UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No: 21-18481-MAM

NITV, LLC, Chapter 7

 Debtor.

_________________________/

SUMMARY OF FINAL FEE APPLICATION OF COUNSEL

1. Name of Applicant: Greenspoon Marder LLP

2. Role of Applicant: Attorneys for Chapter 7 Trustee

3. Name of Certifying Professional: Michael R. Bakst

4. Date Case Filed: August 31, 2021

5. Date of Retention Order: October 1, 2021

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

6. Period for this Application: 

7. Amount of Compensation Sought: 

8. Amount of Expense Reimbursement Sought 

IF FINAL APPLICATION, COMPLETE 9, 10 AND 11 BELOW:

9. Period for this Application October 1, 2021 through January 18, 2023

10. Total Amount of Compensation Sought During Case: $32,983.50 

11. Total Amount of Expense Reimbursement Sought During Case: $ 25.97

12. Amount of Original Retainer(s). Please disclose both Fee Retainer and Cost Retainer if such Retainer has been 

received: N/A

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

14. Last Monthly Operating Report filed (Month/Year and ECF No.) N/A

15. If case is a Chapter 11, current funds in Chapter 11 case: N/A

16. If case is a Chapter 7, current funds held by Chapter 7 Trustee: $164,002.39

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 1 of 20
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In re: Case No: 21-18481-MAM

NITV, LLC, Chapter 7

 Debtor.

_________________________/

FINAL FEE APPLICATION

Greenspoon Marder, LLP, attorneys for the Chapter 7 Trustee, applies for final compensation for fees for 

services rendered and costs incurred in this Chapter 7 proceeding. This application is filed pursuant to 11 U.S.C. §330 

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

2016-1(B)(1). The exhibits attached to this application pursuant to the Guidelines, are:

Exhibits “1-A and 1-B” – Summary of Professional and Paraprofessional Time.

Exhibit “2” – Summary of Requested Reimbursements of Expenses.

Exhibit “3” – The applicant’s complete time records, in chronological order, by activity code category for the 

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

Exhibit “4” – Spreadsheet of previous interim fee applications: N/A.

The applicant believes that the requested fee of $32,983.50 for 51.70 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 the bankruptcy proceedings by In re First Colonial Corp. of America, 544 F.2d 1291 (5th Circuit 1977), as 

follows:

1. THE TIME AND LABOR REQUIRED:

The time expended by the applicant for legal services furnished to the Chapter 7 Trustee as appears on Exhibit 

“A” does not reflect and cannot reflect all of the time actually expended by the applicant. Many telephone calls, 

routine correspondence, requests by creditors regarding the status of the Chapter 7 case and their individual claims 

cannot be reduced to time recordation and would increase the amount of time expended by the applicant in this case.

2. THE NOVELTY AND DIFFICULTY OF THE SERVICES RENDERED:

The Chapter 7 proceeding presented several matters that required the services and skill of an experienced 

bankruptcy attorney.

3. THE PRECLUSION OF OTHER EMPLOYMENT BY THE PROFESSIONAL DUE TO THE 

ACCEPTANCE OF THE CASE:

The applicant has devoted substantial time in the representation of the Chapter 7 Trustee as more fully appears 

on Exhibit “A”. The applicant is aware of no other specific employment which was precluded as a result of its 

accepting this case, but had the applicant not accepted this employment, the time spent in this case would have been 

spent on other matters which would pay an hourly compensation on a current basis.

4. THE CUSTOMARY FEE:

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 2 of 20
The hourly rate charged by Greenspoon Marder, LLP, reflects the hourly rates the applicant bills to its clients 

in other similar bankruptcy cases; which is customary for attorneys in the Southern District of Florida of similar skill 

and experience.

The hourly rate charged for timekeepers who worked on this bankruptcy are as follows:

Name Title Billed Per Hour

Michael R. Bakst Partner $615.00 to $655.00

Rilyn A. Carnahan Senior Counsel $530.00

5. TIME LIMITATIONS IMPOSED BY THE CLIENT OR OTHER CIRCUMSTANCES: 

The services performed by the applicant were performed under time constraints imposed by the Chapter 7 

Trustee. Therefore, considerable time ad to be expended within short periods of time to produce the pleadings, 

responses to other pleadings, and settlement documents, predicated upon the Chapter 7 Trustee’s proposed actions to 

resolve the issues in this bankruptcy estate.

6. THE EXPERIENCE, REPUTATION, AND ABILITY OF THE APPLICANT:

Greenspoon Marder, LLP with Michael R. Bakst as lead attorney, have substantial bankruptcy experience and 

have appeared numerous times before this Court on other matters and their reputation and abilities are well known to 

this Court.

7. UNDESIRABILITY OF THE CASE:

The representation of this Chapter 7 estate was not undesirable.

8. THE LEGAL STANDARD:

The applicable legal standard for compensation under 11 U.S.C. §330 is based on time, nature, extent, and 

value of the applicant’s services, as well as the cost of comparable services other than in a case under Title 11. 

Therefore, it is respectfully required that the Court consider the reasonableness of the fee required by the applicant.

9. CASE NARRATIVE:

This bankruptcy was filed as a voluntary Chapter 7 proceeding on August 31, 2021 by NITV, LLC. Michael 

R. Bakst was appointed as the Chapter 7 Trustee in Bankruptcy for NITV, LLC. The Debtor filed its initial schedules 

on August 31, 2021[ECF No. 1]. The Debtor’s 341 Meeting of Creditors was held and concluded on October 7, 2021

[ECF No. 10].

On October 1, 2021, the Trustee filed his Ex Parte Application to Employ Michael Bakst and the Law Firm of 

Greenspoon Marder LLP as Attorney for Trustee [ECF No. 8]. The Court entered the Granting the Trustee’s 

Emergency Application to Employ Michael Bakst and the Law Firm of Greenspoon Marder LLP as Attorney for 

Trustee on October 1, 2021 [ECF No. 9]. Counsel reviewed the schedules prior to the 341 Meeting of Creditors. 

Counsel corresponded with Scott Zappolo and had conference calls relating to the possible removal of a state court 

action which involved the Debtor and possible cause of action matters. 

At the time the Debtor filed the bankruptcy case, the law firm of Zappolo & Farwell, P.A. had a pending law 

suit against NITV, LLC and Third Party Defendants, NITV Federal Services, LLC, Charles Humble and Lourdes 

Irimia in the Circuit Court of the 15th Judicial Circuit, In and For Palm Beach County, Florida, Case Number 

502005CA001771XXXXMBAE. Counsel spoke with Scott Zappolo as to possibly representing the estate, spent time 

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 3 of 20
preparing the application to employ, affidavit and order and conversing with Special counsel as to matters involved in 

the bankruptcy proceeding. On October 21, 2021, the Trustee filed his Application to Employ Zappolo, Esq., of the 

law firm of Rice Zappolo & Farwell, P.A. as Special Litigation Counsel [ECF No. 12] to represent the estate for the 

State Court Action whether in the Circuit Court or the Bankruptcy Court on a contingency basis. The Court entered 

the Order Granting Application to Employ Scott Zappolo as his Special Litigation Counsel on November 4, 2021 [ECF 

No. 15]. 

Counsel reviewed the claim of Brinkley Morgan and corresponded with Mark Levy, Esq. and Scott Zappolo as 

to issues involved with the claim.

Counsel emailed back and forth numerous times as to the status of the state court litigation. Counsel reviewed 

the correspondence as to course of action to take in state court and had a conference call and many emails discussing 

the matter with Special counsel. Counsel reviewed and responded to email as to allegation of the automatic stay 

applying in regard to the state court matter and reviewed the state court case docket and corresponded with special 

counsel as to same.

Counsel spent time conducting legal research in the argument raised by Debtor’s counsel that the motion 

seeking substitute in as party plaintiff in state court supplement proceeding violates the automatic stay. Counsel 

reviewed case law holding that supplemental proceeding is its own separate action when third parties are brought in 

and cases where courts have specifically found that the Trustee is proper party to substitute into action brought by a 

creditor to recover on a judgment and prepared a summary of his findings to email back and forth with special counsel 

as to status.

Special counsel prepared and counsel reviewed the Motion for Relief from Stay and compared his findings in 

the case law research as to service of proper parties and conferred with special counsel as to same. On February 21, 

2022, the Trustee filed his Motion to Clarify Order on Application to Employ or alternatively for relief from Stay [ECF 

No. 19]. On February 23, 2022, the Trustee filed his Motion for Clarification of the Automatic Stay, or in the 

alternative Motion for Relief from Stay [ECF No. 23]. On February 23, 2022, Adversary 22-01092 was initiated and a

Notice of Removal by Defendant NITV Federal Services, LLC, Lourdes Irimia, James Kane, Charles Humble was 

filed. Counsel corresponded with Eyal Berger regarding his representation in the state court case as to the notice of 

removal and the case law cited in the notice of removal. Counsel emailed back and forth with special counsel as to 

how to proceed in light of removal of the state court matter by defendants and prepared for conference call as to same.

Counsel prepared for and participated in conference calls with special counsel and Eyal Berger, Esq. to discuss 

the case and emails to all parties as to scheduling a settlement conference. Counsel had numerous emails with parties 

to agree on a date for the scheduling conference and the requirements involved in the scheduling conference.

Counsel prepared for and reviewed the settlement conference statements prepared by special counsel and the 

settlement conference statement prepared by the defendant. Counsel had numerous telephone and email 

correspondence with special counsel in preparation for the settlement conference and attendance at same. On May 23, 

2022, counsel attended and participated in the settlement conference.

On June 15, 2022 counsel attended the hearing on the Motion to Clarify Order and corresponded with Trustee 

as to same.

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 4 of 20
Counsel corresponded with special counsel and other attorneys involved in the proposed settlement agreement 

and reviewed the stipulation for settlement, revised same and emailed revisions to all parties. Counsel reviewed the 

motion for settlement and corresponded with all parties with revisions emailed to same. On August 31, 2022, the 

special counsel filed the Motion to Compromise Controversy with Debtor, Humble, Humble and NITV, LLC [ECF 

No. 42]. Counsel reviewed the motion for settlement, prepared for and attended the hearing on the motion for 

settlement. Counsel also reviewed and revised the order granting the settlement. The Court entered the Order 

Granting the Trustee’s Motion to Approve Settlement Agreement Between Michael Bakst, as Chapter 7 Trustee and 

(Debtor) NITV, LLC, and to Pay Trustees Special Counsels Contingent Fees From Settlement Proceeds on October 25, 

2022 [ECF No. 49]. Counsel reviewed the motion for remand, prepared for and attended hearing on same. The Court 

found that the settlement amount of $250,000.00 was reasonable and that special counsel’s contingency fees of 35% in 

the amount of $87,500.00 was approved to be paid. Counsel corresponded with special counsel on pending matters 

based on the settlement and emailed back and forth with Eyal Berger as to form of payment on the settlement and 

emails to payee listed and confirmation that the check could be deposited.

Counsel prepared the orders pursuant to the settlement order, and on November 3, 2022 the Court entered the 

Order Denying as Moot the Motion for Clarification of the Automatic Stay Denying as Moot Motion For Relief From 

Stay [ECF No. 51] and in the adversary proceeding the Agreed Order Granting Agreed Motion to Remand to State 

Court, Denying all Outstanding Motions as Moot and Directing the Clerk to Close the File. On January 9, 2023, the 

adversary proceeding was closed and remanded to State Court [ECF No. 55].

Counsel corresponded with special counsel as to remaining matters in the case and prepared for an internal 

conference as to case status. 

Counsel reviewed communications with counsel for Brinkley Morgan as to whether the statute of limitations 

may have run on its claim, prepared objection to claim based on legal analysis, and prepared the order for same.

The Trustee informed counsel that all funds had been collected and the case was now ready to close.

10. CATERGORIES:

I. ADVERSARY PROCEEDINGS:

The facts surrounding the adversary proceedings are explained within the Case Narrative.

II. CONTESTED MATTERS:

The facts surrounding the contested matters are explained within the Case Narrative.

III. FEE/EMPLOYMENT:

Review files; prepare Final Fee Application.

11. CASE STATUS:

All monies have been received and this case is ready to close.

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 5 of 20
WHEREFORE, applicant seeks a final award of fees in the amount of $32,983.50 and reimbursement of costs 

in the amount of $25.97 for a total of $33,009.47.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the application, with all exhibits, has been furnished to all parties 

listed below in the manner indicated, this 19th day of January 2023.

GREENSPOON MARDER LLP

/s/ Michael R. Bakst

MICHAEL R. BAKST, ESQ.

Florida Bar No.: 866377

Attorneys for Trustee

525 Okeechobee Blvd., Suite 900

West Palm Beach, FL 33401

T: (561) 838-4523

Email: Michael.bakst@gmlaw.com

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.

• Michael R Bakst efilemrb@gmlaw.com, 

ecf.alert+Bakst@titlexi.com;efileu1084@gmlaw.com;efileu1086@gmlaw.com;efileu386@gmlaw.com;efileu1

857@gmlaw.com;efileu3163@gmlaw.com;efileu3214@gmlaw.com;efileu3291@gmlaw.com

• Michael R. Bakst efileu1094@gmlaw.com, 

ecf.alert+bakst@titlexi.com;efileu1092@gmlaw.com;efileu2170@gmlaw.com;efileu386@gmlaw.com;Meliss

a.bird@gmlaw.com;efileu2831@gmlaw.com;efileu3214@gmlaw.com

• Eyal Berger eyal.berger@akerman.com, jeanette.martinezgoldberg@akerman.com

• Julianne R. Frank julianne@jrfesq.com, G59511@notify.cincompass.com

• Amanda Klopp amanda.klopp@akerman.com, jeanette.martinezgoldberg@akerman.com

• Mark A Levy mark.levy@brinkleymorgan.com, 

sandra.gonzalez@brinkleymorgan.com;brinkleymorganecf@gmail.com

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

• Scott W Zappolo szappolo@zappolofarwell.com

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 6 of 20
CERTIFICATION

1. I have been designated by Greenspoon Marder LLP (the "Applicant") as the professional 

with responsibility in this case for compliance with the “Guidelines for Fee Applications for 

Professionals in the Southern District of Florida in Bankruptcy Cases” (the "Guidelines").

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

"Application"). The application complies with the Guidelines, and the fees and expenses sought fall within the

Guidelines, except as specifically noted in this certification and described in the application.

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

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

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

reimbursement only for the actual expenditure and has not marked up the actual cost to provide a profit or to

recover the amortized cost of investment in staff time or equipment or capital outlay (except to the extent that 

the Applicant has elected to charge for 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:

I HEREBY CERTIFY that the foregoing is true and correct.

GREENSPOON MARDER LLP

/s/ Michael R. Bakst

MICHAEL R. BAKST, ESQ.

Florida Bar No.: 866377

Dated: January 19, 2023

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 7 of 20
EXHIBIT 1-A

SUMMARY OF PROFESSIONAL AND

PARAPROFESSIONAL TIME

PROFESSIONALS

Name Total Hours Hourly Rate Total Fees

Year

 Licensed

Rilyn Carnahan 12/31/2002 0.80 530.00 424.00

Michael R. Bakst 12/31/1990 10.80 615.00 6,642.00

Michael R. Bakst 12/31/1990 34.80 645.00 22,446.00

Michael R. Bakst 12/31/1990 5.30 655.00 3,471.50

SUBTOTALS 51.70 $611.25 $32,983.50

PARAPROFESSIONAL

Name

Year

Licensed Total Hours

SUBTOTALS

Total Rate Total Fees

TOTAL:

Total Hours by Professional and Paraprofessional: 51.70

"Blended" Hourly Rate: ** $637.98

Total Professional and Paraprofessional Fees:

$32,983.50

* Indicate any changes in hourly rate during this Application and the date of such change: NONE 

** Hourly Rate Totals Indicate "blended" hourly rate.

8

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 8 of 20
Exhibit "1-B"

Summary of Professional and Paraprofessional Time by 

Activity Code Category for this Time Period Only

Total

Task Code Name Title Hours Total Fees

Hourly

 Rate

B111 - Contested Matters

Michael R. Bakst Partner 645.00 44.60 28,511.00

Rilyn Carnahan Associate 530.00 0.80 424.00

SUBTOTALS 45.40 28,935.00

B118 - Adversary Proceedings

Michael R. Bakst Partner 645.00 2.60 1,677.00

SUBTOTALS 2.60 1,677.00

B160 - Fee/Employment Applications

Michael R. Bakst Partner 655.00 2.50 1,585.50

SUBTOTALS 2.50 1,585.50

B310 - Claims Administration and Objections

Michael R. Bakst Partner 655.00 1.20 786.00

SUBTOTALS 1.20 786.00

9

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 9 of 20
EXHIBIT 2

Summary of Requested Reimbursement of Expenses

for this Time Period Only

(If this is a final application which does not cumulate prior interim applications, a separate 

summary showing cumulative expenses for all applications is attached as well)

1. Filing Fees $0.00

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

(b) Outside Copies

$0.00

$0.00

7. Postage $25.97

8. Overnight Delivery Charges (FedEx) $0.00

9. Outside Courier/Messenger Services $0.00

10. Long-Distance Telephone Charges $0.00

11. Long-Distance Fax Transmissions $0.00

12. Computerized Research $0.00

13. Out of Southern District of Florida Travel

(a) Transportation / Lodging $0.00

(b) Meals $0.00

14. Other Permissible Expenses

Total Expense Reimbursement Requested $25.97

10

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 10 of 20
Trade Centre South - Suite 700

100 West Cypress Creek Road

Fort Lauderdale, Florida 33309

Toll Free (888) 491-1120

Fax (954) 343-6272

Federal Tax ID 59-2402121

01/18/2023

Invoice No. 1433464

File No. 29511.0595

FOR PROFESSIONAL SERVICES RENDERED

NITV LLC

B111-Contested Matters

10/01/2021 0.30 184.50Emails with Scott Zappolo as to 

conference call and matters to possibly 

pursue

M.Bakst

10/01/2021 2.80 1,722.00Review of all related emails with 

pleadings and documents sent by Scott 

Zappolo (some time incurred prior to 

today); evaluate causes of action; 

emails as to same, as well as email as to 

possible removal of state court action; 

internal emails regarding case.

M.Bakst

10/04/2021 0.80 492.00Emails with, prepare for and participate 

in telephone call with Scott Zappolo as 

to issues involving Debtor and case in 

general

M.Bakst

10/12/2021 0.40 246.00Review matter as to status; emails with 

Scott Zappolo as to state court litigation 

and pursuit of same.

M.Bakst

10/14/2021 0.20 123.00Follow up email with Scott Zappolo as 

to being employed as special counsel; 

internal emails as to same.

M.Bakst

11

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 11 of 20
Invoice No. 1433464

10/19/2021 0.60 369.00Emails with prospective special counsel 

as to employment; review and revise 

proposed retention contract.

M.Bakst

10/20/2021 2.20 1,353.00Prepare application to employ special 

counsel, with affidavit and proposed 

order; emails relating to same prior to 

preparation of motion.

M.Bakst

11/02/2021 1.00 615.00Prepare for and attend hearing on 

motion to approve hiring special 

counsel.

M.Bakst

11/03/2021 0.30 184.50Prepare order approving retention of 

special counsel.

M.Bakst

11/04/2021 0.30 184.50Review order entered approving hiring 

of special counsel; prepare email to 

Scott Zappolo as to same.

M.Bakst

11/08/2021 0.40 246.00Review claim of Brinkley Morgan; 

prepare email to Mark Levy as to 

same; emails with Scott Zappolo as to 

same.

M.Bakst

11/19/2021 0.20 123.00Review case status; send email to Scott 

Zappolo as to status of state court 

litigation.

M.Bakst

12/01/2021 0.30 193.50Emails with Scott Zappolo as to 

conference call to discuss case.

M.Bakst

12/02/2021 1.30 838.50Review file and prior emails in 

preparation for telephone call with 

Scott Zappolo as to course of action to 

take in state court; discuss matter with 

Scott Zappolo.

M.Bakst

01/18/2022 1.30 838.50Review and respond to email from 

Julianne Frank as to allegation of 

automatic stay applying in regard to 

state court matter; review state court 

docket and bankruptcy docket as to 

same; emails with Scott Zappolo as to 

same.

M.Bakst

12

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 12 of 20
Invoice No. 1433464

01/18/2022 2.20 1,419.00Legal research argument raised by 

Debtor's counsel that motion seeking to 

substitute in as party plaintiff in state 

court supplemental proceeding violates 

automatic stay; review case law holding 

that supplemental proceeding is its own 

separate action when third parties are 

brought in; review cases where courts 

have specifically that trustee is proper 

party to substitute into action brought 

by creditor to recover on judgment; 

emails with Scott Zappolo summarizing 

results of research.

M.Bakst

02/03/2022 0.30 193.50Review matter as to status; prepare 

follow up email to Scott Zappolo, 

special counsel.

M.Bakst

02/04/2022 0.20 129.00Review and respond to email from Jeff 

Farwell as to inability of Scott Zappolo 

to respond until Monday, February 7th.

M.Bakst

02/21/2022 1.60 1,032.00Review motion for stay relief prepared 

by special counsel; compare to case 

law previously cited and review same; 

email to Scott Zappolo (special 

counsel) as to confirming proper service 

of same.

M.Bakst

02/24/2022 2.40 1,548.00Review and respond to emails from 

Eyal Berger regarding his representation 

in case; review notice of removal and 

case law cited in same; internal emails 

as to same; internal conferences as to 

same.

M.Bakst

02/24/2022 0.40 258.00Review and respond to emails from 

Scott Zappolo as to how to proceed in 

case in light of removal of state court 

matter by defendants.

M.Bakst

02/25/2022 0.60 387.00Emails with and conference with Scott 

Zappolo as to notice of removal; follow 

up emails as to arranging conference 

call.

M.Bakst

13

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 13 of 20
Invoice No. 1433464

02/25/2022 0.30 193.50Review emails and claim as to Brinkley 

Morgan proof of claim; prepare follow 

up email to Mark Levy as to same.

M.Bakst

02/28/2022 1.40 903.00Prepare for and participate in 

conference call with Scott Zappolo and 

Eyal Berger to discuss case; follow up 

emails as to same; emails as to 

scheduling of settlement conference.

M.Bakst

02/28/2022 0.20 129.00Review follow up email from Mark 

Levy as to claim; internal email as to 

same.

M.Bakst

03/01/2022 0.40 258.00Review and respond to emails involving 

scheduling of settlement conference.

M.Bakst

03/04/2022 0.30 193.50Emails with Scott Zappolo as to 

requirements for purposes of settlement 

conference.

M.Bakst

03/07/2022 0.40 258.00Review and respond to email from Eyal 

Berger regarding hearing tomorrow on 

stay relief; follow up emails with 

counsel.

M.Bakst

03/08/2022 0.60 387.00Emails with counsel prior to hearing on 

motion for clarification/stay relief; follow 

up emails as to same.

M.Bakst

03/08/2022 0.30 193.50Prepare for and participate in internal 

department meeting regarding status of 

estate and pending matters to be 

addressed.

M.Bakst

05/17/2022 0.80 516.00Emails with special counsel as to 

settlement conference call scheduled for 

tomorrow; review settlement 

conference statement prepared by 

special counsel.

M.Bakst

05/18/2022 0.80 516.00Prepare for and attend presettlement 

conference call with Court; review 

settlement conference statement of 

defendant.

M.Bakst

14

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 14 of 20
Invoice No. 1433464

05/18/2022 0.20 129.00Emails with Scott Zappolo after 

conference call regarding questions 

about attendance at upcoming 

settlement conference.

M.Bakst

05/18/2022 0.20 129.00Conference call with Scott Zappolo 

regarding upcoming settlement 

conference.

M.Bakst

05/23/2022 0.60 387.00Review email with attachment from 

Scott Zappolo for purposes of 

settlement conference tomorrow; email 

in response; internal emails as to same.

M.Bakst

05/24/2022 4.00 2,580.00Prepare for and attend settlement 

conference.

M.Bakst

06/13/2022 0.80 516.00Review matter; emails with special 

counsel as to status of settlement 

stipulation.

M.Bakst

06/15/2022 0.80 424.00Attend hearing on motion to clarify 

order

R.Carnahan

07/20/2022 0.30 193.50Review email from counsel; prepare 

follow up email to special counsel 

regarding same.

M.Bakst

07/22/2022 0.40 258.00Internal emails as to case status; follow 

up email with Scott Zappolo.

M.Bakst

07/25/2022 0.70 451.50Review and respond to emails between 

counsel as to status of settlement 

agreement.

M.Bakst

07/26/2022 0.50 322.50Review and respond to multiple emails 

on proposed settlement between 

counsel

M.Bakst

07/27/2022 0.60 387.00Emails and telephone conversation with 

Scot Zappplo regarding settlement 

stipulation; review emails involving 

same.

M.Bakst

08/08/2022 0.50 322.50Review latest stipulation draft from 

Scott Zappolo; follow up emails as to 

same

M.Bakst

08/15/2022 0.30 193.50Review and execute final settlement 

stipulation; review related emails.

M.Bakst

15

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 15 of 20
Invoice No. 1433464

08/16/2022 0.80 516.00Review emails with counsel as to 

hearing on remove set for tomorrow 

and pending settlement; review prior 

emails; prepare email to Scott Zappolo 

regarding best form of motion to be 

filed.

M.Bakst

08/25/2022 0.40 258.00Review matter as to pending status; 

follow up email with Scott Zappolo.

M.Bakst

08/29/2022 0.70 451.50Review matter as to status; review draft 

motion to approve settlement; emails 

with special counsel; discuss changes to 

motion with special counsel.

M.Bakst

08/30/2022 0.50 322.50Review emails, case file and pending 

issues in case to prepare for; participate 

in department meeting as to status of 

case and matters to be pursued..

M.Bakst

09/28/2022 1.00 645.00Review matter in preparation for 

hearing and attend hearing on motion to 

approve settlement; follow up email 

with special counsel as to form of 

order.

M.Bakst

10/10/2022 0.30 193.50Review and revise order approving 

settlement; emails as to same.

M.Bakst

11/09/2022 0.30 193.50Review and respond to emails with 

counsel as to ongoing proceedings 

based upon settlement.

M.Bakst

11/09/2022 0.40 258.00internal review of matter based on 

status of settlement and pending 

matters.

M.Bakst

11/09/2022 0.50 322.50Review emails as to form of motion for 

state court; review of motion and order; 

follow up emails as to same.

M.Bakst

11/09/2022 0.30 193.50Review and respond to email from Eyal 

Berger as to payment and form of 

same; internal emails as to payee listed 

on check and confirmation that same 

can be deposited.

M.Bakst

16

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 16 of 20
Invoice No. 1433464

11/28/2022 0.80 516.00Review email from Eyal Berger as to 

settlement payment; review case file; 

prepare email in response; review 

responsive emails.

M.Bakst

11/29/2022 1.00 645.00Prepare for and attend hearing on 

motion for remand; email to counsel as 

to order on same.

M.Bakst

12/02/2022 0.40 262.00Review and revise proposed order on 

remand; emails with counsel as to same.

M.Bakst

12/12/2022 0.70 458.50Review latest email from Scott Zappolo 

as to submission of settlement order to 

state court; prepare email as to same; 

review and respond to emails involving 

remaining matters in case.

M.Bakst

12/15/2022 1.00 655.00Prepare for and participate in internal 

conference as to case status.

M.Bakst

01/12/2023 0.80 524.00Review docket and all orders in order 

to confirm remaining matters to wind up 

case.

M.Bakst

Task Subtotal 45.40 28,935.00

B118-Adversary Proceedings

03/11/2022 1.40 903.00Review proposed agreed motion to 

extend time to file motion for remand; 

emails with Scott Zappolo as to same; 

review applicable Rule involving 

removal and legal issue raised by Scott 

Zappolo.

M.Bakst

03/15/2022 0.20 129.00Emails with Scott Zappolo as to order 

extending time to respond to notice of 

removal.

M.Bakst

08/17/2022 1.00 645.00Prepare for and attend hearing on 

removal; review related emails before 

and after hearing.

M.Bakst

Task Subtotal 2.60 1,677.00

B160-Fee/Employment Applications

10/01/2021 1.30 799.50Prepare application to employ counsel 

with affidavit and order.

M.Bakst

01/12/2023 M.Bakst 1.20 786.00Prepare final fee application.

17

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 17 of 20
Invoice No. 1433464

Task Subtotal 2.50 1,585.50

B310-Claims Administration and Objections

12/12/2022 1.20 786.00Review communications with counsel 

for Brinkley Morgan regarding whether 

statute of limitations may have run on 

claim; review claim; prepare objection 

based on such legal analysis.

M.Bakst

Task Subtotal 1.20 786.00

 51.70

 32,983.50

HOURS

TOTAL FOR SERVICES

18

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 18 of 20
Invoice No. 1433464

DISBURSEMENTS

10/11/2021 Postage - 1 4.24

11/08/2021 Postage - 1 17.49

11/08/2021 Postage - 1 4.24

TOTAL FOR DISBURSEMENTS $25.97

AMOUNT DUE THIS INVOICE $33,009.47

TIME SUMMARY

Name Title Hourly Rate Total Hours Total Fees

Rilyn Carnahan Associate 530.00 0.80 424.00

Michael R. Bakst Partner 615.00 10.80 6,642.00

Michael R. Bakst Partner 645.00 34.80 22,446.00

Michael R. Bakst Partner 655.00 5.30 3,471.50

Total 51.70 $32,983.50

TASK CODE SUMMARY

Task Code Description Total Hours Total Fees

B111 Contested Matters 45.40 28,935.00

B118 Adversary Proceedings 2.60 1,677.00

B160 Fee/Employment Applications 2.50 1,585.50

B310 Claims Administration and Objections 1.20 786.00

Total 51.70 $32,983.50

19

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 19 of 20
Invoice No. 1433464

TASK CODE SUMMARY PER TIMEKEEPER

Total Fees

Total

Name Title Hourly Rate Hours

B111-Contested Matters

Michael R. Bakst Partner $645.00 44.60 $28,511.00

Rilyn Carnahan Associate $530.00 0.80 $424.00

Subtotal 45.40 $28,935.00

B118-Adversary Proceedings

Michael R. Bakst Partner $645.00 2.60 $1,677.00

Subtotal 2.60 $1,677.00

B160-Fee/Employment Applications

Michael R. Bakst Partner $655.00 2.50 $1,585.50

Subtotal 2.50 $1,585.50

B310-Claims Administration and Objections

Michael R. Bakst Partner $655.00 1.20 $786.00

Subtotal 1.20 $786.00

COST SUMMARY

Code Description Amount Billed

SPOS Postage 25.97

20

Case 21-18481-MAM Doc 57 Filed 01/19/23 Page 20 of 20