Christine Jordan

778 Crystal Spgs Lane

Keizer, OR 97303

FETHERSTON EDMONDS, LLP

Ben C. Fetherston, Jr.* ATTORNEYS

James C. Edmonds

Christopher B. Matheny*

 ____________ *Also admitted to practice in Washington

TAX ID NO,.

93-0519796

960 Liberty Street SE, Suite 110

P.O. Box 2206

Salem, Oregon 97308-2206

MAIN OFFICE (503) 581-1542

FAX (503) 585-3978

STATEMENT

Account Number:

0

Statement Date:

Closing Date:

Attorney: JAT

81717

Invoice Number:

12/12/2016

11/30/2016

Matter: Jordan, Christine

Professional Services

Hours Amount

7/25/2014 JAT Review of court docket and documents provided by Christine; including complaint and 1.00 250.00

other pleadings.

JAT Meeting with attorney Jason Siebert re Burt claims. 0.70 175.00

JAT Tel conf with Christine re allegations in complaint and conversation with Siebert. 0.40 100.00

7/28/2014 JAT Email correspondence with Christine re arguments against complaint; review of Judgt 0.40 100.00

of Dissolution; email correspondence with Christine re same.

7/29/2014 JAT Review of emails and other info from Christine; prepare and send letter to Seibert and 2.00 500.00

Silver requesting withdrawal of claims.

JAT Meeting with Jason Seibert re withdrawing claims. 0.30 75.00

7/31/2014 JAT Research and prepare memorandum in response to plaintiff's motion for asset freeze; 3.40 850.00

declaration of Christine Jordan in support; file with the court.

8/4/2014 JAT Discussion with Siebert re his offer to stay proceedings if we close WF account; email 0.40 100.00

to Christine.

JAT Tel conf with Chris re Wells Fargo records and closing account; possible stay proposed 0.50 125.00

as resolution; tel conf with Siebert re terms of stay.

8/5/2014 JAT Email correspondence with Christine re closing Wells Fargo account and her 0.20 50.00

conversations with Rafael.

JAT Tel conf with Will Fallon (Rafael's attorney) re strategy for dealing with Burt and Silver. 0.40 100.00

JAT Tel conf with David Silver re agreement to provide records. 0.40 100.00

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

EXHIBIT 2 

Page 1 of 6
Christine Jordan Page 2

Hours Amount

8/5/2014 JAT Tel conf with Chris re obtaining recent WF statement and closing account. 0.20 50.00

JAT Review of WF bank statement for June/July; email correspondence with Christine re 0.30 75.00

same.

JAT Email correspondence with Silver re terms of abatement. 0.30 75.00

8/6/2014 JAT Review of proposed subpoena from Silver; email correspondence with Christine and 0.30 75.00

Silver re same.

JAT Office conf with Christine to discuss status of case and next steps. 0.30 75.00

JAT Prepare and file answer and affirmative defenses to complaint. 0.60 150.00

8/7/2014 JAT Receipt and review of Plaintiff's Reply to Defendant's Opposition to Emergency Motion. 0.20 50.00

8/12/2014 JAT Email correspondence with Christine re Burt's reply to motion for asset freeze and her 0.20 50.00

availability.

8/19/2014 JAT Review and respond to email from Christine re her being out of country and possibly 0.30 75.00

writing letter to plaintiff.

9/2/2014 JAT Receipt and review of opinion and order from court denying plaintiff's request for 0.20 50.00

preliminary injunction.

9/3/2014 JAT Email correspondence with Christine re order denying asset freeze. 0.20 50.00

9/5/2014 JAT Email correspondence with Siebert and Silver re scheduling 26f conference. 0.20 50.00

9/12/2014 JAT Prepare for and attend Rule 26 conference by phone. 0.50 125.00

9/16/2014 JAT Receipt and review of proposed scheduling order from Siebert. 0.20 50.00

10/2/2014 JAT Make revisions to Rule 26 scheduling order re confidentiality provisions for financial 0.50 125.00

information; email to plaintiff's attys re same; Telephone conference with Court

11/3/2014 JAT Prepare for and attend status conference with Judge; tel conf with plaintiff's counsel 1.00 250.00

following conference.

11/7/2014 JAT Email correspondence with Jason Siebert re subpoenas to various banks; review 0.30 75.00

subpoenas.

12/15/2014 JAT Receipt and review of notice of subpoena from plaintiff's attorney. 0.20 50.00

12/17/2014 JAT Email correspondence with Siebert re ADR; email correspondence with Christine re 0.40 100.00

same; tel conf with Christine.

12/18/2014 JAT Review of email from Christine re ADR options and possible pro se representation; tel 0.30 75.00

conf with Christine; email to plaintiff's attorney.

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

EXHIBIT 2 

Page 2 of 6
Christine Jordan Page 3

Hours Amount

12/18/2014 JAT Email correspondence with Siebert re joint ADR report; email correspondence re 0.50 125.00

proposed changes and various settlement offers.

12/22/2014 JAT Receipt and review of plaintiff's first request for admissions and production. 0.20 50.00

JAT Letter to Christine enclosing plaintiff's first RFA and RFP. 0.30 75.00

1/6/2015 JAT Email correspondence with Jordan re discovery; email from Siebert requesting 0.20 50.00

deposition dates.

1/7/2015 JAT Tel conf with Christine re discovery responses and deposition dates; email 0.30 75.00

correspondence with Siebert re same.

1/9/2015 JAT Office conf with Christine to review and discuss discovery responses. 0.50 125.00

1/13/2015 JAT Tel conf with Jason re discovery requests and possible need to postpone depo. 0.20 50.00

1/14/2015 JAT Receipt and review of prior email correspondence from Rafeal; review in preparation for 0.30 75.00

production to plaintiff.

1/15/2015 JAT Prepare response to Plaintiff's Requests for Admission and Requests for Production; 0.50 125.00

letter to plaintiff's attorney.

1/20/2015 JAT Email correspondence with Seibert and Jordan confirming depo. 0.20 50.00

1/22/2015 JAT Prepare for and attend depo of Christine Jordan. 3.00 750.00

2/2/2015 JAT Email correspondence with court re scheduling conference; review of notice from court 0.20 50.00

re same.

JAT Review of email from Seibert re additional discovery requests; email to Chris; tel conf 0.50 125.00

with Chris to discuss.

JAT Review FRCP 26 re scope of discovery. 0.30 75.00

2/3/2015 JAT Review and respond to lengthy email from Seibert re production issues; review FRCP 0.80 200.00

re scope of discovery.

2/4/2015 JAT Tel conf with Jason Seibert to confer on discovery issues and additional documents 0.50 125.00

they want.

JAT Email to Christine re document production strategy and follow up re conversation with 0.30 75.00

Seibert.

2/5/2015 JAT Additional email correspondence from Seibert and Silver re various threats etc; email 0.30 75.00

correspondence with Christine; tel conf with Christine.

2/6/2015 JAT Email correspondence with Seibert re discovery issues; email from Jason re amending 0.40 100.00

his complaint to add claims for RICO, money lanudering, etc; email correspondence

with Christine.

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

EXHIBIT 2 

Page 3 of 6
Christine Jordan Page 4

Hours Amount

2/6/2015 JAT Discuss case with Jim Edmonds; research re summary judgment options on various 0.40 100.00

claims.

2/10/2015 JAT Email correspondence with Seibert re Wells Fargo checks and other discover requests; 0.30 75.00

respond to his request for stipulation on amended complaint.

ASL Start initial research on disclosure issues 0.50 20.00

2/11/2015 JAT Email correspondence with Court and counsel re postponed scheduling conference. 0.10 25.00

2/12/2015 JAT Receipt and review of WF check copies from Christine; scan and prepare for 0.30 75.00

production to plaintiff.

JAT Email correspondence with Christine re checks; email correspondence with Seibert re 0.30 75.00

checks and his additional requests.

ASL Continue research and draft memo 5.00 200.00

2/16/2015 JAT Email correspondence with Seibert re settlement; email from Christine re 0.20 50.00

correspondence with Brian at Wells Fargo; tel conf with Christine.

2/17/2015 ASL Begin research on possession issue 1.00 40.00

2/18/2015 JAT Scheduling conference with Judge Aiken. 0.30 75.00

JAT Email correspondence with Seibert re settlement conference with Judge Coffin. 0.20 50.00

JAT Receipt and review of scheduling order from court, re settlement conf; email to 0.20 50.00

Christine.

2/19/2015 ASL Finish research and write memo on possession issue 1.50 60.00

2/25/2015 JAT Receipt and review of notice of subpoeanas to US Bank, State Farm and 4 other 0.20 50.00

parties.

2/27/2015 JAT Receipt and review of letter from Seibert enclosing Motion to File First Amended 0.20 50.00

complaint.

JAT Review First Amended Complaint and attached Motion (42 pgs). 0.40 100.00

3/3/2015 JAT Receipt and review of redllined amended complaint from plaintiff's attorney; review new 0.50 125.00

RICO claims and other claims; email to Christine.

JAT Tel conf with Seibert re conferring on motion to file amended complaint. 0.30 75.00

3/11/2015 JAT Receipt and review of plaintiff's motion for leave to file amended complaint. 0.20 50.00

JAT Research and prepare confidential mediation statement for Judge Coffin, in preparation 3.00 750.00

for settlement conf.

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

EXHIBIT 2 

Page 4 of 6
Christine Jordan Page 5

Hours Amount

3/18/2015 JAT Attend settlement conference with Judge Coffin in Eugene 4.20 1,050.00

3/19/2015 JAT Email correspondence with Christine re conversations with Rafeal; questions 0.30 75.00

comments about settlement conference with Coffin.

3/20/2015 JAT Tel conf with Rafael re meeting; tel conf with Will Fallon re case status, status of east 0.50 125.00

coast cases; strategy.

3/23/2015 JAT Office conf with Rafael and Will Fallon (by phone), re background with Burt and 1.30 325.00

possible strategies to resolve case.

JAT Review of complaint and 2010 settlement agreement in light of info from Raf; outline 0.50 125.00

factual inconsistencies and errors; email to Christine.

3/24/2015 JAT Discussion with Jim re discovery issues, options for responding to amended complaint 0.60 150.00

and strategy; research re federal case law and good faith requirement in pleadings.

JAT Receipt and review of Plaintiff's second request for production of documents. 0.20 50.00

JAT Review FRCP and caselaw re permissible purposes of motion to strike. 0.70 175.00

4/1/2015 JAT Prepare defendants first request for production to plaintiff; prepare first request for 0.70 175.00

admissions.

4/7/2015 JAT Tel conf with Christine re plaintiff's second RFP. 0.60 150.00

4/16/2015 JAT Prepare response to plaintiff's second request for production; email to Silver. 0.50 125.00

4/17/2015 ASL Begin research on tax return issue 1.50 60.00

4/20/2015 JAT Tel conf with Jason Seibert re discovery issues and his threats to file various motions. 0.30 75.00

JAT Receipt and review of plaintiff's First Amended Complaint and exhibits (200 pgs). 0.20 50.00

4/21/2015 ASL Continue research on tax return issue 1.50 60.00

JAT Review Response to RRFP; email correspondence with Jason re his accusation that 0.30 75.00

we did not respond.

JAT Email correspondence with Seibert re confirmation of issues discussed; reciting our 0.50 125.00

objections to discovery requests and his threats to file motion to compel.

JAT Letter to Seibert and Silver enclosing copies of Wells Fargo checks. 0.30 75.00

4/23/2015 ASL Finalize research and draft memo for Jeff 1.00 40.00

4/27/2015 JAT Receipt and review of plaintiff's Motion to Compel Production and supporting 0.40 100.00

declaration.

4/28/2015 JAT Review of amended complaint and detail issues for FRCP 11 violations; email to 1.80 450.00

Seibert detailing issues and request to confer before filing motions.

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

EXHIBIT 2 

Page 5 of 6
Christine Jordan Page 6

Hours Amount

5/4/2015 JAT Email correspondence with Jason re further attempt to confer on motions. 0.20 50.00

5/8/2015 JAT Review and respond to email from Siebert re motion to strike. 0.30 75.00

JAT Research and prepare Defendant's Response to Motion to Compel; prepare Jordan 5.30 1,325.00

Declaration; Trautman Declaration; file with court.

5/11/2015 JAT Email correspondence with Christine re status and requesting docs from Wells Fargo. 0.20 50.00

For professional services rendered 65.30 $13,805.00

Accounts receivable transactions

7/31/2014 Invoice No. 23136 23136 $2,050.00

8/7/2014 Payment from Trust - Thank You ($2,050.00)

8/31/2014 Invoice No. 23315 23315 $1,150.00

9/9/2014 Payment from Trust- Thank You ($1,150.00)

9/30/2014 Invoice No. 23505 23505 $325.00

10/9/2014 Payment from Trust - Thank You ($325.00)

10/31/2014 Invoice No. 23624 23624 $125.00

11/6/2014 Payment from Trust- Thank You ($125.00)

11/30/2014 Invoice No. 23844 23844 $325.00

12/4/2014 Payment from Trust- Thank You ($325.00)

12/31/2014 Invoice No. 24088 24088 $475.00

1/14/2015 Payment from Trust- Thank You ($475.00)

1/31/2015 Invoice No. 24204 24204 $1,300.00

2/6/2015 Payment From Trust- Thank You ($1,300.00)

2/28/2015 Invoice No. 24341 24341 $1,920.00

3/4/2015 Payment from Trust- Thank You ($250.00)

3/31/2015 Invoice No. 24660 24660 $3,075.00

4/10/2015 Payment from Trust - Thank You ($4,000.00)

4/30/2015 Invoice No. 24861 24861 $1,560.00

5/26/2015 Payment - Thank You No. 892 ($2,000.00)

5/31/2015 Invoice No. 25035 25035 $1,500.00

Total payments and adjustments $1,805.00

Client funds transactions

New balance of Default $0.00

Our terms are NET DUE ON RECEIPT- a service charge of 1 1/2% per month will be charged on accounts 30 days or more past due

PLEASE make your check payable to FETHERSTON EDMONDS, LLP and write the ACCOUNT NUMBER ON YOUR CHECK

EXHIBIT 2 

Page 6 of 6