Professional Documents
Culture Documents
Houmand Fee Application
Houmand Fee Application
1 Jacob L. Houmand, Esq. (NV Bar No. 12781) Electronically Filed On: February 9, 2021
Email: jhoumand@houmandlaw.com
2 Bradley G. Sims, Esq. (NV Bar No. 11713)
Email: bsims@houmandlaw.com
3 HOUMAND LAW FIRM, LTD.
9205 West Russell Road, Building 3, Suite 240
4 Las Vegas, NV 89148
Telephone: 702/720-3370
5 Facsimile: 702/720-3371
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8 UNITED STATES BANKRUPTCY COURT
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 DISTRICT OF NEVADA
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
23 The Houmand Law Firm, Ltd. (the “Firm”), counsel of record for Shelley D. Krohn,
24 Chapter 7 Trustee in the above-captioned bankruptcy case (the “Trustee”), hereby submits its
25 First and Final Application of Houmand Law Firm, Ltd. for Allowance of Compensation for
26 Services Rendered During the Period From December 22, 2016 through February 8, 2021 and
27 For Reimbursement of Expenses Pursuant to 11 U.S.C. §§ 330 and 331 and Federal Rule of
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2 The Fee Application is filed pursuant to Sections 330 and 331, FRBP 2016, the Guidelines
4 Offices of the United States Trustee (the “Region 17 Guidelines”), and the Guidelines for
6 U.S.C. § 330 effective January 30, 1996 (the “U.S. Trustee Guidelines”). The Application is also
7 based on the following Memorandum of Points and Authorities, the Declaration of Shelley D.
8 Krohn In Support of First and Final Application of Houmand Law Firm, Ltd. for Allowance of
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 Compensation for Services Rendered During the Period From December 22, 2016 Through
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 February 8, 2021 and For Reimbursement of Expenses Pursuant to 11 U.S.C. §§ 330 and 331 and
HOUMAND LAW FIRM, LTD.
11 Federal Rule of Bankruptcy Procedure 2016 (the “Trustee Declaration”), and the Declaration of
12 Jacob L. Houmand, Esq. In Support of First and Final Application of Houmand Law Firm, Ltd.
13 for Allowance of Compensation for Services Rendered During the Period From December 22,
14 2016 Through February 8, 2021 and For Reimbursement of Expenses Pursuant to 11 U.S.C. §§
15 330 and 331 and Federal Rule of Bankruptcy Procedure 2016 (the “Houmand Declaration”), both
16 of which are filed separately and concurrently with this Court pursuant to Local Rule 9014(c)(2).2
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24 1
Unless otherwise indicated, all chapter and section references are to the Bankruptcy Code, 11
25 U.S.C. §§ 101-1532, and to the Federal Rules of Bankruptcy Procedure, Rules 1001-9037. The
Federal Rules of Civil Procedure will be referred to as “FRCP” and the Federal Rules of
26 Bankruptcy Procedure will be referred to as “FRBP.” The Local Rules of Practice for the United
States Bankruptcy Court for the District of Nevada shall be referred to as the “Local Rules”.
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All references to “ECF No.” are to the numbers assigned to the documents filed in the case as
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they appear on the docket maintained by the clerk of the court.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 3 of 19
1 The Fee Application is also based on the pleadings and papers on file herein and any
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By: /s/ Jacob L. Houmand
6 Jacob L. Houmand, Esq. (NV Bar No. 12781)
Bradley G. Sims, Esq. (NV Bar No. 11713)
7 9205 West Russell Road, Building 3, Suite 240
Las Vegas, NV 89148
8 Telephone: 702/720-3370
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
Facsimile: 702/720-3371
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Telephone: (702) 720-3370 Facsimile: (702) 720-3371
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The Firm also requests that the Court take judicial notice of all pleadings filed in the above-
referenced bankruptcy case, including adversary proceedings, pursuant to Rule of Evidence 201,
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incorporated by reference by FRBP 9017.
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3
Date of Retention: December 22, 20164
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6 Period for which Compensation and December 22, 2016 through February 8, 2021
Reimbursement is Sought
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8 Amount of Compensation Requested: $303,267.50
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
Requested:
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HOUMAND LAW FIRM, LTD.
26 On March 20, 2018, the Court entered an Order Granting Ex Parte Application to Employ
Houmand Law Firm, Ltd., Numc Pro Tunc As General Bankruptcy Counsel for Shelley D. Krohn,
27 Chapter 7 Trustee Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Federal Rule of Bankruptcy
Procedure 2014 [ECF No. 308] that employed the Firm effective as of January 19, 2018, the
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appointment of the Trustee as the successor Chapter 7 Trustee in the Debtor’s bankruptcy case.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 5 of 19
1 BILLING SUMMARY
3 Fees
Fees Previously Requested 0.00
4 Fees Previously Awarded 0.00
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Expenses
6 Expenses Previously Requested 0.00
Expenses Previously Awarded 0.00
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Retainer Paid: 0.00
8 Drawn on Retainer: 0.00
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
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HOUMAND LAW FIRM, LTD.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 6 of 19
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14 Blended Hourly Rate: $319.70
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19 TOTAL $303,267.50
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 8 of 19
2 I.
3 INTRODUCTION
4 The Firm, counsel of record to the Trustee in the above-captioned chapter 7 case (the
5 “Bankruptcy Case”), hereby submits this First and Final Fee Application for services rendered in
6 the Bankruptcy Case during the period from December 22, 2016 through February 8, 2021 (the
7 “Fee Application Period”). The Firm requests an order: (i) approving and allowing on a final
8 basis compensation in the amount of $303,267.50 for the reasonable and necessary services of the
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 Firm during the Fee Application Period; (ii) approving and allowing on a final basis
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 reimbursement of expenses in the amount of $12,720.39 that were incurred during the Fee
HOUMAND LAW FIRM, LTD.
11 Application Period; and (iii) authorizing the Trustee to pay such amounts to the Firm. The Firm
12 believes that the services it rendered to the Trustee during the Fee Application Period benefited
13 the Debtor’s estate and that, therefore, the attorneys’ fees and costs requested in this Fee
14 Application should be approved under Section 330(a). The Trustee is currently holding funds in
15 the amount of $528,211.49.5 Throughout the administration of the Debtor’s bankruptcy case, the
17 II.
19 1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1134.
20 This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A). The statutory basis for the relief
21 sought are Sections 330, FRBP 2016, and Local Rule 2016. Venue before this Court is
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25 This number does not include approximately $156,425.00 which is due but not yet received by
the Debtor’s bankruptcy estate pursuant to the Amended Order Granting Motion to Approve
26 Compromise Pursuant to Federal Rule of Bankruptcy 9019 [ECF No. 525] entered by the Court
on January 15, 2021. The Trustee is also awaiting a payment in the amount of approximately
27 $3,971.48 from the Chapter 7 Trustee appointed in the bankruptcy case filed by Linda Graham in
Colorado. After these payments are received, the Trustee will be holding approximately
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$688,607.97.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 9 of 19
2 Local Rule 9014.2, if the Court determines that absent consent of the parties the Court cannot
3 enter final orders or judgment regarding the Application consistent with Article III of the United
4 States Constitution, the Firm consents to entry of final orders and judgment by this Court.
5 III.
9 rendered by the Firm, and it is not meant to be a detailed description of all of the work performed.
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 Detailed descriptions of day-to-day services provided by the Firm and the time expended
HOUMAND LAW FIRM, LTD.
11 performing such services is fully set forth in the billing summary, true and correct copies of which
13 5. Detailed descriptions of the actual expenses incurred by the Firm during the Fee
15 IV.
18 Application, identifying the Firm and amounts requested, has been served on all identified
19 creditors and parties in interest not less than 28 days prior to the date set for hearing on this Fee
20 Application.
21 V.
24 Employ Nelson & Houmand, P.C., Nunc Pro Tunc, As General Bankruptcy Counsel for Victoria
25 L. Nelson, Chapter 7 Trustee Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Federal Rule of
26 Bankruptcy Procedure 2014 [ECF No. 35] (the “First Employment Application”).
27 8. The First Employment Application sought to employ the Firm nunc pro tunc as of
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 10 of 19
1 9. On March 23, 2017, the Court entered an Order Granting the Application to
2 Employ Nelson & Houmand, P.C., Nunc Pro Tunc, As General Bankruptcy Counsel for Victoria
3 L. Nelson, Chapter 7 Trustee Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Federal Rule of
5 10. On October 17, 2017, the Firm filed a Notice of (1) Change of Firm Name and (2)
6 Change of Address [ECF No. 263] that stated the name of the Firm had changed from “Nelson &
9 12. On January 19, 2018, the Trustee was appointed as the successor Chapter 7 Trustee
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
11 13. On March 19, 2018 the Trustee filed an Ex Parte Application to Employ Houmand
12 Law Firm, Ltd. As General Bankruptcy Counsel, Nunc Pro Tunc, for Shelley D. Krohn, Chapter 7
13 Trustee Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Federal Rule of Bankruptcy Procedure
15 14. The Second Application to Employ sought to employ the Firm effective as of
16 January 19, 2018, the date of the appointment of the Trustee as successor Chapter 7 Trustee.
17 15. On March 20, 2018, the Court entered an Order Granting Ex Parte Application to
18 Employ Houmand Law Firm, Ltd. As General Bankruptcy Counsel, Nunc Pro Tunc, for Shelley D.
19 Krohn, Chapter 7 Trustee Pursuant to 11 U.S.C. §§ 327(a) and 328(a) and Federal Rule of
21 16. The scope of the Firm’s employment in this bankruptcy case was as follows:
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 11 of 19
8 17. The results achieved during the Fee Application Period encompassed by this Fee
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 Application relate to the scope of employment set forth in this Fee Application and are set forth in
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 more specific detail in the billing entries attached as Exhibit “1” to the Houmand Declaration.
HOUMAND LAW FIRM, LTD.
11 18. The actual expenses incurred by the Firm during the Fee Application Period are set
12 forth in more specific detail in the billing entries attached as Exhibit “1” to the Houmand
13 Declaration.
14 19. During the time in question, the Firm has assisted the Trustee in those items
15 detailed in the “Scope of Employment” of the Employment Application and other miscellaneous
16 functions.
17 20. The Firm’s services were rendered economically and without unnecessary
18 duplication of efforts. In addition, the work involved, and thus the time expended, was carefully
19 assigned in consideration of the experience and expertise required for each particular task. If
20 more than one person attended a meeting or hearing, it was not a duplication of that effort, but it
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 12 of 19
1 VI.
3 BANKRUPTCY ESTATE
4 20. On December 15, 2016, an Involuntary Bankruptcy Petition [ECF No. 1]6 (the
5 “Involuntary Petition”) was filed against the Debtor pursuant to 11 U.S.C. § 303. The Involuntary
6 Petition was filed by the Estate of Michael B. Macknin, the Sharona Dagani Trust, and the
8 21. On December 16, 2016, the Petitioning Creditors filed a Motion to Appoint Interim
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 Trustee in Involuntary Case [ECF No. 3] (the “Interim Trustee Motion”), which sought authority
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 to appoint an interim trustee to take possession of property and to manage the business operations
HOUMAND LAW FIRM, LTD.
12 22. On December 21, 2016, the Bankruptcy Court entered an Order on Trustee Motion
13 and Order for Relief Under Chapter 7 [ECF No. 21] (the “Order for Relief”).
14 23. The Order for Relief provided that the Debtor had consented to the filing of a
15 bankruptcy petition and that the filing of the bankruptcy case was effective as of December 15,
17 24. The Order for Relief further required that the Office of the United States Trustee
18 (the “U.S. Trustee”) appoint an Interim Chapter 7 Trustee pursuant to 11 U.S.C. § 701.
19 25. On December 22, 2016, Trustee Nelson was appointed as the Chapter 7 Trustee in
21 26. On February 7, 2017, Trustee Nelson filed a Motion to Approve Sale of Personal
22 Property to Ken Chupinsky Pursuant to 11 U.S.C. § 363 [ECF No. 160] (the “Motion to Sell”).
23 27. The Motion to Sell sought approval to sell certain personal property of the Debtor.
24 28. On March 23, 2017, the Court entered an Order Approving Motion to Approve
25 Sale of Personal Property to Ken Chupinsky Pursuant to 11 U.S.C. § 363 [ECF No. 218].
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All references to “ECF No.” are to the numbers assigned to the documents filed in the above-
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referenced case as they appear on the docket maintained by the clerk of the court.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 13 of 19
1 30. On January 19, 2018, the Trustee was appointed as the successor Chapter 7 Trustee
3 31. During the course of the administration of the Debtor’s bankruptcy case, Trustee
4 Nelson and the Trustee have served approximately twenty-two (22) subpoenas issued pursuant to
5 FRBP 2004 (collectively, the “Subpoenas”) seeking the production of financial records related to
7 32. The Subpoenas resulted in the production of tens of thousands of financial records
8 that were required to be analyzed to evaluate whether there were pre-petition transfers of estate
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
11 Nelson and the Trustee employed Eisner Amper, LLP (“EisnerAmper”) as Forensic Accountant to
14 Nelson and the Trustee employed Andersen Law Firm, Ltd. (“Andersen”) as Special Litigation
15 Counsel to assist in recovery of funds from the Debtor’s legal malpractice insurer.
16 35. Through Andersen’s efforts, the Trustee was able to recover $11,583.00 from
18 36. During the course of the administration of the Debtor’s bankruptcy case, the
19 Trustee initiated an adversary (the “Adversary Proceeding”) proceeding against Bank of America,
20 N.A. (“BOA”), alleging the following claims for relief: (a) Avoidance of Constructive Fraudulent
21 Transfers Pursuant to 11 U.S.C. § 544(b), 26 U.S.C. § 6502 and 6901 and N.R.S. Chapter 112; (b)
22 Avoidance of Actual Fraudulent Transfers Pursuant to 11 U.S.C. § 544(b) and N.R.S. Chapter
25 Avoidance of Transfers Pursuant to 11 U.S.C. § 544(b) and the Federal Debt Collection
26 Procedures Act (28 U.S.C. §§ 3301 through 3308); and (f) Recovery of Bankruptcy Estate
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 14 of 19
1 37. On April 24, 2020, the Trustee filed a Motion to Approve Compromise Pursuant to
2 Federal Rule of Bankruptcy Procedure 9019 [ECF No. 488] (the “BOA Compromise Motion”).
3 38. The BOA Compromise Motion sought approval of a settlement agreement which
4 resolved the claims alleged in the Adversary Proceeding in exchange for payment of $215,000.00
6 39. On June 3, 2020, the Court entered an Order Granting Motion to Approve
7 Compromise Pursuant to Federal Rule of Bankruptcy Procedure 9019 [ECF No. 494].
8 40. In addition to the Adversary Proceeding, the Trustee was able to negotiate multiple
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
11 proceeds of $3,971.48 for the Debtor’s bankruptcy estate. As noted herein, this payment will be
12 received by the Trustee following the filing of this Fee Application, but prior to the hearing on the
13 same.
15 Express Centurion Bank resulting in proceeds of $250,000.00 for the Debtor’s bankruptcy estate.
19 in proceeds of $156,425.00 for the Debtor’s bankruptcy estate. As noted herein, this payment will
20 be received by the Trustee following the filing of this Fee Application, but prior to the hearing on
21 the same.
22 41. The various settlements that were negotiated with the parties referenced above
23 were the result of months of negotiations that involved extensive legal analysis concerning
24 nuanced legal issues such as the Ponzi scheme presumption, standing, and state and federal
26 42. Through the efforts of Trustee Nelson and the Trustee, a total of approximately
27 $808,526.00 will have been recovered for the Debtor’s bankruptcy estate.
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 15 of 19
1 VII.
4 (a)(1) After notice to the parties in interest and the United States
trustee and a hearing, and subject to sections 326, 328 and 329 the
5 court may award to a trustee, an examiner, a professional person
employed under section 327 or 1103.
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(A) Reasonable compensation for actual, necessary services
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rendered by the trustee, examiner, professional person, or attorney
8 and by any paraprofessional person employed by any such person;
and
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
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Case 16-16655-btb Doc 540 Entered 02/09/21 11:49:21 Page 16 of 19
1 VIII.
3 47. This Fee Application seeks allowance of compensation as follows: (a) $303,267.50
4 for professional services rendered during the Fee Application Period; and (b) reimbursement of
5 actual expenses in the amount of $12,720.39 incurred by the Firm during the Fee Application
6 Period.
7 IX.
10 48. Services rendered by Applicant are set forth in detail in the billing entries attached
HOUMAND LAW FIRM, LTD.
11 as Exhibit “1” to the Houmand Declaration. The billing entries attached as Exhibit “1” to the
12 Houmand Declaration reflect the tasks and includes a detailed list of all time for which
14 service and hourly billing rate, and description of time spent and tasks performed. See
16 49. Actual expenses incurred by the Firm during the Fee Application Period are
19 51. The Firm has charged customary rates for fees which are allowed by attorneys in
21 52. The Firm is not employed on a contingency basis and, as in all bankruptcy
22 proceedings, the fees charged are subject to the discretion of the Court.
23 53. For the convenience of the Court, the U.S. Trustee, and all interested parties, the
24 following paragraphs set forth a narrative statement, summary and explanation of certain
25 activities and services performed during the time covered by the Fee Application Period. The
26 Firm expended a total of 948.6 hours in providing services on behalf of the Trustee in the
27 Bankruptcy Case over a period of approximately forty-nine (49) months. To provide an orderly
28 and meaningful summary of the services rendered by the Firm in accordance with applicable law
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1 and guidelines the Firm utilized the following separate project billing categories in the Fee
3 B110 – Case Administration. The entries in this category relate to the work performed
5 creditors, counsel for Debtor, and interested parties and their counsel on an on-going day-to-day
6 basis. The entries in this category also involved an inspection of the Debtor’s premises and
7 storage unit, and the preparation of pleadings to abandon property that was of inconsequential
8 value to the Debtor’s bankruptcy estate. The Firm expended 78.3 hours and spent $25,112.50 for
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 this category.
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 B120 – Asset Analysis & Recovery. The entries in this category relate to the investigation
HOUMAND LAW FIRM, LTD.
11 and analysis of the potential recovery of assets for ultimate distribution to the unsecured creditors
12 of the Debtor’s bankruptcy estate. The Firm reviewed tens of thousands of financial documents
13 that were produced pursuant to the Subpoenas and researched nuanced legal issues such as the
14 Ponzi Scheme presumption, standing to avoid transfers from a trust account, and state and federal
15 fraudulent transfer law. The Firm expended 393 hours and spent $118,510.00 for this category.
16 B130 – Asset Disposition. The entries in this category relate to the marketing and sale of
17 one of persona property of the Debtor and the preparation of the Motion to Sell. The Firm
19 B150 – Meetings and Communications. The entries in this category include the
20 preparation and attendance at the Debtor’s 341(a) Creditors Meetings and meeting with Debtor
21 and counsel for the Debtor. The time entries in this category also included communications with
22 creditors of the Debtor’s bankruptcy estate. The Firm expended 11.9 hours and spent $3,305.00
25 to the drafting and filing of applications to employ the Firm, Andersen, EisnerAmper, Diamond
26 McCarthy, LLP, and Paul Healey & Sons CPAs, Ltd. and attending hearings on the same.
27 Following the appointment of the Trustee as successor Chapter 7 Trustee, the Firm prepared
28 second applications to employ these firms as representatives for the Trustee. There was also a
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1 protracted dispute with Markel Insurance concerning the employment of special counsel to
2 recover funds under an insurance policy in the name of the Debtor. Finally, the time entries in
3 this category also relate to the preparation of interim and final fee applications for each of these
4 firms. The Firm expended 92.9 hours and spent $29,350.00 for this category.
6 review of lease agreements in the Debtor’s name. The Firm expended 1.1 hours and spent
8 B190 – Other Contested Matters. The entries in this category related to the prosecution of
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 the Adversary Proceeding and extensive negotiations with numerous third-parties that resulted in
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 the recovery of the majority of the funds recovered by the Trustee. The negotiations with third-
HOUMAND LAW FIRM, LTD.
11 parties were extensive and included multiple agreements to toll the statute of limitations, analysis
12 of legal positions through written correspondence, and preparation of memoranda to the Trustee
13 regarding the same. The Firm expended 344.7 hours and spent $117,975.00 for this category.
14 B310 – Claims Administration & Objections. The entries in this category relate to the
15 review, analysis, and resolution of objections related to the proof of claims filed with the Court.
16 The Firm expended 16.7 hours and spent $5,897.50 for this category.
17 X.
19 54. The Firm is skilled in insolvency proceedings and Chapter 7 Trustee cases and has
20 special knowledge which enabled the Firm to perform services of benefit to the Trustee.
21 Specialized knowledge and skills with respect to insolvency practice, and procedure and law are
23 XI.
26 55. No payments have been made or promised to the Firm for services rendered or to
27 be rendered in connection with this case, other than those payments described in this Fee
28 Application.
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1 56. No agreement or understanding exists between the Firm and any other entity for
2 the sharing of compensation received or to be received for services rendered in connection with
3 this case, except as permitted under Section 504(b)(1). See Houmand Declaration.
4 XII.
5 CONCLUSION
6 WHEREFORE, the Firm respectfully requests that this Court enter an Order: (a) granting
7 this Fee Application; (b) approving and allowing compensation in the amount of $303,267.50 and
8 reimbursement of expenses in the amount of $12,720.39 for the Fee Application Period consistent
9205 West Russell Road, Building 3, Suite 240 Las Vegas, NV 89148
9 with the terms of this Fee Application; (c) authorizing the Trustee to pay the Firm the amounts set
Telephone: (702) 720-3370 Facsimile: (702) 720-3371
10 forth in the Fee Application; and (d) for such other relief as is such and proper.
HOUMAND LAW FIRM, LTD.
13
By: /s/ Jacob L. Houmand
14 Jacob L. Houmand, Esq. (NV Bar No. 12781)
Bradley G. Sims, Esq. (NV Bar No. 11713)
15 9205 West Russell Road, Building 3, Suite 240
Las Vegas, NV 89148
16 Telephone: 702/720-3370
Facsimile: 702/720-3371
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18 Counsel for Shelley D. Krohn, Chapter 7 Trustee
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