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  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
  • Federal National Mortgage Association v. Ballantyne Garden Apt Syracuse Llc, Abraham Wieder, Blueberry Funding Llc Real Property - Mortgage Foreclosure - Commercial document preview
						
                                

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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: