Rubin & Levin 135 N. Pennsylvania St., Suite 1400 Indianapolis, IN Ph (317) Fax (317) FID #

Transcription

1 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 1 of 41 Rubin & Levin 135 N. Pennsylvania St., Suite 1400 Indianapolis, IN Ph (317) Fax (317) FID # WORK IN PROCESS ITT Educational Services, Inc. Case No JMC-7A Deborah J. Caruso, Chapter 7 Trustee Date Range: To: Client/Matter Code: 01/01/ /30/ Originating Timekeeper: DJC Caruso, Deborah J. Billing Timekeeper: DJC Caruso, Deborah J. Attorney Time 01 - Asset Analysis and Recovery DJC Review student settlement as it may relate to Perkins loans $ DJC Review information provided by Huber to evaluate assignment of Perkins loans to Ed $ DJC Review Perkins loan regulations $ DJC to Mark regarding Conduent and loan assignment $ MDR Finalize asset recovery letter to New York Office of Unclaimed Funds, assemble enclosures, prepare overnight delivery DJC Conference with Mark Huber regarding transfer of Perkins loans DJC Review and revise agreement with Conduent regarding assignment of Perkins loans; review student settlement and Court order regarding assignment of Perkins loans; s to Mark Huber $ $ $ DJC Begin preparation of application to assign Perkins loans $ DJC Respond to questions from Meredith regarding Perkins loans DJC Review application to assign Perkins loans, to Mark Huber regarding notice to students DJC Review questions regarding notice to borrowers of Perkins loan assignments; s to Mark Huber DJC Review and revise motion to assign Perkins loans; s with David DeCelles DJC Review numbers from Huber regarding Perkins loan participants; review governmental regulations $ $ $ $ $ of 41 Page 1 of 41

2 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 2 of DJC to DeCelles regarding Motion to Assign Perkins Loans $ DJC Review from Huber regarding notification to Perkins borrowers DJC Review Student Class Settlement and Court Order in preparation for conference call with the students MRT Review and respond to from Tim Konopinski and Kelly Osburn regarding preserving data $ $ DJC Respond to DeCelles and to Huber $ JCH Attention to s to/from from BGBC regarding ADP offer of refund JCH Attention to IRG inquiry and review and response to BGBC documentation $ $ Asset Disposition Subtotal for: Asset Analysis and Recovery $4, JCH Office conference with Trustee and telephone conference regarding claims purchase issues ENH Drafting motion to destroy electronic waste and exchange with ESI to determine estimated cost of disposal DJW ed Johnson Control regarding upcoming closing on Angola Court JCH Attention to vendor review and to paralegal regarding same LFD Re Indianapolis- s re execution of First Amendment and Assignment MRT Exchange s with Ethan Fernhaber regarding 1st amendment to purchase agreement and assignment and assumption agreement DJW Reviewed vendor invoices. Prepared spreadsheet with vendors for payment approval. ed Deb Caruso/John Hoard requesting approval to pay vendors LFD Re Indianapolis-Conference with Trustee re execution of First Amendment and Assignment DJW Telephone call with John Hoard regarding vendors to be paid week ending 10/06/ DJW Processed vendor checks for payment. ed Robin McGraw to print checks, obtain Trustee's signature and mail $ $ $ $ $ $ $ $ MRT Revise motion to destroy $ JCH Review billings from vendors and to/from paralegal regarding approval DJW Reviewed utility spreadsheet. ed John Hoard/Deb Caruso for approval. ed Rebecca Hite to notify of approval to pay $ of 41 Page 2 of 41

3 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 3 of DJW Reviewed vendor invoices. ed John Hoard and Deb Caruso for authorization to pay invoices DJW Exchanged with Rebecca Hite regarding utility invoices to be paid LFD Re Indianapolis-Revise Closing Documents, Conference with Trustee, Review re HVAC refrigerant issue MRT Meeting with Debbie Caruso regarding assignment of Perkins loans and retention of Conduent in connection with assignment of Perkins loans MRT Draft motion for authority to assign Perkins loans to Department of Education LFD Re Indianapolis-Conference with Trustee, to Buyer's Counsel re Closing Documents, s to Title Company re Closing Statement MRT Further draft motion to assign Perkins Loans to Department of Education (1.6); Detail review of relevant statutory law regarding Perkins Loans (1.2) DJW Exchanged s with Larry Dorocke regarding Indianapolis closing LFD Re Indianapolis- to Title Company re Closing Statement LFD Re Indianapolis-Review revised Title Commitment, s to Buyer's Attorney re Federal Tax Lien, Internal re status of Federal Tax Lien $ $ $ $ $ $ $ $ MRT Further revise motion to assign Perkins loans $ MRT Review and respond to from Steve Emery regarding issues with Indianapolis closing DJW Reviewed vendor invoices. Prepared spreadsheet for vendor approvals. ed John Hoard and Deb Caruso for approval. to Deb Caruso regarding payments to Mark Huber $ LFD Re Indianapolis- to Title Company re Federal Tax lien $ MRT Review and respond to s from Steve Hargrove regarding closing for Indianapolis sale DJW Prepared vendor checks. ed Robin McGraw to print, obtain Trustee's signature and distribute DJW Telephone call with Amanda at Johnson Control regarding outstanding service contracts for ITT properties $ LFD Re Indianapolis- to Buyer's Attorney $ DJW Reviewed vendor invoices. Prepared spreadsheet for review. ed Deb Caruso and John Hoard for approval to pay vendor invoices $ LFD Re Carmel- to Title Company re missing check $ LFD Re Indianapolis-Phone conference and to Title Company, Review Closing Statement, Brief conference $ of 41 Page 3 of 41

4 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 4 of 41 with Trustee MRT Review and respond to from Tim Konopinski regarding issues with motion to destroy electronic assets (0.2); Meeting with Debbie Caruso regarding issues with motion to destroy electronic assets (0.2); to Rachel Mauceri regarding preserving esata II hard drive and excluding it from the motion to destroy electronic assets (0.1) $ LFD Re Carmel- to Title Company re missing check $ MRT Detail review of closing documents for Carmel, IN in connection with determining status of outstanding check for 1st quarter association assessments and respond to from Larry Dorocke regarding same DJW Reviewed closing statement for N. Meridian St., Carmel, IN. ed Larry Dorocke regarding check from Meridian Title $ $ DJW ed Trustee regarding DWC trademark DJW ed Dan Orcutt and Granite Telecommunication for August/September/October invoices DJW Telephone call with IPL to disconnect service. Telephone call with Citizens Energy Group to disconnect service. ed utility information to ITT Real Estate team, new owners and title company $ $ Exchanged s with Trustee and Larry Dorocke regarding closing DJW ed Granite Communications requesting invoices for August and September. (.2) ed Granite Communications requesting cancelling of services for Indianapolis location. (.2) DJW Exchanged s with real estate team regarding closing of Indianapolis location LFD re Utility prorations, Phone conference and to Broker, Brief conference with Trustee DJC Conference with lawyer regarding zoning issue with Indianapolis property DJW Contacted IPL and Citizens Energy to cancelled disconnect orders LFD Re Indianapolis, Phone conference with Title Company and Buyer's Attorney, Internal s, Revise closing documents DJW Reviewed vendor invoices. Prepared payment spreadsheet. ed Deb Caruso and John Hoard to review and authorize payment DJW Processed vendor checks. ed Robin McGraw to print checks, obtain Trustee's signature and distribute accordingly DJW ed Johnson Control regarding disconnecting services at Angola Court $ $ $ $ $ $ $ of 41 Page 4 of 41

5 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 5 of DJW Exchanged s with Deb Caruso regarding disconnecting utilities for Angola Court $ LFD Work on closing documents, s to Title Company, Brief conference with Trustee MRT Telephone conference with David Decelles regarding Perkins Loans motion DJW ed Granite to disconnect services at Angola Court on 11/06/ ed Johnson Controls to disconnect services at Angola Court on 11/06/2018. Telephone call to Citizens Energy Group (Victor) to disconnect services at Angola Court on 11/06/ Telephone call to IPL to disconnect services at Angola Court at Angola Court. ed real estate team to inform of disconnections LFD Conference with Trustee to sign Closing Documents, Attend closing at Meridian Title in Carmel, IN, s re keys, Post closing s DJW Exchanged s with real estate team regarding closing and settlement statement $ $ $1, ed Signature Bank regarding incoming wire DJW Exchanged s with Dan Orcutt regarding any outstanding invoices for owned real estate MRT Draft report of sale for Indianapolis $ MRT Attention to issues regarding receipt of Michigan tax refund checks MRT Attention to issues with real estate tax refund for San Bernardino, CA and respond to form William Sekerka regarding same $ $ MRT Update real estate tracking sheet $ DJW Telephone call with Meridian Title confirming wiring instructions. Exchanged s with Signature bank regarding incoming wire. (.2) $ Processed incoming wire. Notified real estate team of incoming wire. ed TES to update Signature account. (1.2) DJW ed Johnson Control to confirm disconnection of services at 9511 Angola Court DJW Exchanged s with Rebecca Hite regarding utilities to be paid DJW Telephone call with Johnson Control regarding disconnecting alarm services MRT Review and respond to from Kelly Osburn regarding destruction of assets JCH Attention to approval of billings $ of 41 Page 5 of 41

6 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 6 of 41 Subtotal for: Asset Disposition $11, Case Administration MRT Review and revise motion to destroy e-waste (1.0); exchange with Kelly Osburn regarding potential sale of monitors to ESI (0.2) $ CAN Attention to subpoena from GRM; Notes to file $ CAN Telephone conference with student Kevin Mason regarding transcript (.2); Telephone conference with GRM regarding student transcript issues (.4) $ MRT Draft proposed agenda for October 17th omnibus hearing DJW Prepared checks for 2017 tax payment to the State of New Mexico. ed Robin McGraw to print checks, obtain Trustee's signature and distribute accordingly MDR Draft proposed agenda of matters scheduled for October 17, 2018 omnibus hearing DJC Review AT&T check and cancellation of services; review s form Nicole Gladden; conference with Debbie MRT Review and revise proposed agenda for October 17th omnibus hearing (0.2); to Suzette Bewley regarding proposed agenda for October 17th omnibus hearing (0.1) MRT Telephone conference with Rachel M. regarding motion to destroy assets (0.1); to Tim Konopinski regarding assets to be destroyed (0.1) MRT Draft proposed orders for October 17th omnibus hearing (0.9); to Suzette Bewley regarding proposed orders for October 17th omnibus hearing (0.1) $ $ $ $ $ MRT Prepare for October 17th omnibus hearing $ CAN Received and reviewed correspondence from Dick Kunz (.1); Draft correspondence to GRM regarding same (.1) MDR Prepare hearing binders for October 17, 2018 omnibus hearing $ $ JCH Prepare for and attend hearing regarding Omnibus Hearing $ MRT Further prepare for October 17th omnibus hearing $ MRT Attend October 17th omnibus hearing $ MDR Draft 9th Motion to Extend Assumption/Rejection Period $ MDR Draft 9th Motion to Schedule Additional Omnibus Hearings $ DJW Exchanged s with Melissa Ralph regarding status of Proskauer's order MDR Telephone conference with Suzette Bewley regarding scheduling of future omnibus hearing dates MDR Draft and e-file certificates of service for docket nos. 2993, 2994, 2995 and $ of 41 Page 6 of 41

7 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 7 of DJW Updated professional fees spreadsheet. ed to Melissa Ralph $ DJW Exchanged s with Trustee and Jeff Marwil regarding payment to Proskauer $ Reviewed and revised Order, uploaded to Court. ed Court to notify of Order MDR Draft and e-file certificate of service for docket MDR Draft and e-file certificate of service for docket no MRT Draft proposed agenda for November 7th omnibus hearing DJW Review mail received at BGBC. Took necessary actions $ JCH Attention to message from counsel in Texas regarding corporate representative for lawsuit $ DJW ed Trustee regarding DWC trademark $ MDR Draft proposed agenda for November 7, 2018 omnibus hearing MRT Review and revise proposed agenda for November 7th omnibus hearing (0.4); to Suzette Bewley regarding draft of proposed agenda for November 7th omnibus hearing (0.1) MRT Draft proposed orders for November 7th omnibus hearing matters $ $ $ MDR Draft and e-file certificate of service for docket no MRT Finalize proposed agenda for November 7th omnibus hearing MRT Prepare for November 7th omnibus hearing $ MDR Prepare hearing binders for November 7, 2018 omnibus hearing JCH Review agenda and matters set for hearing on Omnibus Hearing and attend hearing $ $ MRT Further prepare for November 7th omnibus hearing $ MRT Attend November 7th omnibus hearing $ JCH Telephone conference with paralegal and review of invoices MDR Draft and e-file certificates of service for docket nos. 3024, 3027, 3028 and MDR Draft and e-file certificate of service for docket nos and ENH exchange with opposing counsel for objecting utilities re agreed amounts for administrative expense claims $ $ $ MDR Draft and e-file certificate of service for docket no of 41 Page 7 of 41

8 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 8 of JCH Telephone conference with paralegal regarding billings, duplicate billings and exhibits $ DJC Review status of production per subpoenas sent by Kentucky and Harvard CAN Attention to student voic s regarding transcripts (.1); Telephone conference with education verification entity (.2) JCH Review s regarding scheduling for Omnibus hearing; review settings MRT Draft proposed agenda for November 28th omnibus hearing and to Tim Karcher regarding continuing hearing MRT Being drafting proposed orders for November 28th omnibus hearing MDR Draft proposed agenda for November 28, 2018 omnibus hearing $ $ $ $ $ $ MDR Draft 8th Omnibus Settlement Motion $ MDR Draft 8th Omnibus Settlement Notice MRT Finalize and file proposed agenda for November 28th omnibus hearing MDR Prepare hearing binders for November 28, 2018 omnibus hearing JCH Prepare for and attend Omnibus hearing; attention to orders regarding student settlement $ $1, MRT Prepare for November 28th omnibus hearings $ MRT Attend November 28th omnibus hearing $ MDR Research and compile service addresses for all 50 state attorney generals and US attorney general MDR Draft and e-file certificate of service for docket nos and $ JCH Attention to vendor payment and memo to paralegal $ Subtotal for: Case Administration $14, Claims Admin and Objections ENH Continue analyzing post petition utility statements and amounts to determine administrative expense claim amounts for the objecting utility companies ENH Conduct analysis of Dominion Virginia utility invoices to determine administrative expense claim amount ENH Conduct research re notice of buyer of proof of claim (0.7); exchange with Debbie Caruso re claim buyer (0.2); and copy of notice to Omni to update claims spreadsheet (0.1) $ $ $ ENH Draft to Katie at Omni re: claim issue (0.2); and $ of 41 Page 8 of 41

9 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 9 of 41 $ continue to analyze invoices to determine administrative expense amount for objecting utilities (1.8) ENH Continue analysis of post-petition invoices to determine correct amount of administrative expense claim for Dominion Virginia Power MRT to Rob Briedenbach regarding potential distribution to unsecured creditors MRT Factual inquiry regarding notice of landlord administrative claim procedure to TDCA Resource Square, LLC ENH Conference with Meredith Theisen to discuss resolution of administrative expense claims MRT Factual inquiry as to allowed, but not yet paid admin expenses (0.9); Meeting with Beth Hahn regarding status of objecting utility unresolved admin expenses (0.6); Detailed to Debbie Caruso regarding status of allowed, but not yet paid admin expenses (0.9) ENH Continue analysis of post-petition invoices to determine correct amount of administrative expense claim for all objecting utility companies $ $ $ $ $ MRT Draft notice of objecting utilities' allowed admin expenses $ DJW Telephone call with former employee regarding status of proofs of claim CAN Analysis of proposed revisions to Leveski Protective Order and conference re: same (.6); Draft correspondence to opposing counsel regarding status of matter re: Leveski (.2) CAN Received and reviewed correspondence from opposing counsel for Leveski (.1); Draft correspondence to opposing counsel regarding telephonic conference and protective order (.1) MRT to Debbie Caruso and Debra Wright regarding unpaid admin expenses MRT Review of documents related to Level 3 admin expense and to John Hoard regarding same CAN Review, analysis, and attention to privilege log of Leveski responsive documents (1.6); Memorandum to file regarding review and budget (multiple) (.3); Draft correspondence to Tim Konopinski regarding search of responsive ESI (.1) CAN Telephone conference with John Ketchem regarding Leveski (.4); Drafting detailed correspondence to John Ketchem re: same (.3); Received and reviewed correspondence from opposing counsel (.1); Review of proposed changes to protective order.2) $ $ $ $ $ $ MRT Draft motion for authority to pay TransAmerica invoice $ CAN Draft correspondence to Tim Konopinski regarding ESI searches re: Leveski (.1); Analysis of changes to protective order re: Leveski (.2); Memorandum to file re: changes (.1) MRT Attention to issues with payment of Amazon's allowed administrative claim and respond to from John $ of 41 Page 9 of 41

10 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 10 of 41 Kaplan regarding same MRT Telephone conference with Katie Nownes regarding student proof of claim issue MRT Attention to issues with payment of Amazon's allowed administrative expense $ Subtotal for: Claims Admin and Objections $7, Fee/Employment Applications MRT Begin compiling fee information related to interim fee application for Rubin & Levin related to avoidance actions MRT Telephone conference with Debra Wright regarding confirmation of payments received by A&G Realty and Tiger Capital DJW Telephone call with Meredith Theisen regarding final fee applications for Tiger Capital Group and A&G Realty MRT Attention to issues with itemized time records in connection with Rubin & Levin's 1st interim fee application for avoidance actions MRT Further compile fee information related to interim fee application for Rubin & Levin related to avoidance actions (2.3); Detail review of settled avoidance actions in connection with interim fee application for Rubin & Levin (1.9) JCH Office conference with Meredith Theisen and Trustee regarding preparation of fee application related to avoidance actions MRT Further review of time entries and settled avoidance actions in connection with interim fee application for Rubin & Levin MRT Meeting with John Hoard and Debbie Caruso regarding interim fee application for Rubin & Levin for avoidance claims (2.0); Begin drafting interim fee application (1.0) MDR Finalize and file Proskauer Rose LLP's September Notice of Invoice MRT Attention to issues regarding payment of professional fees from benefit plans $ $ $1, $ $ $1, $ JCH Attention to contingency fee app $ MRT Draft notice of invoice for McKool for September 2018 and update compensation tracking sheet (0.7); Review and respond to from John Hoard regarding McKool September 2018 invoice (0.1) MRT Draft Rubin & Levin 1st interim fee application for avoidance actions, including detail review of itemized statement $ $1, MDR Draft and e-file BGBC's September Notice of Invoice $ MDR Finalize itemized statement exhibit for avoidance actions first interim fee application $ of 41 Page 10 of 41

11 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 11 of JCH Review and revise contingency fee app regarding Avoidance Actions MRT to Erika Gowen and Howard Gross regarding payment of 20% holdback for BGBC MRT Review of compensation tracking sheet regarding status of BGBC interim fee applications and to Debbie Caruso regarding filing of 4th interim fee application for BGBC MRT Further draft and revise 1st interim fee application for Rubin & Levin for avoidance claims representation MRT Detail review of KSM statement and compensation tracking sheet regarding missing payment (0.1); to Bernadette Fletcher regarding missing payment from Pension Plan (0.1) MDR Continue to finalize itemized statement exhibit for avoidance actions first interim fee application JCH Review and revise time entries for September fee application DJW Exchanged with Trustee regarding Proskauer Order. LM with Suzette Bewley regarding same MRT Telephone conference Suzette Bewley regarding issues with Proskauer's 4th interim fee application order DJW Telephone calls with Suzette Bewley regarding Proskauer Order. Reviewed Motion and Order with Suzette. (.6) Prepared check and FedEx label. ed Robin McGraw to print check, obtain Trustee's signature and mail overnight to Proskauer. (.3) $ $ $ $1, $ JCH Attention to September fee app $ MRT Draft BGBC's 4th interim fee application $ MRT Meeting with John Hoard and Robin McGraw regarding avoidance claims fees $ DJC Briefly review McKool engagement letter $ MRT Further draft BGBC's 4th interim fee application $ MRT Draft application to employ McKool for Peaks litigation $ JCH Review and revise entries for notice of fee applications $ MRT Further draft employment application for McKool for Peaks AP $ DJC Review and revise McKool engagement letter $ MRT Review and respond to from Kyle Lonergan regarding McKool employment application and retention agreement MRT Draft notices of invoices for Rubin & Levin for September $ MRT Revise application to employ McKool for Peaks AP $ of 41 Page 11 of 41

12 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 12 of JCH Review McKool employment agreement and comments regarding same to Trustee $ DJC Review revisions to engagement letter; s to Kyle $ MRT Further revise application to employ McKool Smith for Peaks AP MRT Exchange s with Jim Kane regarding final fee application MRT Revise proposed order on Rubin & Levin's 1st interim fee application for avoidance claims $ MRT Begin drafting final fee application for Kane & Co $ MRT Begin drafting final fee application for A&G Realty $ MRT Draft final fee application for A&G Realty $ MRT Draft notice of invoice for McKool for Deloitte $ MRT Draft notice of invoice for BGBC for October $ MRT Further draft final fee application for Kane & Co $ MRT Telephone conference with Jim Kane regarding interim fee application (0.2); Further revise fee application for Kane & Co. (0.9) MRT Review and revise Proskauer's October 2018 notice of invoice $ $ MRT Update compensation tracking sheet $ Subtotal for: Fee/Employment Applications $16, Relief from Stay Proceedings JCH Office conference with associate regarding changes to Agreed Order CAN Revise Agreed Order Lifting Stay (.4); Attention to hearing transcript (.2); Memorandum to file (.4)--all re: Leveski $ $ JCH Attention to Leveski documentation $ JCH Review and revise agreed order; office conference with associate regarding same; check on matters related to pending discovery CAN Attention to Leveski matters including March 7 hearing and limitations (.3); Memorandum to file (multiple) (.3) MRT Draft agreed entry resolving Leveski stay relief motion (1.6); Detail review of docket regarding relevant events in connection with Leveski stay relief motion (0.7) JCH Telephone conference with Trustee regarding settlement with Students and Agreed Entry regarding Leveski JCH Attention to docket research regarding Side A coverage (2.50); initial attention to review of protective order (.20) $ $ $ $ $1, of 41 Page 12 of 41

13 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 13 of JCH Review protective orders and to trustee $ ENH Conferences with Meredith Theisen and John Hoard re: Leveski legal strategy (1.0); and research status of Side A insurance policies for Leveski matter (1.5) $ MRT Meeting with John Hoard and Beth Hahn regarding Leveski $ DJC Review Order regarding Side A policies; review proposed Leviski entry; to John Hoard JCH Attention to Leveski Agreed Entry and exchange of s with Trustee regarding same; to counsel and revisions to Agreed Entry for review by Leveski's counsel $ $ DJC Review Leviski entry; conference with John Hoard $ DJC Review from Scherer regarding changes to Agreed Entry DJC Review protective order; conference with John regarding application of protective order to all document requests JCH Review discovery protective order and prepare and send to John Ketcham regarding protective order JCH Attention to hearing setting and response from John Ketcham; prompt John Ketcham for action MRT Draft proposed order approving agreed entry on Leveski stay relief motion JCH Review changes to protective order and agreed entry; to trustee $ $ $ $ $ $ DJC Review changes to Leviski Agreed Entry and to John $ DJC to John regarding Leviski entry $ CAN Analysis of status of Leveski litigation (.3); Received and reviewed correspondence from opposing counsel and proposed changes to Agreed Order Lifting Stay (.2); Memorandum to file regarding recommendations (.1); Analysis of proposed changes to protective order (.3); Notes to file regarding proposed changes (.2) -all re: Leveski JCH Attention to Leveski order and memo to counsel for estate in other matters MRT Detail review of revisions to Leveski agreed entry and finalize Leveski agreed entry and meeting with John Hoard regarding same DJC Review s regarding Leviski Agreed Entry and comments from Ron and Jeff; to John Hoard $ $ $ $ MRT Finalize Leveski agreed entry DJC Review s regarding Qui Tam Agreed Entry $ JCH Review docket and office conference with paralegal regarding monitoring case for re-opening and filings by Leveski; prepare for discovery pre-meeting and telephone conference with counsel regarding ESI and discovery $ of 41 Page 13 of 41

14 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 14 of 41 protocols JCH Attention to motion for entry of PO $ Litigation Subtotal for: Relief from Stay Proceedings $11, JCH File review and letter to Trustee and John Rogers regarding summons service $ DJC Conference with Harvard regarding document production $ DJC Review docket and protective order for response to Kentucky subpoena DJC Meeting with Meredith, review response to Kentucky subpoena DJC Review and respond to from Steve regarding Kentucky subpoena $ $ $ DJC Review Steve's response regarding Kentucky subpoena $ DJC Review memo regarding default judgments $ MRT Detail review of formal discovery requests in connection with response to KY subpoena $ DJC s regarding subpoena $ MRT Draft motion to compromise and settle avoidance claim of ServiceNow CAN Memorandum to file and recommendations to Trustee regarding Leveski agreed entry (.6); Notes to file regarding audio recording (.1); Memorandum to file regarding discovery (.1); Further revisions to Agreed Entry (.4) DJC Review and revise Kentucky subpoena; conference with Meredith; conference with Tim regarding remote access; to Todd $ $ $ MRT Review and revise response to KY AG subpoena $ DJW Stopped and reissued checks. ed Robin McGraw to print, obtain Trustee's signature and mail. ed Victoria Roytenberg regarding student checks $ DJC Review student subpoena $ DJC Review information on server mapping as it relates to subpoenas MRT Draft 7th notice of settlement and 7th omnibus settlement motion, including detail review of settlements MRT Revise and finalize motion to compromise and settle with ServiceNow, Inc $ $ $ DJC Review response to student subpoena $ MRT Review and revise response to student claimants' subpoena $ of 41 Page 14 of 41

15 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 15 of DJC Review and revise student subpoena $ MRT Further review and revise response to student claimant subpoena DJC Review from attorney with lawsuit in Kentucky; review claim docket; respond to DJW Exchanged s with Mark Huber regarding student checks CAN Received and reviewed correspondence regarding Leveski agreed entry (multiple) (.1); Notes to file: re same (multiple) (.2) DJC Review and respond to regarding subpoena from Kentucky DJW Telephone call with US Bank regarding balance on Perkin Loan account. ed balance to Meredith Theisen DJC Conference with Todd Leatherman of Kentucky regarding subpoena and document production MRT Draft motion to compromise and settle avoidance claim against Facebook MRT Review and revise motion to compromise and settle avoidance claim against Iron Mountain $ $ $ $ $ $ $ DJC to Todd Leatherman regarding Harvard subpoena $ MRT Draft 8th omnibus settlement notice and motion for avoidance claims MRT Meeting with John Hoard and Debbie Caruso regarding issues with statutory notice (0.4); Meeting with John Hoard regarding necessary revisions to final student claimant settlement order (0.5); Revise final student claimant order to address issues with statutory notice (0.6) MRT Further revise final order on student claimant motion and exchange several s with counsel for student claimants CAN Received and reviewed correspondence from opposing counsel regarding ESI search terms re: Leveski MRT Attention to issues with finalizing proposed final order for student claimant settlement $ $ $ $ $ MRT Attention to student class action notice $ CAN Drafting Joint Motion for Entry of Leveski Protective Order $ MRT Meeting with Beth Hahn regarding student proof of claim issue in connection with statutory notice requirement for student claimant settlement CAN Legal inquiry regarding insured-insurer privilege (.4); Draft and review Joint Motion for Entry of Protective Order (1.0); Revise Protective Order (1.0); Conference with John Hoard regarding changes (.5); Memorandum to file comparing original protective order to revised/amended protective order (.8); Draft Agreed Entry Amending Protective Order $ $1, of 41 Page 15 of 41

16 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 16 of WARN Act (.5) Subtotal for: Litigation $11, AM Continue work on work product $ JER Compile prior research re class certification issues and update same JWC Review and analysis of data related to numerosity issue at certain single sites of employment (.9); Office meeting with B. Hahn re: same (.2) ENH Conference with Joshua Casselman to discuss WARN analysis (0.1); and continue conducting WARN analysis for each ITT site (1.6) $ $ $ DJC s to Bernadette $ AM Continue compiling work product $ JER Prepare for weekly litigation team meeting with Trustee (.20); attend same re strategy (1.50) JWC Office meeting with Trustee (1.5); s with K. Osburn at ESI (.2) ENH Conference with Debbie Caruso, Joshua Casselman, and Jim Rossow to discuss status of WARN data analysis, and to determine further analysis needed (1.3); met with staff to discuss and assign task of data entry of adjunct hours from ITT course schedules (0.3); and continue analysis of payroll data per ITT location (3.5) DJC Attention to s regarding compiling data for litigation issues JER Review draft to putative class counsel responding to question presented by them re termination dates (.20): respond to same (.10) JWC Research and analysis re: calculation of adjunct instructors hours worked (1.9); s with Trustee (.3); from interim counsel for putative WARN Act class (.1); Began draft of response (.2) DJC Review s and files to locate names of medical participants; s to Gayl Skolnik JWC Analysis of data on ITT employees by location re: numerosity issue (.7); Conference with B. Hahn re: same (.3) $ $ $1, $ $ $ $ $ ENH Continue analysis of payroll data per ITT location $ ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location JWC Continued analysis of ADP and ITT reports re: numerosity of employees issue at single sites of employment ENH Continue to analyze each ITT location for total employees and hours $ $ $1, of 41 Page 16 of 41

17 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 17 of ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location JER Review detail re master course schedule $ JER exchange with Josh Casselman re status of "employees" for termination after Sept. 6, JWC from K. Osburn at ESI re: status of additional report (.1); s with Trustee (.1); Continued analysis of data and reports re: numerosity at single sites of employment issue (1) $ $ DJC s with Josh and ESI regarding IRIS reports $ JWC s with J. Rossow re: postpetition employees (.1); Revise to interim counsel for putative WARN Act class (.1); Attention to from interim counsel for putative WARN Act Class (.1) JER Review detailed from Jack Raisner re class size, location and "damages" with supporting spreadsheets (.60); analysis of same (.30) JWC Review and analysis of from interim counsel for putative WARN Act class (.3); Review and analysis of spreadsheets prepared for putative WARN Act class interim counsel (3) JER Prepare for meeting with Trustee re litigation (.20); Meeting with Trustee, Josh Casselman and Beth Hahn re discovery and contribute to same re litigation strategy $ $ $1, $ JWC Prepare for and attend meeting with Trustee (1.4) $ JWC Attention to from B. Hahn re: location and inventory of paper documents at HQ ENH Conference with Debbie Caruso, Joshua Casselman, and Jim Rossow to discuss status of WARN data analysis, and to determine further analysis needed (1.1); and continue analysis of payroll data to determine adjunct employee hours per ITT location (2.6) $ $1, DJC Strategy meeting with Jim, Josh and Beth $ AM Continue compiling spreadsheets per location $ JER Review s re WARN liability analysis (.70); research re same (.50) JER Receipt and review of contract renewal detail (.20); instructions to Lisa Dowell (.10); to John Hoard re same contract detail (no additional charge) $ $ JWC Attention to from J. Hoard re: WARN Act defense $ AM Continue spreadsheets by location $ JER Exchange s with Josh Casselman re termination date issues (.20); from Jack Raisner re termination date (.20); from Josh Casselman to Rene Roupinian re number of employees who remained with company after Sept. 6, 2018 (.20) $ of 41 Page 17 of 41

18 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 18 of AM Continue compiling spreadsheets by location $ JWC Attention to from A. McGraw re: status of data entry $ AM Continue compiling spreadsheet data by location $ AM Continue compiling spreadsheet data by location $ AM Continue compiling spreadsheet data by location $1, JER Update from Josh Casselman re degree of completion as to data entry (.10); from Trustee re weekly meeting (.10) JER from Trustee re contact from former employee (.10); provide contact information for WARN Act claim putative class counsel (no additional charge) $ $ AM Continued compiling spreadsheets per location $ JWC from A. McGraw re: status of data entry $ ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location AM Conference with Joshua Casselman, Continue compiling spreadsheets for 3 additional locations that are borderline 50 hours JWC Analysis of updated spreadsheets re: part-time employee issue (1.7); Conference with paralegal re: additional data entry needed (.3); Office meeting with Trustee to discuss same (.4) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location (3.1); and conference with Joshua Casselman to discuss WARN data analysis and legal strategy (0.7) $ $ $1, DJC Conference with Josh regarding calculation of class $ AM Continue compiling spreadsheets by location and implementing formula; to Joshua Casselman JER Update from Josh re formula for estimating adjunct instructional time JWC Office meetings with B. Hahn re: analysis of data and next steps (.6); s with paralegal re: formula in excel (.2); Review initial spreadsheets applying formula (.3); to B. Hahn re: spreadsheets for additional locations (.1) JWC s and conference with paralegal re: additional spreadsheets (.2); Multiple s with B. Hahn re: additional locations (.3) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location $ $ $ $ $ AM Continue compiling spreadsheets per location $ JWC s and meeting with B. Hahn re: ITT online location (.3); Research and analysis of issue re: assigning employees to single site of employment (.7); Meeting with law clerk A. Buis re: same (.2); Review from B. Hahn $ of 41 Page 18 of 41

19 Case JMC-7A Doc 3132 Filed 01/04/19 EOD 01/04/19 15:27:06 Pg 19 of 41 re: assignment of adjuncts to locations (.2) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location JER Review analysis of ADP data re location detail prepared by Beth Hahn (.20); reply from Josh re same (.10) JWC s with B. Hahn re: single site of employment issue and calculation of adjunct hours (.5); Analysis of spreadsheets applying IRS formula (.5) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location AM Conference with Josh Casselman, Begin compiling spreadsheets per location for under 50 employees JWC s with B. Hahn re: numerosity issue (.3); Analysis of data (.4); Conference with paralegal re: inputting additional data (.5) AM Continue compiling spreadsheets per location for under 50 employees JWC Office meeting with Trustee (.2); Attention to from paralegal re: status of data entry (.1); from B. Hahn and review updated spreadsheets (.2); to B. Hahn with comment on format (.1) ENH Conference with Debbie Caruso and Joshua Casselman discuss status of WARN data analysis (0.4); met with staff to discuss and assign additional task of data entry of adjunct hours from ITT course schedules (0.3); and continue analysis of payroll data per ITT location (1.5) AM Continue compiling spreadsheets by location for under 50 employees, and identify assigned locations of those employees teaching at other locations $ $ $ $1, $ $ $ $ $ $ JER Update from Josh Casselman re affected site analysis $ JWC from paralegal A. McGraw with update on data entry (.1); Conference with A. McGraw re: same (.2) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location ACB Researched caselaw re WARN Act and 20 C.F.R (i)(6); draft memo AM Continue compiling spreadsheets and identifying assigned locations JER Review detailed and separate memo prepared by Andrew Buis re affected site analysis JWC Conference with paralegal (.1); Review and memo from law clerk re: single site of employment of adjuncts that taught online and at more than one location (.3) ENH Continue analysis of payroll data to determine adjunct employee hours per ITT location $ $ $ $ $ $ $1, DJC Review memo on single site employment $ of 41 Page 19 of 41