Free Affidavit in Support of Motion - District Court of Arizona - Arizona

AFFIDAVIT OF ATTORNEY MICHAEL SIMES IN SUPPORT OF AMENDED MOTION FOR THE AWARD OF ATTORNEYS' FEES AND COSTS

Exhibit "2"

Case 2:02-cv-02641-ROS

Document 69-3

Filed 11/04/2005

Page 1 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 E-Mail: [email protected] Website: www.MichaelSimes.com

INVOICE FOR LEGAL SERVICES
Invoice Date: January 2, 2002 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 22.0 $250.00 -----------------------$5,500.00 $150.00 $5,650.00 $0.00 ($5,650.00) -----------------------$0.00

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

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Page 1 of 3 Document 69-3 Filed 11/04/2005

Page 2 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($5,650.00) $7,500.00 ----------------------$1,850.00

TIME REPORT DATE 12-04-02 12-06-02 12-10-02 12-12-02 12-13-02 12-16-02 12-18-02 DESCRIPTION Conference with Attorney Brovarone regarding case overview. Review facsimile from Attorney Brovarone regarding Promissory Note and related documents. Commence research regarding Arizona Bulk Sales Act. Continue research regarding Arizona Bulk Sales Act. Commence drafting Complaint. Continue research regarding Arizona Bulk Sales Act. Continue drafting Complaint. Continue drafting Complaint. Commence research regarding Arizona Uniform Fraudulent Transfers Act. Commence research regarding factual relationship between Technology Systems International and Alanco Technologies. Continue research regarding Arizona Uniform Fraudulent Transfers Act. Continue research regarding factual relationship between Technology Systems International and Alanco Technologies. Telephone conference with Attorney Brovarone regarding overview of litigation claims. Continue drafting Complaint. Continue research regarding Arizona Uniform Fraudulent Transfers Act. Continue drafting Complaint. TIME 1.0 0.8 2.0 1.5 0.5 3.2

5.6

12-19-02

3.5

12-20-02

12-21-02

2.3 1.0

Case 2:02-cv-02641-ROS

Page 2 of 3 Document 69-3 Filed 11/04/2005

Page 3 of 140

12-31-02

Finalize and file Complaint. Prepare Summons for indvidual Defendants. TOTAL TIME:

0.6 22.0

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $150.00 $0.00 $0.00 $0.00 $ 150.00

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 4 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 E-Mail: [email protected] Website: www.MichaelSimes.com

INVOICE FOR LEGAL SERVICES
Invoice Date: February 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 1.1 $250.00 -----------------------$275.00 $431.16 $0.00 $0.00 ($706.16) -----------------------$0.00

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 3 Document 69-3 Filed 11/04/2005

Page 5 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $1,850.00 ----------------------($706.16) $0.00 ----------------------$1,43.84

TIME REPORT DATE 01-03-03 01-06-03 01-07-03 DESCRIPTION Prepare First Amended Complaint. Revise Summonses. Research regarding Acceptance of Service of Process by Defendant Alanco Technologies and TSI Acquisition Corporation. Review electronic mail from Attorney Brovarone regarding Technology Systems International--Nevada. Telephone conference with Attorney Brovarone regarding prelitigation settlement negotiations. TIME 0.0 0.2

0.7 0.2

1-30-03

TOTAL TIME:

1.1

Case 2:02-cv-02641-ROS

Page 2 of 3 Document 69-3 Filed 11/04/2005

Page 6 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. C.S. Felton & Associates. Invoice Attached. 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $431.16 $0.00 $ 431.16

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 7 of 140

C.S. FELTON & ASSOCIATES
1730 E. Warner Road, Ste. 10 No. 123 Tempe, Arizona 85284
Telephone: (602) 208-9300 Facsimile: (602) 777-7729

January 20, 2003 Law Office of Michael Simes 903 South Rural Road Suite 101-323 Tempe, Arizona 85281 Via e-mail to: [email protected] Billing Statement December 2002 ­ January 20, 2003 Client/Description Solinvest Group, Ltd. Service of Summons/Affidavits Costs: Copies Total Due: Thank You! Hours 3.5 Rate $45.00 Flat Fee/Costs $180.00 $225.00 $26.16 $431.16

Case 2:02-cv-02641-ROS

Document 69-3

Filed 11/04/2005

Page 8 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 E-Mail: [email protected] Website: www.MichaelSimes.com

INVOICE FOR LEGAL SERVICES
Invoice Date: March 3, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 7.6 $250.00 -----------------------$1,900.00 $0.00 $0.00 $0.00 ($1,143.84) -----------------------$ 756.16

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

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Page 9 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $1,143.84 ----------------------($1,143.84) $0.00 ----------------------$0.00

TIME REPORT DATE 2-3-03 2-4-03 DESCRIPTION Telephone conference with Mr. Oester regarding Answer for TSI--Nevada and Arizona State Court Action filed by Mr. Jones. Review facsimile from Mr. Oester regarding Arizona State Court Action. Telephone conference with Attorney Behm regarding Arizona State Court Action. Draft electronic mail to Attorney Behm regarding Federal Lawsuit. Attend Hearing regarding Temporary Restraining Order in State Court Action. Draft letter to Attorney Brovarone and Mr. Peeper regarding case status. Review electronic mail from Mr. Oester regarding extension of time in which TSI--Nevada may file an Answer in the Federal Lawsuit. Draft electronic mail to Attorney Proper regarding First Amended Complaint in Federal Lawsuit. Draft electronic mail to Mr. Oester regarding extension of time in which TSI--Nevada may file an Answer in the Federal Lawsuit. Telephone conference with Attorney Brovarone regarding intervention in State Court lawsuit. Telephone conference with Attorney Brovarone regarding extension of time in which TSI--Nevada may file an Answer in the Federal Lawsuit. Telephone conference with Attorney Proper regarding extension of time in which TSI--Nevada may file an Answer in the Federal Lawsuit and TSI--Nevada Page 2 of 3 Document 69-3 Filed 11/04/2005 TIME 0.3

1.5 1.5

2-10-03 2-11-03

2.5 0.2 0.3

2-12-03 2-18-03 2-20-03

0.9

Case 2:02-cv-02641-ROS

Page 10 of 140

2-21-03 2-23-03

Board of Directors meeting on February 19, 2003. Draft electronic mail to Attorney Proper regarding extension of time in which TSI--Nevada may file an Answer in the Federal Lawsuit. Review facsimile from Mr. Peeper regarding Alanco Technologies filing with the Securities and Exchange Commission. Draft electronic mail to Mr. Peeper regarding failure of Alanco Technologies to disclose Federal Lawsuit in filing with the Securities and Exchange Commission. TOTAL TIME: EXPENSE REPORT

0.2

0.2 7.6

DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________

EXPENSE $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 0.00

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 11 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 E-Mail: [email protected] Website: www.MichaelSimes.com

INVOICE FOR LEGAL SERVICES
Invoice Date: April 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 1.1 $250.00 -----------------------$ 275.00 $0.00 $0.00 $0.00 ($0.00) -----------------------$ 275.00

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

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Page 12 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT DATE 03-06-03 03-21-03 03-25-03 DESCRIPTION Review electronic mail from Mr. Oester regarding Attorney Proper. Telephone conference with Attorney Behm regarding Arizona State Court Action. Telephone conference with Court Clerk for the Federal District Court of Arizona regarding case status. Telephone conference with Attorney Brovarone regarding case status and Application for Default Judgment. Review electronic mail from Attorney Brovarone regarding Application for Default Judgment. Review electronic mail from Mr. Peeper regarding Application for Default Judgment. TIME 0.1 0.4

0.6 0.0

03-26-03

TOTAL TIME:

1.1

Case 2:02-cv-02641-ROS

Page 2 of 3 Document 69-3 Filed 11/04/2005

Page 13 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 0.00

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 14 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 E-Mail: [email protected] Website: www.MichaelSimes.com

INVOICE FOR LEGAL SERVICES
Invoice Date: May 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 17.6 $250.00 -----------------------$4,400.00 $54.82 $0.00 $0.00 ($0.00) -----------------------$4,454.82

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 3 Document 69-3 Filed 11/04/2005

Page 15 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT DATE 04-07-03 04-08-03 DESCRIPTION Research at law library regarding Motion for Default Judgment against Technology Systems International, the Nevada corporation. Telephone conference with Attorney Behm regarding status of Jones Litigation in Arizona State Court. Draft and finalize Motion for Default Judgment against Technology Systems International, the Nevada corporation. Draft letter to Attorney Brovarone regarding Motion for Default Judgment against Technology Systems International, the Nevada corporation. Prepare for filing and mailing Motion for Default Judgment against Technology Systems International, the Nevada corporation. Draft electronic mail to Attorney Oman regarding Planning Meeting. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding Motion for Default Judgment against Technology Systems International, the Nevada corporation, and Planning Meeting. Telephone conversation with Attorney Oman regarding FRCP Rule 16 Meeting. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding telephone conversation with Attorney Oman. Preparation for and conference with Attorney Oman regarding FRCP Rule 16 Meeting, document overview and settlement discussions. Review notes and documents from conference with Attorney Page 2 of 3 Document 69-3 Filed 11/04/2005 TIME 1.5

2.8

04-09-03

0.5

04-10-03

1.0

04-15-03

2.0 5.0 4.8

4-22-03 04-30-03

Case 2:02-cv-02641-ROS

Page 16 of 140

Oman. Draft letter to Attorney Brovarone and Mr. Peeper regarding case status and settlement negotiations.

TOTAL TIME: EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________

17.6

EXPENSE $36.07 $0.00 $0.00 $15.75 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $3.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 54.82

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 17 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: June 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 14.6 $250.00 -----------------------$3,650.00 $25.94 $0.00 $0.00 ($0.00) -----------------------$3,675.94

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 18 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT DATE 05-06-03 05-12-03 DESCRIPTION Draft electronic mail to Attorney Oman regarding status of settlement discussions. Telephone conference with Clerk for the U.S. District Court regarding Response to Motion for Default Judgment or Answer from Technology Systems International, the Nevada corporation. Telephone conference with Attorney Oman regarding election of new Board of Directors Technology Systems International, the Nevada corporation. Telephone conference with Attorney Brovarone regarding election of new Board of Directors Technology Systems International, the Nevada corporation. Research regarding Nevada corporate laws in relation to election of new Board of Directors Technology Systems International, the Nevada corporation. Draft electronic mail to Attorney Oman regarding request for documentation demonstrating election of new Board of Directors Technology Systems International, the Nevada corporation. Research regarding Judgment divesting title to shares of Alanco Technologies held by Technology Systems International, the Nevada corporation. Research regarding Application for Default Judgment against Technology Systems International, the Nevada corporation. Draft and go final on Application for Default Judgment against Technology Systems International, the Nevada corporation. Draft proposed form of Judgment by Default against Technology Systems International, the Nevada corporation. TIME 0.1

6.8

05-13-03

5.0

Case 2:02-cv-02641-ROS

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Page 19 of 140

5-15-03 5-16-03

5-20-03

5-29-03

Review facsimile from Attorney Oman regarding new Board of Directors for Technology Systems International, the Nevada corporation. Draft electronic mail to Attorney Brovarone regarding election of new Board of Directors Technology Systems International, the Nevada corporation. Draft electronic mail to Attorney Oman regarding delay in settlement discussions due to injury of Attorney Brovarone. Telephone conference with Attorney Oman regarding telephone message from Mr. Peepers. Draft electronic mail to Mr. Peepers regarding inability of Attorney Oman to speak with him directly. Telephone conference with Mr. Peepers regarding case status. Telephone conference with Attorney Brovarone regarding case status. Telephone conference with secretary for Judge Silver regarding status and docketing of Application for Judgment by Default. Telephone conference with Clerk of the U.S. District Court regarding entry of Default Judgment against Technology Systems International.

0.1

0.4

2.0 0.2

TOTAL TIME:

14.6

Case 2:02-cv-02641-ROS

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Page 20 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $11.40 $0.00 $0.00 $6.54 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $8.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 25.94

Case 2:02-cv-02641-ROS

Page 4 of 4 Document 69-3 Filed 11/04/2005

Page 21 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: July 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 25.9 $250.00 -----------------------$6,475.00 $13.20 $0.00 $0.00 ($0.00) -----------------------$6,488.20

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

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RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 06-02-03

06-03-03

DESCRIPTION Telephone conference with Attorney Oman regarding Default Judgment against Technology Systems International, the Nevada corporation, and Shareholder Meeting of Technology Systems International, the Nevada corporation, in June 2003. Review facsimile from Attorney Oman regarding Default Judgment against Technology Systems International, the Nevada corporation, and Shareholder Meeting of Technology Systems International, the Nevada corporation, in June 2003. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding Default Judgment against Technology Systems International, the Nevada corporation, and Shareholder Meeting of Technology Systems International, the Nevada corporation, in June 2003. Research regarding Garnishment Action against Technology Systems International, the Nevada corporation, and Defendant Greg Oester. Draft electronic mail to Attorney Brovarone regarding attorneys fees incurred by Solinvest Group, Ltd. Draft electronic mail to Attorney Brovarone regarding corporate information of Solinvest Group, Ltd. Continue research regarding Garnishment Action against Technology Systems International, the Nevada corporation, and Defendant Greg Oester. Research regarding equitable enforcement against Technology Systems International, the Nevada corporation, for collection of Default Judgment. Telephone conference with Clerk of the Superior Court for Maricopa County, Arizona,

TIME

7.3

6.8

Case 2:02-cv-02641-ROS

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Page 23 of 140

06-06-03

06-09-03

06-10-03

06-17-03

06-18-03

regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Research at the office of Clerk of the Superior Court for Maricopa County, Arizona, regarding pleadings and court orders in Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Research regarding stock valuation of Alanco Technologies, Inc. Telephone conference with Attorney Brovarone regarding attorneys fees incurred by Solinvest Group, Ltd., and equitable enforcement against Technology Systems International, the Nevada corporation, for collection of Default Judgment. Telephone conference with Attorney Oman regarding Shareholder Meeting of Technology Systems International, the Nevada corporation. Review Internal Revenue Service Form W-8BEN regarding foreign status of Solinvest Group, Ltd. Commence drafting Application for Award of Attorneys' Fees. Commence drafting Affidavit of Dennis Brovarone in Support of Application for Award of Attorneys' Fees. Commence drafting Affidavit of Dennis Brovarone in Support of Application for Award of Attorneys' Fees. Review trading status of Alanco Technologies, Inc., regarding Motion to Accelerate. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding stock price of Alanco Technologies, Inc., and the total amount of money due and owing by Technology Systems International, the Nevada company. Telephone conference with Attorney Oman regarding private placement of shares of Alanco Technologies, Inc. Telephone conference with Attorney Reed regarding payment of Judgment against Technology Systems International, the Nevada company. Telephone conference with Attorney Propper regarding payment of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding collection of Judgment against Technology Systems International, the Nevada company. Review facsimile from Mr. Peeper regarding loan from Mr. Jungnitz to Technology Systems International, the Nevada company. Review electronic mail from Mr. Peeper regarding loan from Mr. Jungnitz to Technology Systems International, the Nevada company, and collection of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Mr. Peeper regarding collection of Judgment against Technology Systems International, the Nevada company, and recourse available to Mr. Jungnitz for loan to Technology Systems International, the Nevada

1.8

5.0

0.6

2.5

1.2

Case 2:02-cv-02641-ROS

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06-25-03

06-27-03 06-30-03

company. Draft electronic mail to Attorney Proper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Telephone conference with Mr. Peeper regarding Technology Systems International, the Nevada company. Telephone conference with Mr. Peeper regarding Technology Systems International, the Nevada company. Draft electronic mail to Attorney Brovarone regarding telephone conference with Mr. Peeper.

0.2 0.2

0.3

TOTAL TIME:

25.9

Case 2:02-cv-02641-ROS

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Page 25 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $8.20 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 13.20

Case 2:02-cv-02641-ROS

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Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: July 31, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 25.1 $250.00 -----------------------$6,275.00 $115.59 $0.00 $0.00 ($0.00) -----------------------$6,390.59

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 27 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 07-02-03

07-07-03

07-09-03

07-10-03

07-14-03

07-16-03

DESCRIPTION Telephone conference with Attorney Proper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Telephone conference with Attorney Proper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Review electronic mail from Mr. Peeper regarding his telephone conference with Mr. Jones of Technology Systems International, the Nevada company. Draft electronic mail to Mr. Peeper regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Telephone conference with Attorney Proper regarding satisfaction of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Attorney Oman regarding status of discussions with Attorney Proper satisfaction of Judgment against Technology Systems International, the Nevada company. Draft electronic mail to Attorney Proper regarding satisfaction

TIME

0.7

0.5

1.3

0.1

0.3 0.8

Case 2:02-cv-02641-ROS

Page 2 of 4 Document 69-3 Filed 11/04/2005

Page 28 of 140

07-19-03

07-20-03

07-21-03

07-24-03

07-28-03

07-29-03

of Judgment against Technology Systems International, the Nevada company. Research regarding Writ of Execution to enforce Judgment against Technology Systems International, the Nevada company. Research regarding execution on corporate securities under Arizona state law and under Federal law. Draft Consolidated and Expedited Motion for Leave of Court to file Writ of Execution and Motion for Continuation of Time for Scheduling Conference Finalize Consolidated and Expedited Motion for Leave of Court to file Writ of Execution and Motion for Continuation of Time for Scheduling Conference. Continue research regarding process and procedure for execution on corporate securities under Arizona state law and under Federal law. Conference with Ms. Swan, Supervisory Deputy of U.S. Marshals, District of Arizona, regarding execution on corporate securities. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding Consolidated and Expedited Motion for Leave of Court to file Writ of Execution and Motion for Continuation of Time for Scheduling Conference. Review electronic mail from Mr. Peeper regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Draft electronic mail to Mr. Peeper regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Telephone conference with Mr. Peeper regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937. Telephone conference with Attorney Proper, Mr. K. Jones and Mr. D. Jones regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937, and Attorney Behm. Telephone conference with Attorney Proper regarding Jones v. Alanco Technologies Inc., et. al., Maricopa County Superior Court No. CV2003--001937, and Writ of Execution to enforce Judgment against Technology Systems International, the Nevada company. Review facsimile from Mr. Peeper regarding preferred stock offering from Alanco Technologies, Inc.

7.0

5.7

6.2

0.2

0.3

2.0

TOTAL TIME:

25.1

Case 2:02-cv-02641-ROS

Page 3 of 4 Document 69-3 Filed 11/04/2005

Page 29 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. ______________________________ 2. ______________________________ Additional Information: _________________________________ _________________________________ EXPENSE $18.64 $0.00 $0.00 $7.23 $0.00 $0.00 $86.22 $0.00 $0.00 $0.00 $3.50 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 115.59

Case 2:02-cv-02641-ROS

Page 4 of 4 Document 69-3 Filed 11/04/2005

Page 30 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: September 2, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 30.3 $250.00 -----------------------$7,575.00 $201.89 $0.00 $0.00 ($0.00) -----------------------$7,776.89

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 31 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 08-06-03

DESCRIPTION Telephone conference with Mr. Peeper regarding collection of Judgment against Technology Systems International, the Nevada Company. Telephone conference with the Secretary of Judge Silver regarding status of Consolidated and Expedited Motion for Leave of Court to file Writ of Execution and Motion for Continuation of Time for Scheduling Conference. Telephone conference with Clerk of the U.S. District Court regarding facsimile transmission of Orders from the Court. Draft and finalize Notice of Correct Address. Draft and finalize Authorization for facsimile transmission of Orders from the Court. Telephone conference with Attorney Oman regarding restrictive legend on shares of Alanco Technologies in the possession of Technology Systems International, the Nevada Company. Research regarding sale of securities by U.S. Marshals. Research regarding effect of restrictive legend on shares of Alanco Technologies in the possession of Technology Systems International, the Nevada Company. Continue research regarding effect of restrictive legend on shares of Alanco Technologies in the possession of Technology Systems International, the Nevada Company. Review Order regarding Writ of Execution to enforce Judgment against Technology Systems International, the

TIME

2.2

08-08-03

4.0

08-09-03

4.0

08-14-03

1.0 1.0

08-15-03

Case 2:02-cv-02641-ROS

Page 2 of 4 Document 69-3 Filed 11/04/2005

Page 32 of 140

08-18-03

8-19-03

08-21-03

08-25-03

08-27-03

08-28-03

Nevada company. Prepare Form USM-285 regarding Writ of Execution. Telephone conference with Ms. Swan, Supervisory Deputy of U.S. Marshals, District of Arizona, regarding Writ of General Execution. Research regarding Writ of General Execution including form of Writ, 28 U.S.C. § 3203, Rule 69(a), Federal Rules of Civil Procedure, and Rule 2.22, Rules of Practice of the United States District Court for the District of Arizona. Prepare Writ of General Execution. Research regarding Notice of Levy. Prepare Notice of Levy. Research regarding necessity for Application for Writ of General Execution. Prepare From USM-285 of U.S. Marshals Service for service of Writ of General Execution. Telephone conference with Ms. Swan, Supervisory Deputy of U.S. Marshals, District of Arizona, regarding time for service for Writ of General Execution. Conference with Ms. Baker, Deputy Clerk of the Clerk of the U.S. District Court, regarding issuance of Writ of General Execution. Review all documents in support of service of Writ of General Execution. Two telephone conferences with Secretary to Attorney Proper regarding time of service of Writ of General Execution. Conference with Ms. Swan, Supervisory Deputy of U.S. Marshals, District of Arizona, regarding Acknowledgment of Receipt of Writ of General Execution. Attend service of Writ of General Execution by Ms. Swan, Supervisory Deputy of U.S. Marshals, District of Arizona, upon Attorney Proper at the Law Office of Jeffery Proper. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding status of collection efforts against Technology Systems International, the Nevada Company. Telephone conference with Attorney Oman regarding legend on shares of stock of Alanco Technologies, Inc., that were issued to Technology Systems International, the Nevada Company. Review facsimile from Attorney Oman regarding transfer of stock certificates of Alanco Technologies, Inc., to Attorney Proper. Review facsimile from Mr. Peeper regarding trading volume of Alanco Technologies, Inc. Research regarding trading volume of Alanco Technologies, Inc. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding collection efforts against Alanco Technologies, Inc. Telephone conference with Attorney Oman regarding status of collection efforts against Technology Systems International, the Nevada Company. Research regarding application of attorney-client privilege to transfer of stock certificates from Attorney Proper. Research

4.0

6.0

0.8

1.0

0.3 6.0

Case 2:02-cv-02641-ROS

Page 3 of 4 Document 69-3 Filed 11/04/2005

Page 33 of 140

regarding Rule 69(a) of the Federal Rules of Civil Procedure for Turnover Order. Research regarding defrauding creditors under Arizona Revised Statute Section 13-2205.

TOTAL TIME:

30.3

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: 1. Certified copies of Judgment and Order for U.S. Marshal. 2. U.S. Marshal Fee for Writ of Execution. Additional Information: _________________________________ _________________________________ EXPENSE $7.11 $0.00 $0.00 $0.00 $0.00 $0.00 $28.68 $0.00 $0.00 $0.00 $10.50 $0.00 $0.00 $0.00 $0.00 $17.00 $138.60 $ 201.89

Case 2:02-cv-02641-ROS

Page 4 of 4 Document 69-3 Filed 11/04/2005

Page 34 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: October 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 25.9 $250.00 -----------------------$6,475.00 $141.16 $0.00 $0.00 ($0.00) -----------------------$6,616.16

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 35 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 09-02-03

09-05-03 09-08-03

09-09-03 09-11-03

09-15-03

09-16-03 9-17-09

DESCRIPTION Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding status of collection efforts against Technology Systems International, the Nevada company. Review research regarding Turnover Order. Commence drafting Motion for Turnover Order. Compile exhibits in support of Motion for Turnover Order. Review research regarding Attorney-Client Privilege. Finalize Motion for Turnover Order. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding Motion for Turnover Order. Telephone conference with Attorney Oman regarding Pretrial Conference. Review Order regarding Scheduling Conference. Review the Agenda for the Case Management Meeting of Judge Silver. Review proposed Rule 16 Scheduling Order of Judge Silver. Commence drafting of Proposed Case Management Plan. Review Federal Rules of Civil Procedure and Forms regarding Pretrial Conference. Telephone conference with Attorney Oman regarding Pretrial Conference. Telephone conference with Attorney Brovarone regarding dismissal of Alanco Technologies, Inc. Draft electronic mail to Mr. Peeper regarding dismissal of Alanco Technologies, Inc. Telephone conference with Attorney Oman regarding dismissal from lawsuit. Draft Partial Stipulation for Dismissal Without Prejudice. Draft Notice of Anticipated Partial Stipulation for Dismissal

TIME

0.5 1.0

3.0 2.0

0.7

5.0 0.2 7.0

Case 2:02-cv-02641-ROS

Page 2 of 4 Document 69-3 Filed 11/04/2005

Page 36 of 140

09-19-03

09-29-03

Without Prejudice. Draft cover letter to Attorney Oman regarding Partial Stipulation for Dismissal Without Prejudice. Research regarding intentional interference with a contractual relationship. Research regarding statute of limitations. Finalize and file Notice of Anticipated Partial Stipulation for Dismissal Without Prejudice. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding dismissal of Alanco Technologies, Inc. Review letter from Attorney Oman regarding Partial Stipulation for Dismissal Without Prejudice. Edit Partial Stipulation for Dismissal Without Prejudice. Draft Notice of Filing Partial Stipulation for Dismissal Without Prejudice. Draft proposed form of Order for Dismissal Without Prejudice.

3.0

3.5

TOTAL TIME:

25.9

Case 2:02-cv-02641-ROS

Page 3 of 4 Document 69-3 Filed 11/04/2005

Page 37 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: _________________________________ _________________________________ EXPENSE $24.56 $0.00 $0.00 $14.74 $0.00 $0.00 $101.86 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 141.16

Additional Information: _________________________________ _________________________________

Case 2:02-cv-02641-ROS

Page 4 of 4 Document 69-3 Filed 11/04/2005

Page 38 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: November 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 57.4 $250.00 -----------------------$14,350.00 $157.13 $6,616.16 $66.16 ($0.00) -----------------------$21,189.45

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 39 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 10-01-03

10-04-03 10-06-03 10-07-03

10-08-03

10-09-03

10-10-03

10-13-03

DESCRIPTION Telephone conference with Clerk of the Federal District Court regarding file closure. Telephone conference with Secretary to Judge Silver regarding attending Pretrial Conference telephonically. Prepare for and attend Pretrial Conference telephonically. Review Response to Motion for Turnover Order filed by Technology Systems International, Inc., a Nevada company. Telephone conference with Attorney Oman regarding restrictive covenants on shares of Alanco Technologies owned by Technology Systems International, Inc., the Nevada company. Review facsimile from Mr. Peeper regarding Mr. Seiz. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding Mr. Seiz. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding Turnover Order. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding Order of Dismissal. Telephone conference with Attorney Oman regarding potential distribution of shares of Alanco Technologies owned by Technology Systems International, Inc., the Nevada company. Prepare facsimile of Turnover Order to Computershare Trust Company, Inc. Draft electronic mail to Ms. Davis at Computershare Trust Company, Inc. Research regarding status of restrictive covenants on shares of Alanco Technologies owned by Technology Systems

TIME

0.5 3.0 0.8

1.3

2.5

0.5

0.5 4.0

Case 2:02-cv-02641-ROS

Page 2 of 4 Document 69-3 Filed 11/04/2005

Page 40 of 140

10-14-03

10-15-03 10-16-03

10-17-03

10-18-03

10-19-03 10-20-03 10-21-03 10-30-03

International, Inc., a Nevada company. Research regarding S-3 Registration of shares of Alanco Technologies owned by Technology Systems International, Inc., a Nevada company. Review Order regarding Reply in Support of Turnover Order Research regarding attorney--client privilege. Research regarding Form S-3 registration of shares of Alanco Technologies owned by Technology Systems International, Inc., a Nevada company. Research regarding turnover order. Research regarding corporate dissolution laws. Research regarding filings of Alanco Technologies, Inc., with the U.S. Securities and Exchange Commission. Additional research regarding attorney--client privilege. Commence drafting Reply in Support of Motion for Turnover Order. Review Response to Turnover Order filed by Technology Systems International, Inc., a Nevada company. Review filings of Alanco Technologies, Inc., with the U.S. Securities and Exchange Commission. Continue drafting Reply in Support of Motion for Turnover Order. Finalize Reply in Support of Motion for Turnover Order. Draft letter to Mr. Peeper and Attorney Brovarone regarding Reply in Support of Motion for Turnover Order. Telephone conference with Attorney Brovarone regarding case status.

3.5 0.1

8.0

8.0

8.0 8.0 8.0 0.5 0.2

TOTAL TIME:

57.4

Case 2:02-cv-02641-ROS

Page 3 of 4 Document 69-3 Filed 11/04/2005

Page 41 of 140

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: _________________________________ _________________________________ EXPENSE $157.13 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 157.13

Additional Information: _________________________________ _________________________________

Case 2:02-cv-02641-ROS

Page 4 of 4 Document 69-3 Filed 11/04/2005

Page 42 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: December 1, 2003 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 27.7 $250.00 -----------------------$6,925.00 $92.79 $0.00 $0.00 ($0.00) -----------------------$7,017.79

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 3 Document 69-3 Filed 11/04/2005

Page 43 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 11-03-03 11-05-03

11-11-03 11-13-03

11-17-03

11-18-03 11-19-03

11-21-03

11-22-03

DESCRIPTION Telephone conference with Mr. Peeper regarding case status. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding failure of Technology Systems International, Inc., a Nevada company, to comply with Revised Turnover Order. Commence research regarding contempt sanctions against Technology Systems International, Inc., a Nevada company. Continue research regarding contempt sanctions against Technology Systems International, Inc., a Nevada company. Research regarding contempt sanctions against Directors and Officers of Technology Systems International, Inc., a Nevada company. Review research regarding contempt sanctions. Draft Motion for Order of Contempt. Draft Affidavit in Support of Motion for Order of Contempt. Finalize Motion for Order of Contempt. Draft proposed form of Order of Contempt. Commence drafting Subpoena and Subpoena Duces Tecum for Directors of Technology Systems International, Inc., a Nevada company. Prepare Notice of Deposition for Directors of Technology Systems International, Inc., a Nevada company. Telephone conference with Attorney Proper, attorney for Technology Systems International, Inc., a Nevada company, regarding settlement. Review financial information of Alanco Technologies, Inc. Review facsimile letter from Attorney Proper, attorney for Technology Systems International, Inc., a Nevada company, regarding settlement. Draft electronic mail to Mr. Peeper and Attorney Brovarone regarding settlement offer from Technology Systems Page 2 of 3 Document 69-3 Filed 11/04/2005

TIME 0.4

0.2 5.0

6.0

6.0 4.0

2.5

1.5 0.6

Case 2:02-cv-02641-ROS

Page 44 of 140

11-26-03

International, Inc., a Nevada company. Telephone conference with Attorney Oman regarding case status. Telephone conference with Attorney Brovarone regarding settlement offer from Technology Systems International, Inc., a Nevada company, and contempt sancitons against Technology Systems International, Inc., a Nevada company.

1.5

TOTAL TIME:

27.7

EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: _________________________________ _________________________________ EXPENSE $12.11 $0.00 $0.00 $74.68 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $6.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 92.79

Additional Information: _________________________________ _________________________________

Case 2:02-cv-02641-ROS

Page 3 of 3 Document 69-3 Filed 11/04/2005

Page 45 of 140

Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: January 4, 2004 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 51.4 $250.00 -----------------------$12,850.00 $113.10 $0.00 $0.00 ($0.00) -----------------------$12,963.10

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

Page 1 of 4 Document 69-3 Filed 11/04/2005

Page 46 of 140

RETAINER REPORT OPENING BALLANCE: -------------------------------------APPLIED: DEPOSIT: -------------------------------------TOTAL RETAINER: $0.00 ----------------------($0.00) $0.00 ----------------------$0.00

TIME REPORT

DATE 12-01-03

12-02-03

12-08-03

12-09-03 12-13-03

12-14-03

DESCRIPTION Commence drafting Supplemental Motion for Order of Contempt against Technology Systems International, Inc., a Nevada company. Continue drafting Supplemental Motion for Order of Contempt against Technology Systems International, Inc., a Nevada company. Telephone conference with Clerk of the Bankruptcy Court for the District of Arizona regarding bankruptcy petition of Technology Systems International, Inc., a Nevada company. Telephone call to Attorney Proper regarding bankruptcy petition of Technology Systems International, Inc., a Nevada company. Review Voluntary Petition filed by Technology Systems International, Inc., a Nevada company. Draft electronic mail to Attorney Brovarone and Mr. Peeper regarding bankruptcy petition by Technology Systems International, Inc., a Nevada company. Initial research regarding Chapter 11 Bankruptcy and appointment of trustee in Chapter 11 Bankruptcy. Initial research regarding Proof of Claim in bankruptcy of Technology Systems International, Inc., a Nevada company. Initial research regarding application of automatic stay in bankruptcy of Technology Systems International, Inc., a Nevada company, to the Revised Turnover Order of the Federal District Court. Initial research regarding relief from automatic stay in bankruptcy of Technology Systems International, Inc., a Nevada company. Initial research regarding contempt proceeding before the Bankruptcy Court. Review Notice of Filing for Bankruptcy filed by Technology Systems International, Inc., a Nevada company. Initial research regarding jurisdiction of Bankruptcy Court versus

TIME

1.2

3.4

0.5 3.0

6.5

3.6

Case 2:02-cv-02641-ROS

Page 2 of 4 Document 69-3 Filed 11/04/2005

Page 47 of 140

12-15-03

12-16-03

12-18-03

12-19-03

12-22-03 12-24-03

12-26-03

jurisdiction of Federal District Court as provided for in the Judgment by Default Against Technology Systems International, Inc. Research regarding local rules of procedure for Bankruptcy Court in the District of Arizona and the local rules of procedure for the District Court in the District of Arizona. Continue research regarding application of automatic stay in bankruptcy of Technology Systems International, Inc., a Nevada company, to the Revised Turnover Order of the Federal District Court. Continue research regarding relief from automatic stay in bankruptcy of Technology Systems International, Inc., a Nevada company. Research regarding Continue research regarding jurisdiction of Bankruptcy Court versus jurisdiction of Federal District Court as provided for in the Judgment by Default Against Technology Systems International, Inc. Telephone conference with Attorney Brovarone regarding bankruptcy petition by Technology Systems International, Inc., a Nevada company. Review file at Maricopa County Superior Court Clerk regarding Technology Systems International, Inc. v. Alanco Technologies, Inc., Superior Court of the State of Arizona, County of Maricopa, Case No. CV2003-1937, sub nom. Richard Jones v. Alanco Technologies, Inc. Review file at Bankruptcy Court Clerk regarding bankruptcy of Technology Systems International, Inc., a Nevada company. Initial research regarding application of automatic referral from Federal District Court to Bankruptcy Court in the District of Arizona. Continue research regarding withdrawal of reference of jurisdiction of Bankruptcy Court by the Federal District Court. Telephone conference with Attorney Oman regarding bankruptcy petition of Technology Systems International, Inc., a Nevada company. Telephone conference with Attorney Brovarone regarding bankruptcy petition by Technology Systems International, Inc., a Nevada company. Commence drafting Motion to Withdraw Reference in Whole. Research regarding bad faith filing for bankruptcy protection by Technology Systems International, Inc., a Nevada company. Continue drafting Motion to Withdraw Reference in Whole.

4.5

6.1

6.1

3.8 3.0

4.5 5.2

TOTAL TIME:

51.4

Case 2:02-cv-02641-ROS

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EXPENSE REPORT DESCRIPTION Photocopying Document Scanning Hand Delivery Express, Certified & Non-Standard Mail Long Distance Outgoing Facsimile Long Distance Telephone International Telephone Room Board Travel & Mileage Parking Computerized Legal Research Research Report & Material Judicial & Government Filing Bank Transaction Miscellaneous--1 (Described Below) Miscellaneous--2 (Described Below) TOTAL EXPENSES: Miscellaneous Expenses: _________________________________ _________________________________ EXPENSE $108.10 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $ 113.10

Additional Information: _________________________________ _________________________________

Case 2:02-cv-02641-ROS

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Law Office Of Michael Simes
Federal Tax Employer Identification Number: 86-1034853 PRIVILEGED AND CONFIDENTIAL

U.S. Mail Address: 903 South Rural Road Suite 101--323 Tempe, Arizona 85281 Telephone: 480-699-3636 Facsimile: 480-659-2943 Website: www.MichaelSimes.com E-Mail: [email protected]

INVOICE FOR LEGAL SERVICES
Invoice Date: February 2, 2004 Client: Solinvest Group, Ltd. c/o Dennis Brovarone Law Office of Dennis Brovarone 18 Mountain Laurel Drive Littleton, Colorado 80127

SUMMARY REPORT DESCRIPTION TOTAL TIME:1 HOURLY RATE: ---------------------------------------------TIME/RATE SUBTOTAL: TOTAL EXPENSE:2 OUTSTANDING BALANCE: INTEREST:3 PAYMENT APPLIED: ---------------------------------------------TOTAL AMOUNT DUE:4 AMOUNT 23.8 $250.00 -----------------------$5,950.00 $371.25 $12,963.10 $0.00 ($0.00) -----------------------$19,284.35

See Time Report. See Expense Report. 3 Interest is computed at one percent (1.0%) per month, compounded monthly, on the Outstanding Balance. 4 THIS IS THE AMOUNT TO BE PAID. PAYMENT IN FULL IS DUE UPON RECEIPT OF THIS INVOICE BUT IN NO EVENT LATER THAN TWENTY (20) CALENDAR DAYS AFTER THE INVOICE DATE. CHECKS SHOULD BE MADE PAYABLE TO: Law Office Of Michael Simes.
2

1

Case 2:02-cv-02641-ROS

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