EXHIBIT B Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 1 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 1 of 17 PagelD 1142 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION FEDERAL TRADE COMMISSION, Plaintiff, Case No. 6:12-CV-1588-ORL-28-DAB VS. THE GREEN SAVERS, LLC, a Florida limited liability company, et al., Defendants. / AFFIDAVIT OF BRADLEY M. SAXTON AS TO COSTS AND TIME EXPENDED STATE OF FLORIDA COUNTY OF ORANGE BEFORE ME, the undersigned Notary Public, duly authorized to take acknowledgments and administer oaths, this day personally appeared, BRADLEY M. SAXTON, attorney for the Court-appointed Receiver, Robert B. Morrison, in the above-styled cause of action, who, being by me first duly sworn, deposes and states: 1. This Affidavit is filed in support of the Receiver’s Initial Unopposed Motion for Payment of Compensation and Costs with Incorporated Memorandum of Law (“Motion”). 2 This Affidavit outlines the qualifications of the attorneys and paralegal who have worked on this case on behalf of the Receiver. Additionally, this affidavit explains the work that was performed for the Receiver and the reasonableness of the legal fees incurred thus far. Attached in support of this Affidavit and the Motion is an /nvoice itemizing the costs and time expended for legal services performed on behalf of the Receiver, in addition to a Summary of Work Performed by Category. Exhibit "B" Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 2 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 2 of 17 PagelD 1143 Attorney and Paralegal Qualifications A. Bradley M. Saxton, Esq. — Shareholder Attorney 3. I am a shareholder in the law firm of Winderweedle, Haines, Ward & Woodman, P.A., which has been retained by the Receiver in this cause. I am the responsible billing attorney for this matter, and have primary billing responsibility on many other matters. 4. I was admitted to The Florida Bar in 1990 and I have more than 22 years of experience as a lawyer. I am a member of The Florida Bar, the United States District Court for the Northern District of Florida, the United States District Court for the Middle District of Florida, the United States District Court for the Southern District of Florida, and the United States Court of Appeals, Eleventh Circuit. 5. My practice focus is primarily on bankruptcy and creditor’s rights cases, including extensive experience working with and representing trustees in bankruptcy cases. I have represented the Receiver in a previous Federal Trade Commission case. I have also represented receivers in state court actions, and have been involved in many cases under Fla. Stat. Ch. 727 involving assignments for the benefit of creditors. 6. I am a member of the Florida Bar Business Law Section, have served on the executive council for the Section, and have served as the Chair of the Section’s Bankruptcy/UCC Committee. As a result of my involvement with the Florida Bar Business Law Section, in addition to my experience as a lawyer practicing commercial litigation, I am familiar with the reasonableness of attorneys’ fees and costs when representing a receiver. B. C. Andrew Roy, Esq. — Associate Attorney 7s C. Andrew Roy is an associate with our firm and obtained his law degree in 2011 from the University of Florida; since that time, he has devoted his practice to litigation in state 2 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 3 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 3 of 17 PagelD 1144 and federal courts, primarily bankruptcy and creditor’s rights cases. While in law school at the University of Florida, Mr. Roy served as the President of The Florida Moot Court Team and researched diverse legal issues, drafted appellate-level briefs, and argued developing case law in front several panels of judges while participating as a moot court competitor. 8. In practice, Mr. Roy has worked on appellate issues involving federal law, including drafting principal briefs and outlining oral arguments. Mr. Roy is also a member of The Florida Bar, the United States District Court for the Northern District of Florida, the United States District Court for the Middle District of Florida, the United States District Court for the Southern District of Florida, and the United States Court of Appeals, Eleventh Circuit. 2H Under my supervision, Mr. Roy has handled many of the issues in this case, which, based on his hourly rate of $190.00, has contributed to keeping the legal fees low while maintaining the quality of work performed. Mr. Roy’s work includes researching legal issues regarding the Receiver’s rights and responsibilities, drafting pleadings, and recovering receivership assets. Mr. Roy’s hourly rate is $190.00, which rate is well within the norm for associates working on federal litigation. C. Mary Emanuel — Paralegal 10. Mary Emanuel is a paralegal with our firm and received her college degree in 1992. She joined our firm in 2009 and has worked as a paralegal for approximately ten (10) years. Ms. Emanuel received her Certified Legal Assistant/Certified Paralegal designation in 2000 from the National Association of Legal Assistants and her Florida Bar paralegal registration in 2008. Accordingly, she is qualified to provide the services shown on the Invoice attached hereto. Additionally, her rate of $125 per hour is well within the norm for paralegal work for cases in Federal Court. 3 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 4 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 4 of 17 PagelD 1145 Work Performed and Results Obtained 11. For the legal services our Firm provided to the Receiver, the following fees were incurred through December 31, 2012: Producer Role Rate Hours Amount Bradley M. Saxton | Partner $410.00 13.3 | $ 5,453.00 Bradley M. Saxton | Partner No Charge 0.5 | $ 0.00 C. Andrew Roy Associate $190.00 29.5 | $ 5,605.00 C. Andrew Roy Associate | No Charge 0.8 | $ 0.00 Mary Emanuel Paralegal $125.00 2.7|$ 337.50 TOTAL $ 11,395.50 A typographical error was discovered in the Invoice attached and has been corrected. 12. The fees incurred by the Receiver are assignable to seven general categories of work performed, though, as illustrated below and in the attached Summary, most of the work performed by our Firm falls primarily into four of the seven categories: Category Activity Fees 1 Pre-entry planning and initial entry $ 0.00 2 Creditor matters $ 1,627.00 3 Employee matters $ 0.00 4 Identify, locate, secure, and sell assets | $ 5,319.50 5 Core litigation matters $ 527.00 6 Receivership administrative $ 3,922.00 7 Other activities $ 0.00 NC No charge $ 357.00 TOTAL — $11,395.50 13. Creditor Matters. To assist in the Receiver’s duties, our Firm has analyzed issues concerning various creditors, primarily the landlord who leased the Offices to TGS and the Seminole County Tax Collector. Our Firm continues working to fully resolve these potential claims and has thus far minimized the Receivership Estate’s exposure to claims of creditors. 14. Identify, locate, secure, and sell assets. Our Firm’s most significant time invested in this case concerns the Receiver’s marshaling and administration of Receivership assets. Of note, our Firm assisted the Receiver in recovering $130,840.72 in chargeback reserves held by a 4 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 5 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 5 of 17 PagelD 1146 credit card processor. These funds are currently held in our Firm’s trust account pending final determination of the Receiver’s entitlement to those funds. As of last report from the processor, only $45,815.00 in chargebacks have been processed since the turnover of funds. Additionally, our Firm assisted the Receiver in settling a state court claim against another processor in exchange for the outright turnover of funds. Furthermore, our Firm advised the Receiver as to liquidating certain tangible personal property of the Receivership Defendants in order to realize the full value of those assets without incurring additional liability for rent of TGS’s Offices. In performing this work, our Firm also analyzed the legal issues associated with these activities, and drafted pleadings concerning the liquidation of certain assets via public auction, abandonment of the leased premises, and other issues including pleadings to comply with orders of this Court. IS. Core litigation matters. A majority of this work entailed ensuring the preservation of information, documents, and other evidence that may be essential to the underlying litigation. In addition, our Firm’s work in this category focused on communicating with counsel for the FTC and the Receivership Defendants to coordinate the Receiver’s role in the underlying litigation and allowing the inspection of Receivership property, including documents, available for inspection. 16. Receivership administrative. Our Firm’s work in this category of activities centers on advising the Receiver as to his rights and responsibilities as determined by this Court’s Orders, Federal law, and state law. Work in this category includes representing the Receiver at hearings, drafting necessary pleadings required by this Court, complying with deadlines set forth in Court Orders, assisting the Receiver in preparing his reports, filing the Receiver’s Bond, and assisting in other administrative matters that concern the Receiver as a neutral agent of the Court. 5 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 6 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 6 of 17 PagelD 1147 17. The detail of and time associaied with the tasks summarized above are reflected in the Invoice and Summary attached hereto. Costs Incurred 18. In addition to the legal fees incurred as illustrated above, the following costs were incurred through December 31, 2012: Nature of Expense Lexis® Research Charges |$ 197.80 Photocopy Charges (121) |$ 24.20 Long Distance Charges TOTAL $ 223.20 19, In summary, our Firm assisted the Receiver in recovering much of the nearly $180,000 in Receivership Defendant assets in the control of the Receiver thus far, while also working to preserve the Receivership Estate for the benefit of potential claimants. In so performing our duties as the Receiver’s legal counsel, our Firm has expended a total of $11,618.70, which includes no charge accommodations for certain work performed totaling ba 7.00) FURTHER AFFIANT SAYETH NAUGHT. was i ee BRADLEY M.SAXTON, ESQ.” SWORN TO AND SUBSCRIBED before me by Bradley M. Saxton, Esq., who 4 personally known to me or O) produced as identification, this Ye day of January, 2013. (Notary Seal) Notary Public ike, TONIM. HIGGENS ye : LZ ii a MY COMMISSION # EE 845549 J ; f 3 : Signature Big _ EXPIRES: December 17, 2016 " Beas Bonded Thru Notary Public Underwriters My Commission Expires: Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 7 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 7 of 17 PagelD 1148 WINDERWEEDLE, HAINES, WARD & WOODMAN, P.A. P.O. BOX 880 WINTER PARK, FLORIDA 32790-0880 (407)-423-4246 January 03, 2013 Bob Morrison Tedder, James, Worden & Associates, P.A. INVOICE Matter ID: 74376 Matter Producer: BMS Client ID: 20895CLI Morrison, Bob as Receiver for Federal Trade Comm.v. Green Savers Invoice # 318576 Federal ID # 59-1295597 For Professional Services Rendered: 10/24/2012 BMS Call with B. Morrison regarding receivership (.1); review receivership order (.4); 1.30 hr $533.00 review issues regarding receivership (.6); correspondence to defendant's counsel (.1); call with B. Morrison (.1) 10/26/2012 BMS Call with B. Morrison and P. Dumm regarding bank accounts (.3); call with 0.60 hr $246.00 Tushaar Desai regarding cooperation by his client (.3) 10/29/2012 BMS Review several correspondence in this case 0.30 hr $123.00 10/29/2012 BMS Call with B. Morrison (.2); call with Federal Trade Commission counsel (.3) 0.50 hr $205.00 10/30/2012 CAR Initial review of order imposing preliminary injunction and appointing receiver 1.50 hr $285.00 10/30/2012 BMS Review correspondence from B. Morrison and R. Bhimani and review draft of 0.40 hr $164.00 preliminary injunction order (.4) 10/31/2012 CAR Work on case for notice of appearance and other filings 0.20 hr $38.00 10/31/2012 BMS Correspondence with B. Morrison regarding issues for hearing 0.20 hr $82.00 10/31/2012 BMS Review correspondence from A. Roy regarding strategy (no charge) 0.20 hr $0.00 10/31/2012 BMS Correspondence from B. Morrison (.2); call to M. Griffin (.1); review issues in 0.70 hr $287.00 preparation for hearing (.4) 11/01/2012 BMS Review draft of receiver's report (.5); call with attorney from Financial 1.20 hr $492.00 Transaction Services (.2) call with B. Morrison regarding case status and issues regarding lease, Financial Transaction Services suit and hearing (.4); received correspondence regarding lease (.1) 11/01/2012 CAR Conference with client regarding status of receivership and documents to file 0.40 hr $76.00 11/01/2012 CAR Review and revise notice of appearance (0.2); continue review of order 1.50 hr $285.00 appointing receiver (0.4); review receiver's report (0.7) 11/02/2012 BMS Received correspondence from J. Wei regarding stipulated injunction order (.3); 0.70 hr $287.00 correspondence to J. Wei (.1); received correspondence from B. Morrison (.1); correspondence from J. Wei regarding hearing (.2) 11/02/2012 BMS Review correspondence and work on filing of receiver's report (no charge) 0.30 hr $0.00 11/02/2012 CAR Revise receiver's report and finalize for filing (0.6); email counsel for FTS 1.20 hr $228.00 regarding settlement (0.2); review building lease (0.4) 11/05/2012 BMS Review for hearing in case and attend hearing and meeting with FTC counsel 1.60 hr $656.00 11/05/2012 CAR Attend hearing on preliminary injunctions (no charge) 0.80 hr $0.00 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 8 of 1@age 1 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 8 of 17 PagelD 1149 Matter ID: 74376 Invoice # 318576 Federal ID # 59-1295597 For Professional Services Rendered: 11/05/2012 CAR Review pleadings in case against FTS (0.3); email B. Morrison regarding 0.40 hr $76.00 analysis and possible settlement (0.1) 11/05/2012 BMS Review court filed pleadings in the case 0.20 hr $82.00 11/06/2012 BMS Review analysis regarding FTS complaint 0.20 hr $82.00 11/07/2012 BMS Review regarding collection of funds from processor, review several 0.40 hr $164.00 correspondence regarding processor issue 11/07/2012 CAR Phone call with J. Wei regarding turnover of processor reserves (0.5); review 1.00 hr $190.00 case law regarding turnover of processor reserves (0.2); draft update email to client regarding status of turnover of reserves (0.3) 11/07/2012 CAR Phone calls with FTC counsel and representative of Newtek regarding reserves 0.50 hr $95.00 11/08/2012 BMS Review correspondence regarding processor funds 3-00-HF 0.3 $4,230-005123.00 11/09/2012 BMS Work on issues in the case regarding recovery from processor and liquidation 0.50 hr $205.00 of items (.4); call with B. Morrison regarding liquidation (.1) 11/09/2012 CAR Communicate with FTS counsel and client regarding settlement of claims 1.00 hr $190.00 11/09/2012 CAR Draft update email to client regarding outstanding issues in case 0.70 hr $133.00 11/11/2012 CAR Email FTS counsel regarding settlement 0.10 hr $19.00 11/11/2012 CAR Draft notice of liquidation and abandonment (2.3); email client regarding notice 2.40 hr $456.00 of liquidation and abandonment (0.1) 11/12/2012 BMS Review correspondence regarding chargeback issue (.2) 0.20 hr $82.00 11/14/2012 BMS Review regarding notice of sale 0.10 hr $41.00 11/14/2012 MEE Search public records for current whereabouts of G. Michael Hall for attorney 0.60 hr $75.00 use 11/14/2012 BMS Review pleadings in the case (.3) 0.30 hr $123.00 11/14/2012 CAR Review email from client regarding documents held 0.20 hr $38.00 11/14/2012 CAR Finalize notice of liquidation and abandonment for filing 0.30 hr $57.00 11/14/2012 CAR Draft demand letter to Newtek for turnover of reserves 1.40 hr $266.00 11/15/2012 MEE Emails to/from A. Roy, Esq. re reviewing filings and preparing Stipulation and 0.20 hr $25.00 Order of Dismissal 11/15/2012 MEE Review filings in related circuit court case and confirm correct judge and related 0.30 hr $37.50 in preparation for Stipulation and Order of Dismissal 11/15/2012 MEE Prepare initial draft Stipulation of Dismissal and proposed Order 0.50 hr $62.50 11/15/2012 BMS Review correspondence regarding collection from processor entities (.2); 0.70hr $287.00 review and revise draft of letter to processor to demand payment (.3); review status of other processor claims (.2) 11/15/2012 CAR Finalize demand letter to Newtek (0.4); email letter to Newtek (0.2) 0.60 hr $114.00 11/15/2012 CAR Draft certificates of interested persons and related cases 1.00 hr $190.00 11/15/2012 CAR Start drafting notice of dismissal of state court action 0.40 hr $76.00 11/16/2012 BMS Call with B. Morrison 0.10 hr $41.00 11/18/2012 BMS Review correspondence with Derek Depuydt, Joanie Wei and Marcie Lewis 0.30 hr $123.00 regarding asset freeze 11/20/2012 CAR Emails regarding demand for Newtek to freeze assets and turnover reserves. 0.20 hr $38.00 11/21/2012 CAR fei stipulation for dismissal (0.4); email FTS counsel regarding stipulation 0.50 hr $95.00 11/21/2012 CAR Phone call with J. Wei regarding turnover of reserves by Newtek and response 1.20 hr $228.00 to demand (0.4); communications with Newtek counsel and client to coordinate turnover of reserves (0.8) Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 9 of 1&age 2 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 9 of 17 PagelD 1150 Matter ID: 74376 Invoice # 318576 Federal ID # 59-1295597 For Professional Services Rendered: 11/21/2012 11/25/2012 11/26/2012 11/27/2012 11/27/2012 11/27/2012 11/27/2012 11/27/2012 11/27/2012 11/28/2012 11/28/2012 11/28/2012 11/28/2012 11/28/2012 11/29/2012 11/29/2012 11/29/2012 11/29/2012 11/29/2012 11/30/2012 11/30/2012 11/30/2012 11/30/2012 12/02/2012 12/11/2012 12/13/2012 12/13/2012 12/13/2012 12/13/2012 12/13/2012 BMS BMS CAR BMS BMS CAR CAR CAR MEE CAR CAR CAR CAR CAR MEE CAR CAR CAR CAR CAR CAR CAR CAR BMS CAR BMS CAR CAR CAR CAR Review pleading filed in case (.3); review correspondence regarding NewTek (.2) Review stipulation (.1); review additional correspondence in case (.1) Finalize stipulation for execution by FTS counsel (0.2); draft notice of settlement for filing (0.5); email FTS counsel regarding stipulation (0.2); email Newtek counsel regarding position as to reserves (0.2) Review additional pleadings filed in case Review correspondence regarding settlement, and notice of compromise (.2); receive correspondence from J. Wei to T. Desai (.1) Phone call with J. Wei regarding case mangement order and determination of reserves ownership Review and execute stipulation of dismissal for filing (0.2); review coorespondence to judge regarding stipulation and proposed order (0.2) Phone call with J. Augustine regarding dismissal of case against FTS Letter to Judge (circuit court case) re review of Stipulation for Dismissal and entry of Order of Dismissal; file and serve accordingly Review emails from client regarding Quickbooks accounts Review bond and draft notice of filing bond Analyze issues regarding priority tax lien and selling property Phone call with J. Wei regarding FTC's position as to working out Newtek reserves issue Emails with counsel for Newtek and FTC regarding lien documentation and conference call Search California public records to determine if any UCC filings have been filed in connection with Green Savers and search name variations to ensure accuracy; email A. Roy, Esq. re results Emails regarding submitting original bond to clerk Analyze issues regarding processor reserves by reviewing merchant agreement documents Emails with client regarding processor reserves issues Emails with FTC and counsel for Newtek regarding chargebacks and reserves Conference call with J. Wei and R. Bhimani regarding reserves and chargeback issues Analyze tangible tax issue and status of return filing; communications with tax collector's office Phone call to B. Morrison regarding status of tangible tax issue Phone call to M. Ash regarding reserves turnover issue Review pleadings in case, defendant's answer (.1); review correspondence regarding Bond (.2) Review emails regarding reserve balance and abandoning lease Correspondence regarding auction and abandonment Draft letter to lease company regarding abandonment of lease and vacate premises Emails regarding release of FTS litigation funds Emails regarding lease abandonment issues Analyze issues regarding cleanup of leased premises and priority of claim, if any Review correspondence regarding landlord issues 0.50 hr 0.20 hr 1.10 hr 0.20 hr 0.30 hr 0.20 hr 0.40 hr 0.10 hr 0.50 hr 0.20 hr 0.40 hr 1.30 hr 0.20 hr 0.30 hr 0.60 hr 0.10 hr 0.80 hr 0.50 hr 0.20 hr 0.20 hr 1.00 hr 0.20 hr 0.20 hr 0.30 hr 0.20 hr 0.30 hr 0.60 hr 0.20 hr 0.40 hr 1.90 hr Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 10 of 1Bage 3 $205.00 $82.00 $209.00 $82.00 $123.00 $38.00 $76.00 $19.00 $62.50 $38.00 $76.00 $247.00 $38.00 $57.00 $75.00 $19.00 $152.00 $95.00 $38.00 $38.00 $190.00 $38.00 $38.00 $123.00 $38.00 $123.00 $114.00 $38.00 $76.00 $361.00 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 10 of 17 PagelD 1151 Matter ID: 74376 Invoice # 318576 Federal ID # 59-1295597 For Professional Services Rendered: 12/14/2012 BMS 0.20 hr $82.00 12/17/2012 BMS Review of case management order 0.20 hr $82.00 12/17/2012 CAR Phone call with D. Figliolia regarding lease and deposit issues 0.20 hr $38.00 12/18/2012 CAR Draft turnover letter to Progress Energy (0.5); emails with client regarding 0.70 hr $133.00 status of reserves and lease issues (0.2) 12/20/2012 CAR Review correspondence from Progress Energy (0.3); analyze issues regarding 0.70 hr $133.00 ownership of deposit (0.3); draft email to client regarding turnover of utility deposit (0.1) 12/20/2012 CAR Phone call with B. Hagey of Seminole County Tax Collector 0.30 hr $57.00 12/20/2012 CAR Correspondence with defendants' counsel regarding inspection of documents 0.20 hr $38.00 12/20/2012 BMS Review correspondence regarding tangible property taxes 0.10 hr $41.00 12/27/2012 BMS Review issues in case and compliance with court obligations 0.20 hr $82.00 Total Professional Services: 602, $11,395.50 For Disbursements Incurred: 10/31/2012 Lexis Computer Research Charges $3.61 11/30/2012 Lexis Computer Research Charges $194.19 11/30/2012 121 Photocopy Charges $24.20 11/30/2012 Long Distance Charge $1.20 Total Disbursements Incurred: $223.20 INVOICE SUMMARY ; Producer Role Rate Hours Amount ' | Brad Saxton PARTNER $0.00 0.50 $0.00 : Brad Saxton PARTNER $410.00 46.00 13.3 $5,453.00 $6,560.00 ; Mary Emanuel PARALEGAL $125.00 2.70 $337.50 i C. Andrew Roy ASSOCIATE $0.00 0.80 $0.00 i 1. .0-Andrew Roy PS ene deucecedace ONY ceed a $5,605.00 | _ For Professional Services: : ; 46.80 Hours $11,395.50 For Disbursements Incurred: $223.20 Total this Invoice: wei $11,618.70 Please return one copy of this Invoice with your payment. Thank you. Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 11 of 1Bage 4 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 11 of 17 PagelD 1152 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Time Amount Category 1 Pre-entry Planning and Initial Entry Total §$ 0.00 Category 2 Creditor Matters 2 11/1/2012 BMS Received correspondence regarding lease 0.1 $ 41.00 2 12/14/2012 BMS Review correspondence regarding landlord issues 02 § 82.00 2 12/20/2012 BMS Review correspondence regarding tangible property taxes 0.1 $ 41.00 2 11/2/2012 CAR Review building lease 04 §$ 76.00 2 11/11/2012 CAR Draft notice of liquidation and abandonment (1/2) 1.1 $ 209.00 2 11/11/2012 CAR Email client regarding notice of liquidation and abandonment 0.1 $ 19.00 Z 11/28/2012 CAR Analyze issues regarding priority tax lien and selling property 13 $ 247.00 7 11/30/2012 CAR Analyze tangible tax issue and status of return filing; communications with tax 10 $ 190.00 collector's office 2 11/30/2012 CAR Phone call to B. Morrison regarding status of tangible tax issue 0.2 §$ 38.00 2 12/11/2012 CAR Review emails regarding reserve balance and abandoning lease (1/2) 0.1 $ 19.00 2 12/13/2012 CAR Draft letter to lease company regarding abandonment of lease and vacate premises 0.6 $ 114.00 2 12/13/2012 CAR Emails regarding lease abandonment issues 04 §$ 76.00 2 12/13/2012 CAR Analyze issues regarding cleanup of leased premises and priority of claim, if any 19 $ 361.00 2 12/17/2012 CAR Phone call with D. Figliolia regarding lease and deposit issues 0.2 §$ 38.00 Z 12/18/2012 CAR Emails with client regarding status of reserves and lease issues (1/2) 0.1 $ 19.00 z 12/20/2012 CAR Phone call with B. Hagey of Seminole County Tax Collector 0.3. $ 57.00 Total $ 1,627.00 Category 3 Employee Matters Total §$ 0.00 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 12 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 12 of 17 PagelD 1153 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Entry Time Amount Category 4 Identify, Locate, Secure, and Sell Assets 4 10/26/2012 BMS Call with B. Morrison and P. Dumm regarding bank accounts 0.3 $ 123.00 4 10/29/2012 BMS Call with B. Morrison 0.2 §$ 82.00 4 10/31/2012 BMS Correspondence from B. Morrison 0.2 §$ 82.00 4 10/31/2012 BMS Call to M. Griffin 0.1 $ 41.00 4 11/1/2012 BMS Call with attorney from Financial Transaction Services 0.2 §$ 82.00 4 11/1/2012 BMS ee nadine aes = status and issues regarding lease, Financial 04 § 164.00 4 11/6/2012 BMS Review analysis regarding FTS complaint 0.2 §$ 82.00 4 11/7/2012 BMS he aes of funds from processor, review several correspondence 0.4 § 164.00 4 11/8/2012 BMS Review correspondence regarding processor funds 0.3 $ 123.00 4 11/9/2012 BMS Work on issues in the case regarding recovery from processor and liquidation of items 0.4 $ 164.00 4 11/9/2012 BMS Call with B. Morrison regarding liquidation 0.1 $ 41.00 4 11/12/2012 BMS Review correspondence regarding chargeback issue 0.2 §$ 82.00 4 11/14/2012 BMS Review regarding notice of sale 0.1 $ 41.00 4 11/15/2012 BMS Review correspondence regarding collection from processor entities 0.2 §$ 82.00 4 11/15/2012 BMS Review and revise draft of letter to processor to demand payment 0.3 $ 123.00 4 11/15/2012 BMS Review status of other processor claims 02 3 82.00 4 11/18/2012 BMS Review correspondence with Derek Depuydt, Joanie Wei and Marcie Lewis regarding 03 $ 123.00 asset freeze 4 11/21/2012 BMS Review pleading filed in case 0.3 $ 123.00 4 11/21/2012 BMS Review correspondence regarding NewTek 0.2 $§$ 82.00 4 11/25/2012 BMS Review stipulation 0.1 $ 41.00 4 11/27/2012 BMS Review correspondence regarding settlement, and notice of compromise 0.2 §$ 82.00 4 12/13/2012 BMS Correspondence regarding auction and abandonment OS os 123.00 4 11/2/2012 CAR Email counsel for FTS regarding settlement 0.2 §$ 38.00 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 13 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 13 of 17 PagelD 1154 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Entry Time Amount 4 11/5/2012 CAR Review pleadings in case against FTS 0.3 §$ 57.00 4 11/5/2012 CAR Email B. Morrison regarding analysis and possible settlement 0.1 $ 19.00 4 11/7/2012 CAR Phone call with J. Wei regarding turnover of processor reserves 05 §$ 95.00 4 11/7/2012 CAR Review case law regarding turnover of processor reserves 0.2 §$ 38.00 4 11/7/2012 CAR Draft update email to client regarding status of turnover of reserves 0.3 §$ 57.00 4 11/7/2012 CAR Phone calls with FTC counsel and representative of Newtek regarding reserves 0.5 §$ 95.00 4 11/9/2012 CAR Communicate with FTS counsel and client regarding settlement of claims 10 $ 190.00 4 11/11/2012 CAR Email FTS counsel regarding settlement 0.1 $ 19.00 4 11/11/2012 CAR Draft notice of liquidation and abandonment (1/2) 1.2 $ 228.00 4 11/14/2012 CAR Finalize notice of liquidation and abandonment for filing U3 2 57.00 4 11/14/2012 CAR Draft demand letter to Newtek for turnover of reserves 14 $ 266.00 4 11/15/2012 CAR Finalize demand letter to Newtek 04 §$ 76.00 4 11/15/2012 CAR Email letter to Newtek 0.2 $ 38.00 4 11/15/2012 CAR Start drafting notice of dismissal of state court action 04 §$ 76.00 4 11/20/2012 CAR Emails regarding demand for Newtek to freeze assets and turnover reserves. 02 f 38.00 4 11/21/2012 CAR Revise stipulation for dismissal 0.4 $ 76.00 4 11/21/2012 CAR Email FTS counsel regarding stipulation 0.1 $ 19.00 4 11/21/2012 CAR see ad with J. Wei regarding turnover of reserves by Newtek and response to 04 ¢ 76.00 4 11/21/2012 CAR Communications with Newtek counsel and client to coordinate turnover of reserves 0.8 $ 152.00 4 11/26/2012 CAR Finalize stipulation for execution by FTS counsel 0.2 $§$ 38.00 4 11/26/2012 CAR Draft notice of settlement for filing 05 §$ 95.00 4 11/26/2012 CAR Email FTS counsel regarding stipulation 0.2 §$ 38.00 4 11/26/2012 CAR Email Newtek counsel regarding position as to reserves 0.2 §$ 38.00 4 11/27/2012 CAR ee with J. Wei regarding case mangement order and determination of reserves 02 ¢ 38.00 4 11/27/2012 CAR Review and execute stipulation of dismissal for filing 0.2 §$ 38.00 4 11/27/2012 CAR Review coorespondence to judge regarding stipulation and proposed order 0.2 §$ 38.00 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 14 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 14 of 17 PagelD 1155 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Entry Time Amount 4 11/27/2012 CAR Phone call with J. Augustine regarding dismissal of case against FTS 0.1 $ 19.00 4 11/28/2012 CAR Review emails from client regarding Quickbooks accounts 0.2 $§$ 38.00 4 11/28/2012 CAR Phone call with J. Wei regarding FTC's position as to working out Newtek reserves issue 0.2 $ 38.00 ri 11/28/2012 CAR ae with counsel for Newtek and FTC regarding lien documentation and conference 03 ¢ 57.00 4 11/29/2012 CAR Analyze issues regarding processor reserves by reviewing merchant agreement 08 $$ 152.00 documents 4 11/29/2012 CAR Emails with client regarding processor reserves issues 0.5 $ 95.00 4 11/29/2012 CAR Emails with FTC and counsel for Newtek regarding chargebacks and reserves 0.2 $ 38.00 4 11/30/2012 CAR Conference call with J. Wei and R. Bhimani regarding reserves and chargeback issues 0.2 §$ 38.00 4 11/30/2012 CAR Phone call to M. Ash regarding reserves turnover issue 0.2 $ 38.00 4 12/11/2012 CAR Review emails regarding reserve balance and abandoning lease (1/2) 0.1 $ 19.00 4 12/13/2012 CAR Emails regarding release of FTS litigation funds 0.2 $§$ 38.00 4 12/18/2012 CAR Draft turnover letter to Progress Energy 0.5 $ 95.00 4 12/18/2012 CAR Emails with client regarding status of reserves and lease issues (1/2) 0.1 $ 19.00 4 12/20/2012 CAR Review correspondence from Progress Energy 0.3 §$ 57.00 4 12/20/2012 CAR Analyze issues regarding ownership of deposit 0.3. $ 57.00 4 12/20/2012 CAR Draft email to client regarding turnover of utility deposit 0.1 §$ 19.00 4 11/14/2012 MEE Search public records for current whereabouts of G. Michael Hall for attorney use 0.6 $ 75.00 4 11/15/2012 MEE Emails to/from A. Roy, Esq. re reviewing filings and preparing Stipulation and Order of 02 ¢ 25.00 Dismissal 4 11/15/2012 MEE Review filings in related circuit court case and confirm correct judge and related in 03 $ 37.50 preparation for Stipulation and Order of Dismissal 4 11/15/2012 MEE Prepare initial draft Stipulation of Dismissal and proposed Order 05 §$ 62.50 r 11/27/2012 MEE Letter to Judge (circuit court case) re review of Stipulation for Dismissal and entry of 05 ¢$ 62.50 Order of Dismissal; file and serve accordingly Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 15 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 15 of 17 PagelD 1156 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Time Amount Search California public records to determine if any UCC filings have been filed in 4 11/29/2012 MEE connection with Green Savers and search name variations to ensure accuracy; email A. 0.6 $ 75.00 Roy, Esq. re results Total $ 5,319.50 Category 5 Core Litigation Matters 5 10/24/2012 BMS Correspondence to defendant's counsel 0.1 $ 41.00 5 10/26/2012 BMS Call with Tushaar Desai regarding cooperation by his client 0.3. $ 123.00 5 10/29/2012 BMS Call with Federal Trade Commission counsel 0.3 $ 123.00 5 11/27/2012 BMS Receive correspondence from J. Wei to T. Desai 0.1 $ 41.00 5 12/2/2012 BMS Review pleadings in case, defendant's answer 0.1 $ 41.00 5 12/17/2012 BMS Review of case management order 0.2 §$ 82.00 = 11/14/2012 CAR Review email from client regarding documents held 0.2 §$ 38.00 ) 12/20/2012 CAR Correspondence with defendants’ counsel regarding inspection of documents 0.2 §$ 38.00 Total $ 527.00 Category 6 Receivership Administrative 6 10/24/2012 BMS Call with B. Morrison regarding receivership 0.1 $ 41.00 6 10/24/2012 BMS Review receivership order 0.4 $ 164.00 6 10/24/2012 BMS Review issues regarding receivership 0.6 $ 246.00 6 10/24/2012 BMS Call with B. Morrison 0.1 $ 41.00 6 10/29/2012 BMS Review several correspondence in this case 0.3 $ 123.00 6 10/30/2012 BMS Review correspondence from B. Morrison and R. Bhimani and review draft of 04 § 164.00 preliminary injunction order 6 10/31/2012 BMS Correspondence with B. Morrison regarding issues for hearing 02 § 82.00 6 10/31/2012 BMS Review issues in preparation for hearing 0.4 $ 164.00 6 11/1/2012 BMS Review draft of receiver's report 0.5 $ 205.00 Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 16 of 18 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 16 of 17 PagelD 1157 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Category Date Producer Entry Time Amount 6 11/2/2012 BMS Received correspondence from J. Wei regarding stipulated injunction order 0.3 $ 123.00 6 11/2/2012 BMS Correspondence to J. Wei 0.1 $ 41.00 6 11/2/2012 BMS Received correspondence from B. Morrison 0.1 $ 41.00 6 11/2/2012 BMS Correspondence from J. Wei regarding hearing 0.2 §$ 82.00 6 11/5/2012 BMS Review for hearing in case and attend hearing and meeting with FTC counsel 16 $ 656.00 6 11/5/2012 BMS Review court filed pleadings in the case 0.2 §$ 82.00 6 11/14/2012 BMS Review pleadings in the case 0.3 $ 123.00 6 11/16/2012 BMS Call with B. Morrison 0.1 $ 41.00 6 11/25/2012 BMS Review additional correspondence in case 0.1 $ 41.00 6 11/27/2012 BMS Review additional pleadings filed in case 02 8 82.00 6 12/2/2012 BMS Review correspondence regarding Bond 0.2 §$ 82.00 6 12/27/2012 BMS Review issues in case and compliance with court obligations 0.2 §$ 82.00 6 10/30/2012 CAR Initial review of order imposing preliminary injunction and appointing receiver 15 $ 285.00 6 10/31/2012 CAR Work on case for notice of appearance and other filings 0.2 §$ 38.00 6 11/1/2012 CAR Conference with client regarding status of receivership and documents to file 04 §$ 76.00 6 11/1/2012 CAR Review and revise notice of appearance 0.2 $ 38.00 6 11/1/2012 CAR Continue review of order appointing receiver 0.6 $ 114.00 6 11/1/2012 CAR Review receiver's report 0.7 $ 133.00 6 11/2/2012 CAR Revise receiver's report and finalize for filing 0.6 $ 114.00 6 11/9/2012 CAR Draft update email to client regarding outstanding issues in case 0.7 $ 133.00 6 11/15/2012 CAR Draft certificates of interested persons and related cases 10 $ 190.00 6 11/28/2012 CAR Review bond and draft notice of filing bond 04 §$ 76.00 6 11/29/2012 CAR Emails regarding submitting original bond to clerk 0.1 $ 19.00 Total $ 3,922.00 Category 7 Other Activities Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 17 of 18 Total $ 0.00 Case 6:12-cv-01588-JA-DAB Document 53-2 Filed 01/04/13 Page 17 of 17 PagelD 1158 FTC v. The Green Savers, LLC, et. al. Case. No. 6:12-CV-1588-ORL-28-DAB Summary of Work Performed by Category Winderweedle, Haines, Ward & Woodman, P.A. Time Amount Category Date Producer NO CHARGE ITEMS NC 10/31/2012 BMS Review correspondence from A. Roy regarding strategy (no charge) 0.2 $ (82.00) NC 11/2/2012 BMS Review correspondence and work on filing of receiver's report (no charge) 0.3 $ (123.00) 0.8 $ (152.00) Total $ (357.00) TOTAL FEES $ 11,395.50 NC 11/5/2012 CAR Attend hearing on preliminary injunctions (no charge) Case 4:14-cv-00815-BCW Document 194-2 Filed 12/05/14 Page 18 of 18