Dunn-De 296 GrayRobinson First Interim Fee App

Case 09-11958-AJC Doc 296 Filed 05/22/12 Page 1 of 15
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
In re: Case No. 09-11958-BKC-AJC
MERENDON MINING (Nevada), INC.

a/k/a Milowe Brost,
Chapter 7
Debtor.
__________________________________/
FIRST INTERIM FEE APPLICATION FOR ALLOWANCE AND PAYMENT OF

COMPENSATION AND REIMBURSEMENT OF EXPENSES TO GRAYROBINSON,
P.A., AS GENERAL COUNSEL TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE
1. Name of Applicant: GrayRobinson, P.A.
2. Role of Applicant: Counsel to Marcia Dunn, Chapter 7 Trustee
3. Name of Certifying Professional Ivan J. Reich, Esq.
4. Date case filed: February 4, 2009
5. Date of application for employment: June 16, 2009 [DE #32]
6. Date of order approving employment: June 17, 2009 nunc pro tunc to June 11, 2009
[DE #34]
7. If debtor's counsel, date of Disclosure of N/A

Compensation form:
8. Date of this application: May 22, 2012
9. Dates of services covered: June 11, 2009 through March 31, 2012
10. If case is chapter 7, amount trustee has on $1,216,188.32

hand:
Fees...
11. Total fee requested for this period (from Exh. 1): $716,885.00
12. Balance remaining in fee retainer account as of the Petition Date: $0.00
13. Fees paid or advanced for this period, by other sources: $0.00
14. Net amount of fee requested for this period: $716,885.00
Expenses...
15. Total expense reimbursement requested for this period (from Exh. 2): $37,619.34
16. Balance remaining in expense retainer account as of the Petition $0.00

Date:
17. Expenses paid or advanced for this period, by other sources: $0.00
18. Net amount of expense reimbursements requested for this period $37,619.34
19. Gross award requested for this period (#11 + #15) $754,504.34
20. Net award requested for this period (#14 + #18) $754,504.34
History of Fees and Expenses
1. Dates, sources, and amounts of retainers received: N/A
Dates: Sources: Amounts: For fees or costs?

N/A
2. Dates, sources, and amounts of third party payments received: N/A
Dates: Sources: Amounts: For fees or costs?
3. Prior fee and expense awards...
N/A
Dates covered by First Invoice:
Amount of fees requested:
Amount of expenses requested:
Amount of fees invoiced (80% of fees

requested) (no objection filed):
Amount of expenses invoiced (no

objection filed):
Amount of fees applied against the

retainer:
Amount of expenses applied against

the retainer:
Fees paid by Debtor, net of retainer:
Expenses paid by Debtor, net of

retainer:
Date of application of retainer:
Portion of fees requested but not

invoiced, which applicant wishes to
defer to final fee application:
Portion of expenses requested but not

invoiced, which applicant wishes to
defer to final fee application:
2
UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
In re: Case No. 09-11958-BKC-AJC
MERENDON MINING (Nevada), INC.

a/k/a Milowe Brost,
Chapter 7
Debtor.
__________________________________/
SUMMARY OF FIRST INTERIM FEE APPLICATION OF GRAYROBINSON, P.A., AS

GENERAL COUNSEL TO MARCIA T. DUNN, CHAPTER 7 TRUSTEE
GRAYROBINSON, P.A., (AApplicant@) counsel to the Chapter 7 Trustee (the ATrustee@),
applies for its first interim compensation for fees for services rendered and costs incurred in this
Chapter 7 proceeding. This application is filed pursuant to 11 U.S.C. ' 330 and Rule 2016,
Federal Rules of Bankruptcy Procedure, and meets all of the requirements set forth in the
Guidelines incorporated in Local Rule 2016(B). This application for First Interim Compensation
is for services performed between June 11, 2009, through March 31, 2012. This is a First Interim
Fee Application filed by the Attorney for the Trustee and is not an amendment or supplemental
to a previous Fee Application. The exhibits attached to this application, pursuant to the
Guidelines, are:
Exhibits A1-A@ and A1-B@- Summary of Professional and Paraprofessional Time.
Exhibit "2" - Summary of Requested Reimbursements of Expenses.
Exhibit "3" - The applicant's complete time records, in chronological order, by activity
code category, for the time period covered by this application.
Applicant believes that the requested fee of $716,885.00 for 2,351.80 hours worked for
and expenses in the amount of $37,619.34 a total award of $754,504.34, is reasonable when
considering the twelve factors enumerated in Johnson v. Georgia Highway Express, Inc., 488
F.2d 714 (5th Circuit 1974), made applicable to bankruptcy proceedings by In re First Colonial
Corp. of America, 544 F.2d 1291 (5th Cir. 1977), as follows:
1
The General Nature of the services Rendered; the Amounts Involved and the Results obtained.1
On February 4, 2009, Petitioning Creditors Eileen McCabe, Jane L. Otto, and Diane
Kaplan-Berk filed a Chapter 7 Involuntary Petition in the Southern District of Florida against the
Debtor, Merendon Mining (Nevada), Inc., a Nevada corporation (D.E. 1). Because of the
pendency of another involuntary petition brought by other investor creditors in Colorado that
was subsequently dismissed, it was almost four months, or until June 2009, that an order for
relief was entered on June 9, 2009 (D.E. 29) and Marcia T. Dunn was appointed on June 10,
2009 (D.E. 30) as the Chapter 7 Trustee of this substantively consolidated bankruptcy estate2. On
June 17, 2009, this Court approved Applicant’s employment as counsel for the Trustee, nunc pro
tunc to June 11, 2009 (D.E. 34).
From the inception of this case, the Trustee and her professionals have done all they can
to keep the process open and communicate with creditors/ investors on the status of the case and
our efforts on their behalf. Notwithstanding that this estate until very recently had no assets,
Applicant nonetheless set up a website for creditors or any party interest to go to for updates on
the status of this case, the cost of setting up and maintaining being absorbed by Applicant. In the
early stages of the case, Applicant and the Trustee held a series of conference calls with investors
to apprise them of where we intended and saw this case going, as well as to discuss the unique
set of problems and circumstances that we faced in effectuating any sort of meaningful recovery
in the case. The approach we have followed has been vetted to and with these creditors,
Applicant has fielded hundreds of calls from these investor/ creditors over the course of this case
apprising them of the efforts and approaches we were taking and have continued to take.
1
For the purposes of brevity, Trustee shall incorporate this section on the historical actions taken in this case into
her application for payment of her financial advisors, Marcum LLP, as if fully set forth therein as well.
2
On December 15, 2009, Trustee through Applicant, filed an adversary proceeding seeking substantive
consolidation of multiple entities into this estate (Case No. 09-02518), and on December 17, 2009 filed a motion, as
amended, on December 18, 2009, seeking the same (D.E. 66, 70), which substantive consolidation occurred by
Order of this Court on January 27, 2010, as amended on February 26, 2010 (D.E. 84, 109). On March 11, 2010, this
Court entered partial summary judgment in the adversary case (D.E. 62 in that case) substantive consolidating the
American mining companies and properties into the Debtor’s estate.
2
Applicant had been in communication with the criminal and regulatory investigative
authorities including representatives from the Alberta Securities Commission (the “ASC”), the
Securities and Exchange Commission (the “SEC”), the Royal Canadian Mounted Police (the
“Canadian Mounties”), the Federal Bureau of Investigation (the “FBI”), the Internal Revenue
Service (the “IRS”), the United States District Attorney's Office for the Southern District of New
York (the “US Attorney”), all of whom have ongoing investigations into the fraud that lies at the
heart of this case. However, because of these pending investigations, none of these agencies have
been in a position to share with us the results of their efforts. On the other hand, much of the
work of these agencies has resulted from our sharing the results of our efforts in this matter,
including the eventual issuance of injunctions from a Federal District Court in Washington State
brought by the SEC against the fraud’s perpetrators. We have reached multiple agreements with
the SEC which have been designed to protect all investors of the entire fraud and allowed them
to file late claims in this case, and allowed for the SEC to file a large protective claim on all their
behalves, which will be diminished as recoveries are made and distributions made to claimants.
The SEC has also agreed that any recoveries it effectuates will be distributed through this
bankruptcy estate to claimants.
We have also been exchanging information and cooperating with Mike Quilling, the
receiver appointed in Canada over the debtor's principal's and affiliates who reside in Calgary,
Alberta, Canada (the “Canadian Receiver”), and been in discussions with him about effectuating
joint protocols to jointly pursue assets outside of North America at a time, if and when, the
respective Canadian and American estates can afford to do so.
In addition, we have been working with representatives from the Environmental
Protection Agency (the “EPA”), and the Colorado Attorney General's office (the “AG”)
regarding any potential environmental issues concerning the mines, which fortunately for the
estate had already been cleaned up by the EPA pre petition.

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Also, we have interviewed many of the affiliates of the perpetrators of this fraud, Messrs.
Capstick, Werner and Adair, none of which, except Mr. Garfinkle, who were willing to have any
discussions with us on the record or in legal proceeding because of pending administrative and
criminal investigations against them.
While there was between $135 to $150 million in investor money lost as a result of the
American Merendon mining scheme (most of whom have filed claims in this case), this case is
also part of a much larger fraud, predating the American fraud, that began in Canada and was the
subject of a pending Canadian insolvency receivership proceeding at the time this case was filed.
Most of the billions in fraud long predated the creation of the American Merendon scheme, and
involved Canadian companies, assets and victims. By the time this case was filed, the Canadian
receiver already had an injunction against all the principals and debtor's affiliated assets in
Canada.
When this case was filed it had absolutely no assets, and that has remained the case until
just recently. Unfortunately this case lacked any assets in some part by virtue of the fact that the
investigative and criminal authorities in those other cases moved much more quickly then in this
case to shut down the fraud, at the time those cases were filed those schemes were still operating
and had assets to seize, the assets in those cases were located in the United States, and the
perpetrators of the fraud were American citizens residing in the jurisdictions were those cases
were brought.
Because this estate had no assets, initially Mr. Garfinkle represented to us that he would
be able to provide the estate with financing through funding from some of the defrauded
investors, which would have allowed me to hire foreign investigators, and possibly foreign
counsel, in order to locate and secure assets that had been moved offshore. Those promises
proved to be hollow. Therefore Applicant and the Trustee were left with a choice between trying
to obtain and liquidate American mining assets that we were able to trace were bought with
4
investor funds, or the more daunting task (as pointed out by this Court at repeated hearings) of
trying to bring back the majority of investors funds back into the estate that had been moved
offshore through a defunct Bahamian entity to Gary Sorenson's mining interests and companies
in South and Central America.
While Applicant did get the Bahamian pass through entity, controlled by Mr. Werner, to
turn over its ownership interest in a minority percentage of the Ecuadoran mine (the majority of
which is held by one of Mr. Sorenson’s companies), one of the problems faced in acquiring
ownership of the Latin American mines, beyond the obvious difficulty in obtaining and
enforcing judgments in those jurisdictions, is that the mining rights associated with these Latin
American mines are owned by their respective government and unless licensing and royalty fees
are paid to those governments the mining rights revert back to those governments. Because of the
injunction against the use of Mr. Sorenson’s assets obtained in the Canadian Receivership, and
Canadian regulatory and criminal actions, Mr. Sorenson has been unable to fund and has allowed
those mining rights to lapse and revert back to those governments.
The Discovery Day Mine Recovery
On June 11, 2010 (D.E. 152) Trustee moved against the purported owners a California
mine called Discovery Day for violation of the automatic stay, which was resolved by Order
dated July 1, 2010 (D.E. 155) The impetus for the motion was an accident occur upon that mine
were someone was killed. Fortunately it was the one mine upon which title had never transferred
to debtor or one of its affiliates because the mine was bought under an installment land sales
contract that debtor had defaulted upon so that title never transferred. Fortunately, that mine at
the time of the accident was being operated by the seller who still retained title. The initial
settlement required the seller to make the Trustee a loss payee, be indemnified by the seller, and
to insure and agree to not dispose of the Discovery Day Mine. Eventually we reached a court
approved settlement (D.E. 226, Motion, dated April 7, 2011, D.E. 236, Order, dated May 5,
5
2011) with the seller of Discovery Day for $300,000 of which the last $250,000 was just paid on
April 16, 2012 (after an initial $50,000 down payment) in which the estate relinquished its
interest in Discovery Day, and acknowledged it never had an interest in that mine.
The Glory Hole Mine Recovery
The history of the Glory Hole mine as it relates to this case is that it had been owned by
the late Mr. Caldwell, who was sued by a judge in Texas who got a default judgment against him
and then had the judgment domesticated and executed upon in Colorado. That Texas judgment
had been subsequently set aside as a result of it being issued without due process, and the
Colorado judgment is also in the process of being set aside, if it hasn't already occurred. As part
of that execution, Garfinkle had the judge sell, and Merendon, with over $300,000 of investor
funds, buy the Glory Hole, and then had title to the property vested in a Merendon affiliate called
Sentinel Mining that was controlled by Garfinkle. Garfinkle then obtained a power of attorney
from Caldwell, under what has been described by Caldwell as questionable circumstances, and
settled the dispute. As a result, ownership, while titled in Sentinel (which by Court Order was
subsequently substantively consolidated into this case voluntarily by Garfinkle) was the subject
of multiple lawsuits and claims with the Caldwell Estate and parties who had taken title to the
mine from Caldwell after he had been divested of his ownership.
The multiple investigations into this case have been looking not just into whether the
Merendon scheme was a Ponzi scheme, but whether it was also being sold to investors as
improper tax shelters. Those investigations remain pending. Apparently because of Garfinkle’s
history with these types of investments, the principals of Merendon felt comfortable enough with
Mr. Garfinkle to bring them into their confidences. While we have found no evidence to neither
suggest nor do we have reason to believe that Mr. Garfinkle was a participant in the Merendon
fraud, apparently Merendon's principals did confide in Mr. Garfinkle because they found him to
be a kindred spirit.
6
Because of his pre-petition history with the Glory Hole mine, Mr. Garfinkle has long
expressed an interest in acquiring that mine and has often expressed his belief that he had some
sort of equitable claim in the proceeds from the sale of any such mine, though he never showed
that he had any independent right in his own regard to assert the same other then the fact that he
had possessed a power of attorney from Caldwell. Mr. Garfinkle always wanted the Glory Hole
mine, yet he never put up a contract or money to buy it, and even scared away one of the buyers
we had for all the Colorado mines.
Applicant, the Trustee and her Court approved auctioneers, had been speaking to multiple
buyers presented to us by multiple parties that through relationships with various parties in
interest in this case, including governmental entities, have expressed an interest in making offers
for the various mining interests.
Trustee finally found a buyer and entered into a lucrative contract, dated July 13, 2010
with Coral Gables International Business Enterprises, LLC, which was the subject of an initial
sale motion, on September 3, 2010, to sell the three Colorado Mining Properties in bulk for
$2,250,000 (D.E. 167), and was accompanies by the Trustee filing on September 29, 2010 an
adversary proceeding under Case No. 10-03623 to sell the Colorado Mining Properties under 11
U.S.C. §363 (D.E. 177). However, this offer was interfered with by Mr. Garfinkle who contacted
the buyer directly, because he wanted Glory Hole for himself, leading to the initial buyer
walking away from the transaction to buy all the Colorado mines.
Fisher Auctions then contacted various industry and trade contacts in efforts to generate
interest in these mines since their engagement. They worked the market, and the Trustee
considered every offer presented. However, except for the few instances that have been
presented to the Court, Applicant and the Trustee had not been able to get signed offers with a
deposit. This included potential buyers who had been previously introduced to us by Mr.
Garfinkle, but who never made an actual offer to buy any of these properties.
7
Eventually a new buyer, Glory Development Company (“GDC”), was located and
entered into a June 6, 2011 contract with the Trustee to purchase just the Glory Hole mine at a
stalking horse price of $495,000 (which was the subject of an amended sale motion filed on June
9, 2011 (D.E. 245)), but the Court, at the July 21, 2011 hearing on that sale, wouldn't approve the
sale while ownership issues remained unresolved (D.E. 252, dated July 22, 2011). Hence
Applicant met with the parties with competing ownership claims, and negotiated an agreement
(Ex. A. to Motio to Approve Settlement dated August 19, 2011, D.E. 262, 263) that was
ultimately approved by the Court on September 29, 2011 (D.E. 282) for $600,000 less a 10%
auctioneer’s commission, that would go directly into the estate for abandoning the estate’s claim
to the Glory Hole mine.
The Boulder County Mines Recovery
However, Trustee and Applicant was able to convince the rejected potential buyer of the
Glory Hole Mine, GDC, to enter into a July 28, 2011 contract to instead purchase the remaining
Colorado mines, Bueno and Black Rose (the “Boulder County Mines”) for a stalking horse price
of $495,000 which contract was the subject of a motion to sell the Boulder County Mines on
August 2, 2011, as amended on August 3, 2011 (D.E. 254, 256). After an auction and a hearing
on January 4, 2012 (D.E. 284) this Court approved the sale of the Boulder County Mines to the
winning bidder, David Badner/ Badner Group, Inc. (“Badner”), on January 19, 2012 (D.E. 287)
for $540,000.00, less an expense reimbursement to GDC, and a 10% auctioneer’s commission.
The Boulder County Mines had one lien claimant, Worldwide Rental Services, Inc. a/k/a
Worldwide Machinery, Inc. (“Worldwide”) as a result of a post-petition, but pre-substantive
consolidation judgment lien obtained against one of the substantively consolidated debtors, who
held title to the Boulder County Mines. Trustee reached a settlement for the payment of $88,817
to Worldwide, and filed a motion on March 30, 3012 to approve that settlement, in full
satisfaction of Worldwide’s lien claim to be paid from the proceeds of the sale of the Boulder
8
County Mines (D.E. 290), which settlement was approved by this Court on April 25, 2012 (D.E.
293).
Now that these settlements and sales have been approved, completed and been paid,
resulting in a gross recovery of $1,440,000, Applicant and the Trustee are now at a stage in these
proceedings, after three years, to make this its first application for payment of Applicant, and
Trustee’s financial advisors’ fees and costs, and seeks 100% of those fees and costs on an interim
basis, as compared to the traditional 80% of interim fees, in light of the long wait Applicant and
the financial advisor have had to make before recoveries have finally been made in this case.
Upon approval and payment of these professional fees and costs, the Trustee will then
exercise her business judgment as to whether to proceed to then make a smaller distribution, or
to use the balance of the funds generated by the settlements and sale to go for more significant,
but more difficult, extraterritorial recoveries, or sale of those rights.
The Time and Labor Required: The transcribed time records annexed hereto as Exhibit
"3" show that partners, associates and paralegals associated with your Applicant have devoted
2,351.80 hours of time to servicing the Trustee from June 11, 2009 through March 31, 2012.
The Novelty and Difficulty of the Services Rendered: The legal questions arising in the
representation of the Trustee to date were unusually novel and difficult, and required the exercise
of skillful application of Bankruptcy Code provisions relating to recovery of assets of the estate.
This was a complex international Ponzi scheme conducted initially in Canada by Canadian
citizens, then moved to Colorado, Nevada, Arizona and California involving mines in those
states, the fraud was conducted awhile before the bankruptcy filing, and the monies have been
traced to mining operations in South and Central America. Also obtaining and locating the
cooperation of participants in the fraud, as well as cooperation with governmental authorities has
been difficult due to pending criminal and administrative proceedings by Federal, state and
provincial authorities in multiple states and Canada. The case involved issues of real property
9
and mining law in multiple jurisdictions, and the ability to find information about the assets of
the estate has proven to be elusive.
The Skill Requisite to Perform the Services Properly: In order to perform the legal
services enumerated herein properly, substantive legal knowledge in the fields of bankruptcy,
commercial law, debtor-creditor rights, mining, asset sales, international law, the law of
substantive consolidation, and the duties and powers of a Trustee were required.
The Preclusion of Other Employment by the Professional Due to the Acceptance of the
Case: Applicant is aware of no other employment which was precluded as a result of accepting
this case; however, due to the time spent on this case, Applicant was unable to devote that time
to other matters, therein preventing Applicant from billing and collecting fees in other cases.
The Customary Fee: The rates charged by the participating attorneys and paralegals, as
set forth in the exhibits are well within the range charged by attorneys in the Southern District of
Florida of similar skill and reputation in the area of bankruptcy and commercial law.
Time Limitations Imposed by the Client or Other Circumstances: No specific time
limitations were imposed by the Trustee, but Applicant made all efforts to act quickly in the
representation of the Trustee in this Chapter 7 case. This is Applicant’s first fee application and
Applicant has worked on this matter for approximately three years without seeking or obtaining
compensation for its services.
The Experience, Reputation, and Ability of the Professional: Applicant, is an established
law firm having substantial experience in bankruptcy and commercial law and litigation. The
experience, reputation and ability of Applicant is well-known to this Court.
The Undesirability of the Case: Applicant does not find it undesirable to represent the
Trustee in any form of bankruptcy proceeding.
The Nature and Length of the Professional Relationship of the Client: Applicant has
represented the Trustee in other bankruptcy matters.
10
Awards in Similar Cases: The amount applied for by Applicant is not unreasonable in
terms of awards in cases of like magnitude and complexity. The fees requested by Applicant
comport with the mandate of the Bankruptcy Code, which directs that services be evaluated in
the light of comparable services performed in on-bankruptcy cases in the community. Applicant
respectfully prays that this Court take notice that Applicant occupies professional offices,
maintains sophisticated office equipment, and a staff including paralegals, secretarial and other
support personnel. Consequently, a substantial portion of such hourly fee as may be awarded to
the Applicant will merely defray the overhead and expenses already incurred and paid in cash
during the pendency of this proceeding.
WHEREFORE, the applicant seeks a first and interim award of fees in the amount of
$716,885.00 and costs in the amount of $37,619.34 for this period for a total final award of
$754,504.34.
GRAYROBINSON, P.A.
Attorneys for Plaintiff, Marcia Dunn,
Chapter 7 Trustee
401 E. Las Olas Blvd., Suite 1850
Fort Lauderdale, FL 33301
Ph. (954) 761-8111—Fax (954) 761-8112
By: /s/ Ivan J. Reich

Ivan J. Reich, Esq.
Fla. Bar No. 778011
11
CERTIFICATION
1. I have been designated by GRAYROBINSON, P.A. (the "Applicant") as the

professional with responsibility in this case for compliance with the Guidelines for Fee
Applications for Professionals in the Southern District of Florida in Bankruptcy Cases (the
"Guidelines").
2. I have read the Applicant's application for compensation and reimbursement of
expenses (the "Application"). The application complies with the Guidelines, and the fees and
expenses sought fall within the Guidelines, except as specifically noted in this certification and
described in the application.
3. The fees and expenses sought are billed at rates and in accordance with practices
customarily employed by the Applicant and generally accepted by the Applicant's clients.
4. In seeking reimbursement for the expenditures described on Exhibit 2, the
Applicant is seeking reimbursement only for the actual expenditure and has not marked up the
actual cost to provide a profit or to recover the amortized cost of investment in staff time or
equipment or capital outlay (except to the extent that the Applicant has elected to charge for
in-house photocopies and outgoing facsimile transmissions at the maximum rates permitted by
the Guidelines).
5. In seeking reimbursement for any service provided by a third party, the Applicant
is seeking reimbursement only for the amount actually paid by the Applicant to the third party.
6. The following are the variances with the provisions of the Guidelines, the date of
each court order approving the variance, and the justification for the variance: NONE.
I HEREBY CERTIFY that a true copy of this Application, with all exhibits, was served on
the 22nd day of May, 2012 to all parties registered to receive service via the Court’s CM/ECF
system and in accordance with the Court’s Order of December 30, 2009 [D.E. #74 in the main
case], shall be posted to http://gray-robinson.com/news.php?ACTION=view&CAT=1&ID=1985,
set up for the purposes of providing information on this case.
GRAYROBINSON, P.A.
Attorneys for Plaintiff, Marcia Dunn,
Chapter 7 Trustee
401 E. Las Olas Blvd., Suite 1850
Fort Lauderdale, FL 33301
Ph. (954) 761-8111—Fax (954) 761-8112
By: /s/ Ivan J. Reich

12
Ivan J. Reich, Esq.

Fla. Bar No. 778011
\351016\4 - # 1294422 v1
13
Case 09-11958-AJC Doc 296-1 Filed 05/22/12 Page 1 of 1
EXHIBIT “1-A”
Summary of Professional and Paraprofessional Time
Total per Individual for this Period Only
PROFESSIONALS:
Name Year Total Hours Hourly Rate Total Fee
Licensed
S - Robert Schatzman 1971 (FL) 0.50 $600.00 $ 300.00
S - Robert Schatzman 1971 (FL) 84.40 $550.00 $ 46,420.00
S - Patrick S. Scott 1979 (FL) 16.30 $500.00 $ 8,150.00
S - Patrick S. Scott 1979 (FL) 1.50 $495.00 $ 742.50
S - William M. Pearson 1985 (FL) 6.80 $500.00 $ 3,400.00
S - Frank Terzo 1991 (FL) 13.90 $450.00 $ 6,255.00
S - Ivan J. Reich 1988 (FL) 903.60 $450.00 $406,620.00
S - Ivan J. Reich 1988 (FL) 59.00 $400.00 $ 23,600.00
S - Jeffrey A. Bahnsen 1991 (FL) 21.80 $450.00 $ 9,810.00
S - Jeffrey A. Bahnsen 1991 (FL) 2.10 $400.00 $ 840.00
S - Leyza F. Blanco 1997 (FL) 0.20 $415.00 $ 83.00
S - Steven J. Solomon 1992 (FL) 11.00 $390.00 $ 4,290.00
S - Jason B. Burnett 1989 (FL) 13.70 $365.00 $ 5,000.50
OC - Nathan G. Mancuso 1999 (FL) 16.90 $350.00 $ 5,915.00
A - Ji Hun Kim 2010 (FL) 19.30 $210.00 $ 4,053.00
A - Michael D. Lessne 2010 (FL) 91.00 $225.00 $ 20,475.00
A - Jarred Leibner 2011 (FL) 54.30 $175.00 $ 9,502.50
A - Jarred Leibner N/A 61.80 $125.00 $ 7,725.00
A - Paige Wagner 2008 (FL) 41.50 $150.00 $ 6,225.00
A- Shayna A. Freyman 2010 (FL) 0.40 $125.00 $ 50.00
A - Kirsten Wegel 2010 (FL) 13.50 $110.00 $ 1,485.00
SUBTOTALS: 1,802.70 $644,947.00
S = Shareholder; A = Associate; OC = Of Counsel
PARAPROFESSIONALS:
Name Year Total Hours Hourly Rate Total Fee
Licensed
PL - Lisa A. Negron N/A 58.60 $160.00 $ 9,376.00
PL - Nancy H. Nicole N/A 116.30 $140.00 $ 16,282.00
PL - Jessica Serrano- N/A 229.60 $125.00 $ 28,700.00
Cartagena
PL - Susan Stirling N/A 138.00 $125.00 $ 17,250.00
LS – Emma Bartling N/A 6.60 $ 50.00 $ 330.00
SUBTOTALS: 549.10 $ 71,938.00
PL = Paralegal; LS = Litigation Support
TOTALS:
Total Professional and Paraprofessional Hours: 2,351.80
Blended Average Hourly Rate: $304.82
Total Professional and Paraprofessional Fees: $716,885.00
# 1303073 v1 EXHIBIT “1-A”
EXHIBIT “1-B”
Summary of Professional and Paraprofessional Time by Activity Code Category
ACTIVITY CODE CATEGORY: Asset Analysis and Recovery (001)
Name Rate Hours Total Fees
Robert Schatzman $550.00 57.60 $ 31,680.00
William M. Pearson $500.00 1.20 $ 600.00
Patrick S. Scott $500.00 1.60 $ 800.00
Patrick S. Scott $495.00 0.80 $ 396.00
Ivan J. Reich $450.00 122.40 $ 55,080.00
Ivan J. Reich $400.00 1.30 $ 520.00
Leyza F. Blanco $415.00 0.20 $ 83.00
Steven J. Solomon $390.00 10.50 $ 4,095.00
Nathan G. Mancuso $350.00 3.80 $ 1,330.00
Michael D. Lessne $225.00 3.70 $ 832.50
Michael D. Lessne $215.00 6.20 $ 1,333.00
Michael D. Lessne $190.00 6.80 $ 1,292.00
Jarred Leibner $175.00 6.20 $ 1,085.00
Jarred Leibner $125.00 58.30 $ 7,287.50
Lisa A. Negron $160.00 3.30 $ 528.00
Paige Wagner $150.00 18.40 $ 2,760.00
Jessica Serrano-Cartagena $125.00 0.30 $ 37.50
Susan Stirling $125.00 2.00 $ 250.00
MATTER TOTAL: 304.60 $109,989.50
ACITIVTY CODE CATEGORY: Asset Disposition (002)

Robert Schatzman $600.00 0.50 $ 300.00
Patrick S. Scott $500.00 1.20 $ 600.00
Patrick S. Scott $495.00 0.70 $ 346.50
Ivan J. Reich $450.00 145.90 $ 65,655.00
Jeffrey A. Bahnsen $450.00 21.80 $ 9,810.00
Jeffrey A. Bahnsen $400.00 2.10 $ 840.00
Nathan G. Mancuso $350.00 8.30 $ 2,905.00
Michael D. Lessne $225.00 56.00 $ 12,600.00
Michael D. Lessne $215.00 103.20 $ 22,188.00
Michael D. Lessne $190.00 77.90 $ 14,801.00
Jarred Leibner $175.00 11.90 $ 2,082.50
Jarred Leibner $125.00 3.50 $ 437.50
Nancy H. Nicole $140.00 2.70 $ 378.00
Jessica Serrano-Cartagena $125.00 14.10 $ 1,762.50
Susan Stirling $125.00 72.20 $ 9,025.00
MATTER TOTAL: 522.00 $143,731.00
EXHIBIT “1-B”
ACTIVITY CODE CATEGORY: Case Administration (004)

Frank Terzo $450.00 12.10 $ 5,445.00
Ivan J. Reich $450.00 250.80 $112,860.00
Ivan J. Reich $400.00 48.60 $ 19,440.00
Steven J. Solomon $390.00 0.30 $ 117.00
Jason B. Burnett $365.00 11.70 $ 4,270.50
Nathan G. Mancuso $350.00 1.60 $ 560.00
Michael D. Lessne $225.00 13.10 $ 2,947.50
Michael D. Lessne $215.00 7.70 $ 1,655.50
Michael D. Lessne $190.00 100.00 $ 19,000.00
Jarred Leibner $175.00 2.20 $ 385.00
Lisa A. Negron $160.00 35.90 $ 5,744.00
Paige Wagner $150.00 15.30 $ 2,295.00
Nancy H. Nicole $140.00 12.30 $ 1,722.00
Susan Stirling $125.00 10.20 $ 1,275.00
Kirsten Wegel $110.00 7.00 $ 770.00
MATTER TOTAL: 701.50 $207,724.00
ACTIVITY CODE CATEGORY: Claims Administration and Objections (005)

Patrick S. Scott $500.00 8.70 $ 4,350.00
Ivan J. Reich $450.00 122.80 $ 55,260.00
Nathan G. Mancuso $350.00 0.10 $ 35.00
Michael D. Lessne $225.00 0.40 $ 90.00
Michael D. Lessne $215.00 3.80 $ 817.00
Jarred Leibner $175.00 6.70 $ 1,172.50
Jessica Serrano-Cartagena $125.00 3.70 $ 462.50
Susan Stirling $125.00 1.30 $ 162.50
MATTER TOTAL: 147.50 $ 62,349.50
ACTIVITY CODE CATEGORY: Fee/Employment Applications (007)

Ivan J. Reich $450.00 3.10 $ 1,395.00
Ivan J. Reich $400.00 4.50 $ 1,800.00
Steven J. Solomon $390.00 0.20 $ 78.00
Michael D. Lessne $190.00 1.10 $ 209.00
Lisa A. Negron $160.00 6.40 $ 1,024.00
Susan Stirling $125.00 19.40 $ 2,425.00
MATTER TOTAL: 62.30 $ 12,038.50
EXHIBIT “1-B”
ACTIVITY CODE CATEGORY: Litigation (010)

William M. Pearson $500.00 5.60 $ 2,800.00
Patrick S. Scott $500.00 4.80 $ 2,400.00
Frank Terzo $450.00 1.80 $ 810.00
Ivan J. Reich $450.00 217.30 $ 97,785.00
Ivan J. Reich $400.00 2.00 $ 800.00
Jason B. Burnett $365.00 2.00 $ 730.00
Nathan G. Mancuso $350.00 3.10 $ 1,085.00
Ji Hun Kim $210.00 19.30 $ 4,053.00
Michael D. Lessne $225.00 17.60 $ 3,960.00
Michael D. Lessne $215.00 30.80 $ 6,622.00
Michael D. Lessne $190.00 25.70 $ 4,883.00
Jarred Leibner $175.00 26.60 $ 4,655.00
Lisa A. Negron $160.00 13.00 $ 2,080.00
Paige Wagner $150.00 7.80 $ 1,170.00
Nancy H. Nicole $140.00 101.30 $ 14,182.00
Susan Stirling $125.00 32.40 $ 4,050.00
Kirsten Wegel $110.00 6.50 $ 715.00
Emma Bartling $ 50.00 6.60 $ 330.00
MATTER TOTAL: 562.20 $159,942.50
ACTIVITY CODE CATEGORY: Meetings of Creditors (011)

Ivan J. Reich $450.00 8.10 $ 3,645.00
Ivan J. Reich $400.00 2.60 $ 1,040.00
MATTER TOTAL: 10.70 $ 4,685.00
ACTIVITY CODE CATEGORY: Stay Relief Proceedings (013)

Ivan J. Reich $450.00 27.50 $ 12,375.00
Michael D. Lessne $215.00 0.10 $ 21.50
Michael D. Lessne $190.00 3.40 $ 646.00
Jarred Leibner $175.00 0.40 $ 70.00
Shayna A. Freyman $125.00 0.40 $ 50.00
MATTER TOTAL: 31.80 $ 13,162.50
ACTIVITY CODE CATEGORY: Tax Issues (014)

Ivan J. Reich $450.00 5.70 $ 2,565.00
Michael D. Lessne $225.00 0.20 $ 45.00
Michael D. Lessne $215.00 2.50 $ 537.50
Jarred Leibner $175.00 0.30 $ 52.50
Susan Stirling $125.00 0.50 $ 62.50
MATTER TOTAL: 9.20 $ 3,262.50
# 1316830 v1
EXHIBIT “1-B”
EXHIBIT “2”
Summary of Requested Reimbursement Of Expenses for this Time Period Only [If this is a final
application which does not cumulate prior interim applications, a separate summary showing cumulative
expenses for all applications is attached as well]
1. Filing Fees $ 838.00

2. Process Service Fees $ 60.00
3. Witness Fees $ 0
4. Court Reporter Fees and Transcripts $ 1,769.60
5. Lien and Title Searches (Title Report) $ 1,250.00
6. Photocopies $10,388.69
(a) In-house copies ( 31,723 @ 0.204/page $6,344.60)
( 3,403 color copies @ $1.00/page $3,403.00)
(b) Outside copies by IKON ($ 641.09)
7. Postage $ 931.30
8. Overnight Delivery Charges $ 181.82
9. Outside Courier/Messenger Services $ 119.85
10. Long Distance Telephone Charges $ 1,426.27
11. Long Distance Fax Transmissions
(6 copies at 0.784/page) $ 4.68
12. Computerized Research $18,365.58
13. Travel $ 428.04
(a) Transportation ($ 184.04 )
(b) Lodging ($ 0)
(c) Meals ($ 244.00 )
14. Other Permissible Expenses (must specify and justify) $ 1,855.51
(a) Recording, Public Records ($ 1,068.50 )
(b) Certified Copies ($ 211.05 )
(c) Document production/preparation ($ 323.75 )
(d) Meeting Expense ($ 133.06 )
(e) Other/ Misc. ($ 119.15 )
Total Expense Reimbursement Requested $37,619.34
# 1316981 v1
EXHIBIT “2”
EXHIBIT “3”
Time Records
EXHIBIT “3”
Time by Timekeeper
Client / Matter 351016 Dunn, Marcia -Trustee 4 Merendon Mining (Nevada), Inc.
Bahnsen, Jeffery "Jeff"

Activity Code 002 Asset Disposition
1/12/2012 1.40 630.00 Review asset purchase agreement and related documents in
connection with sale of mining claims.
1/19/2012 2.60 1,170.00 Attention to issues in connection with sale of mining

claims to Golf Hill Minerals (.8); telephone conferences
with purchaser's counsel (.6); prepare closing documents
(1.2)
1/20/2012 4.60 2,070.00 Attention to issues in connection with sale of mining

claims to Golf Hill Minerals (2.0); telephone conferences
with purchaser's counsel (.7); prepare closing documents
(1.9)
1/23/2012 3.20 1,440.00 Prepare closing documents (1.9); address issues raised by
purchaser's counsel regarding ownership (1.3).
1/24/2012 3.10 1,395.00 Prepare for closing and finalize documents (2.2); telephone
conferences with purchaser's counsel (.9)
1/25/2012 3.90 1,755.00 Attention to matters relating to closing on sale of mining

claims to Gold Hill Minerals.
1/27/2012 0.60 270.00 Attention to post closing issues and transfer of interests in
stock of Left Hand Ditch company
1/30/2012 0.80 360.00 Attention to post closing issues, including transfer of rights
in stock of Left Hand Ditch Company (.5); discussions
with purchaser's counsel (.3)
1/31/2012 1.60 720.00 Prepare affidavit of lost stock certificate (1.1); discuss
issues with counsel for purchaser and counsel for Left
Hand Ditch Company (.5)
2/1/2012 2.10 840.00 Attention to post closing matters and resolution of issues
regarding transfer of water rights (1.6); discussion of issues
with counsel for purchaser and client (.5)
Total Activity Code 002 23.90 $10,650.00
Total for Timekeeper Bahnsen, Jeffery " 23.90 $10,650.00
Tuesday, May 22, 2012 Page 1 of 149

Bartling, Emma
Activity Code 010 Litigation
6/13/2011 1.90 95.00 Prepare responsive documents for up-coming

production.
6/16/2011 2.40 120.00 Continue imaging responsive records prior to producing

same.
6/17/2011 2.30 115.00 Export and Finalize responsive records for production of
same.
Total Activity Code 010 6.60 $330.00
Total for Timekeeper Bartling, Emma 6.60 $330.00

Blanco, Leyza F
Activity Code 001 Asset Analysis and Recovery
10/5/2010 0.20 83.00 Merendon - Review and respond to correspondence from I.

Reich regarding discussions with buyer.
Total for Timekeeper Blanco, Leyza F 0.20 $83.00

Burnett, Jason B
Activity Code 004 Case Administration
11/24/2009 3.50 1,277.50 Review documents and follow up regarding drafting of

complaint
11/25/2009 3.00 1,095.00 Continued review regarding drafting of complaint
11/25/2009 0.90 328.50 Follow up regarding Complaint
11/27/2009 2.50 912.50 Review/edit Complaint
12/1/2009 1.80 657.00 Review/Follow up regarding complaint
12/16/2009 2.00 730.00 Review complaint, motion, etc. regarding injunction

relief
Total for Timekeeper Burnett, Jason B 13.70 $5,000.50

Freyman, Shayna A
Activity Code 013 Stay Relief Proceedings
9/13/2010 0.40 50.00 Analysis and review of case law and secondary sources
regarding restraints on alienation.
Total for Timekeeper Freyman, Shayna 0.40 $50.00

Kim, Ji Hun
1/7/2010 2.40 504.00 Conduct research regarding issues involving this case, and
general background.
1/20/2010 2.60 546.00 Research Hague Convention, proper modes of international

service of process, and review relevant documents.
1/21/2010 2.30 483.00 Analysis of issues in connection with service of process in

foreign countries.
1/22/2010 2.00 420.00 Research and prepare memo regarding proper service of
process in foreign countries.
2/1/2010 3.00 630.00 Research proper forms of service on international

defendants.
2/2/2010 1.90 399.00 Research service of process (1.6) and speak to

professionals regarding if mail service is proper (.3).
2/3/2010 0.70 147.00 Research service of process.
2/4/2010 1.50 315.00 Research service of process issues (1.1), contact counsel in
foreign nations to inquire (.4)
2/5/2010 1.50 315.00 Research (1.2) and send out correspondence to foreign
counsel regarding proper foreign service of process (.3)
2/8/2010 1.40 294.00 Research (1.2) and email in regards to foreign service of
process (.2)
Total for Timekeeper Kim, Ji Hun 19.30 $4,053.00

Leibner, Jarred
7/8/2010 2.50 312.50 Researched and analyzed cases regarding installment land
sales whether they can be treated as purchase money
mortgages (.8); Reviewed case materials (.7); Read and
analyzed cases discussing the law in both Nevada and
California on this issue (1.0).
7/9/2010 8.80 1,100.00 Reviewed previous orders in the case and reviewed
discovery documents in order to analyze issue regarding
debtor's property rights in the mining rights that they
purchased under an installment land sale contract (1.7);
Reviewed language in the contr act and addendum's to
whether this contract can be treated as a purchase money
mortgage and entitle the debtor to a constructive trust over
a portion of equity in the mines (2.0); Researched and
analyzed materials regarding installment land sales and
how they are treated under California and Nevada law
(2.5); began researching the various requirements under
California and Nevada regarding what a seller must do to
foreclose on its property and who retains the property
rights if any when the title is in escrow (2.6)
7/12/2010 7.10 887.50 Researched and analyzed statutes, cases, secondary

sources, regarding treatment of installment sales under
Nevada and California law, regarding whether payment of
property taxes provides notice to a subsequent purchaser
(1.8), regarding what procedur es a seller must go through
in order to reclaim complete title to the property (2.3),
regarding whether the debtor's estate includes property that
is being held in escrow that is neither owned by the
debtor/purchaser nor the seller (1.2), and began o rganizing
arguments and reviewing case documents in order to draft a
legal memorandum regarding the trustee's recovery based
on the debtor's legal or equitable title to the gold mines in
controversy (1.8)
7/13/2010 4.30 537.50 Reviewed case documents and legal research in order to
organize arguments for legal memo regarding whether the
debtor's estate has a property interest in mining claims (1.7)
Conducted additional research to support argument under
Nevada law regarding the treatment of Installment Land
Sales Contracts (1.2), began drafting summary of the facts
and argument in order to assert a legal and equitable
interest in the property (1.4)
7/14/2010 8.20 1,025.00 Researched and analyzed case law regarding Nevada and
California treatment of installment land sale contracts (2.3)
Reviewed requirements under both jurisdictions to perform
nonjudicial foreclosure and the various notice requirements
to determine whe ther the seller complied with these
requirements prior to terminating the debtor's interest in the
property (1.7); Reviewed research regarding whether the
subsequent purchaser in this case had actual or constructive
notice regarding the debtor's inte rest in the Mine (2.0).
Strategized how to put research together for legal memo in
effort to reach a favorable settlement (2.2)

7/15/2010 9.20 1,150.00 Drafted legal memo regarding whether the debtor has a
property interest in the Discovery Day Mine, where the
debtor was in default under its installment land sale
contract (4.1). Analyzed and conducted additional research
regarding specific facts of the case and language in
Amended Sales contract in order to strengthen arguments,
and conducted additional research for cases that arose in
bankruptcy context (5.1)
7/16/2010 1.40 175.00 Conducted final research and edits in order to complete
legal memo regarding whether the debtor has a property
interest in the Mine.
7/23/2010 4.30 537.50 Conducted additional research and summarized arguments

regarding avoidance of the Seller's In REM of Agreement
termination as a preference and whether Amendment to
California nonjudicial foreclosure process in 1993 affects
this analysis (2.1) Conduct ed additional research regarding
whether the Debtor maintains an interest in the Mine under
a theory of constructive trust or equitable lien. (2.2)
7/26/2010 2.10 262.50 Made additional revisions to legal memo regarding whether
the debtor has a property interest in the California mine
(1.2) and updated the section that contained the facts to
reflect the updated information that contains documents
that the debtor has made payments in excess of $5 million
dollars towards the purchase price of the mine that was
purchased under an an Installment Land Sale Contract
(.9)
7/27/2010 0.90 112.50 Reviewed legal memo regarding whether the Debtor has a
property interest in the Discovery Day Mine (.9)
7/29/2010 2.70 337.50 Researched issues regarding federal mining laws and
additional equitable theories of recovery for the debtor
8/5/2010 2.80 350.00 Research regarding whether the debtor can recover
property or payments made towards installment land sale
contract in California and whether the debtor can recover
under theories of constructive trust, equitable lien, or
unjust enrichment (1.8) revis ions and analysis into final
memo that analyzes whether debtor has a property interest
in the Mine (1.0)
8/6/2010 4.00 500.00 Researched and analyzed Federal Mining laws and other
state and local mining regulations (2.0); analyzed cases
discussing legal and equitable title the mining claims under
this legislation (2.0).
9/22/2011 0.20 35.00 Review of documents and quitclaim deeds regarding

Arizona Mines
10/10/2011 1.10 192.50 Reviewed and revised language in inspection release of

liability
1/16/2012 1.90 332.50 Reviewed and summarized research regarding avoidance of

mechanics lien under Colorado statute (1.5). Strategy
conference with P. Scott and M. Lessne regarding relevant
legal issues and further research (.4)
1/16/2012 2.70 472.50 Strategy with M. Lessne and Pat Scott regarding legal
arguments regarding postjudgment interest and attorneys
fees for purposes of settlement (.4). Reviewed, researched
and analyzed further legal authority (2.3)
1/31/2012 0.10 17.50 Correspondence with J. Sakalo's assistant regarding

obtaining quitclaim deed.

2/29/2012 0.20 35.00 Correspondence, strategy, and negotiation regarding early
payoff for Discovery Day Mine.
7/27/2010 0.50 62.50 Prepared for settlement negotiation meeting (.5)
7/28/2010 3.00 375.00 Settlement negotiation meeting at Bilzin Sumberg Miami

office regarding treatment of the prior Orders that were
entered as well as discussions regarding settlement over the
Debtor's interest in the Mine.
9/21/2011 6.70 1,172.50 Reviewed and analyzed documents and pleadings for
response to Garfinkle's objection to the trustee's motion to
approve settlement with the Caldwell Estate. Made evisions
to Joint Response.
1/20/2012 1.10 192.50 Researched and analyzed whether settlement agreement

and order approving settlement agreeement have been
complied with re: Discovery Day Mine.
1/23/2012 0.50 87.50 Correspondence regarding discovery day settlement

agreement.
1/26/2012 0.20 35.00 Reviewed notes regarding discovery day settlement.

Correpondence with J. Sakalo regarding quitclaim deed
and payment. Reviewed files regarding previously sent
draft of quitclaim deed.
1/30/2012 0.10 17.50 Correspondence regarding discovery day settlement.
2/1/2012 1.10 192.50 Correpondence regarding compliance with settlement and

order regarding Discovery Day. Reviewed and analyzed
quitclaim deed and reviewed docket regarding legal
description of Discovery Day Mine.
2/15/2012 1.40 245.00 Correspondence regarding alternative settlement regarding

Discovery Day Mine (.3). Reviewed and analyzed
settlement agreement and order (.3). Analyzed various
settlement and interest rate scenarios to evaluate settlement
proposal (.8)
2/16/2012 0.50 87.50 Correspondence regarding alternative settlement regarding

Discovery Day Mine.
3/1/2012 0.30 52.50 Correspondence regarding settlement for discovery day

mine (.1); researched and reviewed settlement agreement
and order regarding deadline to obtain payment of the
modified settlement amount (.2)
9/27/2011 2.00 350.00 Attended hearing regarding 363 sales procedures and
settlement of Glory Hole
2/7/2012 0.10 17.50 Correspondence with M. Lessne regarding research of

attorneys fees and costs under Colorado law.
2/9/2012 0.10 17.50 Correspondence regarding compliance with settlement

agreement and order for Discovery Day.

Activity Code 005 Claims Administration and Objections
9/23/2011 1.80 315.00 Research regarding standing issue to file Proof of claim
9/23/2011 2.90 507.50 Review of Garfinkle's response to Trustee's claim objection

and analyzed documents related to standing.
9/26/2011 1.10 192.50 Researched and analyzed case law regarding derivative
standing to file a proof of claim as a creditor
9/30/2011 0.70 122.50 Objection to amended claim of Paul Garfinkle
10/17/2011 0.20 35.00 Objection to Paul Garfinkle's Amended Claim No. 482
9/26/2011 2.10 367.50 Researched and analyzed case law holding that Power of
Attorney not coupled with an interest is revocable by the
principal
9/27/2011 2.30 402.50 Drafted memo regarding Garfinkle's standing
10/17/2011 0.40 70.00 Conference call to discuss liability issues related to

property inspections
10/18/2011 0.90 157.50 Research regarding whether a judgment during the

preference period can be avoided when there was a
statement of lien recorded prior to the preference period
10/18/2011 2.70 472.50 Researched and analyzed cases regarding whether lien
could be stripped from entity that became a debtor only
after the substantive consolidation
10/19/2011 1.80 315.00 Researched and analyzed Florida law on mechanics liens
and requirements to perfect
11/3/2011 0.60 105.00 Researched and summarized legal issues regarding the
validity of Worldwide machinery's lien
1/13/2012 1.30 227.50 Researched and analyzed whether postpetition judgment

could be avoided where statement of lien was recorded
more than 90 days prior to petition date.
1/13/2012 0.80 140.00 Researched and analyzed case law, regarding nunc pro tunc
order and substantive issues.
1/14/2012 3.30 577.50 Researched and analyzed statutes and case law from
Colorado regarding requirements to perfect a mechanics
lien.
1/16/2012 1.60 280.00 Researched and analyzed issue of federal preemption

regarding postjudgment interest (.5); Researched and
shepardized cases from the 11th Circuit (.4). Researched
and analyzed cases regarding postjudgment attorneys fees
(.7)
1/16/2012 2.70 472.50 Researched and analyzed case law and statutes regarding
postjudgment rate of interest and award of attorneys fees in
Colorado

1/17/2012 1.40 245.00 Researched and analyzed Colorado statutes and case law
regarding right to recover postjudgment contractual rate of
interest and attorneys fees based the contract.
1/18/2012 1.90 332.50 Researched and analyzed Colorado statutes and case law
regarding right to recover postjudgment contractual rate of
interest and attorneys fees based the contract.
1/20/2012 1.70 297.50 Research and strategy with Pat Scott and M. Lessne
regarding postjudgment and postpetition fees and costs of
secured creditor, including whether a proof of claim needs
to be filed in order to recover under 506(b) as a holder of
an allowed secured cla im.
2/2/2012 0.60 105.00 Reviewed and revised quitclaim deed (.3). Correspondence
with J. Sakalo regarding same (.3).
2/6/2012 0.50 87.50 Reviewed and revised redlines to discovery day quitclaim
deed (.3). Correspondence with J. Sakalo regarding same
(.2)
12/9/2011 0.40 70.00 Reviewed documents and correspondence regarding

strategy of whether to file motion for relief for Dolen
Springs mine under section 549.
Activity Code 014 Tax Issues
9/22/2011 0.30 52.50 Email and phone correspondence regarding whether there
are any tax assessments on Merendon Mining Property in
Boulder County, Colorado.
Total for Timekeeper Leibner, Jarred 116.10 $17,227.50

Lessne, Michael D
6/10/2010 4.00 760.00 Conference with W. Capstick and P. Garfinkle re:

Discovery Day Mine sale and deed, and additional
defendants to be served (1.5); researched American Sierra
Gold Corp and Discovery Day Mine (1); further prepared
motion for contempt and sanctions for violation of
automatic stay (1); reviewed service of summary judgment
(.2); conference with I. Reich re: motion for violation of
stay (.3)
7/12/2010 1.50 285.00 Further prepared application for auctioneer, affidavit, and
order on same (.3); conference with I. Reich re: same (.3);
exchanged correspondence with Fisher Auctioneers re:
same (.2); reviewed and revised Nordic's agreed motion to
pay R. Brodsky $1 0,000 (.5); conference with I. Reich re:
same (.2)
7/23/2010 0.50 95.00 Reviewed Memorandum by J. Leibner on the Discovery

Day Mine (.2); correspondence with J. Leibner re: same
(.3)
8/9/2010 0.80 152.00 Correspondence with L. Weltzer re title search of Colorado

Mining Properties and U.S. Merendon Mining Entities (.4);
reviewed production from L. Weltzer re title (.4)
1/11/2011 0.10 21.50 Conference with Garfinkle re mines (.1)
1/18/2011 1.00 215.00 Prepared listing of recorded interests in Colorado Mining

Properties (.5); conference with F. Santos re property (.3);
correspondence with M. Dunn re same (.2)
2/3/2011 1.20 258.00 Conference with T. Cazier and E. Crosby from the CO Div
of Reclamation re the Colorado mines (1); correspondence
with M. Dunn and I. Reich re same (.2)
2/4/2011 0.20 43.00 Reviewed correspondence from E. Crosbey re CO

Reclamation and the Bueno mine
2/10/2011 0.30 64.50 Correspondence with T. Cazier re Bueno Mine status
3/10/2011 0.20 43.00 Reviewed notice of reclamation and correspondence with

M. Dunn's office re same
3/29/2011 0.20 43.00 Correspondence with F. Santos re colorado mines
4/26/2011 0.20 43.00 Correspondence with F. Santos re prospective purchaser T.

Millar
5/2/2011 0.10 21.50 Correspondence with TJ Millar re letter of intent to

purchase Glory Hole Mining Properties
5/13/2011 0.20 43.00 Correspondence with D. Koff and correspondence with F.

Santos re legal description of Glory Hole Mining
Properties
6/20/2011 0.10 21.50 Correspondence with F. Santos re prospective purchaser B.

Young
6/22/2011 0.30 64.50 Correspondence with F. Santos and I. Reich re Glory Hole
mining properties
6/29/2011 0.30 64.50 Strategy re potential bidders for Glory Hole

6/30/2011 1.50 322.50 Conference with G. Papas, D. Murray, I. Reich, F. Santos,
and L. Fisher re potential bid on Glory Hole mining
properties (1); conference with F. Santos and I. Reich re
same (.3); correspondence with M. Dunn re same (.2)
7/27/2011 0.30 64.50 Reviewed correspondence from N Frank re equipment on

mines in Boulder county
10/4/2011 0.90 202.50 Correspondence and conference with T Plumber of the Left
Hand Ditch Company re Merendon's shares of stock and
water rights in CO affecting the Bueno and Black Rose
mines (.5); reviewed stock certificate (.2); correspondence
and conference with S Doyl e re Left Hand Ditch Co (.2)
1/27/2012 2.80 630.00 Reviewed judgment in favor of Dolen Springs Mine and
Development and against MMI and transfer to Silma, and
strategy and analysis re same, including conferences with P
Scott and I Reich re avoidability of transfers (1.5);
conferences with attorney fo r Dolan Springs Mine &
Development K Parker re circumstances for transfer (.5);
prepared memorandum for M Dunn and corresp and conf
with M Dunn re same (.8)
7/15/2010 3.00 570.00 Prepared trustee's motion for the sale of three mines
7/16/2010 2.00 380.00 Further prepared sale motion and of Colorado Mining
Properties and complaint
7/16/2010 0.50 95.00 Reviewed application for auctioneer (.3); correspondence

re: same (.20)
7/19/2010 2.00 380.00 Prepared motion for sale of Colorado Mining Properties
7/20/2010 3.00 570.00 Further prepared motion for sale of Colorado Mining
Properties
7/23/2010 6.50 1,235.00 Further prepared motion to sell free and clear of liens
claims and encumbrances, and sale procedures
7/26/2010 6.50 1,235.00 Further prepared motion to sell Colorado Mining

Properties (3.0); prepared complaint to sell pursuant to
363(h) and for declaratory judgment (3.5)
7/27/2010 4.70 893.00 Further prepared 363 motion to sell Colorado Mining
Properties and further prepared complaint to sell co-owners
interest in same (3.5); conference with N. Mancuso re:
same (1); conference with I. Reich and S. Stirling re: title
search (.2)
7/28/2010 4.00 760.00 Prepared for (2.0) and attended conference with J. Sakalo,
I. Reich, and J. Leibner re: the Discovery Day Mining
Property and ownership claims (2.0)
7/29/2010 3.00 570.00 Further prepared complaint (.5); conference with I. Reich,
P. Scott, N. Mancuso, J. Leibner, and S. Stirling re: sale of
Colorado mines (2.3); conference with S. Stirling re: title
search of mines (.2)
8/2/2010 5.50 1,045.00 Further prepared motion for sale pursuant to 363(f)(4)
(2.0); researched cases providing for the the sale of
disputed interests (2.0); prepared memo re same (1.50)

8/3/2010 1.20 228.00 Further prepared sale motion and complaint (.10;
conference with S. Stirling re title search (.2)
8/5/2010 9.20 1,748.00 Further prepared motion for the sale of Colorado Mining
Properties and complaint to determine validity, priority,
and extent of liens, claims, encumbrances, and interest
(2.0); researched 363(f)(4) cases allowing for the sale of
property free and cle ar of ownership interests (7.2)
8/6/2010 5.50 1,045.00 Further prepared sale motion and complaint
8/6/2010 0.60 114.00 Confernce with L. Weltzer re title issues
8/9/2010 0.70 133.00 Prepared revised letter of intent (.4); correspondence with
H. Winderman re same (.3)
8/10/2010 0.20 38.00 Prepared documents for conference with I. Reich re sale
motion and complaint
8/10/2010 1.50 285.00 Conference with I. Reich and S. Stirling re title issues, sale,
and case
8/11/2010 1.90 361.00 Researched and finalized sale motion (1.6);

correspondence with H. Winderman re letter of intent, sale
motion, deposit, and operating agreement (.3)
8/11/2010 1.50 285.00 Conference with M. Morrison re Wabuska Mining's

Discovery Day mining claims (1.3); correspondence with
M. Morrison, I. Reich, and S. S. Stirling re same (.2)
8/11/2010 0.20 38.00 Correspondence with I. Reich and S. Stirling re N. Franks

equipment claims at Bueno Mine and sale of equipment
8/12/2010 1.30 247.00 Correspondence with H. Winderman re permission to

speak to M. Salit re sale (.1); correspondence with M. Salit
re same (.1); telephone conference with M. Levin re Bueno
mine, equipment, N. Frank, and L. Taylor (.6); memo to I.
Reich re same (.4); cor respondence with M. Levin re same
(.1)
8/13/2010 2.70 513.00 Conference with I. Reich, M. Salit, and C. Pierce re sale of
Colorado Mining Properties (.8); conference with S.
Stirling re M. Levin and sale of mucker (.2); conference
with F. Santos re auction (.6); correspondence with F.
Santos, I. Reich, and S. Stirling re same (.6);
correspondence with M. Levin re same (.2); reviewed
motion to sell equipment (.3)
8/16/2010 1.00 190.00 Conference with I. Reich re sale, sale motion, complaint,
asset purchase agreement, and auction
8/16/2010 3.00 570.00 Further prepared sale motion and complaint
8/17/2010 2.30 437.00 Further prepared sale motion
8/17/2010 3.50 665.00 Correspondence with S. Stirling re complaint and titling of

mines (.4); correspondence with L. Weltzer re titling (.4);
reviewed title documents (1.2); conference with F. Santos
re same (.7); telephone conference with N. Frank re
equipment (.8)
8/20/2010 0.30 57.00 Conference with I. Reich re sale motion and complaint (.2);
correspondence with L. Weltzer re titling of mines (.1)
8/25/2010 0.30 57.00 Further prepared complaint by adding additional

information re Norm Frank

8/31/2010 0.30 57.00 Conference with F. Santos re status of sale and auction
materials
9/3/2010 2.70 580.50 Conference with I. Reich and S. Stirling re motion for
relief from stay, sale motion and Asset purchase agreement
(.5); finalized sale motion (2); correspondence with H.
Winderman re same (.2)
9/7/2010 0.30 64.50 Conference with I. Reich and H. Winderman re Asset

purchase agreement and deposit (.2); conference with S.
Stirling re deeds (.1)
9/10/2010 0.20 43.00 Conference with J. Armengol re Asset purchase agreement

and stalking horse procedures (.2)
9/13/2010 2.30 494.50 Amended sale motion and asset purchase agreement (2);
conference with I. Reich re same (.3)
9/15/2010 2.30 494.50 Revised Asset purchase agreement and Sale Motion to
incorporate 363(i) features (2.3)
9/16/2010 2.30 494.50 Further prepared complaint to determine validity, extent,

and priority of liens, claims and interests
9/17/2010 0.50 107.50 Conference with I. Reich re adversary complaint (.3);

conference with S. Stirling re same (.2)
9/20/2010 1.50 322.50 Further prepared complaint
9/21/2010 0.80 172.00 Conference with S. Stirling and I. Reich re complaint (.5);
finalized complaint (.3)
9/29/2010 5.00 1,075.00 Correspondence with I. Reich re stalking horse bidder due
dilligence and tasks (.5); reviewed objection to sale motion
(.2); reviewed motion for relief from stay from SE Bank
(.3); conference with A. Brodsky and S. Stirling re same
(.2); prepared con tinuance motion and motion to strike
(3.5); correspondence with I. Reich re same (.3)
10/6/2010 0.20 43.00 Prepared Asset purchase agreement for potential new
buyer
10/14/2010 0.20 43.00 Conference with S. Stirling and correspondence with I.

Reich re amended complaint
10/18/2010 0.70 150.50 Conference with I. Reich re sale of Colorado Mines (.5);
reviewed correspondence from I. Reich re same (.2)
10/20/2010 0.50 107.50 Correspondence with S. Stirling re B. Frank and

complaint
11/5/2010 0.10 21.50 Reviewed correspondence from Jamestown Development

Co., Inc. re sale of mines and complaint
11/15/2010 0.30 64.50 Correspondence with Deputy Stanton re theft at Glory Hole
Mine
11/15/2010 0.40 86.00 Correspondence and conference with I. Reich and S.

Stirling re Geralynn Grieve
11/29/2010 0.60 129.00 T/C with A. Katz (USDOJ) and A. Madigan (EPA) re the
Colorado Mining Properties (.4); correspondence with S.
Stirling re titling of mining properties (.2)
1/13/2011 0.20 43.00 Reviewed offers on Black Rose Mine from F. Santos

1/27/2011 0.80 172.00 Conference with I. Reich, M. Dunn, F. Santos, and J. Welt
re sale of Colorado mines, and adversary proceedings
1/31/2011 0.60 129.00 Conference with R. Schatzman and I. Reich re adversary

proceedings and sale of mines
2/2/2011 0.40 86.00 Reviewed correspondence with F. Santos and I. Reich re:
sale (.2); correspondence with M. Dunn re Letter of Intent
with contingency (.2)
2/3/2011 0.20 43.00 Correspondence with F. Santos re sale of mines
2/7/2011 1.20 258.00 Conference with J. Sakalo re discovery day mine (.3);
conference with M. Dunn re same (.3); conference with A.
Madigan re EPA and limited liability of purchasers (.4);
conference with F. Santos re sale of mine (.2)
2/10/2011 0.90 193.50 Correspondence with M. Dunn re disposition of mines and

SEC conference (.7); conference re same (.2)
2/14/2011 0.10 21.50 Correspondence with F. Santos re sale of mines
2/15/2011 0.50 107.50 Correspondence and conference with I. Reich and F.

Santos re Colorado mines and Discovery Day mine
2/16/2011 0.10 21.50 Correspondence with J. Sakalo re Discovery Day mine
2/21/2011 1.70 365.50 Conference with I. Reich re Discovery Day mine (.1);
conference with I. Reich and M. Morrison (and
representatives from his client Wabuska) re offer to
purchase trustee's interest in the Discovery Day mining
properties (.6); reviewed filings involvin g P. Fagan and
Trinity Alps (.3); conference with J. Sakalo re his client's
offer to settle claims with the trustee (.5); correspondence
with trustee and F. Santos re same (.2)
2/22/2011 1.90 408.50 Correspondence with J. Moffa, J. Welt, I. Reich, and M.

Dunn re offer on Glory Hole (1); conference with I. Reich
re same (.5); correspondence with J. Sakalo re offer on
Discovery Day (.2); conference with I. Reich re same
(.2)
2/22/2011 0.40 86.00 Reviewed purchase and sale agreement between Discovery
Day LLC and Merendon and other documents evidencing
the transaction (.3); correspondence with F. Santos re same
(.1)
2/23/2011 0.50 107.50 Conference with M. Dunn, F. Santos, and I. Reich re offer
from Caldwell group on Glory Hole and on offer from
Fagen group on Discovery Day
2/23/2011 0.70 150.50 Conference with J. Sakalo re offer on Discovery Day (.4);
correspondence with I. Reich re same (.2); correspondence
with M. Dunn re results (.1)
2/24/2011 0.40 86.00 Correspondence with J. Sakalo re Discovery Day

settlement (.2); correspondence with M. Dunn and I. Reich
re same (.2)
3/1/2011 1.40 301.00 conference with I. Reich re Colorado mining properties

(.3); conference with I. Reich and J. Moffa re offer by
Fedrigon to be stalking horse bidder (1.1)
3/1/2011 0.50 107.50 Strategy re Colorado mining properties and offer by the
Fedrigons

3/1/2011 0.10 21.50 Correspondence with I. Reich re continuance of hearing on
sale motion and pretrials in order to secure stalking horse
bid
3/2/2011 0.30 64.50 Reviewed and revised email correspondence re continuance

of hearing on sale motion and pretrials (.2); conference
with I. Reich re same (.1)
3/4/2011 0.30 64.50 Finalized motion and order for continuance of hearing on
sale motion and pretrials

stipulation
3/9/2011 0.10 21.50 Reviewed filed order granting motion to continue sale
motion, and continuing pretrial conferences
3/15/2011 0.10 21.50 Correspondence with F. Santos re B. Kitzman as potential

purchaser
3/16/2011 1.50 322.50 Prepared responsive discovery re Clearwater Mining
3/16/2011 1.80 387.00 Prepared for and attended conference with M. Dunn, F.
Santos, I. Reich, and B. Mukamal re disposition of mining
properties and status of case
3/17/2011 0.10 21.50 Reviewed email from F. Santos re mining publications
3/22/2011 0.30 64.50 Reviewed settlement agreement and correspondence with I.

Reich and J. Sakalo re settlement agreement
3/24/2011 1.00 215.00 Conference with J. Sakalo re settlement of Discovery Day

Mine (.3); conference with H. Murelo's office re letter of
intent (.1); conference with I. Reich re both offers (.3);
reviewed settlement agreement with P. Fagen and Trinity
Alps (.3)
3/25/2011 0.80 172.00 Prepared letter to publications re interview of trustee and

disposition of mines
4/5/2011 0.60 129.00 Reviewed and revised settlement agreement with the
Discovery Day entities (.4); correspondence with I. Reich
re same (.2)
4/6/2011 1.50 322.50 Conference with I. Reich and J. Sakalo re settlement

agreement and reviewed same and strategy re same
4/7/2011 2.50 537.50 Finalized letters to mining publications (.3); prepared

motion and order to compromise controversy (1.8);
correspondence with M. Dunn re settlement (.1); final
review of settlement (.3)
4/8/2011 0.30 64.50 Correspondence with S. Doyle and F. Santos re offer on

Merendon Mining claims
4/8/2011 0.50 107.50 Reviewed Glory Hole mining claim documents
4/11/2011 0.20 43.00 Strategy re Glory Hole mining offers
4/11/2011 1.80 387.00 Conference and correspondence with S. Doyle re $495K

offer and terms, and stalking horse benefits (.5); conference
and correspondence with M. Dunn re same (.3); prepared
purchase agreement for S. Doyle (1)
4/12/2011 0.30 64.50 Correspondence and conference with F. Santos re Letter of

Intent from Allied Environmental

4/19/2011 0.20 43.00 Correspondence with S. Doyle re status update for sale of
Glory Hole properties
4/19/2011 0.30 64.50 Correspondence from M. Dunn, F. Santos and I Reich re

H. Murelo's interest in Discovery Day mine

settlement
4/19/2011 0.50 107.50 Correspondence with prospective bidders re sale of

Colorado mines
4/20/2011 0.70 150.50 Conference with Securities and Exchange Commission P.

Atkinson re sale of mining properties and recovery for
investors
4/20/2011 4.50 967.50 Prepared asset purchase agreement for sale of Glory Hole
Properties to purchaser S. Doyle, and prepared sale
procedures and notice procedures
4/20/2011 1.20 258.00 Conference with S. Doyle re sale of Glory Hole Mining
Properties
4/21/2011 0.20 43.00 Correspondence with I. Reich and M. Dunn re Asset

purchase agreement, sale procedures, and notice
procedures for Glory Hole (.1); and settlement of
Discovery Day (.1)
4/22/2011 0.20 43.00 Correspondence with F. Santos re sale of Discovery Day

Mine
4/22/2011 1.30 279.50 Conference with M. Dunn and I. Reich re Asset purchase
agreement, Sales Procedures, Notice Procedures, and bid
procedures for Glory Hole Mining Properties
4/22/2011 0.20 43.00 Further prepared Asset purchase agreement for sale of
Glory Hole Mining Properties
4/26/2011 1.80 387.00 Conference with I. Reich re sale contract, sale procedures,
and notice procedures (.8); further prepared same (1)
4/26/2011 0.10 21.50 Correspondence with I. Reich, M. Dunn, and F. Santos re

offer on Discovery Day from H. Muruelo
4/27/2011 0.70 150.50 Finalized Asset purchase agreement, Reviewed description

of property, Conference with F. Santos re Glory Hole
Mining Properties (.2); correspondence with L. Weltzer re
Glory Hole Mining Properties sale and role as
nontestifying expert (.3), correspon dence with S. Doyle re
Asset purchase agreement, Notice Proc, Sale Proc (.2)
5/4/2011 0.80 172.00 Prepared email to G. Treadway re Glory Hole mine and
Merendon mining Ponzi scheme
5/4/2011 1.80 387.00 Conf with L Weltzer, S. Doyle and F. Santos re sale of
Glory Hole Mining Properties and title, and strategy and
analysis re same
5/11/2011 1.60 344.00 Reviewed letter of intent with Manufasteners, Inc. (.1);
prepared asset purchase agreement, sale procedures, and
notice procedures for sale of Glory Hole to same (1.5)
5/12/2011 1.20 258.00 Conference and correspondence with D. Coff, attorney for
potential buyer Manufasteners, Inc., re sale of Glory Hole
Mining Properties (.5); conference with S. Doyle re sale of
Glory Hole Mining Properties (.7)

5/13/2011 1.10 236.50 Further prepared Asset purchase agreement and Sale and
Notice Procedures (.5); correspondence with S. Doyle re
same (.1); analysis and strategy re same (.5)
5/13/2011 0.30 64.50 Conference with S. Doyle re sale of Glory Hole Mining
Properties
5/13/2011 0.10 21.50 Correspondence with M. Dunn re inverview by G.

Treadway
5/16/2011 0.20 43.00 Reviewed correspondence from G. Tredway re Mining

Journal publication
5/16/2011 0.50 107.50 Correspondence with S. Doyle re status of entering into

Asset purchase agreement for sale of Glory Hole Mining
Properties (.2); correspondence with D. Koff re setting up
conference with L. Weltzer to discuss Glory Hole Mining
PRoperties (.2); confere nce with L. Weltzer re same (.1)
5/17/2011 0.20 43.00 Conference with L. Weltzer re Glory Hole title issues
5/17/2011 0.40 86.00 Conference with D. Koff re sale to Manufasteners
5/18/2011 0.50 107.50 Conference with L. Weltzer re title issues and title
commitment
5/20/2011 0.10 21.50 Correspondence with S. Doyle re Asset purchase

agreement, Sale Proc, and Notice Proc
5/26/2011 0.30 64.50 Reviewed redlined Asset purchase agreement changes
5/27/2011 0.90 193.50 Further prepared asset purchase agreement and

correspondence re same to M. Dunn, F. Santos, and I.
Reich (.8); correspondence with S. Doyle re Asset purchase
agreement (.1)
5/31/2011 0.20 43.00 Correspondence with F. Santos and M. Dunn re asset

purchase agreement
6/7/2011 1.30 279.50 Conference with S. Doyle re Asset purchase agreement and
access to Glory Hole (.3); conference and correspondence
with Gilpin County Sheriff Hartman re access to Glory
Hole (.8); correspondence with J. Welt, I. Reich, and M.
Dunn re Asset purchase ag reement (.2)
6/8/2011 3.30 709.50 Prepared motion to sell Glory Hole Miing Properties
6/10/2011 0.30 64.50 Conference with F. Santos re sale motion, auction, and
proposal for budget
6/16/2011 0.20 43.00 Correspondence with N. Nicole and E. Bartling re

responsive production for S. Doyle
6/20/2011 1.30 279.50 Correspondence with S. Doyle re compliance with Article

IX of Merendon Asset purchase agreement (.5); prepared
documents for submission to S. Doyle (.8)
6/27/2011 0.50 107.50 Conf with D. Murphy and I. Reich re sale of Glory Hole
Mining Properties
6/28/2011 0.80 172.00 Correspondence with M. Dunn re current status of sale of

Glory Hole Mining Properties
6/29/2011 0.50 107.50 Prepared letter to Boulder County Sheriff re trespassing
6/30/2011 0.70 150.50 Correspondence with Gilpin County Sheriff and with
Boulder County Sheriff re access to mining properties

6/30/2011 0.30 64.50 Correspondence with S. Doyle re sale contract and access
to Glory Hole mining properties
7/1/2011 0.20 43.00 Correspondence with S Doyle re security concerns at Glory

Hole
7/11/2011 0.10 21.50 Correspondence from S. Doyle re Glory Hole mine security
concerns
7/11/2011 0.60 129.00 Conference call with I. Reich, M. Dunn, and F. Santos re
settlement offer from Caldwell Estate, and sale of Glory
Hole mining properties
7/15/2011 1.00 215.00 Researched substantive consolidation nunc pro tunc and
effect on creditor asserting lien that was recorded
postpetition, including Bonham, Pearlman, American Way,
and Auto-Train
7/15/2011 0.30 64.50 Correspondence with D. Murray re auction of Glory Hole

and procedures (.2); correspondence with J. Moffa re offer
on Glory Hole (.1)
7/15/2011 0.10 21.50 Correspondence with A. Hampson re pretrial stipulation
7/15/2011 0.30 64.50 Conference with S. Doyle re status of Glory Hole mine,
security issues with respect to the tailings at the mine, and
Asset purchase agreement
7/18/2011 0.20 43.00 Prepared amended Exhibit A for stalking horse contract
and correspondence with M. Dunn re same
7/19/2011 0.20 43.00 Prepared amended Exhibit A to Asset purchase agreement

with GDC, and correspondence with S. Doyle re same
7/20/2011 0.60 129.00 Conference with A. Katz and A. Madagan re sale hearing
and DOJ and EPA concerns, and correspondence re
same
7/20/2011 1.00 215.00 Prepared for sale hearing by reviewing sale motion and
docket, and case law supporting same
7/21/2011 4.20 903.00 Prepared for hearing on sale motion and pretrial
conferences
7/22/2011 0.50 107.50 Correspondence with J. Moffa re confidential settlement

discussions
7/22/2011 0.30 64.50 Prepared orders denying sale motion, and continuing
pretrial conferences
7/22/2011 0.60 129.00 Conference with S. Doyle re denial of sale motion, and
correspondence re sale of Bueno and Black Rose mines
7/25/2011 1.00 215.00 Conference and correspondence with S Doyle re sale of

Bueno and Black Rose mining properties (.5);
correspondence with M Dunn re same (.3); strategy and
analysis re same (.3)
7/26/2011 0.30 64.50 Conference with S. Doyle re sale of Boulder mines
7/27/2011 0.50 107.50 Conference and correspondence with S Doyle re sale of

Bueno and Black Rose mining properties
7/27/2011 2.30 494.50 Prepared Asset purchase agreement and Sale and Notice
Procedures for sale of Bueno and Blackrose Mines

7/28/2011 1.80 387.00 Further prepared Asset purchase agreement for sale of
Bueno and Black Rose mining properties and
correspondence with S. Doyle re same (.8); reviewed title
work for Bueno and Black Rose mining properties (1)
7/29/2011 0.50 107.50 Corresopndence with Boulder County Sheriff re Bueno and
Black Rose mining properties (.3); correspondenc with S.
Doyle re same and Asset purchase agreement (.2)
8/2/2011 2.40 516.00 Strategy re sale of Bueno and Black Rose Mining
properties (.5); prepared sale motion (2.5)
8/3/2011 0.80 172.00 Prepared motion to continue hearing on motion requesting

judicial notice and pretrials
8/3/2011 0.20 43.00 Prepared amended Boulder County mines sale motion
8/3/2011 0.30 64.50 Correspondence with I Reich re N Frank's claim of

ownership of equipment
8/4/2011 0.30 64.50 Further prepared settlement stipulation with Caldwell

Entities (.2); correspondence with J Moffa re same (.1)
8/5/2011 0.90 193.50 Conference with P. Scott re settlement with Caldwell estate
(.3); correspondence and conference with J. Moffa re same
(.4); conference with M. Dunn re same (.2)
8/16/2011 0.60 129.00 Reviewed and revised stipulation for settlement with
Caldwell Estate (.5) and correspondence with J Moffa and
M Dunn re same (.1)
8/18/2011 1.20 258.00 Prepared motion for approval of settlement stipulation with
the Caldwell Entities and order granting same
8/18/2011 0.40 86.00 Correspondence with J Moffa and M Dunn re settlement

stipulation, and reviewed revisions to same
8/27/2011 0.20 43.00 Correspondence with S Doyle re Colorado reclamation and

Bueno and Black Rose Mines
8/27/2011 0.20 43.00 Correspondence with J Moffa and I Reich re objection to

settlement with Caldwell Estate
9/6/2011 0.50 112.50 Conference with I Reich and S Doyle re sale of Bueno and
Black Rose mines
9/7/2011 0.20 45.00 Correspondence with P Garfinkle re objections to

settlement and sale
9/8/2011 0.80 180.00 Conference with R Meacham re Worldwide Services final

judgment (.3); reviewed asserted judgment and dates to
determine avoidability, and strategy re proceeding with
adversary proceeding (.5)
9/16/2011 0.80 180.00 Conference with S Doyle re sale of Bueno and Black Rose
Mines, including liability exposure as superfund site,
necessity of water treatment plant, and liens on properties,
and amendment to Exhibit A
9/19/2011 0.10 22.50 Correspondence with F Santos re AZ mines
9/20/2011 0.30 67.50 Reviewed P Garfinkle's objection and prepared response to

same

9/26/2011 2.50 562.50 Prepared for hearing on sale motion, including review of
all file and all relevant documents, including title report,
Asset purchase agreement, amendment to Asset purchase
agreement, review of notice, and correspondence and
conference with S Doyle an d I reich
9/28/2011 0.50 112.50 Reviewed notes from hearing on sale motion and Asset
purchase agreement and sale motion in preparation of order
granting sale motion
9/30/2011 6.20 1,395.00 Prepared order granting sale of Bueno and Black Rose
Mining Properties, including sale procedures, sale hearing
notice, and notice procedures, and strategy and analysis re
same (5.7), including conference and correspondence with
I Reich and P Scott ( .5)
10/3/2011 4.00 900.00 Further prepared order granting sale motion of Bueno and
Black Rose mining properties
10/4/2011 0.40 90.00 Finalized order granting sale motion
10/5/2011 0.40 90.00 Reviwed order granting motion for sale and strategy re
service
10/5/2011 0.30 67.50 Correspondence with A Katz re EPA's view regarding

dismissal of adversary proceeding
10/7/2011 0.30 67.50 Reviewed and prepared motion to continue pretrial

conference and motion for judicial notice
10/7/2011 0.30 67.50 Correspondence and conference with S Doyle re Glory

Hole mining property
10/19/2011 0.10 22.50 Correspondence with J Moffa and M Dunn re settlement

proceeds
10/20/2011 0.20 45.00 Reviewed inspection waiver and release of liability
10/27/2011 0.40 90.00 Conference with S Doyle re proceeds from Glory Hole
settlement (.2); conference with L Weltzer re same (.2)
mines (.2); conference with L Weltzer re title commitment
(.1)
10/27/2011 0.30 67.50 Correspondence with M Dunn re distribution of Glory

Hole settlement proceeds
10/27/2011 0.70 157.50 Reviewed order granting sale of Bueno and Black Rose
mines and prepared service of Order, including
correspondence with J Serrano and F Santos
10/31/2011 0.20 45.00 Correspondence with F Santos re service to prospective

purchasers of Boulder County mines of Order Granting
motion to sell
10/31/2011 0.20 45.00 Correspondence with L Weltzer and corresp with S Doyle
re payment pursuant to settlement agreement with Caldwell
Estate of Glory Hole mining properties
11/2/2011 0.40 90.00 Conference and correspondence with F Santos and L

Fisher re auction of Black Rose and Bueno mines,
marketing plan, and service in Colorado newspapers
11/4/2011 0.40 90.00 Correspondence with S Doyle and M Dunn re expense

reimbursement to GDC, including review of GDC expenses
for Glory Hole

11/7/2011 0.20 45.00 Correspondence with M Dunn's office re payment of Glory
Hole settlement funds
11/8/2011 0.30 67.50 Conference with D Larson re sale of Bueno and Black
Rose Mining Properties
11/9/2011 0.30 67.50 Conf with L Weltzer re water rights in Colorado and in
Glory Hole legal description
11/10/2011 1.10 247.50 Prepared auction notices for Boulder County newspapers
and correspondence with F Santos re same
11/21/2011 0.20 45.00 Corresp with S Doyle re Sentinel as substantively

consolidated entity
12/1/2011 0.30 67.50 Corresp and conf with F Santos re auction of bueno and
black rose mining properties and service
12/6/2011 1.40 315.00 Reviewed service and C/S for sale order, sale procedures,
and auction notice (1); corresp and conf with F Santos and
M Navarro re service to prospective purchasers and by
publication (.3)
12/7/2011 0.30 67.50 Further prepared certificate of service re Order granting

Sale of Boulder County mines
12/7/2011 0.50 112.50 Strategy re service of order granting sale motion and
approving k and sale procedures
12/12/2011 0.50 112.50 Reviewed title commitment for Bueno and Black Rose
Mining Properties and documents in support of same
12/14/2011 1.00 225.00 Corresp and conf with F Santos re sale and auction of
Bueno and Black Rose mines, and strategy and analysis re
same
Mines
12/16/2011 0.30 67.50 Corresp with F Santos re title commitment, including

review of same
12/20/2011 0.10 22.50 Conf with F Santos re sale of Bueno and Black Rose
mines
12/20/2011 0.30 67.50 Reviewed documentation from S Doyle re Bueno and

Black Rose Mining Properties in preparation for auction
12/27/2011 0.50 112.50 Conf with F Santos, L Fisher, and J Welt re sale procedures
and amended procedures to extend deadline to accept
deposits for sale of Bueno and Black Rose Mines, and
potential bidders (.3); corresp with S Doyle re: extending
deadline for deposit (.1); correspondence with M. Dunn re
same (.1)
12/28/2011 0.20 45.00 Conference wtih F Santos re sale procedures for sale of
Bueno and Black Rose mines
12/29/2011 0.30 67.50 Corresp and conf with F Santos re asset purchase
agreement for Bueno and Black Rose Mining Properties
1/3/2012 2.00 450.00 Correspondence with Auctioneer re Asset purchase

agreement with D Badner (5) and preparation for Auction
and Sale Hearing, including review of record, notice of
Auction, and marketing activities (1.5)
1/3/2012 0.50 112.50 Conferences and correspondence with S Doyle re Auction

of Bueno and Black Rose Mining Properties

1/4/2012 3.80 855.00 Prepared order approving sale of Bueno and Black Rose
Mining Properties to Successful Bidder
1/5/2012 4.00 900.00 Further prepared order approving sale of Bueno and Black
1/6/2012 0.30 67.50 Corresp with Bueno and Black Rose Mining Properties'
Buyer's attorneys T Li and B Grossman re closing
1/6/2012 0.30 67.50 Corresp with J Bahnsen and I Reich re closing of sale of
Bueno and Black Rose Mining Properties
1/9/2012 0.80 180.00 Corresp and conf with T Li re sale of Bueno and Black
1/9/2012 0.50 112.50 Further prepared order approving sale
1/11/2012 2.40 540.00 Conf with Badner's counsel re order granting sale of Bueno
and Black Rose Mining Properties (.5); further prepared
same (1.2); corresp with T Li re same (.2); reviewed
revisions to sale order (.5)
1/12/2012 0.80 180.00 Further prepared sale order (.3); conf with I Reich re same
(.5)
1/13/2012 0.20 45.00 Corresp with T Li re order granting sale of Bueno and
1/17/2012 0.10 22.50 Corresp with T Li re order approving sale of Bueno and
Black Rose Mining Properties
1/18/2012 0.10 22.50 Corresp with T Li and S Williams re Order approving sale
of Bueno and Black Rose Mines
1/18/2012 0.20 45.00 Corresp with R Meacham re Order approving sale of

Bueno and Black Rose Mines and asserted lien on same
1/19/2012 0.10 22.50 Correp with I Reich re Discovery Day settlement

obligations
1/19/2012 0.20 45.00 Coresp with R Meacham re order granting sale of bueno
and black rose mining properties
1/19/2012 0.30 67.50 Corresp with J Bahnsen re closing, including legal

description and title report
1/19/2012 0.10 22.50 Strategy re Dolen Springs AZ mines
1/20/2012 0.50 112.50 Correspondence and conferences with J Bahnsen and with
buyer's counsel re closing of sale
1/23/2012 0.20 45.00 Corresp with T Li, J Bahnsen and I Reich re recording of
sale order
1/23/2012 0.20 45.00 Strategy re estate's interest in Dolen Spring mines and title
report
1/24/2012 0.50 112.50 Corresp with T Li re closing issues for sale of Bueno and
1/24/2012 0.50 112.50 Reviewed and further prepared trustee's deed and bill of
sale (.3); corresp with T Li re closing (.2)
1/25/2012 1.90 427.50 Strategy re title insurance report and exceptions, and
closing on Sale of Bueno and Black Rose Minnig
Properties (.8); conference with T Li re same and sale as is
where is with no representations or warranties (.5); corresp
with I Reich and J Bahnsen re same and closing (.3); conf
with J Bahnsen re all (.3)

1/26/2012 0.10 22.50 Reviewed receipt of wire for $540,000
1/31/2012 0.30 67.50 Reviewed statement of lost stock certificate (.2); corresp
with M Dunn re same (.1)
2/6/2012 0.10 22.50 Corresp with S Doyle re expense reimbursement for sale of
mines.
2/10/2012 0.10 22.50 Corresp with F Santos re South American Mines
2/17/2012 0.20 45.00 Conf with P Scott re settlement with Worldwide Rental
2/17/2012 0.10 22.50 Corresp with S Doyle and M Dunn re expense

reimbursement and deposit with respect to Bueno and
Black Rose Mines
2/20/2012 0.10 22.50 Corresp with I Reich and M Dunn re settlement of

Worldwide Machinery's claim
2/26/2012 0.80 180.00 Prepared settlement stipulation with Worldwide Rental
2/27/2012 0.60 135.00 Corresp with T Li re mining claims for Bueno and Black
Rose Mining Properties (.2) and South American mining
properties (.2); correp with F Santos re South American
holdings (.1)
2/27/2012 0.20 45.00 Conf and corresp with M Dunn re return of deposit and
legal authority for return of deposit
2/28/2012 0.10 22.50 Corresp and conf with A Castro re return of deposit to S
Doyle and corresp with S Doyle re same
2/28/2012 0.40 90.00 Review of settlement changes and revisions to settlement

(.2), and corresp with R Meacham re same (.2)
3/6/2012 0.30 67.50 Corresp with B Grossman re Badner's claim re Glory

Development Company and violation of automatic stay
3/7/2012 0.10 22.50 Corresp with R Meacham re settlement on amount of lien

on proceeds from sale on Bueno and Black Rose Mining
Properties
3/12/2012 1.00 225.00 Conference with S Williams and H Berman re violation of

automtic stay by stalking horse bidder (.5) conf with S
Doyle re same (.5)
3/14/2012 0.20 45.00 Reviewed redlined settlement agreement with Worldwide

Rental and corresp with M Dunn re same (.1); corresp
with opposing counsel re same (.1)
3/15/2012 0.10 22.50 Correp with M Dunn re settlement agreement with

Worldwide Rental
3/15/2012 0.70 157.50 Conference with Dr. Moses Onchiu re sale of South
American mines and Discovery Day mines (.3); conference
with J Sakalo re same (.2); conference with I Reich re
same (.2)
3/16/2012 0.20 45.00 Correspondence with M Dunn re settlement stipulation

with Worldwide Rental (.1); correspondence with D
Hramatulova re same (.1)
3/16/2012 0.10 22.50 Corresp with Boulder County mining property buyer's
attorney re surrounding claims
3/27/2012 0.10 22.50 Corresp with R Meacham re settlement agreement

3/30/2012 0.60 135.00 Prepared motion to approve settlement agreement (.3),
including review of same (.3)
12/15/2009 0.30 57.00 Drafted affidavit of M. Dunn
1/25/2010 4.30 817.00 Attended continued hearing on motion for substantive

consolidation (1.7); conference with I. Reich and M. Dunn
re: hearing (.3); conference with I. Reich re: tasks (.5)
researched reports and prepared notices (1.8)
2/1/2010 8.80 1,672.00 Researched international service of process (4.5); prepared

motion on service through the Hague Convention, Inter-
American Convention and other means (2.8); prepared
motion for summary judgment (1.5)
2/2/2010 10.50 1,995.00 Researched and prepared memorandum on service (2);

Further prepared motion for summary judgment (3);
Researched and prepared Motion to Serve Foreign
Defendants by Mail (5.5)
2/3/2010 8.40 1,596.00 Further prepared Motion to Serve Foreign Defendants by

Mail (4.3) and Motion for Partial Summary Judgment
(3.3); emailed foreign lawyers for questions re: service
(.8)
2/4/2010 3.00 570.00 Correspondence with foreign counsel re: service (2.0);
further prepared motion to serve foreign defendants via
mail (1)
2/7/2010 2.00 380.00 Prepared summary judgment
2/8/2010 6.50 1,235.00 Researched and prepared partial summary judgment on

U.S. Merendon Mining Entities
2/9/2010 7.00 1,330.00 Further prepared summary judgment (5.0); further prepared
service motion (2.0)
2/11/2010 6.80 1,292.00 Conference with I. Reich re: tasks (.2); researched status
of Belize in Hague convention (.2); researched cases on
foreign transferees of fraudulent transfers (.4); prepared for
hearing on injunction (.8); attended injunction hearing
(2.5); conferen ces in break out room re: asset dispositions
and strategy (1.8); prepared order continuing hearing (.9)
2/16/2010 6.10 1,159.00 Researched cases on foreign service via first class mail
(1.1); prepared amendment to service motion (2.4);
prepared response to motion to dismiss (2.6)
2/17/2010 4.20 798.00 Further prepared amendment to service motion (1.1);

Further prepared response to motion to dismiss (1.1);
reviewed and took notes on Sorenson Deposition (1.9);
prepared chart of cash flows (2.1)
2/18/2010 9.00 1,710.00 Researched and reviewed cases, the Sorenson deposition
and affidavits in preparation for continued hearing on
temporary restraining order and hearing on service motion
(7); conference with I. Reich re: same (1.5); prepared
order on service motion (. 5)

2/19/2010 8.00 1,520.00 Prepared for hearing by reviewing motions and cases (2);
attended hearing on temporary restraining order and
motion to serve via alternate means and participated in
conferences with parties (4); prepared orders on service
and setting hearing on summa ry judgment motion (2)
2/23/2010 0.50 95.00 Conference with I. Reich re: tasks and strategy
3/4/2010 1.50 285.00 Researched Eiger Capital for summons, including

documents produced and correspondence with Belizean
websites
3/11/2010 4.20 798.00 Prepared for and attended motion for partial summary
judgment
3/16/2010 1.20 228.00 Motion for continuance and order (.6); research and
correspondence with Defendants (.6)
3/16/2010 1.10 209.00 Researched and reviewed file for letter to Canadian judge
(1.0); conference with I. Reich re: letter (.1)
3/18/2010 0.80 152.00 Attended hearing on motion for clarification in preparation

for Canadan hearing (.5); conference with I. Reich re:
same (.3)
3/22/2010 0.30 57.00 Conference with I. Reich re: tasks
3/25/2010 0.30 57.00 Further prepared initial disclosures
7/1/2010 4.00 760.00 Prepared for and attended hearing on Motion to compel
certain defendants to comply with previous order and
hearing on motion for violation of automatic stay
7/6/2010 1.00 190.00 Prepared application, order, and affidavit on trustee's

employment of auctioneer
7/7/2010 0.20 38.00 Conference with I. Reich re: application of auctioneer and
Discovery Day mine
11/16/2010 0.50 107.50 Prepared motion for continuance of several hearings
11/22/2010 0.30 64.50 Conference with creditor Godwin re status of case (.2);
correspondence re website (.1)
1/10/2011 0.10 21.50 Receipt and Review of Notice of Substitution of Counsel

and Request for Service of Notice and Papers
2/2/2011 0.30 64.50 Correspondence with creditor K. Fletcher re non-debtor

entity Fidelity
2/9/2011 1.20 258.00 Prepared for and conference with L. Hughes and P.
Atkinson from the SEC re claims, permanent injunction,
consent judgment, restitution
2/10/2011 0.20 43.00 Reviewed service on Merendon foreign entities
3/10/2011 0.80 172.00 Conference with I. Reich and P. Atkinson and L. Hughes
of the SEC re status of case and the SEC foregoing
forefeiture to allow trustee to administer assets for the
victim creditors (.6); correspondence with M. Dunn re
same (.2)
4/13/2011 0.10 21.50 Corrrespondence with M. Hannan re continuance of

pretrial
4/19/2011 0.20 43.00 Reviewed motion for continuance of pretrial conferences

and hearing on sale motion

6/20/2011 0.20 43.00 Correspondence with D. Kinsman re status of case and
upcoming auction
7/21/2011 3.80 817.00 Attended hearing on sale motion and pretrials, including
conferences with trustee's team and with defendants
Caldwell Estate and Clearwater
9/27/2011 6.50 1,462.50 Prepared for (4.5) and attended hearing on sale motion and
settlement motion (2)
10/4/2011 0.30 67.50 Prepared spreadsheet to update website
11/14/2011 0.10 22.50 Conference with paralegal re posting documents on

merendon website
11/17/2011 0.30 67.50 Further prepared GR hosted Merendon website
12/28/2011 0.20 45.00 Correspondence with creditor re status of case
1/3/2012 0.20 45.00 Correspondence and conference with courtroom deputy re

Auction
1/4/2012 4.00 900.00 Prepared for and attended Auction of Bueno and Black
Rose Mining Properties and Hearing to Approve Sale to
Successful Bidder
1/5/2012 0.80 180.00 Updated website including narrative and interface and user
ability to access links
1/13/2012 0.30 67.50 Prepared report of summary of case for M Dunn
1/13/2012 0.20 45.00 Strategy re updates to website
1/30/2012 0.20 45.00 Conf with T Li re transfer of stock certificates
1/5/2011 0.20 43.00 Correspondence with B. Stang, creditor, re case status
1/6/2011 0.50 107.50 Correspondence with M. Dunn re Clearwater Mining

Corporation's late filed claim (.2); conference and
correspondence with M. Hannan re same (.3)
1/7/2011 0.20 43.00 Correspondence with M. Hannon re late-filed claim
1/26/2011 0.30 64.50 Correspondence with creditor re late filed claim
2/3/2011 0.30 64.50 Conference with creditor T. Andersen re proof of claim
2/10/2011 0.10 21.50 Correspondence re creditor J. Broderick
2/15/2011 0.20 43.00 Correspondence with T. Anderson re claim
2/22/2011 0.10 21.50 Correspondence with T. Andersen re claim
2/25/2011 0.20 43.00 Conference with creditor T. Anderson re claim
2/25/2011 0.30 64.50 Conference with creditor T. Anderson re case and her
claim
3/8/2011 0.20 43.00 Prepared agreed order allowing the Latimers' late-filed
claim

3/9/2011 0.10 21.50 Reviewed filed order granting S. Latimer's late filed
claim
3/10/2011 0.50 107.50 Reviewed claims to determine number of investor

creditors
3/10/2011 0.20 43.00 Correspondence with creditor S. Taylor re case
4/4/2011 0.20 43.00 Strategy re correspondence with creditors
8/28/2011 0.20 43.00 Correspondence with S Latimer re claim no 639 and order
deeming it timely filed
1/26/2012 0.10 22.50 Corresp with T Andersen re proof of claim
2/6/2012 0.30 67.50 Conf with P Scott re Worldwide Rental's secured claim
Activity Code 007 Fee/Employment Applications
7/14/2010 0.90 171.00 Conference with Fisher Auction Co., J. Welt, I. Reich, and
M. Dunn re: auctioneer application and letter of intent to
purchase several mines (.5); further prepared application
for auctioneer, order granting application for auctioneer,
and affidavit of auctioneer (.4)
7/15/2010 0.20 38.00 Correspondence with auctioneer re: application, motion,

and order (.2)
3/17/2010 3.50 665.00 Prepared letter to Canadian Judge re: motion for
clarification, case synopsis, automatic stay and service
3/23/2010 1.00 190.00 Prepared Initial Disclosures
4/28/2010 1.00 190.00 Reviewed status of service for foreign defendants (.5);
correspondence with I. Reich and S. Stirling re: strategy
for good service (.5)
6/11/2010 8.80 1,672.00 Prepared Motion to Compel South American Entities to

respond to Interrogatories (3.5); further prepared Motion
for Contempt and Sanctions for violation of the stay (4.6);
reviewed memo re: status of case (.2); exchanged
correspondence with I. Reich re: motions (.5)
6/29/2010 1.90 361.00 Prepared motion to continue pretrial (.7); prepared order
granting motion for violation of stay (1); conference with
P. Scott re: same (.3); drafted email to C. Hark and A.
Neiwirth re: pretrial conference (.2)
6/30/2010 1.40 266.00 Prepared Motion and Order Continuing Pretrial and
Modifying Order Setting Filing and Disclosure
Requirements (1.4)

6/30/2010 6.60 1,254.00 Further prepared Agreed Order Denying Motion for
Sanctions and prepared alternative Order Denying Motion
for Sanctions, conference with I. Reich re: same and
strategy for hearing (3); conference with I. Reich and J.
Sakalow re: same (.3); prepared order on motion to
compel, conference with I. Reich re: same and strategy for
hearing (3); conference with C. Hark and I. Reich re:
same (.3)
7/9/2010 0.60 114.00 Reviewed service of process in Venezuela (.2); prepared

service on foreign defendants (.3); conference with I. Reich
re: same (.1)
8/9/2010 0.50 95.00 Prepared Request for Service Abroad of Judicial or

Extrajudicial Documents to Serve Merendon Venezuela
S.A.
8/27/2010 0.40 76.00 Prepared motion for continuance and order granting
same
9/14/2010 0.50 107.50 Reviewed response to stay relief motion
9/30/2010 0.50 107.50 Further prepared Motion to Strike and conference with I.
Reich re same (.5)
10/18/2010 0.50 107.50 Reviewed amended complaint for declaratory relief
10/19/2010 3.00 645.00 Finalized amended complaint (.5); conference with Bonnie
Frank re documents sent to the trustee (.3); prepared
motion and order continuing hearing on stay relief motion
and sale motion (1); correspondence with I. Reich and S.
Stirling re amended com plaint, continuance and case
(1.2);
11/4/2010 0.40 86.00 Correspondence re amending complaint (.2) reviewed

motion to withdraw as counsel by Sorenson (.2)
11/5/2010 0.10 21.50 Reviewed correspondence with J. Moffa re motion to

extend time to file responsive pleading
11/19/2010 0.20 43.00 Prepared amended order granting extension.
11/29/2010 0.10 21.50 Reviewed correspodnence from D. Quick re

counterclaim
11/30/2010 0.20 43.00 Reviewed docket and prepared notice of withdrawal
12/8/2010 0.30 64.50 Correspondence with I. Reich re counterclaim and motion

to dismiss
12/30/2010 1.70 365.50 Reviewed Fedrigon counter-claim (.4); prepared motion to

dismiss (1.3)
1/7/2011 0.30 64.50 Correspondence with J. Moffa re order granting motion to

dismiss
1/10/2011 0.20 43.00 Correspondence with J. Moffa re motion to dismiss
1/11/2011 0.20 43.00 Reviewed Answer by Garfinkle (.2); conference with

Garfinkle re mines (.1)
1/11/2011 0.50 107.50 Correspondence with J. Moffa re agreed order on motion to

dismiss (.2); prepared agreed order (.3)
1/12/2011 0.10 21.50 Correspondence with P. Garfinkle re status and state court
litigation

1/13/2011 0.10 21.50 Correspondence with D. Quick re motion to dismiss
1/14/2011 0.20 43.00 Strategy re initial disclosures
1/17/2011 0.30 64.50 Strategy re continuance of pretrial conferences and related

deadlines
1/18/2011 0.10 21.50 Conference with M. Hannan, counsel for Clearwater

Mining Company, re discovery and pretrial (.1)
1/18/2011 0.60 129.00 Conference with R. Meacham, counsel for defendant,

Worldwide Rental Services, re discovery requests and
pretrial (.3); correspondence with S. Stirling, F. Santos and
R. Meacham re same (.3)
1/19/2011 1.50 322.50 Prepared motion for extension of hearing on sale motion
and pretrial conferences in both adversaries (1.2);
correspondence with S. Stirling re same (.3)
1/19/2011 0.60 129.00 reviewed correspondence with L. Weltzer re G. Greive's

claims (.2); conference with R. Reed re G. Grieve's claims
(.2); correspondence with R. Reed re same (.1);
correspondence with S. Stirling re same (.1)
1/20/2011 0.40 86.00 Correspondence and conference with M. Hannan re

defendant's claims
2/3/2011 0.50 107.50 Prepared service pursuant to the Hague Convention for
Merendon Venezuela
2/3/2011 0.50 107.50 Conference with K. Fletcher re Fidelity
2/9/2011 0.10 21.50 Correspondence with S. Stirling re alias summons
2/10/2011 0.10 21.50 Reviewed correspondence with J. Falzone re alias

summons
2/10/2011 0.20 43.00 Correspondence with A. Neiwirth re pretrial
2/14/2011 0.20 43.00 Reviewed service of foreign defendants
2/21/2011 0.30 64.50 Prepared final documents for service to Merendon

Venezuela
2/23/2011 0.20 43.00 Correspondence with M. Hannan re Clearwater Mining

Company re discovery
2/24/2011 0.20 43.00 Correspondence with M. Hannan re outstanding

discovery
3/2/2011 0.40 86.00 Reviewed documents for responsive discovery to

Clearwater Mining
3/2/2011 0.10 21.50 Correspondence with M. Hannan re Clearwater Mining and

pretrial conference
3/10/2011 0.20 43.00 Strategy re discovery responses to Worldwide

Machinery
3/11/2011 0.10 21.50 Reviewed correspondence between Worldwide Rental and

our office re extension of time to file responses to
discovery
3/15/2011 2.20 473.00 Reviewed documents related to title search of property of

the estate in Boulder County and Gilpin County (1.2);
prepared interrogatories (1)
3/16/2011 0.20 43.00 Prepared Answer to Interrogatories

3/23/2011 0.30 64.50 Reviewed District Ct Order in SEC case dismissing in part
and dening in part the complaint against M Warner
4/12/2011 2.20 473.00 Prepared response to discovery and responsive production

for Worldwide Rental and correspondence with R.
Meacham re same
4/13/2011 0.10 21.50 Corrrespondence with M. Hannan re discovery
4/15/2011 0.10 21.50 Correspondence with counsel for Wabuska re service
4/26/2011 0.30 64.50 Reviewed Order Granting Motion to Compel Defendants to

Comply with Agreed Order Dated 2/26/2010 (.1), Agreed
Order dated 2/26/2010 (.1), and Motion to Withdraw in
preparation for hearing on Sorenson's Counsel's Motion to
Withdraw (.1)
4/26/2011 0.20 43.00 Correspondence from C. Hark and B. Cargill re hearing on

motion to withdraw as counsel (.1); reviewed notice of
hearing on same (.1)
4/29/2011 0.20 43.00 Reviewed certificate of no response to motion for

compromise of controversy with Trinity Alps and P.
Fagen
5/2/2011 1.00 215.00 Conf with C. Hark and I. Reich re his client's violations of
agreed order and about withdrawal (.3), and conf with I.
Reich re same (.2); attended telephonic hearing on motion
to withdraw as counsel for Sorenson and South American
entities (.5)
5/23/2011 0.20 43.00 Strategy re documents provided by B. Mukamal
6/6/2011 0.50 107.50 Analysis and strategy re production for defendant

Worldwide
6/7/2011 0.30 64.50 Reviewed production for action to determine validity,

extent, and priority of liens on Colorado Mining
Properties
6/9/2011 0.80 172.00 Conference with N. Nichole re debtor's documents and

production of documents relating to Colorado Mining
Properties (.5); strategy re personally identifiable
information (.3)
6/13/2011 0.80 172.00 Prepared answer to request for admissions from W.

Kemper and strategy and analysis re same
6/14/2011 1.00 215.00 Prepared production for Worldwide
6/16/2011 0.20 43.00 Correspondence with N. Nicole and E. Bartling re

responsive production for Worldwide
7/12/2011 2.60 559.00 Conference and correspondence with E Alan Hampson re

Kemper and Daggett's asserted lien on Sentinel's assets and
pretrial stipulation (.5); prepared pretrial stipulation (.8);
strategy and analysis re Kemper and Daggett's claims
(1.3)
7/12/2011 0.40 86.00 Conference with R. Meacham re Worldwide Rental's

claims against the Boulder county property, and upcoming
pretrial conference
7/14/2011 0.60 129.00 Correspondence with E. A. Hampson re preiiral order and

asserted lien, and review of facts and law, and strategy re
same

7/18/2011 0.20 43.00 Reviewed proposed stipulation from A Hampson
7/20/2011 0.60 129.00 Prepared for pretrial conferences in both adversaries by

reviewing status of adv procs and filings in both
proceeding
7/28/2011 0.10 21.50 Strategy re service on defendants claiming an interest in

Bueno and Black Rose mining properties
9/27/2011 0.30 67.50 Conference with R Meachem re Worldwide's asserted

lien
10/21/2011 0.20 45.00 Reviewed email to UST re Garfinkle's complaint
11/2/2011 0.20 45.00 Conference with I Reich, J Serrano, and J Leibner re

amended complaint to drop Glory Hole defendants
11/2/2011 0.20 45.00 Correspondence with J Leibner re research on validity of

Worldwide Machinery's lien
11/9/2011 0.80 180.00 Reviewed disclaimer and deeds for Glory Hole settlement
and conference with M Dunn re same
11/22/2011 0.20 45.00 Corresp with A Katz and A Griesel re trustee's receipt of
payment on Glory Hole and dismissal of Glory Hole
defendants
12/15/2011 3.00 675.00 Prepared Second Amended Complaint for Declaratory

Judgment, notice of dropping Glory Hole Parties, and
motion for leave to amend, including review of title work
done by L Weltzer
12/16/2011 1.10 247.50 Further prepared notice of dropping parties, amended

complaint for declaratory judgment, and motion for leave
to amend complaint
12/19/2011 0.30 67.50 Prepared order granting motion for leave to file amended
complaint
12/20/2011 0.20 45.00 Corresp with A Katz re stipulation of dismissal of EPA
12/21/2011 0.40 90.00 Prepared stipulation and order for dismissal of USA from
declaratory action (.2); corresp with A Katz re same (.2)
12/29/2011 0.60 135.00 Prepared stipulation and order of dismissal re G Grieve

(.3); correspondence with G Grieve re same (.3)
1/12/2012 0.30 67.50 Corresp with R Meacham re pretrial conference and

obligations
1/13/2012 0.30 67.50 Reviewed Worldwide Rental's Expert Report disclosures
1/13/2012 0.40 90.00 Prepared initial diclsoures in Adv Proc 10-3623
1/13/2012 0.50 112.50 Strategy re substantive consolidation and avoidance of

Worldwide Rental's lien on Bueno and Boulder County
mining properties
1/16/2012 1.00 225.00 Conference with P Scott and J Leibner re validity and
extent of Worldwide Machinery's lien
1/20/2012 0.10 22.50 Correspondence and conf with R Meacham re pretrial

conference
1/20/2012 1.00 225.00 Prepared motions to continue pretrial conferences and

orders granting same

1/20/2012 1.20 270.00 Research re lien holder's entitlement to postpetition fees
and costs
1/25/2012 0.20 45.00 Strategy re declaratory judgment and defaults
1/30/2012 0.10 22.50 Conf with R Meacham's office re initial disclosures
2/3/2012 0.50 112.50 Conf with P Scott re validity of Worldwide's claim,

including review of judgment, and strategy and analysis re
same
2/7/2012 1.50 337.50 Researched case law re entitlement to attorney fees and
interest (1); conf with P Scott re same and response to R
Meacham re Worldwide Rental's judgment (.5)
2/17/2012 0.20 45.00 Prepared request for production to Worldwide Rental
2/27/2012 2.80 630.00 Prepared for and attended pretrial conferences in both
adversary proceedings
6/8/2010 2.40 456.00 Researched articles on Discovery Day Mine trespass and
claimed ownership of mine (.5); prepared motion for
contempt and sanctions for violation of automatic stay
(1.7); exchanged correspondence with P. Garfinkle re:
Discovery Day Mine (.2)
6/28/2010 1.00 190.00 Conference with P. Garfinkle and I. Reich re: Discovery
Day Mine title (.7); conference with L. Taylor re: same
(.3)
1/10/2011 0.10 21.50 Receipt and Review of Plaintiffs' Notice and Advisement
of Entry of Order Granting Relief from Stay (Caldwell)
5/13/2011 2.50 537.50 Conference with S. Doyle and Deputy Treasurer of Gilpin
County re tax obligations of Sentinal Mining Corp (1.2);
reviewed tax report (.6); conference and correspondence
with S. Doyle re same (.7)
1/23/2012 0.20 45.00 Corresp with T Li re tax liens
Total for Timekeeper Lessne, Michael D 460.20 $94,480.50

Mancuso, Nathan G
8/27/2009 0.50 175.00 Meet with I. Reich regarding proposed substantive

consolidation of non-debtor entities (.3), implications of
same (.2)
9/17/2009 1.00 350.00 Review Garfinkle affidavit
9/18/2009 1.30 455.00 Meet with I. Reich regarding proposed consolidation of

non-debtor entities & mines, discuss legal theories (.5);
review form of substantive consolidation motion (.4);
forward to I. Reich with cover e-mail (.1); follow-up
research regarding substantiv e consolidation of non-debtor
entities (.3).
11/16/2009 0.50 175.00 Meet with I. Reich regarding substantive consolidation

complaint.
1/13/2010 0.50 175.00 Meet with I. Reich regarding substantive consolidation of

various entities (.3), follow-up strategy (.2)
3/11/2010 0.70 245.00 Meet with I. Reich regarding 363(h) sale issues of jointly-
owned property; review form of 363(h) complaint &
forward to I. Reich with comments regarding procedural
issues.
6/11/2010 0.70 245.00 Call with I. Reich regarding asset sale issues, procedure;
review multiple e-mails regarding same.
6/14/2010 0.30 105.00 E-mails with auctioneer regarding mine sale, financing
issues.
6/15/2010 0.30 105.00 E-mails with auctioneer regarding sale & due diligence
issues.
7/26/2010 0.30 105.00 Call with M. Lessne regarding proposed sale of Colorado
mines, section 363(h) sale of co-owner's property
interest.
7/29/2010 2.00 700.00 Meeting regarding sale of Colorado mines, substantive &
procedural issues regarding same (1.0); review sale motion
& 363(h) complaint (1.0).
7/30/2010 0.80 280.00 Meet with J. Liebner regarding section 363(f) sale of
competing ownership interests (.4); review statute &
supporting caselaw, e-mail memorandum regarding same
(.2); draft reply e-mail. (.2)
8/5/2010 1.50 525.00 Multiple meetings, calls w/ M. Lessne regarding

substantive & procedural issues on section 363 sale of
Colorado mines (.5); review background documents
regarding competing ownership interests 9 (1.0).
8/6/2010 1.20 420.00 Review sale motion & complaint 9.5); discuss with M.
Lessne re: same (.7).
8/9/2010 0.50 175.00 Review amendment & accompanying letter to Colorado

mining sale contract (.3); discuss with M. Lessne re same
(.2)

6/12/2009 0.50 175.00 Meet with I. Reich, R. Schatzman regarding status of case,
administration issues & to-do items (.3); review e-mail to
petitioning creditors' counsel (.2).
8/7/2009 0.50 175.00 Review e-mail exchange regarding materials needed for
schedules (.1); review extension order (.1); follow-up e-
mails regarding same & need for further extension (.2); call
to B. Elam regarding same (.1)
8/11/2009 0.30 105.00 Call, e-mails with L. Negron regarding schedules,

extension of time, case status.
6/8/2010 0.30 105.00 Discuss stay violation remedies, civil contempt issues with
M. Lessne.
1/14/2010 0.10 35.00 Call with L. Negron regarding section 501(c) filing of
creditor's claim.
1/20/2010 1.30 455.00 Call with I Reich regarding foreign service of process (.3);
review Rule 7004 regarding same & follow-up legal
research (.6); call & e-mails with J. Kim regarding same
(.4)
1/21/2010 0.70 245.00 Review J. Kim memo on international service of process

(.3), follow-up e-mail regarding continued research on mail
service issues (.1); e-mails with J. Kim regarding mail
service (.3)
1/22/2010 0.80 280.00 E-mails & meeting with J. Kim regarding foreign service of
process issues (.3); review memo of law regarding same
(.3); calls, e-mails with I. Reich regarding same (.2).
3/16/2010 0.30 105.00 Discuss continuance procedure with M. Lessne (.2); review
& forward motion/order for continuance of pretrial
conference. (.1)
Total for Timekeeper Mancuso, Nathan 16.90 $5,915.00

Negron, Lisa
7/16/2009 0.50 80.00 Meeting with I. Reich regarding searches to be performed

re: assets
7/21/2009 2.80 448.00 Perform various corporate and property searches
8/11/2009 0.80 128.00 Prepare Motion and Order extending time to file
schedules
9/1/2009 0.30 48.00 Review emails regarding transfers and preparation of

schedules
9/4/2009 4.00 640.00 Meeting regarding preparation of schedules
9/8/2009 3.00 480.00 Begin drafting schedules and reviewing backup

information
9/9/2009 7.00 1,120.00 Continue preparing schedules
9/10/2009 5.50 880.00 Finalize schedules
9/11/2009 0.50 80.00 Review various emails from M. Dunn's office to coordinate
obtaining signature pages for schedules and prepare
responses to same
9/11/2009 3.00 480.00 Final revisions to schedules
9/16/2009 0.30 48.00 Review various emails regarding obtaining information

from different sources and affidavits
10/14/2009 0.30 48.00 Prepare email correspondence to various creditors

forwarding a copy of the 341 Meeting Notice and a Proof
of Claim form
12/8/2009 0.50 80.00 File ecf emails into file site
1/7/2010 2.30 368.00 Pull case law for hearing on motion for substantive
consolidation
1/8/2010 1.00 160.00 Work on items to be put on website
1/11/2010 4.00 640.00 Prepare for hearing on substantive consolidation
1/12/2010 2.00 320.00 Assist in preparing for hearing on motion for substantive
consolidation
1/15/2010 0.50 80.00 Prepare email to court and forward proposed orders
2/11/2010 0.90 144.00 Telephone call with I. Reich regarding Suggestions of

Bankruptcy (.30; revise Suggestions (.6)
6/11/2009 4.10 656.00 Drafting employment documents for General Counsel,

Special Litigation Counsel and Financial Advisor

6/16/2009 1.20 192.00 Finalize applications to employ and file with the court
6/16/2009 0.50 80.00 Follow up on receiving applications for professionals to be

filed with the Court
6/19/2009 0.40 64.00 Revise certificates of mailing regarding employment

documents (.2); telephone call with B. Elam regarding
revising affidavit (.2)
6/26/2009 0.20 32.00 File application, affidavit and proposed order to employ B.
Elam with the Court
7/16/2009 1.00 160.00 Telephone call to U.S. Bank to obtain service information
(.3); prepare subpoena and notice of 2004 to U.S. Bank
(.7)
12/15/2009 2.00 320.00 File complaint and create parties in CM/ECF (1.0); finalize
affidavit for deferring filing fee (1.0)
12/25/2009 6.00 960.00 Prepare Summons for defendants for service
12/28/2009 4.00 640.00 Preparing and finalizing summonses for defendants of

adversary
Total for Timekeeper Negron, Lisa 58.60 $9,376.00

Nicole, Nancy H
6/9/2011 1.20 168.00 Drafted Motion to Continue Hearing on Motion for Sale
and Pretrial Conference set for June 23, 2011
7/22/2011 1.00 140.00 Communications with I. Reich, Esq., and M. Lessne re:
drafting Order on Motion to Approve Sale, and Orders
Adversary Proceedings re: continuance (.3). Drafted
Order on Motion to Approve Sale (.3). Drafted Orders
continuing and resetting pretrial conference (.4)
8/3/2011 0.50 70.00 Draft Motion and Order to reset hearing on Motion to
Approve Sale of Bueno and Black Rose mines.
7/12/2011 5.00 700.00 Began revision and update of filings and links to
Bankruptcy and both Adversary Proceedings for upload to
website.
7/13/2011 2.50 350.00 Completed revisions and update of filings and links to
Bankruptcy and both Adversary Proceedings for upload to
website.
11/16/2011 0.50 70.00 Reviewed email from M. Lessne re: excel spreadsheet for
website download (.1). Reviewed Excel spreadsheet (.2).
Conference with Patricia Tomlinson re: update of same
(.2).
11/17/2011 4.30 602.00 Revised prior spreadsheet for website links to court
documents, per court Order (1.5). Prepared updated
spreadsheet for website links to court documents (2.8)
5/10/2011 0.10 14.00 Telephone conference with office of Barry Muhkamal,

CPA (Jasmine), re: documents for production and Paul
Garfinkel documents.
5/10/2011 0.20 28.00 Telephone conference with office of Barry Mukamal, CPA
(Sharmilla), re: documents for production and Paul
Garfinkel documents.
5/10/2011 0.10 14.00 Reviewed email from Linda Raymond, Esq. re: supplement
production, non-electronic documents.
5/10/2011 0.20 28.00 Telephone conference with office of Barry Mukamal, CPA
(Doris), re: documents for production and Paul Garfinkel
documents.
5/10/2011 0.30 42.00 Prepared email to M. Lessne, Esq., re: supplement

production, non-electronic documents.
5/10/2011 0.50 70.00 Reviewed file re: request for production, documents
produce to date.
5/11/2011 0.20 28.00 Prepared emails to M. Lessne re: production of

documents, B. Mukamal and Paul Garfinkle documents.

5/11/2011 0.30 42.00 Additional telephone conference with office of B.
Mukamal, re: production of documents.
5/11/2011 0.20 28.00 Telephone conference with office of B. Mukamal, Trustee

re: CD of documents in response to request for
production.
5/11/2011 0.10 14.00 Reviewed email from M. Lessne re: production of

documents.
5/12/2011 0.20 28.00 Reviewed initial Response to Request for Production.
5/17/2011 0.20 28.00 Reviewed email from Linda Raymond, Esq., re:
production.
5/17/2011 0.40 56.00 Prepared memorandum Michael D. Lessne and J.

Cartenega re: electronic and non-electronic production,
supplemental response.
5/17/2011 0.20 28.00 Telephone conference with B. Mukamal's office re:

production of documents.
5/18/2011 0.20 28.00 Reviewed email from office of B. Mukamal re: attaching
documents for production.
5/18/2011 0.20 28.00 Telephone conference with B. Mukamal's office re:

production of documents.
5/19/2011 0.40 56.00 Prepared memorandum to M. Lessne, re: supplemental

production, 1,095 electronic data and files received from
Marcum LLP for Trustee B. Mukamal for document
production.
5/19/2011 1.70 238.00 Received and managed 1,095 electronic data and files
received from Marcum LLP for Trustee B. Mukamal for
document production.
5/19/2011 0.20 28.00 Received and reviewed email and document production
link from Marcum LLP for Trustee B. Mukamal.
5/20/2011 0.40 56.00 Reviewed Excel spreadsheet of additional files and

documents for possible production and documents
produced by Trustee.
5/20/2011 0.40 56.00 Prepared email to Emma Bartling re: production of

Trustee's documents.
5/20/2011 0.50 70.00 Revised Excel spreadsheet of additional files and

documents for possible production.
5/20/2011 3.00 420.00 Management of documents from Trustee for production

(over 100,000 pages).
5/23/2011 1.00 140.00 Began cursory review of categories of (100,000)

documents from Marcum Accounting of Trustee's records
and comparison to records previously produced to
Worldwide.
5/23/2011 3.00 420.00 Began preparation of table of contents of (1,095 files) from
Trustee for production.
5/23/2011 0.30 42.00 Prepared memorandum to M. Lessne, re: organization and

production of documents from Marcum Accounting of
Trustee's records.
5/24/2011 3.50 490.00 Continued reviewed, organization and preparation of table

of content of folders and documents documents produced
by Trustee in response to Worldwide Request for
Production.

5/27/2011 1.00 140.00 Continued reviewing, indexing, and management of over
100,000 pages of electronic documents from Trustee in
response to Worldwide request for production.
6/1/2011 0.50 70.00 Reviewed Adversary Complaint for Declaratory Judgment

re: interests and properties, for purposes of identifying
documents responsive to Worldwide's request for
production.
6/1/2011 0.30 42.00 Telephone conference with Linda Raymon, Paralegal

(Worldwide) re: production and supplemental
production.
6/1/2011 0.20 28.00 Prepared email to Jessican Serrano re: contact with Robert
Meacham re: Trustee's production of documents.
6/1/2011 0.20 28.00 Telephone call to I.T. Dept. re: status of completion of
Table of Contents of files and documents produced by
Trustee's accountant.
6/1/2011 0.20 28.00 Reviewed email from Linda Raymon, Paralegal

(Worldwide) re: production and supplemental production,
pretrial deadline.
6/1/2011 0.40 56.00 Prepared memorandum to M. Lessne, re: supplemental

production, pretrial deadlines.
6/1/2011 0.30 42.00 Drafted email to to Linda Raymon, Paralegal (Worldwide)

re: production and supplemental production, pretrial
deadline.
6/2/2011 0.50 70.00 Office conference with M. Lessne, re: production to

Worldwide (.3); telephone conference with Emma Bartling
re: list of 1,095 downloaded files. (.2)
6/3/2011 1.70 238.00 Communications with J. Cartagena re: production to

Clearwater and to Worldwide (.3); telephone conferences
with Marcum Accounting (Lucy) re: location of original
documents on CD and download Link for production to
Worldwide (.3); prepared memorandu m re: orignal
documents, list of files on CD, additional production to
Worldwide (.2); reviewed documents produced to
Clearwater and compared same to documents produced on
CD by Trustee (.4); reviewed email from Marcum
Accounting re: documents, produ ction (.1); reviewed file
re: prior 383 page production, list of documents on CD and
production of same (.2); communications with I.T. Dept.
re: downloading of production from Trustee, transition to
Summation (.2)
6/6/2011 6.50 910.00 Received and reviewed email from I.T. Dept. and attached
list of files and documents on CD re: production to
Worldwide (.2). Converted list of documents to searchable
text (.6). Continued management of 1,095 electronic files
of production from Tr ustee (2.3). Office conference with
M. Lessne re: preliminary search of production for
privileged communications on Trustee's CD (.3).
Continued review and analysis of production (2.7) .
Prepared memorandum re: documents on 2009 disk from
Trustee and 2011 documents link from Trustee (.4)
6/7/2011 4.50 630.00 Continued management of 1,095 electronic files of

production from Trustee (2.1); continued review of
production from Trustee (2.4)
6/8/2011 7.50 1,050.00 Continued management and review of 1,095 electronic

files of production

6/9/2011 3.80 532.00 Conference with I. Reich, and M. Lessne, re: initial review
of 1,095 files from Trustee for production to Worldwide
and due diligence documentation to Buyer, privilege and
personal information (.5). Continued management and
review of 1,095 electroni c files of production (3.3)
6/10/2011 1.20 168.00 Continued review and management of production from

Trustee.
6/13/2011 6.50 910.00 Continued review and redaction of production by Trustee

for production to Worldwide and for due diligence package
to Buyer (5.4); prepared memorandum to I. Reich, Esq.,
re: status, time to complete and make production to
Worldwide and due diligence package to Buyer (.4);
received, reviewed and replied to communications from
Linda Raymond, Paralegal, (Worldwide) re: status of
production (.4); telephone conferences with Emma Bartling
re: production (.3)

to Buyer.

to Buyer.
6/16/2011 7.00 980.00 Continued review of production by Trustee for production

to Worldwide and for due diligence package to Buyer.
6/17/2011 4.50 630.00 Finalized reviewed, redaction, a nd organization of

documents for electronic production to Worldwide and for
due diligence package to Buyer.
6/20/2011 3.70 518.00 Additional review, redaction and finalization of documents

production Worldwide and for due diligence package to
Buyer (2.5); prepare CD of production (.2); prepared email
to Robert Meacham, Esq., re: CD for production to
Worldwide (.2); prepared em ail to Sean W. Doyle, Esq.,
re: due diligence package (.2); prepared letter to Sean W.
Doyle, Esq., re: enclosing due diligence CD (.2).
7/14/2011 3.40 476.00 Reviewed communications from Kevin Coxwell (Chase)

and M. Lessne re: Credit Bureau Authorization (.4);
reviewed communication from E. Alan Hampson, Esq., re:
Sentinel interest (.3); reviewed communications from
Michael D. Lessne and A. Srour re: inte rest of Sentinel
Mining, review of public records (.4); reviewed Adversary
Dockets (.4); Reviewed list of Adversary Defendants and
Counter and Cross Defendants (.5); reviewed status of
responses of Defendants for Motion for Default (.7);
finalized draft Motion for Default (.7)
7/19/2011 3.00 420.00 Began retrieving and reviewing documents in Clearwater

Adversary Proceeding and file re: Defendants and status of
Service of Process on Defendants for purposes of finalizing
Motion for Entry of Defaults (1.2) Preparation of chart re:
status of Defen dants, process, and response to Complaint
(1.8)
7/20/2011 6.00 840.00 Continued retrieving and reviewing documents data in

Clearwater Adversary Proceeding and file re: Defendants
and status of Service of Process on Defendants for
purposes of finalizing Motion for Entry of Defaults (2.4);
preparation of chart re: statu s of Defendants, process, and
response to Complaint (3.6)

7/21/2011 5.00 700.00 Completed retrieving and reviewing documents and data in
Main and Adversary Proceeding and files re: Defendants,
service of process, responses and answers to Amended
Complaint (1.1); finalized preparation of chart re: status of
Defendants, process, a nd response to Complaint (2.8)
Prepared memorandum to M. Lessne, re: service of process
and responses to Amended Adversary Complaint (.6);
communications with M. Lessne, re: same, motion for
defaults (.5)
7/25/2011 0.40 56.00 Telephone conference with Judicial Assistant re: status of
entry of Orders (.2). Telephone conference with Judicial
Scheduleer re: new Pretrial Conference date (.1). Prepared
memorandum to M. Lessne, re: same (.1)
8/1/2011 0.50 70.00 Received and reviewed communication from I. Reich, Esq.
re: review and comparison of proposed Quit Claim Deed
from Bowerman Holdings (Discovery Day).
8/3/2011 0.50 70.00 Draft Motion and Order to reset hearing on Motion to Take
Judicial Notice.
Total for Timekeeper Nicole, Nancy H 116.30 $16,282.00

Pearson, William (Bill) M

9/17/2009 1.20 600.00 Receive and review affidavit and other documents.
9/13/2009 3.20 1,600.00 Review documentation on various cases in preparation for

meeting with Mr. Reich and FBI Special Agent on
9/14/09.
9/14/2009 2.40 1,200.00 Conference call with I. Reich and FBI Special Agent re:
status of investigation, jurisdictional issues, etc; telephone
conference with I. Reich (1.4); review additional
documents (1.0).
Total for Timekeeper Pearson, William ( 6.80 $3,400.00

Reich, Ivan J
6/25/2009 0.10 40.00 Email from R. Schatzman to Garfinkle re: recovery

committee and memo
6/30/2009 0.20 80.00 Email to and from L. Negron re: asset recovery memo
7/20/2009 0.40 160.00 Exchanging e-mails with B. Elam and J. Ryan regarding
Leslie Taylor, Black Rose mine (.2); with Schatzman
regarding information needed from Paul Garfinkle (.2)
7/28/2009 0.60 240.00 Telephone conference with Schatzman about and review of
transcript of interview with Garfinkle
9/4/2009 4.10 1,845.00 Multiple emails from J. Ryan's office of interview of Les
Taylor (.5); from S. Khanorkar regarding Brad Regier note
asking for investor list and NV Secretary of State
information (.4); teleconference with A. Brodsky regarding
proof of subsidiaries (. 3); emails with L. Negron regarding
Garfinkle statement (.4); emails to AntyIFFL regarding
need for website information (.5); emails to Agent Matthew
Galioto of the FBI (.5); emails to Scoggins of the SEC (.5);
emails to Sgt.Scott Fuller (.2); teleco nference with Dave
Smiley of the SEC all regarding contacts, schedules,
officers and directors (.8)
9/4/2009 10.00 4,500.00 Conference with R. Schatzman, S. Khanorkar and L.

Negron re: schedules and sofas (5.0); review documents
and investigation and research into multiple investigations
and calls with us and Canadian authorities on
investigations and with runner of webm echnaic web site
re: his private investigation (5.0)
9/7/2009 0.20 90.00 E-mails with B. Regier regarding documentation
9/8/2009 2.20 990.00 E-mails with A. Brodsky, L. Negron, et al. regarding letter
to SEC requesting access to information (.5); with S.
Khanorkar regarding schedules (.6); with Kelly Crowley,
investor, and B. Elam (.5); with all regarding IFFL, Capital
Alternatives, Strat egic Metals, Arbor Energy (.6)
9/9/2009 0.20 90.00 Exchanging e-mails with L. Negron regarding adding

plaintiffs in LaPadula case in Colorado as investors and
attach action as an exhibit to statement of financial affairs
(.2)
9/11/2009 0.10 45.00 Email from S. Khanorkar re: bank statement analysis
9/14/2009 2.20 990.00 Telephone conference with Bill Pearson and FBI Agent
Matt Galioto (.6); email from Bill Pearson and 6 from R.
Schatzman re: same (.7), email from agent Galioto (.1);
email to Bill x 2 and R. Schatzman x 5, and email to agent
re: same (.8)
9/14/2009 0.10 45.00 Email to Garfinkle re: affidavit
9/15/2009 0.40 180.00 Exchanging e-mails with Paul Garfinkle (.2); transmit
Garfinkle declaration to him and all others (.2)
9/15/2009 10.00 4,500.00 Draft affidavit of Garfinkle
9/16/2009 0.10 45.00 E-mail from S. Khanorkar transmitting list of structurists

9/16/2009 2.70 1,215.00 Exchanging multiple e-mails with S. Khanorkar regarding
various matters, including affidavit and Merendon cash
flows (.4); with Paul Garfinkle regarding his declaration
and execution of same (.3); to investors and transmit
schedules and statement of financial affairs to them (.3); to
all parties transmitting IFFL chronology of events from
1999 - 2009 from Agency website (.3); with Pearson
regarding Garfinkle declaration (.3); to all transmitting
Agency's letter to Sorensen (.4); with Schatzman r egarding
spreadsheet from Agency site (.3); with Scoggins regarding
access request (.4)
9/17/2009 4.50 2,025.00 Meeting with Paul Garfinkle and Lynda Evensen regarding
Paul's affidavit (2.5); receipt and review revisions to
affidavit and make same (2.0)
9/18/2009 0.70 315.00 Multiple e-mails with Richard Lunger of US DOJ

transmitting Statement of Financial Affairs and Schedules,
access information for Intelligence website and website
announcement (.2); receipt and review of notice of meeting
of creditors to be held on 10 /16/09 and transmit same to
all (.5); with Nicole Chute, Alberta Securities Commission
and Jeff Simpson, RCMP (.3)
9/23/2009 0.60 270.00 Exchanging e-mails with Schatzman regarding FBI,

RCMP, SEC, etc. open communication
9/30/2009 0.30 135.00 Telephone conference with creditor investor Sally

Coupal
10/2/2009 0.50 225.00 Telephone conference with Ward Capstick
10/2/2009 0.80 360.00 Exchanging e-mails with all regarding The Agency
10/5/2009 0.90 405.00 Exchanging e-mails with all regarding The Agency and
with Paul Garfinkle regarding Canadian corporate
information
10/8/2009 0.80 360.00 Exchanging e-mails with B. Elam regarding conversation

with Les Taylor and with Schatzman regarding The
Agency
12/8/2009 0.30 135.00 Emails with P. Wagner regarding injunction motion
12/28/2009 0.50 225.00 Emails with L. Negron and A. Brodsky regarding

Certificate of Service of hearing notices, motion, complaint
(.3); emails with M. Dunn and B. Elam regarding Les
Taylors email to B. Elam (.2)
12/29/2009 0.50 225.00 Notice of hearing on motion and discuss duplicate hearings
with A. Brodsky to try to get all scheduled for 1/12/10
(.5)
12/30/2009 0.20 90.00 Receipt and review of Summons Service Executed [D.E.
13]
1/11/2010 2.30 1,035.00 Telephone conference with Larry Adair (.3); email from P.
Wagner regarding draft order granting motion for
substantive consolidation (.1); emails with B. Elam
regarding articles and Ken Iredale's email (.4), call from
Larry Adair, with L. Negron rega rding articles (.7); emails
and teleconference with L. Negron and Cheryl Bennett re:
transmitting all case documents for website (.8)
1/28/2010 0.70 315.00 Telephone conference with Albert Pelteir, counsel in

Canadian class action law suit

1/28/2010 0.30 135.00 Telephone conference with Ward Capstick
2/2/2010 1.00 450.00 Telephone conference with Canadian receiver and his
counsel
2/2/2010 0.30 135.00 Emails with B. Elam regarding buyers and orders (.3)
2/10/2010 1.10 495.00 Call from Mike Turner, potential mine buyer referred by
M. Dunn (.5), and several emails with Mike Turner (.6)
2/11/2010 0.30 135.00 Emails with Mike Turner, mineral rights buyer
2/16/2010 1.00 450.00 Telephone conference with SEC lawyers and

investigators
2/17/2010 0.30 135.00 Several emials with Mike Turner (mineral rights buyer)
2/18/2010 1.50 675.00 Conference with Paul Taylor, Nordics's counsel
2/24/2010 4.00 1,800.00 Conference with Chris Redmond and Greg Grossman,
counsel for investors re: filing involuntary against
Canadian companies in Canada
3/1/2010 0.30 135.00 Telephone conference with Chris Redmond
3/10/2010 0.30 135.00 Telephone conference with Martin Werner re: Peru sale
offer
3/25/2010 2.50 1,125.00 Meeting with Werner and Garfinkle re: glory hole mine
(2.0) and review documents re: same (.5)
4/19/2010 0.30 135.00 Exchanging e-mails with A. Brodsky regarding call from
Paul Butler regarding Glory Hole
4/27/2010 0.30 135.00 Call from Joseph Davies regarding Glory Hole
5/13/2010 0.30 135.00 Exchanging e-mails with A. Brodsky regarding second call
from Joe Davies regarding Clearwater Mine/Glory Hole -
title issue
5/26/2010 0.60 270.00 Telephone conference with Martin Werner re: Ecuador
mine (.3); emaiils with Werner regarding documents he
sent (.3)
5/28/2010 0.30 135.00 Exchanging e-mails with M. Dunn and B. Elam regarding
Black Rose
6/9/2010 0.10 45.00 Email from M. Dunn forwarding email from Jason Welt of
Fisher Auction Auction regarding mines
6/11/2010 0.60 270.00 Telephone call with Fisher Auction - Lamar and Jason -
call from Garfinkle saying he has a potential buyer
6/16/2010 0.30 135.00 Telephone conference with Martin Werner regarding mine
in Ecuador
6/17/2010 0.30 135.00 Exchanging e-mails with M. Dunn, A. Brodsky and Jason
Welt of Fisher Auction regarding meeting in person at GR's
Miami office
6/21/2010 0.30 135.00 Telephone conference with Michael Morrison (counsel for
Wabeska Mining) regarding competing claims over
Discovery Day Mine in California
6/21/2010 0.40 180.00 emails with A. Brodsky and from Jason Welt and Lamar
Fisher regarding call from Chris Pearce about prospective
buyer of mines

6/21/2010 0.50 225.00 Telephone conference with Michael Morrison, counsel for
Wabasca Mining who has a competing claim
6/24/2010 0.60 270.00 Exchanging e-mails with Jay Sakalo and M. Dunn (.2); call
from Ward Capstick (.2); call from Chris Pearce regarding
purchasing mines, and refer him to Fisher Auction (.2)
6/25/2010 1.20 540.00 Telephone conference with Garfinkle x 2 (.6); telephone

with Capstick (.3); emails with Katie Carter, investor (.2);
email to Jay Sakalo (.1)
6/28/2010 0.70 315.00 Emails with Garfinkle and F. Santos regarding ownership
of Discovery Day and explosion investigation (.6); email to
M. Dunn transmitting copy of Bahama Resource
Assignment of Stock Interest (.1)
6/29/2010 3.00 1,350.00 Review, revise and negotiate draft language of order with
respondent's counsel as well as reviewing documents re:
ownership issues
6/30/2010 0.50 225.00 Email from Joseph Davies transmitting various ownership
documents regarding Glory Hole
7/1/2010 0.50 225.00 Telephone conference with Jay Sakalo regarding Discovery
Day
7/1/2010 1.20 540.00 Email with Joseph Davies regarding Glory Hole; email to
M. Dunn, Garfinkle, Capstick, Werner regarding Davie's
claims to Glory Hole and response from Garfinkle;
telephone conference with M. Dunn and Fisher Auction,
Jason Welt regarding Fisher's reten tion as auctioneer.
7/2/2010 0.90 405.00 Receiving and reviewing many documents from Jay Sakalo
on Discovery Day Mine (.4); emails to A. Brodsky
regarding same for files and for upcoming meeting with
Sakalo (.2); email from Garfinkle regarding documents
(.1); emails with Nicole Hilburn and Gus Pappas regarding
purchase price, auctioneer, etc. (.2)
7/6/2010 3.10 1,395.00 prepare for and attend meeting with Jay Sakalo, Esq.
regarding Discovery Day Mine (2.0); telephone call with F.
Santos of Fisher Auction regarding Discovery Day Mine
(1.1)
7/6/2010 0.30 135.00 Telephone conference with F. Santos of Fisher Auctions

re: discovery day
7/8/2010 0.40 180.00 E-mail from A. Brodsky regarding call from Norman Frank
in Colorado regarding equipment (.2); email from M. Dunn
regarding Bueno Mine reclamation project (.2)
7/13/2010 1.60 720.00 Exchanging e-mails with Fisher Auction and M. Dunn
regarding Letter of Intent (.4); telephone conference to
discuss same (1.20)
7/14/2010 1.00 450.00 Conference call with auctioneers re: retention of

auctioneer and letter of intent to buy Colorado mines
including revising auction documents and response to letter
of intent
7/22/2010 0.30 135.00 Telephone conference with Garfinkle
7/23/2010 1.80 810.00 emails with Jay Sakalo and M. Dunn regarding California
mine and setting meeting (.3); with F. Santos at Fisher
regarding Mark Levine's interest in some of the parcels and
equipment in Colorado (.4); with J. Leibner regarding his
memo report (.4); wi th S. Khanorkar regarding CA mine
report (.7)

7/29/2010 0.30 135.00 Telephone conference with Mike Morrison re: discovery
day
7/29/2010 3.00 1,350.00 Conference to dismiss the drafting of and issues concerning
the 363 sale and motion and complaint regarding selling
the 3 Colorado properties
8/5/2010 1.00 450.00 Review and revise report on discovery day mine dispute
8/27/2010 0.30 135.00 Telephone conference with Mike Morrison, counsel for
party claiming interest in discovery day
8/31/2010 0.40 180.00 Telephone conference with Ward Capstick re purchaser of

property
9/13/2010 0.60 270.00 Telephone conference with Dr. Michael Savic and Chris
Pierce , the proposed purchasers
10/18/2010 0.50 225.00 E-mails between F. Santos, M. Lessne and Matthew

Kramer
10/19/2010 0.50 225.00 Telephone with Bonnie Frank, Norman Frank's daughter,
regarding assets they claim to own
10/20/2010 0.30 135.00 E-mails between M. Dunn and Jay Sakalo
10/20/2010 0.30 135.00 E-mails between Ashley Ochoa and F. Santos
10/22/2010 0.30 135.00 E-mails between Jay Sakalo and M. Dunn
10/26/2010 0.20 90.00 E-mails to and from F. Santos
10/28/2010 0.20 90.00 E-mails to and from G Goodard
10/28/2010 0.40 180.00 E-mails between F. Santos and Andrea Madigan
11/5/2010 0.30 135.00 Telephone conference with Cheryl Linden attorney with
colorado division of mine reclamanation and safety through
attorney general office of colorado
11/5/2010 0.30 135.00 Telephone conference with Cheryl Landen, Colorado

Attorney general's office, Colorado Division of
Reclemation Mining and Safety re prospecting notice and
bond
11/5/2010 0.30 135.00 Telephone conference w/ Cheryl Linden, colorado attorney

general's office, re prospecting notice and bond
11/29/2010 0.50 225.00 Conference call with EPA attorneys regarding mapping of
mining claims
12/8/2010 0.50 225.00 Telephone conference with M. Lessne, M. Dunn, A.

Brodsky from EPA and F. Santos of fisher auctions re
selling colorado properties
12/28/2010 0.60 270.00 E-mails between Patrick Fagan and F. Santos
12/30/2010 0.30 135.00 Telephone with Michael Morrison re discovery day
1/3/2011 0.30 135.00 Telephone with brokers regarding asset sale
1/27/2011 0.70 315.00 Conference call with M. Lessne, M. Dunn, F. Santos and
Jason Wells
2/8/2011 1.00 450.00 Conference with sakalo re discovery day
2/21/2011 0.60 270.00 Conference call with M. Lessne and Jay Sakalo regarding
Discovery Day Mine

2/21/2011 0.60 270.00 Conference call with M. Lessne and Michael Morrison
reagrding Discovery Day Mine
2/22/2011 0.10 45.00 E-mails between M. Lessne, F. Santos and Jason Welt
3/29/2011 0.50 225.00 Telephone conference with potential buyer Herrera
3/30/2011 0.50 225.00 Telephone conference with potential buyer and email to
Giovanni Herrerra regarding glory hole
3/31/2011 0.30 135.00 Telephone conference with Sakalo re discovery day
4/26/2011 0.50 225.00 Phone call with Homer Meruelo re discovery day
5/2/2011 0.40 180.00 Telephone conference with Mike Davis of Robinson

Waters counsel for a potential buyer of Colorado mines
5/4/2011 0.50 225.00 Telephone conference with buyer, auctioneer, title

company and M. Lessne re sale.
5/10/2011 0.30 135.00 Telephone conference with Mike Davis re offer to

purchase
6/7/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sean
Doyle and Sheriff Hartman regarding access to the Glory
Hole.
6/16/2011 0.20 90.00 Emails with Sean Doyle to A. Srour regarding earnest
money deposit wire.
6/16/2011 0.30 135.00 Emails with Sean Doyle and M. Dunn regarding receipt of
funds by wire.
Doyle regarding Compliance with Article IX.
6/20/2011 0.30 135.00 Emails with John Moffa regarding official offer to the
Trustee.
6/20/2011 0.20 90.00 E-mails with Franis Santos regarding marketing plan.
6/21/2011 0.20 90.00 Emails with A. Srour and F. Santos regarding setting a
conference call.
6/22/2011 0.20 90.00 Emails with M. Lessne regarding Gilpin County

Spreadsheet.
6/27/2011 0.80 360.00 Telephone with David Murphy regarding investor looking
to buy Glory Hole and resolve Caldwell claim
6/27/2011 0.30 135.00 E-mails with David Murray regarding potential offer that
your prospective clients have to purchase the Glory Hole
mine.
6/28/2011 0.30 135.00 Receipt and review of an email from F. Santos enclosing
budget for Merendon.
6/29/2011 0.30 135.00 Emails with David Murray regarding materials.
6/29/2011 0.20 90.00 Emails with David Murray regarding conference call.
6/29/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to David
Murray enclosing materials requested.
6/30/2011 1.30 585.00 Call with M. Lessne, D. Murray, G. Pappas, L. Fisher and
F. Santos (.6); seperate call with auctioneers (.7)

6/30/2011 0.20 90.00 Receive, review and reply to email with Gus Pappas
regarding Glory Hole.
7/1/2011 0.20 90.00 Receipt and review of emails between M. Lessne and Sean
Doyle re: Mine trespassers.
7/12/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Mr.
Dorn re: Website and Boulder County Mines.
7/13/2011 0.20 90.00 Receipt and review of an email from David Murray re:
bid
7/15/2011 0.30 135.00 Emails with David Murray re: Bid.
7/15/2011 0.70 315.00 Telephone conference with D. Murray of potential buyer,

email to and from him x 4
7/16/2011 0.20 90.00 aReceipt and review of an email from David Murray re:
bid.
7/18/2011 0.20 90.00 E-mail to an from Martin Hannan re: offer.
7/19/2011 0.20 90.00 Receipt and review of an email from M. Lessne enclosing
letter following up with the attorney for Worldwide Rental,
which claims a lien on the Boulder mine.
Doyle.
Doyle enclosing deeds.
7/22/2011 0.20 90.00 Receipt and review of an email from Francis Santos.
7/25/2011 0.30 135.00 Reviewing and responding to e-mail from F. Santos .
7/25/2011 0.20 90.00 Reviewing and responding to e-mail from Jay M. Sakalo
re: Deed.
7/26/2011 0.20 90.00 Receipt and review of Emails between M. Lessne and
Marica Dunn re: Sean Doyla's bid on the Boulder County
mines.
8/1/2011 0.30 135.00 Reviewing and responding to e-mail Jay Sakalo re:
installment land sales contract.
8/1/2011 0.30 135.00 Receipt and review of an email from Jay M. Sakalo
enclosing a Quiteclaim Deed - Bowerman to Merendon
8/2/2011 0.60 270.00 Telephone conference with Dr. Davis, a geologist who
represents some parties interested in the mines (.3);
telephone with ard capstick re same (.3)
8/9/2011 0.30 135.00 Receipt and review of an email from Jay Sakalo enclosing
quitclaim deed to Bowerman.
8/23/2011 0.20 90.00 Receipt and review of an email from Patrick Fagen to Jay
Sakalo re: executed deed.
8/23/2011 0.30 135.00 Telephone conference with potential buyer
9/9/2011 0.30 135.00 E-mails with Barry I. Grossman regarding Francis D.

Santos, auctioneer.
9/19/2011 0.20 90.00 Receipt and review of emails between M. Lessne and F.
Santos re AZ mines.
9/20/2011 0.30 135.00 Telephone conference with John Watters re potential

purchase of mine

9/22/2011 0.20 90.00 Receiving and reviewing of email from Sean Doyle to
Alicia with Boulder County regarding purchasing the real
and personal property assets owned by Merendon
Mining.
9/27/2011 0.40 180.00 Receipt and review of an email from L. Weltzer enclosing
report concerning the Glory Hole property in Gilpin
County, Colorado.
9/28/2011 0.20 90.00 E-mais with Paul Garfinkle re ownership of Sentinel

Mining Corp.
10/4/2011 0.10 45.00 Receipt and review of an email from A. Srour regarding
phone call from Jones Watters with Kitzman Trucking
from Colorado.
10/4/2011 0.10 45.00 E-mail from M. Lessne to Terry with Left Hand Ditch
Company regarding Merendon's shares.
10/5/2011 0.20 90.00 E-mails between M. Lessne and F. Santos regarding

marketing plan.
10/7/2011 0.20 90.00 E-mails with M. Lessne re outstanding Expense in Glory

Hole.
10/10/2011 0.20 90.00 Receiving and reviewing of an email from J. Leibner to M.

Dunn and F. Santos enclosing the Preview Release
Liability.
10/11/2011 0.20 90.00 E-mails with F. Santos re Inspection Waiver & Release of
Liability.
10/19/2011 0.10 45.00 E-mail from F. Santos to J. Leibner enclosing redlined

Inspection Waiver Release Form.
10/20/2011 0.10 45.00 E-mail from M. Dunn to F. Santos re Inspection Waiver &
Release of Liability.
10/24/2011 0.10 45.00 E-mail from A. Srour re call from Bill Hamilton potential
Mine buyer.
10/29/2011 0.10 45.00 E-mail from M. Lessne to Sean Doyle re Glory Hole's
Expense Reimbursement.
11/3/2011 0.20 90.00 E-mail from F. Santos re proposed advertisement/ notice

(Dunn v. Brost)
11/4/2011 0.20 90.00 E-mails with F. Santos re status of the Glory Hole
commission check
Doyle re Outstanding Expense in Glory Hole.
11/9/2011 0.20 90.00 Receipt and review of an email form M. Lessne to M.

Dunn enclosing Disclaimer of Interest and Trustee Deed
(Quartz Hill) and Trustee Deed (Superior Gold) for
execution and notarization.
11/9/2011 0.30 135.00 E-mail from John Moffa enclosing Disclaimer of Interest,
Trustee Deed (Quartz Hill) and Trustee Deed (Superior
Gold) for review and execution.
11/10/2011 0.30 135.00 Receipt and review of of an email from M. Lessne to M.

Dunn re Fisher Auction, Glory Hole with enclosed
documents.
11/10/2011 0.20 90.00 E-mail from M. Lessne to John Moffa enclosing executed
Disclaimer of Interest, Trustee Deed (Quartz Hill) and
Trustee Deed (Superior Gold)

11/29/2011 0.30 135.00 E-mail from L. Weltzer enclosing title commitment for the
property owned by Merendon Mining (Colorado), Inc. in
Boulder County.
12/6/2011 0.10 45.00 Review emails between M. Lessne and F. Santos re

Merendon - Ads published in Colorado.
12/12/2011 0.30 135.00 Emails from and to Sean Doyle enclosing information re
potential bidders for Merendon.
12/14/2011 0.20 90.00 Emails with F. Santos and M. Lessne re Auction of Bueno
and Black Rose Mining Properties.
1/3/2012 0.20 90.00 E-mails with F. Santos re Merendon Mining attorney for
proposed buyers: Eff Schatzman and Brian Behar
1/3/2012 0.20 90.00 Emails with Jeffrey N. Schatzman re proposed buyers Jeff
Schatzman and Brian Behar
1/3/2012 0.10 45.00 Emails with Brian Behar re bids on the mines
1/10/2012 0.20 90.00 Emails with M. Dunn re buyers
1/13/2012 0.20 90.00 Emails with M. Lessne, J. Leibner and Patrick Scott re
mechanics liens
1/17/2012 0.30 135.00 Telephone conference with John Watters regarding theft of
$30k from estate for taking rocks from Glory hole and not
remitting money to estate.
1/24/2012 0.30 135.00 Telephone conference with buyers re sub con order
1/25/2012 2.00 900.00 Multiple calls and emails to and from buyers counsel, title
company and our counsel regarding issues with
Worldwide's lien and Jamestown's Royalty deed.
1/30/2012 0.20 90.00 Emails with F. Santos and M. Dunn re closing the deal.
2/1/2012 0.20 90.00 Email with M. Dunn re orders reflect payment to

auctioneer
2/1/2012 0.20 90.00 Reviewing of emails between M. Dunn and Jeffrey

Bahnsen re funds.
2/7/2012 0.10 45.00 Review emails between M. Lessne and Sean Doyle re
Expense Reimbursement.
2/7/2012 0.20 90.00 Reviewing e-mail from M. Lessne to M. Dunn re Payment

of Expense Reimbursement and Deposit without Further
Order and Payment of Fisher's Commission
2/10/2012 0.20 90.00 Emails with M. Lessne and Fancis Santos re South
American Mines.
2/15/2012 0.20 90.00 Email from and to Greg Painter re Trinity Payment to
Merendon
2/15/2012 1.00 450.00 Multiple emails by and between Sakalo (.3), his clients
(.3), M. Lessne and trustee (.1) and teleconference with
Sakalo re early payoff (.3)
3/12/2012 1.30 585.00 Telephone conference with h counsel for buyers and Sean
Doyle re Doyle claims during due diligence process.
3/15/2012 0.30 135.00 Telephone conference with Jay Sakalo regarding deed and
early payoff on discovery day.

3/15/2012 0.60 270.00 Telephone conference with Moshe Onciu regarding
discovery day and buying south american mines
3/16/2012 0.30 135.00 Telephone conference with Howard Berman (.3); email to
and from Howard Berman re: Doyle (.1)
1/22/2010 1.10 495.00 E-mails with Riggs of Neiwirth's office, Nate Mancuso, S.
Khanorkar, Ward Capstick, R. Schatzman, Paul Garfinkel
(regarding settlement agreement) (.6); and attention to
matters for same (.5)
1/23/2010 0.40 180.00 E-mails with Schatzman (x3), and with Garfinkle (x1)
regarding settlement agreement
1/24/2010 0.60 270.00 E-mails with B. Elam and S. Khanorkar, and with Ken
Iredale re: settlement
2/18/2010 1.00 450.00 Telephone conference with potential buyer Mike Turner
(.3); telephone conference with potential buyer milt
shlaypac (.3) ; telephone with potential buyer Noreen
Griffin (.4)
2/18/2010 0.30 135.00 Conference with L. Negron and A. Brodsky re: recording
order in counties where mines are located and filing
suggestions of bankruptcy
2/25/2010 0.30 135.00 Telephone conference with John Skaggs re: glory hole
mining litigation
3/9/2010 2.00 900.00 Conference with Werner and potential buyer
6/8/2010 0.50 225.00 Emails with Gus Pappas regarding Glory Hole
6/11/2010 0.50 225.00 Telephone conference with Jason Welt and Lamar Fisher
6/14/2010 0.10 45.00 Receipt and review of notice of hearing on motion for
violation of the automatic stay and sanctions, etc.
6/22/2010 1.70 765.00 Meeting in office with Jason Welt, Lamar Fisher and F.
Santos of Fisher Auction and M. Dunn; telephone call with
Paul Garfinkle
6/24/2010 0.60 270.00 Telephone conference with Ward Capstick and Chris
Pierce, buyer and sale of assets
6/25/2010 0.60 270.00 Multiple emails with Jay Sakalo, M. Dunn and M. Lessne
regarding Trident settlement discussions
7/3/2010 0.80 360.00 Exchanging e-mails with Gus Pappas; review A. Brodsky's
email to opposing counsel and team regarding 9/20/10
pretrial date
7/7/2010 0.90 405.00 Exchanging e-mails with M. Lessne regarding auction

motion; review motion, affidavit of auctioneer, and
proposed order granting same; emails with Gus Pappas;
emails with Richard Brodsky, Nordic's counsel
7/12/2010 0.30 135.00 Emails with J. Leibner regarding research on sales contract
recordation and various other matters

7/14/2010 0.90 405.00 E-mail from F. Santos regarding offer from Winderman
(.1); emails with Greg Levine regarding his mother, Barbra
Lurie's Proof of claim and case status of same (.8).
7/16/2010 2.20 990.00 Exchanging e-mails with Fisher Auction, A. Brodsky, M.

Lessne regarding bonds, affidavit, etc.(1.0); file application
to employ (.5); transmit filed application to team (.2); post
to website (.2); emails with L. Hughes regarding permanent
injunction (.3)
7/19/2010 1.00 450.00 Exchanging e-mails with Lamar at Fisher Auction and M.
Lessne regarding Letter of Intent for Colorado (0.3);
Telephone conference with J. Leibner regarding
memorandum report and with H. Winderman and A.
Brodsky regarding Letter of Intent (.7)
7/20/2010 0.70 315.00 Receiving and reviewing NEF of Order Granting

Application to Employ Fisher Auction Co., as Auctioneer
(.1); forward to team, including J. Armengol and Fisher
Auction (.1); post to website (.1); file certificate of service
(.2); emails with Jay Sakalo regarding documents he sent
(.2)
7/25/2010 0.10 45.00 Reviewing e-mail from S. Khanorkar to Gus Pappas re:
mines
7/26/2010 0.60 270.00 Exchanging e-mails with Gus Pappas regarding auction and
email to Garfinkle (.3); emails with Jason Welt re: same
(.3)
7/27/2010 0.20 90.00 Exchanging e-mails with M. Lessne and S. Stirling

regarding CO property title search
7/28/2010 1.30 585.00 Exchanging e-mails with M. Lessne and S. Stirling

regarding CO property title search and legal description to
Stephen Perin (.4); email from Maureen and Michael
Bondor (creditors) transmitting correspondence from Great
While Nevada (.1); email from K atie Carter (creditor)
regarding case status (.1); receipt and review of revised
memo report from J. Leibner (.5); email with J. Ryan
regarding mucker offer (.2)
7/28/2010 4.00 1,800.00 Review case law and memo in preparation for meeting with
Discovery Day and Trinity's counsel (2.1), attendance at
meeting with M. Dunn, M. Lessne and J. Leibner to
discuss pending issues and settlement (1.9)
7/29/2010 2.60 1,170.00 Exchanging e-mails with Jay Sakalo regarding Webeska
Mining; with S. Stirling regarding title; receipt and review
of Trustee's Interim Report for Period Ending 6/30/10;
email response to creditor, Katie Carter; emails with
Stephen Perin, S. Stirling, Fisher, M. Dunn, M. Lessne
regarding mucker, title search, auction
7/30/2010 1.00 450.00 Exchanging e-mails with N. Mancuso, S. Stirling, J.

Leibner, M. Lessne regarding CO mine sale, title
8/2/2010 1.50 675.00 Exchanging e-mails with S. Stirling and M. Lessne re

Letter of Intent for purchase of three properties (.4); motion
for approval of sale of mucker equipment (.4); title issues
(.2); emails with F. Santos regarding Capstick and
Garfinkle's interest in Glory Hole and email to Capstick
(.3); emails with creditor Melanie Sears re case status (.2)
8/4/2010 0.20 90.00 Exchanging e-mails with Garfinkle regarding sale of Glory
Hole property

8/5/2010 1.40 630.00 Exchanging e-mails with J. Leibner regarding tracing
theory (.20; Telephone conference with S. Stirling and M.
Lessne regarding title search for the three mines (in Gilpin
and Boulder counties)(1.0); emails with Les Taylor
regarding Black Rose, Bueno and Discovery Day (.2)
8/6/2010 1.60 720.00 Exchanging e-mails with F. Santos, S. Stirling and M.

Dunn regarding Norman Frank's equipment at Bueno to be
removed from auction list (.3); meeting with M. Lessne re
sale motion and complaint (1.1); review emails between S.
Stirling and Marcus Willi ams re title (.2)
8/8/2010 0.70 315.00 Reviewing e-mails from S. Stirling to Les Taylor re

Mucker (.2); meeting with A. Brodsky re Nordic hearing
(.5)
8/9/2010 0.50 225.00 Reviewing e-mails from M. Lessne and L. Weltzer

regarding title (.20; meeting with M. Lessne re amended
Letter of Intent (.2); review Mike's emails with H.
Winderman regarding modified Letter of Intent dated
8/9/10 (.1)
8/11/2010 1.90 855.00 Reviewing e-mails between M. Lessne and Michael

Morrison regarding Wabuska, and between M. Lessne and
S. Stirling regarding Bueno equipment (.7); review email
from S. Stirling regarding bid request (.1); multiple emails
with H. Winderman regarding sa le motion (1.1)
8/12/2010 2.20 990.00 Exchanging e-mails with M. Lessne regarding his call and
emails with Mark Levin (.3); meeting with L. Hughes re
waiver status and consent to permanent injunction (.5);
from Matt Kramer at Bilzin Sumberg transmitting draft
agreed motion to vacate subc on and partial summary
judgment (.2); meeting with A. Brodsky regarding
communciation from creditor Orist Pashko (.3); review M.
Lessne's email to H. Winderman re revising sale motion to
add stalking horse protections (.2); review emails between
Dr. Salit and M. Lessne regarding sale of Colorado mining
properties and with M. Lessne re same (.3);meeting with S.
Stirling regarding draft complaint (.2); receipt and review
of Order Granting Agreed Motion to Permit Expenditure of
Funds by Nordic for Legal Representation (.2)
8/13/2010 0.30 135.00 Telephone conference with buyers representatives
8/13/2010 1.80 810.00 Exchanging e-mails with F. Santos and M. Lessne re Sale
(.3); review emails between S. Stirling, M. Lessne and L.
Weltzer re: same (.4); review equipment photos and AZ
legal description and ownership information with Mike and
S. Stirling as well as d iscuss Mucker, auction, emails from
Lawrence Hittle and motion (1.1)
8/15/2010 0.30 135.00 Exchanging e-mails with L. Weltzer and M. Lessne

regarding title search
8/16/2010 1.50 675.00 Exchanging e-mails with S. Stirling and M. Lessne re water
rights to the Colorado mines (Bueno, Black Rose, Glory
Hole), Discovery Day and Arizona mine (.3) and
conversation with Garfinkle re same (.9); review S.
Stirling's email to Lawrence Hittle i n Jamestown and S.
Stirling's emails with M. Lessne (.3)
8/17/2010 3.00 1,350.00 Draft and revise asset purchase agreeement
8/18/2010 0.10 45.00 Receipt and review of Notice of Appearance of John Moffa
for Estate of Harold Caldwell

8/19/2010 0.50 225.00 Telephone conference with Milt Shlapack, buyer for
mines
8/25/2010 0.40 180.00 Conference call with Colorado title agent, Louis Weitzer
8/29/2010 0.40 180.00 E-mail from Garfinkle re case status (.2); review emails
between S. Stirling and M. Lessne re L. Weltzer's report
showing parties having recorded claims or interest (.2)
9/2/2010 0.20 90.00 Emails with Jason Welt re auction (.1); forward Garfinkle's
email re Glory Hole to Francis (.1)
9/3/2010 3.50 1,575.00 Exchanging e-mails with M. Lessne, S. Stirling and A.

Brodsky re filing motion for sale of property (.5); finalize
and file sale motion (1.8); discuss complaint with M.
Lessne (.5); foward sale motion to H. Winderman, F.
Santos (.1); exchange emails with Garfinkle re motion for
stay relief, etc. (.3); emails with M. Lessne and H.
Winderman re Asset purchase agreement (.3)
9/3/2010 5.00 2,250.00 Review and revise sale motion, complaint and asset
purchase agreement
9/8/2010 1.40 630.00 E-mail to H. Winderman regarding status of Asset purchase

agreement and deposit (.1); serve answer to SEC complaint
on L. Hughes and forward to M. Dunn (.3); emails with L.
Hughes and A. Brodsky re filing the answer to complaint
and with A. Brodsky r e obtaining local WA counsel re
same (.3); receipt and review of consent and order from L.
Hughes (.2); discuss same with her (.3); multiple emails
with Matt Kramer and Jay Sakalo regarding corrections to
agreed motion to vacate (.2)
9/10/2010 2.90 1,305.00 Exchanging e-mails with H. Winderman re asset purchase

agreement and deposit (.2), and also with M. Lessne, J.
Armengol, F. Santos (.3); receipt and review of notice of
hearing on sale motion (.3); serve by email and mail to all
on service list (1.7) ; forward to M. Dunn, H. Winderman,
F. Santos and J. Armengol (.4)
9/11/2010 0.10 45.00 Receipt and review of recorded Glory Hole documents
from L. Weltzer
9/12/2010 0.30 135.00 Exchanging e-mails with F. Santos and Garfinkle
9/13/2010 1.00 450.00 Telephone conference with F. Santos re: sale (.3);
telephone with H. Winderman x 2 (.6) both re terms of the
sale; revise asset purchase agreement to reflect new break
up fee and bidding increments (.1)
9/15/2010 0.80 360.00 Exchanging e-mails with Gus Pappas re sale motion; Joe
Davies re Clearwater Mining/Caldwell (.2); telephone
conference H. Winderman re revised Asset purchase
agreement (.3)
9/16/2010 0.80 360.00 Emails with Mike an F. Santos re Asset purchase

agreement and deposit, and conversation with Dr. Salit
(.4); emails with H. Winderman re Asset purchase
agreement and deposit (.4)
9/20/2010 0.80 360.00 Exchanging e-mails with F. Santos re Asset purchase

agreement and deposit (.2); telephone conference with S.
Stirling re complaint (.3); in SEC v. Merendon matter:
receipt and review of agreed motion for preliminary
injunction v. Adair (.3)

9/20/2010 0.60 270.00 Telephone conference with Dr. Savitt, the buyer re
potential interference with sale by another potential buyer
(.3); telephone with Garfinkle re same (.3)
9/20/2010 0.30 135.00 Telephone conference with Milt Schlapack
9/21/2010 1.10 495.00 Exchanging e-mails with F. Santos re Asset purchase

agreement and deposit status (.2); telephone conference
with F. Santos, M. Lessne, Dr. Salit, M. Dunn and B.
Mukamal regarding Garfinkle's attempt to interfere with
stalking horse party (.3); review S. Stirling's transmission
to M. Dunn of the complaint with exhibits for review;
telephone conference with S. Stirling re motion to defer
costs of filing complaint (.3)
9/21/2010 0.10 45.00 E-mail to H. Winderman, et al regarding Asset purchase

agreement and deposit still not received and request for
status update
9/22/2010 0.20 90.00 Emails with H. Winderman re status of Asset purchase

agreement and deposit
9/23/2010 1.20 540.00 Telephone call from and with Dr. Salit (.9); emails with F.
Santos re status of Asset purchase agreement and deposit
(.3)
9/23/2010 0.30 135.00 Telephone conference with F. Santos re sale
9/24/2010 0.60 270.00 Telephone call from and with Dr. Savit (.3); telephone call
with F. Santos re: sale (.3)
9/28/2010 1.00 450.00 Telephone conference with Dr. Savit (.3); telephone
conference with buyer (.7)
10/11/2010 0.50 225.00 Telephone with Paul Danio, representative of new potential
buyer and getting permission to look at property
10/11/2010 0.30 135.00 Telephone conference with paul danio re sale (.3);
10/14/2010 0.30 135.00 Telephone conference with Michael Morrison, Esq.,

represents Wabuska Mining
10/15/2010 0.80 360.00 Telephone with Mike Morrison on california discovery day
mines and settlement re same (.5), conference with Matt
kramer re same (.3)
10/18/2010 1.00 450.00 Telephone with Mike Morrison on california discovery day
mines and settlement re same (.5), and telephone with Matt
Krmaer re same (.5)
10/19/2010 0.50 225.00 Telephone conference with M. Dunn re settlement

discussions regarding discovery day mone in california
10/22/2010 1.50 675.00 Settlement conference with trustee and others regarding
discovery day mine
10/26/2010 0.50 225.00 Telephone with EPA and Department of Justice re

Colorado mines
10/28/2010 1.00 450.00 E-mails to and from A. Brodsky from the EPA about
potential buyer (.5) and emails to and from auctioneer re
same (.5)
10/29/2010 0.30 135.00 Telephone conference with Jay Sakalo re settlement
11/1/2010 0.60 270.00 Telephone with Sakalo re settlement on Discovery Day x 2

(.6)

11/19/2010 1.00 450.00 Settlement conference call with client Jay Sakalo and his
clents regarding Discovery Day
11/29/2010 0.60 270.00 Telephone conference with Sakalo re settlement re

discovery day (.3) and email to and from M. Dunn and jay
re same (.3)
1/10/2011 0.50 225.00 E-mails between John Moffa and M. Lessne
2/17/2011 0.50 225.00 conference call with M. Lessne & J. Sakalo re: Discovery
Day.
2/23/2011 0.60 270.00 Conference call with M. Lessne, F. Santos, Marcis Dunn
and Jason Welt regarding offer
3/16/2011 1.10 495.00 Conference call with trustee and our experts and auctioneer
on selling properties
3/24/2011 1.00 450.00 Review Settlement and offer and conference with Sakalo
and Lessne re: changes
4/22/2011 1.00 450.00 Conference with client re stalking horse and offers for mine
with M. Dunn and mike
5/31/2011 0.30 135.00 Receipt and review of email from M. Lessne to M. Dunn
and F. Santos enclosing the Asset purchase agreement
agreement.
5/31/2011 0.20 90.00 Emails with receipt Patrick Fagen and M. Dunn regarding
funds.
Doyle enclosing the Glory Hole Asset purchase
agreement.
Doyle re: Asset purchase agreement.
6/6/2011 0.20 90.00 Receipt and review of an email from Sean Doyle to M.
Lessne enclosing an executed Asset purchase agreement.
6/6/2011 0.20 90.00 Receipt and review of an email from M. Lessne to M.

Dunn RE: execution of the Asset purchase agreement.
6/6/2011 0.20 90.00 Receipt and review of an email from Sean Doyle regarding
Agreement that has the correct corporate name for the
Purchasing entity.
Doyle enclosing a fully executed Asset purchase
agreement.
6/7/2011 0.20 90.00 Receipt and review of an email from Alexandra Castro
enclosing the Asset purchase agreement.
6/7/2011 0.20 90.00 Receipt and review of an email from Tim Millar re: status
of the Glory Hole auction .
6/7/2011 0.20 90.00 Receipt and review of emails between Jason Welt and M.
Lessne regarding Asset purchase agreement and Sale and
Notice Procedures - Executed Asset purchase agreement.
6/8/2011 0.20 90.00 E-mails with M. Lessne regarding motion to sell and
approve.
6/8/2011 0.20 90.00 E-mails with M. Lessne and A. Srour regarding Amended
sale motion.
6/8/2011 0.30 135.00 Reviewed motion to sell and approve.

6/9/2011 0.20 90.00 E-mails with M. Lessne regarding Motion to Sell Certain
Property of the Estate.
6/9/2011 0.20 90.00 E-mails with M. Lessne regarding obtaining thirty day
extension on the sale hearing and the pretrials.
6/9/2011 0.20 90.00 E-mails with J. Cartagena regarding email to all parties
requesting an extension of time to file a renewed motion to
sell the property.
6/9/2011 0.20 90.00 Receipt and review of emails between M. Lessne and N.
Nicole regarding Motion for Sale and Order on same.
6/9/2011 2.00 900.00 Review revise and draft sale motion and procedures
6/9/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to all
interested parties requesting a 30-Day Continuance of
Hearing set for 6/23 on Amended Sale Motion and Pretrial
Conferences.
6/9/2011 0.20 90.00 Receipt and review of an email from A. Srour to F. Santos
enclosing an Amended Motion for Sale of Property the
Glory Hole Mining Properties Free and Clear of Liens,
Claims, Encumbrances, and Interests, including Interests of
Anyone Laying Claim to th e Estates Rights and Interests
in such Properties, pursuant to 11 U.S.C. Â§105 and
Â§363(B) and (F); (B) Set the Sale Procedures and Sale
Hearing Date
6/10/2011 0.20 90.00 Receipt and review of an email from Arthur C. Neiwirth
advising of no objection to extend the hearing date for the
Amended Sale Motion and the Pretrial Conferences.
6/14/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to all
interested parties requesting the hearing to be continued
and scheduled for the middle of July 2011, during the week
of July 18th through July 22nd.
6/16/2011 0.30 135.00 Receipt and review of Order Granting Motion To Continue
Hearing on Amended Motion for Sale of Property the
Glory Hole Mining Properties Free and Clear of Liens
6/17/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Dana
Kinsman regarding Upcoming Mine Auction.
6/20/2011 0.50 225.00 Telephone conference with David Murray re sale of Glory
Hole mine
6/21/2011 0.20 90.00 Receipt and review of an email from A. Srour to John
Moffa enclosing the Asset purchase agreement.
6/22/2011 0.50 225.00 Conference call with auctioneers and client and mike re
marketing plan when sale procedures are approved for
glory hole
6/29/2011 0.40 180.00 Emails with John Moffa regarding acceptance of the
proposal.
7/5/2011 0.40 180.00 Emails with John Moffa regarding confidential settlement
negotiations.
7/11/2011 0.10 45.00 E-mail to client enclosing the Asset purchase agreement.
7/11/2011 0.50 225.00 Telephone conference with Auctioneers, trustee,

accountants, and Mike re sale hearing and consideration of
caldwell bid

Doyle attaching Exh A to the Asset purchase agreement.
7/18/2011 0.30 135.00 E-mails with M. Dunn and M. Lessne re: Sean Doyle needs
to amend the Asset purchase agreement
7/19/2011 0.30 135.00 Receipt, review and reply to an email from John Moffa re:
Settlement offer.
7/19/2011 0.20 90.00 E-mail to John Moffa re: check received.
7/20/2011 0.30 135.00 Emails with Martin Hannan regarding sale date.
7/21/2011 0.30 135.00 Receipt and review of an email from Mr. Hanna enclosing
a proposed Asset purchase agreement.
7/22/2011 0.20 90.00 Receipt and review of an email from F. Santos attaching
pictures of the Bueno Mine and Black Rose.
Doyle re: information on the Black Rose and Bueno
mining claims
7/22/2011 0.30 135.00 Reviewing and responding to e-mail from John Moffa re:
requesting a title search conducted on properties.
7/22/2011 1.50 675.00 Telephone conference with buyer Sean Doyle & Mike re
result of hearing; telephone conference with John Moffa re
settlement, email to client and client professionals re result
of both calls
7/26/2011 0.20 90.00 Receipt and review of an email form David Murray re:
auction sale of mining claims.
7/26/2011 0.90 405.00 Receipt and review of Order Denying Amended Motion for
Sale of Property.
Doyle enclosing the proposed agreement.
7/27/2011 0.20 90.00 Reviewing and responding to e-mail from John Moffa.
7/28/2011 0.20 90.00 Receipt and review of an email from A. Srour to M. Dunn
enclosing an executed Asset purchase agreement for the
Bueno Mines.
Doyle enclosing executed Asset purchase agreement.
8/1/2011 0.40 180.00 Reviewing and responding to e-mails from John Moffa
enclosing draft of a Stipulation.
8/2/2011 0.10 45.00 Receipt and review of an email from A. Srour to Sean
Doyle enclosing a fully executed copy of the Asset
purchase agreement.
8/2/2011 0.20 90.00 Reviewing and responding to e-mail from Jason Welt re:
Auction.
draft of the Stipulation.
8/3/2011 0.30 135.00 Receipt and review of emails from M. Lessne to John
Moffa enclosing the Settlement Stipulation.
8/3/2011 0.50 225.00 Receipt and review of Notice of Hearing on Motion for
Sale of Property (.3) and attention to matter re: same (.2)

8/3/2011 0.20 90.00 Reviewing and responding to e-mail from Judd Allen re:
Merendon properties in Gilpin county.
8/3/2011 0.20 90.00 Reviewing and responding to e-mails from A. Srour re:
setting hearing on Motion to Approve Sale.
8/3/2011 0.30 135.00 Receipt and review of Notice of Hearing on Motion for
Sale of Property
settlement Stip.
8/5/2011 0.20 90.00 Reviewing and responding to e-mail from Adam Katz re:
motion to sell free and clear (Bueno and Black Rose
properties)
Caldwell Stipulation.
Hearing On Amended Motion for Sale of Property.
Stipulation.
8/12/2011 0.30 135.00 Telephone conference with Robert Eber of colorado

attorney generals office re sale of Glory Hole
8/18/2011 0.40 180.00 Reviewing and responding to e-mail from M. Lessne

enclosing motion for approval of settlement and order
granting same for review.
enclosing signed Stipulation re: Fedrigon and a signed
Stipulation for Settlement.
8/18/2011 0.30 135.00 Telephone conference with Paul Garfinkle re: mines
8/18/2011 0.20 90.00 Receipt and review of emails between M. Lessne and
Dawn Caldwell re: Stipulation.
8/18/2011 0.20 90.00 Reviewing and responding to e-mails from M. Lessne re:
9019 Motion
8/18/2011 0.40 180.00 Reviewing and responding to e-mail an email from John
Moffa enclsing final draft of the Stipulation and a second
attachment with the signatures of his clients.
8/19/2011 0.20 90.00 E-mail to A. Srour and J. Cartagena re: Motion to

Compromise Controversy with and to Approve
Settlement.
8/19/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to Adam
Katz enclosing Notice of Filing Exhibit A to the Settlement
Agreement.
8/19/2011 0.20 90.00 Reviewing and responding to e-mail from Adam Katz re:
9019 Motion to Approve Settlement.
8/19/2011 0.20 90.00 Receipt and review of an email from Paul Garfinkle to Gus
Pappas re: agreement with the Trustee to settle the Glory
Hole Issue.
8/20/2011 0.40 180.00 Reviewing and responding to e-mails from Paul

Garfinkle.
8/22/2011 0.30 135.00 Receipt and review of Notice of Hearing on Motion to

Compromise Controversy with and to Approve
Settlement.

8/23/2011 0.30 135.00 Emails with John Moffa re: Objections to Glory Hole Sale
8/23/2011 0.40 180.00 Receipt and review of an email from Paul Garfinkle
enclosing Objections to your proposed sale of the Glory
Hole Assets.
8/23/2011 0.20 90.00 Reviewing and responding to e-mail an email from John
Moffa re: Objections to Glory Hole sale
8/25/2011 0.60 270.00 Receipt and review of Objection by Paul Garfinkle to

Trustee's Motion to Approve Settlement with the Estate of
Harold Cald Well Through its Personal Representative,
Dawn Caldwell Fedrigon, and Dawn and Michael Fedrigon
and email to client regarding the same.
8/25/2011 0.30 135.00 Receipt and review of an email from J. Cartagena enclosing
Notice of Filing Receipt of Objection by Paul Garfinkle for
review.
8/25/2011 0.30 135.00 Receipt and review of Objection to Motion to Compromise

Controversy with and to Approve Settlement.
8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour to M. Dunn
enclosing Objection by Paul Garfinkle to Trustee's Motion
to Approve Settlement with the Estate of Harold Cald Well
Through its Personal Representative, Dawn Caldwell
Fedrigon, and Dawn and Mic hael Fedrigon.
8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour to John
Moffa enclosing Objection by Paul Garfinkle to Trustee's
Motion to Approve Settlement with the Estate of Harold
Cald Well Through its Personal Representative, Dawn
Caldwell Fedrigon, and Dawn and Michael Fedrigon.
8/27/2011 0.20 90.00 Reviewing and responding to e-mail from Martin Hannan
re: Trustee's Motion to sell free and clear of liens
8/29/2011 0.20 90.00 Reviewing and responding to e-mail from F. Santos re: an
update on the status of the Bueno and Black Rose Mine
auction as far as a projected sale date.
9/6/2011 0.20 90.00 Receipt and review of email to and from Tim Millar re
asset disposition of mines
9/6/2011 0.30 135.00 Emails with Tim Millar regarding settlement.
9/6/2011 0.30 135.00 Telephone conference with Andrea madagan of EPA
9/6/2011 2.30 1,035.00 Telephone conference with Sean Doyle re his possibly
backing out of agreement (.7); telephone with Andrea
Madigan re: same x 2 (.7); telephone with both (.9)
9/6/2011 0.30 135.00 E-mails with Sean Doyle, M. Lessne and Andrea Madigan
regarding conference call to discuss the Bueno and Black
Rose mines.
9/7/2011 0.30 135.00 E-mails with Taz regarding settlement reached for the
Glory mine.
9/8/2011 0.30 135.00 E-mails with A. Srour and M. Lessne regarding Rob
Meacham's call on the Motion to Approve settlement and
Motion to Approve Sale.

9/9/2011 0.30 135.00 E-mail from Laurie Bobrow enclosing correspondence
from Robert Meacham regarding Glory Hole Mining
Properties (“Settlement Motion”) and the second is the
Amended Motion to (A) Approve The Sale of the Bueno
and Black Rose Mining Properties Free and Cl ear of
Liens, Claims, Encumbrances, and Interests Pursuant to 11
U.S.C. § 363; (B) Set the Sale Procedures and Sale
Hearing Date; and (C) Set the Notice Procedures For the
Sale generally referring to the Bueno and Black Rose
Mining Properties (“Sale Motion”).
9/9/2011 0.30 135.00 E-mails with J. Cartagena and M. Lessne regarding the
Amended Sale Motion for Glory Hole and 9019 motion as
well as the second amended sale motion
9/9/2011 0.10 45.00 Receipt and review of email from Robert Meachem re
potential objection to sale of mines
9/14/2011 0.30 135.00 E-mails with John Muffa regarding Objection to Settlement
Motion.
9/15/2011 0.20 90.00 Emails with John Muffa regarding joint response to the
Garfinkle objection.
9/19/2011 4.30 1,935.00 Receipt and review of and revise draft of joint response to
garfinkle objection to sale (3.5), review garfinkle objection
(.5) and telephone with Moffa re same (.3)
9/19/2011 0.60 270.00 Telephone conference with David Murray (.3); telephone
with Charles Gryba (.3) both re sale
9/20/2011 0.20 90.00 E-mail to Brent Baker enclosing purchase contract.
9/20/2011 0.20 90.00 Emails with M. Lessne and J. Cartagena regarding hearing
on 9019 Settlement Motion.
9/20/2011 0.50 225.00 Telephone conference with Moffa counsel to Caldwell

estate re response to objection
9/21/2011 0.40 180.00 E-mails with John Muffa regarding revisions to the Joint
response by Dunn and Caldwell to Paul Garfinkle's
objection.
9/21/2011 0.20 90.00 E-mail to Brent Baker enclosing Trustee's Amended

Motion to Approve the Sale of the Bueno and Black Rose
Mining Properties,
9/21/2011 0.20 90.00 E-mails with Martin Hannan regarding 9019 Settlement
Motion scheduled for Sept. 27, 2011 with regard to the the
Glory Hole Mines.
9/21/2011 2.00 900.00 Review revising and drafting joint response to objection to
settlement.
9/22/2011 0.30 135.00 E-mails with John Muffa enclosing Dunn & Caldwell Joint
Response to Paul Garfinkle's Objection to Settlement.
9/22/2011 2.00 900.00 Review revising and drafting joint response to objection to
settlement
9/22/2011 0.20 90.00 E-mails with J. Cartagena regarding filing of Dunn &
Caldwell Joint Response to Garfinkle Objection to
Settlement.
9/22/2011 0.20 90.00 Receipt and review of an email from F. Santos to Charles
Gryba re Bueno and Black Rose Mining Claims enclosing
attachments.

9/23/2011 0.30 135.00 Receipt and review of Motion to Continue Hearing On:
Motion to Compromise Controversy and Motion to
Approve Settlement.
9/23/2011 0.30 135.00 Emails with Martin Hannan regarding Motion to Continue
Hearing on Motion to Compromise Controversy.
9/26/2011 0.20 90.00 E-mail from M. Lessne to Sean Doyle regarding executed
amendment.
9/26/2011 0.20 90.00 E-mails with Martin Hannan regarding 9019 Settlement
Motion.
9/26/2011 0.10 45.00 Receipt and review of an email from Sean Doyle to M.
Lessne re Amendment to Asset purchase agreement.
9/27/2011 1.60 720.00 Revise settlement order and submit to court, emails to and
from parties re same
9/27/2011 0.20 90.00 E-mails with J. Leibner regarding Research on Standing of

Paul Garfinkle's Arguments.
9/27/2011 0.20 90.00 E-mail from Adam Katz regarding motion to sell free and
clear (Bueno and Black Rose properties).
9/27/2011 0.20 90.00 E-mail to Sean Doyle regarding sale of the Boulder county
properties.
9/28/2011 0.20 90.00 E-mails with Jason Welt regarding sale of the Boulder
county properties.
9/28/2011 0.20 90.00 E-mails with John Moffa enclosing an Order Approving
Settlement with Caldwell based upon the court's ruling of
September 27, 2011 hearing.
9/29/2011 0.50 225.00 Receipt and review of Garfinkle's Answer to Joint

Response to Objection to Motion to Compromise
Controversy with and to Approve Settlement with the
Estate of Harold Caldwell through its Personal
Representative, Dawn Caldwell Fedrigon, and Dawn and
Mi chael Fedrigon with exhibits (.4)and email to client
enclosing the same (.1)
9/30/2011 0.10 45.00 E-mai from A. Srour to Robert Andrews reagrding

settlement of the Estate of Harold Caldwell.
9/30/2011 0.50 225.00 E-mails with M. Lessne regarding Order granting Sale
Motion (Bueno and Black Rose Mines) and review of the
same.
9/30/2011 0.10 45.00 E-mail from J. Cartagena regarding Merendon Stipulation

Time Line.
9/30/2011 0.10 45.00 E-mail from J. Cartagena to M. Dunn, John Moffa and F.
Santos enclosing Order Granting Motion to Approve
Settlement with the Estate of Harold Caldwell through it's
Personal Representative.
9/30/2011 0.30 135.00 E-mails with John Moffa regarding Merendon Stipulation
Time Line.
10/3/2011 5.00 2,250.00 Revise draft of sale order

10/5/2011 0.10 45.00 E-mail to M. Lessne, J. Cartagena and A. Srour regarding
service of Order on Motion for Sale of Property Merendon
Mining.
10/5/2011 0.30 135.00 E-mail from Sean Doyle to M. Lessne enclosing an

expense to be reimbursed in the Glory Hole settlement.
10/5/2011 0.20 90.00 Receipt and review of Order Granting Trustee's Amended
Motion to Approve the Sale of Property.
10/6/2011 0.20 90.00 E-mail from F. Santos regarding the property tour scenario
of the Bueno and Black Rose Mines.
10/17/2011 0.50 225.00 Telephone conference with Marcia, Francis, and Mike re
marketing the sale
10/17/2011 0.20 90.00 E-mail to John Moffa regarding settlement money.
10/19/2011 0.20 90.00 E-mails with John Moffa re receipt of settlement money.
10/19/2011 0.10 45.00 E-mail from John Moffa re wiring of the settlement
money.
10/20/2011 0.20 90.00 E-mails with John Moffa and M. Dunn regarding
settlement money.
10/27/2011 0.20 90.00 E-mails between M. Lessne and M. Dunn re Service of the
Order Granting Sale Motion re Bueno and Black Rose
Mines dated October 5, 2011.
10/31/2011 0.10 45.00 E-mail from M. Lessne to L. Weltzer re Heritage Title's

Invoices.
11/4/2011 0.20 90.00 Emails with M. Dunn and M. Lessne re of the Glory Hole
commission check
11/7/2011 0.10 45.00 Receipt and review of an email from Jason Welt to M.
Dunn re Bueno and Black Rose mines in Boulder, Co.
11/14/2011 0.20 90.00 Receipt and review of e-mail from M. Lessne to M. Dunn
enclosing invoice from Heritage Title
11/21/2011 0.20 90.00 Receipt and review of an email from geologist, Amandip
Singh re the Bueno and Black rose properties.
11/29/2011 0.10 45.00 Receipt and review of an email from Paul Garfinkle re
Glory Hole and Sentinel Mining Corporation.
12/1/2011 0.20 90.00 Receipt and review of emails between M. Lessne and J.
Cartagena re Service of the Order Granting Sale of Bueno
12/7/2011 0.20 90.00 Reviewing of Certificate Of Service Regarding Order

Granting Trustee’s Amended Motion To (A) Approve The
Sale Of The Bueno And Black Rose Mining Properties
Free And Clear Of Liens, Claims, Encumbrances, And
Interests Pursuant To 11 U.S.C. §363; (B) S et The
Sale Procedures And Sale Hearing Date; And (C) Set The
Notice Procedures For The Sale [D.E. # 284]
12/14/2011 0.20 90.00 E-mails with Clark G. Edwards from HUTCHINSON

BLACK AND COOK, LLC who represents Left Hand
Ditch Company re 1/4/2012 auction.
12/14/2011 0.20 90.00 E-mails with M. Lessne re Auction of Bueno and Black

12/20/2011 0.20 90.00 Reviewing e-mails between Jesscia Serrano and Marcia
Dunn re fully executed Asset Purchase Agreement
1/3/2012 0.20 90.00 Emails with M. Lessne and Judicial Assistant Barbara
Cargill re Hearing to Approve Sale of Bueno and Black
Rose Mines.
1/3/2012 0.10 45.00 Reviewing of email from M. Lessne to Francis Santos re

Asset Purchase Agreement between David Badner/Badner
Group Inc.
1/5/2012 0.20 90.00 Review of Order Approving Sale of Bueno and Black Rose
Mining Properties.
1/6/2012 0.10 45.00 Emails with M. Lessne and Jeffery A. Bahnsen re Closing
on Sale of Gold Mines.
1/6/2012 0.10 45.00 Reviewing e-mail from M. Dunn to Tong Li re: sale of
Bueno and Black Rose
1/9/2012 0.20 90.00 Emails with M. Lessne re Order Approving Sale of Bueno
and Black Rose Mining Properties Asset purchase
agreement.
1/10/2012 0.30 135.00 Emails with Tong Li re Order approving sale procedures
and re telephone conference.
1/10/2012 0.10 45.00 Emails with Barry I. Grossman re Proposed Order

Approving Sale of Bueno and Black Rose Mining
Properties.
1/11/2012 0.30 135.00 E-mail to Tong Li, Sarah E. Williams and Barry Grossman
and clients enclosing Order approving Sale of the Boulder
County properties to Badner and emails re same.
1/11/2012 4.00 1,800.00 Draft sale order and revisions to same and telephone with
buyers counsel re same
1/11/2012 0.20 90.00 Emails with M. Lessne and Tong Li re revising the
proposed Order Approving Sale of Bueno and Black Rose
Mining Properties
1/12/2012 0.10 45.00 Receipt and review of emails between M. Lessne and Tong
Li re final version of the proposed Order Approving the
Sale of Bueno and Black Rose Mining Properties
1/17/2012 0.10 45.00 Receipt and review of Order Approving the Sale of the
Bueno and Black Rose Mining Properties and email to
client enclosing the same.
1/18/2012 0.20 90.00 Emails with Robert Meacham re order approving the sale
of Bueno and Black Rose Mines.
1/19/2012 0.20 90.00 Reviewing of Certificate of Service of Order Approving

Sale of Bueno and Black Rose Mining Properties
1/24/2012 0.20 90.00 Receipt and review of Trustee's Deed and Turstee's Bill of
Sale.
1/24/2012 0.20 90.00 Emails with Tong li re Final Trustee's Deed and Bill of
Sale - Bueno and Black Rose Mining Properties
1/24/2012 0.20 90.00 Emails with M. Lessne, Jeff Bahsen and Tong Li re
regarding the deed in Boulder county.
1/25/2012 0.20 90.00 E-mail from and to Tong Li re Revised Trustee's Deed.

1/25/2012 0.10 45.00 Receipt and review of of an email from Jeff Bahnsen to M.
Dunn re Closing Documents.
1/27/2012 0.20 90.00 Reviewing and revising of Memorandum to M. Dunn re

Gold Basin Mine, Dolen Springs, Arizona.
1/31/2012 0.10 45.00 Email with J. Cartagena re Title search in Dolan Springs,
AZ for Merendon Mining.
1/31/2012 0.30 135.00 Emails with Jeffrey Bahnsen re Statement of Lost Stock
Certificate and reviewing of the same.
3/30/2012 0.10 45.00 Trustee's Motion to Approve Settlement with Worldwide

Rental Services
3/30/2012 0.10 45.00 Receipt and review Trustee's Motion to Approve

Settlement with worldwide Rental Services a/k/a
Worldwide Machinery
6/11/2009 2.00 800.00 Conference with client and J. Ryan
6/11/2009 1.00 400.00 Conference call with F. Terzo and B. Elam
6/12/2009 0.50 200.00 Exchange e-mails with M. Dunn, B. Elam regarding 450
Alton Road, Miami Beach address not being "good" and
setting conference call (x4); e-mail to Patrick Scott and
Leyza Blanco regarding securing hard assets in existence in
Colorado and Arizona mines (x1); e-mailing with Leyza
Blanco regarding her tasks in case, i.e., securing assets here
in FL and in Colorado and Arizona (x4) (.5)
6/12/2009 3.00 1,200.00 Conference with Bob Schatzman and Financial Advisors
Berger, Mukamal and Khandahar
6/13/2009 0.10 40.00 E-mail to R. Schatzman, M. Dunn and B. Elam regarding

setting an in-person meeting
6/14/2009 0.10 40.00 E-mail to B. Elam regarding locating documents, people,

and assets
6/15/2009 2.00 800.00 Exchanging numerous e-mails in an attempt to set

conference call with B. Elam, B. Mukamal, Robert
Schatzman, M. Dunn, S. Khanorkar, S. Solomon
6/16/2009 1.70 680.00 Receiving and reviewing multiple emails from Schatzman,
Elam, Zucker, regarding foreign assets and Zucker (.7);
multiple emails with B. Elam regarding other creditors and
resigning (1.0)
6/16/2009 2.30 920.00 email with B. Elam regarding out of country assets,
Zucker, and website for scam (.4); and conference call
with all parties (1.9)
6/21/2009 0.30 120.00 Exchanging e-mails with B. Elam, R. Schatzman and S.

Solomon regarding filing involuntary and consolidating
"other" entity in bankruptcy in Colorado
6/22/2009 0.10 40.00 Receipt and review of memo from R. Schatzman

summarizing June 16 conference call and June 19
meeting

6/23/2009 1.90 760.00 Exchanging multiple e-mails with B. Elam and R.
Schatzman regarding Garfinkle and Nigel Smith (.9);
exchanging e-mails with B. Elam and R. Schatzman
regarding Harry Gurwitch (1.0)
6/24/2009 0.10 40.00 Receipt and review of e-mail from B. Elam to Nigel
Smtih
6/24/2009 0.20 80.00 Receiving and reviewing emails from B. Elam and
Schatzman regarding documents to review from Nigel
6/25/2009 0.10 40.00 Receiving and reviewing email from B. Elam regarding
Garfinkle memo
6/25/2009 0.90 360.00 Exchanging multiple e-mails with Steve and B. Elam
regarding memo to be completed by Garfinkle
6/26/2009 5.40 2,160.00 Meeting with Trustee, lawyers and accountants (4.1);
receipt and review of Trustee's Ex Parte Application for
Employment of Special Investigative Counsel Nunc Pro
Tunc to June 6, 2009 (B. Elam) (.4); exchange emails with
S. Solomon and L. Negron rega rding filing motion for
extension of 45 days to draft schedules (.3); emails with M.
Dunn regarding motion for extension of time (.3); emails
with F. Terzo and B. Elam regarding potential lawsuits
against petitioning creditors (.3)
6/26/2009 0.40 160.00 E-mails to Rosy Lopez regarding Merendon press coverage
(.2); and to L. Negron regarding Motion for Extension to
file schedules (.2)
6/27/2009 0.30 120.00 E-mails from S. Solomon regarding Garfinkle's e-mail

about the roles of the parties
6/29/2009 1.30 520.00 Exchanging e-mails with B. Elam regarding identification

of Nigel (.5); receipt and review of e-notification of Notice
of Hearing on Ex Parte Application to Employ B. Elam as
Special Investigative Counsel (.5); exchanging e-mails with
Leyza Blanco re garding memo (x3) (.3)
6/29/2009 4.50 1,800.00 Review memos and notes (3.5); draft memo and send via
email to Merendon Team outlining status and what needs
to be done (1.0)
6/29/2009 4.50 1,800.00 Review memos by R. Schatzman and Garfinkle (1.1),

review other documents (1.2), draft strategy memo
outlining various tasks to be performed ( 1.1) and assigning
responsibilities and email re: same (.9)
6/30/2009 1.20 480.00 Exchanging e-mails with B. Elam, R. Schatzman, M.

Dunn, S. Solomon, et al., regarding J.Bennett setting
conference call for July 20; and Motion to Extend to
August 14 (x10) (1.0); e-mails to and from F. Terzo
regarding Terzo's conversation with Judge Cristol's
calendar clerk regarding all special counsel (x2) (.2)
6/30/2009 0.80 320.00 Receiving and reviewing emails between M. Dunn and A.
Brodsky regarding setting conference call with creditors
(.3); e-notice of Motion to Extend Time to File Schedules,
Statement of Financial Affairs, and other documents (.2),
and with M. Dunn regar ding J. Ryan's employment (.3)
7/1/2009 1.20 480.00 Receiving and reviewing multiple emails to/from/with A.

Brodsky, B. Elam regarding conference call for 7/20 (.8);
Review email from Tom Suozzo (.1); telephone conference
with R. Schatzman regarding Nevada accounts (.3)

7/1/2009 0.20 80.00 Receipt and review of Order Granting Motion to Extend
Time to File Schedules/Plan (.1); transmit to team (.1)
7/2/2009 0.10 40.00 Receiving and reviewing email from Jenny Reyes
transmitting Order granting extension of time
7/7/2009 3.20 1,280.00 Receiving and reviewing multiple emails to/from/with B.

Elam and R. Schatzman regarding investor funding status
(.4); review email from S. Khanorkar regarding status and
tasks (.1); review amended hearing notice on employment
of B. Elam (.2); teleph one conference with B. Elam and
creditors (2.5)
7/10/2009 1.20 480.00 Receiving and reviewing multiple emails to/from/with B.

Elam and R. Schatzman regarding creditor updating and
case management (.3); recieve and review email from S.
Khanorkar, R. Schatzman, et al., regarding setting meeting
(.3); telephone conference with R. Schatzman, S.
Solomon, and A. Brodsky regarding hearing on hiring B.
Elam (.5); and with M. Dunn regarding conference call
with creditors (.1)
7/14/2009 0.20 80.00 Receiving and reviewing emails with A. Brodsky regarding
meeting in Miami office with B. Mukamal, S. Khanorkar,
and Schatzman on 7/16
7/15/2009 0.70 280.00 Exchanging e-mails with B. Elam regarding upcoming

hearing on his employment application
7/16/2009 0.10 40.00 E-mail from L. Negron transmitting Order employing B.

Elam
7/17/2009 0.50 200.00 Attend hearing telephonically on disclosure statement
7/17/2009 0.10 40.00 Review Notice of Rule 2004 Exam of US Bank
7/17/2009 0.50 200.00 Telephone conference with J. Ryan re: conversation with
Les Taylor
7/21/2009 0.40 160.00 Telephone call to Maureen Bondor regarding creditor

conference call held 7/20/09
7/24/2009 0.90 360.00 E-mails with M. Dunn and Maria Fernandez regarding wire
transfers (.7); and with R. Schatzman regarding US Bank
(.2)
7/27/2009 0.70 280.00 E-mails with A. Brodsky, Sharmils Khanorkar regarding

US Bank Duces Tecum amendment
7/29/2009 0.30 120.00 Receipt and review of emails between S. Khanorkar and B.
Elam
7/30/2009 0.20 80.00 Receipt and review of Trustee's Interim Report for June
(.1); email from Schaztman transmitting Abbott report
(.1)
8/3/2009 0.70 280.00 Receipt and review of Individual Estate Property Record
and Report Asset Cases (.3); emails with M. Dunn, S.
Khanorkar, B. Elam regarding status of preparation of
petition and schedules (.3); email with A. Brodsky
regarding U.S. Bank production (.1)
8/7/2009 1.10 440.00 Exchanging e-mails with M. Dunn, et al. regarding

schedules, Garfinkle and motion for further extension
8/10/2009 0.60 240.00 Exchanging e-mails with L. Negron, R. Schatzman, Nate

Mancuso regarding motion seeking further extension

8/11/2009 0.90 360.00 Exchanging e-mails with S. Khanorkar and A. Brodsky
regarding receipt of documents and CDs from U.S. Bank
(.2); filed Second Ex Parte Motion to Extend Time to File
Schedules, SOFA, and other documents (.4); receipt and
review of Order granting same, serve, circulate and
calendar new deadline (.3)
8/12/2009 0.10 40.00 E-mail from A. Brodsky to M. Dunn and me with new
deadline for filing schedules, etc.: 9/14/09
9/1/2009 2.00 900.00 Receipt and review of Notice of Default on Promissory

Notes, May 2, 2008 (.2); multiple emails with R.
Schatzman, M. Dunn, S. Khanorkar, B. Mukamal, Morris,
J. Ryan regarding US Bank accounts (.8); emails and
telephone conference with M. Dunn regardi ng meeting in
Miami regarding schedules (1.0)
9/4/2009 0.10 45.00 Transmit to all IFFL flow chart
9/8/2009 1.10 495.00 Exchanging e-mails with B. Mukamal regarding contacts

for pending investigations (.2); emails with A. Brodsky
regarding letter to Scoggins at SEC in Denver for access
(.3); review of email regarding retention of Interfor
company (.1); receipt and rev iew of email transmission of
several documents regarding IFFL notice of hearing,
Strategic Metals notice of hearing, Capital Alternatives,
Brost, ASC decision, review ASC sanctioning decision
(.3); review emails between S. Khanorkar and Brad Regier
( .2)
9/9/2009 6.50 2,925.00 Telephone with Vicky Rhineheart (investor/ creditor) (.3);
email to and from M. Dunn re: same and email to and
from Bob Hicock re: same (.4); telephone with Paul
Garfinkle (.5); tele with M. Dunn (.3); reviewing and
revising schedules and statement of financial affairs (1.0);
multiple calls and emails with government investigators in
US and Canada and emails and calls with Bill Pearson re:
same (2.0) emails to and from multiple times with
investors re: stay violations by investor recovery g roup
(2.0)
9/9/2009 4.10 1,845.00 Exchanging e-mails with M. Dunn and Robert Hickok
regarding Reinhart (.3); emails with R. Schatzman
regarding documents from Alberta Securities Commission
(.2); with George Reinhart regarding recovery pool (.7);
with L. Negron and S. Khanorkar regar ding schedules (.9);
with William Pearson regarding case and investigations
(.6); with R. Schatzman regarding receiver (.7); with
William Pearson and L. Negron regarding complaint from
state of Washington (.7)
9/10/2009 5.30 2,385.00 Exchanging e-mails with M. Dunn, B. Mukamal, S.

Khanorkar, R. Schatzman and L. Negron regarding
schedules (.5); meeting with all regarding various cases and
investigations (2.5); with Matt Galioto, Bill Pearson
regarding conference call (2.3)
9/10/2009 0.10 45.00 E-mail to L. Negron regarding Glory Hole
9/11/2009 1.10 495.00 Receipt and review schedules and SOFAs (.8); along with
emails to and from L. Negron and S. Khanorkar and M.
Dunn re: same (.3)

9/14/2009 1.90 855.00 Exchanging e-mails with all parties regarding Garfinkle,
case, investors, etc.; with Matt Galioto regarding Milo
Brost's arrest (1.4); transmit schedules and statement of
financial affairs to M. Dunn, George Rienhart, B. Elam, J.
Ryan, S. Khanorkar, et al. (.5)
9/15/2009 0.20 90.00 E-mails with Robert Hickok regarding Brost being in
custody of RCMP and warrant for Sorenson
9/17/2009 0.70 315.00 Exchanging e-mails with S. Khanorkar regarding B.

Mukamal's affidavit to Mr. Quilling (.5); review email from
Garfinkle regarding revision (.2)
9/18/2009 0.20 90.00 Teleconference with L. Negron regarding 341 meeting

etc.
9/24/2009 0.60 270.00 E-mailing with B. Elam regarding case status (.3); emails
with William Pearson re: same (.3)
9/25/2009 0.30 135.00 E-mailing with B. Elam regarding case status
10/26/2009 0.10 45.00 E-mail from B. Elam regarding Discovery Day mine
10/27/2009 0.60 270.00 Exchanging e-mails with Paul Garfinkle regarding

Strategic Metals
11/18/2009 0.80 360.00 E-mail from B. Elam regarding status (.1); emails with A.
Brodsky regarding Garfinkle call (.3); multiple emails with
M. Dunn, B. Elam, et al. regarding status meeting (.4)
12/13/2009 0.20 90.00 E-mail from Paul regarding Canada hearing/receiver over
Sorenson's properties (.1); and from A. Brodsky regarding
exhibits to Motion (.1)
12/20/2009 0.20 90.00 Exchanging e-mails with Paul regarding trustee appointed
in Canada and hearing on 1/12/10, Proofs of Claim, send
him hearing information
12/21/2009 0.20 90.00 Emails with Paul Garfinkle
12/24/2009 0.20 90.00 Receipt of efiled motions in adversary and main cases
1/4/2010 0.50 225.00 Email from S. Khanorkar transmitting SGD promissory

note (.1), receipt and review of hearing regarding Arbour
Energy in Alberta sent by Nicole Chute, Alberta Securities
Commission (.3), and calendar same (.1)
1/6/2010 0.40 180.00 Receipt and review of order on limited notice and
telephone with L. Negron re: setting up a website to
comply with same
1/8/2010 5.00 2,250.00 Hearing preparation
1/9/2010 4.00 1,800.00 Hearing preparation
1/10/2010 6.30 2,835.00 Hearing preparation (6.0); emails (x2) from Paul
transmitting new article regarding Brost - Google search
(.2); one email from S. Khanorkar with cash flow charts for
hearing (.1)
1/11/2010 0.20 90.00 Exchanging e-mails with Ken Iredale regarding Martin
Werner and geologist
1/11/2010 8.00 3,600.00 Preparation for hearing, research and drafting orders for
hearings
1/12/2010 0.30 135.00 Telephone call from Martin Werner re: case (.1); emails
from Ken Iredale (.2)

1/12/2010 1.20 540.00 Exchanging e-mails with Michelle Khouri, L. Negron, A.
Brodsky, Cheryl Bennett, Maylyn Vargas, B. Elam, M.
Dunn regarding press release, website, creditors (.6);
receipt and review of Martin Werner's Motion to Dismiss
and MOL in Support (.6)
1/12/2010 8.00 3,600.00 Preparing for hearing on Motion for Substantive

Consolidation of Non-Debtor Entities, Turnover of
Property of the Estate, and Injunctive Relief (4.0); attend
hearing (3.0); post-hearing meeting with Martin Werner
and S. Khanorkar (1.0)
1/13/2010 1.80 810.00 Exchanging e-mails with Kyle Roat, Paul Brinkman of Biz
Journals, with many creditors regarding motion and
answering many of their questions
1/14/2010 0.10 45.00 Telephone call from Martin Werner
1/15/2010 2.40 1,080.00 Exchanging e-mails with Cliff Hark, L. Negron, Cheryl
Bennett, B. Elam regarding gold mines, The Agency, Kelly
Crowley (investor) regarding Investment Recovery Pool
(1.0); receipt and review of NOH on Werner's motion to
dismiss (.2); receipt and revi ew of letter to Judge Cristol
from Hark regarding objections to order (.2); many creditor
calls regarding case (1.0)
1/19/2010 0.40 180.00 Exchanging e-mails with Michelle Khouri regarding final
order entered to have on file and for website (.2); receipt
and review of Notice of Appearance of Creditor Ian Zelo
(.2)
1/24/2010 4.00 1,800.00 Preparing for continued hearing on 1/25/10
1/25/2010 4.10 1,845.00 Preparing for and attendance at continued hearing on

Motion for Substantive Consolidation of Non-Debtor
Entities...
1/26/2010 0.40 180.00 Telephone conference with Michelle Khouri regarding

order for posting to website
2/1/2010 3.70 1,665.00 Exchanging e-mails with Werner regarding outstanding

matters (.3); emails with Cliff Hark and A. Brodsky
regarding deposition of Paul Garfinkle (.3); email from M.
Dunn regarding website link (.1);email transmitting
proposed agreed order on Werner mo tion to dismiss and
emails back and forth with Werner regarding the same (.3);
Follow-up with court and cancel hearing on motion to
dismiss (.4); review A. Brodsky's emails to creditors (1.3);
emails with creditor Paul Morgan regarding his motion to
allow late filed claim (.5); draft and upload agreed
order(.5)
2/2/2010 4.00 1,800.00 Exchanging e-mails with team regarding call with
Canadian receiver, Michael Quilling, and his counsel (.3);
emails with Cheryl Bennett and L. Negron regarding
website issues (.3); emails with A. Brodsky regarding late
filed claims order(.2); receipt and review of and transmit
agreed order on Werner's motion to dismiss to Werner and
M. Dunn (1.6); receipt and review of entered agreed order
allowing late filed claim and transmit same to Paul
Morgan(1.2); multiple emails with creditor Karen Fujita
regarding claim and case(.2); email from Werner
forwarding email from Court of Queens Bench, Alberta,
regarding SGD adv. Nostratieh, et al. (.2)

2/3/2010 0.60 270.00 Telephone conference with B. Elam, S. Khanorkar and M.
Dunn re: case administration
2/3/2010 0.90 405.00 Exchanging e-mails with M. Lessne regarding foreign

jurisdictions and translation of documents (.4); telephone
conference with Paul Garfinkle regarding escrow deposit
and email from Les Taylor (.4); email from S. Khanorkar
regarding geologist reports (.1)
2/4/2010 2.10 945.00 Exchanging e-mails with Cliff Hark and A. Brodsky
regarding depositions of Garfinkle and B. Mukamal (.8);
email from S. Richard (.1); email from Ward Capstick
transmitting Alberta Corp. Registry search (.1); receipt and
review of several documents fr om Garfinkle and Capstick
(.8); emails with creditor Terra Finial (.3)
2/4/2010 0.50 225.00 Receipt and review of several emails from Paul Garfinkle
transmitting documents
2/5/2010 2.80 1,260.00 Exchanging e-mails with B. Elam, M. Dunn regarding

translation costs and Janie Munoz, translator (.5); email
from Garfinkle regarding the volume of documents for his
deposition (.2); receipt and review of deposition notices for
B. Mukamal and Paul's depositions from Cliff Hark, as
well as Hark's notice of appearance for Thelma Sorensen,
and notice of limited appearance from Gary Sorensen and
Merendon Mining, SA (1.4); teleconference with S.
Khanorkar regarding contacting Werner (.7)
2/9/2010 1.80 810.00 Receipt and review of Garfinkle deposition transcript (.3);
emails with Peter Walton regarding jurisdiction over
Nordic (.3); email to M. Lessne regarding order
incorporating provisions of SEC (.1); telephone conference
with B. Elam and S. Khanorkar regarding Capstick and
Exotic Wood World (.3); email to L. Negron regarding
suggestions of bankruptcy (.1); telephone conference with
A. Brodsky regarding Garfinkle's declaration with exhibit
(.4); email from Art Neiwirth regarding Adair(.3)
2/10/2010 3.10 1,395.00 Exchanging e-mails with B. Elam and M. Dunn regarding
employing translator (.4); receipt and review of motion to
dismiss for lack of prosecution, and notices of appeal in
main and adversary case filed by Hark on behalf of
Sorensen (2.2); forward same to M. Lessne to begin
drafting response (.1); forward to team (.1); emails with A.
Brodsky regarding Liz Krupa's email for 2/11 hearing
(.3)
2/10/2010 0.30 135.00 Emails with creditor Kelly Miller
2/11/2010 1.90 855.00 Exchanging e-mails with B. Elam regarding affidavit of

translator (.2); receive and review notice of hearing on
motion to serve certain foreign defendants by certified or
registered mail (.3); forward to all and serve (.8); emails to
Garfinkle and B. Elam regarding all US and Canada cases
so we can file suggestions of bankruptcy in those
jurisdictions (.4); email to Cliff Hark transmitting orders
continuing hearing in both cases for his review and
comments (.1); email to J. Armengol re: same (.1 )

2/12/2010 1.50 675.00 Exchanging e-mails with David Baddley, SEC, regarding
setting conference call with him, Susan Sherrill-Beard and
Elizabeth Krupa (.4); emails with A. Brodsky regarding
filing suggestions of bankruptcy and recordation of orders
in all jurisdictions wh ere mines are located (.4); serve
Werner and Neiwirth the order continuing hearing to 2/19
on tro in both cases (.4); review email from B. Elam
regarding translator's affidavit and M. Dunn's response to
same (.1); transmit to Cheryl Kaplan, Judge Cri stol's law
clerk, two orders (.2)
2/14/2010 0.10 45.00 Receipt and review of B. Elam's email to Marci forwarding
motion to appoint translator and his email regarding
pending lawsuits Garfinkle informed us of
2/15/2010 0.30 135.00 Exchanging e-mails with Garfinkle regarding plan of action
collection letters
2/16/2010 1.90 855.00 Exchanging e-mails with Peter Walton and Garfinkle (.3);
receive and review notice of electronic filing of orders
continuing hearing to 2/19 (.3); email to M. Dunn
regarding B. Elam's motion to appoint translator (.1);
receipt and review of motion to dismiss adversary
proceeding against south American Merendon entities (.4);
discuss response with M. Lessne (.4); receipt of Hark's
notice of appearance, receipt of deposition notices from
Hark for Garfinkle and B. Mukamal (.3); email from A.
Brodsk y regarding call from Milt Shlapak (.1)
2/18/2010 0.50 225.00 Telephone conference with Art Neiwirth, Adairs lawyer
and email to him re: same
2/18/2010 8.00 3,600.00 Prep for hearing
2/18/2010 3.20 1,440.00 Exchanging e-mails with B. Elam regarding motion to

appoint translator (.3); review Lessne's email to S.
Khanorkar regarding charts showing money flow (.1);
respond to and discuss same (1.2); emails with Art
Neiwirth regarding Adair's cooperation and what is needed
of him (.3); emails with Ken Iredale regarding case (.2);
email to J. Armengol and Heidi Feinman regarding
attending hearing on 2/19 (.1); review Heidi's response
(.5); many emails with B. Elam, S. Khanorkar, Werner, B.
Mukamal all re garding attendance at hearing (.5)
2/19/2010 7.00 3,150.00 Preparation for hearing, negotiations with Sorenson and
counsel, attend hearing on extension of injunction and
service issues and draft orders re: same
2/19/2010 1.90 855.00 Exchanging e-mails with B. Elam regarding his attendance
at hearing and court ruling making translator unnecessary
(.3); call from Chris Redmond in Kansas City (.5); receipt
and review of correspondence from Chris Redmond (.7);
emails with A. Brodsky and Lessne regarding uploading
order on summary judgment hearing on 3/11 (.4)
2/21/2010 0.20 90.00 E-mails from James King transmitting many documents in
Spanish regarding Merendon de Peru
2/22/2010 0.30 135.00 Telephone conference with Dave Badley of SEC
2/23/2010 0.70 315.00 Exchanging e-mails with Peter Walton (.2); forward
proposed order on service to Hark, Werner, Neiwirth and
copy team, including SEC people (.3); emails with A.
Brodsky regarding Sentinel Mining information (.2)

2/23/2010 0.50 225.00 Telephone conference with Dave Baddley, SEC in
Atlanta
2/24/2010 1.80 810.00 Exchanging e-mails with A. Brodsky regarding service of

process on Nordic (.3); emails from Werner regarding
proposed service order and information on Merendon de
Peru (.3); emails back and forth with A. Brodsky and
Lessne regarding changes to propos ed service order (.5);
emails from Neiwirth regarding same and ongoing
discussion regarding service on his client (.1); emails with
office of John Henerson regarding his firm's claim and with
A. Brodsky regarding same (.3); email regarding proposed
a greed order amending injunction order (.3)
2/25/2010 0.30 135.00 Telephone conference with client re: chapter 15
2/25/2010 2.20 990.00 Exchanging e-mails with A. Brodsky regarding filing

suggestions in Siskiyou County, CA - jurisdiction of
Discovery Day Mine (.4); file Summons Service Executed
on Nordic (.4); many back and forth with all parties
regarding proposed agreed order amend ing injunction
order, including Neiwirth and Sherrill-Beard of SEC (.6);
review emails between A. Brodsky and John Henderson
regarding his firm's proof of claim and service list; call to
M. Dunn re: same (.5); email to Hark and Yon transmitting
redli ned service order and agreed order for same (.3)
2/26/2010 1.20 540.00 Exchanging e-mails with A. Brodsky, Neiwirth, L. Hughes,

Dave Baddley, Matt Yon - all regarding orders (1.2)
3/1/2010 0.70 315.00 Receipt and review of agreed order amending 1/27 order
granting motion for substantive consolidation of non-
debtor entities in the main and the adversary cases (.3);
email to A. Brodsky regarding service (.1); emails with
Mike Letsen, Esq. regarding filing claim as a foreign corp.
(.3)
3/8/2010 1.20 540.00 Exchanging e-mails with Nicole Hilburn of Gus Pappas'
office, and with Gus regarding proposed order on summary
judgment motion (.6); emails with Art Neiwirth regarding
language in para. 57 of order on summary judgment
regarding Larry Adair's role (.6 )
3/9/2010 1.10 495.00 Exchanging e-mails with Art Neiwirth and his paralegal
regarding order language and his appearance at summary
judgment hearing (.2); emails with Pappas re: same (.3);
email to D. Cimo, local counsel re: Shlapak (.1); receipt
and review of fax letter from Art Neiwirth regarding
hearing on 3/11 (.3); emails with A. Brodsky regarding
order on motion to retain translator (.2)
3/10/2010 2.60 1,170.00 Exchanging e-mails with Pappas, Hark, Yon, Garfinkle
regarding order on summary judgment motion - to be
reviewed and to Neiwirth, Werner and team as well (.6);
emails from Garfinkle and from Neiwirth regarding Adair
with comments (.6); call from Garf inkle and from
J.Bennett in CO (.6); send revised proposed order to
everyone again (.2); emails with Nicole Hilburn regarding
revisions to order (.3); emails with Werner regarding sale
option for MDP (.3)
3/11/2010 0.60 270.00 Exchanging e-mails with Nicole Hilburn regarding

revisions to proposed order (.3); and emails with Werner
regarding sales (.3)

3/11/2010 5.00 2,250.00 Teleconference with Caldwell's attorneys (1.5); preparation
for and attendance at summary judgment hearing (3.5)
3/12/2010 0.50 225.00 Exchanging e-mails with David Cimo (.2); receipt and
review of order granting motion for partial summary
judgment (.1); serve on everyone, including those in all
jurisdiction where suggestions were filed (.1); email to
creditor Alan Schlosser (.1)
3/13/2010 0.10 45.00 E-mail from Michael Mysak regarding notice of motion
and hearing set for 3/18 in Canada before Judge Hawco
3/14/2010 0.20 90.00 E-mails from Garfinkle re: case
3/17/2010 5.80 2,610.00 Exchanging e-mails with Mike Mysak, Trish, M. Lessne
regarding hearing, order, letter to Judge Hawco, etc. all in
preparation for hearing in Canada in Nosratieh v. Strategic
(.5); send draft letter to Judge Hawco to Chris Redmond
and Greg Grossman fo r review (.2); file motion to extend
automatic stay, motion to enforce, motion for clarification
against automatic stay, motion for contempt, etc. (2.4);
serve emergency motion on everyone involved: Bennett
Jones, Gowlings, Quilling (2.3); emails wit h Christ
Redmond, B. Elam, Trish regarding emergency motion and
letter(.2); telephone conference with M. Dunn regarding
same and trying to get motion heard (.2)
3/17/2010 6.00 2,700.00 Draft memorandum to Canadian court in response to

receivers motion and draft motion to bankruptcy court re:
same
3/18/2010 5.30 2,385.00 Email to Frank Dearlove with case information for his
order (.1); receipt and review of notice of hearing on
emergency motion (.3); Teleconference with A. Brodsky
regarding drafting a notice of hearing of our own (as
opposed to the court's hearing no tice) (.3), file it, serve it,
file cert/service on both hearing notices (1.1); call from
Garfinkle; emails with Tanya Frizzell at Gowling regarding
their representation of Sorensen and some other Merendon
entities (.4); emails with A. Brodsky regard ing service of
motion and hearing notice on Hark (.3); receipt of notice of
telephonic hearing on motion to extend automatic stay, etc.
(.2); serve on all with motion (.3); receipt and review of
order granting motion to continue pretrial conference,
serve, forward to team, re-calendar (.7); email with Elam
regarding phone attendance (.1); emails with Chris
Redmond regarding hearing (.2); forward draft of proposed
order on emergency motion to Quilling, Dearlove (.1);
back and forth with Redmond re: same (.5); emails with A.
Brodsky regarding Hawco's assistant, Gerald (.2); re-send
draft order to all again after revisions (.2); emails with
Dearlove re: same (.3)
3/18/2010 3.00 1,350.00 Telephonic hearing on stay issues as relates to Canadian

proceeding before bankruptcy court (.5) draft order re:
same and order re: Canadian proceeding (1.0) conference
with Canadian receivers counsel (1.0); hearing before
Canadian court re: same (.5)
3/18/2010 0.10 45.00 E-mail from Frank Dearlove giving go-ahead to file U.S.
Order re: motions to extend automatic stay, enforce,
clarification of automatic stay, contempt, damages for
creditor misconduct, etc. in Nosratieh v. Strategic case in
Canada

3/19/2010 0.50 225.00 Exchanging numerous e-mails with Frank Dearlove
regarding protocol used in Trident and order from hearing
of March 18, 2010 on our motions to extend automatic
stay, enforce, clarification of automatic stay, contempt,
damages for creditor misconduct, etc. in Nosratieh v.
Strategic case in Canada
3/19/2010 2.20 990.00 Email to Garfinkle and from Ward Capstick (.2); receipt
and review of order on emergency motion signed by court,
serve and forward to team (1.1); discuss with A. Brodsky
(.3); receipt and review of correspondence from Gus
Pappas regarding obtaining p roperty and respond (.3);
forward letter from Gus to team and Garfinkle (.2); forward
B. Mukamal's affidavit to Pappas and Nicole Hilburn (.1)
3/20/2010 0.10 45.00 E-mail from S. Khanorkar regarding expectation of

reports/deliverables in April in adversary proceeding
3/24/2010 0.20 90.00 E-mail to Werner regarding John Dupont, of Gloria

Management's filing of a proof of claim in all of SGD's
assets; email from creditor Aaron Taylor regarding claim
3/25/2010 0.90 405.00 Emails from M. Dunn regarding emails from Aaron
Schmiedel about royalty interests (.3); emails from M.
Lessne regarding disclosures (.3); exchange emails with
creditor Aaron Taylor regarding claim (.3)
3/26/2010 0.20 90.00 Email from M. Lessne regarding disclosures (.1); email
from A. Brodsky regarding new case to file suggestion in
(.1)
4/8/2010 0.20 90.00 Receipt and review of emailed documents: transfers and
corporate resolutions regarding Merendon de Peru, S.A.
(not translated)
4/9/2010 0.90 405.00 Receipt and review of emails between A. Brodsky and US
Bank regarding the bank's compliance with order on
summary judgment (.2); emails with Garfinkle regarding
recovery agency (.2); call and email from Richard Brodsky,
coming into the adversary proc eeding on behalf of Nordic
(.1); receipt of notice of appearance of Richard Brodsky
(.2); receipt of motion to allow late filed claim from
Douglas Kirkwood; draft and upload agreed order on same
(.2)
4/13/2010 0.90 405.00 Receipt of filed agreed ex parte motion to extend time for
pretrial conference and related deadlines filed by
A.Brodsky (.1); emails from Graham regarding Structurists
(.3); email to A. Brodsky to forward orders to Paul Butler
(sub con and summary ju dgment) (.1); review order
granting Brodsky's motion to extend pretrial (.2); emails
with Werner regarding option on properties (.2)
4/21/2010 1.00 450.00 Conference call with Canadian receiver and his counsel
4/27/2010 1.70 765.00 Exchanging e-mails with A. Brodsky regarding call from
Paul Garfinkle (.4); receipt and review of motion to allow
late filed claim from Andrew Forster (.4); draft and upload
agreed order granting same (.5); emails with A. Brodsky
and M. Lessne and Ne iwirth regarding his filing of a
notification of return of service (.2); emails with Neiwirth
regarding same (.2)
5/13/2010 0.30 135.00 Emails with Richard Brodsky regarding his compensation
memo and requiring trustee's approval

5/17/2010 0.70 315.00 E-mail from a Norman Wong regarding Sorensen owning
Florida property (.1); email from Richard Brodsky
forwarding draft joint motion allowing Nordic to retain
counsel (.1); emails back and forth with S. Stirling and M.
Lessne regarding service (.5)
5/18/2010 0.80 360.00 E-mail from Ward Capstick forwarding Google news
articles on Brost and Sorensen (.1); emails with Garfinkle
regarding the same and also regarding buyers (.2); response
to Brodsky's motion and forward same to M. Dunn (.3);
several emails with M. Dunn regarding articles and setting
a status meeting (.2)
5/20/2010 0.50 225.00 Exchanging e-mails with A. Brodsky and team to set a
status meeting
5/25/2010 0.50 225.00 (.10Receipt and review of entered order continuing pretrial
conference to July 19th; forward it and filed motion to
team (.1); serve both on all (.2); emails with Hark and
Garfinkle (.1)
5/26/2010 0.30 135.00 Exchanging e-mails with Werner regarding Ecuador (.2);
email to Garfinkle (.1)
6/1/2010 0.90 405.00 Telephone call from Paul Garfinkle re: case (.3);
exchanging emails with B. Elam regarding J.Bennett (.2);
review other emails regarding same (.2); emails with Ken
Iredale (.2)
6/2/2010 1.90 855.00 Exchanging e-mails with M. Dunn, B. Elam, A. Brodsky

regarding Discovery Day and J.Bennett
6/2/2010 1.00 450.00 Telephone with Paul re: case (.3); telephone with Paul and
M. Dunn and B. Elam re: same (.2); follow-up telephone
with M. Dunn, telephone with M. Dunn and B. Elam (.2);
telephone with B. Elam M. Dunn and J. Armengol @ US
Trustee's office (.3)
6/3/2010 0.30 135.00 Receipt and review of a pleading in the Christinansen v.

Chevy Chase Bank case in AZ from M. Dunn's office
6/3/2010 0.20 90.00 E-mails with Mike Letsen, Esq. regarding case (he
represents a group of investors)
6/5/2010 0.20 90.00 E-mails with M. Dunn regarding possible brokers she
found for mines
6/7/2010 0.40 180.00 E-mail from M. Dunn regarding obtaining DD police

report from Garfinkle and drafting stay violation motion
(.2); emails with Susant regarding motion to compel to
Hark and Brodsky's request for a few extra days to respond
to interrogatories (.2)
6/8/2010 1.40 630.00 Exchanging numerous e-mails with team regarding June
9th meeting on Discovery Day and case status (1.4)
6/9/2010 1.50 675.00 Conference with client and B. Elam, S. Khanorkar and B.
Mukamal re: case administration
6/10/2010 0.40 180.00 Exchanging e-mails with S. Stirling regarding motion to

compel to Hark and getting started on interim fee
application
6/11/2010 4.40 1,980.00 Draft status memo (3.9); telephone with L. Hughes SEC
attorney (.5)

6/11/2010 0.60 270.00 Telephone calls received on cell from Mike Orenstein and
L. Hughes of the SEC, Denver
6/29/2010 0.50 225.00 Telephone conference with L. Hughes of SEC re: their
action and coordinating actions
7/1/2010 4.50 2,025.00 Telephone conference with opposing counsel: Hark and
Sakalo (.6), and with M. Dunn, J. Armengol and Garfinkle
each regarding motions and hearings for today (.9); draft
and revise agreed orders (.3); email exchange with counsel
regarding same (.2); tr avel to and attendance at hearing
(2.5)
7/6/2010 0.70 315.00 Receiving and reviewing NEF of Notice of Appearance of

Sakalo for Fagen, Gruden, American Sierra Gold and
Trinity Alps Resources (.2); receipt and review of notice of
compliance from Cliff Hark (.2); email from Gus Pappas
(.1); emails with Garfinkle regarding Google Alerts he sent
regarding Milo Brost criminal matters (.2)
7/21/2010 0.70 315.00 Telephone conference with Laura Hughes of SEC
8/10/2010 2.00 900.00 Preparing for, travel to, attend, return from hearing on
Nordic's motion regarding expense for attorney
8/30/2010 0.10 45.00 Draft suggestion of bankruptcy in colorado
9/2/2010 0.50 225.00 Attending status conference in colorado litigation on glory

hole
9/7/2010 3.00 1,350.00 Telephone with SEC Counsel L. Hughes regarding SEC
injunctive action in Washington (.5), review complaint,
motion for injunction, draft answer and consent to
injunction and injunction (2.5)
9/22/2010 0.10 45.00 Receipt and review of Agreed Motion for Preliminary
Injunction v. Capstick in SEC case
9/23/2010 0.20 90.00 Receipt and review of Order Denying Motion for Default
as to Defendant Syndicated Gold Depository (.1); and
Agreed Motion for Preliminary Injunction v. Werner - both
in SEC case (.1)
10/21/2010 0.60 270.00 E-mails between Blaine Schwabe and John Malesovas
10/22/2010 0.30 135.00 E-mails to and from Suzanne Wilton
10/25/2010 0.10 45.00 Receiving and reviewing Order Granting Motion for Relief
from Stay by Southbank
11/29/2010 0.10 45.00 SEC v. Merendon- receipt and review of REply to

Response to Motion to Dismiss
11/29/2010 1.00 450.00 Telephone conference with SEC and counsel re all matters
plus injunction their claim and disgorgement issues
11/29/2010 0.20 90.00 Receipt and review of the motion calendar
11/30/2010 0.30 135.00 tele with Matt Medvey lawyer in calgary re claims bar
deadline
11/30/2010 1.00 450.00 Review and revise Joint report with SEC in SEC case
11/30/2010 0.40 180.00 SEC v. Merendon- Emails and from L. Hughes
12/1/2010 0.10 45.00 Receipt and Review of Notice of Reservation of Rights

12/1/2010 0.10 45.00 Receipt and Review of Joint Status Report
12/2/2010 0.20 90.00 E-mails to and from F. Santos
12/6/2010 0.10 45.00 Receipt and Review of Correspondence from Larry

Coupal
12/8/2010 0.10 45.00 Receipt and Review of Correspondence Letter Sent from
Andrea Madigan (Case # 09 CV 96) in regards to compact
disk containing documents
12/8/2010 0.10 45.00 Receipt and Review Plainitffs' response to Motion for
Adjudication Under C.R.C.P. 12 (b) Filed by the Estate of
Robert F. Barnes Case # 09 CV 96
12/22/2010 0.50 225.00 Phone conference with Mr. Elliot Rockler
12/30/2010 0.50 225.00 Status memo to client
1/3/2011 0.30 135.00 Conference call with S. Solomon re: case.
1/13/2011 0.40 180.00 E-mails between Dana Quick and M. Lessne
1/18/2011 0.30 135.00 E-mails between M. Dunn and M. Lessne
1/31/2011 0.50 225.00 Telephone Conference R. Schatzman and M. Lessne
3/10/2011 1.00 450.00 Call with L. Hughes of SEC
5/2/2011 0.30 135.00 Telephone conference with Cliff Hark
5/2/2011 2.00 900.00 Telephone conference with Cliff Hark re hearing on

withdrawal (.3), review various orders (.3), draft orders
(.4), emails from hark, and motions to withdraw (.3); attend
hearing on withdrawal (.7)
5/4/2011 0.50 225.00 Email to and from and review and revise proposed order on
Hark's withdrawal as counsel
5/31/2011 0.30 135.00 Receipt and review of Motion to Withdraw as Attorney by

Defendant Ward K. Capstick.
6/3/2011 0.20 90.00 Receipt and review of an email from M. Dunn requesting
status of the case.
6/3/2011 0.30 135.00 Receipt and review of an Amended Order on Motion to

Withdraw as Counsel of Record.
6/6/2011 0.20 90.00 Receipt and review of Notice of Unavailability from

06/13/2011 to 06/17/2011 by Attorney Martin L Hannan,
Esq.
Doyle regarding wiring information.
6/7/2011 0.20 90.00 Receipt and review of emails between A. Srour and
Alexandra Castro regarding wiring information.
6/9/2011 0.20 90.00 Emails with Adam Katz regarding Andrea Madigan's
December 3 email.
6/9/2011 0.20 90.00 Receipt and review of Notice to Withdraw of Notice of

Unavailability Filed by Creditor Clearwater Mining
Corporation.

6/9/2011 0.20 90.00 Receipt and review of emails between A. Srour and Cheryl
Bennett regarding unloading pleadings to Gray Robinson's
Merendon Mining website
6/9/2011 0.30 135.00 Receipt and review of an email from Alison MacGregor
regarding Merendon Mining Ponzi scheme from a reporter
at the Montreal Gazette newspaper and how it relates to
another Ponzi scheme targeting Canadians
6/10/2011 0.10 45.00 Receipt and review of an email from Paul Garfinkle re:
case
6/10/2011 0.20 90.00 Emails with Alison MacGregor regarding conference

call.
6/14/2011 0.20 90.00 Receipt and review of an email from Alison MacGregor
regarding the merendon ponzi scheme.
6/15/2011 0.30 135.00 Emails with Alison MacGregor regarding BRA

(Werner)
6/20/2011 0.20 90.00 Emails with Robert Osborne regarding interview with
Canadian Television Show, W5.
6/21/2011 0.20 90.00 Receipt and review of Notice of Change of Address for
Attorney John A. Moffa.
6/28/2011 0.20 90.00 Emails with Alison MacGregor
6/28/2011 0.20 90.00 Receipt and review of an email from M. Dunn re:
Merendon properties in Jamestown.
6/28/2011 0.20 90.00 Receipt and review of an email from M. Lessne to M.

Dunn re: Current Status of Case.
6/28/2011 0.60 270.00 Receipt and review of and revise status report for trustee
and email from Mike and M. Dunn re same
6/29/2011 0.60 270.00 Emails with Alison MacGregor as well as reviewing a

Supreme Court Order.
6/29/2011 0.30 135.00 Receipt and review of Minute Order by Richard A. Jones,
United States District Judge.
6/29/2011 0.20 90.00 Emails with Mike Letsen, Esq. with Parklane group of
investors re: case update.
7/5/2011 0.30 135.00 Receipt, review and reply to email form Alison MacGregor
regarding Belize court ruling.
7/5/2011 0.20 90.00 Receipt and review of and email from Alison MacGregor
regarding 2008 report submitted by Quilling to an Alberta
court found Merendon assets.
7/8/2011 0.40 180.00 Receipt and review of an email from Joseph Murphy
enclosing SEC’s Notice of Deposition for Brad Regier.
7/11/2011 0.20 90.00 E-mails with clients regarding availability for a conference
call.
7/11/2011 0.20 90.00 Receipt and review of emails re: status of case.
7/11/2011 0.30 135.00 Receipt and review of Notice of Taking Deposition of

Bradley Regier.
7/15/2011 0.20 90.00 Emails with client regarding David Murray.
7/19/2011 0.20 90.00 Receipt and review of an email from Arthur C. Neiwirth re:
hearing on 7/21/11.

7/19/2011 0.20 90.00 Receipt, review and reply to an emil from Jason Welt.
7/20/2011 0.20 90.00 Emails with Arthur C. Neiwirth, Esq. regarding hearing
and call-in information.
7/20/2011 0.30 135.00 Telephone conference with Barbara re telephonic

hearing
7/21/2011 7.00 3,150.00 Conversation with Art neiwirth re pretrial (.3),

conversation with court's calender clerk re administrative
matters regarding hearing (.3), preparation for (4.4), travel
to and from and attendance at multiple hearings today
(2.0)
7/22/2011 0.20 90.00 E-mail to clients regarding the hearing on 7/21/11
7/22/2011 0.20 90.00 E-mail to client regarding conference call with John
Moffa.
8/4/2011 0.20 90.00 Receipt and review of an email from Angela Fiorentino re:
hearing date.
8/4/2011 0.40 180.00 Receipt and review of an email from Ashley Ochoa
enclosing sanction against Leslie Taylor representing
Merendon Mining (Colorado).
8/8/2011 0.20 90.00 Reviewing and responding to e-mail from Barbara Cargill
with Judge A. Jay Cristol re: hearing dates.
attaching correspondence from Kristen Philbrook.
8/17/2011 0.30 135.00 Receipt and review of an email from Polly A. Atkinson
enclosing MM Nevada Consent.
8/18/2011 0.20 90.00 Receipt and review of an email from Paul Garfinkle re:
interview with Robert Osborne of CTV5
8/19/2011 0.50 225.00 Reviewing and responding to e-mails from Paul

Garfinkle.
Notice of Filing for review.
8/19/2011 0.20 90.00 Reviewing and responding to e-mail from Paul Garfinkle
re: logistics of Monday's TV taping from Canadian
Television.
8/24/2011 0.30 135.00 Reviewing and responding to e-mail from Alison

MacGregor re: Merendon de Ecuador.
8/24/2011 0.30 135.00 Receipt and review of Notice of Change of Address for B.
Elam.
8/28/2011 0.20 90.00 Receipt and review of an email from John Moffa to Martin
Hannan.
9/5/2011 0.30 135.00 E-mail from Paul Garfinkle regarding MMNI Bankruptcy
Proceeding with enclosed Orders.
9/6/2011 0.20 90.00 Emails with Marica Dunn re Paul Garfinkle's email on the
MMNI Bankruptcy Proceeding.
9/6/2011 0.20 90.00 Emails with Alison MacGregor regarding Merendon de

Ecuador.

9/7/2011 0.20 90.00 E-mails from Paul Garfinkle re Belize Decisions.
9/7/2011 0.50 225.00 Additional e-mails with Paul Garfinkle re Belize

Decisions.
9/8/2011 0.30 135.00 Telephone conference with Mary Dartis producer from
canadian television show
9/9/2011 0.30 135.00 E-mails with J. Cartagena and M. Lessne regarding the
Substantive Consolidation Order (main case)
9/12/2011 0.30 135.00 E-mail from A. Srour enclosing Notices of Unavailability

to review and approve for filing.
9/13/2011 0.20 90.00 E-mails with J. Cartagena and A. Srour regarding phone
conversation with Barbara Cargill at Judge Cristol's
chambers.
9/13/2011 0.20 90.00 Emails with Biff Marshall and Lisa Novak regarding write
offs.
9/15/2011 0.20 90.00 E-mails with M. Dunn regarding attendance at the hearing
on September 27, 2011.
9/19/2011 0.20 90.00 E-mails with Charles Gryba regarding contact.
9/19/2011 0.20 90.00 Emails with Jason Welt regarding the hearing on Sep. 27,
2011.
9/20/2011 0.50 225.00 Telephone conference with Brent Baker.
9/26/2011 0.10 45.00 Review of an email from J. Cartagena to Paul Garfinkle

confirming that the hearing is scheduled for September 26,
2011.
Doyle regarding appearing at hearing scheduled for
September 27, 2011 by phone.
9/26/2011 0.20 90.00 E-mails with S. Khanorkar regarding B. Mukamal's

attendance at the hearing scheduled for September 27,
2011.
9/27/2011 7.60 3,420.00 Telephone with J. Armengol (.3); preparation for hearings
(3.0); telephone with Worldwide's counsel meachem (.3);
travel to and attenance at hearing on 9019 and 363 sale
(4.0)
10/5/2011 0.20 90.00 E-mails with Jodi Rubin regarding report of W5.
10/6/2011 0.10 45.00 E-mail from Jason Welt regarding setting a conference
call.
10/14/2011 0.30 135.00 Telephone conference with Judge Cristo's JA regarding

hearing date.
10/17/2011 0.10 45.00 E-mail from M. Dunn re the filing of Paul Garfinkle's
Complaint
10/17/2011 0.10 45.00 E-mails with M. Dunn re the letter to Don Walton and
Steve Turner.
10/20/2011 0.20 90.00 E-mail from John Moffa to M. Dunn enclosing Trustee's
authorization for signature.

10/21/2011 0.30 135.00 E-mail to Steve Turner re Response to your letter
concerning Paul Garfinkle's complaint.
10/21/2011 0.10 45.00 E-mail to M. Dunn enclosing Letter in response to the

Garfinkle's complaint.
10/25/2011 2.50 1,125.00 Draft status report and letter to US Trustee in response to
garfinkle complaint
10/25/2011 0.20 90.00 E-mails between John Moffa and M. Dunn re statment of
authorization.
10/26/2011 0.10 45.00 E-mail from Alexandra Castro to Steve Turner enclosing
Trustee’s response letter.
10/29/2011 0.10 45.00 E-mail from Steve Turner confirming receipt of the
Response to your letter concerning Paul Garfinkle's
complaint.
11/1/2011 0.10 45.00 E-mail to Maria Spyroum regarding the status of the
case.
11/8/2011 0.10 45.00 E-mail to Mr. Kitzman re case status.
11/9/2011 0.20 90.00 E-mails with Imtiaz Lakhani re status of the case.
11/10/2011 0.30 135.00 E-mails with Steve Turner re response letter.
11/10/2011 0.10 45.00 E-mail from Alexandra Castro enclosing executed

Disclaimer of Interest.
11/11/2011 0.20 90.00 E-mails with Marica Dunn re preparing a supplemental

response.
11/16/2011 0.10 45.00 Receipt and review of an email from Alexandra Castro to
Steve Turner enclosing Trustee’s response letter.
11/16/2011 0.20 90.00 E-mail to M. Dunn enclosing a follow up letter to Steve

Turner concerning marketing efforts and the values of the
property.
12/20/2011 0.10 45.00 E-mail from J. Cartagena re follow up Letter to Don

Walton and Steve Turner 11-16-11.
1/6/2012 0.20 90.00 E-mails with Tong Li and Barry Gorssman re update on the
case.
1/10/2012 0.10 45.00 Reviewing e-mail from Jason Welt.
1/13/2012 0.20 90.00 Emails with M. Lessne and M. Dunn re summary of the
case.
1/19/2012 0.20 90.00 E-mails with Robert Meacham re order approving sale of
the mines.
1/25/2012 0.30 135.00 E-mail from and to Andre LaBauve and Sarah Williams re
Merendon Closing
1/25/2012 3.00 1,350.00 Attending deposition of Larry L. Adair
1/26/2012 0.20 90.00 Receipt and review of Trustee's Interim Report.
2/7/2012 0.10 45.00 E-mail from Paul Garfinkle re Trustee's Meeting.
2/27/2012 2.00 900.00 Preparation for, travel to and from and attendance at
pretrial conferences in two adversary cases under
litigation.

10/2/2009 0.20 90.00 E-mail to all regarding call with Ward Capstick, and
regarding Sorenson's arrest
10/5/2009 0.20 90.00 E-mails from Paul Garfinkle regarding invoice for Alberta
Ltd. tax year 2009
10/7/2009 0.90 405.00 Receipt and review of 9 Proofs of Claim
10/7/2009 1.10 495.00 Receipt and review of multiple e-notifications of claims

filed
10/9/2009 0.20 90.00 E-mail with creditor Josie Byington re: claim
10/12/2009 0.20 90.00 E-mail (x2) from creditor, John Nelson regarding proof of
claim
10/12/2009 0.10 45.00 Receipt and review of email from investor, John Nelson
10/13/2009 0.10 45.00 Reviewing e-mail from investor, Daniel Reichert
10/13/2009 1.50 675.00 Exchanging multiple e-mails with L. Negron and A.

Brodsky regarding calls from many investors, proofs of
claim needed, and other investor-related questions
10/13/2009 0.90 405.00 Telephone conferences each with with investor/creditors,

Daniel Reichert, Melanie Sears and Kurt Kienitz
10/14/2009 0.40 180.00 Receipt and review of email from investor, Dawn Abel (.2);
emails with investor, Josie Byington (.2)
10/14/2009 2.60 1,170.00 Receipt and review of 26 Proofs of Claims
10/15/2009 0.20 90.00 Emails from A. Brodsky regarding calls from investors:
Gregg Grover and Eddie Scarborough
10/15/2009 0.20 90.00 Receipt and review of filed proofs of claim
10/15/2009 0.60 270.00 Telephone conferences with creditors Eddie Scarborough

and Gregg Grover
10/16/2009 0.10 45.00 E-mail from A. Brodsky regarding call from Calgary
Herald
10/16/2009 0.80 360.00 Receipt and review of multiple filed claims (.8)
10/19/2009 0.50 225.00 Receipt and review of filed claims, filed trustee's statement,
and notification from court of 341 meeting being held and
concluded
10/22/2009 0.10 45.00 E-mail from A. Brodsky regarding call from Ward
Capstick
10/23/2009 0.10 45.00 E-mail to A. Brodsky regarding investor, Tim Carlson
10/27/2009 0.30 135.00 Exchanging e-mails with Paul Garfinkle regarding

Strategic Metals, claiming loss, Canadian company status,
etc.
10/28/2009 0.30 135.00 Exchanging e-mails with Melanie Smendziuk and Hartmut
Bielous, investors
10/29/2009 0.10 45.00 E-mail from investor, Melanie Smerdziuk

10/30/2009 0.30 135.00 Exchanging e-mails with A. Brodsky, L. Negron and
investor, Melanie Smendziuk, regarding Proof of claim
11/3/2009 0.20 90.00 E-mail from A. Brodsky transmitting creditor information

for return call and and email from Alex Castro with address
change for Nolan Hoyme (creditor)
11/5/2009 1.30 585.00 Receiving and reviewing multiple Proofs of Claim
11/6/2009 0.10 45.00 Receiving and reviewing Proof of Claim
11/9/2009 0.40 180.00 Receiving and reviewing Proofs of Claim (.2); emails with
A. Brodsky regarding call from J.Bennett in Colorado (.1);
and regarding calling Sonia Ray (creditor) (.1)
11/12/2009 1.20 540.00 Receiving and reviewing multiple Proofs of Claim
11/13/2009 5.10 2,295.00 Receiving and reviewing many Proofs of Claim (4.8);
emails with A. Brodsky regarding creditor, Leonid Gsirlin
(.3)
11/17/2009 0.10 45.00 E-mail from A. Brodsky regarding Paul Garfinkle call
11/19/2009 0.50 225.00 Exchanging e-mails with A. Brodsky regarding creditor,

Sonia Roy
11/30/2009 2.80 1,260.00 Receiving and reviewing multiple Proofs of Claim (2.5);
emails with A. Brodsky regarding call from creditor, Susan
Braun (.3)
12/1/2009 0.30 135.00 Emails with A. Brodsky regarding creditor phone call
12/5/2009 0.20 90.00 Review emails from A. Brodsky to Creditors with POC and
other questions
12/8/2009 0.80 360.00 Receipt and review of multiple Proofs of Claim filed
12/9/2009 0.30 135.00 Take call from creditor re: claims and case
12/10/2009 0.50 225.00 Receipt and review of multiple Proofs of Claim filed (.5)
12/14/2009 0.10 45.00 Review email from A. Brodsky to creditor re: Claim
12/14/2009 2.80 1,260.00 Receipt and review of multiple Proofs of Claim filed
12/21/2009 0.60 270.00 Receipt and review of multiple Proofs of Claim filed (.4);
review email from A. Brodsky to creditor (.2)
12/24/2009 0.30 135.00 Telephone with Oral Pascal investor re: proof of claim
12/28/2009 2.80 1,260.00 Receipt and review of multiple Proofs of Claim filed (2.4);
take creditor call (.3); email to all re: tall yof claims thus
far: 192 (.1)
12/29/2009 3.10 1,395.00 Receipt and reveiw of multiple Proofs of Claim filed
12/30/2009 3.00 1,350.00 Receipt and review of multiple Proofs of Claim filed; email
from A. Brodsky regarding calls from creditors.
1/4/2010 0.90 405.00 Receipt and review of 5 proofs of claim (.5); emails back
and forth with A. Brodsky regarding creditor calls about
filing proofs of claim (.4)
1/5/2010 0.50 225.00 Receipt and review of Order Conditionally Granting Ex

Parte Motion to Establish Limited Notice and discuss same
with A. Brodsky and L. Negron (.2); several calls from
creditors regarding filing proofs of claim (.3)

1/6/2010 0.80 360.00 Exchanging many emails with A. Brodsky regarding
creditor calls and with creditors regarding case and filing of
proofs of claim;
1/6/2010 1.90 855.00 Telephone conference with creditor Daniel Reichert (.3),
Susie Stevens (.3) and Paul Bentley (.3); numerous emails
with Ken Iredale re: claims (.9); email from Armengol
regarding research for claims administration (.1)
1/6/2010 0.30 135.00 Telephone conference with creditor Susie Stevens re:
claims
1/8/2010 0.10 45.00 Receipt and review of proof of claim from creditor
1/8/2010 1.90 855.00 Telephone conference with creditor Alan Lehman (.3) and
Dirk Farrell (.3) separately; many emails with Paul, B.
Elam, R. Schatzman regarding various claims issues (.6),
including call again from Werner, hearing preparation (.3),
Calgary Herald link ( .1); review A. Brodsky's emails to
several creditors (.3)
1/11/2010 3.90 1,755.00 Receipt and review of proofs of claims from 39 creditors
1/11/2010 1.40 630.00 Teleconference with creditor, Kyle Roat regarding POC
(.5); review A. Brodsky's many emails to creditors (.9)
1/12/2010 0.10 45.00 Email with Bill Lennon (creditor)
1/13/2010 1.70 765.00 Receipt and review of 17 proofs of claims
1/13/2010 0.30 135.00 Receipt and review of 3 proofs of claim
1/14/2010 2.40 1,080.00 Exchanging e-mails with many creditors regarding proofs
of claim (.4); Martin Werner transferring his proposed
changes to order (.3); with L. Negron and A. Brodsky
regarding filing proofs of claim (.4); receipt and review of
Voluntary Statement from creditor Rober Perry (.4); J.
Armengol, USDOJ, Arthur Niewirth, the Agency - all
regarding various aspects of the case, order language,
website (.9)
1/19/2010 0.20 90.00 Telephone conference with creditor, Katherine

Christianson
1/22/2010 0.90 405.00 Receipt and review of correspondence from investor,

Roger Soucy (.6); exchanging emails with Nate Mancuso
and Ji Hun Kim regarding foreign service (.3)
1/25/2010 0.60 270.00 Receipt and review of Motion to Allow Late Filed Claim(s)
by Paul Morgan (.3); calls and emails from creditors: Dawn
Abel, Kelly Crowley; call from Kim Barta, referred by
Werner re: same (.3)
1/26/2010 4.20 1,890.00 Receipt and review of 42 proofs of claims;
1/26/2010 0.10 45.00 E-mail from Kelly Crowley regarding filing proof of claim
late

1/27/2010 1.20 540.00 Receipt and review of notice of hearing on motion to allow
late filed claims for 2/9/10 (.6); emails with creditors, Paul,
A. Brodsky (.6)
1/27/2010 3.20 1,440.00 Receipt and review of 32 proofs of claim
1/28/2010 2.90 1,305.00 Receipt and review of 29 proofs of claim
2/2/2010 0.20 90.00 Emails from creditor Jack Broderick (.2)
2/5/2010 0.80 360.00 Teleconference with Andrea and creditor Cole Rheal
regarding claim.
2/17/2010 0.30 135.00 Telephone conference with creditor Gail Coopey
2/17/2010 0.30 135.00 Receipt and review of claim filed
2/19/2010 0.30 135.00 Telephone conference with Mike Litson, attorney for
Parkland Group, creditor of Syndicated Gold Depository
2/23/2010 0.40 180.00 Review emails between A. Brodsky and creditors, Larry
and Sally Coupal
2/26/2010 1.30 585.00 Emails with A. Brodsky and creditor, Roy Renneberg and
attention to matter re: same (1.3)
3/1/2010 0.30 135.00 Telephone conference with Alan Lehman re: claims
3/3/2010 0.20 90.00 Emails with Mike Letsen regarding extending claims bar
date
3/4/2010 0.20 90.00 Receipt and review of filed claims
3/5/2010 0.60 270.00 Emails with Shaye O'Donnell, creditor
3/16/2010 0.10 45.00 Email to creditors Peacock and Crowley re: claims
3/18/2010 4.10 1,845.00 Receipt and review of many filed proofs of claim (3.6);
receipt and review of several claims filed (.5)
3/19/2010 0.40 180.00 Exchanging e-mails with creditors, the Brodericks
3/21/2010 0.30 135.00 Exchanging emails with Jack Broderick, creditor, regarding
status of case
3/22/2010 0.20 90.00 Review A. Brodsky's email with creditor, Jack Broderick
3/23/2010 0.20 90.00 Exchanging e-mails with Nicole Hilburn regarding proof of
claim
3/25/2010 0.40 180.00 Receipt and review of claims
3/26/2010 0.30 135.00 Receipt and review of filed claims (.2); email to creditor
regarding claim filing (.1)

3/30/2010 1.30 585.00 Receipt and review of filed claims (.5); emails with S.
Khanorkar regarding financial reports requested of Hark
for south American entities (.4); emails with A. Brodsky
regarding claims questions from several creditors who
invested in other companies associated with MM. (.4)
4/1/2010 1.70 765.00 Receipt and review of many filed claims
4/7/2010 0.20 90.00 Receipt and review of motion to allow late filed claim by
Richard Thorlakson (.1); review draft order on same and
upload to court (.1)
4/12/2010 0.50 225.00 Receipt and review of signed agreed order on Thorlakson's
motion to file claim late (.3); emails with Gayle Aspery of
US Bank regarding accounts which are subject of summary
judgment motion (.1); receipt and review of Richard
Brodsky's draft agreed m otion to postpone pretrial
conference and associated deadlines (.1)
4/13/2010 0.70 315.00 Receipt and review of filed claims (.5); receipt of signed
agreed order on Kirkwood's motion to allow late filed
claim (.1); call from Richard Brodsky (.1)
4/14/2010 0.10 45.00 Receipt and review of Agreed Order Granting Creditor
Larabee Capital Inc., Douglas Kirkwood's Motion to Allow
Late Filed Claim
4/15/2010 0.20 90.00 Exchanging e-mails with creditor Walter Forster regarding
filing claim
4/20/2010 2.70 1,215.00 Receipt and review of many filed claims (2.4); exchange
emails with S. Stirling regarding information not
forthcoming from Hark (.3)
4/22/2010 1.10 495.00 Exchanging e-mails with S. Stirling regarding follow up

with Hark (.2); receipt of motion to allow late filed claim
from Brenda Renrick, Janet Heim, Kyle Roat (.2); emails
with A. Brodsky regarding same (.2); draft and upload
agreed orders on the mot ions to file claims late (.4);
review email from creditor Dennis Blanchard (.1)
4/23/2010 0.50 225.00 Receipt and review of signed orders on motions to allow
late filed claims filed by Roat, Heim and Renrick (.3);
emails with Mike Letsen, Esq. regarding concessions
coming due at Peru property (.2)
4/29/2010 0.40 180.00 Receipt and review of motion to allow late filed claim from
Richard and Janet Simmons (.1); draft and upload agreed
order on same (.1); receipt of signed agreed order (.1);
email to creditors (.1)
4/30/2010 0.80 360.00 Receipt and review of motion to allow late filed claim from
Donald Fulton and Walter Forster (.3); draft and upload
agreed orders on same (.3); emails with S. Stirling
regarding defendants to re-serve and Hark still not being
responsive (.2)
5/4/2010 0.40 180.00 Receipt and review of agreed orders on motions to allow
late filed claims filed by Forster and Fulton
5/10/2010 0.90 405.00 E-mails from creditor Forster regarding late filed claim
acceptance (.3); exchange emails with Garfinkle and
Werner regarding Clearwater Mining and Glory Hole Mine
(.3); receipt of three proofs of claim (.3)

5/11/2010 0.10 45.00 Receipt and review of e-filed Motion to Allow Late Filed
Claim by creditor, Lin Cao
5/12/2010 0.20 90.00 Receipt and review of order granting motion to allow late
filed claim of creditor, Lin Cao
5/14/2010 0.30 135.00 Telephone conference with Joseph Davies, Esq. regarding
competing claim of his client re: Glory Hole mine
5/26/2010 0.30 135.00 Telephone conference with Katy Carter, wife of Kim Barta,
creditor of Park Lane
6/1/2010 0.20 90.00 Review A. Brodsky's email to creditor
6/3/2010 0.50 225.00 Telephone conference with Dan McCauley, counsel for a
creditor (.3); receipt and review of letter from creditor,
Zelo, form M. Dunn's office (.2)
6/3/2010 0.30 135.00 Telephone conference with Dan McCauley, counsel for
creditor
6/7/2010 0.20 90.00 Receipt and review of a proof of claim
6/15/2010 1.20 540.00 Exchanging e-mails with creditors regarding claim filing
and with Garfinkle
6/18/2010 0.20 90.00 Receipt and review of proofs of claim
7/6/2010 0.30 135.00 Telephone conference with Dana Kinsman, investor

creditor
7/18/2010 0.30 135.00 Exchanging e-mails with F. Santos regarding Garfinkle's

claim in Glory Hole
8/3/2010 0.50 225.00 Telephone conference with Dan Mccauley, attorney for
investor
8/6/2010 0.30 135.00 Telephone conference with Dana Kinzman, creditor
8/19/2010 0.90 405.00 Receipt and review of multiple proofs of claim (.3); emails
with S. Stirling and Mike re Norm Frank's equipment (.3);
transmit SEC's proof of claim to M. Dunn (.3)
8/20/2010 0.70 315.00 Exchanging e-mails with Ken Iredale, creditor, re case
status
9/13/2010 0.30 135.00 Telephone conference with Debbie Gisonni, creditor
10/28/2010 0.80 360.00 Telephone call from and with an investor/creditor re proof
of claim late filing (.3); telephone call with Mike Morrison
(.5) re Discovery Day and settlement re same
12/21/2010 0.50 225.00 Telephone conference with and email to and from Ben
Stang creditor
1/3/2011 1.00 450.00 Reviewing and Revising Proof of Claims
2/25/2011 0.30 135.00 Telephone with investor creditor
2/26/2011 0.30 135.00 Telephone with investor creditor
5/5/2011 0.30 135.00 Telephone conference with creditor Ken Ireland regarding
status of case and claims
5/9/2011 0.30 135.00 Telephone conference with lawyer for late filing
claimant

6/29/2011 1.00 450.00 Telephone with John Moffa re settlement of Caldwell
claims
8/24/2011 0.20 90.00 Receipt and review of an email from A. Srour re: Christen
Philbrook.
8/25/2011 0.20 90.00 Receipt and review of an email from A. Srour re: call from
Radvena LaVern from Arizona.
8/28/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Tracey
Andersen re: Claim No 639 - Deemed timely filed.
9/1/2011 0.30 135.00 E-mails with Kyle Roat,with Kyle Roat & Associates
regarding swindled Merendon Mining investors.
9/12/2011 0.30 135.00 E-mails with John Moffa regarding the Notice to Withdraw
Claim filed by Interested Parties Estate of Harold
Caldwell.
9/13/2011 0.10 45.00 Receipt and review of an email from John Moffa re
Trustee's Objection to Claim No. 482.
9/13/2011 0.50 225.00 Prepared a Trustee's Objection to Claim No. 482.
9/13/2011 0.10 45.00 E-mail to Paul Garfinkle enclosing Trustee's Objection to

Claim No. 482.
9/13/2011 0.10 45.00 E-mail to John Muffa enclosing Trustee's Objection to

Claim No. 482.
9/13/2011 0.10 45.00 E-mail to client enclosing Trustee's Objection to Claim No.
482.
9/22/2011 0.20 90.00 E-mail from Robert Meacham asking to provide him with
information and documents regarding the claims.
9/22/2011 0.10 45.00 E-mail from Charles Gryba a mining engineer from
Toronto re claims in Colorado.
9/23/2011 0.30 135.00 Review of Notice of Filing Receipt of Garfinkle's

answer.
9/23/2011 3.00 1,350.00 Receipt and review of Garfinkle's response to cliams

objection (1.0); telephone with Hannan (.5), telephone with
Moffa (.5); multiple emails with each regarding and receipt
of clearwater's continuance motion (1.0)
9/26/2011 0.50 225.00 Receipt and review of Paul Garfinkle's Answer to Joint
Response to Garfinkle’s Obj to 9019 Motion.
9/29/2011 0.30 135.00 Receipt and review of Proof of Claim.
10/4/2011 0.30 135.00 Telephone call to Jones Watters with Kitzman Trucking
10/11/2011 0.20 90.00 Emails with Imtiaz Lakhani re Claim for Capital loss.
10/31/2011 0.10 45.00 E-mail from A. Srour re call from Mike Stangl re: True
North Production Company.
11/22/2011 0.10 45.00 E-mail from A. Srour re phone call from Anna Bennett
asking about her Husband J. Bennett's salary from working
at the Black Rose mine.
12/28/2011 0.10 45.00 Reviewing e-mail from Sharon Roberts Creditor.

Tracey Andersen re Proof of Claim.
6/11/2009 0.10 40.00 Receipt and review of Marcum Rachlin's retainer letter to
M. Dunn
6/11/2009 0.30 120.00 Telephone conference with S. Khanorkar re: retention
6/12/2009 0.70 280.00 Exchanging e-mails with L. Negron and Maria Fernandez
receiving executed engagement letter and application for
employment, and with L. Negron regarding filing and
uploading Order regarding same (x3)
6/16/2009 0.20 80.00 Receipt and review of e-filed Ex Parte Application to

Employ B. Mukamal as Financial Advisors and receipt and
review of e-filed Ex Parte Application to Employ I. Reich
and GrayRobinson as Counsel Nunc Pro Tunc to June 11,
2009
6/17/2009 0.20 80.00 Receipt and review of Orders Approving Employment of I.

Reich and GrayRobinson, and B. Mukamal
7/16/2009 1.30 520.00 Telephone with M. Dunn re: hearing tomorrow on B.

Elam's retention (.5); emails with J. Ryan regarding her
retention (.4); emails with M. Dunn regarding 7/20
conference call (.4)
7/17/2009 0.40 160.00 Exchanging e-mails with R. Schatzman regarding 7/20 call
with creditors (.2); receive and review Order granting B.
Elam's employment and discuss B. Elam's role with him
(.2)
7/21/2009 1.30 520.00 Exchanging e-mails with L. Negron regarding Arizona

property search results (.4); with B. Elam and R.
Schatzman regarding 7/20 conference call and Garfinkle
and creditor comments (.4); with Maureen Bondor
regarding investors (.5)
9/16/2009 0.20 90.00 Exchanging multiple e-mails with S. Khanorkar regarding

B. Mukamal's affidavit and bank account review (.2)
9/18/2009 0.50 225.00 Multiple e-mails with S. Khanorkar regarding B.

Mukamal's affidavit and to Nate Mancuso regarding
complaint (.2); with R. Schatzman, M. Dunn, J. Ryan, B.
Elam, L. Negron and A. Brodsky regarding filing Mukamal
affidavit (.3)
7/12/2010 0.30 135.00 Review M. Lessne's email to Fisher Auction and M. Dunn
transmitting application for approval of employment of
auctioneer and proposed order granting same and affidavit
of auctioneer.
10/17/2011 0.10 45.00 E-mail from S. Khanorkar re Marcum fee application.
11/14/2011 0.50 225.00 E-mail from Jazmin Padilla enclosing B. Mukamal’s fee
application
11/22/2011 0.50 225.00 E-mail from S. Khanorkar enclosing Marcum fee

application.
11/28/2011 0.20 90.00 Emails with Frank P. Terzo re Fee Application.

12/20/2011 0.30 135.00 Reviewing of the breakdown per Activity Code for the Fee
App.
12/21/2011 0.50 225.00 Reviewing of first draft of the Fee Application along with
the exhibits.
7/16/2009 2.00 800.00 Conference with B. Mukamal, R. Schatzman and S.

Khanorkar re: discovery issues
9/9/2009 0.20 90.00 Emails with Pearson and L. Negron regarding state of
Washington summary judgment and with M. Dunn
regarding ditch rights (.2)
9/18/2009 0.20 90.00 Multiple e-mails with Nate Mancuso regarding Complaint
(.2)
12/1/2009 2.60 1,170.00 Exchanging e-mails with P. Wagner regarding drafting of

complaint, and motion for substantive consolidation and
injunctive relief (.3); discuss complaint (.8); send Paidge
document links regarding Watchers and others (.1); emails
with all regarding s tatus of complaint in response to B.
Elam's email regarding status of mines (.8); emails with all
regarding Gold Basin, complaint, investors, and emails
from Les Taylor (.6)
12/2/2009 0.50 225.00 Exchanging e-mails with all transmitting adversary

complaint for review and comment, and need to locate
defendants' addresses (.2); email with Paul Garfinkle
regarding need for addresses of defendants (.1); telephone
conference with L. Negron regardi ng no need for filing
motion to defer filing fee (.2)
12/3/2009 0.50 225.00 Exchanging e-mails with all regarding adding wife and ex-
wife of Brost and Sorenson (.3); with Paul Garfinkle and S.
Khanorkar regarding addresses and Les Taylor's phone
number (.2)
12/4/2009 1.60 720.00 Exchanging e-mails with P. Wagner regarding complaint

and with S. Khanorkar regarding address on coloro poster
from Garfinkle (.7); with all, including B. Elam and S.
Khanorkar regarding comments and revisions to complaint
and injunction motion (.7), and receipt of S. Khanorkar's
redlined changes to complaint (.2)
12/8/2009 0.40 180.00 Emails to all regarding breadth of complaint/who to add as

defendants
12/9/2009 0.30 135.00 Exchanging e-mails with P. Wagner, S. Khanorkar, R.

Schatzman, Jason Burnett all regarding draft injunction
motion, revisions, complaint, and hearing date
12/10/2009 0.40 180.00 Emails with Paige regarding revisions to adversary

complaint.
12/11/2009 1.00 450.00 Exchanging e-mails with all, including Paul, sending
motion for review, and instructions for exhibits, etc., to L.
Negron and A. Brodsky (.3); emails from Paul regarding
Werner and Adair addresses and P. Wagner to add to
complaint (.3); email from M. Dunn signing off on
complaint (.1); emails with P. Wagner regarding adding
more defendants to complaint (.3)

12/14/2009 0.70 315.00 Review multiple emails with S. Khanorkar, Paige and all
others regarding addresses of defendants
12/15/2009 1.20 540.00 Exchanging e-mails with A. Brodsky, L. Negron, and S.

Khanorkar regarding SGD exhibit to complaint (.5); receipt
of e-filed Adversary Complaint [D.E. 1] (.1); [D.E. 65 in
main case; emails with L. Negron regarding entry of
defendants into CM/ECF syst em (.6)
12/17/2009 1.40 630.00 Exchanging e-mails with Rosy Lopez regarding Ponzi
scheme story (.3); transmit complaint and motion to her
(.3); emails with B. Elam, et al. regarding motion (.3);
receipt and review of e-filed injunction motion [D.E. 3 in
adv. case]; [D.E. 66 in mai n] (.3); emails from M. Dunn
regarding motion (.3)
12/18/2009 1.00 450.00 Receipt and review summonses and pretrial order, and
calendering deadlines re: same, and receipt of notice of
hearing on injunction and consolidation motion
12/18/2009 1.30 585.00 Exchanging e-mails with A. Brodsky and L. Negron

regarding summonses, service, mailing, etc. (.3); receipt of
Summons Issued on all Defendants [D.E. 4] (.1); receipt of
Order Setting Filing and Disclosure Requirements for
Pretrial and Trial, etc. [D. E. 5] (.1); receipt of Notice of
Hearing on Motion [D.E. 67 in main case] (.1); review
emails from A. Brodsky to all transmitting Motion for
Substantive Consolidation of Non-Debtor Entities,
Turnover of Property of Estate and Injunctive Relief in bot
h adversary and main cases (.7)
12/22/2009 0.80 360.00 Exchanging e-mails with Paul and S. Khanorkar regarding
The Agency and addresses (.6); receipt and review of e-
filed hearing notice on motion (.2)
12/25/2009 0.50 225.00 Exchanging e-mails with A. Brodsky and L. Negron

regarding summonses, service, mailing, etc.
12/27/2009 1.10 495.00 Exchanging e-mails with L. Negron and A. Brodsky

regarding summonses to be served
12/28/2009 0.40 180.00 Exchanging e-mails with L. Negron regarding service of

summonses
12/28/2009 1.00 450.00 Transmit complaint filed to Matt Galioto, Jeff Simpson,
Scott Fuller, Dave Smiley, and Jay Scoggins (.3); email
complaint and motion to various persons at The Herald
(.2); many emails with L. Negron regarding missing
summonses and addresses to defend ants (.5)
12/31/2009 0.20 90.00 Receipt and review of Order Conditionally Granting Ex

Parte Motion to Establish Limited Notice [D.E. 74] (.1);
email from A. Brodsky regarding creditor call (.1)
1/6/2010 1.70 765.00 Telephone conference with R. Schatzman (.3); with B.

Mukamal (.3); with J. Ryan (.3) with J. Armengol (.3) and
conference call with R. Schatzman, B. Mukamal, S.
Khanorkar, and B. Elam (.5) all re: hearing next week on
substantive consolidation

1/6/2010 3.50 1,575.00 Telephone conference with Martin Werner (.7); emails with
L. Negron, A. Brodsky, Cheryl Bennett, Rosy Lopez
regarding posting documents to website (.8); emails with
all regarding conference call about call received by Werner
(.6); send SGD promissory note to A. Brodsky for
inclusion in hearing documents and follow-up re: same
(.7); receipt, review and transmission to L. Negron
information to obtain search warrants in Alberta Canada
from Ken Iredale (creditor) (.5); exchange multiple emails
with Ken Iredale after forwarding motion, Garfinkle
Declaration and Mukamal Affidavit to him (.2)
1/14/2010 0.70 315.00 Telephone conferences with Martin Werner and Katherine
Christianson
1/18/2010 0.30 135.00 Exchanging e-mail with Cliff Hark regarding status of
order
1/20/2010 0.30 135.00 Receipt and review of Notice of Continued Hearing set for
1/25/10 (.1); email to all requesting attendance at hearing
(.1); email from Ward Capstick forwarding copies of wires
and Sorenson deposition transcript from Canada case
(.1)
1/25/2010 0.60 270.00 Exchanging e-mails with M. Lessne regarding filing

Sorenson deposition transcript and report of the RCMP
(.3); receipt and review of filing notice of same (.3)
1/25/2010 0.30 135.00 Telephone conference with class action lawyers
1/26/2010 0.20 90.00 receipt and review of correspondence from Arthur C.

Neiwirth, Esq. informing of his representation of Larry
Adair
1/26/2010 0.80 360.00 Telephone conference with Ward Capstick x 2
1/27/2010 0.60 270.00 Receipt and review of notice of filing copy of affidavit of
Gary Sorenson and Charles Blakey by Clifford Hark
1/28/2010 0.50 225.00 Receipt and review of 2 orders on substantive

consolidation
1/28/2010 8.20 3,690.00 Receipt and review of Order Granting Motion for
Substantial Consolidation of Non-Debor Entities, Granting
Motion for Turnover of Property, Denying Motion for
Preliminary Injunction in main and adversary cases (2.0) ;
email to all transmitting Order a nd discussing service
issues and next steps (2.0); telephone conferences with
Michelle Khouri, Maylyn Vargas, Cheryl Bennett
regarding press release and posting Order to website (1.0);
telephone conference with Paul regarding Order and
counsel in oth er jurisdictions (1.0); with Ji Hun Kim in
Miami office regarding foreign service issues (1.0); with
John Henderson regarding suggestions of bankruptcy, and
with Karen Fujita regarding case (1.0)
1/28/2010 0.10 45.00 Transmit to two creditors the SubCon order in the
adversary proceeding and the main case
1/29/2010 5.50 2,475.00 Exchanging many emails with Ken Iredale, Terzo, L.
Negron, Rosy Lopez, A. Brodsky, Paul, Rick Shor, John
Henderson, Michelle Khouri, Maylyn Vargas regarding
case, press release, creditor calls, website, service of
process on foreign entities, suggest ions (5.3); receipt and
review of Trustee's Report for the Period Ending 12/31/09
(.2)

1/30/2010 0.70 315.00 Exchanging e-mails with Ken Iredale, Paul, Rick Shor, B.
Elam
1/31/2010 0.30 135.00 E-mails with Terra Finial, Ken Iredale, Kristen Wegel -
creditors
2/1/2010 0.30 135.00 Telephone conference with Sorenson's counsel re:

depositions
2/1/2010 0.30 135.00 Telephone conference with Sorenson's counsel Hark
2/3/2010 0.90 405.00 E-mails from Ward Capstick regarding Nordic registered
agent and addresses (.3); with M. Lessne regarding draft
motion for partial summary judgment and proper service in
Belize (.3); and from Lloyde Simmons, creditor (.3)
2/5/2010 0.10 45.00 E-mail from Art Neiwirth
2/8/2010 0.30 135.00 Telephone conference with SEC counsel Elizabeth

Krupa
2/8/2010 6.00 2,700.00 attend deposition of Paul Garfinkle taken by Sorenson's

lawyer
2/9/2010 0.30 135.00 Telephone conference with Nordic's lawyer peter Walton
2/10/2010 0.30 135.00 Telephone conference with SEC counsel (.3)
2/10/2010 3.00 1,350.00 Attend depo of our financial advisor
2/11/2010 7.00 3,150.00 Prepare for hearing on injunction and attendance at same
95.0) including meetings with US Trustee (.5), Paul Taylor
(.4), Martin Werner (.4), Cliff Hark (.4), and draft order on
continuing hearings (.3)
2/12/2010 0.80 360.00 Telephone conference with Sorenson's counsel
2/12/2010 0.30 135.00 Telephone conference with martin Werner
2/16/2010 0.30 135.00 Telephone conference with Paul Taylor
2/17/2010 4.10 1,845.00 Exchanging e-mails with M. Lessne regarding response to

motion to dismiss filed by south American merendon
entities (.3); emails with M. Dunn and B. Elam regarding
translator motion (.8); emails with team regarding Milt
Shlapak (.8); review M. Lessne 's amendment to motion to
serve certain foreign defendants by certified mail (1.1); file
same (.2); review email from L. Hughes, SEC Denver (.1);
emails to A. Brodsky and M. Lessne regarding same (.8)
2/17/2010 8.00 3,600.00 Review documents and prep for hearing
2/18/2010 1.00 450.00 Conference with Garfinkle re: hearing
2/18/2010 3.60 1,620.00 telephone with Seth Levine, Larry Adair's criminal counsel
(1.1); telephone with Martin Werner (1.0); telephone with
Cliff Hark x 2 (1.5) all re: hearing tomorrow
2/22/2010 0.80 360.00 Receipt and review of order setting hearing on motion for
summary judgment for 3/11/10 at 11:00 and notice of filing
Exhibit A to motion for summary judgment regarding
opposing motions for summary judgment (.2); serve on
Hark, Werner, Neiwirth (.1); review transcript of 2/19
hearing sent by court reporter (.1); emails with Art
Neiwirth (.2); call from Dave Baddley of SEC in Atlanta
(.1); email with Kirsten Wegel regarding recordation of
orders (.1)

2/23/2010 2.00 900.00 Receipt and review of transcript of Paul Garfinkle
deposition from 2/8/10
2/24/2010 5.00 2,250.00 Drafting orders re: agreed order amending injunction order
and order re: service of process
2/25/2010 1.50 675.00 Telephone conference with Cliff Hark and Matt on revising
3 orders on service and injunctions
2/26/2010 0.30 135.00 Telephone conference with Art Neiwirth, Adairs counsel re
order
3/3/2010 1.50 675.00 Telephone conference with Nicole of Pappas office (.5) and
counsel of Caldwell heirs (.5) and telephone with Gus
Pappas re: same (.5)
3/3/2010 1.00 450.00 Telephone call from Milt Shlapak regarding meeting (.1);
emails with A. Brodsky regarding same (.2); receipt and
review of orders on service (.3); forward to team and serve
all parties with order amending 1/27 order granting motion
for substantive co nsolidation of non-debtor entities and
order on service (.1); post both to website (.1); emails with
Garfinkle regarding address for Sentinel Mining and add
Sentinel to style and service list (.2)
3/4/2010 0.30 135.00 Telephone call from Gus Pappas (.2); email from M.
Lessne regarding Belizian entities (.1)
3/5/2010 0.90 405.00 E-mails and calls with Garfinkle regarding Recovery Pool
and my call with Gus Pappas and Glory Hole (.6); emails
with Nicole Hilburn in Gus Pappas' office (.3)
3/6/2010 0.30 135.00 E-mail from Hark regarding Eiger's address (.1); emails
with Garfinkle regarding Glory Hole's ownership interest
(.2)
3/8/2010 0.40 180.00 Receipt and review of letter emailed from Arthur Neiwirth
regarding motion for partial summary judgment (.1);
respond to same (.1); review email from B. Elam from Les
Taylor and receipt of email from B. Elam, both regarding
Gold Basiin (.2)
3/10/2010 10.00 4,500.00 Preparation for hearing on motion for summary judgment,
plus research and drafting, reviewing and revising
proposed order re: same (5.0), including emails and
conversations to interested parties for their comments and
changes (5.0)
3/10/2010 0.10 45.00 Receipt and review of email from Art Neiwirth transmitting
revised draft motion for partial summary judgment with
redline changes
3/15/2010 1.00 450.00 Exchanging e-mails with Bennet Jones regarding hearing
and motion in Nosratieth v. Strategic case in Canada (.2);
email to M. Lessne regarding motion and order proposing
to continue pretrial conference and all deadlines for one
month (.2); email to c reditor Gail Coopec regarding claim
(.1); review letter to US Bank transmitting order on
summary judgment and their compliance with same
regarding accounts (.2); discuss with A. Brodsky (.1); call
from Richard Linde (purchaser) and Garfinkle (.2)

3/16/2010 3.20 1,440.00 Exchanging e-mails with A. Brodsky regarding Canadian
hearing (.2); telephone conference with M. Lessne
regarding motion to continue pretrial conference and
deadlines (.5); email to Hark regarding same (.1); meeting
with A. Brodsky regarding letter t o US Bank re:
compliance with order on summary judgment (.7); forward
same to team (.1); with M. Lessne and A. Brodsky
regarding letter needed to go to Judge Hawco in Canada
regarding proper service to Quilling (.5); review draft letter
from M. Less ne (.5); review summons service executed for
Strategic c/o Quilling (.2); receipt and review of agreed
motion to continue pretrial conference set for 3/22 and
associated pretrial deadlines for one month (.2); emails
with S. Khanorkar regarding S.A. e ntities not providing
monthly operating reports; review S. Khanorkar's email to
Hark regarding same (.2)
3/20/2010 0.20 90.00 E-mails with Mike Mysak transmitting two orders and
regarding advice and direction in Nosratieh v. Strategic
3/22/2010 0.10 45.00 Receipt and review of correspondence from Gus Pappas
regarding rights and claims to property
3/22/2010 0.50 225.00 Respond to S. Khanorkar regarding reports for April (.2);
email with A. Brodsky regarding re-serving initial
pleadings on south American entities that Hark wont accept
service (.1); emails with M. Lessne regarding initial
disclosures in adversary pro ceeding (.2)
3/23/2010 0.60 270.00 Emails with A. Brodsky regarding US Bank's compliance

with summary judgment order and recording summary
judgment order in mine jurisdictions (.2); emails with M.
Lessne regarding initial disclosures (.2); call from
Garfinkle re: case (.2)
4/5/2010 0.30 135.00 Receipt and review of fax from Katherine Christensen
regarding her Arizona case against Chevy Chase Bank and
regarding her emergency motion for tro to halt trustee sale
and hearing on same set for 4/6 (.1); discuss my attendance
by phone with A. Brod sky (.1); after review of motion, my
attendance is not necessary and discuss with A. Brodsky re:
same (.1)
4/6/2010 1.00 450.00 Exchanging e-mails with A. Brodsky and M. Lessne

regarding filing and serving Initial Disclosures
4/9/2010 0.50 225.00 Telephone conference with Richard Brodsky, counsel for
Nordic Merchant
4/13/2010 0.10 45.00 Receipt and review of Agreed Ex Pare Motion to Extend
Pretrial Conference and Other Associated Pre-Trial
Deadlines
4/16/2010 0.60 270.00 Exchanging e-mails with Quilling regarding entities' appeal
of receivership (.2); set conference call regarding joint ch.
15 in both jurisdictions with Quilling (.2); serve order on
motion to extend pretrial on all for Brodsky and file
cert/service f or same (.2)
4/21/2010 0.60 270.00 Exchanging e-mails with B. Mukamal regarding pretrial

and other deadline extensions in adversary proceeding (.2);
call from Garfinkle (.20; emails with Hark and S. Stirling
(.2)

4/28/2010 2.50 1,125.00 Exchanging many emails with M. Lessne, S. Stirling and
A. Brodsky regarding re-service of certain south American
defendants and Hark's refusal to cooperate regarding
same
5/3/2010 0.20 90.00 Exchanging e-mail with S. Stirling and A. Brodsky

regarding addresses for re-service of pleadings
5/4/2010 0.10 45.00 Reviewing Interrogatories prepared by S. Stirling to

Nordic
5/4/2010 0.30 135.00 Receipt and review of emails between S. Stirling and US
Embassy in Belize regarding addresses for re-service
5/4/2010 2.00 900.00 Exchanging e-mails and telephone conference with S.

Stirling regarding interrogatories regarding foreign corps.
certs of service (.8); emails with S. Khanorkar, regarding
reports still not received (.3); emails and telephone
conference with S. Stirli ng about contacting Hark (.8); and
email with A. Brodsky regarding call from Joe Davies
about Glory Hole mine (.1)
5/5/2010 0.70 315.00 Exchanging e-mails with S. Stirling regarding finalizing

interrogatories and getting them served on Hark and south
American defendants
5/6/2010 0.10 45.00 E-mail from S. Stirling regarding Merendon Belize
5/6/2010 0.20 90.00 Exchanging e-mails with S. Stirling regarding Richard

Brodsky's discovery query
5/6/2010 0.80 360.00 Exchanging e-mails with S. Stirling regarding south

American defendants' addresses (.4); emails from A.
Brodsky and forward to Werner regarding Joe Davies'
claim regarding Glory Hole (.4)
5/12/2010 0.30 135.00 Telephone call from Richard Brodsky, Nordic's counsel
(.2); emails with S. Stirling regarding service on South
American entities (.1)
5/21/2010 0.40 180.00 Receipt and review of a draft motion for continuance of
pretrial and proposed order from A. Brodsky (.1); file ex-
parte motion to continue pretrial (.1); discuss with court
(.1); receive email from M. Dunn's office transmitting
hearing notice in the Christiansen v. Chevy Chase Bank
case in AZ (.1)
6/3/2010 0.20 90.00 Emails with S. Khanorkar regarding expert disclosures
6/6/2010 0.20 90.00 E-mails with S. Stirling regarding answers to

interrogatories propounded to Hark and Brodsky (.1), and
drafting motion to compel Hark to answer (.1)
6/9/2010 0.40 180.00 Exchanging e-mails with S. Stirling regarding motions to

compel to Hark and Sorensen (.4)
6/10/2010 1.70 765.00 Receipt and review of SEC's complaint from L. Hughes
(.4); forward SEC complaint to team and Werner,
Garfinkle, Neiwirth, and Hark (.4); attention to matters re:
same (.9)
6/11/2010 9.80 4,410.00 Exchanging e-mails all day regarding filing motion to
compel and stay violation motion (1.2); revise, discuss,
file, forward to team, serve on parties (8.6)
6/11/2010 1.70 765.00 Review, revise and draft motion to compel (1.3); emails
with M. Lessne, A. Brodsky, S. Stirling regarding filing
stay violation motion and motion to compel (.4)

6/14/2010 0.60 270.00 Receipt and review of notice of hearing on stay violation
motion (.3); forward to team and serve on all others (.3)
6/16/2010 0.50 225.00 Exchanging e-mails with Richard Brodsky regarding

Nordic (.2); receipt and review of Siskiyou Daily article
about Discovery Day explosion (.20; email to the
Brodericks (investors) (.1)
6/20/2010 0.10 45.00 E-mail from Mike Letsen, Esq. regarding update and SEC
case
6/21/2010 0.40 180.00 Exchanging e-mails with Jay Sakalo regarding Trinity
Alps, American Sierra Gold, Patrick Fagan and Wayne
Gruden
6/21/2010 0.80 360.00 E-mail from Art Neiwirth regarding pretrial participation
(.2); serve motion to compel (.2); email with Richard
Brodsky regarding motion to compel (.2); emails with
Werner regarding Assignment of Bahama Resource Stock
(.2)
6/21/2010 0.10 45.00 Receiving and reviewing correspondence from Arthur

Neiwirth regarding continuation of pretrial and
participation in preparation for trial
6/28/2010 0.50 225.00 Telephone conference with Cliff Hark and email to him
regarding settlement, service of process, and lack of
financial reporting from south America
6/29/2010 1.90 855.00 Exchanging e-mails with Jay Sakalo, M. Lessne regarding
draft order granting motion for sanctions (.6); with Cliff
Hark regarding addresses still needed and other issues
discussed previously still outstanding (.6); with L. Hughes
of the SEC regarding accepting service, my appearance
pro hac vice in Washington State, and asset administration
(.7)
6/30/2010 3.80 1,710.00 Exchanging e-mails with M. Lessne, A. Brodsky, M. Dunn,

and Jay Sakalo regarding DD and agreed order resolving
motion for sanctions (.7); to M. Lessne regarding Sorenson
orders (one with agreement, one without) (.1); telephone
conference with L. Hugh es of the SEC (.3); emails with
Hark regarding draft agreed order on motion to compel
(.7); receive NEF of Agreed Ex Parte Motion to Continue
Pretrial; forward to team (1.0); forward to defendants and
counsel; emails with L. Hughes of the SEC regardi ng
waiving service (1.0)

7/1/2010 3.90 1,755.00 Exchanging e-mails with Mike Letsen, Esq. regarding
update on case for Parklane Group (.3); emails with Jay
Sakalo regarding Trinity stay order (.3); emails from/to
Patrick Fagen regarding Discovery Day GL policy (.3);
emails with Cliff Hark regardin g agreed order on motion
to compel (.3); telephone conference with A. Brodsky
regarding receipt of SEC complaint, and agreement on stay
order and uploading same to court, and status of hearing on
the matter (.4); telephone conference with A. Brodsky and
M. Dunn regarding agreed order on motion to compel to be
uploaded (.3); receipt and review of NEF of Agreed Order
Resolving Motion for Violation of the Automatic Stay, and
Motion for Sanctions against Trinity, et al. (.2); serve and
forward to te am (.3); file certificate of service (.1); receipt
and review of motion to withdraw Agreed Ex Parte Motion
to Continue Pretrial Conference indefinitley (.4); serve on
all adversary counsel (.2); review A. Brodsky's email to
counsel regarding any obje ctions to continuing pretrial for
60 days (.2); emails with Lessne and A. Brodsky regarding
filing of motion to continue pretrial for 60 days and order
upload on same (.3); receipt and review of NEF of Agreed
Order Granting Motion to Compel Certain D efendants to
Comply with Agreed Order Dated February 26, 2010 and
Answer Interrogatories Served on May 5, 2010 (.3)
7/2/2010 1.00 450.00 Receipt and review of NEF of Order Continuing Pretrial
hearing to 9/20/10 (.1); serve (.1); forward to team (.1); file
certificate of service (.3); email from Hark transmitting
letter with additional addresses (.1); emails with Garfinkle
regarding Di scovery Day ownership issues (.3)
7/6/2010 0.60 270.00 Telephone conference with Cliff Hark regarding Sorenson
and receipt and review of Hark's letter containing addresses
for Sorenson and S.A. entities (.6)
7/8/2010 0.30 135.00 Emails with M. Lessne and A. Brodsky regarding re-
service of South American defendants (.3)
7/8/2010 0.10 45.00 Receiving and reviewing copy of correspondence from

Garfinkle to Clerk of Gilpin County Courts re: case no.
09cv96 (.1)
7/9/2010 0.30 135.00 Telephone conference with opposing counsel, Richard

Brodsky, regarding Nordic Merchant Credit Union
7/12/2010 1.00 450.00 Telephone with Brodsky and review and revise Nordic
agreement
7/12/2010 0.10 45.00 Receiving and reviewing copy of correspondence from

Garfinkle to Judge Berryhill and Clerk of Gilpin County
Courts re: case no. 09cv96 transmitting Answer of
Garfinkle and Sentinel Mining
7/12/2010 0.20 90.00 Exchanging e-mails with Richard Brodsky and M. Lessne
regarding Agreed Motion to Permit Nordic's Expenditure
of Funds for Legal Representation (.2)
7/13/2010 1.10 495.00 Emails and teleconference with A. Brodsky and M. Lessne
regarding re-service to South American defendants
7/15/2010 0.20 90.00 Receiving and reviewing NEF of Agreed Motion to Permit
Expenditure of Funds by Nordic (.1); forward same to team
(.1)
7/17/2010 0.30 135.00 Exchanging e-mails with L. Hughes regarding SEC v.

Merendon case

7/22/2010 0.20 90.00 E-mail from and reply to Ward Capstick re SEC defaults
7/23/2010 0.40 180.00 Receiving and reviewing NEF of Notice of Hearing on

Nordic's Agreed Motion to Permit Expenditure of Funds
(.1); email with A. Brodsky re: same (.1); post to website
(.1)
8/3/2010 1.00 450.00 Exchanging e-mails with L. Hughes, SEC, regarding

waiver of service of summons and complaint (.3); emails
with S. Stirling regarding Mucker equipment sale motion,
and with Les Taylor regarding same (.3); with S. Stirling
regarding title issues (.4)
8/10/2010 0.20 90.00 E-mails with A. Brodsky regarding SEC v. Merendon

service waiver
8/17/2010 0.40 180.00 Exchanging e-mails with S. Stirling and Mike regarding
complaint and adding defendants
8/23/2010 0.20 90.00 Reviewing e-mail from Mike to Mike at Venture law
transmitting Agreed Order Resolving Trustee's Motion for
Violation of the Automatic Stay and Sanctions Against
Trinity Alps, et al. (.1); review email from Mark Levin
(.1)
8/23/2010 0.10 45.00 Reviewing e-mail from Martin Werner re representation of

SGD in SEC case
8/24/2010 1.10 495.00 Receipt and review of SEC complaint from L. Hughes (.4);
emails with Mike and A. Brodsky regarding Wabuska and
insurance from Fagan or his counsel (.5); email from John
Moffa, counsel to Estate of Caldwell re CO and TX cases
and motion for stay relie f (.1); email from Jay Sakalo re
draft agreed motion to vacate subcon and partial summary
judgment (.1)
8/25/2010 1.50 675.00 Exchanging e-mails with A. Brodsky and Garfinkle re

status conference call in CO and TX cases of Caldwell v.
Barnes (1.2); email with A. Brodsky re query from creditor
as to case status (.3)
8/26/2010 0.40 180.00 Reviewing e-mail from A. Brodsky to all counsel in

adversary proceeding re continuing pretrial (.2); discuss
with A. Brodsky (.2)
8/26/2010 0.50 225.00 Telephone conference with John Moffa, counsel for
Caldwell estate re stay releif motion
8/26/2010 0.50 225.00 Draft motion and order on continuance of pretrial
8/27/2010 0.40 180.00 Exchanging e-mails with A. Brodsky regarding

continuance motion in adversary proceeding
8/30/2010 0.30 135.00 Receipt and review of filed Agreed Ex Parte Motion to
Continue Pretrial Conference (.1); forward to Cheryl for
posting to website (.1); forward to counsel (.1)
8/31/2010 0.40 180.00 Receipt and review of Order Granting Ex Parte Motion to
Continue Pretrial (.2); forward to Cheryl to post to website
(.1); email with Jay Sakalo re draft of Agreed Motion to
Vacate Subcon and Partial Summary Judgment (.1)
8/31/2010 0.20 90.00 Receipt and review of order continuing pretrial and service
of same

9/1/2010 1.20 540.00 Telephone conference with SEC counsel L. Hughes re SEC
litigation (.4); emails with L. Hughes re case (.4); and
emails with Matt Kramer at Bilzin transmitting changes to
agreed motion to vacate (.4)
9/2/2010 0.20 90.00 Exchanging e-mails with Garfinkle re SEC case (.2)
9/9/2010 1.80 810.00 Exchanging e-mails with A. Brodsky and Kathy Savarin in
Stan Beck's office regarding notice of appearance in SEC
v. Merendon case in Washington state (.4); receipt and
review of Stan's notice of appearance (.2); receipt of filed
application to appear pro hac vice and our filed Answer to
the SEC's complaint (.4); forward to M. Dunn (.2); receipt
and review of agreed motion to vacate subcon and partial
summary judgment (.2); discuss with Matt and Jay
regarding same (.4)
9/10/2010 1.10 495.00 Receipt and review of SEC's response to Werner's Motion
to Dismiss (.4); emails with Matt Kramer at Bilzin re
agreed amended motion to vacate (.3); receipt and review
of filed Agreed Amended Motion to Vacate Subcon and
Partial Summary Judgment (.3); forward same to M. Dunn
(.1)
9/13/2010 0.40 180.00 Receipt and review of: Agreed Motion to Vacate SubCon
and Partial SJ against Discovery Day, American Sierra, et
al. (.1); Agreed Amended Motion to Vacate (.1); and notice
of hearing on the Agreed Amended Motion to Vacate (.1);
transmit revised Asset purchase agreement and amended
sale motion to H. Winderman (.1)
9/14/2010 1.60 720.00 Exchanging e-mails with Mike re objection to stay relief
(.3); email to Jay Sakalo re meeting between clients and
mediation (.1); telephone conference with A. Brodsky re
filing objection, serving, posting to website (.3); emails
from L. Hughes re dra ft consent to permanent injunction
and forward to M. Dunn (.3); review A. Brodsky's email to
translator re Request for Service Abroad (Venezuela) (.3);
attention to matter re: same (.3)
9/16/2010 0.80 360.00 Exchanging e-mails with Garfinkle regarding new pretrial
conference (.4); emails with Mike and S. Stirling re
complaint status (.4)
9/17/2010 0.60 270.00 Exchanging e-mails with S. Stirling and Mike re complaint,
and with M. Dunn re insurance and police report still not
received
9/20/2010 0.20 90.00 Receipt and review of Sorenson's response to SEC

complaint (.1); receipt and review of Stipulated Motion for
Entry of Preliminary Injunction Against Adair (.1)
9/20/2010 0.10 45.00 Receipt and review of Sorenson's response to SEC

complaint
9/21/2010 0.50 225.00 Telephone conference with L. Hughes of SEC
9/22/2010 0.20 90.00 Receipt and review of stipulated motion for entry of
preliminary injunction v. Capstick in the SEC case v.
Merendon (.2)
9/24/2010 1.70 765.00 Conference call with L. Hughes, et al. from the SEC re
consent to injunction

9/24/2010 0.70 315.00 Receipt and review of Reply filed by SEC to respond to
Motion for Preliminary Injuction v. Merendon Mining, et
al. (.3); multiple emails with Polly Atkinson, et al of SEC
regarding the reply they filed (.4)
9/28/2010 1.00 450.00 Conference call with SEC re SEC v. Merendon case
pretrial conference
9/28/2010 0.80 360.00 Telephone conference with Barbara Cargill, Courtroom

Deputy, re motion for stay relief and hearing on same and
certificate of no response re same (.4); telephone call with
Cheryl Kaplan, Law Clerk, and Matt Kramer re agreed
order and hearing on same (.4)
9/29/2010 0.30 135.00 Telephone conference with Judge Cristol and Matt Kramer
re amended agreed motion to vacate subcon and partial
summary judgment
10/1/2010 0.10 45.00 Receiving and reviewing of Motion of Southbank for

Relief from the Automatic Stay
10/6/2010 0.10 45.00 Receiving and reviewing correspondence from Arthur

Neiwirth re case v. Larry Adair
10/7/2010 0.30 135.00 Telephone conference with Trish Redmond, counsel for
Barnes
10/20/2010 0.30 135.00 E-mails to and from Bonnie Frank
11/5/2010 0.60 270.00 Receipt and review of motions for extension of time to
respond to adversary complaint filed in Dunn v.
Clearwater, et al. from the Estate of Harold Caldwell,
Dawn Fedrigon, individually and as Executrix of the Estate
of Harold Caldwell, and Michael F edrigon, Worldwide
Rental, and William Kemper and Marjorie Robbins
Daggett (.3), and receipt of Orders Granting all three (.3)
11/15/2010 0.30 135.00 telephone with Rob Reed attorney representing

defendant
12/14/2010 0.10 45.00 Receipt and review of Summons and Notice of

Pretrial/Trial in an Adversary Proceeding
12/14/2010 0.10 45.00 Receipt and review of Adversary Complaint for a

Declaratory Judgment to Determine the Validity, Extent,
and Priority of any Liens, Claims, Excumbrances, and
Interests in the Colorado Mining Properties, Including
Interests of Anyone Laying Claim to he Estate's Rights and
Interests in Such Properties
3/3/2011 0.30 135.00 Receipt and review Initial Disclosure of Witnesses and
Documents of Defendant, Clearwater Mining Company
[De 79]
4/7/2011 1.00 450.00 Review revise and draft and file discovery day
5/5/2011 0.30 135.00 Receipt and review of order approving settlement re

discovery day (.1), and prepare certificate of service of
same (.1), and serve same (.1)
6/3/2011 0.30 135.00 Receipt and review of Amended Order on Motion to

Withdraw as counsel of record by Clifford Hark (re: Dunn
v. Brost et al)
6/6/2011 0.20 90.00 Receipt and review of an email from N. Nicole to Robert
Meacham regarding Production to Worldwide.

6/6/2011 0.20 90.00 Receipt and review of emails between N. Nicole and Linda
Raymond regarding Production of Worldwide.
6/6/2011 0.20 90.00 Receipt and review of an email from M. Lessne to N.

Nicole regarding Worldwide.
6/14/2011 0.30 135.00 Emails with N. Nicole and M. Lessne regarding Production
to Worldwide.
6/14/2011 0.20 90.00 Receipt and review of an email from N. Nicole to Linda
Raymond and Robert Meacham regarding Worldwide's
Production.
6/15/2011 0.30 135.00 Receipt and review of emails between N. Nicole to Emma
Bartling regarding Production to Worldwide.
6/16/2011 0.30 135.00 Receipt and review of an Order Continuing Pretrial

Conference re Complaint filed by Plaintiff M. Dunn.
Hearing On Amended Complaint (Dunn v. Clearwater)
6/17/2011 0.30 135.00 Emails with Chris Hinks regarding Merendon Mining and
SGD and Gary Sorenson and Martin Werner.
6/20/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Emma
Bartling and N. Nicole regarding Merendon Production to
Worldwide and Due Diligence Package to Buyer.
6/21/2011 0.50 225.00 Telephone with Brett Amron re request for admissions (.3);
review emails from him and attachments and email to him
re same (.2)
6/21/2011 0.40 180.00 Receipt and review of an email from Brett Amaron
enclosing his clients’ RFAs and your responses.
6/21/2011 0.60 270.00 Telephone conference with Brett Amrom - counsel for
William Kemper re responses to request for admissions,
and review same
Preliminary Factual Statement In Connection With The
Trustee’s Consent To Injunctive Relief Herein
6/30/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Deputy
Robinson regarding Summary Judgment awarded to
Trustee.
7/6/2011 0.30 135.00 Receipt and review of an email from A. Srour to Mr.
Meacham enclosing Plaintiff's Answer to Worldwide
Rental Services, Inc.'s First Set of Interrogatories (Dunn v.
Clearwater Mining Company)
7/8/2011 0.30 135.00 Receipt and review of emails from E. Alan Hampson re:
clients William B. Kemper and Marjorie Daggett.
7/12/2011 0.20 90.00 Receipt and review of an email from M. Lessne re: Robert
Meachem
pretrial order to review.
of the Motion for Default to review.
7/13/2011 0.20 90.00 Receipt and review of an email from M. Lessne to Alan
Hampson enclosing proposed pretrial stipulation.

7/14/2011 0.20 90.00 Emails with M. Lessne re: Dunn v. Kemper and Daggett -
Proposed Pretrial order
7/15/2011 0.30 135.00 Emails with Jon Moffa re: Pretrial hearing in the
Adversary case.
7/18/2011 0.30 135.00 Receipt and review of Motion to Request Judicial Notice of
the Judgment Entered by the Clerk of the Gilpin County
Colorado State Court [DE 90]
7/19/2011 0.70 315.00 Telephone with moffa re Caldwell objections
7/19/2011 0.30 135.00 Receipt, review and reply to an email from Adam Katz re:
pretrial conference.
7/19/2011 0.30 135.00 Receipt and review of Motion to Request Judicial Notice of
Colorado State Court.
7/22/2011 0.20 90.00 Emails with M. Lessne re: Worldwide claims.
7/26/2011 0.30 135.00 Receipt and review of Order Continuing Pretrial

Conference.

Conference On Complaint filed by Plaintiff M. Dunn (.2)
and emai lto client regarding the same (.2)

Conference On Amended Complaint filed by Counter-
Defendant M. Dunn, Plaintiff M. Dunn and email to client
regarding the same.
7/27/2011 0.30 135.00 Receipt and review of an email from M. Lessne to Sherriff
Pelle enclosing Summary Judgment.
8/3/2011 0.40 180.00 Receipt and review of an email from N. Nicole enclosing
Motion resetting 8/17/11 hearing (.2) and Order on same
(.2)
8/3/2011 0.30 135.00 Receipt and review of Notice of Hearing Motion to

Request Judicial Notice of the Judgment Entered by the
Clerk of the Gilpin County Colorado State Court
(Clearwater)
8/3/2011 0.30 135.00 Reviewing and responding to e-mail from M. Lessne re: N
Frank's claim of ownership.
8/3/2011 0.30 135.00 Reviewing and responding to e-mails from Jessica Serrano
re: submitting orders
8/4/2011 0.30 135.00 Telephone conference with Angela re request for judicial
notice hearing
8/4/2011 0.20 90.00 Reviewing and responding to e-mails from M. Lessne re:
sanction against Leslie Taylor representing Merendon
Mining (Colorado).
8/4/2011 0.30 135.00 Telephone conference with Ron Reed, attorney for one of
the parties to the litigation
Hearing on Motion to Request Judicial Notice of the
Judgment Entered by the Clerk of the Gilpin County

8/10/2011 0.30 135.00 Receipt and review of an Order Granting Motion To
Continue Hearing On Motion to Request Judicial Notice of
Colorado State Court (Dunn v. Clearwater Mining)
8/10/2011 0.20 90.00 Receipt and review of an email from A. Srour to Ms.
Fiorentino enclosing Order Granting Motion to Continue
9/6/2011 0.20 90.00 E-mails with J. Cartagena regarding message from Mr.
Meacham's office regarding pretrial conference set for 9/19
in Dunn v. Clearwater.
9/6/2011 0.20 90.00 Emails with Andrea Madigan and M. Lessne re Caldwell
and Colorado properties (adversary proceeding)
9/8/2011 0.30 135.00 E-mails with J. Cartagena regarding Paul Garfinkle's

objection to extend the hearing date for the Pretrial
Conferences in Adv. Proc. No. 09-02518-AJC and Adv.
Proc No. 10-03623-AJC scheduled for hearing on
September 19, 2011 at 10:00 a.m. EST.
9/8/2011 0.30 135.00 E-mails with J. Cartagena regarding email to interested

parties seeking their agreement to extend the hearing date
for the Pretrial Conferences in Adv. Proc. No. 09-02518-
AJC and Adv. Proc No. 10-03623-AJC scheduled for
hearing on September 19, 2011 at 10:00 a.m. EST.
9/8/2011 0.20 90.00 E-mails with Deana Hramatulova advising that she has no
9/8/2011 0.10 45.00 E-mail from Richard E. Brodsky advising that he has no
9/8/2011 0.20 90.00 E-mails with Adam Katz regarding objection to extend the
hearing date for the Pretrial Conferences in Adv. Proc. No.
09-02518-AJC and Adv. Proc No. 10-03623-AJC
scheduled for hearing on September 19, 2011 at 10:00 a.m.
EST.
Agreed Motion to continue September 19, 2011 Pretrial
and proposed Order to continue same. (Dunn v.
Clearwater)
9/9/2011 0.30 135.00 E-mails with J. Cartagena regarding Alan Hampson's

approval of the continuance of pretrial conferences in Adv.
Proc. No. 09-02518-AJC and Adv. Proc No. 10-03623-
AJC scheduled for hearing on September 19, 2011 at 10:00
a.m. EST.
Agreed Motion to continue September 19, 2011 Pretrial
and proposed Order to continue same. (Dunn v. Brost)
9/12/2011 0.10 45.00 E-mail to A. Srour advising to serve Order on Motion to

Continue Hearing in Dunn v. Brost and in Dunn v.
Clearwater on all parties.

9/12/2011 0.30 135.00 Receipt and review of an Order on Motion to Continue
Hearing to 11/3/11 (Dunn v. Brost)
Amended Agreed Motion to Continue in Dunn v. Brost
case.
Amended Agreed Motion to Continue in Dunn v.
Clearwater case.
9/12/2011 0.10 45.00 Receipt and review of an email from J. Cartagena advising
that the Court's asked we must file an Amended Motion in
both adversary cases (Brost & Clearwater)
9/13/2011 0.20 90.00 Emails with J. Cartagena regarding Motions filed in Dunn
v. Brost- DE#156 and Dunn v. Clearwater- DE# 100.
Colorado State Court and email to client enclosing the
same.

Conference and email to client enclosing the same (Dunn
v. Clearwater)
9/14/2011 0.10 45.00 E-mail from A. Srour to Paul Garfinle enclosing Order
Granting Motion to Continue Hearing on Motion to
Clerk of the Gilpin County Colorado State Court; and
Order Continuing Pretrial Conference to November 3,
2011 (Dunn v. Clearwater).
9/14/2011 0.10 45.00 E-mail from A. Srour to John Muffa enclosing Order
Granting Motion to Continue Hearing on Motion to
Clerk of the Gilpin County Colorado State Court; and
Order Continuing Pretrial Conference to No vember 3,
2011 (Dunn v. Clearwater)
9/15/2011 0.10 45.00 Email from Paul Garfinkle re Harold Caldwell Pobate
case.
9/15/2011 0.40 180.00 Receipt and review of Plaintiff's Judgment Creditor's

Amended Motion to Renew Revive Judgment Prior to
Dormancy and proposed Order re the same. (Kemper v.
The Estate of Harold Caldwell, Case No.: 92 CV 55)
9/23/2011 0.20 90.00 Review of Notice of Filing Receipt of Clearwater's Motion

to Continue.
9/23/2011 0.20 90.00 Receipt and review of an email from John Moffa to the
trustees enclosing Motion by Clearwater to continue
hearing.
9/27/2011 0.10 45.00 E-mail from Robert Meacham regarding Transcript of

Judgment.
Deana Hramatulova regarding Power Equip Co.
10/4/2011 0.40 180.00 Receipt and review of letter from Robert Meacham and
Defendant Worldwide Rental Services, Inc. A/K/A
Worldwide Machinery, Inc.'S Disclosures Pursuant To
Rule 26, F.R.C.P.

10/5/2011 0.20 90.00 E-mails with Adam Katz dismissal of the adversary
proceeding.
10/6/2011 0.30 135.00 Receipt and review of Answer to Crossclaim Filed by

Clearwater Mining Company.
10/7/2011 0.60 270.00 Receiving and reviewing of an email from J. Cartagena

enclosing the Agreed Motion to Continue November 3,
2011 hearing in the Dunn v. Clearwater and Dunn v. Brost
case.
10/7/2011 0.30 135.00 Receiving and reviewing of e-mails between M. Lessne and
Robert Meacham regarding analysis in the adversary
cases.
10/10/2011 0.10 45.00 E-mail from A. Srour to Yamileth Valencia, clerk

enclosing Agreed Ex Parte Motion to Continue hearing in
Dunn v. Brost case.
10/10/2011 0.20 90.00 E-mails with J. Cartagena re Agreed Motion to Continue

Nov 3rd pretrial conference and Motion re Judical Notice
(Dunn v. Clearwater)
10/10/2011 0.10 45.00 Receipt and review of Stipulation for Dismissal with
Prejudice (Harold Caldwell)
10/10/2011 0.50 225.00 Receiving and reviewing of an email from J. Cartagena

enclosing the Agreed Order to continue November 3, 2011
hearing in the Clearwater and the Brost adversary cases.
10/14/2011 0.40 180.00 Receipt and review of Order Continuing Hearing and Order
Continuing Pretrial Conference (Dunn/Clearwater) and
email to clients enclosing the same.
10/14/2011 0.10 45.00 E-mail from A. Srour to the Trustees enclosing Orders
Continuing Hearing Hearing to 12/12/2011 in the
Clearwater and Brost adversary cases.
10/14/2011 0.30 135.00 Receipt and review of Order granting Motion to Continue
hearing (Dunn/Brost) and email to client enclosing the
same.
10/28/2011 0.30 135.00 Receipt and review of Order for Notice to show cause for
Revival of Judgment - Kemper v. The Estate of Harold
Caldwell Case No.: 92 CV 55.
11/10/2011 0.30 135.00 Receipt and review of an email from Deana Hramatulova
enclosing correspondence from Robert Meacham.
11/16/2011 0.50 225.00 Draft of letter to steve turner re garfinkle's complaint.
11/22/2011 0.20 90.00 E-mails with Adam Katz re dismissal of the EPA.
11/22/2011 0.30 135.00 Receipt and review of Defendant Worldwide Rental

Services, Inc. disclosures.
11/30/2011 0.20 90.00 Receipt and review of Re-Notice of Hearing on Pre-Trial

Re: Complaint by against Milowe Brost, et al.
11/30/2011 0.20 90.00 Receipt and review of Re- Notice of Hearing (Re: [90]
Motion to Request Judicial Notice of the Judgment Entered
by the Clerk of the Gilpin County Colorado State Court.
11/30/2011 0.20 90.00 Receipt and review of Notice of Hearing on Complaint

(Dunn v. Clearwater)
12/7/2011 0.20 90.00 E-mails with Adam Katz re Merendon Mining - adversary
proceeding

12/16/2011 0.80 360.00 Review of Notice of Dropping Parties (Declaratory
Action; Amended Complaint for Declaratory Judgment;
and Motion for Leave to Amend Complaint.
12/19/2011 0.10 45.00 Reviewing e-mails between Micahel Lessne and Jennifer
Rolph re order granting motion for leave to amend
complaint.
12/20/2011 0.20 90.00 Emails with Adam Katz re Merendon Mining's adversary
proceeding
12/20/2011 0.20 90.00 Reviewing of Certificate of Service of Order Granting M

for Leave to Amend Complaint.
12/21/2011 0.40 180.00 Reviewing e-mails between M. Lessne and Adam Katz re
Stipulation of Dismissal and reviewing of the same.
12/23/2011 0.20 90.00 Receipt and review of of correspondence from Robert

Meacham and initial disclosure.
12/27/2011 0.20 90.00 Receipt and review of correspondence from Geralynn

Grieve.
12/28/2011 0.20 90.00 Receipt and review of Notice of Taking Depositions of

Larry Adair and Martin Werner in the Securities and
Exchange Commission v. Merendon Mining (Nevada) Inc.
case.
12/29/2011 0.40 180.00 Receipt and review of email and Motion for Extension of
Time to File Responsive Pleading from Robert
Meacham
12/30/2011 0.10 45.00 Review of Order Dismissing United States From Adversary
Proceeding.
1/3/2012 0.20 90.00 Receipt and review of an email from Deana Hramatulova
Paralegal to Robert C. Meacham enclosing correspondence
and expert disclosures
1/6/2012 1.60 720.00 Receipt and review of plaintiff’s expert report of David
Abbott, Jr. from Leslie J. Hughes via email.
1/9/2012 0.20 90.00 Reviewing of Certificate of Service of Order granting

Motion for Leave to Amend Complaint
1/9/2012 0.20 90.00 Reviewing of Certificate of Service re DE 130 Order

Dismissing US from Adversary Proceeding.
1/9/2012 0.40 180.00 Reviewing of Notice of Filing Expert Witness Report,

along with the report.
1/12/2012 1.00 450.00 Receipt and review of an email from M. Lessne to Robert
Meacham re Worldwide Rental Services.
1/12/2012 0.20 90.00 Receipt and review of a letter from Robert Meacham to M.
Lessne.
1/13/2012 0.50 225.00 Receipt and review of Worldwide Rental's Answer and
Affirmative Defenses to Second Amended Advarsary
Complaint for Declaratory Judgment (.4); email to client
enclosing the same (.1)
1/13/2012 0.60 270.00 Receipt and review of Worldwide's Expert Report

Disclosures.

1/13/2012 0.60 270.00 Receipt and review of Motion to Extend Time to Complete
Discovery And Allow Filing of Motion for Summary
Judgment & Initial Disclosure per FRCP 26 Required by
the Order Setting (Dunn/Cahill/Wenrer)
1/13/2012 0.30 135.00 Receipt and review of an email from Laurie Bobrow Legal
Assistant to Robert Meacham enclosing correspondence to
M. Lessne along with breakdown of estoppel.
1/17/2012 0.10 45.00 Emails with Angela C. Riggs re vs. Larry L. Adair
1/17/2012 0.20 90.00 Email from amd to Arthur C. Neiwirth re upcoming-pre

trial.
1/19/2012 0.10 45.00 Receipt and review of a letter from Robert C. Meacham.
1/19/2012 0.30 135.00 Reviewing of emails from intrested parties re agreement to

extend the hearing date for the Pretrial Conferences.
1/19/2012 0.20 90.00 Receipt and review of SEC’s Withdrawal of Notice of

Deposition for Messrs, Werner and Hickson.
1/20/2012 0.10 45.00 Reviewing of Agreed Motion to Continue Jan 23, 2012
pretrial conference.
1/20/2012 0.20 90.00 Receipt and review of Motion to Extend the Deadline Time
to Complete Discovery , Motion to Allow Filing of Motion
for Summary Judgment Filed by Defendant Worldwide
Rental Services, Inc. (.1); email to client enclosing the
same (.1)
1/23/2012 0.50 225.00 Receipt and review of Agreed Motion for Permanent
Injunction Against Martin Werner by Plaintiff Securities
and Exchange Commission. (SEC v. Merendon)
1/23/2012 0.10 45.00 Reviewing of Notice of Withdrawal of Plaintiffs' Cross-

Notice of Deposition re Cross Notice to Take Deposition
(SEC v. Merendon)
1/23/2012 0.20 90.00 Review of Certificates of Service of Order Continuing

Pretrial to Feb. 27, 2012 (Dunn v. Werner and Dunn v.
Brost)
1/23/2012 0.20 90.00 Reviewing of Withdrawal of Plaintiffs' Cross-Notice of

Deposition.
1/23/2012 0.70 315.00 Receipt and review of Agreed Order Granting Defendant's
Worldwide Rental Services Motion to Extend Time to
Complete Discovery and to Allow Filing of Motion for
Summary Judgment and Order Granting Motion To
Continue Hearing (regarding Cahill and Brost ) (.6); email
to client enclosing the same (.1)
1/23/2012 0.60 270.00 Receipt and review of Agreed Order Granting Motion to
Extend Time to Complete Discovery (Dunn v. Werner)
(.2); Order Granting Motion To Continue Hearing on
Amended Complaint (Dunn v. Werner) (.2); Order
Granting Motion To Continue Hearing on Complain t
(Dunn v. Brost) (.2)
1/24/2012 0.40 180.00 Receipt and review of Certificate of Service Filed by

Defendant Worldwide Rental Services, Inc. (.2) and Order
on Motion to Extend Time (.2)
1/27/2012 0.40 180.00 Receipt and review of Rule 26 Initial Disclosures (.2);
emails to client enclosing the same. (Dunn/Cahill) (.2)

1/27/2012 0.10 45.00 Receipt and review of Rule 26 Initial Disclosures.
1/31/2012 0.10 45.00 Receipt and review of SEC’s Withdrawal of Plaintiff’s

Notice of Deposition for Ward Capstick.
2/3/2012 0.80 360.00 Receipt and review of correspondence from Robert

Meacham, re: Complaint and judgment,
2/7/2012 0.20 90.00 Receipt and review of emails between Deana Hramatulova
, Paralegal to Mr. Meacham and M. Lessne re extend the
deadline to respond to disclose expert witnesses
2/7/2012 0.20 90.00 Receipt and review of Motion to Extend Time for
Disclosure of Expert Testimony under Rule 26 (a)(2)
(Dunn/Cahill)
2/10/2012 0.20 90.00 Receipt and review of Supplemental Initial Disclosure per
FRCP 26 Required by the Order Setting Filing and
Disclosure Requirements regarding Expert Testimony (.1);
email to client enclosing the same (.1).
2/17/2012 0.20 90.00 Receipt and review of unopposed Motion to Extend Time
to comply with Pretrial Deadllines (.1); email to client
enclosing the same (.1).
2/23/2012 0.10 45.00 Receipt and review of Certificate of Service of Agreed

Order Granting Defendant, Worldwide Rental Services,
Inc.'s Unopposed Motion to Extend Pretrial Deadlines
Filed by Defendant Worldwide Rental Services, Inc
2/23/2012 0.10 45.00 Receipt and review of Agreed Order Granting Motion to
Extend Pretrial Deadlines
2/29/2012 0.30 135.00 Receipt and review of Order continuing Pretrial conference
to 4/23/12 and review Certificate of Service re the same
(.2); email to client enclosing the same. (Dunn/Brost)
(.1)
2/29/2012 0.30 135.00 Receipt and review of Order continuing Pretrial conference
to 4/23/12 and review Certificate of Service re the same
(.2); email to client enclosing the same. (Dunn v.
Frank/Cahill/Werner) (.10
3/5/2012 0.20 90.00 Receipt and review of Order by Judge Richard A Jones.
The court DENIES motions for permanent injunctions and
other relief, docket nos: [85], [86], [87] and orders the
SEC to submit a statement in compliance with this order no
later than March 28, 201 2 (.1); email to client enclosing
the same. (.1)
3/6/2012 1.00 450.00 Receipt and review of motion and order from SEC and
email to SEC re same
3/12/2012 0.40 180.00 Receipt and review of Motion for Judgment (.3); email to
client enclosing the same (.1)
Activity Code 011 Meetings of Creditors
7/16/2009 0.30 120.00 Telephone with client re: Monday's call with creditors
7/17/2009 0.50 200.00 Telephone conference with Bob Schatzman re: call with
investors on Monday

7/20/2009 1.80 720.00 Conference call with investors
10/5/2009 0.30 135.00 Telephone conference with Marilyn Sink, creditor

investor
10/9/2009 0.30 135.00 Telephone conference with creditor Orist Pashko
10/10/2009 1.20 540.00 Telephone conference with investor Melanie Sears (.3);
telephone with unidentified investor (.5); telephone with
investor John Nelson and email from nelson (.4)
10/14/2009 2.20 990.00 Telephone conference with investor creditor Judy

Sancartier (.4); telephone Demetrios Sinodinos investor
creditor (.5) telephone with Tawn Talls investor (.4)
telephone with Alicia McDonald (.3) telephone with
George Giesbrecht (.3) telephone with in vestor Dawn Abel
(.3)
10/16/2009 2.30 1,035.00 Meeting of creditors and meeting with trustee and her
financial advisors (2.0); exchange emails with investor,
Greg Grover (.3)
10/26/2009 0.30 135.00 Telephone conference with Tim and Janet Carlson re:
claims administration
1/7/2010 1.50 675.00 Telephone conference with Susie Stevens creditor (.3);
telephone conferences with Ken Iredale creditor x 2 (.6);
teleconference with Susan Brittman creditor (.3); email to
P. Wagner (.1) regarding converting motion into order for
Tuesday hearing; ema ils with Paul Garfinkle (.2)
6/9/2010 0.20 90.00 Emails with M. Lessne regarding Discovery Day and his
call with Garfinkle re: same
6/11/2010 0.30 135.00 Telephone conference with Garfinkle re: stay violation
motion
6/11/2010 1.30 585.00 Review, revise and draft stay violation motion for mine
explosion (1.1); emails with Jason Welt of Fisher Auction
re: same (.2)
6/23/2010 0.50 225.00 Telephone conference with Sakalo re: Tridnet stay
violation
6/24/2010 1.00 450.00 Conference with Jay Sakalo counsel for Trident regarding
stay violation issues
6/25/2010 1.20 540.00 Emails to and from Jay Sakalo counsel for Trident
regarding the stay violation issues and resolution of the
same (.8); conference with Capstick and Garfinkle
regarding this issue (.4)
6/25/2010 1.50 675.00 Telephone conference with Trustee, Paul Garfinkle and Jay
Sakalo, counsel for Trident, each separately regarding
hearing on stay violation and title issues (.9); emails with
Richard Brodsky re: stay violation issues (.6)

6/28/2010 1.60 720.00 Telephone conference with jay Sakalo (.3); receipt and
review property tax bill for 2009 on Discovery Day from
Sakalo (.2); emails with Garfinkle and F. Santos regarding
ownership of Discovery Day and explosion investigation
(.6); email to M. Dunn tr ansmitting copy of Bahama
Resource Assignment of Stock Interest (.1); email to Hark
transmitting Canadian orders on: Receivership and
Suggestion of Bankruptcy automatic stay, and also
regarding Charles Blakey accepting service on behalf of
Gary and T helma Sorenson and all S.A. entities and
addresses for service; financial and reporting information
on all S.A. entities; and financial arrangements for travel to
Calgary (.1); receipt and review of 2009 tax bill for DD
from Sakalo (.1); emails with Capstick regarding Sorenco
Oil & Gas (.2)
6/28/2010 1.00 450.00 Conference with Garfinkle re: hearing on stay violation
against Trinity
9/2/2010 1.00 450.00 Conference call hearing regarding colorado litigation over
glory hole
9/3/2010 0.50 225.00 Receipt and review stay relief motion from caldwell
estate
9/13/2010 6.00 2,700.00 Receipt and review of Caldwell's stay releif motion and
research and drafting objection and opposition to same
9/14/2010 10.00 4,500.00 Draft, research and file objection to Caldwell's motion for
stay relief
10/6/2010 0.30 135.00 Telephone conference with Judge Barnes Estate's counsel
re: stay
10/6/2010 0.30 135.00 Telephone with Bob Hogan, counsel for Colorado New
Blood Vista entities
10/11/2010 0.30 135.00 Telephone conference with Barnes counsel re stay
10/11/2010 0.30 135.00 Telephone conference with Bob Hogan, counsel for
Colorado New Blood Vista re: stay
6/8/2011 0.20 90.00 Receipt and review of an email from M. Lessne regarding
Discovery - Personally Identifiable Information.
12/5/2009 0.20 90.00 E-mail from Paul Garfinkle regarding Boulder City tax
situation
12/14/2009 0.40 180.00 Review emails from B. Elam regarding tax issues in
Boulder
1/20/2010 0.10 45.00 Email with B. Elam regarding tax situation in Colorado;
6/26/2010 0.30 135.00 E-mail to Jay Sakalo transmitting property tax bills (.1);
emails from Capstick (.1); email to M. Dunn regarding
property tax bills (.1)
6/28/2010 0.80 360.00 Telephone conference with jay Sakalo (.3); receipt and
review property tax bill for 2009 on Discovery Day from
Sakalo (.2); receipt and review of 2009 tax bill for DD
from Sakalo (.1); emails with Capstick regarding Sorenco
Oil & Gas (.2)

6/29/2010 1.40 630.00 emails and faxes from Paul Garfinkle transmitting
documents from Siskiyou County Tax Collector, and police
report from DD explosion and review same (1.0); email to
Hark, A. Brodsky, Werner, Neiwirth, Garfinkle regarding
objections to continuing pretr ial indefinitely to allow for
further discovery, resolve outstanding property issues and
sell assets and discuss same with A. Brodsky and M.
Lessne (.4)
6/30/2010 1.00 450.00 Receipt and review of multiple emails from Garfinkle
transmitting Siskiyou County tax collector documents
7/8/2010 0.10 45.00 Receipt and review of correspondence from Les Taylor to
M. Dunn regarding past due taxes for Black Rose Mine in
Jamestown, CO (.10
6/20/2011 0.20 90.00 Receipt and review of an email from J. Cartagena to Sean
Doyle enclosing the 2011 Real Property Notices from
Gilpin County.
Doyle enclosing information from the Colorado Division of
Reclamation.
9/22/2011 0.30 135.00 Received and reviewed emails between M. Lessne and J.
Cartagena regarding AZ Mines, calling Tax Collector in
Dolen County.
9/22/2011 0.10 45.00 E-mail from J. Cartagena regarding Tax Collector's office
and the Assessor's office in Mohave County.
10/17/2011 0.20 90.00 Receiving and reviewing of email from M. Lessne and M.
Dunn re email to the Boulder County tax collector with
attachments.
10/25/2011 0.20 90.00 Emails with M. Dunn and John Moffa regarding unpaid
taxes.
1/23/2012 0.10 45.00 Reviewing e-mail from M. Lessne to Tong Li re Boulder

County tax collector
Total for Timekeeper Reich, Ivan J 962.60 $430,220.00

Schatzman, Robert
6/16/2009 1.50 825.00 Prepare for and participate in conference call re: strategy
6/17/2009 0.20 110.00 Telephone call with Interfor, Inc.
6/18/2009 0.30 165.00 Telephone call with Tom Suozzo.
6/18/2009 0.30 165.00 Telephone call with representative of Interfor, Inc.
6/19/2009 4.00 2,200.00 Telephone call with Interfor, Inc. (.3); conference with S.
Solomon, client, B. Elam, J. Ryan and S. Khanorkar re:
strategy (3.7)
6/20/2009 0.80 440.00 Dictate memo regarding conference call on June 16 and
meeting on June 19, 2009 re: strategy
6/21/2009 0.50 275.00 Review and respond to various e-mails.
6/22/2009 0.80 440.00 Telephone call with Tom Suozzo from Interfor, Inc.
6/23/2009 0.40 220.00 Edit Memo to client and various parties re: strategy
6/23/2009 0.30 165.00 Telephone call with I. Reich.
6/23/2009 1.00 550.00 Review e-mails (.2); telephone call with Paul Garfinkle
(.5); telephone call with Sharmila Khanorkar (.3)
6/23/2009 0.60 330.00 Review and respond to e-mails.
6/24/2009 0.80 440.00 Review and respond to e-mails (.2); conference with I.
Reich (.3); telephone call with Harvey Geerwitch (.3)
6/24/2009 0.40 220.00 Review e-mails.
6/25/2009 0.30 165.00 Telephone call with Paul Garfinkel (.1); telephone call with
I. Reich (.2).
6/26/2009 6.00 3,300.00 Conference I. Reich (.3); conference client and various
professionals regarding case administration and recovery of
assets (5.7)
6/29/2009 0.40 220.00 Telephone call with J. Bennett, Administrator of case.
6/30/2009 0.00 0.00 Telephone call with Tom Cash.
6/30/2009 0.60 330.00 Telephone calls with Tom Cash, Kroll.
7/7/2009 0.40 220.00 Telephone call with Larry Krantz.
7/7/2009 1.00 550.00 Conference call with S. Khanorkar.
7/8/2009 3.20 1,760.00 Review file in preparation for meeting with Tom Cash and
S. Khanorkar (2.0); conference with Tom Cash and S.
Khanorkar (1.2)
7/10/2009 1.00 550.00 Review and respond to e-mails (.6); telephone call with S.
Khanorkar (.4)
7/10/2009 1.20 660.00 Review file (.5); draft memo (.7)

7/13/2009 0.50 275.00 Telephone call with S. Khanorkar (.3); review and respond
to e-mails (.2)
7/13/2009 0.40 220.00 Edit memorandum to client and professionals.
7/13/2009 0.50 275.00 Edit memo to client and counsels and professionals.
7/14/2009 0.70 385.00 Review memorandums (.4); telephone call with Tom Cash
(.3)
7/14/2009 0.20 110.00 Telephone call with Michael Quilling, Canadian

Receiver.
7/20/2009 0.60 330.00 Telephone call with I. Reich.
7/21/2009 1.00 550.00 Review public records regarding corporate filings and
property searches.
7/21/2009 0.60 330.00 Review notes (.3); telephone call with P. Garfinkle (.3)
7/21/2009 1.40 770.00 Review and respond to E-mails (.5); telephone call with
Paul Garfinkle (.4); attention to matter re: same (.5)
7/23/2009 2.50 1,375.00 Prepare for meeting with P. Garfinkle (.5); telephone call
with I. Reich, Meltz and P. Garkinkle (2.0)
7/24/2009 1.10 605.00 Preliminary review of Paul Garfinkle's statement; review

and respond to various e-mails (.5)
7/27/2009 1.00 550.00 Review Garfinkle's transcript.
7/29/2009 0.40 220.00 Telephone call with Harvey Gurwitch (.1); telephone call
with I. Reich (.3)
8/3/2009 0.40 220.00 Review various e-mails.
8/6/2009 1.00 550.00 Review Memo - consulting geologist - David Abbott.
9/7/2009 0.60 330.00 Review various e-mails.
9/8/2009 1.00 550.00 Review of documents from Alberta Securities

Commission.
9/8/2009 0.70 385.00 Review correspondence (.2); telephone call with I. Reich
(.3); review and respond to e-mails (.2)
9/16/2009 0.80 440.00 Review and respond to various e-mails (.5); telephone call
with I. Reich (.3)
9/16/2009 2.50 1,375.00 Review Garfinkel affidavit (1.0); telephone call with I.
Reich re: same and other matters re: same (1.5)

9/18/2009 0.80 440.00 Review Garfinkle Declaration.
12/14/2009 0.40 220.00 Telephone call with I. Reich regarding complaint and
motion for injunctive relief.
12/21/2009 2.00 1,100.00 Review motion for substantive consolidation, turnover and
injunctive relief.
1/6/2010 1.00 550.00 Conference call with I. Reich, B. Elam, S. Khanorkar.
1/7/2010 0.70 385.00 Review e-mails (.3); conference with I. Reich regarding
asset recovery (.4)
1/12/2010 0.70 385.00 Conference with I. Reich and Sharmilla K.
1/28/2010 0.20 110.00 Telephone call with I. Reich regarding Order of substantive
consolidation.
1/31/2011 0.50 300.00 Phone conference with I. Reich and M. Lessne regarding
settlement on Discovery Day Mine.
6/12/2009 1.00 550.00 Conference with I. Reich and F. Terzo regarding case
administration.
6/12/2009 2.40 1,320.00 Conference with I. Reich, B. Mukamal and Morris Berger
(2.0); review memo to B. Elam (.4).
6/15/2009 0.90 495.00 Review and respond to numerous emails.
6/15/2009 1.20 660.00 Telephone call with B. Elam (.8); review and respond to
emails (.4).
6/30/2009 0.80 440.00 Review I. Reich extensive memo (.4); e-mail various
parties (.4)
7/1/2009 0.80 440.00 Review proposal of Interfor (.1); telephone call Tom Cash's
office (.3); telephone call Tom Suozzo (.3); e-mail Tom
Suozzo (.1)
7/16/2009 0.30 165.00 Telephone call with I. Reich regarding Court hearing on
Elan retention.
9/4/2009 3.50 1,925.00 Conference with I. Reich and Sharmilla Khanorkar re:
schedules (.6); prepare schedules and statement of financial
affair (2.9)
9/8/2009 0.90 495.00 Telephone call with I. Reich re: case (.6); review e-mails
re: same (.3)
1/8/2010 0.60 330.00 Review and respond to various e-mails regarding

hearing.

1/12/2010 4.00 2,200.00 Prepare for and attend hearing on Trustee's Motion for
Substantive Consolidation.
7/14/2009 0.40 220.00 Review Kroll engagement letter
7/15/2009 0.20 110.00 E-mail I. Reich re: Kroll.
7/16/2009 2.70 1,485.00 Review file in preparation for meeting; call with I. Reich,
S. Khanorkar and telephone call with M. Quinlling.
9/21/2009 0.60 330.00 Review affidavit of B. Mukamal.
7/28/2009 1.00 550.00 Conference with I. Reich regarding complaint for alter ego
(.3); conference with N. Mancuso and I. Reich re: same
(.7)
9/1/2009 0.40 220.00 Telephone call with I. Reich regarding suit to determine
alter ego.
12/4/2009 2.50 1,375.00 Review and edit draft complaint (2.2); conference call with
I. Reich re: same (.3)
12/9/2009 0.50 275.00 Telephone call with I. Reich regarding draft complaint.
12/18/2009 0.50 275.00 Review pleadings and filings in adversary.
Total for Timekeeper Schatzman, Robert 84.90 $46,720.00

Scott, Patrick S
7/29/2010 0.80 396.00 Conference with I. Reich and others to review strategy for
clearing title to Colorado property
8/5/2011 0.40 200.00 Conference with M. Lessne re strategy for settlement
1/25/2012 0.20 100.00 Conference with M. Lessne re 1983 royalty agreement, and
buyer’s question
1/27/2012 1.00 500.00 Conferences with M. Lessne (.3), and Telephone

conference with I. Reich re whether possible to set aside
2009 and 2010 conveyances of Arizona mine (.7)
8/3/2010 0.70 346.50 Conference with M. Lessne, I. Reich, J. Leibner re: section
363 (.4); draft memo to M. Lessne re use of section 363(f)
to clear co-owner’s interest (.3)
7/19/2011 0.90 450.00 Strategize with I. Reich, M. Lessne re Glory Hole Mine,
options
1/11/2012 0.20 100.00 Conference with M. Lessne re form of sale order
1/13/2012 0.10 50.00 Conference with M. Lessne re service requirements for sale
order
1/13/2012 1.40 700.00 Conferences with J. Leibner, M. Lessne re research needed

on retroactive effect of judgment upon mechanic’s lien
1/16/2012 0.40 200.00 Telephone conference with R. Meacham re Worldwide

Rental’s lien
1/16/2012 1.50 750.00 Conference with M. Lessne, J. Leibner re Worldwide

Rental’s judgment lien (1.1); Telephone conference with I.
Reich, M. Lessne re negotiating with R. Meacham (.4)
1/19/2012 1.00 500.00 Conference with M. Lessne re strategy and research results
on Worldwide Rental’s secured claim (.3); Telephone
conference with R. Meacham re same (.3); exchanged
memos with M. Lessne, I. Reich, R. Meacham (.4)
1/20/2012 1.40 700.00 Numerous conferences with M. Lessne, J. Leibner re

Worldwide’s construction lien claim, research issues, how
to proceed
2/3/2012 0.40 200.00 Reviewed letter from R. Meacham re remaining issues in

Worldwide dispute re: claim (.2); exchanged memos with
M. Lessne re issues for same (.2)
2/6/2012 1.40 700.00 Conference with M. Lessne re Worldwide’s counsel’s letter

(.5); drafted reply to R. Meacham (.3); legal research re
Colorado construction lien statute and Colorado court rules
(.6)

2/24/2012 1.20 600.00 Telephone conference with R. Meacham re possible
settlement of Worldwide Rentals adversary proceeding
(.4); drafted stipulation for settlement (.4); drafted motion
to approve settlement (.4)
2/7/2012 0.40 200.00 Conference with M. Lessne proposed response to R.

Meacham re Worldwide (.2); conference with I. Reich re
same (.2)
2/8/2012 1.70 850.00 Drafted letter to R. Meacham re all issues in his dispute
(.3); reviewed research results (1.4)
2/13/2012 0.60 300.00 Drafted memo to M. Dunn re proposed settlement terms

with Worldwide
2/16/2012 0.40 200.00 Telephone conference with R. Meacham re Worldwide

(.2); conference with I. Reich re same (.2)
2/17/2012 0.40 200.00 Conference and numerous email exchanges with I. Reich re
what to recommend to M. Dunn re Worldwide
2/20/2012 0.20 100.00 Drafted memo to M. Dunn re Worldwide
2/21/2012 0.20 100.00 Revised letter to R. Meacham re settlement offer
2/24/2012 0.50 250.00 Drafted settlement stipulation
2/28/2012 0.30 150.00 Conference with M. Lessne to review his revisions to

settlement with Worldwide
3/1/2012 0.10 50.00 Drafted memo to R. Meacham
Total for Timekeeper Scott, Patrick S 17.80 $8,892.50

Serrano-Cartagena, Jessi
2/7/2012 0.30 37.50 Review several emails from M. Lessne and S. Doyle re:
expense reimbursement for work done regarding Bueno
and Black Rose mines.
3/2/2011 0.40 50.00 Draft and finalize email to interested parties re: 30 Day
Continuance of 3/21 Sale Motion, Pretrial Conference and
All Related Deadlines for M. Lessne and I. Reich's review
(0.3); Email same to interested parties (0.1).
4/20/2011 0.30 37.50 Assist M. Lessne with draft of asset purchase agreement re:
Glory Hole.
4/20/2011 0.20 25.00 Review emails from M. Lessne and I. Reich re:
settlement.
4/27/2011 0.20 25.00 Discuss Glory Hole description with M. Lessne and email
same.
6/2/2011 0.30 37.50 Review email from M. Lessne (0.1) and redlined asset
purchase agreement sent to S. Doyle (0.2).
8/16/2011 0.40 50.00 Review emails from M. Lessne re: Caldwell settlement and
review agreement re: same.
8/18/2011 0.20 25.00 Review redlined version of stipulation agreement.
12/7/2011 0.50 62.50 Discuss service of Order approving Sale of Bueno and
Black Rose Mining Properties with M. Lessne.
12/7/2011 1.30 162.50 Review title reports, matrixes and other documentation for
preparation of service re: Order approving Sale of Bueno
12/7/2011 0.50 62.50 Draft and finalize certificate of service re: Order approving
Sale of Bueno and Black Rose Mining Properties.
1/3/2012 3.60 450.00 Assist I. Reich and M. Lessne with preparation for
1/4/2012 hearing re: Sale of Bueno and Black Rose mining
properties.
1/3/2012 1.00 125.00 Review docs, draft, finalize and file on court's docket
Certificate of Service of publishing and Order Approving
Sale of Bueno and Black Rose mining properties served by
Fisher Auction Company.
1/4/2012 3.80 475.00 Continue with preparation for today's hearing re: Sale of
Bueno and Black Rose mining properties.
1/19/2012 1.10 137.50 Review creditor matrix and Order Approving Sale of
Bueno and Black Rose mining properties in preparation of
service of same (.5) certificate of service for same (.6)
1/20/2012 0.30 37.50 Meeting with Jeff Bahnsen re: documents needed for
closing of sale for Bueno and Black Rose mining
properties.

3/2/2011 1.10 137.50 Review dockets in main case and both adversary cases
(0.4); Review Motions and Orders filed re: Sale and
Pretrial Conferences (0.4); Follow-up with M. Lessne re:
same (0.3).
3/3/2011 1.00 125.00 Review and respond to interested parties re: continuance of
hearing on Sale Motion and pretrial conferences (0.5);
Follow-up with M. Lessne and I. Reich re: same (0.5).
3/4/2011 1.90 237.50 Emails and teleconference with M. Lessne and I. Reich re:
continuances of Motion in main and adversary cases (0.4);
Draft Motion for Continuance of hearing on Sale Motion,
Pretrial Conferences and proposed Order (0.5); Contact
court re: available dat es to continue (0.3) and follow-up
with M. Lessne re: same (0.2); Revise and e-file Motion in
main and adversary cases (0.5).
3/7/2011 0.50 62.50 Follow-up with Court re: Motion and proposed Order
Continuing Sale and Pretrial Conferences (0.3); Follow-up
with M. Lessne re: same (0.2).
3/8/2011 0.80 100.00 Teleconference with Courtroom Deputy re: continued date
and time for proposed Order to Continue hearing on Sale
Motion and Pretrial Conferences (0.1); Email to I. Reich
and M. Lessne re: continued time (0.1) and review
responses re: same (0.1); Prepa re and finalize proposed
Order and upload same to main case and both adversary
cases (0.4); Follow-up with I. Reich and M. Lessne re:
same (0.1).
3/8/2011 0.50 62.50 Emails with M. Lessne and I. Reich re: continued time/date
for Sale Motion and Pretrial Conferences (0.2); Finalize
and upload Orders in main and both adversary cases
(0.3).
3/9/2011 1.10 137.50 Follow-up with Court re: Order to Continue Sale Motion
and Pretrial Conferences (0.2); Review Orders and
calendar same (0.5); Emails and teleconferences with I.
Reich, M. Lessne and M. Dunn re: same (0.4).
3/11/2011 0.70 87.50 Review numerous emails from I. Reich re: new pleadings
filed and calendar dates (0.3); Attention to matters re: same
(0.4).
3/15/2011 0.50 62.50 Review pleadings and calendar upcoming hearing dates.
3/21/2011 0.20 25.00 Follow-up with Cheryl Bennett re: case information on
website for creditors.
3/22/2011 0.20 25.00 Review emails from I. Reich and Garfinkle.
3/23/2011 0.20 25.00 Review email from I. Reich re: SEC v. Merendon case,
download Order Granting Motion to Dismiss and Deny in
part, and email same.
3/24/2011 0.40 50.00 Review emails from I. Reich (0.2); File and email
requested docs re: same (0.2).
4/5/2011 0.20 25.00 Follow-up and emails with C. Bennett re: docs for
website.
4/15/2011 0.90 112.50 Teleconferences with M. Lessne re: email to interested

parties for continuance of 3/26 hearing and pretrial (0.3);
Draft and finalize email to all interested parties re:
continuance of same (0.6).

4/18/2011 0.40 50.00 Forward email to M. Hannan's additional address re:
continuance of hearing and pretrial conferences set for 4/26
(0.1); Review email and teleconference with M. Lessne re:
Agreed Motion and Order to continue hearing and pretrial
conferences (0.3).
4/19/2011 0.90 112.50 Finalize, prepare and e-file Agreed Motion and proposed
Order to continue 4/26 hearing and pretrial conferences in
the main case and both adversary proceedings (0.8); Email
e-filing receipts to I. Reich and M. Lessne (0.1).
4/21/2011 0.80 100.00 Revise (0.2) and upload proposed Orders in main and both
adversaries cases (0.3); Follow-up with A. Srour re:
contacting court and procedures re: same (0.2): Call court
and leave voice message re: certificate of service for order
continuing to 4/26 ( 0.1).
4/25/2011 0.70 87.50 Discuss certificate of service of Orders continuing 4/26

hearing and pretrial conferences to 6/23 with A. Srour
(0.1); Email Orders to C. Bennett for GrayRobinson's
website (0.1); Draft and email all interested parties Orders
entered in main and adve rsary cases (0.3); Emails with I.
Reich re: continued hearing to 6/23 and certificate of
service of same (0.2).
4/25/2011 0.60 75.00 Discuss 4/26 hearing and pretrial conferences with M.
Lessne (0.2); Contact court re: continuing same to June and
entering order on docket re: same (0.2); Follow-up with I.
Reich and M. Lessne confirming 4/26 hearing and pretrials
continued to 6/23 ( 0.2).
4/26/2011 1.40 175.00 Review and organize files into index.
6/3/2011 0.40 50.00 Review Amended Order on Motion to Withdraw as counsel

of record by Clifford Hark (0.2); Download and email same
to I. Reich (0.2).
6/7/2011 0.60 75.00 Reveiw multiple emails re: production to Worldwide (0.3)
and asset purchase agreement (0.3).
6/7/2011 0.70 87.50 Emails and teleconferences with I. Reich and M. Lessne re:
continuance of pretrial conferences and sale motions.
6/9/2011 1.50 187.50 Draft email to interested parties for M. Lessne re: Motion
to continue sale hearing and pretrial conferences (0.8);
Discuss same with M. Lessne (0.3); Finalize and email all
interested parties email re: same (0.2); Email docs to C.
Bennett for Merend on creditor website (0.2).
6/9/2011 0.30 37.50 Review and respond to email from L. Raymond for
Worldwide re: continuance of pretrial conferences.
6/9/2011 0.80 100.00 Review email from Mr. Hampson confirming no objection
to continuance Motion and requests for docs (0.2); Review
dockets and download docs for Mr. Hampson (0.4);
Follow-up email to Mr. Hampson with requested info and
docs (0.2).
6/9/2011 0.90 112.50 Review numerous emails from I. Reich re: Amended
Motion for Sale (0.5); Assist A. Srour and e-file Amended
Motion for Sale of Glory Hole Mining Properties (0.4).
6/9/2011 0.80 100.00 Discuss draft of Motion for Continuance of Sale Motion
and pretrial conferences with N. Nicole (0.3); Email
previously filed Motion to N. Nicole (0.1); Follow-up
emails to N. Nicole re: same (0.2); Discuss same with M.
Lessne (0.2).

6/10/2011 0.90 112.50 Follow-up with C. Bennett re: documents on creditor
website (0.2); Emails and teleconferences with I. Reich re:
Agreed Motion to continue hearing on sale motion and
pretrial conferences (0.4); Review response emails from
interested parties re: no obj ection to continuance of
hearing (0.3).
6/14/2011 0.20 25.00 Review and reply to email from C. Hark re: removal from
distribution list.
6/14/2011 2.50 312.50 Review finalized Agreed Motion and proposed Order to
Continue Amended Sale Motion and Pre-trial Conferences
for M. Lessne (0.5); Emails and teleconferences with M.
Lessne re: same (0.4); Draft and send follow-up email to
interested parties re: potent ial dates for continued hearing
in July (0.3); Prepare and e-file Agreed Motion in main
case (0.3) and both adversary cases (0.6); Upload Orders in
all cases (0.3) and email receipts to I. Reich and M. Lessne
(0.1).
6/15/2011 1.80 225.00 Discuss continued Motions and proposed Orders filed in
main and adversary cases with M. Lessne (0.4); Draft
separate Orders for same (0.9) and review same with M.
Lessne (0.2); Prepare and upload finalized Orders to the
court (0.3).
6/16/2011 1.00 125.00 Review dockets and our three Orders entered by the court
(0.3); Discuss with A. Srour re: scheduling of new calendar
dates and pretrial deadlines (0.4); Attention to matters re:
same (0.3).
6/17/2011 0.30 37.50 Discuss 2011 Real Property Notices of Valuation- Gilpin
County with I. Reich.
6/20/2011 0.60 75.00 Review email from C. Hinks re: Gary Sorenson and Milo
Brost (0.2); Forward same to M. Lessne and I. Reich (0.1);
Reply to C. Hinks re: same (0.1); Review email from M.
Lessne to S. Doyle re: Compliance with Article IX (0.2).
6/20/2011 0.70 87.50 Discuss 2011 Real Property Notice of Valuation- Gilpin
County with M. Lessne (0.3); Prepare scanning docs re:
same (0.2); Emails re: same to S. Doyle (0.2).
6/21/2011 0.30 37.50 Review emails re: Dunn v. Clearwater with I. Reich
6/30/2011 0.30 37.50 Discuss management of creditor website with M. Lessne

(0.2); Review emails from M. Lessne to C. Bennett re:
same (0.1).
6/30/2011 0.20 25.00 Review email from I. Reich re: creditor requesting link to
Merendon website (0.1); Send email to creditor with link
(0.1).
6/30/2011 0.80 100.00 Review I. Reich's email re: Asset Purchase Agreement
(0.1); Retrieve requested documents (0.3); Draft and send
requested documents to David Murray per I. Reich re:
Amended Sale Motion and Asset Purchase Agreement
(0.2); Review emails from I. Reich an d D. Murray re:
conference call to discuss matters re: sale (0.2).
7/6/2011 0.30 37.50 Assist A. Srour with mailing list for adv case Dunn v.
Clearwater.
7/6/2011 0.10 12.50 Discuss update of GrayRobinson's creditor website with A.

Srour.

7/11/2011 0.70 87.50 Teleconference with L. Raymond from R. Meacham's
office re: Sale hearing and past deadline for interested
parties to have a meeting regarding a pretrial stipulation
(0.3); Follow-up email and meeting with M. Lessne re:
same (0.4).
7/12/2011 1.40 175.00 Discuss Dunn v. Clearwater case with M. Lessne (0.3);
Review docket and pull complaint, amended complaints,
cross-claims and answers filed and provide same to M.
Lessne (0.6); Discuss upcoming Sale hearing with M.
Lessne re: same (0.3); Contact R. Me acham's office and
confirm conference call (0.2).
7/12/2011 0.40 50.00 Discuss adversary case re: Kemper and Dagget with M.
Lessne.
7/13/2011 0.40 50.00 Review email from M. Lessne re: Motion for Default and
pretrial (0.1); Draft Motion for Default in Dunn v.
Clearwater (0.2); Review and respond to email from I.
Reich re: same (0.1).
7/15/2011 1.00 125.00 Check online public records and files for docs filed in
Gilpin County for M. Lessne.
7/15/2011 0.50 62.50 Emails and teleconference with I. Reich and M. Lessne re:
Sale hearing and pretrial hearings.
7/19/2011 3.10 387.50 Teleconference and meeting with M. Lessne re: Sale
hearing and pretrial conferences set for 7/21 (0.5); Prepare
for same (2.6).
7/20/2011 6.30 787.50 Continue preparing for 7/21 Sale hearing and pretrial
conferences in both adversary cases.
7/21/2011 3.50 437.50 Continue assisting I. Reich and M. Lessne for preparation
of Sale hearing and pretrial conferences for both adversary
cases.
7/21/2011 4.00 500.00 Travel to and from court and assist I. Reich and M. Lessne
at Sale hearing and pretrial conferences.
7/26/2011 1.60 200.00 Review main docket and both adversary cases for Orders
(0.3); Emails to A. Srour re: same (0.2); Draft certificate of
service for Order denying amended Sale Motion and
Orders continuing 7/21 pretrial conference for both
adversary cases (0.4); Email s ame to I. Reich for review
(0.1); E-file all certificates of services (0.5); Email filing
receipts of same to I. Reich and M. Lessne (0.1).
7/27/2011 1.00 125.00 Search documents and correspondence from Norman Frank
re: evidence of his equipment (0.8); Provide same to M.
Lessne (0.1); Email Norman Frank's objection to the Sale
Motion filed on 10/21/2010 to S. Doyle (0.1).
8/1/2011 0.80 100.00 Review and respond to email from I. Reich re: installment
land sales contract with Discovery Day (0.2); Check files
for same (0.6).
8/2/2011 0.60 75.00 Revise, prepare and e-file Motion to Approve the Sale of
Bueno and Black Rose mining properties (0.5); Email
filing receipt of same to I. Reich and M. Lessne (0.1).

8/3/2011 4.60 575.00 Call and leave message for courtroom deputy Barbara re:
hearing to be set for Motion for Sale of Property of the
Bueno and Black Rose Mining Properties (0.2); Follow-
ups with I. Reich and A. Srour re: same (0.4); Review
Notice of Hearing set for 8/17 on Motion for Sale of
Property of the Bueno and Black Rose Mining Properties
(0.1); Review docket and Notice of Hearing set for 8/17 on
Motion to Request Judicial Notice of the Judgment Entered
by the Clerk of the Gilpin County Colorado State Court in
the Cleawater adversary case (0.2); Follow-up with I. Reich
and court re: conflicting date for same (0.3); Discuss draft
for Motion to Continue hearing with I. Reich and N. Nicole
(0.2); Emails and teleconference with N. Nicole re: other
cases con flicting with 8/17 hearing in main and adversary
case (0.4); Review and discuss N. Nicole's drafts of Motion
to Continue in main and adversary case with M. Lessne
(0.4); Draft Certificate of Service on Amended Sale Motion
re Bueno and Black Rose (0.2 ); Prepare and e-file same
with the court (0.2); Email filing receipt of same to I. Reich
and M. Lessne (0.1); Revise and finalize Motions and
Orders to continue 8/17 hearing in the main and adversary
case (0.8); Prepare and e-file Motion to Continue and
proposed Orders in the main case (0.3) and adversary case
(0.3); Email e-filing receipts for Motion to Continue in
main and adversary case to I. Reich and M. Lessne (0.2);
Upload proposed Orders in main and adversary case (0.2);
Email tracking n
8/4/2011 0.40 50.00 Search files for email from Erica Crosby, pics re: Bueno
Mine and the Notice of Intent to Explore Annual Fee
Invoice from the Colorado Division of Reclamation.
8/4/2011 0.30 37.50 Scan and email pics re: Bueno Mine and Notice of Intent to
Explore Annual Fee Invoice from the Colorado Division of
Reclamation to M. Lessne.
8/4/2011 0.20 25.00 Discuss email from Erica Crosby, pics re: Bueno Mine and
the Notice of Intent to Explore Annual Fee Invoice from
the Colorado Division of Reclamation with M. Lessne.
8/8/2011 0.60 75.00 Emails and teleconferences with court and opposing
counsel re: new dates to continue hearing in main and
adversary case.
8/9/2011 0.40 50.00 Draft certificate of service re: Order on Motion resetting
the 8/17/11 hearing (0.2); Prepare and e-file same (0.1);
Email e-filing receipt of same to I. Reich and M. Lessne
(0.1).
8/10/2011 0.70 87.50 Review ECF notification and Order Continuing hearing on
Motion for Judicial Notice in Clearwater adversary case
(0.2); Draft certificate of service re: same (0.2); Prepare
and e-file same (0.2); Email e-filing receipt of same to I.
Reich and M. Lessn e (0.1).

8/19/2011 2.90 362.50 Discuss Motion to Approve Settlement with Caldwell
Estate with I. Reich and service of same (0.3); Review draft
and revise same (0.2); Prepare and e-file Motion (0.3);
Email filing receipt to I. Reich and M. Lessne (0.1);
Coordinate service of Motion with A. Srour and follow-up
with I. Reich re: same (0.6); Discuss List of Properties for
Glory Hole not included in settlement agreement re:
Caldwell Estate with I. Reich (0.3); Search and confirm list
with I. Reich and Moffa (0.3); Draft Notice of filing
Exhibit A to Caldwell settlement agreement (0.2); Email
same to I. reich for review (0.1); Prepare and e-file Notice
(0.2); Email filing receipt of same to I. Reich (0.1); Email
filed version of Notice to Adam Katz (0.1); Email same to
C. Ben nett to upload on Merendon website (0.1).
8/22/2011 1.40 175.00 Draft certificate of service re: Notice of hearing on Motion
to Settle Caldwell Estate (0.2), Notice of Filing Exh A to
Motion to Settle Caldwell Estate (0.2), and Motion to
Settle Caldwell Estate (0.2); Email three certificates to I.
Reich for revie w (0.1); Prepare and e-file three certificates
of service with the court (0.6); Email filing receipt of same
to I. Reich (0.1).
8/25/2011 1.20 150.00 Review Objection filed by Garfinkle (0.3); Pull docket and
other pleadings for I. Reich (0.3); Draft Notice of Filing
receipt of Garfinkle's objection (0.2); Email same to I.
Reich for review (0.1); Prepare and e-file Notice (0.2);
Email same to C. B ennett to upload on Merendon website
(0.1).
9/6/2011 1.00 125.00 Several teleconferences with R. Meacham's office re:

pretrial conference scheduled on 9/19 (0.4); Follow-up
with M. Lessne and I. Reich re: same (0.4); Follow-up with
R. Meacham's office and advise continuance of 9/19
pretrial (0.2)
9/8/2011 0.50 62.50 Discuss and email draft for interested parties re:
continuance of pretrial to 9/27 to M. Lessne (0.4); Email
all interested parties re: request for continuance of pretrial
to 9/27 (0.1).
9/8/2011 0.40 50.00 Draft email to interested parties re: continuance of pretrial
to 9/27.
9/9/2011 0.30 37.50 Review and forward email to I. Reich and M. Lessne re:
Garfinkle's objection to the continuance of the pretrial
conference.
9/9/2011 7.10 887.50 Review responses/emails from interested parties re: request
for continuance of pretrial conference to 9/27 (0.6); Draft
Motions to Continue pretrial conference to 9/27 and
proposed Orders for same in both adversary cases (2.5);
Teleconference with A. Hampson re: continuance of
hearing (0.2); Follow-up with I. Reich re: same (0.3);
Teleconferences, emails with I. Reich and additional
revisions to Motions and proposed Orders for both
adversary cases (2.5); Prepare and e-file Motion to
Continue in both adversary cases (0.5); Email filing
receipt for both Motions to I. Reich and M. Lessne (0.1);
Upload both Orders to the court's website (0.2); Email
tracking numbers for both Orders to M. Lessne and I.
Reich (0.2).

9/12/2011 3.60 450.00 Retrieve and save e-filed versions of both Motions to
Continue (0.2); Email same to C. Bennett to upload on
GrayRobinson's website (0.1); Teleconference with
courtroom deputy re: both Motions of Continuance
previously filed on 9/9 and Judge's request to file
Amended Motions for same (0.2); Follow-up with I. Reich
re: same (0.3); Draft Amended Motions and proposed
Orders for both adversary cases (1.1); Review the same
with I. Reich (0.4); Revise Amended Motions and
proposed Orders (0.4); Prepare and e-file Amended
Motions and proposed Orders for both adversary cases
(0.5); Upload proposed Orders for both cases with the
court (0.2); Email tracking numbers for both Orders to M.
Lessne and I. Reich (0.1); Email e-filed versions of both
Amended Motions to C. Bennett to upload on
GrayRobinson's website (0.1).
9/13/2011 2.00 250.00 Teleconferences with I. Reich re: Orders for Amended
Motions (0.2); Follow-ups with courtroom deputy re: same
(0.3); Follow-up with I. Reich re: same (0.1); Draft and e-
file certificate of service in Dunn v. Brost re: Order to
Motion continuing pretr ial to 11/3 (0.3); Email filing
receipt of same to I. Reich and M. Lessne (0.1); Review,
prepare and e-file Trustee's Objection to Garfinkle's Claim
(0.4); Email filing receipt fo same to I. Reich and M.
Lessne (0.1); Follow-up with A. Srour re: serv ice of same
and calendar dates for same (0.5).
9/14/2011 1.30 162.50 Review Orders and calendar deadlines with A. Srour (0.5);
Draft two certificates of service for Order continuing
hearing and pretrial conference in both adversary cases
(0.4); Prepare and e-file both certificates of service (0.3);
Email filing receip ts of both certificates of service to I.
Reich and M. Lessne (0.1).
9/20/2011 0.90 112.50 Review email from I. Reich re: Joint Response to
Garfinkle's objection to Caldwell Settlement Motion and
review same (0.3); Review and respond to I. Reich's emails
re: preparation for 9/27/11 hearing (0.3); Reiew email from
M. Lessne, I. Reich and S. Doyle re: Amendment to the
Asset Purchase Agreement for Bueno & Black Rose
(0.3).
9/21/2011 1.00 125.00 Review email from I. Reich re: Asset Purchase Agreement
(0.1); Retrieve and email Mr. Baker Trustee's Amended
Motion to Approve the Sale of the Bueno and Black Rose
Mining Properties, with the Asset Purchase Agreement and
the Sale Procedures (0.2); R eview and respond to M.
Lessne's email requesting draft of the Notice of Filing the
First Amendment to the Asset purchase agreement (0.2);
Draft and email same to M. Lessne (0.3); Review emails
from S. Doyle and M. Lessne re: Amendment to Asset
purch ase agreement (0.2).

9/22/2011 8.00 1,000.00 Review and revise Joint Response to Garfinkle's Objection
to Caldwell Settlement Motion (1.0); Prepare and e-file
same with the Court (0.3); Email filing receipt to I. Reich
and M. Lessne (0.1); Serve Garfinkle and Moffa via email
and US Mail copy of Joint Response (0.4); Email courtesy
copy of same to Trustee, Fisher Auction and Mukamal
(0.1); Discuss taxes and mining properties located in Dolan
Springs, AZ with M. Lessne (0.4); Contact Tax Collector's
Office in AZ (0.4); Multiple teleconferenc es with Tax
Accessor's office in Dolan Springs, AZ re: same (0.7);
Search Tax Recorder's website re: QuitClaim deeds for
mining properties in Mohave county (0.5); Contact Tax
Recorder's office re: same (0.3); Retrieve and download
QuitClaim deeds iss ued to Merendon and Silmar of AZ for
same mining property in Mohave County (0.2); Review
files and Judgment entered in Mohave County (0.2);
Emails and teleconferences with I. Reich and M. Lessne re:
QuitClaim deeds issued to Silmar of AZ (0.4); Prepa re for
9/27/11 hearing (3.0).
9/23/2011 4.70 587.50 Continue preparing for hearing re: Motion for Sale of
Bueno and Black Rose Mining Properties and Motion for
Settlement with Caldwell Estate set for 9/27/11.
9/23/2011 1.20 150.00 Teleconference with I. Reich re: Notice of Filing Receipt of
Paul Garfinkle's Response to Trustee's Objection to Claim
No. 482 (0.2); Draft Notice of Filing Receipt of Paul
Garfinkle's Response to Trustee's Objection to Claim No.
482 and Request for Hearing on Trustee's Objection to
Claim No. 482 (0.2); Email same to I. Reich for approval
(0.1); Prepare and e-file same with the court (0.2); Email
filing receipt of same to I. Reich and M. Lessne (0.1);
Service of same via email and US Mail to Gar finkle and
Moffa (0.4).
9/26/2011 4.70 587.50 Continue preparing for 9/27/ hearing (3.6); Contact Cheryl
Bennett re: previous docs uploaded on website for 9/27
hearing (0.4); Email C. Bennett additional docs to upload
on website (0.1); Draft certificate of service for same and
email to M. Lessne for approval (0.4); Prepare and e-file
certificate of service (0.1); Email filing receipt of same to I.
Reich, M. Lessne and J. Leibner (0.1).
9/26/2011 0.30 37.50 Revise and e-file Notice of Filing First Amendment to that
certain Asset Purchase Agreement between Glory
Development Company and M. Dunn (0.2); Email filing
receipt of same to I. Reich, M. Lessne and J. Leibner
(0.1)
9/26/2011 0.50 62.50 Review and respond to email from Garfinkle confirming
9/27 hearing on Caldwell Settlement Motion (0.2); Prepare
fax cover sheet and fax copy of Notice of Filing Receipt of
Garfinkle's Response to Trustee's Objection to Claim No.
482 and Request for H earing on Trustee's Objection to
Claim No. 482 to Garfinkle (0.3).
9/27/2011 3.10 387.50 Final preparations for today's hearing.
9/28/2011 0.80 100.00 Review email and discuss outcome of 9/27 hearing with I.
Reich and next steps in case for same (0.4); Emails and
teleconference with I. Reich re: proposed Order to
approving Caldwell Settlement Motion (0.2); Revise and
upload proposed Order with the court (0.2).

9/30/2011 1.70 212.50 Review and download Order granting Caldwell Settlement
Motion (0.1); Review and respond to emails from I. Reich
re: Order (0.2); Emails of Order to Trustee, B. Mukamal,
Fisher Auction and other interested parties (0.2); Draft
certificate of service o f Order (0.2); E-file certificate of
service (0.2); Email filing receipt of same to I. Reich, M.
Lessne and J. Leibner (0.1); Discuss service mailing of
Order with A. Srour (0.2); Email service list and certificate
of service to A. Srour (0.1); Email Order to C. Bennett to
upload on GrayRobinson's website (0.1); Review Order for
calendar deadlines (0.3).
10/4/2011 4.10 512.50 Teleconference and meeting with M. Lessne re: Order
granting Amended Motion to Approve Sale with Bueno
and Black Rose (0.5); Review and revise Order of same
(0.5); Email same to M. Lessne (0.1); Draft and prepare
exhibits for Order per M. Lessne (2.0 ); Meeting with M.
Lessne and I. Reich re: same (0.5); Finalize and upload to
the court Order granting Amended Motion to Approve Sale
with Bueno and Black Rose (0.2); Draft and email all
interested parties requesting continuance of the pretrial
confe rences until after the auction set 1/4/2012 (0.3);
10/5/2011 1.30 162.50 Meeting with M. Lessne re: GrayRobinson Merendon

website (0.5); Review entered Order re: Bueno and Black
Rose and calendar deadlines for same (0.4); Discuss
service of same with M. Lessne (0.3); Email Order to C.
Bennett to upload on website (0.1).
10/5/2011 0.70 87.50 Review responses from interested parties re: request to
continue 11/3 pretrial conferences (0.3) and discuss same
with I. Reich and M. Lessne (0.4).
10/7/2011 1.60 200.00 Discuss emails and responses from interested parties re:
request for continuance of pretrial conferences with I.
Reich (0.5); Draft Motion to Continue pretrial conference
in Dunn v. Clearwater (1.0); Email same to I. Reich for
review (0.1).
10/10/2011 3.30 412.50 Revise Motion to Continue pretrial conference in Dunn v.

Clearwater and draft proposed Order for same (1.0); Draft
Motion and proposed Order to Continue pretrial
conference in Dunn v. Brost (1.0); Discuss revisions with
M. Lessne (0.3) and I. Reich ( 0.2); Revisions to both
Motions (0.3); E-file both Motions to Continue in
adversary cases Dunn v. Clearwater and Dunn v. Brost
(0.3); Email filing receipts to I. Reich and M. Lessne (0.1);
Email filed version of Motions to C. Bennett to upload on
our website (0.1).
10/11/2011 0.50 62.50 Follow-up with court re: proposed Orders to continue
pretrial conferences in both adversary cases.
10/14/2011 1.60 200.00 Review Orders continuing pretrial conferences in both

adversary cases to 12/12/11 (0.2); Follow-up with I. Reich
re: pretrial dates continued before requested date in 2012
(0.3); Calendar deadlines with A. Srour (0.3); Draft
certificates of service f or both pretrial Orders and Order
continuing hearing (0.4); E-file three certificates of service
for same (0.3); Email filing receipts of same to I. Reich and
M. Lessne (0.1).
10/27/2011 0.30 37.50 Discuss service of Sale Order re: Bueno and Balck Rose
with M. Lessne.

11/2/2011 0.50 62.50 Discuss with I. Reich and M. Lessne re: case and Order
Granting Sale of Bueno & Black Rose Miining
11/9/2011 1.40 175.00 Review service lists and dockets in main and adversary
cases and comprise list of parties who have filed Notice of
Appearances for same (1.0); Follow-up and meeting with
A. Srour re: service of Order granting Sale of Bueno and
Black Rose Mining Prope rties (0.4).
11/10/2011 0.50 62.50 Review files, deeds and title reports for the Glory Hole
property in Gilpin County & Bueno and Black Rose
properties in Boulder county (0.4); Provide same to M.
Lessne for review (0.1).
11/28/2011 0.20 25.00 Discuss service of Order granting Sale with A. Srour.
12/1/2011 1.30 162.50 Review main and adversary dockets and matrix re:
interested parties to serve Order granting Sale of Bueno
and Black Rose Mining properties (0.5); Review title
report and search addresses for other interested parties
(0.5); Draft certificate of servic e of Order re: same and
email to M. Lessne for review (0.3).
12/6/2011 0.50 62.50 Meeting with M. Lessne re: upcoming Sale Hearing for
Bueno and Black Rose Mining Properties.
12/7/2011 0.20 25.00 Prepare and e-file certificate of service re: Order approving
Sale of Bueno and Black Rose Mining Properties on the
court's docket.
12/15/2011 0.20 25.00 Review, pull and email Amended Complaint re: Dunn v.
Clearwater filed 10/19/2010 to M. Lessne.
12/16/2011 1.90 237.50 Discuss service of Sale Order with I. Reich and M. Lessne
and certificate of service of same (0.3); Review, revise and
e-file Motion for Leave to Amend Complaint on the court's
docket (0.5); Circulate filing receipt fo same to I. Reich
and M. Lessne (0.1); Review and e-file Notice of Dropping
Parties on the court's docket (0.3); Circulate filing receipt
fo same to I. Reich and M. Lessne (0.1); Discuss Second
Amended Complaint with I. Reich (0.2); Review, prepare
and e-file Second Amended Complai nt on the court's
docket (0.3); Circulate filing receipt fo same to I. Reich
and M. Lessne (0.1);
12/20/2011 0.60 75.00 Download court filed version of Motion for Leave to
Amend Complaint, Notice of Dropping Parties, Second
Amended Complaint and Order Granting Motion for Leave
to Amend Complaint (0.5); Email copy of same to C.
Bennett for GR Merendon website (0.1).
12/22/2011 0.40 50.00 Download and email Stipulation of Dismissal of U.S. as

Party Defendant and Order Dismissing U.S. from Adv
Proceeding to C. Bennett for GR Merendon website.
1/4/2012 2.00 250.00 Travel to and from 1/4/2012 hearing re: Sale of Bueno and
Black Rose mining properties.
1/4/2012 1.00 125.00 Attend 1/4/2012 hearing re: Sale of Bueno and Black Rose
mining properties.
1/5/2012 2.50 312.50 Review and update Merendon spreadsheet re: documents
and links on GrayRobinson's website set up for creditors.

1/5/2012 0.20 25.00 Save into database and email fully executed Asset Purchase
Agreement between David Badner/Badner Group Inc. and
M. Dunn to F. Santos.
1/6/2012 1.50 187.50 Pull and resend pdf documents to C. Bennett for
GrayRobinson's Merendon website.
1/9/2012 0.30 37.50 Revise Certificate of Service of Order Granting Motion for
Leave to Amend Complaint (0.1); Prepare and
electronically file the same on the court's docket (0.2).
1/9/2012 0.20 25.00 Retrieve and email Amended Motion for Sale of the Bueno
and Black Rose Mining Properties to Tong Li.
1/12/2012 0.60 75.00 Review letter received from R. Meacham's office re: Joint
Pretrial Stipulation and discuss same with I. Reich (0.3);
Review numerous emails from buyer's counsel re:
comments for draft of Order Approving Sale of Boulder
properties to Badner (0.3).
1/13/2012 0.30 37.50 Prepare and electronically file on the court's docket Initial
Disclosure per FRCP 26 in adversary case Dunn v.
Werner.
1/13/2012 0.40 50.00 Prepare and gather exhibits for proposed Order Approving
Sale of Bueno and Black Rose mining properties to Badner
(0.3); Upload proposed Order Approving Sale of Bueno
and Black Rose mining properties to Badner to court's
website (0.1).
1/18/2012 0.20 25.00 Retrieve and email exhibits to Order approving Sale of
Bueno and Black Rose to R. Meacham.
1/19/2012 0.20 25.00 Prepare and eletronically file certificate of service re: Order
Approving Sale of Bueno and Black Rose mining
properties on the docket.
1/19/2012 1.00 125.00 Draft email to interested parties re: request to continue pre-
trial conference set for 1/23 to beyond 2/8 (0.9); Email
same to all interested parties (0.1).
1/23/2012 0.20 25.00 Retrieve and email Sub Con Order to Tong Li.
1/23/2012 0.70 87.50 Search for tax collector files re: Boulder county for M.
Lessne.
1/23/2012 0.40 50.00 Prepare and electronically file on court's docket two
certificates of service re: Order continuing pre-trial
conferences in both adversary cases.
1/23/2012 1.00 125.00 Search files and email J. Bahnsen the tax assessor's map re:
Boulder County, Inspection Report of the Bueno Mines
and title search reports of same.
1/24/2012 1.60 200.00 Research and follow-up on title agencies in Arizona re: title
search for mining properties in Dolan Springs, AZ.
1/25/2012 0.60 75.00 Retrieve and email Trustee's Bill of Sale and Deed for the
Bueno and Black Rose mining properties to Tong Li and
Jeff Bahnsen (0.2); Follow-up with Jenny Sica and Tong Li
re: inquiries for sale and closing of Bueno and Black Rose
(0.4).
1/25/2012 0.70 87.50 Search files for copy of the contract between James Town
Development Co., LLC and Merendon Mining (Colorado)
Inc. dated as of Dec 29, 2004 requested by Tong Li (0.5);
Follow-up with T. Li via teleconference and email
confirming we don't have copy of contract (0.2).

1/27/2012 0.90 112.50 Retrieve and email Quit Claim Deed to Silmar of Arizona,
LLC recorded 1/12/10 and a Judgment recorded 8/12/09
regarding the same mining entities to M. Lessne and J.
Leibner (0.2); Search files for Sub Con Order recorded in
Mohave County, AZ for M. Le ssne and follow-up email
re: same (0.7).
1/27/2012 0.30 37.50 Follow-up with title agency in Arizona re: title search for
Dolan Springs mines.
1/30/2012 0.20 25.00 Follow-up with title search company in Arizona and advise
we no longer need their services for a title search re: Dolan
Springs mines.
2/1/2012 0.60 75.00 Review M. Lessne's email re: Discovery Day Mines in
California (0.1); Review Order approving settlement with
Trinity Alps, Discovery Day and Bowerman Holdings
(0.1); Contact Siskiyou County in California re: recording
order of same (0.4).
2/6/2012 0.70 87.50 Draft letter to Siskiyou County Recorder advising to record
enclosed Order to approve settlement with Trinity Alps,
Discovery Day (0.2); Follow-up with A. Srour re: check
request for recording fee (0.1); Print two copies of the
Order, prepare pre-sta mped self addressed envelope, and
mail package of same to Siskiyou County Recorder in
California (0.4)
2/7/2012 0.20 25.00 Retrieve and email Order granting approval of the Sale (DE
284) and Order approving the Sale (DE 287) re: Bueno and
Black Rose Mining Properties to M. Lessne.
2/15/2012 0.80 100.00 Meeting with M. Lessne re: upcoming deadlines and
Trustee's expense reimbursements to Glory Development
Company and Fisher Auction (0.4); Review previous
correspondence from Trustee and S. Doyle re: same (0.3);
Follow-up with M. Dunn re: status of ex pense
reimbursements (0.1).
2/15/2012 0.20 25.00 Follow-up with C. Bennett in the IT dept re: maintenance
of the GR's website for creditors.
2/17/2012 0.60 75.00 Discuss case and need for request to produce from Trustee
to Worldwide Rental Services Draft with M. Lessne (0.3);
Draft and email Request to Produce of same to M. Lessne
for review (0.3).
2/21/2012 0.70 87.50 Continue reviewing bill from accounting and revising
exhibits for fee app.
3/27/2012 0.30 37.50 Review executed settlement agreement with Worldwide

and assist A. Srour with calendaring deadline dates for
same.
3/30/2012 0.20 25.00 Prepare and electronically file on court's docket Trustee's
Motion to Approve Settlement with Worldwide.
3/30/2012 0.20 25.00 Scan and email D. Hramatulova draft of Trustee's Motion
to Approve Settlement with Worldwide with exhibits.

3/8/2011 0.80 100.00 Prepare and upload Agreed Order to allow late filed claim
by Collin and Sharen Latimer (0.1); Teleconferences with
Courtroom Deputy re: same and hearing to be cancelled on
3/9/11 (0.2); Email to I. Reich and M. Lessne confirming
same (0.1); Teleconfe rence with M. Lessne re: further
revisions to Agreed Order (0.1); Make revisions, upload
revised Agreed Order and teleconference with Judicial
Assistant re: same (0.3).
3/9/2011 0.50 62.50 Review Order re: Collin and Sharen Latimer to allow late
filed Claim and calendar same (0.2); Emails to I. Reich, M.
Lessne and M. Dunn re: same (0.3).
3/15/2011 0.90 112.50 Review emails from Trustee and creditor S. Taylor re:
claim (0.2); Check claims register, pull and review filed
claim (0.3); Email to M. Lessne and I. Reich re: same
(0.2); Follow-up email to creditor re: same (0.2).
4/6/2011 0.50 62.50 Review email from Trustee's office re: additional inquiry
from Sandra Taylor (0.1); Follow-up call (0.3) and email to
Sandra Taylor re: proof of claim filed with the court on
10/26/2009 (0.1).
6/17/2011 1.00 125.00 Review emails from I. Reich and C. Hinks re: proof of
claim filed (0.3); Check claims register re: same (0.3);
Email filed claim info to I. Reich (0.1); Download filed
claim (0.1); Email creditor website and filed claim to C.
Hinks (0.2).
12/8/2011 0.30 37.50 Follow-up with I. Reich re: First and Final Fee
Application.
12/8/2011 3.50 437.50 Review bill and start drafting summary for First and Final
Fee Application.
12/9/2011 2.30 287.50 Continue drafting summary for First and Final Fee
Application and review of bill.
12/13/2011 0.50 62.50 Discuss First and Final Fee Application with I. Reich.
12/14/2011 5.00 625.00 Continue working on summary for First and Final Fee
Application, reviewing bill and draft exhibit charts for
same.
12/15/2011 1.50 187.50 Continue working on Fee Application.
12/20/2011 2.00 250.00 Continue working on Fee Application.
12/21/2011 5.10 637.50 Continue working on draft of Fee Application and exhibits
for same (5.0); Email same to I. Reich for review (0.1).
2/20/2012 1.00 125.00 Contact accounting for updated bill re: fees and expenses
and work on revising draft of fee app for same.
2/22/2012 2.50 312.50 Continue updating exhibits for fee application to include
fees and costs through January 31, 2012.

3/2/2011 0.80 100.00 Emails and teleconferences with M. Lessne and I. Reich re:
Motion and Order to continue the Pretrial Conferences and
all related deadlines regarding same.
3/2/2011 0.50 62.50 Meeting with M. Lessne re: files and production of docs.
3/3/2011 3.50 437.50 Review emails/electronic & hard files for discovery
request.
3/4/2011 4.20 525.00 Continue reviewing and cataloging files re: discovery
request.
3/8/2011 3.10 387.50 Continue reviewing files for document production.
3/9/2011 1.20 150.00 Continue reviewing files and assist M. Lessne re: discovery
request.
3/10/2011 1.00 125.00 Meeting with M. Lessne re: pretrial and trial deadlines and
upcoming discovery (0.6); Contact R. Meacham's office re:
extension for discovery request (0.2); Follow-up with M.
Lessne re: same (0.2).
3/14/2011 0.30 37.50 Follow-up with R. Meacham's assistant re: additional

extension to 4/12 to respond to discovery request (0.2);
Email same to M. Lessne confirming extension (0.1).
3/15/2011 0.40 50.00 Discuss production of documents and files with M. Lessne
(0.3); Email list re: same (0.1).
3/16/2011 2.00 250.00 Assist M. Lessne with production of documents.
3/17/2011 0.70 87.50 Emails (0.3) and teleconferences with M. Lessne and I.
Reich re: Response to Request for Production of
documents (0.4).
4/12/2011 1.30 162.50 Teleconferences with R. Meacham's office re: outstanding

discovery and continued pretrial conference (0.4); Follow-
up and discuss same with M. Lessne (0.3); Assist M.
Lessne with matters re: discovery due and pretrial
stipulation (0.6).
4/13/2011 0.50 62.50 Follow-up with L. Bobrow and L. Raymond and email
them the Trustee's Response to Worldwide's request for
production of documents and responsive documents (0.2);
Follow-up with M. Lessne re: responsive documents
(0.3).
4/19/2011 0.30 37.50 Meeting with M. Lessne re: Agreed Motion to continue
4/26 hearing and pretrial conferences.
4/19/2011 1.30 162.50 Draft and finalize Agreed Motion and proposed order to
continue 4/26 hearing and pretrial conferences (1.1), and
email same to M. Lessne (0.1); Revise certificate of service
re: Order granting Motion continuing to 4/26 and email
same to M. Lessne (0. 1).
4/25/2011 0.20 25.00 Teleconference with L. Raymond at R. Meacham's office

re: responsive non-electronic discovery documents for
Worldwide Rental (0.2)
5/17/2011 0.70 87.50 Emails and teleconferences with M. Lessne and N. Nicole
re: response to Worldwide Rental's request to produce and
responsive documents.
5/19/2011 0.40 50.00 Review email from N. Nicole re: Worldwide Rental (0.1);
Follow-up with M. Lessne re: same (0.3).

5/23/2011 1.60 200.00 Emails with N. Nicole re: Worldwide Rental (0.2); Meeting
with N. Nicole re: responsive documents for Worldwide
Rental (1.4).
6/1/2011 0.40 50.00 Emails and teleconferences with N. Nicole re: production
of documents to Worldwide.
6/3/2011 0.90 112.50 Emails and teleconferences with N. Nicole re: documents
to produce to Worldwide (0.5); File management re: same
(0.4)
6/6/2011 0.40 50.00 Review emails and files from N. Nicole re: production of
docs to Worldwide.
6/8/2011 0.40 50.00 Emails and tc's with N. Nicole and M. Lessne re:
production docs.
6/15/2011 0.40 50.00 Follow-up with N. Nicole re: Worldwide.
6/16/2011 0.50 62.50 Attention to matters re: doc production for Worldwide
(0.3); Review emails re: same (0.2).
12/9/2011 1.30 162.50 Prepare Second Amended Complaint for M. Lessne.
12/15/2011 0.30 37.50 Discuss next steps in case re: dropping parties in Dunn v.
Clearwater with M. Lessne.
12/20/2011 0.10 12.50 Draft COS re: Order Granting Motion for Leave to Amend
Complaint (0.1);
1/9/2012 0.40 50.00 Review Expert Witness Report and draft Notice of Filing
same (0.3); Email draft of same to I. Reich for review
(0.1).
1/20/2012 0.50 62.50 Numerous teleconferences with the court re: e-filed
Motions to Continue 1/23 pretrial conferences in both
adversary proceedings.
1/20/2012 2.50 312.50 Draft Motions and proposed Orders to Continue 1/23
pretrial conferences in both adversary proceedings (1.5);
Revise same (0.4); Prepare and electronically file on
court's docket Motion to Continue 1/23 pretrial
conferences in both adversary proceed ings (0.4); Upload
proposed Orders for both cases to the court's website
(0.2).
1/20/2012 0.40 50.00 Teleconference and follow-up email with Mr. Hampson re:
continuance of pre-trial conferences and status of main
case.
1/23/2012 0.20 25.00 Follow-up and teleconference with court confirming

continuance of pre-trial conferences in both adversary
cases.
1/23/2012 0.40 50.00 Draft two certificates of service re: Order continuing pre-
trial conferences in both adversary cases.
Total for Timekeeper Serrano-Cartagena 229.60 $28,700.00

Solomon, Steven
6/16/2009 1.20 468.00 Strategy meeting with B. Elam and others.
6/19/2009 4.50 1,755.00 All hands strategy meeting with M. Dunn, J. Ryan, R.
Schatzman, S. Khanakol, M. Berger, P. Garfinkel, R.
Hincock.
6/22/2009 1.20 468.00 Review e-mail from P. Garfinkel and others regarding
meeting, documents, assets (.3); begin research regarding
same (.9)
6/30/2009 1.80 702.00 Finalize motion and order regarding extension to file
schedules and other documents (1.4); memo regarding
follow-up for same (.4)
7/1/2009 0.20 78.00 Review memos concerning bank accounts.
7/7/2009 1.00 390.00 Review memo from S. Khanorkar and analysis of bank
accounts.
7/17/2009 0.40 156.00 Conference with R. Schatzman regarding P. Garfinkle, veil

piercing, documents from bank.
7/22/2009 0.20 78.00 Conference with R. Schatzman regarding gathering

information from P. Garkinkle.
7/21/2009 0.30 117.00 Review memos regarding status of meetings and

conference with R. Schatzman regarding P. Garfinkle.
7/13/2009 0.20 78.00 Review T. Cash's proposal.
Total for Timekeeper Solomon, Steven 11.00 $4,290.00

Stirling, Susan
6/9/2010 1.00 125.00 Draft motions for contempt and for sanctions
8/12/2010 1.00 125.00 Review bids for title work (.4); assist with revising letter of
intent (.3); correspond with M. Morrison re: Wabuska
Mines (.3)
7/27/2010 1.10 137.50 Research title companies in Colorado for assistance with
determining land claims and mining rights
7/28/2010 3.60 450.00 Discussions with title search mining rights companies in
Colorado regarding preparing ownership and
encumbrances report (2.7); furnish information regarding
mines to potential title companies (.4); prepare
memorandum regarding same to attorneys (.5)
7/29/2010 3.90 487.50 Meet with attorneys to develop 363 sale motion and
hearing and proper notice guidelines (2.3); conferences
with title companies to determine what is needed to perfect
notice (.5); prepare memorandum to attorneys regarding
same (.6); organize document s from lawyers Davies and
Pappas regarding filed claims against Merendon Mining
(.5)
7/30/2010 1.40 175.00 Conference with various Colorado title companies to

obtain information about process of providing notice to all
claimants regarding sale of mine (.6); prepare
memorandum to attorneys regarding same (.8)
8/4/2010 1.50 187.50 Telephone calls to title companies and law firms in
Colorado to locate company willing to do mining claims
title research(.6); prepare correspondence to same (.3);
follow up with sale of equipment motion for approval
(.6)
8/5/2010 1.70 212.50 Conference L. Blanco regarding Colorado connections for

title work (.3); telephone conference with additional title
companies for work on titles to mine claims (1.1); prepare
letter to law firm in Colorado to secure title searches (.3)
8/6/2010 4.20 525.00 Continue to develop service list (1.1); telephone

conferences with title servicers in Colorado to find source
for title work on mining claims (.50; work on equipment
sale (2.6)
8/9/2010 2.60 325.00 Assist with revising Letter of Intent (.5); organize and
catalog Gloria Management and Glory Hole mine
documents (1.1); continue to revise complaint to add
parties to receive notice (1.0)
8/10/2010 0.90 112.50 Revise motion to sell assets (.3); obtain information from
Colorado title companies to assist us in pursuing buyer
(.3); organize documents regarding mines into separate
binders (.3)
8/12/2010 0.50 62.50 Continue to prepare notebook of all documents received to

date to be used for 363 Sale

8/13/2010 2.60 325.00 Assist with equipment sale and or motion for approval (.4);
research auction dates (.5); research water rights and cost
of obtaining title to water rights (.5); update fees (.3);
provide information to F. Santos for his auction (.4);
continue to prep are notebooks with documents applicable
to 363 Sale (.5)
8/16/2010 1.50 187.50 Organize and continue to create and maintain database of
any title holders or claimants for motion to sell notice
8/17/2010 1.50 187.50 Add names to 363 Sale Complaint (.4); telephone call with
Bonnie and Norm Frank regarding evidencing ownership
of equipment (.3); review of correspondence from L.
Weltzer regarding water rights to mines (.3); telephone call
with Paul Garfinkle re: sa me (.5)
8/25/2010 0.80 100.00 Assist with developing means of identifying and locating
all potential defendants (.5); telephone call with L.
Weltzer's office regarding status of search (.3)
9/3/2010 1.90 237.50 Prepare certificate of service for motion for sale on
expedited basis (.3); research addresses for entities and
people who have laid claim to mines (1.2); revise letter of
intent (.4)
9/7/2010 2.40 300.00 Assist attorneys with filing and preparing 363 sale motion
(.8); review files for Sentinel Deeds (1.0); correspond with
Paul Garfinkle regarding same (.3); correspond with L.
Weltzer re title work for Gilpin County (.3).
9/14/2010 2.40 300.00 Review of title search/report from L. Weltzer regarding

Gilpin County properties (.8); review of files for
Clearwater Mining lawsuit and caption information (.9);
prepare memo to attorneys regarding results of search
(.7)
9/15/2010 4.70 587.50 Continue to review second title search for Gilpin County,
and formulate new caption for adversary complaint (4.3);
formulate new certificate of service for motion and
complaint to be served (.4)
9/16/2010 3.10 387.50 Gather exhibits for Adversary Complaint (1.1); modify
service list against two title searches (1.2); eliminate
duplicate names (.8)
9/17/2010 3.90 487.50 Amend Complaint to add and take out names of potential
defendants (1.2); research on internet addresses for names
from Title Searches (1.5); prepare amended service list
(1.2)
9/20/2010 4.80 600.00 Continue to edit, add, revise and refine adversary
complaint and service list
9/21/2010 4.40 550.00 Further revisions to Adversary Complaint (1.8); draft

motion to defer filing fees (1.1); revise service list with
additional information from research on companies and
individuals without addresses (.6); research waiving fees
for trustees (.9)
9/24/2010 2.30 287.50 Revise complaint (1.0); prepare service list in alpha order
(.6); amend sale motion in accordance with lack of buyer
for property (.7)
9/29/2010 4.80 600.00 Revise, amend defendants and upload and file adversary
complaint (4.3); telephone conferences with bankruptcy
clerk for instructions of same (.5)

10/1/2010 1.80 225.00 Prepare comprehensive pleadings file for new adverse
matter (1.3); telephone call with bankruptcy clerk for Judge
Cristol regarding defendants and ability to track defaults,
etc. (.5)
10/4/2010 1.30 162.50 Review of summons and court's notice of hearing (.3);
coordinate with clerk of court for service of adversary
complaint (1.0)
10/12/2010 2.10 262.50 Revise Amended Adverary Complaint
10/13/2010 0.50 62.50 Manage calls and information requests from third parties
regarding sale motion filed
10/14/2010 1.00 125.00 Correct sale date and sale motion allegations (.5); cross
reference prior exhibits and revise mailing matrix (.5)
10/20/2010 1.30 162.50 Review of attachments to amended adversary complaint to

comply with requests from various claimants
11/8/2010 0.60 75.00 Review of recently filed pleadings in opposition to our

motion for sale (.3); assist with preparing responses (.3)
11/10/2010 0.30 37.50 Review of objections to sale and process
12/2/2010 0.80 100.00 Assist with providing information to potential interested

parties
4/15/2010 1.20 150.00 Assist with docketing, calendaring and providing notice to
all parties regarding new pretrial date and new pretrial
order.
4/19/2010 0.90 112.50 Develop chart of foreign defendants and determine status
of service of same; telephone call to Cliff Hark regarding
addresses and to seek compliance with court order.
4/22/2010 0.20 25.00 Continue to investigate addresses to serve foreign

entities.
4/27/2010 0.90 112.50 Review of documents from Miami office to being

inventory and document database.
5/3/2010 3.10 387.50 Continue investigation of current and active addresses and
points of contact for Merendon companies doing business
in Central America (2.0); numerous telephone calls to US
Embassies and local consulate offices for information on
corporate registry fo r Merendon (1.1)
5/4/2010 1.80 225.00 Modify interrogatories to foreign entities for information

relevant to us being able to attain service (.7); discussions
with attorney regarding same (.8); telephone calls to Mr.
Hark and Mr. Yon regarding their client's current
information (.3)
6/14/2010 0.30 37.50 Follow up with Mr. Brodsky on discovery responses (.2);
review of SEC filing for new information on service of
defendants (.1)
8/12/2010 0.40 50.00 Assist with posting Order on website (.2); review of Order
(.1); update client with recent Order (.1)
1/18/2011 1.40 175.00 Assist with moving out deadlines for motion responses and
sale procedures

8/12/2010 0.50 62.50 Telephone calls from claimants regarding status of claims
(.5)
1/5/2011 0.80 100.00 Assist attorneys in responding to callers about filing late
proofs of claim
7/8/2010 0.70 87.50 Begin drafting first interim fee application
7/9/2010 2.40 300.00 Revise draft of application for approval of interim fees
(1.0); begin reviewing prebill and reports from accounting
(1.4)
7/21/2010 1.90 237.50 Begin draft of fees and costs for first interim application
for approval
7/22/2010 1.30 162.50 Compare prebill, activity reports and costs to numbers in
first interim fee application
7/23/2010 1.40 175.00 Continue to develop first interim fee application (.6);
clarify time entries and task codes corrected (.8)
7/26/2010 4.50 562.50 Continue to formulate first interim fee application numbers
and task codes (4.1); conference with attorney I. Reich to
confirm details (.4)
7/27/2010 0.90 112.50 Corrections to first interim fee application (.7);

correspondence regarding fee application to associated
accountants (.2)
9/7/2010 1.80 225.00 Begin revising fee application
9/8/2010 3.60 450.00 Prepare amended fee and cost application to file with court
for pre approval of our compensation
9/9/2010 0.90 112.50 Review of local rules to ensure that fee application meets
all guidelines and rules (.4); revise application with new
dates of time period requested and continue to revise
number of hours (.5)
4/20/2010 0.50 62.50 Attempts to locate addresses for foreign defendants to serve
process, telephone call again to Cliff Hark for same
information.
5/5/2010 2.40 300.00 Finalize and get out interrogatories to Mr. Hark and Mr.
Brodsky regarding their foreign entity clients' addresses
and agents information (7 sets in total) (1.8); respond to
email from Mr. Brodsky regarding same (.2); review
responses from US Embassy and Consulate's offices in
Belize and Honduras and make additional attempts to find
information regarding Merendon's current registered agent
(.4)

5/6/2010 0.30 37.50 Continue to monitor responses from foreign embassies
regarding information on Merendon Mining.
5/12/2010 1.40 175.00 Continue attempts to confirm address and agent

information for Merendon in Peru and Venezuela (.6);
reach out to US Embassy in both countries for assistance
(.3); draft motion to compel to Whitelock for identification
of accounts held by Federated an d production of records
for all documents requested in our subpoena (.5)
5/14/2010 0.20 25.00 Review responses from US Embassy in Peru regarding

Merendon's address and information.
5/17/2010 0.50 62.50 Update attorneys on status of service of foreign defendants

represented by Mr. Hark and Mr. Yon (.1); telephone
conference with Mr. Yon as to whereabouts of addresses
(.2); prepare memorandum to attorneys with response from
Mr. Yon (.2)
6/7/2010 0.50 62.50 Telephone conferences with Cliff Hark and Richard
Brodsky regarding discovery responses (.3); prepare
memorandum to attorneys regarding same (.2)
6/9/2010 1.80 225.00 Pull all Order requiring foreign defendants and Sorenson
defendants to provide information or to perform tasks (.4);
assist attorney with drafting motions to compel (1.4)
6/10/2010 1.90 237.50 Assist with preparing and finalizing motion to compel to
two defendants (1.4); review of all orders concerning
disclosure of information and provide same to attorneys
(.5)
6/11/2010 1.20 150.00 Prepare exhibits for filing with motion to compel (.9);
upload and file motion with court and electronically send
to affected parties (.3)
8/2/2010 0.70 87.50 Prepare draft of motion to approve sale of equipment
8/12/2010 0.50 62.50 Revise complaint with new names
8/16/2010 0.30 37.50 Conference with P. Garfinkle regarding water rights and
ownership (.3)
10/14/2010 0.90 112.50 Revise and amend adversary complaint to add parties
(.9)
11/10/2010 0.20 25.00 Review of pleadings to see if service perfected on Estate of

Robert Barnes (.1); review of request from Patricia Stearns
(.1)
11/11/2010 0.40 50.00 Prepare information for response to Patricia Redmond's

inquiry about lack of service and notice of hearing
11/16/2010 0.60 75.00 Obtain information for attorney for G. Grieve regarding
title search (.3); conference with L. Weltzer regarding same
(.3)
11/24/2010 0.50 62.50 Upload and file motion to dismiss counterclaim
12/3/2010 0.80 100.00 Assist with preparing certificate of mailing notice of

withdrawal
12/7/2010 0.60 75.00 Review of counterclaim (.3); calendar deadline to respond

(.3)
1/10/2011 1.20 150.00 Process recently received Orders and discovery requests
and assist with moving deadlines out

1/13/2011 0.90 112.50 Process discovery from defendants (.4); work on getting
extensions (.5)
1/19/2011 2.20 275.00 Assist with providing title search results to attorneys
calling about why they are being named in lawsuit (1.4);
contact all attorney involved to see if they will agree to
move out deadlines another month (.8)
1/20/2011 2.80 350.00 Upload Orders in all cases to continue deadlines and push
out pretrials (.5); survey responses from all parties in three
cases to see if any objections (1.2); process newly filed
adversary proceeding (1.1)
2/4/2011 2.60 325.00 Revive efforts to obtain service on foreign defendants (.9);
review of all attempts to serve and prepare appropriate
filings with court (1.7)
2/7/2011 0.50 62.50 Telephone conference with clerk of court for alias
summons to certain foreign defendants
2/9/2011 5.30 662.50 Prepare attorney for telephone conference with Mr. Sakalo
(1.1); prepare alias summons (1.3); review of entire
dockets in all three cases for any unresolved attempts at
service of all defendants to make sure everyone aware of
upcoming pretrials (2.9)
2/10/2011 0.70 87.50 Assist with preparing alias summons (.3); conference with
clerk (.2); prepare certificate of mailing for foreign
defendants (.2)
2/10/2011 0.50 62.50 Field phone calls from investors and other seeking
information for tax purposes
Total for Timekeeper Stirling, Susan 138.00 $17,250.00

Terzo, Frank
6/8/2009 1.00 450.00 Discussion and conference with B. Elam regarding on

Status of an entry of an Order for Relief in the Involuntary
Action and Concerns by the petitioning creditors to use
GrayRobinson as general Counsel for the Trustee
6/10/2009 1.50 675.00 Conference with I. Reich , B. Elam and forwarded e-mails
to M. Dunn regarding representation as general counsel to
the Trustee and conference call with B. Mukamal to be
engaged to do forensic work
6/11/2009 1.00 450.00 E-mail correspondence and response to Pat Scott regarding
standing issues
6/11/2009 1.00 450.00 Conference Call with I. Reich & David Cimo regarding
taking up General Representation through M. Dunn
6/12/2009 2.30 1,035.00 Conference call with B. Elam, I. Reich , Bob Schatzman,
B. Mukamal and Morris Berger
6/16/2009 0.40 180.00 Conference call with R. Schatzman regarding the status of
the case.
6/22/2009 1.40 630.00 Review of all e-mails pertaining to the Status of the
Discovery that need to be made in order to recover assets
6/23/2009 0.80 360.00 Conference Call with R. Schatzman on Harry Gurwitzh
6/29/2009 1.00 450.00 Review of various E-mails concerning the current status of
Discovery of Assets
7/27/2009 1.70 765.00 Meeting with R. Schatzman regarding current status of

investigation.
8/14/2009 1.80 810.00 Conference with B. Mukamal regarding the forensic

analysis being performed on Merendon Mining and
whether the forensic analysis has demonstrated recoverable
avoidance actions.
Total for Timekeeper Terzo, Frank 13.90 $6,255.00

Wagner, Paige
12/8/2009 4.50 675.00 Begin to draft Motion by Chapter 7 Trustee for Substantive
Consolidation of Non-Debtor Entities, Turnover of
Property of the Estate, and Injunctive Relief.
12/9/2009 4.40 660.00 Continue to draft Motion by Chapter 7 Trustee for

Substantive Consolidation of Non-Debtor Entities,
Turnover of Property of the Estate, and Injunctive Relief.
(4.3). Draft e-mail to I. Reich with attached Motion for
review. (0.1).
12/14/2009 3.90 585.00 Research case law re:motion for turnover of property of the
estate and standard for injunctive relief. (1.0). Revise
Motion by Chapter 7 Trustee for Substantive Consolidation
of Non-Debtor Entities, Turnover of Property of the Estate,
and Injunctiv e Relief. (2.8). Draft e-mail to I. Reich with
attached Motion for review. (0.1).
1/8/2010 5.60 840.00 Telephone correspondence with I. Reich re:drafting Order

Granting Motion for Substantive Consolidation of Non-
Debtor Entities, Turnover of Property of the Estate, and
Injunctive Relief. (0.3). Draft Order. (5.3).
11/13/2009 5.50 825.00 Review bankruptcy pleadings, schedules, and Affidavit of

Paul Garfinkle in preparation of drafting Adversary
Complaint. (2.5) Begin to draft Adversary Complaint.
(3.0).
11/16/2009 6.00 900.00 Continue to draft Adversary Complaint.
11/17/2009 3.80 570.00 Finalize drafting Adversary Complaint. (1.0). Review,

edit, and revise same. (2.8).
12/1/2009 0.50 75.00 Telephone correspondence with I. Reich re:revisions to

Adversary Complaint.
12/10/2009 4.50 675.00 Revise Adversary Complaint with comments from I. Reich,
R. Shatzman, and S. Khanorkar.
12/11/2009 2.80 420.00 Continue to revise Adversary Complaint.
Total for Timekeeper Wagner, Paige 41.50 $6,225.00

Wegel, Kirsten
2/2/2010 2.00 220.00 Prepare Suggestions of Bankruptcy
3/23/2010 3.00 330.00 Record Orders in other jurisdictions.
3/26/2010 2.00 220.00 Prepare and send out Orders to be Recorded in various
jurisdictions.
2/23/2010 1.50 165.00 Obtain recording information to record Order Granting

Motion by Chapter 7 Trustee For Substantive
Consolidation of Non-Debtor Entities in four separate
jurisdictions.
2/25/2010 1.50 165.00 Prepare recording transmittals and orders to be recorded in

various jurisdictions.
2/26/2010 3.50 385.00 Prepare Orders to be sent and recorded in various

jurisdictions;
Total for Timekeeper Wegel, Kirsten 13.50 $1,485.00

2351.80 $716,885.00

Dunn-De 296 GrayRobinson First Interim Fee App

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Case 09-11958-AJC Doc 296 Filed 05/22/12 Page 1 of 15

UNITED STATES BANKRUPTCY COURT

In re: Case No. 09-11958-BKC-AJC

MERENDON MINING (Nevada), INC.

FIRST INTERIM FEE APPLICATION FOR ALLOWANCE AND PAYMENT OF

1. Name of Applicant: GrayRobinson, P.A.

2. Role of Applicant: Counsel to Marcia Dunn, Chapter 7 Trustee

3. Name of Certifying Professional Ivan J. Reich, Esq.

4. Date case filed: February 4, 2009

5. Date of application for employment: June 16, 2009 [DE #32]

7. If debtor's counsel, date of Disclosure of N/A

8. Date of this application: May 22, 2012

10. If case is chapter 7, amount trustee has on $1,216,188.32

14. Net amount of fee requested for this period: $716,885.00

16. Balance remaining in expense retainer account as of the Petition $0.00

History of Fees and Expenses

1. Dates, sources, and amounts of retainers received: N/A

Dates: Sources: Amounts: For fees or costs?

2. Dates, sources, and amounts of third party payments received: N/A

Dates: Sources: Amounts: For fees or costs?

3. Prior fee and expense awards...

Dates covered by First Invoice:

Amount of fees requested:

Amount of expenses requested:

Amount of fees invoiced (80% of fees

Amount of expenses invoiced (no

Amount of fees applied against the

Amount of expenses applied against

Fees paid by Debtor, net of retainer:

Expenses paid by Debtor, net of

Date of application of retainer:

Portion of fees requested but not

Portion of expenses requested but not

UNITED STATES BANKRUPTCY COURT

In re: Case No. 09-11958-BKC-AJC

MERENDON MINING (Nevada), INC.

SUMMARY OF FIRST INTERIM FEE APPLICATION OF GRAYROBINSON, P.A., AS

GRAYROBINSON, P.A., (AApplicant@) counsel to the Chapter 7 Trustee (the ATrustee@),

Exhibits A1-A@ and A1-B@- Summary of Professional and Paraprofessional Time.

Exhibit "2" - Summary of Requested Reimbursements of Expenses.

Corp. of America, 544 F.2d 1291 (5th Cir. 1977), as follows:

tunc to June 11, 2009 (D.E. 34).

bankruptcy estate to claimants.

respective Canadian and American estates can afford to do so.

In addition, we have been working with representatives from the Environmental

estate had already been cleaned up by the EPA pre petition.

criminal investigations against them.

in South and Central America.

those mining rights to lapse and revert back to those governments.

The Discovery Day Mine Recovery

The Glory Hole Mine Recovery

mine from Caldwell after he had been divested of his ownership.

we had for all the Colorado mines.

for the various mining interests.

to the Glory Hole mine.

The Boulder County Mines Recovery

Worldwide Machinery, Inc. (“Worldwide”) as a result of a post-petition, but pre-substantive

but more difficult, extraterritorial recoveries, or sale of those rights.

the estate has proven to be elusive.

Time Limitations Imposed by the Client or Other Circumstances: No specific time

compensation for its services.

The Experience, Reputation, and Ability of the Professional: Applicant, is an established