(DORSEY’S INVOICES – ANCILLARY PROCEEDINGS) · C. Martinez 0.40 112.00 Keller -Draft first set of interrogatories, requests for production, and requests for admission (.4) C

EXHIBIT B2-E, PART 2

(DORSEY’S INVOICES – ANCILLARY PROCEEDINGS)

Case 2:12-cv-00591-BSJ Document 954-9 Filed 06/19/15 Page 1 of 200

C :J» DORSEY DORSEY & WHITNEY LLP

SALT LAKE CITY OFFICE 801-933-7360

(Tax Identification No. 41-0223337)

STATEMENT OF ACCOUNT FOR PROFESSIONAL SERVICES

Klein & Associates, PLLC 1 0 Exchange Place, #502 Salt Lake City, UT 84111

Client-Matter No.: 492728-00099 Timothy F. Keeton

For Legal Services Rendered Through December 31, 2014

INVOICE TOTAL

Total For Current Legal Fees

Total For Current Invoice

··~--

April 27, 2015 Invoice No. ******

Fdt+·our cor:~·,:riienc~(I'lease r'i~i.;i{payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify{1l: hn'"·';ti!<5' questidii:it~tiatding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei'.•;sllle Dep\i-;(!,i.=ent aH-800-861-0760. Thank you.

Mailing lf::;tructions: Dorsey & 'Nhitney LLP P.O. Box 1680

Wire Instructions: U.S. Bank National Association 800 Nicollet Mall

Minneapolis, MN 55480-1680 Minneapolis, MN 55402

ABA Routing Number: 091000022 Account Number: 1602-3010-8500 Swift Code: USBKUS441MT

01936

Please make reference to the invoice number

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which ei1her have not been received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY


()»DORSEY DORSEY & WHITNEY LLP





Client-Matter No: 492728-00099

Timothy F. Keeton

April27, 2015 Invoice No. ******


04/29/14

05/05/14

05/16/14

12/29/14

E. Stauffer 0.20 37.00 Receive and review default certificate entered by clerk, update matrix (.2)

E. Stauffer 0.20 37.00 Receive and review motion to transfer case to Judge Jenkins (.2)

E. Stauffer 0.20 37.00 Receive and review amended motion for transfer of cases to Judge Jenkins, filed in the main case (.2)

C. Martinez 0.20 61.00 Review statute providing for stay of proceedings in light of defendant's military service and correspond with opposing counsel re same

Total Hours 0.80

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTIJERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY



( J}) DORSEY DORSEY & WHITNEY LLP




Klein & Associates, PLLC 10 Exchange Place, #502 Salt Lake City, UT 84111

Client-Matter No.: 492728-00129 Jim Keller

May 22,2015 Invoice No.******

-------------------------------------,.···············--····-········---

For Legal Services Rendered Through December 31,2014

INVOICE TOTAL

Total For Current Legal Fees $534.00

Total For Current Invoice $534.00

Fo; your CO!''-'<;nience, ;.lease :-:-:,;roir payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfY'""·' h1\·:: ;;:;;· rmestio;:·: r;'t;arding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei' ;;iJJe Depa! i ;r:ent l<l J-800-861-0760. Thank you.

Mailing !;;:;tructions: Dorsey & .,,,'1-Jitney LLP P.O. Box 1680



ABA Routing Number: 091000022 Account Number: 1602-3010-8500 Swift Code: USBKUS44IMT

01936





C J» DORSEY DORSEY & WHITNEY LLP






Jim Keller

May22, 2015 Invoice No. ******


02/04/14

02/27114

03/21/14

04/21114

04/24/14

05/21/14

E. Stauffer 0.30 55.50 Prepare spreadsheet of Keller case showing total transfers and false profit transfers and calculate false profit transfers occurring after 2008 for possible settlement negotiations with Toone (.3)

C. Martinez 0.30 84.00 Keller - Draft stipulated motion and order to amend scheduling order (.3)

C. Martinez 0.40 112.00 Keller - Draft first set of interrogatories, requests for production, and requests for admission (.4)

C. Martinez 0.10 28.00 Keller- Correspond with opposing counsel concerning facts of case (.1)

C. Martinez 0.60 168.00 Keller - Prepare for meeting and meet with opposing counsel and defendant to discuss settlement (.6)

C. Martinez 0.10 28.00 Jim Keller - Correspond with opposing counsel regarding possible settlement (.1)




Klein & Associates, PLLC Client-Matter No.: 492728-00129 Invoice No.: ******

05/22/14 C. Martinez


Total Hours

C :lJ> DORSEY

0.10

0.10

2.00

DORSEY & WHITNEY LLP

28.00

30.50

May 22,2015 Page 2

Jim Keller- Correspond with opposing counsel concerning settlement (.1)

Correspond with opposing counsel re settlement check.

Total for Legal Fees .$534~00

Total This Invoice $534.00





C)» DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00121 Kleen Water Power LLC


--------------------------------------···············--····-········---


INVOICE TOTAL

Total For Current Legal Fees $1,071.00

Total For Current Invoice $1,071.00

For your cor.<:wience, )ease ;·(:~t:it payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifyi.•l' hn,·::: :tr:y question.:. r-::;arding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei~<tble Depall:l:~nt til l-800-861-0760. Thank you.

Mailing l::::tructions: Dorsey & \\"hitney LLP P.O. Box lo80



ABA Routing Number: 091000022 Account Number: 1602-30 I 0-8500 Swift Code: USBKUS44IMT

01936











Kleen Water Power LLC



01/15/14

01/22114

01/23/14

01/23114

02/06/14

04/17114

E. Stauffer 0.60 111.00 Prepare documents for production with initial disclosures in Larsen case (.6)

E. Stauffer 0.30 55.50 Review files re status of attempts to serve defendant, memo to C. Martinez re same (.3)

C. Martinez 0.20 56.00 Investigate current location and status of service of defendant and outline strategy for service of same (.2)

E. Stauffer 0.20 37.00 Correspond with process server re service on address given, on whomever opens the door (.2)

E. Stauffer 0.20 37.00 Receive and review proof of service of summons and complaint on Keen Water, file with the court and update calendar/matrix (.2)

E. Stauffer 1.10 203.50 Prepare default certificate paperwork, perform bankruptcy search and military service members search for Kleen Water






04/24/14 E. Stauffer




06/27114 E. Stauffer

12/16114 C. Martinez

Total Hours

C)» DORSEY

0.30

0.30

1.20

0.20

0.20

0.30

0.20

5.30


84.00

55.50

222.00

37.00

56.00

55.50

61.00

May 22,2015 Page2

Power (1.1)

Revise application for entry of default certificate, default certificate, and declaration in support of application for entry of default certificate (.3)

Draft declaration in support of application for default certificate and draft default certificate in Kleen Water Power case (.3)

Finalize and file application for entry of default judgment in Kleen Water Power case, correspond with court clerk re same (.4) update tracking matrix (.8)

Receive and review default certificate in Kleen Water Power matter, update matrix (.2)

Revise application for default judgment and supporting affidavits (.2)

Finalize and file application for entry of default judgment for Kleen Water, correspond with court clerk re same, update matrix (.3)

Review Court's order on motion for default judgment and outline response to same

Total for Legal Fees $1,071.00

Total This Invoice $1,071.00

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement.




( }J> DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00019 Kim La Valley


~~;~~~(ii&jiifj{; -~;: >. , ·~

-------------------------------------~·:··pi'f,;'~''?·ij:;,. '''!i:;;:r;~/&~~J¥-~i~:._\5_ .. __

)d~-. ~( .. j .. :.:.· ·. ·"' =;~::~ -~;,::~ ·r5w:;-~ ·:::~~- -~i>;: ;~-.:-:j~~~---

':::·;,. ·~{'; ~t~:? .... ;~'!:-'-.

·\fUt~- . '.~\~ -~~i~¥flt~~\?:-:

For- Legal Services Rendered Through December 31, 2014

INVOICE TOTAL



..

F&· .. ;(our co1_1;ii!.nience;•;:lease,;£~i!itpayment to the address below or we offer the option of remitting payment electronically by wire transfer. lfyi.·;(;;h~·~(:\,:•?questio:w(~\;_t~fding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receh~~ble Dep~i-l:r:ent ad-800-861-0760. Thank you.

Mailing ·l1\structions: Dorsey & Whitney LLP P.O. Box i~8o




01936


Service charges are based on ra1es established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WIIITNEY


C j» DORSEY DORSEY & WHITNEY LLP






Kim La Valley



01/27/14

02/15/14

02118/14

02/25/14

03i02/14

03/03114

03/10/14

C. Martinez 0.30 84.00 Prepare attorney planning meeting report and scheduling order and correspond with opposing party re same (.3)

C. Martinez 0.10 28.00 Correspond with opposing party concerning scheduling order and attorney planning meeting report (.1)

C. Martinez 0.10 28.00 Phone conference with K. La Valley concerning scheduling order and attorneys' planning meeting report ( .1)

E. Stauffer 0.20 37.00 Finalize and file attorney planning meeting report and proposed scheduling order ( .2)

C. Martinez 0.40 112.00 Draft initial disclosures and compile documents for same

E. Stauffer 0.70 129.50 Prepare documents for production with initial disclosures (. 7)

E. Stauffer 0.30 55.50 Receive and review scheduling order, update calendar/matrix (.3)

S~ice charges arc based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disburse-ments and service charges, which either have not been received or processed. wiiJ appear on a later statement





03/18/14 M. Hunt













C}}) DORSEY

0.40

0.10

0.20

0.20

0.20

0.20

0.20

0.20

0.20

0.20

0.20

0.30

0.20

0.70


112.00

37.00

37.00

56.00

37.00

37.00

37.00

37.00

37.00

37.00

37.00

55.50

37.00

213.50

April27, 2015 Page2

Draft first set of interrogatories and requests for production to K. LaValley and Da Vinci Retirement Trust (.4)

Correspondence with C. Martinez and E. Stauffer regarding Toone entry of appearance and need to prepare discovery and add to settlement letter (.1)

Receive and review substitution of counsel for B. Toone (.2)

Draft first set of interrogatories, requests for production and requests for admission (.2)

Receive and review docket note to follow short form of discovery (.2)

Review plaintiffs 1st set of discovery requests and incorporate into electronic filing system (.2)

Receive and review defendant's initial disclosures (.2)

Receive and review motion for transfer of case to Judge Jenkins (.2)

Receive and review order re motion for reassignment to Judge Jenkins (.2)

Receive and review amended motion for transfer of cases to Judge Jenkins, filed in the main case (.2)

Review expert disclosure and organize files re same (.2)

Prepare copy of supplemental disclosures and letter to opposing counsel forwarding same (.3)

Letter to B. Toone with supplemental disclosures (.2)

Draft memorandum in support of motion for summary judgment

Servi~ charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement

ALL INVOICES ARE DUE 30 OA YS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY




12/29/14 C. Ma11inez

Total Hours

C :1» DORSEY

1.10

0.30

7.00


335.50

91.50

April27, 2015 Page 3

Draft motion for summary judgment and supporting declaration ofW. Klein

Draft and file motion to amend scheduling order

Service.charges arc based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursement's and service charges, which either have not been received or processed. will appear on a later statement.




( )» DORSEY DORSEY & WHITNEY LLP


(fax Identification No.4 I -0223337)





·~i ... ~;~.~~.. ""1~'J;/. ,-·. 2~ -~=--.i.::.-.'.= ~ .. ·.:.~~~1~tr/ .. ·j=?t~:;·; '\-k-. ~ "/

INVOICE TOTAL


$10,522.50

. .. v ·._;{~ ~-~·

Forcyour C9.!1~;ihienc({j';~east;-:ria\it payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfy(,('; h.ai:;l'i\!;;yquestiobci.ri,},t_.arding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Rwii-. ,;tile Depuft:;~l::,nt ud -800-861-0760. Thank you .

. :. . .. : ~: : .

Mailing ii\'i:tructions: Dorsey & ~VIJitney LLP P.O. Box JoHO




01936

Pleftse make reference to the invoice number




C }» DORSEY DORSEY & WHITNEY LLP



STATEMENT OF ACCOUNTFORPROFESSIONAL SERVICES



Reed Larsen



01114114

01/15/14

01/27/14

03/07/14

03/25114

03/26/14

C. Martinez 1.30 364.00 Reed Larsen- Prepare initial disclosures and compile documents to produce with initial disclosures

C. Martinez 1.30 364.00 Reed Larsen - Draft Initial Disclosures and compile documents to produce along with initial disclosures (1.3)

C. Martinez 0.20 56.00 Reed Larsen- Correspond with opposing counsel concerning defendant's failure to serve of initial disclosures (.2)

C. Martinez 0.50 140.00 Reed Larsen - Review documents produced by R. Larsen (.5)

C. Martinez 0.40 112.00 Reed Larsen - Prepare first set of document requests, interrogatories, and requests for admission (.4)

C. Martinez 0.60 168.00 Reed Larsen - Review initial disclosure documents produced by R. Larsen to help prepare discovery requests (.6)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, wiiJ appear on a later statement.




03/31/14 M. Hunt




04/22/14 M. Hunt


05/07/14 M. Hunt




-., 06/13/14 C. Martinez


C J» DORSEY

0.10

0.10

0.20

0.10

0.10

1.50

0.50

0.10

0.30

0.20

1.10

0.20


37.00

28.00

56.00

28.00

37.00

420.00

185.00

28.00

84.00

56.00

308.00

56.00

April27, 2015 Page2

Correspondence with C. Martinez regarding status (Larsen) ( .1)

Reed Larsen- Correspond with W. Klein regarding asset investigation related toR. Larsen (.1)

Reed Larsen - Correspond with opposing counsel concerning possible settlement (.2)

Reed Larsen - Correspond with opposing counsel concerning possible settlement meeting ( .1)

Correspondence with C. Martinez regarding meeting with opposing counsel (.1) (Larsen)

Reed Larsen - Prepare for and meet with attorneys representing R. Larsen to discuss possible settlement (1.5)

Conference with C. Martinez regarding R. Larsen settlement conference and notes on same (.2); meeting with opposing counsel regarding same (.3)

Reed Larsen - Correspond with opposing counsel concerning possible settlement and scheduling order ( .1)

Reed Larsen- Prepare for Friday's status conference hearing (.3)

Reed Larsen- Review hardship affidavit and correspond with opposing counsel regarding same (.2)

Reed Larsen - Prepare for and attend status conference hearing(.9); review hardship affidavits and correspond with W. Klein regarding same ( .2)

Reed Larsen - Outline strategy for settlement with R. Larsen (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of tho-se rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement














07/15/14 M. Hunt




( )» DORSEY

0.40

0.20

0.10

0.10

0.40

0.10

0.90

0.30

0.70

0.70

0.10

0.90

0.30

0.80


112.00

56.00

28.00

28.00

112.00

28.00

252.00

84.00

196.00

196.00

37.00

252.00

84.00

224.00


Reed Larsen- Strategize response to R. Larsen in light of financial information provided (.4)

Reed Larsen - Correspond with opposing counsel concerning settlement (.2)

Reed Larsen- Correspond with W. Klein regarding settlement offer from R. Larsen (.1)

Reed Larsen- Correspond with W. Klein regarding settlement proposal to R. Larsen (.1)

Reed Larsen - Phone and email correspondence with opposing counsel concerning Receiver's settlement offer (.4)

Correspond with opposing counsel concerning possible settlement

Larsen- Draft counteroffer toR. Larsen and phone conference with opposing counsel re same

Reed Larsen - Multiple settlement correspondence with R. Larsen's attorney

Reed Larsen - Draft settlement agreement

Reed Larsen - Prepare for and attend status conference

Review settlement agreement provisions and conference with C. Martinez regarding same (.1)

Revise motion for court to approve settlement with R. Larsen

Correspond with opposing counsel concerning settlement agreement and revise same

Revise memorandum in support of motion to approve settlement with R. Larsen

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates llas been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement.




07/21/14 M. Hunt


07/22/14 M. Hunt


07/23/14 M. Hunt


07/25/14 M. Hunt

C)» DORSEY

0.30

0.50

0.10

0.20

1.10

0.10

2.80



111.00 Review further changes to Larsen settlement motion, request further information, and correspondence with C. Martinez regarding same (.3)

140.00 Revise settlement agreement and correspond with P. Hunt re same.

37.00 Correspondence with W. Klein and C. Martinez regarding further revisions to settlement agreement (.1)

56.00 Correspond with opposing counsel concerning settlement and revisions to settlement agreement.

407.00 Further revise settlement agreement to include ABis, further reps and warranties, and fix consistency in defined terms, and email toW. Klein regarding same (1.); final revisions to motion and correspondence with C. Martinez regarding same (.1)

28.00 Phone conference with W. Klein re settlement with R. Larsen

1,036.00 Review email from W. Romney regarding changes to settlement agreement, review redline of same and conference with C. Martinez regarding same (.4); conference with W. Klein regarding Larsen's revisions of settlement agreement, motion and confessions of judgment (.4); conference with W. Romney regarding same (.3); further revisions to settlement agreement based on negotiations with W. Romney, and conference with W. Klein regarding same (.4); further revisions to confessions of judgment and correspondence with W. Romney regarding same (.2); final revisions to settlement agreement and transmit to W. correspondence for signature (.3); draft W. Klein declaration in support of motion to

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, wiJJ appear on a later statement.





07/28/14 M. Hunt



08/08/14 M. Hunt







09/22/14 M. Hunt

C)» DORSEY

1.30

0.10

1.50

1.50

0.10

0.60

0.20

2.50

0.40

0.30

0.20

0.10


364.00

37.00

420.00

420.00

37.00

111.00

37.00

700.00

112.00

84.00

56.00

37.00

Apri127, 2015 Page 5

approve settlement and send to same (.8)

Revise and file motion to approve settlement agreement and motion to dismiss (.8); prepare for and attend status conference.

Conference with C. Martinez regarding proposed order, and correspondence with W. Romney regarding same (.1)

Prepare for hearing on motion for Court to approve settlement agreement.

Prepare for and attend hearing on motion to approve settlement agreement with R. Larsen

Conference with C. Martinez regarding settlement hearing (.1)

Receive and review documents production from defendants; receive and review settlement agreement with defendant's original signatures (.6)

Receive and review approved minute entry of hearing to resolve matter (.2)

Prepare for and attend hearing on motion to approve settlement agreement.

Outline steps necessary to provide sufficient information for court to approve settlement agreement.

Correspond with opposing counsel concerning steps necessary to settle claim.

Correspond with R. Larsen's counsel concerning additional information needed for settlement

Read and respond to correspondence regarding R. Larson investigation and settlement (.1)









10/23/14 A. Trujillo








C)» DORSEY

0.10

0.30

0.70

0.40

1.70

0.20

1.90

0.10

0.20

0.50

0.30

0.20


30.50

91.50

213.50

122.00

314.50

61.00

351.50

30.50

61.00

92.50

91.50

61.00


Correspond with opposing counsel concerning additional information needed before settlement can be approved

Phone conference with opposing counsel concerning facts necessary to supplement settlement agreement and motion to approve same

Prepare document requests to include with subpoenas to be served on Reed Larsen's tax attorneys

Draft document requests to be served along with subpoenas to R. Larsen and his entities' accountants.

Prepare and draft document Subpoenas to Halliday & Company and Millerberg & Myers; email to C. Martinez regarding the same

Revise subpoenas and notice of issuance of subpoena to R. Larsen's former accountants

Finalize Notice of Issuance of Subpoena and Subpoena to Produce Documents to Halliday & Company and Millerberg & Myers; coordinate with process server regarding the same

Correspond with accountants served with subpoena concerning scope of subpoena.

Phone conference with opposing counsel concerning possible settlement and joint response to Court's notice of pre-trial conference.

Review Affidavit of Service on Subpoenas and filed accordingly with the Court

Prepare stipulation re scheduling order and pretrial conference

Correspond with opposing counsel

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed. will appear on a later statement.



Klein & Associates, PLLC 'Client-Matter No.: 492728-00125 Invoice No.:******



11124/14 J. Koontz

Total Hours

C)» DORSEY

1.60

0.10

0.20

37.20


488.00

30.50

37.00

April27, 2015 Page?

concerning additional information needed to create settlement agreement

Prepare for and attend hearing on motion to amend scheduling order(1.2); Correspond with opposing counsel concerning settlement (.2); Correspond with defendant's accountants concerning their compliance with subpoena (.2)

Correspond with opposing counsel and court concerning scheduling order

Update electronic file

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed. will appear on a later statement.




C }»DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00110 La Von H. Livingston


INVOICE TOTAL



Apri127, 2015 Invoice No. ******

~

'>;~?Jk~~t' $18.50

$18.50

F6f\~our cwr'fi.:ihience; )!.ease !'(<a;it payment to the address below or we offer the option of remitting payment electronically by wire transfer. If y~itL!:ts:\f;~:'i"i!'<Y:.Q,uestiO:'i:;; \{f!:urding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Rece~i;,~ihie Dep'UH~i!~J1t al i-800-861-0760. Thank you.

Mailingti\!:tructions: Dorsey & Whitney LLP P.O. Bqx J<iSO



ABA Routing Number: 091000022 Account Number: 1602-30 I 0-8500 Swift Code: USBKUS441MT

01936


Service charges are based on rates. established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a lalcr slatement.









La Von H. Livingston



01/15/14 E. Stauffer 0.10

Total Hours 0.10

18.50 Receive and review notice of dismissal and update tracking matrix accordingly ( .1)












'.~ ..

. ': • .. ··:

:·: ..

INVOICE TOTAL


$3,264.00

ii'!';:).~our co~:;}~nience;'~'!,ease;:,·i:Atrl"payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifyi~<:: ho.'it\~li!i~·questidii'tr;;t\atding this infonnation, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei ,,;,ule Depdti!Pent ~CJ -800-861-0760. Thank you.

Mailing ii:wuctions: Dorsey & '.;<JIJitney LLP P.O. Box 1680



ABA Routing Number: 091000022 Account Number: 1602-3010-8500 Swift Code: USBKUS44JMT

01936


ScJYicc charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, Mil appear on a later statement

ALL INVOICES ARE DUE30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY


(}»DORSEY DORSEY & WHITNEY LLP






Lawrence Lloyd

April27, 2015 Invoice No.******


01/22/14

01/23/14

01/23/14

01/31/14

02/10/14

02110/14



E. Stauffer 0.20 37.00 Address search to locate possible updated addresses (.2)

E. Stauffer 0.20 37.00 Correspond with process server re status of service (.2)

C. Martinez 0.40 112.00 Revise motion for leave to serve through alternative means and declaration in support (.4)

E. Stauffer 1.00 185.00 Prepare motion for service by alternative means and supporting documents (.7); finalize and file, correspond with court clerk reproposed order, update matrix (.3)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have Oot been received or processed, will appear on a later statement.



~lein & Associates, PLLC Client-Matter No.: 492728-00104 Invoice No.: ******




03/07/14 M. Hunt









C)}:> DORSEY

0.20

0.50

1.30

0.30

0.70

0.30

0.70

0.40

0.10

0.30

0.20

0.20


37.00

140.00

364.00

111.00

196.00

55.50

196.00

74.00

28.00

55.50

37.00

37.00


Receive and review order denying motion to serve by alternative means and requesting additional information (.2)

Research requirements for newspaper to qualify as a newspaper of general circulation and draft amended motion for leave to serve through publication (.5)

Draft amended motion for leave to serve through alternative means (1.3)

Read and revise renewed motion for alternative service and correspondence with C. Martinez regarding same (.3)

Draft amended motion for leave to serve through alternative means, supporting declaration, and order (.7)

Add links to amended motion for alternative service and finalize for filing (.3)

Revise and file amended motion for leave to serve through alternative means and declaration in support of same (.7)

Finalize and file motion for leave to serve by alternative means with exhibits (.4)

Review order approving service via alternative means and correspond with E. Stauffer re same

Receive and review order granting motion for alternative service; email order, complaint and summons to defendant per order (.3)

Email order, complaint and summons per order granting alternative service, update matrix (.2)

Email defendant with copy of complaint, summons and order as per order regarding

Service charges arc based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.















C)» DORSEY

0.20

0.20

0.20

0.20

0.20

0.30

0.80

0.20

0.20

0.20

0.50


37.00

37.00

37.00

37.00

37.00

55.50

148.00

37.00

56.00

56.00

92.50


motion to serve by alternative means, update matrix (.2)

Email complaint and summons per order granting service by alternative means (.2)

Forward summons and complaint to defendant via email in accordance with order granting service by alternative means (.2)

Forward compliant and summons to defendant in compliance with order granting motion to serve by alternative means (.2)

Forward complaint and summons in compliance with order grating motion to serve by alternative means (.2)

Forward complaint and summons in compliance with order granting motion for alternative service (.2)

Prepare declaration of alternative service of summons and complaint on L. Lloyd (.3)

Prepare application for entry of default certificate and supporting documentation (.8)

Perform SCRA military search on defendant in preparation to file application for entry of default certificate (.2)

Research additional service attempts necessary before seeking default judgment and correspond with E. Stauffer re same.

Lloyd -Revise publication summons to be published in Salt Lake Tribune

Prepare summons for publication; contact Salt Lake Tribune and Deseret News to set up publication of summons in accordance with court order (.5)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not beC:n received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS ~'ROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY











Total Hours

C)» DORSEY

0.30

0.10

0.50

0.10

2.00

0.40

0.30

0.10

14.50


55.50

28.00

92.50

30.50

370.00

122.00

91.50

30.50

April27, 2015 Page4

Correspond with Deseret News and the Salt Lake Tribune newspapers re publication of summons as per court order (.3)

Revise notice of filing of affidavits of publication.

Receive and review proof of publication of summons in Salt Lake Tribune and Deseret News (.2); prepare notice of proof of publication and file same with the court (.3)

Revise application for default certificate

Prepare Application for Entry of Default, Declaration of C. Martinez, and Entry of Default Judgment as to Lawrence Lloyd (2.0)

Draft application for entry of default and default certificate

Draft response to order to show cause

Draft and file response to Court's order to show cause





C))) DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00007 Joe and Catherine Lovato


INVOICE TOTAL



··:::.:· :?)"}~%·-/


·~:'.> :;:t·: ·:;;:: .-,:·:-~- . Fo(~pur co~~·<lnience;;IJeas9p~;1'rir payment to the address below or we offer the option of remitting payment electronically. by wire transfer. IfyHt:i.h~,Y;.:.~{m~:'.questiofi;1;l#ftiltding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts ReceJ,:;;ule Dep~i\'!r>ent iri' 1-800-861-0760. Thank you.

. -.; ·'.

Mailing fs;~;truclions: Dorsey &Vlhitney LLP P.O. Box !680




01936


Service charges arc based on rates established by Dorsey & Whimey. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.



C lJ> DORSEY DORSEY & WHITNEY LLP






Joe and Catherine Lovato



01/27114

02/15/14

02/16/14

02/20/14

02/28/,14

03/02114

03/07/14

C. Martinez 0.30 84.00 Prepare attorney planning meeting report and scheduling order and correspond with opposing counsel re same (.3)

C. Martinez 0.20 56.00 Correspond with opposing counsel concerning scheduling order and attorney planning meeting report (.2)

C. Martinez 0.30 84.00 Draft Initial Disclosures and compile documents to produce with initial disclosures (.3)

C. Martinez 0.20 56.00 Correspond with opposing counsel re settlement and discovery plan (.2)

E. Stal)ffer 0.60 111.00 Prepare documents to serve with initial disclosures (.6)

C. Martinez 0.10 28.00 Revise initial disclosures and cover letter accompanying initial disclosures

E. Stauffer 0.20 37.00 Receive and review notice of initial pretrial conference and deadline to file attorneys

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and i.s available upon reques!. Disbursements and service charges. which either have not been received or processed, will appear on a laret statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXI'RESSLY AGREED RY DORSEY & WHITNEY


c~ DORSEY DORSEY & WHITNEY LLP

Kleii1 & Associates, PLLC April27, 2015 Client-Matter No.: 492728-00007 Page2 Invoice No.:******

planning meeting report (.2)

03/27114 C. Martinez 0.20 56.00 Phone conference with opposing counsel re possible settlement (.2)

04115114 C. Martinez 0.40 112.00 Revise attorney planning meeting report and scheduling order, correspond with opposing counsel regarding same and regarding settlement, and file report and scheduling order (.4)

04115/14 E. Stauffer 0.20 37.00 Finalize and file attorney planning report and proposed scheduling order, correspond with court clerk re same (.2)

04/16114 E. Stauffer 0.30 55.50 Receive and review scheduling order, update calendar matrix· (.3)

07/30/14 E. Stauffer 0.20 37.00 Review expert disclosures and organize files re same (.2)

08113/14 E. Stauffer 0.30 55.50 Prepare copy of supplemental disclosures and Jetter to opposing counsel forwarding same (.3)

09110114 E. Stauffer 0.20 37.00 Letter to counsel with copy of supplemental disclosures (.2)

09/22/14 C. Martinez 0.10 28.00 Correspond with court concerning setting a hearing on defendant's motion to dismiss.

09/22/14 C. Martinez 0.20 56.00 Draft meet and confer correspondence concerning defendant's failure to provide initial disclosures and failure to respond to discovery requests.

09/29/14 C. Martinez 0.10 28.00 Correspond with opposing counsel concerning deadline for response to discovery requests. ·

10/21/14 C. Martinez 0.20 61.00 Correspond with opposing counsel concerning facts of case and possible settlement.

11/05/14 C. Martinez 0.10 30.50 Correspond with opposing counsel concerning possible settlement

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received oi processed, will appear on a later statement.








Total Hours

C :1J> DORSEY

0.10

0.40

0.20

0.50

5.60


30.50

122.00

61.00

152.50

April27, 2015 Page3

Correspond with opposing counsel concerning settlement offer

Correspond with opposing counsel concerning possible settlement and problems with Lovato's hardship affidavit

Review new hardship affidavit provided by Defendants and correspond with W. Klein re same

Draft motion for summary judgment (.3); Correspond with opposing counsel concerning scheduling order deadlines (.2)

Service charges are based on ra1es established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 Di\ YS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY








Client-Matter No.: 492728-00106 RayMacCord


INVOICE TOTAL



-__.,, v.

<iWi.:;~,;;M(t:.: -:~ -:~: .


$148.00

... :,:·:;<:)g:;;,:,. ·,r~~~it/<;:: .. :;:·· F~t<',}'o:ur cqp.;f.:~iencif~)J.ease£f:i:~:'ll1 payment to the address below or we offer the option of remitting payment electronically by wire transfer. If y~·t\'i;h.\\\IW~~;·q~estidiiihhliit'ding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receljhfile Depiil'l~nent iitT800-861-0760. Thank you.

-:-~-:,_:.~-·

Mailing (i~::tructions: Dorsey &''.Vhitney LLP P.O. Box JuliO




01936


Service charges: are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.



C)}> DORSEY DORSEY & WHITNEY LLP


(Tax ldentification No. 41-0223337)




RayMacCord



01/02/14

01/03/14

01/07/14

E. Stauffer 0.20 37.00 Receive and review executed settlement agreement and release, update tracking matrix (.2)

E. Stauffer 0.40 74.00 Status check on case, correspond with court clerk re why initial pretrial and attorney report deadline has not been set (.2); correspond with opposing counsel re same (.2)

E. Stauffer 0.20 37.00 Status check on case re settlement and dismissal needs (.2)

Total Hours 0.80

Service charges are based on rates es1ablished by Dor3ey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed. ·will appe"ar on a later statemen1.









Client-Matter No.: 492728-00119 Joe Mackey


INVOICE TOTAL



:;i~(~q;. ~-=~\~\:.:·

"\t.'.~·;····.:_;_ ;·>:·,~;~;.·-__.,._,:;::::/:~·- .. :~:-.~};


036.50

$1,036.50

_;,_.~ .. ~~;>/. '' ·: :;:~.... . :(~(·. __ ;

F~{:t:~ur conl~~ien~~~)leaser.i)~J'\~'payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfy(r~:;,bv.~y:i{{ly;questio'i\(;;tilfiaiding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recel~';l,l1le Depiittit,ent at· i -800-861-0760. Thank you.

Mailing h;!;tructions: Dorsey &·:'vVhitney LLP P.O. Box 1680




01936


Service charges are based on rates established by Dorsey & Whimey. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.







Klein & Associates, PLLC I 0 Exchange Place, #502 Salt Lake City, UT 84111


Joe Mackey



01/07114

01/22/14

01/22/14

01/30/14

01/31/14

01/31/14

E. Stauffer 0.20 37.00 Receive and review notice of initial pretrial conference and deadline to submit attorney planning meeting reports, update calendar (.2)

C. Martinez 0.30 84.00 Draft attorney planning meeting report and proposed scheduling order (.3)

E. Stauffer 0.40 74.00 Correspond with opposing counsel re attorney planning meeting report and proposed scheduling order (.2); finalize and file attorney planning meeting report and correspond with court clerk re scheduling order (.2)

E. Stauffer 0.30". 55.50 Receive and review scheduling order, update calendar/tracking matrix (.3)

C. Martinez 0.40 112.00 Prepare and serve initial disclosures

E. Stauffer 0.60 111.00 Prepare documents to produce with initial disclosures (.6)

Service charges are based on rates established by Dorsey & Whitney. A scheduleofthose rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.















Total Hours

C j» DORSEY

0.30

0.20

0.30

0.20

0.20

0.20

0.30

0.20

0.10

0.30

0.20

4.70


55.50

37.00

84.00

37.00

37.00

37.00

55.50

37.00

30.50

91.50

61.00

April 22,2015 Page2

Prepare spreadsheet of Mackey case showing total transfers and false profit transfers and calculate false profit transfers occurring after 2008 for possible settlement negotiations with Toone (.3)



Receive and review motion to transfer case to Judge Jenkins (.2)





Correspond with J. Mackey re possible settlement (.1)

Draft correspondence to opposing counsel outlining settlement proposal

Correspond with W. Klein concerning possible settlement with J. Mackey (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear· on a later statement




( }» DORSEY DORSEY & WHITNEY LLP


(Tax Identification No. 4I-0223337)





·::_~~~-;.:; .,,

.. :_·.;_;;;;>~

. ,·"~n ···..-~:-.·~·~ .

. ~;Jir~;:~;;:;,':i?:;;, ··; ·· · · ·


Fdti~~{our C9..R~f!hience;:j~!.eas~,;-~{i;ilpayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify'Gil,haS~~l.J\W~\~~Jlestioh'(t~('t~rding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recef:):iltlle Depai·J.:n:!nt u( f-800-861-0760. Thank you.

-~ .. ' .. '.:: ~:.:. '~: '.

Mailing'l&tructions: Dorsey &'~;i(oi:Jitney LLP P.O. Box I680



ABA Routing Number: 091000022 Account Number: I602-30 I 0-8500 Swift Code: USBKUS44JMT

01936


SeJVice charges are based on rates eSI:ablished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.








Client~Matter No: 492728~00098

Joe Marlowe



01/22114

01/23/14

02/10/14

02/10/14

02/11/14




E. Stauffer 1.00 185.00 Prepare motion for service by alternative means and supporting documents (.7); finalize and file with the court, correspond with the clerk reproposed order, update matrix (.3)

E. Stauffer 0.20 37.00 Receive and review order granting motion to serve by alternative means, email de(endant as per order with copy of order, complaint and summons (.2)

Service charges arc based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a Jat(r statement.



Klein & Associates, PLLC Client-Matter No.: 492728-00098 Invoice No.:******












04116114 C. Martinez


(]»DORSEY

0.20

0.10

0.20

0.20

0.20

0.20

0.10

0.30

0.20

0.30

0.20

0.10

0.30


37.00

18.50

37.00

37.00

37.00

37.00

28.00

55.50

37.00

55.50

37.00

28.00

55.50

April27, 2015 Page2

Email defendant with summons, complaint and order granting service by alternative means as required (.2)

Email defendant with copy of summons, complaint and order in compliance with judge's order (.1)

Email to defendant in compliance with order granting motion to serve by alternative means (.2)

Email defendants at all email addresses pursuant to court order for service by alternative means (.2)

Email complaint and summons and order for alternative service to defendant at all emails as required by court order

Status report to C. Martinez re failed service via email and whether or not to move forward with service by publication (.2)

Revise document request attached to subpoena ( .1)

Prepare subpoe:t:la duces tecum for American Pension Services (.2)

Receive and review proof of service for subpoena American Pension Services (.2)

Receive and review documents produced by American Pension Services pursuant to subpoena (.3)

Status check on APS documents subpoena (.2)

Correspond with W. Klein regarding dismissal of J. Marlowe (.1)

Prepare notice of voluntary dismissal, update matrix (.3)

Service charges are based on rates es1ablished by Dorsey & Whitney. A schedule of those rates has been provided and is allailable upon request. Disbursements and service charges, which either have no1 been received or processed, will appear on a later statement.





Total Hours

C)}> DORSEY

0.20

4.90


37.00


Receive and review documents produced by APS pursuant to subpoena (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule. of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later staicment.









Client-Matter No.: 492728-00097


Lori McCool

-------------------------------------...,.:,~}1/:;:{c.t> ~~~ZfzWtwJ!' For Legal Services Rendered Through December 31,2014 _,, :i;~t

INVOICE TOTAL

Total For Current Legal Fees ,:$~,462.00 --:·.c·;:.!,~'


. ' -~

• ~-. <

For"your corr\•;(nience;;;geaser(;gr:it payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify~\ri· h(F/·'' :ii:y questicit\i;:.r<.~;;~rding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receh·;ible Depili:lji:ent l:ill-800-861-0760. Thank you .

.. Mailing ti:>:tructions: Dorsey &':\.Vhitney LLP P.O. Box loHO




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rales has been provided and is available upon requcSI. Disburscmen1s and service charges, which either have not been received or processed, will appear on a laler statement.



C)}:> DORSEY DORSEY & WHITNEY LLP

SALT LAKE CITY OFFICE 801-93 3-7360





Lori McCool



01/09114

01/16/14

01/16/14

04/23114

04/25114

05/21114

07/03/14

C. Martinez 0.10 28.00 Correspond with opposing counsel concerning production of documents

C. Martinez 0.50 140.00 Review documents from McCool investor file to be produced to opposing counsel

E. Stauffer 0.80 148.00 Prepare documents for production (.6); receive order from the court re short form discovery motion procedure, update matrix (.2)

C. Martinez 0.30 84.00 Draft first set of interrogatories, requests for production, and requests for admission (.3)

E. Stauffer 0.20 37.00 Review letter to counsel with discovery requests (.2)

C. Martinez 0.10 28.00 Correspond with opposing counsel concerning pending discovery requests

C. Martinez 0.20 56.00 Draft letter to opposing counsel with Receiver's report and list of materials relied upon (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.·


















(}»DORSEY

0.30

0.20

0.20

0.20

1.20

0.20

0.30

0.50

0.30

0.70

0.60

0.20

0.20

0.20


55.50

37.00

37.00

56.00

336.00

56.00

55.50

140.00

84.00

196.00

111.00

37.00

37.00

56.00

Apri127, 2015 Page2

Receive and review discovery responses from R. McCool and accompanying CD of documents (.3)

Review expert disclosures and organize files re same (.2)

Receive and review L. McCool's discovery requests (.2)

Correspond with opposing counsel and W. Klein re possible settlement

Draft responses to defendants' interrogatories and requests for admission



Draft responses to Defendant's first set of interrogatories, requests for production, and requests for admission

Draft responses and objections to interrogatories, requests for production, and requests for admission and correspond with W. Klein re same

Revise responses to discovery requests, locate documents to be produced along with responses, and prepare same for production.

Prepare and bates label documents to serve with plaintiffs responses to discovery requests (.6)

Receive and review documents produced by defendant (.2)

Letter to counsel with copy of supplemental disclosures (.2)

Correspond with J. Toleno concerning

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon reque5t. Disbursements and service charges. which either have not been received or process<:d, will appear on a later statement.



Klein & Associates, PLLC Cli-ent-Matter No.: 492728-00097 Invoice No.: ******






Total Hours

C 2)) DORSEY

0.10

1.80

1.10

1.10

1.30

12.90


30.50

549.00

335.50

335.50

396.50

possible settlement.

April27, 2015 Page3

Correspond with opposing counsel concerning outstanding discovery issues.


Draft motion for summary judgment and supporting declaration of W. Klein

Draft and edit memorandum in support of motion for summary judgment and declaration ofW. Klein in support of same

Revise and file motion for summary judgment and supporting declarations

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.






(Tax Identification No. 4 I -0223337)






F~¥'~(our c<m,yli.iience] {1lease ;-(,i.iiit payment to the address below or we offer the option of remitting payment electronically by wire transfer. If yi~{t~\\r;W'·'~•:·){Uestioi~:" t<ogiirding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei}i,i&le Depil!:l::_l,~nt at I -800-86 I -0760. Thank you.

Mailing lhS.!ructions: Dorsey &:Whitney LLP P.O. Box ftiiio




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and scrv::e charges, which either have not been received or processed, will appear on a later statement.









Analee McDonald

April22, 2015 Invoice No_ ******


01/09/14

01/16/14

01/16/14

02/25/14

02/27/14

04/24/14

E. Stauffer 0-20 37.00 Receive and review notice of reassignment of Judge Pead to Judge Stewart, update matrix and pleading templates (.2)

C. Martinez 0.30 84.00 McDonald - Correspond with opposing counsel concerning default of defendant and with W. Klein re information needed to move forward with default (.3)

E. Stauffer 0.60 111.00 Review files and begin preparing default papers and supporting documentation (.6)

C. Martinez 0.20 56.00 Correspond with opposing counsel concerning possible settlement (.2)

. c: Martinez 1.80 504.00 Phone conference with opposing counsel (.7); Draft correspondence outlining Receiver's position, legal support, and possible settlement ( 1.1)

C. Martinez 0_20 56.00 Correspond with opposing counsel and W. Klein regarding defendant's hardship affidavit (.2)

Service charges are based on rates eS1ablished by Do{sey /Y. Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which ei1her have not been received or proces.<M:d. will appear on a later statement












10/28/14 M. Hunt






C j» DORSEY

0.30

0.90

0.20

0.10

0.10

0.10

0.10

0.30

0.10

0.40

0.10

0.70

0.20

0.80


84.00

166.50

56.00

28.00

28.00

28.00

28.00

91.50

38.00

122.00

30.50

213.50

61.00

244.00


Draft first set of interrogatories, requests for production, and requests for admission (.3)

Prepare application for default certificate and accompanying documents and perform SCRA search for military duty (1.1)

Correspond with opposing counsel regarding possible settlement (.2)




Correspond with opposing counsel concerning possible settlement.

Correspond with opposing counsel concerning status of case (.1 ); Draft response to Court's order to show cause (.2).

Review OSC response and correspondence with C. Martinez regarding same (.1)

Correspond with opposing counsel concerning status of settlement discussions and facts underlying case

Correspond with opposing counsel concerning answer to complaint

Draft motion for summary judgment(.5); correspond with opposing counsel concerning scheduling order deadlines (.2)

Revise and file attorney planning meeting report and proposed scheduling order

Draft initial disclosures (.3); Compile documents to produce with initial disclosures (.2); Draft first set of discovery

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.




Total Hours


requests (.3)

7.70

Service charges are based on rates established by Dorsey&. Whitney. A schedule of1hos.e rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or proce.sscd, will appear on a later statement.

Apri122, 2015 Page3




C)}) DORSEY DORSEY & WHITNEY LLP






ii::~~~te~~~~n;;;ns-oo 101 ,.:tifl'~ _F_o_r_L_e_g_a_l_S_e_rv_I_. c-e-s _R_e_n_d_e_r-ed..,--T_h_r_o_u_g_h_D_e_ce_m_b_e_r_3_1_, _2_0_1_4-------,,~...,.;J<••':·: . ..,ti\¥~

INVOICE TOTAL . t};:l'iiii~'



Foi'your copi{(~bience;~i)!easy :•(:#;it payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify~i.d:t,<l"~~i;f\_v,9uestio~''•· r-~{;atding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei'i;tlJ!e Depcil·6.n~nt at i-800-861-0760. Thank you.

.. : ::..,··

Mailing·ll_;~tructions: Dorsey &'\Vhitney LLP P.O. Box io~O




01936


Service charges are based on rates established by Dorsey & Whi1ney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement



C }J> DORSEY DORSEY & WHITNEY LLP






Timothy D. McKenna



01/14/14

04/17114

04/23/14

04/23/14

04/24/14

06/20/14

E. Stauffer 0.30 55.50 Prepare letters to defendants re default, update tracking matrix (.3)

E. Stauffer 1.10 203.50 Prepare default certificate paperwork, perform bankruptcy search and military service members searches (1.1)

C. Martinez 0.20 56.00 Revise application for entry of default certificate, default certificate, and declaration in support of application for entry of default certificate (.2)

E. Stauffer 0.20 37.00 Perform SCRA search for military status and update application for default certificate documents (.2)

E. Stauffer 0.40 74.00 Finalize and file application for entry of default certificate, correspond with court clerk re same (.4)

C. Martinez 0.20 56.00 Revise default judgment and motion and declaration in support of same (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates hu been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.








Total Hours

C :l}) DORSEY

0.80

0.40

0.40

0.20

4.20


148.00

112.00

74.00

37.00

April27, 2015 Page2

Prepare application for entry of default judgment and supporting documentation (.8)

Revise motion for default judgment, proposed default judgment, and declaration in support of same (.4)

Finalize and file application for entry of default judgment and supporting documentation (.4)

Receive and review default judgment entered by the court, update tracking matrix (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges. which either have not been received or processed, will appear on a later statement.




( :1» DORSEY DORSEY & WHITNEY LLP

SALT LAKE CITY OFFICE 80 l-933-7360




Client-Matter No.: 492728-00109 Sherman Mehlhoff




. .}.. ::..;;-;_:-:;

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INVOICE TOTAL


$2,401.00

,;' ,;,~ ·2 ,,,,.,);:' . ;i;~1rj;N');;Y ·fP ..

Fo·(your cor;v,~hienced;_!,ease);,¥i'iffpayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifyt;(, h11.~iS t\li)'~questidi\N:l;Bjlii:fding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei\:~ible Dep·Jiii(:~nt iH-i-800-861-0760. Thank you.

Mailingl!;:;tructions: Dorsey & 'V/hitney LLP P.O. Box l&SO




01936





C )J} DORSEY DORSEY & WHITNEY LLP






Sherman Mehlhoff



01/17/14

01/22/14

01/23/14

01/23/14

01/31/14

01/31/14

M. Thomson 0.30 100.50 Analyze docket and pleadings in defendants' bankruptcy case, and draft email to C. Martinez regarding same and impact of case closure on pending lawsuit (.2); conference with C. Martinez regarding same (.1)



E. Stauffer 0.20 37.00 Correspond with process server re update on service and need to have completed by end of the month (.2)

E. Stauffer 0.20 37.00 Phone conference with process server re status of service (.2)

E. Stauffer 0.20 37.00 Correspond with process server re status of

Service charges are based on rates established by Dorsey & Whitney. A schedule of those nttes has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a litter statemenl



Klein {k Associates, PLLC Client-Matter No.: 492728-00109 Invoice No.:******












03/20114 M. Hunt

C ]»DORSEY

0.30

1.00

0.20

0.20

0.20

0.20

0.20

0.20

0.50

0.20

0.30

0.30


84.00

185.00

37.00

37.00

37.00

37.00

37.00

37.00

140.00

56.00

55.50

111.00

service (.2)

April27, 2015 Page2

Revise motion for leave to serve through alternative means and declaration in support (.3)

Prepare motion for service by alternative means and supporting documents (.7); finalize and file with the court, correspond with the clerk reproposed order, update matrix (.3)

Receive and review order granting motion to serve by alternative means; email defendants in accordance with the order (.2)



Send order, complaint and summons to all of defendant's emails pursuant to court order for alternative service (.2)

Email complaint, order and summons to defendant's in accordance with order granting motion for alternative service (.2)

Email defendant copies of complaint, summons and order pursuant to order to serve by alternative means (.2)

Draft Affidavit of Service via e-mail (.5)

Edit affidavit of service via e-mail (.2)

Prepare declaration of service via email in accordance with order for alternative service (.3)

Review and revise declaration for service by electronic means and email to E. Stauffer regarding same (.3)

Service charges are based on rates established by Dorsey & Whilney. A schedule of those rates has been provided and is available upon request. Dlsbursements and service charges. which either have not been received or processed. will appear on a later· statement



Klei~ & Associates, PLLC Client-Matter No.: 492728-00109 Invoice No.: ******











07/01/14 M. Hunt



Total Hours

C)» DORSEY

0.30

0.20

0.80

0.80

0.30

0.40

0.20

0.60

0.80

0.50

0.20

0.40

0.20

10.90


55.50

37.00

148.00

148.00

84.00

74.00

37.00

168.00

148.00

140.00

74.00

74.00

37.00

April27, 2015 Page3

Finalize and file declaration of service by alternative means and exhibits (.3)

Prepare default letter to defendants (.2)

Prepare default judgment papers (.8)

Prepare application for default certificate, declaration thereto and SCRA searches for military service (.8)

Revise application for entry of default certificate and declaration supporting same (.3)

Finalize and file application for entry of default certificate (.4)

Receive and review default certificate (.2)

Revise default judgment and motion and declaration in support of same (.6)

Prepare application for entry of default judgment and supporting documentation (.8)

Revise and file motion for default judgment and notice of voluntary dismissal of remaining claims (.5)

Review and revise proposed default judgment and conferences with C. Martinez regarding same (.2)

Finalize and file application for entry of default judgment and supporting documents (.4)

Receive and review notice of entry of default judgment, update matrix (.2)

Service charges are based on rates established by Dorsey & Whilney. A schedule oflhose rates has been provided and is av~ilable upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement




DORSEY DORSEY & WHITNEY LLP

Service charges are baS(;d on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbunemen1s and service charges. which either have not been received or processed. will appear on a later state"ment.

April27, 2015 Page4




C :J2> DORSEY DORSEY & WHITNEY LLP







~.: '.,.; ... . ;~-~~;.;: ..

. ;(;=,·· -~;:: .

INVOICE TOTAL


. ,;_ .,;:<.

For';:~·our c~r:i•<;hience;,~';Jeaseor;:ii}':lipayment to the address below or we offer the option of remitting payment electronically by wire transfer. lfytiJ,,nnv~:Hn~' questid;i;'k1';/ga~ding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Reed i';1,bfe Depiu I ~r,cnt at i -800-861-0760. Thank you.

Mailing li'';tructions: Dorsey &'\~'hitney LLP P.O. Box 16&0




01936

Please rna ke reference to the invoice number

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later slatement









Robert E. Meldrum



01/03/14

01/07/14

03/11/14

03/12/14

03/12/14

03/13/14


E. Stauffer 0.20 37.00 Status check on case re settlement and dismissal needs (.2)

C. Martinez 0.20 56.00 Correspond with W. Klein and R. Meldrum re final satisfaction of settlement and dismissal of lawsuit (.2)

C. Martinez 0.20 56.00 Revise and file notice of voluntary dismissal with prejudice and correspond with opposing counsel re same (.2)

E. Stauffer 0.20 37.00 Prepare notice of voluntary dismissal (.2)

E. Stauffer 0.20 37.00 Receive and review order dismissing case, update matrix (.2)

1.40

Service charges are basesl on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement.




Total Hours

C)» DORSEY DORSEY&. WHITNEY LLP

Service charges are based on rates established by Dorsey & Whilncy. A schedule oflhose rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed. will appear on a later statement.

April22, 2015 Page2









Client-Matter No.: 492728-00122 Memmott - Innovative Services


INVOICE TOTAL




$2,197.00

Foi~i,·our cod:;~ience~ i~1ease :.:'::::fiitpayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifytit1·.hw;.(!;)iii)' questidi:,,;. r~;gatding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei'hhre DepwJ'i':~).nt at I -800-861-0760. Thank you.

Mailing k;tructions: Dorsey &'.V/Ititney LLP P.O. Box 1680




01936


Service charges are based on rates c31ab1ished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.



C ]»DORSEY DORSEY & WHITNEY LLP




Klein & Associates; PLLC 10 Exchange Place, #502 Salt Lake City, UT 84111


Memmott- Innovative Services



01/23/14

01123114

01/30/14

03/03/14

03/04/14

03/04/14

C. Martinez 0.30 84.00 Innovative Services- Investigate current location and status of service of defendant and outline strategy for service of same (.3)

E. Stauffer 0.20 37.00 Prepare summons and complaint package for service on Innovative via certified mail (.2)

E. Stauffer 0.40 74.00 Phone call from M. Memo re service on innovative services, referred to NW. Klein directly (.1); receive and review answer of Innovative Services (.3)

C. Martinez 1.20 336.00 Innovative - Draft amended complaint to add additional parties

C. Martinez 0.30 84.00 Innovative - Revise amended complaint (.3)

M. Hunt 0.20 74.00 Conference with C. Martinez regarding complaint (.1); review draft amended complaint ( .1) (Innovative)

Service charges are based on rates esaablished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon requeM. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.

ALL INVOICES ARE DlJE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY




03/18/14 M. Hunt


03/31/14 M. Hunt



04/08/14 M. Hunt



Total Hours

C)» DORSEY

0.10

0.10

1.20

0.10

2.30

0.60

0.30

0.30

0.30

7.90


28.00

37.00

336.00

37.00

644.00

168.00

111.00

55.50

91.50

April27, 2015 Page2

Innovative - Correspond with opposing counsel concerning amended complaint (.1)

Correspondence with C. Martinez regarding status of amended complaint (.1)

Innovative Services - Revise amended complaint and correspond with opposing counsel re same (1.2)

Correspondence with C. Martinez regarding motion to amend (lnnovative)(.1)

Innovative - Draft motion for leave to file amended counterclaim and memorandum in support (2.3)

Innovative - Revise memorandum in support of motion for leave to amend (.6)

Review and revise motion to amend complaint and brief conference with C. Martinez regarding same (.3) (Innovative)

Finalize and file motion for leave to amend complaint and accompanying documents (.3)

Correspond with opposing counsel concerning failure to produce initial disclosures and concerning deposition of M. Memmott

Service charges are based on rates established by Dorsey & Whitney. A schedule of those ra1es has been provided and is available upon request. Disbursemems and service charges, which either have nor been received or processed, will appear on a later statement.





· .. SALT LAKE CITY OFFICE 80 I -933-7360




Client-Matter No.: 492728-00131 Robert Mitchell


INVOICE TOTAL




Fd~iyour cor,'i;;hience;;~;!ease.:::t;;:i~;i];payment to the address below or we offer the option of remitting payment electronically by wire transfer. If yr;khnv~ <Hi~' guestion';':;,~§iiiding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei;·i;blt: Depiii'!:r:";.nt al i-800-861-0760. Thank you.

Mailing Ji;;;tructions: Dorsey&: \J/I]itney LLP P.O. Box 1680




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which eilher have not been received or processed, will appear oo a later statement.



C lP DORSEY DORSEY & WHITNEY LLP






Robert Mitchell



01/08/14

01/09/14

01/14/14

01/15114

01/27/14

01/28114

C. Martinez 0.20 56.00 Brian Mitchell - Correspond with opposing counsel concerning possible settlement (.2)

C. Martinez 0.20 56.00 Mitchell - Correspond with opposing counsel concerning possible settlement

C. Martinez 0.30 84.00 Mitchell- Correspond with opposing counsel concerning settlement with R. Mitchell and defendants' purported expert

E. Stauffer 0.20 37.00 Receive and review notice of status and scheduling conference in the Mitchell case, update calendar/matrix (.2)

C. Martinez 0.40 112.00 Brian Mitchell - Prepare attorney planning meeting report and scheduling order and correspond with opposing counsel re same andre settlement (.4)

C. Martinez 0.10 28.00 Robert Mitchell - Revise and file attorney planning meeting report and scheduling order (.1)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service chi'lrges. which either have not been received or processed, will appear on a later statement.

ALL INYOICF.S ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WIIITNEY
















C~ DORSEY

0.30

0.40

0.60

0.20

0.20

0.30

0.30

0.30

0.10

0.20

0.10

1.00

0.20

5.60


55.50

112.00

111.00

56.00

37.00

84.00

84.00

55.50

30.50

61.00

30.50

305.00

61.00

April27, 2015 Page2

Receive and review scheduling order in the Mitchell case, update calendar/matrix (.3)

Robert Mitchell - Draft Initial Disclosures and compile documents to produce with initial disclosures (.4)

Prepare documents to serve with initial disclosures in Mitchell case (.6)

Robert Mitchell - Revise initial disclosures and cover letter accompanying initial disclosures

Receive and review Defendant Robert Mitchell's Initial Disclosures (.2)

Robert Mitchell - Draft first set of interrogatories, requests for production and requests for admission (.3)

Robert Mitchell- Review hardship affidavit and correspond with W. Klein and R. Mitchell regarding possible settlement (.3)


Mitchell: Correspond with opposing counsel concerning settlement (.1)

Robert Mitchell: Revise settlement agreement and correspond with opposing counsel re same (.2) ·

Correspond with opposing counsel concerning amended scheduling order



Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which cilher have not been received or processed. will appear on a later statement




Total Hours

C :1» DORSEY DORSEY & WHITNEY LLP

Service charges are based on rates established by Dorsey & Whitney. A schedule of those races has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.





( :1J> DORSEY DORSEY & WHITNEY LLP


(Tax Identification No.4 I -0223337)





INVOICE TOTAL


$7,848.00

Fo;::·:your con'•/c::.nience;.i~!east<{iY;r\itpayment to the address below or we offer the option of remitting payment electronically by wire transfer. If y(.(j~ hl)\<W~i-l·,y questior:i;,_.,<iJ~(iding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Rece(\~tl:ile Depiid~.<J~nt ai i -800-861-0760. Thank you.

·::-. . ....

Mailing· h{t:tructions: Dorsey &f~:\:hitney LLP P.O. Box 1080


Minneapolis, MN 55480-1680 Minneapolis, MN 554.02


01936

Please make reference to the Invoice number

Service charges are based on rates established by DorS<:y & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.









Sarah Mortensen



01/07/14

01/08/14

01/10114

01/13/14

01/14/14

01/16/14

C. Martinez 0.10 28.00 Correspond with opposing counsel concerning attorney's planning meeting report (.1)

C. Martinez 0.60 168.00 Phone conference with opposing counsel concerning scheduling order and prepare and file attorney planning meeting report and scheduling order (.6)

C. Martinez 1.00 280.00 Prepare for and attend Initial Pre-Trial Conference with J. Jenkins

C. Martinez 0.90 252.00 Draft scheduling order and correspond with opposing counsel re same (.3); draft e-mail

. to opposing counsel outlining legal support for claims and asking for information necessary to facilitate settlement (.6)

C. Martinez 0.10 28.00 Correspond with opposing counsel concerning possible settlement

C. Martinez 0.60 168.00 Prepare initial disclosures and compile documents to produce with initial

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have nol been received or processed, will appear on a later statement.







02/04/14 S. Goldberg


02117/14 S. Goldberg








03/20/14 M. Hunt



03/21/14 M. Hunt

C :1}) DORSEY

0.60

0.20

1.10

0.90

4.30

3.00

2.20

1.10

0.60

0.30

0.20

0.40

2.20

1.50

0.60

0.20

1.30


111.00

37.00

308.00

198.00

946.00

660.00

484.00

308.00

168.00

84.00

56.00

112.00

616.00

555.00

168.00

56.00

481.00

disclosures

April27, 2015 Page2

Prepare documents to produce with initial disclosures (.6)

Receive and review scheduling order, update calendars/tracking matrix (.2)

Draft fact section of motion for summary judgment and correspond with S. Goldberg re same (1.1)

Review and analyze pleadings in preparation of drafting motion for summary judgment; conference with C. Martinez re same

Draft motion for summary judgment

Draft motion for summary judgment

Draft motion for summary judgment and declaration ofW. Klein

Revise motion for summary judgment (1.1)

Revise memorandum in support of motion for summary judgment (.6)

Draft first set of discovery requests

Prepare first set of discovery requests (.2)

Draft first set of interrogatories, requests for production, and requests for admission (.4)

Draft motion for summary judgment on validity of ABI (2.2)

Review and revise motion for summary judgment (1.5)

Draft declaration in support of motion for summary judgment (.6)

Correspond with opposing counsel concerning settlement offer (.2)

Review and revise declaration in support of

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon rt:quest. Disbursements and service charges. which either have not been received or processed, will appear on a later statement





03/25/14 M. Hunt










C)}> DORSEY

0.20

0.70

1.50

0.40

0.50

0.20

0.20

0.10

0.10

0.20

0.20

DORSEY&. WHITNEY LLP

56.00

259.00

420.00

112.00

140.00

56.00

56.00

28.00

28.00

56.00

56.00


summary judgment and finalize all papers to send toW. Klein (1.3)

Correspond with opposing counsel concerning settlement (.2)

Review W. Klein's comments on motion for summary judgment, revise documents regarding same, email to W. Klein with revised documents and email to C. Martinez regarding compiling exhibits and filing same (.5); further correspondence regarding motion for summary judgment and instructions to staff on same (.1 ); conference with C. Martinez regarding settlement offer and course of action on ABI motion for summary judgment (.1)

Revise memorandum in support of motion for summary judgment and supporting declaration (1.5)

Draft first set of discovery requests (.4)

Draft discovery responses and correspond with opposing counsel regarding same and regarding settlement (.5)

Correspond with opposing counsel concerning possible settlement (.2)

Correspond with opposing counsel and W. Klein regarding settlement (.2)



Prepare stipulated motion for order of dismissal and correspond with opposing counsel and the Court regarding same (.2)

Correspond with opposing counsel concerning changes to Stipulated Motion to


ALL INVOICES ARE DUE30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WIIITNEY






07116114 E. Stauffer




Total Hours

C 2» DORSEY

0.40

0.10

0.30

0.20

0.20

0.10

0.10

29.70


74.00

28.00

55.50

37.00

56.00

28.00

30.50

April27, 2015 Page4

Dismiss, given judge's request to include additional information in stipulation

Prepare stipulation and proposed order of dismissal ( .4)

Revise and file stipulated motion to dismiss

Finalize and prepare to file stipulated motion to dismiss, correspond with court clerk re same (.3)

Receive and review order of dismissal, update tracking matrix (.2)

Draft meet and confer correspondence concerning defendant's failure to provide initial disclosures and failure to respond to discovery requests


Senor Mortenson - Correspond with opposing counsel concerning final settlement (.1)

Service charges are based on rates eslablished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed. will appear on a later statement.











f:::.·:~~~':-. . :);;F· ···=~?·

···.·.'"···

INVOICE TOTAL


. ~- _;;:.:.o:--

Fd;?:your c<;m~~i~hienc~i,;i}Jease-n:[:~~iipayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifyi.'i!hQ.i\V~\i}:(~;";,questior.~~!~ga'fding this information, please contact the lawyer you are working with on this project or Dorsey's.Accounts Recd/Ubf~ Depilfh:.~rt iii 'f-800-861-0760. Thank you.

Mailing'!~V~Jructions: Dorsey &','.\'!Jitney LLP P.O. Box lol!O




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rate.s has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later starement.









Eric Myer



01/21114

02/04/14

02/15114

02/20/14

02/27114

03/03/14

03/05/14

C. Martinez 0.20 56.00 Correspond with opposing counsel and W. Klein resettlement (.2)

E. Stauffer 0.30 55.50 Prepare spreadsheet of case showing total transfers and false profit transfers and calculate false profit transfers occurring after 2008 for possible settlement negotiations with Toone (.3)

C. Martinez 0.20 56.00 Correspond with W. Klein re possible settlement (.2)

C. Martinez 0.20 56.00 Correspond with W. Klein resettlement (.2)

C. Martinez 0.20 56.00 Analyze settlement proposal and correspond with W. Klein concerning possible settlement (.2)

C. Martinez 0.30 84.00 Review settlement offer and correspond with Receiver concerning strategy in response to same

C. Martinez 0.60 168.00 Phone conference to discuss settlement and











04/09/14 M. Hunt




05/19/14. C. Martinez




C 2)) DORSEY

0.10

0.60

0.20

0.30

0.60

0.90

0.10

0.20

0.10

0.20

0.10

0.40

0.20

0.20


28.00

168.00

37.00

84.00

168.00

252.00

37.00

56.00

28.00

37.00

28.00

74.00

56.00

37.00

April27, 2015 Page2

procedure for this and other cases (.6)

Review settlement correspondence from opposing counsel and correspond with W. Kleinre same (.1)

Phone conference with B. Toone and W. Klein re possible settlement and draft counteroffer to B. Toone (.6)

Correspond with opposing counsel re answer deadline and status of settlement agreement (.2)


Multiple settlement communications with W. Klein and B. Toone re possible settlement of lawsuit (.6)

Multiple correspondence with B. Toone and W. Klein negotiating settlement (.9)

Read Toone emails and proposed response and correspondence with C. Martinez regarding same ( .1)

Review settlement agreement and correspond with opposing counsel regarding same (.2)

Correspond with B. Toone regarding status of settlement ( .1)

Receive and review order re motion for reassignment to Judge Jenkins (.2)

CmTespond with B. Toone and W. Klein regarding settlement (.1)

Prepare stipulation and proposed order of dismissal (.4)

Revise stipulated motion and order of dismissal

Change stipulation for order of dismissal to

Service charges art based on rates established by Dorsey & Whitney. A schedule of those rates JJas been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.

ALL INVOICES ARR DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY




Total Hours

C)» DORSEY

0.20

6.40


61.00


notice ofvoluntary dismissal (.2)


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed. will appear on a later statement




C :J)> DORSEY DORSEY & WHITNEY LLP

., SALT LAKE CITY OFFICE

801-933-7360




Client-Matter No.: 492728-00085 Edda Nelson


INVOICE TOTAL



.Af:)f'· -·•:::;~:~

<~I{-~~>-·-

:·.~~:,_ ~-:;:~?01~;, /;\~·::.> ·-;,;~·::. <·:-=~~i~~:-

.·-<L.s = - ... ~~J ·--=-~_-,.~~-----' ·.;..:


$12,562.00

~;~-, t

F~t\•our cor;>t~hienc~~h!eas~g~i)~f~ayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifydt:i·hnYd!iB·Y·O\lestidi\;t'fi;i!furding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei,;ilble Depadwent !10-800-861-0760. Thank you.

s:-._ ·.·

Mailing k;tructions: Dorsey &;N~itney LLP P.O. Box 1'680



ABA Routing Number: 091000022 Account Number: 1602-30 I 0-8500 Swift Code: USBKUS44JMT

01936


Service charges are based on rates estabJished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have no1 been received or processed, will appear on a later statement.



C :1J> DORSEY DORSEY & WHITNEY LLP






EddaNelson



06/30/14

07/01114

07/03/14

07/29114

07/30/14

07/30/14

08/05/14

C. Martinez 0.40 112.00 Revise and serve first set of discovery requests ( .4)

E. Stauffer 0.20 37.00 Receive and review discovery responses (.2)

C. Martinez 0.20 56.00 Draft letter to .opposing counsel with Receiver's report and list of materials relied upon (.2)

C. Martinez 1.90 532.00 Draft responses to first set of discovery requests.

C. Martinez 1.20 336.00 Draft responses to E. Nelson's first set of interrogatories, requests for admission, and requests for production of documents.

E. Stauffer 0.20 37.00 Review expert disclosures and organize files re same (.2)

C. Martinez 0.60 168.00 Revise responses to plaintiff's first set of interrogatories, requests for production of documents, and requests for admission;


















C~ DORSEY

0.60

0.20

0.40

0.30

0.20

0.60

1.50

1.50

0.10

0.40

3.50

0.50

5.50


111.00

56.00

74.00

55.50

37.00

183.00

457.50

457.50

30.50

122.00

1,067.50

92.50

1,677.50

April27, 2015 Page2

Review documents produced in response.

Prepare production of documents for initial disclosures (.6)

Edda Nelson- Revise responses to discovery requests and correspond with opposing counsel re same

Receive and review letter and documents production from defendants (.4)




Draft statement of undisputed facts for memorandum in support of motion for summary judgment


Phone call to opposing counsel concerning possible settlement of claims

Correspond with opposing counsel concerning settlement possibility and deadlines for case (.2); draft stipulated motion and order to amend scheduling order (.2)

Praft memorandum in support of motion for summary judgment on fraudulent transfer and unjust enrichment claims (3.5)

File and email Motion to Amend Scheduling Order and Proposed Order with Court

Draft declaration of R. Hoffman in support

Service charges arc based on rates established by Dorsey & Whitney. A schedule of those ra!es has been provided and is available upon requesl. Disbursements and service charges, which either have not been received or processed, wilt appear on a later statement.











Total Hours

C)» DORSEY

3.80

6.90

1.70

1.10

1.70

6.00

1.30

42.50


1,159.00

2,104.50

518.50

335.50

518.50

1,830.00

396.50


of motion for summary judgment (1.3); Draft declaration ofW. Klein in support of motion for summary judgment (3.1); Draft legal argument section of motion for summary judgment ( 1.2)

Draft declarations of. R. Hoffman and W. Klein in support of motion for summary judgment (3.8)

Draft declarations of W. Klein and R. Hoffman and legal argument in support of motion for summary judgment ( 6.9)

Draft argument section of memorandum in support of motion for summary judgment

Draft argument section of motion for summary judgment

Draft W. Klein declaration in support of motion for summary judgment and revise factual statement in motion for summary judgment

Draft and edit motion for summary judgment and declaration ofW. Klein in support of same

Revise and file motion for summary judgment and supporting declarations

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates.has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.




C :1)> DORSEY DORSEY & WHITNEY LLP







INVOICE TOTAL


$2,491.50

Fo(t,our con;,;·(~hience,:l~lease r<;Itii{payment to the address below or we offer the option of remitting payment electronically by wire transfer. If y~iiLh!.I.V<~:'\1\v,,questiOte,:,t<)gurding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recel~:(tble DepiJ·{nr:pt iif-1~800-861-0760. Thank you.

Mailing lt':,:tructions: Dorsey &'\Vf!itney LLP P.O. Box i~8o




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. [)jsbursements and service charges, which either have nol been received or processed, will appear on a later statement.




SALT LAKE CITY OFFICE 801-93 3-7360





New Millenium Operating Co.



01/23/14

01/23114

01/29/14

01/30/14

01/30/14

01/31/14

C. Martinez 0.20 56.00 Rutledge- Investigate current location and status of service of defendant and outline strategy for service of same (.2)

E. Stauffer 0.20 37.00 Receive and review order to show cause on the Rutledge case, update calendar (.2)

E. Stauffer 0.30 55.50 Prepared summary of attempts to serve T. Rutledge ( .3)

C. Martinez 1.70 476.00 Rutledge - Draft ex parte motion for leave to serve by alternative means, declaration in support, and proposed order (1.7)

E. Stauffer 0.20 37.00 Prepare summons for new address ofNew Millennium and correspond with process server re service of same (.2)

C. Martinez 1.10 308.00 Rutledge - Draft declaration in support of motion for leave to serve through alternative means and proposed order granting same ( 1.1)

Service charges are based on rates established by 00f3ey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLF..SS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY



02/03/14 M. Hunt












C)» DORSEY

0.30

0.40

0.20

0.30

0.20

0.20

0.10

0.20

0.10

0.30

0.20

0.20


111.00

112.00

37.00

55.50

37.00

37.00

18.50

37.00

28.00

84.00

37.00

37.00

April27, 2015 Page2

Conference with C. Martinez regarding motion to serve by alternative means and general strategy issues in case (.2); review and authorize motion to serve by alternative means (.1)

Rutledge - Revise motion for leave to serve by alternative means and response to order to show cause (.4)

Receive and review proof of service of New Millennium, update tracking matrix and file with the court (.2)

Receive and review order granting motion to serve Rut ledge by alternative means (.2); e-mail summons, complaint and order to CT. Rutledge (.1)

Email T. Rutledge in accordance with Judge's order re alternative service (.2)

Email to T. Rutledge with summons, complaint and order granting service by alternative means as required (.2)

Email defendant T. Rutledge with copy of summons, complaint and order in compliance with judge's order (.1)

Email toT. Rutledge in compliance with order granting motion to serve by alternative means (.2)

Correspond with W. Klein concerning dismissal ofT. Rutledge (.1)

Rutledge- Correspond with B. Toone and W. Klein re dismissal ofT. Rutledge and revise and file notice of voluntary dismissal ofT. Rutledge (.3)

Prepare notice of voluntary dismissal ofT. Rutledge (.2)

Receive and review answer ofNew













Total Hours

C)?:> DORSEY

0.30

0.30

0.20

0.20

0.80

0.50

0.20

1.00

9.90


84.00

84.00

37.00

56.00

148.00

140.00

37.00

305.00

Millennium (.2)

April27, 2015 Page3

Rutledge - Draft first set of interrogatories, requests for production and requests for admission (.3)

Rutledge - Draft first set of interrogatories, requests for production and requests for admission (.3)

Receive and review notice of initial pretrial conference and deadline to submit attorney planning meeting report in Rutledge matter (.2)

Rutledge - Revise attorney planning meeting report and proposed scheduling order (.2)

Prepare attorneys' planning meeting report and proposed scheduling order in New Millennium matter, correspond with opposing counsel re same (.8)

Rutledge: Draft letter to defendant disclosing documents that form the factual basis of the Receiver's claim and disclosing receiver's report of insolvency (.1 ); draft and serve initial disclosures (.4)

Review expert disclosure for New Millennium case and organize files re same (.2)


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon requcS1. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.









Client-Matter No.: 492728-00116 Ashley Nielsen

June 18, 2015 Invoice No. ******

---------------------------------···········--··-·--··-··-············---

For Legal Services Rendered Through May 31,2015

INVOICE TOTAL

Total For Current Legal Fees $678.00


For your convenience, please remit payment to the address below or we offer the option of remitting payment electronically by wire transfer. If you have any questions regarding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receivable Department at 1-800-861-0760. Thank you.

Mailing Instructions: Dorsey & Whitney LLP P.O. Box 1680




01936











Ashley Nielsen

For Legal Services Rendered Through May 31,2015

01114114 E. Stauffer 0.30 55.50

01116/14 C. Martinez 0.20 56.00

01121114 E. Stauffer 0.20 37.00

01124/14 C. Martinez 0.20 56.00

01127114 E. Stauffer 0.30 55.50

02/07/14 C. Martinez 0.20 56.00

04/16/14 C. Martinez 0.20 56.00

June 18, 2015 Invoice No. ******

Prepare letter to defendant re default, update tracking matrix (.3)

Revise application for default certificate (.2)

Phone conference with A. Neilsen re default letter and response to complaint (.2)

Correspond with W. Klein re possible settlement with A. Nielsen and prior correspondence with her re same (.2)

Receive and review motion for extension of time to file answer; receive answer and notice of ADR and consent to magistrate (.3)

Correspond with W. Klein re settlement negotiations with A. Nielsen (.2)

Revise stipulated motion and order for dismissal (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement








12/11114 A. Trujillo

Total Hours

( )» DORSEY

0.30

0.20

0.10

0.60

0.20

3.00


55.50

37.00

30.50

183.00

0.00

June 18, 2015 Page2

Prepare stipulation and order for dismissal, update matrix (.3)

Correspond with A. Nielsen re stipulated motion to dismiss (.2)

Draft letter to defendant concerning her failure to abide by requirements of settlement agreement (.1)

Draft and send letter to A. Nielsen demanding release of ABI in light of requirement in settlement agreement that she release the same (.6)

Scan and mail R. Wayne Klein the signed settlement agreement (.2)

Total for Legal Fees $678.00

Total This Invoice $678.00





C :J}:> DORSEY DORSEY & WHITNEY LLP


(Tax Identification No.4 I -0223337)





.. >;::'JH"!~;J' :g:~r·

:.z<g\ -.;r:.


$1,260.50

::-~ ', .-··:~·.,".'; \:~-~·;.,,·/~~-:~/"~-~~/;:-··

Fl'r~·~ur cqni·~~ien!f?\J:eas~J74.d,;\;~pa;ment to the address below or we offer the option of remitting payment electronically by wire transfer.· Ify()~:,hn¥~~1(ilY:questidif~h¥(Eiihling this information, please contact the lawyer you are working with on this project or Dorsey's Accounts . Recei',•\1JJie Depli:flf!:rnt M i -800-861-0760. Thank you.

. .< .. •·.

MailingJJ~;tructions: Dorsey &:~'lhitney LLP P.O. Box 1680




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule oflhose rates has been provided and is availablt: upon request Disbursemen1s and service charges, which either have not been received or processed, will appear on a later statement.



( :J» DORSEY DORSEY & WHITNEY LLP






Christy Palmer



01/17/14

01/21/14

01/28114

02/04/14

02/26/14

03/21114

E. Stauffer 0.20 37.00 Receive and review answer to complaint, update tracking matrix (.2)

E. Stauffer 0.30 55.50 Receive and review form consent to assign to magistrate judgment (.1); receive order from the court re short form discovery motion procedure (.1 ); update tracking matrix (.1)

C. Martinez 0.10 28.00 Revise and file attorney planning meeting report and scheduling order ( .1)


C. Martinez 0.40 112.00 Draft attorney planning meeting report and proposed scheduling order

C. Martinez 1.30 364.00 Draft first set of interrogatories, requests for production, and requests for admission (1.3)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon requelt. Disbursements and service charges, which either have nOl been received or processed, will appear on a later statement.















Total Hours

C }J> DORSEY

0.20

0.20

0.20

0.20

0.40

0.30

0.10

0.20

0.30

0.20

0.60

5.50


37.00

37.00

37.00

37.00

74.00

55.50

18.50

37.00

55.50

37.00

183.00

April27, 2015 o o o o o.JI o o o o o o ~12

Review plaintiff's 1st set of discovery requests and incorporate into electronic filing system (.2)

Receive and review motion for transfer of case to Judge Jenkins (.2)

Receive and review notice of initial pretrial conference and deadline to file attorney planning meeting report (.2)


Prepare attorney planning meeting report and proposed scheduling order; correspond with opposing counsel re same (.4)

Receive and review scheduling order, update calendar/matrix (.3)

Receive and review notice of vacating initial pretrial conference (.1)




Draft initial disclosures (.4); Correspond with W. Klein replan for deposing C. Palmer (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is ~tvailable upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.




C J2> DORSEY DORSEY & WHITNEY LLP

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later staiement.

April27, 2015 Page3








Klein & Associates, PLLC 10 Exchange Place, #502 Salt Lake City. UT 84111

Client-Matter No.: 492728-00017 Cory Palmer


INVOICE TOTAL




$784.50

Foi~)·our cor;}';Jilien~J.;liAeast:xifi~kpayment to the address below or we offer the option of remitting payment electronically by wire transfer. If y6t: h)lv.~:!i(i)' questioi);i:d'if«fding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei,·i[ble Depai'!ir:ent aCT~800-86I-0760. Thank you . . -~ ...

:.,

Mailing !ii0,tructions: Dorsey &\:.'!Jitney LLP P.O. Box 1680




01936


SeJVice charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed, will appear on a later statement.



( 2J> DORSEY DORSEY & WHITNEY LLP






Cory Palmer



02/04/14

03/20/14

03/21/14

05/05/14

05/16/14

07/08114


C. Martinez 0.40 112.00 Draft first set of interrogatories, requests for production and requests for admission (.4)

E. Stauffer 0.20 37.00 Review plaintiffs 1st set of discovery requests and incorporate into electronic filing system (.2)



C. Martinez 0.10 28.00 Correspond with opposing counsel concerning possible settlement.

SCtVice charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will cippear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DOUSEY & WHITNEY














Total Hours

····.; -?:

C)» DORSEY

0.20

0.20

0.30

0.10

0.10

0.20

0.30

0.10

0.20

0.10

0.10

3.30


56.00

37.00

55.50

28.00

28.00

37.00

84.00

30.50

61.00

30.50

30.50

April 27, 2015 Page2

Correspond with W. Klein and B. Toone re possible settlement



Correspond with opposing counsel re possible settlement.

Correspond with W. Klein re possible settlement.


Correspond with W. Klein and opposing counsel concerning possible settlement.

Correspond with opposing counsel and W. Klein re settlement

Correspond with opposing counsel and W. Klein re Cory Palmer settlement.

Correspond with opposing counsel re possible settlement

Correspond with W. Klein re C. Palmer's payments required under the settlement agreement

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been pr.ovidcd and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.






{Tax Identification No. 41-0223337)



Client-Matter No.: 492728-00021 Dan Palmer


INVOICE TOTAL



. ~.'·


F~f-tour cqr,~;;nience,i~.\ease :\:~i}tpayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify(H,: h<l~;(i!hy questio)·,.;: !<~;;urding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei',)Iile Dep<ii i;i:ent a(I-800-861-0760. Thank you.

Mailing Ji;';tructions: Dorsey & \:lfl}itney LLP P.O. Box 1680



ABA Routing Number: 09!000022 Account Number: 1602-3010-8500 Swift Code: USBKUS44IMT

01936



ALL INVdiCESARE DUE30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED DY DORSEY & WHITNEY




(Tax Identification No. 41-022333 7)




Dan Palmer



02/04/14

03/21114

04/08/14

04/08/14

05/05/14

05115114


E. Stauffer 0.20 37.00 Review plaintiffs 1st set of discovery requests and incorporate into electronic filing system (.2)

C. Martinez 0.30 84.00 Correspond with P. Hunt and W. Klein concerning B. Toone's representation of D. Palmer (.3)

M. Hunt 0.20 74.00 Read correspondence from B. Toone (.1); correspondence with W. Klein and conference with C. Martinez regarding same (.1)


C. Martinez 0.20 56.00 Correspond with opposing counsel













Total Hours

C)}) DORSEY

0.20

0.10

0.10

0.20

0.40

0.10

0.40

0.20

3.10


37.00

28.00

28.00

37.00

74.00

28.00

74.00

37.00

April27, 2015 Page2

concerning possible settlement (.2)


Correspond with opposing counsel regarding settlement (.1)


Receive and review settlement agreement of D. Palmer, correspond with B. Toone re same (.2)



Edit stipulation and motion for order of dismissal, forward to B. Toone for approval; finalize and file with the court (.4)

Receive and review order of dismissal, update matrix (.2)

Service charges are based on rates established by Dorsey & Whilney. A schedule of those rates has been provK:Ied and i.s available . upon request Disbursements and service charges, which either have not been received or processed. will appear on a later statement.






(fax Identification No. 41-0223337)



Client-Matter No.: 492728-00016 Debra Palmer


INVOICE TOTAL



.·.,_,.


$1,234.50

Fo(·,<iour con·'\~nienc~ri,!ease r,<Mi-'payment to the address below or we offer the option of remitting payment electronically by wire transfer. If yoi,; hTti.·. m;y questioi;fi ,,,;tiarding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recel;;,,{,le Depar!:r:ent a"Ci~S00-861-0760. Thank you.

Mailing li:;;tructions: Dorsey & \'ihitney LLP P.O. Box 1680




01936


Service charges are based on races established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.









Debra Palmer



01/15/14

01/27/14

01/28/14

01/30/14

01/31/14

02/04/14

E. Stauffer 0.20 37.00 Receive and review notice of status and scheduling conference, update calendar/matrix (.2)


E. Stauffer 0.30 55.50 Finalize and file attorney planning meeting report and proposed scheduling order (.2); correspond with court clerk re same (.1)


E. Stauffer 0.20 37.00 Receive and review Amended schequling order, update calendar/matrix (.2)





















C)» DORSEY

0.50

0.20

0.60

0.20

0.20

0.40

0.20

0.20

0.20

0.10

0.10

0.20

0.40

0.10

0.40


140.00

56.00

111.00

37.00

37.00

112.00

37.00

37.00

37.00

28.00

28.00

37.00

74.00

28.00

74.00

April27, 2015 Page2

Draft Initial Disclosures and compile documents to produce with initial disclosures (.5)

Revise and serve initial disclosures

Prepare documents to serve with initial disclosures (.6)

Finalize initial disclosures and correspond with B. Toone re same (.2)

Receive and review Defendant's Initial Disclosures (.2)





Correspond with opposing counsel regarding settlement ( .1)


Receive and review signed agreement of D. Palmer (.2)



Edit stipulation and motion for order of dismissal, forward to B. Toone for approval; finalize and file (.4)

Service charges are based on rates established by Dorsey&. Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.




C])) DORSEY DORSEY & WHITNEY LLP

April27, 2015 Page3

07/17/14 E. Stauffer 0.20 37.00 Receive and review order of dismissal (.2)

Total Hours 5.80

Service charges are based on rates established by Dorsey & Whitney. A schedule oft hose rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement




( :J» DORSEY DORSEY & WHITNEY LLP







•·•,"';

:·~t:">

-:.:::~:· ' -· ::::-: ;

INVOICE TOTAL


Fo(':our coro· ... ;;nienci;\:!east:~''"~~lf'payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfy<i,_: h!l'>'(itn;· questio.ti~;rc@ihling this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receiv;1bie Depuni<:ent titl~800-861-0760. Thank you.

Mailing ·;i;:;tructions: Dorsey & \iiiJitney LLP P.O. Box 1680




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule Of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement.



C 2J> DORSEY DORSEY & WHITNEY LLP






Kenneth Palmer



01/30/14

01/31/14

02/25/14

02/27/14

03/03114

04/23114

04/24/14

05/08/14

E. Stauffer 0.20 37.00 Receive and review letter from M. Olsen re hardship of Mr. Palmer (.2)

C. Martinez 0.30 84.00 Draft letter response to defendant's settlement offer

C. Martinez 0.20 56.00 Phone conference with opposing counsel concerning possible settlement (.2)

C. Martinez 0.20 56.00 Analyze settlement offer and correspond with W. Klein re same (.2)

C. Martinez 0.20 56.00 Draft letter responding to K. Palmer settlement demand



C. Martinez 0.10 28.00 Conference with court concerning status of case (.1)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which ei1her have not been received or processed, will appear on a later statement.








Total Hours

C)» DORSEY

0.20

0.10

0.30

0.20

2.20


37.00

28.00

55.50

37.00

April27, 2015 Page2





Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Oisburse.ments and service charges, which either have not been received or processed, will appear on a later statement

ALL INVOICES ARE DUE30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED DY DORSEY & WHITNEY








Client-Matter No.: 492728-00010 Mont and Shauna Palmer


INVOICE TOTAL



.·:.;Y:~~~-· .:~ . .. . ~:-~=!:··" ..... •. :.(>~


$556.50

F~~-your C<?r;.%r.~hienc~; ;~!easer¢t\lftpayment to the address below or we offer the option of remitting payment electronically by wire transfer. If yh11: !),a_giHbx questio)>;),; r<i'iiltding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei1;;6le Depdi·i.=nr-,nt ~f i -800-861-0760. Thank you. ·

Mailing h;f:!ructions: Dorsey &.\Vhitney LLP P.O. Box itil!o




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon rcquc~t. Disbursements and service charges. which either have not been received or processed. will appear on a later statement.






STATEMENT OF ACCOUNT FORPROFESSIONAL SERVICES



Mont and Shauna Palmer



01/22/14

01/29/14

02/04/14

02/07/14

03/20/14

03/21/14

E. Stauffer 0.20 37.00 Receive and review order of short form discovery motion procedure from the court (.2)

C. Martinez 0.10 28.00 Correspond with W. Klein re potential settlement with M. Palmer (.1)


C. Martinez 0.10 28.00 Correspond with W. Klein resettlement negotiations with new attorney representing M. Palmer (.1)


E. Stauffer 0.20 37.00 Review plaintiffs I st set of discovery requests and incorporate into electronic filing system (.2)










Total Hours

C)?> DORSEY

0.20

0.20

0.40

0.40

0.20

2.70


37.00

37.00

74.00

74.00

37.00

April27, 2015 Page2

Receive and review substitution of counsel, update matrix (.2)

Receive and review settlement agreement, update matrix (.2)

Prepare stipulation and motion for order of dismissal (.4)

Edit stipulation and order of dismissal, forward to opposing counsel for approval; finalize and file with the court (.4)











Client-Matter No.: 492728-00009 Van and Sharon Palmer




For y.our con"l7i:~ience; j;\ease r{,bt,:payment to the. address below or we offer the option of remitting payment electronically by wire transfer. If y~•!i 1:\ll~;,;_ii;',y.questiow,: i~'giirding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recelyt.ible DepiirJ.:nr:nt ill I -800-861-0760. Thank you.

Mailing ,.h:::tructions: Dorsey &\~;~itney LLP P.O. Box Iti80




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbur~emenls and service charges, which either have not been received or processed, will appear on a later statement









Van and Sharon Palmer



02/04/14

03/20/14

05/05/14

05/16/14

06/13/14

06/24/14

07/01/14





C. Martinez 0.20 56.00 Review hardship affidavit and correspond with W. Klein regarding same (.2)

E. Stauffer 0.20 37.00 Receive and review hardship affidavit and update files (.2)

C. Martinez 0.10 28.00 Phone conference with opposing counsel

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service c_harges. which either have not been received or processed. will appear on a later statement












Total Hours

C :J» DORSEY

0.10

0.20

0.20

0.30

0.20

0.30

0.10

0.10

3.00


28.00

56.00

37.00

55.50

56.00

84.00

28.00

30.50

April27, 2015 Page2

concerning possible settlement (.1)


Correspond with W. Klein and B. Toone re possible settlement



Review settlement agreement and correspond with opposing counsel re same.


Correspond with opposing counsel concerning settlement.

Correspond with W. Klein concerning payment of amount owed and final settlement

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursemenls and service charges, which either have not been received or processed, will appear on a later statement.





SALT LAKE CITY OFFICE 80 l-933-7360




Client-Matter No.: 492728-00076 Roy E. Payne


INVOICE TOTAL




$528.00

Foi: .. ;:our cqe)~)hiencl;·i~tease.f~'it{i:;:payment to the address below or we offer the option of remitting payment electronically by wire transfer. If yNr hn~,;(; tWO;' questior>ii t/:!;iirding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts . Recei;·abie Depah_!t:~nt ii(I-800-861-0760. Thank you .

. • if·.·->: • ..

Mailing Ji)i;tructions: Dorsey & \VIlitney LLP P.O. Box 1"680




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon re<1uest. Disbursements and service charges, which either·have not been received or processed, will appear on a later statement.



/




STATEMENT OF ACCOUNT FOR PROFESSIONAL SERVICES·



Roy E. Payne



01/16/14

01/23/14

01/23/14

01/27/14

01/28/14

01/28/14

E. Stauffer 0.80 148.00 Run military search for active duty verification (.2) Review files and begin preparing default certificate papers and supporting documentation (.6)

C. Martinez 0.10 28.00 Correspond with P. Hunt re strategy in light of bankruptcy of defendant ( .1)

E. Stauffer 0.80 148.00 Receive and review bankruptcy order to comply or dismiss the Payne's Chapter 7 bankruptcy case (.2); prepare default judgment papers for entry of default judgment (.6)

C. Martinez 0.20 56.00 Research status of bankruptcy and outline strategy for case in light of same (.2) ·

E. Stauffer 0.40 74.00 Review bankruptcy case petition to determine assets and claim amount (.2); correspond with P. Hunt re same (.2)

E. Stauffer 0.20 37.00 Prepare notice of voluntary dismissal (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursemenl:!i and service charges, which either have not been received or processed. will appear on a later statement.





Total Hours

C)» DORSEY

0.20

2.70


37.00

April27, 2015 Page2


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which .either have not been received or processed. will appear on a Ia1er statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED DY DORSEY & WHITNEY








Client-Matter No.: 492728-00087 Ralph Peiris




·-.;.;·. . :\;c -~~;)~~:.~ ·.:: :- .. !-~~~nr~~:::-·

·.:~:i:;·~7

INVOICE TOTAL


$984.00

·<i/!J;• ·-;);. -=~ '

Fo:~,:\~our con~;~~iencdili}}.eas~;;k;;l{iipayment to the address below or we offer the option of remitting payment electronically by wire transfer. If y(itihnv(~ tiil;' q!lestiolH #i;ul'ding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Rece),,:sble Depw)<J:ent ~tl-800-861-0760. Thank you.

Mailing JL;tructions: Dorsey & ·'.'.VIJitney LLP P.O. Box 1680



ABA Routing Number: 091 000022 Account Number: 1602-3010-8500 Swift Code: USBKUS441MT

01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have nol been received or processed, will appear on a later statement.








Client~Matter No: 492728~00087

Ralph Peiris



01/14/14

04/17/14

04/23/14

04/23/14

04/24/14

04/24/14

04/25/14

E. Stauffer 0.30 55.50 Prepare letter to defendants re default, update tracking matrix (.3)

E. Stauffer 1.10 203.50 Prepare default certificate paperwork, perform bankruptcy search and civil service members searches (1.1)

C. Martinez 0.30 84.00 Revise application for entry of default certificate, default certificate, and declaration in support of application for entry of default certificate (.3)

E. Stauffer 0.20 37.00 Perform SCRA search for military status and update application for default certificate documents (.2)

C. Martinez 0.10 28.00 Revise notice of voluntary dismissal of S. Davison (.1)

E. Stauffer 0.20 37.00 Prepare notice of voluntary dismissal of Maria Davisan (.2)

E. Stauffer 0.40 74.00 Finalize and file application for default certificate, correspond with court clerk re

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either ha.ve not been received or processed, will appear on a laler statement.









Total Hours

C 1}) DORSEY

0.20

0.80

0.50

0.10

0.20

4.40


37.00

244.00

92.50

30.50

61.00

same (.4)

April27, 2015 Page2

Receive and review default certificate entered by clerk, update matrix (.2)

Draft .motion for entry of default judgment, declaration in support of motion for entry of default judgment, and proposed default judgment (.8)

Research Ralph Peiris' military status on the Department of Defense Manpower Data Center for C. Martinez; and Research Aaron Olsen's military status on the Department of Defense Manpower Data Center for C. Martinez (.5)

Review default judgment and correspond with M. Baker concerning domestication of the judgment and asset search on defendant

Correspond with lawyer representing R. Peiris concerning entry of default judgment

. Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have. not been received or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED JlY DORSEY & WHITNEY



C J» D.DRSEY DORSEY & WHITNEY LLP


{Tax Identification No. 41-0223337)



Client-Matter No.: 492728-00075 Visanti Peiris




.. ,e~A;;;t(=, -:;~~~w:---~ ":·:.:- ..

. '1:1t~ .. -:·~~~;)fJY·~~--tiiftiW~ ,.

. . . ~-; .-~·. (•

INVOICE TOTAL


$18.50

$18.50

Fm;\.our con:,~~~ienc~~·~rleast<,;;.{~ii'i'payment to the address below or we offer the option of remitting payment electronically by wire transfer. If yok hrn::: H!)j-!luestioi):kt;~urding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recd.;;ibie Dep<i~ti}:e,nt ~(·T-800-861-0760. Thank you.

Mailing IJ;:,tructions: Dorsey &'':;V~itney LLP P.O. Box 16<!0




01936


Se,...,.ice charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbur.sements and service charges. which either have not been received or processed, will appear on a later statement.









Visanti Peiris



01/15/14 E. Stauffer 0.10

Total Hours 0.10

18.50 Receive and review notice of dismissal and update tracking matrix accordingly (.1)

Service charges are based on rates established by Dorsey & Whitney. A schedule oflhose rates has been provided and is available upon request. Disbursements and service charges, which either have not bef!n received or processed, will appear on a later statement.




C }»DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00074 Colt West Perrin



INVOICE TOTAL


$628.50

FcH;+:our CQtvf¢riience;'t\'ease r0.iiii~'payment to the address below or we offer the option of remitting payment electronically by wire transfer. If y(\( h.!ly~.<1!iy,questiddii dgiiiding this information, please contact the lawyer you are working with on this prqject or Dorsey's Accounts Recei;:;lpre Dep'~it:r;ypt ~l"l-800-861-0760. Thank you.

Mailing ·k\tructions: Dorsey & 'J.'l:litney LLP P.O. Box 16SO




01936

Please mnke reference to the invoice number


ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWiSE EXPRESSLY AGREED BY DORSEY & WHITNEY








Colt West Perrin



01114/14

01/23/14

01/23/14

05/08/14

05/09/14

05/09/14

06/20114

E. Stauffer 0.30 55.50 Prepare letter to defendant re default, update tracking matrix (.3)

C. Sexton 0.20 26.00 Run Accurint report to determine the current address information for Colt West Perrin; deliver findings to E. Stauffer (.2)

E. Stauffer 0.20 37.00 Receive returned mail with no forwarding address, address search to determine if new address is available (.2)

E. Stauffer 0.80 148.00 Prepare application for default certificate papers, declaration in support and perform SCRA military searches (.8)

C. Martinez 0.30 84.00 Revise application for entry of default certificate and declaration supporting same (.3)

E. Stauffer 0.40 74.00 Finalize and file application for entry of default certificate (.4)

C. Martinez 0.20 56.00 Revise default judgment and motion and

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and serVice charges. which either have not been received or processed, wilt appear on a later statement.



·· Klein & Associates, PLLC Client-Matter No.: 492728-00074 Invoice No.: ******


Total Hours

()»DORSEY

0.80

3.20


148.00

April 27, 2015 Page2

declaration in support of same (.2)

Prepare application for default judgment and supporting documentation (.8)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursemenls and service charges, which either have not been received or processed, will appear on a later statement.









Client-Matter No.: 492728-00089 Richard and Larissa Powell


INVOICE TOTAL



;:~~ ·:.:;~.;:.

,;,:' .. } . \~-~-'.:_:~_-_:_:~_:,·.•.{~:;.fW ::: ~7' :-:>.··.::·~·-· .


~d\;:vour cor:\\~nienc'~;lti!eas!<.p;:~i1i(payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ifyt<trhn"iktlu;· .questioii}i )~;(guFding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei':i{;tiie Depiii.f~;;ent at i'-800-861-0760. Thank you .

. •. . ~ ' ..

Mailing·Jly,tructions: Dorsey & -';111-)itney LLP P.o. Box J'o8o




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges. which eilher have nol been received or processed, will appear on a later statement.





(Tax Identification No. 41 -0223337)




Richard and Larissa Powell



01/27/14

01/28/14

01/28/14

02/04/14

02/14114

02115114

02116/14


C. Martinez 0.10 28.00 Revise and file attorney planning meeting report and scheduling order (.1)

E. Stauffer 0.30 55.50 Finalize and file attorney planning meeting report and proposed scheduling order (.2); c~mespond with court clerk re same ( .1)



C. Martinez 0.80 224.00 Draft first set of discovery requests (.8)

C. Martinez 0.60 168.00 Draft Initial Disclosures and compile documents to produce with initial

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have nor been received or processed. will appear on a later statement.


















C)» DORSEY

0.20

0.60

0.20

0.20

0.40

0.20

0.20

0.30

0.50

1.50

0.20

0.20

0.20

0.30


56.00

111.00

37.00

37.00

112.00

37.00

37.00

84.00

140.00

420.00

56.00

37.00

37.00

84.00

disclosures (.6)

April27, 2015 Page2

Revise and serve initial disclosures

Prepare documents to serve with initial disclosures (.6)

Finalize initial disclosures and correspond with B. Toone re same (.2)

Receive and review Defendant's Initial Disclosures (.2)




Draft memorandum in support of motion for summary judgment (.3)

Draft memorandum in support of motion for summary judgment (.5)

Draft memorandum in support of motion for partial summary judgment concerning invalidity of ABI and declaration in support (1.5)

Analyze standing of S.E.C. filing motion for summary judgment and correspond with P. Hunt regarding same (.2)

Receive and review motion to transfer to judge jenkins (.2)


Correspond with B. Toone concerning deadlines for ongoing settlement












Total Hours

C)» DORSEY

0.20

0.30

0.10

0.10

0.20

0.20

0.20

9.20


37.00

55.50

28.00

28.00

37.00

56.00

61.00

negotiations (.3)




Correspond with opposing counsel re possible settlement.

Correspond with W. Klein resettlement offer.



Correspond with opposing counsel and W. Klein concerning final settlement

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or protessed, will.appear on a later statement.




( :J)> DORSEY DORSEY & WHITNEY LLP





Client-Matter No.: 492728-00088 R.C. Willey


-----------------------------------··············--····-·······---


INVOICE TOTAL

Total For Current Legal Fees $6,139.50


Fo; your con'-'<;nience, f'!ease r;;,:r:it payment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify;H.: h'1'.·:.: <H';' auestion•; r::t;arding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei,AJie Dep<>li:r:ent <tl 1-800-861-0760. Thank you.

Mailing J;:::.tructions: Dorsey & ·-...'illitney LLP P.O. Box 1680




01936





()}>DORSEY DORSEY & WHITNEY LLP






R.C. Willey

May 22,2015 Invoice No. ******


02/05/14

02/25/14

02/27/14

02/28/14

03/03114

E. Stauffer 0.20 37.00 Receive and review initial disclosures of

N. Seim

N. Seim

M. Hunt

N. Seim

defendant RC Willey (.2)

1.30 338.00 Telephone conference with R. Pahnke regarding discovery and scheduling order [R.C. Willey] (.3); further correspondence with same (.2); review discovery requests for same, and conference with P. Hunt regarding responses (.8)

0.30 78.00 Review and analyze issues with RC Willey discovery requests (.3)

0.50 185.00 Correspondence with N. Seim regarding discovery issues ( .1 ); correspondence with opposing counsel regarding same (.1 ); review documents sent by opposing counsel and draft email to Receiver regarding same (.3)

0.20 52.00 Review correspondence regarding RC Willey conference (.2)





03/04/14 M. Hunt

03/05/14 M. Hunt

03/06/14 M. Hunt

03/06/14 N. Seim

03/07/14 M. Hunt

03/07/14 M. Hunt

03/07114 N. Seim

03/10/14 N. Seim

03112114 M. Hunt

03112114 N. Seim

(]})DORSEY

0.10

0.60

0.10

1.70

0.20

0.90

0.30

0.20

0.30

1.20


37.00

222.00

37.00

442.00

74.00

333.00

78.00

52.00

111.00

312.00

May22, 2015 Page2

Correspondence with opposing counsel regarding settlement conference (.1)

Prepare for and attend settlement meeting (.5); conference with N. Seim regarding tasks on same (.1)

Conferences with N. Seim regarding discovery issues and settlement proposal (.1)

Draft settlement letter to RC Willey, and send same toP. Hunt (1.5); review and send RC Willey discovery responses to W. Klein (.2)

Correspondence and conference with C. Martinez regarding numerous general discovery issues (.2)

Read and revise settlement and discovery proposal and correspondence with W. Klein regarding same (.7); further correspondence with N. Seim on discovery issues (.2)

Revise RC Willey settlement letter per comments of P. Hunt regarding amendment of scheduling order, and send same toP. Hunt (.3)

Review revised settlement letter to RC Willey (.1); correspondence with P. Hunt regarding amended scheduling order for same (.1)

Review redline of settlement offer letter, further change same and instructions to N. Seim on same as well as discovery issues (.3)

Revise settlement offer letter for RC Willey, and send same to opposing counsel (.5); correspondence with R. Hyman and R. Pahnke regarding amending scheduling order (.2); draft stipulated motion to amend





03/13/14 N. Seim

03/20/14 M. Hunt

03/20/14 N. Seim


03/24/14 M. Hunt


03/28/14 N. Seim

04/22/14 N. Seim

05/08/14 M. Hunt

05/08/14 N. Seim

05/09/14 M. Hunt

06/04/14 N. Seim

(}»DORSEY

0.40

0.10

0.20

3.20

0.10

1.50

0.20

0.20

0.30

0.20

0.20

0.20


104.00

37.00

52.00

896.00

37.00

420.00

52.00

52.00

111.00

52.00

74.00

52.00

scheduling order (.5)

May 22,2015 Page 3

Drafting of amended scheduling order for RC Willey proceeding, and send same to P. Hunt (.4)

Review stipulation regarding extension of time and correspondence with N. Seim regarding same (.1)

Follow-up regarding amending scheduling order, and correspondence with R. Pahnke regarding same [RC Willey] (.2)

Prepare responses and objections to first set of interrogatories, requests for production, and requests for admission (3.2)

Correspondence regarding settlement agreement and settlement issues (.1)

Draft responses to RC Willey's first set of interrogatories, requests for admission, and requests for production (1.5)

Review entered scheduling order for R.C. Willey proceeding, and conference with E. Stauffer regarding calendaring same (.2)

Conference with P. Hunt regarding RC Willey proceeding, and correspondence with R. Pahnke regarding same (.2)

Review settlement letter and forward toW. Klein with memo regarding same (.3)

Review and analyze settlement offer from RC Willey (.2)

Review motion and proposed amended scheduling order pending settlement discussions and correspondence with N. Seim regarding same (.2)

Analyzing issues with R.C. Willey proceeding ( .2)




Klein & Associates, PLLC Client-Matter No.: 492728-00088 Invoice No.:******

06/26/14 M. Hunt

06/26114 N. Seim

06/27/14 M. Hunt

06/30/14 N. Seim



08/27114 M. Hunt

09/08/14 N. Seim


09/09/14 M. Hunt



C }»DORSEY

0.20

2.50

0.20

0.50

0.30

0.20

0.10

0.90

0.10

0.10

0.20

0.30


74.00

650.00

74.00

130.00

55.50

37.00

37.00

234.00

28.00

37.00

37.00

84.00

May 22,2015 Page4

Conference with N. Seim regarding status of settlement issues (.2)

Reviewing issues with R.C. Willey proceeding, including outstanding written discovery (.4); conference with P. Hunt regarding same and AT&T Universal litigation (.4); drafting settlement letter to R.C. Willey with Receiver's report (1.7)

Review draft settlement letter, revise same and send toW. Klein for comments (.2)

Revise letter to RC Willey and coordinate sending same with financial report and exhibits (.5)


Receive and review notice of appearance of B. Toone as co-counsel for defendant (.2)

Correspondence with N. Seim regarding discovery and scheduling ( .1)

Drafting stipulated motion and order to amend scheduling order (.4) [R.C. Willey]; drafting expert disclosures for submittal of R. Hoffman expert report to same (.4); correspondence with P. Hunt and C. Martinez regarding same ( .1)

Review motion to amend scheduling order and correspond with opposing counsel re same.

Review documents on discovery and email with C. Martinez regarding same (.1)


Revise scheduling order and expert disclosure and correspond with opposing






10/20/14 N. Seim

11/17114 N. Seim

11118114 M. Hunt

11/18114 N. Seim

12/03/14 N. Seim

Total Hours

C }»DORSEY

0.20

0.10

0.20

0.10

0.30

0.20

21.60


61.00

29.50

59.00

38.00

88.50

59.00

counsel re same.

May22, 2015 Page 5

Revise and file stipulated motion to amend scheduling order.

Reviewing issues with R.C. Willey scheduling and deadlines (.1)

Correspondence with P. Hunt regarding outstanding issues and timeline (.2)

Conference with N. Seim regarding status (.1)

Review issues and discovery in proceeding (.2); conference with P. Hunt regarding same (.1)

Conference with P. Hunt regarding discovery issues and proceedings in case (.2)

· Total for Legal Fees $6,13.9.50

Total This Invoice











Client-Matter No.: 492728-00092 Jim Sandberg




/" ·~·&f~

. f!~b.t:N:··.:·· : : ~i :;'

•.•'·.-.· \.~/. F' ~:~·"·~ -:/~;;~~~-j~:;; .

. o,t6~~oc' • 'F\ '>:J·

INVOICE TOTAL


-~~;;· )?i ~::,~:. ,\·<·--: Fo1)f:our C<J,1?8i?nience;pleas~.r~ih\it' payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfyr;ii,hl'''~'(i\)'~\i,<),Uestiol:,~,,r~;,;iirding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei,'Jo;((jfe Dep~'i\~o~pt ur i-800-861-0760. Thank you .

. -~- ·:F ..

Mailing·W,i;tructions: Dorsey & ~Vhitney LLP P.O. Box lo80




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Di5bursements and service charges, which either have not been received or processed, will appear on a later stalement



C J}) DORSEY DORSEY & WHITNEY LLP






Jim Sandberg



01/15/14 E. Stauffer 0.30 55.50 Prepare letter to defendant re default, update tracking matrix (.3)

04/23114 E. Stauffer 0.20 37.00 Perform SCRA search for military status and update application for default certificate documents (.2)

04/25/14 E. Stauffer 0.80 148.00 Prepare application for default certificate and supporting documentation (.8)

05/07/14 C. Martinez 0.30 84.00 Revise application for entry of default certificate and affidavit in support of the same (.3)

05/08/14 E. Stauffer 0.40 74.00 Finalize and file motion for default certificate (.4)

05115/14 E. Stauffer 0.20 37.00 Receive and review clerk's entry of default certificate (.2)

06/20114 C. Martinez 0.30 84.00 Revise default judgment and motion and declaration in support of same (.3)

06/20/14 E. Stauffer 0.80 148.00 Prepare default judgment papers and

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.·





April27, 2015 Page2

supporting documentation (.8)

Total Hours 3.30

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appc"ar on a later statement.






(fax Identification No. 41-0223337)



Client-Matter No.: 492728-00107 Thomas Schultz


INVOICE TOTAL




Fbrci\'our corl1niencJ;iheas~;A{:;i(J>ayment to the address below or we offer the option of remitting payment electronically by wire transfer. If yi{h ha\fti'i;): nuestioiJ;!f\~stirciing this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Rece\:,,;i;ule Depwi!''':-nt at'i-800-861-0760. Thank you.

. . :'" ...

Mailing l!;;,tructions: Dorsey & ·,Jfhitney LLP P.O. Box 1680



ABA Routing Number: 091000022 Account Numb~r: 1602-3010-8500 Swift Code: USBKUS44IMT

01936





C :1» DORSEY DORSEY & WHITNEY LLP






Thomas Schultz



01/15/14

04/25/14

05/07/14

05/08/14

06/20/14

06/20/14

06/23/14

07/07/14

E. Stauffer 0.30 55.50 Prepare letter to defendant re default, update tracking matrix (.3)

E. Stauffer 0.80 148.00 Prepare application for default certificate and supporting documentation (.8)

C. Martinez 0.30 84.00 Revise application for entry of default certificate and affidavit in support of the same (.3)

E. Stauffer 0.40 74.00 Finalize and file motion for default certificate (.4)

C. Martinez 0.20 56.00 Revise default judgment and motion and declaration in support of same (.2)

E. Stauffer 0.80 148.00 Prepare application for default judgment and supporting documentation (.8)

E. Stauffer 0.30 55.50 Receive and review order re case assignment to Judge Benson, update pleading and tracking matrix (.3)

E. Stauffer 0.20 37.00 Receive and review default judgment,

Service charges are based on ratC3 established by Dorsey&. Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.




Total Hours

C))} DORSEY DORSEY & WHITNEY LLP

update tracking matrix (.2)

3.30

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed. will appear on a later statement

April27, 2015 Page2




( )J> DORSEY DORSEY&. WHITNEY LLP






Client-Matter No.: 492728-00118 ·><;;:l'\· Richard Schutte 4~:{~i' .

-------------------------------------~.·fi~r:,r;·'£~, ·:~~~·t;tsif;~'~y).: For Legal Services Rendered Through December 31, 2014

INVOICE TOTAL



r~:;:r.·1Jpst6.oo $816.00

'·~>~=~;< ._,· -.'' ..-:..::~f:i*· \~~... ··}·

.> •..• <' ~~-~----~.:::~:~l·::-: .·

Fot ;<:our con·;;,:nienc~A:c!easexf:il:itpayment to the address below or we offer the option of remitting payment electronically by wire transfer. If y<!<;·hnv;,.,(myquestidt\;\ti'ulU'ding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts · Recei'-,ahle Depawpcnt ~H-800-861-0760. Thank you.

Mailing.lt):;tructions: Dorsey & '·'i'hitney LLP P.O. Box 1680




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges. which either have not been received or processed. will appear on a later slatement.









Richard Schutte



01/16/14

01116114

03/25/14

. 03/25/14

04/07114

04/08114

04/15114

C. Martinez 0.20 56.00 Revise application for default certificate

E. Stauffer 0.20 37.00 Letter to defendant's re default, update tracking matrix (.2)

C. Martinez 0.10 28.00 Draft response to order to show cause (.1)

E. Stauffer 1.00 185.00 Receive and review order to show cause, update calendar/matrix (.2); prepare response to order to show cause (.2); prepare application for default certificate (.6)

C. Martinez 0.50 140.00 Revise application for default judgment, default certificate, and declaration in support of application (.5)

E. Stauffer 0.40 74.00 Finalize and file application for entry of default certificate and supporting documentation (.4)

E. Stauffer 0.60 111.00 Prepare application for default judgment, declarations in support and proposed









Total Hours

C :J» DORSEY

0.20

0.20

0.40

0.20

4.00


37.00

37.00

74.00

37.00

judgment (.6)

April27, 2015 Page2

Receive and review notice of reassignment of case from magistrate judge (.2)

Receive and review notice from court of reassignment to Judge Shelby, update matrix (.2)

Finalize and file application for default judgment (.4)

Receive and review order of default judgment, update matrix (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule ofthose rates has been provided and is available upon request. Disbursements and se"rvice charges, which either have not been received or processed, will appear on a later statement









Client-Matter No.: 492728-00135 Secure American Gold Exchange


.: :':>.-. :::·_:_·



. :: .. ~_--.. -~

INVOICE TOTAL


$1,116.75.

Fdt~'y~ur cor:i\;,~nienc~?';~ease !\'xnf'payment to the address below or we offer the option of remitting payment electronically by wire transfer. lfy6i.h!lf<i:'iiilyquesti~i,i:: .. r~5g>Jding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei:t,i,l>I'e Depart~·r:ent al f-800-861-0760. Thank you.

-. --·!.··:·-·

Mailing lfi\tructions: Dorsey & ::-'Z~itney LLP P.O. Box 1'680



ABA Routing Number: 091 000022 Account Number: 1602-3010-8500 Swift Code: USBKUS441MT

01936

Please rna ke reference to the invoice number

Service charges are based on rates &3-lablished by Dorsey & Whitney. A S<:hedule of those rales has been provided and is available upon request. Disbursements and service charges. which either have not been received or processed. will appear on a later statement.

ALL INVOICES ARE DUE 30DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WHITNEY








Secure American Gold Exchange



11124/14

11/25114

11/26/14

11/26/14

12/01/14

12/02/14

12/18/14

C. Martinez 1.20 366.00 Draft complaint (1.2)

C. Martinez 0.30 91.50 Revise complaint and correspond with W. Klein re his additional revisions to complaint (.3)

C. Martinez 0.20 61.00 Revise and file complaint, civil cover sheet, and summons

A. Trujillo 1.50 277.50 Coordinate with C. Martinez to file summons and complaint with District Court; email to court regarding the same

A. Trujillo 0.25 46.25 Coordinate with process server for service of summons and complaint to SAGE

C. Martinez 0.80 244.00 Draft initial disclosures and identify documents for production

C. Martinez 0.10 30.50 Phone conference with opposing counsel concerning possible settlement

4.35

Service charges are based on rates establisbed by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed, will appear on a later statement




Total Hours

C J» DORSEY DORSEY & WHITNEY .LLP

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available . upon request Disborsemenls and service charies, which either have nor been received or proe(ssed, will appear on a later statement.

Apri127, 2015 Page 2




C ::J» DORSEY DORSEY & WHITNEY LLP






.3:

Client-Matter No.: 492728-00081 David L. Sefton

'l!~ftP" ·,


INVOICE TOTAL



:.: :; ·~. F~~'>pur cqr:v<~nienceA~1.ea~\l r.:;~_}:i{payment to the address below or we offer the option of remitting payment electronicalJy· by wire transfer. Ifyiitio.h'l'i{{!i(iy,,9uestioiru}'glirding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receli~'ii.iJre Dep&iltf:,ert a(i'~800-861-0760. Thank you .

. , ~<'.

Mailing'l!;i;tructions: Dorsey &·~'ihitney LLP P.O. Box JbiiO




01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and sen·ice charges, which either have not been received or processed, will appear on a later statement.









David L. Sefton



01/22/14

01/23/14

01/23/14

02/10/14

02110/14

02/12114



E. Stauffer 0.20 37.00 Correspond with process server re update on service and need to have done by end of January (.2)


E. Stauffer 1.00 185.00 Prepare motion for service by alternative means and supporting documents (.7); finalize and file with the court, correspond with the clerk reproposed order, update matrix (.3)

E. Stauffer 0.20 37.00 Email defendant with summons, complaint

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not beC'n received or processed. will appear on a later statement.



,Klein & Associates, PLLC Client-Matter No.: 492728-00081 Invoice No.: ******








Total Hours

C)}) DORSEY

0.10

0.20

0.20

0.20

0.20

0.20

0.20

3.50


18.50

37.00

37.00

37.00

37.00

37.00

37.00

April27, 2015 Page2

and order granting service by alternative means as required (.2)

Email defendant with copy of summons, complaint and order in compliance with judge's order (.1)

Email to defendant in compliance with order granting motion to serve by alternative means (.2)



Status report to C. Martinez re failed service via email and whether or not to move forward with service by publication (.2)

Prepare notice of voluntary dismissal (.2)

Finalize and file voluntary dismissal papers (.2)

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon requeSI. Disbursements and service charges, which either have not been received or processed. will appear on a later statement











~. ·r;~~-~-~/~~\T~-~~ :· . . '-~:. ::: ., ".< ~

..


FdV:your cor:,~li'hience; ~i.lease r<'(l~itpayment to the address below or we offer the option of remitting payment electronically by wire transfer. Ify,iti h<1{'~··''[C:-' ,questioh~ ":'gurding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Recei\'itt:ife Depdh::lif!nt ul J-800-861-0760. Thank you.

Mailing.~l;;,tructions: Dorsey &\Vhitney LLP P.O. Box ioilo




01936





C J}> DORSEY DORSEY & WHITNEY LLP






Emil Sher



01/15/14 E. Stauffer 0.30 55.50 Prepare letter to defendants re default, update tracking matrix (.3)

04/23/14 E. Stauffer 0.20 37.00 Perform SCRA search for military status and update application for default certificate documents (.2)

04/25/14 E. Stauffer 0.80 148.00 Prepare application for default certificate and supporting documentation (.8)

05/08/14 C. Martinez 0.30 84.00 Revise application and supporting declaration in support of application for entry of default certificate (.3)

05/08/14 E. Stauffer 0.40 74.00 Finalize and file application for entry of default certificate (.4)

05/14114 E. Stauffer 0.20 37.00 Receive and review default certificate issued by clerk, update matrix (.2)

06/20/14 E. Stauffer 0.80 148.00 Prepare application for default judgment and supporting documents (.8)

06/24114 C. Martinez 0.30 84.00 Revise application for default judgment and




· Klein & Associates, PLLC Client-Matter No.: 492728-00083 Invoice No.: ******


Total Hours

C)» DORSEY

0.40

3.70


74.00

supporting affidavits (.3)


Finalize and file default judgment application and supporting documentation (.4)

Sc!Vice charges arc based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have hot been received or processed, will appear on a later statement




C :J}) DORSEY DORSEY & WHITNEY LLP

,, SALT LAKE CITY OFFICE

801-933-7360




Client-Matter No.: 492728-00086 James Shoen


INVOICE TOTAL



<~'{l\

'~?~ -.:«{_ .. ~s.K·-

Apri127, 2015 Invoice No.******

'f& <$)§ih'if1g1158 50 \~;hl;, ·o:.**;f@;l •

<~;~) $1,158.50

Fot:'your con~;;~nienc~.:>J.easep:iii:irpayment to the address below or we offer the option of remitting payment electronically by wire transfer. lfyl)t.iJl!l'rY'i;p:;' ouestiOil~;f{t;iirding this information, please contact the lawyer you arc working with on this project or Dorsey!~Accounts Rece~k;1.Uie Dep;;i;;,,_~nt at'' 1-800-861-0760. Thank you.

Mailing li:f;tructions: Dorsey & 'J~I]itney LLP P.O. Box 1680




01936


Service charges are based on rates est11blished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement.









James Shoen



01/03/14

01/07/14

01/16/14

01/22/14

01/22/14


E. Stauffer 0.20 37.00 Receive and review notice of initial pretrial conference and deadline to submit attorney planning meeting report, update calendar (.2)

E. Stauffer 0.20 37.00 Receive and review notice from qourt ordering use of the short form discovery procedure, update matrix/calendars (.2)

· C. Martinez 0.30 84.00 Draft attorney planning meeting report and proposed scheduling order (.3)

E. Stauffer 0.40 74.00 Correspond with opposing counsel re attorney planning meeting report and proposed scheduling order (.2); finalize and file attorney planning meeting report and correspond with court clerk re scheduling

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges. which either have not been Tcccived or processed, will appear on a later statement.

ALL INVOICES ARE DUE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED BY DORSEY & WJIITNEY


·Klein & Associates, PLLC Client-Matter No.: 492728-00086 Invoice No.: ******













09/19/14 M. Hunt

C)» DORSEY

0.30

0.40

0.60

0.30

0.20

0.20

0.20

0.20

0.20

0.20

0.30

0.20

0.50


55.50

112.00

111.00

55.50

37.00

56.00

37.00

37.00

37.00

37.00

55.50

37.00

185.00

order (.2)

April27, 2015 Page2

Receive and review scheduling order, update calendar/tracking matrix (.3)

Prepare and serve initial disclosures (.4)

Prepare documents to produce with initial disclosures (.6)

Prepare spreadsheet of case showing total transfers and false profit transfers and calculate false profit transfers occurring after 2008 for possible settlement negotiations with Toone (.3)


JPS/MKS - Draft first set of interrogatories, requests for production and requests for admission (.2)







Review and revise status report requested by the court and email to C. Long regarding same (.4); final review of same and

Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request Disbursemen1s and service charges, which either have not been received or processed, will appear on a later statement.




C ]»DORSEY DORSEY&. WHITNEY LLP

April27, 2015 Page3

instructions to staff on same (.1)

Total Hours 5.30










Client-Matter No.: 492728-00084 Duane Slaughter


INVOICE TOTAL

'··~



~~;_:_,_._:_ .. -.'.· .. ,, ,;(.~ \~. ~ ·.:~; =· ,; :t2·?~f~}r-···


·.· ; ... ·. -.;_;~~:;;·· ,,,;"c.

FO'(':vour cor:•J,jrtience;jJease.:~li)\Tipayment to the address below or we offer the option of remitting payment electronically by wire transfer. If yoi.: h.n-<t uf!y qjjestidikh:!<ilarding this information, please contact the lawyer you are working with on this project or Dorsey's Accounts Receh)!ble Dep~il:r;(_:nt a(f-800-861-0760. Thank you.

Mailing ·Js)},tructions: Dorsey & ''NIJitney LLP P.O. Box 1680



ABA Routing Number: 09 I 000022 Account Number: 1602-3010-8500 Swift Code: USBKUS44IMT

01936


Service charges are based on rates established by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements: and service charges, which either have not been received or processed. will appear on a later statement.



( 2}) DORSEY DORSEY & WHITNEY LLP






Duane Slaughter



02/28/14 C. Martinez 0.30

04/07/14 C. Martinez 0.10

04/22/14 C. Martinez 0.50

04/23114 C. Martinez 0.30

04/25/14 E. Stauffer 0.20

06/04/14 C. Martinez 0.30

06/30/14 C. Martinez 0.30

84.00 Draft letter to opposing counsel concerning possible settlement

28.00 Correspond with opposing counsel concerning death of defendant ( .1)

140.00 Correspond with W. Klein regarding strategy for case and begin draft of discovery questions to C. Slaughter (.5)

84.00 Draft first set of interrogatories, requests for production, and requests for admission and letter to opposing counsel regarding same (.3)

37.00 Review letter to counsel with discovery requests ( .2)

84.00 Correspond with opposing counsel and W. Klein concerning financial affidavits of C. Slaughter and potential settlements (.3)

84.00 Correspond with opposing counsel regarding facts necessary to evaluate

Service charges are based on rates es1ablished by Dorsey & Whitney. A schedule of those rates has been provided and is available upon request. Disbursements and service charges, which either have not been received or processed. will appear on a later statement.









Total Hours

C)» DORSEY

0.70

0.20

0.30

0.20

0.30

3.70


196.00

37.00

55.50

37.00

91.50

settlement (.3)

April27, 2015 Page2

Draft letter to defendant disclosing documents that form the factual basis of the Receiver's claim and disclosing receiver's report of insolvency (.1 ); Draft and serve initial disclosures (.3); Draft attorney planning meeting report and scheduling order and correspond with defendant re same (.3).




Draft attorney planning meeting report and proposed scheduling order and conespond with opposing counsel concerning same

Service charges are based on rates established by Doney & Whitney. A schedule of those rates has been provided and is available upon request Disbursements and service charges, which either have not been received or processed, will appear on a later statement.

ALL INVOJCF-5 ARE DlJE 30 DAYS FROM DATE OF INVOICE UNLESS OTHERWISE EXPRESSLY AGREED RY DORSEY & WHITNEY
