lohayza, Erlanna L. 11.40 2,223.00Shulman, Leonard M. 11.70 6,142.50
Subtotal 12,528.00
9/1/2013Clapp, Lorre E. 20.80 4,056.00Davis, Melissa R. 3.40 1,275.00
Exhibit 1, Page 40
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 41
Lohayza, Erlanna L. 0.70 136.50Shulman, Leonard M. 4.20 2,205.00
Subtotal 7,672.50
Total Fees 200.30 78,287.50
Exhibit 1, Page 41
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 42
Monthly Fees Task RecapDate Description AmountHours
09/2012**Case Administration** 0.40 130.00** Fee Application** 19.80 4,129.00**Fee and Employment Objections** 0.40 78.00**Plan and Disclosure Statement** 1.60 820.00**Litigation - 001** 0.60 315.00
Subtotal 5,472.00
10/2012**Asset Disposition** 1.00 425.00**Case Administration** 0.70 214.50** Fee Application** 5.40 1,830.00**Fee and Employment Objections** 1.60 707.00**Meeting of Creditors** 1.30 602.50**Plan and Disclosure Statement** 0.70 307.50**Trade Creditor Avoidance Litigation** 0.10 32.50**Litigation - 001** 0.80 420.00
Subtotal 4,539.00
11/2012**Asset Disposition** 11.10 5,247.50**Case Administration** 2.80 1,019.00** Fee Application** 0.10 19.50**Meeting of Creditors** 5.70 2,892.50**Plan and Disclosure Statement** 0.60 295.00**Litigation - 001** 0.80 360.00
Subtotal 9,833.50
12/2012**Asset Disposition** 7.40 3,585.00**Case Administration** 0.80 234.00** Fee Application** 0.20 39.00**Meeting of Creditors** 0.40 210.00**Plan and Disclosure Statement** 0.20 105.00**Litigation - 001** 0.30 97.50
Exhibit 1, Page 42
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 43
Subtotal 4,270.50
01/2013**Asset Disposition** 1.30 667.50**Case Administration** 1.50 634.50**Meeting of Creditors** 3.40 1,695.00**Litigation - 001** 0.10 37.50
Subtotal 3,034.50
02/2013**Asset Disposition** 2.50 1,312.50**Business Operations** 0.70 307.50**Case Administration** 0.80 264.00**Plan and Disclosure Statement** 0.70 367.50**Litigation - 001** 2.80 1,200.00
Subtotal 3,451.50
03/2013**Asset Disposition** 0.10 37.50**Case Administration** 0.60 225.00**Plan and Disclosure Statement** 0.70 352.50**Litigation - 001** 2.50 1,147.50
Subtotal 1,762.50
04/2013**Asset Disposition** 0.60 315.00**Case Administration** 1.20 540.00**Plan and Disclosure Statement** 4.50 1,987.50**Litigation - 001** 1.00 435.00
Subtotal 3,277.50
05/2013**Asset Disposition** 1.40 735.00**Case Administration** 1.10 472.50**Fee and Employment Objections** 0.50 247.50**Meeting of Creditors** 0.80 420.00**Plan and Disclosure Statement** 10.60 5,325.00**Insider Avoidance Litigation** 0.40 210.00**Litigation - 001** 9.50 4,822.50
Exhibit 1, Page 43
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 44
Subtotal 12,232.50
06/2013**Asset Disposition** 3.20 1,560.00**Business Operations** 0.50 187.50**Case Administration** 1.60 666.00**Meeting of Creditors** 1.70 862.50**Plan and Disclosure Statement** 5.10 2,272.50**Litigation - 001** 1.70 832.50
Subtotal 6,381.00
07/2013**Asset Disposition** 1.70 817.50**Case Administration** 1.40 615.00**Plan and Disclosure Statement** 4.80 1,935.00**Litigation - 001** 1.00 465.00
Subtotal 3,832.50
08/2013**Asset Disposition** 1.80 915.00**Case Administration** 4.80 1,707.00**Fee and Employment Objections** 0.80 375.00**Plan and Disclosure Statement** 26.40 9,306.00**Litigation - 001** 0.60 225.00
Subtotal 12,528.00
09/2013**Case Administration** 0.60 171.00** Fee Application** 22.10 4,471.50**Plan and Disclosure Statement** 5.60 2,730.00**Litigation - 001** 0.80 300.00
Subtotal 7,672.50
Total Fees 200.30 78,287.50
Exhibit 1, Page 44
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 45
Cost Recap by Task Code
16.00Attorney and Messenger service 511.08PACER charges 133.36Postage395.80Photocopy106.46Federal Express40.00Parking18.80Computer Research
Subtotal 1,221.50
Total Disbursements 1,221.50
Exhibit 1, Page 45
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 46
Monthly Cost Task RecapAmountDescriptionDate
09/2012
18.80Other Services9.36Pacer
8.00Parking86.60Photocopy25.65Postage
Subtotal 148.41
10/2012
16.00Attorney and Messenger Service81.88Federal Express
36.60Pacer16.00Parking70.20Photocopy15.60Postage
Subtotal 236.28
11/2012
19.80PacerSubtotal 19.80
12/2012
22.20PacerSubtotal 22.20
01/2013
55.80Pacer16.49Postage
Subtotal 72.29
02/2013
66.36Pacer5.06Postage
Subtotal 71.42
03/2013
Exhibit 1, Page 46
Shulman Hodges & Bastian LLP
Marc Asheghian September 26, 2013Re: In re Ezri Namvar/ 11 Creditor CommitteeI.D. 3985-000 - LMS
Invoice 70323Page 47
AmountDescriptionDate65.64Pacer1.84Postage
Subtotal 67.48
04/2013
20.16Pacer8.00Parking
55.90PostageSubtotal 84.06
05/2013
29.88Pacer8.00Parking
1.92PostageSubtotal 39.80
06/2013
27.24Pacer0.66Postage
Subtotal 27.90
07/2013
87.24PacerSubtotal 87.24
08/2013
24.58Federal Express50.28Pacer
164.20Photocopy6.60Postage
Subtotal 245.66
09/2013
20.52Pacer74.80Photocopy3.64Postage
Subtotal 98.96
1,221.50Total Costs
Exhibit 1, Page 47
EXHIBIT 2
Billing Records as Special Claims Counsel to the Trustee
September 26, 2013
R. Todd NeilsonChapter 11 for the Estate of Ezri Namvar2049 Century Park East, Suite 2525Los Angeles, CA 90067
ID: 3985-001 - LMSRe: Claims Work/Neilson-11TT
Invoice 70324
For Services Rendered Through September 25, 2013
Current Fees 96,505.50Current Costs 3,201.18
Fee RecapRate/Hour AmountHours
Erlanna L. Lohayza 9,457.5048.50 195.00ParalegalAnne Marie Vernon 1,435.008.20 175.00ParalegalLeonard M. Shulman 10,290.0019.60 525.00PartnerSteve P. Swartzell 997.505.70 175.00ParalegalRika M. Kido 3,325.0013.30 250.00Associate AttorneyRika M. Kido 43,680.00145.60 300.00Associate AttorneyMelissa R. Davis 3,445.0010.60 325.00Associate AttorneyMelissa R. Davis 8,925.0023.80 375.00Associate AttorneyMichelle Choi 663.003.40 195.00Associate AttorneyMichelle Choi 14,287.5063.50 225.00Associate Attorney
8105 Irvine Center Drive Suite 600 Irvine, California 92618 Telephone : 949/340-3400
Exhibit 2, Page 1
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 2
Fees Grouped by TaskDate Description AmountAtty Hours
**Claims Administration & Objections**
Telephone call from D. Haghani re objection to his late filed claim and our withdrawal of M&S Partnership's claim.
09/17/12 50.00RMK 0.20
Analysis of issues regarding oppositions filed to objections to late filed claims.
09/18/12 32.50MRD 0.10
Review and analyze opposition of creditor D. Haghani to claim objection for late filed claim.
09/19/12 75.00RMK 0.30
Review and analyze opposition of creditor S. Alyeshmerni to claim objection for late filed claim.
09/19/12 50.00RMK 0.20
Review and analyze opposition of creditor BMW Financial Services to claim objection for late filed claim.
09/20/12 75.00RMK 0.30
Review and analyze opposition of creditor BH Commercial to claim objection for late filed claim.
09/20/12 75.00RMK 0.30
Emails to U. Raanan and trustee re opposition filed to objections to late filed claims.
09/20/12 50.00RMK 0.20
Review and reply to email from U. Raanan re D. Haghani's opposition to trustee's objection to his late filed claim.
09/20/12 50.00RMK 0.20
Review and reply to email from U Raanan re S. Alyeshmerni's opposition to trustee's objection to her late filed claim.
09/20/12 25.00RMK 0.10
Review and reply to email from U. Raanan re BH Commercial Capital's opposition to trustee's objection to its late filed claim.
09/20/12 50.00RMK 0.20
Review and reply to email from U. Raanan re BMW's opposition to trustee's objection to its late filed claim.
09/20/12 25.00RMK 0.10
Review and analyze briefly oppositions filed to motions objecting to late filed claims; review comments from U. Ranaan re same.
09/20/12 130.00MRD 0.40
Review and analyze issues re oppositions to objections to late filed claims.09/21/12 100.00RMK 0.40Prepare instructions to R. Kido re reply to oppositions to claim objection motions re late filed claims; send e-mail to T. Neilson and U. Ranaan re same.
09/21/12 97.50MRD 0.30
Draft omnibus reply to oppositions filed to motion to disallow late filed claims.
09/24/12 195.00MRD 0.60
Review and revise reply to oppositions to objections to late filed claims.09/24/12 50.00RMK 0.20Review and analyze case law and statutory authority re requirements for informal proof of claim and whether motion for relief from stay can qualify.
09/25/12 130.00MRD 0.40
Review and revise reply to oppositions to motion to disallow late filed claims.
09/25/12 65.00MRD 0.20
Finalize reply to oppositions to motion to disallow late filed claims.09/26/12 65.00MRD 0.20Review and analyze motion to approve settlement with Wells Fargo; send 09/28/12 97.50MRD 0.30
Exhibit 2, Page 2
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 3
Date Description AmountAtty Hoursemail to committee re same.Telephone conference with U. Ranaan re questions on settlement with Wells Fargo.
09/28/12 32.50MRD 0.10
Prepare for hearing on objections to late filed and duplicate claims.10/02/12 97.50MRD 0.30Prepare for and attend hearings on motions for order disallowing late filed and duplicate claims, send email to client re same.
10/03/12 1,332.50MRD 4.10
Prepare order granting motion to disallow duplicate claims.10/03/12 162.50MRD 0.50Prepare order granting in part and denying in part motion to disallow late filed claims.
10/03/12 97.50MRD 0.30
Review and revise order approving motion to disallow duplicate claims.10/03/12 50.00RMK 0.20Review and revise order re motion to disallow late filed claims.10/03/12 50.00RMK 0.20Review and analyze issues re additional objections to clams.10/03/12 125.00RMK 0.50Telephone conference with E. Alyeshmerni re claim objection filed in Namco case.
10/08/12 32.50MRD 0.10
Telephone conference with E. Alyeshmerni re objection to claim filed in Namco case.
10/09/12 32.50MRD 0.10
Review and reply to email from N. Cowen re five claims filed on behalf of her family.
10/11/12 50.00RMK 0.20
Telephone conference with E. Alyeshmerni re outcome of objection to claim.
10/12/12 32.50MRD 0.10
Draft opposition to objection to claims of E. Alyeshmerni and S. Alyeshmerni.
10/16/12 130.00MRD 0.40
Review and analyze status and prepare instructions for completion of objections to secured claims.
10/19/12 210.00LMS 0.40
Review and analyze status of objections to be made to claims.10/19/12 32.50MRD 0.10Review and analysis of issues re additional objections to claims and work on line of attack for proceeding on the estate's objections.
10/22/12 100.00RMK 0.40
Discuss with R. Kido re objections to claims with one line guarantees.10/22/12 32.50MRD 0.10Review and revise opposition to objection to claims of Alyeshmerni.10/24/12 162.50MRD 0.50Review and analyze proof of claims for claims with one-line guaranties by the debtor; prepare chart re same.
10/28/12 350.00RMK 1.40
Review and analyze correspondence from D. White re correct address for claimant; respond re same.
10/31/12 32.50MRD 0.10
Review mail (Entered Order Granting Motions and Disallowing Claims) addressed to Ernesto and Socorro Vasquez and returned as undeliverable; update master mailing matrix for Rule 2002 notices re same.
11/07/12 19.50ELL 0.10
Review and analyze email from A. Tehran re proper creditor address.11/07/12 32.50MRD 0.10Review and analyze status of completing certain claim objections; prepare instructions.
11/07/12 210.00LMS 0.40
Review and analyze objections to be filed to wrongly classified claims.11/07/12 32.50MRD 0.10Prepare email to A. Tehan re change of address in Namvar case. 11/08/12 32.50MRD 0.10
Exhibit 2, Page 3
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 4
Date Description AmountAtty HoursPrepare communication with D. White re issues with service of documents.
11/15/12 32.50MRD 0.10
Telephone conference with M. Covey re status of case.11/15/12 32.50MRD 0.10Prepare weekly updates to unsecured creditors website.11/29/12 32.50MRD 0.10Email to and from U. Ranaan re status of claims objections and possible objections to one line guarantee claims.
12/06/12 32.50MRD 0.10
Review and analysis of secured claims reviewed and pulled by trustee's financial advisors.
12/13/12 700.00RMK 2.80
Review and analyze case law and statutory authorities re requirements for payment of accrual of interest on claims filed against the estate.
12/13/12 350.00RMK 1.40
Work on strategies for objecting to secured claims; update chart re same.12/13/12 450.00RMK 1.80Analysis of issues related to claims asserted for usurious interest and advise R. Kido re same.
12/13/12 39.00ELL 0.20
Review and analyze Mariana Jalil and Ezra Denis priority claim; determine grounds for objection to priority status.
12/13/12 253.50MC 1.30
Draft objection as to Marian Jalil priority claim.12/13/12 409.50MC 2.10Review and analyze alleged secured claims for objection; send correspondence to U. Ranaan.
12/13/12 162.50MRD 0.50
Review and analysis of interest included on proof of claims for secured claims, work on strategies for objecting to same.
12/14/12 425.00RMK 1.70
Review and analyze status of objections to claims.12/19/12 32.50MRD 0.10Review and analysis of case issues and work on line of attack for proceeding on the estate's claims.
01/03/13 90.00RMK 0.30
Review and revise chart re objections to secured claims in preparation for conference call.
01/04/13 240.00RMK 0.80
Conference call with U. Raanan re issues re objections to secured claims and review of chart re same.
01/04/13 150.00RMK 0.50
Review and analyze secured claims identified as needing to be objected to to determine whether additional documents are needed and that guaranties were executed concurrently with the secured note by the debtor.
01/04/13 420.00RMK 1.40
Prepare for and telephone conference with U. Ranaan re objections to secured claims to file.
01/04/13 225.00MRD 0.60
Draft Objection to Priority claims 27 & 63.01/09/13 202.50MC 0.90Draft communication to E. Held re question re interest accrual on objections to secured claims.
01/10/13 30.00RMK 0.10
Analysis of issues re claims administration.01/10/13 19.50ELL 0.10Draft priority claim objections and accompanying declaration.01/10/13 540.00MC 2.40Investigate status of objections to claims.01/10/13 75.00MRD 0.20Overview of disputed claims and objections needed.01/11/13 39.00ELL 0.20Review and revise motion for order disallowing certain priority claims.01/11/13 75.00MRD 0.20
Exhibit 2, Page 4
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 5
Date Description AmountAtty HoursReview and revise pleadings objecting to priority claims of Jalil and Denis01/14/13 315.00LMS 0.60Review and analyze email from U. Ranaan re additional objections and issues re claims.
01/14/13 120.00RMK 0.40
Review and analyze U. Raanan's comments on draft objection to priority claims; review and revise appropriate changes to background facts.
01/14/13 67.50MC 0.30
Review ECF email correspondence re filing of Proof of Claim by Midland First Bank (including 27 exhibits); access and obtain Proof of Claim and initial review of same; update the claims tracking chart and the service list for Federal Rule of Bankruptcy Procedure 2002 notices regarding same.
01/14/13 39.00ELL 0.20
Telephone conference with M. Cohen re status of case and sale of properties.
01/14/13 37.50MRD 0.10
Prepare email to T. Neilson re draft objection to certain priority claims and review suggested changes.
01/14/13 75.00MRD 0.20
Review email from U. Raanan re additional objectionable/disputed claims and analysis of issues related thereto.
01/14/13 19.50ELL 0.10
Review and analyze U. Raanan's comments regarding priority objections; made appropriate adoptions to claims and argument section.
01/14/13 90.00MC 0.40
Review and analyze correspondence and documents from U. Ranaan re next set of claims objections to be filed.
01/14/13 37.50MRD 0.10
Finalize draft priority objections; send to client for review.01/14/13 45.00MC 0.20Review and revise correspondence to B. Baradaran re additional documentation needed for Virgil Avenue Properties claim.
01/15/13 30.00RMK 0.10
Review and revise correspondence to K. Newman re additional documentation needed for Inland Mortgage Capital Corporation proof of claim.
01/15/13 30.00RMK 0.10
Review and revise correspondence to G. Salvato re additional documentation needed for Haroon Moossai proof of claim.
01/15/13 30.00RMK 0.10
Review and analyze email from U. Raanan re additional claim objections and chart re same.
01/15/13 60.00RMK 0.20
Review letters to send to secured creditors re additional information needed to support claims.
01/15/13 37.50MRD 0.10
Review and revise correspondence to O. Razi re additional documentation needed in support of his proof of claim claim.
01/15/13 30.00RMK 0.10
Review and revise correspondence to S. Montgomery re additional documentation needed in support of Separzadeh Revocable Trust's proof of claim claim.
01/15/13 30.00RMK 0.10
Review and revise correspondence to S. Montgomery re additional documentation needed in support of Jacob and Soraya Separzadeh Trust's proof of claim claim.
01/15/13 30.00RMK 0.10
Review and revise correspondence to S. Montgomery re additional documentation needed in support of Mouris and Diana Separzadeh Trust's proof of claim claim.
01/15/13 30.00RMK 0.10
Exhibit 2, Page 5
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 6
Date Description AmountAtty HoursBrief review of claim filed by Inland Mortgage Capital Corporation, Omid Razi, Haroon Moosai, The John and Katrin Separzadeh Revocable Trust, The Jacob and Soraya Separzadeh Trust, The Mouris Separzadeh Trust and Virgil Avenue Properties, LLC and comments related to possible objections; draft correspondence to each claimant requesting documentation in support of respective claim.
01/15/13 487.50ELL 2.50
Review and analyze new assignment of additional claims work; prepare comments and instructions.
01/16/13 315.00LMS 0.60
Provide instructions to R. Kido and M. Choi re letters to claimants for additional information.
01/16/13 37.50MRD 0.10
Review and analyze chart prepared by Trustee's general counsel re additional claims to object to and/or request additional documentation about.
01/16/13 210.00RMK 0.70
Draft communication to U. Raanan re correspondence to claimants for additional documents/information.
01/16/13 30.00RMK 0.10
Review and analyze chart of (over 20) secured claims for objections prepared by U. Raanan; review specified filed claims and all back up documentation in preparation for drafting objection to claims on grounds that debtor did not personally guarantee such debts.
01/16/13 427.50MC 1.90
Review ECF email correspondence re filing of amended Proof of Claim by Franchise Tax Board; access and obtain Proof of Claim and initial review of same; update the claims tracking chart and the service list for Federal Rule of Bankruptcy Procedure 2002 notices regarding same.
01/16/13 19.50ELL 0.10
Review ECF email and obtain the Notice of Withdrawal of Claim No. 118 filed by the Los Angeles County Metropolitan Transportation Authority and Claim No. 119 filed by the Amended and Restated Kamran and Atoosa Benji 1993 Trust; brief review of same and update electronic case file.
01/16/13 39.00ELL 0.20
Overview of chart received from U. Raanan re additional disputed and objectionable claims and determine manner in which to proceed.
01/16/13 39.00ELL 0.20
Continue to update chart of secured claims for objections and analyze basis of claim in preparation for motion to object to secured claims (corporate debts with no personal guarantee by debtor).
01/17/13 202.50MC 0.90
Continue drafting First Omnibus Motion Objection as to Claim No. 24.01/17/13 135.00MC 0.60Draft First Omnibus Motion Objection as to facts and basis for objections to Claim Nos. 7 and 10.
01/17/13 247.50MC 1.10
Emails to U. Raanan re draft letters to claimants requesting additional documentation.
01/18/13 30.00RMK 0.10
Review and analysis of claim filed by O. Razi (#58) and draft correspondence to O. Razi re documentation needed and proof of security interest in Debtor's assets.
01/21/13 78.00ELL 0.40
Review and analysis of claim filed by Virgil Avenue Properties, LLC (#201); identify documentation needed in support of claim and draft
01/21/13 78.00ELL 0.40
Exhibit 2, Page 6
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 7
Date Description AmountAtty Hourscorrespondence to B. Baradaran re proof of security interest in Debtor's assets. Review and analysis of claim filed by Haroon Moosai (Moosai Trust) (#78) and draft correspondence to G. Salvato re documentation needed to support a security interest in Debtor's assets.
01/21/13 78.00ELL 0.40
Review and analysis of claim filed by Inland Mortgage Capital (#55) and draft correspondence to K. Newman re documentation needed in support of claim and the calculation of interest, default interest and late charges.
01/21/13 78.00ELL 0.40
Review and analysis of claim filed by The John and Katrin Separzadeh Revocable Trust (#126) and draft correspondence to S. Montgomery re documentation needed to support of security interest in Debtor's assets.
01/21/13 78.00ELL 0.40
Review and analysis of claim filed by The Jacob & Soraya Separzadeh Trust (#127) and draft correspondence to S. Montgomery re documentation needed to support of security interest in Debtor's assets.
01/21/13 78.00ELL 0.40
Review and analysis of claim filed by The Mouris Separzadeh Trust (#128) and draft correspondence to S. Montgomery re documentation needed to support of security interest in Debtor's assets.
01/21/13 78.00ELL 0.40
Draft R. Todd Nielson's declaration in support of first omnibus objection to secured claims.
01/21/13 135.00MC 0.60
Begin drafting background section on second omnibus objection to secured claims.
01/21/13 247.50MC 1.10
Review and revise argument section of first omnibus objection to secured claims.
01/22/13 120.00RMK 0.40
Review and finalize correspondence to S. Montgomery re Separzadeh Revocable Trusts' proof of claims.
01/22/13 60.00RMK 0.20
Review and finalize correspondence to O. Razi re his secured proof of claim.
01/22/13 30.00RMK 0.10
Review and finalize correspondence to B. Baradaran re Virgil Avenue Properties' secured proof of claim.
01/22/13 30.00RMK 0.10
Review and finalize correspondence to G. Salvato re H. Moossai's secured proof of claim.
01/22/13 30.00RMK 0.10
Review and finalize correspondence to K. Newman re Inland Mortgage Capital's secured proof of claim.
01/22/13 30.00RMK 0.10
Revise and prepare for final the correspondence to O. Razi (#58), B. Baradaran (#201 by Virgil Avenue Properties, LLC), G. Salvato (#78 by Haroon Moosai - Moosai Trust), K. Newman (#55 by Inland Mortgage Capital), S. Montgomery (#126 by The John and Katrin Separzadeh Revocable Trust), S. Montgomery (#127 by The Jacob & Soraya Separzadeh Trust), and S. Montgomery (#128 by The Mouris Separzadeh Trust).
01/22/13 175.50ELL 0.90
Review and analysis of claim filed by Sorea Soofer (#30) and draft correspondence to S. Soofer re documentation needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by 87th Peoria, LLC (#39) and draft 01/22/13 78.00ELL 0.40
Exhibit 2, Page 7
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 8
Date Description AmountAtty Hourscorrespondence to E. Afaghi re 1031 Exchange against Namco and documentation needed to support a claim against the Debtor.Review and analysis of claim filed by Holly Getlin, Gordon Karsin and Ronald Karsin (#49) and draft correspondence to B. King re documentation and evidence needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Holly Getlin, as Trustee of the Irene Karsin Family Trust (#50) and draft correspondence to B. King re documentation and evidence needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Emanuel Aframian (#52) and draft correspondence to N. Tabibi re documentation and evidence needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Kayvan Aframian (#53) and draft correspondence to N. Tabibi re documentation and evidence needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Behrouz Aframian and Jaclin Aframian, as Trustees of the Aframian Family Trust UTD dated July 1, 1999 (#54) and draft correspondence to N. Tabibi re documentation and evidence needed in support of claim.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Maryam Pirian, Manoucher Pirian, Mehrdad Naim, Joseph Pirian and Nahal Pirian (#80) and draft correspondence to G. Salvato re documentation needed in support of claim which was guaranteed by the Debtor.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Joseph Pirian (#81) and draft correspondence to G. Salvato re documentation needed in support of claim which was guaranteed by the Debtor.
01/22/13 78.00ELL 0.40
Review and analysis of claim filed by Nahal Pirian (#82) and draft correspondence to G. Salvato re documentation needed in support of claim which was guaranteed by the Debtor.
01/22/13 78.00ELL 0.40
Investigate status of motion to disallow certain secured claims.01/22/13 37.50MRD 0.10Review and revise correspondence to G. Salvato re additional documentation needed for N. Pirian's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to G. Salvato re additional documentation needed for J. Pirian's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to N. Tabibi re additional documentation needed for Aframian Family Trust's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to N. Tabibi re additional documentation needed for K. Aframian's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to N. Tabibi re additional documentation needed for E. Aframian's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to G. Salvato re additional documentation needed for Maryam Pirian, Manoucher Pirian, Mehrdad Naim, Joseph Pirian and Nahal Pirian's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to S. Soofer re additional 01/23/13 60.00RMK 0.20
Exhibit 2, Page 8
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 9
Date Description AmountAtty Hoursdocumentation needed for her proof of claim.Review and revise correspondence to E. Afaghi at 87th Peoria, LLC re additional documentation needed for its proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to B. King re additional documentation needed for H. Getline, Gordon Karsin and Ronald Karsin's proof of claim.
01/23/13 60.00RMK 0.20
Review and revise correspondence to B. King re additional documentation needed for the Irene Karsin Family Trust's proof of claim.
01/23/13 60.00RMK 0.20
Review and analyze Sunnylane Partners, LLC's proof of claim and related adversary proceeding against the Debtor.
01/23/13 120.00RMK 0.40
Draft communication to U. Ranaan re Sunnylane Partners, LLC's proof of claim and related adversary proceeding against the Debtor.
01/23/13 60.00RMK 0.20
Review and reply to email from U. Rannan re Sunnylane Partners, LLC's stipulated judgment with the debtor and how to handle their proof of claim.
01/23/13 60.00RMK 0.20
Revise and prepare for final the correspondence to Sorea Soofer (#30), E. Afaghi (#39 by 87th Peoria, LLC), B. King (#49 by Holly Getlin, Gordon Karsin and Ronald Karsin), B. King (#50 by Holly Getlin, as Trustee of the Irene Karsin Family Trust #50), N. Tabibi (#52 by Emanuel Aframian), N. Tabibi (#53 by Kayvan Aframian), N. Tabibi (#54 by Behrouz Aframian and Jaclin Aframian, as Trustees of the Aframian Family Trust UTD dated July 1, 1999), G. Salvato (#80 by Maryam Pirian, Manoucher Pirian, Mehrdad Naim, Joseph Pirian and Nahal Pirian), G. Salvato (#81 by Joseph Pirian) and G. Salvato (#82 by Nahal Pirian).
01/23/13 195.00ELL 1.00
Review Proof of Claim filed by Sunnylane Partners, LLC and investigate outcome of adversary action filed by Sunnylane Partners, LLC against the Debtor; obtain copy of Judgment and prepare memo to R. Kido re same.
01/23/13 58.50ELL 0.30
Review and analysis of claim filed by Maryam Selki (#92) and draft correspondence to D. Selki re promissory note needed related to transaction set forth in Guarantee Agreement signed by the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Sam Selki (#93) and draft correspondence to D. Selki re promissory note needed related to transaction set forth in Guarantee Agreement signed by the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by David Selki (#94) and draft correspondence to D. Selki re promissory note needed related to transaction set forth in Guarantee Agreement signed by the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Saeed Cohen (#107) and draft correspondence to H. Mark Mersel re documentation in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Boyle Avenue LLC (#140) and draft correspondence to S. Montgomery re documentation needed in support of a fraud claim against the Debtor.
01/23/13 78.00ELL 0.40
Exhibit 2, Page 9
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 10
Date Description AmountAtty HoursReview and analysis of claim filed by Robhana, Inc. and draft correspondence to J. Kries and R. Hanasab re documentation in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by 26 Etehad, LLC (#151) and draft correspondence to R. Stonerock re documentation needed in support of a fraud claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by M&Y Management, Inc. (#147); access Pacer and confirm only face page of claim filed and confirm amount; draft correspondence to J. Kries re issues related to docketing of claim and documentation in support of a claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Ramin Gabayan (#157) and draft correspondence to R. Gabayan re documentation needed in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Sion Khadavi (#173) and draft correspondence to S. Khadavi re documentation needed in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Brenden Broumand (#161) and draft correspondence to B. Broumand re documentation needed in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Berrokhim Family Trust (#165) and draft correspondence to B. Berrokhim re documentation needed in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analysis of claim filed by Puritan International Inc. (#164) and draft correspondence to Chief Financial Officer re documentation needed in support of claim against the Debtor.
01/23/13 78.00ELL 0.40
Review and analyze supporting documentary evidence attached to claims No. 117, 126, and 127 in preparation of drafting objection to claims; identify deficiency of claim and formulate argument and basis for objection.
01/23/13 495.00MC 2.20
Continue drafting second omnibus objection to secured claims No. 117, 126, and 127.
01/23/13 630.00MC 2.80
Review and revise correspondence to D. Selki re additional documentation needed for the analysis of M. Selki's proof of claim (POC 92).
01/24/13 60.00RMK 0.20
Review and revise correspondence to D. Selki re additional documentation needed for the analysis of S. Selki's proof of claim (POC 93).
01/24/13 60.00RMK 0.20
Review and revise correspondence to D. Selki re additional documentation needed for the analysis of D. Selki's proof of claim (POC 94).
01/24/13 60.00RMK 0.20
Review and revise correspondence to H. Mersel re additional documentation needed for the analysis of S. Cohen's proof of claim (POC 107).
01/24/13 60.00RMK 0.20
Exhibit 2, Page 10
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 11
Date Description AmountAtty HoursReview and revise correspondence to S. Montgomery re additional documentation needed for the analysis of Boyle Avenue LLC's proof of claim (POC 140).
01/24/13 60.00RMK 0.20
Review and revise correspondence to J. Kries and R. Hanasab re additional documentation needed for the analysis of Robhana, Inc.'s proof of claim (POC 145).
01/24/13 60.00RMK 0.20
Review and revise correspondence to J. Kries re additional documentation needed for M&Y Management Inc.'s proof of claim (POC 147).
01/24/13 60.00RMK 0.20
Review and revise correspondence to R. Stonerock re additional documentation needed for the analysis of 26 Etehad, LLC's proof of claim (POC 151).
01/24/13 60.00RMK 0.20
Review and revise correspondence to R. Gabayan re additional documentation needed for the analysis of his proof of claim (POC 157).
01/24/13 60.00RMK 0.20
Review and revise correspondence to B. Broumand re additional documentation needed for the analysis of his proof of claim (POC 161).
01/24/13 60.00RMK 0.20
Review and revise correspondence to Puritan International, Inc. re additional documentation needed for the analysis of its proof of claim (POC 164).
01/24/13 60.00RMK 0.20
Review and revise correspondence to B. Berookhim re additional documentation needed for the analysis of the Berookhim Family Trust's proof of claim (POC 165).
01/24/13 60.00RMK 0.20
Review and revise correspondence to M. Torbati re additional documentation needed for the analysis of her proof of claim (POC 166).
01/24/13 60.00RMK 0.20
Review and revise correspondence to B. Nahai re additional documentation needed for the analysis of B. Nahai's proof of claim (POC 171).
01/24/13 60.00RMK 0.20
Review and revise correspondence to S. Khadavi re additional documentation needed for the analysis of his proof of claim (POC 173).
01/24/13 60.00RMK 0.20
Review and revise correspondence to E. Negari re additional documentation needed for the analysis of the MMN Family Trust's proof of claim (POC 189).
01/24/13 60.00RMK 0.20
Review and revise correspondence to S. Tabibian re additional documentation needed for the analysis of Princeton Holdings, LLC's proof of claim (POC 197).
01/24/13 60.00RMK 0.20
Review and revise correspondence to B. Nahai re additional documentation needed for the analysis of T. Nahai's proof of claim (POC 170).
01/24/13 60.00RMK 0.20
Review and analysis of claim filed by Melody Torbati and draft correspondence to M. Torbati re documentation needed in support of claim against the Debtor.
01/24/13 78.00ELL 0.40
Review and analysis of claim filed by The MMN Family Trust (#189) and draft correspondence to E. Negari re documentation needed in support of
01/24/13 78.00ELL 0.40
Exhibit 2, Page 11
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 12
Date Description AmountAtty Hoursclaim against the Debtor.Review and analysis of claim filed by Princeton Holdings, LLC (#197) and draft correspondence to S. Tabibian re documentation needed in support of claim against the Debtor.
01/24/13 78.00ELL 0.40
Review and analysis of claim filed by Tara Nahai (#170) and draft correspondence to B. Nahai re documentation needed in support of claim against the Debtor.
01/24/13 78.00ELL 0.40
Review and analysis of claim filed by Angela Nahai (#171) and draft correspondence to B. Nahai re documentation needed in support of claim against the Debtor.
01/24/13 78.00ELL 0.40
Revise and prepare for final the correspondence to R. Stonerock (#151 by 26 Etehad, LLC), B. Berrokhim (#165 by Berrokhim Family Trust), S. Montgomery (#140 by Boyle Avenue LLC), B. Broumand (#161 by B. Broumand), H. Mark Mersel (#107 by Saeed Cohen), R. Gabayan (#157), S. Khadavi (#173), J. Kries (#147 by M&Y Management, Inc.), B. Nahai (#170 by Tara Nahai), B. Nahai (#171 by Angela Nahai), S. Tabibian (#197 by Princeton Holdings, LLC), CFO of Puritan International, Inc. (#164), J. Kries and R. Hanasab (#145 by Robhana, Inc.), D. Selki (#92 by Maryam Selki), D. Selki (#93 by Sam Selki), D. Selki (#94), E. Negari (#189 by The MMN Family Trust) and M. Torbati (#166).
01/24/13 253.50ELL 1.30
Review and analyze supporting documentation to secured claims as against Claim No. 135.
01/24/13 67.50MC 0.30
Review and analyze supporting documentation to secured claims as against Claim No. 127.
01/24/13 135.00MC 0.60
Continue drafting second omnibus objection to secured claims as against Claims No. 127, 128 and 135.
01/24/13 360.00MC 1.60
Review and analyze supporting documentation to secured claims as against Claim No. 128.
01/24/13 90.00MC 0.40
Review and reply to email from S. Montgomery re Separzadeh claims.01/25/13 30.00RMK 0.10Review and analyze issues and documents re resolving Starpoint and related entity claims; prepare instructions for evaluation.
01/25/13 210.00LMS 0.40
Review and analyze email from D. Meadows re Virgil Avenue Properties LLC claim.
01/25/13 30.00RMK 0.10
Review and analyze response from counsel re request for documents re Claims No. 126, 127 and 128; revise and analyze second omnibus motion as to objections to these claims.
01/25/13 45.00MC 0.20
Draft declaration of R. Todd Nielson in support of First Omnibus Objection to Secured Claims.
01/25/13 157.50MC 0.70
Draft declaration of R. Todd Nielson in support of Second Omnibus Objection to Secured Claims.
01/25/13 90.00MC 0.40
Draft background section and argument analysis of Second Omnibus Objection to Secured Claims as to Claim No. 135 as improperly asserted
01/25/13 157.50MC 0.70
Exhibit 2, Page 12
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 13
Date Description AmountAtty Hoursagainst debtor.Analysis of issues related to potential objections to claims filed by the Separzadehs and their trusts and advise M. Cho re same.
01/25/13 19.50ELL 0.10
Review and analyze supporting documentation to Claim No. 135 in preparation for drafting objection to claim.
01/25/13 157.50MC 0.70
Review and analyze supporting documentation as to Claim No. 144 in preparation for drafting claim objection re same.
01/25/13 157.50MC 0.70
Draft background section and argument analysis as to Claims No. 136 and 137 as improperly asserted against the debtor in Second Omnibus Objection to Claims.
01/25/13 202.50MC 0.90
Review and analyze supporting documentation to Claims No. 136 and 137 in preparation for drafting claim objection re same.
01/25/13 67.50MC 0.30
Begin drafting Third Omnibus Objection to secured claims as to claims No. 144, 152, 158, 163, 197, and 23.
01/25/13 292.50MC 1.30
Continue drafting third omnibus motion objecting to claims as to claim no. 163.
01/27/13 90.00MC 0.40
Continue drafting third omnibus motion objecting to claims as to claim no. 158.
01/27/13 90.00MC 0.40
Draft communication to U. Raanan re response from D. Meadows re Virgil Avenue Properties' proof of claim.
01/28/13 30.00RMK 0.10
Telephone call to S. Montgomery re Separzadeh claims and additional documentation needed in the Boyle Avenue claim.
01/28/13 30.00RMK 0.10
Telephone call to G. Salvato re additional information/documentation needed in the Separzadehs' claims.
01/28/13 30.00RMK 0.10
Review and reply to email from U. Raanan re response from D. Meadows re Virgil Avenue Properties' proof of claim.
01/28/13 30.00RMK 0.10
Review and reply to email from D. Meadows re Virgil Avenue Properties' proof of claim.
01/28/13 60.00RMK 0.20
Further instructions on resolving Virgil claim.01/28/13 210.00LMS 0.40Review and revise trustee's first omnibus motion objection as to claim no. 34.
01/28/13 67.50MC 0.30
Review and revise trustee's first omnibus motion objection as to claim no. 35.
01/28/13 67.50MC 0.30
Review and revise trustee's first omnibus motion objection as to claim no. 36.
01/28/13 67.50MC 0.30
Review and revise trustee's first omnibus motion objection as to claim no. 95.
01/28/13 90.00MC 0.40
Review and revise trustee's declaration in support of his first omnibus motion objection as to claim no. 7, 10, 24, 34, 35, 36, 95, 96, 98.
01/28/13 67.50MC 0.30
Email correspondence with R. T. Neilson re priority objections.01/28/13 45.00MC 0.20Review and revise trustee's first omnibus motion objection as to claim no. 01/28/13 90.00MC 0.40
Exhibit 2, Page 13
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 14
Date Description AmountAtty Hours7.Review and revise trustee's first omnibus motion objection as to claim no. 10.
01/28/13 90.00MC 0.40
Review and revise trustee's first omnibus motion objection as to claim no. 24.
01/28/13 67.50MC 0.30
Review and revise trustee's first omnibus motion objection as to claim no. 96.
01/28/13 90.00MC 0.40
Review and revise trustee's first omnibus motion objection as to claim no. 98.
01/28/13 67.50MC 0.30
Review and analyze claims register in docket for claim objection.01/28/13 90.00MC 0.40Review and reply to email from M. Pirian re documents in support of her claim against the estate.
01/29/13 120.00RMK 0.40
Review and analyze issues re additional documents requested for evaluation of Robhana, Inc.'s proof of claim.
01/29/13 60.00RMK 0.20
Review and analyze issues re additional documents requested for evaluation of M&Y Management's proof of claim.
01/29/13 60.00RMK 0.20
Review and revise priority claims objection as to claims no. 27 and 63.01/29/13 45.00MC 0.20Email correspondences with R. T. Neilson re priority claims objection.01/29/13 45.00MC 0.20Brief review of documentation provided by M. Pirian in support of alleged claim against the Debtor.
01/29/13 19.50ELL 0.10
Review and revise Trustee's Second Omnibus Claim Objection Motion as to claims no. 117, 136, 137.
01/30/13 270.00MC 1.20
Review and analyze Robhana proof of claim (145) in preparation for telephone call with J. Kries.
01/31/13 60.00RMK 0.20
Review and analyze M&Y Management proof of claim (147) in preparation for telephone call with J. Kries.
01/31/13 30.00RMK 0.10
Telephone call to J. Kries re supporting documents needed in support of Robhana proof of claim (145) and M&Y Management proof of claim (147).
01/31/13 30.00RMK 0.10
Telephone call from J. Kries re supporting documents needed in support of Robhana proof of claim (145) and M&Y Management proof of claim (147).
01/31/13 30.00RMK 0.10
Review and analyze The John and Katrin Separzadeh Revocable Trust's proof of claim (126) in preparation for telephone call with G. Salvato.
01/31/13 60.00RMK 0.20
Review and analyze The Jacob Separzadeh and Soraya Separzadeh Trust's proof of claim (127) in preparation for telephone call with G. Salvato.
01/31/13 60.00RMK 0.20
Review and analyze The Mouris and Diana Separzadeh Trust's proof of claim (128) in preparation for telephone call with G. Salvato.
01/31/13 60.00RMK 0.20
Review and analyze M. Pirian, et al. proof of claim (80) in preparation for telephone call with G. Salvato.
01/31/13 30.00RMK 0.10
Exhibit 2, Page 14
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 15
Date Description AmountAtty HoursReview and analyze Joseph Pirian proof of claim (81) in preparation for telephone call with G. Salvato.
01/31/13 30.00RMK 0.10
Review and analyze Nahal Pirian proof of claim (82) in preparation for telephone call with G. Salvato.
01/31/13 30.00RMK 0.10
Review and analyze H. Moossai proof of claim (78) in preparation for telephone call with G. Salvato.
01/31/13 30.00RMK 0.10
Telephone call to G. Salvato re Separzadeh claims (126, 127, 128), Pirian claims (80, 81, 82) and Moossai claim (78).
01/31/13 30.00RMK 0.10
Draft communication to J. Kries re supporting documents needed in support of Robhana proof of claim (145) and M&Y Management proof of claim (147).
01/31/13 120.00RMK 0.40
Review and analyze Maryam Selki proof of claim (92) in preparation for telephone call with D. Selki.
01/31/13 60.00RMK 0.20
Review and analyze Sam Selki proof of claim (93) in preparation for telephone call with D. Selki.
01/31/13 30.00RMK 0.10
Review and analyze David Selki proof of claim (94) in preparation for telephone call with D. Selki.
01/31/13 30.00RMK 0.10
Telephone call to R. Hanasab re Robhana claim (145) and M&Y claim (147) and supporting documents/additional information needed for both.
01/31/13 90.00RMK 0.30
Telephone call to D. Selki re M. Selki claim (92), D. Selki claim (93), S. Selki claim (94) and supporting documentation needed re same.
01/31/13 30.00RMK 0.10
Review and analyze issues re effect of settlement of Selki claims in Namco on Namvar claims of D. Selki, M. Selki and S. Selki.
01/31/13 90.00RMK 0.30
Review and analyze facsimile from I. Brookim re documents in support of Puritan International, Inc.'s proof of claim (164).
01/31/13 60.00RMK 0.20
Review and analyze facsimile from B. Berookhim re the Berookhim Family Trust proof of claim (165) and supporting documents requested re same.
01/31/13 90.00RMK 0.30
Review and analyze settlement motion filed in Namco case for the settlement of the Selki claims.
01/31/13 120.00RMK 0.40
Review and analyze email from R. Hanasab re Robhana and M&Y Management claims filed in this case and the Namco case.
01/31/13 180.00RMK 0.60
Review and analyze issues re claims needing additional documents to support claimed amount and/or claim against the debtor.
01/31/13 180.00RMK 0.60
Continue drafting third omnibus motion objecting to claims as to claim no. 231.
01/31/13 90.00MC 0.40
Draft argument section of third omnibus motion objection to claims and supporting declaration of R. T. Neilson.
01/31/13 90.00MC 0.40
Brief review of documentation provided by Berookhim Family Trust in support of his alleged claim against the Debtor.
01/31/13 19.50ELL 0.10
Brief review of documentation provided by Puritan International in support of alleged claim against the Debtor.
01/31/13 19.50ELL 0.10
Exhibit 2, Page 15
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 16
Date Description AmountAtty HoursReview and analyze proof of claim no. 158 in preparation for drafting claim objection.
01/31/13 22.50MC 0.10
Review and analyze proof of claim no. 152 in preparation for drafting claim objection.
01/31/13 22.50MC 0.10
Continue drafting third omnibus motion objecting to claims as to claim no. 197.
01/31/13 67.50MC 0.30
Review and approve for filing new set of objs to claims.01/31/13 157.50LMS 0.30Provide instructions to R. Kido re further information on certain claims.01/31/13 75.00MRD 0.20Review and analyze proof of claim no. 163 in preparation for drafting claim objection.
01/31/13 22.50MC 0.10
Review and analyze proof of claim no. 231 in preparation for drafting claim objection.
01/31/13 67.50MC 0.30
Telephone conference with M. Cohen re status of case.01/31/13 37.50MRD 0.10Continue drafting third omnibus motion objecting to claims as to claim no. 152.
01/31/13 90.00MC 0.40
Continue drafting third omnibus motion objecting to claim 144.01/31/13 360.00MC 1.60Draft correspondence to B. Berookhim re facsimile received and additional documents needed in support of claim against the debtor.
02/01/13 120.00RMK 0.40
Telephone call from I. Brookim re Berookhim Family Trust's proof of claim (165) and Puritan International, Inc.'s proof of claim (164) and request for supporting documents re same.
02/01/13 90.00RMK 0.30
Review and analyze issues re omnibus objections to claims which are not the obligation of the debtor.
02/01/13 120.00RMK 0.40
Finalize first, second, and third omnibus claim objections based on notes by Namco, not guaranteed by debtor.
02/01/13 135.00MC 0.60
Review and analyze responses of creditors to requests for additional documents.
02/01/13 37.50MRD 0.10
Prepare email to U. Raanan and T. Neilson re correspondence sent to claimants requesting documents in support of claims against the Debtor.
02/01/13 19.50ELL 0.10
Review and analysis of claim filed by Gardner Family Trust Dated 1984 (#221) and draft correspondence to A. Gardner re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Review and analysis of claim filed by David Haghani (#232) and draft correspondence to D. Haghani re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Review and analysis of claim filed by Crawford Living Trust Dated September 23, 1983 (#187) and draft correspondence to S. Fainsbert re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Review and analysis of claim filed by Fred Behfarin (#206) and draft correspondence to F. Behfarin re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Analysis of issues related to claim #172 filed by Nahid Nazarian MD that 02/01/13 19.50ELL 0.10
Exhibit 2, Page 16
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 17
Date Description AmountAtty Hourswas filed in the wrong case.Review and analysis of claim filed by SRF Investment LLC (#116) and draft correspondence to S. Montgomery re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Review and analysis of claim filed by Ernesto and Socorro Vasquez Claim (#178) and draft correspondence to S. Fainsbert re documentation needed in support of claim.
02/01/13 78.00ELL 0.40
Review and revise first omnibus objection to claims on the grounds that the objected claims are not an obligation of the debtor.
02/04/13 210.00RMK 0.70
Review and revise second omnibus objection to claims on the grounds that the objected claims are not an obligation of the debtor.
02/04/13 120.00RMK 0.40
Review and revise third omnibus objection to claims on the grounds that the objected claims are not an obligation of the debtor.
02/04/13 120.00RMK 0.40
Review and analyze issues re objections to claims which no not assert an obligation of the debtor.
02/04/13 120.00RMK 0.40
Review and analyze issues re additional letters needed for SC claims.02/04/13 120.00RMK 0.40Review and analyze supporting documentation to Claim No. 135 in preparation for drafting claim objection.
02/04/13 135.00MC 0.60
Draft factual background and legal argument for objection to claim no. 135.
02/04/13 180.00MC 0.80
Analysis of issues related to claims administration and objections to various claims.
02/04/13 39.00ELL 0.20
Review and finalize omnibus claim objection as to claim nos: 144, 152, 158, 163 and supporting declaration.
02/04/13 292.50MC 1.30
Review and finalize omnibus claim objection as to claim nos 117, 135, 136, 137, and supporting declaration.
02/04/13 270.00MC 1.20
Review and finalize omnibus claim objection as to claim nos 197 and 231 and supporting declaration.
02/04/13 90.00MC 0.40
Review and finalize Trustee's Omnibus objection to claim no 7, 10.02/04/13 45.00MC 0.20Review and finalize Trustee's Omnibus objection to claim no 24, 34, 35, 36, 95, 96, 98 and supporting declaration.
02/04/13 270.00MC 1.20
Review and revise correspondence to F. Behfarin re additional documentation needed for the analysis of his proof of claim (POC 206).
02/05/13 60.00RMK 0.20
Review and revise correspondence to S. Fainsbert re additional documentation needed for the analysis of The Crawford Living Trust proof of claim (POC 187).
02/05/13 60.00RMK 0.20
Review and revise correspondence to A. Gardner re additional documentation needed for the analysis of Gardner Family Trust's proof of claim (POC 221).
02/05/13 60.00RMK 0.20
Review and revise correspondence to S. Montgomery re additional documentation needed for the analysis of SRF Investment's proof of claim (POC 116).
02/05/13 60.00RMK 0.20
Exhibit 2, Page 17
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 18
Date Description AmountAtty HoursReview and revise correspondence to S. Fainsbert re additional documentation needed for the analysis of E. Vasquez's and S. Vasquez's proof of claim (POC 178).
02/05/13 60.00RMK 0.20
Telephone call from S. Montgomery re Boyle Avenue's claim and requested supporting documents.
02/05/13 30.00RMK 0.10
Draft communication to S. Montgomery re Boyle Avenue's claim and requested supporting documents.
02/05/13 60.00RMK 0.20
Review and analyze issues re claims missing supporting documents; update claim analysis chart re same.
02/05/13 420.00RMK 1.40
Review and analyze issues re secured claims documents which may have valid objections; update claim analysis chart re same.
02/05/13 270.00RMK 0.90
Review and analyze issues re objections to late filed claims; update claim analysis chart re same.
02/05/13 120.00RMK 0.40
Review and analyze issues re objections to priority claims; update claim analysis chart re same.
02/05/13 90.00RMK 0.30
Review and analyze issues re objections to duplicate claims; update claim analysis chart re same.
02/05/13 210.00RMK 0.70
Review and analyze correspondence from G. Salvato re M. Pirian, J. Pirian and N. Pirian's proof of claims.
02/05/13 30.00RMK 0.10
Review and analyze joint settlement agreement filed in Namco and Namvar cases re treatment of the Pirian Parties' claims in the Namvar matter.
02/05/13 150.00RMK 0.50
Review and analyze communication from S. Montgomery re Boyle Avenue's proof of claim.
02/05/13 60.00RMK 0.20
Draft communication to U. Raanan re Pirian claims and effect of Namco/Namvar settlement agreement.
02/05/13 60.00RMK 0.20
Review and reply to multiple emails from U. Raanan re withdrawal of Pirian claims.
02/05/13 60.00RMK 0.20
Review and analyze correspondence from R. Gabayan re additional documents requested.
02/05/13 60.00RMK 0.20
Draft correspondence to J. Separzedah re Separzedah claims and additional documents needed.
02/05/13 120.00RMK 0.40
Review and analyze R. Gabayan proof of claim (157) in preparation for telephone call with R. Gabayan.
02/05/13 30.00RMK 0.10
Review and analyze email from S. Montgomery re Boyle Avenue's claim and requested supporting documents.
02/05/13 60.00RMK 0.20
Review and analyze issues re appropriateness of Robhana Claim (145).02/05/13 90.00RMK 0.30Analysis of issues related to claims that require a request for documentation in further support.
02/05/13 19.50ELL 0.10
Revise and prepare for final the correspondence to S. Montgomery (#116 by SRF Investment LLC), S. Fainsbert (#178 by E. and S. Vasquez), A. Gardner (#221 by Gardner Family Trust), S. Fainsbert (#187 by The
02/05/13 117.00ELL 0.60
Exhibit 2, Page 18
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 19
Date Description AmountAtty HoursCrawford Living Trust) and F. Behfarin (#206).Review and analyze multiple correspondence re status of obtaining supplemental documents from creditors.
02/05/13 75.00MRD 0.20
Review and reply to email from S. Montgomery re SRF Investment LLC.02/06/13 60.00RMK 0.20Review and reply to email from S. Montgomery re SRF Investment's claim against the estate and additional documents requested.
02/06/13 30.00RMK 0.10
Review and analyze correspondence from K. Newman re assignment of Inland Mortgage Capital Corporation's proof of claim.
02/06/13 30.00RMK 0.10
Review and analyze status of claims work; prepare comments and directions.
02/06/13 210.00LMS 0.40
Draft correspondence to F. Jevahery re SRF Investments proof of claim and additional documents needed.
02/06/13 120.00RMK 0.40
Review and analyze issues re Sunnylane Partners claim and effect of adversary proceeding; update claims analysis chart re same.
02/06/13 90.00RMK 0.30
Review and analyze correspondence from E. Negari re supporting documents re the MMN Family Trust's proof of claim.
02/06/13 90.00RMK 0.30
Review and analyze multiple correspondence re status of objections to claims.
02/06/13 37.50MRD 0.10
Review, revise and finalize draft first, second and third omnibus claim objections.
02/06/13 67.50MC 0.30
Telephone conference with J. Goodfried re status of case.02/06/13 75.00MRD 0.20Telephone call from K. Berokim re proof of claim of E. Aframian (52) and supporting documents re same.
02/07/13 30.00RMK 0.10
Review and reply to email from K. Berokim re proof of claim of E. Aframian (52) and supporting documents re same.
02/07/13 30.00RMK 0.10
Review and analyze documents provided by K. Berokim re proof of claim of E. Aframian (52).
02/07/13 120.00RMK 0.40
Review and revise three new sets of objections to claims.02/07/13 472.50LMS 0.90Review and reply to email from J. Shih re B. Aframian's proof of claim.02/08/13 30.00RMK 0.10Review and reply to email from J. Shih re K. Aframian's proof of claim.02/08/13 30.00RMK 0.10Review and analyze documents provided by N. Tabibi re proof of claim of K. Aframian (53); update case analysis chart re same.
02/08/13 120.00RMK 0.40
Telephone call to B. Beroukim re additional documents requested in support of the Gardner Family Trust proof of claim (221).
02/08/13 30.00RMK 0.10
Draft email to B. King re extension for time to provide documents requested in support of the Getlin proof of claims.
02/08/13 30.00RMK 0.10
Review and analyze Gardner Family Trust proof of claim (221) in preparation for telephone call with B. Beroukim.
02/08/13 90.00RMK 0.30
Telephone call from S. Soofer re additional documents requested in support of his proof of claim (30).
02/08/13 30.00RMK 0.10
Review of deadlines for providing supporting documents for insufficient 02/08/13 120.00RMK 0.40
Exhibit 2, Page 19
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 20
Date Description AmountAtty Hoursclaims and work on strategies for moving forward on objections to proofs of claims.Review and analyze documents provided by N. Tabibi re proof of claim of Aframian Family Trust (54); update case analysis chart re same.
02/08/13 120.00RMK 0.40
Analysis of chart of claims to determine remaining claims that need correspondence requesting additional documentation in support of claim; prepare memo to R. Kido re same.
02/08/13 58.50ELL 0.30
Review claim filed by Moses & Singer LLP (#200) and prepare correspondence to H. Bergman re documentation needed in support of a claim against the Debtor.
02/13/13 58.50ELL 0.30
Review claim filed by D. Morrow (#217) and analysis of issues related to settlement reached with respect to Secret Beach; review various pleadings related to approving compromise and disposition of claims against the Debtor; prepare memo to R. Kido re recommendations.
02/13/13 175.50ELL 0.90
Review the Debtor's case docket for any documents filed by Shaw Blackstone, LLC and identify adversary proceeding and motion for relief from stay; review for status of each in relation to background information for possible objection to claim.
02/13/13 97.50ELL 0.50
Draft correspondence to M. Tavakoli re complete copy of Personal Guarantee needed in support of claim filed by Shaw Blackstone, LLC (#100).
02/13/13 58.50ELL 0.30
Review and revise correspondence to H. Bergman re additional documentation needed for the analysis of Moses & Singer's proof of claim (POC 200).
02/14/13 60.00RMK 0.20
Review and revise correspondence to M. Torbati re additional documentation needed for the analysis of M&S Partnership's proof of claim (POC 235).
02/14/13 60.00RMK 0.20
Review and revise correspondence to M. Tavakoli re additional documentation needed for the analysis of Shaw Blackstone, LLC's proof of claim (POC 100).
02/14/13 60.00RMK 0.20
Review and analyze settlement motion with secret beach and its impact on the proof of claim filed by D. Morrow (POC 217).
02/14/13 120.00RMK 0.40
Review and analyze claims chart to confirm whether any additional letters need to be sent to claimants.
02/14/13 90.00RMK 0.30
Review claim filed by M&S Partnership (#235) and prepare correspondence to M. Torbati re documentation related to guaranteed obligation asserted against the Debtor.
02/14/13 58.50ELL 0.30
Revise and prepare for final the correspondence to M. Tavakoli (#100 by Shaw Blackstone, LLC), M. Torbati (#235 by M&S Partnership) and H. Bergman (#200 by Moses & Singer).
02/14/13 58.50ELL 0.30
Review and reply to email from B. King re status of documents requested in support of Getlin Claims.
02/18/13 60.00RMK 0.20
Review and analyze issues re status of documents requested in support of 02/18/13 180.00RMK 0.60
Exhibit 2, Page 20
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 21
Date Description AmountAtty Hoursclaims lacking sufficient supporting documents.Telephone call from H. Soofer re S. Soofer proof of claim. 02/19/13 60.00RMK 0.20Review and analyze email from H. Soofer re S. Soofer proof of claim. 02/19/13 90.00RMK 0.30Draft communication to U. Ranaan re Soraya Soofer's proof of claim and supporting documents indicating claim is only against Namco.
02/19/13 90.00RMK 0.30
Review and analyze Soraya Soofer claim filed in the Namco bankruptcy for overlap with the Namvar claim.
02/19/13 90.00RMK 0.30
Conduct and review lexis public record search of S. Khadavi for updated address for S. Khadavi's proof of claim (173).
02/19/13 60.00RMK 0.20
Review and analyze issues re objections to claims missing supporting documents and determine plan of action re drafting objections to same.
02/19/13 360.00RMK 1.20
Telephone conference with J. Moradi re status of case and website updates.
02/19/13 37.50MRD 0.10
Review and analyze issues related to claims filed in Namvar case for claims against Namco.
02/19/13 37.50MRD 0.10
Telephone call to M. Torbati re her claim (166) and M&S Partnership claim (235) and supporting documents requested.
02/21/13 30.00RMK 0.10
Review and analyze Torbati claim (166) in preparation for telephone call with M. Torbati.
02/21/13 60.00RMK 0.20
Review and analyze M&S Partnership claim (235) in preparation for telephone call with M. Torbati.
02/21/13 60.00RMK 0.20
Draft communication to H. Soofer re S. Soofer's proof of claim (30) and request withdrawal of said claim.
02/21/13 90.00RMK 0.30
Review and analyze issues re additional documents needed in support of 87th Peoria's proof of claim (39) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and reply to communication from M. Torbati re her claim (166) and M&S Partnership claim (235) and supporting documents requested re same.
02/21/13 60.00RMK 0.20
Draft correspondence to L. Drath re assignment of Inland Mortgage's claim (55) against Namvar.
02/21/13 120.00RMK 0.40
Draft communication to U. Raanan re documents in support of claims indicating guarantees were executed days after the original note.
02/21/13 90.00RMK 0.30
Review and reply to email of M. Ruszecki re Separzadeh claims.02/21/13 60.00RMK 0.20Review and analyze issues re additional documents needed in support of H. Moosai's proof of claim (78) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of S. Cohen's proof of claim (107) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of 26 Etehad, LLC's proof of claim (39) and confirm that no timely response
02/21/13 60.00RMK 0.20
Exhibit 2, Page 21
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 22
Date Description AmountAtty Hourswas received.Review and analyze issues re additional documents needed in support of B. Broumand's proof of claim (161) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of T. Nahai's proof of claim (170) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of A. Nahai's proof of claim (171) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of N. Nazarian's proof of claim (39) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of E. Vasquez's proof of claim (178) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and analyze issues re additional documents needed in support of F. Behfarin's proof of claim (206) and confirm that no timely response was received.
02/21/13 60.00RMK 0.20
Review and revise final omnibus claims objections02/21/13 45.00MC 0.20Review and analyze issues with claims in case with insufficient documentation.
02/21/13 75.00MRD 0.20
Review and revise correspondence to R. Herzog re additional supporting documents needed for Shaw Blackstone claim (100)
02/22/13 30.00RMK 0.10
Prepare correspondence to R. Herzog re Claim No. 100 filed by Shaw Blackstone, LLC and request for additional documentation.
02/22/13 39.00ELL 0.20
Review and analyze issues re omnibus objection to claims where no supporting documents provided as requested.
02/25/13 120.00RMK 0.40
Draft communication to B. Nahai re January 24, 2013 correspondence sent re T. Nahai (170) and A. Nahai (171) proof of claims.
02/25/13 120.00RMK 0.40
Review and reply to email from B. Nahai re proofs of claims of T. Nahai (170) and A. Nahai (171).
02/25/13 90.00RMK 0.30
Review and analyze promissory notes between A. Nahai and Namco provided to support proof of claim of A. Nahai (171).
02/25/13 60.00RMK 0.20
Draft communication to U. Ranaan re documentation provided in support of proofs of claims of T. Nahai (170) and A. Nahai (171).
02/25/13 90.00RMK 0.30
Draft communication to M. Pirian re withdrawal of Pirian proofs of claims.
02/25/13 60.00RMK 0.20
Review and analyze docket and pleadings filed in adversary proceeding filed by Getlin Trust against the Debtor for resolution of Getlin Trust's claim (POC 50) against the Debtor.
02/25/13 120.00RMK 0.40
Review and analyze docket and pleadings filed in adversary proceeding 02/25/13 120.00RMK 0.40
Exhibit 2, Page 22
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 23
Date Description AmountAtty Hoursfiled by H. Getlin against the Debtor for resolution of H. Getlin's claim (POC 49) against the Debtor.Review and analyze docket and pleadings filed in adversary proceeding filed by 87th Peoria against the Debtor for resolution of 87th Peoria's claim (POC 39) against the Debtor.
02/25/13 120.00RMK 0.40
Review and analyze docket and pleadings filed by J. Belle to determine whether there has been any resolution of claims asserted by J. Belle and other SC entities.
02/25/13 180.00RMK 0.60
Review and analyze docket and pleadings filed in adversary proceeding filed by Shaw Blackstone against the Debtor for resolution of Shaw Blackstone's claim (POC 100) against the Debtor.
02/25/13 120.00RMK 0.40
Review and reply to email from U. Ranaan re proof of claim of A. Nahai and concerns re statute of limitations and personal guaranty of the debtor.
02/25/13 60.00RMK 0.20
Review and reply to email from B. Nahai re supporting documents to claim filed by T. Nahai.
02/25/13 30.00RMK 0.10
Draft communication to U. Ranaan re list of claims with one-line guaranties which we are waiting on drafting objections.
02/25/13 120.00RMK 0.40
Draft communication to U. Ranaan re E. Aframian's proof of claim (number 52) and response received including guaranty not entered into contemporaneously with note.
02/25/13 60.00RMK 0.20
Draft communication to U. Ranaan re K. Aframian's proof of claim (number 53) and response received including guaranty not entered into contemporaneously with note.
02/25/13 60.00RMK 0.20
Draft communication to U. Ranaan re Aframian Trustees' proof of claim (number 54) and response received including guaranty not entered into contemporaneously with note.
02/25/13 60.00RMK 0.20
Review and analyze multiple emails re personal guaranty claims and objections thereto.
02/25/13 75.00MRD 0.20
Review and analyze correspondence from B. King re Getlin proof of claims.
02/25/13 180.00RMK 0.60
Review and reply to email from M. Ruszecki re extending the deadline to provide supporting documents to the Separzadeh claims.
02/27/13 60.00RMK 0.20
Review and analyze issues re remaining claims on objection chart which are still missing documentation and confirm whether there is current contact information for claimants.
02/27/13 240.00RMK 0.80
Initial review of pleadings and comments re Cathay Settlement; prep instructions and then discuss with clients.
02/27/13 577.50LMS 1.10
Review and analyze correspondence from B. King re Getlin claims (POC 49, 50) and documents supporting claims.
03/01/13 90.00RMK 0.30
Work on claim objection issues and strategy for further action plan.03/01/13 240.00RMK 0.80Telephone conference with J. Mason re status of Namco Exchange case.03/06/13 37.50MRD 0.10Telephone call to E. Dennis re objection to priority claims.03/07/13 30.00RMK 0.10
Exhibit 2, Page 23
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 24
Date Description AmountAtty HoursReview and analyze E. Dennis' claim (no. 63) and objection filed in preparation for telephone call.
03/07/13 60.00RMK 0.20
Draft communication to U. Ranaan re 87th Peoria's claim and stipulated judgment entered into by debtor during bankruptcy.
03/07/13 90.00RMK 0.30
Telephone call from E. Dennis re objection to priority claim.03/07/13 60.00RMK 0.20Draft communication to U. Ranaan re Getlin claims and stipulated judgment entered into by debtor during bankruptcy.
03/07/13 90.00RMK 0.30
Review and analyze issues re stipulated judgments allowing claim against the debtor and impact on claim.
03/07/13 180.00RMK 0.60
Review and analyze issues re claims where debtor stipulated to non-dischargeable judgment.
03/07/13 37.50MRD 0.10
Review and analyze proof of claim of Omid Razi (no. 58) in preparation for telephone call re request for additional documentation.
03/13/13 30.00RMK 0.10
Telephone call to Omid Razi re request for additional documentation for his proof of claim (no. 58).
03/13/13 30.00RMK 0.10
Draft communication to G. Salvato re request for additional documentation for proof of claim for Moosai Trust (no. 78).
03/13/13 90.00RMK 0.30
Review and analyze proof of claim of Shaw Blackstone, LLC (no. 100) in preparation for telephone call re request for additional documentation.
03/13/13 60.00RMK 0.20
Draft communication to R. Herzog re request for additional documentation for proof of claim for Shaw Blackstone LLC (no. 100).
03/13/13 90.00RMK 0.30
Review and analyze proof of claim of Saeed Cohen (no. 107) in preparation for telephone call re request for additional documentation.
03/13/13 60.00RMK 0.20
Draft communication to M. Mersel re request for additional documentation for proof of claim for Saeed Cohen (no. 107).
03/13/13 90.00RMK 0.30
Review and analyze proof of claim of 26 Etehad, LLC (no. 151) in preparation for telephone call re request for additional documentation.
03/13/13 90.00RMK 0.30
Draft communication to R. Stonerock re request for additional documentation for proof of claim for 26 Etehad, LLC (151).
03/13/13 90.00RMK 0.30
Review and analyze issues re objection to claim no. 172 for being imaged in wrong case.
03/13/13 60.00RMK 0.20
Review and conduct lexis public record search of N. Nazarian MD for current contact information for revision to proof of claim no. 172.
03/13/13 60.00RMK 0.20
Review and reply to email from R. Herzog re request for additional documentation for proof of claim for Shaw Blackstone LLC (no. 100).
03/13/13 30.00RMK 0.10
Review and reply to email from R. Stonerock re request for additional documentation for proof of claim for 26 Etehad, LLC (151).
03/13/13 60.00RMK 0.20
Review and analyze proof of claim of Ernesto and Socorro Vasquez (no. 178) in preparation for drafting communication re request for additional documentation.
03/13/13 60.00RMK 0.20
Draft communication to S. Fainsbert re request for additional documentation for proof of claim for Ernesto and Socorro Vasquez (no.
03/13/13 90.00RMK 0.30
Exhibit 2, Page 24
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 25
Date Description AmountAtty Hours178).Draft communication to H. Bergman re request for additional documentation for proof of claim for Moses & Singer (no. 200).
03/13/13 90.00RMK 0.30
Draft communication to J. Gersh re request for additional documentation for proof of claim for Shaw Blackstone LLC (no. 100).
03/13/13 60.00RMK 0.20
Draft communication to R. Esensten re request for additional documentation for proof of claim for 26 Etehad, LLC (151).
03/13/13 60.00RMK 0.20
Review and reply to email from R. Esensten re request for additional documentation for proof of claim for 26 Etehad, LLC (151) and request completion of the withdrawal form.
03/13/13 60.00RMK 0.20
Review and analyze issues re effect of settlement with Secret Beach on the claim filed by Morrow (POC no. 217).
03/13/13 90.00RMK 0.30
Draft communication to U. Ranaan re effect of settlement with Secret Beach on the claim filed by Morrow (POC no. 217).
03/13/13 60.00RMK 0.20
Review and analyze settlement motion entered into between Namco, Namvar and Pirians for specific language releasing POC 80, 81, and 82.
03/13/13 120.00RMK 0.40
Draft correspondence to M. Pirian re settlement motion entered into between Namco, Namvar and Pirians and specific language releasing POC 80, 81, and 82; request withdrawal of those claims.
03/13/13 90.00RMK 0.30
Draft correspondence to O. Razi re supporting documents requested for proof of claim.
03/13/13 60.00RMK 0.20
Review and analyze issues re change of address notice filed in the case and whether they correspond to any claims with possible objections.
03/13/13 180.00RMK 0.60
Review and analyze proofs of claim (nos. 149 and 150) filed by Paradigm Tax Group in preparation for drafting objections to those claims.
03/13/13 180.00RMK 0.60
Review email from M. Torbati re new address; update master mailing matrix for F.R.B.P. 2002 notices re same and prepare email to M. Torbati with instructions on filing Change of Address with the Court.
03/13/13 39.00ELL 0.20
Review and analysis of issues re pending disputed claims and status of requests for documents in support of claims.
03/13/13 58.50ELL 0.30
Review and analyze multiple correspondence re documents needed from creditors.
03/13/13 75.00MRD 0.20
Draft communication to E. Hold re status of all claim objections.03/14/13 240.00RMK 0.80Review and revise chart re status of all claim objections.03/14/13 180.00RMK 0.60Telephone call from O. Razi re request for supporting documents re claim.03/14/13 60.00RMK 0.20Review and revise correspondence to N. Nazarin re his proof of claim (no. 107) and providing a copy of the claim.
03/14/13 60.00RMK 0.20
Review and revise correspondence to D. White re Crawford Trust's proof of claim (no. 187).
03/14/13 60.00RMK 0.20
Review and revise correspondence to D. White re E. and S. Vasquez's proof of claim (no. 178).
03/14/13 60.00RMK 0.20
Draft correspondence to Dr. Nazarian re request for copy of Proof of 03/14/13 58.50ELL 0.30
Exhibit 2, Page 25
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 26
Date Description AmountAtty HoursClaim due to incorrect image on the Court's Claims Register and for documentation in support.Draft correspondence to David S. White & Associates re request for documentation needed in support of claim filed by the Crawford Trust and Ernesto and Socorro Vasquez.
03/14/13 39.00ELL 0.20
Review communication to E. Held re status of claim objections.03/14/13 75.00MRD 0.20Review and revise status report to clients.03/14/13 262.50LMS 0.50Review and analyze facsimile from H. Bergman re his proof of claim (no. 200) against the debtor; update claim objection chart re same.
03/15/13 60.00RMK 0.20
Review and analyze documents received from M. Ruszecki re Separzadeh proof of claims (nos. 126, 127, 128); update claim objection chart re same.
03/15/13 330.00RMK 1.10
Draft communication to U. Ranaan re Separzadeh proof of claims (nos. 126, 127, 128) and holding off on objections due to one-line guaranties.
03/15/13 90.00RMK 0.30
Draft communication to U. Ranaan re 87th Peoria's proof of claim (POC 39) and effect of stipulation with debtor on claim.
03/15/13 30.00RMK 0.10
Draft communication to U. Ranaan re Getlin's proof of claims (POC 49 and 50) and effect of stipulations with debtor on claim.
03/15/13 30.00RMK 0.10
Review and reply to email from M. Mersel re S. Cohen's proof of claim (107).
03/15/13 30.00RMK 0.10
Review and analyze documents provided by A. Gardner in support of the Gardner Family Trust proof of claim (no. 221); update chart re same.
03/15/13 120.00RMK 0.40
Draft communication to U. Ranaan re Gardner Family Trust proof of claim (no. 221) and supporting documents provided in response to our request which include one-line guaranties.
03/15/13 90.00RMK 0.30
Draft communication to E. Negari re MMN Family Trust's proof of claim and documents received in support of the proof of claim.
03/15/13 60.00RMK 0.20
Telephone call from E. Denis re objection to his priority proof of claim.03/15/13 30.00RMK 0.10Revise and prepare for final the correspondence to Dr. Nazarian (Claim No. 172) and David S. White & Associates (Claim Nos. 178 and 187) re request for documentation needed.
03/15/13 58.50ELL 0.30
Review and reply to communication from D. White re claim of the Crawford Living Trust and Vasquezes.
03/20/13 90.00RMK 0.30
Review and revise Objection to Claims in order to finalize objections in preparation of Review by Client. Prepare Table of Authorities and Table of Contents.
03/20/13 280.00SPS 1.60
Review and update chart re status of request for documents and claim objections.
03/20/13 90.00RMK 0.30
Review and revise Objection to Claims in order to finalize objections in preparation of Review by Client. Prepare Table of Authorities and Table of Contents.
03/21/13 192.50SPS 1.10
Draft fourth omnibus objection to claims which are not an obligation of 03/21/13 720.00RMK 2.40
Exhibit 2, Page 26
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 27
Date Description AmountAtty Hoursthe debtor including Soofer Claim (POC 30), Cushman Claim (POC 109) and SRF Claim (POC 116).Review and reply to email from U. Raanan re Gardner Family Trust Claim (POC 221).
03/21/13 60.00RMK 0.20
Review and revise omnibus objection to claims which are not an obligation of the debtor including Soofer Claim (POC 30), Cushman Claim (POC 109) and SRF Claim (POC 116).
03/21/13 180.00RMK 0.60
Review and reply to email from U. Ranaan re Getlin Claims (POC 49 & 50) and how to handle stipulated judgments for non-dischargeable claims against the Debtor.
03/21/13 90.00RMK 0.30
Review and reply to email from U. Ranaan re Separzadeh Claims (POC 126, 127, 128) and holding off on objecting.
03/21/13 30.00RMK 0.10
Review and reply to email from U. Ranaan re 87th Peoria LLC's proof of claim (POC 39).
03/21/13 30.00RMK 0.10
Review and reply to email from U. Ranaan re documents received in response to our request for supporting documents on the Getlin Claims (POCs 49 & 50).
03/21/13 60.00RMK 0.20
Draft declarations in support of fourth omnibus objection to claims which are not an obligation of the debtor including Soofer Claim (POC 30), Cushman Claim (POC 109) and SRF Claim (POC 116).
03/21/13 210.00RMK 0.70
Review and analyze Soofer Claim (POC 30), Cushman Claim (POC 109) and SRF Claim (POC 116) in preparation for drafting omnibus objection to claims.
03/21/13 90.00RMK 0.30
Review and analyze Paradigm Tax Group, Inc.'s proof of claim (POC 149) in preparation for drafting claim objection.
03/21/13 90.00RMK 0.30
Review and analyze Paradigm Tax Group, Inc.'s proof of claim (POC 150) in preparation for drafting claim objection.
03/21/13 120.00RMK 0.40
Begin drafting claim objection objecting to the Paradigm claims (POCs 149 & 150).
03/21/13 360.00RMK 1.20
Review and analyze multiple emails re status of objections to claims.03/21/13 75.00MRD 0.20Finish drafting claim objection objecting to the Paradigm claims (POCs 149 & 150).
03/22/13 510.00RMK 1.70
Review and analyze case law and statutory authority re whether a request for payment of an administrative expense may be asserted through a proof of claim.
03/22/13 180.00RMK 0.60
Review and analyze the docket for the Namvar bankruptcy re whether Paradigm Tax Group, Inc. filed a request for payment of administrative expense as required under 11 U.S.C. Section 503(a).
03/22/13 90.00RMK 0.30
Draft declaration in support of claim objection objecting to the Paradigm claims (POCs 149 & 150).
03/22/13 120.00RMK 0.40
Review and revise claim objection objecting to the Paradigm claims (POCs 149 & 150).
03/22/13 120.00RMK 0.40
Exhibit 2, Page 27
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 28
Date Description AmountAtty HoursTelephone call to E. Afaghi re 87th Peoria LLC's proof of claim (POC 39) and correspondence sent re supporting documents in January 2013.
03/22/13 30.00RMK 0.10
Draft communication to E. Afaghi's office re 87th Peoria LLC's proof of claim (POC 39) and correspondence sent re supporting documents in January 2013.
03/22/13 90.00RMK 0.30
Review and analyze issues re responses from claimants for follow ups to request for documents; update chart re status of claims re same.
03/22/13 330.00RMK 1.10
Review and reply to email from D. Meadows re release of the D. Morrow claim (POC 217) through the Secret Beach agreement.
03/22/13 60.00RMK 0.20
Draft correspondence to U. Ranaan re release of the D. Morrow claim (POC 217) through the Secret Beach agreement and whether we should request that he file a withdrawal of his claim.
03/22/13 30.00RMK 0.10
Draft communication to B. Nahai re T. Nahai's proof of claim (POC 170) and lack of supporting documents attached.
03/22/13 90.00RMK 0.30
Draft communication to B. Nahai re A. Nahai's proof of claim (POC 171) and assertion that the claim is time barred due to the statute of limitations to enforce the claim.
03/22/13 90.00RMK 0.30
Telephone call to D. Selki re how he would like to handle M. Selki, S Selki and his claims (POC 92, 93, 94).
03/22/13 30.00RMK 0.10
Draft communication to U. Ranaan re claims filed by J. Belle re SC limited liability companies (POC 180-186, 188, 190-196).
03/22/13 90.00RMK 0.30
Review and analyze docket and pleadings filed in instant bankruptcy case re resolution of the SC limited liability companies.
03/22/13 180.00RMK 0.60
Telephone call to B. Broumand re correspondence sent for additional documentation in support of his proof of claim (POC 161).
03/22/13 30.00RMK 0.10
Review and analyze F. Behfarin's proof of claim (POC 206) in preparation for telephone call to F. Behfarin re supporting documents requested.
03/22/13 60.00RMK 0.20
Telephone call to F. Behfarin re his proof of claim (POC 206) and supporting documents requested.
03/22/13 30.00RMK 0.10
Draft communication to F. Behfarin re his proof of claim (POC 206) and supporting documents requested.
03/22/13 60.00RMK 0.20
Review and analyze B. Broumand's proof of claim (POC 161) in preparation for telephone call re request for additional documents.
03/22/13 30.00RMK 0.10
Review and revise objs to Paradign Tax Group claims.03/25/13 262.50LMS 0.50Review and revise objections to Soofer, Cushman and SRF claims.03/25/13 315.00LMS 0.60Review and reply to communication from K. Moynihan re supporting documents in support of Saeed Cohen's proof of claim (No. 107).
03/25/13 60.00RMK 0.20
Review and analyze correspondence from K. Moynihan re supporting documents in support of Saeed Cohen's proof of claim (No. 107).
03/25/13 120.00RMK 0.40
Review and analyze issues re responses from claimants for follow ups to request for documents; update chart re status of claims re same.
03/25/13 90.00RMK 0.30
Exhibit 2, Page 28
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 29
Date Description AmountAtty HoursDraft objection to H. Moossai's proof of claim (number 78).03/25/13 570.00RMK 1.90Draft declarations in support of objection to H. Moossai's proof of claim (number 78).
03/25/13 120.00RMK 0.40
Review and revise objection to H. Moossai's proof of claim (number 78).03/25/13 120.00RMK 0.40Telephone call from D. Selki re D. Selki, M Selki and S. Selki's proofs of claims (no. 92, 93, 94) and documents needed in support of same.
03/26/13 60.00RMK 0.20
Draft communication to D. Selki re D. Selki, M Selki and S. Selki's proofs of claims (no. 92, 93, 94) and documents needed in support of same.
03/26/13 30.00RMK 0.10
Review and finalize claim objection objecting to the Paradigm claims (POCs 149 & 150).
03/26/13 120.00RMK 0.40
Review and finalize fourth omnibus objection to claims which are not an obligation of the debtor including Soofer Claim (POC 30), Cushman Claim (POC 109) and SRF Claim (POC 116).
03/26/13 120.00RMK 0.40
Review and analyze issues re effect of settlement between Namco estate and D. Selki and M Selki for amount of proof of claims.
03/26/13 90.00RMK 0.30
Telephone call from Dr. Navarian re her proof of claim and that she has sent requested documents.
03/26/13 30.00RMK 0.10
Compile and send 3 draft omnibus claim objections based on obligations of Namco to T. Neilson and U. Raanan for review and execution
03/26/13 45.00MC 0.20
Review and finalize omnibus claim objections 03/26/13 67.50MC 0.30Draft omnibus objection to secured claims.03/27/13 330.00RMK 1.10Review and analyze Inland Mortgage Capital Corporation's proof of claim (POC 55) in preparation for drafting objection to secured claims.
03/27/13 120.00RMK 0.40
Review and analyze Shaw Blackstone, LLC's proof of claim (POC 100) in preparation for drafting objection to secured claims.
03/27/13 120.00RMK 0.40
Review and analyze S. Shakib's proof of claim (POC 103) in preparation for drafting objection to secured claims.
03/27/13 120.00RMK 0.40
Review and analyze Wilshire State Bank's proof of claim (POC 139) in preparation for drafting objection to secured claims.
03/27/13 120.00RMK 0.40
Review and reply to email from M. Torbati re requested documents for her claim and M&S Partnership's claim.
03/29/13 30.00RMK 0.10
Telephone call to M. Torbati re her proof of claim and M&S Partnership's proof of claim.
03/29/13 60.00RMK 0.20
Review and analyze issues re unresolved claims and objection issues; update chart re status of claims re same.
03/29/13 270.00RMK 0.90
Continue drafting omnibus objection to secured claims.03/29/13 330.00RMK 1.10Finish drafting omnibus objection to secured claims.03/30/13 180.00RMK 0.60Draft declarations in support of omnibus objection to secured claims.03/30/13 240.00RMK 0.80Draft communication to U. Ranaan re SC proofs of claim and status of liquidation re same.
04/01/13 30.00RMK 0.10
Draft communication to M. Pirian re withdrawal of Proofs of Claim 80-1, 04/01/13 90.00RMK 0.30
Exhibit 2, Page 29
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 30
Date Description AmountAtty Hours81-1, and 82-1 (filed by Pirians).Review and finalize objection to Paradigm claims (POC 149 and 150).04/02/13 90.00RMK 0.30Review and finalize notice of objection to Paradigm claim (POC 149).04/02/13 30.00RMK 0.10Review and finalize notice of objection to Paradigm claim (POC 150).04/02/13 30.00RMK 0.10Review and finalize omnibus objection to S. Soofer's proof of claim (no. 30), Cushman & Wakefield's proof of claim (no. 109), and SRF Investments' proof of claim (no. 116).
04/02/13 120.00RMK 0.40
Review and finalize notice of objection to S. Soofer's proof of claim (no. 30).
04/02/13 30.00RMK 0.10
Review and finalize notice of objection to Cushman & Wakefield's proof of claim (no. 109).
04/02/13 30.00RMK 0.10
Review and finalize notice of objection to SRF Investments' proof of claim (no. 116).
04/02/13 30.00RMK 0.10
Review and analyze documents provided by N. Nazarian in support of her claim (POC 172) filed against the Debtor.
04/02/13 90.00RMK 0.30
Draft communication to U. Ranaan re documents provided by N. Nazarian in support of her claim (POC 172) filed against the Debtor.
04/02/13 90.00RMK 0.30
Draft Notice of Objection to Claim - Claim No. 149 Paradigm Tax Group, Inc. in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 149 - Paradigm Tax Group, Inc. and 150 - Paradigm Tax Group, Inc.
04/02/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 150 Paradigm Tax Group, Inc. in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 149 - Paradigm Tax Group, Inc. and 150 - Paradigm Tax Group, Inc.
04/02/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 30 - Soraya Soofer in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 30 - Soraya Soofer, 109 Cushman & Wakefield of Washington, D.C. and 116 - SRF Investments LLC.
04/02/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 109 - Cushman & Wakefield of Washington, D.C. in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 30 - Soraya Soofer, 109 Cushman & Wakefield of Washington, D.C. and 116 - SRF Investments LLC.
04/02/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 116 - SRF Investments LLC in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 30 - Soraya Soofer, 109 Cushman & Wakefield of Washington, D.C. and 116 - SRF Investments LLC.
04/02/13 52.50AMV 0.30
Review and analyze documents provided by O. Razi in response to our request for the additional documents in support of his claim (no. 58) against the debtor.
04/02/13 90.00RMK 0.30
Review and revise objection to H. Moossai's claim (no. 78) to include additional objection to B. Broumand's claim (no. 161) for lack of
04/02/13 180.00RMK 0.60
Exhibit 2, Page 30
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 31
Date Description AmountAtty Hourssupporting documentation.Review and revise declarations in support of objection to H. Moossai's claim (no. 78) to include additional objection to B. Broumand's claim (no. 161) for lack of supporting documentation.
04/02/13 90.00RMK 0.30
Review and analyze multiple correspondence re objections to secured claims and responses from creditors re same.
04/02/13 75.00MRD 0.20
Telephone call to N. Nazarian re documents provided in support of her proof of claim (no. 172).
04/03/13 30.00RMK 0.10
Draft communication to D. White re status of documents requested for the Crawford Trust's proof of claim (no. 187) and the Vasquez's proof of claim (no. 178).
04/03/13 60.00RMK 0.20
Review and revise omnibus objection for lack of supporting documentation to include T. Nahai claim (170) and F. Behfarin claim (206).
04/03/13 480.00RMK 1.60
Review and analyze proofs of claim filed by O. Razi (no. 58), J. Razi (no. 59) and Jacob and Khorshid Razi (no. 60) and documents provided by O. Razi in support of his claim.
04/03/13 90.00RMK 0.30
Review and analyze 87th Peoria's Claim (POC 39) and correspondence sent re claim in preparation for drafting omnibus objection to claims.
04/03/13 90.00RMK 0.30
Review and analyze Gabayan's Claim (POC 157) and correspondence sent re same in preparation for drafting omnibus objection to claims.
04/03/13 90.00RMK 0.30
Review and analyze MMN Family Trust's Claim (POC 189) and correspondence sent re same in preparation for drafting omnibus objection to claims.
04/03/13 90.00RMK 0.30
Draft fifth omnibus objection to claims for claims which are not obligations of the debtor.
04/03/13 240.00RMK 0.80
Review and analyze T. Nahai's Claim (POC 170) and correspondence sent re claim in preparation for drafting omnibus objection to claims.
04/03/13 90.00RMK 0.30
Review and analyze F. Behfarin's Claim (POC 206) and correspondence sent re claim in preparation for drafting omnibus objection to claims.
04/03/13 90.00RMK 0.30
Review court's docket for oppositions to priority objections to claims no 27 and 63 in preparation for hearing
04/03/13 90.00MC 0.40
Review and revise for final objection to Paradigm claims.04/03/13 157.50LMS 0.30Prepare draft order disallowing priority classification for claims 27 and 4304/03/13 67.50MC 0.30Prepare for, travel to, and appear for hearing on trustee's objection to claims 27, 43 as priority claims
04/03/13 900.00MC 4.00
Review and revise objs to claims of Mosai and Bromuand. 04/03/13 315.00LMS 0.60Review and revise order granting omnibus claim objection to priority claims.
04/04/13 60.00RMK 0.20
Finish drafting fifth omnibus objection to claims for claims which are not obligations of the debtor.
04/04/13 480.00RMK 1.60
Review and revise declarations in support of omnibus objection for lack of 04/04/13 180.00RMK 0.60
Exhibit 2, Page 31
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 32
Date Description AmountAtty Hourssupporting documentation.Draft declarations in support of fifth omnibus objection to claims for claims which are not obligations of the debtor.
04/04/13 210.00RMK 0.70
Review and revise fifth omnibus objection to claims for claims which are not obligations of the debtor.
04/04/13 180.00RMK 0.60
Review and reply to email from U. Ranaan re suggested revisions to omnibus motion for claims lacking documentation.
04/04/13 30.00RMK 0.10
Review revisions to draft proposed order disallowing priority claims 47, 6304/04/13 22.50MC 0.10Review and reply to email from M. Torbati re documents in support of her claim (POC 166) and M&S Partnership's claim (POC 235).
04/05/13 30.00RMK 0.10
Draft communication to U. Ranaan re revisions to Trustee's declaration in support of the omnibus objection to claims lacking documentation.
04/05/13 60.00RMK 0.20
Review and reply to multiple communications from U. Ranaan re revisions to Trustee's declaration in support of the omnibus objection to claims lacking documentation.
04/05/13 120.00RMK 0.40
Draft request for judicial notice in support of omnibus objection for lack of supporting documentation.
04/05/13 120.00RMK 0.40
Review and revise omnibus objection for lack of supporting documentation to include U. Ranaan's revisions re trustee's declaration.
04/05/13 180.00RMK 0.60
Review and analyze documents provided by M. Torbati in support of her claim (POC 166) and M&S Partnership's claim (POC 235).
04/05/13 120.00RMK 0.40
Draft communication to M. Torbati re providing copies of the underlying promissory notes for her claim (POC 166) and M&S Partnership (POC 235).
04/05/13 30.00RMK 0.10
Review and reply to email from M. Torbati re providing copies of the underlying promissory notes for her claim (POC 166) and M&S Partnership (POC 235).
04/05/13 30.00RMK 0.10
Review and revise fifth omnibus objection for obligations which are not against the debtor to include U. Ranaan's revisions re trustee's declaration.
04/05/13 180.00RMK 0.60
Draft request for judicial notice in support of fifth omnibus objection for obligations which are not against the debtor.
04/05/13 90.00RMK 0.30
Review and analyze issues re sufficient documentation provided in support of potentially objectionable claims.
04/05/13 180.00RMK 0.60
Review and analyze issues re evidence for claim objections and how to admit.
04/05/13 75.00MRD 0.20
Review and analyze revised direction for objection to claims strategy re supporting declarations for omnibus claim objection.
04/05/13 67.50MC 0.30
Draft communication to U. Raanan re SC limited liability companies's proof of claims and objection to same.
04/08/13 30.00RMK 0.10
Review and analyze BankFirst's proof of claim (no. 12) and determine whether any additional information should be requested from the claimant.
04/10/13 90.00RMK 0.30
Telephone conference with E. Caldy re status of case and objections to 04/10/13 37.50MRD 0.10
Exhibit 2, Page 32
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 33
Date Description AmountAtty Hoursclaims.Begin drafting motion objecting to A. Nahai's claim (POC 171).04/11/13 180.00RMK 0.60Draft request for judicial notice in support of motion objecting to A. Nahai's claim (POC 171).
04/11/13 90.00RMK 0.30
Review and analyze case law and statutory authorities re the enforcement of a personal guaranty of a contract in writing under California Code of Civil Procedure Section 337.
04/11/13 240.00RMK 0.80
Review and analyze status of completion of claims work; study additional targets; prepare instructions.
04/11/13 367.50LMS 0.70
Draft Notice of Objection to Claim No. 78 - Haroon Mossai in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 78 - Haroon Mossai, 161 - Brenden Broumand, 170 - Tara Nahai and 206 - Fred Behfarin.
04/12/13 52.50AMV 0.30
Draft Notice of Objection to Claim No. 161 - Brenden Broumand in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 78 - Haroon Mossai, 161 - Brenden Broumand, 170 - Tara Nahai and 206 - Fred Behfarin.
04/12/13 52.50AMV 0.30
Draft Notice of Objection to Claim No. 170 - Tara Nahai in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 78 - Haroon Mossai, 161 - Brenden Broumand, 170 - Tara Nahai and 206 - Fred Behfarin.
04/12/13 52.50AMV 0.30
Draft Notice of Objection to Claim No. 206 - Fred Behfarin in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claim Numbers 78 - Haroon Mossai, 161 - Brenden Broumand, 170 - Tara Nahai and 206 - Fred Behfarin.
04/12/13 52.50AMV 0.30
Finish drafting motion objecting to A. Nahai's claim (POC 171).04/12/13 510.00RMK 1.70Review and analyze case law and statutory authorities re whether a personal guaranty of a note may be enforced under California Code of Civil Procedure Section 337 when there has been partial payments on the note.
04/12/13 180.00RMK 0.60
Draft declaration in support of the motion objecting to A. Nahai's claim (POC 171).
04/12/13 120.00RMK 0.40
Review and revise motion objecting to A. Nahai's claim (POC 171).04/12/13 90.00RMK 0.30Review and revise for final objection to claims of Mossai, et al.04/17/13 210.00LMS 0.40Review and revise fifth omnibus motion objecting to claims (POC 39, 157, 189).
04/18/13 120.00RMK 0.40
Review and revise request for judicial notice in support of fifth omnibus motion objecting to claims (POC 39, 157, 189).
04/18/13 60.00RMK 0.20
Review and revise motion objecting to A. Nahai's claim (POC 171).04/18/13 90.00RMK 0.30Review and revise request for judicial notice in support of motion objecting to A. Nahai's claim (POC 171).
04/18/13 30.00RMK 0.10
Review and analyze issues re status of claim objections and strategy for 04/18/13 240.00RMK 0.80
Exhibit 2, Page 33
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 34
Date Description AmountAtty Hoursobjecting to remaining incomplete or erroneously filed claims.Review and revise two sets of objs to claims.04/18/13 735.00LMS 1.40Prepare Order on Disallowing Priority Claim of Mariana Jalil and Exra Denis for service and E-filing with the Court.
04/18/13 70.00SPS 0.40
Review and analyze issues re insufficient documentation provided in support of the Getlin Claim (POC 49) and Getlin Trust Claim (POC 50).
04/19/13 90.00RMK 0.30
Review and analyze issues re Pirian claims (POC 80, 81 and 82) and receipt of withdrawal of same.
04/19/13 60.00RMK 0.20
Review and analyze issues re documents received by D. Selki in support of Selki Claims (POC 92, 93, 94).
04/19/13 60.00RMK 0.20
Review and analyze issues re documents received supporting S. Cohen's claim (POC 107) evidencing fraud.
04/19/13 90.00RMK 0.30
Draft communication to M. Torbati re status of documents in support of her claim and the claim of M&S Partnerships.
04/19/13 30.00RMK 0.10
Draft communication to D. White re status of documents in response to request for Vasquez's claim (POC 178) and Crawford Living Trust claim (POC 187).
04/19/13 60.00RMK 0.20
Review and analyze issues re documents received by R. Hanasab in support of Robhana and M&Y Management Claims (POC 147, 149).
04/19/13 90.00RMK 0.30
Review and analyze issues re sufficient documentation provided in support of potentially objectionable claims; update chart re same.
04/19/13 360.00RMK 1.20
Draft communication to U. Raanan re lack of response from M. Pirian re request for withdrawal of the Pirian claims (POC 80, 81 and 82).
04/19/13 60.00RMK 0.20
Review and reply to email from U. Raanan re Pirian claims (POC 80, 81 and 82) and receipt of withdrawal of same.
04/19/13 30.00RMK 0.10
Review and analyze issues re documents received supporting Boyle Avenue, LLC's claim (POC 140) evidencing fraud.
04/19/13 90.00RMK 0.30
Review and analyze issues re documents received supporting H. Bergman's claim (POC 200) evidencing fraud.
04/19/13 30.00RMK 0.10
Draft Declaration of M. Choi in support of trustee's omnibus objection as to claims No. 144 Khalil Varastehpour; No. 152 The Yasmin Family 1999 Limited Partnership; No. 158 Iraj Farhadian FBO Farhadian Family Trust; No. 163 Bijan Nahai; No. 197 Princeton Holdings, LLC; No. 231 Elodie Khavarani.
04/19/13 90.00MC 0.40
Draft declaration of M. Choi in support of Trustee's omnibus motion objecting to No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; No. 135 Fereshteh Kohanim; No. 136 Behnam Souroudi Retirement Trust; No. 137 Behnam Souroudi Retirement Trust.
04/19/13 90.00MC 0.40
Prepare RJN in support of Trustee's omnibus objection to No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; No. 135 Fereshteh Kohanim; No. 136 Behnam Souroudi Retirement Trust; No. 137 Behnam Souroudi Retirement Trust.
04/19/13 90.00MC 0.40
Exhibit 2, Page 34
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 35
Date Description AmountAtty HoursReview and revise trustee's first omnibus claim objection to claims no: 7, 10, 24, 34, 35, 36, 95, 96.
04/19/13 157.50MC 0.70
Draft RJN in support of trustee's first omnibus claim objection to claims no: 7, 10, 24, 34, 35, 36, 95, 96.
04/19/13 90.00MC 0.40
Prepare declaration of M. Choi in support of trustee's first omnibus claim objection to claims no: 7, 10, 24, 34, 35, 36, 95, 96.
04/19/13 90.00MC 0.40
Review and revise trustee's omnibus motion objection to No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; No. 135 Fereshteh Kohanim; No. 136 Behnam Souroudi Retirement Trust; No. 137 Behnam Souroudi Retirement Trust.
04/19/13 90.00MC 0.40
Review and analyze issues re objections to claims filed. 04/19/13 225.00MRD 0.60Review and revise trustee's omnibus objection as to claims No. 144 Khalil Varastehpour; No. 152 The Yasmin Family 1999 Limited Partnership; No. 158 Iraj Farhadian FBO Farhadian Family Trust; No. 163 Bijan Nahai; No. 197 Princeton Holdings, LLC; No. 231 Elodie Khavaran.
04/19/13 90.00MC 0.40
Draft RJN in support of trustee's omnibus objection as to claims No. 144 Khalil Varastehpour; No. 152 The Yasmin Family 1999 Limited Partnership; No. 158 Iraj Farhadian FBO Farhadian Family Trust; No. 163 Bijan Nahai; No. 197 Princeton Holdings, LLC; No. 231 Elodie Khavarani.
04/19/13 67.50MC 0.30
Review and reply to email from D. White re discussion about Vasquez and Crawford Family Trust claims.
04/22/13 30.00RMK 0.10
Review and revise omnibus claim objections; prepare email to U. O' Raanan re revisions.
04/22/13 90.00MC 0.40
Review and revise first omnibus objection to claims asserted incorrectly against the debtor's estate to include analysis re Claim No. 10 (Manouchehr Tabibzadeh).
04/23/13 180.00RMK 0.60
Review and analyze issues re omnibus objections to claims which were improperly asserted against the Debtor.
04/23/13 180.00RMK 0.60
Review and finalize first omnibus objection to claims asserted incorrectly against the debtor's estate.
04/23/13 120.00RMK 0.40
Review and finalize mandatory notices of objection to claim for the first omnibus objection to claims improperly asserted against the Debtor.
04/23/13 120.00RMK 0.40
Review and finalize notice in support of first omnibus objection to claims asserted incorrectly against the debtor's estate.
04/23/13 60.00RMK 0.20
Draft Notice of Objection to Claim - Claim No. 10 - Manouchehr Tabibzadeh in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Exhibit 2, Page 35
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 36
Date Description AmountAtty HoursDraft Notice of Objection to Claim - Claim No. 7 - Jonathan Baharvar in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 24 - Mansoor Alyeshmerni in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 34 - Mishel Sakhai in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 35 - Kamran Raminfard in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 36 - Mani and Talia Raminfard in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 95 - Fred Mahjoubi in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 52.50AMV 0.30
Draft Notice of Objection to Claim - Claim No. 96 - Ben Mahjoubi in connection with the Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 -
04/23/13 52.50AMV 0.30
Exhibit 2, Page 36
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 37
Date Description AmountAtty HoursManouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.Review, organize and label exhibits (8) to Notices (8) and Chapter 11 Trustee's Omnibus Motion for Order Disallowing Claims of: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 36 - Mani and Talia Raminfard; Claim No. 95 - Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi.
04/23/13 140.00AMV 0.80
Analysis of issues related to three Omnibus Motions objecting to claims that are not obligations of the Debtor and timing of filing of same.
04/23/13 78.00ELL 0.40
Commence review of Second Omnibus Motion Objecting to Claims and analysis of issues relating to need for rescheduling of hearing; prepare memo to R. Kido and M. Choi re same.
04/23/13 58.50ELL 0.30
Review and analyze legal argument objecting to claim No. 10 in ominbus claim objection.
04/23/13 22.50MC 0.10
Review and analyze issues re objections to claims needing further documentation and improper guarantees.
04/23/13 75.00MRD 0.20
Telephone call with D. White re Vasquez's claim (POC 178) and Crawford Living Trust's claim (POC 187).
04/24/13 60.00RMK 0.20
Prepare withdrawal of claim forms for the Vasquez's claim (POC 178) and Crawford Living Trust's claim (POC 187).
04/24/13 60.00RMK 0.20
Review and analyze Vasquez's claim (POC 178) and Crawford Living Trust's claim (POC 187) in preparation for telephone call with D. White.
04/24/13 60.00RMK 0.20
Review and reply to multiple emails from D. White re documents requested re Vasquez's claim (POC 178) and Crawford Living Trust's claim (POC 187).
04/24/13 60.00RMK 0.20
Draft communication to D. White re withdrawal of claim forms for the Vasquez's claim (POC 178) and Crawford Living Trust's claim (POC 187).
04/24/13 60.00RMK 0.20
Revise the Notice of Motion and Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust; work on the Table of Contents and the Table of Authorities.
04/24/13 292.50ELL 1.50
Review and revise for final Omnibus obj pldings re Baharvar, et al04/25/13 210.00LMS 0.40Review files and compile the exhibits to the Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust.
04/25/13 97.50ELL 0.50
Exhibit 2, Page 37
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 38
Date Description AmountAtty HoursReview and revise the Request for Judicial Notice in Support of Chapter 11 Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust; work on service list.
04/25/13 78.00ELL 0.40
Draft Notice of Objection to Claim related to Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust and Claim No. 137 Behnam Souroudi Retirement Trust.
04/25/13 175.50ELL 0.90
Review files and compile exhibits to the Trustee's Third Omnibus Motion for Order Disallowing the Following Claims: Claim No. 144 Khalil Varastehpour; Claim No. 152 The Yasmin Family 1999 Limited Partnership; Claim No. 158 Iraj Farhadian fbo Farhadian Family Trust; Claim No. 163 Bijan Nahai; Claim No. 197 Princeton Holdings, LLC; Claim No. 231 Elodie Khavarani.
04/25/13 156.00ELL 0.80
Review and analyze status of claims and speak to Chair re proposed action.
04/25/13 262.50LMS 0.50
Prepare weekly updates to unsecured creditors website.04/25/13 37.50MRD 0.10Revise the Notice of Omnibus Motion and Trustee's Third Omnibus Motion for Order Disallowing the Following Claims: Claim No. 144 Khalil Varastehpour; Claim No. 152 The Yasmin Family 1999 Limited Partnership; Claim No. 158 Iraj Farhadian fbo Farhadian Family Trust; Claim No. 163 Bijan Nahai; Claim No. 197 Princeton Holdings, LLC; Claim No. 231 Elodie Khavarani; work on the Table of Contents and Table of Authorities; compile final with all exhibits.
04/26/13 331.50ELL 1.70
Review and revise the Request for Judicial Notice in Support of Chapter 11 Trustee's Third Omnibus Motion for Order Disallowing the Following Claims: Claim No. 144 Khalil Varastehpour; Claim No. 152 The Yasmin Family 1999 Limited Partnership; Claim No. 158 Iraj Farhadian fbo Farhadian Family Trust; Claim No. 163 Bijan Nahai; Claim No. 197 Princeton Holdings, LLC; Claim No. 231 Elodie Khavarani; work on service list and prepare for final.
04/26/13 117.00ELL 0.60
Draft Notice of Objection to Claim related to Claim No. 144 Khalil Varastehpour; Claim No. 152 The Yasmin Family 1999 Limited Partnership; Claim No. 158 Iraj Farhadian fbo Farhadian Family Trust; Claim No. 163 Bijan Nahai; Claim No. 197 Princeton Holdings, LLC; Claim No. 231 Elodie Khavarani; compile final with Motion attached to each.
04/26/13 312.00ELL 1.60
Revise the Notice of Motion and Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust; compile final with all
04/26/13 117.00ELL 0.60
Exhibit 2, Page 38
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 39
Date Description AmountAtty Hoursexhibits.Prepare for final the Request for Judicial Notice in Support of Chapter 11 Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust.
04/26/13 39.00ELL 0.20
Revise the Notice of Objection to Claim related to Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; and Claim No. 137 Behnam Souroudi Retirement Trust; compile final with Motion attached to each.
04/26/13 58.50ELL 0.30
Prepare for service and electronic filing with the Court the following documents: (1) Notice of Motion and Trustee's Third Omnibus Motion for Order Disallowing the Following Claims: Claim No. 144 Khalil Varastehpour; Claim No. 152 The Yasmin Family 1999 Limited Partnership; Claim No. 158 Iraj Farhadian fbo Farhadian Family Trust; Claim No. 163 Bijan Nahai; Claim No. 197 Princeton Holdings, LLC; Claim No. 231 Elodie Khavarani; (2) Notice of Objection to Claim (6) and (3) Request for Judicial Notice in Support.
04/26/13 253.50ELL 1.30
Prepare for service and electronic filing with the Court the following documents: (1) Notice of Motion and Trustee's Second Omnibus Motion for Order Disallowing the Following Claims: Claim No. 117 Morad Radfar or Pavaneh Radfar, Trustee of the Radfar Family Trust; Claim No. 135 Fereshteh Kohanim; Claim No. 136 Behnam Souroudi Retirement Trust; Claim No. 137 Behnam Souroudi Retirement Trust; (2) Notice of Objection to Claim (3); and (3) Request for Judicial Notice in Support.
04/26/13 175.50ELL 0.90
Review and revise for final Omnibus objectiob to claims re Radfar et al.04/27/13 210.00LMS 0.40Review and revise Omnibus objection to claim for final re Varastapour et al.
04/27/13 210.00LMS 0.40
Prepare Judge's copy of Motions objecting to claims (2), Notices of Objection to Claim (9) and Request for Judicial Notice (2) and coordinate delivery of same to Chambers as required by Local Rules.
04/29/13 78.00ELL 0.40
Review of status of claim objections and work on strategies for completion of objections or resolution with claimants re issues.
04/29/13 180.00RMK 0.60
Review and analyze issues re M. Alyeshmerni's claim (POC 24) and lack of personal guaranty.
04/29/13 90.00RMK 0.30
Telephone conference with E. Alyeshmerni re objection filed to his claim.04/29/13 37.50MRD 0.10Email with U. Raanan re withdrawal of POC No. 19704/30/13 22.50MC 0.10Review and analyze issues re fourth omnibus claim objection for claims which were improperly asserted against the Debtor (POC 30, 109, 116).
05/01/13 90.00RMK 0.30
Review and reply to email from U. Raanan re SC LLC actions and holding off on objections; update chart re same.
05/01/13 30.00RMK 0.10
Exhibit 2, Page 39
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 40
Date Description AmountAtty HoursEmail with U. Raanan and D. Meadows re withdrawal of objection to Princeton Holdings LLC Claim
05/01/13 22.50MC 0.10
Prepare Notice of Withdrawal of Trustee's Objection to Claim number 197 filed by Princeton Holdings, LLC.
05/02/13 140.00SPS 0.80
Telephone call from B. Mahjoubi re objection to his claim (POC 96) and his fathers (POC 95).
05/02/13 120.00RMK 0.40
Draft communication to B. Mahjoubi re claims filed in Namco bankruptcy case.
05/02/13 30.00RMK 0.10
Review and analyze issues re Mahjoubi claims (POC 95, 96).05/02/13 90.00RMK 0.30Review and finalize notice of withdrawal of claim objection to Princeton Holdings LLC only
05/02/13 45.00MC 0.20
Prepare email to E. Alyeshmerni re further documentation of guarantee.05/03/13 37.50MRD 0.10Review and analyze issues re objection to Cushman & Wakefield of Washington, D.C. (POC 109).
05/03/13 90.00RMK 0.30
Review and analyze issue re objection to S. Alyeshmerni's claim (POC 224).
05/03/13 60.00RMK 0.20
Review and analyze correspondence from E. Alyeshmerni re any documents in support of guarantee of Namco claim.
05/03/13 37.50MRD 0.10
Prepare and file a Notice of Withdrawal of Trustee's Objection to Claim number 197 Princeton Holdings LLC Only.
05/03/13 157.50SPS 0.90
Review and analyze correspondence re status of objections to claims.05/03/13 75.00MRD 0.20Review and reply to commnuications from U. Raanan re objection to A. Nahai's claim.
05/06/13 60.00RMK 0.20
Review and analyze correspondence re objection to claims with one line guarantee.
05/06/13 37.50MRD 0.10
Review and analyze issues re objection to I. Farhadian's claim (POC 158).05/07/13 90.00RMK 0.30Email with J. Far-hadian re Trustee's objection to POC 15805/07/13 45.00MC 0.20Prepare for and attend hearing on the omnibus objections to the following claims: Paradigm (POC 149), Paradign (POC 150), Soraya Soofer (POC 30), Cushman & Wakefield of Washington, D.C. (POC 109) and SRF Investments LLC (POC 116).
05/08/13 990.00RMK 3.30
Draft order approving omnibus objection to Paradigm claims (POC 149, 150).
05/08/13 90.00RMK 0.30
Draft order disallowing the following claims: Soraya Soofer (POC 30), Cushman & Wakefield (POC 109) and SRF Investments, LLC (POC 116).
05/08/13 120.00RMK 0.40
Draft communication to U. Raanan re hearing on the omnibus objections to the following claims: Paradigm (POC 149), Paradign (POC 150), Soraya Soofer (POC 30), Cushman & Wakefield of Washington, D.C. (POC 109) and SRF Investments LLC (POC 116).
05/08/13 60.00RMK 0.20
Multiple telephone conferences with M. Radfar re Trustee's objection to claim
05/08/13 180.00MC 0.80
Exhibit 2, Page 40
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 41
Date Description AmountAtty HoursTelephone conference with J. Far-hadian re Trustee's objection to POC 158
05/08/13 67.50MC 0.30
Review and analyze issues re telephone calls re objections to claims.05/09/13 90.00RMK 0.30Research re forwarding address for Cushman & Wakefield of Texas, Inc. (related to Claim number 109); prepare memo to R. Kido re same.
05/10/13 78.00ELL 0.40
Review and reply to email from S. Koenig re objection to secured claims.05/14/13 30.00RMK 0.10Review ECF email re filing of amended Proof of Claim by Bank of Nevada; access and obtain Proof of Claim and initial review of same; update the service list for Federal Rule of Bankruptcy Procedure 2002 notices regarding same.
05/15/13 19.50ELL 0.10
Review ECF email and obtain amended Proof of Claim filed by Starpoint Properties, LLC.
05/28/13 19.50ELL 0.10
Review Notice of Withdrawal of Proofs of Claim (Claim Nos. 488-490 and 492-503).
05/28/13 19.50ELL 0.10
Review ECF email and obtain amended Proof of Claim filed by Princeton Holdings, LLC (Claim No. 197).
05/29/13 19.50ELL 0.10
Review Notice of Withdrawal of Proof of Claim filed by Princeton Holdings, LLC (Claim No. 247).
05/29/13 19.50ELL 0.10
Telephone conference with E. Alyeshmerni re payment to one line guarantee claimants; discuss same with L. Shulman.
06/05/13 75.00MRD 0.20
Review and analyze issues re one line guarantees; prepare detailed instructions for crafting remaining objections on the issues.
06/06/13 367.50LMS 0.70
Draft Notice of Chapter 11 Trustee's Fifth Omnibus Motion for Order Disallowing Claims: Claim No. 39 - 87th Peoria, LLC.
06/07/13 52.50AMV 0.30
Draft Notice of Chapter 11 Trustee's Fifth Omnibus Motion for Order Disallowing Claims: Claim No. 157 - Ramin Gabayan.
06/07/13 52.50AMV 0.30
Draft Notice of Chapter 11 Trustee's Fifth Omnibus Motion for Order Disallowing Claims: Claim No. 189 - The MMN Family Trust.
06/07/13 52.50AMV 0.30
Review and finalize fifth omnibus motion for order disallowing claims for being improperly asserted against the Debtor.
06/10/13 120.00RMK 0.40
Review and finalize request for judicial notice filed in support of fifth omnibus motion for order disallowing claims for being improperly asserted against the Debtor.
06/10/13 60.00RMK 0.20
Analysis of issues re filing of Omnibus Motion objecting to claims.06/10/13 19.50ELL 0.10Review and revise notice of withdrawal of claim for Vasquez's proof of claim (POC 178).
06/11/13 30.00RMK 0.10
Review and revise notice of withdrawal of claim for Crawford Living Trust's proof of claim (POC 187).
06/11/13 30.00RMK 0.10
Prepare Notice of Withdrawal of Claim No. 178-1 of Ernesto and Socorro Vasquez; compile final with Withdrawal of Claim.
06/11/13 78.00ELL 0.40
Prepare Notice of Withdrawal of Claim No. 187-1 of The Crawford Family Trust Dated September 23, 1983; compile final with Withdrawal of
06/11/13 78.00ELL 0.40
Exhibit 2, Page 41
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 42
Date Description AmountAtty HoursClaim.Revise and prepare for final the Notice of Withdrawal of Claim No. 187-1 of The Crawford Family Trust Dated September 23, 1983 and prepare for electronic filing with the Court.
06/11/13 39.00ELL 0.20
Revise and prepare for final the Notice of Withdrawal of Claim No. 178-1 of Ernesto and Socorro Vasquez and prepare for electronic filing with the Court.
06/11/13 39.00ELL 0.20
Telephone conference with Mr. Doran re status of case.06/12/13 37.50MRD 0.10Prepare email to U. Raanan re status of his review and approval of Omnibus Motion for Order Disallowing Claims.
06/13/13 19.50ELL 0.10
Draft communication to U. Raanan re fifth omnibus objection to claims.06/14/13 30.00RMK 0.10Review and reply to communication from U. Raanan re including brief discussion re stipulated judgment in the objection to Peoria's claim.
06/14/13 30.00RMK 0.10
Draft multiple communications to U. Raanan re revisions to fifth omnibus claim, specifically objection to Peoria's claim.
06/14/13 60.00RMK 0.20
Review and revise fifith omnibus claim to include brief discussion re stipulated judgment between the Debtor and Peoria.
06/14/13 120.00RMK 0.40
Review and revise request for judicial notice to include stipulated judgment entered into between the Debtor and Peoria.
06/14/13 30.00RMK 0.10
Review and finalize fifth omnibus claim objection.06/14/13 120.00RMK 0.40Review and finalize request for judicial notice in support of fifth omnibus claim objection.
06/14/13 30.00RMK 0.10
Analysis of issues related to Motion objecting to claims and timing of filing same.
06/14/13 39.00ELL 0.20
Review and revise the Notice of Motion and Trustee's Omnibus Motion for Order Disallowing Claims: Claim No./Claimant No. 39 - 87th Peoria, LLC, No. 157 - Ramin Gabayan and No. 189 - The MMN Family Trust; compile final with all exhibits.
06/14/13 214.50ELL 1.10
Revise and prepare for final the Request for Judicial Notice in support of the Trustee's Omnibus Motion for Order Disallowing Claims: Claim No./Claimant No. 39 - 87th Peoria, LLC, No. 157 - Ramin Gabayan and No. 189 - The MMN Family Trust.
06/14/13 58.50ELL 0.30
Revise and compile final of the three Notice of Objection to Claim related to the Trustee's Omnibus Motion for Order Disallowing Claims: Claim No./Claimant No. 39 - 87th Peoria, LLC, No. 157 - Ramin Gabayan and No. 189 - The MMN Family Trust.
06/14/13 136.50ELL 0.70
Prepare for service and electronic filing with the Court the Notice of Objection to Claim (3) and the Trustee's Omnibus Motion for Order Disallowing Claims: Claim No./Claimant No. 39 - 87th Peoria, LLC, No. 157 - Ramin Gabayan and No. 189 - The MMN Family Trust and Request for Judicial Notice; prepare Judge's copy of documents for submission to Chambers as required by Local Rules.
06/14/13 214.50ELL 1.10
Review and analyze issues re S. Alyeshmerni's proof of claim and 06/14/13 90.00RMK 0.30
Exhibit 2, Page 42
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 43
Date Description AmountAtty HoursTrustee's objection re same for lack of guaranty.Review and analyze multiple correspondence re claim objections and guarantees in Namvar case.
06/14/13 75.00MRD 0.20
Review and approve for final omnibus claim objection pleadings. 06/17/13 262.50LMS 0.50Communications with clients re issues with claims work. 06/18/13 157.50LMS 0.30Review ECF email re confirmation of docketing of hearing on the Omnibus Motion Objecting to Claims scheduled for July 16, 2013.
06/19/13 19.50ELL 0.10
Review ECF email re filing of amended Proof of Claim by Theodore Kohan; Business to Business Markets, Inc.; Arizona Tempe Town Lake LLC; access and obtain Proof of Claim and update the service list for F.R.B.P. 2002 notices re same.
06/19/13 19.50ELL 0.10
Communications with Chair and prepare instructions re claims administrative issues.
06/20/13 210.00LMS 0.40
Review claims tracking chart. 06/21/13 19.50ELL 0.10Communications with clients re issues with claim objections and proposed additional work requested.
06/21/13 210.00LMS 0.40
Telephone conference with U. Ranaan re one line guarantee claims.06/24/13 150.00MRD 0.40Review and analyze issues re status of claim objections and outstanding issues which need to be addressed.
06/24/13 210.00RMK 0.70
Review and analyze issues re objections to secured claims and multiple duplicate claims.
06/24/13 225.00MRD 0.60
Conference call with U. Raanan and M. Lowe re status of claim objections, how to handle M. Alyeshmerni's claims, and one line guarantees.
06/24/13 120.00RMK 0.40
Telephone conference (left message for J. Osborne) re duplicate claims of Yacoobian entities.
06/24/13 37.50MRD 0.10
Review and analyze alleged secured claims to which to object.06/24/13 150.00MRD 0.40Review and analyze issues re E. Khavarani's claim against Namvar and identical claim against Namco.
06/26/13 180.00RMK 0.60
Review and analyze correspondence from T. Khavarani re Omnibus Claim Objection against POC No. 231.
06/26/13 90.00MC 0.40
Review and analyze multiple correspondence re claims objections on multiple duplicate claims.
06/26/13 37.50MRD 0.10
Telephone conference with J. Osborne re Yacoobian claims.06/27/13 37.50MRD 0.10Propose strategy re responding to correspondence on claim filed by E. Khavarani.
06/27/13 45.00MC 0.20
Telephone conference with E. Alyeshmerni re continuance of hearing on claim objection; discuss with U. Raanan.
06/28/13 75.00MRD 0.20
Review and analyze issues re claims lacking documentation in preparation for hearing.
06/28/13 120.00RMK 0.40
Prepare for hearing on motions to disallow claims lacking sufficient 07/01/13 150.00MRD 0.40
Exhibit 2, Page 43
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 44
Date Description AmountAtty Hoursdocumentation.Final preparations for and attend hearing on objection to claims lacking proper documentation.
07/02/13 525.00MRD 1.40
Review and analyze claims filed by M. Sakhai in Namco and in Namvar bankruptcy case.
07/02/13 67.50MC 0.30
Review and analyze issues re claim of M. Sakhai and his assertion that he has a claim against the Estate.
07/02/13 120.00RMK 0.40
Review and analyze issues re D. Kavarani claim and response re debt owed by Namvar and other claims objections re further documentation needed.
07/02/13 112.50MRD 0.30
Telephone conference with Mishel Sakhai regarding committee's objection to his claim and his request to additional time to respond and move hearing date.
07/02/13 52.50SPS 0.30
Review and analyze Reply to Third Omnibus Motion for Order Disallowing Claim No. 152 of the Yamin Family 1999 Limited Partnership.
07/03/13 90.00RMK 0.30
Draft communication to U. Raanan re Reply to Third Omnibus Motion for Order Disallowing Claim No. 152 of the Yamin Family 1999 Limited Partnership and recommendations re reply to same.
07/03/13 120.00RMK 0.40
Draft order approving omnibus motion objecting to claims which lack documentation.
07/03/13 90.00RMK 0.30
Review and analyze correspondence from U. Raanan re filing Reply to filed oppositions to Trustee's Objection to Claim No. 152.
07/03/13 45.00MC 0.20
Review and reply to communication from U. Raanan re Reply to Third Omnibus Motion for Order Disallowing Claim No. 152 of the Yamin Family 1999 Limited Partnership and recommendations re reply to same.
07/03/13 30.00RMK 0.10
Review and analyze filed Response to Trustee's Objection to Claim 152 and supporting declaration.
07/03/13 90.00MC 0.40
Review and analyze responses to various objections to claims; instructions for hearing.
07/03/13 367.50LMS 0.70
Prepare stipulation and order to continue hearing on objection to claim of M. Alyeshmerni; correspondence with claimant re same.
07/08/13 150.00MRD 0.40
Review and analyze attached exhibit re alleged collateral pledge by Debtor in support of Response to Trustee's Objection to Claim No. 152.
07/08/13 90.00MC 0.40
Review and analyze attached exhibit re payoff demand by claimant in support of Reply to Trustee's Objection to Claim No 152.
07/08/13 45.00MC 0.20
Prepare Reply filing in support of the Trustee's Objection to Claim No. 152.
07/08/13 270.00MC 1.20
Review and revise reply to opposition of Yamin Trust to disallow claim.07/09/13 75.00MRD 0.20Review and revise Reply to Opposition to Claim Objection re Claim No. 152 by the Yamin Family Partnership.
07/09/13 45.00MC 0.20
Review suggestions from U. Raanon and make corresponding amendments to Reply in support of Claim Objection to Claim No 152, and
07/09/13 67.50MC 0.30
Exhibit 2, Page 44
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 45
Date Description AmountAtty Hoursprovide instructions for filing. Telephone call from Karen at Judge Russell's chambers re status report on the Cushman claim.
07/09/13 30.00RMK 0.10
Draft status report re motion objecting to Cushman & Wakefield Claim (No. 109).
07/09/13 120.00RMK 0.40
Review and revise status report re motion objecting to Cushman & Wakefield Claim (No. 109).
07/09/13 60.00RMK 0.20
Prepare Reply in Support of Trustee's Third Omnibus Motion for Order Disallowing Claim No. 152 for service and e-filing with the Court.
07/09/13 105.00SPS 0.60
Prepare correspondence for U. Raanan re proposed Reply to opposition to claim objection re Claim No. 152.
07/09/13 22.50MC 0.10
Review and revise status report re motion objecting to Cushman & Wakefield Claim (No. 109).
07/10/13 30.00RMK 0.10
Review and revise reply to responses to objs to claims by various claimants.
07/10/13 210.00LMS 0.40
Review and analyze order continuing hearing on objection to claim of E. Alyeshmerni.
07/11/13 37.50MRD 0.10
Review and revise report re Cushman objection to claim. 07/11/13 105.00LMS 0.20Review and analyze issues re objections to secured claims and duplicative claims.
07/12/13 75.00MRD 0.20
Review and revise motion for order disallowing claims as secured claims.07/12/13 787.50MRD 2.10Discuss with U. Ranaan re objection to claims alleging personal guaranties.
07/12/13 75.00MRD 0.20
Review of chart re claim objections and work on strategies for finalizing remaining objections to claims.
07/12/13 180.00RMK 0.60
Review and analyze email from U. Raanan re M. Alyeshmerni's claim (POC 24) and continued hearing on claim objection re same.
07/12/13 30.00RMK 0.10
Multiple correspondence with W. Oetzell re duplicative claims of Laskas.07/15/13 37.50MRD 0.10Prepare email to J. Ozbirn re resolving duplicative claims of Yacoobians.07/15/13 37.50MRD 0.10Review and revise motion for order reclassifying secured claims to unsecured claims and related request for judicial notice.
07/15/13 337.50MRD 0.90
Review and revise request for judicial notice in support of objection to secured claims.
07/15/13 60.00RMK 0.20
Review and revise omnibus claim objection to secured claims to include correspondence sent to Shaw Blackstone re security interest alleged in their claim.
07/15/13 180.00RMK 0.60
Review and analyze status of claim objections and all documents sent re claim objections in preparation for hearing on the omnibus objections to claims (lack of documentation).
07/15/13 120.00RMK 0.40
Review and analyze filed Request for Judicial Notice by Yamin Family Trust re request for continuance on account of filed dischargeability complaint.
07/15/13 90.00MC 0.40
Exhibit 2, Page 45
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 46
Date Description AmountAtty HoursReview and analyze docket and status of adversary proceeding of nondischargeability complaint filed by claimant POC 152.
07/15/13 90.00MC 0.40
Review and analyze issues re objections to Yamin claims. 07/15/13 112.50MRD 0.30Review and analyze request for judicial notice filed in support of Yamin claim's response to trustee's objection.
07/15/13 60.00RMK 0.20
Review and analyze issues re Yamin claim's response to trustee's objection.
07/15/13 90.00RMK 0.30
Propose strategy to allow continuance of claim objection as to POC 152. 07/15/13 45.00MC 0.20Review and analyze issues re objection to the MMN Family Trust's claim.07/16/13 90.00RMK 0.30Draft order approving second omnibus motion objecting to claims (POC 117, 135, 136, 137).
07/16/13 60.00RMK 0.20
Draft order approving fourth omnibus motion objecting to Cushman & Wakefield claim (POC 109)
07/16/13 60.00RMK 0.20
Draft order approving fifth omnibus motion objecting to claims (POC 39, 157, 189).
07/16/13 90.00RMK 0.30
Draft order approving third omnibus motion objecting to claims (POC 144, 152, 158, 163, 231).
07/16/13 90.00RMK 0.30
Draft order approving first omnibus motion objecting to claims (POC 1, 10, 24, 34, 35, 36, 95, 96).
07/16/13 90.00RMK 0.30
Provide instructions to M. Choi re speaking to claimants without personal claims against E. Namvar case.
07/16/13 75.00MRD 0.20
Draft communication to U. Raanan and T. Neilson re result of hearings on the omnibus claims objecting to debts that are not debts of the debtor.
07/16/13 60.00RMK 0.20
Review and revise chart re status of resolution to claims with objections.07/16/13 180.00RMK 0.60Prepare for, travel to, and appear at hearings on Trustee's omnibus claim objections as claims against Namco and not against the Debtor.
07/16/13 1,012.50MC 4.50
Prepare correspondence for U. Raanan re status of claims 7, 10, 34, and 189.
07/16/13 45.00MC 0.20
Review and analyze status of disallowed claimants as filed claims in Namco Estate.
07/16/13 90.00MC 0.40
Review and analyze issues re additional objections which may be asserted against claimants with claims lacking evidence of a security interest.
07/17/13 120.00RMK 0.40
Telephone conference with Trustee of MMN Family Trust re claim filed in Namco Estate.
07/17/13 45.00MC 0.20
Prepare email for E. Negari of MMN Family Trust re claim filed in Namco Estate.
07/17/13 45.00MC 0.20
Review correspondence from U. Raanan re status of disallowed claims filed in Namco Case.
07/17/13 45.00MC 0.20
Review and analyze issues re personal guarantee claimants filing claims in Namco case.
07/17/13 75.00MRD 0.20
Draft Notice of Lodgment of Order Granting Chapter 11 Trustee's First 07/17/13 70.00AMV 0.40
Exhibit 2, Page 46
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 47
Date Description AmountAtty HoursOmnibus Motion Disallowing Claims: Claim No. 7 - Jonathan Baharvar; Claim No. 10 - Manouchehr Tabibzadeh; Claim No. 24 - Mansoor Alyeshmerni; Claim No. 34 - Mishel Sakhai; Claim No. 35 - Kamran Raminfard; Claim No. 95 Fred Mahjoubi; and Claim No. 96 - Ben Mahjoubi. Draft Notice of Lodgment of Order Granting Chapter 11 Trustee's Third Omnibus Motion Disallowing Claims: Claim No. 144 - Khalil Varastehpour; Claim No. 152 - The Yasmin Family 1999 Limited Partnership; Claim No. 158 - Iraj Farhadian fbo Farhadian Family Truste; Claim No. 163 - Bijan Nahai; Claim No. 197 - Princeton Holdings, LLC; and Claim No. 231 - Elodie Khavarani.
07/17/13 70.00AMV 0.40
Draft Notice of Lodgment of Order Granting Chapter 11 Trustee's Fifth Omnibus Motion Disallowing Claims: Claim No. 39 - 87th Peoria, LLC, Claim No. 157 - Ramin Gabayan, and Claim No. 189 - The MMN Family Trust.
07/17/13 70.00AMV 0.40
Review and revise objections to claims of Inland Mortgage, Shaw Blackstone and Wilshire State Bank.
07/17/13 682.50LMS 1.30
Review and analyze results of hearing in objections to claims re lack of consideration; prepare instructions.
07/17/13 210.00LMS 0.40
Review and analyze issues re duplicative claims and attempts to resolve without objection.
07/19/13 75.00MRD 0.20
Review and revise motion to disallow duplicate claims of Yacoobian parties.
07/23/13 525.00MRD 1.40
Review and analyze issues re duplicate Laska claims.07/23/13 37.50MRD 0.10Draft request for judicial notice in support of motion to disallow duplicate claims of Yacoobian parties.
07/23/13 112.50MRD 0.30
Review and revise omnibus objection to disallow Yacoobian claims on grounds of being duplicative.
07/24/13 120.00RMK 0.40
Discuss with U. Raanan re objection to duplicate claims of Yacoobians.07/25/13 112.50MRD 0.30Review and revise motion to disallow duplicate and disputed claims of Yacoobian parties to add section relating to claims being unliquidated and disputed.
07/25/13 825.00MRD 2.20
Telephone conference with Stacy re hearing date for motion objecting to Yacoobian claims.
07/25/13 37.50MRD 0.10
Review and revise request for judicial notice in support of motion to disallow duplicate claims of Yacoobian parties.
07/25/13 150.00MRD 0.40
Review and analyze correspondence from G. Elmer objection to Yacoobian claims.
07/26/13 37.50MRD 0.10
Telephone conference with G. Elmer re information to include in claim objections.
07/26/13 37.50MRD 0.10
Exhibit 2, Page 47
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 48
Date Description AmountAtty HoursReview and analyze issues re remaining objections to claims to be made.07/26/13 112.50MRD 0.30Email to and from E. Alyeshmerni re questions on his opposition to motion to disallow claim.
07/26/13 37.50MRD 0.10
Communications with Trustee tax counsel and prepare instructions re issues with debtor's books and records and making law of case.
07/26/13 262.50LMS 0.50
Review and approve for final another set of objections to claims. 07/26/13 210.00LMS 0.40Review and analyze open claim issues; prepare instructions for upcoming hearings.
07/29/13 262.50LMS 0.50
Review and analyze issues re objections to claims re personal guarantees.07/30/13 112.50MRD 0.30Telephone conference with E. Kohani re status of case.07/31/13 37.50MRD 0.10Telephone call from E. Denis re claim against the estate and documents received.
08/01/13 60.00RMK 0.20
Review and reply to communication from N. Cowen re Paris claims.08/06/13 30.00RMK 0.10Review and analyze correspondence from N. Cowen re claims for C. Paris.
08/06/13 37.50MRD 0.10
Review and analyze correspondence from J. Ozbirn re new counsel for Yacoobians.
08/09/13 37.50MRD 0.10
Review correspondence from U. O'Raanan re order sustaining Trustee's objection to POC 95 filed by F. Mahjoubi.
08/12/13 45.00MC 0.20
Review and analyze issues re objection to F. Mahjoubi's claim and claim filed in Namco bankruptcy.
08/12/13 60.00RMK 0.20
Draft facsimile to M. Radfar re claims filed in the Namvar and Namco bankruptcies.
08/13/13 30.00RMK 0.10
Telephone conference with E. Alyeshmerni re objection to his claim and possible resolution.
08/13/13 75.00MRD 0.20
Telephone conference with A. Baylash re change of address form.08/19/13 37.50MRD 0.10Review and analyze issues re claim filed by B. Broukhim08/19/13 30.00RMK 0.10Review ECF email re filing of Proof of Claim by Anthony Khosrow Mirzaie and Susan Mirzaie; access and obtain Proof of Claim; update the claims tracking chart and the service list for F.R.B.P. 2002 notices re same.
08/19/13 19.50ELL 0.10
Telephone conference with E. Alyeshmerni re filing of opposition to motion objecting to claim.
08/21/13 37.50MRD 0.10
Review and analyze correspondence from E. Alyeshmerni re opposition to objection to claim.
08/21/13 37.50MRD 0.10
Email to and from S. Golditch and others re claim of E. Alyeshmerni.08/26/13 75.00MRD 0.20Review Notice of Withdrawal of Proof of Claim #90 Filed by Wells Fargo Bank, N.A. as Trustee.
08/27/13 19.50ELL 0.10
Review and analyze issues and prepare instructions for 9/3 hearing on Omnibus objections.
08/29/13 210.00LMS 0.40
Review and analyze correspondence from M. Asheghian re creditors' 08/30/13 37.50MRD 0.10
Exhibit 2, Page 48
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 49
Date Description AmountAtty Hoursneeding further explanation from trustees. Review and analyze open issues and prepare final instructions for hearing.
09/03/13 157.50LMS 0.30
Prepare for and attend hearing on the motion objecting to M. Alyeshmerni's proof of claim.
09/03/13 1,290.00RMK 4.30
Draft order approving motion to disallow M. Alyeshmerni's claim.09/04/13 90.00RMK 0.30Draft Notice of Lodgment of Order Approving Chapter 11 Trustee's Omnibus Motion Disallowing Claim No. 24 - Mansoor Alyeshmerni.
09/04/13 35.00AMV 0.20
Review ECF email re filing of amended Proof of Claim by Paul and Judith Laska Family Trust of Oct. 9, 1997; access and obtain Proof of Claim and initial review of same; update the claims tracking chart and the service list for F.R.B.P. notices re same.
09/05/13 19.50ELL 0.10
Review Notice of Withdrawal of Claim No. 44 and Claim No. 179 by Paul and Judith Laska; update claims tracking chart re same.
09/05/13 19.50ELL 0.10
Review and analyze issues to finalize motion objecting to secured claims.09/13/13 150.00MRD 0.40Review and analyze documents supporting secured claim of S. Shakib re objection.
09/16/13 75.00MRD 0.20
Telephone conference with J. Ozbirn re claims of Yacoobians.09/19/13 37.50MRD 0.10Telephone conference with U. Raanan re claim of S. Shakib; provide notes to file re same.
09/19/13 112.50MRD 0.30
Review and revise motion to disallow secured claims.09/19/13 75.00MRD 0.20Prepare email to S. Oh re further information on Wilshire State Bank claim.
09/25/13 37.50MRD 0.10
Subtotal 342.20 96,505.50
Total Fees 342.20 96,505.50
Exhibit 2, Page 49
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 50
CostsDate Description Amount09/24/12 2.52Access and review PACER database for; Claims Register09/26/12 11.00Photocopy; Objection to Claim09/28/12 8.00Attorney and Messenger Service; Inv.2399000;09/28/2012;File and return conformed
copies of Docs09/28/12 8.00Attorney and Messenger Service; Inv.5031291;09/26/2012;File and return conformed
copies of File/Conform/Return09/28/12 8.00Attorney and Messenger Service; Inv.5031331;09/27/2012;File and return conformed
copies of Reply to Oppo10/02/12 0.48Access and review PACER database for; Claims Register10/02/12 0.96Access and review PACER database for; Image26379018-010/02/12 0.60Access and review PACER database for; Claims Register10/02/12 0.12Access and review PACER database for; Claims Register10/08/12 102.80Photocopy; Objection to Claim10/18/12 54.00Photocopy; Objection to Claim10/24/12 3.60Access and review PACER database for; Claims Register12/31/12 13.95Computer Research; Inv. 1212015447;12/31/12;Computer research ; Lexis Nexis01/18/13 2.64Access and review PACER database for; Claims Register01/23/13 2.64Access and review PACER database for; Claims Register01/28/13 2.64Access and review PACER database for; Claims Register01/30/13 35.00Photocopy; Objection to Claim01/31/13 2.64Access and review PACER database for; Claims Register01/31/13 0.12Access and review PACER database for; Image29692164-001/31/13 7.20Access and review PACER database for; Docket Report01/31/13 0.36Access and review PACER database for; Associated Cases01/31/13 3.24Access and review PACER database for; Image1430-001/31/13 0.84Access and review PACER database for; Image1449-002/01/13 8.00Attorney and Messenger Service; Inv.5049515;02/01/2013;File and return conformed
copies of Ntc and Mtn 02/05/13 3.60Access and review PACER database for; Claims Register02/05/13 16.80Photocopy; Objection to Claim02/19/13 0.96Access and review PACER database for; Image24423026-002/19/13 0.96Access and review PACER database for; Image24423026-102/19/13 3.60Access and review PACER database for; Claims Register02/25/13 3.60Access and review PACER database for; Docket Report02/25/13 1.08Access and review PACER database for; Image397-002/25/13 0.60Access and review PACER database for; Image737-0
Exhibit 2, Page 50
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 51
Date Description Amount02/25/13 5.04Access and review PACER database for; Docket Report02/25/13 2.76Access and review PACER database for; Associated Cases02/25/13 0.84Access and review PACER database for; Image9-002/25/13 0.48Access and review PACER database for; Image15-002/25/13 0.60Access and review PACER database for; Image15-002/25/13 0.48Access and review PACER database for; Image16-002/25/13 0.84Access and review PACER database for; Image16-002/25/13 0.48Access and review PACER database for; Image17-002/25/13 0.96Access and review PACER database for; Image13-002/25/13 0.84Access and review PACER database for; Docket Report02/28/13 16.53Computer Research; Inv. 1302015372;2/28/13;Computer Research ; Lexis Nexis03/07/13 10.20Photocopy; Motion03/07/13 2.52Postage03/13/13 0.60Access and review PACER database for; Claims Register03/13/13 0.12Access and review PACER database for; Claims Register03/13/13 3.60Access and review PACER database for; Claims Register03/13/13 3.60Access and review PACER database for; Docket Report03/13/13 3.60Access and review PACER database for; Image770-003/13/13 3.60Access and review PACER database for; Image770-103/13/13 3.60Access and review PACER database for; Image770-203/20/13 2.64Access and review PACER database for; Claims Register03/22/13 7.20Access and review PACER database for; Docket Report03/22/13 3.60Access and review PACER database for; Image373-003/22/13 0.84Access and review PACER database for; Image391-003/22/13 0.60Access and review PACER database for; Image392-003/22/13 3.60Access and review PACER database for; Docket Report03/26/13 3.60Access and review PACER database for; Docket Report03/31/13 17.89Computer Research; Inv. 13030115329;3/31/13;Computer research ; Lexis Nexis04/02/13 477.00Photocopy; Objection to Claim04/05/13 3.60Access and review PACER database for; Docket Report04/05/13 0.96Access and review PACER database for; Image1925-004/05/13 3.60Access and review PACER database for; Image1925-104/05/13 2.16Access and review PACER database for; Image2114-004/05/13 0.12Access and review PACER database for; Claims Register04/05/13 0.24Access and review PACER database for; Image30126189-004/17/13 155.00Photocopy; Objection to Claim04/17/13 8.85Postage04/17/13 5.60Postage
Exhibit 2, Page 51
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 52
Date Description Amount04/17/13 5.60Postage04/17/13 5.60Postage04/17/13 5.60Postage04/19/13 8.00Attorney and Messenger Service; Inv. 5050544;4/19/13;file and return conformed copies
of order04/24/13 349.60Photocopy; Objection to Claim04/24/13 13.50Postage04/24/13 44.80Postage04/26/13 330.00Photocopy; Objection to Claim04/26/13 7.56Postage04/26/13 7.45Postage04/26/13 5.80Postage04/26/13 15.12Postage04/29/13 67.60Photocopy; Objection to Claim05/01/13 1.92Access and review PACER database for; Docket Report05/02/13 3.72Access and review PACER database for; Claims Register05/03/13 8.00Attorney and Messenger Service; Inv.5050687;04/29/2013;File and return conformed
copies of Ntc of Objection;Mtn;RJN05/03/13 8.00Attorney and Messenger Service; Inv.5050739;05/03/2013;File and return conformed
copies of Notice drop off in bin suite 166005/08/13 85.00Photocopy; Objection to Claim05/10/13 1.32Postage05/10/13 12.00Postage05/10/13 58.58Computer Research; Inv. 1304015304;4/30/13;Computer Research ; Lexis Nexis05/20/13 5.60Photocopy; Objection to Claim05/20/13 0.66Postage05/20/13 1.98Postage06/11/13 2.28Access and review PACER database for; Claims Register06/11/13 2.04Access and review PACER database for; Docket Report06/11/13 5.20Photocopy; Objection to Claim06/11/13 0.66Postage06/11/13 0.66Postage06/11/13 0.66Postage06/14/13 140.40Photocopy; Objection to Claim06/14/13 9.75Postage06/14/13 8.16Postage06/14/13 5.80Postage06/24/13 3.60Access and review PACER database for; Claims Register
Exhibit 2, Page 52
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 53
Date Description Amount06/25/13 2.28Access and review PACER database for; Docket Report06/26/13 10.92Access and review PACER database for; Claims Register06/26/13 1.08Access and review PACER database for; Image30687111-006/26/13 7.20Access and review PACER database for; Docket Report06/26/13 1.08Access and review PACER database for; Image2132-006/26/13 1.32Access and review PACER database for; Image2152-007/02/13 0.36Access and review PACER database for; Image25366115-007/03/13 3.60Access and review PACER database for; Claims Register07/03/13 6.20Photocopy; Order07/03/13 1.98Postage07/03/13 1.32Postage07/08/13 7.80Photocopy; Stipulation to Continue Hearing07/08/13 0.66Postage07/08/13 2.12Postage07/10/13 7.80Photocopy; Objection to Claim07/10/13 1.92Postage07/10/13 0.66Postage07/11/13 0.66Postage07/12/13 8.00Attorney and Messenger Service; Inv.5051563;07/10/2013;File and return conformed
copies of reply07/16/13 8.32Federal Express; Inv. 2-334-46270;7/12/13;Overnight delivery on 7/10/13 to M. Berger,
Beverly Hills; Federal Express07/16/13 3.60Access and review PACER database for; Claims Register07/16/13 3.36Access and review PACER database for; Docket Report07/16/13 0.84Access and review PACER database for; Image1477-007/16/13 4.80Photocopy; Order07/16/13 2.64Postage07/17/13 0.12Access and review PACER database for; Claim History07/17/13 3.60Access and review PACER database for; Claims Register07/17/13 50.20Photocopy; Order07/17/13 5.28Postage07/17/13 1.98Postage07/17/13 3.96Postage07/17/13 5.80Postage07/23/13 2.28Access and review PACER database for; Claims Register07/25/13 2.28Access and review PACER database for; Claims Register07/25/13 229.80Photocopy; Objection to Claim07/26/13 8.00Attorney and Messenger Service; Inv.5051815;07/26/2013;File and return conformed
Exhibit 2, Page 53
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 54
Date Description Amountcopies of Ntc of Mtn;Rjn;Ntc of Claim;Exhibits
07/26/13 130.00Photocopy; Objection to Claim07/26/13 56.00Photocopy; Objection to Claim07/26/13 16.20Photocopy; Objection to Claim07/26/13 74.00Photocopy; Objection to Claim07/26/13 3.44Postage07/26/13 6.60Postage07/30/13 3.60Access and review PACER database for; Claims Register07/30/13 30.80Photocopy; Order07/30/13 13.86Postage07/31/13 39.12Computer Research; Inv. 1307015196;7/31/13;Computer Research ; Lexis Nexis08/07/13 2.88Access and review PACER database for; Docket Report08/07/13 1.92Access and review PACER database for; Image1497-008/07/13 1.32Access and review PACER database for; Image1630-008/07/13 1.44Access and review PACER database for; Image1631-008/07/13 7.80Photocopy; Motion08/08/13 3.60Access and review PACER database for; Docket Report08/08/13 1.68Access and review PACER database for; Image292-008/08/13 56.12Postage08/09/13 2.76Postage08/13/13 2.28Access and review PACER database for; Claims Register08/13/13 3.60Access and review PACER database for; Claims Register08/13/13 1.20Access and review PACER database for; Image25057718-008/13/13 2.04Access and review PACER database for; Image27288487-008/13/13 3.60Access and review PACER database for; Docket Report08/13/13 3.60Access and review PACER database for; Claims Register08/13/13 2.28Access and review PACER database for; Claims Register08/14/13 8.00Parking; Parking expense at hearing on 7/16/13; Michelle Choi08/15/13 0.46Postage08/16/13 2.28Access and review PACER database for; Claims Register08/20/13 0.46Postage08/21/13 0.46Postage08/21/13 0.46Postage08/23/13 3.60Access and review PACER database for; Docket Report08/26/13 5.88Access and review PACER database for; Claims Register08/28/13 0.46Postage09/13/13 2.40Access and review PACER database for; Claims Register
Exhibit 2, Page 54
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 55
Date Description Amount
Total Disbursements 3,201.18
Exhibit 2, Page 55
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 56
Fee Recap by Task Code**Claims Administration & Objections**
Rika M. Kido 158.90 300.00 47,005.00Melissa R. Davis 34.40 375.00 12,370.00Michelle Choi 66.90 225.00 14,950.50Erlanna L. Lohayza 48.50 195.00 9,457.50Anne Marie Vernon 8.20 175.00 1,435.00Steve P. Swartzell 5.70 175.00 997.50Leonard M. Shulman 19.60 525.00 10,290.00
96,505.50Subtotal
96,505.50
Exhibit 2, Page 56
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 57
Fees by Month
9/1/2012Davis, Melissa R. 2.60 845.00Kido, Rika M. 2.70 675.00
Subtotal 1,520.00
10/1/2012Davis, Melissa R. 6.70 2,177.50Kido, Rika M. 2.90 725.00Shulman, Leonard M. 0.40 210.00
Subtotal 3,112.50
11/1/2012Davis, Melissa R. 0.60 195.00Lohayza, Erlanna L. 0.10 19.50Shulman, Leonard M. 0.40 210.00
Subtotal 424.50
12/1/2012Choi, Michelle 3.40 663.00Davis, Melissa R. 0.70 227.50Kido, Rika M. 7.70 1,925.00Lohayza, Erlanna L. 0.20 39.00
Subtotal 2,854.50
1/1/2013Choi, Michelle 34.30 7,717.50Davis, Melissa R. 2.00 750.00Kido, Rika M. 19.50 5,850.00Lohayza, Erlanna L. 21.50 4,192.50Shulman, Leonard M. 2.30 1,207.50
Subtotal 19,717.50
2/1/2013Choi, Michelle 6.80 1,530.00Davis, Melissa R. 1.20 450.00Kido, Rika M. 30.30 9,090.00
Exhibit 2, Page 57
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 58
Lohayza, Erlanna L. 6.60 1,287.00Shulman, Leonard M. 2.40 1,260.00
Subtotal 13,617.00
3/1/2013Choi, Michelle 0.50 112.50Davis, Melissa R. 0.80 300.00Kido, Rika M. 41.10 12,330.00Lohayza, Erlanna L. 1.30 253.50Shulman, Leonard M. 1.60 840.00Swartzell, Steve P. 2.70 472.50
Subtotal 14,308.50
4/1/2013Choi, Michelle 9.50 2,137.50Davis, Melissa R. 1.50 562.50Kido, Rika M. 30.10 9,030.00Lohayza, Erlanna L. 12.40 2,418.00Shulman, Leonard M. 5.10 2,677.50Swartzell, Steve P. 0.40 70.00Vernon, Anne Marie 5.90 1,032.50
Subtotal 17,928.00
5/1/2013Choi, Michelle 1.60 360.00Davis, Melissa R. 0.50 187.50Kido, Rika M. 6.80 2,040.00Lohayza, Erlanna L. 0.90 175.50Swartzell, Steve P. 1.70 297.50
Subtotal 3,060.50
6/1/2013Choi, Michelle 0.60 135.00Davis, Melissa R. 2.40 900.00Kido, Rika M. 4.60 1,380.00Lohayza, Erlanna L. 5.10 994.50Shulman, Leonard M. 2.30 1,207.50Vernon, Anne Marie 0.90 157.50
Exhibit 2, Page 58
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 59
Subtotal 4,774.50
7/1/2013Choi, Michelle 10.00 2,250.00Davis, Melissa R. 13.10 4,912.50Kido, Rika M. 7.90 2,370.00Shulman, Leonard M. 4.40 2,310.00Swartzell, Steve P. 0.90 157.50Vernon, Anne Marie 1.20 210.00
Subtotal 12,210.00
8/1/2013Choi, Michelle 0.20 45.00Davis, Melissa R. 1.00 375.00Kido, Rika M. 0.70 210.00Lohayza, Erlanna L. 0.20 39.00Shulman, Leonard M. 0.40 210.00
Subtotal 879.00
9/1/2013Davis, Melissa R. 1.30 487.50Kido, Rika M. 4.60 1,380.00Lohayza, Erlanna L. 0.20 39.00Shulman, Leonard M. 0.30 157.50Vernon, Anne Marie 0.20 35.00
Subtotal 2,099.00
Total Fees 342.20 96,505.50
Exhibit 2, Page 59
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 60
Monthly Fees Task RecapDate Description AmountHours
09/2012**Claims Administration & Objections** 5.30 1,520.00
Subtotal 1,520.00
10/2012**Claims Administration & Objections** 10.00 3,112.50
Subtotal 3,112.50
11/2012**Claims Administration & Objections** 1.10 424.50
Subtotal 424.50
12/2012**Claims Administration & Objections** 12.00 2,854.50
Subtotal 2,854.50
01/2013**Claims Administration & Objections** 79.60 19,717.50
Subtotal 19,717.50
02/2013**Claims Administration & Objections** 47.30 13,617.00
Subtotal 13,617.00
03/2013**Claims Administration & Objections** 48.00 14,308.50
Subtotal 14,308.50
04/2013**Claims Administration & Objections** 64.90 17,928.00
Subtotal 17,928.00
05/2013**Claims Administration & Objections** 11.50 3,060.50
Exhibit 2, Page 60
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 61
Subtotal 3,060.50
06/2013**Claims Administration & Objections** 15.90 4,774.50
Subtotal 4,774.50
07/2013**Claims Administration & Objections** 37.50 12,210.00
Subtotal 12,210.00
08/2013**Claims Administration & Objections** 2.50 879.00
Subtotal 879.00
09/2013**Claims Administration & Objections** 6.60 2,099.00
Subtotal 2,099.00
Total Fees 342.20 96,505.50
Exhibit 2, Page 61
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 62
Cost Recap by Task Code
216.48PACER charges 72.00Attorney and Messenger service
2,466.60Photocopy146.07Computer Research283.71Postage
8.32Federal Express8.00Parking
Subtotal 3,201.18
Total Disbursements 3,201.18
Exhibit 2, Page 62
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 63
Monthly Cost Task RecapAmountDescriptionDate
09/2012
24.00Attorney and Messenger Service2.52Pacer
11.00PhotocopySubtotal 37.52
10/2012
5.76Pacer156.80Photocopy
Subtotal 162.56
12/2012
13.95Other ServicesSubtotal 13.95
01/2013
22.32Pacer35.00Photocopy
Subtotal 57.32
02/2013
8.00Attorney and Messenger Service16.53Other Services
27.72Pacer16.80Photocopy
Subtotal 69.05
03/2013
17.89Other Services40.80Pacer
10.20Photocopy2.52Postage
Subtotal 71.41
04/2013
8.00Attorney and Messenger Service
Exhibit 2, Page 63
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 64
AmountDescriptionDate10.68Pacer
1,379.20Photocopy125.48Postage
Subtotal 1,523.36
05/2013
16.00Attorney and Messenger Service58.58Other Services5.64Pacer
90.60Photocopy15.96Postage
Subtotal 186.78
06/2013
31.80Pacer145.60Photocopy25.69Postage
Subtotal 203.09
07/2013
16.00Attorney and Messenger Service8.32Federal Express
39.12Other Services23.64Pacer
613.60Photocopy
52.88PostageSubtotal 753.56
08/2013
43.20Pacer8.00Parking7.80Photocopy
61.18PostageSubtotal 120.18
09/2013
2.40Pacer
Exhibit 2, Page 64
Shulman Hodges & Bastian LLP
R. Todd Neilson September 26, 2013Re: Claims Work/Neilson-11TTI.D. 3985-001 - LMS
Invoice 70324Page 65
AmountDescriptionDateSubtotal 2.40
3,201.18Total Costs
Exhibit 2, Page 65
EXHIBIT 3
Biographies
EXHIBIT 3 - PAGE 1
PARTNERS SHULMAN, LEONARD M., born Los Angeles, California, June 1, 1961; Admitted to bar, 1986, California, U.S. District Court, Central, Eastern, Northern and Southern Districts of California. Education: University of California at San Diego (B.A. Magna Cum Laude, 1983); University of San Diego (J.D. 1986). Regent Scholar. Member: 1984-1986 and Comments Editor, 1985-1986, University of San Diego Law Review. Author: "Compensation for Collegiate Athletes: A Run for More Than Roses" 22 San Diego Law Review 701 (1986); Case Note, "Matter of Western Electronics, Inc.," 16 Cal. Bankr. J. 23 (Winter, 1988); Article, "Reasonable Reliance on a False Financial Statement," 17 Cal. Bankr. J. 225, 1989. Co-Author, Article "A Retrospect: 1989 Ninth Circuit Bankruptcy Decisions," Cal. Bankr. J. 1990. Author: Article, "Abatement of a Landlord's Rights under the Shopping Center Amendments: Section 365(d)(2) Does Not Mean What It Says," 18 Cal. Bankr. J. 851, 1990; "In re Mercado: Enjoining the Collection Efforts of a Holder of a Nondischargeable Claim," Norton Bankruptcy Law Advisor, October, 1991; "Armed and Dangerous: Continuation of a Receiver in Bankruptcy, "Norton Bankruptcy Law Advisor, May 1992; "Is It Fair and Equitable to Alter the Bargained-for Exchange," The Bankruptcy Strategies, June 1992. “Supergeneric Descriptions of Debtor’s Holdings Won’t Do,” Los Angeles Daily Journal, Business Law Section, August, 2005. “A Debtor’s Right to Silence in a Bankruptcy Proceeding,” Orange County Lawyer, September 2005; “Running On Empty: The Limitations Period On Installment Obligations,” Orange County Business Journal, November 2006. Featured Speaker: "Pitfalls of Practice in Bankruptcy Court, Central District of California," December 1989, San Diego Bar Association; "How Reasonable Must Reliance Be on a False Financial Statement?" May 1990, Orange County Bar Association; "Bankruptcy in Today's Real Estate Market," February 1991, California Real Estate Investment Forum; "Automatic Stay -- Pitfalls of Practice," December 1991, Orange County Bar Association Creditors' Rights Section; "Automatic Stay -- Pitfalls of Practice," June 1992, Orange County Paralegal Association; "Representation of Creditors= Committees" (April 1993, Orange County Paralegal Association). Panelist: "Litigating Nondischargeability Actions" December 1990, Orange County Bankruptcy Forum; "Litigating Preference Actions," June 1991, Orange County bankruptcy Forum; "Handling a Chapter 11 Case," January 1992, Continuing Education of the Bar; "Bankruptcy Issues for the Real Estate Practitioner," June 1992, Orange County Bankruptcy Forum; "Bankruptcy Evidence I: Overcoming Evidentiary Roadblocks" (June 1992, Orange County Bankruptcy Program). "1994 Bankruptcy Reform Act" (November, 1994, Orange County Bankruptcy Forum); "Handling a Chapter 11 Reorganization The Right Way" (January 1994, CEB). “Small Business Chapter 11 Bankruptcies” (January 2008, Orange County Bankruptcy Forum); Moderator: "Employment of Professionals In Bankruptcy" (March 1994, Orange County Bar Association (Commercial Law and Bankruptcy Section); "What Price Justice: Is There an Exception to the Absolute Priority Rule?" January 1993, Orange County Bankruptcy Forum; "Law Practice Management for Bankruptcy Practitioners," April 1993, Orange County Bankruptcy Forum. Memberships: Member, Board of Directors, Orange County Bankruptcy Forum, 1991-1995 (Past President, 1995); California State Bar Association 1986 - Present. Member, Board of Directors, Pediatric Cancer Research Foundation (President 2006-2007). HODGES, RONALD S., born Santa Monica, California, December 29, 1964; admitted to California Bar, 1990; admitted to Bar in District of Columbia, Court of Appeal, 1992; U.S. District Court, Central District of California, Northern District of California, 1996. Education: Loyola Marymount University (B.A. 1987); Loyola University School of Law (J.D. 1990). Recipient, American Jurisprudence Award: Trial Skills. Formerly: Judicial Extern to the Honorable Harvey A. Schneider, Superior Court of California, Los Angeles, 1989. Memberships: American Bar Association; California State Bar Association; Orange County Bar Association; Riverside County Bar Association; Defense Research Institute; Association of Southern California Defense Counsel. ASSOCIATES KIDO, RIKA M., born Tokyo, Japan, March 12, 1981; admitted to the California Bar, 2010; admitted to the U.S. District Court, Central District of California, 2010. Education: Middlebury College (B.A., 2003); University of California, San Diego (M.P.I.A., 2007); University of San Francisco School of Law (J.D., 2010). Recipient, CALI Excellence for the Future Award for highest grade in Legal Research & Writing I, Legal Research & Writing II, and International Business Transactions. Technical Editor, 2008, Assistant Literary Editor, 2008-2009, and Literary Editor, 2009-2010, USF Maritime Law Journal. Co-Author: “Operator, Can You Get Me an Extension? Extending the Automatic Stay to Non-Debtor Parties,” 30 CAL. BANKR. J. 361 (2010). LOWE, MELISSA DAVIS, Melissa is a member of the firm’s Bankruptcy and Reorganization department and is a resident of the Irvine office. Ms. Lowe graduated magna cum laude from the Honors College at the University of Arizona with a B.S.B.A. in Finance in 2003. Ms. Lowe earned her J.D. in 2006 from Loyola Law School in Los Angeles and earned her Tax LL.M. from Loyola Law School in 2008. During law school, Ms. Lowe was a staff member of the Loyola Entertainment Law Review and a Scott Moot Court competitor and competed as a finalist in the American Bar Association Law Student Tax Challenge. She also held several leadership positions at the University of Arizona and at Loyola, including President of Phi Alpha Delta. Ms. Lowe is admitted to practice before the United States District Court for the Central, Southern, and Eastern District of California and all the courts of the State of California. Ms. Lowe is active in the community. She is a member of the Orange County Bankruptcy
EXHIBIT 3 - PAGE 2
Forum, serving as its Secretary for 2011 and Vice President for 2012, and of the Orange County Bar Association, and is active in the Junior League of Orange County, California, as well as her church. CHOI, MICHELLE S., Michelle is a member of the firm’s Bankruptcy and Reorganization department. Ms. Choi graduated from the University of California, San Diego in 2008 with a B.A. in Sociology and a minor emphasis in Law and Society, placing on the dean’s honor roll in multiple semesters. Prior to entering law school, Ms. Choi taught classes and tutored students in preparation for the LSAT. Ms. Choi received her law degree in 2012 from The University of Michigan Law School, where she served as the Vice President of the Asian Pacific American Law Student Association. During the summer after her first year of law school, Ms. Choi served as a judicial extern to the Honorable Jamoa A. Moberly (Orange County Superior Court, Civil Division). Ms. Choi studied abroad in 2011 at the University of College London in Great Britain, with a focus on International Insolvency Law. Ms. Choi started with the firm as a summer clerk after her second year of law school, and returned to the firm upon graduating. Ms. Choi was admitted to the California Bar in 2012, and is admitted to practice before the United States District Court for the Central District of California. Ms. Choi was born and raised in Orange County, is involved with her church and with local politics in the City of Irvine, where she currently resides. PARAPROFESSIONALS LOHAYZA, ERLANNA L., Education: Paralegal Program, University of California at Irvine, Extension, American Bar Association Certification (Completion 1996); Member: Orange County Paralegal Association. Formerly: Recording Secretary for Newport-Santa Ana Legal Secretaries Association (now known as NALS of Orange County), 2000-2002. CLAPP, LORRE, Education: California State University, Long Beach (B.A. 1978); Paralegal Program, University of California at Irvine, Extension. American Bar Association Certification (Completion 1985). SWARTZELL, STEVEN P., Education: Fullerton College (A.S. 1993), Paralegal Certificate Program, Fullerton College, American Bar Association Certification (Completion 1993); Member: Orange County Paralegal Association; West Coast Association of Paralegals. VERNON, ANNE MARIE, Education: Coastline Community College, Costa Mesa (A.A. 2004); Paralegal Program, Coastline Community College, American Bar Association Certification (Completion 2004). Member: Orange County Paralegal Association; Orange County Legal Secretaries Association.
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 8105 Irvine Center Drive, Suite 600, Irvine, California 92618 A true and correct copy of the foregoing document entitled (specify): FIFTH INTERIM APPLICATION FOR APPROVAL OF FEES AND REIMBURSEMENT OF EXPENSES BY SHULMAN HODGES & BASTIAN LLP, ATTORNEYS FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS; AND SECOND INTERIM APPLICATION FOR APPROVAL OF FEES AND REIMBURSEMENT OF EXPENSES OF SHULMAN HODGES & BASTIAN LLP, SPECIAL CLAIMS COUNSEL FOR R. TODD NEILSON, CHAPTER 11 TRUSTEE; DECLARATION OF LEONARD M. SHULMAN IN SUPPORT THEREOF will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) September 26, 2013, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:
Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On (date) September 26, 2013, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. Debtor Ezri Namvar 12855 Parkyns Street Los Angeles, CA 90049
Interested PartyOffice of the U.S. Trustee 725 South Figueroa Street, Suite 2600 Los Angeles, CA 90017
Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) September 26, 2013, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Committee Member (via Email) Hersel Babajoni Email: [email protected]; [email protected]
Committee Member (via Email)Marc Asheghian Email: [email protected]
Committee Member (via Email)Elliott Sharaby Email: [email protected]
Chapter 11 Trustee (via Email) R. Todd Neilson BRG, LLP Email: [email protected]
Judge’s Copy (via Messenger)U.S. Bankruptcy Court Attn: Honorable Barry Russell 255 East Temple Street Bin Outside of Suite 1660 Los Angeles, CA 90012
Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.
September 26, 2012 Lorre Clapp /s/ Lorre Clapp Date Printed Name Signature
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
NEF SERVICE LIST
Theresa W Bangert on behalf of Creditor Inland Mortgage Capital Corporation [email protected]
Richard T Baum on behalf of Creditor BH Commercial Capital, Inc. [email protected], [email protected]
Michael Jay Berger on behalf of Interested Party Courtesy NEF [email protected], [email protected]
Stephen F Biegenzahn on behalf of Attorney Law Offices of Stephen F. Biegenzahn [email protected]
Christopher L Blank on behalf of Mediator Christopher Blank [email protected]
Linda M Blank on behalf of Mediator Linda Blank [email protected]
Vivian Bodey on behalf of Counter-Claimant United States Of America [email protected]
David W Brody on behalf of Creditor American Savings Bank [email protected], [email protected]
Alan F Broidy on behalf of Creditor Interested Party [email protected], [email protected]
Gillian N Brown on behalf of Interested Party Bradley D. Sharp, Chapter 11 Trustee for Namco Capital Group, Inc. [email protected], [email protected]
Richard W Brunette [email protected] NEF for interested party
Rebecca A Caley on behalf of Creditor Financial Services Vehicle Trust, by and through its servicer, BMW Financial Services NA, LLC [email protected]
J Sheldon Capeloto on behalf of Interested Party Courtesy NEF [email protected]
Candace Carlyon on behalf of Creditor Community Bank of Nevada [email protected]
Jeffrey D Cawdrey on behalf of Interested Party Garrison Credit Investments I, LLC [email protected], [email protected]
Sara Chenetz on behalf of Creditor BurBank LLC [email protected], [email protected];[email protected]
Michelle S Choi [email protected], [email protected] NEF for the Trustee
Carol Chow [email protected] NEF for interested party
Mark M Clairmont on behalf of Creditor Outsource Services Mgn. [email protected]
Yona Conzevoy on behalf of Interested Party Informal Credit Group of Namco and Namvar [email protected]
Dawn M Coulson on behalf of Interested Party Courtesy NEF [email protected]
Ashleigh A Danker on behalf of Creditor Solomon Rastegar [email protected], [email protected];[email protected]
Brian L Davidoff on behalf of Creditor Mousa Namvar [email protected], [email protected];[email protected]
Richard K Diamond on behalf of Attorney Danning Gill Diamond & Kollitz [email protected], [email protected];[email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
Richard K Diamond on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected]
Caroline Djang on behalf of Interested Party Courtesy NEF [email protected]
Mark Domeyer on behalf of Interested Party Courtesy NEF [email protected]
Joseph A Eisenberg on behalf of Interested Party Courtesy NEF [email protected]
Lei Lei Wang Ekvall on behalf of Interested Party Courtesy NEF [email protected]
James R Felton on behalf of Defendant Homa Sarshar [email protected]
H Alexander Fisch on behalf of Creditor Canyon Springs Shopping Center, LLC, a California limited liability company [email protected]
Michael G Fletcher on behalf of Creditor Carhay Bank [email protected], [email protected];[email protected]
Heather Fowler on behalf of Interested Party Courtesy NEF [email protected], [email protected]
Jon H Freis on behalf of Interested Party Courtesy NEF [email protected]
Sandford Frey on behalf of Creditor Committee Official Unsecured Creditors' Committee of Namco Capital Group, Inc. [email protected]
Jerome Bennett Friedman [email protected], [email protected];[email protected];[email protected] NEF for interested party
Amir Gamliel on behalf of Interested Party Garrison Credit Investments I, LLC [email protected], [email protected]
Philip A Gasteier on behalf of Interested Party Courtesy NEF [email protected]
Randi R Geffner on behalf of Defendant Ezri Namvar [email protected]
Randi R Geffner on behalf of Plaintiff Sam Sohrab Shakib [email protected]
Thomas M Geher on behalf of Plaintiff Bradley Sharp [email protected]
Julia P Gibbs on behalf of Plaintiff Park General LLC [email protected]
Bernard R Given on behalf of Interested Party Courtesy NEF [email protected], [email protected]
Barry S Glaser on behalf of Creditor Paradigm Tax Group, LLC [email protected]
Jeffrey I Golden on behalf of Creditor Roya Boucherian [email protected], [email protected]
Stanley E Goldich on behalf of Trustee R. Todd Neilson (TR) [email protected]
David Gould on behalf of Interested Party Courtesy NEF [email protected]
Matthew Grimshaw on behalf of Interested Party Parviz Lavi [email protected]
Irving M Gross on behalf of Interested Party Courtesy NEF [email protected], [email protected]
Stacy W Harrison on behalf of Creditor DB Private Wealth Mortgage Ltd. [email protected], [email protected]
Rochelle A Herzog on behalf of Creditor Interested Party [email protected]
Kimberly D Howatt on behalf of Interested Party Garrison Credit Investments I, LLC [email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
William W Huckins on behalf of Creditor Robert Hanasab [email protected], [email protected]
James KT Hunter on behalf of Trustee R. Todd Neilson (TR) [email protected]
Allan H Ickowitz [email protected], [email protected] NEF for interested party
Eric P Israel on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected]
Lemuel B Jaquez [email protected] NEF for interested party
Seymone Javaherian on behalf of Interested Party Courtesy NEF [email protected]
Peter F Jazayeri on behalf of Creditor BurBank LLC [email protected]
David Joe on behalf of Creditor Mousa Namvar [email protected], [email protected]
David S Kadin [email protected] NEF for interested party
David S Kadin [email protected] NEF for interested party
Jerome Kaplan on behalf of Plaintiff M & Y MANAGEMENT, INC. [email protected], [email protected]
Rika Kido on behalf of Trustee R. Todd Neilson (TR) [email protected]
George H Kim on behalf of Interested Party Courtesy NEF [email protected]
Yale K Kim on behalf of Creditor Starpoint Properties, LLC [email protected]
Yi S Kim [email protected] NEF for interested party
Benjamin R King on behalf of Plaintiff Gordon Karsin [email protected], [email protected]
Stuart I Koenig on behalf of Creditor Benjamin Efraim [email protected]
John P Kreis on behalf of Creditor DAN SHAVOLIAN [email protected]
Jeffrey A Krieger on behalf of Creditor Starpoint Properties, LLC [email protected], [email protected];[email protected]
Pamela Labruyere on behalf of Interested Party Courtesy NEF [email protected]
Jennifer Leland on behalf of Defendant Ezri Namvar [email protected]
Melissa Davis on behalf of Creditor Committee Official Committee of Unsecured Creditors [email protected]
Ron Maroko on behalf of U.S. Trustee United States Trustee (LA) [email protected]
Elmer D Martin on behalf of Accountant Elmer Martin Iii [email protected]
Daniel J McCarthy on behalf of Defendant Nadar & Sons, LLC [email protected], [email protected];[email protected]
Scotta E McFarland on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected]
Alexis M McGinness on behalf of Defendant Namco Capital Group [email protected], [email protected];[email protected]
David W. Meadows on behalf of Interested Party Beshmada of Delaware, LLC [email protected]
Neeta Menon on behalf of Defendant Mousa Namvar [email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
Hal M Mersel on behalf of Creditor Wells Fargo Bank, N.A., as Trustee for the Registered Holders of J.P.Morgan Chase Commercial Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2006-LDP7 [email protected]
Lawrence C Meyerson on behalf of Creditor Drivers Way Investments, LLC [email protected]
Elissa Miller on behalf of Creditor Bijan Kianmahd [email protected], [email protected]
Susan I Montgomery on behalf of Interested Party Susan Montgomery [email protected]
Monserrat Morales on behalf of Debtor Ezri Namvar [email protected] NEF for interested party
Monserrat Morales [email protected] NEF for interested party
Kerry A Moynihan on behalf of Interested Party Courtesy NEF [email protected], [email protected];[email protected]
Randall P Mroczynski on behalf of Creditor Daimler Trust [email protected]
Alan I Nahmias on behalf of Defendant The Paul and Judith Laska Family Trust [email protected], [email protected]
R. Todd Neilson (TR) [email protected], [email protected]; [email protected]; [email protected]
R. Todd Neilson on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected];[email protected];[email protected]
Christopher R Nelson [email protected] NEF for interested party
Christopher R Nelson [email protected] NEF for interested party
Michael S Neumeister [email protected] NEF for interested party
David Norouzi on behalf of Interested Party Courtesy NEF [email protected]
William Novotny on behalf of Creditor MARISCAL WEEKS McINTYRE & FRIEDLANDER PA [email protected]
Walter K Oetzell on behalf of Debtor Ezri Namvar [email protected], [email protected]
Robert B Orgel on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected]
Randy P Orlik on behalf of Interested Party DEI X Partnership REIT, LP [email protected]
Malhar S Pagay on behalf of Interested Party Bradley D. Sharp, Chapter 11 Trustee for Namco Capital Group, Inc. [email protected], [email protected]
Jenny Y Park Garner on behalf of Interested Party Courtesy NEF [email protected]
Lawrence Peitzman on behalf of Interested Party Courtesy NEF [email protected]
Leo D Plotkin on behalf of Creditor David and Mojgan York [email protected], [email protected]
David M Poitras on behalf of Interested Party Bradley D. Sharp, Chapter 11 Trustee for Namco Capital Group, Inc. [email protected]
Samuel Price on behalf of Creditor Arizona Tempe Town Lake, LLC [email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
Uzzi O Raanan on behalf of Attorney Danning Gill Diamond & Kollitz [email protected], [email protected]
Christopher S Reeder on behalf of Creditor Homayoun Namvar [email protected]
Saul Reiss on behalf of Defendant Hersel Babajoni [email protected]
Leslie T Riansanovsky on behalf of Creditor Federal Deposit Insurance Corporation, as receiver of Community Bank of Nevada [email protected]
Ronald N Richards on behalf of Defendant Synergy Holding, LLC [email protected]
Jeremy E Rosenthal on behalf of Creditor REB Malibu, LLC [email protected]
Rachel S Ruttenberg on behalf of Plaintiff Parviz Lavi [email protected]
Neal Salisian on behalf of Defendant TN Management, LLC [email protected], [email protected];[email protected]
Henley L Saltzburg on behalf of Creditor Homayoun Namvar [email protected], [email protected];[email protected]
Allan D Sarver on behalf of Interested Party Courtesy NEF [email protected]
Robert M Saunders on behalf of Interested Party Bradley D. Sharp, Chapter 11 Trustee for Namco Capital Group, Inc. [email protected], [email protected]
Steven J Schwartz on behalf of Plaintiff R. Neilson [email protected], [email protected]
Stephanie M Seidl on behalf of Creditor Gordon Karsin [email protected]
Benjamin Seigel on behalf of Petitioning Creditor Abraham Assil [email protected], [email protected]
David Selki on behalf of Interested Party Courtesy NEF [email protected]
David B Shemano on behalf of Debtor Ezri Namvar [email protected]
Leonard M Shulman on behalf of Creditor Committee Official Committee of Unsecured Creditors [email protected]
Nico N Tabibi on behalf of Interested Party Courtesy NEF [email protected]
Sam Tabibian on behalf of Interested Party Courtesy NEF [email protected]
Derrick Talerico on behalf of Interested Party Derrick Talerico [email protected], [email protected]
David A Tilem on behalf of Non-Filing Spouse Ilana Namvar [email protected], [email protected];[email protected];[email protected]
Alan G Tippie on behalf of Interested Party Courtesy NEF [email protected], [email protected];[email protected]
United States Trustee (LA) [email protected]
Elissa A Wagner on behalf of Plaintiff Bradley Sharp [email protected]
Matthew S Walker on behalf of Creditor Wells Fargo Bank, N.A., as Trustee for the Registered Holders of J.P.Morgan Chase Commercial Mortgage Securities Corp., Commercial Mortgage Pass-Through Certificates, Series 2006-LDP7 [email protected], [email protected];[email protected]
Howard J Weg on behalf of Debtor Ezri Namvar [email protected]
Michael H Weiss on behalf of Defendant Mobil 601 Plaza, LLC [email protected], [email protected];[email protected]
Monika S Wiener on behalf of Interested Party Courtesy NEF [email protected]
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.
June 2012 F 9013-3.1.PROOF.SERVICE
Katherine Winder on behalf of Interested Party Courtesy NEF [email protected], [email protected]
Kimberly S Winick on behalf of Interested Party Courtesy NEF [email protected]
David M Wiseblood on behalf of Creditor BankFirst [email protected]
Richard Lee Wynne on behalf of Special Counsel Jones Day [email protected], [email protected]
Mark T Young on behalf of Plaintiff Arizona Tempe Town Lakes, LLC [email protected]
A David Youssefyeh on behalf of Creditor Jack & Gitta Nagel Foundation [email protected]
Dean A Ziehl on behalf of Trustee R. Todd Neilson (TR) [email protected], [email protected]