Preview
FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013
NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
EXHIBIT “O”
FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013
NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF ROCKLAND
PARAGON FEDERAL CREDIT UNION C/K/A
VISIONS FEDERAL CREDIT UNION, Index No.: 032165/2013
Plaintiff, ATTORNEY FEE
AFFIRMATION
-vs-
MURIEL BOONE A/K/A MURIEL T. THORNTON,
ROBERT ELLSWORTH, UNITED STATES OF AMERICA,
IRS, TENANTS AND OCCUPANTS #1 THROUGH #12 OF
THE MORTGAGED PREMISES,
Defendants.
Alyssa Gillespie, an attorney duly admitted to practice law before the courts of the State of
New York, affinns the following to be true under penalties of perjury:
1. I am an associate at Dorf & Nelson LLP, attorneys for the Plaintiff PARAGON
FEDERAL CREDIT UNION C/K/A VISIONS FEDERAL CREDIT UNION, ("Plaintiff"), and
as such, I am familiar with the facts and circumstances and prior pleadings and proceedings
heretofore had herein.
2. I submit this Affinnation in support of the attorney's fees associated with this
commercial foreclosure action to date.
Attorneys'
3. fees of $32,557.50 are requested in this foreclosure action; that being a
reasonable fee based on actual time extended and quantum meruit and actual time expended.
Your deponent respectfully states that such fees are reasonable in amount and that Plaintiff is
justly and equitably entitled to an award thereof pursuant to the note and mortgage which are the
subject of this action.
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4. The work performed by Plaintiff's counsel included, but was not limited to, filing
a summons and complaint, drafting and filing a motion for an Order of Reference, attending
court appearances, appearing as a creditor in the accompanying Bankruptcy action, obtaining the
Referee's Report of Amount Due, and preparing the instant application for entry of a Judgment
of Foreclosure and Sale. To this end, after the Order of Reference was obtained, Plaintiff's
counsel consulted with Plaintiff to prepare Plaintiff s Testimony Before Referee that formed part
of the Referee's Report of Amount Due. Thereafter, Plaintiff prepared and submitted the
requisite materials to the Referee in order to obtain the Referee's Report of Amount Due.
Plaintiff's counsel also prepared the within final Judgment of Foreclosure and Sale and
affinnation in support thereof. Your deponent respectfully request additional funds be set aside
for additional costs for attorney fees and other expenses for additional services, which will be
required by Plaintiff s counsel, to be added to the final judgment amount.
5. Additional services which will be required of Plaintiff s counsel include, but are
not limited to, the preparation of the notice of sale, serving the notice of sale, overseeing the
publication of the notice of sale, preparing the terms of sale, submitting the terms of sale to the
Referee, collaborating with Plaintiff to compute the upset price, attending the foreclosure sale
and submitting the necessary terms of the sale to the Referee, arranging for the closing of titleto
the Mortgaged Premises at the Referee's office, reviewing any possible title objections,
preparing and submitting the Referee's Deed and Referee's Report of Sale, preparing and
submitting the attendant tax forms for the Referee's Deed. In the event there are insufficient
monies realized from the sale, Plaintiff s counsel must obtain the necessary certificates of
appearance and of no exceptions to the Referee's Report of Sale for a deficiency judgment
application, allof which Plaintiff's counsel must prepare.
2
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
6. To the best of my knowledge, information, and belief, the proceedings herein
have been regular, in conformity with the law, and in accordance with the rules of this Court.
7. That no previous application for any of the relief herein prayed for has been
made.
WHEREFORE, your deponent respectfully requests that this Court enter into an Order:
(1) confirming and ratifying the Referee's Report of Amount Due, dated February 20, 2018; (2)
entering a Judgment of Foreclosure and Sale; and (3) awarding any such other and further relief
as this Court may deem just and proper.
Dated: Rye, New York
May 9, 2018 DORF & NELSON LLP
lyss Gillespie, Esq
3
FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013
NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
D & N
DORF & NELSONtte
The International Corporate Center
555 Theodore Fremd Avenue, A300
Rye, NY 10580
Phone: 914.381.7600Fax: 914.381.7608
April 30, 2018
Visions FCU
Attn: Collections Dept./Workout Specialist
24 McKinley Avenue
Endicott, NY 13760
In Reference To: Muriel Boone
PROFESSIONAL SERVICES
Hours Amount
3/29/2013 DES Draft and prepare request for foreclosure search. 0.30 67.50
DES Receipt and review file,including note, mortgage, worksheet, 0.40 90.00
pre-foreclosure notices, policy.
4/15/2013 DES Draft and prepare summons, complaint and notice of pendency. 3.50 787.50
6/11/2013 JJY Draft & prepare client affidavit. 1.00 225.00
JJY Draft & prepare affirmation and memo of law 2.00 450.00
JJY Draft & prepare client Lippman Affidavit. 0.10 22.50
9/20/2013 JJY Draft and prepare reinstatement letter to Defendant's attomey. 0.30 67.50
2/14/2014 RCB Review and analyze case filefor continued discovery 0.50 112.50
3/12/2014 RCB Review and analyze case fileregarding Motion for Summary 0.10 22.50
Judgment
3/13/2014 RCB Communicate with Stacy Shoemaker regarding status of matter. 0.20 45.00
4/3/2014 JVD Review of order denying motion for summary judgment with 0.80 180.00
leave to renew. Drafting of new motion.
4/8/2014 JVD Finalized renewed motion for summary judgment; review of 0.50 112.50
Judge Kelly's Individual Rules regarding motions.
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 2
Hours Amount
4/9/2014 JVD Edits to renewed motion for summary judgment; related legal 0.80 180.00
research.
4/10/2014 JVD Revisions to motion for summary judgment. 0.50 112.50
4/11/2014 JVD Finalized motion for summary judgment; filing and service of 0.30 67.50
same.
5/6/2014 JVD Preparation of reply in further support of motion for summary 2.50 562.50
judgment; including supporting affidavit and memorandum of law.
5/7/2014 ABR E filingand assembling Plaintiff's Affidavit in Further Support 0.50 112.50
and Memorandum of Law in Reply and in Further Support of its
motion for summary judgment.
JVD Communications with client regarding reply in further support of 1.50 337.50
motion for summary judgment; finalizing reply and filing and
service of same.
5/22/2014 JBN Draft Notice of Entry regarding:the Decision and Order of the 0.30 67.50
Honorable William A. Kelly dated the 19th day of May, 2014 and
entered in the Rockland County Clerks Office on the21st day of
May, 2014.
6/19/2014 JVD Preparation of Order of Reference. 1.20 270.00
7/2/2014 JVD Preparation of application for Order of Reference. 4.00 900.00
7/3/2014 JVD Revisions to application for Order of Reference. 0.20 45.00
7/31/2014 JVD Preparation of application for Order of Reference and 0.30 67.50
communications with client regarding same.
8/5/2014 JBN Draft Notice of Appearance regarding Bankruptcy case. 0.30 67.50
JVD Review of bankruptcy proceedings. 0.10 22.50
10/29/2014 JVD Preparation for Bankruptcy case management conference 1.00 225.00
scheduled for October 30, 2014.
10/30/2014 JVD Attendance at and participation in InitialCase Management 2.40 540.00
Conference for defendant's bankruptcy case.
2/2/2015 JJK Communication with Borrower's counsel Robert Reda regarding 0.40 90.00
status of matter.
2/3/2015 JJK Communication with borrower's counsel, Robert Reda, regarding 0.30 67.50
case status.
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 3
Hours Amount
3/17/2015 JJK Communication with borrower's counsel Robert Reda 0.20 45.00
4/7/2015 JJK Review Borrower Debtor's bankruptcy filing of operating 0.30 67.50
procedures
4/8/2015 JJK Communication with client; update case status sheet 0.20 45.00
7/10/2015 OCA Drafted Affidavit in support of motion for relief from stay. 1.40 315.00
7/16/2015 OCA Reviewed documents in preparation for motion to liftbankruptcy 0.70 157.50
stay.
OCA Drafted affirmation in support of motion to liftbankruptcy stay. 1.60 360.00
7/17/2015 OCA Revised motion for relief of automatic stay of foreclosure actions. 0.30 67.50
JJK Communication with client regarding motion to liftstay; 0.40 90.00
draft/revise motion to liftstay
7/20/2015 OCA Drafted motion to liftbankruptcy stay. 0.30 67.50
8/14/2015 OCA Communicated with client regarding status of matter. 0.10 22.50
8/26/2015 OCA Drafted motion for relief from bankruptcy stay. 0.80 180.00
8/27/2015 OCA Drafted motion forrelief from bankruptcy stay. 1.30 292.50
8/28/2015 OCA Communicated with client regarding motion to liftbankruptcy 0.20 45.00
stay.
9/14/2015 LMH Prepare for hearing in Bankruptcy matter. 0.50 112.50
JJK Communication with client regarding status; confer with 0.40 90.00
appeariñg attorney on motion to liftstay, status of post petition
payments, and foreclosure.
9/15/2015 LMH Appear for status conference in Bankruptcy proceeding. 2.10 472.50
JJK Communication with appearing attorney on status of court 0.60 135.00
appearance; communication with client on statusof matter and
court appearance; communication with Borrower's counsel Robert
Reda on upcoming sale
9/18/2015 JJK Review/analyze disclosures and operating reports filed by 0.20 45.00
borrower in bankruptcy
9/21/2015 JJK Communication with client regarding reinstatement and payoff; 0.50 112.50
communication with Borrowers counsel Robert Reda regarding
payoff, reinstatement and status of matter
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 4
Hours Amount
9/22/2015 JJK Communication with Robert Reda, borrower's attorney, regarding 0.20 45.00
status of matter, sale and reinstatement
9/24/2015 JJK Communication with client contact regarding payoff and case 0.40 90.00
status; review payoff letter and attorneys fees; communication
with Borrowers counsel regarding updating payoff
10/2/2015 JJK Communication with Borrowers attorney Robert Reda regarding 0.20 45.00
status of matter, payoff amounts and proposed sale
10/6/2015 JJK Communication with Borrowers counsel Robert Reda regarding 0.20 45.00
status of matter and contract of sale
10/13/2015 JJK Communication with Borrower's counsel, Robert Reda, 0.20 45.00
communication with client regarding status of sale
11/3/2015 JJK Communication with Borrower's counsel Robert Reda, 0.30 67.50
communication with client regarding status of matter and
upcoming sale
11/9/2015 JJK Review operating report filed by Debtor Muriel Boone 0.30 67.50
11/16/2015 JJK Communication with Borrower's counsel Robert Reda, regarding 0.20 45.00
sale, communication with client regarding status of matter
11/18/2015 JJK Review/analyze Borrower/Debtor's application to sell property 0.80 180.00
free and clear of liens and to shorten time for application;
communication with client contact regarding Borrower's
application and proposed response
11/19/2015 JJK Draft/revise affirmation in response to Borrower's application to 0.80 180.00
sell free and clear of liens
11/20/2015 JJK Draft affirmation in response to Debtor's application to sell 1.70 382.50
property and in support of motion to lift stay
11/23/2015 JJK Review/analyze motion to settlement deadline for filing proofs of 0.40 90.00
claim filed by Debtor
JJK Draft/revise attorney affirmation in response to Debtor's 0.50 112.50
application to sell property and in support of application to lift
stay; communication with client regarding status of matter
11/24/2015 JJK Communication with client contact regarding status of motion to 0.70 157.50
sell;review payoff letters, compile exhibits for filing,finalize
affirmation in response to Debtor's motion and filewith ECF
11/25/2015 JH Communication with Stacy Shoemaker regarding status of matter. 0.10 22.50
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 5
Hours Amount
11/25/2015 JH Assembling Opposition to Debtor's Application for an Order to 0.60 135.00
Authorize Sale.
JBN E-filing Opposition to Debtor's Application for an Order to 0.50 112.50
Authorize Sale
12/1/2015 JJK Communication with Danny Alter, counsel for Debtor, regarding 0.30 67.50
status of matter
JJK Communication with client contact Stacy Shoemaker regarding 0.20 45.00
status of matter
12/2/2015 RCB Plan and prepare for mandatory court appearance in Bankruptcy 0.70 157.50
Court in the Souther District of NY.
12/3/2015 ABR Communication with Robert Read, Esq. regarding status of 0.10 22.50
matter.
ABR Communication with Dorothy Li, Judge Drain's Law Clerk, 0.10 22.50
regarding status of matter.
12/4/2015 JJK Communication with Robert Reda, Borrower's counsel, regarding 0.50 112.50
upcoming sale, status of BK plan, and closing details;
communication with client contact Stacy Shoemaker regarding
status of matter
12/15/2015 JJK Communication with client contact, and Borrower's counsel, 0.40 90.00
Robert Reda, regarding status of matter and closing
12/16/2015 JJK Communication with client regarding status of matter; 0.50 112.50
communication with Borrower's counsel Robert Reda regarding
status of matter and closing
1/12/2016 JJK Communication with client regarding status of matter, 0.50 112.50
communication with counsel for the debtor regarding status of
sale.
JJK Draft proofs of claim 0.50 112.50
1/20/2016 JJK Communication with Borrower's counsel regarding status of sale 0.20 45.00
and payment of taxes
1/27/2016 JJK Communication with client contact Stacy Shoemaker regarding 0.40 90.00
status of bankruptcy, sale and proofs of claim, review/revise
proofs of claim
2/2/2016 DJW Communication with Robert L. Reda, P.C.'s Law office regarding 0.10 22.50
status of matter.
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 6
Hours Amount
2/4/2016 JJK Draft/revise proofs of claim 0.30 67.50
2/5/2016 JJK Draft/revise proof of claim to incorporate client changes; 0.70 157.50
draft/revise mortgage proof of claim attachment
2/9/2016 JJK Draft proof of claim for Nyack Property and Mortgage Proof 0.70 157.50
Attachment; draft/revise Proof of claim and attachment for
Mahwah
2/19/2016 JJK Communication with client regarding status of sale and lift stay; 0.30 67.50
communication with Borrower's counsel regarding status of sale
2/22/2016 ALK Draft motion to liftautomatic stay 2.00 450.00
2/23/2016 ALK Draft/revise motion to liftstay 1.00 225.00
2/24/2016 JJK Communication with Borrower/Debtor's counsel, Robert Reda, 0.40 90.00
regarding status of bankruptcy and sale,communication with
client contact Stacy Shoemaker regarding update from Borrower's
counsel
2/25/2016 JJK Draft/revise motion to liftstay 0.60 135.00
2/29/2016 JJK Draft/revise motion to liftstay 0.70 157.50
3/7/2016 ALK Draft/revise motion to lift stay 1.00 225.00
JJK Draft/revise motion to lift stay 0.40 90.00
3/11/2016 ALK Draft/revise motion to lift stay 0.80 180.00
3/16/2016 JJK Communication with Debtor/Borrower's counsel regarding sale, 0.30 67.50
status of bankruptcy, liftstay motion and payoff amount;
3/22/2016 JJK Communication with Robert Reda, counsel for Borrower, 0.20 45.00
regarding updated payoff, sale closing and status of bankruptcy
3/28/2016 JJK Communication with client contact Stacy Shoemaker regarding 0.40 90.00
property sale, status of bankruptcy matter and reinstatement of
Nyack loan; Communication with Robert Reda, Esq, counsel for
Borrower
3/30/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.40 90.00
surplus money, reinstatement and status of bankruptcy,
communication with client regarding status of matter
4/15/2016 JJK Communication with client contact; communication with Debtor's 0.20 45.00
counsel Robert Reda
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 7
Hours Amount
4/22/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.20 45.00
surplus funds and status of bankruptcy
5/3/2016 JJK Communication with Debtor's counsel, Robert Reda, 0.20 45.00
Communication with client contact regarding status of matter
5/5/2016 JJK Communication with Robert Reda regarding status of bankruptcy 0.20 45.00
5/10/2016 JJK Communication with Debtor/Borrower's counsel Robert Reda 0.40 90.00
regarding status of bankruptcy, liftstay, and sale proceeds
JJK Communication with client contact Stacy Shoemaker regarding 0.20 45.00
status of bankruptcy and debtor's application to disburse surplus
funds
5/11/2016 JJK Communication with Muriel Boone's counsel, Robert Reda, 0.30 67.50
regarding application regarding surplus funds
5/17/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.10 22.50
application for disbursement of surplus funds
5/23/2016 JJK Communication with Robert Reda regarding status of matter and 0.10 22.50
motion for disbursement of surplus funds
5/24/2016 JJK Communication with Debtor's counsel Robert Reda, regarding 0.30 67.50
application for surplus funds; communication with client
regarding status of matter
5/27/2016 JJK Communication with Debtor's counsel Robert Reda, 0.20 45.00
communication with client contact regarding status of filing
6/7/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50
status of matter
6/21/2016 JJK Communication with Debtor's counsel, Robert Reda, about bk 0.30 67.50
application and motion to lift stay
6/22/2016 JJK Communication with client contact Julie Prince, communication 0.20 45.00
with Borrower/Debtor's counsel Robert Reda.
6/28/2016 JJK Draft/revise application for disbursement of surplus sale proceeds 1.80 405.00
6/29/2016 JJK Communication with client contact regarding case update, case 0.40 90.00
strategy, trustee's motion to dismiss, and upcoming appearance;
draft/revise letter to the court regarding scheduling conference
regarding surplus funds
7/8/2016 JH Communication with Doroty Li, law clerk to Judge Robert Drain, 0.10 22.50
regarding status of matter.
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 8
Hours Amount
7/11/2016 ABR Communication with clients regarding status of matter. 0.10 22.50
JLM Prepare for status conference 0.20 45.00
7/12/2016 JLM Appear for status conference 3.90 877.50
7/18/2016 JJK Communication with client contact, Scott Bird, regarding status of 0.20 45.00
matter and application for surplus funds
7/19/2016 JJK Communication with Scott Bird from Visions regarding status of 0.40 90.00
matter.
7/20/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.50 112.50
payoff figures and application to disburse surplus funds,
communication with client contact Scott Byrd regarding attorneys
fees and reinstatement and payoff figures.
8/8/2016 JJK Review/analyze Borrower's application to appoint broker; 0.50 112.50
communication with Debtor's counsel Robert Reda regarding
status of matter and surplus funds
8/9/2016 JJK Communication with Chris Alfarano regarding status of matter 0.50 112.50
JJK Review/analyze notice for appointment of broker for subject 0.40 90.00
property
8/11/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.10 22.50
status of matter and application for surplus funds
8/12/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50
status of application for disbursement of surplus proceeds.
8/16/2016 JJK Draft/revise letterto the court regarding status of surplus funds. 0.40 90.00
JJK Communication with Debtor's counsel, Robert Reda, regarding 0.20 45.00
status of surplus proceeds
JJK Communication with client contact, Chris Alfarano regarding 0.20 45.00
status of matter and surplus proceeds
8/17/2016 JBN E-filing letter to Judge Drain regarding request for conference. 0.10 22.50
8/22/2016 JJK Communication with Court regarding court conference for surplus 0.20 45.00
proceeds
JJK Review/analyze Debtor's application to disburse surplus proceeds, 0.50 112.50
including exhibits
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 9
Hours Amount
8/22/2016 JJK Review/analyze Debtor's application to shorten notice for pending 0.20 45.00
applications
8/23/2016 JJK Communication with client contacts, including Chris Alfaro, 0.30 67.50
regarding status of bankruptcy, and surplus proceeds application
JJK Draft/revise attorney affirmation in response to Debtor's 1.20 270.00
application for an Order Authorizing Disbursement of Basic
Living Expenses and in Support of Visions Application for
Disbursement of Retroactive payment of Post Petition Payments
8/25/2016 JJK Draft/revise attorney affirmation requesting disbursement of 0.60 135.00
retroactive post-petition payments for filing of said application
with the court
9/6/2016 JJK Communication with client contact Scott Byrd regarding status of 0.40 90.00
matter at his request
9/7/2016 JJK Review/analyze Debtor's supplementary application for the 0.80 180.00
disbarment of funds filed on 9/6/2016; draft/revise affirmation in
response to Debtor's application
9/26/2016 RCB Prepare for appearance on Debtors Motion for Payment of Living 0.50 112.50
Expenses.
JJK Communication with Scott Byrd regarding status of matter, 0.40 90.00
including court appearance and taxes, draft/revise case summary
for oral argument and appearance on Debtor's application for
disbursement of surplus proceeds
9/27/2016 RCB Attend oral argument on Debtor's Motion for the Payment of 3.10 697.50
Living Expenses in Southern District Bankruptcy Court in White
Plains NY.
JJK Review/analyze communication from Debtor's counsel to the 0.40 90.00
court regarding correction to application for disbursement of
surplus proceeds
Visions'
JJK Communication with Scott Byrd, and contacts, regarding 0.40 90.00
status of court appearance and disbursement of surplus proceeds.
10/11/2016 JJK Review/analyze proposed orders drafted by Borrower's counsel, 0.70 157.50
Robert Reda, regarding appointment of broker, and disbursement
of escrow funds, communication with Robert Reda regarding
language and revisions to Orders.
JJK Communication with client contact, Scott Byrd, at his request 0.40 90.00
regarding status of matter
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NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018
Visions FCU Page 10
Hours Amount
10/12/2016 JJK Communication with Chris Alfaro regarding status of matter; 0.40 90.00
communication with Debtor's counsel Robert Reda, regarding
status of proposed orders
11/1/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.50 112.50
status of matter and property; communication with client Scott
Byrd regarding status of matter and property
11/2/2016 JJK Communication with Borrower's counsel Robert Reda regarding 0.10 22.50
status of Nyack Property listing, and post petition payments
11/7/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.10 22.50
status of listing of Nyack property and post petition payment
11/14/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50
status of matter, property and post petition payment
11/18/2016 JJK Review/analyze proof of claim filed by Rockland County Dept of 0.40 90.00
Finance with regard to Nyack Property; communication with
Debtor's counsel regarding status of payments
12/13/2016 JJK Communication with client contact Scott Bird from Visions 0.80 180.00
regarding status of matter; draft/revise letter to the Court
regarding request for court conference based on Debtor's
non-payment of scheduled post petition payments; review/compile
communication with Debtor's counsel, Robert Reda
12/14/2016 JJK Communication with counsel for all parties and the court 0.30 67.50
regarding letter request for conference
12/16/2016 JJK Communication with trustee Paul Schwartberg at his request 0.30 67.50
regarding status of matter
12/19/2016 JH Communication with Dorothy Li, law clerk to Judge Drain, 0.10 22.50
regarding status of matter.
12/22/2016 JJK Communication with Ms. Li in Judges chambers regarding court 0.50 112.50
conference, communication with counsel for allparties regarding
court conference at court's instruction
12/29/2016 JJK Communication with Debtor's counsel Robert Reda and trustee, 0.20 45.00
per court's instruction, regarding court conference
1/3/2017 JJK
Preview
FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 EXHIBIT “O” FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ROCKLAND PARAGON FEDERAL CREDIT UNION C/K/A VISIONS FEDERAL CREDIT UNION, Index No.: 032165/2013 Plaintiff, ATTORNEY FEE AFFIRMATION -vs- MURIEL BOONE A/K/A MURIEL T. THORNTON, ROBERT ELLSWORTH, UNITED STATES OF AMERICA, IRS, TENANTS AND OCCUPANTS #1 THROUGH #12 OF THE MORTGAGED PREMISES, Defendants. Alyssa Gillespie, an attorney duly admitted to practice law before the courts of the State of New York, affinns the following to be true under penalties of perjury: 1. I am an associate at Dorf & Nelson LLP, attorneys for the Plaintiff PARAGON FEDERAL CREDIT UNION C/K/A VISIONS FEDERAL CREDIT UNION, ("Plaintiff"), and as such, I am familiar with the facts and circumstances and prior pleadings and proceedings heretofore had herein. 2. I submit this Affinnation in support of the attorney's fees associated with this commercial foreclosure action to date. Attorneys' 3. fees of $32,557.50 are requested in this foreclosure action; that being a reasonable fee based on actual time extended and quantum meruit and actual time expended. Your deponent respectfully states that such fees are reasonable in amount and that Plaintiff is justly and equitably entitled to an award thereof pursuant to the note and mortgage which are the subject of this action. FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 4. The work performed by Plaintiff's counsel included, but was not limited to, filing a summons and complaint, drafting and filing a motion for an Order of Reference, attending court appearances, appearing as a creditor in the accompanying Bankruptcy action, obtaining the Referee's Report of Amount Due, and preparing the instant application for entry of a Judgment of Foreclosure and Sale. To this end, after the Order of Reference was obtained, Plaintiff's counsel consulted with Plaintiff to prepare Plaintiff s Testimony Before Referee that formed part of the Referee's Report of Amount Due. Thereafter, Plaintiff prepared and submitted the requisite materials to the Referee in order to obtain the Referee's Report of Amount Due. Plaintiff's counsel also prepared the within final Judgment of Foreclosure and Sale and affinnation in support thereof. Your deponent respectfully request additional funds be set aside for additional costs for attorney fees and other expenses for additional services, which will be required by Plaintiff s counsel, to be added to the final judgment amount. 5. Additional services which will be required of Plaintiff s counsel include, but are not limited to, the preparation of the notice of sale, serving the notice of sale, overseeing the publication of the notice of sale, preparing the terms of sale, submitting the terms of sale to the Referee, collaborating with Plaintiff to compute the upset price, attending the foreclosure sale and submitting the necessary terms of the sale to the Referee, arranging for the closing of titleto the Mortgaged Premises at the Referee's office, reviewing any possible title objections, preparing and submitting the Referee's Deed and Referee's Report of Sale, preparing and submitting the attendant tax forms for the Referee's Deed. In the event there are insufficient monies realized from the sale, Plaintiff s counsel must obtain the necessary certificates of appearance and of no exceptions to the Referee's Report of Sale for a deficiency judgment application, allof which Plaintiff's counsel must prepare. 2 FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 6. To the best of my knowledge, information, and belief, the proceedings herein have been regular, in conformity with the law, and in accordance with the rules of this Court. 7. That no previous application for any of the relief herein prayed for has been made. WHEREFORE, your deponent respectfully requests that this Court enter into an Order: (1) confirming and ratifying the Referee's Report of Amount Due, dated February 20, 2018; (2) entering a Judgment of Foreclosure and Sale; and (3) awarding any such other and further relief as this Court may deem just and proper. Dated: Rye, New York May 9, 2018 DORF & NELSON LLP lyss Gillespie, Esq 3 FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 D & N DORF & NELSONtte The International Corporate Center 555 Theodore Fremd Avenue, A300 Rye, NY 10580 Phone: 914.381.7600Fax: 914.381.7608 April 30, 2018 Visions FCU Attn: Collections Dept./Workout Specialist 24 McKinley Avenue Endicott, NY 13760 In Reference To: Muriel Boone PROFESSIONAL SERVICES Hours Amount 3/29/2013 DES Draft and prepare request for foreclosure search. 0.30 67.50 DES Receipt and review file,including note, mortgage, worksheet, 0.40 90.00 pre-foreclosure notices, policy. 4/15/2013 DES Draft and prepare summons, complaint and notice of pendency. 3.50 787.50 6/11/2013 JJY Draft & prepare client affidavit. 1.00 225.00 JJY Draft & prepare affirmation and memo of law 2.00 450.00 JJY Draft & prepare client Lippman Affidavit. 0.10 22.50 9/20/2013 JJY Draft and prepare reinstatement letter to Defendant's attomey. 0.30 67.50 2/14/2014 RCB Review and analyze case filefor continued discovery 0.50 112.50 3/12/2014 RCB Review and analyze case fileregarding Motion for Summary 0.10 22.50 Judgment 3/13/2014 RCB Communicate with Stacy Shoemaker regarding status of matter. 0.20 45.00 4/3/2014 JVD Review of order denying motion for summary judgment with 0.80 180.00 leave to renew. Drafting of new motion. 4/8/2014 JVD Finalized renewed motion for summary judgment; review of 0.50 112.50 Judge Kelly's Individual Rules regarding motions. FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 2 Hours Amount 4/9/2014 JVD Edits to renewed motion for summary judgment; related legal 0.80 180.00 research. 4/10/2014 JVD Revisions to motion for summary judgment. 0.50 112.50 4/11/2014 JVD Finalized motion for summary judgment; filing and service of 0.30 67.50 same. 5/6/2014 JVD Preparation of reply in further support of motion for summary 2.50 562.50 judgment; including supporting affidavit and memorandum of law. 5/7/2014 ABR E filingand assembling Plaintiff's Affidavit in Further Support 0.50 112.50 and Memorandum of Law in Reply and in Further Support of its motion for summary judgment. JVD Communications with client regarding reply in further support of 1.50 337.50 motion for summary judgment; finalizing reply and filing and service of same. 5/22/2014 JBN Draft Notice of Entry regarding:the Decision and Order of the 0.30 67.50 Honorable William A. Kelly dated the 19th day of May, 2014 and entered in the Rockland County Clerks Office on the21st day of May, 2014. 6/19/2014 JVD Preparation of Order of Reference. 1.20 270.00 7/2/2014 JVD Preparation of application for Order of Reference. 4.00 900.00 7/3/2014 JVD Revisions to application for Order of Reference. 0.20 45.00 7/31/2014 JVD Preparation of application for Order of Reference and 0.30 67.50 communications with client regarding same. 8/5/2014 JBN Draft Notice of Appearance regarding Bankruptcy case. 0.30 67.50 JVD Review of bankruptcy proceedings. 0.10 22.50 10/29/2014 JVD Preparation for Bankruptcy case management conference 1.00 225.00 scheduled for October 30, 2014. 10/30/2014 JVD Attendance at and participation in InitialCase Management 2.40 540.00 Conference for defendant's bankruptcy case. 2/2/2015 JJK Communication with Borrower's counsel Robert Reda regarding 0.40 90.00 status of matter. 2/3/2015 JJK Communication with borrower's counsel, Robert Reda, regarding 0.30 67.50 case status. FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 3 Hours Amount 3/17/2015 JJK Communication with borrower's counsel Robert Reda 0.20 45.00 4/7/2015 JJK Review Borrower Debtor's bankruptcy filing of operating 0.30 67.50 procedures 4/8/2015 JJK Communication with client; update case status sheet 0.20 45.00 7/10/2015 OCA Drafted Affidavit in support of motion for relief from stay. 1.40 315.00 7/16/2015 OCA Reviewed documents in preparation for motion to liftbankruptcy 0.70 157.50 stay. OCA Drafted affirmation in support of motion to liftbankruptcy stay. 1.60 360.00 7/17/2015 OCA Revised motion for relief of automatic stay of foreclosure actions. 0.30 67.50 JJK Communication with client regarding motion to liftstay; 0.40 90.00 draft/revise motion to liftstay 7/20/2015 OCA Drafted motion to liftbankruptcy stay. 0.30 67.50 8/14/2015 OCA Communicated with client regarding status of matter. 0.10 22.50 8/26/2015 OCA Drafted motion for relief from bankruptcy stay. 0.80 180.00 8/27/2015 OCA Drafted motion forrelief from bankruptcy stay. 1.30 292.50 8/28/2015 OCA Communicated with client regarding motion to liftbankruptcy 0.20 45.00 stay. 9/14/2015 LMH Prepare for hearing in Bankruptcy matter. 0.50 112.50 JJK Communication with client regarding status; confer with 0.40 90.00 appeariñg attorney on motion to liftstay, status of post petition payments, and foreclosure. 9/15/2015 LMH Appear for status conference in Bankruptcy proceeding. 2.10 472.50 JJK Communication with appearing attorney on status of court 0.60 135.00 appearance; communication with client on statusof matter and court appearance; communication with Borrower's counsel Robert Reda on upcoming sale 9/18/2015 JJK Review/analyze disclosures and operating reports filed by 0.20 45.00 borrower in bankruptcy 9/21/2015 JJK Communication with client regarding reinstatement and payoff; 0.50 112.50 communication with Borrowers counsel Robert Reda regarding payoff, reinstatement and status of matter FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 4 Hours Amount 9/22/2015 JJK Communication with Robert Reda, borrower's attorney, regarding 0.20 45.00 status of matter, sale and reinstatement 9/24/2015 JJK Communication with client contact regarding payoff and case 0.40 90.00 status; review payoff letter and attorneys fees; communication with Borrowers counsel regarding updating payoff 10/2/2015 JJK Communication with Borrowers attorney Robert Reda regarding 0.20 45.00 status of matter, payoff amounts and proposed sale 10/6/2015 JJK Communication with Borrowers counsel Robert Reda regarding 0.20 45.00 status of matter and contract of sale 10/13/2015 JJK Communication with Borrower's counsel, Robert Reda, 0.20 45.00 communication with client regarding status of sale 11/3/2015 JJK Communication with Borrower's counsel Robert Reda, 0.30 67.50 communication with client regarding status of matter and upcoming sale 11/9/2015 JJK Review operating report filed by Debtor Muriel Boone 0.30 67.50 11/16/2015 JJK Communication with Borrower's counsel Robert Reda, regarding 0.20 45.00 sale, communication with client regarding status of matter 11/18/2015 JJK Review/analyze Borrower/Debtor's application to sell property 0.80 180.00 free and clear of liens and to shorten time for application; communication with client contact regarding Borrower's application and proposed response 11/19/2015 JJK Draft/revise affirmation in response to Borrower's application to 0.80 180.00 sell free and clear of liens 11/20/2015 JJK Draft affirmation in response to Debtor's application to sell 1.70 382.50 property and in support of motion to lift stay 11/23/2015 JJK Review/analyze motion to settlement deadline for filing proofs of 0.40 90.00 claim filed by Debtor JJK Draft/revise attorney affirmation in response to Debtor's 0.50 112.50 application to sell property and in support of application to lift stay; communication with client regarding status of matter 11/24/2015 JJK Communication with client contact regarding status of motion to 0.70 157.50 sell;review payoff letters, compile exhibits for filing,finalize affirmation in response to Debtor's motion and filewith ECF 11/25/2015 JH Communication with Stacy Shoemaker regarding status of matter. 0.10 22.50 FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 5 Hours Amount 11/25/2015 JH Assembling Opposition to Debtor's Application for an Order to 0.60 135.00 Authorize Sale. JBN E-filing Opposition to Debtor's Application for an Order to 0.50 112.50 Authorize Sale 12/1/2015 JJK Communication with Danny Alter, counsel for Debtor, regarding 0.30 67.50 status of matter JJK Communication with client contact Stacy Shoemaker regarding 0.20 45.00 status of matter 12/2/2015 RCB Plan and prepare for mandatory court appearance in Bankruptcy 0.70 157.50 Court in the Souther District of NY. 12/3/2015 ABR Communication with Robert Read, Esq. regarding status of 0.10 22.50 matter. ABR Communication with Dorothy Li, Judge Drain's Law Clerk, 0.10 22.50 regarding status of matter. 12/4/2015 JJK Communication with Robert Reda, Borrower's counsel, regarding 0.50 112.50 upcoming sale, status of BK plan, and closing details; communication with client contact Stacy Shoemaker regarding status of matter 12/15/2015 JJK Communication with client contact, and Borrower's counsel, 0.40 90.00 Robert Reda, regarding status of matter and closing 12/16/2015 JJK Communication with client regarding status of matter; 0.50 112.50 communication with Borrower's counsel Robert Reda regarding status of matter and closing 1/12/2016 JJK Communication with client regarding status of matter, 0.50 112.50 communication with counsel for the debtor regarding status of sale. JJK Draft proofs of claim 0.50 112.50 1/20/2016 JJK Communication with Borrower's counsel regarding status of sale 0.20 45.00 and payment of taxes 1/27/2016 JJK Communication with client contact Stacy Shoemaker regarding 0.40 90.00 status of bankruptcy, sale and proofs of claim, review/revise proofs of claim 2/2/2016 DJW Communication with Robert L. Reda, P.C.'s Law office regarding 0.10 22.50 status of matter. FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 6 Hours Amount 2/4/2016 JJK Draft/revise proofs of claim 0.30 67.50 2/5/2016 JJK Draft/revise proof of claim to incorporate client changes; 0.70 157.50 draft/revise mortgage proof of claim attachment 2/9/2016 JJK Draft proof of claim for Nyack Property and Mortgage Proof 0.70 157.50 Attachment; draft/revise Proof of claim and attachment for Mahwah 2/19/2016 JJK Communication with client regarding status of sale and lift stay; 0.30 67.50 communication with Borrower's counsel regarding status of sale 2/22/2016 ALK Draft motion to liftautomatic stay 2.00 450.00 2/23/2016 ALK Draft/revise motion to liftstay 1.00 225.00 2/24/2016 JJK Communication with Borrower/Debtor's counsel, Robert Reda, 0.40 90.00 regarding status of bankruptcy and sale,communication with client contact Stacy Shoemaker regarding update from Borrower's counsel 2/25/2016 JJK Draft/revise motion to liftstay 0.60 135.00 2/29/2016 JJK Draft/revise motion to liftstay 0.70 157.50 3/7/2016 ALK Draft/revise motion to lift stay 1.00 225.00 JJK Draft/revise motion to lift stay 0.40 90.00 3/11/2016 ALK Draft/revise motion to lift stay 0.80 180.00 3/16/2016 JJK Communication with Debtor/Borrower's counsel regarding sale, 0.30 67.50 status of bankruptcy, liftstay motion and payoff amount; 3/22/2016 JJK Communication with Robert Reda, counsel for Borrower, 0.20 45.00 regarding updated payoff, sale closing and status of bankruptcy 3/28/2016 JJK Communication with client contact Stacy Shoemaker regarding 0.40 90.00 property sale, status of bankruptcy matter and reinstatement of Nyack loan; Communication with Robert Reda, Esq, counsel for Borrower 3/30/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.40 90.00 surplus money, reinstatement and status of bankruptcy, communication with client regarding status of matter 4/15/2016 JJK Communication with client contact; communication with Debtor's 0.20 45.00 counsel Robert Reda FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 7 Hours Amount 4/22/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.20 45.00 surplus funds and status of bankruptcy 5/3/2016 JJK Communication with Debtor's counsel, Robert Reda, 0.20 45.00 Communication with client contact regarding status of matter 5/5/2016 JJK Communication with Robert Reda regarding status of bankruptcy 0.20 45.00 5/10/2016 JJK Communication with Debtor/Borrower's counsel Robert Reda 0.40 90.00 regarding status of bankruptcy, liftstay, and sale proceeds JJK Communication with client contact Stacy Shoemaker regarding 0.20 45.00 status of bankruptcy and debtor's application to disburse surplus funds 5/11/2016 JJK Communication with Muriel Boone's counsel, Robert Reda, 0.30 67.50 regarding application regarding surplus funds 5/17/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.10 22.50 application for disbursement of surplus funds 5/23/2016 JJK Communication with Robert Reda regarding status of matter and 0.10 22.50 motion for disbursement of surplus funds 5/24/2016 JJK Communication with Debtor's counsel Robert Reda, regarding 0.30 67.50 application for surplus funds; communication with client regarding status of matter 5/27/2016 JJK Communication with Debtor's counsel Robert Reda, 0.20 45.00 communication with client contact regarding status of filing 6/7/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50 status of matter 6/21/2016 JJK Communication with Debtor's counsel, Robert Reda, about bk 0.30 67.50 application and motion to lift stay 6/22/2016 JJK Communication with client contact Julie Prince, communication 0.20 45.00 with Borrower/Debtor's counsel Robert Reda. 6/28/2016 JJK Draft/revise application for disbursement of surplus sale proceeds 1.80 405.00 6/29/2016 JJK Communication with client contact regarding case update, case 0.40 90.00 strategy, trustee's motion to dismiss, and upcoming appearance; draft/revise letter to the court regarding scheduling conference regarding surplus funds 7/8/2016 JH Communication with Doroty Li, law clerk to Judge Robert Drain, 0.10 22.50 regarding status of matter. FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 8 Hours Amount 7/11/2016 ABR Communication with clients regarding status of matter. 0.10 22.50 JLM Prepare for status conference 0.20 45.00 7/12/2016 JLM Appear for status conference 3.90 877.50 7/18/2016 JJK Communication with client contact, Scott Bird, regarding status of 0.20 45.00 matter and application for surplus funds 7/19/2016 JJK Communication with Scott Bird from Visions regarding status of 0.40 90.00 matter. 7/20/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.50 112.50 payoff figures and application to disburse surplus funds, communication with client contact Scott Byrd regarding attorneys fees and reinstatement and payoff figures. 8/8/2016 JJK Review/analyze Borrower's application to appoint broker; 0.50 112.50 communication with Debtor's counsel Robert Reda regarding status of matter and surplus funds 8/9/2016 JJK Communication with Chris Alfarano regarding status of matter 0.50 112.50 JJK Review/analyze notice for appointment of broker for subject 0.40 90.00 property 8/11/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.10 22.50 status of matter and application for surplus funds 8/12/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50 status of application for disbursement of surplus proceeds. 8/16/2016 JJK Draft/revise letterto the court regarding status of surplus funds. 0.40 90.00 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.20 45.00 status of surplus proceeds JJK Communication with client contact, Chris Alfarano regarding 0.20 45.00 status of matter and surplus proceeds 8/17/2016 JBN E-filing letter to Judge Drain regarding request for conference. 0.10 22.50 8/22/2016 JJK Communication with Court regarding court conference for surplus 0.20 45.00 proceeds JJK Review/analyze Debtor's application to disburse surplus proceeds, 0.50 112.50 including exhibits FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 9 Hours Amount 8/22/2016 JJK Review/analyze Debtor's application to shorten notice for pending 0.20 45.00 applications 8/23/2016 JJK Communication with client contacts, including Chris Alfaro, 0.30 67.50 regarding status of bankruptcy, and surplus proceeds application JJK Draft/revise attorney affirmation in response to Debtor's 1.20 270.00 application for an Order Authorizing Disbursement of Basic Living Expenses and in Support of Visions Application for Disbursement of Retroactive payment of Post Petition Payments 8/25/2016 JJK Draft/revise attorney affirmation requesting disbursement of 0.60 135.00 retroactive post-petition payments for filing of said application with the court 9/6/2016 JJK Communication with client contact Scott Byrd regarding status of 0.40 90.00 matter at his request 9/7/2016 JJK Review/analyze Debtor's supplementary application for the 0.80 180.00 disbarment of funds filed on 9/6/2016; draft/revise affirmation in response to Debtor's application 9/26/2016 RCB Prepare for appearance on Debtors Motion for Payment of Living 0.50 112.50 Expenses. JJK Communication with Scott Byrd regarding status of matter, 0.40 90.00 including court appearance and taxes, draft/revise case summary for oral argument and appearance on Debtor's application for disbursement of surplus proceeds 9/27/2016 RCB Attend oral argument on Debtor's Motion for the Payment of 3.10 697.50 Living Expenses in Southern District Bankruptcy Court in White Plains NY. JJK Review/analyze communication from Debtor's counsel to the 0.40 90.00 court regarding correction to application for disbursement of surplus proceeds Visions' JJK Communication with Scott Byrd, and contacts, regarding 0.40 90.00 status of court appearance and disbursement of surplus proceeds. 10/11/2016 JJK Review/analyze proposed orders drafted by Borrower's counsel, 0.70 157.50 Robert Reda, regarding appointment of broker, and disbursement of escrow funds, communication with Robert Reda regarding language and revisions to Orders. JJK Communication with client contact, Scott Byrd, at his request 0.40 90.00 regarding status of matter FILED: ROCKLAND COUNTY CLERK 10/25/2018 04:08 PM INDEX NO. 032165/2013 NYSCEF DOC. NO. 146 RECEIVED NYSCEF: 10/25/2018 Visions FCU Page 10 Hours Amount 10/12/2016 JJK Communication with Chris Alfaro regarding status of matter; 0.40 90.00 communication with Debtor's counsel Robert Reda, regarding status of proposed orders 11/1/2016 JJK Communication with Debtor's counsel, Robert Reda, regarding 0.50 112.50 status of matter and property; communication with client Scott Byrd regarding status of matter and property 11/2/2016 JJK Communication with Borrower's counsel Robert Reda regarding 0.10 22.50 status of Nyack Property listing, and post petition payments 11/7/2016 JJK Communication with Borrower's counsel, Robert Reda, regarding 0.10 22.50 status of listing of Nyack property and post petition payment 11/14/2016 JJK Communication with Debtor's counsel Robert Reda regarding 0.10 22.50 status of matter, property and post petition payment 11/18/2016 JJK Review/analyze proof of claim filed by Rockland County Dept of 0.40 90.00 Finance with regard to Nyack Property; communication with Debtor's counsel regarding status of payments 12/13/2016 JJK Communication with client contact Scott Bird from Visions 0.80 180.00 regarding status of matter; draft/revise letter to the Court regarding request for court conference based on Debtor's non-payment of scheduled post petition payments; review/compile communication with Debtor's counsel, Robert Reda 12/14/2016 JJK Communication with counsel for all parties and the court 0.30 67.50 regarding letter request for conference 12/16/2016 JJK Communication with trustee Paul Schwartberg at his request 0.30 67.50 regarding status of matter 12/19/2016 JH Communication with Dorothy Li, law clerk to Judge Drain, 0.10 22.50 regarding status of matter. 12/22/2016 JJK Communication with Ms. Li in Judges chambers regarding court 0.50 112.50 conference, communication with counsel for allparties regarding court conference at court's instruction 12/29/2016 JJK Communication with Debtor's counsel Robert Reda and trustee, 0.20 45.00 per court's instruction, regarding court conference 1/3/2017 JJK