Ce a 10 ret 12 13 14 15 16 M7 18 19 20 21 22 23 24 25 MICHAEL K. JEANES Clerk of the Superior Court By duty Baker Desuty Date 02/08/9017 Tina 08123 Deseription A — CASE (DO1T-OOLG00 ~ CIVIL HEM COMPLAINT a : A WILENGHIK.6¢ BARTNESS ATTORNEYS AT Law ‘The Wilenebile 8 Barnes Building 2810 Nowth Thied Sueet Phoenix, Arizona 65004 “Flephone: 602-606-2810 Facsimile: 602.606.2811 Dennis I. Wilenchik, #005350 John D. Wilenchik, #029353 Attorneys for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA HOMECREST, LLC, an Arizona limited | CASE NO. liability company, as Assignee of Claim of CV 2017-001400 Wilenchik & Bartness, P.C., a Professional Corporation, COMPLAINT (Breach of Contract) Plaintiff, v. (Jury Trial Requested) ADVOCATES FOR INDIVIDUALS WITH DISABILITIES, LLC, an Arizona limited liability company, Defendant. Homecrest, LLC, by and through counsel undersigned, for its Complaint against Defendant | Advocates for Individuals with Disabilities, LLC, alleges as follows: PARTIES JURISDICTION & VENUE 1. Plaintiff, Homecrest, LLC (“Homecrest”) is an Arizona limited liability company authorized to do business in the State of Arizona. Plaintiff is lawfully conducting its business in| this state and within the County of Maricopa, 2. Homecrest is assignee of the claim of the Account Receivable of Wilenchik &z co Bio ew a au 15 16] 17] 18 19] 20} 2 22] 2B 2a| 25] Bartness, P.C. (“W&B”) related to the delinquent accounts set forth herein. 3. Defendant Advocates for Individuals With Disabilities, LLC (“AID” or: “Defendant”) is an Arizona limited liability company, doing business in the State of Arizona, within the County of Maricopa. 4. The underlying events which give rise to this complaint occurred in Maricopa County, Arizona, 5. ‘Venue and jurisdiction are proper in this Court because the actions taken between the parties giving rise to this action and the conduct complained of occurred principally in Maricopa County, Arizona, and pursuant to ARIZ.REV.STAT.ANN. § 12-401.. 6. Jurisdiction is proper in the Maricopa County Superior Court pursuant to ARIZ. REV.STAT.ANN, §§ 12-122 and 12-123. GENERAL ALLEGATIONS 7. Plaintiff incorporates the preceding allegations as if set forth fully herein. 8. On or about July 21, 2016, Defendant AID executed an engagement letter wherein it agreed to pay W&B for services for legal advice and representation at its regular hourly rates as well as for all costs incurred incident to those services. A true and correct copy of the signed engagement letter is attached hereto as Exhibit A and incorporated by reference (“AID Letter”), 9. On or about August 16, 2016, Peter Strojnik (“Strojnick”) executed an engagement letter wherein W&B would provide services at its regular hourly rates as well as for all costs incurred related to his representation arising out of his work with AID, A true and correct copy of| the signed engagement letter is attached hereto as Exhibit B and incorporated by reference (Strojnik Letter.”) AID agreed to pay Strojnick’s fees, 10, The AID Letter and the Strojnik Letter are collectively referred to herein as “Engagement Letters.” 11, Plaintiff fulfilled all of its obligations under the Engagement Letters, 2a wn 5| 12. Defendant and Strojnik were billed monthly from the inception of the representation through and including December 31, 2016. 13, Defendant made sporadic payments, further acknowledging its agreement to pay WB for services rendered. True and correct copies of the W&B invoices (REDACTED) are attached as Exhibit C and incorporated herein. 14, After W&B made repeated requests to Defendant to pay the outstanding balance, the Defendant agreed to pay to W&B the sum of $5,000.00 per month until the account was paid in full. A true and correct copy of email communications is attached as Exhibit D and incorporated by reference. 15, Defendant has failed and refused to pay past due amounts. 16. On or about January 26, 2017, all right, title and interest in the Accounts Receivable of W&B related to the AID Engagement and the Strojnick Engagement were assigned for valuable consideration to Homecrest, LLC (the “Homecrest Accounts Receivable”). 17. To date, there is an outstanding balance left due and owing on the Homecrest Accounts Receivable is $72,652.72, plus accrued and accruing interest, attomeys’ fees and costs. COUNTI (Breach of Contract) 18. Plaintiff re-incorporates and re-alleges the allegations contained in Paragraphs 1 through 15 above. 19, Plaintiff is the assignee of the claims of W&B, which at all times performed all the stipulations, conditions and agreements under the Engagement Letters. 20, Defendant has failed and refused, and still fails and refuses, despite repeated requests, to perform by paying all of the amounts due and owing. 21. By reason thereof, the amount due and owing on the Homecrest Account Receivable is due in the sum of $72,652.72, plus interest at the rate of 1.5% per month (18% per annum), and 3Lim ss wien 10} MW 2 13 14] 15 16} 17 18} 19 20 2 23 24 25 fees and costs associated with collection. WHEREFORE, Plaintiff requests that the Court enter judgment against Defendant, as follows: A. For the principal amount of $72,652.72; B. For interest on the principal amount from December 31, 2016, to the date of judgment, at the rate of 1.5% per month (18% per annum); C. For postjudgment interest at the rate of 1.5% per month (18% per annum) on the principal until paid in full D. _ Forreasonable attorneys’ fees and costs; E. For interest on the awarded fees and costs at the legal rate of interest of 4.75% until paid in full; F. For costs incurred in the collection of this matter; G. For such other and further relief as the Court deems just and proper under the circumstances, including an award of post judgment interest at the highest legal rate until paid in’ full; H. — For costs of collection upon any judgment, including reasonable attomeys’ fees and costs, RESPECTFULLY SUBMITTED February _74, 2017. WILENCHAY& BARTNESS, P.C. 1. Wilenchik, Esq. D. Wilenchik, Esq. fe Wilenchik & Bartness Building 10 North Third Street Phoenix, Arizona 85004 Attorneys for Plaintifffs BARTNESS WILENCHIK & A PROFESSIONAL! ‘ EXHIBIT ADennis I, Wilenchik Licensed in diw@wb-law.com WILENCHIK & BARTNESS Arizona, Texas, New ATTORNEYS AT LAW ‘York, and the — “The Wilenchik & Bartness Building District of Columbia 2510 North Thicd Steet Phoenix Aceon 85004 ‘Telephone: 602-606-2810 Facsimile: 602-606-2811 July 18, 2016 Advocates For Individuals With Disabilities, LLC lo Fabian Zazueta, if-house counsel fibien@aidon || Re: Engapement of Wilenchik & Bartness, P.C. Dear Fabian Zamuetai ‘We appreciatp that you have asked Wilenchik & Bariness to provide legal services to Advocates For Individuals With Dissbilities, LLC (“AID”) in connection with a potential action for defamation (among other related causes of action) against E.D. Marshall and Lindsay Leavitt. Cohsistent with our normal practice, this letter and the attached Statement of Engagement Terms and Billing Practices (the “Statement”) set forth the terms of our ‘engagement. Unless jexpressly stated otherwise in this letter, our representation does not include an appeal of your matter and will terminate, if not sooner, upon completion of all trial-related services: It is important that you review the attached Statement so that you understand in advance how various issues will be handled. Our fees for Jegal services, unless expressly stated otherwise, are based on the time ‘we spend on your engagement, In the event that you or we believe that the services or manner of billing should be changed, we will discuss doing so. We charge separately for expenses and other costs incurred in connection with our services, as described in the attached Statement, and we may require advance fees for such items. ur billing statements are normally rendered on a monthly basis and are due and payable upon receipt: We will try to include expenses and other charges in the statement for ‘the month in which they are incurred, but on occasion, accounting for certain expenses and ‘charges (i.¢., Iate-popted items or international charges) may be delayed, In that case, late- posted items will be billed on a future statement, The Firm reserves the right to charge a late payment penalty in the form of interest on any statements not paid within 30 days after the statement dete, at the legal rate of interest, Our represetitation is conditioned upon receipt of a signed copy of this letter confirming your understanding and approval of these terms, accompanied by your deposit of $5,000 retainer that may or may not be refundable, depending on the circumstances,WILENCHIK & BARTNESS ‘Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 2 of 8 “We do our best to see that our clients are satisfied not only with our services but also with the fees charged for those services, If this letter and the attached Statement correctly set forth our mutual understanding, please sign and date the enclosed copy of this letter and retum it to us with the attached Statement. There shall be no attomey-client relationship ‘between us unless and until you sign and retum this agreement. We appreciate the opportunity to serve you and sincerely hope that our relationship will be one of mutual trust and respect as well es of value and assistance to you. If you ever have any questions or concems, I urge you to contact me, ‘Very truly yours, Dennis I. Wilenchik ‘THE TERMS OF THE ENGAGEMENT OF ‘THE FIRM AS STATED ABOVE AND IN THE ATTACHED STATEMENT ARE ACCEPTED AND APPROVED BY: (Signature) rrineaName:_ {phan Zazveks Title: Zn = Piisg actor parep:__ “7 16WILENCHIK & BARTNESS Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 3 of 8 ‘ATE! TERMS AND BILL} ‘Our representation is effective as of the date of the mutual execution of the attached agreement. We will undertake your representation and work with you to achieve the desired objectives in the most effective way that we can, mindful of costs. We will endeavor to use cour best judgment and skill in representing you. We are bound by th¢ Arizona Rules of Professional Conduct and may only advance causes and defenses that car be brought in good faith, based upon the facts and the established law. Together, we need 16 identify and review all documents that may be relevant to your claims or defenses. We request your full cooperation and attention. in this regard. All work performed and workiproductof any kind will be deemed to be confidential and/or privileged material. 1 ‘You understand that! we cannot and have not made any guarantee regarding the outcome of ‘any matter. Comments made by any of the Firm’s attomeys and/or staff concerning the ‘outcome of a mattef are expressions of opinion only. Also, any estimates of fees that are given shall not be a puarantee, ‘and actual fees may vary based on circumstances that we are “unable to foresee. ‘Staffing. I will have|primary responsibility for the matter, Staffing decisions will be made by ‘me. I may utilize other attorneys, paralegals and litigation/clerical assistants, with an end to providing services op an efficient and cost-effective basis. Fees, We anticipate billing for professional services in accordance with Rule 1.5 of the Rules of Professional Conduct promulgated by the Arizona Supreme Court, primarily based upon the schedule of hourly rates established by the Firm for the lawyers and other members of the ‘professional staff of the Firm. In order to help us determine the value of services that we render, our attorneys, paralegals and document clerks maintain written records of the actual time they spend working for clients. The hourly rates are based on years of experience, specialization in training and practice and level of professional attainment, We periodically review our hourly rates and make adjustments as necessary, and you will be provided with written notice of any ‘changes to them, ‘Our current hourly rates are as follows: ATTORNEYS Dennis I. Wilenchik $400.00 Becky A. Bartness $400.00 ‘Thomas E. Lordan $225.00 Jeff Bouma $225.00WILENCHIK & BARTNESS Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 4 of 8 Lawrence J. Felder $210.00 Tyler Q. Swetsen $200.00 Jack D. Wilerichik $200.00 Brian J. Hemibd $200.00 Kyle B. Nelson $200.00 Colleen Cox Thomas $180.00 David A. Timchak $125.00 PARALEGALS. Lisa R. Loftis 3 55.00 Hilary J. Myers $ 55.00 Christine Ferreira $55.00 Lisa M. Marduez $ 55.00 Michael Wilenchik $ 50.00 Monica Rapps $125.00 Aileen De Las Angeles $135.00 Victoria Stevens $150.00 Costs, In addition to our fees for services, you will be responsible for all out-of-pocket disbursements that we incur on your behalf. You hereby authorize us to incur and agree to reimburse the Firm for all out-of-pocket costs incurred by us that we believe are necessary t0 fulfill our engagement. Typical of such costs are filing fees, travel expenses, long-distance telephone calls, outgoing faxes, Federal Express, courier services, and delivery charges, photocopying, expert witness fees, court reporter and transcript costs, and costs for computer assisted legal research (Westlaw, ctc.). We anticipate making advances to cover out-of- pocket costs incurred but reserve the right to forward to you any items with the request that you pay them directly to the service providers. Billings. Our statements for services rendered and costs incurred will be prepared and mailed to the address listed above during the month following the month in which services are rendered ‘and costs advanced. We will make every effort to include our out-of:pocket disbursements in the next monthly statement, However, some disbursements are not immediately available to us and, as a result, may not appear on @ statement until sometime after the charges were actually incured. All statements are due and payable upon receipt and considered past due thirty (30) days after the statement date, Any bill that is not paid within thirty (30) days will be charged with interest at the rate of 1.5% per month (18% per annum). The Firm reserves the right to decline to perform further services if any account is thirty (30) days or more past due. Ifthe Firm ‘must engage counsel or otherwise expend finds to collect bills over sixty (60) days old, you also ‘agree to reimburse the Firm for all fees and costs associated with collection. Advance Deposit. It is our policy to ask clients without an established payment history with the Fim, and otherclients as well, to provide us an advance deposit before commencingWILENCHIK & BARTNESS Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 5 of 8 ‘work, Except as proyided herein, the advance deposit amount will be held by us in a trust account until our representation is concluded. If any monthly statement is not paid before coming past due, we|will have the right, in our discretion, to epply the amount being held in trust to your outstanding balance. Should that become necessary, you will still be responsible for any remaining balance, and we will have the right to withdraw from further representation if the balance remains unpaid, If we use the advance deposit to pay an outstanding statement, ‘we reserve the right to notify you that we have done so, whereupon you will promptly replenish the advance deposit. Ifthe advance deposit is not replenished within 15 days, we reserve the right to terminate our representation. Advance Fee for Tea [In the event the matter proceeds to trial, we also reserve the right to request a sufficient additional advance fee for trial. “Advance Fee for Apjeal. In the event we expressly agree to expand the scope of our representation to include an appeal, we also reserve the right to request a sufficient additional advance fee for the appeal. Cliont’s Responsibilities. We will try to keep you informed as to the status of our representation end as to the course of action which we are following or which is being recommended by us, We will make all written material sent or received by us reasonably favtilable to you by way of copy, or you may examine the originals in our office at all reasonable times. Recognizing that the Firm cannot effectively represent you without your cooperation and assistance, you agree to cooperate fully with the Firm and to provide promptly all information known or available to you relevant to the Firm's representation, Jncluding, without limitation, providing information and documents requested in a timely fashion; assisting in Uiscovery, disclosure and trial preparation; cooperating in scheduling and related matters; responding to telephone calls and correspondence in a timely manner, and informing the Firm of changes in your address and telephone numbers, Spollation. Please be advised that both the Arizona and Federal Rules of Civil Provedure Tequire all parties tq litigation to preserve and disclose all information related to the case, Both parties and their counsel can be sanctioned for failing to preserve and disclose both hard-copy documents and electronically stored information (“ESI”). ESI includes, but is not limited to, electronic mail, voice mail, text messages, and all documents and data sorted on computers, PDA's (Blackberries, iPhones, ete.) laptops, cell phones, and the like. EST can also include data stored on personal hardware (home computers, personal cell phones, etc.) if used for work purposes. Therefore, itis important that such data not be deleted from your computers or networks, and that hardware in use during the relevant time period not be discarded.(Note: the litigation hold does not apply to inaccessible backup tapes [tapes typically maintained solely for disaster recovery] unless the backup tapes are accessible or are actively used for information retrieval.)WILENCHIK & BARTNESS Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 6 of 8 ‘You must suspeid routine documents retention/destruction policies and put in place a “tigation hold” tojensure preservation of relevant documents and EIS. As a rule of thumb, the a ‘hold should be retroactive to your first contact with the opposing party regarding the litigation matter and continuing through the present. We request, at a rinimum, that the flowing steps be taken once the litigation hold i in place: 1. All destruction of documents of any type, including EIS, pertaining in any way to this matter must immediately stop even if your document retention policy would otherwise call for routine destruction, Ail such documents and EIS must be retained. 2. Please notify us of the cmployees responsible for information technology/document retention, as well as all those with knowledge or information regarding the facts underlying the litigation matter. 3. A designee’ of our firm will talk with each person identified under the immediately: preceding paragraph 2 in order to understand his/her document retention practices so that this firm can comply with its duty to ensure proper retention and disclosure, as well as it duty to monitor the litigation bold. Insurance Coverage. If you have insurance policy(ies) that may provide coverage on this ‘ater, you should potify the insurer(s) in order to preserve any rights you may have to coverage and/or defanse costs. We would be happy to review your policies and advise of the possibility of such edverage, Joint Representation. This clause applies only if multiple parties are being represented under this Agreement. If at any time any of the Clients becomes aware of any conflict or potential conflict between their interests and those of other of the Clients, I ask that they immediately call that to my attention so that we can consider whether we can continue to represent any of the Clients in this case, In the event a dispute docs arise between any of the Cleats, the Firm may only be able to represent one of the parties in the dispute, and, under certain circumstances, we may be precluded from representing any party to the dispute. ‘Advance Waiver of Conflicts. The Firm represents many other companies and individuals. {tis possible, ifnot probable, that some of our present or furure clients could have disputes or transactions with you.. Therefore, as a condition to our undertaking this matter, you must agree that the Firm may continue to represent or may undertake in the future to represent existing or new clients in any matter that is not substantially related to our work for you, even if the interosts of such entities in those other matters are directly adverse to you. We agree, however, that your prospective consent to conflicting representation contained in this paragraph shall not apply in any instances where, as a result of our representation of you, we have obtained privileged, proprietary or other confidential information of a nonpublic natureWILENCHIK & BARTNESS A reorestionss CORPORATION — Advocates For Individuals With Disabilities, LLC July 18, 2016 Page 7 of 8 that, if known to such other entity, could be used in any such other matter by such entity to your material disadvantage. Documents. During the course of our representation, you may have occasion to provide us with documents and other materials from your files, At the end of our engagement, we will return the documents and materials to you in care of your office, or retain them as you direct. If'we are unable to reach you, and the documents and materials are not retumed to you, then ‘you agree that the documents may be destroyed after a reasonable period of time, to be ‘determined at our discretion but not to exceed three years in most cases. Confidentiality, All' work performed and materials and work product of any kind generated jm furtherance of the engagement will be deemed to be confidential and/or privileged ‘material. The Firm ‘will not reveal any such information, documents, materials or work product to any person except as directed or approved by you; however, the Firm may reveal such information pursuant to government process, Should you so direct, the Firm will undertake to challenge such process, provided that such challenge is permitted by law. ‘Termination of Engagement and Post-Engagement Matters, Either party may terminate ‘the engagement upon reasonable notice to the other for any reason, regardless if tral has been set, subject on our part to the applicable rules of professional conduct. Notice shall be made in writing and shall become effective upon receipt by the other perty. In the event that you or ‘we terminate the engagement, we will take such steps as are reasonably practicable to protect your interests in this matter. If you so request, we will suggest possible successor counsel to You and provide that counsel with whatever papers have been provided to us and that are ‘necessary for the protection and advancement of your interests. Unless previously terminated, our representation will terminate when a matter for which our firm was hired is completed, whether or not the final bill has been rendered or paid. Unless expressly stated in the attached agreement, our representation does not include an appeal of your tater, In the event of any termination, you shall promptly pay us in fall forall services rendered ‘nd forall charges and expenses incurred, In the event that we are forced to commence any legal proceeding against you in order to collect our fees or costs, the prevailing party in such litigation shall be entitled to full recovery of all costs and attorneys’ fees. ‘Should termination of the engagement occur for any reason, including failure to timely remit payment for fees, costs, services and/or agreed upon retainers, we shall have the authority hereby to withdraw from any pending litigation or matter regardless of whether trial has been set, and this agreement shall constitute your full consent for us to do so. Continuing Advice. You are engaging the Firm to provide legal services in connection with a specific matter. After completion of the matter, changes may occur in laws or regulations that ‘are applicable to you that could have an impact upon your future rights and liabilities. UnlessWILENCHIK & BARTNESS Advocates For Individuals With Disabilities, LLC July 18, 2016 1 Page 8 of 8 1 you continue to engige us to provide additional advice, this Firm will assume that it has no continuing obligationito advise you with respect to future legal developments. ‘Survival of Terms.(The agreements, terms and understandings set forth in this letter shall survive the terminatipn of any and all work performed. Lien, You hereby grant the Firm a lien on any and all recoveries for claims or causes of action that are the sibject of the representation under this agreement while our fees or costs are unpaid, even if You remove the matter to a new law firm, The lien will be for any sums owing 1o the Firm at the conclusion of the services performed. The lien will attach to any recovery you may obtain, whether by arbitration award, judgment, settlement or otherwise, ‘The effect of such alien is that the Firm may be able to compel payment of fees and costs from any such funds recovered on your behalf even if the Firm has been discharged before the end of the case. ' ‘Subpoenas. Should’ the Firm be subpoenaed for information that has been obtained as 2 result of the work performed, the Firm shall promptly notify you and follow your lawful directions regarding a response to the subpoena. You agree to pay, reimburse, indemnify ‘and/or hold the Firm harmless for charges, fees, costs, attorney's fees and disbursements that ‘may arise from responding to the subpoena. Arbitration, At tha option of the Firm, any disagrecment or controversy arising out of or relating to this Agreement and/or Engagement, including but not limited to any dispute concerning the Finn’s fees or expenses, shall be submitted for resolution to mediation and then arbitration. Jurisdiction, The parties consent to the jurisdiction of the federal, state, municipal and/or justice courts in Maricopa County, Arizona or the District of Arizona. No Advice Regarding This Fee Agreement. The Firm is not acting as your counsel in advising you with réspect to this letter, as we would have a conflict of interest in doing so. If you wish to be advibed by independent counsel on the question of whether you should be so epresented, we recommend that you consult with independent counsel of your choice, In ‘addition, if you have any questions or would like any additional information, we would be happy to discuss thif matter with you.WILENCHIK & BARTNESS —— A PROFESSIONAL: CORPORATION een EXHIBIT BDennis 1. Wilenchik diw@wb-law.com WILENCHIK & BARTNESS Licensed in A PROFESSIONAL ConrORATION Arizona, Texas ATTORNEYS AT LAW and New York ‘The Wilenchik & Bartaess Building 2610 North Thid Sweet Phoenix Arizona 85004 ‘Telephone: 602-606-2810 Facsimile: 602-606-2811 CONFIDENTIAL VIA EMAIL, Peter Strojnik ps@strojnik.com Re: Engagement of Wilenchik & Bartness, P.C. Dear Peter: We appreciate that you have asked Wilenchik & Bartness to provide legal services to you in connection with potentiaVexpected litigation arising out of your work with ‘Advocates for Individuals with Disabilities, and related entities (collectively, “AID”).' Consistent with our normal practice, this letter and the attached Statement of Engagement Terms (the “Statement”) set forth the terms of our engagement. It is important that you review the attached Statement so that you understand in advance how various issues will be handled. Your legal fees are being paid by a third party, AID. Both you and AID must understand that our ethical duties of confidentiality and communications are owed primarily to you, and not to the person paying the fees. Our representation is conditioned upon receipt of a signed copy of this letter confirming your understanding and approval of these terms. We do our best to see that our clients are satisfied not only with our services. If this letter and the attached Statement correctly set forth our mutual understanding, please sign and date the enclosed copy of this letter and return it to us with the attached Statement. We appreciate the opportunity to serve you and sincerely hope that our relationship ‘will be one of mutual trust and respect as well as of value and assistance to you. If you ever have any questions or concerns, I urge you to contact me. " Advocates for American Disabled Individuals, LLC; Advocates for Individuals with Disabilities Foundation, Inc veannnb Taw com Founded ia 1991WILENCHIK & BARTNESS Peter Strojnik, Esq. Page? of 6 Very truly yours, Dun ffllidede Dennis I, Wilenchik ‘THE TERMS OF THE ENGAGEMENT OF ‘THE FIRM AS STATED ABOVE AND IN THE ATTACHED STATEMENT ARE ACCEPTED AND APPROVED BY: Ge F Peter Strojnik, Esq. DATED:WILENCHIK & BARTNESS Peter Strojnik, Esq. Page 3 of 6 STATEMENT OF ENGAGEMENT TERMS Our representation is effective as of the date of the mutual execution of the attached agreement. We will undertake your representation and work with you to achieve the desired objectives in the most effective way that we can, mindful of costs, We will endeavor to use cour best judgment and skill in representing you. ‘We are bound by the Arizona Rules of Professional Conduct and may only advance causes and defenses that can be brought in good faith, based upon the facts and the established law. ‘Together, we necd to identify and review all documents that may be relevant to your defenses or to plaintiff's claims. We request your full cooperation and attention in this regard. All work performed and work product of any kind will be deemed to be confidential and/or privileged material. ‘You understand that we cannot and have not made any guarantee regarding the outcome of any matter, Comments made by any of the Firm’s attorneys anor staff concerning the outcome of a matter are expressions of opinion only. Staffing. I will have primary responsibility for the matter. Staffing decisions will be made by me. I may utilize other attorneys, paralegals and litigation/clerical assistants, with an end to providing services on an efficient and cost-effective basis, Client’s Responsibilities. We will try to keep you informed as to the status of our representation and as to the course of action which we are following or which is being recommended by us. We will make all written material sent or received by us reasonably available to you by way of copy, or you may examine the originals in our office at all reasonable times. Recognizing that the Firm cannot effectively represent you without your cooperation and assistance, you agree to cooperate fully with the Firm and to provide promptly all information known or available to you relevant to the Firm’s representation, including, without limitation, providing information and documents requested in a timely fashion; assisting in discovery, disclosure and trial preparation; cooperating in scheduling and related matters; responding {o telephone calls and correspondence in a timely manner; and informing the Firm of changes in your address and telephone numbers. Spoliation. Please be advised that both the Arizona and Federal Rules of Civil Procedure require all parties to litigation to preserve and disclose all information related to the case. Both parties and their counsel can be sanctioned for failing to preserve and disclose both hard-copy documents and electronically stored information, (“ESI”), ESI includes, but is not limited to, electronic mail, voice mail, text messages, and all documents and data sorted on computers, PDA's (Blackberries, iPhones, etc.) laptops, cell phones, and the like. ESI can also include data stored on personal hardware (home computers, personal cell phones, etc.) if used for work purposes. Therefore, it is important that such data not be deleted from yourWILENCHIK & BARTNESS Peter Strojnik, Esq, Page4of6 computers or networks, and that hardware in use during the relevant time period not be discarded. (Note: the litigation hold does not apply to inaccessible backup tapes tapes typically maintained solely for disaster recovery] unless the backup tapes are accessible or are actively used for information retrieval.) ‘You must suspend routine documents retention/destruction policies and put in place “litigation hold” to ensure preservation of relevant documents and EIS. As a rule of thumb, the litigation hold should be retroactive to your first contact with the opposing, party regarding the litigation matter and continuing through the present, We request, at a minimum, that the following steps be taken once the litigation hold is in place: 1. All destruction of documents of any type, including EIS, pertaining in any way to this matter must immediately stop even if your document retention policy would otherwise call for routine destruction, All such documents and EIS must be retained. 2. Please notify us of the employees responsible for information technology/document retention, a5 well as all those with knowledge or information regarding the facts underlying the litigation matter. 3. A designee of our firm will talk with each person identified under the immediately preceding paragraph 2 in order to understand his/her document retention practices to that this firm can comply with its duty to ensure proper retention and disclosure, as ‘well as it duty to monitor the litigation hold. Insurance Coverage. If you have insurance policy(ies) that may provide coverage on this ‘matter, you should notify the insurer(s) in order to preserve any rights you may have to coverage and/or defense costs. We would be happy to review your policies and advise of the possibility of such coverage, Joint Representation. This clause applies only if multiple partics are being represented under this Agreement. If at any time any of the Clients becomes aware of any conflict or potential conflict between their interests and those of other of the Clients, I ask that they immediately call that to my attention so that we can consider whether we can continuc to represent any of the Clients in this case. In the event a dispute does arise between any of the Clients, the Firm may only be able to represent one of the parties in the dispute, and, under certain circumstances, we may be precluded from representing any party to the dispute. Advance Waiver of Conflicts, The Firm represents many other companies and individuals, It is possible, if not probable, that some of our present or future clients could have disputes or transactions with you. Therefore, as a condition to our undertaking this matter, you must agree that the Firm may continue to represent or may undertake in the future to represent cxisting or new clients in any matter that is not substantially related to our work for you, even if the interests of such entities in those other matters are directly adverse to you. We agree,WB. WILENCHIK'& BARTNESS =n moresionae EOMORATION— Peter Strojnik, Esq. Page 5 of 6 however, that your prospective consent to conflicting representation contained in this paragraph shall not apply in any instances where, as a result of our representation of you, we have obtained privileged, proprietary or other confidential information of a nonpublic nature that, if known to such other entity, could be used in any such other matter by such entity to your material disadvantage, Documents, During the course of our representation, you may have occasion to provide us with documents and other materials from your files. At the end of our engagement, we will return the documents and materials to you in care of your office, or retain them as you direct, If we are unable to reach you, and the documents and materials are not returned to you, then ‘you agree that the documents may be destroyed after a reasonable period of time, to be determined at our discretion but not to exceed three years in most cases. Confidentiality. All work performed and materials and work product of any kind generated in furtherance of the engagement will be deemed to be confidential and/or privileged material. The Firm will not reveal any such information, documents, materials or work Product to any person except as directed or approved by you; however, the Firm may reveal such information pursuant to government process. Should you so direct, the Firm will undertake to challenge such process, provided that such challenge is permitted by law. ‘Termination of Engagement and Post-Engagement Matters, Either party may terminate the engagement upon reasonable notice to the other for any reason, regardless if tral has been set, subject on our part to the applicable rules of professional conduct. Notice shall be made in writing and shall become effective upon receipt by the other party. In the event that you or ‘we terminate the engagement, we will take such steps as are reasonably practicable to protect. your interests in this matter. If you so request, we will suggest possible successor counsel to ‘you and provide that counsel with whatever papers have been provided to us and that are necessary for the protection and advancement of your interests Unless previously terminated, our representation will terminate when a matter for which our firm was hired is completed, whether or not the final bill has been rendered or paid, Should termination of the engagement occur for any reason, including failure to timely remit payment for fees, costs, services and/or agreed upon retainers, we shall have the authority hereby to withdraw from any pending litigation or matter regardless of whether trial has been set, and this agreement shall constitute your full consent for us to do so. Continuing Advice. You are engaging the Firm to provide legal services in connection with a specific matter. After completion of the matter, changes may occur in laws or regulations that are applicable to you that could have an impact upon your future rights and liabilities. Unless you continue to engage us to provide additional advice, this Firm will assume that it has no Continuing obligation to advise you with respect to future legal developments.AYES j ! WILENCHIK’& BARTNESS Peter Strojnik, Esq. Page 6 of 6 Survival of Terms. The agreements, terms and understandings sot forth in this letter shall survive the termination of any and all work performed. Lien, You hereby grant the Firm a possessory lien on any and all recoveries for claims or causes of action that are the subject of the representation under this agreement while our fees or costs are unpaid, even if you remove the matter to a new law firm, The lien will be for any sums owing to the Firm at the conclusion of the services performed, The lien will attach to any recovery you may obtain, whether by arbitration award, judgment, settlement or otherwise. The effect of such a lien is that the Firm may be able to compel payment of fees and costs from any such funds recovered on your behalf even if the Firm has been discharged before the end of the case. Subpoenas. Should the Firm be subpoenaed for information that has been obtained as a result of the work performed, the Firm shall promptly notify you and follow your lawful directions regarding a response to the subpoena. Arbitration At the option of the Firm, any disagreement or controversy arising out of or relating to this Agreement and/or Engagement, including but not limited to any dispute concerning the Firm's fees or expenses, shall be submitted for resolution to mediation and then arbitration. J ‘The parties consent to the jurisdiction of the federal, state, municipal and/or justice courts in Maricopa County, Arizona or the District of Arizona. No Advice Regarding This Fee Agreement. The Firm is not acting as your counsel in advising you with respect to this letter, as we would have a conflict of interest in doing so. If you wish to be advised by independent counsel on the question of whether you should be so represented, we recommend that you consult with independent counsel of your choice. In addition, if you have any questions or would like any additional information, we would be happy to discuss this matter with you.ERD WILENCHIK. & BARTNESS — A PROFESSIONAL, CORPORATION — EXHIBIT CWILENCHIK & BARTNESS, PC ‘THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 85004 (602)606-2610 ‘August 03, 2016 Invoice submitted to FABIAN ZAZUETA, ADVOCATES FOR INDIVIDUALS WITH DISABILITIES 40 NORTH CENTRAL AVENUE. SUITE 1400 PHOENIX, AZ 85004 In Reference To: AIDIGENERAL, Invoice # 138826 Professional Services 71872016 DIW REVISE LETTER AND REVIEW E-MAILS; SEND E-MAILS AND ‘TELEPHONE CONFERENCE WITH CLIENT ahaa a (.5) OFFICE CONFERE? ZAZUETA AND D_ WILENCHIK | (1.0), PREPARE REVIEW Et ROGERS AND F, 8.0) 792016 JDW EXCHANGE E-MAILS WITH D. WILENCHIK, J. ROGERS AND F. 247 UE ER Se RS 7/28/2016 JOW TELEPHONE CONFERENCE WITH J. ROGERS aa Ps ai ad For professional services rendered Additional Charges 71312018 PHOTOCOPIES POSTAGE Total costs —Hours _Amount 00 200.00 2.00 800.00 4:50 900.00 070 140.00 0.30 60.00 8.00 $2,100.00 448 20.04 $24.22FABIAN ZAZUETA Page 2 Amount Total amount of this bill $2,124.22 Balance due $2,124.22 Professional Summary Name Hours __Rale __ Amount IDRIS eT ee 0 JOHN D. WILENCHIK 550 20000 $1,100.00 ‘Tax Identification #85-0688256 Previous balance of retainer 7/19/2016 Payment to account Now balance of retainerWILENCHIK & BARTNESS, PC ‘THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 85004 (602)606-2810 September 02, 2016 Invoice submitted fo FABIAN ZAZUETA, ADVOCATES FOR INDIVIDUALS. WITH DISABILITIES ATTENTION: FABIAN ZAZUETA fabian@aid.org | AZ {In Reference To: AIDIGENERAL, Invoice #139049 Professional Services 9/3/2016 DW RI AND E-MAIL J. ROGERS, F. ZAZUETA ‘AND P. STROJNIK| 8/4/2016 JDW Ea 8/5/2016 JOW REVIEW E-MAILS FROM J. ROGERS EXCHANGE E-MAILS WITH J. ROGERS AND F. ZAZUETA (isbn cnet 141 ON= CONFERENCE WITH F. ZAZUETA, A. CALLAN AND J. ROGERS 61072016 JOW EXCHANGE E-MAILS WITH E, ZAZUETA, | Jow maa EXCHANGE £-MAILS WITH G. ROBINSON 8/11/2016 JDW ==: 8/12/2016 DIW CONFERENCE IN OFFICE WITH CLIENTS AND FOLLOW UP WITH J. WILENCHIK Hours 0.30 1.80 2.00 0.40 020 0.40 1.60 Amount 60.00 320.00 400,00 80.00 40.00 640.00FABIAN ZAZUETA 8/12/2016 JDW OFFICE CONFERENCE WITH P. STROJNIK, A. CALLAN, J. ROGERS: ik Ra Soe AND F. ZAZUETA, D. WILENCHI 8/15/2016 JOW REVIEW E-MAIL FROM F. ZAZUETA Sa aaccaeaes OW EMA Ss a \. aa 8/16/2016 JOW REVIEW E-MAILS TO/FROM A1D; SSS (RRB. EXCHANGE E-MAILS WITH F. ZAZUETA, ET AL, 8242016 OW E-MAILS SS Di Revi vy RS Se SS SST JDW EXCHANGE EMAILS WITH D. WILENCHIK, P, STROJNIK, A. CALLAN [.5); REVIEW 1.5) 8/25/2016 DIW FOLLOW UP [aaa E-MAILS AND TELEPHONE. CONFERENCE WITH CLIENTS; REVIEW Soa spw EMAILS REGARDING ND E-MA 8/26/2016 DIW, ee keer? RES OW Rev Se a JOW LEGAL RESEARCH Ayo Tee one OMe eee el Page 2 Hours 1.50 3.70 0.30 260 0.30 440 0.30 0.30 2.00 1.00 3.70 0.30 1.50 1.40 8.80 Amount 300.00 740.00 120.00 620.00 60.00 880,00 120.00 120.00 400.00 400.00 740,00 120.00 600.00 280.00 4,760.00FABIAN ZAZUETA 872912016 JDW 8/30/2016 DIW CONFERENCE WITH J. WILENCHIK AND E-MA|_S a ENCE WITH F. ZAZUETA REVIEW (RBBB AND OFFICE iLENCHIK] 4.8); @a) 6172016 DW EMA. a a DIW MEETING! ; REVIEW NE CALL DIW TELEPHONE CONFERENCE WITH CLIENTS AND J. WILENCHIK AND FOLLOW UP. JDW TELEPHONE CONFERENCE WITH F. ZAZUETA, P.STROUNIK, G. (CRANE AND D. WILENCHIK| OFFICE CONFERENCE WITH D. WILE AND For professional services rendered sow ‘Adiional Charges : 31/2016 + - PHOTOCOPIES POSTAGE, Total costs Total amount of this bill Previous balance 8/31/2016 COURTESY ADJUSTMENT PER DIW Total payments and adjustments Balance due Page 3 — Hours _Amount 4.00 800.00 040 180.00 4.40 820.00 020 80.00 1.80 600,00 0.50 200.00 110 220.00 560.40 $11,660.00 946 58.23 $67.69 $14,727.69 $2,124.22 ($1,660.00) ($1,660.00) $12,191.91FABIAN ZAZUETA t Professional Summary JOHN D, WILENCHIK Tax Identification #86-0688256 Previous balance of retainer Now balance of retainer Hours Rate Page 4 ‘Amount 730 40000 ~$3,760.00 4250 200.00 ‘$8,600.00 Amount $6,000.00WILENCHIK & BARTNESS, PC ‘THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 85004 (602)868-2810, October 07, 2016 Invoice submitted to: FABIAN ZAZUETA, ADVOCATES FOR INDIVIDUALS. WITH DISABILITIES ATTENTION: FABIAN ZAZUETA fabian@ald.org AZ In Reference To: AIDIGENERAL Invoice #199265, Professional Services 9/1/2018 ASD REVIEW/PRINT DOCUMENTS, ORGANIZE WORKING NOTEBOOK FOR D. WILENCHIK vs zn E-MAIL J, WILENCHIK AND OTHERS JOW EXCHANGE E-MAILS WITH AID] REVI TIPLE RENCES WITH F. ZAZUETA al 97972016 BH EXCHANGE E-MAILS WITH J, WILENCHk SSS za JDW RESEARCH| 2142016 OW OF AF 82016 6M OA 2) LEGAL RAC aac a Hours 0.80 030 4.70 0.20 430 10.20 490 3.60 Amount 108.00 45.00 382.50 40,00 967.50 2,296.00 980.00 720.00FABIAN ZAZUETA 91672018 JOW RESEARCH| Vs FOLLOWUP ON SS LF ORFIGE CONFERENCE WITH J WILE NcHiG 3) + SSeS DIW EMAILS! aa") 7 oe ‘AND C. FERREIRA ii es (+) VS FORMAT a LUF EXCHANGE EMAILS AND OFFICE CONFERENCE WILENCHIK (3); LEGAL RESEARCH AND OW WORK ©. EE 9182016 BH REVISE (9), RESEARCH : PAILS WITH J. PML ENCHIk AND CLIENTS aa in Seca ON Bey Ss ECR eee i Sina ‘NAD 00 2 er EE oe LUF EXCHANGE EMAILS AND OFFICE CONFERENCE WITH J. WILENCHIK| (3); LEGAL. RESEARCH| MAIL. J, WILENCHIK Page 2 Hours 12.70 0.30 3.50 0.50 0.40 1.80 4.00 2.00 4.40 260 450 1.20 230 Amount 2,857.50 45,00 875.00 200.00 160.00 243.00 160.00 1500.00 ‘990,00 520,00 4,012.50 270.00 575.00FABIAN ZAZUETA 97972016 BH sow WF 911072016 BH sow 912016 JOW ow UF 91372016 JOW UF 9142016 JOW WF 911572016 BH sow 3) ao ae REVISE AND FINALIZE| TELEPHONE: CONFERENCE WITH F. mTHG. EXCHANGE E-MAILS WITH J. WILENCHIK AND CLIENT EXCHANGE E-MAILS WITH J. ca RE Fe mn REVIEW) ‘AID REVIEW AND SEND E-MAILS SSS EXCHANGE E-MAILS WITH J. WILENCHIK AND CLIENT LEGAL RESEARCH AND TELEPHONE CONFI ee TELEPHONE CONFERENCE WITH OPP EL REVIEW E-MAILS BETWEEN J, WILENCHIK AND CLIENTS il RESEARCH AND DRAFT| BBR C.4) LECAL Res OFFICE CONFERENCE WITH J. WILENCHIK AND REVIEW es 4); LEGAL RESEARCH} (8); FERENCE WITH J WIL 7 EXCHANGE EMAILS AND OFFICE CONFERENCE WITH J. WILENCHIK} (4); RESEARCH OFFICE CONFERENCE WITH D. WILENCHIK TELEPHONE CONFERENCE WITH AID EXCHANGE EMAILS Sa Hours 1.70 610 0.20 0.80 0.40 0.30 0.10 6.00 0.20 7.90 1.20 1.10 2.30 Page 3 Amount 340.00 1,372.50 60.00 20.00 180.00 90.00 120.00 25.00 1,350.00 0.00 4,777.50 300.00 20.00 517.50FABIAN ZAZUETA 911612016 JOW UF 9/17/2016 DIW 971972018 JOW UF 972012016 BOK BH sow LF 9/21/2016 ASD ee E-MAIL A. CALLAN AND F. ZAZUETA OFFICE CONFERENCE WITH L. FELDER] OFFICE CONFERENCE WITH J. WILENCHIK AND LEGAL RESEARCH| E-MAILS WITH J. WILENCHIK AND CLIENT on Ra po EXCHANGE EMAILS AND TELEPHONE CONFERENCE WITH J. WILENCHIK (4); REVIEW E-MAILS (1), DRAFT AND REVISI ID EXCHANGE E-MAILS Srisca Research 20 RE was (2.4) OFFICE CONFERENCE WITH J WLENCHIC B HEED AND L. FELDER (1.0), LEGAL RESEARCH ce, (2.9); Rt = J. a OFFICE CONFERENCE WITH J. WILENCHIK AND L. FELDER RESEARCH| JAND OFFICE CONFERENCE WITH B. KAN (2.0): OFFI S Sa a STE (1.6) EXCHANGE E-MAILS WITH J. WILENCHIK (1); OFFICE CONFERENCE WITH J. WILENCHIK, B. HEMBD AND B. KAMINSK! (1.0); LEGAL RESEARCH AND EXCHANGE E-MAILS WITH J ama cei igs =e DRAFT] 0.80 2.00 0.20 10.60 3.60 4.40 4.00 3.60 3.00 4.20 180.00 00.00 80.00 2,386.00 875.00 550,00 200.00 810.00 750.00 4162.00FABIAN ZAZUETA 92112018 BOK sDw LF 19/22/2016 BDK sow IW UF BH 9123/2016 BDK sow BH ASD UF 9724/2016 BH CONTINUE LEGAL RESEARCH 1.6), DRAFT] 4.4) DRAFT] EXCHANGE E-MAILS WITH J. WILENCHIK AND CLIENT (2) DRAFT| REVISE| 1.2), REVIEW egeatl 0 °° E-MAILS, REVIEW| (9); REVISE | EXCHAI HANGE E-MAILS AND OFFICE CONFERENCE WITH J. WILENCHIK 2): LEGAL EXCHANGE LEGAL RESEARCH DRAFT) F CHANGE = "A, CALL EXCHANGE E-MAILS WITH J, WILENCHIK AND D. WILENCHIK 2): RESEARCH| (25) FINALIZE) 1 TS TT CONTINUE LEGAL Soc a ea 05 ora a IAILS WITH CLIENTS AND J. WILENCHIK Hours 6.00 13.20 070 4.10 8.40 2.50 0.30 0.60 6.00 2.70 0.50 3.10 Page 5 Amount 750.00 2,970.00 475.00 512.50 1,890.00 625.00 60.00 75.00 4,350.00 540.00 125.00 620.00FABIAN ZAZUETA Page 8 Hours __Amount 9125/2016 BH CONTINUE DRAFT| 240 420.00 EXCHANGE E-MAIL 3) 9/26/2016 BH Rat eo ae 8), EXCHANGE EMAILS 3.10 620.00 AND Tt HJ. WILENCHIK (3) ee 130 17860 80K LEGAL RESEARCH] 1.90 297.50 JOW EXCHANGE E-MAILS WITH ADE LOS ANGELES FR 8.90 2,002.60 (4), EXCHANGE E-MAILS WITH OPI VS ASSISTC. WOEHLER WITH DOCKETNG ey i iil eee LIF EXCHANGE E-MAILS WITH J. WILENCHIK AND B, KANINSK! 030 75.00 (2) ore7m016 ASD REVISE 350 472.50 ze BH EXCHANGE E-MAILS WITH J. WILENCHK Sa 050 10000 BDK CONTINUE 3.90 487.60 JOW TELEPHONE CONFERENCE WITH F. ZAZUE I 5.70 1,282.60 ‘AND OFFICE C TH (1.0); REVISE| a LJF REVIEW OFA Ie 2), EXCHANGE 0.50 125.00 E-MAILS WITH 8 KAMINSK!FABIAN ZAZUETA 9728/2016 BDK CONTINUE LEGAL RESEARCH] 12.00 2,700.00 sow (5), PREPARE (85) 92972016 JOW ATTEND| CONFERENCE 750 1,687.50 SAME, BOK ATTEND 2.60 NO CHARGE a3) 9/30/2016 JOW EXCHANGE EMAILS AND OFFICE CONFERENCE WITH B 1180 405.00 BOK LEGAL RESEARCH| 240 30000 (3) For professional services rendered 240.60 $49,549.00 Additional Charges 97302018 PHOTOCOPIES 136.18, COURT FILING FEES 384.00 POSTAGE 2a HEARING TRANSCRIPTS 478.00 WesTLAW 581.84 Total costs "$4,581.79 Total amount ofthis bill $51,130.78 $12,191.91 Previous balanceFABIAN ZAZUETA Page 8 Amount 19/29/2016 Payment - thank you ($5,000.00) 9/30/2016 COURTESY ADJUSTMENT PER DIW ($4,549.00) Total payments and adjustments ($9,549.00) Balance due $53,773.70 Professional Summary Name Hours __Rate __Amount AILEENS, DE LOS ANGELES ‘40 73500 ~ $7,269.00 BRIAN HEMBD 3050 200,00 $6,100.00 BROCK D. KAMINSK 30.80 12500 $3,850.00 260 0.00 $0.00 BROCK D. KAMINSKI DENNIS |. WILENCHIK JOHN D. WILENCHIK LARRY J, FELDER VICTORIA STEVENS 170 400.00 $680.00 14100 225.00 $34,725.00 2250 250.00 $5,625.00 2.00 150.00 $300.00 ‘Tax Identification #86-0688256 Previous balance of AID $5,000.00 91202016 Payment to account 35,000.00, New balance of AID $10,000.00 Total Cost and Fee History Total Fees $13,760.00 Total Costs 01.91WILENCHIK & BARTNESS, PC ‘THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 85004 (602/606-2810 November 04, 2016 Invoice submitted to: FABIAN ZAZUETA ADVOCATES FOR INDIVIDUALS. ‘WITH DISABILITIES ATTENTION: FABIAN ZAZUETA fabian@attong In Reference To: AIDIGENERAL, Invoice #199371 Professional Services 0000 0% 5 JOW LEGAL RESEARCH| 10/4/2016 JOW OFFICE CONFERENCE WITH H. 5s ee 40/5/2016 BH EXCHANGE E-MAILS WITH J. WILENCHIK AND D. WILENCHIK OK FV JOW REVIEW] JAND TELEPHONE ‘CONF! IGE E-MAILS WITH D. WILENCHIK AND B. HEMD| 2); RESEARCH AND DRAFT| OW REV ER #0 FOLLOW UP TH J. WILE! Hours 9.10 1.60 40 020 5.80 0.30 Amount 2,047.50 360.00 80.00 25.00 1,305.00 420.00FABIAN ZAZUETA 1016/2016 BH LEGAL RESEARCH (3.2); EXCHANGE EMAIL Ichik’ (8) JOW EXCHANGE E-MAILS WITH OppOSING COUNSE| II 1): TELEPI VS EXCHANGE E-MAILS WITH C. WOEHLER REGARDING DOCKETING J0r7r20%6 JOW &-MAlL F, 2AZUETA [i fortogo%6 BH LEGAL RESEARCH RRR AND EXCHANGE EMAILS AND TELE! WITH J, WILENCHIK JOW OFFIC CONFERENCE WITH 8, HEN 00 ag ‘AND TELEPHONE CONFERE RESEARCH AND REVISE| 40/11/2016 JOW eae RE AY) 280s: RAR Af RENCE Wi EAL °. 5120 he rc (1.7) REVIEW ES 10/12/2016 JOW REVISE} TOS TELEPHONE CONFERENCE WITH J. WILENCHIK ey ZUETA AND A. CALLAN] com TELEPHONE CONFERENCE WITH F i revs JAND E: N ZAZU XCHANGE E-MAILS WITH F. ZAZUETA| 13.2) 10/14/2016 VS ASSIST C. WOEHLER WITH DOCKETING Hours __ 3.70 6.80 0.30 oto 0.40 450 1.40 3.60 0.20 Pago 2 Amount 740.00 4,530.00 45.00 2.50 80.00 4,012.60 562.50 316.00 787.50 30.00FABIAN ZAZUETA, 107142016 O1W © As JDW RESEARCH! REVIEW E-MAIL FROM A. CALLAN] AND E-MA 10/17/2016 JDW EXCHANGE E-MAILS WITH F. ZAZUETA AND A. CALLAN FERENCE JOW ORAFT [REI (1.1 - NO CHARGE) VS peppercorns oer DOCKETING EE 10/18/2016 JOW REVISE AND FINALIZE | SS {oR92018 JOW EXCHANGE E-MAILS WITH C, FeR =i ER "AND EXCHANGE E-MAILS WITH (4); REVIEW IGE WITH J. WALSH AND E-MAIL A. CALLAN, ET AL, SASS 5) JOW EXCHANGE E-MAILS WITH A. CALLAN [SS BBB (4 No CHARGE} 10/21/2016 JDW REVIEW E-MAILS FROM F. ZA ND TELEPHONE, CONFERENCE WITH SANE | torzai2016 JDW 10/25/2016 JOW DRAFT E-MAIL TO AlD| AND EXC! "| TELEPHONE CONFERENCE WITH F. rar avo REVISE Ct eee Page 3 Hours __Amount 030 120,00 320 720.00 390 877.60 4.10 NO CHARGE 0.40 60.09 a a 060 13500 0.40 NO CHARGE 1.00 22500 610 1,372.50 230 517.50FABIAN ZAZUETA Page 4 Hours __ Amount 10262018 OW TELEPHONE CONFERENCE WITH. ZAZUETA 100 22500 7S IeLEPrione Cont eee By TELEDIIONE CONFERENCE 4027/2016 JOW TELEPHONE CONFERENCE WITH OPPOSING COUNSEL 360 810.00 ‘AND TELEPHONE CONFERENCE WITH TELEPHONE CONFERENCE WITH E. , REVISE! a6 voc 0 rou concn ie oe oy 101312016 JOW ORY SS 800 1.80000 For profesional services rndered aa sane Additional Charges 1031/2018 = WESTLAW 29.17 PACER COURT SERVICE 23.60 COURT FILING FEES 44.00 PHOTOCOPIES 1452 Total costs $114.29 Total amount of this bill $18,168.79 Previous balance $63,773.70 10/31/2016 Payment - thank you ($5,000.00) 10/31/2016 Payment from account ($10,000.00) Total payments and adjustments ($45,000.00) Balance due $56,042.49Page 5 FABIAN ZAZUETA Professional Summary Name Hours _ Rate ___Amount BRIAN FEI —0.0T BROCK D. KAMINSKI 2.60 12500 $312.60 DENNIS I WILENCHIK 0.60 400.00 $240.00 JOHN D, WILENCHIK 71.80 226.00 $16,185.00 JOHN D: WILENCHIK 150 0.00 $0.00 TYLER Q, SWENSEN 140 22500 $315.00 VICTORIA STEVENS 090 150.00 $135.00 ‘Tax Identification #86-0688256 Amount Previous balance of AID {$10,000.00 40/31/2016 Payment from account ($10,000.00) New balance of AID $0.00 Total Cost and Fee History Total Fees $63,634.00 Total Costs $1,673.70WILENCHIK & BARTNESS, PC ‘THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 86004 (602)608-2810, December 06, 2016 Invoice submitted to: FABIAN ZAZUETA ‘ADVOCATES FOR INDIVIDUALS WITH DISABILITIES ATTENTION: FABIAN ZAZUETA fabian@aid.org AZ In Reference To: AIDIGENERAL Invoice #138392 Professional Services 11/1/2016 JOW E-MAIL E, ZAZUETAI NSE 63) 11272016 JDW TELEPHONE CONFERENCE WITH E. ZAZUETA 111972016 JOW ATTEND] 11142016 JOW REVISE| AND TELEPI 1172016 JOW EXCHANGE E-MAILS WITH F. ZAZUETA AND OPPOSING COUNSEL 4118/2016 JOW REVIEW ORDER| AND E-MAIL F. ZAZUE “MATL FROM OPPOSING COUNSt 411972016 JOW EXCHANGE E-MAILS WITH F. ZAZUETA| Wm Review EMAILS (1.2) Hours _Amount 640 1,440.00 2.50 962.50 2.60 85.00 1.70 382.50 040 22.50 130 202.50FABIAN ZAZUETA 11/16/2018 JDW REVIEW} AND Di 11/1772018 JDW TELEPHONE CONFERENCE WITH A. CALLAN AND E. ZAZUETA (4); REVISE| 11/18/2016 JOW EXCHANGE E-MAILS WITH E. ZAZUETA| Eee 11212018 JOW EXCHANGE E-MAILS WITH F, ZAZUETA SESS 1112312016 JOW EXCHANGE E-MAILS WITH F. ZAZUETA ee (1-4); REVI 9) 11/28/2016 JOW REVIEW| RESEARt 112912018 JDW TELEPHONE CONFERENCE WITH F. ZAZUETA AND A. CALLAN VS ASSIST C. WOEHLER WITH DOCKETING For professional services rendered ‘Additional Charges +1902018 PHOTOCOPIES COURT FILING FEES Total costs Total amount of this bill Previous balance Balance due Page 2 Hours _ Amount 4.40 990.00 4.00 225.00 040 90.00 o10 22.50 330 742,50 4.00 225.00 040 90,00 040 80.00 44.40 $9,217.50 8.60 44.00 ‘$50.60 $9,268.10 $56,942.49 $66,210.59,Page 3 FABIAN ZAZUETA Professional Summary Nome Hours __Rate ___ Amount SOHND- WENCH ay 7g 2500" —30,187 80, VICTORIA STEVENS 0.40 150.00 $60.00 Tax Identification #66-0688255, Total Cost and Fee History Total Fees $82,029.00 Total Costs $1,784.99WILENCHIK & BARTNESS, PC THE WILENCHIK & BARTNESS BUILDING 2810 NORTH THIRD STREET PHOENIX, AZ 86004 (602)606-2810, January 05,2017 Invoice submited to: FABIAN ZAZUETA ADVOCATES FOR INDIVIDUALS WITH DISABILITIES: ATTENTION: FABIAN ZAZUETA {abian@aid.org AZ In Reference To: AIDIGENERAL Invoine # 139528 Professional Services 12722016 JOW TELEPHONE CONFERENCE WITH F. ZAZUETA 12442016 JOW DRAFT SSRI AND E-MAIL F. ZAZUETA SR 4215m2016 JOW TELEPHONE CONFERENCE WITH E, ZAZUETA AND C BROADBENT| BM assisty, stevens! VS _ WORK ON SSS 12/6/2018 JDW TELEPHONE CONFERENCE WITH E. ZAZUETA AND C. BROADSENT| 3); EXCHANGE (4) ‘AND PREPARE BB ( Hours 040 7.40 070 a 2.70 070 3.10 Amount 90.00 1,685.00 187.50 = 1405.00 187.50 485.00FABIAN ZAZUETA | r ASD. DRAET] ke a (3) Page 2 Hours _Amount 12/8/2016 JOW REVISE| JAND TELEPHONE 590 1,327.50 CONFES ASD REVISE] REVISE | (1.3); REVIEW AND 3a0 445.50 2), EXCHANGE E-MAILS ° eke ie 12792016 JOW EXCHANGE EMAILS AND TELEPHONE CONFERENCE WITH F. 60 13500 ZAZUETA F REVIEW SAME AND EXC! A zL ASD CONTINUE TO REVISE! 2.90 91050 Heme vs REVISE 4.00 150.00 For professional services rendered Additional Charges 12/30/2016 COURT FILING FEES 12/31/2016 PHOTOCOPIES: WESTLAW Total costs Total amount of this Previous balance 36.40 $6,391.00 12.00 3.08 36.05 $51.13 $6,442.13, $66,210.59Page 3 FABIAN ZAZUETA Amount Balance due $72,852.72 Professional Summary Name Hours Rate ___Amount AILEEN'S. DE LOS ANGELE 650 735.00 ——$887.00 JOHN D. WILENCHIK 1570 226.00 $3,532.60 MONICA RAPPS 440 126.00 $512.60 VICTORIA STEVENS 970 150.00 $1,455.00 “Tax Identification #86-0688256 Total Cost and Fee History oo * ees, 391,246.50 Total Costs $1,835.59WILENCHIK & BARTNESS = A PRORESSIONL! CORPORATION — — EXHIBIT DFrom: Alex Callan {mailto:alex@alexcalian.com] Sent: Thursday, December 29, 2016 11:29 AM To? Lisa Lofti; fablan@aid.ora Subject: RE: Payment Ms. loftis, Thank you for your message. We are not ina position to make a payment at this time. We are working ‘to make a payment as soon as possible. Thank you, Alex Callan From: Lisa Lofts (malltoxisal@wblaw.com)} Sent: Thursday, December 29, 2016 10:10 AM To: fabian@aid.org; Alex Callan (alex@aid.org) Subject: Payment Importance: High Gentlemen - | am writing again requesting that you hold up to your agreement of at least $5,000.00 per month to get our fees paid. So far, my emails have gone unanswered. Ineed to hear from you today please. Lisa Lofts ‘Administrative Assistant lisal@wb-law.com ‘The Wilanhik& Barness ung 2840 Nort Ti Set Phoenix, Azone 85004 802-608-2810 F 602-s00.2811 ‘wonw.wb-law.com ATTORNEY/CLIENT COMMUNICATION “The information transmitted by this e-mail i intended only for the addressee and may contain confidential and/or privileged material. Any interception, review, retransmission, dissemination or other use ofthis information by persons or entities other than the intended recipient is prohibited by law and may subject them to eriminal or civil liability. 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