case 09-11958-ajc doc 296 filed 05/22/12 page 1 of 15

UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re: Case No. 09-11958-BKC-AJC

MERENDON MINING (Nevada), INC. a/k/a Milowe Brost,

Chapter 7Debtor.

__________________________________/

FIRST INTERIM FEE APPLICATION FOR ALLOWANCE AND PAYMENT OF COMPENSATION AND REIMBURSEMENT OF EXPENSES TO GRAYROBINSON,

P.A., AS GENERAL COUNSEL TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE

1. Name of Applicant: GrayRobinson, P.A.

2. Role of Applicant: Counsel to Marcia Dunn, Chapter 7 Trustee

3. Name of Certifying Professional Ivan J. Reich, Esq.

4. Date case filed: February 4, 2009

5. Date of application for employment: June 16, 2009 [DE #32]

6. Date of order approving employment: June 17, 2009 nunc pro tunc to June 11, 2009 [DE #34]

7. If debtor's counsel, date of Disclosure of Compensation form:

N/A

8. Date of this application: May 22, 2012

9. Dates of services covered: June 11, 2009 through March 31, 2012

10. If case is chapter 7, amount trustee has on hand:

$1,216,188.32

Fees...

11. Total fee requested for this period (from Exh. 1): $716,885.00

12. Balance remaining in fee retainer account as of the Petition Date: $0.00

13. Fees paid or advanced for this period, by other sources: $0.00

14. Net amount of fee requested for this period: $716,885.00

Expenses...

15. Total expense reimbursement requested for this period (from Exh. 2): $37,619.34

16. Balance remaining in expense retainer account as of the Petition Date:

$0.00

17. Expenses paid or advanced for this period, by other sources: $0.00

18. Net amount of expense reimbursements requested for this period $37,619.34

19. Gross award requested for this period (#11 + #15) $754,504.34

20. Net award requested for this period (#14 + #18) $754,504.34

Case 09-11958-AJC Doc 296 Filed 05/22/12 of 15

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History of Fees and Expenses

1. Dates, sources, and amounts of retainers received: N/A

Dates:

N/A

Sources: Amounts: For fees or costs?

2. Dates, sources, and amounts of third party payments received: N/A

Dates: Sources: Amounts: For fees or costs?

3. Prior fee and expense awards...

N/A

Dates covered by First Invoice:

Amount of fees requested:

Amount of expenses requested:

Amount of fees invoiced (80% of fees requested) (no objection filed):

Amount of expenses invoiced (no objection filed):

Amount of fees applied against the retainer:

Amount of expenses applied against the retainer:

Fees paid by Debtor, net of retainer:

Expenses paid by Debtor, net of retainer:

Date of application of retainer:

Portion of fees requested but not invoiced, which applicant wishes to defer to final fee application:

Portion of expenses requested but not invoiced, which applicant wishes to defer to final fee application:


1

UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

In re: Case No. 09-11958-BKC-AJC

MERENDON MINING (Nevada), INC. a/k/a Milowe Brost,

Chapter 7Debtor.

__________________________________/

SUMMARY OF FIRST INTERIM FEE APPLICATION OF GRAYROBINSON, P.A., AS GENERAL COUNSEL TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE

GRAYROBINSON, P.A., (AApplicant@) counsel to the Chapter 7 Trustee (the ATrustee@),

applies for its first interim compensation for fees for services rendered and costs incurred in this

Chapter 7 proceeding. This application is filed pursuant to 11 U.S.C. ' 330 and Rule 2016,

Federal Rules of Bankruptcy Procedure, and meets all of the requirements set forth in the

Guidelines incorporated in Local Rule 2016(B). This application for First Interim Compensation

is for services performed between June 11, 2009, through March 31, 2012. This is a First Interim

Fee Application filed by the Attorney for the Trustee and is not an amendment or supplemental

to a previous Fee Application. The exhibits attached to this application, pursuant to the

Guidelines, are:

Exhibits A1-A@ and A1-B@- Summary of Professional and Paraprofessional Time.

Exhibit "2" - Summary of Requested Reimbursements of Expenses.

Exhibit "3" - The applicant's complete time records, in chronological order, by activity code category, for the time period covered by this application.

Applicant believes that the requested fee of $716,885.00 for 2,351.80 hours worked for

and expenses in the amount of $37,619.34 a total award of $754,504.34, is reasonable when

considering the twelve factors enumerated in Johnson v. Georgia Highway Express, Inc., 488

F.2d 714 (5th Circuit 1974), made applicable to bankruptcy proceedings by In re First Colonial

Corp. of America, 544 F.2d 1291 (5th Cir. 1977), as follows:


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The General Nature of the services Rendered; the Amounts Involved and the Results obtained.1

On February 4, 2009, Petitioning Creditors Eileen McCabe, Jane L. Otto, and Diane

Kaplan-Berk filed a Chapter 7 Involuntary Petition in the Southern District of Florida against the

Debtor, Merendon Mining (Nevada), Inc., a Nevada corporation (D.E. 1). Because of the

pendency of another involuntary petition brought by other investor creditors in Colorado that

was subsequently dismissed, it was almost four months, or until June 2009, that an order for

relief was entered on June 9, 2009 (D.E. 29) and Marcia T. Dunn was appointed on June 10,

2009 (D.E. 30) as the Chapter 7 Trustee of this substantively consolidated bankruptcy estate2. On

June 17, 2009, this Court approved Applicant’s employment as counsel for the Trustee, nunc pro

tunc to June 11, 2009 (D.E. 34).

From the inception of this case, the Trustee and her professionals have done all they can

to keep the process open and communicate with creditors/ investors on the status of the case and

our efforts on their behalf. Notwithstanding that this estate until very recently had no assets,

Applicant nonetheless set up a website for creditors or any party interest to go to for updates on

the status of this case, the cost of setting up and maintaining being absorbed by Applicant. In the

early stages of the case, Applicant and the Trustee held a series of conference calls with investors

to apprise them of where we intended and saw this case going, as well as to discuss the unique

set of problems and circumstances that we faced in effectuating any sort of meaningful recovery

in the case. The approach we have followed has been vetted to and with these creditors,

Applicant has fielded hundreds of calls from these investor/ creditors over the course of this case

apprising them of the efforts and approaches we were taking and have continued to take.

1 For the purposes of brevity, Trustee shall incorporate this section on the historical actions taken in this case into her application for payment of her financial advisors, Marcum LLP, as if fully set forth therein as well.2 On December 15, 2009, Trustee through Applicant, filed an adversary proceeding seeking substantive consolidation of multiple entities into this estate (Case No. 09-02518), and on December 17, 2009 filed a motion, as amended, on December 18, 2009, seeking the same (D.E. 66, 70), which substantive consolidation occurred by Order of this Court on January 27, 2010, as amended on February 26, 2010 (D.E. 84, 109). On March 11, 2010, this Court entered partial summary judgment in the adversary case (D.E. 62 in that case) substantive consolidating the American mining companies and properties into the Debtor’s estate.


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Applicant had been in communication with the criminal and regulatory investigative

authorities including representatives from the Alberta Securities Commission (the “ASC”), the

Securities and Exchange Commission (the “SEC”), the Royal Canadian Mounted Police (the

“Canadian Mounties”), the Federal Bureau of Investigation (the “FBI”), the Internal Revenue

Service (the “IRS”), the United States District Attorney's Office for the Southern District of New

York (the “US Attorney”), all of whom have ongoing investigations into the fraud that lies at the

heart of this case. However, because of these pending investigations, none of these agencies have

been in a position to share with us the results of their efforts. On the other hand, much of the

work of these agencies has resulted from our sharing the results of our efforts in this matter,

including the eventual issuance of injunctions from a Federal District Court in Washington State

brought by the SEC against the fraud’s perpetrators. We have reached multiple agreements with

the SEC which have been designed to protect all investors of the entire fraud and allowed them

to file late claims in this case, and allowed for the SEC to file a large protective claim on all their

behalves, which will be diminished as recoveries are made and distributions made to claimants.

The SEC has also agreed that any recoveries it effectuates will be distributed through this

bankruptcy estate to claimants.

We have also been exchanging information and cooperating with Mike Quilling, the

receiver appointed in Canada over the debtor's principal's and affiliates who reside in Calgary,

Alberta, Canada (the “Canadian Receiver”), and been in discussions with him about effectuating

joint protocols to jointly pursue assets outside of North America at a time, if and when, the

respective Canadian and American estates can afford to do so.

In addition, we have been working with representatives from the Environmental

Protection Agency (the “EPA”), and the Colorado Attorney General's office (the “AG”)

regarding any potential environmental issues concerning the mines, which fortunately for the

estate had already been cleaned up by the EPA pre petition.


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Also, we have interviewed many of the affiliates of the perpetrators of this fraud, Messrs.

Capstick, Werner and Adair, none of which, except Mr. Garfinkle, who were willing to have any

discussions with us on the record or in legal proceeding because of pending administrative and

criminal investigations against them.

While there was between $135 to $150 million in investor money lost as a result of the

American Merendon mining scheme (most of whom have filed claims in this case), this case is

also part of a much larger fraud, predating the American fraud, that began in Canada and was the

subject of a pending Canadian insolvency receivership proceeding at the time this case was filed.

Most of the billions in fraud long predated the creation of the American Merendon scheme, and

involved Canadian companies, assets and victims. By the time this case was filed, the Canadian

receiver already had an injunction against all the principals and debtor's affiliated assets in

Canada.

When this case was filed it had absolutely no assets, and that has remained the case until

just recently. Unfortunately this case lacked any assets in some part by virtue of the fact that the

investigative and criminal authorities in those other cases moved much more quickly then in this

case to shut down the fraud, at the time those cases were filed those schemes were still operating

and had assets to seize, the assets in those cases were located in the United States, and the

perpetrators of the fraud were American citizens residing in the jurisdictions were those cases

were brought.

Because this estate had no assets, initially Mr. Garfinkle represented to us that he would

be able to provide the estate with financing through funding from some of the defrauded

investors, which would have allowed me to hire foreign investigators, and possibly foreign

counsel, in order to locate and secure assets that had been moved offshore. Those promises

proved to be hollow. Therefore Applicant and the Trustee were left with a choice between trying

to obtain and liquidate American mining assets that we were able to trace were bought with


5

investor funds, or the more daunting task (as pointed out by this Court at repeated hearings) of

trying to bring back the majority of investors funds back into the estate that had been moved

offshore through a defunct Bahamian entity to Gary Sorenson's mining interests and companies

in South and Central America.

While Applicant did get the Bahamian pass through entity, controlled by Mr. Werner, to

turn over its ownership interest in a minority percentage of the Ecuadoran mine (the majority of

which is held by one of Mr. Sorenson’s companies), one of the problems faced in acquiring

ownership of the Latin American mines, beyond the obvious difficulty in obtaining and

enforcing judgments in those jurisdictions, is that the mining rights associated with these Latin

American mines are owned by their respective government and unless licensing and royalty fees

are paid to those governments the mining rights revert back to those governments. Because of the

injunction against the use of Mr. Sorenson’s assets obtained in the Canadian Receivership, and

Canadian regulatory and criminal actions, Mr. Sorenson has been unable to fund and has allowed

those mining rights to lapse and revert back to those governments.

The Discovery Day Mine Recovery

On June 11, 2010 (D.E. 152) Trustee moved against the purported owners a California

mine called Discovery Day for violation of the automatic stay, which was resolved by Order

dated July 1, 2010 (D.E. 155) The impetus for the motion was an accident occur upon that mine

were someone was killed. Fortunately it was the one mine upon which title had never transferred

to debtor or one of its affiliates because the mine was bought under an installment land sales

contract that debtor had defaulted upon so that title never transferred. Fortunately, that mine at

the time of the accident was being operated by the seller who still retained title. The initial

settlement required the seller to make the Trustee a loss payee, be indemnified by the seller, and

to insure and agree to not dispose of the Discovery Day Mine. Eventually we reached a court

approved settlement (D.E. 226, Motion, dated April 7, 2011, D.E. 236, Order, dated May 5,


6

2011) with the seller of Discovery Day for $300,000 of which the last $250,000 was just paid on

April 16, 2012 (after an initial $50,000 down payment) in which the estate relinquished its

interest in Discovery Day, and acknowledged it never had an interest in that mine.

The Glory Hole Mine Recovery

The history of the Glory Hole mine as it relates to this case is that it had been owned by

the late Mr. Caldwell, who was sued by a judge in Texas who got a default judgment against him

and then had the judgment domesticated and executed upon in Colorado. That Texas judgment

had been subsequently set aside as a result of it being issued without due process, and the

Colorado judgment is also in the process of being set aside, if it hasn't already occurred. As part

of that execution, Garfinkle had the judge sell, and Merendon, with over $300,000 of investor

funds, buy the Glory Hole, and then had title to the property vested in a Merendon affiliate called

Sentinel Mining that was controlled by Garfinkle. Garfinkle then obtained a power of attorney

from Caldwell, under what has been described by Caldwell as questionable circumstances, and

settled the dispute. As a result, ownership, while titled in Sentinel (which by Court Order was

subsequently substantively consolidated into this case voluntarily by Garfinkle) was the subject

of multiple lawsuits and claims with the Caldwell Estate and parties who had taken title to the

mine from Caldwell after he had been divested of his ownership.

The multiple investigations into this case have been looking not just into whether the

Merendon scheme was a Ponzi scheme, but whether it was also being sold to investors as

improper tax shelters. Those investigations remain pending. Apparently because of Garfinkle’s

history with these types of investments, the principals of Merendon felt comfortable enough with

Mr. Garfinkle to bring them into their confidences. While we have found no evidence to neither

suggest nor do we have reason to believe that Mr. Garfinkle was a participant in the Merendon

fraud, apparently Merendon's principals did confide in Mr. Garfinkle because they found him to

be a kindred spirit.


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Because of his pre-petition history with the Glory Hole mine, Mr. Garfinkle has long

expressed an interest in acquiring that mine and has often expressed his belief that he had some

sort of equitable claim in the proceeds from the sale of any such mine, though he never showed

that he had any independent right in his own regard to assert the same other then the fact that he

had possessed a power of attorney from Caldwell. Mr. Garfinkle always wanted the Glory Hole

mine, yet he never put up a contract or money to buy it, and even scared away one of the buyers

we had for all the Colorado mines.

Applicant, the Trustee and her Court approved auctioneers, had been speaking to multiple

buyers presented to us by multiple parties that through relationships with various parties in

interest in this case, including governmental entities, have expressed an interest in making offers

for the various mining interests.

Trustee finally found a buyer and entered into a lucrative contract, dated July 13, 2010

with Coral Gables International Business Enterprises, LLC, which was the subject of an initial

sale motion, on September 3, 2010, to sell the three Colorado Mining Properties in bulk for

$2,250,000 (D.E. 167), and was accompanies by the Trustee filing on September 29, 2010 an

adversary proceeding under Case No. 10-03623 to sell the Colorado Mining Properties under 11

U.S.C. §363 (D.E. 177). However, this offer was interfered with by Mr. Garfinkle who contacted

the buyer directly, because he wanted Glory Hole for himself, leading to the initial buyer

walking away from the transaction to buy all the Colorado mines.

Fisher Auctions then contacted various industry and trade contacts in efforts to generate

interest in these mines since their engagement. They worked the market, and the Trustee

considered every offer presented. However, except for the few instances that have been

presented to the Court, Applicant and the Trustee had not been able to get signed offers with a

deposit. This included potential buyers who had been previously introduced to us by Mr.

Garfinkle, but who never made an actual offer to buy any of these properties.


8

Eventually a new buyer, Glory Development Company (“GDC”), was located and

entered into a June 6, 2011 contract with the Trustee to purchase just the Glory Hole mine at a

stalking horse price of $495,000 (which was the subject of an amended sale motion filed on June

9, 2011 (D.E. 245)), but the Court, at the July 21, 2011 hearing on that sale, wouldn't approve the

sale while ownership issues remained unresolved (D.E. 252, dated July 22, 2011). Hence

Applicant met with the parties with competing ownership claims, and negotiated an agreement

(Ex. A. to Motio to Approve Settlement dated August 19, 2011, D.E. 262, 263) that was

ultimately approved by the Court on September 29, 2011 (D.E. 282) for $600,000 less a 10%

auctioneer’s commission, that would go directly into the estate for abandoning the estate’s claim

to the Glory Hole mine.

The Boulder County Mines Recovery

However, Trustee and Applicant was able to convince the rejected potential buyer of the

Glory Hole Mine, GDC, to enter into a July 28, 2011 contract to instead purchase the remaining

Colorado mines, Bueno and Black Rose (the “Boulder County Mines”) for a stalking horse price

of $495,000 which contract was the subject of a motion to sell the Boulder County Mines on

August 2, 2011, as amended on August 3, 2011 (D.E. 254, 256). After an auction and a hearing

on January 4, 2012 (D.E. 284) this Court approved the sale of the Boulder County Mines to the

winning bidder, David Badner/ Badner Group, Inc. (“Badner”), on January 19, 2012 (D.E. 287)

for $540,000.00, less an expense reimbursement to GDC, and a 10% auctioneer’s commission.

The Boulder County Mines had one lien claimant, Worldwide Rental Services, Inc. a/k/a

Worldwide Machinery, Inc. (“Worldwide”) as a result of a post-petition, but pre-substantive

consolidation judgment lien obtained against one of the substantively consolidated debtors, who

held title to the Boulder County Mines. Trustee reached a settlement for the payment of $88,817

to Worldwide, and filed a motion on March 30, 3012 to approve that settlement, in full

satisfaction of Worldwide’s lien claim to be paid from the proceeds of the sale of the Boulder


9

County Mines (D.E. 290), which settlement was approved by this Court on April 25, 2012 (D.E.

293).

Now that these settlements and sales have been approved, completed and been paid,

resulting in a gross recovery of $1,440,000, Applicant and the Trustee are now at a stage in these

proceedings, after three years, to make this its first application for payment of Applicant, and

Trustee’s financial advisors’ fees and costs, and seeks 100% of those fees and costs on an interim

basis, as compared to the traditional 80% of interim fees, in light of the long wait Applicant and

the financial advisor have had to make before recoveries have finally been made in this case.

Upon approval and payment of these professional fees and costs, the Trustee will then

exercise her business judgment as to whether to proceed to then make a smaller distribution, or

to use the balance of the funds generated by the settlements and sale to go for more significant,

but more difficult, extraterritorial recoveries, or sale of those rights.

The Time and Labor Required: The transcribed time records annexed hereto as Exhibit

"3" show that partners, associates and paralegals associated with your Applicant have devoted

2,351.80 hours of time to servicing the Trustee from June 11, 2009 through March 31, 2012.

The Novelty and Difficulty of the Services Rendered: The legal questions arising in the

representation of the Trustee to date were unusually novel and difficult, and required the exercise

of skillful application of Bankruptcy Code provisions relating to recovery of assets of the estate.

This was a complex international Ponzi scheme conducted initially in Canada by Canadian

citizens, then moved to Colorado, Nevada, Arizona and California involving mines in those

states, the fraud was conducted awhile before the bankruptcy filing, and the monies have been

traced to mining operations in South and Central America. Also obtaining and locating the

cooperation of participants in the fraud, as well as cooperation with governmental authorities has

been difficult due to pending criminal and administrative proceedings by Federal, state and

provincial authorities in multiple states and Canada. The case involved issues of real property


10

and mining law in multiple jurisdictions, and the ability to find information about the assets of

the estate has proven to be elusive.

The Skill Requisite to Perform the Services Properly: In order to perform the legal

services enumerated herein properly, substantive legal knowledge in the fields of bankruptcy,

commercial law, debtor-creditor rights, mining, asset sales, international law, the law of

substantive consolidation, and the duties and powers of a Trustee were required.

The Preclusion of Other Employment by the Professional Due to the Acceptance of the

Case: Applicant is aware of no other employment which was precluded as a result of accepting

this case; however, due to the time spent on this case, Applicant was unable to devote that time

to other matters, therein preventing Applicant from billing and collecting fees in other cases.

The Customary Fee: The rates charged by the participating attorneys and paralegals, as

set forth in the exhibits are well within the range charged by attorneys in the Southern District of

Florida of similar skill and reputation in the area of bankruptcy and commercial law.

Time Limitations Imposed by the Client or Other Circumstances: No specific time

limitations were imposed by the Trustee, but Applicant made all efforts to act quickly in the

representation of the Trustee in this Chapter 7 case. This is Applicant’s first fee application and

Applicant has worked on this matter for approximately three years without seeking or obtaining

compensation for its services.

The Experience, Reputation, and Ability of the Professional: Applicant, is an established

law firm having substantial experience in bankruptcy and commercial law and litigation. The

experience, reputation and ability of Applicant is well-known to this Court.

The Undesirability of the Case: Applicant does not find it undesirable to represent the

Trustee in any form of bankruptcy proceeding.

The Nature and Length of the Professional Relationship of the Client: Applicant has

represented the Trustee in other bankruptcy matters.


11

Awards in Similar Cases: The amount applied for by Applicant is not unreasonable in

terms of awards in cases of like magnitude and complexity. The fees requested by Applicant

comport with the mandate of the Bankruptcy Code, which directs that services be evaluated in

the light of comparable services performed in on-bankruptcy cases in the community. Applicant

respectfully prays that this Court take notice that Applicant occupies professional offices,

maintains sophisticated office equipment, and a staff including paralegals, secretarial and other

support personnel. Consequently, a substantial portion of such hourly fee as may be awarded to

the Applicant will merely defray the overhead and expenses already incurred and paid in cash

during the pendency of this proceeding.

WHEREFORE, the applicant seeks a first and interim award of fees in the amount of

$716,885.00 and costs in the amount of $37,619.34 for this period for a total final award of

$754,504.34.

GRAYROBINSON, P.A.Attorneys for Plaintiff, Marcia Dunn, Chapter 7 Trustee401 E. Las Olas Blvd., Suite 1850Fort Lauderdale, FL 33301Ph. (954) 761-8111—Fax (954) 761-8112

By: /s/ Ivan J. ReichIvan J. Reich, Esq. Fla. Bar No. 778011


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CERTIFICATION

1. I have been designated by GRAYROBINSON, P.A. (the "Applicant") as the

professional with responsibility in this case for compliance with the Guidelines for Fee

Applications for Professionals in the Southern District of Florida in Bankruptcy Cases (the

"Guidelines").

2. I have read the Applicant's application for compensation and reimbursement of

expenses (the "Application"). The application complies with the Guidelines, and the fees and

expenses sought fall within the Guidelines, except as specifically noted in this certification and

described in the application.

3. The fees and expenses sought are billed at rates and in accordance with practices

customarily employed by the Applicant and generally accepted by the Applicant's clients.

4. In seeking reimbursement for the expenditures described on Exhibit 2, the

Applicant is seeking reimbursement only for the actual expenditure and has not marked up the

actual cost to provide a profit or to recover the amortized cost of investment in staff time or

equipment or capital outlay (except to the extent that the Applicant has elected to charge for

in-house photocopies and outgoing facsimile transmissions at the maximum rates permitted by

the Guidelines).

5. In seeking reimbursement for any service provided by a third party, the Applicant

is seeking reimbursement only for the amount actually paid by the Applicant to the third party.

6. The following are the variances with the provisions of the Guidelines, the date of

each court order approving the variance, and the justification for the variance: NONE.

I HEREBY CERTIFY that a true copy of this Application, with all exhibits, was served on

the 22nd day of May, 2012 to all parties registered to receive service via the Court’s CM/ECF

system and in accordance with the Court’s Order of December 30, 2009 [D.E. #74 in the main

case], shall be posted to http://gray-robinson.com/news.php?ACTION=view&CAT=1&ID=1985,

set up for the purposes of providing information on this case.

GRAYROBINSON, P.A.Attorneys for Plaintiff, Marcia Dunn, Chapter 7 Trustee401 E. Las Olas Blvd., Suite 1850Fort Lauderdale, FL 33301Ph. (954) 761-8111—Fax (954) 761-8112

By: /s/ Ivan J. Reich


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Ivan J. Reich, Esq. Fla. Bar No. 778011

\351016\4 - # 1294422 v1


# 1303073 v1 EXHIBIT “1-A”

EXHIBIT “1-A”

Summary of Professional and Paraprofessional TimeTotal per Individual for this Period Only

PROFESSIONALS:Name Year

LicensedTotal Hours Hourly Rate Total Fee

S - Robert Schatzman 1971 (FL) 0.50 $600.00 $ 300.00 S - Robert Schatzman 1971 (FL) 84.40 $550.00 $ 46,420.00S - Patrick S. Scott 1979 (FL) 16.30 $500.00 $ 8,150.00S - Patrick S. Scott 1979 (FL) 1.50 $495.00 $ 742.50S - William M. Pearson 1985 (FL) 6.80 $500.00 $ 3,400.00S - Frank Terzo 1991 (FL) 13.90 $450.00 $ 6,255.00S - Ivan J. Reich 1988 (FL) 903.60 $450.00 $406,620.00 S - Ivan J. Reich 1988 (FL) 59.00 $400.00 $ 23,600.00S - Jeffrey A. Bahnsen 1991 (FL) 21.80 $450.00 $ 9,810.00S - Jeffrey A. Bahnsen 1991 (FL) 2.10 $400.00 $ 840.00S - Leyza F. Blanco 1997 (FL) 0.20 $415.00 $ 83.00S - Steven J. Solomon 1992 (FL) 11.00 $390.00 $ 4,290.00S - Jason B. Burnett 1989 (FL) 13.70 $365.00 $ 5,000.50OC - Nathan G. Mancuso 1999 (FL) 16.90 $350.00 $ 5,915.00A - Ji Hun Kim 2010 (FL) 19.30 $210.00 $ 4,053.00A - Michael D. Lessne 2010 (FL) 91.00 $225.00 $ 20,475.00 A - Michael D. Lessne 2010 (FL) 154.30 $215.00 $ 33,174.50A - Michael D. Lessne 2010 (FL) 214.90 $190.00 $ 40,831.00A - Jarred Leibner 2011 (FL) 54.30 $175.00 $ 9,502.50A - Jarred Leibner N/A 61.80 $125.00 $ 7,725.00A - Paige Wagner 2008 (FL) 41.50 $150.00 $ 6,225.00A- Shayna A. Freyman 2010 (FL) 0.40 $125.00 $ 50.00 A - Kirsten Wegel 2010 (FL) 13.50 $110.00 $ 1,485.00SUBTOTALS: 1,802.70 $644,947.00S = Shareholder; A = Associate; OC = Of Counsel

PARAPROFESSIONALS:Name Year

LicensedTotal Hours Hourly Rate Total Fee

PL - Lisa A. Negron N/A 58.60 $160.00 $ 9,376.00PL - Nancy H. Nicole N/A 116.30 $140.00 $ 16,282.00PL - Jessica Serrano- Cartagena

N/A 229.60 $125.00 $ 28,700.00

PL - Susan Stirling N/A 138.00 $125.00 $ 17,250.00LS – Emma Bartling N/A 6.60 $ 50.00 $ 330.00SUBTOTALS: 549.10 $ 71,938.00 PL = Paralegal; LS = Litigation Support

TOTALS:

Total Professional and Paraprofessional Hours: 2,351.80Blended Average Hourly Rate: $304.82Total Professional and Paraprofessional Fees: $716,885.00

Case 09-11958-AJC Doc 296-1 Filed 05/22/12 Page 1 of 1

EXHIBIT “1-B”

EXHIBIT “1-B”

Summary of Professional and Paraprofessional Time by Activity Code Category

ACTIVITY CODE CATEGORY: Asset Analysis and Recovery (001)Name Rate Hours Total FeesRobert Schatzman $550.00 57.60 $ 31,680.00William M. Pearson $500.00 1.20 $ 600.00Patrick S. Scott $500.00 1.60 $ 800.00Patrick S. Scott $495.00 0.80 $ 396.00Ivan J. Reich $450.00 122.40 $ 55,080.00Ivan J. Reich $400.00 1.30 $ 520.00Leyza F. Blanco $415.00 0.20 $ 83.00Steven J. Solomon $390.00 10.50 $ 4,095.00Nathan G. Mancuso $350.00 3.80 $ 1,330.00Michael D. Lessne $225.00 3.70 $ 832.50Michael D. Lessne $215.00 6.20 $ 1,333.00Michael D. Lessne $190.00 6.80 $ 1,292.00Jarred Leibner $175.00 6.20 $ 1,085.00Jarred Leibner $125.00 58.30 $ 7,287.50Lisa A. Negron $160.00 3.30 $ 528.00Paige Wagner $150.00 18.40 $ 2,760.00Jessica Serrano-Cartagena $125.00 0.30 $ 37.50Susan Stirling $125.00 2.00 $ 250.00MATTER TOTAL: 304.60 $109,989.50

ACITIVTY CODE CATEGORY: Asset Disposition (002)Name Rate Hours Total FeesRobert Schatzman $600.00 0.50 $ 300.00Patrick S. Scott $500.00 1.20 $ 600.00Patrick S. Scott $495.00 0.70 $ 346.50Ivan J. Reich $450.00 145.90 $ 65,655.00Jeffrey A. Bahnsen $450.00 21.80 $ 9,810.00Jeffrey A. Bahnsen $400.00 2.10 $ 840.00Nathan G. Mancuso $350.00 8.30 $ 2,905.00Michael D. Lessne $225.00 56.00 $ 12,600.00Michael D. Lessne $215.00 103.20 $ 22,188.00Michael D. Lessne $190.00 77.90 $ 14,801.00Jarred Leibner $175.00 11.90 $ 2,082.50Jarred Leibner $125.00 3.50 $ 437.50Nancy H. Nicole $140.00 2.70 $ 378.00Jessica Serrano-Cartagena $125.00 14.10 $ 1,762.50Susan Stirling $125.00 72.20 $ 9,025.00MATTER TOTAL: 522.00 $143,731.00


EXHIBIT “1-B”

ACTIVITY CODE CATEGORY: Case Administration (004)Name Rate Hours Total FeesRobert Schatzman $550.00 18.00 $ 9,900.00Frank Terzo $450.00 12.10 $ 5,445.00Ivan J. Reich $450.00 250.80 $112,860.00Ivan J. Reich $400.00 48.60 $ 19,440.00Steven J. Solomon $390.00 0.30 $ 117.00Jason B. Burnett $365.00 11.70 $ 4,270.50Nathan G. Mancuso $350.00 1.60 $ 560.00Michael D. Lessne $225.00 13.10 $ 2,947.50Michael D. Lessne $215.00 7.70 $ 1,655.50Michael D. Lessne $190.00 100.00 $ 19,000.00Jarred Leibner $175.00 2.20 $ 385.00Lisa A. Negron $160.00 35.90 $ 5,744.00Paige Wagner $150.00 15.30 $ 2,295.00Nancy H. Nicole $140.00 12.30 $ 1,722.00Jessica Serrano-Cartagena $125.00 154.70 $ 19,337.50Susan Stirling $125.00 10.20 $ 1,275.00Kirsten Wegel $110.00 7.00 $ 770.00MATTER TOTAL: 701.50 $207,724.00

ACTIVITY CODE CATEGORY: Claims Administration and Objections (005)Name Rate Hours Total FeesPatrick S. Scott $500.00 8.70 $ 4,350.00Ivan J. Reich $450.00 122.80 $ 55,260.00Nathan G. Mancuso $350.00 0.10 $ 35.00Michael D. Lessne $225.00 0.40 $ 90.00Michael D. Lessne $215.00 3.80 $ 817.00Jarred Leibner $175.00 6.70 $ 1,172.50Jessica Serrano-Cartagena $125.00 3.70 $ 462.50Susan Stirling $125.00 1.30 $ 162.50MATTER TOTAL: 147.50 $ 62,349.50

ACTIVITY CODE CATEGORY: Fee/Employment Applications (007)Name Rate Hours Total FeesRobert Schatzman $550.00 3.90 $ 2,145.00Ivan J. Reich $450.00 3.10 $ 1,395.00Ivan J. Reich $400.00 4.50 $ 1,800.00Steven J. Solomon $390.00 0.20 $ 78.00Michael D. Lessne $190.00 1.10 $ 209.00Lisa A. Negron $160.00 6.40 $ 1,024.00Jessica Serrano-Cartagena $125.00 23.70 $ 2,962.50Susan Stirling $125.00 19.40 $ 2,425.00MATTER TOTAL: 62.30 $ 12,038.50


EXHIBIT “1-B”

ACTIVITY CODE CATEGORY: Litigation (010)Name Rate Hours Total FeesRobert Schatzman $550.00 4.90 $ 2,695.00William M. Pearson $500.00 5.60 $ 2,800.00Patrick S. Scott $500.00 4.80 $ 2,400.00Frank Terzo $450.00 1.80 $ 810.00Ivan J. Reich $450.00 217.30 $ 97,785.00Ivan J. Reich $400.00 2.00 $ 800.00Jason B. Burnett $365.00 2.00 $ 730.00Nathan G. Mancuso $350.00 3.10 $ 1,085.00Ji Hun Kim $210.00 19.30 $ 4,053.00Michael D. Lessne $225.00 17.60 $ 3,960.00Michael D. Lessne $215.00 30.80 $ 6,622.00Michael D. Lessne $190.00 25.70 $ 4,883.00Jarred Leibner $175.00 26.60 $ 4,655.00Lisa A. Negron $160.00 13.00 $ 2,080.00Paige Wagner $150.00 7.80 $ 1,170.00Nancy H. Nicole $140.00 101.30 $ 14,182.00Jessica Serrano-Cartagena $125.00 33.10 $ 4,137.50Susan Stirling $125.00 32.40 $ 4,050.00Kirsten Wegel $110.00 6.50 $ 715.00Emma Bartling $ 50.00 6.60 $ 330.00MATTER TOTAL: 562.20 $159,942.50

ACTIVITY CODE CATEGORY: Meetings of Creditors (011)Name Rate Hours Total FeesIvan J. Reich $450.00 8.10 $ 3,645.00Ivan J. Reich $400.00 2.60 $ 1,040.00MATTER TOTAL: 10.70 $ 4,685.00

ACTIVITY CODE CATEGORY: Stay Relief Proceedings (013)Name Rate Hours Total FeesIvan J. Reich $450.00 27.50 $ 12,375.00Michael D. Lessne $215.00 0.10 $ 21.50Michael D. Lessne $190.00 3.40 $ 646.00Jarred Leibner $175.00 0.40 $ 70.00Shayna A. Freyman $125.00 0.40 $ 50.00MATTER TOTAL: 31.80 $ 13,162.50

ACTIVITY CODE CATEGORY: Tax Issues (014)Name Rate Hours Total FeesIvan J. Reich $450.00 5.70 $ 2,565.00Michael D. Lessne $225.00 0.20 $ 45.00Michael D. Lessne $215.00 2.50 $ 537.50Jarred Leibner $175.00 0.30 $ 52.50Susan Stirling $125.00 0.50 $ 62.50MATTER TOTAL: 9.20 $ 3,262.50

# 1316830 v1


EXHIBIT “2”

EXHIBIT “2”

Summary of Requested Reimbursement Of Expenses for this Time Period Only [If this is a final application which does not cumulate prior interim applications, a separate summary showing cumulative expenses for all applications is attached as well]

1. Filing Fees $ 838.00

2. Process Service Fees $ 60.00

3. Witness Fees $ 0

4. Court Reporter Fees and Transcripts $ 1,769.60

5. Lien and Title Searches (Title Report) $ 1,250.00

6. Photocopies $10,388.69

(a) In-house copies ( 31,723 @ 0.204/page $6,344.60) ( 3,403 color copies @ $1.00/page $3,403.00)

(b) Outside copies by IKON ($ 641.09)

7. Postage $ 931.30

8. Overnight Delivery Charges $ 181.82

9. Outside Courier/Messenger Services $ 119.85

10. Long Distance Telephone Charges $ 1,426.27

11. Long Distance Fax Transmissions

(6 copies at 0.784/page) $ 4.68

12. Computerized Research $18,365.58

13. Travel $ 428.04

(a) Transportation ($ 184.04 )

(b) Lodging ($ 0 )

(c) Meals ($ 244.00 )

14. Other Permissible Expenses (must specify and justify) $ 1,855.51

(a) Recording, Public Records ($ 1,068.50 )

(b) Certified Copies ($ 211.05 )

(c) Document production/preparation ($ 323.75 )

(d) Meeting Expense ($ 133.06 )

(e) Other/ Misc. ($ 119.15 )

Total Expense Reimbursement Requested $37,619.34

# 1316981 v1


EXHIBIT “3”

EXHIBIT “3”

Time Records


Time by Timekeeper

Client / Matter 351016 Dunn, Marcia -Trustee Merendon Mining (Nevada), Inc.4

Bahnsen, Jeffery "Jeff"

Activity Code 002 Asset Disposition

1/12/2012 1.40 630.00 Review asset purchase agreement and related documents in connection with sale of mining claims.

1/19/2012 2.60 1,170.00 Attention to issues in connection with sale of mining claims to Golf Hill Minerals (.8); telephone conferences with purchaser's counsel (.6); prepare closing documents (1.2)

1/20/2012 4.60 2,070.00 Attention to issues in connection with sale of mining claims to Golf Hill Minerals (2.0); telephone conferences with purchaser's counsel (.7); prepare closing documents (1.9)

1/23/2012 3.20 1,440.00 Prepare closing documents (1.9); address issues raised by purchaser's counsel regarding ownership (1.3).

1/24/2012 3.10 1,395.00 Prepare for closing and finalize documents (2.2); telephone conferences with purchaser's counsel (.9)

1/25/2012 3.90 1,755.00 Attention to matters relating to closing on sale of mining claims to Gold Hill Minerals.

1/27/2012 0.60 270.00 Attention to post closing issues and transfer of interests in stock of Left Hand Ditch company

1/30/2012 0.80 360.00 Attention to post closing issues, including transfer of rights in stock of Left Hand Ditch Company (.5); discussions with purchaser's counsel (.3)

1/31/2012 1.60 720.00 Prepare affidavit of lost stock certificate (1.1); discuss issues with counsel for purchaser and counsel for Left Hand Ditch Company (.5)

2/1/2012 2.10 840.00 Attention to post closing matters and resolution of issues regarding transfer of water rights (1.6); discussion of issues with counsel for purchaser and client (.5)

$10,650.00Total Activity Code 002 23.90

$10,650.0023.90Total for Timekeeper Bahnsen, Jeffery "

Tuesday, May 22, 2012 Page 1 of 149


Bartling, Emma

Activity Code 010 Litigation

6/13/2011 1.90 95.00 Prepare responsive documents for up-coming production.

6/16/2011 2.40 120.00 Continue imaging responsive records prior to producing same.

6/17/2011 2.30 115.00 Export and Finalize responsive records for production of same.

$330.00Total Activity Code 010 6.60

$330.006.60Total for Timekeeper Bartling, Emma



Blanco, Leyza F

Activity Code 001 Asset Analysis and Recovery

10/5/2010 0.20 83.00 Merendon - Review and respond to correspondence from I. Reich regarding discussions with buyer.


$83.000.20Total for Timekeeper Blanco, Leyza F



Burnett, Jason B

Activity Code 004 Case Administration

11/24/2009 3.50 1,277.50 Review documents and follow up regarding drafting of complaint

11/25/2009 3.00 1,095.00 Continued review regarding drafting of complaint

11/25/2009 0.90 328.50 Follow up regarding Complaint

11/27/2009 2.50 912.50 Review/edit Complaint

12/1/2009 1.80 657.00 Review/Follow up regarding complaint



12/16/2009 2.00 730.00 Review complaint, motion, etc. regarding injunction relief


$5,000.5013.70Total for Timekeeper Burnett, Jason B



Freyman, Shayna A

Activity Code 013 Stay Relief Proceedings

9/13/2010 0.40 50.00 Analysis and review of case law and secondary sources regarding restraints on alienation.


$50.000.40Total for Timekeeper Freyman, Shayna



Kim, Ji Hun


1/7/2010 2.40 504.00 Conduct research regarding issues involving this case, and general background.

1/20/2010 2.60 546.00 Research Hague Convention, proper modes of international service of process, and review relevant documents.

1/21/2010 2.30 483.00 Analysis of issues in connection with service of process in foreign countries.

1/22/2010 2.00 420.00 Research and prepare memo regarding proper service of process in foreign countries.

2/1/2010 3.00 630.00 Research proper forms of service on international defendants.

2/2/2010 1.90 399.00 Research service of process (1.6) and speak to professionals regarding if mail service is proper (.3).

2/3/2010 0.70 147.00 Research service of process.

2/4/2010 1.50 315.00 Research service of process issues (1.1), contact counsel in foreign nations to inquire (.4)

2/5/2010 1.50 315.00 Research (1.2) and send out correspondence to foreign counsel regarding proper foreign service of process (.3)

2/8/2010 1.40 294.00 Research (1.2) and email in regards to foreign service of process (.2)


$4,053.0019.30Total for Timekeeper Kim, Ji Hun



Leibner, Jarred


7/8/2010 2.50 312.50 Researched and analyzed cases regarding installment land sales whether they can be treated as purchase money mortgages (.8); Reviewed case materials (.7); Read and analyzed cases discussing the law in both Nevada and California on this issue (1.0).

7/9/2010 8.80 1,100.00 Reviewed previous orders in the case and reviewed discovery documents in order to analyze issue regarding debtor's property rights in the mining rights that they purchased under an installment land sale contract (1.7); Reviewed language in the contr act and addendum's to whether this contract can be treated as a purchase money mortgage and entitle the debtor to a constructive trust over a portion of equity in the mines (2.0); Researched and analyzed materials regarding installment land sales and how they are treated under California and Nevada law (2.5); began researching the various requirements under California and Nevada regarding what a seller must do to foreclose on its property and who retains the property rights if any when the title is in escrow (2.6)

7/12/2010 7.10 887.50 Researched and analyzed statutes, cases, secondary sources, regarding treatment of installment sales under Nevada and California law, regarding whether payment of property taxes provides notice to a subsequent purchaser (1.8), regarding what procedur es a seller must go through in order to reclaim complete title to the property (2.3), regarding whether the debtor's estate includes property that is being held in escrow that is neither owned by the debtor/purchaser nor the seller (1.2), and began o rganizing arguments and reviewing case documents in order to draft a legal memorandum regarding the trustee's recovery based on the debtor's legal or equitable title to the gold mines in controversy (1.8)

7/13/2010 4.30 537.50 Reviewed case documents and legal research in order to organize arguments for legal memo regarding whether the debtor's estate has a property interest in mining claims (1.7) Conducted additional research to support argument under Nevada law regarding the treatment of Installment Land Sales Contracts (1.2), began drafting summary of the facts and argument in order to assert a legal and equitable interest in the property (1.4)

7/14/2010 8.20 1,025.00 Researched and analyzed case law regarding Nevada and California treatment of installment land sale contracts (2.3) Reviewed requirements under both jurisdictions to perform nonjudicial foreclosure and the various notice requirements to determine whe ther the seller complied with these requirements prior to terminating the debtor's interest in the property (1.7); Reviewed research regarding whether the subsequent purchaser in this case had actual or constructive notice regarding the debtor's inte rest in the Mine (2.0). Strategized how to put research together for legal memo in effort to reach a favorable settlement (2.2)



7/15/2010 9.20 1,150.00 Drafted legal memo regarding whether the debtor has a property interest in the Discovery Day Mine, where the debtor was in default under its installment land sale contract (4.1). Analyzed and conducted additional research regarding specific facts of the case and language in Amended Sales contract in order to strengthen arguments, and conducted additional research for cases that arose in bankruptcy context (5.1)

7/16/2010 1.40 175.00 Conducted final research and edits in order to complete legal memo regarding whether the debtor has a property interest in the Mine.

7/23/2010 4.30 537.50 Conducted additional research and summarized arguments regarding avoidance of the Seller's In REM of Agreement termination as a preference and whether Amendment to California nonjudicial foreclosure process in 1993 affects this analysis (2.1) Conduct ed additional research regarding whether the Debtor maintains an interest in the Mine under a theory of constructive trust or equitable lien. (2.2)

7/26/2010 2.10 262.50 Made additional revisions to legal memo regarding whether the debtor has a property interest in the California mine (1.2) and updated the section that contained the facts to reflect the updated information that contains documents that the debtor has made payments in excess of $5 million dollars towards the purchase price of the mine that was purchased under an an Installment Land Sale Contract (.9)

7/27/2010 0.90 112.50 Reviewed legal memo regarding whether the Debtor has a property interest in the Discovery Day Mine (.9)

7/29/2010 2.70 337.50 Researched issues regarding federal mining laws and additional equitable theories of recovery for the debtor

8/5/2010 2.80 350.00 Research regarding whether the debtor can recover property or payments made towards installment land sale contract in California and whether the debtor can recover under theories of constructive trust, equitable lien, or unjust enrichment (1.8) revis ions and analysis into final memo that analyzes whether debtor has a property interest in the Mine (1.0)

8/6/2010 4.00 500.00 Researched and analyzed Federal Mining laws and other state and local mining regulations (2.0); analyzed cases discussing legal and equitable title the mining claims under this legislation (2.0).

9/22/2011 0.20 35.00 Review of documents and quitclaim deeds regarding Arizona Mines

10/10/2011 1.10 192.50 Reviewed and revised language in inspection release of liability

1/16/2012 1.90 332.50 Reviewed and summarized research regarding avoidance of mechanics lien under Colorado statute (1.5). Strategy conference with P. Scott and M. Lessne regarding relevant legal issues and further research (.4)

1/16/2012 2.70 472.50 Strategy with M. Lessne and Pat Scott regarding legal arguments regarding postjudgment interest and attorneys fees for purposes of settlement (.4). Reviewed, researched and analyzed further legal authority (2.3)

1/31/2012 0.10 17.50 Correspondence with J. Sakalo's assistant regarding obtaining quitclaim deed.



2/29/2012 0.20 35.00 Correspondence, strategy, and negotiation regarding early payoff for Discovery Day Mine.



7/27/2010 0.50 62.50 Prepared for settlement negotiation meeting (.5)

7/28/2010 3.00 375.00 Settlement negotiation meeting at Bilzin Sumberg Miami office regarding treatment of the prior Orders that were entered as well as discussions regarding settlement over the Debtor's interest in the Mine.

9/21/2011 6.70 1,172.50 Reviewed and analyzed documents and pleadings for response to Garfinkle's objection to the trustee's motion to approve settlement with the Caldwell Estate. Made evisions to Joint Response.

1/20/2012 1.10 192.50 Researched and analyzed whether settlement agreement and order approving settlement agreeement have been complied with re: Discovery Day Mine.

1/23/2012 0.50 87.50 Correspondence regarding discovery day settlement agreement.

1/26/2012 0.20 35.00 Reviewed notes regarding discovery day settlement. Correpondence with J. Sakalo regarding quitclaim deed and payment. Reviewed files regarding previously sent draft of quitclaim deed.

1/30/2012 0.10 17.50 Correspondence regarding discovery day settlement.

2/1/2012 1.10 192.50 Correpondence regarding compliance with settlement and order regarding Discovery Day. Reviewed and analyzed quitclaim deed and reviewed docket regarding legal description of Discovery Day Mine.

2/15/2012 1.40 245.00 Correspondence regarding alternative settlement regarding Discovery Day Mine (.3). Reviewed and analyzed settlement agreement and order (.3). Analyzed various settlement and interest rate scenarios to evaluate settlement proposal (.8)

2/16/2012 0.50 87.50 Correspondence regarding alternative settlement regarding Discovery Day Mine.

3/1/2012 0.30 52.50 Correspondence regarding settlement for discovery day mine (.1); researched and reviewed settlement agreement and order regarding deadline to obtain payment of the modified settlement amount (.2)



9/27/2011 2.00 350.00 Attended hearing regarding 363 sales procedures and settlement of Glory Hole

2/7/2012 0.10 17.50 Correspondence with M. Lessne regarding research of attorneys fees and costs under Colorado law.

2/9/2012 0.10 17.50 Correspondence regarding compliance with settlement agreement and order for Discovery Day.




Activity Code 005 Claims Administration and Objections

9/23/2011 1.80 315.00 Research regarding standing issue to file Proof of claim

9/23/2011 2.90 507.50 Review of Garfinkle's response to Trustee's claim objection and analyzed documents related to standing.

9/26/2011 1.10 192.50 Researched and analyzed case law regarding derivative standing to file a proof of claim as a creditor

9/30/2011 0.70 122.50 Objection to amended claim of Paul Garfinkle

10/17/2011 0.20 35.00 Objection to Paul Garfinkle's Amended Claim No. 482



9/26/2011 2.10 367.50 Researched and analyzed case law holding that Power of Attorney not coupled with an interest is revocable by the principal

9/27/2011 2.30 402.50 Drafted memo regarding Garfinkle's standing

10/17/2011 0.40 70.00 Conference call to discuss liability issues related to property inspections

10/18/2011 0.90 157.50 Research regarding whether a judgment during the preference period can be avoided when there was a statement of lien recorded prior to the preference period

10/18/2011 2.70 472.50 Researched and analyzed cases regarding whether lien could be stripped from entity that became a debtor only after the substantive consolidation

10/19/2011 1.80 315.00 Researched and analyzed Florida law on mechanics liens and requirements to perfect

11/3/2011 0.60 105.00 Researched and summarized legal issues regarding the validity of Worldwide machinery's lien

1/13/2012 1.30 227.50 Researched and analyzed whether postpetition judgment could be avoided where statement of lien was recorded more than 90 days prior to petition date.

1/13/2012 0.80 140.00 Researched and analyzed case law, regarding nunc pro tunc order and substantive issues.

1/14/2012 3.30 577.50 Researched and analyzed statutes and case law from Colorado regarding requirements to perfect a mechanics lien.

1/16/2012 1.60 280.00 Researched and analyzed issue of federal preemption regarding postjudgment interest (.5); Researched and shepardized cases from the 11th Circuit (.4). Researched and analyzed cases regarding postjudgment attorneys fees (.7)

1/16/2012 2.70 472.50 Researched and analyzed case law and statutes regarding postjudgment rate of interest and award of attorneys fees in Colorado



1/17/2012 1.40 245.00 Researched and analyzed Colorado statutes and case law regarding right to recover postjudgment contractual rate of interest and attorneys fees based the contract.

1/18/2012 1.90 332.50 Researched and analyzed Colorado statutes and case law regarding right to recover postjudgment contractual rate of interest and attorneys fees based the contract.

1/20/2012 1.70 297.50 Research and strategy with Pat Scott and M. Lessne regarding postjudgment and postpetition fees and costs of secured creditor, including whether a proof of claim needs to be filed in order to recover under 506(b) as a holder of an allowed secured cla im.

2/2/2012 0.60 105.00 Reviewed and revised quitclaim deed (.3). Correspondence with J. Sakalo regarding same (.3).

2/6/2012 0.50 87.50 Reviewed and revised redlines to discovery day quitclaim deed (.3). Correspondence with J. Sakalo regarding same (.2)



12/9/2011 0.40 70.00 Reviewed documents and correspondence regarding strategy of whether to file motion for relief for Dolen Springs mine under section 549.


Activity Code 014 Tax Issues

9/22/2011 0.30 52.50 Email and phone correspondence regarding whether there are any tax assessments on Merendon Mining Property in Boulder County, Colorado.


$17,227.50116.10Total for Timekeeper Leibner, Jarred



Lessne, Michael D


6/10/2010 4.00 760.00 Conference with W. Capstick and P. Garfinkle re: Discovery Day Mine sale and deed, and additional defendants to be served (1.5); researched American Sierra Gold Corp and Discovery Day Mine (1); further prepared motion for contempt and sanctions for violation of automatic stay (1); reviewed service of summary judgment (.2); conference with I. Reich re: motion for violation of stay (.3)

7/12/2010 1.50 285.00 Further prepared application for auctioneer, affidavit, and order on same (.3); conference with I. Reich re: same (.3); exchanged correspondence with Fisher Auctioneers re: same (.2); reviewed and revised Nordic's agreed motion to pay R. Brodsky $1 0,000 (.5); conference with I. Reich re: same (.2)

7/23/2010 0.50 95.00 Reviewed Memorandum by J. Leibner on the Discovery Day Mine (.2); correspondence with J. Leibner re: same (.3)

8/9/2010 0.80 152.00 Correspondence with L. Weltzer re title search of Colorado Mining Properties and U.S. Merendon Mining Entities (.4); reviewed production from L. Weltzer re title (.4)

1/11/2011 0.10 21.50 Conference with Garfinkle re mines (.1)

1/18/2011 1.00 215.00 Prepared listing of recorded interests in Colorado Mining Properties (.5); conference with F. Santos re property (.3); correspondence with M. Dunn re same (.2)

2/3/2011 1.20 258.00 Conference with T. Cazier and E. Crosby from the CO Div of Reclamation re the Colorado mines (1); correspondence with M. Dunn and I. Reich re same (.2)

2/4/2011 0.20 43.00 Reviewed correspondence from E. Crosbey re CO Reclamation and the Bueno mine

2/10/2011 0.30 64.50 Correspondence with T. Cazier re Bueno Mine status

3/10/2011 0.20 43.00 Reviewed notice of reclamation and correspondence with M. Dunn's office re same

3/29/2011 0.20 43.00 Correspondence with F. Santos re colorado mines

4/26/2011 0.20 43.00 Correspondence with F. Santos re prospective purchaser T. Millar

5/2/2011 0.10 21.50 Correspondence with TJ Millar re letter of intent to purchase Glory Hole Mining Properties

5/13/2011 0.20 43.00 Correspondence with D. Koff and correspondence with F. Santos re legal description of Glory Hole Mining Properties

6/20/2011 0.10 21.50 Correspondence with F. Santos re prospective purchaser B. Young

6/22/2011 0.30 64.50 Correspondence with F. Santos and I. Reich re Glory Hole mining properties

6/29/2011 0.30 64.50 Strategy re potential bidders for Glory Hole



6/30/2011 1.50 322.50 Conference with G. Papas, D. Murray, I. Reich, F. Santos, and L. Fisher re potential bid on Glory Hole mining properties (1); conference with F. Santos and I. Reich re same (.3); correspondence with M. Dunn re same (.2)

7/27/2011 0.30 64.50 Reviewed correspondence from N Frank re equipment on mines in Boulder county

10/4/2011 0.90 202.50 Correspondence and conference with T Plumber of the Left Hand Ditch Company re Merendon's shares of stock and water rights in CO affecting the Bueno and Black Rose mines (.5); reviewed stock certificate (.2); correspondence and conference with S Doyl e re Left Hand Ditch Co (.2)

1/27/2012 2.80 630.00 Reviewed judgment in favor of Dolen Springs Mine and Development and against MMI and transfer to Silma, and strategy and analysis re same, including conferences with P Scott and I Reich re avoidability of transfers (1.5); conferences with attorney fo r Dolan Springs Mine & Development K Parker re circumstances for transfer (.5); prepared memorandum for M Dunn and corresp and conf with M Dunn re same (.8)



7/15/2010 3.00 570.00 Prepared trustee's motion for the sale of three mines

7/16/2010 2.00 380.00 Further prepared sale motion and of Colorado Mining Properties and complaint

7/16/2010 0.50 95.00 Reviewed application for auctioneer (.3); correspondence re: same (.20)

7/19/2010 2.00 380.00 Prepared motion for sale of Colorado Mining Properties

7/20/2010 3.00 570.00 Further prepared motion for sale of Colorado Mining Properties

7/23/2010 6.50 1,235.00 Further prepared motion to sell free and clear of liens claims and encumbrances, and sale procedures

7/26/2010 6.50 1,235.00 Further prepared motion to sell Colorado Mining Properties (3.0); prepared complaint to sell pursuant to 363(h) and for declaratory judgment (3.5)

7/27/2010 4.70 893.00 Further prepared 363 motion to sell Colorado Mining Properties and further prepared complaint to sell co-owners interest in same (3.5); conference with N. Mancuso re: same (1); conference with I. Reich and S. Stirling re: title search (.2)

7/28/2010 4.00 760.00 Prepared for (2.0) and attended conference with J. Sakalo, I. Reich, and J. Leibner re: the Discovery Day Mining Property and ownership claims (2.0)

7/29/2010 3.00 570.00 Further prepared complaint (.5); conference with I. Reich, P. Scott, N. Mancuso, J. Leibner, and S. Stirling re: sale of Colorado mines (2.3); conference with S. Stirling re: title search of mines (.2)

8/2/2010 5.50 1,045.00 Further prepared motion for sale pursuant to 363(f)(4) (2.0); researched cases providing for the the sale of disputed interests (2.0); prepared memo re same (1.50)



8/3/2010 1.20 228.00 Further prepared sale motion and complaint (.10; conference with S. Stirling re title search (.2)

8/5/2010 9.20 1,748.00 Further prepared motion for the sale of Colorado Mining Properties and complaint to determine validity, priority, and extent of liens, claims, encumbrances, and interest (2.0); researched 363(f)(4) cases allowing for the sale of property free and cle ar of ownership interests (7.2)

8/6/2010 5.50 1,045.00 Further prepared sale motion and complaint

8/6/2010 0.60 114.00 Confernce with L. Weltzer re title issues

8/9/2010 0.70 133.00 Prepared revised letter of intent (.4); correspondence with H. Winderman re same (.3)

8/10/2010 0.20 38.00 Prepared documents for conference with I. Reich re sale motion and complaint

8/10/2010 1.50 285.00 Conference with I. Reich and S. Stirling re title issues, sale, and case

8/11/2010 1.90 361.00 Researched and finalized sale motion (1.6); correspondence with H. Winderman re letter of intent, sale motion, deposit, and operating agreement (.3)

8/11/2010 1.50 285.00 Conference with M. Morrison re Wabuska Mining's Discovery Day mining claims (1.3); correspondence with M. Morrison, I. Reich, and S. S. Stirling re same (.2)

8/11/2010 0.20 38.00 Correspondence with I. Reich and S. Stirling re N. Franks equipment claims at Bueno Mine and sale of equipment

8/12/2010 1.30 247.00 Correspondence with H. Winderman re permission to speak to M. Salit re sale (.1); correspondence with M. Salit re same (.1); telephone conference with M. Levin re Bueno mine, equipment, N. Frank, and L. Taylor (.6); memo to I. Reich re same (.4); cor respondence with M. Levin re same (.1)

8/13/2010 2.70 513.00 Conference with I. Reich, M. Salit, and C. Pierce re sale of Colorado Mining Properties (.8); conference with S. Stirling re M. Levin and sale of mucker (.2); conference with F. Santos re auction (.6); correspondence with F. Santos, I. Reich, and S. Stirling re same (.6); correspondence with M. Levin re same (.2); reviewed motion to sell equipment (.3)

8/16/2010 1.00 190.00 Conference with I. Reich re sale, sale motion, complaint, asset purchase agreement, and auction

8/16/2010 3.00 570.00 Further prepared sale motion and complaint

8/17/2010 2.30 437.00 Further prepared sale motion

8/17/2010 3.50 665.00 Correspondence with S. Stirling re complaint and titling of mines (.4); correspondence with L. Weltzer re titling (.4); reviewed title documents (1.2); conference with F. Santos re same (.7); telephone conference with N. Frank re equipment (.8)

8/20/2010 0.30 57.00 Conference with I. Reich re sale motion and complaint (.2); correspondence with L. Weltzer re titling of mines (.1)

8/25/2010 0.30 57.00 Further prepared complaint by adding additional information re Norm Frank



8/31/2010 0.30 57.00 Conference with F. Santos re status of sale and auction materials

9/3/2010 2.70 580.50 Conference with I. Reich and S. Stirling re motion for relief from stay, sale motion and Asset purchase agreement (.5); finalized sale motion (2); correspondence with H. Winderman re same (.2)

9/7/2010 0.30 64.50 Conference with I. Reich and H. Winderman re Asset purchase agreement and deposit (.2); conference with S. Stirling re deeds (.1)

9/10/2010 0.20 43.00 Conference with J. Armengol re Asset purchase agreement and stalking horse procedures (.2)

9/13/2010 2.30 494.50 Amended sale motion and asset purchase agreement (2); conference with I. Reich re same (.3)

9/15/2010 2.30 494.50 Revised Asset purchase agreement and Sale Motion to incorporate 363(i) features (2.3)

9/16/2010 2.30 494.50 Further prepared complaint to determine validity, extent, and priority of liens, claims and interests

9/17/2010 0.50 107.50 Conference with I. Reich re adversary complaint (.3); conference with S. Stirling re same (.2)

9/20/2010 1.50 322.50 Further prepared complaint

9/21/2010 0.80 172.00 Conference with S. Stirling and I. Reich re complaint (.5); finalized complaint (.3)

9/29/2010 5.00 1,075.00 Correspondence with I. Reich re stalking horse bidder due dilligence and tasks (.5); reviewed objection to sale motion (.2); reviewed motion for relief from stay from SE Bank (.3); conference with A. Brodsky and S. Stirling re same (.2); prepared con tinuance motion and motion to strike (3.5); correspondence with I. Reich re same (.3)

10/6/2010 0.20 43.00 Prepared Asset purchase agreement for potential new buyer

10/14/2010 0.20 43.00 Conference with S. Stirling and correspondence with I. Reich re amended complaint

10/18/2010 0.70 150.50 Conference with I. Reich re sale of Colorado Mines (.5); reviewed correspondence from I. Reich re same (.2)

10/20/2010 0.50 107.50 Correspondence with S. Stirling re B. Frank and complaint

11/5/2010 0.10 21.50 Reviewed correspondence from Jamestown Development Co., Inc. re sale of mines and complaint

11/15/2010 0.30 64.50 Correspondence with Deputy Stanton re theft at Glory Hole Mine

11/15/2010 0.40 86.00 Correspondence and conference with I. Reich and S. Stirling re Geralynn Grieve

11/29/2010 0.60 129.00 T/C with A. Katz (USDOJ) and A. Madigan (EPA) re the Colorado Mining Properties (.4); correspondence with S. Stirling re titling of mining properties (.2)

1/13/2011 0.20 43.00 Reviewed offers on Black Rose Mine from F. Santos



1/27/2011 0.80 172.00 Conference with I. Reich, M. Dunn, F. Santos, and J. Welt re sale of Colorado mines, and adversary proceedings

1/31/2011 0.60 129.00 Conference with R. Schatzman and I. Reich re adversary proceedings and sale of mines

2/2/2011 0.40 86.00 Reviewed correspondence with F. Santos and I. Reich re: sale (.2); correspondence with M. Dunn re Letter of Intent with contingency (.2)

2/3/2011 0.20 43.00 Correspondence with F. Santos re sale of mines

2/7/2011 1.20 258.00 Conference with J. Sakalo re discovery day mine (.3); conference with M. Dunn re same (.3); conference with A. Madigan re EPA and limited liability of purchasers (.4); conference with F. Santos re sale of mine (.2)

2/10/2011 0.90 193.50 Correspondence with M. Dunn re disposition of mines and SEC conference (.7); conference re same (.2)

2/14/2011 0.10 21.50 Correspondence with F. Santos re sale of mines

2/15/2011 0.50 107.50 Correspondence and conference with I. Reich and F. Santos re Colorado mines and Discovery Day mine

2/16/2011 0.10 21.50 Correspondence with J. Sakalo re Discovery Day mine

2/21/2011 1.70 365.50 Conference with I. Reich re Discovery Day mine (.1); conference with I. Reich and M. Morrison (and representatives from his client Wabuska) re offer to purchase trustee's interest in the Discovery Day mining properties (.6); reviewed filings involvin g P. Fagan and Trinity Alps (.3); conference with J. Sakalo re his client's offer to settle claims with the trustee (.5); correspondence with trustee and F. Santos re same (.2)

2/22/2011 1.90 408.50 Correspondence with J. Moffa, J. Welt, I. Reich, and M. Dunn re offer on Glory Hole (1); conference with I. Reich re same (.5); correspondence with J. Sakalo re offer on Discovery Day (.2); conference with I. Reich re same (.2)

2/22/2011 0.40 86.00 Reviewed purchase and sale agreement between Discovery Day LLC and Merendon and other documents evidencing the transaction (.3); correspondence with F. Santos re same (.1)

2/23/2011 0.50 107.50 Conference with M. Dunn, F. Santos, and I. Reich re offer from Caldwell group on Glory Hole and on offer from Fagen group on Discovery Day

2/23/2011 0.70 150.50 Conference with J. Sakalo re offer on Discovery Day (.4); correspondence with I. Reich re same (.2); correspondence with M. Dunn re results (.1)

2/24/2011 0.40 86.00 Correspondence with J. Sakalo re Discovery Day settlement (.2); correspondence with M. Dunn and I. Reich re same (.2)

3/1/2011 1.40 301.00 conference with I. Reich re Colorado mining properties (.3); conference with I. Reich and J. Moffa re offer by Fedrigon to be stalking horse bidder (1.1)

3/1/2011 0.50 107.50 Strategy re Colorado mining properties and offer by the Fedrigons



3/1/2011 0.10 21.50 Correspondence with I. Reich re continuance of hearing on sale motion and pretrials in order to secure stalking horse bid

3/2/2011 0.30 64.50 Reviewed and revised email correspondence re continuance of hearing on sale motion and pretrials (.2); conference with I. Reich re same (.1)

3/4/2011 0.30 64.50 Finalized motion and order for continuance of hearing on sale motion and pretrials

3/8/2011 0.20 43.00 Correspondence with J. Sakalo re Discovery Day stipulation

3/9/2011 0.10 21.50 Reviewed filed order granting motion to continue sale motion, and continuing pretrial conferences

3/15/2011 0.10 21.50 Correspondence with F. Santos re B. Kitzman as potential purchaser

3/16/2011 1.50 322.50 Prepared responsive discovery re Clearwater Mining

3/16/2011 1.80 387.00 Prepared for and attended conference with M. Dunn, F. Santos, I. Reich, and B. Mukamal re disposition of mining properties and status of case

3/17/2011 0.10 21.50 Reviewed email from F. Santos re mining publications

3/22/2011 0.30 64.50 Reviewed settlement agreement and correspondence with I. Reich and J. Sakalo re settlement agreement

3/24/2011 1.00 215.00 Conference with J. Sakalo re settlement of Discovery Day Mine (.3); conference with H. Murelo's office re letter of intent (.1); conference with I. Reich re both offers (.3); reviewed settlement agreement with P. Fagen and Trinity Alps (.3)

3/25/2011 0.80 172.00 Prepared letter to publications re interview of trustee and disposition of mines

4/5/2011 0.60 129.00 Reviewed and revised settlement agreement with the Discovery Day entities (.4); correspondence with I. Reich re same (.2)

4/6/2011 1.50 322.50 Conference with I. Reich and J. Sakalo re settlement agreement and reviewed same and strategy re same

4/7/2011 2.50 537.50 Finalized letters to mining publications (.3); prepared motion and order to compromise controversy (1.8); correspondence with M. Dunn re settlement (.1); final review of settlement (.3)

4/8/2011 0.30 64.50 Correspondence with S. Doyle and F. Santos re offer on Merendon Mining claims

4/8/2011 0.50 107.50 Reviewed Glory Hole mining claim documents

4/11/2011 0.20 43.00 Strategy re Glory Hole mining offers

4/11/2011 1.80 387.00 Conference and correspondence with S. Doyle re $495K offer and terms, and stalking horse benefits (.5); conference and correspondence with M. Dunn re same (.3); prepared purchase agreement for S. Doyle (1)

4/12/2011 0.30 64.50 Correspondence and conference with F. Santos re Letter of Intent from Allied Environmental



4/19/2011 0.20 43.00 Correspondence with S. Doyle re status update for sale of Glory Hole properties

4/19/2011 0.30 64.50 Correspondence from M. Dunn, F. Santos and I Reich re H. Murelo's interest in Discovery Day mine

4/19/2011 0.10 21.50 Correspondence with J. Sakalo re Discovery Day settlement

4/19/2011 0.50 107.50 Correspondence with prospective bidders re sale of Colorado mines

4/20/2011 0.70 150.50 Conference with Securities and Exchange Commission P. Atkinson re sale of mining properties and recovery for investors

4/20/2011 4.50 967.50 Prepared asset purchase agreement for sale of Glory Hole Properties to purchaser S. Doyle, and prepared sale procedures and notice procedures

4/20/2011 1.20 258.00 Conference with S. Doyle re sale of Glory Hole Mining Properties

4/21/2011 0.20 43.00 Correspondence with I. Reich and M. Dunn re Asset purchase agreement, sale procedures, and notice procedures for Glory Hole (.1); and settlement of Discovery Day (.1)

4/22/2011 0.20 43.00 Correspondence with F. Santos re sale of Discovery Day Mine

4/22/2011 1.30 279.50 Conference with M. Dunn and I. Reich re Asset purchase agreement, Sales Procedures, Notice Procedures, and bid procedures for Glory Hole Mining Properties

4/22/2011 0.20 43.00 Further prepared Asset purchase agreement for sale of Glory Hole Mining Properties

4/26/2011 1.80 387.00 Conference with I. Reich re sale contract, sale procedures, and notice procedures (.8); further prepared same (1)

4/26/2011 0.10 21.50 Correspondence with I. Reich, M. Dunn, and F. Santos re offer on Discovery Day from H. Muruelo

4/27/2011 0.70 150.50 Finalized Asset purchase agreement, Reviewed description of property, Conference with F. Santos re Glory Hole Mining Properties (.2); correspondence with L. Weltzer re Glory Hole Mining Properties sale and role as nontestifying expert (.3), correspon dence with S. Doyle re Asset purchase agreement, Notice Proc, Sale Proc (.2)

5/4/2011 0.80 172.00 Prepared email to G. Treadway re Glory Hole mine and Merendon mining Ponzi scheme

5/4/2011 1.80 387.00 Conf with L Weltzer, S. Doyle and F. Santos re sale of Glory Hole Mining Properties and title, and strategy and analysis re same

5/11/2011 1.60 344.00 Reviewed letter of intent with Manufasteners, Inc. (.1); prepared asset purchase agreement, sale procedures, and notice procedures for sale of Glory Hole to same (1.5)

5/12/2011 1.20 258.00 Conference and correspondence with D. Coff, attorney for potential buyer Manufasteners, Inc., re sale of Glory Hole Mining Properties (.5); conference with S. Doyle re sale of Glory Hole Mining Properties (.7)



5/13/2011 1.10 236.50 Further prepared Asset purchase agreement and Sale and Notice Procedures (.5); correspondence with S. Doyle re same (.1); analysis and strategy re same (.5)

5/13/2011 0.30 64.50 Conference with S. Doyle re sale of Glory Hole Mining Properties

5/13/2011 0.10 21.50 Correspondence with M. Dunn re inverview by G. Treadway

5/16/2011 0.20 43.00 Reviewed correspondence from G. Tredway re Mining Journal publication

5/16/2011 0.50 107.50 Correspondence with S. Doyle re status of entering into Asset purchase agreement for sale of Glory Hole Mining Properties (.2); correspondence with D. Koff re setting up conference with L. Weltzer to discuss Glory Hole Mining PRoperties (.2); confere nce with L. Weltzer re same (.1)

5/17/2011 0.20 43.00 Conference with L. Weltzer re Glory Hole title issues

5/17/2011 0.40 86.00 Conference with D. Koff re sale to Manufasteners

5/18/2011 0.50 107.50 Conference with L. Weltzer re title issues and title commitment

5/20/2011 0.10 21.50 Correspondence with S. Doyle re Asset purchase agreement, Sale Proc, and Notice Proc

5/26/2011 0.30 64.50 Reviewed redlined Asset purchase agreement changes

5/27/2011 0.90 193.50 Further prepared asset purchase agreement and correspondence re same to M. Dunn, F. Santos, and I. Reich (.8); correspondence with S. Doyle re Asset purchase agreement (.1)

5/31/2011 0.20 43.00 Correspondence with F. Santos and M. Dunn re asset purchase agreement

6/7/2011 1.30 279.50 Conference with S. Doyle re Asset purchase agreement and access to Glory Hole (.3); conference and correspondence with Gilpin County Sheriff Hartman re access to Glory Hole (.8); correspondence with J. Welt, I. Reich, and M. Dunn re Asset purchase ag reement (.2)

6/8/2011 3.30 709.50 Prepared motion to sell Glory Hole Miing Properties

6/10/2011 0.30 64.50 Conference with F. Santos re sale motion, auction, and proposal for budget

6/16/2011 0.20 43.00 Correspondence with N. Nicole and E. Bartling re responsive production for S. Doyle

6/20/2011 1.30 279.50 Correspondence with S. Doyle re compliance with Article IX of Merendon Asset purchase agreement (.5); prepared documents for submission to S. Doyle (.8)

6/27/2011 0.50 107.50 Conf with D. Murphy and I. Reich re sale of Glory Hole Mining Properties

6/28/2011 0.80 172.00 Correspondence with M. Dunn re current status of sale of Glory Hole Mining Properties

6/29/2011 0.50 107.50 Prepared letter to Boulder County Sheriff re trespassing

6/30/2011 0.70 150.50 Correspondence with Gilpin County Sheriff and with Boulder County Sheriff re access to mining properties



6/30/2011 0.30 64.50 Correspondence with S. Doyle re sale contract and access to Glory Hole mining properties

7/1/2011 0.20 43.00 Correspondence with S Doyle re security concerns at Glory Hole

7/11/2011 0.10 21.50 Correspondence from S. Doyle re Glory Hole mine security concerns

7/11/2011 0.60 129.00 Conference call with I. Reich, M. Dunn, and F. Santos re settlement offer from Caldwell Estate, and sale of Glory Hole mining properties

7/15/2011 1.00 215.00 Researched substantive consolidation nunc pro tunc and effect on creditor asserting lien that was recorded postpetition, including Bonham, Pearlman, American Way, and Auto-Train

7/15/2011 0.30 64.50 Correspondence with D. Murray re auction of Glory Hole and procedures (.2); correspondence with J. Moffa re offer on Glory Hole (.1)

7/15/2011 0.10 21.50 Correspondence with A. Hampson re pretrial stipulation

7/15/2011 0.30 64.50 Conference with S. Doyle re status of Glory Hole mine, security issues with respect to the tailings at the mine, and Asset purchase agreement

7/18/2011 0.20 43.00 Prepared amended Exhibit A for stalking horse contract and correspondence with M. Dunn re same

7/19/2011 0.20 43.00 Prepared amended Exhibit A to Asset purchase agreement with GDC, and correspondence with S. Doyle re same

7/20/2011 0.60 129.00 Conference with A. Katz and A. Madagan re sale hearing and DOJ and EPA concerns, and correspondence re same

7/20/2011 1.00 215.00 Prepared for sale hearing by reviewing sale motion and docket, and case law supporting same

7/21/2011 4.20 903.00 Prepared for hearing on sale motion and pretrial conferences

7/22/2011 0.50 107.50 Correspondence with J. Moffa re confidential settlement discussions

7/22/2011 0.30 64.50 Prepared orders denying sale motion, and continuing pretrial conferences

7/22/2011 0.60 129.00 Conference with S. Doyle re denial of sale motion, and correspondence re sale of Bueno and Black Rose mines

7/25/2011 1.00 215.00 Conference and correspondence with S Doyle re sale of Bueno and Black Rose mining properties (.5); correspondence with M Dunn re same (.3); strategy and analysis re same (.3)

7/26/2011 0.30 64.50 Conference with S. Doyle re sale of Boulder mines

7/27/2011 0.50 107.50 Conference and correspondence with S Doyle re sale of Bueno and Black Rose mining properties

7/27/2011 2.30 494.50 Prepared Asset purchase agreement and Sale and Notice Procedures for sale of Bueno and Blackrose Mines



7/28/2011 1.80 387.00 Further prepared Asset purchase agreement for sale of Bueno and Black Rose mining properties and correspondence with S. Doyle re same (.8); reviewed title work for Bueno and Black Rose mining properties (1)

7/29/2011 0.50 107.50 Corresopndence with Boulder County Sheriff re Bueno and Black Rose mining properties (.3); correspondenc with S. Doyle re same and Asset purchase agreement (.2)

8/2/2011 2.40 516.00 Strategy re sale of Bueno and Black Rose Mining properties (.5); prepared sale motion (2.5)

8/3/2011 0.80 172.00 Prepared motion to continue hearing on motion requesting judicial notice and pretrials

8/3/2011 0.20 43.00 Prepared amended Boulder County mines sale motion

8/3/2011 0.30 64.50 Correspondence with I Reich re N Frank's claim of ownership of equipment

8/4/2011 0.30 64.50 Further prepared settlement stipulation with Caldwell Entities (.2); correspondence with J Moffa re same (.1)

8/5/2011 0.90 193.50 Conference with P. Scott re settlement with Caldwell estate (.3); correspondence and conference with J. Moffa re same (.4); conference with M. Dunn re same (.2)

8/16/2011 0.60 129.00 Reviewed and revised stipulation for settlement with Caldwell Estate (.5) and correspondence with J Moffa and M Dunn re same (.1)

8/18/2011 1.20 258.00 Prepared motion for approval of settlement stipulation with the Caldwell Entities and order granting same

8/18/2011 0.40 86.00 Correspondence with J Moffa and M Dunn re settlement stipulation, and reviewed revisions to same

8/27/2011 0.20 43.00 Correspondence with S Doyle re Colorado reclamation and Bueno and Black Rose Mines

8/27/2011 0.20 43.00 Correspondence with J Moffa and I Reich re objection to settlement with Caldwell Estate

9/6/2011 0.50 112.50 Conference with I Reich and S Doyle re sale of Bueno and Black Rose mines

9/7/2011 0.20 45.00 Correspondence with P Garfinkle re objections to settlement and sale

9/8/2011 0.80 180.00 Conference with R Meacham re Worldwide Services final judgment (.3); reviewed asserted judgment and dates to determine avoidability, and strategy re proceeding with adversary proceeding (.5)

9/16/2011 0.80 180.00 Conference with S Doyle re sale of Bueno and Black Rose Mines, including liability exposure as superfund site, necessity of water treatment plant, and liens on properties, and amendment to Exhibit A

9/19/2011 0.10 22.50 Correspondence with F Santos re AZ mines

9/20/2011 0.30 67.50 Reviewed P Garfinkle's objection and prepared response to same



9/26/2011 2.50 562.50 Prepared for hearing on sale motion, including review of all file and all relevant documents, including title report, Asset purchase agreement, amendment to Asset purchase agreement, review of notice, and correspondence and conference with S Doyle an d I reich

9/28/2011 0.50 112.50 Reviewed notes from hearing on sale motion and Asset purchase agreement and sale motion in preparation of order granting sale motion

9/30/2011 6.20 1,395.00 Prepared order granting sale of Bueno and Black Rose Mining Properties, including sale procedures, sale hearing notice, and notice procedures, and strategy and analysis re same (5.7), including conference and correspondence with I Reich and P Scott ( .5)

10/3/2011 4.00 900.00 Further prepared order granting sale motion of Bueno and Black Rose mining properties

10/4/2011 0.40 90.00 Finalized order granting sale motion

10/5/2011 0.40 90.00 Reviwed order granting motion for sale and strategy re service

10/5/2011 0.30 67.50 Correspondence with A Katz re EPA's view regarding dismissal of adversary proceeding

10/7/2011 0.30 67.50 Reviewed and prepared motion to continue pretrial conference and motion for judicial notice

10/7/2011 0.30 67.50 Correspondence and conference with S Doyle re Glory Hole mining property

10/19/2011 0.10 22.50 Correspondence with J Moffa and M Dunn re settlement proceeds

10/20/2011 0.20 45.00 Reviewed inspection waiver and release of liability

10/27/2011 0.40 90.00 Conference with S Doyle re proceeds from Glory Hole settlement (.2); conference with L Weltzer re same (.2)

10/27/2011 0.30 67.50 Conference with S Doyle re sale of Bueno and Black Rose mines (.2); conference with L Weltzer re title commitment (.1)

10/27/2011 0.30 67.50 Correspondence with M Dunn re distribution of Glory Hole settlement proceeds

10/27/2011 0.70 157.50 Reviewed order granting sale of Bueno and Black Rose mines and prepared service of Order, including correspondence with J Serrano and F Santos

10/31/2011 0.20 45.00 Correspondence with F Santos re service to prospective purchasers of Boulder County mines of Order Granting motion to sell

10/31/2011 0.20 45.00 Correspondence with L Weltzer and corresp with S Doyle re payment pursuant to settlement agreement with Caldwell Estate of Glory Hole mining properties

11/2/2011 0.40 90.00 Conference and correspondence with F Santos and L Fisher re auction of Black Rose and Bueno mines, marketing plan, and service in Colorado newspapers

11/4/2011 0.40 90.00 Correspondence with S Doyle and M Dunn re expense reimbursement to GDC, including review of GDC expenses for Glory Hole



11/7/2011 0.20 45.00 Correspondence with M Dunn's office re payment of Glory Hole settlement funds

11/8/2011 0.30 67.50 Conference with D Larson re sale of Bueno and Black Rose Mining Properties

11/9/2011 0.30 67.50 Conf with L Weltzer re water rights in Colorado and in Glory Hole legal description

11/10/2011 1.10 247.50 Prepared auction notices for Boulder County newspapers and correspondence with F Santos re same

11/21/2011 0.20 45.00 Corresp with S Doyle re Sentinel as substantively consolidated entity

12/1/2011 0.30 67.50 Corresp and conf with F Santos re auction of bueno and black rose mining properties and service

12/6/2011 1.40 315.00 Reviewed service and C/S for sale order, sale procedures, and auction notice (1); corresp and conf with F Santos and M Navarro re service to prospective purchasers and by publication (.3)

12/7/2011 0.30 67.50 Further prepared certificate of service re Order granting Sale of Boulder County mines

12/7/2011 0.50 112.50 Strategy re service of order granting sale motion and approving k and sale procedures

12/12/2011 0.50 112.50 Reviewed title commitment for Bueno and Black Rose Mining Properties and documents in support of same

12/14/2011 1.00 225.00 Corresp and conf with F Santos re sale and auction of Bueno and Black Rose mines, and strategy and analysis re same

12/14/2011 0.40 90.00 Conference with S Doyle re sale of Bueno and Black Rose Mines

12/16/2011 0.30 67.50 Corresp with F Santos re title commitment, including review of same

12/20/2011 0.10 22.50 Conf with F Santos re sale of Bueno and Black Rose mines

12/20/2011 0.30 67.50 Reviewed documentation from S Doyle re Bueno and Black Rose Mining Properties in preparation for auction

12/27/2011 0.50 112.50 Conf with F Santos, L Fisher, and J Welt re sale procedures and amended procedures to extend deadline to accept deposits for sale of Bueno and Black Rose Mines, and potential bidders (.3); corresp with S Doyle re: extending deadline for deposit (.1); correspondence with M. Dunn re same (.1)

12/28/2011 0.20 45.00 Conference wtih F Santos re sale procedures for sale of Bueno and Black Rose mines

12/29/2011 0.30 67.50 Corresp and conf with F Santos re asset purchase agreement for Bueno and Black Rose Mining Properties

1/3/2012 2.00 450.00 Correspondence with Auctioneer re Asset purchase agreement with D Badner (5) and preparation for Auction and Sale Hearing, including review of record, notice of Auction, and marketing activities (1.5)

1/3/2012 0.50 112.50 Conferences and correspondence with S Doyle re Auction of Bueno and Black Rose Mining Properties



1/4/2012 3.80 855.00 Prepared order approving sale of Bueno and Black Rose Mining Properties to Successful Bidder

1/5/2012 4.00 900.00 Further prepared order approving sale of Bueno and Black Rose Mining Properties

1/6/2012 0.30 67.50 Corresp with Bueno and Black Rose Mining Properties' Buyer's attorneys T Li and B Grossman re closing

1/6/2012 0.30 67.50 Corresp with J Bahnsen and I Reich re closing of sale of Bueno and Black Rose Mining Properties

1/9/2012 0.80 180.00 Corresp and conf with T Li re sale of Bueno and Black Rose Mining Properties

1/9/2012 0.50 112.50 Further prepared order approving sale

1/11/2012 2.40 540.00 Conf with Badner's counsel re order granting sale of Bueno and Black Rose Mining Properties (.5); further prepared same (1.2); corresp with T Li re same (.2); reviewed revisions to sale order (.5)

1/12/2012 0.80 180.00 Further prepared sale order (.3); conf with I Reich re same (.5)

1/13/2012 0.20 45.00 Corresp with T Li re order granting sale of Bueno and Black Rose mining properties

1/17/2012 0.10 22.50 Corresp with T Li re order approving sale of Bueno and Black Rose Mining Properties

1/18/2012 0.10 22.50 Corresp with T Li and S Williams re Order approving sale of Bueno and Black Rose Mines

1/18/2012 0.20 45.00 Corresp with R Meacham re Order approving sale of Bueno and Black Rose Mines and asserted lien on same

1/19/2012 0.10 22.50 Correp with I Reich re Discovery Day settlement obligations

1/19/2012 0.20 45.00 Coresp with R Meacham re order granting sale of bueno and black rose mining properties

1/19/2012 0.30 67.50 Corresp with J Bahnsen re closing, including legal description and title report

1/19/2012 0.10 22.50 Strategy re Dolen Springs AZ mines

1/20/2012 0.50 112.50 Correspondence and conferences with J Bahnsen and with buyer's counsel re closing of sale

1/23/2012 0.20 45.00 Corresp with T Li, J Bahnsen and I Reich re recording of sale order

1/23/2012 0.20 45.00 Strategy re estate's interest in Dolen Spring mines and title report

1/24/2012 0.50 112.50 Corresp with T Li re closing issues for sale of Bueno and Black Rose mining properties

1/24/2012 0.50 112.50 Reviewed and further prepared trustee's deed and bill of sale (.3); corresp with T Li re closing (.2)

1/25/2012 1.90 427.50 Strategy re title insurance report and exceptions, and closing on Sale of Bueno and Black Rose Minnig Properties (.8); conference with T Li re same and sale as is where is with no representations or warranties (.5); corresp with I Reich and J Bahnsen re same and closing (.3); conf with J Bahnsen re all (.3)



1/26/2012 0.10 22.50 Reviewed receipt of wire for $540,000

1/31/2012 0.30 67.50 Reviewed statement of lost stock certificate (.2); corresp with M Dunn re same (.1)

2/6/2012 0.10 22.50 Corresp with S Doyle re expense reimbursement for sale of mines.

2/10/2012 0.10 22.50 Corresp with F Santos re South American Mines

2/17/2012 0.20 45.00 Conf with P Scott re settlement with Worldwide Rental

2/17/2012 0.10 22.50 Corresp with S Doyle and M Dunn re expense reimbursement and deposit with respect to Bueno and Black Rose Mines

2/20/2012 0.10 22.50 Corresp with I Reich and M Dunn re settlement of Worldwide Machinery's claim

2/26/2012 0.80 180.00 Prepared settlement stipulation with Worldwide Rental

2/27/2012 0.60 135.00 Corresp with T Li re mining claims for Bueno and Black Rose Mining Properties (.2) and South American mining properties (.2); correp with F Santos re South American holdings (.1)

2/27/2012 0.20 45.00 Conf and corresp with M Dunn re return of deposit and legal authority for return of deposit

2/28/2012 0.10 22.50 Corresp and conf with A Castro re return of deposit to S Doyle and corresp with S Doyle re same

2/28/2012 0.40 90.00 Review of settlement changes and revisions to settlement (.2), and corresp with R Meacham re same (.2)

3/6/2012 0.30 67.50 Corresp with B Grossman re Badner's claim re Glory Development Company and violation of automatic stay

3/7/2012 0.10 22.50 Corresp with R Meacham re settlement on amount of lien on proceeds from sale on Bueno and Black Rose Mining Properties

3/12/2012 1.00 225.00 Conference with S Williams and H Berman re violation of automtic stay by stalking horse bidder (.5) conf with S Doyle re same (.5)

3/14/2012 0.20 45.00 Reviewed redlined settlement agreement with Worldwide Rental and corresp with M Dunn re same (.1); corresp with opposing counsel re same (.1)

3/15/2012 0.10 22.50 Correp with M Dunn re settlement agreement with Worldwide Rental

3/15/2012 0.70 157.50 Conference with Dr. Moses Onchiu re sale of South American mines and Discovery Day mines (.3); conference with J Sakalo re same (.2); conference with I Reich re same (.2)

3/16/2012 0.20 45.00 Correspondence with M Dunn re settlement stipulation with Worldwide Rental (.1); correspondence with D Hramatulova re same (.1)

3/16/2012 0.10 22.50 Corresp with Boulder County mining property buyer's attorney re surrounding claims

3/27/2012 0.10 22.50 Corresp with R Meacham re settlement agreement



3/30/2012 0.60 135.00 Prepared motion to approve settlement agreement (.3), including review of same (.3)



12/15/2009 0.30 57.00 Drafted affidavit of M. Dunn

1/25/2010 4.30 817.00 Attended continued hearing on motion for substantive consolidation (1.7); conference with I. Reich and M. Dunn re: hearing (.3); conference with I. Reich re: tasks (.5) researched reports and prepared notices (1.8)

2/1/2010 8.80 1,672.00 Researched international service of process (4.5); prepared motion on service through the Hague Convention, Inter-American Convention and other means (2.8); prepared motion for summary judgment (1.5)

2/2/2010 10.50 1,995.00 Researched and prepared memorandum on service (2); Further prepared motion for summary judgment (3); Researched and prepared Motion to Serve Foreign Defendants by Mail (5.5)

2/3/2010 8.40 1,596.00 Further prepared Motion to Serve Foreign Defendants by Mail (4.3) and Motion for Partial Summary Judgment (3.3); emailed foreign lawyers for questions re: service (.8)

2/4/2010 3.00 570.00 Correspondence with foreign counsel re: service (2.0); further prepared motion to serve foreign defendants via mail (1)

2/7/2010 2.00 380.00 Prepared summary judgment

2/8/2010 6.50 1,235.00 Researched and prepared partial summary judgment on U.S. Merendon Mining Entities

2/9/2010 7.00 1,330.00 Further prepared summary judgment (5.0); further prepared service motion (2.0)

2/11/2010 6.80 1,292.00 Conference with I. Reich re: tasks (.2); researched status of Belize in Hague convention (.2); researched cases on foreign transferees of fraudulent transfers (.4); prepared for hearing on injunction (.8); attended injunction hearing (2.5); conferen ces in break out room re: asset dispositions and strategy (1.8); prepared order continuing hearing (.9)

2/16/2010 6.10 1,159.00 Researched cases on foreign service via first class mail (1.1); prepared amendment to service motion (2.4); prepared response to motion to dismiss (2.6)

2/17/2010 4.20 798.00 Further prepared amendment to service motion (1.1); Further prepared response to motion to dismiss (1.1); reviewed and took notes on Sorenson Deposition (1.9); prepared chart of cash flows (2.1)

2/18/2010 9.00 1,710.00 Researched and reviewed cases, the Sorenson deposition and affidavits in preparation for continued hearing on temporary restraining order and hearing on service motion (7); conference with I. Reich re: same (1.5); prepared order on service motion (. 5)



2/19/2010 8.00 1,520.00 Prepared for hearing by reviewing motions and cases (2); attended hearing on temporary restraining order and motion to serve via alternate means and participated in conferences with parties (4); prepared orders on service and setting hearing on summa ry judgment motion (2)

2/23/2010 0.50 95.00 Conference with I. Reich re: tasks and strategy

3/4/2010 1.50 285.00 Researched Eiger Capital for summons, including documents produced and correspondence with Belizean websites

3/11/2010 4.20 798.00 Prepared for and attended motion for partial summary judgment

3/16/2010 1.20 228.00 Motion for continuance and order (.6); research and correspondence with Defendants (.6)

3/16/2010 1.10 209.00 Researched and reviewed file for letter to Canadian judge (1.0); conference with I. Reich re: letter (.1)

3/18/2010 0.80 152.00 Attended hearing on motion for clarification in preparation for Canadan hearing (.5); conference with I. Reich re: same (.3)

3/22/2010 0.30 57.00 Conference with I. Reich re: tasks

3/25/2010 0.30 57.00 Further prepared initial disclosures

7/1/2010 4.00 760.00 Prepared for and attended hearing on Motion to compel certain defendants to comply with previous order and hearing on motion for violation of automatic stay

7/6/2010 1.00 190.00 Prepared application, order, and affidavit on trustee's employment of auctioneer

7/7/2010 0.20 38.00 Conference with I. Reich re: application of auctioneer and Discovery Day mine

11/16/2010 0.50 107.50 Prepared motion for continuance of several hearings

11/22/2010 0.30 64.50 Conference with creditor Godwin re status of case (.2); correspondence re website (.1)

1/10/2011 0.10 21.50 Receipt and Review of Notice of Substitution of Counsel and Request for Service of Notice and Papers

2/2/2011 0.30 64.50 Correspondence with creditor K. Fletcher re non-debtor entity Fidelity

2/9/2011 1.20 258.00 Prepared for and conference with L. Hughes and P. Atkinson from the SEC re claims, permanent injunction, consent judgment, restitution

2/10/2011 0.20 43.00 Reviewed service on Merendon foreign entities

3/10/2011 0.80 172.00 Conference with I. Reich and P. Atkinson and L. Hughes of the SEC re status of case and the SEC foregoing forefeiture to allow trustee to administer assets for the victim creditors (.6); correspondence with M. Dunn re same (.2)

4/13/2011 0.10 21.50 Corrrespondence with M. Hannan re continuance of pretrial

4/19/2011 0.20 43.00 Reviewed motion for continuance of pretrial conferences and hearing on sale motion



6/20/2011 0.20 43.00 Correspondence with D. Kinsman re status of case and upcoming auction

7/21/2011 3.80 817.00 Attended hearing on sale motion and pretrials, including conferences with trustee's team and with defendants Caldwell Estate and Clearwater

9/27/2011 6.50 1,462.50 Prepared for (4.5) and attended hearing on sale motion and settlement motion (2)

10/4/2011 0.30 67.50 Prepared spreadsheet to update website

11/14/2011 0.10 22.50 Conference with paralegal re posting documents on merendon website

11/17/2011 0.30 67.50 Further prepared GR hosted Merendon website

12/28/2011 0.20 45.00 Correspondence with creditor re status of case

1/3/2012 0.20 45.00 Correspondence and conference with courtroom deputy re Auction

1/4/2012 4.00 900.00 Prepared for and attended Auction of Bueno and Black Rose Mining Properties and Hearing to Approve Sale to Successful Bidder

1/5/2012 0.80 180.00 Updated website including narrative and interface and user ability to access links

1/13/2012 0.30 67.50 Prepared report of summary of case for M Dunn

1/13/2012 0.20 45.00 Strategy re updates to website

1/30/2012 0.20 45.00 Conf with T Li re transfer of stock certificates



1/5/2011 0.20 43.00 Correspondence with B. Stang, creditor, re case status

1/6/2011 0.50 107.50 Correspondence with M. Dunn re Clearwater Mining Corporation's late filed claim (.2); conference and correspondence with M. Hannan re same (.3)

1/7/2011 0.20 43.00 Correspondence with M. Hannon re late-filed claim

1/26/2011 0.30 64.50 Correspondence with creditor re late filed claim

2/3/2011 0.30 64.50 Conference with creditor T. Andersen re proof of claim

2/10/2011 0.10 21.50 Correspondence re creditor J. Broderick

2/15/2011 0.20 43.00 Correspondence with T. Anderson re claim

2/22/2011 0.10 21.50 Correspondence with T. Andersen re claim

2/25/2011 0.20 43.00 Conference with creditor T. Anderson re claim

2/25/2011 0.30 64.50 Conference with creditor T. Anderson re case and her claim

3/8/2011 0.20 43.00 Prepared agreed order allowing the Latimers' late-filed claim



3/9/2011 0.10 21.50 Reviewed filed order granting S. Latimer's late filed claim

3/10/2011 0.50 107.50 Reviewed claims to determine number of investor creditors

3/10/2011 0.20 43.00 Correspondence with creditor S. Taylor re case

4/4/2011 0.20 43.00 Strategy re correspondence with creditors

8/28/2011 0.20 43.00 Correspondence with S Latimer re claim no 639 and order deeming it timely filed

1/26/2012 0.10 22.50 Corresp with T Andersen re proof of claim

2/6/2012 0.30 67.50 Conf with P Scott re Worldwide Rental's secured claim


Activity Code 007 Fee/Employment Applications

7/14/2010 0.90 171.00 Conference with Fisher Auction Co., J. Welt, I. Reich, and M. Dunn re: auctioneer application and letter of intent to purchase several mines (.5); further prepared application for auctioneer, order granting application for auctioneer, and affidavit of auctioneer (.4)

7/15/2010 0.20 38.00 Correspondence with auctioneer re: application, motion, and order (.2)



3/17/2010 3.50 665.00 Prepared letter to Canadian Judge re: motion for clarification, case synopsis, automatic stay and service

3/23/2010 1.00 190.00 Prepared Initial Disclosures

4/28/2010 1.00 190.00 Reviewed status of service for foreign defendants (.5); correspondence with I. Reich and S. Stirling re: strategy for good service (.5)

6/11/2010 8.80 1,672.00 Prepared Motion to Compel South American Entities to respond to Interrogatories (3.5); further prepared Motion for Contempt and Sanctions for violation of the stay (4.6); reviewed memo re: status of case (.2); exchanged correspondence with I. Reich re: motions (.5)

6/29/2010 1.90 361.00 Prepared motion to continue pretrial (.7); prepared order granting motion for violation of stay (1); conference with P. Scott re: same (.3); drafted email to C. Hark and A. Neiwirth re: pretrial conference (.2)

6/30/2010 1.40 266.00 Prepared Motion and Order Continuing Pretrial and Modifying Order Setting Filing and Disclosure Requirements (1.4)



6/30/2010 6.60 1,254.00 Further prepared Agreed Order Denying Motion for Sanctions and prepared alternative Order Denying Motion for Sanctions, conference with I. Reich re: same and strategy for hearing (3); conference with I. Reich and J. Sakalow re: same (.3); prepared order on motion to compel, conference with I. Reich re: same and strategy for hearing (3); conference with C. Hark and I. Reich re: same (.3)

7/9/2010 0.60 114.00 Reviewed service of process in Venezuela (.2); prepared service on foreign defendants (.3); conference with I. Reich re: same (.1)

8/9/2010 0.50 95.00 Prepared Request for Service Abroad of Judicial or Extrajudicial Documents to Serve Merendon Venezuela S.A.

8/27/2010 0.40 76.00 Prepared motion for continuance and order granting same

9/14/2010 0.50 107.50 Reviewed response to stay relief motion

9/30/2010 0.50 107.50 Further prepared Motion to Strike and conference with I. Reich re same (.5)

10/18/2010 0.50 107.50 Reviewed amended complaint for declaratory relief

10/19/2010 3.00 645.00 Finalized amended complaint (.5); conference with Bonnie Frank re documents sent to the trustee (.3); prepared motion and order continuing hearing on stay relief motion and sale motion (1); correspondence with I. Reich and S. Stirling re amended com plaint, continuance and case (1.2);

11/4/2010 0.40 86.00 Correspondence re amending complaint (.2) reviewed motion to withdraw as counsel by Sorenson (.2)

11/5/2010 0.10 21.50 Reviewed correspondence with J. Moffa re motion to extend time to file responsive pleading

11/19/2010 0.20 43.00 Prepared amended order granting extension.

11/29/2010 0.10 21.50 Reviewed correspodnence from D. Quick re counterclaim

11/30/2010 0.20 43.00 Reviewed docket and prepared notice of withdrawal

12/8/2010 0.30 64.50 Correspondence with I. Reich re counterclaim and motion to dismiss

12/30/2010 1.70 365.50 Reviewed Fedrigon counter-claim (.4); prepared motion to dismiss (1.3)

1/7/2011 0.30 64.50 Correspondence with J. Moffa re order granting motion to dismiss

1/10/2011 0.20 43.00 Correspondence with J. Moffa re motion to dismiss

1/11/2011 0.20 43.00 Reviewed Answer by Garfinkle (.2); conference with Garfinkle re mines (.1)

1/11/2011 0.50 107.50 Correspondence with J. Moffa re agreed order on motion to dismiss (.2); prepared agreed order (.3)

1/12/2011 0.10 21.50 Correspondence with P. Garfinkle re status and state court litigation



1/13/2011 0.10 21.50 Correspondence with D. Quick re motion to dismiss

1/14/2011 0.20 43.00 Strategy re initial disclosures

1/17/2011 0.30 64.50 Strategy re continuance of pretrial conferences and related deadlines

1/18/2011 0.10 21.50 Conference with M. Hannan, counsel for Clearwater Mining Company, re discovery and pretrial (.1)

1/18/2011 0.60 129.00 Conference with R. Meacham, counsel for defendant, Worldwide Rental Services, re discovery requests and pretrial (.3); correspondence with S. Stirling, F. Santos and R. Meacham re same (.3)

1/19/2011 1.50 322.50 Prepared motion for extension of hearing on sale motion and pretrial conferences in both adversaries (1.2); correspondence with S. Stirling re same (.3)

1/19/2011 0.60 129.00 reviewed correspondence with L. Weltzer re G. Greive's claims (.2); conference with R. Reed re G. Grieve's claims (.2); correspondence with R. Reed re same (.1); correspondence with S. Stirling re same (.1)

1/20/2011 0.40 86.00 Correspondence and conference with M. Hannan re defendant's claims

2/3/2011 0.50 107.50 Prepared service pursuant to the Hague Convention for Merendon Venezuela

2/3/2011 0.50 107.50 Conference with K. Fletcher re Fidelity

2/9/2011 0.10 21.50 Correspondence with S. Stirling re alias summons

2/10/2011 0.10 21.50 Reviewed correspondence with J. Falzone re alias summons

2/10/2011 0.20 43.00 Correspondence with A. Neiwirth re pretrial

2/14/2011 0.20 43.00 Reviewed service of foreign defendants

2/21/2011 0.30 64.50 Prepared final documents for service to Merendon Venezuela

2/23/2011 0.20 43.00 Correspondence with M. Hannan re Clearwater Mining Company re discovery

2/24/2011 0.20 43.00 Correspondence with M. Hannan re outstanding discovery

3/2/2011 0.40 86.00 Reviewed documents for responsive discovery to Clearwater Mining

3/2/2011 0.10 21.50 Correspondence with M. Hannan re Clearwater Mining and pretrial conference

3/10/2011 0.20 43.00 Strategy re discovery responses to Worldwide Machinery

3/11/2011 0.10 21.50 Reviewed correspondence between Worldwide Rental and our office re extension of time to file responses to discovery

3/15/2011 2.20 473.00 Reviewed documents related to title search of property of the estate in Boulder County and Gilpin County (1.2); prepared interrogatories (1)

3/16/2011 0.20 43.00 Prepared Answer to Interrogatories



3/23/2011 0.30 64.50 Reviewed District Ct Order in SEC case dismissing in part and dening in part the complaint against M Warner

4/12/2011 2.20 473.00 Prepared response to discovery and responsive production for Worldwide Rental and correspondence with R. Meacham re same

4/13/2011 0.10 21.50 Corrrespondence with M. Hannan re discovery

4/15/2011 0.10 21.50 Correspondence with counsel for Wabuska re service

4/26/2011 0.30 64.50 Reviewed Order Granting Motion to Compel Defendants to Comply with Agreed Order Dated 2/26/2010 (.1), Agreed Order dated 2/26/2010 (.1), and Motion to Withdraw in preparation for hearing on Sorenson's Counsel's Motion to Withdraw (.1)

4/26/2011 0.20 43.00 Correspondence from C. Hark and B. Cargill re hearing on motion to withdraw as counsel (.1); reviewed notice of hearing on same (.1)

4/29/2011 0.20 43.00 Reviewed certificate of no response to motion for compromise of controversy with Trinity Alps and P. Fagen

5/2/2011 1.00 215.00 Conf with C. Hark and I. Reich re his client's violations of agreed order and about withdrawal (.3), and conf with I. Reich re same (.2); attended telephonic hearing on motion to withdraw as counsel for Sorenson and South American entities (.5)

5/23/2011 0.20 43.00 Strategy re documents provided by B. Mukamal

6/6/2011 0.50 107.50 Analysis and strategy re production for defendant Worldwide

6/7/2011 0.30 64.50 Reviewed production for action to determine validity, extent, and priority of liens on Colorado Mining Properties

6/9/2011 0.80 172.00 Conference with N. Nichole re debtor's documents and production of documents relating to Colorado Mining Properties (.5); strategy re personally identifiable information (.3)

6/13/2011 0.80 172.00 Prepared answer to request for admissions from W. Kemper and strategy and analysis re same

6/14/2011 1.00 215.00 Prepared production for Worldwide

6/16/2011 0.20 43.00 Correspondence with N. Nicole and E. Bartling re responsive production for Worldwide

7/12/2011 2.60 559.00 Conference and correspondence with E Alan Hampson re Kemper and Daggett's asserted lien on Sentinel's assets and pretrial stipulation (.5); prepared pretrial stipulation (.8); strategy and analysis re Kemper and Daggett's claims (1.3)

7/12/2011 0.40 86.00 Conference with R. Meacham re Worldwide Rental's claims against the Boulder county property, and upcoming pretrial conference

7/14/2011 0.60 129.00 Correspondence with E. A. Hampson re preiiral order and asserted lien, and review of facts and law, and strategy re same



7/18/2011 0.20 43.00 Reviewed proposed stipulation from A Hampson

7/20/2011 0.60 129.00 Prepared for pretrial conferences in both adversaries by reviewing status of adv procs and filings in both proceeding

7/28/2011 0.10 21.50 Strategy re service on defendants claiming an interest in Bueno and Black Rose mining properties

9/27/2011 0.30 67.50 Conference with R Meachem re Worldwide's asserted lien

10/21/2011 0.20 45.00 Reviewed email to UST re Garfinkle's complaint

11/2/2011 0.20 45.00 Conference with I Reich, J Serrano, and J Leibner re amended complaint to drop Glory Hole defendants

11/2/2011 0.20 45.00 Correspondence with J Leibner re research on validity of Worldwide Machinery's lien

11/9/2011 0.80 180.00 Reviewed disclaimer and deeds for Glory Hole settlement and conference with M Dunn re same

11/22/2011 0.20 45.00 Corresp with A Katz and A Griesel re trustee's receipt of payment on Glory Hole and dismissal of Glory Hole defendants

12/15/2011 3.00 675.00 Prepared Second Amended Complaint for Declaratory Judgment, notice of dropping Glory Hole Parties, and motion for leave to amend, including review of title work done by L Weltzer

12/16/2011 1.10 247.50 Further prepared notice of dropping parties, amended complaint for declaratory judgment, and motion for leave to amend complaint

12/19/2011 0.30 67.50 Prepared order granting motion for leave to file amended complaint

12/20/2011 0.20 45.00 Corresp with A Katz re stipulation of dismissal of EPA

12/21/2011 0.40 90.00 Prepared stipulation and order for dismissal of USA from declaratory action (.2); corresp with A Katz re same (.2)

12/29/2011 0.60 135.00 Prepared stipulation and order of dismissal re G Grieve (.3); correspondence with G Grieve re same (.3)

1/12/2012 0.30 67.50 Corresp with R Meacham re pretrial conference and obligations

1/13/2012 0.30 67.50 Reviewed Worldwide Rental's Expert Report disclosures

1/13/2012 0.40 90.00 Prepared initial diclsoures in Adv Proc 10-3623

1/13/2012 0.50 112.50 Strategy re substantive consolidation and avoidance of Worldwide Rental's lien on Bueno and Boulder County mining properties

1/16/2012 1.00 225.00 Conference with P Scott and J Leibner re validity and extent of Worldwide Machinery's lien

1/20/2012 0.10 22.50 Correspondence and conf with R Meacham re pretrial conference

1/20/2012 1.00 225.00 Prepared motions to continue pretrial conferences and orders granting same



1/20/2012 1.20 270.00 Research re lien holder's entitlement to postpetition fees and costs

1/25/2012 0.20 45.00 Strategy re declaratory judgment and defaults

1/30/2012 0.10 22.50 Conf with R Meacham's office re initial disclosures

2/3/2012 0.50 112.50 Conf with P Scott re validity of Worldwide's claim, including review of judgment, and strategy and analysis re same

2/7/2012 1.50 337.50 Researched case law re entitlement to attorney fees and interest (1); conf with P Scott re same and response to R Meacham re Worldwide Rental's judgment (.5)

2/17/2012 0.20 45.00 Prepared request for production to Worldwide Rental

2/27/2012 2.80 630.00 Prepared for and attended pretrial conferences in both adversary proceedings



6/8/2010 2.40 456.00 Researched articles on Discovery Day Mine trespass and claimed ownership of mine (.5); prepared motion for contempt and sanctions for violation of automatic stay (1.7); exchanged correspondence with P. Garfinkle re: Discovery Day Mine (.2)

6/28/2010 1.00 190.00 Conference with P. Garfinkle and I. Reich re: Discovery Day Mine title (.7); conference with L. Taylor re: same (.3)

1/10/2011 0.10 21.50 Receipt and Review of Plaintiffs' Notice and Advisement of Entry of Order Granting Relief from Stay (Caldwell)



5/13/2011 2.50 537.50 Conference with S. Doyle and Deputy Treasurer of Gilpin County re tax obligations of Sentinal Mining Corp (1.2); reviewed tax report (.6); conference and correspondence with S. Doyle re same (.7)

1/23/2012 0.20 45.00 Corresp with T Li re tax liens


$94,480.50460.20Total for Timekeeper Lessne, Michael D



Mancuso, Nathan G


8/27/2009 0.50 175.00 Meet with I. Reich regarding proposed substantive consolidation of non-debtor entities (.3), implications of same (.2)

9/17/2009 1.00 350.00 Review Garfinkle affidavit

9/18/2009 1.30 455.00 Meet with I. Reich regarding proposed consolidation of non-debtor entities & mines, discuss legal theories (.5); review form of substantive consolidation motion (.4); forward to I. Reich with cover e-mail (.1); follow-up research regarding substantiv e consolidation of non-debtor entities (.3).

11/16/2009 0.50 175.00 Meet with I. Reich regarding substantive consolidation complaint.

1/13/2010 0.50 175.00 Meet with I. Reich regarding substantive consolidation of various entities (.3), follow-up strategy (.2)



3/11/2010 0.70 245.00 Meet with I. Reich regarding 363(h) sale issues of jointly-owned property; review form of 363(h) complaint & forward to I. Reich with comments regarding procedural issues.

6/11/2010 0.70 245.00 Call with I. Reich regarding asset sale issues, procedure; review multiple e-mails regarding same.

6/14/2010 0.30 105.00 E-mails with auctioneer regarding mine sale, financing issues.

6/15/2010 0.30 105.00 E-mails with auctioneer regarding sale & due diligence issues.

7/26/2010 0.30 105.00 Call with M. Lessne regarding proposed sale of Colorado mines, section 363(h) sale of co-owner's property interest.

7/29/2010 2.00 700.00 Meeting regarding sale of Colorado mines, substantive & procedural issues regarding same (1.0); review sale motion & 363(h) complaint (1.0).

7/30/2010 0.80 280.00 Meet with J. Liebner regarding section 363(f) sale of competing ownership interests (.4); review statute & supporting caselaw, e-mail memorandum regarding same (.2); draft reply e-mail. (.2)

8/5/2010 1.50 525.00 Multiple meetings, calls w/ M. Lessne regarding substantive & procedural issues on section 363 sale of Colorado mines (.5); review background documents regarding competing ownership interests 9 (1.0).

8/6/2010 1.20 420.00 Review sale motion & complaint 9.5); discuss with M. Lessne re: same (.7).

8/9/2010 0.50 175.00 Review amendment & accompanying letter to Colorado mining sale contract (.3); discuss with M. Lessne re same (.2)





6/12/2009 0.50 175.00 Meet with I. Reich, R. Schatzman regarding status of case, administration issues & to-do items (.3); review e-mail to petitioning creditors' counsel (.2).

8/7/2009 0.50 175.00 Review e-mail exchange regarding materials needed for schedules (.1); review extension order (.1); follow-up e-mails regarding same & need for further extension (.2); call to B. Elam regarding same (.1)

8/11/2009 0.30 105.00 Call, e-mails with L. Negron regarding schedules, extension of time, case status.

6/8/2010 0.30 105.00 Discuss stay violation remedies, civil contempt issues with M. Lessne.



1/14/2010 0.10 35.00 Call with L. Negron regarding section 501(c) filing of creditor's claim.



1/20/2010 1.30 455.00 Call with I Reich regarding foreign service of process (.3); review Rule 7004 regarding same & follow-up legal research (.6); call & e-mails with J. Kim regarding same (.4)

1/21/2010 0.70 245.00 Review J. Kim memo on international service of process (.3), follow-up e-mail regarding continued research on mail service issues (.1); e-mails with J. Kim regarding mail service (.3)

1/22/2010 0.80 280.00 E-mails & meeting with J. Kim regarding foreign service of process issues (.3); review memo of law regarding same (.3); calls, e-mails with I. Reich regarding same (.2).

3/16/2010 0.30 105.00 Discuss continuance procedure with M. Lessne (.2); review & forward motion/order for continuance of pretrial conference. (.1)


$5,915.0016.90Total for Timekeeper Mancuso, Nathan



Negron, Lisa


7/16/2009 0.50 80.00 Meeting with I. Reich regarding searches to be performed re: assets

7/21/2009 2.80 448.00 Perform various corporate and property searches



8/11/2009 0.80 128.00 Prepare Motion and Order extending time to file schedules

9/1/2009 0.30 48.00 Review emails regarding transfers and preparation of schedules

9/4/2009 4.00 640.00 Meeting regarding preparation of schedules

9/8/2009 3.00 480.00 Begin drafting schedules and reviewing backup information

9/9/2009 7.00 1,120.00 Continue preparing schedules

9/10/2009 5.50 880.00 Finalize schedules

9/11/2009 0.50 80.00 Review various emails from M. Dunn's office to coordinate obtaining signature pages for schedules and prepare responses to same

9/11/2009 3.00 480.00 Final revisions to schedules

9/16/2009 0.30 48.00 Review various emails regarding obtaining information from different sources and affidavits

10/14/2009 0.30 48.00 Prepare email correspondence to various creditors forwarding a copy of the 341 Meeting Notice and a Proof of Claim form

12/8/2009 0.50 80.00 File ecf emails into file site

1/7/2010 2.30 368.00 Pull case law for hearing on motion for substantive consolidation

1/8/2010 1.00 160.00 Work on items to be put on website

1/11/2010 4.00 640.00 Prepare for hearing on substantive consolidation

1/12/2010 2.00 320.00 Assist in preparing for hearing on motion for substantive consolidation

1/15/2010 0.50 80.00 Prepare email to court and forward proposed orders

2/11/2010 0.90 144.00 Telephone call with I. Reich regarding Suggestions of Bankruptcy (.30; revise Suggestions (.6)



6/11/2009 4.10 656.00 Drafting employment documents for General Counsel, Special Litigation Counsel and Financial Advisor



6/16/2009 1.20 192.00 Finalize applications to employ and file with the court

6/16/2009 0.50 80.00 Follow up on receiving applications for professionals to be filed with the Court

6/19/2009 0.40 64.00 Revise certificates of mailing regarding employment documents (.2); telephone call with B. Elam regarding revising affidavit (.2)

6/26/2009 0.20 32.00 File application, affidavit and proposed order to employ B. Elam with the Court



7/16/2009 1.00 160.00 Telephone call to U.S. Bank to obtain service information (.3); prepare subpoena and notice of 2004 to U.S. Bank (.7)

12/15/2009 2.00 320.00 File complaint and create parties in CM/ECF (1.0); finalize affidavit for deferring filing fee (1.0)

12/25/2009 6.00 960.00 Prepare Summons for defendants for service

12/28/2009 4.00 640.00 Preparing and finalizing summonses for defendants of adversary


$9,376.0058.60Total for Timekeeper Negron, Lisa



Nicole, Nancy H


6/9/2011 1.20 168.00 Drafted Motion to Continue Hearing on Motion for Sale and Pretrial Conference set for June 23, 2011

7/22/2011 1.00 140.00 Communications with I. Reich, Esq., and M. Lessne re: drafting Order on Motion to Approve Sale, and Orders Adversary Proceedings re: continuance (.3). Drafted Order on Motion to Approve Sale (.3). Drafted Orders continuing and resetting pretrial conference (.4)

8/3/2011 0.50 70.00 Draft Motion and Order to reset hearing on Motion to Approve Sale of Bueno and Black Rose mines.



7/12/2011 5.00 700.00 Began revision and update of filings and links to Bankruptcy and both Adversary Proceedings for upload to website.

7/13/2011 2.50 350.00 Completed revisions and update of filings and links to Bankruptcy and both Adversary Proceedings for upload to website.

11/16/2011 0.50 70.00 Reviewed email from M. Lessne re: excel spreadsheet for website download (.1). Reviewed Excel spreadsheet (.2). Conference with Patricia Tomlinson re: update of same (.2).

11/17/2011 4.30 602.00 Revised prior spreadsheet for website links to court documents, per court Order (1.5). Prepared updated spreadsheet for website links to court documents (2.8)



5/10/2011 0.10 14.00 Telephone conference with office of Barry Muhkamal, CPA (Jasmine), re: documents for production and Paul Garfinkel documents.

5/10/2011 0.20 28.00 Telephone conference with office of Barry Mukamal, CPA (Sharmilla), re: documents for production and Paul Garfinkel documents.

5/10/2011 0.10 14.00 Reviewed email from Linda Raymond, Esq. re: supplement production, non-electronic documents.

5/10/2011 0.20 28.00 Telephone conference with office of Barry Mukamal, CPA (Doris), re: documents for production and Paul Garfinkel documents.

5/10/2011 0.30 42.00 Prepared email to M. Lessne, Esq., re: supplement production, non-electronic documents.

5/10/2011 0.50 70.00 Reviewed file re: request for production, documents produce to date.

5/11/2011 0.20 28.00 Prepared emails to M. Lessne re: production of documents, B. Mukamal and Paul Garfinkle documents.



5/11/2011 0.30 42.00 Additional telephone conference with office of B. Mukamal, re: production of documents.

5/11/2011 0.20 28.00 Telephone conference with office of B. Mukamal, Trustee re: CD of documents in response to request for production.

5/11/2011 0.10 14.00 Reviewed email from M. Lessne re: production of documents.

5/12/2011 0.20 28.00 Reviewed initial Response to Request for Production.

5/17/2011 0.20 28.00 Reviewed email from Linda Raymond, Esq., re: production.

5/17/2011 0.40 56.00 Prepared memorandum Michael D. Lessne and J. Cartenega re: electronic and non-electronic production, supplemental response.

5/17/2011 0.20 28.00 Telephone conference with B. Mukamal's office re: production of documents.

5/18/2011 0.20 28.00 Reviewed email from office of B. Mukamal re: attaching documents for production.

5/18/2011 0.20 28.00 Telephone conference with B. Mukamal's office re: production of documents.

5/19/2011 0.40 56.00 Prepared memorandum to M. Lessne, re: supplemental production, 1,095 electronic data and files received from Marcum LLP for Trustee B. Mukamal for document production.

5/19/2011 1.70 238.00 Received and managed 1,095 electronic data and files received from Marcum LLP for Trustee B. Mukamal for document production.

5/19/2011 0.20 28.00 Received and reviewed email and document production link from Marcum LLP for Trustee B. Mukamal.

5/20/2011 0.40 56.00 Reviewed Excel spreadsheet of additional files and documents for possible production and documents produced by Trustee.

5/20/2011 0.40 56.00 Prepared email to Emma Bartling re: production of Trustee's documents.

5/20/2011 0.50 70.00 Revised Excel spreadsheet of additional files and documents for possible production.

5/20/2011 3.00 420.00 Management of documents from Trustee for production (over 100,000 pages).

5/23/2011 1.00 140.00 Began cursory review of categories of (100,000) documents from Marcum Accounting of Trustee's records and comparison to records previously produced to Worldwide.

5/23/2011 3.00 420.00 Began preparation of table of contents of (1,095 files) from Trustee for production.

5/23/2011 0.30 42.00 Prepared memorandum to M. Lessne, re: organization and production of documents from Marcum Accounting of Trustee's records.

5/24/2011 3.50 490.00 Continued reviewed, organization and preparation of table of content of folders and documents documents produced by Trustee in response to Worldwide Request for Production.



5/27/2011 1.00 140.00 Continued reviewing, indexing, and management of over 100,000 pages of electronic documents from Trustee in response to Worldwide request for production.

6/1/2011 0.50 70.00 Reviewed Adversary Complaint for Declaratory Judgment re: interests and properties, for purposes of identifying documents responsive to Worldwide's request for production.

6/1/2011 0.30 42.00 Telephone conference with Linda Raymon, Paralegal (Worldwide) re: production and supplemental production.

6/1/2011 0.20 28.00 Prepared email to Jessican Serrano re: contact with Robert Meacham re: Trustee's production of documents.

6/1/2011 0.20 28.00 Telephone call to I.T. Dept. re: status of completion of Table of Contents of files and documents produced by Trustee's accountant.

6/1/2011 0.20 28.00 Reviewed email from Linda Raymon, Paralegal (Worldwide) re: production and supplemental production, pretrial deadline.

6/1/2011 0.40 56.00 Prepared memorandum to M. Lessne, re: supplemental production, pretrial deadlines.

6/1/2011 0.30 42.00 Drafted email to to Linda Raymon, Paralegal (Worldwide) re: production and supplemental production, pretrial deadline.

6/2/2011 0.50 70.00 Office conference with M. Lessne, re: production to Worldwide (.3); telephone conference with Emma Bartling re: list of 1,095 downloaded files. (.2)

6/3/2011 1.70 238.00 Communications with J. Cartagena re: production to Clearwater and to Worldwide (.3); telephone conferences with Marcum Accounting (Lucy) re: location of original documents on CD and download Link for production to Worldwide (.3); prepared memorandu m re: orignal documents, list of files on CD, additional production to Worldwide (.2); reviewed documents produced to Clearwater and compared same to documents produced on CD by Trustee (.4); reviewed email from Marcum Accounting re: documents, produ ction (.1); reviewed file re: prior 383 page production, list of documents on CD and production of same (.2); communications with I.T. Dept. re: downloading of production from Trustee, transition to Summation (.2)

6/6/2011 6.50 910.00 Received and reviewed email from I.T. Dept. and attached list of files and documents on CD re: production to Worldwide (.2). Converted list of documents to searchable text (.6). Continued management of 1,095 electronic files of production from Tr ustee (2.3). Office conference with M. Lessne re: preliminary search of production for privileged communications on Trustee's CD (.3). Continued review and analysis of production (2.7) . Prepared memorandum re: documents on 2009 disk from Trustee and 2011 documents link from Trustee (.4)

6/7/2011 4.50 630.00 Continued management of 1,095 electronic files of production from Trustee (2.1); continued review of production from Trustee (2.4)

6/8/2011 7.50 1,050.00 Continued management and review of 1,095 electronic files of production



6/9/2011 3.80 532.00 Conference with I. Reich, and M. Lessne, re: initial review of 1,095 files from Trustee for production to Worldwide and due diligence documentation to Buyer, privilege and personal information (.5). Continued management and review of 1,095 electroni c files of production (3.3)

6/10/2011 1.20 168.00 Continued review and management of production from Trustee.

6/13/2011 6.50 910.00 Continued review and redaction of production by Trustee for production to Worldwide and for due diligence package to Buyer (5.4); prepared memorandum to I. Reich, Esq., re: status, time to complete and make production to Worldwide and due diligence package to Buyer (.4); received, reviewed and replied to communications from Linda Raymond, Paralegal, (Worldwide) re: status of production (.4); telephone conferences with Emma Bartling re: production (.3)

6/14/2011 7.00 980.00 Continued review and redaction of production by Trustee for production to Worldwide and for due diligence package to Buyer.

6/15/2011 7.00 980.00 Continued review and redaction of production by Trustee for production to Worldwide and for due diligence package to Buyer.

6/16/2011 7.00 980.00 Continued review of production by Trustee for production to Worldwide and for due diligence package to Buyer.

6/17/2011 4.50 630.00 Finalized reviewed, redaction, a nd organization of documents for electronic production to Worldwide and for due diligence package to Buyer.

6/20/2011 3.70 518.00 Additional review, redaction and finalization of documents production Worldwide and for due diligence package to Buyer (2.5); prepare CD of production (.2); prepared email to Robert Meacham, Esq., re: CD for production to Worldwide (.2); prepared em ail to Sean W. Doyle, Esq., re: due diligence package (.2); prepared letter to Sean W. Doyle, Esq., re: enclosing due diligence CD (.2).

7/14/2011 3.40 476.00 Reviewed communications from Kevin Coxwell (Chase) and M. Lessne re: Credit Bureau Authorization (.4); reviewed communication from E. Alan Hampson, Esq., re: Sentinel interest (.3); reviewed communications from Michael D. Lessne and A. Srour re: inte rest of Sentinel Mining, review of public records (.4); reviewed Adversary Dockets (.4); Reviewed list of Adversary Defendants and Counter and Cross Defendants (.5); reviewed status of responses of Defendants for Motion for Default (.7); finalized draft Motion for Default (.7)

7/19/2011 3.00 420.00 Began retrieving and reviewing documents in Clearwater Adversary Proceeding and file re: Defendants and status of Service of Process on Defendants for purposes of finalizing Motion for Entry of Defaults (1.2) Preparation of chart re: status of Defen dants, process, and response to Complaint (1.8)

7/20/2011 6.00 840.00 Continued retrieving and reviewing documents data in Clearwater Adversary Proceeding and file re: Defendants and status of Service of Process on Defendants for purposes of finalizing Motion for Entry of Defaults (2.4); preparation of chart re: statu s of Defendants, process, and response to Complaint (3.6)



7/21/2011 5.00 700.00 Completed retrieving and reviewing documents and data in Main and Adversary Proceeding and files re: Defendants, service of process, responses and answers to Amended Complaint (1.1); finalized preparation of chart re: status of Defendants, process, a nd response to Complaint (2.8) Prepared memorandum to M. Lessne, re: service of process and responses to Amended Adversary Complaint (.6); communications with M. Lessne, re: same, motion for defaults (.5)

7/25/2011 0.40 56.00 Telephone conference with Judicial Assistant re: status of entry of Orders (.2). Telephone conference with Judicial Scheduleer re: new Pretrial Conference date (.1). Prepared memorandum to M. Lessne, re: same (.1)

8/1/2011 0.50 70.00 Received and reviewed communication from I. Reich, Esq. re: review and comparison of proposed Quit Claim Deed from Bowerman Holdings (Discovery Day).

8/3/2011 0.50 70.00 Draft Motion and Order to reset hearing on Motion to Take Judicial Notice.


$16,282.00116.30Total for Timekeeper Nicole, Nancy H



Pearson, William (Bill) M


9/17/2009 1.20 600.00 Receive and review affidavit and other documents.



9/13/2009 3.20 1,600.00 Review documentation on various cases in preparation for meeting with Mr. Reich and FBI Special Agent on 9/14/09.

9/14/2009 2.40 1,200.00 Conference call with I. Reich and FBI Special Agent re: status of investigation, jurisdictional issues, etc; telephone conference with I. Reich (1.4); review additional documents (1.0).


$3,400.006.80Total for Timekeeper Pearson, William (



Reich, Ivan J


6/25/2009 0.10 40.00 Email from R. Schatzman to Garfinkle re: recovery committee and memo

6/30/2009 0.20 80.00 Email to and from L. Negron re: asset recovery memo

7/20/2009 0.40 160.00 Exchanging e-mails with B. Elam and J. Ryan regarding Leslie Taylor, Black Rose mine (.2); with Schatzman regarding information needed from Paul Garfinkle (.2)

7/28/2009 0.60 240.00 Telephone conference with Schatzman about and review of transcript of interview with Garfinkle

9/4/2009 4.10 1,845.00 Multiple emails from J. Ryan's office of interview of Les Taylor (.5); from S. Khanorkar regarding Brad Regier note asking for investor list and NV Secretary of State information (.4); teleconference with A. Brodsky regarding proof of subsidiaries (. 3); emails with L. Negron regarding Garfinkle statement (.4); emails to AntyIFFL regarding need for website information (.5); emails to Agent Matthew Galioto of the FBI (.5); emails to Scoggins of the SEC (.5); emails to Sgt.Scott Fuller (.2); teleco nference with Dave Smiley of the SEC all regarding contacts, schedules, officers and directors (.8)

9/4/2009 10.00 4,500.00 Conference with R. Schatzman, S. Khanorkar and L. Negron re: schedules and sofas (5.0); review documents and investigation and research into multiple investigations and calls with us and Canadian authorities on investigations and with runner of webm echnaic web site re: his private investigation (5.0)

9/7/2009 0.20 90.00 E-mails with B. Regier regarding documentation

9/8/2009 2.20 990.00 E-mails with A. Brodsky, L. Negron, et al. regarding letter to SEC requesting access to information (.5); with S. Khanorkar regarding schedules (.6); with Kelly Crowley, investor, and B. Elam (.5); with all regarding IFFL, Capital Alternatives, Strat egic Metals, Arbor Energy (.6)

9/9/2009 0.20 90.00 Exchanging e-mails with L. Negron regarding adding plaintiffs in LaPadula case in Colorado as investors and attach action as an exhibit to statement of financial affairs (.2)

9/11/2009 0.10 45.00 Email from S. Khanorkar re: bank statement analysis

9/14/2009 2.20 990.00 Telephone conference with Bill Pearson and FBI Agent Matt Galioto (.6); email from Bill Pearson and 6 from R. Schatzman re: same (.7), email from agent Galioto (.1); email to Bill x 2 and R. Schatzman x 5, and email to agent re: same (.8)

9/14/2009 0.10 45.00 Email to Garfinkle re: affidavit

9/15/2009 0.40 180.00 Exchanging e-mails with Paul Garfinkle (.2); transmit Garfinkle declaration to him and all others (.2)

9/15/2009 10.00 4,500.00 Draft affidavit of Garfinkle

9/16/2009 0.10 45.00 E-mail from S. Khanorkar transmitting list of structurists



9/16/2009 2.70 1,215.00 Exchanging multiple e-mails with S. Khanorkar regarding various matters, including affidavit and Merendon cash flows (.4); with Paul Garfinkle regarding his declaration and execution of same (.3); to investors and transmit schedules and statement of financial affairs to them (.3); to all parties transmitting IFFL chronology of events from 1999 - 2009 from Agency website (.3); with Pearson regarding Garfinkle declaration (.3); to all transmitting Agency's letter to Sorensen (.4); with Schatzman r egarding spreadsheet from Agency site (.3); with Scoggins regarding access request (.4)

9/17/2009 4.50 2,025.00 Meeting with Paul Garfinkle and Lynda Evensen regarding Paul's affidavit (2.5); receipt and review revisions to affidavit and make same (2.0)

9/18/2009 0.70 315.00 Multiple e-mails with Richard Lunger of US DOJ transmitting Statement of Financial Affairs and Schedules, access information for Intelligence website and website announcement (.2); receipt and review of notice of meeting of creditors to be held on 10 /16/09 and transmit same to all (.5); with Nicole Chute, Alberta Securities Commission and Jeff Simpson, RCMP (.3)

9/23/2009 0.60 270.00 Exchanging e-mails with Schatzman regarding FBI, RCMP, SEC, etc. open communication

9/30/2009 0.30 135.00 Telephone conference with creditor investor Sally Coupal

10/2/2009 0.50 225.00 Telephone conference with Ward Capstick

10/2/2009 0.80 360.00 Exchanging e-mails with all regarding The Agency

10/5/2009 0.90 405.00 Exchanging e-mails with all regarding The Agency and with Paul Garfinkle regarding Canadian corporate information

10/8/2009 0.80 360.00 Exchanging e-mails with B. Elam regarding conversation with Les Taylor and with Schatzman regarding The Agency

12/8/2009 0.30 135.00 Emails with P. Wagner regarding injunction motion

12/28/2009 0.50 225.00 Emails with L. Negron and A. Brodsky regarding Certificate of Service of hearing notices, motion, complaint (.3); emails with M. Dunn and B. Elam regarding Les Taylors email to B. Elam (.2)

12/29/2009 0.50 225.00 Notice of hearing on motion and discuss duplicate hearings with A. Brodsky to try to get all scheduled for 1/12/10 (.5)

12/30/2009 0.20 90.00 Receipt and review of Summons Service Executed [D.E. 13]

1/11/2010 2.30 1,035.00 Telephone conference with Larry Adair (.3); email from P. Wagner regarding draft order granting motion for substantive consolidation (.1); emails with B. Elam regarding articles and Ken Iredale's email (.4), call from Larry Adair, with L. Negron rega rding articles (.7); emails and teleconference with L. Negron and Cheryl Bennett re: transmitting all case documents for website (.8)

1/28/2010 0.70 315.00 Telephone conference with Albert Pelteir, counsel in Canadian class action law suit



1/28/2010 0.30 135.00 Telephone conference with Ward Capstick

2/2/2010 1.00 450.00 Telephone conference with Canadian receiver and his counsel

2/2/2010 0.30 135.00 Emails with B. Elam regarding buyers and orders (.3)

2/10/2010 1.10 495.00 Call from Mike Turner, potential mine buyer referred by M. Dunn (.5), and several emails with Mike Turner (.6)

2/11/2010 0.30 135.00 Emails with Mike Turner, mineral rights buyer

2/16/2010 1.00 450.00 Telephone conference with SEC lawyers and investigators

2/17/2010 0.30 135.00 Several emials with Mike Turner (mineral rights buyer)

2/18/2010 1.50 675.00 Conference with Paul Taylor, Nordics's counsel

2/24/2010 4.00 1,800.00 Conference with Chris Redmond and Greg Grossman, counsel for investors re: filing involuntary against Canadian companies in Canada

3/1/2010 0.30 135.00 Telephone conference with Chris Redmond

3/10/2010 0.30 135.00 Telephone conference with Martin Werner re: Peru sale offer

3/25/2010 2.50 1,125.00 Meeting with Werner and Garfinkle re: glory hole mine (2.0) and review documents re: same (.5)

4/19/2010 0.30 135.00 Exchanging e-mails with A. Brodsky regarding call from Paul Butler regarding Glory Hole

4/27/2010 0.30 135.00 Call from Joseph Davies regarding Glory Hole

5/13/2010 0.30 135.00 Exchanging e-mails with A. Brodsky regarding second call from Joe Davies regarding Clearwater Mine/Glory Hole - title issue

5/26/2010 0.60 270.00 Telephone conference with Martin Werner re: Ecuador mine (.3); emaiils with Werner regarding documents he sent (.3)

5/28/2010 0.30 135.00 Exchanging e-mails with M. Dunn and B. Elam regarding Black Rose

6/9/2010 0.10 45.00 Email from M. Dunn forwarding email from Jason Welt of Fisher Auction Auction regarding mines

6/11/2010 0.60 270.00 Telephone call with Fisher Auction - Lamar and Jason - call from Garfinkle saying he has a potential buyer

6/16/2010 0.30 135.00 Telephone conference with Martin Werner regarding mine in Ecuador

6/17/2010 0.30 135.00 Exchanging e-mails with M. Dunn, A. Brodsky and Jason Welt of Fisher Auction regarding meeting in person at GR's Miami office

6/21/2010 0.30 135.00 Telephone conference with Michael Morrison (counsel for Wabeska Mining) regarding competing claims over Discovery Day Mine in California

6/21/2010 0.40 180.00 emails with A. Brodsky and from Jason Welt and Lamar Fisher regarding call from Chris Pearce about prospective buyer of mines



6/21/2010 0.50 225.00 Telephone conference with Michael Morrison, counsel for Wabasca Mining who has a competing claim

6/24/2010 0.60 270.00 Exchanging e-mails with Jay Sakalo and M. Dunn (.2); call from Ward Capstick (.2); call from Chris Pearce regarding purchasing mines, and refer him to Fisher Auction (.2)

6/25/2010 1.20 540.00 Telephone conference with Garfinkle x 2 (.6); telephone with Capstick (.3); emails with Katie Carter, investor (.2); email to Jay Sakalo (.1)

6/28/2010 0.70 315.00 Emails with Garfinkle and F. Santos regarding ownership of Discovery Day and explosion investigation (.6); email to M. Dunn transmitting copy of Bahama Resource Assignment of Stock Interest (.1)

6/29/2010 3.00 1,350.00 Review, revise and negotiate draft language of order with respondent's counsel as well as reviewing documents re: ownership issues

6/30/2010 0.50 225.00 Email from Joseph Davies transmitting various ownership documents regarding Glory Hole

7/1/2010 0.50 225.00 Telephone conference with Jay Sakalo regarding Discovery Day

7/1/2010 1.20 540.00 Email with Joseph Davies regarding Glory Hole; email to M. Dunn, Garfinkle, Capstick, Werner regarding Davie's claims to Glory Hole and response from Garfinkle; telephone conference with M. Dunn and Fisher Auction, Jason Welt regarding Fisher's reten tion as auctioneer.

7/2/2010 0.90 405.00 Receiving and reviewing many documents from Jay Sakalo on Discovery Day Mine (.4); emails to A. Brodsky regarding same for files and for upcoming meeting with Sakalo (.2); email from Garfinkle regarding documents (.1); emails with Nicole Hilburn and Gus Pappas regarding purchase price, auctioneer, etc. (.2)

7/6/2010 3.10 1,395.00 prepare for and attend meeting with Jay Sakalo, Esq. regarding Discovery Day Mine (2.0); telephone call with F. Santos of Fisher Auction regarding Discovery Day Mine (1.1)

7/6/2010 0.30 135.00 Telephone conference with F. Santos of Fisher Auctions re: discovery day

7/8/2010 0.40 180.00 E-mail from A. Brodsky regarding call from Norman Frank in Colorado regarding equipment (.2); email from M. Dunn regarding Bueno Mine reclamation project (.2)

7/13/2010 1.60 720.00 Exchanging e-mails with Fisher Auction and M. Dunn regarding Letter of Intent (.4); telephone conference to discuss same (1.20)

7/14/2010 1.00 450.00 Conference call with auctioneers re: retention of auctioneer and letter of intent to buy Colorado mines including revising auction documents and response to letter of intent

7/22/2010 0.30 135.00 Telephone conference with Garfinkle

7/23/2010 1.80 810.00 emails with Jay Sakalo and M. Dunn regarding California mine and setting meeting (.3); with F. Santos at Fisher regarding Mark Levine's interest in some of the parcels and equipment in Colorado (.4); with J. Leibner regarding his memo report (.4); wi th S. Khanorkar regarding CA mine report (.7)



7/29/2010 0.30 135.00 Telephone conference with Mike Morrison re: discovery day

7/29/2010 3.00 1,350.00 Conference to dismiss the drafting of and issues concerning the 363 sale and motion and complaint regarding selling the 3 Colorado properties

8/5/2010 1.00 450.00 Review and revise report on discovery day mine dispute

8/27/2010 0.30 135.00 Telephone conference with Mike Morrison, counsel for party claiming interest in discovery day

8/31/2010 0.40 180.00 Telephone conference with Ward Capstick re purchaser of property

9/13/2010 0.60 270.00 Telephone conference with Dr. Michael Savic and Chris Pierce , the proposed purchasers

10/18/2010 0.50 225.00 E-mails between F. Santos, M. Lessne and Matthew Kramer

10/19/2010 0.50 225.00 Telephone with Bonnie Frank, Norman Frank's daughter, regarding assets they claim to own

10/20/2010 0.30 135.00 E-mails between M. Dunn and Jay Sakalo

10/20/2010 0.30 135.00 E-mails between Ashley Ochoa and F. Santos

10/22/2010 0.30 135.00 E-mails between Jay Sakalo and M. Dunn

10/26/2010 0.20 90.00 E-mails to and from F. Santos

10/28/2010 0.20 90.00 E-mails to and from G Goodard

10/28/2010 0.40 180.00 E-mails between F. Santos and Andrea Madigan

11/5/2010 0.30 135.00 Telephone conference with Cheryl Linden attorney with colorado division of mine reclamanation and safety through attorney general office of colorado

11/5/2010 0.30 135.00 Telephone conference with Cheryl Landen, Colorado Attorney general's office, Colorado Division of Reclemation Mining and Safety re prospecting notice and bond

11/5/2010 0.30 135.00 Telephone conference w/ Cheryl Linden, colorado attorney general's office, re prospecting notice and bond

11/29/2010 0.50 225.00 Conference call with EPA attorneys regarding mapping of mining claims

12/8/2010 0.50 225.00 Telephone conference with M. Lessne, M. Dunn, A. Brodsky from EPA and F. Santos of fisher auctions re selling colorado properties

12/28/2010 0.60 270.00 E-mails between Patrick Fagan and F. Santos

12/30/2010 0.30 135.00 Telephone with Michael Morrison re discovery day

1/3/2011 0.30 135.00 Telephone with brokers regarding asset sale

1/27/2011 0.70 315.00 Conference call with M. Lessne, M. Dunn, F. Santos and Jason Wells

2/8/2011 1.00 450.00 Conference with sakalo re discovery day

2/21/2011 0.60 270.00 Conference call with M. Lessne and Jay Sakalo regarding Discovery Day Mine



2/21/2011 0.60 270.00 Conference call with M. Lessne and Michael Morrison reagrding Discovery Day Mine

2/22/2011 0.10 45.00 E-mails between M. Lessne, F. Santos and Jason Welt

3/29/2011 0.50 225.00 Telephone conference with potential buyer Herrera

3/30/2011 0.50 225.00 Telephone conference with potential buyer and email to Giovanni Herrerra regarding glory hole

3/31/2011 0.30 135.00 Telephone conference with Sakalo re discovery day

4/26/2011 0.50 225.00 Phone call with Homer Meruelo re discovery day

5/2/2011 0.40 180.00 Telephone conference with Mike Davis of Robinson Waters counsel for a potential buyer of Colorado mines

5/4/2011 0.50 225.00 Telephone conference with buyer, auctioneer, title company and M. Lessne re sale.

5/10/2011 0.30 135.00 Telephone conference with Mike Davis re offer to purchase

6/7/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sean Doyle and Sheriff Hartman regarding access to the Glory Hole.

6/16/2011 0.20 90.00 Emails with Sean Doyle to A. Srour regarding earnest money deposit wire.

6/16/2011 0.30 135.00 Emails with Sean Doyle and M. Dunn regarding receipt of funds by wire.

6/20/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle regarding Compliance with Article IX.

6/20/2011 0.30 135.00 Emails with John Moffa regarding official offer to the Trustee.

6/20/2011 0.20 90.00 E-mails with Franis Santos regarding marketing plan.

6/21/2011 0.20 90.00 Emails with A. Srour and F. Santos regarding setting a conference call.

6/22/2011 0.20 90.00 Emails with M. Lessne regarding Gilpin County Spreadsheet.

6/27/2011 0.80 360.00 Telephone with David Murphy regarding investor looking to buy Glory Hole and resolve Caldwell claim

6/27/2011 0.30 135.00 E-mails with David Murray regarding potential offer that your prospective clients have to purchase the Glory Hole mine.

6/28/2011 0.30 135.00 Receipt and review of an email from F. Santos enclosing budget for Merendon.

6/29/2011 0.30 135.00 Emails with David Murray regarding materials.

6/29/2011 0.20 90.00 Emails with David Murray regarding conference call.

6/29/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to David Murray enclosing materials requested.

6/30/2011 1.30 585.00 Call with M. Lessne, D. Murray, G. Pappas, L. Fisher and F. Santos (.6); seperate call with auctioneers (.7)



6/30/2011 0.20 90.00 Receive, review and reply to email with Gus Pappas regarding Glory Hole.

7/1/2011 0.20 90.00 Receipt and review of emails between M. Lessne and Sean Doyle re: Mine trespassers.

7/12/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Mr. Dorn re: Website and Boulder County Mines.

7/13/2011 0.20 90.00 Receipt and review of an email from David Murray re: bid

7/15/2011 0.30 135.00 Emails with David Murray re: Bid.

7/15/2011 0.70 315.00 Telephone conference with D. Murray of potential buyer, email to and from him x 4

7/16/2011 0.20 90.00 aReceipt and review of an email from David Murray re: bid.

7/18/2011 0.20 90.00 E-mail to an from Martin Hannan re: offer.

7/19/2011 0.20 90.00 Receipt and review of an email from M. Lessne enclosing letter following up with the attorney for Worldwide Rental, which claims a lien on the Boulder mine.

7/19/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle.

7/22/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing deeds.

7/22/2011 0.20 90.00 Receipt and review of an email from Francis Santos.

7/25/2011 0.30 135.00 Reviewing and responding to e-mail from F. Santos .

7/25/2011 0.20 90.00 Reviewing and responding to e-mail from Jay M. Sakalo re: Deed.

7/26/2011 0.20 90.00 Receipt and review of Emails between M. Lessne and Marica Dunn re: Sean Doyla's bid on the Boulder County mines.

8/1/2011 0.30 135.00 Reviewing and responding to e-mail Jay Sakalo re: installment land sales contract.

8/1/2011 0.30 135.00 Receipt and review of an email from Jay M. Sakalo enclosing a Quiteclaim Deed - Bowerman to Merendon

8/2/2011 0.60 270.00 Telephone conference with Dr. Davis, a geologist who represents some parties interested in the mines (.3); telephone with ard capstick re same (.3)

8/9/2011 0.30 135.00 Receipt and review of an email from Jay Sakalo enclosing quitclaim deed to Bowerman.

8/23/2011 0.20 90.00 Receipt and review of an email from Patrick Fagen to Jay Sakalo re: executed deed.

8/23/2011 0.30 135.00 Telephone conference with potential buyer

9/9/2011 0.30 135.00 E-mails with Barry I. Grossman regarding Francis D. Santos, auctioneer.

9/19/2011 0.20 90.00 Receipt and review of emails between M. Lessne and F. Santos re AZ mines.

9/20/2011 0.30 135.00 Telephone conference with John Watters re potential purchase of mine



9/22/2011 0.20 90.00 Receiving and reviewing of email from Sean Doyle to Alicia with Boulder County regarding purchasing the real and personal property assets owned by Merendon Mining.

9/27/2011 0.40 180.00 Receipt and review of an email from L. Weltzer enclosing report concerning the Glory Hole property in Gilpin County, Colorado.

9/28/2011 0.20 90.00 E-mais with Paul Garfinkle re ownership of Sentinel Mining Corp.

10/4/2011 0.10 45.00 Receipt and review of an email from A. Srour regarding phone call from Jones Watters with Kitzman Trucking from Colorado.

10/4/2011 0.10 45.00 E-mail from M. Lessne to Terry with Left Hand Ditch Company regarding Merendon's shares.

10/5/2011 0.20 90.00 E-mails between M. Lessne and F. Santos regarding marketing plan.

10/7/2011 0.20 90.00 E-mails with M. Lessne re outstanding Expense in Glory Hole.

10/10/2011 0.20 90.00 Receiving and reviewing of an email from J. Leibner to M. Dunn and F. Santos enclosing the Preview Release Liability.

10/11/2011 0.20 90.00 E-mails with F. Santos re Inspection Waiver & Release of Liability.

10/19/2011 0.10 45.00 E-mail from F. Santos to J. Leibner enclosing redlined Inspection Waiver Release Form.

10/20/2011 0.10 45.00 E-mail from M. Dunn to F. Santos re Inspection Waiver & Release of Liability.

10/24/2011 0.10 45.00 E-mail from A. Srour re call from Bill Hamilton potential Mine buyer.

10/29/2011 0.10 45.00 E-mail from M. Lessne to Sean Doyle re Glory Hole's Expense Reimbursement.

11/3/2011 0.20 90.00 E-mail from F. Santos re proposed advertisement/ notice (Dunn v. Brost)

11/4/2011 0.20 90.00 E-mails with F. Santos re status of the Glory Hole commission check

11/4/2011 0.10 45.00 Receipt and review of an email from M. Lessne to Sean Doyle re Outstanding Expense in Glory Hole.

11/9/2011 0.20 90.00 Receipt and review of an email form M. Lessne to M. Dunn enclosing Disclaimer of Interest and Trustee Deed (Quartz Hill) and Trustee Deed (Superior Gold) for execution and notarization.

11/9/2011 0.30 135.00 E-mail from John Moffa enclosing Disclaimer of Interest, Trustee Deed (Quartz Hill) and Trustee Deed (Superior Gold) for review and execution.

11/10/2011 0.30 135.00 Receipt and review of of an email from M. Lessne to M. Dunn re Fisher Auction, Glory Hole with enclosed documents.

11/10/2011 0.20 90.00 E-mail from M. Lessne to John Moffa enclosing executed Disclaimer of Interest, Trustee Deed (Quartz Hill) and Trustee Deed (Superior Gold)



11/29/2011 0.30 135.00 E-mail from L. Weltzer enclosing title commitment for the property owned by Merendon Mining (Colorado), Inc. in Boulder County.

12/6/2011 0.10 45.00 Review emails between M. Lessne and F. Santos re Merendon - Ads published in Colorado.

12/12/2011 0.30 135.00 Emails from and to Sean Doyle enclosing information re potential bidders for Merendon.

12/14/2011 0.20 90.00 Emails with F. Santos and M. Lessne re Auction of Bueno and Black Rose Mining Properties.

1/3/2012 0.20 90.00 E-mails with F. Santos re Merendon Mining attorney for proposed buyers: Eff Schatzman and Brian Behar

1/3/2012 0.20 90.00 Emails with Jeffrey N. Schatzman re proposed buyers Jeff Schatzman and Brian Behar

1/3/2012 0.10 45.00 Emails with Brian Behar re bids on the mines

1/10/2012 0.20 90.00 Emails with M. Dunn re buyers

1/13/2012 0.20 90.00 Emails with M. Lessne, J. Leibner and Patrick Scott re mechanics liens

1/17/2012 0.30 135.00 Telephone conference with John Watters regarding theft of $30k from estate for taking rocks from Glory hole and not remitting money to estate.

1/24/2012 0.30 135.00 Telephone conference with buyers re sub con order

1/25/2012 2.00 900.00 Multiple calls and emails to and from buyers counsel, title company and our counsel regarding issues with Worldwide's lien and Jamestown's Royalty deed.

1/30/2012 0.20 90.00 Emails with F. Santos and M. Dunn re closing the deal.

2/1/2012 0.20 90.00 Email with M. Dunn re orders reflect payment to auctioneer

2/1/2012 0.20 90.00 Reviewing of emails between M. Dunn and Jeffrey Bahnsen re funds.

2/7/2012 0.10 45.00 Review emails between M. Lessne and Sean Doyle re Expense Reimbursement.

2/7/2012 0.20 90.00 Reviewing e-mail from M. Lessne to M. Dunn re Payment of Expense Reimbursement and Deposit without Further Order and Payment of Fisher's Commission

2/10/2012 0.20 90.00 Emails with M. Lessne and Fancis Santos re South American Mines.

2/15/2012 0.20 90.00 Email from and to Greg Painter re Trinity Payment to Merendon

2/15/2012 1.00 450.00 Multiple emails by and between Sakalo (.3), his clients (.3), M. Lessne and trustee (.1) and teleconference with Sakalo re early payoff (.3)

3/12/2012 1.30 585.00 Telephone conference with h counsel for buyers and Sean Doyle re Doyle claims during due diligence process.

3/15/2012 0.30 135.00 Telephone conference with Jay Sakalo regarding deed and early payoff on discovery day.



3/15/2012 0.60 270.00 Telephone conference with Moshe Onciu regarding discovery day and buying south american mines

3/16/2012 0.30 135.00 Telephone conference with Howard Berman (.3); email to and from Howard Berman re: Doyle (.1)



1/22/2010 1.10 495.00 E-mails with Riggs of Neiwirth's office, Nate Mancuso, S. Khanorkar, Ward Capstick, R. Schatzman, Paul Garfinkel (regarding settlement agreement) (.6); and attention to matters for same (.5)

1/23/2010 0.40 180.00 E-mails with Schatzman (x3), and with Garfinkle (x1) regarding settlement agreement

1/24/2010 0.60 270.00 E-mails with B. Elam and S. Khanorkar, and with Ken Iredale re: settlement

2/18/2010 1.00 450.00 Telephone conference with potential buyer Mike Turner (.3); telephone conference with potential buyer milt shlaypac (.3) ; telephone with potential buyer Noreen Griffin (.4)

2/18/2010 0.30 135.00 Conference with L. Negron and A. Brodsky re: recording order in counties where mines are located and filing suggestions of bankruptcy

2/25/2010 0.30 135.00 Telephone conference with John Skaggs re: glory hole mining litigation

3/9/2010 2.00 900.00 Conference with Werner and potential buyer

6/8/2010 0.50 225.00 Emails with Gus Pappas regarding Glory Hole

6/11/2010 0.50 225.00 Telephone conference with Jason Welt and Lamar Fisher

6/14/2010 0.10 45.00 Receipt and review of notice of hearing on motion for violation of the automatic stay and sanctions, etc.

6/22/2010 1.70 765.00 Meeting in office with Jason Welt, Lamar Fisher and F. Santos of Fisher Auction and M. Dunn; telephone call with Paul Garfinkle

6/24/2010 0.60 270.00 Telephone conference with Ward Capstick and Chris Pierce, buyer and sale of assets


6/25/2010 0.60 270.00 Multiple emails with Jay Sakalo, M. Dunn and M. Lessne regarding Trident settlement discussions

7/3/2010 0.80 360.00 Exchanging e-mails with Gus Pappas; review A. Brodsky's email to opposing counsel and team regarding 9/20/10 pretrial date

7/7/2010 0.90 405.00 Exchanging e-mails with M. Lessne regarding auction motion; review motion, affidavit of auctioneer, and proposed order granting same; emails with Gus Pappas; emails with Richard Brodsky, Nordic's counsel

7/12/2010 0.30 135.00 Emails with J. Leibner regarding research on sales contract recordation and various other matters



7/14/2010 0.90 405.00 E-mail from F. Santos regarding offer from Winderman (.1); emails with Greg Levine regarding his mother, Barbra Lurie's Proof of claim and case status of same (.8).

7/16/2010 2.20 990.00 Exchanging e-mails with Fisher Auction, A. Brodsky, M. Lessne regarding bonds, affidavit, etc.(1.0); file application to employ (.5); transmit filed application to team (.2); post to website (.2); emails with L. Hughes regarding permanent injunction (.3)

7/19/2010 1.00 450.00 Exchanging e-mails with Lamar at Fisher Auction and M. Lessne regarding Letter of Intent for Colorado (0.3); Telephone conference with J. Leibner regarding memorandum report and with H. Winderman and A. Brodsky regarding Letter of Intent (.7)

7/20/2010 0.70 315.00 Receiving and reviewing NEF of Order Granting Application to Employ Fisher Auction Co., as Auctioneer (.1); forward to team, including J. Armengol and Fisher Auction (.1); post to website (.1); file certificate of service (.2); emails with Jay Sakalo regarding documents he sent (.2)

7/25/2010 0.10 45.00 Reviewing e-mail from S. Khanorkar to Gus Pappas re: mines

7/26/2010 0.60 270.00 Exchanging e-mails with Gus Pappas regarding auction and email to Garfinkle (.3); emails with Jason Welt re: same (.3)

7/27/2010 0.20 90.00 Exchanging e-mails with M. Lessne and S. Stirling regarding CO property title search

7/28/2010 1.30 585.00 Exchanging e-mails with M. Lessne and S. Stirling regarding CO property title search and legal description to Stephen Perin (.4); email from Maureen and Michael Bondor (creditors) transmitting correspondence from Great While Nevada (.1); email from K atie Carter (creditor) regarding case status (.1); receipt and review of revised memo report from J. Leibner (.5); email with J. Ryan regarding mucker offer (.2)

7/28/2010 4.00 1,800.00 Review case law and memo in preparation for meeting with Discovery Day and Trinity's counsel (2.1), attendance at meeting with M. Dunn, M. Lessne and J. Leibner to discuss pending issues and settlement (1.9)

7/29/2010 2.60 1,170.00 Exchanging e-mails with Jay Sakalo regarding Webeska Mining; with S. Stirling regarding title; receipt and review of Trustee's Interim Report for Period Ending 6/30/10; email response to creditor, Katie Carter; emails with Stephen Perin, S. Stirling, Fisher, M. Dunn, M. Lessne regarding mucker, title search, auction

7/30/2010 1.00 450.00 Exchanging e-mails with N. Mancuso, S. Stirling, J. Leibner, M. Lessne regarding CO mine sale, title

8/2/2010 1.50 675.00 Exchanging e-mails with S. Stirling and M. Lessne re Letter of Intent for purchase of three properties (.4); motion for approval of sale of mucker equipment (.4); title issues (.2); emails with F. Santos regarding Capstick and Garfinkle's interest in Glory Hole and email to Capstick (.3); emails with creditor Melanie Sears re case status (.2)

8/4/2010 0.20 90.00 Exchanging e-mails with Garfinkle regarding sale of Glory Hole property



8/5/2010 1.40 630.00 Exchanging e-mails with J. Leibner regarding tracing theory (.20; Telephone conference with S. Stirling and M. Lessne regarding title search for the three mines (in Gilpin and Boulder counties)(1.0); emails with Les Taylor regarding Black Rose, Bueno and Discovery Day (.2)

8/6/2010 1.60 720.00 Exchanging e-mails with F. Santos, S. Stirling and M. Dunn regarding Norman Frank's equipment at Bueno to be removed from auction list (.3); meeting with M. Lessne re sale motion and complaint (1.1); review emails between S. Stirling and Marcus Willi ams re title (.2)

8/8/2010 0.70 315.00 Reviewing e-mails from S. Stirling to Les Taylor re Mucker (.2); meeting with A. Brodsky re Nordic hearing (.5)

8/9/2010 0.50 225.00 Reviewing e-mails from M. Lessne and L. Weltzer regarding title (.20; meeting with M. Lessne re amended Letter of Intent (.2); review Mike's emails with H. Winderman regarding modified Letter of Intent dated 8/9/10 (.1)

8/11/2010 1.90 855.00 Reviewing e-mails between M. Lessne and Michael Morrison regarding Wabuska, and between M. Lessne and S. Stirling regarding Bueno equipment (.7); review email from S. Stirling regarding bid request (.1); multiple emails with H. Winderman regarding sa le motion (1.1)

8/12/2010 2.20 990.00 Exchanging e-mails with M. Lessne regarding his call and emails with Mark Levin (.3); meeting with L. Hughes re waiver status and consent to permanent injunction (.5); from Matt Kramer at Bilzin Sumberg transmitting draft agreed motion to vacate subc on and partial summary judgment (.2); meeting with A. Brodsky regarding communciation from creditor Orist Pashko (.3); review M. Lessne's email to H. Winderman re revising sale motion to add stalking horse protections (.2); review emails between Dr. Salit and M. Lessne regarding sale of Colorado mining properties and with M. Lessne re same (.3);meeting with S. Stirling regarding draft complaint (.2); receipt and review of Order Granting Agreed Motion to Permit Expenditure of Funds by Nordic for Legal Representation (.2)

8/13/2010 0.30 135.00 Telephone conference with buyers representatives

8/13/2010 1.80 810.00 Exchanging e-mails with F. Santos and M. Lessne re Sale (.3); review emails between S. Stirling, M. Lessne and L. Weltzer re: same (.4); review equipment photos and AZ legal description and ownership information with Mike and S. Stirling as well as d iscuss Mucker, auction, emails from Lawrence Hittle and motion (1.1)

8/15/2010 0.30 135.00 Exchanging e-mails with L. Weltzer and M. Lessne regarding title search

8/16/2010 1.50 675.00 Exchanging e-mails with S. Stirling and M. Lessne re water rights to the Colorado mines (Bueno, Black Rose, Glory Hole), Discovery Day and Arizona mine (.3) and conversation with Garfinkle re same (.9); review S. Stirling's email to Lawrence Hittle i n Jamestown and S. Stirling's emails with M. Lessne (.3)

8/17/2010 3.00 1,350.00 Draft and revise asset purchase agreeement

8/18/2010 0.10 45.00 Receipt and review of Notice of Appearance of John Moffa for Estate of Harold Caldwell



8/19/2010 0.50 225.00 Telephone conference with Milt Shlapack, buyer for mines

8/25/2010 0.40 180.00 Conference call with Colorado title agent, Louis Weitzer

8/29/2010 0.40 180.00 E-mail from Garfinkle re case status (.2); review emails between S. Stirling and M. Lessne re L. Weltzer's report showing parties having recorded claims or interest (.2)

9/2/2010 0.20 90.00 Emails with Jason Welt re auction (.1); forward Garfinkle's email re Glory Hole to Francis (.1)


9/3/2010 3.50 1,575.00 Exchanging e-mails with M. Lessne, S. Stirling and A. Brodsky re filing motion for sale of property (.5); finalize and file sale motion (1.8); discuss complaint with M. Lessne (.5); foward sale motion to H. Winderman, F. Santos (.1); exchange emails with Garfinkle re motion for stay relief, etc. (.3); emails with M. Lessne and H. Winderman re Asset purchase agreement (.3)

9/3/2010 5.00 2,250.00 Review and revise sale motion, complaint and asset purchase agreement

9/8/2010 1.40 630.00 E-mail to H. Winderman regarding status of Asset purchase agreement and deposit (.1); serve answer to SEC complaint on L. Hughes and forward to M. Dunn (.3); emails with L. Hughes and A. Brodsky re filing the answer to complaint and with A. Brodsky r e obtaining local WA counsel re same (.3); receipt and review of consent and order from L. Hughes (.2); discuss same with her (.3); multiple emails with Matt Kramer and Jay Sakalo regarding corrections to agreed motion to vacate (.2)

9/10/2010 2.90 1,305.00 Exchanging e-mails with H. Winderman re asset purchase agreement and deposit (.2), and also with M. Lessne, J. Armengol, F. Santos (.3); receipt and review of notice of hearing on sale motion (.3); serve by email and mail to all on service list (1.7) ; forward to M. Dunn, H. Winderman, F. Santos and J. Armengol (.4)

9/11/2010 0.10 45.00 Receipt and review of recorded Glory Hole documents from L. Weltzer

9/12/2010 0.30 135.00 Exchanging e-mails with F. Santos and Garfinkle

9/13/2010 1.00 450.00 Telephone conference with F. Santos re: sale (.3); telephone with H. Winderman x 2 (.6) both re terms of the sale; revise asset purchase agreement to reflect new break up fee and bidding increments (.1)

9/15/2010 0.80 360.00 Exchanging e-mails with Gus Pappas re sale motion; Joe Davies re Clearwater Mining/Caldwell (.2); telephone conference H. Winderman re revised Asset purchase agreement (.3)

9/16/2010 0.80 360.00 Emails with Mike an F. Santos re Asset purchase agreement and deposit, and conversation with Dr. Salit (.4); emails with H. Winderman re Asset purchase agreement and deposit (.4)

9/20/2010 0.80 360.00 Exchanging e-mails with F. Santos re Asset purchase agreement and deposit (.2); telephone conference with S. Stirling re complaint (.3); in SEC v. Merendon matter: receipt and review of agreed motion for preliminary injunction v. Adair (.3)



9/20/2010 0.60 270.00 Telephone conference with Dr. Savitt, the buyer re potential interference with sale by another potential buyer (.3); telephone with Garfinkle re same (.3)

9/20/2010 0.30 135.00 Telephone conference with Milt Schlapack

9/21/2010 1.10 495.00 Exchanging e-mails with F. Santos re Asset purchase agreement and deposit status (.2); telephone conference with F. Santos, M. Lessne, Dr. Salit, M. Dunn and B. Mukamal regarding Garfinkle's attempt to interfere with stalking horse party (.3); review S. Stirling's transmission to M. Dunn of the complaint with exhibits for review; telephone conference with S. Stirling re motion to defer costs of filing complaint (.3)

9/21/2010 0.10 45.00 E-mail to H. Winderman, et al regarding Asset purchase agreement and deposit still not received and request for status update

9/22/2010 0.20 90.00 Emails with H. Winderman re status of Asset purchase agreement and deposit

9/23/2010 1.20 540.00 Telephone call from and with Dr. Salit (.9); emails with F. Santos re status of Asset purchase agreement and deposit (.3)

9/23/2010 0.30 135.00 Telephone conference with F. Santos re sale

9/24/2010 0.60 270.00 Telephone call from and with Dr. Savit (.3); telephone call with F. Santos re: sale (.3)

9/28/2010 1.00 450.00 Telephone conference with Dr. Savit (.3); telephone conference with buyer (.7)

10/11/2010 0.50 225.00 Telephone with Paul Danio, representative of new potential buyer and getting permission to look at property

10/11/2010 0.30 135.00 Telephone conference with paul danio re sale (.3);

10/14/2010 0.30 135.00 Telephone conference with Michael Morrison, Esq., represents Wabuska Mining

10/15/2010 0.80 360.00 Telephone with Mike Morrison on california discovery day mines and settlement re same (.5), conference with Matt kramer re same (.3)

10/18/2010 1.00 450.00 Telephone with Mike Morrison on california discovery day mines and settlement re same (.5), and telephone with Matt Krmaer re same (.5)

10/19/2010 0.50 225.00 Telephone conference with M. Dunn re settlement discussions regarding discovery day mone in california

10/22/2010 1.50 675.00 Settlement conference with trustee and others regarding discovery day mine

10/26/2010 0.50 225.00 Telephone with EPA and Department of Justice re Colorado mines

10/28/2010 1.00 450.00 E-mails to and from A. Brodsky from the EPA about potential buyer (.5) and emails to and from auctioneer re same (.5)

10/29/2010 0.30 135.00 Telephone conference with Jay Sakalo re settlement

11/1/2010 0.60 270.00 Telephone with Sakalo re settlement on Discovery Day x 2 (.6)



11/19/2010 1.00 450.00 Settlement conference call with client Jay Sakalo and his clents regarding Discovery Day

11/29/2010 0.60 270.00 Telephone conference with Sakalo re settlement re discovery day (.3) and email to and from M. Dunn and jay re same (.3)

1/10/2011 0.50 225.00 E-mails between John Moffa and M. Lessne

2/17/2011 0.50 225.00 conference call with M. Lessne & J. Sakalo re: Discovery Day.

2/23/2011 0.60 270.00 Conference call with M. Lessne, F. Santos, Marcis Dunn and Jason Welt regarding offer

3/16/2011 1.10 495.00 Conference call with trustee and our experts and auctioneer on selling properties

3/24/2011 1.00 450.00 Review Settlement and offer and conference with Sakalo and Lessne re: changes

4/22/2011 1.00 450.00 Conference with client re stalking horse and offers for mine with M. Dunn and mike

5/31/2011 0.30 135.00 Receipt and review of email from M. Lessne to M. Dunn and F. Santos enclosing the Asset purchase agreement agreement.

5/31/2011 0.20 90.00 Emails with receipt Patrick Fagen and M. Dunn regarding funds.

5/31/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing the Glory Hole Asset purchase agreement.

6/3/2011 0.10 45.00 Receipt and review of an email from M. Lessne to Sean Doyle re: Asset purchase agreement.

6/6/2011 0.20 90.00 Receipt and review of an email from Sean Doyle to M. Lessne enclosing an executed Asset purchase agreement.

6/6/2011 0.20 90.00 Receipt and review of an email from M. Lessne to M. Dunn RE: execution of the Asset purchase agreement.

6/6/2011 0.20 90.00 Receipt and review of an email from Sean Doyle regarding Agreement that has the correct corporate name for the Purchasing entity.

6/7/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing a fully executed Asset purchase agreement.

6/7/2011 0.20 90.00 Receipt and review of an email from Alexandra Castro enclosing the Asset purchase agreement.

6/7/2011 0.20 90.00 Receipt and review of an email from Tim Millar re: status of the Glory Hole auction .

6/7/2011 0.20 90.00 Receipt and review of emails between Jason Welt and M. Lessne regarding Asset purchase agreement and Sale and Notice Procedures - Executed Asset purchase agreement.

6/8/2011 0.20 90.00 E-mails with M. Lessne regarding motion to sell and approve.

6/8/2011 0.20 90.00 E-mails with M. Lessne and A. Srour regarding Amended sale motion.

6/8/2011 0.30 135.00 Reviewed motion to sell and approve.



6/9/2011 0.20 90.00 E-mails with M. Lessne regarding Motion to Sell Certain Property of the Estate.

6/9/2011 0.20 90.00 E-mails with M. Lessne regarding obtaining thirty day extension on the sale hearing and the pretrials.

6/9/2011 0.20 90.00 E-mails with J. Cartagena regarding email to all parties requesting an extension of time to file a renewed motion to sell the property.

6/9/2011 0.20 90.00 Receipt and review of emails between M. Lessne and N. Nicole regarding Motion for Sale and Order on same.

6/9/2011 2.00 900.00 Review revise and draft sale motion and procedures

6/9/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to all interested parties requesting a 30-Day Continuance of Hearing set for 6/23 on Amended Sale Motion and Pretrial Conferences.

6/9/2011 0.20 90.00 Receipt and review of an email from A. Srour to F. Santos enclosing an Amended Motion for Sale of Property the Glory Hole Mining Properties Free and Clear of Liens, Claims, Encumbrances, and Interests, including Interests of Anyone Laying Claim to th e Estates Rights and Interests in such Properties, pursuant to 11 U.S.C. Â§105 and Â§363(B) and (F); (B) Set the Sale Procedures and Sale Hearing Date

6/10/2011 0.20 90.00 Receipt and review of an email from Arthur C. Neiwirth advising of no objection to extend the hearing date for the Amended Sale Motion and the Pretrial Conferences.

6/14/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to all interested parties requesting the hearing to be continued and scheduled for the middle of July 2011, during the week of July 18th through July 22nd.

6/16/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue Hearing on Amended Motion for Sale of Property the Glory Hole Mining Properties Free and Clear of Liens

6/17/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Dana Kinsman regarding Upcoming Mine Auction.

6/20/2011 0.50 225.00 Telephone conference with David Murray re sale of Glory Hole mine

6/21/2011 0.20 90.00 Receipt and review of an email from A. Srour to John Moffa enclosing the Asset purchase agreement.

6/22/2011 0.50 225.00 Conference call with auctioneers and client and mike re marketing plan when sale procedures are approved for glory hole

6/29/2011 0.40 180.00 Emails with John Moffa regarding acceptance of the proposal.

7/5/2011 0.40 180.00 Emails with John Moffa regarding confidential settlement negotiations.

7/11/2011 0.10 45.00 E-mail to client enclosing the Asset purchase agreement.

7/11/2011 0.50 225.00 Telephone conference with Auctioneers, trustee, accountants, and Mike re sale hearing and consideration of caldwell bid



7/18/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle attaching Exh A to the Asset purchase agreement.

7/18/2011 0.30 135.00 E-mails with M. Dunn and M. Lessne re: Sean Doyle needs to amend the Asset purchase agreement

7/19/2011 0.30 135.00 Receipt, review and reply to an email from John Moffa re: Settlement offer.

7/19/2011 0.20 90.00 E-mail to John Moffa re: check received.

7/20/2011 0.30 135.00 Emails with Martin Hannan regarding sale date.

7/21/2011 0.30 135.00 Receipt and review of an email from Mr. Hanna enclosing a proposed Asset purchase agreement.

7/22/2011 0.20 90.00 Receipt and review of an email from F. Santos attaching pictures of the Bueno Mine and Black Rose.

7/22/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle re: information on the Black Rose and Bueno mining claims

7/22/2011 0.30 135.00 Reviewing and responding to e-mail from John Moffa re: requesting a title search conducted on properties.

7/22/2011 1.50 675.00 Telephone conference with buyer Sean Doyle & Mike re result of hearing; telephone conference with John Moffa re settlement, email to client and client professionals re result of both calls

7/26/2011 0.20 90.00 Receipt and review of an email form David Murray re: auction sale of mining claims.

7/26/2011 0.90 405.00 Receipt and review of Order Denying Amended Motion for Sale of Property.

7/27/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing the proposed agreement.

7/27/2011 0.20 90.00 Reviewing and responding to e-mail from John Moffa.

7/28/2011 0.20 90.00 Receipt and review of an email from A. Srour to M. Dunn enclosing an executed Asset purchase agreement for the Bueno Mines.

7/29/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing executed Asset purchase agreement.

8/1/2011 0.40 180.00 Reviewing and responding to e-mails from John Moffa enclosing draft of a Stipulation.

8/2/2011 0.10 45.00 Receipt and review of an email from A. Srour to Sean Doyle enclosing a fully executed copy of the Asset purchase agreement.

8/2/2011 0.20 90.00 Reviewing and responding to e-mail from Jason Welt re: Auction.

8/3/2011 0.30 135.00 Reviewing and responding to e-mail from John Moffa re: draft of the Stipulation.

8/3/2011 0.30 135.00 Receipt and review of emails from M. Lessne to John Moffa enclosing the Settlement Stipulation.

8/3/2011 0.50 225.00 Receipt and review of Notice of Hearing on Motion for Sale of Property (.3) and attention to matter re: same (.2)



8/3/2011 0.20 90.00 Reviewing and responding to e-mail from Judd Allen re: Merendon properties in Gilpin county.

8/3/2011 0.20 90.00 Reviewing and responding to e-mails from A. Srour re: setting hearing on Motion to Approve Sale.

8/3/2011 0.30 135.00 Receipt and review of Notice of Hearing on Motion for Sale of Property

8/4/2011 0.20 90.00 Reviewing and responding to e-mail from John Moffa re: settlement Stip.

8/5/2011 0.20 90.00 Reviewing and responding to e-mail from Adam Katz re: motion to sell free and clear (Bueno and Black Rose properties)

8/5/2011 0.30 135.00 Reviewing and responding to e-mail from John Moffa re: Caldwell Stipulation.

8/8/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue Hearing On Amended Motion for Sale of Property.

8/9/2011 0.20 90.00 Reviewing and responding to e-mail from John Moffa re: Stipulation.

8/12/2011 0.30 135.00 Telephone conference with Robert Eber of colorado attorney generals office re sale of Glory Hole

8/18/2011 0.40 180.00 Reviewing and responding to e-mail from M. Lessne enclosing motion for approval of settlement and order granting same for review.

8/18/2011 0.40 180.00 Receipt and review of an email from Alexandra Castro enclosing signed Stipulation re: Fedrigon and a signed Stipulation for Settlement.

8/18/2011 0.30 135.00 Telephone conference with Paul Garfinkle re: mines

8/18/2011 0.20 90.00 Receipt and review of emails between M. Lessne and Dawn Caldwell re: Stipulation.

8/18/2011 0.20 90.00 Reviewing and responding to e-mails from M. Lessne re: 9019 Motion

8/18/2011 0.40 180.00 Reviewing and responding to e-mail an email from John Moffa enclsing final draft of the Stipulation and a second attachment with the signatures of his clients.

8/19/2011 0.20 90.00 E-mail to A. Srour and J. Cartagena re: Motion to Compromise Controversy with and to Approve Settlement.

8/19/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to Adam Katz enclosing Notice of Filing Exhibit A to the Settlement Agreement.

8/19/2011 0.20 90.00 Reviewing and responding to e-mail from Adam Katz re: 9019 Motion to Approve Settlement.

8/19/2011 0.20 90.00 Receipt and review of an email from Paul Garfinkle to Gus Pappas re: agreement with the Trustee to settle the Glory Hole Issue.

8/20/2011 0.40 180.00 Reviewing and responding to e-mails from Paul Garfinkle.

8/22/2011 0.30 135.00 Receipt and review of Notice of Hearing on Motion to Compromise Controversy with and to Approve Settlement.



8/23/2011 0.30 135.00 Emails with John Moffa re: Objections to Glory Hole Sale

8/23/2011 0.40 180.00 Receipt and review of an email from Paul Garfinkle enclosing Objections to your proposed sale of the Glory Hole Assets.

8/23/2011 0.20 90.00 Reviewing and responding to e-mail an email from John Moffa re: Objections to Glory Hole sale

8/25/2011 0.60 270.00 Receipt and review of Objection by Paul Garfinkle to Trustee's Motion to Approve Settlement with the Estate of Harold Cald Well Through its Personal Representative, Dawn Caldwell Fedrigon, and Dawn and Michael Fedrigon and email to client regarding the same.

8/25/2011 0.30 135.00 Receipt and review of an email from J. Cartagena enclosing Notice of Filing Receipt of Objection by Paul Garfinkle for review.

8/25/2011 0.30 135.00 Receipt and review of Objection to Motion to Compromise Controversy with and to Approve Settlement.

8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour to M. Dunn enclosing Objection by Paul Garfinkle to Trustee's Motion to Approve Settlement with the Estate of Harold Cald Well Through its Personal Representative, Dawn Caldwell Fedrigon, and Dawn and Mic hael Fedrigon.

8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour to John Moffa enclosing Objection by Paul Garfinkle to Trustee's Motion to Approve Settlement with the Estate of Harold Cald Well Through its Personal Representative, Dawn Caldwell Fedrigon, and Dawn and Michael Fedrigon.

8/27/2011 0.20 90.00 Reviewing and responding to e-mail from Martin Hannan re: Trustee's Motion to sell free and clear of liens

8/29/2011 0.20 90.00 Reviewing and responding to e-mail from F. Santos re: an update on the status of the Bueno and Black Rose Mine auction as far as a projected sale date.

9/6/2011 0.20 90.00 Receipt and review of email to and from Tim Millar re asset disposition of mines

9/6/2011 0.30 135.00 Emails with Tim Millar regarding settlement.

9/6/2011 0.30 135.00 Telephone conference with Andrea madagan of EPA

9/6/2011 2.30 1,035.00 Telephone conference with Sean Doyle re his possibly backing out of agreement (.7); telephone with Andrea Madigan re: same x 2 (.7); telephone with both (.9)

9/6/2011 0.30 135.00 E-mails with Sean Doyle, M. Lessne and Andrea Madigan regarding conference call to discuss the Bueno and Black Rose mines.

9/7/2011 0.30 135.00 E-mails with Taz regarding settlement reached for the Glory mine.

9/8/2011 0.30 135.00 E-mails with A. Srour and M. Lessne regarding Rob Meacham's call on the Motion to Approve settlement and Motion to Approve Sale.



9/9/2011 0.30 135.00 E-mail from Laurie Bobrow enclosing correspondence from Robert Meacham regarding Glory Hole Mining Properties (“Settlement Motion”) and the second is the Amended Motion to (A) Approve The Sale of the Bueno and Black Rose Mining Properties Free and Cl ear of Liens, Claims, Encumbrances, and Interests Pursuant to 11 U.S.C. § 363; (B) Set the Sale Procedures and Sale Hearing Date; and (C) Set the Notice Procedures For the Sale generally referring to the Bueno and Black Rose Mining Properties (“Sale Motion”).

9/9/2011 0.30 135.00 E-mails with J. Cartagena and M. Lessne regarding the Amended Sale Motion for Glory Hole and 9019 motion as well as the second amended sale motion

9/9/2011 0.10 45.00 Receipt and review of email from Robert Meachem re potential objection to sale of mines

9/14/2011 0.30 135.00 E-mails with John Muffa regarding Objection to Settlement Motion.

9/15/2011 0.20 90.00 Emails with John Muffa regarding joint response to the Garfinkle objection.

9/19/2011 4.30 1,935.00 Receipt and review of and revise draft of joint response to garfinkle objection to sale (3.5), review garfinkle objection (.5) and telephone with Moffa re same (.3)

9/19/2011 0.60 270.00 Telephone conference with David Murray (.3); telephone with Charles Gryba (.3) both re sale

9/20/2011 0.20 90.00 E-mail to Brent Baker enclosing purchase contract.

9/20/2011 0.20 90.00 Emails with M. Lessne and J. Cartagena regarding hearing on 9019 Settlement Motion.

9/20/2011 0.50 225.00 Telephone conference with Moffa counsel to Caldwell estate re response to objection

9/21/2011 0.40 180.00 E-mails with John Muffa regarding revisions to the Joint response by Dunn and Caldwell to Paul Garfinkle's objection.

9/21/2011 0.20 90.00 E-mail to Brent Baker enclosing Trustee's Amended Motion to Approve the Sale of the Bueno and Black Rose Mining Properties,

9/21/2011 0.20 90.00 E-mails with Martin Hannan regarding 9019 Settlement Motion scheduled for Sept. 27, 2011 with regard to the the Glory Hole Mines.

9/21/2011 2.00 900.00 Review revising and drafting joint response to objection to settlement.

9/22/2011 0.30 135.00 E-mails with John Muffa enclosing Dunn & Caldwell Joint Response to Paul Garfinkle's Objection to Settlement.

9/22/2011 2.00 900.00 Review revising and drafting joint response to objection to settlement

9/22/2011 0.20 90.00 E-mails with J. Cartagena regarding filing of Dunn & Caldwell Joint Response to Garfinkle Objection to Settlement.

9/22/2011 0.20 90.00 Receipt and review of an email from F. Santos to Charles Gryba re Bueno and Black Rose Mining Claims enclosing attachments.



9/23/2011 0.30 135.00 Receipt and review of Motion to Continue Hearing On: Motion to Compromise Controversy and Motion to Approve Settlement.

9/23/2011 0.30 135.00 Emails with Martin Hannan regarding Motion to Continue Hearing on Motion to Compromise Controversy.

9/26/2011 0.20 90.00 E-mail from M. Lessne to Sean Doyle regarding executed amendment.

9/26/2011 0.20 90.00 E-mails with Martin Hannan regarding 9019 Settlement Motion.

9/26/2011 0.10 45.00 Receipt and review of an email from Sean Doyle to M. Lessne re Amendment to Asset purchase agreement.

9/27/2011 1.60 720.00 Revise settlement order and submit to court, emails to and from parties re same

9/27/2011 0.20 90.00 E-mails with J. Leibner regarding Research on Standing of Paul Garfinkle's Arguments.

9/27/2011 0.20 90.00 E-mail from Adam Katz regarding motion to sell free and clear (Bueno and Black Rose properties).

9/27/2011 0.20 90.00 E-mail to Sean Doyle regarding sale of the Boulder county properties.

9/28/2011 0.20 90.00 E-mails with Jason Welt regarding sale of the Boulder county properties.

9/28/2011 0.20 90.00 E-mails with John Moffa enclosing an Order Approving Settlement with Caldwell based upon the court's ruling of September 27, 2011 hearing.

9/29/2011 0.50 225.00 Receipt and review of Garfinkle's Answer to Joint Response to Objection to Motion to Compromise Controversy with and to Approve Settlement with the Estate of Harold Caldwell through its Personal Representative, Dawn Caldwell Fedrigon, and Dawn and Mi chael Fedrigon with exhibits (.4)and email to client enclosing the same (.1)

9/30/2011 0.10 45.00 E-mai from A. Srour to Robert Andrews reagrding settlement of the Estate of Harold Caldwell.

9/30/2011 0.50 225.00 E-mails with M. Lessne regarding Order granting Sale Motion (Bueno and Black Rose Mines) and review of the same.

9/30/2011 0.10 45.00 E-mail from J. Cartagena regarding Merendon Stipulation Time Line.

9/30/2011 0.10 45.00 E-mail from J. Cartagena to M. Dunn, John Moffa and F. Santos enclosing Order Granting Motion to Approve Settlement with the Estate of Harold Caldwell through it's Personal Representative.

9/30/2011 0.30 135.00 E-mails with John Moffa regarding Merendon Stipulation Time Line.

10/3/2011 5.00 2,250.00 Revise draft of sale order



10/5/2011 0.10 45.00 E-mail to M. Lessne, J. Cartagena and A. Srour regarding service of Order on Motion for Sale of Property Merendon Mining.

10/5/2011 0.30 135.00 E-mail from Sean Doyle to M. Lessne enclosing an expense to be reimbursed in the Glory Hole settlement.

10/5/2011 0.20 90.00 Receipt and review of Order Granting Trustee's Amended Motion to Approve the Sale of Property.

10/6/2011 0.20 90.00 E-mail from F. Santos regarding the property tour scenario of the Bueno and Black Rose Mines.

10/17/2011 0.50 225.00 Telephone conference with Marcia, Francis, and Mike re marketing the sale

10/17/2011 0.20 90.00 E-mail to John Moffa regarding settlement money.

10/19/2011 0.20 90.00 E-mails with John Moffa re receipt of settlement money.

10/19/2011 0.10 45.00 E-mail from John Moffa re wiring of the settlement money.

10/20/2011 0.20 90.00 E-mails with John Moffa and M. Dunn regarding settlement money.

10/27/2011 0.20 90.00 E-mails between M. Lessne and M. Dunn re Service of the Order Granting Sale Motion re Bueno and Black Rose Mines dated October 5, 2011.

10/31/2011 0.10 45.00 E-mail from M. Lessne to L. Weltzer re Heritage Title's Invoices.

11/4/2011 0.20 90.00 Emails with M. Dunn and M. Lessne re of the Glory Hole commission check

11/7/2011 0.10 45.00 Receipt and review of an email from Jason Welt to M. Dunn re Bueno and Black Rose mines in Boulder, Co.

11/14/2011 0.20 90.00 Receipt and review of e-mail from M. Lessne to M. Dunn enclosing invoice from Heritage Title

11/21/2011 0.20 90.00 Receipt and review of an email from geologist, Amandip Singh re the Bueno and Black rose properties.

11/29/2011 0.10 45.00 Receipt and review of an email from Paul Garfinkle re Glory Hole and Sentinel Mining Corporation.

12/1/2011 0.20 90.00 Receipt and review of emails between M. Lessne and J. Cartagena re Service of the Order Granting Sale of Bueno and Black Rose Mining Properties.

12/7/2011 0.20 90.00 Reviewing of Certificate Of Service Regarding Order Granting Trustee’s Amended Motion To (A) Approve The Sale Of The Bueno And Black Rose Mining Properties Free And Clear Of Liens, Claims, Encumbrances, And Interests Pursuant To 11 U.S.C. §363; (B) S et The Sale Procedures And Sale Hearing Date; And (C) Set The Notice Procedures For The Sale [D.E. # 284]

12/14/2011 0.20 90.00 E-mails with Clark G. Edwards from HUTCHINSON BLACK AND COOK, LLC who represents Left Hand Ditch Company re 1/4/2012 auction.

12/14/2011 0.20 90.00 E-mails with M. Lessne re Auction of Bueno and Black Rose Mining Properties



12/20/2011 0.20 90.00 Reviewing e-mails between Jesscia Serrano and Marcia Dunn re fully executed Asset Purchase Agreement

1/3/2012 0.20 90.00 Emails with M. Lessne and Judicial Assistant Barbara Cargill re Hearing to Approve Sale of Bueno and Black Rose Mines.

1/3/2012 0.10 45.00 Reviewing of email from M. Lessne to Francis Santos re Asset Purchase Agreement between David Badner/Badner Group Inc.

1/5/2012 0.20 90.00 Review of Order Approving Sale of Bueno and Black Rose Mining Properties.

1/6/2012 0.10 45.00 Emails with M. Lessne and Jeffery A. Bahnsen re Closing on Sale of Gold Mines.

1/6/2012 0.10 45.00 Reviewing e-mail from M. Dunn to Tong Li re: sale of Bueno and Black Rose

1/9/2012 0.20 90.00 Emails with M. Lessne re Order Approving Sale of Bueno and Black Rose Mining Properties Asset purchase agreement.

1/10/2012 0.30 135.00 Emails with Tong Li re Order approving sale procedures and re telephone conference.

1/10/2012 0.10 45.00 Emails with Barry I. Grossman re Proposed Order Approving Sale of Bueno and Black Rose Mining Properties.

1/11/2012 0.30 135.00 E-mail to Tong Li, Sarah E. Williams and Barry Grossman and clients enclosing Order approving Sale of the Boulder County properties to Badner and emails re same.

1/11/2012 4.00 1,800.00 Draft sale order and revisions to same and telephone with buyers counsel re same

1/11/2012 0.20 90.00 Emails with M. Lessne and Tong Li re revising the proposed Order Approving Sale of Bueno and Black Rose Mining Properties

1/12/2012 0.10 45.00 Receipt and review of emails between M. Lessne and Tong Li re final version of the proposed Order Approving the Sale of Bueno and Black Rose Mining Properties

1/17/2012 0.10 45.00 Receipt and review of Order Approving the Sale of the Bueno and Black Rose Mining Properties and email to client enclosing the same.

1/18/2012 0.20 90.00 Emails with Robert Meacham re order approving the sale of Bueno and Black Rose Mines.

1/19/2012 0.20 90.00 Reviewing of Certificate of Service of Order Approving Sale of Bueno and Black Rose Mining Properties

1/24/2012 0.20 90.00 Receipt and review of Trustee's Deed and Turstee's Bill of Sale.

1/24/2012 0.20 90.00 Emails with Tong li re Final Trustee's Deed and Bill of Sale - Bueno and Black Rose Mining Properties

1/24/2012 0.20 90.00 Emails with M. Lessne, Jeff Bahsen and Tong Li re regarding the deed in Boulder county.

1/25/2012 0.20 90.00 E-mail from and to Tong Li re Revised Trustee's Deed.



1/25/2012 0.10 45.00 Receipt and review of of an email from Jeff Bahnsen to M. Dunn re Closing Documents.

1/27/2012 0.20 90.00 Reviewing and revising of Memorandum to M. Dunn re Gold Basin Mine, Dolen Springs, Arizona.

1/31/2012 0.10 45.00 Email with J. Cartagena re Title search in Dolan Springs, AZ for Merendon Mining.

1/31/2012 0.30 135.00 Emails with Jeffrey Bahnsen re Statement of Lost Stock Certificate and reviewing of the same.

3/30/2012 0.10 45.00 Trustee's Motion to Approve Settlement with Worldwide Rental Services

3/30/2012 0.10 45.00 Receipt and review Trustee's Motion to Approve Settlement with worldwide Rental Services a/k/a Worldwide Machinery



6/11/2009 2.00 800.00 Conference with client and J. Ryan

6/11/2009 1.00 400.00 Conference call with F. Terzo and B. Elam

6/12/2009 0.50 200.00 Exchange e-mails with M. Dunn, B. Elam regarding 450 Alton Road, Miami Beach address not being "good" and setting conference call (x4); e-mail to Patrick Scott and Leyza Blanco regarding securing hard assets in existence in Colorado and Arizona mines (x1); e-mailing with Leyza Blanco regarding her tasks in case, i.e., securing assets here in FL and in Colorado and Arizona (x4) (.5)

6/12/2009 3.00 1,200.00 Conference with Bob Schatzman and Financial Advisors Berger, Mukamal and Khandahar

6/13/2009 0.10 40.00 E-mail to R. Schatzman, M. Dunn and B. Elam regarding setting an in-person meeting

6/14/2009 0.10 40.00 E-mail to B. Elam regarding locating documents, people, and assets

6/15/2009 2.00 800.00 Exchanging numerous e-mails in an attempt to set conference call with B. Elam, B. Mukamal, Robert Schatzman, M. Dunn, S. Khanorkar, S. Solomon

6/16/2009 1.70 680.00 Receiving and reviewing multiple emails from Schatzman, Elam, Zucker, regarding foreign assets and Zucker (.7); multiple emails with B. Elam regarding other creditors and resigning (1.0)

6/16/2009 2.30 920.00 email with B. Elam regarding out of country assets, Zucker, and website for scam (.4); and conference call with all parties (1.9)

6/21/2009 0.30 120.00 Exchanging e-mails with B. Elam, R. Schatzman and S. Solomon regarding filing involuntary and consolidating "other" entity in bankruptcy in Colorado

6/22/2009 0.10 40.00 Receipt and review of memo from R. Schatzman summarizing June 16 conference call and June 19 meeting



6/23/2009 1.90 760.00 Exchanging multiple e-mails with B. Elam and R. Schatzman regarding Garfinkle and Nigel Smith (.9); exchanging e-mails with B. Elam and R. Schatzman regarding Harry Gurwitch (1.0)

6/24/2009 0.10 40.00 Receipt and review of e-mail from B. Elam to Nigel Smtih

6/24/2009 0.20 80.00 Receiving and reviewing emails from B. Elam and Schatzman regarding documents to review from Nigel

6/25/2009 0.10 40.00 Receiving and reviewing email from B. Elam regarding Garfinkle memo

6/25/2009 0.90 360.00 Exchanging multiple e-mails with Steve and B. Elam regarding memo to be completed by Garfinkle

6/26/2009 5.40 2,160.00 Meeting with Trustee, lawyers and accountants (4.1); receipt and review of Trustee's Ex Parte Application for Employment of Special Investigative Counsel Nunc Pro Tunc to June 6, 2009 (B. Elam) (.4); exchange emails with S. Solomon and L. Negron rega rding filing motion for extension of 45 days to draft schedules (.3); emails with M. Dunn regarding motion for extension of time (.3); emails with F. Terzo and B. Elam regarding potential lawsuits against petitioning creditors (.3)

6/26/2009 0.40 160.00 E-mails to Rosy Lopez regarding Merendon press coverage (.2); and to L. Negron regarding Motion for Extension to file schedules (.2)

6/27/2009 0.30 120.00 E-mails from S. Solomon regarding Garfinkle's e-mail about the roles of the parties

6/29/2009 1.30 520.00 Exchanging e-mails with B. Elam regarding identification of Nigel (.5); receipt and review of e-notification of Notice of Hearing on Ex Parte Application to Employ B. Elam as Special Investigative Counsel (.5); exchanging e-mails with Leyza Blanco re garding memo (x3) (.3)

6/29/2009 4.50 1,800.00 Review memos and notes (3.5); draft memo and send via email to Merendon Team outlining status and what needs to be done (1.0)

6/29/2009 4.50 1,800.00 Review memos by R. Schatzman and Garfinkle (1.1), review other documents (1.2), draft strategy memo outlining various tasks to be performed ( 1.1) and assigning responsibilities and email re: same (.9)

6/30/2009 1.20 480.00 Exchanging e-mails with B. Elam, R. Schatzman, M. Dunn, S. Solomon, et al., regarding J.Bennett setting conference call for July 20; and Motion to Extend to August 14 (x10) (1.0); e-mails to and from F. Terzo regarding Terzo's conversation with Judge Cristol's calendar clerk regarding all special counsel (x2) (.2)

6/30/2009 0.80 320.00 Receiving and reviewing emails between M. Dunn and A. Brodsky regarding setting conference call with creditors (.3); e-notice of Motion to Extend Time to File Schedules, Statement of Financial Affairs, and other documents (.2), and with M. Dunn regar ding J. Ryan's employment (.3)

7/1/2009 1.20 480.00 Receiving and reviewing multiple emails to/from/with A. Brodsky, B. Elam regarding conference call for 7/20 (.8); Review email from Tom Suozzo (.1); telephone conference with R. Schatzman regarding Nevada accounts (.3)



7/1/2009 0.20 80.00 Receipt and review of Order Granting Motion to Extend Time to File Schedules/Plan (.1); transmit to team (.1)

7/2/2009 0.10 40.00 Receiving and reviewing email from Jenny Reyes transmitting Order granting extension of time

7/7/2009 3.20 1,280.00 Receiving and reviewing multiple emails to/from/with B. Elam and R. Schatzman regarding investor funding status (.4); review email from S. Khanorkar regarding status and tasks (.1); review amended hearing notice on employment of B. Elam (.2); teleph one conference with B. Elam and creditors (2.5)

7/10/2009 1.20 480.00 Receiving and reviewing multiple emails to/from/with B. Elam and R. Schatzman regarding creditor updating and case management (.3); recieve and review email from S. Khanorkar, R. Schatzman, et al., regarding setting meeting (.3); telephone conference with R. Schatzman, S. Solomon, and A. Brodsky regarding hearing on hiring B. Elam (.5); and with M. Dunn regarding conference call with creditors (.1)

7/14/2009 0.20 80.00 Receiving and reviewing emails with A. Brodsky regarding meeting in Miami office with B. Mukamal, S. Khanorkar, and Schatzman on 7/16

7/15/2009 0.70 280.00 Exchanging e-mails with B. Elam regarding upcoming hearing on his employment application

7/16/2009 0.10 40.00 E-mail from L. Negron transmitting Order employing B. Elam

7/17/2009 0.50 200.00 Attend hearing telephonically on disclosure statement

7/17/2009 0.10 40.00 Review Notice of Rule 2004 Exam of US Bank

7/17/2009 0.50 200.00 Telephone conference with J. Ryan re: conversation with Les Taylor

7/21/2009 0.40 160.00 Telephone call to Maureen Bondor regarding creditor conference call held 7/20/09

7/24/2009 0.90 360.00 E-mails with M. Dunn and Maria Fernandez regarding wire transfers (.7); and with R. Schatzman regarding US Bank (.2)

7/27/2009 0.70 280.00 E-mails with A. Brodsky, Sharmils Khanorkar regarding US Bank Duces Tecum amendment

7/29/2009 0.30 120.00 Receipt and review of emails between S. Khanorkar and B. Elam

7/30/2009 0.20 80.00 Receipt and review of Trustee's Interim Report for June (.1); email from Schaztman transmitting Abbott report (.1)

8/3/2009 0.70 280.00 Receipt and review of Individual Estate Property Record and Report Asset Cases (.3); emails with M. Dunn, S. Khanorkar, B. Elam regarding status of preparation of petition and schedules (.3); email with A. Brodsky regarding U.S. Bank production (.1)

8/7/2009 1.10 440.00 Exchanging e-mails with M. Dunn, et al. regarding schedules, Garfinkle and motion for further extension

8/10/2009 0.60 240.00 Exchanging e-mails with L. Negron, R. Schatzman, Nate Mancuso regarding motion seeking further extension



8/11/2009 0.90 360.00 Exchanging e-mails with S. Khanorkar and A. Brodsky regarding receipt of documents and CDs from U.S. Bank (.2); filed Second Ex Parte Motion to Extend Time to File Schedules, SOFA, and other documents (.4); receipt and review of Order granting same, serve, circulate and calendar new deadline (.3)

8/12/2009 0.10 40.00 E-mail from A. Brodsky to M. Dunn and me with new deadline for filing schedules, etc.: 9/14/09

9/1/2009 2.00 900.00 Receipt and review of Notice of Default on Promissory Notes, May 2, 2008 (.2); multiple emails with R. Schatzman, M. Dunn, S. Khanorkar, B. Mukamal, Morris, J. Ryan regarding US Bank accounts (.8); emails and telephone conference with M. Dunn regardi ng meeting in Miami regarding schedules (1.0)

9/4/2009 0.10 45.00 Transmit to all IFFL flow chart

9/8/2009 1.10 495.00 Exchanging e-mails with B. Mukamal regarding contacts for pending investigations (.2); emails with A. Brodsky regarding letter to Scoggins at SEC in Denver for access (.3); review of email regarding retention of Interfor company (.1); receipt and rev iew of email transmission of several documents regarding IFFL notice of hearing, Strategic Metals notice of hearing, Capital Alternatives, Brost, ASC decision, review ASC sanctioning decision (.3); review emails between S. Khanorkar and Brad Regier ( .2)

9/9/2009 6.50 2,925.00 Telephone with Vicky Rhineheart (investor/ creditor) (.3); email to and from M. Dunn re: same and email to and from Bob Hicock re: same (.4); telephone with Paul Garfinkle (.5); tele with M. Dunn (.3); reviewing and revising schedules and statement of financial affairs (1.0); multiple calls and emails with government investigators in US and Canada and emails and calls with Bill Pearson re: same (2.0) emails to and from multiple times with investors re: stay violations by investor recovery g roup (2.0)

9/9/2009 4.10 1,845.00 Exchanging e-mails with M. Dunn and Robert Hickok regarding Reinhart (.3); emails with R. Schatzman regarding documents from Alberta Securities Commission (.2); with George Reinhart regarding recovery pool (.7); with L. Negron and S. Khanorkar regar ding schedules (.9); with William Pearson regarding case and investigations (.6); with R. Schatzman regarding receiver (.7); with William Pearson and L. Negron regarding complaint from state of Washington (.7)

9/10/2009 5.30 2,385.00 Exchanging e-mails with M. Dunn, B. Mukamal, S. Khanorkar, R. Schatzman and L. Negron regarding schedules (.5); meeting with all regarding various cases and investigations (2.5); with Matt Galioto, Bill Pearson regarding conference call (2.3)

9/10/2009 0.10 45.00 E-mail to L. Negron regarding Glory Hole

9/11/2009 1.10 495.00 Receipt and review schedules and SOFAs (.8); along with emails to and from L. Negron and S. Khanorkar and M. Dunn re: same (.3)



9/14/2009 1.90 855.00 Exchanging e-mails with all parties regarding Garfinkle, case, investors, etc.; with Matt Galioto regarding Milo Brost's arrest (1.4); transmit schedules and statement of financial affairs to M. Dunn, George Rienhart, B. Elam, J. Ryan, S. Khanorkar, et al. (.5)

9/15/2009 0.20 90.00 E-mails with Robert Hickok regarding Brost being in custody of RCMP and warrant for Sorenson

9/17/2009 0.70 315.00 Exchanging e-mails with S. Khanorkar regarding B. Mukamal's affidavit to Mr. Quilling (.5); review email from Garfinkle regarding revision (.2)

9/18/2009 0.20 90.00 Teleconference with L. Negron regarding 341 meeting etc.

9/24/2009 0.60 270.00 E-mailing with B. Elam regarding case status (.3); emails with William Pearson re: same (.3)

9/25/2009 0.30 135.00 E-mailing with B. Elam regarding case status

10/26/2009 0.10 45.00 E-mail from B. Elam regarding Discovery Day mine

10/27/2009 0.60 270.00 Exchanging e-mails with Paul Garfinkle regarding Strategic Metals

11/18/2009 0.80 360.00 E-mail from B. Elam regarding status (.1); emails with A. Brodsky regarding Garfinkle call (.3); multiple emails with M. Dunn, B. Elam, et al. regarding status meeting (.4)

12/13/2009 0.20 90.00 E-mail from Paul regarding Canada hearing/receiver over Sorenson's properties (.1); and from A. Brodsky regarding exhibits to Motion (.1)

12/20/2009 0.20 90.00 Exchanging e-mails with Paul regarding trustee appointed in Canada and hearing on 1/12/10, Proofs of Claim, send him hearing information

12/21/2009 0.20 90.00 Emails with Paul Garfinkle

12/24/2009 0.20 90.00 Receipt of efiled motions in adversary and main cases

1/4/2010 0.50 225.00 Email from S. Khanorkar transmitting SGD promissory note (.1), receipt and review of hearing regarding Arbour Energy in Alberta sent by Nicole Chute, Alberta Securities Commission (.3), and calendar same (.1)

1/6/2010 0.40 180.00 Receipt and review of order on limited notice and telephone with L. Negron re: setting up a website to comply with same

1/8/2010 5.00 2,250.00 Hearing preparation

1/9/2010 4.00 1,800.00 Hearing preparation

1/10/2010 6.30 2,835.00 Hearing preparation (6.0); emails (x2) from Paul transmitting new article regarding Brost - Google search (.2); one email from S. Khanorkar with cash flow charts for hearing (.1)

1/11/2010 0.20 90.00 Exchanging e-mails with Ken Iredale regarding Martin Werner and geologist

1/11/2010 8.00 3,600.00 Preparation for hearing, research and drafting orders for hearings

1/12/2010 0.30 135.00 Telephone call from Martin Werner re: case (.1); emails from Ken Iredale (.2)



1/12/2010 1.20 540.00 Exchanging e-mails with Michelle Khouri, L. Negron, A. Brodsky, Cheryl Bennett, Maylyn Vargas, B. Elam, M. Dunn regarding press release, website, creditors (.6); receipt and review of Martin Werner's Motion to Dismiss and MOL in Support (.6)

1/12/2010 8.00 3,600.00 Preparing for hearing on Motion for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of the Estate, and Injunctive Relief (4.0); attend hearing (3.0); post-hearing meeting with Martin Werner and S. Khanorkar (1.0)

1/13/2010 1.80 810.00 Exchanging e-mails with Kyle Roat, Paul Brinkman of Biz Journals, with many creditors regarding motion and answering many of their questions

1/14/2010 0.10 45.00 Telephone call from Martin Werner

1/15/2010 2.40 1,080.00 Exchanging e-mails with Cliff Hark, L. Negron, Cheryl Bennett, B. Elam regarding gold mines, The Agency, Kelly Crowley (investor) regarding Investment Recovery Pool (1.0); receipt and review of NOH on Werner's motion to dismiss (.2); receipt and revi ew of letter to Judge Cristol from Hark regarding objections to order (.2); many creditor calls regarding case (1.0)

1/19/2010 0.40 180.00 Exchanging e-mails with Michelle Khouri regarding final order entered to have on file and for website (.2); receipt and review of Notice of Appearance of Creditor Ian Zelo (.2)

1/24/2010 4.00 1,800.00 Preparing for continued hearing on 1/25/10

1/25/2010 4.10 1,845.00 Preparing for and attendance at continued hearing on Motion for Substantive Consolidation of Non-Debtor Entities...

1/26/2010 0.40 180.00 Telephone conference with Michelle Khouri regarding order for posting to website

2/1/2010 3.70 1,665.00 Exchanging e-mails with Werner regarding outstanding matters (.3); emails with Cliff Hark and A. Brodsky regarding deposition of Paul Garfinkle (.3); email from M. Dunn regarding website link (.1);email transmitting proposed agreed order on Werner mo tion to dismiss and emails back and forth with Werner regarding the same (.3); Follow-up with court and cancel hearing on motion to dismiss (.4); review A. Brodsky's emails to creditors (1.3); emails with creditor Paul Morgan regarding his motion to allow late filed claim (.5); draft and upload agreed order(.5)

2/2/2010 4.00 1,800.00 Exchanging e-mails with team regarding call with Canadian receiver, Michael Quilling, and his counsel (.3); emails with Cheryl Bennett and L. Negron regarding website issues (.3); emails with A. Brodsky regarding late filed claims order(.2); receipt and review of and transmit agreed order on Werner's motion to dismiss to Werner and M. Dunn (1.6); receipt and review of entered agreed order allowing late filed claim and transmit same to Paul Morgan(1.2); multiple emails with creditor Karen Fujita regarding claim and case(.2); email from Werner forwarding email from Court of Queens Bench, Alberta, regarding SGD adv. Nostratieh, et al. (.2)



2/3/2010 0.60 270.00 Telephone conference with B. Elam, S. Khanorkar and M. Dunn re: case administration

2/3/2010 0.90 405.00 Exchanging e-mails with M. Lessne regarding foreign jurisdictions and translation of documents (.4); telephone conference with Paul Garfinkle regarding escrow deposit and email from Les Taylor (.4); email from S. Khanorkar regarding geologist reports (.1)

2/4/2010 2.10 945.00 Exchanging e-mails with Cliff Hark and A. Brodsky regarding depositions of Garfinkle and B. Mukamal (.8); email from S. Richard (.1); email from Ward Capstick transmitting Alberta Corp. Registry search (.1); receipt and review of several documents fr om Garfinkle and Capstick (.8); emails with creditor Terra Finial (.3)

2/4/2010 0.50 225.00 Receipt and review of several emails from Paul Garfinkle transmitting documents

2/5/2010 2.80 1,260.00 Exchanging e-mails with B. Elam, M. Dunn regarding translation costs and Janie Munoz, translator (.5); email from Garfinkle regarding the volume of documents for his deposition (.2); receipt and review of deposition notices for B. Mukamal and Paul's depositions from Cliff Hark, as well as Hark's notice of appearance for Thelma Sorensen, and notice of limited appearance from Gary Sorensen and Merendon Mining, SA (1.4); teleconference with S. Khanorkar regarding contacting Werner (.7)

2/9/2010 1.80 810.00 Receipt and review of Garfinkle deposition transcript (.3); emails with Peter Walton regarding jurisdiction over Nordic (.3); email to M. Lessne regarding order incorporating provisions of SEC (.1); telephone conference with B. Elam and S. Khanorkar regarding Capstick and Exotic Wood World (.3); email to L. Negron regarding suggestions of bankruptcy (.1); telephone conference with A. Brodsky regarding Garfinkle's declaration with exhibit (.4); email from Art Neiwirth regarding Adair(.3)

2/10/2010 3.10 1,395.00 Exchanging e-mails with B. Elam and M. Dunn regarding employing translator (.4); receipt and review of motion to dismiss for lack of prosecution, and notices of appeal in main and adversary case filed by Hark on behalf of Sorensen (2.2); forward same to M. Lessne to begin drafting response (.1); forward to team (.1); emails with A. Brodsky regarding Liz Krupa's email for 2/11 hearing (.3)

2/10/2010 0.30 135.00 Emails with creditor Kelly Miller

2/11/2010 1.90 855.00 Exchanging e-mails with B. Elam regarding affidavit of translator (.2); receive and review notice of hearing on motion to serve certain foreign defendants by certified or registered mail (.3); forward to all and serve (.8); emails to Garfinkle and B. Elam regarding all US and Canada cases so we can file suggestions of bankruptcy in those jurisdictions (.4); email to Cliff Hark transmitting orders continuing hearing in both cases for his review and comments (.1); email to J. Armengol re: same (.1 )



2/12/2010 1.50 675.00 Exchanging e-mails with David Baddley, SEC, regarding setting conference call with him, Susan Sherrill-Beard and Elizabeth Krupa (.4); emails with A. Brodsky regarding filing suggestions of bankruptcy and recordation of orders in all jurisdictions wh ere mines are located (.4); serve Werner and Neiwirth the order continuing hearing to 2/19 on tro in both cases (.4); review email from B. Elam regarding translator's affidavit and M. Dunn's response to same (.1); transmit to Cheryl Kaplan, Judge Cri stol's law clerk, two orders (.2)

2/14/2010 0.10 45.00 Receipt and review of B. Elam's email to Marci forwarding motion to appoint translator and his email regarding pending lawsuits Garfinkle informed us of

2/15/2010 0.30 135.00 Exchanging e-mails with Garfinkle regarding plan of action collection letters

2/16/2010 1.90 855.00 Exchanging e-mails with Peter Walton and Garfinkle (.3); receive and review notice of electronic filing of orders continuing hearing to 2/19 (.3); email to M. Dunn regarding B. Elam's motion to appoint translator (.1); receipt and review of motion to dismiss adversary proceeding against south American Merendon entities (.4); discuss response with M. Lessne (.4); receipt of Hark's notice of appearance, receipt of deposition notices from Hark for Garfinkle and B. Mukamal (.3); email from A. Brodsk y regarding call from Milt Shlapak (.1)

2/18/2010 0.50 225.00 Telephone conference with Art Neiwirth, Adairs lawyer and email to him re: same

2/18/2010 8.00 3,600.00 Prep for hearing

2/18/2010 3.20 1,440.00 Exchanging e-mails with B. Elam regarding motion to appoint translator (.3); review Lessne's email to S. Khanorkar regarding charts showing money flow (.1); respond to and discuss same (1.2); emails with Art Neiwirth regarding Adair's cooperation and what is needed of him (.3); emails with Ken Iredale regarding case (.2); email to J. Armengol and Heidi Feinman regarding attending hearing on 2/19 (.1); review Heidi's response (.5); many emails with B. Elam, S. Khanorkar, Werner, B. Mukamal all re garding attendance at hearing (.5)

2/19/2010 7.00 3,150.00 Preparation for hearing, negotiations with Sorenson and counsel, attend hearing on extension of injunction and service issues and draft orders re: same

2/19/2010 1.90 855.00 Exchanging e-mails with B. Elam regarding his attendance at hearing and court ruling making translator unnecessary (.3); call from Chris Redmond in Kansas City (.5); receipt and review of correspondence from Chris Redmond (.7); emails with A. Brodsky and Lessne regarding uploading order on summary judgment hearing on 3/11 (.4)

2/21/2010 0.20 90.00 E-mails from James King transmitting many documents in Spanish regarding Merendon de Peru

2/22/2010 0.30 135.00 Telephone conference with Dave Badley of SEC

2/23/2010 0.70 315.00 Exchanging e-mails with Peter Walton (.2); forward proposed order on service to Hark, Werner, Neiwirth and copy team, including SEC people (.3); emails with A. Brodsky regarding Sentinel Mining information (.2)



2/23/2010 0.50 225.00 Telephone conference with Dave Baddley, SEC in Atlanta

2/24/2010 1.80 810.00 Exchanging e-mails with A. Brodsky regarding service of process on Nordic (.3); emails from Werner regarding proposed service order and information on Merendon de Peru (.3); emails back and forth with A. Brodsky and Lessne regarding changes to propos ed service order (.5); emails from Neiwirth regarding same and ongoing discussion regarding service on his client (.1); emails with office of John Henerson regarding his firm's claim and with A. Brodsky regarding same (.3); email regarding proposed a greed order amending injunction order (.3)

2/25/2010 0.30 135.00 Telephone conference with client re: chapter 15

2/25/2010 2.20 990.00 Exchanging e-mails with A. Brodsky regarding filing suggestions in Siskiyou County, CA - jurisdiction of Discovery Day Mine (.4); file Summons Service Executed on Nordic (.4); many back and forth with all parties regarding proposed agreed order amend ing injunction order, including Neiwirth and Sherrill-Beard of SEC (.6); review emails between A. Brodsky and John Henderson regarding his firm's proof of claim and service list; call to M. Dunn re: same (.5); email to Hark and Yon transmitting redli ned service order and agreed order for same (.3)

2/26/2010 1.20 540.00 Exchanging e-mails with A. Brodsky, Neiwirth, L. Hughes, Dave Baddley, Matt Yon - all regarding orders (1.2)

3/1/2010 0.70 315.00 Receipt and review of agreed order amending 1/27 order granting motion for substantive consolidation of non-debtor entities in the main and the adversary cases (.3); email to A. Brodsky regarding service (.1); emails with Mike Letsen, Esq. regarding filing claim as a foreign corp. (.3)

3/8/2010 1.20 540.00 Exchanging e-mails with Nicole Hilburn of Gus Pappas' office, and with Gus regarding proposed order on summary judgment motion (.6); emails with Art Neiwirth regarding language in para. 57 of order on summary judgment regarding Larry Adair's role (.6 )

3/9/2010 1.10 495.00 Exchanging e-mails with Art Neiwirth and his paralegal regarding order language and his appearance at summary judgment hearing (.2); emails with Pappas re: same (.3); email to D. Cimo, local counsel re: Shlapak (.1); receipt and review of fax letter from Art Neiwirth regarding hearing on 3/11 (.3); emails with A. Brodsky regarding order on motion to retain translator (.2)

3/10/2010 2.60 1,170.00 Exchanging e-mails with Pappas, Hark, Yon, Garfinkle regarding order on summary judgment motion - to be reviewed and to Neiwirth, Werner and team as well (.6); emails from Garfinkle and from Neiwirth regarding Adair with comments (.6); call from Garf inkle and from J.Bennett in CO (.6); send revised proposed order to everyone again (.2); emails with Nicole Hilburn regarding revisions to order (.3); emails with Werner regarding sale option for MDP (.3)

3/11/2010 0.60 270.00 Exchanging e-mails with Nicole Hilburn regarding revisions to proposed order (.3); and emails with Werner regarding sales (.3)



3/11/2010 5.00 2,250.00 Teleconference with Caldwell's attorneys (1.5); preparation for and attendance at summary judgment hearing (3.5)

3/12/2010 0.50 225.00 Exchanging e-mails with David Cimo (.2); receipt and review of order granting motion for partial summary judgment (.1); serve on everyone, including those in all jurisdiction where suggestions were filed (.1); email to creditor Alan Schlosser (.1)

3/13/2010 0.10 45.00 E-mail from Michael Mysak regarding notice of motion and hearing set for 3/18 in Canada before Judge Hawco

3/14/2010 0.20 90.00 E-mails from Garfinkle re: case

3/17/2010 5.80 2,610.00 Exchanging e-mails with Mike Mysak, Trish, M. Lessne regarding hearing, order, letter to Judge Hawco, etc. all in preparation for hearing in Canada in Nosratieh v. Strategic (.5); send draft letter to Judge Hawco to Chris Redmond and Greg Grossman fo r review (.2); file motion to extend automatic stay, motion to enforce, motion for clarification against automatic stay, motion for contempt, etc. (2.4); serve emergency motion on everyone involved: Bennett Jones, Gowlings, Quilling (2.3); emails wit h Christ Redmond, B. Elam, Trish regarding emergency motion and letter(.2); telephone conference with M. Dunn regarding same and trying to get motion heard (.2)

3/17/2010 6.00 2,700.00 Draft memorandum to Canadian court in response to receivers motion and draft motion to bankruptcy court re: same

3/18/2010 5.30 2,385.00 Email to Frank Dearlove with case information for his order (.1); receipt and review of notice of hearing on emergency motion (.3); Teleconference with A. Brodsky regarding drafting a notice of hearing of our own (as opposed to the court's hearing no tice) (.3), file it, serve it, file cert/service on both hearing notices (1.1); call from Garfinkle; emails with Tanya Frizzell at Gowling regarding their representation of Sorensen and some other Merendon entities (.4); emails with A. Brodsky regard ing service of motion and hearing notice on Hark (.3); receipt of notice of telephonic hearing on motion to extend automatic stay, etc. (.2); serve on all with motion (.3); receipt and review of order granting motion to continue pretrial conference, serve, forward to team, re-calendar (.7); email with Elam regarding phone attendance (.1); emails with Chris Redmond regarding hearing (.2); forward draft of proposed order on emergency motion to Quilling, Dearlove (.1); back and forth with Redmond re: same (.5); emails with A. Brodsky regarding Hawco's assistant, Gerald (.2); re-send draft order to all again after revisions (.2); emails with Dearlove re: same (.3)

3/18/2010 3.00 1,350.00 Telephonic hearing on stay issues as relates to Canadian proceeding before bankruptcy court (.5) draft order re: same and order re: Canadian proceeding (1.0) conference with Canadian receivers counsel (1.0); hearing before Canadian court re: same (.5)

3/18/2010 0.10 45.00 E-mail from Frank Dearlove giving go-ahead to file U.S. Order re: motions to extend automatic stay, enforce, clarification of automatic stay, contempt, damages for creditor misconduct, etc. in Nosratieh v. Strategic case in Canada



3/19/2010 0.50 225.00 Exchanging numerous e-mails with Frank Dearlove regarding protocol used in Trident and order from hearing of March 18, 2010 on our motions to extend automatic stay, enforce, clarification of automatic stay, contempt, damages for creditor misconduct, etc. in Nosratieh v. Strategic case in Canada

3/19/2010 2.20 990.00 Email to Garfinkle and from Ward Capstick (.2); receipt and review of order on emergency motion signed by court, serve and forward to team (1.1); discuss with A. Brodsky (.3); receipt and review of correspondence from Gus Pappas regarding obtaining p roperty and respond (.3); forward letter from Gus to team and Garfinkle (.2); forward B. Mukamal's affidavit to Pappas and Nicole Hilburn (.1)

3/20/2010 0.10 45.00 E-mail from S. Khanorkar regarding expectation of reports/deliverables in April in adversary proceeding

3/24/2010 0.20 90.00 E-mail to Werner regarding John Dupont, of Gloria Management's filing of a proof of claim in all of SGD's assets; email from creditor Aaron Taylor regarding claim

3/25/2010 0.90 405.00 Emails from M. Dunn regarding emails from Aaron Schmiedel about royalty interests (.3); emails from M. Lessne regarding disclosures (.3); exchange emails with creditor Aaron Taylor regarding claim (.3)

3/26/2010 0.20 90.00 Email from M. Lessne regarding disclosures (.1); email from A. Brodsky regarding new case to file suggestion in (.1)

4/8/2010 0.20 90.00 Receipt and review of emailed documents: transfers and corporate resolutions regarding Merendon de Peru, S.A. (not translated)

4/9/2010 0.90 405.00 Receipt and review of emails between A. Brodsky and US Bank regarding the bank's compliance with order on summary judgment (.2); emails with Garfinkle regarding recovery agency (.2); call and email from Richard Brodsky, coming into the adversary proc eeding on behalf of Nordic (.1); receipt of notice of appearance of Richard Brodsky (.2); receipt of motion to allow late filed claim from Douglas Kirkwood; draft and upload agreed order on same (.2)

4/13/2010 0.90 405.00 Receipt of filed agreed ex parte motion to extend time for pretrial conference and related deadlines filed by A.Brodsky (.1); emails from Graham regarding Structurists (.3); email to A. Brodsky to forward orders to Paul Butler (sub con and summary ju dgment) (.1); review order granting Brodsky's motion to extend pretrial (.2); emails with Werner regarding option on properties (.2)

4/21/2010 1.00 450.00 Conference call with Canadian receiver and his counsel

4/27/2010 1.70 765.00 Exchanging e-mails with A. Brodsky regarding call from Paul Garfinkle (.4); receipt and review of motion to allow late filed claim from Andrew Forster (.4); draft and upload agreed order granting same (.5); emails with A. Brodsky and M. Lessne and Ne iwirth regarding his filing of a notification of return of service (.2); emails with Neiwirth regarding same (.2)

5/13/2010 0.30 135.00 Emails with Richard Brodsky regarding his compensation memo and requiring trustee's approval



5/17/2010 0.70 315.00 E-mail from a Norman Wong regarding Sorensen owning Florida property (.1); email from Richard Brodsky forwarding draft joint motion allowing Nordic to retain counsel (.1); emails back and forth with S. Stirling and M. Lessne regarding service (.5)

5/18/2010 0.80 360.00 E-mail from Ward Capstick forwarding Google news articles on Brost and Sorensen (.1); emails with Garfinkle regarding the same and also regarding buyers (.2); response to Brodsky's motion and forward same to M. Dunn (.3); several emails with M. Dunn regarding articles and setting a status meeting (.2)

5/20/2010 0.50 225.00 Exchanging e-mails with A. Brodsky and team to set a status meeting

5/25/2010 0.50 225.00 (.10Receipt and review of entered order continuing pretrial conference to July 19th; forward it and filed motion to team (.1); serve both on all (.2); emails with Hark and Garfinkle (.1)

5/26/2010 0.30 135.00 Exchanging e-mails with Werner regarding Ecuador (.2); email to Garfinkle (.1)

6/1/2010 0.90 405.00 Telephone call from Paul Garfinkle re: case (.3); exchanging emails with B. Elam regarding J.Bennett (.2); review other emails regarding same (.2); emails with Ken Iredale (.2)

6/2/2010 1.90 855.00 Exchanging e-mails with M. Dunn, B. Elam, A. Brodsky regarding Discovery Day and J.Bennett

6/2/2010 1.00 450.00 Telephone with Paul re: case (.3); telephone with Paul and M. Dunn and B. Elam re: same (.2); follow-up telephone with M. Dunn, telephone with M. Dunn and B. Elam (.2); telephone with B. Elam M. Dunn and J. Armengol @ US Trustee's office (.3)

6/3/2010 0.30 135.00 Receipt and review of a pleading in the Christinansen v. Chevy Chase Bank case in AZ from M. Dunn's office

6/3/2010 0.20 90.00 E-mails with Mike Letsen, Esq. regarding case (he represents a group of investors)

6/5/2010 0.20 90.00 E-mails with M. Dunn regarding possible brokers she found for mines

6/7/2010 0.40 180.00 E-mail from M. Dunn regarding obtaining DD police report from Garfinkle and drafting stay violation motion (.2); emails with Susant regarding motion to compel to Hark and Brodsky's request for a few extra days to respond to interrogatories (.2)

6/8/2010 1.40 630.00 Exchanging numerous e-mails with team regarding June 9th meeting on Discovery Day and case status (1.4)

6/9/2010 1.50 675.00 Conference with client and B. Elam, S. Khanorkar and B. Mukamal re: case administration

6/10/2010 0.40 180.00 Exchanging e-mails with S. Stirling regarding motion to compel to Hark and getting started on interim fee application


6/11/2010 4.40 1,980.00 Draft status memo (3.9); telephone with L. Hughes SEC attorney (.5)



6/11/2010 0.60 270.00 Telephone calls received on cell from Mike Orenstein and L. Hughes of the SEC, Denver

6/29/2010 0.50 225.00 Telephone conference with L. Hughes of SEC re: their action and coordinating actions

7/1/2010 4.50 2,025.00 Telephone conference with opposing counsel: Hark and Sakalo (.6), and with M. Dunn, J. Armengol and Garfinkle each regarding motions and hearings for today (.9); draft and revise agreed orders (.3); email exchange with counsel regarding same (.2); tr avel to and attendance at hearing (2.5)

7/6/2010 0.70 315.00 Receiving and reviewing NEF of Notice of Appearance of Sakalo for Fagen, Gruden, American Sierra Gold and Trinity Alps Resources (.2); receipt and review of notice of compliance from Cliff Hark (.2); email from Gus Pappas (.1); emails with Garfinkle regarding Google Alerts he sent regarding Milo Brost criminal matters (.2)

7/21/2010 0.70 315.00 Telephone conference with Laura Hughes of SEC

8/10/2010 2.00 900.00 Preparing for, travel to, attend, return from hearing on Nordic's motion regarding expense for attorney

8/30/2010 0.10 45.00 Draft suggestion of bankruptcy in colorado

9/2/2010 0.50 225.00 Attending status conference in colorado litigation on glory hole

9/7/2010 3.00 1,350.00 Telephone with SEC Counsel L. Hughes regarding SEC injunctive action in Washington (.5), review complaint, motion for injunction, draft answer and consent to injunction and injunction (2.5)

9/22/2010 0.10 45.00 Receipt and review of Agreed Motion for Preliminary Injunction v. Capstick in SEC case

9/23/2010 0.20 90.00 Receipt and review of Order Denying Motion for Default as to Defendant Syndicated Gold Depository (.1); and Agreed Motion for Preliminary Injunction v. Werner - both in SEC case (.1)

10/21/2010 0.60 270.00 E-mails between Blaine Schwabe and John Malesovas

10/22/2010 0.30 135.00 E-mails to and from Suzanne Wilton

10/25/2010 0.10 45.00 Receiving and reviewing Order Granting Motion for Relief from Stay by Southbank

11/29/2010 0.10 45.00 SEC v. Merendon- receipt and review of REply to Response to Motion to Dismiss

11/29/2010 1.00 450.00 Telephone conference with SEC and counsel re all matters plus injunction their claim and disgorgement issues

11/29/2010 0.20 90.00 Receipt and review of the motion calendar

11/30/2010 0.30 135.00 tele with Matt Medvey lawyer in calgary re claims bar deadline

11/30/2010 1.00 450.00 Review and revise Joint report with SEC in SEC case

11/30/2010 0.40 180.00 SEC v. Merendon- Emails and from L. Hughes

12/1/2010 0.10 45.00 Receipt and Review of Notice of Reservation of Rights



12/1/2010 0.10 45.00 Receipt and Review of Joint Status Report

12/2/2010 0.20 90.00 E-mails to and from F. Santos

12/6/2010 0.10 45.00 Receipt and Review of Correspondence from Larry Coupal

12/8/2010 0.10 45.00 Receipt and Review of Correspondence Letter Sent from Andrea Madigan (Case # 09 CV 96) in regards to compact disk containing documents

12/8/2010 0.10 45.00 Receipt and Review Plainitffs' response to Motion for Adjudication Under C.R.C.P. 12 (b) Filed by the Estate of Robert F. Barnes Case # 09 CV 96

12/22/2010 0.50 225.00 Phone conference with Mr. Elliot Rockler

12/30/2010 0.50 225.00 Status memo to client

1/3/2011 0.30 135.00 Conference call with S. Solomon re: case.

1/13/2011 0.40 180.00 E-mails between Dana Quick and M. Lessne

1/18/2011 0.30 135.00 E-mails between M. Dunn and M. Lessne

1/31/2011 0.50 225.00 Telephone Conference R. Schatzman and M. Lessne

3/10/2011 1.00 450.00 Call with L. Hughes of SEC

5/2/2011 0.30 135.00 Telephone conference with Cliff Hark

5/2/2011 2.00 900.00 Telephone conference with Cliff Hark re hearing on withdrawal (.3), review various orders (.3), draft orders (.4), emails from hark, and motions to withdraw (.3); attend hearing on withdrawal (.7)

5/4/2011 0.50 225.00 Email to and from and review and revise proposed order on Hark's withdrawal as counsel

5/31/2011 0.30 135.00 Receipt and review of Motion to Withdraw as Attorney by Defendant Ward K. Capstick.

6/3/2011 0.20 90.00 Receipt and review of an email from M. Dunn requesting status of the case.

6/3/2011 0.30 135.00 Receipt and review of an Amended Order on Motion to Withdraw as Counsel of Record.

6/6/2011 0.20 90.00 Receipt and review of Notice of Unavailability from 06/13/2011 to 06/17/2011 by Attorney Martin L Hannan, Esq.

6/7/2011 0.20 90.00 Receipt and review of an email from A. Srour to Sean Doyle regarding wiring information.

6/7/2011 0.20 90.00 Receipt and review of emails between A. Srour and Alexandra Castro regarding wiring information.

6/9/2011 0.20 90.00 Emails with Adam Katz regarding Andrea Madigan's December 3 email.

6/9/2011 0.20 90.00 Receipt and review of Notice to Withdraw of Notice of Unavailability Filed by Creditor Clearwater Mining Corporation.



6/9/2011 0.20 90.00 Receipt and review of emails between A. Srour and Cheryl Bennett regarding unloading pleadings to Gray Robinson's Merendon Mining website

6/9/2011 0.30 135.00 Receipt and review of an email from Alison MacGregor regarding Merendon Mining Ponzi scheme from a reporter at the Montreal Gazette newspaper and how it relates to another Ponzi scheme targeting Canadians

6/10/2011 0.10 45.00 Receipt and review of an email from Paul Garfinkle re: case

6/10/2011 0.20 90.00 Emails with Alison MacGregor regarding conference call.

6/14/2011 0.20 90.00 Receipt and review of an email from Alison MacGregor regarding the merendon ponzi scheme.

6/15/2011 0.30 135.00 Emails with Alison MacGregor regarding BRA (Werner)

6/20/2011 0.20 90.00 Emails with Robert Osborne regarding interview with Canadian Television Show, W5.

6/21/2011 0.20 90.00 Receipt and review of Notice of Change of Address for Attorney John A. Moffa.

6/28/2011 0.20 90.00 Emails with Alison MacGregor

6/28/2011 0.20 90.00 Receipt and review of an email from M. Dunn re: Merendon properties in Jamestown.

6/28/2011 0.20 90.00 Receipt and review of an email from M. Lessne to M. Dunn re: Current Status of Case.

6/28/2011 0.60 270.00 Receipt and review of and revise status report for trustee and email from Mike and M. Dunn re same

6/29/2011 0.60 270.00 Emails with Alison MacGregor as well as reviewing a Supreme Court Order.

6/29/2011 0.30 135.00 Receipt and review of Minute Order by Richard A. Jones, United States District Judge.

6/29/2011 0.20 90.00 Emails with Mike Letsen, Esq. with Parklane group of investors re: case update.

7/5/2011 0.30 135.00 Receipt, review and reply to email form Alison MacGregor regarding Belize court ruling.

7/5/2011 0.20 90.00 Receipt and review of and email from Alison MacGregor regarding 2008 report submitted by Quilling to an Alberta court found Merendon assets.

7/8/2011 0.40 180.00 Receipt and review of an email from Joseph Murphy enclosing SEC’s Notice of Deposition for Brad Regier.

7/11/2011 0.20 90.00 E-mails with clients regarding availability for a conference call.

7/11/2011 0.20 90.00 Receipt and review of emails re: status of case.

7/11/2011 0.30 135.00 Receipt and review of Notice of Taking Deposition of Bradley Regier.

7/15/2011 0.20 90.00 Emails with client regarding David Murray.

7/19/2011 0.20 90.00 Receipt and review of an email from Arthur C. Neiwirth re: hearing on 7/21/11.



7/19/2011 0.20 90.00 Receipt, review and reply to an emil from Jason Welt.

7/20/2011 0.20 90.00 Emails with Arthur C. Neiwirth, Esq. regarding hearing and call-in information.

7/20/2011 0.30 135.00 Telephone conference with Barbara re telephonic hearing

7/21/2011 7.00 3,150.00 Conversation with Art neiwirth re pretrial (.3), conversation with court's calender clerk re administrative matters regarding hearing (.3), preparation for (4.4), travel to and from and attendance at multiple hearings today (2.0)

7/22/2011 0.20 90.00 E-mail to clients regarding the hearing on 7/21/11

7/22/2011 0.20 90.00 E-mail to client regarding conference call with John Moffa.

8/4/2011 0.20 90.00 Receipt and review of an email from Angela Fiorentino re: hearing date.

8/4/2011 0.40 180.00 Receipt and review of an email from Ashley Ochoa enclosing sanction against Leslie Taylor representing Merendon Mining (Colorado).

8/8/2011 0.20 90.00 Reviewing and responding to e-mail from Barbara Cargill with Judge A. Jay Cristol re: hearing dates.

8/9/2011 0.30 135.00 Receipt and review of an email from Alexandra Castro attaching correspondence from Kristen Philbrook.

8/17/2011 0.30 135.00 Receipt and review of an email from Polly A. Atkinson enclosing MM Nevada Consent.

8/18/2011 0.20 90.00 Receipt and review of an email from Paul Garfinkle re: interview with Robert Osborne of CTV5

8/19/2011 0.50 225.00 Reviewing and responding to e-mails from Paul Garfinkle.

8/19/2011 0.20 90.00 Receipt and review of an email from J. Cartagena enclosing Notice of Filing for review.

8/19/2011 0.20 90.00 Reviewing and responding to e-mail from Paul Garfinkle re: logistics of Monday's TV taping from Canadian Television.

8/24/2011 0.30 135.00 Reviewing and responding to e-mail from Alison MacGregor re: Merendon de Ecuador.

8/24/2011 0.30 135.00 Receipt and review of Notice of Change of Address for B. Elam.

8/28/2011 0.20 90.00 Receipt and review of an email from John Moffa to Martin Hannan.

9/5/2011 0.30 135.00 E-mail from Paul Garfinkle regarding MMNI Bankruptcy Proceeding with enclosed Orders.

9/6/2011 0.20 90.00 Emails with Marica Dunn re Paul Garfinkle's email on the MMNI Bankruptcy Proceeding.

9/6/2011 0.20 90.00 Emails with Alison MacGregor regarding Merendon de Ecuador.



9/7/2011 0.20 90.00 E-mails from Paul Garfinkle re Belize Decisions.

9/7/2011 0.50 225.00 Additional e-mails with Paul Garfinkle re Belize Decisions.

9/8/2011 0.30 135.00 Telephone conference with Mary Dartis producer from canadian television show

9/9/2011 0.30 135.00 E-mails with J. Cartagena and M. Lessne regarding the Substantive Consolidation Order (main case)

9/12/2011 0.30 135.00 E-mail from A. Srour enclosing Notices of Unavailability to review and approve for filing.

9/13/2011 0.20 90.00 E-mails with J. Cartagena and A. Srour regarding phone conversation with Barbara Cargill at Judge Cristol's chambers.

9/13/2011 0.20 90.00 Emails with Biff Marshall and Lisa Novak regarding write offs.

9/15/2011 0.20 90.00 E-mails with M. Dunn regarding attendance at the hearing on September 27, 2011.

9/19/2011 0.20 90.00 E-mails with Charles Gryba regarding contact.

9/19/2011 0.20 90.00 Emails with Jason Welt regarding the hearing on Sep. 27, 2011.

9/20/2011 0.50 225.00 Telephone conference with Brent Baker.

9/26/2011 0.10 45.00 Review of an email from J. Cartagena to Paul Garfinkle confirming that the hearing is scheduled for September 26, 2011.

9/26/2011 0.10 45.00 Receipt and review of an email from A. Srour to Sean Doyle regarding appearing at hearing scheduled for September 27, 2011 by phone.

9/26/2011 0.20 90.00 E-mails with S. Khanorkar regarding B. Mukamal's attendance at the hearing scheduled for September 27, 2011.

9/27/2011 7.60 3,420.00 Telephone with J. Armengol (.3); preparation for hearings (3.0); telephone with Worldwide's counsel meachem (.3); travel to and attenance at hearing on 9019 and 363 sale (4.0)

10/5/2011 0.20 90.00 E-mails with Jodi Rubin regarding report of W5.

10/6/2011 0.10 45.00 E-mail from Jason Welt regarding setting a conference call.

10/14/2011 0.30 135.00 Telephone conference with Judge Cristo's JA regarding hearing date.

10/17/2011 0.10 45.00 E-mail from M. Dunn re the filing of Paul Garfinkle's Complaint

10/17/2011 0.10 45.00 E-mails with M. Dunn re the letter to Don Walton and Steve Turner.

10/20/2011 0.20 90.00 E-mail from John Moffa to M. Dunn enclosing Trustee's authorization for signature.



10/21/2011 0.30 135.00 E-mail to Steve Turner re Response to your letter concerning Paul Garfinkle's complaint.

10/21/2011 0.10 45.00 E-mail to M. Dunn enclosing Letter in response to the Garfinkle's complaint.

10/25/2011 2.50 1,125.00 Draft status report and letter to US Trustee in response to garfinkle complaint

10/25/2011 0.20 90.00 E-mails between John Moffa and M. Dunn re statment of authorization.

10/26/2011 0.10 45.00 E-mail from Alexandra Castro to Steve Turner enclosing Trustee’s response letter.

10/29/2011 0.10 45.00 E-mail from Steve Turner confirming receipt of the Response to your letter concerning Paul Garfinkle's complaint.

11/1/2011 0.10 45.00 E-mail to Maria Spyroum regarding the status of the case.

11/8/2011 0.10 45.00 E-mail to Mr. Kitzman re case status.

11/9/2011 0.20 90.00 E-mails with Imtiaz Lakhani re status of the case.

11/10/2011 0.30 135.00 E-mails with Steve Turner re response letter.

11/10/2011 0.10 45.00 E-mail from Alexandra Castro enclosing executed Disclaimer of Interest.

11/11/2011 0.20 90.00 E-mails with Marica Dunn re preparing a supplemental response.

11/16/2011 0.10 45.00 Receipt and review of an email from Alexandra Castro to Steve Turner enclosing Trustee’s response letter.

11/16/2011 0.20 90.00 E-mail to M. Dunn enclosing a follow up letter to Steve Turner concerning marketing efforts and the values of the property.

12/20/2011 0.10 45.00 E-mail from J. Cartagena re follow up Letter to Don Walton and Steve Turner 11-16-11.

1/6/2012 0.20 90.00 E-mails with Tong Li and Barry Gorssman re update on the case.

1/10/2012 0.10 45.00 Reviewing e-mail from Jason Welt.

1/13/2012 0.20 90.00 Emails with M. Lessne and M. Dunn re summary of the case.

1/19/2012 0.20 90.00 E-mails with Robert Meacham re order approving sale of the mines.

1/25/2012 0.30 135.00 E-mail from and to Andre LaBauve and Sarah Williams re Merendon Closing

1/25/2012 3.00 1,350.00 Attending deposition of Larry L. Adair

1/26/2012 0.20 90.00 Receipt and review of Trustee's Interim Report.

2/7/2012 0.10 45.00 E-mail from Paul Garfinkle re Trustee's Meeting.

2/27/2012 2.00 900.00 Preparation for, travel to and from and attendance at pretrial conferences in two adversary cases under litigation.





10/2/2009 0.20 90.00 E-mail to all regarding call with Ward Capstick, and regarding Sorenson's arrest

10/5/2009 0.20 90.00 E-mails from Paul Garfinkle regarding invoice for Alberta Ltd. tax year 2009

10/7/2009 0.90 405.00 Receipt and review of 9 Proofs of Claim

10/7/2009 1.10 495.00 Receipt and review of multiple e-notifications of claims filed

10/9/2009 0.20 90.00 E-mail with creditor Josie Byington re: claim

10/12/2009 0.20 90.00 E-mail (x2) from creditor, John Nelson regarding proof of claim

10/12/2009 0.10 45.00 Receipt and review of email from investor, John Nelson

10/13/2009 0.10 45.00 Reviewing e-mail from investor, Daniel Reichert

10/13/2009 1.50 675.00 Exchanging multiple e-mails with L. Negron and A. Brodsky regarding calls from many investors, proofs of claim needed, and other investor-related questions

10/13/2009 0.90 405.00 Telephone conferences each with with investor/creditors, Daniel Reichert, Melanie Sears and Kurt Kienitz

10/14/2009 0.40 180.00 Receipt and review of email from investor, Dawn Abel (.2); emails with investor, Josie Byington (.2)

10/14/2009 2.60 1,170.00 Receipt and review of 26 Proofs of Claims

10/15/2009 0.20 90.00 Emails from A. Brodsky regarding calls from investors: Gregg Grover and Eddie Scarborough

10/15/2009 0.20 90.00 Receipt and review of filed proofs of claim

10/15/2009 0.60 270.00 Telephone conferences with creditors Eddie Scarborough and Gregg Grover

10/16/2009 0.10 45.00 E-mail from A. Brodsky regarding call from Calgary Herald

10/16/2009 0.80 360.00 Receipt and review of multiple filed claims (.8)

10/19/2009 0.50 225.00 Receipt and review of filed claims, filed trustee's statement, and notification from court of 341 meeting being held and concluded

10/22/2009 0.10 45.00 E-mail from A. Brodsky regarding call from Ward Capstick

10/23/2009 0.10 45.00 E-mail to A. Brodsky regarding investor, Tim Carlson

10/27/2009 0.30 135.00 Exchanging e-mails with Paul Garfinkle regarding Strategic Metals, claiming loss, Canadian company status, etc.

10/28/2009 0.30 135.00 Exchanging e-mails with Melanie Smendziuk and Hartmut Bielous, investors

10/29/2009 0.10 45.00 E-mail from investor, Melanie Smerdziuk



10/30/2009 0.30 135.00 Exchanging e-mails with A. Brodsky, L. Negron and investor, Melanie Smendziuk, regarding Proof of claim

11/3/2009 0.20 90.00 E-mail from A. Brodsky transmitting creditor information for return call and and email from Alex Castro with address change for Nolan Hoyme (creditor)

11/5/2009 1.30 585.00 Receiving and reviewing multiple Proofs of Claim

11/6/2009 0.10 45.00 Receiving and reviewing Proof of Claim

11/9/2009 0.40 180.00 Receiving and reviewing Proofs of Claim (.2); emails with A. Brodsky regarding call from J.Bennett in Colorado (.1); and regarding calling Sonia Ray (creditor) (.1)

11/12/2009 1.20 540.00 Receiving and reviewing multiple Proofs of Claim

11/13/2009 5.10 2,295.00 Receiving and reviewing many Proofs of Claim (4.8); emails with A. Brodsky regarding creditor, Leonid Gsirlin (.3)

11/17/2009 0.10 45.00 E-mail from A. Brodsky regarding Paul Garfinkle call

11/19/2009 0.50 225.00 Exchanging e-mails with A. Brodsky regarding creditor, Sonia Roy

11/30/2009 2.80 1,260.00 Receiving and reviewing multiple Proofs of Claim (2.5); emails with A. Brodsky regarding call from creditor, Susan Braun (.3)

12/1/2009 0.30 135.00 Emails with A. Brodsky regarding creditor phone call

12/5/2009 0.20 90.00 Review emails from A. Brodsky to Creditors with POC and other questions

12/8/2009 0.80 360.00 Receipt and review of multiple Proofs of Claim filed

12/9/2009 0.30 135.00 Take call from creditor re: claims and case

12/10/2009 0.50 225.00 Receipt and review of multiple Proofs of Claim filed (.5)

12/14/2009 0.10 45.00 Review email from A. Brodsky to creditor re: Claim

12/14/2009 2.80 1,260.00 Receipt and review of multiple Proofs of Claim filed

12/21/2009 0.60 270.00 Receipt and review of multiple Proofs of Claim filed (.4); review email from A. Brodsky to creditor (.2)

12/24/2009 0.30 135.00 Telephone with Oral Pascal investor re: proof of claim

12/28/2009 2.80 1,260.00 Receipt and review of multiple Proofs of Claim filed (2.4); take creditor call (.3); email to all re: tall yof claims thus far: 192 (.1)

12/29/2009 3.10 1,395.00 Receipt and reveiw of multiple Proofs of Claim filed

12/30/2009 3.00 1,350.00 Receipt and review of multiple Proofs of Claim filed; email from A. Brodsky regarding calls from creditors.

1/4/2010 0.90 405.00 Receipt and review of 5 proofs of claim (.5); emails back and forth with A. Brodsky regarding creditor calls about filing proofs of claim (.4)

1/5/2010 0.50 225.00 Receipt and review of Order Conditionally Granting Ex Parte Motion to Establish Limited Notice and discuss same with A. Brodsky and L. Negron (.2); several calls from creditors regarding filing proofs of claim (.3)



1/6/2010 0.80 360.00 Exchanging many emails with A. Brodsky regarding creditor calls and with creditors regarding case and filing of proofs of claim;

1/6/2010 1.90 855.00 Telephone conference with creditor Daniel Reichert (.3), Susie Stevens (.3) and Paul Bentley (.3); numerous emails with Ken Iredale re: claims (.9); email from Armengol regarding research for claims administration (.1)

1/6/2010 0.30 135.00 Telephone conference with creditor Susie Stevens re: claims

1/8/2010 0.10 45.00 Receipt and review of proof of claim from creditor

1/8/2010 1.90 855.00 Telephone conference with creditor Alan Lehman (.3) and Dirk Farrell (.3) separately; many emails with Paul, B. Elam, R. Schatzman regarding various claims issues (.6), including call again from Werner, hearing preparation (.3), Calgary Herald link ( .1); review A. Brodsky's emails to several creditors (.3)

1/11/2010 3.90 1,755.00 Receipt and review of proofs of claims from 39 creditors

1/11/2010 1.40 630.00 Teleconference with creditor, Kyle Roat regarding POC (.5); review A. Brodsky's many emails to creditors (.9)

1/12/2010 0.10 45.00 Email with Bill Lennon (creditor)

1/13/2010 1.70 765.00 Receipt and review of 17 proofs of claims

1/13/2010 0.30 135.00 Receipt and review of 3 proofs of claim

1/14/2010 2.40 1,080.00 Exchanging e-mails with many creditors regarding proofs of claim (.4); Martin Werner transferring his proposed changes to order (.3); with L. Negron and A. Brodsky regarding filing proofs of claim (.4); receipt and review of Voluntary Statement from creditor Rober Perry (.4); J. Armengol, USDOJ, Arthur Niewirth, the Agency - all regarding various aspects of the case, order language, website (.9)



1/19/2010 0.20 90.00 Telephone conference with creditor, Katherine Christianson



1/22/2010 0.90 405.00 Receipt and review of correspondence from investor, Roger Soucy (.6); exchanging emails with Nate Mancuso and Ji Hun Kim regarding foreign service (.3)


1/25/2010 0.60 270.00 Receipt and review of Motion to Allow Late Filed Claim(s) by Paul Morgan (.3); calls and emails from creditors: Dawn Abel, Kelly Crowley; call from Kim Barta, referred by Werner re: same (.3)

1/26/2010 4.20 1,890.00 Receipt and review of 42 proofs of claims;

1/26/2010 0.10 45.00 E-mail from Kelly Crowley regarding filing proof of claim late



1/27/2010 1.20 540.00 Receipt and review of notice of hearing on motion to allow late filed claims for 2/9/10 (.6); emails with creditors, Paul, A. Brodsky (.6)

1/27/2010 3.20 1,440.00 Receipt and review of 32 proofs of claim

1/28/2010 2.90 1,305.00 Receipt and review of 29 proofs of claim

2/2/2010 0.20 90.00 Emails from creditor Jack Broderick (.2)




2/5/2010 0.80 360.00 Teleconference with Andrea and creditor Cole Rheal regarding claim.



2/17/2010 0.30 135.00 Telephone conference with creditor Gail Coopey

2/17/2010 0.30 135.00 Receipt and review of claim filed

2/19/2010 0.30 135.00 Telephone conference with Mike Litson, attorney for Parkland Group, creditor of Syndicated Gold Depository

2/23/2010 0.40 180.00 Review emails between A. Brodsky and creditors, Larry and Sally Coupal

2/26/2010 1.30 585.00 Emails with A. Brodsky and creditor, Roy Renneberg and attention to matter re: same (1.3)

3/1/2010 0.30 135.00 Telephone conference with Alan Lehman re: claims

3/3/2010 0.20 90.00 Emails with Mike Letsen regarding extending claims bar date

3/4/2010 0.20 90.00 Receipt and review of filed claims

3/5/2010 0.60 270.00 Emails with Shaye O'Donnell, creditor

3/16/2010 0.10 45.00 Email to creditors Peacock and Crowley re: claims

3/18/2010 4.10 1,845.00 Receipt and review of many filed proofs of claim (3.6); receipt and review of several claims filed (.5)

3/19/2010 0.40 180.00 Exchanging e-mails with creditors, the Brodericks

3/21/2010 0.30 135.00 Exchanging emails with Jack Broderick, creditor, regarding status of case

3/22/2010 0.20 90.00 Review A. Brodsky's email with creditor, Jack Broderick

3/23/2010 0.20 90.00 Exchanging e-mails with Nicole Hilburn regarding proof of claim

3/25/2010 0.40 180.00 Receipt and review of claims

3/26/2010 0.30 135.00 Receipt and review of filed claims (.2); email to creditor regarding claim filing (.1)




3/30/2010 1.30 585.00 Receipt and review of filed claims (.5); emails with S. Khanorkar regarding financial reports requested of Hark for south American entities (.4); emails with A. Brodsky regarding claims questions from several creditors who invested in other companies associated with MM. (.4)

4/1/2010 1.70 765.00 Receipt and review of many filed claims

4/7/2010 0.20 90.00 Receipt and review of motion to allow late filed claim by Richard Thorlakson (.1); review draft order on same and upload to court (.1)


4/12/2010 0.50 225.00 Receipt and review of signed agreed order on Thorlakson's motion to file claim late (.3); emails with Gayle Aspery of US Bank regarding accounts which are subject of summary judgment motion (.1); receipt and review of Richard Brodsky's draft agreed m otion to postpone pretrial conference and associated deadlines (.1)

4/13/2010 0.70 315.00 Receipt and review of filed claims (.5); receipt of signed agreed order on Kirkwood's motion to allow late filed claim (.1); call from Richard Brodsky (.1)

4/14/2010 0.10 45.00 Receipt and review of Agreed Order Granting Creditor Larabee Capital Inc., Douglas Kirkwood's Motion to Allow Late Filed Claim

4/15/2010 0.20 90.00 Exchanging e-mails with creditor Walter Forster regarding filing claim

4/20/2010 2.70 1,215.00 Receipt and review of many filed claims (2.4); exchange emails with S. Stirling regarding information not forthcoming from Hark (.3)

4/22/2010 1.10 495.00 Exchanging e-mails with S. Stirling regarding follow up with Hark (.2); receipt of motion to allow late filed claim from Brenda Renrick, Janet Heim, Kyle Roat (.2); emails with A. Brodsky regarding same (.2); draft and upload agreed orders on the mot ions to file claims late (.4); review email from creditor Dennis Blanchard (.1)

4/23/2010 0.50 225.00 Receipt and review of signed orders on motions to allow late filed claims filed by Roat, Heim and Renrick (.3); emails with Mike Letsen, Esq. regarding concessions coming due at Peru property (.2)

4/29/2010 0.40 180.00 Receipt and review of motion to allow late filed claim from Richard and Janet Simmons (.1); draft and upload agreed order on same (.1); receipt of signed agreed order (.1); email to creditors (.1)

4/30/2010 0.80 360.00 Receipt and review of motion to allow late filed claim from Donald Fulton and Walter Forster (.3); draft and upload agreed orders on same (.3); emails with S. Stirling regarding defendants to re-serve and Hark still not being responsive (.2)

5/4/2010 0.40 180.00 Receipt and review of agreed orders on motions to allow late filed claims filed by Forster and Fulton

5/10/2010 0.90 405.00 E-mails from creditor Forster regarding late filed claim acceptance (.3); exchange emails with Garfinkle and Werner regarding Clearwater Mining and Glory Hole Mine (.3); receipt of three proofs of claim (.3)



5/11/2010 0.10 45.00 Receipt and review of e-filed Motion to Allow Late Filed Claim by creditor, Lin Cao

5/12/2010 0.20 90.00 Receipt and review of order granting motion to allow late filed claim of creditor, Lin Cao

5/14/2010 0.30 135.00 Telephone conference with Joseph Davies, Esq. regarding competing claim of his client re: Glory Hole mine

5/26/2010 0.30 135.00 Telephone conference with Katy Carter, wife of Kim Barta, creditor of Park Lane

6/1/2010 0.20 90.00 Review A. Brodsky's email to creditor

6/3/2010 0.50 225.00 Telephone conference with Dan McCauley, counsel for a creditor (.3); receipt and review of letter from creditor, Zelo, form M. Dunn's office (.2)

6/3/2010 0.30 135.00 Telephone conference with Dan McCauley, counsel for creditor

6/7/2010 0.20 90.00 Receipt and review of a proof of claim

6/15/2010 1.20 540.00 Exchanging e-mails with creditors regarding claim filing and with Garfinkle

6/18/2010 0.20 90.00 Receipt and review of proofs of claim

7/6/2010 0.30 135.00 Telephone conference with Dana Kinsman, investor creditor

7/18/2010 0.30 135.00 Exchanging e-mails with F. Santos regarding Garfinkle's claim in Glory Hole

8/3/2010 0.50 225.00 Telephone conference with Dan Mccauley, attorney for investor

8/6/2010 0.30 135.00 Telephone conference with Dana Kinzman, creditor

8/19/2010 0.90 405.00 Receipt and review of multiple proofs of claim (.3); emails with S. Stirling and Mike re Norm Frank's equipment (.3); transmit SEC's proof of claim to M. Dunn (.3)

8/20/2010 0.70 315.00 Exchanging e-mails with Ken Iredale, creditor, re case status

9/13/2010 0.30 135.00 Telephone conference with Debbie Gisonni, creditor

10/28/2010 0.80 360.00 Telephone call from and with an investor/creditor re proof of claim late filing (.3); telephone call with Mike Morrison (.5) re Discovery Day and settlement re same

12/21/2010 0.50 225.00 Telephone conference with and email to and from Ben Stang creditor

1/3/2011 1.00 450.00 Reviewing and Revising Proof of Claims

2/25/2011 0.30 135.00 Telephone with investor creditor

2/26/2011 0.30 135.00 Telephone with investor creditor

5/5/2011 0.30 135.00 Telephone conference with creditor Ken Ireland regarding status of case and claims

5/9/2011 0.30 135.00 Telephone conference with lawyer for late filing claimant



6/29/2011 1.00 450.00 Telephone with John Moffa re settlement of Caldwell claims

8/24/2011 0.20 90.00 Receipt and review of an email from A. Srour re: Christen Philbrook.

8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour re: call from Radvena LaVern from Arizona.

8/28/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Tracey Andersen re: Claim No 639 - Deemed timely filed.

9/1/2011 0.30 135.00 E-mails with Kyle Roat,with Kyle Roat & Associates regarding swindled Merendon Mining investors.

9/12/2011 0.30 135.00 E-mails with John Moffa regarding the Notice to Withdraw Claim filed by Interested Parties Estate of Harold Caldwell.

9/13/2011 0.10 45.00 Receipt and review of an email from John Moffa re Trustee's Objection to Claim No. 482.

9/13/2011 0.50 225.00 Prepared a Trustee's Objection to Claim No. 482.

9/13/2011 0.10 45.00 E-mail to Paul Garfinkle enclosing Trustee's Objection to Claim No. 482.

9/13/2011 0.10 45.00 E-mail to John Muffa enclosing Trustee's Objection to Claim No. 482.

9/13/2011 0.10 45.00 E-mail to client enclosing Trustee's Objection to Claim No. 482.

9/22/2011 0.20 90.00 E-mail from Robert Meacham asking to provide him with information and documents regarding the claims.

9/22/2011 0.10 45.00 E-mail from Charles Gryba a mining engineer from Toronto re claims in Colorado.

9/23/2011 0.30 135.00 Review of Notice of Filing Receipt of Garfinkle's answer.

9/23/2011 3.00 1,350.00 Receipt and review of Garfinkle's response to cliams objection (1.0); telephone with Hannan (.5), telephone with Moffa (.5); multiple emails with each regarding and receipt of clearwater's continuance motion (1.0)

9/26/2011 0.50 225.00 Receipt and review of Paul Garfinkle's Answer to Joint Response to Garfinkle’s Obj to 9019 Motion.

9/29/2011 0.30 135.00 Receipt and review of Proof of Claim.

10/4/2011 0.30 135.00 Telephone call to Jones Watters with Kitzman Trucking

10/11/2011 0.20 90.00 Emails with Imtiaz Lakhani re Claim for Capital loss.

10/31/2011 0.10 45.00 E-mail from A. Srour re call from Mike Stangl re: True North Production Company.

11/22/2011 0.10 45.00 E-mail from A. Srour re phone call from Anna Bennett asking about her Husband J. Bennett's salary from working at the Black Rose mine.

12/28/2011 0.10 45.00 Reviewing e-mail from Sharon Roberts Creditor.



12/28/2011 0.10 45.00 Receipt and review of emails between M. Lessne and Tracey Andersen re Proof of Claim.



6/11/2009 0.10 40.00 Receipt and review of Marcum Rachlin's retainer letter to M. Dunn

6/11/2009 0.30 120.00 Telephone conference with S. Khanorkar re: retention

6/12/2009 0.70 280.00 Exchanging e-mails with L. Negron and Maria Fernandez receiving executed engagement letter and application for employment, and with L. Negron regarding filing and uploading Order regarding same (x3)

6/16/2009 0.20 80.00 Receipt and review of e-filed Ex Parte Application to Employ B. Mukamal as Financial Advisors and receipt and review of e-filed Ex Parte Application to Employ I. Reich and GrayRobinson as Counsel Nunc Pro Tunc to June 11, 2009

6/17/2009 0.20 80.00 Receipt and review of Orders Approving Employment of I. Reich and GrayRobinson, and B. Mukamal

7/16/2009 1.30 520.00 Telephone with M. Dunn re: hearing tomorrow on B. Elam's retention (.5); emails with J. Ryan regarding her retention (.4); emails with M. Dunn regarding 7/20 conference call (.4)

7/17/2009 0.40 160.00 Exchanging e-mails with R. Schatzman regarding 7/20 call with creditors (.2); receive and review Order granting B. Elam's employment and discuss B. Elam's role with him (.2)

7/21/2009 1.30 520.00 Exchanging e-mails with L. Negron regarding Arizona property search results (.4); with B. Elam and R. Schatzman regarding 7/20 conference call and Garfinkle and creditor comments (.4); with Maureen Bondor regarding investors (.5)

9/16/2009 0.20 90.00 Exchanging multiple e-mails with S. Khanorkar regarding B. Mukamal's affidavit and bank account review (.2)

9/18/2009 0.50 225.00 Multiple e-mails with S. Khanorkar regarding B. Mukamal's affidavit and to Nate Mancuso regarding complaint (.2); with R. Schatzman, M. Dunn, J. Ryan, B. Elam, L. Negron and A. Brodsky regarding filing Mukamal affidavit (.3)

7/12/2010 0.30 135.00 Review M. Lessne's email to Fisher Auction and M. Dunn transmitting application for approval of employment of auctioneer and proposed order granting same and affidavit of auctioneer.

10/17/2011 0.10 45.00 E-mail from S. Khanorkar re Marcum fee application.

11/14/2011 0.50 225.00 E-mail from Jazmin Padilla enclosing B. Mukamal’s fee application

11/22/2011 0.50 225.00 E-mail from S. Khanorkar enclosing Marcum fee application.

11/28/2011 0.20 90.00 Emails with Frank P. Terzo re Fee Application.



12/20/2011 0.30 135.00 Reviewing of the breakdown per Activity Code for the Fee App.

12/21/2011 0.50 225.00 Reviewing of first draft of the Fee Application along with the exhibits.



7/16/2009 2.00 800.00 Conference with B. Mukamal, R. Schatzman and S. Khanorkar re: discovery issues

9/9/2009 0.20 90.00 Emails with Pearson and L. Negron regarding state of Washington summary judgment and with M. Dunn regarding ditch rights (.2)

9/18/2009 0.20 90.00 Multiple e-mails with Nate Mancuso regarding Complaint (.2)

12/1/2009 2.60 1,170.00 Exchanging e-mails with P. Wagner regarding drafting of complaint, and motion for substantive consolidation and injunctive relief (.3); discuss complaint (.8); send Paidge document links regarding Watchers and others (.1); emails with all regarding s tatus of complaint in response to B. Elam's email regarding status of mines (.8); emails with all regarding Gold Basin, complaint, investors, and emails from Les Taylor (.6)

12/2/2009 0.50 225.00 Exchanging e-mails with all transmitting adversary complaint for review and comment, and need to locate defendants' addresses (.2); email with Paul Garfinkle regarding need for addresses of defendants (.1); telephone conference with L. Negron regardi ng no need for filing motion to defer filing fee (.2)

12/3/2009 0.50 225.00 Exchanging e-mails with all regarding adding wife and ex-wife of Brost and Sorenson (.3); with Paul Garfinkle and S. Khanorkar regarding addresses and Les Taylor's phone number (.2)

12/4/2009 1.60 720.00 Exchanging e-mails with P. Wagner regarding complaint and with S. Khanorkar regarding address on coloro poster from Garfinkle (.7); with all, including B. Elam and S. Khanorkar regarding comments and revisions to complaint and injunction motion (.7), and receipt of S. Khanorkar's redlined changes to complaint (.2)

12/8/2009 0.40 180.00 Emails to all regarding breadth of complaint/who to add as defendants

12/9/2009 0.30 135.00 Exchanging e-mails with P. Wagner, S. Khanorkar, R. Schatzman, Jason Burnett all regarding draft injunction motion, revisions, complaint, and hearing date

12/10/2009 0.40 180.00 Emails with Paige regarding revisions to adversary complaint.

12/11/2009 1.00 450.00 Exchanging e-mails with all, including Paul, sending motion for review, and instructions for exhibits, etc., to L. Negron and A. Brodsky (.3); emails from Paul regarding Werner and Adair addresses and P. Wagner to add to complaint (.3); email from M. Dunn signing off on complaint (.1); emails with P. Wagner regarding adding more defendants to complaint (.3)



12/14/2009 0.70 315.00 Review multiple emails with S. Khanorkar, Paige and all others regarding addresses of defendants

12/15/2009 1.20 540.00 Exchanging e-mails with A. Brodsky, L. Negron, and S. Khanorkar regarding SGD exhibit to complaint (.5); receipt of e-filed Adversary Complaint [D.E. 1] (.1); [D.E. 65 in main case; emails with L. Negron regarding entry of defendants into CM/ECF syst em (.6)

12/17/2009 1.40 630.00 Exchanging e-mails with Rosy Lopez regarding Ponzi scheme story (.3); transmit complaint and motion to her (.3); emails with B. Elam, et al. regarding motion (.3); receipt and review of e-filed injunction motion [D.E. 3 in adv. case]; [D.E. 66 in mai n] (.3); emails from M. Dunn regarding motion (.3)

12/18/2009 1.00 450.00 Receipt and review summonses and pretrial order, and calendering deadlines re: same, and receipt of notice of hearing on injunction and consolidation motion

12/18/2009 1.30 585.00 Exchanging e-mails with A. Brodsky and L. Negron regarding summonses, service, mailing, etc. (.3); receipt of Summons Issued on all Defendants [D.E. 4] (.1); receipt of Order Setting Filing and Disclosure Requirements for Pretrial and Trial, etc. [D. E. 5] (.1); receipt of Notice of Hearing on Motion [D.E. 67 in main case] (.1); review emails from A. Brodsky to all transmitting Motion for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of Estate and Injunctive Relief in bot h adversary and main cases (.7)

12/22/2009 0.80 360.00 Exchanging e-mails with Paul and S. Khanorkar regarding The Agency and addresses (.6); receipt and review of e-filed hearing notice on motion (.2)

12/25/2009 0.50 225.00 Exchanging e-mails with A. Brodsky and L. Negron regarding summonses, service, mailing, etc.

12/27/2009 1.10 495.00 Exchanging e-mails with L. Negron and A. Brodsky regarding summonses to be served

12/28/2009 0.40 180.00 Exchanging e-mails with L. Negron regarding service of summonses

12/28/2009 1.00 450.00 Transmit complaint filed to Matt Galioto, Jeff Simpson, Scott Fuller, Dave Smiley, and Jay Scoggins (.3); email complaint and motion to various persons at The Herald (.2); many emails with L. Negron regarding missing summonses and addresses to defend ants (.5)

12/31/2009 0.20 90.00 Receipt and review of Order Conditionally Granting Ex Parte Motion to Establish Limited Notice [D.E. 74] (.1); email from A. Brodsky regarding creditor call (.1)

1/6/2010 1.70 765.00 Telephone conference with R. Schatzman (.3); with B. Mukamal (.3); with J. Ryan (.3) with J. Armengol (.3) and conference call with R. Schatzman, B. Mukamal, S. Khanorkar, and B. Elam (.5) all re: hearing next week on substantive consolidation



1/6/2010 3.50 1,575.00 Telephone conference with Martin Werner (.7); emails with L. Negron, A. Brodsky, Cheryl Bennett, Rosy Lopez regarding posting documents to website (.8); emails with all regarding conference call about call received by Werner (.6); send SGD promissory note to A. Brodsky for inclusion in hearing documents and follow-up re: same (.7); receipt, review and transmission to L. Negron information to obtain search warrants in Alberta Canada from Ken Iredale (creditor) (.5); exchange multiple emails with Ken Iredale after forwarding motion, Garfinkle Declaration and Mukamal Affidavit to him (.2)

1/14/2010 0.70 315.00 Telephone conferences with Martin Werner and Katherine Christianson

1/18/2010 0.30 135.00 Exchanging e-mail with Cliff Hark regarding status of order

1/20/2010 0.30 135.00 Receipt and review of Notice of Continued Hearing set for 1/25/10 (.1); email to all requesting attendance at hearing (.1); email from Ward Capstick forwarding copies of wires and Sorenson deposition transcript from Canada case (.1)

1/25/2010 0.60 270.00 Exchanging e-mails with M. Lessne regarding filing Sorenson deposition transcript and report of the RCMP (.3); receipt and review of filing notice of same (.3)

1/25/2010 0.30 135.00 Telephone conference with class action lawyers

1/26/2010 0.20 90.00 receipt and review of correspondence from Arthur C. Neiwirth, Esq. informing of his representation of Larry Adair

1/26/2010 0.80 360.00 Telephone conference with Ward Capstick x 2

1/27/2010 0.60 270.00 Receipt and review of notice of filing copy of affidavit of Gary Sorenson and Charles Blakey by Clifford Hark

1/28/2010 0.50 225.00 Receipt and review of 2 orders on substantive consolidation

1/28/2010 8.20 3,690.00 Receipt and review of Order Granting Motion for Substantial Consolidation of Non-Debor Entities, Granting Motion for Turnover of Property, Denying Motion for Preliminary Injunction in main and adversary cases (2.0) ; email to all transmitting Order a nd discussing service issues and next steps (2.0); telephone conferences with Michelle Khouri, Maylyn Vargas, Cheryl Bennett regarding press release and posting Order to website (1.0); telephone conference with Paul regarding Order and counsel in oth er jurisdictions (1.0); with Ji Hun Kim in Miami office regarding foreign service issues (1.0); with John Henderson regarding suggestions of bankruptcy, and with Karen Fujita regarding case (1.0)

1/28/2010 0.10 45.00 Transmit to two creditors the SubCon order in the adversary proceeding and the main case

1/29/2010 5.50 2,475.00 Exchanging many emails with Ken Iredale, Terzo, L. Negron, Rosy Lopez, A. Brodsky, Paul, Rick Shor, John Henderson, Michelle Khouri, Maylyn Vargas regarding case, press release, creditor calls, website, service of process on foreign entities, suggest ions (5.3); receipt and review of Trustee's Report for the Period Ending 12/31/09 (.2)



1/30/2010 0.70 315.00 Exchanging e-mails with Ken Iredale, Paul, Rick Shor, B. Elam

1/31/2010 0.30 135.00 E-mails with Terra Finial, Ken Iredale, Kristen Wegel - creditors

2/1/2010 0.30 135.00 Telephone conference with Sorenson's counsel re: depositions

2/1/2010 0.30 135.00 Telephone conference with Sorenson's counsel Hark

2/3/2010 0.90 405.00 E-mails from Ward Capstick regarding Nordic registered agent and addresses (.3); with M. Lessne regarding draft motion for partial summary judgment and proper service in Belize (.3); and from Lloyde Simmons, creditor (.3)

2/5/2010 0.10 45.00 E-mail from Art Neiwirth

2/8/2010 0.30 135.00 Telephone conference with SEC counsel Elizabeth Krupa

2/8/2010 6.00 2,700.00 attend deposition of Paul Garfinkle taken by Sorenson's lawyer

2/9/2010 0.30 135.00 Telephone conference with Nordic's lawyer peter Walton

2/10/2010 0.30 135.00 Telephone conference with SEC counsel (.3)

2/10/2010 3.00 1,350.00 Attend depo of our financial advisor

2/11/2010 7.00 3,150.00 Prepare for hearing on injunction and attendance at same 95.0) including meetings with US Trustee (.5), Paul Taylor (.4), Martin Werner (.4), Cliff Hark (.4), and draft order on continuing hearings (.3)

2/12/2010 0.80 360.00 Telephone conference with Sorenson's counsel

2/12/2010 0.30 135.00 Telephone conference with martin Werner

2/16/2010 0.30 135.00 Telephone conference with Paul Taylor

2/17/2010 4.10 1,845.00 Exchanging e-mails with M. Lessne regarding response to motion to dismiss filed by south American merendon entities (.3); emails with M. Dunn and B. Elam regarding translator motion (.8); emails with team regarding Milt Shlapak (.8); review M. Lessne 's amendment to motion to serve certain foreign defendants by certified mail (1.1); file same (.2); review email from L. Hughes, SEC Denver (.1); emails to A. Brodsky and M. Lessne regarding same (.8)

2/17/2010 8.00 3,600.00 Review documents and prep for hearing

2/18/2010 1.00 450.00 Conference with Garfinkle re: hearing

2/18/2010 3.60 1,620.00 telephone with Seth Levine, Larry Adair's criminal counsel (1.1); telephone with Martin Werner (1.0); telephone with Cliff Hark x 2 (1.5) all re: hearing tomorrow

2/22/2010 0.80 360.00 Receipt and review of order setting hearing on motion for summary judgment for 3/11/10 at 11:00 and notice of filing Exhibit A to motion for summary judgment regarding opposing motions for summary judgment (.2); serve on Hark, Werner, Neiwirth (.1); review transcript of 2/19 hearing sent by court reporter (.1); emails with Art Neiwirth (.2); call from Dave Baddley of SEC in Atlanta (.1); email with Kirsten Wegel regarding recordation of orders (.1)



2/23/2010 2.00 900.00 Receipt and review of transcript of Paul Garfinkle deposition from 2/8/10

2/24/2010 5.00 2,250.00 Drafting orders re: agreed order amending injunction order and order re: service of process

2/25/2010 1.50 675.00 Telephone conference with Cliff Hark and Matt on revising 3 orders on service and injunctions

2/26/2010 0.30 135.00 Telephone conference with Art Neiwirth, Adairs counsel re order

3/3/2010 1.50 675.00 Telephone conference with Nicole of Pappas office (.5) and counsel of Caldwell heirs (.5) and telephone with Gus Pappas re: same (.5)

3/3/2010 1.00 450.00 Telephone call from Milt Shlapak regarding meeting (.1); emails with A. Brodsky regarding same (.2); receipt and review of orders on service (.3); forward to team and serve all parties with order amending 1/27 order granting motion for substantive co nsolidation of non-debtor entities and order on service (.1); post both to website (.1); emails with Garfinkle regarding address for Sentinel Mining and add Sentinel to style and service list (.2)

3/4/2010 0.30 135.00 Telephone call from Gus Pappas (.2); email from M. Lessne regarding Belizian entities (.1)

3/5/2010 0.90 405.00 E-mails and calls with Garfinkle regarding Recovery Pool and my call with Gus Pappas and Glory Hole (.6); emails with Nicole Hilburn in Gus Pappas' office (.3)

3/6/2010 0.30 135.00 E-mail from Hark regarding Eiger's address (.1); emails with Garfinkle regarding Glory Hole's ownership interest (.2)

3/8/2010 0.40 180.00 Receipt and review of letter emailed from Arthur Neiwirth regarding motion for partial summary judgment (.1); respond to same (.1); review email from B. Elam from Les Taylor and receipt of email from B. Elam, both regarding Gold Basiin (.2)

3/10/2010 10.00 4,500.00 Preparation for hearing on motion for summary judgment, plus research and drafting, reviewing and revising proposed order re: same (5.0), including emails and conversations to interested parties for their comments and changes (5.0)

3/10/2010 0.10 45.00 Receipt and review of email from Art Neiwirth transmitting revised draft motion for partial summary judgment with redline changes

3/15/2010 1.00 450.00 Exchanging e-mails with Bennet Jones regarding hearing and motion in Nosratieth v. Strategic case in Canada (.2); email to M. Lessne regarding motion and order proposing to continue pretrial conference and all deadlines for one month (.2); email to c reditor Gail Coopec regarding claim (.1); review letter to US Bank transmitting order on summary judgment and their compliance with same regarding accounts (.2); discuss with A. Brodsky (.1); call from Richard Linde (purchaser) and Garfinkle (.2)



3/16/2010 3.20 1,440.00 Exchanging e-mails with A. Brodsky regarding Canadian hearing (.2); telephone conference with M. Lessne regarding motion to continue pretrial conference and deadlines (.5); email to Hark regarding same (.1); meeting with A. Brodsky regarding letter t o US Bank re: compliance with order on summary judgment (.7); forward same to team (.1); with M. Lessne and A. Brodsky regarding letter needed to go to Judge Hawco in Canada regarding proper service to Quilling (.5); review draft letter from M. Less ne (.5); review summons service executed for Strategic c/o Quilling (.2); receipt and review of agreed motion to continue pretrial conference set for 3/22 and associated pretrial deadlines for one month (.2); emails with S. Khanorkar regarding S.A. e ntities not providing monthly operating reports; review S. Khanorkar's email to Hark regarding same (.2)

3/20/2010 0.20 90.00 E-mails with Mike Mysak transmitting two orders and regarding advice and direction in Nosratieh v. Strategic

3/22/2010 0.10 45.00 Receipt and review of correspondence from Gus Pappas regarding rights and claims to property

3/22/2010 0.50 225.00 Respond to S. Khanorkar regarding reports for April (.2); email with A. Brodsky regarding re-serving initial pleadings on south American entities that Hark wont accept service (.1); emails with M. Lessne regarding initial disclosures in adversary pro ceeding (.2)

3/23/2010 0.60 270.00 Emails with A. Brodsky regarding US Bank's compliance with summary judgment order and recording summary judgment order in mine jurisdictions (.2); emails with M. Lessne regarding initial disclosures (.2); call from Garfinkle re: case (.2)

4/5/2010 0.30 135.00 Receipt and review of fax from Katherine Christensen regarding her Arizona case against Chevy Chase Bank and regarding her emergency motion for tro to halt trustee sale and hearing on same set for 4/6 (.1); discuss my attendance by phone with A. Brod sky (.1); after review of motion, my attendance is not necessary and discuss with A. Brodsky re: same (.1)

4/6/2010 1.00 450.00 Exchanging e-mails with A. Brodsky and M. Lessne regarding filing and serving Initial Disclosures

4/9/2010 0.50 225.00 Telephone conference with Richard Brodsky, counsel for Nordic Merchant

4/13/2010 0.10 45.00 Receipt and review of Agreed Ex Pare Motion to Extend Pretrial Conference and Other Associated Pre-Trial Deadlines

4/16/2010 0.60 270.00 Exchanging e-mails with Quilling regarding entities' appeal of receivership (.2); set conference call regarding joint ch. 15 in both jurisdictions with Quilling (.2); serve order on motion to extend pretrial on all for Brodsky and file cert/service f or same (.2)

4/21/2010 0.60 270.00 Exchanging e-mails with B. Mukamal regarding pretrial and other deadline extensions in adversary proceeding (.2); call from Garfinkle (.20; emails with Hark and S. Stirling (.2)



4/28/2010 2.50 1,125.00 Exchanging many emails with M. Lessne, S. Stirling and A. Brodsky regarding re-service of certain south American defendants and Hark's refusal to cooperate regarding same

5/3/2010 0.20 90.00 Exchanging e-mail with S. Stirling and A. Brodsky regarding addresses for re-service of pleadings

5/4/2010 0.10 45.00 Reviewing Interrogatories prepared by S. Stirling to Nordic

5/4/2010 0.30 135.00 Receipt and review of emails between S. Stirling and US Embassy in Belize regarding addresses for re-service

5/4/2010 2.00 900.00 Exchanging e-mails and telephone conference with S. Stirling regarding interrogatories regarding foreign corps. certs of service (.8); emails with S. Khanorkar, regarding reports still not received (.3); emails and telephone conference with S. Stirli ng about contacting Hark (.8); and email with A. Brodsky regarding call from Joe Davies about Glory Hole mine (.1)

5/5/2010 0.70 315.00 Exchanging e-mails with S. Stirling regarding finalizing interrogatories and getting them served on Hark and south American defendants

5/6/2010 0.10 45.00 E-mail from S. Stirling regarding Merendon Belize

5/6/2010 0.20 90.00 Exchanging e-mails with S. Stirling regarding Richard Brodsky's discovery query

5/6/2010 0.80 360.00 Exchanging e-mails with S. Stirling regarding south American defendants' addresses (.4); emails from A. Brodsky and forward to Werner regarding Joe Davies' claim regarding Glory Hole (.4)

5/12/2010 0.30 135.00 Telephone call from Richard Brodsky, Nordic's counsel (.2); emails with S. Stirling regarding service on South American entities (.1)

5/21/2010 0.40 180.00 Receipt and review of a draft motion for continuance of pretrial and proposed order from A. Brodsky (.1); file ex-parte motion to continue pretrial (.1); discuss with court (.1); receive email from M. Dunn's office transmitting hearing notice in the Christiansen v. Chevy Chase Bank case in AZ (.1)

6/3/2010 0.20 90.00 Emails with S. Khanorkar regarding expert disclosures

6/6/2010 0.20 90.00 E-mails with S. Stirling regarding answers to interrogatories propounded to Hark and Brodsky (.1), and drafting motion to compel Hark to answer (.1)

6/9/2010 0.40 180.00 Exchanging e-mails with S. Stirling regarding motions to compel to Hark and Sorensen (.4)

6/10/2010 1.70 765.00 Receipt and review of SEC's complaint from L. Hughes (.4); forward SEC complaint to team and Werner, Garfinkle, Neiwirth, and Hark (.4); attention to matters re: same (.9)

6/11/2010 9.80 4,410.00 Exchanging e-mails all day regarding filing motion to compel and stay violation motion (1.2); revise, discuss, file, forward to team, serve on parties (8.6)

6/11/2010 1.70 765.00 Review, revise and draft motion to compel (1.3); emails with M. Lessne, A. Brodsky, S. Stirling regarding filing stay violation motion and motion to compel (.4)



6/14/2010 0.60 270.00 Receipt and review of notice of hearing on stay violation motion (.3); forward to team and serve on all others (.3)

6/16/2010 0.50 225.00 Exchanging e-mails with Richard Brodsky regarding Nordic (.2); receipt and review of Siskiyou Daily article about Discovery Day explosion (.20; email to the Brodericks (investors) (.1)

6/20/2010 0.10 45.00 E-mail from Mike Letsen, Esq. regarding update and SEC case

6/21/2010 0.40 180.00 Exchanging e-mails with Jay Sakalo regarding Trinity Alps, American Sierra Gold, Patrick Fagan and Wayne Gruden

6/21/2010 0.80 360.00 E-mail from Art Neiwirth regarding pretrial participation (.2); serve motion to compel (.2); email with Richard Brodsky regarding motion to compel (.2); emails with Werner regarding Assignment of Bahama Resource Stock (.2)

6/21/2010 0.10 45.00 Receiving and reviewing correspondence from Arthur Neiwirth regarding continuation of pretrial and participation in preparation for trial

6/28/2010 0.50 225.00 Telephone conference with Cliff Hark and email to him regarding settlement, service of process, and lack of financial reporting from south America

6/29/2010 1.90 855.00 Exchanging e-mails with Jay Sakalo, M. Lessne regarding draft order granting motion for sanctions (.6); with Cliff Hark regarding addresses still needed and other issues discussed previously still outstanding (.6); with L. Hughes of the SEC regarding accepting service, my appearance pro hac vice in Washington State, and asset administration (.7)

6/30/2010 3.80 1,710.00 Exchanging e-mails with M. Lessne, A. Brodsky, M. Dunn, and Jay Sakalo regarding DD and agreed order resolving motion for sanctions (.7); to M. Lessne regarding Sorenson orders (one with agreement, one without) (.1); telephone conference with L. Hugh es of the SEC (.3); emails with Hark regarding draft agreed order on motion to compel (.7); receive NEF of Agreed Ex Parte Motion to Continue Pretrial; forward to team (1.0); forward to defendants and counsel; emails with L. Hughes of the SEC regardi ng waiving service (1.0)



7/1/2010 3.90 1,755.00 Exchanging e-mails with Mike Letsen, Esq. regarding update on case for Parklane Group (.3); emails with Jay Sakalo regarding Trinity stay order (.3); emails from/to Patrick Fagen regarding Discovery Day GL policy (.3); emails with Cliff Hark regardin g agreed order on motion to compel (.3); telephone conference with A. Brodsky regarding receipt of SEC complaint, and agreement on stay order and uploading same to court, and status of hearing on the matter (.4); telephone conference with A. Brodsky and M. Dunn regarding agreed order on motion to compel to be uploaded (.3); receipt and review of NEF of Agreed Order Resolving Motion for Violation of the Automatic Stay, and Motion for Sanctions against Trinity, et al. (.2); serve and forward to te am (.3); file certificate of service (.1); receipt and review of motion to withdraw Agreed Ex Parte Motion to Continue Pretrial Conference indefinitley (.4); serve on all adversary counsel (.2); review A. Brodsky's email to counsel regarding any obje ctions to continuing pretrial for 60 days (.2); emails with Lessne and A. Brodsky regarding filing of motion to continue pretrial for 60 days and order upload on same (.3); receipt and review of NEF of Agreed Order Granting Motion to Compel Certain D efendants to Comply with Agreed Order Dated February 26, 2010 and Answer Interrogatories Served on May 5, 2010 (.3)

7/2/2010 1.00 450.00 Receipt and review of NEF of Order Continuing Pretrial hearing to 9/20/10 (.1); serve (.1); forward to team (.1); file certificate of service (.3); email from Hark transmitting letter with additional addresses (.1); emails with Garfinkle regarding Di scovery Day ownership issues (.3)

7/6/2010 0.60 270.00 Telephone conference with Cliff Hark regarding Sorenson and receipt and review of Hark's letter containing addresses for Sorenson and S.A. entities (.6)

7/8/2010 0.30 135.00 Emails with M. Lessne and A. Brodsky regarding re-service of South American defendants (.3)

7/8/2010 0.10 45.00 Receiving and reviewing copy of correspondence from Garfinkle to Clerk of Gilpin County Courts re: case no. 09cv96 (.1)

7/9/2010 0.30 135.00 Telephone conference with opposing counsel, Richard Brodsky, regarding Nordic Merchant Credit Union

7/12/2010 1.00 450.00 Telephone with Brodsky and review and revise Nordic agreement

7/12/2010 0.10 45.00 Receiving and reviewing copy of correspondence from Garfinkle to Judge Berryhill and Clerk of Gilpin County Courts re: case no. 09cv96 transmitting Answer of Garfinkle and Sentinel Mining

7/12/2010 0.20 90.00 Exchanging e-mails with Richard Brodsky and M. Lessne regarding Agreed Motion to Permit Nordic's Expenditure of Funds for Legal Representation (.2)

7/13/2010 1.10 495.00 Emails and teleconference with A. Brodsky and M. Lessne regarding re-service to South American defendants

7/15/2010 0.20 90.00 Receiving and reviewing NEF of Agreed Motion to Permit Expenditure of Funds by Nordic (.1); forward same to team (.1)

7/17/2010 0.30 135.00 Exchanging e-mails with L. Hughes regarding SEC v. Merendon case



7/22/2010 0.20 90.00 E-mail from and reply to Ward Capstick re SEC defaults

7/23/2010 0.40 180.00 Receiving and reviewing NEF of Notice of Hearing on Nordic's Agreed Motion to Permit Expenditure of Funds (.1); email with A. Brodsky re: same (.1); post to website (.1)

8/3/2010 1.00 450.00 Exchanging e-mails with L. Hughes, SEC, regarding waiver of service of summons and complaint (.3); emails with S. Stirling regarding Mucker equipment sale motion, and with Les Taylor regarding same (.3); with S. Stirling regarding title issues (.4)

8/10/2010 0.20 90.00 E-mails with A. Brodsky regarding SEC v. Merendon service waiver

8/17/2010 0.40 180.00 Exchanging e-mails with S. Stirling and Mike regarding complaint and adding defendants

8/23/2010 0.20 90.00 Reviewing e-mail from Mike to Mike at Venture law transmitting Agreed Order Resolving Trustee's Motion for Violation of the Automatic Stay and Sanctions Against Trinity Alps, et al. (.1); review email from Mark Levin (.1)

8/23/2010 0.10 45.00 Reviewing e-mail from Martin Werner re representation of SGD in SEC case

8/24/2010 1.10 495.00 Receipt and review of SEC complaint from L. Hughes (.4); emails with Mike and A. Brodsky regarding Wabuska and insurance from Fagan or his counsel (.5); email from John Moffa, counsel to Estate of Caldwell re CO and TX cases and motion for stay relie f (.1); email from Jay Sakalo re draft agreed motion to vacate subcon and partial summary judgment (.1)

8/25/2010 1.50 675.00 Exchanging e-mails with A. Brodsky and Garfinkle re status conference call in CO and TX cases of Caldwell v. Barnes (1.2); email with A. Brodsky re query from creditor as to case status (.3)

8/26/2010 0.40 180.00 Reviewing e-mail from A. Brodsky to all counsel in adversary proceeding re continuing pretrial (.2); discuss with A. Brodsky (.2)

8/26/2010 0.50 225.00 Telephone conference with John Moffa, counsel for Caldwell estate re stay releif motion

8/26/2010 0.50 225.00 Draft motion and order on continuance of pretrial

8/27/2010 0.40 180.00 Exchanging e-mails with A. Brodsky regarding continuance motion in adversary proceeding

8/30/2010 0.30 135.00 Receipt and review of filed Agreed Ex Parte Motion to Continue Pretrial Conference (.1); forward to Cheryl for posting to website (.1); forward to counsel (.1)

8/31/2010 0.40 180.00 Receipt and review of Order Granting Ex Parte Motion to Continue Pretrial (.2); forward to Cheryl to post to website (.1); email with Jay Sakalo re draft of Agreed Motion to Vacate Subcon and Partial Summary Judgment (.1)

8/31/2010 0.20 90.00 Receipt and review of order continuing pretrial and service of same



9/1/2010 1.20 540.00 Telephone conference with SEC counsel L. Hughes re SEC litigation (.4); emails with L. Hughes re case (.4); and emails with Matt Kramer at Bilzin transmitting changes to agreed motion to vacate (.4)

9/2/2010 0.20 90.00 Exchanging e-mails with Garfinkle re SEC case (.2)

9/9/2010 1.80 810.00 Exchanging e-mails with A. Brodsky and Kathy Savarin in Stan Beck's office regarding notice of appearance in SEC v. Merendon case in Washington state (.4); receipt and review of Stan's notice of appearance (.2); receipt of filed application to appear pro hac vice and our filed Answer to the SEC's complaint (.4); forward to M. Dunn (.2); receipt and review of agreed motion to vacate subcon and partial summary judgment (.2); discuss with Matt and Jay regarding same (.4)

9/10/2010 1.10 495.00 Receipt and review of SEC's response to Werner's Motion to Dismiss (.4); emails with Matt Kramer at Bilzin re agreed amended motion to vacate (.3); receipt and review of filed Agreed Amended Motion to Vacate Subcon and Partial Summary Judgment (.3); forward same to M. Dunn (.1)

9/13/2010 0.40 180.00 Receipt and review of: Agreed Motion to Vacate SubCon and Partial SJ against Discovery Day, American Sierra, et al. (.1); Agreed Amended Motion to Vacate (.1); and notice of hearing on the Agreed Amended Motion to Vacate (.1); transmit revised Asset purchase agreement and amended sale motion to H. Winderman (.1)

9/14/2010 1.60 720.00 Exchanging e-mails with Mike re objection to stay relief (.3); email to Jay Sakalo re meeting between clients and mediation (.1); telephone conference with A. Brodsky re filing objection, serving, posting to website (.3); emails from L. Hughes re dra ft consent to permanent injunction and forward to M. Dunn (.3); review A. Brodsky's email to translator re Request for Service Abroad (Venezuela) (.3); attention to matter re: same (.3)

9/16/2010 0.80 360.00 Exchanging e-mails with Garfinkle regarding new pretrial conference (.4); emails with Mike and S. Stirling re complaint status (.4)

9/17/2010 0.60 270.00 Exchanging e-mails with S. Stirling and Mike re complaint, and with M. Dunn re insurance and police report still not received

9/20/2010 0.20 90.00 Receipt and review of Sorenson's response to SEC complaint (.1); receipt and review of Stipulated Motion for Entry of Preliminary Injunction Against Adair (.1)

9/20/2010 0.10 45.00 Receipt and review of Sorenson's response to SEC complaint

9/21/2010 0.50 225.00 Telephone conference with L. Hughes of SEC

9/22/2010 0.20 90.00 Receipt and review of stipulated motion for entry of preliminary injunction v. Capstick in the SEC case v. Merendon (.2)

9/24/2010 1.70 765.00 Conference call with L. Hughes, et al. from the SEC re consent to injunction



9/24/2010 0.70 315.00 Receipt and review of Reply filed by SEC to respond to Motion for Preliminary Injuction v. Merendon Mining, et al. (.3); multiple emails with Polly Atkinson, et al of SEC regarding the reply they filed (.4)

9/28/2010 1.00 450.00 Conference call with SEC re SEC v. Merendon case pretrial conference

9/28/2010 0.80 360.00 Telephone conference with Barbara Cargill, Courtroom Deputy, re motion for stay relief and hearing on same and certificate of no response re same (.4); telephone call with Cheryl Kaplan, Law Clerk, and Matt Kramer re agreed order and hearing on same (.4)

9/29/2010 0.30 135.00 Telephone conference with Judge Cristol and Matt Kramer re amended agreed motion to vacate subcon and partial summary judgment

10/1/2010 0.10 45.00 Receiving and reviewing of Motion of Southbank for Relief from the Automatic Stay

10/6/2010 0.10 45.00 Receiving and reviewing correspondence from Arthur Neiwirth re case v. Larry Adair

10/7/2010 0.30 135.00 Telephone conference with Trish Redmond, counsel for Barnes

10/20/2010 0.30 135.00 E-mails to and from Bonnie Frank

11/5/2010 0.60 270.00 Receipt and review of motions for extension of time to respond to adversary complaint filed in Dunn v. Clearwater, et al. from the Estate of Harold Caldwell, Dawn Fedrigon, individually and as Executrix of the Estate of Harold Caldwell, and Michael F edrigon, Worldwide Rental, and William Kemper and Marjorie Robbins Daggett (.3), and receipt of Orders Granting all three (.3)

11/15/2010 0.30 135.00 telephone with Rob Reed attorney representing defendant

12/14/2010 0.10 45.00 Receipt and review of Summons and Notice of Pretrial/Trial in an Adversary Proceeding

12/14/2010 0.10 45.00 Receipt and review of Adversary Complaint for a Declaratory Judgment to Determine the Validity, Extent, and Priority of any Liens, Claims, Excumbrances, and Interests in the Colorado Mining Properties, Including Interests of Anyone Laying Claim to he Estate's Rights and Interests in Such Properties

3/3/2011 0.30 135.00 Receipt and review Initial Disclosure of Witnesses and Documents of Defendant, Clearwater Mining Company [De 79]

4/7/2011 1.00 450.00 Review revise and draft and file discovery day

5/5/2011 0.30 135.00 Receipt and review of order approving settlement re discovery day (.1), and prepare certificate of service of same (.1), and serve same (.1)

6/3/2011 0.30 135.00 Receipt and review of Amended Order on Motion to Withdraw as counsel of record by Clifford Hark (re: Dunn v. Brost et al)

6/6/2011 0.20 90.00 Receipt and review of an email from N. Nicole to Robert Meacham regarding Production to Worldwide.



6/6/2011 0.20 90.00 Receipt and review of emails between N. Nicole and Linda Raymond regarding Production of Worldwide.

6/6/2011 0.20 90.00 Receipt and review of an email from M. Lessne to N. Nicole regarding Worldwide.

6/14/2011 0.30 135.00 Emails with N. Nicole and M. Lessne regarding Production to Worldwide.

6/14/2011 0.20 90.00 Receipt and review of an email from N. Nicole to Linda Raymond and Robert Meacham regarding Worldwide's Production.

6/15/2011 0.30 135.00 Receipt and review of emails between N. Nicole to Emma Bartling regarding Production to Worldwide.

6/16/2011 0.30 135.00 Receipt and review of an Order Continuing Pretrial Conference re Complaint filed by Plaintiff M. Dunn.

6/16/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue Hearing On Amended Complaint (Dunn v. Clearwater)

6/17/2011 0.30 135.00 Emails with Chris Hinks regarding Merendon Mining and SGD and Gary Sorenson and Martin Werner.

6/20/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Emma Bartling and N. Nicole regarding Merendon Production to Worldwide and Due Diligence Package to Buyer.

6/21/2011 0.50 225.00 Telephone with Brett Amron re request for admissions (.3); review emails from him and attachments and email to him re same (.2)

6/21/2011 0.40 180.00 Receipt and review of an email from Brett Amaron enclosing his clients’ RFAs and your responses.

6/21/2011 0.60 270.00 Telephone conference with Brett Amrom - counsel for William Kemper re responses to request for admissions, and review same

6/28/2011 0.30 135.00 Receipt and review of an email from M. Lessne enclosing Preliminary Factual Statement In Connection With The Trustee’s Consent To Injunctive Relief Herein

6/30/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Deputy Robinson regarding Summary Judgment awarded to Trustee.

7/6/2011 0.30 135.00 Receipt and review of an email from A. Srour to Mr. Meacham enclosing Plaintiff's Answer to Worldwide Rental Services, Inc.'s First Set of Interrogatories (Dunn v. Clearwater Mining Company)

7/8/2011 0.30 135.00 Receipt and review of emails from E. Alan Hampson re: clients William B. Kemper and Marjorie Daggett.

7/12/2011 0.20 90.00 Receipt and review of an email from M. Lessne re: Robert Meachem

7/12/2011 0.30 135.00 Receipt and review of an email from M. Lessne enclosing pretrial order to review.

7/13/2011 0.30 135.00 Receipt and review of an email from J. Cartagena enclosing of the Motion for Default to review.

7/13/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Alan Hampson enclosing proposed pretrial stipulation.



7/14/2011 0.20 90.00 Emails with M. Lessne re: Dunn v. Kemper and Daggett - Proposed Pretrial order

7/15/2011 0.30 135.00 Emails with Jon Moffa re: Pretrial hearing in the Adversary case.

7/18/2011 0.30 135.00 Receipt and review of Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court [DE 90]

7/19/2011 0.70 315.00 Telephone with moffa re Caldwell objections

7/19/2011 0.30 135.00 Receipt, review and reply to an email from Adam Katz re: pretrial conference.

7/19/2011 0.30 135.00 Receipt and review of Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court.

7/22/2011 0.20 90.00 Emails with M. Lessne re: Worldwide claims.

7/26/2011 0.30 135.00 Receipt and review of Order Continuing Pretrial Conference.

7/26/2011 0.40 180.00 Receipt and review of Order Continuing Pretrial Conference On Complaint filed by Plaintiff M. Dunn (.2) and emai lto client regarding the same (.2)

7/26/2011 0.40 180.00 Receipt and review of Order Continuing Pretrial Conference On Amended Complaint filed by Counter-Defendant M. Dunn, Plaintiff M. Dunn and email to client regarding the same.

7/27/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sherriff Pelle enclosing Summary Judgment.

8/3/2011 0.40 180.00 Receipt and review of an email from N. Nicole enclosing Motion resetting 8/17/11 hearing (.2) and Order on same (.2)

8/3/2011 0.30 135.00 Receipt and review of Notice of Hearing Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court (Clearwater)

8/3/2011 0.30 135.00 Reviewing and responding to e-mail from M. Lessne re: N Frank's claim of ownership.

8/3/2011 0.30 135.00 Reviewing and responding to e-mails from Jessica Serrano re: submitting orders

8/4/2011 0.30 135.00 Telephone conference with Angela re request for judicial notice hearing

8/4/2011 0.20 90.00 Reviewing and responding to e-mails from M. Lessne re: sanction against Leslie Taylor representing Merendon Mining (Colorado).

8/4/2011 0.30 135.00 Telephone conference with Ron Reed, attorney for one of the parties to the litigation

8/10/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue Hearing on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court.



8/10/2011 0.30 135.00 Receipt and review of an Order Granting Motion To Continue Hearing On Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court (Dunn v. Clearwater Mining)

8/10/2011 0.20 90.00 Receipt and review of an email from A. Srour to Ms. Fiorentino enclosing Order Granting Motion to Continue Hearing on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court.

9/6/2011 0.20 90.00 E-mails with J. Cartagena regarding message from Mr. Meacham's office regarding pretrial conference set for 9/19 in Dunn v. Clearwater.

9/6/2011 0.20 90.00 Emails with Andrea Madigan and M. Lessne re Caldwell and Colorado properties (adversary proceeding)

9/8/2011 0.30 135.00 E-mails with J. Cartagena regarding Paul Garfinkle's objection to extend the hearing date for the Pretrial Conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/8/2011 0.30 135.00 E-mails with J. Cartagena regarding email to interested parties seeking their agreement to extend the hearing date for the Pretrial Conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/8/2011 0.20 90.00 E-mails with Deana Hramatulova advising that she has no objection to extend the hearing date for the Pretrial Conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/8/2011 0.10 45.00 E-mail from Richard E. Brodsky advising that he has no objection to extend the hearing date for the Pretrial Conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/8/2011 0.20 90.00 E-mails with Adam Katz regarding objection to extend the hearing date for the Pretrial Conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/9/2011 0.50 225.00 Receipt and review of an email from J. Cartagena enclosing Agreed Motion to continue September 19, 2011 Pretrial and proposed Order to continue same. (Dunn v. Clearwater)

9/9/2011 0.30 135.00 E-mails with J. Cartagena regarding Alan Hampson's approval of the continuance of pretrial conferences in Adv. Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-AJC scheduled for hearing on September 19, 2011 at 10:00 a.m. EST.

9/9/2011 0.50 225.00 Receipt and review of an email from J. Cartagena enclosing Agreed Motion to continue September 19, 2011 Pretrial and proposed Order to continue same. (Dunn v. Brost)

9/12/2011 0.10 45.00 E-mail to A. Srour advising to serve Order on Motion to Continue Hearing in Dunn v. Brost and in Dunn v. Clearwater on all parties.



9/12/2011 0.30 135.00 Receipt and review of an Order on Motion to Continue Hearing to 11/3/11 (Dunn v. Brost)

9/12/2011 0.40 180.00 Receipt and review of an email from J. Cartagena enclosing Amended Agreed Motion to Continue in Dunn v. Brost case.

9/12/2011 0.40 180.00 Receipt and review of an email from J. Cartagena enclosing Amended Agreed Motion to Continue in Dunn v. Clearwater case.

9/12/2011 0.10 45.00 Receipt and review of an email from J. Cartagena advising that the Court's asked we must file an Amended Motion in both adversary cases (Brost & Clearwater)

9/13/2011 0.20 90.00 Emails with J. Cartagena regarding Motions filed in Dunn v. Brost- DE#156 and Dunn v. Clearwater- DE# 100.

9/14/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue Hearing on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court and email to client enclosing the same.

9/14/2011 0.40 180.00 Receipt and review of Order Continuing Pretrial Conference and email to client enclosing the same (Dunn v. Clearwater)

9/14/2011 0.10 45.00 E-mail from A. Srour to Paul Garfinle enclosing Order Granting Motion to Continue Hearing on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court; and Order Continuing Pretrial Conference to November 3, 2011 (Dunn v. Clearwater).

9/14/2011 0.10 45.00 E-mail from A. Srour to John Muffa enclosing Order Granting Motion to Continue Hearing on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court; and Order Continuing Pretrial Conference to No vember 3, 2011 (Dunn v. Clearwater)

9/15/2011 0.10 45.00 Email from Paul Garfinkle re Harold Caldwell Pobate case.

9/15/2011 0.40 180.00 Receipt and review of Plaintiff's Judgment Creditor's Amended Motion to Renew Revive Judgment Prior to Dormancy and proposed Order re the same. (Kemper v. The Estate of Harold Caldwell, Case No.: 92 CV 55)

9/23/2011 0.20 90.00 Review of Notice of Filing Receipt of Clearwater's Motion to Continue.

9/23/2011 0.20 90.00 Receipt and review of an email from John Moffa to the trustees enclosing Motion by Clearwater to continue hearing.

9/27/2011 0.10 45.00 E-mail from Robert Meacham regarding Transcript of Judgment.

9/27/2011 0.20 90.00 Receipt and review of emails between M. Lessne and Deana Hramatulova regarding Power Equip Co.

10/4/2011 0.40 180.00 Receipt and review of letter from Robert Meacham and Defendant Worldwide Rental Services, Inc. A/K/A Worldwide Machinery, Inc.'S Disclosures Pursuant To Rule 26, F.R.C.P.



10/5/2011 0.20 90.00 E-mails with Adam Katz dismissal of the adversary proceeding.

10/6/2011 0.30 135.00 Receipt and review of Answer to Crossclaim Filed by Clearwater Mining Company.

10/7/2011 0.60 270.00 Receiving and reviewing of an email from J. Cartagena enclosing the Agreed Motion to Continue November 3, 2011 hearing in the Dunn v. Clearwater and Dunn v. Brost case.

10/7/2011 0.30 135.00 Receiving and reviewing of e-mails between M. Lessne and Robert Meacham regarding analysis in the adversary cases.

10/10/2011 0.10 45.00 E-mail from A. Srour to Yamileth Valencia, clerk enclosing Agreed Ex Parte Motion to Continue hearing in Dunn v. Brost case.

10/10/2011 0.20 90.00 E-mails with J. Cartagena re Agreed Motion to Continue Nov 3rd pretrial conference and Motion re Judical Notice (Dunn v. Clearwater)

10/10/2011 0.10 45.00 Receipt and review of Stipulation for Dismissal with Prejudice (Harold Caldwell)

10/10/2011 0.50 225.00 Receiving and reviewing of an email from J. Cartagena enclosing the Agreed Order to continue November 3, 2011 hearing in the Clearwater and the Brost adversary cases.

10/14/2011 0.40 180.00 Receipt and review of Order Continuing Hearing and Order Continuing Pretrial Conference (Dunn/Clearwater) and email to clients enclosing the same.

10/14/2011 0.10 45.00 E-mail from A. Srour to the Trustees enclosing Orders Continuing Hearing Hearing to 12/12/2011 in the Clearwater and Brost adversary cases.

10/14/2011 0.30 135.00 Receipt and review of Order granting Motion to Continue hearing (Dunn/Brost) and email to client enclosing the same.

10/28/2011 0.30 135.00 Receipt and review of Order for Notice to show cause for Revival of Judgment - Kemper v. The Estate of Harold Caldwell Case No.: 92 CV 55.

11/10/2011 0.30 135.00 Receipt and review of an email from Deana Hramatulova enclosing correspondence from Robert Meacham.

11/16/2011 0.50 225.00 Draft of letter to steve turner re garfinkle's complaint.

11/22/2011 0.20 90.00 E-mails with Adam Katz re dismissal of the EPA.

11/22/2011 0.30 135.00 Receipt and review of Defendant Worldwide Rental Services, Inc. disclosures.

11/30/2011 0.20 90.00 Receipt and review of Re-Notice of Hearing on Pre-Trial Re: Complaint by against Milowe Brost, et al.

11/30/2011 0.20 90.00 Receipt and review of Re- Notice of Hearing (Re: [90] Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court.

11/30/2011 0.20 90.00 Receipt and review of Notice of Hearing on Complaint (Dunn v. Clearwater)

12/7/2011 0.20 90.00 E-mails with Adam Katz re Merendon Mining - adversary proceeding



12/16/2011 0.80 360.00 Review of Notice of Dropping Parties (Declaratory Action; Amended Complaint for Declaratory Judgment; and Motion for Leave to Amend Complaint.

12/19/2011 0.10 45.00 Reviewing e-mails between Micahel Lessne and Jennifer Rolph re order granting motion for leave to amend complaint.

12/20/2011 0.20 90.00 Emails with Adam Katz re Merendon Mining's adversary proceeding

12/20/2011 0.20 90.00 Reviewing of Certificate of Service of Order Granting M for Leave to Amend Complaint.

12/21/2011 0.40 180.00 Reviewing e-mails between M. Lessne and Adam Katz re Stipulation of Dismissal and reviewing of the same.

12/23/2011 0.20 90.00 Receipt and review of of correspondence from Robert Meacham and initial disclosure.

12/27/2011 0.20 90.00 Receipt and review of correspondence from Geralynn Grieve.

12/28/2011 0.20 90.00 Receipt and review of Notice of Taking Depositions of Larry Adair and Martin Werner in the Securities and Exchange Commission v. Merendon Mining (Nevada) Inc. case.

12/29/2011 0.40 180.00 Receipt and review of email and Motion for Extension of Time to File Responsive Pleading from Robert Meacham

12/30/2011 0.10 45.00 Review of Order Dismissing United States From Adversary Proceeding.

1/3/2012 0.20 90.00 Receipt and review of an email from Deana Hramatulova Paralegal to Robert C. Meacham enclosing correspondence and expert disclosures

1/6/2012 1.60 720.00 Receipt and review of plaintiff’s expert report of David Abbott, Jr. from Leslie J. Hughes via email.

1/9/2012 0.20 90.00 Reviewing of Certificate of Service of Order granting Motion for Leave to Amend Complaint

1/9/2012 0.20 90.00 Reviewing of Certificate of Service re DE 130 Order Dismissing US from Adversary Proceeding.

1/9/2012 0.40 180.00 Reviewing of Notice of Filing Expert Witness Report, along with the report.

1/12/2012 1.00 450.00 Receipt and review of an email from M. Lessne to Robert Meacham re Worldwide Rental Services.

1/12/2012 0.20 90.00 Receipt and review of a letter from Robert Meacham to M. Lessne.

1/13/2012 0.50 225.00 Receipt and review of Worldwide Rental's Answer and Affirmative Defenses to Second Amended Advarsary Complaint for Declaratory Judgment (.4); email to client enclosing the same (.1)

1/13/2012 0.60 270.00 Receipt and review of Worldwide's Expert Report Disclosures.



1/13/2012 0.60 270.00 Receipt and review of Motion to Extend Time to Complete Discovery And Allow Filing of Motion for Summary Judgment & Initial Disclosure per FRCP 26 Required by the Order Setting (Dunn/Cahill/Wenrer)

1/13/2012 0.30 135.00 Receipt and review of an email from Laurie Bobrow Legal Assistant to Robert Meacham enclosing correspondence to M. Lessne along with breakdown of estoppel.

1/17/2012 0.10 45.00 Emails with Angela C. Riggs re vs. Larry L. Adair

1/17/2012 0.20 90.00 Email from amd to Arthur C. Neiwirth re upcoming-pre trial.

1/19/2012 0.10 45.00 Receipt and review of a letter from Robert C. Meacham.

1/19/2012 0.30 135.00 Reviewing of emails from intrested parties re agreement to extend the hearing date for the Pretrial Conferences.

1/19/2012 0.20 90.00 Receipt and review of SEC’s Withdrawal of Notice of Deposition for Messrs, Werner and Hickson.

1/20/2012 0.10 45.00 Reviewing of Agreed Motion to Continue Jan 23, 2012 pretrial conference.

1/20/2012 0.20 90.00 Receipt and review of Motion to Extend the Deadline Time to Complete Discovery , Motion to Allow Filing of Motion for Summary Judgment Filed by Defendant Worldwide Rental Services, Inc. (.1); email to client enclosing the same (.1)

1/23/2012 0.50 225.00 Receipt and review of Agreed Motion for Permanent Injunction Against Martin Werner by Plaintiff Securities and Exchange Commission. (SEC v. Merendon)

1/23/2012 0.10 45.00 Reviewing of Notice of Withdrawal of Plaintiffs' Cross-Notice of Deposition re Cross Notice to Take Deposition (SEC v. Merendon)

1/23/2012 0.20 90.00 Review of Certificates of Service of Order Continuing Pretrial to Feb. 27, 2012 (Dunn v. Werner and Dunn v. Brost)

1/23/2012 0.20 90.00 Reviewing of Withdrawal of Plaintiffs' Cross-Notice of Deposition.

1/23/2012 0.70 315.00 Receipt and review of Agreed Order Granting Defendant's Worldwide Rental Services Motion to Extend Time to Complete Discovery and to Allow Filing of Motion for Summary Judgment and Order Granting Motion To Continue Hearing (regarding Cahill and Brost ) (.6); email to client enclosing the same (.1)

1/23/2012 0.60 270.00 Receipt and review of Agreed Order Granting Motion to Extend Time to Complete Discovery (Dunn v. Werner) (.2); Order Granting Motion To Continue Hearing on Amended Complaint (Dunn v. Werner) (.2); Order Granting Motion To Continue Hearing on Complain t (Dunn v. Brost) (.2)

1/24/2012 0.40 180.00 Receipt and review of Certificate of Service Filed by Defendant Worldwide Rental Services, Inc. (.2) and Order on Motion to Extend Time (.2)

1/27/2012 0.40 180.00 Receipt and review of Rule 26 Initial Disclosures (.2); emails to client enclosing the same. (Dunn/Cahill) (.2)



1/27/2012 0.10 45.00 Receipt and review of Rule 26 Initial Disclosures.

1/31/2012 0.10 45.00 Receipt and review of SEC’s Withdrawal of Plaintiff’s Notice of Deposition for Ward Capstick.

2/3/2012 0.80 360.00 Receipt and review of correspondence from Robert Meacham, re: Complaint and judgment,

2/7/2012 0.20 90.00 Receipt and review of emails between Deana Hramatulova , Paralegal to Mr. Meacham and M. Lessne re extend the deadline to respond to disclose expert witnesses

2/7/2012 0.20 90.00 Receipt and review of Motion to Extend Time for Disclosure of Expert Testimony under Rule 26 (a)(2) (Dunn/Cahill)

2/10/2012 0.20 90.00 Receipt and review of Supplemental Initial Disclosure per FRCP 26 Required by the Order Setting Filing and Disclosure Requirements regarding Expert Testimony (.1); email to client enclosing the same (.1).

2/17/2012 0.20 90.00 Receipt and review of unopposed Motion to Extend Time to comply with Pretrial Deadllines (.1); email to client enclosing the same (.1).

2/23/2012 0.10 45.00 Receipt and review of Certificate of Service of Agreed Order Granting Defendant, Worldwide Rental Services, Inc.'s Unopposed Motion to Extend Pretrial Deadlines Filed by Defendant Worldwide Rental Services, Inc

2/23/2012 0.10 45.00 Receipt and review of Agreed Order Granting Motion to Extend Pretrial Deadlines

2/29/2012 0.30 135.00 Receipt and review of Order continuing Pretrial conference to 4/23/12 and review Certificate of Service re the same (.2); email to client enclosing the same. (Dunn/Brost) (.1)

2/29/2012 0.30 135.00 Receipt and review of Order continuing Pretrial conference to 4/23/12 and review Certificate of Service re the same (.2); email to client enclosing the same. (Dunn v. Frank/Cahill/Werner) (.10

3/5/2012 0.20 90.00 Receipt and review of Order by Judge Richard A Jones. The court DENIES motions for permanent injunctions and other relief, docket nos: [85], [86], [87] and orders the SEC to submit a statement in compliance with this order no later than March 28, 201 2 (.1); email to client enclosing the same. (.1)

3/6/2012 1.00 450.00 Receipt and review of motion and order from SEC and email to SEC re same

3/12/2012 0.40 180.00 Receipt and review of Motion for Judgment (.3); email to client enclosing the same (.1)


Activity Code 011 Meetings of Creditors

7/16/2009 0.30 120.00 Telephone with client re: Monday's call with creditors

7/17/2009 0.50 200.00 Telephone conference with Bob Schatzman re: call with investors on Monday



7/20/2009 1.80 720.00 Conference call with investors

10/5/2009 0.30 135.00 Telephone conference with Marilyn Sink, creditor investor

10/9/2009 0.30 135.00 Telephone conference with creditor Orist Pashko

10/10/2009 1.20 540.00 Telephone conference with investor Melanie Sears (.3); telephone with unidentified investor (.5); telephone with investor John Nelson and email from nelson (.4)

10/14/2009 2.20 990.00 Telephone conference with investor creditor Judy Sancartier (.4); telephone Demetrios Sinodinos investor creditor (.5) telephone with Tawn Talls investor (.4) telephone with Alicia McDonald (.3) telephone with George Giesbrecht (.3) telephone with in vestor Dawn Abel (.3)

10/16/2009 2.30 1,035.00 Meeting of creditors and meeting with trustee and her financial advisors (2.0); exchange emails with investor, Greg Grover (.3)

10/26/2009 0.30 135.00 Telephone conference with Tim and Janet Carlson re: claims administration

1/7/2010 1.50 675.00 Telephone conference with Susie Stevens creditor (.3); telephone conferences with Ken Iredale creditor x 2 (.6); teleconference with Susan Brittman creditor (.3); email to P. Wagner (.1) regarding converting motion into order for Tuesday hearing; ema ils with Paul Garfinkle (.2)



6/9/2010 0.20 90.00 Emails with M. Lessne regarding Discovery Day and his call with Garfinkle re: same

6/11/2010 0.30 135.00 Telephone conference with Garfinkle re: stay violation motion

6/11/2010 1.30 585.00 Review, revise and draft stay violation motion for mine explosion (1.1); emails with Jason Welt of Fisher Auction re: same (.2)

6/23/2010 0.50 225.00 Telephone conference with Sakalo re: Tridnet stay violation

6/24/2010 1.00 450.00 Conference with Jay Sakalo counsel for Trident regarding stay violation issues

6/25/2010 1.20 540.00 Emails to and from Jay Sakalo counsel for Trident regarding the stay violation issues and resolution of the same (.8); conference with Capstick and Garfinkle regarding this issue (.4)

6/25/2010 1.50 675.00 Telephone conference with Trustee, Paul Garfinkle and Jay Sakalo, counsel for Trident, each separately regarding hearing on stay violation and title issues (.9); emails with Richard Brodsky re: stay violation issues (.6)



6/28/2010 1.60 720.00 Telephone conference with jay Sakalo (.3); receipt and review property tax bill for 2009 on Discovery Day from Sakalo (.2); emails with Garfinkle and F. Santos regarding ownership of Discovery Day and explosion investigation (.6); email to M. Dunn tr ansmitting copy of Bahama Resource Assignment of Stock Interest (.1); email to Hark transmitting Canadian orders on: Receivership and Suggestion of Bankruptcy automatic stay, and also regarding Charles Blakey accepting service on behalf of Gary and T helma Sorenson and all S.A. entities and addresses for service; financial and reporting information on all S.A. entities; and financial arrangements for travel to Calgary (.1); receipt and review of 2009 tax bill for DD from Sakalo (.1); emails with Capstick regarding Sorenco Oil & Gas (.2)

6/28/2010 1.00 450.00 Conference with Garfinkle re: hearing on stay violation against Trinity

9/2/2010 1.00 450.00 Conference call hearing regarding colorado litigation over glory hole

9/3/2010 0.50 225.00 Receipt and review stay relief motion from caldwell estate

9/13/2010 6.00 2,700.00 Receipt and review of Caldwell's stay releif motion and research and drafting objection and opposition to same

9/14/2010 10.00 4,500.00 Draft, research and file objection to Caldwell's motion for stay relief

10/6/2010 0.30 135.00 Telephone conference with Judge Barnes Estate's counsel re: stay

10/6/2010 0.30 135.00 Telephone with Bob Hogan, counsel for Colorado New Blood Vista entities

10/11/2010 0.30 135.00 Telephone conference with Barnes counsel re stay

10/11/2010 0.30 135.00 Telephone conference with Bob Hogan, counsel for Colorado New Blood Vista re: stay

6/8/2011 0.20 90.00 Receipt and review of an email from M. Lessne regarding Discovery - Personally Identifiable Information.



12/5/2009 0.20 90.00 E-mail from Paul Garfinkle regarding Boulder City tax situation

12/14/2009 0.40 180.00 Review emails from B. Elam regarding tax issues in Boulder

1/20/2010 0.10 45.00 Email with B. Elam regarding tax situation in Colorado;

6/26/2010 0.30 135.00 E-mail to Jay Sakalo transmitting property tax bills (.1); emails from Capstick (.1); email to M. Dunn regarding property tax bills (.1)

6/28/2010 0.80 360.00 Telephone conference with jay Sakalo (.3); receipt and review property tax bill for 2009 on Discovery Day from Sakalo (.2); receipt and review of 2009 tax bill for DD from Sakalo (.1); emails with Capstick regarding Sorenco Oil & Gas (.2)



6/29/2010 1.40 630.00 emails and faxes from Paul Garfinkle transmitting documents from Siskiyou County Tax Collector, and police report from DD explosion and review same (1.0); email to Hark, A. Brodsky, Werner, Neiwirth, Garfinkle regarding objections to continuing pretr ial indefinitely to allow for further discovery, resolve outstanding property issues and sell assets and discuss same with A. Brodsky and M. Lessne (.4)

6/30/2010 1.00 450.00 Receipt and review of multiple emails from Garfinkle transmitting Siskiyou County tax collector documents

7/8/2010 0.10 45.00 Receipt and review of correspondence from Les Taylor to M. Dunn regarding past due taxes for Black Rose Mine in Jamestown, CO (.10

6/20/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to Sean Doyle enclosing the 2011 Real Property Notices from Gilpin County.

8/4/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sean Doyle enclosing information from the Colorado Division of Reclamation.

9/22/2011 0.30 135.00 Received and reviewed emails between M. Lessne and J. Cartagena regarding AZ Mines, calling Tax Collector in Dolen County.

9/22/2011 0.10 45.00 E-mail from J. Cartagena regarding Tax Collector's office and the Assessor's office in Mohave County.

10/17/2011 0.20 90.00 Receiving and reviewing of email from M. Lessne and M. Dunn re email to the Boulder County tax collector with attachments.

10/25/2011 0.20 90.00 Emails with M. Dunn and John Moffa regarding unpaid taxes.

1/23/2012 0.10 45.00 Reviewing e-mail from M. Lessne to Tong Li re Boulder County tax collector


$430,220.00962.60Total for Timekeeper Reich, Ivan J



Schatzman, Robert


6/16/2009 1.50 825.00 Prepare for and participate in conference call re: strategy

6/17/2009 0.20 110.00 Telephone call with Interfor, Inc.

6/18/2009 0.30 165.00 Telephone call with Tom Suozzo.

6/18/2009 0.30 165.00 Telephone call with representative of Interfor, Inc.

6/19/2009 4.00 2,200.00 Telephone call with Interfor, Inc. (.3); conference with S. Solomon, client, B. Elam, J. Ryan and S. Khanorkar re: strategy (3.7)

6/20/2009 0.80 440.00 Dictate memo regarding conference call on June 16 and meeting on June 19, 2009 re: strategy

6/21/2009 0.50 275.00 Review and respond to various e-mails.

6/22/2009 0.80 440.00 Telephone call with Tom Suozzo from Interfor, Inc.

6/23/2009 0.40 220.00 Edit Memo to client and various parties re: strategy

6/23/2009 0.30 165.00 Telephone call with I. Reich.

6/23/2009 1.00 550.00 Review e-mails (.2); telephone call with Paul Garfinkle (.5); telephone call with Sharmila Khanorkar (.3)

6/23/2009 0.60 330.00 Review and respond to e-mails.

6/24/2009 0.80 440.00 Review and respond to e-mails (.2); conference with I. Reich (.3); telephone call with Harvey Geerwitch (.3)

6/24/2009 0.40 220.00 Review e-mails.

6/25/2009 0.30 165.00 Telephone call with Paul Garfinkel (.1); telephone call with I. Reich (.2).


6/26/2009 6.00 3,300.00 Conference I. Reich (.3); conference client and various professionals regarding case administration and recovery of assets (5.7)

6/29/2009 0.40 220.00 Telephone call with J. Bennett, Administrator of case.

6/30/2009 0.00 0.00 Telephone call with Tom Cash.

6/30/2009 0.60 330.00 Telephone calls with Tom Cash, Kroll.


7/7/2009 0.40 220.00 Telephone call with Larry Krantz.

7/7/2009 1.00 550.00 Conference call with S. Khanorkar.

7/8/2009 3.20 1,760.00 Review file in preparation for meeting with Tom Cash and S. Khanorkar (2.0); conference with Tom Cash and S. Khanorkar (1.2)

7/10/2009 1.00 550.00 Review and respond to e-mails (.6); telephone call with S. Khanorkar (.4)

7/10/2009 1.20 660.00 Review file (.5); draft memo (.7)




7/13/2009 0.50 275.00 Telephone call with S. Khanorkar (.3); review and respond to e-mails (.2)


7/13/2009 0.40 220.00 Edit memorandum to client and professionals.

7/13/2009 0.50 275.00 Edit memo to client and counsels and professionals.

7/14/2009 0.70 385.00 Review memorandums (.4); telephone call with Tom Cash (.3)

7/14/2009 0.20 110.00 Telephone call with Michael Quilling, Canadian Receiver.

7/20/2009 0.60 330.00 Telephone call with I. Reich.

7/21/2009 1.00 550.00 Review public records regarding corporate filings and property searches.

7/21/2009 0.60 330.00 Review notes (.3); telephone call with P. Garfinkle (.3)

7/21/2009 1.40 770.00 Review and respond to E-mails (.5); telephone call with Paul Garfinkle (.4); attention to matter re: same (.5)

7/23/2009 2.50 1,375.00 Prepare for meeting with P. Garfinkle (.5); telephone call with I. Reich, Meltz and P. Garkinkle (2.0)

7/24/2009 1.10 605.00 Preliminary review of Paul Garfinkle's statement; review and respond to various e-mails (.5)

7/27/2009 1.00 550.00 Review Garfinkle's transcript.

7/29/2009 0.40 220.00 Telephone call with Harvey Gurwitch (.1); telephone call with I. Reich (.3)

8/3/2009 0.40 220.00 Review various e-mails.


8/6/2009 1.00 550.00 Review Memo - consulting geologist - David Abbott.




9/7/2009 0.60 330.00 Review various e-mails.

9/8/2009 1.00 550.00 Review of documents from Alberta Securities Commission.

9/8/2009 0.70 385.00 Review correspondence (.2); telephone call with I. Reich (.3); review and respond to e-mails (.2)



9/16/2009 0.80 440.00 Review and respond to various e-mails (.5); telephone call with I. Reich (.3)

9/16/2009 2.50 1,375.00 Review Garfinkel affidavit (1.0); telephone call with I. Reich re: same and other matters re: same (1.5)



9/18/2009 0.80 440.00 Review Garfinkle Declaration.

12/14/2009 0.40 220.00 Telephone call with I. Reich regarding complaint and motion for injunctive relief.

12/21/2009 2.00 1,100.00 Review motion for substantive consolidation, turnover and injunctive relief.

1/6/2010 1.00 550.00 Conference call with I. Reich, B. Elam, S. Khanorkar.

1/7/2010 0.70 385.00 Review e-mails (.3); conference with I. Reich regarding asset recovery (.4)

1/12/2010 0.70 385.00 Conference with I. Reich and Sharmilla K.

1/28/2010 0.20 110.00 Telephone call with I. Reich regarding Order of substantive consolidation.



1/31/2011 0.50 300.00 Phone conference with I. Reich and M. Lessne regarding settlement on Discovery Day Mine.



6/12/2009 1.00 550.00 Conference with I. Reich and F. Terzo regarding case administration.

6/12/2009 2.40 1,320.00 Conference with I. Reich, B. Mukamal and Morris Berger (2.0); review memo to B. Elam (.4).


6/15/2009 0.90 495.00 Review and respond to numerous emails.

6/15/2009 1.20 660.00 Telephone call with B. Elam (.8); review and respond to emails (.4).

6/30/2009 0.80 440.00 Review I. Reich extensive memo (.4); e-mail various parties (.4)

7/1/2009 0.80 440.00 Review proposal of Interfor (.1); telephone call Tom Cash's office (.3); telephone call Tom Suozzo (.3); e-mail Tom Suozzo (.1)


7/16/2009 0.30 165.00 Telephone call with I. Reich regarding Court hearing on Elan retention.


9/4/2009 3.50 1,925.00 Conference with I. Reich and Sharmilla Khanorkar re: schedules (.6); prepare schedules and statement of financial affair (2.9)

9/8/2009 0.90 495.00 Telephone call with I. Reich re: case (.6); review e-mails re: same (.3)

1/8/2010 0.60 330.00 Review and respond to various e-mails regarding hearing.



1/12/2010 4.00 2,200.00 Prepare for and attend hearing on Trustee's Motion for Substantive Consolidation.



7/14/2009 0.40 220.00 Review Kroll engagement letter

7/15/2009 0.20 110.00 E-mail I. Reich re: Kroll.

7/16/2009 2.70 1,485.00 Review file in preparation for meeting; call with I. Reich, S. Khanorkar and telephone call with M. Quinlling.

9/21/2009 0.60 330.00 Review affidavit of B. Mukamal.



7/28/2009 1.00 550.00 Conference with I. Reich regarding complaint for alter ego (.3); conference with N. Mancuso and I. Reich re: same (.7)

9/1/2009 0.40 220.00 Telephone call with I. Reich regarding suit to determine alter ego.

12/4/2009 2.50 1,375.00 Review and edit draft complaint (2.2); conference call with I. Reich re: same (.3)

12/9/2009 0.50 275.00 Telephone call with I. Reich regarding draft complaint.

12/18/2009 0.50 275.00 Review pleadings and filings in adversary.


$46,720.0084.90Total for Timekeeper Schatzman, Robert



Scott, Patrick S


7/29/2010 0.80 396.00 Conference with I. Reich and others to review strategy for clearing title to Colorado property

8/5/2011 0.40 200.00 Conference with M. Lessne re strategy for settlement

1/25/2012 0.20 100.00 Conference with M. Lessne re 1983 royalty agreement, and buyer’s question

1/27/2012 1.00 500.00 Conferences with M. Lessne (.3), and Telephone conference with I. Reich re whether possible to set aside 2009 and 2010 conveyances of Arizona mine (.7)



8/3/2010 0.70 346.50 Conference with M. Lessne, I. Reich, J. Leibner re: section 363 (.4); draft memo to M. Lessne re use of section 363(f) to clear co-owner’s interest (.3)

7/19/2011 0.90 450.00 Strategize with I. Reich, M. Lessne re Glory Hole Mine, options

1/11/2012 0.20 100.00 Conference with M. Lessne re form of sale order

1/13/2012 0.10 50.00 Conference with M. Lessne re service requirements for sale order



1/13/2012 1.40 700.00 Conferences with J. Leibner, M. Lessne re research needed on retroactive effect of judgment upon mechanic’s lien

1/16/2012 0.40 200.00 Telephone conference with R. Meacham re Worldwide Rental’s lien

1/16/2012 1.50 750.00 Conference with M. Lessne, J. Leibner re Worldwide Rental’s judgment lien (1.1); Telephone conference with I. Reich, M. Lessne re negotiating with R. Meacham (.4)

1/19/2012 1.00 500.00 Conference with M. Lessne re strategy and research results on Worldwide Rental’s secured claim (.3); Telephone conference with R. Meacham re same (.3); exchanged memos with M. Lessne, I. Reich, R. Meacham (.4)

1/20/2012 1.40 700.00 Numerous conferences with M. Lessne, J. Leibner re Worldwide’s construction lien claim, research issues, how to proceed

2/3/2012 0.40 200.00 Reviewed letter from R. Meacham re remaining issues in Worldwide dispute re: claim (.2); exchanged memos with M. Lessne re issues for same (.2)

2/6/2012 1.40 700.00 Conference with M. Lessne re Worldwide’s counsel’s letter (.5); drafted reply to R. Meacham (.3); legal research re Colorado construction lien statute and Colorado court rules (.6)



2/24/2012 1.20 600.00 Telephone conference with R. Meacham re possible settlement of Worldwide Rentals adversary proceeding (.4); drafted stipulation for settlement (.4); drafted motion to approve settlement (.4)



2/7/2012 0.40 200.00 Conference with M. Lessne proposed response to R. Meacham re Worldwide (.2); conference with I. Reich re same (.2)

2/8/2012 1.70 850.00 Drafted letter to R. Meacham re all issues in his dispute (.3); reviewed research results (1.4)

2/13/2012 0.60 300.00 Drafted memo to M. Dunn re proposed settlement terms with Worldwide

2/16/2012 0.40 200.00 Telephone conference with R. Meacham re Worldwide (.2); conference with I. Reich re same (.2)

2/17/2012 0.40 200.00 Conference and numerous email exchanges with I. Reich re what to recommend to M. Dunn re Worldwide

2/20/2012 0.20 100.00 Drafted memo to M. Dunn re Worldwide

2/21/2012 0.20 100.00 Revised letter to R. Meacham re settlement offer

2/24/2012 0.50 250.00 Drafted settlement stipulation

2/28/2012 0.30 150.00 Conference with M. Lessne to review his revisions to settlement with Worldwide

3/1/2012 0.10 50.00 Drafted memo to R. Meacham


$8,892.5017.80Total for Timekeeper Scott, Patrick S



Serrano-Cartagena, Jessi


2/7/2012 0.30 37.50 Review several emails from M. Lessne and S. Doyle re: expense reimbursement for work done regarding Bueno and Black Rose mines.



3/2/2011 0.40 50.00 Draft and finalize email to interested parties re: 30 Day Continuance of 3/21 Sale Motion, Pretrial Conference and All Related Deadlines for M. Lessne and I. Reich's review (0.3); Email same to interested parties (0.1).

4/20/2011 0.30 37.50 Assist M. Lessne with draft of asset purchase agreement re: Glory Hole.

4/20/2011 0.20 25.00 Review emails from M. Lessne and I. Reich re: settlement.

4/27/2011 0.20 25.00 Discuss Glory Hole description with M. Lessne and email same.

6/2/2011 0.30 37.50 Review email from M. Lessne (0.1) and redlined asset purchase agreement sent to S. Doyle (0.2).

8/16/2011 0.40 50.00 Review emails from M. Lessne re: Caldwell settlement and review agreement re: same.

8/18/2011 0.20 25.00 Review redlined version of stipulation agreement.

12/7/2011 0.50 62.50 Discuss service of Order approving Sale of Bueno and Black Rose Mining Properties with M. Lessne.

12/7/2011 1.30 162.50 Review title reports, matrixes and other documentation for preparation of service re: Order approving Sale of Bueno and Black Rose Mining Properties.

12/7/2011 0.50 62.50 Draft and finalize certificate of service re: Order approving Sale of Bueno and Black Rose Mining Properties.

1/3/2012 3.60 450.00 Assist I. Reich and M. Lessne with preparation for 1/4/2012 hearing re: Sale of Bueno and Black Rose mining properties.

1/3/2012 1.00 125.00 Review docs, draft, finalize and file on court's docket Certificate of Service of publishing and Order Approving Sale of Bueno and Black Rose mining properties served by Fisher Auction Company.

1/4/2012 3.80 475.00 Continue with preparation for today's hearing re: Sale of Bueno and Black Rose mining properties.

1/19/2012 1.10 137.50 Review creditor matrix and Order Approving Sale of Bueno and Black Rose mining properties in preparation of service of same (.5) certificate of service for same (.6)

1/20/2012 0.30 37.50 Meeting with Jeff Bahnsen re: documents needed for closing of sale for Bueno and Black Rose mining properties.





3/2/2011 1.10 137.50 Review dockets in main case and both adversary cases (0.4); Review Motions and Orders filed re: Sale and Pretrial Conferences (0.4); Follow-up with M. Lessne re: same (0.3).

3/3/2011 1.00 125.00 Review and respond to interested parties re: continuance of hearing on Sale Motion and pretrial conferences (0.5); Follow-up with M. Lessne and I. Reich re: same (0.5).

3/4/2011 1.90 237.50 Emails and teleconference with M. Lessne and I. Reich re: continuances of Motion in main and adversary cases (0.4); Draft Motion for Continuance of hearing on Sale Motion, Pretrial Conferences and proposed Order (0.5); Contact court re: available dat es to continue (0.3) and follow-up with M. Lessne re: same (0.2); Revise and e-file Motion in main and adversary cases (0.5).

3/7/2011 0.50 62.50 Follow-up with Court re: Motion and proposed Order Continuing Sale and Pretrial Conferences (0.3); Follow-up with M. Lessne re: same (0.2).

3/8/2011 0.80 100.00 Teleconference with Courtroom Deputy re: continued date and time for proposed Order to Continue hearing on Sale Motion and Pretrial Conferences (0.1); Email to I. Reich and M. Lessne re: continued time (0.1) and review responses re: same (0.1); Prepa re and finalize proposed Order and upload same to main case and both adversary cases (0.4); Follow-up with I. Reich and M. Lessne re: same (0.1).

3/8/2011 0.50 62.50 Emails with M. Lessne and I. Reich re: continued time/date for Sale Motion and Pretrial Conferences (0.2); Finalize and upload Orders in main and both adversary cases (0.3).

3/9/2011 1.10 137.50 Follow-up with Court re: Order to Continue Sale Motion and Pretrial Conferences (0.2); Review Orders and calendar same (0.5); Emails and teleconferences with I. Reich, M. Lessne and M. Dunn re: same (0.4).

3/11/2011 0.70 87.50 Review numerous emails from I. Reich re: new pleadings filed and calendar dates (0.3); Attention to matters re: same (0.4).

3/15/2011 0.50 62.50 Review pleadings and calendar upcoming hearing dates.

3/21/2011 0.20 25.00 Follow-up with Cheryl Bennett re: case information on website for creditors.

3/22/2011 0.20 25.00 Review emails from I. Reich and Garfinkle.

3/23/2011 0.20 25.00 Review email from I. Reich re: SEC v. Merendon case, download Order Granting Motion to Dismiss and Deny in part, and email same.

3/24/2011 0.40 50.00 Review emails from I. Reich (0.2); File and email requested docs re: same (0.2).

4/5/2011 0.20 25.00 Follow-up and emails with C. Bennett re: docs for website.

4/15/2011 0.90 112.50 Teleconferences with M. Lessne re: email to interested parties for continuance of 3/26 hearing and pretrial (0.3); Draft and finalize email to all interested parties re: continuance of same (0.6).



4/18/2011 0.40 50.00 Forward email to M. Hannan's additional address re: continuance of hearing and pretrial conferences set for 4/26 (0.1); Review email and teleconference with M. Lessne re: Agreed Motion and Order to continue hearing and pretrial conferences (0.3).

4/19/2011 0.90 112.50 Finalize, prepare and e-file Agreed Motion and proposed Order to continue 4/26 hearing and pretrial conferences in the main case and both adversary proceedings (0.8); Email e-filing receipts to I. Reich and M. Lessne (0.1).

4/21/2011 0.80 100.00 Revise (0.2) and upload proposed Orders in main and both adversaries cases (0.3); Follow-up with A. Srour re: contacting court and procedures re: same (0.2): Call court and leave voice message re: certificate of service for order continuing to 4/26 ( 0.1).

4/25/2011 0.70 87.50 Discuss certificate of service of Orders continuing 4/26 hearing and pretrial conferences to 6/23 with A. Srour (0.1); Email Orders to C. Bennett for GrayRobinson's website (0.1); Draft and email all interested parties Orders entered in main and adve rsary cases (0.3); Emails with I. Reich re: continued hearing to 6/23 and certificate of service of same (0.2).

4/25/2011 0.60 75.00 Discuss 4/26 hearing and pretrial conferences with M. Lessne (0.2); Contact court re: continuing same to June and entering order on docket re: same (0.2); Follow-up with I. Reich and M. Lessne confirming 4/26 hearing and pretrials continued to 6/23 ( 0.2).

4/26/2011 1.40 175.00 Review and organize files into index.

6/3/2011 0.40 50.00 Review Amended Order on Motion to Withdraw as counsel of record by Clifford Hark (0.2); Download and email same to I. Reich (0.2).

6/7/2011 0.60 75.00 Reveiw multiple emails re: production to Worldwide (0.3) and asset purchase agreement (0.3).

6/7/2011 0.70 87.50 Emails and teleconferences with I. Reich and M. Lessne re: continuance of pretrial conferences and sale motions.

6/9/2011 1.50 187.50 Draft email to interested parties for M. Lessne re: Motion to continue sale hearing and pretrial conferences (0.8); Discuss same with M. Lessne (0.3); Finalize and email all interested parties email re: same (0.2); Email docs to C. Bennett for Merend on creditor website (0.2).

6/9/2011 0.30 37.50 Review and respond to email from L. Raymond for Worldwide re: continuance of pretrial conferences.

6/9/2011 0.80 100.00 Review email from Mr. Hampson confirming no objection to continuance Motion and requests for docs (0.2); Review dockets and download docs for Mr. Hampson (0.4); Follow-up email to Mr. Hampson with requested info and docs (0.2).

6/9/2011 0.90 112.50 Review numerous emails from I. Reich re: Amended Motion for Sale (0.5); Assist A. Srour and e-file Amended Motion for Sale of Glory Hole Mining Properties (0.4).

6/9/2011 0.80 100.00 Discuss draft of Motion for Continuance of Sale Motion and pretrial conferences with N. Nicole (0.3); Email previously filed Motion to N. Nicole (0.1); Follow-up emails to N. Nicole re: same (0.2); Discuss same with M. Lessne (0.2).



6/10/2011 0.90 112.50 Follow-up with C. Bennett re: documents on creditor website (0.2); Emails and teleconferences with I. Reich re: Agreed Motion to continue hearing on sale motion and pretrial conferences (0.4); Review response emails from interested parties re: no obj ection to continuance of hearing (0.3).

6/14/2011 0.20 25.00 Review and reply to email from C. Hark re: removal from distribution list.

6/14/2011 2.50 312.50 Review finalized Agreed Motion and proposed Order to Continue Amended Sale Motion and Pre-trial Conferences for M. Lessne (0.5); Emails and teleconferences with M. Lessne re: same (0.4); Draft and send follow-up email to interested parties re: potent ial dates for continued hearing in July (0.3); Prepare and e-file Agreed Motion in main case (0.3) and both adversary cases (0.6); Upload Orders in all cases (0.3) and email receipts to I. Reich and M. Lessne (0.1).

6/15/2011 1.80 225.00 Discuss continued Motions and proposed Orders filed in main and adversary cases with M. Lessne (0.4); Draft separate Orders for same (0.9) and review same with M. Lessne (0.2); Prepare and upload finalized Orders to the court (0.3).

6/16/2011 1.00 125.00 Review dockets and our three Orders entered by the court (0.3); Discuss with A. Srour re: scheduling of new calendar dates and pretrial deadlines (0.4); Attention to matters re: same (0.3).

6/17/2011 0.30 37.50 Discuss 2011 Real Property Notices of Valuation- Gilpin County with I. Reich.

6/20/2011 0.60 75.00 Review email from C. Hinks re: Gary Sorenson and Milo Brost (0.2); Forward same to M. Lessne and I. Reich (0.1); Reply to C. Hinks re: same (0.1); Review email from M. Lessne to S. Doyle re: Compliance with Article IX (0.2).

6/20/2011 0.70 87.50 Discuss 2011 Real Property Notice of Valuation- Gilpin County with M. Lessne (0.3); Prepare scanning docs re: same (0.2); Emails re: same to S. Doyle (0.2).

6/21/2011 0.30 37.50 Review emails re: Dunn v. Clearwater with I. Reich

6/30/2011 0.30 37.50 Discuss management of creditor website with M. Lessne (0.2); Review emails from M. Lessne to C. Bennett re: same (0.1).

6/30/2011 0.20 25.00 Review email from I. Reich re: creditor requesting link to Merendon website (0.1); Send email to creditor with link (0.1).

6/30/2011 0.80 100.00 Review I. Reich's email re: Asset Purchase Agreement (0.1); Retrieve requested documents (0.3); Draft and send requested documents to David Murray per I. Reich re: Amended Sale Motion and Asset Purchase Agreement (0.2); Review emails from I. Reich an d D. Murray re: conference call to discuss matters re: sale (0.2).

7/6/2011 0.30 37.50 Assist A. Srour with mailing list for adv case Dunn v. Clearwater.

7/6/2011 0.10 12.50 Discuss update of GrayRobinson's creditor website with A. Srour.



7/11/2011 0.70 87.50 Teleconference with L. Raymond from R. Meacham's office re: Sale hearing and past deadline for interested parties to have a meeting regarding a pretrial stipulation (0.3); Follow-up email and meeting with M. Lessne re: same (0.4).

7/12/2011 1.40 175.00 Discuss Dunn v. Clearwater case with M. Lessne (0.3); Review docket and pull complaint, amended complaints, cross-claims and answers filed and provide same to M. Lessne (0.6); Discuss upcoming Sale hearing with M. Lessne re: same (0.3); Contact R. Me acham's office and confirm conference call (0.2).

7/12/2011 0.40 50.00 Discuss adversary case re: Kemper and Dagget with M. Lessne.

7/13/2011 0.40 50.00 Review email from M. Lessne re: Motion for Default and pretrial (0.1); Draft Motion for Default in Dunn v. Clearwater (0.2); Review and respond to email from I. Reich re: same (0.1).

7/15/2011 1.00 125.00 Check online public records and files for docs filed in Gilpin County for M. Lessne.

7/15/2011 0.50 62.50 Emails and teleconference with I. Reich and M. Lessne re: Sale hearing and pretrial hearings.

7/19/2011 3.10 387.50 Teleconference and meeting with M. Lessne re: Sale hearing and pretrial conferences set for 7/21 (0.5); Prepare for same (2.6).

7/20/2011 6.30 787.50 Continue preparing for 7/21 Sale hearing and pretrial conferences in both adversary cases.

7/21/2011 3.50 437.50 Continue assisting I. Reich and M. Lessne for preparation of Sale hearing and pretrial conferences for both adversary cases.

7/21/2011 4.00 500.00 Travel to and from court and assist I. Reich and M. Lessne at Sale hearing and pretrial conferences.

7/26/2011 1.60 200.00 Review main docket and both adversary cases for Orders (0.3); Emails to A. Srour re: same (0.2); Draft certificate of service for Order denying amended Sale Motion and Orders continuing 7/21 pretrial conference for both adversary cases (0.4); Email s ame to I. Reich for review (0.1); E-file all certificates of services (0.5); Email filing receipts of same to I. Reich and M. Lessne (0.1).

7/27/2011 1.00 125.00 Search documents and correspondence from Norman Frank re: evidence of his equipment (0.8); Provide same to M. Lessne (0.1); Email Norman Frank's objection to the Sale Motion filed on 10/21/2010 to S. Doyle (0.1).

8/1/2011 0.80 100.00 Review and respond to email from I. Reich re: installment land sales contract with Discovery Day (0.2); Check files for same (0.6).

8/2/2011 0.60 75.00 Revise, prepare and e-file Motion to Approve the Sale of Bueno and Black Rose mining properties (0.5); Email filing receipt of same to I. Reich and M. Lessne (0.1).



8/3/2011 4.60 575.00 Call and leave message for courtroom deputy Barbara re: hearing to be set for Motion for Sale of Property of the Bueno and Black Rose Mining Properties (0.2); Follow-ups with I. Reich and A. Srour re: same (0.4); Review Notice of Hearing set for 8/17 on Motion for Sale of Property of the Bueno and Black Rose Mining Properties (0.1); Review docket and Notice of Hearing set for 8/17 on Motion to Request Judicial Notice of the Judgment Entered by the Clerk of the Gilpin County Colorado State Court in the Cleawater adversary case (0.2); Follow-up with I. Reich and court re: conflicting date for same (0.3); Discuss draft for Motion to Continue hearing with I. Reich and N. Nicole (0.2); Emails and teleconference with N. Nicole re: other cases con flicting with 8/17 hearing in main and adversary case (0.4); Review and discuss N. Nicole's drafts of Motion to Continue in main and adversary case with M. Lessne (0.4); Draft Certificate of Service on Amended Sale Motion re Bueno and Black Rose (0.2 ); Prepare and e-file same with the court (0.2); Email filing receipt of same to I. Reich and M. Lessne (0.1); Revise and finalize Motions and Orders to continue 8/17 hearing in the main and adversary case (0.8); Prepare and e-file Motion to Continue and proposed Orders in the main case (0.3) and adversary case (0.3); Email e-filing receipts for Motion to Continue in main and adversary case to I. Reich and M. Lessne (0.2); Upload proposed Orders in main and adversary case (0.2); Email tracking n

8/4/2011 0.40 50.00 Search files for email from Erica Crosby, pics re: Bueno Mine and the Notice of Intent to Explore Annual Fee Invoice from the Colorado Division of Reclamation.

8/4/2011 0.30 37.50 Scan and email pics re: Bueno Mine and Notice of Intent to Explore Annual Fee Invoice from the Colorado Division of Reclamation to M. Lessne.

8/4/2011 0.20 25.00 Discuss email from Erica Crosby, pics re: Bueno Mine and the Notice of Intent to Explore Annual Fee Invoice from the Colorado Division of Reclamation with M. Lessne.

8/8/2011 0.60 75.00 Emails and teleconferences with court and opposing counsel re: new dates to continue hearing in main and adversary case.

8/9/2011 0.40 50.00 Draft certificate of service re: Order on Motion resetting the 8/17/11 hearing (0.2); Prepare and e-file same (0.1); Email e-filing receipt of same to I. Reich and M. Lessne (0.1).

8/10/2011 0.70 87.50 Review ECF notification and Order Continuing hearing on Motion for Judicial Notice in Clearwater adversary case (0.2); Draft certificate of service re: same (0.2); Prepare and e-file same (0.2); Email e-filing receipt of same to I. Reich and M. Lessn e (0.1).



8/19/2011 2.90 362.50 Discuss Motion to Approve Settlement with Caldwell Estate with I. Reich and service of same (0.3); Review draft and revise same (0.2); Prepare and e-file Motion (0.3); Email filing receipt to I. Reich and M. Lessne (0.1); Coordinate service of Motion with A. Srour and follow-up with I. Reich re: same (0.6); Discuss List of Properties for Glory Hole not included in settlement agreement re: Caldwell Estate with I. Reich (0.3); Search and confirm list with I. Reich and Moffa (0.3); Draft Notice of filing Exhibit A to Caldwell settlement agreement (0.2); Email same to I. reich for review (0.1); Prepare and e-file Notice (0.2); Email filing receipt of same to I. Reich (0.1); Email filed version of Notice to Adam Katz (0.1); Email same to C. Ben nett to upload on Merendon website (0.1).

8/22/2011 1.40 175.00 Draft certificate of service re: Notice of hearing on Motion to Settle Caldwell Estate (0.2), Notice of Filing Exh A to Motion to Settle Caldwell Estate (0.2), and Motion to Settle Caldwell Estate (0.2); Email three certificates to I. Reich for revie w (0.1); Prepare and e-file three certificates of service with the court (0.6); Email filing receipt of same to I. Reich (0.1).

8/25/2011 1.20 150.00 Review Objection filed by Garfinkle (0.3); Pull docket and other pleadings for I. Reich (0.3); Draft Notice of Filing receipt of Garfinkle's objection (0.2); Email same to I. Reich for review (0.1); Prepare and e-file Notice (0.2); Email same to C. B ennett to upload on Merendon website (0.1).

9/6/2011 1.00 125.00 Several teleconferences with R. Meacham's office re: pretrial conference scheduled on 9/19 (0.4); Follow-up with M. Lessne and I. Reich re: same (0.4); Follow-up with R. Meacham's office and advise continuance of 9/19 pretrial (0.2)

9/8/2011 0.50 62.50 Discuss and email draft for interested parties re: continuance of pretrial to 9/27 to M. Lessne (0.4); Email all interested parties re: request for continuance of pretrial to 9/27 (0.1).

9/8/2011 0.40 50.00 Draft email to interested parties re: continuance of pretrial to 9/27.

9/9/2011 0.30 37.50 Review and forward email to I. Reich and M. Lessne re: Garfinkle's objection to the continuance of the pretrial conference.

9/9/2011 7.10 887.50 Review responses/emails from interested parties re: request for continuance of pretrial conference to 9/27 (0.6); Draft Motions to Continue pretrial conference to 9/27 and proposed Orders for same in both adversary cases (2.5); Teleconference with A. Hampson re: continuance of hearing (0.2); Follow-up with I. Reich re: same (0.3); Teleconferences, emails with I. Reich and additional revisions to Motions and proposed Orders for both adversary cases (2.5); Prepare and e-file Motion to Continue in both adversary cases (0.5); Email filing receipt for both Motions to I. Reich and M. Lessne (0.1); Upload both Orders to the court's website (0.2); Email tracking numbers for both Orders to M. Lessne and I. Reich (0.2).



9/12/2011 3.60 450.00 Retrieve and save e-filed versions of both Motions to Continue (0.2); Email same to C. Bennett to upload on GrayRobinson's website (0.1); Teleconference with courtroom deputy re: both Motions of Continuance previously filed on 9/9 and Judge's request to file Amended Motions for same (0.2); Follow-up with I. Reich re: same (0.3); Draft Amended Motions and proposed Orders for both adversary cases (1.1); Review the same with I. Reich (0.4); Revise Amended Motions and proposed Orders (0.4); Prepare and e-file Amended Motions and proposed Orders for both adversary cases (0.5); Upload proposed Orders for both cases with the court (0.2); Email tracking numbers for both Orders to M. Lessne and I. Reich (0.1); Email e-filed versions of both Amended Motions to C. Bennett to upload on GrayRobinson's website (0.1).

9/13/2011 2.00 250.00 Teleconferences with I. Reich re: Orders for Amended Motions (0.2); Follow-ups with courtroom deputy re: same (0.3); Follow-up with I. Reich re: same (0.1); Draft and e-file certificate of service in Dunn v. Brost re: Order to Motion continuing pretr ial to 11/3 (0.3); Email filing receipt of same to I. Reich and M. Lessne (0.1); Review, prepare and e-file Trustee's Objection to Garfinkle's Claim (0.4); Email filing receipt fo same to I. Reich and M. Lessne (0.1); Follow-up with A. Srour re: serv ice of same and calendar dates for same (0.5).

9/14/2011 1.30 162.50 Review Orders and calendar deadlines with A. Srour (0.5); Draft two certificates of service for Order continuing hearing and pretrial conference in both adversary cases (0.4); Prepare and e-file both certificates of service (0.3); Email filing receip ts of both certificates of service to I. Reich and M. Lessne (0.1).

9/20/2011 0.90 112.50 Review email from I. Reich re: Joint Response to Garfinkle's objection to Caldwell Settlement Motion and review same (0.3); Review and respond to I. Reich's emails re: preparation for 9/27/11 hearing (0.3); Reiew email from M. Lessne, I. Reich and S. Doyle re: Amendment to the Asset Purchase Agreement for Bueno & Black Rose (0.3).

9/21/2011 1.00 125.00 Review email from I. Reich re: Asset Purchase Agreement (0.1); Retrieve and email Mr. Baker Trustee's Amended Motion to Approve the Sale of the Bueno and Black Rose Mining Properties, with the Asset Purchase Agreement and the Sale Procedures (0.2); R eview and respond to M. Lessne's email requesting draft of the Notice of Filing the First Amendment to the Asset purchase agreement (0.2); Draft and email same to M. Lessne (0.3); Review emails from S. Doyle and M. Lessne re: Amendment to Asset purch ase agreement (0.2).



9/22/2011 8.00 1,000.00 Review and revise Joint Response to Garfinkle's Objection to Caldwell Settlement Motion (1.0); Prepare and e-file same with the Court (0.3); Email filing receipt to I. Reich and M. Lessne (0.1); Serve Garfinkle and Moffa via email and US Mail copy of Joint Response (0.4); Email courtesy copy of same to Trustee, Fisher Auction and Mukamal (0.1); Discuss taxes and mining properties located in Dolan Springs, AZ with M. Lessne (0.4); Contact Tax Collector's Office in AZ (0.4); Multiple teleconferenc es with Tax Accessor's office in Dolan Springs, AZ re: same (0.7); Search Tax Recorder's website re: QuitClaim deeds for mining properties in Mohave county (0.5); Contact Tax Recorder's office re: same (0.3); Retrieve and download QuitClaim deeds iss ued to Merendon and Silmar of AZ for same mining property in Mohave County (0.2); Review files and Judgment entered in Mohave County (0.2); Emails and teleconferences with I. Reich and M. Lessne re: QuitClaim deeds issued to Silmar of AZ (0.4); Prepa re for 9/27/11 hearing (3.0).

9/23/2011 4.70 587.50 Continue preparing for hearing re: Motion for Sale of Bueno and Black Rose Mining Properties and Motion for Settlement with Caldwell Estate set for 9/27/11.

9/23/2011 1.20 150.00 Teleconference with I. Reich re: Notice of Filing Receipt of Paul Garfinkle's Response to Trustee's Objection to Claim No. 482 (0.2); Draft Notice of Filing Receipt of Paul Garfinkle's Response to Trustee's Objection to Claim No. 482 and Request for Hearing on Trustee's Objection to Claim No. 482 (0.2); Email same to I. Reich for approval (0.1); Prepare and e-file same with the court (0.2); Email filing receipt of same to I. Reich and M. Lessne (0.1); Service of same via email and US Mail to Gar finkle and Moffa (0.4).

9/26/2011 4.70 587.50 Continue preparing for 9/27/ hearing (3.6); Contact Cheryl Bennett re: previous docs uploaded on website for 9/27 hearing (0.4); Email C. Bennett additional docs to upload on website (0.1); Draft certificate of service for same and email to M. Lessne for approval (0.4); Prepare and e-file certificate of service (0.1); Email filing receipt of same to I. Reich, M. Lessne and J. Leibner (0.1).

9/26/2011 0.30 37.50 Revise and e-file Notice of Filing First Amendment to that certain Asset Purchase Agreement between Glory Development Company and M. Dunn (0.2); Email filing receipt of same to I. Reich, M. Lessne and J. Leibner (0.1)

9/26/2011 0.50 62.50 Review and respond to email from Garfinkle confirming 9/27 hearing on Caldwell Settlement Motion (0.2); Prepare fax cover sheet and fax copy of Notice of Filing Receipt of Garfinkle's Response to Trustee's Objection to Claim No. 482 and Request for H earing on Trustee's Objection to Claim No. 482 to Garfinkle (0.3).

9/27/2011 3.10 387.50 Final preparations for today's hearing.

9/28/2011 0.80 100.00 Review email and discuss outcome of 9/27 hearing with I. Reich and next steps in case for same (0.4); Emails and teleconference with I. Reich re: proposed Order to approving Caldwell Settlement Motion (0.2); Revise and upload proposed Order with the court (0.2).



9/30/2011 1.70 212.50 Review and download Order granting Caldwell Settlement Motion (0.1); Review and respond to emails from I. Reich re: Order (0.2); Emails of Order to Trustee, B. Mukamal, Fisher Auction and other interested parties (0.2); Draft certificate of service o f Order (0.2); E-file certificate of service (0.2); Email filing receipt of same to I. Reich, M. Lessne and J. Leibner (0.1); Discuss service mailing of Order with A. Srour (0.2); Email service list and certificate of service to A. Srour (0.1); Email Order to C. Bennett to upload on GrayRobinson's website (0.1); Review Order for calendar deadlines (0.3).

10/4/2011 4.10 512.50 Teleconference and meeting with M. Lessne re: Order granting Amended Motion to Approve Sale with Bueno and Black Rose (0.5); Review and revise Order of same (0.5); Email same to M. Lessne (0.1); Draft and prepare exhibits for Order per M. Lessne (2.0 ); Meeting with M. Lessne and I. Reich re: same (0.5); Finalize and upload to the court Order granting Amended Motion to Approve Sale with Bueno and Black Rose (0.2); Draft and email all interested parties requesting continuance of the pretrial confe rences until after the auction set 1/4/2012 (0.3);

10/5/2011 1.30 162.50 Meeting with M. Lessne re: GrayRobinson Merendon website (0.5); Review entered Order re: Bueno and Black Rose and calendar deadlines for same (0.4); Discuss service of same with M. Lessne (0.3); Email Order to C. Bennett to upload on website (0.1).

10/5/2011 0.70 87.50 Review responses from interested parties re: request to continue 11/3 pretrial conferences (0.3) and discuss same with I. Reich and M. Lessne (0.4).

10/7/2011 1.60 200.00 Discuss emails and responses from interested parties re: request for continuance of pretrial conferences with I. Reich (0.5); Draft Motion to Continue pretrial conference in Dunn v. Clearwater (1.0); Email same to I. Reich for review (0.1).

10/10/2011 3.30 412.50 Revise Motion to Continue pretrial conference in Dunn v. Clearwater and draft proposed Order for same (1.0); Draft Motion and proposed Order to Continue pretrial conference in Dunn v. Brost (1.0); Discuss revisions with M. Lessne (0.3) and I. Reich ( 0.2); Revisions to both Motions (0.3); E-file both Motions to Continue in adversary cases Dunn v. Clearwater and Dunn v. Brost (0.3); Email filing receipts to I. Reich and M. Lessne (0.1); Email filed version of Motions to C. Bennett to upload on our website (0.1).

10/11/2011 0.50 62.50 Follow-up with court re: proposed Orders to continue pretrial conferences in both adversary cases.

10/14/2011 1.60 200.00 Review Orders continuing pretrial conferences in both adversary cases to 12/12/11 (0.2); Follow-up with I. Reich re: pretrial dates continued before requested date in 2012 (0.3); Calendar deadlines with A. Srour (0.3); Draft certificates of service f or both pretrial Orders and Order continuing hearing (0.4); E-file three certificates of service for same (0.3); Email filing receipts of same to I. Reich and M. Lessne (0.1).

10/27/2011 0.30 37.50 Discuss service of Sale Order re: Bueno and Balck Rose with M. Lessne.



11/2/2011 0.50 62.50 Discuss with I. Reich and M. Lessne re: case and Order Granting Sale of Bueno & Black Rose Miining

11/9/2011 1.40 175.00 Review service lists and dockets in main and adversary cases and comprise list of parties who have filed Notice of Appearances for same (1.0); Follow-up and meeting with A. Srour re: service of Order granting Sale of Bueno and Black Rose Mining Prope rties (0.4).

11/10/2011 0.50 62.50 Review files, deeds and title reports for the Glory Hole property in Gilpin County & Bueno and Black Rose properties in Boulder county (0.4); Provide same to M. Lessne for review (0.1).

11/28/2011 0.20 25.00 Discuss service of Order granting Sale with A. Srour.

12/1/2011 1.30 162.50 Review main and adversary dockets and matrix re: interested parties to serve Order granting Sale of Bueno and Black Rose Mining properties (0.5); Review title report and search addresses for other interested parties (0.5); Draft certificate of servic e of Order re: same and email to M. Lessne for review (0.3).

12/6/2011 0.50 62.50 Meeting with M. Lessne re: upcoming Sale Hearing for Bueno and Black Rose Mining Properties.

12/7/2011 0.20 25.00 Prepare and e-file certificate of service re: Order approving Sale of Bueno and Black Rose Mining Properties on the court's docket.

12/15/2011 0.20 25.00 Review, pull and email Amended Complaint re: Dunn v. Clearwater filed 10/19/2010 to M. Lessne.

12/16/2011 1.90 237.50 Discuss service of Sale Order with I. Reich and M. Lessne and certificate of service of same (0.3); Review, revise and e-file Motion for Leave to Amend Complaint on the court's docket (0.5); Circulate filing receipt fo same to I. Reich and M. Lessne (0.1); Review and e-file Notice of Dropping Parties on the court's docket (0.3); Circulate filing receipt fo same to I. Reich and M. Lessne (0.1); Discuss Second Amended Complaint with I. Reich (0.2); Review, prepare and e-file Second Amended Complai nt on the court's docket (0.3); Circulate filing receipt fo same to I. Reich and M. Lessne (0.1);

12/20/2011 0.60 75.00 Download court filed version of Motion for Leave to Amend Complaint, Notice of Dropping Parties, Second Amended Complaint and Order Granting Motion for Leave to Amend Complaint (0.5); Email copy of same to C. Bennett for GR Merendon website (0.1).

12/22/2011 0.40 50.00 Download and email Stipulation of Dismissal of U.S. as Party Defendant and Order Dismissing U.S. from Adv Proceeding to C. Bennett for GR Merendon website.

1/4/2012 2.00 250.00 Travel to and from 1/4/2012 hearing re: Sale of Bueno and Black Rose mining properties.

1/4/2012 1.00 125.00 Attend 1/4/2012 hearing re: Sale of Bueno and Black Rose mining properties.

1/5/2012 2.50 312.50 Review and update Merendon spreadsheet re: documents and links on GrayRobinson's website set up for creditors.



1/5/2012 0.20 25.00 Save into database and email fully executed Asset Purchase Agreement between David Badner/Badner Group Inc. and M. Dunn to F. Santos.

1/6/2012 1.50 187.50 Pull and resend pdf documents to C. Bennett for GrayRobinson's Merendon website.

1/9/2012 0.30 37.50 Revise Certificate of Service of Order Granting Motion for Leave to Amend Complaint (0.1); Prepare and electronically file the same on the court's docket (0.2).

1/9/2012 0.20 25.00 Retrieve and email Amended Motion for Sale of the Bueno and Black Rose Mining Properties to Tong Li.

1/12/2012 0.60 75.00 Review letter received from R. Meacham's office re: Joint Pretrial Stipulation and discuss same with I. Reich (0.3); Review numerous emails from buyer's counsel re: comments for draft of Order Approving Sale of Boulder properties to Badner (0.3).

1/13/2012 0.30 37.50 Prepare and electronically file on the court's docket Initial Disclosure per FRCP 26 in adversary case Dunn v. Werner.

1/13/2012 0.40 50.00 Prepare and gather exhibits for proposed Order Approving Sale of Bueno and Black Rose mining properties to Badner (0.3); Upload proposed Order Approving Sale of Bueno and Black Rose mining properties to Badner to court's website (0.1).

1/18/2012 0.20 25.00 Retrieve and email exhibits to Order approving Sale of Bueno and Black Rose to R. Meacham.

1/19/2012 0.20 25.00 Prepare and eletronically file certificate of service re: Order Approving Sale of Bueno and Black Rose mining properties on the docket.

1/19/2012 1.00 125.00 Draft email to interested parties re: request to continue pre-trial conference set for 1/23 to beyond 2/8 (0.9); Email same to all interested parties (0.1).

1/23/2012 0.20 25.00 Retrieve and email Sub Con Order to Tong Li.

1/23/2012 0.70 87.50 Search for tax collector files re: Boulder county for M. Lessne.

1/23/2012 0.40 50.00 Prepare and electronically file on court's docket two certificates of service re: Order continuing pre-trial conferences in both adversary cases.

1/23/2012 1.00 125.00 Search files and email J. Bahnsen the tax assessor's map re: Boulder County, Inspection Report of the Bueno Mines and title search reports of same.

1/24/2012 1.60 200.00 Research and follow-up on title agencies in Arizona re: title search for mining properties in Dolan Springs, AZ.

1/25/2012 0.60 75.00 Retrieve and email Trustee's Bill of Sale and Deed for the Bueno and Black Rose mining properties to Tong Li and Jeff Bahnsen (0.2); Follow-up with Jenny Sica and Tong Li re: inquiries for sale and closing of Bueno and Black Rose (0.4).

1/25/2012 0.70 87.50 Search files for copy of the contract between James Town Development Co., LLC and Merendon Mining (Colorado) Inc. dated as of Dec 29, 2004 requested by Tong Li (0.5); Follow-up with T. Li via teleconference and email confirming we don't have copy of contract (0.2).



1/27/2012 0.90 112.50 Retrieve and email Quit Claim Deed to Silmar of Arizona, LLC recorded 1/12/10 and a Judgment recorded 8/12/09 regarding the same mining entities to M. Lessne and J. Leibner (0.2); Search files for Sub Con Order recorded in Mohave County, AZ for M. Le ssne and follow-up email re: same (0.7).

1/27/2012 0.30 37.50 Follow-up with title agency in Arizona re: title search for Dolan Springs mines.

1/30/2012 0.20 25.00 Follow-up with title search company in Arizona and advise we no longer need their services for a title search re: Dolan Springs mines.

2/1/2012 0.60 75.00 Review M. Lessne's email re: Discovery Day Mines in California (0.1); Review Order approving settlement with Trinity Alps, Discovery Day and Bowerman Holdings (0.1); Contact Siskiyou County in California re: recording order of same (0.4).

2/6/2012 0.70 87.50 Draft letter to Siskiyou County Recorder advising to record enclosed Order to approve settlement with Trinity Alps, Discovery Day (0.2); Follow-up with A. Srour re: check request for recording fee (0.1); Print two copies of the Order, prepare pre-sta mped self addressed envelope, and mail package of same to Siskiyou County Recorder in California (0.4)

2/7/2012 0.20 25.00 Retrieve and email Order granting approval of the Sale (DE 284) and Order approving the Sale (DE 287) re: Bueno and Black Rose Mining Properties to M. Lessne.

2/15/2012 0.80 100.00 Meeting with M. Lessne re: upcoming deadlines and Trustee's expense reimbursements to Glory Development Company and Fisher Auction (0.4); Review previous correspondence from Trustee and S. Doyle re: same (0.3); Follow-up with M. Dunn re: status of ex pense reimbursements (0.1).

2/15/2012 0.20 25.00 Follow-up with C. Bennett in the IT dept re: maintenance of the GR's website for creditors.

2/17/2012 0.60 75.00 Discuss case and need for request to produce from Trustee to Worldwide Rental Services Draft with M. Lessne (0.3); Draft and email Request to Produce of same to M. Lessne for review (0.3).

2/21/2012 0.70 87.50 Continue reviewing bill from accounting and revising exhibits for fee app.

3/27/2012 0.30 37.50 Review executed settlement agreement with Worldwide and assist A. Srour with calendaring deadline dates for same.

3/30/2012 0.20 25.00 Prepare and electronically file on court's docket Trustee's Motion to Approve Settlement with Worldwide.

3/30/2012 0.20 25.00 Scan and email D. Hramatulova draft of Trustee's Motion to Approve Settlement with Worldwide with exhibits.





3/8/2011 0.80 100.00 Prepare and upload Agreed Order to allow late filed claim by Collin and Sharen Latimer (0.1); Teleconferences with Courtroom Deputy re: same and hearing to be cancelled on 3/9/11 (0.2); Email to I. Reich and M. Lessne confirming same (0.1); Teleconfe rence with M. Lessne re: further revisions to Agreed Order (0.1); Make revisions, upload revised Agreed Order and teleconference with Judicial Assistant re: same (0.3).

3/9/2011 0.50 62.50 Review Order re: Collin and Sharen Latimer to allow late filed Claim and calendar same (0.2); Emails to I. Reich, M. Lessne and M. Dunn re: same (0.3).

3/15/2011 0.90 112.50 Review emails from Trustee and creditor S. Taylor re: claim (0.2); Check claims register, pull and review filed claim (0.3); Email to M. Lessne and I. Reich re: same (0.2); Follow-up email to creditor re: same (0.2).

4/6/2011 0.50 62.50 Review email from Trustee's office re: additional inquiry from Sandra Taylor (0.1); Follow-up call (0.3) and email to Sandra Taylor re: proof of claim filed with the court on 10/26/2009 (0.1).

6/17/2011 1.00 125.00 Review emails from I. Reich and C. Hinks re: proof of claim filed (0.3); Check claims register re: same (0.3); Email filed claim info to I. Reich (0.1); Download filed claim (0.1); Email creditor website and filed claim to C. Hinks (0.2).



12/8/2011 0.30 37.50 Follow-up with I. Reich re: First and Final Fee Application.

12/8/2011 3.50 437.50 Review bill and start drafting summary for First and Final Fee Application.

12/9/2011 2.30 287.50 Continue drafting summary for First and Final Fee Application and review of bill.

12/13/2011 0.50 62.50 Discuss First and Final Fee Application with I. Reich.

12/14/2011 5.00 625.00 Continue working on summary for First and Final Fee Application, reviewing bill and draft exhibit charts for same.

12/15/2011 1.50 187.50 Continue working on Fee Application.

12/20/2011 2.00 250.00 Continue working on Fee Application.

12/21/2011 5.10 637.50 Continue working on draft of Fee Application and exhibits for same (5.0); Email same to I. Reich for review (0.1).

2/20/2012 1.00 125.00 Contact accounting for updated bill re: fees and expenses and work on revising draft of fee app for same.

2/22/2012 2.50 312.50 Continue updating exhibits for fee application to include fees and costs through January 31, 2012.





3/2/2011 0.80 100.00 Emails and teleconferences with M. Lessne and I. Reich re: Motion and Order to continue the Pretrial Conferences and all related deadlines regarding same.

3/2/2011 0.50 62.50 Meeting with M. Lessne re: files and production of docs.

3/3/2011 3.50 437.50 Review emails/electronic & hard files for discovery request.

3/4/2011 4.20 525.00 Continue reviewing and cataloging files re: discovery request.

3/8/2011 3.10 387.50 Continue reviewing files for document production.

3/9/2011 1.20 150.00 Continue reviewing files and assist M. Lessne re: discovery request.

3/10/2011 1.00 125.00 Meeting with M. Lessne re: pretrial and trial deadlines and upcoming discovery (0.6); Contact R. Meacham's office re: extension for discovery request (0.2); Follow-up with M. Lessne re: same (0.2).

3/14/2011 0.30 37.50 Follow-up with R. Meacham's assistant re: additional extension to 4/12 to respond to discovery request (0.2); Email same to M. Lessne confirming extension (0.1).

3/15/2011 0.40 50.00 Discuss production of documents and files with M. Lessne (0.3); Email list re: same (0.1).

3/16/2011 2.00 250.00 Assist M. Lessne with production of documents.

3/17/2011 0.70 87.50 Emails (0.3) and teleconferences with M. Lessne and I. Reich re: Response to Request for Production of documents (0.4).

4/12/2011 1.30 162.50 Teleconferences with R. Meacham's office re: outstanding discovery and continued pretrial conference (0.4); Follow-up and discuss same with M. Lessne (0.3); Assist M. Lessne with matters re: discovery due and pretrial stipulation (0.6).

4/13/2011 0.50 62.50 Follow-up with L. Bobrow and L. Raymond and email them the Trustee's Response to Worldwide's request for production of documents and responsive documents (0.2); Follow-up with M. Lessne re: responsive documents (0.3).

4/19/2011 0.30 37.50 Meeting with M. Lessne re: Agreed Motion to continue 4/26 hearing and pretrial conferences.

4/19/2011 1.30 162.50 Draft and finalize Agreed Motion and proposed order to continue 4/26 hearing and pretrial conferences (1.1), and email same to M. Lessne (0.1); Revise certificate of service re: Order granting Motion continuing to 4/26 and email same to M. Lessne (0. 1).

4/25/2011 0.20 25.00 Teleconference with L. Raymond at R. Meacham's office re: responsive non-electronic discovery documents for Worldwide Rental (0.2)

5/17/2011 0.70 87.50 Emails and teleconferences with M. Lessne and N. Nicole re: response to Worldwide Rental's request to produce and responsive documents.

5/19/2011 0.40 50.00 Review email from N. Nicole re: Worldwide Rental (0.1); Follow-up with M. Lessne re: same (0.3).



5/23/2011 1.60 200.00 Emails with N. Nicole re: Worldwide Rental (0.2); Meeting with N. Nicole re: responsive documents for Worldwide Rental (1.4).

6/1/2011 0.40 50.00 Emails and teleconferences with N. Nicole re: production of documents to Worldwide.

6/3/2011 0.90 112.50 Emails and teleconferences with N. Nicole re: documents to produce to Worldwide (0.5); File management re: same (0.4)

6/6/2011 0.40 50.00 Review emails and files from N. Nicole re: production of docs to Worldwide.

6/8/2011 0.40 50.00 Emails and tc's with N. Nicole and M. Lessne re: production docs.

6/15/2011 0.40 50.00 Follow-up with N. Nicole re: Worldwide.

6/16/2011 0.50 62.50 Attention to matters re: doc production for Worldwide (0.3); Review emails re: same (0.2).

12/9/2011 1.30 162.50 Prepare Second Amended Complaint for M. Lessne.

12/15/2011 0.30 37.50 Discuss next steps in case re: dropping parties in Dunn v. Clearwater with M. Lessne.

12/20/2011 0.10 12.50 Draft COS re: Order Granting Motion for Leave to Amend Complaint (0.1);

1/9/2012 0.40 50.00 Review Expert Witness Report and draft Notice of Filing same (0.3); Email draft of same to I. Reich for review (0.1).

1/20/2012 0.50 62.50 Numerous teleconferences with the court re: e-filed Motions to Continue 1/23 pretrial conferences in both adversary proceedings.

1/20/2012 2.50 312.50 Draft Motions and proposed Orders to Continue 1/23 pretrial conferences in both adversary proceedings (1.5); Revise same (0.4); Prepare and electronically file on court's docket Motion to Continue 1/23 pretrial conferences in both adversary proceed ings (0.4); Upload proposed Orders for both cases to the court's website (0.2).

1/20/2012 0.40 50.00 Teleconference and follow-up email with Mr. Hampson re: continuance of pre-trial conferences and status of main case.

1/23/2012 0.20 25.00 Follow-up and teleconference with court confirming continuance of pre-trial conferences in both adversary cases.

1/23/2012 0.40 50.00 Draft two certificates of service re: Order continuing pre-trial conferences in both adversary cases.


$28,700.00229.60Total for Timekeeper Serrano-Cartagena



Solomon, Steven


6/16/2009 1.20 468.00 Strategy meeting with B. Elam and others.

6/19/2009 4.50 1,755.00 All hands strategy meeting with M. Dunn, J. Ryan, R. Schatzman, S. Khanakol, M. Berger, P. Garfinkel, R. Hincock.

6/22/2009 1.20 468.00 Review e-mail from P. Garfinkel and others regarding meeting, documents, assets (.3); begin research regarding same (.9)

6/30/2009 1.80 702.00 Finalize motion and order regarding extension to file schedules and other documents (1.4); memo regarding follow-up for same (.4)

7/1/2009 0.20 78.00 Review memos concerning bank accounts.

7/7/2009 1.00 390.00 Review memo from S. Khanorkar and analysis of bank accounts.

7/17/2009 0.40 156.00 Conference with R. Schatzman regarding P. Garfinkle, veil piercing, documents from bank.

7/22/2009 0.20 78.00 Conference with R. Schatzman regarding gathering information from P. Garkinkle.



7/21/2009 0.30 117.00 Review memos regarding status of meetings and conference with R. Schatzman regarding P. Garfinkle.



7/13/2009 0.20 78.00 Review T. Cash's proposal.


$4,290.0011.00Total for Timekeeper Solomon, Steven



Stirling, Susan


6/9/2010 1.00 125.00 Draft motions for contempt and for sanctions

8/12/2010 1.00 125.00 Review bids for title work (.4); assist with revising letter of intent (.3); correspond with M. Morrison re: Wabuska Mines (.3)



7/27/2010 1.10 137.50 Research title companies in Colorado for assistance with determining land claims and mining rights

7/28/2010 3.60 450.00 Discussions with title search mining rights companies in Colorado regarding preparing ownership and encumbrances report (2.7); furnish information regarding mines to potential title companies (.4); prepare memorandum regarding same to attorneys (.5)

7/29/2010 3.90 487.50 Meet with attorneys to develop 363 sale motion and hearing and proper notice guidelines (2.3); conferences with title companies to determine what is needed to perfect notice (.5); prepare memorandum to attorneys regarding same (.6); organize document s from lawyers Davies and Pappas regarding filed claims against Merendon Mining (.5)

7/30/2010 1.40 175.00 Conference with various Colorado title companies to obtain information about process of providing notice to all claimants regarding sale of mine (.6); prepare memorandum to attorneys regarding same (.8)

8/4/2010 1.50 187.50 Telephone calls to title companies and law firms in Colorado to locate company willing to do mining claims title research(.6); prepare correspondence to same (.3); follow up with sale of equipment motion for approval (.6)

8/5/2010 1.70 212.50 Conference L. Blanco regarding Colorado connections for title work (.3); telephone conference with additional title companies for work on titles to mine claims (1.1); prepare letter to law firm in Colorado to secure title searches (.3)

8/6/2010 4.20 525.00 Continue to develop service list (1.1); telephone conferences with title servicers in Colorado to find source for title work on mining claims (.50; work on equipment sale (2.6)

8/9/2010 2.60 325.00 Assist with revising Letter of Intent (.5); organize and catalog Gloria Management and Glory Hole mine documents (1.1); continue to revise complaint to add parties to receive notice (1.0)

8/10/2010 0.90 112.50 Revise motion to sell assets (.3); obtain information from Colorado title companies to assist us in pursuing buyer (.3); organize documents regarding mines into separate binders (.3)

8/12/2010 0.50 62.50 Continue to prepare notebook of all documents received to date to be used for 363 Sale



8/13/2010 2.60 325.00 Assist with equipment sale and or motion for approval (.4); research auction dates (.5); research water rights and cost of obtaining title to water rights (.5); update fees (.3); provide information to F. Santos for his auction (.4); continue to prep are notebooks with documents applicable to 363 Sale (.5)

8/16/2010 1.50 187.50 Organize and continue to create and maintain database of any title holders or claimants for motion to sell notice

8/17/2010 1.50 187.50 Add names to 363 Sale Complaint (.4); telephone call with Bonnie and Norm Frank regarding evidencing ownership of equipment (.3); review of correspondence from L. Weltzer regarding water rights to mines (.3); telephone call with Paul Garfinkle re: sa me (.5)

8/25/2010 0.80 100.00 Assist with developing means of identifying and locating all potential defendants (.5); telephone call with L. Weltzer's office regarding status of search (.3)

9/3/2010 1.90 237.50 Prepare certificate of service for motion for sale on expedited basis (.3); research addresses for entities and people who have laid claim to mines (1.2); revise letter of intent (.4)

9/7/2010 2.40 300.00 Assist attorneys with filing and preparing 363 sale motion (.8); review files for Sentinel Deeds (1.0); correspond with Paul Garfinkle regarding same (.3); correspond with L. Weltzer re title work for Gilpin County (.3).

9/14/2010 2.40 300.00 Review of title search/report from L. Weltzer regarding Gilpin County properties (.8); review of files for Clearwater Mining lawsuit and caption information (.9); prepare memo to attorneys regarding results of search (.7)

9/15/2010 4.70 587.50 Continue to review second title search for Gilpin County, and formulate new caption for adversary complaint (4.3); formulate new certificate of service for motion and complaint to be served (.4)

9/16/2010 3.10 387.50 Gather exhibits for Adversary Complaint (1.1); modify service list against two title searches (1.2); eliminate duplicate names (.8)

9/17/2010 3.90 487.50 Amend Complaint to add and take out names of potential defendants (1.2); research on internet addresses for names from Title Searches (1.5); prepare amended service list (1.2)

9/20/2010 4.80 600.00 Continue to edit, add, revise and refine adversary complaint and service list

9/21/2010 4.40 550.00 Further revisions to Adversary Complaint (1.8); draft motion to defer filing fees (1.1); revise service list with additional information from research on companies and individuals without addresses (.6); research waiving fees for trustees (.9)

9/24/2010 2.30 287.50 Revise complaint (1.0); prepare service list in alpha order (.6); amend sale motion in accordance with lack of buyer for property (.7)

9/29/2010 4.80 600.00 Revise, amend defendants and upload and file adversary complaint (4.3); telephone conferences with bankruptcy clerk for instructions of same (.5)



10/1/2010 1.80 225.00 Prepare comprehensive pleadings file for new adverse matter (1.3); telephone call with bankruptcy clerk for Judge Cristol regarding defendants and ability to track defaults, etc. (.5)

10/4/2010 1.30 162.50 Review of summons and court's notice of hearing (.3); coordinate with clerk of court for service of adversary complaint (1.0)

10/12/2010 2.10 262.50 Revise Amended Adverary Complaint

10/13/2010 0.50 62.50 Manage calls and information requests from third parties regarding sale motion filed

10/14/2010 1.00 125.00 Correct sale date and sale motion allegations (.5); cross reference prior exhibits and revise mailing matrix (.5)

10/20/2010 1.30 162.50 Review of attachments to amended adversary complaint to comply with requests from various claimants

11/8/2010 0.60 75.00 Review of recently filed pleadings in opposition to our motion for sale (.3); assist with preparing responses (.3)

11/10/2010 0.30 37.50 Review of objections to sale and process

12/2/2010 0.80 100.00 Assist with providing information to potential interested parties



4/15/2010 1.20 150.00 Assist with docketing, calendaring and providing notice to all parties regarding new pretrial date and new pretrial order.

4/19/2010 0.90 112.50 Develop chart of foreign defendants and determine status of service of same; telephone call to Cliff Hark regarding addresses and to seek compliance with court order.

4/22/2010 0.20 25.00 Continue to investigate addresses to serve foreign entities.

4/27/2010 0.90 112.50 Review of documents from Miami office to being inventory and document database.

5/3/2010 3.10 387.50 Continue investigation of current and active addresses and points of contact for Merendon companies doing business in Central America (2.0); numerous telephone calls to US Embassies and local consulate offices for information on corporate registry fo r Merendon (1.1)

5/4/2010 1.80 225.00 Modify interrogatories to foreign entities for information relevant to us being able to attain service (.7); discussions with attorney regarding same (.8); telephone calls to Mr. Hark and Mr. Yon regarding their client's current information (.3)

6/14/2010 0.30 37.50 Follow up with Mr. Brodsky on discovery responses (.2); review of SEC filing for new information on service of defendants (.1)

8/12/2010 0.40 50.00 Assist with posting Order on website (.2); review of Order (.1); update client with recent Order (.1)

1/18/2011 1.40 175.00 Assist with moving out deadlines for motion responses and sale procedures





8/12/2010 0.50 62.50 Telephone calls from claimants regarding status of claims (.5)

1/5/2011 0.80 100.00 Assist attorneys in responding to callers about filing late proofs of claim



7/8/2010 0.70 87.50 Begin drafting first interim fee application

7/9/2010 2.40 300.00 Revise draft of application for approval of interim fees (1.0); begin reviewing prebill and reports from accounting (1.4)

7/21/2010 1.90 237.50 Begin draft of fees and costs for first interim application for approval

7/22/2010 1.30 162.50 Compare prebill, activity reports and costs to numbers in first interim fee application

7/23/2010 1.40 175.00 Continue to develop first interim fee application (.6); clarify time entries and task codes corrected (.8)

7/26/2010 4.50 562.50 Continue to formulate first interim fee application numbers and task codes (4.1); conference with attorney I. Reich to confirm details (.4)

7/27/2010 0.90 112.50 Corrections to first interim fee application (.7); correspondence regarding fee application to associated accountants (.2)

9/7/2010 1.80 225.00 Begin revising fee application

9/8/2010 3.60 450.00 Prepare amended fee and cost application to file with court for pre approval of our compensation

9/9/2010 0.90 112.50 Review of local rules to ensure that fee application meets all guidelines and rules (.4); revise application with new dates of time period requested and continue to revise number of hours (.5)



4/20/2010 0.50 62.50 Attempts to locate addresses for foreign defendants to serve process, telephone call again to Cliff Hark for same information.

5/5/2010 2.40 300.00 Finalize and get out interrogatories to Mr. Hark and Mr. Brodsky regarding their foreign entity clients' addresses and agents information (7 sets in total) (1.8); respond to email from Mr. Brodsky regarding same (.2); review responses from US Embassy and Consulate's offices in Belize and Honduras and make additional attempts to find information regarding Merendon's current registered agent (.4)



5/6/2010 0.30 37.50 Continue to monitor responses from foreign embassies regarding information on Merendon Mining.

5/12/2010 1.40 175.00 Continue attempts to confirm address and agent information for Merendon in Peru and Venezuela (.6); reach out to US Embassy in both countries for assistance (.3); draft motion to compel to Whitelock for identification of accounts held by Federated an d production of records for all documents requested in our subpoena (.5)

5/14/2010 0.20 25.00 Review responses from US Embassy in Peru regarding Merendon's address and information.

5/17/2010 0.50 62.50 Update attorneys on status of service of foreign defendants represented by Mr. Hark and Mr. Yon (.1); telephone conference with Mr. Yon as to whereabouts of addresses (.2); prepare memorandum to attorneys with response from Mr. Yon (.2)

6/7/2010 0.50 62.50 Telephone conferences with Cliff Hark and Richard Brodsky regarding discovery responses (.3); prepare memorandum to attorneys regarding same (.2)

6/9/2010 1.80 225.00 Pull all Order requiring foreign defendants and Sorenson defendants to provide information or to perform tasks (.4); assist attorney with drafting motions to compel (1.4)

6/10/2010 1.90 237.50 Assist with preparing and finalizing motion to compel to two defendants (1.4); review of all orders concerning disclosure of information and provide same to attorneys (.5)

6/11/2010 1.20 150.00 Prepare exhibits for filing with motion to compel (.9); upload and file motion with court and electronically send to affected parties (.3)

8/2/2010 0.70 87.50 Prepare draft of motion to approve sale of equipment

8/12/2010 0.50 62.50 Revise complaint with new names

8/16/2010 0.30 37.50 Conference with P. Garfinkle regarding water rights and ownership (.3)

10/14/2010 0.90 112.50 Revise and amend adversary complaint to add parties (.9)

11/10/2010 0.20 25.00 Review of pleadings to see if service perfected on Estate of Robert Barnes (.1); review of request from Patricia Stearns (.1)

11/11/2010 0.40 50.00 Prepare information for response to Patricia Redmond's inquiry about lack of service and notice of hearing

11/16/2010 0.60 75.00 Obtain information for attorney for G. Grieve regarding title search (.3); conference with L. Weltzer regarding same (.3)

11/24/2010 0.50 62.50 Upload and file motion to dismiss counterclaim

12/3/2010 0.80 100.00 Assist with preparing certificate of mailing notice of withdrawal

12/7/2010 0.60 75.00 Review of counterclaim (.3); calendar deadline to respond (.3)

1/10/2011 1.20 150.00 Process recently received Orders and discovery requests and assist with moving deadlines out



1/13/2011 0.90 112.50 Process discovery from defendants (.4); work on getting extensions (.5)

1/19/2011 2.20 275.00 Assist with providing title search results to attorneys calling about why they are being named in lawsuit (1.4); contact all attorney involved to see if they will agree to move out deadlines another month (.8)

1/20/2011 2.80 350.00 Upload Orders in all cases to continue deadlines and push out pretrials (.5); survey responses from all parties in three cases to see if any objections (1.2); process newly filed adversary proceeding (1.1)

2/4/2011 2.60 325.00 Revive efforts to obtain service on foreign defendants (.9); review of all attempts to serve and prepare appropriate filings with court (1.7)

2/7/2011 0.50 62.50 Telephone conference with clerk of court for alias summons to certain foreign defendants

2/9/2011 5.30 662.50 Prepare attorney for telephone conference with Mr. Sakalo (1.1); prepare alias summons (1.3); review of entire dockets in all three cases for any unresolved attempts at service of all defendants to make sure everyone aware of upcoming pretrials (2.9)

2/10/2011 0.70 87.50 Assist with preparing alias summons (.3); conference with clerk (.2); prepare certificate of mailing for foreign defendants (.2)



2/10/2011 0.50 62.50 Field phone calls from investors and other seeking information for tax purposes


$17,250.00138.00Total for Timekeeper Stirling, Susan



Terzo, Frank


6/8/2009 1.00 450.00 Discussion and conference with B. Elam regarding on Status of an entry of an Order for Relief in the Involuntary Action and Concerns by the petitioning creditors to use GrayRobinson as general Counsel for the Trustee

6/10/2009 1.50 675.00 Conference with I. Reich , B. Elam and forwarded e-mails to M. Dunn regarding representation as general counsel to the Trustee and conference call with B. Mukamal to be engaged to do forensic work

6/11/2009 1.00 450.00 E-mail correspondence and response to Pat Scott regarding standing issues

6/11/2009 1.00 450.00 Conference Call with I. Reich & David Cimo regarding taking up General Representation through M. Dunn

6/12/2009 2.30 1,035.00 Conference call with B. Elam, I. Reich , Bob Schatzman, B. Mukamal and Morris Berger

6/16/2009 0.40 180.00 Conference call with R. Schatzman regarding the status of the case.

6/22/2009 1.40 630.00 Review of all e-mails pertaining to the Status of the Discovery that need to be made in order to recover assets

6/23/2009 0.80 360.00 Conference Call with R. Schatzman on Harry Gurwitzh

6/29/2009 1.00 450.00 Review of various E-mails concerning the current status of Discovery of Assets

7/27/2009 1.70 765.00 Meeting with R. Schatzman regarding current status of investigation.



8/14/2009 1.80 810.00 Conference with B. Mukamal regarding the forensic analysis being performed on Merendon Mining and whether the forensic analysis has demonstrated recoverable avoidance actions.


$6,255.0013.90Total for Timekeeper Terzo, Frank



Wagner, Paige


12/8/2009 4.50 675.00 Begin to draft Motion by Chapter 7 Trustee for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of the Estate, and Injunctive Relief.

12/9/2009 4.40 660.00 Continue to draft Motion by Chapter 7 Trustee for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of the Estate, and Injunctive Relief. (4.3). Draft e-mail to I. Reich with attached Motion for review. (0.1).

12/14/2009 3.90 585.00 Research case law re:motion for turnover of property of the estate and standard for injunctive relief. (1.0). Revise Motion by Chapter 7 Trustee for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of the Estate, and Injunctiv e Relief. (2.8). Draft e-mail to I. Reich with attached Motion for review. (0.1).

1/8/2010 5.60 840.00 Telephone correspondence with I. Reich re:drafting Order Granting Motion for Substantive Consolidation of Non-Debtor Entities, Turnover of Property of the Estate, and Injunctive Relief. (0.3). Draft Order. (5.3).



11/13/2009 5.50 825.00 Review bankruptcy pleadings, schedules, and Affidavit of Paul Garfinkle in preparation of drafting Adversary Complaint. (2.5) Begin to draft Adversary Complaint. (3.0).

11/16/2009 6.00 900.00 Continue to draft Adversary Complaint.

11/17/2009 3.80 570.00 Finalize drafting Adversary Complaint. (1.0). Review, edit, and revise same. (2.8).



12/1/2009 0.50 75.00 Telephone correspondence with I. Reich re:revisions to Adversary Complaint.

12/10/2009 4.50 675.00 Revise Adversary Complaint with comments from I. Reich, R. Shatzman, and S. Khanorkar.

12/11/2009 2.80 420.00 Continue to revise Adversary Complaint.


$6,225.0041.50Total for Timekeeper Wagner, Paige



Wegel, Kirsten


2/2/2010 2.00 220.00 Prepare Suggestions of Bankruptcy

3/23/2010 3.00 330.00 Record Orders in other jurisdictions.

3/26/2010 2.00 220.00 Prepare and send out Orders to be Recorded in various jurisdictions.



2/23/2010 1.50 165.00 Obtain recording information to record Order Granting Motion by Chapter 7 Trustee For Substantive Consolidation of Non-Debtor Entities in four separate jurisdictions.

2/25/2010 1.50 165.00 Prepare recording transmittals and orders to be recorded in various jurisdictions.

2/26/2010 3.50 385.00 Prepare Orders to be sent and recorded in various jurisdictions;


$1,485.0013.50Total for Timekeeper Wegel, Kirsten



$716,885.002351.80

