Case 9:08-bk-11457-PC Doc 4191 ... - Omni Agent Solutions

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Vernon Calder Berkeley Research Group, LLC 201 South Main, Suite 450 Salt Lake City, UT 84111 Telephone No. (801) 321-0053 Facsimile No. (385) 218-5914

Accountants for the Chapter 11 Trustee

UNITED STATES BANKRUPTCY COURT

CENTRAL DISTRICT OF CALIFORNIA

NORTHERN DIVISION

In re: ESTATE FINANCIAL, INC., Debtor. _______________________________

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Case No.: 9:08-bk-11457 PC Chapter 11 TENTH INTERIM AND FINAL APPLICATION OF BERKELEY RESEARCH GROUP, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES AS ACCOUNTANTS TO THOMAS P. JEREMIASSEN, CHAPTER 11 TRUSTEE; DECLARATION OF VERNON CALDER; DECLARATION OF THOMAS P. JEREMIASSEN, TRUSTEE, IN SUPPORT THEREOF Date: February 15, 2017 Time: 10:00 a.m. Place: Courtroom 201 1415 State Street Santa Barbara, CA 93101Judge: Honorable Peter Carroll

TO THE HONORABLE PETER CARROLL, UNITED STATES BANKRUPTCY JUDGE;

EFI CREDITORS’ COMMITTEE; AND THE OFFICE OF THE UNITED STATES

TRUSTEE:

Berkeley Research Group, LLC (“BRG” or the “Applicant”)

hereby applies for compensation and reimbursement of expenses as

accountants for Thomas P. Jeremiassen, Chapter 11 Trustee (the

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Case 9:08-bk-11457-PC Doc 4191 Filed 01/25/17 Entered 01/25/17 15:57:49 Desc Main Document Page 1 of 85

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“Trustee”) of Estate Financial, Inc. (“EFI” or the “Debtor”),

and respectfully represent:

I.

INTRODUCTION

BRG respectfully applies under 11 U.S.C. §§ 330, 331,

503(b), and 507(a)(2) and Local Bankruptcy Rule 2016-1, for

final allowance and payment of compensation for accounting and

financial services rendered and reimbursement of expenses

incurred from March 1, 2011 through November 20, 2016 (the

“Application”).

1. BRG was employed as the successor accountants for the

Trustee effective March 1, 2011, pursuant to court order entered

on May 31, 2011.

2. BRG previously requested compensation in this case

through its first interim application for the period March 1,

2011, through April 30, 2011 ("First Interim Period"). BRG

incurred total fees in the amount of $83,216.00 representing

325.60 hours of services to the Estate for which it sought full

interim approval and payment. BRG did not advance expenses for

the First Interim Period related to its services rendered.

3. Pursuant to the Order Granting the Various Interim

Applications of Professionals for Compensation and Reimbursement

of Expenses, BRG was allowed $83,216.00 in fees and $0 in

expenses for a total of $83,216.00. As of the date of this

application, BRG has been paid a total of $83,216.00.


through its second interim application for the period May 1,

2011, through November 30, 2011 ("Second Interim Period"). BRG

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interim approval and payment. BRG also advanced expenses for

the Second Interim Period related to its services in the amount

of $205.63 for which it sought full interim approval and

reimbursement. The total for both fees and expenses was

$210,722.13.



of Expenses, BRG was allowed $210,516.50 in fees and $205.63 in




through its third interim application for the period December 1,

2011, through May 31, 2012 ("Third Interim Period"). BRG




the Third Interim Period related to its services in the amount



$199,430.54.



of Expenses, BRG was allowed $198,844.00 in fees and $586.54 in



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8. BRG has previously requested compensation in this case

through its fourth interim application for the period June 1,

2012, through November 30, 2012 ("Fourth Interim Period"). BRG




the Fourth Interim Period related to its services in the amount



$150,208.90.

9. Pursuant to the Order Granting the Various Interim and

Final Applications of Professionals for Compensation and

Reimbursement of Expenses dated February 14, 2013, BRG was

allowed $150,106.50 in fees and $102.40 in expenses for a total

of $150,208.90. As of the date of this application, BRG has

been paid a total of $150,208.90.


through its fifth interim application for the period December 1,

2012, through July 31, 2013 ("Fifth Interim Period"). BRG




the Fifth Interim Period related to its services in the amount



$208,797.90.



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Reimbursement of Expenses dated September 16, 2013, BRG was





through its sixth interim application for the period August 1,

2013, through February 28, 2014 ("Sixth Interim Period"). BRG




the Sixth Interim Period related to its services in the amount



$108,419.67.



Reimbursement of Expenses dated June 13, 2014, BRG was allowed

$108,054.00 in fees and $365.67 in expenses for a total of

$108,419.67. As of the date of this application, BRG has been

paid a total of $108,419.67.


through its seventh interim application for the period March 1,

2014, through October 31, 2014 ("Seventh Interim Period"). BRG




the Seventh Interim Period related to its services in the amount


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$127,421.21.



Reimbursement of Expenses dated December 18, 2014, BRG was





through its eighth interim application for the period November

1, 2014, through May 31, 2015 ("Eighth Interim Period"). BRG



interim approval and payment. BRG also advanced expenses for the

Eighth Interim Period related to its services in the amount of

$2,835.09 for which it sought full interim approval and


$106,988.59.

15. Pursuant to a stipulation with the U.S. Trustee, BRG

agreed to be approved and paid on an interim basis fees equal to

80% of the requested fees and 100% of the requested

reimbursement of expenses incurred during the Eight Interim

Period, with BRG preserving all rights to seek approval and

payment of the remaining 20% of the requested fees in a

subsequent application. Pursuant to the Order Granting the

Various Interim and Final Applications of Professionals for

Compensation and Reimbursement of Expenses dated August 6, 2015,

BRG was allowed $83,322.80 in fees and $2,835.09 in expenses for

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a total of $86,157.89. As of the date of this application, BRG

has been paid a total of $86,157.89.


through its ninth interim application for the period June 1,

2015, through December 31, 2015 ("Ninth Interim Period"). BRG



interim approval and payment. BRG also advanced expenses for the

ninth interim period related to its services in the amount of

$831.92 for which it sought full interim approval and


$76,774.92.



Reimbursement of Expenses dated March 14, 2016, BRG was allowed

$75,943.00 in fees and $831.92 in expenses for a total of

$76,774.92. As of the date of this application, BRG has been

paid a total of $76,774.92.

18. During the period covered by this Application, January

1, 2016 through November 20, 2016 (“Tenth Interim Period”), BRG


267.70 hours of services to the Estate for which it seeks final

approval and payment. BRG also advanced expenses for the Tenth

and Final Reporting Period related to its services in the amount

of $299.79 for which it seeks final approval and reimbursement.

The total for both fees and expenses is $87,022.29.

The following table summarizes, for each interim period,

the amounts that BRG applied for, amounts that were previously

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approved on an interim basis and paid to BRG, and amounts

currently owed to BRG:

Interim Applied For Previously Approved/Paid Owed

Period Fees Expenses Fees Costs Fees Costs

First $83,216.00 $0.00 $83,216.00 $0.00 $0.00 $0.00

Second 210,516.50 205.63 210,516.50 205.63 0.00 0.00

Third 198,844.00 586.54 198,844.00 586.54 0.00 0.00

Fourth 150,106.50 102.40 150,106.50 102.40 0.00 0.00

Fifth 208,464.20 333.70 208,464.20 333.70 0.00 0.00

Sixth 108,054.00 365.67 108,054.00 365.67 0.00 0.00

Seventh 126,859.00 562.21 126,859.00 562.21 0.00 0.00

Eighth 104,153.50 2,835.09 83,322.80 2,835.09 20,830.70 0.00

Ninth 75,943.00 831.92 75,943.00 831.92 0.00 0.00

Tenth 86,722.50 299.79 0.00 0.00 86,722.50 299.79

Totals $1,352,879.20 $6,122.95 $1,245,326.00 $5,823.16 $107,553.20 $299.79

By way of this Application, BRG seeks:

1) Final allowance of compensation for fees incurred

during the First through Tenth Interim Periods, or

$1,352,879.20, of which $1,245,326.00 has been previously

allowed on an interim basis and paid to BRG;

2) Approval for payment to BRG of fees not previously

allowed on an interim basis, or $107,553.20;

3) Final allowance of reimbursement of expenses incurred

by BRG during the First through Tenth Interim Periods, or

$6,122.95, of which $5,823.16 has been previously allowed on an

interim basis and paid to BRG; and

4) Approval for payment to BRG for reimbursement of

expenses not previously allowed on an interim basis, or $299.79.

A. Exhibits to this Application

1. The nature and extent of BRG services during the Tenth

Interim Period are described in subsequent paragraphs and in the

following exhibits to this Application:

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Exhibit “A” is a copy of the Order Approving Application of

Chapter 11 Trustee to Employ Berkeley Research Group, LLC, of

which the Trustee is a Director, as Successor Accountants,

Effective as of March 1, 2011 (“BRG Employment Order”).

Exhibit "B" is a monthly summary of fees incurred by BRG as

accountants for the Trustee, organized by category of service.

Exhibit "C" is a schedule setting forth the total hours

each professional and paraprofessional has expended for BRG in

this case during the Tenth and Final Period and the hourly rates

for those services.

Exhibit "D" provides the detailed time entries and

descriptions for services provided, organized by category of

service performed. The average hourly billing rate for BRG was

$323.95.

Exhibit "E" is a summary of costs and expenses incurred by

BRG, organized by category of expense.

Exhibit "F" provides a detailed schedule of costs and

expenses incurred by BRG, organized by category of expense.

Exhibit "G" includes the resumes describing the education

and qualifications of the professionals and paraprofessionals

for BRG whose time constitutes a basis for this Application.

Exhibit "H" is a schedule of Applicant’s normal hourly

billing rates during the Tenth and Final Period. These were the

rates charged by Applicant’s personnel to solvent clients for

which Applicant ordinarily receives payment in full within less

than 90 days. Applicant carefully reviewed all time charges to

ensure they were reasonable and non-duplicative. Costs and

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disbursements were also reviewed. Time was billed in tenths of

an hour.

2. BRG has reviewed and “written-off” time for service

and expenses which generally may not be billed to bankruptcy

estates. Additionally, BRG has voluntarily removed all travel

time to/from Court, which typically can be billed to bankruptcy

estates at half rates, all travel related expenses incurred by

BRG professionals on this case living outside the Los Angeles,

CA area that would not have normally been incurred by Los

Angeles professionals working on out-of-town engagements, and

has capped hourly rates of its professionals at $500 per hour

based on the guidelines set forth by the Court.

B. Reasonableness of Rates

1. Each year, BRG attempts to gather accurate information

about rates charged by comparable accounting firms for

comparable services to ensure its rates are competitive.

BRG is informed and believes the rates charged by its staff and

accountants are fair and reasonable in light of the rates

charged by comparable firms. By way of example, Mr. Calder has

an hourly rate of $590 (reduced to $500 per hour for this

matter) during the billing period, which is among the highest

rates of any BRG professional whose time is included in this

application. As set forth in Mr. Calder’s resume (Exhibit “G”),

Mr. Calder has over 30 years of public accounting experience.

Applicant is informed and believes professionals at Mr. Calder’s

level at so-called “Big-Four” or equivalent accounting or

consulting firms, with whom Applicant competes, have hourly

rates as high, or higher, than those of Applicant.

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2. During January of each year, BRG revises its billing

rates for new cases accepted thereafter and for pending cases in

the coming year based on facts described above. All services

included in this fee application were billed at the applicable

standard hourly rates.

II.

BACKGROUND FACTS/DESCRIPTION OF SERVICES

A. Case Background

1. The Debtor, EFI, was a private money lender in central

California. EFI had been a licensed real estate brokerage firm

since the late 1980’s according to the prepetition Offering

Circular for EFI and a related entity, Estate Financial Mortgage

Fund, LLC (“EFMF” or the “Fund”). EFI solicited investments

for, arranged and executed, real estate loans secured by first

deeds of trust encumbering commercial and residential real

estate primarily located in California. Investors were placed

by EFI in certain loans pursuant to their investment and were to

receive an assignment of a fractional interest in the underlying

deed of trust. EFI was also the sole manager of the Fund, which

is a California Limited Liability Company organized for the

purpose of creating a pool of investors to invest in these

secured loans arranged by EFI. The Fund had been investing in

EFI arranged and serviced mortgage loans since 2002.

2. Five creditors filed an involuntary petition against

the Debtor on June 25, 2008(“Petition Date”). EFI consented to

the entry of an order for relief under chapter 11 on July 11,

2008 and an order was entered on July 16, 2008 by the United

States Bankruptcy Court for the Central District of California,

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Northern Division (the “Court”). This chapter 11 case is

related to another chapter 11 case pending before this Court,

that of EFMF bankruptcy case 9:08-bk-11535-RR. The EFMF chapter

11 case was filed with the Court on July 1, 2008.

3. On July 25, Thomas P. Jeremiassen was appointed the

chapter 11 trustee for the EFI bankruptcy estate (the “Trustee”)

and Bradley D. Sharp was appointed the chapter 11 trustee for

the EFMF bankruptcy estate (the “EFMF Trustee”)(collectively,

the “Trustees”) by the Court.

4. As of the Petition Date, there were 544 outstanding

loans (including approximately 42 loans for which the underlying

real property had been foreclosed upon or deeded to EFI or its

investors in lieu of foreclosure). All of the remaining loans

were in default and the Trustees worked closely together to

service, foreclose, reconcile, investigate, and liquidate these

loans and underlying real property for the benefit of their

constituencies.

5. These 544 loans were funded with several thousand

direct investments by more than 1,000 individual “direct”

investors and by the Fund, which itself has over 1,500 remaining

investors. The 544 loans had outstanding principal balances

totaling nearly $318 million, of which approximately $151

million was funded by the Fund with the remainder of roughly

$167 million funded by other direct investors as of the

bankruptcy filings.

6. In an effort to minimize duplication of efforts and

maximize efficiency, the Trustee and the EFMF Trustee originally

agreed that LECG, LLC (“LECG”) would be employed as accountants,

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and Development Specialist, Inc. (“DSI”) would be employed as

financial advisors in both chapter 11 bankruptcy cases.

7. LECG was employed as Accountants to the Trustee

effective July 30, 2008, pursuant to the LECG Employment Order.

8. On September 4, 2008, the Office of the United States

Trustee (“OUST”) appointed an official investors’ committee in

the EFMF chapter 11 case.

9. On October 20, 2008, the OUST appointed an official

committee of unsecured creditors in the EFI chapter 11 case.

10. On March 1, 2011, the LECG professionals with primary

responsibility for the EFI and EFMF matters joined BRG. Due to

existing and immediate demands of the case, the BRG

professionals and staff continued to provide services to the

Trustee and submitted an application with the Court to employ

BRG in a role similar to LECG. BRG was employed as Successor

Accountants to the Trustee effective March 1, 2011 pursuant to

the BRG Employment Order.

11. This case had some very challenging and complex issues

for the Trustee which required a significant amount of time to

analyze, reconcile, investigate and resolve in order to

liquidate and ultimately distribute proceeds upon the sale of

real property, including examples listed below:

a. poor real estate and mortgage environment;

b. poor record keeping and documentation;

c. significant number of difficult and complex

legal and accounting issues that have been

identified, including;

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i. various loan layers beginning with an

original land acquisition loan, which many

times were later sub-divided and refinanced

into individual construction loans, and

later refinanced several times;

ii. loans were not properly paid off and

reconveyed upon a refinancing leaving two

competing loans with different investor

groups on the same property;

iii. assignments that were never prepared and/or

recorded with the county, recorded in the

wrong county, recorded using wrong ownership

percentages, remained on title after

investor was paid, prepared using wrong

investor name, recorded within 90-day

preference period, and recorded referencing

wrong instrument and/or document numbers;

iv. numerous loans were fully funded and

periodic loan servicing advances were paid

from both EFI and EFMF for on-going

construction costs and interest payments due

to borrower defaults;

v. numerous transfers made to/from loans to

cover construction costs, interest payments,

lot payoffs, etc. when needed;

vi. circular cash transactions between related

loans, with no real economic substance, to

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transfer investors from old loan to new

refinanced loan;

vii. large number of related party loans and

transactions;

viii.significant number of investor roll-overs to

new loans with or without investor

knowledge;

ix. Fund investments moving in and out of loans

on an “as needed” basis causing fluctuations

in principal balances over loan history.

ix. EFI performed accounting functions for many

of the borrowers including tracking

construction costs and paying vendors and

subcontractors;

x. transaction descriptions are vague,

cryptic, and many times difficult to

decipher;

d. properties are in varying stages of completion;

e. properties span a large geographical area within

California.

12. Ultimately, as of November 21, 2016, the effective

date of the confirmed plan of liquidation proposed by the

Trustee and the EFI Creditors’ Committee, all of the loans were

disposed of, including the sale of properties securing 529 loans

for gross proceeds totaling approximately $94 million. To date,

distributions to investors from the Trustee have totaled

approximately $40 million.

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B. Description of Services

Applicant has been employed to render professional services

to the Trustee which include, without limitation, assisting the

Trustee in the administration of the Estate; preparing Monthly

Operating Reports and other financial reporting as required by

the Bankruptcy Code, the U.S. Trustee or other applicable law;

assisting the Trustee and other professionals employed in the

chapter 11 case with the preparation of required bankruptcy

filings including the Seven-day Package, Top-20 Unsecured

Creditor Listing, Bankruptcy Schedules and Statement of

Financial Affairs; carving out Debtor operations and activity

from Karen Guth and Joshua Yaguda entities and Borrower

transactions and obligations being account for by EFI;

investigating allegations of fraudulent activity; analyzing and

accounting for daily transactions; maintaining post-petition

general ledger; assisting the Trustee in the identification of

assets, including real property, personal property, and causes

of action; performing any necessary tax compliance, planning and

other analysis required by the Trustee to properly administer

the estate; assisting the Trustee in preparations of federal and

state income tax returns for the estate; communicating with

taxing authorities on behalf of the Estate; conducting a massive

loan reconciliation and investigation including analyzing and

reconciling investor accounts, deeds of trust, assignments, loan

and investor payoffs, accrued interest, principal balances, and

loan servicing advances; providing cash tracing and related

forensic accounting; reviewing and maintaining insurance

coverage; preparing claims analysis, reconciliation and

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verification; assisting Trustee with the liquidation of estate

assets and analyses relating to the distribution of proceeds;

investigating potential causes of action; and assisting with

such other accounting services requested by the Trustee.

The details of BRG’s services during the Tenth Interim

Period are included herein as Exhibit "D" and the monthly

summary is provided in Exhibit "B". Without limiting the detail

given in Exhibit "D", the areas of emphasis of work are as

follows:

1. General Accounting (120): Applicant rendered general

accounting services pursuant to the needs of the Estate. For

example, Applicant maintained system for tracking deposits and

allocating to individual properties/loans; reconciled and

recorded activity for on-going post-petition accounts of the

Trustee; paid approved invoices required to maintain and protect

the assets of the Estate; prepared and tracked construction and

loan servicing trust balances by loan; allocated and applied

invoices to specific projects to pay expenses by property/loan;

prepared accruals and journal entries as required; recorded and

allocated professional fees; researched, deposited, prepared

check requests for EFI Trustee for various invoices,

professional fees and expenses, and distribution to investors;

and applied rent and other deposits received on a daily basis.

Additionally, as more and more properties are sold, claims

identified and addressed, and potential distributions analyzed

and made to investors, additional tracking and segregation of

proceeds is required and requested by the EFI Trustee.

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During the Tenth Interim Period, BRG has expended 15.00

hours resulting in fees in the amount of $4,725.00 related to

general accounting issues.

2. Monthly Court Reporting (130): During the time period

covered by this application, Applicant prepared eleven required

Monthly Operating Reports from December 2015 through October

2016. Applicant analyzed the Trustee’s accounting system,

maintained by the Applicant, in order to identify and compile

the Debtor's assets, liabilities, and cash activity to be

reported in the respective Monthly Operating Reports. In

addition, BRG analyzed bank accounts in order to determine asset

values as of the end of each monthly reporting period. As more

properties are sold, the Trustee has established numerous

segregated bank accounts that need to be included in the Monthly

Operating Report. BRG also coordinated the filing of these

Monthly Operating Reports with the U.S. Trustee’s office and

OMNI Management Group.

During the Tenth Interim Period, BRG expended 40.90 hours

resulting in fees in the amount of $12,343.50 related to monthly

court reporting.

3. Loan /Property Analysis & Reconciliations (300 –

354.4): Applicant undertook a massive loan/property analysis

and reconciliation for the 544 outstanding loans at the

direction of the Trustee. This analysis and reconciliation were

an integral part of the liquidation and distribution process.

Each of these loans had its own unique issues needing analysis

and examination prior to the sale of the underlying real

property and distribution of proceeds.

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Applicant has included task codes 3000 through 3544 in this

category as they pertain to the loan/property analysis and

reconciliation project. The 3000 task code pertains to work

performed that could not be allocated to specific loans.

Applicant has attempted to allocate time to specific loans

whenever possible (see task codes 300.1–354.4).

Applicant is utilizing two large databases that it has

developed as part of the massive loan/property analysis and

reconciliation process. Applicant will refer to these databases

as the Loan Tracking Database and the Phase II Loan

Reconciliation Database.

The Loan Tracking Database was developed from a variety of

data sources including data extracted from the Debtor’s loan

servicing software, loan files, preliminary title reports,

closing statements and sale documentation, etc. to analyze and

track the details and information of the 544 outstanding loans.

This database is being utilized for numerous purposes,

including, but not limited to:

A. Phase I Loan Reconciliation – The Phase I loan

reconciliation provides the loan details, calculates the

total amount owed on the loan and identifies the ownership

problems and issues. Below are examples of the information

analyzed and captured in this reconciliation:

i. identification of the loan details and terms

(i.e. interest rates, loan term, original loan amount,

property description, borrower, investors, sold rate,

last interest payment, etc.);

ii. identification of amounts funded by investors;

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iii. calculation of funding percentage of loan by

investor;

iv. verification of funding percentage with

assignments and preliminary title reports;

v. identification of assignment/ownership issues

including non-existent assignments, assignment errors,

and recording issues (some loans have numerous

investors and assignments);

vi. calculation and reconciliation of loan balances,

including the following items:

a. outstanding principal balance;

b. accrued unpaid interest;

c. loan servicing fee;

d. loan servicing advances;

e. late charges;

f. rents received;

g. construction trust balance; and

h. loan servicing trust balance.

B. Sale Procedures Exhibits and Schedules – The Loan

Tracking Database is being utilized to track and query data

to prepare the exhibits and schedules provided to investors

to obtain majority consent, if required, pursuant to the

approved sale procedures. These exhibits and schedules

include information such as:

i. loan number(s) involved;

ii. property description and address;

iii. whether improvements to property have been

completed;

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iv. current recorded holders of loan or property;

v. marketing details/realtors commissions;

vi. proposed buyer;

vii. gross purchase price/comparable property values;

viii.payments from proceeds – closing costs;

ix. loan payoff balance;

x. whether transaction will pay off the loan in full

or will be a short pay;

xi. whether majority action is required;

xii. disbursements to EFI estate for advances and

fees;

xiii.other disbursements;

xiv. net proceeds to EFI trustee for distribution to

co-owners or segregated account; and

xv. a proposed distribution.

C. Sale and Distribution Tracking – The Loan Tracking

Database is also being utilized to track results of the

real property sales upon closing, distributions to

investors, and amounts held by loan, and by investor until

issues are ultimately resolved.

The Trustee, with the assistance of their professionals,

have sold properties or have received loan payoffs secured by

529 loans with gross sales prices totaling approximately $94.2

million to date. The Trustee has distributed through

December 31, 2016, approximately $25.7 million to individual,

“direct” investors, and approximately $14.1 million to EFMF.

The Phase II Loan Reconciliation Database was developed

from a variety of data sources including data extracted from the

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Debtor’s loan servicing software, loan files, bank statements,

deposit detail, check detail, and bank reconciliation

information. This database is being utilized for several

purposes, including, but not limited to:

A. understanding the relationships and transactions

between loans. Many loans originated with a land

acquisition loan, after which, land was subdivided and

individual lot loans were executed. Many of these lot

loans were later refinanced several times.

B. identifying instances where the original loan was not

paid off upon refinancing resulting in competing loans

on the same property.

C. confirming and verifying loan servicing trust balances

by loan.

D. confirming and verifying construction trust balances

by loan.

E. analyzing the detail transactions by loan relating to

investor activity, construction costs, loan

acquisition costs, loan servicer advances, activity

to/from other loans, transfers to/from loan servicing

account, interest payments from borrowers, interest

payments to investors, return of principal payments to

investors, loan fees, etc.

F. identifying and confirming amounts to include in Phase

I Loan Reconciliation.

Applicant has faced a number of challenges extracting,

compiling, and analyzing the loan data in the construction trust

account and loan servicing account by loan number. For example:

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A. Many transaction descriptions prepared by the Debtor

are vague and cryptic, requiring further investigation

in the loan files and documentation.

B. The Debtor’s record keeping and documentation are

poor.

C. Loan servicing trust activity reflected in the trust

module of the Debtor’s loan servicing software does

not distinguish payments to the investors by loan.

These amounts were summarized, paid and recorded on

one check. Applicant’s programmers were able to match

up these checks with another table in the loan

servicing module by check number, however, there were

numerous instances in which the check numbers and

amounts per the loan servicing module did not match

those in the trust module. Applicant was required to

manually review many of these transactions to properly

break amounts out by loan. There are still over 5,000

transactions that have not been allocated to a loan.

As each loan is analyzed prior to sale, some of these

unallocated transactions are identified through the

reconciliation process.

D. On many occasions Applicant is required to analyze the

predecessor loans of the loan being analyzed (loan

acquisition loan, lot loans, and lot refinances) in

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order to understand the transaction flows, investor

makeup, and economic substance of the remaining loan.

To date the Phase II Loan Reconciliation Database consists

of over 150,000 records for the construction trust account and

550,000 for the loan servicing trust. As loans are analyzed the

transactions are categorized and summarized type. The following

are examples of these categories:

i. investor investments;

ii. construction draws and costs;

iii. loan fees;

iv. loan servicer advances;

v. transfers between loan servicing and construction

account;

vi. transfers between other loans;

vii. borrower payments;

viii.investor interest payments; and

iv. investor principal payments;


resulting in fees in the amount of $11,370.00 related to loans,

property analysis and reconciliations.

5. Claims Analysis (400): Applicant reviewed and

analyzed claims database received from Rust Omni, the estate’s

claims agent, analyzed over 3,800 claims filed by vendors,

borrowers, and lenders/investors totaling approximate $1

billion, reconciled amounts with Debtor records and scheduled

claim amounts, performed preliminary reconciliation with Trustee

property sales activity and unsecured claims awarded as a result

of the sale, and assisted counsel with omnibus claims objections

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related to claims filed by investors for whom settlement

agreements have been reached with respect to all investments.

Through November 20, 2016, objections to over 2,000 claims

have been filed and sustained by the Court, resulting in a

reduction of claimed amounts totaling approximately $740

million.


resulting in fees in the amount of $18,250.00 related to claims

analysis.

6. Plan and Disclosure Statement (410): BRG reviewed,

analyzed, and corresponded with the Trustee the various tax

ramifications of proposed Chapter 11 Plan. On October 20, 2016,

on order was entered confirming the third amended plan of

liquidation proposed by the Trustee and the EFI Creditors’

Committee. The confirmed plan went effective on November 21,

2016.


resulting in fees in the amount of $50.00 related to plan and

disclosure statement.

7. Bryan Cave Litigation (610): Applicant performed

analyses to address damage related issues relating pre-petition

actions of the Debtor’s pre-petition legal counsel, Bryan Cave.

Services include the analysis of pre-petition legal fees, cash,

and asset activity involving hundreds of loans, hundreds of

thousands of cash, real estate and construction related activity

involving hundreds of properties from December 2006 through the

bankruptcy petition.

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In addition to the damage analysis, a portion of the

Applicant’s time incurred during this period was with respect to

discovery issues, including review of, responses to, and

coordination of, document production requests received from the

Defendants.


resulting in fees in the amount of $10,709.00 relating to the

Bryan Cave litigation.

8. General Tax Compliance / Planning (700): Applicant

analyzed numerous disbursements related to the sale of REO and

other properties in order to identify investors share of

proceeds, to calculate proceeds due EFI, to identify property

taxes, to identify seller expenses and to determine the proper

reporting of the transaction(s) for the preparation of the 2015

income tax returns. BRG analyzed numerous separate investor

loans related to these real estate transactions in order to

identify investor disbursements, remaining liabilities, if

applicable, and to determine proper income tax reporting.

Applicant also identified allowed deductible expenses related to

these transactions. Applicant prepared detailed work papers to

reconcile the amounts reported on previously prepared Form 1099-

S with the amount of cash received and disbursed. BRG prepared

required 2015 IRS Form(s) 1099S to report distribution of

proceeds from real estate sales to investors. Required 2015 IRS

Form(s) 1099 were provided to investors and to the IRS.

Applicant prepared state minimum tax payment vouchers and

assured that required state minimum tax payments were timely

made.

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BRG analyzed Liquidating Trust Agreement and consulted with

Trustee to insure compliance with established IRS protocol when

drafting the Plan and Liquidating Trust.

BRG consulted with Trustee regarding requirement to issue

IRS Schedule K-1 to S Corporation shareholders.


resulting in fees in the amount of $14,662.50 related to general

tax compliance and planning.

9. Income Tax Return Preparation (710): Applicant

analyzed cash receipts and disbursements in order to identify

taxable receipts, to identify deductible expenditures and to

calculate gross rents received in order to properly prepare the

2015 income tax returns.

BRG prepared balance sheet, income statement and other

supporting work papers for the preparation of the 2015 income

tax returns. Applicant referenced all work papers prior to

submitting for review. Applicant prepared the 2015 federal and

state income tax returns of the debtor. BRG reviewed the

completed income tax returns and related supporting work papers

for completeness and accuracy. Revisions and corrections were

made as was required. Applicant caused that the completed

returns were electronically filed with the proper taxing

authorities.


resulting in fees in the amount of $10,307.50 related to income

tax return preparation.

10. Fee Application Preparation (920): The Applicant

prepared schedules and exhibits detailing its fee and costs

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incurred, prepared narratives, and finalized BRG’s ninth interim

fee application, which requested fees and expenses incurred

during the period June 1, 2015 through December 31, 2015.


resulting in fees in the amount of $3,999.00 related to fee

application preparation.

11. Investor Communications / Inquires (932.5): Applicant

addressed inquiries from investors regarding status of

investment, distributions made, and historical investment

activity.


resulting in fees in the amount of $306.00 related to investor

communications and inquires.

III.

CONCLUSION

1. Applicant believes compensation awarded herein will

account for the quality of services rendered, the complexity of

the issues at hand, the desirability of employment, the results

obtained and the contingency thereof, as well as the actual

hours expended. Applicant believes full payment of its fees is

justified when considered in relation to the benefit of its

work, as described above.

2. No agreement exists between Applicant nor any other

person for the sharing of compensation that is received in

connection with this case, except for the understanding

concerning compensation among its owners/shareholders.

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DECLARATION OF VERNON CALDER

I, Vernon Calder, declare as follows:

1. I am a Certified Public Accountant, Certified

Insolvency and Restructuring Adviser, and a Managing Director in

the firm of Berkeley Research Group, LLC (“BRG”). I have read

the foregoing Tenth Interim and Final Application of Berkeley

Research Group, LLC for Compensation and Reimbursement of

Expenses as Accountants to Thomas P. Jeremiassen, Chapter 11

Trustee (the "Application") and know the contents thereof. I

certify the facts stated therein are true of my own knowledge,

except for those stated upon information and belief, which I

believe to be true.

2. The Application seeks final approval for compensation

totaling $1,352,879.20 for fees incurred by BRG from March 1,

2011, through November 20, 2016, of which $1,245,326.00 was

previously approved on an interim basis and paid to BRG. The

time billed in the Application is based on records kept in the

ordinary course of BRG's business, and it is the customary

practice of the professionals and paraprofessionals to record

their time on a substantially contemporaneous basis.

3. The Application also seeks final approval for

reimbursement of expenses totaling $6,122.05 incurred from March

1, 2011, through November 20, 2016, of which $5,823.16 was

previously approved on an interim basis and paid to BRG. It is

customary for BRG to charge its clients for photocopies at $0.20

per copy. BRG also customarily charges its clients for faxes,

postage, overnight mail, courier services, and other such

expenses at its cost.

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ESTATE FINANCIAL - ACCOUNTANTS TO THE TRUSTEEProfessional ServicesJanuary 1, 2016 - November 20, 2016

CategoryCODE FEE CATEGORIES Jan-16 Feb-16 Mar-16 Apr-16 May-16 Jun-16 Jul-16 Aug-16 Sep-16 Oct-16 Nov-16 Totals Hours

120 General Accounting 724.50 126.00 693.00 661.50 409.50 189.00 315.00 819.00 346.50 252.00 189.00 4,725.00 15.0

130 Monthly Court Reporting 2,173.50 1,059.00 1,059.00 1,437.00 882.00 409.50 1,008.00 819.00 724.50 1,323.00 1,449.00 12,343.50 40.9

300 Loan / Property Analysis & Reconciliations - General 870.00 1,740.00 600.00 210.00 2,460.00 1,320.00 840.00 480.00 1,590.00 870.00 390.00 11,370.00 37.9

400 Claims Analysis 180.00 3,390.00 3,390.00 1,860.00 600.00 1,200.00 100.00 1,380.00 120.00 990.00 5,040.00 18,250.00 60.7

410 Plan and Disclosure Statement - - - - - 50.00 - - - - - 50.00 0.1

610 Bryan Cave Litigation - 2,720.00 - 189.00 1,050.00 - 1,740.00 2,010.00 937.50 922.50 1,140.00 10,709.00 31.5

700 General Tax Compliance / Planning 10,651.00 1,075.50 138.00 241.50 - 783.00 1,673.50 50.00 50.00 - - 14,662.50 43.4

710 Income Tax Return Preparation - - 137.00 - - - 7,003.50 2,800.50 366.50 - - 10,307.50 25.9

920 Fee Application Preparation 3,999.00 - - - - - - - - - - 3,999.00 11.3

932.5 Investor Communications / Inquiries - - - - - - - - - 306.00 - 306.00 1.0

18,598.00$ 10,110.50$ 6,017.00$ 4,599.00$ 5,401.50$ 3,951.50$ 12,680.00$ 8,358.50$ 4,135.00$ 4,663.50$ 8,208.00$ 86,722.50$ 267.70

Expenses AmountData Retieval 26.80 Parking 18.75 Postage 233.30 Shipping 20.94

-

Total 299.79

TOTAL FEES $86,722.50 BRG, LLC Fed ID No. 27-1451273TOTAL HOURS 267.70TOTAL FEES & EXPENSES $87,022.29AVERAGE BILLING RATE $323.95

1

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045


Estate Financial - Accountant to the TrusteeTimekeeper SummaryJanuary 1, 2016 - November 20, 2016

Name Position Rate Year 2016 Hours Amount

Vernon Calder Director $ 500.00 11.40 $ 5,700.00 Paul Shields Director 500.00 5.20 2,600.00 Leif Larsen Senior Managing Consultant 435.00 37.10 16,138.50 Spencer Ferrero Consultant 315.00 53.00 16,695.00 James Armstrong Consultant 300.00 140.00 42,000.00 Laura Kramer Associate 240.00 7.20 1,728.00 Alec Swope Summer Associate 175.00 5.00 875.00 Evelyn Perry Paraprofessional 155.00 3.60 558.00 Kathy McKee Paraprofessional 95.00 0.80 76.00 Victoria Calder Summer Intern 80.00 4.40 352.00

Total Hours & Fees 267.70 86,722.50$

BRG, LLC Fed ID No. 27-1451273

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Estate Financial - Accountant to the TrusteeJanuary 1, 2016 - November 20, 2016

TASK CODE SUMMARYTASK CODE DESCRIPTION

Average Rate HOURS AMOUNT

120 General Accounting 315.00 15.00 4,725.00 130 Monthly Court Reporting 301.80 40.90 12,343.50 300 Loan / Property Analysis & Reconciliations - General 300.00 37.90 11,370.00 400 Claims Analysis 300.66 60.70 18,250.00 410 Plan and Disclosure Statement 500.00 0.10 50.00 610 Bryan Cave Litigation 339.97 31.50 10,709.00 700 General Tax Compliance / Planning 337.85 43.40 14,662.50 710 Income Tax Return Preparation 397.97 25.90 10,307.50 920 Fee Application Preparation 353.89 11.30 3,999.00

932.5 Investor Communications / Inquiries 306.00 1.00 306.00

323.95 267.70 86,722.50


1048


DATE NAME DESCRIPTION HOURS RATE AMOUNT

Re: Estate Financial, Inc.

Service Rendered January 1, 2016 Through November 30, 2016

120.0 General AccountingTask Code:

1/4/2016 Spencer Ferrero Reviewed and analyzed historical water bills for B518-05 per request from new property owner

0.20 315.00 63.00

1/11/2016 Spencer Ferrero Reviewed and analyzed invoices received and check requests in order to update QuickBooks.

0.30 315.00 94.50

1/18/2016 Spencer Ferrero Reviewed and analyzed transfers relating to sales proceeds account in order to update QuickBooks.

0.40 315.00 126.00

1/21/2016 Spencer Ferrero Reviewed and analyzed payments made to Peggy Coffman to identify any uncashed distribution checks.

0.30 315.00 94.50

1/21/2016 Spencer Ferrero Reviewed and analyzed payments made to Blance Bailey to identify any uncashed distribution checks.

0.30 315.00 94.50

1/21/2016 Spencer Ferrero Reviewed and analyzed invoices received to process check requests and update QuickBooks.

0.30 315.00 94.50

1/22/2016 Spencer Ferrero Reviewed and analyzed payments made to Lorraine Alltounian to identify any uncashed distribution checks.

0.20 315.00 63.00

1/26/2016 Spencer Ferrero Reviewed and analyzed check requests and invoices received to update QuickBooks.

0.30 315.00 94.50

2/16/2016 Spencer Ferrero Conversation with James Armstrong regarding QuickBooks entries and making of adjusting entries.

0.20 315.00 63.00

2/29/2016 Spencer Ferrero Reviewed and analyzed invoices received to process check requests and update QuickBooks

0.20 315.00 63.00

3/1/2016 Spencer Ferrero Reviewed and analyzed checks received to process deposit requests and update QuickBooks

0.20 315.00 63.00


0.20 315.00 63.00

3/8/2016 Spencer Ferrero Reviewed and analyzed checks received to process deposit request and update QuickBooks.

0.20 315.00 63.00

3/8/2016 Spencer Ferrero Reviewed and analyzed checks issued to update QuickBooks. 0.20 315.00 63.00

3/22/2016 Spencer Ferrero Reviewed and analyzed professional fee payments to adjust future accruals and update QuickBooks.

0.50 315.00 157.50

3/22/2016 Spencer Ferrero Reviewed and analyzed invoices and checks received in order to process requests and update QuickBooks.

0.40 315.00 126.00


0.30 315.00 94.50


0.20 315.00 63.00

4/7/2016 Spencer Ferrero Reviewed and analyzed transfers involving B575-05 to update QuickBooks.

0.20 315.00 63.00

4/7/2016 Spencer Ferrero Reviewed and analyzed distribution payment made to Kirit Patel per settlement agreement

0.10 315.00 31.50

4/8/2016 Spencer Ferrero Reviewed and analyzed distribution payment made to Kirit Patel per settlement agreement

0.20 315.00 63.00

4/11/2016 Spencer Ferrero Reviewed and analyzed transactions in order to update Sales Proceeds tracking spreadsheet.

0.50 315.00 157.50


0.30 315.00 94.50

4/19/2016 Spencer Ferrero Reviewed and analyzed remaining proceeds in Sales Proceeds account

0.20 315.00 63.00


0.20 315.00 63.00

Page 1 of 12

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4/26/2016 Spencer Ferrero Reviewed and analyzed invoices and check requests in order to update QuickBooks.

0.20 315.00 63.00

4/29/2016 Spencer Ferrero Reviewed and analyzed invoices and check requests in order to update QuickBooks.

0.20 315.00 63.00


0.20 315.00 63.00

5/9/2016 Spencer Ferrero Reviewed QuickBooks to identify professional fees expense. 0.30 315.00 94.50

5/12/2016 Spencer Ferrero Reviewed and analyzed distributions to Michael Donahue. 0.10 315.00 31.50

5/17/2016 Spencer Ferrero Reviewed and analyzed checks received to process deposit requests and update QuickBooks.

0.20 315.00 63.00

5/20/2016 Spencer Ferrero Reviewed and analyzed invoices in order to process check request and update QuickBooks

0.10 315.00 31.50


0.40 315.00 126.00


0.20 315.00 63.00


0.20 315.00 63.00

6/21/2016 Spencer Ferrero Reviewed and analyzed checks paid to update QuickBooks. 0.20 315.00 63.00


0.30 315.00 94.50

7/19/2016 Spencer Ferrero Reviewed and analyzed invoices received to process check request and update QuickBooks.

0.20 315.00 63.00

7/19/2016 Spencer Ferrero Reviewed and analyzed checks received to process deposit requests and update QuickBooks.

0.30 315.00 94.50


0.20 315.00 63.00

8/11/2016 Spencer Ferrero Reviewed and analyzed stopped checks for possible reissuance. 0.20 315.00 63.00


0.30 315.00 94.50


0.20 315.00 63.00

8/16/2016 Spencer Ferrero Prepared checks to pay invoices. 0.80 315.00 252.00

8/16/2016 Spencer Ferrero Reviewed and analyzed checks issued for invoices in order to update QuickBooks.

0.20 315.00 63.00

8/22/2016 Spencer Ferrero Prepared check requests for payment. 0.20 315.00 63.00

8/23/2016 Spencer Ferrero Prepared distribution check from settlement notice. 0.30 315.00 94.50

8/24/2016 Spencer Ferrero Reviewed checks received to process deposit request and update QuickBooks.

0.40 315.00 126.00


0.20 315.00 63.00

9/21/2016 Spencer Ferrero Reviewed and analyzed invoices received in order to update QuickBooks

0.20 315.00 63.00

9/21/2016 Spencer Ferrero Reviewed and analyzed checks issued in order to update QuickBooks. 0.20 315.00 63.00

9/23/2016 Spencer Ferrero Reviewed and analyzed invoices received in order to update QuickBooks

0.20 315.00 63.00

9/29/2016 Spencer Ferrero Reviewed and analyzed total distributions issued to Brad Clark. 0.30 315.00 94.50


0.20 315.00 63.00

Page 2 of 12

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10/20/2016 Spencer Ferrero Reviewed and analyzed sales proceeds transfers in order to update sales proceeds tracking sheet.

0.40 315.00 126.00

10/20/2016 Spencer Ferrero Reviewed and analyzed checks received to process deposit requests and update QuickBooks

0.20 315.00 63.00


0.30 315.00 94.50


0.30 315.00 94.50

Total for Task Code: 15.00120.0 4,725.00General Accounting

130.0 Monthly Court ReportingTask Code:

1/7/2016 Spencer Ferrero Reviewed disbursements and receipts in order to prepare December 2015 monthly operating report.

1.40 315.00 441.00

1/7/2016 Spencer Ferrero Reviewed distributions and tax adjusting entries in order to prepare December 2015 monthly operating report.

1.70 315.00 535.50

1/8/2016 Spencer Ferrero Reviewed distributions and tax adjusting entries in order to prepare December 2015 monthly operating report.

0.30 315.00 94.50

1/8/2016 Laura Kramer Analyzed and reviewed bank statements to confirm and list the balance at 12/31/15 for the creation of the bond status reports.

0.30 240.00 72.00

1/12/2016 Laura Kramer Analyzed and reviewed bank statements to reconcile with ledger reports to create bank reconciliations.

0.50 240.00 120.00

1/12/2016 Laura Kramer Analyzed and reviewed bank statements and bonds to confirm and list the balance at 12/31/15 for the creation of the bond status reports.

0.60 240.00 144.00


0.50 240.00 120.00


0.30 240.00 72.00

1/19/2016 Laura Kramer Analyzed and reviewed bank statements to reconcile with ledger reports to create bank reconciliations for November 2015.

0.70 240.00 168.00

1/20/2016 Laura Kramer Analyzed and reviewed bank statements to reconcile with ledger reports to create bank reconciliations for November 2015.

1.00 240.00 240.00

1/27/2016 Spencer Ferrero Reviewed November 2015 bank reconciliations. 0.30 315.00 94.50

1/28/2016 Laura Kramer Analyzed and reviewed bank statements to reconcile with ledger balance for December 2015 bank reconciliations.

0.30 240.00 72.00

2/9/2016 Spencer Ferrero Prepared January 2016 monthly operating report. 2.40 315.00 756.00

2/17/2016 Spencer Ferrero Prepared January 2016 monthly operating report. 0.20 315.00 63.00

2/23/2016 Laura Kramer Analyzed and reviewed bank statements to reconcile with ledger balance for December 2015 bank reconciliations.

0.50 240.00 120.00

2/24/2016 Laura Kramer Analyzed and reviewed distributions amounts to spot check and confirm amounts matched.

0.50 240.00 120.00

3/7/2016 Spencer Ferrero Prepared February 2016 monthly operating report. 2.40 315.00 756.00

3/8/2016 Spencer Ferrero Reviewed December 2015 bank reconciliations. 0.20 315.00 63.00

3/28/2016 Laura Kramer Analyzed and reviewed bank statement to confirm stale dated check was reversed to complete December 2015 bank reconciliations.

0.30 240.00 72.00

3/30/2016 Laura Kramer Analyzed and reviewed February 2016 bank statements and detailed bank reconciliation reports to reconcile accounts.

0.20 240.00 48.00

3/31/2016 Laura Kramer Analyzed and reviewed January 2016 bank statements and detailed bank reconciliation reports to reconcile accounts.

0.50 240.00 120.00

Page 3 of 12

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4/1/2016 Laura Kramer Analyzed and reviewed February 2016 bank statements and detailed bank reconciliation reports to reconcile accounts.

0.60 240.00 144.00

4/6/2016 Spencer Ferrero Reviewed January 2016 bank reconciliations. 0.30 315.00 94.50

4/11/2016 Spencer Ferrero Reviewed transfers and QuickBooks transactions in order to prepare March 2016 monthly operating report.

1.10 315.00 346.50

4/11/2016 Spencer Ferrero Reviewed receipts and disbursements in order to prepare March 2016 monthly operating report.

2.20 315.00 693.00

4/12/2016 Laura Kramer Analyzed and reviewed bank statements and ledger reports to confirm amounts and prepare the first quarter bond status reports for UST.

0.40 240.00 96.00

4/12/2016 Spencer Ferrero Reviewed February 2016 bank reconciliations. 0.20 315.00 63.00

5/11/2016 Spencer Ferrero Prepared April 2016 monthly operating report. 2.40 315.00 756.00

5/12/2016 Spencer Ferrero Prepared April 2016 monthly operating report. 0.20 315.00 63.00

5/18/2016 Spencer Ferrero Reviewed March 2016 bank reconciliations 0.20 315.00 63.00

6/6/2016 Spencer Ferrero Prepared May 2016 monthly operating report. 1.00 315.00 315.00

6/14/2016 Spencer Ferrero Prepared May 2016 monthly operating report. 0.30 315.00 94.50

7/6/2016 Spencer Ferrero Prepared June 2016 monthly operating report. 2.30 315.00 724.50

7/6/2016 Spencer Ferrero Reviewed April 2016 bank reconciliations. 0.20 315.00 63.00

7/8/2016 Spencer Ferrero Prepared June 2016 monthly operating report. 0.50 315.00 157.50

7/14/2016 Spencer Ferrero Reviewed May 2016 bank reconciliations. 0.20 315.00 63.00

8/2/2016 Spencer Ferrero Reconciled June 2016 bank statements. 0.50 315.00 157.50

8/15/2016 Spencer Ferrero Prepared July 2016 monthly operating report 2.10 315.00 661.50

9/9/2016 Spencer Ferrero Prepared MOR for August 2016 2.10 315.00 661.50

9/30/2016 Spencer Ferrero Reviewed and analyzed August 2016 monthly operating report. 0.20 315.00 63.00

10/3/2016 Spencer Ferrero Reconciled July 2016 bank statements 0.10 315.00 31.50

10/5/2016 Spencer Ferrero Reconciled July 2016 bank statements 0.50 315.00 157.50

10/12/2016 Spencer Ferrero Prepared September 2016 monthly operating report 2.30 315.00 724.50

10/21/2016 Spencer Ferrero Reconciled August 2016 bank statements 0.20 315.00 63.00


10/25/2016 Spencer Ferrero Reconciled September 2016 bank statements 0.30 315.00 94.50


10/26/2016 Spencer Ferrero Reconciled September 2016 bank statements 0.20 315.00 63.00

11/4/2016 Spencer Ferrero Reconciled August and September 2016 bank statements 0.10 315.00 31.50

11/7/2016 Spencer Ferrero Prepared October 2016 monthly operating report. 2.20 315.00 693.00

11/11/2016 Spencer Ferrero Prepared October 2016 monthly operating report. 1.60 315.00 504.00

11/11/2016 Spencer Ferrero Reconciled cash transactions to sales proceeds tracking schedule. 0.70 315.00 220.50

Total for Task Code: 40.90130.0 12,343.50Monthly Court Reporting

300.0 Loan / Property Analysis & Reconciliations - GeneralTask Code:

1/6/2016 James Armstrong Reviewed and processed distributions for settlements signed. 0.40 300.00 120.00


1/14/2016 James Armstrong Reviewed and analyzed balances in the Sales Proceeds banking account.

0.70 300.00 210.00

Page 4 of 12

052








2/2/2016 James Armstrong Reviewed and updated the Exhibit A schedules for loan B575-05. 1.60 300.00 480.00




0.80 300.00 240.00



1.70 300.00 510.00


3/15/2016 James Armstrong Reviewed and analyzed address information for stale distribution checks.

0.90 300.00 270.00


4/4/2016 James Armstrong Reviewed and analyzed the Exhibit A schedules for loan B575-05. 0.50 300.00 150.00

4/5/2016 James Armstrong Reviewed and analyzed the Exhibit A schedules for loan B575-05. 0.20 300.00 60.00

5/5/2016 James Armstrong Reviewed and processed distributions to investors with signed agreements.

0.50 300.00 150.00

5/18/2016 James Armstrong Reviewed and analyzed the loan history for the Goleta related loans. 0.70 300.00 210.00



5/26/2016 James Armstrong Reviewed and analyzed the loan history for the Dorama related loans. 2.30 300.00 690.00




0.90 300.00 270.00




0.50 300.00 150.00

6/28/2016 James Armstrong Reviewed and analyzed signed agreements outstanding. 1.80 300.00 540.00


0.90 300.00 270.00


0.50 300.00 150.00

7/30/2016 James Armstrong Reviewed and analyzed signed agreements outstanding. 1.40 300.00 420.00

8/16/2016 James Armstrong Reviewed and analyzed the distribution schedules for loan B367-05. 0.90 300.00 270.00


0.70 300.00 210.00

9/20/2016 James Armstrong Reviewed and processed ditributions to investors with signed agreements.

0.70 300.00 210.00

9/20/2016 James Armstrong Reviewed and analyzed the Exhibit A schedules for loans B575-05 & B649-05.

0.60 300.00 180.00

Page 5 of 12

053






1.70 300.00 510.00


0.30 300.00 90.00




0.40 300.00 120.00


0.80 300.00 240.00

10/20/2016 James Armstrong Reviewed and processed distibutions to investors with signed agreements.

0.50 300.00 150.00

10/23/2016 James Armstrong Reviewed and processed distributions for proceeds received on loans B575-05 & B649-05.

1.30 300.00 390.00


0.30 300.00 90.00


0.40 300.00 120.00


0.70 300.00 210.00


0.20 300.00 60.00

Total for Task Code: 37.90300.0 11,370.00Loan / Property Analysis & Reconciliations - General

400.0 Claims AnalysisTask Code:

1/17/2016 James Armstrong Reviewed and updated the claim tracking database. 0.30 300.00 90.00





2/19/2016 James Armstrong Reviewed and updated the claim tracking database. 4.20 300.00 1,260.00



3/4/2016 James Armstrong Reviewed and updated the claim objections for signed settlement agreements.

1.70 300.00 510.00


1.30 300.00 390.00

3/11/2016 James Armstrong Reviewed and updated the claim objections for investors with no open investments.

1.10 300.00 330.00

3/15/2016 James Armstrong Reviewed and discussed the claim objections with EFI counsel. 0.80 300.00 240.00


0.70 300.00 210.00




0.70 300.00 210.00

Page 6 of 12

054






1.50 300.00 450.00


0.40 300.00 120.00

4/11/2016 James Armstrong Reviewed and analyzed remaining claims in the EFI estate. 0.30 300.00 90.00


0.30 300.00 90.00




0.60 300.00 180.00

5/12/2016 James Armstrong Reviewed and analyzed claims due to signed settlement agreements. 0.20 300.00 60.00

5/16/2016 James Armstrong Reviewed and analyzed the claims for lender L686. 0.50 300.00 150.00



6/14/2016 James Armstrong Reviewed and analyzed the claims filed for specific lenders. 2.60 300.00 780.00



7/8/2016 Vernon Calder Analyzed issues regarding determination of whether certain property tax claims have priority status.

0.20 500.00 100.00

8/4/2016 James Armstrong Reviewed and analyzed investor claims filed against EFI. 0.80 300.00 240.00








11/2/2016 James Armstrong Reviewed and analyzed the EFMR claim amount against the EFI estate.

2.10 300.00 630.00




11/9/2016 James Armstrong Reviewed and analyzed the EFMF claim amount against the EFI 2.10 300.00 630.00

11/15/2016 James Armstrong Reviewed and analyzed omnibus claims objections and updated tracking sheet.

2.00 300.00 600.00


1.40 300.00 420.00


2.00 300.00 600.00

Total for Task Code: 60.70400.0 18,250.00Claims Analysis

410.0 Plan and Disclosure StatementTask Code:

Page 7 of 12

055





6/30/2016 Vernon Calder Analyzed issues regarding creation of Disputed Ownership Fund in conjunction with creation of Liquidating Trust.

0.10 500.00 50.00

Total for Task Code: 0.10410.0 50.00Plan and Disclosure Statement

610.0 Bryan Cave LitigationTask Code:

2/18/2016 Paul Shields Updated damage calculation and developed preliminary narrative. 3.30 500.00 1,650.00

2/19/2016 Paul Shields Prepared for and met with counsel and trustees regarding assessment of damages and disclosures.

1.70 500.00 850.00

2/22/2016 Paul Shields Reviewed damage model. 0.20 500.00 100.00

2/25/2016 James Armstrong Reviewed and analyzed issues related to the Bryan Cave Damages. 0.40 300.00 120.00

4/4/2016 Spencer Ferrero Reviewed and analyzed documents requested for review related to Bryan Cave litigation.

0.60 315.00 189.00

5/5/2016 James Armstrong Reviewed and analyzed investor detail for the Bryan Cave damage schedules.

2.30 300.00 690.00

5/9/2016 James Armstrong Reviewed and analyzed investor detail for the Bryan Cave damage schedules.

1.20 300.00 360.00

7/21/2016 James Armstrong Reviewed and analyzed document requests related to the Bryan Cave matter.

1.00 300.00 300.00


1.90 300.00 570.00

7/25/2016 James Armstrong Reviewed and discussed document requests related to the Bryan Cave matter.

0.90 300.00 270.00


0.90 300.00 270.00


1.10 300.00 330.00

8/23/2016 James Armstrong Reviewed and analyzed the Request for Admissions related to the Bryan Cave matter.

0.20 300.00 60.00

8/25/2016 James Armstrong Reviewed and discussed the Request for Admissions related to the Bryan Cave matter with the Trustee.

0.40 300.00 120.00


2.10 300.00 630.00

8/26/2016 James Armstrong Reviewed and discussed the Request for Admissions related to the Bryan Cave matter with the Trustee.

1.50 300.00 450.00


1.90 300.00 570.00


0.60 300.00 180.00

9/6/2016 James Armstrong Reviewed and analyzed the request for admissions related to the Bryan Cave matter.

0.70 300.00 210.00

9/8/2016 James Armstrong Reviewed and analyzed the request for admissions related to the Bryan Cave matter with the Trustee.

0.20 300.00 60.00


1.70 300.00 510.00

9/30/2016 Spencer Ferrero Reviewed and analyzed documents in preparation for Bryan Cave document production request

0.50 315.00 157.50

10/5/2016 Leif Larsen Analyzed historical tax records for 2007 through 2015 in order to secure documents requested by Bryan Cave.

1.50 435.00 652.50


0.90 300.00 270.00

Page 8 of 12

056






1.80 300.00 540.00


2.00 300.00 600.00

Total for Task Code: 31.50610.0 10,709.00Bryan Cave Litigation

700.0 General Tax Compliance / PlanningTask Code:

1/6/2016 Leif Larsen Analyzed records on hand and requested additional information needed for 2015 tax work.

0.20 435.00 87.00

1/8/2016 Leif Larsen Reviewed 2014 Forms 1099-S and requested additional information needed for the preparation of 2015 returns.

0.40 435.00 174.00

1/11/2016 James Armstrong Reviewed and analyzed disbursements to investors for the 1099-S. 2.50 300.00 750.00

1/11/2016 Leif Larsen Followed up on information needed for 2015 1099-S work. 0.40 435.00 174.00

1/14/2016 Leif Larsen Analyzed 2015 transaction ledgers and prepared required 2015 Forms 1099-Misc.

2.70 435.00 1,174.50

1/15/2016 Spencer Ferrero Reviewed and analyzed payees to send W-9 forms per tax department request.

0.20 315.00 63.00

1/15/2016 Leif Larsen Cleared review notes related to the 2015 1099 returns. 0.40 435.00 174.00

1/15/2016 Vernon Calder Analyzed 2015 financial activity in conjunction with preparation of IRS Form(s) 1099.

0.60 500.00 300.00

1/15/2016 Vernon Calder Reviewed 2015 IRS Form(s) 1099. 0.20 500.00 100.00

1/15/2016 Alec Swope Prepared W-9 request letter for mailing. 0.30 175.00 52.50

1/15/2016 Vernon Calder Reviewed corrections made to 2015 IRS Form(s) 1099. 0.20 500.00 100.00



1/18/2016 James Armstrong Reviewed and updated the schedule of 2015 disbursements for the 1099-S.

1.30 300.00 390.00

1/18/2016 Leif Larsen Reviewed 2015 transaction ledgers in order to identify required 1099-S recipients.

0.50 435.00 217.50

1/19/2016 James Armstrong Reviewed and updated the schedule of 2015 disbursements for the 1099-S.

1.40 300.00 420.00


1/19/2016 Victoria Calder Analyzed 2015 transaction ledgers in conjunction with preparation of IRS Form(s) 1099.

0.30 80.00 24.00

1/20/2016 Vernon Calder Reviewed 2015 IRS Form(s) 1099S to be issued to recipients of real estate proceeds.

2.60 500.00 1,300.00

1/20/2016 Vernon Calder Reviewed corrections to 2015 IRS Form(s) 1099. 0.30 500.00 150.00

1/20/2016 Leif Larsen Prepared over 2015 Form(s) 1099-S. 3.80 435.00 1,653.00

1/21/2016 Leif Larsen Cleared review notes related to 2015 Form(s) 1099-S and corresponding work papers and updated Forms with new information received.

2.30 435.00 1,000.50

1/22/2016 Alec Swope Prepared and printed 1099's for mailing. 0.50 175.00 87.50

1/25/2016 Vernon Calder Verified corrections made to 2015 IRS Form(s) 1099S. 0.30 500.00 150.00

1/28/2016 Victoria Calder Analyzed 2015 transaction ledgers in conjunction with preparation of IRS form(s) 1099.

0.20 80.00 16.00

1/29/2016 Leif Larsen Reviewed 2015 1099-S files and instructed tax staff on preparation and distribution.

0.40 435.00 174.00

Page 9 of 12

057





1/29/2016 Alec Swope Prepared 1099-S for mailing. 3.50 175.00 612.50

1/29/2016 Evelyn Perry Prepared 2015 Forms 1099-S for mailing. 3.40 155.00 527.00

2/2/2016 Leif Larsen Reviewed finalized 2015 1099s to ensure proper distribution. 0.20 435.00 87.00


2/23/2016 Leif Larsen Reviewed 1099-S supporting work papers to ensure accuracy prior to electronically filing returns.

0.40 435.00 174.00

2/25/2016 Leif Larsen Electronically filed the 2015 Forms 1096/1099-S. 0.40 435.00 174.00

2/25/2016 Leif Larsen Electronically filed the 2015 Forms 1096/1099-Misc for EFI. 0.30 435.00 130.50

3/17/2016 Victoria Calder Prepared 2016 California minimum tax payment vouchers. 0.30 80.00 24.00

3/22/2016 Victoria Calder Prepared 2016 California minimum tax payment tax vouchers. 0.30 80.00 24.00

3/29/2016 Victoria Calder Prepared 2016 California minimum tax payment vouchers. 0.30 80.00 24.00

3/30/2016 Vernon Calder Reviewed request for 2016 California Minimum Tax payments. 0.10 500.00 50.00

3/30/2016 Victoria Calder Updated 2015 tax files with current information. 0.20 80.00 16.00

4/1/2016 Alec Swope Filed tax documents into corresponding folders. 0.70 175.00 122.50

4/4/2016 Leif Larsen Reviewed 2016 check requests and distributed to trustee's office. 0.20 435.00 87.00

4/7/2016 Victoria Calder Updated electronic tax files. 0.20 80.00 16.00

4/11/2016 Victoria Calder Updated California minimum tax payments. 0.20 80.00 16.00

6/28/2016 Leif Larsen Analyzed liquidating trust agreement and participated in conference call.

1.10 435.00 478.50

6/29/2016 Leif Larsen Prepared for and participated in conference call regarding liquidating trust agreement.

0.70 435.00 304.50

7/8/2016 Leif Larsen Analyzed property tax claims in order to determine status. 0.40 435.00 174.00

7/11/2016 Vernon Calder Reviewed tax research regarding requirement to issue Schedule K to S Corporation shareholders.

0.30 500.00 150.00

7/12/2016 Vernon Calder Performed tax research regarding a receiver's responsibility to file income tax returns. This analysis was done in conjunction with the question of to whom should Schedule K-1 from EFI be issued.

0.60 500.00 300.00

7/20/2016 Leif Larsen Prepared for and participated in conference call regarding ownership interest in EFI.

0.30 435.00 130.50

7/20/2016 Vernon Calder Discussed via telephone with Trustee regarding whether equity interest in EFI was transferred to Receiver.

0.20 500.00 100.00

7/20/2016 Spencer Ferrero Reviewed and analyzed QuickBooks to export 2015 financial data for tax return purposes

0.70 315.00 220.50

7/21/2016 Spencer Ferrero Reviewed and analyzed bank statements relating to loan servicing and construction accounts per tax department request.

0.20 315.00 63.00

7/22/2016 Spencer Ferrero Reviewed and analyzed loan servicing and construction account transactions to update corresponding QuickBooks per tax department.

1.70 315.00 535.50

8/31/2016 Vernon Calder Reviewed and approved correspondence to be provided to Josh Yaguda regarding issuance of Schedule K-1.

0.10 500.00 50.00

9/2/2016 Vernon Calder Analyzed IRS efile rejection. 0.10 500.00 50.00

Total for Task Code: 43.40700.0 14,662.50General Tax Compliance / Planning

710.0 Income Tax Return PreparationTask Code:

3/3/2016 Vernon Calder Reviewed 2015 IRS Form 7004, Application for Automatic Extension of Time to File Certain Business Income Tax Returns.

0.10 500.00 50.00

3/15/2016 Leif Larsen Prepared federal extension for filing. 0.20 435.00 87.00

Page 10 of 12

058





7/20/2016 Leif Larsen Analyzed 2015 QuickBooks statements and prepared balance sheet and other supporting work papers to be used in conjunction with the preparation of the 2015 income tax returns.

2.50 435.00 1,087.50

7/21/2016 Leif Larsen Analyzed 2015 QuickBooks statements and prepared income statement and other supporting work papers to be used in conjunction with the preparation of the 2015 income tax returns.

2.30 435.00 1,000.50

7/22/2016 Leif Larsen Prepared additional supporting work papers to be used in conjunction with the preparation of the 2015 income tax returns.

1.60 435.00 696.00

7/22/2016 Leif Larsen Analyzed 2015 general ledgers and prepared analysis of gross receipt and reconciliation schedules to reconcile with income reported.

2.90 435.00 1,261.50

7/26/2016 Leif Larsen Prepared the 2015 federal income tax return. 2.70 435.00 1,174.50

7/27/2016 Leif Larsen Reviewed and referenced the 2015 income tax returns and supporting work papers.

1.90 435.00 826.50

7/27/2016 Leif Larsen Prepared the 2015 California income tax return. 2.20 435.00 957.00

8/11/2016 Vernon Calder Reviewed 2015 income tax returns and related tax file. 2.00 500.00 1,000.00

8/11/2016 Leif Larsen Cleared review notes related to the 2015 income tax returns. 1.60 435.00 696.00

8/12/2016 Vernon Calder Verified clearance of review notes on 2015 income tax returns and related tax file.

0.80 500.00 400.00

8/12/2016 Leif Larsen Made revisions to required footnotes included in the 2015 EFI income tax returns.

0.70 435.00 304.50

8/15/2016 Victoria Calder Prepared 2015 tax return to send to taxing authorities. 1.40 80.00 112.00

8/15/2016 Vernon Calder Performed final review and signed 2015 income tax returns. 0.30 500.00 150.00

8/16/2016 Evelyn Perry Sent tax returns to trustee. 0.20 155.00 31.00

8/25/2016 Katherine McKee Prepared and mailed tax returns to taxing authorities. 0.40 95.00 38.00


8/31/2016 Vernon Calder Finalized 2015 income tax returns. 0.10 500.00 50.00

9/1/2016 Leif Larsen Electronically filed the 2015 EFI income tax returns and reviewed diagnostic failures.

0.50 435.00 217.50

9/2/2016 Vernon Calder Discussed via telephone with Tom Jeremiassen regarding IRS rejection of efiled 2015 tax return. Discussed need to paper file the tax return.

0.10 500.00 50.00

9/6/2016 Victoria Calder Prepared 2015 tax return to send to taxing authorities. 1.00 80.00 80.00


Total for Task Code: 25.90710.0 10,307.50Income Tax Return Preparation

920.0 Fee Application PreparationTask Code:

1/7/2016 James Armstrong Reviewed and analyzed data for the ninth interim fee application. 1.80 300.00 540.00



1/18/2016 Leif Larsen Reviewed time entry descriptions and prepared tax narrative for upcoming fee application.

1.40 435.00 609.00



1/19/2016 Vernon Calder Reviewed and revised Ninth Interim Fee Application. 1.50 500.00 750.00

1/19/2016 Vernon Calder Reviewed, revised and signed Ninth interim fee application. 0.60 500.00 300.00

Page 11 of 12

059





Total for Task Code: 11.30920.0 3,999.00Fee Application Preparation

932.5 Investor Communications / InquiriesTask Code:

10/8/2016 James Armstrong Reviewed and responded to request for information from investors. 0.60 300.00 180.00

10/17/2016 Spencer Ferrero Correspondence with Winnojean Eberle regarding status of distribution check.

0.40 315.00 126.00

Total for Task Code: 1.00932.5 306.00Investor Communications / Inquiries

Total Professional Services 267.70 86,722.50

Page 12 of 12

060


061


- Estate Financial - Accountant to the TrusteeJanuary 1, 2016 - November 20, 2016

Expense Category Amount

Data Retieval 26.80$ Parking 18.75 Postage 233.30 Shipping 20.94

Total Expenses Due 299.79$


062


063


DATE NAME DESCRIPTION AMOUNT


Expenses from January 1, 2016 Through November 30, 2016

Data Retrieval CATEGORY:

4/14/2016 BRG TLO Research 10.00




10/14/2016 BRG CCH Research 12.80

26.80Data RetrievalTOTAL:

Express Messenger/Shipping CATEGORY:

8/31/2016 BRG Shipping - FedEx 10.50

9/22/2016 BRG Shipping - FedEx 10.44

20.94Express Messenger/ShippingTOTAL:

Postage CATEGORY:

1/31/2016 BRG Postage 0.96

1/31/2016 BRG Postage 209.04

8/31/2016 BRG Postage 0.94

8/31/2016 BRG Postage 1.88

8/31/2016 BRG Postage 20.48

233.30PostageTOTAL:

Travel - Parking CATEGORY:

2/29/2016 BRG Parking 18.75

18.75Travel - ParkingTOTAL:

299.79TOTAL EXPENSES

Page 1 of 1

064


065


9/21/2015 www.thinkbrg.com Page 1 of 3

Vernon L. Calder, Managing Director 201 South Main Street, Suite 450 Salt Lake City, UT 84111 Direct: 801.321.0053 Fax: 801.364.6230 Email: [email protected] Summary Vernon L. Calder, a Director with Berkeley Research Group (“BRG”), has over thirty years of experience in public accounting specializing in tax services. Mr. Calder is a Certified Public Accountant (CPA) and a Certified Insolvency and Reorganization Advisor (CIRA). For the last over twenty years he has specialized in bankruptcy tax compliance and planning. Prior to joining BRG Vernon was a director of LECG, LLC (“LECG”), which acquired Neilson Elggren LLP (“NE”) in 2005. Prior to the acquisition of NE by LECG, Mr. Calder was the Partner-in-Charge of the tax practice of Neilson Elggren LLP. Prior to joining NE Mr. Calder was a Sr. Manager and tax consultant for Arthur Andersen; a Sr. Manager for Neilson Elggren Durkin & Company; a Manager for the international accounting firms of Ernst & Young; and a Senior Tax Consultant for Touche Ross & Co. Mr. Calder has provided a wide variety of tax services to clients throughout his career. His efforts have focused on special tax issues in corporate, partnership and individual bankruptcy, formation of and tax compliance for liquidating trusts; representation of taxpayers before federal and state taxing authorities; tax consulting with regard to “change of ownership” issues; tax consulting and compliance for U.S. companies operating internationally; tax consulting and compliance for corporations with multi-state income using “water’s edge” method; analysis of deductible ordinary and necessary business expenses; and supervising tax compliance for high technology companies. Mr. Calder’s clients have included companies ranging in size from $1 billion in annual sales to small development companies in many industries such as computer and peripherals, software, semiconductors, life sciences, energy, hospitality, professional sports and automotive parts rebuilders. In addition, he has provided tax services to a variety of clients including individuals, corporations, partnerships, decedent estates, trusts, and bankruptcy estates. Services rendered include tax compliance, representation before taxing authorities, bankruptcy court appearances, testifying as an expert witness, and tax consulting and planning. Mr. Calder has been a featured speaker at many firm sponsored seminars covering special bankruptcy tax issues, new tax legislation and general tax concepts. He has written numerous articles and other publications.

066



Case Examples

Estate Financial, Inc. – Responsible for tax compliance and consulting. Consulted with investors regarding deduction of theft losses in specified fraudulent arrangements.

Cedar Funding, Inc. – Responsible for tax compliance and consulting. Consulted with investors regarding deduction of theft losses in specified fraudulent arrangements.

Le*Nature’s, Inc. – Represented trustee in defending IRS examination of prepetition tax liabilities. Successful in eliminating prepetition tax claim in excess of $30 million. Responsible for tax compliance and consulting.

Mike Tyson Bankruptcy Estate – Responsible for defending IRS examination of prepetition tax years. Responsible for tax compliance and tax consulting.

Reed Slatkin Bankruptcy Estate – Responsible for all tax compliance and tax consulting work. Represented trustee in defending IRS examination of prepetition tax liabilities of the debtor. Extensive involvement in formation of Liquidating Trust created pursuant to Chapter 11 Plan of Reorganization.

JMS Automotive – Rebuilder of Automotive Parts – Responsible for all tax compliance and tax consulting work. Represented trustee in defending IRS examination of pre-petition tax liabilities of the debtor.

Bonneville Pacific Corporation--Geothermal Energy Corporation. Responsible for all tax compliance and tax consulting work. Extensive involvement in disposition of subsidiary stock.

Holder’s Capital Corporation--Ownership and management of hotels. Responsible for tax planning relating to restructuring of affiliated groups of corporations. Extensive work with provisions relating to taxation of affiliated groups. Represented Trustee in defending Internal Revenue Service examination of administrative tax liability.

Property Mortgage Company, Inc.—Private mortgage company. Responsible for all tax compliance and tax consulting for several corporations and real estate partnerships.

Bankruptcy--Responsible for tax compliance and tax consulting for various bankruptcies. Individual, partnership, and corporate. Advise trustees and attorneys concerning bankruptcy tax issues. Provide testimony in bankruptcy court.

Various individuals--Tax Compliance, advisor and Taxpayer Advocate. Supervised tax compliance work for many top-level executives. Taxpayer advocate before IRS in attempt by the IRS to garnish wages for delinquent taxes.

067



Industry Experience

Aviation Automotive

Real Estate Construction

Agricultural Energy

Restaurant Transportation

Convenience Store/Gas Retail Legal and accounting

Amusement and Recreation Services Security and Commodity Brokers

Healthcare Insurance Carriers

Electronic and Other Electrical Equipment Insurance Agents and Brokers

Telecommunications Furniture and Fixtures

Online Retailing Technology

Education

Bachelor of Science, Brigham Young University Master of Accountancy/Taxation, Brigham Young University

Professional Memberships

Certified Fraud Examiner Association of Insolvency and Restructuring Advisors American Bankruptcy Institute American Institute of Certified Public Accountants Utah Association of Certified Public Accountants National Association of Bankruptcy Trustees

Instruction, Presentations & Publications

Mr. Calder has provided instruction on the subject of taxation of bankruptcy estates at conferences for the American Bankruptcy Institute, the Association of Insolvency and Restructuring Advisors, and the Mississippi Bankruptcy Conference, Inc.

Co-author of 2005 Bankruptcy Revision, Implications for Business and Financial Advisors published jointly by the American Institute of Certified Public Accountants and the Association of Insolvency and Restructuring Advisors in 2005.

068


Page 1 of 3

Paul N. Shields, Managing Director 201 South Main Street, Suite 450 Salt Lake City, UT 84111 Direct: 801.321.0073 Mobile: 801.550.5933 Email: [email protected] Summary Paul N. Shields is a Managing Director at Berkeley Research Group. He has over twenty years of experience as a financial analyst and valuation expert. His professional designations include Chartered Financial Analyst (CFA), Certified Public Accountant (CPA), Certification in Distressed Business Valuation (CDBV), and Accredited in Business Valuation (ABV). Mr. Shields has expertise in business valuation, damage assessments and the evaluation of earnings capacity – particularly in the context of financial distress and bankruptcy. Mr. Shields has performed numerous solvency studies, and has evaluated business interests and assets for corporate reorganizations and distressed sales. He has performed services in the context of state‐court receiverships and as a special master and mediator, and has testified in federal and state courts on numerous occasions. Case Examples

Bankruptcy Estate of Vickie Lynn Marshall (a/k/a Anna Nicole Smith) – Supervised the valuation of Koch Industries, Inc., the second largest closely held business in the United States. The valuation was performed to assist counsel representing Ms. Marshall in her litigation against E. Pierce Marshall, the son of J. Howard Marshall II.

The IT Group, Inc. – Assessed the reorganization value of The IT Group for purposes of plan confirmation. At the time, The IT Group had annual revenues in excess of $1.3 billion and was a leading provider of diversified environmental consulting, engineering, construction, remediation, and facilities management services.

Bonneville Pacific Corporation – Assisted in supervising the damage study involving a bankrupt independent power producer. Responsibilities included tracing funds and analyzing transactions in excess of $5.5 billion over a six‐year period.

Webvan Group, Inc. – Supervised the solvency analysis of a leading online e‐grocer. Funding received by the company from public and private sources exceeded $800 million. The solvency analysis was performed in the context of avoidance actions.

Vann’s, Inc. – Assessed the solvency of, and evaluated alleged damages incurred by, a consumer electronics retailer with annual revenue in excess of $100 million. The solvency analysis was performed in the context of avoidance actions.

069


Page 2 of 3

Case Examples (Continued)

Arthur D. Little, Inc. – Supervised the solvency analysis of an international technology and management consulting firm with annual revenues in excess of $450 million. The solvency analysis was performed in the context of avoidance actions.

JD Services, Inc. – Assessed the solvency of a full‐service prepaid long distance phone company. The company’s annualized revenues were in excess of $100 million. The solvency analysis was performed in the context of avoidance actions.

Case Name Withheld – Performed services as a consulting expert in the context of a contested, leveraged transaction. At issue, among other things, was the solvency of the combined entities subsequent to a leveraged transaction.

Calcor Space Facility, Inc. – Assessed the solvency of an aircraft parts manufacturer. The company’s annual revenues were approximately $50 million. The solvency analysis was performed in the context of avoidance actions.

G.I. Industries, Inc. – Assessed the reorganization value of Conejo Enterprises, Inc., a wholly owned subsidiary of G.I. Industries, Inc., for purposes of plan confirmation. Conejo Enterprises, Inc. was a solid waste disposal company with annual revenues of $17 million.

Case Name Withheld – Prepared the valuation of a grocery store chain with annual revenues in excess of $100 million.

Case Name Withheld – Prepared the valuation of an aftermarket auto parts distributor with annual revenues of approximately $70 million.

Case Name Withheld – Prepared the valuation of a mechanical contractor with annual revenues in excess of $50 million.

Michael Gerard “Mike” Tyson – Prepared the valuation of assets transferred to a liquidation trust in accordance with IRS Revenue Procedure 94‐45 in the context of a bankruptcy proceeding.

Le‐Nature’s, Inc. – Prepared the valuation of assets transferred to a liquidation trust in accordance with IRS Revenue Procedure 94‐45 in the context of a bankruptcy proceeding.

Case Name Withheld – Appointed by the court as independent accountant. Responsibilities included securing trust assets, selling real property, effectuating a distribution to trust beneficiaries, and providing an accounting of prior trust activity.

070


Page 3 of 3

Education Bachelor of Arts in Accounting, University of Utah Master of Business Administration, University of Utah Professional Memberships CFA Institute Association of Insolvency and Restructuring Advisors American Bankruptcy Institute American Institute of Certified Public Accountants Utah Association of Certified Public Accountants Instruction, Presentations & Publications

Mr. Shields has provided instruction on valuation in the context of financial distress and bankruptcy at conferences for the American Bankruptcy Institute, the Association of Insolvency and Restructuring Advisors, the American Institute of Certified Public Accountants, and the Utah Association of Certified Public Accountants. Co‐author of Business Valuation in Bankruptcy, a Consulting Services Practice Aid published by the American Institute of Certified Public Accountants in 2002.

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Leif M. Larsen, Senior Managing Consultant

201 South Main Street, Suite 450 Salt Lake City, UT 84111 Direct: 801.321.0080 Fax: 801.364.6230 Email: [email protected] Summary Leif M. Larsen, a Senior Managing Consultant with Berkeley Research Group, LLC has over seventeen years experience in tax return preparation. Prior to working at Berkeley Research Group, LLC he was with LECG, LLC, working as Senior Managing Consultant and prior to that he was with Neilson Elggren, LLP, working as a Tax Manager. Mr. Larsen is a Certified Public Accountant and is an Enrolled Agent. Mr. Larsen is also a Certified Insolvency Restructuring Advisor. His experience also includes all areas of payroll taxes and sales & use taxes, including return preparation. A few of the cases in which Mr. Larsen has been involved include:

Le-Nature’s, Inc. – Accountants to the Trustee. Prepared original and amended corporate income tax returns and numerous information returns for related entities. Analyzed the many tax issues relating to the formation of a Liquidating Trust pursuant to the plan confirmation. Also prepared Liquidating Trust returns having over four hundred beneficiaries and prepared and maintained databases to track all pertinent beneficiary information.

Leslie Todd Bankruptcy Estate – Accountants to the Trustee. Prepared initial and final fiduciary tax returns for Individual bankruptcy case. Analyzed treatment of settlement proceeds received from breach of contract related to sale of debtors business to an outside party.

Reed Slatkin – Accountants to the Trustee. Prepared individual and S Corporation tax returns and numerous information returns for pass through entities, including Partnerships, and LLCs. Analyzed the many tax issues relating to the formation of a Liquidating Trust pursuant to the plan confirmation. Also prepared Liquidating Trust returns having over three hundred beneficiaries and prepared and maintained databases to track all pertinent beneficiary information.

Metropolitan Mortgage & Securities Co., Inc. – Accountants to the Trustee. Prepared consolidated income tax returns and prepared Liquidating Trust returns having over seven thousand beneficiaries.

National Summit Corporation – Accountants to the Trustee. Prepared consolidated income tax returns and prepared Liquidating Trust returns having over two thousand beneficiaries.

Michael G. Tyson – Accountants to the Debtor in Possession. Prepared individual and S Corporation tax returns. Also prepared Liquidating Trust returns having over one hundred beneficiaries and prepared and maintained databases to track all pertinent beneficiary information.

JMS Automotive Rebuilders, Inc. – Accountants to the Trustee. Analyzed many tax documents relating to the Internal Revenue Service’ audit of multiple tax years. Prepared corporate tax return.

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Webvan Group, Inc. and Subsidiaires – Accountants to the Trustee. Prepared consolidatedcorporate tax returns which included assets of over one billion dollars.

Licenses & Certifications

Certified Public Accountant – Licensed in the state of California Enrolled Agent – Internal Revenue Service Certified Insolvency & Restructuring Advisor - Association of Insolvency and Restructuring Advisors

Education

Bachelor of Science in Accounting, University of Utah

Professional Memberships

California Society of CPAs American Institute of Certified Public Accountants Association of Insolvency and Restructuring Advisors American Bankruptcy Institute

Employment History

2011 – Present Berkeley Research Group, LLC Senior Managing Consultant (2011 – Present)

2005 – 2011 LECG, LLC Senior Managing Consultant (2011 – 2011) Managing Consultant (2007 – 2010) Consultant (2005 - 2006)

2001 – 2005 Neilson Elggren LLP Manager (2005) Experienced Senior (2002 - 2005) Senior (2000 – 2001)

1996 – 2001 Interwest Business Group, Inc. Manager (1999 - 2001) Staff Accountant (1996 – 1998)

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Spencer G. Ferrero, Consultant 2049 Century Park East Suite 2525 Century City, CA 90067 Phone: 310-499-4742 Fax: 310-557-8982 Email: [email protected] Summary Spencer G. Ferrero is a Consultant at Berkeley Research Group, LLC (BRG) in the Century City, California office. Mr. Ferrero has eight years of experience providing services in bankruptcy, forensic and investigative accounting, litigation support and business valuation. Mr. Ferrero has been involved in chapter 11 and chapter 7 bankruptcy cases, providing accounting services to chapter 11 and 7 trustees, independent examiners and to the official committee of unsecured creditors. His experience includes claims analyses, solvency analyses, pre- and post-petition transfer analyses and the tracing of funds to prepare for avoidance action litigation. Case Examples

In re Ezri Namvar and In re Namco Capital Group, Inc. – Accountants and financial advisors to both the chapter 11 trustees of both bankruptcy estates. A well-known member of the Iranian Jewish community in Los Angeles received $3 billion in investments and loans over

five years and disbursed those funds through close to 400 separate LLC’s holding a wide array of assets such as hotels, golf courses, low-income housing projects, pistachio farms, conference center sites, medical buildings and ground leases. Mr. Ferrero has worked to

untangle the financial and business relationships among this multitude of inter-related LLC’s.

In re Galleria USA, Inc. (“GUSA”) – Accountants and financial advisors to the chapter 11

trustee. GUSA was an importer of furniture for “big box” retailers. GUSA, along with its sister company in Asia, had collective obligations to their secured and unsecured creditors totaling approx. $233 million. Mr. Ferrero assisted in the liquidation of inventory and the investigation

of fraud related to the loan collateral and inflated sales. The chapter 11 trustee released a detailed accounting report based on this investigation, which ultimately led to the indictment of the two principals of the debtor.

In re Estate Financial, Inc. - Accountants and financial advisors to the chapter 11 trustee.

Estate Financial was a “hard money lender” that solicited investments for, and arranged and made, real estate secured loans. At the time of the bankruptcy filing, the loan portfolio consisted of nearly 550 loans, all of which were in default, totaling approximately $350 million

funded by over 2,000 investors. Mr. Ferrero assisted in the ongoing liquidation of the loans or properties securing the loans and also accounted for the received proceeds.

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Other Engagements Turner Gas vs. Mark Harris, Kamps Company, et al – Litigation Support In re Le-Nature's, Inc. – Accountants to the Trustee BHE Group Inc. and GBM International, Inc. v. MTS Products – Litigation Support In re Peck/Jones Construction – Accountants to the Trustee In re Reed Slatkin – Accountants to the Trustee In re Death Row Records – Accountants to the Trustee In re Hiuka America – Accountants to the Trustee In re Cedar Funding, Inc. – Accountants to the Trustee In re David Prenatt – Accountants to the Trustee Wells Fargo & Company, et al vs. United States of America – Litigation Support Employment History March 2011 – Present Berkeley Research Group, LLC Associate, Senior Associate, Consultant September 2007 – February 2011 LECG, LLC

Intern, Research Analyst, Associate

Education Masters of Accounting University of Utah, Salt Lake City, Utah Bachelor of Arts in Accounting University of Utah, Salt Lake City, Utah Licenses & Certifications Certified Public Accountant –California Certified Fraud Examiner (CFE) Certified Insolvency and Restructuring Advisor (CIRA) Certified in Financial Forensics (CFF) Professional Memberships American Bankruptcy Institute American Institute of Certified Public Accountants Association of Certified Fraud Examiners Association of Insolvency and Restructuring Advisors California Society of Certified Public Accountants Awards Zolfo Cooper/Randy Waits CIRA Bronze Medal, 2012

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James Armstrong Updated 12/8/2014 Page 1 of 1

James Armstrong, Consultant 2021 NE Alberta St. Portland, OR 97211 Direct: (310) 499-4932 Office: (310) 499-0997 Email: [email protected]

Summary James Armstrong is a Consultant in the Portland, Oregon office of Berkeley Research Group, LLC (BRG), where he uses his knowledge in economics, accounting and finance to conduct research and analyses related to bankruptcy, forensic accounting, and securities litigation cases. Before joining BRG, Mr. Armstrong began his career as a financial advisor with Ameriprise Financial Services where he provided flexible and ongoing financial advice and comprehensive planning.

Case Examples

Estate Financial, Inc o Conducted the review and analysis of loan documentation and transactional data

related to the servicing of over 500 construction loans. o Oversaw the allocation and distribution of proceeds from the sale of assets. o Created analysis tools to determine damage estimates for multiple time periods prior

to the bankruptcy.

Estate Financial Mortgage Fund o Reconciled the cash transactions of a multimillion dollar funds used to finance

construction loans across Central and Southern California.

Le-Natures o Assisted with a large scale database project to combine transactional data in

Microsoft Access with soft copy backup documentation housed in a Concordance database.

Diversified Lending Group / Yellowstone Mountain Club / Others o Oversaw the extraction of transactional accounting data from hard copy statements

into an electronic database format.

Education MBA, Marylhurst University, 2009 BS, Economics, University of Oregon, 2006

Present Position BRG, Senior Associate, Consultant, 2011 to present

Other Positions Held LECG, Associate, 2006 to 2011 Ameriprise Financial Services, Vancouver, Washington, Financial Advisor, 2006–2006 Associated Students, University of Oregon, Eugene, Oregon, Controller, 2005–2006

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Laura J. Kramer, Senior Associate 2049 Century Park East Suite 2525 Century City, CA 90067 Phone: 310-499-4716 ext 4716 Fax: 310-557-8982 Email: [email protected] Summary Laura Kramer is an Associate at Berkeley Research Group, LLC (BRG). Ms. Kramer joined BRG in July 2013. Prior to employment at BRG, Ms. Kramer graduated from Loyola Marymount University with a Bachelor’s of Science in Accounting. Ms. Kramer has over a year of experience providing services in bankruptcy, forensic accounting, and litigation support. Ms. Kramer has been involved in chapter 11 and chapter 7 bankruptcy cases, providing accounting services to chapter 11 and chapter 7 trustees, independent examiners and to the official committee of unsecured creditors. Her experience includes claims analyses, post-petition transfer analyses and the liquidation of assets. Case Examples

In re Ezri Namvar and In re Namco Capital Group, Inc. – Accountants and financial advisors to both

the chapter 11 trustees of both bankruptcy estates. A well-known member of the Iranian Jewish

community in Los Angeles received $3 billion in investments and loans over five years and disbursed

those funds through close to 400 separate LLC’s holding a wide array of assets such as hotels, golf

courses, low-income housing projects, pistachio farms, conference center sites, medical buildings and

ground leases. Mr. Troszak has worked to untangle the financial and business relationships among this

multitude of inter-related LLC’s. Other Engagements

In re Reed Slatkin – Accountants to the Trustee

In re Death Row Records – Accountants to the Trustee

In re GGW Brands, LLC et al. – Accountants to the Chapter 11 Trustee

In re Ray Gonzales – Accountants to the Chapter 11 Trustee

In re The Tulving Company, Inc. a Corporation – Accountants to the Chapter 7 Trustee Employment History July 2013 – Present Berkeley Research Group, LLC Associate Education Bachelor of Science in Accounting Loyola Marymount University, Los Angeles, CA

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www.thinkbrg.com Page 1 of 1

Alec Swope, Summer Associate

201 South Main Suite 450 Salt Lake City, Utah 84111 Main: 801.364.6233 Fax: 801.355.9926 Email: [email protected]

Summary

Alec Swope is a Summer Associate at BRG, LLC. He has provided support services related to bankruptcy cases including tax services and financial analyses. His responsibilities have included researching and analyzing financial and non-financial tax data, analysis of monthly operating reports and assistance with accounting investigations.

Case Examples

Ezri Namvar Bankruptcy Estate – Accountants to the Trustee Castle Arch Legacy Trust – Accountants to the Trustee Archdiocese of Milwaukee – Financial Advisors to the Official Committee of Unsecured Creditors

Industry Experience

Legal Financial Manufacturing

Employment History

Summer 2015 BRG, LLC Summer Associate

Summer 2015 Deloitte Summer Leadership Conference Participant

2014 – 2015 ESL Writing Lab – Brigham Young University Writing Tutor

2013 – 2014 NorthStar Alarm Services Advertising Director

Education

Brigham Young University, Provo, UT, Bachelor of Science in Accountancy

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8/15/2011 www.brg-expert.com Page 1

Evelyn S. Perry, Paraprofessional 201 South Main Street, Suite 450 Salt Lake City, Utah 84111 Direct: 801.321.0082 Fax: 801.364.6230 Email: [email protected] Summary Evelyn Perry is a member of Berkeley Research Group, LLC (“BRG”) with over twenty-three years experience in the areas of Bankruptcy and Tax. Prior to joining BRG she was with LECG LLC, Neilson Elggren LLP, Arthur Andersen LLP in the Global Corporate Finance division and Neilson Elggren Durkin & Company. Evelyn’s responsibilities include the preparation and submission of fee application pleadings to the bankruptcy court as well assisting with assembly and submission of tax returns. Other responsibilities include reconciliation and assembly of billings to litigation, tax and other clients, reconciliation of client bank accounts and related support duties assisting professionals.

Case Examples Several of the cases in which Evelyn has been involved include: • Kenetech Windpower - Engagement wherein the firm represents the creditors committee in the

ongoing litigation of the largest windpower manufacturer in the United States. • Death Row Records—Trustee and Accountants to the Trustee. • LeNature — Accountants to the Trustee. • Robert B. Solomon – Chapter 11 Debtor-in-possession. • Estate Financial – Accountants to the Trustee. . • Reed E. Slatkin (One of California’s largest ponzi schemes) -Accountants to the Trustee. • Adelphia – Forensic Accountants to the Creditor Committee. Education Ricks College, Associates Degree in Business Education

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Kathy McKee, Paraprofessional 201 South Main Street, Suite 450 Salt Lake City, Utah 84111 Direct: 801.321.6333 Fax: 801.364.6230 Email: [email protected] Summary Kathy McKee is a member of Berkeley Research Group with over ten years experience in the areas of litigation support such as personal injury, Intellectual property and forensic accounting. She has performed adversary proceeding services, assisted in litigation matters and has been involved in major cases requiring document control, indexing and research of related documents. Case Examples A few of the cases in which Ms. McKee has been involved include:

• Suncrest – Case Assistant

• Abraham –- Case Assistant

• Brzowski Plastic Surgery – Case Assistant

• Owner Operator Independent Driver Association – Case Assistant

• Columbia Sportswear North American, Inc. – Case Assistant

• Mears – Case Assistant

• New School District Transition Team – Case Assistant

• William James Del Biaggio - Case Assistant

Education Salt Lake Community College, Business and Accounting Ashford University, Business Administration

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Victoria Calder, Summer Intern

201 South Main Street, Suite 450

Salt Lake City, Utah 84111

Phone: 801-321-6637

Fax: 801-335-9926

Summary

Victoria Calder is a member of Berkeley Research Group, LLC (“BRG”) in the Salt Lake City office. Prior to joining BRG she graduated from Morgan High School. She will attend BYU – Idaho in the fall of 2015. Employment History June 2015 – Present Berkeley Research Group, LLC Summer Intern Education Bachelor Degree – In Progress Bringham Young Univeristy – Idaho, Rexburg, ID

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Berkeley Research Group, LLC (“BRG”)

Schedule of Billing Rates

2016

Position Rate

Director

Senior Managing Consultant

Consultant

Associate

Summer Associates

$510 – 695

$385 – 420

$280 – 315

$200 – 265

$70 -- 175

083


This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE DOCS_LA:273999.1 46346/001

PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: Pachulski Stang Ziehl & Jones LLP, 10100 Santa Monica Blvd., 13th Floor, Los Angeles, CA 90067 A true and correct copy of the foregoing document entitled (specify): TENTH INTERIM AND FINAL APPLICATION OF BERKELEY RESEARCH GROUP, LLC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES AS ACCOUNTANTS TO THOMAS P. JEREMIASSEN, CHAPTER 11 TRUSTEE; DECLARATION OF VERNON CALDER; DECLARATION OF THOMAS P. JEREMIASSEN, TRUSTEE, IN SUPPORT THEREOF will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date) January 25, 2017, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On January 25, 2017, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. David W. Meadows 1801 Century Park East, Ste.1235 Los Angeles, CA 90067

Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) January 25, 2017, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. By Federal Express The Honorable Peter Carroll United States Bankruptcy Court Central District of California 1415 State Street Santa Barbara, CA 93101 Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. January 25, 2017 Myra Kulick /s/ Myra Kulick Date Printed Name Signature

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This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE DOCS_LA:273999.1 46346/001

Mailing Information for Case 9:08-bk-11457-PC

1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Mark Bradshaw [email protected],

[email protected];[email protected] Martin J Brill [email protected] James L Brunello [email protected] Christopher Celentino [email protected],

[email protected] Jonathan J Damen [email protected],

[email protected] Daniel Denny [email protected] Caroline Djang [email protected] Joseph A Eisenberg [email protected],

[email protected];[email protected];[email protected];[email protected]

John D Faucher [email protected], [email protected]

Brian D Fittipaldi [email protected] John W Fricks [email protected] Larry W Gabriel [email protected],

[email protected] Jon F Gauthier [email protected],

[email protected] Thomas M Geher [email protected],

[email protected];[email protected];[email protected] Philip J Giles [email protected] David Gould [email protected] Matthew Grimshaw [email protected],

[email protected] Jacqueline A Gruber [email protected] Steven T Gubner [email protected],

[email protected] Ralph P Guenther [email protected] Asa S Hami [email protected],

[email protected];[email protected];[email protected]

Thomas P Jeremiassen (TR) [email protected]

David A Juhnke [email protected] Brian M Kandel [email protected],

[email protected] Jeffrey L Kandel [email protected] Jeffrey L Kandel [email protected] Talin Keshishian [email protected],

[email protected] Lewis R Landau [email protected] rene Lastreto [email protected],

[email protected];[email protected] Erica T Loftis [email protected],

[email protected] Samuel R Maizel [email protected],

[email protected];[email protected]

Daniel M McGee [email protected] Frank F McGinn [email protected] Alexis M McGinness [email protected],

[email protected];[email protected] David W. Meadows [email protected]

Krikor J Meshefejian [email protected] Craig Millet [email protected],

[email protected];[email protected] Jennifer L Nelson [email protected] Jeffrey P Nolan [email protected] Christopher A Nowlin [email protected] Robert B Orgel [email protected], [email protected] David M Poitras [email protected],

[email protected];[email protected];[email protected] Hanno T Powell [email protected],


Kelly M Raftery [email protected], [email protected]

Dean G Rallis [email protected], [email protected];[email protected];[email protected];[email protected]

Edwin J Rambuski [email protected], [email protected]

Edwin J Rambuski [email protected], [email protected]

Paul F Ready [email protected] John P Reitman [email protected],

[email protected];[email protected];[email protected];[email protected];[email protected]

Christopher O Rivas [email protected], [email protected]

Yonaton M Rosenzweig [email protected], [email protected];[email protected]

John D Schlotter [email protected] Timothy J Silverman [email protected] Evan D Smiley [email protected],


Robyn B Sokol [email protected], [email protected]

Peter Susi [email protected], [email protected];[email protected]

Cathy Ta [email protected], [email protected];[email protected]

Bill Taylor [email protected] United States Trustee (ND)

[email protected] Darlene C Vigil [email protected] Marshall C Wallace [email protected] Kristin S Webb [email protected],

[email protected] Corey R Weber [email protected],

[email protected] Edward T Weber [email protected] Katherine M Windler [email protected] Jennifer C Wong [email protected] Kelly A Woodruff [email protected] Jonathan R Zeko [email protected],

[email protected]

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