Case 1:15-cv-02401-ELH Document 103-1 Filed 05/31/17 …colonialtidewaterreceivership.com/Sent Court...

:UND ACCOUNTINGDetâil

9/r/2075-3/3712077Subtotal

9/r/2O7s-3/31./2077

Lnanges Stnce 5th leeAppl¡cation

7/16/2077-3/3u2077of Receiver noted items in transit paid by bank prior to recelv¡ng notice of appo¡ntment

Pre.Rece¡vership Account at Bank of America

lncome:Êâgle Bank lnterest

Money Mãrket Account

ICS Sweep Account

River Valley Townhomes, LLC settlement w¡th Woodlands Bank

River Valley Townhomes, LLC - TD Eank Account transferred to Receiver for CTRIp AccountRiver Valley Townhomes, LLc - Woodlands Bank Account transferred to Recelver

Stone Brook Apartment Homes, ll settlement with MSI Rece¡ver

Êdgewood Holdings, LLC settlement with Regal BankD¡str¡bution from the Bânkruptcy Estate of Catalyst Group, Lp

D¡strlbut¡on from the Bankruptcy Estate of Catalyst croup, LP

of Funds from Balls and Sorber Associates, LLC for payment of profess¡onal fees thru 5/16/16 per Term Sheetby the Court on 4/25116. See Exhibit 1.1.

of Funds from Stony Fork Associate, LLC for payment of Pennsylvan¡a Department of Revenue Tâx Assessment for the7/7/rStrc 72/3L/r5.

Bank Fee Reversal

6.29A.92

6,298.92

792.90

634,950.14

110.00

745.7!48.34

707.45

85.45

10,000.00

11,358.92

2.79

361,284,00

5,000.00

752,267.57

45,252.93

49,702.72

82.47

110.00

lotal Funds Avallable lncome U.C 642,75t.96 193.45

EXHIBIT A to Receiver's Sixth Fee ApplicationSTANDARDIZED tUND ACCOUNTING REPORT for Estate of Colonial Tidewater, et al., Civ¡l court Docket No. 1:15-cv-02401-ELH

Report¡ng Per¡od 9 /t/2O!5-3/3U2Ot7 - Cash Basis

279,091.00

4,2723A1,336.50

2,9L4.OO

8,128.31

2,699.25

170.00

199.85

613.00

25.00

82.47

1,031.50

Dlsbußements for Recelver Operqtlons

D¡sbursements to Receiver and Counsel for Profess¡onal Fees (Court Approved)D¡sbursements to Rece¡ver and Counsel for Re¡mbursable Expenses (Court Approved)Disbursement to Cl¡ftonLarsonAllen LLP for Tax Seryices re Colonlal Edgewood Holdings, LLc (court Approved)D¡sbursement to cl¡ftonLarsonAllen LLP for Tax Sery¡ces re Greater River Valley Townhomes LLC (Court Approved)

Disbursement to CliftonLarsonAllen LLP for Tax Sery¡ces re Colonial Stone Brook Apartment Homes ll LLC (Court Approved)Disbursement to cliftonLarsonAllen LLP forTâx Seryices re f¡nal Colonlal Tldewater partnership return and ReceivershipEstate QSF (Court Approved)Website

Storage Facility

Bank Fees

Federal and State Tax Payments

New York State Filing Fee

Pennsylvania Department of Revenue Filing Year 2015 Tâx AssessmentTotal Disbursements for Receiver 300,563.26

205.50

18,435.00

2,425.34

of lncome LLC 341,588.70 21.06s.84

9,631.49

!62,592.O2

130,232.83

LLG BankAccount Balances {as of 3/3112017}:

I's and Sorber Associâtes, LLC [See Exhib¡t 4.1]Creek Assoc¡ates, LLC [See Exhíbit 4.4]

Fork Associates, LLC [See Exh¡blt 4.5]Total Funds ln Affiliate LLcs 302.456.34

8.38

747.70

6!.79

and Affillate LLCSEalance of 6/M,045.04 2fl.47

Eank Check¡ng Account Balance (as of 3/31/2017) - Colonial Tidewater Realty lncome partners, LLC 1,991.36Outstanding Checks (as o1 3/3I/2O!7\

Eagle Bank Money Market Account Balance las of 3/37/20771 - Colon¡al Tidewater Realty lncome Partners, LLC

lnsured Cash Sweep {lCS) account w¡th Promontory lnterfinânc¡al Network, LLC through Eagle Bank (as of 3/37/20771Plus Affìl¡ate Bank Account Balances (âs of 3/37/21f7l

235,511.89

104,085.45

302,456.34

s 644,045.04

1of 6

Case 1:15-cv-02401-ELH Document 103-1 Filed 05/31/17 of 1

EXHIBIT A.1to Receiver's Sixth Fee ApplicationSubsidiary Schedule of Cash Activity for Ball's Sorber Associâtes LLC

Reporting Period 9 /t/2O75 to 3/3U2017 - Cash Bas¡s

Note L; Funds transferred to Colonial Tidewater lncome Partners, LLC per Term approved by the Court on 4-25-2016. See Exh¡bit A.

FUND ACCOUNTING

Detail

9/r/2Ùrs-3/37/2Or7Subtotal

9/tl2O7s-3/3L/2Or7

Changes Since 5th Fee

Application

r/ß/2017-3/3r/2017Beginning Bâlance {As of 9/f/2Aß) Receiver noted items in transit pa¡d by bank pr¡or to receiving noticeof appo¡ntment order;

Pre-Rece¡vership Account ât Cec¡IBANK

lncreases in Fund Balance:

Bus¡ness Revenue

Rental lncome

Loan Repayments

Sale Proceeds

Refund Post Clos¡ng - lnsurance

OtherRefund - NYSEG (Electr¡c Ut¡lity)

Corning Nâtural Gâs Corporation

72,724.67

12,724.67

47,624.M

106 368.38

51,611.03

72,291.O2

22,709.39

1,0L3.00

87.33

19.03

Total Funds Ava¡lable too,4s5.47 8.38

Decreases in Fund Balance:

Dísbußements lor Reêe¡vet Opetat¡onsD¡sbursement to CliftonLarsonAllen LLP for Tâx Seru¡ces (Court Approved)

Disbursement to Coloniâl T¡dewater Receivership (Note 1)

Bus¡ness Operation Expense

Utilities (Electric, Garbage ând Recycling, Water/sewer)lnsurance

On-Site Management

Permits and Licensing

Repairs

Property Maintenânce (landscaping, lawn mowing, snow removal)

Wâter Testing

Bânk Fees

Steuben County Clerks Off¡ce - Copies of Deeds

Annuâl Maryland Personal Property Tâx for LLCS

New York Stête Tax Return Fil¡ng Fee

Net Due trom Rece¡verto Buyer

Sale Proceeds Due to tive Star Bânk

Total Disbursements

3,765.00

49,702.72

15,990.70

4,029.61

32s.00

1s0.00

1,070.00

1,730.00

6,312.54

12.50

3.25

600.00

25.00

1,391.39

s.776.47

s0.823 98Ending Balance (as of 3/3f/2O171 9.531.49

9,631.49

$ 9,631.49

Reconc¡liat¡on:

Checking Account Balance (as of 3/31/2017)Less Outstânding Checks

Plus Deposits in Transit

2of6

Case 1:15-cv-02401-ELH Document 103-2 Filed 05/31/17 Page 1 of 1

EXHIBIT A.2 to Receiver's Sixth Fee ApplicationSubsidiary Schedule of Cash Activityfor Catalvst Group Lp

Reporting Pe¡iod 8/26/2015-3/3112017 - Cash Basis

Account Closed

Accounts turned over to Counsel for the Debtor on 7 17 lL6 pursuant to an Order of the Bankruptcy CourtAll accounts are property of the Ba Estate of Catalyst Group, LP

Note 1.: The Bankruptcy Court made a to Ræe¡ver for Colon¡al Tidewater et. al in the amount 51. See Exhibit A.

FUND ACCOUNTING

Detail

8/26/20rs-3/37/21r'lsubtotal

8/26/2075-3/3U2O!7

Changes S¡nce sth Fee

Applicat¡on

rl76/2017-3137/2077

335,930.61

70,229.75

1,696.96

geg¡nning Balance (As of 8/26/2076'):Pre-Receivership Account at BB&T (Escrow)

Pre-Receivership Account at B8&T (Operating)

Pre-Rece¡vership Account at BB&T (Water Management, LLC)

347,857 32

Total Funds Ava¡lable 347,857.32

Decreases ln Fund Balance:

D¡sbursements for Reæ¡vet Ope rdtlonsD¡sbursements to Receiver and Counsel for Professional Fees - None to DateDisbursements to Receiver and Counsel for Relmbursable Expenses - None to DateEankruptcy Court Approved Payment of Fees to Counsel ând AccountantBank Fees

Balance Transferred to Bankruptcy Estate of Catalyst Group, L.p. per Order (Note 1)Total D¡sbursements

27,92I.O5

40.00

325,896.27

347,857 32

Ending Bâlânce (as of 3/3U20U) - Account Closed s0.00 0.0c

3of6


FUND ACCOUNTING

Detail

8/26/2075-3/37/2077Subtotal

8/2612or5-313112017

Changes Since sth Fee

Application

rl16/2or7-3/3112077Beglnning Balance (As of 812612076)l

Pre-Recelvership Account at TD Bank

lncreases ln Fund Balance:

Suslness Revenue

Rental Income -1.0 Eagle Court

OtherReversal of Bânk Feê

3.300 92

3,300.92

8,500.00

125.00

8,500 00

175OO

Total Funds Avallãble 11.925.92

EXHIBIT A.3 to Receiver's S¡xth Fee ApplicationSubsidiary Schedule of Cash Activlty for Greater River Vallev Townhomes LLC

Report¡ng Period 8/26/2Ol5-3/3t/2OI7 - Cash Basis

Account Closed

77,35892

384 00

183 00

77,925,92Ending Balance (as of 3/37/2O771 - Account closed to Receiver for Colon¡al Tidewâter et. âlfsee Exhibit Al s0.00 000

4of6


D ACCOUNTING

Detail

9/rl20rs-3/37/2O!7subtotal

9/7/zjrs-3/3u2071

Changes Since sth Fee

Appl¡cation

u16/2017-3/3r/2Or7Beg¡nning Ealance (As of 9/1/2015) Receiver noted items ¡n trans¡t pa¡d by bank prior to receiving noticeofappointment ord€r:

Pre-Receiversh¡p Account at North West Savings Bank


I nterest/ D¡vld e n d I nco m e :Eagle Bank lnterest

Money Market Account

Bus¡ness Revenue

Rental lncome

Tra¡ler Loan Repayments

OtherRe¡mbursement - lnsurance Premium

Refund - Charlie Cooper Overpayment due to lncorrect lnvoice

Refund - PPL Electric (Electric Ut¡lity)

Bank Fee Reversal

25,780.75

25,780.75

305.47

275,846.37

3,67t 02

96.70305.47

270,232.47

5,613 96

7,727 Ss

1,000 00

739.47

7s0 00

lotal Funds Ava¡lable 305,549.61 96.70

EXHIBIT 4.4 to Receiver's Sixth Fee ApplicationSubsldiary Schedule of Cash Act¡vity for Pine Creek Associates LLC

Reporting Period 9 / U2OI5-3/3I/2OI7 . Cash Basis

Reconciliation:

Eagle Bank Checking Account Balance (as of 3/31/2017) - See Note 1

Eagle Bank Money Market Account Bãlance las of 3/3I/2OL?|ss

5,679.60

756,9r2.42

s 162,592,O2

Note 1: Northwest Savlngs Bânk ãccount transferred to Eagle Bank on 5-24-2016.

Decreases ¡n Fund Balance:

D¡sbußements Íor Rece¡ver Operotlons

Disbursements to Receiver and Counsel for Professional Fees - None to Date

D¡sbursements to Receiver ãnd Counsel for Reimbursable Expenses - None to Date

Disbursement to CliftonlarsonAllen LLP for Tax Seru¡ces (Court Approved)

Business Operãtions Expenses:

Utilities (Electr¡q Garbage/Recycling, Gas, Sewer)

Advertis¡ng Expense

lnternet/Phone Expense

Property Ma¡ntenance Expense (Landscâp¡ng, Snow Plow¡ng, Tree Removal)

On-Site Management Expense

Mortgage

Repairs

Water/ Sewer B¡lling Expense

lnsurance

Copies of Tra¡ler T¡tles (net)

Return of Security Deposits

Annuãl Mary¡and Personal Property Tax for LLCS

Bank Fees

PO Box Rênewal

Total Disbursements

3,r72 50

51,345.60

r57.157,034 97

16,575 00

12,000 00

41,624 07

2,650 36

3,265 50

2,850 00

102 00

200 00

600 00

1,345 90

34 00

742,957 59

(s1.oo)

Balance L62,592.O2 fs1.00l

5of6


ND ACCOUNTING

Deta¡l

thl20!s-3/3rl2ortsubtotal

9/rl20rs-3/3u2077

Changes 5¡nce 5th Fee

Applicat¡on

u76/2077-313712077

Beginning Ealance (As of 9/1/2015) Receiver noted ltems in trans¡t pâ¡d by bank prior to receiving

notice of appo¡ntment order:

Pre-Receivership Account at North West Savings Bank


lnte rcst/ Dlvlde nd lnco me :Ëagle Bânk lnterest

Money Market Account

Euslness Revenue

Rental lncome

Sale Proceeds

Refund Post Clos¡ng - lnsurance

Escrow Post Clos¡ng

OthetBank Fee Reversal

6.417.AA

6,477.48

250.69

744,2863r

750.00

6r.79250.69

34,952.50

100,504.56

329.258.S00.o0

750.00

Total Funds Ava¡lable 151.764.88 61.79

EXHIBIT 4.5 to Receiver's Sixth Fee ApplicationSubsidiary Schedule of Cash Activityfor Stonv ForkAssociates LLC

Reporting Petiod I / r/20L5-3l3L/20L7 - Cash Basis

Reconc¡l¡at¡on:

Eagle Bank Checking Ac€ount Balance (as of 3/31/2017) - See Note 1

Eagle Bânk Money Market Account Balance las oÍ 3/37/2ol7ls5

4,917.53

125,315.30

I 130,232.83

Note 1: Northwest Sav¡ngs Bank account transferred to Eagle Bank on 4-8-2016,

Note 2: Funds transferred to Colonial Tidewater Realty lncome Partners, LLC for payment of Pennsylvania Department of Revenue Tax Assessment for the per¡od 1/1/15 tot2/37/7s.

Decreases ln Fund Balance:

D¡sbursements lor ßece¡vet Operat¡ons

D¡sbursements to Recelver and Counsel for Professional Fees - None to Dâte

Disbursements to Rece¡ver and Counsel for Re¡mbursable Expenses - None to Date

D¡sbursement to Cl¡ftonLarsonAllen LLP for Tax seru¡ces (Court Approved)

Disbursement to Colon¡al Tidewater Receivershlp (Note 2)

Business Operãt¡ons Expense:

Ut¡lities (€lectric, Gas, Sewer)

lnsurance

Mortgãge

Phone

Property Maintenance (Landscâping, Lâwn Mowing)

Repa¡rs

Supplies

Water Testing

Bank Fees

Annual Maryland Personal Property Tax for LLCS

Total Disbursements

3,726.OO

42.47

7,050.05

488.25

4,009.70

773.36

460.00

2,550.00

205.99

1,198.36

987.87

600.00

2l,s32.OsEndins Balance las of 1/37/2077\ 130.232.83

6of6


EXHIBIT BColonial Tidewater Realty Income Partnerso LLC Receivership Estate

Summary of Receiver's Professional Time - Sixth Fee ApplicationPeriod Covered: December 24,2016 through March 3L,2017

Engagement Name HoursExcludes exp€nses

Marion Hecht

Heather Martinez

Receiver ActivitiesColonial Stone Brook Litigation

Catalyst Group (dba Cinnamon Woods)

Ball's & Sorber Associates

Pine Creek Associates

Greater River Valley Townhomes

Colonial Edgewood Holdings(dba Melissa's Manor)Stony Fork Associates (dba Country Living)

Colonial Stone Brook Apartment Homes II3212East Jopppa Road

Employee Total

Receiver ActivitiesColonial Stone Brook LitigationCatalyst Group (dba Cinnamon V/oods)




Colonial Edgewood Holdings(dba Melissa's Manor)

Stony Fork Associates (dba Country Living)Colonial Stone Brook Apartment Homes II3212East Jopppa Road

Employee Total

22.10 $

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

Amount

7,905.00

42.s0

245.25

297.50

170.00

935.00

9,595.25

2s.00

25.00

0.10

1.05

0.70

0.40

2.20

26.5s

0.10

0.10

I of3


EXHIBIT BColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Professional Time - Sixth Fee ApplicationPeriod Covered: December 24,2016 through March 31,2017

Engagement NameReceiver ActivitiesColonial Stone Brook Litigation

Catalyst Group (dba Cinnamon'Woods)




Colonial Edgewood Holdings(dba Melissa's Manor)Stony Fork Associates (dba Country Living)Colonial Stone Brook Apartment Homes II3212East Jopppa Road

Employee Total






Colonial Edgewood Holdings(dba Melissa's Manor)Stony Fork Associates (dba Country Living)Colonial Stone Brook Apartment Homes II3212EastJopppa Road

Employee Total

Receiver Activities

Colonial Stone Brook LitigationCatalyst Group (dba Cinnamon Woods)




Colonial Edgewood Holdings(dba Melissa's Manor)Stony Fork Associates (dba Country Living)Colonial Stone Brook Apartment Homes II3212East Jopppa Road

Employee Total

Amount

0.10 9.00

0.10 9.00

0.10 9.00

0.30 27.00

26.10 5,160.00

0.20 $ 40.00

0.60

2.60

4.00

0.40

100.00

500.00

780.00

60.00

HoursJillMiller

Megan Miller

Ginger Stafford

$

$

$

$

$

$

$

$

$

$$

$

$

$

$

$

$

36.60 7,160.00

26.3s I,840.50

2.00

0.70

380.00

140.00

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

0.10

0.50

9.00

45.00

18.00

18.00

0.20

0.20

27.35

2of3

1,930.50


EXHIBIT BColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Professional Time - Sixth Fee ApplicationPeriod Covered: December 24,2016 through March 31,2017

Stewart

Becky Wienke

Engagement Name

Receiver Activities

Colonial Stone Brook Litigation







Employee Total








Employee Total

Total Hours

Total Fees:

0.67

0.33

0.92

67.00

33.00

92.00

Ifours0.50

0.50

2.92

0.20

0.20

1.00

94.82

Amount50.00

50.00

292.00

60.00

60.00

300.00

s 19,329.75

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

0.20

0.20

0.20

60.00

60.00

60.00

3 of3


EXHIBIT CColonial Tidewater Realty Income Partners, LLC Receivership EstateSummary of Receiver's Fees by Month - Sixth Fee Application Period

Covered: December 24,2016 through March 31,2017

Period Engagement Name Expenses Fees

December 24,2016 -

January 31,2017

February l -28,2017

March 1 -25,2017

Receiver Activities








Receiver Activities

Colonial Stone Brook LitigationCatalyst Group (dba Cinnamon Woods)






Receiver Activities







Colonial Stone Brook Apartment Homes II3212 EasI Jopppa Road

Tota

6,320.00

236.00

637.00

867.s0

60.00

40.00

421.50

522.50

9,104.50

0.96 4,806.00

42.50

1s0.2s

218.50

163.00

570.50

0.96 5,950.75

3,889.50

60.00

222.50

t 02.s0

0.96

4,274.50

19,329.75

Total

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

s

$

$

$

$

$

$

$

$

$

$

$

$

$

Total

Total All Invoices

1of I

Total Fees and Expenses: $ 19,330.71


EXHIBIT DColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Fees and Expenses by Activity - Sixth Fee ApplicationPeriod Covered: December 24,2016 through March 31,20L7

Receivership Engagement HoursProfessional Services

Fees Bxpenses

Receiver Activities







Stony Fork Associates (dba Country Living)


75.25

1.67

4.28

6.52

0.40

0.20

3.403.10

15,015.50

278.50

847.2s1,308.50

60.00

40.00

687.00

1,093.00

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

0.96

SUB-TOTAL 94.82 $19,329.75 $0.96

TOTAL $19,330.71

I of 1


EXHIBITEColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiverts Fees by Task Code - Sixth Fee ApplicationPeriod Covered: December 24,2016 through March 3L,2017

Receivership Engagement Task Code Hours Amount

Accounting/auditing

Analysis of Claims

Asset analysis and recovery

Asset disposition

Business analysis

Business operations

Case administration

Court Hearings / Filings

Claims administration, obj ections

Data analysis

Data analysis and compilation

Fee application

Forensic accounting

Litigation consulting

Professional Services Not Billed to the Estate

Review of documents

Status reports

Tax issues

Tax Returns

Travel Not Billed to the Estate

Valuation

Professional Services Subtotal

Expenses

TOTAL

0.10

31.70

0.20

20.00

5,591.00

18.00

5.70

10.00

6.50

10.20

1,065.00

2,819.25

2,628.50

3,084.50

4,103.50

11.50

18.92

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

94.82 $ 19,329.75

0.96$

$ 19,330.71


IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

V Case No. 1 : 1 5-cv-02401 -ELH

COLONIAL TIDEWATER REALTY INCOMEPARTNERS, LLC, et al.,

Defendants

NOTICE OF FILING EXHIBIT OR ATTACHMENT UNDER SEAL

Exhibit F, which is an attachment to Receiver's Sixth Interim Fee Application, will be

filed with the Clerk's Office in PDF format within 24 hours of the filing of this Notice so that it

may be electronically filed under seal.

Date: lr4ay 37,2017 Respectfully submitted,

/s/ J. Jonathan SchraubJ. Jonathan Schraub, MD Bar No. 02708SeNos ANnnRsoN, PC1497 ChainBridge Road, Suite 202Mclean, Virginia 22101 -5728Email: [email protected]: 703.893.3600Facsimile: 703.893.8484Counsel for Receiver


EXHIBIT G

CERTIFICATION

(1) The undersigned Certifying Professional has read the Application;

(2) to the best of the Applicant's knowledge, information and belief formed afterreasonable inquiry, the Application and all fees and expenses therein are true and accurate and

comply with the Billing Instructions (with any exceptions specifically noted in the Certificationand described in the Application);

(3) all fees contained in the Application are based on the rates listed in theApplicant's fee schedule attached hereto and such fees are reasonable, necessary andcommensurate with the skill and experience required for the activity performed;

(4) the Applicant has not included in the amount for which reimbursement is soughtthe amortization of the cost of any investment, equipment, or capital outlay (except to the extentthat any such amortization is included within the permitted allowable amounts set forth hereinfor photocopies and facsimile transmission); and,

(5) in seeking reimbursement for a service which the Applicant justifiably purchased

or contracted for from a third party (such as copying, imaging, bulk mail, messenger service,overnight courier, computerized research, or title and lien searches), the Applicant requestsreimbursement only for the amount billed to the Applicant by the third-party vendor and paid bythe Applicant to such vendor. If such services are performed by the Applicant, the Applicantcertifies that it is not making a profit on such reimbursable service.

(6) With respect to each litigation matter undertaken, I, in conjunction with mycounsel at Sands Anderson PC have determined the litigation actions will product a net economicbenefit to the estate, based on a review of, (i) the legal theories upon which the action was based,

including issues of standing; (ii) the likelihood of collection on any judgment which might be

obtained; and (iii) alternative methods of seeking the relief, such as the retention of counsel on acontingency basis.

--l'r ¡tut j *r/

ll ,4,J¿¡,/tT#",+/,&t-

Marion A. Hecht, ReceiverCertifying Professional


EXHIBITHColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Counsel's Professional Time - Sixth Fee.A'pplicationPeriod Covered: January 1,2017 through March 3lr20l7

Engagement Name Hours AmountExcludes expenses

George Pitts Receiver Activities









1.00 $ 380.00

Employee Total 1.00 $ 380.00

Total Hours

Total Fees:

1.00

$ 380.00

l of 1


EXHIBIT IColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Counsel's Fees by Month - Sixth Fee ApplicationPeriod Covered: January lr2017 through March 31,2017

Period Engagement Name Expenses Fees

January I - February28,2017

March I - 31,2017

Receiver Activities









Receiver Activities






Colonial Edgewood Holdings(dba Melissas Manor)


Colonial Stone Brook Apaftment Homes II3212Easf Jopppa Road

45.90

Total $ 45.90

$

$

$

$

$

$

$

$

s

$

$

380.00

380.00

380.00

425.90

$

$

$

$

$

$

$

s

s

$

$

Total Invoices

Total $

$ 45.90 $

Total All Fees and Expenses $

l of 1


EXHIBITJColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Counsel's Fees and Expenses by Activify - Sixth Fee ApplicationPeriod Covered: January 1,2017 through March 31,2017

HoursProfessional Services

X'ees ExpensesReceivership Engagement

Receiver Activities


Catalyst Group (dba Cinnamon \üoods)






Colonial Stone Brook Apartment Homes II

3212Easf Jopppa Road

1.00 380.00 45.90$

$

$

$

$

$

$

s$

$

$

$

$

$

$

$

$

$

$

$

SUB-TOTAL 1.00 $380.00 $4s.90

TOTAL $425.90

1of I


EXHIBIT KColonial Tidewater Realty Income Partners, LLC Receivership Estate

Summary of Receiver's Counsel's Fees by Task Code - Sixth Fee ApplicationPeriod Covered: January 1,2017 through March 31,2017

Receivership Engagement Task Code Amount

Accounting/auditingAnalysis of ClaimsAsset analysis and recoveryAsset dispositionBusiness analysis

Business operations

Case administrationCourt Hearings

Claims administration, objectionsData analysis

Data analysis and compilationFee applicationForensic accountingLitigation consultingReview of documents

Status reports

Tax issues

Tax Returns

Valuation

Professional Services Subtotal

Expenses

TOTAL

$

$

$

$

$

$

$

$

$

s$

$

$

$

$

$

$

$

$

190.00

190.00

$

$

3 80.00

$ 380.00

1of 1


IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

V Case No. 1 : I 5-cv-02401 -ELH

COLONIAL TIDEWATER REALTY INCOMEPARTNERS, LLC, et al.,

Defendants

NOTICE OF FILING EXHIBIT OR ATTACHMENT UNDER SEAL

Exhibit L, which is an attachment to Receiver's Sixth Interim Fee Application, will be

filed with the Clerk's Office in PDF format within 24 hours of the filing of this Notice so that it

may be electronically filed under seal.

Date: }y'ray 37,2017 Respectfully submitted,

/s/ J. Jonathan SchraubJ. Jonathan Schraub, MD Bar No. 02708SeNos ANoeRsoN, PC1497 ChainBridge Road, Suite 202Mclean, Virginia 2210I -57 28Email: [email protected]: 703.893.3600Facsimile: 703.893.8484Counsel for Receiver


EXHIBIT M

CERTIFICATION

(1) The undersigned Certifying Professional has read the Application;

(2) to the best of the Applicant's knowledge, information and belief formed afterreasonable inquiry, the Application and all fees and expenses therein are true and accurate andcomply with the Billing Instructions (with any exceptions specifically noted in the Certificationand described in the Application);

(3) all fees contained in the Application are based on the rates listed in theApplicant's fee schedule attached hereto and such fees are reasonable, necessary andcommensurate with the skill and experience required for the activity performed;

(4) the Applicant has not included in the amount for which reimbursement is soughtthe amortization of the cost of any investment, equipment, or capital outlay (except to the extentthat any such amortization is included within the permitted allowable amounts set forth hereinfor photocopies and facsimile transmission); and,

(5) in seeking reimbursement for a service which the Applicant justifiably purchased

or contracted for from a third party (such as copying, imaging, bulk mail, messenger service,ovemight courier, computerized research, or title and lien searches), the Applicant requestsreimbursement only for the amount billed to the Applicant by the third-party vendor and paid bythe Applicant to such vendor. If such services are performed by the Applicant, the Applicantcertifies that it is not making a profit on such reimbursable service.

(6) at present there are no litigation matters. However, with respect to each litigationmatter undertaken, I, in conjunction with the Receiver, Marion A. Hecht, have determinedcontemplated actions will produce a net economic benefit to the Estate, based on a review of: (i)the legal theories upon which the action would be based, including issues of standing; (ii) thelikelihood of collection of any judgment which might be obtained; and (iii) alternative methodsof seeking the reliet such as retention of counsel on a

GeorgeCerti


Case 1:15-cv-02401-ELH Document 103-1 Filed 05/31/17 …colonialtidewaterreceivership.com/Sent Court...

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