SUBMISSION OF RECEIVER S VERIFIED INVOICE THROUGH JUNE 20, 2018

Transcription

1 DISTRICT COURT, DENVER COUNTY, STATE OF COLORADO Court Address: 437 Bannock Street, Room 256 Denver, CO Phone: (720) Plaintiff: CITY AND COUNTY OF DENVER, a municipal Corporation of the State of Colorado, V. Defendants: TELE COMM RESOURCES, Limited Partnership, a Nevada Limited Partnership, also d/b/a TELE COMM RESOURCES, LP Attorneys for Receiver Sterling Consulting Corporation: John M. Tanner, #6233 Fairfield and Woods, P.C. 80 California Street Suite 2600 Denver, Colorado Phone: Fax: jtanner@fwlaw.com A COURT USE ONLY A Case Number: 205CV3098 Div.: 409 SUBMISSION OF RECEIVER S VERIFIED INVOICE THROUGH JUNE 20, 208 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 May 2, 208 through June 20, 208, attached as Exhibit. Respectfully submitted this 26th day of June, 208.

2 FAIRFIELD & WOODS, P.C. Original duly signed and on file for review By: s/ John M. Tanner John M. Tanner ATTORNEYS FOR RECEIVER, STERLING CONSULTING CORPORATION CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was E-filed through the Colorado Court s E-filing system this 26th day of June, 208, and E-served or sent via U.S. Mail as indicated, upon the following: E-Served: Jacques Alan Machol Machol & Johannes, LLC 700 7th Street, Ste. 200 Denver, CO VIA U.S. Mail to: Jeffrey P. Wright, GP Tele Comm Resource LP 5 Lewis Drive Lowman, Idaho and Douglas Bruce PO Box 2608 Colorado Springs, CO By: s/ Sharon A. Chiecuto Sharon A. Chiecuto 2

3 40 East Louisiana Avenue Suite 300 j j V Denver, Colorado I X' ' rblock@xpn.com INVOICE Client: For: By: From: To: June 20, 208 Cheesman Villa Condos - Lipan Professional Services and Expenses Sterling Consulting Corporation May 2, 208 June 20, 208 Date: Services: Hours Worked: Hours Billed: 2-May-8 Worked on Amendment to Contract to Buy and Sell Real Estate for Lipan sale (.25); reviewed, commented on, VCUP application (2); reviewed Xcel cost estimates for demolition (). 22-May-8 Worked on Amendment to Contract to Buy and Sell Real Estate for Lipan sale (.25); worked on utility demolition issues (.75); prepared detailed memo to S. Brown regarding title insurance issues at Cheesman (). 23-May-8 Worked on sale of Lipan, Amendment, title commitment, settlement statement (2.75); worked on Motion, Confirmation Order, Receiver s Deed for Lipan (.75); worked on City liens (.75). 24-May-8 Worked on VCUP application and issues (2.25); reviewed updated Title Commitment, Lipan (.5); worked on TyL objections to Cheesman Title Commitment (.5). 25-May-8 Worked on VCUP application and issues (2); worked on utility demolition issues (.75). 26-May-8 Worked on Motion for Order Confirming Sale of the Lipan Property (.5) EXHIBIT

4 Invoice, Cheesman Villas and Lipan June 20, 208 Page 2 27-May-8 29-May May-8 3- May-8 l-jun-8 4-Jun-8 5-Jun-8 6-Jun-8 Worked on Motion for Order Confirming Sale of the Lipan Property (4.5); made comments to title commitment for Lipan Property (2). Worked on Motion for Order Confirming Sale of the Lipan Property (2.5); made comments to title commitment for Lipan Property (.25). Worked on utility demolition isssues (.75). Worked on VCUP application. Worked on sale of Lipan, Amendment, title commitment, settlement statement, earnest money release from First American (2); worked on application for demolition permit (.75); prepared memo to P. Tobin (.75). Prepared schedule of liens for title company (.5); site inspection (, no charge for drive time -.5). Cheesman property inspection for burned Unit 03 (, no charge for drive time -.5); worked on Motion for Confirmation Order, exhibits, calculations of liens (2.75); worked on Amendment for Lipan Contract to Buy and Sell Real Estate (.5); worked on demolition and abatement issues (.25). Met with S. Sprinke, S. Brown, P. Tobin, and J. Tanner (.5, no charge for drive time -.25); assembled package of exception and requirement docuements for Cheesman, Lipan (2.5); worked on Amendments to Extend Contracts to Buy and Sell Real Estate for 3735 Units (2.25); worked on Motion for Confirmation Order, exhibits (.25)

5 Invoice, Cheesman Villas and Lipan June 20, 208 Pages 7-Jun-8 8-Jun-8 2- Jun-8 3- Jun-8 4- Jun-8 5- Jun-8 6- Jun-8 Worked on Amendments to Contracts to Buy and Sell Real Estate, 3735 York, Units 0, 02, and 03, processed payments to Tiago for Earnest Money Deposits, prepared letter to Tiago (2.5); obtained and processed 902 Plat Map and Dedication for Cheesman Property (); assembled package of Exceptions scheduled in the title insurance commitment for Buyer (2); reviewed and commented on Motion for Confirmation Order, Proposed Confirmation Order, and form of Receiver's Deed for Lipan Property (.75). Worked on Cheesman title exceptions (.75); worked on acquisition of three units, 3735 (.5). Met with P. Tobin, C. Higgins, J Johanson, Orion on site regarding abatement, demolition, and restoration of the site (2.5, no charge for drive time -.75); worked on Motion, Proposed Confirmation Order, Receiver s Deed for Lipan (.25); worked on abatement, demolition, Xcel demolition (2). Prepared analysis of Xcel demolition (); worked on Receiver s Certificate (.75). Prepared budget and timeline for Cheesman project (.5). Worked on Motion, Confirmation Order, Receiver s Deed for Lipan (2); prepared demolition cost analysis (). Worked on Earnest Money Release for Lipan (.5); prepared project cost analysis and budgets for Cheesman (.25); worked on drainage issues and requests (.5).

6 Invoice, Cheesman Villas and Lipan June 20, 208 Page 4 8-Jun-8 9-Jim-8 20-Jun-8 Worked on demolition and abatement issues (.75) Prepared detailed memo and budgets for Receiver s Certificate (.75). Worked on Lipan sale (.75); prepared for and attended conference call with S. Brown, S. Sprinkle, P. Tobin, and J. Tanner (.25); worked on demolition issues, cuts and caps locations for water and sewer (). Total hours First ten hours 0.00 Hourly rate (first ten hours) This Invoice 3, Hours between ten and twenty 0.00 Hourly rate (second ten hours) This Invoice 2, Hours above twenty Hourly rate above twenty hours , Total time charges for R. Block 6, Less 20% retention. (3,350.00) This Invoice 3, Plus 20% retention from May 20th 2, Expenses (from attached) 2,79.5 Payment on this Invoice 9,03.5

7 Invoice, Cheesman Villas and Lipan June 20, 208 Page 5 Cheesman Villa Expense Report Sterling Consulting Corporation May 2-June 20, 208 Date Description Amount Amount Incurred Billed Fencing fees 23-May-8 American Fence Company Professional 20-Jun-8 20-Jun-8 Fees Professional Fees-Justin Block Professional Fees-Kim Fenimore 3, , , , Travel-Auto 20-Jun-8 Mileage-Justin Block Grand Total Expense 3, ,79.5

8 INVOICE AMERICAN FENCE COMPANY INC 90 PEARL STREET THORNTON, CO (303) AMERICAN FENCE COMPANY Securing America Since 948 INVOICE Sold To: STERLING GROUP 40 E LOUISIANA AVE #300 DENVER, CO Ship to: STERLING GROUP 60 LIPAN STREET 60 LIPAN STREET DENVER, CO Invoice Date: 05/23/8 Invoice # : Request Date 05/23/8 Customer P.O. Ship: Inst: N26483 SHERRY A WILSON Description Ext. Price Work Performed Rental of 26 ft. of temporary fence. Rent from 05/23/8 through 06/22/8. **Please note that rent is not prorated.** N26483 Tax Amount : 3.65 Subtotal : Amount Paid: Amount Due : Thank You for Your Business! American Fence Company: 06349, 0569, , , 09483, 03476, 02556, , , , , A03, ; American Fence Company, Inc.: , C-8697, *550,37023, 37024: American Fence Company of New Mexico, Inc.: 00942! O DETACH THIS PORTION AND INCLUDE WITH PAYMENT ' Please disregard this invoice if payment has been made. Customer #: Order # : BL Send your remittance to: Related PO: American Fence Company Bra/Pit : P.O. Box 9040 Invoice # : Phoenix, AZ For billing inquiries only, call Amount Enclosed:

9 Justin Block Cheesmen Villa Invoice May 2 - June 20, 208 Date Description Time Miles 22-May-8 Going to office to work on utility pole problem and other things relating to demo on cheesman brought up in meeting May-8 Starting by trying to get someone on thne 4.00 phone about the poles then finding out that Jack Tanner knows someone and working with them to get someone out to the property and leaving early 24-May-8 Downloading and posting docs from docket May-8 29-May-8 Posting for Cheesman but not finishing either before leaving for meeting and to inspect each property Going to the office to follow up on Cheesman issues over the holiday weekend then answer all calls and working on posting once again May-8 Being food poisned and working from home on Cheesman issues relating to demo May-8 Landscape maintaince Cheesman alone l-jun-8 4-Jun-8 5-Jun-8 Working on getting things for demo project, inspecting site and working on getting utilities removed still Going to office to work on posting from docket to website starting by going to meeting about uitliy poles on the cheesman property and memo of what we talked about in meeting, then gonig to office to work on xcel bill that has no discription and work on getting all meter readings

10 Date Description Time Miles 3-Jun-8 Starting by working on Century link follow up then working on getting somthing show alley is vacated Jun-8 Doing all landscape maintance for Cheesman Totals Hourly Rate Grand Total 3,

11 Kim Fenimore May 2 -June 20, 208 Cheeseman Villa Billing Date Description Hours 06/2/208 Worked on going through the Xcel contracts, built a spreadsheet to make sure we got it all, on phone with Chris Higgens to talk about all this /3/208 Go through all the s between Rick and Chris and work through the accounting 0.50 Total Hours 2.50 Hourly Rate Grand Total 87.50

12 STATE OF COLORADO ) ) ss. COUNTY OF DENVER ) VERIFICATION 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. 205CV3098 in District Court, Denver County, Colorado, the Honorable Jennifer Bourn Torrington, 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 May 2, 208 to June 20, 208 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. STATE OF COLORADO ) ) ss. COUNTY OF DENVER ) Sterling Consulting Corporation as receiver by Richard A. Block, President Subscribed and sworn to before me by Richard A. Block as the President of Sterling Consulting Corporation, as receiver on the 25th day of June, 208. Witness my hand and official seal. My commission expires: ' KIMBERLY KAY FENIMORE Notary Public - State of Colorado ' < Notary ID > i My Commission Expires Jan, 202, Notary Puhli