Doc1031 pay day for lynn tillotson pinker & cox $189,945.99

1 #4814-6499-0756

Jeffrey M. Tillotson, P.C. ([email protected]) Texas Bar No. 20039200 Eric W. Pinker, P.C. ([email protected]) Texas Bar No. 16016550 John Volney ([email protected]) Texas Bar No. 24003118 LYNN TILLOTSON PINKER & COX, L.L.P. 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE

IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION In re: § Chapter 11 § FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH § Debtor. § ______________________________________________________________________________

FOURTH APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES

INCURRED FROM MAY 1, 2014 THROUGH MAY 31, 2015 ______________________________________________________________________________

NO HEARING WILL BE CONDUCTED ON THIS APPLICATION UNLESS A WRITTEN RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT, 1100 COMMERCE STREET, SUITE 1254, DALLAS, TEXAS 75242, BEFORE 5:00 P.M. PREVAILING CENTRAL TIME ON JULY 7, 2015, (THE “OBJECTION DEADLINE”), WHICH IS AT LEAST TWENTY-FOUR DAYS AFTER THE DATE OF SERVICE OF THIS APPLICATION. ANY RESPONSE MUST BE IN WRITING AND FILED WITH THE CLERK, AND A COPY MUST BE SERVED UPON THE UNDERSIGNED COUNSEL PRIOR TO THE DATE AND TIME SET FORTH ABOVE. IF A RESPONSE IS TIMELY FILED, A HEARING MAY BE HELD WITH NOTICE ONLY TO THE OBJECTING PARTY. IF NO RESPONSE TO THIS APPLICATION IS TIMELY FILED, THE RELIEF SOUGHT HEREIN SHALL BE DEEMED TO BE UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING SUCH RELIEF.

Case 09-33918-hdh11 Doc 1031 Filed 06/11/15 Entered 06/11/15 12:36:39 of 19

mailto:[email protected]



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Lynn Tillotson Pinker & Cox, LLP (“LTPC,” the “Firm” or the “Applicant”), special

litigation counsel to Matthew D. Orwig, the liquidating Trustee (“Trustee”) for the estate of

FirstPlus Financial Group, Inc. (the “Debtor”), files this Fourth Application of Lynn Tillotson

Pinker & Cox, LLP for Allowance of Compensation and for payment of Expenses Incurred from

May 1, 2014 through May 31, 2015 (this “Application”).

I. SUMMARY OF APPLICATION

By this Application, LTPC seeks approval for payment of its attorney’s fees in the

amount of $183,333.33, which reflects LTPC’s one-third contingency fee interest in the

Trustee’s settlement with Buckno Lisicky & Company, P.C. and Anthony Buczek, which has

been filed for approval by this Court pursuant to Bankruptcy Rule 9019. [Docket No. 1029]. In

addition to its contingency fee, LTPC requests reimbursement of its expenses incurred from

May 1, 2014 through May 31, 2015 (the “Application Period”) in the amount of $6,542.66. The

total amount sought by LTPC in this Application is $189,875.99. For the reasons set out below,

LTPC respectfully requests that the Court grant this Application.

II. JURISDICTION AND VENUE

1. The Court has jurisdiction over the relief requested in this Application pursuant to

28 U.S.C. § 1334(a) and (b). Venue is proper in this District pursuant to 28 U.S.C. §§ 1408 and

1409(a).

2. The statutory predicates for the relief requested herein are 11 U.S.C. §§ 327-328

and 330 and Fed. R. Bankr. P. 2016.


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III. BACKGROUND

3. On June 23, 2009, FirstPlus Financial Group, Inc. (“Debtor”) filed its petition for

relief under Chapter 11 of the United States Code.

4. On July 24, 2009, the Court entered its Order appointing Matthew D. Orwig as

the Liquidating Trustee for the Debtor.

5. On April 29, 2011, the Trustee filed an application to employ LTPC as special

counsel to the Trustee in this Bankruptcy Case. [Docket No. 565].

6. On May 12, 2011, the Court entered its order granting the application and

authorizing employment of LTPC. [Docket No. 572]. As relevant to this Application, the

Court’s Order authorized the Trustee to employ LTPC as Special Litigation Counsel to evaluate

and pursue claims against the former professionals, fiduciaries and others affiliated with Debtor.

The Order provided that LTPC would be paid (1) a reduced hourly rate up to a total of $25,000

to evaluate the potential claims and then (2) one-third of any net monetary recovery by the Estate

pursuant to a standard contingency fee arrangement if claims were pursued. The Order further

provided that LTPC would credit the estate for any payment made pursuant to the reduced hourly

arrangement in the event that LTPC recovered under the contingency fee arrangement, which

credit was taken when the Court approved LTPC’s Second Application. [Docket No. 572].

Under the Court’s order, all compensation for fees and expenses were made subject to Court

approval under section 330 of the Bankruptcy Code, the federal and local rules of bankruptcy

procedures, and other applicable guidelines and case law. LTPC’s Application is supported by

the Affidavit of John Volney attached as Exhibit A.


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A. Summary of Work Performed and Results Achieved.

7. In June 2011, the Trustee (represented by LTPC) filed Adversary Proceeding

No. 11-03397 against former professionals and others affiliated with Debtor, including Buckno

Lisicky & Company, P.C. and Anthony Buczek. Mr. Buczek and Buckno Lisicky & Company,

P.C. answered the lawsuit and filed motions to dismiss and to withdraw the reference in January

2015. After responding to the various motions filed by the referenced defendants, the Trustee

negotiated and reached a monetary settlement with Buckno Lisicky & Company, P.C. and

Anthony Buczek in the amount of $550,000.00. On May 6, 2015, the Trustee filed his motion

for order approving the settlement. [Docket No. 1029].

B. Summary of Expenses Incurred.

8. In providing professional services to the Trustee, LTPC has incurred actual and

necessary expenses in satisfaction of which LTPC has advanced and disbursed funds, and for

which LTPC now requests reimbursement. As set forth in the invoice attached as Exhibit B, the

actual and necessary expenses incurred by LTPC on behalf of the Trustee during the Application

Period amount to $6,542.66. The expenses incurred by LTPC are charged at the actual cost by

LTPC on a pass-through basis, with no mark-up or profit by LTPC. The expenses sought to be

reimbursed include the following categories:

• Transcripts from Crim. Trial $3,571.50 • Westlaw/Internet Search Service $1,005.86 • Copies/Duplication Costs $ 4.20 • Postage $ 175.34 • Court Parking $ 8.00 • Travel Expenses for Attendance at Criminal Trial $1,777.76

Total: $6,542.66

The Invoice sets forth the date the expense was incurred or billed and the nature and

amount of the expense. No request is made for overhead expenses. The bulk of the expenses


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sought to be reimbursed is related to obtaining transcripts of certain testimony from the parallel

criminal trial, which the undersigned counsel believed was necessary to successfully evaluate the

case for settlement. Travel expenses were incurred in connection with attending closing

arguments at the criminal trial. Copies were necessary to serve pleadings on various parties and

to disseminate documents to various interested parties. Throughout this case, pleadings have

been served on the parties in interest. A copy service was used when it could provide services

more cheaply than LTPC could provide the same services in-house. LTPC incurred postage

charges in connection with service of documents on certain defendants who are not subscribers

to the Court’s ECF system. Computerized research has been utilized only when a professional

believes that the benefits of computerized research outweigh the cost of such research and that

the costs will be less than those incurred in utilizing more traditional research methods.

Necessary computerized research was extensive.

IV. RELIEF REQUESTED

9. By this Application, LTPC respectfully requests that the Court allow

compensation for professional services rendered by LTPC during the Application Period

pursuant to 11 U.S.C. § 330. In total, this Application requests allowance of compensation in the

amount of $183,333.33, along with expenses incurred during the Application Period of

$6,542.66 , for a total requested allowance of $189,875.99.

10. The Bankruptcy Code specifically authorizes the bankruptcy court to approve the

employment and compensation of special counsel on a contingency fee basis. 11 U.S.C.

§ 328(a); Daniels v. Barron (In re Barron), 325 F.3d 690 (5th Cir.2003) (“Under 11 U.S.C.

§ 330, attorneys’ fees are reviewed for their reasonableness after representation has concluded.

In contrast, Section 328 ... allows an attorney seeking to represent a bankruptcy estate to obtain


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prior court approval of her compensation plan.”). As explained above, the Trustee (represented

by LTPC) filed suit against and then settled with Buckno Lisicky & Company, P.C. and Anthony

Buczek in cash. Upon approval of the settlement, the net monetary recovery to the Liquidating

Trust will be $550,000.00, with LTPC owed a contingent fee of $183,333.33.

11. To the extent that Court considers the factors listed in Johnson v. Georgia

Highway Express, Inc., 488 F.2d 714, 717–19 (5th Cir. 1974) (the “Johnson Factors”) in

evaluation LTPC’s requested contingent fee, those factors support the award.

12. The Time and Labor Required. LTPC’s fee was a contingent fee for the work

performed. LTPC provided its services efficiently to allow the Trustee to continue this

bankruptcy case without undue delay.

13. The Novelty and Difficulty of the Questions Presented. LTPC’s employment

required them to perform services within their area of expertise, namely litigating business tort

claims against Debtor’s former lawyer and his law firm.

14. The Skill Required to Perform the Services. LTPC believes that its skill in

litigating business tort claims such as the claims alleged against Buckno Lisicky & Company,

P.C. and Anthony Buczek contributed substantially to the settlement.

15. Preclusion of Other Employment Due to Acceptance of the Case. While

LTPC has devoted substantial time and effort to its representation of the Trustee in the adversary

proceeding, LTPC has not been precluded from accepting other employment.

16. The Customary Fee. The amount of compensation sought herein has been

computed pursuant to a customary contingent fee. The fee charged for LTPC’s services in this

case is equal to or less than the rates charged by other professionals of similar reputation.


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17. Whether the Fee is Fixed or Contingent. LTPC’s fee is set according to the

contingent fee agreement, as previously approved by the Court.

18. Time Limitations Imposed by the Client or Other Circumstances. The best

interests of the creditors were served by pushing the case and settlement forward in order to

minimize expenses.

19. The Experience, Reputation, and Ability of the Applicant. LTPC submits that

it is respected for its skill in litigating business disputes. It is the Applicant’s belief that its

reputation is recognized and respected.

20. The “Undesirability” of the Case. Working on behalf of the Trustee in this case

has not been undesirable. However, LTPC’s fee is subject to approval by the Court and is

contingent upon a recovery.

21. The Nature and Length of the Professional Relationship with the Client.

LTPC worked with the Trustee throughout the existence of the adversary proceeding. LTPC had

no prior dealings with the Debtor or the Trustee.

22. The Amount Involved and the Results Obtained. The amount of LTPC’s

contingent fee is calculated pursuant to the methodology previously approved by the Court.


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V. COMPLIANCE WITH FED. R. BANK. P. 2016(a)

23. LTPC does not now hold or represent, and has not held or represented at any time

during the Application Period or otherwise, any interest adverse to the Trustee or the Estate with

respect to the matters for which it has been employed. LTPC is now, and has at all times

material hereto been, a “disinterested person” as that term is used and defined in the Bankruptcy

Code.

24. This is LTPC’s Fourth Application for payment of attorney’s fees and

reimbursement of expenses. LTPC received $1,290,447.00 in attorney’s fees and expenses

pursuant to its First, Second, and Third Applications.

25. No agreement or understanding exists between the Applicant and any other entity

for sharing of compensation received or to be received for services rendered in or in connection

with this Bankruptcy Case. Applicant shall not share or agree to share with any other entity the

compensation awarded in connection with this Application, if any.

26. No agreement or understanding prohibited by 18 U.S.C. § 155 has been made, or

will be made, by LTPC.

VI. NOTICE

27. A copy of this Application, together with exhibits, is being transmitted, inter alia,

(i) electronically by the Clerk of Court through the CM/ECF system to all parties receiving such

notice in this Bankruptcy Case and (ii) to the Office of the United States Trustee. A copy of this

Application without exhibits is being sent via regular United States mail, postage prepaid, to the

parties appearing on the master mailing matrix for this case. Accordingly, all parties entitled to

receive notice of this Application have received such notice. LTPC respectfully submits that no

additional notice of this Application is necessary under the circumstances.


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28. Any party that was not served with a copy of the exhibits to this Application

may obtain a copy of such exhibits by mailing a written request to the undersigned counsel

on or before the Objection Deadline set forth on the first page of this Application.

VII. PRAYER

BASED UPON THE FOREGOING, LTPC respectfully requests that the Court enter an

order in substantially the form of that attached hereto as Exhibit C:

i. granting this Application;

ii. allowing compensation for professional services rendered by LTPC asspecial counsel to the Trustee during the Application Period in the totalamount of $183,333.33;

iii. allowing reimbursement of LTPC’s expenses in the amount of $6,542.66;and

iv. awarding Applicant such other and further relief to which it may be justlyentitled.

Date: June 11, 2015 Respectfully submitted,

/s/ John Volney Jeffrey M. Tillotson, P.C. ([email protected]) Texas Bar No. 20039200 Eric W. Pinker, P.C. ([email protected]) Texas Bar No. 16016550 John Volney ([email protected]) Texas Bar No. 24003118 LYNN TILLOTSON PINKER & COX, L.L.P. 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile

ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE





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CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served either via ECF on counsel of record or via first class United States mail, prepaid, on the attached Limited Service List on June 11, 2015.

/s/ John Volney John Volney


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Jeffrey M. Tillotson, P.C. ([email protected]) Texas Bar No. 20039200 Eric W. Pinker, P.C. ([email protected]) Texas Bar No. 16016550 John Volney ([email protected]) Texas Bar No. 24003118 LYNN TILLOTSON PINKER & COX, L.L.P. 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile

ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE


DALLAS DIVISION

In re: § Chapter 11 §

FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH §

Debtor. § ______________________________________________________________________________

AFFIDAVIT OF JOHN VOLNEY IN SUPPORT OF THE FOURTH APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF COMPENSATION

AND FOR REIMBURSEMENT OF EXPENSES ______________________________________________________________________________

STATE OF TEXAS § §

COUNTY OF DALLAS §

BEFORE ME, the undersigned authority, on this date appeared John Volney (“Affiant”) and, after having been first duly sworn, stated as follows:

1. “My name is John Volney. I am over the age of twenty-one (21) and competentin all respects to make this Affidavit. This Affidavit is being filed in support of the Fourth Application of Lynn Tillotson Pinker & Cox, LLP for Allowance of Compensation and for Reimbursement of Expenses (the “Application”) filed contemporaneously herewith.

2. I am making this Affidavit on behalf of Lynn Tillotson Pinker& Cox, LLP(“LTPC”). I am a partner at LTPC and I am authorized to make this affidavit on behalf of LTPC.

3. Pursuant to the Court’s order of May 12, 2011, LTPC was retained by MatthewD. Orwig, the Liquidating Trustee (the “Trustee”) for the estate (the “Estate”) of FirstPlus Financial Group, Inc. (the “Debtor”) as Special Litigation Counsel pursuant to a reduced hourly and contingent fee arrangement.

EXHIBIT A





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4. I am the professional designated by the Firm with responsibility for compliance with the applicable Guidelines for Compensation and Expense Reimbursement of Professionals promulgated by the Court and by the Office of the United States Trustee.

5. I have read the Application. To the best of my knowledge, information, and belief, the compensation and expense reimbursement sought therein is in substantial and satisfactory conformity with the Guidelines.

6. As relevant to this application, LTPC is to be paid a one-third contingency fee based on the net monetary recovery that LTPC obtains for the Estate against former professionals and fiduciaries of Debtor and others, less the amount previously paid to LTPC pursuant to its reduced hourly fee arrangement. The amount previously paid to LTPC pursuant to its reduced hourly fee arrangement was recouped in connection with LTPC’s Second Application and is therefore not relevant to this Fourth Application.

7. LTPC assisted the Trustee in the matters described in the Application. The work LTPC performed was reasonable and was necessary to comply with its representation of the Trustee in Adversary Proceeding No. 11-03397. LTPC brought suit against (among others) Buckno Lisicky & Company, P.C. and Anthony Buczek for alleged accounting malpractice, conspiracy, and other claims. After Buckno Lisicky & Company, P.C. and Anthony Buczek filed motions to dismiss, and after responses were filed on behalf of the Trustee, the Trustee represented by LTPC had extensive settlement negotiations with those defendants, which resulted in the parties’ reaching a negotiated settlement. On May 6, 2015, the Trustee filed his motion seeking approval of his settlement with Buckno Lisicky & Company, P.C. and Anthony Buczek. Upon approval of the settlement and payment of settlement proceeds, the net monetary recovery to the Estate will be $550,000.00. LTPC’s contingent fee based on that recovery is $183,333.33, which is one-third of the recovery.

8. The contingent fee LTPC charged in this matter is less than or equal to its customary fees. I am generally familiar with the rates charged by other law firms for services such as those that LTPC performed for the Trustee. The contingent fee LTPC charged in this matter is less than or equal to those charged by comparable professionals for similar services.

9. Attached to the Application as Exhibit B is a true and correct copy of the Firm’s invoice for expenses incurred during the Application Period in connection with its role as special litigation counsel to the Trustee this case (the ‘Invoice’).


Attorneys and Counselors2100 ROSS AVE., SUITE 2700

Dallas, TX 75201214-981-3800

Invoice submitted to:

Jones DayAttn. Matthew D. Orwig, Trustee2727 N. Harwood St.Dallas, TX 75201

June 10, 2015

Invoice #: 20150980

In ReferenceTo:

FirstPlus Financial Group, Inc. Trustee ActionOur Client/Matter No.: 02372-101.

Tax I.D.#: 75-2507536

LYNN TILLOTSON PINKER & COX, L.L.P.

TERMS: NET 30 DAYS

Additional charges:

Amount

5/31/2014 174.68Westlaw Research for May 2014.

6/9/2014 53.60Reimbursement paid to Mr. Volney for travel expenses for trial in NewJersey ($40 airport parking, $13.60 for meal for Mr. Volney and B.Ghorayeb, $10.00 in tolls).

6/22/2014 1,077.00Airfare for FirstPlus Criminal trial in PA, 5/30/14.

40.00Meal for Mr. Volney during FirstPlus Criminal trial in PA, 6/3/14.

300.46Hertz car rental during FirstPlus Criminal trial in PA, 6/4/14.

306.70Hotel fee for Mr. Volney during FirstPlus Criminal trial in PA, 6/5/14.

6/30/2014 4.20Copy charges.

84.62Postage fees.

7/31/2014 2.40Postage fees.

8/18/2014 1,500.00Reimbursement paid to Mr. Volney for Anthony Buczek transcripts.

8/31/2014 0.48Postage fees.

9/29/2014 2,071.50Fee for transcripts of David Roberts and Robert O'Neal made payable to CarlNami.

EXHIBIT B


Jones Day 2Page

Amount

9/30/2014 71.98Westlaw Research for September 2014.

10/31/2014 0.48Postage fees.

11/30/2014 469.78Westlaw research for November 2014.

1/20/2015 8.00Reimbursement for Mr. Volney for parking at courthouse for statusconference, 1/13/15.

2/28/2015 149.11Westlaw research for February 2015.

3/31/2015 45.03Westlaw research for March 2015.

5/31/2015 87.36Postage fees.

95.28Westlaw research for May 2015

Total costs $6,542.66

Lynn Tillotson Pinker & Cox, L.L.P. - Tax I.D. #: 75-2507536.


1 #4851-3907-7924


DALLAS DIVISION

In re: § Chapter 11 §

FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH §

Debtor. §

ORDER ALLOWING FOURTH APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF

COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MAY 1, 2014 THROUGH MAY 31, 2015

Came on for consideration on July ___, 2015, the Fourth Application of Lynn Tillotson

Pinker & Cox, LLP for Allowance of Compensation and Reimbursement of Expenses (the

“Application”) filed on June 11, 2015 [Docket No. ____]. After due notice and hearing, this

Court having considered such Application, the representations of Lynn Tillotson Pinker & Cox,

LLP and all matters on file, the Court finds and concludes that the fees and expenses set forth in

the Application are reasonable and necessary and good cause exists for the allowance thereof.

EXHIBIT C


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The Court finds that all necessary parties were served with notice of the Application, that no

further notice need be given, and that no objection or responsive pleading was filed. It is

therefore,

ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded Attorney’s

Fees in the amount of $183,333.33 representing its contingency fee interest of the Liquidating

Trust’s settlement with Buckno Lisicky & Company, P.C. and Anthony Buczek. It is further

ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded

Reimbursement of Expenses in the amount of $6,542.66. It is further

ORDERED that the Trustee is hereby authorized to pay Lynn Tillotson Pinker & Cox,

LLP the amount of $189,875.99 as fourth interim payment.

### END OF ORDER###

Order drafted by:

John Volney ([email protected]) Lynn Tillotson Pinker & Cox, LLP 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile

Attorney for Matthew D. Orwig, Liquidating Trustee for the Estate of FirstPlus Financial Group, Inc.



James L. Schutza 7920 Belt Line Road, Suite 650 Dallas, Texas 75254

Prober & Raphael, A Law Corporation P. O. Box 4365 Woodland Hills, CA 91365-4365

FirstPlus Financial Group, Inc. PO Box 142979 Irving, TX 75014

Aaron Michael Kaufman George H. Tarpley Cox Smith Matthews , Inc. 1201 Elm St., Ste. 3300 Dallas, TX 75270

Scott F. Mascianica Sonnenschein Nath & Rosenthal 2000 McKinney Ave., Ste 1900 Dallas, TX 75201

Jo Christine Reed SNR Denton US LLP 1221 Avenue of the Americas New York, NY 10020

Erin Marie Schmidt United States Trustee 1100 Commerce Street, Room 976 Dallas, TX 75242

William Topp Maxwell #71944-279 Federal Detention Center P.O. Box 562 Philadelphia, PA 19106

Internal Revenue Service Spec. Procedures – Insolvency P.O. Box 21126 Philadelphia, PA 19114

Hulse & Stucki Attn: Jay R. Stucki 2912 West Story Road Irving, TX 75038

James W. Puzey Law Offices Of James W. Puzey P.O. Box 70172 Reno, NV 89570

John Clarson 4200 Ranier Court Fort Worth, TX 76109

Patrick John Hethcoat 1365 Wayne Way San Mateo, CA 94403-1565

George H. Tarpley Cox Smith Matthews Inc. 1201 Elm St., # 3300 Dallas, TX 75270

Eric A. Liepins Eric A. Liepins, P.C. 12770 Coit Road, Suite 950 Dallas, TX 75251

Jerry C. Carter Jenkins & Carter 501 Hammill Lane Reno, NV 89511

Securities & Exchange Commission c/o Rose L. Romero, Reg. Dir. Burnett Plaza, Suite 1900 801 Cherry Street, Unit 18 Fort Worth, TX 76102

Arkadiy Grinshpun 7909 Bustleton Avenue Philadelphia, PA 19152

Firstline Mortgage v. Rutgers c/o Robert Johnson Law Corp 34197 Pacific Coast Hwy, Ste 100 Dana Point, CA 92629

Buckno Lisicky & Company Attn: Tony Buckno 1524 Linden Street Allentown, PA 18102-4251

Robert O’Neal 324 N . 23rd Street Beaumont, TX 77707

Laurie Spindler Huffman Linebarger, et al. 2323 Bryan Street, Suite 1600 Dallas , TX 75201

Michael A. McConnell Kelly Hart & Hallman PC 201 Main Street, Suite 2500 Fort Worth, Texas 76102

Nathan Jenkins Jenkins & Carter 501 Hammill Lane Reno, NV 89511

Gary B. Freedman 7909 Bustleton Avenue Philadelphia, PA 19152

Patton Boggs Attn: Cass Weiland, Esq. 2000 Mckinney Ave, Suite 1700 Dallas , TX 75201

Downey Brand LLP 427 West Plumb Lane Reno, NV 89509

Secore &Waller, LLP Attn: Wayne M. Secore 12222 Merit Dr., # 1350 Dallas, TX 75251

Rutgers Investment 3965 Phelan Blvd, # 209 Beaumont, TX 77707-2232

Angela Dodd Securities And Exchange Comm. 175 W Jackson Blvd, Ste 900 Chicago, IL 60604

James P. Hanson 5824 Cold Water Drive Castro Valley, CA 94552-1807

Ronald J. Miller 772 Westray Dr. Westerville, OH 43081

Daniel J. Sherman Sherman & Yaquinto, LLP 509 N. Montclair Avenue Dallas, TX 75208

Lepercq Corporate Income Fund David Staber/Clayton Ketter Akin Gump, et al., LLP 1700 Pacific Ave., #4100 Dallas, TX 7520 1

SERVICE LISTCase 09-33918-hdh11 Doc 1031 Filed 06/11/15 Entered 06/11/15 12:36:39 of 19

Daniel P. Elms/Heather Bell Nunnally & Martin LLP 1400 One McKinney Plaza 3232 McKinney Avenue Dallas, TX 75204-2429

Bowne of Dallas, L.P. c/o Gail B. Price, Bronwen Price 2600 Mission St., # 206 San Marino, CA 91108 Justin L. Payne, Attorney 6777 Camp Bowie Blvd. Suite 215 Fort Worth, TX 76116

James Hanson Sherman & Yaquinto, L.L.P. 509 N. Montclair Avenue Dallas, TX 75208-5498 Derrel Luce Law Office of Derrel Luce 4600 Bosque, Suite 2B Waco, Texas 76710

All other parties on the electronic service list.


Doc1031 pay day for lynn tillotson pinker & cox $189,945.99

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