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Page 1: Doc876 robbins tapp cobb & assoc accountants_work done_final comp

IN RE:

IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

§ §

FIRSTPLUS FINANCIAL GROUP, INC § Case No. 09-33918-HDH-11 §

DEBTOR § Hearing Date: May 4, 2012 § Hearing Time: 9:00 AM §

FEE APPLICATION COVER SHEET

Third and Final Chapter 11 Application of Robbins Tapp Cobb & Associates, PLLC.

For the time July 27, 2011 to February 22, 2012

Chapter: 11

Case No. 09-33918-HDH-11

Capacity: Accountants for Trustee

Debtor: FirstPius Financial Group, Inc.

Retainer Received: $0.00

Amount Requested:

Amount Previously Paid: $116,922.27

Reductions:

Fees:

Expenses:

$ 91,177.00

$ 0.00

Vol. Fee Reductions: $0.00

Expense $0.00 Reductions:

Other: $ 31,606.48 Prior Holdback Total Reductions: $0.00

Total: $122,783.48

Expenses: $0.00

Copies ($0.20/ page): $0.00 Courier Service:

Postage/Overnight Delivery: $0.00 Reimbursement of expenses:

Long Distance: $0.00 Filing Fees:

PACER charges: $0.00 Other Costs:

Client Parking: $0.00 Outside Copier Service:

Hourly Rates: Accountant Paralegal/ Clerical

Highest Rates: $275.00 $60.00

Hours Billed: 365.4 0.00

Average: $249.53 $ 0.00

Is/ J. James Jenkins April 6, 2012

Signature Date

ROBBINS TAPP COBB & ASSOCIATES, PLLC THIRD & FINAL FEE APPLICATION COVER SHEET- Page Solo

$0.00

$0.00

$0.00

$0.00

$0.00

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J.JamesJen~ns,CPA Robbins Tapp Cobb & Associates, PLLC 600 N. Pearl, L.B. 146 Dallas, Texas 75201 (214) 979-2323 (214) 979-2423 Fax

ACCOUNTANTFORTHETRUSTEE

IN RE:

IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

§ §

FIRSTPLUS FINANCIAL GROUP, INC. § Case No. 09-33918-HDH-11 §

DEBTOR § § § Hearing Date: May 4, 2012 § Hearing Time: 9:00 AM

THIRD AND FINAL CHAPTER 11 APPLICATION OF ROBBINS TAPP COBB & ASSOCIATES, PLLC, FOR ALLOWANCE OF

ACCOUNTING FEES AND REIMBURSEMENT OF EXPENSES

TO: ALL CREDITORS AND OTHER PARTIES IN INTEREST:

NO HEARING WILL BE CONDUCTED HEREON UNLESS A WRITTEN RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT AT 1100 COMMERCE STREET, ROOM 1254, DALLAS, TX 75242-1496 BEFORE THE CLOSE OF BUSINESS ON APRIL 30,2012 WHICH IS TWENTY (24) DAYS OR MORE FROM THE DATE OF SERVICE HEREOF.

ANY RESPONSE MUST BE IN WRITING AND FILED WITH THE CLERK, AND A COPY MUST BE SERVED UPON THE APPLICANT PRIOR TO THE DATE AND TIME SET FORTH ABOVE. IF A RESPONSE IS FILED A HEARING WILL BE HELD WITH NOTICE ONLY TO THE OBJECTING PARTY.

IF NO HEARING ON SUCH NOTICE OR APPLICATION IS TIMELY REQUESTED, THE RELIEF REQUESTED SHALL BE DEEMED TO BE UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING THE RELIEF SOUGHT OR THE NOTICED ACTION MAY BE TAKEN.

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page 1

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TO THE HONORABLE HARLIN D. HALE UNITED STATES BANKRUPTCY JUDGE:

COMES NOW ROBBINS TAPP COBB & ASSOCIATES, PLLC ("Applicant"), Accountants for the Trustee and makes this Third and Final Chapter 11 Application for Allowance of Fees and Reimbursement of Expenses and represents to the Court as follows:

1. On June 23, 2009, a voluntary petition was filed by the Debtor seeking relief under

Chapter 11 of Title 11 of the United States Code (the "Bankruptcy Code").

2. On July 24, 2009, Matthew D Orwig was appointed as Chapter 11 Trustee, accepted

his appointment and continues to serve.

3. Applicant was employed by Order Authorizing The Retention Of Robbins Tapp Cobb

& Associates, PLLC As Accountant To Chapter 11 Trustee Nunc Pro Tunc to August

17, 2009 entered on November 12, 2009 ..

4 Applicant has been employed by the Trustee in connection with this bankruptcy

case. All services covered by the Application were performed on behalf of the

Trustees and not on behalf of any other person or entity.

5. Applicant filed its First Interim Application on November 23, 2010 requesting

accounting fees in the amount of $110,514.25 and expenses of $0.00. Hearing was

held on December 17, 2010 and on or about December 21, 2010, an Order approving

fees of $110,514.25, less a 20% Holdback of $22,102.85, was entered by the Court.

Applicant received $88,411.40 in compensation.

6. Applicant filed its Second Application on September 2, 2011 requesting accounting

fees in the amount of $38,014.50 for the period November 1, 2010 through July 25,

2011, less a 25% Holdback of $9,503.63. Hearing was held on September 27, 2011

and on or about September 29, 2011, an Order approving fees of $28,510.87 was

entered by the Court. Applicant received $28,510.87 in compensation and has

received $116,922.27 in total compensation, to date.

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page 2

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7. The services rendered in this "Application Period", from July 27, 2011 to

February 22, 2012, totaling $91,117.00, listed by date services rendered, description of

the services rendered, the professional providing the service and the amount of time

spent by each professional in providing the service is attached as Exhibit A.

8. Applicant has neither shared or agreed to share its compensation for services

rendered in connection with this case with any other person.

9. In connection with its employment by the Trustee in this case, Applicant has

incurred out-of-pocket expenses in the amount of $0.00.

10. Section 330 of the Code authorizes the Court to award a professional, retained

by a Trustee, reasonable compensation for services and reimbursement of

expenses. Section 330 sets forth a number of parameters for use by Courts in

determining whether to allow compensation. See also Johnson v. Georgia

Highway Express. Inc .. 488 F. 2d 714 (5th Cir. 1974); In re First Colonial Corp.

of America, 544 F2d, 1291, 1299 (5th Cir. 1977, cert denied, 431 U.S. 904

( 1977) established a set of twelve factors for use by lower courts when setting

reasonable professional fees.

11. The parameters set forth in Section 330 of the Code are addressed below:

a. Time and Labor Required: Exhibit A is a listing of services rendered,

listed by date of services rendered, description of the services rendered,

the professional providing the service and the amount of time and the

amount spent by each professional in providing the service.

b. The Novelty and Difficulty of the Questions: The case did not involve

novel or difficult questions.

c. The Skill Required to Perform the Services Properly: The services

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page 3

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required knowledge of accounting and tax practice, accounting and tax practice

in a case under the Bankruptcy Code, the Internal Revenue Code and IRS

Regulations.

d. The Preclusion of Other Employment by Applicant Due to the Acceptance

of the Case: Applicant was not precluded from accepting other

employment due to the acceptance of this case.

e. The Customary Fee Charged by Applicant: Applicant's hourly charges for

services rendered to the Trustee are computed at the same rates as

Applicant regularly charges other clients.

f. Whether the Fee is Fixed or Contingent: The fee in this case is subject to

the Court's approval as necessary and reasonable.

g. Time Limitations: No specific time limitations were imposed by this case.

h. Results Obtained: Applicant assisted the Trustee and the Trustee's counsel

with analysis of pre-petition transactions, property of the Debtor, evaluation and

analysis of tax matters, reporting required by the Bankruptcy Code and Rules

and by the Office of the U.S. Trustee, administration of the Debtor estate and

preparation of the Trustee's amended plan of liquidation, liquidation trust and

disclosure statement. Pursuant to Local Rules for the Northern District of

Texas, Dallas Division, a breakdown of the projects and services performed in

this Application Period and the costs of those services is attached as Exhibit B.

i. The Experience, Reputation and Ability of Applicant: Applicant is

experienced in all aspects of accounting and tax matters as relating to the

issues arising in bankruptcy cases.

i. The Desirability of the Case: This case was not in any way "Undesirable".

k. The Nature and Length of Applicant's Professional relationship with the

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page4

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Client: Applicant had no prior relationship with the Debtor.

I. Awards in Similar Cases : The compensation requested by Applicant is

consistent with the compensation awarded in other cases of similar size

and complexity.

Applicant respectfully requests that they be allowed compensation of $91,177.00 in

connection with their employment by the Trustee during the Application Period. This amount

consists of $91,177.00 for professional fees and $0.00 for out-of-pocket expenses. The

compensation requested in this Application represents the product of a reasonable number of

hours for the work done, multiplied by a reasonable hourly rate for work on this case.

Applicant respectfully requests that the total compensation requested during the administration

of this Chapter 11 in the amount of $239,705.75 be finally allowed and approved as

reasonable, necessary and beneficial to the Chapter 11 Debtor and that the Trustee be

authorized to pay the $91,177.00 of accounting fees of this Application Period and the prior

holdbacks of $31,606.48, a total of $122,783.48, at this time, from the general funds of the

Liquidating Trust, as provided in the Amended Plan of Liquidation and Liquidating Trust

Agreement.

WHEREFORE, Applicant prays that the Court award and authorize the payment to Applicant the total sum of $122,783.48, representing $91,177.00 as accounting fees for the period July 27, 2011 through February 22, 2012, and $0.00 for reimbursement of out-of-pocket expenses during such period, and prior fee hold backs of $31,606.48, as final compensation from the Chapter 11 Debtor Estate.

Respectfully submitted,

Is/ J. James Jenkins J. James Jenkins, CPA Robbins Tapp Cobb & Associates, PLLC 600 N. Pearl, LB. 146 Dallas, TX. 75201 ACCOUNTANTSFORTHETRUSTEE

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page 5

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CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the Third and Final Application of Robbins Tapp Cobb & Associates, PLLC, has been served on the parties listed below by First Class U.S. Mail or by email transmission of digital media on this 6th day of April2012.

Erin Marie Schmidt Office of United States Trustee 11 00 Commerce Street, Room 976 Dallas, Texas 75242

George H Tarpley Aaron Michael Kaufman Cox Smith Matthews, Inc. 1201 Elm Street, Suite 3300 Dallas, Texas 75270

Peter A Franklin, Ill Doug D Skierski Franklin Skierski Lovall Hayward, LLP 10501 N Central Expwy, Suite 106 Dallas, Texas 75231

Matthew D Orwig, Trustee Jones Day 2727 N Harwood Street, 5th Floor Dallas, Texas 75201

Basheer Ghorayeb Jones Day 2727 N Harwood Street, 5th Floor Dallas, Texas 75201

Is/ J. James Jenkins

J. James Jenkins, CPA

THIRD AND FINAL APPLICATION OF ROBBINS TAPP COBB & ASSOC. FOR ALLOWANCE OF ACCOUNTING FEES AND EXPENSES Page 6

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Our- $

Date Emglo~ee Descrigtion Rate at ion Amount

07/27/11 KCobb Meeting with J Jenkins & A DiFrancesco re handling filing of

235.00 0.60 141.00 delinquent tax returns

07/27/11 J Jenkins Assist K Cobb with 201 0 and earlier tax return issues 275.00 0.30 82.50

A. Review of balance sheets for periods beginning with 2007 and

08/08/11 DiFrancesco

activity in accounts involving payments to other related 225.00 1.90 427.50 companies.

Prep for and telcon with Doug Skierski and meeting with Peter 08/09/11 J Jenkins Franklin re tax elements of plan and definition of trust; followup 275.00 3.50 962.50

research

08/10/11 J Jenkins Researching tax issues for plan and trust and disclosure

275.00 3.00 825.00 statement presentation

08/15/11 J Jenkins Assisting in drafting Plan & Trust Agreement 275.00 6.00 1,650.00

08/16/11 A. Meeting with Jim Jenkins relating to amounts relating to FPFI

225.00 1.40 315.00 DiFrancesco trust payments to FPFG and supporting schedules

08/16/11 J Jenkins Assisted in drafting Plan & Trust Agreement and Disclosure Stmt 275.00 5.50 1,512.50

08/17/11 A. Researching the various cash accounts of FPFG relating to

225.00 2.30 517.50 DiFrancesco transactions involving FPFI Trust.

Prepare MOR; Update cash summary for preparation of estimated trustee compensation; telcon with M Orwig, trustee,

08/17/11 J Jenkins and P Franklin re estimated trustee compensation; prepare 275.00 5.50 1,512.50 memo toP Franklin re question on Nevada and Texas franchise tax filings and payments

08/18/11 KCobb review e-mails from various parties, inculding PLR's and revised

235.00 2.00 470.00 Disclosure Statement

08/18/11 A. Completed reseaarch of FPFG bank account activity and noted

225.00 2.10 472.50 DiFrancesco several items of further interest.

Prep of fee application; upload July MOR; lunch meeting with M

08/18/11 J Jenkins Orwig & P Franklin re implementation of liquidating trust and

275.00 6.00 1,650.00 related issues; Telcons with R Richard and J Santoli re: tax issues and considerations in creating FPFG liquidating trust

08/19/11 KCobb research on tax issues for plan; cont. call replan of reorg.;

235.00 5.50 1,292.50 discuss w/ JJ changes to be made to trust

A. Completed research of bank accounts for FirstPies Enterprises;

08/19/11 DiFrancesco

FirstPius Acquisition and FirstPius Development relating to 225.00 2.50 562.50 possible transactions involving FPFI

Page 1 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Our- $

Date Em~lo~ee Descri~tion Rate ation Amount

Reading private letter ruling, field advisory memo and related

08/19/11 J Jenkins documents; prepare memo in preparation for conference call

275.00 6.00 1,650.00 with tustee and case professionals; followup on instructions from conference call

08/20/11 KCobb review of changes made by JJ to Trust Agreement & Plan of

235.00 3.30 775.50 Reorg.; discuss changes w/ JJ

Suggested wording changes to Liquidating Trust Agreement and 08/20/11 J Jenkins 1st Amended Plan; discussions with K Cobb re adjusting 275.00 7.50 2,062.50

Quickbooks general ledger records to facilitate tax return prep

08/21/11 J Jenkins Suggested wording changes to FPFG Disclosure Stmt to

275.00 2.00 550.00 conform with changes in Plan and Liquidating Trust Agreement

review of changes made by JJ to Disclosure Stmt.; forward to 08/22/11 KCobb Peter & Doug; draft lang. on equity interests continuation in Plan 235.00 5.70 1,339.50

and Trust Agreement

A. Completed research of bank accounts for FirstPius Facility

08/22/11 DiFrancesco

Services; FirstPius Restoration and FirstPius Restoration and 225.00 2.40 540.00 Facility Services.

08/22/11 J Jenkins Complete suggested changes to Disclosure Stmt, transmit to

275.00 2.50 687.50 and telcon with Kirk Cobb

08/23/11 KCobb draft lang. on equity interest continuation and Federal tax

235.00 3.40 799.00 provisons in Disclosure Stmt.

08/23/11 A. Completed research of bank accounts for Rutgers Investment

225.00 2.10 472.50 DiFrancesco and The Premier Group

review revised draft of the Liquidating Trust Agreement and 08/25/11 KCobb discuss same w/ JJ; review & research suggested changes 235.00 1.10 258.50

made by Tim Santoli

08/25/11 J Jenkins Telcons w K Cobb re changes suggested by SNR 275.00 0.30 82.50

review new draft of Trust Agreement; respond by e-mail; call to 08/26/11 KCobb Doug S. to discuss various use of PLR on tax aspects of Trust 235.00 1.20 282.00

Agreement

review new draft of Plan of Reorg. And e-mails from others as to

08/29/11 KCobb changes; reply re changes; exchange emails w P Franklin re

235.00 2.80 658.00 SEC issues and revising Plan and Trust; telcons with J Jenkins re SEC and equity issues under Plan

multiple calls to/from P. Franklin, D. Skierski, & J. Jenkins re 08/30/11 KCobb proposed changes in Plan and Trust Agreement; review multiple 235.00 2.20 517.00

e-mails on same and reply

Page 2 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Dur- $

Date Emj2loyee Description Rate ation Amount

Prepare Project Breakdown exhibit for fee application; telcons

08/30/11 J Jenkins with K Cobb, P Franklin and D Skierski re questions raised by

275.00 2.60 715.00 SNR Re shareholder treatment, liquidating trust and relationship to Debtor after confirmation

call to Keith Enger to discuss his contact w/IRS spec. 08/31/11 KCobb procedures; draft e-mails toP. Franklin; telcons with J Jenkins re 235.00 0.60 141.00

update on proposed changes to plan and trust

08/31/11 A. Began researching back-up for selected receipts possibly

225.00 1.10 247.50 DiFrancesco involving FPFI Trust

09/01/11 K Cobb review revised Disclosure Statement 235.00 0.70 164.50

A. Continued researching general ledgers for FPFG for years 2002

09/01/11 DiFrancesco

through 2009 for transactions and support for entries involving 225.00 3.40 765.00 the FPFI Trust

09/01/11 J Jenkins Complete fee application and notices 275.00 4.00 1,100.00

review comments ofT. Santoli on Dis. St.; research and draft

09/02/11 KCobb changes; research issue on discharge & respond to T S, confcall

235.00 7.20 1,692.00 w D Skierski & P Franklin re issues on discharge; prepare & mail notices of fee application

09/02/11 J Jenkins Upload Fee Application to ECF 275.00 1.00 275.00

09/05/11 A. Continued review of selected bank accounts relating to

225.00 3.00 675.00 DiFrancesco transactions with FPFI Trust.

review e-mails on remaining issues; search for Vectrix Plan doc.; 09/06/11 KCobb send email w copies of Vectrix documents to D Skierski & P 235.00 0.70 164.50

Franklin

09/06/11 A. Continued review of selected bank accounts relating to

225.00 1.70 382.50 DiFrancesco transactions with FPFI Trust.

09/06/11 J Jenkins Review reorg documents; TC D Skierski re changes 275.00 1.20 330.00

A. Finalized research and review and began tracing entries to

09/07/11 DiFrancesco

documents prepared from FPFI records to try to reconcile 225.00 3.60 810.00 amounts reflected in both entities.

review of FPFI plan of reorg; 2005 - 2006 tax returns & other 09/08/11 KCobb docs for informaton on tax status to Debtor; meeting w J Jenkins 235.00 6.50 1,527.50

to discuss

Analysis of payments received from FPFI, 2000 - 2009 general 09/08/11 J Jenkins ledger trial balances; FPFI plan provisions relating to FPFG 275.00 4.50 1,237.50

claim

Page 3 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time .Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Our- $

Date Emglo)lee Descrigtion Rate ation Amount

discuss possible tax positions for 2010 w/ RR & JJ; confcall w K Enger re FPFI disclosure statement and settlement agreement;

09/09/11 KCobb 1 099s issued to FPFG; FPFI's position for treating distributions 235.00 1.30 305.50 as interest income; use of NOL's of former consolidated group and other matters

09/12/11 J Jenkins Email memo to Leo Carey re Plan of Liquidation. 275.00 1.50 412.50

09/13/11 J Jenkins Telcon with Leo Carey re email about Plan, etc 275.00 0.30 82.50

09/15/11 KCobb review of MOR;s for 2010 revenue & deductions; prepare

235.00 3.20 752.00 workpapers and

09/15/11 J Jenkins Analysis of 2009 and 2010 transactions and assist in preparation

275.00 3.50 962.50 of2010 Form 1120

09/16/11 A. Continued tracing various entries from FPFI records to FPFG

225.00 2.30 517.50 DiFrancesco general ledger entries for comparison

09/16/11 J Jenkins Researching SEC filings in FPFI reorg period (1999-2000) 275.00 3.50 962.50

09/19/11 KCobb prep of revised POA; review e-mail on shareholders list; prep

235.00 1.90 446.50 client copy of tax return & organize files

A. Retrieved "Summary of Group Distributions from FPFI" and

09/19/11 DiFrancesco

began updating same using recently received data from FPFI 225.00 4.10 922.50 accountants and began tracing

09/19/11 J Jenkins Prep for meeting w Trustee Re Fee hearing 275.00 2.50 687.50

09/20/11 KCobb e-mail POA to trustee; draft cover ltr for copy of tax return 235.00 0.20 47.00

09/20/11 A. Continued updating "Summary" carefully tracing distributions

225.00 2.40 540.00 DiFrancesco from FPFI to "Summary"

09/20/11 J Jenkins Prep for and meeting with Trustee Orwig etal at SNR 275.00 2.00 550.00

09/21/11 J Jenkins Prepare August 2011 MOR; prepare project list for Trustee's

275.00 3.00 825.00 declaration

09/22/11 J Jenkins Prep August 2011 MOR 275.00 1.50 412.50

A. Finalized Summary update and began tracing total distributions

09/23/11 DiFrancesco

from FPFI website to Summary and adjusted Summary 225.00 2.50 562.50 accordingly

09/23/11 J Jenkins Witness & Exhibit List; upload MOR; at Lain Faulkner re FPFI

275.00 3.00 825.00 distribution cancelled checks

A. Began comparing adjusted Summary to one previously

09/26/11 DiFrancesco

distributed to determine differences and reconciling both 225.00 4.50 1,012.50 documents.

Page4 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Our- $

Date Emgloyee Descrigtion Rate ation Amount

09/27/11 J Jenkins Prep for and attend Hearing on fee applications; upload

275.00 3.20 880.00 proposed order

A. Preparation of specific workpapers; meeting with Jim Jenkins

09/28/11 DiFrancesco

reviewing current workpapers and determining remaining data to 225.00 4.30 967.50 be accumulated.

Telcon with P Franklin re preparation for hearing on W Maxwell 2004 motion and related issues; read W Maxwell response and

09/28/11 J Jenkins objection to 2004 motion; tracing The Premier Group 275.00 6.50 1,787.50 transactions related to Jan 2008 purchase and payments on purchase

09/29/11 KCobb assist JJ w/ creating reports in quickbooks of vendor payments. 235.00 0.90 211.50

Reading document relating to hearing on W Maxwell 2004 ; telcon with Peter Franklin re Mitsubishi documents and related;

09/29/11 J Jenkins tracing and downloading FPFG vendor payments reports and

275.00 6.50 1,787.50 related reports on Consulting and Legal Professional fees; telcon with John Volny re questions on purchases of Rutgers, Globalnet and Premeir and related questions

09/30/11 A. Began implementing changes recommended by Jenkins

225.00 2.90 652.50 DiFrancesco specifically as relates to reconciling various worksheets.

Transaction analysis of sub purchases, legal fees ; met with 09/30/11 J Jenkins John V re purchase amounts v. operating advances to Rutgers 275.00 5.50 1,512.50

and Globalnet and Premier; organize and finalize analysis

A. Began reviewing activity for various FPFG bank statements

10/03/11 DiFrancesco

(Bank of America) and tracing results to general ledger and 225.00 3.10 697.50 updating date for activity subsequent to posting of Quick Books

A. Continued and finalized reviewing activity for BOA accounts and

10/04/11 DiFrancesco

prepared suggested journal entries for use in preparation of 225.00 4.20 945.00 federal tax returns

10/06/11 A. Began recording transactions within Wells Fargo Bank (4223)

225.00 3.70 832.50 DiFrancesco from 6/30/08 to 6/30/09.

10/10/11 J Jenkins TC & email memo to D Marsh re IRS tax notice re 2010 Fm 1120 275.00 0.40 110.00

10/11/11 A. Continued recording transactions within Wells Fargo Bank

225.00 3.20 720.00 DiFrancesco (4223) from 6/30/08 to 6/30/09 on Excel spreadsheet.

A. Finalized recap of receipts and disbursements within Fargo

10/12/11 DiFrancesco

(4223) and began recording same on Excel for Fargo (8176) 225.00 3.90 877.50 from April through June 2009

Page 5 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Our- $

Date Employee Description Rate ation Amount

Analyzing documents received in connection with Velia Charters 10/13/11 J Jenkins project; assisting A DiFrancesco with locating Ole enterprises 275.00 2.50 687.50

and other 2007-08 financial files for 2007/2008 Corp Tax

A. Finalized spreadsheet for Fargo (8176) and reviewed results for

10/14/11 DiFrancesco

both Fargo accounts attempting to identify specific transactions 225.00 4.10 922.50 and possible trace to other FPFG accounts

10/17/11 A. Began researching files for financial data for Ole' Auto especially

225.00 2.10 472.50 DiFrancesco as related to year end 2007 & 3/08

A. Continued research relating to Ole"; reviewing prior year tax

10/18/11 DiFrancesco

returns (2006 & 2005) as relates to Ole' and FPFG as a single 225.00 2.90 652.50 tax entity

10/18/11 J Jenkins TC P Franklin re "source of document" questions raised by W

275.00 2.50 687.50 Maxwell; followup research

A. Finalized review of prior years tax returns: reviewed comparative

10/19/11 DiFrancesco

trial balances for FPFG posted on Quick Books for 2006 to data 225.00 4.30 967.50 contained on 2006 federal tax returns.

10/19/11 J Jenkins Memo to E Lovall re questions Re "Source of Documents" used

275.00 0.50 137.50 in tracing subsidiary transactions

10/20/11 A. Meeting with J. Jenkins relating to year end balances tax returns

225.00 1.90 427.50 DiFrancesco vs. quickbooks and possible adjustments

10/20/11 J Jenkins Prep for and meeting with P Franklin and E Lovall at FSLH Re

275.00 3.00 825.00 document used in tracing Velia transactions and other analysis

A. Began researching documents and internet relating to FPFG

10/21/11 DiFrancesco

purchase of Rutgers and tracing cash activity to quick book 225.00 2.40 540.00 entries.

10/21/11 J Jenkins Assist D Marsh with reports to US Trustee program 275.00 0.80 220.00

10/22/11 J Jenkins TC P Franklin Re analysis and tracing of legal fees paid in

275.00 2.50 687.50 2007/08; followup analysis and tracing

10/23/11 J Jenkins Reading plan, disclosure and trust documents; prepare email

275.00 3.00 825.00 memo to D Skierski re questions and issues

10/24/11 A. Finalizing research of Rutgers pruchase and obtaining

225.00 2.10 472.50 DiFrancesco documents relating to actural transaction

Page 6 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Dur- $

Date EmQioyee DescriQtion Rate ation Amount

Analyzing and tracing legal fee payments and related transactions; searching document files for bank documents and statements; reconciling cash transactions to accounting detail

10/24/11 J Jenkins and adjustments; discuss plan and disclosure issues with Kirk 275.00 6.50 1,787.50 Cobb; telcons with P Franklin and reading draft of Liquidation Trust received today; respond to email memos from P Franklin and D Skierski

10/25/11 KCobb research and prep form 4506 requesting copies of 1999- 2001

235.00 0.80 188.00 consolidated tax returns to get pre-bankruptcy tax information

Meeting with J. Jenkins relating to transactions involving J.

10/25/11 A. Maxwell from various sourches withing quickbooks; began

225.00 3.10 697.50 DiFrancesco researching all trial balances of all entities for possible

transactions involving Maxwell

Tracing wire transfers and adjustments to and from W Maxwell;

10/25/11 J Jenkins met with A DiFrancesco reconciling information and analysis;

275.00 4.50 1,237.50 followup tracing to Oppenheimer records; TC w P Franklin and D Skierski re Plan, Disclosure and Trust documents

10/26/11 KCobb mtg w/ J Jenkins,P Franklin & John Volney, re W. Maxwell

235.00 0.50 117.50 subpeona

A. Finalized Maxwell review; discussed same with Jenkins and

10/26/11 DiFrancesco

researched the various accounts charged with Maxwell 225.00 2.70 607.50 disbursements

Prepare information for meeting w P Franklin & J Volney;

10/26/11 J Jenkins meeting and followup with A DiFrancesco to research Rutgers

275.00 5.00 1,375.00 and Global Net transactions; prepare Sept MORand transmit to trustee and attorneys

A. Began extensive review of all entries and documents including

10/27/11 DiFrancesco

internet access relating to purchase of Globolnet interests and 225.00 3.10 697.50 cash transactions involved in the acqusition of these interests.

10/27/11 J Jenkins Upload Sept MOR to ECF 275.00 0.50 137.50

10/28/11 A. Finalized Globolnet activity and discussed final results with

225.00 1.90 427.50 DiFrancesco Jenkins including actual purchase documents

A. Reviewed numerous documents relating to financial information

11/01/11 DiFrancesco

for Ole' Auto group; acquired year end 2007 balance sheet & 225.00 3.10 697.50 income statement for use in consolidated tax return.

A. Began preparation of 2007 consolidated financial statements for

11/02/11 DiFrancesco

FPFG & Ole'; researched FPFG 2007 general ledger for activity 225.00 2.70 607.50 involving Ole'.

11/03/11 A. Completed 2007 consolidated financial statements (FPFG &

225.00 3.10 697.50 DiFrancesco Ole');

Page 7 EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity Dur- $

Date EmQIO)lee DescriQtion Rate ation Amount

Researched selected accounts at 12/31/2007 and recorded

11/08/11 A. specific activity within those accounts for use in preparation of

225.00 3.40 765.00 DiFrancesco consolidated tax return; completed preliminary balance sheet &

P&L for FPFG for year 2008 to include in 2008 tax return

11/09/11 A. Began researching details relating to unidentified transactions

225.00 2.90 652.50 DiFrancesco occuring in 2008 & 2009; meeting with Jim Jenkins re: same

11/09/11 J Jenkins Assist with locating and reconciling transaction info from 08-09

275.00 2.50 687.50 with A Difrancesco; telcon and analyzing data from E Lovall

Continued research of cash transactions, especially as relates to

11/10/11 A. Wells Fargo accts, for 2008 & 2009; began identifying selected

225.00 3.60 810.00 DiFrancesco items from information received from various sources including

Preference Analysis

Recapped all cash entries for year 2008; identified those from

A. known sources (remaining entries to be discussed at a later

11/11/11 DiFrancesco

date); prepared preliminary year end 2008 financial statements 225.00 3.70 832.50 requiring further adjustment; cursory review of payroll and payroll tax expense for FPFG during 2008.

11/11/11 J Jenkins Analysis- IRS claim and search for related documents; met with

275.00 2.00 550.00 K Cobb re filed and unfiled Forms 1120

Began recapping all receipts and disbursements for year 2009

11/14/11 A. from various sources including MORs; began creating adjusting

225.00 3.50 787.50 DiFrancesco entries to record these events to be posted to trial balance

worksheets for 2009.

A. Finalized all financial activity for 2009; completed preliminary

11/16/11 DiFrancesco

adjusting entries and completed preliminary trial balance at 225.00 3.40 765.00 12/31/09

Reviewed trial balances for 2007, 2008 &2009; made certain

11/17/11 A. adjustments relating to comparative numbers; prepared excel

225.00 2.80 630.00 DiFrancesco worksheet containing year end balance sheet details for

inclusion in preparation of 1120s for each year.

11/18/11 A. More definitive review/research relating to payroll for 1st & 2nd

225.00 2.60 585.00 DiFrancesco Qtr 2008

Continued researching payroll activity for year 2008 discovering

11/21/11 A. that FPFG employees were being paid by other entities long

225.00 2.70 607.50 DiFrancesco after the books for FPFG stopped posting to the GIL; discussed

same with J. Jenkins.

Completed review of payroll activity; traced and noted selected

11/22/11 A. entries between various related entities as affects FPFG;

225.00 2.80 630.00 DiFrancesco updated FPFG trial balance to include balances per MOR,

schedules, and 1120 for comparison purposes

Page 8 EXHIBIT A

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Activity Date

11/23/11

11/30/11

12/06/11

12/07/11

12/09/11

12/12/11

12/13/11

12/22/11

01/21/12

01/23/12

01/25/12

01/30/12

02/01/12

02/01/12

02/08/12

02/09/12

02/09/12

ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11

Emglo~ee Descrigtion

A. Completed final adjustments to trial balances for 2007, 2008 & DiFrancesco 2009. Submitted all to K. Cobb for review and discussion.

J Jenkins Prep & upload October 2011 MOR; telcons with E Lovall re MOR information

Meeting w E Lovall Re Patton Boggs preference settlement; J Jenkins meeting w P Franklin & E Lovall re disclosure hearing

preparation; discussed income tax reporting issues with K Cobb

KCobb re-draft & print request for prior tax returns, disc w/ J. Jenkins

J Jenkins Email memo to Denise Marsh transmitting request to IRS for copies of 199-2001 Form 1120.

At Court - Patton Boggs settlement; TC M Orwig re call from K Rust in UST Office; tc K Rust re copies of MORs; copy July -

J Jenkins October 2011 MORs, draft transmittal and deliver to UST Office; TC D Skierski re probable schedule for plan voting and confirmation

J Jenkins TC P Franklin re meeting with D Obergfeld, claims by lawsuit defendants against Debtor

J Jenkins Prepare and upload Nov 2011 MOR

J Jenkins Prepare Dec 2011 MOR

J Jenkins Upload Dec 2011 MOR

J Jenkins At Court for Confirmation Hearing on Trustee's Plan

J Jenkins Review of drafts of Order of Confirmation; discuss with P. Franklin;

KCobb review of revised Order of Confirmation; discuss w/ J. Jenkins; call toP. Franklin; exchange e-mails w P Franklin on same

J Jenkins Discuss draft confirmation order with K Cobb; review D Skierski post-confirmation task list and prepare listing of additional items

J Jenkins Research claim filed by Edwin Perkins, former Ole Auto exec and alter ego issues; report result to D Skierski

KCobb Obtain EIN for FPFG Liquidating Trust

J Jenkins Transmit Trust ID #to J Black for opening new bank accounts at Wells Fargo

Page 9

Our- $ Rate ation Amount

225.00 2.50 562.50

275.00 2.00 550.00

275.00 3.50 962.50

235.00 0.60 141.00

275.00 0.50 137.50

275.00 3.50 962.50

275.00 0.40 110.00

275.00 2.50 687.50

275.00 2.00 550.00

275.00 0.50 137.50

275.00 2.50 687.50

275.00 1.00 275.00

235.00 1.40 329.00

275.00 2.50 687.50

275.00 4.50 1,237.50

235.00 0.60 141.00

275.00 0.30 82.50

EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC Detail Time Activities By Client July 26, 2011 to February 22, 2012

Client Name: FirstPius Financial Group, Inc , Case No. 09-33918-HDH-11 Activity

Date Employee

02/14/12 K Cobb

02/14/12 J Jenkins

02/21/12 J Jenkins

Description

review and respond to e-mail from Wells Fargo request for State filings documents for FPFG Liquidating Trust

Prepare memo to Wells Fargo bank renew accounts and transfers needed to fund liquidating trust

Meeting with D Skierski re Post-confirm claim records and other financial records

Totals

PERSONNEL SUMMARY

KCobb

A DiFrancesco

J Jenkins

Totals

Page 10

Our- $ Rate ation Amount

235.00 0.30 70.50

275.00 2.00 550.00

275.00 0.40 110.00

365.40 91,177.00

55.20 12,972.00

142.00 31,950.00

168.20 46,255.00

365.40 91,177.00

EXHIBIT A

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ROBBINS TAPP COBB & ASSOCIATES, PLLC

FIRSTPLUS FINANCIAL GROUP, INC. 09-33918-HDH-11

THIRD AND FINAL CHAPTER 11 APPLICATION FOR ALLOWANCE OF ACCOUNTING FEES AND OF EXPENSES

PROJECT BREAKDOWN

Pursuant to Local Rules for the Northern District of Texas, Dallas Division, the Applicant is to provide an exhibit concerning a breakdown of the projects and services performed and the costs of those services. Therefore, the Applicant provides this Project Breakdown in support of the Application. Applicant has divided its services into five different areas or projects as follows:

I. REPORTING TO U.S. TRUSTEE PROGRAM. PREPARATION OF MONTHLY OPERATING REPORTS AND OTHER ASSISTANCE IN ADMINISTERING CASE

Applicant prepared Monthly Operating Reports for the months of July 2011 through January 2012 during the application period. These services included analyzing and summarizing Debtor's receipts and disbursement and related transactions.

Applicant expended 17.8 hours in connection with preparation of Monthly Operating Reports and related reports for a total of $4,895.00 in accounting fees.

II. FEDERAL TAX ISSUES

Applicant analyzed and traced financial and tax information into Debtor's and Debtor's related and subsidiary entities books, records and prior tax returns. Transactions between Debtor, FPFI Creditors' Trust, FPFG Grantor Trust, FPFG shareholders and the entities created or allegedly acquired in 2007 and 2008 were analyzed for taxability or as offsets against taxable income. No tax returns had been filed by the Debtor or a consolidated group, which may or may not exist, since the Corporate Tax Return filed for 2006. Applicant prepared and filed a Federal Income Tax return for the calendar year 2010 using the best information available. Applicant through the Chapter 11 Trustee requested and received copies of tax returns for the years 1999 and 2001 and performed other summarization and analysis, which will assist in preparing tax returns for remaining unfiled years

Applicant assisted with analysis of tax issues in connection with preparation of Trustee's First Amended Plan of Liquidation and related liquidation trust.

Applicant expended 160.7 hours in connection with tax transaction analysis and research for a total of $36,573.50 in accounting fees.

PROJECT BREAKDOWN SUPPLEMENT TO THIRD AND FINAL CHAPTER 11 APPLICATION OF ROBBINS TAPP COBB & ASSOCIATES, PLLC - Page 1

EXHIBIT 8

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Ill. PROPERTY OF THE DEBTOR AND PRE-PETITION TRANSACTIONS

Applicant made a limited investigation of the subsidiaries and other entities created or allegedly acquired in 2007 and 2008, transactions between the Debtor and these entities, and regulatory reports filed with the Securities and Exchange Commission. Applicant traced distributions from the FPFI Creditors' Trust into the Debtor's accounting records, investigated transactions in the FPFG Grantor Trust where possible, analyzed expenditures for purchase of subsidiaries, property and expenses and provided assistance and information as requested by the Trustee and his counsel.

Applicant assisted counsel for Trustee in recovering or tracing property of the Debtor. Applicant traced and analyzed sources of funds used to purchase a Mitsubishi airplane titled in the name of an alleged subsidiary of Debtor and well as tracing the sources of funds used to purchase or pay a portion of the purchase price of alleged subsidiaries of Debtor in 2007 and 2008 to payments recorded as legal fees on Debtor's records.

Applicant expended 57.0 hours in connection with tracing and analysis of property transactions for a total of $15,809.00 in accounting fees.

IV. PREPARATION OF SECOND INTERIM FEE APPLICATION

Applicant prepared and filed its First Interim Fee Application and Request For Reimbursement Of Expenses in November and December, 2010.

Applicant expended 19.6 hours in connection with preparing and filing its Second Interim Fee Application, which was filed on September 2, 2011, for a total of $5,377.00 in accounting fees

V. ASSISTANCE WITH PREPARATION AND IMPLEMENTATION OF THE AMENDED PLAN OF LIQUIDATION, LIQUIDATING TRUST AND DISCLOSURE STATEMENT

Applicant provided assistance, tax research and analysis to counsel for the Trustee in the preparation of the amended plan of liquidation, creation and operation of the liquidating trust and the related information provided in the disclosure statement. Applicant provided assistance, as requested, in the post-confirmation implementation of the elements of the plan and trust.

Applicant expended 103.8 hours in connection with assisting in the preparation and implementation of the amended plan of liquidation, liquidating trust and disclosure statement for a total of $26,734.50 in accounting fees.

PROJECT BREAKDOWN SUPPLEMENT TO THIRD AND FINAL CHAPTER 11 APPLICATION OF ROBBINS TAPP COBB & ASSOCIATES, PLLC - Page 2

EXHIBIT 8

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VI. INVESTIGATION OF CLAIMS AGAINST THE DEBTOR

Applicant, at the request of counsel for the Trustee, evaluated and reported its findings on two claims against the Debtor.

Applicant expended 6.5 hours in connection with tracing and analysis of property transactions for a total of $1,787.50 in accounting fees.

Respectfully submitted,

Is/ J. James Jenkins

J. James Jenkins, CPA Robbins Tapp Cobb & Associates, PLLC 600 N. Pearl, LB. 146 Dallas, TX. 75201 Telephone (214) 979-2323 Telecopier (214) 979-2423 Email: jenkinsjj@sbcglobal. net

ACCOUNTANTS FOR THE TRUSTEE

PROJECT BREAKDOWN SUPPLEMENT TO THIRD AND FINAL CHAPTER 11 APPLICATION OF ROBBINS TAPP COBB & ASSOCIATES, PLLC - Page 3

EXHIBIT 8


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