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  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
  • IN THE MATTER OF THE ROSIA L. HART REVOCABLE TRUST TRUST (PETITION TO REVOKE POWERS OF TRUSTEES) document preview
						
                                

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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