UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM 

 Chapter 7 

CHANCE & ANTHEM, LLC, 

 Debtor. 

____________________________________/ 

ROBERT C. FURR not individually but ADV. NO. 19-01298-MAM 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC, 

Plaintiff, 

v. 

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES, 

et al. 

Defendants. 

____________________________________/ 

SUMMARY OF ATTORNEYS FEES AND COSTS INCURRED BY 

GENOVESE JOBLOVE & BATTISTA, P.A. SUBMITTED PURSUANT TO THE 

ORDER [ECF NO. 381] GRANTING CHAPTER 7 TRUSTEE ROBERT C. FURR’S 

RENEWED MOTION (I) TO STRIKE CERTAIN AFFIRMATIVE DEFENSES IN 

DEFENDANT JEFFREY SISKIND’S AMENDED ANSWER AND AFFIRMATIVE 

DEFENSES [ECF NO. 272] AND ALLEGED COUNTERCLAIM [ECF NO. 273]; 

(II) FOR AN ORDER TO SHOW CAUSE WHY JEFFREY SISKIND SHOULD NOT 

BE HELD IN CONTEMPT OF COURT; AND (III) FOR SANCTIONS [ECF NO. 281] 

1. Name of Applicant: Genovese Joblove & Battista, P.A. 

2. Role of Applicant: Counsel to the Chapter 7 Trustee 

3. Name of Certifying Professional: John H. Genovese, Esq. 

4. Date Case Filed: January 29, 2018 

5. Date of Retention Order: July 24, 2018 [ECF No. 103] 

6. Period for this Application: April 13, 2020 through June 19, 2020 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 1 of 29
2 

7. Amount of Compensation Sought: $58,885.00 

8. Amount of Expense Reimbursement: $126.40 

9. Total Amount of Compensation Sought 

During Case N/A 

10. Total Amount of Expense 

Reimbursement Sought During Case N/A 

11. Amount of Original Retainer: N/A 

12. Current Balance of Retainer Remaining: N/A 

13. Last monthly operating report filed: N/A 

14. If case is Chapter 11, Current funds in 

Chapter 11 estate: N/A 

15. If case is Chapter 7, current funds held $36,473.251

 by Chapter 7 trustee: 

 

 

1 The GJB Law Firm, at this time, does not seek a fee award payable from the Debtor’s bankruptcy estate. 

The following Application represents the amount of fees and costs incurred in connection with the 

prosecution of the Motion to Strike, which have been assessed as sanctions against Jeffrey Siskind 

pursuant to the Court’s Order Granting [ECF No. 381] Plaintiff Chapter 7 Trustee Robert C. Furr’s 

Renewed Motion (I) to Strike Certain Affirmative Defenses in Defendant Jeffrey Siskind’s Amended 

Answer and Affirmative Defenses [ECF No. 272] and Alleged Counterclaim [ECF No. 273]; (II) for an 

Order to Show Cause Why Jeffrey Siskind Should Not Be Held in Contempt of Court; and (III) for 

Sanctions [ECF No. 281]. 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 2 of 29
UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

www.flsb.uscourts.gov

In re: Case No. 18-16248-BKC-MAM 

 Chapter 7 

CHANCE & ANTHEM, LLC, 

 Debtor. 

____________________________________/ 

ROBERT C. FURR not individually but ADV. NO. 19-01298-MAM 

as Chapter 7 Trustee of the estate of the 

Debtor, Chance & Anthem, LLC, 

Plaintiff, 

v. 

JEFFREY M. SISKIND, individually and 

d/b/a SISKIND LEGAL SERVICES, 

et al. 

Defendants. 

____________________________________/ 

APPLICATION FOR AWARD OF ATTORNEYS FEES AND COSTS INCURRED BY 

GENOVESE JOBLOVE & BATTISTA, P.A. SUBMITTED PURSUANT TO THE 

ORDER [ECF NO. 381] GRANTING CHAPTER 7 TRUSTEE ROBERT C. FURR’S 

RENEWED MOTION (I) TO STRIKE CERTAIN AFFIRMATIVE DEFENSES IN 

DEFENDANT JEFFREY SISKIND’S AMENDED ANSWER AND AFFIRMATIVE 

DEFENSES [ECF NO. 272] AND ALLEGED COUNTERCLAIM [ECF NO. 273]; 

(II) FOR AN ORDER TO SHOW CAUSE WHY JEFFREY SISKIND SHOULD NOT 

BE HELD IN CONTEMPT OF COURT; AND (III) FOR SANCTIONS [ECF NO. 281] 

 John H. Genovese, Esq. and the law firm of Genovese, Joblove & Battista, P.A. (the 

“GJB Law Firm”), pursuant to 11 U.S.C. § 330 and Rule 2016, Federal Rule of Bankruptcy 

Procedure, and the requirements set forth in the Guidelines incorporated in Local Rule 2016-

1(B), and having been approved by this Court as attorneys for the Chapter 7 Trustee, Robert C. 

Furr (the “Trustee”) [Main Case, ECF No. 103], file their application for compensation, payable 

to the GJB Law Firm as sanctions assessed against Jeffrey Siskind, pursuant to the Order

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2 

Granting [ECF No. 381] (the “Sanctions Order”) Plaintiff Chapter 7 Trustee Robert C. Furr’s 

Renewed Motion (I) to Strike Certain Affirmative Defenses in Defendant Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 272] and Alleged Counterclaim [ECF No. 

273]; (II) for an Order to Show Cause Why Jeffrey Siskind Should Not Be Held in Contempt of 

Court; and (III) for Sanctions [ECF No. 281] (the “Motion to Strike”). The exhibits attached to 

this Application, pursuant to the Guidelines, are: 

Exhibits “1-A” and “1-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. The 

requested fees are itemized to the tenth of an hour. 

 The Applicant believes that the requested fees in the amount of $58,885.00 for 106 hours 

worked are reasonable considering the twelve factors enumerated in Johnson v. Georgia 

Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974), made applicable to bankruptcy proceedings 

by In re First Colonial Corp. of America, 554 F.2d 1291 (5th Cir. 1977). 

INTRODUCTION 

 The Court and the parties are well aware of the facts and circumstances that gave rise to 

the Motion to Strike. By way of summary, Jeffrey Siskind is a member of the Florida Bar and an 

adversary defendant in this litigation who is representing himself pro se. On April 9, 2020, Mr. 

Siskind filed two affirmative defenses and an alleged counterclaim alleging the Trustee was 

somehow improvidently appointed in this bankruptcy case, and as a result, making the instant 

adversary proceeding is a “fraud on the court” (the “Alleged Counterclaim”) [ECF No. 273]. 

Mr. Siskind had repeatedly made this unfounded allegation in this bankruptcy case and had 

retreated each time the matter was called for hearing. In fact, Mr. Siskind himself had submitted 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 4 of 29
3 

to the Court uncontroverted proof that the Trustee’s interim appointment in this case was made 

in the ordinary course by the Office of the United States Trustee. The Alleged Counterclaim 

sought to assert claims against the Trustee, individually, as well as the GJB Law Firm and 

attorney with the firm involved in this litigation. 

 On April 23, 2020, the Trustee, through the GJB Law Firm, filed the Motion to Strike. 2

On May 14, 2020, the Court noticed an evidentiary hearing on the Motion to Strike and issued a 

pre-trial order for an evidentiary hearing [ECF No. 326]. Thereafter, the GJB Law Firm 

undertook preparation for the evidentiary hearing by (i) conducting the deposition of Jeffrey 

Siskind; (ii) preparing an evidentiary presentation through trial exhibits and witness lists that 

were served and submitted to the Court and the parties; (iii) designating the testimony of Jeffrey 

Siskind; (iv) preparing a joint stipulation of facts; and (iv) preparing to Chapter 7 Trustee for his 

direct examination at the hearing. 

 On June 5, 2020, the Court convened the evidentiary hearing by Zoom and advise the 

parties that the Court was prepared to rule on the materials submitted to the Court. At the 

hearing, the Court awarded the GJB Law Firm compensatory sanctions in connection with the 

Motion to Strike: 

“To the extent that ordering compensatory sanctions requires a finding of bad 

faith, the Court finds that the assertion of the second affirmative defense and 

the counterclaims is indicative of Mr. Siskind's bad faith in ignoring an 

express order of this Court. And for that the Court cites to In Re [M]Raz, 

cited at 65 F 3d 1567, at pages 1574 to 76, a 4 decision of the 11th Circuit in 

1995. Mr. Suarez, please submit the fees and costs solely for preparing and 

 

2 The Trustee, through the GJB Law Firm, prosecuted the Motion to Strike on the basis that the Alleged 

Counterclaim failed on its face as a matter of law for four key independent reasons. First, that its entire 

premise was facially defective, an affront to the integrity of these judicial proceedings and should be 

stricken. Second, that a counterclaim cannot be asserted exclusively against non-parties. Third, that even 

if the Court permitted the filing of the alleged counterclaim it would be futile because the Trustee and his 

counsel are immune from suit for actions taken in connection with the discharge of their duties. Fourth, 

that the Court previously struck Siskind’s affirmative defense with respect to the very same allegations 

yet Siskind ignored that order and restated his previously stricken defenses. 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 5 of 29
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prosecuting the motion to strike by way of a motion for approval of sanctions 

award and have that filed by no later than June 19th, 2020. To the extent that 

Mr. Siskind disputes the amount of the sanctions award, not the entitlement, 

the amount, that is sought by the trustee, Mr. Siskind may file an objection 

identifying with specificity the specific time entries to which he objects by 

July 2nd, 2020. The Court will thereafter rule on the amount of the sanctions 

award.” 

06/05/2020 H’rg Trans. [ECF No. 382] at p. 18, ln 22 – p. 19, ln 9. Although the allegations 

were frivolous and ultimately stricken by the Court, their very nature required a thorough 

response and careful review by senior lawyers at the firm. In granting the Motion to Strike, the 

Court struck the offending affirmative defenses and dismissed the Alleged Counterclaim with 

prejudice. 

I. RETENTION OF APPLICANT, DISCLOSURE OF COMPENSATION AND 

 REQUESTED AWARD 

 On July 24, 2018, this Court entered the Order Approving Chapter 7 Trustee’s 

Application for Employment of John H. Genovese, Esq., and the firm of Genovese Joblove & 

Battista, P.A. as counsel for the Chapter 7 Trustee [ECF No. 103]. To date, the GJB Law Firm 

has not sought compensation from the Debtor’s bankruptcy estate. This application is filed 

solely pursuant to the Sanctions Order and seeks reimbursement from Jeffrey Siskind of fees and 

costs incurred in connection with the prosecution of the Motion to Strike (the “Application”) 

from April 23, 2020 through June 19, 2020 (the “Application Period”). 

 By way of this Application, then GJB Law Firm submits that it has incurred at least 

$58,885.00 in professional fees and $126.40 in costs in connection with the prosecution of the 

Motion to Strike. 

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II. PROCEDURAL BACKGROUND 

a. The Bankruptcy Case. 

1. On January 29, 2018, the Debtor through Siskind filed a voluntary petition for 

bankruptcy relief under Chapter 7 of the United States Code (the “Bankruptcy Code”) [Main 

Case, ECF No. 1] in the United States Bankruptcy Court for the District of Maryland (the 

“Bankruptcy Case”). 

2. On January 29, 2018, George W. Liebmann was appointed interim Chapter 7 

Trustee in the District of Maryland [Main Case, ECF No. 4]. 

3. The Debtor’s section 341 Meeting of Creditors was scheduled to take place on 

March 15, 2018 [Main Case, ECF No. 4]. 

4. On March 15, 2018, Defendant Siskind (purportedly on behalf of the Debtor) 

sought to disqualify Mr. Liebmann as Trustee [Main Case, ECF No. 38] and sought to continue 

the Meeting of Creditors [Main Case, ECF No. 37]. 

5. On March 17, 2018, the Bankruptcy Court in the District of Maryland denied 

without prejudice the Motion to Disqualify Mr. Liebmann [Main Case, ECF Nos. 43, 48]. 

6. On May 24, 2018, the Bankruptcy Court in the District of Maryland entered a 

Memorandum and Order Transferring Venue to the Bankruptcy Court for the Southern District 

of Florida. [Main Case, ECF No. 73]. 

7. On May 25, 2018, Robert C. Furr was appointed as the Chapter 7 Trustee by the 

Office of the United States Trustee. [Main Case ECF No. 76]. 

8. On June 8, 2019, the Trustee filed an Application to Employ John H. Genovese, 

Esq. and the law firm of Genovese Joblove & Battista, P.A. as General Counsel to the Chapter 7 

Trustee [Main Case, ECF No. 80] (the “GJB Application”). 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 7 of 29
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9. On July 9, 2018, the Trustee conducted the Debtor’s section 341 Meeting of 

Creditors at 8:30 a.m. in the Southern District of Florida, West Palm Beach Division [Main Case, 

ECF No. 78, 90]. 

10. On August 7, 2018, the Court granted the Trustee’s application to employ GJB as 

counsel to the Trustee [Main Case, ECF No. 103]. 

b. The Siskind Adversary Proceeding. 

11. On August 9, 2019, the Trustee filed the above-captioned adversary proceeding 

seeking to avoid and recover transfers made by and among the Debtor to Defendant Siskind, his 

spouse and entities controlled by Siskind [ECF No. 1]. 

12. On November 1, 2019, the Trustee filed the First Amended Adversary Complaint 

[ECF No. 95] (the “FAC”). 

13. On January 2, 2020, Siskind filed his Answer and Affirmative Defenses to 

Plaintiff Robert C. Furr’s First Amended Complaint to Avoid and to Recover Fraudulent 

Transfers, for Turnover, for an Accounting, Substantive Consolidation, Injunctive Relief and for 

Other Relief [ECF No. 220] (the “Initial Answer”). 

14. On January 23, 2020, the Trustee filed a Motion to Strike Siskind’s Second 

Affirmative Defense and Third Affirmative Defense [ECF No. 230] (the “Motion to Strike”). 

15. Defendant Siskind did not file a response to the Motion to Strike. On February 

25, 2020, the Court entertained argument concerning the Motion to Strike. On March 19, 2020, 

the Court entered an Order on the Motion to Strike [ECF No. 263] (“Striking Order”). 

16. On April 9, 2020, Siskind filed the Amended Answer and Affirmative Defenses 

[ECF No. 272] and [Purported] Counterclaim [ECF No. 273] (the “Sham Pleading”). 

17. On April 23, 2020, the Trustee filed the Renewed Motion (I) to Strike Certain 

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Affirmative Defenses in Defendant Jeffrey Siskind’s Amended Answer and Affirmative 

Defenses [ECF No. 272] and Alleged Counterclaim [ECF No. 273]; (II) for an Order to Show 

Cause Why Jeffrey Siskind Should Not Be Held in Contempt of Court; and (III) for Sanctions 

[ECF No. 281]. 

18. On May 14, 2020, the Court entered the Order Setting Evidentiary Hearing by 

Video Conference and Establishing Related Deadlines [ECF No. 326] and set the hearing on the 

Motion to Strike for June 5, 2020 at 10:00 a.m. 

19. On May 31, 2020, Siskind filed the Notice of Withdrawal of Second Affirmative 

Defense and Counterclaims [ECF No. 346]. 

20. On June 3, 2020, the Trustee filed his Designation of Deposition Testimony of 

Jeffery M. Siskind in Support of the Motion to Strike [ECF No. 355]. 

21. Additionally, on June 3, 2020, the Trustee filed the Joint Stipulation of Facts 

Concerning the Motion to Strike [ECF No. 356]. 

22. On June 5, 2020, the Court held and evidentiary hearing on the Motion to Strike. 

At that time, the Court ruled on the record before it and awarded the GJB Law Firm its fees and 

costs in connection with the prosecution of the Motion to Strike. 

23. On June 18, 2020, the Court entered the Order Granting the Motion to Strike 

[ECF No. 31] that among other things, directed the GJB Law Firm to file an application 

consistent with the Guidelines by June 19, 2020 [ECF No. 381]. 

III. DESCRIPTION AND SUMMARY OF SERVICES PERFORMED 

During the Application Period, the GJB Law Firm performed the services identified in 

this Application in connection with the Motion to Stroke. The specific services rendered by the 

GJB Law Firm are detailed in the firm’s billing records attached hereto as Exhibit “3”, and 

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which are highlighted in the introductory paragraphs of this Application and below. 

IV. EVALUATION OF SERVICES RENDERED: 

FIRST COLONIAL CONSIDERATIONS

 This Application presents the nature and extent of the professional services rendered by 

the GJB Law Firm in connection with its representation of the Trustee in connection with the 

Motion to Strike. The recitals set forth in the daily diaries attached hereto constitute only a 

summary of the time spent. The undertakings of the GJB Law Firm, and the results obtained, are 

evident from the record before the Court and the results obtained in the Sanctions Order. 

American Benefit Life Ins. Co. v. Baddock (In re First Colonial Corp.), 544 F.2d 1291 

(5th Cir.), cert. denied, 431 U.S. 904 (1977), enumerates twelve factors a bankruptcy court 

should evaluate in awarding fees. First Colonial remains applicable in the Eleventh Circuit to 

the determination of reasonableness of fees to be awarded under the Bankruptcy Code. Grant v. 

George Schuman Tire & Battery Company, 908 F.2d 874 (11th Cir. 1990); 2 Collier on 

Bankruptcy ¶ 330.05[2][a] at 330-33 through 330-37 (L. King 15th ed. 1991); See also Bonner v. 

City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981). The twelve factors are: 

The Time and Labor Required: 

The Novelty and Difficulty of the Services Rendered: 

The Skill Requisite to Perform the Services Properly: 

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

Case: 

The Customary Fee: 

Whether the Fee is Fixed or Contingent: 

Time Limitations Imposed by the Client or Other Circumstances: 

The Experience, Reputation, and Ability of the Professional: 

The Undesirability of the Case: 

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

Awards in Similar Cases: 

First Colonial, 544 F.2d at 1298-99. 

 Based on the standards set forth in section 330 of the Bankruptcy Code and First 

Colonial, GJB believes that the fair and reasonable value of its services rendered during the 

period covered by this Application is in the amount of $58,885.00 in professional fees and 

$126.40 in costs. 

 A. Time, Nature and Extent of Services Rendered, Results Obtained and Related 

 First Colonial Factors. 

 The foregoing summary, together with the exhibits attached hereto, details the time, 

nature and extent of the professional services the GJB Law Firm rendered in connection with the 

Motion to Strike during the period covered by this Application. The total number of hours 

expended (106 hours) reveals both the seriousness and thoroughness of the work performed in 

prosecuting the Motion to Strike. The average hourly rate for the GJB Law Firm during the 

period covered by this Application is approximately $555.523. As previously stated, the Motion 

to Strike required the involvement of the most senior lawyers at the firm on account of the nature 

of the frivolous allegations that were made by Mr. Siskind. 

A. Novelty and Difficulty of Questions Presented. 

The questions presented in the Motion to Strike were neither novel nor difficult. 

However, the seriousness of the allegations raised in the Alleged Counterclaim required a 

comprehensive undertaking by the firm. 

 

3 The rates set forth in this Application are the prevailing rates charged by the GJB Law Firm in 

bankruptcy litigation matters during the Application Period. The GJB Law Firm has raised its rates on an 

annual basis as disclosed in its initial application for employment in this case [Main Case, ECF No. 80]. 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 11 of 29
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B. Skill Requisite to Perform Services Properly. 

 In rendering services to the Trustee, the GJB Law Firm demonstrated substantial legal 

skill and expertise in the areas of bankruptcy and fiduciary litigation. 

C. Preclusion from Other Employment by Attorney Due to Acceptance of Case. 

The GJB Law Firm’s representation in this case did not preclude it from accepting other 

employment. However, the nature of the allegations required the firm to devote substantial 

resources to its resolution. 

D. Customary Fee. 

 The hourly rates of the GJB Law Firm set forth in the attached exhibits reflect the hourly 

rates the GJB Law Firm bills to its clients in other similar bankruptcy cases during the 

Application Period. Courts within this district have approved these rates, as have other courts 

outside of this district, in other bankruptcy matters in which the GJB Law Firm and other counsel 

of like reputation and experience have been involved. 

E. Whether Fee is Fixed or Contingent. 

The GJB Law Firm’s compensation in this matter is subject to approval of the Court, 

subject to the availability of funds for payment, and therefore contingent. The Court should 

consider this factor, which militates in favor of a fee in the amount requested. The amount 

requested is consistent with the fee which the GJB Law Firm would charge its clients in other 

non-contingent, bankruptcy cases for similar work. 

F. Time Limitations Imposed by Client or Other Circumstances. 

 The circumstances of this case typically imposed serious time constraints on the GJB 

Law Firm due to the necessity for rapid resolution of significant issues. 

G. Experience, Reputation and Ability of Attorneys. 

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 The attorneys of Genovese Joblove & Battista, P.A. are experienced in matters of this 

kind and are well known to this Court. 

H. “Undesirability” of Case. 

 The GJB Law Firm is privileged to have the opportunity to represent the Trustee and 

appear before the Court in this proceeding. However, no law firm or professional desires to be 

the subject of allegations in the nature of those raised by the Alleged Counterclaim which 

resulted in the filing and prosecution of the Motion to Strike. 

 I. Nature and Length of Professional Relationship with Client. 

 The GJB Law Firm has represented the Trustee in various cases in the United States 

Bankruptcy Court for the Southern District of Florida. 

 J. Awards in Similar Cases. 

 The amount requested by the GJB Law Firm is reasonable in terms of awards in cases of 

similar magnitude and complexity. The compensation which the GJB Law Firm requests 

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

light of comparable services performed in non-bankruptcy cases in the community. Likewise, as 

with all law firms, the GJB Law Firm’s overhead expenses are absorbed in the hourly rate. A 

large portion of any fee which the Court awards the GJB Law Firm will merely defray such 

significant overhead expenses already incurred and paid during the pendency of this case. In 

connection with this Application, the GJB Law Firm does not seek reimbursement for fees 

incurred on account of work done by paraprofessionals – as would be customary in similar 

engagements. 

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 V. CONCLUSION 

 The GJB Law Firm respectfully submits that the fees incurred in connection with the 

Motion to Strike were necessary and appropriate under the circumstances. For this reason and all 

of the reasons set forth in this Application, the GJB Law Firm submits that its fees and costs 

incurred in connection with the Motion to Strike represent $58,885.00 in fees and $126.40 in 

costs. The GJB Law firm respectfully defers to the Court’s discretion as to the amount of fee 

and costs that should be imposed against Jeffrey Siskind as a sanction. 

WHEREFORE, the GJB Law Firm respectfully request the Court enter an Order, on a 

final basis, awarding it its fees and costs incurred in connection with the prosecution of the 

Motion to Strike payable as a sanction from Jeffrey Siskind; and (ii) awarding such other and 

further relief as the Court deems just and appropriate. 

Dated this 19th day of June, 2020. 

 GENOVESE JOBLOVE & BATTISTA, P.A. 

 Counsel to the Chapter 7 Trustee 

100 S.E. 2nd Street, Suite 4400 

Miami, FL 33131 

Tel.: (305) 349-2300 

Fax.: (305) 349-2310 

 By: /s/ John H. Genovese 

John H. Genovese, Esq. 

Florida Bar No. 280852 

jgenovese@gjb-law.com 

Jesus M. Suarez, Esq. 

Fla. Bar No. 60086 

jsuarez@gjb-law.com 

Barry P. Gruher, Esq. 

Florida Bar No. 960993 

bgruher@gjb-law.com 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 

via CM/ECF notification upon all interested parties registered to receive electronic notification 

on this matter and/or via U.S. Mail as indicated on the Service List below on this 19th day of 

June, 2020. 

By: /s/ John H. Genovese 

 John H. Genovese, Esq. 

SERVICE LIST 

Served Via CM/ECF Notification 

John H Genovese, Esq on behalf of Plaintiff Robert C Furr 

jgenovese@gjb-law.com, hburke@gjb-law.com;gjbecf@gjblaw.com;gjbecf@ecf.courtdrive.com;jzamora@gjb-law.com 

Barry P Gruher on behalf of Plaintiff Robert C Furr 

bgruher@gjb-law.com, vlambdin@gjb-law.com;gjbecf@gjb-law.com;cesser@gjblaw.com;gjbecf@ecf.courtdrive.com;chopkins@gjb-law.com 

Philip B Harris on behalf of Defendant CannaMed Pharmaceuticals, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Florida's Association of Community Banks and Credit 

Unions, Incorporated 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Second Siskind Family Trust 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Siskind Legal Services 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Sovereign Gaming and Entertainment, LLC 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Sympatico Equine Rescue, Inc. 

philip@philipbharris.com 

Philip B Harris on behalf of Defendant Tanya Siskind 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 15 of 29
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philip@philipbharris.com 

Jeffrey M Siskind on behalf of Counter-Claimant Jeffrey M Siskind 

jeffsiskind@msn.com, jmsesq500@gmail.com 

Jeffrey M Siskind on behalf of Defendant Jeffrey M Siskind 

jeffsiskind@msn.com, jmsesq500@gmail.com 

Jesus M Suarez on behalf of Plaintiff Robert C Furr 

jsuarez@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjb-law.com;jzamora@gjblaw.com;ecastellanos@gjb-law.com;gjbecf@ecf.courtdrive.com

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 16 of 29
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CERTIFICATION

 1. I have been designated by Genovese, Joblove & Battista, P.A., (the “Applicant”) 

as the professional with responsibility in this case for compliance with the current Mandatory 

Guidelines on Fees and Disbursements For Professionals In The Southern District of Florida 

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 inhouse 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. 

Dated: June 19, 2020. 

GENOVESE JOBLOVE & BATTISTA, P.A. 

 Counsel to the Chapter 7 Trustee 

 By: /s/ John H. Genovese 

 John H. Genovese, Esq. 

 

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Summary of Professional and Paraprofessional Time 

Total per Individual for this Period Only 

(EXHIBIT “1-A”) 

[If this is a final application, and does not cumulate fee details from prior interim applications, then a 

separate Exhibit “1-A” showing cumulative time summary from all applications is attached as well] 

PROFESSIONALS: 

NAME (Title) 

Partner/

Associate 

or 

Paraprofessional

Year 

Licensed 

Total 

Hours 

Hourly 

Rate Total Fee 

John H. Genovese Senior Partner / 

Shareholder 

1979 19.50 $795 $14,527.50 

Barry P. Gruher Partner 1992 28.00 $550 $15,400.00 

Jesus M. Suarez Partner 2008 58.50 $495 $28,957.50 

TOTAL 106.00 $58,885.00 

Blended Average Hourly Rate: $555.52 

Total Fees: $58,885.00 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 18 of 29
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Summary of Professional and 

Paraprofessional Time by 

Activity Code Category 

for this Time Period Only 

(EXHIBIT “1-B”) 

ACTIVITY CODE CATEGORY: General Litigation (031) 

NAME Total Hours Hourly Rate Total Fee 

John H. Genovese 19.50 $795 $14,527.50 

Barry P. Gruher 28.00 $550 $15,400.00 

Jesus M. Suarez 58.50 $495 $28,957.50 

SUBTOTALS 106.00 $58,885.00 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 19 of 29
18 

Summary of Requested Reimbursement Of Expenses 

for this Time Period Only 

(EXHIBIT “2”) 

[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 $0.00 

2. Process Service Fees $0.00 

3. Witness Fees $0.00 

4. Court Reporter Fees and Transcripts $126.40 

5. Lien and Title Searches $0.00 

6. Photocopies 

(a) In-house copies (14,786 at 15¢/page) $0.00 

(b) Outside copies ($ ) $0.00 

7. Postage $0.00 

8. Overnight Delivery Charges $0.00 

9. Outside Courier/Messenger Services $0.00 

10. Long Distance Telephone Charges (Court Call) $0.00 

11. Long Distance Fax Transmissions 

(copies at $1/page) $0.00 

12. Computerized Research /PACER $0.00 

13. Out-of-Southern-District-of-Florida Travel $0.00 

(a) Airfare $0.00 

(b) Transportation $0.00 

(b) Lodging $0.00 

(c) Parking $0.00 

14. Other Permissible Expenses (must specify and justify) $0.00 

(a) Local Travel $0.00 

(b) Professional Fees $0.00 

(c) Translation/Interpreting Service $0.00 

(d) Document Production $0.00 

Total Expense Reimbursement Requested $126.40 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 20 of 29
19 

EXHIBIT “3” 

[The Applicant’s complete time records, in chronological order, by activity code category, for 

the time period covered by this application. The requested fees are itemized to the tenth of an 

hour.] 

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 21 of 29
Genovese Joblove & Battista, P.A.

100 Southeast Second Street, 44th Floor

Miami, Florida 33131

Telephone (305) 349-2300 Facsimile (305) 349-2310

Employer ID# 65-0518134

Attn: Robert Furr, Trustee

Robert Furr (Chance & Anthem, LLC) June 19, 2020

, 

File # 12094-002

Inv. # 98207

Re: Robert Furr (Chance & Anthem / Counterclaim

Statement for Services Rendered Through Jun 19/20

- - - Legal Fees - - -

031 / General Litigation

04/13/20 BPG 1.00hr $550.00

$550.00/hr

Receipt and review of Jeffrey M. Siskind’s Amended Answer, 

Affirmative Defenses And Counterclaims To Plaintiff Robert 

C. Furr’s First Amended Complaint To Avoid And To Recover 

Fraudulent Transfers, For Turnover, For An Accounting, 

Substantive Consolidation, Injunctive Relief And For Other 

Relief and Jeffrey M. Siskind’s Limited Objection To Trustee’s 

Motion For Entry Of Order Allowing Payment Of Mediation 

Fees To Mediator And Standing Objection To The Chapter 7 

Trustee’s Claim To Be Duly Appointed (.6); Follow up with J. 

Suarez, Trustee and J. Genovese re: same (.4).

04/13/20 JMS 4.00hr $1,980.00

$495.00/hr

Research factual issues and preliminary drafting on Motion 

to Strike Counterclaim (3.4); review issues relating to 

strategy for responding to counterclaim (.6)

04/14/20 BPG 1.20hr $660.00

$550.00/hr

Review and provide comments to draft of Renewed Motion 

(I) to Strike Certain Affirmative Defenses in Defendant Jeffrey 

Siskind’s Amended Answer and Affirmative Defenses [ECF 

No. 264]; (II) for an Order to Show Cause Why Jeffrey 

Siskind Should Not Be Held in Contempt of Court; and (III) 

for Sanctions (.8); Research various issues with respect to 

Motion to Strike and for Sanctions (.4).

04/14/20 JMS 5.00hr $2,475.00

$495.00/hr

Legal research and drafting of Motion to Strike Counterclaim 

and for Sanctions (3.8) and to research concerning immunity 

doctrines (1.2).

04/15/20 JMS 4.50hr $2,227.50

$495.00/hr

Continued drafting of Motion to Strike and elaboration of fact 

section (2.3); review bar rules concerning bad faith pleadings 

(1.2); and research Rule 13 issues related to timeliness (1).

Page 1

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 22 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

04/16/20 JMS 5.00hr $2,475.00

$495.00/hr

Work on Motion to Strike Counterclaim and for Sanctions 

including factual development (2.4); and research 

concerning trustee immunity and florida litigation privilege 

(2.6).

04/16/20 BPG 0.60hr $330.00

$550.00/hr

Review and revise initial draft of Renewed Motion (I) to Strike 

Certain Affirmative Defenses in Defendant Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 264]; 

(II) for an Order to Show Cause Why Jeffrey Siskind Should 

Not Be Held in Contempt of Court; and (III) for Sanctions and 

interoffice conferences with J. Suarez re: same.

04/17/20 JHG 1.70hr $1,266.50

$745.00/hr

Review motion to strike counterclaim and conference with J. 

Suarez regarding same.

04/17/20 JMS 4.50hr $2,227.50

$495.00/hr

Work on Motion to Strike Counterclaim and for Sanctions, 

and develop arguments concerning offensive pleadings 

under Rule 12(f) (2.2); and Florida Bar rules on frivolous 

pleadings (2.3).

04/17/20 BPG 2.00hr $1,100.00

$550.00/hr

Revisions and editing draft of Chapter 7 Trustee Robert C. 

Furr’s Renewed Motion (I) To Strike Certain Affirmative 

Defenses In Defendant, Jeffrey Siskind’s Amended Answer 

And Affirmative Defenses And Purported Counterclaim [Ecf 

No. 264]; (III) For An Order To Show Cause Why Jeffrey 

Siskind Should Not Be Held In Contempt Of Court; And (III) 

For Sanctions (1.5); Review and analysis of preliminary draft 

of Expert Witness Report (.5).

04/20/20 JMS 3.20hr $1,584.00

$495.00/hr

Work on Motion to Strike, and develop arguments 

concerning Rule 13 and identity of counter defendants (3.2).

04/20/20 BPG 0.90hr $495.00

$550.00/hr

Receipt and review of Chapter 7 Trustee Robert C. Furr’s 

Renewed Motion 

(I) To Strike Certain Affirmative Defenses In Defendant,

Jeffrey Siskind’s Amended Answer And Affirmative 

Defenses And Purported Counterclaim [Ecf No. 264]; 

(Ii) For An Order To Show Cause Why Jeffrey Siskind 

Should Not Be Held In Contempt Of Court; And (Iii) For 

Sanctions

04/21/20 BPG 2.50hr $1,375.00

$550.00/hr

Review, revise and finalize Renewed Motion (I) to Strike 

Certain Affirmative Defenses in Defendant, Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 272] 

and Alleged Counterclaim [ECF No. 273]; (II) For An Order to 

Show Cause Why Jeffrey Siskind Should Not Be Held in 

Contempt of Court; and (III) for Sanctions (2.2); Follow up 

with J. Suarez and E. Castellanos re: same (.3).

04/22/20 JMS 3.70hr $1,831.50

$495.00/hr

Continued work on Motion to Strike including research on 

standard for Rule 12 and Lawrence v. Goldberg line of 

cases.

Page 2

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 23 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

04/22/20 BPG 0.50hr $275.00

$550.00/hr

Final review and editing of Renewed Motion (I) to Strike 

Certain Affirmative Defenses in Defendant Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 272] 

and Alleged Counterclaim [ECF No. 273]; (II) for an Order to 

Show Cause Why Jeffrey Siskind Should Not Be Held in 

Contempt of Court; and (III) for Sanctions with J. Suarez (.5).

04/23/20 JHG 1.90hr $1,415.50

$745.00/hr

Review revised motion to strike affirmative defense and 

conference regarding same.

04/23/20 JMS 5.30hr $2,623.50

$495.00/hr

Research case law concerning Barton and Lawrence and 

incorporate into final memorandum of law (3.5); finalize 

Motion to Strike Counterclaim and prepare same for filing 

(1.8)

04/23/20 BPG 1.30hr $715.00

$550.00/hr

Conferences with J. Suarez and J. Genovese re: status of 

case and filing of Motion to Strike Affirmative Defenses and 

for Sanctions (.3); Emails with J. Suarez, J. Genovese and 

Trustee re: consideration of Barton doctrine in connection 

with sanctions motion (.3); Follow up with J. Suarez re: email 

correspondence with J. Siskind, filing of Counterclaim 

against J. Suarez and GJB law firm, and related case 

administrative matters (.3); Continuation of review, revise 

and finalize Plaintiff Chapter 7 Trustee Plaintiff Robert C. 

Furr's Renewed Motion (I) to Strike Certain Affirmative 

Defenses in Defendant Jeffrey Siskind’s Amended Answer 

and Affirmative Defenses [ECF No. 272] and Alleged 

Counterclaim [ECF No. 273]; (II) for an Order to Show Cause 

Why Jeffrey Siskind Should Not Be Held in Contempt of 

Court; and (III) for Sanctions re: Barton Doctrine (.4).

04/23/20 BPG 1.20hr $660.00

$550.00/hr

Final review and editing of Renewed Motion (I) to Strike 

Certain Affirmative Defenses in Defendant Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 272] 

and Alleged Counterclaim [ECF No. 273]; (II) for an Order to 

Show Cause Why Jeffrey Siskind Should Not Be Held in 

Contempt of Court; and (III) for Sanctions (.4); Interoffice 

conferences with J. Suarez re: issues pertaining to the 

Barton doctrine and finalizing Motion to Strike (.4); Revise 

and finalize Order Granting Trustee’s Motion for Entry of 

Order Allowing Payment of Mediation Fees to Mediator and 

follow up with C. Hopkins re: uploading with the Court (.3); 

Review draft of Pretrial Stipulation (.4)

05/13/20 JMS 1.80hr $891.00

$495.00/hr

Initial analysis and preparation for presentation on hearing on 

motion to strike (.6); review factual development (.8) and 

present analysis of potential witnesses for trial and facts that 

need to be established at same (.4).

05/18/20 BPG 0.50hr $275.00

$550.00/hr

Review and edits to outline for topic areas at evidentiary 

hearing on Motion to Strike Affirmative Defenses and for 

Sanctions.

05/26/20 JHG 3.10hr $2,309.50

$745.00/hr

Review case strategy issues regarding adversary and 

counterclaim.

Page 3

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 24 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

05/29/20 JHG 5.50hr $4,097.50

$745.00/hr

Preparation for and attend deposition of Jeffrey Siskind and 

strategy email regarding same.

05/29/20 JMS 6.00hr $2,970.00

$495.00/hr

Prepare for and conduct deposition of Jeffrey Siskind (4.5); 

attention to preparation for hearings on 6/5 and review order 

on evidentiary hearing (1.2)

05/29/20 BPG 5.00hr $2,750.00

$550.00/hr

Conferences with J. Suarez and J. Genovese re: issues 

relating to deposition of J. Siskind (1.0); Preparation for and 

attendance at deposition of J. Siskind in connection with 

evidentiary hearing on Motion to Strike and for Sanctions and 

Siskind Adversary Proceeding (4.0).

06/01/20 JHG 1.10hr $819.50

$745.00/hr

Review notice of withdrawal and conference with J. Suarez 

regarding same, review and conference regarding settlement 

proposal.

06/01/20 JMS 4.20hr $2,079.00

$495.00/hr

Review and Finalize preparation of trial exhibits for 6/5 

evidentiary hearing on Motion to Strike Counterclaim (2.4); 

attention to order of proof for evidentiary hearing and 

development of facts to be adduced at same (1.8)

06/01/20 BPG 1.00hr $550.00

$550.00/hr

Preparation of Plaintiff’s Designation Of Deposition 

Testimony Of Jeffrey M. Siskind In Support Of The Plaintiff 

Chapter 7 Trustee Robert C. Furr’s Renewed Motion (I) To 

Strike Certain Affirmative Defenses In Defendant Jeffrey 

Siskind’s Amended Answer And Affirmative Defenses [Ecf 

No. 272] And Alleged Counterclaim [Ecf No. 273]; (II) For An 

Order To Show Cause Why Jeffrey Siskind 

Should Not Be Held In Contempt Of Court; And (III) For 

Sanctions.

06/02/20 BPG 0.50hr $275.00

$550.00/hr

Follow up with J. Suarez, C. Hopkins and J. Sardina re: 

preparation for evidentiary hearing on Renewed Motion (I) to 

Strike Certain Affirmative Defenses in Defendant Jeffrey 

Siskind’s Amended Answer and Affirmative Defenses [ECF 

No. 272] and Alleged Counterclaim [ECF No. 273]; (II) for an 

Order to Show Cause Why Jeffrey Siskind Should Not Be 

Held in Contempt of Court; and (III) for Sanctions (.5).

06/03/20 JMS 1.50hr $742.50

$495.00/hr

Prepare deposition designation of J. Siskind in connection 

with Motion to Strike Counterclaim (.3) and attention to 

preparation of stipulation on agreed facts for hearing on 

Motion to Strike Counterclaim (.4); review Motion to Strike 

Counterclaim and consider evidentiary presentation related 

to same (.8)

06/03/20 BPG 1.50hr $825.00

$550.00/hr

Continued preparation for Zoom evidentiary hearing on 

Renewed Motion (I) to Strike Certain Affirmative Defenses in 

Defendant Jeffrey Siskind’s Amended Answer and Affirmative 

Defenses [ECF No. 272] and Alleged Counterclaim [ECF No. 

273]; (II) for an Order to Show Cause Why Jeffrey Siskind 

Should Not Be Held in Contempt of Court; and (III) for 

Sanctions and Motion for Summary Judgment, final hearing 

exhibits and stipulation of facts (1.0); Follow up with J. 

Suarez, J. Genovese and Trustee re: same (.5).

Page 4

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 25 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

06/04/20 JHG 2.60hr $1,937.00

$745.00/hr

Review motion to strike (.9); review hearing notebook in 

preparation for hearing (1.7).

06/04/20 JMS 5.40hr $2,673.00

$495.00/hr

Draft direct examination of Robert Furr in connection with 

hearing on Motion to Strike Counterclaim (1.8); Conference 

with R. Furr regarding his direct examination (.6); review 

case law cited in brief on Motion to Strike Counterclaim in 

preparation of hearing on Motion to Streak (.9); review 

Siskind deposition transcript and prepare for direct of Siskind 

or introduction through designation (.7); draft hearing outline, 

evidence plan and organize trial exhibits for digital 

presentation (1.4)

06/04/20 BPG 3.80hr $2,090.00

$550.00/hr

Preparation for evidentiary hearing on Trustee’s Renewed 

Motion (I) to Strike Certain Affirmative Defenses in Defendant 

Jeffrey Siskind’s Amended Answer and Affirmative Defenses 

[ECF No. 272] and Alleged Counterclaim [ECF No. 273]; (II) 

For An Order To Show Cause Why Jeffrey Siskind Should 

Not Be Held In Contempt of Court; and (III) for Sanctions 

(2.5); Review and revise draft of Trustee's direct testimony 

(.5);Follow up with J. Suarez, Trustee and J. Genovese re: 

facts and issues relating to Motion for Sanctions and 

presentation of evidence in connection with evidentiary 

hearing (.8).

06/05/20 JHG 2.20hr $1,639.00

$745.00/hr

Meet with J. Suarez and B. Gruher prior to hearing (.5); 

attend telephonic hearing (1.); conference after hearing 

regarding sanctions and proposed orders (.7).

06/05/20 JMS 2.60hr $1,287.00

$495.00/hr

Prepare for hearing on Motion to Strike Counterclaim and 

Affirmative Defenses (1.2); Attend evidentiary hearing on 

Motion to Strike Counterclaim (.8) and draft proposed order 

(.6)

06/05/20 BPG 2.50hr $1,375.00

$550.00/hr

Meeting with J. Suarez and J. Genovese to review exhibits, 

motions and pleadings in connection with final preparation for 

evidentiary hearing (.8); Attendance and conduct Zoom 

evidentiary hearing onTrustee’s Renewed Motion (I) to Strike 

Certain Affirmative Defenses in Defendant Jeffrey Siskind’s 

Amended Answer and Affirmative Defenses [ECF No. 272] 

and Alleged Counterclaim [ECF No. 273]; (II) For An Order 

To Show Cause Why Jeffrey Siskind Should Not Be Held In 

Contempt of Court; and (III) for Sanctions [ECF No. 281] and 

Motion for Summary Judgment as to Substantive 

Consolidation filed by Adversary Defendant Jeffrey Siskind 

[ECF No. 319] (1.2); Review, revise and finalize proposed 

Orders on Sanctions Motion for circulation to J. Siskind for 

review and comments (.3); Follow up with J. Suarez re: same 

(.2).

06/08/20 JHG 0.60hr $447.00

$745.00/hr

Review proposed orders.

06/09/20 JHG 0.80hr $596.00

$745.00/hr

Review email from Jeffrey Siskind and proposed order and 

review proposed alternative order and conference regarding 

same, review adversary.

Page 5

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 26 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

06/18/20 BPG 2.00hr $1,100.00

$550.00/hr

Preparation of Summary Of First And Final Fee Application 

For Allowance And Payment Of Compensation And 

Reimbursement Of Expenses For The Law Firm Of 

Genovese Joblove & Battista, P.A. As Counsel For The 

Chapter 7 Trustee, Robert C. Furr Pusuant To The Renewed 

Motion (I) To Strike Certain Affirmative Defenses In 

Defendant Jeffrey Siskind’s Amended Answer And 

Affirmative Defenses [Adv. Ecf No. 272] And Alleged 

Counterclaim [Adv. Ecf No. 273]; (II) For An Order To Show 

Cause Why Jeffrey Siskind Should Not Be Held In Contempt 

of Court; And (III) For Sanctions and interoffice conferences 

with J. Suarez re: same.

06/18/20 JMS 1.80hr $891.00

$495.00/hr

Work on Fee Application in Connection with Motion for 

Sanctions.

Total 031 / General Litigation 106.00 $58,885.00

Total Legal Fees . . . 106.00 $58,885.00

Professional Hours Rate Amount

FEE SUMMARY:

John H Genovese 19.50 $745.00 $14,527.50

Barry P Gruher 28.00 $550.00 $15,400.00

Jesus M Suarez 58.50 $495.00 $28,957.50

Total Legal Fees . . . 106.00 $58,885.00

Page 6

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 27 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

 - - Costs - - -

06/17/2020 Court Reporter Fees - hearing transcripts (12094-002) Furr / Chance & Anthe 126.40

Total Costs . . . $126.40

Page 7

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 28 of 29
Robert Furr (Chance & Anthem, LLC)

12094-002

File # 12094-002

Inv. # 98207

=====DISBURSEMENT SUMMARY ===============================================================

H214 Court Reporter Fees 126.40

Total Disbursements . . . $126.40

Total New Charges $59,011.40

OUTSTANDING BALANCE $59,011.40

TRUST BALANCE $0.00

Page 8

Case 19-01298-MAM Doc 384 Filed 06/19/20 Page 29 of 29