In re: GOLDBLATT’S BARGAIN STORES, INC. Chapter 7, Debtor.
Case No. 03 B 10796.United States Bankruptcy Court, N.D. Illinois, Eastern Division.
July 7, 2010
FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO LEIBOWITZ LAW CENTER N/K/A LAKELAW, ATTORNEYS FOR THE TRUSTEE, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES
EUGENE WEDOFF, Bankruptcy Judge
TOTAL FEES REQUESTED: $73,170.00 TOTAL COSTS REQUESTED: $337.00
TOTAL FEES REDUCED: $3,602.00 TOTAL COSTS REDUCED: $0.00
TOTAL FEES ALLOWED: $69,568 TOTAL COSTS ALLOWED: $337.00
TOTAL FEES AND COSTS ALLOWED: $69,905.00
The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by numerical notations that appears on the left of each underlined entry. The numerical notations correspond to the enumerated paragraphs below.
(1) Unreasonable Time
The Court denies the allowance in part of compensation for the following task since the professional or paraprofessional expended an unreasonable amount of time on this task in light of the nature of the task, the experience and knowledge of the professional performing the task, and the amount of time previously expended by the professional or another on the task In re Pettibone, 74 B.R. 293, 306 (Bankr. N.D. Ill. 1987) (“The Court will determine what is the reasonable amount of time an attorney should have to spend on a given project . . . An-attorney should not be rewarded for inefficiency. Similarly, attorneys will not be fully compensated for spending an unreasonable number of hours on activities of little benefit to the estate.”); In re Wildman, 72 B.R. 700, 713 (Bankr. N.D. Ill. 1987) (same).
(2) Clerical Work Not Compensable
The court disallows the compensation of clerical or stenographic employees of the professional for the performance of routine clerical or administrative activities in the normal course of the professional’s business, such as photocopying, secretarial work, or routine filing. Such activities are not in the nature of professional services and must be absorbed by the applicant’s firm as an overhead expense. In re Dimas, LLC, 357 B.R. 563, 577 (Bankr. N.D. Cal. 2006) (citing Missouri v. Jenkins, 491 U.S. 274, 288 n. 10 (1989)). See also In re Chellino, 209 B.R. 106, 114 (Bankr. C.D. Ill. 1996) (Paralegal, but not “clerk” services entitled to compensation at an hourly rate; clerk activities are overhead of the professional); Souza v. Miguel, 32 F.3d 1370, 1375 (9th Cir. 1994) (Trustee not entitled to reimbursement or compensation of overhead expenses such as secretarial, stenographic, clerical, and routine messenger services).
(3) Computational or Typographical Error
The court denies the allowance of compensation for the following tasks because the amount of fees appears to be a computational or typographical error. Also, where there are two identical entries (same day, same tasks, same time billed), the court will consider one of the entries to be a typographical error.
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(4) Lumping
The Court may impose a ten percent penalty for “lumping.” In re Wildman, 72 B.R. 700, 709 (Bankr. N.D. Ill. 1987) (“Applicants may not circumvent the minimum time requirement or any of the requirements of detail by “lumping” a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.”).
(5) Insufficient Description
The Court denies the allowance of compensation for the following task since the description of the time entry fails to identify in a reasonable manner the service rendered. In re Pettibone, 74 B.R. 293, 301 (Bankr. N.D. Ill. 1987) (“A proper fee application must list each activity, its date, the attorney who performed the work, a description of the nature and substance of the work performed, and the time spent on the work. [Citation omitted] Records which give no explanation of the activities performed are not compensable.”); In re Wildman, 72 B.R. 700, 708-9 (Bankr. N.D. Ill. 1987) (same).
(6) Trustee Work Can Not Be Compensated As Professional Services
“The Trustee cannot effectively expand the maximum limits of Section 326(a) by hiring other people to perform his duties for him, whether they are paralegals, attorneys, accountants or other professional persons, and utilize the potentially unlimited scope of Section 330 as a basis for award of reasonable compensation.”Boldt v. United States Trustee (In re Jenkins), 130 F.3d 1335, 1341 (9th Cir. 1997) (quoting In re Prairie Cent. Ry. Co., 87 B.R. 952, 959 (Bankr. N.D. Ill. 1988)).
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EXHIBIT A-1
______________________________
Lakelaw
420 West Clayton Street
Waukegan, IL 60085-4216
Date: 4/16/2010
Regarding: Goldblatts. Preferences
Invoice No: 05766
Services Rendered
Date Staff Description Hours Rate Charges
Leg — Case Administration
11/17/2005 LBD draft responses to discovery documents 4.00 $250.00 $1,000.00
in L.D. Adversary proceeding formatting
of same to tender responses, review of
file in response of discovery
11/17/2005 LBD email to L. West regarding responses 0.10 $250.00 $25.00
to Discovery in L.D. Wholesale
adversary proceeding
11/18/2005 DPL review and revise responses to 0.50 $500.00 $250.00
discovery with L.D. Wholesale
adversary
11/18/2005 LBD conf with dpl re discovery, discussed 0.30 $275.00 $82.50
objections, etc-L.D Wholesale
11/18/2005 LBD amendment and additions to discovery 0.90 $250.00 $225.00
responses
11/18/2005 LBD preparation of documents to comply 0.60 $250.00 $150.00
with request for productions
11/23/2005 KBO Prepared deposit of check from Star 1.00 $75.00 No Charge
Distributors, prepared deposit packet for
fedex.
11/28/2005 LBD email to H. Biolansky re global 0.20 $250.00 $50.00
settlement with CIT group re various
pending adversary proceedings
11/29/2005 KBO Prepared deposit from Total 1.00 $75.00 No Charge
International in re adversary proceeding,
prepared fedex envelope for deposit.
12/01/2005 KBO Prepared service list for M for Order 1.20 $75.00 $15.00
Allowing trustee to compromise certain
preferences rule 9019.
12/01/2005 KBO Prepared notice of motion for Motion for 0.20 $75.00 $15.00
Entry of an Order Allowing Trustee to
Compromise Certain Preferences rule
9019.
Page 4
12/01/2005 LBD review draft of mtn to approve 0.40 $250.00 $100.00
settlements per rule 9019 drafted by
SG, make changes and have
corrections made for filing
12/01/2005 LBD conf with SG re drafting mtn to approve 0.20 $250.00 $50.00
settlements per rule 9019
12/01/2005 SG Drafted motion to authorize settlement 1.00 $200.00 $200.00
12/01/2005 SG Reviewed settlement letters in 0.30 $200.00 $60.00
preparation to draft motion to authorize
settlement
12/01/2005 SG Revised the motion to authorize 0.80 $200.00 $160.00
settlement and order as per LBD
12/01/2005 SG Conference with LBD re: motion to 0.30 $200.00 $60.00
authorize settlements
12/02/2005 KBO Prepared to file M to Compromise 0.20 $75.00 $15.00
certain preference claims utilizing
template from former motions
12/02/2005 KBO Electronically filed M for Order Allowing 1.30 $75.00 $22.50
Trustee to Compromise Certain
Preference claims.
12/02/2005 LBD review of mtn to authorize compromise 0.50 $250.00 $125.00
with draft order, etc for filing today
12/02/2005 LBD amendment to preference status spread 1.70 $250.00 $425.00
sheet, update case records, etc to
deliver to J. Wedoff’s chambers in
antcipation of hearing
12/02/2005 SG Revised motion to authorize as per LBD 0.20 $200.00 $40.00
12/21/2005 KBO Draft dismissal order for adversary 0.20 $75.00 $15.00
proceeding against Star Distributors 04
A 3383.
12/22/2005 CDW Vcmail to Biolansky re: Settlement 0.10 $225.00 $22.50
Approved, process check, will forward
Order when docketed
12/28/2005 KBO Prepared email to Laura re dismissal 0.20 $75.00 $15.00
orders in goldblatts from Dec 22nd
hearing.
12/28/2005 KBO Phonecall with Velda Wiliams re 0.20 $75.00 $15.00
Preferences that need dismissal orders
from Dec. 22nd hearing.
1/03/2006 KBO Prepared deposit slip for check from 0.20 $75.00 No Charge
Total Intl. Prepared fedex package for
deposit.
1/03/2006 KBO Prepared dismissal order for Fruit of the 0.20 $75.00 $15.00
Loom inc.
1/03/2006 LBD phone call to M. Duncan, atty for L.D. 0.10 $250.00 $25.00
wholesale re offer and counter offer in
case, left message with information and
requested return call
1/03/2006 LBD phone call with local counsel for L.D. 0.20 $250.00 $50.00
Wholesale, requested follow up, to
discuss with dpl re offer/counter
Page 5
withdrawing the reference
1/24/2006 LBD phone call with atty regarding status of 0.20 $250.00 $50.00
payment on settlement with Total
International
1/26/2006 LBD recieve letter and copy of signed 0.20 $250.00 $50.00
settlement from L.D.Wholesale atty,
reviewed same, settlement to dpl for
signature
1/30/2006 LBD draft settlement agreement for CIMCO 0.50 $250.00 $125.00
adversary, to DPL for review and
signature
2/01/2006 KBO Phonecall with Bruce Tenzer regarding 0.20 $75.00 $15.00
2004 subpoena for CIT group. I let him
know per dpl’s note that the subpoena
was resolved.
2/01/2006 LBD forward copy of executed settlement to 0.20 $250.00 $50.00
atty for L.D. Wholesale, with info
regarding approval of settlement
2/01/2006 LBD recieve executed settlement from DPL 0.30 $250.00 $75.00
re CIMCO adversary, e-mail copy of
same to Atty Frank Tighe
2/06/2006 KBO Prepared to file M Entry of Order 1.20 $75.00 $15.00
Allowing Trustee to Compromise
Certain pref. Claims p to 9019 by
printing does to pdf and merging
appropriatedocs.
2/06/2006 LBD phone call to atty for preference 0.20 $250.00 $50,00
defendant re claim and non-payment of
settlement amount
2/06/2006 LBD phone call with Preference defendant 0.20 $250.00 $50.00
regarding status of payment, to renew
mtn for default, Kirch
2/06/2006 LBD draft mtn to authorize compromise of 0.60 $275.00 $165.00
additional preferences, L.D. Wholesale
and CIMCO, draft order re same, to
KBO for notice of mto and MO with
service list
2/06/2006 MIG Service of Notice of Motion for entry of 0.40 $50.00 $20.00
an order allowing the trustee to
compromise certain preference claims
2/23/2006 KBO Draft dismissal order for CIMCO 04- 0.30 $75.00 $22.50
3269. Emailed to Velda Williams.
2/23/2006 KBO Draft Dismissal order for L.D. 0.20 $75.00 $15.00
Wholesale. Emailed to Velda Williams.
2/23/2006 LBD Hearing on M to Comp Certain 1.00 $250.00 $250.00
Preferences actions
2/23/2006 LBD attend hearing, travel to office from 1.00 $250.00 $250.00
same
3/06/2006 KBO Prepared deposit package to chase for 1.10 $75.00 $7.50
check from CIMCO.
3/06/2006 KBO Prepared deposit of preference 1.20 $75.00 $15.00
settlement check from CIMCO for adv.
Page 6
pro # 04 A 3269.
3/07/2006 LBD receive email for Pepsi co requesting 0.10 $250.00 $25.00
copy of dismissal order or other
documents showing case is closed
3/07/2006 LBD email to Pepsi, downloaded copy of 0.20 $250.00 $50.00
dismissal order and attached thereto,
advised of case closing date and
dismissal with prejudice
3/09/2006 SG Leave message for Jack Zackin with 0.20 $200.00 $40.00
secretary
3/09/2006 SG Leave message for Mr. Wang re: 0.10 $200.00 $20.00
chateau international
3/09/2006 SG Review files and check status on 0.50 $200.00 $100.00
settlements of preference actions
3/09/2006 SG Fax copy of signed settlement 0.20 $200.00 $40.00
agreement to Mizrahi Gardner — general
release
3/10/2006 SG Receive voicemail from Jack Zackin re: 0.10 $200.00 $20.00
payment of settlement offer by Beacon
Looms by early next week
3/14/2006 KBO Prepared deposit from Beacon Looms 1.20 $75.00 $15.00
to Chase Bank.
3/14/2006 KBO Draft dismissal order for Beacon Looms 0.20 $75.00 $15.00
04-3246.
3/15/2006 KBO Prepare/Update Motion for Default 0.20 $75.00 $15.00
Judgment for service for April 18th for
LaRue Intl.
3/15/2006 KBO Prepare/Update Motion for Default 0.30 $75.00 $22.50
Judgment for service for April 18th
hearing for CEM Global.
3/15/2006 KBO Prepare Draft Order for Motion for 0.20 $75.00 $15.00
Default to show no total judment rate for
Intex Recreation.
3/15/2006 KBO Prepare Minute Order for Motion for 0.10 $75.00 $7.50
Default Judgment for Intex Recreation.
3/15/2006 KBO Electronically Filed Motion for Default 1.40 $75.00 No Charge
Judgment on Complaint to Avoid
Preferential Transfers for Intex
Recreation.
3/15/2006 KBO Prepare Minute Order for Motion for 0.10 $75.00 $7.50
Default Judgment for CEM Global.
3/15/2006 KBO Electronically Filed Motion for Default 1.50 $75.00 $37.50
Judgment on Complaint to Avoid
Preferential Transfers for LaRue Intl.
3/15/2006 KBO Prepare Affidavit for DPL for Motion for 0.20 $75.00 $15.00
Default Judgment on Intex Recreation.
3/15/2006 KBO Prepare Affidavit for DPL for Motion for 0.20 $75.00 $15.00
Default Judgment on CEM Global.
3/15/2006 KBO Electronically Filed Motion for Default 1.20 $75.00 No Charge
Judgment on Complaint to Avoid
Preferential Transfers for CEM Global.
Page 7
3/15/2006 KBO Prepared Notice of Motion for Motion for 0.20 $75.00 $15.00
Default Judgment for April 18th for
LaRue Intl.
3/15/2006 KBO Prepare Minute Order for Motion for 0.10 $75.00 $7.50
Default Judgment for LaRue Intl.
3/15/2006 KBO Prepare Draft Order for Motion for 0.10 $75.00 $7.50
Default to show no total judment rate for
CEM Global.
3/15/2006 KBO Prepare Draft Order for Motion for 0.10 $75.00 $7.50
Default to show no total judment rate for
LaRue Intl.
3/15/2006 KBO Prepare Affidavit for DPL for Motion for 0.20 $75.00 $15.00
Default Judgment on LaRue Intl.
3/15/2006 KBO Emailed Dismissal Order for Beacon 1.20 $75.00 $15.00
Looms to Velda Williams.
3/15/2006 KBO Prepared Notice of Motion for Motion for 0.20 $75.00 $15.00
Default Judgment for April 18th for Intex.
3/15/2006 KBO Prepare/Update Motion for Default 0.20 $75.00 $15.00
Judgment for service for April 18th
hearing for Intex.
3/15/2006 KBO Prepared Notice of Motion for Motion for 0.20 $75.00 $15.00
Default Judgment for April 18th Hearing
for CEM Global.
3/15/2006 LBD Draft updated adversary case list to 0.50 $250.00 $125.00
email to V. Williams for status hearing
tomorrow at 10:30
3/15/2006 LBD review of docket items for hearing, 0.40 $250.00 $100.00
discussion of default motions with KBO
3/15/2006 LBD review of mtns for default drafted by 0.40 $250.00 $100.00
KBO
3/16/2006 KBO Prepared deposit package to chase 1.10 $75.00 $7.50
bank for settlement check from LD
Wholesale.
3/16/2006 KBO Prepared deposit from LD Wholesale 1.20 $75.00 $15.00
settlement.
3/16/2006 LBD status on cases and pretrial 1.20 $300.00 $360.00
conferences, hearing set for 10:30,
heard at 11:40
4/07/2006 LBD email to atty re CEM global case and 0.30 $275.00 $82.50
possible settlement, receive a response
thereto
4/10/2006 KBO Prepared deposit package to chase for 1.10 $75.00 $7.50
LD Inc settlement check.
4/10/2006 KBO Prepared deposit from LD Inc. as per 1.20 $75.00 $15.00
settlement.
4/17/2006 LBD Draft updated preference case list, 0.70 $275.00 $192.50
email same to V. Williams for hearing
5/01/2006 LBD letter to atty for Intex re possible 0.30 $275.00 $82.50
settlement and/or proof of defense
5/02/2006 SG Travel time from home to court to attend 1.00 $200.00 $0.00
Page 8
hearing on motion to dismiss
5/02/2006 SG Attend hearing on motion to dismiss 1.00 $200.00 $200.00
5/12/2006 KBO Prepared deposit from LD wholesale. 1.20 $75.00 $15.00
5/12/2006 KBO Prepared deposit package for check 1.10 $75.00 $7.50
from LD Wholesale to chase for
deposit.
5/12/2006 KBO Entered check from LD Wholesale into 1.10 $75.00 $7.50
cases receipts log.
6/12/2006 LBD prepare adversary case list for hearing 0.70 $275.00 $192.50
on 6/13, email to dpl and V. Williams for
hearing
6/12/2006 LBD Telephone conference with E. Schuler, 0.30 $275.00 $82.50
atty for CEM Global, discussed
settlement and agreed upon same
6/13/2006 KBO Prepared deposit package for deposit 1.10 $75.00 No Charge
from LD Wholesale.
6/13/2006 KBO Prepared deposit from LD Wholesale, 0.20 $75.00 No Charge
installment payment of 2,666.66
6/15/2006 KBO Telephone call to Nancy Markoff re Intex 1.20 $75.00 $15.00
Recreation settlement check. She ok’d
deposit of check as she will look for
dismissal order around Aug. 1st.
6/15/2006 KBO Prepared deposit package for 0.10 $75.00 No Charge
settlement check from Intex Recreation
to Chase bank.
6/15/2006 LBD Prepared deposit of settlement check 0.20 $275.00 $55.00
from Intex Recreation
6/22/2006 KBO Prepared email to Velda Williams for 0.10 $75.00 No Charge
Total Intl. dismissal order.
7/19/2006 LBD prepare updated spreadsheet regarding 1.00 $300.00 $300.00
preferences, consulted with dpl re
same, updated and advised KBO to
forward dismissal order to V. Williams
by Friday
7/20/2006 KBO Draft motion for default for Gerrit 0.20 $75.00 $15.00
Verburg.
7/26/2006 LBD letter to atty for Intex with copy of 0.30 $300.00 $90.00
dismissal order, advised of case closing
date and review of docket for info
7/27/2006 KBO Revised motion for default for Gerrit 0.20 $75.00 $15.00
Verburg per Ibd’s changes.
7/27/2006 KBO Draft second default motion for Kirch 0.30 $75.00 $22.50
Industrial.
7/27/2006 KBO Draft default order for Gerrit Verburg for 0.20 $75.00 $15.00
second motion for default.
7/27/2006 KBO Draft order for second motion for default 0.20 $75.00 $15.00
for Kirch Industrial.
7/27/2006 KBO Prepared affidavits for motions for 0.20 $75.00 $15.00
default for Kirch Industrial and Gerrit
Verburg.
7/31/2006 KBO Prepared service list for filing of two 0.30 $75.00 $22.50
Page 9
default motions for Kirch Ind. and Gerrit
Verburg. Prepared for filing for Pam or
Gina.
8/02/2006 PIP Preparation Mailing for Motion for 0.50 $50.00 $25.00
Default Judgment on Trustee’s
Complaint to Avoid Preferential
Transfers
Kirch Industrial
8/02/2006 PIP Drafting a Notice of Motion for Motion 0.20 $50.00 $10.00
for Default Judgment on Trustee’s
Complaint to Avoid Preferential
Transfers
Gerrit Verburg Co.
8/02/2006 PIP Preparation and Mailing of Motion for 0.50 $50.00 $25.00
Default Judgment on Trustee’s
Complaint to Avoid Preferential
Transfers
Gerrit Verburg Co.
8/02/2006 PIP Drafted Notice of Motion for Default 0.10 $50.00 $5.00
Judgment on Trustee’s Complaint to
Avoid Preferential Transfers
Kirch Industrial
8/03/2006 LBD Draft settlement agreement for CEM 0.50 $300.00 $150.00
Global settlement
8/03/2006 LBD email to atty for CEM, attached draft 0.20 $300.00 $60.00
settlement and await his review to file
9019 motion, requested response to
same asap
8/11/2006 LBD Telephone conference with A. Farnell re 0.20 $300.00 $60.00
settlement, left msg
8/14/2006 KBO Review preference case/complaint in 0.20 $75.00 $15.00
preparation of drafting motion to
authorize settlement with CEM.
8/14/2006 KBO Draft motion to compromise/settle 0.50 $75.00 $37.50
adversary for CEM Global LLC.
8/14/2006 PIP Amended service list for undeliverable 0.30 $50.00 $15.00
mail to Shao Hua Wu
Entered new address and remailed
8/15/2006 KBO Prepared to file motion to compromise 0.10 $75.00 $7.50
controversy with CEM global, Scanned
does to pdf and merged appropriate
does.
8/15/2006 KBO Prepared supplemental certificate of 0.20 $75.00 $15.00
service for attny of CEM global, Elliot
Schuler.
8/15/2006 KBO Draft order for motion to compromise 0.20 $75.00 $15.00
controversy and settle with CEM
Global.
8/15/2006 KBO Prepared notice of motion for motion to 0.20 $75.00 $15.00
compromise certain preference claim
with CEM.
Page 10
8/15/2006 KBO Prepared MO for Motion to compromise 0.20 $75.00 $15.00
controversy with CEM Global
8/15/2006 KBO Prepared service list for motion to 1.20 $75.00 $15.00
compromise controversy with CEM
global to top 20 creditors and attorney’s
of record.
8/15/2006 KBO Filed motion for entry of an order 0.30 $75.00 $22.50
allowing trustee to compromise certain
preference claim with CEM Global.
8/15/2006 KBO Revise motion to compromise 0.30 $75.00 $22.50
controversy and settle per lbd’s
changes.
8/15/2006 LBD review of draft mtn to authorize CEM 0.30 $300.00 $90.00
settlement, changes thereto and to
KBO for amendments and filing
8/16/2006 MIG Service of Notice of Motion for entry of 0.50 $50.00 $25.00
an order allowing the trustee to
compromise a certain preference claim
8/30/2006 LBD amend and update the adversary case 0.40 $300.00 $120.00
list for 8/31 hearing, email same to V.
Williams for hearing
8/31/2006 DPL Motion for Default Judgement on 0.50 $500.00 $250.00
Trustee’s Complaint/Gerrit; moton for
default on two other matters — status on
4 remaining cases
9/15/2006 PIP Drafted dismissal letter to Alan Farnell 0.50 $50.00 $25.00
and Elliot Schuler and mailed with
dismissal
10/12/2006 LBD Attended hearing-return to office from 1.00 $300.00 $300.00
same
10/12/2006 LBD Court attend hearing on final adversary 1.00 $300.00 $300.00
proceedings, dismissal of one and
continued date on other for citation
10/13/2006 KBO Prepared summons for Citation to 0.30 $75.00 $22.50
discover assets.
10/13/2006 KBO Prepared summons for citation to 0.30 $75.00 $22.50
discoverassets to third party.
10/13/2006 LBD Draft citation to discover assets to 1.10 $300.00 $330.00
Sejal, draft third party citation to
discover assets to CIB Bank, discuss
same with K. Ojanpera, requested she
prepare notice of hearing and minute
order for filing
10/17/2006 KBO Prepared certificate of service to CIB 0.20 $75.00 $15.00
Bank for Citation to Discover Assets.
10/17/2006 KBO Prepared certificate of service to Sejal 0.20 $75.00 $15.00
Inc for citation to discover assets.
Adversary no 04-3375
10/17/2006 KBO Service of certificate of service and 0.20 $75.00 $15.00
citation to discover assets to third party
and Sejal Inc.
10/17/2006 LBD Telephone conference with S. Gururajan 0.30 $300.00 $90.00
Page 11
and Bankruptcy Clerk regarding
issuance of citations to discover
assets, discussed certification and
need for summons
10/17/2006 SG Conference with Bankruptcy Court 0.40 $200.00 $80.00
Clerk’s office and case administrator
regarding whether there was a
requirement to obtain summons for
citation to discover assets, file citation
10/18/2006 KBO Filed certificate of service for citations 0.30 $75.00 $22.50
to discover assets.
10/23/2006 KBO Draft motion for turnover of bank 0.60 $75.00 $45.00
account for Sejal, Inc. from third party
response to citation to discover assets.
10/23/2006 LBD response to citation to discover assets 0.20 $300.00 $60.00
received review of same
10/26/2006 LBD Hearing and or Deadline to file answer 1.00 $300.00 $300.00
for Citations to Discover Assets in
Sejal, advised judge of hold on money
at bank, discussed matter after hearing
with representative of Sejal regarding
citation and Trustee’s unwillingness to
accept anything less than $16,000
10/27/2006 LBD review K. Ojanpera’s initial draft of 0.30 $300.00 $90.00
motion for turnover of funds held in First
Bank account per Third party citation.
Amendments to motion to include
discussion of agreed judgment order,
add language re turnover from First
Bank not from Defendant as previously
drafted
10/30/2006 KBO Revise motion for turnover of funds held 0.40 $75.00 $30.00
by First Bank in Sejal adversary 04-
3375
10/30/2006 KBO Prepared notice of motion for motion for 0.20 $75.00 $15.00
turnover of funds at First Bank in Sejal
Adversary.
11/13/2006 SG Review Trustee’s citation to discover 0.20 $200.00 $40.00
assets and motion to turnover funds in
preparation to attend hearings on the
same, conference with L. Duvall
regarding her conversations with the
debtor at the previous hearing and
Trustee’s position on these motions
11/13/2006 SG Telephone conference with Sejal 0.50 $200.00 $60.00
regarding our motion for turnover,
represented to defendant that we are
not willing to lower the settlement
amount to $8000.00 and we will be
appearing in court requesting the
turnover of $16,000 (.3); Telephone
conference with L. DuVall regarding
Page 12
LakeLaw April 16, 2010
Serving your Legal Needs from Chicago to Milwaukee
420 West Clayton Street
Waukegan, IL 60085-4216
Tel: 847.249.9100
Fax: 847.249.9180
Web: www.lakelaw.com
FEIN: 36-4344743
Regarding: Goldblatts.Secured Creditor
20303.07
Invoice No: 05766
Professional Services Hours Rate Amount
Date Staff Description Hours Rate Charges
Leg — Litigation
3/11/2005 DPL Review letter from L Newman and 1.10 $475.00 $522.50
begin analysis of their assertion of
security interest in certain property of the
Estate, liquidated by Truslee
3/14/2005 DPL LaSalle Bank Secured 0.30 $475.00 $142.50
Phone Lauren Newman regarding
surcharge, bank lien, earmarking.
marshalling and related issues.
3/14/2005 DPL Review letter from L Newman 1.40 $475.00 $665.00
concerning LaSalle Secured Claim;
address Form 2 issues; generally
describe various deposit categories in
detailed correspondence to her.
Carefully review letter prior to sending
the same to L Newman, with all Form 2
documents attached
3/22/2005 DPL Phone call with Dennis Quaid re trustee’s 0.40 $475.00 $190.00
proposed treatment of certain receipts
relative to LaSalle’s secured claim.
Discussed relative treatment of
guarantors Kane. Kane and Amato by
LaSalle and by Trustee in respective
litigation.
5/17/2005 DPL Review letter from L Newman re 0.30 $475.00 $142.50
surcharge and begin to respond utilizing
previously prepared spreadsheet
Page 13
5/27/2005 DPL corr to L. Newman regarding proposed 0.60 $475.00 $285.00
treatment of LaSalle Secured Claim and
surcharge of collateral in connection
there with
6/28/2005 DPL review and revise Goldblatts LaSalle 0.50 $475.00 $237.50
Surcharge Motion
6/28/2005 LBD amendment to mtn to pay LaSalle less 0.30 $225.00 $67.50
surcharges
6/28/2005 LBD draft mtn to authorize payment to 0.60 $225.00 $135,00
LaSalle and surcharge per notes and
draft of 6.24
6/28/2005 LBD conf with DPL re mtn to surcharge and 0.20 $225.00 $45.00
pay LaSalle and corrections to be made
7/02/2005 DPL Revise motion to surcharge collateral to 0.30 $475.00 $142.50
allow payments to Bank less agreed
upon surcharges
7/11/2005 DPL Advise staff regarding who gets notice 0.10 $475.00 $47.50
of this motion
7/11/2005 KBO Prepared Nolice of Motion for M to 0.20 $75.00 $15.00
Authorize Payment of Secured Claim
Less Surcharges.
7/11/2005 KBO Prepared Minute Order for Motion to 0.20 $75.00 $15.00
Auth. Payment of Secured Claim Less
Surcharges.
7/11/2005 KBO Preparation of service list for Motion to 0.10 $75.00 $7.50
Auth. Payment of Secured Claim Less
Surcharges.
7/11/2005 KBO Service of Motion to Auth. Payment of 0.30 $75.00 $22.50
Claim less Surcharge to top twenly
creditors and attny list.
7/11/2005 LBD amendment to mtn to authorize payment 0.50 $225.00 $112.50
of secured claim and draft of order re
same
8/09/2005 LBD Hearing on Motion to Auth. Payment of 1.00 $225.00 $225.00
Secured Claims Less Surcharges and
prepare for same. confer with L.
Newman prior to and after hearing
8/12/2005 LBD conf with KBO re cutting check to LaSalle 0.20 $225.00 $45.00
and from which account, verify with dpl
9/06/2006 DPL phoned Brad regarding LaSalle motion 0.30 $500.00 $150.00
to intervene and grounds for objection
thereto
1/25/2007 DPL Research re secured creditors’ right to 2.00 $500.00 $1,000.00
intervene in Trustee’s preference suit
2/13/2007 DPL called re brief. 0.40 $500.00 $200.00
10/11/2007 DPL In re Goldblatt’s: Leibowitz v. Great 2.00 $575.00 $1,150.00
American and LaSalle — Review Judge
Coar’s decision and discuss with Brad
Nelson
Page 14
1/24/2008 DPL Meet with representatives of GAG as 0.80 $575.00 $460.00
well as counsel from Schopf Weiss to
discuss various aspects of the
case/appeal
1/29/2008 DPL Telephone conference with Quaid re 0.50 $575.00 $287.50
LaSalle complaint
1/29/2008 DPL review LaSalle complaint 0.80 $575.00 $460.00
2/28/2008 DPL research and preparalion of Trustee’s 2.20 $575.00 $1,265.00
Motion to Dismiss
2/28/2008 KBO PRepared service list for molion to 0.10 $150.00 $15.00
dismiss.
2/28/2008 KBO Service of motion to dismiss to service 0.20 $150.00 $30.00
list.
2/28/2008 KBO Prepared notice of motion for motion to 0.30 $150.00 $45.00
dismiss in adv 08-57.
2/28/2008 KBO Prepared to file motion to dismiss 08-57. 0.20 $150.00 $30.00
Saved all docs to pdf and merged
appropriate docs.
2/28/2008 KBO Filed molion to dismiss adversary 08-57 0.30 $150.00 $60.00
2/28/2008 KBO Draft order of dismissal for motion to 0.30 $150.00 $45.00
dismiss adversary 08-57
2/28/2008 KBO Prepared minute order for molion to 0.20 $150.00 $30.00
dismiss.
2/28/2008 KBO Telephone call to Peter Judge Wedoff’s 0.10 $150,00 $15.00
deputy to confirm the scheduling time of
the motion to dismiss. To be scheduled
for 10 am.
3/11/2008 DPL Hearing on M to Dismiss Adversary 1.00 $575.00 $575.00
LaSalle v. Leibowitz in Goldblalts
3/24/2008 DPL review “LaSalle” Response to Motion to 0.50 $575.00 $287.50
Dismiss
3/25/2008 KBO Prepared nolice of filing for reply to 0.30 $150.00 $45.00
motion lo dismiss Pursuant to rule 7012
(b)(6)
3/25/2008 KBO Filed response to molion to dismiss with 0.30 $150.00 $45.00
notice of filing.
3/31/2008 DBG Prepare for hearing in Lasalle Bank v. 0.50 $400.00 $200.00
Leibowirz and review of pleadings in
connection with same.
4/01/2008 DBG Court: attended hearing on molion to 1.00 $400.00 $400.00
dismiss.
4/01/2008 DBG Review of pleadings and motions in 0.40 $400.00 $160.00
case filed by Lasalle Bank to determine
validily of lien in preparation for
hearing: conference with DPL regarding
hearing.
4/22/2008 MIG Administrative Time converled 0.90 $50.00 $45.00
complainf into editable complaint
4/23/2008 KBO Filed answer to complaint. 0.30 $150.00 $45.00
Page 15
publication should be filed under.
11/30/2005 KBO Prepared Notice of Filing for Certificate 0.20 $75.00 $15.00
of Publication of Notice for filing admin
claims.
12/01/2005 KBO Prepared to file claim on behalf of 0.20 $75.00 No Charge
Beantown Marketing. Scanned in
supporting docs and claim saved in pdf
file.
2/06/2006 LBD email to I. Fisher with copy of figures, 0.20 $250.00 $50.00
etc from distribution report for
approximate total of unsecured claims
without objections
2/07/2006 LBD phone call to I. Fisher, left message 0.10 $250.00 $25.00
requesting call back
2/14/2006 LBD letter to B. Shaw requesting accounting 0.30 $250.00 $75.00
of money recd during liquidation and tax
paid, specifically to I DOR
2/17/2006 LBD final draft letter to B. Shaw re GAG 0.20 $250.00 $50.00
accounting of IDOR taxes paid
1/17/2007 WHC Research: does secured party have 1.50 $200.00 $300.00
interest in trustee’s recovery of
fraudulent transfers.
1/25/2007 WHC Further research on whether prepetition 1.50 $200.00 $300.00
secured interest attach to trustee’s
recovery.
1/26/2007 WHC Reviewed cases on line regarding 1.00 $200.00 $400.00
prepetition lien on trustee’s avoidance
action recovery and printed same.
Wrote research memo. Copied cases
10/13/2009 MIG Electronically filed first omnibus 1.00 $100.00 No Charge
objection to claims
10/15/2009 MIG Created Excel spreadsheet with 0.40 $100.00 $40.00
accounts ledgers
10/19/2009 MIG Review of List of judgments per DPl’s 1.00 $100.00 $100.00
request-Emailed David with list of
assets to be determinated as to DA or
FA
10/20/2009 MIG Revised second omnibus objection per 4.90 $100.00 No Charge
Dpl’s review. Printed and organized
Exhibits
11/13/2009 MIG Reviewed of judgement list provided by 2.00 $100.00 $200.00
Jake, searched for unpaid adv.
proceedings. Emailed List to Jake after
review
12/08/2009 MIG met with David to review Motion for sell 0.50 $100.00 $50.00
judgments. — Made revisions.
12/09/2009 MIG prepared service list for motion to sell 1.00 $100.00 $100.00
judgments — prepared motion to file by
printing docs. to pdf
12/09/2009 MIG Prepared Notice of motion to sell 0.30 $100.00 $30.00
12/10/2009 MIG Prepared to file Motion to Sell 0.60 $100.00 $60.00
Page 16
judgments by printing docs. to pdf.
Conf. with Jake from Oak Partners re
Agreement and Month dated
12/10/2009 MIG Electronically filed Motion to Sell 0.00 $100.00 $60.00
Judgments —
12/21/2009 MIG Email DPL and Theresa Scheuer re 0.30 $100.00 $30.00
received stipulation and filing date.
Conf. with Theresa, waiting on David’s
signature.
12/22/2009 MIG Emailed copy of the signed stipulation 0.60 $100.00 $60.00
to opposing counsel, prepared cover
letter to send same via mail. Sent copy
of stipulation via mail
12/28/2009 MIG Revised exhibit A 0.30 $100.00 $30.00
12/30/2009 MIG Prepared service list — finalized exhibit A 1.50 $100.00 $150.00
1/07/2010 MIG List of Judgment with totals 1.50 $100.00 $150.00
1/12/2010 MIG Emailed DPL re supplement to Motion 0.20 $100.00 $20.00
to sell
1/13/2010 MIG Printed COServices for each defendant 2.00 $100.00 $200.00
for the preferences judgements
1/14/2010 MIG Searched for existence of corporation 2.00 $100.00 $200.00
for judgments exhibit
1/14/2010 MIG Finalized excel spreadsheet with list of 0.50 $100.00 $50.00
judgments status, etc. emailed David re
same
1/20/2010 DPL prepare supplement to motion to sell 1.00 $625.00 $625.00
1/27/2010 DPL Court on motion for authority to sell 1.00 $625.00 $625.00
2/09/2010 MIG Prepared Letter to Jake Miller re 0.30 $100.00 $30.00
executed agreement and copy of court
order
2/10/2010 MIG Sent executed agreement with a copy 0.20 $100.00 $20.00
of order to Jake at Oakbrook partners
3/12/2010 MIG 9019 for JTX Companies 0.80 $150.00 $120.00
3/15/2010 JPE Revise 9019 motion for JTX companies. 0.40 $250.00 $100.00
3/17/2010 DPL (CHI) Motion to Approve Compromise or 1.00 $625.00 $625.00
Settlement with Great American
Group-Judge Wedoff
3/17/2010 MIG Prepared to file Motion to authorize 0.20 $150.00 $30.00
settlement with TJX Companies by
printing docs. to pdf
3/17/2010 MIG Electronically filed Motion to authorize 0.40 $150.00 $60.00
settlement with TJX Companies
3/17/2010 SER Service of Motion to Approve Settlement 0.20 $75.00 $15.00
Pursuant to Federal Rule of Bk
procedure 9019 with The TJX
Companies, F/B/O GRP Stony, LLC
Sub Total: Leg — Case Administration $6,415.00
Page 17
10/21/2005 LBD review all claims, adjust claims per 2.40 $225.00 $540.00
settlements in preference actions to
prepare new claims register
10/21/2005 LBD conf with dpl regarding status of LaSalle 0.30 $225.00 $67.50
and GAG claims/currently allowed is 0,
discuss leaving value at 0 for purposes
of M. Goldman report
12/01/2005 KBO Electronically file claim on behalf of 0.40 $75.00 No Charge
Beantown Marketing.
12/09/2005 KBO Filing of claim in Goldlblatts for Eton 0.30 $75.00 No Charge
Trading Inc.
12/09/2005 MIG Phone call with SIMEX TRADING CO. 0.20 $50.00 $10.00
re filing claim.
12/09/2005 MIG Electronically file claim on behalf of 0.40 $50.00 No Charge
SIMEX TRADING CO.
12/09/2005 MIG Prepared to file claim on behalf of 0.20 $50.00 $10.00
SIMEX TRADING CO. Scanned in
supporting docs and claim saved in pdf
file.
2/06/2006 LBD claims review for approximate amount of 0.60 $250.00 $150.00
unsecured/priority claims, excluded late
filed claims in calculation
2/06/2006 LBD phone call with I. Fisher regarding 0.30 $250.00 $75.00
current claim status and approximate
objections, exclusive of GAG and
LaSalle claims
2/10/2006 LBD phone call with I. Fisher regarding all 0.30 $250.00 $75.00
outstanding claims, specifically various
priority claims.
2/10/2006 LBD Goldblatt’s priority creditors and 0.20 $250.00 $50.00
questions as to validity of claim
2/10/2006 LBD review of claims register, pull all taxing 0.60 $250.00 $150.00
authority claims to determine what
liability estate has if any
2/14/2006 LBD phone call to IRS, left message for 0.20 $250.00 $50.00
return call regarding POC filed for
$75000 FICA deficiency
2/14/2006 LBD review of all ILDOR claims to determine 0.30 $250.00 $75.00
if tax incurred during liquidation thus
GAG liability or Estate
2/14/2006 LBD receive phone message from IRS, return 0.20 $250.00 $50.00
phone call re same, left message for
return phone call re filed claims
2/16/2006 LBD receive phone call from Agent at IRS 0.10 $250.00 $25.00
regarding POC, left message to call me
back
2/21/2006 LBD phone call with IRS regarding POC filed, 0.30 $250.00 $75.00
the first return was for 7/1-9/30 period
and they are claiming S75k for prior
quarter, to determine if operating
3/06/2006 MIG Called Tony at Frito Lay re status of 0.10 $50.00 $5.00
claims
Page 18
David’s request
10/27/2009 DPL Preparation of objections to claims 3rd 1.10 $625.00 $687.50
Omnibus
10/27/2009 MIG met with David to finalized review of 1.00 $100.00 $100.00
Claims, Con re objection to claims for
shareholders
10/29/2009 CAC Review and revise omnibus objections 0.30 $300.00 No Charge
10/29/2009 MIG Prepared to file Second omnibus 2.00 $100.00 No Charge
objections, enabling exhibits, etc-
review service list etc
10/29/2009 MIG prepared Notice of withdrawal of claim 0.40 $100.00 $40.00
per dpi’s request to be sent to Brian
Shaw
10/30/2009 MIG prepared to file 2nd omnibus objection 1.00 $100.00 $100.00
to claim by making last minute
revisions and printing docs. to pdf
10/30/2009 MIG Electronically filed 2nd omnibus 2.00 $100.00 No Charge
objection to claims — prepared labels
11/02/2009 JTB First Omnibus Objection to Claims 0.50 $350.00 $175.00
discussion w/Dionne re documents
11/04/2009 MIG Reviewed of Claims for third omnibus 2.00 $100.00 $200.00
objection to be drafted. Prepared excel
spreadsheet with status of each claim
11/09/2009 MIG started Drafting 3rd omnibus objection 1.50 $100.00 No Charge
to claims
11/14/2009 MIG Drafted Notice of objection withdrawal 0.90 $100.00 $90.00
against Salton Toastmaster for DPI’s
Review
11/14/2009 MIG Continued to draft third omnibus 2.90 $100.00 No Charge
objection-emails to DPL re same
11/16/2009 DPL Review and revise notice of withdrawal 0.20 $625.00 $125.00
of objection to claim of Salton
Toastmaster Logistics LLC
11/16/2009 MIG Continued to draft third omnibus 3.00 $100.00 No Charge
objection
11/16/2009 MIG Electronically filed notice of withdrawal 0.40 $100.00 $40.00
on objection to Salton Toasmaster
logistics llc
11/16/2009 MIG Emailed David re reviewing notice of 0.20 $100.00 $20.00
withdrawal of objection to claim of
salton toastmaster logistics, llc
11/17/2009 CAC Conference with JTB and MIG regarding 0.30 $300.00 $90.00
omnibus objections; review Rule 3007
regarding same
11/17/2009 MIG emailed Jonathan re order for Jaylyn 0.30 $100.00 $30.00
Sales
11/17/2009 MIG Finalized third objection, review 4.00 $100.00 $400.00
objections to find reasons etc. conf.
with Jtb re same
11/17/2009 MIG Prepared Draft Minute Order per 1.00 $100.00 $100.00
Jonathan’s request. conf with Carrie re
Page 19
12/08/2009 MIG emailed draft stipulation to Therese A. 0.10 $100.00 $10.00
Scheuer for her review RE: Claims 219,
220 and 221
12/08/2009 MIG Revised MOTION TO SELL 0.40 $100.00 $40.00
JUDGMENTS
12/08/2009 MIG Draft objection to claim 27 filed by B 0.50 $100.00 $50.00
F Coffee
12/08/2009 MIG Draft objection to claim 41 filed by 0.50 $100.00 $50.00
Bazaar Inc
12/14/2009 MIG continued to Draft individual objection 1.50 $100.00 $150.00
to claims for dpl’s review
12/15/2009 DPL met with Maria to review individual 1.00 $625.00 $625.00
objections to claim
12/15/2009 DPL Preparation of objections to several 1.50 $625.00 $937.50
claims — detailed objections in light of
amendments to Rules of Bankruptcy
Procedures, compared claims to
schedules
12/15/2009 MIG met with David to review individual 1.00 $100.00 $100.00
objections to claim
12/15/2009 MIG revised approximately 20 objections as 5.00 $100.00 $500.00
per dpl’s review including exhibits
12/15/2009 VME reviewed and edited objections to 3.00 $100.00 $300.00
claims
12/16/2009 DPL Court on objection to IDOR claim 1.00 $625.00 $625.00
12/16/2009 DPL Conference with Newbodl RE: objection 0.10 $625.00 $62.50
to IDOR claim
12/16/2009 DPL Phone conversation with Naughton of 0.30 $625.00 $187.50
GAG RE:objection to IDOR claim
12/17/2009 JPE Advise on preparation of omnibus 0.20 $250.00 $50.00
claims objection.
12/18/2009 JPE Edit Omnibus objection to claims 0.50 $250.00 $125.00
12/18/2009 MIG Revised Omnibus objection to duplicate 2.00 $100.00 $200.00
claims alphabetically, prepared exhibit A
with creditors’ addresses — Conf. with
John Eggum re same — Emailed David
with final draft
12/21/2009 JPE 3001 Objection to Claims — draft form for 0.50 $250.00 $125.00
multiple objections
12/21/2009 MIG Draft objection to claim 87 filed by D 0.80 $100.00 $80.00
L apparel -conf with John Re same
12/22/2009 DPL revise omnibus objection to claims in 0.50 $625.00 $312.50
accordance with rules
12/22/2009 DPL revise objection to claim 87 in light of 0.50 $625.00 $312.50
Iqbal and Judge Wedoff’s prior opinions
regarding claim objection standards —
these changes apply to other claim
objections as well.
12/22/2009 MIG Electronically filed stipulation to claims 0.30 $100.00 $30.00
219, 220 and 221
12/31/2009 MIG Filed Omnibus objection to claim 2.00 $100.00 $200.00
Page 20
1/05/2010 MIG Drafted Objection to claim 193 0.80 $100.00 $80.00
1/05/2010 MIG Drafted Objection to claim 208 0.50 $100.00 $50.00
1/05/2010 MIG Drafted Objection to claim 134 0.80 $100.00 $80.00
1/05/2010 MIG Drafted Objection to claim 150 0.80 $100.00 $80.00
1/05/2010 MIG Drafted Objection to claim 145 0.80 $100.00 $80.00
1/05/2010 MIG Drafted Objection to claim 158 0.80 $100.00 $80.00
1/05/2010 MIG Drafted Objection to claim 203 0.50 $100.00 $50.00
1/05/2010 MIG Drafted Objection to claim 182 0.80 $100.00 $80.00
1/05/2010 MIG Draft Objection to claim 178 0.80 $100.00 $80.00
1/05/2010 MIG Revised Objection to claim 158 per 0.20 $100.00 $20.00
Attorney’s review.
1/05/2010 MIG Drafted Objection to claim 159 0.50 $100.00 $50.00
1/05/2010 MIG Objection to Con-Way Claim 0.80 $100.00 $80.00
1/05/2010 MIG Objection to claim 131 0.80 $100.00 $80.00
1/06/2010 MIG Drafted Objection to claims 190 and 0.80 $100.00 $80.00
261
1/06/2010 MIG Draft Objection to claim 270 0.80 $100.00 $80.00
1/06/2010 MIG Drafted Objection to claim 250 0.50 $100.00 $50.00
1/06/2010 MIG Draft Objection to claim 278 0.80 $100.00 $80.00
1/06/2010 MIG Emailed Carrie with objection to claims 0.50 $100.00 $50.00
1/11/2010 CAC Review and revise objections to claims 0.70 $300.00 $210.00
1/17/2010 MIG Prepared to file Objection to claim 158 0.20 $100.00 $20.00
by printing docs. to pdf
1/19/2010 DPL Objection to Claims 75 and 275 — 0.40 $625.00 $250.00
Armouth — 502(d)
1/19/2010 DPL Preparation for and attendance at Court 1.80 $625.00 $1,125.00
on 10 objectionsto claims’
1/19/2010 DPL Prepare objection to claim based on 0.50 $625.00 $312.50
502(d) — preference judgment
outstanding.
1/19/2010 DPL corr Therese Scheuer regarding 0.10 $625.00 $62.50
amended proof of claim
1/19/2010 DPL Conference with Jim Newbold re 0.40 $625.00 $250.00
resolution of objection to IDOR claim in
Goldblatt’s
1/19/2010 JPE Begin drafting section 502d motion. 0.30 $250.00 $75.00
1/19/2010 MIG Exchanged Emails with David re 0.60 $100.00 $60.00
hearing on objection to claims. Last
batch to be filed after his revisions
1/19/2010 MIG Made Revisions to objections prepared 3.00 $100.00 $300.00
for filing
1/19/2010 MIG Prepared amended proof of claim for for 0.40 $100.00 $40.00
The TJX companies per David’s
instructions and as per Judge’s clerk
1/20/2010 CAC Final revision of objections to claims 0.30 $300.00 $90.00
229, 190, 261, 181, and 270
1/20/2010 JPE Complete form for 502d objections 0.50 $250.00 $125.00
related to avoided claims.
1/20/2010 MIG Electronically filed second batch of 3.00 $100.00 No Charge
Objection to claims — Hearing on
02/23/2010
Page 21
1/20/2010 SER Service of Multiple objection to Claim 1.00 $75.00 $75.00
1/21/2010 JPE Draft 502d motion re Carolina 0.50 $250.00 $125.00
Manufacturing Co.
1/21/2010 JPE Draft 502d motion re HS Signs 0.50 $250.00 $125.00
1/21/2010 JPE Draft 502d motion re Chateau 0.40 $250.00 $100.00
International
1/21/2010 JPE Draft 502d motion re Blitzz International 0.60 $250.00 $150.00
1/21/2010 JPE Draft 502d motion re Kirch Industrial 0.40 $250.00 $100.00
1/21/2010 JPE Draft 502d motion re Kevins Wholesale 0.40 $250.00 $100.00
Co.
1/21/2010 JPE Make changes to 502d form per DPL 0.40 $250.00 $100.00
and JTB.
1/22/2010 JPE Draft 502d re Lion Force (first claim) 0.40 $250.00 $100.00
1/22/2010 JPE Draft 502d re Lion Force (second claim) 0.30 $250.00 $75.00
1/22/2010 JPE Prepare all 502d motions for filing (incl. 0.30 $250.00 $75.00
upload to internal system and
correspond with MIG)
1/22/2010 JPE Draft 502d re Chateau (second claim) 0.20 $250.00 $50.00
1/22/2010 MIG Electronically File objections to claims 1.50 $100.00 $150.00
1/22/2010 MIG Conference with John re filing objection 0.40 $100.00 $40.00
to claims where Trustee has a judgment
1/22/2010 MIG Prepared to filed objections to claims 0.70 $100.00 $70.00
by printing docs to pdf
2/02/2010 DPL (CHI) Objection to Claim [709] (Jdg 1.00 $625.00 $625.00
Wedoff) — omnibus objection granted —
two claims to be addressed separately —
Bazaar claim continued
2/04/2010 MIG Printed and updated BMS with 0.90 $100.00 $90.00
objections granted
2/05/2010 MIG Service of Notice of withdrawal of 0.10 $100.00 $10.00
objection to claim 145
2/05/2010 MIG Prepared Notice of withdrawal to 0.30 $100.00 $30.00
objection to claim 145
2/09/2010 MIG Prepared amended POC sent to 1.00 $100.00 $100.00
Creditors for signature
2/15/2010 MIG Conference with David re Trial Claims 0.20 $150.00 $30.00
Objections. He is to appear
2/15/2010 MIG Electronically filed amended POC for 0.40 $150.00 $60.00
claim 153 — Emailed filed claim to
Creditors
2/16/2010 DPL Court appearance before Judge Wedoff 1.00 $625.00 $625.00
in connection with objection to
Landlord’s claims — trial — creditors did
not appear. Objections sustained
2/16/2010 MIG emailed copy of the filed claim to 0.20 $150.00 $30.00
Karen at L Craven Sons. Claim 216
2/16/2010 MIG Filed amended claim to claim 216 (.2) 0.20 $150.00 $30.00
emailed copy of the filed claim to Karen
at L Craven Sons (.2)
2/23/2010 DPL Court appearance on objections to 1.00 $625.00 $625.00
numerous claims, all objections
Page 22
sustained
2/24/2010 MIG Preparation of orders disallowing claims 0.40 $150.00 $60.00
2/25/2010 MIG Letter transmitting form 941 to IRS 0.10 $150.00 $15.00
demonstrating that there were no
employees in the period prior to June
2000, necessary for withdrawal of IRS
priority claim
2/25/2010 MIG Advised Judge Wedoffs clerk that 0.10 $150.00 No Charge
objection to claim 41 was to be
withdrawn.
2/26/2010 DPL research regarding $74,000 IDOR claim 1.50 $625.00 $937.50
and investigation re possible liability of
LaSalle/Bank of America — concluded
not worthy of further estate time and
effort
3/01/2010 MIG Telephone conference with Becka re 0.10 $150.00 $15.00
941 form to call her tomorrow
3/01/2010 MIG Draft minute order to withdraw of 0.20 $150.00 $30.00
objection to claim 41
3/01/2010 MIG Electronically filed amended proof of 0.40 $150.00 $60.00
claim 219 — Emailed a copy of the filed
claim to creditor
3/02/2010 JPE Revise minute order for withdrawal of 0.30 $250.00 $75.00
objection.
3/02/2010 MIG Follow up with creditors re POC filed 0.80 $150.00 $120.00
and waiting on their amended POC
forms for allowance of unsecured
general claim
3/02/2010 MIG Telephone conference with Becka re 0.10 $150.00 $15.00
941 form to call her tomorrow
3/03/2010 JPE Revise objection to claim. 0.20 $250.00 $50.00
3/03/2010 MIG Follow up with creditors re amended 0.50 $150.00 $75.00
POC
3/03/2010 MIG Left a message for Becka IRS counsel 0.10 $150.00 $15.00
to call our office re 941 sent
3/05/2010 JPE Assist MIG re objection to priority 0.30 $250.00 $75.00
claim.
3/05/2010 JPE Revise objection to claim 261 0.20 $250.00 $50.00
3/05/2010 JPE Revise claim 20 0.20 $250.00 $50.00
3/05/2010 JPE Revise objection to claim 233. 0.40 $250.00 $100.00
3/05/2010 JPE Revise objection to claim 190 0.30 $250.00 $75.00
3/05/2010 MIG Prepared to file Objection to claim 261 0.20 $150.00 $30.00
by printing docs. to pdf
3/05/2010 MIG Electronically filed Objection to claim 0.40 $150.00 $60.00
261
3/05/2010 MIG Service of Objection to claim 261 0.20 $150.00 $30.00
3/05/2010 MIG Prepared to file Objection to claim 20 0.20 $150.00 $30.00
by printing does to pdf
3/05/2010 MIG Electronically filed Objection to claim 0.40 $150.00 $60.00
20
3/05/2010 MIG Service of Objection to claim 20 0.20 $150.00 $30.00
Page 23
3/05/2010 MIG Drafted objection to claims 190, 261, 20 2.00 $150.00 $300.00
and 233
3/05/2010 MIG Prepared to file Objection to claim 233 0.20 $150.00 $30.00
by printing to pdf
3/05/2010 MIG Electronically filed Objection to claim 0.40 $150.00 $60.00
233
3/05/2010 MIG Service of Objection to claim 233 0.20 $150.00 $30.00
3/05/2010 MIG Prepared to file Objection to claim 190 0.20 $150.00 $30.00
by printing docs.to pdf
3/05/2010 MIG Electronically filed Objection to claim 0.40 $150.00 $60.00
190
3/05/2010 MIG Service of objection to Objection to 0.20 $150.00 $30.00
claim 190
3/08/2010 MIG Conference with David re additional 0.20 $150.00 $30.00
claims objections to be filed.
3/09/2010 MIG Electronically filed amended proof of 0.40 $150.00 $60.00
claim to claim 155. (.20) email a filed
copy to creditor. (20)
3/09/2010 MIG Follow up with with creditors re 0.80 $150.00 $120.00
amended proof of claims — claim 155 to
send amended proof of claim today.
Claim 144 faxed amended proof fo claim
for signature and emailed amended
proof of claim 55 for executions
3/10/2010 MIG Prepared excelspread sheet with totals 0.40 $150.00 $60.00
for assets# per David’s request
3/10/2010 MIG Electronically filed amended poc to 0.30 $150.00 $45.00
claim 55
4/05/2010 MIG Follow up with Creditors RE: amended 0.40 $150.00 $60.00
proof of claims.
4/05/2010 MIG Electronically filed amended proof of 0.30 $150.00 $45.00
claim to claim 144
4/08/2010 MIG Emailed amended proof of claim to 0.10 $150.00 $15.00
claim 195
4/08/2010 MIG Telephone conference with National 0.20 $150.00 $30.00
Fashions Imports re Claim 195 to file an
amended proof of claim to reflect status
of claim. Unsecured claim
4/08/2010 MIG Electronically filed amended proof of 0.20 $150.00 $30.00
claim to claim 195
4/08/2010 MIG Telephone conference with Teri Lingerie 0.20 $150.00 $30.00
re duplicate claim filed
4/08/2010 MIG Prepared amended proof of claim to 0.30 $150.00 $45.00
claim 195
4/08/2010 MIG Follow up with Hoover re amended proof 0.10 $150.00 $15.00
of claim 210
4/08/2010 MIG Emailed claim register to Teri Lingerie 0.40 $150.00 $60.00
Company and copies of claims 197 and
270 both filed for the same amount. 270
was amended but we need 197 to be
withdrawn
Page 24
LakeLaw April 16, 2010
Serving your Legal Needs from Chicago to Milwaukee
420 West Clayton Street
Waukegan, IL 60085-4216
Tel: 847.249.9100
Fax: 847.249.9180
Web: www.lakelaw.com
FEIN: 36-4344743
Regarding: Goldblatts.Tax
20303.05
Invoice No: 05766
Professional Services Hours Rate Amount
Date Staff Description Hours Rate Charges
Leg — Case Administration
3/31/2010 HAP emailed Mr. Newbold requesting a 0.10 $150.00 $15.00
signed copy of the settlement
agreement
4/12/2010 MIG Prepared Checks for David’s signature, 0.40 $150.00 $60.00
(.20) prepared Fedex Envelope to send
payment (.20)
Sub Total: Leg — Case Administration $75.00
Leg — Tax Issues
3/15/2005 LBD review tax levy form sent to dpl and 0.20 $225.00 $45.00
consider how to handle il.
4/26/2005 DPL review 2004 tax returns, K-l’s, and 2004 0.40 $475.00 $190.00
tax returns to the IDR.
3/15/2006 DPL Corr with Nelson and Fisher re 0.20 $500.00 $100.00
discrepancies with tax and tax
accounting vis a vis Goldblatts’ officers
and directors
3/15/2006 DPL Corr with Naughton re discrepancies 0.30 $500.00 $150.00
with tax and tax accounting vis a vis
Goldblatts’ officers and directors
4/29/2009 DPL Discuss with Nelson RE: proof of claim 0.30 $625.00 $187.50
filed by IDOR
5/07/2009 DPL Goldblatts Bargain Stores — review 1.50 $625.00 $937.50
Petition for Review — work on petition for
review
Page 25
3/28/2005 DPL Preparation of motion for employment of 0.50 $475.00 $237.50
Michael Goldman as forensic
accountant. Add information in motion
regarding his background and prior
assignments; add information in motion
regarding other engagements for me as
Trustee in other estates
3/28/2005 KBO Revise Affidavit for Michael Goldman 0.20 $75.00 No Charge
and attach resume and history on
forensic work.
3/29/2005 KBO Preparation of all documents needed for 0.60 $75.00 $45.00
Employment of Michael Goldman
scanned, merged and printed to PDF
documents for electronic filing.
3/30/2005 DPL Preparation of amended fee application 0.60 $475.00 $285.00
— trustee — begin review and recategorize
time previously billed as professional
time by trustee’s staff
3/30/2005 LBD conf with DPL re professional legal time 0.40 $225.00 $90.00
v. trustee time, DPL requested review of
all time enteries to verify same
4/13/2005 DPL Revise and finalize Trustee’s Amended 1.80 $475.00 No Charge
First Interim Fee Application
4/13/2005 DPL finalize attorneys fee application 2.50 $475.00 $1,187.50
4/21/2005 DPL Hearing on employment of Michael 0.50 $475.00 $237.50
Goldman — allowed over objection of
Kane et al
We set if for 21 days out because of
notice needing to go to top 20 creditors
room 744
4/27/2005 CDW Draft Reply to Objections to Trustee’s 1.00 $175.00 $175.00
and Leibowitz Law Center’s Amended
First Application for Interim
Compensation and Expense
Reimbursement and ECF
4/27/2005 DPL Brief reply to objections to fees 0.20 $475.00 $95.00
4/28/2005 KBO Draft Trustee’s Motion to Employ 0.60 $75.00 $45.00
Michael J. Kelly as Appraiser for
Goldblatt’s Store located at 4700 S.
Ashland Ave., Chicago, IL
4/28/2005 KBO Draft Declaration of Michael J. Kelly as 0.30 $75.00 $22.50
Appraiser for Goldblatt’s Store on
Ashland Ave.
5/09/2005 DPL Review amended fee applications of 1.20 $475.00 No Charge
Trustee and Leibowitz Law Center,
objections. Prepare draft orders
allowing applications, leaving amounts
blank.
