2025-01-23 DIP Financing - Benjamin Carson Reimburs (Doc 333)Case 24 -11647 -MFW Doc 333 Filed 01/23/25 Page 1 of 8
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development Company, et al.,
Debtors.'
Chapter 11
Case No. 24-11647 (MFW)
(Jointly Administered)
Objection Deadline: February 13, 2025
SUMMARY OF FOURTH MONTHLY APPLICATION OF LAW OFFICES OF
BENJAMIN M. CARSON, P.C, AS CO -COUNSEL TO THE DEBTORS AND
DEBTORS IN POSSESSION, FOR ALLOWANCE OF COMPENSATION
AND REIMBURSEMENT OF EXPENSES INCURRED FOR THE
PERIOD FROM NOVEMBER 1, 2024, THROUGH NOVEMBER 30, 2024
Name of Applicant: The Law Offices of Benjamin M. Carson, P.0
Authorized to Provide Professional Services to: Debtors and Debtors in Possession
Date of Retention:
Period for which compensation and
reimbursement is sought:
Amount of compensation sought as
actual, reasonable and necessary:
August 5, 2024 (order entered September 13, 2024)
November 1, 2024 through November 30, 2024
$73,670.00
Amount of expense reimbursement sought
as actual, reasonable and necessary: N/A
'The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification
number, as applicable, are:. SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996), SilverRock
Lifestyle Residences, LLC (0721), SilverRock Lodging, LLC, (4493), SilverRock Luxury Residences, LLC (6598)
and SilverRock Phase 1, LLC (2247). The location of the Debtors' principal place of business and the Debtors'
mailing address is 343 Fourth Avenue, San Diego, CA 92101.
1
Case 24 -11647 -MFW Doc 333 Filed 01/23/25 Page 3 of 8
COMPENSATION BY INDIVIDUAL
Name of
Professional Person
Position of the Applicant,
Number of Years in that
Position, Prior
Relevant Experience, Year of
Obtaining License to Practice,
Area of Expertise
Hourly
Billing
Rate ($)
Total
Billed
Hours
Total
Compensation ($)
Benjamin M. Carson
Attorney, licensed to
practice since 2012, with
expertise in commercial
bankruptcy and
restructuring.
$375.00
98.00h
$36,750.00
Victor A. Vilaplana
Senior Counsel, licensed to
practice since 1973, with
expertise in commercial
bankruptcy and
restructuring.
$650.00
56.80h
$36,920.00
3
Case 24 -11647 -MFW Doc 333 Filed 01/23/25 Page 5 of 8
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development Company, LLC et
al.,
Debtors.2
Chapter 11
Case No. 24-11647 (MFW)
(Jointly Administered)
Objection Deadline: February 13, 2025
FOURTH MONTHLY APPLICATION OF LAW OFFICES OF BENJAMIN M.
CARSON, P.C., AS CO -COUNSEL TO THE DEBTORS AND
DEBTORS IN POSSESSION, FOR ALLOWANCE OF COMPENSATION AND
REIMBURSEMENT OF EXPENSES INCURRED FOR THE PERIOD FROM
NOVEMBER 1 THROUGH NOVEMBER 30, 2024
Pursuant to sections 330 and 331 of title 11 of the United States Code, 11 U.S.C. §§ 101 et
seq. (the "Bankruptcy Code"), and rule 2016 of the Federal Rules of Bankruptcy Procedure, and
in accordance with that certain Order Authorizing the Retention and Employment of Law Offices
of Benjamin M Carson, P.C. as Bankruptcy Co -Counsel for the Debtors, Nunc Pro Tunc to the
Petition Date [Docket No. 102] (the "Retention Order") and that certain Order, Pursuant to
Sections 105(a) and 331 of the Bankruptcy Code, Bankruptcy Rule 2016(a), and Local Rule 2016-
2, Establishing Procedures for Interim Compensation and Reimbursement of Professionals
[Docket No. 108] (the "Interim Compensation Order"), the law firm of Law Offices of Benjamin
M. Carson, P.C. ("Firm") hereby applies (this "Application") to the United States Bankruptcy
Court for the District of Delaware (the "Court") for reasonable compensation for professional legal
services rendered as counsel to the above -captioned debtors and debtors in possession (together,
2The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification
number, as applicable, are: SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996), SilverRock
Lifestyle Residences, LLC (0721), SilverRock Lodging, LLC, (4493), SilverRock Luxury Residences, LLC (6598)
and SilverRock Phase 1, LLC (2247). The location of the Debtors' principal place of business and the Debtors'
mailing address is 343 Fourth Avenue, San Diego, CA 92101.
5
Case 24 -11647 -MFW Doc 333 Filed 01/23/25 Page 7 of 8
7. Attorneys Carson and Vilaplana have collectively expended a total of 154.8 hours
in connection with this matter during the Monthly Fee Period.
8. The amount of time spent by Carson and Vilaplana, respectively, is fully set forth
in the detail attached hereto as Exhibit A. These are Carson and Vilaplana's normal hourly rates
of compensation for work of this character. The reasonable value of the services rendered by
Carson and Vilaplana for the Monthly Fee Period as counsel for the Debtors in these cases is
$73,670.00.
9. Firm believes that the time entries included in Exhibit A attached hereto is in
compliance with the requirements of Local Rule 2016-2.
10. In accordance with the factors enumerated in section 330 of the Bankruptcy Code,
the amount requested is fair and reasonable given (a) the complexity of these chapter 11 cases, (b)
the time expended, (c) the nature and extent of the services rendered, (d) the value of such services,
and (e) the costs of comparable services other than in a case under chapter 11 of the Bankruptcy
Code.
11. This Application covers the fee period from November 1, 2024, through and
including November 30, 2024. Finn has continued, and will continue, to perform additional
necessary services for the Debtors subsequent to the Monthly Fee Period, for which Firm will file
subsequent monthly fee applications.
[Remainder of page intentionally left blank]
7
Case 24 -11647 -MFW Doc 333-1 Filed 01/23/25 Page 1 of 1
VERIFICATION
I, Benjamin M. Carson, declare, pursuant to 28 U.S.C. § 1746, under penalty of perjury:
1. I am the attorney and principal for the applicant firm, Law Offices of Benjamin M.
Carson, P.C. ("Firm"), and have been admitted to this case on a pro hac vice basis.
2. I have personally performed many of the legal services rendered by Firm to the
debtors and debtors in possession in connection with their chapter 11 cases and am familiar with
the work performed by Senior Counsel Victor A. Vilaplana. Mr. Vilaplana and I are the only two
attorneys to perform work on behalf of the Firm.
3. The facts set forth in the foregoing Application are true and correct to the best of
my knowledge, information and belief.
Dated: January 23, 2025 /s/Benjamin M. Carson
BENJAMIN M. CARSON
Case 24 -11647 -MFW Doc 333-2 Filed 01/23/25 Page 2 of 2
PLEASE TAKE FURTHER NOTICE THAT ONLY IF AN OBJECTION IS
PROPERLY AND TIMELY FILED IN ACCORDANCE WITH THE ABOVE
PROCEDURES WILL A HEARING BE HELD ON THE APPLICATION.
Dated: January 21, 2025, The Law Offices of Benjamin M. Carson, P.C.
San Diego, California
/s/Benjamin M. Carson
Benjamin M. Carson (Pro Hac Vice)
Victor A. Vilaplana (Pro Hac Vice)
5965 Village Way Ste E105
San Diego, CA 92130
Phone:1-858-255-4529
ben@benjamincarsonlaw.com
Co -Counsel to the Debtors and
Debtors in Possession
2
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 2 of 27
11/01/2024 BC
11/01/2024 BC
11/01/2024 VV
11/01/2024 VV
11/01/2024 VV
11/01/2024 VV
case law pertaining to revised SARE
motion opposition.
Service Case Administration: SR -DC - Edited 0.50 $375.00 $187.50
working draft of SARE motion opposition.
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Communicated with
counsel for secured creditors, City of La
Quinta, and bankruptcy co -counsel on
adjournment of deadline for filing SARE
motion opposition.
Service Business Operations: SR -PI - Strategized 0.30 $650.00 $195.00
legal issues surrounding obtaining D&O
insurance for Independent Manager.
Service Fact Investigation / Development: SR -PI - 0.50 $650.00 $325.00
Strategized on possibility of secured
creditors voluntarily reconveying deeds of
trust and returning to preferred equity
status.
Service Business Operations: SR -PI - Strategized 0.30 $650.00 $195.00
on obtaining necessary signatures for
Independent Manager retention.
Service Business Operations: SR -PI - Strategized
on possible alternatives to D&O insurance
in advance of bringing independent
manager on board.
11/01/2024 VV Service Business Operations: PA789 - Reviewed
proposed amendment to operating
agreement for bringing in Independent
Manager.
0.20 $650.00
0.20 $650.00
$130.00
$130.00
11/01/2024 VV Service Case Administration: SR -DC - Reviewed 0.20 $650.00 $130.00
working draft of SARE motion opposition.
11/01/2024 VV Service Meetings of and Communications with 0.30 $650.00
Creditors: SR -DC - Strategized on
adjournment of deadline for filing SARE
motion opposition.
$195.00
11/02/2024 BC Service Pleadings: SR -DC - Worked on adversary 0.70 $375.00 $262.50
proceeding to avoid transactions conveying
deeds of trust on preferred equity holders'
prepetition.
11/02/2024 BC
Service Other Case Assessment, Development and 0.80 $375.00 $300.00
Administration: SR -PI - Prepared text of
proposed reconveyance agreement for
signature by preferred equity holders
converted to secured creditors prepetition.
Page 2 of 27
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 4 of 27
recent amendments to operating agreements
with bankruptcy co -counsel and counsel for
City of La Quinta.
11/04/2024 BC
Service Pleadings: PA789 - Reviewed fraudulent
transfer and avoidable preference complaint
with bankruptcy co -counsel.
11/04/2024 BC
0.30 $375.00
$112.50
Service Case Administration: PA789 - Edited 0.20 $375.00 $75.00
Operating Agreement amendment
following discussion with counsel for City
of La Quinta.
11/04/2024 VV Service Case Administration: SR -DC - Strategized 1.90 $650.00 $1,235.00
on finalizing retention of Independent
Manager.
11/04/2024 VV Service Case Administration: PA789 - Strategized 0.80 $650.00 $520.00
on recent amendments to operating
agreements.
11/04/2024 VV
11/05/2024 BC
11/05/2024 BC
11/05/2024 BC
11/05/2024 BC
11/05/2024 BC
Service Pleadings: PA789 - Reviewed and analyzed 0.30 $650.00 $195.00
fraudulent transfer and avoidable
preference complaint.
Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -DC - Call with Major
Constituents to bankruptcy case to discuss
case status, including SARE motion status.
Service Case Administration: SR -PI - Reviewed 0.70 $375.00 $262.50
Operating Agreement and attached
corporate formation documents to
determine necessary edits and signature
requirements.
Service Case Administration: SR -PI - Discussed 0.70 $375.00 $262.50
revised language and revised consent
requirements to substitute in Independent
Manager for SRPI with client, bankruptcy
co -counsel, counsel for City of La Quinta,
and counsel for Independent Manager.
Service Business Operations: SR -PI - Discussed 0.20 $375.00 $75.00
obtaining D&O insurance for Independent
Manager with client and CRO.
Service Business Operations: SR -PI - Discussed 0.50 $375.00 $187.50
with client issue pertaining to bank
threatening to close DIP accounts and
advised client as to next step forward.
11/05/2024 BC Service Case Administration: PA789 - Reviewed 0.80 $375.00 $300.00
operating agreement and attendant loan
docs to verify consent rights of lender prior
Page 4 of 27
11/06/2024 VV
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 6 of 27
Service Case Administration: SR -DC - Reviewed 0.30 $650.00 $195.00
Operating Agreement amendments
necessary prior to retaining Judge Sontchi
as independent manager.
11/06/2024 VV
Service Case Administration: SR -DC - Strategized 0.50 $650.00 $325.00
on revised operating agreement
amendments.
11/06/2024 VV
11/06/2024 VV
11/07/2024 BC
11/07/2024 BC
Service Business Operations: SR -DC - Strategized 0.30 $650.00 $195.00
on the Operating Agreements, ownership
structure, and need for outside signatures.
Service Other Case Assessment, Development and 0.10 $650.00 $65.00
Administration: SR -DC - Strategized on
obtaining D&O insurance policy for new
independent manager.
Service Meetings of and Communications with
Creditors: SR -DC - Discussed latest status
of DIP loan with client, bankruptcy co-
counsel, and City of La Quinta.
Service
11/07/2024 BC
Case Administration: SR -DC - Reviewed
and edited latest DIP Interim order and
Term Sheet to serve as a basis for next
interim funding.
0.50 $375.00 $187.50
1.00 $375.00 $375.00
Service Case Administration: SR -DC - Discussed 0.50 $375.00 $187.50
issues pertaining to DIP Term Sheet and
proposed new interim DIP funding order
with client and bankruptcy co -counsel.
11/07/2024 BC Service Case Administration: SR -DC - Discussed 0.50 $375.00 $187.50
strategies for preserving Debtors' Plan
filing exclusivity rights with client, City of
La Quinta counsel, and bankruptcy co-
counsel.
11/07/2024 BC
11/07/2024 BC
Service Case Administration: SR -PI - Discussed 0.30 $375.00 $112.50
revised interim DIP budget with client and
bankruptcy co -counsel.
Service Case Administration: SR -PI - Discussed 0.20 $375.00 $75.00
status of amending operating agreements to
bring on board Independent Manager with
counsel for Independent Manager.
11/07/2024 VV Service Meetings of and Communications with 0.50 $650.00 $325.00
Creditors: SR -DC - Strategized on the latest
status of DIP loan.
11/07/2024 VV
Service Case Administration: SR -DC - Strategized 0.50 $650.00 $325.00
on the DIP Term Sheet and proposed new
interim DIP funding order.
Page 6 of 27
11/08/2024 VV
11/08/2024 VV
11/09/2024 BC
11/09/2024 VV
11/10/2024 BC
11/10/2024 BC
11/10/2024 BC
11/10/2024 BC
11/10/2024 BC
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 8 of 27
on extending exclusivity.
Service Business Operations: SR -PI - Strategized 0.70 $650.00 $455.00
and reviewed DIP budget and upcoming
financial needs.
Service Case Administration: SR -DC - Strategized 0.30 $650.00 $195.00
on outstanding issues pertaining to
Operating Agreement amendments
necessary to substitute in Independent
Manager.
Service Plan of Reorganization: SR -DC - Discussed 0.50 $375.00 $187.50
realistic high-level options for confirmable
Chapter 11 plan with bankruptcy co-
counsel.
Service Plan of Reorganization: SR -DC -
Strategized on realistic high-level options
for confirmable Chapter 11 plan.
Service Case Administration: SR -PI - Reviewed
working draft of probably, upcoming
interim DIP budget and proposed final DIP
budget.
Service Case Administration: SR -PI - Prepared and
reviewed with bankruptcy co -counsel
agenda for upcoming meeting with
incoming Independent Manager.
0.50 $650.00 $325.00
0.30 $375.00 $112.50
0.50 $375.00
$187.50
Service Case Administration: SR -PI - Finalized text 0.50 $375.00 $187.50
for working drafts of all six operating
agreement amendments to substitute in
Independent Manager and possible
execution following morning.
Service Case Administration: SR -PI - Discussed 0.30 $375.00 $112.50
latest changes to working drafts of all six
operating agreement amendments with
counsel for Independent Manager.
Service Case Administration: SR -PI - Drafted fifth 0.30 $375.00 $112.50
interim CRO retention order in advance of
hearing to fmally retain CRO.
11/10/2024 BC Service Case Administration: SR -DC - Discussed 0.30 $375.00 $112.50
status of exclusivity and strategy for
extending exclusivity moving forward with
bankruptcy co -counsel.
11/10/2024 BC Service Case Administration: SR -DC - Reviewed, 0.50 $375.00 $187.50
with bankruptcy co -counsel, complaint
filed by City pre -bankruptcy against
various preferred equity holders of debtors
Page 8 of 27
11/11/2024 BC
11/11/2024 BC
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 10 of 27
latest draft of agreement engaging
independent manager.
Service Case Administration: SR -PI - Applied 0.30 $375.00 $112.50
additional edits to DIP loan documents,
including proposed DIP Credit Agreement
before sending back to counsel for City of
La Quinta.
Service Case Administration: SR -PI - Discussed
terms of DIP Credit agreement with
bankruptcy co -counsel.
11/11/2024 BC Service Meetings of and Communications with
Creditors: SR -PI - Communication with
Creditors -Discussed strategy for finalizing
DIP funding with City of La Quinta and
possible secured creditor contributor.
11/11/2024 BC
11/11/2024 BC
0.20 $375.00 $75.00
0.80 $375.00 $300.00
Service Case Administration: SR -LUX - Reviewed 0.20 $375.00 $75.00
initial draft of motion to extend exclusivity
period as provided by bankruptcy co-
counsel.
Service Case Administration: SR -LU - Reviewed
initial draft of motion to extend
assumption/rejection deadline as provided
by bankruptcy co -counsel.
0.20 $375.00 $75.00
11/11/2024 BC Service Case Administration: SR -LUX - Discussed 0.20 $375.00 $75.00
strategy for setting claims bar date with
bankruptcy co -counsel.
11/11/2024 BC Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -DC - Discussed construction
and prepetition secured debt issues with
Independent Manager and counsel for R.D.
Olson.
11/11/2024 VV
11/11/2024 VV
11/11/2024 VV
11/11/2024 VV
11/11/2024 VV
Service Case Administration: SR -DC - Strategized 0.30 $650.00 $195.00
on avoidable preference action.
Service Case Administration: SR -PI - Reviewed 0.10 $650.00 $65.00
edits to DIP loan documents, including
proposed DIP Credit Agreement.
Service Case Administration: SR -PI - Strategized 0.20 $650.00 $130.00
on terms of DIP Credit.
Service Case Administration: SR -LUX - 0.20 $650.00 $130.00
Strategized and reviewed initial draft of
motion to extend exclusivity period.
Service Case Administration: SR -LU - Strategized
on reviewed initial draft of motion to
Page 10 of 27
0.20 $650.00 $130.00
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 12 of 27
11/12/2024 VV
approve unwind agreements.
Service Meetings of and Communications with
Creditors: PA789 - Strategized on
implementing Operating Agreement
amendment allowing Independent Manager
to come on board.
11/12/2024 VV
11/12/2024 VV
11/13/2024 BC
11/13/2024 BC
11/13/2024 BC
11/13/2024 BC
Service Case Administration: PA789 - Reviewed
Operating Agreement amendment to lender
that would allow Independent Manager to
come on board.
Service Case Administration: PA789 - Reviewed
outline of 9019 motion to settle and
approve unwind agreements.
Service Meetings of and Communications with
Creditors: SR -PI - Prepared and dispatched
multiple settlement offers to former
preferred equity holders and unsecured
creditors to see if they will voluntarily
reconvey deeds of trust.
1.60 $650.00 $1,040.00
0.30 $650.00 $195.00
0.20 $650.00 $130.00
4.30 $375.00 $1,612.50
Service Case Administration: SR -PI - Worked on 1.00 $375.00 $375.00
draft of 9019 motion to settle avoidance
claims with Debtors' former preferred
equity holders and unsecured creditors.
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: PA789 - Communicated with
counsel for lender whose consent was
required to amend operating agreement and
bring independent manager on board.
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -LIFE - Communicated with
counsel for former preferred equity holder
of client regarding necessary amendment to
operating agreement to appoint
Independent Manager.
11/13/2024 BC
Service Meetings of and Communications with
Creditors: SR-LOD - Discussed interim and
final DIP facility with client and City of La
Quinta counsel.
1.00 $375.00
$375.00
11/13/2024 BC Service Case Administration: SR -DC - Reviewed 1.10 $375.00 $412.50
strategy for implementing a number of
immediately necessary tasks with
independent manager on board.
11/13/2024 VV Service Case Administration: SR -PI - Reviewed
draft of 9019 motion to settle avoidance
claims with Debtors' former preferred
Page 12 of 27
0.50 $650.00 $325.00
11/15/2024 BC
11/15/2024 BC
11/15/2024 BC
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 14 of 27
Service Meetings of and Communications with 0.80 $375.00 $300.00
Creditors: PA789 - Discussed unwind
agreements and reconveyance of deeds of
trust, fmalizing signatures, with client,
bankruptcy co -counsel, and multiple former
preferred equity holders.
Service Case Administration: SR -LIFE - Reviewed 0.50 $375.00 $187.50
operating agreement to determine potential
alternative to appointing independent
manager over objection of preferred equity
holder.
Service Case Administration: SR -LIFE -
Strategized with client and bankruptcy co-
counsel how to get independent manager on
board given issues raised by preferred
equity holder with consent rights.
11/15/2024 BC Service Case Administration: SR -DC - General
strategy discussion to review critical
upcoming tasks with client and bankruptcy
co -counsel.
1.10 $375.00 $412.50
0.50 $375.00 $187.50
11/15/2024 BC Service Case Administration: SR -DC - Discussed 0.50 $375.00 $187.50
settling potential dispute with secured
creditor in advance of filing DIP financing
motion.
11/15/2024 VV Service Professional Employment Application: SR- 0.20 $650.00 $130.00
PI - Reviewed September fee application
for filing.
11/15/2024 VV Service Meetings of and Communications with 0.80 $650.00 $520.00
Creditors: PA789 - Strategized on the
unwind agreements and reconveyance of
deeds of trust, finalizing signatures.
11/15/2024 VV
Service Case Administration: SR -LIFE -
Strategized on how to get independent
manager on board given issues raised by
preferred equity holder with consent rights.
1.10 $650.00
$715.00
11/15/2024 VV Service Case Administration: SR -DC - Strategized 0.50 $650.00 $325.00
on and reviewed critical upcoming tasks.
11/15/2024 VV Service Case Administration: SR -DC - Strategized 0.50 $650.00 $325.00
on settling potential dispute with secured
creditor in advance of filing DIP financing
motion.
11/16/2024 BC Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: PA789 - Back and forth
communication with preferred equity
holder regarding unwind agreement and
Page 14 of 27
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 16 of 27
creditors as settlement.
11/17/2024 BC Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Communicated with
unsecured creditors and preferred equity
holders regarding execution of unwind
agreements and reconveyance of deeds of
trust.
11/17/2024 BC Service Case Administration: SR -DC - Discussed 0.20 $375.00 $75.00
11/17/2024 BC
SARE opposition with client and
bankruptcy co -counsel.
Service Case Administration: SR -DC - Worked on
draft declaration for appraiser in support of
new DIP financing motion.
11/17/2024 VV Service Case Administration: SR -LIFE -
Strategized on issues with Lifestyle
Operating Agreement amendment.
0.50 $375.00 $187.50
1.60 $650.00 $1,040.00
11/17/2024 VV Service Case Administration: SR -LIFE - Reviewed 0.30 $650.00 $195.00
Operating Agreement amendment to
appoint new Manager.
11/17/2024 VV Service Case Administration: SR -DC - Strategized 0.20 $650.00 $130.00
on SARE opposition.
11/17/2024 VV Service Case Administration: SR -DC - Reviewed 0.30 $650.00 $195.00
draft declaration for appraiser in support of
new DIP financing motion.
11/18/2024 BC
11/18/2024 BC
Service Case Administration: SR -LIFE - Reviewed
Operating Agreement to re -determine legal
mechanism for amendment of clause stating
Manager cannot be removed.
0.50 $375.00
$187.50
Service Case Administration: SR -LIFE - Discussed 0.80 $375.00 $300.00
amending Operating Agreement with
bankruptcy co -counsel, counsel for
Independent Manager, and counsel for
Class A Preferred Members.
11/18/2024 BC Service Case Administration: SR-LOD - Reviewed 0.20 $375.00
motion to set claims bar date.
11/18/2024 BC Service Case Administration: SR-LOD - Discussed 0.20 $375.00
motion to extend exclusivity with
bankruptcy co -counsel.
11/18/2024 BC Service Analysis/Strategy: SR -DC - Reviewed 0.30 $375.00 $112.50
pleading standard for fraudulent transfer
and avoidance action claims.
$75.00
$75.00
11/18/2024 BC
Service Analysis/Strategy: SR -DC - Edited 0.30 $375.00 $112.50
Page 16 of 27
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 18 of 27
Strategized on motion to extend
exclusivity.
11/18/2024 VV Service Analysis Strategy: SR -DC - Reviewed 0.10 $650.00 $65.00
complaint for damages for avoidance and
fraudulent transfer claims.
11/18/2024 VV
11/18/2024 VV
11/18/2024 VV
Service Meetings of and Communications with 1.00 $650.00 $650.00
Creditors: SR -DC - Strategized on and
reviewed current major case updates.
Service Case Administration: SR -DC - Reviewed 0.10 $650.00 $65.00
draft declaration for appraiser in support of
upcoming DIP priming loan motion.
Service Case Administration: PA789 - Strategized 0.20 $650.00 $130.00
on completing settlement negotiations with
preferred equity holders and unsecured
creditors.
11/18/2024 VV Service Case Administration: PA789 - Reviewed 0.10 $650.00 $65.00
Rule 9019 motion to approve Unwind
Agreements as settlement.
11/18/2024 VV
11/19/2024 BC
Service Case Administration: PA789 - Reviewed
and analyzed application to employ
Independent Manager's counsel.
Service Case Administration: PA789 - Completed
first draft of complaint for avoidable
preference and fraudulent transfer claims.
11/19/2024 BC Service Case Administration: PA789 - Reviewed
multiple documents and agreement, with
bankruptcy co -counsel and counsel for
Independent Manager, regarding ownership
interest and operational control of Planning
Area 9.
11/19/2024 BC
11/19/2024 BC
0.10 $650.00 $65.00
.__.._...............................__...........
2.20 $375.00
1.10 $375.00 $412.50
$825.00
Service Meetings of and Communications with 0.70 $375.00 $262.50
Creditors: SR -LUX - Discussed draft of
motion to settle under Bankruptcy Rule
9019 with bankruptcy co -counsel counsel
for City of La Quinta.
Service Case Administration: SR -LUX - Back and 0.80 $375.00 $300.00
forth communication with various parties
agreeing to voluntarily reconvey deeds of
trust and client regarding unwind
agreements.
11/19/2024 BC Service Case Administration: SR -LIFE - 0.30 $375.00 $112.50
Communicated with client, bankruptcy co-
counsel and counsel for Series A Preferred
Membership Interest on appointing
Page 18 of 27
11/20/2024 VV
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 20 of 27
Creditors: SRDC - Strategized on
upcoming DIP financing and related issues.
Service Case Administration: SRDC - Reviewed 0.30 $650.00 $195.00
and analyzed operating agreement
amendment to substitute in independent
manager.
11/20/2024 VV Service Case Administration: PA789 - Strategized
on TIC agreement.
11/21/2024 BC Service Meetings of and Communications with
Creditors: SR -LIFE - Worked with client,
bankruptcy co -counsel, and counsel for
preferred equity holder on finalizing
Operating agreement amendment for
substituting in of independent manager.
11/21/2024 BC Service Business Operations: SR -PI - Discussed 0.10 $375.00 $37.50
status of DIP bank accounts with client.
0.50 $650.00 $325.00
0.70 $375.00 $262.50
11/21/2024 BC Service
11/21/2024 BC
11/21/2024 BC
11/21/2024 BC
11/21/2024 VV
Case Administration: SR -PI - Worked with 0.70 $375.00 $262.50
client to finalize October 2024 Monthly
Operating report.
Service Case Administration: SR -DC - Discussed 0.30 $375.00 $112.50
application for setting bar date with client
and bankruptcy co -counsel.
Service Case Administration: SR -DC - Chapter 11 0.80 $375.00 $300.00
case strategy meeting with client and
bankruptcy co -counsel.
Service
Meetings of and Communications with
Creditors: PA789 - Communicated with
former preferred equity holders regarding
unwind agreements and reconveying deeds
of trust.
0.30 $375.00
$112.50
Service Meetings of and Communications with
Creditors: SR -LIFE - Strategized for
preferred equity holder on finalizing
Operating agreement amendment for
substituting in of independent manager.
11/21/2024 VV
0.70 $650.00 $455.00
Service Case Administration: SR -DC - Strategized 0.30 $650.00 $195.00
on application for setting bar date.
11/21/2024 VV
11/22/2024 BC
Service Case Administration: SR -DC - Strategized 0.80 $650.00 $520.00
on Chapter 11 case.
Service Case Administration: SR -LIFE - Finalized 0.80 $375.00 $300.00
implementation of edits to SR Lifestyle
Operating Agreement amendment to bring
independent manager on board.
Page 20 of 27
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 22 of 27
11/24/2024 BC
11/24/2024 VV
11/25/2024 BC
11/25/2024 BC
11/25/2024 BC
11/25/2024 BC
11/25/2024 BC
11/25/2024 BC
11/25/2024 BC
Strategized on upcoming meeting with US
Trustee.
Service Case Administration: SR -PI - With 0.20 $375.00 $75.00
bankruptcy co -counsel discussed status of
early December motion filings and
potential issues to address with major
Constituents and US Trustee.
Service Case Administration: SR -PI - Strategized 0.20 $650.00 $130.00
on the status of early December motion
filings and potential issues to address with
major Constituents and US Trustee.
Service Meetings of and Communications with 0.70 $375.00 $262.50
Creditors: SR -LIFE - Discussed DIP
financing efforts and efforts to finalize
appointment of Independent Manager with
US Trustee.
Service Case Administration: SR -LIFE - 0.20 $375.00 $75.00
Communicated with counsel for
shareholder of SilverRock Lifestyle to
finalize appointment of Independent
Manager.
Service Case Administration: SR -LIFE - Edited
proposed final CRO Order.
Service Meetings of and Communications with
Creditors: SR -LIFE - Communicated with
US Trustee and Major Constituents
regarding content of final CRO Order.
Service Meetings of and Communications with
Creditors: SR -PI - Communicated with
client and former preferred equity holder on
voluntarily reconveying deed of trust.
Service Case Administration: SR -PI - Reviewed
proposed DIP Term Sheet with City of La
Quinta.
Service Business Operations: SR -PI - Discussed
transfer of bank accounts with client and
counsel for Bank of America.
0.30 $375.00 $112.50
0.20 $375.00 $75.00
0.30 $375.00
$112.50
0.20 $375.00 $75.00
0.30 $375.00 $112.50
11/25/2024 BC Service Business Operations: SR -PI - With 0.20 $375.00 $75.00
bankruptcy co -counsel, reviewed and edited
proposed communication with utility
provider of Project.
11/25/2024 BC Service Business Operations: SR -PI - Discussed 0.20 $375.00 $75.00
status of utility services for Project with
client.
Page 22 of 27
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 24 of 27
which Debtors can file plan of
reorganization.
11/26/2024 VV Service Case Administration: SR -DC - Strategized 0.80 $650.00 $520.00
on DIP financing.
11/26/2024 VV Service Case Administration: SR -DC - Reviewed 0.10 $650.00 $65.00
and analyzed revised DIP financing term
sheet from City of La Quinta.
11/26/2024 VV Service Business Operations: SR -PI - Reviewed 0.10 $650.00 $65.00
and analyzed communication between CRO
and utility service provider at Project.
11/26/2024 VV Service Case Administration: SR -LUX - Reviewed 0.20 $650.00 $130.00
motion to extend deadline to assume or
reject nonresidential lease.
11/27/2024 BC
11/27/2024 BC
11/27/2024 BC
11/27/2024 BC
Service Case Administration: SR -DC - With 1.70 $375.00 $637.50
bankruptcy co -counsel and client, applied
further edits to motion to extend exclusivity
period.
Service Case Administration: SR -DC - Applied
further edits to motion to extend
assumption/rejection deadline.
Service Meetings of and Communications with
Creditors: SR -DC - Discussed draft motion
to extend exclusivity with counsel for City
of La Quinta.
0.20 $375.00
$75.00
0.30 $375.00 $112.50
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -DC - Communicated
contents of motion to extend exclusivity
and assumption/rejection deadline with
counsel for Major Constituents.
11/27/2024 BC Service Meetings of and Communications with 0.10 $375.00 $37.50
Creditors: SR -PI - Communicated with
counsel for unsecured creditor regarding
claims bar date.
11/27/2024 BC
Service Business Operations: SR -PI - Reviewed 0.30 $375.00 $112.50
status of DIP bank accounts and threat of
bank to close accounts with client and
bankruptcy co -counsel
11/27/2024 BC Service Case Administration: SR -PI - Case
Administration -Reviewed latest draft of
DIP Term sheet with City of La Quinta.
11/27/2024 BC
0.30 $375.00 $112.50
Service Case Administration: PA789 - Reviewed
status of unwind agreements for 9019
motion with client and bankruptcy co -
Page 24 of 27
0.30 $375.00
$112.50
11/30/2024 BC
Case 24 -11647 -MFW Doc 333-3 Filed 01/23/25 Page 26 of 27
notice provision requirements for upcoming
motions with bankruptcy co -counsel.
Service Case Administration: SR -DC - Discussed 0.10 $375.00 $37.50
365 motion to extend deadline to assume/
reject nonresidential lease with bankruptcy
co -counsel.
11/30/2024 VV
11/30/2024 VV
11/30/2024 VV
11/30/2024 VV
Service Case Administration: SR -DC - Reviewed 0.30 $650.00 $195.00
declaration for Independent Manager in
support of motion to extend exclusive
period during which Debtors can file
Chapter 11 Plan.
Service Case Administration: SR -DC - Reviewed
motion to extend exclusive period during
which Debtors can file Chapter 11 Plan.
Service Case Administration: SR -DC - Strategized
on motion to extend exclusive period
during which Debtors can file Chapter 11
Plan.
Service Case Administration: SR -DC - Strategized
on notice provision requirements for
upcoming motions.
11/30/2024 VV Service Case Administration: SR -DC - Strategized
on 365 motion to extend deadline to
assume/reject nonresidential lease.
0.10 $650.00 $65.00
0.20 $650.00 $130.00
0.10 $650.00 $65.00
0.10 $650.00
Hours Subtotal
$65.00
154.8
Benjamin Carson
Victor Vilaplana
Statement of Account
Attorney
Senior Co -Counsel
98.0 $375.00 $36,750.00
56.8
Outstanding Balance New Charges
$87,357.00 + $73,670.00
Page 26 of 27
$650.00 $36,920.00
Hours Total 154.8
Subtotal $73,670.00
Total $73,670.00
Total Balance