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6. Draft, file and serve motion to appoint receiver, declarations, notice, order, etc. — 40 hours - <br />$7560 <br />7. Review opposition, draft, file and serve reply —15 hours - $2835 <br />8. Inspections of subject property with receiver, staff and opposing counsel — 4 hours - $756 <br />9. Meetings with receiver and city staff — 5 hours - $945 <br />10. Communications with receiver, opposing counsel and staff, including updates, and direction <br />from staff and to receiver —10 hours - $1890 <br />11. Review and respond to receiver's court filings and oppositions from opposing parties — 25 <br />hours - $4725 <br />12. Court appearances (initial hearing, case management conferences, accounting and motion <br />hearings, etc.) — 30 hours - $5670 <br />13. Demands on receiver for City's costs and attorneys' fees (mid -case and at final accounting), <br />review and respond to oppositions -- 20 hours - $3780 <br />14. Case disposition, final ,judgment, notices and case wrap up —12 hours - $2268 <br />Total hours: 192.5 <br />Total attorneys' fees through case disposition: $36.382.50 <br />Estimated costs (preliminary title report service of process mailin�sl• $1_ 500 <br />Grand total: $37,882.50 <br />These attorneys' fees are recoverable fi•om the subject property by law, and we have already <br />determined that the subject property contains enough value to fulfill the City's recovery. We will <br />ask the Court to sign an order allowing the City to recover the fees and costs it incurs out of the <br />receivership estate, as we did in the Saddleback Inn case. Our usual strategy is to make two <br />demands on the estate for repayment: one after the Court approves the receiver's action plan (very <br />soon), and another at the final accou citing. This will help ensure the City is made whole, and <br />perhaps allow the City to use the intermediate funds for other projects. <br />Please feel free to contact me if you wish to discuss further. <br />r <br />Very Truly Yours, <br />Matthew R. Silver, Esq. <br />SILVER & WRIGHT, LLP <br />Attorneys at Law <br />N <br />25F -9 <br />