On November 02, 2016 a
Exhibit,Appendix
was filed
involving a dispute between
Chin Chung Lu,
Li Hua Lu,
Lu Holding Llc,
Wen Mei Lu,
and
Wen Fu Lu,
Wen Ying Gamba,
Yuen Hsiang Lu,
for Commercial - Other (Constructive Trust)
in the District Court of Saratoga County.
Preview
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
10/21/2020 Receive and review application for rerouting from 0.5
contractor; copy, add check for fee; hand-deliver to 150.00
City Hall. Advise parties.
10/26/2020 Work on Order to show cause - walls, etc. 1 300.00
10/28/2020 Pay motion fee for order to show cause to repair 0.2
60.00
walls, etc.
10/28/2020 Draft letter to clerk with order to show cause. 0.2 60.00
10/28/2020 pay insurance for 175 S Broadway 0.2 60.00
11/2/2020 Respond to Duo's inquiry about status of repair to 0.2
60.00
external walls.
11/2/2020 Draft letter to Utica First Insurance Company 0.4
regarding the requested repairs to 175 South 120.00
Broadway.
11/4/2020 Receive signed OTSC; diary; serve upon the 0.3
90.00
attorneys.
11/4/2020 Receive e-mail and photographs from GMC 0.2
60.00
requesting another $6,200 for new plywood.
11/4/2020 Draft letter to Judge Nolan requesting authority to 0.6
180.00
spend $6,200 to replace the plywood.
11/5/2020 Receive attorney Brennan's consent to buy the wood; 0.2
60.00
integrate into folder.
11/5/2020 Receive and review attorney Freund's motion to name 0.5
myself as party defendant in PI case. Review cited 150.00
statutes.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 1
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
11/5/2020 Check insurance policy for Duo's; draft letter to agent 0.5
150.00
requesting representation.
11/5/2020 Check errors & omissions insurance folder; draft 0.5
150.00
letter to agent to place carrier on notice.
11/5/2020 Draft and efile letter to Judge Nolan requesting a one 0.5
month adjournment to give time to carrier to respond 150.00
to motion.
11/5/2020 Call and e-mail Jon Crain to request his consent to 0.2
60.00
payment for the plywood.
11/5/2020 e-mail to court clerk to expedite permission to spend 0.2
60.00
the $6,200.
11/6/2020 Receive letter order allowing the expenditure of 0.2
60.00
$6,200; integrate into folder.
11/6/2020 Cut check @ $6,200. 0.2 60.00
11/6/2020 e-mail and phone call to GMC to arrange for pick up 0.2
60.00
of check.
11/11/2020 Numerous emails, letters & tel conf relative to 3
motion to name me as party defendant in the Kings 900.00
County PI case.
11/13/2020 Receive rent for 3310 South Broadway. 0.2 60.00
11/13/2020 Tel conf with Tim Brennan about posture of the case. 0.2 60.00
11/13/2020 Receive coverage letter from Hanover; review and 0.4
120.00
integrate into folder.
11/13/2020 Review Nolan's 2016 Decision and the resulting 0.5
150.00
Appellate Division Decision.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 2
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
11/13/2020 Tel conf with attorney Jon Crain. 0.4 120.00
11/13/2020 Receive and review the complaint in the instant 0.5
action, with special focus on cause of action to 150.00
challenge the deeds.
11/13/2020 Draft long letter to NY Mutual regarding its 0.8
240.00
disclaimer of coverage.
11/13/2020 Draft letter to Duo's asking if they made a claim for 0.4
120.00
"business interruption".
11/18/2020 Receive and record rent for 175 So Broadway 0.2 60.00
11/18/2020 Follow up with City Hall to see about status of 0.2
60.00
re-roofing permit and any required inspection.
11/18/2020 Ask Duo's for confirmation that the roof repair is 0.2
complete and that the rain is not leaking into the 60.00
restaurant.
11/19/2020 Tel conf with Paul Waterfield of NY Mutual 0.4
120.00
Insurance Company re PI litigation.
11/19/2020 Report to malpractice carrier the tel conf with Paul 0.3
90.00
Waterfield.
11/19/2020 Contact attorney for defendants in title litigation. 0.2 60.00
11/20/2020 Tel conf with Hanover attorney and assigned counsel. 0.5
Discuss status of motion to name receiver as party 150.00
defendant in Kings County PI case.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 3
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
11/21/2020 Receive and review papers in opposition to, and in 0.5
support of, motion to repair the walls. Integrate into
150.00
folder. Reach out to Duo's regarding business
interruption insurance.
11/21/2020 Receive building permit from Building Department 0.2
for the re-roofing of 175 South Broadway. Review 60.00
and integrate into folder.
11/21/2020 e-mail to Building Department to ask about 0.1
30.00
inspections and CO.
11/21/2020 Receive e-mail from Duo's raising a question of 0.1
30.00
"stinky gutters".
11/21/2020 Respond to Duo's request for payment; ask about 0.2
60.00
inspections.
11/23/2020 Receive confirmation from Building Department that 0.2
they do not need to inspect the new roof at 175 South 60.00
Broadway.
11/23/2020 Cut check for final payment to GMC Construction 0.2
for roof replacement at 175 South Broadway. Notify 60.00
contractor.
11/24/2020 Long explanatory letter to Zongrone Agency 1.5
directing them to name both LLCs on the insurance
450.00
policies. Forward to litigants' attorneys for
comments.
11/24/2020 Put letter to Zongrone agency in final form; add 0.3
90.00
attachments and send.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 4
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
11/24/2020 Correspond with insurance agency about correct 0.3
90.00
spelling of Lu Holding LLC.
11/24/2020 Emails with both parties attorneys and again with 0.4
Duo's about business interruption insurance. Locate
120.00
and review old policy of Duo's - note that it does
contain coverage; provide to Duo's with explanation.
11/25/2020 Pay insurance for 3310 South Broadway. 0.2 60.00
11/25/2020 Pay insurance for 175 South Broadway. 0.2 60.00
11/27/2020 Receive, review responsive affirmation from attorney 0.2
Brennan in opposition to relief requested by plaintiff. 60.00
Integrate into folder.
11/27/2020 Receive coverage letter from NY Mutual and forward 0.2
60.00
to attorneys.
11/30/2020 Pay property tax for 3 parcels. 0.6 180.00
11/30/2020 Receive and review e-mail from Paul Waterfield to 0.2
Preferred Mutual Insurance. Integrate into folder; 60.00
forward to attorneys Ferris and Flanagan.
11/30/2020 Correspond with attorney Brian Casey. 0.2 60.00
12/1/2020 Telephone conference with attorneys from Hanover 0.8
and NY Mutual to discuss the motion to name me as 240.00
defendant.
12/2/2020 Receive and review long letter from attorney 0.3
90.00
Flanagan.
12/2/2020 e-mail with attorney Flanagan. 0.1 30.00
12/4/2020 Receive and deposit rent for 175 South Broadway. 0.2 60.00
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 5
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
12/4/2020 Receive and review attorney Flanagan's long letter 0.4
120.00
about motion to name me as defendant.
12/10/2020 Receive and review Judge Nolan's order allowing for 0.5
the repair of the exterior walls of 175 South
Broadway. Integrate into folder. Notify tenant. 150.00
Contact attorneys to see if they wish to submit
estimates.
12/11/2020 Receive notice of re-assignment of case to judge 0.1
30.00
Walsh.
12/11/2020 Emails from attorneys about gathering estimates for 0.2
60.00
wall repairs, etc.
12/14/2020 Review affirmation of attorney Brian Casey. 0.4 120.00
12/14/2020 Tel conf with attorney Matthew Flanagan. 0.2 60.00
12/14/2020 Receive & deposit rent from 3310 South Broadway. 0.2 60.00
12/15/2020 Receive and review attorney Flanagan's 0.3
90.00
correspondence to Traveller's and Preferred Mutual.
12/15/2020 Balance five monthly statements. 0.5 150.00
12/15/2020 Confer with attorneys re inspection of the boiler. 0.2 60.00
12/15/2020 Confer with attorneys re paragraph 35 of lease and 0.3
90.00
boiler inspection.
12/15/2020 Receive and review draft affidavit of attorney Casey. 0.5 150.00
12/16/2020 Receive affidavit from attorney Casey; review same; 0.4
120.00
respond to his e-mail.
12/17/2020 Telephone conf with attorney Flanagan. 0.2 60.00
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 6
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
12/17/2020 Receive and review new affidavit from attorney 0.2
60.00
Casey.
12/20/2020 Went to Duo's, observed the sewer smell; discussed 0.5
150.00
with staff and Iris.
12/21/2020 Receive detailed e-mail from Iris re: odor, integrate 0.5
150.00
into folder, forward to attorneys.
12/21/2020 Contact roofing contractor to return to site. (GMC) 0.2 60.00
12/21/2020 Send e-mail to independent contractor for second 0.2
60.00
opinion.
12/22/2020 Correspond with attorneys re odor and the roofing 0.2
60.00
contractor.
12/24/2020 Receive opposition papers of attorney Freund; review 0.5
150.00
same and respond to attorney Casey.
12/24/2020 Emails with Duo about remediation efforts. 0.3 90.00
12/24/2020 Call contractor Billy Morris; leave message. 0.2 60.00
12/29/2020 Tel conf with Paul Waterfield; e-mail to him a COI. 0.2 60.00
12/29/2020 Tel conf with contractor Billy Morris about the sewer 0.2
60.00
odor.
12/30/2020 e-mail to attorneys and Duo's about the sewer odor. 0.2 60.00
1/4/2021 Pay insurance for 175 S. Broadway 0.2 60.00
1/5/2021 Multiple emails on 12-30 re odors and contractors. 0.4 120.00
1/5/2021 Review long e-mail from Tim Brennan; his view is 0.2
that the odor must be resolved at the expense of the 60.00
tenant. Reply; request city code section.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 7
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
1/5/2021 Long e-mail to Duo's to explain to them how to 0.4
120.00
proceed with fixing the sewer odor.
1/27/2021 Receive and amend and deposit rent check for 3310 0.2
60.00
South Broadway.
1/28/2021 Pay insurance for 175 South Broadway 0.2 60.00
1/28/2021 Pay school taxes on three parcels. 0.6 180.00
2/2/2021 Schedule video conference. 0.2 60.00
2/2/2021 e-mail correspondence re Duo's business interruption 0.2
60.00
insurance.
2/2/2021 Remind the attorneys that the CD does not bear 0.2
interest; we need the names of the beneficial owners 60.00
in order to do so.
2/2/2021 e-mail correspondence with attorneys about the need 0.2
for estimates to repair the exterior walls of 175 south 60.00
Broadway.
2/2/2021 Call to Saratoga National to request the form - 0.2
60.00
Certification of Beneficial Owners
2/2/2021 Look for court order regarding validity of deeds. 0.2 60.00
2/2/2021 Look for deeds to establish chain of title. 0.5 150.00
2/2/2021 Long e-mail to attorneys to request copies of deeds 0.4
and to point out the discrepancy in names between 120.00
the court order and the actual deeds.
2/2/2021 Correspondence with the court about the status of the 0.2
PI case in King's County and the motion to add me as 60.00
party defendant.
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 8
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 Due on receipt
Service Date Professional Services Time Amount
2/3/2021 Confer with malpractice attorney on motion. 0.2 60.00
2/3/2021 Order deeds from Clerk's office. 0.2 60.00
2/3/2021 Receive and review two deeds from Clerk's Office. 0.2
60.00
Note there was a typo in Judge Nolan's Decision.
2/4/2021 Call to Saratoga Bank officer, leave detailed 0.2
60.00
message.
2/4/2021 Review Certification of Benefic Ownership; forward 0.3
90.00
to attorney Brennan.
2/4/2021 Correspondence with bank officer regarding my 0.5
appointment as receiver, and an explanation of how
150.00
title is in Chuen Lou, LLC. Provide court orders with
explanation.
2/5/2021 Receive rent for 175 South Broadway 0.2 60.00
2/8/2021 Correspondence with Saratoga National Bank re: 0.3
90.00
documentation.
2/8/2021 More correspondence with Saratoga National Bank 0.2
60.00
and Tim about documentation for Chuen Lou, LLC
2/11/2021 Pay property tax bills for three properties. 0.6 180.00
2/12/2021 Balance checking account per December statement 0.3 90.00
2/12/2021 Balance checking account per January statement 0.2 60.00
2/17/2021 e-mail with bank; send reminder to attorney Brennan 0.2
for documentation to help put money in interest 60.00
bearing account.
2/20/2021 Pay insurance on both properties. 0.4 120.00
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total
Page 9
FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946
NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021
The Law Office of David A Harper, P.C. Invoice
480 Broadway - Suite 211
Saratoga Springs, NY 12866
518-587-6670 pclute@davidharperlaw.com
Bill To
Lu vs. Lu
Invoice # Date Total Due Terms Enclosed
18131 4/16/2021 $12,510.00 Due on receipt
Service Date Professional Services Time Amount
2/24/2021 Contact insurance agent to change the name of the 0.2
60.00
insured owner to Chuen Lou, LLC.
2/26/2021 Emails about the alleged "boiler". 0.2 60.00
2/26/2021 Long tel conf with Paul Waterfield. 0.4 120.00
3/2/2021 Receive rent for 3310 South Broadway. 0.2 60.00
3/2/2021 Balance per bank statement as of 02-15-21. 0.2 60.00
3/2/2021 Receive e-mail with estimate to replace the stucco 0.2
walls. Integrate into folder - ask attorney Crain if he 60.00
intends to submit an estimate.
3/2/2021 Emails regarding changing the name of the insured 0.2
60.00
owner.
3/10/2021 Attend video conference with Judge Walsh. 0.4 120.00
3/10/2021 Receive and deposit rent for 175 South Broadway 0.2 60.00
3/29/2021 Pay insurance for 175 South Broadway 0.2 60.00
3/29/2021 Pay insurance for 3310 S Broadway 0.2 60.00
3/30/2021 Receive March's rent for 3310 S Broadway 0.2 60.00
Accounts open beyond 30 days are subject to a finance
fee of 1% per month (12% per year). Total $12,510.00
Page 10
Document Filed Date
April 16, 2021
Case Filing Date
November 02, 2016
Category
Commercial - Other (Constructive Trust)
Status
Stayed-Court Date/Application Pending
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FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 10/21/2020 Receive and review application for rerouting from 0.5 contractor; copy, add check for fee; hand-deliver to 150.00 City Hall. Advise parties. 10/26/2020 Work on Order to show cause - walls, etc. 1 300.00 10/28/2020 Pay motion fee for order to show cause to repair 0.2 60.00 walls, etc. 10/28/2020 Draft letter to clerk with order to show cause. 0.2 60.00 10/28/2020 pay insurance for 175 S Broadway 0.2 60.00 11/2/2020 Respond to Duo's inquiry about status of repair to 0.2 60.00 external walls. 11/2/2020 Draft letter to Utica First Insurance Company 0.4 regarding the requested repairs to 175 South 120.00 Broadway. 11/4/2020 Receive signed OTSC; diary; serve upon the 0.3 90.00 attorneys. 11/4/2020 Receive e-mail and photographs from GMC 0.2 60.00 requesting another $6,200 for new plywood. 11/4/2020 Draft letter to Judge Nolan requesting authority to 0.6 180.00 spend $6,200 to replace the plywood. 11/5/2020 Receive attorney Brennan's consent to buy the wood; 0.2 60.00 integrate into folder. 11/5/2020 Receive and review attorney Freund's motion to name 0.5 myself as party defendant in PI case. Review cited 150.00 statutes. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 1 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 11/5/2020 Check insurance policy for Duo's; draft letter to agent 0.5 150.00 requesting representation. 11/5/2020 Check errors & omissions insurance folder; draft 0.5 150.00 letter to agent to place carrier on notice. 11/5/2020 Draft and efile letter to Judge Nolan requesting a one 0.5 month adjournment to give time to carrier to respond 150.00 to motion. 11/5/2020 Call and e-mail Jon Crain to request his consent to 0.2 60.00 payment for the plywood. 11/5/2020 e-mail to court clerk to expedite permission to spend 0.2 60.00 the $6,200. 11/6/2020 Receive letter order allowing the expenditure of 0.2 60.00 $6,200; integrate into folder. 11/6/2020 Cut check @ $6,200. 0.2 60.00 11/6/2020 e-mail and phone call to GMC to arrange for pick up 0.2 60.00 of check. 11/11/2020 Numerous emails, letters & tel conf relative to 3 motion to name me as party defendant in the Kings 900.00 County PI case. 11/13/2020 Receive rent for 3310 South Broadway. 0.2 60.00 11/13/2020 Tel conf with Tim Brennan about posture of the case. 0.2 60.00 11/13/2020 Receive coverage letter from Hanover; review and 0.4 120.00 integrate into folder. 11/13/2020 Review Nolan's 2016 Decision and the resulting 0.5 150.00 Appellate Division Decision. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 2 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 11/13/2020 Tel conf with attorney Jon Crain. 0.4 120.00 11/13/2020 Receive and review the complaint in the instant 0.5 action, with special focus on cause of action to 150.00 challenge the deeds. 11/13/2020 Draft long letter to NY Mutual regarding its 0.8 240.00 disclaimer of coverage. 11/13/2020 Draft letter to Duo's asking if they made a claim for 0.4 120.00 "business interruption". 11/18/2020 Receive and record rent for 175 So Broadway 0.2 60.00 11/18/2020 Follow up with City Hall to see about status of 0.2 60.00 re-roofing permit and any required inspection. 11/18/2020 Ask Duo's for confirmation that the roof repair is 0.2 complete and that the rain is not leaking into the 60.00 restaurant. 11/19/2020 Tel conf with Paul Waterfield of NY Mutual 0.4 120.00 Insurance Company re PI litigation. 11/19/2020 Report to malpractice carrier the tel conf with Paul 0.3 90.00 Waterfield. 11/19/2020 Contact attorney for defendants in title litigation. 0.2 60.00 11/20/2020 Tel conf with Hanover attorney and assigned counsel. 0.5 Discuss status of motion to name receiver as party 150.00 defendant in Kings County PI case. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 3 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 11/21/2020 Receive and review papers in opposition to, and in 0.5 support of, motion to repair the walls. Integrate into 150.00 folder. Reach out to Duo's regarding business interruption insurance. 11/21/2020 Receive building permit from Building Department 0.2 for the re-roofing of 175 South Broadway. Review 60.00 and integrate into folder. 11/21/2020 e-mail to Building Department to ask about 0.1 30.00 inspections and CO. 11/21/2020 Receive e-mail from Duo's raising a question of 0.1 30.00 "stinky gutters". 11/21/2020 Respond to Duo's request for payment; ask about 0.2 60.00 inspections. 11/23/2020 Receive confirmation from Building Department that 0.2 they do not need to inspect the new roof at 175 South 60.00 Broadway. 11/23/2020 Cut check for final payment to GMC Construction 0.2 for roof replacement at 175 South Broadway. Notify 60.00 contractor. 11/24/2020 Long explanatory letter to Zongrone Agency 1.5 directing them to name both LLCs on the insurance 450.00 policies. Forward to litigants' attorneys for comments. 11/24/2020 Put letter to Zongrone agency in final form; add 0.3 90.00 attachments and send. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 4 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 11/24/2020 Correspond with insurance agency about correct 0.3 90.00 spelling of Lu Holding LLC. 11/24/2020 Emails with both parties attorneys and again with 0.4 Duo's about business interruption insurance. Locate 120.00 and review old policy of Duo's - note that it does contain coverage; provide to Duo's with explanation. 11/25/2020 Pay insurance for 3310 South Broadway. 0.2 60.00 11/25/2020 Pay insurance for 175 South Broadway. 0.2 60.00 11/27/2020 Receive, review responsive affirmation from attorney 0.2 Brennan in opposition to relief requested by plaintiff. 60.00 Integrate into folder. 11/27/2020 Receive coverage letter from NY Mutual and forward 0.2 60.00 to attorneys. 11/30/2020 Pay property tax for 3 parcels. 0.6 180.00 11/30/2020 Receive and review e-mail from Paul Waterfield to 0.2 Preferred Mutual Insurance. Integrate into folder; 60.00 forward to attorneys Ferris and Flanagan. 11/30/2020 Correspond with attorney Brian Casey. 0.2 60.00 12/1/2020 Telephone conference with attorneys from Hanover 0.8 and NY Mutual to discuss the motion to name me as 240.00 defendant. 12/2/2020 Receive and review long letter from attorney 0.3 90.00 Flanagan. 12/2/2020 e-mail with attorney Flanagan. 0.1 30.00 12/4/2020 Receive and deposit rent for 175 South Broadway. 0.2 60.00 Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 5 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 12/4/2020 Receive and review attorney Flanagan's long letter 0.4 120.00 about motion to name me as defendant. 12/10/2020 Receive and review Judge Nolan's order allowing for 0.5 the repair of the exterior walls of 175 South Broadway. Integrate into folder. Notify tenant. 150.00 Contact attorneys to see if they wish to submit estimates. 12/11/2020 Receive notice of re-assignment of case to judge 0.1 30.00 Walsh. 12/11/2020 Emails from attorneys about gathering estimates for 0.2 60.00 wall repairs, etc. 12/14/2020 Review affirmation of attorney Brian Casey. 0.4 120.00 12/14/2020 Tel conf with attorney Matthew Flanagan. 0.2 60.00 12/14/2020 Receive & deposit rent from 3310 South Broadway. 0.2 60.00 12/15/2020 Receive and review attorney Flanagan's 0.3 90.00 correspondence to Traveller's and Preferred Mutual. 12/15/2020 Balance five monthly statements. 0.5 150.00 12/15/2020 Confer with attorneys re inspection of the boiler. 0.2 60.00 12/15/2020 Confer with attorneys re paragraph 35 of lease and 0.3 90.00 boiler inspection. 12/15/2020 Receive and review draft affidavit of attorney Casey. 0.5 150.00 12/16/2020 Receive affidavit from attorney Casey; review same; 0.4 120.00 respond to his e-mail. 12/17/2020 Telephone conf with attorney Flanagan. 0.2 60.00 Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 6 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 12/17/2020 Receive and review new affidavit from attorney 0.2 60.00 Casey. 12/20/2020 Went to Duo's, observed the sewer smell; discussed 0.5 150.00 with staff and Iris. 12/21/2020 Receive detailed e-mail from Iris re: odor, integrate 0.5 150.00 into folder, forward to attorneys. 12/21/2020 Contact roofing contractor to return to site. (GMC) 0.2 60.00 12/21/2020 Send e-mail to independent contractor for second 0.2 60.00 opinion. 12/22/2020 Correspond with attorneys re odor and the roofing 0.2 60.00 contractor. 12/24/2020 Receive opposition papers of attorney Freund; review 0.5 150.00 same and respond to attorney Casey. 12/24/2020 Emails with Duo about remediation efforts. 0.3 90.00 12/24/2020 Call contractor Billy Morris; leave message. 0.2 60.00 12/29/2020 Tel conf with Paul Waterfield; e-mail to him a COI. 0.2 60.00 12/29/2020 Tel conf with contractor Billy Morris about the sewer 0.2 60.00 odor. 12/30/2020 e-mail to attorneys and Duo's about the sewer odor. 0.2 60.00 1/4/2021 Pay insurance for 175 S. Broadway 0.2 60.00 1/5/2021 Multiple emails on 12-30 re odors and contractors. 0.4 120.00 1/5/2021 Review long e-mail from Tim Brennan; his view is 0.2 that the odor must be resolved at the expense of the 60.00 tenant. Reply; request city code section. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 7 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 1/5/2021 Long e-mail to Duo's to explain to them how to 0.4 120.00 proceed with fixing the sewer odor. 1/27/2021 Receive and amend and deposit rent check for 3310 0.2 60.00 South Broadway. 1/28/2021 Pay insurance for 175 South Broadway 0.2 60.00 1/28/2021 Pay school taxes on three parcels. 0.6 180.00 2/2/2021 Schedule video conference. 0.2 60.00 2/2/2021 e-mail correspondence re Duo's business interruption 0.2 60.00 insurance. 2/2/2021 Remind the attorneys that the CD does not bear 0.2 interest; we need the names of the beneficial owners 60.00 in order to do so. 2/2/2021 e-mail correspondence with attorneys about the need 0.2 for estimates to repair the exterior walls of 175 south 60.00 Broadway. 2/2/2021 Call to Saratoga National to request the form - 0.2 60.00 Certification of Beneficial Owners 2/2/2021 Look for court order regarding validity of deeds. 0.2 60.00 2/2/2021 Look for deeds to establish chain of title. 0.5 150.00 2/2/2021 Long e-mail to attorneys to request copies of deeds 0.4 and to point out the discrepancy in names between 120.00 the court order and the actual deeds. 2/2/2021 Correspondence with the court about the status of the 0.2 PI case in King's County and the motion to add me as 60.00 party defendant. Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 8 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 Due on receipt Service Date Professional Services Time Amount 2/3/2021 Confer with malpractice attorney on motion. 0.2 60.00 2/3/2021 Order deeds from Clerk's office. 0.2 60.00 2/3/2021 Receive and review two deeds from Clerk's Office. 0.2 60.00 Note there was a typo in Judge Nolan's Decision. 2/4/2021 Call to Saratoga Bank officer, leave detailed 0.2 60.00 message. 2/4/2021 Review Certification of Benefic Ownership; forward 0.3 90.00 to attorney Brennan. 2/4/2021 Correspondence with bank officer regarding my 0.5 appointment as receiver, and an explanation of how 150.00 title is in Chuen Lou, LLC. Provide court orders with explanation. 2/5/2021 Receive rent for 175 South Broadway 0.2 60.00 2/8/2021 Correspondence with Saratoga National Bank re: 0.3 90.00 documentation. 2/8/2021 More correspondence with Saratoga National Bank 0.2 60.00 and Tim about documentation for Chuen Lou, LLC 2/11/2021 Pay property tax bills for three properties. 0.6 180.00 2/12/2021 Balance checking account per December statement 0.3 90.00 2/12/2021 Balance checking account per January statement 0.2 60.00 2/17/2021 e-mail with bank; send reminder to attorney Brennan 0.2 for documentation to help put money in interest 60.00 bearing account. 2/20/2021 Pay insurance on both properties. 0.4 120.00 Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total Page 9 FILED: SARATOGA COUNTY CLERK 04/16/2021 03:28 PM INDEX NO. 20162946 NYSCEF DOC. NO. 206 RECEIVED NYSCEF: 04/16/2021 The Law Office of David A Harper, P.C. Invoice 480 Broadway - Suite 211 Saratoga Springs, NY 12866 518-587-6670 pclute@davidharperlaw.com Bill To Lu vs. Lu Invoice # Date Total Due Terms Enclosed 18131 4/16/2021 $12,510.00 Due on receipt Service Date Professional Services Time Amount 2/24/2021 Contact insurance agent to change the name of the 0.2 60.00 insured owner to Chuen Lou, LLC. 2/26/2021 Emails about the alleged "boiler". 0.2 60.00 2/26/2021 Long tel conf with Paul Waterfield. 0.4 120.00 3/2/2021 Receive rent for 3310 South Broadway. 0.2 60.00 3/2/2021 Balance per bank statement as of 02-15-21. 0.2 60.00 3/2/2021 Receive e-mail with estimate to replace the stucco 0.2 walls. Integrate into folder - ask attorney Crain if he 60.00 intends to submit an estimate. 3/2/2021 Emails regarding changing the name of the insured 0.2 60.00 owner. 3/10/2021 Attend video conference with Judge Walsh. 0.4 120.00 3/10/2021 Receive and deposit rent for 175 South Broadway 0.2 60.00 3/29/2021 Pay insurance for 175 South Broadway 0.2 60.00 3/29/2021 Pay insurance for 3310 S Broadway 0.2 60.00 3/30/2021 Receive March's rent for 3310 S Broadway 0.2 60.00 Accounts open beyond 30 days are subject to a finance fee of 1% per month (12% per year). Total $12,510.00 Page 10