Preview
FILED: NASSAU COUNTY CLERK 01/25/2023 04:02 PM INDEX NO. 601483/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/25/2023
SUPREivlE COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
-------------------------------------------------------------------)(
FORCHELLI DEEGAN TERRANA LLP, Date Filed: 1/25/2023
Index No.
Plaintiff, VERIFIED
COMPLAINT
-against-
GLOBAL REACH AEROSPACE, LLC, GLOBAL
REACH AEROSPACE, INC., and CHRISTOPHER F.
MILAM,
Defendants.
----------------------------------------------------------- -----)(
Plaintiff, Forchelli Deegan Terrana LLP ("Plaintiff' of "FDT"), complaining
of the defendants, Global Reach Aerospace, LLC, GLOBAL REACH
AEROSPACE, INC. (collectively "Global Reach") and Christopher F. Milam
("Milam" and collectively "Defendants") respectfully alleges as follows:
Nature and Purpose of Action
I. Plaintiff FDT brings this action to collect the outstanding balance due
from Defendants for legal services rendered on their behalf, and at their request, in
2022. Defendants retained Plaintiff pursuant to a written engagement letter
(Exhibit I hereto), dated April 21, 2022, under which Defendants agreed to timely
pay for the services rendered on their behalf.
2. Despite the timely rendition of services for Defendants, the rendition
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of detailed monthly bills showing the services that were performed, and repeated
promises by Milam that the fees would be paid, Defendants have not paid for any
of the services rendered, and have not reimbursed Plaintiff for the disbursements
incurred on their behalf.
3. As discussed more fully below, those services included the attending
and monitoring atrial in the Delaware Chancery Court involving amanagement
dispute of a public entity which was a potential acquisitiontarget of Global Reach
where at the request of Milam, FDT agreed to cap the daily hourly charges for
attending the trial and submitting daily reports on the trial events. Consequently,
the fair and reasonable value of FDT's legal services exceeds the amount for which
Defendants were billed.
The Parties
4. Plaintiff is a prominent regional law firm with its office and place of
business a1333 Earle Ovington Blvd., Suite 1010, Uniondale, in the County of
Nassau, State of New York.
5. Plaintiff was retained by Defendants at the recommendation of the
corporate counsel retained by Defendants to assist them with the potential
acquisition of the public target company.
6. Not only have Defendants failed to pay Plaintiff for the professional
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services rendered, upon information and belief, Defendants have failed and refused
to pay all of the professionals they retained in connection with the potential
acquisition of the target company, including their investment bankers, their
corporate counsel, additional special litigation counsel, and Delaware counsel
involved with the express permission of Defendants to obtain court filings which
were not generally available.
7. Upon information and belief, at aIl times hereinafter mentioned,
defendant Global Reach is and was a Delaware Corporation. However, Global
Reach held itself out as a foreign limited liability company establish under Alaskan
law. Global Reach maintains its principal place of business in Houston, Texas
8. Upon information and belief, defendant Christopher F. Milam is an
individual residing in Houston Texas. Upon information and belief Milam is the
managing member of MFGP,LLC, another Alaska limited liability company
which is the sponsor of Global Reach (the LLC). Upon information and belief
Milam is an officer and director of Global Reach (the Delaware Corporation).
9. Milam personally participated in the activities giving rise to Plaintiffls
retention and representation of Global Reach, including signing the engagement
I When Milam signed the engagement letter, Global Reach was identified as a Delaware Limited Liability
Company.
J-
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letter, a copy of which is annexed as Exhibit 1 which was sent to Plaintiff in
Nassau County New York, negotiating a aap on the fee to be charged in connection
with activities he expressly requested that we perform in monitoring a trial
regarding control of the target entity in the Delaware Chancery Court, and making
numerous unfulfilled promises of payment to Plaintiff for the legal services
requested from and performed by plaintiff on behalf of Defendants
10. Plaintiff performed legal services for Defendants in Nassau County,
New York and in Wilmington Delaware at their request. Milam, the entity
Defendants and Plaintiffs understood and agreed that services would be performed
on their behalf by Plaintiff in Nassau County.
11. Upon information and belief, at all relevant times Global Reach was
an entity established by Milam for the pu{poses of engaging in a leveraged buyout
and the taking private of a major publicly traded company in the aerospace
industry the previous acquisition of which by another publicly traded company,
had been blocked by the Federal Trade Commission. That entity subsequently was
acquired by another suitor.
12. In connection with this potential acquisition and leveraged buyout,
Defendants assembled a team of professionals including FDT and other law firms
and investment bankers to advise and assist Defendants with their potential
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acquisition.
13. In or around July 2022 after questions were raised as to the visibility
of the role Milam could play in the entity to be acquired because its business
involved contracting with the government, and Milam had plead guilty to a crime,
Milam discharged his lead corporate attorney and investment bankers and hired
different attorneys and investment bankers to continue to pursue the possible
leveraged buyout.
14. Ultimately, Global Reach did not succeed in acquiring the target
company
BACKGROUND
15. Pursuant to the Engagement Letter, and at the request of the
Defendants, Plaintiff performed various legal services, including, inter alia,
obtaining reviewing and analyzingthe public court papers in legal proceedings
involving the target company, attendingatrial between factions of the target
company's board in the Delaware Chancery Court and providing daily reports of
the testimony and trial proceedings, providing background research on potential
board candidates for Global Reach or the entity to exist following the possible
acquisition, and other matters requested of Plaintiff related to the potential
acquisition.
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16. The Engagement Letter provides that PlaintifPs services would be
determined on an hourly basis at hourly rates specified in the Engagement Letter,
that services would be invoiced to Global Reach monthly, and that payment was to
be made by Global Reach within 10 days.
17. The engagement letter further provided that any dispute would be
resolved in Nassau County, New York.
18. Defendants agreed to these terms, retained Plaintiff and requested,
received and accepted the benefit of legal services from Plaintiff.
19. Commencing in Muy, 2022, and continuing for each month billing
cycle, Plaintiff sent Defendants invoices which reflected the work performed by
Plaintiff, the hourly rate andthe time expended.2 Copies of these Invoices are
cc2,'t3.
annexed collectively as Exh.
20. The unpaid and invoiced balance due and payable from Defendants to
Plaintiff is $60,196.47 .
21. Throughout and following the representation, and as late as October 3,
2
Although more than 8 hours daily were spent attending the Chancery Court trial and preparing and sending the
daily reports, the invoices reflect billing for the time of Gabriella Botticelli at 8 hours as requested by Mr. Milam
and-agried to prior to such services. Accordingly, those invoices understate both the time expended and the fair
and reasonable value for such services.
3 Thr invoices and emails attached as Exhibits to this complaint have been redacted to avoid publicly identifying
the target company, potential board members, and other sensitive information. Unredacted copies will be made
available to the Court.
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2022, Milam, in his individual and representative capacities, repeatedly assured
Plaintiff that Plaintiff would be paid in fulI and that Defendants would bring their
account current.
22. For example, by email dated July 19,2022, Milam wrote to Russell
Tisman, the FDT partner with primary responsibility for the legal work to be
performed for Defendants, that he was 'Just back from overseas (Slava Ukraina).
I will get the payment out to you. To expedite, can you have someone send me
the most recent invoices with the totals as of today!"
23. Although all invoices previously had been sent to Defendants,
additional copies were promptly resent to Milam.
24. After Defendants still failed to pay anything toward their legal fees, in
response to a follow up email from Mr. Tisman sent on October 3,2022, Milam
responded by email the same day assuring Plaintiff that he "Will get you paid
before the end of the month, if not the end of the week. No one's issue but mine."
Copies of these emails and the emails to which they respond are annexed
collectively as Exhibit 3.
25. As the invoices and emails reflect, Plaintiff has demanded payment
but despite personal assurances of payment from Milam, Defendants have failed
and refused to pay the balance due.
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26. The Engagement Letter advised Defendant in accordance with Part
137 of the Rules of the Chief Administrator of the Defendants' right to pursue
arbitration. Because the amount in dispute involves a sum of more than
$50,000.00, this case is not subject to arbitration pursuant toPatt 137.
27. Pursuant to the terms of the Engagement Letter, this dispute must be
brought in Nassau County, New York.
AS AND F R A FIRST CAUSE O F'ACTION
28. Plaintiff repeats and realleges each and every allegation contained in
(61"
paragraphs through '(27)) of the Complaint as if more fully set forth herein.
29. Defendants has breached their contract with Plaintiff by failing to pay
for the legal services rendered and the disbursements incurred on its behalf.
30. As a result of a breach of contract by Defendants, Plaintiff has
sustained damages in the amount of $60,196.47 .
AND FOR A S OF ACTI
31. Plaintiff repeats and realleges each and every allegation contained in
paragraphs "1" through 430)' of the Complaint set forth herein.
32. The services set forth above were performed by Plaintiff for
Defendant, in good faith and the Defendant accepted the services.
33. Plaintiff expected to be compensated for the services rendered.
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34. Defendant understood that Plaintiff was entitled to be paid for services
rendered
35. The reasonable value of the services rendered to Defendants was in
excess of $60,196.47, all of which remains unpaid.
36. Plaintiff is entitled to recover from Defendants the sum of not less
than $60,196.47 representing the fair and reasonable value for unpaid services and
disbursements
WHEREFORE, Plaintiff demands judgment against Defendant, as follows:
(a) On its First Cause of Action judgment against Defendants in the sum
of $60,196.47 with interest from June 1,2022;
(b) On its Second Cause of Action judgment against Defendants in the
sum of $60,196.47 with interest from June 1,2022;
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(c) the costs and disbursements of this action and such other and further
relief as this Court may deem just and proper.
Dated Uniondale, New York
January 23,2023
FORCI{ELLI DEEGAN TERRANA LLP
By: Russell G. Tisman, Esq.
Attorneys for Plaintiff
333 Earle Ovington Blvd.
Suite 1010
Uniondale, New York I 1553
(s16) 248-1700
To: Global Reach Aerospace, LLC
clo Oralia Everett
I9I2 Melissa Oaks Lane
Austin, TX 78744
Global Reach Aerospace, Inc.
c/o Corporation Services Co.
251Little Falls Drive
Wilmington, DE 19808
Christopher F. Milam
600 w. 2nd st
Austin, TX 7807I
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VERIFICATION
srATE OF NEW YORK )
) ss.:
COUNTY OF NASSAU )
RUSSELL G. TISMAN, being duly sworn, deposes and says:
I am aPartner in Forchelli Deegan Terrana LLP, plaintiff in the
above-captioned action. I am authorizedto make this verification. I have read
the foregoing Amended Verified Complaint and the same is true of my personal
knowledge and based on documents including the annexed exhibits, except as to
those matters stated upon information and belief and, as to those matters, I believe
them to be true.
Russell G
Sworn to before me this
2sth of January , 2023.
Notary
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EXHIBIT 1
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FS $EC H HI*LI
FI)T Btt.G.l\.N
TgFIRANA
RUSSELLG.TISMAN
PARTNER
FrnslvlANsltof,lc HtLLILAw-c oM
PERSoNAL Fex: (866) 522-7819
April2l ,2022
Mr. Christopher Milam, Manager
Global Reach Aerospace LLC
P.O. Box 151538
Austin, Texas 7871 5-1 538
RE: Retainer Letter
Dear Mr. Milam:
It is our customary practice, and it is now required by the Office of Court Administration'
that we provide our clients with a retainer letter with respect to our representation.
You have asked Forchelli Deegan Terrana LLP ("FDT") to represent Global Reach
Aerospace as co-counsel with Rimon Law and Edwards Maxon Mago and MacCauley to provide
advice with respect to a possible bid for Aerojet Rocketdyne and, if litigation is commenced, or
needs to be commenced, to serve as co-counsel in such related litigation along with Rimon,
Edwards Maxon, and if needed local counsel in the forum of such litigation.
This letter will set forth the scope of the services FDT will render for or on your behalf,
the manner in which our fees for those services will be determined, the extent to which you will
be responsible for our fees and expenses, our billing practices, and provisions for arbitration in
the event ofany fee dispute.
$eose af Renrssentstipp
FDT will represent you in connection with the above-described matter. Appeals, if any,
will require a separate agreement or engagement.
$'ees. Expeqscg. And Billlng *rsctic{s
We will charge for our legal services based upon hourly billing rates as lhey are in effect
from time to time. lfr/. ,"r"*. the right to adjust our rates in the future, and typically do so
annually. I expect that most of the work will be done by me. My current hourly rates is $605'00,
Other utto.neyr and paraprofessional will be involved as needed.
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Mr. Christopher Milam, Manager
April2l,2022
Page 2
We require the payment of $5,000.00 as an advance toward the satisfaction of charges for
fees and disbursements. We reserve the right to require a further retainer deposit if this deposit is
expended. If subsequent litigation or arbitration is filed or commenced, a further deposit will be
required. We will discuss amount at that time.
will submit monthly statements to you for our services rendered and disbursements
We
incuned. Our statements will indicate the nature of the work done during the time period covered
by the statement.
You are also responsible to pay or reimburse us for all out-of-pocket costs and expenses
that we incur in connection with this matter, including but not limited to, filing fees, copying
charges, express delivery charges, court and deposition transcript fees, reasonable travel
expenses, computer-assisted research, experts or consultants (who will not be retained without
your prior consent) and all costs and expenses ofany litigation or alternative dispute resolution
proceedings. Charges for costs may be sent to you for direct payment to the party rendering the
.tt*gr if nlt phced on our invoice. As we discussed, we may need to engage a forensic
document service in connection with the defense of this matter.
Payments are due within 10 days of receipt of our statements. If our statements are not
timely paid, we reserve the right to withdraw from our representation of you in the above matter
(with permission of a court where required).
In the event the firm receives funds which are generated by legal services provided by the
firmo or are otherwise the properly of the client, the firm reserves the right, and you agree that we
may apply any or all of such funds in payment of amounts due to the hrm for legal fees or other
expenses incurred on your behalf.
Fsrni$,Slss to Us af Accura,te Informatiqn
We have informed you that pursuant to court rule we are required, as your attorney, to
certifr in our court paper* ihut*.are aware of no inaccuracies in the submission. Accordingly,
you ugr.. to provide the firm with complete and accurate information which forms the basis of
any papers to be submitted to any court.
No Gua-fpntee gf Success
You acknowledge that the tirm has made no guarantees as to the disposition of any phass
of the matter,
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Mr. Christopher Milam, Manager
April2l,2A22
Page 3
Record Rctention and Disnosition
Unless otherwise agreed, our representation will terminate upon our sending our final
invoice of fees and expenses in this matter. Upon yoru request, we will retum documents and
other materials you have supplied to us in connection with this matter. We will retain our own
records relating to your representation (including accounting and time records, colrespondence,
attorney work product, etc.) in accordance with our records retention policy, a copy of which is
available upon request. For various reasons, including administrative and storage convenience
and expensi, we reserve the right to dispose of any documents and materials that we retain
within a reasonable time after the termination of our representation in this matter, in accordance
with the firm's record retention policy subject to applicable rules.
FDT makes every effort to bill fairly and clearly for fees and expenses, and to represent
client interests zealously and diligently. Nevertheless, you should know that if a fee dispute
arises in this matter, you may have the right to elect to resolve the dispute through arbitration
pursuant to Part 137 of the Rules of the Chief Administrator of the New York Courts. A copy of
Part I37 will be provided upon request, and will be provided in the event a dispute over fees
should arise. Any such dispute will be resolved in Nassau County, New York
In the event you request our professional services with regard to any matters not
specifically coveredby this retainer letter, in the absence of a separate agreement covering such
other services, the terms and conditions contained in this retainer letter shall apply. You
acknowledge that this is the entire agreement between us and that there are no promises or
representations which are not contained herein'
If you agres to &ese terms, pls*se sign a copy of this rstainsiletter at the.spece{s)
provided 6chw]anC return it te m;: Upon rlceipt oithe letter signed by you and the requested
ietainer deposit, we will proceed with our representation of you.
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Mr. Christopher Milam, Manager
Apnl2l,2A22
Page 4
We are delighted to have the opportunity to work with you again and appreciate your
confidence in us.
Very truly yours,
FORCHELLI DEEGAN TERRANA LLP
Russell G. Tisman
The foregoing terms nnd conditione
rre agreed to and acceptedl
Reach LLC
& company
04-2
F
Itns Manager
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EXHIBIT 2
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FORCHELLI
FDT DEEGAN
TERRANA
A LIMITED LIABILITY PARTNERSHIP
333 EARLE OVINGTON BLVD, SUITE IOIO
UNIONDALE, NEW YORK 11553
(516) 24A-17OO
TAX lD: ll-239489O
Oralia Everett - Controller May'J.,2022
Global Reach Aerospace LLC Matter No. 43818
P.O. Box 151538 Statement/Invoice No. 30597 8
Austin, Texas 78715-1538
RE: Co-Counsel in connection with possible bid for Aerojet Rocketdyne and related litigation
STATEMENT SUMMARY THROUGH April 30, 2022
Previous Statement Balance $o.oo
Cunent Billing Activity
Legal Services Rendered $29,302.00
Disbursements and Other Costs Incurred $o.oo
$0.00
Total Current Billing 929,302.00
Total $29,302.00
Payments and Credits Since Last Statement: $0.00
Total Balance Due: $29,302.00
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FORCHELLI
FDT DEEGAN
TERRANA
A LIMITED LIABILITY PARTNERSHIP
333 EARLE OVINGTON E}LVD, SUITE 1OIO
UNIONDALE, NEW YORK 11553
(516) 24A-17OO
Tax lD: tl-239489O
Oralia Everett - Controller May 1,2022
Global Reach Aerospace LLC Matter No. 43818
P.O. Box 151538 Statement/Invoice No. 305978
Austirl Texas 78715-1538
RE: Co-Counsel in connection with possible bid for Aerojet Rocketdyne and related litigation
For PROFESSIONAL SERVICES rendered from April 7,2022 THROUGH April30,2022z
DATE ATTY HOURS DESCRIPTION
0411812022 RGT 2.90 Review email from TF; Online search for information on
litigation involving Aerojet Rocketdyne; Obtain and review
case filings and email to TF re research results and open items.
0411912022 RGT 0.30 Review emails from client re developments and information
on board dispute and email exchange with TF and MS re same
and re privilege issues.
0412012022 RGT 1.80 Review additional client email re developments; Email
exchange with TF and MS; Conference call with TF and MS re
privilege issues and related issues; Follow up call with MS;
Initial telephone call with potential Delaware litigation local
counsel and emails with information for conflict check and
case information to obtain Chancery Court documents.
04121.12022 LMC 4.30 Phone call with R. Tisman re:backgrund and research
assignment, conduct legal research on the attorney-client
privilege, begin drafting memorandum re: attorney-client
issues.
0412't12022 RGT 1.40 ExtendedtelephonecallwithLCreprivilegeand
confidentiality issues as background for requested research;
Review email thread from Blank Rome and review docket
sheets from 2 Chancery Court Aerojet cases; Email exchange
with team re Chancery Court materials.
0412212022 GEB 4.70 Conf. with RGT re: background of case and research needed.
Review docket and pull all substantive filings and organize
same for review. Begin to review docket filings.
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0412212022 RGT 4.20 Email exchange with Blank Rome re Delaware litigation;
Review information re False Claim Act suit against Aerojet
and email exchange with TF re same; Telephone call with GB
re analysis of False Claim act litigation and evidence of alleged
wrongdoing and email to GB and team re same; Telephone
call with LC re privilege research and review preliminary
draft of legal analysis; Telephone call with TF re issues related
to litigation; Review email from TF re developments in proxy
contest and anticipated activity; Review dockets and designate
documents for review; Email to BR re obtaining documents;
Review email from GB re documents from Markus; Review
email from LC and preliminary analysis of Delaware privilege;
Emails to TF and MS re status of projects.
0412512022 GEB 4.40 Continue to review docket filings in preparation for summary
of allegations and evidence memorandum'
o4l2sl2o22 LMC 3.40 Conduct legal research on attorney-client privilege issues and
prepare memorandum outlining legal standards and issues.
0412s12022 RGT 0.80 Email exchange with GB re Marcus lawsuit analysis; Review
email from GB to team and follow up email exchange re scope
of documents available; Email to SET (BR) re Chancery Court
documents.
0412612022 GEB 9.80 Continue to review documents in Markus v. Aerodyne in
preparation for legal memorandum summarizing allegations
and evidence.
0412612022 LMC 4.20 Prcparcmemorandum outlining legal issues and strategy to
assert privilege over correspondence relating to potential
private equity transaction., review case law regard the Garner
doctrine and potential exemptions to the privilege'
0412612022 RGT 7.40 Email exchange with IT and Blank Rome re documents from
Chancery Court; Review email from LC with updated MOL
and status; Email exchange with TF and MS re litigation
analysis; Review Drake website materials; Obtain and initial
review of public filings from Chancery Court cases and email
exchange with MS re same; Review LC memo re
privilege/confidentiality issues and emails to LC re same.
0412712022 GEB 9.40 Draftlegal memorandums re: (i) ARmembers and (ii)
surunary of allegations and evidence in false claims case.
Discuss same with LC and RGT.
0412712022 LMC 2.00 Revise memorandum regarding attorney-client privilege
issues.
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0412712022 RGT 4.80 Continued review of materials from Chancery case files and
review of selected materials from CA litigation; Extended
telephone call with MS re analysis of cases and follow up;
Email to TF re analysis and follow up; Conference calls with
MS and TF re court files and next steps; Review emails and
wire reports re proxy contesf Telephone call with GB re
memos on Markus; review email from GB and draft memos;
Follow up email to MS, TF and GB re Markus litigation
analysis.
0412912022 RGT 0.80 Email exchange with AEC re insurance issue; Email to KS re
information needed on insurance issue.
0413012022 RGT 0.10 Review email from MS re California litigation.
PROFESSIONAL SERVICES: $29,302.00
SERVICES SUMMARY
ATTY NAME RATE HOURS AMOUNT
GEB Gabriella E. Botticelli 325.00 28.30 9,197.50
LMC LisaCasa 380.00 13.90 5,282.00
RGT Russell G. Tisman 605.00 24.50 1.4+822.50
TOTAL FORSERVICES 66.70 29,302.00
STATEMENTTOTAL $29,302.00
Page:3
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FORCHELLI
FDT DEEGAN
TE R RANA.
A LIMITED LIABILITY PARTNERSHIP
333 EARLE OVINGTON BLVD, SUITE IOIO
UNIONDALE, NEW YORK 11553
(516) 24e-17OO
Tax lD:11-2394890
Oralia Everett - Controller Statement/lrvoice No. 30597 I
Global Reach Aerospace LLC
P.O. Box 151538 Statement as of 05 /0U2022
AustirL Texas 78715-1538
Matter No:43818
Total Amount Due: 629,302.00
Amount enclosed:$-
Remit to:
FORCHELLI DEEGAN TERRANA LLP
333 Earle Ovington Boulevar4 Suite 1010
Uniondale, New York 11553
All Maior Credit Cards Accepted
Pay online at
http :/www.Forchellilaw. com/payments
Firm Wire Instructions
First National Bank of Long Island
Garden City, NY 11530
ABA#021411335
Account# 187019500
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F()RCHELLI
FDT DEEGAN
TERRANA
A LIMITED LIABILITY PARTNERSHIP
333 EARLE OVINGTON BLVD, SUITE IOIO
UNIONDALE, NEW YORK 11553
(516) 24e-17OO
Tax lD:11-2394890
Oralia Everett - Controller June'1.,2022
Global Reach Aerospace LLC Matter No. 43818
P.O. Box 151538 Statement/Invoice No. 306635
Austiry Texas 78715-1538
RE: Co-Counsel in connection with possible bid for Aerojet Rocketdyne and telated litigation
STATEMENT SUMMARY THROUGH May 31.,2022
Previous Statement Balance $29,302.00
Cunent Billing Activity
Legal Services Rendered $23,204.00
Disbursements and Other Costs Incurred $187.36
$o.oo
Total Current Billing $23,39L.36
Total $52,693.36
Payments and Credits Since Last Statement: $0.00
Total Balance Due: $52,693.36
23 of 56
FILED: NASSAU COUNTY CLERK 01/25/2023 04:02 PM INDEX NO. 601483/2023
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 01/25/2023
FORCHELLI
FDT DEEgAN
TERRANA
A LIMITED LIABILITY PARTNERSHIP
333 EARLE OVINGTON EILVD, SUITE IOIO
UNIONDALE, NEW YORK II553
(516) 24a-17OO
TAX lD:11-2394490
Oralia Everett - Controller |une1,,2022
Global Reach Aerospace LLC Matter No.438L8
P.O. Box 151538 Statement/Invoice No. 306635
Austin, Texas 78715-1538
RE: Co-Counsel in connection with possible bid for Aerojet Rocketdyne and related litigation
For PROFESSIONAL SERVICES rendered from May 7,2022 THROUGH May 3\,20222
DATE ATTY HOURS DESCRIPTION
05101,12022 RGT 0.60 Review analysis of California securities litigation.
0s10212022 RGT 1.10 Email to MS and TF re Cal. lit analysis memo; Telephone call
from SET (Blank Rome) re research and status on Delaware li|
Email exchange re update of Chancery filings and impending
TRO in CA; Email to BR re further Chancery filings; Review
email from BR and conunence review of docket sheets;
Review emails from MS re absence of motion in CA action and
activity in Chancery Court.
0510312022 RGT 1.00 Review chancery docket sheets and designate filings; Email to
AC and SET (BR) re Chancery documents; Email exchange
with TF and MS re developments in Chancery court.
05/04/2022 RGT 1.80 Review email from MS re proxy contest and respond;
Continued review of SEC filing.
0510712022 RGT 1.20 Email exchange arnong team re settlement of False Claim Act
lawsuit and review of documents related to settlement and to
current project.
0510912022 RGT 0.70 Quick file review and follow up email exchange with AC re
additional docket entries from Chancery Court proceedings.
05/L012022 RGT