2025-02-19 DIP Financing - Benjamin Carson SDC Co-Counsel Reimburs Dec. 2024Case 24-11647-MFW Doc 356 Filed 02/19/25 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:
March 12, 2025, at 4:00 P.M. (ET)
SUMMARY OF FIFTH 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 DECEMBER 1, 2024, THROUGH DECEMBER 31, 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)
December 1, 2024 through December 31, 2024
$51,865.00
Amount of expense reimbursement sought
as actual, reasonable and necessary: N/A
IThe 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.
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 2 of 8
This is a: X monthly final application
This application includes 0.5 hours and $215.00 in fees incurred in connection with
the preparation of Fee Applications.
Prior applications: N/A
2
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 3 of 8
COMPENSATION BY INDIVIDUAL
Name of
Professional Person
Position of the Applicant,
Number of Years in that
Position, Prior
Relevant Experience, Year of
Obtaining License to Practice,
Area of Expertise
Hourly
Billing
Rate ($)
Total
Billed
Hours
Total
Compensation ($)
Benjamin M. Carson
Attorney, licensed to
practice since 2012, with
expertise in commercial
bankruptcy and
restructuring.
$375.00
74.00h
$27,750.00
Victor A. Vilaplana
Senior Counsel, licensed to
practice since 1973, with
expertise in commercial
bankruptcy and
restructuring.
$650.00
37.10h
$24,115.00
3
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 4 of 8
COMPENSATION BY PROJECT CATEGORY
Project Category
Total Hours
Total Fees ($)
Analysis/Strategy
14.50h
$6,730.00
Meetings of and Communications with Creditors
15.40h
$6,957.50
Business Operations
0.50h
$187.50
Case Administration
80.20h
$37,775.00
Professional Employment Application
0.50h
$215.00
TOTAL
111.10h
$51,865.00
4
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 5 of 8
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development Company, et al.,
Debtors.2
Chapter 11
Case No. 24-11647 (MFW)
(Jointly Administered)
Objection Deadline:
March 12, 2025 at 4:00 P.M. (ET)
FIFTH 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
DECEMBER 1 THROUGH DECEMBER 31, 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,
'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.
5
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 6 of 8
the "Debtors"), in the amount of $51,865.00, for the period from December 1, 2024 through and
including December 31, 2024 (the "Monthly Fee Period"). In support of this Application, Firm
respectfully represents as follows:
BACKGROUND
1. On August 5, 2024 (the "Petition Date"), each of the Debtors filed a voluntary
petition with the Court under chapter 11 of the Bankruptcy Code.
2. Pursuant to the Retention Order, Firm was retained to represent the Debtors as
bankruptcy co -counsel in connection with these chapter 11 cases, effective as of the Petition Date.
The Retention Order authorizes Firm to be compensated on an hourly basis and to be reimbursed
for actual and necessary out-of-pocket expenses.
3. All services for which compensation is requested herein by Firm were performed
for or on behalf of the Debtors.
SUMMARY OF SERVICES RENDERED
4. Attached hereto as Exhibit A is a detailed statement of fees incurred during the
Monthly Fee Period, showing the amount of $51,865.00 due for fees.
5. The services rendered by Firm during the Monthly Fee Period are grouped into the
categories set forth in Exhibit A. The attorneys, Benjamin M. Carson ("Carson") and Victor A.
Vilaplana ("Vilaplana") who rendered services relating to each category are identified, along with
the number of hours for each individual and the total compensation sought for each category, in
the attachments hereto.
DISBURSEMENTS
6. Firm has not incurred out-of-pocket disbursements during the Monthly Fee Period.
6
Case 24-11647-MFW Doc 356 Filed 02/19/25 Page 7 of 8
VALUATION OF SERVICES
7. Attorneys Carson and Vilaplana have collectively expended a total of 111.1 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
$51,865.00.
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 December 1, 2024, through and
including December 31, 2024. Firm 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 356 Filed 02/19/25 Page 8 of 8
CONCLUSION
WHEREFORE, Firm requests that allowance be made to it in the sum of $51,865.00 as
compensation for necessary professional services rendered to the Debtors for the Monthly Fee
Period and requests such other and further relief as the Court may deem just and proper.
Dated: February 19, 2025
San Diego, CA
The Law Offices of Benjamin M. Carson, P.0
/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: (85 8)-255-4529
ben@benjamincarsonlaw.com
Co -Counsel to the Debtors and Debtors in
Possession
8
Case 24-11647-MFW Doc 356-1 Filed 02/19/25 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: February 19, 2025
/s/Benjamin M. Carson
BENJAMIN M. CARSON
9
Case 24-11647-MFW Doc 356-2 Filed 02/19/25 Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development Company, et al.,
Debtors.3
Chapter 11
Case No. 24-11647 (MFW)
(Jointly Administered)
Objection Deadline:
March 12, 2025 at 4:00 P.M. (ET)
NOTICE OF FIFTH MONTHLY APPLICATION OF ARMSTRONG
TEASDALE LLP, AS CO -COUNSEL TO THE DEBTORS AND
DEBTORS IN POSSESSION, FOR ALLOWANCE OF COMPENSATION AND
REIMBURSEMENT OF EXPENSES INCURRED FOR THE PERIOD FROM
DECEMBER 1 THROUGH DECEMBER 31, 2024
PLEASE TAKE NOTICE that the FIFTH Monthly Application of Armstrong
Teasdale LLP, as Co -Counsel to the Debtors and Debtors In Possession, for Allowance of
Compensation and Reimbursement of Expenses Incurred for the Period from December 1, 2024
Through December 31, 2024 (the "Application") has been filed with the United States Bankruptcy
Court for the District of Delaware (the "Court"). The Application seeks allowance of monthly fees
in the amount of $51,865.00.
PLEASE TAKE FURTHER NOTICE that objections to the Application, if any, are
required to be filed on or before March 12, 2025 at 4:00 p.m. (ET) (the "Objection Deadline")
with the Clerk of the United States Bankruptcy Court, 824 N. Market Street, 3rd Floor,
Wilmington, Delaware 19801, and served so as to be received on or before the Objection Deadline
by the undersigned counsel to the Debtors.
PLEASE TAKE FURTHER NOTICE THAT, PURSUANT TO THE ORDER,
PURSUANT TO SECTIONS 105(A) ABD 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], IF NO
OBJECTIONS ARE FILED AND SERVED IN ACCORDANCE WITH THE ABOVE
PROCEDURES, THE DEBTORS WILL BE AUTHORIZED TO PAY 80% OF THE
REQUESTED FEES AND 100% OF THE REQUESTED EXPENSES WITHOUT FURTHER
ORDER OF THE COURT.
3The 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.
10
Case 24-11647-MFW Doc 356-2 Filed 02/19/25 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: February 19, 2025,
San Diego, California
The Law Offices of Benjamin M. Carson, P.C.
/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
11
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 1 of 23
Exhibit A
12
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 2 of 23
LAW OFFICES OF BENJAMIN M. CARSON, P.C.
5965 Village Way Ste E105
San Diego, CA 92130
Phone: 1-858-255-4529
Email: ben@benjamincarsonlaw.com
https://www.benjamincarsonlaw.com/
SilverRock Development Company, LLC
343 Fourth Ave
San Diego, California 92101
Statement of Account
Outstanding Balance New Charges
$51,241.00 + $51,865.00
Date Employee Type
12/01/2024 BC
12/01/2024 BC
12/01/2024 BC
12/01/2024 BC
Description
Invoice # 5 - SR -DC
Date: 02/18/2025
Due On: 03/20/2025
Total Balance
Hours
Rate Total
Service Case Administration: SR -DC - Edited 1.20 $375.00 $450.00
final draft of motion to extend
exclusivity and supporting declarations.
Service Case Administration: SR -DC - Edited 0.30 $375.00 $112.50
final draft of motion to extend time to
assume/reject leases.
12/01/2024 BC
12/01/2024 BC Service
Service Case Administration: SR -DC - 0.70 $375.00 $262.50
Discussed needed edits to final draft of
motion to extend exclusivity with client
and bankruptcy co -counsel.
Service Case Administration: SR -DC - 0.20 $375.00 $75.00
Discussed needed edits to final draft of
motion to extend time to assume/reject
leases with client and bankruptcy co -
counsel.
Service Case Administration: SR -DC -
Reviewed proposed agenda for
upcoming omnibus hearing.
Case Administration: SR -DC - With
bankruptcy co -counsel, worked on text
of 4th interim DIP financing order.
12/01/2024 VV Service Case Administration: SR -DC -
0.20 $375.00 $75.00
0.50
$375.00
$187.50
0.50 $650.00 $325.00
Page 1 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 3 of 23
12/01/2024 VV
Strategized and reviewed text of 4th
interim DIP financing order.
Service Case Administration: SR -DC - 0.20 $650.00 $130.00
Strategized, edited, and reviewed final
draft of motion to extend time to
assume/reject leases.
12/01/2024 VV
12/01/2024 VV
12/01/2024 VV
12/02/2024 BC
Service Case Administration: SR -DC - 0.20 $650.00 $130.00
Strategized on edits to final draft of
motion to extend exclusivity.
Service Case Administration: SR -DC - 0.10 $650.00 $65.00
Reviewed final draft of motion to extend
time to assume/reject leases.
Service Case Administration: SR -DC - 0.50 $650.00 $325.00
Reviewed final draft of motion to extend
exclusivity and supporting declarations.
Service Case Administration: SR-P1 - Edited 0.70 $375.00 $262.50
Draft Fourth Interim Order for DIP Loan
with City of La Quinta.
12/02/2024 BC
12/02/2024 BC
12/02/2024 BC
12/02/2024 BC
Service Case Administration: SR -PI - Discussed 0.50 $375.00 $187.50
issues pertaining to the Fourth Interim
Order with client and bankruptcy co -
counsel.
Service Case Administration: SR -PI - Discussed 0.30 $375.00 $112.50
preparation for upcoming status
conference hearing with client and
bankruptcy co -counsel.
Service Case Administration: SR -DC - 0.10 $375.00 $37.50
Discussed fmalizing CRO Order with
Major Constituents.
Service
Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -PI - Attended weekly
scheduled meeting with counsel for City
of La Quinta and Major Constituents.
12/02/2024 BC
Service Case Administration: SR -PI - Reviewed
latest draft of loan agreement and
attached memorandum of understanding
redlined by City of La Quinta.
0.20
$375.00
$75.00
12/02/2024 BC
Service Case Administration: PA789 - Finalized 0.50 $375.00 $187.50
exclusivity order and supporting
declaration for filing.
12/02/2024 BC
Service Meetings of and Communications with
Creditors: PA789 - Communicated with
multiple creditors regarding voluntary
1.20 $375.00 $450.00
Page 2 of 22
12/02/2024 BC
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 4 of 23
reconveyance of deeds of trust
encumbering real property of the estate.
Service Case Administration: PA789 - 0.50 $375.00 $187.50
Discussed strategy for implementing
unwind and reconveyance agreements
with client and bankruptcy co -counsel.
12/02/2024 BC
12/02/2024 VV
12/02/2024 VV
Service Case Administration: PA789 - Prepared 0.30 $375.00 $112.50
exhibits containing unwind and
reconveyance agreements in support of
upcoming 9019 motion to approve
settlement reconveying deeds of trust.
Service Case Administration: SR -PI - Reviewed 0.30 $650.00 $195.00
Draft Fourth Interim Order for DIP Loan
with City of La Quinta.
12/02/2024 VV
Service Case Administration: SR -PI - 0.50 $650.00 $325.00
Strategized on issues pertaining to the
Fourth Interim Order.
Service Case Administration: SR -PI - 0.30 $650.00 $195.00
Strategized on preparation for upcoming
status conference hearing.
12/02/2024 VV
Service Case Administration: SR -DC -
Strategized on finalizing CRO Order
with Major Constituents.
0.10 $650.00 $65.00
12/02/2024 VV
Service Meetings of and Communications with
Creditors: SR -PI - Attended weekly
scheduled meeting with counsel for City
of La Quinta and Major Constituents.
0.30
$650.00
$195.00
12/02/2024 VV Service Case Administration: SR -PI - 0.10 $650.00 $65.00
Strategized and reviewed latest draft of
loan agreement and attached
memorandum of understanding redlined
by City of La Quinta.
12/02/2024 VV
12/02/2024 VV
12/02/2024 VV
Service Case Administration: PA789 - Reviewed 0.30 $650.00 $195.00
exclusivity order and supporting
declaration for filing.
Service Meetings of and Communications with 0.30 $650.00 $195.00
Creditors: PA789 - Strategized on
voluntary reconveyance of deeds of trust
encumbering real property of the estate.
Service Case Administration: PA789 -
Strategized on implementing unwind
and reconveyance agreements.
12/02/2024 VV Service Case Administration: PA789 - Reviewed
0.50 $650.00 $325.00
0.10 $650.00 $65.00
Page 3 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 5 of 23
12/03/2024 BC
12/03/2024 BC
12/03/2024 BC
12/03/2024 BC
exhibits containing unwind and
reconveyance agreements in support of
upcoming 9019 motion to approve
settlement reconveying deeds of trust.
Service Case Administration: SR -DC - Prepared 1.10 $375.00 $412.50
for and attended omnibus bankruptcy
hearing.
Service Case Administration: SR -DC - Finalized
4th interim DIP order for circulation.
Service Analysis/Strategy: SR -DC - Prepared
final draft of initial fraudulent transfer
and preferential transfer complaint for
filing.
0.30
$375.00
1.30 $375.00
$112.50
$487.50
Service Case Administration: SR -DC - Prepared 0.70 $375.00 $262.50
final draft of 9019 motion and
supporting documents/declarations for
filing.
12/03/2024 VV
12/03/2024 VV
12/03/2024 VV
12/03/2024 VV
Service Case Administration: SR -DC - Prepared
for and attended omnibus bankruptcy
hearing.
Service Case Administration: SR -DC -
Reviewed 4th interim DIP order for
circulation.
1.10 $650.00 $715.00
0.10 $650.00 $65.00
Service Analysis/Strategy: SR -DC - Reviewed 0.30 $650.00 $195.00
final draft of initial fraudulent transfer
and preferential transfer complaint for
filing.
Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Reviewed final draft of 9019 motion and
supporting documents/declarations for
filing.
12/04/2024 BC
Service Case Administration: SR -PI - Finalized 0.50 $375.00 $187.50
Fourth Interim DIP Order for filing.
12/04/2024 BC
Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -PI - Discussed contents of
4th interim DIP Order with client and
counsel for City of La Quinta.
12/04/2024 BC
Service Analysis/Strategy: SR -PI - Discussed 0.20 $375.00 $75.00
steps to finalize adversary proceeding
against preferred equity holders with
client and bankruptcy co -counsel.
12/04/2024 BC Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -PI - Discussed new
Page 4 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 6 of 23
12/04/2024 BC
12/04/2024 BC
12/04/2024 BC
priming DIP term sheet with client and
counsel for City of La Quinta.
Service Business Operations: SR -PI - Reviewed 0.10 $375.00 $37.50
plan to switch DIP bank accounts with
client.
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -PI - Discussed state
litigation matter with counsel for
plaintiff suing several Debtor entities.
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -PI - Discussed finalizing
Fourth Interim DIP Order through
Certification of Counsel with counsel
for UST and Major Constituents.
12/04/2024 BC
Service Case Administration: SR -PI -Discussed 0.20 $375.00 $75.00
preparation of motion and order for new
priming DIP loan with City of La Quinta
with bankruptcy co -counsel.
12/04/2024 BC
Service Case Administration: PA789 -
Discussed status of PA 9 and its tenant
in common with client and bankruptcy
co -counsel.
12/04/2024 BC
0.50 $375.00 $187.50
Service Case Administration: SR -LUX -
Reviewed status of motion extending
deadline to assume/reject non-residential
leases with client.
0.20 $375.00 $75.00
12/04/2024 VV Service Case Administration: SR -PI - Reviewed
Fourth Interim DIP Order for filing.
12/04/2024 VV
12/04/2024 VV
12/04/2024 VV
12/05/2024 BC
12/05/2024 BC
Service
Analysis/Strategy: SR -PI - Strategized
on steps to finalize adversary proceeding
against preferred equity holders.
0.30 $650.00 $195.00
0.20 $650.00
$130.00
Service Case Administration: SR -PI - 0.20 $650.00 $130.00
Strategized on preparation of motion
and order for new priming DIP loan
with City of La Quinta.
Service Case Administration: PA789 - 0.50 $650.00 $325.00
Strategized on status of PA 9 and its
tenant in common.
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: PA789 - Discussed tenancy in
common issue on PA 9 with counsel for
City of La Quinta.
Service Case Administration: PA789 -
0.80 $375.00 $300.00
Page 5 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 7 of 23
12/05/2024 BC
12/05/2024 BC
12/05/2024 BC
Researched strategies for resolving
issues posed by tenancy in common on
PA 9.
Service Case Administration: PA789 - 0.70 $375.00 $262.50
Discussed issues posed by tenancy in
common on PA 9 with client and
bankruptcy co -counsel.
Service Analysis/Strategy: PA789 - Discussed 0.50 $375.00 $187.50
next steps in settling with defendants
sued in avoidance action with client and
bankruptcy co -counsel.
Service Case Administration: SR -PI - Made 0.30 $375.00 $112.50
final clean up edits to fourth Interim DIP
Financing Order.
12/05/2024 BC Service Meetings of and Communications with 0.30 $375.00 $112.50
12/05/2024 BC
Creditors: SR -PI - Communicated with
counsel for Major Constituent and UST
regarding execution of fourth interim
DIP Order via CoC.
Service Business Operations: SR -PI - Reviewed
and discussed with client issue
pertaining to newly imposed costs of
contractor proposed to clean up
development site.
0.30
$375.00
$112.50
12/05/2024 BC
12/05/2024 VV
Service Case Administration: SR -PI - Discussed 0.20 $375.00 $75.00
with bankruptcy co -counsel issues
pertaining to upcoming introductory
meeting with preferred real estate broker
of Debtor.
Service Case Administration: PA789 - 0.70 $650.00 $455.00
Strategized on issues posed by tenancy
in common on PA 9.
12/05/2024 VV
12/05/2024 VV
Service Analysis/Strategy: PA789 - Strategized 0.50 $650.00 $325.00
on next steps in settling with defendants
sued in avoidance action.
Service Case Administration: SR -PI - Reviewed 0.10 $650.00 $65.00
edits to fourth Interim DIP Financing
Order.
12/05/2024 VV
Service Case Administration: SR -PI - 0.20 $650.00 $130.00
Strategized on issues pertaining to
upcoming introductory meeting with
preferred real estate broker of Debtor.
12/06/2024 BC Service Case Administration: PA789 - With 0.50 $375.00 $187.50
client and bankruptcy co -counsel,
Page 6 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 8 of 23
discussed potential issues pertaining to
co -tenancy on PA 9.
12/06/2024 BC
Service Case Administration: SR -LUX - 0.50 $375.00 $187.50
Reviewed and discussed with
bankruptcy co -counsel various
documents pertaining to capital and debt
structure and relationship to ground
leases on debtors' property.
12/06/2024 BC
12/06/2024 BC
12/06/2024 BC
Service Case Administration: SR -PI - Reviewed
revised unwind agreement provided by
counsel for former preferred equity
holder.
Service Meetings of and Communications with
Creditors: SR -PI - Discussed proposed,
revised unwind agreement with counsel
for preferred equity holder.
0.30
$375.00
0.20 $375.00
$112.50
$75.00
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -PI - Discussed unwind
agreements and requests for
reconveyance with various preferred
equity holders converted into secured
creditors just before bankruptcy filed.
12/06/2024 VV
12/06/2024 VV
Service Case Administration: PA789 - 0.50 $650.00 $325.00
Strategized on potential issues
pertaining to co -tenancy on PA 9.
Service Case Administration: SR -LUX - 0.50 $650.00 $325.00
Strategized on various documents
pertaining to capital and debt structure
and relationship to ground leases on
debtors' property.
12/08/2024 BC
Service Analysis/Strategy: SR -DC - With client
and bankruptcy co -counsel, discussed
strategy for obtaining consent of
lienholders to priming terms and
admitting expert testimony regarding
underlying value of property into record.
12/08/2024 VV
12/09/2024 BC
0.70
$375.00
$262.50
Service Analysis/Strategy: SR -DC - Strategized 0.70 $650.00 $455.00
on obtaining consent of lienholders to
priming terms and admitting expert
testimony regarding underlying value of
property into record.
Service Case Administration: SR -DC - Edited
drafts of DIP motion, proposed order,
and supporting documents.
12/09/2024 BC Service Case Administration: SR -DC -
2.30 $375.00 $862.50
1.00
$375.00
$375.00
Page 7 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 9 of 23
12/09/2024 BC
12/09/2024 BC
12/09/2024 BC
Discussed needed edits to text of DIP
motion, proposed order, and supporting
documents with bankruptcy co -counsel.
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Participated in
discussion with Major Constituents on
upcoming motion practice and case
status update.
Service Meetings of and Communications with 0.50 $375.00 $18.7.50
Creditors: SR -LUX - Discussed final
terms of unwind agreement with former
preferred equity holder converted into
secured creditor.
Service Case Administration: SR -LUX -
Discussed revised final terms of unwind
agreement with bankruptcy co -counsel.
0.30 $375.00 $112.50
12/09/2024 BC Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -LUX - Discussed revised
terms of unwind agreement with counsel
for City of La Quinta and concerns
expressed by counsel for preferred
equity holder converted into secured
creditor.
12/09/2024 VV
12/09/2024 VV
Service Case Administration: SR -DC -
Reviewed drains of DIP motion,
proposed order, and supporting
documents.
0.50
$650.00
$325.00
Service Case Administration: SR -DC - 0.50 $650.00 $325.00
Strategized and reviewed needed edits to
text of DIP motion, proposed order, and
supporting documents.
12/09/2024 VV
12/09/2024 VV
12/10/2024 BC
Service Meetings of and Communications with
Creditors: SR -DC - Attended discussion
with Major Constituents on upcoming
motion practice and case status update.
Service Case Administration: SR -LUX -
Strategized on revised final terms of
unwind agreement.
Service
Case Administration: SR -PI - Reviewed
prior monthly operating reports and
account methods used therein in
preparation for call with client.
0.30
$650.00
$195.00
0.30 $650.00 $195.00
0.50 $375.00 S 187.50
12/10/2024 BC
Service Case Administration: SR -PI - Discussed 0.50 $375.00 $187.50
accounting questions raised by counsel
for secured creditor pertaining to
Page 8 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 10 of 23
12/10/2024 BC
12/10/2024 BC
monthly operating reports.
Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -DC - Discussed potential
impact of co -tenant in common on
upcoming DIP financing motion with
counsel for City of La Quinta and
bankruptcy co -counsel.
Service Case Administration: SR -DC - Edited 0.70 $375.00 $262.50
proposed order granting upcoming DIP
motion in accordance with recent
comments received by client and
bankruptcy co -counsel.
12/10/2024 VV
12/10/2024 VV
12/11/2024 BC
12/11/2024 BC
12/11/2024 VV
12/11/2024 BC
Service Meetings of and Communications with 0.50 $650.00 $325.00
Creditors: SR -DC - Strategized on
potential impact of co -tenant in common
on upcoming DIP financing motion with
counsel for City of La Quinta.
Service Case Administration: SR -DC - 0.50 $650.00 $325.00
Strategized, edited, and reviewed
proposed order granting upcoming DIP
motion.
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Discussed strategy for obtaining consent
to priming terms with client and
bankruptcy co -counsel.
Service Case Administration: SR -DC -
Continued applying edits to DIP priming
motion, order and supporting
documents.
Service Case Administration: SR -DC - Edited
draft of proposed DIP priming order.
2.60 $375.00 $975.00
0.80
$650.00
$520.00
Service Meetings of and Communications with 0.70 $375.00 $262.50
Creditors: SR -DC - Reviewed working
draft of DIP motion, order, and
supporting documents with client,
bankruptcy co -counsel, and counsel for
City of La Quinta.
12/11/2024 BC
Service Case Administration: SR -DC -
Reviewed revised draft of final DIP
budget.
12/11/2024 BC
12/11/2024 BC
0.20 $375.00 $75.00
Service Case Administration: SR -DC - 0.30 $375.00 $1'12.50
Discussed final DIP budget with client
and bankruptcy co -counsel.
Service Meetings of and Communications with 0.20 $375.00 $75.00
Page 9 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 11 of 23
12/11/2024 VV
12/11/2024 VV
12/11/2024 VV
12/11/2024 VV
12/12/2024 BC
Creditors: SR -DC - Summarized
working draft of DIP motion, order,
declarations, term sheets, and other
supporting documents for counsel to
major constituents.
Service Case Administration: SR -DC -
Strategized on obtaining consent to
priming terms.
Service Case Administration: SR -DC -
Strategized, edited, and reviewed DIP
priming motion, order and supporting
documents.
0.30 $650.00 $195.00
0.50 $650.00 $325.00
1212'2024 BC
Service Meetings of and Communications with 0.70 $650.00 $455.00
Creditors: SR -DC - Reviewed working
draft of DIP motion, order, and
supporting documents.
Service Case Administration: SR -DC -
Strategized on final DIP budget.
Service
Case Administration: SR -DC - Finalized
preparation of DIP motion, order, and
supporting documents for filing.
Service Case Administration: SR -DC - Back and
forth communication with client,
bankruptcy co -counsel, and counsel for
City of La Quinta to resolve outstanding
issues for DIP motion, order and
supporting documents to complete
timely filing.
0.30 $650.00 $195.00
4.10 $375.00 $1,537.50
2.90 $375.00 $1,087.50
12/12/2024 BC Service Case Administration: SR -PI - Reviewed 0.50 $375.00 $187.50
application to employ broker and
supporting documents.
12/12/2024 BC
12/12;2024 VV
12/12/2024 VV
12/12/2024 VV
Service Case Administration: SR -PI - Discussed 0.70 $375.00 $262.50
finalizing application to employ broker
with client and bankruptcy co -counsel.
Service
Service
Case Administration: SR -PI - Worked 0.80 $650.00 $520.00
through draft of application to employ
broker.
Case Administration: SR -DC - 0.50 $650.00 $325.00
Reviewed finalized DIP motion, order,
and supporting documents for filing.
Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Strategized on resolving outstanding
issues for DIP motion, order and
supporting documents to complete
Page 10 of 22
12/12/2024 VV
12/13/2024 BC
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 12 of 23
timely filing.
Service Case Administration: SR -PI - 0.70 $650.00 $455.00
Strategized on finalizing application to
employ broker.
Service Case Administration: SR -DC - Prepared
high-level summary of capital structure
and secured debt obligations for
potential expert testifying in support of
DIP priming motion to consider.
0.50
12/13/2024 BC
12/13/2024 BC
$375.00
$187.50
Service Case Administration: SR -DC - 0.50 $375.00 $187.50
Discussed strategy for obtaining consent
to DIP priming terms with client and
bankruptcy co -counsel.
Service Case Administration: SR -PI - Discussed 1.20 $375.00 $450.00
outstanding issues pertaining to fmal
retention of broker with client and
bankruptcy co -counsel.
12/13/2024 BC
Service Case Administration: SR -PI - Reviewed 0.50 $375.00 $187.50
revised conflicts list, declaration, and
listing agreement provided by counsel
for potential broker.
12/13/2024 BC
Service Case Administration: SR -PI - Discussed 0.30 $375.00 $112.50
strategy for obtaining order to retain
broker with counsel for broker and
bankruptcy co -counsel.
12/13/2024 VV
Service Case Administration: SR -DC - 0.20 $650.00 $130.00
Reviewed high-level summary of capital
structure and secured debt obligations
for potential expert testifying in support
of DIP priming motion to consider.
12/13/2024 VV
12/13/2024 VV
12/13/2024 VV
12/14/2024 BC
Service
Case Administration: SR -DC - 0.50 $650.00 $325.00
Strategized on obtaining consent to DIP
priming terms.
Service Case Administration: SR -PI - 0.70 $650.00 $455.00
Strategized on outstanding issues
pertaining to final retention of broker.
Service Case Administration: SR -PI - 0.30 $650.00 $195.00
Strategized on obtaining order to retain
broker with counsel.
Service Case Administration: SR -DC -
Discussed strategy for examining expert
witness in support of underlying
property valuation for DIP priming
motion with bankruptcy co -counsel.
0.50 $375.00 $187.50
Page 11 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 13 of 23
12/14/2024 VV
Service Case Administration: SR -DC -
Strategized on examining expert witness
in support of underlying property
valuation for DIP priming motion.
12/15/2024 BC
12/15/2024 VV
Service Case Administration: SR -DC -
Discussed strategy for upcoming motion
practice and upcoming workflow issues
for debtors with bankruptcy co -counsel.
0.50 $650.00
$325.00
0.50 $375.00 $187.50
Service Case Administration: SR -DC - 0.50 $650.00 $325.00
Strategized on upcoming motion
practice and upcoming workflow issues
for debtors.
12/16/2024 BC
Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: SR -PI - Call with US Trustee
on upcoming DIP motion.
12/16/2024 BC
12/16/2024 BC
12/16/2024 BC
Service Analysis/Strategy: SR -PI - Reviewed 0.30 $375.00 $112.50
settlement agreement between
SilverRock and Cypress and
corresponding loan/deed of trust.
Service Business Operations: SR -PI - Discussed 0.10 $375.00 $37.50
potential need to pay critical vendor
with CRO.
Service Case Administration: SR -PI - Discussed
preparation of retention application with
counsel for potential broker.
12/16/2024 BC
12/16/2024 BC
0.30
$375.00
$112.50
Service Meetings of and Communications with
Creditors: SR -PI - Communicated with
US Trustee counsel about change in DIP
bank accounts.
Service
Case Administration: SR -DC -
Discussed potential opposition to
recently filed DIP priming motion with
bankruptcy co -counsel and client.
12/16/2024 BC
0.10 $375.00 $37.50
0.70 $375.00 $262.50
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Ca11 with Major
Constituents to provide key updates on
bankruptcy case.
12/16/2024 BC
Service Analysis/Strategy: SR -DC - Reviewed
causes of action in potential fraudulent
transfer case with bankruptcy co -
counsel.
0.30 $375.00 $112.50
12/16/2024 BC
Service
Case Administration: SR -DC -
Discussed potential amendments to prior
MOR's with client and bankruptcy co-
0.20
$375.00
$75.00
Page 12 of 22
12/16/2024 BC
12/16/2024 BC
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 14 of 23
counsel.
Service Case Administration: SR -DC -
Discussed potential strategies for
obtaining consent of various secured
creditors to DIP priming lien with
bankruptcy co -counsel.
0.30 $375.00 $112.50
Service Case Administration: SR -LUX - 0.50 $375.00 $187.50
Strategized on next steps for settlement/
unwind agreements with preferred
equity holders and related complaint
against preferred equity holders with
client and bankruptcy co -counsel.
12/16/2024 BC
Service Meetings of and Communications with 0.10 $375.00 $37.50
Creditors: SR -LUX - Communicated
with counsel for preferred equity holder
and defendant in avoidance lawsuit
about possible settlement.
12/16/2024 VV
12/16/2024 VV
12/16/2024 VV
Service Case Administration: SR -DC -
Strategized on potential opposition to
recently filed DIP priming motion.
0.20
$650.00
$130.00
Service Meetings of and Communications with 0.30 $650.00 $195.00
Creditors: SR -DC - Attended call with
Major Constituents to provide key
updates on bankruptcy case.
Service Analysis/Strategy: SR -DC - Strategized
on causes of action in potential
fraudulent transfer case.
0.30 $650.00
$195.00
12/16/2024 VV
Service Case Administration: SR -DC -
Strategized on potential amendments to
prior MOR's.
12/16/2024 VV
12/16/2024 VV
12/17/2024 BC
Service Case Administration: SR -DC -
Strategized on obtaining consent of
various secured creditors to DIP priming
lien.
0.20 $650.00 $130.00
0.30 $650.00 $195.00
Service Case Administration: SR -LUX - 0.50 $650.00 $325.00
Strategized and reviewed next steps for
settlement/unwind agreements with
preferred equity holders and related
complaint against preferred equity
holders.
Service Analysis/Strategy: SR -DC - Researched
issues pertaining to new avoidance and
fraudulent transfer complaint to avoid
lien.
0.70 $375.00 $262.50
Page 13 of 22
12/17/2024 BC
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 15 of 23
Service Analysis/Strategy: SR -DC - Worked on 0.80 $375.00 $300.00
draft of fraudulent transfer and
avoidance complaint.
12/17/2024 BC
12/17/2024 BC
12/17/2024 BC
12/17/2024 BC
12/17/2024 VV
Service Analysis/Strategy: SR -DC - Discussed 0.30 $375.00 $112.50
issues pertaining to avoidance and
fraudulent transfer complaint with
bankruptcy co -counsel.
Service Case Administration: SR -DC - 1.30 $375.00' $487.50
Discussed outstanding issues related to
motion for DIP financing and DIP
priming lien with client and bankruptcy
co -counsel.
Service Case Administration: SR -DC - Revised 0.30 $375.00 $112.50
unwind agreement to re -execute with
preferred equity holder converted into
secured creditor.
Service Meetings of and Communications with 1.00 $375.00 $375.00
Creditors: SR -DC - Back and forth
communication between client,
bankruptcy co -counsel, and preferred
equity holder regarding re -executing
unwind agreement.
Service Analysis/Strategy: SR -DC - Reviewed 0.30 $650.00 $195.00
draft of fraudulent transfer and
avoidance complaint.
12/17/2024 VV
12/17/2024 VV
Service Analysis/Strategy: SR -DC - Strategized 0.30 $650.00 $195.00
on issues pertaining to avoidance and
fraudulent transfer complaint.
Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Strategized on outstanding issues related
to motion for DIP financing and DIP
priming lien.
12/17/2024 VV
Service Case Administration: SR -DC - 0.10 $650.00 $65.00
Reviewed unwind agreement to re -
execute with preferred equity holder
converted into secured creditor.
12/17/2024 VV
12/18/2024 VV
Service
Meetings of and Communications with
Creditors: SR -DC - Strategized on
regarding re -executing unwind
agreement.
0.50
$650.00
$325.00
Service Case Administration: SR -DC -
Discussed status of motion to retain
broker and working draft of listing
agreement with counsel for JLL.
0.50 $650.00 $325.00
Page 14 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 16 of 23
12/18/2024 VV
Service Meetings of and Communications with 0.50 $650.00 $325.00
Creditors: SR -DC - Discussed City's
possible objections to 9019 motion to
approve unwind agreements and
reconveyances with counsel for City of
La Quinta.
12/18/2024 BC
Service Case Administration: SR -DC - 1.00 $375.00 $375.00
Discussed motion to retain JLL as real
estate broker with client and bankruptcy
co -counsel.
12/18/2024 BC
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Discussed possible
consent to extension of exclusive period
to file plan of reorganization with
multiple secured creditors.
12/18/2024 BC
Service Case Administration: SR -DC - Drafted
supplemental supporting declarations
requested by City of La Quinta in
support of approving 9019 motion to
approve settlement.
12/18/2024 BC
1.00 $375.00 $375.00
Service Analysis/Strategy: SR -DC - Worked 2.40 $375.00 $900.00
through draft of complaint including
avoidance, fraudulent transfer, and usury
causes of action to avoid lien of secured
creditor.
12/18/2024 BC
12/18/2024 VV
Service Case Administration: SR -DC - 0.50 $375.00 $187.50
Discussed strategy for obtaining consent
to extend exclusivity period from Major
Constituents with client and bankruptcy
co -counsel.
Service Case Administration: SR -DC -
Strategized on motion to retain JLL as
real estate broker.
12/18/2024 VV
12/18/2024 VV
12/18/2024 VV
Service Case Administration: SR -DC -
Reviewed supplemental supporting
declarations requested by City of La
Quinta in support of approving 9019
motion to approve settlement.
0.50 $650.00 $325.00
0.50
$650.00
$325.00
Service Analysis/Strategy: SR -DC - Reviewed 0.50 $650.00 $325.00
draft of complaint including avoidance,
fraudulent transfer, and usury causes of
action to avoid lien of secured creditor.
Service Case Administration: SR -DC -
Strategized on obtaining consent to
extend exclusivity period from Major
Constituents.
0.50 $650.00 $325.00
Page 15 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 17 of 23
12/19/2024 BC
Service Meetings of and Communications with 0.50 $375.00 $187.50
Creditors: PA789 - Back and forth
communication with client, bankruptcy
co -counsel, and preferred equity holder
unwinding secured interest regarding
terms of re -executed unwind agreement
and DOT.
12/19/2024 BC
12/19/2024 BC
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Reviewed City limited objection to 9019
motion to reconvey secured interest.
12/19/2024 BC
12/19/2024 BC
12/19/2024 BC
12/19/2024 BC
12/19/2024 BC
Service Case Administration: SR -DC -
Discussed response to City's limited
objection to 9019 motion to reconvey
secured interest with client and
bankruptcy co -counsel.
0.50
$375.00
$187.50
Service Case Administration: SR -DC - Began 0.30 $375.00 $112.50
work on reply to City's limited objection
to 9019 motion.
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -DC - Discussed extending
exclusivity period with counsel for two
secured creditors.
Service Analysis/Strategy: SR -PI - Reviewed 1.00 $375.00 $375.00
draft complaint to compel secured
creditor to reconvey DOT with
bankruptcy co -counsel.
Service Analysis/Strategy: SR -PI - Edited draft
complaint compelling secured creditor
to reconvey DOT.
Service Professional Employment Application:
SR -PI - Edited October fee application
for Carson and Vilaplana.
12/19/2024 BC
0.70
0.20
$375.00
$375.00
$262.50
$75.00
Service Case Administration: SR -PI - Reviewed 0.30 $375.00 $112.50
draft of monthly operating reports.
12/19/2024 VV
12/19/2024 VV
Service Meetings of and Communications with 0.50 $650.00 $325.00
Creditors: PA789 - Strategized on
unwinding secured interest regarding
terms of re -executed unwind agreement
and DOT.
Service Case Administration: SR -DC - 0.50 $650.00 $325.00
Strategized on response to City's limited
objection to 9019 motion to reconvey
secured interest.
12/19/2024 VV Service Analysis/Strategy: SR -PI - Strategized
1.00
$650.00
$650.00
Page 16 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 18 of 23
12/19/2024 VV
and reviewed draft complaint to compel
secured creditor to reconvey DOT.
Service Analysis/Strategy: SR -PI - Reviewed
draft complaint compelling secured
creditor to reconvey DOT.
0.30
$650.00
$195.00
12/20/2024 BC Service Professional Employment Application: 0.20 $375.00 $75.00
SR -PI - Finalized draft of October fee
application for filing.
12/20/2024 BC
Service Case Administration: SR -PI - Discussed, 0.50 $375.00 $187.50
with bankruptcy co -counsel, issues
pertaining to dispute over former
preferred equity holder's secured status.
12/20/2024 BC
12/20/2024 BC
12/20/2024 BC
Service Case Administration: SR -PI - Reviewed
multiple transaction documents,
preceding bankruptcy filing, relating to
conversion of preferred equity holder
into secured creditor.
Service
Case Administration: SR -DC -
Discussed status and strategy moving
forward on multiple pending motions
with client and bankruptcy co -counsel.
1.10 $375.00 $412.50
0.70
$375.00
$262.50
Service Meetings of and Communications with 0.30 $375.00 $112.50
Creditors: SR -DC - Discussed
outstanding issues related to upcoming
motion to approve unwind agreements
and reconveyances with counsel for City
of La Quinta.
12/20/2024 BC
12/20/2024 BC
12/20/2024 VV
12/20/2024 VV
12/20/2024 VV
Service Case Administration: SR -DC -
Reviewed agenda for upcoming
omnibus hearing and motion calendar.
Service Case Administration: SR -DC -
Discussed agenda for upcoming
omnibus hearing and motion calendar
with bankruptcy co -counsel.
0.20 $375.00 $75.00
0.10 $375.00 $37.50
Service Professional Employment Application: 0.10 $650.00 $65.00
SR -PI - Reviewed draft of October fee
application for filing.
Service Case Administration: SR -PI -
Strategized on issues pertaining to
dispute over former preferred equity
holder's secured status.
Service Case Administration: SR -DC -
Strategized on moving forward on
multiple pending motions.
0.50
$650.00
$325.00
0.70 $650.00 $455.00
Page 17 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 19 of 23
12/20/2024 VV
Service Case Administration: SR -DC - 0.10 $650.00 $65.00
Strategized on agenda for upcoming
omnibus hearing and motion calendar.
12/23/2024 BC
12/23/2024 BC
12/23/2024 BC
12/23/2024 VV
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -DC - Discussed status of
DIP Motion with counsel for secured
creditor.
Service
Service
Case Administration: SR -DC - 0.20 $375.00 $75.00
Reviewed revised exclusivity order with
comments from City and US Trustee.
Case Administration: SR -DC - 0.30 $375.00 $112.50
Reviewed revised settlement proposal
with Cypress in connection with
obtaining their consent to DIP Order.
Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Reviewed revised settlement proposal
with Cypress in connection with
obtaining their consent to DIP Order.
12/23/2024 BC
12/23/2024 VV
12/23/2024 VV
12/26/2024 BC
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Discussed revised Cypress settlement
proposal with client and bankruptcy co -
counsel.
Service Case Administration: SR -DC -
Reviewed final JLL retention
application prior to filing.
Service Case Administration: SR -DC -
Strategized on revised Cypress
settlement proposal.
0.30
$650.00
$195.00
0.30 $650.00 $195.00
Service Case Administration: PA789 - 0.30 $375.00 $112.50
Discussed mechanics lien claims
erroneously placed on RGC PA 789
with bankruptcy co -counsel.
12/26/2024 BC
12/26/2024 VV
Service Case Administration: SR -DC -
Reviewed revised exclusivity order for
filing through CoC.
Service Case Administration: SR -DC -
Discussed potential Builders Capital
objection to DIP priming loan with
client.
12/26/2024 VV
12/27/2024 BC
Service Case Administration: PA789 -
Strategized on mechanics lien claims
erroneously placed on RGC PA 789.
0.20
0.30
$375.00
$650.00
$75.00
$195.00
0.30 $650.00 $195.00
Service Case Administration: SR -DC -
100
$375.00
$375.00
Page 18 of 22
12/27/2024 BC
12/27/2024 VV
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 20 of 23
Reviewed recent title report and
exceptions within report to ensure
proper service on all mechanics lien
claimants.
Service Case Administration: SR -DC -
Discussed validity of various mechanic
liens claims and service on claimants
with client and bankruptcy co -counsel.
0.70 $375.00 $262.50
Service Case Administration: SR -DC - 0.70 $650.00 $455.00
Strategized on validity of various
mechanic liens claims and service on
claimants.
12/29/2024 VV Service Case Administration: SR -DC - 0.70 $650.00 $455.00
Reviewed case law pertaining to
property perfecting mechanics liens in
bankruptcy cases.
12/29/2024 BC Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Discussed issues pertaining to perfection
of mechanics liens in bankruptcy cases
with bankruptcy co -counsel.
12/29/2024 BC Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Reviewed City of La Quinta complaint
pertaining to specific causes of action
against equity holders.
12/29/2024 VV Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Strategized on issues pertaining to
perfection of mechanics liens in
bankruptcy cases.
12/30/2024 BC Service Case Administration: SR -DC - 0.50 $375.00 $187.50
Reviewed documents and
communications pertaining to possible
exercise of acquiring Phase II option and
its potential value in future sale of client
property.
12/30/2024 BC
12/30/2024 BC
12/30/2024 BC
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Discussed issues pertaining to and
potential value of Phase II option with
client and bankruptcy co -counsel.
Service Case Administration: SR -DC -
Reviewed Court notice pertaining to
upcoming omnibus bk hearing.
0.10 $375.00 $37.50
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Reviewed communication from
common equity holder and discussed
with client and bankruptcy.co-counsel.
•
Page 19 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 21 of 23
12/30/2024 BC
12/30/2024 BC
12/30/2024 VV
Service Case Administration: SR -DC -
Reviewed order extending exclusive
period to file plan of reorganization.
0.10 $375.00 $37.50
Service Case Administration: SR -DC -
Discussed benefits and drawbacks of
substantive consolidation with client and
bankruptcy co -counsel.
12/30/2024 BC
0.30
$375.00
$112.50
Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Communicated with Debtors' prior
principal regarding standalone value of
PA 9.
Service
12/30/2024 BC
12/30/2024 BC
Case Administration: SR -DC - 0.30 $375.00 $112.50
Reviewed terms of ground leases and
potential value to estate as between
SilverRock Lifestyle, Luxury, and
Lodging and SRDC.
Service Case Administration: SR -DC - With
client, prepared thorough legal
description of real property parcels,
including capital structure description
and description of all encumbrances for
internal review.
1.30 $375.00 $487.50
Service Case Administration: SR -DC - 0.50 $375.00 $187.50
Reviewed full descriptions of parcels
with capital structure and encumbrance
details with client and bankruptcy co -
counsel.
12/30/2024 BC
Service Case Administration: SR -DC - 0.30 $375.00 $112.50
Discussed cross-collateralization options
for DIP priming motion with client and
bankruptcy co -counsel.
12/30/2024 BC Service Case Administration: SR -PI - Reviewed 0.10 $375.00 $37.50
revised DWC staffing report before
filing.
12/30/2024 VV Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Strategized on issues pertaining to and
potential value of Phase II option.
12/30/2024 VV Service Case Administration: SR -DC - 0.30 $650.00 $195.00
Strategized and reviewed
communication from common equity
holder and discussed.
12/30/2024 VV
Service Case Administration: SR -DC -
Strategized on benefits and drawbacks
of substantive consolidation.
0.30 $650.00 $195.00
Page 20 of 22
•
12/30/2024 VV
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 22 of 23
Service
Case Administration: SR -DC -
Strategized and reviewed full
descriptions of parcels with capital
structure and encumbrance details.
12/30/2024 VV Service Case Administration: SR -DC -
Strategized on cross-collateralization
options for DIP priming motion.
0.50 $650.00 $325.00
0.30 $650.00 $195.00
12/31/2024 BC Service Case Administration: SR -PI - Discussed 0.50 $375.00 $187.50
upcoming DIP financing motion with
bankruptcy co -counsel.
12/31/2024 BC
12/31/2024 BC
12/31/2024 BC
Service Analysis/Strategy: SR -PI - Discussed
status of Axia complaint with
bankruptcy co -counsel.
0.30 $375.00 $112.50
Service Analysis/Strategy: SR -PI - 0.30 $375.00 $112.50
Communicated with counsel for Axia
regarding status of avoidance and
fraudulent transfer complaint.
Service Meetings of and Communications with 0.70 $375.00 $262.50
Creditors: SR -PI - Discussed pending
motions before Court in early January
with bankruptcy co -counsel and counsel
for City of La Quinta.
12/31/2024 BC
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -PI - Discussed possible
settlement with Poppy Bank with
bankruptcy co -counsel and counsel for
City of La Quinta.
12/31/2024 BC
12/31/2024 VV
Service Meetings of and Communications with 0.20 $375.00 $75.00
Creditors: SR -PI - Discussed terms of
Keilor capital consent to DIP financing
motion with counsel for City of La
Quinta and bankruptcy co -counsel.
Service Case Administration: SR -PI -
Strategized on upcoming DIP financing
motion.
0.50 $650.00 $325.00
12/31/2024 VV Service Analysis/Strategy: SR -PI - Strategized 0.30 $650.00 $195.00
on status of Axia complaint.
12/31/2024 VV Service Meetings of and Communications with 0.20 $650.00 $130.00
Creditors: SR -PI - Strategized on
possible settlement with Poppy Bank.
12/31/2024 VV Service Meetings of and Communications with 0.20 $650.00 S130.00
Creditors: SR -PI - Strategized and
reviewed terms of Keilor capital consent
to DIP financing motion.
Page 21 of 22
Case 24-11647-MFW Doc 356-3 Filed 02/19/25 Page 23 of 23
Time Keeper
Benjamin Carson
Victor Vilaplana
Attorney
Senior Co -Counsel
74.0
37.1
Hours Subtotal
$375.00
$650.00
Detailed Statement of Account
Other Invoices
a°yaf sir- agot
1 - SR -DC
2 - SR -DC
3 - SR -DC
4 - SR -DC
Current Invoice
5 - SR -DC
08/31/2024
09/30/2024
10/31/2024
02/28/2025
$50,185.00
$68,187.50
$63,562.50
$73,670.00
03/20/2025
$51,865.00
Hours Total
Subtotal
Total
$40,148.00
$54,430.00
$50,850.00
$58,936.00
$0.00
$27,750.00
$24,115.00
111.1
$51,865.00
$51,865.00
$10,037.00
$13,757.50
$12,712.50
$14,734.00
alance Due
$51,865.00
Outstanding Balance $103,106.00
Total Amount Outstanding $103,106.00
Please make all amounts payable to: LAW OFFICES OF BENJAMIN M. CARSON, P.C.
Page 22 of 22