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1 DANIEL A. CONRAD (076110)
ELISABETH J. HANOWSKY (252478)
2 Law Offices of Daniel A. Conrad ELECTRONICALLY
3] 1850 Bryant Street, Suite 760 spot tb ED
4 Sen aid 398 ca oh 03 County of San Francisco ‘
& ° MAY 05 2014
5|| Fax: (415) 359-0073 Clerk of the Court
BY: LESLIE GOMEZ
6 Deputy Clerk
Attorneys for HERB THOMAS,
7, Former Trustee
8
9 SUPERIOR COURT OF CALIFORNIA
10 COUNTY OF SAN FRANCISCO
4
12 THE ROSIA L. HART REVOCABLE NO. PTR-06-288755
43 TRUST
DECLARATION OF DANIEL A.
14 dated May 19, 2004. CONRAD IN SUPPORT OF
45 ALLOWANCE OF LITIGATION
COUNSEL’S FEES AND COSTS, ASA
16 LIEN AGAINST REAL PROPERTY
18 Date: June 2, 2014
Time: 9:00 a.m.
19 Dept: 204
ot Cross Ref. Case No. PCN-06-288756
Conservatorship of Rosia Lee Hart
1, Daniel A. Conrad, declare:
25 4. lam an attorney at law duly licensed to practice before all courts of the
26}} State of California and am one of the attorneys of record for Herb Thomas, former
271 Successor Trustee of the Rosia L. Hart Revocable Trust (“Former Trustee’).
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 428
2. On May 9, 2012, this Court authorized the Law Offices of Daniel A. Conrad
(‘litigation counsel”) to represent Former Trustee to “secure the rental income streams
from the Newhall and Suisun City properties, including bringing unlawful detainer actions
if necessary, dissolve Bayview Village LLC, and pursue collection efforts against
Gregory Wiggins, including a debtor's exam”.
3. Pursuant to this Court’s May 9, 2012 order, Former Trustee paid litigation
counsel a retainer of $3,500. On July 10, 2013, this Court awarded fees for legal
services provided to Former Trustee from December 6, 2011 to February 28, 2013 in the
amount of $15,961.69 as a judgment debt in favor of Daniel A. Conrad with interest of
5% per annum to be secured by a lien against 950 Newhall Street, San Francisco
(‘Newhall Street’). The balance of this award now due to litigation counsel is $14,329.63
plus accrued interest.
4, Litigation counsel’s services to Former Trustee are as follows:
a) General services. Litigation counsel's general services to Former Trustee
include reviewing the listing agreement for the laundromat at Newhall Street, reviewing
bill files regarding costs advanced, and reviewing the Request for Judicial Notice filed on
September 4, 2013 by co-counsel Andrew Schultz.
b) Gregory Wiggins.
Newhall Street is a property once owned by Bayview Village LLC, a limited liability
company formed by Gregory Wiggins and Rosia Hart. Litigation counsel successfully
caused the dissolution of the LLC. After Bayview Village LLC was dissolved, litigation
counsel and co-counsel Andrew Schultz discovered that, prior to Former Trustee’s
involvement, the architects Baum Thornley recorded a design professional's lien against
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 228
Newhall Street and were subsequently obtained a default judgment against Bayview
Village LLC. Litigation counsel researched the validity of Baum Thornley Architects’ lien.
Litigation counsel obtained title documents provided by Old Republic Title Company.
Litigation counsel communicated with Former Trustee regarding Baum Thornley
Architects, Litigation counsel's research was extensive due to the complexity of issues
regarding the effect of the court’s order rescinding the deed to Bayview Village LLC and
restoring title to Rosia Hart, and the chain of title wnen Baum Thornley Architects
recorded their lien.
Gregory Wiggins testified at his debtor's exam that he had a bank account at the
San Francisco Police Credit Union which contained approximately $100. Litigation
counsel prepared a Writ of Execution and other forms to levy the monies in that bank
account. Gregory Wiggins had closed his account at San Francisco Police Credit Union
before the levy was served.
At his debtor’s exam on January 22, 2013, Gregory Wiggins stated that he
received $2,000 per month in rent from 211 Tanager Way, Hercules (“Tanager Way’).
Gregory Wiggins currently holds title to the Tanager Way property. Litigation counsel
researched the process of levying the rents paid by Vanessa Bowman, current tenant at
Tanager Way. Litigation counsel worked with co-counsel Andrew Schultz to prepare the
Writ of Execution and Notice of Levy in order to levy the rents from Tanager Way.
Litigation counsel submitted the documents to the Contra Costa County Sheriff's Office
on August 5, 2013 and received the first levied rental payment in October 2013. Contra
Costa County Sheriff's Office prepares the rent checks payable to litigation counsel.
Upon receiving the checks, litigation counsel endorsed the checks in favor of Former
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 328
Trustee. Contra Costa County Sheriff's Office has sent checks for this rent levy totaling
nearly $12,000.
U.S. District Court Judge Charles Breyer contacted me - “not as a judge” -
because he knows the tenant's family. He asked me to advise Former Trustee not to
pursue the rent levy. | did not agree, and the rent levy has been effective.
Former Trustee filed his resignation as trustee on January 29, 2014. Paula Bibbs
was appointed as temporary successor trustee on January 30, 2014 and was appointed
as general successor trustee on March 25, 2014. Upon receiving the rent checks from
the Contra Costa County Sheriff's Office, litigation counsel sent two letters to Ernest Der,
attorney for Paula Bibbs, to request that he ask the Contra Costa County Sheriff's Office
to make the checks payable to him instead of litigation counsel. Litigation counsel has
instructed the Contra Costa County Sheriff's Office to send the checks directly to Ernest
Der.
c) Fee petition. Litigation counsel prepared and filed Petition for Order to Pay
Litigation Counsel Fees, to Continue Legal Representation, and to Waive Notice to Trust
Beneficiary (the “fee petition’) on March 29, 2013. The fee petition requested 1)
payment to litigation counsel for legal services provided to Former Trustee from
December 6, 2011 to February 28, 2013 in the amount of $17,368.69 and 2) to waive
notice of hearing to trust beneficiary Gregory Wiggins.
Subsequent to filing the fee petition, on June 14, 2013, this Court issued Probate
Examiner's Notes which requested that litigation counsel file an Ex Parte petition in order
to request authority to waive notice of hearing to Gregory Wiggins.
Hf
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 41 Litigation counsel prepared Ex Parte Petition for Order to Waive Notice to Trust
Beneficiary of Petition for Authority to Pay Litigation Counsel Fees and prepared a
Supplement to Petition for Order to Pay Litigation Counsel Fees. Litigation counsel filed
the Ex Parte petition and supplement on June 25, 2013 and prepared an order approving
6|| the Ex Parte petition. On June 27, 2013, this Court granted litigation counsel’s Ex Parte
7] petition to waive notice to Gregory Wiggins.
8 Litigation counsel served the fee petition, filed the Notice of Hearing, and
9
prepared the proposed order. On June 27, 2013, this Court issued Probate Examiners
10
Notes. Litigation counsel reviewed the Examiner’s Notes and prepared for the hearing.
42|| Litigation counsel attended the hearing regarding the fee petition on July 1, 2013. On
13]} July 9, 2013, this Court awarded fees to litigation counsel for services provided to
141 Former Trustee from December 6, 2011 to February 28, 2013 in the amount of
$15,961.69. On July 31, 2013, litigation counsel recorded the July 9, 2013 Order as a
16
7 judgment lien against the Newhall Street property.
18 Litigation counsel's services to Former Trustee also include coordinating with co-
191| counsel Andrew Schultz to add this current fee request to Former Trustee’s Fourth and
20] Final Account filed on April 21, 2014.
5. Litigation counsel incurred fees in the total amount of $14,534 for services
provided to Former Trustee from March 1, 2013 to April 2, 2014 and costs in the amount
of $972.74. Attached as Exhibit A is a detailed listing of the legal services provided and
251] costs paid by litigation counsel. On September 4, 2013, Former Trustee paid $1,177.11
2611 for costs incurred by litigation counsel from February 28, 2013 to August 5, 2013 (see
Exhibit B). The balance on this award now due to litigation counsel is $14,329.63, plus
accrued interest.
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 528
The hourly rates in effect for litigation counsel between March 1, 2013 to April 2,
2014 were:
3/1/13 - 6/3/13 6/4/13 - 12/31/13 1/1/14 - present
Daniel A. Conrad $420 $420 $450
Robin Rudderow $360 $360 $390
Elisabeth J. Hanowsky $270 $270 $290
Melanie S. O’Brien $75 $150 $200
6. I have been licensed by the State of California as an attorney since
December 1977. | have an AV peer review rating with Martindale-Hubbell. | ama
member of the San Francisco Probate Court pro bono mediation panel for estate and
trust litigation. | have extensive experience in contested probate and real property
matters.
7. Robin Rudderow has been licensed by the State of California as an
attorney since December 1986. Robin Rudderow has an AV peer review rating with
Martindale-Hubbell, a Masters of Law degree in taxation, and extensive experience in
contested probate and real property matters.
8. Elisabeth J. Hanowsky has been licensed as an attorney by the State of
California since 2007.
9. Melanie S. O’Brien was a paralegal who met the requirements set forth in
Business and Professions Code section 6450(c)(3). Melanie S. O’Brien has a bachelor’s
degree in sociology from Otterbein College, a law degree from Golden Gate University
School of Law, and worked under attorneys who have been active members of the State
Bar of California for at least one year. The paralegal services of Melanie S. O’Brien
were a benefit to the estate because the cost of having the work performed by Melanie
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 6=
28
S. O’Brien and reviewed by attorneys does not exceed the amount appropriate if the
attorney had performed the services without Melanie S. O’Brien’s assistance. Melanie S.
O’Brien became a licensed California attorney on June 4, 2013.
| declare under penalty of perjury under the laws of the State of California that the
Ze
foregoing is true and correct and that this declaration was executed on May , 2014
at San Francisco, California.
DANIEL A. CONRAD
DECLARATION OF DANIEL A. CONRAD IN SUPPORT 7Law Offices of
DANIEL A. CONRAD
1550 Bryant Street, Suite 760
San Francisco, CA 94103
(415) 359-0900
invoice submitted to:
Herb Thomas
875-A Island Drive, Suite 387
Alameda, CA 94502
April 30, 2014
in Reference To:Rosia L. Hart Revocable Trust
Client 11-073
Professional Services
Eee Petition
3/8/2013 - RR
3/11/2013 - AR
- MOB
3/26/2013 - MOB
3/29/2013 - MOB
4/1/2013 - MOB
4/9/2013 - MOB
Legal
Revise fee petition regarding continue representation, waiver of
notice te Gregory Wiggins.
Fee Petition
Legai
Fee Petition: Revise fee petition. Correspondence to client.
Fee Petition
Paralegal
Edit Petition for Order to Pay Litigation Counsel Fees, to Continue
Legal Representation, and to Waive Notice of Trust Beneficiary.
Draft letter to Herb Thomas. Prepare Notice of Hearing.
Fee Petition
Paralegal
Draft Notice of Hearing.
Fee Petition
Paralegal
Fite Fee Petition.
Fee Petition
Paralegal
Serve Fee Petition and Notice of Hearing.
Fee Petition
Paralegal
File Notice of Hearing.
Fee Petition
EXHIB
Hrs/Rate Amount
0.70
360.00/hr
0.80
75.00/hr
0.20
75.00/hr
0.20
75.00/hr
0.40
75.00/hr
0.20
75.00/hr
mA
360.00
252.00
60.00
15.00
15.00
30.00
15.00
ESEHerb Thomas
5/7/2013 -
5/22/2013 -
5/29/2013 -
6/14/2013 ~-
6/17/2013 -
6/19/2013 -
6/20/2013 -
DAC.
EJH
MOB
RR
DAC
DAC
DAC.
RR
DAC
MOB
EJH
Legal
Correspondence from Andrew Schultz to Bruce Feder.
Correspondence from Andrew Schultz regarding levy on rents,
bank account. Memorandum to Elisabeth Hanowsky.
Fee Petition
Legal
Conference with Daniel A. Conrad regarding levies.
Fee Petition
Paralegal
Draft Order for Payment of Litigation Counsel Fees. Drop-off Order
at 400 McAllister Street.
Fee Petition
Legal
Revise fee petition order.
Fee Petition
Legat
Correspondence to Herb Thomas.
Fee Petition
Legal
Review examiner's notes. Correspondence to Herb Thomas.
Fee Petition
Legal
Correspondence from Andrew Schultz regarding notes.
Fee Petition
Legal
Review Examiner's Notes.
Fee Petition
Legal
Correspondence from, to Sandra Hilton regarding hearing.
Correspondence to, from Bruce Feder. Correspondence from
Andrew Schultz,
Fee Petition
Legal
Calendaring.
Fee Petition
Legal
Prepare Ex Parte Petition for Waiver of Notice and accounting.
Prepare Writs of Execution, Notice of Levy, and Memorandum of
Costs. Legal research regarding appropriate costs for
memorandum.
Fee Petition
__Hrs/Rate
0.20
420.00/nr
0.10
270.00/nr
0.40
75.00/hr
0.20
360.00/hr
0.10
420.00/hr
0.10
420.00/hr
0.10
420.00/hr
0.20
360.00/hr
9.20
420.00/hr
0.10
150.00/hr
2.20
270.00/nr
Page 2
Amount
84.00
27.00
30.00
72.00
42.00
42.00
42.00
72.00
84.00
15.00
594.00Herb Thomas
6/21/2013 -
6/24/2013 -
6/25/2013 -
6/28/2013 -
6/30/2013 -
7/2013 -
7/11/2013 ~
7/12/2013 -
7/19/2013 ~
12/10/2013 -
EJH
EJH
EJH
DAC
EJH
DAC
EJH
EJH
EJH
Legal
Revise all pieadings. Review of Examiner Notes and perform
billing analysis.
Fee Petition
Legal
Revise Ex Parte Application to Waive Notice. Prepare Supplement
to petition.
Fee Petition
Legal
Prepare supplement to fee petition and notice of hearing. Revise
Ex Parte Application. Fax to Sandy Hilton.
Fee Petition
Legal
Revise supplement to petition. Review and sign ex parte petition
regarding notice to Gregory Wiggins.
Fee Patition
Legat
File fee petition and Ex Parte Application. Deliver to Room 202.
Fee Petition
Legal
Review file. Revise Order.
Fee Petition
Legal
Review file.
Fee Petition
Legal
Attend fee petition hearing.
Fee Petition
Legal
Review order granting petition.
Fee Petition
Legal
Review and email Order.
Fee Petition
Legal
Prepare Order for recording.
Fee Petition
Legal
Review of fees/biiling.
Fee Petition
_Hrs/Rate
1.30
270.00/hr
0.60
270.00/nr
2.00
270.00/hr
0.20
420.00/hr
0.10
270.00/hr
0.40
360.00/hr
0.50
360.00/hr
2.00
360.00/hr
0.10
420.00/hr
0.10
270.00/hr
0.10
270.00/hr
0.10
270.00/hr
Page 3
Amount
351.00
162.00
540.00
84.00
27.00
144,00
180.00
720.00
42.00
27.00
27.00
27.00Herb Thomas.
2/7/2014 - DAC
- MOB
Legal
Review billing, payments, revise correspondence to Andrew
Schultz,
Fee Petition
Legal
Revise bill and recelvables. Conference with Daniel A. Conrad
regarding prior fee petition and prior order. Draft correspondence
to Andrew Schultz.
Fee Petition
SUBTOTAL:
General
4/25/2013 - DAC
7/26/2013 - DAC
8/6/2013 - EJH
8/14/2013 - DAC
8/21/2013 - DAC
Legai
Review Newhall taundromat listing agreement with Cassidy -
Turley. Conference with Andrew Schultz.
General
Legal
Telephone call from Andrew Schultz.
General
Legal
Revise correspondence to Herb Thomas.
General
Legal
Telephone call to Andrew Schultz. Review file regarding costs
advanced.
General
Legai
Telephone call from, Correspondence from, correspondence to
Andrew Schultz regarding request for judicial notice.
General
SUBTOTAL:
Gregory Wiggins
3/4/2013 - DAC
Legal
Correspondence from Andrew Schultz regarding collection of
judgment.
Gregory Wiggins
—tits/Rate
0.20
450.00/hr
0.50
200.00/hr
15.60
0.30
420.00/hr
0.10
420.00/hr
0.10
270.00/hr
0.20
420.00/hr
0.10
420.00/hr
0.80
0.10
420.00/hr
Page 4
Amount
90.00
100.00
4,372.00
126.00
42.00
27.00
84.00
42.00
321.00
42.00Herb Thomas
3/4/2018 -
93/5/2013 -
3/6/2013 -
3/11/2013 -
3/12/2013 -
3/13/2013 -
3/14/2013 -
3/20/2013 -
9/21/2013 -
3/22/2013 -
DAG
EJH
EJH
DAC
DAG
DAC
EJH
EJH
EJH
EJH
DAC
Legal
Conference with Andrew Schultz regarding Wiggins, fee petition.
Gregory Wiggins
Legal
Legal research regarding third party rent levies and assignment
orders. Memorandum regarding same.
Gregory Wiggins
Legal
Review debtor exam transcript and revise memorandum regarding
rental payments.
Gregory Wiggins
Legal
Review memorandum from Elisabeth Hanowsky regarding levying
on Wiggins’ Hercules rent. Correspondence to Andrew Schultz.
Gregory Wiggins
Legai
Correspondence from, to Andrew Schultz. Review correspondence
to Gregory Wiggins.
Gregory Wiggins
Legal
Correspondence from, to Andrew Schultz regarding Newhall,
Hercules properties. Memo to Elisabeth Hanowsky regarding
Newhal title, mechanics lien judgment.
Gregory Wiggins
Legal
Legal and Lexis research regarding mechanics liens.
Gregory Wiggins
Legal
Legal and lexis research regarding attachment of mechanics liens,
cancellation of deeds and relation back, and unenforceable
mechanic's liens,
Gregory Wiggins
Legal
Further legal research regarding invalidating mechanics lien.
Gregory Wiggins
Legai
Legal and Lexis research regarding void and voidable deeds, effect
of.
Gregory Wiggins
Legal
Conference with Andrew Schultz regarding Sheriff levy to collect
Wiggins rental income, default judgment by architects on Newhall
property. Correspondence from A. Schultz regarding order which
—Hrs/Rate
0.30
420.00/hr
4.70
270.00/nr
0.30
270.00/hr
0.10
420.00/hr
0.10
420.00/hr
0.20
420.00/hr
1.00
270.00/hr
4.20
270.00/hr
1.50
270.00/nr
1.50
270.00/hr
0.70
420.00/hr
Page 5
Amount
126.00
459.00
81.00
42.00
42.00
84.00
270.00
1,134.00
405.00
405.00
294.00Herb Thomas
3/25/2013 -
3/26/2013 -
3/27/2013 -
4/9/2013 -
4/10/2013 -
4/12/2013 -
4/15/2013 -
4/25/2013 -
EJH
DAC
EJH
EJH
DAC
EJH
EJH
DAC
DAC
DAC
canceled Newhall deed. Memorandum to Elisabeth Hanowsky.
Gregory Wiggins
Legal
Draft memorandum regarding foreclosure of mechanics lien.
Gregory Wiggins
Legal
Conference with Elisabeth Hanowsky regarding architects’
judgment, order canceling deed to LLC.
Gregory Wiggins
Legal
Revise memorandum regarding mechanics lien.
Gregory Wiggins
Legal
Conference with Daniel A. Conrad and Andrew Schultz.
Gregory Wiggins
Legal
Memorandum to Elisabeth Hanowsky regarding correspondence to
lawyers for the architects regarding Newhall judgment lien.
Gregory Wiggins
Legal
Draft settlement letter to Baum Thornley Architects.
Gregory Wiggins
Legal
Revise correspondence to David Phillips and to attorney for Baum
Thornley Architects.
Gregory Wiggins
Legal
Correspondence to David Phillips at Old Republic Title Company
regarding Newhall title.
Gregory Wiggins
Legal
Review memorandum from Elisabeth Hanowsky regarding rent
levy. Conference with Andrew Schultz regarding levy on rent.
Gregory Wiggins
Lega!
Conference with Andrew Schultz regarding Newhall title, lien.
Correspondence to Old Republic Title.
Gregory Wiggins
—Hrs/Rate
1.20
270.00/hr
0.20
420.00/hr
0.60
270.00/nr
0.20
270.00/hr
0.10
420.00/hr
0.60
270.00/nr
0.40
270.00/nr
0.10
420.00/hr
0.40
420.00/hr
0.40
420.00/hr
Page 6
Amount
324.00
84.00
162.00
54.00
42.00
162.00
108.00
42.00
168.00
168.00Herb Thomas
4/25/2013 -
4/26/2013 -
6/10/2013 -
6/11/2013 -
6/12/2013 -
6/17/2013 -
6/18/2013 -
6/19/2013 -
6/25/2013 -
EJH
DAC
DAC
DAC
EJH
DAG
DAC
EJH
DAC
EJH
DAC
Legal
Conference with Daniel A. Conrad regarding status.
Gregory Wiggins
Legal
Correspondence from Old Republic Title regarding no recorded
judgment by architects. Correspondence to Andrew Schultz.
Gregory Wiggins
Legal
Correspondence from, to Andrew Schultz,
Gregory Wiggins
Legal
Memorandum to Elisabeth Hanowsky.
Gregory Wiggins
Legal
Prepare levies. Legal and Lexis research regarding abstract
attachment to trust assets. Email to Andrew Schultz.
Gregory Wiggins
Legai
Correspondence from, telephone call to Andrew Schultz regarding
Mrs. Hart petition to amend trust, collection efforts regarding
Gregory Wiggins.
Gregory Wiggins
Legal
Correspondence from Andrew Schuitz to Bruce Feder.
Gregory Wiggins
Legal
Review research regarding Wiggins trust, liens. Lexis research
regarding same, pre- and post-death enforcement. Conference
with Daniel A. Conrad.
Gregory Wiggins
Legal
Conference cail with Herb Thomas and Andrew Schultz.
Gregory Wiggins
Lega!
Legal and Lexis research on affect of judgment lien, title, abstract,
and design professional liens. Prepare memorandum.
Gregory Wiggins
Legal
Correspondence from, to Andrew Schultz. Review Mrs. Hart
petition to amend trust and disinherit Gregory Wiggins.
Gregory Wiggins
Hrs/Rate
0.20
270.00/hr
0.10
420.00/hr
0.10
420.00/hr
0.10
420.00/hr
1.20
270.00/nr
0.20
420.00/hr
0.10
420.00/hr
2.20
270.00/hr
0.50
420.00/hr
2.00
270.00/hr
0.20
420.00/hr
Page 7
——Amount
54.00
42.00
42.00
42.00
324.00
84.00
42.00
594.00
210.00
540.00
84,00Herb Thomas
7/1/2013 -
7/3/2013 -
7/17/2013 -
7/18/2013 -
8/5/2013 -
8/7/2013 -
8/13/2013 -
8/23/2013 -
8/29/2013 -
EJH
EJH
EJH
EJH
EJH
EJH
DAC
EJH
EJH
DAC
Legal
Revise Writs of Execution. Conference with Daniel A. Conrad.
Telephone call to Contra Costa Sheriff.
Gregory Wiggins
Legal
Review of service list/fee petition for reason of address change.
Gregory Wiggins
Legal
Revise two Writs of Execution. Calculate new interest charges.
Gregory Wiggins
Legal
Telephone call to court regarding e-file procedure for probate writs.
E-file Memorandum of Costs.
Gregory Wiggins
Legal
Correspondence to San Francisco and Contra Costa Sheriffs.
Gregory Wiggins
Legal
Telephone call from Carla at the San Francisco Sheriff's Office.
Review deposition transcript for additional information on bank
account. Fax to same.
Gregory Wiggins
Legal
Telephone call from, correspondence from David Phillips at Old
Republic Title. Correspondence to Andrew Schultz.
Gregory Wiggins
Legal
Email to Andrew Schultz and to Herb Thomas. Telephone call to
and conference with Karel Marecek regarding fevy on 211 Tanager.
Gregory Wiggins
Legal
Telephone call to Karel Marecek. Telephone call to Vanessa
Bowman - she has a lawyer who will call us. Review file, levy.
Telephone call to Contra Costa Sheriff.
Gregory Wiggins
Legal
Telephone call to Judge Charles Breyer. Correspondence to Herb
Thomas.
Gregory Wiggins
Hrs/Rate
0.40
270.00/hr
0.10
270.00/hr
0.40
270.00/hr
0.30
270.00/hr
0.50
270.00/hr
0.40
270.00/hr
0.20
420.00/nr
0.40
270.00/nr
1.00
270.00/hr
0.30
420.00/hr
Page 8
Amount
408.00
27.00
108.00
81,00
135.00
108.00
84.00
108.00
270.00
126.00Herb Thomas
8/29/2013 -
8/30/2013 -
9/3/2013 -
9/4/2013 -
9/6/2013 -
9/20/2013 -
9/23/2013 -
10/2/2013 -
10/15/2013 -
11/4/2013 -
DAC
DAG
DAC
DAC
EJH
DAC
EJH
DAC
EJH
EJH
DAG
DAG
Legal
Conference with Andrew Schultz regarding LLC.
Gregory Wiggins
Legal
Correspondence from Andrew Schultz.
Gregory Wiggins
Legal
Correspondence from Herb Thomas.
Gregory Wiggins
Legal
Review declaration regarding no funds in credit union account
subject to San Francisco Sheriff levy.
Gregory Wiggins
Legal
Email to Herb Thomas and Andrew Schultz. Review of lien history
on Tanager property.
Gregory Wiggins
Legal
Conference with Andrew Schultz regarding rent levy.
Gregory Wiggins
Legal
Review correspondence from Contra Costa County Sheriff
regarding funds received.
Gregory Wiggins
Legal
Review memorandums of garnishee (2) from credit union.
Gregory Wiggins
Lega!
Review checks from Contra Costa Sheriff regarding rent levy.
Gregory Wiggins
Legal
Revise correspondence to Herb Thomas. Conference with Danie!
A. Conrad.
Gregory Wiggins
Legal
Review 2 checks from Contra Costa County Sheriff. Endorse to
Herb Thomas. Correspondence to Herb Thomas.
Gregory Wiggins
Legal
Correspondence from Contra Costa County Sheriff regarding
received additional $2,000 on rent levy.
Hrs/Rate
0.20
420.00/nr
0.10
420.00/hr
0.10
420.00/hr
0.10
420.00/nr
0.30
270.00/hr
0.10
420.00/hr
0.10
270.00/hr
0.10
420.00/hr
0.10
270.00/nr
0.20
270.00/hr
0.20
420.00/hr
0.10
420.00/hr
Page 9
Amount
84.00
42.00
42.00
42.00
81.00
42.00
27.00
42.00
27.00
54.00
84.00
42.00Herb Thomas
11/20/2013 -
1/9/2014 -
1/10/2014 -
1/16/2014 -
2/3/2014 -
2/10/2014 -
2/19/2014 -
DAC
EJH
EJH
EJH
DAC
DAG
DAC
EJH
DAC
DAC
Gregory Wiggins
Legai
Review, endorse check from contra Contra Costa County Sheriff.
Gregory Wiggins
Legal
Correspondence to Andrew Schultz and Herb Thomas.
Gregory Wiggins
Legal
Memorandum regarding received checks, review of file.
Gregory Wiggins
Legal
Review checks and correspondence to Herb Thomas. Notes to file.
Gregory Wiggins
Legal
Telephone call to Andrew Schultz regarding checks received from
Contra Costa County Sheriff, accounting.
Gregory Wiggins
Legal
Correspondence from Contra Costa County Sheriff regarding
received $2,000.
Gregory Wiggins
Legal
Review, endorse checks received from Contra Costa County
Sheriff.
Gregory Wiggins
Legal
Correspondence to Herb Thomas. Telephone call from Andrew
Schultz regarding new trustee appointed. Telephone call to Herb
Thomas regarding accounts. Review of checks and update to file.
Gregory Wiggins
Legal
Correspondence from Andrew Schultz. Correspondence to,
telephone call from Ernest Der regarding Wiggins judgment
collection, architect judgment.
Gregory Wiggins
Legal
Correspondence from Contra Costa Sheriff regarding received
$2,000 for Wiggins !evy.
Gregory Wiggins
Hrs/Rate
0.10
420.00/hr
0.10
270.00/hr
0.30
290.00/hr
0.20
280.00/hr
0.10
450.00/hr
0.10
450.00/nr
0.10
450.00/hr
0.40
290.00/hr
0.20
450.00/hr
0.10
450.00/hr
Page 10
Amount
42.00
27.00
87.00
58.00
45.00
45.00
45.00
116.00
90.00
45.00Herb Thomas
2/25/2014 -
2/28/2014 -
3/6/2014 -
3/7/2014 -
3/24/2014 -
3/26/2014 -
3/27/2014 -
4/2/2014 -
DAC
DAC
EJH
DAC
EJH
DAC
DAC
EJH
EJH
EJH
DAC
Legal
Correspondence to Ernest Der regarding checks on Wiggins levy.
Gregory Wiggins
Legal
Review two checks from Contra Costa County Sheriff.
Gregory Wiggins
Legal
Correspondence to Ernest Der. Review file, prepare for storage.
Gregory Wiggins
Legal
Endorse checks to Paula Bibbs. Revise correspondence to Ernest
Der.
Gregory Wiggins
Legal
Revise correspondence to Ernest Der.
Gregory Wiggins
Legal
Correspondence from Contra Costa County Sheriff. Telephone call
to Ernest Der regarding substitution of judgment creditor
(voicemail). Memorandum to Elisabeth Hanowsky regarding
procedure.
Gregory Wiggins
Legal
Review and revise correspondence to Contra Costa County Sheriff
regarding change of trustee.
Gregory Wiggins
Legal
Correspondence to Contra Costa Sheriff and telephone call to
same. Conference with Daniel A. Conrad.
Gregory Wiggins
Legal
Review order appointing trustee and revise correspondence to
Ernest Der.
Gregory Wiggins
Legal
Review of checks received from the Contra Costa Sheriff.
Correspondence to Ernest Der.
Gregory Wiggins
Legal
Endorse checks from Sheriff, correspondence to Ernest Der.
Gregory Wiggins
Hrs/Rate
0.10
450.00/hr
0.10
450.00/nr
0.40
290.00/hr
0.10
450.00/hr
0.20
290.00/hr
0.20
450.00/hr
0.10
450.00/hr
0.50
290.00/hr
0.10
290.00/hr
0.20
280.00/hr
0.10
460.00/hr
Page 11
Amount
45.00
45.00
116.00
45.00
58.00
90.00
45.00
145.00
29.00
58.00
45.00Herb Thomas
SUBTOTAL:
For professional services rendered
Additional Charges :
Gregory Wiggins
4/5/2013 Court Fees
Court Fee. San Francisco Superior Court.
Gregory Wiggins
4/25/2013 $Lexis
Computer research
Gregory Wiggins
6/25/2013 $filing fees
Filing Fee. Superior Court of California.
Gregory Wiggins
7/19/2013 Court Fees
Court fees. San Francisco Superior Court.
Gregory Wiggins
7/30/2013 $Lexis
Computer public records research
Gregory Wiggins
7/31/2013 Court Fees
Court fees. San Francisco Superior Court.
Gregory Wiggins
$recordation
San Francisco Assessor Recorder.
Gregory Wiggins
8/5/2013 $process server
San Francisco Sheriff's Department.
Gregory Wiggins
$process server
Pracess server. Contra Costa County Sheriff.
Gregory Wiggins
9/29/2013 $filing fees
Filing fees. File & Serve Xpress.
Gregory Wiggins
—Hrs/Rate
32.30
48.70
Pris
Page 12
Amount
9,841.00
$14,534.00
450.00
194.10
60.00
26.00
44.19
50.00
22.00
35.00
35.00
5.00Herb Thomas
9/30/2013 Data Tree
Computer records search
Gregory Wiggins
10/31/2013 $Lexis
Computer public records research
Gregory Wiggins
SUBTOTAL:
Total costs
9/4/2013 Payment - thank you. Check No. 289
TOTAL AMOUNT DUE:
1 31.44
31.14
1 20.31
20.31
972.74
$972.74
($1,177.11)
$14,329.634/18/2014 Law Offices of
10:09 AM Listing Page 1
Selection Criteria
Slip. Transaction Dat 2/1/2013 - 8/5/2013
Clie.Selection include: 11-073 Rosia Hart Trust
Slip.Slip Type Expense
Slip.Selection Exclude: 153523
Rate Info - identifies rate source and level
Slip [ID Atterney Units Rate Slip Value Billed SV
Dates and Time Activity DNB Time Rate Info Adjustment
Posting Status Client Est. Time Bill Status Markup
Description Reference Variance
Client: 11-073 Rosia Hart Trust
150821 EXP DAC 1 305.01 305.04 305.01
2/28/2013 $Lexis
Bilted G:22738 4/19/2013 11-073 Rosia Hart Trust
Computer research
151451 EXP DAC 1 450.00 450.00 450.00
4/5/2013 $Court Fees
Billed G:22818 5/20/2013 11-073 Rosia Hart Trust
Court Fee. San Francisco Superior Court. Gregory Wiggins
151452 EXP DAC 1 194.10 194.10 494.10
4/25/2013 SLexis
Billed G:22818 5/20/2013 11-073 Rosia Hart Trust
Computer research Gregory Wiggins
152823 EXP DAC 1 60.00 60.00 60.00
6/25/2013 Sfiling fees
Billed G:22997 7/19/2013 11-073 Rosia Hart Trust
Filing Fee. Superior Court of California. Gregory Wiggins
153505 EXP DAC 4 26.00 26.00 26.00
7119/2013 $Court Fees
Billed G:23192 8/14/2013 11-073 Rosia Hart Trust
Court fees. San Francisco Superior Court. Gregory Wiggins
163504 EXP DAC 41 22.00 22.00 22.00
7/31/2013 $recordation
Billed G.23192 8/14/2013 11-073 Rosia Hart Trust
San Francisco Assessor Recorder. Gregory Wiggins
183506 EXP. DAC 1 50.00 50.00 50.00
7/31/2013 $Court Fees
Billed G:23192 8/14/2013 11-073 Rosia Hart Trust
Court fees. San Francisco Superior Court. Gregory Wiggins
ExHiBiT_ ©4/18/2014 Law Offices of
10:09 AM Listing Page 2
Slip iD Attomey Units Rate Slip Value Billed SV
Dates and Time Activity DNB Time Adjustment
Posting Status Client Est. Time Markup
Description Reference Variance
154199 EXP DAC 1 35.00 35.00
8/5/2013 $process server
Billed G:23397 9/16/2013 11-073 Rosia Hart Trust
San Francisco Sheriff's Department. Gregory Wiggins
154203 EXP DAC 4 35.00 35.00
8/5/2013 $process server
Billed G:23397 9/16/2013 11-073 Rosia Hart Trust
Process server. Contra Costa County Sheriff. Gregory Wiggins
Total: 11-073 Rosia Hart Trust
Billabie 0.00 4177.44 4177.14
Unbillable 0.00 0.00
Total 0.00 1177.44
Grand Total
Billable 0.00 VW77414 ANT7A4
Unbillable 0,00 0.00
Total 0.00 AATTAAoR N DH ek WOH A
NNN YN NN NY Ba we mw eo
NOoaesk &©S 255 G62 USHER AS
PROOF OF SERVICE
| declare that | am over the age of eighteen years and not a party to the within
entitled cause. | am an employee of the LAW OFFICES OF DANIEL A. CONRAD, and my
business address is 1550 Bryant Street, Suite 760, San Francisco, California, 94103.
On May 2, 2014, | served the following documents:
1. DECLARATION OF DANIEL A. CONRAD IN SUPPORT OF ALLOWANCE OF
LITIGATION COUNSEL'S FEES AND COSTS, AS A LIEN AGAINST REAL
PROPERTY.
in said cause, by delivering a true copy thereof addressed as follows:
SEE ATTACHED LIST
[XX] BY MAIL: To be mailed by the United States Postal Service by piacing the
sealed envelopes, with the postage thereon fully prepaid, for collection and
mailing in the ordinary course of business.
{] BY PERSONAL DELIVERY: To be personally delivered by hand to the above
address.
[] BY OVERNIGHT DELIVERY: To be delivered to the above address within 24
hours by Federal Express overnight delivery service.
[] BY FACSIMILE TRANSMISSION: To be transmitted by facsimile to the
telephone numbers indicated above.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct and that this declaration was executed on May 2, 2014, at San
Francisco, California.
MICHAEL WORRALLRosia L. Hart Revocable Trust
PTR-06-288755
Rosia Lee Hart
3133 Crestline Court
Antioch, CA 94531
Bruce Feder, Esq.
Kato, Feder & Suzuki
685 Market Street, Suite 540
San Francisco, CA 94105
Pastor Henry Gaines
1490 Kennedy Ave.
Weed, CA 96094
Adeline Reed
306 Portland Avenue
Oakland, CA 94606
Gayle R. Reed
2389 Flatley Circle
Fairfield, CA 94533
Rosalind Reed Williams
4766 Stonewood Drive
Fairfield, CA 94531
Reverend Andrew Smith
2709 Lotus Court
Antioch, CA 94531
SERVICE LIST
Jackie Smith
2705 Lotus Court
Antioch, CA 94531
Baum Thomiley Architects LLP
c/o Coblentz, Patch, Duffy & Bass LLP
One Ferry Building, Suite 200
San Francisco, CA 94111
Paula Bibbs
35 Grove Street, Suite 108
San Francisco, CA 94102
Ernest Der, Esq.
Skootsky & Der LLP
90 New Montgomery Street, Suite 600
San Francisco, CA 94105
Herb Thomas
875-A Island Drive #387
Alameda, CA 94502
Andrew Schultz
Witherspoon & Siracusa
1550 Bryant Street, Suite 725
San Francisco, CA 94103