Preview
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Exhibit A
[Duane Morris Invoices]
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PLEASE REMIT PAYMENT TO: PHILADELPHIA
DUANE MORRIS LLP CHICAGO
ATTN: PAYMENT PROCESSING WASHINGTON, DC
SAN FRANCISCO
PO BOX 787166 SILICON VALLEY
PHILADELPHIA, PA 19178-7166 SAN DIEGO
SHANGHAI
BOSTON
HOUSTON
October 18, 2022 DALLAS
AUSTIN
LOS ANGELES
BANKUNITED, N.A. TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
NEWARK
LAS VEGAS
CHERRY HILL
LAKE TAHOE
MYANMAR
You can pay this invoice on-line at No Charge!
Avoid the delays and lost mail through the USPS
Eliminate the time and cost of printing and save the postage
Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/)
VATIVORX, LLC, ET AL.
FILE# G6344-00081 INVOICE# 2959510 IRS#
CURRENT INVOICE $31,597.50
Fed Wire Payments: ACH Payments: Overnight Payment address
Lockbox Services 787166
Duane Morris LLP
MAC Y1372-045
401 MARKET STREET
PHILADELPHIA, PA 19106
PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM
AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE
END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS
INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS
WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH
LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED.
D UANE M ORRIS LLP
30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PHILADELPHIA
CHICAGO
WASHINGTON, DC
SAN FRANCISCO
October 18, 2022 SILICON VALLEY
SAN DIEGO
SHANGHAI
BOSTON
BANKUNITED, N.A. HOUSTON
DALLAS
AUSTIN
LOS ANGELES
TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
VATIVORX, LLC, ET AL. NEWARK
LAS VEGAS
CHERRY HILL
File# G6344-00081 Invoice# 2959510 IRS# LAKE TAHOE
MYANMAR
FOR PROFESSIONAL SERVICES RECORDED OMAN
THROUGH 09/30/2022 IN CONNECTION
WITH THE ABOVE-CAPTIONED MATTER. $31,597.50
TOTAL BALANCE DUE $31,597.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
October 18, 2022
Page 2
File # G6344-00081 INVOICE# 2959510
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
9/1/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH BRIAN 0.00 $0.00
MCGAHEE RE NEW WORKOUT MATTER.
9/2/2022 06357 JM PETRAKIS RECEIVED DEAL DOCUMENTS FROM 1.20 $990.00
BRIAN MCGAHEE AND
COMMUNICATIONS RE SAME; INITIAL
REVIEW TO VERIFY WHAT RECEIVED
AND WHAT ADDITIONAL INFORMATION
AND DOCUMENTS ARE NEEDED.
9/8/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF ALL DEAL 4.70 $3,877.50
DOCUMENTS, COLLATERAL, AND LIST
OF QUESTIONS AND CONCERNS
PROVIDED BY BANKUNITED; PREPARED
INTERNAL MEMO RE SAME; EMAIL
COMMUNICATIONS WITH BRIAN
MCGAHEE
9/8/2022 06357 JM PETRAKIS REVIEW AURORA ENGAGEMENT 0.40 $330.00
LETTER. .
9/8/2022 06357 JM PETRAKIS DRAFT LETTER TO LUIS LLUBERAS, 1.50 $1,237.50
COUNSEL FOR REGIONS REGARDING
MULTIPLE ISSUES AND CONCERNS
THAT BANK UNITED HAS ABOUT
9/9/2022 06357 JM PETRAKIS FOLLOW UP COMMUNICATIONS WITH 3.40 $2,805.00
BRIAN MCGAHEE AND BARRY BELDIN
RE
DRAFT EMAIL
TO LUIS LLUBERAS RE SAME; REVIEW
EMAIL FROM BRIAN MCGAHEE TO
PATRICK CARRIGAN.
9/9/2022 06357 JM PETRAKIS FOLLOW UP COMMUNICATIONS WITH 0.90 $742.50
CLIENT RE
INVESTIGATION RE SAME.
9/12/2022 06357 JM PETRAKIS RECEIVE AND REVIEW ADDITIONAL 2.80 $2,310.00
DOCUMENTS FROM CLIENT; REVIEW
LUIS LLABERAS' RESPONSES TO OUR
INQUIRIES IN EMAIL FROM 9/9 AND
DISCUSS WITH CLIENT; CONFERENCE
CALL WITH BARRY BELDIN AND BRIAN
MCGAHEE; REVIEW DRAFT OF EMAIL
PREPARED BY BRIAN MCGAHEE TO
REGIONS AND FOLLOW UP RE SAME. .
9/12/2022 06357 JM PETRAKIS REVIEWED EMAIL FRO LUIS LLABERAS 0.90 $742.50
WITH REVISED TERM SHEET;
ADDITIONAL COMMUNICATIONS WITH
BARRY BELDIN AND BRIAN MCGAHEE
RE
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
October 18, 2022
Page 3
File # G6344-00081 INVOICE# 2959510
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
9/13/2022 06357 JM PETRAKIS RECEIVE AND REVIEW DRAFTS OF 2.70 $2,227.50
FORBEARANCE TERM SHEETS AND
COMMUNICATIONS WITH CLIENT RE
SAME; DRAFT LIST OF COMMENTS AND
QUESTIONS; COMMUNICATIONS WITH
CLIENTS ABOUT CALL WITH REGIONS.
9/13/2022 06357 JM PETRAKIS CALL WITH REGIONS COUNSEL; AND 0.50 $412.50
PREPARE MEMO RE SAME.
9/14/2022 06357 JM PETRAKIS EMAIL COMMUNICATIONS WITH 0.40 $330.00
CLIENTS RE TERM SHEET ISSUES.
9/15/2022 06357 JM PETRAKIS REVIEW LATEST DRAFT OF 2.40 $1,980.00
FORBEARANCE TERM SHEET; DISCUSS
WITH CLIENTS; PREPARE FOR AND
ATTEND CALL WITH REGIONS BANK,
PARTICIPANT LENDERS, AND COUNSEL;
FOLLOW UP RE ADDITIONAL
REVISIONS TO TERM SHEET TO
ADDRESS .
9/15/2022 06357 JM PETRAKIS REVIEW LATEST DOCUMENTS 1.20 $990.00
UPLOADED TO DATA ROOM; FOLLOW
UP WITH CLIENT.
9/19/2022 06357 JM PETRAKIS REVIEW LATEST TURN OF 1.10 $907.50
FORBEARANCE TERMS SHEET;
COMMUNICATIONS WITH CLIENT RE
SAME AND OPEN ISSUES; EMAIL
EXCHANGE WITH LUIS LLABERAS.
9/19/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH BARRY 0.50 $412.50
BELDIN RE
.
9/20/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF LATEST 2.30 $1,897.50
DRAFT OF FORBEARANCE AGREEMENT;
COMMUNICATIONS WITH CLIENT RE
SAME; DRAFT EMAIL TO LUIS
LLABERAS WITH QUESTIONS AND
COMMENTS; REVIEW RESPONSE AND
DISCUSS WITH CLIENTS.
9/21/2022 06357 JM PETRAKIS COMMUNICATIONS WITH CLIENT RE 0.40 $330.00
FORBEARANCE AGREEMENT,
REMAINING CONCERNS, AND TIMING.
9/21/2022 06357 JM PETRAKIS REVIEW DOCUMENT REQUEST LIST 1.70 $1,402.50
UPDATE AND COMMUNICATIONS WITH
CLIENTS RE SAME AND OTHER ISSUES
OF CONCERN; ANALYSIS OF PERTINENT
CREDIT AGREEMENT TERMS IN
CONNECTION WITH
9/22/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 2.00 $1,650.00
LENDER GROUP CALL; EMAIL AND
PHONE COMMUNICATIONS WITH
CLIENTS RE SAME AND ISSUES ARISING
THEREFROM; ANALYSIS RE ACCOUNT
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
October 18, 2022
Page 4
File # G6344-00081 INVOICE# 2959510
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
DEBTOR LETTERS USE AND TIMING;
ANALYSIS OF REMEDIES.
9/23/2022 06357 JM PETRAKIS REVIEW BANKUNITED'S CONSENT TO 0.50 $412.50
ACCELRATION AND EXERCISE OF
REMEDIES; COMMUNICATIONS RE
SAME;
9/26/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 0.30 $247.50
MCGAHEE;
9/27/2022 06357 JM PETRAKIS REVIEW LETTER FROM BORROWER 1.80 $1,485.00
COUNSEL IN RESPONSE TO
ACCELERATION OF LOAN; DISCUSS
WITH CLIENTS; COMMUNICATIONS
WITH REGIONS COUNSEL; REVIEW
CORRESPONDENCE FROM CLIENT RE
ANALYSIS OF CREDIT
AGREEMENT AND DRAFT LETTER TO
LUIS LLABERAS .
9/28/2022 06357 JM PETRAKIS CREDIT AGREEMENT ANALYSIS IN 2.00 $1,650.00
RESPONSE TO CLIENT INQUIRIES;
COMMUNICATIONS WITH CLIENT RE
SAME; INVESTIGATION RE
9/29/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 1.50 $1,237.50
LENDER CALL; FOLLOW UP WITH
BRIAN MCGAHEE; COMMUNICATIONS
WITH LUIS LLABERAS.
9/30/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS RE LETTER 0.80 $660.00
FROM BORROWER WITH PROPOSAL;
PREPARE FOR AND CONDUCT CALL
WITH CLIENT RE SAME.
9/30/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF PROPOSED 0.40 $330.00
RESPONSE TO BORROWER
LETTER;CALL TO BRIAN MCGAHEE RE
SAME
Subtotal: 38.30 $31,597.50
TOTAL SERVICES 38.30 $31,597.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
October 18, 2022
Page 5
File # G6344-00081 INVOICE# 2959510
VATIVORX, LLC, ET AL.
TIMEKEEPER
NO. NAME CLASS HOURS RATE VALUE
06357 JM PETRAKIS PARTNER 38.30 825.00 $31,597.50
38.30 $31,597.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PLEASE REMIT PAYMENT TO: PHILADELPHIA
DUANE MORRIS LLP CHICAGO
ATTN: PAYMENT PROCESSING WASHINGTON, DC
SAN FRANCISCO
PO BOX 787166 SILICON VALLEY
PHILADELPHIA, PA 19178-7166 SAN DIEGO
SHANGHAI
BOSTON
HOUSTON
November 11, 2022 DALLAS
AUSTIN
LOS ANGELES
BANKUNITED, N.A. TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
NEWARK
LAS VEGAS
CHERRY HILL
LAKE TAHOE
MYANMAR
You can pay this invoice on-line at No Charge!
Avoid the delays and lost mail through the USPS
Eliminate the time and cost of printing and save the postage
Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/)
VATIVORX, LLC, ET AL.
2022-01292
FILE# G6344-00081 INVOICE# 2969087 IRS#
CURRENT INVOICE $15,670.50
Fed Wire Payments: ACH Payments: Overnight Payment address
Lockbox Services 787166
Duane Morris LLP
MAC Y1372-045
401 MARKET STREET
PHILADELPHIA, PA 19106
PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM
D UANE M ORRIS LLP
30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
November 11, 2022
File # G6344-00081 INVOICE# 2969087
AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE
END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS
INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS
WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH
LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED.
D UANE M ORRIS LLP
30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PHILADELPHIA
CHICAGO
WASHINGTON, DC
SAN FRANCISCO
November 11, 2022 SILICON VALLEY
SAN DIEGO
SHANGHAI
BOSTON
BANKUNITED, N.A. HOUSTON
DALLAS
AUSTIN
LOS ANGELES
TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
VATIVORX, LLC, ET AL. NEWARK
2022-01292 LAS VEGAS
CHERRY HILL
LAKE TAHOE
File# G6344-00081 Invoice# 2969087 IRS# MYANMAR
OMAN
FOR PROFESSIONAL SERVICES RECORDED
THROUGH 10/31/2022 IN CONNECTION
WITH THE ABOVE-CAPTIONED MATTER. $15,670.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
November 11, 2022
Page 2
File # G6344-00081 INVOICE# 2969087
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
10/3/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 1.20 $990.00
MCGAHEE AND LUIS LLABERAS;
REVIEW RESPONSE TO
COUNTERPROPOSAL FROM COMPANY;
BRIEF REVIEW OF CREDIT AGREEMENT
10/4/2022 06357 JM PETRAKIS REVIEW DOCUMENTS IN SYNDTRAK 1.40 $1,155.00
AND COMMUNICATIONS WITH CLIENT
10/4/2022 06357 JM PETRAKIS REVIEW EMAIL FROM CARRIGAN RE 2.50 $2,062.50
REGIONS' RECOMMENDATION IN LIGHT
OF COMPANY RESPONSE TO PROPOSAL;
REVIEW MOU SENT BY COMPANY RE
TWRX; ANALYSIS OF SAME AND DRAFT
EMAIL TO BRIAN MCGAHEE RE
QUESTIONS AND CONCERNS; CALL
WITH BRIAN; REVIEW RESPONSES TO
QUESTIONS.
10/5/2022 06357 JM PETRAKIS MULTIPLE AND DAY LONG 1.50 $1,237.50
COMMUNICATIONS WITH CLIENT, LUIS
LLABERAS, AND PATRICK CARRIGAN
RE STRATEGY FOR PROCEEDING WITH
BORROWER; REVIEW CREDIT
AGREEMENT IN CONNECTION WITH
SAME.
10/6/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 1.50 $1,237.50
LENDER CALL; FOLLOW UP
COMMUNICATIONS WTIH CLIENT AND
LUIS LLABERAS.
10/7/2022 06357 JM PETRAKIS REVIEW ACCOUNT DEBTOR NOTICE; 0.40 $330.00
COMMUNICATIONS WITH LUIS
LLABERAS AND CLIENT RE SAME.
10/13/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF LETTER 2.50 $2,062.50
FROM BORROWER TO LENDER GROUP;
INVESTIGATION REGARDING
; INVESTIGATION
RE ; PREPARE FOR AND ATTEND
WEEKLY LENDER CALL;
COMMUNICATIONS WITH BRIAN
MCGAHEE; DRAFT EMAIL TO LUIS
LLABERAS.
10/20/2022 06357 JM PETRAKIS PREPARATION FOR LENDER GROUP 2.70 $2,227.50
CALL; COMMUNICATIONS WITH CLIENT
AND LUIS LLABERAS; ATTEND GROUP
CALL; DRAFT FOLLOW UP EMAIL TO
LUIS LLABERAS.
10/24/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH LUIS 0.50 $412.50
LLABERAS RE STATUS OF THE
FORBEARANCE TERM SHEET AND THE
; FOLLOW UP WITH CLIENT.
10/25/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH LUIS 0.70 $577.50
LLABERAS RE ;
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
November 11, 2022
Page 3
File # G6344-00081 INVOICE# 2969087
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
REVIEW MARK UP OF TERM SHEET;
EMAIL EXCHANGE WITH CLIENT RE
; EMAIL TO LOUISE MELCHOR;
EMIAL EXCHANGE WITH LUIS
LLABERAS RE .
10/27/2022 06357 JM PETRAKIS ANALYSIS OF MVA MEMO RE 0.90 $742.50
COMMUNICATIONS WITH LOUISE
MELCHOR AND CLIENT.
10/31/2022 06357 JM PETRAKIS EMAIL FROM LOUISE MELCHOR RE 0.50 $412.50
RESULTS OF LAST LENDER CALL;
ANALYSIS RE PATH FORWARD.
Subtotal: 16.30 $13,447.50
10/25/2022 06359 L MELCHOR CORRESPONDENCE WITH J. PETRAKIS 1.80 $1,053.00
AND B. MCGAHEE RE STATUS OF
MATTER, UPCOMING CALL WITH
ACCOUNT DEBTOR; REVIEW
FORBEARANCE TERM SHEET MARKUP
AND LOAN DOCUMENTS FILE
10/27/2022 06359 L MELCHOR REVIEW AGENT COUNSEL 1.60 $936.00
MEMORANDUM RE
FOLLOW UP
CORRESPONDENCE WITH AGENT
COUNSEL RE
ATTEND WEEKLY LENDER
STATUS CALL; CORRESPONDENCE
WITH J. PETRAKIS AND CLIENT RE
MATTER STATUS
10/31/2022 06359 L MELCHOR FOLLOW UP WITH J. PETRAKIS RE 0.40 $234.00
THURSDAY STATUS CALL
Subtotal: 3.80 $2,223.00
TOTAL SERVICES 20.10 $15,670.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
November 11, 2022
Page 4
File # G6344-00081 INVOICE# 2969087
VATIVORX, LLC, ET AL.
TIMEKEEPER
NO. NAME CLASS HOURS RATE VALUE
06357 JM PETRAKIS PARTNER 16.30 825.00 $13,447.50
06359 L MELCHOR SPECIAL COUNSEL 3.80 585.00 $2,223.00
20.10 $15,670.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PLEASE REMIT PAYMENT TO: PHILADELPHIA
DUANE MORRIS LLP CHICAGO
ATTN: PAYMENT PROCESSING WASHINGTON, DC
SAN FRANCISCO
PO BOX 787166 SILICON VALLEY
PHILADELPHIA, PA 19178-7166 SAN DIEGO
SHANGHAI
BOSTON
HOUSTON
December 09, 2022 DALLAS
AUSTIN
LOS ANGELES
BANKUNITED, N.A. TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
NEWARK
LAS VEGAS
CHERRY HILL
LAKE TAHOE
MYANMAR
You can pay this invoice on-line!
Avoid the delays and lost mail through the USPS
Use your bank account for free or your credit card (with a merchant fee)
Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/)
VATIVORX, LLC, ET AL.
2022-01292
FILE# G6344-00081 INVOICE# 2979747 IRS#
CURRENT INVOICE $35,765.50
Fed Wire Payments: ACH Payments: Overnight Payment address
Lockbox Services 787166
Duane Morris LLP
MAC Y1372-045
401 MARKET STREET
PHILADELPHIA, PA 19106
D UANE M ORRIS LLP
30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
December 09, 2022
File # G6344-00081 INVOICE# 2979747
PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM
AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE
END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS
INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS
WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH
LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED.
D UANE M ORRIS LLP
30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
FIRM and AFFILIATE OFFICES
NEW YORK
LONDON
SINGAPORE
PHILADELPHIA
CHICAGO
WASHINGTON, DC
SAN FRANCISCO
December 09, 2022 SILICON VALLEY
SAN DIEGO
SHANGHAI
BOSTON
BANKUNITED, N.A. HOUSTON
DALLAS
AUSTIN
LOS ANGELES
TAIWAN
HANOI
HO CHI MINH CITY
ATLANTA
BALTIMORE
WILMINGTON
MIAMI
BOCA RATON
PITTSBURGH
VATIVORX, LLC, ET AL. NEWARK
2022-01292 LAS VEGAS
CHERRY HILL
LAKE TAHOE
File# G6344-00081 Invoice# 2979747 IRS# MYANMAR
OMAN
FOR PROFESSIONAL SERVICES RECORDED
THROUGH 11/30/2022 IN CONNECTION
WITH THE ABOVE-CAPTIONED MATTER. $35,765.50
D UANE M ORRIS LLP
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022
NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024
Duane Morris
December 09, 2022
Page 2
File # G6344-00081 INVOICE# 2979747
VATIVORX, LLC, ET AL.
DATE ID # TIMEKEEPER HOURS VALUE
11/3/2022 06357 JM PETRAKIS REVIEW DOCUMENTS LOADED TO 1.90 $1,567.50
SYNDTRAK; COMMUNICATIONS WITH
COUNSEL FOR REGIONS RE
ACCELERATION AND DEMAND LETTER;
PREPARE FOR AND ATTEND LENDER
CALL.
11/10/2022 06357 JM PETRAKIS RECEIVED AND ANALYZED DRAFT OF 1.80 $1,485.00
COMPLAINT; MADE NOTES RE
COMMENTS AND QUESTIONS; PREPARE
FOR AND ATTEND WEEKLY LENDER
CALL; POST CALL FOLLOW UP
COMMUNICATIONS WITH LUIS
LLABERAS.
11/10/2022 06357 JM PETRAKIS INITIAL RESEARCH RE 0.50 $412.50
DRAFT ASSIGNMENT
FOR ASSOCIATE FOR FOLLOW UP.
11/11/2022 06357 JM PETRAKIS ANALYSIS RE FRAUD AND BREACH OF 1.40 $1,155.00
CONTRACT CLAIMS;
COMMUNICATIONS WITH LUIS
LLABERAS AND JIM MANNING;
ANALYSIS RE
AND INTIAL RESEARCH; DRAFT
MEMO FOR FOLLOW UP RESEARCH
NEEDED BY ASSOCIATE
11/14/2022 06357 JM PETRAKIS ANALYSIS OF 1.30 $1,072.50
SSOCIATED WITH INCLUSION
OF TORT (FRAUD) CLAIMS IN REGIONS'
BANK'S COMPLAINT DRAFT;
COMMUNICATIONS WITH ANNE
GRUNER RE RESEARCH MEMO NEEDED.
11/14/2022 06357 JM PETRAKIS REVIEW OF COMMON INTEREST 1.60 $1,320.00
AGREEMENT AND ASSESSED
REVISIONS NEEDED; EMAIL TO CLIENTS
RE SAME; EMAIL TO LUIS LLABERAS.
11/14/2022 06357 JM PETRAKIS PREPARE FOR AND CONDUCT CALL 1.70 $1,402.50
WITH REGIONS COUNSEL RE
COMMENTS TO COMPLAINT AND
; PREPARE REPORT WITH
RECOMMENDATIONS TO CLIENT.
11/15/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 0.50 $412.50
MCGAHEE RE COMMON INTEREST
AGREEMENT; FOLLOW UP WITH LUIS
LLABERAS; ASSESSED NEED FOR
LOCAL COUNSEL IN NY OFICE.
Preview
FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Exhibit A [Duane Morris Invoices] FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PLEASE REMIT PAYMENT TO: PHILADELPHIA DUANE MORRIS LLP CHICAGO ATTN: PAYMENT PROCESSING WASHINGTON, DC SAN FRANCISCO PO BOX 787166 SILICON VALLEY PHILADELPHIA, PA 19178-7166 SAN DIEGO SHANGHAI BOSTON HOUSTON October 18, 2022 DALLAS AUSTIN LOS ANGELES BANKUNITED, N.A. TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH NEWARK LAS VEGAS CHERRY HILL LAKE TAHOE MYANMAR You can pay this invoice on-line at No Charge! Avoid the delays and lost mail through the USPS Eliminate the time and cost of printing and save the postage Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/) VATIVORX, LLC, ET AL. FILE# G6344-00081 INVOICE# 2959510 IRS# CURRENT INVOICE $31,597.50 Fed Wire Payments: ACH Payments: Overnight Payment address Lockbox Services 787166 Duane Morris LLP MAC Y1372-045 401 MARKET STREET PHILADELPHIA, PA 19106 PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED. D UANE M ORRIS LLP 30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PHILADELPHIA CHICAGO WASHINGTON, DC SAN FRANCISCO October 18, 2022 SILICON VALLEY SAN DIEGO SHANGHAI BOSTON BANKUNITED, N.A. HOUSTON DALLAS AUSTIN LOS ANGELES TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH VATIVORX, LLC, ET AL. NEWARK LAS VEGAS CHERRY HILL File# G6344-00081 Invoice# 2959510 IRS# LAKE TAHOE MYANMAR FOR PROFESSIONAL SERVICES RECORDED OMAN THROUGH 09/30/2022 IN CONNECTION WITH THE ABOVE-CAPTIONED MATTER. $31,597.50 TOTAL BALANCE DUE $31,597.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris October 18, 2022 Page 2 File # G6344-00081 INVOICE# 2959510 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE 9/1/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH BRIAN 0.00 $0.00 MCGAHEE RE NEW WORKOUT MATTER. 9/2/2022 06357 JM PETRAKIS RECEIVED DEAL DOCUMENTS FROM 1.20 $990.00 BRIAN MCGAHEE AND COMMUNICATIONS RE SAME; INITIAL REVIEW TO VERIFY WHAT RECEIVED AND WHAT ADDITIONAL INFORMATION AND DOCUMENTS ARE NEEDED. 9/8/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF ALL DEAL 4.70 $3,877.50 DOCUMENTS, COLLATERAL, AND LIST OF QUESTIONS AND CONCERNS PROVIDED BY BANKUNITED; PREPARED INTERNAL MEMO RE SAME; EMAIL COMMUNICATIONS WITH BRIAN MCGAHEE 9/8/2022 06357 JM PETRAKIS REVIEW AURORA ENGAGEMENT 0.40 $330.00 LETTER. . 9/8/2022 06357 JM PETRAKIS DRAFT LETTER TO LUIS LLUBERAS, 1.50 $1,237.50 COUNSEL FOR REGIONS REGARDING MULTIPLE ISSUES AND CONCERNS THAT BANK UNITED HAS ABOUT 9/9/2022 06357 JM PETRAKIS FOLLOW UP COMMUNICATIONS WITH 3.40 $2,805.00 BRIAN MCGAHEE AND BARRY BELDIN RE DRAFT EMAIL TO LUIS LLUBERAS RE SAME; REVIEW EMAIL FROM BRIAN MCGAHEE TO PATRICK CARRIGAN. 9/9/2022 06357 JM PETRAKIS FOLLOW UP COMMUNICATIONS WITH 0.90 $742.50 CLIENT RE INVESTIGATION RE SAME. 9/12/2022 06357 JM PETRAKIS RECEIVE AND REVIEW ADDITIONAL 2.80 $2,310.00 DOCUMENTS FROM CLIENT; REVIEW LUIS LLABERAS' RESPONSES TO OUR INQUIRIES IN EMAIL FROM 9/9 AND DISCUSS WITH CLIENT; CONFERENCE CALL WITH BARRY BELDIN AND BRIAN MCGAHEE; REVIEW DRAFT OF EMAIL PREPARED BY BRIAN MCGAHEE TO REGIONS AND FOLLOW UP RE SAME. . 9/12/2022 06357 JM PETRAKIS REVIEWED EMAIL FRO LUIS LLABERAS 0.90 $742.50 WITH REVISED TERM SHEET; ADDITIONAL COMMUNICATIONS WITH BARRY BELDIN AND BRIAN MCGAHEE RE D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris October 18, 2022 Page 3 File # G6344-00081 INVOICE# 2959510 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE 9/13/2022 06357 JM PETRAKIS RECEIVE AND REVIEW DRAFTS OF 2.70 $2,227.50 FORBEARANCE TERM SHEETS AND COMMUNICATIONS WITH CLIENT RE SAME; DRAFT LIST OF COMMENTS AND QUESTIONS; COMMUNICATIONS WITH CLIENTS ABOUT CALL WITH REGIONS. 9/13/2022 06357 JM PETRAKIS CALL WITH REGIONS COUNSEL; AND 0.50 $412.50 PREPARE MEMO RE SAME. 9/14/2022 06357 JM PETRAKIS EMAIL COMMUNICATIONS WITH 0.40 $330.00 CLIENTS RE TERM SHEET ISSUES. 9/15/2022 06357 JM PETRAKIS REVIEW LATEST DRAFT OF 2.40 $1,980.00 FORBEARANCE TERM SHEET; DISCUSS WITH CLIENTS; PREPARE FOR AND ATTEND CALL WITH REGIONS BANK, PARTICIPANT LENDERS, AND COUNSEL; FOLLOW UP RE ADDITIONAL REVISIONS TO TERM SHEET TO ADDRESS . 9/15/2022 06357 JM PETRAKIS REVIEW LATEST DOCUMENTS 1.20 $990.00 UPLOADED TO DATA ROOM; FOLLOW UP WITH CLIENT. 9/19/2022 06357 JM PETRAKIS REVIEW LATEST TURN OF 1.10 $907.50 FORBEARANCE TERMS SHEET; COMMUNICATIONS WITH CLIENT RE SAME AND OPEN ISSUES; EMAIL EXCHANGE WITH LUIS LLABERAS. 9/19/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH BARRY 0.50 $412.50 BELDIN RE . 9/20/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF LATEST 2.30 $1,897.50 DRAFT OF FORBEARANCE AGREEMENT; COMMUNICATIONS WITH CLIENT RE SAME; DRAFT EMAIL TO LUIS LLABERAS WITH QUESTIONS AND COMMENTS; REVIEW RESPONSE AND DISCUSS WITH CLIENTS. 9/21/2022 06357 JM PETRAKIS COMMUNICATIONS WITH CLIENT RE 0.40 $330.00 FORBEARANCE AGREEMENT, REMAINING CONCERNS, AND TIMING. 9/21/2022 06357 JM PETRAKIS REVIEW DOCUMENT REQUEST LIST 1.70 $1,402.50 UPDATE AND COMMUNICATIONS WITH CLIENTS RE SAME AND OTHER ISSUES OF CONCERN; ANALYSIS OF PERTINENT CREDIT AGREEMENT TERMS IN CONNECTION WITH 9/22/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 2.00 $1,650.00 LENDER GROUP CALL; EMAIL AND PHONE COMMUNICATIONS WITH CLIENTS RE SAME AND ISSUES ARISING THEREFROM; ANALYSIS RE ACCOUNT D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris October 18, 2022 Page 4 File # G6344-00081 INVOICE# 2959510 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE DEBTOR LETTERS USE AND TIMING; ANALYSIS OF REMEDIES. 9/23/2022 06357 JM PETRAKIS REVIEW BANKUNITED'S CONSENT TO 0.50 $412.50 ACCELRATION AND EXERCISE OF REMEDIES; COMMUNICATIONS RE SAME; 9/26/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 0.30 $247.50 MCGAHEE; 9/27/2022 06357 JM PETRAKIS REVIEW LETTER FROM BORROWER 1.80 $1,485.00 COUNSEL IN RESPONSE TO ACCELERATION OF LOAN; DISCUSS WITH CLIENTS; COMMUNICATIONS WITH REGIONS COUNSEL; REVIEW CORRESPONDENCE FROM CLIENT RE ANALYSIS OF CREDIT AGREEMENT AND DRAFT LETTER TO LUIS LLABERAS . 9/28/2022 06357 JM PETRAKIS CREDIT AGREEMENT ANALYSIS IN 2.00 $1,650.00 RESPONSE TO CLIENT INQUIRIES; COMMUNICATIONS WITH CLIENT RE SAME; INVESTIGATION RE 9/29/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 1.50 $1,237.50 LENDER CALL; FOLLOW UP WITH BRIAN MCGAHEE; COMMUNICATIONS WITH LUIS LLABERAS. 9/30/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS RE LETTER 0.80 $660.00 FROM BORROWER WITH PROPOSAL; PREPARE FOR AND CONDUCT CALL WITH CLIENT RE SAME. 9/30/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF PROPOSED 0.40 $330.00 RESPONSE TO BORROWER LETTER;CALL TO BRIAN MCGAHEE RE SAME Subtotal: 38.30 $31,597.50 TOTAL SERVICES 38.30 $31,597.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris October 18, 2022 Page 5 File # G6344-00081 INVOICE# 2959510 VATIVORX, LLC, ET AL. TIMEKEEPER NO. NAME CLASS HOURS RATE VALUE 06357 JM PETRAKIS PARTNER 38.30 825.00 $31,597.50 38.30 $31,597.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PLEASE REMIT PAYMENT TO: PHILADELPHIA DUANE MORRIS LLP CHICAGO ATTN: PAYMENT PROCESSING WASHINGTON, DC SAN FRANCISCO PO BOX 787166 SILICON VALLEY PHILADELPHIA, PA 19178-7166 SAN DIEGO SHANGHAI BOSTON HOUSTON November 11, 2022 DALLAS AUSTIN LOS ANGELES BANKUNITED, N.A. TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH NEWARK LAS VEGAS CHERRY HILL LAKE TAHOE MYANMAR You can pay this invoice on-line at No Charge! Avoid the delays and lost mail through the USPS Eliminate the time and cost of printing and save the postage Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/) VATIVORX, LLC, ET AL. 2022-01292 FILE# G6344-00081 INVOICE# 2969087 IRS# CURRENT INVOICE $15,670.50 Fed Wire Payments: ACH Payments: Overnight Payment address Lockbox Services 787166 Duane Morris LLP MAC Y1372-045 401 MARKET STREET PHILADELPHIA, PA 19106 PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM D UANE M ORRIS LLP 30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris November 11, 2022 File # G6344-00081 INVOICE# 2969087 AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED. D UANE M ORRIS LLP 30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PHILADELPHIA CHICAGO WASHINGTON, DC SAN FRANCISCO November 11, 2022 SILICON VALLEY SAN DIEGO SHANGHAI BOSTON BANKUNITED, N.A. HOUSTON DALLAS AUSTIN LOS ANGELES TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH VATIVORX, LLC, ET AL. NEWARK 2022-01292 LAS VEGAS CHERRY HILL LAKE TAHOE File# G6344-00081 Invoice# 2969087 IRS# MYANMAR OMAN FOR PROFESSIONAL SERVICES RECORDED THROUGH 10/31/2022 IN CONNECTION WITH THE ABOVE-CAPTIONED MATTER. $15,670.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris November 11, 2022 Page 2 File # G6344-00081 INVOICE# 2969087 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE 10/3/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 1.20 $990.00 MCGAHEE AND LUIS LLABERAS; REVIEW RESPONSE TO COUNTERPROPOSAL FROM COMPANY; BRIEF REVIEW OF CREDIT AGREEMENT 10/4/2022 06357 JM PETRAKIS REVIEW DOCUMENTS IN SYNDTRAK 1.40 $1,155.00 AND COMMUNICATIONS WITH CLIENT 10/4/2022 06357 JM PETRAKIS REVIEW EMAIL FROM CARRIGAN RE 2.50 $2,062.50 REGIONS' RECOMMENDATION IN LIGHT OF COMPANY RESPONSE TO PROPOSAL; REVIEW MOU SENT BY COMPANY RE TWRX; ANALYSIS OF SAME AND DRAFT EMAIL TO BRIAN MCGAHEE RE QUESTIONS AND CONCERNS; CALL WITH BRIAN; REVIEW RESPONSES TO QUESTIONS. 10/5/2022 06357 JM PETRAKIS MULTIPLE AND DAY LONG 1.50 $1,237.50 COMMUNICATIONS WITH CLIENT, LUIS LLABERAS, AND PATRICK CARRIGAN RE STRATEGY FOR PROCEEDING WITH BORROWER; REVIEW CREDIT AGREEMENT IN CONNECTION WITH SAME. 10/6/2022 06357 JM PETRAKIS PREPARE FOR AND ATTEND WEEKLY 1.50 $1,237.50 LENDER CALL; FOLLOW UP COMMUNICATIONS WTIH CLIENT AND LUIS LLABERAS. 10/7/2022 06357 JM PETRAKIS REVIEW ACCOUNT DEBTOR NOTICE; 0.40 $330.00 COMMUNICATIONS WITH LUIS LLABERAS AND CLIENT RE SAME. 10/13/2022 06357 JM PETRAKIS REVIEW AND ANALYSIS OF LETTER 2.50 $2,062.50 FROM BORROWER TO LENDER GROUP; INVESTIGATION REGARDING ; INVESTIGATION RE ; PREPARE FOR AND ATTEND WEEKLY LENDER CALL; COMMUNICATIONS WITH BRIAN MCGAHEE; DRAFT EMAIL TO LUIS LLABERAS. 10/20/2022 06357 JM PETRAKIS PREPARATION FOR LENDER GROUP 2.70 $2,227.50 CALL; COMMUNICATIONS WITH CLIENT AND LUIS LLABERAS; ATTEND GROUP CALL; DRAFT FOLLOW UP EMAIL TO LUIS LLABERAS. 10/24/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH LUIS 0.50 $412.50 LLABERAS RE STATUS OF THE FORBEARANCE TERM SHEET AND THE ; FOLLOW UP WITH CLIENT. 10/25/2022 06357 JM PETRAKIS EMAIL EXCHANGE WITH LUIS 0.70 $577.50 LLABERAS RE ; D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris November 11, 2022 Page 3 File # G6344-00081 INVOICE# 2969087 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE REVIEW MARK UP OF TERM SHEET; EMAIL EXCHANGE WITH CLIENT RE ; EMAIL TO LOUISE MELCHOR; EMIAL EXCHANGE WITH LUIS LLABERAS RE . 10/27/2022 06357 JM PETRAKIS ANALYSIS OF MVA MEMO RE 0.90 $742.50 COMMUNICATIONS WITH LOUISE MELCHOR AND CLIENT. 10/31/2022 06357 JM PETRAKIS EMAIL FROM LOUISE MELCHOR RE 0.50 $412.50 RESULTS OF LAST LENDER CALL; ANALYSIS RE PATH FORWARD. Subtotal: 16.30 $13,447.50 10/25/2022 06359 L MELCHOR CORRESPONDENCE WITH J. PETRAKIS 1.80 $1,053.00 AND B. MCGAHEE RE STATUS OF MATTER, UPCOMING CALL WITH ACCOUNT DEBTOR; REVIEW FORBEARANCE TERM SHEET MARKUP AND LOAN DOCUMENTS FILE 10/27/2022 06359 L MELCHOR REVIEW AGENT COUNSEL 1.60 $936.00 MEMORANDUM RE FOLLOW UP CORRESPONDENCE WITH AGENT COUNSEL RE ATTEND WEEKLY LENDER STATUS CALL; CORRESPONDENCE WITH J. PETRAKIS AND CLIENT RE MATTER STATUS 10/31/2022 06359 L MELCHOR FOLLOW UP WITH J. PETRAKIS RE 0.40 $234.00 THURSDAY STATUS CALL Subtotal: 3.80 $2,223.00 TOTAL SERVICES 20.10 $15,670.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris November 11, 2022 Page 4 File # G6344-00081 INVOICE# 2969087 VATIVORX, LLC, ET AL. TIMEKEEPER NO. NAME CLASS HOURS RATE VALUE 06357 JM PETRAKIS PARTNER 16.30 825.00 $13,447.50 06359 L MELCHOR SPECIAL COUNSEL 3.80 585.00 $2,223.00 20.10 $15,670.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PLEASE REMIT PAYMENT TO: PHILADELPHIA DUANE MORRIS LLP CHICAGO ATTN: PAYMENT PROCESSING WASHINGTON, DC SAN FRANCISCO PO BOX 787166 SILICON VALLEY PHILADELPHIA, PA 19178-7166 SAN DIEGO SHANGHAI BOSTON HOUSTON December 09, 2022 DALLAS AUSTIN LOS ANGELES BANKUNITED, N.A. TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH NEWARK LAS VEGAS CHERRY HILL LAKE TAHOE MYANMAR You can pay this invoice on-line! Avoid the delays and lost mail through the USPS Use your bank account for free or your credit card (with a merchant fee) Visit our website (https://www.e-billexpress.com/ebpp/duanemorrisa/) VATIVORX, LLC, ET AL. 2022-01292 FILE# G6344-00081 INVOICE# 2979747 IRS# CURRENT INVOICE $35,765.50 Fed Wire Payments: ACH Payments: Overnight Payment address Lockbox Services 787166 Duane Morris LLP MAC Y1372-045 401 MARKET STREET PHILADELPHIA, PA 19106 D UANE M ORRIS LLP 30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris December 09, 2022 File # G6344-00081 INVOICE# 2979747 PAYMENT ADVICES MAY BE EMAILED TO: ACCOUNTSRECEIVABLE@DUANEMORRIS.COM AMOUNTS INCLUDED FOR DISBURSEMENTS INCLUDE EXPENSES RECEIVED AND RECORDED THROUGH THE END OF THE INVOICE PERIOD. THERE MAY BE ADDITIONAL EXPENSES RECEIVED AND DISBURSEMENTS INVOICED IN THE FUTURE. AS PER THE TERMS OF OUR ENGAGEMENT, PAYMENT IS DUE IN U.S. DOLLARS WITHIN 30 DAYS OF THE DATE OF THIS INVOICE. AFTER 30 DAYS A LATE FEE OF 1% PER MONTH (OR SUCH LOWER RATE AS REQUIRED BY APPLICABLE LAW) MAY BE CHARGED. D UANE M ORRIS LLP 30 SOUTH 17TH STREET PHILADELPHIA, PA 19103-4196 PHONE: 215.979.1000 FAX: 215.979.1020 FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 FIRM and AFFILIATE OFFICES NEW YORK LONDON SINGAPORE PHILADELPHIA CHICAGO WASHINGTON, DC SAN FRANCISCO December 09, 2022 SILICON VALLEY SAN DIEGO SHANGHAI BOSTON BANKUNITED, N.A. HOUSTON DALLAS AUSTIN LOS ANGELES TAIWAN HANOI HO CHI MINH CITY ATLANTA BALTIMORE WILMINGTON MIAMI BOCA RATON PITTSBURGH VATIVORX, LLC, ET AL. NEWARK 2022-01292 LAS VEGAS CHERRY HILL LAKE TAHOE File# G6344-00081 Invoice# 2979747 IRS# MYANMAR OMAN FOR PROFESSIONAL SERVICES RECORDED THROUGH 11/30/2022 IN CONNECTION WITH THE ABOVE-CAPTIONED MATTER. $35,765.50 D UANE M ORRIS LLP FILED: NEW YORK COUNTY CLERK 04/12/2024 07:00 PM INDEX NO. 654741/2022 NYSCEF DOC. NO. 318 RECEIVED NYSCEF: 04/12/2024 Duane Morris December 09, 2022 Page 2 File # G6344-00081 INVOICE# 2979747 VATIVORX, LLC, ET AL. DATE ID # TIMEKEEPER HOURS VALUE 11/3/2022 06357 JM PETRAKIS REVIEW DOCUMENTS LOADED TO 1.90 $1,567.50 SYNDTRAK; COMMUNICATIONS WITH COUNSEL FOR REGIONS RE ACCELERATION AND DEMAND LETTER; PREPARE FOR AND ATTEND LENDER CALL. 11/10/2022 06357 JM PETRAKIS RECEIVED AND ANALYZED DRAFT OF 1.80 $1,485.00 COMPLAINT; MADE NOTES RE COMMENTS AND QUESTIONS; PREPARE FOR AND ATTEND WEEKLY LENDER CALL; POST CALL FOLLOW UP COMMUNICATIONS WITH LUIS LLABERAS. 11/10/2022 06357 JM PETRAKIS INITIAL RESEARCH RE 0.50 $412.50 DRAFT ASSIGNMENT FOR ASSOCIATE FOR FOLLOW UP. 11/11/2022 06357 JM PETRAKIS ANALYSIS RE FRAUD AND BREACH OF 1.40 $1,155.00 CONTRACT CLAIMS; COMMUNICATIONS WITH LUIS LLABERAS AND JIM MANNING; ANALYSIS RE AND INTIAL RESEARCH; DRAFT MEMO FOR FOLLOW UP RESEARCH NEEDED BY ASSOCIATE 11/14/2022 06357 JM PETRAKIS ANALYSIS OF 1.30 $1,072.50 SSOCIATED WITH INCLUSION OF TORT (FRAUD) CLAIMS IN REGIONS' BANK'S COMPLAINT DRAFT; COMMUNICATIONS WITH ANNE GRUNER RE RESEARCH MEMO NEEDED. 11/14/2022 06357 JM PETRAKIS REVIEW OF COMMON INTEREST 1.60 $1,320.00 AGREEMENT AND ASSESSED REVISIONS NEEDED; EMAIL TO CLIENTS RE SAME; EMAIL TO LUIS LLABERAS. 11/14/2022 06357 JM PETRAKIS PREPARE FOR AND CONDUCT CALL 1.70 $1,402.50 WITH REGIONS COUNSEL RE COMMENTS TO COMPLAINT AND ; PREPARE REPORT WITH RECOMMENDATIONS TO CLIENT. 11/15/2022 06357 JM PETRAKIS COMMUNICATIONS WITH BRIAN 0.50 $412.50 MCGAHEE RE COMMON INTEREST AGREEMENT; FOLLOW UP WITH LUIS LLABERAS; ASSESSED NEED FOR LOCAL COUNSEL IN NY OFICE.