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

Case 1:01-cv-00645-JLK

Document 194-4

Filed 10/12/2007

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EXHIBIT B SUMMARY OF BILLINGS July 1, 2007 through September 30, 2007

I.

CASE BACKGROUND

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

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Case 1:01-cv-00645-JLK

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

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II.

SCOPE OF ACTIVITIES AND RELATED PROFESSIONAL FEES

This is the Receiver's eighth application for professional fees and expenses. Detailed descriptions of the activities undertaken by the Receiver since its appointment through the end of the period preceding that covered by this fee application are provided in the Receiver's quarterly reports for the calendar quarters ended December 31, 2005, March 31, 2006, June 30, 2006, September 30, 2006, December 31, 2006, March 31, 2007 and June 30, 2007. Just prior to the beginning of the calendar quarter covered by this fee application, the Receiver had reviewed and considered a total of 1,866 claims submitted by investors in J&K Global Marketing Corporation ("J&K Global") and AAA-Auction.com, Inc. ("AAAAuction.com"). Those claims represented approximately 4,600 investments in J&K Global and at least 22 investments in AAA-Auction.com. The total amount claimed by those 1,866 claims was $4,981,072. During the calendar quarter covered by this fee application, the Receiver's staff, among other things: ! ! Prepared and submitted to the Court the Receiver's Seventh Quarterly Report for the Quarter Ended June 30, 2007. Thoroughly reviewed the 1,866 claims mentioned above and eliminated a significant number of duplicate claims. In addition, the Receiver considered a handful of Late-Filed Claims submitted shortly before the filing of its status report and motion on July 27, 2007. Details concerning the number and amount of claims allowed/disallowed by the Receiver can be found in the Receiver's Eighth Quarterly Report for the Quarter Ended September 30, 2007 ("Eighth Quarterly Report"), filed with the Court on October 11, 2007.

Case 1:01-cv-00645-JLK

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Filed 10/12/2007

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 3 ! Responded to the Motions for Review by Court filed by claimants James Raissis ("Raissis"), Karyn Daniels ("Daniels"), Gary Pedler ("Pedler"), and Frank L. Miller ("Miller"). Prepared and filed with the Court Receiver's Combined Status Report and Motion for Order Authorizing and Directing Payment of Allowed Claims and to Set Hearing Date on Claimants' Motions for Review by Court ("July 27 Status Report and Motion"). Among other things, the July 27 Status Report and Motion asked the Court to approve the payment of 1,746 allowed claims, totaling $2,124,980. Prepared for the Clerk of the Court's Financial Supervisor Microsoft Excel® spreadsheets containing all of the data needed to prepare, issue and mail checks to claimants approved by the Court's Order Authorizing and Directing Payment of Allowed Claims and Setting a Hearing Date on Claimants' Motions for Review ("July 31 Order"). The spreadsheets included (1) a list of 1,011 checks, totaling $1,098,205, to be made payable to J&K Global investors residing in the United States; (2) a list of 713 checks, totaling $637,575, to be made payable to J&K Global investors residing in 29 foreign countries; and, (3) a list of 22 checks, totaling $389,200, to be made payable to AAA-Auction.com investors, all of whom reside in the United States. Sent a broadcast e-mail to all claimants approved to receive a distribution check, advising them of the Court's July 31 Order and the anticipated time table for distribution of checks. In addition, the Receiver updated its website to allow claimants the opportunity to review all exhibits to the July 27 Status Report and Motion and to keep them informed of the check process. Worked closely with the Clerk of the Court's Financial Supervisor to monitor and assist with the issuance and mailing of all checks approved by the Court's July 31 Order, less several additional duplicate claims discovered during the check preparation process. Received and handled, literally, hundreds of e-mail, telephone and postal communications from claimants regarding previously undisclosed address changes and the status of their claims and/or checks. In addition, the Receiver received communications from, and maintained a list of a number of J&K Global investors wanting to submit a claim, for the first time, after the receipt of a distribution check by a friend or family member.

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 4 ! Reviewed and considered an additional 17 claims received by the Receiver prior to August 10, 2007, the date after which the Receiver determined that it would no longer consider late-filed claims. Successfully negotiated a mutually-satisfactory resolution of the Motions for Review by Court filed by Daniels, Pedler and Miller. The Receiver also made several attempts to contact Raissis to discuss his claim; but, to no avail. Prepared, forwarded to the claimant for signature, and filed with the Court all pleadings and proposed orders related to settlement of the Daniels, Pedler and Miller claims. Communicated with both the Federal Public Defender's Office and the U.S. Attorney's Office regarding the amount and status of the criminal restitution ordered to be paid by Defendant Kenneth Weare, as well as the identity of investors submitting a claim in this matter and the amount of payment to each approved by the Court. Prepared and filed with the Court Receiver's Unopposed Motion for Order Authorizing and Directing Payment of Allowed Claims ("September 7 Motion"), asking the Court to approve the payment of 14 additional claims, totaling $23,625.

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In preparing this fee application, the Receiver noted that the total time spent by the Receiver's staff responding to e-mails and telephone calls or otherwise communicating with investors during this receivership, 666.3 hours, has been greater than the total time spent reviewing, validating and administering claims, 608.0 hours. All other categories, together, total 419.1 hours, for an aggregate total of 1,693.4 hours. For the three-month period from July 1, 2007 through September 30, 2007, the Receiver requests the payment of its professional fees in the amount of $34,259.00 and the reimbursement of its out-of-pocket expenses in the amount of $11,741.52. The effective hourly rate requested by the Receiver in this fee application is $138.87. To date, the Court has approved payment to the Receiver of $181,537.50 for professional fees and $68,227.30 for reimbursement of the Receiver's out-of-pocket expenses. A breakdown, by category, of the Receiver's hourly charges for this fee application and all previous applications follows:

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 5 Communication and/or Reports to the Court Hours billed in this category relate to the preparation, review, revision and submission of quarterly reports to the Court that present and discuss the Receiver's activities for the quarter, as well as all pleadings and other submissions to the Court by the Receiver, including the July 27 Status Report and Motion, the September 7 Motion, and the Receiver's pleadings related to the five Motions For Review By Court filed with the Court. In addition, this category includes communications with the Clerk of the Court's Financial Supervisor regarding the preparation, issuance and delivery of checks to investors approved by the Court. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 40.4 0.0 0.0 0.0 0.0 0.2 40.6 Fees $0.00 $10,100.00 $0.00 $0.00 $0.00 $0.00 $10.00 $10,110.00 Previous Applications Hours 8.5 24.4 0.0 0.0 0.0 0.0 0.0 32.9 Fees $2,125.00 $4,475.00 $0.00 $0.00 $0.00 $0.00 $0.00 $6,600.00

Cumulative Hours 8.5 64.8 0.0 0.0 0.0 0.0 0.2 73.5 Fees $2,125.00 $14,575.00 $0.00 $0.00 $0.00 $0.00 $10.00 $16,710.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 6 Communication and/or Meeting with the SEC Included in the hours billed in this category are meetings and telephone conferences with attorneys and/or other staff at the SEC. These meetings pertain to the SEC's investigation into the fraud engaged in by the Defendants, the SEC's steps in recovering data related to the fraud, and the Receiver gaining an understanding of the work completed by the SEC in conjunction with this matter.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 1.2 0.0 0.0 0.0 0.0 0.0 1.2 Fees $0.00 $300.00 $0.00 $0.00 $0.00 $0.00 $0.00 $300.00

Previous Applications Hours 8.4 14.6 0.0 0.0 0.0 0.0 0.0 23.0 Fees $2,100.00 $3,400.00 $0.00 $0.00 $0.00 $0.00 $0.00 $5,500.00

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

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Filed 10/12/2007

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 7 Project Planning and Coordination Included in the hours billed in this category are meetings and telephone conferences pertaining to establishing a framework for notifying and collecting information regarding potential claimants, receiving claims, validating claims and preparing a proposed plan of distribution for the Court. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Jan L. Loser Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $100 $375 $50 Hours 0.0 2.2 0.0 8.0 0.0 0.0 1.5 11.7 Fees $0.00 $550.00 $0.00 $600.00 $0.00 $0.00 $75.00 $1,225.00 Previous Applications Hours 34.9 65.9 0.0 3.5 7.7 0.0 0.5 112.5 Fees $8,225.00 $9,975.00 $0.00 $350.00 $770.00 $0.00 $25.00 $19,345.00

Cumulative Hours 34.9 68.1 0.0 11.5 7.7 0.0 2.0 124.2 Fees $8,225.00 $10,525.00 $0.00 $950.00 $770.00 $0.00 $100.00 $20,570.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 8 Communication and/or Meeting with Counsel for the Receiver Included in the hours billed in this category are meetings and telephone conferences with the Receiver's attorney. These meetings and telephone calls relate to the preparation for procedural motions for the claims process and all relevant court filings required to establish the claims process and procedures. Also included in this category were discussions related to the basis for consolidation of the entity defendants, J&K Global Marketing Corporation and AAA-Auction.com, Inc.

Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 1.90 0.00 0.00 0.00 0.00 1.90 Fees $0.00 $475.00 $0.00 $0.00 $0.00 $0.00 $475.00

Previous Applications Hours 3.75 5.00 0.00 0.00 0.00 0.00 8.75 Fees $937.50 $875.00 $0.00 $0.00 $0.00 $0.00 $1,812.50

Cumulative Hours 3.75 6.90 0.00 0.00 0.00 0.00 10.65 Fees $937.50 $1,350.00 $0.00 $0.00 $0.00 $0.00 $2,287.50

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Filed 10/12/2007

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 9 Communication and/or Meeting with Investors Included in the hours billed in this category are review and responses to email questions sent to the Receiver by investors, as well as listening and responding, via email, to voicemails left for the Receiver. Also included in this category are unsolicited phone calls from investors answered by representatives of the Receiver. This category primarily captures time spent locating, soliciting registrations, and updating contact information for potential claimants. Time spent communicating with investors related to their particular claimed amount is recorded in the "Claims Administration" category summarized later in this exhibit. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 29.10 0.00 67.90 0.00 21.10 118.10 Fees $0.00 $7,275.00 $0.00 $5,094.00 $0.00 $1,055.00 $13,424.00 Previous Applications Hours 13.50 73.90 0.00 382.90 0.00 77.90 548.20 Fees $3,000.00 $15,625.00 $0.00 $32,240.00 $0.00 $3,165.00 $54,030.00

Cumulative Hours 13.50 103.00 0.00 450.80 0.00 99.00 666.30 Fees $3,000.00 $22,900.00 $0.00 $37,334.00 $0.00 $4,220.00 $67,454.00

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 10 Identification of Investors Appearing on the FBI/DOJ Restitution List This category contains time spent on cross-referencing the restitution list created pursuant to Mr. Weare's plea agreement to the database of potential claimants provided to the Receiver by the SEC. The Department of Justice requested that the Receiver account for any funds disbursed which may reduce the restitution amounts due from Mr. Weare and to report back to them once the final distribution amounts are determined. During the period covered by this fee application, the Receiver also spent time communicating with and assisting the Federal Public Defender's Office. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 3.30 0.00 0.00 0.00 0.00 3.30 Fees $0.00 $825.00 $0.00 $0.00 $0.00 $0.00 $825.00 Previous Applications Hours 0.00 0.00 0.00 19.70 0.00 1.75 21.45 Fees $0.00 $0.00 $0.00 $1,970.00 $0.00 $87.50 $2,057.50

Cumulative Hours 0.00 3.30 0.00 19.70 0.00 1.75 24.75 Fees $0.00 $825.00 $0.00 $1,970.00 $0.00 $87.50 $2,882.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 11 Website and/or Database Development and Testing Included in the hours billed in this category are meetings and telephone conferences with the website and database developers. These discussions related to the data to be captured from the potential claimant pool, validation of such data, the establishment of user names and passwords of individuals and entities contained in the database seized by the SEC during its investigation. Also included is time spent preparing narrative for the website and designing, formatting and implementation of the screens to be placed on the website. No time was incurred for this activity during the period covered by this fee application.

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

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

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

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 12 Communications - Miscellaneous Hours billed in this category relate to communications meetings with parties other than counsel and investors, such as vendors or suppliers. No time was incurred for this activity during the period covered by this fee application.

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

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

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

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 13 Database Verification and Analysis ­ Bank Account Activity Hours billed in this category relate to the compilation, verification, and ongoing analysis and modification of an electronic database created from various MS Excel workbooks and spreadsheets prepared by the SEC based on its review and analysis of bank account statements and enclosures by the either seized from the Defendants or directly subpoenaed from the banks. Also included in this category is the review of source documents related to the validation and supplementation of this database. No time was incurred for this activity during the period covered by this fee application.

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

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

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

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 14 Database Verification and Analysis ­ Investor Related Activity Hours billed in this category relate to the verification and ongoing analysis and maintenance of an electronic database seized from the Defendants which contains an accounting of cash deposits and withdrawals as well as contact and identification information of investors. Also included in this category is the review of documents related to the validation and supplementation of this database. No time was incurred for this activity during the period covered by this fee application.

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

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

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

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 15 Claims Administration Time included in this category relates to the establishment of the time period and procedures for investors to submit their claims, the procedures to be followed by the Receiver in allowing/disallowing claims and the process for investors to appeal any claims disallowed by the Receiver. Also included is time spent preparing and filing with the Court the Motion to Establish Procedures, Claims Bar Date Notice and proposed Proof of Claim Form; updating the Receiver's website to notify investors of the claims process; sending a broadcast email and mailing paper Proof of Claim forms to investors who had provided the Receiver with their current contact information; and, reviewing and allowing/disallowing (in whole or in part) each claim submitted to the Receiver. Current Application Biller John Paul Anderson Michael D. Burns Eileen K. Leslie Stephanie L. Katz Leslie A. Patten Carolyn J. Pharis Totals Rate $250 $250 $125 $100 $375 $50 Hours 0.00 15.20 0.00 54.60 0.00 0.10 69.90 Fees $0.00 $3,800.00 $0.00 $4,095.00 $0.00 $5.00 $7,900.00 Previous Applications Hours 49.90 134.3 17.50 270.80 0.00 65.60 538.10 Fees $4,100.00 $26,750.00 $2,187.50 $20,420.00 $0.00 $2,455.00 $55,912.50

Cumulative Hours 49.90 149.5 17.50 325.40 0.00 65.70 608.00 Fees $4,100.00 $30,550.00 $2,187.50 $24,515.00 $0.00 $2,460.00 $63,812.50

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SEC v. J&K Global Marketing Corp., et al. Exhibit B, Summary of Billings July 1, 2007 through September 30, 2007 Page 16 III. SUMMARY OF PROFESSIONAL FEES A list of the names and hourly rates of all professionals and para-professionals who billed time on this matter is contained at Exhibit A. Attachment 1 contains a summary of professional fees in chronological order by month, and includes detail by biller and by category for the period July 1, 2007 through September 30, 2007. As set forth in Attachment 1, the Receiver is requesting the payment of $34,259.00 for 246.7 hours of services, which represents an effective hourly rate of $138.87. IV. SUMMARY OF EXPENSES Attachment 2 contains a detailed listing of expenses by category for the period July 1, 2007 through September 30, 2007. V. CONCLUSION The Receiver believes that the requested fees and expenses were reasonable and necessary to complete the tasks required and discharge its duties in this matter. The Receiver has charged reasonable rates based upon the customary compensation charged by comparably skilled professionals charged with similar fiduciary duties. Further, the Receiver believes the requested fees and expenses were reasonable and necessary considering the complexity of the issues involved. The Receiver has reviewed this summary of billings to ensure that it accurately reflects the fees and outof-pocket expenses incurred by the Receiver.