UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

www.flsb.uscourts.gov

IN RE: Case No.: 21-14169-AJC 

MICHAEL PETRUSHA and 

TRACEY PETRUSHA, 

 Debtors./ 

Chapter 7 

SUMMARY OF FIRST AND FINAL FEE APPLICATION OF MARKOWITZ, RINGEL, 

TRUSTY & HARTOG, P.A., COUNSEL TO THE CHAPTER 7 TRUSTEE 

1. Name of Applicant: Markowitz Ringel Trusty & Hartog, P.A. 

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

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

4. Date case filed: April 30, 2021 

5. Date of Retention Order: June 29, 2021 [ECF No. 20] 

Effective as of June 16, 2021 

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

6. Period for this Application: N/A

7. Amount of Compensation Sought: N/A

8. Amount of Expense Reimbursement Sought: N/A

IF FINAL APPLICATION, COMPLETE 9 AND 10 BELOW:

9. Total Amount of Compensation Sought during case: $37,380.00

10. Total Amount of Expense Reimbursement Sought during case: $665.72

11. Amount of Original Retainer (s) Please disclose both Fee Retainer and 

Cost Retainer if such a Retainer has been received: N/A

12. Current Balance of Retainer(s) remaining: N/A

13. Last monthly operating report filed (Month/Year and ECF No.): N/A

14. If case is Chapter 11, current funds in the Chapter 11 estate: N/A

15. If case is Chapter 7, current funds held by Chapter 7 trustee: $184,981.47

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 1 of 24
UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION

www.flsb.uscourts.gov

IN RE: Case No.: 21-14169-AJC 

MICHAEL PETRUSHA and 

TRACEY PETRUSHA, 

 Debtors./ 

Chapter 7 

FIRST AND FINAL FEE APPLICATION OF MARKOWITZ, RINGEL, 

TRUSTY & HARTOG, P.A., COUNSEL TO THE CHAPTER 7 TRUSTEE 

JOHN H. LEE, ESQ. and the law firm of MARKOWITZ, RINGEL, TRUSTY & HARTOG, 

P.A. (collectively, the “Applicant” or the “Firm”), counsel to the Chapter 7 Trustee (the “Trustee”), 

applies for First and Final application for compensation for fees for services rendered and costs 

incurred in this Chapter 7 proceeding (the “Application”) for the period of June 16, 2021 to September 

7, 2022 (the “Application Period”). This Application is filed pursuant to 11 U.S.C. § 330 and 

Bankruptcy Rule 2016 and meets all of the requirements set forth in the Guidelines incorporated in 

Local Rule 2016-1(B)(1). No understanding exists between the Applicant and any other person for 

the sharing of compensation sought by Applicant, except among the partners and associates of the 

Applicant. 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. 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 2 of 24
Applicant has expended a total of 96.6 hours during the Application Period rendering 

necessary and beneficial legal services to the Trustee and is seeking an award of fees totaling 

$37,380.00 plus reimbursement of expenses totaling $665.72. 

DESCRIPTION OF SERVICES BY ACTIVITY CODES 

 As set forth in the exhibits to this Application, Applicant has organized its time records by 

activity codes in accordance with the Guidelines. Applicant summarizes the services provided as 

follows: 

Asset Analysis and Recovery 

 The Applicant expended considerable time analyzing and researching the Debtor’s financial 

affairs and whether there were assets in this case. Applicant reviewed the Debtor’s bank statements 

and tax returns, as well as conducted independent diligence on the Debtor’s financial affairs. 

 During the pendency of this case the Trustee discovered that the Debtors procured pre-petition 

fully executed sales contracts for three separate real properties in which the Debtors were both the 

buyer’s and seller’s real estate agent. The Trustee asserted that the commissions from these three 

properties, if the sales closed, were property of the bankruptcy estate. The Debtors’ disputed the 

Trustee’s assertion and much of Applicant’s time revolved around the prosecution of same. 

Applicant’s efforts involved extensive and ongoing legal research, drafting a motion to compel 

turnover of the real estate commissions and attending three separate hearings on same, drafting a 

response to the Debtors’ motion to dismiss this case and successfully arguing at the subsequent 

hearing for same, conducting a deposition of the Debtors, and ongoing negotiations with Debtors’ 

counsel. Due to Applicant’s efforts the real estate commissions, totaling over $190,000.00, were 

found to be property of the estate and the Debtors were ordered to turnover same. 

 Applicant has expended 86.6 hours and is seeking an award of fees in the amount of 

$33,780.00 for services provided in this category. 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 3 of 24
Case Administration 

 Applicant has managed all aspects of this case, including compliance with all statutes, rules 

and guidelines. Applicant provided the Trustee with constant updates and summary information 

necessary for compliance with reporting requirements. Applicant also spent time drafting and 

finalizing a criminal referral of the Debtors and discussing same with the Trustee. 

 Applicant has expended 4.6 hours (including estimated time to attend to matters related to 

closing the estate) and is seeking an award of fees in the amount of $2,145.00 for services provided 

in this category. 

Fee/Employment Applications 

 Applicant assisted the Trustee with all necessary pleadings to retain the Firm as counsel to the 

Trustee. Applicant also expended time drafting and finalizing its fee application. 

 Applicant has expended 5.4 hours (including estimated time to prepare this Application) and 

is seeking an award of fees in the amount of $1,455.00 for services provided in this category. 

EVALUATION OF SERVICES PROVIDED 

The Applicant believes that the requested fee of $37,380.00 for 96.6 hours worked is 

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

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

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

The Time and Labor Required: The Applicant's actual time records are attached as Exhibit 

“4”. They reflect the nature of the services performed, but not the quality or importance of the services 

nor the priority accorded this case. Typically, some minor services are not recorded in the time 

records. The time records do reflect, however, the extended numerous services performed, including 

drafting pleadings, analyzing financial records and documents, conducting examinations, negotiating, 

attending conferences and court appearances and research required to adequately represent the 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 4 of 24
interests of the Trustee. A summary of the time reports and services provided are also attached to this 

Application as Exhibits 2-A and 2-B. 

 The Novelty and Difficulty of the Services Rendered: The issues which have arisen during 

the Application Period are not unusual in chapter 7 bankruptcy cases. Applicant dealt with creditor 

inquiries, financial record review, analysis of possible sources of recovery, negotiations with the 

Debtors and general case administration issues. 

 The Skill Requisite to Perform the Legal Services Properly: To properly represent any Chapter 

7 Trustee requires substantial legal skill and experience in the area of bankruptcy law. The skill 

necessary in this case is not different from other Chapter 7 cases. 

The Preclusion of Other Employment by the Attorney Due to the Acceptance of the Case: To 

our knowledge, no other employment was precluded by our accepting this case. Of course, had we 

not accepted this case, we might have devoted our time to other matters for which we are compensated 

by clients on a current monthly basis. 

The Customary Fee: The fee request is reflective of the same hourly rates which we charge 

other commercial clients on a monthly basis. The hourly rates charged by Applicant as set forth in 

Exhibits 2-A and 2-B range from $375.00 to $525.00 per hour for attorneys and $125.00 to $175.00 

per hour for paralegals and law clerks, which is well within (or lower than) the rates charged by other 

professionals and paraprofessionals in the Southern District of Florida of similar skill and experience. 

Whether the Fee is Fixed or Contingent: Applicant’s compensation in this matter is subject 

to approval of the Court and therefore contingent. The Court should consider this factor, which 

militates in favor of a fee award in the amount requested. The amount requested is based on a fixed 

hourly rate that is consistent with what Applicant charges its clients in other non-contingent, 

bankruptcy and commercial cases. 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 5 of 24
Time Limitations Imposed by the Client or Other Circumstances: Applicant is mindful of the 

desire to administer this case expeditiously in the interest of creditors and the Debtor. 

The Experience, Reputation, and Ability of the Attorneys: Applicant is experienced in 

bankruptcy proceedings and is well known to this court. Applicant enjoys a fine reputation and the 

attorneys working on this matter have proven ability in the fields of bankruptcy and bankruptcy 

litigation. Mr. Hartog is well known to the Court and is a shareholder of the Applicant. Mr. Hartog 

concentrates on the representation of trustees, creditors, creditors' committees, and debtors in 

bankruptcy cases. Mr. Hartog is on the panel of chapter 7 bankruptcy trustees in the Southern District 

of Florida. Mr. Hartog is also a past president of the Bankruptcy Bar Association for the Southern 

District of Florida. Mr. Lee focuses his practice on bankruptcy and restructuring, bankruptcy 

litigation, and creditors' rights and representing bankruptcy trustees in chapter 7 cases. 

The Undesirability of the Case: This case is not undesirable and Applicant is proud to have 

had the privilege of serving the Trustee and the Court in this matter. 

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

frequently served as counsel to the client in other bankruptcy proceedings in his capacity as a Chapter 

7 Trustee. 

Awards in Similar Cases: The fee requested is typical of fees requested and received by 

applicants for similar services involving similar results obtained, considering the size and complexity 

of the disputes among the parties. The fees requested by the Applicant, computed at the hourly rate 

of between $125.00 and $525.00 per hour, comport with the economic spirit of the Bankruptcy Code. 

Applicant respectfully requests that this Court take notice that Applicant occupies extensive and 

expensive offices in prime commercial locations, with extensive library facilities, sophisticated office 

equipment, and a large staff of paralegals, secretarial and other support personnel, all of which 

contributed to the results obtained in this case. Consequently, a significant portion of any fee award 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 6 of 24
necessarily defrays the substantial overhead charges incurred in operating the Applicant law firm for 

which clients outside of bankruptcy proceedings may be separately charged.

 WHEREFORE, the Applicant seeks a first and final award of fees in the amount of 

$37,380.00 and costs in the amount of $665.72. 

Dated: September 7, 2022 Markowitz, Ringel, Trusty & Hartog, P.A. 

 Counsel to Chapter 7 Trustee 

 9130 South Dadeland Boulevard, Suite 1800 

 Miami, Florida 33156 

 Tel. (305) 670-5000 

 Fax. (305) 670-5011 

 By: /s/ John H. Lee 

 JOHN H. LEE 

 Florida Bar No. 91795 

 E-mail: jlee@mrthlaw.com

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 7 of 24
Fee Application Summary Chart 

Exhibit "1" 

REQUEST APPROVAL PAID 

Date Filed 

ECF # Period 

Covered 

 Fees Requested 

 Expenses Requested 

Date Order Entered 

ECF # Fees 

Approved 

 Expenses Approved 

 Fees Paid 

ExpPaid 

Not Applicable as this is the first and final fee application.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 8 of 24
EXHIBIT “2-A”

Summary of Professional and Paraprofessional Time 

Total Per Individual for this Period Only

Name Shareholder, 

Partner, 

Associate, 

Paraprofessional 

Year 

Licensed 

Total 

Hours 

Rate Fee 

Ross R. Hartog Shareholder 19951 11.8 $525.00 $6,195.00

John H. Lee Partner 2011 82.1 $375.00 $30,787.50

Grace Ruiz Paralegal N/A 1.2 $175.00 $210.00

Mark Salazar Paralegal N/A 1.5 $125.00 $187.50

Total Hours (a) (a) 96.6 

Average “Blended” Hourly 

Rate (b) 

 (b) $386.96 

Total Fees (c) (c)$37,380.00

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

1

 Admitted to practice in Arizona in 1995 and Florida in 2000. 

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 9 of 24
EXHIBIT "2-B"

Summary of Professional and Paraprofessional Time by

Activity Code Category for this Time Period Only 

Activity Code: Asset Analysis and Recovery 

Name Rate Hours Fees 

Shareholder Ross R. Hartog $525.00 8.7 $4,567.50

Partner John H. Lee $375.00 77.9 $29,212.50

Activity Subtotal: 86.6 $33,780.00

Activity Code: Case Administration 

Name Rate Hours Fees 

Shareholder Ross R. Hartog $525.00 2.8 $1,470.00

Partner John H. Lee $375.00 1.8 $675.00

Activity Subtotal: 4.6 $2,145.00

Activity Code: Fee/Employment Applications 

Name Rate Hours Fees 

Shareholder Ross R. Hartog $525.00 0.3 $157.50

Partner John H. Lee $375.00 2.4 $900.00

Paralegal Grace Ruiz $175.00 1.2 $210.00

Paralegal Mark Salazar $125.00 1.5 $187.50

Activity Subtotal: 5.4 $1,455.00

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 10 of 24
EXHIBIT "3" 

Summary of Requested Reimbursement Of Expenses for this Time Period Only 

1. Filing Fees $ 

2. Process Service Fees $ 

3. Witness Fees $ 

4. Court Reporter Fees and Transcripts $ 260.00

5. Lien and Title Searches $ 

6. Photocopies 

(a) In-house copies (None at 0.15/page) 

$ 

7. Postage $ 0.51

8. Overnight Delivery Charges $ 

9. Outside Courrier/Messenger Services $ 

10. Long Distance Telephone Charges $ 

11. Long Distance Fax Transmissions $ 

12. Computerized Research 

(a) Westlaw ($205.11) 

(b) Pacer ($1.80) 

$ 206.91

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

14. Other Permissible Expenses (must specify and justify) 

(a) Court Solutions Hearings 

$ 150.00

15. Certified Court Copies $ 

16. Certificate of Service Mailings $ 48.30

TOTAL EXPENSE REIMBURSEMENT REQUESTED: $ 665.72

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 11 of 24
Exhibit “4” 

(Applicant’s Time Records for Application Period)

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 12 of 24
Soneet Kapila, Chapter 7 Trustee

1000 South Federal Highway

Suite 200

Fort Lauderdale,FL. 33316

For Services Rendered through September 7, 2022

Asset Analysis and Recovery

06/16/21 JHL Review case file in new Petrusha case. Discuss 3.60 375.00 1,350.00

case issues with R. Hartog and Trustee. 

Correspond and conference with Debtor's

counsel discussing case issues. Conduct legal

research regarding real estate commissions and

property of the estate.

06/16/21 RRH Multiple e-mails and conferences with Trustee, 1.80 525.00 945.00

A. Poilit, and J. Lee regarding new case, due

diligence, and seeking hold on real estate

commission.

06/17/21 JHL Conference with R. Hartog regarding case 0.50 375.00 187.50

issues in new Petrusha case.

06/17/21 JHL Correspond with R. Hartog regarding 0.20 375.00 75.00

employment as Trustee's attorney in the

Petrusha case.

06/17/21 RRH E-mails with J. Lee and L. Gener regarding due 0.20 525.00 105.00

diligence and following up on hold of disputed

funds.

06/18/21 JHL Correspond with Debtor's counsel regarding 1.30 375.00 487.50

legal research and case issues in the Petrusha

case. Continue legal research. Review case law

also provided by Debtor's counsel and discuss

same.

06/25/21 JHL Correspond with Debtor's counsel regarding 0.70 375.00 262.50

extension of deadlines and case issues in the

Petrusha case. Conduct further legal research. 

Correspond with Debtor's counsel confirming

receipt of the commission checks in Debtor's

attorney's possession.

06/29/21 JHL Review order entered granting application to 0.10 375.00 37.50

employ Trustee attorney in the Pestrusha case.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 13 of 24
 06/29/21 JHL Draft and finalize motion and order to enlarge 0.50 375.00 187.50

deadlines in the Petrusha case.

07/01/21 JHL Review order granting motion to extend 0.10 375.00 37.50

deadlines.

07/09/21 JHL Correspond with Debtor's counsel regarding 3.20 375.00 1,200.00

case issues and settlement. Discuss same with

Trustee. Continue legal research regarding

when real estate commission are earned and

property of the bankruptcy estate. Provide

memorandum of law regarding same.

07/09/21 RRH Multiple communications with J. Lee and Trustee 0.20 525.00 105.00

regarding money in trust and commissions.

07/12/21 JHL Correspond with Debtor's counsel regarding 1.60 375.00 600.00

update with case and settlement. Review

additional documents from Debtors' counsel. 

Conduct legal research.

07/13/21 JHL Correspond with Debtors' counsel regarding 5.10 375.00 1,912.50

amounts held in trust, additional commissions,

discovery and settlement. Review additional

documents provided by Debtors' counsel. 

Continue legal research regarding commission

and property of the estate. Call with Debtors'

counsel discussing case law and potential

settlement. Review counter offer from Debtors'

counsel and send same to Trustee. Update legal

analysis and send same to Trustee and Debtors'

counsel.

07/13/21 RRH Continued communications with J. Lee and 0.20 525.00 105.00

Trustee regarding commissions.

07/15/21 JHL Provide case update to Trustee. Correspond 0.50 375.00 187.50

with Debtors' counsel regarding receipt of

second commission checks. Conference with R.

Hartog discussing same.

07/15/21 RRH Debrief J. Lee on call with T. Kingcaid and 0.20 525.00 105.00

issues in case; develop strategy; and prepare

update for Trustee.

07/19/21 JHL Correspond with Debtor's counsel confirming 0.30 375.00 112.50

amount held in trust and other case issues.

07/22/21 JHL Correspond with Debtors' counsel discussing 0.30 375.00 112.50

potential settlement of commission issue.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 14 of 24
 07/23/21 JHL Follow up with Debtors' counsel regarding 0.10 375.00 37.50

potential settlement.

07/24/21 JHL Review email from Debtor's counsel with update 0.10 375.00 37.50

regarding efforts to contact client regarding

settlement.

07/26/21 JHL Correspond with Debtors' counsel requesting 0.20 375.00 75.00

update and potential agreement to enlarge

deadlines.

07/27/21 JHL Review email from Debtors' counsel informing of 0.10 375.00 37.50

motion to dismiss case.

07/28/21 JHL Review motion to dismiss filed by Debtors. 0.30 375.00 112.50

Correspond with R. Hartog.

07/28/21 JHL Review email from Debtors' counsel agreeing to 0.40 375.00 150.00

enlarge deadlines. Discuss case issues with

Debtors' counsel and trustee's opposition to

Debtor's motion to dismiss.

07/28/21 RRH Continued development of strategy for recovery 0.20 525.00 105.00

of commissions and drafting of motion to compel

turnover.

07/29/21 JHL Draft motion to compel turnover of commissions. 6.20 375.00 2,325.00

Continue legal research regarding same. 

Correspond with Debtors' counsel regarding

potential additional unscheduled sales contracts

and discovery related to same.

07/29/21 RRH Review and revise motion to compel turnover of 0.50 525.00 262.50

real estate commissions.

07/30/21 JHL Draft and file motion and order enlarging 0.50 375.00 187.50

deadlines.

07/30/21 JHL Provide Trustee case update. Discuss same 0.60 375.00 225.00

with R. Hartog. Correspond with Debtors'

counsel regarding update with documents.

07/30/21 RRH E-mails with J. Lee regarding motion to compel, 0.20 525.00 105.00

motion to dismiss, and research regarding

commissions.

07/30/21 RRH E-mails with B. Beckett regarding MLS. 0.20 525.00 105.00

08/02/21 JHL Follow up with Debtor's counsel regarding 0.10 375.00 37.50

documents.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 15 of 24
 08/02/21 JHL Review order granting motion to extend 0.10 375.00 37.50

deadlines.

08/02/21 JHL Revise and finalize motion to compel turnover of 2.70 375.00 1,012.50

commissions. Discuss same with R. Hartog.

08/02/21 RRH Conferences and e-mails with J. Lee regarding 0.50 525.00 262.50

motion to compel; review and revise same.

08/03/21 JHL Correspond with Debtor's counsel regarding 0.20 375.00 75.00

deposition dates.

08/04/21 RRH E-mails and conferences with J. Lee and 0.20 525.00 105.00

Trustee regarding Rule 2004 Examination.

08/05/21 JHL Correspond with Debtor's counsel regarding 0.20 375.00 75.00

deposition dates.

08/09/21 JHL Draft notice of 2004 examination of the Debtors. 1.00 375.00 375.00

08/09/21 JHL Review case file and discovery. Correspond 0.70 375.00 262.50

with Trustee's office regarding all documents

produced to trustee and requests for copies of

same.

08/10/21 JHL Continue reviewing discovery and investigate 1.10 375.00 412.50

asset profile. Finalize notice of 2004

examination.

08/12/21 JHL Correspond with Debtors' counsel regarding 0.20 375.00 75.00

2004 and missing documents.

08/16/21 JHL Correspond with M. Walker regarding debtor 0.20 375.00 75.00

documents produced to Trustee.

08/18/21 JHL Correspond with Debtor's counsel regarding 0.40 375.00 150.00

missing documents. Conference regarding

same.

08/20/21 JHL Correspond with Debtor's counsel regarding 0.50 375.00 187.50

case issues and documents. Conference and

e-mails with Y. Candia and court reporter 

regarding 2004 exam of the Debtor and

confirming same.

08/23/21 JHL Prepare for deposition of Debtors. 5.00 375.00 1,875.00

08/24/21 JHL Prepare for and conduct deposition of Debtors. 5.10 375.00 1,912.50

08/24/21 RRH E-mails and call with J. Lee to debrief and 0.20 525.00 105.00

evaluate Rule 2004 Examination.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 16 of 24
 08/25/21 JHL Conference with R. Hartog regarding case issue 0.20 375.00 75.00

and status.

08/25/21 JHL Call with R. Hartog discussing case issues. 0.30 375.00 112.50

08/26/21 JHL Correspond with Debtor's counsel regarding 0.30 375.00 112.50

case issues and conference to discuss same.

08/26/21 JHL Review additional documents provided by 0.60 375.00 225.00

Debtor that were requested at the 2004 exam.

08/27/21 JHL Conference with Debtor's counsel to discuss 0.30 375.00 112.50

case issues.

08/30/21 JHL Review email from Debtor's counsel regarding 0.10 375.00 37.50

case status and potential settlement.

09/02/21 JHL Conference with R. Hartog discussing case 0.20 375.00 75.00

issues and response to motion to dismiss.

09/02/21 JHL Draft response to motion to dismiss case. 5.90 375.00 2,212.50

Conduct legal research regarding same. 

Correspond with R. Hartog regarding response.

09/02/21 RRH Evaluate strategies for motion to compel 0.20 525.00 105.00

turnover in light of Debtor's position; conference

with J. Lee regarding same.

09/02/21 RRH Review and revise response to motion to 0.50 525.00 262.50

dismiss and e-mails with J. Lee regarding same.

09/07/21 JHL Prepare for and attend hearing on motion to 2.60 375.00 975.00

dismiss.

09/08/21 JHL Draft order denying motion to dismiss. Draft 0.60 375.00 225.00

order continuing hearing on motion to compel. 

Discuss same with Debtors' counsel.

09/09/21 JHL Provide case udpate to Trustee. 0.30 375.00 112.50

09/09/21 JHL Correspond with L. Gener regarding order on 0.20 375.00 75.00

continuing motion to compel and new date for

same.

09/09/21 RRH Multiple calls and e-mails with Trustee, M. 0.50 525.00 262.50

Walker, and J. Lee regarding hearings on motion

to compel and motion to dismiss as well as

criminal referral.

09/10/21 JHL Review order entered by judge denying motion 0.10 375.00 37.50

to dismiss case.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 17 of 24
 09/13/21 JHL Review order entered continuing hearing on 0.10 375.00 37.50

motion to compel.

09/14/21 JHL Conference with K. Gonzalez discussing case 0.30 375.00 112.50

issues.

09/14/21 JHL Review additional discovery provided by debtors. 0.70 375.00 262.50

09/15/21 JHL Revise criminal referral letter. Discuss same with 0.80 375.00 300.00

R. Hartog.

09/15/21 JHL Conference with R. Hartog discussing various 0.30 375.00 112.50

issues and legal arguments regarding dismissal

and property of the estate.

09/16/21 JHL Finalize criminal referral letter. 0.40 375.00 150.00

09/17/21 JHL Correspond with Debtor's counsel regarding 0.60 375.00 225.00

potential settlement. Conference with counsel

regarding same.

09/17/21 JHL Draft and file motion to extend deadlines. 0.50 375.00 187.50

09/17/21 RRH Evaluate settlement options and continued 0.20 525.00 105.00

hearing on motion to compel; conference with J.

Lee regarding same.

09/18/21 RRH E-mails with Trustee regarding criminal referrals. 0.10 525.00 52.50

09/20/21 JHL Correspond with L. Gener regarding hearing on 0.20 375.00 75.00

motion to extend deadline and moving same.

09/20/21 JHL Review re-notice of hearing on motion to extend. 0.10 375.00 37.50

09/20/21 JHL Correspond with Debtors' counsel regarding 0.20 375.00 75.00

case status.

09/20/21 RRH Confirm stance on dismissal and settlement 0.10 525.00 52.50

terms with J. Lee.

09/27/21 JHL Correspond with Debtors' counsel and Trustee 0.40 375.00 150.00

regarding potential settlement.

09/27/21 RRH E-mails with J. Lee and Trustee regarding 0.10 525.00 52.50

settlement offer.

10/06/21 JHL Correspond with A. Polit regarding coverage of 0.20 375.00 75.00

motion to compel hearing.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 18 of 24
 10/06/21 RRH Assist J. Lee in preparation for hearing on 0.50 525.00 262.50

motion to compel turnover of real estate

commissions.

10/07/21 JHL Conference with JA regarding continued hearing 0.30 375.00 112.50

on motion to compel. Review notice of

continued hearing filed by judge.

10/07/21 RRH Commuincations with J. Lee regarding hearing 0.20 525.00 105.00

on motion to compel.

10/08/21 JHL Prepare for and attend hearing on motion to 2.30 375.00 862.50

compel. Correspond with Trustee regarding

udpate with case and the hearing.

10/08/21 RRH Debrief J. Lee on motion to compel; 0.20 525.00 105.00

commuincations with Trustee regarding same.

10/11/21 JHL Draft order granting motion to extend deadlines. 0.30 375.00 112.50

10/11/21 JHL Draft order granting motion to compel turnover 0.60 375.00 225.00

of non-exempt assets. Send same to debtors'

counsel. Correspond with Debtor's counsel

regarding same.

10/12/21 JHL Review order entered by judge granting motion 0.30 375.00 112.50

to compel and motion to enlarge deadlines. 

Discuss same with Debtors' counsel and status

of payment.

10/13/21 JHL Correspond with Debtors' counsel regarding 0.20 375.00 75.00

status of commission checks.

10/14/21 JHL Correspond with Debtors' counsel regarding 0.20 375.00 75.00

status of payments.

10/15/21 JHL Correspond with Debtors' counsel and A. Polit 0.50 375.00 187.50

regarding turnover of commission checks.

10/29/21 JHL Prepare and send email to Debtor's counsel 0.10 375.00 37.50

requesting update with third property and

documents related to potential sales

commissions.

11/01/21 JHL Review email from Debtor's counsel with update 0.10 375.00 37.50

regarding discovery.

11/03/21 JHL Correspond with Debtor's counsel regarding 0.30 375.00 112.50

update with discovery and agreement to enlarge

deadlines. Correspond with L. Gener regarding

filing not agreed motion to extend deadlines.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 19 of 24
 11/04/21 JHL Draft and file motion to extend deadlines. 0.40 375.00 150.00

11/08/21 JHL Correspond with Debtors' counsel requesting 0.20 375.00 75.00

update with documents and agreement to

extend deadlines.

11/09/21 JHL Correspond with Debtors' counsel regarding 0.40 375.00 150.00

update with case. Review additional discovery.

11/09/21 RRH Assist J. Lee in preparing for continued hearing 0.50 525.00 262.50

on motion to compel.

11/10/21 JHL Correspond with Debtors' counsel regarding 0.30 375.00 112.50

missing discovery, extension of deadlines, and

pending hearing on motion to compel.

11/10/21 JHL Prepare for and attend continued hearing on 1.30 375.00 487.50

motion to compel.

11/10/21 RRH Debrief J. Lee on continued hearing on motion 0.20 525.00 105.00

to compel and report to Trustee.

11/11/21 JHL Draft order continuing hearing on motion to 0.70 375.00 262.50

compel. Draft order on motion to extend

deadlines. Correspond with Debtors' counsel

regarding edits to order and dispute of same.

11/12/21 JHL Review emails from Debtors' counsel regarding 0.20 375.00 75.00

case issues.

11/15/21 JHL Correspond with Debtors' counsel regarding 0.20 375.00 75.00

case issues.

11/16/21 JHL Review order continuing hearing on motion to 0.10 375.00 37.50

compel.

12/14/21 JHL Correspond with Debtors' counsel regarding 1.20 375.00 450.00

update regarding sale efforts on third property. 

Prepare for and attend hearing on motion to

compel.

12/15/21 JHL Correspond with Debtors' counsel regarding 0.30 375.00 112.50

proof that they no longer have listing agreement

for last remaining property.

12/22/21 JHL Draft agreed order continuing hearing on motion 0.50 375.00 187.50

to compel. Discuss same with Debtor's counsel

and L. Gener.

12/23/21 JHL Review order entered continuing hearing on 0.10 375.00 37.50

motion to compel.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 20 of 24
 12/30/21 JHL Correspond with Debtor's counsel regarding 0.20 375.00 75.00

case issues and potential settlement.

01/03/22 JHL Draft agreed motion and order enlarging 0.50 375.00 187.50

deadlines.

01/03/22 JHL Review proof of claim filed by IRS. 0.20 375.00 75.00

01/05/22 JHL Review order entered granting motion to extend 0.10 375.00 37.50

deadlines.

01/07/22 JHL Send email to Debtor's counsel regarding 0.10 375.00 37.50

update with sale documents.

01/17/22 JHL Correspond with Debtor's counsel regarding 0.20 375.00 75.00

status of closing on last property.

01/17/22 RRH Work with J. Lee to prepare for third hearing on 0.40 525.00 210.00

motion to compel.

01/18/22 JHL Prepare for and attend hearing on motion to 1.30 375.00 487.50

compel.

01/18/22 RRH Debrief J. Lee on hearing on motion to compel 0.20 525.00 105.00

and prepare report for Trustee.

01/18/22 JHL Correspond with Debtor's counsel requesting 0.20 375.00 75.00

the closing documents for the sale of the last

property.

01/21/22 JHL Draft order on motion to compel. Correspond 0.60 375.00 225.00

with Debtor's counsel regarding status of

commission check.

01/21/22 JHL Review order entered by judge on motion to 0.10 375.00 37.50

compel.

01/24/22 JHL Correspond with Debtor's counsel regarding 0.30 375.00 112.50

update with closing. Review closing statement

and checks for third property from Debtor's

counsel.

01/25/22 RRH Communications with J. Lee confirming the 0.20 525.00 105.00

estate's entitlement to real estate commissions

and to determine next steps.

01/26/22 JHL Provide case update to trustee and correspond 0.50 375.00 187.50

regarding payment to estate. Correspond with

Debtor's counsel regarding same.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 21 of 24
 01/28/22 JHL Provide case update to trustee. Provide analysis 0.90 375.00 337.50

regarding all case issues including potential

exemption or discharge issues. Correspond

with Trustee regarding same.

01/31/22 JHL Review motion for referral to mortgage 0.20 375.00 75.00

modification program.

02/04/22 JHL Correspond with trustee confirming receipt of 0.20 375.00 75.00

payment from Debtors.

02/23/22 JHL Review order entered on verified out of time 0.10 375.00 37.50

motion for referral to mortgage modification.

03/09/22 JHL Review notice of selection of mortgage 0.10 375.00 37.50

modification mediator.

04/27/22 JHL Review Trustee's interim report. 0.20 375.00 75.00

04/29/22 JHL Review final report of loss mitigation mediator. 0.10 375.00 37.50

05/20/22 JHL Review order entered discharging debtors. 0.10 375.00 37.50

07/11/22 JHL Review amended proof of claim filed by IRS. 0.10 375.00 37.50

AR Sub Total 86.60 33,780.00

Case Administration

08/04/21 JHL Provide case update to trustee. 0.30 375.00 112.50

08/06/21 RRH E-mails with Trustee regarding criminal referral. 0.20 525.00 105.00

08/10/21 RRH E-mails with Trustee regarding criminal referral. 0.10 525.00 52.50

08/19/21 RRH E-mails with M. Walker regarding criminal 0.20 525.00 105.00

referral.

08/23/21 RRH Conference with J. Lee to evalute discovery and 0.30 525.00 157.50

dismissal issues.

09/02/21 RRH Review and revise respose to motion to dismiss 1.00 525.00 525.00

and conferences and emails with J. Lee

regarding same.

09/15/21 RRH Review and revise criminal referral; conference 0.40 525.00 210.00

with J. Lee regarding same.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 22 of 24
 09/16/21 RRH E-mails and calls with J. Lee regarding criminal 0.20 525.00 105.00

referral and revisions to same.

09/24/21 JHL Correspond with A. Polit regarding criminal 0.20 375.00 75.00

referral letter.

01/28/22 RRH Commuincations with J. Lee and Trustee 0.20 525.00 105.00

regarding expiration of deadlines.

02/04/22 RRH Communications with J. Lee regarding case 0.20 525.00 105.00

status and whether further action is needed now

that debtor's commision proceeds have been

received by the Trustee.

02/25/22 JHL Review email from UST to Trustee requesting 0.10 375.00 37.50

update with case.

02/28/22 JHL Review email from Trustee to UST regarding 0.10 375.00 37.50

case update.

04/07/22 JHL Review notice of abandonment of certain assets 0.10 375.00 37.50

filed by Trustee.

09/07/22 JHL Tend to matters related to closing the estate. 1.00 375.00 375.00

CA Sub Total 4.60 2,145.00

Fee/Employment Applications

07/15/22 RRH Commuincations with M. Walker and J. Lee 0.20 525.00 105.00

regarding FFA and final taxes.

07/28/22 JHL Review order entered granting application to 0.10 375.00 37.50

employ Kapila as accountants.

08/25/22 RRH E-mails with M. Walker and M. Salazar 0.10 525.00 52.50

regarding FFA.

08/26/22 JHL Review and finalize time entries and costs for 0.90 375.00 337.50

purposes filing a final fee application.

09/02/22 JHL Review and finalize fee application. 0.30 375.00 112.50

09/07/22 PMS Draft first interim fee application for 1.50 125.00 187.50

compensation.

09/07/22 JHL Review and revise first interim fee application for 1.10 375.00 412.50

compensation.

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 23 of 24
 09/07/22 PGR Filing of fee application with the Court. 0.20 175.00 35.00

09/07/22 PGR Prepare notice to creditors of filing fee 0.50 175.00 87.50

application; due diligence to make sure service

list is updated.

09/07/22 PGR Prepare certificate of service; file with Court and 0.50 175.00 87.50

serve on all interested parties.

FA Sub Total 5.40 1,455.00

Total Fees 96.60 37,380.00

Total Fees after credits 37,380.00

Fee Summary Hours Rate Amount

John H. Lee 82.10 375.00 30,787.50

Grace Ruiz 1.20 175.00 210.00

Mark Salazar 1.50 125.00 187.50

Ross R. Hartog 11.80 525.00 6,195.00

Total Fees 96.60 37,380.00

Case 21-14169-PGH Doc 84 Filed 09/07/22 Page 24 of 24