united states district court southern … · page 2 of 24 1. $30,760.61 for the receiver’s...

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA

INDIANAPOLIS DIVISION __________________________________________ ) UNITED STATES SECURITIES ) AND EXCHANGE COMMISSION, ) ) Plaintiff, ) )

v. ) Case No. 1:15-cv-659-JMS-MJD ) VEROS PARTNERS, INC, ) MATTHEW D. HAAB, ) JEFFERY B. RISINGER, ) VEROS FARM LOAN HOLDING LLC, ) TOBIN J. SENEFELD, ) FARMGROWCAP LLC, ) PINCAP LLC, and ) )

Defendants, ) ) PIN FINANCIAL LLC, ) ) Relief Defendant. ) )

MOTION FOR RECEIVER’S TENTH QUARTERLY FEE APPLICATION

William E. Wendling, Jr., the Receiver herein, by counsel, files this Motion for Tenth

Quarterly Fee Application which covers the period from July 1, 2017 through September 30,

2017, (the “Application Period”), and hereby requests that this Court enter an Order allowing and

approving the following amounts for fees, costs and expenses during the Application Period:

Case 1:15-cv-00659-JMS-MJD Document 446 Filed 11/21/17 of 24 PageID #: 6083

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1. $30,760.61 for the Receiver’s services consisting of $30,260.00 in fees and $500.61

as reimbursement for costs and expense incurred by the Receiver during the

Application Period1;

2. $2,156.19 for Anne Hensley Poindexter’s (the Receiver’s counsel) services consisting

of $2,155.00 in fees and $1.19 in costs and expenses during the Application Period.

3. $9,392.50 in compensation for Blue & Co. accounting services consisting of

$8,455.50 in fees for Blue & Co. and $0.00 in costs and expenses during the

Application Period and $937.00 for its Affiliate, Aliign2; and,

4. $2,030.00 for the Receiver’s bankruptcy counsel, David R. Krebs and Hester Baker

Krebs LLC, consisting of $1,490.00 for services and $540.00 in costs and expenses

during the Application Period.

5. $110.00 for the Receiver’s Illinois counsel, Jeffrey D. Richardson and Richards &

Erickson, consisting of $110.00 for services and $0.00 in costs and expenses during

the Application Period.

The total of all fees and expenses for this period is $44,449.30. In support of this

Application, the Receiver states as follows:

Introduction

1. William E. Wendling, Jr. was appointed the Receiver over Veros Farm Loan

Holding LLC (“VFLH”); FarmGrowCap LLC (“FarmGrowCap”); PinCap LLC (“PinCap”); and

1 The amount paid to Receiver will be reduced by $130.00 due to an inadvertent overpayment to Receiver on the Motion for Ninth Quarterly Fee Application. 2 Risinger paid directly to Blue & Co. a total of $1,500.00 for the preparation of tax returns for the FarmGrowCap LLC and PinCap LLC entities, thus reducing the balance due to Blue & Co., from $10,892.50 to $9,392.50.

Case 1:15-cv-00659-JMS-MJD Document 446 Filed 11/21/17 Page 2 of 24 PageID #: 6084

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all private offerings in which Defendant Veros Partners, Inc. (“Veros”) controls investor funds

(“Private Offerings”) on May 1, 2015, [Filing No. 34] to serve without bond.

2. The Receiver was authorized to solicit persons and entities (“Retained

Personnel”) to assist him. On June 23, 2015, the Receiver [Filing No. 65] retained Anne Hensley

Poindexter and Rodney T. Sarkovics of Campbell Kyle Proffitt LLP as counsel for the Receiver,

and on June 30, 2015, the Receiver retained the accounting firm, Blue & Co. [Filing No. 76], and

Attorneys Thomas M. Orr and Patrick L. Stevens of the law firm Hutchinson, Cox, Coons, Orr &

Sherlock, P.C. of Oregon [Filing No. 88], to further assist him in carrying out his duties. On

September 14, 2016, the Receiver retained Attorney David R. Krebs of Hester Baker Krebs LLC

as bankruptcy counsel for the Receiver [Filing No. 275].

3. The law firm of Campbell Kyle Proffitt LLP began the process of dissolving

effective April 30, 2016. Rodney T. Sarkovics withdrew his appearance [Filing No. 194 and

Filing No. 196], and Mrs. Poindexter is now a member of the law firm of Altman, Poindexter &

Wyatt, LLC [Filing No. 199]. Due to the dissolution of Campbell Kyle Proffitt LLP, the

Receiver joined the law firm of Cohen Garelick & Glazier on April 1, 2016 [Filing No. 193]. His

current address is 8888 Keystone Crossing Blvd, Suite 800, Indianapolis, Indiana 46240-4636;

telephone: (317) 573-8888, email: [email protected] and the Receivership web pages

can be found at http://www.cgglawfirm.com/Receiverships/.

4. In the twenty-nine months since the Receiver was appointed, he has reviewed the

assets of the Receivership Estates; taken control of all known bank accounts and transferred those

funds to corresponding bank accounts at The National Bank of Indianapolis; notified each known

investor of VFLH, FarmGrowCap, PinCap, and the Private Offerings of the Receivership and

information needed regarding all of their investments in each of the entities; reviewed litigation


https://ecf.insd.uscourts.gov/doc1/07314826226









mailto:[email protected]

http://www.cgglawfirm.com/Receiverships/

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pending at the time the Receivership was established; talked to numerous debtors and begun

collecting on current and past due payments for loans/investments made; engaged and met with

the accounting firm, Blue & Co. and worked with the accountants to review the private placements

and in connection with review and preparation of tax returns and related documents including

1099’s and K-1s; talked to several parties about either purchasing or managing some of the private

placements (more about this below); and, continued to update web pages with information for the

investors and all other interested parties. The Receiver also provided supervision over Pin

Financial’s principal, Tobin Senefeld, and supervision over Veros Partners, Inc.’s wealth

management operation. Veros Partners, Inc., closed its business, and Matthew D. Haab has been

released from the obligation to provide further reports.

5. The Receiver, as previously reported, states that the Receivership is nearing

completion. As of September 30, 2017, during the term of the Receivership, the Receiver has

collected a total of approximately $14,856,760.72. Of that, approximately $9,877,871.283 has been

distributed to Investors. The total amount of Receivership fees paid and incurred through

September 30, 2017 (including the fees being requested herein), is $1,671,434.47. Other ongoing

business and administrative expenses of the private placements, Veros Farm Loan Holding, and/or

FarmGrowCap were paid by the Receiver. As of September 30, 2017, there was a total of

approximately $558,964.04 remaining in the Receivership bank accounts less $15,898.34 in

outstanding Investor checks for a net balance of $543,065.70 remaining for further investor

distributions and payment of expenses. See Exhibit A hereto.

6. Some of the key activities of the Receiver, during this last three (3) months period

include:

3 This amount includes $15,898.34 of Interim Distribution checks to the Investors of True Blue Berry Annual Operating Loans (acct #6040) which had not yet cleared the Receiver’s bank account as of September 30, 2017.


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a. The Receiver requested and was authorized by the Court to make a second interim

distribution of $450,000.00 to the investors of Veros Farm Loan Holding and

FarmGrowCap. The Receiver has additional funds to pay these investors at the close of

the Receivership.

b. The Receiver collected $283,640.00 from the SEC, which were disgorgement

funds from the Defendants Matthew Haab and Jeffrey Risinger. Those funds were used,

along with other monies held by the Receivership, to pay investors associated with the

following Veros Partners Private Placements:

i. Blue Crop Group $115,339.97;

ii. True Blue Berry Management Mid Term Loan $20,484.15;

iii. HF Land GP $17,233.62;

iv. Veros 702 North $441.73;

v. Rockdale Holding $9,551.08;

vi. Jennings Design $50,411.17; and

vii. True Blue Berry Annual Operating Loan $77,099.35.

The Receiver has additional Funds to pay these investors at the close of the Receivership.

c. Pursuant to court order, the Receiver paid the administrative costs of the

Receivership.

d. The Receiver and Blue & Co. finalized the Federal and Indiana State 2016 tax

returns for PinCap LLC and FarmGrowCap LLC.

e. The Court approved the Receiver’s request to abandon the claims relating to

Veros Craft Brew private placements, the Rosentreter entities that were part of the

FarmGrowCap offerings and the profits that a few investors received that did not


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roll forward their investments in FarmGrowCap, LLC offering. The abandonment

of these investments was, in part, the result of the investors position that no

further Receivership assets be spent pursuing these claims.

f. The Receiver continues to take action to wind down the Receivership. The

primary issue regarding the wind down has to do with a pending claim the

Receiver has against the personal guarantors of the RJW Williams Settlement

Agreement. The defendants did not respond or answer the complaint and a default

was entered against them [Filing No. 15]. Unfortunately, it does not appear that

the defendants have any assets to pay the judgment and the Receiver is reluctant

to spend any more Receivership assets pursuing this claim. The Receiver will file

a motion with the Court requesting instructions as how to proceed with this issue.

7. The Receiver has consulted and followed the Billing Instructions for Receivers in

Civil Actions Commenced by the U.S. Securities and Exchange Commission (hereafter “Billing

Instructions”).

8. Pursuant to the Billing Instructions, the Receiver has attached as Exhibit A to this

Application the SEC’s Standardized Fund Accounting Report (“SFAR”) submitted by the

Receiver for the most recent quarter. Billing Instructions Requirement, ¶C.4.

Information About the Applicant and the Application

9. As discussed above, the time period covered by this Application is July 1, 2017

through September 30, 2017. Billing Instructions Requirement, ¶C.1.(a).

10. The Receiver was appointed on May 1, 2015 [Filing No. 34]. Billing Instructions

Requirement, ¶C.1.(b).





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11. The Receiver previously submitted the Receiver’s First Quarterly Fee Application

for the period from May 1, 2015, through June 30, 2015, in the amount of $173,839.69, which

was approved on August 26, 2016 [Filing No. 111]; the Receiver’s Second Quarterly Fee

Application for the Period from July 1, 2015, through September 30, 2015, in the amount of

$219,940.26, which was approved on November 9, 2015 [Filing No. 147]; the Receiver’s Third

Quarterly Fee Application for the period from October 1, 2015, through December 31, 2015, in

the amount of $173,886.63, which was approved on March 30, 2016 [Filing No. 192]; the

Receiver’s Fourth Quarterly Fee Application for the period from January 1, 2016, through March

31, 2016, in the amount of $194,876.83, which was approved on June 22, 2016 [Filing No. 233];

the Receiver’s Fifth Quarterly Fee Application for the period from April 1, 2016, through June

30, 2016, in the amount of $206,316.48, which was approved on September 20, 2016 [Filing No.

276]; the Receiver’s Sixth Quarterly Fee Application for the period from July 1, 2016, through

September 30, 2016, in the amount of $243,298.69, which was approved on December 8, 2016

[Filing No. 313]; the Receiver’s Seventh Quarterly Fee Application for the period from October

1, 2016, through December 30, 2016, in the amount of $176,051.08, which was approved on

March 17, 2017 [Filing No. 367]; the Receiver’s Eighth Quarterly Fee Application for the period

January 1, 2017, through March 31, 2017, in the amount of $173,566.32, which was approved on

July 13, 2017 [Filing No. 403]; and the Receiver’s Ninth Quarterly Fee Application for the

period April 1, 2017, through June 30, 2017, in the amount of $65,209.20, which was approved

on September 19, 2017 [Filing No. 413].

12. The names and hourly rates of all the Receiver’s professionals and

paraprofessionals are set forth on the Fee Schedules attached hereto as Exhibits B, C, D, E, and

F. Billing Instructions Requirement, ¶C.1.(c).

















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13. This Application is an interim application. Billing Instructions Requirement,

¶C.1.(d).

Case Status (Narrative)

14. The amount of net cash on hand as of September 30, 2017, was approximately

$543,065.70. At the end of September, 2017, the accrued administrative expenses total

$44,449.30 and are comprised of the following: Blue & Co.’s bill in the total amount of

$9,392.50 ($937.00 of which is for its Affiliate, Aliign); fees and expenses of the Receiver’s

bankruptcy counsel, Hester Baker Krebs LLC in the total amount of $2,030.00; fees and

expenses of the Receiver’s Oregon counsel in the total amount of $110.00; the Receiver’s time

and expenses totaling $30,760.61, and the Receiver’s counsel, Anne Hensley Poindexter’s time

and expenses totaling $2,156.19. The amount of unencumbered funds in the Receivership

estate(s) as of September 30, 2017, is therefore $498,616.40. Billing Instructions Requirement,

¶C.2.(a).

15. Summary of the administration of the case, including all funds received and

disbursed and when the case is expected to close, per Billing Instructions Requirement, ¶C.2.(b):

• See Receiver’s Tenth Interim Report at pages 3 - 14 [Filing No. 440, at pp. 3-14].

Billing Instructions Requirement, ¶C.2.(b).

16. Summary of Creditor Claims Proceedings, per Billing Instructions Requirement,

¶C.1.(c):

• No formal claims procedure has yet been established for the general public;

however, the Receiver has negotiated settlements to the creditors that have

provided statements alleging services were provided to PinCap LLC and/or Pin

Financial LLC. The Receive has concluded that I would best serve the interests of


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the investors to settle these third-party creditor claims. See Receiver’s Motion for

Authority to Pay Third Party Creditors [Filing No. 442].

17. Description of assets in the Receivership estate(s), including approximate or

actual valuations, anticipated or proposed dispositions, and reason for retaining assets where no

disposition is intended, per Billing Instructions Requirement, ¶C.2.(d):

• As set forth in the Receiver’s First Interim Report [Filing No. 89, at pp. 10-11],

the Receiver opened accounts at The National Bank of Indianapolis (hereinafter

“NBofI”) and transferred the funds seized from each MainSource account to a

mirror account at NBofI. Those accounts initially contained $284,597.51.

• The Receiver seized additional funds that were held in the name of Midwest

Blueberry Farms, Inc. at Macatawa Bank located in Holland, Michigan. These

funds were deposited into the Blue Crop Group Account ending in 5976. Funds

held in escrow accounts at MainSource Bank for various Private Placements, the

Citibank Account belonging to Pin Financial, and the Veros Partners, Inc. Sundry

Account held by TD Ameritrade were each seized and transferred into mirror

accounts at NBofI. See Second Interim Report [Filing No. 143, at p. 12].

• The total amount of funds in all of the NBI accounts in the Receiver’s possession

as of September 30, 2017, is approximately $543,065.70. See SFAR Exhibit A

and the Receiver’s Tenth Interim Report [Filing No. 440].

• Since the inception of this Receivership, the Receiver has received approximately

$14,573,120.72 in payments from debtors owed on various farm loans and Private

Placements and fees (adding in those funds initially and subsequently transferred

from MainSource Bank of $414,366.39 results in an approximate total of







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$14,987,487.11 in funds marshalled and collected to date). In turn, the Receiver

has paid out a total of approximately $14,313,710.084. See previous quarterly

reports for a detailed accounting of payments to date and see SFAR Exhibit A

attached hereto and the Receiver’s Tenth Interim Report [Filing No. 440] for

details specific to this quarter period.

• Of the $14,313,710.08, in payments to date, $9,877,871.28 was paid to Investors.

Total fees and expenses to date for the Receiver and his Retained Personnel

(including the fees and expenses requested for this quarter period of $44,449.30)

are $1,671,434.47. The remaining $2,764,404.33 was paid to various operating

expenses of the private placement investors, i.e. land sale contract obligations,

bank loans, etc.

18. Description of liquidated and unliquidated claims held by the Receiver, including

the need for forensic and/or investigatory resources; approximate valuation of such claims; and

anticipated or proposed methods of enforcing such claims (including the likelihood of success in

(1) reducing the claims to judgment; and (ii) collecting in such judgment) per Billing Instructions

Requirement, ¶C.2.(e).

Current and Previous Billings:

19. This is the Receiver’s Tenth quarterly application for fees. The Court has

previously considered and entered orders on prior applications as follows, per Billing

Instructions Requirement, ¶C.3.(a) and (b):

Party Application Time Period Fees Awarded

Costs Awarded

Total

Receiver 1st May 1 to June 30, 2014 $170,435.00 $3,404.69 $173,839.69 4 The funds paid out by Receiver to date include $15,898.34 in outstanding Investor Interim Distribution checks which had not cleared the Receiver’s bank account as of 9/30/2017.




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Receiver 2nd July 1 to September 30, 2015

$219,063.25 $877.01 $219,940.26

Receiver 3rd October 1 to December 31, 2015

$173,200.50 $686.13 $173,886.63

Receiver 4th January 1 to March 31, 2016

$193,444.76 $1,432.07 $194,876.83

Receiver 5th April 1 to June 30, 2016 $204,861.90 $1,454.58 $206,316.48 Receiver 6th July 1 to

September 30, 2016 $242,010.40 $1,288.29 $243,298.69

Receiver 7th October 1 to December 31, 2016

$175,467.14 $583.94 $176,051.08

Receiver 8th January 1, – March 31, 2017

$172,485.45 $1,080.87 $173,566.32

Receiver 9th April 1, – June 30, 2017 $64,818.51 $390.69 $65,209.20

20. Total hours billed and total amounts of billings for each person who billed during

the Application Period, per Billing Instructions Requirement, ¶C.3.(c):

Receiver and Receiver’s Staff:

Professional Hours Hourly Rate Dollar Amount William E. Wendling, Jr. (WEW) John Bishop (JEB) Subtotal

95.80 1.60 97.40

$325 $175

$ 26,455.00 $ 280.00 $ 26,735.00

Paraprofessional Hours Hourly Rate Dollar Amount Anita G. Haworth, RP, CEDS (AGH) Jessica O. Smith, RP (JS) Subtotal

0.00 58.80 58.80

$125 $125

$ 0.00 $3,525.00 $3,525.00

Total 245.50 $30,260.00 Receiver’s Counsel: Professional Hours Hourly Rate Dollar Amount Anne Hensley Poindexter (AHP) 5.20 $275 $1,430.00 Paraprofessional Hours Hourly Rate Dollar Amount Cari W. Bonty, RP (CB) 8.90 $125 $725.00

Total 14.10 $2,155.00


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Blue & Co. & Aliign, Accountants:

Professional Hours Hourly Rate Dollar Amount Jarit T. Loughmiller (JTL) Larry Steinburg (LS) Jerry Hammel (JH) Paul Roth (PR) Beth Harling (BH) Staff*

Sub-total Blue & Co. Joell Grisel (Aliign) (JG) Nicole Paredes-Palma Blue & Co. Employee**

Sub-total Aliign

12.00 0.00 6.25 13.80 0.00 16.92 48.97 0.75 5.99 0.00 6.74

$260/$248 $224 $248.51 $228/$228.19 $208 $140/$136/$92 $208 $131

$3,068.32 $ 00.00 $1,553.20 $3,103.75 $ 00.00 $2,230.23 $9,955.50

$ 156.00 $ 781.00 $ 0.00 $ 00.00 $ 937.00

Total 55.71 $10,892.50 Less payments from Risinger for

preparation of tax returns ($ 1,500.00)

Grand Total 55.71 $9,392.50 Staff* - consisting of professional staff, not partners or directors, but may include some managers who had minimal time involvement. Forensic Staff at $124/hr. and Tax Staff at $136/hr. **Blue & Co. Employee working on Aliign/Cherry Farms accounting Illinois Counsel, Jeffrey D. Richardson, RICHARDSON & ERICKSON.

Professional Dollar Amount Jeffry D. Richardson (JDR) $110.00

Total $110.00 Bankruptcy Counsel, Hester Baker Krebs Professional Hours Hourly Rate Dollar Amount David R. Krebs (DRK) 4.2 $325 $1,365.00 John J. Allman (JJA) 0.00 $275 $ 0.00 Paraprofessional Hours Hourly Rate Dollar Amount Donna Adams (JJA) 1.0 $125 $ 125.00

Total 5.2 $1,490.00 Fee and Expense Statements, and Summary of Services Rendered:

21. A copy of the Receiver’s statement of fees for this Application is attached hereto

as Exhibit B. As shown by this statement, the Receiver seeks a total of $30,760.61, which



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includes $30,260.00 in compensation for the Receiver and his Staff’s services during the

Application period and $500.61 in costs.

22. A copy of Anne Hensley Poindexter’s statement of fees for this Application is

attached hereto as Exhibit C. As shown by this statement, Mrs. Poindexter seeks a total of

$2,156.19, which includes $2,155.00 in compensation for Mrs. Poindexter’s services during the

Application period and $1.19 in costs.

23. The Receiver only used counsel as necessary and has determined that his and his

counsel’s fees and expenses are proper and reasonable and that they should be paid.

24. A copy of the Blue & Co. (and its affiliate, Aliign) statement of fees and

supporting invoices are attached hereto as Exhibit D. As shown by the statement, Blue & Co.

seeks $9,392.50 ($8,455.50 for Blue & Co., of which $0.00 is for costs, and $937.00 for Aliign)

for their services during the Application period.

25. The Receiver only used the Accountants as necessary and has determined that the

Accountants’ fees are proper and reasonable and that they should be paid.

26. A copy of the statement of fees for the Receiver’s bankruptcy counsel, Hester

Baker Krebs LLC is attached hereto as Exhibit E. As shown by the statement, bankruptcy

counsel seeks a total of $2,030.00, which includes $1,490.00 for services during the Application

period and $540.00 in costs.

27. The Receiver only used counsel as necessary and has determined that his


28. A copy of the statement of fees for the Receiver’s Illinois counsel, Richardson &

Erikson is attached hereto as Exhibit F. As shown by the statement, Illinois counsel seeks a total






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of $110.00, all of which is compensation for counsel’s services during the application period

($0.00 in costs).

29. The Receiver only used said counsel as necessary and has determined that his


30. The attached statements contain daily time entries describing the time spent by

each of the Receiver’s professionals during the application Period. The Receiver and his

counsel’s and other professionals’ time records are kept contemporaneously with the

professional services being rendered. The Receiver’s counsel and other professionals only

charged for actual professional services rendered and have not charged any fees for travel time

except to the extent professional services were rendered on behalf of the Receivership Estates

during such travel time.

Summary of Services by Project:

31. Pursuant to the Billing Instructions, the Receiver has categorized his

responsibilities and activities in to the following categories: (i) Asset Analysis and Recovery,

which involves identification and review of potential assets including causes of action and non-

litigation recoveries; (ii) Asset Disposition, which involves sales, leases, abandonment and

related transaction work; (iii) Business Operations, which involves issues relating to the

operation of an ongoing business; (iv) Case Administration, which involves coordination and

compliance activities, including, but not limited to, preparation of reports to the Court and

investor inquiries; (v) Claims Administration and Objections, which involves formulating,

gaining approval of and administering any claims procedure; (vi) Employee Benefits/Pension,

which involves such issues as severance, retention, 401(k) coverage and continuance of any


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pension plan; and (vii) Accounting/Auditing, which involves maintaining and auditing books of

account, preparation of financial statements and account analysis.

32. Pursuant to the Billing Instructions, Blue & Co. (including Aliign) has

categorized its responsibilities and activities in the following financial activities categories: (vii)

Accounting/Auditing, which involves maintaining and auditing books of account, preparation of

financial statements and account analysis; (viii) Business Analysis, which includes preparation

and review of company business plan, development and review of strategies, preparation and

review of cash flow forecasts and feasibility studies; (ix) Corporate Finance, which includes

review of financial aspects of potential mergers, acquisitions and disposition of company or

subsidiaries; (x) Data Analysis, which involves management information systems review,

installation and analysis, construction, maintenance and reporting of significant case financial

data, lease rejections, claims, etc.; (xi) Status Reports, which involves preparation and review of

periodic reports as may be required by the court; (xii) Litigation Consulting, which involves

providing consulting and expert witness services relation to forensic accounting, etc.; (xiii)

Forensic Accounting, which involves reconstructing books and records from past transactions

and bringing accounting current; tracing and sourcing assets, (xiv) Tax Issues, which involves

analysis of tax issues and preparation of state and federal tax returns; and (xv) Valuation, which

involves appraising or review of appraisals of assets.

33. The Receiver and his professionals have attempted to place time entries into the

category that best relates to such services. However, because certain time entries may relate to

professional services in one or more categories, such entries were included in the category for

which the bulk of the professional services were rendered with respect to a particular time entry.

Therefore, services pertaining to one category may in fact be included in another category.


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Pursuant to the Billing Instructions, matters with “block billing” that exceed 1 hour include a

notation of the approximate time spent on each activity.

Subject Matter Categories:

34. Category 1: Asset Analysis. A breakout of the fees and narrative of the work

undertaken by the Receiver, the Receiver’s bankruptcy counsel, and the Receiver’s Illinois

Counsel, which were incurred in this category, are attached as Exhibit B-1, Exhibit E and Exhibit

F.

35. For this category, the Receiver seeks $19,860.00 in fees for 64.8 hours of work,

the Receiver’s Illinois counsel seeks $110.00 in fees, and David Krebs/Hester Baker Krebs seeks

$1,490.00 for 5.2 hours of work.

36. Category 2: Asset Disposition. A breakout of the fees and narrative of the work

undertaken by the Receiver’s counsel, which were incurred in this category, are attached as

Exhibit C-1.

37. For this category, the Receiver seeks $0.00 in fees for 0.00 hours of work and

Mrs. Poindexter seeks $1,892.50 in fees for 8.9 hours of work.

38. Category 3: Business Operations. A breakout of the fees and narrative of the

work undertaken by the Receiver, which were incurred in this category, are attached as Exhibit

B-2.

39. For this category, the Receiver seeks $1,377.50 in fees for 5.10 hours of work.

40. Category 4: Case Administration. A breakout of the fees and narrative of the

work undertaken by the Receiver and his counsel, which were incurred in this category, is

attached as Exhibit B-3 and Exhibit C-2.











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41. For this category, the Receiver seeks $9,022.50 in fees for 86.30 hours of work

and Mrs. Poindexter seeks $262.50 for 5.20 hours of work.

42. Category 5: Claims Administration. The Receiver and his counsel have no fees

or expenses for this category.

43. Category 6: Employee Benefits/Pension. The Receiver and his counsel have no

fees or expenses for this category.

44. Category 7: Accounting/Auditing. The Receiver and his counsel have no fees or

expenses for this category.

45. Category 8: Business Analysis. Blue & Co. has no fees or expenses for this

category.

46. Category 9: Corporate Finance. Blue & Co. has no fees or expenses for this

category.

47. Category 10: Data Analysis. Blue & Co. has no fees or expenses for this

category.

48. Category 11: Status Reports. Blue & Co. has no fees or expenses for this

category.

49. Category 12: Litigation Consulting. Blue & Co. has no fees or expenses for this

category.

50. Category 13: Forensic Accounting. A breakout of the fees and narrative of the

work undertaken by Blue & Co., which was incurred in this category, is attached as Exhibit D.

51. For this category, Blue & Co. and its affiliate, Aliign, seek $5,706.00 in fees for

26.84 hours of work.



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52. Category 14: Tax Issues. A breakout of the fees and narrative of the work

undertaken by Blue & Co., which was incurred in this category, is attached as Exhibit D.

53. For this category, Blue & Co. and its affiliate, Aliign seek $3,686.50 in fees for

28.87 hours of work.

54. Category 15: Valuation. Blue & Co. has no fees or expenses for this category.

Summary of Fees:

55. Thus, the total fees for the Receiver and his counsel and other professionals for

this Application are as follows:

Category Description Hours Dollar Amount 1 Asset Analysis and Recovery 70.00 $21,460.00 2 Asset Disposition 8.90 $ 1,892.50 3 Business Operations 5.10 $ 1,377.50 4 Case Administration 91.50 $ 9,285.00 5 Claims Administration and Objections 0.00 $ 0.00 6 Employee Benefits/Pension 0.00 $ 0.00 7 Accounting/Auditing 0.00 $ 0.00 8 Business Analysis 0.00 $ 0.00 9 Corporate Finance 0.00 $ 0.00 10 Data Analysis 0.00 $ 0.00 11 Status Reports 0.00 $ 0.00 12 Litigation Consulting 0.00 $ 0.00 13 Forensic Accounting 26.84 $ 5,706.00 14 Tax Issues 28.87 $ 3,686.50 15 Valuation 0.00 $ 0.00 Totals 231.21 $43,407.50

56. Expenses: During the Application Period, the Receiver incurred and/or advanced

the costs set forth on Exhibit B. These costs total $500.61 and were largely comprised of

photocopying fees at $0.15/page, postage, and shipping charges. Mrs. Poindexter incurred and/or

advanced the costs set forth on Exhibit C. These costs total $1.19 and were comprised of postage

charges.




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57. In accordance with the factors enumerated by this Court in assessing the

reasonableness of fees, Receiver respectfully asserts that the amount of fees requested is fair and

reasonable given: (a) the complexity of this case; (b) the time expended; (c) the nature and extent

of the services rendered; (d) the value of such services; (e) the costs of comparable services; and

(f) the delay in receiving compensation.

58. Likewise, the Receiver respectfully states that payment of $500.61 in expenses to

William E. Wendling, Jr., and payment of $1.19 in expenses to Mrs. Poindexter, is justified in

that the expenses were reasonable, were costs advanced by or billed by counsel and were

reasonably incurred by the Receiver and/or in representing the Receiver.

59. The Receiver has reviewed this Application and finds the fees requested

appropriate based on the work done and results obtained. The fees detailed in this Application

were provided to the SEC in advance of the filing of this Application.

60. Source of Funds and Allocation for Payment of Fees and Expenses. The

Receiver’s time in this Receivership involves three (3) primary areas of concern:

• Collections - relating to the past due farm loans within FarmGrowCap and VFLH

as well as collection of payments as they come due (or become past due) on loans

made within the Private Offerings;

• Supervision – relating to the Receiver’s obligations to supervise/monitor the

activities of the Defendants Veros Partners and Matthew D. Haab, and Pin

Financial/Tobin Senefeld, and supervision and handling of loans made under the

Private Offerings; and

• The Private Offerings (Private Placements) themselves, specifically in regard to

the investors. The time spent designated as Private Placement includes, but is not


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limited to, correspondence and telephone calls with investors, review and

handling of investor documents, creation of a complete listing of investors, their

contact information and investments, review of Private Placement Memoranda,

the investors within each, etc.

The Receiver and his counsel and staff have therefore allocated their time into the

specific Subject Matter Categories as required by the SEC Billing Instructions, and thereafter

notated the particular area of concern (collections/supervision/private placement) to which each

time entry pertains.

The Receiver has determined that the total fees and expenses of $44,449.30, for the

Receiver, his counsel, and other professionals, break down among the three areas of concern as

follows:

a. Collections: $39,239.30

b. Private Placement: $1,867.50

c. Supervision: $3,342.50

Accordingly, the Receiver believes that of the funds held in the Receivership Accounts,

Forty Two Thousand Four Hundred Fifty One and 80/100 ($42,451.80)5 of the total fees and

expenses related to this Fee Application should come from the FarmGrowCap Receivership

Account for the Collections and Supervision related activities and the remaining One Thousand

Eight Hundred Sixty-Seven Dollars and 50/100 ($1,867.50) should come from funds held within

the Receiver’s General Private Placement Account #6065.

5 This amount equals $42,581.80 in fees and expenses for the Receiver’s Tenth Quarterly Fee Application less the $130.00 inadvertent overpayment to the Receiver in the Ninth Quarterly Fee Application.


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This allocation among the accounts is the Receiver’s best and fairest calculation of how

the fees and expenses for this Application should be paid. At the end of the Receivership, this

allocation shall be reviewed and revised if necessary.

61. Certification. Pursuant to the Billing Regulations, the Receiver hereby certifies:

• That Receiver has read this Application;

• That to the best of Receiver’s knowledge, information and belief formed after

reasonable inquiry, the Application and all fees and expenses herein are true and

accurate and comply with the Billing Instructions (with any exceptions being

noted here: NONE and described in this Application: NONE);

• All fees contained in this Application are based on the rates listed in the

Applicants’ Fee Schedule set forth below and such fees are reasonable, necessary

and commensurate with the skill and experience required for the activity

performed:

William E. Wendling, Jr. (WEW) $325 Anne Hensley Poindexter (AHP) $275 Steven J. Glazier (SJG) $325 John Bishop (JEB) $175 Anita G. Haworth (AGH) $125 Jessica O. Smith (JS) $125

Anne Hensley Poindexter (AHP) $275 Cari W. Bonty (CB) $125

Jarit T. Loughmiller (JTL) $245 Jerry Hammel (JH) $236 Paul Roth (PR) $220 Beth Harling (BH) $200 Staff $124 Other Staff $136 Gwen Parker $155 Nicole Paredes-Palmer $105 Blue & Co. Employee working on Aliign Cherry Farms Accounting

$236


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David R. Krebs (DRK) $325 John J. Allman (JJA) $275

• Receiver has not included in the amount for which reimbursement is sought the

amortization of the cost of any investment, equipment or capital outlay (except to

the extent that any such amortization is included within the permitted allowable

amounts set forth herein for photocopies and facsimile transmission); and,

• In seeking reimbursement for a service where the Receiver has justifiably

purchased or contracted from a Fourth party (such as copying, imaging, bulk mail,

messenger service, overnight courier, computerized research or title and lien

searches, the Receiver requests reimbursement only for the amount billed to the

Receiver by the Fourth-party vendor and paid by the Receiver to such vendor. If

such services are performed by the Receiver, the Receiver hereby certifies that he

is not making a profit on such reimbursable service.

WHEREFORE, William E. Wendling, Jr., Receiver, by counsel, respectfully requests

the Court to enter an order providing that for the Application Period, an allowance be made to:

1. William E. Wendling, Jr., the Receiver, in the sum of $30,630.61 which includes

$30,130.00 as compensation for actual and necessary professional services rendered, the

sum of $500.61 for the Receiver’s out-of-pocket expenses, and credit for the inadvertent

overpayment of $130.00 in the Ninth Quarterly Fee Application;

2. Anne Hensley Poindexter, in the sum of $2,156.19 which includes $2,155.00 as

compensation for actual and necessary professional services rendered and the sum of

$1.19 for Mrs. Poindexter’s out-of-pocket expenses


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3. Blue & Co. in the sum of $8,455.50 (which includes $0.00 for expenses) and its affiliate,

Aliign, in the sum of $937.00 as compensation for actual and necessary professional

services rendered;

4. Hester Baker Krebs LLC, the Receiver’s bankruptcy counsel, in the sum of $2,030.00

which includes $1,490.00 as compensation for actual and necessary professional services

rendered and the sum of $540.00 for Hester Baker Krebs LLC’s out of pocket expenses;

5. Richardson & Erickson, the Receiver’s Illinois counsel, in the sum of $110.00 as

compensation for actual and necessary professional services rendered (zero out of pocket

expenses); and,

6. That the Receiver’s proposed allocation of fees and expenses ($42,451.80 to

FarmGrowCap; and, $1,867.50 to the Receiver’s General Private Placement Account

#6065) be approved; and,

7. For such other and further relief as this Court may deem just and proper.

Dated: November 21, 2017 s/William E. Wendling, Jr. William E. Wendling, Jr., Receiver

Cohen Garelick & Glazier Suite 800, Keystone Crossing Plaza 8888 Keystone Crossing Blvd. Indianapolis, IN 46240-4636 Telephone: (317) 573-8888 Fax: (317) 574-3855 Email: [email protected]



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Respectfully submitted,

By s/Anne Hensley Poindexter . Anne Hensley Poindexter, #14051-29 Altman, Poindexter & Wyatt LLC 90 Executive Drive, Suite G Carmel, IN 46032 Telephone: (317) 350-1000 Fax: (844) 840-3461 Email: [email protected]

Counsel for the Receiver

Certificate of Service

I hereby certify that on November 21, 2017, a copy of the foregoing Motion for Receiver’s Tenth Quarterly Fee Application was filed electronically. Notice of this filing will be made on all ECF-registered counsel by operation of the Court’s electronic filing system. Parties may access this filing through the Court’s system.

s/Anne Hensley Poindexter . Anne Hensley Poindexter, #14051-29 Altman, Poindexter & Wyatt LLC 90 Executive Drive, Suite G Carmel, IN 46032 Telephone: (317) 350-1000 Fax: (844) 840-3461 Email: [email protected]




STANDARDIZED FUND ACCOUNTING REPORTReceivership; US District Court Southern District of Indiana

Case no. 1:15-cv-659-JMS-MJDReporting Period 07/01/207 - 09/30/2017

Exhibit "A"

Detail Subtotal Grand TotalLine 1 Beginning Balance (As of 07/01/2017):

FarmGrowCap LLC acct #5968 (Opening balance was $681,001.43. However, $275,948.92 owed to FarmGrowCap by Blue Crop Group was transferred into this account from Blue Crop Group acct #5967, and $120,273.08 owed to FarmGrowCap by PinCap LLC was transferred into this account from PinCap LLC acct #5950). 681,001.43$ HF Land GP acct #5927 -$

Jennings Design LLC acct #5851(Opening balance was $3,971.92. However, per the Court's 8/11/17 Order Authorizing Receiver to Distribute Funds to Private Placement Investrs , $46,439.26 was transferred into this account from Private Placement General Receiver acct #6065). 3,971.92$

PinCap LLC acct #5950 (Opening balance was $248.80. However, $120,273.08 owed to PinCap LLC by Blue Crop Group was transferred into this account from Blue Crop Group acct #5976, and $120,273.08 owed to FarmGrowCap by PinCap LLC was transferred out of this account into FarmGrowCap acct #5968). 248.80$ True Blue Berry Mgmt LLC acct #5885 -$ Veros 702 N Holding LLC acct #5802 -$ Blue Crop Group LLC acct #5976 (Opening balance was $396,222.00. However, $275,948.92 was transferred out of this account into FarmGrowCap LLC acct #5968 and $120,273.08 was transferred out of this account into PinCap LLC #xx5950). 396,222.00$ Stadiumred, Inc. acct #6073 7.53$ True Blue Berry Mgmt LLC Annual Op Loans acct #6040 (Opening balance was $37,615.85. However, $39,483.50 was transferred into this account from Private Placement General Receiver acct #6065). 37,615.85$ True Blue Berry Mgmt LLC Midterm acct #6016 -$ Pin Financial General Receiver acct #6057 90,094.07$ TD Sundry acct #6156 -$ Rockdale LLC acct #5778 -$ Private Placement General Receiver acct #6065 (Opening balance was $72,364.19. However, per the Court's 8/11/17 Order Authorizing Receiver to Distribute Funds to Private Placement Investrs, $46,439.26 was transferred to Jennings Design acct #5851, and $39,483.50 was transferred to True Blue Berry Management LLC Op Loans acct #6040) 72,364.19$ Total Beginning Balance (as of 07/01/2017) 1,281,525.79$

Increases in Fund Balance:Line 2 Business Income 283,640.00$

283,640.00$

FUND ACCOUNTING

Case 1:15-cv-00659-JMS-MJD Document 446-1 Filed 11/21/17 Page 1 of 5 PageID #: 6107



Exhibit "A"

Detail Subtotal Grand TotalLine 3 Cash and Securitites -$ -$ Line 4 Interest/Dividend Income -$ -$ Line 5 Business Asset Liquidation -$ -$ Line 6 Personal Asset Liquidation -$ -$ Line 7 Third-Party Litigation Income -$ -$ Line 8 Miscellaneous - Other -$

-$ Total Funds Available (Lines 1 - 8): 1,565,165.79$

Decreases in Fund Balance:Line 9 Disbursements to Investors

Distribution to FarmGrowCap investors (501,886.50)$ Distribution to Jennings Design investors (50,411.17)$ Distribution to True Blue Berry Operating Loan investors 1 (61,201.01)$ Distrubtion to Blue Crop Group (115,339.97)$ Distribution to True Blue Berry Management (20,484.15)$ Distribution to Howell Farms (17,233.62)$ Distribution to Rockdale LLC (9,551.08)$ Distribution to 702 North LLC (441.73)$

Line 10 Disbursements for Receivership OperationsLine 10a Disbursements to Receiver or Other Professionals

Blue & Co. (42,859.00)$ Aliign (9,071.96)$ Richardson & Erickson (1,752.50)$ Altman, Poindexter & Wyatt LLC (20,004.60)$ Cohen Garelick & Glazier (149,785.46)$ Hutchison Cox Coors Orr & Sherlock PC (344.50)$ Hester Baker Krebs (5,765.00)$

Line 10b Business Asset ExpensesWire transfer and bank account fees, checks $ (69.50)

Line 10c Personal Asset Expenses -$ Line 10d Investment Expenses -$ Line 10e Third-Party Litigation Expenses (FGC/Williams Illinois Litigation)

1. Attorney Fees: -$ 2. Litigation Expenses -$ Total Third-Party Litigation Expenses -$

Line 10f Tax Administrator Fees and Bonds -$ Line 10g Federal and State Tax Payments -$

Total Disbursements for Receivership Operations2 (1,006,201.75)$

1The total amount of distributions in the current reporting period for this investement was $77,099.35. However, there remains outstanding $15,898.34 in Investor Interim Distribution checks which had not yet cleared the Receiver's bank account as of 9/30/2017.

2The total amount of disbursements for Receivership Operations for the current reporting period was $1,022,100.09 which includes $15,898.34 in Investor Interim Distribution checks which had not yet cleared the Receiver's bank account as of 9/30/2017.




Exhibit "A"

Detail Subtotal Grand TotalLine 11 Disbursements for Distribution Expenses Paid by the Fund:

Line 11a Distribution Plan Development Expenses:1. Fees:

Fund Administrator -$ Independent Distribution Consultant (IDC) -$ Distribution Agent -$ Consultants -$ Legal Advisers -$ Tax Advisers -$

2. Administrative Expenses -$ 3. Miscellaneous -$

Total Plan Development Expenses -$ Line 11b Distribution Plan Implementation Expenses:

1. Fees:Fund Administrator -$ Independent Distribution Consultant (IDC) -$ Distribution Agent -$ Consultants -$ Legal Advisers -$ Tax Advisers -$

2. Administrative Expenses -$ 3. Investor Identification: -$

Notice/Publishing Approved Plan -$ Claimant Identification -$ Claims Processing -$ Web Site Maintenance/Call Center -$

4. Fund Administrator Bond -$ 5. Miscellaneous -$ 6. Federal Account for Investor Restitution -$ (FAIR) Reporting Expenses -$

Total Plan Implementation Expenses -$ Total Disbursements for Distribution Expenses Paid by the Fund:3 (1,006,201.75)$

Line 12 Disbursements to Court/Other:Line 12a Investment Expenses/Court Registry Investment System (CRIS)

Fees-$

Line 12b Federal Tax Payments -$ Total Disbursements to Court/Other: -$ Total Funds Disbursed (Lines 9-11):3 (1,006,201.75)$

Line 13 Ending Balance (As of 09/30/2017):4 558,964.04$

Line 14 Ending Balance of Fund - Net Assets:Line 14a Cash & Cash EquivalentsLine 14b Investments -$ Line 14c Other Assets or Uncleared Funds -$

-$ Total Ending Balance of Fund - Net Assets -$

3Total Disbursements for Distribution Expenses Paid (Line 11) by the Fund and Total Funds Disbursed (Line 2) do not include $15,898.34 which had not cleared the Receiver's Bank account as of 9/30/17. 4Ending Balance as of 9/30/17 (Line 13) of $558,694.04 less outstanding checks of $15,898.34 equals NET Ending Balance of $543,065.70.




Exhibit "A"

Detail Subtotal Grand Total

Report of Items NOT To Be Paid by the Fund:Line 15 Disbursements for Plan Administration Expenses Not Paid by the Fund:

Line 15a Plan Development Expenses Not Paid by the Fund:1. Fees:


2. Administrative Expenses -$ 3. Miscellaneous -$

Total Plan Development Expenses Not Paid by the Fund -$

Line 15b Distribution Plan Implementation Expenses Not Paid by the Fund:1. Fees:


2. Administrative Expenses -$ 3. Investor Identification: -$

Notice/Publishing Approved Plan -$ Claimant Identification -$ Claims Processing -$ Web Site Maintenance/Call Center -$

4. Fund Administrator Bond -$ 5. Miscellaneous -$ 6. Federal Account for Investor Restitution -$ (FAIR) Reporting Expenses -$

Total Plan Implementation ExpensesNot Paid by the Fund -$

Line 15c Tax Administrator Fees & Bonds Not Paid by the Fund -$ Total Disbursements for Plan Administration Expenses Not Paid by the Fund -$

Line 16 Disbursements to Court/Other Not Paid by the Fund:Line 16a Investment Expenses/Court Registry Investment System (CRIS)

Fees-$

Line 16b Federal Tax Payments -$ Total Disbursements to Court/Other Not Paid by the Fund: -$

Line 17 DC & State Tax PaymentsLine 18 No. of Claims:

Line 18a # of Claims Received this Reporting PeriodLine 18b # of Claims Received Since Inception of Fund




Exhibit "A"

Detail Subtotal Grand TotalLine 19 No. of Claimants/Investors:

Line 19a # of Claimants/Investors Paid This Reporting Period 0Line 19b # of Claimants/Investors Paid Since Inception of Fund 0

(date)

William E. Wendling, Jr. (printed)

Receiver (title)

Receiver:

By:___s/William E. Wendling, Jr. ___________ (signature)

11/21/2017_________________________________


US SEC v Veros Partners, Inc., et al USDC Southern IN, Case No. 1:15-cv-

00659-J MS-DJ M

Anne Hensley Poindexter, Altman

Poindexter & Wyatt LLC

Counsel for Receiver

Legal Activity

Asset Analysis & Recovery-001

Asset Disposition-002

Business Operations-003

Case Administration-004

Accounting/ Auditing-007

Totals:

Total Fees and Expenses:

Fees

$0.00

$1,892.50

$0.00

$262.50

$0.00

$2,155.00

EXHIBIT C

Quarter Period: 07 /01/17-09/30/17

Expenses Total Due

$0.00 $0.00

$1.19 $1,893.69

$0.00 $0.00

$0.00 $262.50

$0.00 $0.00

$1.19 $2,156.19

$2,156.19

Invoice No.

1860

1861

SEC Receivership -

Invoice time period Quarter Period

2017- 3rd quarter

2017- 3rd quarter

Last updated:

10/31/2017

By: js

Note:

To be submitted with Receiver's

2017 3rd quarter (10th) fee app


Altman, Poindexter & Wyatt LLc

90 Executive Drive, Suite G Carmel, Indiana 46032 Phone: 317-350-1000 Email: [email protected] www.apwlawyer.com

William E. Wendling, Jr. Cohen Garelick & Glazier 8888 Keystone Crossing, Suite 800 Indianapolis, IN 46240

1605-00248/SEC v. Veras, et al ... Asset Disposition

SEC v. Veros, et al . .. Asset Disposition

·Type Date Attorney Description

Service 07/03/2017 AHP Private Placement: Receive order, email from and to Doressia re; transfer of funds

Service 07/05/2017 AHP Private Placement: Receive and begin review of motion

Service 07/10/2017 CB-Paralegal Private Placement: Review email from A. Poindexter; prepare and send correspondence to D. Krebs enclosing flash drives with QuickBooks file and copy of Receiver's electronic file pertaining to Cherry Farms.

Expense 07/10/2017 CB-Paralegal Reimbursable expense: Postage

Service 07/11/2017 AHP Private Placement: Emails to and from Conway.call from Bill, emails re: same

Service 07/12/2017 AHP Private Placement: Receive and respond to emails from Krebs.email to Jessica, receive orders re: distributions to investors and to abandon craft brew

Service 07/13/2017 AHP Private Placement: Receive and respond to emails for Cherry counsel, email from Bill

Service 07/13/2017 CB-Paralegal Private Placement - Revisions to private placement distribution motion; draft proposed order thereon; email documents to SEC for review.

Service 07/20/2017 AHP Private Placement: Receive and review draft letter from Bill, email suggestion

Service 07/21/2017 AHP Private Placement: Emails to and from Bill, reply

Page 1 of 3

INVOICE

Invoice# 1860 Date: 10/30/2017

Due Upon Receipt

Time Total

0.30 $82.50

0.30 $82.50

0.40 $50.00

1.00 $1.19

0.30 $82.50

0.40 $110.00

0.20 $55.00

1.00 $125.00

0.20 $55.00

0.20 $55.00

EXHIBIT C-1


EXHIBIT C-2


US SEC v Veros Partners, Inc., et al

USDC Southern IN, Case No. 1:15-cv-00659-JMS-DJM

David R. Krebs, Hester Baker Krebs

Bankruptcy Counsel for Receiver

Per Order dated 9/14/16 - Doc. No. 275

Description

RJW Williams Farms

RJW Williams Farms

RJW Williams Farms

Totals:

Total Fees and Expenses:

RJW Williams Farms Legal Activity: Asset Analysis and

Recovery (Collections)

Fees

$1,197.50

$130.00

$162.50

$1,490.00

EXHIBIT E

Quarter Period: 07/01/2017 - 09/30/2017

Expenses Total Due Invoice No.

$400.00 $1,597.50 2046

$0.00 $130.00 2294

$140.00 $302.50 2402

$540.00 $2,030.00

$2,030.00

Last Updated:

10/18/2017

By: js

Invoice time SEC Receivership - Quarter

period Period

To be submitted with

Receiver's 2017 3rd quarter

fee app

6/30/2017

8/31/2017

9/30/2017


united states district court southern … · page 2 of 24 1. $30,760.61 for the receiver’s...

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