Preview
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
"A"
EXHIBIT
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
HARRIS BEAC‰
ATTORNEYS AT LAW
Orazio D. Crisalli April 21, 2023
c/o Syracuse Realty Group, LLC Invoice #8913705
106 S. Main Street
N. Syracuse, NY 13212
Firm Attorney: David Capriotti Client Name: Orazio D. Crisalli
Firm Matter Numbers: 0307478.423349 Matter Name: FC: Counsel to Receiver - Ballantyne Garden
Apt. Syracuse, LLC
April Invoice for Statement of Services and Disbursements
ACCOUNT SUMMARY FOR THIs MATTER
TOTAL FEES THIS INVOICE........................................................................................................................$7,035.00
I O I AL AMOL YE DL E FOR THIS I VVON . . . . . . . ........ . . .M.035E
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
0307478.423349 Orazio D. Crisalli Harris Beach PLLC
FC: Counsel to Receiver - Ballantyne Garden Apt. Invoice # 8913705
Syracuse,
LLC Page 2
PROFESSIONAL SERVICESRENDERED:
DATE TIMEKEEPER HOURS NARRATIVE
03/21/23 DMC 0.70 Confer with client regarding potential Receiver and management of
property. Discuss issues of ability to fund operations and
willingness of lender to provide funding.
03/23/23 DMC 2.40 Various conversations with client to determine directives of the
Receiver Order. Receipt, review and analysis of Order to discuss
operations with Plaintiffs counsel. Conference call with Receiver
and Plaintiffs counsel. Receipt, review and analysis of requested
language from Plaintiffs counsel.
03/23/23 EG 2.20 Draft the Proposed Ex Parte Order Appointing Counsel to Receiver
as well as the Receiver Affidavit in Support of Ex Parte Application
to Appoint Counsel to Receiver after brief conference with David
Capriotti. Review of docket and fled pleadings to date also
conducted in order to prepare documents.
03/24/23 DMC 1.20 E-mails to/from client. Call with client. Call with Judge's
chambers to discuss appointment of counsel. Call to Defendant's
counsel to discuss retention. Work on agreement to appoint
counsel. Receipt, review and analysis of new County letter
regarding habitability.
03/24/23 EG 0.20 Conference with C. Jaffe, counsel to defendant regarding our Ex
Parte papers and review of the same. Send email to counsel with
papers.
03/24/23 EG 0.30 Receive and review executed Receiver Affidavit in Support of Ex
Parte Application. Draft Receiver's Oath for completion once we
receive information on surety bond.
03/27/23 DMC 1.30 Receipt and review of e-mails to/from Plaintiffs counsel related to
orderappointing counsel and language of motion. E-mails to/from
Chaim Jaffe regarding order to appoint counsel. Receipt and
review of e-mails from
regarding client money that willadditional
be necessary to comply with City's requirements for safety and
health of residents. E-mails to/from Ozzie regarding status of
meeting and Receiver's oath for signature and filing. Call with
client regarding funding of project and . Review and edit
Receiver's oath. Review and edit Order to Show Cause to expend
emergency funds, Receiver Affidavit, Proposed Order and
Receiver's Oath.
03/27/23 EG 3.50 Correspondence back and forth with defendant's counsel regarding
the papers for the appointment of counsel to receiver. Draft the
Order to Show Cause, affidavit in support, and the proposed order
for relief of $75,000 in funding in order to make necessary repairs.
03/27/23 EG 0.40 Make revisions to the Order to Show Cause Papers.
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
0307478.423349 Orazio D. Crisalli Harris Beach PLLC
FC: Counsel to Receiver - Ballantyne Garden Apt. Invoice # 8913705
Syracuse,
LLC Page 3
. DATE TIMEKEEPER HOURS NARRATIVE
03/28/23 DMC 1.60 Call withChaim Jaffe regarding appointment as counsel and
request for emergency budget. Receipt and review of proposed
language on e-mail to property manager. Call with client to discuss
conversations with defendant and property manager. E-mails
to/from Jaffe regarding same conversations. E-mails to/from client.
Call with Court to advise of soon to be filed applications and
motions. Additional calls with client regarding process of filing
applications and bond information. E-mails to/from Plaintiff and
Defendant counsel regarding
consenting to Emergency Funding.
03/28/23 EG 0.80 Draft Order to Show Cause papers - and proposed
order, affidavit,
order. Conference with David Capriotti and the Receiver. Discuss
paperwork conceming Oath and Bond.
03/29/23 DMC 1.70 E-mails to/from all attorneys regarding proposed changes to
requested relief. Confer with client regarding same. Prepare and
edit all documents for filing Order to Show Cause. Calls with client
to discuss various aspects of the relief sought.
03/29/23 EG 0.50 Receive and review edits made to OTSC by Plaintiffs counsel.
Accept and make changes. Correspondence to Plaintiffs counsel
confinning change.
03/29/23 EG 2.00 Conference with David M. Capriotti regarding substance of papers,
consent of parties, edits to Oath, receipt of signed affidavits from
Receiver, and timing of filings. Draft letter to Court outline plan to
file and consent of parties. Coordinate with Joanne Simmons the
compiling of papers, exhibits, and timing of filings.
03/30/23 DMC 0.50 Receipt and review of various order entered by court.
Communications with client regarding next steps and meeting with
officials.
03/30/23 EG 0.30 Correspondence back and forth with Court to provide proof of
consent. Further conference with David Capriotti concerning order.
Receive and review Order regarding Emergency funds.
03/30/23 EG 0.30 Receive and review order appointing counsel to receiver.
Conference with David Capriotti regarding the fee structure within
the order and arguments to be made against.
03/31/23 EG 0.20 Receive and review Receiver's Bond. Coordinate with Joanne
Simmons for filing. Brief scheduling correspondence between
Receiver and Counsel to Receiver regarding possible evictions.
TOTAL HOURS AND FEES 20.10 $7,035.00
TÓ EAl A TIO L T DUE Ï HÏS INyOICE...........f.... ....2..... .. ....... ........... .. ... 7 35 0
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
HARRIS BˆAC‰
ATTORNEYS AT LAW
REMITTANCE
Orazio D. Crisalli April 21, 2023
c/o Syracuse Realty Group, LLC
106 S. Main Street
N. Syracuse, NY 13212
Firm Matter Number: 0307478.423349
Invoice #8913705
Firm Attorney: David Capriotti
April Invoice for Statement of Services and Disbursements
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
PAYMENT INS TRUC ONS
.. PayE•édt by CreditsCE I
hups u u h:umbeach co m payment
Click on link and you will be directed to the Harris Beach Invoice Payment Page.
Please include the Firm Matter Number and Invoice Number which are referenced on this invoice above.
Bank Name: Citizens Bank, Rochester, NY 14604
Account Name: Harris Beach PLLC Operating A/C
Account #:
ABA #:
Swift Code:
Payment by Check (U.S. Only) .
Please include this remittance or print your matter and invoice number (8913705) in the check memo. Mail to:
HARRIS BEACH PLLC
333 West Washington Street, Suite 200
Syracuse, NY 13202
RefeFUEe Informatioh .
Firm Matter Number: 0307478.423349
Attorney: David Capriotti
For questions please contact: billin arrisbeach corn
Federal Tax Id:
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
HARRIS BˆAC‰il
ATTORNEYS AT LAW
Orazio D. Crisalli May 11, 2023
c/o Syracuse Realty Group, LLC Invoice #8917126
106 S. Main Street
N. Syracuse, NY 13212
Firm Attorney: David Capriotti Client Name: Orazio D. Crisalli
Firm Matter Numbers: 0307478.423349 Matter Name: FC: Counsel to Receiver - Ballantyne Garden
Apt. Syracuse, LLC
May Invoice for Statement of Services and Disbursements
ACCOUNT SUMMARY FOR THIs MATTER
TOTAL FEES THIS INVOICE........................................................................................................................$3,852.50
TOTAL COSTS THIS INVOICE..........................................................................................................................$92.70
TOTAL AMOUNT DUE FOR THIS INVO (F . ... . 94 20
PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER .................................................................$7,035.00
TOT M A MOUNT DUE FÓ I MS MATI ER AS OF C L RRENT TNVOICE (O A I 13) 19380 20
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
OlrfSTANDING INVOICE DETAIL AS OF: 05/11/23
Invoice Date Original Amount Payments/Credits Amount Due
8913705 04/21/23 7,035.00 0.00 7,035.00
TOTALS $7,035.00 $0.00 $7,035.00
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
0307478.423349 Orazio D. Crisalli Harris Beach PLLC
FC: Counsel to Receiver - Ballantyne Garden Apt. Invoice # 8917126
Syracuse,
LLC Page 2
PROFESSIONALSERVICESRENDERED:
DATE TIMEKEEPER HOURS NARRATIVE
04/05/23 DMC 0.50 E-mails to/from Chaim Jaffe regarding of counsel. E-
meeting
mails to/from client related to funding and meeting of counsel.
Review status of funding for repairs.
04/06/23 DMC 0.60 Attend conference call with client and attorney for Plaintiff to
discuss various aspects of property, security, financials and funding
of cleanup costs.
04/07/23 DMC 0.30 Receipt, review and analysis of insurance information sent by
Chapman. E-mails to/from client regarding insurance requirements.
04/11/23 DMC 0.20 Receipt and review of stipulated order relating to action. Call to
Receiver to discuss budget for expenses.
04/11/23 EG 0.40 Receive and review stipulated order directing deadlines for the
defendant to answer the amended complaint.
04/13/23 DMC 1.20 Prepare for conference call with Plaintiff and Defendant to discuss
various issues. Review Receiver order for various obligations.
Attend weekly conference call.
04/17/23 DMC 0.20 E-mails to/from Dean Chapman related to insurance and adding
referee and property managers as additional insureds.
04/18/23 DMC 0.30 Communications to/from client regarding motion to approve
property management application. Review of e-mail from
Chapman.
04/18/23 EG 1.50 Draft Notice of Motion, Affidavit in Support, and Proposed Order,
regarding the appointnient of a property management company of
the mortgaged premises.
04/19/23 DMC 0.50 Receipt and review of e-mails from Chapman regarding insurance.
E-mails to/from client regarding insurance issue. Receipt and
review of e-mails regarding property inspection. Conference call
with client to discuss retaining property manager.
04/20/23 DMC 0.50 Prepare for and attend weekly meeting with counsel.
04/26/23 DMC 0.20 Review of notice from City Codes.
04/27/23 DMC 2.70 Call to Chaim Jaffe regarding requested information. Review and
edit notice of motion to appoint property manager. Review and edit
affidavits and order for appointment of property manager. E-mails
to/from client with revisions to management agreement. Attend
weekly meeting. Separate call with client and management
company regarding appointment of manager.
04/27/23 EG 0.50 Revise papers in support of motion to appoint property management
company. Finalize for signature of Receiver.
04/28/23 DMC 1.40 Proceed with finalizing papers for filing. Call with chambers
regarding motion to appoint property manager. Draft e-mail to all
parties. Communications with client. receipt, review and analysis
of various notices from court.
TOTAL HOURS AND FEES 11.00 $3,852.50
DISBURSEMENTS:
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
0307478.423349 Orazio D. Crisalli Harris Beach PLLC
FC: Counsel to Receiver - Ballantyne Garden Apt. Invoice # 8917126
Syracuse,
LLC Page 3
DATE NARRATIVE AMOUNT
03/29/23 Vendor: Citizens Bank Invoice#: Date: 4/27/2023 - 45.00
Fees -Exparte Order - ONONDAGA COUNTY SUPREME
Filing (Proposed)
COURT EF
03/29/23 Vendor: Citizens Bank Invoice#: Date: 4/27/2023 - 1.35
- Exparte Order Fee - ONONDAGA
Filing Fees (Proposed) CC Service
COUNTY SUPREME COURT EF
03/29/23 Vendor: Citizens Bank Invoice#: Date: 4/27/2023 - 45.00
Fees - Order to Show Cause - ONONDAGA COUNTY
Filing (Proposed)
SUPREME COURT EF
03/29/23 Vendor: Citizens Bank Invoice#: Date: 4/27/2023 - 1.35
- Order to Show Cause - ONONDAGA
Filing Fees (Proposed) CC Service Fee
COUNTY SUPREME COURT EF
TOTAL DISBURSEMENTS $ 92.70
FILED: ONONDAGA COUNTY CLERK 05/15/2023 10:16 AM INDEX NO. 001377/2023
NYSCEF DOC. NO. 75 RECEIVED NYSCEF: 05/15/2023
HARRIS BˆAC‰s
ATTORNEYS AT LAW
REMITTANCE
Orazio D. Crisalli May 11, 2023
c/o Syracuse Realty Group, LLC
106 S. Main Street
N. Syracuse, NY 13212
Firm Matter Number: 0307478.423349
Invoice #8917126
Firm Attorney: David Capriotti
May Invoice for Statement of Services and Disbursements
TOT AL AMOL NT DUE trOR THIS INVOICE._. . =.=,.=.... . =. . . =. 4120
PREVIOUS OUTSTANDING BALANCE FOR THIS MATTER.................................................................$7,035.00
A late payment penalty .75% per month will be applied to all balances remaining unpaid 30 days
after the invoice date and for each 30 day period thereafter.
PAYMENT INSTRUCTIONS
.. ., .. . Payment by Credit Card
https ww hamsheach com payment
Click on link and you will be directed to the Harris Beach Invoice Payment Page.
Please include the Firm Matter Number and Invoice Number which are referenced on this invoice above.
Bank Name: Citizens Bank, Rochester, NY 14604
Account Name: Harris Beach PLLC Operating A/C
Account #
ABA #:
Swift Code:
Payment by Check (U.S. Only)
Please include this remittance or print your matter and invoice number (8917126) in the check memo. Mail to:
HARRIS BEACH PLLC
333 West Washington Street, Suite 200
Syracuse, NY 13202
R fereIce Informátion
Firm Matter Number: 0307478.423349
Attorney: David Capriotti
For questions please contact: billing@harrisbeach.com
Federal Tax Id: