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FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
JONES MORRISON, LLP
670 White PlainsRoad PH
Scarsdale, NY 10583
Telephone (914)472-2300
Facsimile (914) 472-2312
New York City Office
60 East 42nd Street, 40th Floor
New York,NY 10165
Telephone (212) 759-2500
Mr. Krzystof Wolyniec June 01, 2016
444 East Putnam Avenue, #1
Cos CT 06807 Client# 24864.001
Cob,
Invoice # 11896
In Reference To: Matrimonial-Post Judgment
Professional Services
Hours Amount
5/27/2016 HO MEETING WITH CLIENT ON HOUSING MATTER AND ON SUPERIOR 2.00 1,000.00
COURT FAMILY MATTER; DISCUSS AND REVIEW; ADDRESS ISSUES;
MOTIONS; CROSS-MOTIONS; OBJECTIONS; ISSUES; COUNSEL; ETC.;
5/31/2016 KM REVIEW OF AND ANALYZE HOUSING COMPLAINT AND NOTICE TO 0.80 220.00
QUIT, REVIEW AND ANALYZE AMENDED MOTION TO STAY IN
HOUSING MATTER, REVIEW JUDICIAL WEBSITE, REVIEW CONTEMPT
IN MATRIMONIAL MATTER AND SEPARATION AGREEMENT, OFFICE
CONVERSATION ATTORNEY OPINSKY.
For professional services rendered 2.80 $1,220.00
5/31/2016 Retainer Payment - Thank You ($5,000.00)
Total payments and adjustments ($5,000.00)
Credit balance ($3,780.00)
Attorney Summary
Name Hours Rate Amount
Heidi Opinsky 2.00 500.00 $1,000.00
Kristen Mazur 0.80 275.00 $220.00
Please review your billimmediately and contact our officewith any questions.
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
JONES MORRISON, LLP
670 White PlainsRoad PH
Scarsdale,NY 10583
Telephone (014) 472-2300
Facsimlle(914)472-2312
New York City Office
60 East 42nd Street, 40th Floor
New York, NY 10165
Telephone (212) 759-2500
Mr. KrzystofWolynlec August 01, 2018
444 East Putnam Avenue, #1
Cos Cob, CT 08807 Client# 24864.001
invoice # 12159
In Reference To: Matrimonial-Post Judgment
Professional Services I
Hours Amount
KM REVlEW HOUSING FILE AND AMENDED MOTION TO STAY HOUSING 1.70 467.50
MATTER, REVIEW AND RESEARCH HOUSING STATUTES,
TELEPHONE CALL HOUSING CLERK REGARDING HEARING AND
MOTIONS, OFFICE CONVERSATION.
HO OFFICE CONFERENCE ASSOCIATE ON LEGAL RESEARCH NEEDED 0.20 100.00
FOR HOUSING COURT CASE AND TO CONTACT COURT;
6/2/2016 KM REVlEW HOUSING FILE AND MOTIONS FILED BY CLIENT, DRAFT 0.70 192.50
OBJECTION TO AMENDED MOTION TO STAY, REVIEW AND ANALYZE
MATRIMONIAL JUDGMENT AND MOTION FOR CONTMEPT
6/3/2016 HO EMAIL CLIENT ON MOTION FOR STAY ON 6.14; ADDRESS; 0.20 100.00
OBJECTION AND RESPONSE AND MOTION WILL DO; REVIEW CASE
DOCKET; OFFICE CONFERENCE ASSOCIATE; REVIEW MOTION;
6/7/2016 HO REVIEW FILE; REVIEW STATUTES AND CASELAW PERTINENT TO 3.00 1,500.00
LEGAL ARGUMENTS TO BE ADVANCED; OFFICE CONFERENCE
ASSOCIATE; PREPARE TIMELINE; PERFORM LEGAL RESEARCH FOR
MORE CASES ON CASE FACTS; AND STATUTES REQUIRED AND
CITED IN MOTIONS; OBTAIN; REVIEW;
61812016 KM REVIEW AND ANALYZE HOUSING STATUTES AND RESEARCH CASE 3.00 825.00
LAW REGARDING RENTAL INCOME AND FILING OF SUMMARY
PROCESS IN HOUSING COURT, MULTIPLE OFFICE CONVERSATIONS
REGARDING MOTIONS TO FILE, PREPARE MATRIMONIAL MOTION
FOR CONTEMPT, OBJECTION TO WIFE'S MOTION FOR CONTEMPT,
AND MOTION TO ENFORCE MATRIMONIAL JUDGMENT
!
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Mr. Krzystof Wolyniec Page 2
Hours Amount
6/8/2016 HO ADDRESS SEVERAL; EMAIL EXCHANGES AND TELEPHONE 1.50 750.00
CONFERENCES CLIENT ON THEORY OF CASE AND ISSUES THAT
ARE GOOD AND THOSE THAT ARE PROBLEMATIC; REVIEW FILE:
REVIEW CASE LAW AND STATUTES; REVIEW MOTIONS FILED IN
HOUSING COURT; TELEPHONE CONFERENCE CALLS HOUSING
COURT; OFFICE CONFERENCES CUENT; ADDRESS;
HO LEGAL RESEARCH FOR ALL PERTINENT CASE LAW AND CITED 1.00 500.00
STATUTES CONTINUED: OFFICE CONFERENCE ASSOCIATE TO
PREPARE MOTION EXCLUSlVE OCCUPANCY AND FOR PAYMENTS,'
PAYMENTS;
TELEPHONE CONFERENCES CLIENT;
6/9/2016 KM REVIEW EMAILS HEO, REVIEW CASELAW, EMAll CLIENT, OFFICE 1.00 275.00
I, CONVERSATION, PREPARE FOR HEARING
!
HO REVIEW FILE; PREPARE; REVIEW AND REVISE MOTIONS TO 0.40 200.00
ENFORCE AND FOR CONTEMPT AND OUR MOTIONS HOUSING
COURT FOR OCCUPANCY AND DAMAGES AND RENT; OBJECTIONS
AND MOTIONS FILED IN SUPERIOR COURT AGAINST FERRARA
CONTEMPT MOTION ON AllMONY ARREARS; ADDRESS CLIENT
EMAILS,'
INQUIRIES; EMAILS;
6/10/2016 KM DRAFT MOTION TO ENFORCE POST MAJORITY EDUCATIONAL 0.80 220.00
!, SUPPORT ORDER, OFFICE CONVERSATION, MEMO TO FILE.
I
HO REVIEW FILE AND CASE LAW IN ADVANCE OF CLIENT MEETING AND 3.00 1,500,00
PREPARE FOR HEARINGS; OFFICE CONFERENCE CLIENT FOR
I
! TRIAL PREPARATION;
6/13/2016 KM PLAN AND PREPARE FOR HOUSING COURT HEARING, PREPARE 5.00 1,375.00
TRIAL BlNDER AND EXHIBITS, PREPARE MOTIONS AND FILE,
PREPARE AND REVIEW OF SUPPORTING CASE LAW AND
DOCUMENTS, MULTIPLE OFFICE CONVERSATIONS, TELEPHONE
CALLS WITH ATTORNEY HEISLER OFFICE RE CONTINUANCE,
OFFICE CONVERSATION, REVIEW JUDICIAL SITE RE CONTINUANCE,
DRAFT RESPONSE TO CONTINUANCE REQUEST AND EFILE
6/14/2016 HO HEARING PREPARATION; REVIEW TRIAL BOOKS; PREPARE CASE 1.50 750.00
LAW FOR ARGUMENT; OFFICE CONFERENCES ASSOCIATE;
TELEPHONE CONFERENCES CLIENT; PREPARE OBJECTION TO
CONTINUANCES; SEVERAL TELEPHONE CONFERENCES COURT
AND COUNSEL ON HOUSING MATTER;
6/15/2016 H0 OFFICE CONFERENCE ASSOCIATE TO ADDRESS CONTINUANCE 0.50 250.00
GRANTED SUA SPONTE DATE BY COURT; CONTACT OPPOSING
COUNSEL; PREPARE, REVIEW AND REVISE AND FILE NEW MOTION
. CONTINUANCE; SEVERAL EMAILS AND TELEPHONE CONFERENCES
CLIENT;
6/16/2016 HO REVIEW AND ADDRESS CLIENT MANY DETAILED EMAILS AND 0.50 250,00
TELEPHONE CONFERENCES CLIENT ON HOUSING MATTER;
I
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Mr. Krzystof Wolyniec Page 3
Hours Amount
6/17/2016 HO EMAILS AND TELEPHONE CONFERENCES CARL FERRARA AND 0.40 200,00
CLIENT AND ADDRESS GLOBAL SETTLEMENT CONCEPTS;
6/21/2016 KM DRAFT REQUEST FOR PRODUCTION AT HEARING, REVIEW 1.00 275.00
MOTIONS FILED AND RELIEF REQUESTED, REVIEW DOCUMENTS IN
FILE
HO CARL FERRARA SCHEDULE NOW CHANGED FOR 8.2 OR 8.3 ; 0.10 50.00
ADVISE CLIENT;
6/22/2016 KM OFFICE CONVERSATION, REVISIONS TO REQ UEST TO PRODUCE AT 2.30 632.50
HEARING, PREPARE NOTICE OF FILING, EMAIL TO CLIENT, REVIEW
EMAILS AND DISCUSS ATTORNEY OPINSKY, PREPARE EXHIBITS
AND DOCUMENTS FOR HEARING, LEGAL RESEARCH.
6/23/2016 KM PLAN AND PREPARE EXHIBITS FOR HEARING, PREPARATION OF 4.00 1,100.00
MOTIONS, CLIENT NOTES AND EMAILS, AND DOCUMENTS FOR
HOUSING HEARING, RESEARCH, MULTIPLE OFFICE
CONVERSATIONS
HO PREPARATION FOR FOUR-WAY; REVIEW CLIENT RECORDS AND 2.00 1,000.00
EXCEL SHEET ON PAYMENTS; TELEPHONE CONFERENCES AND
EMAILS CLIENT; PREPARE AND DISCUSS WITH CLIENT; ADDITIONAL
PROOF NECESSARY; CLIENT TO REDO SCHEDULE REQUEST TO
PRODUCE DISCUSSED; FOUR-WAY CANCELLED; CARL FERRARA
EMERGENCY,'
FAMILY EMERGENCY;
6/24/2016 HO RESCHEDULE FOUR-WAY WITH CARL FERRARA AND CLIENT; 0.50 250.00
SEVERAL TELEPHONE CONFERENCES; SET TWO DATES FOR NEXT
WEEK; CARL AGREES TO MARK HIS MOTION FOR CONTEMPT AND
ALIMONY ARREARS OFF CALENDAR;
6/28/2016 KM APPEAR IN COURT TO ENSURE WIFE'S CONTEMPT MARKED OFF BY 0.50 137.50
ATTORNEY FERRARO; TRAVEL TO AND FROM COURTHOUSE
HO ADDRESS SETTLEMENT ISSUES WITH CARL FERRARA DURING 0.40 200.00
TIME SLOT THAT WAS ON FOR CONFERENCE;
HO CONFIRMATION MOTIONS ARE MARKED OFF WITH CARL FERRARA 0.40 200.00
AND ADVISE CLIENT; EMAIL EXCHANGES; DISCUSS MEETING AGAIN
TO SETTLEMENT GLOBALLY SUPERIOR COURT CASE;
6/29/2016 HO ADDRESS DATES FOR FOUR-WAY SETTLEMENT CONFERENCE 0.20 100.00
WITH CLIENT AND COUNSEL; ADDRESS;
6/30/2016 KM TELEPHONE CALL WITH HOUSING CLERK REGARDING COURT 1.00 275,00
AVAILABILITY FOR CONTINUANCE OF HEARING, OFFICE
CONVERSATION, REVIEW EMAILS FROM HEO AND CLIENT
REGARDING CONTINUANCE, EMAIL TO ATTORNEY HEISLER AND
TELEPHONE CALL REGARDING CONTINUANCE
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Mr. KrzystofWolyniec Page 4
Hours Amount
7/1/2016 HO EMAILS WITH CLIENT TO ARRANGE FOUR-WAY; LEFT MESSAGE 0.10 50.00
WITH CARL FERRARA INDATES;
KM REVIEW EMAIL ATTORNEY HEISLER RE HOUSING CONTINUANCE 1.00 275.00
REQUEST; E-FILE CONTINUANCE HEARING DATE WITH COURT AND
EMAIL ATTORNEY HEISLER; REVIEW COURT WEBSITE RE
CONTINUANCE REQUEST; OFFICE CONFERENCE RE CONTINUANCE
DATE; EMAIL TO CLIENT
7/18/2016 HO ATTEMPT TO RESCHEDULE FOUR-WAY: EMAILS EXCHANGED WITH 0.10 50.00
COUNSEL GOOD FOR 8.2 OR 8.3 AT 5:00.
7/19/2016 HO REVIEW AND RESPOND TO EMAIL EXCHANGES WITH CUENT ON 0.20 100.00
FOUR-WAY AND HOUSING COURT; OFFICE CONFERENCE
ASSOCIATE
7/21/2016 KM EMAIL TO CLIENT RE MEETING AND PREPARATION FOR HEARING; 0.20 55.00
REVIEW RESPONSE; OFFICE CONVERSATION
7/22/2016 HO WOLYNIEC HOUSING COURT ISSUES DISCUSSED WITH CLIENT 0.20 100.00
THAT HOUSING COURT LIKELY TO DO NOTHING DUE TO SUPERIOR
COURT ACTION FAMILY MATTER EXCLUSlVE ORIGINAL
JURISDICTION SUPERIOR TO HOUSING COURT;; ADVISED CLIENT;
CLIENT PITCHES EVICTION STATUTORY BUT NO AGREEMENT TO
LEASE HERE AND MOTHER; LIVED THERE FOR YEARS; NO MONEY
TO MOVE LlKELY TO IMPACT STAY BEING GRANTED; ADVISED; WILL
TRY TO PITCH MOVING FORWARD BY COURT AND WILL SEE;
KM PREPARATION OF EXHIBITS AND DOCUMENTS FOR HEARING 2,00 550.00
! 7/25/2016 HO MOTION FOR USE & OCCUPANCY & PAYMENTS & COUNSEL FEES IN 0.50 250.00
HOUSING COURT; OFFICE CONFERENCE ASSOCIATE
7/26/2016 KM PLAN AND PREPARE EXHIBITS, TRIAL BlNDER FOR HOUSING 4.00 1,100.00
HEARING, TELEPHONE CALL HOUSING CLERK RE CONTINUANCE
OF HEARING TO AUGUST 2ND; EMAILS TO CLIENT; OFFICE
CONFERENCE AND EMAILS TO HEO REGARDING CONTINUANCE BY
COURT; REVIEW JUDICIAL WEBSITE; RESEARCH FOR HEARING
HO EMAILS ATTORNEY TO RESOLVE ISSUES 0.20 100.00
7/27/2016 KM PREPARE TRIAL BINDER FOR HOUSING HEARING; RESEARCH RE 4.00 1,100.00
SUMMARY PROCESS MATTERS AND EVICTION
HO HOUSING COURT TELEPHONE CONFERENCE MOVED HEARING NO CHARGE
FROM 7.28 TO NEXT WEEK -- ADVISE OFFICE CONFERENCE
CLIENT;
ASSOCIATE
HO ATTEMPT TO RESCHEDULE 4-WAY WITH CARL FERRARO. SEVERAL 0.50 250.00
EMAILS COUNSEL & CLIENTS ON DATES 8.9;8.10; 8.11;ADDRESS
WITH CUENT.
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
I
Mr. Krzystof Wolynlec Page 5
Hours Amount
,
7/27/2016 HO SEVERAL EMAILS EXCHANGED COUNSEL & CLIENT OFFICE 0.30 150.00
CONFERENCE WITH ASSOCIATE; SCHEDULE 4-WAY & ADDRESS
WITH CLIENT.
HO TELEPHONE CONFERENCE CLIENT. 0.20 100.00
7/28/2016 KM PREPARE TRIAL BINDER, CASELAW BlNDER FOR HOUSING 5.00 1,375.00
HEARING; OFFICE CONVERSATION RE TRIAL BINDER; EMAILS TO
AND FROM CLIENT RE ZILLOW VALUE HOME AND PICTURES
NEEDED AS EXHIBITS; INTERNET RESEARCH REGARDING RENTAL
VALUE OF HOME; REVIEW MOTIONS; PREPARE MOTION FOR
COUNSEL FEES; RESEARCH RE ATTORNEY FEE ORDERS IN
HOUSING AND SUMMARY PROCESS ACTIONS
HO TRIAL PREPARATION; REVIEW & PREPARE FILE; REVIEW CASE LAW 2.00 1,000.00
RESEARCH EXHIBITS; TRIAL BOOKES; PREPARE; REVIEW & REVISE;
SEVERAL EMAILS CLIENT ON NECESSARY FURTHER EXHIBITS;
TELEPHONE CONFERENCE SCHEDULE.
For professional services rendered 57,30 $20,280,00
Previous balance ($3,780.00)
Balance due $16,500.00
Attorney Summary
Name Hours Rate Amount
Heidi Opinsky 20.10 500.00 $10,050.00
Kristen Mazur 37.20 275.00 $10,230.00
Please review your bill
immediately and contact our office with any questions,
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Law Offices of Heidi E. Opinsky, LLC
One Landmark Square
21st Floor
Stamford, Connecticut 06901
T: 203.653.3542
F: 203.653.3545
Krzysztof Wolyniec
444 East Putnam Avenue
#1
Cos Cob, CT 06807
September 01, 2016
In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment
Matrimonial and Housing
Professional Services
Hours Amount
8/1/2016 HO PREPARE FOR HEARING; MAKE NOTES; PROVIDE CLIENT; 4.00 2,000.00
PREPARE TRIAL BOOK AND NOTES;
HO TRIAL PREPARATION ALL AFTERNOON AND EVENING; SEVERAL 8.00 4,000.00
EMAIL EXCHANGED; REJECT REQUEST FOR CONTINUANCE;
COMMUNICATE WITH COURT; CASE PROCEEDING; PREPARE TRIAL
NOTES THROUGHOUT EVENING UNTIL 11:00 AND REQUEST FOR
LEGAL FEES AND AFFIDAVIT AND EXHIBITS; EMAILS CLIENT AND
COUNSEL OBJECTING TO CONTINUANCE;
8/2/2016 HO PREPARE IN MORNING PRIOR TO HEARING; APPEAR IN COURT; 4.00 2,000.00
MEET WITH COUNSEL; CLIENT AND COURT MEDIATOR; MEDIATOR
SET DOWN ADVANCED DATE 8.25; IN COURT ALL MORNING;
HO PREPARE FOR COURT; APPEARANCE COURT FOR HEARING; MET 3.50 1,750.00
WITH COURT MEDIATOR; ATTENDED CALL OF CALENDAR; MATTER
PUT OVER TO 8/25;
8/9/2016 HO SEVERAL EMAILS CLIENT AND COUNSEL TO CONTINUE MEETING 3.00 1,500.00
AT HIS OFFICE; PREPARE FILE; FOUR-WAY CONFERENCE AT CARL
FERRARO'S OFFICE
8/10/2016 HO EMAILS EXCHANGED WITH CLIENT REGARDING ISSUES 0.40 200.00
DISCUSSED AT CONFERENCE; PAYMENTS COLLEGE; SUPPORT;
ESCROW; FEES; ETC.
8/11/2016 HO EMAILS EXCHANGED WITH CLIENT ON RESOLUTION OBJECTIVES 0.40 200.00
AND DIFFERENT SCENARIOS;
8/12/2016 KM WESTLAW RESEARCH REGARDING DEFAULT FOR FAILURE TO 1.00 275.00
PLEAD AND ISSUE OF APPLICABILITY OF CLOSED PLEADINGS IN
SUMMARY PROCESS MATTERS; OFFICE CONVERSATION HEIDI.
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Krzysztof Wolyniec Page 2
Hours Amount
8/12/2016 HO EMAILS CLIENT ON COURT PUTTING CASE OVER TO 9/8 AS COURT 0.40 200.00
DOCKET WAS FILLED AND NOT ROOM FOR HEARING; ADDRESS
WITH CLIENT COURT PUT OVER SUA SPONTE;
8/14/2016 HO EMAILS EXCHANGED WITH CLIENT ON THOUGHTS AND 0.30 150.00
SCENARIOS FOR RESOLUTION;
8/30/2016 HO OFFICE CONFERENCE ASSOCIATE AND EMAILS CLIENT; 0.20 100.00
For professional services rendered 25.20 $12,375.00
Accounts receivable transactions
9/27/2016 Invoice $16,500.00
9/27/2016 Payment - Thank You 9/8/16 ($5,000.00)
Total payments and adjustments $11,500.00
Balance due $23,875.00
Attorney Summary
Name Hours Rate Amount
Heidi E. Opinsky 24.20 500.00 $12,100.00
Kristen Mazur 1.00 275.00 $275.00
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Law Offices of Heidi E. Opinsky, LLC
One Landmark Square
21st Floor
Stamford, Connecticut 06901
T: 203.653.3542
F: 203.653.3545
Krzysztof Wolyniec
444 East Putnam Avenue
#1
Cos Cob, CT 06807
October 01, 2016
In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment
Matrimonial and Housing
Professional Services
Hours Amount
9/6/2016 HO SEVERAL EMAILS EXCHANGED; OFFICE CONFERENCE ASSOCIATE 0.40 200.00
TO FOLLOW; ADDRESS; PREPARE FILE FOR COURT; TELEPHONE
CONFERENCE CLIENT ON FINANCIAL AFFIDAVIT; NOTICE TO QUIT;
ETC.;
9/7/2016 HO DOZENS OF EMAILS THROUGHOUT DAY AND TELEPHONE 4.00 2,000.00
CONFERENCES CLIENT ON UPDATED EXECUTED LEASES; RENT
BY AGREEMENT V. ZILLOW VALUES; ADDRESS WITH CLIENT; NEED
FULLY EXECUTED LEASES; DISCUSS SUPERIOR COURT HAS
EXCLUSlVE CONTINUING JURISDICTION WITH CLIENT AND LIKELY
WILL DISMISS AND REFER TO SUPERIOR COURT MATTER; WILL
FIGHT AS HARD AS CAN; CLIENT ISAWARE AND FINANCIAL
AFFIDAVIT ISSUE IF FEES ARE BROUGHT UP; PREPARE UPDATED
AFFIDAVIT ON FEES; CLIENT WISHES TO BlFURCATE ISSUE;
EMAILS THROUGHOUT DAY; PREPARE FOR HEARING; PREPARE
CLIENT'S NOTES TO REVIEW FOR COURT; CONCLUDE IN EVENING
AND SEND TO CLIENT; PREPARE FILE FOR HEARING; REVIEW FILE
AND PREPARE FOR HEARING DURING DAY AND CONTINUlNG
DURING EVENING WITH CLIENT;
9/8/2016 HO PREPARE AND ATTEND HEARING HOUSING COURT; REVIEW FILE 3.50 1,750.00
FOR COURT IN A.M.; MEET WITH CLIENT;
9/9/2016 KM PREPARE RECLAIM ALL PLAINTIFF MOTIONS, FAX FILE WITH 0.50 137.50
COURT, EMAIL CARL FERRARO, REVIEW EMAIL CARL FERRARO
ENCLOSING HIS RECLAIM AND APPEARANCE
HO OFFICE CONFERENCE ASSOCIATE; RECLAIM MOTIONS IN 0.20 100.00
SUPERIOR COURT POST-JUDGMENT PROCEEDINGS;
9/13/2016 HO SEVERAL EMAILS EXCHANGED DURING DAY WITH CLIENT ON 0.80 400.00
MOTIONS IN SUPERIOR COURT AND AMENDMENTS; PREPARE,
REVIEW AND REVISE MOTIONS; EMAILS ON FINANCIAL AFFIDAVIT
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Krzysztof Wolyniec Page 2
Hours Amount
IF SEEKING FEES; CLIENT NOT DISPUTING THE 200k IN PAYMENTS;
ADDRESS ISSUES WITH CLIENT; DISCUSS;
9/21/2016 KM MARK PLAINTIFF'S MOTIONS READY FOR 10/3 CALENDAR, EMAIL 1.30 357.50
TO CLIENT RE AVAILABILITY, REVISE AND AMEND MOTIONS TO
REMOVE EDUCATIONAL SUPPORT ORDER REFERENCES, OFFICE
CONVERSATION RE REVISIONS, REVIEW AND FILE WITH COURT,
EMAIL TO ATTORNEY FERRARO
9/28/2016 KM PREPARE FILE FOR HEARING 1.00 275.00
9/29/2016 HO OFFICE CONFERENCE ASSOCIATE TO ADDRESS COURT 0.20 100.00
APPEARANCES WITH CLIENT;
9/30/2016 HO OFFICE CONFERENCE ASSOCIATE TO READY FILE FOR COURT; 0.40 200.00
EMAILS CLIENT; REVIEW MOTION FEES TO HOLD IN FILE;
For professional services rendered 12.30 $5,520.00
Previous balance $23,875.00
Balance due $29,395.00
Attorney Summary
Name Hours Rate Amount
Heidi E. Opinsky 9.50 500.00 $4,750.00
Kristen Mazur 2.80 275.00 $770.00
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Law Offices of Heidi E. Opinsky, LLC
One Landmark Square
21st Floor
Stamford, Connecticut 06901
T: 203.653.3542
F: 203.653.3545
Krzysztof Wolyniec
444 East Putnam Avenue
Cos Cob, CT 06807
November 01, 2016
In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment
Matrimonial and Housing
Professional Services
Hours Amount
10/3/2016 HO PREPARE FOR COURT APPEARANCE COURT ON WOLYNIEC; MEET 4.00 2,000.00
WITH OTHER SIDE; APPEAR BEFORE COLIN; SENT TO FAMILY
MEET'
RELATIONS BY COLIN; MEET WITH COUNSEL ALONE AND THEN
WITH FAMILY RELATIONS; PARTIES MET ALONE AND THEN WITH
COUNSEL; MET WITH JEFF DIAMOND FOR DATES; RECEIVE
NOTICE COLIN SET MATTER DOWN FOR JUDICIAL PRETRIAL 11.1.
ADVISE CLIENT; PREPARE, REVIEW AND REVISE UPDATED
DOCUMENTS IN FILE FOR APPEARANCE;
KM TELEPHONE CALLS HEO RE AFFIDAVIT COUNSEL FEES AND 1.50 412.50
UPDATING FOR MATRIMONIAL MOTIONS, REVIEW AND UPDATE
AFFIDAVIT OF FEES, WALK TO AND FROM COURTHOUSE WITH
AFFIDAVIT
10/5/2016 KM EMAIL TO CLIENT RE COURT DATES FOR PRETRIAL AND HEARING, 0.40 110.00
REVIEW JUDICIAL WEBSITE, OFFICE CONFERENCE, REVIEW NOTES
10/28/2016 HO PREPARE FOR JUDICIAL PRETRIAL; GO THROUGH TRIAL BOOK 1.00 500.00
WITH ASSOCIATE; REVIEW AND UPDATE DOCUMENTS AND
AFFIDAVIT OF FEES WITH ASSOCIATE; ADVISE TO FOLLOW-UP
WITH CLIENT;
10/31/2016 HO OFFICE CONFERENCE ASSOCIATE ON AMENDED MOTIONS AND 0.70 350.00
READY MARKINGS; REVIEW AMENDMENTS TO MOTIONS AND
READY MARKINGS; EMAIL EXCHANGES WITH COUNSEL; ADDRESS
DATES AND MOTIONS WITH CLIENT; REVIEW AND PREPARE TRIAL
BOOK TO ENSURE DOCUMENTS IN ORDER FOR JUDICIAL
PRETRIAL TOMORROW; ADDRESS SCHEDULING PREPARATION;
APPEARANCE WITH CLIENT WITH ASSOCIATE; FOLLOW;
KM OFFICE CONFERENCE RE PRETRIAL, PREPARATION OF FILE, 1.50 412.50
EXHIBITS, MOTIONS FOR PRETRIAL CONFERENCE
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Krzysztof Wolyniec Page 2
Amount
For professional services rendered 9.10 $3,785.00
Previous balance $29,395.00
Balance due $33,180.00
Attorney Summary
Name Hours Rate Amount
Heidi E. Opinsky 5.70 500.00 $2,850.00
Kristen Mazur 3.40 275.00 $935.00
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018
NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018
Law Offices of Heidi E. Opinsky, LLC
One Landmark Square
21st Floor
Stamford, Connecticut 06901
T: 203.653.3542
F: 203.653.3545
Krzysztof Wolyniec
444 East Putnam Avenue
#1
Cos Cob, CT 06807
December 01, 2016
In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment
Matrimonial and Housing
Professional Services
Hours Amount
11/1/2016 KM PREPARE DOCUMENTS AND EXHIBITS FOR PRETRIAL, UPDATE 1.00 275.00
AFFIDAVIT OF ATTORNEY FEES
11/28/2016 HO EMAILS FROM JEFF DIAMOND IN COURT AND COUNSEL 0.20 100.00
EXCHANGED REGARDING SCHEDULING HEARING AND DATES;
11/29/2016 HO TELEPHONE CALL TO CLIENT AND EMAIL TO CALL TO DISCUSS 0.50 250.00
MATTER; HEARD FROM OPPOSING COUNSEL AND THEY WILL
SETTLEALONGTERMSRECOMMENDED BY COURT;
COMMUNICATE WITH CLIENT; CLIENT DID NOT RETURN CALLS,
ONLY EMAIL INDICATING HE REFUSES SETTELMENT DISCUSSIONS
WITHOUT HEARING MATTER OUT; CLIENT ADVISES IN MIDST OF
MOVE AND CANNOT SPEAK; DOES NOT PROVIDE NEW CONTACT
INFORMATION;
11/30/2016 HO CLIENT PROVIDED AUTHORIZATION TO PAY BILL LAST IN COURT; 0.50 250.00
RESEND CREDIT CARD AUTHORIZATION FOR PAYMENT AND ASK
AND LOOK FORWARD TO DISCUSS CASE SETTLEMENT OR
PREPARATION FOR HEARING AND SCHEDULING ISSUES UPON
COURT NOTICE; SEVERAL CLIENT EMAILS REFUSES TO
NEGOTIATE UNDER 150K NET SETTLEMENT TO CLIENT IS AROUND
WHAT HE WANTS AND ADVISE; LENGTHY EMAIL EXCHANGE AND
EMAILS TO CLlENT ON IN BEST INTERESTS TO SETTLE BASED
JUDGES'
UPON RECOMMENDATIONS FAVORABLE TO HIM; ADVISE
HOW TAX IMPACT IS AROUND NUMBER HE WANTS; CLIENT
REFUSES TO DISCUSS EXCEPT ON HIS TERMS THAT ARE
Preview
FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 JONES MORRISON, LLP 670 White PlainsRoad PH Scarsdale, NY 10583 Telephone (914)472-2300 Facsimile (914) 472-2312 New York City Office 60 East 42nd Street, 40th Floor New York,NY 10165 Telephone (212) 759-2500 Mr. Krzystof Wolyniec June 01, 2016 444 East Putnam Avenue, #1 Cos CT 06807 Client# 24864.001 Cob, Invoice # 11896 In Reference To: Matrimonial-Post Judgment Professional Services Hours Amount 5/27/2016 HO MEETING WITH CLIENT ON HOUSING MATTER AND ON SUPERIOR 2.00 1,000.00 COURT FAMILY MATTER; DISCUSS AND REVIEW; ADDRESS ISSUES; MOTIONS; CROSS-MOTIONS; OBJECTIONS; ISSUES; COUNSEL; ETC.; 5/31/2016 KM REVIEW OF AND ANALYZE HOUSING COMPLAINT AND NOTICE TO 0.80 220.00 QUIT, REVIEW AND ANALYZE AMENDED MOTION TO STAY IN HOUSING MATTER, REVIEW JUDICIAL WEBSITE, REVIEW CONTEMPT IN MATRIMONIAL MATTER AND SEPARATION AGREEMENT, OFFICE CONVERSATION ATTORNEY OPINSKY. For professional services rendered 2.80 $1,220.00 5/31/2016 Retainer Payment - Thank You ($5,000.00) Total payments and adjustments ($5,000.00) Credit balance ($3,780.00) Attorney Summary Name Hours Rate Amount Heidi Opinsky 2.00 500.00 $1,000.00 Kristen Mazur 0.80 275.00 $220.00 Please review your billimmediately and contact our officewith any questions. FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 JONES MORRISON, LLP 670 White PlainsRoad PH Scarsdale,NY 10583 Telephone (014) 472-2300 Facsimlle(914)472-2312 New York City Office 60 East 42nd Street, 40th Floor New York, NY 10165 Telephone (212) 759-2500 Mr. KrzystofWolynlec August 01, 2018 444 East Putnam Avenue, #1 Cos Cob, CT 08807 Client# 24864.001 invoice # 12159 In Reference To: Matrimonial-Post Judgment Professional Services I Hours Amount KM REVlEW HOUSING FILE AND AMENDED MOTION TO STAY HOUSING 1.70 467.50 MATTER, REVIEW AND RESEARCH HOUSING STATUTES, TELEPHONE CALL HOUSING CLERK REGARDING HEARING AND MOTIONS, OFFICE CONVERSATION. HO OFFICE CONFERENCE ASSOCIATE ON LEGAL RESEARCH NEEDED 0.20 100.00 FOR HOUSING COURT CASE AND TO CONTACT COURT; 6/2/2016 KM REVlEW HOUSING FILE AND MOTIONS FILED BY CLIENT, DRAFT 0.70 192.50 OBJECTION TO AMENDED MOTION TO STAY, REVIEW AND ANALYZE MATRIMONIAL JUDGMENT AND MOTION FOR CONTMEPT 6/3/2016 HO EMAIL CLIENT ON MOTION FOR STAY ON 6.14; ADDRESS; 0.20 100.00 OBJECTION AND RESPONSE AND MOTION WILL DO; REVIEW CASE DOCKET; OFFICE CONFERENCE ASSOCIATE; REVIEW MOTION; 6/7/2016 HO REVIEW FILE; REVIEW STATUTES AND CASELAW PERTINENT TO 3.00 1,500.00 LEGAL ARGUMENTS TO BE ADVANCED; OFFICE CONFERENCE ASSOCIATE; PREPARE TIMELINE; PERFORM LEGAL RESEARCH FOR MORE CASES ON CASE FACTS; AND STATUTES REQUIRED AND CITED IN MOTIONS; OBTAIN; REVIEW; 61812016 KM REVIEW AND ANALYZE HOUSING STATUTES AND RESEARCH CASE 3.00 825.00 LAW REGARDING RENTAL INCOME AND FILING OF SUMMARY PROCESS IN HOUSING COURT, MULTIPLE OFFICE CONVERSATIONS REGARDING MOTIONS TO FILE, PREPARE MATRIMONIAL MOTION FOR CONTEMPT, OBJECTION TO WIFE'S MOTION FOR CONTEMPT, AND MOTION TO ENFORCE MATRIMONIAL JUDGMENT ! FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Mr. Krzystof Wolyniec Page 2 Hours Amount 6/8/2016 HO ADDRESS SEVERAL; EMAIL EXCHANGES AND TELEPHONE 1.50 750.00 CONFERENCES CLIENT ON THEORY OF CASE AND ISSUES THAT ARE GOOD AND THOSE THAT ARE PROBLEMATIC; REVIEW FILE: REVIEW CASE LAW AND STATUTES; REVIEW MOTIONS FILED IN HOUSING COURT; TELEPHONE CONFERENCE CALLS HOUSING COURT; OFFICE CONFERENCES CUENT; ADDRESS; HO LEGAL RESEARCH FOR ALL PERTINENT CASE LAW AND CITED 1.00 500.00 STATUTES CONTINUED: OFFICE CONFERENCE ASSOCIATE TO PREPARE MOTION EXCLUSlVE OCCUPANCY AND FOR PAYMENTS,' PAYMENTS; TELEPHONE CONFERENCES CLIENT; 6/9/2016 KM REVIEW EMAILS HEO, REVIEW CASELAW, EMAll CLIENT, OFFICE 1.00 275.00 I, CONVERSATION, PREPARE FOR HEARING ! HO REVIEW FILE; PREPARE; REVIEW AND REVISE MOTIONS TO 0.40 200.00 ENFORCE AND FOR CONTEMPT AND OUR MOTIONS HOUSING COURT FOR OCCUPANCY AND DAMAGES AND RENT; OBJECTIONS AND MOTIONS FILED IN SUPERIOR COURT AGAINST FERRARA CONTEMPT MOTION ON AllMONY ARREARS; ADDRESS CLIENT EMAILS,' INQUIRIES; EMAILS; 6/10/2016 KM DRAFT MOTION TO ENFORCE POST MAJORITY EDUCATIONAL 0.80 220.00 !, SUPPORT ORDER, OFFICE CONVERSATION, MEMO TO FILE. I HO REVIEW FILE AND CASE LAW IN ADVANCE OF CLIENT MEETING AND 3.00 1,500,00 PREPARE FOR HEARINGS; OFFICE CONFERENCE CLIENT FOR I ! TRIAL PREPARATION; 6/13/2016 KM PLAN AND PREPARE FOR HOUSING COURT HEARING, PREPARE 5.00 1,375.00 TRIAL BlNDER AND EXHIBITS, PREPARE MOTIONS AND FILE, PREPARE AND REVIEW OF SUPPORTING CASE LAW AND DOCUMENTS, MULTIPLE OFFICE CONVERSATIONS, TELEPHONE CALLS WITH ATTORNEY HEISLER OFFICE RE CONTINUANCE, OFFICE CONVERSATION, REVIEW JUDICIAL SITE RE CONTINUANCE, DRAFT RESPONSE TO CONTINUANCE REQUEST AND EFILE 6/14/2016 HO HEARING PREPARATION; REVIEW TRIAL BOOKS; PREPARE CASE 1.50 750.00 LAW FOR ARGUMENT; OFFICE CONFERENCES ASSOCIATE; TELEPHONE CONFERENCES CLIENT; PREPARE OBJECTION TO CONTINUANCES; SEVERAL TELEPHONE CONFERENCES COURT AND COUNSEL ON HOUSING MATTER; 6/15/2016 H0 OFFICE CONFERENCE ASSOCIATE TO ADDRESS CONTINUANCE 0.50 250.00 GRANTED SUA SPONTE DATE BY COURT; CONTACT OPPOSING COUNSEL; PREPARE, REVIEW AND REVISE AND FILE NEW MOTION . CONTINUANCE; SEVERAL EMAILS AND TELEPHONE CONFERENCES CLIENT; 6/16/2016 HO REVIEW AND ADDRESS CLIENT MANY DETAILED EMAILS AND 0.50 250,00 TELEPHONE CONFERENCES CLIENT ON HOUSING MATTER; I FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Mr. Krzystof Wolyniec Page 3 Hours Amount 6/17/2016 HO EMAILS AND TELEPHONE CONFERENCES CARL FERRARA AND 0.40 200,00 CLIENT AND ADDRESS GLOBAL SETTLEMENT CONCEPTS; 6/21/2016 KM DRAFT REQUEST FOR PRODUCTION AT HEARING, REVIEW 1.00 275.00 MOTIONS FILED AND RELIEF REQUESTED, REVIEW DOCUMENTS IN FILE HO CARL FERRARA SCHEDULE NOW CHANGED FOR 8.2 OR 8.3 ; 0.10 50.00 ADVISE CLIENT; 6/22/2016 KM OFFICE CONVERSATION, REVISIONS TO REQ UEST TO PRODUCE AT 2.30 632.50 HEARING, PREPARE NOTICE OF FILING, EMAIL TO CLIENT, REVIEW EMAILS AND DISCUSS ATTORNEY OPINSKY, PREPARE EXHIBITS AND DOCUMENTS FOR HEARING, LEGAL RESEARCH. 6/23/2016 KM PLAN AND PREPARE EXHIBITS FOR HEARING, PREPARATION OF 4.00 1,100.00 MOTIONS, CLIENT NOTES AND EMAILS, AND DOCUMENTS FOR HOUSING HEARING, RESEARCH, MULTIPLE OFFICE CONVERSATIONS HO PREPARATION FOR FOUR-WAY; REVIEW CLIENT RECORDS AND 2.00 1,000.00 EXCEL SHEET ON PAYMENTS; TELEPHONE CONFERENCES AND EMAILS CLIENT; PREPARE AND DISCUSS WITH CLIENT; ADDITIONAL PROOF NECESSARY; CLIENT TO REDO SCHEDULE REQUEST TO PRODUCE DISCUSSED; FOUR-WAY CANCELLED; CARL FERRARA EMERGENCY,' FAMILY EMERGENCY; 6/24/2016 HO RESCHEDULE FOUR-WAY WITH CARL FERRARA AND CLIENT; 0.50 250.00 SEVERAL TELEPHONE CONFERENCES; SET TWO DATES FOR NEXT WEEK; CARL AGREES TO MARK HIS MOTION FOR CONTEMPT AND ALIMONY ARREARS OFF CALENDAR; 6/28/2016 KM APPEAR IN COURT TO ENSURE WIFE'S CONTEMPT MARKED OFF BY 0.50 137.50 ATTORNEY FERRARO; TRAVEL TO AND FROM COURTHOUSE HO ADDRESS SETTLEMENT ISSUES WITH CARL FERRARA DURING 0.40 200.00 TIME SLOT THAT WAS ON FOR CONFERENCE; HO CONFIRMATION MOTIONS ARE MARKED OFF WITH CARL FERRARA 0.40 200.00 AND ADVISE CLIENT; EMAIL EXCHANGES; DISCUSS MEETING AGAIN TO SETTLEMENT GLOBALLY SUPERIOR COURT CASE; 6/29/2016 HO ADDRESS DATES FOR FOUR-WAY SETTLEMENT CONFERENCE 0.20 100.00 WITH CLIENT AND COUNSEL; ADDRESS; 6/30/2016 KM TELEPHONE CALL WITH HOUSING CLERK REGARDING COURT 1.00 275,00 AVAILABILITY FOR CONTINUANCE OF HEARING, OFFICE CONVERSATION, REVIEW EMAILS FROM HEO AND CLIENT REGARDING CONTINUANCE, EMAIL TO ATTORNEY HEISLER AND TELEPHONE CALL REGARDING CONTINUANCE FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Mr. KrzystofWolyniec Page 4 Hours Amount 7/1/2016 HO EMAILS WITH CLIENT TO ARRANGE FOUR-WAY; LEFT MESSAGE 0.10 50.00 WITH CARL FERRARA INDATES; KM REVIEW EMAIL ATTORNEY HEISLER RE HOUSING CONTINUANCE 1.00 275.00 REQUEST; E-FILE CONTINUANCE HEARING DATE WITH COURT AND EMAIL ATTORNEY HEISLER; REVIEW COURT WEBSITE RE CONTINUANCE REQUEST; OFFICE CONFERENCE RE CONTINUANCE DATE; EMAIL TO CLIENT 7/18/2016 HO ATTEMPT TO RESCHEDULE FOUR-WAY: EMAILS EXCHANGED WITH 0.10 50.00 COUNSEL GOOD FOR 8.2 OR 8.3 AT 5:00. 7/19/2016 HO REVIEW AND RESPOND TO EMAIL EXCHANGES WITH CUENT ON 0.20 100.00 FOUR-WAY AND HOUSING COURT; OFFICE CONFERENCE ASSOCIATE 7/21/2016 KM EMAIL TO CLIENT RE MEETING AND PREPARATION FOR HEARING; 0.20 55.00 REVIEW RESPONSE; OFFICE CONVERSATION 7/22/2016 HO WOLYNIEC HOUSING COURT ISSUES DISCUSSED WITH CLIENT 0.20 100.00 THAT HOUSING COURT LIKELY TO DO NOTHING DUE TO SUPERIOR COURT ACTION FAMILY MATTER EXCLUSlVE ORIGINAL JURISDICTION SUPERIOR TO HOUSING COURT;; ADVISED CLIENT; CLIENT PITCHES EVICTION STATUTORY BUT NO AGREEMENT TO LEASE HERE AND MOTHER; LIVED THERE FOR YEARS; NO MONEY TO MOVE LlKELY TO IMPACT STAY BEING GRANTED; ADVISED; WILL TRY TO PITCH MOVING FORWARD BY COURT AND WILL SEE; KM PREPARATION OF EXHIBITS AND DOCUMENTS FOR HEARING 2,00 550.00 ! 7/25/2016 HO MOTION FOR USE & OCCUPANCY & PAYMENTS & COUNSEL FEES IN 0.50 250.00 HOUSING COURT; OFFICE CONFERENCE ASSOCIATE 7/26/2016 KM PLAN AND PREPARE EXHIBITS, TRIAL BlNDER FOR HOUSING 4.00 1,100.00 HEARING, TELEPHONE CALL HOUSING CLERK RE CONTINUANCE OF HEARING TO AUGUST 2ND; EMAILS TO CLIENT; OFFICE CONFERENCE AND EMAILS TO HEO REGARDING CONTINUANCE BY COURT; REVIEW JUDICIAL WEBSITE; RESEARCH FOR HEARING HO EMAILS ATTORNEY TO RESOLVE ISSUES 0.20 100.00 7/27/2016 KM PREPARE TRIAL BINDER FOR HOUSING HEARING; RESEARCH RE 4.00 1,100.00 SUMMARY PROCESS MATTERS AND EVICTION HO HOUSING COURT TELEPHONE CONFERENCE MOVED HEARING NO CHARGE FROM 7.28 TO NEXT WEEK -- ADVISE OFFICE CONFERENCE CLIENT; ASSOCIATE HO ATTEMPT TO RESCHEDULE 4-WAY WITH CARL FERRARO. SEVERAL 0.50 250.00 EMAILS COUNSEL & CLIENTS ON DATES 8.9;8.10; 8.11;ADDRESS WITH CUENT. FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 I Mr. Krzystof Wolynlec Page 5 Hours Amount , 7/27/2016 HO SEVERAL EMAILS EXCHANGED COUNSEL & CLIENT OFFICE 0.30 150.00 CONFERENCE WITH ASSOCIATE; SCHEDULE 4-WAY & ADDRESS WITH CLIENT. HO TELEPHONE CONFERENCE CLIENT. 0.20 100.00 7/28/2016 KM PREPARE TRIAL BINDER, CASELAW BlNDER FOR HOUSING 5.00 1,375.00 HEARING; OFFICE CONVERSATION RE TRIAL BINDER; EMAILS TO AND FROM CLIENT RE ZILLOW VALUE HOME AND PICTURES NEEDED AS EXHIBITS; INTERNET RESEARCH REGARDING RENTAL VALUE OF HOME; REVIEW MOTIONS; PREPARE MOTION FOR COUNSEL FEES; RESEARCH RE ATTORNEY FEE ORDERS IN HOUSING AND SUMMARY PROCESS ACTIONS HO TRIAL PREPARATION; REVIEW & PREPARE FILE; REVIEW CASE LAW 2.00 1,000.00 RESEARCH EXHIBITS; TRIAL BOOKES; PREPARE; REVIEW & REVISE; SEVERAL EMAILS CLIENT ON NECESSARY FURTHER EXHIBITS; TELEPHONE CONFERENCE SCHEDULE. For professional services rendered 57,30 $20,280,00 Previous balance ($3,780.00) Balance due $16,500.00 Attorney Summary Name Hours Rate Amount Heidi Opinsky 20.10 500.00 $10,050.00 Kristen Mazur 37.20 275.00 $10,230.00 Please review your bill immediately and contact our office with any questions, FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Law Offices of Heidi E. Opinsky, LLC One Landmark Square 21st Floor Stamford, Connecticut 06901 T: 203.653.3542 F: 203.653.3545 Krzysztof Wolyniec 444 East Putnam Avenue #1 Cos Cob, CT 06807 September 01, 2016 In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment Matrimonial and Housing Professional Services Hours Amount 8/1/2016 HO PREPARE FOR HEARING; MAKE NOTES; PROVIDE CLIENT; 4.00 2,000.00 PREPARE TRIAL BOOK AND NOTES; HO TRIAL PREPARATION ALL AFTERNOON AND EVENING; SEVERAL 8.00 4,000.00 EMAIL EXCHANGED; REJECT REQUEST FOR CONTINUANCE; COMMUNICATE WITH COURT; CASE PROCEEDING; PREPARE TRIAL NOTES THROUGHOUT EVENING UNTIL 11:00 AND REQUEST FOR LEGAL FEES AND AFFIDAVIT AND EXHIBITS; EMAILS CLIENT AND COUNSEL OBJECTING TO CONTINUANCE; 8/2/2016 HO PREPARE IN MORNING PRIOR TO HEARING; APPEAR IN COURT; 4.00 2,000.00 MEET WITH COUNSEL; CLIENT AND COURT MEDIATOR; MEDIATOR SET DOWN ADVANCED DATE 8.25; IN COURT ALL MORNING; HO PREPARE FOR COURT; APPEARANCE COURT FOR HEARING; MET 3.50 1,750.00 WITH COURT MEDIATOR; ATTENDED CALL OF CALENDAR; MATTER PUT OVER TO 8/25; 8/9/2016 HO SEVERAL EMAILS CLIENT AND COUNSEL TO CONTINUE MEETING 3.00 1,500.00 AT HIS OFFICE; PREPARE FILE; FOUR-WAY CONFERENCE AT CARL FERRARO'S OFFICE 8/10/2016 HO EMAILS EXCHANGED WITH CLIENT REGARDING ISSUES 0.40 200.00 DISCUSSED AT CONFERENCE; PAYMENTS COLLEGE; SUPPORT; ESCROW; FEES; ETC. 8/11/2016 HO EMAILS EXCHANGED WITH CLIENT ON RESOLUTION OBJECTIVES 0.40 200.00 AND DIFFERENT SCENARIOS; 8/12/2016 KM WESTLAW RESEARCH REGARDING DEFAULT FOR FAILURE TO 1.00 275.00 PLEAD AND ISSUE OF APPLICABILITY OF CLOSED PLEADINGS IN SUMMARY PROCESS MATTERS; OFFICE CONVERSATION HEIDI. FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Krzysztof Wolyniec Page 2 Hours Amount 8/12/2016 HO EMAILS CLIENT ON COURT PUTTING CASE OVER TO 9/8 AS COURT 0.40 200.00 DOCKET WAS FILLED AND NOT ROOM FOR HEARING; ADDRESS WITH CLIENT COURT PUT OVER SUA SPONTE; 8/14/2016 HO EMAILS EXCHANGED WITH CLIENT ON THOUGHTS AND 0.30 150.00 SCENARIOS FOR RESOLUTION; 8/30/2016 HO OFFICE CONFERENCE ASSOCIATE AND EMAILS CLIENT; 0.20 100.00 For professional services rendered 25.20 $12,375.00 Accounts receivable transactions 9/27/2016 Invoice $16,500.00 9/27/2016 Payment - Thank You 9/8/16 ($5,000.00) Total payments and adjustments $11,500.00 Balance due $23,875.00 Attorney Summary Name Hours Rate Amount Heidi E. Opinsky 24.20 500.00 $12,100.00 Kristen Mazur 1.00 275.00 $275.00 FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Law Offices of Heidi E. Opinsky, LLC One Landmark Square 21st Floor Stamford, Connecticut 06901 T: 203.653.3542 F: 203.653.3545 Krzysztof Wolyniec 444 East Putnam Avenue #1 Cos Cob, CT 06807 October 01, 2016 In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment Matrimonial and Housing Professional Services Hours Amount 9/6/2016 HO SEVERAL EMAILS EXCHANGED; OFFICE CONFERENCE ASSOCIATE 0.40 200.00 TO FOLLOW; ADDRESS; PREPARE FILE FOR COURT; TELEPHONE CONFERENCE CLIENT ON FINANCIAL AFFIDAVIT; NOTICE TO QUIT; ETC.; 9/7/2016 HO DOZENS OF EMAILS THROUGHOUT DAY AND TELEPHONE 4.00 2,000.00 CONFERENCES CLIENT ON UPDATED EXECUTED LEASES; RENT BY AGREEMENT V. ZILLOW VALUES; ADDRESS WITH CLIENT; NEED FULLY EXECUTED LEASES; DISCUSS SUPERIOR COURT HAS EXCLUSlVE CONTINUING JURISDICTION WITH CLIENT AND LIKELY WILL DISMISS AND REFER TO SUPERIOR COURT MATTER; WILL FIGHT AS HARD AS CAN; CLIENT ISAWARE AND FINANCIAL AFFIDAVIT ISSUE IF FEES ARE BROUGHT UP; PREPARE UPDATED AFFIDAVIT ON FEES; CLIENT WISHES TO BlFURCATE ISSUE; EMAILS THROUGHOUT DAY; PREPARE FOR HEARING; PREPARE CLIENT'S NOTES TO REVIEW FOR COURT; CONCLUDE IN EVENING AND SEND TO CLIENT; PREPARE FILE FOR HEARING; REVIEW FILE AND PREPARE FOR HEARING DURING DAY AND CONTINUlNG DURING EVENING WITH CLIENT; 9/8/2016 HO PREPARE AND ATTEND HEARING HOUSING COURT; REVIEW FILE 3.50 1,750.00 FOR COURT IN A.M.; MEET WITH CLIENT; 9/9/2016 KM PREPARE RECLAIM ALL PLAINTIFF MOTIONS, FAX FILE WITH 0.50 137.50 COURT, EMAIL CARL FERRARO, REVIEW EMAIL CARL FERRARO ENCLOSING HIS RECLAIM AND APPEARANCE HO OFFICE CONFERENCE ASSOCIATE; RECLAIM MOTIONS IN 0.20 100.00 SUPERIOR COURT POST-JUDGMENT PROCEEDINGS; 9/13/2016 HO SEVERAL EMAILS EXCHANGED DURING DAY WITH CLIENT ON 0.80 400.00 MOTIONS IN SUPERIOR COURT AND AMENDMENTS; PREPARE, REVIEW AND REVISE MOTIONS; EMAILS ON FINANCIAL AFFIDAVIT FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Krzysztof Wolyniec Page 2 Hours Amount IF SEEKING FEES; CLIENT NOT DISPUTING THE 200k IN PAYMENTS; ADDRESS ISSUES WITH CLIENT; DISCUSS; 9/21/2016 KM MARK PLAINTIFF'S MOTIONS READY FOR 10/3 CALENDAR, EMAIL 1.30 357.50 TO CLIENT RE AVAILABILITY, REVISE AND AMEND MOTIONS TO REMOVE EDUCATIONAL SUPPORT ORDER REFERENCES, OFFICE CONVERSATION RE REVISIONS, REVIEW AND FILE WITH COURT, EMAIL TO ATTORNEY FERRARO 9/28/2016 KM PREPARE FILE FOR HEARING 1.00 275.00 9/29/2016 HO OFFICE CONFERENCE ASSOCIATE TO ADDRESS COURT 0.20 100.00 APPEARANCES WITH CLIENT; 9/30/2016 HO OFFICE CONFERENCE ASSOCIATE TO READY FILE FOR COURT; 0.40 200.00 EMAILS CLIENT; REVIEW MOTION FEES TO HOLD IN FILE; For professional services rendered 12.30 $5,520.00 Previous balance $23,875.00 Balance due $29,395.00 Attorney Summary Name Hours Rate Amount Heidi E. Opinsky 9.50 500.00 $4,750.00 Kristen Mazur 2.80 275.00 $770.00 FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Law Offices of Heidi E. Opinsky, LLC One Landmark Square 21st Floor Stamford, Connecticut 06901 T: 203.653.3542 F: 203.653.3545 Krzysztof Wolyniec 444 East Putnam Avenue Cos Cob, CT 06807 November 01, 2016 In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment Matrimonial and Housing Professional Services Hours Amount 10/3/2016 HO PREPARE FOR COURT APPEARANCE COURT ON WOLYNIEC; MEET 4.00 2,000.00 WITH OTHER SIDE; APPEAR BEFORE COLIN; SENT TO FAMILY MEET' RELATIONS BY COLIN; MEET WITH COUNSEL ALONE AND THEN WITH FAMILY RELATIONS; PARTIES MET ALONE AND THEN WITH COUNSEL; MET WITH JEFF DIAMOND FOR DATES; RECEIVE NOTICE COLIN SET MATTER DOWN FOR JUDICIAL PRETRIAL 11.1. ADVISE CLIENT; PREPARE, REVIEW AND REVISE UPDATED DOCUMENTS IN FILE FOR APPEARANCE; KM TELEPHONE CALLS HEO RE AFFIDAVIT COUNSEL FEES AND 1.50 412.50 UPDATING FOR MATRIMONIAL MOTIONS, REVIEW AND UPDATE AFFIDAVIT OF FEES, WALK TO AND FROM COURTHOUSE WITH AFFIDAVIT 10/5/2016 KM EMAIL TO CLIENT RE COURT DATES FOR PRETRIAL AND HEARING, 0.40 110.00 REVIEW JUDICIAL WEBSITE, OFFICE CONFERENCE, REVIEW NOTES 10/28/2016 HO PREPARE FOR JUDICIAL PRETRIAL; GO THROUGH TRIAL BOOK 1.00 500.00 WITH ASSOCIATE; REVIEW AND UPDATE DOCUMENTS AND AFFIDAVIT OF FEES WITH ASSOCIATE; ADVISE TO FOLLOW-UP WITH CLIENT; 10/31/2016 HO OFFICE CONFERENCE ASSOCIATE ON AMENDED MOTIONS AND 0.70 350.00 READY MARKINGS; REVIEW AMENDMENTS TO MOTIONS AND READY MARKINGS; EMAIL EXCHANGES WITH COUNSEL; ADDRESS DATES AND MOTIONS WITH CLIENT; REVIEW AND PREPARE TRIAL BOOK TO ENSURE DOCUMENTS IN ORDER FOR JUDICIAL PRETRIAL TOMORROW; ADDRESS SCHEDULING PREPARATION; APPEARANCE WITH CLIENT WITH ASSOCIATE; FOLLOW; KM OFFICE CONFERENCE RE PRETRIAL, PREPARATION OF FILE, 1.50 412.50 EXHIBITS, MOTIONS FOR PRETRIAL CONFERENCE FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Krzysztof Wolyniec Page 2 Amount For professional services rendered 9.10 $3,785.00 Previous balance $29,395.00 Balance due $33,180.00 Attorney Summary Name Hours Rate Amount Heidi E. Opinsky 5.70 500.00 $2,850.00 Kristen Mazur 3.40 275.00 $935.00 FILED: NEW YORK COUNTY CLERK 04/24/2018 03:25 PM INDEX NO. 651992/2018 NYSCEF DOC. NO. 6 RECEIVED NYSCEF: 04/24/2018 Law Offices of Heidi E. Opinsky, LLC One Landmark Square 21st Floor Stamford, Connecticut 06901 T: 203.653.3542 F: 203.653.3545 Krzysztof Wolyniec 444 East Putnam Avenue #1 Cos Cob, CT 06807 December 01, 2016 In Reference To: Marlena Wolyniec v.Krzysztof Wolyniec, Post Judgment Matrimonial and Housing Professional Services Hours Amount 11/1/2016 KM PREPARE DOCUMENTS AND EXHIBITS FOR PRETRIAL, UPDATE 1.00 275.00 AFFIDAVIT OF ATTORNEY FEES 11/28/2016 HO EMAILS FROM JEFF DIAMOND IN COURT AND COUNSEL 0.20 100.00 EXCHANGED REGARDING SCHEDULING HEARING AND DATES; 11/29/2016 HO TELEPHONE CALL TO CLIENT AND EMAIL TO CALL TO DISCUSS 0.50 250.00 MATTER; HEARD FROM OPPOSING COUNSEL AND THEY WILL SETTLEALONGTERMSRECOMMENDED BY COURT; COMMUNICATE WITH CLIENT; CLIENT DID NOT RETURN CALLS, ONLY EMAIL INDICATING HE REFUSES SETTELMENT DISCUSSIONS WITHOUT HEARING MATTER OUT; CLIENT ADVISES IN MIDST OF MOVE AND CANNOT SPEAK; DOES NOT PROVIDE NEW CONTACT INFORMATION; 11/30/2016 HO CLIENT PROVIDED AUTHORIZATION TO PAY BILL LAST IN COURT; 0.50 250.00 RESEND CREDIT CARD AUTHORIZATION FOR PAYMENT AND ASK AND LOOK FORWARD TO DISCUSS CASE SETTLEMENT OR PREPARATION FOR HEARING AND SCHEDULING ISSUES UPON COURT NOTICE; SEVERAL CLIENT EMAILS REFUSES TO NEGOTIATE UNDER 150K NET SETTLEMENT TO CLIENT IS AROUND WHAT HE WANTS AND ADVISE; LENGTHY EMAIL EXCHANGE AND EMAILS TO CLlENT ON IN BEST INTERESTS TO SETTLE BASED JUDGES' UPON RECOMMENDATIONS FAVORABLE TO HIM; ADVISE HOW TAX IMPACT IS AROUND NUMBER HE WANTS; CLIENT REFUSES TO DISCUSS EXCEPT ON HIS TERMS THAT ARE