1 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 

COSTA HOLLYWOOD PROPERTY OWNER, LLC1

 Case No. 19-22483-AJC 

 Debtor. 

_____________________________________________/ 

SUMMARY OF FIRST INTERIM APPLICATION 

OF MELAND RUSSIN & BUDWICK, P.A. 

1. Name of Applicant: Meland Russin & Budwick, P.A. 

2. Role of Applicant: Counsel for Debtor in Possession 

3. Name of Certifying Professional: Peter D. Russin, Esquire 

4. Date case filed: September 19, 2019

5. Date of Retention Order: October 23, 2019 [ECF No. 113], 

nunc pro tunc to the Petition Date 

IF INTERIM APPLICATION, COMPLETE 6, 7 AND 8 BELOW:

6. Period for this Application: September 19, 2019 to January 31, 2020

7. Amount of Compensation Sought: $393,552.00

8. Amount of Expense Reimbursement 

Sought: 

$5,211.53 

IF FINAL APPLICATION, COMPLETE 9 AND 10 BELOW:

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 (s) Please 

disclose both Fee Retainer and Cost 

Retainer if such a Retainer has been 

received: 

$0 

12. Current Balance of Retainer(s) remaining: $02

13. Last monthly operating report filed 

(Month/Year and ECF No.): 

January 2020 [ECF No. 238] 

14. If case is Chapter 11, current funds in the 

Chapter 11 estate: 

$ 309,212.82 per ECF No. 238 

15. If case is Chapter 7, current funds held by 

Chapter 7 trustee: 

N/A 

1

 The Debtor’s current mailing address is 777 North Ocean Drive, Hollywood, FL 33019. The Debtor’s EIN is 47-

4883778. 

2

 Prepetition, MRB waived fees and costs due totaling $75,016.03. 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 1 of 144
2 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

First Interim Application 

Meland Russin & Budwick, P.A. (“MR&B”), counsel to the Debtor in Possession, 

applies for compensation for fees for services rendered and costs incurred in this Chapter 11 

proceeding. This application is filed pursuant to 11 U.S.C. §331 and Bankruptcy Rule 2016 and 

meets all of the requirements set forth in the Guidelines incorporated in Local Rule 2016-

1(B)(1). The exhibits attached to this application, pursuant to the Guidelines, are: 

Exhibit "1" – Fee Application Summary Chart 

Exhibits “2-A” and “2-B”- Summary of Professional and Paraprofessional Time. 

Exhibit "3" - Summary of Requested Reimbursements of Expenses. 

Exhibit "4" - 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. 

Summary of Services 

1. While this application seeks only compensation for post-petition services 

rendered to the Debtor from September 19, 2019 through and including January 31, 2020, it is 

important to understand the history of this Debtor, how it ended up in bankruptcy, and the 

extensive pre-petition services rendered by applicant. 

2. Pre-petition, on or about April 23, 2019, 777 N. Ocean Dr. LLC (the “Secured 

Lender”) filed a six-count complaint against the Debtor (and 12 other defendants)3

 for, among 

other things, foreclosure of its mortgage and appointment of a receiver. Between April 23, 2019 

and September 18, 2019, the Debtor and the Secured Lender engaged in extensive negotiations 

involving both the filing of bankruptcy and potential ways to avoid bankruptcy. As is clear, 

given the very difficult situation the Debtor found itself in – facing appointment of a receiver and 

3

 In July 2019, the complaint was amended to, among other things, name additional defendants, bringing the total 

number of defendants to 15 (including the Debtor). 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 2 of 144
3 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

lengthy foreclosure litigation with many creditors and potential significant additional litigation – 

ultimately the Debtor and applicant determined that bankruptcy was the best option for the 

Debtor and all of its creditors. As set forth more fully in the application to employ applicant 

[ECF No. 21], applicant waived fees and costs totaling over $75,000 for pre-petition services 

rendered to the Debtor. 

3. The applicant believes that the requested fee of $393,552.00 for 924.1 hours 

worked for the period of time from September 19, 2019 and January 31, 2020, is reasonable 

considering the nature, extent, and the value of such services, taking into account all relevant 

factors, including: 

a) The time spent on such services. 

Many of the fee categories are interrelated. However, MR&B has attempted to categorize 

its services as follows: 

i) Case Administration. MR&B devoted 72.3 hours for a total of 

$22,183 towards case administration. This time includes advising and counseling 

the Debtor regarding matters concerning the administration of this case; drafting 

and filing pleadings and other legal papers required under the Bankruptcy Code, 

the Federal Rules of Bankruptcy Procedure and the Local Rules of this Court 

relating to the administration of the Debtor's estate and making Court appearances 

in connection with those filings; numerous calls and meetings with the Debtor 

regarding status and strategy and overall management of the bankruptcy case, 

amending the Debtor’s schedules, attending to exclusivity issues, and attending to 

issues relating to the administration of this Debtor’s estate. Additionally, MR&B 

reviewed and responded to motions for stay relief and successfully defeated the 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 3 of 144
4 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

United States Trustee’s (I) Emergency Motion to Dismiss or Convert this Case to 

Chapter 7 or Alternatively, to Direct the Appointment of a Chapter 11 Trustee and 

(II) Request for an Expedited Hearing [ECF No. 46] and non-substantive joinders 

were filed by various parties, including the hotel manager Evolution Hospitality, 

LLC at ECF Nos. 49, 51-68. 

ii) DIP Reports/AUST Guidelines. MR&B devoted 41.5 hours for a 

total of $15,357 towards compliance with the US Trustee Guidelines, and 

attention to, review and e-filing of monthly DIP reports for the Debtor. 

iii) Claims. MR&B devoted 18.7 hours for a total of $6,876.50 

towards the review and attention to claims and research. This time also includes 

analysis of claims (including reviewing claims to determine which may be 

executory), preparing a table of creditors, calls with claimants, and attention to 

various specific alleged claims. 

iv) Plan/Disclosure Statement. MR&B devoted 216.2 hours for a 

total of $93,312.50 towards the analysis, research, strategy and preparation of the 

Debtor’s draft disclosure statement and plan of liquidation and related documents. 

This time includes, among other things: (A) multiple rounds of drafting and 

negotiating: (i) a stalking horse purchase and sale agreement with counsel and 

local counsel the Secured Lender; (ii) the Debtor’s disclosure statement; (iii) the 

Debtor’s Chapter 11 plan of liquidation; (iv) a proposed liquidating trust 

agreement; (B) preparing the Debtor’s liquidation analysis; (C) considering the 

assumption and rejection of executory contracts; (D) multiple rounds of 

negotiation and drafting a Motion for Entry of (A) an Order Approving Bidding 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 4 of 144
5 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

Procedures, (B) Approving Certain Protections to Stalking Horse Purchaser, (C) 

Approving Notice Procedures, and (D) and Order (I) Approving the Authorizing 

the Sale of All or Substantially All of the Assets of the Debtor Free and Clear of 

All Liens, Claims, Encumbrances and other Interests, (III) Authorizing the 

Assumption and Assignment of Certain Executory Contracts and Unexpired 

Leases, (IV) Scheduling Dates to Conduct Auction and Hearing to Consider Final 

Approval of Sale, and (V) Granting Related Relief (and related pleadings); and 

(E) working on extensive service issues relating the Debtor’s Chapter 11 plan 

package given the number of interested parties required to be served. 

v) Fee Application/Employment. MR&B devoted 35.9 hours for a 

total of $11,400.50 towards the preparation of retention applications, affidavits 

and orders for itself, Robb E. Udell, Esq. and Rennert Vogel Mandler & 

Rodriguez, P.A. as Special Tax Appeal Counsel, and of Michael R. Kassower, 

Esq. and Frank Weinberg Black, P.L. as Special Counsel. MR&B further prepared 

this interim fee application. 

vi) Business Operations. MR&B devoted 472.8 hours for a total of 

$216,307.50 towards operational issues. This time includes preparing and 

negotiating (with the Secured Lender) the approval of an operating budget and 

dealing with numerous funding issues, including critical DIP financing. MR&B 

has also had to address a number of unanticipated issues relating to operations, 

including for example, expedited payment of heavily discounted real estate taxes 

following a successful tax appeal [see ECF No. 242]. In all, MR&B devoted 

numerous hours negotiating budget, critical vendor, shared facilities operating and 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 5 of 144
6 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

other critical operational issues, without which the Debtor would have likely had 

to cease operations. 

vii) Litigation. MR&B devoted 66.7 hours for a total of $28,115 

towards litigation. The majority of this time includes addressing litigation issues 

that arose prior to retention of special counsel, addressing a motion to dismiss 

filed by the U.S. Trustee [see ECF No. 46], addressing and responding to multiple 

stay relief motions, addressing stay relief violations, addressing and responding to 

motions filed by purported creditor Costa Investors LLC to extend time to object 

to dischargeability [ECF No. 196] and compel the Debtor’s 2004 examination 

[ECF No. 197], and addressing and responding to numerous litigation issues for 

which bankruptcy counsel involvement or input was necessary post-retention of 

special counsel. 

b) The rates charged for such services. 

MR&B is requesting the amount of $393,552.00 in attorneys’ fees for services rendered. 

MR&B logged a total of 924.1 hours at hourly rates ranging from $180 for paralegals to $695 for 

partners. The transcribed time records and details of services rendered by MR&B are attached 

hereto as Exhibit 4. A summary of the hours is attached as Exhibit 2-A and 2-B. 

All attorneys and legal assistants of MR&B record the time expended in the rendition of 

professional services for the Debtor by recording a detailed description of such professional 

services rendered. Exhibit 4 does not include any time spent by secretaries or staff in providing 

support services, which were substantial. 

All professionals involved in the rendering of services in this proceeding avoided any 

unnecessary duplication of work and time expended. A substantial amount of time incurred by 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 6 of 144
7 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

Peter D. Russin, Esquire, was either not recorded or written down in order to avoid any potential 

duplicate time charges to the estate. 

c) Whether the services were necessary to the administration of, or beneficial 

at the time at which the service was rendered toward the completion of the case. 

The services performed by MR&B on behalf of the Debtor were necessary and beneficial 

towards the completion of this case. As detailed above, such services included drafting and filing 

a Chapter 11 plan of liquidation and disclosure statement, negotiating related matters including a 

potential sale of substantially all of the Debtor’s extensive assets to a stalking horse bidder, and 

dealing with day to day operational issues of the Debtor. 

d) Whether the services were performed within a reasonable amount of time 

commensurate with the complexity, importance, and nature of the problem, issue, or task 

addressed. 

The services performed by MR&B were within a reasonable amount of time, and 

commensurate with the complexity and importance of this large Chapter 11 case. 

e) With respect to a professional person, whether the person is board certified 

or otherwise has demonstrated skill and experience in the bankruptcy field. 

MR&B is a specialized commercial litigation and transactional firm having substantial 

experience in bankruptcy. MR&B represents clients throughout the Southern District of Florida 

and appears regularly in the Southern District Bankruptcy Courts. The quality of work performed 

by MR&B in this proceeding attests to the firm’s experience, reputation and ability. 

Peter D. Russin obtained his B.A. degree with departmental honors in 1985 from Tulane 

University. He received his J.D. degree in 1988 from The George Washington University 

National Law Center, where he was a member of the Moot Court Board and was the winner of 

the 1987 Van Vleck Advanced Moot Court Competition. Mr. Russin was admitted to the Florida 

Bar in 1988, and is admitted to practice before the United States District Court and United States 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 7 of 144
8 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

Bankruptcy Court for the Southern District of Florida. He is a member of the Dade County Bar 

Association and was the President of the Bankruptcy Bar Association of the Southern District of 

Florida, and a member of the UCC/Bankruptcy Committee of the Business Law Section of the 

Florida Bar. Mr. Russin has lectured throughout the State of Florida on bankruptcy topics and 

has published several articles on bankruptcy issues. Mr. Russin is AV rated by Martindale 

Hubbell and highly ranked by Chambers. 

James C. Moon obtained his B.G.S. from the University of Connecticut in 1995. He 

received his J.D. from the University of Connecticut School of Law (with Honors) in 2000. Mr. 

Moon was a member, editor and published author of the Connecticut Law Review, a member of 

the Connecticut Moot Court Board, and won the 1998 Alva P. Loiselle Moot Court Competition. 

Mr. Moon was admitted to the Connecticut bar in 2000, the New York bar in 2001, and the 

Florida bar in 2004, and is admitted to practice before the United States District and Bankruptcy 

Courts for the Southern and Eastern Districts of New York and the United States District and 

Bankruptcy Courts for the Southern and Middle Districts of Florida. Mr. Moon is a pastpresident of the Bankruptcy Bar Association for the Southern District of Florida. Mr. Moon is 

AV rated by Martindale-Hubbell. 

Meaghan E. Murphy obtained her B.S. from the University of Idaho in 2008. She 

received her J.D. from the University of Miami School of School (magna cum laude) in 2012. 

Ms. Murphy was a member and managing editor of the Psychology, Public Policy & Law 

Journal, and is a member of the Order of the Coif. Ms. Murphy was admitted to the Florida bar in 

2013 and is admitted to practice before the United States District and Bankruptcy Courts for the 

Southern District of Florida. Ms. Murphy has co-authored several articles published in the 

American Bankruptcy Institute Journal. 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 8 of 144
9 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

f) Whether the compensation is reasonable based on the customary 

compensation charged by comparably skilled practitioners in cases other than cases under 

title 11. 

The rates charged by the attorneys providing services to the Debtor are well within the 

reasonable range for hourly rates charged by attorneys of comparable skills in bankruptcy 

proceedings in the Southern District of Florida. 

 The applicant represents that the fees applied for are in conformity with the fees allowed 

in similar proceedings for similar services rendered and results obtained. MR&B respectfully 

requests that the Court take notice of the awards which have been made in similar proceedings. 

4. The applicant seeks an award of fees in the amount of $393,552.00 and costs in 

the amount of $5,114.96. 

 WHEREFORE, MR&B requests the Court to enter an Order (i) awarding, on an interim 

basis, the sum of $393,552.00 for fees and $5,114.96 for costs incurred between September 19, 

2019 and January 31, 2020, for a total of $398,763.53; (ii) authorizing and directing the Debtor 

to immediately pay applicant such amounts awarded subject to any applicable and standard 

holdbacks; and (iii) granting such other and further relief as the Court deems appropriate. 

CERTIFICATION 

1. I have been designated by Meland Russin & Budwick, 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 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 9 of 144
10 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

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 3, 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. 

 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 10 of 144
11 

LAW OFFICES OF MELAND RUSSIN & BUDWICK, P.A. 

3200 SOUTHEAST FINANCIAL CENTER, 200 SOUTH BISCAYNE BOULEVARD, MIAMI, FLORIDA 33131 • TELEPHONE (305) 358-6363 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, pursuant to Local Rule 2002-1(F), a true and correct copy 

of the foregoing was served on March 20, 2020, to Registered Users via the Court’s Notice of 

Electronic Filing as set forth on the attached Exhibit A and via U.S. Mail on the Manual Notice 

List. A copy will be served by U.S. Regular Mail along with the Notice of Hearing once 

docketed and a certificate of service will be filed. 

s/ Peter D. Russin 

Peter D. Russin, Esquire 

Florida Bar No. 765902 

prussin@melandrussin.com 

MELAND RUSSIN & BUDWICK, P.A. 

3200 Southeast Financial Center 

200 South Biscayne Boulevard 

Miami, Florida 33131 

Telephone: (305) 358-6363 

Telecopy: (305) 358-1221 

Attorneys for Debtor in Possession 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 11 of 144
Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email 

notice/service for this case. 

 Alejandro R Alvarez service@ara-lawfirm.com 

 Scott Andron sandron@broward.org 

 Robert C. Arnold bob@thevictorialawgroup.com, bankruptcy@thevictorialawgroup.com 

 Eric N Assouline ena@assoulineberlowe.com, ah@assoulineberlowe.com 

 Paul J. Battista pbattista@gjb-law.com, gjbecf@gjb-law.com;chopkins@gjblaw.com;jzamora@gjb-law.com;gjbecf@ecf.courtdrive.com;vlambdin@gjb-law.com 

 Jeffrey S. Berlowitz jberlowitz@siegfriedrivera.com, jortega@siegfriedrivera.com 

 Yasin Daneshfar ydaneshfar@bplegal.com, 

ecuellar@bplegal.com;kbrown@bplegal.com;FTLefile@bplegal.com;tfritz@beckerlawyers.c

om 

 Steven M Davis sdavis@bplegal.com 

 Darin A DiBello dibello@fasidibellolaw.com, perry@fasidibellolaw.com 

 Michael P Dunn michael.dunn@dunnlawpa.com, 

rbasnueva@dunnlawpa.com;mzucker@dunnlawpa.com 

 Julie Feigeles jf@womenatlawfl.com, way@womenatlawfl.com 

 Jerold C Feuerstein jfeuerstein@kandfllp.com, 

litigation@kandfllp.com;CValenzuela@kandfllp.com;skossar@kandfllp.com;skossar@kandf

llp.com 

 Brandon J Hechtman bhechtman@wickersmith.com 

 Kimberly H Israel kisrael@mcglinchey.com, jglus@mcglinchey.com 

 Mark Journey mjourney@broward.org, swulfekuhle@broward.org 

 Michael R Kassower mkassower@fwblaw.net, mrothman@fwblaw.net 

 Andrew V Layden alayden@bakerlaw.com, 

orlbankruptcy@bakerlaw.com;cmartin@bakerlaw.com 

 Mendy Lieberman mmlegalpa@gmail.com, 

llevey@leveylaw.com,leveylieberman@gmail.com,liebermanlawyers@gmail.com,dlacayo@

leveylaw.com 

 James C. Moon jmoon@melandrussin.com, 

ltannenbaum@melandrussin.com;mrbnefs@yahoo.com;jmoon@ecf.courtdrive.com;ltannenb

aum@ecf.courtdrive.com;phornia@ecf.courtdrive.com 

 Meaghan E Murphy mmurphy@melandrussin.com, 

ltannenbaum@melandrussin.com;mrbnefs@melandrussin.com;mmurphy@ecf.courtdrive.co

m 

 Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov 

 Alberto H Orizondo aorizondo@aglawpa.com, bfernandez@aglawpa.com 

 Alexander S Orlofsky alex@orlofskylawfirm.com 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 12 of 144
 Christina V Paradowski cvp@trippscott.com, 

bankruptcy@trippscott.com;hbb@trippscott.com 

 Meghan E Paraschak meghan@orlofskylawfirm.com 

 Chad P Pugatch cpugatch.ecf@rprslaw.com 

 Alexis S Read alexis.read@dunnlawpa.com, asr@alexisreadlaw.com 

 Humberto E Rivera humberto@hriveralaw.com, 

G61034@notify.cincompass.com;humberto@ecf.courtdrive.com 

 Raymond L Robinson teri@rrobinsonlaw.com, ray@rrobinsonlaw.com 

 Victor K Rones vrones@victorkronespa.com, jrones@victorkronespa.com 

 Peter D. Russin prussin@melandrussin.com, 

ltannenbaum@melandrussin.com;mrbnefs@yahoo.com;prussin@ecf.courtdrive.com;ltannen

baum@ecf.courtdrive.com;phornia@ecf.courtdrive.com 

 Zana Michelle Scarlett Zana.M.Scarlett@usdoj.gov 

 James Schwitalla jwscmecf@bellsouth.net, 

miamibkcmyecf@gmail.com;schwitallajr74031@notify.bestcase.com 

 Zach B Shelomith zbs@lsaslaw.com, 

fpd@lsaslaw.com;info@lsaslaw.com;zshelomith@ecf.inforuptcy.com 

 Andrew D. Zaron azaron@leoncosgrove.com, jgomez@leoncosgrove.com 

Manual Notice List 

The following is the list of parties who are not on the list to receive email notice/service for this case 

(who therefore require manual noticing/service). 

Michael R. Kassower 

FRANK WEINBERG & BLACK, P.L. 

7805 SW 6th Court 

Plantation, FL 33324 

Jairo Romero 

16979 NW 19th Street 

Pembroke Pines, FL 33028 

Robb Udell 

100 SE 2nd ST 29th Flr 

Miami, FL 33131 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 13 of 144
Date Filed ECF #

Period

Covered

Fees

Requested

Expenses

Requested

Date Order

Entered ECF #

Fees

Approved

Expenses

Approved

Fees 

Paid

Expenses

Paid

Fees

Holdback

Expenses

Holdback

N/A

TOTALS: $ - $ - $ - $ - $ - $ - $ - $ -

FEE APPLICATION SUMMARY CHART - EXHIBIT 1

REQUEST APPROVAL PAID HOLDBACK

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 14 of 144
Name

Partner, Associate

or Paraprofessional

Year

Licensed

Total

Hours

Average

Hourly

Rate* Fee

Peter D. Russin Partner 66.2 $695.00 $46,009.00

James C. Moon Partner 481.4 $492.46 $237,798.00

Meaghan Murphy Associate 159.3 $354.38 $56,388.00

Marianne Callaos Associate 7.9 $297.50 $2,338.50

Bryan N Vega Associate 1.8 $325.00 $585.00

Lisa Tannenbaum Paraprofessional 163.1 $255.90 $41,713.50

Patricia Hornia Paraprofessional 11.2 $245.00 $2,744.00

Melissa Ramos Paraprofessional 33 $180.00 $5,940.00

Irene Hernandez Paraprofessional 0.2 $180.00 $36.00

$425.88

924.1 $393,552.00

*Indicate any changes in hourly rate and the date of such change: 

Rates: 2019 1/1/2020

Peter D. Russin $695.00 $695.00

James C. Moon $495.00 $495.00

Meaghan Murphy $350.00 $365.00

Marianne Callaos $295.00 $305.00

Bryan N Vega $325.00 $325.00

Lisa Tannenbaum $255.00 $260.00

Patricia Hornia $245.00 $245.00

Melissa Ramos $180.00 $180.00

Irene Hernandez $180.00 $180.00

Summary of Professional and Paraprofessional Time Total

per Individual for this Period Only

(EXHIBIT “2-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]

Blended Hourly Rate

TOTAL HOURS AND FEES:

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 15 of 144
Name Rate Hours Fees

Peter D. Russin $695.00 8.6 $5,977.00

James C. Moon $495.00 1.8 $891.00

Associates Meaghan Murphy $350.00 4.9 $1,715.00

$260.00 9.7 $2,522.00

$255.00 31.5 $8,032.50

Patricia Hornia $245.00 3.1 $759.50

Melissa Ramos $180.00 12.7 $2,286.00

Irene Hernandez $170.00 $0.00

72.3 $22,183.00

Name Rate Hours Fees

Peter D. Russin $695.00 1.0 $695.00

James C. Moon $495.00 17.1 $8,464.50

Associates $365.00 0.4 $146.00

$350.00 2.0 $700.00

$260.00 0.8 $208.00

$255.00 20.1 $5,125.50

Melissa Ramos $180.00 0.1 $18.00

41.5 $15,357.00

Name Rate Hours Fees

Peter D. Russin $695.00 2.5 $1,737.50

James C. Moon $495.00 2.7 $1,336.50

Associates $365.00 2.0 $730.00

$350.00 1.8 $630.00

$260.00 2.8 $728.00

$255.00 6.3 $1,606.50

Melissa Ramos $180.00 0.6 $108.00

18.7 $6,876.50

Lisa Tannenbaum

Paralegals: Lisa Tannenbaum

Meaghan Murphy

Partners:

Meaghan Murphy

Paralegals: Lisa Tannenbaum

Summary of Professional and Paraprofessional Time by

Activity Code Category for this Time Period Only

(EXHIBIT “2-B”)

CATEGORY: 5589-3 UST/DIP

CATEGORY SUBTOTAL: 

Partners:

Paralegals:

CATEGORY: 5589-2 Case Admin

Partners:

CATEGORY SUBTOTAL: 

CATEGORY: 5589-4 Claims

CATEGORY SUBTOTAL: 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 16 of 144
Name Rate Hours Fees

Peter D. Russin $695.00 25.6 $17,792.00

James C. Moon $495.00 90.9 $44,995.50

Associates $365.00 25.7 $9,380.50

$350.00 20.1 $7,035.00

$305.00 0.8 $244.00

$295.00 7.1 $2,094.50

Bryan N. Vega $325.00 1.3 $422.50

$260.00 3.5 $910.00

$255.00 40.3 $10,276.50

Melissa Ramos $180.00 0.9 $162.00

216.2 $93,312.50

Name Rate Hours Fees

Peter D. Russin $695.00 1.0 $695.00

James C. Moon $495.00 5.7 $2,821.50

Associates $365.00 0.2 $73.00

$350.00 8.2 $2,870.00

$260.00 7.1 $1,846.00

$255.00 5.7 $1,453.50

Patricia Hornia $245.00 3.1 $759.50

Melissa Ramos $180.00 4.9 $882.00

35.9 $11,400.50

Name Rate Hours Fees

Peter D. Russin $695.00 21.0 $14,595.00

James C. Moon $495.00 340.5 $168,547.50

Associates $365.00 5.2 $1,898.00

$350.00 54.4 $19,040.00

Bryan N. Vega $325.00 0.5 $162.50

$260.00 0.6 $156.00

$255.00 33.7 $8,593.50

Patricia Hornia $245.00 4.2 $1,029.00

Irene Hernandez $180.00 0.2 $36.00

Melissa Ramos $180.00 12.5 $2,250.00

472.8 $216,307.50

Partners:

Meaghan Murphy

Lisa Tannenbaum

Partners:

Paralegals:

Meaghan Murphy

Paralegals: Lisa Tannenbaum

CATEGORY: 5589-5 Plan/Disclosure Statement

Partners:

Meaghan Murphy

Paralegals: Lisa Tannenbaum

Marianne Callaos

CATEGORY SUBTOTAL: 

CATEGORY SUBTOTAL: 

CATEGORY: 5589-8 Business Operations

CATEGORY: 5589-7 Fee App/Employ

CATEGORY SUBTOTAL: 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 17 of 144
Name Rate Hours Fees

Peter D. Russin $695.00 6.5 $4,517.50

$495.00 21.7 $10,741.50

$0.00 1.0 $0.00

Associates $365.00 8.7 $3,175.50

$350.00 25.7 $8,995.00

$260.00 0.1 $26.00

$255.00 0.9 $229.50

Patricia Hornia $245.00 0.8 $196.00

Melissa Ramos $180.00 1.3 $234.00

66.7 $28,115.00

CATEGORY: 5589-9 Litigation

Partners:

Meaghan Murphy

Paralegals: Lisa Tannenbaum

James C. Moon

CATEGORY SUBTOTAL: 

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 18 of 144
1. Filing Fees $31.00

2. Process Service Fees $0.00

3. Witness Fees $0.00

4. Court Reporter Fees and Transcripts $0.00

5. Lien and Title Searches: $0.00

6. Photocopies:

 (a) In-house copies (23,300 at $0.15/page) $3,495.00

 (b) Outside copies $0.00

7. Postage $694.57

8. Overnight Delivery Charges $34.44

9. Outside Courier/Messenger Services $0.00

10. Long Distance Telephone Charges (conf calls) $0.00

11. Long Distance Fax Transmissions (@ $1/page) $0.00

12. Computerized Research $928.77

13. Out-of-Southern-District-of-Florida Travel:

 (a) Transportation $0.00

 (b) Lodging $0.00

 (c) Meals $0.00

14. Other Permissible Expenses (must specify and 

justify): Parking $27.75

TOTAL: $5,211.53

Summary of Requested Reimbursement Of Expenses

for this Time Period Only

"EXHIBIT 3"

[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]

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 19 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 33131

TELEPHONE (305) 358-6363 Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention: Moses Bensusan

Matter #:

Invoice #:

5589-1

69834

RE: Costa Hollywood Property Owner - CI 1 BKC (Costs)

DISBURSEMENTS Disbursements Receipts

3,495.00

DUPLICATION EXPENSE

694.57

POSTAGE EXPENSE

October 34.44 1,2019 FEDEX

INV.6-754-03214

October 3, 2019 AMERICAN EXPRESS

5589-1/FlLING FEES- FL SOUTHERN

CM ECF TRACKING ID#26KKA2B2

October 7, 2019 PACER SERVICE CENTER

INV.260 1 644-Q320 1 9

31.00

4,10

November Legacy Parking Company 18.00 1,

2019

INV.391715

West Payment Center 255.07

INV.841202801

November 9.75 2 1 , AMERICAN EXPRESS

2019

PARKING (VERRUS) 0971/ JCM

PARKING

December West Payment Center 213.77 1,

2019

INV. 84 13 694 17

188.53 January 1, 2020 West Payment Center

INV.841 549370

EXHIBIT 4

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 20 of 144
January 7, 2020 PACER SERVICE CENTER 267.30

INV.260 1 644-Q420 1 9

$5,211.53 $0.00 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 21 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 33131

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

Matter #:

Invoice #:

5589-2

69835

RE: Costa Hollywood Property Owner - CI 1 BKC (Case Admin)

DATE LAWYER DESCRIPTION RATE HOURS FEE

Review and revise lengthy $695.00 $1,112.00

draft schedules

Review and consider email

regarding request from

Court for any motions

requiring expedited relief

(.2); review suggestions of

bankruptcy for various cases

in which Debtor was

prepetition defendant (.4);

review and revise case

management summary (.3).

Review upcoming state

court deadlines to determine

any deadlines that may

require continued

compliance (0.1). Review

notice of appearance filed by

Rones in bankruptcy case

(0.1). Review status of

expedited first days and

necessary tasks associated

with same (0.2).

Revise case management

summary (.3).

Revise schedule F (.1).

Finalize and send

correspondence to

September 20, PDR 1.60

2019

JCM $495.00 0.90 $445.50

MM $350.00 0.40 $140.00

LRT $255.00 0.40 $102.00

MR $180.00 0.20 $36.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 22 of 144
Association Specialty Group

and Evolution Hospitality

September 23, $255.00

2019

Email re payroll/sale tax $127.50

report (1.). Prepare Cll

table of deadlines per rules

and code provisions (.2).

LRT 0.50

Work on MSL (.2).

MR Review Notice of $180.00 0.20 $36.00

Deadline(s) to Correct Filing

Deficiencies [DE 4] [.1];

update calendar; Receipt of

several notices of

appearances; update Master

Service List [.1]

Review IDI scheduling letter

and email regarding

documents needed for IDI.

Telephone conference with

Star from office of counsel

for Beachamp Construction

and email Petition (.2).

Review additional litigation

matters (.2). Update

statement of financial affairs

$495.00 0.20 $99.00 September 24, JCM

2019

$255.00 1.00 $255.00 LRT

and schedule F (.3). Update

pending items memo (.3).

Receipt ofNotice of

Appearance; update Master

Service List

Review updated litigation

search; prepare Suggestions

MR $180.00 0.10 $18.00

MR $180.00 0.50 $90.00

of Bankruptcy in (3)

additional matters

Work $255.00 0.80 $204.00 September 25, LRT on schedules and

2019 statement.

Calculate $180.00 $108.00 MR and calendar all 0.60

Cll deadlines pursuant to

the Bankruptcy Code

Review and revise: Chapter

1 1 Case Management

$695.00 0.30 $208.50 September 26, PDR

2019

Summary (.3);

Revise, $180.00 $144.00 compile exhibits and

finalize Case Management

Summary and Notice of

Filing Master Service List

[.4]; receipt ofNotice of

Appearance of Rivera Law

Firm; update Master Service

List [.1]; telephone

conference and email

MR 0.80

exchanges with Edy Gomez

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 23 of 144
at Judge Ray's chambers re:

hearing on first day motions

[.2]; receipt of various

Notices ofAppearance;

update and maintain Master

Service List [.1]

Email latest draft of balance

of filing to Jairo re status.

Review docs from clients

and continue working on

schedules.

Review revisions and make

same to schedules.

Review notice of appearance

by senior secured lender.

$255.00 1.00 $255.00 September 27,

2019

LRT

$255.00 3.20 $816.00 September 29,

2019

September 30,

2019

LRT

MM $350.00 0.10 $35.00

MR Receipt ofNotice of $180.00 0.10 $18.00

Appearance [DE 32]; update

Master Service List

MM Review notice of 341 $350.00 0.30 $105.00 October 1, 2019

meeting (0.1). Review status

of bankruptcy, upcoming

deadlines and associated

tasks (0.2).

Work $255.00 4.70 $1,198.50 LRT on further revisions to

schedules/SOFA and

exchange emails with Jairo

re same. Receipt of Notice of

Meeting of Creditors;

review and calendar all

deadlines

Review revised draft of

MR $180.00 0.10 $18.00

$695.00 0.50 $347.50 October 2, 2019 PDR

SOFA (.5)

Review withdrawal of $350.00 0.10 $35.00

appearance by AMO

attorney (0.1).

Work on revisions to

MM

$255.00 3.80 $969.00 LRT

schedules and SOFA (2.1).

Finalize attachments 3 and 4

to SOFA (.4). Work on LF-4

add, correct and delete lists

(1.3).

Revise $255.00 0.90 $229.50 pleadings and

exhibits for filing.

October 3, 2019 LRT

$180.00 0.60 $108.00 telephone conference with

Melva at Bankruptcy Court

re: balance of schedules

filing; review Local Form 4

and prepare service list for

creditors [.3]; serve Notice

MR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 24 of 144
of Meeting of Creditors on

additional notice parties;

review local form 4 and

prepare Certificate of

Service re: same [.3]

Review email from

chambers regarding

scheduling of hearings;

respond to same.

Calls from Jerry Fuerstein

re: numerous issues

including false accusations

in UST Motion to Dismiss,

status of budget and

funding, status of PSA etc

(.6); Follow up on these

several matters re: same (.4);

TC w Jairo Romero re:

related issues (.2); TC with

Moses Bensusan and Jairo

Romero re: Evolution

issues, spreading of false

rumors and accusations and

related matters (.3)

Receipt of Notices of

Appearance; update Master

Service List and Notice of

October $495.00 0.20 $99.00 4, 2019 JCM

October $695.00 1.50 $1,042.50 7, 2019 PDR

MR $180.00 0.20 $36.00

Filing MSL

Review BNC from BKC $245.00 1.90 $465.50 PH

Court. Research better

addresses and review Jairo's

communications re same.

Prepare form for correcting

bad addresses for filing with

Court.

Review and consider email

regarding notice required for

undeliverable addresses.

Exchange emails and read

LR re updating matrix re

better addresses.

Review Notice of Hearing

on Emergency Motion to

Dismiss; review local rules

and calculate and calendar

response deadline

Review additional BNC

from Court and prepare draft

form addressing same.

Research better addresses.

Email communications with

$495.00 0.20 $99.00 October 8, 2019 JCM

$255.00 0.30 $76.50 LRT

MR $180.00 0.10 $18.00

$245.00 0.70 $171.50 PH

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 25 of 144
Jim Moon and Lisa

Tannenbaum re same.

October 9, 2019 Review email from Clerk $495.00 $49.50

regarding resubmission of

order; draft email regarding

same (.1).

Review numerous emails re

JCM 0.10

LRT $255.00 0.90 $229.50

pending items and recent

budget and backup.

PH Prepare Notice of Change of $245.00 0.20 $49.00

Address re 10-9-19 BNC

from Court.

Review Notice of

Undeliverable Mail;

compare to Master Service

List and update as necessary

Prepare certificate of service

of BNC undeliverable

documents ECF 34 and 50.

Review notice ofrecusal and

reassignment to Judge

Olson.

Compare contracts to Sched

G and consider amendment

to schedule G (.7). Attention

to return mail and research

October $180.00 $36.00 10, 2019 MR 0.20

PH $245.00 0.20 $49.00

October $695.00 0.20 $139.00 11, 2019 PDR

$255.00 1.10 $280.50 LRT

better addresses (.4).

Receipt of various notices of

appearance; update Master

Service List [.2]; revise and

finalize Response to Motion

$180.00 1.00 $180.00 October 15, 2019 MR

for Relief (DE 36) [.4];

revise and finalize Response

to Motion for Relief (DE 37)

[-4]

Compile extensive $180.00 1.10 $198.00

documents and prepare JCM

and MEM for hearings on

10-17-19 re: Motion to

October 16, 2019 MR

Dismiss, Joinders, Motions

for Stay Relief, etc. [1.0];

receipt ofNotice of

Appearance for Beauchamp

Construction Co; update

Master Service List and

Notice of Filing MSL [.1]

Monitor docket. $245.00 0.10 $24.50 PH

Review $695.00 $764.50 results of hearings

and consider strategy going

forward; TC from Michael

October PDR 1.10 17, 2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 26 of 144
Schlessinger re: buyer client

and related matters; TC w

Moses Bensusan re: results

of hearing and sales process;

Review follow up matters

on the following

1). Expedited Motion to Use

Cash Collateral [DE 23]

2). Debtor's Expedited

Motion to Maintain Bank

Accounts [DE 19];

3). PSO Investments'

Motion for Relief from Stay

(DE 36);

4). Costa 402's Motion for

Relief from Stay (DE 37);

5). US Trustee's Motion to

Dismiss (DE 46) and all

Joinders

$255.00 0.40 $102.00 LRT Research whether Order was

appealed re Order on

Plaintiffs Verified

Emergency Motion to Strike

Affidavit ofAlexey Burya

From Public Records.

MR $180.00 0.10 $18.00 Receipt of Notice of

Appearance (DE 100);

update Notice of Filing

Master Service List and

service list

MM Call with Tom Lehman re:

hearing updates (0.2).

$350.00 0.20 $70.00 October 18, 2019

Receipt $180.00 0.10 $18.00 ofNotice of

Appearance for LA Cuisine,

LLC; update service list and

Notice of Filing Master

Service List

Review United agreement to

determine if lease or finance

(0.2). Review issues

concerning incomplete

operating reports (0.2).

Email to Zana Scarlett re:

operating report (0.1).

Review correspondence

from IRS re: request for

business information (0.1).

Review letter from IRS

requesting information.

MR

MM $350.00 0.60 $210.00 October 21, 2019

$255.00 0.10 $25.50 LRT

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 27 of 144
Review demand letter from $695.00 $139.00

High Horizons counsel,

Rodrigo Da Silva and

consider violation of stay

and related matters

Draft letter to Da Silva re:

October 22, 2019 PDR 0.20

MM $350.00 2.80 $980.00

automatic stay, collection

efforts (0.3). Begin review

of stalking horse agreement

(0.5). Review current draft

of DIP report (0.4). Develop

strategy issues regarding

difficulty in finalizing DIP

reports (0.6).

Correspondence with UST

re: DIP reports (0.2). Begin

drafting motion to pay trust

fund taxes (0.4). Continue

reviewing stalking horse

agreement (0.4).

Research and email re $255.00 0.30 $76.50 LRT

scheduling of High

Horizons. Exchange emails

re same. Prepare Notice of Filing $180.00 0.20 $36.00

Correspondence from Max

MR

Goldfarb, Esq.; update

Master Service List

accordingly

Update pending items memo

(.3). Work on returned mail

$255.00 1.00 $255.00 October 23, 2019 LRT

(.7).

Receipt of Notice of Hearing $180.00 0.10 $18.00

on Creditor, Pamela Terry's

Motion for Relief from Stay

[ECF No. 25]; review rules

and calculate deadline to

respond

Review final executed order

MR

MM $350.00 0.20 $70.00 October 24, 2019

denying motion to dismiss

case (0.1). Review order

continuing hearing on

motions for stay relief (0.1).

Receipt of Notice of MR $180.00 0.10 $18.00

Appearance (DE 108);

update Master Service List

and Notice of Filing same

Email re notice of filing

update master service list.

$255.00 0.10 $25.50 October 25, 2019 LRT

Compile $180.00 0.80 $144.00 MR documents and

prepare JCM for 341

Meeting [.5]; revise and

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 28 of 144
finalize updated Master

Service List for filing [.3]

consider results of 341 $695.00 0.40 $278.00

Meeting and review follow

up matters

Exchange emails re prep for

341 meeting. Exchange

emails re response to IRS

request for business

information. Leave vmail for

October 28, 2019 PDR

LRT $255.00 0.40 $102.00

creditor Vincenzo Imparato

from Aqua Green Services

LLC

Review returned mail and $255.00 0.20 $51.00

email Jairo re same.

October 30, 2019 LRT

Receipt of various returned $180.00 $180.00

mail and emails from Court;

research division of

corporations in various

states to locate alternate

addresses; prepare list of

corrected addresses; prepare

list of bad addresses unable

to locate

Work on returned mail (bad

addresses).

MR 1.00

October LRT $255.00 0.60 $153.00 31, 2019

November Receipt ofNotice of $180.00 0.30 $54.00 1, MR

2019 Appearance (DE 125);

update Master Service List

and notice of fding same

[.1]; receipt of court's

returned mail notice;

research Colorado Division

of Corporations; update

Matrix and COR mailing list

[•2]

Review and respond to $495.00 0.20 $99.00

emails regarding recusal of

Judge Olson and

rescheduling of hearings.

Update notes and review

emails re required

amendments to schedules

November 5, JCM

2019

$255.00 0.90 $229.50 LRT

F/G.

Receipt of returned mail; $180.00 0.20 $36.00

review division of

corporations; update Matrix

and Master Service List and

corrected addresses list

MR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 29 of 144
Work on returned mail (.7). $255.00 $204.00

Email Jairo re better

addresses and known bad

addresses (.1).

Update CORR service list

and MSL [.1]; review Order

Query re: status of pending

orders on ECF Nos. 18 and

20; telephone conference

with Cheryl at Judge

Cristol's office; email

exchange with Edy Gomez

at Judge Grossman's office

November 6, LRT 0.80

2019

MR $180.00 0.40 $72.00

[•3]

Update pending items $255.00 0.20 $51.00

memo. Exchange emails re

Jairo re same.

Receipt ofNotice of

November 7, LRT

2019

MR $180.00 0.80 $144.00

Appearance (DE 137);

update Notice of Filing

Master Service List and

MSL; review NEF list and

mark Matrix with all

appearances; review notes

from client regarding

updated creditor addresses;

update corrected addresses

list and matrix [.7]; receipt

of Notice of Hearing on

Pamela Terry's Motion for

Relief from Stay (DE 25);

review local rules and

calendar and calendar

response deadline [.1]

Update notes re required

amendments to

schedules/better addresses

$255.00 0.60 $153.00 November 8, LRT

2019

(.6).

Work $255.00 2.80 $714.00 on notes re

amendments to schedules

and contracts/leases.

Leave vmail returning call to

Julia of SOS Security.

Receipt of various returned

mail; research division of

corporations for better

addresses; update corrected

and bad service lists and

matrix

Work on return mailed (.3).

Update memo re items to

amend on schedules (.4).

November 12, LRT

2019

$255.00 0.10 $25.50 November 15, LRT

2019

MR $180.00 0.30 $54.00 November 19,

2019

$255.00 0.70 $178.50 November 20, LRT

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 30 of 144
Review bad address list and $255.00 $25.50

email Jairo re same.

November 21, LRT 0.10

2019

Update BAD addresses $180.00 $72.00

service list [.2]; Compile

documents re: Motions for

MR 0.40

Relief from Stay and prepare

JCM re: hearing on

11-26-19 [.2]

Compile documents and $180.00 0.50 $90.00

prepare MEM for hearing on

November 25, MR

2019

11-26-19

Prepare for and attend $695.00 2.30 $1,598.50

hearings on:

1). Motion for Payment of

Prepetition Tourist

Development Taxes (DE

November 26, PDR

2019

121)

2). App to Employ Robb

Udell, Esq. (DEI 24)

3). PSO Investments Motion

for Relief from Stay (DE

36)

4). Costa 402's Motion for

Relief from Stay (DE 37)

5). Debtor's Motion to Use

Cash Collateral (DE 97)

6). Expedited App to

Employ Jairo Romero of JV

Int'l [DE 143]

$255.00 0.80 $204.00 Telephone conference with

rep ofAqua Green Services

and email 341 notice. Work

LRT

on returned mail.

Exchange emails re attorney

for unit owner appearing for

client.; Work on returned

mail.

Receipt of various returned

mail; update bad addresses

list and Matrix

Email Jairo re bad addresses

$255.00 0.60 $153.00 December 3, LRT

2019

MR $180.00 0.30 $54.00

$255.00 0.40 $102.00 December 4, LRT

2019 (.1). Email Meli re reply

from Jairo re same (.1).

Email Jairo re amendments

to schedules (.2).

Revise and finalize Notice

of Filing Master Service List

MR $180.00 0.20 $36.00

Update $255.00 0.30 $76.50 pending items memo. December 11, LRT

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 31 of 144
Receipt of returned mail and $180.00 $72.00

review of email from Jairo

regarding corrected

addresses; update Matrix,

corrected and bad addresses

lists

Exchange emails with Jim re

contracts (.1). Update

spreadsheet (.3). Work on

returned mail (.7).

Email Jairo re better

addresses for returned mail.

Update service lists.

Review insurance issues and

MR 0.40

$255.00 $280.50 December 12, LRT 1.10

2019

$255.00 0.30 $76.50 December 13, LRT

2019

$350.00 0.20 $70.00 December 17, MM

confirm prior order allows

Debtor to finance premiums

2019

(0.2).

Receipt of Notices of $180.00 $18.00

Appearance; update Master

Service List and Notice of

0.10 December 19, MR

2019

Filing same

Email Jairo re info needed

for amendments to

schedules.

Email re updated MSL.

Review pending items memo. Update pending items memo.

$255.00 0.10 $25.50 December 30, LRT

2019

$260.00 0.30 $78.00 January 3, 2020 LRT

$260.00 0.20 $52.00 January 6, 2020 LRT

Email $260.00 0.10 $26.00 Jairo re info to amend

schedules.

January 7, 2020 LRT

Conf $695.00 $347.50 call with Lender's

counsel re: status of various

pending matters

Revise and finalize latest

PDR 0.50 January 8, 2020

MR $180.00 0.30 $54.00

Notice of Filing Master

Service List [.2]; receipt of

returned mail; update matrix

accordingly [.1]

Review $260.00 0.30 $78.00 spreadsheet from

Jairo and email re same.

January 13, 2020 LRT

Revise $180.00 0.30 $54.00 and finalize Debtor's

Response in Opposition to

Motion for Extension of

Time to Object to Notice of

Discharge

Review spreadsheet and

email from Jairo and reply

re amendments to schedules.

Telephone conference with

Jairo and review newest

MR

$260.00 0.40 $104.00 January 14, 2020 LRT

$260.00 1.30 $338.00 January 15, 2020 LRT

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 32 of 144
version of amendments to

schedules spreadsheet.

LRT Attention to MSL. $260.00 0.10 $26.00 January 27, 2020

Work on amendments to $260.00 7.00 $1,820.00 January 28, 2020 LRT

schedules D, F, and G (4.9).

Work on service lists (2.1).

72.30 $22,183.00 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 33 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 331 31

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

Matter #:

Invoice #:

5589-3

69836

RE: Costa Hollywood Property Owner - CI 1 BKC (DIP/UST)

RATE HOURS FEE DATE LAWYER DESCRIPTION

Review $495.00 $198.00 and analyze Trustee

guidelines on large chapter

0.40 September 23,

2019

JCM

11 cases (.4).

Work $255.00 $306.00 LRT on IDI checklist and 1.20

review docs (1.1). Telephone

conference with client re

DIP accounts (.1).

Review IDI letter and email

to client re tel conf and

missing items. Work on

memo to UST re IDI

Checklist.

Review IDI docs received.

$255.00 0.70 $178.50 September 24,

2019

LRT

$255.00 0.60 $153.00 September 25, LRT

2019

September 27,

2019

Review $255.00 $204.00 docs provided by

client and continue to work

on IDI checklist.

Review issues in preparation

for 341 meeting

Review and consider emails

from Ms. Tannenbaum and

Mr. Romero regarding IDI

information collection and

preparation for IDI; respond

to same (.6); review notice

of 341 meeting; draft email

to client regarding same (.2).

LRT 0.80

$695.00 0.20 $139.00 October 1, 2019 PDR

$495.00 0.80 $396.00 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 34 of 144
Review IDI documents $255.00 1.60 $408.00 LRT

provided by Jairo. Work on

IDI checklist.

Review emails re DIP $255.00 0.80 $204.00

accounts (.1). Continue

review of IDI docs (.7).

Work on IDI checklist and

documents.

October 2, 2019 LRT

$255.00 1.20 $306.00 October 3, 2019 LRT

Review and analyze UST $495.00 3.20 $1,584.00

Motion to Dismiss; consider

response (1.8); call with Mr.

Romero regarding same (.3);

transmit proof of insurance

to UST (.2); draft email to

Debtor regarding analysis of

UST motion to dismiss and

strategy with respect to

response (.5);call with Mr.

Feurstein regarding UST

Motion to dismiss (.3);

review email from Mr.

Battista to UST regarding

Motion to Dismiss (.1).

Telephone conference and

several emails with Jairo re

IDI deadline and pending

items (.4). Review IDI docs

and prepare for submission

to UST (.9). Revise and

finalize memo and checklist

October 4, 2019 JCM

$255.00 1.50 $382.50 October 7, 2019 LRT

(.2).

$255.00 0.10 $25.50 October 8, 2019 LRT Email Jairo to prepare for

IDI.

$495.00 7.10 $3,514.50 October 10, 2019 JCM Prepare for IDI with UST

analyst (1.2); participate in

IDI call with UST analyst

(.8); revise and edit response

to UST Motion to Dismiss;

draft emails regarding same

(2.5); review and consider

email from Mr. Kronin

requesting documents

subsequent to the IDI (.2);

review and analyze budget

documentation and critical

vendor documentation for

budget and critical vendor

analysis (2.4).

$255.00 1.70 $433.50 LRT Prepare for and attend the

IDI via conf call (1.1).

Emails re pending items

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 35 of 144
arising out of IDI (.2).

Discuss DIP report inclusion

of income/receipts from

management companies and

other required info (.4).

Draft email to UST

regarding confirmation from

Chase Bank that accounts

have been converted to DIP

accounts (.1); draft email to

UST with requested redline

between interim and

proposed final Cash

Management Order (.2).

Draft email to UST

regarding proposed Cash

Management Order (.1);

review emails regarding

status of documents

$495.00 $148.50 October 15, 2019 JCM 0.30

$495.00 0.30 $148.50 October 17, 2019 JCM

requested by UST at IDI

(-2)

$255.00 $25.50 Email re status of additional

docs requested at IDI.

LRT 0.10

$255.00 0.90 $229.50 Telephone conference with

Jairo re DIP report and

attachments. Prepare for

additional docs response

deadline on Monday.

Review email with

documents submitted to

October 18, 2019 LRT

$495.00 0.20 $99.00 October 21, 2019 JCM

UST pursuant to requests

out of IDI.

$255.00 $382.50 Exchange emails with Jairo

re DIP report (.3). Review

1.50 LRT

DIP report (1.2).

$695.00 0.40 $278.00 Review draft DIP report and

consider complications

relating to reporting

financial data

October 22, 2019 PDR

$255.00 4.10 $1,045.50 Email Jairo re status of

receipts report (.1). Email

Jairo re status of DIP report

(.1). Telephone conference

with Jairo and review entire

LRT

DIP report (3.9).

Review $695.00 0.40 $278.00 October 23, 2019 PDR and revise MOR

and related notes

$255.00 0.70 $178.50 LRT Telephone conference with

UST and James re DIP

report (.2). Telephone

conference with Jairo re DIP

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 36 of 144
report (.2). Review final

draft of DIP report (.3).

October Review docs for IDI addl $255.00 $51.00 24, 2019 LRT 0.20

doc request. Email same to

Keith at UST.

Exchange emails re amount $255.00 $51.00 October 25, 2019 LRT 0.20

of UST fees due.

Review email from UST re: $495.00 $49.50 October 27, 2019 JCM 0.10

budget.

Respond to email from UST $495.00 $2,277.00

(.1); prepare for and attend

341 meeting; meeting with

clients before and after (4.5).

Follow up on prepetition

bank accounts converted to

DIP accounts.

Review and respond to

email from Ms. Scarlett re:

transfer of UST to Miami.

Review pending items re

Sept DIP report and email re

Oct DIP report.

Email Jairo re status of

amending Sept DIP report

and draft Oct DIP report.

Email Jairo re pending items

re DIP reports.

October 4.60 28, 2019 JCM

$255.00 0.10 $25.50 October 30, 2019 LRT

$495.00 0.10 $49.50 November 5, JCM

2019

$255.00 0.30 $76.50 November 12, LRT

2019

$255.00 0.10 $25.50 November 13, LRT

2019

$255.00 0.10 $25.50 November 18, LRT

2019

$255.00 0.20 $51.00 Initial review of Oct DIP

report and email Jairo re

same. Review draft DIP report

(1.2). Brief review of

revised DIP report (0.3).

Email re DIP Tax account

November 20, LRT

2019

$350.00 1.50 $525.00 November 21, MM

2019

$255.00 0.70 $178.50 LRT

(. 1). Review draft Oct DIP

report and email comments

to Jairo (.6).

Finalize and efile October $180.00 0.10 $18.00 November 22, MR

2019 2019 DIP

Review monthly $350.00 0.50 $175.00 operating

report for Nov 2019 prior to

December 23, MM

2019

filing (0.5).

Review Nov DIP $255.00 0.70 $178.50 LRT report.

Preliminary $365.00 $146.00 review of

debtor's monthly operating

MM 0.40 January 20, 2020

report (0.4).

Review DIP $260.00 0.30 $78.00 January 21, 2020 LRT report and

email Jairo re same.

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 37 of 144
LRT Calculate 4Q19 UST fees $260.00 0.50 $130.00

due (.2). Create table (.1).

January 22, 2020

Review updated UST fee

schedule and email re same

(.2).

41.50 $15,357.00 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 38 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 33131

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

5589-4

69837

Matter #:

Invoice #:

RE: Costa Hollywood Property Owner - CI 1 BKC (Claims)

RATE HOURS FEE DATE LAWYER DESCRIPTION

Review $695.00 0.30 $208.50 email from Andrew

Zaron counsel for

September 30,

2019

PDR

Beauchamp and review

Beauchamp claim issues

$255.00 0.10 $25.50 October 8, 2019 LRT Email Claim no. 2 filed by

Broward County Tourist

Dev Tax Section to Jairo re

secured claim for taxes.

TC from Andrew Zaron re:

Beachamp claims and

related matters.

Review issues raised by

Evolution counsel re: bed

tax obligations and related

matters

Review correspondence re:

tourism tax (0.3). Call with

American Pools re:

outstanding balance (0.2).

Emails with client re: pool

service (0.2).

Review tax claims and email

to Jairo.

$695.00 0.20 $139.00 October 1 1 , 20 1 9 PDR

$695.00 0.20 $139.00 October 16, 2019 PDR

MM $350.00 0.70 $245.00

$255.00 0.10 $25.50 October 17,2019 LRT

Review Plumbing Expert $350.00 0.10 $35.00

proof of claim.

Receipt of proof of claim

from The Plumbing Experts;

review claims register

October 21, 2019 MM

MR $180.00 0.10 $18.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 39 of 144
October 22, 2019 Call with Rodrigo Da Silva $350.00

re: High Horizons claim

MM 0.10 $35.00

(0.1).

October 24, 2019 Review POC 14; draft email $495.00 $99.00 JCM 0.20

regarding lack of referenced

liens (.2).

$255.00 $76.50 October 25, 2019 LRT Receipt and docket claims 0.30

filed.

Review $255.00 $76.50 October 31, 2019 LRT claims filed. 0.30

Review $255.00 $204.00 title search with

respect to liens (.7). Email

Jairo re prepetition purchase

and sale contracts for units

which didn't close (.1).

Review filed claims.

November 7, LRT 0.80

2019

$255.00 0.40 $102.00 November 8, LRT

2019

Review POC $350.00 $105.00 1 8 filed by

Costa Investors LLC (0.3).

0.30 November 12, MM

2019

Review $695.00 $486.50 issues with Davis'

unit owner clients and

settlement terms to offer;;

TC w Jeffrey Berlowitz re:

his client's claims and

related matters

0.70 November 14, PDR

2019

Review $695.00 0.60 $417.00 issues raised by IT

company and large

prepetition claim and threat

to cease services and options

November 1 8, PDR

2019

$350.00 $35.00 Review POC filed by 0.10 November 19, MM

2019 Florida Dept. Of Revenue

(0.1).

$255.00 $25.50 Email priority tax claim to 0.10 LRT

Jairo.

Consider $695.00 $347.50 negotiations with

Lender and IT re: CV

0.50 November 21, PDR

2019

pre-petition claim and

options ifno agreement

Review claim filed and

update lease spreadsheet to

include cure claim amount.

$255.00 0.20 $51.00 November 22, LRT

2019

$255.00 1.60 $408.00 November 25, LRT Export schedules D/E/F and

begin to create creditor body

table.

Work on table.

2019

$255.00 0.90 $229.50 December 2, LRT

2019

$255.00 0.10 $25.50 Read order and update notes

re amending schedules re

tourist taxes ok to pay.

December 3, LRT

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 40 of 144
Review email with recently $495.00

filed proofs of claim.

Review proofs of claim filed

by tax certificate holders.

$99.00 December 4, JCM 0.20

2019

MM $350.00 0.20 $70.00

Review proof of claim filed $350.00 $70.00 December 6, MM 0.20

2019 by Rapallo Group (0.1).

Review proof of claim filed

by Ximee LLC (0. 1).

Receipt and docket claims $255.00 $25.50 December 11, LRT 0.10

2019 filed.

Review POC 37 and email $495.00 $99.00

related to same (.2).

December 0.20 12, JCM

2019

MM Review proof of claim filed $350.00 0.10 $35.00

by City of Hollywood (0.1).

Receipt and docket claim $255.00 $204.00

filed and email Jairo re same

LRT 0.80

(.1). Work on table (.7).

Email $255.00 $51.00 Jairo re claim and 0.20 December 13, LRT

amendments to schedules re

claims.

Receipt and docket claim

filed. Email client same.

2019

$255.00 0.10 $25.50 December 18, LRT

2019

Review $255.00 $51.00 claim 41 and email

to Jairo.

0.20 December 19, LRT

2019

Review $260.00 0.30 $78.00 January 8, 2020 LRT claims.

Review POCs $495.00 $148.50 47 and 48; 0.30 January 16, 2020 JCM

consider priority deposit

claim over cap and need for

objection in that amount

(.3).

Review $365.00 $73.00 claim filed by

United Leasing (0.1).

Review priority deposit

MM 0.20

claim filed by Ramos (0. 1).

Review $260.00 0.10 $26.00 LRT and email claims to

Jairo.

Review $365.00 $36.50 MM proof of claim filed 0.10 January 17, 2020

by Unit Owner S408 (0.1).

Review $365.00 $73.00 proof of claim filed

by secured lender (0.2).

Email secured lender's proof

of claim to Jairo.

Review recently filed proofs

of claim (.3); review and

respond to email from Mr.

MM 0.20 January 21, 2020

$260.00 0.10 $26.00 LRT

$495.00 0.50 $247.50 January 22, 2020 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 41 of 144
Kassower regarding proof of

claim for prepetition fees

(.2).

Review amended claim filed $365.00 $109.50

by secured creditor (0.2).

Review claim filed by

Evolution (0.1).

Email Jairo amended claim

of Madison and claim of

Evolution.

Review Costa claims

claiming priority status;

review email regarding

same. (.3)

Review proofs of claim filed

by unit owners and parking

service (0.3).

Search for and link priority

claims to Meaghan and

James.

Review and consider email

from Mr. Shelomith

regarding Beje Investments,

owner of Unit #N222; draft

email to Mr. Romero

regarding same (.3).

Review secured and priority

proofs of claim filed (.7).

0.30 January 23, 2020 MM

$260.00 0.10 $26.00 LRT

$495.00 0.30 $148.50 January 24, 2020 JCM

MM $365.00 0.30 $109.50

$260.00 0.10 $26.00 LRT

$495.00 0.30 $148.50 January 26, 2020 JCM

$495.00 0.70 $346.50 January 27, 2020 JCM

Review $365.00 0.90 $328.50 priority claims filed

as of today's date (0.4).

Review secured claims filed

as of today's date (0.5).

Receipt and docket

numerous claims filed,

review for secured status

MM

$260.00 2.10 $546.00 LRT

and email same to Jim (.4).

Begin working on table

(1.7).

Review $180.00 0.50 $90.00 claims register;

mark/organize all secured

and priority claims

MR

18.70 $6,876.50 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 42 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 331 31

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

5589-5

69838

Matter #:

Invoice #:

RE: Costa Hollywood Property Owner - CI 1 BKC (Plan/Disco)

RATE HOURS FEE DATE LAWYER DESCRIPTION

Review $695.00 0.30 $208.50 emails from

potential brokers and related

matters re: potential sale

process matters

Exchange emails with

Lender's counsel re: status of

October 1, 2019 PDR

$695.00 0.20 $139.00 October 3, 2019 PDR

PSA

Review Beauchamp and $695.00 0.70 $486.50

related state court litigation

and consider whether claims

may impact sale of property

Begin drafting disclosure

statement and consider plan

classes and issues.

Review submissions by

potential brokers for sale of

real estate assets

Work on disclosure

October 7, 2019 PDR

$255.00 3.20 $816.00 October 8, 2019 LRT

$695.00 0.30 $208.50 October 10, 2019 PDR

$255.00 0.90 $229.50 LRT

statement.

Review $255.00 0.90 $229.50 stalking horse bid

agreement.

Review draft PSA from

Jerry Feuerstein;

Work on disclosure

statement (.7). Work on plan

(2.7). Work on Liquidating

Trust Agreement (.7).

October 1 1 , 20 1 9 LRT

$695.00 0.80 $556.00 October 14, 2019 PDR

$255.00 4.10 $1,045.50 LRT

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 43 of 144
October TC w Brenda Scupple of $695.00 0.20 $139.00 15, 2019 PDR

Greenberg Traurig re:

escrow funds

October Review Sterwart Title $695.00 0.60 $417.00 16, 2019 PDR

Indemnity Agreement and

issues re: escrow funds from

closings

Review Costa Hollywood

PSA and comment on same

MCC $295.00 3.20 $944.00

Review PSA (.6); review $325.00 1.00 $325.00

and respond to

correspondence. (.4)

Review and respond to

email correspondence (1.0);

meeting with Bryan re:

review and comment on

PSA (1.0); review and make

comments/changes to PSA

(.8); send email with bullet

point summary of items for

Jim/Peter to review/confirm

October 17, 2019 BNV

MCC $295.00 3.40 $1,003.00

(.6)

Finalize $325.00 0.30 $97.50 October 18, 2019 BNV comments to PSA

Review and respond to $295.00 0.50 $147.50

email correspondence (.1);

meeting with Bryan are:

comments to PSA (.2); make

changes to PSA (.1); send

draft email with summary of

point for client's

review/approval (. 1 )

Review and revise

MCC

$695.00 0.40 $278.00 October 23, 2019 PDR

bankruptcy provisions of

draft PSA

Meeting with Moses and $695.00 1.20 $834.00

Jairo re: sale process, plan

and related matters

Review proposed LOI form

PDR

$695.00 0.80 $556.00 October 24, 2019 PDR

JMS Family LP; TC w Jay

Patel re: same; TC w Jill

Barzilay re: interested buyer

and process issues; consider

potential brokerage firms to

run sale

Review $695.00 0.60 $417.00 and revise draft

PSA from Lender

October 29, 2019 PDR

$695.00 0.30 $208.50 TC from broker of potential

buyer

November 1, PDR

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 44 of 144
November 4, Review email and $695.00 $417.00

attachment from JR Patel re:

potential stalking horse bid

and related matters

Draft email regarding timing

of plan filing (.1); review

and respond to inquiry

regarding specific plan

provision (.2); consider plan

and disclosure statement

issues and compliance with

bankruptcy code disclosure

and confirmation

PDR 0.60

2019

$495.00 $1,435.50 JCM 2.90

requirements (2.6).

Meet on plan/disco/APA

issues and update pending

items list (2.2). Revise Trust

agreement (.3).

Legal research re: continued

viability of gifting plans,

$255.00 2.50 $637.50 LRT

$350.00 1.60 $560.00 November 5, MM

2019

types of gifting plans (1.6

)•

Research re gift plans (.3). $255.00 $969.00

Revise plan (2.7). Revise

disclosure statement (.8).

Work on disclosure

statement.

Review and respond to

email regarding composition

of liquidating trust and

trustee (.2); draft and

respond to email with Mr.

Feurstein regarding call to

discuss plan issues (.1); draft

plan and disclosure

statement; draft emails

regarding same (6.8).

Work on plan and disclosure

statement.

Review draft of liquidating

plan and revise

Draft plan of liquidation and

disclosure statement; draft

emails regarding same (6.6);

call with Mr. Feurstein

regarding plan issues (.3).

Research confirmation

issues.

LRT 3.80

$255.00 2.30 $586.50 November 6, LRT

2019

$495.00 7.10 $3,514.50 November 7, JCM

2019

$255.00 4.80 $1,224.00 LRT

$695.00 1.60 $1,112.00 November 8, PDR

2019

$495.00 6.90 $3,415.50 JCM

$255.00 1.20 $306.00 LRT

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 45 of 144
Review additional revisions $695.00 $764.50

to stalking horse PSA with

Lender

Draft email to Ms. Murphy

regarding bidding

procedures motion (.1);

research regarding auction

and bidding procedures and

other plan confirmation

issues (3.4); review proofs

of claim and analyze class

treatment for plan (.3);

review and respond to

emails from Ms.

Tannenbaum regarding

hearing on second interim

cash collateral order (.2);

consider information needed

for liquidation analysis and

responsible parties for such

information (.4).

Begin drafting bidding

procedures motion (0.7).

November 12, PDR 1.10

2019

JCM $495.00 4.40 $2,178.00

MM $350.00 0.70 $245.00

$255.00 1.00 $255.00 LRT Read draft stalking horse

PSA (.4). Revise disclosure

statement (.6).

MM Review recent revisions to $350.00 3.30 $1,155.00 November 13,

stalking horse agreement

(0.2). Continue drafting

bidding procedures motion

2019

(3.1).

MM Review $350.00 0.20 $70.00 status of plan and

disclosure statement (0.2).

Email $255.00 0.30 $76.50 exclusivity deadlines

to Jim (.1). Discuss form of

liquidation analysis (.2).

Review liquidating trust

issues raised by Lender's

counsel; Review legal issues

and post confirmation

matters re: same - Analyze status and

anticipated timing of plan,

disclosure statement and bid

procedures motion (0.3).

Continue working on bid

procedures motion (0.4).

Work on disclosure

statement (1.2). Email Jairo

re values in schedules (.1).

LRT

$695.00 0.80 $556.00 November 14, PDR

2019

MM $350.00 0.70 $245.00

$255.00 1.30 $331.50 LRT

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 46 of 144
Review issues re: escrow $695.00 $278.00

held by GT and process for

release of funds

Conf call with Jerry

Feuerstein and Paul Battista

re: proposed plan and sale

related issues;

Call with Mr. Feurstein

regarding plan, disclosure

statement and purchase and

sale agreement issues (.4).

Continue drafting bid

procedures motion (1.9).

Review issues for bid

procedures motion and

related matters

Draft email to and review

response from Mr. Feurstein

regarding confirmation of

non-default pursuant to Plan

(.2); review and respond to

email regarding bidding

procedures motion; review

same (.4);

Draft email to and review

response from Mr. Feurstein

regarding confirmation of

non-default pursuant to Plan

(.2); review and respond to

email regarding bidding

procedures motion; review

same (.4); call with Mr.

Battista and Mr. Feurstein to

discuss plan drafting issues

November 15, PDR 0.40

2019

PDR $695.00 0.50 $347.50

JCM $495.00 0.40 $198.00

MM $350.00 1.90 $665.00

November $695.00 0.60 $417.00 18, PDR

2019

November $495.00 0.60 $297.00 21, JCM

2019

$495.00 1.00 $495.00 JCM

(.4).

Draft email to and review $495.00 0.60 $297.00

response from Mr. Feurstein

regarding confirmation of

non-default pursuant to Plan

(.2); review and respond to

email regarding bidding

procedures motion; review

same (.4).

Call with Battista and

Feuerstein re: plan issues;

Consider further revisions to

JCM

$695.00 1.00 $695.00 November 22, PDR

2019

plan

Prepare for call with Mr. $495.00 2.00 $990.00

Battista and Mr. Feurstein

JCM

regarding plan issues;

review draft plan and PSA

(1.3); call with Mr.

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 47 of 144
Battista and Mr. Feurstein

regarding plan issues (.7).

Read redlined plan. Update

pending items memo.

Review lender's changes to

plan; Review draft bid

procedures order included in

$255.00 0.70 $178.50 November 27, LRT

2019

$695.00 1.40 $973.00 December 2, PDR

2019

plan

Review email from Mr. $495.00 $2,821.50

Feurstein regarding

provisions needed in Plan

(.1); review and analyzes

proposed edits and

comments to Plan from Mr.

Battista (1.3); preparation

for and call with Mr.

JCM 5.70

Feurstein regarding Plan

issues (1.6); research for and

drafting of plan (2.7).

MM Review secured lender's $350.00 0.30 $105.00

comments to proposed draft

plan.

PDR Review updated draft of $695.00 0.60 $417.00 December 3,

2019 plan

Review emails and drafts re $255.00 0.80 $204.00

plan and related documents.

Draft Plan of Liquidation;

draft email to Mr. Feurstein

regarding same (4.3).

Meeting to review pending

items re plan/disco and 9019

issues. Update memo.

Call with Jerry Feuerstein

re: sale process; Review

STG indemnity agreement

and review issues to escrow

funds release

Call with Mr. Feurstein

regarding Plan issues (.4).

Prepare for and participate

in call with Mr. Feurstein

and Mr. Battista regarding

the proposed Plan of

Liquidation (1.3); draft

email regarding condo

association (.1); draft email

regarding treatment of gym

equipment in Plan (.1);

review draft plan and

consider edits based on

LRT

$495.00 4.30 $2,128.50 December 4, JCM

2019

$255.00 1.00 $255.00 LRT

$695.00 0.90 $625.50 December 5, PDR

2019

$495.00 0.40 $198.00 JCM

$495.00 2.80 $1,386.00 December 10, JCM

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 48 of 144
issues raised in call with

secured lender (1.3).

$495.00 $49.50 December 11, Draft email to Mr. Feurstein

confirming Debtor is not in

default of filing

requirements for Plan and

Disclosure Statement (.1).

Review status of deadlines

JCM 0.10

2019

MM $350.00 1.20 $420.00

to file plan and disclosure

statement (0.2). Review

proposed revisions to

bidding procedures order

from secured lender (0.7).

Review proposed order

granting stay submitted by

Costa 402 (0.3).

$255.00 0.10 $25.50 Email re plan/disco

deadlines.

LRT

$695.00 $347.50 Review bidding procedures

revised by Lender's counsel

0.50 December 12, PDR

2019

$495.00 5.70 $2,821.50 Revise and edit draft

bidding procedures order

(1.3); review and respond to

email from Mr. Feurstein

regarding debtor contracts

for reference in bidding

procedures order (.2);

review and consider edits to

draft of motion to approve

bidding procedures and

purchase and sale agreement

(.7); review and analyze plan

and disclosure statement for

JCM

necessary comments or edits

(3.4).

$350.00 0.20 $70.00 Review status and open

issues regarding plan and

disclosure statement (0.2).

Revise disclosure statement

MM

$255.00 0.70 $178.50 LRT

pending items memo.

$255.00 2.10 $535.50 December 13, LRT Revise plan/disco.

2019

$495.00 $198.00 Review revised Plan and 0.40 December 17, JCM

2019 PSA.

$695.00 0.70 $486.50 Review and revise draft

bidding procedures motion

December 19, PDR

2019

$350.00 1.40 $490.00 December 20, MM Correspondence with Jairo

2019 re: JLL (0.1).

Correspondence with

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 49 of 144
secured lender re: status of

broker, plan and disclosure

statement (0.2). Review

notice of withdrawal filed in

state court litigation (0.1).

Review Paul's revisions to

motion to approve bidding

procedures etc. (0.3).

Review draft November DIP

report (0.3). Revise motion

to pay USPF insurance

premium (0.2). Review

order authorizing USPF

payment (0.1). Email to

Jairo re: USPF order issues

(0.1).

$255.00 3.80 $969.00 LRT Work on disclosure

statement.

MM $350.00 $770.00 Prepare revisions to draft 2.20 December 23,

2019 Stalking Horse PSA (0.8).

Revise motion to pay USPF

(0.2). Correspondence with

Jairo re: USPF motion (0.2).

Correspondence with Jerry

and Paul re: upcoming

retention hearing (0.1).

Review and approve USPF

motion (0.2). Briefreview of

hotel management

agreement provided by Jerry

(0.3). Briefreview of code

provisions and case law re:

retention of special counsel,

adverse interests (0.4).

MM Review proposed revisions $350.00 1.80 $630.00

to plan from Paul (0.7).

Begin review of disclosure

statement (0.7). Develop

strategy for reconciling plan

and disclosure statement

(0.4).

$255.00 2.10 $535.50 LRT Work on plan/disclosure and

related pleadings.

$255.00 2.10 $535.50 December 24, LRT Work on disco.

2019

MM $350.00 0.20 $70.00 Correspondence with client

re: USPF motion, upcoming

December 26,

2019

hearings (0.2).

MM $350.00 1.60 $560.00 Continue review of

disclosure statement.

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 50 of 144
$695.00 $278.00 December 27, PDR Review further revisions to 0.40

2019 draft PSA

Review $695.00 $973.00 draft of Disclosure

Statement

PDR 1.40

$350.00 $980.00 Prepare significant revisions

to Disclosure Statement

(2.6). Correspondence with

Secured Lender re: open

issues (0.2).

Attention to deadlines and

update calendar. Consider

further edits to disco.

Review exclusivity issues

MM 2.80

$255.00 0.60 $153.00 LRT

$695.00 0.20 $139.00 January 2, 2020 PDR

Review $495.00 0.20 $99.00 draft motion to

extend exclusivity (.2).

JCM

$365.00 0.40 $146.00 MM Revise motion to extend

exclusivity and acceptance

periods (0.4).

$260.00 0.70 $182.00 LRT Draft motion to extend

exclusivity and proposed

order.

Review draft order granting

extension of exclusivity

period (.1); review draft plan

and disclosure statement

(1.5); review draft purchase

and sale agreement (.3);

review draft motion to

approve bidding procedures

$495.00 2.30 $1,138.50 January 3, 2020 JCM

(.4).

$365.00 0.10 $36.50 Review proposed order

granting motion to extend

exclusivity periods (0.1).

Review and consider

revisions for draft Plan

(1.5); review motion to

approve bidding procedures

motion (.4); review draft

purchase and sale agreement

MM

$495.00 2.10 $1,039.50 January 6, 2020 JCM

(.2).

$695.00 0.30 $208.50 review draft motion to

extend exclusivity

Draft email to Mr. Feurstein

and Mr. Battista regarding

draft motion to to extend

exclusivity and request to

discuss open issues (.3);

review and consider open

issues with Plan, Disclosure

January 7, 2020 PDR

$495.00 5.20 $2,574.00 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 51 of 144
Statement, Motion to

Approve PSA and Motion to

Approve Bidding

Procedures, and broker

retention issues (4.5);

meeting with Ms. Murphy

regarding same (.4)

JCM Call with Mr. Feurstein and $495.00 $247.50 January 8, 2020 0.50

Mr. Battista regarding

finalization of Plan and

Disclosure Statement and

related documents (.5).

Draft email to Mr. Feurstein

regarding motion to extend

exclusivity (.1); draft emails

regarding finalization and

filing of motion to extend

exclusivity (.2); review and

revise Plan and Disclosure

$495.00 4.10 $2,029.50 January 9, 2020 JCM

Statement, Stalking Horse

Agreement and Motion to

Approve Bidding

Procedures (3.8)

LRT Review revised disco (.7). $260.00 0.70 $182.00

MR Revise $180.00 $54.00 and finalize

Expedited Motion to Extend

Exclusivity and Solicit

Acceptances

JCM Review and revise draft Plan

and Disclosure Statement

(3.4); review and respond to

email regarding

administrative deadlines for

filing Plan and Disclosure

Statement and related

0.30

$495.00 3.60 $1,782.00 January 10, 2020

deadlines (.2).

MM Review $365.00 0.80 $292.00 revisions to

disclosure statement

proposed by secured lender

(0.8).

MR Review Notice of Hearing $180.00 $36.00

on Debtor's Expedited

Motion Pursuant To Section

0.20

1121 (D) Of The Bankruptcy

Code For An Extension Of

Exclusive Right To File A

Plan Of Reorganization And

To Solicit Acceptances [ECF

No. 215]; update calendar;

review local rules for proper

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 52 of 144
service list for certificate of

service of DE 215

PDR Exchange emails with

broker re: sale process

JCM Review and revise draft

Plan, Disclosure Statement,

Motion to Approve Bidding

Procedures and Stalking

Horse Agreement; draft

email regardin same (3.5).

PDR Review revised disclosure

statement and plan

PDR Review revise PSA

$695.00 0.20 $139.00 January 13, 2020

$495.00 3.50 $1,732.50

$695.00 1.40 $973.00 January 14, 2020

$695.00 0.60 $417.00

Review and revise draft $495.00 4.40 $2,178.00

Plan, Disclosure Statement,

Motion to Approve Bidding

Procedures, Stalking Horse

Agreement and proposed

Order on Motion to Approve

Bidding Procedures. (4.4).

Review stalking horse

agreement to determine

what must be completed by

both sides (0.3).Review bid

procedures motion to

determine what must be

completed or updated (0.3).

Develop strategy for

completion of outstanding

items in cooperation with

secured lender (0.5). Revise

stalking horse agreement

and determine necessary

issues for secured lender to

JCM

MM $365.00 2.50 $912.50

address (0.7). Revise

bidding procedures motion

and order (0.4).

Correspondence with

secured lender re: missing

information and deliverables

for stalking horse

agreement, changes to

bidding procedures motion

and order (0.3).

MM Review most $365.00 3.50 $1,277.50 recent version

of plan to determine what

must be completed (0.4).

Review most recent version

of disclosure statement to

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 53 of 144
determine what must be

completed (0.3). Revise

liquidating plan to be

consistent with disclosure

statement and psa (1 .2).

Revise disclosure statement

to be consistent with plan

and psa (1.1).

Correspondence with

secured lender re: missing

information and deliverables

for plan and disclosure

statement (0.5).

Compile documents and

prepare JCM for hearing on

1-15-20 re: Motion for

Extension of Time to File

MR $180.00 0.20 $36.00

Plan

MM Review draft liquidation $365.00 0.30 $109.50 January 15, 2020

analysis (0.3).

$260.00 0.30 $78.00 LRT Read email of pending items

for plan/disco and related

pleadings (.2). Email re

liquidation analysis (exhibit

to disco) (.1).

PDR Review issues from call

with Lender's counsel re:

plan, disco, PSA etc.

JCM Review and edit draft Plan,

Disclosure Statement and

related pleadings and

proposed orders (2.3);

prepare for and participate in

call with Mr. Feurstein and

Mr. Battista regarding Plan

and Disclosure Statement

$695.00 0.40 $278.00 January 16, 2020

$495.00 3.30 $1,633.50

issues; draft email memo

regarding actions items from

call (1.0).

MM Correspondence with Victor $365.00 0.50 $182.50

Rones re: proposed orders

(0.1). Review and approve

proposed orders on debtor's

motion to upload to judge

(0.1). Prepare clean versions

of bidding procedures

motion and order and

stalking horse agreement for

circulation (0.3).

PDR Review and revise PSA $695.00 0.30 $208.50 January 21, 2020

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 54 of 144
Review and revise plan and $695.00 0.60 $417.00

disco based on call with

Lender's counsel;

Revise and edit Plan and

Disclosure Statement,

Stalking Horse PSA, Motion

to Approve Bidding

Procedures and draft Order

PDR

$495.00 5.70 $2,821.50 JCM

Approving Bidding

Procedures; draft email to

Mr. Feurstein regarding

same; (4.4).; consider

procedural issues with

confirmation; direct plan of

action for completion (.8);

Draft email to Prospective

Liquidating Trustee

regarding retention

liquidating trustee (.2); call

with Mr. Feurstein regarding

plan and sale process issues

(.3).

MM Review $365.00 0.50 $182.50 revised clean plan

(0.2). Review revised clean

disclosure statement (0.3).

MM Review revised clean $365.00 0.60 $219.00

stalking horse agreement

(0.2). Review revised clean

bid procedures motion and

order (0.3). Review

correspondence with

potential liquidating trustee

(0.1).

$695.00 0.40 $278.00 January 22, 2020 PDR Review JLL information and

qualifications

MR Receipt $180.00 0.20 $36.00 of Order Granting

Debtor's Motion Pursuant to

Section 1121(d) of the

Bankruptcy Code for an

Extension of Exclusive

Right to File a Plan of

Reorganization and to

Solicit Acceptances [ECF

No. 222]; review order and

local rules for proper service

list of DE 222; update

calendar

$695.00 0.50 $347.50 PDR Review revisions to bid

procedures motion; PSA etc.

from Lender's counsel

January 23, 2020

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 55 of 144
PDR Review additional changes $695.00

to plan and disco from

Lender's counsel

JCM Review edits of Plan,

Disclosure Statement,

Stalking Horse PSA, Motion

to Approve Bidding

Procedures and Draft Order

0.60 $417.00

$495.00 2.80 $1,386.00

Approving Bidding

Procedures from secured

creditor; review open items

need to be resolved prior to

filing. (2.4); review

disinteredness affidavit from

Prospective Liquidating

Trustee (.2); review list of

executory contracts and

email with same (.2);

Review Secured Lender's

proposed revisions to

bidding procedures motion

(0.2). Further revise bidding

procedures motion (0.5).

Review Secured Lender's

proposed revisions to

bidding procedures order

(0.2). Further revise bidding

procedures order (0.5).

Review Secured Lender's

MM $365.00 3.60 $1,314.00

proposed revisions to

stalking horse agreement

(0.2). Further revise stalking

horse agreement (1.3).

Correspondence with Stuart

K re: missing agreement

exhibits (0.2). Determine

open issues and items

needed for bidding

procedures motion, bidding

procedures order and

stalking horse agreement

(0.5).

MM Review Secured Lender's $365.00 5.10 $1,861.50

proposed revisions to plan

(0.2). Further revise plan

(0.4). Review Secured

Lender's proposed revisions

to disclosure statement (0.2).

Further revise Disclosure

Statement (0.8). Determine

open issues and items still

needed for plan and

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 56 of 144
disclosure statement (0.5).

Draft motion for conditional

approval of disclosure

statement and combined

hearing with plan (1.8).

Draft order granting motion

for conditional approval

(1.2)

$495.00 2.00 $990.00 JCM Consider open issues that

must be addressed prior to

filing Plan, Disclosure

Statement and releated

January 24, 2020

pleadings (.8); call with Mr.

Romero regarding Plan and

Disclosure Statement issues;

draft email regarding same

(.5).; Call with Ms.

Rodriguez of JLL regarding

market and sale process and

listing agreement (.3);

review memorandum

regarding service of plan

and disclosure statement and

email from Ms. Tannenbaum

regarding same (.4).

Review local rules re:

timing of confirmation,

service of plan, disclosure

statement and related orders

and hearing dates (0.6).

Strategize and prioritize all

outstanding matters/issues to

be addressed in order to

MM $365.00 2.70 $985.50

comply with rules/statutes

and get necessary motions

and plan and disclosure

statement filed (1.6).

Develop to do and priority

list (0.5).

MM Review $365.00 1.60 $584.00 Plan effective date

and consider issues

concerning timing of

effective date on sale,

assumption and rejection

(1 .2). Review Plan re:

treatment of priority claims

(0.4).

$260.00 1.10 $286.00 LRT Meet regarding plan track

and pending items and

create task list (.7). Review

service rules for

plan/disco/ballots (.4)

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 57 of 144
Draft email to Mr. Rumpel $495.00 1.70 $841.50

regarding status ofretention

of broker (.1); call with Ms.

Rodriguez and Mr. Rumpel

regarding market and sale

process and retention (.5);

review email from Ms.

Tannenbaum regarding

litigation targets; consider

potential litigation targets

(.4); draft email to Mr.

Rumpel and Ms. Rodriguez

with draft motion to

approving bidding

procedures (.2); review

revised PSA and exhibits

and email from Mr. Kossar

January 27, 2020 JCM

(•5);

LRT Email Jairo/Moses re list of $260.00 0.30 $78.00

preserved causes of action

for exhibit to plan (.1).

Work on memo re

solicitation packages (.2).

PDR Review JLL Exclusive

Listing Agreement

$695.00 0.40 $278.00 January 28, 2020

$495.00 2.00 $990.00 JCM Review email and affidavit

from Prospective

Liquidating Trustee; respond

to same regarding potential

selection as Liqiudating

Trustee (.3); review and

revise JLL's draft listing

agreement; draft email to

Ms. Rodriguez regarding

same (.8); review and

respond to email regarding

potential litigation targets

(.2). Review email from

Prospective Liquidating

Trustee regarding

Liquidating Trustee issues

(.2); review and revise JLL

draft listing agreement (.5).

Review outstanding tasks

and upcoming deadlines

MM $365.00 1.30 $474.50

(0.3).; Review JLL listing

agreement (0.3). Review

Secured Lender's revisions

to PSA (0.5). Revise legal

description in PSA (0.2).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 58 of 144
LRT Email Trustee Services re $260.00 0.40 $104.00

solicitation packages (.1).

Prepare plan exhibit: list of

potential litigation target

(.3).

PDR Review status of plan and $695.00 0.40 $278.00

disco and related matters

including status of sale

pleadings

JCM Review voicemail from Ms.

Rodriguez regarding listing

agreement and bankruptcy

issues (.1); review email

from Mr. Kossar regarding

acceptance of edits to

Stalking Horse Agreement

January 29, 2020

$495.00 0.20 $99.00

(.1).

MCC Review $305.00 0.80 $244.00 and respond to

email correspondence;

review stalking horse

purchase agreements and

make comments on same

MM Review $365.00 0.50 $182.50 strategy and

potential timing re:

finalizing and filing plan

and disco (0.3).Update list

of potential litigation targets

(0.2).

MM Review $365.00 0.90 $328.50 strategy and

potential timing re:

finalizing and filing bidding

procedures motion, stalking

horse agreement (0.5). Make

additional minor revisions to

exhibits to stalking horse

agreement (0.2). Review

real estate revisions to

stalking horse exhibits (0.2).

PDR Review and revise PSA $695.00 0.40 $278.00 January 30, 2020

Revise $495.00 1.90 $940.50 and edit JLL draft

listing agreement; draft

email to Mr. Feurstein

regarding same (1.7); review

and respond to email from

Ms. Rodriquez regarding

same (.1); draft email to Mr.

Feurstein regarding draft

Stalking Horse Agreement

JCM

(.1).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 59 of 144
Draft email to Mr. Romero $495.00 0.10 $49.50

regarding need to review

draft Stalking Horse

Agreement (.1).

Review status of plan and

disclosure statement.

January 3 1 , 2020 JCM

MM $365.00 0.20 $73.00

Review status of stalking $365.00 0.60 $219.00

horse agreement, JLL listing

agreement, and sale motion

MM

(0.4). Review

correspondence re: budget

(0.1). Review

correspondence re: listing

agreement (0.1).

216.20 $93,312.50 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 60 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 331 31

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

Matter #:

Invoice #:

5589-7

69839

RE: Costa Hollywood Property Owner - CI 1 BKC (Fee App/Employ)

RATE HOURS FEE DATE LAWYER DESCRIPTION

MM Research re: whether $350.00 $175.00

disputed claims are counted

toward liabilities in UST

0.50 September 23,

2019

guidelines for retention and

applications in larger cases

(0.5).

$255.00 0.40 $102.00 LRT Research large case UST

guidelines.

Revise retention application $350.00 1.20 $420.00

in compliance with UST

large case guidelines (0.4).

Revise PDR affidavit in

compliance with UST large

case guidelines (0.3). Draft

Debtor's affidavit in

compliance with UST large

case guidelines (0.5).

Prepare retention application

for final review and

September 24,

2019

MM

MM $350.00 0.30 $105.00 September 25,

2019

signature prior to filing

(0.3).

PDR Application of the Debtor $695.00 $278.00

for an Order, on an Interim

Basis, Authorizing the

Employment and Retention

of Meland Russin &

0.40 September 26,

2019

Budwick, PA. as Attorneys

for the Debtor and Debtor In

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 61 of 144
Possession Nunc Pro Tunc

to the Petition Date (.4);

Revise, compile exhibits and $180.00 $54.00

finalize Application to

MR 0.30

Employ MRB

Receipt of Notice of Hearing $180.00 0.30 $54.00

re:Application to Employ

MRB; review local rules for

proper service list for

Certificate of Service; serve

September 27,

2019

MR

Notice; update calendar [.1];

compile documents and

prepare PDR for hearing on

Application to Employ [.2]

Review $695.00 0.20 $139.00 October 2, 2019 PDR disclosure of

compensation

Revise $180.00 0.10 $18.00 MR and finalize Order on

Application to Employ

MRB [DE 21]

Email $255.00 0.80 $204.00 re special tax counsel

retention (.1). Revise

invoices for fee app

purposes (.7).

Draft email regarding

application to employ

special tax counsel to pursue

tax appeal.

Draft application to employ

October 7, 2019 LRT

$495.00 0.10 $49.50 October 14, 2019 JCM

$245.00 1.80 $441.00 PH

Robb Udell, Esq. as special

tax appeal counsel. Draft

affidavit and order granting

same. Review draft application to

retain special counsel and

affidavit; draft email

regarding same (.2).

Work on draft employment

application for Udell. Email

to Udell re same.

Review docket re: Order on

Application to Employ

MRB; email exchange with

Christina Romero re: status

of Order

Draft email regarding

Court's ruling on record

regarding order approving

retention of MRB as counsel

to the Debtor and

preparation of final order.

$495.00 0.20 $99.00 October 15, 2019 JCM

$245.00 0.40 $98.00 PH

$180.00 0.20 $36.00 October 16, 2019 MR

$495.00 0.20 $99.00 October 17, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 62 of 144
Review proposed final order $495.00 $99.00

authorizing employment of

MRB; draft email regarding

same (.2).

Prepare final order

authorizing retention of

MRB as debtor's counsel.

Draft and respond to emails

regarding retention of Mr.

Udell for tax appeal of a d

valorem taxes (.2).

Telephone conference with

Jairo re resume (.1). Draft

retention app, affidavit and

proposed order (.7).

Finalize and upload Final

Order Approving

October 0.20 18, 2019 JCM

$255.00 0.30 $76.50 LRT

$495.00 0.20 $99.00 October 22, 2019 JCM

$255.00 0.80 $204.00 LRT

MR $180.00 0.10 $18.00

Employment of MRB

Follow up email to Robb $245.00 0.10 $24.50 PH

Udell re app to employ.

Review final executed order $350.00 2.40 $840.00 October 24, 2019 MM

on application to employ

MRB (0.1). Legal research

re: prepetition payment to

necessary professionals

(0.4). Revise application to

employ Jairo Romero and

pay prepetition amounts due

(1.6). Revise order

authorizing employment and

payment to Jairo (0.2).

Revise affidavit of Jairo

(0.1).

Receipt of Final Order $180.00 0.20 $36.00

Authorizing the

Employment and Retention

October 29, 2019 MR

of PDR and MRB [DE 113];

review local rules for proper

service list for certificate of

service of ECF No. 113

Review updated affidavit

from Robb Udell. Review

draft employment

application and order.

Communications with Udell

re his draft employment

application.

Read Consulting Agreement

and email re same.

$245.00 0.40 $98.00 PH

$255.00 0.20 $51.00 October 30, 2019 LRT

Review $495.00 0.20 $99.00 signed affidavit

from Mr. Udell; draft email

October 31, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 63 of 144
regarding filing of

application for employment.

MR Compile exhibits; revise and $180.00 $90.00

finalize Application to

0.50

Employ Robb Udell

PH Communications with Robb $245.00 0.30 $73.50

Udell. Review executed

affidavit. Finalize

application to employ.

MR Receipt ofNotice of Hearing

on Application of the Debtor

for an Order Authorizing the

Employment and Retention

$180.00 0.20 $36.00 November 4,

2019

of Robb Udell, Esq., and

Rennert Vogel Mandler &

Rodriguez, P.A. as Special

Tax Appeal Counsel Nunc

Pro Tunc to September 1 9,

2019 [ECFNo. 127]; review

local rules for proper service

list for Certificate of Service

re: same; update calendar

Revise JV Consulting

agreement (0.6). Review

independent contractor

agreement for JV Consulting

(0.2). Revise application to

employ Jairo as controller

(0.2). Revise order on

application to employ Jairo

(0.1). Revise Jairo's affidavit

MM $350.00 1.20 $420.00 November 5,

2019

(0.1).

$245.00 $24.50 PH Email communications with 0.10

Robb Udell re employment

application and hearing.

JCM Review and revise

application and affidavit for

retention of Mr. Romero as

$495.00 0.50 $247.50 November 6,

2019

controller; draft emails

regarding same.

MR Compile exhibits; revise and

finalize Expedited Motion to

Employ Jairo Romero as

Controller and for Payment

of Prepetition Amounts Due

MR Receipt ofNotice of Hearing

on Application of the Debtor

for an Order Authorizing the

Employment and Retention

$180.00 0.50 $90.00

$180.00 0.20 $36.00 November 7,

2019

of Robb Udell, Esq., and

Rennert Vogel Mandler &

Rodriguez, P.A. as Special

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 64 of 144
Tax Appeal Counsel Nunc

Pro Tunc to September 19,

2019 [ECFNo. 142]; update

calendar; review local rules

for proper service list for

Certificate of Service re:

same Review docket re:

Application to Employ Jairo

Romero (DE 143); discuss

with MEM; email exchange

with Susan (JA) re: same

Receipt of Notice of Hearing

on Expedited Application of

the Debtor for an Order

Authorizing the

Employment and Retention

of Jairo Romero of JV

International Consultants,

Inc. as Controller Nunc Pro

November $180.00 0.20 $36.00 19, MR

2019

November $180.00 0.20 $36.00 20, MR

2019

Tunc to September 19, 2019

and Authorizing Payment of

Prepetition Amounts Due

[ECF No. 156]; review local

rules for proper service list

for certificate of service;

update calendar

MR Compile documents re:

multiple applications to

employ and prepare JCM for

$180.00 0.20 $36.00 November 21,

2019

hearing on 11-26-19

$255.00 0.10 $25.50 November 27, LRT Revise Udell order.

2019

$495.00 0.20 $99.00 JCM Draft email regarding filing

of first fee application and

review response (.2);

MR Review Order Authorizing

the Employment and

Retention of Robb Udell,

December 5,

2019

$180.00 0.10 $18.00

Esq., and

Rennert Vogel Mandler &

Rodriguez, P.A. as Special

Tax Appeal Counsel Nunc

Pro Tunc to September 1 9,

2019 [ECF No. 167]; review

local rules for proper service

list for Certificate of Service

$255.00 0.80 $204.00 LRT Review and revise invoices

for fee app purposes.

December 9,

2019

$255.00 0.90 $229.50 December 10, LRT Revise invoices for fee app.

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 65 of 144
Review and respond to $495.00 0.10 $49.50

email from Mr.Kassower

regarding retention (.1).

Draft email to Mr. Kassower

regarding MaxCom

adversary case and Costa

402 case.

Review and respond to

email from Mr. Kassower

regarding retention; call

with Mr. Kassower

regarding same (.5).

Review and respond to

emails regarding retention of

special counsel; review edits

to application and affidavit

(.5); research regarding

disinterestedness standard

December 13, JCM

2019

December $495.00 0.30 $148.50 14, JCM

2019

December $495.00 0.50 $247.50 15, JCM

2019

December $495.00 1.10 $544.50 16, JCM

2019

pursuant to 11 U.S.C. Sec.

327(e) (.6).

Telephone conference with $255.00 0.20 $51.00

Michael Kassower re

information for retention

LRT

app. Review and respond to $495.00 0.80 $396.00

email from Mr. Kassower

December 17, JCM

2019

regarding employment as

special counsel, call with

Mr. Kassower regarding

same (.5); revise and edit

draft application to employ

Mr. Kassower, draft email

regarding same (.3).

Prepare retention

application, affidavit and

proposed order re Kassower

as special counsel.

Review Notice of Hearing in

Maxcom adversary (ECF

No. 5); review local rules for

deadline to respond;

calculate and calendar

deadline

Review emails and

pleadings re amended

disclosure.

Email exchange with

Michael Kassower, Esq.;

compile exhibits; revise and

finalize Expedited

Application to Employ

Michael Kassower as

$255.00 0.70 $178.50 LRT

MR $180.00 0.10 $18.00

$255.00 0.30 $76.50 December 19, LRT

2019

MR $180.00 0.60 $108.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 66 of 144
Special Counsel; email

exchange with Judicial

Assistant regarding

expedited hearing

Receipt ofNotice of Hearing

on Application to Employ

Michael Kassower, Esq. (DE

192); update calendar;

review local rules for proper

service list for Certificate of

$180.00 0.50 $90.00 December 20, MR

2019

Service of same; compile

documents and prepare

binder for hearing on

12-27-19

Call with Ms. Murphy to $495.00 0.30 $148.50 December 23, JCM

discuss hearing on retention

of Mr. Kassower and

2019

secured lender funding (.3).

Review and revise amended

disclosures re: Groisman

prior representation of J&R

Prepare amended declaration

of Peter adding Gabe

disclosures.

Review emails regarding

outcome of hearing on

retention of special counsel

$695.00 0.20 $139.00 December 26, PDR

2019

$255.00 0.20 $51.00 LRT

$495.00 0.20 $99.00 December 27, JCM

2019

(.2).

$350.00 2.40 $840.00 Prepare for hearing on

application to retain Michael

Kassower (0.5). Attend

hearing on application to

retain Michael Kassower

(1.0). Correspondence with

client re: special counsel

retention (0.2). Call with

Kassower re: approval of

retention (0.2). Draft order

granting application to retain

special counsel (0.5).

Review status of order

approving Kassower

retention.

Work on first interim fee

app and exhibits.

MM

MM $350.00 0.20 $70.00 December 3 1 , 2019

$260.00 1.70 $442.00 January 3, 2020 LRT

Review $365.00 0.20 $73.00 order authorizing

Kassower retention (0.1).

Correspondence with

Kassower re: entered order

January 6, 2020 MM

(0.1).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 67 of 144
Receipt of Order $180.00 0.20 $36.00

Authorizing the

Employment and Retention

of Michael R. Kassower,

Esq. and Frank Weinberg

Black, RL. as Special

Counsel Nunc Pro Tunc to

January 7, 2020 MR

December 9, 2019 [ECF No.

207]; review local rules for

proper service list for

Certificate of Service of DE

207

Work on exhibits to fee $260.00 1.10 $286.00 January 8, 2020 LRT

app. Work on exhibits to fee $260.00 1.30 $338.00 January 10, 2020 LRT

app.

Prepare Notice of Filing $180.00 0.20 $36.00

Amended Declaration of

Peter D. Russin, Esq. in

Support of Debtor's

Application to Employ and

Retain Meland Russin &

Budwick, P.A. as Attorney

for the Debtor and Debtor in

Possession Nunc Pro Tunc

to the Petition Date; revise

and finalize same

Finalize and file amended

disclosures (Gabe Groisman

joining firm)

Work on fee app exhibits.

January 13, 2020 MR

$695.00 0.20 $139.00 January 14, 2020 PDR

$260.00 2.40 $624.00 LRT

Review $495.00 0.30 $148.50 and respond to

email regarding potential for

collection actions by Mr.

Kassower (.3).

Work on invoices for fee

January 24, 2020 JCM

$260.00 0.60 $156.00 January 27, 2020 LRT

app. Review $495.00 0.30 $148.50 invoices from Mr.

Kassower and discussion of

fee structure for collections

activity (.3).

January 28, 2020 JCM

35.90 $11,400.50 Totals

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 68 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 331 31

TELEPHONE (305) 358-6363

Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

201 N Ocean Drive

Hollywood, FL 33019

Attention:

Matter #:

Invoice #:

5589-8

69840

RE: Costa Hollywood Property Owner - CI 1 BKC (Business Op)

RATE HOURS FEE DATE LAWYER DESCRIPTION

Review budgets for cash $695.00 $1,181.50

collateral motion (.5);

Review additional matters

that may require expedited

relief including critical

vendor list etc. (.5) TCs with

Jerry Feuerstein re: first day

motions and pending

litigation matters that need

to be resolved and related

matters. (.7)

Exchange emails with Josh

Rubens re: bankruptcy filing

and stay of pending

litigation (.3); TC from

Judge Ray's chambers

asking if any matters need to

be set on short notice (.3);

Review issues re: use of

cash and critical vendors

procedural issues and timing

for hearings given flux of

Judge's calendar (.5);

Review and revise letter to

Evolution re: restrictions on

use of cash collateral and

bank accounts (.3); Consider

Evolution demands and

related issues (.2);

PDR 1.70 September 20,

2019

$695.00 1.60 $1,112.00 PDR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 69 of 144
Review email from Steven

Davis re: request that unit

owners be able to rent their

own units despite rules to

the contrary; Review rules

related issues

Review and analyze emails

(.3); review and analyze

draft pleadings and related

support (1.4); research for

and drafting of cash

collateral motion (3.5);

meeting with clients (1.1);

review various email

PDR $695.00 0.30 $208.50

JCM $495.00 6.90 $3,415.50

correspondence related to

filing (.6).

Review management $495.00 $3,910.50

agreement with Evolution

regarding events of default

and termination issues (.5);

conference regarding same

(.8); review and analyze

draft pleadings and related

support for filing bankruptcy

(1.4); research for and

drafting of cash collateral

motion (3.5); meeting with

clients (1.1); review various

email correspondence

related to filing (.6).

JCM 7.90

Research for and drafting of $495.00 $3,861.00

letters to management

companies to stop all

payments (.7); draft email to

Mr. Romero regarding

discussion of budget and

critical vendors (.2); review

and analyze draft budget

(1.2); draft email and call to

Mr. Feurstein (.2); calls with

Mr. Romero regarding

budget (1.5); review and

analyze draft parking

services contract; analyze

whether the debtor can and

should enter contract

postpetition (.5); review and

analyze critical vendors and

amounts due and how to

JCM 7.80

handle payments (2.4);

review and consider issue of

unit owners attempting to

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 70 of 144
terminate their RMAs (.6);

call with Mr. Dunn and Ms.

Read regarding bankruptcy

and impact on Evolution's

management (.5).

MM Review status and necessary

items.

$350.00 0.80 $280.00

LRT Review and email re budget $255.00 $433.50

for cash collateral motion

1.70

(.4).

Revise cash management

motion and proposed order

(.2).

Revise insurance premium

motion and proposed order

(.2).

Revise customer programs

motion and proposed order

(.2).

Draft motion to pay critical

vendors and proposed order

(.7).

Review revised draft budget $695.00 $1,390.00

for cash collateral motion

(.4); Review draft pleadings

re: same (.6); Review issues

with Evolution contract and

consider management issues

September PDR 2.00 22,

2019

(.8);

TC w Jerry Feuerstein re: $695.00 2.10 $1,459.50

status of draft motion for use

of cash/financing and related

matters (.3); Review further

revised draft motion and

order re: same (.4); Review

and comment on further

revised draft budget (.3);

Review critical vendor list

(.4); Review issues and

concerns raised by Lender

re: funding operational short

falls (.3); Review cash

management motion draft

September 23,

2019

PDR

(•4)

Draft email to Mr. Romero $495.00 8.80 $4,356.00

regarding budget

preparations (.1); review and

analyze draft budget; callS

with Mr. Romero regarding

adjustments to same (3.8);

research for and drafting of

motion for use of cash

JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 71 of 144
collateral (4.4); draft email

to and call with Mr.

Feurstein regarding first day

motions (.5).

Review status of first days

and determine necessary

steps for review and filing

(0.2). Review notice of

deficiency (0.1). Review

notices of appearance (0.1).

Review and revise motion

and order re: customer

programs (0.3). Review and

revise cash management

motion and order (0.5).

Review and revise insurance

motion and order (0.3).

Review and revise critical

vender motion and order

MM $350.00 1.80 $630.00

(0.3).

$255.00 0.20 $51.00 Telephone conferences with

Jairo re budget and critical

vendor listing (.2).

Review multiple emails re:

use of cash, budget, critical

vendor issues etc. (.6);

Review numerous emails

LRT

$695.00 1.10 $764.50 September 24,

2019

PDR

with Evolution's counsel re:

inappropriate demands by

Evolution and related issues

(.5)

Call with Mr. Feurstein $495.00 8.80 $4,356.00

regarding cash collateral

issues (.2); research for and

drafting of 1 month cash

collateral motion (4.0); draft

and respond to emails from

Mr. Romero regarding same

(.3); review and respond to

emails from counsel for

Evolution; draft email to Mr.

Romero regarding same (.2);

discuss budget edits with

Mr. Romero (1.4); call with

counsel for Evolution

regarding budget issues (.2);

draft and respond to various

emails regarding report that

Mr. Greene of Evolution is

failing to turnover required

inforamtion to Mr. Romero

(.6); draft and respond to

JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 72 of 144
emails with Mr. Feurstein

regarding suggestion of

bankruptcy needed for case

(.3); call with Evolution

counsel and Mr. Romero

regarding budgetary issues

with Evolution work product

(.5); review list of

prepetition litigation in

which Costa was a

defendant or cross-defendant

(.2); review draft

suggestions of bankruptcy;

draft email to Mr. Feurstein

regarding same (.3); review

and respond to email from

Mr. Romero regarding

cancellation of wedding

event (.2); review and

respond to email regarding

review of first day motions

for consistency (.2).

Review revised cash

collateral motion (0.2).

Review IDI correspondence

(0.1). Review cash

management motion and

order re: DIP financing issue

(0.1). Review insurance

motion and order re: DIP

financing issue (0.1).

Review customer program

motion and order re: DIP

financing issue (0.1).

Review and revise critical

vendor motion and order re:

DIP financing issue (0.2).

Review correspondence re:

Evolution and ASG

MM $350.00 1.50 $525.00

information needed (0.3).

Participate in conference

call with management

counsel re: budget (0.4).

Strategize re cash collateral

(.2). Email Jairo re one

month budget (.1). Review

$255.00 1.00 $255.00 LRT

budget (.3). Telephone

conference re Initial Period

budget (.3). Telephone

conference and email with

Jairo re 366 Utilities (.1).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 73 of 144
Review numerous emails re: $695.00 0.80 $556.00

issues with Evolution,

Review revised budget and

related issues to use of cash

collateral; TC with counsel

re: strategic issues in deal

with Evolution issues

Draft email memorandum to

Mr. Feurstein regarding need

for procedure for approval

of use of cash collateral

outside of budget (.4)j;

review and analyze budget

and work with Mr. Romero

on edits (6.2); draft email to

Mr. Feurstein requesting use

of cash collateral to pay

Evolution payroll (.2);

review and respond to

inquiry regarding payroll

from Mr. Feurstein (.2); call

with Ms. Read regarding

Evolution issues (.3); call

with Mr. Feurstein to discuss

edits to budget line items

September 25,

2019

PDR

JCM $495.00 7.50 $3,712.50

(.3).

Revise and edit first day $495.00 0.40 $198.00

motions, draft email

regarding same (.4).

Review correspondence re:

cash collateral motion and

DIP financing (0.1). Revise

critical vendor motion (0.1).

Revise case management

system motion (0.1). Revise

insurance motion (0.1).

Revise customer program

motion (0.1). Review

revised insurance, cash

JCM

MM $350.00 1.50 $525.00

management, customer

program motions for

approval for filing (0.3).

Review notice of filing

master service list for filing

(O.l).Revise and prepare

insurance motion and order

(0.2). Revise and prepare

cash management motion

and order (0.2). Revise and

prepare customer programs

motion and order (0.2).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 74 of 144
Telephone conferences and $255.00 $867.00

emails with Alexis Read and

Michael Dunn re numerous

operations issues such as

payroll, budget items, DIP

accounts, cash management

motion, etc. (.8). Emails re

same (.8). Telephone

conferences and emails with

Jairo re revisions to Initial

LRT 3.40

Period budget for cash

collateral motion (.6).

Review first day pleadings

(1.2).

PDR Review $695.00 0.80 $556.00 and revise draft use

of cash motion etc.; Review

basis for title company

holding funds in escrow

PDR Debtor's Expedited Motion

for Authrization to (I)

Continue Insurance

September 26,

2019

$695.00 1.10 $764.50

Programs; and (II) Pay All

Insurance Obligation (.4);

Debtor's Expedited Motion

Pursuant to Sections 105(a),

363(b), and 503(b)(1) of the

Bankruptcy Code for

Authorization to Honor

Certain Prepetition

Customer Programs (.3);

Debtor's Expedited Motion

for (A) Authority to (I)

Maintain Certain Bank

Accounts and Continue to

Use Existing Business

Forms and Checks, and (II)

Continue to Use Existing

Cash Management System,

and (B) Waiver of Certain

Investment and Deposit

Guidelines (.4).

Review and analyze issues

related to estate assets

vis-a-vis funds held in

escrow by Greenberg

Traurig (.4); review and

respond to email from Mr.

Feurstein regarding changes

to draft cash collateral

motion and order; analyze

suggested edits and

incorporate accepted edits

$495.00 6.90 $3,415.50 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 75 of 144
(.7); work with Mr. Romero

to revise and edit budget and

motion and proposed interim

order (3.2); review and

respond to emails from Ms.

Read regarding various

inquiries related to cash

collateral motion (.3);

attention to finalizing and

filing first day motions (2.3).

Exchange emails re money

held in trust at GT (.1).

Exchange emails re

finalizing first day motions

and exhibits (.3).

Revise, compile exhibits and

finalize Motion to Maintain

Bank Accounts; Motion to

Continue Insurance

Programs and Pay

Obligations; Motion to Use

Cash Collateral and Motion

to Honor Certain Prepetition

Customer Programs

Review and respond to

emails from Mr. Romero

regarding opening of DIP

Accounts (.2); review and

respond to email from Ms.

Read regarding closure of

DIP Accounts and transfer of

funds inquiry (.2); review

email from Ms. Read

regarding past due amounts

owed to Evolution and

reimbursement requests;

draft email to Mr. Romero

regarding same (.4); review

draft of schedules and

SOFA, review areas where

information is still required

(.3); review first day

motions in preparation for

hearing (3.4); review and

analyze AP list regarding

amounts due and owing to

Evolution and Aimbridge

(.3); review email from Mr.

Romero with edits to

schedules (.2); research and

preparation for hearing on

first day motions (2.5).

LRT $255.00 0.40 $102.00

MR $180.00 1.30 $234.00

$495.00 7.40 $3,663.00 September 27, JCM

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 76 of 144
Exchange emails re deposits $255.00 $204.00

pending opening of DIP

operating account. Review

proposed order for first day

pleadings.

Receipt ofNotices of

Hearing re: Motion for Cash

Collateral; Motion to

Maintain Bank Accounts;

Motion for Authorization to

Continue Insurance

LRT 0.80

MR $180.00 1.00 $180.00

Programs and Motion to

Honor Prepetition Customer

Programs; review local rules

for proper service list for

Certificate of Service; serve

Notices; update calendar

[.5]; compile documents and

prepare PDR for hearings on

10-2-19 [.5]

PDR Review emails with UST $695.00 0.20 $139.00 September 30,

2019 and follow up re: bank

account issues;

Review email from Ms.

Read regarding life safety

and pest control (.2); draft

email to Mr. Romero

regarding same (.1);

research contracts and

determine if critical vendor

status with Mr. Romero (.4);

review and consider

inquiries from UST; call

with UST regarding same

(.4); review correspondence

on status of DIP Accounts

(.2); review correspondence

regarding proposal for

purchase (.1); review

correspondence from Ms.

Read re: ad buys; consider

response (.2); review

petition, case management

summary and draft first day

motions in preparation for

hearing; review statutory

and caselaw support for

authorities (3.7).

Review issues raised by

Andrew Zaron (Beauchamp)

re: cash collateral issues;

Review issues raised by

$495.00 5.40 $2,673.00 JCM

PDR $695.00 0.70 $486.50 October 1, 2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 77 of 144
Evolution counsel re:

prepetition taxes due and

consider if necessary to pay

before plan confirmation

Review and consider email

from Ms. Read regarding

past due sales and tourism

tax (.2); draft email to Mr.

Romero regarding same (.1);

call with Mr. Romero

regarding same (.2); call

with Ms. Read regarding

same (.3); review and

consider email from Mr.

Zaron regarding Beauchamp

issues with proposed cash

collateral order (.1); call to

Mr. Zaron regarding same

(.2); review and respond to

email from Mr. Welt

regarding interest in

purchase of property (.2);

review schedules and

$495.00 8.90 $4,405.50 JCM

underlying documentation

relevant to hearing on First

Day motions; prepare for

hearing (7.6).

Telephone conference with $255.00 0.90 $229.50

Jim, Michael and Alexis re

pending budget items and

critical vendors (.3). Update

pending items memo (.2).

Review proposed orders for

tomorrow's hearing (.4).

Review revised draft of

Cash Collateral order and

UST suggested revisions

(.4); Review Stay Relief

motions filed by Costa 402,

incorporate company and

PSO Investments and

LRT

PDR $695.00 1.30 $903.50 October 2, 2019

consider response to same

(.6); Review email from

Alexis Read re: operational

issues (.3)

Prepare for hearing on First

Day Motions and draft

prepared argument (3.1);

discussions with UST and

counsel for secured lender

and Evolution prior to

hearing (.4); attend hearing

$495.00 8.40 $4,158.00 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 78 of 144
on First Day Motions (2.0);

revise and edit cash

collateral order and cash

management order based on

comments from UST (.6);

review and respond to

emails and calls from Mr.

Feurstein regarding cash

collateral order (.3); revise

and edit proposed cash

collateral order (.2); review

and respond to emails with

Mr. Battista regarding cash

collateral order (.2); review

and consider email from Ms.

Read regarding Evolution

payment issues; draft email

to Mr. Romero regarding

same (.3); review and

consider email from Ms.

Read regarding FFE account

transfer request; draft email

to Mr. Romero regarding

same (.3); review and

consider email from Mr.

Romero regarding claims

against estate (.2); review

emails from Mr. Romero

regarding DIP bank account

status (.2); review and

respond to emails from Ms.

Read regarding DIP

Accounts; calls with Mr.

Romero regarding same (.6).

LRT Review numerous emails re $255.00 0.80 $204.00

business ops issues like cash

collateral budget and bank

accounts.

Revise and finalize Interim

Order Granting Debtor's

Amended Expedited Motion

for Use of Cash Collateral

(DE 23); revise and finalize

Order Granting Debtor's

Expedited Motion for

Authorization to Honor

Certain Pre-Petition

Customer Programs [DE

20]; revise and finalize

Order Granting Expedited

Motion to Continue

Insurance Programs [DE 1 8]

MR $180.00 0.60 $108.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 79 of 144
October $695.00 $347.50 3, 2019 Review emails from Alexis

Read and with Jerry

Fuerstein re: Critical Vendor

issues and related matters

and issues with funding

from Lender;

Review and consider, then

respond to various emails

from Ms. Read regarding

Evolution request to pay

prepetition critical vendor

past due invoices with cash

collateral; discuss with Mr.

Romero (2.2); review

schedules and disclosure of

compensation and finalize

for filing (.4); review and

respond to emails and call

with Mr. Feurstein regarding

PSA and related case issues

(.4); calls with Mr. Romero

regarding 6-month budget

preparation and consider

issues related to same (3.2);

draft email to Ms. Read

regarding preparation of 6

month budget and

slow-walking from

Evolution (.2); review and

respond to emails regarding

DIP bank accounts at

Marquis Bank (.2); call with

Mr. Feurstein regarding

debtor business operational

issues and plan

considerations (.4).

Consider issues raised by

Evolution's counsel re:

nonpayment of booking

vendors (0.3). Review

motions for stay relief filed

by unit owners (0.6).

Draft email to Mr. Romero

regarding second hearing on

use of cash collateral (.1);

review and respond to email

regarding Boucher Bros,

threat to terminate service;

calls with Mr. Romero

regarding same and various

budget issues and responses

to critical vendors (4.2); call

PDR 0.50

$495.00 7.00 $3,465.00 JCM

MM $350.00 0.90 $315.00

$495.00 5.20 $2,574.00 October 4, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 80 of 144
to Boucher to explain cash

collateral issues (.6); call

with Mr. Cendrati and

follow up email regarding

treatment of pre- and

post-petition debt of

Boucher Bros. (.3).

Email exchange with Edy

(JA) re: hearing on Cash

Collateral Motion and Cash

Management Motion; revise

and finalize Orders on ECF

MR $180.00 0.50 $90.00

Nos. 19 and 23

PDR TC $695.00 0.60 $417.00 from potentially

interested buyer (Doug

Wolfe)(he may send offer)

(.3); TC from Jeff Coppell

October 7, 2019

re: interest in property (.3)

Review and respond to

emails regarding DIP

account and prepetition bank

account closure status (.2);

draft email to UST regarding

her motion to dismiss (.1);

calls with UST regarding

motion to dismiss (.5);

review emails regarding

information for turnover

$495.00 8.30 $4,108.50 JCM

prior to IDI (.3); review

latest draft of 6-month

budget; transmit to Mr.

Feurstein for his preliminary

review (.4); investigate

sprinkler safety issue; call

with Mr. Romero regarding

same; draft email to UST

regarding same (.6); draft

email to Mr. Feurstein

regarding potential

protective advance for

booking services (.3);

review and respond to email

regarding retention of

special tax counsel on

contingency (.2); review and

analzye hotel management

agreement for default and

remedy issues; research

regarding rejection issues

(2.4); Review secured

lender's request for

documentation; research

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 81 of 144
files for same; draft email to

ms. Tannenbaum regarding

retrieval of same (.5);

review and analyze

documents to be turned over

pursuant to UST Guidelines

prior to IDI and prepare for

IDI (2.2); review and

consider email regarding

issue of payment of

prepetition taxes (.3); review

email from Mr. Romero

regarding funds availability

for Boucher Bros.; call with

Mr. Romero regarding same

(.3).

$255.00 $459.00 LRT Export Sched G and begin

compiling master

contracts/leases spreadsheet.

PDR Review numerous budget

issues raised by Lender

1.80

$695.00 0.40 $278.00 October 8, 2019

$495.00 9.40 $4,653.00 JCM Draft email to Mr. Romero

regarding budget (.1);

review and consider email

from Ms. Read regarding

sweep of FFE account for

paying payroll and status of

payment of sales and use

tax; draft email to Mr.

Romero regarding same (.4);

review and consider claim

filed by Broward County

regarding tax liability (.2);

research regarding executory

contracts and status (.6);

calls with Mr. Romero

regarding budget (2.2);

review and respond to email

from Ms. Read regarding

sweep of FFE account (.1);

review and respond to email

from Mr. Romero regarding

effect of bankruptcy on

condo association (.1); draft

email to Mr. Feurstein

regarding responses to

inquiries from secured

lender (.5); draft and

respond to emails from Ms.

Read to confirm constitution

of FFE funds (.4); consider

response to UST Motion to

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 82 of 144
dismiss (1.3); review and

analyze motion to strike

affidavit ofAlexey Bury and

order granting same; review

and respond to emails

regarding same (.4); prepare

for and participate in call

with counsel for prepetition

litigants against the Debtor

(.5); review and consider

email from Mr. Feurstein

regarding budget inquiry

items (.4); review and

consider joinders of various

unit owners to motion to

dismiss; draft email

regarding same (.3); review

and consider issue with

respect to developer; draft

email regarding same (.3);

review and analyze

executory contracts for

potential assumption

rejection issues (1.6).

Review and reply to

numerous emails and docs

re back up for budgeted

items.

Review documents

requested by Secured Lender

(.3); draft email transmitting

same to Mr. Feurstein and

$255.00 1.60 $408.00 LRT

$495.00 9.50 $4,702.50 October 9, 2019 JCM

inquiring regarding request

for protective advance of

Expedia bill (.2); draft email

to Mr. Romero regarding

budget development (.1);

review emails regarding

conversion of Chase bank

accounts to DIP Accounts

(.1); analyze proposed

budget; challenge

assumptions and research

backup for numbers; review

and analyze critical vendors;

draft emails regarding same;

calls with Mr. Romero

regarding same (7.8); review

and respond to email from

Mr. Feurstein regarding

Expedia bill (.2); research

regarding use of cash

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 83 of 144
collateral and retroactive

approval from court (.6);

call with Mr. Romero

regarding preparation for

IDI (.4).

MM Review entered interim cash $350.00 4.60 $1,610.00

collateral order (0.1). Emails

with Jairo re: response to

motion to dismiss (0.3).

Continue drafting response

to motion to dismiss (3.1).

Legal research re: unproven

allegations in motions (0.2).

Legal research re: standards

to establish cause for

appointment of a trustee

(0.5) Legal research re: best

interests of creditors and

estate for appointment of a

trustee (0.4).

Review Sched

G/Spreadsheet and compare

to current docs provided,

review email from Judicial

Assistant re: Cash

Management Order; revise

Order as requested and

upload same

Review updated budget for

use of cash and financing

motion

Draft email to Mr. Feurstein

$255.00 3.80 $969.00 LRT

MR $180.00 0.20 $36.00

October PDR $695.00 0.40 $278.00 10, 2019

$495.00 0.50 $247.50 JCM

regarding budget (.2);

review parking contract with

M&M; transmit to Mr.

Feurstein (.2); review

documents from Mr.

Romero regarding budget

backup from Evolution;

draft email regarding same

(.1);

MM Review upcoming hearings $350.00 0.10 $35.00

and associated deadlines

(0.1).

$255.00 0.30 $76.50 LRT Review Expedia invoice and

add re critical vendor.

Review parking contract and

compare to Schedule G.

MR Review Interim Order $180.00 0.60 $108.00

Granting Motion for Cash

Collateral (DE 69); calendar

all dates and deadlines;

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 84 of 144
review Re-Notice of

Hearing on Motion for Cash

Collateral (DE 70); update

calendar; review local rules

for proper service list for

Certificate of Service of

ECF Nos. 69 and 70

$495.00 7.40 $3,663.00 JCM Consider issues related to

DIP Financing and Secured

Lender's funding mechanism

and terms for DIP

Financing; draft emails

regarding same (3.6); review

and consider email from Mr.

Romero regarding

threatening letter from Unit

Owner attorney re: revenue

share and how to respond;

research regarding 365 and

executory contract issues

(2.6); review and consider

email from Mr. Feurstein

regarding removal of state

court action (.4); review

email from Ms. Read

regarding condo dec. Send

email regarding same (.2);

review condo declaration

October 11, 2019

(.2); review GL entries from

Evolution and ASG (.4).

MR Review Order Granting $180.00 0.60 $108.00

Debtor's Expedited Motion

for Authority to Maintain

Bank Accounts and

Continue Use of Cash

Management System (DE

78); calculate and calendar

deadline(s); receipt of

Re-Notice of Hearing on

Motion for Cash

Management (DE 80);

review Re-Notice of

Hearing on Motion for Use

of Cash Collateral (DE 79);

review local rules for proper

service lists for Certificate

of Service of ECF Nos. 78,

79, and 80

$495.00 0.90 $445.50 JCM Research regarding

requirements for filing

removal of state court action

(.6); review and respond to

October 13, 2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 85 of 144
email from Mr. Feurstein

(.1); call with Mr. Feurstein

regarding removal issues

(.2).

Review critical vendor and $695.00 0.30 $208.50

financing issues including

procedural matters

Review issues raised by

Lender's counsel to budget

and cash collateral motion

and order

Draft email regarding status

of bank accounts to comply

with Cash Management

Order (.2); draft email

regarding allegations made

against Mr. Bensusan and

the Debtor (.2); review and

respond to various emails

from Ms. Read regarding

allegations regarding Mr.

Romero (.6); draft email and

call with Mr. Romero

regarding same (.4); review

and analyze proposed

6-month budget; draft

emails and call with Mr.

Feurstein regarding same

(3.2) review and respond to

emails with Ms. Read

regarding Expedia service

(.2); review and analyze

critical vendors list; draft

email regarding same (.4);

research regarding funds

held in escrow account at

GT on behalf of Stewart

Title; draft emalis regarding

same (2.1); review booking

service invoitces; draft email

regarding same (.3); review

and consider draft PSA (.5);

draft email to Mr. Vega

regarding review of PSA

(.1); revise and edit cash

collateral and financing

motion; draft email to Mr.

Feurstein regarding same

(1.2); draft and respond to

various emails regarding

cash collateral budget and

interim order (.5);

October 14, 2019 PDR

PDR $695.00 0.70 $486.50

JCM $495.00 9.90 $4,900.50

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 86 of 144
Review critical vendor and $255.00 $153.00

create exhibit to motion (.2).

Revise motion to pay critical

vendors (.2). Review

numerous emails re critical

vendors and invoices (.2).

Review revised draft order

on use of cash and

financing; Call with

Lender's counsel re: cash

collateral/financing order

Review and analyze RMAs;

consider

LRT 0.60

$695.00 0.80 $556.00 October 15, 2019 PDR

$495.00 9.50 $4,702.50 JCM

assumption/rejection issues

related to RMAs (2.1); draft

email to Mr. Romero and

Mr. Bensusan regarding

hearing on motion to

dismiss (.1); research

regarding escrow held at GT

for Stewart Title (.6); call

with Mr. Romero regarding

escrow held at GT (.3);

review limited objection

filed by Beauchamp (.2);

review and analyze motions

for relief from stay; draft

email to Mr. Romero

regarding same (.6); draft

email to Mr. Romero

regarding status of

conversion of Chase

accounts to DIP accounts

(.1); draft email to Mr.

Feurstein and Mr. Battista

regarding review of budget

and cash collateral order

(.1); draft email to Mr.

Sharpe at GT regarding

escrow account for Stewart

Title; call with Mr. Sharpe

regarding same (.5); draft

email to Ms. Supple

regarding interaction with

GT lawyers regarding

escrow account for Stewart

Title (.1); call with Mr.

Feurstein regarding escrow

account at GT for Stewart

Title (.3); review and revise

draft responses to motions to

lift stay; draft emails

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 87 of 144
regarding same (.4); revise

and edit draft interim cash

collateral order; draft emails

regarding same (2.8); review

critical vendor list; draft

email regarding same (.3);

review and respond to email

from Ms. Read regarding

payment due to Cintas (.2);

draft email to Mr. Romero

regarding Cintas and

consider response (.2); call

with Mr. Andron regarding

county tourism trust fund

taxes due; consider issue

and research trust fund taxes

(•6);

$495.00 0.40 $198.00 JCM Review edits to proposed

Cash Management Order

from counsel for Chase

Bank; draft email regarding

same (.3); draft email to

counsel for Chase Bank

regarding her proposed edits

to proposed Cash

Management Order (.1)

MR Meeting with JCM to

discuss cash collateral

motion and critical vendor

$180.00 1.20 $216.00

motion; discuss upcoming

hearing on 10-17-19 [.5];

Revise, compile exhibit(s)

and finalize Expedited

Motion to Use Cash

Collateral [.7]

MR Revise, $180.00 0.60 $108.00 compile exhibit(s)

and finalize Expedited

Motion to Pay Critical

Vendors Prepetition Claims

PH Prepare redline cash

management order (.1) Work

on critical vendor motion

$245.00 1.30 $318.50

and exhibit (.4) Review

budget and discuss same

with Jim Moon. Work on

cash collateral exhibit and

motion (.8)

TCs from Thomas Lehman,

counsel for certain unit

owners re: cash collateral

budget and financing issues

and specific line items re:

$695.00 0.30 $208.50 October 16, 2019 PDR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 88 of 144
distribution ofroom revenue

to unit owners

Call with client to discuss

hearing and sale process for

bankruptcy case (.8); review,

consider and respond to

email from Ms. Read

regarding past due sales and

use tax (.4); research

regarding payment of

prepetition trust fund taxes;

draft email to Mr. Feurstein

regarding same (1.6);

review, consider and

respond to Ms. Read's email

regarding past due amounts

owed to Evolution and its

affilates and employees;

draft email to Mr. Feurstein

regarding same (.4); draft

email to Mr. Romero

regarding amounts due to

Evolution (.2); review and

respond to emails requesting

meeting with Mr. Bensusan;

call with Mr. Bensusan

regarding preparation for

hearing on motion to

dismiss and other motions

(.6); review email and

attachment from Mr.

Romero regarding task force

receivable; draft email to

Ms. Read regarding same

(.3); review and respond to

emails regarding American

Pool (.2); review email from

Mr. Romero regarding job

duties of Mr. Bensusan (.2);

review email from Mr.

Romero regarding Stewart

title indemnity agreements;

draft email to Mr. Feurstein

regarding same (.2);

research regarding status of

appeal of state court action

regarding Burya; draft email

regarding same (.3); review

email from Mr. Lehman

regarding postpetition

payments to unit owners he

JCM $495.00 10.70 $5,296.50

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 89 of 144
represents; research issue

and respond (.4); review

email regarding Hotelier

threat to suspend service;

consider response; draft

emails regardng same (.7);

review email from Mr.

Andron regarding trust fund

taxes; review form moition

and caselaw references; draft

email regarding same (1.2);

review motions and

responses to be heard at

hearing on 10/17 and

prepare for hearing (3.2).

Compile extensive

documents and prepare JCM

and MEM for hearing on

10-17-19 re: Motions to

Maintain Bank Accounts,

Cash Collateral, et al

Review issue re: Lender

interest rate for post petition

advances

Consider mechanism for

funding shortfalls in budget;

draft email to Mr. Feurstein

regarding same (.4); review

and respond to email from

Mr. Battista regarding

language in interim cash

collateral order to resolve

objection of Beauchamp

(.2); prepare for and attend

hearing on Motion to

Dismiss and other motions;

negotiate critical vendor

issues at court (8.5); review

and consider emails from

Mr. Davies regarding his

motions for stay relief (.3);

draft email to Mr. Romero

inquring regarding the issues

described by Mr. Davies

(.2); draft and respond to

emails regarding status of

state court appeal in Burya

matter (.3); review email

from Mr. Halperin regarding

his client's financing of gym

equipment; forward to Mr.

Feurstein (.2); review email

MR $180.00 0.50 $90.00

$695.00 0.20 $139.00 October 1 7, 20 1 9 PDR

$495.00 10.30 $5,098.50 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 90 of 144
regarding reinstatement of

valet charge to room; draft

email to Mr. Romero

regarding same (.2).

Work on updated critical

vendor list and totals (0.3).

Review orders that need to

MM $350.00 0.80 $280.00

be updated post-hearing

prior to submission (0.2).

Review necessary tasks

following hearing (0.3).

LRT Email critical vendor $255.00 2.00 $510.00

spreadsheet v6. Read

recently filed pleadings (.9).

Strategize re status of case

and next steps (.8). Obtain

status of hearings (.3).

JCM Review and respond to

email from UST regarding

upload of Cash Management

Order.

JCM Review and respond to

email from Mr. Battista

October $495.00 0.10 $49.50 18, 2019

$495.00 5.40 $2,673.00

regarding DIP Financing

priming lien (.2); review

voicemail from Mr. Lehman

regarding inquiry related to

hearing on 10/17; draft

email regarding same (.2);

review and respond to email

regarding upload of Cash

Management Order (.1);

review DIP Report

documentation prepared by

ASG (.4); review email from

Mr. Romero to Mr. Chu

asking for input on critical

vendors; draft email to Mr.

Romero regarding

modification of critical

vendor list (.2); revise and

edit draft second interim

order approving use of cash

collateral and Postpetition

Financing; draft email to Mr.

Feurstein and Mr. Battista

regarding same (1.2); review

email from Ms. Read

regarding payment and

reporting of trust fund tax

(.2); review comments to

draft PSA from RE team

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 91 of 144
(.3); research regarding

executory contracts - assumption/rejection issues

(1.4); review and consider

email inquiry from Mr.

Romero regarding

accounting for debt owed by

debtor to debtor; draft email

regarding same (.2); review,

consider and respond to

email inquiry from Mr.

Romero regarding unit

owner revenue share

treatment (.6); review emails

and attached agreements

from Mr. Halperin regarding

his client United Leasing's

position that it has a PMSI

in the gym equipment and

reservation ofrights (.4).

MR Revise and finalize Final $180.00 0.10 $18.00

order on Cash Management

System (DE 19)

$495.00 0.90 $445.50 October 20, 2019 JCM Review and consider email

from Mr. Romero regarding

difficulty getting

information from Evolution

to do the DIP Reports; call

with Mr. Romero regarding

same (.5); review email

from Mr. Battista regarding

review of proposed cash

collateral order (.1); draft

email to Mr. Romero

regarding status of revised

cash collateral budget (.1);

review email from Mr.

Romero to Mr. Chu

requesting various

information for the DIP

Report (.1); review response

from Mr. Chu regarding

information needed for the

DIP Report (.1).

PDR Review management $695.00 0.40 $278.00 issues

with Evolution and consider

October 2 1 , 20 1 9

alternatives

JCM Consider information

needed from Mr. Romero

and DIP responsibilities;

draft email to Ms.

Tannenbaum regarding same

$495.00 4.60 $2,277.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 92 of 144
(.4); draft email regarding

review of United Leasing

financing documents; review

response from Ms. Murphy

(.2); draft update email to

Mr. Feurstein and Mr.

Battista regarding status of

open items for Debtor (.4);

review email from Mr.

Feurstein regarding hotel

management; draft email to

client regarding same (.2);

review and respond to email

from Ms. Murphy regarding

DIP Report status (.1);

review email from Mr.

Kassower and response from

Ms. Murphy; consider

automatic stay violation

issue (.4); review emails

between Mr. Andron and

Ms. Read regarding tax

payment logistics (.3);

review various emails

regarding DIP Report and

issues preventing filing

(1.5); call with Mr. Feurstein

regarding management

issues and budget shortfall

funding (.4); review AP

request from Mr. Chu (.2);

review email from Mr.

Davis regarding negotiations

over rental rules (.1); review

proofs of claim filed against

estate (.2); review letter

from IRS requesting

business information (.2);

Call with Mr. Orlovski

regarding his unit owner

clients and request to

negotiate regarding terms for

renting condos outside of

RMA (.2); review email

regarding call from Mr.

Kessler re: creditor (.1);

review letter from Mr.

Kassower re: High

Horizons; consider stay

violation issues; review and

respond to emails regarding

same (.5); review letter

$495.00 7.20 $3,564.00 October 22, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 93 of 144
from IRS requesting

business information (.2);

review draft HMA and email

regarding same (.2);

consider retention of Mr.

Romero and related issues;

draft email regarding same

(.7); consider issues related

to payment of bed taxes and

motion seeking approval to

pay same; draft email with

form of motion (.4); review

and respond to email from

Ms. Read regarding payment

of critical vendors (.2);

review and analyze Stewart

Title Indemnity Agreements

(.4); review and respond to

emails regarding DIP Report

filing status and issues

completing information (.3);

review email from Ms. Read

regarding valet charges;

draft email to Mr. Romero

regarding same (.2); review

correspondence from AFCO

representative regarding

payment of insurance

premiums (.2); review

critical vendor list; draft

email to Mr. Romero

regarding same (.2); review

and respond to email

regarding amount due to

Johnson Controls (.2);

consider issues with

finalizing DIP Report;

review and respond to

emails regarding same (.9);

review and respond to

emails from Ms. Read

regarding payment of taxes

due (.2); consider issues

with completing DIP Report

(.8); review and revise notes

for DIP Report (.3); review

and respond to email

regarding reach out to UST

(.2); review email and call

with Ms. Israel regarding

PMSI status of United

Leasing; review financing

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 94 of 144
documents (.7); review

email regarding stop

payment of checks (.1);

Review Final Order

Granting Debtor's

Expedited Motion for (A)

Authority to (I) Maintain

Bank Accounts and

Continue to Use Existing

Business Forms and Checks,

and (II) Continue to Use

Existing Cash Management

System, and (B) Waiver of

Certain Investment and

Deposit Guidelines [ECF

No. 103]; review local rules

for proper service list for

Certificate of Service of

MR $180.00 0.20 $36.00

same Review issues with secured

claim of gym equipment

financier and adequate

protection payments per

budget; Review issue re:

insurance premium

financing

Draft email to Mr. Romero

regarding need for critical

vendor list (.1); consider the

issue of adequate protection

payments for United

Leasing; review agreements

and draft email to Mr.

October PDR $695.00 0.30 $208.50 23, 2019

$495.00 7.90 $3,910.50 JCM

Halperin and Ms. Israel and

review response (.7); review

and respond to email from

Mr. Feurstein regarding

United Leasing's PMSI (.1);

review and analyze revised

draft DIP Report; draft email

with inquires regarding

same (.8); preparation for

and call with UST regarding

DIP Report (.6); draft email

to Ms. Ryan regarding

payment of insurance

premium (.2); review edits

to proposed second interim

cash collateral order; draft

email regarding same (.3);

review edits to critical

vendor proposed order; draft

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 95 of 144
email regarding same (.2);

draft email to, and review

response from Mr. Davis

regarding discussion to

consider settlement of issues

with unit owners he

represents (.2); revise and

edit notes to DIP report;

draft email regarding same

(.4); consider whether DIP

Report reflects gross

revenue accurately; draft

email to Mr. Romero

regarding same (.3); review

critical vendor list; draft

email with required edits

(.4); review email regarding

edits to draft purchase and

sale agreeement (.2); draft

email to Mr. Feurstein

regarding edits to critical

vendor list (.1); draft email

with required edits to critical

vendor list (.2); review and

respond to email from Mr.

Romero regarding payment

of insurance (.1); revise

draft proposed order

approving payment of

critical vendors; draft email

to Mr. Feurstein regarding

same (.2); review, consider

and respond to inquiry from

Mr. Chu regarding change

order with bank (.2); draft

critical vendor order and

budget to UST, hotel

management company and

secured lender (.2); review

and respond to email from

Ms. Read regarding funding

from the secured lender

protocol (.3); review and

analyze draft HMA; draft

email to Mr. Romero

regarding same (.6); meeting

with Mr. Romero and Mr.

Bensusan regarding case

sale issues (1.5);

Review outstanding tasks

and priority (0.2). Review

notice of hearing on Terry

MM $350.00 4.10 $1,435.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 96 of 144
motion for relief from stay

(0.1). Legal research re:

relationship between tourist

development tax and trust

fund tax (0.5). Draft and

revise motion to pay

prepetition tourist

development tax (0.9). Draft

proposed order authorizing

payment of tourist

development tax (0.3).

Meeting with client re:

strategy for various

outstanding tasks including

retention of professionals

and timing of sale motion

(1.0) Continue review of

draft stalking horse

agreement (0.5). Revise

stalking horse agreement to

include additional

bankruptcy protections and

bidding procedures (0.6).

Draft email regarding

fmalization and upload of

critical vendor proposed

order (.2); review United

Leasing PMSI agreement for

gym equipment; draft email

regarding same (.3); draft

and respond to emails

regarding cash collateral

October JCM $495.00 5.00 $2,475.00 24, 2019

budget (1.2); draft and

respond to emails regarding

retention of RE broker (.3);

draft email regarding

retention of Mr. Udell as

special counsel for tax

appeal (.2); review and

respond to emails from Mr.

Chu and Ms. Read regarding

AP list (.3); review and

respond to emails regarding

line items in DIP report (.3);

review and respond to

emails regarding sweep of

the FFE account (.3); review

proposed pest control

contract; review and respond

to emails regarding same

(.4); review and analyze LOI

from potential purchaser and

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 97 of 144
email regarding same (.2);

review email from Mr.

Andron regarding motion

for payment of county bed

taxes (.2); review shared

facilities invoices from Mr.

Chu (.3); draft email

regarding questionaire for

IRS (.1); review MCR

contract and redline; call

with Mr. Feurstein regarding

same (.6).

MR Revise and finalize Order $180.00 0.20 $36.00

Granting Motion

Authorizing Payment of

Prepetition Claims of

Critical Vendors (DE 98)

[.1]; discuss claim of The

Plumbing Experts with

JCM; review claims register

[.1]

Draft $495.00 4.80 $2,376.00 emails regarding

selection of broker for sale

of project (.2); draft email

regarding status of budget

(.1); review and respond to

email from Mr. Chu

regarding timing of funding

from Madison (.1); review

email from Mr. Chu

attaching invoices for

certain vendors (.2); draft

email to Mr. Bensusan

regarding the execution of

postpetiton contracts (.2);

review and analyze AP

request from Mr. Chu; draft

email requesting

clarification of intent of

email (.3); call with Mr. Chu

regarding AP request (.3);

review and analyze draft

Second Interim Cash

Collateral Order; draft email

requiring clarification of

UST fees (.5); consider

payments to critical vendors;

draft email regarding order

approving such payments

(.2); review LOI for

property; consider

sufficiency of offer (.3);

October 25, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 98 of 144
review and consider budget

and shortfall funding issues

(1.3); circulate draft budget

and draft second interim

order to Mr. Feurstein and

request interim amount (.2);

draft email regarding filing

of motion to pay trust fund

taxes (.1); review and

respond to emails regarding

security at property (.2);

ddraft email to UST

regarding motion to pay

trust fund taxes (.1); review

email regarding business

information request from

IRS (.1); draft email to Mr.

Romero regarding need for

updated budget for

circulation (.1); review and

respond to email from Mr.

Chu regarding payment to

specific critical vendors;

review critical vendor list

(.2); review email from Ms.

Israel regarding United

Leasing adequate protection

issue (.1);

Review strategy re:

Evolution (0.1). Revise

motion to pay tourist

development tax and order

on same (0.1). Email to

Scott Andron re: motion to

pay tax (0.1). Review status

of security for hotel (0.2).

Email to Jairo re: security

MM $350.00 0.60 $210.00

(0.1).

Review AP request no. 1 $255.00 1.00 $255.00

(.2). Read emails re broker

for marketing business (.1).

Review contract/lease

LRT

schedule and compare to zip

file contracts/leases (.7).

Draft email regarding

Evolution request regarding

valet charges (.1); review

and respond to email from

Ms. Besu of City Group

Consulting regarding unit

owner inquiry (.2); review

and analyze demands from

$495.00 1.00 $495.00 October 26, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 99 of 144
unit owners reprsented by

Mr. Davis; review condo

declaration; draft email to

Mr. Romero regarding same

(•7);

JCM Draft emaii to Mr. Romero $495.00 2.20 $1,089.00

regarding call with UST and

availability (.1); draft email

to Ms. Israel regarding

United Leasing PMSI

financing and consideration

of adequate protection issues

(.2); review and respond to

email from Mr. Romero

October 28, 2019

regarding unit owner issues

of clients of Mr. Davis (.2);

review and respond to email

from Ms. Murphy regarding

filing of motion to approve

payment oftaxes (.2);

review and analyze revised

budget; draft email to Mr.

Romero regarding same (.3);

review request for business

information (.1); review and

consider responses to issues

of unit owners represented

by Mr. Davis (.4); call with

Mr. Feurstein regarding

funding issues (.2); review

email from Ms. Israel

regarding her client's

preparation of adequate

protection motion (.1);

review email from Mr.

Rochford with offer for

Hilco to provide auction and

brokerage services for

bankruptcy case (.3); review

email from Mr. Udell

regarding affidavit for

application to employ (.1);

review and consider email

from Mr. Chu regarding

need for funding (.3).

Read numerous emails and

attachments re budget items

and follow up.

Revise and finalize Motion

to Pay Prepetition Tourist

Tax [.4]; prepare

correspondence to IRS re:

$255.00 0.80 $204.00 LRT

MR $180.00 0.60 $108.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 100 of 144
Request for Business

Information Form [.2]

Review and analyze revised $495.00 6.70 $3,316.50

budget; draft email to Mr.

Romero regarding same (.4);

draft email to Mr. Feurstein

regarding budget and need

for interim amount (.2);

review and analyze emails

and documentation related

October 29, 2019 JCM

to payment of critical vendor

Itekz (.4); review edits to

affidavit made by Mr. Udell;

draft email regarding same

(.2); draft email regarding

approval of PE services

contract (.1); review emails

from Ms. Tecedor regarding

payment of critical vendor

Cintas (.2); review email

from Mr. Romero regarding

amount of interim amount

(. 1); review revised budget;

draft email to Mr. Romero

regarding interim amount

needed for order (.3); review

emails and draft motion and

affidavit regarding

employment of Mr. Udell

(.3); review and analyze

revised budget; draft email

to Mr. Feurstein regarding

same (.4); review redline of

purchase and sale

agreement; call with Ms.

Murphy regarding same (.3);

review and analyze email

from Mr. Chu regarding

funding request; draft email

to Mr. Romero regarding

same (.4); draft email to Mr.

Feurstein regarding edits to

budget (.1); call with Mr.

Feurstein regarding budget

and funding interim amount

(.3); review and analyze

draft consulting agreement

for Mr. Romero's LLC (.7);

review and analyze revised

budget and projections from

Evolution (2.3);

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 101 of 144
Compare budget with $350.00 1.60 $560.00

funding request from

Evolution to determine

discrepancy (0.2). Analyze

non-bankruptcy provisions

of Stalking Horse agreement

from Secured Lender (0.3).

Further revise Stalking

Horse agreement (1.1).

Review issues re: payments

due to internet and related

service provider

Review email from Mr.

Romero regarding budget

issues; call with Mr. Romero

regarding same (.5); review

and respond to email

requesting call with

Evolution and Counsel and

Costa and Counsel (.1); call

with Ms. Read regarding

budget issues (.4); call with

Mr. Romero regarding

budget issues (.3); call with

Evolution and counsel with

Costa (.6); review and

respond to email regarding

conversion of bank accounts

to DIP accounts (.1);

consider postpetition

contract approval and timing

(.4); review and analyze

updated funding chart from

Mr. Chu; draft email to Mr.

Romero regarding same (.4);

review and analyze the

condo declaration; consider

issues of Mr. Davis' client

and potential for settlement

(2.6); draft email to Mr.

Romero regarding issues of

Mr. Davis' clients (.2); draft

email to Mr. Davis setting

up call to discuss his issues

(.1); call with Mr. Davis to

discuss potential settlement

and draft email regarding

same (.7);j review and

analyze latest draft of

budget; draft email to Mr.

Romero regarding same (.4);

review and respond to

MM

October $695.00 0.20 $139.00 30, 2019 PDR

JCM $495.00 8.20 $4,059.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 102 of 144
inquiry regarding payment

to critical vendors (.2);

review condo declaration;

draft email to Mr. Vega

requesting analysis of

amendement v. Rule

promulgation authority (.9);

review and respond to email

from Ms. Read regarding

payment to critical vendors

(.1); review and respond to

inquiry regarding payment

of cable provider (.2).

Read numerous issues on

pending items relative to

budget and critical vendors

(.9). Update pending items

memo (.2). Review Comcast

invoices and issues (.2).

Review condo dec and

RMA issues (.7).

Draft email regarding

inquiry from Evolution

regarding charging of valet

charges to rooms (.1);

review funding calculations

from Mr. Chu; draft email to

Mr. Romero regarding same

(.4); review and respond to

email from Mr. Chu

regarding ability to pay

critical vendors (.2); listen to

voicemail from potential

unit owner; draft email to

Mr. Romero regarding same

(.3); review analysis of

condo dec. From Mr. Vega

(.3); draft update email to

Mr. Feurstein regarding

budget and funding issues

(.4); review email from Mr.

Andron regarding tax

liability and related emails

in response (.4); review

funding update from Mr.

Chu; draft email to Mr.

Feurstein regarding same

(.2); review and analyze

latest draft of budget;

forward to Evolution for

their review (.4);draft update

email to UST with draft

LRT $255.00 2.00 $510.00

$495.00 4.40 $2,178.00 October 31, 2019 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 103 of 144
budget (.2); draft email to

Mr. Feurstein with new draft

budget (.1); review draft

consulting agreement for

Mr. Romero; draft email of

preliminary thoughts based

on review (.6); revise draft

second interim cash

collateral order; draft email

to Mr. Feurstein with draft

order and budget (.3);

review demand letter sent

from counsel for unit owner;

draft email regarding stay

violation (.2); draft email

directing fmalization and

upload of order and budget

(.1); review email from Ms.

Israel regarding agreement

on adequate protection;

consider response (.2).

Review Condo Dec for

amendment provisions;

review and respond to

correspondence

Review and consider issues

pertaining to continued cash

collateral problems (0.2).

Review and respond to

email from Ms. Israel

$325.00 0.50 $162.50 BNV

MM $350.00 0.20 $70.00

$495.00 2.60 $1,287.00 November 1, JCM

2019

regarding United Leasing's

adequate protection issue

(.2); review notice of

hearing for Motion for

Relief from Stay filed by

creditor Pamela Terry;

review motion for relief

from stay; draft email

regarding same (.4); draft

detained email to Mr.

Romero regarding

negotiation points with Mr.

Davis' unit-owner clients

(.4); review email from Mr.

Romero with responses to

Mr. Davis' issues (.2);

review demand letter re:

Unit 302 and email

regarding same (.2); review

email from Mr. Romero

regarding valet charges to

room (.1); review response

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 104 of 144
email from Ms. Israel

regarding United Leasing

adequate protection issue

(.1); review and respond to

email from Mr. Romero

regarding budget (.1); draft

emails regarding fmalization

and filing of draft cash

collateral order and budget

(.3); review and respond to

email from Mr. Romero

regarding payment of

vendors (.1); review draft

agreement for potential

retention post-petition (.6);

MM Review order setting hearing $350.00

on motion for payment of

prepetition trust fund taxes

0.70 $245.00

(0.1). Call with Eduardo

Rodriguez re: potential

Whats Contact demand

letter stay violation (0.2).

Review client comments on

issues involving unit owners

claims and valet parking

(0.3). Email to client re: stay

relief violation (0.1).

Revise and finalize Second

Interim Order on Cash

Collateral [.3]; receipt of

Notice of Hearing on

Debtor's Motion To Pay

Prepetition Tourist

Development Tax [ECF No.

123]; review local rules for

proper service of list re:

same [.2]

Consider consulting

agreement with Jairo

Romero;

Review and consider issues

raised by Mr. Davis' clients

regarding condo rules (.5);

Call with Mr. Romero

regarding case issues and

negotiation regarding Mr.

Davis' clients (.5); call with

Mr. Davis to discuss

settlement with his client

PSO Investments (.3);

review entered Second

Interim Cash Collateral

MR $180.00 0.50 $90.00

November PDR $695.00 0.30 $208.50 4,

2019

$495.00 7.00 $3,465.00 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 105 of 144
Order; send to Mr. Romero

(.2); consider open to do

items for bankruptcy case

(.5); review and consider

email from Mr. Romero

regarding responses to Mr.

Davis (.2); review and

respond to inquiry regarding

payment to specific vendor

(.2); call with Mr. Zaron

regarding Beachamp issues

and proposed discovery (.2);

review and respond to email

from Mr. Feurstein

regarding Beauchamp

discovery request; call with

Mr. Feurstein regarding

same (.4); review and

respond to email regarding

budget item for security

personnel (.2); review and

analyze potential HMA from

prospective manager; draft

emails regarding same (3.2);

review and consider email

from Mr. Romero regarding

PSO Investment issue (.4);

review draft consulting

agreement from Mr.

Romero; review emails

regarding same (.3); review

emails regarding status of

stalking horse purchase and

sale agreement (.1);

Review notice of hearing on

application to employ Udell

(.1). Review status of stay

relief motions filed by unit

owners and consider

potential resolutions (0.2).

Prepare for meeting re:

upcoming filings, deadlines

and hearings (0.3). Develop

strategy re: necessary

motions to approve

postpetition contracts,

motions relating to APA and

bidding procedures, plan and

disclosure statement,

necessity of liquidating

trustee and trustee (1.5).

Correspondence with Jairo

MM $350.00 3.10 $1,085.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 106 of 144
re: security company (0.1).

Review draft consulting

agreement for Jairo (0.3).

Correspondence with Jairo

re: changes to consulting

agreement, request for

additional letter agreements

for maintenance workers

(0.3). Review entered

second interim cash

collateral order (0.2).

Correspondence with Jerry

F. Re: APA(O.l).

LRT Respond to email re stay $255.00 2.80 $714.00

relief and requests (.1).

Review certain contracts and

email re same (.4). Continue

work on adding claim info

on contract/lease

spreadsheet (2.3).

Review draft independant

contractor agreement with

Jairo Romero

Review draft consulting

agreement (.4); draft

independent contractor

agreement; draft and

respond to emails regarding

same (1.7); review emails

regarding retention of Mr.

Udell as special counsel (.1);

review and respond to email

from Mr. Romero regarding

his independent contractor

agreement; call with Mr.

Romero regarding same (.5);

Update contracts/leases

spreadsheet to include proof

of claims amounts,

review Second Interim

Order Granting Expedited

Motion of the Debtor for

Entry of Interim and Final

Orders (I) Authorizing the

Debtor to (A) Use Cash

Collateral Nunc Pro Tunc to

PDR $695.00 0.30 $208.50 November 5,

2019

$495.00 2.70 $1,336.50 JCM

$255.00 0.40 $102.00 LRT

MR $180.00 0.20 $36.00

September 19, 2019, (B)

Obtain Secured Postpetition

Financing from 777 North

Ocean Drive, LLC, (II)

Granting Adequate

Protection, and (III)

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 107 of 144
Scheduling Final Hearing

[ECF No. 129]; calendar

dates and deadlines; review

local rules for proper service

list for certificate of service

of same

Review and respond to

email from Mr. Romero

regarding Johnson Controls

(.3); review and respond to

email from Mr. Romero

regarding dumpster service

inquiry (.2); review and

respond to inquiry regarding

payment of pest control

vendor (.1); review emails

from Mr. Chu and Ms. Read

regarding owner relations

notification; consider

response (.3); review emails

regarding hotel operations

issues (.2); review and

respond to emails regarding

status of orders on

maintaining insurance

policies and customer

programs (.3); consider

outstanding action items for

motions to be filed and plan

and and disclosure statement

(and related motions) timing

issues (.6);

Review issues re: Johnson

November $495.00 2.00 $990.00 6, JCM

2019

MM $350.00 1.20 $420.00

controls (0.2).

Correspondence with Jairo

re: application to employ

(0.2). Emails with Johanna

A. Re: application to employ

Jairo (0.2). Review updated

docket entries following

judicial reassignment (0.2).

Revise Jairo application and

order (0.2). Review and

approve application for

filing (0.2).

$255.00 0.90 $229.50 LRT Follow up on orders

submitted 10/3 that have not

been docketed (.1). Work on

contracts/leases spreadsheet

(.8).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 108 of 144
Prepare motion to approve $245.00 1.10 $269.50

pest control agreement and

order granting same.

Draft email to Mr. Romero

and Mr. Bensusan regarding

retention of broker (.2); draft

email to Mr. Feurstein

requesting title report (.1);

review title report sent by

Mr. Feurstein (.2); prepare

for and participate in call

with Mr. Feurstein and MCR

PH

November $495.00 1.90 $940.50 7, JCM

2019

representatives regarding

hotel operations; review

draft MCR HMA(.7);

review and respond to email

from Mr. White regarding

management issues (.2);draft

email to Mr. Romero

regarding review of HMA;

review response (.2); review

and consider emails from

Mr. Romero and Ms.

Tannenbaum regarding

prepetition sales contracts

(.2); review email regarding

DIP Reports (.1).

MM Review $350.00 0.90 $315.00 current status of

retaining broker (0.2).

Review current status of

locating new management

(0.2). Review notices of

hearing from court on

outstanding motions (0.2).

Review foreclosure

commitment for title issues

impacting plan (0.3).

Receipt ofNotice of Hearing

on Debtor's Motion To Pay

Prepetition Tourist

Development Tax [ECF No.

140]; update calendar;

review local rules for proper

service list for certificate of

MR $180.00 0.40 $72.00

service of same [.2]; receipt

of Order Granting Debtor's

Expedited Motion Pursuant

to Sections 105(A), 363(B),

and 503(B)(1) of the

Bankruptcy Code for

Authorization to Honor

Certain Prepetition

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 109 of 144
Customer Programs [ECF

No. 146] and Order

Granting Debtor's Expedited

Motion for Authorization to

(I) Continue Insurance

Programs and to (II) Pay All

Insurance Obligations [ECF

No. 147]; review local rules

for proper service lists for

certificate of service of same

[•2]

Continue work on draft $245.00 $147.00

motion to approve pest

elimination services

agreement. Draft order

granting same.

Draft email to Ms. Israel

regarding adequate

protection issues for United

Leasing; call with Ms. Israel

regarding same (.4); review

and respond to emails from

Mr. Romero regarding his

postpetition retention; call

with Mr. Romero regarding

same (.4).

Review numerous emails re

budget and organize files.

Review and respond to

email from Ms. Israel

regarding call to discuss

issues related to Plan

treatement of United

Leasing claim (.1); review

emails from Mr. Chu and

Ms. Read regarding request

for commission payment;

draft email to Mr. Romero

regarding same (.2); review

email from Ms. Weyland of

Itekz regarding statement of

account due (.1).

Draft email to Mr. Romero

regarding amount due to

United Leasing for Gym

equipment; review and

consider response; draft

email to Ms. Israel regarding

same (.4); review and

consider email from Mr.

Chu regarding recently

PH 0.60

$495.00 0.80 $396.00 November 8, JCM

2019

$255.00 0.70 $178.50 LRT

$495.00 0.40 $198.00 November 11, JCM

2019

$495.00 2.60 $1,287.00 November 12, JCM

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 110 of 144
discovered past due invoices

and how to pay; draft email

to Mr. Romero regarding

same (.4); revise and edit

draft stalking horse purchase

and sale agreement (1.8).

Review email re gym

financing payments and

reply to same.

Revise and edit draft

stalking horse purchase and

sale agreement; draft email

regarding same (1.9); review

email from Hilco regarding

interest in performing broker

services (.1); review and

respond to email from Mr.

Bensusan regarding

retention of counsel and

broker (.2); draft email to

Mr. Feurstein and Mr.

Battista regarding status of

case and request for call (.2);

review email describing

exclusivity deadlines (.1);

review invoices from Itekz

LRT $255.00 0.20 $51.00

November 13, JCM $495.00 2.70 $1,336.50

2019

(.2).

MR $180.00 0.10 $18.00 telephone conference with

Susan at Judge Cristol's

chambers re: final hearing

on ECF No. 97

JCM Draft email to Mr. Romero $495.00 0.50 $247.50

regarding status of budget

(.1); draft clarification of no

default email to Mr.

Feurstein; review response

November 14,

2019

(.4).

MR Receipt ofNotice of Hearing $180.00 $36.00

on Debtor's Expedited

Motion of the Debtor for

Entry of Interim and Final

Orders (I) Authorizing the

Debtor to (A) Use Cash

Collateral Nunc Pro Tunc to

0.20

September 19, 2019, (B)

Obtain Secured Postpetition

Financing from 777 North

Ocean Drive, LLC, (II)

Granting Adequate

Protection, and (III)

Scheduling Final Hearing

[ECF No. 154]; review local

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 111 of 144
rules for proper service list

for certificate of service;

update calendar

Review plan provisions and

determine open items for

fmalization (1.2); draft

email to Mr. Romero

regarding status of contract

with Johnson controls and

discussions with broker (.2);

consider postconfirmation

issues for liquidating trust;

draft email regarding same

(.3); review and respond to

email from Mr. Romero

regarding payments to Itekz

November 15, JCM $495.00 1.90 $940.50

2019

(.2).

JCM Review and respond to $495.00 0.40 $198.00

email from Mr. Romero with

attached invoices from Itekz

November 17,

2019

(.4).

JCM Review email regarding $495.00 0.20 $99.00

postpetition contracts of the

Debtor (.1); review email

from Ms. Weyland regarding

past due invoices of Itekz

November 18,

2019

(.1).

MM Review status of 6 month $350.00 4.10 $1,435.00

budget and DIP report prior

to upcoming hearing (0.2).

Call with Jairo re: status of

pending items (0.2).

Continue drafting and

revising bid procedures

motion (1.1). Draft bid

procedures order (1.1). Draft

exhibit 1 to bid procedures

order (bidding procedures)

(0.8). Draft exhibit 2 to bid

procedures motion (cure

notice) (0.4). Draft exhibit 3

to bid procedures motion

(sale notice) (0.3).

Exchange emails re post

petition contracts requiring

Court approval.

Draft email to Mr. Romero

$255.00 0.20 $51.00 LRT

$495.00 1.70 $841.50 November 19, JCM

and Mr. Bensusan regarding

information and deliverable

requests (.3); review IRS

POC 23 (.1); review email

from Ms. Weyland regarding

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 112 of 144
Itekz invoices; draft email to

Mr. Romero regarding same

(.2); review budget draft

from Mr. Romero; draft

email in response (.3);

review draft budget; draft

email regarding same (.3);

draft email regarding

procedures for introducing

new budget to court; review

responses (.3); review and

respond to email from Ms.

Read regarding hearings on

11/26 (.2).

Call with Jairo re: budget $350.00 1.20 $420.00

(0.2). Review what is set for

all upcoming scheduled

hearings (0.2). Address

court's failure to set hearing

on application to employ

Jairo (0.2). Begin drafting

hearing script for 11/26

MM

hearing (0.6).

Review updated cash $695.00 0.60 $417.00

collateral budget and

procedural issues

Draft email regarding budget

review and circulation (.2);

review and respond to email

from Ms. Read regarding

hearing on cash collateral

order (.1); review email

from Ms. Weyland regarding

past due payments to Itekz;

draft email to Mr. Romero

November 20, PDR

2019

$495.00 1.40 $693.00 JCM

regarding same (.2); review

and respond to email from

Ms. Israel regarding plan

(.1); draft email regarding

adequate protection

payments for United Leasing

and budget inclusion and

review response (.2); review

and analyze draft budget

(.6).

Review budget from Jairo $350.00 2.60 $910.00

and compare with prior

budget to ensure consistency

(0.3). Correspondence with

Jairo re: budget items (0.3).

Emails to secured lender,

Beauchamp, United Leasing

MM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 113 of 144
and UST re: 6 month budget

(0.2). Continue drafting

hearing outline for 11/26

hearing (1.8).

Prepare notice of filing six

month budget (.1). Work on

leases/contracts spreadsheet

LRT $255.00 1.30 $331.50

(1.2).

Review and respond to $495.00 7.60 $3,762.00

emails regarding 6 month

budget (.5); draft email to

and review response from

Mr. Feurstein regarding

payment of FPL deposits

(.2); review and respond to

email regarding interest in

bidding and document

request (.2); review motion

to approve pest elimination

services contract; draft email

regarding same (.3); review

and respond to email

regarding Itekz debt (.2);

review drafts of Oct. DIP

November 2 1 , JCM

2019

Report and emails

discussing edits and

clarifications (.5); review

revised 6 month budget (.3);

consider issue of budget

shortfall and funding

requirements; review and

respond to emails regarding

same (3.6); calls with Mr.

Romero regarding Itekz and

budget issues (.4); draft

email to Ms. Weyland

regarding Itekz debt (.2);

call with Mr. Feurstein

regarding budget funding

issues (.3); consider issue of

release of funds held by

Greenberg Traurig (.4); draft

email to Mr. Feurstein with

invoices from Itekz and

description of debt (.3);

review email from Mr. Chu

regarding bonus payment

request (.2);

Correspondence with

Evolution's counsel re:

MM $350.00 2.90 $1,015.00

budget (0.2).

Correspondence with Jairo

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 114 of 144
re: budget (0.2). Additional

revisions to hearing outline

for 11/26 (0.5). Review

updated budget and consider

significantly increased

shortfalls and issue with

critical vendors (0.5).

Correspondence with Jairo

re: updated budget (0.2).

Call with Melissa Groisman

re: unit owner issues (0.2).

Call with Ryan Tables re:

unit owner issues (0.2). Call

with Jairo re: shortfall issues

(0.2). Consider potential

ways to cut budget shortfalls

(0.2). Consider strategy re:

addressing budget shortfalls

with Secured Lender (0.5).

Review budget emails (.3).

Email re FPL post petition

deposits (.1).

Compile documents re:

Motion to Use Cash

Collateral and Motion for

$255.00 0.40 $102.00 LRT

MR $180.00 0.70 $126.00

Payment of Taxes and

prepare JCM for hearing on

11-26-19 [.3]; Compile

exhibits; revise and finalize

Motion to Approve Pest

Elimination Services

Agreement; email Susan

(Judicial Assistant)

regarding expedited hearing

on same [.4]

JCM Draft email to Mr. Romero $495.00 4.50 $2,227.50 November 22,

and Mr. Bensusan regarding

attendance at hearing (.1);

draft emails to and respond

to emails from Ms. Weyland

regarding call to discuss

2019

Itekz debt (.3); call with Ms.

Weyland and Mr. Rivas

regarding Itez debt (.4);

review email from Mr.

Feurstein regarding Itekz;

draft email to Mr. Romero

regarding same (.2);

consider budget shortfall

issue; call with Mr. Romero

regarding same (2.5); review

and respond to email from

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 115 of 144
Mr. Zaron regarding cash

collateral order language

(.2); draft email to Mr.

Romero regarding status of

Itekz negotiations (.1);

review email from Ms.

Groisman regarding unit

owner inquiries; review

emails regarding same (.3);

review and refvise draft of

final cash collateral order

(.4);

MM Consider $350.00 $735.00 necessary

preparation ahead of 1 1/26

hearing (0.6). Review

2.10

updated budget (0.2).

Circulate updated budget to

Evolution, United Leasing,

Beauchamp and UST (0.4).

Draft final cash collateral

order (0.9).

MR Revise $180.00 0.20 $36.00 and finalize Notice

of Filing Sixth Month

Budget

PDR Review revised final order

on use of cash collateral

$695.00 0.40 $278.00 November 25,

2019

Revise $495.00 7.90 $3,910.50 and edit draft final

cash collateral order (1.2);

draft email to and review

response from Mr. Romero

regarding edits to final cash

collateral order (.3); review

and respond to email from

Mr. Feurstein regarding total

funding commitment (.2);

review and respond to email

from Lenny's Painting

representative regarding

document request (.2);

review and respond to

emails from Mr. Battista

regarding edits to final cash

collateral order; review and

consider edits (.4); draft

email to Mr. Romero

regarding attendance at

hearing (.1); review and

respond to emails from Mr.

Romero regarding funding

request (.4); draft email to

Mr. Feurstein with funding

request from Debtor (.2);

JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 116 of 144
review email regarding

commission request for

insider; draft email to Mr.

Bensusan and Mr. Romero

regarding same (.2); revise

and edit draft final cash

collateral order; draft and

respond to emails regarding

same (.8); review email

from Mr. Romero regarding

Johnson Controls contract

issues; review attachments

(.3); prepare for hearing on

11/26 (3.6).

MM Updated hearing outline for $350.00 1.60 $560.00

11/26 hearing (0.4). Review

revisions to cash collateral

order from secured lender

(0.3). Review motions set

for hearing on 1 1/26 in

preparation for same (0.9).

Read emails re budget and

pending items. Proposed

final order on cash

collateral. Prepare notice of

filing. Review updated title

report.

Receipt of Notice of Hearing

on Motion for Approval of

Pest Elimination Services

$255.00 1.00 $255.00 LRT

MR $180.00 0.20 $36.00

Agreement [ECF No. 160];

review local rules for proper

service list for certificate of

service of same

Review issues re: "challenge

period" for cash collateral

order

Review and respond to

email from Mr. Feurstein

regarding new default dates

(.2); review and respond to

email from Mr. Feurstein

regarding need for debtor to

use funds prior to funding

from secured lender

(.3);review email from Mr.

Chu regarding unit owner

payments (.2); review and

respond to emails from Mr.

Battista and Mr. Zaron

regarding edits to final cash

collateral order (.3); review

$695.00 0.30 $208.50 November 26, PDR

2019

$495.00 9.30 $4,603.50 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 117 of 144
and respond to emails from

Mr. Feurstein regarding use

of cash collateral and terms

of financing (.2); review and

respond to request for draft

of bidding procedures

motion (.2); call with UST

regarding issues with Mr.

Romero application;

consider how to address

(1.6); prepare for and attend

hearing on 11/26 (5.5);

review emails between Mr.

Andron and Mr. Chu

regarding bed tax payment

to county (.3); review and

respond to emails regarding

upload of final cash

collateral order (.2); call

with Mr. Feurstein regarding

hearing on 1 1/26 and

post-hearing issues (.3);

Review additional revisions

to proposed final cash

collateral order (0.2).

Update hearing outline to

include substantial revisions

MM $350.00 4.60 $1,610.00

with regard to cash collateral

and financing (0.5).

Additional preparation for

hearing including review of

docket and outstanding

motions (0.5). Attend

hearing on cash collateral

motion, motion to pay taxes,

application to employ Udell

and application to employ

Jairo (3.0). Call with

Melissa Groisman re: unit

owner reconcilitation issues

(0.2). Correspondence with

Jairo re: reconciliations and

ledgers to unit owners (0.2).

LRT Calculate plan track

deadlines and email Jim re

$255.00 1.70 $433.50

same (.3). Review and

update pending items memo

(.7). Work on

contracts/leases spreadsheet

(.7).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 118 of 144
JCM Draft and respond to emaisl $495.00 $940.50

regarding orders that need to

be uploaded as a result of

November 27, 1.90

2019

hearing on 11/26 (.4); call

with Ms. Armengol

regarding Romero

application (.3); review and

respond to emails regarding

funding requests from

Debtor (.2); review and

respond to emails regarding

payments authorized by

second interim cash

collateral order v. payments

needed to be paid under the

final cash collateral order

(.3); review draft letter to

unit owners; review and

respond to emails regarding

same (.7);

Revise Order re Tourist

Taxes.

LRT $255.00 0.10 $25.50

$495.00 0.10 $49.50 JCM Review email regarding unit

owner notices.

December 2,

2019

Correspondence with $350.00 0.80 $280.00

secured lender re: bid

procedures exhibits (0.2).

Correspondence with

Melissa Groisman re:

notices to unit owners (0.2).

Email to Jairo re: notice

MM

address for unit owner (0.2).

Call with Rodrigo da Silva

re: unit owner objections

(0.2).

$495.00 6.50 $3,217.50 JCM Draft email regarding need

to draft proposed order

denying motion to lift stay

(.1); draft email to Mr.

Romero and Mr. Bensusan

December 3,

2019

regarding status of

discussions with prospective

broker (.1); review budget

line items and financing

needs in short and long term

(1.2); review order

authorizing payment of

tourist development tax;

review and respond to

emails from Mr. Chu and

Mr. Romero regarding same

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 119 of 144
(.2); call with Mr. Davis

regarding motion to lift stay;

draft and respond to emails

regarding same (.4); review

and respond to emails from

Ms. Israel regarding the final

cash collatateral order (.3);

review and respond to email

from Ms. Armengol

regarding UST position on

motions before the court on

12/4 (.2); review email and

voicemail re: prepetition

counsel for Debtor and stay

relief issues (.2); prepare for

hearing on 12/4 (3.8).

MM Review $350.00 $175.00 executed order 0.50

authorizing payment of

prepetition tourist

development taxes (0.1).

Develop strategy re: motions

for stay relief given newly

filed adversary (0.2).

Review status, upcoming

deadlines and outstanding

tasks (0.2).

MR Compile $180.00 0.50 $90.00 documents and

prepare JCM for hearing on

12-4-19

$495.00 5.30 $2,623.50 December 4, JCM Draft email to Mr. Romero

and Mr. Bensusan regarding

hearing today and matters to

2019

be heard (.2); call with Ms.

Armengol regarding calls

and correspondence from

counsel for Costa Monrovia

(.4); draft email and review

response from Mr. Romero

regarding same (.2); review

and respond to email from

Mr. Romero regarding

funding request pursuant to

second interim cash

collateral order; draft email

to Mr. Feurstein regarding

same (.2); draft email to Mr.

Udell with the order

approving his retention (.1);

review email and draft order

denying motion for stay

relief (.3); draft email to Mr.

Feurstein confirming no

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 120 of 144
default with respect to the

Plan filing date (.1); prepare

for and attend hearing on

various motions (3.4);

review and consider email

from Mr. Romero regarding

friends and family renter

issue (.3); review email

regarding meeting with

proopective broker (.1);

Review information from

Jairo re: notices to unit

owners (0.1).

Correspondence with

Melissa Groisman re:

notices and payments to unit

owners (0.2). Draft proposed

order denying Costa 402's

motion for stay relief (2. 1).

Review final cash collateral

order and circulate (0.2).

Review issues raised by

Debtor re: unit owner's

MM $350.00 2.70 $945.00

friends and family program

(0.1).

Research regarding funds $495.00 4.00 $1,980.00

held in escrow by Stewart

Title (3.8); review and

respond to email from Mr.

Romero regarding potential

broker (.1); review and

respond to emails with Mr.

Romero regarding funding

requests (.1);

Numerous emails re

December 5, JCM

2019

$255.00 0.40 $102.00 LRT

indemnification contract

with STG.

MR Review Final Order $180.00 0.20 $36.00

Granting Expedited Motion

of the Debtor for Entry of

Interim and

Final Orders (I) Authorizing

the Debtor to (A) Use Cash

Collateral Nunc Pro Tunc to

September 19, 2019, (B)

Obtain Secured Postpetition

Financing from 777 North

Ocean Drive, LLC, and (ii)

Granting Adequate

Protection [ECF No. 169];

calculate and calendar all

dates and deadlines; review

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 121 of 144
local rules for proper service

list for certificate of service

$495.00 2.40 $1,188.00 JCM Review and analyze condo

declaration and rules and

December 6,

2019

regulation promulagated by

Debtor on July 12, 2019

(1.4); revise and edit draft

order denying motion to lift

stay; draft email regarding

same (.7); review and

respond to email and

proposed contract regarding

formula 1 racing (.3).

Revise and edit draft Order $495.00 1.50 $742.50 December 9, JCM

denying motion to lift stay;

draft email regarding same

(.5); review and respond to

various emails regarding

rules for competing orders

and submission to court (.3);

review and consider

purported notice of

termination ofrental

management agreement and

accompanying email; draft

email regarding same (.3);

review and consider email

from Mr. Romero regarding

insurance coverage issues;

draft email to Mr. Feurstein

regarding same (.3); review

and respond to email from

Mr. Romero regarding

approval of pest control

services contract (.1).

Review emails re contract.

2019

$255.00 0.10 $25.50 LRT

$180.00 0.20 $36.00 IH Review local rules for

proper service list for

certificate of service of

Order Authorizing Debtor's

Motion for Approval of Pest

Elimination Services

Agreement.

JCM Research regarding funds

held by Greenberg Traurig

for Stewart Title; draft email

to Mr. Sharpe regarding

same (3.4); review and

respond to email from Mr.

Sharpe regarding escrowed

$495.00 4.50 $2,227.50 December 10,

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 122 of 144
funds (.3); research caselaw

regarding executory nature

of indemnity agreements

(.6); review and respond to

email from Mr. Romero

regarding financing request

(.1); draft email to Mr.

Feurstein with documents

provided by insurance

broker (.1).

LRT Exchange emails and $255.00 0.20 $51.00

discuss CHPO condo assn.

JCM Draft email to Mr. Feurstein $495.00 3.10 $1,534.50

regarding Mr. Romero's

request for input regarding

timing of funding for

Debtor's funding request

(.1); research regarding

release of funds held in

escrow for Stewart Title

(2.1); review and respond to

email from Mr. Flail

December 1 1 , 2019

regarding escrowed funds

for Stewart Title (.4); review

and respond to email

regarding renewal of

insurance issue; consider

how to resolve; draft email

to Mr. Feurstein regarding

same (.4); review email

regarding need to amend

schedules (.1).

$495.00 0.50 $247.50 JCM Draft and respond to email

regarding confirmation of

non-default status under

Final Cash Collateral Order

regarding date to file Plan

and Disclosure Statement

(.2); draft email to Mr.

Romero regarding status of

discussions with prospective

broker (.1)1 draft and review

response to email to Mr.

Romero regarding status of

broker negotiations (.2).

MM Review status and strategy

for completing bidding

procedures motion and order

(0.2). Consider strategy re:

open insurance issues (0.2).

Participate in call with

December 12,

2019

$350.00 0.70 $245.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 123 of 144
Kassower re: special counsel

(0.3).

Draft email to Mr. Hall $495.00 5.20 $2,574.00

regarding need to discuss

Debtor funds held in escrow

by Stewart Title (.1); draft

email to Mr. Feurstein

regarding confirmation of no

default pursuant to final

cash collateral order; review

and respond to response

from Mr. Feurstein (.2);

review email and

attachments from Mr.

Romero regarding insurance

renewal issue; call with Mr.

Romero regarding same (.6);

review and respond to email

from Ms. Read regarding

request to discuss hotel

operation issues (.2); call

with Mr. Hall of Stewart

Title regarding escrow

issues; draft email to Mr.

Feurstein regarding same

(.6); review email from Mr.

Davis regarding use of

rooms during holidays; draft

email to Mr. Romero

regarding same (.1); review

and consider email from Ms.

Israel inquring about

payment of adequate

protection; draft email to

Mr. Romero regarding same

(.1); respond to email from

Ms. Israel regarding budget

needed as attachment to

final cash collateral order

(.2); research regarding

executory nature of

indemnity contracts (3.1).

Review email from Mr.

Battista regarding Stewart

Title issue.

Review emails from Mr.

Romero and Ms. Israel

regarding status of adequate

protection payments to

United Leasing; draft emails

to Ms. Israel regarding same

(.4); review and respond to

December 13, JCM

2019

$495.00 0.10 $49.50 December 15, JCM

2019

$495.00 1.70 $841.50 December 16, JCM

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 124 of 144
emails regarding budget

missing from Final Cash

Collateral Order (.2); review

and respond to emails

regarding insurance

coverage and downpayment

for financing (.4); review

email from Mr. Romero

regarding status of 6 month

funding request (.1); call

with Mr. Romero regarding

insurance funding needs and

deadlines (.4); review email

from Mr. Romero regarding

specific funding needs (.2).

telephone conference with

Judge Cristofs chambers

regarding cash collateral

order; prepare and finalize

Amended Cash Collateral

Order as to budget

Review email from Mr.

Feurstein regarding

insurance financing (.1);

review and respond to email

regarding exclusivity

deadline (.1); review emails

regarding insurance

premium financing and

analyze orders needed (.5);

review and respond to email

regarding Itekz financing

MR $180.00 0.30 $54.00

$495.00 0.90 $445.50 December 17, JCM

2019

(.2).

MM Review $350.00 0.50 $175.00 verified statement

and claims filed by multiple

creditors represented by

Tripp Scott (0.2). Review

and prioritize all upcoming

deadlines and necessary

December 18,

2019

tasks (0.3).

$255.00 0.20 $51.00 LRT Review email and insurance

docs. Email client re same.

MR Review Amended Final $180.00 0.30 $54.00

Order Granting Expedited

Motion of the Debtor for

Entry of Interim and Final

Orders (I) Authorizing the

Debtor to (A) Use Cash

Collateral Nunc Pro Tunc to

September 19, 2019, (B)

Obtain Secured Postpetition

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 125 of 144
Financing from 777 North

Ocean Drive, LLC, (II)

Granting Adequate

Protection, and (III)

Scheduling Final Hearing

[ECF No. 189]; calendar all

dates/deadlines; review local

rules for proper service list

for certificate of service of

same MM Review bidding procedures

motion to be consistent with

revised bidding procedures

order (2.3). Revise bidding

procedures order (0.2)

Correspondence with Jerry

and Paul re: revised bidding

procedures motion (0.1).

Correspondence with

lender's counsel re:

confirmation of no default

December $350.00 5.10 $1,785.00 19,

2019

(0.2). Review significant

revisions to purchase and

sale agreement from secured

lender (1.6).

Correspondence with Jairo

re: status of broker

engagement, commercial

tenants (0.2). Revise motion

to pay USPF insurance (0.3).

Revise USPF insurance

order (0.2).

PH Review forms from USPF. $245.00 1.20 $294.00

Draft motion to approve

premium finance agreement

and order granting same.

Discuss issues re same with

Meaghan Murphy.

$495.00 0.40 $198.00 JCM Review emails regarding

status of JLL negotiations

December 27,

2019

(.2); call with Ms. Murphy

regarding status of JLL

negotiations and related

business operation issues

(.2).

MM Correspondence with $350.00 0.40 $140.00 Jairo

re: broker (0.1).

Correspondence with Jerry

re: confirmation of no

default, status of PSA and

related items (0.3).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 126 of 144
Consider issues re: delay in $350.00 $70.00

retaining broker and

correspondence with Jerry

re: same (0.2).

Review letter from Costa

MM 0.20

December $495.00 0.40 $198.00 30, JCM

2019 402 to Judge Bidwell;

review emails between Mr.

Kassower and Mr. Davis

regarding same (.4).

Email Jairo re deadline to $260.00 0.10 $26.00 January 2, 2020 LRT

assume/reject leases for

non-residential real property.

JCM Call with Ms. Fgigeles $495.00 1.10 $544.50 January 3, 2020

regarding PSA that was not

closed prior to bankruptcy

(.2); review email

correspondence between Mr.

Udell and Mr. Romero

regarding tax appeal issues

(.3); review draft HMA (.6).

Review and respond to $495.00 0.20 $99.00

email from Mr. Romero

January 6, 2020 JCM

regarding status of

discussions with potential

broker (.2).

Review email regarding $495.00 0.10 $49.50

information needed for

January 7, 2020 JCM

amending schedules. (.1).

Draft and respond to emails

with Mr. Romero regarding

update regarding broker (.2)

Review re-notices of hearing

on pending matters filed by

court (0.2). Correspondence

with Jerry re: confirmation

$495.00 0.20 $99.00 January 10, 2020 JCM

MM $365.00 3.80 $1,387.00

of no default (0.3). Legal

research re: standard on

extension of time to file 523

complaint (0.6). Legal

research re: exception to

discharge for actually

fraudulent transfers (0.6).

Legal research re: exception

to discharge for

constructively fraudulent

transfers (0.4). Draft

response in opposition to

Costa Investors motion to

extend time to file 523

complaint (1.7).

Receipt of Re-Notice of

Hearing on Motion for

MR $180.00 0.20 $36.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 127 of 144
Authorization to (I) Enter

Into Insurance Premium

Financing Agreement and

(II) Pay All Insurance

Obligations [ECF 214];

update calendar; review

local rules for proper service

list for certificate of service

of DE 214

Review and respond to $495.00 0.80 $396.00

email regarding Ms. Terry

action against Liberty

Grande; call with Mr.

Romero regarding same (.4);

review email from Ms.

Feigeles regarding

alternative assurances and

escrow agreement; draft

email to Mr. Romero

regarding same (.3); review

email from Ms. Barzilay

regarding interest in

purchasing property (.1).

Revise and finalize response

to Costa Investors motion to

compel 2004 examination

(0.3). Revise and finalize

response to Costa Investors

motion to extend time to file

523 complaint (0.2). Review

correspondence concerning

tax appeal status (0.2).

Review surety and escrow

documents; draft email to

Ms. Feigeles regarding

same. (.7); review email

from Ms. Israel regarding

alleged nonpayment of

monthly payment for gym

equipment (.2); draft email

to Mr. Romero regarding

same (.1); draft email to Ms.

Israel regarding payment

sent (.1); draft email to Ms.

Israel request invoice from

United Leasing; review

response from Ms. Israel

January 13, 2020 JCM

MM $365.00 0.70 $255.50

$495.00 1.30 $643.50 January 14, 2020 JCM

(.2).

Compile documents and $180.00 0.20 $36.00

prepare JCM for hearing on

1-15-20 re: Motion to Enter

MR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 128 of 144
Financing Agreement and

Pay Insurance

Review email from Ms.

Feigeles regarding surety

bond (.1); draft email to Mr.

Romero regarding Surety

Bond (.1); draft email to Mr.

Romero with invoice from

United Leasing (.1).

Read and reply to email re

settling tax issues.

Review insurance financing

motion

January 15, 2020 JCM $495.00 0.30 $148.50

LRT $260.00 0.20 $52.00

January 16, 2020 PDR $695.00 0.30 $208.50

Review chart of information $495.00 0.10 $49.50

for amendments to

JCM

schedules (.1).

Draft email to Mr. Romero $495.00 0.20 $99.00 January 17, 2020 JCM

regarding surety bond and

review response (.1); review

emails regarding payment of

insurance premium and

threat to cancel (.1).

Review email from Mr.

Romero including

TripAdvisor review;

consider and respond.

Review MOR for December

JCM $495.00 0.20 $99.00 January 20, 2020

JCM $495.00 0.20 $99.00 January 21, 2020

(.2).

Draft email to Mr. Romero $495.00 2.00 $990.00

regarding broker (.1); review

email from Ms. Feigeles,

draft email to Mr. Romero

January 22, 2020 JCM

regarding surety bond (.2);

review escrow agreement

and related surety bond

documents provided by Mr.

Romero (.7); review and

respond to emails regarding

UST fees and payment (.4);

draft email to Mr. Romero

regarding collections

counsel (.1); call with Mr.

Rumpel of JLL regarding

market and sale process for

Debtor's assets (.5).

MM Review JLL qualifications $365.00 0.50 $182.50

packet (0.5).

Receipt of Order Granting $180.00 0.10 $18.00

Debtor's Motion For

Authorization To (I) Enter

MR

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 129 of 144
Into Insurance Premium

Financing Agreement And

(II) Pay All Insurance

Obligations [ECF No. 223];

review order and local rules

for proper service list for

Certificate of Service of DE

223

Review and respond to $495.00 1.00 $495.00

email from Ms. Feigeles

regarding surety bond (.1);

draft email to Mr. Romero

regarding same (.1); review

surety bond information

received from Mr. Romero;

forward to Ms. Feigeles (.2);

review and consider email

from Mr. Romero regarding

various issues to discuss

regarding operations; call

with Mr. Romero regarding

same (.6).

Exchange emails with Jairo

re trademark.

January 24, 2020 JCM

LRT $260.00 0.10 $26.00

Review and respond to $495.00 1.90 $940.50

email from Mr. Shelomith

regarding his client's

prepetition judgment against

the Debtor (.2); review state

court pleadings, proof of

claim and correspondence

from Mr. Shelomith

regarding creditor Betje

Investments; draft email to

Mr. Romero regarding same

(.8); review, consider and

respond to email

memorandum from Mr.

Kassower regarding

recommendation for

collection of delinquent

shared facilities dues; draft

email to Mr. Romero

regarding same (.5); review

email string from Mr.

Romero detailing unit owner

abuses and potential

remedies; respond to same

(.1); call with Mr. Kassower

regarding potential

January 27, 2020 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 130 of 144
expansion of retention and

related issues (.4);

Review correspondence re:

potential litigation targets,

retention of collections

attorney (0.20).

Review accounting of

revenue for Unit #N222,

draft email to Mr. Shelomith

regarding same (.3); draft

email to Mr. Feurstein

regarding proposal from Mr.

Kassower regarding

collections (.1); call with

Mr. Romero regarding

dispute with Airstron,

review and analyze contract

between Debtor and

Airstron; draft email

memorandum regarding

defaults and remedies and

send to Mr. Romero (.7);

Exchange emails re Airstron

MM $365.00 0.20 $73.00

January 28, 2020 JCM $495.00 1.10 $544.50

LRT $260.00 0.20 $52.00

(.2).

JCM Review and consider email $495.00 $247.50

from Ms. Read regarding

Evolution Management's

recommendation to spend

additional funds on specific

marketing; draft email to

Mr. Romero regarding

availability of funds and

response to other substantive

matters in email (.5).

JCM Review email from Mr.

January 29, 2020 0.50

January 3 1 , 2020 $495.00 0.20 $99.00

Romero regarding additional

marketing costs and budget

shortfall (.2).

Totals 472.80 $216,307.50

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 131 of 144
MELAND RUSSIN & BUDWICK

PROFESSIONAL ASSOCIATION

3200 SOUTHEAST FINANCIAL CENTER

200 SOUTH BISCAYNE BOULEVARD

MIAMI, FLORIDA 33131

TELEPHONE (305) 358-6363 Costa Hollywood Property Owner, LLC FACSIMILE (305) 358-1221

FID# 65-0340687

February 26, 2020

c/o Moses Bensusan

20 1 N Ocean Drive

Hollywood, FL 33019

Attention:

Matter #:

Invoice #:

5589-9

69841

RE: Costa Hollywood Property Owner - CI 1 BKC (Litigation)

DATE LAWYER DESCRIPTION RATE HOURS FEE

Review Motion to lift $495.00 $247.50

automatic stay; draft email

recommending response

(.2); review and respond to

emails regarding same (.2);

draft email to Mr. Romero

regarding same (.1).

Review filed motion for

September 27, 0.50

2019

JCM

MM $350.00 0.20 $70.00

relief from stay (0.1).

Correspondence with state

court counsel re: stay relief

motion (0.1).

Review results of hearings

and follow up issues (.3);

Review motions for stay

October 2, 2019 PDR $695.00 0.80 $556.00

relief filed by PSO and

Costa 402 and consider

response to same (.5)

Review UST Emergency

Motion to Dismiss and

consider responses to

arguments in motion

Review motion to dismiss

October 4, 2019 PDR $695.00 0.80 $556.00

MM $350.00 0.60 $210.00

filed by UST (0.3). Consider

motion to dismiss strategy

(0.2). Call with Tom

Lehman re: 363 sale (0.1).

Review joinders to UST $695.00 $139.00

motion (.2)

October 7, 2019 PDR 0.20

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 132 of 144
Review strategy re: motion $350.00 $105.00

to dismiss filed by UST

(0.2). Review joinder in

motion to dismiss filed by

Evolution (0.1).

TC from Victor Rones re:

motion to dismiss filed by

UST; Review joinders filed

by unit owners;

Review notice of hearing on

UST motion to dismiss or

convert (0.1). Review

upcoming deadlines (0.2).

Work on response to UST's

emergency motion to

dismiss (2.1). Review

background information re:

Costa Investors and alleged

security interest in property

(0.4). Review joinders filed

to motion to dismiss (0.1).

Review and revise draft

response to UST Motion to

Dismiss;

Review and revise further

MM 0.30

October 8, 2019 PDR $695.00 0.40 $278.00

MM $350.00 2.90 $1,015.00

October 10, 2019 PDR $695.00 1.30 $903.50

October 11, 2019 PDR $695.00 0.40 $278.00

revised draft of response to

UST MTD

Revise and edit response to $495.00 0.80 $396.00

UST Motion to Dismiss;

draft email regarding same

JCM

(.8).

Research rules re removal. $245.00 $98.00

Communications with Jim

Moon re same.

Review and analyze motions

for relief from stay; draft

email regarding same (.7);

Review revised response to

UST motion to dismiss

PH 0.40

October 14, 2019 JCM $495.00 0.70 $346.50

MM $350.00 0.40 $140.00

(0.2). Review order of

recusal and reassignment to

Judge Olson (0.1). Review

re-notices of hearing on

outstanding motions (0.1).

Legal research re: purposes

of automatic stay (0.4).

Legal research re: standard

for stay relief under

MM $350.00 4.90 $1,715.00

362(d)(1) (0.5). Legal

research re: standard for stay

relief under 362(d)(2) (0.5).

Draft response in opposition

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 133 of 144
to PSO Investment LLC's

motion for stay relief (1.5).

Draft response in opposition

to multiple unit owner's

motion for stay relief (1.4).

Correspondence with client

re: motions for stay relief

(0.2). Revise response in

opposition to multiple unit

owner's motion for stay

relief (0.4).

Consider issues raised by $695.00 0.30 $208.50

unit owners in stay relief

motion and response to

same in consideration of

October 15, 2019 PDR

Debtor's view of facts

Revise response to PSO's

motion for stay relief based

on additional information

from Jairo (0.5).

Review Secured Lender's

MM $350.00 0.50 $175.00

October 16, 2019 MM $350.00 0.90 $315.00

response to UST motion to

dismiss (0.2). Prepare for

hearing on motion to

dismiss and motions for stay

relief (0.7).

Attend hearing on UST $350.00 6.20 $2,170.00

motion to dismiss, motions

for stay relief, cash collateral

and financing motion, and

critical vendor motion.

October 17, 2019 MM

Consider efforts by Victor $695.00 0.40 $278.00

Rones, counsel for

non-creditor to take

discovery and potential for

November 7, PDR

2019

MPO

Review email regarding $495.00 0.20 $99.00

request from Mr. Rones for

deposition dates; consider

and respond.

Prepare for and participate

in call with Mr. Rones to

discuss standing to conduct

discovery.

Draft and transmit

settlement communication

to Mr. Davis (.6).

Review and consider

adversary complaint filed by

MaxCom Advisors; draft

emails regarding same (.6).

JCM

November 8, JCM $495.00 0.50 $247.50

2019

November 14, JCM $495.00 0.60 $297.00

2019

November 27, JCM $495.00 0.60 $297.00

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 134 of 144
Review adversary complaint $350.00 $105.00

filed by Maxcom.

December 2, MM 0.30

2019

Legal research re: relief $350.00 1.60 $560.00

from stay where case is in

December 5, MM

2019

pleadings stage (0.6). Legal

research re: relief from stay

when identical adversary is

pending (0.5). Revise draft

proposed order denying

Costa 402's motion for stay

relief (0.5).

Review pending state court $245.00 0.40 $98.00

cases re appellate matters.

PH

Review draft order on Stay $695.00 0.60 $417.00

Relief Motion

December 6, PDR

2019

MM Review and revise draft $350.00 0.20 $70.00

proposed order denying

Costa 402 stay relief (0.2).

December 9, PDR Review additional $695.00 0.40 $278.00

arguments for proposed

order on stay relief motion

Review additional revisions

to draft proposed order

denying Costa 402 motion

for relief from stay (0.3).

Review correspondence

from unit owner re:

2019

MM $350.00 0.70 $245.00

purported cancellation (0.2).

Correspondence with Jairo

re: unit owner stay violation

(0.2).

Review proposed order on $255.00 0.10 $25.50

stay relief.

LRT

Review order granting $350.00 0.10 $35.00

Pamela Terry relief from the

December 10, MM

2019

stay (0.1).

Review and analyze $495.00 1.20 $594.00

MaxCom complaint;

consider defense; draft email

regarding same (.7); draft

email regarding requirement

to provide competing order

to opposing counsel and

request for same (.1); review

draft order submitted by

Costa 402; draft email to

Mr. Romero and Mr.

December 11, JCM

2019

Bensusan regarding same

(.4).

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 135 of 144
MM Review deadlines in $350.00 $70.00

Maxcom adversary (0.2).

LRT Email deadlines re

MaxComm AR

0.20

$255.00 0.10 $25.50

MR Review docket for Maxcom $180.00 $18.00

AP; calendar dates/deadlines

JCM Review amended motion for

enforcement of settlement

agreement flied by Pamela

Terry in state court; consider

whether motion is consistent

with lift stay order issued by

bankruptcy court (.2).

JCM Review and analyze

MaxCom's Motion to

Expedite or Abstain (.3);

draft email regarding same

to Mr. Romero and Mr.

Bensusan and to Mr.

Feurstein and Mr. Battista

0.10

December 12, $495.00 0.20 $99.00

2019

December 13, $495.00 0.50 $247.50

2019

(.2).

MM Review and consider merits $350.00 0.50 $175.00

of motion for expedited

ruling or to abstain filed by

MaxCom (0.5).

MM Review strategy re: Stewart $350.00 0.90 $315.00

Title and funds held by

Greenberg (0.5). Review

docket and pleadings for

Burya matter re: Stewart

reference to pending motion

(0.4).

JCM Review Court's Order lifting $495.00 $297.00

automatic stay; draft email

to Mr. Bensusan and Mr.

December 14, 0.60

2019

Romero regarding same (.4);

draft email to Mr. Feurstein

regarding same; review

response (.2).

Review Court's order

granting Costa 402 Stay

Relief Motion and consider

litigation issues

Review notice of filing of

Order lifting stay filed in

state court by Costa 402 (.1);

review email and attachment

from Mr. Udell regarding

tax appeal hearing date and

request for information

December 16, PDR $695.00 0.40 $278.00

2019

JCM $495.00 0.40 $198.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 136 of 144
needed for hearing (.2);

review email from Mr.

Kassower regarding state

court case (.1);

Review notice of hearing on

MaxCom's motion for

expedited ruling on

adversary complaint (0.1).

Review issues for attention

in Jm's absence (0.2).

Review Memorandum in

MM $350.00 0.30 $105.00

December 17, JCM $495.00 0.30 $148.50

2019 Support filed by Costa 402

in state court case; draft

emails to Mr. Romero and

Mr. Kassower regarding

same (.3).

Briefreview of new

pleadings in Costa 402 state

court case and consider

status prior to retention of

special counsel (0.5).

Call with Michael Kassower

re: retention application,

expedited relief, general

litigation strategy (0.3).

Email to Michael re: follow

up items (0.1). Review

Kassower retention

application (0.2). Review

Kassower affidavit (0.2).

Call with Mike Kassower re:

possible automatic stay

violations (0.3). Email to

Steven Davis re: stay

violation (0.3). Email to

Alex Orlofsky re: stay

violation (0.4).

Review issues caused by

Costa 402 violation of 14

day finality rule

Correspondence with

Kassower re: stay of state

court litigation (0.2).

Review email from Mr.

Udell requesting

information for appeal (.1);

review motions filed by Mr.

Rones regarding 2004

examination and to extend

deadline to object to

dischargeability of a debt

MM $350.00 0.50 $175.00

December 18, MM $350.00 0.80 $280.00

2019

MM $350.00 1.00 $350.00

December 19, PDR $695.00 0.20 $139.00

2019

MM $350.00 0.20 $70.00

December 24, JCM $495.00 0.50 $247.50

2019

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 137 of 144
and email related to same

(.4).

Review motion to compel $350.00 $280.00

2004 examination filed by

Victor Rones (0.2). Review

motion to extend time to file

MM 0.80

dischargeability complaint

filed by Victor Rones (0.2).

Email to client re: filed

motions, strategy (0.3).

Review correspondence

from Rob Udell (0.1).

Review Motion to Compel $495.00 0.80 $396.00

2004 examination and

December 27, JCM

2019

motion to extend 523

deadline filed by Mr. Rones;

review emails regarding

same (.4); review lawsuit

filed in state court by

Visualscape; review emails

regarding same (.4).

Correspondence with

Kassower re: new lawsuit

(0.2). Review new lawsuit

filed against Debtor (0.2).

Review and approve

suggestion of bankruptcy for

new lawsuit (0.1).

Review new lawsuit and

email Jairo re amending

schedules. Update pending

items memo.

Review correspondence to

state court judge from

Steven Davis (0.2).

Review motion for status

conference and emails

related to same. (.2).

Review emails re state court

proceeding.

MM $350.00 0.50 $175.00

LRT $255.00 0.60 $153.00

December 30, MM $350.00 0.20 $70.00

2019

December 3 1 , JCM $495.00 0.20 $99.00

2019

LRT $255.00 0.10 $25.50

Review letter to Judge $495.00 0.80 $396.00

Bidwell and related email

from Mr. Kassower (.2); call

with Ms. Murphy regarding

inquiry regarding proposal

to MaxCom (.2); review

email from Mr. Kassower

regarding same (.2); review

proposed agreed order

regarding Maxcom

January 2, 2020 JCM

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 138 of 144
adversary and email from

Mr. Kassower (.2).

MM Review status and upcoming $365.00 $146.00

deadlines and associated

tasks (0.2). Correspondence

with Kassower re: litigation

issues (0.2).

JCM Review email

correspondence regarding

status conference on Costa

0.40

January 3, 2020 $495.00 0.20 $99.00

402 Motion for TRO (.2).

JCM Draft and respond to emails $495.00 1.90 $940.50

with Mr. Kassower

January 6, 2020

regarding hearings in

bankruptcy court on

adversary proceeding and

response deadline and state

court hearing (.4); prepare

for and call with Mr. Stern

and Mr. Kassower regarding

state court and adversary

proceeding issues. (1.2);

review response to motion

to expedite; draft email to

Mr. Kassower regarding

same (.3).

Review status of litigation

matters given upcoming

deadlines (0.2). Brief review

of proposed response to

MaxCom motion to expedite

adversary (0.2).

Draft and respond to emails

with Mr. Kassower inquring

about the MaxCom

adversary procedural posture

and upcoming hearing (.2);

review MaxCom settlement

offer and email from Mr.

Kassower regarding same

MM $365.00 0.40 $146.00

January 7, 2020 JCM $495.00 0.50 $247.50

(.3).

Confirm filing of response $365.00 0.50 $182.50

to motion in adversary (0.1).

Determine and prioritize

outstanding matters (0.4).

Review and respond to

email from Mr. Kassower

(.1); call with Mr. Kassower

regarding litigation against

Debtor in state court (.3).

MM

January 9, 2020 JCM $495.00 0.40 $198.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 139 of 144
Legal research re: whether $365.00 2.80 $1,022.00

Costa Investors is a "party in

interest" under Rule 2004

(0.4). Legal research re:

using Rule 2004 for an

improper purpose or scope

(0.3). Review background

documents concerning

claims by Costa Investors,

including state court

pleadings, appeal

documents, and proof of

claim (0.5). Draft response

in opposition to Costa

Investor's motion to compel

2004 examination (1.6).

Review and edit draft

response to Motion to

Compel 2004 Examination

(.9); review and edit draft

response to Motion to

Extend Exclusivity; research

regarding standard for

extension (.5).

Revise and edit response to

Motion to Extend

Exclusivity; draft and

respond to emails regarding

same (.6); review email

from Mr. Udell regarding

property tax appeal (.2);

review and comment on

draft proposed Order on

MaxCom Motion to abate

adversary; draft email

regarding same (.4); review

and analyze transcript of

hearing to determine Court's

intent with respect to

non-movant relief from the

automatic stay (.7).

Review and consider

counsel's proposed order

after hearing on motion to

expedite filed in adversary

(0.3). Review special

counsel correspondence re:

adversary hearing order

(0.2). Brief review of

adversary hearing transcript

to determine extent of

potential stay relief (0.3).

MM

January 10, 2020 JCM $495.00 1.40 $693.00

January 13, 2020 JCM $495.00 1.90 $940.50

MM $365.00 0.80 $292.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 140 of 144
MR Compile exhibits; revise and $180.00 $90.00

finalize Debtor's Response

in Opposition to Motion to

Compel 2004 Examination

0.50

[DE 197]

JCM Review and respond to $495.00 0.80 $396.00

email from Ms. Armengol

regarding UST position on

motions set for hearing on

January 14, 2020

1/15/20 (.1); review and

consider email memo from

Mr. Kassower and proposed

order on MaxCom Motion

to Expedite or Abstain; draft

email to Mr. Kassower

regarding same (.6); review

and respond to email from

Mr. Udell regarding

bankruptcy court approval of

any settlement Broward

County Property Appraiser

(.1).

Call with Mike Kassower re: $365.00 0.40 $146.00

adversary issues (0.2).

Consider strategy re:

requests by Orlofsky

concerning other unit

owners and turning over

association (0.2).

Compile documents and

prepare JCM for hearing on

1-15-20 regarding Motion to

Compel Deposition

Review results of hearings

MM

MR $180.00 0.20 $36.00

January 15, 2020 PDR $695.00 0.30 $208.50

on1) Motion to Extend Time to

File Section 523 Complaint

Objecting to

Dischargeability of a Debt

[DE 196]

2) Motion to Compel [DE

197]

3) Motion for Authorization

to (I) Enter Into Insurance

Premium Financing

Agreement and (II) Pay

Alllnsurance Obligations

[DE 198]

4). Debtor's Expedited

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 141 of 144
Motion to Extend

Exclusivity Period to file

Plan and Solicit Acceptances

[DE 211]

JCM Review, consider and $495.00 3.90 $1,930.50

respond to email from Mr.

Udell regarding status of tax

appeal negotiations and

process for approving

settlement in banrkutpcy

(.2); prepare for and attend

hearing on Burya Motions

and Debtor's Motions (3.6);

review email from Mr.

Davis regarding potential for

settlement; draft email to

Mr. Romero regarding same

(.1).

Prepare for hearing on $365.00 2.60 $949.00

pending motions (0.7).

Attend hearing on pending

motions (1.2). Revise order

granting motion to extend

exclusivity (0.1). Revise

order granting USPF motion

MM

(0.1). Draft order denying

Costa Investors motion to

extend time to object to

dischargeability (0.2). Draft

order denying Costa

Investors motion to compel

Debtor's 2004 exam (0.2).

Correspondence with Jairo

re: United Leasing (0.1).

January 16, 2020 JCM [DO NOT BILL] Attend $0.00 1.00 $0.00

Motion for Status

Conference Regarding

Litigation between Costa

402 and Debtor (1.0).

JCM Review draft Orders from $495.00 0.20 $99.00

hearing on Jan. 15; draft

email regarding same (.2).

Review complaint filed in

state court naming Debtor as

defendant; consider

response; draft email

regarding same (.3); review

and consider email from Mr.

Kassower regarding his firm

prosecuting collections

actions on unpaid

assessments (.1); review

January 17, 2020 JCM $495.00 0.60 $297.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 142 of 144
Order on MaxCom's Motion

to Expedite and email from

Mr. Kassower regarding

same (.2).

Review new lawsuit naming

Debtor as junior lienholder

(0.3). Review status of entry

of orders from 1/15 hearing

(0.2). Correspondence with

Jairo re: entered order (0.1).

Review correspondence

from special counsel re:

order entered in adversary,

possibility of settlement

negotiations.

Review mortgage

foreclosure litigation filed

naming debtor and reply to

email.

Review Julio Wajs

complaint; draft email to Mr.

Romero and Mr. Bensusan

MM $365.00 0.60 $219.00

January 20, 2020 MM $365.00 0.10 $36.50

January 21, 2020 LRT $260.00 0.10 $26.00

January 22, 2020 JCM $495.00 0.30 $148.50

regarding same.

Review and approve filing

of suggestion of bankruptcy

in newly filed state court

foreclosure matter (0.1).

Review Complaint re: Wajs

MM $365.00 0.10 $36.50

MR $180.00 0.40 $72.00

v. CHPO; prepare

Suggestion of Bankruptcy

re: same [.2]; Receipt of

Order Denying Costa

Investors LLC's Motion to

Compel the 2004 Deposition

of the Corporate

Representative of Costa

Hollywood Property Owner

LLC [ECF No. 225]; review

Order and Local Rules for

proper service list for

Certificate of Service of DE

225 [.2]

MR Receipt of Order Denying $180.00 0.10 $18.00

Costa Investors LLC's

Motion for Extension of

Time to Object to Notice of

Dischargeability [ECF No.

224]; review order and local

rules for proper service list

for Certificate of Service of

DE 224

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 143 of 144
JCM Draft email to Mr. Udell $495.00 0.20 $99.00

regarding status of

settlement negotiations (.1);

review response from Mr.

Udell regarding same (.1).

January 27, 2020

Totals 66.70 $28,115.00

Case 19-22483-AJC Doc 256 Filed 03/20/20 Page 144 of 144