UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

Case No . 03-80612 CIV -MARRA/VITUNAC

SECURITIES AND EXCHANGE COMMISSION

Plaintiff,

V .

MICHAEL LAUER ,LANCER MANAGEMENT GROUP, LLC, andLANCER MANAGEMENT GROUP II, LLC ,

Defendants ,

and

LANCER OFFSHORE, INC .,LANCER PARTNERS, LP,OMNIFUND, LTD. ,LSPV, INC ., and LSPV, LLC ,

Relief Defendants .

In re :

LANCER PARTNERS L .P.,

Debtor .

NIGHT BOXFILE D

MAY 16 2005CLARENCE MADDOX

CLERK, USDC/SDFL/FTL

Chapter 11 Cas eCase No . : 04-80211 -CIV-MARRA

SUMMARY OF NOTICE OF SIXTH INTERIM APPLICATION FORAUTHORIZATION TO PAY (I) RECEIVER'S ATTORNEYS' FEES AND COSTS, (II )

RECEIVER'S FEES AND (III) RECEIVER'S INVESTIGATIVE FEES FROMRECEIVERSHIP FUNDS

(Request for Relief in Receivership Proceeding Only )

If no party files and se rves an objection to this Notice on orbefore ten days from the date of se rvice indicated on theCertificate of Se rvice attached hereto , the Receiver shall be

Case N., . 03-80612 CIV -MARRAJVITUNAC

automatically empowered to perform the intended actionwithout further order from this Court. '

1 . Name of Applicant Hunton & Williams LLP

2 . Role of Applicant Counsel for the Receive r

3 . Name of certifying professional Craig V . Rasile

4 . Date Case Filed July 8, 2003

5 . Date of Application for Employment October 3, 200 3

6 . Date of Order approving employment October 14, 2003 (nunc pro tunc to July 10, 2003 )

7 . Date of Order appointing Receiver July 10, 2003

8. Date of this Application May 26, 200 5

9. Date of services covered December 1, 2004 through March 31, 200 5

Fees . . .

10. Total fee requested for this period (from Exhibit 1-A) $1,241,257.23

11 . Balance remaining in fee retainer account, not yet awarded $0.00

12 . Fees paid or advanced for his period, by other sources $0.00

13 . Net amount of fee requested for this perio d

Expenses . . .

$1,241,257.23

14 . Total expense reimbursement requested for this period $79,982.60

15 . Balance remaining in expense retainer account, not yet received $0.00

16 . Expenses paid or advanced for this period, by other sources $0.00

17 . Net amount of expense reimbursements requested fo r

this period

$79,982.60

18 . Gross award requested for this period (#10 + #14) $1,321,239.83

19 . Net award requested for this period (#13 + #17) $1,321,239.83

'Pursuant to the Court's January 8, 2004 Case Management Order, no compensation will be paid by theReceiver before the Court enters an order awarding such compensation or (30) thirty days after this Notice ofCompensation to ensure that even if no party in interest objects within ten (10) days of service, the Court will havean additional twenty (20) days to consider the Notice of Compensation and, if the court deems necessary, schedule ahearing on the Notice of Compensation .

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Case N . , . 03-80612 CIV-MARRA/VITUNAC

History of Fees and Expenses

Dates covered by first application July 10 , 2003 through September 30, 2003

1 . Dates, sources, and amounts of retainers received :Dates Sources Amounts For fees and costsNone

2. Dates, sources, and amounts of third party payments received :Dates Sources Amounts For fees and costsNone

3 . Prior Fee and expense award to Hunton & Williams LLP $994,532 .86Prior Fee and expense award to Turnstone Investigation Group $166,537 .89Prior Fee and expense award to the Receiver $55,600 .00

Dates covered by second application: October 1, 2003 through November 30, 2003

1 . Dates, sources, and amounts of retainers received :Dates Sources Amounts For fees and costsNone

2. Dates, sources, and amounts of third party payments received :Dates Sources Amounts For fees and costsNone

3 . Prior Fee and expense award to Hunton & Williams LLP $653,508 .46Prior Fee and expense award to Turnstone Investigation Group $42,570 .00Prior Fee and expense award to the Receiver $32,300 .00

Dates covered by third application : December 1, 2003 through February 29, 2004

1 . Dates, sources , and amounts of retainers received :Dates Sources Amounts For fees and costsNone

2 . Dates, sources , and amounts of th ird party payments received :Dates Sources Amounts For fees and costsNone

3 . Prior Fee and expense request on behalf of Hunton & Williams LLP $975,658 .21Prior Fee and expense request on behalf of Tu rnstone Investigation Group $32,856.00Prior Fee and expense request on behalf of the Receiver $ 13,800 .00

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Case N . 03-80612 CIV-MARRANITUNA C

Dates covered by fourth application : March 1, 2004 through June 30, 2004

1 . Dates, sources, and amounts of retainers received :Dates Sources Amounts For fees and costsNone

2. Dates, sources, and amounts of third party payments received :Dates Sources Amounts For fees and costsNone

3 . Prior Fee and expense request on behalf of Hunton & Williams LLP $1,365,512 .30Prior Fee and expense request on behalf of Turnstone Investigation Group $49,219 .50Prior Fee and expense request on behalf of the Receiver $86,254 .80

Dates covered by fifth application : July 1, 2004 through November 30, 2004(Fees requested but not yet awarded )

1 . Dates , sources , and amounts of retainers received :Dates Sources Amounts For fees and costsNone

2 . Dates, sources , and amounts of third party payments received :Dates Sources Amounts For fees and costsNone

3 . Prior Fee and expense request on behalf of Hunton & Williams LLP $1,557,389.10Prior Fee and expense request on behalf of Tu rnstone Investigation Group $53 ,395 .80Prior Fee and expense request on behalf of the Receiver $63.040.00

4

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORID A

FORT LAUDERDALE DIVISIONCase No. 03-80612 CIV-MARRA/VITUNAC

SECURITIES AND EXCHANGE COMMISSION

Plaintiff,

V .

MICHAEL LAUER,LANCER MANAGEMENT GROUP , LLC, andLANCER MANAGEMENT GROUP II, LLC,

Defendants,

and

LANCER OFFSHORE, INC .,LANCER PARTNERS, LP,OMNIFUND, LTD . ,LSPV, INC., and LSPV, LLC ,

Relief Defend ants .

In re :

LANCER PARTNERS L .P.,

Debtor .

Chapter 11 CaseCase No . : 04-80211 -CIV-MARRA

NOTICE OF RECEIVER'S SIXTH INTERIM APPLICATION FOR AUTHORIZATIONTO PAY (I) RECEIVER'S ATTORNEYS' FEES AND COSTS . (II) RECEIVER'S FEES

AND (III) RECEIVER'S INVESTIGATIVE FEES FROM RECEIVERSHIP FUNDS(Request for Relief in Receivership Proceeding Only )

If no party files and serves an objection to this Notice on orbefore ten days from the date of service indicated on theCertificate of Service attached hereto, the Receiver shall beautomatically empowered to perform the intended actionwithout further order from this Court . 2

2Pursuant to the Court' s January 8, 2004 Case M anagement Order, no compensation will be paid by the

Receiver before the Court enters an order awarding the compensation or (30 ) thirty days after this Notice of

Compensation to ensure that even if no party in interests objects wi thin ten (10 ) days of se rvice, the Court will have

(continued . . . )

Case Iv ,, . 03-80612 CIV -MARRA/VITUNAC

Marty Steinberg, Esq ., court-appointed receiver (the "Receiver") of Lancer Management

Group LLC ("Lancer"), Lancer Management Group II LLC ("Lancer II"), Lancer Offshore Inc .

("Offshore"), Omnifund Ltd . ("Omnifund"), LSPV Inc . ("Offshore LSPV"), LSPV LLC

("Partners LSPV"), Alpha Omega Group Inc. ("Alpha Omega") and G.H. Associates LLC

("G.H . Associates")("G .H. Associates" together with Offshore, Omnifund, Offshore LSPV,

Partners LSPV, Lancer, Lancer II and Alpha Omega, the "Receivership Entities"), and the

responsible person in control of Lancer Partners, L .P. ("Partners") ("Partners" together with the

Receivership Entities, the "Lancer Entities"), through undersigned counsel and pursuant to the

Court's Order Appointing Receiver dated July 10, 2003 (the "Receivership Order"), and the Case

Management Order dated January 8, 2004 (the "CMO"), hereby requests the Court to enter an

order authorizing him to pay : (i) the reasonable attorneys' fees and costs incurred by Hunton &

Williams LLP, ("H&W") as reported in this Sixth interim fee notice (the "Notice") ; (ii) the

Receiver's fees as reported in this Notice ; and (iii) the investigative fees for Turnstone

Investigative Group ("TIG"), a subsidiary of H&W, as reported in this Notice, for the period July

1, 2004 through November 30, 2004, (the "Application Period") .

Pursuant to the powers granted to the Receiver under the Receivership Order, the

Receiver has employed, and the Court has approved, the Receiver's retention of H&W and TIG,

a subsidiary of H&W .

By this Notice, the Receiver requests authority to pay his professionals for their fees and

costs for services rendered during the Application Period, from the Receivership Entities, a s

an additional twenty (20) days to consider the Notice of Compensation and, if the Court deems necessary, schedule ahearing on the Notice of Compensation .

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Case N ., . 03-80612 CIV -MARRA /VITUNAC

follows : H&W, in the amount of $1,174,516 .23 for fees and $79,982 .60 in costs; TIG in the

amount of $48 ,270.00 for fees ; and the Receiver in the amount of $18,471 .00 for fees for a total

award of $1,321,239.83 .3

DESCRIPTION OF SERVICES

During the Application Period, H&W, TIG and the Receiver rendered extensive and

necessary services for and on behalf of the estates of the Receivership Entities , as set forth

below . The following categories describe the services rendered and summarize the fees

requested by H&W, TIG and the Receiver during the Application Period . Pursuant to Court

Order, the invoices and additional suppo rt for this Notice will be filed with the Court under seal .

1 .Hunton & Williams . LLP

1 . Case Administratio n

During the Application Period, H&W continued to advise and confer with the Receiver

and interested parties in respect of the progress of the receivership case . H&W consulted with

the Steering Committee and various investor constituents about an effort to move the case toward

an interim distribution to investors, the possibilities of in kind distributions, and strategies for an

ultimate plan of distribution, including the possible substantive consolidation of the Funds 4

'This Application does not include fees and expenses incurred for Partners, which is not a ReceivershipEntity . All fees and expenses incurred for the exclusive benefit of Partners are being requested by separateapplication to the Bankruptcy Court . Insofar as the Receivership Entities and Partners have many common portfolioholdings, however, some of the services rendered for the benefit of the Receivership Entities also benefited Partners .The extent and value of the holdings in the various Funds and related entities remains unclear, in large part becausethe records of the Funds and related entities recovered by the Receiver were incomplete and in disarray. As a result,the Receiver has estimated the fees and costs attributed to each fund based upon each fund's ownership of thevarious positions in their respective portfolios and the work performed for the benefit of each portfolio .Nevertheless, the Receiver reserves the right to reallocate a portion of the fees and costs incurred by theReceivership Entities to Partners at the appropriate time in the future .

4 The Funds shall be defined herein to include Partners, Offshore, Omnifund, Partners LSPC and Offshore

LSPV .

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Case Nu . 03-80612 CIV -MARRA/VITUNAC

and/or the Management Companies5 . H&W has also continued extensive dialogue with counsel

for the Group Plaintiffs in respect of the cases and various litigation components, as well as a

form of cooperation agreement to establish a formal framework for joint or common efforts and

sharing information .

During the Application Period, H&W prepared and filed a motion with the Court to

approve a protocol to be used for making an interim distribution . The motion had the desired

effect of opening up a formal dialogue with the investor constituents about distribution and claim

issues. H&W and counsel for the Group Plaintiffs and both bankruptcy committees negotiated

and agreed to the form of an order granting a portion of the relief requested in the motion and

withdrawing the remainder while the parties continue their dialogue . In particular, the parties

agreed that the Receiver should analyze claims based on the net invested capital of each of the

investors : that is, on a cash basis the amount of capital invested less the amount of funds

redeemed. The only parties to file formal opposition to the Receiver's motion were Michael

Lauer and his one-time counsel, Leonard Hecht. Lauer and Hecht oppose the use of net invested

capital for purposes of analyzing claims, and instead support analyzing claims based on the

number of shares held by each investor in the Funds . H&W has filed papers in reply to the

objections filed by Lauer and Hecht . The motion remains pending .

To further the efforts to conclude several pending matters, H&W filed certain requests for

status conferences before the court and advised the court of pending matters, including a

comprehensive litigation status report . H&W also worked on a comprehensive status report for

the Receiver and the SEC. During the Application Period, H&W participated in multipl e

5 The Management Companies shall be defined herein to include Lancer and Lancer II .

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Case Nu . 03-80612 CIV -MARRA/VITUNA C

conferences with the Receiver and various parties, including several conferences with th e

Steering Committee . H&W continued to communicate with investors in connection wi th

transfers of their interests .

H&W is requesting $57,077 .85 in attorney 's fees for 152 .00 hours in connection wi th

Case Administration.

2 . Asset Analysis and Recovery

During the Application Period , H&W continued its analysis of various portfolio

compan ies . Among other things, H&W continued its extensive due diligence regarding Zi

Corporation ("Zi" or "Zi Corp.") and analyzed its con trol position therein . H&W held numerous

conferences with DDJ, the Receiver ' s investment advisor, concern ing the value of Zi and the

direction the Receiver should pursue to maximize the estate ' s interest in Zi . H&W also

addressed numerous issues affecting registration rights, securities filings and disclosure issues .

Additionally , H&W, in consultation with DDJ, handled the proxy voting on behalf of the

Receiver for a number of securities held in the portfolio. H&W prepared insider trading repo rts

and analyzed employee agreements and director and officer insur ance liability issues for various

portfolio compan ies . H&W reviewed records from transfer agents and portfolio compan ies

regarding holdings . H&W reviewed and analyzed issues relating to transfer restrictions on

certain securities and analyzed the potential litigation impact on m any po rtfolio compan ies .

H&W also responded to various audit inquiries from portfolio compan ies and began making

demands on certain po rtfolio compan ies to which L ancer had extended loans .

With respect to the assets of the Receivership Entities, H&W held numerous conferences

with DDJ regarding the liquidation of certain securities , auctioning certain investment positions

and resolving certain transfer obstacles . H&W researched and analyzed me thods for removin g

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Case No . 03 - 80612 CIV - MARRA/VITUNAC

res tr ictions on certain securities to enable a timely sale of and mean ingful recovery from the

securities . H&W also held discussions and conference calls with current and former principals

and employees of various po rtfolio compan ies as part of the overall analysis of the holdings .

H&W also continued to review documents , including public filings , correspondence from

various th ird part ies , bank statements , broker statements, financial statements , docket sheets

from pertinent pending litigation and EDGAR filings . H&W continued its effo rts to locate,

verify and analyze the holdings of the Receivership Entities . H&W also held numerous

telephone conferences wi th investors to address questions they had regarding the Funds'

holdings , and responded to written inquiries from certain investors .

During the Application Period, H&W continued to review proposed transactions for

certain portfolio compan ies and researched securities laws and issues affecting directors for

certain portfolio compan ies . H&W also addressed issues with respect to the freeze of Lauer's

assets , the ownership of ce rtain assets including the GMC Denali SUV, and the use of

Receivership Entities ' funds to acquire personal assets by the insiders .

During the course of its investigation, H&W uncovered evidence that Lauer used funds

belonging to Offshore to purchase a 1990 Mercedes -Benz C-11-05 racecar, potentially worth

millions of dollars, in the name of an entity called CLR Associates, LLC ("CLR") . As a result,

on February 1, 2005 the Receiver filed a motion to expand the receivership to include CLR so

that the racecar can be returned to the estate for liquidation . Lauer contested the motion . The

Receiver ' s motion remains pending before the Court.

Finally, H&W analyzed the impact that avoidance actions and o ther litigation might have

on certain companies remaining in the portfolio . H&W also analyzed documents and

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Case Nu . 03 - 80612 CIV - MARRA/VITUNA C

information in connection with the Lancer Management Group Money Purchase Plan and the

securities held by the plan .

H&W is requesting $92,456 .73 in attorney's fees for 335 .90 hours in connection with

Asset Analysis and Recovery .

3 . Asset Disposition

During the Application Period, H&W conferred with DDJ concerning the possible

proposals to sell certain securities . H&W spent a significant amount of time addressing investor

concern arising from the Receiver's intention to commence with limited sales of Zi Corp . on the

public markets. H&W communicated with counsel for the Group Plaintiffs, the bankruptcy

committees and other investor groups . H&W coordinated a widely-attended conference call with

DDJ to discuss the strategies with respect to the proposed Zi sales and ultimately found investor

support for the proposed transactions . Lauer, on the other hand, filed an emergency motion to

halt the sales. H&W responded and Lauer's motion was ultimately denied. Lauer sought

reconsideration of the order denying his motion and has recently appealed the order to the United

States Court of Appeals for the Eleventh Circuit . H&W continues to communicate with the

investor constituents about the progress of Zi and other securities sales .

In addition, H&W continued to correspond with DDJ with respect to the disposition of

certain other portfolio companies and their assets . H&W also conferred with transfer agents

concerning the removal of restrictive legends on various securities and continued to field

numerous offers for portions of the Funds' portfolios . H&W also continues to field offers for

various securities, including from certain portfolio insiders . Finally, H&W is continuing to

explore alternative methods for disposing of certain po rtfolio companies in bulk, including a

possible auction sale .

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Case Nt. . 03-80612 CIV -MARRA/VITUNAC

H&W is requesting $78,536 . 35 in attorney ' s fees for 260 . 10 hours in connection with

Asset Disposition .

4 . Investor/Creditor Communications

H&W continued to respond to investor inquiries through a toll free number, (866) 285-

5897, and an e-mail address, lancer@hunton . com, so investors and other interested parties may

contact the Receiver for information at any time . H&W further updated and maintained the

Receiver 's web page at www.hunton .com, which has a link that contains relevant information

and certain pleadings specific to this matter . H&W is also maintaining an Investor Contact Sheet

for future communications and notices . H&W regularly fields investor inquiries through these

channels .

During the Application Period , H&W fielded numerous calls from investors wi th general

inquiries involving tolling agreements , the claims objection process, late claims , transfer

agreements , the disclosure of investments of beneficial owners that might impact an investor's

willingness to execute such transfer agreements . During the Application Period , H&W routinely

communicated with counsel for individual investors and groups of investors to keep them abreast

of the status of significant events in the receivership .

Additionally , during the Application Period, H&W communicated extensively wi th

investors and counsel in connection with a common interest and no- trade agreement to facilitate

the exchange of information in connection wi th Zi and other portfolio sales, the proposed

cooperation agreement with the counsel for the Group Plaintiffs , and the exchange of additional

information to certain investor groups .

H&W is requesting $20,313 .72 in attorney ' s fees for 67 .90 hours in connection wi th

Investor Meetings .

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Case No . 03-80612 CIV -MARRA/VITUNAC

5 . Fee/Employment Application s

During the Application Period , H&W prepared its fifth interim fee application and

commenced with the preparation of th is six th interim application . H&W also prepared and filed

the seven th, eighth and nin th interim fee applications for DDJ and assisted with the preparation

and filing of the seventh application for BDPB , as well as applications for Kapila & Co, Sender

& Wasserm an, CBIZ, Fasken Martineau, and Colson Hicks . H&W prepared for and attended

the fee hearing on twelve different fee applications on December 28, 2004 and prepared

numerous schedules summarizing the applications for the professionals pending at the time .

H&W regularly communicates wi th DDJ and other professionals in respect of pending fee issues .

H&W is requesting $70,999 .97 in attorney 's fees for 276 .30 hours in connection with

Fee/Employment Applications .

6 . Fee Application/Employment Application Objections :

During the Application Period , the Group Plaintiffs objected to BPDB ' s seventh and

H&W's fifth interim applications . H&W prepared a detailed response to the objection and

conferred wi th counsel for the Group Plaintiffs regarding the same . Finally , Lauer objected to

numerous fee applications and H&W responded in similar fashion .

H&W is requesting $24,695 . 07 in attorney 's fees for 79.80 hours in connection with Fee

Employment Objections .

7 . Plan of Distr ibution

During the Application Period , H&W conferred with the Receiver about the format for a

plan of distribution . H&W communicated with the Steering Committee and various counsel

regarding the same . H&W prepared the motion to approve a protocol for interim dis tributions

and ultimately prepared an agreed order granting part ial relief related to the treatment of investo r

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Case No . 03-80612 CIV -MARRAIVITUNAC

claims on a net invested capital basis . H&W also analyzed the possibilities of in-kind

dis tr ibutions and various hurdles to same .

H&W is requesting $5,987 .35 in attorney's fees for 19.30 hours in connection with Plan

of Distribution .

8 . Preparation and Review of Report s

During the Application Period, H&W prepared and filed quarterly financial reports

summarizing the cash flow of the Receivership Entities during the receivership . H&W also

prepared and filed a Litigation Status Report which detailed the status and pending motions in

the numerous ancillary proceedings at the time .

H&W is requesting $3,180.00 in attorney ' s fees for 12 .80 hours in connection with

Preparation and Review of Reports .

9 . Business Operation s

During the Application Period, H&W continued to analyze and address numerous

operational issues at the po rtfolio company level, including changes in the board of directors .

Additionally, H&W continued to review and respond to business mail directed to the

Receivership Entities . H&W fielded correspondence from certain stock exchanges related to the

operations . H&W also handled certain correspondence and issues related to the maintenance of

the Receivership Entities . H&W and the Receiver continue to review and communicate

extensively with certain investors regarding the Consent to Transfer Agreements , including

issues related to transfers for beneficial versus nominal holders. H&W has also solicited offers

from several financial institutions with regard to the maintenance of the receivership accounts to

ensure the maximization of return on the receivership funds. Finally, H&W continued to

negotiate agreements with a new prime broker for the Funds .

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Case Nu . 03-80612 CIV-MARRA/VITUNAC

H&W is requesting $46,051 . 14 in attorney ' s fees for 157 .10 hours in connection wi th

Business Operations .

10 . Accounting/Auditing

During the Application Period , H&W worked with the Receiver's forensic

accountants with respect to their analysis and extensive on-going effo rts to create cash

reconciliations for each Receivership Entity necessitated largely by the absence of customary

books and records. Consequently, the accountants have created a forensic database of the history

of these funds . The database is not yet complete , but H&W is now able to use the database in

connection with its efforts to locate and analyze assets and possible litigation targets .

Additionally , H&W worked closely wi th the accountants in connection wi th the analysis

of certain portfolio transactions and confirmation of ce rtain holdings and securities transactions .

H&W also worked with the accountants wi th respect to certain securities trading analyses,

relationship schedules , valuation analysis and account reconciliations .

H&W is requesting $7,454 . 11 in attorney ' s fees for 21 . 70 hours in connection wi th the

preparation , filing and analysis of accounting related matters .

11 . Employee Benefits

During the Application Period, H&W analyzed the Lancer Management Group Money

Purchase Pl an , the various duties that may arise under the plan and the possible termination of

the plan . Additionally , H&W fielded communications from the Department of Labor inquiring

about certain ERISA related matters .

H&W is requesting $7,615 .00 in attorney ' s fees for 22 .80 hours in connection wi th

Employee Benefits .

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Case Nu . 03-80612 CIV-MARRA/VITUNAC

12 . Data Analysi s

During the Application Period, H&W analyzed the schedules of payments to

intermediaries and consultants, payee lists for the Receivership Entities, cash and redemption

reports, spreadsheets of restrictive legends, financial reports, custodial statements and

transactional details of executing brokers and spreadsheets for confirmation of holdings . In

addition, H&W and the Receiver analyzed certain data reflected on the "blue sheets" obtained by

the SEC which track activity for publicly traded securities . Specifically, the blue sheets reflect

trade data of certain of the holdings of the Funds . H&W, along with BDPB, met with the SEC to

better understand the blue sheets, which will ultimately suppo rt certain litigation to be brought

by the Receiver .

H&W is requesting $225 .61 in attorney's fees for .50 hour in connection with Data

Analysis .

13 . Department of Justice Investigation

Pursuant to the Receivership Order, the Receiver and H&W continued to cooperate and

meet with various federal law enforcement agencies and their representatives including the SEC,

FBI, U .S. Marshal's Office and the Department of Justice regarding this proceeding. The

Receiver and his professionals have had several formal and informal meetings and conference

calls with the federal agencies in connection with the Receivership .

H&W is requesting $689 .92 in attorney's fees for 1 .80 hours in connection with the

Department of Justice Investigation .

14 . Document Management

H&W and the Receiver continued to issue subpoenas to various individuals and entities ,

including banks, brokers, investors and administrators, among others. As a result of these

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Case Nu. 03-80612 CIV-MARRA/VITUNAC

efforts, H&W has received hundreds of thousands of documents . As documents are obtained and

recovered , they are imaged and scanned into a database that is full-text searchable .

H&W has implemented a comprehensive system to review and analyze the documents .

The Receiver ' s professionals have worked in tandem to establish a protocol for reviewing the

documents to ensure that the review is both thorough and efficient . The review has focused on

identification of assets ; location of documents confirming the debt and equity holdings in the

portfolio compan ies ; identification of potential litigation claims against th ird parties and insiders

of the Lancer Entities ; reconciliation of all accounts of the Lancer Entities ; and analysis of all

transfers from the Lancer Entities . H&W continues to update the current databases with new

fields to assist in th is review and continues to improve the comprehensive system to analyze

documents relating to the receivership . H&W also continues to work wi th its accountants to

refine the document management process, and to create efficiencies in the review of documents .

H&W prepares logs reflecting new documents that are obtained and the dates that these

documents are scanned onto the text searchable database so that the Receiver 's professionals c an

follow-through wi th the original intent of the document requests .

H&W is requesting $36,013 .38 in attorney ' s fees for 386 .50 hours in connection with

Document Management .

15 . Document Revie w

A continuing goal of the document review process has been to ascertain the specific

holdings of the Lancer Entities in the portfolio compan ies to enable the Receiver to administer

these positions for the benefit of investors and creditors . To determine the extent of the Lancer

Entities ' investment positions in the portfolio companies, as well as any additional rights or

responsibilities with respect to any security comprising an investment position , H&W has

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Case No . 03-80612 CIV -MARRA/VITUNAC

continued to review the documents seized from the offices of the Receivership Entities as well as

documents produced in response to subpoenas served by the Receiver . During the Application

Period, the Receiver's professionals have focused on reviewing documents produced by transfer

agents and portfolio companies in an effort to ascertain whether and to what extent the holdings

as reported on the prime broker's portfolio statements are accurate .

During the Application Period, H&W and the Receiver also refined a document review

protocol aimed at identifying documents to support causes of action against various third parties,

including insiders and service providers . Shortly after the Application Period, the Receiver filed

a 49-page, eight count complaint against Lauer and a number of other insiders, including Martin

Garvey, Eric Hauser, Milton Barbarosh, James Kelley and David Newman, among others . In

connection with preparing this complaint, H&W expended significant efforts reviewing the

online database of hundreds of thousands of documents by focusing searches on these

individuals and various companies with which they are affiliated .

During the Application Period , the Receiver also filed actions against certain po rtfolio

compan ies and serv ice providers , including the Offshore Funds ' administrator, Citco Fund

Serv ices (Curacao) and Citco Fund Serv ices (U.S.A.) (Collectively, "Citco") . In preparing the

complaints commencing these actions , H&W focused its effo rts on conduction specific searches

on the online database relating to Citco.

As H&W and the Receiver review incoming documents, they further refine their

understanding of the individuals who played a critical role in the depletion of the Receivership

Entities . This more refined review has assisted the Receiver in the preparation of complaints and

follow-up discovery .

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Case N. . . 03-80612 CIV-MARRANITUNAC

The Receiver and H&W also reviewed documents to analyze other assets of the Lancer

Entities, including bank accounts , insurance policies and the Mercedes C-11 race car .

H&W is requesting $142,953 .65 in attorney 's fees for 979 . 00 hours in connection wi th

Document Review .

16 . Investigation

During the Application Period , H&W continued to work with TIG regarding leads to

follow for the Receiver ' s investigation , witnesses to interv iew or depose, financial institutions,

serv ice providers and professionals to interv iew.

H&W is requesting $21,987 .50 in attorney's fees for 70 .20 hours in connection with the

Investigation category .

17 . Securities Complianc e

During the Application Period , H&W and the Receiver continued their efforts , to ensure

that the Receiver and the Funds comply wi th applicable U .S . and Canadian securities laws .

H&W consulted with local counsel in Canada to assist with several issues relating to

Canadian securities laws and to prepare and file certain reports required thereby. H&W

continued to analyze the scope of the Receiver ' s repo rt ing obligations , and the dates that certain

security repo rts are due . Among o ther things , H&W performed extensive legal research and

prepared memoranda concern ing non-exchange , public-market sales; notices required by the

NASDAQ and Toronto Stock Exchange with respect to the sales of certain holdings; proper

methods for removing restrictive language on certain holdings to enable the sale of such

holdings ; amendment requirements under Section B of the Securities and Exchange Act of 1934 ;

and the definitions of "affiliate " and "current public information" under Rule 144 .

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Case N . 03-80612 CIV -MARRA/VITUNAC

In addition , H&W prepared and filed various Schedule 13D in the United States reports

relating to a number of the Funds' holdings . The 13D reports reflect the extent of the Funds'

holdings in a part icular company .

H&W is requesting $28,054 .40 in attorney ' s fees for 139 . 90 hours in connection with

Securities Compliance .

18 . Tax Issues

Lancer, Lancer II, GH Associates and Alpha Omega failed to file tax returns for the 2001

tax year as well as all subsequent tax years . Tax returns for 2003 for L ancer Partners, LP,

Lancer Management Group, LLC, Lancer Management Group II, LLC, Alpha Omega Group,

Inc . and GH were on extension until December 30, 2003 . H&W has assisted in the efforts of the

Receiver ' s accountants in preparing books and records for these entities from documents

produced by Harold Zoref CPA, B anc of America Securities , Fleet Bank and Chase Manhattan

Bank . The books and records re-created will be utilized to suppo rt the preparation of the 2003

returns as well as the 2001 and 2002 returns for the Receivership Entities (2001 and 2002 tax

returns for the Receivership Entities were delinquent prior to the receivership) . There are a

number of unresolved issues that must be rectified prior to the completion of the tax returns for

the Receivership Entities . The accountants have prepared open item lists for each entity by year

and are working to resolve these issues . The receivership returns will be filed as soon as the

remaining open issues are resolved . H&W is communicating regularly with the accountan ts

regarding these tax issues as well as resolution of the open items . H&W has corresponded with

the IRS wi th respect to the various tax returns due for the receivership entities as well as certain

investigations by the IRS into Lauer' s tax issues .

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Case Nu . 03-80612 CIV-MARRA /VITUNAC

H&W is requesting $15,151 .72 in attorney ' s fees for 37 .40 hours in connection wi th Tax

Issues .

19 . Claims Adminis tration /Objections

During the Application Period , H&W and the Receiver have been working with the

accountants in the review of the claims and voluminous suppo rt ing documents. With the

assistance of the accountants, H&W has commenced the preparation of a comprehensive claims

report and omnibus objections to claims by category . H&W and the accountants have spent a

significant amount of time analyzing and confirming the net invested capital for each investor .

This process was delayed significantly by the absence of complete production of documents by

Citco evidencing individual investors ' contr ibutions and redemptions . It is made more di fficult

due to the large number of investors subscribing to the funds through nominal holders and the

massive volume of inter- investor and inter-nominee transfers .

During the Application Period , H&W has also continued to communicate wi th investors

regarding the status of their respective claims, objection to claims, the use of net invested capital,

and claims wi th insufficient documentation . H&W has also reviewed numerous investor replies

and conferred with numerous claimants in connection with the claims .

H&W is requesting $17,431 .72 in attorney's fees for 78 . 40 hours in connection wi th time

expended in the Claims Administration/Objections catego ry .

20 . Litigation - General

During the Application Period, H&W undertook substantial efforts researching law and

investigating facts relevant to potential litigation by the Receiver against numerous targets and

potential defenses to such litigation . Among other things , H&W updated its research on the

applicability of the in pari delicto defense to actions by Receiver ' s against third parties. H&W

21

Case N ., . 03-80612 CIV-MARRA/VITUNAC

identified a case decided in 2005 out of the United States Bankruptcy Court for the Southern

Dis tr ict of Florida in which the Court held that the in pari delicto defense does not apply to

bankruptcy trustees given the independent nature of trustees and their charge to pursue assets for

the benefit of creditors . The same analysis would apply to receivers . H&W also performed legal

research and drafted memoranda on other issues relevant to general litigation efforts of the

Receiver, including the potential liability of finders under federal securities laws ; the extent to

which monies received by investors in a Ponzi scheme are recoverable by a receiver ; and the

standards that gove rn hedge fund valuations .

In addition, on May 7, 2004, the Court entered an order compelling Citco to produce

documents to the Receiver . The May 7 Order provides that a protective order preventing the

Receiver from "sharing the documents and information contained therein with any entity covered

by the stay provisions of the PSLRA is appropriate , however , the Receiver is free to use the

documents and information on behalf of the Receivership Entities and may share same wi th the

SEC ." Citco filed a motion alleging that the Receiver should be sanctioned for attaching Citco-

produced documents to a complaint that the Receiver filed against PWC . The Receiver filed

pleadings opposing the position taken by Citco . Furthermore , as a result of Citco ' s allegations,

HW has been forced to prepare and file motions to allow the Receiver to file pleadings under

seal wherever documents or information obtained from Citco are included with the relevan t

pleading .

During the Application Period, H&W also assisted in the preparation of a request for

status conference to clarify the Court' s view of the litigation that has been brought by the

Receiver, as well as the litigation that has been brought by the Group and Class Plaintiffs . H&W

22

Case No . 03-80612 CIV-MARRA /VITUNAC

also reviewed certain pleadings prepared in the Group and Class Actions as they relate to the

Receiver ' s actions , although H&W has limited its involvement in the Group and Class Actions .

During the Application Period, the Receiver and H&W also met with counsel for the

Group Plaintiffs in an effort to reach a cooperation agreement that would allow for sharing of

documents and an efficient and equitable method to pursue and distr ibute proceeds from certain

litigation . In connection with the negotiations , H&W and the Receiver have also consulted with

members of the Steering Commi ttee.

H&W also dispatched a number of proposed tolling agreements to pa rties with potential

liability to the Receiver , including net redeemers , brokers, finders, and serv ice providers. A

number of these potential defendants agreed to toll the statute of limitations for the Receiver to

bring suit in order to allow the Receiver to investigate causes of action more fully and procure

additional discove ry .

H&W finally investigated facts and researched law relev ant to potential suits against

portfolio compan ies and their management .

H&W is requesting $57,854 . 16 in attorney ' s fees for 251 . 70 hours in connection with

General Litigation .

21 . Litigation - Discovery Matters :

During the Application Period , H&W and the Receiver continued to undertake extensive

formal discovery . H&W issued subpoenas for production of documents to several hundred more

individuals and entities, including former officers and employees, executing brokers, transfer

agents, po rtfolio compan ies , accountants, insiders , intermediaries , and administrators. H&W

corresponded with many of the subpoenaed entities and individuals, and established a detailed

procedure to track responses, objections , and production .

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Case Nu . 03-80612 CIV -MARRA/VITUNAC

During the Application Period , H&W and the Receiver 's special counsel , Colson Hicks

& Eidson ("CHE") maintained consistent contact wi th each other to synchronize the discovery

process . H&W and CHE coordinated discovery to ensure production of documents from all

subpoenaed entities , to issue subpoenas , to locate entities sought to be subpoenaed, to add

entities to be subpoenaed, to serve subpoenas and to review produced documents . Additionally,

H&W and CHE employed a uniform discovery protocol , including the use of standstill

agreements, supplemental production requests , and essential follow-up wi th non-responsive

entities . To accomplish th is end, H&W and CHE corresponded consistently to remain apprised

of updated discovery issues .

During the Application Period, various entities served wi th subpoenas responded to those

subpoenas . The responses ranged from objections to the documents requested to asse rt ions that

the entity se rved did not have any documents responsive to the subpoenas. Before responding to

the subpoenas , many entities corresponded with H&W to clarify the scope of production, to

extend the time to reply to the subpoena, and to inquire about the production requests and the

Funds generally . In ce rtain instances where subpoenaed entities asse rted they had no responsive

documents , H&W instituted a protocol of verifying specific transactions which revealed that the

subpoenaed entity did in fact have responsive documents . In turn, H&W would correspond with

these entities to "refresh their recollection" to obtain the relevant documents . This procedure

proved important in identifying certain holdings of the Funds .

In instances where an entity objected to the subpoena, H&W would work with that entity

to resolve the objections amicably to avoid litigation . Often , H&W would enter into standstill

agreements pursuant to which subpoenaed part ies would produce a certain level of documents,

and H&W would rese rve the right to compel production of additional documents if the initia l

24

Case Nu. 03-80612 CIV-MARRA/VITUNAC

production proved insufficient for any reason. The process of applying resources to the

subpoenas was and continues to be time -consuming , part icularly given the number of subpoenas

served, the size of the Funds, the number of transactions executed by the Funds, and the need to

follow-up and correspond wi th subpoenaed entities . Nevertheless , the standstill agreements

provide an efficient means to preserve resources .

During the Application Period, H&W continued to refine the procedures for identifying

subpoena targets and pertinent information and expended time with the accountants ascertaining

gaps in the discovery provided by the subpoenaed parties . H&W participated in weekly

conference calls wi th the accountants to discuss various discovery issues and methods for

tracking discove ry . These conference calls tracked the accountants ' discove ry priorities and

alerted H&W of any supplemental production required by the accountants , including any new

entities sought to be subpoenaed by the accountants .

During the Application Period , H&W also conducted research into discove ry related

matters, including the applicability of the Fifth Amendment privilege to the act of producing

documentation , whe ther a privilege log is required under the act of production doctrine , whe ther

an entity can assert such privilege on behalf of a corporation , and whether a Fifth Amendment

privilege shields the contents of any subpoenaed documents . H&W also researched issues

relating to protective orders and motions to compel, and the evidentiary value of deposition

testimony versus statements made during an informal witness interview . H&W also continued to

research issues relating to discove ry from offshore entities and issuance of subpoenas to entities

outside of the United States , including the issuance of le tters rogatory .

25

Case N. , . 03-80612 CIV-MARRA /VITUNAC

During the Application Period, H&W continued to work closely with the SEC to recover

and analyze documents . H&W held weekly conference calls with the SEC to gauge the status of

documents produced .

In addition, H&W continued its extensive review and analysis of documents produced to,

among other th ings , determine claims against litigation targets, including, wi thout limitation,

suspicious payees, insiders , and entities who received potentially avoidable transfers . H&W also

reviewed documents for the purpose of drafting detailed deposition outlines and complaints .

H&W also reviewed and analyzed confidentiality agreements proposed by certain entities

responding to the document requests . H&W is requesting $82,725.33 in attorney ' s fees for

495 .80 hours in connection wi th Litigation -Discovery Matters .

22 . Litigation - Third Party :

The Receiver and H&W unde rtook effo rts in advancing the Receivership Entities'

interests in ancillary litigation , including the Group Action and the Class Action . Specifically,

the Receiver and H&W drafted briefs and motions designed to suppo rt the investors ' causes of

action and th is Court' s jurisdiction over same . H&W researched and prepared detailed

memoranda of law in opposition to certain defend ants ' motions to dismiss and/or transfer the

Class Action . The Receivership Order directs the Receiver to do so where he deems it necessary .

The Receiver and H&W also followed developments in the Group Action and the Class

Action to prepare for the Receiver ' s claims against identical defend ants . H&W reviewed and

analyzed the Group Action Complaint , the Class Action Complaint, and the motions to dismiss

and/or transfer those ancillary proceedings in order to frame his own complaints and to plead

around potential defenses by the Citco defend ants and the PwC defendants . As a result of these

efforts, the Receiver 's complaints against these parties will be less likely to be deemed legally

26

Case N . 03-80612 CIV-MARRA /VITUNA C

deficient or subject to jurisdictional and venue challenges .

In November 2004, the Court entered an order transferring the Group Action and the

Class Action to the Southern District of New York . The Receiver believes it is important that the

actions against the service providers proceed in one venue . Accordingly, the Receiver joined in

the Class Plaintiffs' motion to reconsider such order and provided independent grounds in

opposition to the transfer of venue. The Receiver also joined in a request for a status conference

so that the Court would have the benefit of oral argument on this important subject .

H&W finally researched relevant law and prepared a detailed memorandum in response

to an order to show cause why the Receiver' s cause of action against PwC should not be stayed

in favor of the ancillary actions initiated by investors .

H&W is requesting $49,613 .89 in attorney's fees for 166.40 hours in connection with

Litigation - Third Party .

23 . Litigation - Nephros :

During the Application Period, H&W continued to prosecute the Receiver' s litigation

against Nephros, one of the Funds' portfolio compan ies, to recover on a $1,500,000 matured loan

and obligation to deliver to Offshore certain warrants for Nephros stock . H&W has conducted

numerous depositions and served additional discovery on Nephros, responded to additional

discovery requests and addressed numerous motions to compel and for protective orders . H&W

also defended the Receiver' s deposition in this action . H&W has essentially concluded its

discovery in the proceeding and recently prepared and filed an extensive motion for summary

judgment on all counts in the Complaint . Finally, H&W continues its sett lement dialogue with

counsel for Nephros in the hopes of an amicable resolution .

27

Case No . 03-80612 CIV -MARRA/VITUNAC

H&W is requesting $72,670.37 in attorney' s fees for 290 .00 hours in connection with

Litigation - Nephros :

24 . Litigation - SEC :

During the Application Period , H&W unde rtook efforts in support of the SEC's

enforcement action against Lauer . H&W provided the SEC wi th factual support and documents

suppo rt ing the SEC' s allegations against Lauer and undermining Lauer 's many spurious

allegations regarding the SEC. Lauer has violated countless discovery rules , orders and

obligations throughout the course of the enforcement action . During the Application Period, the

Receiver and H&W held a number of telephone conferences with the SEC regarding Lauer's

blatant failures , and reviewed pleadings relating to the SEC's motions to hold Lauer in contempt .

H&W also held conferences wi th the SEC regarding Lauer ' s blatant and extensive violations of

the asset freeze and possible ways to remedy Lauer ' s violations . H&W also reviewed and joined

in the SEC 's motion to strike Lauer' s motion to dismiss . Finally, H&W conferred with the SEC

on numerous occasions regarding securities compliance and portfolio company issues .

H&W is requesting $ 13,968 .82 in attorney 's fees for 34 .70 hours in connection with

Litigation - SEC .

25 . Litigation - Citco

During the Application Period , H&W undertook substantial efforts in pursuing litigation

against the Citco defendants . As noted in various repo rts and pleadings filed with the Court,

Citco produced approximately 60,000 documents to the Receiver in response to a subpoena

issued upon them. Citco produced these documents only after the Court granted a motion to

compel production filed by the Receiver .

28

Case No . 03-80612 CIV - MARRAIVITUNA C

The Receiver requested Citco to produce the documents electronically to allow the

accountants to readily use and analyze the data produced. Citco initially refused to produce the

documents in an electronic format, and insisted that elec tronic production of the documentation

was not feasible . Accordingly, H&W filed a motion to compel electronic production . After the

Receiver filed the motion to compel , Citco finally agreed to produce documents elec tronically .

H&W worked closely and extensively wi th the accountants to develop a "spec" sheet which

described the format and nature in which the documents should be produced elec tronically .

Once the documents were produced elec tronically, H&W had numerous conferences with the

accountants to discuss the shortfalls in the production , and thereafter held discussions wi th

Citco' s counsel regarding same . H&W and Citco' s counsel continue to work towards a

satisfactory production .

During the Application Period , H&W continued to pour through the documents produced

by Citco with an eye towards pursuing the estate ' s rights against Citco . During the Application

Period , H&W drafted , finalized and ultimately filed a detailed and comprehensive complaint

against Citco and certain employees of Citco who se rved as directors of the Offshore Funds

alleging , among o ther things, professional negligence .

H&W filed the complaint under seal in light of Citco' s interpretation of the May 7 Order .

In connection with the complaint , H&W continued to perform extensive legal research into the

standards applicable to administrators of hedge funds and into the various causes of action that

the Receiver may have against Citco . H&W also consulted wi th ERISA counsel to discuss the

applicability of ERISA to the Funds and the ability to asse rt ERISA causes of action against

Citco. H&W also reviewed issues relating to the fiduciary obligations of Citco and certain of its

29

Case No . 03-80612 CIV - MARRA /VITUNA C

directors . In addition , H&W reviewed and analyzed various repo rts and memoranda prepared

by Citco as they related to the Funds' holdings and the valuation of these holdings .

H&W is requesting $91,844 .83 in attorney ' s fees for 291 . 70 hours in connection wi th

Litigation - CITCO .

26. Litigation - Fraudulent Transfers

During the Application Period , H&W filed additional complaints against net redeemers,

finders, and o ther potential recipients of fraudulent transfers by the Funds . H&W worked closely

with the accountants' to analyze all transfers by the Receivership Entities . H&W carefully

reviewed the accountants analyses of transfers and insolvency to prepare detailed complaints

seeking to recover transfers from numerous part ies . In light of the aggressive position Citco has

taken wi th respect to the Receiver's use of information provided pursu ant to a protective order,

H&W has filed the exhibits to the recent complaints under seal . H&W has obtained extensions

of time to serve summonses on these numerous defendants until the exhibits are unsealed or an

agreement can be reached wi th Citco to allow for the serv ice of exhibits to the defendants. In the

meantime , H&W continues its investigation into the nature of certain transfers and is

communicating wi th many of the recipients about the transfers at issue and the allegations in the

complaints .

During the Application Period , H&W has continued its analysis and has identified

numerous transactions and defendants who should not be subject of these complaints . H&W has

amended several of the complaints and recently filed (after the Application Period) amended

complaints .

H&W is requesting $51,736.22 in attorney's fees for 237 . 10 hours in connection with

Litigation - Fraudulent Transfers

30

Case N,, . 03-80612 CIV-MARRA /VITUNAC

27 . Litigation - Insiders :

During the Application Period, H&W continued its investigation regarding Lauer and

other insiders whom the Receiver believes were responsible for the financial demise of the

Funds. H&W focused its efforts on identifying the key insider targets and reviewing all

documents pertaining to those insiders . Based on the information gathered, H&W began drafting

a detailed and extensive complaint against the insiders . H&W also consulted with the SEC

regarding the roles of insiders, and reviewed notes from interv iews taken of the insiders .

H&W is requesting $50,649 .61 in attorney's fees for 165.50 hours in connection with

Litigation - Insiders .

28 . Litigation - PWC ;

During the Application Period , H&W assisted special counsel in investigating the facts

surrounding PwC's role as auditor of the Funds . H&W attorneys also provided analyses of

international and U .S. auditing standards relevant to PwC's audit of the Offshore Funds . H&W

conferred with special counsel on numerous occasions regarding th is investigation and the claims

against the PwC for the Receiver's complaint .

In early December 2004 , special counsel filed a complaint against PwC. The Court

entered an order to show cause why the Receiver's action against PWC should not be stayed,

primarily on the basis that the Group and Class Plaintiffs were already pursuing PwC on behalf

of investors . The Receiver, through H&W, filed a detailed response to this order explaining that

the Receiver ' s causes of action are separate from the investors ' causes of action , even if the facts

giving rise to the causes of action are similar. Because the causes of action are distinct, the

Receiver believes it is critical that his action against PwC move forward, preferably in concer t

31

Case No . 03 -80612 CIV-MARRA/VITUNAC

and in the same venue as the Group and Class Actions to allow for a more efficient and orderly

litigation process .

H&W is requesting $5,036 .02 in attorney's fees for 13 .10 hours in connection wi th

Litigation - PwC .

29. Michael Laue r

H&W expended substantial efforts responding to Lauer 's numerous spurious motions and

papers during the period covered by th is application . H&W expended substantial efforts

responding to Lauer ' s numerous motions, replies, sur -replies, motions for reconsideration, and

other papers filed in opposition to the Receiver 's proposed sale of the Funds ' holdings in Zi

Corporation and in opposition to the Court ' s prior orders authorizing the Receiver to liquidate

holdings on public exch anges . The Cou rt eventually denied all of Lauer's requests for relief.

Lauer immediately filed a motion for reconsideration , which the Court denied . Lauer has

appealed the Court ' s rejection of his requests for a halt to the sale of Zi Corporation shares and

for reconsideration of the Receiver ' s authority to liquidate holdings on public exch anges .

H&W additionally attempted to procure Lauer ' s consent to a confidentiality order in

order to provide Lauer with advance notice of sales of holdings on public exch anges , as directed

by the Court . Unfortunately , Lauer refused to negotiate wi th H&W in good fai th. After

considerable discussions , Lauer refused to enter into the same confidentiality agreement

executed by o ther part ies entitled to advance notice of asset sales .

H&W further prep ared and filed pleadings in response to Lauer ' s opposition to the

Receiver ' s motion for approval of a protocol for interim distribution to investors .

H&W also assisted the SEC in seeking discove ry and depositions from Lauer and in

prosecuting motions for contempt and sanctions after Lauer failed to provide discove ry upon

32

Case No . 03-80612 CIV-MARRA /VITUNAC

Court orders . H&W assisted the SEC by assembling information to support the SEC's

allegations of contempt and by preparing and filing joinders in support of the SEC's requests for

sanctions against Lauer . H&W further prepared a motion to compel Lauer to respond to the

Receiver's discovery requests . H&W also assisted the SEC in preparing a motion to strike

Lauer's improper motion for summary judgment and prepared a joinder to the motion to strike .

H&W additionally continued its efforts to procure assets of the Receivership Entities held

by Lauer. H&W continued its efforts to repossess the Yukon Denali owned by G.H. Associates

and held by Lauer. Lauer continued filing pleadings in opposition to turnover of the vehicle

despite the Court's orders granting the relief sought by the Receiver . The Court eventually

overruled all of Lauer's objections to turnover, and the Receiver finally repossessed the Denali .

H&W further prepared and filed a motion to expend the receivership to include CLR, a

corporation whose existence Lauer failed to disclose until recently, and a valuable Mercedes race

car purchased by Lauer using the Funds' assets .

H&W finally expended substantial efforts responding to Lauer's spurious and groundless

objections to fee applications filed by the Receiver's professionals .

H&W is requesting $29,081 .79 in attorney's fees for 109 .10 hours in connection with

Michael Lauer

II .Turnstone Investigation Group

In addition to assisting with the control and security of books, records and various other

assets, during the Application Period, TIG continued to undertake efforts to discover additional

assets of the Receivership Entities and to assist H&W in seeking discovery of relevant facts .

Turnstone performed background investigations on Lauer's associates both in the United States

and abroad. Turnstone also investigated CLR and Lauer's use of that company to purchase a

33

Case No . 03-80612 CIV -MARRA/VITUNAC

Mercedes race car using investor funds . Tumstone additionally assisted the Receiver in tracking

down numerous third parties for discovery purposes . Turnstone further performed extensive and

numerous background investigations on portfolio companies and their officers and directors .

Turnstone also repossessed the Denali from Lauer and cleared its title for sale. Turnstone finally

assisted the Receiver and the SEC in discovering Lauer's violation of the Court's asset freeze .

Much of this work required travel outside of the State of Florida .

TIG is requesting $40,730 .00 in fees for 203 .65 hours in connection with its services .

III.Receiver

The Receiver is responsible for the oversight of all aspects of th is extensive receivership,

including investor relations . The Receiver has spent considerable time preparing and reviewing

pleadings , motions and subpoenas as well as reviewing business records, witness interv iews and

contracts . He has corresponded with various entities, including without limitation, commi ttee

members, investors and their counsel through personal meetings , teleconferences , le tters and

elec tronic mail .

The Receiver has further administered certain of the Fund assets for the benefit of all

investors and creditors . Since his appointment , the Receiver has worked extensively on litigation

issues, including research, legal memoranda, pleadings, preparation for and attendance at Court

hearings in connection wi th status conferences and motion practice , witness interviews,

depositions , and factual development . The Receiver worked extensively wi th the forensic

accountants to prepare repo rts that can be used by him in his civil litigation as well as by the

federal agencies working on this case . The Receiver has cooperated and met wi th various

Federal Law Enforcement agencies and representatives including the SEC , FBI, and the

34

Case No. 03-80612 CIV -MARRA/VITUNAC

Department of Justice regarding th is proceeding . The Receiver has participated extensively in

court proceedings , litigation decisions, meetings and conferences regarding strategy and case

administration as well as case management decisions involving the cases . During the

Application Period , the Receiver coordinated with H&W and his forensic accountants and other

professionals in connection with substantially all aspects of this case and their representation of

him .

The Receiver is requesting $18,471 .00 for 39 .30 hours he expended rendering services on

behalf of the receivership estates .

RECEIVERSHIP FUNDS

As of May 26, 2005, the Receiver is in possession of $14,493,833.47 .

COMPENSATION

This Court has the power to appoint a receiver and to award the receiver fees for his

services and expenses incurred in the perform ance of his duties . See Donovan v. Robbins, 588 F.

Supp . 1268, 1272 (N .D. Ill . 1984) ("[T]he receiver diligently and successfully discharged the

responsibilities placed upon him by the Court and is entitled to reasonable compensation for his

efforts .") . See also Securities & Exchange Commission v. Elliott, 953 F. Supp . 1560 (11th Cir.

1992) (receiver is entitled to compensation for perform ance of his duties .) .

The determination of fees to be awarded is largely wi th in the discretion of the trial court .

Monaghan v. Hill, 140 F .2d 31 (9 th Cir. 1944) . Such discretion, however, is predicated upon the

assumption that careful consideration is given to all evidence pertaining to the value of the

attorneys ' services in the light of the factors relevant to a determination . These factors are set

forth in In re Norman v. Housing Authority of City of Montgomery, 836 F.2d 1292 (11 th Cir.

35

Case No. 03-80612 CIV-MARRA/VITUNA C

1988), as follows : ( 1) the time and labor properly employed by the attorneys in processing the

case ; (2) the quality of serv ices rendered ; (3) the scope of the activity and conspiracy under

attack ; (4) the financial risk involved ; (5) the magnitude , complexity and novelty of the issues

involved; (6) the beneficial results obtained ; and (6) the degree to which , if any, efforts were

suppo rted by prior gove rnmental action . The Receiver requests the Court to consider these

factors in determining reasonable compensation for the serv ices rendered to date by the Receiver,

H&W and TIG as summarized below :

a . Time and Labor Required - The exhibits attached to this Notice and filed under

seal include Exhibit 1 , which contains a summary of professional and paraprofessional time, and

Exhibit 2, which is a summary of requested expenses . The exhibits and narrative descriptions in

th is Notice evidence the time and labor employed in processing th is case .

b . Novelty and Difficulty of the Issues and Questions Presented - Due to the nature

of th is case, it was necessary for the Receiver to employ professionals that are experienced and

familiar wi th securities, insolvency, hedge funds , bankruptcy, tax, general litigation , commercial

transactions , fraud , negligence , professional malpractice and a host of other practice areas .

Insofar as there have not been many SEC imposed receiverships involving hedge funds, m any of

the issues presented in th is proceeding are novel .

c . Skill Requisite to Perform the Legal Serv ices Properly - In order to perform the

services in connection wi th th is complex matter , the Receiver ' s and H&W ' s legal skill and

experience in the areas of negligence , fraud, securities , hedge funds , bankruptcy , insolvency,

federal receivership, litigation , tax, commercial transactions and malpractice were required .

36

Case No . 03-80612 CIV-MARRA/VITUNAC

d . Preclusion From O ther Employment - Although this case has required an

extensive investment of professional and paraprofessional time , it has not been necessary for the

Receiver , TIG or H&W to turn away other work .

e . Hourly Rates - The hourly rates charged by the attorneys and investigators

providing se rv ices to the Receiver, as well as the Receiver 's hourly rate , are below the customary

rates charged by attorneys of comparable skills in the Southern District of Florida . H&W has

written off time valued at $112,041 .05

f. Whether the Fee is Fixed or Contingent - The Receiver and his professionals '

hourly compensation in this matter is subject to final Court approval . The Receiver, TIG and

H&W have not received any compensation for their services or unreimbursed costs incurred

during the Application Period .

g . The Limitations Imposed By The Client or the Circumstances - This case has

imposed significant time limitations on the Receiver, H&W and TIG because of the need to

resolve many issues rapidly, efficiently and economically . This effort has been hampered by the

number and frequency of securities transactions undertaken by the Lancer Entities prior to the

Receivership and the lack of adequate internal bookkeeping for said transactions . In addition,

the administrative tasks required to manage the Funds require almost daily monitoring and

attention . The Receiver's investigation has also been impeded by the decisions of certain third

parties not to respond to formal and informal discovery requests .

h . The Amount Involved and the Results Obtained - The above narrative, together

with the exhibits attached hereto, detail the time, nature and extent of the professional serv ices

rendered by the Receiver, H&W and TIG for the benefit of the investors and creditors . The

Receiver, H&W and TIG, without the necessity of litigation, have successfully collecte d

37

Case No . 03-80612 CIV - MARRA /VITUNA C

approximately $30 million . The Receiver anticipates that he will collect and administe r

additional funds .

i . The Experience, Reputation and Ability of the Attorneys - The Receiver and

H&W are established, experienced attorneys with substantial experience in the substantive areas

of law required by this proceeding including fraud, securities, bankruptcy, insolvency, federal

receiverships , tax, hedge funds and litigation .

J . The Undesirability of the Case - The Receiver , TIG and H&W firmly believe th i s

case is complex , difficult and challenging, as well as extremely important to investors , creditors

and the SEC . Therefore, the Receiver, TIG and H&W do not believe the case is "undesirable . "

k . The Nature and Length of the Professional Relationship of the Client - Neither the

Receiver, TIG nor H&W had a professional relationship with the Receivership Entities, or any of

their principals, prior to the institution of this proceeding .

1 . Awards in Similar Cases - As set forth above, the Court has the ability and power

to award fees and costs to H&W, TIG and the Receiver. Other federal judges in the Southern

District of Florida and elsewhere have actually awarded higher fees at full hourly rates for the

same quantity and quality of work expended in receivership cases of similar complexity and

magnitude .

M. Government Support - Although the SEC investigated and filed the initial

pleadings in this case, the Receiver, TIG and H&W had to secure and protect the assets of the

Receivership Entities as well as investigate and analyze the Receivership Entities' business

operations . The Receiver has undertaken extensive discovery efforts in connection with th is

receivership and shared his findings with several federal agencies as required by the

Receivership Order.

38

Case No . 03-80612 CIV - MARRA/VITI NAC

CONCLUSION

The Receiver respectfully requests that this Court authorize him to compensate : (i) H&W

for its attorneys ' fees for reasonable and necessary se rv ices rendered during the Application

Period in the amount of $1,174,516 .23 plus expenses of $79 ,982.60 ; (ii) TIG for its investigative

fees for reasonable and necessary serv ices rendered during the Application Period in the amount

of $48 ,270 .00 to be paid from the appropriate estates of the Receivership Entities and (iii) the

Receiver for the reasonable and necessary serv ices he rendered during the Application Period in

the amount of $18,471 . 00 for a total award of $1,321 ,239.83 to be paid by the appropriate estates

of the Receivership Entities .

Date : May 26, 2005Miami , Florida

Respectfully submitted,HUNTON & WILLIAMS, LLPCounsel for the Receiver1111 Brickell Avenue - Suite 2500Miami , FL 33131Tel: (305) 810-2500Fax: (3QS181p?460

Craig V ile (FBN 613691)Jeffrey A/Bast (FBN 996343)Andrew D . Zaron (FBN 965790)

39

Case No . 03-80612 CIV -MAR .R.A/VITUNA C

CERTIFICATE OF SERVIC E

I FURTHER CERTIFY that a true and correct copy of the foregoing Notice was

furnished this day of May, 2005 , upon the parties on the attached Service List and

posted on the Receiver's website located at www.hunton .com.

4064036 .000002 MIAMI 284442v7

JOINTLY ADMINISTERED CASELANCER/RECEIVERSHIP AND BANKRUPTCY CASE

CASE NO . 03-80612 -MARRA/VITUNAC/CASE NO .04-CIV -80211 -MARRAIVITUNACETC.

SERVICE LIST

Christopher MartinMichael Lauer pro se Heidi Caren s

Senior Trial Counsel,

Heidi Carens 7 Dwight Lan eU .S. Securities & Exchange Commission7 Dwight Lane CT 0683 1Greenwich

801 Brickell Avenue - Suite 1800 Greenwich CT 06831,

Miami, F133131,

Patricia Beary Nina Fiskaae nM sM. Regina Thomas

.Office of the U .S . Trustee Nordea Liv Norge A SControlle rUnited States Trustee/Department of Justice ,One Century Tower, Suite 1103 Folke Bernadottes vei 3 851 SW Ist Avenue - Suite 120 4265 Church Street 5147 Fyllingsdalen

Miami FL 3313 0New Haven, CT 06510 ,1201 Bergen - NORWA Y

David Blaylock EsqGa FF), M. G&Feber Gerry LaBush Esq .

, .,

PLL CGlankler BrownHodgsen Russ LLP 711 Third Avenue,

i1700 One Commerce Squar e

Ono 4.49,T- PIRAEi; Su te 2000 Suite 150 5Buff to Now Vork 14203 New York New York 10017

Memphis, Tennessee 3810 3,

Counsel for George R. Pidgeon, Sr.

David NewmanTrisha D Sindler Jimmy Tsakn i. Hoeffnerc/o Timothy ESpecial Counsel c/o Shari A . Brandt Esq .

.,

1500 Market streetU .S . Securities & Exchange Commission Richard Spears Kibbe & Orbe. LLP ` h38 Floo r801 Brickell Avenue - Suite 1800 One World Financial Center

PA 19102-218 6Philadelphi aMiami, FI 33131 New York, NY 10281

,

Frank Paul Terzo Noah J . Schafler, Esq .Mercedes G Hal eKatz Barron Squitero Faust . The Law Offices of David W . Rubi nPiper Rudnick LL P

2699 S Bayshore Drive 600 Summer Street Suite 20 1. 101 E Kennedy Boulevard Suite 2000,

Eight Floor. ,

Pampa, FL 33602 Stamford, CT 0690 1Miami, FL 3313 3

Kenneth B . Robinson Esq . Mark S . Gregory,Robert M Dombroff EsqRice, Pugatch, Robinson & Schiller, P .A . . , . Delphine W . Knight BrownJonathan Alter Esq848 Brickell Avenue Suite 1 100 , . Kelley Drye & Warren LL P,Bingham McCutchen LL P

Miami FL 33131 Two Stamford Plaza,One State Street

281 Tresser BoulevardHartford CT 0610 3,

Stamford, CT 0690 1

David Barrack, Esq . Anthony & Patricia O'Callagahan/Hal M . Hirsch, Esq . Christopher B . O'Callaghan/ Joshua W. CohenGreenberg Traurig, LLP Diane J . Nelson/John P . Heffernan Cummings & LockwoodMet Life Building Attn : Timothy T. Brock 700 State Stree t200 Park Avenue Satterlee Stephens Burke & Burke LLP New Haven, CT 06509New York, NY 10166 230 Park Avenu e

New York, NY 1016 9

Thomas D GoldbergBrian C Getioney Esq

.Barbara H .Kat z. , . Day Berry & Howard LL P

Rome muciuigafl sabanesh PC,

Law Office of Barbara H . Katz, , ,One State Street One Canterbury Green

57 Trumbull StreetT 06 1f Stamford CT 0690 1o rd , CH art 03 3402 ,

New Haven, CT 0651 0

James M . Nugent, Esq .Klein Joseph P . Moodhe KFO Investors Partnershi p

Debevoise and Plimpton James M . Nugen t919 Third Avenue Harlow, Adams & Friedman, P .C .

Stamford, CT 06905 New York, NY 10022 300 Bic Driv eMillford, CT 06460

Howard L . Siege lBrown Rudnick Berlack Israels LLP Thaddeus E. Delonis, CPACityplace I, 38`x' Floor 290 Towne Center Drive185 Asylum Avenue Troy, MI 48084 -1774Hartford , CT 060103

Garry M . Graber Leonard H. Hechtc/o Joseph Galda, Esq . 1270 avenue of the AmericasCorsair Advisors , Inc. Suite 214497 Delaware Avenue

New York, NY 10020Buffalo, NY 14202

Timothy W. WalshPeper Rudnick LL P1251 Avenue of the AmericasNew York, NY 10020-1 104

E-MAIL SERVICE LIS T

Jeffrey Greilsheimer, Esq .Hughes Hubbard and Reed, LL POne Batte ry P ark PlazaNew York, New York 10004E-mail : greilshe(a?hugheshubbard .com

Scott M. Berman, Esq .Anne E . Beaumont, Esq .Friedman, Kaplan,Siiler & Adelman LL P1633 Broadway, 46th FloorNew York, NY 100 19-6708sberman@fklaw . co m/abeau mo nt@fklaw. com

Greg T . Arnol dBrown Rudnick Berlack Israel sOne Fin ancial Cente rBoston , MA 0211 1E-mail : garnold(ulbrbilaw .co m

Travis Corder David Cimo Esq . Paul WallaceGenovese Joblove & Battista P A

Brown Rudnick Berlack Israels, . . 9701 S. Bexley Drive

Bank of Tower 36th Floo rOne Financial Center

,Littleton CO 80126100 S 2nd StreetE ,

Boston , MA 02111. .

comE-mail : wallaceclandenver(dms nE-mail : tcorder(ribrbilaw.com

Miami, FL 33131 .

E-mail : dcimo(u~gib-law .co m

Bill McCowen Mr. Hans Jacob Dahle David P . Milian, Esq .Vesta Forsikring AS Kozyak Tropin & Throckmorton, P .A .Metamora Multi Managers L .L C. .P .O . Box 7070 2525 Ponce de Leo n

E-mail : mccowenbiII(a.voyager . net 5020 B NORWAY 3313 4l GC b lergen - ora a e se-mail : hans.jacob.dahle(ijvesta .no E-mail : dmili an ,,u!kttlaw .co m

Michael A . Hanzman Esq . Aaron Podhurst Es q, , .Joel H . Bern stein Esq .

Hanzman & Criden P.A . Podhurst Josefsbur gOrseck,

, ,, ,Goodkind Labaton Rudoff & Sucharow LL P

Commerce B ank Building Eaton Meadow Olin & Perwin P A, , , . .100 Park Avenu e

220 Alhambra Circle - Suite 400 25 West Flagler Street - Suite 800New York 1001 7New Yor k

Coral Gables Florida 33134 Miami Florida 33130,

, ,E-mail ibernstein(aiglrslaw .co m

E-mail : Ml lanzmaniu~l1anzmanCriden .com E-mail : aoodhurst(iPoodhurst .com

Carol Felicett aRoberto Martinez Esq . Joseph Matthews Esq, , .

Reid & Riege P CColson Hicks Eidson P A . Colson Hicks Eidson P A

. .,. . .

9th Floor234 Church Stree t255 Aragon Avenue 2nd Floor 2nd Floo r255 Aragon Avenue

,, ,

CT 06510-181 9New Have nCoral Gables FL 33134 Coral Gables FL 33134

,, ,

E-mail : cfclicetta;tureidandriege .comE-mail : bob'acolson .com E-mail : joseph u?colson .co m

David L . Snyder, Esq . Rudolph F . Aragon . Fsq . Salvatore A. Barbatano, Esq .Craig B . Leavers, Esq. White & Case Foley & LardnerNeuberger, Quinn. Gielen, Rubin & Gibber Wachovia Fin ancial Center, Suite 4900 150 W. Jefferso n

One South Street, 27`h Floor 200 South Biscayne Boulevard Suite 100 0Baltimore, MA 21202-3282 Miami, Florida 33131-2352 Detroit, MI 48226-261 6E-mail : dls( nggrg.com/cblru;nggrp, com E-mail : raragon@whitecase .com E-mail : sbarbatano("q?foleylaw .co m

Eric A . Henzy, Esq . Donald Workman, Esq .Reid and Riege, P .C . Foley & Lardner Timothy P . Harkness, Esq .One Fin an cial Plaza 3000 K Street, N . W . Kramer Levin Naftalis & Frankel LL PHartford, CT 06103 Suite 500 919 Third Avenu eE-mail : chenzy(areidandrie eg com Washington, D .C . New York, New York 1002 2

E-mail : dworkmarviOble),law .com E-mail : tharkness(u)kramerlevin .co m

Lewis N . Brown Harley S . Tropin, Esq . Christopher Marti nGilbride, Heller & Brown, PA . Kozyak Tropin & Throckmorton, P .A . Senior Trial Counse lOne Biscayne Tower, Suite 1570 2525 Ponce de Leon U .S . Securities & Exchange Commissio nTwo South Biscayne Blvd . Coral Gables 33134 801 Brickell Avenue - Suite 180 0Miami, Florida 33131 E-mail : hst Ikttlaw .com Miami, Fl 3313 1E-mail : l brownca))ghblaw .com E-mail :sf(ui.kttlaw .com E-mail : martinc(fi[sec . ov

Lewis N . Brown, Esq.

Andrew L . Jiranek Michael J . Dell Esq .Dyanne E . Feinberg, Esq .

McKennon Shelton & Henn LLP,

Kramer Levin Naftalis & Frankel LLP Gilbride, Heller & Brown, P .A.

401 East Pratt St . Suite 2315 919 Third Avenue One Biscayne Tower, Suite 1570,Two South Biscayne Blvd

Baltimore Md 21202 New York, New York 10022.

.,E-mail : andrew jiranek@mshll com E-mail : mdell@kramerlevin.com Miami, FL 3313 1

. p . E-mail: lbrown@,ghblaw . com/dfeinberggghblaw .com

Daniel A . Casey, Esq . Seth M. Schwartz, Esq . John Hochman, Esq .Kirkpatrick & Lockhar

t Miami Center - 20'h Floor Skadden, Arps, Slate. Meagher & Flom LLP Schindler Cohen & Hochman LL P

201 S . Biscayne Blvd. Four Times Square 100 Wall Street, 15`h Floo r

Miami, FL 33131 New York, New York 10036 New York, New York 1000 5E-mail : dcasey@kl.com E-mail : sschwart@skadden .com . E-mail : jhochman @schlaw .co m

David Cimo Esq . Robert T . Wright, Esq .

Robert Pershes Esq . Genovese Joblove & Battista, P .A . Coffey & Wright, LL P,Buckingham Doolittle & Bouroughs LLP Bank of Tower, 36th Floor Grand Bay Plaza, ,2500 North Military Trail Suite 480 100 S .E . 2nd Street Penthouse 2 B,Boca Raton FL 33431 Miami FL 33131 2665 S . Bayshore Driv e,E-mail : rpershes@bdblaw .com

,E-mail : deimo@gjb-law com

Miami, FL 3313 3.

E-mail : rwright@coffeywright .com

William R . Maguire Esq .,Jeffrey Greilsheimer, Esq . Jacqueline Wilson Kevin E . Gunthe r

Hughes Hubbard & Reed, LLP British Virgin Islands Financial Services 27 Reid Street, I" Floo r

One Battery Par k Plaza Commission P.O. Box HM 305 1New York, NY 10004 Pasea Estate, Road Town Hamilton HM N XE-mail : maguire@ hughesbubb ard.com Tortola, British Virgin Islands Bermuda

greilshe@hugheshubbard .com e-mail : wilsonj@bvifsc .vg e-mail : kevin .gunther@lom .bm

Mr. Dylan WolffM anaging Director Norges Investor ValueP .O . Box 1863 Vika0124 Oslo - NORWAYe-mail : dw @norgesinvestor .no

Box 3331P .O.Road TewA, To

Michael Lauer, pro se7 Dwight LaneGreenwich, CT 06831mblauer(ii hotmaiI .co m

William S . Fish, Esq .William H. Champlin, Esq .Tyler Cooper & Alcorn, LL P185 Asylum St ., CityPlace 35th FloorHartford, CT 0610 3e-mail : fish @tylercooper.com/champl in(c_tylercooper . com

John G . Moon, Esq .Chadbourne & Parke LLP30 Rockefeller PlazaNew York, NY 1011 2e-mail : jmoon@chadbourne .com

54036 .000002 MIAMI 236715v l

EXHIBIT A

Summary of Professional And Paraprofessional TimeHUNTON & WILLIAMS LLP

PROFESSIONALS - LEGAL SERVICES RENDERED (TOTAL)NAME STATUS HOURS RATE TOTAL FEES

FERNANDO C. ALONSO Partner 2.90 $435 . 00 $,261 .50

JEFFREY P. BAST Pa rtner 343 .30 $340 . 00 $116 ,722.00

MARK S. DRAY Pa rtner 7 . 30 $495 . 00 $3,613.50

ALBERTO M . HERNANDEZ Pa rtner 19 . 60 $385 . 00 $7,546.00

LESLIE O. JUAN Pa rtner 9 . 50 $655 . 00 $6,222.50

ENRIQUE MARTIN Partner 0 . 50 $355 .00 $177.50

MICHAEL P . MASSAD Pa rtner 1 . 30 $400 . 00 $520.00

ROBERTO R. PUPO Pa rtner 0 .30 $355 . 00 $106.50

JOHN JAY RANGE Pa rtner 0 . 60 $525 . 00 $315.00

CRAIG V . RASILE Partner 425.10 $445 .00 $ 189,169 .50

JENNINGS G . RITTER, II Pa rtner 0 .50 $475 .00 $237.50

DAVID E. WELLS Partner 138.90 $355 .00 $49,309.50

ANDREW D . ZARON Pa rtner 374 . 20 $355 .00 $132,841 .00

RICHARD E. MAY Counsel 11 .00 $575.00 $6,325.00

RAFAEL G . PROHIAS Counsel 87.90 $325.00 $28,567.50

RICHARD J . RAZOOK Counsel 14.00 $450.00 $6,300.00

ALEXANDRA M . AGUIRRE Associate 58.90 $240.00 $ 14,136.00

MICHAEL W . ALEXANDER Associate 21 .70 $275 . 00 $5,967.50

PHILIP S. BUBB Associate 47.00 $200.00 $9,400.00

COURTNEY A . CAPRIO Associate 426.70 $180.00 $76,806.00

K. STACIE CORBETT Associate 36.60 $220.00 $8,052.00

MICHAEL A . DUNN Associate 60.40 $ 180.00 $ 10,872.00

KEVIN M . ECKHARDT Associate 313.00 $260.00 $81,380.00

ARTURO J . FERNANDEZ Associate 22.00 $ 180.00 $3,960.00

ANTHONY R . FOXX Associate 37.90 $305.00 $ 11,559.50

DANA MICHELLE GRYNIUK Associate 18.10 $200.00 $3,620.00

JARRETT L . HALE Associate 2 . 20 $220 . 00 $484.00

JOSEPH F . HESSION Associate 108.40 $305.00 $33,062 .00

STEVEN T. HOLMES Associate 0.30 $265.00 $79.50

ANTHONY D . LEHMAN Associate 180 .50 $285.00 $51,442.50

CARRIE M . LEVINE Associate 17 .90 $215.00 $3,848.50

GUILLERMO A . LEVY Associate 1 .50 $260 . 00 $390.00

GUSTAVO J . MEMBIELA Associate 5 .10 $235 . 00 $1,198.50

ALEJANDRA PENNIE Associate 8 .20 $295.00 $2,419.00

BENJAMIN W. PREVOST Associate 63 .90 $180.00 $ 11,502.00

AMY ALCOKE QUACKENBOSS Associate 37 .90 $325 . 00 $12 ,317 .50

AHMED RIESGO Associate 132 .10 $ 180 .00 $23,778.00

CARLO ALEXANDERRODRIGUEZ

Associate 24 .30 $180 .00 $4,374.00

ALEX MCLANE SOTO Associate 56 .20 $215 .00 $ 12,083.00

FRADYN SUAREZ Associate 144 .00 $200 .00 $28,800.00

JAMES JAY THORNTON Associate 185 .80 $260 .00 $48,308.00

BENJAMIN WOLKOV Associate 31 .30 $260 .00 $8,138.00

TOTAL BYPROFESSIONAL 3478 . 8 $1,016,212.00

PARAPROFESSIONAL SERVICES RENDERED TOTA LNAME STATUS HOURS RATE TOTAL FEES

CAROL A. CASEY Paralegal 23.70 $120.00 $2,844.00

VIVIAN CHAPUNOFF Paralegal 253 . 70 $65 . 00 $16,490 .50

NANCY F . COHEN Paralegal 76.90 $150.00 $ 11,535.00

RAYMOND E . GALBRAITH Paralegal 1 .00 $130.00 $130.00

AMELIA R . GOULD Paralegal 6.20 $120.00 $744 .00

GLENDA INGRID GUTSTEIN Paralegal 187.20 $130.00 $24,336.00

AL HERNANDEZ Paralegal 100.40 $150.00 $15,060 .00

CAROL ANN KRAINSON Paralegal 44.00 $115.00 $5,060.00

HORTENSIA LECON Paralegal 20.10 $120.00 $2,412.00

BETH ANNE MOON Paralegal 244 . 80 $160 . 00 $39,168 .00

UNEEK R . MURPHY Paralegal 26.00 $100.00 $2,600.00

BETTY C . RICHARDS Paralegal 1 .00 $150 . 00 $150 .00

DENISE A. RUDASILL Paralegal 23 . 10 $120 . 00 $2,772.00

ARETINA K . SAMUEL Paralegal 4.20 $125 . 00 $525.00

NAOMI STEINBERG Paralegal 16.70 $150.00 $2,505.00

RANDYALMAGUER Staff 181 . 70 $45 . 00 $8,176.50

DEANETTE PAULA DUNN Staff 187 .70 $44 . 41 $8,335.23

CHRISTOPHER R. HIGGINS Staff 4.20 $160 . 00 $672.00

ETHLYN E. LEWIS Staff 10.80 $125.00 $1,350.00

TOM M . MCKENNEY Staff 4 . 00 $170 . 00 $680 .00

COLETTE J . PERKINS Staff 1 .00 $130 . 00 $130 .00

MARITZA SERENTILL Staff 63 . 00 $65 . 00 $4,095.00

NICHOLAS P. SERFASS Staff 19 . 60 $45 . 00 $882 .00

RAFAEL TORNES Staff 90.00 $45.00 $4,050.00

JACQUELINE CRESPO Professiona lAssistant

2.50 $65 . 00 $162 .50

MONICA C . TUCKER Professiona lAssistant

11 .40 $65.00 $741 .00

KERRI-ANN M. PHILP Librarian 2 .20 $140 .00 $308 .00

MICHAEL VALLEJO Other 30 .90 $45 .00 $1,390.50

TOTAL by Paraprofessional 1638 $157,304 .23

RECEIVER SERVICES RENDERED (TOTALNAME STATUS HOURS RATE TOTAL FEES

MARTYSTEINBERG

Pa rtner 39 .30 $470 . 00 $18 ,471 .00

TOTAL 39.3 $18,471 .00

TURNSTONE INVESTIGATIVE GROUP SERVICES RENDERED TOTA LNAME STATUS HOURS RATE TOTAL FEES

TURNSTONE Investigator 4.00 $200 . 00 $800.00

TURNSTONE09248 Investigator 50.25 $200.00 $10,050 .00

TURNSTONE09364 Investigator 1 .00 $200.00 $200 .00

TURNSTONE4113 Investigator 8.00 $200 .00 $1,600.00

TURNSTONE8764 Investigator 94.60 $200.00 $18,920 .00

TURNSTONE8991 Investigator 83.50 $200 .00 $16,700 .00

TOTAL 241.35 $48 ,270.00

TOTAL FOR SERVICES5397.45 $1,241,257 .23 1RENDERE D

64036 .000002 MIAMI 286604v 1

EXHIBIT B

ACTIVITY CODE CATEGORY : B110 CASE ADMINISTRATIONNAME Code HRS VALUE RATE

BAST B110 13 .30 4,522 .00 340.00CRESPO B110 1 .50 97.50 65.00

DYE B110 0 .00 0 .00ECKHARDT B110 3 .10 806.00 260.00FOXX B110 0.00 0 .00 305 .00GUTSTEIN B110 0.20 26.00 130 .00HESSION B110 5 .30 1,616 .50 305 .00RASILE B110 68 .20 30,556 .85 445 .00RIESGO B110 1 .50 270.00 180 .00RUDASILL B1 10 0.40 48.00 120 .00SOTO B110 2.60 559.00 215.00SUAREZ B110 0.70 140 .00 200.00TUCKER BI 10 4.00 260.00 65.00ZARON B110 51 .20 18,176.00 355 .00

Total 152.00 57,077.85

EXHIBIT B

ACTIVITY CODE CATEGORY : B120 ASSET ANALYSIS AND RECOVERYNAME Code HRS VALUE RATEAGUIRRE B 120 13 .90 3,336 .00 240.00

ALONSO B120 2.90 1,261 .50 435.00BAST B 120 6 .50 2,210 .00 340.00CAPRIO B 120 24 . 10 4,338 .00 180.00ECKHARDT B 120 3 .20 832.00 260.00

FUCHS B 120 0 . 00 0.00HERNANDEZ B 120 3 .50 525 .00 150 .00

HERNANDEZ B120 15 .80 6,083 .00 385.00KRAINSON B120 35.60 4,094 .00 115 .00LECON B 120 15 .60 1,872 . 00 120 .00

PHILP B 120 0 .50 70 .00 140 .00

PUPO B120 0.30 106.50 355 .00

QUACKENBOSS B120 4.60 1,495 . 00 325 .00RASILE B120 11 .20 4,990 .41 445.00

RIESGO B120 13 . 80 2,484 .00 180 .00SUAREZ B120 24.10 4,820 .00 200.00

WELLS B120 106 .30 37,742 . 82 355 .00WOLKOV B120 31 . 30 8,138 . 00 260.00ZARON B120 22 . 70 8,058 .50 355.00

Total 335.90 92,456.73

EXHIBIT B

ACTIVITY CODE CATEGORY : B130 ASSET DISPOSITIO NNAME Code HRS VALUE RATE

AGUIRRE B130 42.20 10,128.00 240.00

BAST B 130 37.10 12,614.00 340.00ECKHARDT B130 0 .30 78.00 260.00

GRYNIUK B130 7.00 1,400 .00 200.00

GUTSTEIN B130 0 .50 65.00 130 .00

HERNANDEZ B130 3.80 1,463 .00 385.00MARTIN B130 0.50 177 .50 355.00

RASILE B130 33 .70 15,200.63 445 .00

RIESGO B130 19 .00 3,420.00 180 .00SUAREZ B130 46.50 9,300.00 200.00WELLS B130 23.30 8,289 .22 355.00

ZARON B130 46.20 16,401 .00 355 .00

1 1 1-Total 260.10 78,536 .35 :::d

EXHIBIT B

ACTIVITY CODE CATEGORY : B150 INVESTOR CREDITOR COMMUNICATIO NNAME Code HRS VALUE RATE

BAST B150 12 . 30 4,182 .00 340.00ECKHARDT B150 7 . 50 1,950 .00 260 .00RASILE B150 17 .60 7,663 . 22 445.00SOTO B 150 27.90 5,998 . 50 215.00SUAREZ B150 2 .60 520 . 00 200.00

Total 67 .90 20,313 .72

ACTIVITY CODE CATEGORY : B160 FEE/EMPLOYMENT APPLICATIO N

NAME Code HRS VALUE RATE

BAST B 160 26 . 80 9,112 . 00 340.00

CAPRIO B160 16.50 2,970.00 180.00

ECKHARDT B160 30 .20 7,852 . 00 260 .00GUTSTEIN B160 93 . 60 12,168 . 00 130.00

RASILE B 160 47 .70 21,070.47 445.00

RUDASILL B 160 12 . 80 1,536 . 00 120.00

SOTO B160 6 . 90 1,483 . 50 215.00SUAREZ B 160 0.20 40 . 00 200.00VALLEJO B 160 0 .00 0.00 45.00

ZARON B 160 41 . 60 14,768 .00 355 .00

Total 276.30 70,999 .97

EXHIBIT B

ACTIVITY CODE CATEGORY : B170 FEE /EMPLOYMENT OBJECTION SNAME Code HRS VALUE RATEALEXANDER B170 3 . 20 880 .00 275 .00

BAST B170 3 .90 1,326.00 340.00CAPRIO B170 0 .30 54 . 00 180 .00DRAY B170 0 . 30 148 .50 495.00ECKHARDT B 170 36.20 9,412 .00 260.00RASILE B170 23 .10 10,250 .57 445.00

SOTO B170 7.50 1,612.50 215.00TUCKER B170 3 .00 195 .00 65.00

ZARON B 170 2 . 30 816 .50 355 .00

Total 79 . 80 24,695.07

EXHIBIT B

ACTIVITY CODE CATEGORY : B181 PLAN OF DISTRIBUTIO N

NAME Code HRS VALUE RATE

BAST B181 6.40 2,176.00 340.00

ECKHARDT B181 9 .20 2,392 .00 260.00

RASILE B181 1 .10 496.35 445.00

ZARON B181 2.60 923 .00 355 .00

Total 19 . 30 5,987.35

EXHIBIT B

ACTIVITY CODE CATEGORY : B182 PREPARATION AND REVIEW OF REPORT SNAME Code HRS VALUE RATEBAST B182 6.10 2,074 . 00 340 .0 0HERNANDEZ B 182 4.00 600 . 00 150 .00RIESGO B182 1 .70 306.00 180 .00SERENTILL B182 0.00 0 .00 65 .00SUAREZ B182 1 .00 200 . 00 200.00

Total 12 .80 3,180 .00

EXHIBIT B

ACTIVITY CODE CATEGORY : B184 RECEIVE R

NAME Code HRS VALUE RATESTEINBERG B 184 39 .30 18,471 .00 470.00

Total 39.30 18 , 471.00

EXHIBIT B

ACTIVITY CODE CATEGORY: B210 BUSINESS OPERATION SNAME Code HRS VALUE RATEBAST B210 5.10 1,734 .00 340.00

GUTSTEIN B210 19 .20 2,496.00 130 .00

PROHIAS B210 87.90 28 ,567.50 325 .00

RASILE B210 13 .40 6,031 .08 445.00

RIESGO B210 5.70 1,026 . 00 180 .0 0SUAREZ B210 19 .20 3,840.00 200.0 0

WELLS B210 4.80 1,717 .56 355 .00

ZARON B210 1 .80 639 .00 355 .00

157 .10 46,051 .14

ACTIVITY CODE CATEGORY : B217 ACCOUNTING/AUDITING

NAME Code HRS VALUE RATE

BAST B217 16 . 00 5,440 . 00 340.00

GUTSTEIN B217 1 .00 130 . 00 130 .00

RASILE B217 2 . 50 1,103 .11 445 .00

ZARON B217 2 . 20 781 . 00 355 .00

Total 21 .70 7,454 .11

EXHIBIT B

ACTIVITY CODE CATEGORY : B219 TURNSTONE INVESTIGATIO NNAME Code HRS VALUE RATE

TURNSTONE09190 B219 4 . 00 800 .00 200 .00TURNSTONE09248 B219 50 .25 10,050 .00 200 .00TURNSTONE09364 B219 1 .00 200 .00 200.00TURNSTONE4113 B219 8 . 00 1,600.00 200.00TURNSTONE8764 B219 56 . 90 11,380.00 200.00TURNSTONE8991 B219 83 .50 16,700.00 200.00

Total 203.65 40,730.00

EXHIBIT B

ACTIVITY CODE CATEGORY : B220 EMPLOYEE BENEFITS/PENSIONSNAME Code HRS VALUE RATEALEXANDER B220 15 .70 4,317 .50 275 .00BAST B220 1 .40 476.00 340 .00DRAY B220 5 .70 2,821 .50 495.00

Total 22.80 7,615.00

EXHIBIT B

ACTIVITY CODE CATEGORY : B223 DATA ANALYSI S

NAME Code HRS VALUE RATE

RASILE B223 0.50 225.61 445.00

ZARON B223 0.00 0.00 355 .00

Total 0 .50 225.61

EXHIBIT B

ACTIVITY CODE CATEGORY : B2228 DEPARTMENT OF JUSTICE INVESTIGATIONNAME Code HRS VALUE RATEBAST B228 0.20 68 . 00 340.00RASILE B228 0 .70 302.42 445.00ZARON B228 0 . 90 319.50 355.00

Total 1 .80 689.92

EXHIBIT B

ACTIVITY CODE CATEGORY : B233 DOCUMENT MANAGEMEN T

NAME Code HRS VALUE RATE

ALMAGUER B233 99.30 4,473 .19 45 .00

BAST B233 0.20 68.00 340.00

DUNN B233 8.00 355.53 45 .00

FOXX B233 0.30 91 .66 305 .0 0

GALBRAITH B233 1 .00 130.00 130 .00

GOULD B233 1 .50 180.00 120 .0 0

HIGGINS B233 4.20 672 . 00 160 .0 0LEHMAN B233 6.20 1,767 .00 285 .00

LEWIS B233 10 .80 1,350 .00 125 .00

MCKENNEY B233 4 .00 680 .00 170 .00

MOON B233 114 .60 18 , 336.00 160 .0 0PENNIE B233 2.40 708.00 295 .00

SERENTILL B233 57.80 3,757 .00 65 .00

SERFASS B233 19 .60 882 .00 45 .00

TORNES B233 51 .40 2,313 .00 45 .00

TUCKER B233 0 .80 52.00 65 .00

VALLEJO B233 4.40 198 .00 45 .00

Total 386.50 36 ,013.38

EXHIBIT B

ACTIVITY CODE CATEGORY : B234 DOCUMENT REVIEWNAME Code HRS VALUE RATE

ALMAGUER B234 80.90 3,635 .57 45 .00

BAST B234 3.50 1,190.00 340.0 0

BUBB B234 47.00 9,400.00 200.00

CASEY B234 23.70 2,844.00 120 .00

CHAPUNOFF B234 44.30 2,879.50 65 .00

COHEN B234 76.90 11,535 .00 150 .0 0CORBETT B234 36.60 8,052 .00 220.00

DUNN B234 179 .70 8,090 .97 45 .0 0

DUNN B234 60.40 10,872.00 180 .0 0FERNANDEZ B234 16 .30 2,934 .00 180 .00

FOXX B234 33.70 10,278.27 305 .00HESSION B234 97.60 29,768.00 305 .00

KRAINSON B234 5.20 598.00 115 .00

LEHMAN B234 34.40 9,804 .00 285 .00

MOON B234 120 .80 19,328.00 160 .00MURPHY B234 26.00 2,600 .00 100 .00

PREVOST B234 24.60 4,428.00 180.00RASILE B234 0.50 225.61 445 .00

RICHARDS B234 1 .00 150 .00 150 .00

RUDASILL B234 9.90 1,188 .00 120 .00

SAMUEL B234 4.20 525.00 125.00SERENTILL B234 1 .80 117 .00 65.00

TORNES B234 38.60 1,737 .00 45.00

VALLEJO B234 10.20 459.00 45.00

ZARON B234 1 .20 426 .00 355.00

Total 979.00 142,953 .65

EXHIBIT B

ACTIVITY CODE CAT EGORY: B235 INVESTIGATIO N

NAME Code HRS VALUE RATE

BAST B235 0 .90 306.00 340 .00

RASILE B235 30.70 13,822 .00 445.00

TURNSTONE8764 B235 37 .70 7,540.00 200.00

ZARON 2235 0 .90 319.50 355 .00

Total 70.20 21 ,987.50

EXHIBIT B

ACTIVITY CODE CATEGORY : B235 INVESTIGATIONNAME Code HRS VALUE RATEAGUIRRE B236 2 .80 672 .00 240.00ECKHARDT B236 0 .40 104 . 00 260.00GRYNIUK B236 11 .10 2,220 .00 200.00LEVINE B236 17 .90 3,848 . 50 215.00LEVY B236 1 .50 390 . 00 260.00RIESGO B236 54.00 9 , 720.00 180 .00SUAREZ B236 47.70 9,540.00 200.00WELLS B236 4 .50 1,559 . 90 355.00

Total 139 .90 28,054.40

EXHIBIT B

ACTIVITY CODE CATEGORY : B240 TAX ISSUE SNAME Code HRS VALUE RATE

BAST B240 3 .80 1,292 . 00 340.00MAY B240 11 . 00 6,325 . 00 575.00

RASILE B240 2 . 10 932 . 22 445.00

RAZOOK B240 14 .00 6 , 300.00 450.00

TUCKER B240 0.50 32 . 50 65 .00

VALLEJO B240 6.00 270 . 00 45.00

Total 37 .40 15 ,151 .72

ACTIVITY CODE CATEGORY : B310 CLAIMS ADMINISTRATION /OBJECTION SNAME Code HRS VALUE RATEBAST B310 28 .50 9,690.00 340.00CAPRIO B310 29 .30 5,274 . 00 180.00CHAPUNOFF B310 0 .20 13 .00 65.00GUTSTEIN B310 4.50 585 . 00 130 .0 0HALE B310 1 .70 374.00 220.00HOLMES B310 0 . 00 0.00 265 .00MOON B310 2.30 368.00 160.00RASILE B310 1 .00 451 . 22 445.00VALLEJO B310 10 . 30 463 . 50 45.00ZARON B310 0.60 213 . 00 355.00

Total 78.40 17 ,431 .72

EXHIBIT B

ACTIVITY CODE CATEGORY : B510 LITIGATION GENERA LNAME Code HRS VALUE RATE

BAST B510 13 . 20 4,488 . 00 340.0 0

CAPRIO B510 70 .10 12,618 . 00 180 .0 0

CRESPO B510 0.00 0 . 00 65.00

ECKHARDT B510 29 . 60 7,696 . 00 260.00

FOXX B510 0 .30 91 .66 305.00

GUTSTEIN B510 18 .90 2,457 . 00 130 .00

HERNANDEZ B510 17 . 00 2,550 . 00 150 .0 0

LEHMAN B510 0 .70 199 . 50 285.00

LEWIS B510 0 . 00 0.00 125 .0 0

MEMBIELA B510 5.10 1,198 .50 235.00

PHILP B510 1 .70 238 . 00 140 .00

RASILE B510 21 .50 9,471 . 00 445.00

RIESGO B510 36 .40 6,552.00 180 .00

RUDASILL B510 0 .00 0 .00 120 .00

SERENTILL B510 0 . 30 19 .50 65.00

SOTO B510 7 . 50 1,612 .50 215.00STEINBERG B510 7 . 90 1,185 . 00 150 .00

SUAREZ B510 1 .00 200.00 200.00

TUCKER B510 0.00 0.00 65.00

ZARON B510 20 .50 7,277 .50 355 .00

Total 251 . 70 57,854.16

ACTIVITY CODE CATEGORY : B540 DISCOVERY MATTERSNAME Code HRS VALUE RATE

ALMAGUER B540 1 .50 67 .74 45.00

BAST B540 1 .40 476.00 340.00

CAPRIO B540 209.70 37,746 .00 180.00CHAPUNOFF B540 192.20 12,493 .00 65.00

CRESPO B540 1 .00 65 .00 65.00

GOULD B540 0.00 0.00 120 .00HALE B540 0.50 110 .00 220.00

HOLMES B540 0.30 79 .50 265.00

JUAN B540 9.50 6,222 .50 655.00KRAINSON B540 3 .20 368 .00 115 .00LEHMAN B540 3 .40 969 .00 285.00

MARTIN B540 0.00 0.00 355 .00

MASSAD B540 1 .30 520.00 400.00

MOON B540 3 .90 624.00 160.00PENNIE B540 5 .50 1,622 .50 295 .00

RASILE B540 7.90 3,507 .09 445.00

SERENTILL B540 1 .20 78 .00 65.00

STEINBERG B540 5 .30 795 .00 150.00

TORNES B540 0.00 0 .00 45.00TUCKER B540 0 .20 13 .00 65 .00ZARON B540 47 .80 16,969.00 355.00

Total 495 . 80 82 ,725.33

EXHIBIT B

ACTIVITY CODE CATEGORY : B550 DISCOVERY MATTER S

NAME Code HRS VALUE RATEBAST B550 14 . 00 4,760 . 00 340.00BUBB B550 0.00 0.00 200 .00CAPRIO B550 14 . 80 2,664 . 00 180 .00DUNN B550 0 . 00 0.00 45.00ECKHARDT B550 89 . 30 23,218 .00 260 .0 0GUTSTEIN B550 0 . 20 26.00 130 .00HESSION B550 5 .50 1,677 . 50 305 .00PREVOST B550 4 . 10 738 . 00 180 .0 0RASILE B550 34.40 15,074.89 445 .00ZARON B550 4.10 1,455 . 50 355 .00

Total 166 .40 49 ,613.89

EXHIBIT B

ACTIVITY CODE CATEGORY : B560 LITIGATION NEPHROSNAME Code HRS VALUE RATEBAST B560 34.00 11,560.00 340.00CAPRIO B560 47.50 8,550 .00 180.00ENJAMIO B560 0 . 00 0.00GOULD B560 4.70 564.00 120.00HERNANDEZ B560 0.00 0 .00 150.00

LECON B560 4.50 540.00 120 .00

MOON B560 1 .40 224 . 00 160 .00

RASILE 8560 0.30 135.37 445.00RUDASILL B560 0 .00 0.00 120 .00SERENTILL B560 1 .90 123 .50 65.00

SUAREZ B560 0 .80 160 .00 200.00

THORNTON B560 185.80 48 ,308.00 260.00TUCKER B560 2 .50 162 .50 65.00

ZARON B560 6 .60 2,343 .00 355.00

Total 290 .00 72 ,670 .37

EXHIBIT B

ACTIVITY CODE CATEGORY : B570 LITIGATION - SE CNAME Code HRS VALUE RATEBAST B570 2.60 884.00 340 .00CAPRIO B570 0.50 90.00 180 .00CRESPO B570 0.00 0.00 65.00

ECKHARDT B570 0.30 78.00 260 .00GUTSTEIN B570 0.00 0 .00 130 .00RASILE B570 19 . 10 8,585 .82 445.00

ZARON B570 12 .20 4,331 .00 355 .00

Total 34.70 13,968.82

EXHIBIT B

ACTIVITY CODE CATEGORY : B575 LITIGATION - CITCONAME Code HRS VALUE RATE

ALEXANDER B575 2.50 687.50 275 .00BAST B575 14.40 4 ,896 .00 340.0 0DRAY B575 1 .00 495 .00 495.00ECKHARDT B575 21 .70 5,642.00 260.00

FERNANDEZ B575 5 .70 1,026 . 00 180.00FOXX B575 3 .60 1,097 .91 305 .00

GUTSTEIN B575 4.00 520.00 130.00

LEHMAN B575 34 . 80 9,918 . 00 285 .00MOON B575 1 .80 288 . 00 160 .00PENNIE B575 0.00 0.00 295 .00PREVOST B575 35 .20 6,336 . 00 180 .00RANGE B575 0.60 315 .00 525 .00RASILE B575 64.00 28,463 .92 445.00

RITTER, 11 B575 0.50 237.50 475.00

RODRIGUEZ B575 24.30 4,374 . 00 180 .00ZARON B575 77.60 27,548.00 355 .00

Total 291 . 70 91 ,844.83

EXHIBIT B

ACTIVITY CODE CATEGORY : B590 FRAUDULENT TRANSFER

NAME Code HRS VALUE RATE

BAST B590 81 . 90 27,846 . 00 340.00CAPRIO B590 9.20 1,656 .00 180.00CHAPUNOFF B590 17 . 00 1,105 . 00 65 .00CRESPO B590 0 . 00 0.00 65 .00ECKHARDT B590 4 .70 1,222 . 00 260.00GUTSTEIN B590 38.40 4 ,992.00 130 .00HERNANDEZ B590 75.90 11,385.00 150 .00RASILE B590 1 .00 451 . 22 445 .00

TUCKER B590 0 .40 26 . 00 65.00

ZARON B590 8.60 3 ,053 .00 355 .00

Total 237.10 51,736.22

EXHIBIT B

ACTIVITY CODE CATEGORY : B595 LITIGATION - INSIDER SNAME Code HRS VALUE RATE

ALEXANDER B595 0 . 30 82 . 50 275 .00

BAST B595 1 .90 646 . 00 340.00

CAPRIO B595 4 . 70 846.00 180 .00

DRAY B595 0 . 30 148 . 50 495 .0 0

LEHMAN B595 101 .00 28 , 785 .00 285 .00

PERKINS B595 1 .00 130 . 00 130 .00QUACKENBOSS B595 33 . 30 10,822 . 50 325 .00

RASILE B595 11 .70 5,177 . 61 445 .00

ZARON B595 11 .30 4,011 . 50 355 .00

Total 165 .50 50,649 .61

EXHIBIT B

ACTIVITY CODE CATEGORY : B596 LITIGATION - PW C

NAME Code HRS VALUE RATE

BAST B596 0 .40 136 .00 340 .00

ECKHARDT B596 2 .10 546 . 00 260.00

RASILE B596 6 .90 3,040.52 445 .00

ZARON B596 3 .70 1,313 .50 355 .00

Total 13 .10 5,036 .02

EXHIBIT B

ACTIVITY CODE CATEGORY : B701 MICHAEL LAUE RNAME Code HRS VALUE RATE

BAST B701 7.50 2,550.00 340.00ECKHARDT B701 75 .20 19,552 .00 260.00

GUTSTEIN B701 6 .70 871 .00 130 .00PENNIE B701 0 . 30 88 .50 295.00

RASILE B701 4.30 1,940 .29 445.00

SOTO B701 3 . 80 817 .00 215.00STEINBERG B701 3 .50 525 .00 150 .00

SUAREZ B701 0.20 40.00 200.00ZARON B701 7 .60 2,698 .00 355.00

Total 109.10 29,081 .79

EXHIBIT 2

Summary of Requested Reimbursement of Expenses(HUNTON & WILLIAMS LLP )

Description Amount

Copying 8,358.20

Outside Printing 223.1 8

Telephone 445.35

Online Research 21,968 .83

Delivery serv ices/messengers 8,742.24

Postage 964 .1 3

Local travel 33 .76

Out-of-Town Travel 1,987.44

Meals 364 .7 1

Subpoena fees 7,548 .1 3

Witness fees -160 .40

Deposition Transcripts 1,796 .52

Trial Transcripts 100 .00

Litigation Support 25,719 .92

Experts 1,259 .75

Local counsel 250.00

Other-Miscellaneous -1,416 .16

Other-Filing Fees 1,767 .00

Other-Secretary of State Fees 30 .00

TOTAL EXPENSES 79,982.60