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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: )

) Chapter 7

JOHN T. LI, ) Case No. 16-24660

) Hon. Timothy A. Barnes

) Hearing Date: Tues., Aug. 7, 2018

Debtor. ) @ 10:30 a.m.

NOTICE OF MOTION

PLEASE TAKE NOTICE that Tuesday, August 7, 2018 at 10:30 a.m., or as soon 

thereafter as may be possible, we shall appear before the Honorable Timothy A. Barnes or any 

other Judge sitting in his stead, in Courtroom 744, of the Dirksen Federal Building, 219 South 

Dearborn, in Chicago, Illinois, and shall then and there present the attached Application of 

Trustee’s Attorneys for the Allowance of Final Compensation and Reimbursement of

Expenses, a copy of which is hereby served upon you.

/s/ Norman B. Newman

Norman B. Newman, Trustee for the bankruptcy estate 

of John T. Li

Norman B. Newman, ARDC No. 02045427

MUCH SHELIST, P.C.

191 North Wacker Drive, Suite 1800

Chicago, Illinois 60606

Telephone: 312.521.2000

Facsimile: 312.521.2100

CERTIFICATE OF SERVICE

Norman B. Newman, an attorney, hereby certifies that on July 16, 2018, he electronically 

filed this Application for Compensation with the Clerk of the Court via the Court’s CM/ECF 

system which will send electronic notification to those individual registered to receive notice.

/s/Norman B. Newman

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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: )

) Chapter 7

JOHN T. LI, ) Case No. 16-24660

) Hon. Timothy A. Barnes

) Hearing Date: Tues., 8/7/18 @ 10:30 a.m.

Debtor. )

APPLICATION OF TRUSTEE’S ATTORNEYS FOR THE ALLOWANCE OF FINAL 

COMPENSATION AND REIMBURSEMENT OF EXPENSES

Much Shelist, P.C. (“Much Shelist”), attorneys for Norman B. Newman, not individually 

but solely as the Chapter 7 Trustee herein, (the "Trustee") moves this Court, pursuant to Section 

330 of the Bankruptcy Code and Bankruptcy Rule 2016, for the allowance of final compensation 

and reimbursement of expenses for services rendered during the period September 27, 2016 

through June 12, 2018. In support of this application, Much Shelist states as follows:

1. On August 1, 2016, the Debtor filed his petition for relief under Chapter 7 of the 

Bankruptcy Code.

2. On October 5, 2016, this Court entered an Order authorizing the Trustee to 

employ Much Shelist as his attorneys in this case. This application includes legal services 

rendered by the Trustee. Mr. Newman has taken care to distinguish his legal services from his 

Trustee services. Attached hereto as Exhibit “A” is an itemization of Mr. Newman’s Trustee 

services. Much Shelist is not seeking compensation for the services identified on Exhibit “A” as 

part of this Application. Mr. Newman is filing a separate Application for Trustee Compensation.

3. Other than as permitted under Section 504 of the Bankruptcy Code, Much Shelist 

has no agreement with any person or firm whatsoever with regard to its compensation in this 

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case. To date, Much Shelist has not received any compensation for services rendered as 

attorneys for the Trustee. 

4 Much Shelist is entitled to receive final compensation in the amount of 

$19,814.00 plus reimbursement of expenses in the amount of $367.10 for services 

rendered during the period of September 27, 2016 through June12, 2018.

5. Much Shelist provided 31.50 hours of services on behalf of the Trustee 

during the time period covered by this application.

6. The following is a summary of time expended, by individual, during the 

time period covered by this application. The summary below references their rates 

during the applicable time period.

Attorney Hours Expended Hourly Rate Amount

Norman B. Newman 6.20 hrs. $640.00/hr. $3,968.00

Norman B. Newman 18.00 hrs. $655.00/hr. 11,790.00

Jeffrey M. Schwartz 4.90 hrs. $600.00/hr. 2,940.00

Jeffrey L. Gansberg 2.40 hrs. $465.00/hr. 1,116.00

TOTAL 31.50 hrs. $19,814.00

7. Attached hereto as Exhibit “B” is a statement of legal services rendered. The 

services are listed chronologically and are separated by activity. The services were rendered in 

connection with and in furtherance of assisting the Trustee in the performance of his duties as 

delineated by §704 of the Bankruptcy Code. This application complies with the standards 

enunciated in In re Continental Securities Litigation, 572 F. Supp. 931 (N.D. Ill. 1983) modified

692 F.2d 766 (7

th

Cir. 1992). 

8. At all times relevant hereto, Much Shelist provided legal services in the most 

efficient and cost effective manner. Much Shelist's goal was to obtain a positive resolution of the 

matter at hand, while in the process minimizing the costs to the estate. As more fully detailed in 

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the statement of services attached hereto as Exhibit “B”, Much Shelist provided services with 

respect to the following matters:

A. General Administration (Tab No. 1): Much Shelist provided 1.10 hours of 

general administrative services to the Trustee. At the Section 341 meeting held in this case, the 

Trustee discovered that the Debtor held a 50% membership interest in two Illinois Limited 

Liability Companies, JTL Properties, LLC and JTL2 Properties LLC (the “LLCs”). The LLCs 

owned, in the aggregate, three parcels of real estate. The remaining 50% membership interest 

were held, in the aggregate, by James Li and Teresa Li, the Debtor’s brother and sister-in-law 

(the “Li’s). Counsel reviewed documents relating to Debtor’s membership interest in the LLCs, 

including operating agreements, leases and loan documents. Much Shelist discussed with the 

Li’s the possibility of the LLCs employing a real estate broker to sell the real estate owned by the 

LLCs. As an alternative, the Trustee also discussed selling the Debtor’s membership interest in 

the LLCs to the Li’s. Time was also spent communicating with counsel for the Debtor regarding 

adding additional creditors to the Debtor’s Schedules and obtaining a status update on the sale of 

the LLC membership interests.

The individual who provided services in connection with the General Administration and 

the time expended by him is as follows:

Attorney Hours Rate Total

Norman B. Newman 1.10 hrs. $640.00/hr. $704.00

Total: 1.10 hrs. $740.00

B. Retention of Professionals (Tab No. 2): Much Shelist expended 7.00 hours in 

connection with the retention of professionals. Counsel engaged in telephonic and written 

communications with the Li’s and two real estate brokers, Frontline Real Estate Partners and 

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Keller Williams. Time was spent reviewing and revising the Brokers’ listing agreements to sell 

the real estate owned by the LLCs. Much Shelist expended time on the preparation of pleadings 

and appearances in Court on the Trustee’s Motion to Employ Attorneys and the Trustee’s Motion 

to Employ Accountants. Much Shelist attorneys communicated with the Trustee’s accountant 

with respect to the preparation of its engagement letter and affidavit.

The individuals who provided services in connection with this matter and the time 

expended by them are as follows:

Attorney Hours Rate Total

Norman B. Newman 3.60 hrs. $640.00/hr. $2,304.00

Norman B. Newman 2.60 hrs. $655.00/hr. 1,703.00

Jeffrey L. Gansberg .80 hrs. $465.00/hr. 372.00

TOTAL 7.00 hrs. $4,379.00

C. Disposition of Assets (Tab No. 3): Much Shelist expended 20.10 hours in 

connection with the disposition of assets. As previously mentioned, the LLCs owned three 

parcels of real estate. Through the efforts of Frontline Real Estate Partners, the LLCs’ real estate 

broker, an offer was received on one of the three parcels of property. Much Shelist reviewed the 

operating agreements for the LLC which owned the subject property, existing leases on the 

property, as well as a proposed contract and provided suggested revisions to same. In addition, 

counsel communicated with all parties involved with the pending sale and the status of required 

mortgage contingencies. Time was spent drafting a motion for authority to implement a sale of 

real estate. Before the motion could be heard by the Court, the buyer’s attorney notified the 

Trustee that the buyer could not obtain requisite financing resulting in the termination of the 

contract. Counsel prepared a notice of withdrawal for the pending motion and communicated 

with the real estate broker to return the earnest money.

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Shortly thereafter, counsel for the Trustee received an expression of interest from Cash 

for Interests, LLC to purchase the Debtor’s LLC membership interests. Time was spent 

reviewing and drafting a non-disclosure agreement, reviewing operating agreements and tax 

returns of the LLC. Counsel communicated extensively with the Li’s real estate attorney and the 

Li’s regarding numerous mortgage contingencies that needed to be addressed and communicated

with the Mortgage Holder Bank’s attorney regarding the outstanding loans on each of the 

properties and the Bank’s position as to sale proceeds. Once again, the contract was cancelled.

After a year of efforts to sell the real estate owned by the LLCs the Trustee received an 

offer from the Li’s to purchase his 50% interest in the two LLC’s which resulted in a shift of the 

burden of selling the real estate to the Li’s and allowed the Trustee to receive the sum of 

$20,000.00 to distribute to the creditors of this estate. Time was spent by Much Shelist drafting 

a motion to sell the Trustee’s interest in the Debtor’s membership interests in the LLCs and 

appearing in Court on same. Upon completion of the sale, Much Shelist attorneys drafted a Bill 

of Sale and provided same to the Li’s. 

The individuals who provided services in connection with the Disposition of Assets and 

the time expended by them are as follows:

Attorney Hours Rate Total

Norman B. Newman 1.50 hrs. $640.00/hr. $960.00

Norman B. Newman 12.10 hrs. $655.00/hr. 7,925.50

Jeffrey L. Gansberg 1.60 hrs. $450.00/hr. 720.00

Jeffrey M. Schwartz 4.90 hrs. $600.00/hr. 2,940.00

TOTAL 20.10 hrs. $12,545.50

D. Claims Administration/Analysis (Tab No 4.): A total of .20 hours of time was 

spent communicating with counsel for Toyota Motor Credit regarding the allowance of Toyota’s 

claim as an unsecured claim for distribution purposes.

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The individual who provided services in connection with the Administration of Claims 

and the time expended by him is as follows:

Attorney Hours Rate Total

Norman B. Newman .20 hrs. $655.00/hr. $131.00

TOTAL .20 hrs. $131.00

E. Tax Issues (Tab No 5.): A total of 1.00 hour of time was spent by Norman B. 

Newman communicating with the Trustee's accountant regarding tax consequences from the sale 

of the Trustee’s interest in the Debtor’s membership interests in the LLCs. Time was also spent 

reviewing and transmitting federal and state tax returns. 

Attorney Hours Rate Total

Norman B. Newman 1.00 hrs. $655.00/hr. $655.00

TOTAL 1.00 hrs. $655.00

F. Fee Matters (Tab No. 6): Much Shelist expended total of 2.10 hours of time 

dealing with the preparation of Much Shelist’s and the Trustee’s Accountant‘s final fee 

applications. 

Attorney Hours Rate Total

Norman B. Newman 2.10 hrs. $655.00/hr. $1,375.50

TOTAL 2.10 hrs. $1,375.50

9. During the time period covered by this Application, Much Shelist incurred out-ofpocket expenses in the amount of $367.10. Attached hereto as Exhibit “C” is an itemization of 

Much Shelist’s out-of-pocket expenses. The charge for photocopies is 10¢ per page. Facsimile 

charges are billed at the rate of $1.00 per page, incoming and outgoing. Much Shelist asserts that 

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these out-of-pocket expenses were reasonable and necessary expenses incurred in its 

representation of the Trustee.

10. By reason of the foregoing, Much Shelist states that it is entitled to a final award 

of compensation and reimbursement of out-of-pocket expenses for services rendered to the 

Trustee in this matter.

11. Much Shelist recognizes that the Trustee is not holding sufficient funds on hand 

to pay the requested compensation amount in full. Much Shelist is willing to accept payment of 

the funds remaining after payment of the Trustee’s Accountants, awarded Trustee’s 

Compensation, and a five percent (5%) distribution to allowed unsecured claims.

WHEREFORE, Much Shelist, P.C. respectfully requests that this Court enter an Order 

as follows:

1. Granting this Application and awarding Much Shelist final compensation in the 

amount of $19,814.00 plus reimbursement of out-of-pocket expenses in the amount of $367.10

for services rendered during the period September 27, 2016 through June 12, 2018.

2. Authorizing the Trustee to pay Much Shelist the amount awarded forthwith as a 

Chapter 7 expense of administration of this estate; and

3. Granting such other and further relief as this Court deems just and appropriate.

Respectfully Submitted,

Much Shelist, P.C.

By: /s/Jeffrey L. Gansberg 

One of Its Attorneys

Jeffrey L. Gansberg ARDC # 06242943)

MUCH SHELIST, P.C.

191 N. Wacker Drive ,Suite 1800

Chicago, IL 60606

(312) 521-2000

nnewman@muchshelist.com

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IN THE UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

IN RE: )

) Chapter 7

JOHN T. LI, ) Case No. 16-24660

) Hon. Timothy A. Barnes

) Hearing Date: Tues., August 7, 2018

Debtor. ) @ 10:00 a.m.

COVER SHEET FOR APPLICATION FOR PROFESSIONAL SERVICES

Name of Applicant: Much Shelist, P.C.

Authorized to provide professional services to: Norman B. Newman, Chapter 7 Trustee 

Date of Order Authorizing Employment: October 5, 2016

Period for which compensation is sought: September 27, 2016 through June 12, 2018

Amount of fees sought: $19,814.00

Amount of expense reimbursement sought: $367.10

Retainer previously received: $0.00

This is a(n): Interim Application Final Application X

Prior fee applications: 

Date Filed Period Covered Total Requested 

(Fees and 

Expenses) 

Total Allowed Any Amount 

Ordered Withheld

The aggregate amount of fees and expenses paid to the Applicant to date for services 

rendered and expenses incurred herein is: $0.00

Dated: 7/16/18 MUCH SHELIST, P.C.

By: /s/Jeffrey L. Gansberg

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