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February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 1204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY
9/14/2009
Transfer from Trust Account: Iolta $0.00
$10,000.00
X ($10,000.00)
9/28/2009
Transfer from Trust Account: Iolta $0.00
$25,000.00
X ($35,000.00)
9/30/2009
Hourly Bill Posting
Period: 09/01/2009 - 09/30/2009
$28,925.50
$0.00
C ($6,074.50)
Date Timekeeper Hours Rate*
Charge*
9/1/2009
Attendance at hearing on cash collateral motion; several telephone conferences with
J. Hall regarding same; conference with R. Patel regarding same.
GMP 2.20 $500.00
$1,100.00
9/2/2009
Work on various issues; telephone conference with L. Friedman; numerous
telephone conferences with J. Hall regarding same.
GMP 2.20 $500.00
$1,100.00
9/3/2009
Conference with J. Hall and J. Baron at J. Hall's office regarding various issues.
GMP 2.80 $500.00
$1,400.00
9/4/2009
Telephone conference with P. Kieffer regarding various issues, including trustee
situation; telephone conference with J. Hall regarding same; telephone conference
with L. Friedman regarding same; review correspondence from J. Hall regarding
background of various matters.
GMP 2.00 $500.00
$1,000.00
9/5/2009
Conference at L. Friedman's office with L. Friedman, J. Baron, J. Hall and R. Lurich;
telephone conference with J. Hall regarding various issues; review and analysis of
information relating to background.
GMP 2.80 $500.00
$1,400.00
9/8/2009
Telephone conference with J. Hall regarding various issues; telephone conference
with J. Hall and J. Barron regarding same; review and analysis of emails and
information sent by J. Hall regarding continued factual background.
GMP 1.40 $500.00
$700.00
9/9/2009
Draft Form Joinder to Motion to Dismiss; circulate upon request.
CWS 1.00 $195.00
$195.00
9/10/2009
Draft and revise Joinder in Motion to Dismiss.
CWS 0.70 $195.00
$136.50
9/10/2009
Communication with C. Stephenson regarding electronic filing of the Joinder in
LDW 0.90 $85.00
$76.50
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 4 of 58
EXHIBIT "A"
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 2204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Motion to Dismiss Bankruptcy Case (.1); revise Joinder in Motion to Dismiss
Bankruptcy case (.2); oversee electronic filing of the Joinder in Bankruptcy Case
with service to all interested parties (.6).
9/10/2009
Preparation for hearing on appointment of trustee; numerous telephone conferences
with J. Hall and J. Baron regarding issues relating to same; telephone conference
with L. Friedman regarding same; telephone conference with P. Kieffer regarding
same.
GMP 3.40 $500.00
$1,700.00
9/11/2009
Review order; analyze issues regarding same.
CWS 0.20 $195.00
$39.00
9/11/2009
Attendance at hearing on Motion to Appoint Trustee; preparation for same;
telephone conference with J. Hall regarding same; telephone conference with J. Hall
regarding same; telephone conference with P. Kieffer regarding same; telephone
conference with J. Hall regarding same; conference with J. Baron, S. Jones, J. Hall
regarding issues following appointment of trustee; telephone conference with N.
Resnick regarding same; telephone conference with E. Schurig and others regarding
same.
GMP 8.30 $500.00
$4,150.00
9/12/2009
Extended Telephone conference with E. Schurig, J. Baron and J. Hall regarding
various issues; telephone conference with J. Hall regarding same; telephone
conference with J. Hall regarding same; telephone conference with J. Hall regarding
same.
GMP 2.10 $500.00
$1,050.00
9/13/2009
Several telephone conferences with J. Hall and J. Baron regarding various issues;
review and analysis of email correspondence regarding same.
GMP 1.80 $500.00
$900.00
9/14/2009
Calendar hearing on Motion to Withdraw as Counsel for Debtor.
SLM 0.10 $100.00
$10.00
9/14/2009
Conference with C. Sherman, P. Kieffer and J. Hall at Ondova offices; several
telephone conferences with J. Baron and J. Hall regarding same.
GMP 3.00 $500.00
$1,500.00
9/15/2009
Review and revise Notice of Appearance.
CWS 0.30 $195.00
$58.50
9/15/2009 $100.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 5 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 3204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Calendar hearing on Emergency Motion to Impound Contents of Statement of Affairs
and Motion to Withdraw Reference of Bankruptcy Case.
SLM 0.20
$20.00
9/15/2009
Prepare and file Notice of Appearance on behalf of Jeff Baron.
SLM 0.40 $100.00
$40.00
9/15/2009
Numerous telephone conferences with J. Hall regarding various issues; numerous
telephone conferences with J. Baron regarding various issues; telephone conference
with J. Hall and various management individuals regarding operations of other
businesses; extended Telephone conference with J. Hall and J. Barron regarding
various issues.
GMP 2.40 $500.00
$1,200.00
9/15/2009
Telephone conference with J. Hall and J. Barron; telephone conference with J. Hall
and various managers of entities.
RVP 2.20 $350.00
$770.00
9/16/2009
Numerous telephone conferences with J. Hall regarding various issues; telephone
conference with M. Hayward regarding settlement issues; telephone conference with
J. Baron regarding various issues; telephone conference with J. Weilibinski;
telephone conference with C. Sherman.
GMP 2.00 $500.00
$1,000.00
9/17/2009
Calendar deadline to produce documents and 2004 Exam of Jeffrey Baron.
SLM 0.20 $100.00
$20.00
9/17/2009
Several telephone conferences with J. Baron, J. Hall and L. Friedman regarding
various issues; telephone conference with J. Weilibinski regarding 2004
Examination; telephone conference with Washington counsel regarding same;
telephone conference with J. Baron regarding same; telephone conference with J.
Hall regarding same.
GMP 1.50 $500.00
$750.00
9/18/2009
Attendance at 2004 Examination; conference with various counsel regarding various
issues relating to same and relating to settlement of Andrea case; several telephone
conferences with J. Hall and J. Baron regarding various issues; telephone
conference with L. Friedman and J. Baron and J. Hall regarding overall strategies.
GMP 4.70 $500.00
$2,350.00
9/21/2009
Telephone conference with J. Baron regarding various issues; telephone conference
GMP 3.20 $500.00
$1,600.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 6 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 4204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
with J. Hall regarding same; telephone conference with J. Baron regarding same;
conference with J. MacPete regarding settlement issues; telephone conference with
E. Taub regarding various issues.
9/22/2009
Telephone conference with J. Hall regarding various issues; telephone conference
with C. Sherman regarding various issues; review and analysis of pleadings filed in
Ondova bankruptcy case and voluminous email traffic among various parties
regarding various issues; telephone conference with C. Sherman, J. Baron and J.
Hall regarding various matters, including removal of personal files.
GMP 3.30 $500.00
$1,650.00
9/23/2009
Numerous telephone conferences with J. Hall and J. Baron regarding various
matters.
GMP 1.10 $500.00
$550.00
9/24/2009
Several telephone conferences with C. Sherman, J. Hall and J. Baron regarding
various matters.
GMP 0.70 $500.00
$350.00
9/25/2009
Several telephone conferences with J. Baron and J. Hall regarding various matters.
GMP 0.80 $500.00
$400.00
9/25/2009
Several telephone conferences with J. Baron and J. Hall regarding various matters.
GMP 0.90 $500.00
$450.00
9/28/2009
Telephone conference with J. Hall regarding hearing; attendance at hearing on
Motions to Seal, Withdraw Reference and Kieffer withdrawal; attendance at meeting
with J. Baron, S. Jones, J. Hall, R. Lurich regarding various strategy matters.
GMP 2.50 $500.00
$1,250.00
9/30/2009
Calendar continued hearing on Motion to Impound Contents of Statement of
Financial Affairs.
SLM 0.10 $100.00
$10.00
Total Hours: 61.40
9/30/2009
Expense Posting
Period: 09/01/2009 - 09/30/2009
$69.01
$0.00
C ($6,005.49)
Date Expense Description
Amount
9/10/2009
Copies and Mailout
$63.45
9/30/2009
Fax
$1.00
9/30/2009
PACER
$4.56
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 7 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 5204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
10/30/2009
Transfer from Trust Account: Iolta $0.00
$3,000.00
X ($9,005.49)
10/31/2009
Hourly Bill Posting
Period: 10/01/2009 - 10/31/2009
$13,552.00
$0.00
C $4,546.51
Date Timekeeper Hours Rate*
Charge*
10/1/2009
Calendar hearing on Trustee's Application to Employ Sherman & Yaquinto.
SLM 0.10 $100.00
$10.00
10/2/2009
Phone call with G. Pronske regarding claims treatment and analysis of claims.
JPK 0.20 $160.00
$32.00
10/2/2009
Obtain Schedules for J. Kathman's review.
LDW 0.20 $85.00
$17.00
10/5/2009
Prepare work product regarding claim amounts and contact information on each.
JPK 1.00 $160.00
$160.00
10/5/2009
Telephone conference with J. Hall regarding various issues; telephone conference
with J. Baron regarding same.
GMP 0.60 $500.00
$300.00
10/6/2009
Create work-product chart of unsecured claims and contacts at each creditor's
location.
JPK 2.60 $160.00
$416.00
10/6/2009
Telephone conference with J. Baron, J. Hall and S. Jones regarding intervention;
extended telephone conference with C. Sherman regarding same; draft proposed
language for Vogel Order; numerous further telephone conferences with J. Baron
and J. Hall regarding same.
GMP 4.00 $500.00
$2,000.00
10/7/2009
Numerous telephone conferences with J. Hall and J. Baron; conference with C.
Sherman, R. Urbanik, J. Hall and J. Baron at Sherman & Yaquinto offices;
conference with J. Hall and J. Baron regarding same.
GMP 3.00 $500.00
$1,500.00
10/8/2009
Telephone conference with J. Hall and J. Baron regarding stay issues; review
correspondence from S. Jones regarding same; telephone conference with J. Baron
regarding same; revisions to S. Jones correspondence to E. Taube.
GMP 1.00 $500.00
$500.00
10/9/2009 GMP 0.30 $500.00
$150.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 8 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 6204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Telephone conference with J. Hall regarding various issues, including stay.
10/12/2009
Calendar deadline to file response to Manila Industries' Motion for Relief from Stay.
SLM 0.10 $100.00
$10.00
10/12/2009
Extended Telephone conference with J. Baron regarding settlement and other
issues.
GMP 0.50 $500.00
$250.00
10/13/2009
Several telephone conferences with J. Hall regarding various issues.
GMP 0.40 $500.00
$200.00
10/14/2009
Conference with J. Hall and J. Baron at J. Hall's office regarding primarily issues
relating to whether case should be in Chapter 7 or Chapter 11.
GMP 2.00 $500.00
$1,000.00
10/15/2009
Calendar hearing on Manila and Nesphere's Motion to Lift Stay.
SLM 0.10 $100.00
$10.00
10/15/2009
Calendar hearing on Application to Employ Munsch Hardt.
SLM 0.10 $100.00
$10.00
10/16/2009
Calendar rescheduled hearing on Application to Employ Munsch Hardt; calendar
deadline to file objections to same.
SLM 0.20 $100.00
$20.00
10/19/2009
Telephone conference with J. Baron regarding various issues, including settlement
conference; attendance at settlement conference at P. Vogel's office.
GMP 4.50 $500.00
$2,250.00
10/20/2009
Extended Telephone conference with J. Baron regarding settlement and other
issues; telephone conference with J. Hall regarding same.
GMP 0.50 $500.00
$250.00
10/21/2009
Conference with G. Pronske regarding hearing on Motion to Impound Contents of
Statement of Financial Affairs.
SLM 0.20 $100.00
$20.00
10/26/2009
Review Motion to Lift Stay; draft Response in Opposition to Motion to Lift Stay; draft
correspondence to G. Pronske regarding same.
CWS 1.80 $195.00
$351.00
10/27/2009
Telephone conference with J. Hall regarding Response to Motion to Lift Stay; review
GMP 1.70 $500.00
$850.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 9 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 7204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
and analysis of draft of same; revisions to same; extended telephone conference
with J. Hall and J. Baron regarding same; review and analysis of Trustee's Response
to Motion to Lift Stay; review and analysis of Trust Response to Motion to Lift Stay.
10/27/2009
Attended hearing on Application to Employ Sherman and Yaquinto; draft
correspondence to G. Pronske regarding same.
CWS 0.50 $195.00
$97.50
10/27/2009
Revise Response to Motion to Lift Stay; format and file Response to Motion to Lift
Stay.
CWS 1.80 $195.00
$351.00
10/29/2009
Telephone conference with J. Hall regarding settlement issues; telephone
conference with J. Baron regarding same; telephone conference with J. Baron
regarding trusts potentially agreeing to pay Ondova estate funds unnecessarily;
review and analysis of Manassas Agreement regarding security agreement
questions.
GMP 1.20 $500.00
$600.00
10/30/2009
Telephone conference with E. Taub regarding payment of demand by C. Sherman;
telephone conference with J. Baron regarding same; draft correspondence to E.
Taub regarding same; conference with C. Stephenson regarding legal issues
presented by inadequate collateral descriptions and failure of Ondova to execute
Agreement; review and analysis of memo from C. Stephenson regarding same;
telephone conference with J. Baron regarding same; draft correspondence to E.
Taub regarding same.
GMP 2.40 $500.00
$1,200.00
10/30/2009
Perform research regarding domain name registration agreement; analyze research
and present to G. Pronske; draft correspondence to G. Pronske regarding research.
CWS 4.50 $195.00
$877.50
10/30/2009
Review and analyze potential objections to enforcement of security agreement.
VLD 0.40 $300.00
$120.00
Total Hours: 35.90
10/31/2009
Expense Posting
Period: 10/01/2009 - 10/31/2009
$2,672.80
$0.00
C $7,219.31
Date Expense Description
Amount
10/27/2009
Parking - Hearing
$4.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 10 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 8204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
10/30/2009
LexisNexis
$2,666.80
10/30/2009
Secretary of State
$1.00
10/30/2009
Secretary of State
$1.00
11/12/2009
Transfer from Trust Account: Iolta $0.00
$5,849.31
X $1,370.00
11/30/2009
Hourly Bill Posting
Period: 11/30/2009
$3,946.00
$0.00
C $5,316.00
Date Timekeeper Hours Rate*
Charge*
11/2/2009
Attend hearing on Motion to Impound Contents of Statement of Financial Affairs.
CWS 1.20 $195.00
$234.00
11/3/2009
Confer with G. Pronske regarding hearing on Motion to Impound Contents of
Statement of Financial Affairs.
CWS 0.10 $195.00
$19.50
11/3/2009
Telephone conference with J. Hall regarding various issues.
GMP 0.20 $500.00
$100.00
11/4/2009
Telephone conference with J. Hall regarding Motion to Lift Stay and regarding Kieffer
fees.
GMP 0.30 $500.00
$150.00
11/5/2009
Prepare notebook on hearing regarding Manila Industries and Netsphere's Motion
for Relief from Stay.
SLM 0.30 $100.00
$30.00
11/6/2009
Calendar deadline to file response to Trustee's Motion to Establish Procedures for
the Interim Compensation of Professionals and hearing regarding same.
SLM 0.20 $100.00
$20.00
11/6/2009
Telephone conference with J. Baron regarding various matters.
GMP 0.30 $500.00
$150.00
11/10/2009
Telephone conference with J. Hall regarding various issues.
GMP 0.20 $500.00
$100.00
11/13/2009
Telephone conference with J. Hall and J. Baron regarding UT stay issues.
GMP 1.00 $500.00
$500.00
11/14/2009
Telephone conference with J. Hall and J. Baron regarding Kieffer fee issues and UT
GMP 1.00 $500.00
$500.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 11 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 9204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
issues.
11/16/2009
Analyze issues regarding fee application for Wright, Ginsberg Brusilow.
CWS 0.20 $195.00
$39.00
11/16/2009
Extended Telephone conference with J. Hall and R. Urbanik regarding various
issues, including UT settlement, stay issues and overall settlement.
GMP 0.70 $500.00
$350.00
11/17/2009
Draft Limited Objection to Fee Application of Wright Ginsberg Brusilow (1.2); confer
with G. Pronske regarding same (.1).
CWS 1.30 $195.00
$253.50
11/17/2009
Review and analysis of Order Lifting Stay; draft correspondence to J. Baron
regarding same; review correspondence from J. Baron regarding same; draft
correspondence to J. Baron regarding same; review correspondence from J. Baron
regarding claims deadline; draft correspondence to S. Meiners regarding same;
review and analysis of draft of objection to Fee Application of Keiffer and revisions to
same; draft correspondence to J. Baron and J. Hall regarding same.
GMP 1.20 $500.00
$600.00
11/18/2009
Telephone conference with J. Hall regarding UT settlement situation and stay
issues.
GMP 0.30 $500.00
$150.00
11/19/2009
Telephone conference with J. Baron regarding preparation of Proof of Claim.
SLM 0.20 $100.00
$20.00
11/20/2009
Draft proof of claim; telephone conference with client regarding same.
SLM 0.50 $100.00
$50.00
11/24/2009
Conference with J. Baron regarding proof of claim; conference with G. Pronske
regarding same.
SLM 0.30 $100.00
$30.00
11/25/2009
Telephone conference with J. Baron regarding preparation of proof of claim; draft
Exhibit "A" to proof of claim; file proof of claim.
SLM 0.50 $100.00
$50.00
11/25/2009
Telephone conference with J. Hall and J. Baron regarding various issues; work on
Proof of Claim issues and preparation; telephone conference with J. Baron regarding
same.
GMP 1.20 $500.00
$600.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 12 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 10204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Total Hours: 11.20
11/30/2009
Expense Posting
Period: 11/30/2009
$251.00
$0.00
C $5,567.00
Date Expense Description
Amount
11/2/2009
Parking - Hearing
$10.00
11/17/2009
LexisNexis
$241.00
12/14/2009
Transfer from Trust Account: Iolta $0.00
$6,197.00
X ($630.00)
12/31/2009
Hourly Bill Posting
Period: 12/01/2009 - 12/31/2009
$13,797.50
$0.00
C $13,167.50
Date Timekeeper Hours Rate*
Charge*
12/1/2009
Telephone conference with J. Hall regarding various issues; review correspondence
from various parties regarding various issues.
GMP 0.40 $500.00
$200.00
12/2/2009
Telephone conference with R. Urbanic and J. Hall regarding various settlements;
telephone conference with J. Hall regarding same; conference with R. Patel
regarding same.
GMP 1.40 $500.00
$700.00
12/3/2009
Telephone conference with J. Hall regarding meeting with Schurig; travel to Austin to
attend meeting; conference with J. Baron, J. Hall, C. Capula, E. Taube, and E.
Schurig regarding various settlement and strategy issues; travel back to Dallas.
GMP 7.50 $500.00
$3,750.00
12/4/2009
Discuss strategy with regard to claims with G. Pronske.
JPK 0.20 $160.00
$32.00
12/7/2009
Telephone conference with J. Hall regarding various issues; telephone conference
with J. Baron regarding same.
GMP 0.60 $500.00
$300.00
12/9/2009
Draft Motion for Order Barring Certain Unfiled Claims.
JPK 3.60 $160.00
$576.00
12/10/2009
Continue Drafting Motion for Order Barring Certain Unfiled Claims.
JPK 3.10 $160.00
$496.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 13 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 11204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
12/10/2009
Attendance at hearing on Motions regarding payments for Vogel and Equivalent
Data; telephone conference with J. Baron regarding same.
GMP 2.60 $500.00
$1,300.00
12/11/2009
Calendar status conference.
SLM 0.10 $100.00
$10.00
12/11/2009
Communication with J. Kathman regarding research and comparison of all
Unsecured Creditors who are Contingent, Unliquidated and/or Disputed; conduct
comparison and validation of all Unsecured Creditors listed whose claims are listed
in these categories; review and confirm all Schedule F Creditors that were served
with the 341 Notice.
LDW 1.50 $85.00
$127.50
12/15/2009
Numerous telephone conferences with various parties.
GMP 0.70 $500.00
$350.00
12/16/2009
Calendar deadline to file response to Trustee's Motion for Approval of Compromise
and Settlement with Liberty Media; calendar deadline to file response to Trustee's
Motion for Authority to File Under Seal Settlement Agreement with Liberty Media;
calendar deadline to file response to Trustee' s Motion for Approval of Compromise
and Settlement with the Board of Regents, The University of Texas System; calendar
deadline to file response to Trustee' Motion for Authority to File Seal Settlement
Agreement with the Board of Regents, The University of Texas System.
SLM 0.40 $100.00
$40.00
12/16/2009
Telephone conference with L. Friedman regarding fee issue; telephone conference
with J. Baron regarding same; telephone conference with J. Hall regarding same;
telephone conference with L. Friedman regarding same; telephone conference with
J. Hall regarding same.
GMP 1.00 $500.00
$500.00
12/17/2009
Review and analysis of numerous correspondence from various parties, including
Judge Ferguson, P. Vogel, J. McPete, J. Hall, R. Lurick and others, regarding
payment orders; numerous telephone conferences with J. Hall and J. Baron
regarding same; telephone conference with L. Friedman regarding same.
GMP 2.10 $500.00
$1,050.00
12/18/2009
Calendar hearing on Debtor's Emergency Motion Asserting No Perfected Lien on
Debtor's Cash or Accounts and Abilitly to Utilize Such Property of the Estate.
SLM 0.10 $100.00
$10.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 14 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 12204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
12/18/2009
Further telephone conferences with J. Baron, J. Hall and L. Friedman regarding
payment issues.
GMP 1.10 $500.00
$550.00
12/23/2009
Extended Telephone conference with J. Baron regarding various issues.
GMP 0.40 $500.00
$200.00
12/28/2009
Review Motions for 2004 Examination (.5); draft Joinder in Motions for 2004
Examination (.5); draft Subpoena per G. Pronske (.5).
CWS 1.50 $195.00
$292.50
12/28/2009
Calendar deadline to file response to Trustee's Motion for an Examination of Jeffrey
Baron; calendar deadline to file response to Trustee's Motion for Examination of
Munish Krishan; calendar deadline to file response to Trustee's Motion for
Examination of Manish Aggrawal; calendar deadline to file response to Trustee's
Motion for Examination of Jill Johnson.
SLM 0.40 $100.00
$40.00
12/28/2009
Numerous telephone conferences with J. Baron and J. Hall regarding various issues.
GMP 0.80 $500.00
$400.00
12/29/2009
Calendar hearing on Trustee's Motions for 2004 Exam of M. Aggrawal, M. Krishan, J.
Johnson and J. Baron.
SLM 0.10 $100.00
$10.00
12/29/2009
Conference with J. Baron and J. Hall regarding various strategy and bigger picture
issues relating to resolution of various matters.
GMP 2.00 $500.00
$1,000.00
12/30/2009
Revise, format, file and serve Joinder in 2004 Examination Motions.
CWS 0.50 $195.00
$97.50
12/30/2009
Calendar deadline to file response to Motion to File Under Seal Intervenor's Brief in
Support of Objection to Debtor's Emergency Motion Asserting No Perfected Lien on
Debtor's Cash or Accounts and Ability to Utilize Such Property of the Estate.
SLM 0.10 $100.00
$10.00
12/30/2009
Telephone conference with J. Hall regarding various issues; conference with C.
Sherman, R. Urbanik, J. Baron and J. Hall regarding same.
GMP 2.60 $500.00
$1,300.00
12/31/2009
Review pleadings regarding cash collateral (.4); draft Joinder in Debtor's Motion
CWS 0.80 $195.00
$156.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 15 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 13204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
regarding cash collateral (.4).
12/31/2009
Telephone conference with J. Baron regarding Rassansky and Carrington Coleman;
telephone conference with M. Sutherland regarding Carrington Coleman claim;
telephone conference with J. Baron regarding same.
GMP 0.60 $500.00
$300.00
Total Hours: 36.20
12/31/2009
Expense Posting
Period: 12/01/2009 - 12/31/2009
$796.16
$0.00
C $13,963.66
Date Expense Description
Amount
12/4/2009
LexisNexis
$12.50
12/4/2009
LexisNexis
$50.00
12/4/2009
LexisNexis
$50.00
12/4/2009
LexisNexis
$58.00
12/4/2009
LexisNexis
$62.50
12/4/2009
LexisNexis
$7.25
12/9/2009
LexisNexis
$232.00
12/11/2009
LexisNexis
$37.50
12/11/2009
LexisNexis
$135.00
12/11/2009
LexisNexis
$25.00
12/30/2009
Copies and Mailout
$70.57
12/31/2009
PACER
$52.64
12/31/2009
PACER
$3.20
1/18/2010
Transfer from Trust Account: Iolta $0.00
$14,593.66
X ($630.00)
1/31/2010
Hourly Bill Posting
Period: 01/01/2010 - 01/31/2010
$9,304.50
$0.00
C $8,674.50
Date Timekeeper Hours Rate*
Charge*
1/4/2010
Telephone conference with J. Baron and J. Hall regarding various matters.
GMP 0.40 $550.00
$220.00
1/5/2010
Calendar deadline to file response to Trustee's and Quantec Parties' Joint Motion for
Relief.
SLM 0.10 $100.00
$10.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 16 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 14204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
1/5/2010
Revise, format and file Joinder in Debtor's Motion regarding Cash Collateral.
CWS 0.50 $225.00
$112.50
1/5/2010
Telephone conference with J. Baron regarding claims.
GMP 0.30 $550.00
$165.00
1/7/2010
Calendar hearing on Joint Motion for Relief from Stay to File Motion in District Court
Litigation.
SLM 0.10 $100.00
$10.00
1/7/2010
Conference Call with J. MacPete and G. Pronske; conference call with J. Razansky;
confer with G. Pronske regarding agreed motion.
CWS 0.80 $225.00
$180.00
1/11/2010
Confer with G. Pronske and analyze issues related to sealed objection documents;
draft limited motion to disclose documents filed under seal.
CWS 1.30 $225.00
$292.50
1/12/2010
Draft Agreed Limited Motion to Unseal Documents; draft proposed agreed order
regarding same.
CWS 1.20 $225.00
$270.00
1/13/2010
Calendar deadline to file response to Trustee's Motion for Authority to File Under
Seal or Restrict Access to Trustee's Reply Brief.
SLM 0.10 $100.00
$10.00
1/15/2010
Confer with J. Rasansky regarding proposed agreed motion and order allowing
limited disclosure of documents filed under seal.
CWS 0.40 $225.00
$90.00
1/15/2010
Motion Barring Unfiled Claims.
JPK 0.10 $160.00
$16.00
1/19/2010
Confer with V. Driver regarding claim objection issues.
CWS 0.20 $225.00
$45.00
1/19/2010
Motion to Bar Unfiled Claims.
JPK 2.90 $160.00
$464.00
1/19/2010
Revise Master Service List.
LDW 0.30 $85.00
$25.50
1/19/2010
Calendar deadline to file response to Friedman and Fieger's Motion to Lift Stay and
SLM 0.20 $100.00
$20.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 17 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 15204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
hearing regarding same.
1/19/2010
Analyze issues relating to 2004 examination; review and analyze issues relating to
motion to bar non-filed claims; correspondence with client regarding same; review
service issues correspondence with client regarding same.
VLD 0.70 $330.00
$231.00
1/20/2010
Telephone conference with J. Hall regarding issues relating to motion for barring
claims and 2004 exam issues; telephone conference with R. Urbanik regarding
motion to bar claims.
VLD 0.40 $330.00
$132.00
1/21/2010
Conference call with V. Driver and J. Hall regarding claim objection issues.
CWS 0.50 $225.00
$112.50
1/21/2010
Review Proof of Claim filed by Rasansky Law Firm.
JPK 0.10 $160.00
$16.00
1/21/2010
Telephone conference with J. Hall regarding claims objections and grounds
therefore; telephone conference with J. Rasansky regarding issues with motion to
bar claims; review proof of claim regarding J. Rasansky .
VLD 0.70 $330.00
$231.00
1/25/2010
Confer with V. Driver regarding objection to Joinders in Motion for 2004 Exam filed
by Netsphere Parties.
CWS 0.20 $225.00
$45.00
1/25/2010
Telephone conference with J. Hall and R. Urbanik regarding objection filed by
Netsphere parties to motion to take 2004 exam and issues relating to Baron's
participation; review and analyze objection filed by Netsphere parties to Motion for
2004 examination; preparation for hearing on motion for 2004 examination.
VLD 2.20 $330.00
$726.00
1/25/2010
Communication with V. Driver regarding preparation of Hearing Notebook on
Trustee's Motion for 2004 Exam of Manish Aggrawal, Munish Krishan, Jill Johnson
and Jeffrey Baron (.3); prepare Hearing Notebook regarding same (1.0).
LDW 1.30 $85.00
$110.50
1/26/2010
Draft and forward via email 2019 letter to all counsel.
SLM 0.30 $100.00
$30.00
1/26/2010
Preparation for hearing on 2004 exams; attend hearing on 2004 exams; analyze
VLD 6.10 $330.00
$2,013.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 18 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 16204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
issues relating to status conference in federal court; work on issues relating to
federal court hearing.
1/27/2010
Telephone conferences with potential counsel for fiduciary duty claim.
VLD 0.70 $330.00
$231.00
1/27/2010
Numerous telephone conferences with J. Baron, L. Friedman, and R. Lurich
regarding settlement of Friedman, Feiger claims and work on written agreements
regarding same.
GMP 5.00 $550.00
$2,750.00
1/28/2010
Calendar deadline to file response to Application to Employ Lain Faulkner; calendar
reset bench ruling on Debtor's Emergency Motion Asserting No Perfected Line on
Debtors Cash or Accounts and Ability to Utilize Such Property.
SLM 0.20 $100.00
$20.00
1/28/2010
Telephone conferences with potential referral for hearing; review and revise order on
2004 exam.
VLD 2.20 $330.00
$726.00
Total Hours: 29.50
1/31/2010
Expense Posting
Period: 01/01/2010 - 01/31/2010
$315.53
$0.00
C $8,990.03
Date Expense Description
Amount
1/5/2010
Copies and Mailout
$70.57
1/19/2010
Copies and Mailout
$244.96
2/18/2010
Transfer from Trust Account: Iolta $0.00
$9,304.50
X ($314.47)
2/28/2010
Hourly Bill Posting
Period: 02/01/2010 - 02/28/2010
$17,066.00
$0.00
C $16,751.53
Date Timekeeper Hours Rate*
Charge*
2/1/2010
Review and approve order on 2004 exam and joinder.
VLD 0.20 $330.00
$66.00
2/1/2010
Removed response deadline to Friedman & Feiger's Motion for Relief from Stay.
SLM 0.10 $100.00
$10.00
2/1/2010
Numerous telephone conferences with J. Baron and J. Hall regarding settlement
issues.
GMP 0.60 $550.00
$330.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 19 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 17204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
2/2/2010
Several telephone conferences with J. Baron and J. Hall regarding settlement
issues.
GMP 0.40 $550.00
$220.00
2/3/2010
Telephone conference with J. Baron and J. Hall regarding operational issues.
GMP 0.50 $550.00
$275.00
2/10/2010
Calendar deadline to file response to Application to Employ The Beckham Group
and Trustee's Motion for Order Approving Compromise and Settlement with River
Cruise; calendar hearing on Trustee's Application to Employ The Beckham Group.
SLM 0.10 $100.00
$10.00
2/10/2010
Telephone conference with J. Baron regarding Carrington Coleman and Grupo
Andrea; telephone conference with M. Andrews regarding Grupo Andrea; review and
analysis of Order regarding J. Baron 2004 Examination; review and analysis of Court
minutes regarding cash collateral ruling; telephone conference with J. Hall;
telephone conference with J. Baron regarding River Cruise settlement.
GMP 1.40 $550.00
$770.00
2/11/2010
Telephone conference with J. Baron regarding various issues.
GMP 0.40 $550.00
$220.00
2/12/2010
Telephone conferences with J. Baron and J. Hall regarding various issues, including
settlement terms.
GMP 0.60 $550.00
$330.00
2/19/2010
Review Proofs of Claim and client correspondence; draft Claim objections for Grupo
Andrea, Adlous-Rasansky and R. Shaffer.
CWS 3.40 $225.00
$765.00
2/19/2010
Review correspondence from Grupo Andrea counsel regarding claim; telephone
conference with M. Andrews regarding same; telephone conference with J. Baron
regarding same; telephone conference with J. Hall regarding same.
GMP 1.10 $550.00
$605.00
2/22/2010
Review correspondence from and draft correspondence to D. Pacione regarding
claim objections; conference calls with D. Pacione; draft and revise Claim objections;
file and serve claim objections; redact and format exhibits; confer with G. Pronske
regarding exhibits.
CWS 4.40 $225.00
$990.00
2/22/2010 GMP 0.60 $550.00
$330.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 20 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 18204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Numerous telephone conferences with J. Hall and J. Baron regarding same.
2/23/2010
Confer with C. Ladue regarding service of claim objections.
CWS 0.20 $225.00
$45.00
2/23/2010
Attendance at settlement conference.
GMP 8.00 $550.00
$4,400.00
2/24/2010
Attendance at settlement conference.
GMP 8.00 $550.00
$4,400.00
2/25/2010
Attendance at settlement conference.
GMP 4.00 $550.00
$2,200.00
2/26/2010
Numerous telephone conferences with regarding settlement with J. Baron, J. Hall, E.
Schurig, E. Taub and R. Urbanik.
GMP 1.70 $550.00
$935.00
2/27/2010
Telephone conference with J. Baron regarding settlement issues.
GMP 0.30 $550.00
$165.00
Total Hours: 36.00
2/28/2010
Expense Posting
Period: 02/01/2010 - 02/28/2010
$904.95
$0.00
C $17,656.48
Date Expense Description
Amount
2/22/2010
Copies and Mailout
$825.25
2/22/2010
Copies and Mailout
$78.87
2/28/2010
LexisNexis
$0.83
3/12/2010
Transfer from Trust Account: Iolta $0.00
$1,055.53
X $16,600.95
3/31/2010
Hourly Bill Posting
Period: 03/31/2010
$51,816.00
$0.00
C $68,416.95
Date Timekeeper Hours Rate*
Charge*
3/1/2010
Telephone conference with J. Baron and J. Hall regarding River Cruise settlement
issues; review correspondence from E. Schurig, R. Urbanik, D. Hinterliter, and K.
Thomason regarding resolution of tax issues; telephone conference with settlement
attorneys regarding settlement issues; numerous telephone conferences with J.
Baron and J. Hall regarding settlement issues; review correspondence from E. New
GMP 3.70 $550.00
$2,035.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 21 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 19204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
regarding issue relating to Grupo Andrea claim; telephone conference with J. Baron
regarding medical issues relating to appearance for deposition; telephone
conference with R. Urbanik regarding same; review correspondence from R. Urbanik
regarding same.
3/2/2010
Review correspondence from J. Hall regarding settlement status; numerous
telephone conferences with J. Baron and J. Hall regarding same; attendance at
Telephone conference with our side attorneys regarding settlement issues;
telephone conference with R. Urbanik regarding settlement status and regarding
2004 Examination of J. Baron; review correspondence from R. Urbanik regarding
March 5 2004 examination; telephone conference with J. Baron regarding same;
review and analysis of numerous 2004 Examination Motions filed by J. MacPete;
conference with C. Stephenson regarding responding to River Cruise settlement
motion; review and analysis of River Cruise settlement motion; review
correspondence E. Schurig regarding payment issues relating to K. Thomason;
review correspondence from K. Thomason regarding same; telephone conference
with K. Thomason regarding same; telephone conference with J. Baron regarding
same; factual research regarding 2004 Exam agreements and orders regarding J.
Baron to attempt to keep J. Baron from being deposed; draft correspondence to R.
Urbanik regarding same; telephone conference with J. Baron regarding same;
telephone conference with E. Schurig and other attorneys regarding issues relating
to payment of K. Thomason.
GMP 6.70 $550.00
$3,685.00
3/3/2010
Calendar deadline to file responses to Netsphere Parties' Motions for 2004 Exam of
Diamond Key, Manassas, Ron Sheridan and Adrian Taylor; calendar hearing
regarding same; calendar hearing on Application to Employ Lain Faulkner.
SLM 0.30 $100.00
$30.00
3/3/2010
Review Trustee's Motion to Approve Compromise with River Cruise; conference call
with J. Baron and G. Pronske regarding River Cruise settlement and Trustee's
motion regarding same; draft, format, file and serve Objection to Trustee's Motion to
Approve Compromise with River Cruise and exhibit thereto.
CWS 2.80 $225.00
$630.00
3/3/2010
Review correspondence from L. Friedman regarding breach of agreement to have J.
Baron pay; telephone conference with J. Baron regarding same; review
correspondence from R. Urbanik regarding 2004 Examination of J. Baron; telephone
conference with R. Urbanik regarding same; telephone conference with J. Baron and
GMP 6.20 $550.00
$3,410.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 22 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 20204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
J. Hall regarding same; review and analysis of Application to Employ Lain, Faulkner
as C. Sherman's accountants; draft correspondence to J. Baron regarding
non-payment to L. Friedman; review correspondence from J. Hall regarding doctor's
opinion regarding J. Baron deposition; review correspondence from J. Hall regarding
doctor's letter; review and analysis of River Cruise information to determine course
for objection to settlement; telephone conference with C. Stephenson regarding
same; telephone conference with J. Baron regarding same; telephone conference
with J. Baron and E. Schurig regarding same; review correspondence from E.
Schurig regarding PokerStar; review correspondence from J. Hall regarding standing
of deal points for settlement; telephone conference with J. Hall regarding same;
telephone conference with J. Baron regarding same; work on Objection to River
Cruise settlement; telephone conference with J. Baron regarding same; telephone
conference with C. Stephenson regarding same; finalize Objection to River Cruise
settlement for filing; telephone conference with J. Baron and E. Schurig regarding
correct ownership of River Cruise settlement funds.
3/4/2010
Telephone conference with J. Baron regarding Friedman settlement agreement;
review correspondence from J. Baron regarding same; review correspondence from
P. Vogel regarding settlement status; review correspondence from E. Taube
regarding status of 2004 Examinations; review and analysis of River Cruise
settlement draft and email from R. Urbanik regarding same; review correspondence
from C. Capua regarding settlement status; review correspondence from E. Schurig
regarding K. Thomason; review correspondence from C. Sherman regarding
settlement status; review and analysis of several emails from J. Hall regarding
settlement status; numerous telephone conferences with J. Baron regarding
settlement status; review and analysis of Order regarding payment of Vogel fees and
expenses; review correspondence from F. Perry regarding settlement status.
GMP 3.70 $550.00
$2,035.00
3/5/2010
Review Opposition to Objection to Claim of R. Shaffer.
CWS 0.30 $225.00
$67.50
3/5/2010
Review correspondence from J. Baron regarding 2004 examination; review and
analysis of C. Sherman's objections to Omnibus objection to creditor claims; review
and analysis of P. Vogel's new invoices; review correspondence from J. Baron
regarding Friedman settlement issues; review correspondence from J. MacPete, R.
Urbanik and J. Hall regarding 2004 examinations; review and analysis of E.
Schurig's revisions to settlement draft; review numerous emails from E. Schurig and
GMP 3.10 $550.00
$1,705.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 23 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 21204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
J. Hall regarding same; review correspondence from J. Portelo regarding River
Cruise settlement agreement; several Telephone conference with J. Baron and J.
Hall regarding various issues, mostly settlement.
3/8/2010
Review and analysis of J. Baron's comments to settlement agreement; review and
analysis of J. Hall's comments regarding same; several telephone conferences with
J. Baron and J. Hall regarding various issues, including settlement and River Cruise;
review and analysis of numerous emails regarding settlement from J. MacPete, J.
Hall, R. Urbanik, J. Baron and others regarding settlement issues; review and
analysis of proposed 2004 exam orders.
GMP 1.80 $550.00
$990.00
3/9/2010
Calendar deadline to provide Jeff Baron for 2004 exam.
SLM 0.10 $100.00
$10.00
3/9/2010
Telephone conference with J. Hall and J. Baron regarding settlement issues;
telephone conference with J. Hall, J. Baron, and E. Schurig regarding same;
settlement conference call with J. McPete, R. Urbanik, C. Sherman, E. Schurig, J.
Hall, C. Capua, F. Perry; Second telephone conference with J. Hall, M. McPete, R.
Urbanik, and others.
GMP 5.80 $550.00
$3,190.00
3/10/2010
Telephone conference with J. Baron regarding settlement issues; telephone
conference with J. McPete regarding same; extended telephone conference with J.
McPete, R. Urbanik, C. Capua, F. Perry, J. Hall and D. Hinterliter regarding
settlement issues; extended Telephone conference with J. Hall and J. Baron
regarding settlement issues; second Telephone conference with with everyone
regarding settlement; review and analysis of numerous correspondence from all
attorneys regarding Baron 2004 examination; review and analysis of proposed River
Cruise order approving settlement.
GMP 7.20 $550.00
$3,960.00
3/11/2010
Telephone conference with J. Hall and R. Urbanik regarding settlement issues;
telephone conference with J. Baron regarding same; telephone conference with J.
Baron and J. Hall regarding MacPete counteroffer; review and analysis of numerous
correspondence from all attorneys regarding settlement issues and settlement
status; review correspondence from J. Hall and responses from various lawyers
regarding how to put Krishan on "the hot seat".
GMP 5.10 $550.00
$2,805.00
3/12/2010 GMP 5.80 $550.00
$3,190.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 24 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 22204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Telephone conference with J. Baron and J. Hall regarding remaining settlement
issues; telephone conference with J. Hall regarding same; extended telephone
conference with R. Urbanik and J. Hall regarding same; telephone conference with
entire group of lawyers regarding settlement issues; conference with J. Baron and J.
Hall regarding same; review correspondence from R. Urbanik regarding same;
review correspondence from J. MacPete regarding same; telephone conference with
J. Hall regarding same; telephone conference with J. Baron regarding same.
3/15/2010
Telephone conference with J. Hall regarding settlement issues; telephone
conference with all attorneys regarding settlement issues; telephone conference with
E. Taub regarding channeling order possibilities; telephone conference with R.
Urbanik regarding same; second call with all attorneys regarding settlement issues;
third call with all attorneys without MacPete regarding settlement issues.
GMP 6.10 $550.00
$3,355.00
3/16/2010
Several telephone conferences with J. Hall regarding settlement issues; review and
analysis of proposed stipulation from M. Andrews regarding Grupo Andrea; review
and analysis of Termination of Engagement of K. Thomason; telephone conference
with J. Baron regarding same and regarding various settlement issues; review
several days of correspondence from all attorneys regarding settlement issues and
settlement status.
GMP 3.60 $550.00
$1,980.00
3/17/2010
Telephone conference with J. Hall and J. Baron regarding various settlement issues;
telephone conference with R. Urbanik regarding same; telephone conference with R.
Urbanik and E. Taube and C. Sherman regarding same; review and analysis of
numerous and extensive correspondence from E. Taube, C. Sherman, J. Hall, R.
Urbanik and J. MacPete regarding settlement issues; review correspondence from
E. Taube regarding findings and settlement negotiations.
GMP 2.10 $550.00
$1,155.00
3/18/2010
Review correspondence from E. Taube regarding settlement negotiations and
issues; review order entered by court regarding River Cruise settlement and
Telephone conference with J. Baron regarding same; several telephone conferences
with J. Hall and J. Baron regarding settlement issues; work on settlement terms
sheet; telephone conference with J. Baron regarding same; telephone conference
with J. Hall regarding same; draft correspondence to R. Urbanik regarding same;
telephone conference with R. Urbanik regarding same; draft correspondence to J.
MacPete regarding same; telephone conference with J. MacPete regarding same;
GMP 7.30 $550.00
$4,015.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 25 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 23204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
review correspondence from J. MacPete regarding same; review correspondence
from E. Schurig regarding same; review correspondence from R. Urbanik regarding
same; review correspondence from E. Taube regarding same; telephone conference
with E. Schurig and E. Taube regarding same; review and analysis of J. Hall's
proposed findings of fact and conclusions of law; preparation for settlement
conference at R. Urbanik's office.
3/19/2010
Perform research regarding relation back doctrine; confer with G. Pronske regarding
same.
CWS 0.80 $225.00
$180.00
3/19/2010
Several telephone conferences with J. Baron and J. Hall regarding settlement
conference; attendance at settlement conference at R. Urbanik's office; several
telephone conferences with J. Baron regarding settlement issues, mostly relating to
Oversee; several telephone conferences with R. Urbanik regarding settlement
issues; review and analysis of numerous attempts to agree to various findings.
GMP 6.20 $550.00
$3,410.00
3/22/2010
Review Motion Barring Claims and Objections filed to same.
JPK 0.50 $160.00
$80.00
3/22/2010
Confer with J. Kathman regarding Court correspondence.
CWS 0.40 $225.00
$90.00
3/22/2010
Review and analysis of Settlement and Indemnity Agreement; review
correspondence from A. Taylor regarding payment of fees and expenses of various
attorneys; review correspondence from J. Baron regarding same; several telephone
conferences with J. Baron regarding same; review and analysis of budget for fees of
trust submitted by J. Baron; telephone conference with J. Hall and J. Baron
regarding edits to settlement agreement draft; review correspondence from J. Baron
regarding same; review and analysis of numerous correspondence regarding tax
issues from various attorneys; draft correspondence to R. Urbanik regarding
settlement issues from estate; draft correspondence to J. Baron regarding
settlement status; telephone conference with R. Urbanik regarding settlement
issues; review correspondence from E. Taube regarding remaining settlement
issues; review correspondence from J. Baron regarding Newman and Newman;
telephone conference with J. Baron regarding same.
GMP 6.30 $550.00
$3,465.00
3/23/2010
Brief attention to Motion to Bar Unfiled Claims.
JPK 0.10 $160.00
$16.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 26 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 24204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
3/23/2010
Telephone conference with J. Baron regarding call with A. Tayor and trust lawyers;
telephone conference with J. Hall regarding same; review correspondence from D.
Hinterliter regarding remaining tax issues; draft further revisions to settlement
agreement terms; draft correspondence to E. Taube regarding same.
GMP 1.40 $550.00
$770.00
3/24/2010
Conference with Court Clerk regarding possible hearing regarding the Motion to
Disallow Claims.
LDW 0.30 $85.00
$25.50
3/24/2010
Review correspondence from J. Hall regarding Domain Jamboree; review
correspondence from R. Urbanik regarding Baron 2004 examination; telephone
conference with R. Urbanik regarding same; telephone conference with J. Hall
regarding same; telephone conference with J. Baron regarding same.
GMP 1.10 $550.00
$605.00
3/25/2010
Review and analysis of various correspondence regarding Domain Jamboree.
GMP 0.40 $550.00
$220.00
3/26/2010
Telephone conference with J. Baron regarding settlement issues; telephone
conference with J. Hall regarding same; telephone conference with R. Urbanik
regarding same.
GMP 1.20 $550.00
$660.00
3/29/2010
Review correspondence from J. Hall to A. Taylor regarding Domain Jamboree;
conference with M. Columbine regarding court correspondence regarding hearing on
Omnibus Objection to Claims; work on correspondence to E. Schurig regarding fees
and expenses of trust; telephone conference with J. Baron regarding same;
telephone conference with J. Hall regarding same; review and analysis of changes
to letter from J. Baron.
GMP 2.10 $550.00
$1,155.00
3/30/2010
Review Objections filed to Motion to Bar Unfiled Claims.
JPK 0.50 $160.00
$80.00
3/30/2010
Review correspondence from R. Urbanik regarding Baron 2004 examination;
finalization of letter to E. Schurig regarding attorneys fees and expenses; work on
settlement counter to terms sheet; numerous telephone conferences with J. Baron
regarding same; telephone conference with R. Urbanik regarding same; review
correspondence from J. MacPete regarding same.
GMP 2.70 $550.00
$1,485.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 27 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 25204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
3/31/2010
Prepare Notice of Hearing on Motion to Disallow Claims (.3); oversee electronic filing
of same with service to all interested parties (.4).
LDW 0.70 $85.00
$59.50
3/31/2010
Review and revise notice of hearing on Motion to bar claims; confer with L. Whatley
regarding same.
CWS 0.50 $225.00
$112.50
3/31/2010
Work on counter to Terms Draft Sheet; several telephone conferences with J. Baron
regarding same; review and analysis of various discovery motions and
correspondence from J. Baron regarding same.
GMP 2.10 $550.00
$1,155.00
Total Hours: 99.00
3/31/2010
Expense Posting
Period: 03/31/2010
$70.42
$0.00
C $68,487.37
Date Expense Description
Amount
3/31/2010
LexisNexis
$5.94
3/31/2010
PACER
$64.48
4/30/2010
Hourly Bill Posting
Period: 04/30/2010
$46,535.00
$0.00
C $115,022.37
Date Timekeeper Hours Rate*
Charge*
4/1/2010
Several telephone conferences with and J. Baron and with J. Hall regarding various
matters; telephone conference with E. Schurig and J. Baron regarding various
matters; review correspondence from E. New regarding hearing agenda and
response to same.
GMP 1.10 $550.00
$605.00
4/2/2010
Confer with L. Whatley regarding witness and exhibit lists for pending motions.
CWS 0.20 $225.00
$45.00
4/2/2010
Telephone conference with counsel regarding settlement issues.
GMP 5.10 $550.00
$2,805.00
4/3/2010
Review correspondence from M. McPete regarding settlement issues; draft
correspondence to J. Baron regarding same; review and analysis of tax memoranda;
review and analysis of various correspondence from J. Baron.
GMP 1.40 $550.00
$770.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 28 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 26204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
4/5/2010
Attendance at settlement telephone conference meeting; review correspondence
from J. Baron regarding fees of trust; telephone conference with J. Baron regarding
same.
GMP 8.00 $550.00
$4,400.00
4/6/2010
Attendance at settlement meetings; review correspondence from C. Capua
regarding trust issues; telephone conference with E. Taube regarding various
settlement issues; review and analysis of PhoneCards issues; telephone conference
with J. Baron regarding same; telephone conference with J. MacPete regarding
same.
GMP 8.00 $550.00
$4,400.00
4/7/2010
Several telephone conferences with R. Urbanik regarding Phone Cards issue;
telephone conference with E. Taube regarding release for E. Schurig; several
telephone conferences with J. Hall regarding same; joint conference call with all
attorneys regarding remaining settlement issues; several telephone conferences
with J. Baron regarding same.
GMP 6.00 $550.00
$3,300.00
4/8/2010
Review correspondence from J. Hall regarding Anheiser Busch; review
correspondence from R. Urbanik regarding River Cruise; telephone conference with
J. Baron regarding same; draft correspondence to R. Urbanik regarding same;
telephone conference with R. Urbanik regarding various issues.
GMP 0.80 $550.00
$440.00
4/9/2010
Telephone conference with various counsel regarding settlement issues; review
correspondence from J. Hall regarding River Cruise; review correspondence from J.
Baron regarding items to be completed prior to settlement.
GMP 3.20 $550.00
$1,760.00
4/12/2010
Calendar hearing on Motion for Order Barring Certain Claims.
SLM 0.10 $100.00
$10.00
4/12/2010
Review correspondence from J. Hall regarding River Cruise; telephone conference
with counsel regarding settlement issues, including release issues; review
correspondence from J. Hall regarding Domain Jamboree; draft correspondence to
J. Baron regarding River Cruise; review correspondence from R. Urbanik regarding
name deletions.
GMP 3.60 $550.00
$1,980.00
4/13/2010 GMP 1.30 $550.00
$715.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 29 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 27204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Review correspondence from E. Taube regarding release issues; telephone
conference with E. Taube regarding same; telephone conference with J. Baron
regarding same; review correspondence from J. Baron regarding items to be
completed and update to same.
4/14/2010
Prepare and forward to court transcript order for hearing on 4/7/10 regarding Motions
for 2004 Exam of Diamond Key, A. Taylor, Manassas and R. Sheridan; telephone
conference with Judge Jernigan's ecro clerk regarding same.
SLM 0.30 $100.00
$30.00
4/14/2010
Draft correspondence to various counsel regarding release of attorney issues in the
settlement; review correspondence from numerous emails regarding same issue of
releases of attorneys and draft of responses; telephone conference with J. Baron
regarding same; telephone conference with J. Hall regarding same; telephone
conference with R. Urbanik regarding same; telephone conference with E. Taube
regarding same; telephone conference with C. Sherman regarding same; work on
referral for Cook Islands trustee; telephone conference with J. Baron regarding
same; telephone conference with R. Urbanik regarding attorney release situation;
review correspondence from M. Taylor and R. Urbanik regarding discovery issues.
GMP 4.30 $550.00
$2,365.00
4/15/2010
Review and analysis of disciplinary rules regarding releases of counsel and
prevention of further actions; telephone conference with R. Urbanik and E. Taube
regarding release issues; telephone conference with J. Baron regarding same;
telephone conference with J. Hall regarding same; review and analysis of
information regarding payment of Vogel invoices; review and analysis of Jernigan
transcript regarding releases of attorneys; draft correspondence to attorneys
regarding transcript language and regarding release issue; review and analysis of
correspondence from E. Taube regarding possibility of plan in lieu of settlement;
telephone conference with J. Baron regarding same.
GMP 2.30 $550.00
$1,265.00
4/16/2010
Review and analysis of latest deal points from NetSphere and correspondence from
J. MacPete regarding same; telephone conference with J. Baron regarding same;
review correspondence from C. Capua regarding attorney releases; review
correspondence from R. Urbanik regarding River Cruise; review and analysis of
numerous emails regarding Schurig release situation; telephone conference with J.
MacPete regarding same; telephone conference with J. Baron regarding same;
telephone conference with E. Taube and R. Urbanik regarding same.
GMP 3.20 $550.00
$1,760.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 30 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 28204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
4/19/2010
Review correspondence from J. Baron regarding Village Trust fees and expenses;
review and analysis of pleadings regarding withdrawal of J. Hall as attorney; review
and analysis of Village Trust attorney fee statements; telephone conference with J.
Baron regarding same; review correspondence from E. Taube regarding attempting
to negotiate with C. Sherman directly on plan in lieu of settlement.
GMP 1.30 $550.00
$715.00
4/20/2010
Review correspondence from E. Schruig regarding registrar negotiation issues;
review correspondence from J. Baron regarding Village Trust fee issues; review and
analysis of 2004 Examination Orders; review correspondence from J. Portela
regarding River Cruise; several telephone conferences with J. Baron regarding
various issues.
GMP 1.70 $550.00
$935.00
4/21/2010
Review correspondence from A. Taylor regarding distribution; review
correspondence from E. Taube regarding plan ideas and release issues; telephone
conference with E. Taube regarding same; telephone conference with J. Baron
regarding same; telephone conference with all counsel regarding settlement issues;
telephone conference with J. Baron regarding same.
GMP 4.20 $550.00
$2,310.00
4/22/2010
Calendar status conference and possible Rule 2004 Exams pursuant to Order.
SLM 0.10 $100.00
$10.00
4/22/2010
Review and analysis of Operating Report of Ondova; review correspondence from
various counsel regarding settlement issues; telephone conference with J. Baron
regarding same; telephone conference with all counsel regarding settlement issues;
review correspondence from J. Baron regarding River Cruise.
GMP 3.20 $550.00
$1,760.00
4/23/2010
Review and analysis of information regarding collateralizing of domain names; work
on agreement regarding same; telephone conference with J. Baron regarding same;
review and analysis of Draft Settlement Agreement and email from M'Lou Patton
regarding same and regarding outstanding issues; review correspondence from C.
Sherman regarding Judge Jernigan transcript regarding releases; review
correspondence from J. Baron regarding River Cruise; telephone conference with all
counsel regarding remaining settlement issues.
GMP 4.70 $550.00
$2,585.00
4/26/2010 GMP 3.40 $550.00
$1,870.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 31 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 29204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Review and analysis of R. Lurich email and agreement to pay fees; telephone
conference with J. Baron regarding same; telephone conference with E. Taube
regarding various issues; review and analysis of information from E. Schurig
regarding new registrar agreement; attendance at status hearing before Judge
Ferguson; telephone conference with various counsel following status hearing;
telephone conference with J. Baron regarding results of status hearing.
4/27/2010
Review correspondence from J. MacPete regarding status of settlement
negotiations; review correspondence from R. Urbanik regarding same; telephone
conference with J. Baron regarding same.
GMP 0.70 $550.00
$385.00
4/27/2010
Attendance at settlement conference; telephone conference with J. Baron regarding
various settlement issues; telephone conference with E. Taube regarding same;
telephone conference with R. Urbanik regarding same.
GMP 3.70 $550.00
$2,035.00
4/28/2010
Calendar hearing and deadline to file response to First Interim Fee Application of
Munsch Hardt.
SLM 0.10 $100.00
$10.00
4/29/2010
Telephone conference with all counsel regarding settlement issues; review and
analysis of Pokerstar License Agreement; several telephone conferences with J.
Baron regarding same.
GMP 5.10 $550.00
$2,805.00
4/30/2010
Calendar continuance of status conference.
SLM 0.10 $100.00
$10.00
4/30/2010
Attendance at settlement conference at Munch Hart.
GMP 8.10 $550.00
$4,455.00
Total Hours: 85.30
4/30/2010
Expense Posting
Period: 04/30/2010
$337.81
$0.00
C $115,360.18
Date Expense Description
Amount
4/1/2010
Copies and Mailout
$96.91
4/21/2010
Transcript
$240.90
5/31/2010
Hourly Bill Posting
Period: 05/31/2010
$47,040.50
$0.00
C $162,400.68
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 32 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 30204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Date Timekeeper Hours Rate*
Charge*
5/3/2010
Review and analysis of J. Baron comments to release language; review and analysis
of G. Lyon comments regarding same; attendance at settlement conference; review
correspondence from J. Baron regarding Michael Nelson; review correspondence
from G. Lyon regarding collateralizing domain names; review correspondence from
C. Becket regarding tax issues; review correspondence from G. Lyons regarding
Friedman settlement agreement; review correspondence from R. Puri regarding
Verisign; review and analysis of Friedman Motion to Lift Stay; review and analysis of
Settlement Draft from M. Patton; review and analysis of settlement language from G.
Lyon; Review and analysis of J. Baron comments to settlement agreement;
attendance at settlement conference at Munch Hart.
GMP 8.20 $550.00
$4,510.00
5/4/2010
Calendar deadline to file response to Friedman & Feiger's Motion to Lift Stay and
hearing regarding same.
SLM 0.10 $100.00
$10.00
5/4/2010
Review correspondence from C. Sherman regarding massive changes to settlement
agreement; review and analysis of response letter of A. Taylor to fee issues;
telephone conference with J. Baron regarding same; numerous telephone
conferences with R. Urbanik and J. MacPete and J. Baron regarding settlement
issues; review correspondence from R. Urbanik regarding estate cash needs;
telephone conference with J. Baron regarding same; review correspondence from C.
Sherman regarding Verisign payment needs; review correspondence from R. Lurich
regarding settlement agreement and stay motion; review correspondence from J.
Baron regarding Rasansky.
GMP 3.10 $550.00
$1,705.00
5/5/2010
Attendance at hearing on status conference motion; telephone conference with J.
Baron regarding results of same; review and analysis of new settlement draft from
M. Patton; telephone conference with J. Baron regarding same; review and analysis
of ICANN breach letter; review and analysis of information requested by J. Baron
regarding reps and warranties from Village Trust and E. Schurig; draft
correspondence to J. Baron regarding status conference ruling; review
correspondence from G. Lyon regarding same; telephone conference with all
counsel regarding new settlement agreement draft.
GMP 4.30 $550.00
$2,365.00
5/6/2010 GMP 5.60 $550.00
$3,080.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 33 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 31204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Conference with J. Baron regarding various settlement issues; telephonic settlement
conference; review correspondence from D. Nelson regarding domain names;
review and analysis of G. Lyon's comments to settlement; review and analysis of
Order to be uploaded by R. Urbanik regarding status conference ruling.
5/7/2010
Review correspondence from E. Taube regarding various issues; telephone
conference with J. Baron regarding settlement issues.
GMP 0.40 $550.00
$220.00
5/10/2010
Calendar deadlines pursuant to Order Scheduling Hearing and Other Matters
entered 5/7/10 regarding possible conversion and settlements.
SLM 0.20 $100.00
$20.00
5/10/2010
Review correspondence from J. Baron regarding trust distribution; Review
correspondence from J. MacPete regarding Phone Cards Order; Review and
analysis of Oversee language; Review and analysis of Escrow Agreement language;
Telephone conference with J. Baron regarding same; Review and analysis of
Netsphere changes to security agreement.
GMP 2.20 $550.00
$1,210.00
5/11/2010
Conference with all counsel at Munch Hart regarding settlement issues.
GMP 3.50 $550.00
$1,925.00
5/12/2010
Review correspondence from R. Urbanik regarding domain name deletions; review
and analysis of tax revisions from G. Lyon; review and analysis of findings language
and reps and warranties language from G. Lyons; attendance at settlement
conference; attendance at second settlement conference.
GMP 4.50 $550.00
$2,475.00
5/13/2010
Calendar deadline to file response to Verisign's Motion for Allowance of
Administrative Claim, to Compel Assumption or Rejection of Executory Contract, or
in the Alternative, for Relief from Stay.
SLM 0.10 $100.00
$10.00
5/13/2010
Review and analysis of G. Lyon's comments to Pokerstar Agreement; review and
analysis of G. Lyon's revisions to intellectual property language; settlement
conference at Munch Hart.
GMP 3.80 $550.00
$2,090.00
5/14/2010
Review and analysis of revised settlement agreement from M. Pattton; review
correspondence from J. Baron regarding mediation paper; review and analysis of
GMP 2.10 $550.00
$1,155.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 34 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 32204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Motion to Convert; telephone conference with R. Urbanik regarding same; telephone
conference with J. Baron regarding same; review and analysis of Version 6 of
Settlement Draft agreement.
5/17/2010
Calendar deadline to file response to Trustee's Motion to Convert Case to Chapter 7.
SLM 0.10 $100.00
$10.00
5/17/2010
Attendance at settlement conference at Munch Hart; telephone conference with C.
Capua, J. Baron, and E. Schurig regarding various release and other issues.
GMP 6.10 $550.00
$3,355.00
5/18/2010
Calendar hearing on Verisign's Motion for Allowance and Payment of Administrative
Claim, to Compel Assumption or Rejection of Executory Contract, or Relief from
Stay.
SLM 0.10 $100.00
$10.00
5/18/2010
Prepare Notice of Withdrawal of Motion Barring Certain Scheduled Claims (.5);
oversee electronic filing of same (.4); confirmation of removal of hearing from
Judge's Clerk (.3).
LDW 1.20 $85.00
$102.00
5/18/2010
Attendance at settlement conference.
GMP 5.00 $550.00
$2,750.00
5/19/2010
Several telephone conferences with J. Baron regarding mediation sessions with
Judge Stickney; review and analysis of Pokerstar language submitted by J. Baron;
review and analysis of Intellectual property language submitted by J. Baron.
GMP 1.60 $550.00
$880.00
5/20/2010
Attendance at mediation session with Judge Stickney; attendance at conversion
hearing and hearing on Verisign Motion for Administrative Expense; several
conferences with J. Baron regarding same.
GMP 4.40 $550.00
$2,420.00
5/24/2010
Calendar continued hearing on Motion to Convert Case to Chapter 7 and Verisign's
Motion for Allowance and Payment of Administrative Claim.
SLM 0.10 $100.00
$10.00
5/24/2010
Review and analysis of G. Lyon's comments to settlement agreement; telephone
conference with attorneys regarding intellectual property issues; review
correspondence from R. Urbanik regarding same; review correspondence from J.
Baron regarding same.
GMP 3.10 $550.00
$1,705.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 35 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 33204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
5/25/2010
Confirm service of Notice of Withdrawal of Motion for Order Barring Certain
Scheduled Claims.
LDW 0.10 $85.00
$8.50
5/25/2010
Review and analysis of J. Baron's comments to IP language; review correspondence
from J. Baron to E. Schurig regarding comments to IP language.
GMP 0.80 $550.00
$440.00
5/26/2010
Review and analysis of language for IP proposed by J. Cone; review and analysis of
settlement agreement drafts and proposed change language; several telephone
conferences with J. Baron regarding same.
GMP 2.70 $550.00
$1,485.00
5/27/2010
Attendance at mediation session with Judge Stickney; conference with J. Baron
regarding same; attendance at hearing on Motion to Lift Stay of Friedman & Feiger.
GMP 2.80 $550.00
$1,540.00
5/28/2010
Attendance at mediation session with Judge Stickney; conference with J. Baron
regarding same.
GMP 2.00 $550.00
$1,100.00
5/29/2010
Attendance on telephone conference call with all parties; conference with J. Baron
regarding same; telephone conference with R. Urbanik regarding same.
GMP 6.00 $550.00
$3,300.00
5/30/2010
Extended settlement conference telephone meetings with all counsel, and
conferences with J. Baron regarding same.
GMP 8.00 $550.00
$4,400.00
5/31/2010
Extended settlement conference telephone meetings with all counsel, and
conferences with J. Baron regarding same.
GMP 5.00 $550.00
$2,750.00
Total Hours: 87.20
5/31/2010
Expense Posting
Period: 05/31/2010
$87.62
$0.00
C $162,488.30
Date Expense Description
Amount
5/19/2010
Copies and Mailout
$87.62
6/30/2010
Hourly Bill Posting
Period: 06/30/2010
$54,322.00
$0.00
C $216,810.30
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 36 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 34204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Date Timekeeper Hours Rate*
Charge*
6/1/2010
Review and analysis of Order regarding Friedman & Feiger Stay Motion; telephone
conference with attorneys regarding settlement issues regarding IP issues; draft
correspondence to R. Urbanik regarding names requested by the Trustee to be
retained; review correspondence from R. Puri regarding restriction language
regarding IP language; draft correspondence to R. Puri regarding same; review
correspondence from J. Cone regarding software issues; review correspondence
from E. Schurig regarding various tax issues; second telephone conference with
various counsel regarding settlement issues, primarily IP related.
GMP 4.70 $550.00
$2,585.00
6/2/2010
Attendance at settlement meeting; attendance at hearing on Motion to Convert.
GMP 4.90 $550.00
$2,695.00
6/3/2010
Calendar continued hearing on Motion to Convert with conditions pertaining to
settlement.
SLM 0.10 $100.00
$10.00
6/3/2010
Conference with counsel regarding settlement issues; extended telephone
conference with J. MacPete regarding same; telephone conference with R. Urbanik
and J. MacPete regarding same; telephone conference with J. Baron regarding
same; telephone conference with J. Cone and J. Baron regarding same.
GMP 4.00 $550.00
$2,200.00
6/4/2010
Review correspondence from M. Nelson regarding resignation of trustee and
protector; review correspondence from E. Shurig regarding same; review
correspondence from J. Cone regarding representation issues; review and analysis
of red-line of settlement agreement provided by M. Patton; telephone conference
with J. Baron regarding same; review correspondence from G. Nee regarding
Webncc; telephone conference with J. Baron regarding issues relating to J. Cone
representation; preparation for telephone settlement conference on June 5; review
correspondence from J. Baron regarding comments to settlement agreement; review
and analysis of settlement draft changes from M. Patton; review and analysis of J.
Cone's paragraph 12 changes.
GMP 3.10 $550.00
$1,705.00
6/5/2010
Conference with J. Baron regarding settlement conference; attendance at telephonic
settlement conference with counsel and J. Baron.
GMP 5.00 $550.00
$2,750.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 37 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 35204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
6/6/2010
Conference with J. Baron regarding settlement conference; attendance at telephonic
settlement conference with counsel and J. Baron, mostly regarding IP language and
concepts; telephone conferences with J. Cone regarding same.
GMP 5.00 $550.00
$2,750.00
6/7/2010
Conference with all counsel regarding settlement issues, mostly IP; review
correspondence from J. Baron regarding same; several telephone conferences with
J. Baron regarding same; work with J. Baron regarding Webncc procedures and
transfers; work with R. Puri regarding same; draft correspondence to R. Puri
regarding same; review correspondence from R. Puri and G. Nee regarding same;
work on IP issues, including drafts of settlement agreement language; work on
Gardere Wynn Order and telephone conferences with J. Baron regarding same;
work on PhoneCards language; telephone conference with J. Baron regarding same;
second settlement conference call with all attorneys.
GMP 8.50 $550.00
$4,675.00
6/8/2010
Review correspondence from E. Taube regarding resignations and changing
counsel; telephone conference with E. Taube regarding same; telephone conference
with J. Baron regarding same; review correspondence from G. Nee regarding
Webncc issues; review correspondence from J. Baron regarding nameservers;
exented telephone conference with J. MacPete regarding various settlement issues;
telephone conference with J. Baron regarding same; settlement telephone
conference with all counsel.
GMP 5.10 $550.00
$2,805.00
6/9/2010
Document Production of Settlement Agreement.
LDW 0.20 $85.00
$17.00
6/9/2010
Review correspondence from C. Sherman regarding deadline imposed to settle;
review correspondence from J. Cone regarding IP issues; telephone conference with
J. Baron regarding same; review correspondence from J. Baron regarding D. Wilson;
work on issues relating to Webncc; work on IP issues; numerous telephone
conferences with J. Baron regarding same; review and analysis of newest redlined
draft of settlement agreement and telephone conference with J. Baron regarding
same; conference with J. MacPete, J. Baron and G. Lyon regarding attempting to
settle IP issues.
GMP 8.30 $550.00
$4,565.00
6/10/2010
Several telephone conferences with J. Baron regarding settlement issues.
GMP 1.20 $550.00
$660.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 38 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 36204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
6/11/2010
Several telephone conferences with J. Baron regarding settlement issues.
GMP 0.80 $550.00
$440.00
6/12/2010
Attendance at telephone settlement conference; conference with J. Baron regarding
same.
GMP 4.20 $550.00
$2,310.00
6/13/2010
Conference with J. Baron; attendance at telephone settlement conference with all
attorneys.
GMP 4.50 $550.00
$2,475.00
6/14/2010
Review and analysis of latest settlement redline version; review and analysis of
revisions to settlement agreement by E. Taube; review correspondence from J.
Baron regarding changes to security agreement regarding domain name; telephone
conference with J. Baron regarding email addresses; telephone conference with J.
Baron regarding Rasansky issues; review correspondence from C. Capua regarding
privacy service; telephone conference with J. Baron regarding trustee excusing
attendance of Krishan from settlement conference; telephone conference with G.
Lyon regarding same; review and analysis of Trustee's Motion for Reconsideration of
Order regarding attendance of Krishan; telephone conference with E. Taube
regarding Baron/Shurig offline issues; review correspondence from J. MacPete
regarding paragraph 12 IP issues; telephone conference with J. Baron regarding
same; telephone conference with J. MacPete regarding same; draft correspondence
to all regarding proposals for remaining issues.
GMP 5.60 $550.00
$3,080.00
6/15/2010
Review correspondence from J. MacPete regarding summary of all issues needed to
be resolved; telephone conference with J. Baron regarding same; telephone
conference with J. MacPete regarding same; work on Webncc issues; telephone
conference with J. Baron regarding same; review correspondence from J. Baron
regarding resolution of remaining issues; review correspondence from J. Cone
regarding transferability of software; telephone conference with J. Baron regarding
same; review correspondence from R. Urbanik regarding settlement issues and
meeting with C. Sherman; telephone conference with J. Baron regarding business
plan; telephone conference with R. Urbanik regarding same; review correspondence
from J. Baron regarding same.
GMP 4.30 $550.00
$2,365.00
6/16/2010
Review correspondence from R. Urbanik regarding B. Dean; telephone conference
GMP 0.60 $550.00
$330.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 39 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 37204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
with J. Baron regarding Michael Nelson; review correspondence from J. Baron
regarding email addresses; telephone conference with J. Baron regarding same;
telephone conference with C. Sherman regarding same.
6/17/2010
Settlement conference with all counsel at Munch Hart; review correspondence from
E. Taube regarding threats from Trustee regarding Blue Horizons names and other
threats; draft correspondence to J. MacPete regarding responses to all issues
relating to IP issues; telephone conference with J. Baron regarding same; telephone
conference with J. MacPete regarding same; review correspondence from G. Lyon
regarding order in PhoneCards case.
GMP 3.20 $550.00
$1,760.00
6/18/2010
Attendance at court ordered settlement conference at Munch Hart.
GMP 6.00 $550.00
$3,300.00
6/19/2010
Attendance at court ordered settlement conference at Munch Hart.
GMP 6.00 $550.00
$3,300.00
6/20/2010
Review correspondence from G. Lyon to E. Shurig regarding fee dispute; work on
issues relating to Shurig disputes and agreements; draft correspondence to J. Baron
regarding remaining issues with E. Shurig; review correspondence from D. Nelson
regarding privacy service.
GMP 0.80 $550.00
$440.00
6/21/2010
Work on settlement issues with E. Taube; several emails with E. Taube regarding
same; conference with J. Baron and G. Lyons regarding settlement; review
correspondence from M. Barsi regarding privacy service issues; review
correspondence from E. Shurig regarding tax issues; conference with C. Sherman,
R. Urbanik, J. Baron and G. Lyon regarding settlement issues.
GMP 5.50 $550.00
$3,025.00
6/22/2010
Calendar response deadline and hearing on Munsch Hardt's Second Interim
Application for Allowance of Fees and Expenses.
SLM 0.10 $100.00
$10.00
6/22/2010
Conference with J. Baron and G. Lyon regarding settlement issues; draft
correspondence to J. Baron regarding settlement; review correspondence from R.
Urbanik regarding River Cruise; attendance at hearing regarding conversion and
settlement.
GMP 2.80 $550.00
$1,540.00
6/23/2010 GMP 0.80 $550.00
$440.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 40 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 38204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Review and analysis of Revised Settlement Agreement and correspondence from R.
Puri regarding same; telephone conference with J. Baron regarding same.
6/28/2010
Review correspondence from A. Taylor regarding fee dispute; review
correspondence from M. Rosenblatt regarding additional trust expenses; telephone
conference with J. Baron regarding same; work on Paragraph 6C regarding
collateralization; telephone conference with R. Urbanik and C. Sherman regarding J.
MacPete issues relating to Grupo Andrea; telephone conference with J. Baron
regarding same.
GMP 2.10 $550.00
$1,155.00
6/29/2010
Review and analysis of Revised Settlement Agreement; telephone conference with
J. Baron regarding same; telephone conference with R. Urbanik regarding California
freeze order relating to Blue Horizon names; review correspondence from J.
MacPete regarding Grupo Andrea representation.
GMP 1.70 $550.00
$935.00
Total Hours: 99.10
6/30/2010
Expense Posting
Period: 06/30/2010
$12.40
$0.00
C $216,822.70
Date Expense Description
Amount
6/30/2010
PACER
$12.40
7/31/2010
Hourly Bill Posting
Period: 07/31/2010
$23,720.00
$0.00
C $240,542.70
Date Timekeeper Hours Rate*
Charge*
7/1/2010
Review correspondence from G. Lyon regarding Domain Jamboree; Review
correspondence from G. Lyon regarding amended paragraph 20 of Settlement
Agreement; Telephone conference with G. Lyon regarding same; Review
correspondence from M. Bell regarding revised version of Settlement Agreement;
Review and analysis of revised version of Settlement Agreement; Telephone
conference with J. Baron regarding same; Telephone conference with D. Nelson
regarding email accounts; Telephone conference with J. Baron regarding same;
Draft correspondence to D. Nelson regarding same; Review correspondence from R.
Puri regarding amended Paragraph 20 of Settlement Agreement; Review
correspondence from G. Lyon regarding trusts entering into agreements; Telephone
conference with J. Baron regarding same; Review correspondence from J. MacPete
GMP 3.00 $550.00
$1,650.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 41 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 39204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
regarding settlement agreement; Review correspondence from J. Baron regarding
settlement drafts; Review and analysis of numerous corrections to settlement
agreement requested by R. Puri.
7/2/2010
Telephone conference with E. Schurig regarding assurances of no new agreements
by the Trust; Draft correspondence to E. Schurig regarding same; Review
correspondence from E. Schurig regarding same; Telephone conference with J.
Baron regarding same; Work on issues regarding Belton Trust and Telephone
conference with J. Baron regarding same; Work on issues relating to Trust fees and
expenses; Telephone conference with J. Baron regarding same; Review and
analysis of Motion to Compromise Controversy; Review and analysis of red-lined
new settlement draft from M. Bell; Review correspondence from opposing counsel
regarding revised draft; Review correspondence from G. Lyon regarding paragraph
20(b).
GMP 2.40 $550.00
$1,320.00
7/6/2010
Calendar hearing on Motion for Approval of Settlement Agreement with J. Baron.
SLM 0.10 $100.00
$10.00
7/6/2010
Work on paragraph 6(c); Telephone conference with R. Urbanik regarding same;
Telephone conference with J. Baron regarding same; Draft of 6(c) language and
correspondence to R. Urbanik regarding same; Review correspondence from E.
Taube regarding attempting to settle with Grupo Andrea; Telephone conference with
E. Taube regarding same; Telephone conference with J. Baron regarding same.
GMP 2.20 $550.00
$1,210.00
7/7/2010
Draft correspondence to E. Schurig regarding requests from trust for settlement
agreement; Telephone conference with E. Schurig regarding same; Telephone
conference with J. Baron regarding same.
GMP 1.00 $550.00
$550.00
7/8/2010
Numerous telephone conferences with J. Baron regarding paragraph 6C and other
closing and settlement issues; Review correspondence from J. Baron regarding
timetable for various actions; Telephone conference with J. Baron regarding same;
Review correspondence from J. Baron regarding trust taking certain actions;
Telephone conference with J. Baron regarding same; Telephone conference with all
attorneys regarding settlement issues.
GMP 2.70 $550.00
$1,485.00
7/9/2010
Several telephone conferences with J. Baron regarding settlement closing issues;
GMP 4.40 $550.00
$2,420.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 42 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 40204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Telephone conference with R. Urbanik and J. Baron regarding Verisign and
paragraph 6C; Review correspondence from E. Schurig regarding trust expenses;
Review correspondence from J. Baron regarding same; Telephone conference with
J. Baron regarding same; Telephone conference with E. Schurig, E. Taube, C.
Capua, J. Baron and A. Taylor regarding trust expenses; Telephone conference with
J. Baron regarding same; Telephone conference with J. Baron regarding problems
of timing regarding transfer of Remaining Allocated Names; Draft correspondence to
R. Urbanik and J. MacPete regarding same; Telephone conference with J. Baron
regarding same; Draft correspondence to J. Baron regarding Remaining Allocated
Names; Review correspondence from E. Schurig regarding fee dispute; Review and
analysis of new Exhibits J and K and H; Telephone conference with R. Urbanik and
J. Baron regarding remaining issues.
7/12/2010
Prepare and file Limited Objection to Motion to Compromise (.5); calendar hearing
on VeriSign's Motion for Allowance and Payment of Administrative Claim, to Compel
Assumption or Rejection of Executory Contract and in the alternative, for Relief from
Stay (.1).
SLM 0.60 $100.00
$60.00
7/12/2010
Prepare for continuance of hearing on Motion to Compromise.
SLM 0.70 $100.00
$70.00
7/12/2010
Review correspondence from M. Rosenblatt regarding W-9; Review correspondence
from E. Schurig regarding attorneys fees; Review and analysis of revised Settlement
Agreement; Review correspondence from J. Baron regarding open items;
Conference with C. Stephenson regarding limited objection to Settlement Agreement
motion; Telephone conference with J. Baron regarding same; Telephone conference
with R. Urbanik regarding same; Review correspondence from G. Lyon regarding
trust fees and expenses; Review correspondence from G. Lyon regarding Grupo
issues; Review correspondence from G. Lyon regarding fee issues; Review
correspondence from J. Baron regarding money paid to Beckham trust account;
Review correspondence from P. Vogel regarding invoices; Attendance at hearing on
settlement motion; Conference with J. Baron regarding same.
GMP 4.10 $550.00
$2,255.00
7/13/2010
Review correspondence from E. Schurig regarding Supplemental Agreement;
Review and analysis of Supplemental Agreement; Work on paragraph 6(c); Several
telephone conferences with J. Baron regarding various settlement issues; Telephone
conference with R. Urbanik regarding settlement issues; Telephone conference with
GMP 3.80 $550.00
$2,090.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 43 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 41204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
E. Taube regarding same; Telephone conference with tax attorneys for J. Baron;
Review correspondence from J. Baron regarding same; Review correspondence
from various parties regarding privacy service.
7/14/2010
Work on Supplemental Agreement and paragraph 6(c); Conference with J. Baron
regarding agreements with trust and paragraph 6(c); Telephone conferences with E.
Schurig and J. Baron regarding settling issues with trust; Several telephone
conferences with R. Urbanik and J. Baron regarding settling issues with Trustee
regarding paragraph 6(c); Conference with J. Baron regarding same; Draft of
documents regarding settling with trust and settling paragraph 6(c); Preparation for
hearing on settlement motion; Attendance at hearing on settlement motion;
Conference with J. Baron regarding same.
GMP 6.00 $550.00
$3,300.00
7/15/2010
Review correspondence from R. Puri regarding Webncc; Review correspondence
from R. Urbanik regarding Belton Trust; Review correspondence from R. Urbanik to
Court regarding status of various matters; Review correspondence from J. MacPete
regarding Belton Trust; Telephone conference with J. Baron regarding same; Review
and analysis of Blue Horizons Security Agreement; Review correspondence from E.
Taube regarding same.
GMP 2.10 $550.00
$1,155.00
7/16/2010
Calendar hearing on Amended Motion to Seal Transcript of Hearing Held on 6/22/10.
SLM 0.10 $100.00
$10.00
7/16/2010
Review correspondence from various parties regarding finalization of documents;
Telephone conference with J. Baron regarding same; Telephone conference with R.
Urbanik regarding same.
GMP 1.30 $550.00
$715.00
7/19/2010
Review correspondence from R. Urbanik regarding pricing issues; Telephone
conference with J. Baron regarding same; Review correspondence from J. Baron
regarding same; Preparation work regarding pricing issues and potential hearing
regarding same; Review and analysis of proposed Quantec agreement; Review
correspondence from G. Lyon regarding Belton Trust; Review correspondence from
M. Nelson regarding various issues; Review correspondence from R. Urbanik
regarding remaining issues; Review and analysis of registrar agreements; Review
and analysis of monthly budget for Ondova for purposes of analyzing pricing;
Telephone conference with J. Baron regarding same; Telephone conference with R.
GMP 4.20 $550.00
$2,310.00
Case 12-37921-sgj7 Doc 52-1 Filed 02/01/13 Entered 02/01/13 17:06:14 Page 44 of 58
February 10, 2011
S T A T E M E N T
Pronske & Patel P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
214-658-6500 (telephone)
214-658-6509 (fax)
Account Description:
Balance:
Statement Period: From Earliest to 07/31/2010
Jeff Baron
Client ID:
Acct
Page 42204
1 $240,542.70
Jeff Barron
Invoice #5916
Date Description Charges
Credits
Type* Balance
TRANSACTION SUMMARY (CONTINUED)
Urbanik regarding same.
7/20/2010
Work on issues relating to pricing; Numerous telephone conferences with J. Baron
regarding same; Numerous telephone conferences with R. Urbanik regarding same.
GMP 1.80 $550.00
$990.00
7/21/2010
Calendar status conference (.1); calendar deadline to file response to Trustee's
Motion to Extend Bar Date for Creditors Who Did Not Receive Notice of Bankruptcy
Filing (.1).
SLM 0.20 $100.00
$20.00
7/21/2010
Calendar deadline to file response to Trustee's Motion to Extend Bar Date for
Creditors Who did Not Receive Notice of Bankruptcy Filing.
SLM 0.10 $100.00
$10.00
7/22/2010
Attendance at status conference hearing; Telephone conference with J. Baron
regarding same; Telephone conference with G. Lyon regarding same.
GMP 1.60 $550.00
$880.00
7/23/2010
Work on issues relating to trust fees and expenses; Numerous telephone
conferences with J. Baron regarding same; Draft correspondence to E. Schurig
regarding same; Telephone conference with J. Baron regarding same; Work on
assurances from Trust.
GMP 2.20 $550.00
$1,210.00
Total Hours: 44.60
*C = Charge, P or X = Payment, A or W = Adjustment, B = Balances Forwarded, Y = Transfer to Trust Account, N/C = No Charge
Balance: $240,542.70
Comments:
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APPLICATION OF PRONSKE & PATEL, P.C. FOR PAYMENT OF FEES AND EXPENSES AS AN
ADMINISTRATIVE EXPENSE FOR A SUBSTANTIAL CONTRIBUTION TO THE ESTATE – PAGE 1
Gerrit M. Pronske
State Bar No. 16351640
Rakhee V. Patel
State Bar No. 00797213
PRONSKE & PATEL, P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
(214) 658-6500 - Telephone
(214) 658-6509 – Telecopier
Email: gpronske@pronskepatel.com
Email: rpatel@pronskepatel.com
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re: §
§
ONDOVA LIMITED COMPANY §
§
§ CASE NO. 09-34784-SGJ-11
§ Chapter 11
Debtor. §
APPLICATION OF PRONSKE & PATEL, P.C.,
FOR PAYMENT OF FEES AS AN ADMINISTRATIVE
EXPENSE FOR A SUBSTANTIAL CONTRIBUTION TO THE ESTATE
SUMMARY OF FEE APPLICATION
First Application of:
Pronske & Patel, P.C.
For the time period of:
February 1, 2010 through July 24, 2010
Capacity:
COUNSEL FOR JEFF BARON
Unpaid Fees and Expenses Sought:
$241,172,70
TO THE HONORABLE STACEY G. JERNAGIN,
UNITED STATES CHIEF BANKRUPTCY JUDGE:
Pronske & Patel, P.C. (“Pronske & Patel” or “Applicant”) hereby files this its Application
for Payment of Fees and Expenses as an Administrative Expense for a Substantial Contribution
to the Estate (the “Application”) pursuant to 11 U.S.C. § 503(b)(4).
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EXHIBIT "B"
PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 2
I. JURISDICTION
1. This Court has jurisdiction over the subject matter of this Application pursuant to
28 U.S.C. §§ 1334 and 157. This is a core proceeding under 11 U.S.C. § 157(b)(2)(A).
II. RELIEF REQUESTED
2. As more fully set forth herein, Pronske & Patel asks this Court to enter an order:
granting approval and payment of fees and expenses incurred by Pronske & Patel during the
Application Period in this case as a substantial contribution to the Ondova bankruptcy estate
pursuant to 11 U.S.C. §503(b)(4).
III. FACTUAL BACKGROUND RELATING TO
SUBSTANTIAL CONTRIBUTION TO THE ESTATE
3. For a six month period beginning in February 2010, Pronske & Patel’s
representation of Baron
1
1
Baron is a Creditor of the Ondova bankruptcy case. He filed numerous pleadings in the Ondova
bankruptcy case stating that he was filing such pleadings as “as creditor” of Ondova. This position taken by Baron
granted him standing to be heard in the Ondova bankruptcy case. By virtue of the standing garnered by the claim of
being a Creditor in the case, he cannot now say that he is not a creditor. Further, Baron is the ultimate equity owner
of Ondova, as he is the sole beneficiary of the Daystar Trust, which is the 100% equity owner of Ondova. 11 U.S.C.
§503(b)(3)(D) and (b)(4).
became focused almost exclusively on the settlement (the “Settlement
Negotiations”) of various litigation in the Federal District Court for the Northern District of
Texas, Dallas Division, and various Texas State Courts involving Netsphere, Inc., Baron and
Ondova (the “Netsphere Litigation”). The Settlement Negotiations were, during that 6 month
period, extremely time-consuming, contentious, complex, difficult – and successful. The
Settlement Negotiations involved almost daily participation and work on Pronske & Patel’s part.
Pronske & Patel became a lead negotiator in the Settlement Negotiations along with John
McPete (representing Netsphere), Ray Urbanik (representing the bankruptcy estate), Eric Taube
and Craig Capua (representing either the Village Trust or various entities owned and controlled
by the Village Trust), and numerous other parties. These Settlement Negotiations generated a
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 3
settlement document that was over 100 pages long – every sentence of which was the subject of
substantial negotiation and discussion, often resulting in impasse. The time-consuming nature of
these negotiations is shown, by example, in the month of June 2010, where nearly every day,
including both days of every weekend, was spent in negotiations. Most of the lawyers involved
in these negotiations were experienced lawyers who have handled numerous significant cases in
their careers. Nevertheless, most if not all of these attorneys agreed that this negotiation was the
most complex and difficult negotiation that any of them had ever handled. The difficulty of the
case was exacerbated by the difficulty of the personalities of the clients, each of which was often
relentless with various positions and slow to warm to the idea of compromise without significant
amounts of time being spent on any given issue at hand. Almost every issue of the Settlement
Negotiation was an extended battle, often turning into impasse numerous times before a
compromise could emerge.
4. Despite the difficulties in the Settlement Negotiations, a final deal was struck, and
the terms of the deal were approved by this Court.
5. In terms of success, the Settlement Negotiations yielded payments to the
bankruptcy estate of Ondova that will provide funds that will likely pay unsecured creditors a
healthy, if not complete dividend. The cash sum of $1,250,000 provided in the Settlement
Agreement resulting from the negotiations has already been funded to the bankruptcy trustee by
Netsphere, due to the success of the Settlement Negotiations. Absent continuing litigation with
Netsphere, for which Netsphere’s counter-parties were running out of funds to continue, no
money would likely have been realized by the Ondova bankruptcy estate from Netsphere.
6. In terms of substantial contribution, the work performed by Pronske & Patel
clearly resulted an actual and demonstrable (or, as some courts say, a “direct and material”) benefit to
the debtor’s estate and its creditors.
See, e.g., Lister v. United States, 846 F.2d 55 (10
th
Cir. 1988).
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 4
7. Pronske & Patel submits that without the work that it did in connection with the
settlement, the settlement would likely not have come to fruition, and the Ondova estate would
not have benefited from the cash that has been paid (and will be paid in the future) under the
Settlement Agreement that will result in creditors of Ondova likely receiving up to 100% of the
amount of their claims in this case.
8. The benefit that the Ondova estate realized as a result of the settlement amount to
far more than an incidental one arising from activities the applicant has pursued in protecting its
own interests. The work performed by Pronske & Patel has operated to foster and enhance,
rather than retard or interrupt the progress of reorganization in this case.
9. The services performed by Pronske & Patel were in addition to, and were not
duplicative of services performed by attorneys for the Bankruptcy Trustee. In many respects, the
interests of Ondova and Baron against Netsphere were aligned, making the work performed by
Pronske & Patel directly beneficial to the Ondova estate in terms of realizing sums from
Netsphere by the Ondova estate that will be utilized to pay creditor claims a substantial dividend.
10. The reimbursement for attorneys’ fees and expenses sought herein will not result
in the impairment of other creditors; to the contrary, the work performed by Pronske & Patel will
help to make a dividend to creditors much higher than it would otherwise have been.
11. Costs associated with bringing this Application include numerous hours that
Pronske & Patel attorneys have spent in Court dealing with the issue of compensation in
connection with the settlement negotiations, together with the time spent in preparing this
application. These costs are compensable under 11 U.S.C. §503(b)(4). In re Wind N’ Wave, 509
F.3d 938 (9th Cir. 2007) (“. . .[C]reditors who receive compensation under 503(b)(4) should also
be compensated for costs incurred in litigating a fee award, so long as the services meet the §
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 5
503(b)(4) requirements and the case “exemplifies a ‘set of circumstances’ where litigation was
‘necessary’”. . . .”).
IV. SUMMARY OF SERVICES OF APPLICANT
12. Pronske & Patel hereby seeks this Court’s approval for compensation of
professional services and reimbursement of expenses for the Application Period. Pronske &
Patel has performed legal services in connection with this case, incurring unpaid fees in the sum
of $241,172.70 for attorney and paraprofessional time.
V. OBJECTIVE FACTORS AFFECTING LEGAL FEES
13. The fee setting process providing for the recovery of attorneys’ fees begins with an
examination of the nature and extent of the services rendered or what is referred to as the “time
spent” standard. In other words, a measure of the quantum of the services must precede the
determination of the value of these services.
2
14. Pronske & Patel recognizes that this Court will allow lawyers to be compensated
only for legal work performed and that the dollar value of a particular task is not enhanced
simply because a lawyer performs it. Considerable care, therefore, has been taken to avoid the
performance of purely ministerial tasks by using paraprofessionals where possible.
Exhibit A provides detail all of the time for which
compensation is sought by Pronske & Patel, broken-down by month and day, and explains the
hours by each attorney and paraprofessional who provided services in this case and the requested
rate of compensation.
VI. SUBJECTIVE FACTORS AFFECTING COMPENSATION
15. In fixing the amount of reasonable compensation to be awarded a law firm for
worked performed in a case, the Court may consider factors other than the numbers of hours
2
See In re First Colonial Corp. of America, 544 F. 2d 1291 (5
th
Cir.) cert. denied, 97 S. Ct. 1696 (1977).
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
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spent and the hourly rate normally charged.
3
The standards established by Fifth Circuit have
been further modified by the opinion of the Supreme Court in Pennsylvania v. Delaware Valley
Citizens Counsel for Clean Air.
4
16. In Delaware Valley, the Supreme Court, in considering the Johnson case, noted the
practical difficulties encountered by courts in applying the sometimes-subjective Johnson
factors. The Court in Delaware Valley also considered the “lodestar” approach of the Third
Circuit Court of Appeals.
While Delaware Valley concerned the award of attorneys’ fees
under section 304(d) of the Clean Air Act, the language of the opinion makes it generally
applicable to the award of attorneys’ fees pursuant to federal statutes which require that the fee
awarded be “reasonable.”
5
The Court also revisited its prior opinions
6
whereby it determined
that the proper first step in determining a reasonable attorneys’ fee is to multiply the number of
hours reasonably expended on the litigation times a reasonable hourly rate, and that adjustment
of this figure based on some of the Johnson factors might be appropriate,
7
but that such
modifications would be proper only in certain rare and exceptional cases and when supported by
specific evidence and detailed findings of the lower court.
8
3
See In re First Colonial Corp. of America, supra; and Johnson v. Georgia Highway Express, Inc., 488 F.
2d 714 (5
th
Cir. 1974).
In Delaware Valley, the Court took
an even more restrictive approach to the relevance of the Johnson factors and concluded that the
4
Pennsylvania v. Delaware Valley Citizens Counsel for Clean Air, 478 U.S. 546.
5
See e.g., Lindy Brothers Builders, Inc. v. American Radiator and Standard Sanitary Corporation, 487 F. 2d
161 (3d Cir. 1973) (Lindy I).
6
See Hensley v. Eckerhart, 461 U.S. 424 (1983); Blum v. Stenson, 465 U.S. 886 (1984).
7
See Hensley, 461 U.S. at 434, n. 9.
8
See Blum, 465 U.S. at 898-901.
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 7
“lodestar” figure includes most, if not all, of the relevant factors comprising a “reasonable
attorneys’ fee.”
9
17. Thus, under the Delaware Valley approach, this Court is guided to determine the
number of hours reasonably spent in representing the Trustee, multiplied by a reasonable hourly
rate for the services performed. The following discussion incorporates the Johnson factors only
insofar as they might add the Court in its determination of the “lodestar” figure.
18. The following subjective Johnson factors are offered for consideration:
Time and the labor required. Pronske & Patel attorneys and
paraprofessionals have expended a significant number of hours providing
necessary and reasonable services incident to its representation of the
Baron for the Application Period, as detailed in the attached Exhibit A.
The total value of this time is $241,172.70.
The novelty and difficulty of the questions. This case presented several
novel and/or difficult issues in varying degrees. It was necessary for
Pronske & Patel to analyze these complex problems in the light of
applicable laws and seek resolution based on such laws with the objective
of achieving a result which would benefit the Estate.
The skill requisite to perform the legal services properly. Mr. Gerrit
Pronske is a skilled and highly experienced attorney who has specialized
in commercial bankruptcy law for 28 years. Mr. Pronske is a shareholder
in the firm of Pronske & Patel. He was a law clerk to the now retired
Honorable Robert C. McGuire, Chief Bankruptcy Judge of the Northern
District of Texas. He is a regular presenter at legal seminars on
9
See In Delaware Valley, 106 S. Ct. at 309.
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 8
commercial and consumer bankruptcy, commercial transactions and other
related topics. Mr. Pronske is the author of PRONSKE’S TEXAS
BANKRUPTCY ANNOTATED, which is published by Texas Lawyer,
and currently in its 10
th
Edition. Additionally, Mr. Pronske is the editor of
2010 PRONSKE’S TEXAS BANKRUPTCY MINI-CODE, also
published by Texas Lawyer. Ms. Rakhee V. Patel, a partner with Pronske
& Patel, was a bankruptcy law clerk for Judge Harlin D. Hale and a
bankruptcy law clerk for Retired Judge Robert C. McGuire. Ms. Patel is a
regular speaker at legal seminars on commercial bankruptcy and author of
various bankruptcy related articles. Ms. Christina W. Stephenson, an
associate, has practiced bankruptcy law for two years and is a former
extern for the Honorable Harlin D. Hale. Ms. Sandra Meiners and Mr.
Louis Whatley, legal assistants, provided assistance in this case. Both are
proficient legal assistants with a total of over 30 years experience in
bankruptcy law.
The preclusion of other employment by attorneys due to acceptance of this
case. This factor was present because Mr. Pronske spent a significant
amount of time on this case, thereby precluding other representation.
The customary fee. Exhibit A to this Application sets forth the hourly
rate at which compensation is requested. These rates are no greater, and in
many cases considerably less, than those being charged by attorneys for
other major parties-in-interest in this or other bankruptcy cases in this
district. Pronske & Patel and other similar firms customarily charge these
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 9
rates for equivalent services. These rates compare favorably to the cost of
legal services to ordinary corporate legal consumers.
Whether the fee is fixed or contingent. The fee in this case is not
contingent upon the outcome of any particular issue or adversary
proceeding.
Time limitations imposed by the client or other circumstances. Time
constraints have been substantial in this case as shown by the time records
attached hereto as Exhibit A.
The experience, reputation and ability of the attorneys. Applicant submits
that Ms. Patel and Mr. Pronske have established themselves as able and
conscientious practitioners in the Northern and other districts of Texas.
Ms. Stephenson is an experienced bankruptcy associate. Ms. Meiners and
Mr. Whatley are proficient legal assistants with substantial experience in
bankruptcy law.
The “undesirability” of the case. This factor is not relevant in this case.
The nature and length of the professional relationship with the client.
Applicant had no professional relationship with the Baron prior to their
retention by the Baron as counsel.
Awards in similar cases. Pronske & Patel represents and would
demonstrate that the compensation for the services rendered and expenses
incurred in connection with this case is not excessive and is commensurate
with, or below the compensation sought or ordered in similar cases under
the Bankruptcy Code. Pronske & Patel’s fee request is based upon normal
hourly charges that Pronske & Patel charges private clients of the firm.
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES – PAGE 10
Taking into consideration the time and labor spent, the nature and extent
of the representation, Pronske & Patel believes the allowance prayed for
herein is reasonable.
Additional consideration. The Court in First Colonial Corp. of America,
supra, stated that two additional considerations should be considered by
the Court:
The policy of the Bankruptcy Code that estates be
administered as efficiently as possible. It is the policy of
Pronske & Patel to assign work to attorneys who have the
degree of expertise and specialization to perform efficiently
and properly the services required and to utilize law clerks
and legal assistants whenever appropriate. This practice
has been followed to date in this case and will be followed
in the future.
The Bankruptcy Code does not permit the award of
duplicate fees or compensation for non-legal services.
There has been no unnecessary or unavoidable duplication
of legal services and there have been no non-legal services
performed by this firm for which legal fees have been
charged.
VII. REASONABLENESS OF PRONSKE & PATEL’S FEES
19. Pronske & Patel’s representation of the Baron were time intensive during the
Application Period. Pronske & Patel accepted this engagement without certainty that all of its
fees and expenses would be paid and is charging a fixed hourly rate for services performed.
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20. Pronske & Patel represents that the fees and expenses requested herein are fair and
reasonable in connection with the services provided. The rates charged by Pronske & Patel are
competitive and customary for the degree of skill and expertise necessary for cases of this type
and are consistent with, or below, rates charged by other counsel with similar experience in the
Northern District of Texas.
21. The work Pronske & Patel performed during its representation herein has been
beneficial to the estate as set forth above, and has made a substantial contribution to the estate
and its creditors. Taking into consideration the time and labor spent, the nature and extent of the
representation, and the results obtained in this proceeding, Pronske & Patel believes the
allowance prayed for herein is reasonable and just.
VIII. SUMMARY
22. Applicant seeks an award of compensation as set forth in Exhibit “A”, for
attorneys’ time and paraprofessionals’ time for services furnished to the Baron during the
Application Period in the unpaid amount of $241,172.70. Pronske & Patel additionally requests
this Court to award the fees and expenses associated with the filing and prosecution of this
Motion.
23. Exhibit “A” to this Application details how time was spent as well as how the
requested compensation has been calculated. The amounts sought are fair and reasonable
compensation in light of all the circumstances.
IX. REQUEST FOR RELIEF
For these reasons, Pronske & Patel respectfully asks this Court to enter an order: (i)
granting approval of all fees and expenses incurred by Pronske & Patel in this case during the
Application Period in the amount of $241,172.70 (plus the fees and expenses associated with the
filing and prosecution of this Motion) as a substantial contribution to the Debtor’s bankruptcy
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PRONSKE & PATEL, P.C.’S FEE APPLICATION FOR
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estate, compensable as an administrative expense pursuant to 11 U.S.C. §503(b)(4) (ii) allowing
compensation and reimbursement of all sums requested as an administrative expense from the
Debtor’s bankruptcy estate, pursuant to the fee statements attached as Exhibit A for the
Application Period; and (iii) authorizing the allowed fees and expenses to be immediately paid as
allowed by the bankruptcy estate as an administrative expense.
Dated: October 20, 2010 Respectfully submitted,
Dallas, Texas
s/ Gerrit M. Pronske
Gerrit M. Pronske
State Bar No. 16351640
Rakhee V. Patel
State Bar No. 00797213
PRONSKE & PATEL, P.C.
2200 Ross Avenue, Suite 5350
Dallas, TX 75201
214-658-6500 – Telephone
214-658-6509 – Telecopier
CERTIFICATE OF SERVICE
The undersigned does hereby certify that on this 20
th
day of October 2010, a true and
correct copy of the above and foregoing Fee Application of Pronske & Patel, P.C., was served
upon the twenty largest unsecured creditors, all parties who have filed a notice of appearance, the
United States Trustee and the Baron, as more fully illustrated on the attached Master Service
List, via First Class United States mail and/or electronic filing, if available.
/s/ Gerrit M. Pronske
Gerrit M. Pronske
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EXHIBIT “A” OMITTED
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