Free Motion for Disbursement of Funds - District Court of Colorado - Colorado

Case 1:01-cv-00645-JLK

Document 199-4

Filed 12/07/2007

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EXHIBIT B SUMMARY OF BILLINGS October 1, 2007 through November 30, 2007

I.

CASE BACKGROUND

On October 26, 2005, the Court appointed Patten, MacPhee & Associates, Inc. of Denver, Colorado (the "Receiver") as a receiver in the civil action brought by the United States Securities and Exchange Commission ("SEC") against Kenneth Roy Weare a/k/a Roy Weaver, J&K Global Marketing Corporation and AAA-Auction.com, Inc. ("Defendants"). According to the Order Appointing Receiver dated October 26, 2005, The Receiver was appointed by the Court to: · Create a contact list for soliciting claims from investors, using a Microsoft Access® database containing approximately 48,415 record lines of historical investor information; Compare the Access® database to summaries of deposit items for several bank accounts located in the United States, Luxembourg and Canada listing investors' names and identification numbers, in order to make a determination as to which investors made deposits and received monies in order to identify the full group of potential claimants; Devise an efficient and comprehensive method of establishing the current location of the approximately 23,000 investors estimated by the SEC; Establish a claims procedure by determining the form of notice to be sent to investors and the information to be submitted by investors to establish their claims, the length of time for investors to submit claims and the necessary proof investors must submit to support each claim; Give notice to investors to begin the claims process through email and other communications, including postal mail to investors without valid email addresses, as well as develop the necessary tools, such as a website, for collecting data from potential claimants; Receive claims from investors and evaluate the validity of claims; Prepare a distribution proposal assigning investors a pro rata share of funds collected after costs of the distribution plan have been deducted and submit the distribution proposal to the Court for approval;

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 2 · Give notice to claimants of the process to contest the final distribution plan; and, Administer the distribution of funds from the registry of the Court in coordination with the Clerk's office and prepare any tax forms related to interest earned on the funds to be distributed.

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II.

SCOPE OF ACTIVITIES AND RELATED PROFESSIONAL FEES

This is the Receiver's ninth and final application for professional fees and expenses. Detailed descriptions of the activities undertaken by the Receiver since its appointment through the end of the period preceding that covered by this fee application are provided in the Receiver's quarterly reports for the calendar quarters ended December 31, 2005, March 31, 2006, June 30, 2006, September 30, 2006, December 31, 2006, March 31, 2007, June 30, 2007, and September 30, 2007. In addition, a detailed summary of the Receiver's activities during the course of this receivership is set forth in the Receiver's Ninth and Final Report and Unopposed Motion to Discharge Receiver, With Certificate of Compliance, filed contemporaneously herewith. Prior to the beginning of the two-month period covered by this fee application, the Receiver had already sought the Court's approval for the payment of 1,759 claims. On July 27, 2007, the Receiver filed with the Court Receiver's Combined Status Report and Motion for Order Authorizing and Directing Payment of Allowed Claims and to Set Hearing Date on Claimants' Motions for Review by Court ("July 27 Status Report and Motion"), asking the Court to approve the payment of 1,743 claims totaling $2,124,980. On July 31, 2007, the Court entered its Order Authorizing and Directing Payment of Allowed Claims and Setting a Hearing Date on Claimants' Motions for Review ("July 31 Order"), granting the relief requested by the Receiver in its July 27 Status Report and Motion. The July 31 Order also set a hearing for the afternoon of October 15, 2007 ("October 15 Hearing") to consider any remaining Motions For Review By Court and, in its discretion, to address any other issue that might come before the Court at that time. Checks related to those approved claims were mailed by the Clerk of the Court's Financial Supervisor beginning August 9, 2007. On September 7, 2007, the Receiver filed with the Court its Unopposed Motion for Order Authorizing and Directing Payment of Allowed Claims ("September 7 Motion"), asking the Court to approve the payment of 14 additional allowed claims totaling $23,625. The Court entered its order that same day authorizing and directing the payment of those additional claims. Checks related to those claims were mailed by the Clerk of the Court's Financial Supervisor on or about September 13, 2007.

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 3 As discussed more fully in the Receiver's Eighth Quarterly Report for the Quarter Ended September 30, 2007 ("Eighth Quarterly Report"), two claimants, Karyn Daniels ("Daniels") and Gary Pedler ("Pedler") initially filed Motions For Review By Court, but later dropped their requests for Court review and accepted the amounts initially allowed by the Receiver. Consequently, the Court entered two orders on September 5, 2007, directing the payment of $750, each, to Daniels and Pedler. Those checks were also mailed by the Clerk of the Court's Financial Supervisor on or about September 13, 2007. James Raissis ("Raissis") of Australia, who also filed a timely Motion For Review By Court refused to respond to the Receiver's requests for additional information, let alone attempt to settle with the Receiver. For reasons discussed more fully in the Eighth Quarterly Report, the Clerk of the Court's Financial Supervisor had mailed to claimants a total of 1,751 checks, totaling $2,142,605, prior to the beginning of the period covered by this fee application. Nevertheless, at the time of filing its September 7 Motion, the Receiver had partially disallowed three other claims and each of those claimants still had the right to seek reconsideration and/or Court review at September 30, 2007. Moreover, the Receiver continued to receive late-filed claims, even though the Receiver had previously determined that it would not consider, or reconsider, any new or supplemental claim after August 10, 2007. During the two-month period covered by this fee application, the Receiver's staff, among other things: ! Prepared and filed with the Court on October 2, 2007, Receiver's Unopposed Motion for Order Authorizing and Directing Payment of Additional Allowed Claims ("October 2 Motion"), asking the Court to approve the payment of three additional claims, totaling $1,125. Provided to the Clerk of the Court's Financial Supervisor all data needed to prepare, issue and mail distribution checks to the claimants identified in the October 2 Motion. Prepared and submitted to the Court the Receiver's Eighth Quarterly Report on October 11, 2007. Regularly communicated with the Clerk of the Court's Financial Supervisor concerning a number of issues that had arisen related to distribution checks previously mailed to claimants.

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 4 ! Prepared and filed with the Court the Receiver's Response to the Motion For Review By Court Filed By Claimant Robert Lee Pillow III on September 24, 2007. Continued to receive and handle communications from J&K Global investors wanting to submit a claim for the first time, after the receipt of a distribution check by a friend or family member. Consulted with legal counsel as to whether such late-filed claims could be allowed after previously determining that the Receiver would not consider, or reconsider, any new or supplemental claim after August 10, 2007. Reviewed and considered an additional 55 claims received by the Receiver after August 10, 2007, and prepared an exhibit for the October 15 Hearing showing the amount that the Receiver would allow with respect to each claim. Prepared to defend at the October 15 Hearing the Receiver's disallowance of all but $375 of Raissis' claim for $100,000. Attended the October 15 Hearing. Notified all post-August 10 claimants of the Court's allowance/disallowance of their claims at the October 15 Hearing. Prepared and provided to the Clerk of the Court's Financial Supervisor all data needed to prepare, issue and mail distribution checks to the claimants whose late-filed claims were allowed by the Court at the October 15 Hearing. Determined an estimate of the fees and expenses that the Receiver could reasonably expect to incur after it is discharged from further service in this matter. Drafted for review by the Receiver's legal counsel and counsel for the SEC and subsequently finalized for filing with the Court Receiver's Ninth and Final Report and Unopposed Motion to Discharge Receiver, With Certificate of Compliance, filed contemporaneously herewith.

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 5 For its carrying out of the above-described services during the two-month period from October 1, 2007 through November 30, 2007, the Receiver requests the payment of its professional fees in the amount of $14,880.00 and the reimbursement of its out-of-pocket expenses in the amount of $10,930.29. The effective hourly rate requested by the Receiver in this fee application is $166.63. To date, the Court has approved payment to the Receiver of $215,796.50 for professional fees and $79,968.82 for reimbursement of the Receiver's out-of-pocket expenses. A breakdown, by category, of the Receiver's hourly charges for this fee application and all previous applications follows:

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 6 Communication and/or Reports to the Court Hours billed in this category relate to the preparation, review, revision and submission of quarterly reports to the Court that present and discuss the Receiver's activities for the quarter, as well as all pleadings and other submissions to the Court by the Receiver, including the July 27 Status Report and Motion, the September 7 Motion, the October 2 Motion, and the Receiver's pleadings related to the five Motions For Review By Court filed with the Court. In addition, this category includes communications with the Clerk of the Court's Financial Supervisor regarding the preparation, issuance and delivery of checks to investors approved by the Court. Finally, this category includes the Receiver's attendance at the October 15 Hearing.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate Hours Fees

Previous Applications Hours Fees

Cumulative Hour s 8.5 90.2 0.0 4.0 0.0 1.0 0.5 104.2 Fees

$250 $250 $125 $100 $100 $375 $50

0.0 25.4 0.0 4.0 0.0 1.0 0.3 30.7

$0.00 $6,350.00 $0.00 $300.00 $0.00 $375.00 $15.00 $7,040.00

8.5 64.8 0.0 0.0 0.0 0.0 0.2 73.5

$2,125.00 $14,575.00 $0.00 $0.00 $0.00 $0.00 $10.00 $16,710.00

$2,125.00 $20,925.00 $0.00 $300.00 $0.00 $375.00 $25.00 $23,750.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 7 Communication and/or Meeting with the SEC Included in the hours billed in this category are meetings and telephone conferences with attorneys and/or other staff at the SEC. These meetings pertain to the SEC's investigation into the fraud engaged in by the Defendants, the SEC's steps in recovering data related to the fraud, and the Receiver gaining an understanding of the work completed by the SEC in conjunction with this matter.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 0.7 0.0 0.0 0.0 0.0 0.0 0.7 Fees $0.00 $175.00 $0.00 $0.00 $0.00 $0.00 $0.00 $175.00

Previous Applications Hours 8.4 15.8 0.0 0.0 0.0 0.0 0.0 24.2 Fees $2,100.00 $3,700.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5,800.00

Cumulative Hours 8.4 16.5 0.0 0.0 0.0 0.0 0.0 24.9 Fees $2,100.00 $3,875.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5,975.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 8 Project Planning and Coordination Included in the hours billed in this category are meetings and telephone conferences pertaining to establishing a framework for notifying and collecting information regarding potential claimants, receiving claims, validating claims, preparing a proposed plan of distribution for the Court, issuing and delivering distribution checks to claimants, and closing-out the administration of this receivership matter. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 1.7 0.0 0.7 0.0 0.0 0.0 2.4 Fees $0.00 $425.00 $0.00 $52.50 $0.00 $0.00 $0.00 $477.50 Previous Applications Hours 34.9 68.1 0.0 11.5 7.7 0.0 2.0 124.2 Fees $8,225.00 $10,525.00 $0.00 $950.00 $770.00 $0.00 $100.00 $20,570.00

Cumulative Hours 34.9 69.8 0.0 12.2 7.7 0.0 2.0 126.6 Fees $8,225.00 $10,950.00 $0.00 $1,002.50 $770.00 $0.00 $100.00 $21,047.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 9 Communication and/or Meeting with Counsel for the Receiver Included in the hours billed in this category are meetings and telephone conferences with the Receiver's attorney. These meetings and telephone calls relate to the preparation for procedural motions for the claims process and all relevant court filings required to establish the claims process and procedures. Also included in this category were discussions related to the basis for consolidation of the entity defendants, J&K Global Marketing Corporation and AAA-Auction.com, Inc., the allowance of "claims" submitted after August 10, 2007, and various issues raised at the October 15 Hearing. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate Hours Fees Previous Applications Hours Fees

Cumulative Hour s 3.75 12.00 0.00 0.00 0.00 0.00 15.75 Fees

$250 $250 $125 $100 $375 $50

0.00 5.10 0.00 0.00 0.00 0.00 5.10

$0.00 $1,275.00 $0.00 $0.00 $0.00 $0.00 $1,275.00

3.75 6.90 0.00 0.00 0.00 0.00 10.65

$937.50 $1,350.00 $0.00 $0.00 $0.00 $0.00 $2,287.50

$937.50 $2,625.00 $0.00 $0.00 $0.00 $0.00 $3,562.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 10 Communication and/or Meeting with Investors Included in the hours billed in this category are review and responses to email questions sent to the Receiver by investors, as well as listening and responding, via email, to voicemails left for the Receiver. Also included in this category are unsolicited phone calls from investors answered by representatives of the Receiver. This category primarily captures time spent locating, soliciting registrations, and updating contact information for potential claimants. Time spent communicating with investors related to their particular claimed amount is recorded in the "Claims Administration" category summarized later in this exhibit. During the period covered by this fee application, time spent communicating with claimants regarding their distribution checks is also included in this category. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 0.60 0.00 18.10 0.00 2.20 20.90 Fees $0.00 $150.00 $0.00 $1,357.50 $0.00 $110.00 $1,617.50 Previous Applications Hours 13.50 103.00 0.00 450.80 0.00 99.00 666.30 Fees $3,000.00 $22,900.00 $0.00 $37,334.00 $0.00 $4,220.00 $67,454.00

Cumulative Hours 13.50 103.60 0.00 468.90 0.00 101.20 687.20 Fees $3,000.00 $23,050.00 $0.00 $38,691.50 $0.00 $4,330.00 $69,071.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 11 Identification of Investors Appearing on the FBI/DOJ Restitution List This category contains time spent on cross-referencing the restitution list created pursuant to Mr. Weare's plea agreement to the database of potential claimants provided to the Receiver by the SEC. The Department of Justice requested that the Receiver account for any funds disbursed which may reduce the restitution amounts due from Mr. Weare and to report back to them once the final distribution amounts are determined. During the period covered by this fee application, the Receiver also spent time communicating with and assisting the Federal Public Defender's Office. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 0.50 0.00 0.00 0.00 0.00 0.50 Fees $0.00 $125.00 $0.00 $0.00 $0.00 $0.00 $125.00 Previous Applications Hours 0.00 3.30 0.00 19.70 0.00 1.75 24.75 Fees $0.00 $825.00 $0.00 $1,970.00 $0.00 $87.50 $2,882.50

Cumulative Hours 0.00 3.80 0.00 19.70 0.00 1.75 25.25 Fees $0.00 $950.00 $0.00 $1,970.00 $0.00 $87.50 $3,007.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 12 Website and/or Database Development and Testing Included in the hours billed in this category are meetings and telephone conferences with the website and database developers. These discussions related to the data to be captured from the potential claimant pool, validation of such data, the establishment of user names and passwords of individuals and entities contained in the database seized by the SEC during its investigation. Also included is time spent preparing narrative for the website and designing, formatting and implementation of the screens to be placed on the website. No time was incurred for this activity during the period covered by this fee application.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Fees $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Previous Applications Hours 11.1 18.3 0.0 6.6 0.0 0.0 0.0 36.0 Fees $2,775.00 $4,575.00 $0.00 $660.00 $0.00 $0.00 $0.00 $8,010.00

Cumulative Hours 11.1 18.3 0.00 6.6 0.0 0.0 0.0 36.0 Fees $2,775.00 $4,575.00 $0.00 $660.00 $0.00 $0.00 $0.00 $8,010.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 13 Communications - Miscellaneous Hours billed in this category relate to communications meetings with parties other than counsel and investors, such as vendors or suppliers. No time was incurred for this activity during the period covered by this fee application.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Fees $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Previous Applications Hours 1.2 4.6 0.0 0.0 0.3 0.0 0.0 6.1 Fees $300.00 $1,150.00 $0.00 $0.00 $30.00 $0.00 $0.00 $1,480.00

Cumulative Hours 1.2 4.6 0.0 0.0 0.3 0.0 0.0 6.1 Fees $300.00 $1,150.00 $0.00 $0.00 $30.00 $0.00 $0.00 $1,480.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 14 Database Verification and Analysis ­ Bank Account Activity Hours billed in this category relate to the compilation, verification, and ongoing analysis and modification of an electronic database created from various MS Excel workbooks and spreadsheets prepared by the SEC based on its review and analysis of bank account statements and enclosures seized from the Defendants or directly subpoenaed from the banks. Also included in this category is the review of source documents related to the validation and supplementation of this database. No time was incurred for this activity during the period covered by this fee application.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Fees $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Previous Applications Hours 63.0 0.0 0.0 0.0 0.0 0.0 1.3 64.3 Fees $15,750.00 $0.00 $0.00 $0.00 $0.00 $0.00 $65.00 $15,815.00

Cumulative Hours 63.0 0.0 0.0 0.0 0.0 0.0 1.3 64.3 Fees $15,750.00 $0.00 $0.00 $0.00 $0.00 $0.00 $65.00 $15,815.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 15 Database Verification and Analysis ­ Investor Related Activity Hours billed in this category relate to the verification and ongoing analysis and maintenance of an electronic database seized from the Defendants which contains an accounting of cash deposits and withdrawals as well as contact and identification information of investors. Also included in this category is the review of documents related to the validation and supplementation of this database. No time was incurred for this activity during the period covered by this fee application.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Fees $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Previous Applications Hours 34.0 9.9 0.0 0.0 0.0 0.0 0.0 43.9 Fees $8,500.00 $2,475.00 $0.00 $0.00 $0.00 $0.00 $0.00 $10,975.00

Cumulative Hours 34.0 9.9 0.0 0.0 0.0 0.0 0.0 43.9 Fees $8,500.00 $2,475.00 $0.00 $0.00 $0.00 $0.00 $0.00 $10,975.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 16 Claims Administration Time included in this category relates to the establishment of the time period and procedures for investors to submit their claims, the procedures to be followed by the Receiver in allowing/disallowing claims and the process for investors to appeal any claims disallowed by the Receiver. Also included is time spent preparing and filing with the Court the Motion to Establish Procedures, Claims Bar Date Notice and proposed Proof of Claim Form; updating the Receiver's website to notify investors of the claims process; sending a broadcast email and mailing paper Proof of Claim forms to investors who had provided the Receiver with their current contact information; and, reviewing and allowing/disallowing (in whole or in part) each claim submitted to the Receiver. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 12.50 0.00 8.80 0.00 7.70 29.00 Fees $0.00 $3,125.00 $0.00 $660.00 $0.00 $385.00 $4,170.00 Previous Applications Hours 49.90 149.5 17.50 325.40 0.00 65.70 608.00 Fees $4,100.00 $30,550.00 $2,187.50 $24,515.00 $0.00 $2,460.00 $63,812.50

Cumulative Hours 49.90 162.00 17.50 334.20 0.00 73.40 637.00 Fees $4,100.00 $33,675.00 $2,187.50 $25,175.00 $0.00 $2,845.00 $67,982.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings October 1, 2007 through November 30, 2007 Page 17 III. SUMMARY OF PROFESSIONAL FEES A list of the names and hourly rates of all professionals and para-professionals who billed time on this matter is contained at Exhibit A. Attachment 1 contains a summary of professional fees in chronological order by month, and includes detail by biller and by category for the period October 1, 2007 through November 30, 2007. As set forth in Attachment 1, the Receiver is requesting the payment of $14,880.00 for 89.3 hours of services, which represents an effective hourly rate of $166.63. IV. SUMMARY OF EXPENSES Attachment 2 contains a detailed listing of the Receiver's out-of-pocket expenses, by category, for the period October 1, 2007 through November 30, 2007. V. CONCLUSION The Receiver believes that the requested fees and expenses were reasonable and necessary to complete the tasks required and to discharge its duties in this receivership matter. The Receiver has charged reasonable rates based upon the customary compensation charged by comparably skilled professionals charged with similar fiduciary duties. Further, the Receiver believes that the requested fees and expenses were reasonable and necessary considering the complexity of the issues involved. The Receiver has reviewed this summary of billings to ensure that it accurately reflects the fees and out-of-pocket expenses incurred by the Receiver.