SUBMISSION OF RECEIVER S VERIFIED INVOICE THROUGH APRIL 20, 2018

Transcription

1 DISTRICT COURT, DENVER COUNTY, STATE OF COLORADO 1437 Bannock Street, Room 256 Denver, Colorado Phone Number: In re the Receivership Estate of MYH And Concerning: Alpine Herbal Wellness, LLC, Serenity Moon Wellness Center, LLC; Walnut Associates, LLC; ADG Herbal Wellness Center, Inc.; FL89, LLC; Frosted Leaf, LLC; Big Mouth Snacks, LLC, Lightshade Productions, LLC; 399 Harrison Street, LLC; Straight River, LLC; Vape Tools, LLC; East 40th Avenue, LLC; 420 Events, LLC; Canna Co, LLC; and Kiri A. Humphrey And Third Party Intervenor, Scott Simon, an individual. Attorneys for Receiver: John M. Tanner Fairfield and Woods, P.C California #2600 Denver, Colorado Phone: Fax: A COURT USE ONLY A Case Number: 17CV31274 Division: 303 SUBMISSION OF RECEIVER S VERIFIED INVOICE THROUGH APRIL 20, 2018 Sterling Consulting Corporation, as receiver, by and through its attorneys, Fairfield and Woods, P.C., hereby submits the Receiver s verified invoice for work from March 21, 2018 through April 20, 2018, attached as Exhibit 1. Respectfully submitted this 11th day of May, 2018.

2 FAIRFIELD AND WOODS, P.C. By: s/ Udhn/M{/Wanner ' John M. Tanner Attorneys for Receiver CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was E-filed via the Colorado Court s E-filing System this 11th day of May, 2018, and E-served upon the following or as indicated below: Claudia Brett Goldin Duncan L. Griffiths J. Alan Call Jon Eric Stuebner Colorado Attorney General Carolyn Witkus 1300 Broadway, FI. 10 Griffiths Law P.C. Denver, CO Park Meadows Dr., Ste. 520 Claudia. goldin(o),coag. gov Littleton, CO Alan.call@coag.gov carolvn(a), griffithslawpc.com jstuebner@griffithslawpc.com Matthew William Buck Red Law Gary D. Nicholas Nicholas Family Law Kyler K. Burgi 4601 DTC Blvd., Ste R. Kirk Mueller Denver, CO Davis Graham & Stubbs, LLP th Street, #500 John L. Skari, Jr. John S. Zakhem Kvler.Burgi(2>dgslaw.com Jackson Kelly PLLC Kirk.mueller(a),dgslaw.com th Street, Suite 2150 Robert T. Hoban C. Adam Foster Robert J. Corry, Jr. Keenan M. Jones Abbey Gail Moffitt Hoban Law Group Law Office of Corry & Associates th Street, Suite W. Colfax, Suite 300 Denver, CO bob(2),hoban.law adam(o),hoban.law KeenanfS),hoban. law

3 Amanda Halstead Mills Schmitz th St., #28008 Jerry Oliver Porterfield and Associates 101 Eagle Road, Building 8 Eagle-Vail, CO ioliver@opa-law.com William Eikenberry Darling Milligan Smith & Lesch, PC th St., Ste. 800 beikenberrv@dmsl-law.com apanicucci@dmsl-law.com John Goutell The Minerva, EEC 9457 S. University Blvd., #528 Highlands Ranch, CO i ohn@theminerva. com Aaron C. Acker Springer and Steinberg, P.C Broadway, Suite 1200 Courtesy copies via to: Jennifer Lynne Lewis Lewis and Matthews P.C Gaylord Street Denver, CO Jlewis@,matthe wslaw.com Adam Slipakoff Slipakoff and Slomka, LLLP Atlanta Tech Village 3423 Piedmont Rd., N.E. Atlanta, GA as@mvatllaw.com Rachel Gillette Greenspoon Marder 1401 Lawrence St., #1900 Rachel. gillette@,gmlaw.com Christian D. Hammond Dalla Hammond, P.C Elizabeth Street Thornton, CO chris@dallahammond.com John Hodgden 205 W. Maple, Suite 806 Enid, OK pjh@nwok-law.net Rebekah B. Watada Assistant City Attorney 201 W. Colfax, Dept. 801 Rebekah.watada@denvergov.org By: s/ Sharon A. Chiecuto Sharon A. Chiecuto Peter Terrence Moore Langdon Jon Jorgensen Jennifer Christine Alldredge Robinson, Waters & O Dorision, P.C th Street, Suite

4 Sterling Consulting Corporation 4101 East Louisiana Avenue Suite 300 Denver, Colorado Office: Fax: INVOICE April 20, 2018 Client: IRMYH Receivership Denver District Court - Civil Action No. 17CV31274 For: Receiver's Professional Services and Expenses By: Sterling Consulting Corporation From: March 21, 2018 To: April 20, 2018 Date: Services: Hours Worked: Hours Billed: 21-Mar-18 Worked on Reply to AG re Instructions, T. Gillaspie Affidavit (1.75); prepared Pitch Deck, reveiwed 506 C exemption (2); worked on administrative matters (.75). 22-Mar-18 Reviewed ATE's Amended Claim, attachments (1.5); worked on Pearl sale, Tiago commitment (1.75); worked on Jane sale and zoning issues (1.25); worked on Pitch Deck, Reg D (1). 23-Mar-18 Worked on Second Receiver s Certificate (1); worked on S. Simon Claim (1); prepared detailed memo on procedures for Jane sale (1.75). 24-Mar-18 Prepared Sixth Report (2); worked on Second Receiver s Certificate (1). 25-Mar-18 Worked on Jane sale, zoning issues (.75) Mar-18 Worked on response to JE Stuebner, C Witkus regarding 4900 visit (2). 27-Mar-18 Reviewed Denver's new License Application process (.5); worked on data storage issues (.5) EXHIBIT 1

5 Invoice, IRMYH Receivership April 20, 2018 Page Mar-18 Worked on Pitch Deck (1.5) Mar-18 Reviewed Claim of K. Humphrey (1.5); worked on Pitch Deck (1); met with J. Goutell and K. Humphrey (2); worked on Pearl sale, title insurance (1). 30-Mar-18 Worked on Pearl sale, title insurance (1) Mar-18 Prepared detailed memo to J. Tanner (2) Apr-18 Worked on motion and proposed Confirmation Order (1.5); worked on budget and financial projections for all operations (1.75); worked on Sixth Report (1). 2-Apr-18 Reviewed Tiago title commitment with Tiago, reviewed A. Halstead for issues (1.25); prepared detailed memo to A. Halstead regarding issues in title commitment (1.75); reviewed recorded documents regarding Pearl (1); prepared market value balance sheet for total operation, prepared for hearing (2.5). 3-Apr-18 Prepared market value balance sheet for entire operation (3); prepared for and attended hearing (4, no charge for drive time -.5); worked on sale of Pearl, survey, title commitment (1). 4-Apr-18 Prepared analysis of Excel easement on Pearl Street property (1.25); worked on title commitment and survey issues (1); prepared market value balance sheet (1.75). 5-Apr-18 Prepared comments to Tiago title commitment on Pearl, prepared package of related documents (2.5); prepared and sent Receiver s Certificate (1); worked on objections to invoices (.5); reviewed report on marital waste (.5)

6 Invoice, IRMYH Receivership April 20, 2018 Page 3. 6-Apr-18 Prepared Pitch Deck, market value balance sheet (3); worked on ATE Stipulation and Order (.75); worked on administrative matters (.5); prepared letter in response to letter regarding 4900 Colorado Boulevard (.5). 7-Apr-18 Prepared market value balance sheet for entire operation (1). 9-Apr-18 Prepared for and attended hearing before the Special Master in the Divorce Action (3, no charge for drive time -.5); prepared summary of receiver's fees and expenses (1); reviewed and commented on waste letter (.75); worked on Shoen discovery (.5). 10-Apr-18 Prepared detailed memo and package of documents to J. Quattlebaum for Endless Ammo (2); worked on administrative matters (1). 11-Apr-18 Prepared letter to J.E. Stuebner (1.25) Apr-18 Worked on RJJ discovery (1); prepared Pitch Deck (1.25). 13-Apr-18 Worked on RJJ discovery (1); worked on Shoen discovery (1.5). 14-Apr-18 Worked on the Petition for Certiorari (2.5); prepared Pitch Deck (1.25); worked on discovery issues (.75). 16-Apr-18 Worked on the Petition for Certiorari (1); prepared Pitch Deck (1.25); worked on Jane transaction (.5). 17-Apr-18 Reviewed RJJ Motion for Summary Judgment (.5); worked on administrative, IRS matters (1); worked on Walter, Lopez, Corry commercial extorsion threat (1)

7 Invoice, IRMYH Receivership April 20, 2018 Page Apr-18 Prepared Pitch Deck, market value balance sheet (1.5); prepared Report on K. Humphrey Claim (1.75); worked on Jane transaction (.75). 19-Apr-18 Prepared letter to J.E. Stuebner (.5); prepared Report on K. Humphrey Claim (.5); worked on Walter, Lopez, Corry commercial extorsion threat (1); worked on Jane transaction (.75). 20-Apr-18 Worked on motion to extend time for Pitch Deck (1.5); worked on 4900 issues (.75); prepared package of documents for the Special Master (.5) First ten hours Hourly rate (first ten hours) This Invoice 3, Hours between ten and twenty Hourly rate (second ten hours) This Invoice 3, Hours above twenty Hourly rate above twenty hours , This Invoice 22, Less 20% retention -4, Total, This Invoice 17, Plus Retainage Nov - March 15, Expenses (from attached) 8, Pay this amount 42,203.33

8 Invoice, IRMYH Receivership April 20, 2018 Page 5. IRMYH Sterling Consulting Corporation March 21-April 20, 2018 Date Description Amount Incurred Amount Billed Postage 20-Apr-18 Postage Professional Fees 20-Apr-18 Professional Fees-Justin Block 1, , Apr-18 Professional Fees-Kim Fenimore 6, , Mar-18 Professional Fees-KXPN 1, , , Travel-Auto 3-Apr-18 Parking-Kim Fenimore Apr-18 Parking-Rick Block Grand Total Expense 9, ,813.33

9 Invoice, IRMYH Receivership April 20, 2018 Page 6. Sterling Consulting Corporation Accruals: Date: Description: Amount: 20-Nov-17 Retainage 4, Dec-17 Retainage 4, Feb-18 Retainage 3, Mar-18 Retainage 3, Total Accrued 15, Fairfield and Woods Accruals: Date: Description: Amount: 20-Apr-18 Invoice 18, Mar-18 Invoice 12, ,450.00

10 VERIFICATION STATE OF FLORIDA ) ) ss. COUNTY OF PALM BEACH ) I, Richard A. Block, being duly sworn upon oath, solemnly affirm as follows: I am the President of Sterling Consulting Corporation ("Sterling"); (b) Sterling is the receiver in Civil Action No. 2017CV in District Court, Denver County, Colorado, the Honorable Andrew P. McCallin, District Judge presiding; (c) I prepared all of the receiver's invoices in this Receivership Action on behalf of Sterling, including the Receiver's Invoice for the period March 21, 2018 to April 20, 2018 to which this Verification is attached; (d) all invoices (both the invoice to which this attached and those previously submitted) fairly reflect the work performed by the receiver authorized or directed by the District Court; and (e) the information contained therein is true and accurate to the best of my knowledge and belief. ~~ Sterling Consulting Corporation as receiver by Richard A. Block, President STATE OF FLORIDA ) ) ss. COUNTY OF PALM BEACH ) Subscribed and sworn to before me by Richard A. Block as the President of Sterling Consulting Corporation, LLC as receiver on the of May, Witness my hand and official seal. My commission expires: fj\ 1',.&. -~~---t~q---+-{_ o_b 1~8 GLENN LAUFER Notary Public, State of Florida Commission# FF M4f rflffl, iliplrt~ Awg, Q, th day