FTC vs. Digital Altitude, LLC, et aldigitalaltitudereceiver.com/Images/315-1 Exhibit A.pdf ·...

EXHIBIT A

Case 2:18-cv-00729-JAK-MRW Document 315-1 Filed 08/15/19 of 48 Page ID #:7341

10100 SANTA MONICA BLVD

SUITE 2200

LOS ANGELES, CA 90067

(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS

Payment by wire or ACH, please use the following :

Payment by check, please remit to:

City National Bank

2029 Century Park East

Los Angeles, CA, 90067

ABA: 122016066

Account no: 210-034722

Beneficiary: Loeb & Loeb LLP - General Account SWIFT Code: CINAUS6L

Loeb & Loeb LLP 10100 Santa Monica Blvd Suite 2200 Los Angeles, CA 90067

** Please include as a reference client no: 211605 or invoice number 1791662.

To aid in application of the payment, details should be sent to [email protected].

OCTOBER 8, 2018

THOMAS SEAMAN

THOMAS SEAMAN COMPANY

3 PARK PLAZA, SUITE 550

IRVINE, CA 92614

INVOICE NO. 1791662

PAYMENT DUE UPON RECEIPT RE: DIGITAL ALTITUDE OUR FILE NO: 211605-10008

FEES FOR PROFESSIONAL SERVICES RENDERED AS PER ATTACHED DETAIL 4,552.50

TOTAL CURRENT AMOUNT DUE 4,552.50


MATTER # 211605-10008 THOMAS SEAMAN 10/8/2018 INVOICE # 1791662 DIGITAL ALTITUDE PAGE 2

Date TK Description of Services Rendered Hours

9/4/18 BRK REVISED AND FINALIZED DRAFT DECLARATION OF MARY DEE

RE JOHN SOUZA

0.8

9/4/18 BRK EMAIL TO MARY DEE RE REVISED DRAFT DECLARATION RE

JOHN SOUZA

0.3

9/4/18 BRK DRAFTED AND REVISED WAIVER LETTER RE SEAN BROWN

COMMUNICATIONS

0.9

9/4/18 BRK EMAIL TO THOMAS SEAMAN AND DARREN CLEVINGER RE

0.3

9/11/18 BRK EMAILS TO AND FROM MARY DEE RE EXECUTION OF SOUZA

DECLARATION (SEVERAL)

0.2

9/11/18 BRK TELEPHONE CONFERENCE WITH THOMAS SEAMAN RE

0.5

9/12/18 BRK EMAILS FROM AND TO MARY DEE RE EXECUTION OF SOUZA

DECLARATION AND PERMISSION FOR RELEASE OF RECORDS

FROM THE DOLINS GROUP (SEVERAL)

0.3

9/12/18 BRK REVISED WAIVER LETTER RE SEAN BROWN 0.3

9/12/18 BRK TELEPHONE FROM THOMAS SEAMAN RE 0.2

9/14/18 BRK FINALIZED WAIVER LETTER RE SEAN BROWN; EMAIL TO

ANDREW HUDSON RE SAME

0.3

9/20/18 BRK EMAILS TO AND FROM MARY DEE RE EXECUTION OF SOUZA


0.2

9/20/18 BRK EMAILS FROM AND TO ANDREW HUDSON RE COURT RULING ON

FTC MOTION TO TERMINATE DEFENDANT LIVING EXPENSE

PAYMENTS

0.2

9/20/18 BRK EMAILS FROM AND TO THOMAS SEAMAN RE

N

0.2

9/24/18 LNJ TELEPHONE CONFERENCE WITH RECEIVR RE

(.2); E-MAIL TO RECEIVER (.1).

0.3

9/24/18 BRK TELEPHONE CONFERENCE WITH DARREN CLEVINGER RE

0.2

9/24/18 BRK RESEARCHED

0.6

9/24/18 BRK CONFERENCE WITH LANCE JURICH RE

0.2




9/25/18 LNJ ENGAGED AS TO RECEIVER ISSUES; E-MAIL TO B. KING

REGARDING ; MEETING WITH B. KING

REGARDING

0.2

9/25/18 BRK CONFERENCE WITH LANCE JURICH RE

0.3

9/26/18 BRK EMAILS FROM AND TO MARY DEE RE REVIEW AND EXECUTION

OF SOUZA DECLARATION (AND EMAIL TO THOMAS SEAMAN RE

SAME)

0.3

9/27/18 LNJ ENGAGED AS TO RECEIVER RECOVERIES 0.4

9/28/18 BRK EMAIL AND TELEPHONE TO THOMAS SEAMAN RE

0.2

9/28/18 BRK EMAIL TO MARY DEE RE STATUS OF EXECUTION OF

DECLARATION

0.1

Time & Fee Summary

Timekeeper Init Hours Rate Fee Value

B R KING BRK 6.6 595.00 3,927.00

L N JURICH LNJ 0.9 695.00 625.50

TOTAL 7.5 4,552.50



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






NOVEMBER 19, 2018

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1798618



DISBURSEMENTS MADE FOR YOUR ACCOUNT AS PER ATTACHED DETAIL 34.85





10/1/18 BRK EMAILS FROM AND TO MARY DEE RE FINALIZING

DECLARATION PERTAINING TO PMV/SOUZA DISPUTE

0.2

10/2/18 LNJ ENGAGED AS TO RECEIVER RECOVERY ISSUES TO INCREASE

RECOVERIES.

0.4

10/5/18 BRK CONFERENCES WITH, AND EMAILS FROM AND TO, FIONA

MCKEOWN RE

0.4

10/5/18 F M ENGAGED IN PREPARING DRAFT SECOND FEE APPLICATION;

PREPARE CHARTS IN SUPPORT THEREOF PURSUANT TO LOCAL

RULES

4.3

10/8/18 LNJ TELEPHONE CONFERENCE WITH T. SEAMAN RE (.1);

ENGAGED AS TO FEE APPLICATION ISSUES (.2).

0.3

10/8/18 BRK EMAILS FROM AND TO MARY DEE RE EXECUTION OF SOUZA


0.2

10/8/18 BRK EMAIL TO THOMAS SEAMAN RE

0.2

10/9/18 BRK TELEPHONE TO THOMAS SEAMAN RE 0.2

10/11/18 LNJ ENGAGED AS TO ISSUES RE RECEIVER RECOVERIES (.3);

REVIEWED EMAILS FROM B. KING AND T. SEAMAN (.1).

0.4

10/11/18 BRK REVIEWED AND REVISED DRAFT RECEIVER'S THIRD REPORT TO

COURT

1.8


0.1

10/12/18 BRK REVIEWED COURT WEBSITE RE OPEN HEARING DATES FOR

RECEIVER'S APPLICATION FOR FEES

0.1

10/12/18 BRK EMAILS FROM AND TO LANCE JURICH RE

0.4

10/12/18 BRK EMAIL TO MICHAEL QUINN (COUNSEL TO JOHN SOUZA) RE

OVERPAYMENT DISPUTE AND DECLARATION RE SAME

0.8


0.2


0.4

10/15/18 BRK CONFERENCE WITH FIONA MCKEOWN RE

0.3




10/16/18 LNJ ENGAGED AS TO RECEIVER STRATEGY AND CAUSES OF

ACTION.

0.4

10/16/18 BRK REVIEWED AND REVISED DRAFT SECOND FEE APPLICATION

FOR RECEIVER'S FEES

1.6

10/16/18 BRK EMAILS FROM AND TO TIM MCDONNELL RE

0.2

10/16/18 BRK TELEPHONE CONFERENCE WITH PARALEGAL FIONA MCKEOWN

RE

0.2

10/17/18 BRK EMAILS FROM AND TO MICHAEL QUINN (COUNSEL TO JOHN

SOUZA) RE OVERPAYMENT DISPUTE

0.2

10/24/18 BRK REVIEWED CLASS ACTION COMPLAINT FILED AGAINST DIGITAL

ALTITUDE AND ENGAGED AS TO RECEIVER RESPONSE TO SAME

0.7

10/24/18 BRK DRAFTED AND REVISED EMAIL TO PLAINTIFF'S COUNSEL RE

RESPONSE TO FILING/SERVICE OF CLASS ACTION COMPLAINT

AND REVIEW OF PRELIMINARY INJUNCTION RE PROHIBITIONS

ON SAME

0.6

10/24/18 BRK EMAILS FROM AND TO THOMAS SEAMAN AND ALISON JUROE

RE FILING OF CLASS ACTION COMPLAINT AND RESPONSE TO

SAME

0.2


0.2

10/24/18 BRK EMAILS TO AND FROM, AND CONFERENCE WITH, PARALEGAL

FIONA MCKEOWN RE

0.3

10/24/18 F M PREPARE EXCEL SPREADSHEET OF FEES FOR SUBMISSION TO

COURT

0.4

10/25/18 BRK REVISED AND FINALIZED THIRD RECEIVER'S REPORT AND

SECOND FEE APPLICATIONS FOR FILING

1.9

10/25/18 BRK EMAIL TO, AND CONFERENCE WITH, PARALEGAL FIONA

MCKEOWN RE

0.2

10/25/18 BRK PREPARED EXHIBITS TO RECEIVER'S THIRD REPORT AND

SECOND FEE APPLICATIONS FOR FILING

0.6

10/25/18 BRK REVIEWED COURT RULES RE DELIVERY OF BILLING

SPREADSHEET AND ENGAGED AS TO DELIVERY OF SAME TO

COURT

0.3




10/25/18 F M ENGAGED IN REDACTION OF RECEIVER'S BILLS 0.6

10/26/18 BRK EMAIL FROM ATTY ADRIAN BACON RE AGREEMENT TO STAY

CLASS ACTION LITIGATION

0.1


0.1


0.1

Time & Fee Summary


B R KING BRK 12.8 595.00 7,616.00

F MCKEOWN F M 5.3 300.00 1,590.00

L N JURICH LNJ 1.5 695.00 1,042.50

TOTAL 19.6 10,248.50

Disbursement Detail

Date Description of Disbursements Amount

10/4/18 LOCAL TRAVEL PARKING; 07/02/18 PAYEE: BENJAMIN KING -

ATTENDED HEARING ON VARIOUS MOTIONS

20.00

10/4/18 LOCAL TRAVEL MILEAGE; 07/02/18 PAYEE: BENJAMIN KING -

ATTENDED HEARING ON VARIOUS MOTIONS

14.85

TOTAL 34.85



STATEMENT OF PRIOR OUTSTANDING INVOICES

INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

TOTALS 4,552.50 0.00 4,552.50



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






DECEMBER 6, 2018

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1801237








11/1/18 BRK EMAILS FROM AND TO MICHAEL QUINN (COUNSEL TO JOHN

SOUZA) RE RESPONSE TO DRAFT DECLARATION OF MARY DEE

(SEVERAL)

0.2

11/1/18 BRK REVIEWED JOINT APPLICATION TO STAY CASE AND ARRANGED

FOR SAME TO BE SENT TO RECEIVER

0.3

11/1/18 BRK TELEPHONE TO THOMAS SEAMAN RE

0.1

11/2/18 LNJ ENGAGED AS TO RECEIVER RECOVERY ISSUES FOR VICTIMS. 0.4

11/6/18 BRK PREPARED FOR, AND PARTICIPATED IN, TELEPHONE

CONFERENCE WITH MICHAEL QUINN RE SOUZA OVERPAYMENT

DISPUTE

0.7

11/6/18 BRK EMAILS TO AND FROM, AND TELEPHONE CONFERENCE WITH,

THOMAS SEAMAN RE

0.2

11/6/18 BRK EMAILS TO AND FROM MICHAEL QUINN RE CALL TO DISCUSS

SOUZA OVERPAYMENT DISPUTE

0.1

11/7/18 BRK EMAILS TO AND FROM JODY GOODMAN AND THOMAS SEAMAN

RE RECEIVER COMMENTS ON PROPOSED STAY ORDER

0.2

11/7/18 BRK REVIEWED DRAFT STAY ORDER PROPOSED BY FTC 0.1

11/7/18 BRK TELEPHONE TO THOMAS SEAMAN RE 0.1

11/8/18 BRK TELEPHONE FROM THOMAS SEAMAN RE 0.1

11/9/18 BRK EMAILS FROM AND TO JODY GOODMAN AND THOMAS SEAMAN

RE SUBMISSION OF STAY ORDER TO COURT

0.1


0.4

11/27/18 BRK REVIEWED AND ANALYZED SETTLEMENT CORRESPONDENCE

FROM MICHAEL QUINN RE SOUZA DISPUTE

0.3


0.1



Time & Fee Summary


B R KING BRK 3.0 595.00 1,785.00

L N JURICH LNJ 0.4 695.00 278.00

TOTAL 3.4 2,063.00

Disbursement Detail


11/26/18 ONLINE RESEARCH PACER COURT RESEARCH - OCTOBER 2018 14.20

TOTAL 14.20




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

TOTALS 14,835.85 0.00 14,835.85



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






FEBRUARY 25, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1813536








12/14/18 BRK EMAILS FROM AND TO LANCE JURICE RE 0.1


0.3

1/11/19 BRK EMAILS FROM AND TO LANCE JURICH RE 0.2

1/11/19 BRK DRAFTED AND REVISED REPLY BRIEFS FOR SECOND RECEIVER

APPLICATION TO PAY RECEIVER FEES AND SECOND RECEIVER

MOTION FOR AUTHORITY TO PAY COUNSEL FEES

3.2

1/11/19 BRK EMAILS TO AND FROM, AND TELEPHONE CONFERENCE WITH,

THOMAS SEAMAN RE

0.3

1/14/19 BRK FINALIZED REPLY BRIEFS RE RECEIVER FEE APPLICATIONS AND

ENGAGED AS TO FILING OF SAME WITH COURT

0.5


0.3

1/23/19 BRK PREPARED SUPPLEMENTAL DECLARATION OF BENJAMIN KING

RE BILLING RATE CHARGED BY PARALEGAL FIONA MCKEOWN

IN FURTHER SUPPORT OF MOTION FOR AUTHORITY OF

RECEIVER TO PAY LEGAL FEES

0.8

1/23/19 BRK EMAILS FROM AND TO, AND TELEPHONE CONFERENCES WITH,

FIONA MCKEOWN RE

0.6


0.4

1/24/19 BRK TELEPHONE TO MICHAEL QUINN RE

0.2


0.1

1/30/19 LNJ ENGAGED AS TO STATUS OF RECEIVER MATTERS (.1); E-MAIL

FROM B. KING RE (.1).

0.2


0.2

1/30/19 BRK REVIEWED FTC APPLICATION TO EXTEND STAY AND STATUS

REPORT RE SAME

0.2




1/30/19 BRK TELEPHONE AND EMAILS TO AND FROM MICHAEL QUINN

(COUNSEL FOR JOHN SOUZA) RE SETTLEMENT DISCUSSIONS

0.4

1/31/19 BRK TELEPHONE FROM AND TO MICHAEL QUINN RE SETTLEMENT

DISCUSSIONS (SEVERAL)

0.5

Time & Fee Summary


B R KING BRK 8.3 595.00 4,938.50

L N JURICH LNJ 0.2 695.00 139.00

TOTAL 8.5 5,077.50

Disbursement Detail


1/31/19 MESSENGER/COURIER 01/14/19-USDC CENTRAL DISTRICT; DESC:

DELIVER ENVELOPE - COURTESY COPY; PAYEE: NATIONWIDE

LEGAL - INV# 186470 REF 116531

63.95

TOTAL 63.95




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

TOTALS 16,913.05 0.00 16,913.05



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






MARCH 18, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1817360








2/4/19 BRK TELEPHONE CONFERENCE WITH MICHAEL QUINN RE

SETTLEMENT DISCUSSIONS WITH SOUZA

0.2

2/4/19 BRK BEGAN DRAFTING TURNOVER MOTION AGAINST JOHN SOUZA

AND RESEARCH RE AUTHORITY FOR BRINGING SAME

1.8

2/5/19 LNJ E-MAIL FROM T. SEAMAN; E-MAIL FROM B. KING; ENGAGED AS

TO RECEIVER ISSUES AND AVOIDANCE OF LITIGATION;

REVIEWED DRAFT REPORT FROM T. SEAMAN; E-MAIL FROM B.

KING RE .

0.6

2/5/19 BRK EMAILS TO AND FROM THOMAS SEAMAN RE

AND REVIEW AND FILING OF RECEIVER'S FOURTH REPORT

(SEVERAL)

0.3

2/5/19 BRK REVIEWED AND REVISED RECEIVER'S FOURTH REPORT 0.8

2/5/19 BRK FURTHER RESEARCH RE

2.3

2/6/19 LNJ E-MAIL FROM B. KING; ENGAGED AS TO ISSUES RE RECEIVER

AND RECOVERY OF FUNDS; E-MAIL FROM T. SEAMAN.

0.3

2/6/19 BRK FURTHER REVIEWED AND REVISED DRAFT FOURTH RECEIVER'S

REPORT

0.9


(SEVERAL)

0.5

2/6/19 BRK ENGAGED AS TO FILING AND SERVICE OF RECEIVER'S FOURTH

REPORT

0.6

2/7/19 BRK TELEPHONE CONFERENCE WITH MICHAEL QUIN (COUNSEL FOR

PARADISE MEDIA VENTURES) RE SETTLEMENT AND

PROCEDURE FOR POTENTIAL TURNOVER MOTION

0.3

2/8/19 BRK REVIEWED COURT ORDER RE RULING ON FEE APPLICATIONS 0.5


0.2

2/8/19 BRK EMAILS TO AND FROM LANCE JURICH RE

0.1

2/11/19 BRK FURTHER DRAFTED MOTION FOR TURNOVER OF FUNDS

AGAINST PARADISE MEDIA VENTURES

3.8

2/14/19 BRK CONTINUED DRAFTING/REVISING MOTION FOR TURNOVER OF

FUNDS AGAINST PARADISE MEDIA VENTURES AND FURTHER

RESEARCH RE SAME

2.7




2/15/19 LNJ TELEPHONE CONFERENCE WITH T. SEAMAN RE

I .

0.2

2/22/19 BRK FURTHER DRAFTED/REVISED RECEIVER MOTION FOR

TURNOVER AGAINST PARADISE MEDIA VENTURES

1.6

2/28/19 LNJ TELEPHONE CONFERENCE WITH T. SEAMAN; ENGAGED AS TO

SETTLEMENT ISSUES; ENGAGED AS TO SOUZA'S ISSUES.

0.3


0.2

Time & Fee Summary


B R KING BRK 16.8 595.00 9,996.00

L N JURICH LNJ 1.4 695.00 973.00

TOTAL 18.2 10,969.00

Disbursement Detail



COURTESY COPY - DELIVER ENVELOPE; PAYEE: NATIONWIDE

LEGAL - INV# 187276 REF 116792

63.95

2/27/19 LEXIS RESEARCH 01/21/19 - 02/20/19 - F. MCKEOWN 9.40

2/27/19 ONLINE RESEARCH PACER COURT RESEARCH - JANUARY 2019 2.00


DELIVER ENVELOPE - COURTESY COPY; PAYEE: NATIONWIDE

LEGAL - INV# 188244 REF 117166

68.36

TOTAL 143.71




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

1813536 02/25/19 5,141.45 0.00 5,141.45

TOTALS 22,054.50 0.00 22,054.50



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






APRIL 12, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1821841









0.1


0.2

3/11/19 BRK TELEPHONE CONFERENCE WITH THOMAS SEAMAN AND FTC

REPRESENTATIVES RE OPEN MATTERS AND TIMETABLE FOR

CLOSING OUT RECEIVERSHIP

0.6

3/11/19 BRK EMAIL AND TELEPHONE TO MICHAEL QUINN RE SETTLEMENT

DISCUSSIONS FOR DISPUTE WITH PARADISE MEDIA VENTURES

0.3

3/13/19 LNJ ENGAGED AS TO SOUZA ISSUES AND MOTION. 0.5

3/13/19 BRK FURTHER DRAFTED AND REVISED MOTION FOR TURNOVER,

ETC. AGAINST PARADISE MEDIA VENTURES

1.6

3/14/19 LNJ TELEPHONE FROM T. SEAMAN; CONFERENCE WITH B. KING;

ENGAGED AS TO TURNOVER MOTION; E-MAIL FROM B. KING.

0.6

3/14/19 BRK FURTHER DRAFTED AND REVISED MOTION FOR TURNOVER OF

OVERPAYMENTS TO PARADISE MEDIA VENTURES

3.9

3/14/19 BRK TELEPHONE FROM, AND EMAILS TO AND FROM, THOMSAS

SEAMAN RE

0.5

3/14/19 BRK EMAILS FROM AND TO, AND TELEPHONE CONFERENCE WITH,

LANCE JURICH RE

0.7

3/14/19 BRK EMAILS TO AND FROM RYAN ISENBERG AND MICHAEL QUINN

(COUNSEL TO PARADISE MEDIA VENTURES) RE SERVICE OF

MOTION FOR TURNOVER AND RESPONSE TO SETTLEMENT

COUNTEROFFER

0.3

3/14/19 BRK DRAFTED AND REVISED KING AND SEAMAN DECLARATIONS IN

SUPPORT OF MOTION FOR TURNOVER, ETC.

2.6

3/14/19 BRK PREPARED EXHIBITS TO MARY DEE DECLARATION FOR FILING

OF TURNOVER MOTION

0.6

3/15/19 LNJ TELEPHONE CONFERENCE WITH T. SEAMAN; E-MAIL TO AND

FROM T. SEAMAN; E-MAIL FROM B. KING; ENGAGED AS TO

FILING AND SERVING TURNOVER MOTION.

0.8

3/15/19 BRK TELEPHONE CONFERENCE WITH, AND EMAILS TO AND FROM,

LANCE JURICH RE

0.2




3/18/19 BRK REVIEWED COURT ORDER CONTINUING HEARING AND EMAILS

TO AND FROM LANCE JURICH AND THOMAS SEAMAN RE SAME

0.1

3/18/19 BRK EMAILS FROM AND TO FTC REPRESENTATIVES AND RECEIVER

RE MARY D ACCOUNT FREEZE ISSUE

0.2

3/18/19 BRK EMAILS FROM AND TO RYAN ISENBERG (COUNSEL TO

PARADISE MEDIA VENTURES) RE CONTINUANCE OF HEARING

ON TURNOVER MOTION AND REMAINING BRIEFING SCHEDULE

(AND REVIEWED COURT RULES RE SAME)

0.4

3/19/19 LNJ E-MAIL FROM ISENBERG; TELEPHONE CONFERENCE WITH

RECEIVER; ENGAGED AS TO RECEIVER ISSUES; ENGAGED AS TO

COURT SCHEDULING.

0.3

3/19/19 F M BEGIN DRAFTING THIRD FEE APPLICATION AND DECLARATION

OF BEN KING; REVIEW OF BILLS AND CATEGORIZE SAME

2.8

3/20/19 F M DRAFT DECLARATION; REVIEW AND REVISE APPLICATION 1.3

3/22/19 BRK CONFERENCE WITH PARALEGAL FIONA MCKEOWN RE

0.2

Time & Fee Summary


B R KING BRK 12.5 595.00 7,437.50

F MCKEOWN F M 4.1 300.00 1,230.00

L N JURICH LNJ 2.2 695.00 1,529.00

TOTAL 18.8 10,196.50

Disbursement Detail


3/27/19 ONLINE RESEARCH PACER COURT RESEARCH - FEBRUARY 2019 3.70

3/31/19 POSTAGE 9.81

TOTAL 13.51




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

1813536 02/25/19 5,141.45 0.00 5,141.45

1817360 03/18/19 11,112.71 0.00 11,112.71

TOTALS 33,167.21 0.00 33,167.21



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






MAY 28, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1828556








4/1/19 LNJ ENGAGED AS TO ISSUES RE RECOVERY FOR CREDITORS. 0.3

4/2/19 LNJ ENGAGED AS TO RECEIVER ISSUES AND RECOVERIES. 0.4

4/5/19 LNJ REVIEWED OPPOSITION RE SOUZA (.4); E-MAIL FROM B. KING

(.1).

0.5

4/5/19 BRK REVIEWED AND ANALYZED OPPOSITION PAPERS FILED BY PMV

TO TURNOVER MOTION (AND EMAIL TO THOMAS SEAMAN RE

SAME)

1.3

4/15/19 BRK REVIEWED CASE LAW CITED IN PMV'S OPPOSITION TO

TURNOVER MOTION

1.2

4/15/19 BRK RESEARCHED CASE LAW RE

1.7

4/16/19 BRK BEGAN DRAFTING REPLY MEMORANDUM IN SUPPORT OF

RECEIVERSHIP MOTION AND FURTHER RESEARCH RE CASE

LAW FOR SAME

1.5

4/17/19 BRK CONTINUED DRAFTING REPLY RE RECEIVER'S TURNOVER

MOTION

3.2

4/17/19 BRK EMAILS TO AND FROM DANIEL FRIEDMAN RE

0.2

4/17/19 DJF CONFERENCE WITH B. KING RE (.3);

PREPARE OBJECTIONS TO DECLARATION OF J. SOUZA (4.0);

RESEARCH

(.4)

4.7

4/18/19 LNJ CONFERENCE WITH B. KING RE (.2); TELEPHONE

CONFERENCE WITH B. KING AND T. SEAMAN RE (.2);

REVIEWED AND REVISED REPLY BRIEF (1.4).

1.8

4/18/19 BRK FURTHER DRAFTED AND REVISED REPLY MEMORANDUM RE

TURNOVER MOTION

5.2


0.2

4/18/19 BRK TELEPHONE CONFERENCE WITH LANCE JURICH AND THOMAS

SEAMAN RE

0.5

4/18/19 BRK EMAILS TO LANCE JURICH AND THOMAS SEAMAN RE

(SEVERAL)

0.3




4/18/19 BRK EMAILS FROM AND TO ATTY DANIEL FRIEDMAN RE

0.1

4/18/19 BRK REVIEWED AND REVISED EVIDENTIARY OBJECTIONS TO SOUZA

DECLARATION

0.5

4/18/19 DJF REVIEW AND REVISE EVIDENTIARY OBJECTIONS 0.7

4/19/19 LNJ CONFERENCE WITH B. KING RE (.2);

ENGAGED AS TO REVISIONS TO REPLY AND FILING (.7).

0.9

4/19/19 BRK FURTHER REVISED AND FINALIZED REPLY MEMORANDUM AND

EVIDENTIARY OBJECTIONS TO SOUZA DECLARATION

1.0

4/19/19 BRK ENGAGED AS TO FILING AND SERVICE OF TURNOVER REPLY

MEMORANDUM AND EVIDENTIARY OBJECTIONS

0.3

4/26/19 F M CREATE CHARTS FOR THIRD FEE APPLICATION EXHIBITS 1.8

4/29/19 F M FINALIZE EXHIBITS TO FEE APPLICATION; ENGAGED IN

REVISING DECLARATION

2.3

4/30/19 F M EMAIL TO ATTORNEY ATTACHING DRAFT OF FEE APP AND

SUPPORTING DOCUMENTS

0.2

Time & Fee Summary


B R KING BRK 17.2 595.00 10,234.00

D J FRIEDMAN DJF 5.4 575.00 3,105.00

F MCKEOWN F M 4.3 300.00 1,290.00

L N JURICH LNJ 3.9 695.00 2,710.50

TOTAL 30.8 17,339.50



Disbursement Detail


4/30/19 ONLINE RESEARCH PACER COURT RESEARCH - MARCH 2019 17.50

4/30/19 PHOTOCOPY 56.85

TOTAL 74.35




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

1813536 02/25/19 5,141.45 0.00 5,141.45

1817360 03/18/19 11,112.71 0.00 11,112.71

1821841 04/12/19 10,210.01 0.00 10,210.01

TOTALS 43,377.22 0.00 43,377.22



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






JUNE 11, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1831088







5/24/19 LNJ ENGAGED AS TO RECEIVER ISSUES. 0.2

5/27/19 BRK BEGAN DRAFTING MOTION FOR REAPPOINTMENT OF RECEIVER 3.5

5/28/19 LNJ ENGAGED AS TO RECEIVER ISSUES. 0.4

5/28/19 BRK RESEARCHED FEDERAL CASE LAW RE

0.6

5/28/19 F M REVISE SPREADSHEET TO INCLUDE NEWLY RELEASED TIME 0.9

5/29/19 BRK CONTINUED DRAFTING MOTION FOR REAPPOINTMENT OF

RECEIVER

1.3

5/29/19 BRK FURTHER RESEARCH RE

0.3

5/30/19 LNJ ENGAGED AS TO MOTION TO RE-APPOINT (.3); E-MAIL FROM B.

KING AND REVISED PLEADINGS (.2).

0.5

5/30/19 BRK CONTINUED DRAFTING/REVISING MOTION FOR RECEIVER

REAPPOINTMENT

4.7

5/30/19 BRK DRAFTED AND REVISED DECLARATION OF THOMAS SEAMAN

RE MOTION FOR REAPPOINTMENT

2.3


0.2

5/31/19 BRK TELEPHONE CONFERENCES WITH THOMAS SEAMAN AND

ALISON JUROE RE REVISING AND FINALIZING RECEIVER'S

MOTION FOR REAPPOINTMENT

1.3

5/31/19 BRK REVISED PAPERS RE RECEIVER'S MOTION FOR REAPPOINTMENT

BASED UPON CLIENT COMMENTS

1.4

5/31/19 BRK ENGAGED AS TO FILING AND SERVICE OF RECEIVER'S MOTION

FOR REAPPOINTMENT

0.4

5/31/19 BRK REVIEWED EMAILS RE FACTUAL MATTERS FOR RECEIVER

REAPPOINTMENT MOTION

1.0

5/31/19 BRK EMAILS FROM AND TO THOMAS SEAMAN AND ALISON JUROE

RE FINALIZING RECEIVER'S MOTION FOR REAPPOINTMENT

(SEVERAL)

0.4

5/31/19 BRK REVIEWED COURT WEBSITE RE POTENTIAL TENTATIVE RULING

ON RECEIVER'S MOTION FOR TURNOVER AGAINST PMV

0.1




5/31/19 BRK REVIEWED BRIEFS, DECLARATIONS, EXHIBITS AND CASE LAW

IN PREPARATION FOR HEARING ON RECEIVER MOTION FOR

TURNOVER

3.1

Time & Fee Summary


B R KING BRK 20.6 595.00 12,257.00

F MCKEOWN F M 0.9 300.00 270.00

L N JURICH LNJ 1.1 695.00 764.50

TOTAL 22.6 13,291.50




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

1813536 02/25/19 5,141.45 0.00 5,141.45

1817360 03/18/19 11,112.71 0.00 11,112.71

1821841 04/12/19 10,210.01 0.00 10,210.01

1828556 05/28/19 17,413.85 0.00 17,413.85

TOTALS 60,791.07 0.00 60,791.07



SUITE 2200


(310) 282-2000 IRS #95-1780806

PAYMENT OPTIONS



City National Bank



ABA: 122016066






JULY 12, 2019

THOMAS SEAMAN



IRVINE, CA 92614

INVOICE NO. 1836323








6/3/19 LNJ ENGAGED AS TO ISSUES RE RECEIVERSHIP AND EMAIL TO B.

KING; E-MAIL FROM B. KING RE .

0.3

6/3/19 BRK ATTENDED COURT HEARING ON RECEIVER'S MOTION FOR

TURNOVER OF OVERPAID FUNDS

4.3


0.3

6/3/19 BRK CONTINUED PREPARATION FOR HEARING ON RECEIVER'S

MOTION FOR TURNOVER OF FUNDS

0.6


0.2

6/4/19 LNJ CONFERENCE WITH B. KING; E-MAIL FROM B. KING RE

; ENGAGED AS TO

SOUZA ISSUES.

0.3

6/4/19 BRK EMAILS TO THOMAS SEAMAN RE

0.2

6/4/19 BRK STRATEGIZED RE

0.2

6/4/19 BRK TELEPHONE FROM AND TO THOMAS SEAMAN RE

0.6

6/5/19 LNJ E-MAIL FROM R. ISENBERG (SOUZA LAWYER); E-MAIL FROM B.

KING; ENGAGED AS TO SOUZA AND RECEIVER ISSUES.

0.3

6/5/19 BRK PREPARED FOR, AND PARTICIPATED IN, TELEPHONE

CONFERENCE WITH RYAN ISENBERG (COUNSEL FOR PMV) RE

SETTLEMENT DISCUSSION AND MEET AND CONFER RE

TURNOVER DISPUTE PROCESS

0.7

6/5/19 BRK EMAILS TO AND FROM RYAN ISENBERG RE MEET AND CONFER 0.2

6/7/19 LNJ ENGAGED AS TO SOUZA ISSUES; E-MAIL TO AND FROM B. KING. 0.3

6/7/19 BRK TELEPHONE TO RYAN ISENBERG RE SETTLEMENT DISCUSSIONS

AND FURTHER MEET AND CONFER ON RESOLUTION OF

TURNOVER DISPUTE

0.5

6/7/19 BRK EMAILS TO AND FROM RYAN ISENBERG RE SETTLEMENT

DISCUSSIONS/MEET AND CONFER AND PREPARATION OF JOINT

REPORT TO COURT (SEVERAL)

0.3




6/10/19 LNJ ENGAGED AS TO SOUZA ISSUES (.1); ENGAGED AS TO FEE

APPLICATION ISSUES (.2); E-MAIL FROM R. ISENBERG (.1).

0.4

6/10/19 BRK TELEPHONE CONFERENCE WITH, AND EMAILS FROM AND TO,

RYAN ISENBERG RE SETTLEMENT DISCUSSIONS, FURTHER

MEET AND CONFER, AND DRAFT REPORT TO COURT ON SAME

0.4

6/10/19 BRK DRAFTED AND REVISED REPORT TO COURT RE SETTLEMENT

DISCUSSIONS AND MEET AND CONFER TOWARD RESOLUTION

OF TURNOVER DISPUTE WITH THIRD PARTY PMV

1.8

6/10/19 BRK ENGAGED AS TO FILING OF JOINT REPORT WITH COURT RE PMV

DISPUTE

0.2


(SEVERAL)

0.3

6/11/19 BRK ENGAGED AS TO DELIVERY OF COURTESY COPY OF JOINT

REPORT WITH COURT

0.1

6/12/19 LNJ E-MAIL FROM COURT; REVIEWED MINUTE ORDER. 0.2

6/12/19 BRK TELEPHONE FROM THOMAS SEAMAN RE

0.3

6/13/19 BRK EMAILS TO AND FROM LANCE JURICH AND THOMAS SEAMAN

RE

(SEVERAL)

0.3

6/13/19 BRK DRAFTED AND REVISED NOTICE OF LODGMENT AND PROPOSED

ORDER RE MOTION FOR RECEIVER REAPPOINTMENT

2.1

6/14/19 BRK ENGAGED AS TO LODGING OF PROPOSED ORDER RE RECEIVER

REAPPOINTMENT

0.2


0.1

6/18/19 BRK REVIEWED COURT ORDER TAKING MOTION FOR RECEIVER

REAPPOINTMENT UNDER SUBMISSION AND TELEPHONE FROM

THOMAS SEAMAN RE SAME

0.3

6/21/19 BRK TELEPHONE CONFERENCE WITH THOMAS SEAMAN RE S

0.3

6/24/19 BRK EMAILS FROM AND TO ANDREW HUDSON RE

0.4



Time & Fee Summary


B R KING BRK 14.9 595.00 8,865.50

L N JURICH LNJ 1.8 695.00 1,251.00

TOTAL 16.7 10,116.50

Disbursement Detail


6/6/19 SERVICE FEE - RETRIEV-IT LLC/STEPHEN SAMUEL WASSERMAN -

INV: 9822 06/01/2019 REQUESTED BY: BENJAMIN KING UCLA

LIBRARY RETRIEVAL

60.00

6/28/19 ONLINE RESEARCH PACER COURT RESEARCH - MAY 2019 27.60

6/30/19 MESSENGER/COURIER 06/02/19-USDC/CENTRAL DISTRICT; DESC:

DELIVER ENVELOPE; COURTESY COPY; PAYEE: NATIONWIDE

LEGAL - INV# 194506 REF 119956

133.46


DELIVER ENVELOPE; COURTESY COPY; PAYEE: NATIONWIDE

LEGAL - INV# 194506 REF 120159

68.36

6/30/19 PHOTOCOPY 81.90

6/30/19 POSTAGE 6.13

TOTAL 377.45




INVOICE

NUMBER

INVOICE

DATE

INVOICE

AMOUNT

PAYMENTS

TO DATE

INVOICE

BALANCE

1791662 10/08/18 4,552.50 0.00 4,552.50

1798618 11/19/18 10,283.35 0.00 10,283.35

1801237 12/06/18 2,077.20 0.00 2,077.20

1813536 02/25/19 5,141.45 0.00 5,141.45

1817360 03/18/19 11,112.71 0.00 11,112.71

1821841 04/12/19 10,210.01 0.00 10,210.01

1828556 05/28/19 17,413.85 0.00 17,413.85

1831088 06/11/19 13,291.50 0.00 13,291.50

TOTALS 74,082.57 0.00 74,082.57


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Transcript of FTC vs. Digital Altitude, LLC, et aldigitalaltitudereceiver.com/Images/315-1 Exhibit A.pdf ·...