IN THE SUPREME COURT OF FLORIDA

Transcription

1 IN THE SUPREME COURT OF FLORIDA THE FLORIDA BAR, v. Petitioner, Supreme Court Case No. SC- The Florida Bar File No ,326(15C)FES BRETT A. ELAM, Respondent. / THE FLORIDA BAR S PETITION FOR EMERGENCY SUSPENSION This Petition of The Florida Bar seeks emergency relief and requires the immediate attention of the Court pursuant to R. Regulating Fla. Bar The Florida Bar seeks the emergency suspension of Brett A. Elam, Attorney No , from the practice of law in Florida based on facts that establish clearly and convincingly that Brett A. Elam appears to be causing great public harm as will be shown by facts supported by the affidavit of Carl Totaro, Chief Florida Bar Auditor, attached hereto as TFB s Composite Exhibit A, as follows: AS TO ALL COUNTS 1. The filing of this Petition for Emergency Suspension has been authorized by the Executive Director of The Florida Bar. 1

2 2. Respondent, Brett A. Elam, is and at all times hereinafter mentioned, was a member of The Florida Bar and subject to the jurisdiction and disciplinary rules of the Supreme Court of Florida. 3. This matter was brought before the Bar for investigation by way of the Bankruptcy Court s Order dated October 24, 2017, titled ORDER ON THE ORDER TO SHOW CAUSE WHY BRETT ELAM, ESQ. SHOULD NOT BE SUSPENDED FROM BANKRUPTCY PRACTICE (EFC NO. 347) AND THE BANK OF NEW YORK MELLON S AMENDED MOTION FOR SANCTIONS AGAINST BRETT ELAM, ESQ. (EFC NO. 337) (hereinafter referred to as the October 24, 2017 Order, attached hereto and incorporated herein as Exhibit 1 of TFB s Composite Exhibit A), from the United States Bankruptcy Court Southern District of Florida, West Palm Beach Division, Bankruptcy Court Case No BKC-PHG, styled In re: Kim C. Crawford (hereinafter referred to as the Chapter 11 Bankruptcy Proceeding ). Among other things the bankruptcy found that Mr. Elam had misappropriated funds, willfully violated multiple court orders, and made false representations to the court. As a result, Mr. Elam was suspended for one year or until The Florida Bar completed its investigation. A referral was made by the Bankruptcy Court to The Florida Bar. 4. The Bar s investigation of The Florida Bar File No ,326(15C) has indicated that Respondent caused $34, from the 2

3 bankruptcy estate s Debtor in Possession Bank Account (hereinafter referred to as DIP Account ) to be wrongfully transferred into his trust account and then misappropriated the estate s funds for his own benefit. 5. The enclosed Affidavit of Carl Totaro, Chief Florida Bar Auditor, (attached hereto and incorporated herein as TFB s Composite Exhibit A) is used by the Bar to support this Petition for Emergency Suspension. 6. A Trust Account Subpoena (hereinafter referred to as the Subpoena ) was served upon Respondent on November 17, 2017, requiring the production of bank account records for the compliance audit period of January 1, 2017 through October 31, In response to the Subpoena, Respondent produced some, but not all, of the required documents. 8. A subpoena was served upon Seacoast National Bank on November 17, 2017, requiring the production of Respondent s bank account records for the compliance audit period of January 1, 2017 through October 31, After receiving the documents produced by Seacoast National Bank and the Incomplete Trust Records produced by Respondent, Carl Totaro, Chief Florida Bar Auditor, performed a compliance audit on Respondent s trust account records at Seacoast National Bank, account titled The Law Offices of Brett A. Elam Trust Account, account number ending in #7647, for the period of January 1, 3

4 2017 through October 31, 2017 (hereinafter referred to as the Trust Account ), and thereafter determined that Respondent was not in compliance with Trust Accounting Rules. (See TFB s Composite Exhibit A). 10. Carl Totaro, Chief Florida Bar Auditor, also reviewed the following bank accounts for the period of January 1, 2017 through October 31, 2017: A. The Law Offices of Brett A. Elam P.A. Operating Account number ending in #7654 at Seacoast National Bank; and B. Brett A. Elam Lauren Elam Account number ending in #1630 at Seacoast National Bank. COUNT I RESPONDENT S MISAPPROPRIATION OF THE CRAWFORD ESTATE FUNDS 11. Respondent was retained by Kim Clarke Crawford (hereinafter referred to as "Crawford") to represent her in the Chapter 11 Bankruptcy Proceeding. 12. On November 4, 2014, Respondent was granted permission by the Bankruptcy Court to serve as Crawford's attorney under 11 U.S.C. 327 and Pursuant to 11 U.S.C. 330, Respondent was required to seek permission from the Bankruptcy Court prior to receiving compensation for his services. 4

5 14. Crawford, the debtor, served as the Debtor in Possession to the estate, and as required, opened a DIP Account to hold estate funds. 15. The funds in the DIP Account belonged to the estate. 16. On February 28, 2017, Respondent had a $5, balance in Trust Account # On March 2, 2017, Respondent deposited a check from the DIP Account in the amount of $34, into Trust Account #7647 in which he notated as for "attorney's fees" in the memorandum portion of the check. 18. The $34, transferred into Respondent's Trust Account as "attorney's fees" had not been approved by the Bankruptcy Court or the entities that had an interest in such funds in accordance with 11 U.S.C. 363(c)(2). 19. On March 7, 2017, the bank balance in Trust Account #7647 was $34, $34, of that $34, related to the Crawford matter. 20. During the period of March 20, 2017 through August 3, 2017, twentyseven transfers totaling $54, were made from Trust Account #7647 to Operating Account # The audit determined that $34, of those twenty-seven transfers totaling $54, from Trust Account #7647 to Operating Account #7654 were funds that should not have been disbursed from the Trust Account. 5

6 22. Respondent misappropriated $34, of funds relating to the Crawford matter for his personal benefit by not maintaining those funds in the trust account until approval to disburse those funds was received from the Bankruptcy Court. 23. Wherefore, by reason of the foregoing, Respondent has violated the following Rules Regulating The Florida Bar: [The standards of professional conduct to be observed by members of the Bar are not limited to the observance of rules and avoidance of prohibited acts, and the enumeration herein of certain categories of misconduct as constituting grounds for discipline shall not be deemed to be all-inclusive nor shall the failure to specify any particular act of misconduct be construed as tolerance thereof. The commission by a lawyer of any act that is unlawful or contrary to honesty and justice, whether the act is committed in the course of the attorney's relations as an attorney or otherwise, whether committed within or outside the state of Florida, and whether or not the act is a felony or misdemeanor, may constitute a cause for discipline.]; [A lawyer shall comply with The Florida Bar Rules Regulating Trust Accounts.]; 4-8.4(a) [A lawyer shall not violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another.]; 4-8.4(b) [A lawyer shall not commit a criminal act that reflects adversely on the lawyer's honesty, trustworthiness, or fitness as a lawyer in other respects.]; 4-8.4(c) 6

7 [A lawyer shall not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, except that it shall not be professional misconduct for a lawyer for a criminal law enforcement agency or regulatory agency to advise others about or to supervise another in an undercover investigation, unless prohibited by law or rule, and it shall not be professional misconduct for a lawyer employed in a capacity other than as a lawyer by a criminal law enforcement agency or regulatory agency to participate in an undercover investigation, unless prohibited by law or rule.]; 4-8.4(d) [A lawyer shall not engage in conduct in connection with the practice of law that is prejudicial to the administration of justice, including to knowingly, or through callous indifference, disparage, humiliate, or discriminate against litigants, jurors, witnesses, court personnel, or other lawyers on any basis, including, but not limited to, on account of race, ethnicity, gender, religion, national origin, disability, marital status, sexual orientation, age, socioeconomic status, employment, or physical characteristic.]; and 5-1.1(b) [Money or other property entrusted to an attorney for a specific purpose, including advances for fees, costs, and expenses, is held in trust and must be applied only to that purpose. Money and other property of clients coming into the hands of an attorney are not subject to counterclaim or setoff for attorney's fees, and a refusal to account for and deliver over such property upon demand shall be deemed a conversion.]. 7

8 COUNT II RESPONDENT S MISREPRESENTATIONS TO THE COURT AND OPPOSING COUNSEL, CREDITOR, REGARDING HIS MISAPPROPRIATION OF THE CRAWFORD ESTATE FUNDS 24. On May 9, 2017, Respondent filed the Debtor s Amended Monthly Operating Report (Individual) for the period from March 1, 2017 to March 31, 2017, dated April 16, 2017 (hereafter referred to as the "Amended MOR"). 25. The Amended MOR stated, in part: In anticipation of confirmation hearing March 15, 2017, the D tendered a check for admin fees to counsel. These funds were deposited into counsel's trust account. As the Court failed to confirm the plan, those fees were not approved. The fees are in counsel's trust account pending approval from the Court. (See Exhibit 2, page 22 of TFB's Composite Exhibit A). Professional Fees (Legal, Accounting) Being held in trust 34,400 *** Fees being held in D's attorney's trust Account, pending approval. 34,400 (See Exhibit 2, page 28 of TFB's Composite Exhibit A) /2 Brett Elam Attorney's Fees 34,400 amount being held in trust pending court approval. 8

9 *** * Check number 256 for attorney fees to Brett Elam, was deposited into Counsel's trust account where they remain pending Court approval of the fees. The fees will be disbursed upon approval of the fees. (See Exhibit 2, page 37 of TFB's Composite Exhibit A). 26. On April 18, 2017, Gary Freedman, the attorney representing Creditor, Bank of New York (hereinafter referred to as "the Creditor") ed Respondent to inquire about the $34, transfer of funds. 27. On April 18, 2017, Respondent replied to the Creditor stating, in part: April 18, :47AM Gary she wrote it to me and it is held in trust. I had it for the confirmation hearing. It hasn't been disbursed. I just had it in anticipation of confirmation. I am still holding it. (emphasis supplied) (See Exhibit 2, page 14 of TFB's Composite Exhibit A). April 18, :03AM In every case I have ever been in Gary, the fees are held in trust until the order is entered. I mean really, this is what we are going to argue about. The funds are there and the reason they weren't given back is the same reasons your client worries about it, I don't want them dissipated. (See Exhibit 2, page 13 of TFB's Composite Exhibit A). 9

10 28. A review of Respondent's Trust Account #7647, as of March 31, 2017, reveals that by March 31, 2017 Respondent had already misappropriated $3, from his Trust Account. 29. On April 18, 2017, the bank balance in Trust Account #7647 was $26, Respondent's statements to the Creditor and the Bankruptcy Court were misrepresentations. 31. On April 30, 2017, the bank balance in Trust Account #7647 was $22, The evidence substantiates that Respondent misappropriated at least $11, of funds related to the Crawford matter as of April 30, Respondent was ordered by the Bankruptcy Court to provide evidence to the Creditor that the $34, was in his trust account and that it had always remained in his trust account. (See the May 9, 2017 status hearing transcript, attached hereto and incorporated herein as Exhibit 1, pages of TFB's Composite Exhibit B and the Bankruptcy's Order titled, "Order on Status Conference," attached hereto and incorporated herein as Exhibit 2, page 2 (paragraph 5) of TFB's Composite Exhibit B, attached). 33. In an attempt to deceive the Creditor into believing that the funds had always remained in Trust Account #7647 and were still being held in Trust Account #7647, on May 11, 2017, Respondent made four (4) deposits into Trust 10

11 Account #7647 to raise the balance over $34, (See Exhibit 9, page 8 of TFB's Composite Exhibit A). 34. On July 11, 2017, Respondent ed the Creditor a redacted bank document, attached hereto and incorporated herein as Exhibit 3 of TFB's Composite Exhibit B, purporting to show that on May 11, 2017 he still had the $34, in Trust Account #7647. (See Exhibit 3, page 3 of TFB's Composite Exhibit B). 35. On May 11, 2017, Respondent made the following two (2) disbursements from Trust Account #7647 to Operating Account #7654 as follows: A. "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $6, B. "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $2, (See Exhibit 9, page 8 of TFB's Composite Exhibit A). 36. Thereafter, Respondent continued to deplete the remaining Crawford funds in Trust Account # By August 3, 2017, Respondent had misappropriated the entire $34, Wherefore, by reason of the foregoing, Respondent has violated the following Rules Regulating The Florida Bar: [Violation of the Rules of 11

12 Professional Conduct as adopted by the rules governing The Florida Bar is a cause for discipline.]; [The standards of professional conduct to be observed by members of the Bar are not limited to the observance of rules and avoidance of prohibited acts, and the enumeration herein of certain categories of misconduct as constituting grounds for discipline shall not be deemed to be all-inclusive nor shall the failure to specify any particular act of misconduct be construed as tolerance thereof. The commission by a lawyer of any act that is unlawful or contrary to honesty and justice, whether the act is committed in the course of the attorney's relations as an attorney or otherwise, whether committed within or outside the state of Florida, and whether or not the act is a felony or misdemeanor, may constitute a cause for discipline.]; 4-3.3(a)(1) [A lawyer shall not knowingly make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer.]; 4-8.4(a) [A lawyer shall not violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another.]; 4-8.4(c) [A lawyer shall not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, except that it shall not be professional misconduct for a lawyer for a criminal law enforcement agency or regulatory agency to advise others about or to supervise another in an undercover investigation, unless prohibited by law or rule, and it shall not be professional misconduct for a lawyer employed in a 12

13 capacity other than as a lawyer by a criminal law enforcement agency or regulatory agency to participate in an undercover investigation, unless prohibited by law or rule.]; and 4-8.4(d) [A lawyer shall not engage in conduct in connection with the practice of law that is prejudicial to the administration of justice, including to knowingly, or through callous indifference, disparage, humiliate, or discriminate against litigants, jurors, witnesses, court personnel, or other lawyers on any basis, including, but not limited to, on account of race, ethnicity, gender, religion, national origin, disability, marital status, sexual orientation, age, socioeconomic status, employment, or physical characteristic.]. COUNT III RESPONDENT S FAILURE TO PRODUCE AND MAINTAIN THE REQUIRED TRUST ACCOUNTING DOCUMENTS 39. A Subpoena was served upon Respondent on November 17, 2017 by The Florida Bar, requiring the production of trust accounting records, which include the bank records, for the compliance audit period of January 1, 2017 through October 31, In response to the Subpoena, Respondent produced some, but not all, of the required documents. 41. Respondent failed to produce the following required trust accounting records in violation of Rule Regulating Fla. Bar 5-1.2: A. Cash receipts and disbursements journal. 13

14 B. Client ledgers. C. Monthly bank reconciliations. D. Monthly comparisons. 42. By the conduct set forth above, Respondent violated Rules Regulating Florida Bar: [The standards of professional conduct to be observed by members of the Bar are not limited to the observance of rules and avoidance of prohibited acts, and the enumeration herein of certain categories of misconduct as constituting grounds for discipline shall not be deemed to be all-inclusive nor shall the failure to specify any particular act of misconduct be construed as tolerance thereof. The commission by a lawyer of any act that is unlawful or contrary to honesty and justice, whether the act is committed in the course of the attorney's relations as an attorney or otherwise, whether committed within or outside the state of Florida, and whether or not the act is a felony or misdemeanor, may constitute a cause for discipline.]; [A lawyer shall comply with The Florida Bar Rules Regulating Trust Accounts.]; 4-8.4(a) [A lawyer shall not violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another.]; 5-1.2(b)(6) [The following are the minimum trust accounting records that must be maintained: a separate cash receipts and disbursements journal, including columns for receipts, disbursements, transfers, and the account balance, and containing at least: (A) the identification of 14

15 the client or matter for which the funds were received, disbursed, or transferred; (B) the date on which all trust funds were received, disbursed, or transferred; (C) the check number for all disbursements; and (D) the reason for which all trust funds were received, disbursed, or transferred.]; 5-1.2(b)(7) [The following are the minimum trust accounting records that must be maintained: a separate file or ledger with an individual card or page for each client or matter, showing all individual receipts, disbursements, or transfers and any unexpended balance, and containing: (A) the identification of the client or matter for which trust funds were received, disbursed, or transferred; (B) the date on which all trust funds were received, disbursed, or transferred; (C) the check number for all disbursements; and (D) the reason for which all trust funds were received, disbursed, or transferred.]; 5-1.2(d)(1)(A) [The minimum trust accounting procedures that must be followed by all members of The Florida Bar (when a choice of laws analysis indicates that the laws of Florida apply) who receive or disburse trust money or property are as follows: (1) The lawyer is required to make monthly: (A) reconciliations of all trust bank or savings and loan association accounts, disclosing the balance per bank, deposits in transit, outstanding checks identified by date and check number, and any other items necessary to reconcile the balance per bank with the balance per the checkbook and the cash receipts and disbursements journal]; and 5-1.2(d)(1)(B) [The minimum trust accounting 15

16 procedures that must be followed by all members of The Florida Bar (when a choice of laws analysis indicates that the laws of Florida apply) who receive or disburse trust money or property are as follows: (1) The lawyer is required to make monthly: (B) a comparison between the total of the reconciled balances of all trust accounts and the total of the trust ledger cards or pages, together with specific descriptions of any differences between the 2 totals and reasons for these differences.]. COUNT IV RESPONDENT S MISREPRESENTATION TO THE FLORIDA BAR AND FAILURE TO ABIDE BY THE OCTOBER 24, 2017 COURT ORDER 43. On December 11, 2017, the Bar sent Respondent a letter requesting proof that he remitted the $34, to Crawford in accordance with the October 24, 2017 Bankruptcy Order. (See Exhibit 1 of TFB's Composite Exhibit C). 44. On December 22, 2017, Respondent sent the Bar an attaching a letter in response to the Bar's request for proof of payment stating, in part: Pursuant to the Court's Order, this amount was to be paid back to Crawford within sixty (60) days of the date of the Order, or as otherwise agreed to by the parties. As the Order was entered October 24, 2017, the payment is due to Crawford in or before December 23, 2017, or as otherwise agreed by the parties. Currently, I am not in the position to make a lump sum payment to Ms. Crawford, but have engaged her counsel in negotiations for repayment of the amount to Ms. Crawford. (emphasis supplied.) (See Respondent's December 22, 16

17 2017 and attached letter, attached hereto and incorporated herein as Exhibit 2 of TFB's Composite Exhibit C). 45. On December 26, 2017, Crawford's counsel filed a motion in the Bankruptcy Court case, titled "MOTION FOR CONTEMPT; TO IMPOSE SUPPLEMENTAL SANCTIONS, TO ENTER JUDGEMENT AND TO COMPEL PRODUCTION." (hereinafter referred to as the "Motion for Contempt," attached hereto and incorporated herein as Exhibit 3 of TFB's Composite Exhibit C). 46. In the Motion for Contempt, Julianne Frank, Crawford's Counsel states, in part, The court ordered that the remittances described above shall be made on or before the 60th day from the date of the order (December 23, 2017) unless Ms. Crawford otherwise agreed. On the 23rd day of December, 2017, Mr. Elam contacted the undersigned requesting a payment plan. Ms. Crawford declined. (emphasis supplied) (See Exhibit 3 of TFB's Composite Exhibit C). 47. When Respondent sent the December 22, 2017 letter to the Bar, Respondent had not engaged Crawford's counsel in negotiations. 48. Respondent did not engage Crawford's counsel until December 23, 2017, when his request for a payment plan was declined. 49. Respondent's December 22, 2017 statement that he had engaged Crawford's counsel in negotiations was a misrepresentation to the Bar. 17

18 50. Further, once Respondent was advised that a payment plan was rejected on December 23, 2017, Respondent failed to advise The Florida Bar that there were in fact no pending negotiations. 51. Respondent failed to remit the $34,400.00, in accordance with the October 24, 2017 Order. 52. Wherefore, by reason of the foregoing, Respondent has violated the following Rules Regulating The Florida Bar: [Violation of the Rules of Professional Conduct as adopted by the rules governing The Florida Bar is a cause for discipline.]; [The standards of professional conduct to be observed by members of the Bar are not limited to the observance of rules and avoidance of prohibited acts, and the enumeration herein of certain categories of misconduct as constituting grounds for discipline shall not be deemed to be all-inclusive nor shall the failure to specify any particular act of misconduct be construed as tolerance thereof. The commission by a lawyer of any act that is unlawful or contrary to honesty and justice, whether the act is committed in the course of the attorney's relations as an attorney or otherwise, whether committed within or outside the state of Florida, and whether or not the act is a felony or misdemeanor, may constitute a cause for discipline.]; 4-3.4(c) [A lawyer must not knowingly disobey an obligation under the rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists.]; 4-8.1(a) [An applicant for admission to 18

19 the bar, or a lawyer in connection with a bar admission application or in connection with a disciplinary matter, shall not knowingly make a false statement of material fact.]; 4-8.4(a) [A lawyer shall not violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another.]; 4-8.4(c) [A lawyer shall not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, except that it shall not be professional misconduct for a lawyer for a criminal law enforcement agency or regulatory agency to advise others about or to supervise another in an undercover investigation, unless prohibited by law or rule, and it shall not be professional misconduct for a lawyer employed in a capacity other than as a lawyer by a criminal law enforcement agency or regulatory agency to participate in an undercover investigation, unless prohibited by law or rule.]; and 4-8.4(d) [A lawyer shall not engage in conduct in connection with the practice of law that is prejudicial to the administration of justice, including to knowingly, or through callous indifference, disparage, humiliate, or discriminate against litigants, jurors, witnesses, court personnel, or other lawyers on any basis, including, but not limited to, on account of race, ethnicity, gender, religion, national origin, disability, marital status, sexual orientation, age, socioeconomic status, employment, or physical characteristic.]. 19

20 WHEREFORE, based on the aforementioned facts, the Bar asserts the Respondent has caused, or is likely to cause, immediate and serious harm to clients and/or the public and that immediate action must be taken for the protection of the Respondent's clients and the public. Therefore, pursuant to R. Regulating Fla. Bar 3-5.2, The Florida Bar respectfully requests this court to: A. Suspend Respondent from the practice of law until further order of this Court. B. Order Respondent to accept no new clients from the date of this Court's order and to cease representing any clients after 30 days from the date of this Court's order. In addition, Respondent shall cease acting as personal representative for any estate, as guardian for any ward, and as trustee for any trust and will seek to withdraw from said representation within thirty days from the date of this Court s order and will immediately turn over to any successor the complete financial records of any estate, guardianship or trust upon the successor s appointment. C. Order Respondent to furnish a copy of the suspension order to all clients, opposing counsel and courts before which Brett A. Elam is counsel of record as required by Rule 3-5.1(h) of the Rules of Discipline of The Florida Bar and to furnish Staff Counsel with the requisite affidavit 20

21 listing all clients, opposing counsel and courts so informed within 30 days after receipt of the Court's order. D. Order Respondent to refrain from withdrawing or disbursing any money from any trust account related to Respondent's law practice until further order of this Court, a judicial referee appointed by this Court or by order of the Circuit Court in an inventory attorney proceeding instituted under R. Regulating Fla. Bar 1-3.8, and to deposit any fees, or other sums received in connection with the practice of law or in connection with the Respondent s employment as a personal representative, guardian or trustee, paid to the Respondent after issuance of this Court's order of emergency suspension, into a specified trust account from which withdrawal may only be made in accordance with restrictions imposed by this Court. Further, Respondent shall be required to notify Bar Counsel of The Florida Bar of the receipt and location of said funds within 30 days of the order of emergency suspension. E. Order Respondent to not withdraw any money from any trust account or other financial institution account related to Respondent's law practice or transfer any ownership of any real or personal property purchased in whole or in part with funds properly belonging to clients, probate estates for which Respondent served as personal representative, guardianship estates 21

22 for which Respondent served as guardian, and trusts for which Respondent served as trustee without approval of this Court, a judicial referee appointed by this Court or by order of the Circuit Court in an inventory attorney proceeding instituted under R. Regulating Fla. Bar F. Order Respondent to notify, in writing, all banks and financial institutions where the Respondent maintains an account related to the practice of law, or related to services rendered as a personal representative of an estate, or related to services rendered as a guardian, or related to services rendered as a trustee, or where Respondent maintains an account that contains funds that originated from a probate estate for which Respondent was personal representative, guardianship estate for which Respondent was guardian, or trust for which Respondent was trustee, of the provisions of this Court's order and to provide all the aforementioned banks and financial institutions with a copy of this Court's order. Further, Respondent shall be required to provide Bar Counsel with an affidavit listing each bank or financial institution Respondent provided with a copy of said order. G. Order Respondent to immediately comply with and provide all documents and testimony responsive to a subpoena from The Florida Bar for trust account records and any related documents necessary for completion of a trust account audit to be conducted by The Florida Bar. 22

23 H. And further to authorize any referee appointed in these proceedings to determine entitlement to funds in any trust account(s) frozen as a result of an order entered in this matter. Respectfully submitted, Linda Ivelisse Gonzalez Bar Counsel The Florida Bar Ft. Lauderdale Branch Office Lake Shore Plaza II 1300 Concord Terrace, Suite 130 Sunrise, Florida (954) Florida Bar No LGonzalez@floridabar.org Adria E. Quintela Staff Counsel The Florida Bar Lakeshore Plaza II, Suite Concord Terrace Sunrise, Florida (954) Florida Bar No aquintel@flabar.org 23

24 /s/ Joshua E. Doyle Joshua E. Doyle Executive Director The Florida Bar 651 East Jefferson Street Tallahassee, Florida (850) Florida Bar No CERTIFICATE OF SERVICE I certify that this Petition For Emergency Suspension has been E-filed with The Honorable John A. Tomasino, Clerk of the Supreme Court of Florida, with a copy provided via to Douglas Crane Broeker, Respondent's Counsel, at doug@broekerlaw.com, using the E-filing Portal and that a copy has been furnished by United States Mail via certified mail No , return receipt requested to Douglas Crane Broeker, Respondent s Counsel, whose record bar address is Sweetapple, Broeker & Varkas, PL, 44 W. Flagler St., Suite 1500, Miami, FL , and via to Linda Ivelisse Gonzalez, Bar Counsel, lgonzalez@flabar.org and dmacha@flabar.org, on this 2nd day of February, Adria E. Quintela Staff Counsel The Florida Bar Lakeshore Plaza II, Suite Concord Terrace Sunrise, Florida (954) Florida Bar No aquintel@flabar.org 24

25 NOTICE OF DESIGNATION OF PRIMARY ADDRESS PLEASE TAKE NOTICE that Bar Counsel in this matter is Linda Ivelisse Gonzalez, Bar Counsel, whose address, telephone number and primary and secondary address are The Florida Bar, Ft. Lauderdale Branch Office, Lake Shore Plaza II, 1300 Concord Terrace, Suite 130, Sunrise, Florida 33323, (954) , and Respondent need not address pleadings, correspondence, etc. in this matter to anyone other than bar counsel and to Adria E. Quintela, Staff Counsel, The Florida Bar, Lakeshore Plaza II, Suite 130, 1300 Concord Terrace, Sunrise, Florida 33323, 25

26 MANDATORY ANSWER NOTICE RULE 3-5.2(a), RULES OF DISCIPLINE, EFFECTIVE JULY 1, 2012, 2004, PROVIDES THAT A RESPONDENT SHALL ANSWER A COMPLAINT. 26

27 AFFIDAVIT STATE OF FLORIDA ) ) S.S. COUNTY OF BROW ARD ) Before me, the undersigned authority, this day personally appeared Carl Totaro, who being duly sworn stated: Qualifications of Auditor 1. My name is Carl Totaro. I am a Certified Public Accountant, licensed in the State of Florida since I have two bachelor degrees, one in accounting and the other in business administration. I have worked in public accounting as an external auditor, and in indust1y as an internal auditor. I have held various accounting positions at private companies. I am a member of the American Institute of Certified Public Accountants and the Florida Institute of Certified Public Accountants. I am employed by The Florida Bar as Chief Auditor to perform compliance audits of attomey trnst account records. My job duties consist primarily of compliance examinations of trust account records pertaining to members of The Florida Bar. The examinations determine whether or not such records are in compliance with the trnst accounting requirements under the Rules Regulating The Florida Bar. This examination of records focuses on the financial transactions relating to the subject matters noted in Court Orders. I have been employed by The Florida Bar since December I have been qualified as an expert on 21 occasions for trust accounting matters before a referee. Scope of Compliance Audit 2. A compliance audit for the Respondent named Brett A. Elam was performed on the trust account records of the above-named attorney for the period of January 1, 2017 through October 31, This case was assigned to me on November 2, The compliance audit consists of an examination of the trust account by verification of the accounting records and supporting documents to determine whether or not the records and procedures complied with Chapter 5 of the Rules Regulating The Florida Bar. The primary focus of this compliance audit was the examination of the financial transactions relating to the subject matters noted in Corui Orders. The compliance audit relates to the following Florida Bar file number: ,326(15C). The trust bank account I examined was as follows: a) The Law Offices of Brett A. Elam Trust Account number ending with #7647 at Seacoast National Bank. Scope of Review The Florida Bar's Composite Exhibit A

28 3. I also reviewed the following bank accounts, for the period of January 1, 2017 through October 31, 2017, as follows: a) The Law Offices of Brett A. Elam P.A. Operating Account number ending with #7654 at Seacoast National Bank. b) "Brett A. Elam Lauren Elam" Account number ending with number #1630 at Seacoast National Bank. c) I have not performed a compliance audit of the reviewed accounts, as they were not attorney trust account(s). I have not perfonned a financial statement audit of the Law Offices of Brett A. Elam P.A. and/or the Law Offices of Brett A. Elam P.A. Law Firm Operating Account, or other bank accounts reviewed. Summary of Court Orders and Docket Entries 4. Copies of the Comi Orders are attached to this affidavit and identified as Composite Exhibit 1. a) Court Order dated October 24, In re: Kim C. Crawford, Debtor. Case No BKC-PGH Chapter 7. Order on the order to show cause why Brett Elam, Esq. should not be suspended from Bankruptcy Practice (ECF No. 347) and the Bank of New York Mellon's Amended Motion for Sanctions against Brett Elam Esq. (ECF No. 337). The Court Order stated the following in pertinent part: 1) The Court Order stated, "This matter came before the Court for hearing on September 19, 2017, upon the Order to Show Cause why Attorney Brett Elam should not be suspended from practicing before the Bankruptcy Court for making false Statements regarding financial information relating to the Debtor in Possession Funds and any related sanctions (the "Order to Show Cause") (ECF No. 347) and the Amended Motion for Sanctions (ECF No. 337) filed by The Bank ofnew York Mellon (as Trustee for the Ce1iificate Holders of CWALT, Inc. Alternative Loan Trust , Mortgage Pass -Through Certificate Series ) and Bayview Servicing, LLC (collectively, the "Creditor")." (Exhibit 1, pages 1-2). 2) The Court Order stated, "For the reasons that follow, the Comi orders that: (1) the Debtor's counsel, Brett Elam, Esq., ("Mr. Elam") shall pay $8, to the Creditor as sanctions within 30 days of the date of entry ofthis Order; (2) Mr. Elam shall pay $34,400 to the Debtor as sanctions within sixty days of the date of entry ofthis Order; (3) to the extent that the Debtor paid Mr. Elam any of the $14,350 in attorney's fees awarded in this case, Mr. Elam is to return any such payments-unless already accounted for by the aforementioned $34,400 paymentto the Debtor within sixty days of the date of entry of this Order; ( 4) this matter will be referred to the Florida Bar to investigate whether fmiher proceedings against Mr. Elam may be necessary as a result of this Order... " (Exhibit 1, page 2). 2

29 3) The Cami Order stated, "On April 17, 2017, the Debtor filed a Monthly Operating Report for the period beginning March 1, 2017, and ending March 31, 2017 (the "March 2017 MOR") (ECF No. 293), reflecting a $34,400 check paid out of the Debtor's Debtor-in-Possession account (the "DIP Account") on March 2, 2017, to "Brett Elam" as "Payee" and fisting "Attorney's Fees" as the "Purpose or Description" ofthe $34,400 check... " (Exhibit 1, page 5). 4) The Court Order stated, "Regarding the $34,400 check, Mr. Elam responded to the Creditor's attorney's inquiry that the "[Debtor] wrote it to me and it is held in trust. I had it for the confomation hearing. It hasn't been disbursed. I just had it in anticipation of confirmation. I am still holding it." Id. at Ex. A (April 18, 2017, sent at 8:47 A.M.). The Creditor's attorney responded to the foregoing asking Mr. Elam what evidence he could provide to show that the $34,400 still remained in his trust account for the Debtor (the "Trust Account") and further asking Mr. Elam ifhe had a copy of the check. Id. (April 18, 2017, sent at 9:25 A.M.). Mr. Elam responded that he did have a copy of the check and that the "funds [were] there," to which the Creditor's attorney responded asking Mr. Elam to send proof ofthis and to return the funds to the DIP Account. Id. (April 18, 2017, s sent at 10:03 A.M. and 10:07 A.M.)..." (Exhibit 1, page 6). 5) The Court Order stated, "On April 21, 2017, the Creditor filed the Filing in Fmiher Support of Motion to Dismiss Case, wherein the Creditor asserted that: The main purpose for this filing is to bring to the Court's attention that the Debtor's March 2017 MOR reflects that on March 2, 2017, check number 256 in the sum of$34,400 cleared the Debtor's DIP account at TD Bank, and it reflected as having been paid to "Brett Elam" for "Attorneys Fees." Moreover, the Debtor's cash position in her MOR was reflected as having been reduced by the $34,400. But the Cami did not award attorney's fees to Brett Elam at the March 15, 2017 confirmation [hearing]... " (Exhibit 1, page 7). 6) The Cami Order stated, "On May 9, 2017, at 11:34 A.M. -less than two and a half hours before the 1:00 P.M. hearing on the Creditor's First Motion for Sanctions - the Debtor filed an Amended Monthly Operating Report for the Period from March 1, 2017, to March 31, 2017 (the "Amended March 2017 MOR") (ECF No. 296), specifying that $34,400 in legal fees was "being held in" the Trust Account "pending approval" of the Debtor's plan. See Am. March 2017 MOR, at 8. Specifically, Mr. Elam asserted that: In anticipation of confirmation hearing March 15, 2017, the [Debtor] tendered a check for Admin fees to counsel. These funds were deposited into counsel's trust account. As the Court failed to confirm the Plan, those fees were not approved. The fees are in counsel's trust acconnt pending approval from the Cami." (Exhibit 1, pages 7-8). 3

30 7) The Court Order stated, "The Creditor asserted that the pertinent Trust Account statements which Mr. Elam ultimately ed the Creditor on July 11, 2017, showed that on March 2, 2017, the $34,400 was deposited from the DIP Account into the Trust Account, increasing the Trust Account balance to $39, See Am. Mot. For Sanctions, Ex. A, 6 ( sent at 9:29 PM on July 11, 2017). The Creditor asserted that sometime between March 2, 2017 and March 31, 2017, the Trust Account balance dropped from $39, to $30,458.34, and the account records that Mr. Elam provided to the Creditor made no indication of where this roughly $8,950 disbnrsement went. Id. at 7. The Creditor also asserted that on April 28, 2017, the Trust Account balance had dropped to roughly $22,520 (i.e., another disbnrsement of roughly $8,000). Id. However, on May 11, two days after the Court heard the Creditor's Motion to Compel Sanctions for Failure to Comply with Comi Order and ordered Mr. Elam to prove that the $34,400 in question was always in the Trust Account - the Trust Account's balance was back up to $34, Id. at 8." (Exhibit 1, page 12). 8) The Comi Order stated, "At the September 19, 2017, Show Cause Hearing on the Amended Motion for Sanctions and the Order to Show Cause, the Comi asked Mr. Elam why he should not be suspended from practice for lying to the Comi and misappropriating funds from the Trust Account. Mr. Elam responded that if he told the comi the DIP Funds were "always" in the Trust Account, then that was "inconect" and he "apologize[d]." See Show Cause Hr'g, at 9:34 A.M. Mr. Elam further stated that he took the DIP Funds out of the Trust Account "in an emergency situation and they were put back." Id. Mr. Elam testified that "the funds were there, and [his] wife had snrgery, and [he] needed to use the funds to live for a bit and when [they] got the funds, [they] put them back." Id. at 11:01 A.M. (emphasis added). Mr. Elam also testified that he could not recall on what exactly he spent the DIP Funds and that he had no communication with the Debtor regarding his withdrawal of the DIP Funds from the Trust Account." (Exhibit 1, page 13-14). 9) The Court Order stated, "At the conclusion of the Show Cause Hearing, the Conrt directed Mr. Elam to produce complete Trust Account records by September 22, On September 22, 2017, Mr. Elam filed complete Trust Account records, reflecting the $34,400 deposit into the Trust Account on March 2, 2017, and eighteen separate withdrawals-ranging from $250 to $6,200-made from the Trust Account between March 2, 2017, and May 11, See ECF No. 356." (Exhibit 1, page 15). 10) The Court Order stated, "The Court finds that Mr. Elam committed professional misconduct warranting sanctions by misappropriating his client's Trust Account funds for personal use, in clear violation of the Rules Regulating the Florida Bar... " (Exhibit 1, page 18). 4

31 11) The Court Order stated, "Fmiher, the Comi finds that Mr. Elam made false representations to the Comi by listing "Attorney's Fees" as the "Purpose or Description" of the $34,400 check at issue in the Debtor's March 2017 MOR, because Mr. Elam admitted that he used the $34,400 disbursement for personal living expenses." (Exhibit 1, pages 18-19). b) Court Order dated October 24, In re: Kim C. Crawford, Debtor. Case No BKC-PGH Chapter 7. Final Judgment. The Comi Order stated the following in pertinent paii: 1) The Court Order stated, "Mr. Elam is to pay $34,400 to the Debtor, representing the amount that he transferred from the DIP Account into the Trust Account on March 2, 2017, as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 60 days of entry ofthis Order, absent agreement ofthe Debtor to a different time period." (Exhibit 1, page 32). c) Comi Order dated December 1, In re: Kim C. Crawford, Debtor. Case No BKC-PGH Chapter 7. Order Denying Motion to Stay Pending Appeal. (Exhibit 1, pages 35-37). 5. I printed selected docket entries relating to the Kim C. Crawford, Debtor. Case No BKC-PGH Chapter 7 bankruptcy matter. Copies ofthose relevant docket entry documents are attached to this affidavit and identified as Composite Exhibit 2. Those documents stated the following in pertinent part: a) correspondence was attached to Bony's Filing in Further Support of its Motion to Dismiss Case, docket entry ) In an dated April 18, 2017 from Gary M. Freedman to Brett A. Elam, Mr. Freedman stated, "I was just flipping through Crawford's March MOR and noticed that check number 256 in the SU111 of $34,400 written on her DIP account was paid to you or your firm on March 2, " (Exhibit 2, page 14). 2) In an dated April 18, 2017 from Brett A. Elam to Gary M. Freedman, Mr. Elam stated, "Gary she wrote it to me and it is held in trust. I had it for the confirmation hearing. It hasn't been disbursed. I just had it in anticipation of confirmation. I am still holding it." (Exhibit 2, page 14). 3) In an dated April 18, 2017 from Brett A. Elam to Gary M. Freedman, Mr. Elam stated, "In every case I have ever been in Gary, the fees are held in trust until the order is entered. I mean really, this is what we are going to argue about. The funds are there and the reason they weren't given back is the same reason your client wojties about it, I don't want them dissipated." (Exhibit 2, page 13). b) Within the Debtor's Amended Monthly Operating Repmi (Individual) for the period from March 1, 2017 to March 31, 2017, dated April 16, 2017, docket entry 296, the following was stated, "In anticipation of confomation hearing March 15, 2017, the D 5

32 tendered a check for admin fees to counsel. These funds were deposited into com1sel's trust account. As the Court failed to confirm the plan, those fees were not approved. The fees are in counsel's trust account pending approval from the Comi." (Exhibit 2, page 22). c) Transaction history for Seacoast Bank account number ending with number was attached to Notice of Filing dated September 22, 2017, docket entry 356. I noted the following: 1) The bank balance in account #7647 was $26,000 on April 7, (Exhibit 2, page 47). 2) The bank balance in account #7647 was $25,000 on April 20, (Exhibit 2, 1 page 47). d) Auditor Note: It appears that Mr. Elam's statement to Mr. Freedman on April 18, 2017 representing that the $34,400 was still in the trust accou11t is inconsistent with the bank balance in his trust account on April 18, Mr. Elam's trust accou11t records show a balance of $26,000 as of April 18, The evidence is clear and convincing that the $34,400 was not maintained in the trust account. Summary of Responses, Additional Correspondence and Other Findings 6. Brett A. Elam provided multiple responses and documents to The Florida Bar's inquiry relating to this matter. Copies of the relevant response and documents are attached to this affidavit and identified as Composite Exhibit 3. Mr. Elam stated the following in pe1iinent pmi: a) Respondent stated, "The $34,400 check, to which the Comi referred and about which you inquired, was written, signed, m1d tendered to me by Crawford. The check was for attorney's fees earned during my Firm's representation of Crawford in her Chapter 11 bankruptcy. Upon receipt of the funds, I deposited them into my trust account awaiting Bankruptcy Comi approval. However, based upon the time records enclosed with my response as Exhibit "A", it is clear the attorney fees had been earned. Moreover, based upon my Bankruptcy Engagement Letter, a copy of which is also enclosed as Exhibit "B", the fees were earned upon receipt. As such, it was, and always has been, my understanding receiving payment for post-petition attorney's fees prior to obtaining Bankrnptcy Comi approval is not an ethical violation ofthe Rules Regulating the Florida Bar. Had I known then the repercussions of accepting payment prior to obtaining Bankruptcy Court Approval, I would not have utilized the fees... " (Exhibit 3, page 1 ). b) Respondent stated, "In closing, it is my position, or understanding of the Rules Regulating the Florida Bar, that the findings by the Bankrnptcy Court that funds were improperly disbursed from the Debtor's Debtor-in-Possession account, only relate to a potential violating of a Bankruptcy Rule. Based upon the work performed in this bankruptcy case, as well as the language in my Bankruptcy Engagement Letter, the 6

33 attorney fees paid by the Debtor to my firm had been earned. As such, it is my understanding it is not an ethical violation, or a violation of the Rule Regulating the Florida Bar. Ifthis is an incorrect assumption or an incorrect assessment of the Rules Regulating the Florida Bar, my actions were not intentional, nor did I intentionally take actions that I believed were a violation of any law... " (Exhibit 3, pages 4-5). c) Respondent stated, "I am in receipt of your December 22, 2017, correspondence related to the Complaint filed by The Florida Bar as a result of the Order entered in the Bankmptcy Court. In your correspondence, you request a copy ofthe front and back of the check in the amount of $34,400, for payment to Kim Crawford. Pursuant to the Court's Order, this amount was to be paid back to Crawford within sixty (60) days of the date ofthe Order, or as othetwise agreed by the parties. As the Order was entered October 24, 2017, the payment is due to Crawford on or before December 23, 2017, or as otherwise agreed by the parties. Currently, I am not in the position to make a lump sum payment to Ms. Crawford, but have engaged her counsel in negotiations for repayment of the amount owed to Ms. Crawford... " (Exhibit 3, page 44). 7. To fully investigate this matter, the required minimum trust account records and procedures were subpoenaed from Mr. Elam, and the trust records from the Seacoast National Bank were subpoenaed. 8. A subpoena was served upon Seacoast National Bank on November 17, 2017, requiring production of bank account records for the compliance audit period identified above. A copy of the bank subpoena is attached to this affidavit and identified as Exhibit 4. The records provided by the bank subpoena were received on December 20, Thereafter, a subpoena was served upon Mr. Elam on November 17, 2017, requiring production of trust account records and other related records for the compliance audit period identified above. A copy of the subpoena is attached to this affidavit and identified as Exhibit 5. The subpoenaed records were due by December 17, 2017, the thitiieth day following service of the subpoena. 10. In response to the subpoena, on December 7, 2017, the Respondent provided a portion, but not all, of the required records and procedures. Copies of the documents provided by Respondent, on December 7, 2017, in response to the subpoena are attached to this affidavit and identified as Composite Exhibit 6. Mr. Elam stated the following in pertinent part: a) Mr. Elam stated, "I have produced the following documents: 1. Copies of the online bank statements for my Seacoast National Bank, Trust Account, Account# from January 1, 2017, through October 31, 2017; 2. Copies of all the checks, which were either deposited or debited from the Trust Account; 3. Copies ofthe ledger I keep for the Trust Account; and 4. Copies of all deposit slips I have for the Trust Account." (Exhibit 6, page 2). 7

34 b) Mr. Elam stated, "In addition, the subpoena requested other categories of documents, which I will explain below. Pursuant to paragraph 1, I have produced a copy ofthe Order Allowing Interim Fees, which was entered by the Bankruptcy Court March 27, As for the documents requested in paragraph 2 of the subpoena, there are no documents in existence. Additionally, pursuant to paragraph 3, I have provided copies ofthe bank statements above, which reflect the disbursements from the Trust Account. Other than documents I have provided, there are no fnrther documents responsive." (Exhibit 6, page 2). c) Mr. Elam stated, "Currently, there is only (1) client, which has fonds deposited into my trust account. This client is Melvin Casanas, and I have enclosed a copy ofthe settlement statements for the matter, in which he is involved..." (Exhibit 6, page 3). 11. The documents that were provided by the Respondent on December 7, 2017, included copies ofthe following: a) A letter to Carl Totaro dated December 7, (Exhibit 6, pages 2-3). b) Bankruptcy Court docket entry #64 documents dated March 27, 2015 relating to the Kim C. Crawford matter. (Exhibit 6, pages 4-5). c) Copies of online bank statements for Seacoast National Bank trust account #7647 for the period of January 1, 2017 through October 31, (Exhibit 6, pages 7-12). d) Cancelled checks for trust account #7647. (Exhibit 6, pages 16, 20, 34-39). e) Copy ofa check Respondent received from Miguel A. Larrieu trust. (Exhibit 6, page 15). f) Copies of checks Respondent received from Chandra Parker Doucette for the Casanas matter. (Exhibit 6, pages 19, 27-33). g) Copy of a check Respondent received from Kidz Exploration Center for Early Development Inc. (Exhibit 6, page 40). h) Copies ofseacoast Bank deposit approved notifications for trust account # (Exhibit 6, pages 23-26). 12. Prior to the subpoena being served upon Mr. Elam, the following records were provided by the Respondent that relate to the subpoena request: a) Time records relating to the Kim C. Crawford matter provided with the Respondent's response dated November 6, (Exhibit 3, pages 6-21). b) Engagement letter agreement for bankruptcy and bankruptcy related legal services 8

35 and representation for the Kirn C. Crawford matter provided with the Respondent's response dated November 6, (Exhibit 3, pages 22-25). 13. As ofthe date ofthis compliance audit report, Mr. Elam failed to produce some ofthe requested records and procedures for the tmst account, despite the issuance ofthe subpoena. The following Chapter 5 Rule trust account records and procedures were not provided by Mr. Elam for the period from January 1, 2017 through October 31, 2017: a) Cash receipts and disbursements journal, Rule 5-1.2(b)(6). The rule states: "A separate cash receipts and disbursements journal, including columns for receipts, disbursements, transfers, and the account balance, and containing at least: (A) the identification ofthe client or matter for which funds were received, disbursed, or transferred; (B) the date on which all trust funds were received, disbursed, or transferred; (C) the check number for all disbursements; and (D) the reason for which all trust funds were received, disbursed, or transferred." A cash receipts and disbursements journal is a chronological record of all activity going into and out of the trust bank account for all matters. A journal would contain a running account balance for all matters within the trust account. These are records compiled by Respondent and cannot be obtained from the bank. b) Client ledgers (active and closed), Rule 5-1.2(b)(7). The rule states: "A separate file or ledger with an individual card or page for each client or matter, showing all individual receipts, disbursements, or transfers and any unexpended balance, and containing: (A) the identification ofthe client or matter for which trust funds were received, disbursed, or transferred; (B) the date on which all trust funds were received, disbursed, or transferred; (C) the check number for all disbursements; and (D) the reason for which all trust funds were received, disbursed, or transferred." A ledger is an accounting document that details every monetary transaction(s) on behalf ofa client or matter, and shows the balance owed or unexpended balance for a specific client or matter. These are records compiled by Respondent and cannot be obtained from the bank. c) Monthly bank reconciliations. The rule states: "Reconciliations of all trust bank or savings and loan association accounts, disclosing the balance per bank, deposits in transit, outstanding checks identified by date and check number, and any other items necessary to reconcile the balance per bank with the balance per checkbook and the cash receipts and disbursements journal." Rule 5-1.2( d)(l)(a). These are procedures to be performed by Respondent and cannot be obtained from the bank. The Respondent did not provide a document for each respective month reflecting that a bank reconciliation ofthe trust account was performed by the Respondent, or perfmmed by someone on behalf ofthe Respondent under the Respondent's superv1s1on. d) Monthly comparisons. The rule states: "A comparison between the total ofthe reconciled balances of all trust accounts and the total of the trust ledger cards or 9

36 pages, together with specific descriptions of any differences between the 2 totals and reasons for the differences." Rule 5-1.2(d)(l)(B). These are procedures to be performed by Respondent and cannot be obtained from the bank. The Respondent did not provide a document for each respective month reflecting that a monthly comparison ofthe trust account was perfmmed by the Respondent, or perfo1med by someone on behalf ofthe Respondent under the Respondent's supervision. 14. The subpoena served upon Mr. Elam also requested the following: a) Paragraph 1) "Provide the date(s), amount(s) and copies of documents substantiating the Bankruptcy Court's approval of attorney fees and costs you received, prior to March 2, 2017, relating to the Kim C. Crawford matter." (Exhibit 5, page 1). In response to this request, on December 7, 2017 Mr. Elam provided a copy ofthe Bankruptcy Court Order allowing interim fees to Brett A. Elam P.A. Attorneys for Debtor-In-Possession in the amount of$14,350. (Exhibit 6, pages 4-5). b) Paragraph 2) "All documentary suppmi substantiating the Bankruptcy Court's approval as of March 2, 2017 or anytime thereafter, for earned attorney fees and costs in the amount of $34,400 that you received from Kim C. Crawford that was deposited into the trust account on March " (Exhibit 5, page 2). In response to this request, on December 7, 2017 Mr. Elam stated, "As for the documents requested in paragraph 2 ofthe subpoena, there are no documents in existence... " (Exhibit 6, page 2). 15. On December 7, 2017, The Florida Bar received a written copy ofthe September 19, 2017 tt anscripts relating to Re: Case No BKC-PGH Kim C. Crawford, Debtor. ECF #349. A copy of those tt anscripts is attached to this affidavit and identified as Exhibit 7. The transcript stated the following in pertinent part: a) The Court stated, "Mr. Elam, we're here on an order to show cause why you should not be suspended from the practice of bankruptcy law, based on two things. Number one, lying to the Court, and two, misappropriating funds from the trust account for Ms. Crawford." (Exhibit 7, page 4, lines 8-13). b) Mr. Elam was asked by the Court: "What about the misappropriation, taking the funds out ofthe trust account?" Mr. Elam answered: "Your Honor, that was in an emergency situation, and they were put back, and--" (Exhibit 7, page 5, lines 2-5). c) Mr. Elam was asked by the Co mi: "Can you tell me where in the ethical rules there's any provision that says, I can take a client's funds out oftrust account based on an emergency?" Mr. Elam answered: "No. There is none." (Exhibit 7, page 5, lines 6 10). d) The Comi stated: "Go ahead." Mr. Elam (the witness) answered: "Your Honor, first, the funds were there, and my wife had surgery, and I needed to use the funds to live for a bit, and when we got the funds we put them back." (Exhibit 7, page 44, lines 1 10

37 5). 16. Bank signature cards were obtained for account numbers ending with numbers #7647, #7654 and #1630 at Seacoast National Bank. Those signature cards substantiate that Brett A. Elam was the authorized signer of account numbers #7647 and #7654. Brett A. Elam and Lauren Elam were the authorized signers of account # Copies of those signature cards, provided by the bank subpoena compliance, are attached to this affidavit and identified as Composite Exhibit An accounting of all the transactions that occutted in Trust Account #7647 at Seacoast National Bank during the period of January 1, 2017 through October 31, 2017 (including the related bank statements, bank deposit slips, deposited items and cancelled checks), provided by the bank subpoena compliance, are attached to this affidavit and identified as Composite Exhibit The bank balance in Trust Account #7647 was $8.28 as of December 31, (Exhibit 9, page 1). 19. Thereafter, the bank balance in Trust Account #7647 was $5, as of February 28, (Exhibit 9, page 4). The next transaction within the tiust account was on March 2, A check from Kim Clarke Crawford in the amount of$34,400 was deposited into Trust Account #7647 for "attorney's fees." (Exhibit 9, pages 4 and 20). 20. The bank balance in Trust Account #7647 was $34, as of March 7, $34,400 of that $34, related to the Kim C. Crawford matter. (Exhibit 9, page 4). 21. The bank balance in Trust Account #7647 was $30, as of March 31, (Exhibit 9, page 4). 22. The bank balance in Trust Account #7647 was $22, as of April 30, (Exhibit 9, page 7). The evidence substantiates that Mr. Elam utilized as least $11, (34,400-22,519.58) of funds relating to the Kim C. Crawford matter as of April 30, On May 11, 2017, a $5,000 cash deposit was made into Trust Account #7647. (Exhibit 9, pages 8 and 19). The source of those funds for that deposit is unknown to me as of the date of this affidavit. The bank balance in Trust Account #7647 was $29, after that $5,000 deposit. (Exhibit 9, page 8). The next transaction within the ti ust account was also on May 11, A "Internet Transfer" from Operating account #7654 to Trust Account #7647 in the amount of$4,180. (Exhibit 9, page 8). The bank balance in trust account #7647 was $34, after that $4,180 deposit. (Exhibit 9, page 8). a) Those deposit transactions reflect Mr. Elam's efforts to replenish the frmds relating to the Kim C. Crawford matter into the trust account. b) Even though Mr. Elam made deposits into the trust accounts on May 11, 2017 to 11

38 replenish funds relating to the Kim C. Crawford matter, Mr. Elam continued making additional "Internet Transfers" from Trust Account #7647 to Operating Account #7654 on May 11, 2017 utilizing Ms. Crawford's funds, despite him telling the Bankruptcy Court he put the funds back. Those "Internet Transfer" transactions will be discussed in detail within this affidavit. 24. The bank balance in TrustAccount#7647 was $6, as of May 31, (Exhibit 9, page 8). 25. The bank balance in Trust Account #7647 was $3, as of June 30, (Exhibit 9, page 11). 26. The bank balance in Trust account #764 7 was $3, as of July 31, (Exhibit 9, page 13). 27. The bank balance in Trust Account #7647 was $2, as of August 31, (Exhibit 9, page 14). 28. During the period of March 20, 2017 through August 3, 2017, twenty-seven (27) transfers totaling $54, were made from Trust Account #7647 to Operating Account #7654 as follows: a) On March 20, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$4,000. (Exhibit 9, page 4). b) On March 20, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$400. (Exhibit 9, page 4). c) On March 20, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $300. (Exhibit 9, page 4). d) On March 20, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $250. (Exhibit 9, page 4). e) On March 28, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$499 relating to fee for Casanas. (Exhibit 9, page 4). f) On April 3, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $3,000. (Exhibit 9, page 7). g) On April 7, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1, (Exhibit 9, page 7). h) On April 20, 2017, a "Internet Transfer" from Trust Account #7647 to Operating 12

39 Account #7654 in the amount of$1,000. (Exhibit 9, page 7). i) On April 20, 2017, a "Internet Transfer" from Tmst Account #7647 to Operating Account #7654 in the amount of $500. (Exhibit 9, page 7). j) On April 25, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1,400. (Exhibit 9, page 7). k) On April 25, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1, (Exhibit 9, page 7). 1) On April 25, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1,000. (Exhibit 9, page 7). m) On May 4, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $2,000. (Exhibit 9, page 8). n) On May 8, 2017, a "Internet Transfer" from Tmst Account #7647 to Operating Account #7654 in the amount of$3,000. (Exhibit 9, page 8). o) On May 8, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1,200. (Exhibit 9, page 8). p) On May 11, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $6,200. (Exhibit 9, page 8). q) On May 11, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $2,000. (Exhibit 9, page 8). r) On May 16, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$4,100. (Exhibit 9, page 9). s) On May 18, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$11,500. (Exhibit 9, page 9). t) On May 22, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$2,500. (Exhibit 9, page 9). u) On June 19, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $1,500. (Exhibit 9, page 11 ). v) On June 19, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1,000. (Exhibit 9, page 11). 13

40 w) On June 22, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$ (Exhibit 9, page 11). x) On June 26, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $300. (Exhibit 9, page 11). y) On July 7, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of $100. (Exhibit 9, page 13). z) On August 2, 2017, a "Internet Transfer" from Trust Account #7647 to Operating Account #7654 in the amount of$1,000. (Exhibit 9, page 14). aa) On August 3, 2017, a "Internet Transfer" from Trust Accmmt #7647 to Operating Account #7654 in the amount of $2,399. (Exhibit 9, page 14). 29. $34,400 of those 27 transfers totaling $54, from Trust Account #7647 to Operating Account #7654 were funds that should not have been disbursed from the trust account. Mr. Elam misappropriated $34,400 of funds relating to the Kim C. Crawford (Debtor) matter for his personal benefit not by maintaining those funds in the trust account until approval to disburse those funds was received from the Bankruptcy Court. Mr. Elam has not applied money ($34,400) entrusted to an attorney for a specific purpose. The Respondent needed the bankruptcy court's approval to disburse those fees to himself. By not having approval from the bankruptcy court, Respondent was in violation of Rule 5 1.l(b). The Respondent had no right to utilize those funds for his personal benefit. Those funds were not his to use. 30. The bank balance in Trust Account #7647 was $2, as of October 31, (Exhibit 9, page 17). That balance reflects funds on deposit for the Casanas matter as follows: a) On September 15, 2017, a check from Chandra Parker Doucette in the amount of $1, was deposited into trust account #7647 for "August Casanas." (Exhibit 9, pages 16 and 19). b) On October 13, 2017, a check from Chandra Parker Doucette in the amount of $1, was deposited into trust account #7647 for "Sept dish-casanas." (Exhibit 9, pages 17 and 24). 31. The bank balance in Operating Account #7654 was $7, as of October 31, A copy of the related bank statement, provided by the bank subpoena compliance, is attached to this affidavit and identified as Exhibit The bank balance in Personal Account #1630 was $ as of October 31, A copy of the related bank statement, provided by the bank subpoena compliance, is attached to this affidavit and identified as Exhibit

41 Opinion of Auditor 33. Based upon the finding ofmisappropriation (relating to Rule 5-1.l(b)) reflected in this affidavit, the facts described indicate the Respondent represents great public hrum contemplated by Rule The emergency suspension should be effected forthwith. This action is necessary in order to ale1t the public to the danger ofentrusting money with the Respondent. 34. I may find it appropriate to revise or supplement my opinions, analysis, and conclusions stated herein in the future if other information is subsequently discovered. FURTHER AFFIANT SAYETH NAUGHT. The foregoing instrument was sworn to and subscribed before me this 4 -+liday of January 2018 by Carl Totaro, who is personally known to me and who did take an oath. CARLTARO ~tf-v P111,,. HOLLY CARULLO "'~~ MYCOMMISSION#GG , * *.. ~ ~"" EXPIRES:November 5, f;-~off~o~ Bonded l1vu Budget Nolary SeMct. 15

42 EXHIBIT 1

43 RECEIVEI) OCT THE FLORIDA llar - A C\I' TALLAHASSEE,.FL0l{i0 1., ORDERED in the Southern District of Florida a on October 24, Paul G. Hyma, r., J dge United States Bankruptcy Court UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION In re: Kim C. Crawford, Case No.: BKC-PGH Chapter 7 Debtor. I ORDER ON THE ORDER TO SHOW CAUSE WHY BRETT ELAM, ESQ. SHOULD NOT BE SUSPENDED FROM BANKRUPTCY PRACTICE (ECF NO. 347) AND THE BANK OF NEW YORK MELLON'S AMENDED MOTION FOR SANCTIONS AGAINST BRETT ELAM. ESQ. (ECF NO. 337) THIS MATTER came before the Court for hearing on September 19, 2017, upon the Order to Show Cause Why Attorney Brett Elam Should Not Be Suspended 1 ' From Practicing Before the Bankruptcy Court for Making False Statements Regarding Financial Information Relating to the Debtor in Possession Funds and Any Related 1 ca/"/posite E..X/118/T j_

44 Sanctions (the "Order to Show Cause") (ECF No. 347) and the Amended Motion For Sanctions (ECF No. 337) Jiled by The Bank of New York Mellon (as Trustee for the Certificate Holders of CWALT, Inc. Alternative Loan Trust , Mortgage Pass- Through Certificates Series ) and Bayview Loan Servicing, LLC (collectively, the "Creditor"). For the reasons that follow, the Court orders that: (1) the Debtor's counsel, Brett Elam, Esq., ("Mr. Elam") shall pay $8, to the Creditor as sanctions within thirty days of the date of entry ofthis Order; (2) Mr. Elam shall pay $34, to the Debtor as sanctions within sixty days of the date of entry of this Order; (3) to the extent that the Debtor paid Mr. Elam any ofthe $14, inattorney's fees awarded in this case, Mr. Elam is to return any such payments-unless already accounted for by the aforementioned $34, payment-to the Debtor within sixty days of the date of entry of this Order; (4) this matter will be referred to the Florida Bar to investigate whether further proceedings against Mr. Elam may be necessary as a result of this Order; and (5) Mr. Elam shall be suspended from practice in the Bankruptcy Court for the Southern District of Florida for the longer of: (a) one year from the date of entry of this Order or (b) upon conclusion of the investigation by the Florida Bar and satisfaction ofthe required payments to the Creditor and the Debtor. PROCEDURAL BACKGROUND AND FINDINGS OF FACT On August 22, 2014, the Debtor filed her Voluntary Petition (ECF No. 1) under chapter 11 of the United States Bankruptcy Code. On November 4, 2014, the Court issued an Order Granting Application to Employ Brett A. Elam as Attorney for Debtor I

45 (ECF No. 36). On September 25, 2015, the Debtor filed a Disclosure Statement (ECF No. 104) and Chapter 11 Plan of Reorganization (ECF No. 105). On November 16, 2015, the Court issued an Order Setting Hearing to Consider Approval ofdisclosure Statement and Setting Deadline for Filing Objections to Disclosure Statement (ECF! No. 116), setting the disclosure hearing for December 22, On December 15, 2015, the Creditor filed an Objection to Disclosure Statement and Plan of Reorganization (the "Objection to Confirmation'') (ECF No. 120), arguing, in pertinent part, that the Debto1's Chapter 11 plan failed to provide adequate information to determine the feasibility of.the plan. See Obj. to Confirmation, if 10. On December 28, 2015, the Debtor filed a First Amended Disclosure Statement (ECF No. 127) and a First Amended Chapter 11 Plan ofreorganization (ECF No. 128). On April 20, 2016, the Creditor filed an Objection to Amended Disclosure Statement and Amended Plan of Reorganization (the "Second Objection to Confirmation'') (ECF No. 152), again arguing, in pertinent part, that the Amended Chapter 11 Plan failed to provide adequate information to determine the feasibility 0 the plan. See Second Obj. to Confirmation, if 11. On September 19, 2016, the Debtor filed a Second Amended Chapter 11 Plan (ECF No. 180) and a Third Amended Chapter 11 Plan (ECF No. 181), and on October 31, 2016, the Debtor filed a Fourth Amended Chapter 11 Plan (ECF No. 197). On January 13, 2017, the Creditor filed an Objection to Confirmation ofdebtor's Fourth Amended Plan of Reorganization and Motion to Dismiss Case or, in the Alternative,

46 Motion for Stay Relief (ECF Nos. 226, 232).1 See also Chapter 11 Ballot Rejecting Plan (ECF No. 227); Suppl. to Obj. to Confirmation of Fourth Am. Plan (ECF No. 252). On January 26, 2017, the Creditor conducted a Rule 2004 Examination of the Debtor. See Notice ofrule 2004 Examination Duces Tecum (the "Deposition Notice") (ECF No. 225). On February 6, 2017, the Creditor filed a Motion to Compel Debtor's Production of Documents (the "First Motion to Compel") (ECF No. 249), arguing that the Debtor failed to produce most ofthe documents requested in the Deposition Notice prior to her deposition, ifat all-such as all documents relating to the Debtor's assets and financial affairs and any documents on which the Debtor intends to rely at her confirmation hearing. See First Mot. to Compel, at 1-3. Following a hearing on the First Motion to Compel on February 15, 2017, the Court entered an Order Granting Motion to Compel Production of Documents (ECF No. 253), ordering the Debtor to deliver to the Creditor "all documents in Debtor's possession, custody or control responsive to [the Creditor's] Notice of Rule 2004 Examination Duces Tecum of Debtor [ECF 225], or which relate to Debtor's assets and the value thereof." On February 23, 2017, the Creditor filed a Motion to Compel Sanctions for Failure to Comply with Court Order (the "First Motion for Sanctions") (ECF No. 256), citing the "vast number of requested documents" which Mr. Elam still had not produced as required by the Order Granting Motion to Compel Production of Documents and, 1 The same pleading appears at two separate docket entries (ECF Nos. 226, 232) because an objection to confirmation and a motion to dismiss must be coded as separate docket events

47 accordingly, requesting that the Court grant the First Motion for Sanctions, deny con rmation 0 the Debtor's Chapter 11 Plan, and grant the Creditor's Motion to Dismiss the case. Id. at 2, 4. On March 15, 2017, the Court held a hearing on the First Motion for Sanctions and the Objection to Con rmation 0 Debtor's Fourth Amended Plan 0 Reorganization and Motion to Dismiss Case or, in the Alternative, Motion for Stay Relief. Thereafter, on March 27, 2017, the Court entered an Order Granting Motion for Stay Relief. (ECF No. 282), ordering that the Motion for Stay Relie would not become effective until April 14, 2017, and deferring ruling on the Motion to Dismiss to April 14, On April 4, 2017, the Court entered an Order Denying Confirmation of. Debtors Fourth Amended Plan of. Reorganization and Setting Status Conference (ECF No. 287), scheduling a status conference for May 9, The First Motion for Sanctions was also continued for hearing to May 9, See ECF No On April 17, 2017, the Debtor filed a Monthly Operating Report for the Period Beginning March 1, 2017, and Ending March 31, 2017 (the "March2017MOR") (ECF No. 293), reflecting a $34, check paid out of, the Debtor's Debtor-in-Possession account (the "DIP Account")2 on March 2, 2017, to "Brett Elam" as "Payee" and fisting "Attorney's Fees" as the "Purpose or Description" o the $34, check. See March 2017 MOR, 10, 17. On April 18, 2017, the Creditor's attorney ed Mr. Elam "for an explanation as to this [$34,400.00] payment. See Filing in Further Swpport of. Motion to Dismiss Case (ECF No. 294), '1l 7, Ex. A (April 18, 2017, sent at 8:38 2 TD Bank account number

48 A.M.). Regarding the $34, check, Mr. Elam responded to the Creditor's attorney's inquiry that the "[Debtor] wrote it to me and it is held in trust. I had it for the confirmation hearing. It hasn't been disbursed. I just had it in anticipation ofconfirmation. I am still holding it." Id. at Ex. A (April 18, 2017, sent at 8:47 A.M.). The Creditor's attorney responded to the fmegoing asking Mr. Elam what evidence he could provide to show that the $34, still remained in his trust account for the Debtor (the "Trust Account")3 and further asking Mr. Elam ifhe had a copy ofthe check. Id. (April 18, 2017, sent at 9:25 A.M.). Mr. Elam responded that he did have a copy of the check and that the "funds [were] there," to which the Creditor's attorney responded asking Mr. Elam to send proofofthis and to return the i funds to the DIP Account. Id. (April 18, 2017, s sent at 10:03 AM and 10:07 A.M.). Mr. Elam responded that he would send what the Creditor's attorney requested "in the morning." Id. (April 18, 2017, sent at 5:56 P.M.). The following afternoon, on April 19, 2017, the Creditor's attorney ed Mr. Elam asking why he still had not provided evidence "that the $34,400 [was], and always [had] been, in" the Trust Account, adding that Mr. Elam's "unfulfilled promises to do so [was] causing [the Creditor's attorney] to think that the situation [was] not as [Mr. Elam] claimed it to be." Id. (April 19, 2017, sent at 4:09 P.M.). Mr. Elam responded that ifhe told the Creditor's attorney that he "would send [him] something... which [he didn't] i ecall doing or seeing, then [he would]," but that he was currently "trying 3 Seacoast Bank account ending in See Trust Account Records (ECF No. 356, filed September 22, 2017) i

49 to get caught up" after having been out of the office to spend time with his family. Id. (April 19, 2017, sent at 4:41 P.M.). The Creditor's attorney responded that he would "proceed accordingly" and that these exchanges would serve as the Creditor's "good faith effort to resolve this issue withoutcourt intervention." Id. (April 19, 2017, sent at 5:00 P.M.). In the Filing in Further Support of Motion to Dismiss Case, the Creditor noted that as of the time of filing, Mr. Elam still had not provided "proof that the subject funds [had] been held in his trust account." See Filing in Further Supp. of Mot. to Dismiss Case, at if 10. On April 21, 2017, the Creditor filed the Filing in Further Support of Motion to Dismiss Case, wherein the Creditor asserted that: The main purpose for this filing is to bring to the Court's attention that the Debtor's March 2017 MOR reflects that on March 2, 2017, check number 256 in the sum of $34,400 cleared the Debtor's DIP account at TD Bank, and is reflected as having been paid to "Brett Elam" for "Attorneys Fees." Moreover, the Debtor's cash position in her MOR was reflected as having been reduced by the $34, But the Court did not award attorney's fees to Brett Elam at the March 15, 2017 confirmation [hearing]... See Filing in Further Supp. of Mot. to Dismiss Case, if 6; March 2017 MOR, 10, 17. However, the Order Allowing Interim Fees to Brett A. Elam, HA. (ECF No. 64) was not entered until twenty eight days after Mr. Elam allegedly accepted the $34, check for "Attorney's Fees." On May 9, 2017, at 11:34 A.M.-less than two and a half hours before the 1:00 P.M. hearing on the Creditor's First Motion for Sanctions-the Debtor filed an Amended Monthly Operating Report for the Period from March 1, 2017, to March 31,

50 2017 (the "Amended March 2017 MOR") (ECF No. 296), specifying that $34, in legal fees was "being held in" the Trust Account "pending approval" of the Debtor's plan. See Am. March 2017 MOR, at 8. Specifically, Mr. Elam asserted that: In anticipation of confirmation hearing March 15, 2017, the [Debtor] tendered a check for Admin fees to counsel. These funds were deposited into counsel's trust account. As the Court failed to confirm the Plan, those fees were not approved. The fees are in counsel's trust account pending approval from the Court. Id. at 2. On May 9, 2017, at 1:00 P.M., the Court conducted the status conference hearing and considered the Creditor's Motion to Compel Sanctions for Failure to Comply with Court Order. At the May 9, 2017, hearing, the Creditor acknowledged that Mr. Elam amended the March 2017 Monthly Operating Report to show that the $34, was is in the Trust Account, but still had not proved that this money was always in the Trust Account. See May 9, 2017, Hr'g, at 1:28 P.M. Mr. Elam responded that the $34, was "put in [his] trust account based on a pending confirmation hearing" and "would be available to pay down... whatever [he] needed to do." Id. at 1:32P.M. On May 16, 2017, the Court entered an Order on Status Conference (ECF No. 299), which in pertinent part: (1) denied without prejudice the C1 editor's Motion to Dismiss and ordered that ifthe Debtor cannot confirm a reorganization plan by July 28, 2017, the Court would grant the Creditor's Motion to Dismiss; and (2) ordered Mr. Elam to provide the Creditor with a true and correct copy of his redacted Trust Account statement(s) reflecting that the sum of $34, paid out of the DIP Account on March 2, 2017, had always been maintained in the Trust Account. On

51 May 16, 2017, the Court also entered an Order Granting Motion to Compel Sanctions for Failure to Comply with Court Order (ECF No. 300), granting the First Motion for Sanctions only to the extent that the Debtor would be "precluded from relying upon or seeking to introduce into evidence in any proceeding in this matter any documents that existed and which were not previously produced" prior to May 9, 2017, and imposing other discovery requirements on Mr. Elam with regards to expert reports and witnesses. On May 19, 2017, the Debtor filed a Motion for Extension ofi Time to Comply with Court Order and Produce Expert Reports (ECF No. 302), requesting a seven day extension "to produce all financial documents, including the expert reports upon which she would rely at the contested confirmation hearing scheduled on any new Chapter 11 Plan of Reorganization." See Mot. for Extension of Time, 5. On May 22, ' 2017, the Creditor filed a (I) Response to Debtor-in-Possession's Motion for Extension ofi Time to Comply with Court Order and Produce Expert Reports and (II) Motion to Compel Production ofi Trust Account Documents (the "Response and Motion to Compel Production'') (ECF No. 305), stating that while the Creditor had no objection to the specific extension requested, the Extension Motion continued "to advance the same plan concept already rejected by this Court." See Resp. and Mot. to Compel Produc., 'lf'll 2-3. In addition, the Creditor alleged in the Motion to Compel Production portion of the filing, that the Debtor was in violation of the Court's Order on Status Conference insofar as Mr. Elam still had not provided "any proof that the $34,400 always resided in his trust account," as required by the Order on Status Conference,

52 and requested that the Court compel Mr. Elam "to demonstrate that the $34,400 always resided in his trust account." Id. at if 3, 6 (emphasis added). On June 12, 2017, the Court entered an Order Granting Motion to Compel Production ofi Trust Account Documents (ECF No. 313), ordering Mr. Elam to provide the Creditor with "true and correct copies of his firm's trust account records for March through May 2017, reflecting the DIP Account maintained in the [Trust Account]." On June 19, 2017, the Creditor filed a Motion for Order to Show Cause Why Debtor's Counsel Brett Elam Should Not Be Held in Contempt and for Sanctions (the "Motion for Order to Show Cause") (ECF No. 318), citing Mr. Elam's "continuing failure to provide trust account records reflecting what he did with the $34,400 paid out ofthe Debtor's DIP account on March 2, "Mot. for Order to Show Cause, 1. In the Motion for Order to Show Cause, the Creditor asserted that Mr. Elam failed to comply with two separate court orders regarding production of the pertinent Trust Account records: (1) the Order on Status Conference; and (2) the Order Granting Motion to Compel Production oftrust Account Documents. Id. at if 5. Accordingly, the Creditor requested that the Court enter an order requiring Mr. Elam "to show cause why he should not be held in civil contempt ofcourt for willfully violating the Order on Status Conference and Trust Account Order," and awarding the Creditor "reasonable attorneys' fees and costs incurred in obtaining the trust account records against Mr. Elam." Id. at 4. On June 27, 2017, the Debtor filed a Motion to Vacate Order Granting Motion to Compel Production ofitrust Account Documents (ECF No. 322). On July 11, 2017,

53 the Court held a hearing on the Motion for Order to Show Cause and on the Motion to Vacate Order Granting Motion to Compel Production o Trust Account Documents. On July 14, 2017, the Court entered an Order Denying Debtor-in-Possession's Motion to Vacate Order Granting Motion to Compel Production of. Trust Account Documents (ECF No. 328) and an Order Dismissing Case with Prejudice (ECF No. 330) "as a result 0 it becoming obvious that the Debtor would be unable to conform a Plan 0 Reorganizatioll'' and the Debtor's resultant consent "to the immediate dismissal 0 her bankruptcy case." Order Dismissing Case with Prejudice, 1-2. The Court also denied the Motion for Order to Show Cause without prejudice. On July 19, 2017, the Creditor filed an Amended4 Motion for Sanctions (the "Amended Motion for Sanctions'') (ECF No. 337) requesting, "pursuant to 11 U.S.C. 105(a)," that the Court require Mr. Elam "to reimburse [the Creditor] for the reasonable attorney's fees it has incurred with respect to the improper disbursement of, the DIP Funds" and "to return the DIP Funds to the Debtor." See Am. Mot. for Sanctions, 1, 3. OnAugust29, 2017, the Court held a hearing on the Amended Motion for Sanctions, which, notably, Mr. Elam did not attend. At the hearing on the Amended Motion for Sanctions, the Creditor's attorney explained that he noticed $34, missing from the DIP Account upon review 0 the Debtor's March 2017 MOR. See March 2017 MOR, 10 (showing a $34, checks paid out o the DIP on March 2, 2017). The Creditor's attorney detailed his many efforts to get Mr. Elam to 4 The Creditor initially filed a Motion for Sanctions (ECF No. 332) on July 18, However, on July 19, 2017, the Creditor filed the Amended Motion for Sanctions, amended only "to include redacted exhibits." See Am. Mot. for Sanctions, 1 n

54 explain what happened to the $34,400.00, which Mr. Elam had previously asserted was being held for the purposes of confirmation and were never dispersed from the Trust Account, and attached s between the Creditor's attorney and Mr. Elam regarding the Creditor's ongoing attempts to get Mr. Elam to produce complete Trust Account records. See Am. Mot. for Sanctions, Exs. A-D. The Creditor asserted that the pertinent Trust Account statements which Mr. Elam ultimately ed the Creditor on July 11, 2017, showed that on March 2, 2017, the $34, was deposited from the DIP Account into the Trust Account, increasing the Trust Account balance to $39, See Am. Mot. for Sanctions, Ex. A, 6 ( sent at 9:29 PM on July 11, 2017). The Creditor asserted that sometime between March 2, 2017 and March 31, 2017, the Trust Account balance dropped from $39, to $30,458.34, and the account records that Mr. Elam provided to the Creditor made no indication of where this roughly $8, disbursement went. Id. at 7. The Creditor also asserted that on April 28, 2017, the Trust Account balance dropped to roughly5 $22, (i.e., another disbursement of roughly $8,000.00). Id. However, on May 11, 2017-two days after the Court heard the Creditor's Motion to Compel Sanctions for Failure to Comply with Court Order and ordered Mr. Elam to prove that the $34,400.00in question was always in the TrustAccount-the Trust Account's balance. was back up to $34, Id. at 8. On September 1, 2017, the Court entered the Order to Show Cause, ordering Mr. Elam to appear for an evidentiary hearing to show cause (the "Show Cause 5 The amount of cents is not visible on the bank statement

55 Hearing") as to why he should not be suspended from practicing before the Bankruptcy Court, in addition to other sanctions requested by the Amended Motion for Sanctions, for: (a) making false statements regarding financial information relating to the Debtor-in-Possession funds (the "DIP Funds"); and (b) making improper disbursements ofthe DIP Funds from the Trust Account. The Court further directed Mr. Elam to produce at the Show Cause Hearing any and all Trust Account statements and related records reflecting the receipt and disbursement 0 the DIP Funds from March 2017 to the present, including the recipient of the disbursements, adding that the Court would determine at the Show Cause Hearing the amount of reasonable attorney's fees and costs that Mr. Elam would pay to the Creditor regarding the Creditor's discovery efforts relating to the DIP Funds. At the September 19, 2017, Show Cause Hearing on the Amended Motion for Sanctions and the Order to Show Cause, the Court asked Mr. Elam why he should not be suspended from practice for lying to the Court and misappropriating funds from the Trust Account. Mr. Elam responded that ifhe told the court the DIP Funds were "always" in the Trust Account, then that was "incorrect" and he "apologize[d]." See Show Cause Hr'g, at 9:34 A.M. Mr. Elam further stated that he took the DIP Funds out 0 the Trust Account "in an emergency situation and they were put back." Id. Mr. Elam testified that "the funds were there, and [his] wife had surgery, and [he] needed to use the funds to live for a bit and when [they] got the funds, [they] put them back." Id. at 11:01 A.M (emphasis added). Mr. Elam also testified that he could not recall on what exactly he spent the DIP Funds and that he

56 had no communication with the Debtor regarding his withdrawal of the DIP Funds from the Trust Account. Finally, at the Show Cause Hearing, the Creditor's attorney testified regarding the attorney's fees and costs that the Creditor incurred in trying to get Mr. Elam to produce the pertinent Trust Account and DIP Funds evidence. See Ex. F ("Fee Statements," reflecting 43.9 hours of work billed at $15, $14, in attorney's fees and $1, in costs-eontaining both redacted and unredacted time entries). The Creditor's attorney added that the time entries in the Fee Statements end on September 13, 2017, making them non-inclusive of the time he spent preparing for the Show Cause Hearing, which he explained necessitated 5 hours of work at $ per hour, totaling $1, in additional attorney's fees that he was seeking as sanctions-bringing the total amount of requested sanctions to $17,259.01for48.9 hours of work. The Creditor's attorney represented at the Show Cause Hearing that the unredacted charges in the Fee Statements represent time spent on the Trust Account and DIP Funds discovery issues (i.e., not on other issues in the case). The Creditor's attorney explained that he did not include in the total amount requested as sanctions any of the redacted time entries. However, the Creditor's attorney admitted that various unredacted time entries reflected work on the Trust Account and DIP Funds discovery issues in addition to another issue in the case in the same time entry, and 6 The Creditor's attorney testified that his standard rate is $ per hour but he charges the Creditor a reduced rate of $

57 that he discounted by fifty percent any such multi-pm'pose time entries. The Creditor's attorney testified that the unredacted time entries do not reflect the abovementioned discounts, but that the calculation of 43.9 hours does. Finally, Mr. Elam cross-examined the Creditor's attorney with regards to which specific time entries should be discounted and by how much, which the Court has incorporated into its determination of the reasonable amount of attorney's fees that Mr. Elam will be required to pay the Creditor as sanctions. At the conclusion of the Show Cause Hearing, the Com t directed Mr. Elam to produce complete Trust Account records by September 22, On September 22, 2017, Mr. Elam filed complete Trust Account records, reflecting the $34, deposit into the Trust Account on March 2, 2017, and eighteen separate withdrawals-ranging from $ to $6, made from the Trust Account between March 2, 2017, and May 11, See ECF No CONCLUSIONS OF LAW For the reasons that follow, the Court finds it appropriate to impose "both compensatory sanctions (monetary sanctions) and sanctions designed to coerce compliance (suspension)" on Mr. Elam pursuant to 11 U.S.C. 105, Local Rule (B)(l), and, alternatively, the Court's inherent power to sanction civil contempt. See Ginsberg u. Evergreen Sec.,,Ltd. (In re Evergreen Sec., Ltd.), 570 F.3d 1257, 1280 (11th Cir. 2009). Pursuant to 11 U.S.C. 105(a), bankruptcy courts "may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title," and take any action or make any determination "necessary or appropriate

58 to enforce or implement court orders or rules, or to prevent an abuse of process." The Eleventh Circuit has held that the language of. 105 encompasses the court's power to "award monetary and other forms of relief' and issue "any type of order, whether injunctive, compensative or punitive, as long as it is 'necessary or appropriate to carry out the provisions of the Bankruptcy Code."' Hardy v. U.S. (In re Hardy), 97 F.3d 1384, (11th Cir. 1996) (internal citation omitted); see also Franken v. Mukamal, 449 F. App'x 776, 778 (11th Cir. 2011) (affirming a sanctions award against an attorney who, in pertinent part, was "responsible for submitting false and misleading documents to the court"). Indeed, ''bankruptcy courts enjoy broad discretion under 105 to fashion their orders." Green Point Credit, LLC v. McLean (In re McLean), 794 F.3d 1313, 1325 (11th Cir. 2015); Chambers v. NASCO, Inc., 501 U.S. 32, 55 (1991) (noting that the appellate court reviews a court's imposition of sanctions only for abuse of discretion). A finding of bad faith is not required to impose sanctions under 105, which "grants statutory contempt powers in the bankruptcy context, distinct from the court's inherent contempt powers in bankruptcy proceedings." Hardy, 97 F.3d at (noting that while a party "may be cited for contempt under the court's inherent powers only upon a showing of 'bad faith,"' a party can be found "liable for contempt under 105 if it willfully violated" a court order (internal citation omitted)). Accordingly, the "focus" of a court's inquiry in a civil contempt proceeding brought pursuant to 105 "is not on the subjective beliefs or intent of the alleged

59 contemnors in complying with the order, but whether in fact their conduct complied with the order at issue." Hardy, 97 F.3d at In order to make an initial finding that a party was in contempt of a court order, the Court must find that the party seeking a civil contempt finding "prove[d] by clear and convincing evidence that the respondent violated a court order." U.S. u. Hayes, 722 F.2d 723, 725 (11th Cir. 1984); see also McLean, 794 F.3d at 1326 (noting that findings of civil contempt "must be based on clear and convincing evidence that a court order was violated"). Once the Court finds that civil contempt was proven by clear and convincing evidence, the.court may impose civil contempt sanctions pursuant to 105 "for either or both of two distinct purposes, to coerce compliance with a court order, and to compensate the complainant for actual losses sustained by him as the result ofthe defendants' contumacy." Granfinanciera, S.A. u. Nordberg (In re Chase & Sanborn Corp.), 872 F.2d 397, (11th Cir. 1989).7 Finally, courts may also impose sanctions for professional misconduct. Jn re Parker, 485 F. App'x 989, 991 (11th Cir. 2012) (reaffirming a bankruptcy court's order permanently disbarring an attorney from practice in the bankruptcy court pursuant to 11 U.S.C. 105 and the court's inherent powers where the attorney misappropriated client funds and made false statements in court filings). 7 The Eleventh Circuit has noted that the "requirements of due process in a civil contempt proceeding are flexible, varying with the circumstances of each case." Mercer v. Mitchell, 908 F.2d 763, 769 n.11 (11th Cir. 1990). However, "[a]t most, due process requires only 'skeletal' protections in civil contempt proceedirigs: a show-cause order providing notice and a hearing in which the alleged contemnor, who may be represented by counse~ can introduce evidence rebutting the allegation ofcontempt and testify on its own behalf." McLean,, 794 F.3d at 1324 (distinguishing this standard from the "more stringent" due process protection required for criminal contempt proceedings)

60 Here, the Court finds that Mr. Elam committed professional misconduct warranting sanctions by misappropriating his client's Trust Account funds for personal use, in clear violation of the Rules Regulating the Florida Bar, which provide, in pertinent part, that: A lawyer must hold in trust, separate from the lawyer's own property, funds and property of clients or third persons that are in a lawyer's possession in connection with a representation. Money or other property entrusted to an attorney for a specific purpose, including advances for fees, costs, and expenses, is held in trust and must be applied only to that purpose. Money and other property of clients coming into the hands of an attorney are not subject to counterclaim or setoff for attorney's fees, and a refusal to account for and deliver over such property upon demand shall be deemed a conversion. See R. Regulating Fla. Bar, Trust Accounts (emphasis added). As explained in the Procedural Background and Findings of Fact section above, Mr. Elam admitted at the Show Cause Hearing that he took the DIP Funds out of the Trust Account for his own personal use, stating that he "needed to use the funds to live for a bit." See Show Cause Hr'g, at 9:34 A.M, 11:01 A.M. Therefore, by using the Trust Account funds for personal living expenses, Mr. Elam committed professional misconduct by failing to keep the Trust Account funds "separate from [his] own property" and failing to apply the Trust Account funds "only to" the "specific purpose" for which the funds were being held. See R. Regulating Fla. Bar, 5 l. l(a b). Further, the Court finds that Mr. Elam made false representations to the Court by listing "Attorney's Fees" as the "Purpose or Description" of the $34, check at issue in the Debtor's March 2017 MOR, because Mr. Elam admitted that he used

61 the $34, disbursement for personal living expenses. Finally, the Court finds that the Creditor proved by clear and convincing evidence that Mi. Elam willfully violated two separate court orders regarding production of:the pertinent trust account records: (1) the Order on Status Conference (ECF No. 299), and (2) the Order Granting Creditor's Motion to Compel Production of: Trust Account Documents (ECF No. 313). As explained in the Procedural Background and Findings of: Fact section above, the Order on Status Conference required Mr. Elam to provide the Creditor with a true and correct copy of: his redacted Trust Account statement(s) reflecting that the $34, paid out of: the DIP Account on March 2, 2017, had always been maintained in the Trust Account. Due to Mr. Elam's continued failure to provide such documentation, the Court's subsequent Order Granting Motion to Compel Production of: Trust Account Documents directed Mr. Elam, once again, to provide the Creditor with the pertinent Trust Account documentation. However, Mr. Elam did not produce complete Trust Account records until September 22, 2017-more than four months after he was originally ordered to do so in the Order on Status Conference. See also Order Granting Motion to Compel Sanctions for Failure to Comply with Court Order (ECF No. 300). Accordingly, the Court may award civil contempt sanctions pursuant to 105(a) to the Creditor and to the Debtor to compensate them for actual losses they sustained as the result of: Mr. Elam's: (1) willful contempt of: Court; (2) professional misconduct; and (3) false representations made to the Court

62 I. Authority to Suspend an Attorney from P1 actice 'Before the Court Pursuant to Local Rule (B)(J) In addition to the Court's ability to suspend an attorney from practice pursuant to 11 U.S.C. 105(a), as explained above, the Court's Local Rules specifically provide that: Upon order to show cause entered by at least one judge, any attorney appearing before the court may, after 30 days' notice and hearing and for good cause shown, be suspended from practice before the court, reprimanded or otherwise disciplined, by a judge whose order to show cause initiated the disciplinary proceedings. Local Rule (B)(l). Having issued an Order to Show Cause and held a hearing on same, the Court finds that Mr. Elam has been provided with proper notice and appropriate proceedings in which to defend his conduct. The Court finds Mr. Elam's conduct-specifically, misappropriating his client's funds for his personal use, making false representations to the Court (i.e., writing "Attorney's Fees" on the March 2017 MOR as the purpose of the March 2, 2017, $34, disbursement which, as Mr. Elam eventually admitted, he used for personal living expenses), and willfully violating multiple court orders (i.e., the Order on Status Conference and the Order Granting Motion to Compel Production of Trust Account Documents)-to be inexcusable and warrants suspension from practice before the United States Bankruptcy Court for the Southern District of Florida and referral of the matter to 1 the Florida Bar Attorney Consumer Assistance Program (ACAP) to investigate whether further proceedings against Mr. Elam may be necessary. See generally The Florida Bar v. Mirk, 64 So. 3d 1180, 1185 (Fla. 2011) (approving the Florida Bar

63 referee's recommendation ofdisbarment where an attorney made "secret withdrawals from his client trust account without his client's knowledge or permission," noting that "attorney misconduct involving the misuse or misappropriation of client funds is unquestionably one of the most serious offenses a lawyer can commit" and that "disbarment is presumed the appropriate discipline when an attorney engages in this type of misconduct," with the presumption of disbarment being "exceptionally weighty when the attorney's misuse is intentional rather than a result of neglect or inadvertence"). II. The Court's Inherent Power to Impose Sanctions for Civil Contempt and to Suspend an Attorney from Practice Before the Court In addition to the statutory authority to impose sanctions for contempt discussed in the preceding sections, the Supreme Court ofthe United States has held that "[a]ll courts, whether established under Article I or Article III, have the inherent!jower to enforce compliance with their lawful orders by imposing sanctions for contempt." Chambers, 501 U.S. at 43 (noting that "the inherent power of a court can be invoked even if procedural rules exist which sanction the same conduct"). Moreover, a federal court has the "power to control admission to its bar and to discipline attorneys who appear before it" pursuant to its inherent powers. Id. Further, in "narrowly defined circumstances," federal courts have "inherent power to assess attorney's fees against counsel... even though the so-called 'American Rule' prohibits fee shifting in most cases." Id. at 45 (affirming the Fifth Circuit Court of Appeals' finding that the district court acted within its discretion in invoking its

64 inherent power to assess as a sanction for a party's bad-faith conduct attorney's fees and related expenses). Indeed, a court "may assess attorney's fees against the responsible party'' pursuant to its inherent powers where the court finds "that fraud has been practiced upon it, or that the very temple of justice has been defiled," or where a party "shows bad faith by delaying or disrupting the litigation or by hampering enforcement of a court order." Id. at 46. Accordingly, the Com t has the authority to suspend from practice and assess attorney's fees against Mr. Elam pursuant to its inherent powers because the Court finds, as detailed above, that Mr. Elam committed fraud upon the Court by making false representations to the Court (i.e., writing "Attorney's Fees" on the March 2017 MOR as the purpose of the pertinent $34, disbursement which, as Mr. Elam eventually admitted, he used at least in part for personal living expenses), willfully violating multiple court orders (i.e., the Order on Status Conference and the Order Granting Motion to Compel Production of Trust Account Documents), and misappropriating his client's funds for his own personal use. In making this finding, the Court is cognizant that the Supreme Court ofthe United States has advised that a court must "exercise caution in invoking its inherent power," noting that while a com t "may safely rely on its inherent power," where there is "bad-faith conduct in the course of litigation that could be adequately sanctioned under the Rules, [courts] ordinarily should rely on the Rules rather than the inherent power." Chambers, 501 U.S. at 50. Accordingly, the Court notes its ability to suspend Mr. Elam from practice before this Court as well as to award attorney's fees against Mr. Elam pursuant to its

65 inherent powers only as an alternative, as the Court finds that Mr. Elam's conduct is sanctionable under 11 U.S.C. 105 and Local Rule (B)(l). III. The Reasonableness of the Amount of Attorney's Fees and Costs Incurred by the Creditor as a Direct Result ofmr. Elam's Conduct As explained above, the Creditor's attorney testified at the Show Cause Hearing concerning the reasonableness and necessity of incurring the attorney's fees and costs reflected in the Fee Statements regarding discovery efforts related to the pertinent Trust Account and DIP Account records. Having reviewed the Fee Statements and in light of the nature, extent, and value ~f the Creditor's attorney's legal services and the Creditor's attorney's testimony as to which time entries should be discounted and by how much, the Court finds that $8, is a reasonable amount of sanctions to be awarded to the Creditor as attorney's fees that the Creditor incurred as a direct result ofmr. Elam's conduct. The Court concludes that $8, is a reasonable amount of sanctions to be awarded to the Creditor because this amount represents half of the 48.9 hours of work, at $ per hour, which the Creditor sought as sanctions. This reduction by halfis warranted by the fact that the Creditor's attorney admitted that many of the time entries on his Fee Statements represented work on matters other than the Trust Account and DIP Funds discovery issue. The Court finds $8, to be a reasonable amount of attorney's fees in terms of the nature, extent, and value of the services provided with regards to the Trust Account and DIP Funds discovery issues. The Court also finds that $8,

66 represents a reasonable amount oftime spent on and rates charged for such services by the Creditor, commensurate with the complexity, importance, and nature of the problem addressed. Finally, the Court finds that $8, ofthe legal costs and fees incurred by the Creditor as a direct result of Mr. Elam's conduct were reasonable based on the customary compensation charged by comparably skilled practitioners, were not unnecessary duplicative, and were reasonably necessary to adequately respond to Mr. Elam's continued failure to produce the pertinent Trust Account records as ordered by the Court on multiple occasions. IV. Attorney's Fees Awarded to Mr. Elam On March 30, 2015, the Court entered an Order Allowing Interim Fees to Brett Elam, P.A. (ECF No. 64), awardingbrett Elam, PA. $14, in attorney's fees and $0.00 in expenses on an interim basis. See Interim Application for Compensation (ECF No. 43) (requesting $14, in attorney's fees and $0.00 in expenses for the period of August 22, 2014, to February 4, 2015). An award on an interim basis is subject to later determination as to the amount and reasonableness of such fees after consideration of the factors enumerated in 11 U.S.C. 330(a)(3-4). On August 30, 2016, Mr. Elam filed an Amended Application for Final Compensation (ECF No. 175), requesting $34, in attorney's fees and $30.00 in expenses. See Application for Final Compensation (ECF No. 171) (requesting $20, in attorney's fees and $0.00 in expenses). The Court never entered an order on the Amended Application for Final Compensation

67 V. The Sanctioned Party's Ability to Pay the Contemplated Sanction The Eleventh Circuit has instructed that sanctions "must never be hollow gestures" but also "must not involve amounts that are so large that they seem to fly in the face of common sense, given the financial circumstances of the party being sanctioned." Martin u. Automobili Lamborghini Exclusive, Inc., 307 F.3d 1332, 1337 (11th Cir. 2002). Accordingly, a party may claim "inability to pay a sanction" as a defense to a contemplated sanction. U.S. u. Coulton, 594 F. App'x 563, 568 (11th Cir. 2014). However, inability to pay is treated as an affirmative defense, meaning that it is "waived if not asserted" and that the party who asserts inability to pay bears the burden of proof on that issue. Id. (explaining that the Court "need not explicitly, or even implicitly, evaluate a person's ability to pay a sanction unless that person asserts to the... court an inability to pay the sanction"); see also Sussman u. Salem, Saxon & Nielsen, P.A., 150 F.R.D. 209, 217 (M.D. Fla. 1993) (noting that inability to pay a sanction "should be regarded as akin to an affirmative defense with the burden placed upon the sanctioned parties to present financial status information"). Here, Mr. Elam did not assert an inability to pay a sanction-neither in his pleadings nor in court. Accordingly, the Court need not assess his ability to pay these sanctions. ORDER Accordingly, the Court, being fully advised in the premises and for the reasons discussed above, hereby ORDERS AND ADJUDGES that: 1. Mr. Elam is determined to have committed professional misconduct, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l),

68 and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustained by them as the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 2. Mr. Elam is determined to have willfully violated multiple court orders, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l), and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustained by them as the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 3. Mr. Elam is determined to have made false representations to the Court, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l), and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustained by them as the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 4. Pursuant to Local Rule (B)(l), 11 U.S.C. 105(a), and, in the alternative, the Court's inherent powers, Mr. Elam is SUSPENDED from practice before the United States Bankruptcy Court for the Southern District of Florida, effective thirty days from the date of entry of this Order, for the longer of: (1) one year from the date of entry of this Order; or (2) upon

69 conclusion of the investigation by the Florida Bar and satisfaction of the required payments provided below. 5. Mr. Elam shall file a Motion to Withdraw as Attorney of Record from all of his currently active cases case in the United States Bankruptcy Court for the Southern District of Florida within 30 days of entry of this Order. 6. Effective thirty days from the date of entry of this Order, Mr. Elam is hereby prohibited from filing any pleadings or other papers in this or any other bankruptcy case in the United States Bankruptcy Court for the Southern District offlorida-with the sole exception ofmotions to Withdraw as Attorney of Record in any currently active cases-without prior written Order of this Court granting him permission in each instance to file such pleading or paper for a period of one year or upon conclusion of the investigation by the Florida Bar and satisfaction of the required payments provided below-whichever is longer. 7. This matter is hereby referred to the Florida Bar Attorney Consumer Assistance Program (ACAP) to investigate whether further proceedings against Mr. Elam may be necessary as a result of this Order. 8. Mr. Elam is directed to pay $8, directly to the Creditor as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 30 days ofentry ofthis Order, absent agreement ofthe Creditor to a different time period

70 9. Mr. Elam is to pay $34, to the Debtor, representing the amount that he transferred from the DIP Account into the Trust Account on March 2, 2017, as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 60 days of entry of this Order, absent agreement of the Debtor to a different time period. 10. To the extent that the Debtor paid Mr. Elam any ofthe $14, in attorney's fees awarded, Mr. Elam is to return any such payments-unless already accounted for by the payment required in paragraph 9 above-to the Debtor as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 60 days of entry of this Order, absent agreement of the Debtor to a different time period. 11. The Court will issue a separate final judgment contemporaneously with this Order, Copies furnished to: Brett Elam, Esq. Gary Freedman, Esq. Kim C. Crawford, Debtor Heidi Feinman, Trustee! AUST The Florida Bar, Attn: ACAP Dept. 651 East Jefferson Street Tallahassee, FL ###

71 ORDERED in the Southern District of Florida a on October 24, Paul G. Hyma, r., J dge United States Bankruptcy Court UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION In re: Case No.: BKC-PGH Kim C. Crawford, Chapter 7 Debtor. ~~~~~~~~~~~~' FINAL JUDGMENT THIS MATTER came before the Court for hearing (the "Show Cause Hearing") on September 19, 2017, upon the Order to Show Cause Why Attorney Brett Elam Should Not Be Suspended From Practicing Before the Bankruptcy Court for Making False Statements Regarding Financial Information Relating to the Debtor in Possession Funds and Any Related Sanctions (the "Order to Show Cause") (ECF No. 347) and the Amended Motion For Sanctions (ECF No. 337) filed by The Bank o New York Mellon (as Trustee for the Certificate Holders 0 CW ALT, Inc. Alternative Loan

72 Trust , Mortgage Pass-Through Certificates Series ) and Bayview Loan Servicing, LLC (collectively, the "Creditor"). The Court has considered the evidence presented at the Show Cause Hearing, including the testimony of witnesses and the documentary and other evidence admitted, as well as the presentations of counsel, and applicable law. The Court is otherwise fully advised in the premises. In accordance with Federal Rule ofbankruptcyprocedure 7058, for the reasons stated on the record at the Show Cause Hearing and contained in the Order on the Order to Show Cause Why Brett Elam, Esq. Should Not be Suspended from Bankruptcy Practice (ECF No. 347) and the Bank of. New York Mellon's Amended Motion for Sanctions Against Brett Elam, Esq. (ECF No. 337), it is ORDERED AND ADJUDGED that: 1. Mr. Elam is determined to have committed professional misconduct, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l), and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustainedby them as the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 2. Mr. Elam is determined to have willfully violated multiple court orders, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l), and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustainedby them as

73 the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 3. Mr. Elam is determined to have made false representations to the Court, warranting sanctions pursuant to 11 U.S.C. 105(a), Local Rule (B)(l), and, in the alternative, pursuant to the Court's inherent powers, in order to compensate the Creditor and the Debtor for actual losses sustained by them as the result of Mr. Elam's conduct (i.e., attorney's fees and costs) as well as to coerce compliance (i.e., suspension). 4. Pursuant to Local Rule (B)(l), 11 U.S.C. 105(a), and, in the alternative, the Court's inherent powers, Mr. Elam is SUSPENDED from practice before the United States Bankruptcy Court for the Southern District of Florida, effective thirty days from the date of entry of this Order, for the longer of: (1) one year from the date of entry of this Order; or (2) upon conclusion of the investigation by the Florida Bar and satisfaction of the required payments provided below. 5. Mr. Elam shall file a Motion to Withdraw as Attorney of Record from all of his currently active cases case in the United States Bankruptcy Court for the Southern District of Florida within 30 days of entry of this Order. 6. Effective thirty days from the date of entry of this Order, Mr. Elam is hereby prohibited from filing any pleadings or other papers in this or any other bankruptcy case in the United States Bankruptcy Court for the Southern District offlorida-with the sole exception ofmotions to Withdraw as Attorney

74 of Record in any currently active cases-without prior written Order of this Court granting him permission in each instance to file such pleading or paper for a period of one year or upon conclusion of the investigation by the Florida Bar and satisfaction of the required payments provided below-whichever is longer. 7. This matter is hereby referred to the Florida Bar Attorney Consumer Assistance Program (ACAP) to investigate whether further proceedings against Mr. Elam may be necessary as a result of this Order. 8. Mr. Elam is directed to pay $8, directly to the Creditor as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 30 days ofentry ofthis Order, absent agreement ofthe Creditor to a different time period. 9. Mr. Elam is to pay $34, to the Debtor, representing the amount that he transferred from the DIP Account into the Trust Account on March 2, 2017, as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's inherent powers, within 60 days of entry of this Order, absent agreement of the Debtor to a different time period. 10. To the extent thatthe Debtor paid Mr. Elam any ofthe $14, in attorney's fees awarded, Mr. Elam is to return any such payments-unless already accounted for by the payment required in paragraph 9 above--to the Debtor as a sanction pursuant to 11 U.S.C. 105(a) and, in the alternative, the Court's

75 inherent powers, within 60 days of entry of this Order, absent agreement of the Debtor to a different time period. Copies furnished to: Brett Elam, Esq. Gary Freedman, Esq. Kim C. Crawfurd, Debtor Heidi Feinman, Trustee AUST The Florida Bar, Attn: ACAP Dept. 651 East Jefferson Street Tallahassee, FL

76 Totaro, Carl From: Sent: To: Subject: Attachments: Gonzalez, Linda Friday, December 08, :06 PM Macha, Dana; Totaro, Carl FW: Brett A. Elam ,326(15C) Brett Elam.pd! See enclosed Linda I. Gonzalez Senior Bar Counsel-Lawyer Regulation The Florida Bar 1300 Concord Terrace, Suite 130 Sunrise, FL Phone: Fax: From: Austin, Susan Sent: Friday, December 08, :57 AM To: Gonzalez, Linda Subject: Brett A. Elam ,326(15C) Hi Linda. Please see the attached correspondence that was received in ACAP today. Does this relate to your pending file noted above? Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 1

77 DEC /. rue FL<:)Htl\ \ F,. c.; J'Al,J,/~HA.'-t-.;~.:. i '1,.; :..,,,,I ORDERED in the Southern District of Florida a on December 1, UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION In re: Case No.: BKC-PGH Kim C. Crawford, Chapter 7 Debtor. I ORDER DENYING MOTION TO STAY PENDING APPEAL (ECF NO. 394) THIS MATTER came before the Court for hearing (the "Hearing'') on December 1, 2017, upon the Motion for Stay Pending Appeal (the "Motion") (ECF No. 394) filed by Brett Elam, Esq. (the "Movant"). In the Motion, the Movant seeks a stay pending appeal ofthe Order on Order to Show Cause Why Attorney Brett Elam Should Not Be Suspended From Practicing Before the Bankruptcy Court for Making False

78 Statements Regarding Financial Information Relating to the Debtor in Possession Funds and Any Related Sanctions (ECF No. 347), the Amended Motion For Sanctions (ECF No. 337), and the Order Denying Motion to Reconsider the Order Sanctioning and Suspending Brett Elam, Esq. (ECF No. 388). "A motion f01 stay pending appeal is an extraordinary remedy and requires a substantial showing on the part of the movant." In re Sanders, 544 B.R. 463, (Bankr. S.D. Fla. 2016) (internal citation and quotation marks omitted); see also, Garcia-Mir v. Meese, 781F.2d1450, 1453 (11th Cir. 1986) (noting that "[t]he grant of an emergency motion to stay the trial court's mandate is... an exceptional response"). In determining whether to grant a stay pending appeal, a court must determine whether the movant has adequately demonstrated four factors: (1) that the movant is likely to prevail on the merits of its appeal; (2) that the movant will suffer irreparable injury if a stay or other injunctive relief is not granted; (3) that other parties will suffer no substantial harm if a stay or other injunctive relief is granted; and (4) in circumstances where the public interest is implicated, that the issuance of a stay or other injunctive relief will serve, rather than disserve, such public interest. Garcia-Mir, 781 F.2d at All four elements "must be present if the bankruptcy court is to grant a stay pending appeal." In re Sanders, 544 B.R. at 467. For the reasons stated on the record at the Hearing, the Court finds that the movant is not likely to prevail on the merits of his appeal. The Court finds that the movant may suffer damage if a stay is not granted. However, other parties such as

79 his clients may suffer substantial harm that exceeds any potential damage to the Movant if a stay is granted. Finally, the Court finds that the issuance of a stay would. disserve the public interest if the Court authorized the Movant to practice-before this Court under these circumstances because of potential damage to his clients. Accordingly, the Court, being fully advised in the premises and for the reasons stated on the record at the Hearing, hereby ORDERS AND ADJUDGES that the Motion is DENIED. ### Copies furnished to: Brett Elam, Esq. Gary Freedman, Esq. Kim C. Crawford, Debtor Heidi Feinman, Trustee AUST The Florida Bar, Attn: ACAP Dept. 651 East Jefferson Street Tallahassee, FL

80 EXHIBIT 2

81 Case PGH Doc 294 Filed 04/21/17 Page 1 of 20 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION IN RE: KIM C. CRAWFORD, Case No.: BKC-PGH Chapter 11 Proceeding Debtor, BONY'S 1 FILING IN FURTHER SUPPORT OF ITS MOTION TO DISMISS CASE Secured Creditor BONY submits this filing in further support of its Motion to Dismiss Case [ECF 232], which is presently set for hearing on May 9, 2017, and states as follows: 1. This individual chapter 11 case, if allowed to proceed, will soon be celebrating its third anniversary. 2. Having gone through the failed confirmation hearing of the Debtor's Fourth Amended Plan of Reorganization--which was further amended on the record at the March 15, 2017 hearing-the Court is now aware of just how disingenuous this Debtor has been. 3. For example, in her schedules [ECF 26], Debtor identified "lot in Honduras" with an ascribed value of $0.00. If not for BONY's investigation, that valuation would have sailed through. But we now know that the "lot in Honduras" is actually 24 acres on the island of Roatan, which was purchased for $440,000, and with respect to which Debtor has a 50% ownership interest. The concession the Debtor was. forced to make at the March 15, 2017 confirmation hearing, is that her interest in the BONY is the abbreviated term for The Bank of New York, As Trustee for the Certificateholders of CWALT, Inc. Alternative Loan Trust , Mortgage Pass-Through Certificates Series BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida

82 Case PGH Doc 294 Filed 04/21/17 Page 2 of 20 Case No BKC-PGH Roatan island property is worth at least $78k, but the Court found even that valuation lacked credibility. 4. Similarly, the Debtor listed interests in a number of entities, all of which she ascribed a value of $0.00. But again, through BONY's investigation, the values of at least some of these entities is substantially more than nothing. Busch Canvas & Interiors, Inc., for instance, is a well-established fabricator and installer of canvas for boats, including yachts located in Palm Beach. It has two locations. In the past, Debtor and her partner were able to take out substantial salaries and distributions, and then during the bankruptcy, Debtor decided to characterize all of her compensation as salary--$101,000 worth of salary. And Debtor testified that Bush is presently having the best year of its existence. 5. The Debtor made a vague reference to a Vanguard account and, again ascribed a value to it of $0.00. But at her Rule 2004 examination, she was forced to reveal the true value. And now her March 2017 MOR [ECF 293] reflects the Vanguard accounts have a value in excess of $29,000, which she did not seek to exempt. Purpose for Notice of Filing-Unauthorized Payment of Attorney's Fees 6. The main purpose for this filing is to bring to the Court's attention that the Debtor's March 2017 MOR reflects that on March 2, 2017, check number 256 in the sum of $34,400 cleared the Debtor's DIP account at TD Bank, and is reflected as having been paid to "Brett Elam" for "Attorneys Fees." Moreover, the Debtor's cash position in her MOR was reflected as having been reduced by the $34, But the Court did not award attorney's fees to Brett Elam at the March 15, 2017 confirmation, having determined to role his application to May 9, BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida 33!31~

83 Case PGH Doc 294 Filed 04/21/17 Page 3 of 20 Case No.: BKC-PGH 7. Notwithstanding the Debtor's prior misrepresentations, wanting to provide the Debtor and her counsel the benefit of the doubt, on the morning of Tuesday, April ' 18, 2017, undersigned counsel ed Mr. Elam for an explanation as to this payment. A true and correct copy of the exchange that started at 8:38 AM on April 18, and continued through the late afternoon on Wednesday, April 19, 2017, is attached hereto as Exhibit "A" 8. That exchange is summarized as follows: a) Mr. Elam asserted that the funds were provided for confirmation and were being held in his trust account b) Mr. Freedman notes that the docket does not reflect the filing of a local form Certificate of Funds Deposited and the Debtor's MOR does not reflect providing Mr. Elam any other funds necessary to confirm the Debtor's Fourth Amended Plan. Mr. Freedman requested that Mr. Elam provide proof that the $34, remains in his trust account and also suggested that the funds should be sent back to the Debtor as confirmation of the Debtor's Plan was denied. c) Mr. Elam states that he has proof that the funds remain in his trust account and that the reason the funds remain there and "weren't given back [to the Debtor] is the same reasons your client worries about it, I don't want them dissipated." funds back." d) Mr. Freedman writes back: "Send proof of what I asked for, and then send e) Upon Mr. Freedman's further request for the offered proof, at 2:03 on April 18, Mr. Elam writes, "Gary I am not in the office right this second. Let me get to the office. I am not ignoring but you gotta let me get to the office." 3 BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida I I

84 Case PGH Doc 294 Filed 04/21/17 Page 4 of 20 Case No.: BKC-PGH f) At 5:36 PM on April 18, Mr. Freedman s Mr. Elam: "You at your office yet?" g) Mr. Elam responds shortly thereafter that he never went back to his office, he is spending time with his parents, and concludes by stating, "I promise when I get back from taking them to the airport in the morning I will send you whatever you need." h) At 7:17 AM on April 19, Mr. Freedman s Mr. Elam stating that, "if you are holding the funds in trust for Crawford, the funds belong to her and should be reflected as such on her March MOR." i) Having heard nothing from Mr. Elam, at 4:09 PM on April 19, Mr. Freedman s Mr. Elam expressing his bafflement as to why Mr. Elam has not delivered the promised "evidence that the $34,400 is, and always has been, in your trust account." j) At 4:41 PM on April 19, Mr. Elam responds with curt claiming now that he has been with family for the last day and a half and that, "I told you I would send you something, which I don't recall doing or seeing, then I will." 9. Another exchange started on Thursday, April 20, 2017, a true and correct copy of which is attached hereto as Exhibit B," and is summarized as follows: a) On Thursday, April 20, 2017, at 11 :05 AM, Mr. Elam ed Mr. Freedman a redacted portion of his IOTA Trust Account Statement showing the deposit of the $34, into his trust account on March 2, b) Mr. Freedman s back at 11 :20 AM, "[!]hank you for this. But what I really need, as you know, is proof that the funds still reside in your trust account. Please provide." 4 BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida

85 Case PGH Doc 294 Filed 04/21/17 Page 5 of 20 Case No.: BKC-PGH c) Having received no response, at 12:43 p.m., Mr. Freedman s Mr. Elam asking him if he is going to provide the requested evidence. d) Mr. Elam immediately s back indicating that he has "other things going on too." "I will be back later this afternoon." 10. As of this Filing, 2 Mr. Elam has failed to provide proof that the subject funds have been held in his trust account. Any way you look at it, providing this proofwhich Mr. Elam had agreed to do-should not have a been a significant undertaking. Likewise, reflecting the $34,400 as the Debtor's property in her MOR could have been easily remedied. 11. The foregoing events, along with the tortured history of this case, including the Debtor's failure to carry her burden at the March 15 confirmation hearing, further supports BONY's Motion to Dismiss Case. 12. Alternatively, BONY submits that good cause exists for appointing a chapter 11 trustee, who can stop these shenanigans, continue to manage the debtor's businesses where warranted, value her assets, and liquidate them. That may be the only way creditors are assured of maximizing their recoveries. See 11 U.S.C WHEREFORE, BONY makes this filing in further support of its Motion to Dismiss case, or alternatively, moves for the appointment of a Chapter 11 trustee. Undersigned counsel attempted to call Mr. Elam at 10:57 AM on April 20, 2017, immediately prior to submitting this filing, but was forced to leave a message on his firm's answering machine. 5 BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Bisci1yne Blvd. Miami, Florida 33131~

86 Case PGH Doc 294 Filed 04/21/17 Page 6 of 20 Case No.: BKC-PGH CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via CM/ECF to all registered to receive electronic noticing in this case and via First Class U.S. Mail to all parties on the attached service list on April 20, Respectfully submitted, BROAD AND CASSEL LLP Attorneys for Bank of New York Mel/on and Bayview Loan Servicing, LLC One Biscayne Tower, 21st Floor 2 South Biscayne Boulevard Miami, Florida gfreedman@broadandcassel.com Telephone: (305) Facsimile: (305) By: Isl Garv M. Freedman Gary M. Freedman Florida Bar No BROAD and CASSEL LLP One Biscayne Tower, 21st Floor 2 South Biscayne Blvd. Miami, Florida 33!

87 Case PGH Doc 294 Filed 04/21/17 Page 7 of 20 Label Matrix for local noticing Bank of America 1 NA Bank of New York Mellon 113C-9 Michelle Gilbert Garcia, P.A. c/o SHD Legal Group PA Case PGH 2005 Pan Am Circle POB Southern District of Florida Suite 110 Fort Lauderdale, FL West Palm Beach Tampa, FL Fri Apr 21 12:23:47 EDT 2017 Bayview Loan Servicing, LLC Nationstar Mortgage LLC Wells Fargo Bank, National Association 1 ; Tabas, Freedman &Soloff, P.A. c/o Shapiro, Fishman &Gache Shapiro, Fishman &Gach, LLP c/o Gary MFreedman 4630 Woodland Corporate Blvd # Woodland Corporate Blvd. 14 NE 1st Ave., Penthouse Tampa, FL Suite 100. Miami, FL Tampa, FL BANK OF l\merica, N.A. Bank of America Central Finl Control GILBERT GARCIA GROUP, P.A. Attn: Correspondence Unit/CA Po Box PAN AM CIRCLE, SUITE 110 Po Box 5170 Maryland Heights, MO TAMPA, FL Simi Valley, CA Green Tree Internal Revenue Service (p)nationstar MORTGAGE LLC Po Box 6172 Centralized Insolvency Operation PO BOX Rapid City, SD P.O. Box 7346 DALLAS TX Philadelphia, PA Nationstar Mortgage LLC Office of the US Trustee Select Portfolio Servicing c/o Vivian J. Elliott, Esq. 51 S.W.!st Ave. Po Box Woodland Corporate Boulevard Suite 1204 Salt Lake City, UT Suite 100 Miami, FL Tampa, FL The Bank of New York Mellon Fka The Bank of Wells Fargo Bank Nv Na Wells Fargo Bank, N.A. Select Portfolio Servicing, Inc. Attn: Deposits Bankruptcy MAC# P610 I Home Campus 3815 South West Temple Po Box 3908 MAC X2303-0IA Salt Lake City, UT Portland, OR Des Moines, IA Phone number Brett AElam Esq. Brian KMcMahon Carlos Cerezo Farber +Elam, LLC 1401 Forum Way 166 San Remo Dr 105 S. Narcissus Avenue 6th Floor Jupiter, FL Suite 802 West Palm Beach, FL West Palm Beach, FL Kim CCrawford 1090 Coral Way. Nest Palm Beach, FL The preferred mailing address (p) above has been substituted for the following entity/entities as so specified by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P (g) (4). Nationstar Mortgage LLC Attn: Bankruptcy 350 Highland Dr Lewisville, TX 75061

88 Case PGH Doc 294 Filed 04/21/17 Page 8 of 20 Gary M. Freedman From: Sent: To: Cc: Subject: Gary M. Freedman Wednesday, April 19, :00 PM Brett Elam Dahlia Parry; Gary M. Freedman RE: Crawford I will not rehash what you have promised to do, the s are the best evidence of that. I will proceed accordingly. Thanks for getting back to me just now. Also, please allow the exchanges since yesterday morning to serve as my good faith effort to resolve this issue without court intervention. Best, Gary...~fJi~~il!lf~i$1~~1~1il Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT llne: E~MAIL: GFREEDMAN@BROADANDCASSEL.COM From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Wednesday, April 19, :41 PM To: Gary M. Freedman <gfreedman@broadandcassel.com> Cc: Dahlia Parry <DParry@broadandcassel.com> Subject: RE: Crawford Gary, Did I not tell you I was gone all day yesterday and I was gone all morning today. I am not sure about you, but I enjoy spending time with my family and I am not going to not do so just to get you something. An if you call me a liar again, I am not going to be happy. Second, if you were gone for a day and half, do you think you might have a lot going on when you get back? If I told you I would send you something, which I don't recall doing or seeing, then I will. But, in the meantime, I am trying to get caught up and I have had someone in my office since I got here Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T l EXHIBIT A

89 Case PGH Doc 294 Filed 04/21/17 Page 9 of 20 (561) llretr A. lilam, ESQ, $1 1.~:'l.1.ill) v.-'"",lil\'u l.!f>yll1tn>,'l/!1> This transmission is intended to be delivered only to the named addressee(s) and may contain information that is confidential, proprietary, attorney work-product or attorney-client privileged. If this information is received by anyone other than the named and intended addressee(s), the recipient should immediately notify the sender by and by telephone at the phone number of the sender listed on the and obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the named addressee(s), except with the express consent of the sender or the named addressee(s), Thank you. CIRCULAR 230 DISCLAIMER: This communication does not constitute a "covered opinion" as such term is defined within Circular 230, and does not comply with the requirements for a "covered opinion." We have not conducted, nor have we been asked to conduct, that type of analysis in this communication. To ensure compliance with requirements imposed by the IRS, we must inform you that any U.S. federal tax advice contained in this communication (including any documents or items appended herein) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. From: Gary M. Freedman [mailto:gfreedman@broadandcassel.com] Sent: Wednesday, April 19, :09 PM To: Brett Elam <belam@brettelamlaw.com> Cc: Dahlia Parry <DParry@broadandcassel.com> Subject: RE: Crawford Brett, I am baffled as to why this has not been resolved and why you have not provided me evidence that the $34,400 is, and always has been, in your trust account Your unfulfilled promises to do so is causing me to think that the situation is not as you claimed it to be. Please send me the proof now. Thank you. Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 2

90 I Case PGH Doc 294 Filed 04/21117 Page 10 of 20 broad and casse I. com/" style='position: absolute; left:o;text a I ign: left; ma rgi n-1 eft:o; margin to p :O;width:91.5 pt; height: 3 7.S pt;zindex: ;visibility:visible;mso-wrap style:square;mso-width-percent:o;mso-height percent:o; mso-wra p-d ista nee-i eft:o; mso-wra p d ista nce-to p :O; mso-wra p-d ista nce-right :O;msowrap-dis ta nce-botto m :0; mso-positio n ho rizo nta I: left; mso-positio n-ho rizo nta! relative :text; mso-positio n-ve rtica I :a bso I ute; mso positio n-vertica I-relative: I ine; mso-width perce nt:o; m so-he ight-pe rcent:o ;mso-wi dth relative: page; mso-height-relative: page' o:allowoverlap= 11 f' 1 o:button= 11 t 11 > 21sr FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT LINE: GFREEDMAN@BROADANDCASSEL.COM From: Gary M. Freedman Sent: Wednesday, April 19, :17 AM To: Brett Elam <belam@brettelamlaw.com> Cc: Dahlia Parry <DParrv@broadandcassel.com> Subject: RE: Crawford Brett, Also, if you are holding funds in trust for Crawford, the funds still belong to her and should be reflected as such on her March MOR. Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. broad a ndcassel.com/" style=' posit ion :a bso I ute; left :O; textalign: left; ma rgi n-1 eft :O; margin _top:o;width:91.~pt;~e-ight:37.spt;z-.j 3

91 Case PGH Doc 294 Filed 04/21/17 Page 11of20 index: ;visibility:visible;mso-wrap style:square;mso-width-percent:o;mso-height percent:0;mso-wra p-d ista nce-left:o ;mso-wra p distan ce-to p:o; mso-wra p-d ista nce-right:o; msowrap-d ista nce-botto m :O;mso-position ho rizo nta I: left; mso-position-horizonta I re lative :text; mso-position-ve rtica I :a bso I ute; mso pos itio n-ve rtica 1-relative: I ine; mso-width percent:o;mso-height-percent:o;mso-width relative:page;mso-height-relative:page' o:allowoverlap::: 11 f 11 o:button::::: 11 t 11 > 21sr FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT LINE:305, GFREEDMAN@BROADANDCASSEL.COM From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Tuesday, April 18, :56 PM To: Gary M. Freedman <gfreedman@broadandcassel.com> Cc: Dahlia Parry <DParry@broadandcassel.com> Subject: Re: Crawford Gary no I am actually not. I am with my parents who are visiting and leaving tomorrow. After court today I actually took off to spend their last day with them. They have been here a week and I haven't seen them at all. I promise when I get back from taking them to the airport in the morning I will send you whatever you need. Brett A. Elam, Esq. BRETT A. ELAM, P.A. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) F From: qfreedman@broadandcassel.com Sent: April 18, :36 PM To: belam@brettelamlaw.com Cc: DParry@broadandcassel.com Subject: RE: Crawford You at your office yet? 4

92 Case PGH Doc 294 Filed 04/21/17 Page 12 of 20 Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, Fl TELEPHONE: FACSIMILE: DIRECT LINE; GFREEDMAN@BROAOANDCASSEL.COM From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Tuesday, April 18, :03 PM To: Gary M. Freedman <gfreedman@broadandcassel.com> Cc: Dahlia Parry <DParry@broadandcassel.com>; Gary M. Freedman <gfreedman@broadandcassel.com> Subject: Re: Crawford Gary I am not in the office right this second. Let me get to the office. I am not ignoring but you gotta let me get to the office. Brett A. Elam, Esq. BRETT A. ELAM, P.A. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) F From: gfreedman@broadandcassel.com Sent: April 18, :01 PM To: belam@brettelamlaw.com Cc: DParry@broadandcassel.com; gfreedman@broadandcassel.com Subject: RE: Crawford Brett, Third request. AT 1 llll NJ.\'~.J.1 1..J.'11 Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, FL TELEPHONE: FACSIMILE: I DIRECT LINE: E-MA!L: GFREEDMAN@BROADANDCASSEL.COM.l i11 5

93 Case PGH Doc 294 Filed 04/21/17 Page 13 of 20 From: Gary M. Freedman Sent: Tuesday, April 18, :07 AM To: 'Brett Elam' Cc: Dahlia Parry Subject: RE: Crawford Send proof of what I asked for, and then send funds back. BTW, it's a local form. Gary M. Freedman PARTNER 2 SOUTH SISCAYNE BL VD. 21ST FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT L1NE: E-MAlL: GFREEDMAN@BROADANDCASSEL.COM From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Tuesday, April 18, :03 AM To: Gary M. Freedman <gfreedman@broadandcassel.com> Cc: Dahlia Parry <DParry@broadandcassel.com>; Gary M. Freedman <gfreedman@broadandcassel.com> Subject: Re: Crawford Yes I do. I have never had to file a certificate of deposit. 1.n every case I have ever been in Gary, the fees are held in trust until the order is entered. I mean really, this is what we are going to argue about. The funds are there and the reason they weren't given back is the same reasons your client worries about it, I don't want th.em dissipated. Brett A. Elam, Esq. BRETT A. ELAM, P.A. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) F From: gfreedman@broadandcassel.com Sent: April 18, :25 AM To: belam@brettelamlaw.com Cc: DParry@broadandcassel.com; gfreedman@broadandcassel.com Subject: RE: Crawford 6

94 Case PGH Doc 294 Filed 04/21/17 Page 14 of 20 Brett, I do not see that you ever filed a Certificate of Amount Deposited. When confirmation was denied and your fee apps got rolled, why did you not return the funds? What evidence can you provide that the $34,400 remains in your trust account? Do you have a copy of the check? r R~1 ~1!fil~~f±l~llii1~ Gary M. Freedman 1 1 PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT L!NE: GFREEDMAN@BROADANDCASSELCOM 1 From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Tuesday, April 18, :47 AM To: Gary M. Freedman <gfreedman@broadandcassel.com> Cc: Gary M. Freedman <gfreedman@broadandcassel.com>; Dahlia Parry <DParry@broadandcassel.com> Subject: Re: Crawford Gary she wrote it to me and it is held in trust. I had it for the confirmation hearing. It hasn't been disbursed. I just had it in anticipation of confirmation. I am still holding it. Brett A. Elam, Esq. BRETT A. ELAM, P.A. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) F From: gfreedman@broadandcassel.com Sent: April 18, :38 AM To: belam@brettelamlaw.com Cc: qfreedman@broadandcassel.com; DParry@broadandcassel.com Subject: Crawford Brett, I was just flipping through Crawford's March MOR and noticed that check number 256 in the sum of $34,400 written on her DIP account was paid to you or your firm on March 2, I know we had hearings on March 15, when confirmation of Crawford's fourth amended plan was denied, and your fee applications were carried over to the next hearing date of May 9. And I remember you were upset with me for asking the Court to carry over those fee applications. But this check was paid even before the March 15 hearings. I thought that perhaps I missed an order, but 7

95 Case PGH Doc 294 Filed 04/21/17 Page 15 of 20 went back and looked at the docket and could not find a corresponding order. I do not want to prematurely raise any alarm, so please get back to me this morning on this. Otherwise, I feel compelled to let the UST know and bring it to the Court's attention. I look forward to hearing from you. Gary Gary M. Freedman PARTNER 2 SOUTH SISCAYNE BL VD. 21ST FLOOR 1-t ' MIAMI, Fl t31~q/\l:?,,~1, C::l\?'.;m. TELEPHONE: _,\flllll.nl FACSIMILE: ~ Al I..<,\\.' DIRECT LINE: E~MAIL: GFREEDMAN@BROADANDCASSEL.GOM THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT JS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. ANY ATTACHMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICATION CONTAINED THEREIN. NO TRANSMISSION OF UNDERLYING CODE OR METADATA IS INTENDED. USE OF ANY ATTACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED THEREIN IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY AND RETURN THE ORIGINAL MESSAGE TO THE SENDER. THANK YOU. THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. ANY ATTACHMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICATION CONTAINED THEREIN. NO TRANSMISSION OF l!nderlying CODE OR METADATA IS INTENDED. USE OF ANY ATTACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED THEREIN IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY AND RETURN THE ORIGINAL MESSAGE TO THE SENDER. THANK YOU. THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE, ANY ATTACHMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICATION CONTAINED THEREIN. NO TRANSMISSION OF UNDERLYING CODE OR METADATA IS INTENDED. USE OF ANY A1TACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED THEREIN IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY AND RETURN THE ORIGINAL MESSAGE TO THE SENDER. THANK YOU. THE INFORMATION CONTAINED IN THIS TRANSMISSION rs ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. ANY ATI'ACIIMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICA TJON CONTAINED THEREIN. NO TRANSMISSION OF UNDERLYING CODE OR METADATA IS INTENDED. USE OF ANY ATTACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED THEREIN IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED, IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE IMMEDIATELY NOTIFY AND RETURN THE ORIGINAL MESSAGE TO THE SENDER. THANK YOU. THE INFORMATION CONTAINED IN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. ANY ATTACHMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICATION CONTAINED THEREIN. NO TRANSMISSION OF UNDERLYING CODE OR METADA TA IS INTENDED. USE OF ANY ATTACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED THEREIN IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY

96 Case PGH Doc 294 Filed 04/21/17 Page 16 of 20 Gary M. Freedman From: Sent: To: Cc: Subject: Brett Elam Thursday, April 20, :50 PM Gary M. Freedman Dahlia Parry; Gary M. Freedman Re: Crawford Proof of Deposit Gary I will but I have other things going on too. I don't stay in my office all day. I am on the way to a 341. I will be back later this afternoon. Brett A. Elam, Esq. BRETT A. ELAM, P.A. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) F From: gfreedman@broadandcassel.com Sent: April 20, :43 PM To: belam@brettelamlaw.com Cc: DParry@broadandcassel.com; gfreedman@broadandcassel.com Subject: RE: Crawford Proof of Deposit Brett, Are you going to send this? I have a filing ready to go, but want to give you a final chance to show that fonds remain in your trust account. This is not hard to do, just show disbursement sand end of month balance. Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, Fl TELEPHONE: FACSIMILE: DIRECT LINE: GFREEOMAN@BROADANDCASSEL.COM 1 EXHIBIT 6

97 ,-- H mm iliillr~~wl~~~~~ti~ Case PGH Doc 294 Filed 04/21/17 Page 17 of 20?~~~1at1141;~ From: Gary M. Freedman Sent: Thursday, April 20, :20 AM To: 'Brett Elam' <belam@brettelamlaw.com> Cc: Dahlia Parry <DParry@broadandcassel.com> Subject: RE: Crawford Proof of Deposit Thank you for this. But what I really need, as you know, is proof that funds still reside in your trust account. Please provide..\jloll.nt:y~.\l l..~w Gary M. Freedman PARTNER 2 SOUTH BISCAYNE BLVD. 21ST FLOOR MIAMI, FL TELEPHONE: FACSIMILE: DIRECT LINE: E~MAIL: GFREEDMAN@BROADANDCASSEL.COM From: Brett Elam [mailto:belam@brettelamlaw.com] Sent: Thursday, April 20, :05 AM To: Gary M. Freedman <gfreedman@broadandcassel.com> Subject: Crawford Proof ofdeposit Importance: High 2

98 Case PGH Doc 294 Filed 04/21/17 Page 18 of 20 Gary, You asked me to send you proof of the deposit into my IOTA trust account. I have attached a copy of the redacted statement. I have more than one client, so I am not sending the unredacted version of the statement. But here is the portion that shows the check was deposited into my trnst account. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) THE LAWOFFIC!iS 01' - ~ ' - - ~ '~~---"' ~ BRETT" A, ELAM, ESQ, $t l.h:u. I 1 t,1..v.w.hr"11~!~1\1ll;'1<,.,,m This transmission is intended to be delivered only to the named addressee(s) and may contain information that is confidential, proprietary, attorney work-product or attorney-client privileged, Ifthis information is received by anyone other than the named and intended addressee(s), the recipient should immediately notify the sender by and by telephone at the phone number of the sender listed on the and obtain instrnctions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the named addressee( s ), except with the express consent of the sender or the named addressee(s), Thank you, CIRCULAR 230 DISCLAIMER: This communication does not constitute a "covered opinion" as such term is defined within Circular 230, and does not comply with the requirements for a "covered opinion." We have not conducted, nor have we been asked to conduct, that type of analysis in this communication, To ensure compliance with requirements imposed by the IRS, we must inform you that any U.S. federal tax advice contained in this communication (including any documents or items appended herein) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein, 3

99 Case PGH Doc 294 Filed 04/21/17 Page 19 of 20 THE INFORMATION CONTAINED TN THIS TRANSMISSION IS ATTORNEY PRIVILEGED AND CONFIDENTIAL. IT IS INTENDED FOR THE USE OF THE fndiv!dllal OR ENTITY NAMED ABOVE. ANY ATTACHMENTS TO THIS TRANSMISSION ARE FOR THE SOLE PURPOSE OF CONVEYING THE DIRECT WRITTEN AND COMMONLY VISIBLE COMMUNICATION CONTAINED THEREIN. NO TRANSMISSION OF UNDERLYING CODE OR METADATA IS INTENDED. USE OF ANY ATTACHMENT FOR ANY PURPOSE OTHER THAN RECEIPT OF THE DIRECT WRITTEN COMMUNICATION CONTAINED Tl!ERE!N IS STRICTLY PROHIBITED. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS COMMUNICATION IS STRICTLY PROHIBITED. IF YOU HAVE RECEIVED THIS COMMUNICATION TN ERROR, PLEASE IMMEDIATELY NOTIFY AND RETURN THE ORIGINAL MESSAGE TO Tl!E SENDER. THANK YOU. 4

100 Case PGH Doc 294 Filed 04/21/17 Page 20 of 20 4 A! SeacoastBank Statement of Account Member ~ i> Seacoast National Bank FDIG '"1)11 P.O. Box 9012, Stuart, FL Last statement: February 28, 2017 This statement: March 31, I SeacoastBank.com Total clays iu statement period: 31 Temp-Return Service Requested 47 Page 1 of FIMR THE LAW OFFICES OF Direct inquiries to: Customer Service Center BRETT A ELAM P.A. IOTA TRUST ACCOUNT S NARCISSUS SUITE 802 WEST PALM BEACH FL Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL "'f -.,,~,,.,,_,,..-.,.;: :,.,.;:,_.:.,~,:~,}:.:? (~:;::~ '" ;;:'~{;:~:-:: _,-. :: : ~.- Accouut nun1hor Enclosure Ba/a11ca $5,00IJ,i~ 39,_iQ!lJ?.

101 case PGH Doc 296 Filed 05/09/17 Page 1 of 22 L: UNITED STATES BANKRUPTCY COURT )e"--\-\1-e l'.-rj DISTRICT OF fl L' iticl""-' Cu, p, r;,,j\,. DIVISION IN"RE: ) l l l l DEBTOR. K\,,, Q(L \l\0 f'.-0(4) ) CHA.PTER11 JU))GE.?c_,,J ~-\1,pV\ 4, 1,.._ A;;;;JaRi DEBTOR'S MONTHLY OPERATING REPORT (INDIVIDUAL) FOR T.8.E PERIOD FROM fv\cltd\ \ 1 './..b\l TO \\\(\,;(G\\ 'I)\, '.).t. \1 I I Comes no'\v the above-named debtor and tiles its Monthly Operating R~port in accordance \vhh the Guidelines established by the United States Trustee and FRBP Dre.+t 8 <e,m Atfomey for Debtor Debtor's Addi:es:s and Phone Nu1nbcr: Attorney's ~'\.ddress and Phone Number: *-~~ K\Lt.1 c\ s,.-; LLS -t;fll~g. 1>' \ciol Ear No. Toi. i(&cj' '!J - I U_1 Note: 'Ille original Monthly OpuutingReport is to be filed with the court and a copy.5unultaneous(y providc<l to tm United States Trustte. Monthly Operatiug Rcronsmust be filed by the 20th day ofthe: following month, Foras;;istauc~ in preparing the Monlhly Operating Report, ref!!( to I.he folkiwng r Snurces on. the United States Trustee Program website, hltp:/lwww.usdolqov/usur61lfeg info.him_ 1) Instnictfous for Prepm-atl.onDcbtor's Chapter ll Monthly Opetating Repon 2) Initial Filing R1:qu.irements 3) frequently Asl:<:d Questions (FAQs)

102 case PGH Doc 296 Filed 05/09/17 Page 2 of 22 MONTHLY OPERA.TING REPORT!NDIVDUAL ATIAOIMENTNO. i QUF...,<;l'IONNAffiE YES~ ' NO L. Have :1ny a.%el5 bc:cn oold or1r:uisicr1ed outsidi;: thetioml:tl ctitlt'"..o ofbusin=!luring!lii$,/ renoniru:; ncrlod lfav"nny fund_~ bttn di\bun;;:j!'mm :n1y:1ceount oth.,.- Ihm o dtb!or in po.s=ion account'/ 1/ l. Aro nny po.st-pe:liliou 1'.>t:dYabks (1tcCOllll!s, note>, orloaiis) d\lc: froni :my 1do.tivcs, irui<k:rs, or reiatoo: eaim v 4. ff;p;~any paymerus b~n made cm pre-pdition liahilitii:s this rqwit1ngpe0od1 i/ 5. H"'v"~"Y p<.- l-f>"tition \,,~ hmfit<>e<lv~d by 1hc deblo< fro1nanyp:my? i/ 6. Arc any po5l-p~titiojj payroll tro:.es pmt due'! i/ - 1. Ano My post.petition staieor fo(\eml income ---j- la.'1'.c.~ JlUI due'/ - 8. Are any po~t:ficlllfon st:uc or local sal.:s la.'1'..:s [!U->t due? J '. Are ;my po.~t-pctition R"1 estme t-u~ pall dlw?./ JO. Are any nmuunjs nwcd to11<1st-pui.tion e1cdito!lllvendor.;: ddinqucnt? / l!. Arc-any waga p~ymoots past due?.ifthe atj.mtr to ;myoffuc ;tbavequielillons l5 "YES,.. pro,1dc 3 ildaik!l e~1ibn{lfion nfnitb l!cnl on; s~plr"-teshtct. v' INSOBANCE INFORMATION YES I.,Me rca\111:1<1 petsowi\ pn;ii1eny, v~hfoie/auto, gcncr:tllfabilily, :Jiro, the fr, wmktc's oomh~n'iation. andolhw f\l':<:>:!:s!u)'!usurance cov.,mi-;cs iu ~ffect? / AN all rm::jillum payments1:1"renl'i ' 1/., J lhe auswer lo any of the :lhovc questions is.., NO, " provide :'I del-alltd uplrmatlon af euclt ifcm nn a separ:i.1<!.s-hcct NO CONl"JRt.IATION OF JNSlfRANCE 1'1!)'DlCl'lf /ttjiolm! TI"f>E ofl'ol.lcy CARRIER Pc1foil af C0Yera<>11. aud J'nquciii:Y '"' '" I <J,t.rtj, 0) tt?,. ""_-i-;fl ' "' l-il\.+-11 NJI:. ;if/l_l 1""'1 - Uf1f/7',?l f, lni "--'0'1"" UW1Jet~ ) U..i.JL1i.rv..0-ne;~L-f(hi;i.;J-f-1,' ".,Vt'. -., "", I. - j,. r"'in (l I. 'r-dil\\- I\ n{ ;Cl\\)\,I l~ioch'-' r~.r?, }~ }.);..)<. -, ( :~f1tii 17~>J.. ' DtliDIJU<!llc;Y Amo"rint 'A IY DRSCRIBJ.?. PERTINF.NT JJEVELOPMENTS, VENTS, AND t.l\tiers DURING TBlSREP-ORTrNG PE JUOD; '!'."' <>.,...\\..:,~~QM. ~ ~,..,Q, t.w:.,~o"" ~<'\ "'.) f.aa>j, i.<>1\ 1 J,.\... I:>,.\.v.<.&...J (). ~ ~ ta.&.~i\ Cw.. \o l!,o"":wn. if.~.r~...j.s:,,...,_,,_ JA'+": k.{),',,/;,. e.o..,~'j, ~.s.\-- o..u.01111" Ac LL.. e...vfll- ~ lo <%lv>l},...,. U... Nai;,, ~ ~ ~ 11\ol- ll.ffro..dl. ~ ~ l)a..o..,;. ae,,,,.sj!.s Jr.,.+ a.,~ ~\.ol.s o..~~ f.f.tlryi Ji... CovM; f':.mirnat~d Dal«<>fFiliog th<' l'l:ui ofrwrganiz.ition and Discfo3\lf<' SM~rn~m;

103 Case PGH Doc 296 Filed 05/09/17 Page 3 of 22 Renewal auto policy dedarations... C_) ~ ~Allstate.. Your policy effective date is February 12, 2017 You're in good hands. Total Premium for the Policy Period Please review your insu(ed vehicle and \lerify its VIN is correct. VeliicJe c:.overed ldentifkation Number (VIN) Pre1niu Acura Rsx JH4DC54892C $ ~~~M~~~~a.:~@lWlfPPeM&iM&~~ifU~iw!i= ~~~ ~o~~~~~~ "'Vour bit/ wjj1 be n1ailed separately, Before 111aldng a pay1nent, please 1 efer to yoilr latest blll, which includes paynient options and install1nentfee lnfonnatjon. If you do not pay in full, you will be charged an instafhnent fee(s). See the Important payment and coverage information section for details about installment fees. ID>isco1.mts (included in your total premium) r,==~.~ts:::~ ::=J Excluded drivers from yo~~e_o_li~cy None Information as at January 3, 2017 S!lmmary Named lnsured(s) l(im C Crawford 0 Riviera Beach FL Po\ic number Page 1of3 Your policy provided by Allstate Property and Casualty Insurance tompany Policy period Beginning February 1:2, 2017 through August 12, 2017at12:01 a.m. standard Passive Restraint $20.66 Antilock Brakes $16.94 Horne Ownership $27.98 Premier Plus $ time Your Allstate agency is Batten lnsurance W Frst HI 1104 Wellington FL DJscourUs per vehicle (561) ( 2002.Acura Rsx $332.98) ABATTEN@ALLSTATE.COM Passive Restraint $20.66 Antilock Brakes $16.94 Some or all of the infonnation 011 your Home Ownel'ship $27.98 Pre1nier Plus $ PoliGy Declarations is used in the rating of your policy or it could affect your Listed driver 011 your policy eligiqllity for certain coverages. Please Kim Crawford notify \IS immediately if you believe that any lnfon11atlon on your Polk.y Decli:lrations Is incon ect. We will n1ake co1 rections once you have notified us, and any result\ng rate adjustmentsr will be 111ade only tor the current policy period or for future policy periods. Please also not\fy us immediately if you believe ally coverages are not listed or are inacc.ur~tely listed. [;}l)j_i

104 . case PGH Renewal auto poltcy declarations Policy number: j gfil Policy effective date: February 12, 2017 Doc 296 Filed Page 4 of 22 Page2of3 Coverage detaii for 2002 Acura Rsx Coverage Limits Deductible Premium --= Personal Injury Protection $0 $63.68 Death Benefit $5,000 each person Aggregate Medical Expenses (Emergency or Non-Emergency Medical Condition), Income loss and Loss of Services $10,000 each person Medical Expenses Limit Medical Expenses Emergency Medical Condition $10,000 each person OR Medical Expenses Non-Emergency Medical Condition $2,500 each person The sum ~f Medical_~enses, Income Lo,?-s and Loss of Services benefits cannot exceed the aggregate $10,000 limit.. ~ Auto Collision Insurance Not pur<:hased* 0 Auto Comprehensive Insurance Not purchased* Automobile Liability Insurance e Bodily Injury $100,000 each person Not applicable $ $300,000 each occurren-ce e Property Dan1age $100,000 each occurrence Not applicable $ ~;\Reimbursement Not purchased* _2"owing-~~~~~o~-Cosb; _!J~: purchai~.:--.~~~~ ~-=~=~= Uninsured Motorists Insurance for Bodily $10,000 each person Not applicable $39.63 Injury $ each accident ~}~~~red ~~!~ists!0~e \irni~s of insu~~~yeh~~~!tlay ~~~tac~ed: ~ - ~ Au~?-~ob~~e ~7_dlcal P~men!:. ~otp_~!~as~* Lea~~-~-oan_Gap ~!_purchased* Repalr or Replacement Cost Option Not purchased* $-S~~~d System - -- Not p~rch;;d; Tape (Total p1 emium for 2002 Acura Rsx Not purchased* 'Tiiis covernge can provide you with valuable protectlor1. To help you stoy current with your insurance needs, contact your Altstate agent to discuss coverane options and other products and services that ca11 l1elp protectyou. ("">, VIN JH4DC54892C Rat\ng lnformatidn ~ This vehicle Is driven over 7,500 miles per year, for pleasure, adult age SB, with no unmarried driver under 25 1 good d_river rate

105 Case PGH Doc 296 Filed 05/09/11 Page 5 of 22 A Stock Company FFL P.O. Box St. Petersburg, FL /31/17 FLOOD DECLARATIONS PAGE NEW BUSINESS, ~P~Q~J~iC~ '.' NunibCr NFIP Polic,<Nu1nbcr Pnfrhtct 'J'vnc:-- Standa;i;d PoJJ_:cy Dwellinq Form FLD RGLR { Polic\'':PeriOd llatc of ls!iue (.f'l'om: 3/ 14/17 To: 3/14/18 12:01 am S1111ulanl Time 03/ Agent (561) SUN STATE INSlJlUlliCE AGENCY KIM CRAWFORD OF THE PALM BEACHES INC 1090 CORAL WAY 623 NORTHLAKE BLVD SINGER ISLAND FL N PALM BEACH FL Pnlpcrlr Lucallou (ifull11. 1 lh:1ll nllll\'t) 1090 CORAL WAY, SINGER lsland FL A!lili ~ss 11u\yh\\\'<' bn'll ch;mgcol i11 m ro1 1Iann with \l~l's ~l;l1u1nn\s. Building Occupancy: Single Family Community Name: RIVIERA :BEACH, CITY OE' ~ximary Residence: Y Community /I: Map Panel/Suffix: 0003 D Number of F.laors: One Flot'.lr Conununity Rating: 09 I 05% Building Indicator: Non-Elevated Program Status: Regular G~andfathered: No Bascment/Enclosu~e/Crawlspace: Flood gisk/rated Zone: A07 No Basetnent Condo Type: N/A Elevation Difference: 2 1,.--.-,,e:ritgC :pc<luctiblc Prcn1iun1 ~JILDING $250,000 $2,000 $ CONTENTS $20,000 $2,000 $76.00 ANNUAL SUBTOTAL! $ DEDUCTIBLm DISCOUNT/SURCHARGE: $40.00 j :'THIS.'.IS.NOT A BILL ::J ICC PRF.MIUM: $4.00 DEM MORTGAGEE COMMCJNITY RATING DISCOUNT: $25,00 1'hc Rcfot m Ad of 1994 rcquin:~ yon tn notit:.' t'hl" \VYO cotnpnny for thh policy withln 60 days of nn~' ch;)nges In tlw sl!nit.:el" of this loan. SUB~-TOTAL : RESERVE FUND ASSESSMENT: $ $70.00 the i1bo\'e mc.~sngc tipplit'!> 11nlr when there ii.'' PROBATION SURCHARGE: $.00 mortgagee 011 the in~urcd lm:ntion. FEDERAL POLICY SERVICE FEE: $50.00 HFIAA SURCHARGE: $25,00!?.:i:emium Paid by: Insured TOTAL OF PREMIUMS AND FEES: $ ,._,,.:--. Thi~ plllicy corers only onl' building. If suu have 11mrc thun one building on ymu- pro1icrt}', 11lc:1se nrnkc swv th{})' nrc all 1;u\'tH'Cll. Sec 111. J>ropcl'ty CO\'crcd "'Uhin your Flnod policy for the NFJP dcf!nilion of "ln1ildi11g" or cont;itl _ro10 ngcnt, hrokcr, or l11mn nnci: c.:um)hlll}', Covcr11gc Lilnilntions rnny apply. Please 1 cfor to yo11r Flood Lt1~11rm1cc Policy Furm for tldni\s, WFL 99, FFL 99, WFL ~1,,'lJ:is po1icy is issued by NAIC company ight National Flood In~urance cnmpany A stock company Copy Sent To: As indicated on back or additional pages, if any, ' Insuxed

106 Universal Property & casualfy lnsurauce Con1pany c/o Universal Risk Advisors -- ~"\10 W. Com1ncrcial Blvd Suite. 300,rt Lauderdale, FL lot! Pree: 800~ Case PGH Doc 296 Filed 05109/17 Page 6 of 22 Claims: Homeowners Declaration Effective 3/10/2017 AMENDED: Coveraga(s), Swimming Pool, Background Queslion(s) Servlce: Con.lo.ct your Agent Listed Below Policy Nunlber FROM Polley Period TO INSURED BILLED Agent Code 150H / /10/ :01 AM Standard lime 9Y ~nsured and Address Agent Name and Address Kim Crawford Sun Stale Insurance 1090 Coral Way 623 Northlake Blvd Singer Island, FL North Palm Beach, fl (561) (661) Premium Summary Basic Coverages Attached Endorsements Tola\ Policy Premium Premium Pffimium Assessments I Surcharges MGA Fees/Policy Fees (Including Assessnil'lnts & Surcharges) $7, ($6,010.00) $3, $27.ClO $4, Location 001 Townhouse/ Nurnberof Pfolec\ion Form Canstn.1cUon Rowhouse Fam\!ies Occupied Class Territory BCEG H03 Masonry 1968 N y Dwelling Pro\ective Device Credits: Wind/Hai\ County Replacemenl Cosl Home Updated Burglar Fire Sprink.ler Shutter Exclusion Palm Bench y y None None N N N We wlll provide lhe insurance described in this policy in return for the premium and vomp\lancc wlth all applicable provls\ons of lhls policy. If we elect lo continue this Insurance, we wm renew this policy if you pay \he required renewal premium for each -....,_ successive pol\cy period subiect to our premiums, rules and forms then!n effect. You must pay us prior to the end of the current pollcy period or else this policy wi\j expire. lnsuraoqe is provided only with respecl to the fallowing coverages for which a limit of \iabft!ty is specified, subject to all the ~?nd_it~o-~~. c:i~ ~~!s.p.~-~~:. COVERAGES - SECTION I LIMITS PREMIUMS COVERAGIOS SECTION II LIMITS PREMIUMS ~-~-~!-~_9.~.-~A~. µ~~ui_n_g-. $265, $7.341.oo $ $iiloo Cov_e r.a9.~ ~~~- O\her Struc~ure $26,575 ~ov~ra!il~ -F- M_edlcal Payments $1,000 $0.00 ~o.vei~~~-.:.c_~ Person.~\ Prop~rl.)'.. $132,873 C?Ve<<iJJ~. ~0- Loss o~.1::1.s~. $53,150 NOTE: The portion otyol1r pre1nium for hurricane coverage!s: $3,671.54!~: port!on o!_y?~.~p:emtum for all olher ~~v~rages is: $8~7.4G Section 1 coverages subject to a minimum 2.0% $5,315 hurricane deductible per calendar year. -.. ~-~-~.~?~ 1?overa_g~s _su?)~?~ ~o- $? 1_5_0~_n_on:.~~1:r_i?~~e._~1:.o,n~si~k~?le) ~~?~~~?!t:_p~~~oss.. DESCRIBED LOCATION - Iha De::;cnbed Location covered by this policy Is at the above address unlei;s otherwise slated:.\090 CORAL.WAY RIVIERA B~l\CH, FL THIS POLICY CONTAINS A SEPARATE DEDUCTIBLE FOR I HURRICANE LOSSES WHICH IVIAY RESUI/f IN HIGH OUT OF-JPOCKET EXPENSES TO YOU. ' Flood coverage ls not provided by Universal Property and Casualty lnsurance Company and is not part of this policy.._s::-.r~<1#-~-~- Cou11\ersipnature Date Chief xacutjve Offlcer UPCIG \-to Oec Printed Dale: :30:36 AM 1 of2

107 c/o Universal Risk Advisors 1110 W. Commercial Blvd Suite 300 Fort Lauderdale, FL Toll Free: Claims: 800~218~3206 Declaratlon Effective 3/10/2017 AMENDED: Coverage(s), Swimming Poo!, Background Questlon(s) Service: Contact your Agent Listed 8elow Policy Number FROM Policy Period. TO INSURED BILLED Agent Code J ~---~3/~10 '/2" 0"'18~---"'12o:;:0'-'1"A"'M...,S,.,.ta"-'n'da_r_d~Ti~m~e---~~9Y~9~0--~ Mortgagee I Additional Interest 01 Agent Name and AddroS_$. Sun State Insurance 623 Northlake Blvd North Palm Beach, FL (561) Additional Interest Mortgagee/Addltlonal Interest 01 Mortgagee/AddiHonal lntere9t 02 Mortgagee/AUdUlonal Interest 03!"""\ l Polley Fonns and Endorsements Applicable to thfs Policy NUM13E:R EDITION DESCRIPTION LIMITS PREMIUMS H Y1 Homeowners 3 Speclal Form $7,341,00 UPCJC QB Limited Fungi, Wet or Dry Roi, or Bacteria Section I~ $10,000/$20,000; Sectlon II~ $50,000 UPClC B Outline of Your Homeowner Polley UPClC (06~07) Hltrricane Deductible UPCIG Spec!al Provisions- Florida LlPClC Windstorm Protei:!ivo Devices ($6,028.00] UPCIC Loss Assessment Coverage $1,000 Ho Windstorm Exterior Pain! or Waterproofing Endo1sement HO No Coverage for Home Day Care Business H _91 D!her Structures $26,575 UPCIC (06 07) Existing Damage Exclusion Yeer Built surch<ir9e $2, No Prior lnsuranet:1 Surcharge $ Personal Uabifily Increase Endorsement $300,000 $18.00 MGA Fee $25,00 Emergency Management Preparedness Assistance Trust Fund $ ~ ~ , ~---~ LAW AND ORDINANCE COVERAGE IS AN IMPORTANT COVERAGE THAT YOU MAY WISH TO PURCHASE. YOU MAY ALSO NEED TO CONSIDER THE PURCHASE OF FLOOD INSURANCE FROM THE NATIONAL FLOOD INSURANCE PROGRAM. WITHOUT THIS COVERAGE, YOU MAY HAVE UNCOVERED LOSSES. PLEASE DISCUSS THESE COVERAGES WITH YOUR INSURANCE AGENT. COINSURANCE CONTRACT: THIS POLICY CONTAINS A CO-PAY PROVISION THAT MAY RESULT IN HIGH OUT-OF POCKET EXPENSES TO YOU. YOUR POLICY PROVIDES COVERAGE FOR ACATASTROPHIC GROUND COVER COLLAPSE THAT RESULTS IN THE PROPERTY BEING CONDEMNED AND UNINHABITABLE. OTHERWISE, YOUR POLICY DOES NOT PROVIDE COVERAGE FOR SINKHOLE LOSSES. YOU MAY PURCHASE ADDITIONAL COVERAGE FOR SINKHOLE LOSSES FOR AN ADDITIONAL PREMIUM., -~ I Tiiis replaces all previously issuet.1 policy dm;larations, U any and Is subject lo all forms and '1ndorsements i'!tblchad to U1!s policy. UPCIC HO Dec 0212 Prinled Dale: :30:38 AM 2 of 2

108 case PGH Doc 296 Filed 05109/17 Page 8 of 22 SCHEDULE OF HOUSEHOLD CASH RECEIPTS AND CASH DISBURSEMENTS CASH - Beginning ofmonth M~ {V\/'Hl-' fl/:(o,l/-{,,"/, :> D Cumulative Total CASB" RECEIPTS Salary or Cash from Business I. i<o Wages from Other Sources (attach list to this re_eort) 1nterest or Dividend Incorue ~~ Alimony or Child SueeOrt -~ Social Security/PeosioruRetire1uent - Sale ofhousehold Asi;ets (attach Jist to this report) -.~ Loans/Borrovring fro1n Outside Sources (attach list to this report) Other (soecify) (attach list to this report) /(~,,J.,.. f 1 10,'IL.. f.:\ r.:11 V),) cl_ '(OO - Uc"".hl. 1 (,,().. ' Q., >r, o < I. lr>,t- /_ti A 1 ft oc> ( TOTAL Rli:CEJPTS /J.. <:i/t::i --- CASH DJSllu:RSEMEN'.fS - Alimony or Child S-uoport Payments Charitable Contributions ~- G;ns ~ Household Exoenses/Food/Clothing f,)..\! I Of; Household Repairs & Maiotenancc lusuronce (, </ 't r,cm JRA Contribution Lease/Rent Payments Medi cal/denial l 1 a"'"" ents l{'i,?..& Morhrage PayJnent(s) "}, {," " bi '!: :\ Other Secured Payments,., Taxes -Personal P(operty -~--~--- Taxes - Real &tate Taxes Other {11ttach schedule) Travel & Entertainment.~ Tuitiori/Educution ---e - iot/, o q Utilities (Electric Gas, Water, Cable, Sanitation) Vehicle EXlH~nses Vehicle Secured Payrocnt(s) U.S. T:rustee Quarterly fees - -- Professiona.l'Fees (Lelia\, Accounting)~... L.. ~\cl io. ~@J. 2ilf <./Oo Other (attacb scbedulelt-k/c,nu l>u.< IC-el? 1"'-''li 13ol I ~i.jc> ; 1../, IJJI. Gj- l (t}j ~o{l ~loo-e! (Vt',1 Coro..I 0.A-..1 ' \(. )..GRS' \,J~s+.. v.a\-v s~o [:t@f:t_,;se C[<vS) ' - /.J&.{iJ 1.zs.,:Jl}CJ,;q l'otal liousehold Disbursements ~IW> 't;~, ~ CASH - End ofmonth (h-1ust equal rcconc;ilu<l bank statement- Attachment No. 2) i 15, (,)/]o/ '"' 1:1.'& a.\\~r ' +t>j~r DO

109 Case PGH Doc 296 Filed 05/09/17 Page 9 of 22 SUMMARY OF CASH RECEIPTS AND CASH DISBURSEMENTS,; D 'Mori lb Cumulative. fvlo_rd.._ Toetl CASH- Bcrrillnlnµ: ofl\1onth {Hou~cholll) CASH- Beginning ormontb {Businl'ss) Tohtl Household Rcceints l'mal Hu.~ine.ss Receipts Total Receints. i'/-4>.'i l> '/. l' -- /).1 'ho f)_,c/?o Tot:i.I Hou~cllold Disllur~emcnts 'i3. 791,,, It --- Total Busines~ Dh;bur-scmc11ts - - Total Disbursements i-f''-'1 7q1,,,17 Ni!.'J' CASH FLOW (Total Receipts mhi\1s Total Disbnrae:ments) '6 ;J.(o,1 CASH. End of Month (ludiyidual) / {$ 1 l,c/7,01 CASH- End of Month (Business) ~ CALCULATION OF DlSBURSEfrIBNTS 11on 'Ol'.'1TED STATES TRUSTEE QlJARTERL)' FEES TOTAL DISDU:R.SEf\ffiNTS (Fr<im Abovt) 'f.;,, z.1 1,, t'l '. Ll!SS! All)' A ts: Tninsli:1nrl or l';lid fr<)rn t\!.'.bnsh ~M AHQn11t to tile HotJSchold - A~couut (i,c., Sabry l'.aitl t<:i ll~btor or Owner'~ DrilW) OJSBURSF.1\-IENTS FOR lj.s. 7RlJSTEE ll!;.e CALCULA.TlON lt,h,, 791,,/~ l ikdnrcundc.r pl'llalty of{il-rjitl')' that lhts st:i.tcmcnt 11nd the 11cco1Dp:tnyin~ ducumn}ls and n11orts :ll"c rruo and corr~~l t<j the bt.s-t of. my lmowle\\gc and belfcf /.. \ /) T.. _f.1{11 ""Y f_j'.lt/,lld w_l\, 1)VI'<. l Gw~~~ "" J l)ebl[)r's Sigm;tuu: -v~

110 ~~~~~~~ ~~~~~~~~~~~~~~~- -~~~~~- Ball11&: PGH Doc 296 Filed Page 10 of 22 Amerk<1.'s Most Convenient Bnnk FlDO l O<!!Uil\) <;1J- I(IOOOO l<im CLARl\E CRAWFORD Page: 1Of4 DIP CASE SDFL Statement Peciocl: f\1ar Mar CORAL WAY Cust Ref#: T4111# RIVIERA BEACH FL Primary Account#: T Chapter 11 Checking KIM CLARKE CRA\\'PORD Account 11 DIP CASE S])fL /.\CCOUNT 8U! 1 11MARY Beginning Balance 146, Average Collected Balance 114, Deposits 12, Annual Percentage Yield Earned 0.00% Days in Period 31 Checl~s Paid 34, Electronic Payments 8, Ending Balance 115, l)/.\ily 1\CCOUNT 1'>i.GT!V!YY Deposits \'.'.:.H3T!NG 01\TE Df!.>GRIP'f!Ot-J 313 DEPOSIT l,434.00,.,,.,., 318 DEPOSIT 2, /8 DEPOSIT 2, /10 DEPOSIT 1, /"17 DEPOSIT 1, /24 DEPOSIT 1, /3 1 DEPOSIT 1, Subtotal: 12, Checks Paid No. Check$: 2- '!ndic:a\eli; brn<ik in serial sequence or 1:heck µrocessed P,l1m\ronically anu llsled under Elco!ronlc Payments Di\1E SERl1\L Nt1. ti.mou Ni" 3/ / , Electronic Payrnents \>ostlf\ig Of~TE DESCHlPT!OM Subtotal: 34, DEBIT POS, '"" , AUT ODA PURCHASE GULFSTREAM GOODWILL R1 RIVIERA BEACH FL f-;\ 3/6 DEBIT POS, "'." , AUT ODA PURCHASE PUBLIX PALM BEACH GA' FL \-\}.\ 316 DEBIT CARD PURCHASE, *m' , AUT VISA ODA PUR ~ NORTH PALM CITGO LAKE PARK ' FL 3/6 DEBIT POS, *"" , AUT DOA PURCHASE ~ (; RESTAURANT DEPOT RIVIERA BEACH FL t-\~\ 1l.,.,.-., 3/6 DEBIT POS, '"" , AUT DOA PURCHASE GULFSTREAM GOODWILL R1 RIVIERA BEACH FL [\\.\: 3/6 DEBIT POS, '"" , AUT ODA PURCHASE WHOLEFDS PGA L WEST PALM BEA' FL \:\: \\ 3/7 ACH DEBIT, CLR SOLUTIONS TITLE BOX M"" ~;< CC\<;< clec>' /8 ELECTRONIC PMT-TEL, NATIONSTAR NATIONSTAR '"' \ 2, \MIJ(\i\ Cc'\\'; Call 1.. gqo--h3y ;2000 fo1 ;yr.hour F~cinf< hy +"hong se1 v!cf.ls (~r ccn~rhjct to v11nv'.l.trlbanh.corn

111 Case PGH Doc 296 Filed 05/09/17 Page 11of22 Ffow to Balance your Account Page: 2 of 4 Begin by atljustfng your account reglstt'!r as follows: Subtract any services charges sho\vn on this slate1ncnt. Subtract any antonu1tic pnyn1ents, transfers or other electronic withdrawals not prevjously recorded Add any interest earned ifyou have an interest~bearing account. Add any auton1atic deposit or overdraft line of credit Revie\v all.\vithdraw als shown on this staleu1ent and check lhen1 off in your account register. Follov" h1sln1ctiorn; 2-5 to verify your ending account balance, i. Your ending balance shown on this state1nent is: z. List belo\v the runount of deposits or credit transfers \Vhich do not appear on this staternenl Total lhe deposits and enter on Line 2. ' Subtotal by ad<ling lines l and 2. 4, List belo\v t11e total.an1ount of wiu1dra\vals tbat do not appear on this staten1ent. Total the Withdrawals and enter on Line Subtract Line 4 fron1 3, This adjusted b~_~ce.sh(>ltld equ<jl youi' account balance, -.F"'\ ~ O!lPOS!TS HOT ON Si'ATEME!J't OOLl.AflS CENTS WITHDRAWALS NOT OH STATEMENT --- DOLLARS CENTS WrTHDRAWALS N01 DOI.LARS CENTS ONSTA1EMEtlT --- FOR OONSUMER AOCOUNTS ONLY - IN CASE OF ERRORS OR QUEl5TIONS ABDUi YOUR ELEGTRONIC: FUNDS TRANSFERS: II you m1ed lnfonnalfon ~bou! a11 e\ec\ronic lunri troni;fer or if 'fil!j beliwo lho11> Is an e1mron Y<>llr banksla\ementcr f60afplm!31ing lo an el~ctian!g IU11~ trnnsl~r,!eh,11l 011e lh11 bank irnmv<llille!y 31 the phone numb~ li!;tod on ihe l!o!l\ (ll Your.lfol\'lontor.\\lril!!: to: TO aank, N.A., Oep<isll Opernllons Pept, P.O. Box 1377, Lewiston, Maine 042' We m1mtheartro111 yoll n:i latarthan sb;ty {60} calentlar dill"" J11\n1wo_so11t you lhe first slatamentuponwhir;h1.he llfroru1problem1irst11ppcarct1. Wilch ctil!laciin!i tha Bahk, plaass e~-plal11 as dearly as \'OU Ga!JVl\t{\'OU Wlieva H1cta Is an e1mr orwh1 mma!nformall1m ts needatl. Please lnclud11: Yournonlll 'ilnd account nurnlmr. Adoscilption ofll'l9 nrrarortrnnsaciinn yeti ara tll\5u/c abm1t. lhn do:la1 aniount:md tlate 0:1h1: suspecilld error. WhM maldng a verb;i\lnqujry, llie Ba11k111ay ask that You sand u~ \\1ur cornplalntin w1ltlng wl!llirt len (10} buslnos.s- day& aftor fuo il!st1olnphons call. Wl'Will lnvasugala your wrnp\a\ol 1111dwlll wrr11itt any 11uor p1omplly. Hwa!~ke nlora lh~n foll {to) busl111:ss days to do t\1is, \'/Et Will credit your acco\mlfor Oui amounl you thlnk!s h1 error, 'o thah ou havo \hr uso ofth& motiay durinu f11e lln\a it takes. io.mmp!ele- our lnve5tiga\ion, \NT!';REST Hoitce Toi<il tnlere~tcredila(i b1 U111 oankto \'011 lhi& yeanvill bl! raporled by lhe BanktotM lnl&mlll Rnvamw S:aNlw and Sl<'l\o im(1111thori\ie$_ l11e umount lo b1;t rni;.~rtedwill h& reporlml sup3'r.itoly loy(l\j hytt10 Bank. FOR CONSUMER LOAN ACCOUNTS ONLY - BILLING HlGHTB SUMMARY Incas~ o!enors or aue~lons /\bout Your Gilk Uyo11 ti!lnk\'l)urbill ls wrong, or ii you need morn ln!nrma!lon ahou\ atlansacillln ori your hill. \VfllB Us at P.O. Sox 1377, l&wiston, Mo in~ 0424a.tey71 ~s soon as ~o$5lbla, We musthe;u-fmnl you no la~r lhiln "'WY (00) da\'s a!lsrwowntyo11um F'!R$T b\u on-.,.,hleh Ille euo or 1>1oblem iop~11;i.ra~. You wn 1elephune u~. bu\do!nn ~o\'11\l nol pre&erv(lyour riqhls. In youf!e\tm, givu u,; Iha io\luwinn inlorma1l<m: Your name and agi;oun\ n~mber.. The dollar amount oftha s11sf"!iittcd emir.. D~stlibe the r.nor ;.ml ~laln, If you c::in, why you balisw1 therll lr.-::111 error. If you noe!l morn!mo1mauon, daootloo lhll iteh"i you 111a unwre about. You do 110\ h~velo p;i.y:any amount in quesuon v.t1llewourt> lnve&uge\in9, butynu aw ~Ill obli1j3idd lopaylhg p~rt~ (Jfyourbl\l lhal me not In quesllon. Wh\!u 11c \lfl'e..uaale your queshon, we c:mnol reportyou as ~al\nquont orlaka any 3cilnn to i:olloctlhe amount \'llll quesllon. FINANCECHARGES:Althounh \he llan\; usot>llle Oally Gal"ni:e 111alhntl lo i:alculate theiiuan~e t;\ia111eon your!';',onaylln~/ovardralt Pro\e.,liM accqunlrjie (;,1111 0DP'' or "OD" WfiHG Jo 01ardra1t PIO!ecUon), \Im l;lankdleh;.\ooss thu A'lerage Daily 6alam:a.1 of! \ho plli;odio sta\ome-nl-as Ell\ aaslcr molllodfo1~ 1 ou IQ oa1nul11\e lhafinongc c:horge. TI1e tin:mce c:har11e beolnsloaccfll!l on U\e do\!;l adv:im;0s and o\horueb\\s nw l'<>l'tall to \'Ol!fa.:count ;rndwill contjnub unhl U1e balance has bo(lo paid il1 l11t\. To compute \ho flmm.:o char(le, rnv1uplylh11 Avor.111e 03\\y Da!anca timu~ U1e Ony&in Pl!!iod limes lhn Da\11 P01iQd!cHate {asli5'i!d ln the /\ccounlsunima1y sacllon on tneftnnl of!he fi\a!eman!)_ 'Tha Avaraoe oa\lybalanc!! I~ cn 1 culalct1 bya<l\llnij lhe balance for a;ich day of \he blll~l[j tydo, lhan divlillng thefo\al llalanca by!he rn1mba1 ofoays in the Bil~ng ()/c!s. ihe dallybalan~eit> lho bah111c&furlha dnyulic1 aclvanccs h;wb beei1 added ;111d pnym9tltsqr cred~ haveliaan su'o\lacted Pl\ls or ml~us <ITJI' olh~r adjmrtments \hat rniohl tiavn 0GC!JITT1d thot day. 1horn 1~ nri or;i.c~ ~erlod durin{jwhioh no financa ohar1111 ilcc1ues Finance chaine BdiHstinenls aro lncludutl in your loin\ finance ~hmge.

112 lit!j ~k' pgh Doc 296 Americ«'s Most C:onvenlent B~nk 0 Filed 05/09/17 Page 12 of 22 KIM CLARl<E Cl1AWFORD Page: 3 of 4 DIP CASE SDFL Statement Period: Mar Mar Gust Ref#: T-### Prhnary Accotint #: Df\\LY /\CCOUNr i-\.ct!'jity ~~~~-~~~-~~~~ Electronic Payments (continued) POS.T\M(~ D/\TE 11f':SCR!PT10N /.'d\~o!jnt 3/8 ELECTRONIC PMT, TEL, BANK OF AMERICA MORTGAGE ""76220 ('ilo<'\«r«jf 2, DEBIT CARD PURCHASE, -"' , AUT VISA ODA PUR 1.00 WPB PARKING METERS WEST PALM BCH *FL ~t..<\"-t P j 3110 DEBIT POS, ""' , AUT DOA PURCHASE WAL MART SUPER GEMTER LAKE PARK FL \>t \'r 3/10 DEBIT CARD PURCHASE, '""45' , AUT VISA DOA PUR MEDITERRANEAN MARKET WEST PALM BEA' FL \\\'I: 3110 DEBIT CARD PURCHASE, "'" , AUT VISA DOA PUR 1'1.63 LYNORAS OSTERIA WEST PALM BEA' FL 11 ilr 3/10 DEBIT POS, '~'* , AUT DPA PURCHASE GULFSTREAM GOODWILL R1 RIVIERA BEACH" FL \\\\ 31'13 DEBIT CARP PURCHASE, "'" , AUT v1si-; DSA PUR fl J;,;,, DON MEYLER INSPECTIONS 'FL Il ht.c<c<h(.< l-'71"' 3114 ACH DEBIT, UNIVERSAL P&C INSURANCE ""-170'1-2549,i 10'',<5-~{::t~ 1'~~ 1, /15 DEBIT POS, , AUT DOA PURCHASE Cc«<.\ vj"''( WAI.GREENS STORE 1515 NF WEST PALM BEA' FL lh J. 3/17 ACH DEBIT, WRIGHT FLOOD INS PREM DEBIT CARP PURCHASE, '*"''45148'122233, AUT VISA QDA PUR GARDENS DRUGS PALM BEACH GA"' FL {'\\-.e<.\! 3/17 DEBIT CARD PURCHASE, ~'* , AUT VISA ODA PUR NORTH PALM CITGO LAKE PARK 'FL ~ <1..) 311"/ DEBIT POS, m" , AUT DDA PURCHASE 8.56 PUBLIX RIVIERA BEACH' FL \-\\~ 3/20 DEBIT POS, "m45' , AUT DOA PURCHASE \.\ \~ PUBLIX PALM BEACH GA FL 3/21 DEBIT CARD PURCHASE, '*'" , AUT VISA DOA PUR 2.00 WPS PARKING METERS WEST PALM BCH *FL?ccc\i..( 1'-'i' 3122 DEBIT pos, ""' , AUT ODA PURCHASE PUBLIX RIVIERA BEACH* FL \-( fk 3127 DEBIT POS, *-""4ii , AUT ODA PURCHASE MI~ PUBLIX PALM BEACH GA FL 3/27 DEBIT CARD PURCHASE, ""' , AUT VISA PDA PUR ROCKET FUEL WPB NORTH PALM BE' FL ~<:ti 3/27 DEBIT POS, '"" , AlJT DOA PURCHASE Im GULFSTREAM GOODWILL R1 RIVIERA BEACH' FL i-\ i-\ ~ GULFSTREAM GOODWILL R2 JUPITER FL f\ll: 3/27 DEBIT POS,,,.,*45' , AUT PDA PURCHASE /28 DEBIT POS, "'*' , AUT ODA PURCHASE PUBLIX RIVIERA BEACH FL 3129 DEBIT POS, """ , AUT ODA PURCHASE GULFSTREAM GOODWILL R1 PALM BEACH GA" FL

113 Case PGH Doc 296 Filed 05/09/17 Page 13 of 2.2 Bank America's Most Convenlel\t Bank"' STATEM6NT or ACCOUNT KIM CLARKE CRAWFORD Page: 4 of 4 DIP CASE W SDFL Statement Period: Mar Mar Gust Ref#: T41#11 Primary Account# : DAILY ACCOUNT ACTIVITY Electfonic Payments {continued) POSTlNG DATE DESCRIPTlON AMOUNT 3/30 DE'BIT POS, -m , AUT DDA PURCHASE \-'< \-\ PUBLIX RIVIERA BEACH' FL DAILY BALANCE SUMMARY DATE BALANCE i4a;aw.zo 3/2 112, , , ,T , , /13 113, /14 112, "112, DATE /20 3/ / /29 3/30 3/31 Subtotal: 8, BALANCE "113,197:37 113, , , , "14, , , ~ 114, , Call for 2.4-hour Bank-by-Phone services or connect to

114 case PGH Doc 296 Filed 05/09/17 Page 14 of 22 MONTHLY OPERATING RllPORT ATTACHMENT NO. 2 ln))lvjdual BANK ACCOUNT RECONCILIATIONS Banlc Acco\intluformation Account Account #1 #1 Nnu1e ofba.nk; Account Number: Plll[)Ose of Account (Busincss/Pl"lrsoua1) 1-rD R1. v P.t(S<nvd Type ofaccount (e.g. checking) C,,k"' (l1 M( I. Balance perbankstatcmcut / /S:e<.i3.b] 2. ADD; Deposits not credited (atlach lfal to tl1fa report) 3. SUBTRACT: Outstanding Checks (auii.ch llilt)?,a')o(j 4. Other Reconciling Items (iituch list to this n:port) 5. I\-fonth End Balance (Must Agree with Books) / 1 :1.,/<.j?,vi TOTAL OF ALL ACCOUNTS (I J.., (L('J,Di, Account Account #3 #4 t Note: Attach a cupy of the bank statement and bank reconciliation for car.b account. Investment Account lnformation Date of Type of Bank I Account Name /Numb;er Pu:rcbase Jnstt-un1ent T IJ "'"'"'e<'.rlro)\,,//!>. Cb..",,_,J~s<;-rnJ"- ' ' Purehao;e Price Current Value 9,4?-. Note: Attach a copy of each investment account statement

115 / ; { [ Ame11r&il:ll'ade ~~~ Statement Reporting Period: ~-Q~1~t; 01101/17 ~ 03/31/ TO AMERITRADE DIVISION OF TD AMERITRADE INC N PD BOX :2209 N OMAHA, NE Q TD Ameritr.:de Clearing, Inc., Member SfPC,, li) "' Statement for Account# K!M C CRAWFORD 1090 CORAL 'V'JA Y RiVJERA BEACH, FL OJ ('ti.. ~ t Current Prior, Perlod o/o Estimated Estimated r- -~~.Y~~:7.~-~ Value Value Chanfi.e Chenge Income Yield Portfolio Allocation ~ Cash ($2.00) ($2.0D) S S g, lnsrd Dep Acct ODA) i7.i Monev Market ~ Short-Balance 17.5 /~,-92 Stocks %.LL Short stocks Fixed Income ~ Options ~ Short Options o Mutual Funds O Other :c Total $7.42 $5.39 $ '3/a $ ~ (.') 0..,;, gf.@it#ijijfilii?li i!hi!h4$mmiiif#i i4m *1U ~1utfi=1'# A n.7@1ln!.1$1*4@'6i J I N ~ Current YTD Reporta~te Reportable YTD rl..._._ ,.. _ ~Opening Balance ($2.00) ($2.00) tncome Cost Basis t:s Of !"" $ ccl Securities Purchased Dividends s $ $ Unreallzed Gains U Securities Sold Interest Unrealized Losses Funds Deposited Other funds Deposited/(Disbursed)'fT 0 Funds Disbursed Expense lncornef(expense).,.,.c:i Income lnterest Securities Received/(Dellvered}nv 0.00 Expense Faes '''To 1;iew rea!ized gains arid losses for your account. logln ;iit other Other and visit NIY Account,. Gain/Lo-ss Closing Balance ($2.00) ($2.00) Net $0.00 $0.00 $0.00 Non 82.5o/c Cash

116 (" (' Statement for Account# 01101/ illlillld~~ HJ!ll&G~n~~iS 1111 Symbol! Current Market Purchase Cost Average Unrealized Estimated N Investment Descriptlon CUSIP Quantity P'rice V.alue Date Basis Cost Gain{Loss) Income Yield N Stocks - Cash 0 <D ALLIANCE ALLP 100 $NA $NA $ - $ $ $ - <-l PHARMACEUTICAL CORP gs, COM ff_ CEL-SCI CORP CV{l(i COM r-- - ~Tota[ Stocks $9-42 $0.00 $0.00 $ % "' ~ Total Cash Account $9.42 $0.00 $0.00 $0.00 O.Oo/c. 0 u CJ ' LL Trade Settle Acct Transaction/ Symbol/ Date Date Type Cash Activity" Description CUS[P Quantity Price Amount 6aJance m gj Openfng Balance ($2.00) o 03/27/', Cash De!lvere::I - Other THINKENGINE NETWORKS INC THNKQ 1,500 $ 0.00 $ - (2-00) a COM Cl REMOVE WORTHLESS SECURITY Auto Reorg#.:334320[REMOVE I WORTHLESS (') O...C!Osing Balance ($2.00) ' ~ For Cash Activity totals,re[erto the C~lt Activity S1.1mITTary ori page: one o.fyo:ir statemanl "' - hjll'r. ~... ~ '."i?reakpdints (lj ~ertain purchases of Class A Mutual Funds may be eligible for breakpoints on, and vvatvers of, the sales charge. To learn more about breakpoint discounts, go to u1ttp:/lwvn1.finra.org/industry/issues/breakpoints. For more information on waiver eligibility, please refer to the fund prospectus. FINRA INFORMATION Required Annual FINRA Information: Investors may request dfsc!osable backgrour.d Information on any U.S. 1icens&I broker or broker-dealer via FlNRA's ~rokercheclc.. a free onjine tool Visit brokerchack.finra.org. Additionally, Fl NRA has a brochure which describes fhe BrokerCheck program. You may request this broohure elther through the F!NRA web Slte VNNV. finra.org or by camng (800) , ihe BrokerCheck Hotline Number. ( ( \~. { "

117 Case PGH Doc 296 Filed 05/09/17 Page 17 of 22 MON'lliLY Ol 1 ERATING REPORT - INDIVIDUAL ATTACHMENT NO. 3A Name of-bantc Account.NUhlb(;!r Purpose 9r ACcbUri~ (Personal} Type of AC otttit (e:g., Checiklng) Che.cl<, Date of GASH DISBURSEMENTS DETAILS - HOUSEHOLD ff) Kft;.Ji:'. U.Q_(S, CJY1.(?/ -----f'._ia"' <:, ~1rJc1 ' Number Check Payee Purpose or Description Amnunt z<. :: 11"7 1')A-JJ i! 1>-J V Al H..f?<t (Ci 'i?4-l /ti.1. (.,<!. l F. e 1;---e,.,, Vv\8( r..-, 4.4 e. -,, Or'i ~q,, -;!'IA.,,,,,.,.@+-I l,,...i l'f.m-1 rt'-"o~tje.l,(-$ r--e..e ~ i...j.-00._ I ' -".L. -~ I A. (b\.\d.) I J t l I TOTAL $:.it/.. <I tj{) If any checks written this period have not been delivered to the payee, provide Oetalls, including tha payee, amount, explanation for holding check and anliclpaled delivery date of check.

118 N N II.. Client ) 1) I I I -~ j Roth IRA account ~ 0 Kim C. Crawto rd ~ co.-1 " Ol "' m -.,. Vangt!.iiarei.f Services: CL Account overview $10, Tctal account.va\uia. a$ of-marcb '.31; 2\)17 I'..., Ol 0 Year-to-date inoeome Retirement swnmary -LO Taxable income $ contributions $ Nontaxable income M Cl distributions 0.00 ~ u::: Tota! $~7.01 Balances and holdings for Vanguartl funds "' 01 N u 0 Cl Beginning on January 1, 2012, ne 1 N tax rules on taxable tnonretiiementl mutual fund accounts {exc\ud'mg money market iunds) require Vanguard to track cost basis information for shares acquired and subsequently sold, on or after that date. Unless you select another method, sales oi \lat1f;uard mutual funds_, bu"t not ETFs, will default to the average cost method. For more [nforma1ion, visit vanguard.comfcostbasis. I Average pricl:'; Balance on Balance on (.'.) Symbol Norno Fur.d ~rid account persbare Total cos~ 12/31!Z016 03/31/2017 CL VflNX 500 Index filnci Irr; $ $ ' "" N $111, $10, Ol co N "". f>,ccountattivity,f ~ Vang.,ard fu_nd~.... '.. '. "' U1 500 Index Fund Inv m () Cofru"ibuti0l'.s Distributions o:r.1ldends $ $0.00 I $4151 ' i \ To~I shares Tr~nsactiori Amourit Share price '"""" trarisac\ed owned \talus "'" Beginning balance on 12/31/2016 $ ,436 S"i0, " ~ ~ ;;; E ;;:; " 0 l 'il g $ t1 ~ 0 ~- i " I < s g ; ~ :: March 31, 2017, quarter-to-date statement Page5cf6

119 ii m ~ \~Y:E 1.!IT:\gtlRJ'~lftr1r' N N 0 Ol '"" "' o._ "" "' Roth IRA account l<im C. Crawford Account activity for Vanguard funds continued 500 Index Fund Inv continued ~ Dat~ Trzmsac<1on An;ount Share price (r~risaeted Ci ;;:; c--,--..,,, Income dividend.961 $ ares ro>al sh~res Client Services: B ;=! r,: :';; '.t ~ t: ~ ~ 8 owned Valu<; ~ ~ 8 0 Ending balanc.e on 3/31/2017 $ $10, f::; -0 ii "' "' Ol N 0 0 Cl " I CJ o._ "'1 N m OJ N._\ '"""' CJ :fl u March 3 ~, 2o i 7, quarter-to-date staternent Page6 of6 ( {. \ /

120 m,;~~ ) ) ) I I I Vanguard' ~ ~ C!lent Services: 801)-() N Traditional I RA account e N " 0 Kim C. Crawford ~ ~ 0 iii N e :;:: QJ OJ ~ ~ Account overview $18, CL "' g Total account value as cf March.31, 2017 ;:::; I ~ Ci Year~to-date income Retirement summary 0 ~ l?i Taxable lncome $ contrtbutions $0.00 g 0 Nontaxable income o; distribut\ons '!! Total $85.18 ii ~ Balances and holdings for Va11guard. funds <S) m N Beginning on January 1, 2012, new tax rules on taxable (nonretirernent) mutual iund eccounts (excluding money market funds} require Vanguard to track cost basis u information for shares acquired and subsequently sold, on or after that date. Unless you select another method, sales of Vanguard mutual funds, but not ETFs, will 0 default to the average cost method. For more inforrnation, visit vanguard.comjcostbasis. 0 Average price Bal<lr!C~ on Balar:o!! on I Symbol N1.:me Fund and accoun.t per shoire Total cost 12/31/20"'.6 03/31/2017 l') CL VFIAX 500 Index Fund Adm $17, $ (") ' N $17,508.4& $18, m gj ;!; Accoifrlt ac~ivityforvanguard funi!s:...! ~ QJ 500 Index Fund Adm ~ ill () Contributions Dlstributkms Dividends S0.00 $0.00. ', $85.18 ' Sbares Tota1 shares Date Tran~aolion Amount Share price tr.;nsacied OVYl'led V:a!ue Beginning balance on 12/31/2016 $ B4.758 $17, " r. 0 ii ~ ~ Mar ch , ql1arter-to-date statement Page-3 of6

121 ~ i..., ~,!_~ ' ~ c ~.,,,,,.. :r,:i~i" '"'1~0.0t!'i'hl_i!J; Q,.,\l,?.J.li1. W.<:.. ~<!: G:'1.ii:.. '\:;;;~ = -~ '0 w N N 0,--! N C.l it CL Traditional I RA account Kim C, Crawford Account activity for Vanguard funds continued 500 Index Fund Adm continued Client Services: !'- Sl1ar~ Toi:3lsl1ares,--! "\ransacted o\11/rl!;:d V<i\i.:e a Ci ~- -_!~~ ~-- ~~me price '2 03!21 Income dividend $ ~ in 0 Ending balance on 3/31)2017 $218.UG $18,56825 G -a.92,., R; ii "' <J) N Ll 0 0 I c.:j CL N "" "' 00 N ~ C.l gj (.) :>:: -~ ~ ~ " f E s.o " March , q1.iarter-to-date state111ent ( ( f \ Page 4 ofs

122 ~ i ~ ~ Tf"'.-.. 7'1.l '""'''m M:. f.'' ;1 P ~~-&J1t!!~.~G:±i'lJ 'tbfl :;_.,(1 Client Services: N Ṉ a N N ClJ Ol Statement overview $29, Q_ "' Total value of all accounts as oi' March 31, 2017,. """' Value ~ri Value cm V:olu:?cn Oi Accounts 12/31/ /31./2017 Asset mix CZ/ Q L~ ffi!i 100.0% Stocks --- $29, CTS 0.0~{; Borids l<im C. Crawford... " ""'.0!2 Traditional lbaaccount $17, $18,56$.25 ii Q.0 /o Short-term reserves 0.00 Roth!RA account $10, $10, O.Oo/o Otller 0.00 (JJ Total $27, $29, crj $29, N Your asset rnix percen tages are based on your holdings as o f the prior n1on1h-end. "a 0 I ('.) Q_ "' N crj ro N._:,...-! ClJ gj u 1\-iarch 31, 2017, qunrter-lo-dat2 staterr1ent ( ( ( Page 2 of6

123 Case PGH Doc 356 Filed 09/22/17 Page 1of3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION INRE: Case No.: BKC-PGH Chapter 11 Proceeding CRAWFORD, KIM C. Debtors. NOTICE OF FILING The undersigned, Brett A. Elam, Esq., does hereby file this his Notice offiling Trust Account Records Pursuant to the Order to Show Cause (DE#347)1. I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this Court set forth in Local Rule (A). I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by CMIECF on this 22"d day of September 2017 to: Adam A Diaz on behalf of Creditor BANK OF NEW YORJ( MELLON adiaz@shdlegalgroup.com, southerndistrict@shdlegalgroup.com Brett A Elam, Esq. on behalf of Debtor Kim C Crawford belam@brettelamlaw.com info@brettelamlaw. com;deanna@brettelamlaw.com; lynn@farberelam The Order to Show Cause required Brett A. Elam, Esq., to file all documentation reflecting the receipt and disbursements of the funds received from the Debtor, Kin1 Crawford. Currently, the full account statements are being sent to Brett A. Elam from his bank, but they have not been received as of the deadline to file this document. Coupled with the issues as outlined in the Ex-Parte Motion for Extension, the undersigned has been unable to obtain the full records to satisfy the Court's requirement. The attached docun1cnts run from March 1, 2017 through May 15, However, the attached documents are all of the docu1nentation currently in the possession of Brett A. Elam. The docu111ents are being filed to show the Court the undersigned is not atte1npting to circumvent its Order, but is just not in possession of the full responsive doeu111ents. However, upon receipt of the full account statements from his bank, the undersigned will file then1 with the Court. The docu111cnts should be received by the latest Monday or Tuesday or next week, being Septetnber 25 or Septen1ber 26.

124 Case PGH Doc 356 Filed 09/22/17 Page 2 of 3 law.com;adamfarberlaw@gmail.com;brettelamlaw@gmail.com;elise@adamfm berlaw.com Vivian J Elliott on behalf of Creditor Nationstar M01tgage LLC velliott@logs.com, electronicbankrnptcynotices@logs.com Heidi A Feinman on behalf ofu.s. Trnstee Office of the US Trnstee Heidi.A.Feinman@usdoj.gov Michelle Garcia Gilbert on behalf ofcreditor Banlc of America, NA mgilbert@gilbertgrouplaw.com, bankrnptcy@gilbertgrouplaw.com Kevin L Hing on behalf of Creditor Nationstar Mortgage LLC khing@logs.com, electronicbankruptcynotices@logs.com Amy M Kiser on behalf of Creditor Bank of America, NA bankrnptcy@gilbe1tgrouplaw.com Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov Ashley Prager Popowitz on behalf of Creditor Nationstar Mortgage LLC Ashley.popowitz@mrpllc.com, flbkecf@mrpllc.com Anita Rasul on behalfof Creditor The Banlc ofnew York Mellon flea The Banlc of New York, as Trustee for the Certificateholders of CWALT, Inc., Alternative Loan Trnst , Mortgage Pass-Through Ce1tificates, Series arasul@shdlegalgroup.com, southerndistrict@shdlegalgroup.com

125 Case PGH Doc 356 Filed 09/22/17 Page 3 of 3 and by regular U.S. Mail on the 22"d day of September 2017 to: Carlos Cerezo 166 San Remo Dr Jupiter, FL Brian K McMahon 1401 Fornm Way 6th Floor West Palm Beach, FL BRETT A ELAM, ESQ. Attomey for Debtor 105 S. Narcissus Avenue Suite 802 West Palm Beach, FL (561) (telephone) (561) (facsimile) BY: /s/ Brett A. Elam BRETT A. ELAM Florida Bar No

126 Case PGH Doc Filed 09/22/17 Page 1of2 SeacoastBank Business Online Banking Activity - Deposit Account Report created: 07/13/ :31:08 PM (ET) Account Information Account *7647 Current balance: $3,03 Accessible balance: $3, Closing ledger balance: $3, Transaction History Date range: 3/1/2017 to 5/15/2017 Transaction types: Detail option: All transactions Includes transaction detail Post Date Reference Additional Description Debit Credit Reference Calculated Balance BOOK TRANSFER DEBIT 05/11/ REF L FUNDS TRANSFER TO DEP $2, $28, FROM BOOK TRANSFER DEBIT 05/11/ REF L FUNDS TRANSFER TO DEP $6, $30, FROM 05/11/2017 DEPOSIT $1, $36, /11/2017 DEPOSIT $1, $35, BOOK TRANSFER CREDIT 05/11/2017 REF REF L FUNDS TRANSFER FRMDEP $4, $34, FROM 05/11/2017 DEPOSIT $5, $29, BOOK TRANSFER DEBIT REF L FUNDS 05/08/ TRANSFER TO DEP $1, $24, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT 05/08/ REF L FUNDS TRANSFER TO DEP $3, $26, FROM 05/08/2017 DEPOSIT $3, $29, BOOK TRANSFER DEBIT REF L FUNDS 05/04/ TRANSFER TO DEP $2, $25, FROM MOBIL ETRANSFER 05/03/2017 DEPOSIT $5, $27, TO ACCOUNT NO MISCELLANEOUS DEBIT 04/28/2017 TO ACCOUNT NO $0.42 $22, /28/ INTEREST CREDIT $0.42 $22, BOOK TRANSFER DEBIT REF L FUNDS 04/25/ TRANSFER TO DEP $1, $22, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/25/ TRANSFER TO DEP $1, $23, FROM MOBIL ETRANSFER

127 Case PC l=l Dee Filed 09/22/17 Page 2 el 2 Post Date Reference Additional Description Debit Credit Reference Calculated Balance 04/25/ BOOK TRANSFER DEBIT REF L FUNDS TRANSFER TO DEP $1, $24, FROM MOBIL ETRANSFER 04/25/2017 DEPOSIT $1, $25, BOOK TRANSFER DEBIT REF L FUNDS 04/20/ TRANSFER TO DEP $ $24, FROM MOBIL E TRANSFER BOOK TRANSFER DEBIT 04/20/ REF P FUNDS TRANSFER TO DEP FROM MOBIL $1, ~) ETRANSFER BOOK TRANSFER DEBIT 04/07/ REF L FUNDS TRANSFER TO DEP FROM MOBIL $1, ~ ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/03/ TRANSFER TO DEP $3, $27, FROM MOBIL ETRANSFER MISCELLANEOUS DEBIT 03/31/2017 TO ACCOUNT NO TO ACCOUNT NO $0.52 $30, /31/ INTEREST CREDIT $0.52 $30, /28/2017 BOOK TRANSFER DEBIT REF L FUNDS TRANSFER TO DEP $ $30, FROM FEE F OR CASANAS 03/28/2017 DEPOSIT $1, $30, BOOK TRANSFER DEBIT 03/20/ REF L FUNDS TRANSFER TO DEP $ $29, FROM BOOK TRANSFER DEBIT 03/20/ REF L FUNDS TRANSFER TO DEP $ $29, FROM BOOK TRANSFER DEBIT REF L FUNDS 03/20/ TRANSFER TO DEP $ $30, FROM MOBIL E TRANSFER BOOK TRANSFER DEBIT REF L FUNDS 03/20/ TRANSFER TO DEP $4, $30, FROM MOBIL ETRANSFER 03/07/ CHECK PAID $2, $34, BOOK TRANSFER DEBIT REF L FUNDS 03/03/ TRANSFER TO DEP $2, $36, FROM MOBIL E TRANSFER 03/02/2017 DEPOSIT $34, $39,408.28

128 EXHIBIT 3

129 w:.ifflt:l't A. E.L \M 1 p,_ti..., ~ovt..~rnbi:r 6, 2017 vill ele~tr cmk mllil LGonzm lezi:a}floridaim r.o rg Limla I vclis>c Grntzalez I] 00 C1.mr,,rd Tc1 t llce S1liti3 130 Sunrise, FL 1:nn R ~: Tile IJodda l'tir \,_Brclli'.I" hlam, E"~11 Case No.: 20 Hl-5Ct326 {I 5C) I om i11 rcci. ipl ol'ym1r November/ cntc>pomkncc rdmei:l 1,0 lb«cot11ph1in1 Hied by ihc Florida B~r as a remit of~he D1der entered in the Bankruptcy CourL [have reviewed yom con'csp.:..}nc.jencl\ an~ \i. ilj t1!5i]-.\t)nd bclov1,1,.r h.> i.:vc\ cr 1 prj.urr to fcsponjing tu. lht t~~ourr~ llnding 1hr1i lirnd~ were improperly dlshursc<l from Kim L Crnwford'sf''Crawford") [:ltlbtm -ir1-posses~ion,1\ccounl f"'.j)jp 1\ccounf'}i i \Vnntod to anj~\vcr!hi..~ onjg qut:::i~lon po:c:cd ~n y(jur Nuvt~r.nbe.r 2 1 2f)17, cdrrcspondcnc-c, Hrc Dll' A~counl fs an account D11c1i1~cL conlrnlkd,,mrj rniiil!lained hy H ChHpt<lr 11 dd>t>li'. llj,_ ll!d1 l huve 1iri 1Kce:;,;_ Tile $.)4,40{~.00 chl'.'ck, to which the Cot.ut referred and nbciut which }'f~u ~nquircd! 1i-\las. \\ ritten~ signt:u, and rcni::k. i\~d to ine by c n:r1;vt:r:-rrj, rne check \Vas f(lf attidit'.iey~g foes eimwd during my firm's rcprcsc11ti1!ion of CrnwforJ in lwr Chapt0r 1 l bmik rnplcy. UiJOn receipt (>f the fund;,,! t!epusirnd 1bcm irill\ my tnist accmm111wt1iting Bankruptcy Court apprm al. f i(~v.'c\ cr, iih:4.ed l.ll)(j.h Ihe 1!nlC re-.en1 ds encltlst: d.vith 1 1ny Elesp.;:~nse tl~1 r::xhi bh "'/\!!~ ~t is clear tj1c auorncy foes hml been earned. Morl'Ov r, based upon my nanl;niplcy r\ngngcrncnt l.ctkr, ~ < opy ofwhkh is also enclo~;ed ~s Exhibit "B" 1.!he foes were ctr!'nctl upon r<~c~ipt. As such, ii \\'fl.i, <lml rdv:ay,~; has he.an~ tny Uf1d{!rstnndlj~g receiving Jiayn1cnt fbr pos~.,.,petitlon atton10y's tccs prior to 1>h1:dninis rlankrnp1cy Coul1 appmval i~ not an ethical l'iolaiinn ofthc Rule,, Regulating lhc Florida Bar. llnd I known then L~e repcrcussim1s of 01cccpling paynh:nt prior lo obtaining llankrup~cy Cu11n nppmvi1i,! wou~d nv11 have ulilizc:d 1he fe<j>.. lh)lwver, at the.!lone I "'ms unaware it might ill' c(mskfor1xl an c11ii( til vi<>iatkm hy lh,' Fk ri<fa lli<r. AddilionriHy. I spt>ke with eollcag3ie,; of mine about the suhje.ct, and these colkaguc11 shared my vkw. ln fo(;t, thlc colk aguc rdt:r~ticcri" Cnniinuing Legal l:-\lm:ali1\n s1:minm by Shr.:lin 'fom11, hs 1.. s11ppo11ing rr1}' view of the i;rnuc. Iii~~ i:'n1:'lu:s.~d (llpy is lh( url'.dgncd \' -.: r..:,1~~111lf~h U11nkr 1tph.:~.. 1.~:111~;1g1.i-111t}11i1 l,l)hi,:i', \ltlijeh ('1',f~~'ford did fijgn J:itn.:, 10 lh~ nn1uro nr th~s Rcspti n:s.c, ::irid r.ho::: 1ln1c~hlliK' i:t \\ 1 :J.i-; co111pli:ted, I tun ::idu lui:uling lh~~ i:.:-;:e1,.:1.1tl..'...;.t 1_kw;~1~t1;;Jnt l ln\vc 1 1cr, ~ dn no4 t.hlnk lbl :rc \'>'ottld 1 h9 a rl~!oij,)i}l,f L"l<J,.to+vhc iherr ~S: Vorr41ne: 11t 1 'j'if.."s i!ii:~ ulj11y i~lgn{!d i t1 I, 1.., I, I,,. I f-,1..,, ~,.,..>.>...--':!\El,-.,;-.;1>.~ef.'f'T;uu... r. '-'-"" cou COMpOGi le 'i~ 11 // 1 /l Dfl LiTC,.,,...J1/1 1 N C:(.11.,1 r:.xh,-rii r lfj.~ ~,(.; U1H i\'/1.f.;'(;l'~: 1 :IU'.;;,.".,\!~HUE. 'J.1.l:Tt.:'l(!;~ C::. D '//!> :~. I l'/!.. 1. f il i' F_.>:, <: 1"! F L. (':':!I :,,<:., J :~. ~ 1.\ I 3

130 r::rkt't' /lo., II.LAr.1.. P.A. "The Lnw 0 ffi ces <ef Bmtt A, Elam, 'I nmt Accnuntt'', and the ~"'"1111H nwnber is I 0 l , I have nls.1> e1wkis.ed a c<\py of lh<' liim7lfa1:tcd Trust i\ccount bimk records nc1 Exhibit "C", which were filt-.:1 with the Bankrup<tey Court Sep1ember 22, 21f 17. I w1ml1i lil;t: l'-1 l)lllll! u11i the bank rernrds filed Wrl h!h<: Dankrnptcy Court S<.,ptcmbcr 22, ]017, are the same lnt5t Accmmt recmds, prn<luced pursuam ln each nfthc lla11kru11ll'y Cmirt's Onkr~ 1 cluted to pnidudng same. ll1is is.sue \Vas raised 1.;,y t.t se{:ured tj'etiitot's eoon5e~ on or nrnund /\cprll 20, and discttqse,d at n iv1av, i 7. 81al~JS ('t)_nf~n:nl;,.,::, /\l the StHtus (:onl~;r~ ~nee, [~ '\\TIS nr'r,. 1md1;r$lm1<Jin[\ the Court (1fdcrcd mew produce my trnsl accouni rncords to tl1e seemed c11t1litrn"~ cmmscl 011 or l>cforc l;-lay 11, 2Hl 7, which evitlenc"<l the nmds w r" 01inently in my trust uc1,uunt I lowever, Ihe s"cur~d credi1or'~ cnunsd indnlled l tn!j.iwhi: in lhc propo:.:cd (!rckr 011 St.a»us Cnnfrrcm:c. (J)E#299) requiring me lo produce documents eviclendng the fund~ had ali,:vays. hccn in my U'llHL Hceorn11. U11<>11 1 ci.:d111 (1f Jlw r1 or<is.:d Or<for 1:in S!.Mli.~ (\lnkri:nc\:, l ''xpres.~ ~<l my objec1lon to r.hts language. as it was my undets(imding Hie Court only nnkrtcd pr!jdm:1lrn1 nf my trust ucoeourtt 1 ccmds sbowt11g the fonds w<:rc in my ac~11\.llil on fl,fay 11, u copy nflhc m11.wil lo opposing rn11nscl is enclosed as Exhibit "D''. lk~ptte my 1>hJ~c1i1.>11,,;e(:.rwi;d \:r~di!<><'~ 1:m1nsel uphm;i\:d 1h~ prof.{l!;ed 1mfor1. On },fay 11, 20 [ 7, based upon my undrrnlanding of the Bankmptcy Court"s Order. 1 smit an which q :nfllilif,1t";d fl Sl'n~1:11 i;:;ho11 1f' ff'ij' l1li'l.t i-l~~c1)ilrl1 -::;rah:hl'if fll (Hl tl1.:~~ 1'!!.' " H {:Opy 1.1( ~Vll~L_'.l'.1i'i-1-"n~!](~~~(l,f~S Exltibil '"E". Al l!ml![me,.it was my belief I lrnd cmnplleti wih111~ l3m1kruptcy Court"s dircdii'c 'fay 22, 2017, th1: ';~q1r<;1! ncdit.or's ~o\tns<:i r1kd n R<,spon~c lo tlw D~blor'\ Molion for Extens~on of rin1c to c:on1ply \Vi~h C~nuri ()rder 3, \vhi(~h included requested ri~1ief rej3ted to comreto!ling prnductiorn of my trust accciunt records.. A h0ari11g was scheduled on tni> milher June , i\t tile June l, 2.017, twari11a the issue Wll'l!<ttsc.d al the end,11' the nrniln by ilp!'"'i"g c\h111s~l Al llml timi;, ii ix. my r"""~~le.,;tion lhc Flrmkrnplcy Ci.nm wu-< infonrnod lhl'rc lmr! hct:ll :m f)rdcr entered 1.1!1 the ;;ubjcd, ltl whi<:h, 11 is my rt1~uijc,;ti1.111, rh : Brmk1. op\<!y Cmirl rc~p(md<:d, "Gond", lllll dld not lmtrnct :inyon>e to st1hmit an Order on th~ matter, SJ:k'cifirnlly, lt was my prn;i!ion the Hanlm1plcy l'ourt did nol set 11 new dct1dli11c or hmc '!, 20i /',in wllich HJ prndtict' uny J,wt.lltl>'tlt~ r~ kitc~l tn my lnt~i Ae<.:1>1mt I!nwcwr, ile~pik thi~ foe~ opposing cm11t~d 1nc~1arcd il[il(l\hcr prnposcd trrdc r. Upon fcc( ipl o}f the propo:ml order. r spc1jifa&1jy informed l)jjpming t ou11icl of my b<jli.d related hl tlw llmihuprcy Cmiri's dlrcctlve_! hav0 011clmed my s r\:k;ted ld this matter m; Exhibit"!"', Jn fact, rm June 6, 2017, th~ prnposed 01 ctern wc1c :mbmitte<l. to 1hc Uankruptc.y Com! l 11 i:l rn~, recolh::cli-nn thu p1'{)pc1sc:d lh"dcr n~1 Stah1::s c.;: nfcr.i::ncc 1 despite, w1y ubjce-1lon to :;ziiuc 1 'Jr'a::. upl,i:iad<:<l l Zi 11H:; l3-nt1&n1µrcy Courr i:h:reiugh the Cr1urt's C:J\r1/EC'.U: 111i:.'iEl5, and nut 1hrough thi:. dc:dlc.11lc: d r.ne111ls fbr.;.',onlcsti..~u ()rdr:rt.. tn iljiy l,:\.'1.-'~11, ih(! pn~po::il'>tt (>nj~;r hjlj\ijn,~(l ll\j; tu pri.iil\1.:.:._; n1y illlst ;_1\:..:~H(!)I l\!1,'.(lt'~h (1-li. t'li' h8t<ht.'.' i\~;!i.,j' 11 l 21) I?1 hui '!~ dtl nut {!n\ered unlil ~ lay 16, 2017, u.hl~r llm.:- lkm<ll hk~. 3 rhc :\ h.:ition fr1r Extension. ot~-rl111c- r{!j~,llcl f%.~.scqi'r~l{'. \)nlij? l~~\llrj~_iithptri~~trir to protiul:~ i:-xp1~ fl v1llnes<>1~~, 1 1 El L LA}.{ fjjf:3f.: L 1 I l: l_t..,:.;!i. t., 1 JV C.()t.,.1.\' \\1\''.', fd~ i:. Tt L l /., h1 L/.'t,t>.1. C: C t 11 1()5 '.)("'JUT'l i 4/\!~c1:,;:,u~~ A\/[[\11Jf, :: ;u11l ~.02 '}.'t~:t.; 1 t\lj.,; l-.'::;\l~;! FL<:")R,r1/', :\.~1.1111

131 ffrett A, if.lam, P.A, 1hrn11gh the means for comes!cd nnler>. lfowevcr, the submh~ion only '1!ated i did no! belitve die.:ir<lers fl(:em~icly rdkcted the Bankruptcy Court'& rnliog, II did mh slnk I l>bj~xtetl lo the fact mi Order should oo 8uhmhted completdy. A n1py Jfw-hich is enclosed us Exhibit "U". A,; l ditl 1101 agree an On.k:r \'/Hs to bt submit!.cd, I did not submit a. comr>ciing Onfor. On Jmw L , the Bankrnplt'Y C"'u'' eme 1 ed li.;1 ()nkr Onmting BON Y's 1'foti011 to C\1rnpd Prnduc1ion of Trnst Account Documents (DIW] I;~}. Th" Onkr r<;(1 uirc<l m~ lo, "provide l:!ony with tme anj cmrecl copies 1\l' his Jinn's trust c;('g0\1!11 rccnrdc1 for fl.forch thrmigl1 Mu)' '.Wl 7. refi~fo1g 1he Dcbt<.>r'~ DIP account maintained in the 10'1'.I\ Trnst A<:co~iit for l.iw Lmv 011fo<:~ <:!' Br,:H A. Elam P.A." The Order sci l1 deudli11c nf..!um: '.l \> ijljl' Order was cntgrcd AFTER the deadllne m produc.:: Hoe Trn~I Accotinl documents, and al a time J was m11 ot' the C~OUU~J')1 \\ lth no n~.::cess to cn1ails, dl1is deadline \ViJS not 11~~1"~. /\gnin, n1 "\\ ~~s n1y pn~1i1ion lbi: Bunkrnpwy Court did not "rnlly!;.et n dc~dlinc fi.w J1111c!, 20l 7, and the Ord~r wa~ ncil enlet'l:'d until after!lie expiratkin of the d~i1diirw. Bu.1cd my intc111rc1:it.ion of the Bimkmplcy Cmtrt';; oral rl.llil1g, aml!lw litnetinc of th~ cn11 y oflllc actubl Or\!er. it would have l;cen imp,111sihl~ form" ii.> <:<m1piy wm1 the tenns of :>mnc. Upon returning [o the Count1'}. I di;;c{)v<jr~d llw Barnkrnptcy Court had entered the pn1prn;cd ()rd~r subtn lni.;<l hy opposing i;ounscl ~ \Vhich req u~red rn.,:; to ptoduee certain 'fru:::t,i\cc~1unt re:-cnnjs iiy.hnm '! nn~rd 11pm1 my hdirf 1lw. H:u1krup~<:y Court lrnd 11ol rec1ue.skd any pltrl)' lo s\ihmit w1 Ord<:r r~lf1le<l to tl1c produc!ion ofa11y Trust Account <loc1.m1mm, nor did toe llanknipiny Court ~t u deadline 0f Jrnv2 9, for the pro<luct~nn, Oll Jurie 26, 2017' 1, I tikd u t> lotio11 '" Vacate Ordef G1-;:imio1g BONY'~; )v)\11k111 L'-l C(l!l'lpd Pwmlueliun 1.11 Trns: 1\e~ounl Documents. This l\ fotion was sdie<luled to he heard hy th~ BankruplC)' C L>~lfl on July l I, 20 l 7. /\t tlw!waring on this Molinti, l argtwd w tbe Bunkruptcy COlll1 rny 1mslrilm. Tli<: Bankruptcy Cnurl dcni~d rny Mmitm, h11t ;1i~o 1lismi~"~d the pending Clmplcr 11 bmikrnptcy of Kim C. Crnwford. The dismissal was vohmtary. nfo;i the Brmkrnpicy Cnur1 pn~j1nkd Inc Debtor's expei1s from t~s1ifying 1'li <uly \"W e<ml!rm<iri1m hcnrlng. I advised the Debtor lo v,n!untarily ~~~:ek dh;1ni!l!ial.,. us the l~ankruptcy {~tn1rl ~:iald ~1 \Vould Cl)Jlsidc,r convcrslon of the cas._2 to Chapter 7,. ir1hc sc cmed crcdiior so rcquc.slcd. As this was the first lime the Bcmkn.1p1cy Co<l11 secn)e<l h \\'Cn..Ilfll consi.fter conve~it_1n over ~1i.s1111:;881 1 f1 \Vus n~y advice tcp th{: [lcbtor tif> s:eek >i:'oluntarv di!iruis-~?!i~ of lh1..~- ~-H$t:, rhj~; udvi.;,:(: v1n:1& ln~scd upon the t"'.act th1; [lcbtor O\Vned fifty 1}'.::-fc.cnt (S{) 1 Jt1) of~t ]Jo11dura.n torporu1io11~ virhigh o\vncd an 11nenc111nl)';:.re<l prirc.el ofl'eat pn)ni0rty localed on the island of Roatart in lfomlurns. lf~1h-' t;jlst: h11d bcrn coiivcrlcd, lh(' Dcbtoi would have most ~eriainly lost her nwneiship,r1 r11c (J.Hle;r uhil'l' llto\y ~~11tH\:d h> 1hc, B::;r'1\,r11.p((.y folrrt; wa~ JTI1od~fii;.~d by the lltt:nkn1plt:y (\aht fr01n Ht~ ririghud Cun11 ~1tl.1t11iH;.!d h}' opp1_1!\it1t?. cnun~;~;i, '."" I }1avc ~nc{fis(."~i ;;1 ~!OJl]' ~)f li1~ Pii!"l-:~w:-::in a~. J;~hibil ""f', \vhh:l1_ t"ello;;i;;ts 1no;:: bt:ing Ln Pt.'l J frurn June 9; 2:017, thr0u~h June I{}, 2(117. t. r11e ej1try of thss kforton on_ the doi.:&o!.'t shr1»'r.-: q ~hu0 ~:if Junc '27,, ~!'.}!7,!:-qq ]1, Wit:.tils'd sb~n1jy ~1l11~t tll khrl.!:ht ~}!\ J1..111~ 20, 201 /. ll i.:0nt.i:1:1d it 'i\'as a tin1>::iiy filo:~ h tnr1nu.. H~l ii '>~':-i;:. nth fili,:d b.>' ti~1hlnighr. h11~1~d r.lpnn 11 i;:o1llpul.1;;r nwl fhni;i hh~. i:d'l 1?i,1 ;i, \ l 1 :1 I I,.:;,, ~."!Li.~ 'i 1! fi ttfi /\t 11@TiffF-T~!./'i.\,".t/\'N C.l]\11 '/l W' t/ ~J :~' E T i F:, A Iv~!,t\ 'IJ,(: :: 1 \r! ':-~1(-j {;{t"i!til l'l;\l.: :"'."::f~;;,:;'d~: /\'./f:.hijc, :::.U!IL,so2

132 BRE:TT A. ELAM, P.A. imcrc~\ in the Honduran cmpnmrion, mid lhe I londman corporntion's parcel c1freul property,..\~ suel>, the Deb<or mad~ an ore 1nms Motion ~o Dismiss, which wns grn11!ei:l hy 111,, f31l1jkmptq Colon, Finally, the' Bmikruplcy C.:,un fjrnl'ly infom1cd me lo produce the Trnst Account S~-atcni.c-i11s by tj1e end of hu:i::inc~s tbar s<101(~ day.. July I 1, 2G l 7. On foly 11, 2017,! S'-'ll( 11 cnpy ui' lbe Trnst Accmmi Sunemems 10 "lll'nslng C(><l!l:<d, have cncl n~t:d u ~-Oi~Y Oflbt: cnhjlj e~challigt" \Vith opposing C4.1unse~ as l~-xhib~t nlr". 1--lovv>::v""~r. u.s was die theme l f this case whh thl~ paiticular ere.di lot, fiis eo1.1110d 11gairi s:;id rfiat! not complied with the Btmkrl.lrtey Cou1 t's dir<":ii' ~:. I! is my position this is wmpletdy filuse, OR!he ~kclronk at:..::.out)i stutcnicnt:-: Vr't;r{!: prnvid~~d 10 opposing counsel:, af.. reflected fron1 tht: i;;. n(:.h.lscli cn1.ai~ :string, Mm~nvet, Hie llppu~i11g wunsd cooiimtcd to file h>!otkms wi1l11he liankn.1pt(:y Cmor1, 1.kspitc 1hc i'lt1;1 the pcmfo1g Chapter i I ba11k011p1cy l111d hc<:n dismiss1«i. In an Amended Motion fo1 Sa11ctk111s, fih;d hy th~ i:~c\<n.hl urntliwr'o coumd, the ultnmey alleged I hrnj ma<k fi1jr,, statc.1n~"l'l1~ N>tilJ.:rning 1hc runds being hdd in my Trns! Account, Jlowever,. it i.s my recolk~lion when asked < boul lhc food;, I responded!hey were deposited in1,1 my Tru~I /\~wunl. 11 is nm my rcco!iection [ w;is a:sked abm11 w[1eil1cr die fomb h11d ulwuys remained in my 'l'rns1 i\ccounl l lmvever, 1!l(t11 of ilie foo 1(\,; lit.ii.i r<:nrnirmd in my Trust AccmmL So, H' the qucstk<jll a.~ked h,\' the Bun~mp1cy Omrl wi~s did the Debtor's funds fo1 the alloni.ey\ foes pnkl (o rm; r~minin in my Trns! /H:cottn! from tlw time of March ,rough t>. 1 fay 2017, mul I rcspomfot! y 1 ~s. funds had remained ln tl'li' 'l"rus1 J"\i.:-i::ourH Elirnug_houl lhl:+ ~hnt;fnn11c~ ii VfnHad h(}vr'. hc:i: :n il 1n1ri: Nf~ ~N'intr~nl 'l'flll{ n,_ ~j'ji)flst would mh be fab;;:, A lm gc portion of the foods n:mu1i1>ed iii my Tni~t Account ~\>rrnisicntly tbniughout 1his timcframc, h wa:1 nevct 111~/ intcrl1i<>n In misk-ml anyone, especially 1he Bankrup!ey Court. flppcm ing, in rh<: Bnnkrnpr.cy Cm1r1 is appmximatety 95% of the work r do, and I <1p11cr1r hefon: lh0 l3imkrurtcy Court on an averng of appmximme!y dm:~ 0) duys ellcli wc~k. I have never intentionally mi,lead 1hc Baolkn11>l(:~ Court, nor wotilli I i11lentimiatly mislead the Bankrnp1cy C<JLlri, Tn the conlrnry, on numerous occcaskm~, rnthcl' thai1 lry and ski11 an i5:iu~,\ f \\ 'l)l'l]d rt.:"5pt~nd 'LVi~h HJ'l!i\V<CfS V thicji \VGfC not in f11j" 01' 1t1)' cjlet~t's. he,;;t lnlt:j't:xv:i 1 bnt \VCl'l~ tlc{.:~lihttt:: FCSJl-C}fJSC;S. ~l bas nh.v-il)'s ht:en li''i,)' phijotlophy tft {)~ h011!1;':-:s1, 1-Hl-d, )'011 can \\'Ofk \Vi th lhc ~ssucs ru14.l fllc1s yot1 :are givl'.nr LL'i lon~ n~ :\''f~u a1~e- ho:nenl 1:.1::-:_,!'.,r.11.:.t:: e1;!::! r ~ L.c\t,..1L.t.\\ 1 '/,;'I/ 'N :!!i' [ ~! l L /,\/Lt\'~'.;' ':: I.) 1.;1 cc::~/ 1u.'.: ~.i:.:::u11; n~\r;,'cl:s~u::> t-.\"~nur. ~::u1rc ;Jo~' ti!":",1 P/!.l..I n1./'.c:li i-!c Dif.1/, 1J,.t(1':

133 Tljfj LA'.,'11 OFFlCES OF BRrn A, E-"l~AM.. P'..i\, Ui<: finjing.s by 1hc B:mkrnpicy (\1t1r! thm funds were improp<:rly disl.n1r>td lfom the Debtor's Delltnr-in-f'u~~<'ssion ac:count, only relate 1n a p1.1knli111 violating or a Btrnkrnptcy Huie. Bfl~ed 1ipo11 the work perfrmmd In 1hi~ h1rnkrnplc)' cl1se, as wdl u.> lhe lungm1gi: in my Bankruptcy Engagement i.r:ll<:r, tbc 11t!omcy fees paid by tile Dehtor ID my firm had been earned. A:; suth, ii is my im1fcrslanji11g ii is 1101 ml ethkul viollllion. x a vil>!ation of r.hc Rlllc Regulating the Floridll Bw. lr rid, h llll im:,1rri:t1ij <1ssumptlrn1 or all i11cm'tec1 '<i:s<0%1n~lll of 1b" Ruks RcgL1laii11g the Fli1ri1fa Bar, my ac!ion;; were not im~mill1ml now did [ in!cnlionnlly lake ilcllnns that l bdicv1o<:l v.n:rc u viohhion of any lu\~ 1 J-to ~../t.~vcr, ph.~a&l~ let 11\l' knnv..' H' you,:nr: in nr;,~~d (}f Hny further finfijt:mntion or ctncuhllc:nt~hiori, If so. 1 V1tHI pro~npuly providl: :Jarn1~ eo you, i ltiok ~~H-\Vard to bc.f!lting rrn1~1 you. BAl::/me i :ru:li}:i.uf"!;"i 1nr.: ~.1.::u~ r-0 t J/1i~'C.1'~Su:~.1\VENUL, :::,u1rr ao;~ //I:~;' P:'' Lh I i!-l:\ci!, f-: C1~Jlf_ 1\. 1, 1,1J " 1'

134 The law Office of Brett A. Elam, P.A. tjre~l l» Eliilrn, 1;;'110 Clie11t Ledger J:.!!~' 11, :!Ott r.f-i AV:iff1A;f:J Re''"'"1n;; aft dacl;j;7f;&fih;; lflfffl:;!qtlljff!' OOc.li(titt 1!1?.l.;)'!inq- fi:'.1ttha W'lf'fEf l~~q::'ortj C'Y..Vtlti!d b'.t l,ht:) [)!;'tbtof. {t1q U(:C; f;1jij!ir;!hfi:of!:l!'i for lhi7 IY~ i.iy'r!:,(;tfl C' Vn% riit'.fl-i' prt:l(:~;y 0 tl '..or D!Blr'llng nho:l Jm 1 i1.lilng lhn ~'.':,trtluun!!- rrd fwilint\' ~,;a,;>~~t '['.:rnrji~nrs [14,:z"'"'Ji ~ l ev;fpflu, Ji.rid BB!'1$-n, ;:.t,:;v t~-;:; f)itt4,:::.x Dnr <,J, ftiio\ irt';j i<tnd t.tj'tj, fl.t'~,,,4.j:b{;:i"1 f;';;t i~trii;;~tv-fm">!snt i15.j1ejjj. os; Affi:.'9'4,,,1r ff\t.f2i:tr:$~ t:w 1c1rt"a\1, Cftftt/yf':JJJlfi'?2.i:O A1fJ<':J :S1}fi nn l:fitt,..~'t,?ilj&: f,-'.1>1.:;~;'fi ta 5th-C('>.l,(r5. ti:n<j fjnl r'jrthr:fng, fifilvl!!.lng, end Ehng 'lhi:;r C1J.1i~ fwfj0,:t':y!t1f.:r.1 Sumr:nary f0f Ul~ Debt1)f Cl~rV/iJFi)f?i['::i t.:} 1{i f\1fj.'1,,,,,,,,, '81!;'\'1Sor Q -tihd fi -oh-1j tho f.;t-cn:;t11d E'it. Part"1' f ;v~18'!\t, f'jt i H;.\f (>f.l?.''lt'fl)r{~ ~ 1 }'H) ;'VIC,; H>ii)~ t111r<j f..tjj- i;)_:,~4t'!i\cfn1.'i2'ittb~'i lto':it'.:."{.t ~x, ll'4l S :::hi;ltjj,1;1l'0'cl ianc:l St2e1IT'ti!!ni!. cj' f vt\ilj\ t:t;iii,a13:4t.tt._ :in rjn1~''ih 11? 4 ''"" fi1~-x] Fr-r:Z?L'Z4:'';! V:~ :S-,:::hei-:t-; ff"~: S~i!f,1?1".filoftr-t -or F riarx::~ai AffEiif1,..lJ.4;,1!f';if t~ti,,;-a'\d\':j p12cikh! or 1.t,a S-'::!r~</'2:-3 ir;. p-:n1;;.m,vi.i.i~'"" 1"11 ;,;.,,.'J 1-";dfl IH6 C!lUl'f 11;.i 1i'?'.)1 ~~ ''l"""'"'~v'--:j pi <?.-{t&rlna!01 In~ J4 t Fsu~ ti1r1qr ntj 11r Cttt1i1t;:i1n Gf\E C-RA'v\ 1 FC Fi:tJ ]'/~{J.t:Ji1UH N113'tr'J~d th1~ '.:µ 1 j'!?;.\ of Ct odih1t!l ty U1r.:.1 ''All

135 The Law Office of Brett A. Elam, P.A. Brt:>ti A. Eiwtri. E;,a Client Ledger J,,J~i 11 :::10"!"7 BAE!JffJ';J4tt1n1J inf jt-w;:j! 133q ; lf'if} Cf'r, IJ1u ApplicatM)11 to r: 1i\ploy Co1.Jn!'F.1JI 1\\'tiGTr~Cf '!l'h1' F'1'Z.!Hi-~ t;jj1, tf <l A4l vir 'it:jii,r;:;\t lo Ernpli:iy ('.!:':ltl!ls-e! HY1E {~ftl'\1/'{fc;r[) 21,',!;) h;'1dj i:"'''~i'li} f\5v~l-d.jj lila''b1 ::.:;,,,'):. r+r.rr-l Lfdf:I CA' the teppllc<ihi: f'i t::j f'.'ff1f~-c'j ~bf:iy,,\t '':1.'JiJFS:S~Ji: fiae GRi 1 "~~JF(JF>;O U 1U il.1(1) [;qrt,f:!ng re \ 1 1J!.Jfl~L fijitj hhf1q 1l!e. A~<'P\iCe:l!Gfl!' ';) ~fjtqjkji C'n~~/J(_n i;i 'F >.,~µu11 ~Mnrngerrc1:inI l.a"1itlj:1%m"-t' n&dfj Op1:1raiJnrJ CHAV'/f{JRD )f!~;o ti. t!j-4 Re'<1<,w11>a, 011,o;vz:r'<:i.ttns f11ing 1r1rrt f1;t.j1'1ln1 1 Snp~O)li &?:fl1~ U-,\-f:3 1~Hf1,'1fiiF(ri'{_[;, :!;K'IO A;10:1 ""''~'"" ffrnli.'fq:] _;1g::; f4bfd'li:n,;;i µ-,_12 VtYtefi.&d McJJ(ln t(l f~f;(!,;11 t:-1) r'41i,1i,af:,{ i:}([; c~~;y;/ Vla 1 ~-1');r,:>9r~~ BAE Ct-ttV1 1 JF'CiRD t1,"'hj /\tr>-~, Gl0il't.ir1i;i. lr~le411j, f1n1:j p1nrca.n1~ th :~ Vrt.fifl~d hl+~<it4'1 :b RBf~ to r~r~~l\ti Ofl ~~[i~1;" v t~fc11h,' ev J;'}:t}1':'2-:7J ~l'llf '' "l'c'.l ~f'r6 i1/1;r,-fif,;tj \i\h::1']! ll''fi<'<'l',f'j i5~i-2'.:''{j'.'}[t:j 'i'f-".cl YJ't-i± ;l',f,/;.c"d\'.f Opnr J'.'.irlg Ri1~5<>1. ~.::;,;' O.'i.c:4"h< '.;;1101.i $.?HJ (!(i P1ep(1nn;~ tfhj c:k;w~1jffl~tit1} Wl#J-W!t?i.'.t-J.t!i;J;;J.i!ht rm;a! fi!"gfmniji,!nc!udfn1j- b!j~ iifnlltid ~O r,11'it.;p,::inri-q,

136 The Law Office of Brett A, Elam, P.A. ff.'fdf I~ Elai:n Er;;q CH~mt Ledger J;,t!{ l,l, }(}17 P ;,,;;, Dt.~t<f'l P~ ~tal d0lt.1flft't< 01s, ts1:b1fl ~j::,f1g 11rnrnr!l, a:11~1 "'"ififtf') if'c~ 'V{fj,,1', IJ,;"Y?;l,J.,'!lt'lfT1.t rnnd l?.*1 M'l ;,W;!f:lf 1 id "'"""''"""'" bt:9111j1t.~ fxt11rler fajf ff$it:l.$in),fl lie,:;;;;;f,;(rr;)il!;{'! 1't:ii2/J!$ C'f th < f'h;tf~j';){"% w-0fl':r(~l'#% r';a"'.t?&:4!i thle1'?t \-:;'.('. f~c~lk ta lif:'.;.ld f-i:i;-;r.rriy!n P'Pt1:par;;:!f.P.:i1 1 ~ tf"b rt~x -Sir:'.'~~J\.4 1bq EP'ofl r ~-0'11f:a:l 10 1n0010nun \ti U1i::s rnatre:r flp.e G!l~WFl:'RO 22 IQ Al\J'i 1.:6t J&1i1/; r11, P!rli:)i~ tirrg' and f<jj'l!;l lh~ r~1(~/,qi'!! r ZJitH;;H~l'''iLl! lfcpt.w~ far Hc:vernl"ltif i{114 ""'''"''''" 8'1iicl.cm,,1 ft!'!fl CR.fa.'1JVfCJRD th!# ff!dnlhl~ Frwrr,ei,i tpcat'!1 if;j,~:if. 4JrJ»} ~rrr.'m tn~~ [li114'1~,(1,j11"1t{: y O<e_.PT t' -n C~'L'!a E L#..1 ~J~,: t:'.:;'' \~ H>u,,W,J~'J tnt.frt11l F~!:a 6t0~1 A Elw;:n. PA, AIT :t.t<j:7'{ fa_:c1 :tf1:t [Jf.lfit:tJ-1-ln-Po:c;a.Er'i.e.li::ir1 (0-,P:,!Ji;:w".l.r,;oi::lef!t<il*:::l k?/ ~th'c tla:tt4:rup-1aj{ Cct.:±1 Man~fl l1", 21Jt;5 H/1.,f CH1\}l',if'l)fH') Jj,t;r;_i.91 i G); O?-uf~lng. fi'.e-\*lyjflt~ ij;:,-fj U11@lk:1!T!J ihfl A:ft0rr1t:J'j' RepJB~i'.\trr~ (Jjj~ C'.-~ iilfflt] r~::'!'jnn k~>l Ri:,~Hy':''C l to ~.t<mf1~ Wiri'1 HJ&JT«I-; i; f N"-f'.f>'I ''r(tjr!i. '1/~fb11..;r::v 1t;tr 0 ~~ er1d f,htt t~f!f.' lf"vy R-e-,P.'%.~ t-~t~jjlk5 {.1-ut,D-f l;rr,t- r-,}t 1 ~01r11'i%1 k'l M~->tP~\';NiEF-1 1 -J-/'fi.'2'.'.'-i U <. Nl'; k'fi:n:rh1',( tj'f~1irtg affd ~fii9..~;}~jt;;:r1 '!{ri 1/ul1,i0.i'.11f1d Dml'.f:'Jrtrina ::t,tj<,ur"-t!'.! 5t il u-~ n~ l l t!<' il<'1!-~rfj.ll PirJpNrtv t'jryk1 th{ V'Jr&l!-:t fh!rqo H/... E TZl?CtJpJ ~irrl~a\ ;:~rid fihr11~ 1;111.hi3 r~~ontj1ly f.jt:)<j l.jflir"v) R"l?.f'.tt'IJi'S fr~r.s JEil'll,ll~i'V )f.!ll:t; ite (tn.y:-t!il "''""'M 1hn f-r!,,::<:i:l1j11:s ~a REJfQJ ~Jit-,/tr1n :;~n1j 82n~.

137 The Law Office of Brett A. Elam, P.A. f1itt'lt A [l;+sn. E!$q Client l{ldger Empli:il'l'i! H.nr: C.f1:f ;~~1F(lf~D 300 Qi] f<w 1ctdi,1'. 11'.j'vrt1~,.~ ctn1j tic1.rr;.:;.f tlhk fi,~;;;';illl r tj,it.e {;:R;\"/,rFfJf\![p, fl'ucj>!:jpt, J ft,,t~l'n!'ert:;:j 11? r.?1'*' l'ms'.t~1~tl.;''t.::jpi?rtiitjr..9 Reto'(lrt@ r~., :?.1J:'f ~"!lab (Jrmflirl(f. ffh1 1~1og tj'#~ LJ.:th:-1 f;t:ir:kn.g rhilt f.1otim tt.j \.'tjk.tel 1 /\l;u!i~ FrJf1!,JO n {:\Jn a. \!? c1;ir1li1f'oa.1j i:ssli /i.,h)l Dratt11'i1, r.b'ltwir1g end f1rroiti:ij%.jftjif if- Agreeil'.:i 1J1del'!Yi! tht; ~*1t4:i.;;JTI r.o Re~r 10 r.~1'1.l!t.t ;\Jll.lJ ~'1P:ilD<;::1n'1iill 'B;2i2D1e! IJ,fa,E Cff/l,\A;fOft:L~ ~::,J~~iJ.A ld-:1 $ 80.Utl Roc~1pr, fd'<lltyn il!r..jj 'fi!1n.g. aef&ln OpatEtir1g Rt:1p.,; ~42 :\ir ApnL '.day...l,'x.u &r,j J<;ii-y /\E Dr:a:tr:nci. ftt'li11lf1"..) mr:c,:'.ii f,nz1h1.. :rt~ ~hd 1Jlih " o~; r,,,1; c'' Jt",~ Pl av. ~~lld f.).,;,,;1hni vh!::' f.l~.atmm.f;i..y;! v.> i"''" tuy&.~, end ri%it'.<'.:if'il:'.hntj 1r1 ti!ttc!to1"1k O'.P't'lffMj\1\t.illilittn:S hc<n 1t"vi!< c!]jjlflt 1&lztlmd k> I ho lr;0t1\!ff. i ~ho PkJrr and [tr,r:j;)ful..f "'G. Sttrilc-tfl".ff'~ l\r: '1.l'1'i~ ~i'r0th fy(.;;-;f\ T,ltH;! F-%l;.')~\SQ '>l11i@ll'<i,oi '.-9fi1" 0 d'.h!1; iif.fi fzi.f\!i;f'j.rj '.'!'fj,f,;ffel 1il"'.-'.JCTI~'-J' tr fj F.J"\;' t.:irrafllng r~o. 1 l:lifitj +l!!-1d t\n,nh;1ng lhif-p,.pfi!icll:!u< f tfj ~~rnrao,- l\(.t::i:1tifiii"iint H ut<l?~flt l'l!jvlr.:tw iv'a1 flilfl!) of i:hn- ~fi.tjnt) 1.\ Cv~'''""'g Ri;;ports i~:' 4.{J i G 63J!,, Cf{t._il~ 1 f'.t1<rd ~'i'!,.,c ".ipt rw'""tfu'a' {t--"t:l ~dir..g J?f 171? ~fj.l':.in!j'~ t11

138 The Law Office of Brett A.. Elam, P.A. Sreh,f';, J;.:!a'n It: S'.'1'1 Client Ledger.J\l.'"'j( 1 1. ~t)~7 f.!~e Cf:;f,\>Vt'l)f;:D d-3):\tl A Hf.'1 rr:~~e</:1!t: ~'ftrw, 1a:;d ihll&i r'~'$ t:hjs t)bjec:iicn k.i Cc;:.fr m:-'.l:ti:.n!4et<' bi:- f4r+:.v;.ns.1ft: :..::t, ~ f:1j-e.1j 1f172!~J];i;tf'.{J ('.C j.;?; Af;'Jlir :'.0;r:<}c1: 19 fn':pl(lj' if,if) ;;r::i,.,,,"'ij,;ti'ij 1!.JOH l'lhul.l H/t,5: ~JrrJ~llflqt HAE Re:cwipl H:'.l\:!i J.,i,i t;i;r;j otj>tiftzu!f1"11)bjitti:.:li:.;"'1 eq '!!1 '.1 Bii;-. ;l~rnu11j l5l 1!.H nw11~ lih~1j!j~ i; "'" tj11it'!... \J :not:"'.:i 'fn.;;jl!yb's Offir;Jf;' SAE Rt!lr.:!!<.ipl r111 1io 1 N,:,jJ'r'd ~t11± tjbj&g!1cc:1 tu ConfirJ:--1;1'tiut! r1nd (}11ctrE;u1e S1al'i?~li7f'l.I fi:.is<1 t;,/ E:!-at:Jii, ;-;il fl&t V:Ork fw~i:t::rn P""',.t'!P:pt f;ff.jlq;,o).!!.'.'"':!'filing of ltfa i!j.o!innij' D;;"''''ri.r'J Rin:partB to-~ C c:tr;c:,.h'h 2n1 :;, IP;;::t1~-nPJ~'.i-. J:-Tr.r>D1ing.E~nd sr1!jji:rr::>f1~ &.-1 obj4m'.'.zn:inc <t ;.::rt2'i:-..eirat,:;01 <Ci:i tl\~ il~~,zu,r-;,,3 t~in r..:'! 'j'f1~ DrfaLit1)f:hii:'(': s;;;tf!f(y':g~-,t 11c,,l\.c. 1 r;sv;'lif.'rj ~v1+j fafl{??n:'.f<l; 'iirb' ~A,n-:'!:!fi'fii:!i<:l Dl!>chJ3K<"'* ii;}jt0f H}t«t ~lnd, irr;-{}fioj~d PfJ:\:, 1J1 CCi\,;H C\! 1!l''f,;HtJ lff.6 rr"'*'z:j ie«;i 1fl1± CJ'W1tcr:; nrtd ~he u.s1" Gf1.r\'1/\l f"{j;fdj ZJ8 t /:., i ll:j J5Cl,f)iJ lkfid nn21l1 il19 Li-P-:i Order. l.k!.<!1ltcl " Stnli:1rit:.""'l 1 and Sell!flkJ

139 The Law Office of Brett A. Elam, P.A. Cllent Ledger Ju:i i: ~ 7D rz t:ia.f l<haff/ai :g fl:f tp E11if!;fi'{') lii'hkr le_:;. ~ ~Hj i trtr: ~tr lifivi';l L:f'f..;)$'1 /\ ltfj f-~,ri,e LRAV 1 1if{)f1'.l.) ;;3,:y1 f\t1~n!1b::h 1"tli" k~:a:11ng {Jfj ~f!fj rk1dpl1n Jo EJi1tl!ld ifh::-cb ( J :f~h2'-f:~ ;Jn;J!".'l 1i11jb:1 0 /i, 11};} H,l\E c.vu..i..~ifc>;::;d Rwrt1J1;~\\~irV;J, an"l+-i?:rr;;i: i!f~d_r:lls!f::(;1jf',;9 i:..:-a l':? r.;orihtty1stion fi!$3 t:v fj~-k ot.fl Jl'tE\1";(.'.0 ME CR/lh'VF'ORD t::&-&ipr.@-c1:j re-«n~w (:/ thn ~atlur Pfain 1 1lt<:J L'i" Bcr:-i, t.if 1'-tr'10t<:',i1! :r,11\ 2..:1,~t 2:3,t;f.1 llii:t,,\~(jl~ 1\fOl1 H..ft.f tfi..i~v-if.{)r D R!fi'rlltt\,1Tf,J, il1rl4['fif/;;' ~ ia:r:r:t et':b D:'C<c:.iJc'd ltj t~~'10tn'11'.jtkin fil> J tiy ~at'ziyv.il\4'!t M-0rt:J<lOA 2210 i Ht!Vijlj('fl t;jnj 1M1tdy1i; 1.i4[!1 B~-I:'.il lt'.!jf::itllfl:j tr10 Pinn!\'*'~ N5L:::d1t!W;r t,ll;;,,ttg:frf;* - lnt /\ 104 C1A!S GflAY~~ 1 F<YI'~t:J :t:8 t r~.;ri:~ei~a, t!t!l..'10w, t.ind an~lyajn f;!!'.rlill D0ni fr1:' t.,,1%~.:-?' h'::o t.f.;;;,,j1l ~ :::.;1!.hJ! 1 Mnd I.Pi HilnX 1;;Jf A:nrrr1GFJ Nt~.R1'J:tSib ~. ITTVit?~\i', anhl)'i'.1-"1 nnti Ti;~ rj'18 r1~011thl~ C~',;filicl'<l Rt?fiJ.1'15. f;,;.j 1J~i.11nb$1.:,i~1';Jii1:; BAE CR.,<\lfiFCf~J:;i?:'!~1 Ptann!n~J, 1ri 11Hvr1rHt1t\tH 1 ~i.r prapr1nf1!;j: Ll!11J rrj'iirj'.fi!8\i u:i' ;J.,J:cun"_.z: " ;!: t it 1!i# c.j":it1ft'111a\!t111 H "'.'"' r:;h:f\'1nfc1h"[r :~~1 1 t: H''l'''N1'r( n:ru&ly.ip-: µi.nd f1~"fl ij & fllt>flt!"itv!:r: J;i;;::,;.:J.'Y /G,tf; O~Hc>1if,,1 ~ ~1':+*:'.wi~...".10~ /;,,; ns ;:;::HJ no B!iiE CPP,V14 1 F(;.RO IJ,!.lt.!1'<1J+5::1 l'.he!hi\i:g1 C onfi"'lfljj1hjf1 fi-,,':'.fh'&j\l?{',.::l ff'tl 1h~1 0ffJes J~,;;::..,nn.:r~nr.-11 ll'a,! l)pr:,{:l: r,urn ;1s;J DIJ P11Ji'J!i'.1r1y l1elrji b #' tl:.2;"\:0:.:;if _11;.rrnq(fi.Y:1, F11-, rjj i.feq i::f'l F(i!: r..

140 The Law Office of Brett A, Elam, P.A. Htl1li /\.!'.:; Gtn. t: :iq Client Ledger j 1, ;;:0)77 Uf':1 (;H,li,\\fFCIHD 238'1,C..~ft.4 l ZwcolpL rn1.,1&/fj r-:;n;? r14"1dlyze. ~lie R-1:,pur! ul' t~1ed1atnr :i:fr:j f(1 thri i11od1t1i:m1or. (124'~J& ir. wl'lh Uan~. 0t' /'.fhef't{:fii. ~~ft,!:!j\e ~ec::;;;ipt, l'f'."'ljjh, hlft'i'.:1 ttie: f)bjo :;J;t;f1 ~o fr~nhr'.ln 1.n '1Jwl1,.1t~ ~ttd [}ij!ht:ffr1int;j f:a".1t-.v!f1!r:l L:Dii t'.:>'7, Ff.17~)\-! fy!{';f"rt~f!~i1 f:~j.j f:jp H@llk 0~ Aff 1 ; 'J'il'.& N/1 Unl!!fu ifi4'1{} 'f, t';t (;c'f;;:- l!ji.;:i~~ty'k I' ~"'IJ!i~ t-<:r 1! 6/ ie CRA\ VFrJf.:D 7.',l/ ~ ~i(jj rjtjlft!hq !~ '~ t!t>:j inllbmrttlno Jhf? OhJ>[j ~ c~'.'ft'liirji,;<ng thr! C(:i:lflffT"?Jb"J:i ~41':!.:Jrlfl!J: thn Ct1ia1,,1or1 Plkl!'1n1>!{1i, prb[jdfr."y;j li'.l!'ld' rnv1~in 1;;:.~!u i\!yjuun IJ.J V,_:J~UliJ', u:i w~ll t!:l 1.1 ;c; MwJ;1;i;i ILJ "."~1lu!3 Jn J.lfF,:fJffiftitiOfi frh' f\'d 11.;fl}f.;ng Cit'1!$Flrt!0 L3AE Ci'\/\!JVroND ~-'.JL~i A1l.l'-3 1:;:;0 no AHVind~:li t!jm i'v.jt5ilrlt;i til1 '1.ho fi.4;::;,-"jnn If;, ;11~J.k1n ;:J: } Ckr:~f'f'fffllh7!$.r::f'.1;li~d SlrilIJ~J, C 1!LJ.µ.r, (V; F1f'; t41 P!i'.4'4Hiv fi nd ~ f\-~ CJbi t3<ction f,jfn::t irrt:jt-k::. c_v±f'..1fi'd rr.r,,!..''1'::! :;r.::j f.71 ;!FJ<FfiJ!~1 ~.:..'(f'!&~~ ()2~&1 [~) ~h'il 10r \tuj/j; r'l1'ld [}4'.!l'%1{f1"!1"Hl "'10.'..i;' -T.;d l:l~t:il'.dl%: tr) IJer:, en R <S'a:l ~'":!/ti t;i Ba:;} :,:i,; f.rn!ilr'idh, W4-A, and r:1a ;1r~~ tiri':'.e&~::1i!b-'ejjj'f ~h0!1~0'a!clll!e:&-!"7--~ tl'ir.;irl!j('.) 4/HWIJ!ti IRmi:tilpl. r.12vten ari rd $\t11iv1.o r,he' Ftr.ai Frepon 01 ~flr.~dfe1lu1 w'1 th1? Ni1JJt:ifl!J 1nr 1'rpn::l1at :r.1n C.fJ...f,, 1 /~FOR n 1.:"Yi,.~,t:;: r., an:l ':ht! OL'i'Jt:11c', ltj 7~1Fi 1.il 'l'oit p'1'i~l<.'.1lxj>'li}' t:irn:j lb,\:2-".h'1;;4 lj 1 :fr '1h1 1: 1xr if:."'r 1 :;si fi;j 0~1i~'''d"' fi!it;ij t<j C:!'.W!f:ir'i<ltf..::in in L' &p~1;r:;rt':~11\ lt1 th.u onnt-, rt1li."itj Conf!rfi',tdJ,:;.<1 lla.c CR)\'i'lFCJ ii',0 Aiit;!nd1:;'1 t:rr\i! i:atflf.111'-!t?d t(~1firrn;;:it:nn

141 The Law Office of Brett A. lam, P.A. Client Ledger Ju:\,- i~. ;"JJ77 u rt0.::111t;:.t. H.l'?iF.h'l. nnnlyj~1 iilf!!l l'ijit fht! Munthh l'jpbr@tih!j f<r:1~;;,;;-,,4~ for Meiti:-h ;J01ki Cf{f>,WF1)t'(tJ ~l/l.e f]1 :ttt1t1g, r1u Ylm~1t; 01r~j f'.ll!fiq lth$,,"i,fne:"."-5.."lid Cit:hrdu!G:z. B.AE Cf\f~V 1 JFDREJ :::ut i L 1 LJ Af'ilBndm-En j r :~ ~ut 1/im.i'4Tit:inr:JB::l BchP.dLl'.e:J Ct'l'.r~'if1iF~JHC:1 -,1.:t.1:11 l\10il.150 Iii] '"''''"'"'!ti\'1i;"1v1 f!lf1j'.% ft!!k thei Monthl~ G'f!<Nil!"''fl li\&1:;.1l};\"jfi4 h".ii' f\j:;,.,.,<± 201 t1 CPJt.V<FORD fio;-p j ~!f.;' tr'ifr l./;(ol'.lich/ Cr*'''l'nn:R;12~(;'115:> for M;;i'f?f1Hl UBllil "'AE Dri':ltt1n';!i. t,l/\l CFtl;,V~f(lH)J 231'1. t~1,j<j 8!"11J fr.;'lf:1ln1ju1~h,.l 11t~~;f1:e;ti 2 c:t,inrriunleii!l ;;: n ~o ii1a co121111je! tor N(1~iDnit1J11~nJ E%u1~: cf ArnatlcDi, i.>4f1>.:;1 1 fili:>fit along IT:f!1 pi<>fir{'.i"f:;t; d Tf.ed A1ME8'fcitld Pk4n or lle!r"!lanl1,ii<:11 CNAVVF~'.Jfr.t1 J,::iA-1!!FSI ~;jrp r,11@ Mcrr1nl'i /i'l Ho1 fqr~tit.i'-f)1. f0v1~w ;!jf\f): flrt~j.'fl'l:i" : mt C!fl f;o~)lf::il'lj)ftilfd!lo!! h 1,;.r 1 ll&>l'1k r)~ /';r;1p11['.}i [ J!l!"1'Jroi k~ Lltt:i ~ornrm. Dr ~1'!11 i-{'.!flfl ~J tlh:: r;tf'.:d11tr1dir'vfill b.j1;;ir,.r.:je due at t:'ct~ tirn n 1}~ l_:f}1'ifi i'ff1stlj.:;11 c_1.,,".; 1 ~vrt.;.1-~~,:i 1..S v':i;:~,~ jj_/' _,::;i t}l'i;j.fi2 f;jii} L'Lq.,O!c'1!

142 The Law Office of Brett A. Elam, P.A. Clle11t ledger July 1.1, ~l'l1t' 'I StliJ 8.4.E Drafnf1 ;l, 18\>T:'.1lfl1J fh1d ~t1::!17j(!ra"lfi rf1:f! ()HJ,gr Ct111tlnuinq (;.~:inhtrnat-un Haar.c<1 o-f ~hr:t [!,~tr'.ijf l:il i:l CNJ, 1 l11 (ih_!j '.;'.t[jfl 1\ :-ri:1 Dn:irtin~d-- h~-ifv%hibj BniJ Ulf! G-er!!JF<~.O~n ;Jt L'lif;1n11~iJt Su,_JJtHi Oli!,ll 1Jo1 1' i?t:±,11 :::-~-;j!='7'.'i?pe!ili ')N it>t LDf1h:rT18tdJ11 hr~,ann-q pf!:l~i?. f)~tr:-gr BAE t~4'j~vvf(lrd Jit <ij Ait'1'.:, t~!fil!fl:~ng, f"t"'l ;,;f".:j ;kf".>;j &1Jf;Jfn1ftJ~g lf1%1 e;cj'g-1 c:r::n!'ll1l1,_fl'~j ;; ;nr~11rn~shr-<1!h!l'/li''<{j Pr@p.BrE>:j; ffnr th~ LL'1-fl11ri1;'4f,,;_t 1:.;nnf:rrna.ih;In llennng ut u 1rJ Oet>t.Gr f\tienijej thb C:Drt:iri1lfJd C{:tflf>f;\111iltlUfl h88lln1] ui If~ 01?1.Jl'C-l Pf Pf01Jl <J (1;4 t:hn r,c,._;c1::rrr111<t"i'1 r1~m;ni} 1Jfl \ltr1 D ;:!;'i"&r;;:c f~ P<hn 1 frdfj B,t.,E CP.t;,Vi/F(JR.0 )'4.(JfJ ~\~Q) Dra1!r>;;i, Jl?'/f.ing D11d 1_;;;J:.>TJ1.~f2,gi the ".Jfdsr cofl~inuing trlf\ i;;r)nfhr1lr.1ij;,jr,. \1gari1':~} 1Jf il"ir Di,::tr.or Q

143 law Office of Brett Elam, P.A. Client ledger hl'!" 1"1 21}'\-7.Al~i;!i1d00 trii? cun~1r1ur;r:l r:c:rihntieth:."jn of!ftr.: [Jf'.lb~ot CH;~,v~if't)FJ[I k''l'nlfm """in:;ronct fudli ' iil:,nn 1:itoparin1 hv ~h1:- ccw,flrrn-dt'!':jf'l h&tt1r,7\e;;r e::;1r tf>s< DnlP'.1,11 f!a,f {;f{a:l~fon f'j +U&3 A'.\{:,~ f!,_ul!f(~~w ~na m ""'~"" cunfirrnt41nn he:ml'1~ /\:i ad rj\tj!d0bhh IJl'!>ltiUll!fJ'lJhl{"r~ ~JF('.i ~U(~j'tlllflr1Q tr1..;, l)jtnf ' "'"'''"'''"the.:,c::ntl1tr<;.\,l;,:5-:'1 fpe-b- nrrg,;j!f1a f){:b1(:/ LSU~.t: 0-:-::l:fti:I!') :.ii:.,i f-1dy\i!!:', ~;.,:""' C k:.~,~ ;711 ~IJ ~M t Ffi'HJf z:,f [!ON?!' BM: ~,,,"'.,,, ri:.ri.ts fk;t.:&f'i.:j ma./t_r:: -..J:JL~- ~ fyllpport.:;f (:ont1rtn;:i,r;<n f"or ;n~ (~"',_{rx (ll1,e Ct:lA 1 lv'fc1f'{ tj 241'.:til A!-(~ Df11i'!lf'i%j ri\y!llt!no ti!nd 11nuhl'lriq lfk~ (;ry:fi,:f\qeb? o~ Piaf\ P!O[A.Prt-;11 Eh@ B:t-pB 1t! 10t:-1Jn>"'1!?:> 0'21YCl1"c:i1Y "r' l Jc:rc< ~ '.' "'<"J\ Ihr;.f: V f;isfi.0 Ht\E C;t;\VVFCH:f'.:li ~! 0{';(j (~'!Gt :P!1M1nlng Hild prnp&rln~1 f.r:;o- f;\1'1 1::.andfkii21J ::onf-irrr1aajc!i\ cj.~ ~ht~ tlfe!,;tl'.ir IJA,E f:t:t11;1t!ffofl-d ~'f1ch1 /1. 1,34 ;f\jsl:<?,'ifll 1'i '.f.>0yi Bi'Jd ~hei l~12spt.'1f!s.it.~ 11 ; l~:;j;' u:'4«~j2n ~c 1re ~._11"Cx'l4 cd Clt:-:"TI of t-11j*..j'l'' f\.;.!.'.,q,~l rr+~~1t',»'f " lf1d iyl'*'f22' ~fr<!' kll:;<:i-c>l }'.;ii' d1:>. t.j0t1n">l~l 1 / Eli!llh::'l I) \Of)

144 The Law Office of Brett A. Elam, P.A. Client Ledger Ju1 / ~i,.?llr1i;1' H~~f#' ttb~.w;;k n_o7'j-~fi"n~-~""1ji :ll'!a fhh f-;f;;'jt:,,c0r Df jf{j-s *~f)\,),t EXErft,-JiA~t'-iYJ 'Vr'. '}1 ~.h-<:c Ofld ti,_{) th:::o~l_!rfl8f1f" n+1>r.l1 s.j'u,,;.) tx'(t l~j<jvt<:'ff,:'.' pvt\mjo!fn~ r,i:,:.silfiilfil rit t--#;.\'fr ijtrij ;;;,t-:i:jl'fj''l? tl't>b,f,&;;j'.jf;.n lo r,h':'>iy" '&:8 l'.'1!1'9'.f trv Jff)f1fV t::i.i\e?44'.if\ 1\': t}'j r 1!@flfl[Of;:, jlti?pu.ffliii;}' i;'!fl(j re!...~iiffi;- i:f,5 tl~!fyj:;.ijc!f! nub::jeirr ~ "!KJ L.!it7:,'.trni&nh i<'thh lt'.<li.i l:~lj'blof!rt {J-!1t<p'!l!r1?1Eli'1n 1'i::."1 l;l\l?,!rule ;i'ntm f:!xi.i1clllr'12jf1tn1 a!1 1J1-'2f-l m (lf:1'i&1\rr,-r; :a:it. ;:u&k 'lt'if' -IBfid PLYEuffl"Z'-1ds: 1n ~r ri~ f1:'.-iii~fjl J"4()'-3 A-T~.Pfi1 s,,:; ~)L'.' TOJ on c.nq"""'"' r~«ns.ir1i,j &f:-r'.i t:_jlill:2:zrjiiji ';:fijz' ~A' P cm Mi6Jll;ln, flj Appn:r~r*: li!)!j:s }JIJb~Ii:~"ei 1::1;irrF;!,Q,pon0tr+;'j lf:iji; f:iil!i:> i nf <~f as;.ir:it G' f}\a :? l :.r.:1 /J, 'j [L3.J.:SU:.(Jl.i O.t<DO 51!0 l,j'd f~ [jj,fif1in1j, ~ fi~! lf1g E!tld ~!Jtf.~!n~ J:tll :J.~)CJ..,,7f](if!.2t! JJ.c;,;1 e..:dc;ihif r~rw~m i:; Tt: 9.a.;:rfffe:1 fvr th : c-einh1 r10tiun f"4'\./!ff';7'"'ilfi' it'.jr:<:lfif;,.~:it 1it1Y1;:r+t'.11~.{$ CJjYflf) '.1! f', ti-d E;t)tf( UAE CJ:J.,t1111Vf t.}.htj ;>"1 A I i:,;,..1 fl.:;i/if.~ u. nru~i.rw:.:g ;:±lv,j tufn!r<~ d1~ :1Ennnt~ Pl OVi ;,:lr,d ~J't lhi:r rli0bl.1)f tf'.i 1'\,;t:]f1d 1tJ t;h)' fi8.::jilf<ij {U'1 ~f,zy. ~Au 0.t011 '!ij. 1:.;'c:';.'n;rr:.: l!hr,k! ti:~ [BCJ~.jy 1 HJn EJ./iJ:, f'.ttf\1f. f'l.l'' ;;c,at)'"" 0Til$ hf'.'":1 QVf.fl 11 id J}U!,;.\J!\'.f?<.nl3

145 The law Office of Brett. A. Elam, P.A. Client Ledg1n Jui;/ i1 2-\}'li Pl<Jf'lf1!fl'iJ'.!JfF!fltHlr»J. th'!fj' nh ~J! \:he: doc,urn~'fifj b';f i:ti.a Dtz::;:;tq( nil nf t:o\t_"' th'fida1 fl:5 :,n or ~hifl i.: xr,i fofl!' :;l:'.l pi bf+!jlt'ii 111ndi the i'~ -:nair,>frj i:1-~_lf.;l!ith:jf1tu- ln pnir..tjn~""' of UTE! E ijidr;-:1ni1±1"1 +:tfl tn0 rdj1i''"'"'" i:-4.:inffrr;\a:'.iiori,rdt;~ the E~:h1t>i1 l<<y~y&i<"~ l:efhj U"i8 *%;:;+?1"'(?>41[~ in!j-fi4tll? 1/ 'i(/j 'J Hfrfl 11 HH-i OD p;!!?parmd and lh!'.'l rr.~rf,e!ni'1yu da.c:...!t!h:!xil.fi 1j. on:pgrt3l-vn e.t!fk"a mvir:ibnt&-er~ l1l1ct17ii'>'.: on i.c; -~ canib leo e-0nfi1ttnii!tinn fl,jso piepririe.11 ti':. ; E:~ hlhit Hf>rJJShrn J rand lhii% dncuntenlb u1 5,J'.1n~ 1 6J\E 1'.':.,tti!!ndfJil lf'4j 1:r~ hjt!nlirnpf 1_.Hl \Yi~t-U\liU! htj c;e:r&j:!ie.1121~ cvnf:jmafjlln nf lf:4j w rn'"' l'.r:-'0 1 i!1 f'.;,i',!iyf';(i"lj:t,;j Chap-~oi 1 i Plrnn crtavff (:r~<tl '..: 1.:!JQ~, /\ lfl:1 i:qs~:.vx:i r.2v::sj;1,g #>fbj.j:t:.p.t:it"';1 t'hfr Drrli:J!l<"'1et'1'l (:" :F1";Jti'\.&;jici11 ra:1t~j th$.;:.~:r11~f7&!1;.f). hir:i.'"lr.;; C,;o'\1l'T1U!1[Cf1t fyi lt>m.:'.b ith:~ "\:Jt:;Y1 'i"j':!f; 1F.;m.t:l<'1t: r1 1elah?.d i!l iitn~~ t';:::)f!fi nrhj1i 1rr t:if!:r.0 t)nbbj-i '"' i>l>.-t u~.;e crli\'.i\rfcfih!j.;.>itr;}.~ ~ f}.t f(j,~~ :pt, renict f.i i;.i/ 1,;j '.fle (;)!JC,~ff'IH:!~>ltJ J'.'.<l-aAclud by thm Diubtur ~D BCJfi'f rf'.11!jtf.7fj l\1!~~ ~ ~J1.JitltH:if1 cit lhe bus\hes:~ti?-s rand '!Vi-* fl'~u<:!ir~:d)::1dn rd 1r1ei f'i!r;<1qdt J>7 ~\.,1flf'lff1Q ;Tulf1d f11 r;;pr:inng f C<r the. o:tcf\jofflich n:: 1l'in Gc.bt.;:%1 i' 11B:\1J1B_<J l_t'"'' "!W.,/~;:%t~i'Jfl', '.Jf CfBwfC:L'!J- f~.f:.r'!,:'.'i'~';,o1,.:":! Fv'{ lili)f'j'(' 13Ji,E_ c: -RJ\'liiF1::::RC1 ;.z::y:~ t~~0-4 f '{l!'ji::, 1Jj'.i~, (E!'1lf.ii;"i ~1'1 '.J lll(tiji'y",i(v i f~'2 tfo:;c;!.lo:'i" 2.,~iDi pn::t\i',drsd f;y Jt1,.q Qol'±bt::;Y ~ITTkHftJ-:";Ji 1(~ t)'-'e mtlr:frftcahon

146 law Office of Brett A. Elam, P.A. Client Ledger J4 4 { 't~. 1CJi r?.:;:;tf"jfll i~: rlp:'pi :1 ;,;.1 trflnz:ri '! 1lu: li"1'o' :,,i:.::,?:! fr t:-tn,~nsu(~ ~P t.tof"f~ '1iii courw..!iftl.1'lfll!iatoo t,r.;.i i;tiq rj'6 rf:;ir.;1iinn r;f1i] 11 1-v prr:idi.j;:jiun <1r W0:rli!\1 B.AE Cfi;il\'1/l FGRC: Pirnnnin~~ n1 Id tirr!'rirj(rf'l J\'.ll 1f!Y'.! ':::o.:;f.;r;nabjti!1@l'.hiflt) J:\iU GRA'vVF{}F;f) ;!~(!(~ Ai 11;1nrfotr.J,1 tf'1ill con:lr1ued D;:.r1 firmabnn "r-::annij r:.i lh~1 [ialik;"'~::; u:an!., l1tj 11AJ1 R~::;oir;~. t av1b1n ond re~{)j.nd 10 1lur pn1p.;~;~hl ortler fr::r BON'{;:;i fo10tt.!'.'11t frff r~til1~ [JJ\E' R.&:.>J!~, :r!j-rl-"1'n arrj ~fllffiiti,~- lh'\2 f1zj!l?'o! 1!{!1ih t: --0 Porial ~o lflt< c._,\&fjt ttd<l~o(j h:;, i'f":'('o rn-~khhr::a:tfi;~v; f;o\iti'.!y 2Ir't:J W(<!t)iE1iptj d1::.:urnontlkti{:rf'1 rrr.i ~t1in rnnt1l~1~1qr;, tit thei tn(jjig~:ig~ Vri11f1 BOf'JY Pn<JJ&:: re.t&ited fq er>a [!A} Cflfl}i\l:f O~~ 0 ~-~06,.j'.11 j 0vl,-..:\,, ~«id 121-_; 'il:<urno::intsl.:.:'! ro. ~11c i"&=et'flr_:;,!'.!! b";-o rn1jdtfk:;,ut11::j~ i:1' ":fltj-itl ::f:\'jiil1jd llw',-ffl tt(;i~f"tf :J'>ifYf+ \ H;';i; f.lt...e Cf~J'1i/~,1#'.tJf1 n :;_'>V.f:J -l~t:rr;j.?;pl i d-rl)t,«) -ftn:j ctg-'ti'{.t'jft~j 1ft dq<;.;-t,/i"*;""/[% t:!}i'.ai!13d 1_,3 ~ha r:;~<l-h.~ghl ritl~'!i- p-;o;:~rt;r- (?h-'l'.--t$<1 t:{ >-in-err f}j;~):.;::ir p,,~.;;.,z DfK1l1Ui J HS' 1%Jlfl5! e;11d fli>r' Hl+e-li-~Jfl&+,11 t;'...:-fll'l?:: 1 r.11j~1on lt> r.~(d'1trnul;;! Conff17! it1:i. i> I :1lt f'b un BPiE GRP!!/'lf(}MfJ Z4C9 LntrnH 1;:11n'~'-6fiJ-$ll -~fl Roch nnd re 4)T 'if J\f'i rni:l-'4::<f-!1''!i!p 1;il'.:itP:-d ~tj llitr; prr1t:"tuz:t1nn :;:_;,f dcicvm~ t'.-!% 1,1, rh'9 Pon: ;!. A.1(ff tli\t [:fi4"1!ii

147 The Law Office of Brett.A. Elam, P.A. Elre ~t.a, Flinn, FK<l Client ledger 11 2()\1 4, 1 ~ (/,/:}'01 T 'f.jaf~ GFV\i/ 1 lf t1r~1e1 1-+DD.fi, 1fjA 1~(l t>q n ~x:'..."ttj ~17S.tin R*:d;;r2,,,1"t:h1n>'.:'j flnrj!jj'ov+dinfl tjnn.. :otlt<~1jjr'r n.t O~r.i::e t.:;i ffrb:fjdfliljji! rrol~l1tr~ ki lhtj d12pi>02<h or 1l1tifa f~!:l [J!~E CHftiVt/Ff~:J:t(J )~i:; 2 c'\1~ l~t1ce1r~, 1nv"'1Yv1 HnrJ :twf'itdyjn 11 1~ F,,t1: 1itJ11 1n f:;::,jf>pt'll 1jr ~.\nf,oti ~?'J Di!t"r1 $J'J- l1lod b1f (]f)ny R~~.:-:t"l >t>wktff'-ai' ;mhr;tl: enii4'(7w? il"i 11f rhr_;; ;: '!!-nf1n1q t.'+..a..i;ij1:,ry:rrn.0 rz-r trl'!f c.a'&>e.fu~ :<"it>l r..z~ ~r, l<.f-;"r+:: ~e rer,;ort14' f!$f&tm:m I;[! tr~ lfij,,,~j ~'1:if:'.;st!" ff~ ri 1"'i<\-'t::Ricn1!! rand ~ 1,; ~w;alicfl'.'.~ Dff ~hl& W-it:t'iiif~"l!! sr<l't;ft,,~~~ ~Yi ~?"-~ OebUJ.f JO Df!K!OaTMtion ('it l'i:f ryj ~fl*< Ii) l~r-z~ sunu:t. Cz.Jnf~l'Pnt~ Dfrnf'llng. r@iii&!ng -:&nij finn!12in!;l fi1'1f Pffi;f>\f,"Y ',-ti~ to::i tl\t1 Qrt,:f1y~- :Si;:,;f;r1g t iilffitlj& Co:'1ft$-2JVn;:;iy <Jilli 11t1_':;p0i,na; tht'j "n 1_-wrl! JJiar,f!-,-;:-"-'' l in ',,;!J11f111;;-.;:til ;.~_ :i ljf iii~~ Cn1'.lipl~l 1i As--~1 ~ fht:? D~-t-!1tif Ht :'(y~ 1p~ rn v P'~"'l'T.j.lll'\Q 1,1M;.r;-;-"Jf,fng 1rc:: i'16tof1hr11!'+ ff(jfi,-,f'~r ii'b f';::,rf"i;j! 1t!Wt.tr'cl "D lh-11 rt:-c1'.l!'l:-<t±ttro,n HAE Pr@?Z:f1ftt} fi1f tf1fl' tj'-'1~11tj r;nnfnrf-ti>-'.'.4 4:if:it tiv ~h2.1 C-c1uft ft:!l.:jtt;!'.j ir;. I~ i'f3'0::j ffp1pp {;'ff 1~!ln1'1rrl-G"h&1 llr1p Dratt il~v!t;ir;:g- and f_i,r1\; ~l!f1,l\;"j!n.rii:j0j;i W~:;ir11f',JV l}f)01ei ""' f{l!fjgrt 1'c1r!t'tfJ Gl1tlli71 Gr:nf :irt::nct3 f\ jfj-:,1 /(:'JFr'i~2' i 1$U:f ':'.):t@i:i:t t 'l7frh141!'1"'."il~ IL-'Jc! nt!\'y,~>9>-:1 l~ji t;f-&j n::h?? j, rtl-frff 1-~M Wf" Pi""'ii1'":n.J fjo\j t1:lc..;~:" ti;t',;t{f',f B.!'id i!m1; f,)(c-,-;-<;'.;j;-'0'j C'Jfttf:- ( (:;liill thf H::t t~ f;l!b'.:ll"e: YJf-i--_;f :;:r"''tnt;f_i-.:-,~, fr"'-~ r:.1jo1!1i11-'"1ltu ffr FrE1!.'1$Yi-ilf1 3'.i!l ~f) Uli.E, l~\ft/\v\tfop.lo :;'.40~.J,;\'!f!7 i:n)iil!-'.-' t!zy,)\ on~~ ~-Hlf1 lft.11h Fr*-1Jr,-1~n fl'.';'li!lltr::'.i tr.:; thb DObttr:!i@l fiimtflr'lffh'?lll nr IllfJ tf-1 11& IJ.BtPJ ~31~

148 The Law Office of Brett A. Elam, Brett A El,arn, Esq. A. Client Ledger i'l ~70~7 BAE f~l#~f1i!:lf (;,fiflkj 1~ i,jj~li: l;}ftln'"tij :;~l.jit!t~j f;:j 1f i1fr '>,i;!!'~ii(;.tt :)f t!t+ ~tv.ndu1 i:h Hts prt~:i rtv, (f!.fi.b'j!llq (!ti'';uf ~:ff',0ff4lft'"ar$ f{v, R.f!iJ%! tr~ drftwl>bfll l/;i!f4jtj1lg e:~ fft,}fti Df/\fi; f r~,m-,c'~'"'~'- 8p11HlltlnfJ <t.hj 1 To/r?tltt>f fro,11 ~t1jn:j1jt!il17 nt:\.ed_!ftt h;::i t~o0 V@.llJi:1Hon t:'.if tr\@ rm,a.j t:ir~t:~4y t:t.r~f~ CRA'i/1'P-fJRf1 l\ii@nc.'-w rnee~ing 'Jfith (li~rr-g, Ll!\T~ Gf{~\1,~~ 1 r:c1ro Zil~'.)Y),_fli1GA Ht'tt:-Bpt <"~ith~i. at:,cj ans:tzs tili f~e:~p:onia rr Opt>'.:l5il.inn 1(;:, Lo;~ ~U(A'i fdf J:xt~ ilhi~j{j IQ I<>" //, 11.eal.:;-t;;_i 1 m!t: Pn1J! ~"ihni~nac~- rat~3~ vlj L1!i'1>C ;e:~~:pt;-tt re-1;:.:irt-s, r;:_~u1red pur!ih&:ilit k.:i rha C 11.;rfr:;. 1::)n:~1' RrJ1:'."..tti~iL l''fjl<i{t'i~,;s,1".;j t;>r+0'.~'j'&!fn!: L!t,:'<'.:<li'l\'2:Ht i~h:n; ~fli~-g T;]()~f'{ i~;a\m@ r.tj ~h<e: r.vjfls. EFIZ! f1cj0 P!fifwlL'.'0iJL pi npstl,--.9 t:1fitt onl>!!f:s rela~ ro 1fl;n prc:~jf6til'.lr1 rlrj!c:cl r JJ?f'l4!1 f:':t:?_:qrrr::i:r,it;.q ~1:+ nl tr"'"' ITh".'i 1"!q:.;3c: -t"':j EJ~\E CF~A. 1 t:t'fl'.)f~'ij 24-Lr~i,i'.\Jl E<rd'2Jj f:he he:arw1g: nn tr?!' Y>.~r;1c;r' I:.,f E.~ltit'-\Jc::tn 'J1itJ'i.;~nun; ()1 d-r;,+ of 11'1lt:J-1r,:.. 1: '..HA 1.1"~ 1 Ft'JH!J.f lcl'.i [J'ntilif '"'-"'""'l"~~hh Ff,rf't~r-1Jt-"' r e!a:~2d ;w, tl'-: ;s fi!1fc-o IJ5,-d!JI 1j.;:4"" tjf tl''.-4:! C.tJUl't,!2.l.nd 1hi'J l"l'.'.'.' "">'Jt-~ or f!hh'.hj~l?"'tj f;ft i?;:i":rb of thi!j ;i;;t;i~+:!. f; ~':>[f :'!i 1(J;-1 Hi;;--::fli}';fl, Ff;'lif;;Ni' Xi~Mj ;1!."iiii.'.'J(f"ki Lf\~J: ~/:(/'.j,":fj ITC< Cl.ff.*< It'} :Sl'ii;"Vti (:~-,~i'"'.'i 1/;!%-f#-'J:i Ii: ite7-!:;i\i$4 &f>~'1~/..!r-'j rf.jr::ntti"p Hll~t 1"'4'.'.l!lf.;;JfJ.{"i!l k1 f'r(j<'fi;~ t :)'r)0!"! [_".:'.'.-1Jtlf!l/,;ef..:f HAf (; t{j\i,. 1,;1; Crfl;f;; ],1(1.i± flt>-tk)lj)l ft:rylg1v iiv!lt A:IHll1fJe ih"'j fi(_''.i.})(1 tiy 'lil~!'.!1>f'101~,;f,, on.;t G4?HT.1~j, re!,a 1 '.it"";j it:i H1ie1 "010,00-''""' n"1 1lh8!: 'ljij!l.j;f'kls>s :ifl;a1::i-:b.!!3 of: Llis Di:!bi.or 2nd t_jp:~ p1~-c110''"' ar the Huf1dlJ.fB:'.\ n::al PJ'C'fl(!iiy /::... l~ :::,.~

149 The Law Office of Brett A. Elam, P.A. 0~10 Eer\1pl01"" Mil!fillH" hwu±t::;g Cn-ri'i:t ATifi-1'.'JL!:fH U f1f:flj,!e':l!:1ffja"jj:litri1 ~-~ ""-"'"..== - -~ ---- '"~"' ooe< ----M ~~- E>'J;,/;,;,~1i7!ME C.R/i,'ll~'FCl-HD 2409 l~ iuo.?.bi) IJli :;1 1'.)l)'J t.70h.c1{l 1',~'?;1'.;nD <A~fh r-jir::~:~:e 1 tj1rnjoo f1.j 'lhi4 tinf\1-q nr rj1u...,.~_,,,,,""'"""' (';.~'; ' 1:Jrnfung ffjv!x.jrtg e:ind 0'1~ f 1Mfl #.,-~tj!1:/1id1:n1 r::f 1~~pl:D1 t 1 'J'.1';f$FI f)f lfle v./: ',-.;,;,:h 111.::trrpr;1;:+te11 tf\'!3 1rtlum1.1e1n11 nf!jie bu:1ar1121.t 1n~&1r.nt:s t'jf 17,;i: Debl&f -fldl t-t-1s va!uatit.jrl..:::if 1.t--~!"t.t;t;r;dut ;lf&,z;:al!r"''3t1-t:1tv ly;1,n.jtw41. a1i.:i\l t:11~i:tlng ~Pio F't:4:tn(1 i"ff;;i1 $1;JCfi!!'B;j!M' ll!ff'"if~-~ M<:t ~JZl":a W"-~j~ %1,Jtr-end'2:r ~vd~ la"m fjh&'!4'.f\11':f.l faj t;j--.:a Finn Afh-Eridi;"".~ 11 Pt,~ 1 110\J DA.l~ CRftV,r;:'C)RD J:>1{JiJ A!C<1 re:da1ng a,nd f1nc1knng L"lE t;,* ::itjcn r.q Drruf!in~ '-/Jt::;41 1 j:i f}nje:r f:r_,fr,pi;ijirn) P113li,;r::L0:;i:n r:;.if fnj11-f, f~i.,'. ::.. J,d i f;:t::'-lv31j". fjj.\.t {;;t{;-: i,\llf',;:i1j,t1'.e} 2<?::~ A 1[?"1 0 5\JU i'~lf!c%'1~ 1t r~ ;;;.:e<if ar+;f. '&"l:l'. ir'!yi})i~.1\.% 3 f.'..j?c t:1v l?.ony in llii!i #ih:jt P1 ~o VEicEifJ? Qrr_14!r P:i: i:r.rj.-:arin1] f,;2 thv f:43annu ;;:in!.hm ~~1ut\GJn ir,; Ei:i:;zutl%i!:>:pert Tell:i1rr:t'Jf'l'f FiLrnJ t/t E1l)M 't' f:li.f (; f{j't..il ~r()fld?.4fjb /i,,1 c9 r'\tffll' i:j(:mj \hit! j p~.f!r:f J 1)(1 tr'j@. ~llulli.)71!.j.) E:i>:L'Hdn ;c:... i11-~j t N f.0 t 11 e.<;..:-rv C-l1 iiltt ChrJi~IJ'e GIHHli ""''""'"!I!> $.~l.t;1}.;1.ll1} lfil.i < g3 :,,Vi}-~> :i}{i ~~~ --~ ~- - fot, f ch ll~ Tc1U! I t 0 a:fi'~i~t'l1» ~--~<= ~=-.,_~ ""''~

150 ENGAGKM.ENT LETTE ENT ~ ou l:iankrlwtc'\{ AND l:iankjutl'tcy ~GAL SERVI('. ~S <\ND!! ATI N lhis Enge>gernc:H( Le11cr dco<::ribe.~ the basis Uf""' whid1!lie tlrm will pw, ide y1>1j wilh lev,ul knkcs und is th<: agn::cm:'!nt bdwi,-cn Kim C. Cn.wford, hereinafter r\:forrcd to us "Ciicnl". Wh<)S<: address in I090 Corn! Way, Rivii;m Bench, 1:L lh04 and who;«; 1clcphone 11un1hcr in (56 l ' am! The L11w Oflicell Gf Hrdi,.\. "fam, P,A._ a flm1d11 profes.~inn~l ussoci~linn, hcrdnafkr i;ullectivdy rcforroc'tl tc1 us ihc ;,Fi1m'', whose <!dd1<:s~ is Ill) Somh N"rcisslis iwem1c. ~1Jii.; ~02. I/Vest P11Jm!kai.:11.. i'l I. l'rofcscsfo.nal IJ11denaldng: Tho; rnost impornml point i11 1.ht~ lct!cr is that we will do our utrrmst to ~.:rw y<)llr inten:sls cffeciiwly. We canm>l grnmmte>;) tj1c ~uccess,,f any r,ivr11 wmurc, but wo will stnve Ill repr~scn! your l1h rcsts viµorotmly and ctlldcrhly. At the fllc.'l<:m time, we hiw.i equal responsibility for' this reim:scnlalitm~nd Wl1 will utilin~ other attomt;ys atid legal ~sislanls in our t1m1s_in the }' :st ~xerd~c of prnfi ssional judgrnc11l his nur p<.11icy, 10 lhc maxmmm Gxtcm compahblc wnh 11"' quallty ot our wmk pl\"n.luet, lo ru:s1g11 pcr.~onncl in a way tle8igned to [lmd 11ee r.rpid aitil C<:<Jnomical handling of111a1tcn;, 1, Srnpe of Rcpresent11d )!!: Client hereby retain,; aritl employs!111;: FirTn as my/nur <'mmsd m mpresell! me regnrding tile following limited 1md stated matter: ('.llapter J BANKRUPfCY: C@sultalion and ar1alvsis of th!il Clienl'~ finance~ att1l e"\'u ua!non t)f avrufable legiir n~mctlie,;. i11duding brinknlph:y; addressing 1md r12ccivi1ig c~.?iws!j?llderk<i frpm, Cliem'>i ~roditorn: l~er:u c~n!atlon in Uis t;:hllplo!' l l fa111.k111ptcy. n1~.. hmi w11l also assisl m 1he prcparalmn ol tj11; ( haptcr 11 pct11:lon, schedule. shllcmcnl ol fil1mir:ial affal~'s.. s!~_t;..wcnt of tum nl mc1;n1hly jnrnme, me.ans lest palcuiml~m, plan and ±JIJlttmCTit of HJienl!qn; and Re1Jn:8mtat1qt1 o~ an~ ntte11tla11ct? mili t~e Cht;nt,'!t t!!e schc'<.lulcd meetmg ol cred11ms W 1n!ht' as>rniam Umtcd State~ tru1hoec asmgn1,xl!o Clicnn casi:-, often refo~i:l io ss a ":141 m~i;ting", /\, Flf~M F.i.'1\S: In ~.-1r;~i krn!iu11 of!j1e ~crvi.:es remk~d and to b" n:micrcd bv the Finn, Client hereby agn,"1..'s to pay to Firm a norh<:fumlabfo retailier of $l 5,0(JO.Ofl ~"Initial Retainer") llirnullmlcm.1!11}' wi!h the execution of this i\g.1>,;~1no:mt Th" lnitial Remfrtt,r shall be deemed chj'iled upon rcccipl an.j shall oo paid 111for lo any do,,lmwnts bci.ng filed by FilTII io the pending Chu(. U."T 11 hankruptl:y rdcrei1c..,,l above. Any further rim,11m1 tlue aml payable!(> die Firm!>hall be payable 'i>1l*cf to future work pcrfom1ed by Viol!.for the benefit f)f C!ienl'$ Chapter 1l pr<'l:t:.:di11g, sul;.jei;t to applicable Fl1mkrnpt0y mks all<l r~gufa(inrc~. Ii is 0x11r<!»S<fy mhk,nt11.»l lhat tl1c Firm shall ha~'<' no ohllgi.litm tq represtmt C licni ir! Ml.}' m11mwr or forum wl~v.::1 wth"'"' and 1miil the non reluodi~blc lnitlal r<;luiner i~ rc,;dw:.d by the Pim1 cmd all iern1~ under thij< Agreement are Ctlrl\li tiorml upnn r«n~ipt and ckmunco of'iljdl smmml Client cxpresst~ unders!luid~, agrees >lllll arpmves l~hi Firm'~ initfal Jmn-rcfo"idahlc rel.hiner i~ deemed earned when pu.((l CLJF:NTfN/TJAiS ~~~~~,~~~~-~~~~~~~~~~~~~~~~~~~~~~~f'mfrl'~,ff--=""'< 10~ South Na.n+~ ~u:; /i.'~'l"ihjc', Suite- :;.:0 2 W~!i! Pml.m Hc-ni::;h, FL J,J.401 5(~ 1-'.liJJ-111 :'I,; F 561 :!'i.lj- 'l ~ 15 r!yj~(l.i'im!-i~it:re-tti.:!lamk1 1 c\ ',~~;1,'rntl "' 'J/~'IP~V.hfi'l.toJ.dn:nlkl'w.r..:OiiTJ

151 PIE I AV.' (JFF'ICES C-5" BRETT A. E'L1\M, PA ll. C1lAPTLiH 1 ~ 1'..t.\ t~'1enli;b,ovisloc!; ClietU i.mdcrstands. apprm es imd a!)rcei; that the Firm canno! ru1d will not. umkr ru;y cin::umslim<:l'5, file any pctllinn or paper to initiate a hankrup!cy ca~c mt tichalf of Clic111 Uri less 0.0;~ urtti! tlie IOla! foe und c:osts <Jf Iiling are pllld in foll and received and cleared by 1hc Finn. 1;,;ccpt for those!~4'.:s which will be paid fiy'"' tlm pl>m as may be agr~ed upon and J;mcnded from time lo 1.lmc. (. COSTS ()f AC'l'l.()fj; The Client is respmisibti: for all costs im,urred irn reprn0<e11ling the dicnt, including.. but tlnl limiled w.!he fe~ f.s) charged li:r <ltl}' i1pprtw1:d credit cm1sultath>ri ;_1g< ncy providing r..:qulred pre-fl ling nnd posl filing tieb!or "''iu~atlm1. llw Cli~m is responsibk for fhlying the tiling fee iti 1his nmut:r. bdng $ l,717.00, which I~ NOT incllll.k"t in the Initial H.eu.lner.!'his mnmml 1~ sul:ijcct 10 change Jn1m tim~ lo; lime ruxl the l'irn1 shall 1101ify Clicnl n,; soon a_, prnctkaily po.dole If the lilirig foe increhse~~ or dec.rcasc$. D. FEES: Clicfll ackn(1wledgl"' that the hr1sir for etmtputing Finn foes has bt:en cxplaimid 10!he Clierl( am! drnt Firm,,ompe11~atim1 i~ l'ms01j or1!iine, Jah<:>r. novelty and difficuhy ofrlie kgal mau~r. r.ime 1imimtions imposc d. and 'lhc cxperic'.11cc aml ability oflh" 1-'im1, Our stawinen ts for professional S<:rvices will bec ba~e\i upon rvlr. Elruu 's ~um::m hmtrly rate tjf$350.do fl\'r!iour. firnd<lition,, pmukgals uud law clnks will he hilled at$ I I0.00 I'"'' hour. We reserve the rlght in ru.ljus1 our h<0urly rates unm.mlly.. Client will also J,., hilled fot <!i:;burserm,nls and other diatges relating to mrr pmfossional services.. :foch charge~ may indude, will"nd limitaiitm, filing f<:<ls, long-distance telephone < au~.. rnmic-r service, tnwd 1Cxp.:nsc~. plmltwopying, :<!t nograpber:;' chargi:.1.. transcripts.. court cosrn, llppraisab, iic, 0111ntanr's fees 1md cxpert'5 fees, ll.11<l 1;omputerb:J l~gnl rcsemch d:iarges. n1c Flrm wilt bifj yo11 $ l]:lllgc fo1 photocopies und $ UHJ/p~gc t(jr taesimi r~ transm ~ssions_ r: CLIENT COOI?Jm/1.TION: Th~ Clt~m agrees tl) [u!jy C(1,;perate wlth Lhc Hrm, to respond truthli.jlly, ac<::\m1te!y and promptly k au requests for i11fom1rnirm. dncum~j%. sign~\ures, ru1swern to interrogatoricoi, aml nn}' oti:ic't r<:quesl by th~ Finn. to art<,:n.j ttll uppointmerlts, indudlnm, the Hl meeting nl creditors ruid, ifnt.-;;e5s;tr)'; deposition~ und any and all n!flcr rcquiri.xl lit:arfngs nr sthe<lufod ev.;rli.~. Additlun11lly_ t:li~'nt Lmder~laruls 1ha! Clicnl 1s nhlngaicdi > timely make plan payment~ cnmmcndng shortly after ca.~e filing, tlml Clie11! is obliga!<!d to strkily 001nply with all r11lcs relating lo Jchiors in fl<.>s:;cssim1 sueh as creation of new bank ru.-.:<jtmls, Cn:lilion and defiv<:ry of debtor iii posse.ssio1i reports 1mrl slat<:m~ntlf, and such olll<'t rcquiremcnis a'\ m!ly be imposed upon the deblor in pn~\:cssion fh:im time!o rime. F. i\l;i!y OTHLiR. t<.::i/\ TIEf{~: Nu ull1~r li;gal mm1ers otherthilii state-0 h"rcin are b1d1«k:d in this Agrccrriiml und Cticnt flpprnvcs, umkrnlrmds ood awees tha!!hi; Firm slu1j! rak~ rm uther <ill!ion on bdrntr of Cli..:nl ruit! 110 ucrion wlll be taken unkss 5p~cifki'.llly rctaim:d by separnrc "~ iitcn agrcerni:111 for such :>ervices. Further,!the Client lms lx,,cri <!<!vised UJ!d i1dkl1owldg ' the conscij!lc!le ~S regarding the, fhlng of a Chuptcr ~! bankruptcy pc!ltiun and all '11Cli1ms th111 m~y be hrmlght by tile Assi$tirnt Unilcd Statr Trustee, aoy app..iiinted bruikmpk:y tmsiee, or <'rcdihirs of lhe Client. CUEN1' JN/71MS 1()5 Si:nHh Nnn~.i.i;.-;LJ:s.Ai... t..ilil1t'\ Suilc ~H2 V1/tBt Pr1hr;1 Hc--.3~h" FL :l'. VHH ~ ft 1-:'{l:l 1! I\ F 5f1 l -RJ.).. ~ ji r 5.. l:n:. ];1:1~1i:i_IJ,bf-e1tc];;:hlll~w.cn1n w ',lf\l;."'v1.bn:lk i111nb 1 1r".Cllf!l

152 3, Sn~iik l\:x<."lusio~~; The friilow111g are additional ~er. \cc$ which the t:in.:tm151ull\:cs of y<:iur caw may ncee:;sitaw or you may "clc.cl and OU'e specifically ;:.~dtr<lcd from me ;1hovc rcferen~cj rcwcscmuui1_in; sh<lu/d Clk:nl choose lo engage Film for <1ny of rhe l'ohowin~ ~"rviccs, these are hilled sermrnwly. <llld ~hall bt: hilled ai 11 llal rntc or HI a staodani hourly m1e._ plus cotirl co~ts; All litigation inclrnling, hm!lul limited W. defense or~ny aj.v,~i:,,.~ry adinn by m. dit< rs,!fll~1l.'\:s., nr llll.y uthcr iot~rcsled particll; 4. l{cium oforlg,inal Oocum~ll.1.s; V."ithin lh~ firnt r,inety (90} <lays fo!lclwirng Climir'& disdu.rg<' in bnrlkruptcy,.:onfinnildon ofclknl's b:mkrnptcy plan, or closing ofclient's c.:ase, Firin shall, within a rea~onablt: p;:riod of jimc following a written re4uc~t hy th~ Client.. return ro Ctienl tmy and a1j original do;:umenb of Client's which l'wd been pmvidcd to Firm.. Foll0wing!he 1irtcly..d11y period si.t1icd 31l<W<'. Client wttivcs miy and ah right to the nornm of imy origirwt documents whkh had been provided to Finn., us said tl<j<.:urnents ~hall be shn:dd;;;d ta pn:!l<:rve confidentiality. lhi~ clm1sc <ki-c;; rmi apply lo Firm "'ork pr1_idu1:t.. 5, Terminlltion of C<.o:l!rad: Uicnl um:forsllmds, appr :>vcs and ai,<rces 1.hat ifc'ricnt fairs lo limety comply with all of!ht t~nns <lrid co11did<1ns of this,\grcerm.:111.. if }"<'U fail 1<1 timely comply and cuoporatc- with reasonable requesl> of 1bc Finn lt,l cn~ure prompt alld prnper lmndling of y( Ur c.ase, and/or if any o( Client's rerrescn!ations are folsc. the Firn1 may tciminatc thi~ reprcw111a1inn and withdraw from rnptc'lcnta1io11 promptly uml ~!icnt agr<- cs thar C!iclll will rnrtscnt to Firm's withdrawal from rcprcsenfa!ion 1111d pay for ah lc!j.al!lerviccs ilnd wsts incumx! by tlic Finn tlh'ough the d'1t ' of withdrawal, I\. Statem~ul uffaet~ :rnd Affi!l!!atio.ni.: The facts and al'finmuions rel<iit.:d by th-e Client In lh~ Flrm ~onccming this case ru"e tnie amd com <cl lo the ties! ofcll<:ot's klmwk<igc.. \nduding the regul~r incom~ of the Ctlcnt and rile valuntivn of al! n:a! and Jll.'fiiollal prnf>tjrl.y of the Client's C$l<lte, and Client appmv~;s and agrees!hal!hl' Firm ma<lc a rea'!-{>m\bly dltigcnt inquiry of the fimmdal affairs oftl1e Client 7, Nn11-"\lt'm<ive1:. S!wer~bllity Fonnn Sele..,riu11: Client umlcrstan<l~ th1h tbb Agreement n1ay onfy 0C. 3rne'Jided o-r clwoged upon written signed ugre<iment }f tlie parties, and filrthcr lmdcr>1amis and ~g,rces!:h~i if 1my j)f Jvi,;im1,,~-till~ llgn:cmcnt is detm..mtnc<i w be voklur otherwise ummforljellble, lhcn the rnmnr11ing prnvi~ions of this Agreement shah ~main i11 l\111 force ruij dfaet Vcmoo for c11forcemc11l -of this contrru;t shall be in Palm lki.1d1 Cm.mly, florida. 8_ Client lkl!ponnilluhi~ 1!1tdAi;kn11Wlli$1 i:mt\lli: Ii ls me C.limit's re;ipm1sibil'i1y lo JHTlVide aec;m-ate creditor narrico, currellt 11d<lres~e:; al1.d accotm! nwnbt:oc:-1.. The Client ndu1owledges nltlll it fs hislhcrllheir obligation lo obmin accurate payoff ~mount$ on all :recured loaris. AH co-ohlfgor~ ~}r gl!llmntol":') i1ws1 h;; Hsrc.d n11 1h1~ lxmkrt1plcy 11ch(;dy]~it Alihmigll the Fir.ii <igroc;; to utilize it$ bc.~t effort~ 1.0 e11sun: rhat Client's filing ts cnmplete and m:curate, Clren! 1Jn<krshmds, Jl!Jproves fll14 UJ')-Ces th'lt it i~ the Client's cluty lo ensure that tfuc schedules anti 8tar.:,1m.m! of fimmcial uffairs whid1 afl.' prepared mid signed arc ac.::uram an.j tlmt no mlsr~rescntations are tlimk. Thi' Firm mlvi~e:d Clieii:t tko:t the bi:flflt.rupt<y pe:1:ilim1 and its rehti!d sched11les amt statcmentf 1~ill /,.;.vit:ned hy Client wuief the pe.naji)' ofperju~v. ArtY willfl11 ~m?prese11tatio11~ IMJ! resmt i11 criminal prm::eedings being brought ngai the Client hy lh tt.vepart1y1enl of Justke or s11ncri1m. by th<' Com"/, inc-lltdi,~g tlismi,,.ml of rile C<i,~e ;,ml otll~t penlllf/'!tf, The Clien1 ~hn 11 prov id0 to Firm co1lie1l of "H 1-c-qucsteJ J(>c umrnt' Cl.JENTJN!TMLS ~05 :\':oulh Ni11fti:i:TiLi;; J\ve~Ht~. :Suite :H.02.. Wt::H P.alm B-enr::h, FL JJ<fO'I 5(~1.~JJ. [l Ll ~ F.~(;.l-:!-Ltl-11 L~ t...~jnn11{i'~'.brte'lh!tn.n,1l8'~-.~;r11n ~ 1N\i.: 1 /l1.b1r.::hel,:-irnja\11,' Lt~m

153 in a fim~lv ma1m"r as Client t1rn:krstw.11il~: that n lbi!lrre to do so may result in the: dismissal of C!icnt.'s ('abc. ni~ Client umkrslan<ls 1.hat certf1in dd:>t~ are n1m-dtsehargcablc, including Momc IRS lnx 1drued d~bi>. stud~1il lo..'ids. iilimony, child SlllJJl<.>l!, and emlit rard dmq;~s or cash adva11ccs Within oim,ty da)'s prior to filing, ff thl' Clietll wi~hcs to keep certain pmpcrty. Client rlf;.;y have!o reatllrm!hose <kbl8. a~ wdl m; 1u1y Gar loa11$, fumimre loans, lll<iflgagc ; m o1her '.<ecurcd lom1s on f)ropcrty the C!k nl WiHh ~~ ( ) o..'tain. Th<~ Client wit! rccet\'<' n,">tk,; ui" the 341 meeting ofcrediwrn dirl...:11)' frnrn 1111: cnun. The Client'~ uttcndan<~<' at the 341 meeting is mimdm<>ry, lflhe Clienl foils lo uppear. the case will be dismissed. 111e Chen! imrn! present a 1 11fo:l 11Jioio idcniifirntion u11<l >!Jdal Ac:rnrity ca!fd at 1l1c.14 l meeting. in oodirion!o nlh,,r "'""""~my and reque ->ted documents. The Client may also lw r~guired to suhmic to u 1004.lcp1.Jsiticm by ihe trustee aml/or any 0rl'<litor rcgardinj!, iifly charge.s, as well us Hvc Clicnr':~ fimu1cial conditl<.>n. Failure!O apr:.i:ar ni the dcposi!km. if sdicdulcd, mil}' rn.>ult in dismii;;:;al of Lhc r.:asc f'r snnction~. l'lcus.e review!he foregoing and, if it me.% with ym1r appr1.11 <t!, sig)l thb; JcHcr umj rctuw h lo us. Jfym1 h1w<' any question~. p!cllsc call Thiu1k you!<'>r the (>[lpurtunlty I< rt'.]xcscth you. We look forward lo a successful re!;1!ionship, ~icci-e!y, f' rwsa<-~ Qfelt A. Elam, r;:_.;q, DATED!his 18'~ Jay of Augu~ APl'ROVl~D AND AGREED KIM C. CRAWFORD CUENJ' /N11Ml.S t(l5 Soull~ :S.;111;i~st!1' t\vt:11ij7!!., SJJite R:fJ;::... Wc-.~I Pnhn Hc;il1::J1 1. Fil. 334fll ) 6 l -X_\ J- f: I 11 ~ F 5() t -R.:i..,_ t 11 5, ~ hf:l;;irni:~~-ihrot U.c l."h11j1!1n_i;,n1n r.r\i. w.b-r<.:~hel.arn~a:1&.1.:-nn~

154 Activity - Deposit Account f~oi:tj;t (lf C!J}1' t'il b..bj41 IC:!i" /v.~c_r+ce:;:1lf/ii1 r11;t-incj'.'! ~l>" ::."-,ij [i._,.:ky~i I~ 11,~~11.n 'TtkiiY C~tv<<tZ''{J (';~:[J. ~J:,;;} :r~~ #V..::;;::E-::;:s,dro ~;:) lljb.j:;;j!l:<l. (f 1 ;e.fir~ "&:.~!J.1>6 119 z~i,o~~:'l. r.'.f4 UD'le t.:<q\:)l!l, Tt.mnmB1Aits't t~ fbf.i De:Jiid 1;'.e;:Jti1y1 111 ou ~ ~ V> ~v 1f51?0 t7 /!,\! lff1h?flfffl!l'j l-"'jtjutj"4u 11 w 1tr1Jt:t.1n r'~ta1l.r_1cr- «:1;;;n ~---~~~--~~---- f)tj()f< fhl';";sper c:ru~on Ri~I fief '!:S'lt44-U TUNC!l~ 1j"'\ i,, (! TIF!/ J~!1fl:rl FH'~.~tit:_B 1F:1076$.~,;:p,ot.~ ~~ ~ ~ - -~---.. th:an b~)l)~~ TFiil.~~l:S(t_'.:J;, REY t?4 t~4g:t f lj~jds 1l~A1-~: :t=.~ :Jq, f'.l'tcf-<i_4 fj(;:fml c: l 4-:-A!t.l srr:r:;.![tfp{"'1s;it 'ir.j DI:? 1H1fJffi~,::l 01Y.ifjf)f\fttJJ110JOl)J fm)ok "i ftj~:t:;sf'lh Qf:l'H'f 11 I! r-' '1 '! t)filj:.tot 1: l JUI')[~, 1'R1\.NS.r.Fn "j! f} r:.f.p l'i'.! 1fili:1t,.l fildf,_4 tkop.li r lp.aj.jh!-i:}~

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160 Gary llll. r"' d11u1n ['.1,i;!r::..i H 1 ~: F!1 :.~fir"tc: ni.'.'',!.:.t:jj,(2 {. /., ""' "" L.: r 1ty If?''* 'po~ltton; aij~;~)! ute;:tll! h: :O ~t!f!jlft i\f la11: l~lr: rn hr11in-lett: O;n1 Mg In IDp:r);wldlh.!;l!.5~t;hniBl\1 J7.Spt.:i: fj<~r ti'.! nt.;~j,;m.so wra fi"" d lt;;.t;;i nit.e - lett;_o ~;ttr?& J"\_Vfdp d Ir.~ ilnrf"-io p :O;tn~ov'Nt'~P...iJbh~t1ce s~afn:o;ttl!i.o v~ lf:!j f1'-dlsti3.!lti"' -t+o-f. tu,1n.fj;rnst1-pqtill!n n hdr:1jatt~3i:1tit~;tti '.\rt) po~iilo&1n,.htjkvro nt.uj pr,j r,i t~on ve nfr; 111f -:r11;-j;;1\fvit:; llrtr::; ms.er- ii.vn'.tn Fip~-rcq nt~q ;m i;,r:z h.uf.r;ht. ptirt'-'iffl t :-0'~!Yi~~ -.,;.1;dtt1 re Im: tj.;~:pag~; ITir;-0- heigh{ if I.'? IiithiB ~ p;;;tilg" CJ yi[!1'.))~ti:jvej rla p:;:;- 1 "r in: btnto1ls '"t 11 :.~.2 J.,:,i:1,_,,-,,, ';.:~1 P.4, <:> i;ll,, 1 :.11.1: i:~t o~:~.~/~ ~ 1-r: 1.41 v :~1'/11 r,,,(;. J;!'i 1 Hl. 1 \ Tf.LAJ J'i,\t1. 1 i\l\jf\ 1!\Pd 1~ ;111 r ~:,, '!' FIU VJ! J>!,. J;1,i; L; n.;- n.~l.11i.tf~,;1 L\1 r. I j,-:;, t:i'!'l'i'" d !de 1 c-~ ni:f- f.." lj!<fv 1JH ' 1 /it iij.b; i.'~,,~ flt\" u \Ml n ldlf t\'i" ~-\ v AT l'ld 1i'di f'j r_', r.; 1 I Ji'.jl) Tl'V\N~ 1.M',S':'J:ON i\li I. H ht Hiic: 'ii 111! irf H1f t.i\' il! r+, t ~-,~.;\!' \! : -,.;, rji. l t:va((. r ';\'"l,t1\'rt L~~-,i, ~.H kj.'?l;,,l;~1m rv: J "{!, 1Ji'iil f,f1f.'i"'<ik.'\ 'J',H }\) 1_,'i 1 fol 'IF.?1 r-i?" hf 1 ~I~,\J\'~; \l1.'1sh! ~ ~)j. '! it4 i }~- HJ 1!' l!' ii I 1; -~:ii JL nf~ 1 \~1;1i.-\JJi. ; L"' t>,!"-l"h- "-i"nrn i: 1~, rll A"'i 1 f fi5.1.\),) '! J'f 1i O.i' 11 7 ~ Lh.h~ t~ Ll Yll'1; 1'1;::- tin 1! i;i. :.r ;,_--J 11qHT ftlj!.;-, \1P>1L i~ J1 ',J,_11: i"; I '1'1tsr "i l"d.'r'l 'i'i 1.1 "fr\l ( ; I"~ ";! ~Ec:: rt.1/ fi"i-~"'i1-1'1h!l.u tj n &. f:!z<,'j,'l :-1y1,J ' 1 Ti \f i fd{ _'.< ~ '..-L' v~ ~'-'''T Ti ff. f! il!: ~-~'PL \;1 i"li. Jf'.JJ.i,n '\Tit!,ci,_f1J. ('Jf," f l'1 ~ Nrn 11 1rJ:i'I J!/d f\fxv ur J<,f}dl'i_ \!1i.. Jtci, Hi\t i'.df-u.:n11~1 uf~ t'1'j~ 1 Y n:r ll H< 1"u. 1 :{'4,f~ >.;i-{'_r~ 1, fi'y 1 ~ i'.'.i ::i'i:k~t 11 \' r::i J?~f1-J! lb J 1, n l UViiJ _td r, r-. ~ 11) 1Hi~ Ci 1ri Fq11: 'iii. )j1 1 li'l~ ~ jf--i f, tig';"'"jt, P! L1~.'.\\-, l"«h.h 1)I,\TH,\' 1 ";011! : _,i,~.: 1;, r.:c11 ijt:~: n W: i: r"~j<l-i.'"' \ :' ~,1;,;'1...~ :1~ 'ij- 1,,1 11~ni., hf 1_ 1.,:J-'.. 't,,! 1 ~-j ii J1 :,1(rt' ''d h f«! '.. L"-ii' _i,j.kf r:1 ;'~) n lt'l- J l?_.-.v'i'.1,,'!j\'iji,!i-1 :;'; A f t j l!'l'.'-1. '\ f'ij l 'i' Il! 1il l.1,~ f-jli l '.:;i};j!dt.hliai. ) ( Vi, P" j! I'.h'l.1!'.:U fhl L!",! Llf' l)i {[i' i,i\'i liv('pt! /;L j!ii_ [ '.' i. ff r v "" -\. \1! "i ~Hu\ I i'd,; jj,.~.f'i... L j p,11:::,~ j <;, r1 I n 1~~; i.t~j1i>.1.if.j 1:-;1; ffl I;! 11d!J;!!,l!,i 'l lfl!.j Jl,j' r- l i'frf'fj':i't, L\Jt ri/h'r'1hl'.l 1 y. L 1_1\-_';j.~ t r \\,.'Fl.i j'f, '.'i i'1~ii' il 'I.!Gn--\f.0h \' "; r,!'.jlf ~- ~ 1_1\f.hq~.'!l't1.' /\,'1\;i'.f'< f_{,_t;~,.'\~~-,,b tj :t ;i:i1 if'l ]\J,.(.'l! l j!_: I 'h'oi MI.'1' l'"~h ~- ITfJL: (J-11: :" n 1 \n,'\ [.''1 1:; I<~;- I f).;f!ld 1 hf,: Ii' /1J,:'{ /«TT,.:1,x.'HJ.-1{ itt )'tj-1"1 />;'; 'l'! 'i. P Y1' t" 1 ± Fr 1lT1f -1: ; }lj.r,'.1 I q:!'bi: ~t r V;'i1.J ~ tt.l'~ t Uf.1,t,.fl.)!\'\~ }, l1u!-.!. 1 i ( L'H ij,_j\ :r.!'l T\J.:..J\~!f l t'l fl~ HIC 11 r Jl)~!, JHJHl'rtJ.J i,f THY:. Hi',,,,J ~~.!«~ ; 1 p!4t- l/i :-~; ;-)!;j-p- }j_i Cf.fi-'C" f a' "i'i t!- :dti: ~i!-'t!ffl,) f.. i :ii 1! d l l '.J JI.~l 1',»; V J)l:\~,.r_ f,1j! ~A;;t-1 Pi '-l.'1h::up1 ]J i'i'l 1.'!t CflP\' Ol l>lll, ',\ f'vy -i L'i ( 1 \-i,t'kj!jlfffl lii H ~;i;~ i' :t 11..\Vf' lf1'~.l''i'f p l HJ~ L-~!iht\11 «~ Ji-: 'A fl J.11h! 1.U! HJ-IJ.tfi. I'J J?dl\1.l"\f/A!)! 'r' ~-~n l'li 'i.\.\'.,\; 1 ~.J r:rh!4_f: f!11.: UVli ll'r l/,~ r IT~"'' i! qj' 1 t" Ip_;,_ 1 il ~ (: 1 <1 j.j_ -r1l,. 1,?-i't~ \'i, >L

161 5\Jbjecl:!l:F" Crnwftlrr:i lmpormi"oc"' 1-figh ~..s I.gr the ur:i;jb~ t'~!:) rnt: r,h!? ~n.t~a. attort:it1 1hH Jude,-e dki ~iot _$Eilf,;Jrtv1hln~t ;:bout S:-iJltlrnH~lna 1:1!1 or.tier. Viihi~n 'YlJ!J s.tuid -J J~ ;c,rdvit r)n ~his_, Uu~ (.fjlif~ S; ~d l'lind ftdi 1t W1 th!~ dfl.d did nnt ri,d)' an v-r hlr~m J Uuut producirvg the rt!'t4:jrd~ -~un<rf 9 or HJ 5-uhrw'.11t An ordcl'" i!t~ 1ihe CH dii?r.µn tt'lt'. f'x!pi~rl l 11&\hf: snid i 1r.'!J,0'i nc1i r;v~11l.abl{? fi:.;1~ thfi dirtj1-fl:'1 thi:: kv!tt.' k, of th4::> "'' f r:itl1ffi)~,f!1tt: ~\d (hzt' 1fr-t~i:'',k, lf ltdu c21n ~Jf<;W~L' 10 Ji:.,;::,:ve 11 th!! nexl week, r ak will! 11 B"'lt A, EJ11m, ~q..!(>~ &1,;,c.JH~ r1~rol~jtu h.vi';'~ejp:> Stu1*" Thl% t.r<l-n;111i!5.:;;krn ti Jnt:en-11tn] i:v be 11t ih11?n~d -11nl.,f 10 the nr:i111il;d tlddre'i/~-1'.'.:'r~{~-~ niu'id ITIQ'r ~"nf~tilj.o 1nfnnndUon rhli~. ti;:. ~l'.t,fi fi:d~tn~ja-t, 4l1 bq nef or ~ttcim~y t.li r? nt pri:v!l~!:;i'!tl ll' 1!1~~ Infarrnation I~ ruct1!vt 1 d b'f' ctf'plrjn&l n i.hi?t th41n ~hi!! nr:my1tid AOO \nt:t:jfh]pd i htt fii"ci.pltr1~ s,,t;ouhj Jiw1nii dt15lr.<ly not1fv ~h e 5.f:itidll?~ by E-tt/IAH.. 4)ntJ tij}f p~(1fie J1 thw,;: pfti'.j.ne fhtfii;bki:r tjv tf i:f:: ~4it~.d1Er J;(a;tt:U: un tb11 t-fl 1;;i.iJ Dind PbirIN'lr1 lnytnh::fh:.~n-s a1 b:j ~he djsp~.j!±li:il 4J>f the ttfi!hl'hhitted fnd!t!llirixil rn fl{} ~IJ~rH 1~Tu,Jl/ H~lr, trtdtert;-;ij a~ 'ij 1~{'.d. str..aed Of ~r::fialf'4@d by JillVOfH.! uth~t t.hf,lri th~ n..~111@d 5th1rC'S,5$-ta]~,~;, wjth r,h1: 8i.pn;i i;1f,fjf1:ia!il~i11..1~ th ;::< t4'.'thj!l1f ih' ~he lf'l&trh:~d?lddrpj,13':'#j(:s) 1lHJP;k 't(t:1u C~f.l:CUl.~4.f\ 230 l)~s.c LAI ~r1fft Thh. r:nttw1111 nif.1hon r! CJ%!~ fin t C6FIS Li~Lltfi \1,, 13,1'..'t;f'f;'"d 1.'lp fx)~l)f'l!i f,i:i ~ L;,i,J; f.l":: Ill I: j~ dfiop.f' tl c,v,:jh'/n tfn:.:ul!.ir 4,+0 1 ;;iptj tfr.j~'.i. nut i'.ti rn ply 'li. hhi t h<t:o req u\ft:hrj t~ nl'"~ fox i~ ; i;-oo;,;{ 1ir ri OJllriiun 1 ~'1J-e fbavv rv'.jt (OtM.:liJ.rtfrJ, J'HJt ~,41 i;'e ;,ftif bi"i.:j:f'ij litrl\t±d io r.ondutr 1 ~h.;11 tvf:h'! u~ a11ti!yt~l~ tn th~t tdf1:'.lf1\1uj'ikhjl.lop; Tz.i (lfl."iufe c0niplj.jnj.:.itr v. Tth tiy ~he UtS, 'FM ' IT! US:t rnforrr1 '0l.J lhjjt ~ n1; 1,.;L,S, ff,~dr:!r.'n~!elf,;.uf,1,..1 H3.l C-Of1tI]'tned \n 1h;s t:'offl[f~ij(j\'f.'.,ftltkll1 ('!ne[tjdlni.f: ~1(t 1 l di'.i'<:.th'f\i;i1tt~ nrltem:i "'JjIH.'.'I)dt-D i1ff,i_%tji) ti; nut l'!h1:r1ej~3d nr ' '~ri11!0j111) lln US'1:'d 1 ~1nr:I r..~rhh'.j1 IY'ii~d 1 to1 th e t.>d l;ii, undr r 1~1.-E' ~WH Jtl'!i'Foiil H1~ 1t1:111Jt«(::r)dE' a r (id pr t~jntr.1i 1'11],;, n1 ;] ";J.;:t'1ing flf ii*f'.fll'f1 n ~enr:!! flf'.$ 10 J fl<il h.r!'r ff<l!rflv an ~ 1f ~lnyjt:t:~of+; th.m;;t'\ilff.hjj'..ff+!''s'.)",fi:ji fh::jt< n, from1 G.rtPt rv'i. f!'.t81:::iitjf1j(lh '1 [!' s~n11fttdrr~,11.~ne! o:i, l0j7 4JJ1 P~t To:. Urmt:I Elam Li;~ ilahh$ PiI!rrv -: 1 :1: :54..I bl"'tt~ C.r.rtWff.Hd, 'f',' 1 "1\il'.Y

162 fh]!;ff'ti: (::iarip fr111 Fri?l':.dtna n,,_-qfr-rrdrnc1n'~j/b r, o;ada ndr,a,~i:i-el.kair1, S<>rnl: t u12ktl1y«h 1'10' flf:,,/ll l y 4 'f'.jg Pf:J 1~:: Cc fi-t!<t1. Elam_ t>~~,,ji8 ~\5rry S11bJ~t: ::i:i re, r, ;_lfi ~Jr;,; <?S923 Attaclum\!liti: Cuffll>~i TnJJl. /~_t-t1~~11jn1 g,1~t.urtis 4fi;,J-2-1 J.6-2 7d'I 0 ti,;,di:tc) nr,, I lw1umble Paul G, Jiyman Urnled S!!!leli Sc:mk1Llplcy Court 1515 Nm1h Flagler D1ivri!J,lh Floor, Courtioom A 1Nesl El~oh, FL ::l'.5~dt Re" lf'i' r-n. K.t-n11 CnJ~~vfeinj No Attacl1ed hernlo please find the foll!ll'v1ng pmpo'sed orders emar1a1mg l1om t 2017 in lhls mal!er 1. Ordt11r \;lranti11g BON"'!''';, Motion to 2. Order Grnntrng Deb!m in-pci:0; ~e.,;s1rrn'11 Motton for i:;,.1i,,n,,ian Ottfor an<i Produce E;;pert Report:<> (!he "Orders') Mr Elam has e.~im~ss:ffl'.j he me y b" submrlllng!ha! Ile ddh:> no1 agree to U1e lorm ol H1<4 proposed own!.::nm of nu'""" bell.eve ~lhai the F1c,po~>e4l Orders appn::wilj, k,1mjli1 <mler si~mo. Eih~ b~t 11 G

163 Gary lit hi!!!l'tlnu1~ ~ )/,F!nlf:'.2 : 1.-\<_ ~.. Ti!31:/~ Ayq[,' l~ii \'1.J ~11tp:.// 1N1l>JVV, bl'ifj, Jlca,;JrH:.! t4::s}t fa'.tc1h 1/., 1 i;.t, 11te 7, flijs~t ion: ilb'.'1'd lute-; l rft. :O.; b.::1~'. ali11n'.f~fl;m;i rgm,ir fr O; rnur~ln iop~o,wftlih;9 i_sp~.~h~lf,l;h~; -5'1,Spt ~-.i Inde~: L: '.lil 65 ~:i l64l ;vfsr,bl h[ 1~ :\'hilbh: :rnj,o -'lftifttit~- ~-t i"~e; $4) LL.$J! l\ i"rtsci- Jrfdr.l 1, r1itrce nt o;ni J:{J.. helr;i1 t: fo<btic.it?-ff\.ij;mw '#!;' ra p-!l h.1 tiee-te-f1 :0(F'fL'if;. 'IAft',a,p d1~ t<!ncr-top j lg lit :Ol;~TI';,1)' po i I; k;ir1-ve ftijr:a~- rf'.'.'~>jtlvr±: line; rns'.1- V<tf:~~f1 th D0' r1; t!fi t ;O;rn~o.. l1ur,e:ht JJ.ercent:O; n1'1tl-wfrjt h r fl l;i t hre:(j.;ij it&i rrif'.44'.l" h~--1ghg-- 4t.! la1h1m: pliilg-e' o;j11 1otVt'.ltrerlar;r:::"f"' ;fl:btjtfvn=r''i. 1 '> ;: i:r: F lcj.>p IL1:,,l"" t'«i{ ~~d>~ :Jf'8 ~l.'.f') r,i;y_fc.1j:,_f i:r 1~-':-4Al? (; ;;::::::"!L.,!,+ );,:,:;, :J.?J! '.>4.;;;;,::..'1,-;1,L;,,,.; ->1'µ ;;'.'4J:L>l!Jj;f>--'".!3-'.H-f,/; '. ;. \ ~'--".'.'\ :.-~ '.,>'{f ;'-.if1~_,4',\l.,'~!.,1'j}-'i' ;~:l:"f!;;1 JTI> fjj -~L;-~ jl.l'.bj-o:.m\!:'.1(!\jj, IS \n D~Nff PH\Vll.i <d 11 fi_l'jij 1>JH:1 i-1.:'-ltj IIll.I.. j.j 'I}. -JTtM't.~iJ)!t1il l"h. USf trr THI!' f}-.;\:gi,tj!!,%1,_ (lit; ~N\iTi ~tk.~-t:: ti,a.s.:}''i'i. -Ahf }, ft},>:~.1'.ij~~ r:; ru TI Hf,. T~J'il'_i.f,l J,jfj]':'f.k_.}:l, f ;::m, 11'1f' '\,,fh,;f f\/f-f'(i)-[ o+- -LC'!'4Vl 1'Wf'~l' 1Hf_ [JI)?[ [) l/llljt! f-ia i~}jd mmmr'.)?-lt \ihn!li i (l'jf..1t,, 1LJ?JlLti f"t'ln t.ili'~t.<-1/<!fd! f!f -lf..lf.1. -~} f;tj,j,/'v)-%1111-s'.(j-jf!h ti.!'~ii'.'i~ «i! i"tjhf {fc;:r: {l-.j\ f-ifjr 'faf}d1i.t, It> if~1thl1lf), US~'. OJ.~-~,_;-'f AM!<.(:1\f~lf*~f \.;.'.) '!_ /i!ii*ii JlU<t,fO'il i:.\'i i!~fl ll-!ai'-,1 n i'.e ;rrr Oif f I1-1. r..:-"h L7 ' V!i>1T'fl\i CO-*-JitlS<t~ rli\.f.,(1t (i\'.~'t," I?-J.Hf 1ii 1Jf ftj ;J.i \ t1t)c 11 1' f'".ki'~iiii't.11l ~ l' rt-. ~l4_!':!'"~ ~1i E-J' ii id F,k-1~:1,,.,r,.;;; '"i Ni:)l Tl Iii. 1mr JJ'.rffl fiid!'\'!~d I, yr_;,u,,1,11f, H~'J;f'll'f k!jfit!{i) Pfflf,t,f~'i' kl!".';,}{\yi-;fl_ft,,tfo~ { u::-;:-rr:;;",1~s;"y,jp,, {%,' {1,){"ff_)'J i'h!.'1 CDly!tJ,t-\ifffffii't{)!'J!5:'b~Wt::'[I_11' 0f1'('JHIL?T rn. II' ~L/;J!JJ\'1/f 9.f'(!'.J\'( S~ h'ti r:ijj.,1 V.lJP, :,,\TllJf.i< tfj: f.l'j1nli, r,,,t ~;,.;_ lml~fffll-" T!:_t;'I' t,!f, t 1Fii' Nt)J P.ifTUJ;t~i :n1~ (p0:'.~.,1:'.trjl! ~Ji t':'."h:(.-i ttfffo[ '.;,Lhit."1 L T1 ;ft!.%h: l'(h1

164 Bri!lt Elam F1om:: > ml; Ta; Subf~<t; AltlithllH"ll-" ifpuf<t-~i-;e,! 'tttthti. hii:c.k Flhd!,fJDk1_td at tt'l,~' '!!.(ill~mrjnts I st>nt. l:1_s1 night. 111 r11v prepar~1tkjil!'.:.f tht! J\~dt:1thon.Jf t!p." SlJ!tC!H~nt l ~-P1Tit; JE"1'.] tht a-:c oun1 nurnber, I hi.rv1~ go tt'2'f'l '[ht: f1f ilf1'.'11hrnr: frurn t hh.,'1.1t!. bsl~,e ;agf1ln -t:l'id r-t:{;!'4r~ed &"'-t1ry\h11 1g b:-ut 1nr tir--tlv.:1n-rr.l. ll1!tt onir: h1!i~ 1hc acrduf1t: hwrnbf'f.nn ih!q'!:!\jjfii"fnt:'-rh Sren i'<w E.iam, 1')!', :li~n ~3n:k,_;;f.;-t f<~-w IHH i l A 11 \".~. i 1.1,1 ;'I c Tf 1fi; tf'ilif'l'~nilt;.~jr;u, h; h1lr?f!-dic<d t(::<i h~ dt~jh,'i':o--rt::d c:inl:.( 10 thp narned ad.prt11st~r (s.) t1rid rn,,~ t'.t:jf1jj1lti lnforma~jarr th,3f ;~ (DllHdrn1L~I, J1fDJ]rir;t;yrv,. i' :ltdtnt!'y< 'i1<'.f'nrk-producr or ::il_i.r1rn~:'li' {Ht;nt ptriv1l~!ijstll H thl;;;,. lnfntrrtltr;llnn i'.~ rf::::ct::jvno h\'.tfr'\;v~>rh~ oth~r ljtan Hn_::_ n;)tl'i~::rl <llf'lt!l lntc!-rt:a1t:d a-drrres!!~ed,:;;)~ t IH~ FPf iphi!nl :1hll 1.!ld I111r11-t! dld tlll'llf r1c1tif\1 f h'?.~;:jnd-.er t t-(t:aji Zi:rtd 1(~ ht"phtiiflf:: ai:t IJH?< J:?~:l Ile n1.tmb&r (.1 rhli? 5ic-n.d1~ r 1t ~te ti {J!:l di11 GftTaif ~1ri!i i(1 hf;t ln frv; t,ructions.1s ta \Ji-~ tht~ irnn'i>rnrtted H'tal.Etl-2!1, an nn evr: f'fajj: ~hctjh ihl5 l1'1i:llt11;~~ 1:li~ b(~ H~.1.tJ, u:~~d. cup!-tid,. r-1"'!prrw:luoe'd, ~toft"i'j <t..11 r 6"~ iritt:e:ti by anror:1,_~- Cht t;1liir 23:0,,.;)f'ld t:j.jje:;;i nnt 1:'.:C>1 ~ 1j)Uy t?~llh ~hi"' requ!n:1-1110iu11s ~-Qi 1-1 ujvtlr'l.f.1j trplnlan,' V-lr:; h~j'i«--;: 11<.'.!1 t!jii"hj1c1.'ifhj, f\j::hi' hwy. ;t,,-i? b~~e':f'fi lo tonducr~ th?i~ t'r'pe DW ih'ij.ly~~~- fp. CUflttVt':Jn'.it.iJth.HL lo ert5'li t1' t1:-if1'1plia11ct;' \~.dth INHtiff1'12 1ilt1;, 1rn1n1.rn by ~he fl{$, 'i,'l.l i.rnu:;;;t fnfc.1fr1'1 yolll th<4l.lllf'llf IJ $., f~~dttr.a~ j,;j:t, ;;~riv~rl!j' rnntafr1-ed ln tff 1t5 C1Jtm!fttuni rafl' t"h1 doz: rjf'ih.:nt~ rn lterns ;appendii?d ltbfi3an) iti HOK frht2 ndt d flt ' iii rit~flfl 1:0 tw:i fj':i.ed, i!hld (~fhh'.:'.11 h l!s,f::!'d' f>;)f tt he' FUffHl~-~- :Of r~:j fj iioh1i~!f1 ~;ir, 1. nt1l1ie."s ~1nde1 the lntcrn;tl,fl;<i.~'tenqe r.-,.r j\lj n~:arkriffing or rrt.:;; Bno1'h10r ti: )'( 1rE1n;.;.,:-icti!un ur mat-tof.'f otidjt.!ll.110d ~1fl'Fflfln From1Ci{ffV1\1, Fnz:12dntm11 t~t1~\lh.o~c~l{if?e\lrrhill'l@hr-0;]dt!11d-t.eiss;el conr1!,!>l;jrm We<lnv~1:f1)'y, July- :Wl 'I l::m AM

165 T'o: Efa11 ~ 5ubfE}t't; fit Cqwfo~if! 'liti~ie"",, poshidn:,;i br,;01\1 t 1? ;le f'1: O;, n~1 rshg njrt ft;rrtargfn, t'"?4 f~ ;f!l; rnu 1 1,Hl HJ'f},i/),v<ll>tith:~) 1,5pt ;ttelgh t<37.5pt; ;r Wfdf! tl i '1 #.l>toc fp.;;~ t 1}ltLU.;rn:;;o po:5:li Jir;.n, hot i.tt'.httji@: \'t:' ft; nii:;d ""'""'''! vuiutrd';,!, u:l ii b'll r~ :it 10.;rr~,; rn ";.Zl PQ ~.i:; la n <'1.>' ~1 rt.l.r.11:.1 ah~1ute; rn ~~o Frllm: Brett Elam "'' '"LL'''',,, S~nt~ 11JL1iu:fiJV, Jul 1 ~1 11! 20179,_J t.j1ii,f.,,~ Tu+ G1H' 1,i l'\a f'tii~~~rlrrid n '' 'L,,,,, SLJbjiJ!et~ HE: CtrTiv.. 1 ford Pt1f5-!JJH)l ro 1h~'l "?llihli'l b~~.01..v, pl1!21~itt ffnd il l:'tarht1rl ~ht! ft".'l'f,jc-t E <l.0c('1:fi,tt:h i1ijtl~tt"cnl~ 5hU'..\lifll{ tjh: 'lun('.};1!li;'o;-rt.~ lhifr,jj,('.(.fjuih i<1'5 '\p-(p. d~>)('ij' '~ed. At!-tlhltHHil~f:~-'! r1~~1\<"t Jt1UH.:h;;;>:~ ~th~ t,jf OH." :iif.l.r.urnent \ '!>unl ''r 1 0~J In Fv1.Gy :&.JHJiWll1fi{ th{!!

166 (oun.. ~ ord~t tu ~ui'jduca~ l1!h: do1~tjn1~flt';j,_ Fi1rsiu21n-~ t l\'~1! th1--d1t.1~aiu'nhng l 1nif!~ ~Jrrl.1nc--rl t-l! ""'o~,ut<'th<? r~dart:ed futat~nh:#1lf:. ~tr,:~r-fl tfllf".' d~jtt'.' u:f 11he IS't!!Ji15U tfl nu ~1'Rh l l. why; n th&: List stjte'hi$:r;1 /;,-:; Ph~&:ie l:j'.j nfrm1 th Li:; ta~!i;;flf,-_f~ V.hi± Lourt''ii nrrl di of prodw:tl<m Frnm: Sr?t1 H.111, Sant: Jutv!!. Z!Jl~t ;\';r9 lo: Gary M fr<;~dmim s,uljjett: Cr:Jwtn1d I j-u 'rt vvjrhtu.l ti;:i)!yi!'~ V:1Ju knlfyjit l arn Wii:'.Jt1 t~re- tin} :a i~t:::tthtl't ;gi, ~,_n~;rr1,;r~ J ti(ii?-f. to 1 nv IJHire i ~--i.;hl to!it"tlvr 1 rnrn~dl;t~1'.'ll ~ aitpj t.he iockiv.jr'rd arn ln flt. l i'.lorl'r, ~J1t0ieft! ~1" 11 ' \,'i-ll! l~12lke '11 P~cW hv thi" ' 1 ~~(J"Sr:': uf!jur'!llrv:-s?t', f!.sf::n;-i;la--lly If y-r:rttt (::Ofl~ldor ft 5 [pm, But 21.!.t 1iJ:Jq)n.di~ [ li;,fj\-lr;± c:r:hrr?c --Hr~d g_~~-10 ~riv 1wffi<«>e-t'.f':k! dtr-1r vdu ttt:: i:j 0 1'! ~he V-.'.il't P!e:0s1? dfjrt 1 1file; f.i ff.'n:ithj11 01 ihl11k ~ arn In contempt 1 21P'1 th@rr1 nor rj1a~ ibl1:- ti!'.j ~~;;p U1ttij-e \ t 1 ara~egal iel out tfjq!;4y,;;rs 11lft:ll Ore-~~ t-1,_ [ta::'n, '-s.q BRfTI tt ElJi.P\'1, 1fJ,_,l\, 10s, $., fil'i]rt!s1.0s fivf!nue -;..1.ttU e: HO : vw~t!'~im fl 3340l (%!) ll33 llb - T (%1) 83~-l l 15, F '"Hr ~h(!>litfil, li-nr~ jjjh7 f_jj;j p Jt. l! l:z~ TJ:\AH~h--!Jf;,)!i r~, 1: I-!!! Ul :"JI 'I 1')',! t, lf:l,_, ti.) /<;\:("1 f()ij1'j(l(htl/<j... tl IS JN:r r ~J(ttlt H>-i{ lh~ l".'-:f- CH "j Hif Hr:Zi;',.',i\1-0;At!j/i untp h'-af,t[d l -.!.Y:-1-'Jf A.IJ~ ;t:\-!i'j,,j-mya 1-H 1 :.. 't f)'fq5 1.il}l,f!'. ipj!!~s!f}-i,j r.jj[,' Fi19. 1Ht -~"?)4 r PU?.fJCt~r or ff)~_j )[\'lf~'>_:, J hf PlFlii L"l \";'ii rr11~ BA11 l)'.'.:ii,,;h;j.(\t+)y 'il'.ol-"{jt.f:_,~j}:t,j\;-{1/f(-;_;'.:_,"-~l:fl);!~ f{p~1arj%u i"ll 'JHf ri'm- NO 1 ~).'11\!~!0!:15.Sl(H~ O! \.)Nti;; TI! r-; ql] ((jj)± ("}fi Mt:TAU-A'T,;!, l'ii!ntfp~rtfp, l}:i~ Of AF'(il'.t. l't'.ac_!if1itf11rt!{jg, M-"/,'f ft_i-ktt>i~ GJH~i<: HU1}-il ~r[(f1y"l G'i" -~Hr rms:( {'J!NW-Jn-.: N tj)m!efjljn.(-lft,"1 i!1h lj)nl,!'.1r~ -tu 1HLbON lfj ~;i [lic1ljl rm)j IJ!;;Jti) li--' t'hf fl[a0?.:'1 (:;# fhr"i t;1!f'i)ac~i I"'.:. NUT t t{ :~H"fhi:-f.;;> ffl.cjlfi!ff; (>!.! I-ffi'f 4c! Fl~ Nl.'.f:llPf.D llih'f /l-jiy Df:S~d'.M1N ~,J f{jf{, J2Vi,1ljJ()lJl-!QU 1:n1 CflF"fi Of- f-h!'.o f..:d_jjdl.!vfufijcjl,tit)f~ j') TH'i!f.,ll'f i"?!d*--:!ij(f~d til -~ j'il_!+l'.\-'! f; (?it.cj Wit2l (ti,t,tl,\"jj-iri)h 1.1,i\JJj P ~ i!:~fk(:rfr_ f"-tfasf L\-'fi--/:t (11,q I Li' r~'j1! '! P.fHJ l~l1 unr~ THE on1i,;,d~.'!it MJ'SS.,ti,l,H lf! 'ftlf!l('._fjqif,~ rh,;\l'j- -Y[!U '> 3

167 Business Online Banking Activity ~ Deposit Account Account Information Transaction History De-~& f:1'.ffrl)ti: 3/112n 1 r ID 4(:.'IOJ:tr. 11 TranBifc1h:c1 t) P8$!l.'11rani:Jetliore;; Dui.llil r.:f)uon: lnthf<ler. ttari:ieclh:'.«l d1tt.j1!1 C lcul tod B-..l;Jfntc1 lo ACCOUNT Nfj MISC!iUJ,,l;"C US D 0iT TO AiC~CUUNT NO SU.52 DEPOSIT

168

169

170

171 Totaro, Carl From: Brett Elam Sent: Thursday, November 30, :11 PM To: Totaro, Carl; Gonzalez, Linda; Macha, Dana Subject: RE: Florida Bar File No: ,236(15() Importance: High Mr. Totaro, Thank you so very much. I will get the documentation to you as soon as possible. ijlso, as a side note, in the last few weeks, I filed a Motion for Reconsideration with he Bankruptcy Court, which was denied However in the Court's wling the Court made a statement that the funds in question were for the payment of a creditor upon confirmati()n of the Debtor's Chapter 11 Plan. The Court went on to say when I used those funds, this is what violated the Florida Bar Rules. When I read the Order I was confused, and started reviewing everything in depth, well more in-depth. It seems the Court was under the impression that the funds that were to be used to pay creditors is what was used. But, this was not what actually happened. The funds I was holding were from the Debtor as payment of my fees. The other funds for the ayment to creditors is a completely different thing. The amounts look close, one is $3,500 and one is $34,400. Is there any way I could amend my response to the Bar to include this information or let you guys know? I have een at a lose for words at why the Court thought I used funds I was not supposed to use, but it is now clear why the Court thought what it did. But, I just wanted to let someone there know this revelation. Thanks! Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T {561) From: Totaro, Carl [mailto:ctotaro@floridabar.org] Sent: Thursday, November 30, :04 PM To: Brett Elam <belam@brettelamlaw.com>; Gonzalez, Linda <LGonzalez@floridabar.org>; Macha, Dana <dmacha@floridabar.org> Subject: RE: Florida Bar File No: ,236(15C) An extension until December 7, 2017 is granted. Thanks Carl Totaro, CPA Chief Auditor (Lawyer Regulation) The Florida Bar Lake Shore Plaza II 1300 Concord Terrace, Suite Ext # Ctotaro@floridabar.org 1

172 THE'. LAW OFFICE'.S OF BRETT A. ELAM, P.A. December 22, 2017 via electronic mail Linda Ivelisse Gonzalez 1300 Concord Terrace Suite 130 Sunrise, FL Re: The Florida Bar v. Brett A. Elam, Esq. Case No.: ,326 (15C) Dear Ms. Gonzalez: I am in receipt of your December 22, 2017, correspondence related to the Complaint filed by the Florida Bar as a result of the Order entered in the Bankruptcy Court. In your correspondence, you request a copy ofthe front and back ofthe check in the amount of$34,400.00, for payment to Kim Crawford. Pursuant to the Court's Order, this amount was to be paid back to Crawford within sixty (60) days of the date of the Order, or as otherwise agreed by the parties. As the Order was entered October 24, 2017, the payment is due to Crawford on or before December 23, 2017, or as otherwise agreed by the parties. Currently, I am not in the position to make a lump sum payment to Ms. Crawford, but have engaged her counsel in negotiations for repayment of the amount to Ms. Crawford. I will provide you with any documentation related to an agreement when reached. Additionally, I will supply the Florida Bar with copies ofany and all checks which are paid pursuant to an agreement with Ms. Crawford. Please let me!mow if you are in need ofany further infmmation or documentation. Ifso, I will promptly provide same to you. I look forward to hearing from you. Respectfully submitted, BAE/me Brett A. Elam T I F BE LAM@BRETTELAMLAW. COM WWW. BRETTELAM LAW. COM 105 SOUTH NARCISSUS AVENUE. SUITE 802 WEST PALM BEACH. FLORIDA 33401

173 EXHIBIT 4

174 IN THE SUPREME COURT OF FLORIDA (Before a Grievance Committee) THE FLORIDA BAR, Witness Subpoena Duces Tecum [To Testify and Produce Evidence] IN RE: CONFIDENTIAL PROCEEDING BY THE FLORIDA BAR UNDER THE RULES OF DISCIPLINE. The Florida Bar File No ,326(15C) TO: Seacoast Bank 50 Kindred Street, Ste. 201 Stuart, FL YOU ARE HEREBY COMMANDED to produce by regular U.S. Mail to Carl Totaro, Branch Auditor, at The Florida Bar, Lake Shore Plaza II, 1300 Concord Terrace, Suite 130, Sunrise, Florida 33323, or by to ototaro@floridabar.org. on the thirtieth day following service ot'this subpoena, the following documents: Copies of bank statements, canceled checks (front & back), detailed wire transfer records (i110oming & outgoing) in addition to basic wire information captured on bank statements, detailed fund transfer records (incoming & outgoing), cashiers checks issued with supporting documentation, items deposited with corresponding deposit slips including ATM deposits, signature cards and any debits or credits posted to the acoount(s) for the following account number(s), identified as Th Law Offices ofbl'ett A. Elam Trust Account, account II 1 7 and account II 4 for the pel"iod of January I, 2017 through October 31, 2017, and any other accounts in which Mr. Brett A. Elam has signatory capacity for the period of January I, 2017 through October 31, [PLEASE PROVIDE ACTUAL SIZE IMAGES] Ifyou have any questions regarding this matter, please contact Carl Totaro The Florida Bar (954) , extension Please be advised that The Florida Bar is an arm of the Supreme Court of The State of Florida, and therefore is entitled to receive state government charges for photocopying and research time. According to FDIC Regulation S Cl 2 CFR, subpart A, section "Cost Reimbursement") maximum allowable charges are $11.00 per hour and $0.25 per page. Any questions regarding these chai ges should be directed to The Florida Bar. For failure to comply as herein required, you may be deemed to be in contempt ofthe Supreme Court offlorida. 1

175 Dated this 9th day of November ' Rule 3-7.4(h) Rights and Responsibilities ofthe Respondent. The respondent may be required to testify and to produce evidence as any other witness unless the respondent claims a privilege or right properly available to the respondent under applicable federal or state Jaw. The respondent may be accompanied by counsel. At a reasonable time before any finding of probable cause or minor misconduct is made, the respondent shall be advised of the conduct which is being investigated and the rules that may have been violated. The respondent shall be provided with all materials considered by the committee and shall be given an opportunity to make a written statement, sworn or unswom, explaining, refuting, or admitting the alleged misconduct. Rule 3-7.4(i) Right of the Complaining Witness. The complaining witness is not a party to the disciplinary proceeding. Unless found to be impractical by the chair of the grievance committee due to um easonable delay or other good cause, the complainant shall be granted the right to be present at any grievance committee hearing when the respondent is present before the committee. Neither unwillingness nor neglect of the complaining witness to cooperate, nor settlement, compromise, or restitution will excuse the completion of an uwestigation. The complaining witness shall have no right to appeal. Rule 3-7.ll(d)(?) Contempt. Any persons who without adequate excuse fail to obey such a subpoena served upon them may be cited for contempt of this court ln the manner provided by this rule. 2

176 EXHIBIT 5

177 IN THE SUPREME COURT OF FLORIDA THE FLORIDA BAR, IN RE: CONFIDENTIAL PROCEEDING BY THE FLORIDA BAR UNDER THE RULES OF DISCIPLINE. Witness Subpoena Duces Tecum [To Produce Evidence] The Florida Bar File No ,326(15C) TO: Brett A. Elmn, Esquire 105 S Narcissus Avenue, Ste. 802 West Palm Beach, FL YOU ARE HEREBY COMMANDED to produce by regular U.S. Mail to Carl Totaro, Branch Auditor, at The Florida Bar, Lake Shore Plaza II, 1300 Concord Terrace, Suite 130, Sumise, Florida 33323, or by to ctotaro@floridabar.ol'g, on the thh'tieth day following service of this subpoena, the following documents: Umedacted copies of bank statements, check stubs, canceled checks (front and back), detailed wire transfers (incoming & outgoing) in addition to basic wire information captured on bank statements, detailed fund transfers (incoming & outgoing), cashier's checks issued with supporting documentation, bank deposit slips, cash receipts and disbursements journal, client ledgers (active and closed with activity or a balance)*, monthly bank reconciliations, monthly comparisons(**) and annual detailed listing of trust liabilities for your trust accounts, executed HUD-1 statements with settlement statement balance sheets for all real estate transactions, closing statements from any type of case, fee agreements, and any documentary evidence suppo!'ting all trust disbursements, transfers and receipts for any trust account in which you have a signatory capacity as well as all supporting documentation for any other account in which the funds pertaining to clients were placed. In addition, a copy of the law firm written plan in place for supervision and compliance for each of the firm's trust account(s). This records production must include your Trust Account number ending with #7647 maintained at Seacoast National Bank including a receipts mid disbursements journal identifying the client name and client matter for every deposit and disbursement reflected on the bank statements during the compliance audit period noted below, This request applies for documentation maintained for the period beginning January 1, 2017 through October 31, In addition, provide copies ofthe following: 1) Provide the date(s), amount(s) and copies documents substantiating the Bankruptcy Coutt's approval of any atto1 ney fees and costs you received, prior to March 2, 2017, relating to the Kim C. Crawford matter. 1

178 2) All documentary support substantiating the Bankrnptcy Couit's approval as ofmarch 2, 2017 or anytime thereafter, for earned attorney fees and costs in the amount of $34,400 that you received from Kim C. Crawford that was deposited into the trust account on March 2, ) All documentary support for all disburnement(s) from the trnst account relating to the $34,400 deposit to the trust account on March 2, Ifyou have any questions regarding this matter, please contact Carl Totaro at The Florida Bar (954) , extension *Active and closed ledgers must also include ledgers equaling the beginning trust account bank balance as ofthe beginning ofthe period requested. **The monthly comparison is an important trust account record. It lists a comparison between the total ofall client liabilities held in trust as of each month end per your client ledgers, which is agreed to the reconciled bank balance (from the monthly bank reconciliations), together with specific descriptions and reasons of any differences between the 2 totals. Dated this 9th day of~n~ovlemb~~e~r~---~' RETURN OF SERVICE I CERTIFY tliat the foregoing subpoe~l} wcys sej'ved this /?t~day of/vp\ki"l /}?IL-, 2017, by. /J!!U'o1V14 J{/\ V!t'{ t'11/ lf~(o/j~ '''' iff.l- (methof.d fser~ice) 1'11si~,u.t. // v ;,J, / I I k//'~.,, J01ja C~tdf:.f/'v//,{j Lj ~t'l4'f-t//c~~ ~-~ (Signature and '.l;it1e,6f Person Making Service) \.~/ THE FLORIDA BAR Gdevance Committee 15C Please note that if any entrusted monies have been deposited in any non-trust accouut (such as operating or pe1 sonal) during tliis period of time, you are hereby compelled to produce the documents itemized above for that account(s) as well. Rule 3-7.4(h) Rights and Responsibilities of the Respondent. The respondent may be required to testify and to produce evidence as any other witness unless the respondent claims a privilege or right properly available to the respondent under applicable federal or state law. The respondent may be accompanied by counsel. At a reasonable time before any finding of probable cause or minor misconduct is made, the respondent shall be advised ofthe conduct which is being investigated and the rnles that may have been violated. The respondent shall be provided with all materials considered by the committee and shall be given an opportunity to make a written statement, sworn or uuswom, explaining, refuting, or admitting the ajleged misconduct. Rule 3-7.4(i) Right of the Complaining Witness. The complaining witness is not a party to the disciplinary prnceeding. Unless found to be impractical by the chair ofthe grievance committee due to unreasonable delay or other good cause, the complainant shall be granti;d the right to be present at 2

179 any grievance committee hearing when the respondent is present before the committee. Neither unwillingness nor neglect of the complaining witness to cooperate, nor settlement, compromise, or restitution will excuse the completion of an investigation. The complaining witness shall have no right to appeal. Rule 3-7.ll(d)(7) ContemQ\. Any persons who without adequate excuse fail to obey such a subpoena served upon them may be cited for contempt of this court in the manner provided by this rule. IN ACCORDANCE WITH THE AMERICANS WITH DISABILITIES ACT, PERSONS WITH DISABILITIES NEEDING A SPECIAL ACCOMMODATION TO PARTICIPATE IN THIS PROCEEDING SHOULD CONTACT BAR COUNSEL AT NOT LATER TI.JAN 7 DAYS PRIOR TO THE PROCEEDING. 3

180 EXHIBIT 6

181 Totaro, Carl From: Brett Elam Sent: Thursday, December 07, :36 PM To: Totaro, Carl Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15() Attachments: Letter to Totaro(l2.7.17).pdf; Order Allowing Fees.pdf Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1of6. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 1 CoMpOSi re xh1131r G

182 THE LAW OFFICES OF BRETT A. ELAM, P.A. December 7, 2017 via electronic mail Carl Totaro 1300 Concord Terrace Suite 130 Sunrise, FL Re: The Florida Bar v. Brett A. Elam, Esg. Case No.: ,326 (15C) Dear Mr. Totaro: I am in receipt ofthe Subpoena, which was served on me November 17, I appreciate the courtesy of the extension you extended me up through and including today, December 7, Pursuant to the Subpoena, I have produced the following documents: I. Copies of the online bank statements for my Seacoast National Bank, Trust Account, Account 7 from January 1, 2017 through October 31, 2017; 2. Copies of all the checks, which were either deposited or debited from the Trust Account; 3. Copies of the ledger I keep for the Trust Account; and 4. Copies of all deposit slips I have for the Trust Account. In addition, the Subpoena requested other categories of documents, which I will explain below. Pursuant to paragraph 1, I have produced a copy of the Order Allowing Interim Fees, which was entered by the Bankruptcy Corut Mfil'ch 27, As for the documents requested in paragraph 2 of the Subpoena, there are no documents in existence. Additionally, pursuant to paragraph 3, I have provided copies of the bank statements above, which reflect the disbursements from the Trust Account. Other than the documents I have provided, there are no fruther documents responsive. T lll3 I F lll5 BE LAM@BRETTELAMLAW. COM WWW. BRETTELAMLAW. COM 105 SOUTH NARCISSUS AVENUE, SUITE 802 WEST PALM BEACH. FLORIDA 33401

183 THE LAW OFFICES OF BRETT A. ELAM, P.A. I would like to point out, the Seacoast Bank account is the only trust account I maintain, and as you can see from the documents produced, there are not many matters, in which I am involved, which require the use ofmy ttust account. Currently, there is only one (1) client, which has funds deposited into my trnst account. This client is Melvin Casanas, and I have enclosed a copy ofthe Settlement Statements for the matter, in which he is involved. Ifyou have any further documentation requests, please do not hesitate to contact me. Respectfully submitted, BAE/me Enclosure f;wj:o~~'c Brett A. Elam T I F BELAM@BRETTELAMLAW.COM WWW. BRETTELAMLAW. COM I 05 SOUTH NARCISSUS AVENUE. SUITE 802 WEST PALM BEACH. FLORIDA 33401

184 Case PGH Doc 64 Filed 03/30/15 Page 1 of 2 ORDERED in the Southern District of Florida on March 27, {;J~b Paul G. Hyma'n, ~r Chief United s::an:r:tcyj:dge UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION In Re: CASE NO.: BKC-PGH Chapter 11 proceeding CRAWFORD, KIM C., Debtor(s). ORDER ALLOWING INTERIM FEES TO BRETT A. ELAM, P.A. ATTORNEYS FOR DEBTOR-IN-POSSESSION THIS CAUSE came on to be heard on in West Palm Beach, Florida, on the 11th day ofmarch 2015, upon the Interim Fee Application filed by Brett A. Elam, P.A., as attorney for the Debtor-in- Possession, the Cami having considered the matter and being otherwise fully advised in the premises, it is therefore ORDERED AND ADJUDGED that: I. The Court finds that a reasonable interim compensation for Brett A. Elam, P.A., for attorney fees is the total amount of $14, However, of this amount$ I 0, shall be

185 Case PGH Doc 64 Filed 03/30/15 Page 2 of 2 credited from amount held in trust. 2. The Debtor-in-Possession is authorized and directed to pay the foregoing sums. 3. In allowing the foregoing fees and expenses, this Court has considered the criteria specified in 11 U.S.C. 326 and 330 and the requirements ofb.r in light ofthe principles stated in Hensley v. Eckerhart,. 461 U.S. 424,433 (1983); Blum v. Stenson, 465 U.S. 886, 897 (1984); Pennsylvania v. Delaware Valley Citizens' Council for Clear Air, 478 U.S. 546 (1986); First Colonial Coro. ofamerica, 544 F.2d 1291 (5th Cir.), cert. denied,431 U.S.904 (1977); and Norman v. Housing Authority ofmontgomery, 836 F.2d 1292, 1299 (11th Cir. 1988). Specific findings and the considerations suppmting these conclusions have been omitted in the interest ofbrevity, but will be prepared and filed at the request ofany party ifreceived by this Court within ten (10) days after the entry of this Order. ### Submitted by: Brett A. Elam 105 S. Narcissus Avenue Suite 802 West Palm Beach, FL Copies to: Brett Elam, Esq., 105 S. Narcissus Avenue, Suite 802, West Palm Beach, FL *The Trustee (or Trustee's attorney) is directed to furnish a complete and correct copy ofthis order to all interested parties and file a certificate ofservice with the court.

186 Totaro, Carl From: Sent: To: Subject: Attachments: Importance: Brett Elam Thursday, December 07, :37 PM Totaro, Carl 2 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Statement ( through ).pdf; Statement ( through ).pdf High 2 of6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :36 PM To: ctotaro@floridabar.org Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1of6. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 1

187 SeacoastBank Business Online Banking Activity - Deposit Account Report created: 12/07/ :49:47 PM (ET) Account Information Account: *7647 Checking Checking-7647 Accessible $4, Current balance: $4, Accessible balance: $4, Closing ledger balance: $4, Transaction History Date range: 10/1/2017 to 10/31/2017 Transaction types: Detail option: All transactions Includes transaction detail Post Date Reference Additional Description Debit Credit Reference Calculated Balance MISCELLANEOUS DEBIT 10/31/2017 TO ACCOUNT NO TO ACCOUNT NO $0.07 $2, /31/ INTEREST CREDIT $0.07 $2, /31/ CHECK PAID $2, $2, /13/2017 DEPOSIT $1, $4, (j)

188 SeacoastBank Business Online Banking Activity - Deposit Account Report created: 12/ :49:28 PM (ET) Account Information Account: *7647 Checking Checking-7647 Accessible $4, Current balance: $4, Accessible balance: $4, Closing ledger balance: $4, Transaction History Date range: to 9/ Transaction types: Detail option: All transactions Includes transaction detail Post Date Reference Additional Description Debit Credit Reference Calculated Balance MISCELLANEOUS DEBIT TO ACCOUNT NO TO ACCOUNT NO $0.05 $3, INTEREST CREDIT $0.05 $3, DEPOSIT $1, $3, TO ACCOUNT NO MISCELLANEOUS DEBIT TO ACCOUNT NO $0.05 $2, INTEREST CREDIT $0.05 $2, CHECK PAID $6, $2, BOOK TRANSFER DEBIT REF L FUNDS TRANSFER TO DEP $2, $8, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS TRANSFER TO DEP $1, $10, FROM MOBIL ETRANSFER DEPOSIT $1, $11, DEPOSIT $1, $10, DEPOSIT $1, $9, DEPOSIT $4, $8, MISCELLANEOUS DEBIT TO ACCOUNT NO TO ACCOUNT NO $0.05 $3, INTEREST CREDIT $0.05 $3, BOOK TRANSFER DEBIT REF L FUNDS TRANSFER TO DEP $ $3, FROM MOBIL ETRANSFER

189 Totaro, Carl From: Brett Elam < > Sent: Thursday, December 07, :37 PM To: Totaro, Carl Subject: 3 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Attachments: Statement ( through ).pdf; Statement ( through ).pdf Importance: High 3 of6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :36 PM To: ctotaro@floridabar.org Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1 of 6. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 1

190 Seacoast Bank Business Online Banking Activity - Deposit Account Report created: :48:06 PM (ET) Account Information Account: *7647 Checking Checking-7647 Accessible $4, Current balance: $4, Accessible balance: $4, Closing ledger balance: $4, Transaction History Date range: 1/1/2017 to 3/31/2017 Transaction types: Detail option: All transactions Includes transaction detail Post Date Reference Additional Description Debit Credit Reference Calculated Balance TO ACCOUNT NO MISCELLANEOUS DEBIT 03/31/2017 TO ACCOUNT NO $0.52 $30, /31/ INTEREST CREDIT $0.52 $30, BOOK TRANSFER DEBIT REF L FUNDS 03/28/ TRANSFER TO DEP $ $30, FROM FEEF OR CASANAS 03/28/2017 DEPOSIT $1, $30, BOOK TRANSFER DEBIT 03/20/ REF L FUNDS TRANSFER TO DEP $ $29, FROM BOOK TRANSFER DEBIT 03/20/ REF L FUNDS TRANSFER TO DEP $ $29, FROM BOOK TRANSFER DEBIT REF L FUNDS 03/20/ TRANSFER TO DEP $ $30, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 03/20/ TRANSFER TO DEP $4, $30, FROM MOBIL ETRANSFER 03/07/ CHECK PAID $2, $34, BOOK TRANSFER DEBIT REF L FUNDS 03/03/ TRANSFER TO DEP $2, $36, FROM MOBIL ETRANSFER 03/02/2017 DEPOSIT $34, $39, /28/2017 TO ACCOUNT NO MISCELLANEOUS DEBIT TO ACCOUNT NO $0.15 $5, /28/ INTEREST CREDIT $0.15 $5, /27/ CHECK PAID $5, $5, MISCELLANEOUS DEBIT 01/31/2017 TO ACCOUNT NO TO ACCOUNT NO $0.08 $10, /31/ INTEREST CREDIT $0.08 $10, /17/2017 DEPOSIT $10,

191 SeacoastBank Business Online Banking Activity - Deposit Account Report created: 12/07/ :48:48 PM (ET) Account Information Account: *7647 Checking Checking-7647 Accessible $4, Current balance: $4, Accessible balance: $4, Closing ledger balance: $4, Transaction History Date range: 4/1/2017 to 6/30/2017 Transaction types: Detail option: All transactions Includes transaction detail Post Date Reference Additional Description Debit Credit Reference Calculated Balance MISCELLANEOUS DEBIT 06/30/2017 TO ACCOUNT NO TO ACCOUNT NO $0.10 $3, /30/ INTEREST CREDIT $0.10 $3, /27/ CHECK PAID $1, $3, BOOK TRANSFER DEBIT REF L FUNDS 06/26/ TRANSFER TO DEP $ $5, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 06/22/ TRANSFER TO DEP $ $5, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT 06/19/ REF L FUNDS TRANSFER TO DEP $1, $5, FROM BOOK TRANSFER DEBIT 06/19/ REF L FUNDS TRANSFER TO DEP $1, $6, FROM 06/16/2017 DEPOSIT $1, $8, TO ACCOUNT NO MISCELLANEOUS DEBIT 05/31/2017 TO ACCOUNT NO $0.31 $6, /31/ INTEREST CREDIT $0.31 $6, /23/ CHECK PAID $2, $6, BOOK TRANSFER DEBIT REF L FUNDS 05/22/ TRANSFER TO DEP $2, $9, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 05/18/ TRANSFER TO DEP $11, $11, FROM MOBIL ETRANSFER 05/16/2017 MISCELLANEOUS DEBIT $1, $23, BOOK TRANSFER DEBIT REF L FUNDS 05/16/ TRANSFER TO DEP $4, $24, FROM MOBIL ETRANSFER

192 Post Date Reference Additional Description Debit Credit Reference Calculated Balance BOOK TRANSFER DEBIT 05/11/ REF L FUNDS TRANSFER TO DEP $2, $28, FROM BOOK TRANSFER DEBIT 05/11/ REF L FUNDS TRANSFER TO DEP $6, $30, FROM 05/11/2017 DEPOSIT $1, $36, /11/2017 DEPOSIT $1, $35, BOOK TRANSFER CREDIT 05/11/2017 REF REF L FUNDS TRANSFER FRMDEP $4, $34, FROM 05/11/2017 DEPOSIT $5, $29, BOOK TRANSFER DEBIT REF L FUNDS 05/08/ TRANSFER TO DEP $1, $24, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT 05/08/ REF L FUNDS TRANSFER TO DEP $3, $26, FROM 05/08/2017 DEPOSIT $3, $29, BOOK TRANSFER DEBIT REF L FUNDS 05/04/ TRANSFER TO DEP $2, $25, FROM MOBIL ETRANSFER 05/03/2017 DEPOSIT $5, $27, MISCELLANEOUS DEBIT 04/28/2017 TO ACCOUNT NO TO ACCOUNT NO $0.42 $22, /28/ INTEREST CREDIT $0.42 $22, BOOK TRANSFER DEBIT REF L FUNDS 04/25/ TRANSFER TO DEP $1, $22, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/25/ TRANSFER TO DEP $1, $23, FROM MOBIL E TRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/25/ TRANSFER TO DEP $1, $24, FROM MOBIL ETRANSFER 04/25/2017 DEPOSIT $1, $25, BOOK TRANSFER DEBIT REF L FUNDS 04/20/ TRANSFER TO DEP $ $24, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF P FUNDS 04/20/ TRANSFER TO DEP $1, $25, FROM MOBIL ETRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/07/ TRANSFER TO DEP $1, $26, FROM MOBIL E TRANSFER BOOK TRANSFER DEBIT REF L FUNDS 04/03/ TRANSFER TO DEP $3, $27, FROM MOBIL ETRANSFER

193 Totaro, Carl From: Sent: To: Subject: Attachments: Importance: Brett Elam Thursday, December 07, :38 PM Totaro, Carl 4 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Check to Larrieu(6.6.17).pdf; Deposit from Larrieu(S.8.17).pdf High 4 of 6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :37 PM To: ctotaro@floridabar.org Subject: 2 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High 2 of 6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :36 PM To: ctotaro@floridabar.org Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1 of 6. Brett A. Elam, Esq. 105 South Narcissus Avenue 1

194 Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 2

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197 Totaro, Carl From: Sent: To: Subject: Attachments: Importance: Brett Elam Thursday, December 07, :39 PM Totaro, Carl 5 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Casanas Documents2.pdf; Check to Casanas(l283).pdf High 5 of6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :38 PM To: ctotaro@floridabar.org Subject: 4 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High 4of6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :37 PM To: ctotaro@floridabar.org Subject: 2 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High 2 of 6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561)

198 From: Brett Elam Sent: Thursday, December 07, :36 PM To: Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1 of 6. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 2

199 ,,- i_:c ;~=-~ t~,1. ~t ' >J L() If! () C\ llj I UJ () () CHANDRA PARKER DOUCETTE f;l.e~~\._ ~,.,..\,- "In 2020 IOTA TRUST ACCOUNT ~' 621 N.W. 53RD ST. STE 240 /, 63-27/631 FL BOCA RATON, FL 33' /,/ J Date., m ~ "z < co U.1 I,_, u. 0.",:;::i 1.n ~ t; - -_j 1,-- -,:1 ('.J,. E > ""'-' (.) ~ IJJ 0 ll LU D

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201 Totaro, Carl From: Brett Elam Sent: Thursday, December 07, :41 PM To: Totaro, Carl Subject: 6 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15() Attachments: Casanas Documents.pdf Importance: High 6 of 6. Please confirm receipt of 6 s. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :38 PM To: ctotaro@floridabar.org Subject: 4 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High 4 of 6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) From: Brett Elam Sent: Thursday, December 07, :37 PM To: ctotaro@floridabar.org Subject: 2 of 6: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High 2 of 6 Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL

202 (561) T (561) From: Brett Elam Sent: Thursday, December 07, :36 PM To: Subject: The Florida Bar v. Brett Elam, Case No.: ,326(15C) Importance: High Mr. Totaro, Please find attached the response to the Subpoena which was served by the Florida Bar. I have also attached the documents responsive to the Subpoena. I will be sending them in a series of s, to make sure they go through. I will be sending six s. This is 1of6. Brett A. Elam, Esq. 105 South Narcissus Avenue Suite 802 West Palm Beach, FL (561) T (561) Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar regarding Bar business may be considered public records, which must be made available to anyone upon request. Your communications may therefore be subject to public disclosure. 2

203 Brett Elam From: SeacoastBank > Sent: Wednesday, August 02, :27 PM To: Brett Elam Subject: Deposit Notification (Deposit Approved) Account Number Ending: 7647 SeacoastBank This message confirms your deposit of $1, has been approved and processed. For more information, you may access your SeacoastBank - Business Digital Deposit account online at Please do not respond to this message or send to this address. This message is for information purposes only. should not be considered secure and should not be used for account related questions. Thank you, SeacoastBank - Business Digital Deposit 1

204 Brett Elam From: SeacoastBa nk n k.com > Sent: Wednesday, August 02, :29 PM To: Brett Elam Subject: Deposit Notification (Deposit Approved) Account Number Ending: 7647 SeacoastBank This message confirms your deposit of $1, has been approved and processed. For more information, you may access your SeacoastBank - Business Digital Deposit account online at Please do not respond to this message or send to this address. This message is for information purposes only. should not be considered secure and should not be used for account related questions. Thank you, SeacoastBank - Business Digital Deposit

205 Brett Elam From: SeacoastBan k < customerservice@seacoastba nk.com > Sent: Wednesday, August 02, :49 PM To: Brett Elam Subject: Deposit Notification (Deposit Approved) Account Number Ending: 7647 SeacoastBank This message confirms your deposit of $4, has been approved and processed. For more information, you may access your SeacoastBank - Business Digital Deposit account online at Please do not respond to this message or send to this address. This message is for information purposes only. should not be considered secure and should not be used for account related questions. Thank you, SeacoastBank - Business Digital Deposit 1

206 Brett Elam From: Sent: To: Subject: SeacoastBan k <customerservice@seacoastbankcom> Monday, January 16, :45 PM Brett Elam Deposit Notification (Deposit App roved) Account Number Ending: 7647 SeacoastBank This message confirms your deposit of $10, has been approved and processed. For more information, you may access your SeacoastBank - Business Digital Deposit account online at Please do not respond to this message or send to this address. This message is for information purposes only. should not be considered secure and should not be used for account related questions. Thanl< you, SeacoastBank - Business Digital Deposit 1

207 CHANDRA PARKER DOUCETTE IOTA TRUST ACCOUNT 621 N.W. 53RD ST. STE 240 BOCA RATON, FL CHANDRA PARKER DOUCETTE 2030 IOTA TRUST ACCOUNT. I 621 N.W. 53RD ST. STE /631 fl BOCA RATON, FL "+7/J.5/!l 904 Date

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210 ~4 ""' ( 1 ','\. BOCA RATON, FL 33o!B} 7/;),,)/ / / o4 ~.\ I.! I Date. i I: "" i!'.i Pay to the r: "''.' ~ '\ r: I - ',, "' ~. ' $. t~' 4 - )) :J i[,t Order of r), " r"' 'C.Fi ' l(.i~,. ' 'i 1 / l/. tjo!ii i'i f't,, ' _. J_;t i~! ~ti j ' "'di:"',. l ~ t,_... tr_ 1..,, :1_! l, '.'\,,., S.z-;:v~;"'.~ -~ 1 i! 1"4,.;I./'' Ir; ;:;,,..,7:,{.'. '1.. "t /(i t, ~..t 1 ':.im'\., '1...'(_J.!l.tA~\.1"' a l.:::::1'.:jo1tars ld ~::;~:,':..},;' il!.,.,..,,.: 1!~i -~~ :l~\ t].r.. :m ~"'!IJ.o,;~ ~ ' 1:1 Bankof Arner1c.3 ~~~ ;,: ' i ~ l 1 /! ACH R!T ~: ~! ht! ] ~I ' I,..' I-I A..,,,..,, I.".' ;i!', :r:, F. "' t"' "("" _!".,_ ~ 'i.t 4;,,,,..'~. ; ~ 1.; ~ tt \..; :ll!l"j!.,i.'.\' i!t Or 1 11n t.,..~ 1,, ~ I"~, -t.., ;,._, \v, L,,,,..._,,, 0 ( rwr 1,y - I:? l 0 ' 1 ~~,t~~g~;:~~:tf~:f~ff:;~-::::~~i~~:::'l;f::;e:t.:f:::'.f:;;'f~~-::~-:~_::~~-;-::_~ -~ -v~~.;;; - l> + '""n :~= ~ ~,_...~~ " +,..,-...,._.~,. -~-..., ,..,-=rf~-~- ~-;,:.,-~,ic~]~ ~~~~~~- lf: ;f\] Z1l

211 - -.,,...~_,.,;;;;-;.~,19_2'&*"" ~--- - ii' CHANDRA PARKER DOUCETTE 2036 IOTA TRUST ACCOUNT ri 621 N.W. 53RD ST. STE 240 BOCA RATON, FL '' b~x:~;fe~~ ~ ~h-h I~-- Date 63-27/631 FL 904 CJ214-~z;;:f -:::;/,/' s-.:; I $ Jl/1f~$ =-' -~ ~ t<> ACH Rff ' "" I BonkofAmorica~ L':' A.-cd o,,,,m d. ~ M' ~ ~ ~."!:' m:'...6 ~ '",,,,.,,,.,,.%' _A,k<' '1W<''::&~""i''tin'"v" - fy"' ""Ffh.. ~ "Gd~~';Fifi;f$Cu~- ~

212 CHANPRA PARKER DOUCETTE IOTA TRUST ACCOUNT 621 N.W, 53RD ST. STE /631 FL BOCA RATON, PL Date

213 .,_C::HANDRA PARKER DOUCETTE 2043 '!(')lfa TRUST ACCOUNT 621 N.W. 53RD ST. STE 24-0 BOCA RATON, FL Dat.e 63' Fl 904

214 t!" :{'/.~::~:: < ''\'. :::.(., :;-;:!. ~:C)f. '...,. ~:i!.1 :. ;DAlE' Cl,:J2:" ~:1.~:\1Ci\r;.,,:7jj)'.<i/ l11 :<: :'! - ~ "'--~'":':'_,"' /..,_,-,, SS: ' BRANCr(o1_ th1s:-~"'.check :OTH-ER-,_ :: :~., TRANS-,+./;.' BALANCE. ~,. m~ ~-- ''" ""' """\ BOO ""'"""""""~ &Thi.JST '1-i.(~::, iof»!f9~ l ~ffor'/.z. \~d:feo\ ~m.<mif!! S'I(, sefl.le'iti k - ~~ ~ I ~c.e.i>.:o.s 10 ll 2??11 1 1: TOTAL

215 . ~~\HE ORDER OF~~~~~~---~~~~~~~,,.-~~~~.._~~~~~~~~~~--' OOLLA~S TOTAL THIS CHECK OTHER Jf.IANS +/ BAI.AN.CE GRAND : { BANK&Tuusr NOT NEGOTIABLE '{ WEST AIUIOEACt~ Fl.OnlDA,, ', :,,!_ 'f>r. ~~,?'~"<~1'':\>i'~"'~~~-'Af>li< ~,:.~ lt~~ t..'\"'"' ~ c""llil"i;"" ; " f,;j,~'\ei.i~*""" gt:je ~~-cym:"""~'<":li'il'r'li -.ai~~ ~--r f ~...~'!-~ : '!!>''\'' ~:<:. -, : f:\, :.' '. ' ~..w ~.~.,Mi;i 1,.~ "' ~:.:~, "-"~~... "...:....!II 1'. Y.W@... _.' n oo ~ 2??n',,l: '.\.~ '"- "' ('A. ~....A A fr'!w.anc~ IDIOllWffnlA'NMD BRETT A ELAM, ESQ W ATLANTIC AVE, STE0-5 DELRAY.BEACH, FL l.3 l BRAt<CH 6' "' DATE 3 fl. a Ill~ [ ' g ~, TOTAL ~ TH1S 1-S-ro 00 CHECK OTHER TRANS+/- BAlANCE ~~ b~~~of N\e.l" 'i (\ Ca.5o.N\n:S, $ isvo!!! - tw ' ' ' D. ~. ""'""" 11.L ~!. ~ o01. DOLLARS {I) ~1irl.":, ~. + ~ :$=/D GRAND eiiu.tlc!;drolmhtfoawmo BRETT A ELAM, ESQ 301 W ATLANTIC AVE, STE DELRAY BEACH, Fl RANCH01 DATE TOTAL K~ THIS CHECK OTHER \V'i, TRANS+/ BALANCE ~ ~ a :~1~ ~~\He '~~ ORDEAOF~-,--~~~~~~~~~~~~~~~~~~~~~~~~~~~~-,--1 $ ~I GRAND &NK&Thusr WEST PAUi BEACU. l'l.orna.\ DOLLARS. 1 2' ~ 'f 0 E8I~t~~ r~'~ ~'~~ 4 11 o01.2? qr~ -; :!.7 1 r' :t~'~~~f7 0. ~:i:'jl\r, L!J 11.'i~'"""

216 -~ ~~-~-~-~----~~~-----~----~~~ ,,_ ---~~~-._~--~--~--.,._,_-~---~ ~ l BRETT A ELAM ESQ 301 W ATLANTIC AVE, ST~ 0-5 DELRAY BEACH, FL_ ~I I BMNCH01 DATE. [i.{ ' G/670

217 BRETT A ELAM,.ESQ W ATLANTIC AVE, STE 0-5 DELRAY BEACH, FL 33444

218 BRETT A ELAM ESQ W ATLANTIC AVE, ST~ 0-5 DELRAY BEACH, FL /670 SflANCH01 ---

219 WEST BRETT A ELAM, ESQ &I.CH.FLO~ I W ATLANTIC AVE, STE 0-5 DELRAY BEACH, l FL /670 BRANQHOt ~~ -- r I,,, ~i~~~of \ {'J, ~ ~~ 6i8i I $ \~?Jt:! (\W\o U 01 ~ ±i \\.Jl IA 'f/,,cj_,.. b\) L\O,V\ ~.. /I eo~.--d-ol_l'ii_f'[s-~i~~ffir.m!!mf<.':. GRAND.. ~ ~i BANK&ThusT '

220 ,.,. --~

221 EXHIBIT 7

222 I UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA 2 3 Judge Paul G. Hyman, Jr. 4 5 In Re: 6 Case No BKC-PGH 7 8 KIM C. CRAWFORD, 9 Debtor ECF # Septetnber 19, The above entitled cause came on for hearing before the HONORABLE PAUL G. HYMAN, JR., one ofthe Judges in 19 the UNITED STATES BANKRUPTCY COURT, in and for the SOUTHERN DISTRICT OF FLORIDA, at 1515 North Flagler 20 Drive, West Palm Beach, Palm Beach County, Florida, on September 19th, 2017, commencing on or about 21 9:30 a.m., and the follo\ving proceedings \Vere had: Transcribed from a digital recording by: 25 Jacquelyn Ann Jones, Court Reporter Page 1 Page3 I 2 INDEX 3 PAGE 4 5 TESTIMONY BY MR FREEDMAN CROSS EXAMINATION BY MR. ELAM TESTIMONY BY MR. ELAM I 9 CROSS EXAMINATION BY MS, CRAWFORD CROSS EXAMINATION BY MR. FREEDMAN I' I I 12 TESTIMONY BY MS. CRAWFORD CROSS EXAMINATION BY MR. FREEDMAN EXHIBITS All Freedman Exhibits admitted APPEARANCES: 2 3 BROAD AND CASSEL, LLP By: GARY FREEDMAN, ESQUIRE 4 On bchalfof Bank of New York 5 BRETT A. ELAM, P.A. 6 By: BRETT ELAM, ESQUIRE On behalf of Brett A. Elam 7 8 Also Present: 9 Kim Crawford IO Page2 Page4 I THE COURT: Good morning. Please be seated. 2 Crawford. Appearances for the record. 3 MR. ELAM: Good morning, Your Honor. Brett 4 Elam on, I guess behalf of myself. 5 MR. FREEDMAN: Good morning, YourHonor.1 6 Gaiy Freedman on behalf of Bank ofnew York. 7 THE COURT: Okay. Thank you. 8 fyj:r_. Elam. we 1 re here on an order to show 9 cause why you should not he suspended from the 10 P,ractice ofbankruptc:y Iaw based on two thjngs. 11 Number one lyjng to the Court and two, 12 misappropriating funds from the trust account for Ms. 13 Crawford. 14 MR. ELAM: Well, Your Honor, in my defense, 15 1did not intentionally mislead the Court. I was, in 16 my opinion, I thought I had answered the question that 17 the funds were in my account. And at that time they 18 were in my account. I would have never stood before 19 this Court and lied to this Court. 20 THE COURT: Mr. Freedman asked you 21 specifically, and if! have to get a transcript, I 22 will, have they always been there. 23 MR. ELAM: And if! answered that yes, Your 24 Honor, then I will stand before the Court and take 25 whatever punishment I need. Because if that's the I (Pages I to 4) OUELLETTE & MAULDIN COURT REPORTERS, INC, (305)

223 Pages I case, then yes, it was incorrect, and I apologize. I always in his ttust account. 2 THE COURT: What about the misaeerdj2riation, 2 Moreover, pursuant to paragraph 2, the order 3 to show cause on which we are here today, it provides 4 that at the show cause hearing Elam is directed to 5 produce any and all trust account statements and 6 related records reflecting the receipt and 7 disbursement of the DIP funds for March, 2017, to the 8 present, including the recipient of the disbursements 9 (unrelated matters may be redacted). So we've still 10 not received those. 11 And as the Court recalls, and it's attached 12 as Exhibit E, there were two separate disbursements. 13 We don't know when they were made, but we know between 14 March 2, 2017, when the $34,400 came into his trust 15 account from the DIP account, by March 31, 2017 there 16 was only 30, sorry, $457 remaining. So there 17 had been a disbursement ofapproximately $5,000. And 18 then between March 31, 2017, and March 28, 2017, Mr. 19 Elam's trust account went down to $22,520. So there 20 was another $8,000 disbursement. 21 So this isn't a situation where there was 22 one disbursement. And we still are here under the 23 order to show cause. And we don't have the records 24 reflecting exactly when the money went out, and to 25 whom it went out to. And that's one of the things the 3 taking the funds out ofthe trust account? 4 MR. ELAM: Your Honor, that was in an 5 e1nergenc:( situationi and they were 1211t baqls;, aad - 6 THE COURT: Can ~ou tell me where in the 7 ethical rules there's anj:: Qrovision that saysl I can 8 take a client's funds out oftrust account based on an 9 e1nergency? 10 MR. ELAM: No. There is none. 11 Your Honor, I had -- I -- I can't argue with 12 you. I'm not going to. I just -- I ask the Coutt to 13 not suspend me because that would really be 14 devastating to me. And after last night what I found 15 out, I don't know if I'm actually able to tell the 16 Comt, but I will be covering for someone whose son 17 died last night, and now that would be even worse. 18 THE COURT: Well, I'm not sure that I have 19 much leeway, frankly. On the lying to the Court, I 20 have leeway. I have to take a look at the 21 misappropriation of funds. Because I -- I'll take a 22 look at every Bar opinion there is on that issue, but 23 I'1n sure I have any -- much leeway. 24 MR. ELAM: I understand. I understand. 25 THE COURT: Okay. Mr. Freedman. Page7 Page6 1 MR. FREEDMAN: Yes, sir. 2 THE COURT: You're also here on a motion for 3 sanctions. 4 MR. FREEDMAN: Yes, sir. And I've already 5 provided to Mr. Elam my exhibit register. And we were 6 rushing to put this together. This morning I went to 7 the office, I realized that I had left out two 8 exhibits, which are G and H. So if I may hand this up 9 to the Court. 10 THE COURT: Sure. Mr. Elam, have you taken 11 a look at them? 12 MR. ELAM: Your Honor, I'm looking at them 13 now. 14 MR. FREEDMAN: And Your Honor, before I get 15 to the issue of the sanctions, I just do want to let 16 the Court know that we did file a request for the 17 Court to take judicial notice of other filings we've 18 made with the coutt. In the exhibit register, 19 Exhibits A, B, C, D, E, and then G and H, those are 20 the communications between myself and Mr. Elam. 21 I can go through them with the Court, but 22 there are specific representations made in those 23 s where I'm trying to find out what happened to 24 the trust funds, where Mr. Elam represents to 1ne, and 25 filed with the coutt, that those trust funds were Page 8 1 Comt requested in the order to show cause. So I I' 2 think this is the fifth time we're here on this matter 3 and we still don't have the records. So I just wanted 4 to address that with the Court. 5 THE COURT: Let's talk about the sanctions 6 for you and your client. 7 MR. FREEDMAN: Yes, sir. 8 THE COURT: I'll deal with the other issue. 9 MR. FREEDMAN: Exhibit F are my firm's 10 account statements to Bank ofnew York on behalf of 1, 11 servicer, Bayview. 1'1n going to see a recap. This 12 was tlu ough September 13. And we've calculated that 13 my firm spent 43.9 hours oftime on this issue through 14 the 13th. I provided - 15 THE COURT: Now, what issue? On the trust 16 account issue? 17 MR. FREEDMAN: Account issue, Your Honor. 18 THE COURT: And those are the things you 19 have not redacted? 20 MR. FREEDMAN: Those are the things I've not 21 redacted, yes, sir. 22 I provided this client a discounted rate of 23 $350 an hour. My regular rate is $550 and hour, you 24 see. So the total fees are $14,450, costs of coming 25 up here on the matters, and related copy costs and OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 5 to 8)

224 Page9 Page 11 I other costs are $1,059.01, which brings a total of I THE COURT: Take a look at them. I'll tell 2 $15, you what, I'm going to give Mr. Elam 15 minutes to 3 That did not include the time to prepare 3 look at the records and I'll come back. 4 yesterday and to come up here today. Adding another 4 Now, one thing l 1 m going to ask you, Mr. 5 five hours between yesterday and today, and that's 5 Freedman, you 1 ve given n1e an exhibit register, which 6 being very conservative, because I had a paralegal 6 is appropriate, but you added two exhibits. Can you 7 prepare all this stuff - 7 submit, just send it in -- call Vivian and ask how she 8 THE COURT: Five hours ofhow much? 8 wants it, with a revised exhibit register with the two 9 MR. FREEDMAN: $350 an hour, which comes to 9 additional exhibits. IO $I,750, which comes to a total of $I7, I want IO MR. FREEDMAN: Yes, sir. II to - 11 THE COURT: And you can -- Mr. Elam, any 12 THE COURT: Give me that number again. 12 objection to the documents, authenticity of any of 13 MR. FREEDMAN: $17, these documents, or do you want to wait - 14 THE COURT: Okay. Now tell me one thing. I 14 MR. ELAM: I don't have any objection except 15 want to make sure that the record is clear. You 1 ve 15 for the time records. And I would just like to say 16 spent, as to the trust account issue, 43 hours and 16 too, there's nobody here to testify to the 17 nine tenths. 17 reasonableness ofthose fees for Mr. Freedman. 18 MR. FREEDMAN: Through the 13th. 18 THE COURT: I can deal with that myself. Ii 19 THE COURT: Yes. 19 MR. ELAM: Yes, sir. 20 MR. FREEDMAN: Yes, sir. 20 THE COURT: Okay. So and you don't object 21 THE COURT: Which represents fees of 14,450, 21 to the authenticity ofmr. Freedman's time records? I 22 plus costs related to the trust account issue of 22 MR. ELAM: I have no reason. 23 $1, THE COURT: So Mr. Freedman, you can I 24 MR. FREEDMAN: Yes, sir. And - 24 indicate on the revised exhibit register that all 25 THE COURT: Plus the five hours at exhibits were admitted. Page 10 Page 12 ' I MR. FREEDMAN: Yes. And let me let the I (All Freedman Exhibits admitted.) 2 Comt know. There are times when I came before the 2 MR. FREEDMAN: Yes, sir. 3 Cou1t on matters relating to the trust account issue 3 THE COURT: Okay. I'll be back at 10:00. 4 and there were other -- another matter. And so what I 4 (A recess was taken.) 5 did was, when I went through the time records I 5 THE COURT: Please be seated. Back on the 6 divided it in half. 6 record. 7 THE COURT: Thank you. 7 Mr. Elam, did you have a chance to look at,: 8 MR. FREEDMAN: Allocated half to the trust 8 the time records? Are you ready to cross examine Mr. 9 account issue, half to where our other issue is before 9 Freedman? ; IO the Court. So I did want to provide the Comt that 10 MR. ELAM: Yes, Y om Honor, I have, and l ' 11 infmmation, and let Mr. Elam know that where there 11 don 1 t have many questions, maybe one or two, and 12 was an issue we did divide that time between the 12 that's it. 13 two tasks. 13 THE COURT: You're entitled to any. Mr. 14 THE COURT: Now, Mr. Elam, do you accept 14 Freedman, up to the stand. Please raise your right 15 what Mr. Freedman said as a proffer, or I will have 15 hand. 16 him sworn in and testify to that. 16 Do you swear or affirm to tell the truth, 17 MR. ELAM: I mean, Your Honor, 43 homs on 17 nothing but the truth, so help you God? 18 this issue is a pretty exorbitant amount oftime, I 18 THE WITNESS: I do. 19 think, but THE COURT: Okay. Please be seated. State 20 THE COURT: Mr. Freedman, come on up to the 20 and spell your name for the record. 21 stand. I'll let him testify. 21 THE WITNESS: Gary M. Freedman, 22 MR. ELAM: I mean, Your Honor, I F-r-e-e-d-m-a-n. 23 THE COURT: You can cross examine him. 23 THE COURT: Thank you. Mr. Freedman, I 24 MR. ELAM: I haven't had a chance to look at 24 suggest that you, since you 1 re under oath now, you 25 these records, Your Honor. 25 repeat what you said from the podium concerning your ' OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 9 to 12)

225 Page 13 1 titne, the reduction in time, and what have you. I THE COURT: Mr. Freedman, I think you said 2 THE WITNESS: Yes, sir. 2 Exhibit E, not Exhibit F. 3 THE COURT: And then Mr. Elam can cross 3 THE WITNESS: Sony. 4 examine you on it. 4 THE COURT: I think your time records are 5 THE WITNESS: Exhibit E to the exhibit 5 ExhibitF. 6 register that I presented to the Court this morning 6 THE WITNESS: I do apologize. Thank you, 7 includes the billing records from my finn, Broad and 7 Your Honor, yes. The time records are Exhibit F. 8 Cassel, LLP. 8 MR. ELAM: I just thought I couldn't hear. 9 The time that's not redacted, as reflected 9 BY MR. ELAM: 10 in the account statements, are for time devoted to the IO Q Mr. Freedman, ifyou will look at Exhibit F, 11 issues with respect to the trust fund issues that came I I I guess we'll start at the beginning, and can you tell 12 from the DIP account on March 2, 2017, and the efforts 12 me which entries that you determined should be 13 that my client undertook through me to investigate and 13 discounted? 14 dete1mine what happened to those funds, and the 14 A Sure. I'm starting with the May, 2017 time 15 various pleadings and motions and court appearances in 15 entries. Tell me when you're there, please. 16 respect thereto. I 6 Q Well, if you could, start on page 2 in the 17 The time entries are through September 13, 17 April, or is that , and reflect hours expended of43.9 hours, total 18 A There's nothing. There's nothing discounted 19 fees of$14,450, costs associated with those 19 there. 20 activities at $1,059.01, for a total of$15,509.0l. 20 Q Okay. All right. Okay. May 8th. 21 And as I indicated in my presentation, 21 A I misspoke. No. Okay. So May 8, as to May 22 between my time and my paralegal's time yesterday and 22 9, 2017, receive and review from B. Elam and 23 today we're asking for another five hours at $350 an 23 prepare for today's hearings, including status 24 hour, which is sony, $1,750.!fl may step 24 conference, 3.7. I discounted that by 50 percent, so 25 down and grab my other sheet, Your Honor. 25 therefore 1. 9 hours was allocated to the DIP fund Page 15 Page 14 1 THE COURT: Yes, sir. 1 issue. 2 THE WITNESS: So with that additional $1,750 2 The next time entry, telephone conference 3 the total that my client is seeking is $17, with B. Elam regarding the status conference and 4 As I indicated, the rate that I charged this 4 attend hearing on status conference, 4.2 hours. I 5 client is a significantly discounted rate of $350. My 5 discounted that by 50 percent. So therefore, 2.1 hour 6 standard rate is $550 an hour. 6 was allocated to the DIP fund issue. 7 And in respect to those time entries 7 Moving on to July. 8 reflected in Exhibit E, in which I determined that I 8 Q Okay. I' 9 undertook another task other than specifically just 9 A July 7, 2017, prepare for July 11 hearings, 10 solely related to the task relating to the DIP funds, I 0 2 hours. Discounted that by 50 percent, so 1 hour was 11 on those tasks I discounted the time by 50 percent, 11 allocated to the DIP fund issues. 12 and that's where I came up with the 43.9 hours. 12 My paralegal, examine pleading to pending 13 THE COURT: Thank you. Mr. Elam. 13 motions, pull case law supporting our motion to 14 CROSS EXAMINATION I 4 preclude debtor's purported expert. Pull case law 15 BY MR. ELAM: I 5 regarding our motion to show cause. Order related to 16 Q Mr. Freedman, when you say that you 16 conte1npt and sanctions against debtor 1 s counsel. 17 discounted the time, is the time that's in the I 7 Prepare for upcoming hearings. Prepare binder and 18 records before the Court the discounted time, or is 18 index for pending motions That was reduced to 19 that the time prior to the discount? A The unredacted time in Exhibit E is a 20 Under there, July IO, 2017, prepare for 21 nondiscounted time. However, the 43.9 hours that we 21 hearings on motions to preclude expe1t 1 s motion for 22 are -- that I am seeking is giving the discount of the 22 order to show cause and motion to vacate, 2 hours percent on those time entries that I determined 23 That was reduced by 50 percent to 1 hour. 24 that I undertook another task other than solely the 24 And those are the total number oftime 25 task related to the DIP fund. 25 entries that were allocated between the two different Page 16 OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 13 to 16)

226 Page 17 Page 19 assignn1ents. 1 THE COURT: No, that's in the previous 2 Q Ifyou'll look at, I guess it's the fifth 2 month. This is the June 8th, 2017 bill. 3 page into Exhibit F. It says page 4 of 5. It says 3 THE WITNESS: I see. No, I believe all that 4 iten1ized expenses. 4 time related to the DIP fund issue. 5 THE COURT: What's the date? Which bill? 5 THE COURT: So none ofthat should be 6 MR. ELAM: I'm sorry. March -- it goes from 6 included? 7 March 8th, 2017 to April 30th, THE WITNESS: No, it should be. This 8 THE COURT: Okay. Thank you. And you're on 8 related-- ifl'm looking at the May 9, 2017 through 9 the last page of that? 9 the June 30, 2017 expense items for (inaudible) those I 0 MR. ELAM: Yes, sir. I 0 all related, in my view, to matters relating to the 11 THE WITNESS: I'm there. 11 DIP fund issue. 12 BY MR. ELAM: 12 THE COURT: Which would relate to the trust 13 Q Are these expenses that you are asking for 13 fund? 14 reimbursement for as well? 14 THE WITNESS: Yes, sir. 15 A Yes. 15 THE COURT: What was the research? There's 16 Q On March 15th, well, let me back up. 16 two ite1ns ofresearch there. 17 On March 8th, 2017, you're seeking travel, Gary 17 THE WITNESS: I don't have the backup. In 18 Freedman, mileage to from West Palm Beach office to 18 fact, Your Honor, for purposes ofjust moving this 19 attend continued 2004 examination. Could you tell me 19 along, the $479.38, I'm willing to waive that. 20 how that related to the sanction, or attorney fee? 20 THE COURT: I'm not making - 21 A And it doesn't. And let me say, we didn't 21 THE WITNESS: I understand. But my problem 22 get back into our office until yesterday because of 22 is, again, I didn't have an opportunity to go through 23 the hun-icane. We put this together. Did the best we 23 all the backup yesterday. So I think -- I cannot 24 could. But if! could go through this, I will tell 24 swear under oath that that time related specifically 25 you where I think that the time entries, or the 25 to the DIP fund issue, and therefore, I don't feel Page 18 I itemized expenses should not be included. I comfortable advancing it. 2 I don't believe that , that any of 2 THE COURT: I appreciate that. Thank you. 3 that should be included. 3 Let's talk about the August 11th bill. Let's do the 4 Q Are there any other items that you might 4 same exercise, in essence. 5 have overlooked that you think might not should be 5 THE WITNESS: The same, Your Honor. I'll 6 included? 6 waive that. 7 A Open pages now 5/24 2,017, as the Westlaw 7 THE COURT: And then we have the next 8 for $ I can't tell you specifically what that 8 month's bill, September 18th bill. I'm not sure I see 9 research related to. I know that we were in the midst 9 any expenses on that one. I don't. 10 of the DIP fund issue at the time. I know I was 10 THE WITNESS: I would add, Your Honor, that 11 filing motions in respect of it at the time. And I I I today I believe the IRS rate of 58 cents a mile, know I was doing research. But I can't tell you 12 miles, would be, I think it's $87. That's not I 13 specifically what that research was for. 13 reflected there. 14 Ifyou count in from the back three pages - 14 THE COURT: Okay. You said 58 cents times 15 THE COURT: Well, why don't we take the miles? 16 bills for 5/9/2017 through 6/30/2017, any of those 16 THE WITNESS: No. 58 cents times 150 miles. 17 that you believe should not be included? Let's just 17 THE COURT: 75 miles each way. 18 go by month by month. 18 THE WITNESS: Each way, yes, sir. 19 THE WITNESS: Yes, sir. 19 THE COURT: Okay. Thank you. 20 MR. ELAM: Your Honor, what date did you 20 BY MR.ELAM: 21 say? 21 Q Mr. Freedman, do you -- does your client pay 22 THE COURT: 5/9/2017 through 6/30/ you for travel time? 23 THE WITNESS: There was only one itemized 23 A Yes. 24 expense, which was the 5/24 that I've already 24 Q Ifyou can look at the five -- 5/15/ commented on, Your Honor. 25 entry. It looks like its from an NF. Page20 OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 17 to 20)

227 Page21 Page 23 1 A Yes, I see it. 1 been filed. And you had appeared on behalf of your 2 Q Can you tell me how that relates to the DIP 2 client. 3 funds or the trust issue? 3 Q If you can look at the entry above that, 4 A That was my paralegal preparing for the 4 exchange further s with B. Elam regarding case 5 hearing on the motion to compel, which related 5 and orders on 5/12,.3, can you tell me what those 6 directly to the DIP issue. 6 s were and what orders you're referring to? 7 Q Redacting confidential information and Bate 7 THE WITNESS:!fl may step down? 8 stamping of documents? 8 THE COURT: Yes, sir. : 9 A I believe that related to it, yes. 9 THE WITNESS: Mr. Elam, tell me the date IO Q What client documents were received and 10 again, please. I turned the page. 11 reviewed? 11 MR. ELAM: Oh, why did you ask me that. May 12 A I don't believe that they were my client 12 12th. 13 documents. 1believe that they were your client 13 THE WITNESS: I see that there was time 14 documents. I can't tell you exactly what documents 14 billed on May 12 with respect to the motion to compel, 15 were reviewed back on May, and that we had exchanged s in respect ofthat. 16 Q What production were you preparing for, or 16 I know, as well as you do, that I was having a 17 was your paralegal preparing for? 17 difficult time getting a straight answer from you with 18 A It wasn 1 t our production. You never served 18 respect to what happened to the DIP funds. 19 a request for production ofdocu1nents on us. So it 19 I sent you numerous s trying to get the 20 would have been documents that you had produced, on 20 account staten1ents, trying to get a straight answer, 21 behalf ofyour client, that we were going through to 21 and!lying to clear up what I thought was a pretty 22 redact confidential information, for the upcoming 22 concise issue, so -- and all of that began on about 23 hearing, and the upcoming hearing -- because I don't 23 April 20th. So given the chronology of events, I 24 have unredacted bills, but I'm assuming it's - 24 believe that related to the DIP fund issue. 25 Q I'm sony, I'1n listening, I'm sorry, I just 25 BY MR.ELAM: Page22 Page 24 I 1 was looking at a date. I apologize. 1 Q Do you have any ofthose s here to show I 2 A -- hearings on the status conference and 2 that those fmther s and regarding the case and 3 motion to compel. 3 orders relate to the DIP funds? 4 Q So the client documents that you were 4 A All I can do is refer to the time entries 5 reviewing were documents that we had produced? 5 that relate directly to the motion to compel, those 6 A I believe that's correct. 6 trust account records, exchanging s with respect 7 Q You believe it is, or do you know that 7 to the form of orders, in respect to that. 8 that's what it was? 8 And I know that you had even contested the 9 A Again, we've never published my client 9 form ofthe order. I believe 1 sent the Court my 10 documents. You never requested my client documents. I 0 proposed form of order indicating that you did not 11 So I'm fairly ce1tain that they were debtor produced 11 agree to the form, and that you had indicated that you 12 documents. 12 would be submitting a competing of order, which you 13 Q So we never requested a copy ofthe note and 13 never did. 14 mmtgage? 14 Q Mr. Freedman -- I'm not going to get into 15 A No. 15 that. 16 Q You didn't tell me at a deposition that you 16 Ifyou look at the entry right above that 17 had a copy of the note and mortgage in your desk 17 ifs, review orders on status conference and prepare 18 drawer, and that you could produce it if we insisted? 18 to B. Elam regarding dispute over orders. 19 A Absolutely. Because you had filed what I 19 A You're right. That one should not be in 20 believed to be a meritless motion, and my client 20 there. 21 didn't have standing (inaudible). So I told you that 21 Q So how do we know that the next one is not 22 I had in my possession the original note. 22 regarding the exact same order that you don't think 23 Q. We never asked for a copy of it? 23 should be in there? 24 A I don't believe so. You already had a copy 24 A Because it's referring to orders, and orders 25 of it because the complaint in State Court had already 25 related to both the status conference order, as well I OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 21 to 24)

228 Page 25 Page 27 1 as the motion to compel order. 1 Q So how -- in your time keeping when you 2 Q So the entry above that, revise order on 2 referenced documents or tasks performed on behalf of 3 motion to compel and prepare s to B. Elam 3 your client, how do you normally characterize that? 4 regarding sa1ne, that , or that time entry 4 A You're referring to inc personally versus how 5 represents tasks undertaken regarding the DIP funds? 5 my paralegal regards it? 6 A Yes. That's what the motion to compel was 6 Q I said you. 7 all about. 7 A I would have used the term debtor documents, 8 Q In the next entry you said since the time 8 or if it referred to my client's documents I would 9 entry said order, it didn't relate to the DIP funds. 9 have put Doney's (phonetic) documents, most likely. 10 Yet this time enh y says, order, and you say it does 10 Q Did you not review her time entry? 11 relate to time entry, or DIP funds. 11 A I review all time entries before they go to 12 A I'm son y, I don't understand the question. 12 the client. 13 I had already indicated that the (inaudible) Q Are you able to change them? 14 entry that said, review order on status conference and 14 A Yes. 15 prepare to B. Elam regarding dispute over order, 15 Q Why didn't you change this one if it were 16.2, is there inadvertently. 16 truly documents produced by the debtor? 17 Q Right. 17 A Because I didn't think it was that confusing 18 A Right. 18 for purposes ofthe transmittal to Bank ofnew York. 19 Q Because the other enh'y right below that you 19 Or I just miss it. I mean, I try to be careful 20 said did belong because it said orders. 20 reviewing my bills, but I mean -- and you'll see, I 21 A Right. Because you and I kept going baek 21 don't think there's many typographical errors in these 22 and forth over the orders, including and in 22 bills. The term, client documents, may have just -- I 23 patticular, the order on the motion to compel. 23 may have missed it. But I know that I did not ask 24 Q What I'm getting at, Mr. Freedman, is, I 24 this paralegal to review my client's documents don't understand since there is an S on orders, you 25 know that for a fact. Page 26 I think it should be included. 1 Q What documents were Bate stamped? 2 A Yes. I know we went back and forth over the 2 A They would have been debtor's documents. 3 form ofthe order a number oftimes, and I made 3 Q Do you recall what those documents related 4 revisions to it, is my recollection, and you still 4 to? 5 didn't approve it. 5 A I don't recall as I sit here. 6 Q What about the entry above that one on 5/11, 6 Q So how do we know that they related to the 7 review additional production by debtor? What task or 7 DIP funds? 8 what production did you review? 8 A Given the proximity oftime. But as I sit 9 A I have no specific recollection as I sit 9 here today, I cannot tell you specifically that they 10 here what I reviewed at that titne. 10 do. I I Q Do you know if it related to the DIP funds? 11 Q Ifyou'll look at the entry on 5/22. I2 A I have no specific recollection as I sit 12 Receipt and review debtor's motion for extension of 13 here. 13 time and notice of hearing. How does that relate to I4 Q On that entry obviously the production is 14 the DIP funds? I5 from the debtor; correct? 15 A I thought that was your motion to extend the I6 A Yes. 16 time to comply with the court order requiring the I7 Q Okay. So on 5/15 you say you testified that 17 production ofdocuments. 18 you were reviewing documents produced by us. Why does 18 Q You sure it wasn't 1ny motion for extension I9 it say client documents? 19 oftime to produce experts? 20 A My paralegal put in the wrong nomenclature. 20 A I would have to look at the docket, Mr. 2I Q Or did she review documents produced by your 21 Elam. Ifyou'll hand it to me, I'm happy to look at 22 client? 22 it. 23 A No. 23 Q What document? 24 Q You 1 re sure? 24 A The docket. 25 A Yes. 25 Q Docket. Oh. Sony. Page28 : OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 25 to 28)

229 Page 29 1 THECOURT: Youcan MR. ELAM: Their computer in front of you. 2 3 THE COURT: No, no, no. That's not one 3 4 that's -- he can look at the one right on the table, 4 5 counsel table. 5 6 MR. ELAM: Okay. 6 7 THE WITNESS: It's taking a bit of time to 7 8 load. Your Honor, may I continue? 8 9 THE COURT: Yes, sir. I'm sony THE WITNESS: Looking at the docket, to the extent that the time entry on May 22, 2017, receive and review debtor's motion for extension of time and notice of hearing, refers to court paper 302, there was debtor's motion for extension oftime to file the expert reports, and should not be included BYMR.ELAM: Q Well, Mr. Freedman, that's maybe the fifth time that you've reviewed this again and said, you're right, that maybe that shouldn't be included. How do we know all of the time entries, and I'm not saying that every bit of it should not be included, but each time that I've asked you about something you said, oh, you're right, that shouldn't be included. So how do we know that this entire 43.9 hours, or a vast majority of it, shouldn't be included? 25 Page 31 account statements and order on debtor's inotion for extension of time and prepare to B. Elam regarding sa1ne. A You can split that. THE COURT: You said split that? THE WITNESS: Yes, sir. BY MR.ELAM: Q Well, Mr. Freedman, how much time did you spend preparing the order on the motion to compel? MR. ELAM: Or you know what, Your Honor, strike that question. BY MR.ELAM: Q. Let me back up to the June!st enlly. Attended hearing a motion for extension of time to provide reports and motion to compel trust account records. How much time did you spend here arguing about the motion to compel versus the motion for extension oftime? A More. Q More? A Yes, sir. On May these time enn ies where I split tbem 50-50, I think I gave you the benefit of the doubt, including the fact that you got the discounted rate of$350 an hour versus my regular rate of 550 an hour. Page 30 I A Because it should be included. I 2 Q Can you tell me why A Yeah. 3 4 Q Let me finish. Every enlly that I've asked 4 5 you about, you have agreed, oh, it shouldn't be. 5 6 A No, that's not n ue. Not at all. 6 7 Q Let's look at the next entry, 5/22. Prepare 7 8 response to extension 1notion and motion to compel 8 9 trust account. Why was that not divided by two to 9 IO allocate one portion to another task and another IO 11 pmtion to the DIP funds? A That should have been Q Okay. There's another one A Is that a question, Mr. Elam? Q Ifthat THE COURT: It's argumentative. You need to ask questions, not have a discussion with hitn MR. ELAM: Sorry, Your Honor BY MR.ELAM: Q Let's look at June 1st. Attended hearing on motion for extension of time to provide expert repo1is and motion to compel trust account records hours. Why shouldn't that be divided? A That should have been divided Q 6/2, prepare order on motion to compel trust 25 Page 32 MR. ELAM: Your Honor, that was not a response to my question. I move to strike that. THE COURT: I'll overrule that. But I understand your argu1nent, Mr. Freedman, and Mr. Elam. And frankly, my ruling would be, whatever you charge your client is the damage done to you and your client. BY MR.ELAM: Q. Let's look at June 5th. Prepare to B. Elam regarding orders. What orders are.you referring to? A The orders on the motion to compel and the orders on the 1notion for extension. Although I don't -- hold on a second, please. It would be those two orders. THE COURT: Any other questions, Mr. Elam? MR. ELAM: I'm sorry, Your Honor. I thought Mr. Freedman was about to respond to the -- I thought he had said wait a second. THE WITNESS: I responded. THE COURT: I thought so too. MR. ELAM: Oh, I'm sorry. I'm so sorry. I was waiting on him. THE COURT: I thought so too. Okay. Go ahead. BY MR.ELAM: OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 29 to 32)

230 Page 33 Page 35 I Q Mr. Freedman, on June 6th, exchange s I to B. Dempsey (phonetic) regarding same. Do you 2 with B. Elam regarding orders. What orders were you 2 recall what the 1notion to vacate was about? 3 referring to? 3 A Yes. You were seeking to vacate the Cou1t 1 s 4 A It would be those same two orders. 4 order on the 1notion to co1npel, is tny recollection. 5 Q So then why are those two entries not 5 That was the only motion to vacate, l believe you 6 divided by five, or in half? 6 filed. 7 A My recollection is, we were having a 7 Q Based upon what issue? 8 significant more lively debate over the form ofthe 8 A l don't recall specifically. l think l have 9 order on the motion to compel than we were on the 9 it in my binder. But whatever it was, the Court 10 motion for extension of time on the expert reports. I 10 rejected it. Ifyou want me to go grab my binder, I 11 don't think there was any contest over that fonn of 11 can - 12 order. But -- but you can split them, sure. 12 Q No, I don 1 t. 13 Q Again, On June 6th, exchange s with B. 13 A -- look at the motion. 14 Elam regarding form of orders. 14 THE COURT: l would like for you to go grab 15 A l was referring to both those time entries, 15 your binder. 16 Mr. Elam. 16 THE WITNESS: Yes, sir. 17 Q. Are you talking about the two -- the June 17 I'm looking at court paper 322, paragraph th, prepare to B. Elam regarding orders, 18 You state, at the hearing on the debtor's motion for 19 exchange s with B. Elam regarding orders, and the 19 extension both pruties argued about the production of 20 next two entries as well? 20 the trust account. At the conclusion ofthe argument i 21 A No. I was referring to the 2.2 time 21 (inaudible) counsel stated, an order had been entered 22 entries. 22 related to the production ofthe trust account 23 Q What about the two before that, prepare 23 records, which prompted the Coutt to state, uaood." 24 to B. Elam regarding orders? 24 Paragraph 10, at no time during the hearing 25 A I bill them as pursuant to trnstee 25 did the Court order the debtor's counsel to produce Page 34 Page 36 1 guidelines, in point one hour increments. Even ifit I any further records, nor did the Court set a hard 2 related to just the one order, it's the -- it would 2 deadline ofjune 9, 2017, in which the debtor's 3 still be billing at. I. 3 counsel was required to produce any further trust 4 Q Mr. Freedman, it is not the point ofwhether 4 account record. 5 it's a.i or a.05. It's the fact of, I'm asking you 5 Paragraph 11, however, despite the fact the 6 whether they apply to the DIP funds or whether they 6 Court did not include June 9, 2017 as any deadline 7 apply to the motion for extension. 7 production, and despite the fact the debtor's counsel 8 A And my answer would be the same, Mr. Elrun, 8 objected to this deadline for many reasons, as a 9 which is, my recollection as l spent significant - 9 footnote, as with the original order Doney's counsel 10 more time dealing with the issue ofthe order in 10 submitted an order to the Court requiring debtor's 11 respect to the trust account records, because that was 11 counsel to produce trust account records on or before 12 a combative conversation that we continued to have for 12 June 9, three months. 13 Paragraph 12, on June 12th, 2017, after 14 Q. Look at June 12th. Receipt and review order 14 debtor's counsel was out ofthe country on a 15 on motion to compel trust account records and order on 15 preplanned family vacation, the Coutt entered its 16 expert reports,. I. Why was -- again, I understand 16 order compelling production oftrust account 17 it's.1, but the fact is, ifyou 1 re going to give 17 documents. Referring to docket entry 315. Pursuant 18 credit for what goes to the DIP funds, and what goes 18 to this order the debtor's counsel was required to 19 to something else, we need to know why that wasn't 19 produce certain trust account docu1nents on or before 20 divided by two as well. 20 June 9, A Because again, if! had just received the 21 13, as the order submitted by Doney's 22 order on motion to compel I would have billed. I on 22 counsel, and ultimately entered by the Court, failed 23 it. 23 to accurately reflect the Court's ruling at the June 24 Q Ifyou'll look at the July 3rd, 2017 entry, 24 I, 2017, there's a word missing, l guess it should be 25 receipt and review motion to vacate and prepare 25 hearing, as the Coutt never stated the trust account OUELLETrE & MAULDIN COURT REPORTERS, INC. (305) (Pages 33 to 36)

231 Page 37 I documents were to be produced on or before June 9, , the order compelling production oftrust account 3 documents should be vacated. 4 And then that's the reliefthat you sought 5 in the wherefore clause. 6 BY MR. ELAM: 7 Q Exactly. And my point is, was it -- was the 8 motion -- did 1 seek to vacate the order based upon 9 not wanting to produce the documents, or was it I 0 because it was my position that you had uploaded an 11 order that didn't reflect what the Comt had ruled? 12 A I don't know what your state ofmind was, 13 other than continuing to be dilatory in respect to 14 producing the trust account records, which you still 15 haven't done as of today. 16 Q Let's look at entty on 7 /11. Prepare for 17 and attend hearings on motion to preclude experts, 18 tnotion for order to show cause, and motion to vacate, Why was that en tty not allocated halfto one issue 20 and half to the other just like the entry above it, 21 which is for the exact same task? 22 A It should be. 23 Q Previously Mr. Freedman, I know that you had 24 testified that you bill your client for travel, which 25 I understand. It doesn't appear that travel is billed Page 39 spent? A You mean actually the time to tt avel up, is that what you're looking for? Q I'm asking you, do you bill for the time to travel up? A Yes. Q Sorry. The computers went off. Maybe I should close. A So either it was inadvertently redacted, or I failed to bill my client for that time. Either way I think it's for your benefit. Q Well, I mean, I understand that. And I just want to be uniform, or I want to know ifmaybe the time you do bill your client for you really don't bill for travel. I don't know. A I've already testified under oath, but I'll answer again, Mr. Elam. I charged this client for my travel time. The client gets billed for my travel time. And the client pays for my travel time. If! inadvertently missed it this time, I don't know, because again, there's things redacted, I don't have them redacted bills. Perhaps it was redacted and you're not being sought to pay the reimbursement of that. But I don't recall any instances where I've ever cognitively not charged this Page 38 for in this, unless you have a very fast car,.6, to 2 travel from Miami to West Palm is pretty quick. Could you explain why that's not THE COURT: Can you tell me what the date 4 5 is? 5 6 MR. ELAM: I'm sorry, Your Honor. June or July I Ith, THE WITNESS: There's certain expenses on 8 9 page 5 that have been redacted. I can't recall if 9 I0 that was redacted or not And I can tell you that my legal assistant, or my secreta1y, who was in charge of submitting l3 mileage to our accounting office is no longer with me And for the reason was, she wasn't ver good at that task. So perhaps therers some time that expenses should have been allocated to that travel to the court for that matter, for which I'm not seeking any reimbursement for BY MR. ELAM: Q I'm not sure I understood that. Why was the travel time not included here? A I don't know, but perhaps it should have been. Ifyou want me to include it I'm happy to include it Q How do you know how much time you would have 25 Page40 client for travel tiine. Q July 12th, the very next entry. Prepare order granting motion to preclude experts. Order on motion for order to show cause and order denying motion to vacate. Again, why was that not allocated to one task and portion allocated to another? A Yeah, to be fair, two thirds of the.4 should have been allocated to the trust account. Q How do you know - THE COURT: Wait, wait, wait. You're talking about July 12th? MR. ELAM: Yes, sir. THE COURT: So two thirds should be allocated to - THE WITNESS: For three orders, Your Honor. THE COURT: Okay. I just asked a question. BY MR.ELAM: Q So how much time did you spend preparing the order granting motion to preclude? A Again, I don't recall specifically as I sit here, but there were three orders, it's fair to say that I spent an equal amount oftime on each order, and that's why I said two thirds ofthe.4 should be allocated to the tt ust fund issues. Q The next, same question, I know it's a.1, 10 (Pages 37 to 40) OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

232 Page 41 Page 43 1 but why was there -- strike that question, Your Honor. 1 THE COURT: Okay. Thank you. Mr. Freedman, 2 I'll go forward. 2 do you want to say anything else, in essence in 3 July 13th, revise dismissal order and 3 redirect? 4 to counsel. How does that relate to the DIP funds? 4 MR. FREEDMAN: Yes, sir. No, sir. 5 A Yeah. 1 know I spent some time making 5 THE COURT: Okay. You can step down. Mr. 6 certain that the dismissal order retained jurisdiction 6 Freedman, do you wish to introduce anything else? 7 to be able to trust fund issues, but you're right, all 7 MR. FREEDMAN: No, sir. 8 ofthat should be allocated to 50 percent. 8 THE COURT: Okay. Any other items. 9 Q Two below that, July 13th, exchange s 9 Mr. Elam? 10 with B. Elam regarding orders. How do you know what 10 MR. ELAM: Yes, sir. 11 orders took what time? 11 THE COURT: You're entitled to testify. I 12 A It's.I. 12 think at the vmy least you should testify concerning 13 Q I understand it's.1, Mr. Freedman, but I'm 13 the circumstances under the misappropriation. 14 asking you MR. ELAM: Yes, sir., 15 A 1 couldn't have billed any less than. I. 15 THE COURT: Ifyou want -- I assume you want 16 THE COURT: That's not his question. His 16 me to take into account. 17 question is, for tabulation purposes why should you 17 MR. ELAM: Yes, sir. 18 not be charging $17.50 versus $ THE COURT: Please raise your right hand. 19 THEWITNESS: Yeah. Ifwe'rereferringto 19 Do you swear or affirm to tell the truth, 20 three orders, two of the orders relating to the trust 20 nothing but the truth, so help you God? 21 fund issue, so two thirds of the. I should be 21 THE WITNESS: Yes. 22 allocated. 22 THE COURT: Please be seated. Please state 23 THE COURT: Thank you. 23 and spell your name for the record. 24 BY MR. ELAM: 24 THE WITNESS: Brett Elam. B-r-e-t-t 25 Q On July 17th, receipt and review order at 9, 25 E-1-a-m. Page42 1 debtor 1 s motion to vacate, order granting motion to 1 '!'.HE COURT: Go ahead. 2 preclude, and order dismissing case, and prepare 2 THE WITNESS: Your Honor, first, the funds 3 to B (inaudible) regarding same. How much time is 3 were there and my wife had surge1y. and 1 needed to 4 allocated to the order denying motion to vacate? 4 use the funds to live for a bit, and when we got the 5 A Let me look at a time entry. There's four 5 funds we put them back. I 6 specific tasks, so you can allocate.25 to that task. 6 THE COURT: Okay. When did you - 7 Q I'm sony? 7 THE WITNESS: And that - 8 A I thought you asked, how much time do 1 8 THE COURT: Go ahead. 9 allocate to the receipt and review order denying 9 THE WITNESS: Sony. Go ahead. That's what 10 debtor's motion to vacate order in respect ofthe.2 10 happened. 11 hours that was allocated, or billed for that group of 11 THE COURT: When you said you needed the 12 time entries. So looking at the time entries, I would 12 funds, what did you need the funds for? 13 allocate.25 for receipt and review ofthe two. 13 THE WITNESS: I don't recall offhand exactly 14 Q How do you give.25 of27 That's more than 14 what it was, but I just -- I believe it was just 15 the-- 15 living at that time, because of her surgery and issues 16 A Quarter. That's quarter. Quarter. Quarter 16 going on with that. 17 oftwo. 17 THECOURT: Okay. Didyouhaveany 18 Q Oh. 18 com1nunications with your client concerning this issue? 19 A The dismissal order again, dealt in my mind, 19 HIE.WITNESS: No, sir. 20 it's partially with the trust fund issue, so THE COURT: You don't dispute that you took 21 percent of the.2. And then I can't disclose to you 21 14,000 I guess, total? 22 what I communicated to my client, but certainly the 22 THE WITNESS: I -- that's -- whatever. 23 trust account issue was pa1t of that co1rununication. 23 THE COURT: Mr. Freedman, any questions? 24 MR. ELAM: Your Honor, I don't think I have 24 You don't have to, I just -- on this topic, it's 25 any further questions. 25 really not your issue. I understand. So don't feel Page44 OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 41to44)

233 Page 45 Page47 1 compelled to - I MS. CRAWFORD: So I just -- I find that hard 2 MR. FREEDMAN: No. I believe the 2 to swallow with a horrible outcome. 3 co1nmunications are ad1nitted into evidence, speak for 3 THE COURT: Okay. That's your statement. I 4 themselves, Your Honor, with respect to the 4 understand. Do you have any questions ofhim? 5 representations. 5 MS. CRAWFORD: Um - 6 THE COURT: Okay. Good. 6 THE COURT: Ifyou don't, then I'll excuse 7 Ms. Crawford, I see that you're here. Do 7 him and let you -- I'll frankly, put you on the stand 8 you have any questions of Mr. Elam? Come up to the 8 and let you say what you think or feel about this 9 podium, and you can answer that question, and ask him 9 trust fund issue. I0 any questions you have. It may be relevant, may not 10 MS.CRAWFORD: That's all I can talk about? 11 be. I don't know the answer. Because I haven't 11 THE COURT: Yes. For this hearing. 12 completely crystallized my thought process. 12 MS. CRAWFORD: Yes. 13 MS.CRAWFORD: I can just ask questions? 13 THE COURT: Ifyou have a malpractice claim 14 THE COURT: You can ask Mr. Elam questions. 14 agaiust him, a grievance against him with the Florida 15 MS. CRAWFORD: I mean, but I can't -- like I 15 Bar, that's -- this would not and is not going to 16 have a whole lot to say, but - 16 resolve any such claims. 17 THE COURT: That was the next thing I was 17 MS. CRAWFORD: Okay. 18 going to do, is ask you ifyou wanted say anything. 18 THE COURT: Okay. 19 But first, since Mr. Elam is here, do you have any 19 MS. CRAWFORD: So I don't have anymore 20 questions ofhim? 20 questions. 21 MS.CRAWFORD: Regarding the trust account? 21 THE COURT: Okay. You can step down. 22 THE COURT: Yep. 22 MR. FREEDMAN: Your Honor, I'm sorry, if! 23 MS. CRAWFORD: I have a questions what 23 may, I've got one question. 24 happens to that money. 24 THE COURT: Yes, sir. 25 THE COURT: You can ask. 25 CROSS EXAMINATION Page 46 Page 48 I CROSS EXAMINATION I BY MR. FREEDMAN: 2 BY MS. CRAWFORD: 2 Q Mr. Elam, pursuant to the show cause order 3 Q What happens to that money in your trust 3 upon which we are here today, docket ent1y 347, 4 account? 4 paragraph 2 states, at the show cause hearing Elam is 5 A I mean, after the case the bills were -- it 5 directed to produce any and all trust account 6 was more than that, so - 6 statements and related records reflecting the receipt 7 THE COURT: You're talking about your 7 and disbursement ofthe DIP funds from March, 2017 to 8 atto1ney's fees? 8 the present, including the recipient ofthe 9 THE WITNESS: Right. Yes, sir. 9 disbursements. Did you bring those records here I 0 THE COURT: I'm not saying that's right or I 0 today? 11 wrong, but that's what he's -- you've applied those to 11 A Mr. Freedman, honestly, I did not realize 12 your outstanding bills? 12 that with the hurricane and everything going on. I 13 THE WITNESS: Yes, sir. Once the case is 13 saw the entry, and I did not even realize that there 14 dismissed. 14 was a document production to go along with it. 15 MS.CRAWFORD: And I - 15 THE COURT: Okay. Thank you. 16 THE WITNESS: There was -- I'm sorry - 16 Mr. Elam, I will tell you, by the close of 17 there was more than that afterwards. 17 business tomorrow you will file under a notice of 18 THE COURT: More than that? 18 filing a copy ofthe trust records that indicate 19 THE WITNESS: More than the 34 outstanding 19 transactions in this account. 20 still. 20 MR. ELAM: Oh, yes, sir, I will. But just 21 MS.CRAWFORD: So initially I had paid it was just moved to my operating. But I will ,000, then another ten, and this And then he 22 THE COURT: That's not the - 23 asked me for another $43, MR. ELAM: Right. I understand. 24 THE WITNESS: That was the final bill, Your 24 THE COURT: Okay. You can step down. 25 Honor. 25 Now, Ms. Crawford, you want to come up on OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 45 to 48)

234 Page49 Page 51 I the -- come on up. Let me explain what I was saying I that, because that's relevant. 2 before. 2 Please raise your right hand. 3 In my opinion, Mr. Elam has violated ethical 3 Do you swear or affinn to tell the truth, 4 rules by taking money out ofyour trust account, using 4 nothing but the truth, so help you God? 5 it for purpose -- for personal purposes, even though 5 THE WITNESS: Yes. 6 he repaid it into the trust account. 6 THE COURT: Please be seated. 7 I'm going to contemplate what sanctions I'm 7 State your name and spell it for the record. 8 going to issue against him. That's the purpose of 8 THE WITNESS: Kim Crawford. K-i-m 9 this hearing. And frankly, I'm going to review what 9 C-r-a-w-f-o-r-d. 10 the Florida Bar does in similar situations. My guess IO THE COURT: Okay. Now you made a statement. 11 is, he's going to be suspended from the practice of II Why don't you say again what you just said. 12 law. 12 THE WITNESS: We had come out of court, and 13 The second issue ofcourse is, how inuch, if 13 this trust account issue was a repetitive issue. 14 any, he owes Mr. Freedman and his client. I'm going 14 THE COURT: It was. 15 to sanction Mr. Elam on that amount. Those are the 15 THE WITNESS: And we were downstairs, and I 16 two issues that I have to decide today. 16 just said, whether you took the money out or you 17 You may have other issues. You may not like 17 didn't, were you allowed to. And he said, yeah. So I 18 what he did, may think what he did was not up to 18 didn't say another word. 19 professional standards, that he committed malpractice. 19 THE COURT: Okay. Mr. Elam, you want to ask 20 I don't know the answer to that. That's not the issue 20 any questions, or Mr. Freedman? 21 today. 21 MR. ELAM: I don't, Your Honor, I - 22 That's why I said your complaint about his 22 THE COURT: Then that's all you have to say. 23 services is not relevant today. It is relevant to 23 MR. FREEDMAN: May I, Your Honor? 24 you, it1s relevant to what happened to your case, it's 24 THE COURT: Yes. 25 relevant to what would happen in the future. Meaning, 25 CROSS EXAMINATION Page 50 Page 52 whether you sued him or not. That's what I'm saying I BY MR. FREEDMAN: 2 to you. 2 Q Ms. Crawford, did Mr. Elam ever tell you 3 MS. CRAWFORD: Okay. 3 that the $34,400 that he took out ofthe DIP account, 4 THE COURT: So having said that, is there 4 your debtor-in-possession account, and put in his 5 something else you want to say about the trust account 5 trust account, that he ever disbursed any of those 6 issues, ineaning, him taking funds out ofyour trust 6 funds? 7 account and using them, other than it's wrong? 7 A No. 8 Believe me, I'm going to find that he did wrong. That 8 Q Did you ever ask him ifhe ever disbursed 9 what he did was completely inappropriate. 9 any ofthose funds? 10 MS.CRAWFORD:!just ask ifwhether he took 10 A Oh, I just said, whether you did or you 11 it or he didn't, if it was allowed, and he said it 11 didn't, were you allowed to. That's all I said. 12 was. 12 Q Whether or not he disbursed them? 13 THE COURT: Okay. When did he tell you 13 A Because that was the issue here in court 14 that? 14 repetitively. So I just said, whether you did or you 15 MS.CRAWFORD: After a hearing one morning, 15 didn't, don't tell me, I don't want to know, but are 16 downstairs. 16 you allowed. Because I don't, you know, I'd be a 17 THE COURT: Okay. Mr. Elam, did you - 17 lawyer if! knew all the rules here. 18 MR. ELAM: Your Honor, I believe what she 18 Q So in response - 19 had asked me, was it okay for the money to be in my 19 A I was. 20 trust account. That's what I was saying. She - 20 Q In response to that question he said he was 21 THE COURT: Come up here and take the stand. 21 allowed to? 22 MS. CRAWFORD: Me? 22 A Yes. 23 THE COURT: Yes. 23 MR. FREEDMAN: Thank you. 24 MR. ELAM: And I may be wrong. 24 THE COURT: Okay. Anything else you want to 25 THE COURT: I'm going to let her testify to 25 say about the a ust account, the funds that are OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 49 to 52)

235 Page 53 Page 55 I escrowed? I 2 THE WITNESS: Well, I just don't know what's 2 CERTIFICATE 3 going to happen to it. I mean, I know one of your 3 4 tnotions, number B, letter B or something, was to have 4 I, JACQUELYN ANN JONES, Court Reporter and 5 it put back in the debtor's DIP account. But I don't 5 Notary Public in and for the State of Florida at 6 know -- that was one of his motions, so I don 1 t know 6 Large, do hereby certify that the foregoing 7 what -- what happens. 7 proceedings were transcribed by me from a digital 8 THE COURT: Okay. And that may be an 8 recording held on the date and from the place as 9 approptiatc remedy, refund the money to you. I have 9 stated in the caption hereto on page I, to the best of IO to decide -- rm -- this is a serious matter, just so 10 my ability. I I you understand MS.CRAWFORD: Oh, trust me, three years of 12 In witness whereof I have hereunto set my 13 this and - 13 hand and seal this 1st day of October, THE COURT: No, no, I understand. But it's a serious matter for Mr. Elam too. It's a big deal MS.CRAWFORD: I don't know where I'm in my life now. I'm stuck in the middle - 17 JACQUELYN ANN JONES 18 THE COURT: I understand. I understand. 18 Commission GG To the extent it helps you, the real problem 19 Expires Feb. 18, with your case is getting valuations on the property down in Honduras, Guatemala, I forget which of the two countries it was in. That was the biggest problem MS. CRAWFORD: And I even questioned the (a)(2)(B) Rule, and did we need to do that THE COURT: That's something you may want to 25 Page 54 I talk to another attorney about. That's all I can tell 2 you. Thank you. Anything else, Mr. Elam? 3 MR. ELAM: No, Your Honor. 4 THE COURT: Okay. Thank you. I'll issue an 5 appropriate written order. 6 MR. FREEDMAN: Thank you, Your Honor. 7 THE COURT: Thank you. 8 (The proceedings were concluded.) :. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) (Pages 53 to 55)

236 EXHIBIT 8

237 lp.6_!sc<-' ('.Vl3 T P."'-~~ OEt..Gt r f'l L SUPERCEDES PRIOR SJ'R~+v- -tt ~ ~ ~ !~":1!*RSHIP (If AC(:!OUN1 Cli~$UMt:ff PURPOS!i ~;e;~ tt,i "'" ~r.:: \ ~- S!f'lg!il-Pl(Hi't Acco~nt P,,i Jit1pie,P11rh' ~\!;:'i:;{'l;,j"'r' j, Mu1up1e P'.uw lu:n:: Jr:1 Tuna;icv l: t ~r~ &11;i-&11~- i )'!ws.1 :S?nn1l!' ~\~~~..,.,,~,..,! 0ut!'tl,,. --,--,,..-~- ===-===--:--:= ! ~IG.HTS Al' DE:A.TH Is~~., U :i.-i1 n $it19l.1 ;.11rh,\_ ;:):IV'l' Sif'.fjltl,-;.arty /1r:counl ','ltl 1 P~;;-">.w-G-~fl\i'i ::.B'l:'"Jn:o;i,u 1 t.-r<!;"'f!t: ht!l"'ll!h~ -!l"c." l!!h'./ '1 f,~v.ll~~t~j-?iht\1 ;.o::_,:1...,-,.1t \VtL:n fr.gl:!1 ~d Sunr1 1Dr5-l'i ;.1 b.('-ltti;jlft-?t1ft'1' Ar.r.c'...ltl~ \l(,1h HUjitl~ ~~ S-1.11Vfvt:1'ih'f1?o\-,,."11-~Jt'! Jlh-Ur:s.i.;1nn~.r<f1 friarrni b~~1!r:1:ir~5 6!-0., d ' ttutti;c~-f.jn'i' R1~caun; -~'IJ\Uu.-.1.n f4it-c:1 c! S;Jr_';r;o ship! fij!j/it OR ~PJ!'S'ii,>:Jf~1cTi.~TfS-...:. ----i l! Ot/1'NERS!-llf' OF ACGOIJ~T. BUSIN!:$5 PLtl'tPOSf SC. PRC<>?_!::-nJF'-:; ~l~!' i<"; ~.-1!'!:'.!'1!,I :~con~11ar1r)'-.-,:,:-~ ::,,..-,:;,r :;- - ~c~ F::ti :iito:r!" :-H.1tf''l!1 \.IAH!Ur- CQ. ;Jr.l,'.1w - ---! ACCGOJ\fT 1111JMB:tR fqrtfol,jo NUM9t!A I r----~ - --,.,._---,-- - -' ""'= J Accout;r OWNllm:.s; W.M &.tiocftuis I TH,E LAV.' (H~ i=:ic-fs OF JAETT A!;LAM {i..;...! 1 zor I< l"fhjs- r ACG-:~HJNr! i ::i11-t :1ND."VE i Df:i.HAV-SfACH. l'l 'l;:l EX18l Jr~(; -:-it:.\'i ,,, --~ 'TY~ OF ]} CH-EC-~lN(i g_a 1.'INGf jaccounf _j ~/1{'i~l Y MA.~,t;f_l L. GE'RTlFl\-;:ATI:: OF 0EP0Sl1" ' -~: NO.'.-\' c..,,a,.. \-ln-1' 1..:11~;1o. 11 n-:-; :<>TA ~ l4i L SlGiiAlL'RE!SI fite 11rr#C~!fi1d ctr111ii:i&llh- UCl4'~ tj tl:.tfnformitim:- t-4:~'(i!'l J!1'0V'dt-d L~!] *r.t~ltjtt"-' rtai~ ~ ~ Wl'I~ 1H1d_ t'tvi of t~s ~tttt M r~!fl_tll t1!.ttti"l~f 1tu-11nn1tiil fothllihtti to,ei!fy--mlil Md -errp:o:,ltllnt iuit~r, uid'ut 11.i\'t a (tt\ii1 ''~ttnij ~ni:l til+:uf'"- ll up;!.f1l nwt ~ 1M 1,1~~"9.ud, J:S IO'cih1th~ tht l:"~~ti ~llf.! «+;wtdt_dj(: ~'It tt~lli'"j ~f in:i r;rti:: ~IM rft-*jf. I)( 111.,!?U;i.a~np.1~~1/))1!1$Ct4i;li!Q$':1'tt]S~ --- T~ri11~ -ti_ CC-'ltiitn.lf!!!. '}:'\ Trut'l '1 SlP< ir;l.ill.x F~ul:a,r..-.,.c1lf!bthtv ]IJ t:li:u:tr11n,..,.. f..,i<i!j- '!rprt:dcr"!i,;,t f"i.;;~;11;-,- ~ Su'tl!llilL<!eo Chf!tk" :'.J i~ Tf.fll').1_iS_-At1D rrh\drnqns_... ~-~--- //_ ] ~FAC ~fled.,... '~ ] i'r'<'-'lcn E;.'.:; ;?!;_!;_~---~~,_, (21 L thj-tl ]!. )flj(! Y>0 J ]>J J!~-J ;J_,; ~qm11;- -i.f.(! «: -'.!>I,.._,j,-;, )<;H,:.F- 1-,:-<../. ;<::l'![':-->" ~A.Cil'.UP' WITHHOlt>iN(l CERTIFIC.A.Ti-0-tAS. TIN: ~~-!'~O~Qi, --~~ :i;: Ti!iXYJ,'I'~! 0 NUMt!EA ''" = -:-~-n.!1 ~ '~lt' ::i'.':" It/I-&;' i;-,;~ ~- i ~-;-;f~;-~.:: '~I"'! :!;'11':"" I b:o: "e' ~1 1 '.;.i!j:- <r...~ J.';!!AQt;iJP l'i'it_m~_kg-- ~: t.11-?' ~~~ 1-~-~Sf.,IJ.' ~wm.:;;a-; J!_,~ re;;::.iw.! i"l-.oe ra. t~ "\.'-I l>if:!1'"---1 ';;f ~..~~!-1 ::;;-~~=-r. -~-tl'fl;:-'dca n: 1 f'!{:;il :J t 'a-:vt ~:i ;~_1~-1'11.V«-~ :;,!i!.:\wtl-;:j ;; _!"! r~\e-:~--! P-~i~.i-:! ~f;!l\ ta ~trl'.1--!i?:: r~~t);j. Fi F').~'.~!? bw-~ r1,1 i;:;l::.i'.~ "~-~~!:tl"g ~- Et8! l't Rft:t 1 NTS ~!r ~1.,_,.;:t1 ~r::.-e VI.:-~ t/'4 1-.:7:"1ili He-?>-u: E>!''~ r.; ~~J.1 :.;c ~J:j ] 1'4,; >D L ' 'u. if L ' o. t j)_q B ] ] 1.0.~ COMfos;fe. EX!fre1r 8 1.';;:,~uu- 1. t!.l '"l:-.:itl "' pc.l;l'

238 SUPERCEDES PRIOR CARD 1 u ~lt'l'i\(, =------,!\J9Atl'[) l)/,n~!. l :;-i.js~ ;lf ""LOA.JD>'! jfl a. Ben.: 37::15 jt\ 1 i::st PA~M BEACH J:L 3'."M.O::.J70E i Md~ f"'~ ~"ll'1i' Ar:i::r:- m -.w.r~ wy by!htl f11-\;re1 01.i:! T1._1>1r $t i!.'!1rl.ll!'.i.,;p.c-~rrc,11 C!frrt1;j i I ' !!~~_GHTS.Ar OEJ\ T~ lw<~1.,,,..,., ;_..,,,,.!, 1 ' 5,,~ili~-P~'i r Ac:.:'>'.1r.~ 5;-1 111ll:i f'~t 1 i\,:-: :JL l"t -~'/i~~\ PiJf ;)<') ;:J\!'3tb Defi!IJ<111tk1r. I!1\~:-i ~ b~,~~k:ior~1 bo::-jw i. - ~(..i111 :1(o-Parw A-t«tilUT'!t ' Vit-'l R.;;:Jl'i1 c-r 5n1=Jt-.ui~tiiu -- ~l~;~hfpl;r-?i1q1 A;:;_~;i;:Jn! V/1;h M1y.11~ ~J; -fi~;r--.;tv_11~til1 Puy,lli'l :mtt;h Dm>~r,rniO'l tr;nrr"!l btmt:-11r:inr;u, br;jl,',~j,\ful\<ol,,.:<11rri,l;<..:;~vit l\'ilnll\h RiQ,f1\ at.sv 11,Yur13!o~ --i:i~;\.r.ffoii".iit::\~~~:f!:~ef~-i::f1cl. i;f1e$-:-----~~--.,_.. 1--AG-COUNfO"iNER1!i! NAt.tt-~' :.;.:o-oii;;~.-s- ~ TI-iE LA\"I O~FlCf!S Of'.!lR rt A ~LAM F>..-?. DP.ERA Tlri{j A-CC()Uf JT ~ 27 tfe 2~~D ;\vt \ DELRA.~ fle '<Cl--t. FL JJ.::"1.t,~-y~~ Of -~ ~~~:K lh V I $A 1./l~~S ia.ccovn'i' I 1 h'.i1 ~ -;',;-.,, ii:!!t>ji_ l'-"''' ir. Pnnr.M1r.n ~H)'.--\1 ~ OFAC velified bybv -... f C CE~llJ!_i-CAiE OF OE?(;)$1T.lOX!Ll:!lr J[;V~01,f'l.f, ----' nn: ~-~ --' J~~ SAC-)CUfl 1'/ITHH-Ol.OING CEFIT\FlCAllONS i.i~1ljl]. \~'. TAJPl!~tfl 1.0. Kl.UBEll. ~r-.e -;-o- ;'.T.l/IS '~!,;;:;;,..,!;\~~ ".i;-u~ P;<;»'B-"' f.~, s 7;. i;u ~~""~ir.w! ' ~ii ~- ~~t-t' ~,; Sot.er.OP WITK,-te~ll~ _I.f.:' '"i; ~;J;;,-'iq '-1 b-~-'-4_ 'f31'f',~':!'i.~~ ~~- j h.i~! ~ t~ ~.rt;h'-!~ l"j!, XF- J.~!I;; :.;.~.:i'.iol(;_ :;.._!f1,~~r,g -~ $ f~j!$ '_f;i:t.l-'i!i_!~ o'~! a<: t~jt'h! -r:; &~~.:;.!!"~!Nitr'-.J- _;;)':',~.;-1 ~v,n-""~"...;f~.~~~ \tcll li-""1 "':-1:n-~ t:zjttl lo t-.::.;;.;! J. l~t>~ "''; : -_- EX at PT RECIPif;ijT.s! ;rr. zc!", -~\..,.,..~ rk IH'~.~o:r!~ ;~~v":1r- S!Y!'~t'* &n>t! ~.:;-it; S!'i~l'i.i.luru:. -. 'J _urjjh ~~ll.!o_s ri _;«!WY n.. $f1111jm!mi :.~ot~l<.-jij ln lt~-l!.tttlffil" I hli j tm ii U.S._ OlrHfl [l"!l\htr ti.$.!>!ts-or! 11S defintd ln tm: ;Ltr1i ).,,.-~I. ll'< "-AM<!. C/f--, I :,. ~., '" -, q>c :;,.;.;c1<'~ '~-.-.~,.,,,,r '~. : 1. 1:1:. ::;-: ~ : L ~GWl'1\J~l ~_-fht Utdi:rs~ffDzriHin tbs b~k)' ii Uttlrd~nUill)ll- nti~t'f'j1$ ;;r<:ridli:i md :id-11dwh~5 rt~i o-1 ii ~Htd~ Of!his firm. lll~lri~hi;jmii.tljt~lm ihl ~it-4rdm l'!wj~!w C-(l Viti!)' Cttdtt ffid fil'l\i."-.l(l'j=tttl tfl)r;r I~ Ml~ J -i:rt'11 t_ff»"lf!j 1,.,-icy pr-tty:rf. -I frt!1. t fjjy.irt i:wi IA'1 mtil!rfl~d,,jj ltilfljlf!.hlt, tbl! U1(11ul;Md ~llo id:rm.clldp!! t!'ji.rt:tf 'ri.1 rnw Md Jg-ff 1a lh1otl!'ll!ll cl' CM ic:uowhg ~fih NM"'l!S'!llW"!i~MuraJi r!_ f!!rrns.& C:or.-0~1iGl'IS '.X Tcr<.tlll In Savin;Jil ~1 r:u-;itt: /~..,;:!i!1tl:ilit"1 1\ Eh!t-\rol1k f.\md Trllt?Jiet!l :~ f?pr.?c..'") X -SuU~~JtuH1 CheC}:ii <It L L L to. ;: ~-. L f~tions ---~ o o a ] J a.a..!. ~ ~ :::-::- o_._c_. _ =-::= -::c:-::-::-::-:: :.::-= ===-= ::. ] ] ] ]

239 - GRAND BANK & TRUST OF FLORIDA P.O. BOX 3705 WEST PALM BEACH,FL OWNERSHIP OF ACCOUNT - CONSUMER PURPOSE iselsct ann and I lnitlnl): D SinglEi-Party Account IZl Multiple-Party Account c Multiple-Party Account - Tetlancy by the Entireties lj Trust-Separate Agreement Dated: D i RIGHTS AT DEATH {Sa!ect one and 1nft1aU: l-j -. Single-Pany Account [] Single-Party Account With Pay-on-Death Designation 1 I (name beneficiaries below) I 1 lll Multiple-Party Account With Right of Survivorship j D Multiple-Party Ac.taunt With Right of Survivorship and : Pay-on-Death Designation (name beneficiaries below) I D Multiple-Party Account Without Right of Survivorship 1~,. "" """''""" ~- _J lo SOL~:~:=,~~:~;PAC~~U;A:~:E~!~SN::~:::::FIT.-1 I [_] CORPORATION: ' - ~-I 0 FOR PROF\T LIM!TED UABILITY COMPANY tl~~~si. osota~t-, d ORGANIZATiON: U~~?RIZAT!ON DA~<~E=D~'-============== HOME TELEPHONE# {561J.?~2-16~4~B, BUS1NE$S PHONE 11 (561)"8~1~9~6~2~5~6, .--",---" EMPLOYER LAW OFFICES OF BRETT ELAM Name and address of someone who will always know your location:,----~~~p WITHHOLDING CERTIFICATl.ONS ' TIN< 427> lZl TAXPAYER 1.D. NUM_B_I;R. T~re Taxpayer ldentifica;ion Numba" shown above {TIN) 1s my i:orred \axpay~!dei1t1ftcat1on numbe:. I!Zl BACKUP WITHHOLDING-\ am not subject lo backup withholc!:ng either be::ause I ~ave not ~ r10tified_ t~at lam Si.lbjoc\. to backup witl'ilold!ng as a result of a failure lo report al! mteres\ or d1~1dellds, or the Internal Reverue S fv1ce has notified me that I am no lon9e< su~ ec1 to backup withholding [] EXEMPT RECIPIENTS J am an exenipl recipiffii under the Internal Rev 0lUe SeHice Regulations. SIGNATURE: l certify under p enelties of perjury the ~tatements checked in this section a that I am a U.S. citizen or her U.S. person {as defined in the lnstructio (l ACCOUNT NUMBER ACCOUNT OWNER{S] NAME & ADDRESS BRETT A ELAM LAUREN ELAM I 2076 CHAGALL CIRCLE 1 WEST PALM BEACH, Fl IBJ NEW PORTFOLIO NUMBE_R TYPE OF ACCOUNT [Zi 0 CHECKING MONEY MARKET 0 SAVINGS CERTIFICATE OF DEPOSIT 0 NOW [] This is your (check one): FREE CHECKING (01) l 0 0 EXISTING IB.l Permanent C Temporary accourit agreement. Number of signatures required for withdrawal ~' FACSIMILE SiGNAT_URE(S) ALLOWED.? 0 YES lzj NO L I I ] SIGNATURE($). The undersigned certifies the accuracy of the information he/she has provided and acknowjeldj:les receipt of a completed copy of this form. The undersigned authorizes the'flnanc!al institution to verify credit and employment history and/or have a credit reporting -agency prepare a credit report on the underslgned, as ind!viduals. The undersigned also acknow.ledge the receipt of acopy and agree to lhe terms of the following agreemenl(s) and/or disclosure{s): D Terms & Conditions lzl Truth \n Savings IBl Funds Availability!Zl Electronic Fund Tra nsfers lz! Privacy IBl Substitute Checks!Zl TERMS AND CONDITIONS \) (11,,L-1,.- s 1.D. ti===="" D.O.B. Oec6~/~0~6~/1~9~7~4~ ] ] (),(~Ix~,~ ~., E EA 131< (41< L LO. II [x ~~f ,f13/ 1~ ] LO. II D.O.B, ] b.0.8. _,, 1.0. II D Convenience Account Agem 1Single PartY Accounts Only! L l.d.i! D.0.B ~ ].Sign?.U rn Card fl MPSC-LAZ-FL 10/112009!lank~. SysternsTM Wcitrrs Kiuwm Fjnancial $orvkcs 1992, 2009

240 EXHIBIT 9

241 Statement of Account Last statement: December 31, 2016 This statement: January 31, 2017 Total clays in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 7. c ~8.28)' Date Description Additions Subtractions Balance Beginning balance #Digital Depos~it--=====:::: 10, , #Interest Paid.08 10, #Interest Transfer , TO ACCOUNT NO 0 ~61~-~ ~~~~ Ending totals -- 10, OB $10, COMfOSife_ Xllil6/'r 1

242 Statement of Account Last statement: January 31, 2017 This statement: February 28, 2017 Total <lays in statement period: 28 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page I of 1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 1 Enclosure Date Description Additions Subtraction~s Balance Beginning balanc,e $10, Check 1277 ~ =5~, ~-5~,~oo~o~.o~o~-- 02="28 #Interest Paid , ~5~, #Interest Transfer -o.15 TO ACCOUNT NO Ending totals.15-5, $5, Number Date Amount Number Date Amount =5~,0=0= ~---- 0~2= ~2~7-

243 4 ~ "' SeacoastBank Seacoast National Bank THE LAW OFFICES OF Account: 1 i:,.., " ''"" Orw02/N;1' """' "

244 Statement of Account Last statement: February 28, 2017 This statement: March 31, 2017 Total clays in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Pagelof2 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 7 1 Enclosure Date _J?._escriptio11 -~A~d=d'="tio~n~s Subtractions Balance Beginning balanc.e.,,,.;;-; #Digital Deposit ~,~08.28 $5,008.28) #Internet Tran-s~f~er -2, , REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER Check , (34,408.28) #Internet Transfer ---(~ 4,ooo.oo) 30, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER #Internet Tr.ansfer Goo.oo) 30, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER #Internet Transfer ( , REF L FUNDS TRANSFER TO DEP FROM #Internet Transfer REF L FUNDS TRANSFER TO DEP , FROM #Digi\a~I=D_e_p-os~i-t- #1 nternet T ransfer 1, REF L FUNDS TRANSFER TO DEP FROM FEE FOR CASANAS #Interest Paid ==~ ,458.34

245 March 31, 2017 Page 2 of2 THE LAW OFFICES OF Date Description Additions Subtractions Balance #I nterest.t~ra_n_s~fe-, , ~~~~T~O~A_C~COUNT NO Ending totals 35, , $30, Number Date Amount Number Date Amount ~ 2,500.00

246 ~ THE LAW OFFICES OF,4 SeacoastBank Account: Ji> Seacoast National Bank ~ y

247 Statement of Account Last statement: March 31, 2017 This statement: April 30, 2017 Total days in statement period: 30 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account ntunber ~D =' ~ D_ s-cr=iptio=n A~d=<i=iti=on=s ----~Subtractions Balance Beginning balance. $30, #Internet Transfer ('.'3~000.0]) 27, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER ~o-4--0~7~#=1nternet Transfer (".1,457.8:2) 26, REF L FUNDS TRANSFER TO DEP o _#_1-:t:~~e~~~~l~s~:~ns=f~er~--- uc,ooo.o'.:) 25, REF P FUNDS TRANSFER TO DEP ~F~ROM MOBILE TRANSFER #Internet Transfer ~---- UG? ). 24, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER 04--~2~5-#=D~i-g-ita~l -Deposit , , #Internet Transfer 24, REF L FUNDS TRANSFER TO DEP ~FR=OM MOBILE TRANSFE=R~ #Internet Transfer (i'.o48.9d 23, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER 04:25 #Internet Transfer -22, REF L FUNDS TRANSFER TO DEP FROM MOBILE ) u 04=30 #1 nterest Paid.42 22, #Interest Transfer , TO ACCOUNT NO Ending totals ,

248 Statement of Account Last statement: April 30, 2017 This statement: May 31, 2017 Total clays in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1 of2 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 2 Enclosures Date Description Additions Beginning balance #Digital Deposit 5,168.00~ #lnternett~r~a~ns~f~e-r-- REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER 0~5~-0~8~...-.#~D""i~gFit"'al,cD""eposit 3, #Internet Transfer REF L FUNDS TRANSFER TO DEP FROM #Internet Transfer REF L FUNDS TRANSFER TO DEP ~~=~FR~O~M~M=OBILE TRANSFER #Deposit 29,987.5f #Internet Transfer 34, REF L FUNDS TRANSFER FRMDEP _FROM #Digital Deposit 1, ~3~5~ ~ ~11 #Digital Deposi~t--======--_ 1, ~--...,,_ 36,836.TI #internet Transfer REF L FUNDS TRANSFER TO DEP ~FROM #I ntern~e~t~t~ra-n-sf~e_r REF L FUNDS TRANSFER TO DEP FROM Subtractions ---~B =l,ance )-0~,.. ---~~~~:~~;: 29,187.5] 26, (-1,260.0~) 24, C?O:OV 30, ~ 28,636.12

249 May 31, 2017 Page 2 of 2 THE LAW OFFICES OF Date Description Additions Subtractions Balance #fnt_e_rn~e-t~t=r_a_n_s~fer- [4,100.00_) 24, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER Debit Memo -1, , :13 #Internet Transfer 11,53(fl2 REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER #Internet Transfer (-2,500.oo:) 9, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER =o=5-~2~3~~check ~2~,0~55~.9~6~ , #Interest -~P~ai~d~ , ~T-#lnterest Transfer ,98016 TO ACCOUNT NO 0 ~~=~ ~~ Ending totals 20, , $6; Number Date Amount Number Date Amount T27= ~~~ ----~2,055.96

250 4 SeacoastBank Account: 1 ~ THE LAW OFFICES OF ~ Seacoast National Bank 2-fl,,-.JJ r;. &d~ A- k... B. 1.: fr~5j.f1anu.f 15oow 05/16/20l7 $1, "'"'"'"''"~' ""''"' "'"'" '"' "'' m,.,...,,,.,-"-"'" M~l'O m1"cf

251 Statement of Account Last statement: May 31, 2017 This statement: June 30, 2017 Total days in statement period: 30 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 1 Enclosure Date Description Additions Subtractions Balance Beginin"'in=g~ba~l-an_c_e_ $6, #Deposit (4~6=8=.=5=5~-- 8, #Internet Transfor ---- (1,500.B) 6, REF L FUNDS TRANSFER TO DEP FROM #Internet Transfer 5, REF L FUNDS TRANSFER TO DEP FROM ~~~~' #Internet Transfer ( '.:J. 5, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER ~0~6~-2~6~#~1~n~te~rnet Transfer 5,093. f5 REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER Check , , ~0=5-~3=o~#~ln-terest Paid.10 3, ~~~ #Interest Transfer , TO ACCOUNT NO Ending i:otals 1,46!3:65-5, $3, Nu1nher Date Amount Number Date Amount -- illocc ~0~6~-=2= ~,~.9=5~

252 4 ~ SeacoastBank Ji, Seacoast Natrona! Bank THE LAW OFFICES OF Account: 06/27/ $1,956,46

253 Statement of Account Last statement: June 30, 2017 This statement: July 31, 2017 Total days in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number C O?J Date Description Additions Subtractions Balance 05:30 Beginning balance $3, #Internet Transfer 3, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER #Interest Paid.05 3, #Interest Transfer , TO ACCOUNT NO Ending totals.05 : $3,036.69

254 Statement of Account Last statement: July 31, 2017 This statement: August 31, 2017 Total days in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 1 Enclosure Date Description ~Additions ----~Subtractions ---~B=a/ance Beginning balance $3, ~02 #Digital Deposit 4, ,006:69 ~0~8~-0~2-#~D~i~g~ital Dep~os=ci~t -1, ~f, #Digital Deposit 1,46=8~.5~4 10,973: #D-igital Deposit 1,000.0CJ ~1~1, #Internet Transfer C1,ooo.08J' 10, REF L FUNDS TRANSFER TO DEP FROM MOBILE TRANSFER Os~=o=3~#~ln-te_r_n-et Transfer REF L FUNDS TRANSFER TO DEP O:r 8, FROM MOBILE TRANSFER Check , ~2,017: #lnterest~p=a~id~ ;017.88,,,_,_ #Interest Transfer ,011:83 TO ACCOUNT NO Ending totals ---8~, , $2, Number Date A~1nount Nu111her Date Atnount ,556-:94

255 ,4 SeacoastBank Account: 1 Seacoast Nat!onal Bank ~ THE LAW OFFICES OF

256 Statement of Account Last statement: August 31, 2017 This statement: September 30, 2017 Total days in statement period: 30 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of1 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number =Da~t ~~D~e~.cription Addition_s Subtractions Balance Beginning bala_n_c~e,,...-:-.=-:-:;~..._ $2, #Defl.o~s=it~--- CL498._@J ~3~, #Interest Paid ~~~~~~-- 3, #Interest Transfer ~3~, TO ACCOUNT NO =09~_~3=0-E~n-cling totals 1, $3,516.38

257 Statement of Account Last statement: September 30, 2017 This statement: October 31, 2017 Total clays in statement period: 31 THE LAW OFFICES OF BRETT A ELAM P.A. IOTA TRUST ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page I of I Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account nu1nber 1 Enclosure Additions Subtractions --~~Balance ~D ='~"-~D~ ~ c~rip.t=fo=n-~ Beginning balance r"'.~ $3, =~~=~ #Digital Deposit,,(1A68.54) ---~~ ~---- 4,984fil Check , , ~10~-~3~1~#~1n~t~er=est~P=a=id~ ,908: W31 #Interest Transfer , TO ACCOUNT NO 1 ~0~-=3~1-=E-nd~i~n-g totals ----,~, , $2,907:95 Number Date Amount Number Date Amount ,

258 4 ~ SeacoastBank Account: 1 Seacoast National Bank THE LAW OFFICES OF 10/31/20" $2, _-- _-_-,!

259 4 SeacoastBank Seacoast National Bank Page: 1 SU.COAST NATIONAL 11"11K,,,, llle,,f1"'11/n - r- e,utt g1un ~ :~:.:... z~7..:=-:;:-:.':'::::~... 1 Ch<cking Account Deposit CREDIT * ; o i o 7b Y 7 -~" $ o 1 I 'ill /16/2017- $1, CASHIN P"'-"\BEACHL.AKES TEll.ERNUMGEn 862 TIM2 a3-bf1 Clfilf!l C2,~6 PM OOH IN!nl07SH 8:'1 862 ''. s_z so~ s1: 05 /11/2_0_1_ $5.ooo.no $5, ~~ i ~i~! ~ M" 0 )0 ~ " "! " - "" <l :l ~ ~ia~p'!!. '' IW,~"'l ~J "l1'!~'.~i CHANDRA PARKER DOUCllTill!OTA TRU5T...CCOVNT liunw.5.llw5f.~t1'ul llocaaaton,fl :uw.mj ti)ln D to >-11,..1n m I - SMCCAST tfational DANK Checklng Acrnunt Deposit CREDIT I b!,_./z.-dl- E!Z_..,,,, 0.,. '1/rr/11 * - l!~;s""'"'...,.,_,..,,.,._,,,..,! "'""'"~K""'""'""'"...,.,... H,..._ o...:: AC'O'.l<..'<T ~><>Ell I 7(ol.j'] ~ I ~ f I.rr - ' 06/16/ $1, ]>... i '... $ 1~91.sr 01 ' 09/15/2017 $1, ~!.. K.. KKK ~ '"t~'1:... 'Q ~ 81i _,_ ~~~ {.,... ' '.,. ffi 'I 1' " rn lr>f!b B3-B01 0~ O< SS P" l!,. "! i,. il ~-. j SEACOAST NATIONAL llank '" ] 1 2 Checking A«OUnl Deposit Clt 01'f I'"",,,LJ. CT~"' i ::':~...,..~:~:.!:'.:;;~.'~".'~-"'... 05/11/ }DJD/IR_l/'1 ~ 0.::::: $.5 0 C:Jt).:70 $5, CHANDRA PARKER oouarrrn IOTh TRUST A<XOUN'f lil! N.W.5JRDST.Slll :U0 ~0\'.AMTON,ll. 3:H87-Wl 'i'lf 17, ' "'"...,,,.,~ b';~::~~o ~(-/) /1. E/.4et_ - J $ iyf(s.f,,,,,,j/,,,~,,,;,f.y'/tfj;; _... ~ ""' BankofAmerlca~.,,,.,_, a. ~ 2036 For.&',pzrd d,,4/lif fl. 1:ar ao~r. ~ ~ 09/15/ $1, ' \~ ~ I 0 (ic!) '.>

260 ~~~~~~~- ~~~~~~~ 4 SeacoastBank Page: 2 Seacoa5t Natlonal Bank Mobile Deposit Checking-7647 '7647 Deposit amount: !,i'OOO l.ooooooi" 01/17/2017 $10, /02/ $34,400: ('..?O 11,a 2 C ll <'" j..lob l'-lcib ~ 2 'i l~l'~ " ~IW.''.fOii.'1 W-'4 [ ~: DEPOSIT TICKET BACK... '. " "~"._-,, "A"'-""''"'"'"'""''-''"'"'"'"""' ""'"'"" p..'"......,..,, ' "'""'"'' '""~'"''"'"""""'"'"'"'''".''--:'~"'! "].. Mobile Deposit Checking-7647 '7647 Deposit amount: /17/ $10, /28/2017 $:1', DEPOSIT TICKET BACK Mobile Deposit Checking-7647 '7647 Deposit amount: /02/2017 $34, /28/ $1, DEPOSIT TICKET BACK

261 4 SeacoastBank Page: 3 Seacoast National Bank Mobile Deposit Checking-7647 '7647 Deposit amount: /25/2017 $1, DEPOSIT TICKET BACK 05/03/2017" $5, '' ; ~.-':!f;'' /. 1 '., t '. j./j ; ' ~ '/ ~ _..f '.,,;,;.. «" Mobile Deposit Checking Deposit amount: ' 1 04/25/ $1, /08/2017 $3, DEPOSIT TICKET BACK Mobile Deposit Checking-7647 '7647 Deposit amount: /03/2017 $5, DEPOSIT TICKET BACK 05/o.ll/ $3,50o.oo f-}: ' c1 I!:~ ~J ff f~ ] ' " H' ;;;:! ~~j l'-' l r ~~ l~ ;i' ' i ~ b JO... ~~.-.,! '~ U-..:~ lf ~:i.' i f, j.,' " ' '

262 4 SeacoastBank Seacoast National Bank Page: 4 Mobile Deposit Checking-7647 '7647 Deposit amount: ~JJ::~ C? '"' '''"" l'hll' f[,,,,,,.-r 1 QOf.O!l~r $/~U1 t $1'00-- l _()_= '" -"'d'ii' ~n~_' l 05/11/2017 $1, DEPOSIT TICKET BACK 05/11/ $1, ~... ;. :-, r '! ~ r.! CHANDRA PARKER OOLICEITE 2020 tota nu.-r"'=vm ~\::..~,~~.&'.IL.s/.f bz r ""'" Mobile Deposit Checking-7647 '7647 Deposit amount: :, ' 05/11/ $1, j ~ -,,,,.. :.,,. ;n ",._ ~ ( : 08/02/2017 $1, DEPOSIT TICKET BACK Mobile Deposit Checking-7647 '7647 Deposit amount: : 20000/ 05/11/2017 $1, DEPOSIT TICKET BACK 08/02/ $1, , i ~i.. ; \ ~ i :-~ l j' ' - -~. 1i d. '-~ '\.\.,,, _'_' \=];@ '

263 4 SeacoastBank Seacoast National Bank Page: 5 Mobile Deposit CHANDRA PARKER DOUCETTE 2027 IOTA TJ.UST Ac.'C'OUl«621 N.W. SW>ST. STE 1-16 ~oc.t>ratos,11..l.jw-&?111 Checking-7647 '7647 Deposit amount: /02/2017 $1, DEPOSIT TICKET BACK CHANDRA PARKl!R DOUCl!TIE. IOTA TllUST ACCOUNT QI N.W. 5JRD ST. m1rn lloca UTON,fL.llW-1\.."11 Mobile Deposit Checking-7647 '7647 Deposit amount: /02/2017 $4, DEPOSIT TICKET BACK Mobile Deposit Checking-7647 '7647 Deposit amount; 1468,54 08/02/2017 $1, DEPOSIT TICKET BACK

264 4 SeacoastBank Page: 6 Seacoast National 8a!1lt Mobile Deposit Checking-7647 '7647 Deposit amount: /13/2017 $1, DEPOSIT TICKET BACK l0/13/ $1, !,,, ', -! ~,, "!: r ~ ',.

265 4 SeacoastBank Page: 1 Seacoast National Bank 02/27/ $5, /27/ $1, S~q: 46 Ba1d1: -575&97 Dat~: 02/2~/17 > n4< 111,111<0 1v11111 B'1IlkUn.ited 106~ ~C~H!jrCt: I lllti '"" Batch 1107G2as oc:<> t "'" < too o;; l'd-;1; /08/ $6, ~ /31/ $2, ~

266 4 SeacoastBank Page: 1 Seacoast National Bank 4 Se~~ ~~J;~!i1~~ DATE May 16, 2017 P.O. BOX 91ll2 SU COLORADO AVE,, STUART, FL SfU& &l'll2 No P~1~~ uunrinker BIDDLE & REATH, LLP+ H ONE THOUSAND FIVE HUNDRED DOLLARS AND ZERO CENTS Reminer: Bretl A Elam faq CASHIER'S CHECK COPY NOT NEGOTIABLE AUTllOBIZED SIGNAliiiE 05/16/ $1, oo CIOS'!$ -'IJ J<JJ451'J l~9w!61 u J L(:61) lj/91.fso tls-~8 oi dl Sea oa t BanJL Advice of Debit Memo W <iurv 1""'"'0<Wtlt s fol!o"' ~scrip1ion ~, D~te: S - /(o-/j * i(j/61/_,'-fl Aoco~1"1um\><r r:;, L &e..\\- Afie.,., B'J.. /r~sl- i'rc,;o~ f $ 1500 {X) 05/16/2017 $1, <lll':l1jdll(j Uf'lllXON J;:iwoi.~nJ ~ Cl "IJ<14J OO'OOS'l$ l\\!j sn uo l~9lol01 ~\,! L'.!00 Ll19VSD tl0 PEl 6! 1 111

267 EXHIBIT 10

268 Statement of Account Last statement: September 30, 2017 This statement: October 31, 2017 Total days in statement period: 31 THE LAW OFFICES OF BRETT A ELAM PA OPERATING ACCOUNT 105 S NARCISSUS SUITE 802 WEST PALM BEACH FL Page 1of20 Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number 0 14 Enclosures Date Description_~~--- Additions Subtractions Balance Beginning balance --~$6=, O-b~2~#~A~2~A=P=m~t'-c=r=e=d~it= TERMINAL snc 10 3ZNR95MS 6, SAN FRANC CA :51 PM ~1o=-~o~2~#~A2A Pmt Credit , TERMINAL snc 10 3ZRE5YBF SAN FRANC CA :51 AM #A2A Pmt Credit , TERMINAL SQC*ID 3ZPHCPE2 S~A~N FRANC CA :57 PM Tb-02 #A2A-Pmt Credit , TERMINAL SQC-ID 3ZAT2SGH SAN FRANC CA :30 PM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card-Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~c"--g co help CA _3~0~-1~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex --~g~co~help CA ~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA EXflt/3(/ {O

269 October 31, 2017 Page 2 of 20 THE LAW OFFICES OF Date Descriptio11 Additions #Check Card Purchase------~ ---- MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase ---- Subtractions -99.9~9 Balance 7, , , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~--=g co help CA 4802_ :1_ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~---~g co help CA #Check Card Purchase - :99.99 MERCHANT PURCHASE TERMINAL GOOGLE Elex g co_ help CA ~0~-0~2-~#=c"'h-eck Card Purcha-se , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA l 0-02 #ATM Withdrawal , CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL ,00 AM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g_co help CA ~1~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~--=g co help CA 4802_ _ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~--~""co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #POS Purchase , POS PURCHASE TERMINAL NST BEST BUY # WEST PALM FL ~,0~8~P~M~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE SVCSAPPS_f arbe cc@google CA _ #Check Card Purchase , MERCHANT PURCHASE TERMINAL VENDOSTORE LEADCON xx #Check Card Purchase -~ , MERCHANT PURCHASE TERMINAL STAMPS COM EL SEGUND CA ~10~-=0=2~#=c~h-ec~k Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA

270 October 31, 2017 Page 3 of 20 THE LAW OFFICES OF Date Description Additions Subtractions Balance #Po=s~P~u-rc~h~a_s_e ~--- 6, POS PURCHASE TERMINAL TARGET T-2427 WEST PALM FL :30_~P~M~_ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Scopely In cg co help CA #Check Card Purchase - -f3.58 6, MERCHANT PURCHASE TERMINAL CLEMATIS STREET NE WS STA WEST PALM FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~-0~1~-1~7~ #Check Card Purchase 6, MERCHANT PURCHASE TERMINAL GOOGLE Elex ~=~~gc-c~o-i-help CA ~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA To--=0=2~#~P=o s~p~urchase , Pos PURCHASE TERMINAL NST BEST BUY # WEST PALM FL :41 PM 10~-=0=2-#=c=h_e_c~k~Card Purchase , MERCHANT PURCHASE TERMINAL CLEMATIS STREET NE WS STAWEST PALM FL #Check Card Purchase - ~ , MERCHANT PURCHASE TERMINAL FLAMINGO PARK FOOD MARKEWEST PALM FL ~ #Check Card PU-rchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~ g co help CA #POS Purchase , POS PURCHASE TERMINAL DOLLAR TREE ~~~=W~E~ST~.PALM FL :29 PM #EFT S/C , SVC CHG INTRNTL_T~R~A~N~ #A2A Pmt Credit- 2, , TERMINAL SOC*ID 3ZJNCQS8 --~S~A~N~F_RANC CA :54 AM #A2A Pmt Credit , TERMINAL soc -io 3Z4RM7KC SAN FRANC CA :28 AM Check ,600.00~-- 6, #Preauthorized Wd , COMCAST COMCAST #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA (j)

271 October 31, 2017 Page 4 of 20 THE LAW OFFICES OF Date Description Additions Subtractions #Check~C~a-r~d~P~u-rc~h-ase MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~~ g co help CA 480_ Oc0_2~-1~7 Balance 6, , #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell ---~g co help CA ~1~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~=~g co help CA ,_1_ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA ~1~0--0~3~~#=P~re-authorized Wd , PAYPAL INST XFER #Check Card PUrchase ,870-:17 MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL ~1~0--0-3~-#~C-h~e~ck Card Purchase , MERCHANT PURCHASE TERMINAL CLEMATIS STREET NE WS STAWEST PALM FL ~-0-4~#-A_2_A~Pmt Credit , TERMINAL SQC*ID 3ZKSBC2E SAN FRANC CA :51 PM #Deposit ReturnItem , ~3~,4~ #Service Charge , DEPOSIT RETURN ITE #Check Card Purchase , MERCHANT PURCHASE TERMINAL WEST PALM BEACH PA RKING FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL PP ROBLOX CORP CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~=g co help CA 4802_ _1_ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~g,_c~o~h~e=lp CA _ #Check Card Purchase , MERCHANT PURCHASE TERMINAL SVK Hooked On Phon ics CT #Check Card Puichase , MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA ~1~0--0~4~-#=Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA

272 October 31, Page 5 of 20 THE LAW OFFICES OF Date Descript/011 Additions Subtractions Balance #Che~c-c-kccc"'a-r'd'P~u-r-c'h-a-se , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #ATM Withdrawal , CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :38 PM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase --~~ , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~1~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL DAD WA llf'os Pch Cash Back , POS PCH CSH BACK TERMINAL 13981T41 WALGREENS STORE WEST PALM FL :08 AM 1=0~-~0=5~u=c=h_e_c'ok-Card Purchase , MERCHANT PURCHASE TERMINAL PARK BY APP -~~-~FcC-O~R~T~LAUD FL #A2A Prrit Credit 1,251:36 TERMINAL SQC*ID 3ZRSV1 CH SAN FRANC CA :10 AM 1~0~-0=6~#~Ac'02~A~P=-rrit Credit 1, 2 51 : 3 6 TERMINAL SQC*ID 3ZF9G8MG SAN FRANC CA :43 AM 3, , #Deposit , Check , , #POS Purccoh=a=s-e ---~--~81~. 4~ ~4, POS PURCHASE TERMINAL 13981T42 WALGREENS STORE WEST PALM FL :51 PM T6'-0=5~~u=c h-e-ck~c--ard Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA , ~06 #Check Card Purchase MERCHANT PURCHASE TERMINAL DOWNTOWNVAPES FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell ~=~=g~c_o help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card PurcI1ase , MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL DAD WA ~-'1'o~u=D=i-g~ita'1 Deposit 2,900.o~o~--- 6, To-1 o #Digital Deposit 1,800:00 8,615.56

273 October 31, Page 6 of 20 THE LAW OFFICES OF _D~al_ ~~~D~es~c~rip~.ti_on ~_ Additions Subtractions #Digital Deposit. 1, check , ~1~0--~10~~#=P-re-a~u-tho-r~iz-e~d~W~d AMEX EPAYMENT ACH PMT ~1~0--~1o~~#=P-reauthorized Wd oo CHASE CREDIT CRD AUTOPAY ~1=0--1~o~~u=c~heck Card Purchase MERCHANT PURCHASE TERMINAL HP INSTANT INK CA ~1~0--1~0~~#=P-reauthorized Wd -121:05 CITI AUTOPAY PAYMENT O Check i2o.oo -102.s ~ #ATM Withdrawal CASH WITHDRAWAL TERMINAL LK SOUTHERN BLVD ----~W~E~ST PALM FL :54 AM #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card-Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card"Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g co help CA ~-~09~-~1~ o #Check card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~=,,_g_co help CA _0_-0_8_-_ O #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~-='g~co help CA ~-0~8_-1_ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ---~g_co~help CA _~9-~1~ #Check- Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex =~~=g co help CA _ O #Check Card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE MENT WEST PALM FL :08 AM 1~0--~1O~#~C~heck Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA O #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card- Purchase MERCHANT PURCHASE TERMINAL STAMPS COM EL SEGUND CA Balance. 9, , , , , , , , , , , , , , , , , , , ,479.86

274 October 31, 2017 Page 7 of 20 THE LAW OFFlCES OF Date Description Additions Subtractions #Check Card Purchase MERCHANT PURCHASE TERMINAL FLANIGAN S 11 WEST PALM FL #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA _0: #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA 48_ : =10 #Check Card Purchase MERCHANT PURCHASE TERMINAL CCBill com XFC I nc AZ #Check card Purchase MERCHANT PURCHASE TERMINAL PSM HELP COM FL #Check Card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE MENT WEST PALM FL :30 PM #Che"c:k Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA #Check Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA #Check Card Purchase MERCHANT PURCHASE TERMINAL HLU Hulu U HULU COM CA #Check Ca-rd Purchase MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL #Check Card Purchase MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL #Check Card -Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Kajo Andro Dev g co help CA #Check-Card Purchase MERCHANT PURCHASE TERMINAL PSM HELP COM FL Ti:J-1 o #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Luke Klink er CA #A2A Pmt Credit TERMINAL SQC'"ID 3Z3J9V45 SAN FRANC CA :19 AM Check , Check Balance 5, , , , , , , , , , , , , ,299. fl 5, , , , ,872.20

275 October 31, Page 8 of20 THE LAW OFFICES OF Date Description Additions Subtractions Balance #A TM Withdrawal , CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :25 AM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA To:11 #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA T #Check Card P-urchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA () #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Preauthorized Wd , STARMOUNT LIFE I CASH TRANS #Check Card Purch-ase , MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 8 28 SOUWEST PALM FL :41 PM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check -Card Purchase , MERCHANT PURCHASE TERMINAL EB MEMBERS ONLY WE STG CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase : MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card.Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Pu-rchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA () #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL DAD WA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA ~

276 October 31, Page 9 of20 THE LAW OFFICES OF Date Description Additions Subtractions Balance #Check Card Purchase MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL _ #Fed-Dom Wire-IN 10, , WIRE FROM STB ATLANTA GA PREMIER FLORIDA TITLE LLC #Service Charge , FED-DOM WIRE-IN #Digital Deposit 1, , #A2A Pmt Credit 1, ; TERMINAL SQC'ID 3ZQEGK5C SAN FRANC CA :44 AM Check 3530 : , :13 #A TM Withdrawal , CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :46 AM #POS Purchase , POS PURCHASE TERMINAL 13981T41 WALGREENS STORE WEST PALM FL :58 PM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex _g co help CA 480_ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA #ATM Withdrawal , CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :50 AM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GREASEBURGERBAR WEST PALM FL #Chec-k Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Piirchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #CheC-k Card Purchase , MERCHANT PURCHASE TERMINAL BUFFALO WILD WINGS 0493 WEST PALM FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL ABC ULTIMA FITNESS FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA

277 October 31, 2017 Page 10 of 20 THE LAW OFFICES OF Dato Description Additions Subtractions f0-16 #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~-~~ g cohelp CA _4:_1_Z #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g~c~o. help CA ~5~-1~ #Check Card Purchase MERCHANT PURCHASE TERMINAL CIN LEGAL DATA SER VICES OH ~1=0--1~6~#=c=h~e-ck Card Purchase MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA ~1~0--1~6~~#=c~h-e~cc-k Card Purchase ~ MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~~g_c~o~h~elp CA ~7~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Pu.rchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 5 00 BELWEST PALM FL :06 PM #Check Card Purchase MERCHANT PURCHASE TERMINAL TACO BELL WEST PALM FL _#_C~h-e~c-k Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL ---~O~A=D WA #Check Card Purchase MERCHANT PURCHASE TERMINAL PlaystationNetwork CA To~-~1=5-#=c~h_e_c~k Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~"'g_c_o~help CA _-1_ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA ~1=o-~1~6~#=c~heck Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA =0--1~6~~#=c"'h-eck Card Purchase MERCHANT PURCHASE TERMINAL THE HOME DEPOT #63 20 W PALM BE FL :02 PM TO-T6 #Check Card Purchase - ~ MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA #Check Card Purchase MERCHANT PURCHASE TERMINAL MCDONALD S F7129 WEST PALM FL Balance --~1~2~, , , j 2, , , , , , , , , , , , , , ,753.72

278 October 31, 2017 Page 11 of 20 THE LAW OFFICES OF Date Descriptio11 Additions Subtractions #Chec~k~C-ar-d~P~u_r_c~h-as_e_ MERCHANT PURCHASE TERMINAL WENDYS 2568 WEST PALM FL #Check Card-Purch-aS_e MERCHANT PURCHASE TERMINAL CITY OF LAKE WORTH WWW parkm FL 480,, #Check Card Purchase MERCHANT PURCHASE TERMINAL SO PHIPPS PARK BA S WEST PALM FL #Check Card Purchase MERCHANT PURCHASE TERMINAL FLAMINGO PARK FOOD MARKEWEST PALM FL ~1=o--1~6~#~Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~~9. co help CA ~3-_1_ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA TCJ-16 #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Preauthorlzed Wd CHASE CREDIT CRD AUTOPAY #Preauthorized Wd WASHINGTON NAT PREM DEBIT #Check Card Purchase -~~ MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Preauthorized Wd UNITED AMERICAN INS. PREM 1710~17~ #Preauthorized Wd WASHINGTON NAT PREM DEBIT #Check Card-Purchase MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL #Check Card Purchase MERCHANT PURCHASE TERMINAL CLEMATIS STREET NE WS STAWEST PALM FL #Check Card Purc-hase MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay ~~=e~r~e~p_g_co.. help CA ~1~7-~1~7~ #A2A Pmt Credit - 1, TERMINAL soc -io 3Z686YPA SAN FRANC CA :16 AM #A2A Pmt Debit TERMINAL V FPL: SPEEDPAY PAYM ENT JUNO BEAC FL :29 PM #Preauthorized wa CHASE CREDIT CRD AUTOPAY #POS Purchase POS PURCHASE TERMINAL 13981T41 WALGREENS STORE WEST PALM FL :28 AM Balance 11, , , , , , , , , , , , , , , , , , , ,090.93

279 October 31, 2017 Page 12 of20 THE LAW OFFICES OF Date Description Additions Subtractions Balance #Check Car.~d_P_u_r_ch_a_s_e , MERCHANT PURCHASE TERMINAL GOOGLE Elex _g co help CA Oc1-Z:: #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~1~0~-~18~~#~C~h-e-ck Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~1~0~-~18~~#~C~h-e~ck Card Purchase , MERCHANT PURCHASE TERMINAL PSM HELP COM ~~~~-c-8~66~4~50400 FL ~1~7-~1~ #Check Card Purchase 10, MERCHANT PURCHASE TERMINAL PARK BY APP ~~='ofoc-crc'-t~la~.uo FL ~1~7-~1~7 T0-19 #A2A Pmt Credit , TERMINAL SQC'ID 3ZTAEYOE SAN FRANC CA :40 AM iipreauthorized Wd , CHASE CREDIT CRD AUTOPAYBLP #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA :j 9 #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay erep g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay erep g co help CA ~1=o~-1~9~#=ctieck Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay ~~~=~erep g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay ~~~~ R~ep g co help CA #Check Card Purchase 11, MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL ---~O~A~D~ WA #Check card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay erep g co help_ca _ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay ~~~~er-oe~pg co help CA #POS Pch Cash Back , POS PCH CSH BACK TERMINAL 13981T42 WALGREENS STORE WEST PALM FL :30 PM #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay erep g co help CA

280 October 31, 2017 Page 13 of20 THE LAW OFFICES OF Date Description Additions #Check Card Purchase MERCHANT PURCHASE TERMINAL AMAZON DIGITAL SVC S AMZN WA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay erep g co help CA _17~---- SON PWest Palm FL ~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA _ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell -~~~~g_co help CA ~1~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE GooglePlay ----~er~e,p g co help CA #Chec-k Card Purchase , MERCHANT PURCHASE TERMINAL CLEMATIS STREET NE WS STA WEST PALM FL =1=0~-2~0-u=c~h-eck Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #A2A Pmt Credit , TERMINAL sac 1D 3ZZD1 xsx SAN FRANC CA ,28 PM Check , #POS Purchase , i POS PURCHASE TERMINAL SY8 DICK'S CLOTHIN G430 WEST PALM FL ,05 PM #POS Purchase 8~ POS PURCHASE TERMINAL NNT RIVER RANCH MA R082 RIVER RAN FL ,59 PM 10-=2=3-=c~he~c~k~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell ---~ c_o help CA ~21~-~1~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase - MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check CarclPurchase - MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA :99.99 Balance ---1~1~,~a 3e , #Deposit - 2, , :20 Check ~ , , ~1o~-~2=0-=c~he-ck :1, , :20 #Check Card Purchase , MERCHANT PURCHASE TERMINAL SQ ROBINS ERICK -8, , , , , , ,381.83

281 October 31, 2017 Page 14 of 20 THE LAW OFFICES OF Date Description ~-~- Additions Subtractions Balance #ATM Withdrawal CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :59 AM~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~~"'g _co help CA _0-_2_1-_1_ ~,~ , #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~1~0~-2~3~~u=c"'h-eck Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~~~g_c~o help CA ~17~ #Check Card Purchase -- MERCHANT PURCHASE TERMINAL GOOGLE Supercell ~~~=~g~cc-o~help CA ~ #POS Purchase POS PURCHASE TERMINAL SUNSHINE# 12 OKEECHOBE FL :33 AM 1O-i3 #Check Card Purchase MERCHANT PURCHASE TERMINAL WG RIVER RANCH SHG SALOOLAKE WALE FL #Check Card Purchase MERCHANT PURCHASE TERMINAL WG RIVER RANCH GEN ERAL RIVER RAN FL i3 #Check Card Purchase MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR ----~K CA #Check Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL DAD WA ~1=o-~2~3~u=c~h-eck Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Square Eni x g co help CA ~1=0--2~3~~u=c~h~ecl< Card Purchase --~---- MERCHANT PURCHASE TERMINAL GOOGLE Supercell ---~g~c~o~help CA ~ #Check card Purchase MERCHANT PURCHASE TERMINAL WG RIVER RANCH RET AIL RIVER RAN FL #POS Purchase POS PURCHASE TERMINAL SUNSHINE # 12 OKEECHOBE FL :40 AM ~1=o~-2~3~~#~Check Card Purchase --- MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL ~0~-2~3~#~C~heck Card Purchase =~--- MERCHANT PURCHASE TERMINAL GOOGLE Supercell ~~='1-g~co~he~lp CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE TerminalEI even g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA , , , , , , , , , , , , , ,870.46

282 October 31, Page 15 of 20 THE LAW OFFICES OF Date Description Additions Subtractions Balance #Check Card P-urchase 6, MERCHANT PURCHASE TERMINAL PALM BEACH PUBLIC FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~7~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Ca-rd Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA =~~ #A2A Pmt Credit , TERMINAL SQC'ID 3ZG6BTVA SAN FRANC CA :59 AM Check , , #Check Ca-r~d~P~u-rc~h~a_s_e ~o~o~-- 4, MERCHANT PURCHASE TERMINAL EVER YOUNG ANTI A GING 2BOCA RATO FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~7~--- Check o:c6-c-5'c.o~o 4,, #Check Card Pu-rchase MERCHANT PURCHASE TERMINAL STAMPS COM CA , ~0--2=5~~u=c~h-ei:k card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ~-~g~c~o help CA =24~-~1=7 T0-25 #Check Card Purchase , MERCHANT PURCHASE TERMINAL ONE PARKING CCWPB --~l=n=c PWEST PALM FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL ~2~5~#~C~h~e-c~k Card Purchase , MERCHANT PURCHASE TERMINAL WPB CELL PARKING FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL DEFAULT MITIGATION KY ~ #POS Pch Cash Back 4, POS PCH CSH BACK TERMINAL 13981T42 WALGREENS STORE ---~W~EST PALM FL :22~PM~ #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA

283 October 31, Page 16 of 20 THE LAW OFFICES OF Date Description Additions Subtractions #Check C~a-rd_P_u-rc-h-ase --~ :59_99 MERCHANT PURCHASE TERMINAL GOOGLE Elex --- g co help CA _ _ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Supercell ~~~=~g_co help CA _ #Check Card Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA ~#-C~h-eck Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g~co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ~~~=~g_c~ohelp CA _ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~ "I/Check Card-Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA =0--2~6~#-C"'h~eck Card Purchase MERCHANT PURCHASE TERMINAL SQ PHIPPS PARK BA ~-u~c-~~~~~:~~~~~c~8is2: MERCHANT PURCHASE TERMINAL PARK BY APP ----~F~O~RT LAUD FL #Chec-k Card Purchase MERCHANT PURCHASE TERMINAL WPB CELL PARKING ---~5~6~1~82215 FL #Deposit - - 5, #A2A Pmt Credit 850-.~1~1--- TERMINAL soc 10 3ZXWC5CF SAN FRANC CA :40 PM #Electronic Bill Pay MBS9YU03 SANTANDER CONSUMER o--2~7~#~POS Purchase Pos PURCHASE TERMINAL 13981T41 WALGREENS STORE WEST PALM FL :23 PM 1_0 2_7_#_C~heck Card Pu-rchase MERCHANT PURCHASE TERMINAL RAUL J RODRIGUEZ M D PA FL #ATM Wi-thdrawal CASH WITHDRAWAL TERMINAL 0380P CARMA-PALM-BE REE T W. PALM B FL :44 AM #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA Balance ---4-, , , , , , ,871:81 3, , , , , , , , , , , ,829.24

284 October 31, Page 17 of20 THE LAW OFFICES OF Date Desctiption Additions Subtractions #Check c~-a-rd~p-u-rc~h_a_s_e ~8~.5~0~ MERCHANT PURCHASE TERMINAL HIS HISCOX INC GA #check Card Purchase MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA ~2~10~-~26~-~1~7 Balance 8, , :27 #Check Card Purchase , MERCHANT PURCHASE TERMINAL TACO BELL WEST PALM FL To~27 -#Preauthorized Wd -- ==~ , PAYPAL INST XFER #Check Card Purchase--~ , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Preauthorized Credit -----~3~,3=9=5~_~6~8---- Square lnc L , T0-30 #A2A Pmt Credit , TERMINAL soc 10 3ZDBF3Q8 _ 1 ~ 0 -_ 3 ~ ~-#A-~~ ~:tgr~~i~ ~-~~~-~~ ~~0_A_M 0 TERMINAL soc 10 3ZX53S18 SAN FRANC CA :40 AM _#_A~iA Pmt Credit 403.~0~1~~ TERMINAL soc 10 3ZNA3SC7 SAN FRANC CA :18 AM #Preauthorized Wd --- PROG SELECT INS INS PREM T0-30 #Check Card Purchase ----= MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA , , Lr 13; ,903: , ~0~-#~C""h-e-ck _C_a rd Purchase : , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA =58~4~4=2~1=0~-2=8~-~17~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~0~-3~o~n=c" h,_e_c~k-c"'a-r~d Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA , , , #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g~c~o~h~el~p~c~a 48027_ #Check card P-urchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA :30 #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA , ,103-:13

285 October 31, 2017 Page 18 of 20 THE LAW OFFICES OF Date Description Additions Subtractions #C~he-c-'k~C~a-rd~P~u-rc~liils e MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA T0-30 #Check Card Purchase - MERCHANT PURCHASE TERMINAL PlaystationNetwork CA ~ #POS Purchase.. POS PURCHASE TERMINAL AMAZON.COM SEATTLE WA :_5_2_A_M -----~~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA if #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g~c~o~h~e.lp CA ~2~1~0~-2~9--1~ #Check Card Purchase MERCHANT PURCHASE TERMINAL CRB CARBONITE BACK UP MA '1"0~-3nO~~u=c"h_e_c'k~Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA "0~-3nO~~u=c~h-e-c'k~Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA = #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA 480.2] _ ~ #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL PLAYSTATION NETWOR K CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GLASS CHAMBER WPB WEST PALM FL ~0--~3~0-u~c-h-e~c'k-C~ard Purchase MERCHANT PURCHASE TERMINAL STARBUCKS CARD REL OAD WA #Check Card P-urchase MERCHANT PURCHASE TERMINAL PP ROBLOX CORP CA #Check Card Purchase MERCHANT PURCHASE TERMINAL PP ROBLOX CORP CA '1~o~-3=0-u c=heck Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex ----~g~c~o~h~elp.ca ~10~-~27~-~ #Check c ard Purchase - - MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA Balance 12, , , , , , , , , , , , , , ,183.46

286 October 31, Page 19 of 20 THE LAW OFFICES OF Date Description A~d.~a~it~io~n~s Subtract~io~11s~ Balance #Check Card Purchas-e , MERCHANT PURCHASE TERMINAL GOOGLE Elex. g co help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA () #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA :3() 71check Card Purchase , MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 5 00 BELWEST PALM FL :37 PM #fiiSS-Purchase , POS PURCHASE TERMINAL AMAZON.COM SEATTLE WA :11 PM ~1=o~-3~0~#=P~r-e-authorTied Wd , ReadyRefresh ECHECKPAY #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Supercell g co help CA ~~ #Check Card Purchase MERCHANT PURCHASE TERMINAL CITY OF LAKE WORTH www parkm FL ~-1~ #Check Card Purchase MERCHANT PURCHASE TERMINAL AMAZON DIGITAL SVC S WA #A2A Pmt Credit TERMINAL SQC'ID 3ZPHD72Y SAN FRANC CA :25 AM #A2A Pmt Credit TERMINAL SQC'ID 3ZWJGW1 Y SAN FRANC CA :49 PM #A2A Pmt Credit TERMINAL SQC'ID 3ZR8RRJG --. SANf_RANC CA :46 AM #A2A Pmt Credit TERMINAL SQC'ID 3Z65KNA 1 SAN FRANC CA l :30 PM Check #Check Card Purchase MERCHANT PURCHASE TERMINAL COURTS USBC FL S FL ~,~10~2': #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA ~1=o~-3~1~#~C"'hc-e-c~k card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA :31 #Check Card Purchase MERCHANT PURCHASE TERMINAL GOOGLE Elex g co help CA , , , , , , ,527:21 8, , , , ,867.25

287 October 31, 2017 Page 20 of 20 THE LAW OFFICES OF Date Description Additions Subtractions Ba/a11ce 1o-:3T - #Chec~k_C_a_r_d_P_u_r_c_h-as-e------=== , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g GO help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase ~9-4- 7, MERCHANT PURCHASE TERMINAL FITBIT INC ZEEMF F4JV WWW FITBI CA #Check Card Purchase - ~~~ _ , MERCHANT PURCHASE TERMINAL GOOGLE SuperGell g Go help CA #Check Card Purchase ~ =9=9-7, MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA #Check Card Purchase , MERCHANT PURCHASE TERMINAL PARK BY APP FORT LAUD FL #Check Card Purchase , MERCHANT PURCHASE TERMINAL GOOGLE Elex g Go help CA Ending totals 46, , $7, Date Amount Number Date , * , _,_ : ,To-2: * ~3~ i~~ i~~~ , Ei7* * , * Skip in check sequence Amount 2, ,

288 EXHIBIT 11

289 Statement of Account Last statement: September 30, 2017 This statement: October 31, 2017 Total clays in statement period: 31 BRETT A ELAM LAUREN ELAM 322 MONCEAUX RD WEST PALM BEACH FL Page 1 ofs Direct inquiries to: Customer Service Center Seacoast National Bank 2055 Palm Beach Lakes Blvd. West Palm Beach, FL Account number Date Desc1iption Additions Beginning bala_nce #POS Purchase POS PURCHASE TERMINAL DONNI NI ENTERPRISE S, I JUPITER FL :18 PM SEQ# #Electronic Bill Pay 8BU9CORW FLORIDA PUBLIC UTl #Check Card Purchase MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 5 00 BELWEST PALM FL :04 PM SEQ# #Check Card Purchase :() To:-63 MERCHANT PURCHASE TERMINAL Amazon FreeTime Un ltd WA SEO# #Deposit 3, #Check Card Purchase MERCHANT PURCHASE TERMINAL COSTCO WHSE # ROYAL PAL FL :21_PM SEQ# 727_ #POS Purchase POS PURCHASE TERMINAL SYS DICK'S CLOTHIN G961 WEST PALM FL :46 PM SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL UTOPIA SPA WEST PALM FL SEQ #Check Card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE MENT WEST PALM FL :37 PM SEO # Subtractions EXlll.BiT II Balance $ , , , , ,815.72

290 October 31, Page 2 of 5 BRETT AELAM Date Description Additions Subtractions Balance #Check Card Purchase , MERCHANT PURCHASE TERMINAL COSTCO WHSE #0623 ROYAL PAL FL :32 PM SEQ# ~1~0--0~4~~#~Check Card Purchase , MERCHANT PURCHASE TERMINAL MASSAGE ENVY 0620 WEST PALM FL SEQ# ~1~0--0~5~~#=P-re-a~u-thorized Wd , ~~~= Seterus, Inc. Payment #Deposit - 2, , O #Check Card Purchase , MERCHANT PURCHASE TERMINAL MCCRANELS ORTHODON =~~=i-tl~c~s~w~est PALM FL SEO# #Electronic Bill Pay , BW9SOCQ SUNSHINE POOL SERV o---1-0_#_Ch~eck Card Purchase ~~ , MERCHANT PURCHASE TERMINAL WALGREENS STORE S DWEST PALM FL :02 PM SEO# ~10~-~1~0~#~A~T~MWithdrawal , CASH WITHDRAWAL TERMINAL P N DIXIE HWY LAKE WORT FL :35 PM SEQ# #Check Card Purchase , MERCHANT PURCHASE TERMINAL ORANGETHEORY WPLMB WEST PALM FL SEQ# #Check Card Purchase , MERCHANT PURCHASE TERMINAL CHEVRON/SUN GAS & PETRO WEST PALM FL :36 AM SEO# O #Check Card Purchase - 2, MERCHANT PURCHASE TERMINAL ORANGETHEORY WPLMB WEST PALM FL SEQ# ~1~ ~#~Check Card Purchase , MERCHANT PURCHASE TERMINAL FIRST CARE (NQNPRO FIT) WWW FIRST FL SEO# ~10~-~1-1-~Check c'-, T0-11 Check , i #Check Card P-u-rc_h_a_s_e , MERCHANT PURCHASE TERMINAL SUSHI JDS WEST PALM FL SEO# #Check Card Purchase , MERCHANT PURCHASE TERMINAL TEXACO #-Efu~~~~~~~i~IL ~~~10-17 SEO# , XB79AOXQ BANK OF AMERICA M ~-#=P-reauthorized Wd ~~ , Monitronics Alarrp Svc #Check Card Purchase , MERCHANT PURCHASE TERMINAL FLAMINGO PARK FOOD M~A~RKEWEST PALM FL SEQ# T0-13 #Preauihorized Wd , ATT Payment #Check Card Purc~h~as_e , MERCHANT PURCHASE TERMINAL DATURA WEST PALM FL SEQ# o-_-1_3_#_C~h~eck Card Purchase , MERCHANT PURCHASE TERMINAL HOT PIE WEST PALM FL SEQ#

291 October 31, 2017 Page 3 of 5 BRETT A ELAM Date Description Additions Subtractions Balance #Electronic Bill Pay ~0~ ~,~ MBl9YUS9 AES STUDENT LOAN S #Preauthorized Wd , =Ll~G~HTINBOXL IAT PAYPAL #Preaui:horized Wd : , _~ 6 ~~u=p-~;-:~j:hl0 1~;;dx~~ ~6~ _~ 1 ~ , PA YPAL INST XFER #Preauthorized wa ~~~ , PAYPAL INST XFER #Electronic Bill Pay , NBM9KUS9 TOMASELLO PEST CON ~1=0--1~7~~u=c"h_e_c~k Card Purchase , MERCHANT PURCHASE TERMINAL DUNKIN DONUTS AUTO MA SEQ# ~0~-~1~8~#~C=h~e~c~k~C:ard Purchase -8f MERCHANT PURCHASE TERMINAL ALDI WEST PALM FL :20 PM SEO# check #POS Purchase ----: POS PURCHASE TERMINAL AMAZON.COM SEATTLE WA :25 AM SEO# D504TDJT78KW ~1o=-~1~9~u=p=o=s~rurchase POS PURCHASE TERMINAL 004 CONTAINERSTOREPALM ~~~~~BC~H~G PALMBEACH FL :24 PM SEO# #Check Card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE ---~M=E~NT WEST PALM FL :43 AM SEO# #Check Card Refund i MERCHANT REFUND TERMINAL ORANGETHEORY WPLMB WEST PALM FL :00 AM SEQ# =0~-2~o~u=c=h_e_c~k Card Refund MERCHANT REFUND TERMINAL ORANGETHEORY WPLMB WEST PALM FL :00 AM SEO# #Check Card Purchase -58.8i MERCHANT PURCHASE TERMINAL SCOUT SHOP 4121 PALMBCHGA FL SEO# _0 2_0_#~C~h~e~c-k Card Purchase =~ MERCHANT PURCHASE TERMINAL WALGREENS STORE S DWEST PALM FL :27 AM SEO# ~1=0~-2=o~u=c=rieck card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/SUN GAS & PETRO WEST PALM FL :23 PM SEO# #Check Carel Purchase MERCHANT PURCHASE TERMINAL ORANGETHEORY WPLMB WEST PALM FL SEQ# ~8~ #Check Card -Purchase MERCHANT PURCHASE TERMINAL CARVEL 1225 WEST PALM FL SEO# =20'CO:'-i0"'00'0== #Digital Deposit TcY-23 #Electronic Bill Pay HB091UFR AMBETTER FROM SUNS o=-~2~3~#=E~l~e-c-tr-ol1ic Bill Pay BQ91UFR BANK OF AMERICA C

292 October 31, 2017 Page 4 of 5 BRETT AELAM Date Description Additions Subtractions ---~Bala11ce 10~23 #Check Card Purchase MERCHANT PURCHASE TERMINAL COMCAST XFINITY ----~8~ FL SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL ORANGETHEORY =~~= W~P~L~M=B.;.cWEST PALM FL SEQ# #Electronic Bill Pay =EB~19Huv2 NORTHWESTERN MUTUA #Check Card Purchase MERCHANT PURCHASE TERMINAL TEXACO WEST PALM FL SEQ# ~1~0~-2~3~~#=c"h_e_ck Card Purchase MERCHANT PURCHASE TERMINAL SUSHI JOS WEST PALM FL SEQ# ~1=0--2~3~~#=c"h-e~c~k- Card Purchase ---- : MERCHANT PURCHASE TERMINAL CITGO BEL _ #C~~~~R6~~~Tp~~~~a:L;O 1917 SEQ# ~0~39_1~8~ MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 5 00 BELWEST PALM FL :06 PM SEQ# #Overdraft Fee ~_FO~R~O~VERDRAFT ELECTRONIC BILL PA #Overdraft Fee -35.oo -1, FOR OVERDRAFT ELECTRONIC BILL PA ~1~0--2~4-#~C~h-eck Card Purchase , MERCHANT PURCHASE TERMINAL ORANGETHEORY W_P~L~M=B WEST PALM FL SEQ# ~1=68~ #Deposit 2, #Electronic Bill Pay o:-t=b~190's'-'00c'1w CITY OF WEST PALM #Check Card Purchase MERCHANT PURCHASE TERMINAL URGENT CARE OF THE PALM WEST PALM FL SEQ# #Check Card Purchase ~ MERCHANT PURCHASE TERMINAL KITCHEN WEST PALM FL SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL ORANGETHEORY W~_PLMB WEST PALM FL SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL FLAMINGO PARK FOOD MARKEWEST PALM FL SEQ# ~10~-2~7~=#~C'h-ec~kCard Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE MENT WEST PALM FL :51 AM SEQ# To~-~3~0-#~C~h_e_c~k-Card Purchase MERCHANT PURCHASE TERMINAL PUBLIX SUPER MAR 5 00 BELWEST PALM FL :46 PM SEQ# ~8~5~47~ #Check Card Pu-rchase MERCHANT PURCHASE TERMINAL Amazon FreeTime Un ltd WA SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL WALGREENS STORE S DWEST PALM FL :16 PM SEQ# ~0-~3-1-~C~h-eck

293 October 31, 2017 Page 5 of 5 BRETT A ELAM Date Description Additions Subtractions Balance #Check Card Purchase MERCHANT PURCHASE TERMINAL SUSHI JOS WEST PALM FL SEQ# #Check Card Purchase MERCHANT PURCHASE TERMINAL CHEVRON/AGG MANAGE MENT WEST PALM FL :16 PM SEQ# Ending totals 7, , $ Number Date Amount Number > 1348~.~ * Skip in check sequence Date Amount 1_0_-3_1 ----~29.00 Total for this period Total year-to-date Total Overdraft Fees $70.00 $1, Total Returned Item Fees $0.00 $0.00 SEACOAST OFFERS OVERDRAFT PROTECTION PLANS WHICH MAY BE LESS EXPENSIVE THAN OUR STANDARD OVERDRAFT FEES. FOR MORE INFORMATION PLEASE SEE A BRANCH ASSOCIATE OR CALL US AT

294 Page In Re: KIM C. CRAWFORD, UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA Debtor. Judge Paul G. Hyman, Jr. Case No BKC-PGH ECF #171, 175, 226, 232, 256, 287 May 9, 2017 The above entitled cause came on for hearing before the HONORABLE PAUL G. HYMAN, JR., one of the Judges in the UNITED STATES BANKRUPTCY COURT, in and for the SOUTHERN DISTRICT OF FLORIDA, at 1515 North Flagler Drive, West Palm Beach, Palm Beach County, Florida, on May 9th, 2017, conunencing on or about 1:00 p.m., and the following proceedings were had: Transcribed from a digital recording by: Jacquelyn Ann Jones, Court Reporter OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) The Florida Bar's Composite Exhibit B Exhibit 1

295 Page 2 1 APPEARANCES: 2 3 BROAD & CASSEL, LLP By: GARY FREEDMAN, ESQUIRE 4 On behalf of Bank of New York Mellon 5 BRETT A. ELAM, P.A. 6 By: BRETT ELAM, ESQUIRE On behalf of the Debtor 7 8 SHAPIRO, FISHMAN & GACHE, LLP By: STEVEN POWROZEK, ESQUIRE 9 On behalf of Nationstar Mortgage 10 GERARD M. KOURI, P. A. 11 By: GERARD KOURI, ESQUIRE On behalf of Bank of America OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

296 Page THE COURT: Good afternoon. Please be seated. Crawford. Appearances. MR. FREEDMAN: Good afternoon, Your Honor. Gary Freedman on behalf of the Bank of New York. 5 MR. POWROZEK: Good afternoon, Your Honor. 6 Steven Powrozek, P-o-w-r-o-z-e-k, for Nationstar 7 8 Mortgage, Class 3. MR. KOURI: Good afternoon, Your Honor. 9 Gerard Kouri on behalf of Bank of America, Claim 10 number 2, Class number 2. We are in agreement, and I 11 voted in favor of the latest filed plan THE COURT: MR. ELAM: Okay. Good afternoon, Your Honor Brett Elam on behalf of Ms. Crawford, who is also here with me today THE COURT: MR. ELAM: Okay. Your Honor, we're here today on a 18 status conference from the previous hearing where 19 confirmation was denied. The Court set a status conference on whether the debtor would be able to confirm a plan over the objection of Bank of New York Mellon. We have -- we were instructed to appear and, I guess provide the Court with a road map of how we would be able to confirm any subsequent Chapter 11 OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

297 Page plan. THE COURT: Well, there's a motion to dismiss pending, that I'm going to grant, unless you can provide that road map. MR. ELAM: Yes, sir. That's -- I didn't want to say it like that, but THE COURT: I did. MR. ELAM: Yes, sir. THE COURT: That's the reason it's set this way. MR. ELAM: Yes, sir. THE COURT: Okay. MR. ELAM: And Your Honor, if the Court recalls, the main reason that we were unable to confirm at the last hearing was based upon the valuation of several business entities, or Ms. Crawford's interest in those business entities. The evidence before the Court was not admitted into evidence -- actually, the documentation before the Court was not admitted into evidence because Ms. Crawford did not have personal knowledge of the documents or the information that was included in those documents. THE COURT: And the biggest problem is the property owned down in Central America, and how do you OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

298 Page 5 1 value it, and how do you meet the liquidation standard 2 without evaluation. 3 MR. ELAM: Yes, sir. On that issue, Your 4 Honor, we have actually done some further research, 5 and we've found one property that was sold that was 6 approximately 30 acres. It did have electricity, 7 water, road access, and several other - I think it 8 had doubled the waterfront that the property that Ms. 9 Crawford owns. 10 Your Honor, we looked at that, and we 11 believe that the value is $240,000 of the current 12 property that she owns, based upon that comparable. 13 So with that information, I believe that that is the 14 proper value of the Honduras real property. 15 THE COURT: How do you prove it if they 16 don't agree to it? 17 MR. ELAM: Your Honor, we can have Ms. 18 Crawford testify. There is a realtor in Honduras, 19 that if the Court would allow us to arrange either 20 video testimony, or some other form of electronic 21 testimony, that could testify as to the properties 22 that have been sold - or the proper key that was sold 23 there, and the, I guess conditions or shape of that 24 property, and base it on what the value of our current 25 property would be. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

299 Page 6 1 THE COURT: Well, you've got to be able to 2 get through any - get by any objection based on 3 hearsay. 4 MR. ELAM: Yes, sir. And that's why I would 5 ask the Court for permission to maybe have video 6 testimony, or maybe take a video deposition before the 7 next hearing, and let Mr. Freedman have opportunity to 8 cross examine the same person, or that witness. So 9 that way we could use that testimony, and it would not 10 be hearsay. 11 And Your Honor, as far as the valuation of 12 the different business entities - 13 THE COURT: That's a big issue. 14 MR. ELAM: - we had, there was an entity, 15 Help is Here, Harbor House Resort, Harbor House 16 Enterprises, Sobetty (phonetic), Singer Island Resort, 17 Busch Canvas, Secret Gardens and Artistic Upholstery. 18 Each of those entities, has an accountant. 19 There's two, Carlos Cerezo, I'm not sure if 20 I'm pronouncing that correctly, Jr., and I believe it 21 is Mike - Paul, I'm sorry, how do you say his last 22 name, Paul Wieseneck (phonetic), and they are the 23 people who actually compiled the financial information 24 and the financial documentation, and they have 25 personal knowledge of the liquidation value of each of OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

300 Page those entities. And if I could proffer what we've discussed with them, approximately the estate's interest in each of the business entities liquidation value is approximately $30,000. And add that to the 120,000 of the estate's interest in the Honduras property, the debtor would be paying $150,000 to unsecured creditors over a period of five years, which would increase the payment to $2500 a month from, I believe it was 1300 before. So I believe that that would accurately satisfy, or would satisfy the liquidation test, and we would be able to cram down - THE COURT: You've got to deal with the feasibility. Does she have $2500 in income, net income. MR. ELAM: It would be tight, Your Honor. But looking back, there would need to be some adjustments to her budget. She would have to cut certain things out, but there is enough income there to pay for it. THE COURT: Okay. MR. ELAM: So Your Honor, I believe that that would be how we would get to confirmation. THE COURT: Any other comments by other OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

301 Page parties? MR. FREEDMAN: Your Honor, Gary Freedman on behalf of Bank of New York, if I may. Last evening Mr. Elam filed court paper 295, which is entitled, Debtor-in-possession's Response for Status Conference Related to Confirmation of the Chapter 11 Plan of Reorganization, which I understood to be the road map that the Court had requested, and that is what I base my conunents on. And I have some initial points, and then I'm going to draw down on some of them. I'm going to submit to the Court that the CPAs that are identified in this response are not identified as valuation experts. They're CPAs. They are tax preparers. They're not going to be competent to testify as to valuation of businesses like the ones at issue. And I'll talk a bit more about that in a moment. THE COURT: How do you know that? MR. FREEDMAN: I've done some research. did some research this morning, looked on line with respect to their credentials, what was identified as their areas of practice, and neither one of those individuals reflected in the report, even reference, had any reference to an evaluation experience. And Mr. Elam concluded by saying, well, in I OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

302 Page their, in the debtor's view, there's $150,000 of value of assets for the liquidation analysis. We're dealing with the same issue that we dealt with on March 15th, when the Court denied confirmation, because there are other assets that he still continues not to incorporate in the analysis. Including a $30,000 retirement account, which is not an exempt asset. There is, according to amended monthly operating report that was just filed as I was driving up here, from March, there's $150,000 in the debtor-in-possession account, which are not factored into this analysis that, or this road map that the debtor is required to provide. And I'm uncertain with respect to what plan the debtor now is trying to advance, because I -- last time we were here on March 15th, we were on the fourth amended plan. Mr. Elam, on behalf of the debtor, ore tenus amended it. And now I'm having further amendments. So I don't even know what plan the debtor seeks to advance. But when I saw this this morning, I saw a reference to a Carlos C-e-r-e-z-o, Jr., and it reads, who is the accountant for Help is Here, LLC, Harbor House Resort, LLC, Harbor House Enterprises, LLC, Singer Island Resort, LLC and Secret Gardens, LLC. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

303 1 And it goes on in paragraph 9. Page 10 Cerezo will testify based upon his personal knowledge obtained from his review of the books and records of the Cerezo entities. First of all, the books and records -- and there's a motion to compel that's before the Court as 7 well, and it keeps getting carried over. And the books and records that have been provided to me with respect to the entities is, the general ledger, cash returns and profit and lost statements. The typical documents that you would expect to see for businesses like these, and for purposes of valuing a business, would also include balance sheet. I don't know how a business valuation, even if these gentlemen are qualified, could ever testify as to value without a balance sheet. 17 There's no statement of cash flows. There's 18 no statement of retained earnings. The typical four financial statements that you would read in order to undertake a financial analysis in respect to 21 valuation, have never been provided to me. And as far as I understand, the debtor doesn't have them for those entities. Now, when I look at Mr. Cerezo this morning, he does have his own website, but there is something OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

304 Page called Buzz Life where it lists Carlos Cerezo, CPA, and I'm reading a portion of it. Carlos Cerezo, Jr., CPA is located in Jupiter, Florida. This organization primarily operates in the certified public accountant business industry within engineering, accounting research and management services sector. And then it goes on, category, accounting, auditing and bookkeeping, and is a certified CPA. And then there's also a website under the National Directory Registered Tax Return Preparers and Professionals. And it reads about Mr. Cerezo, for tax preparation in Jupiter, Florida you can count on Carlos A. Cerezo, CPA and Carlos Cerezo, Jr., CPA. Carlos A. Cerezo, CPA assists taxpayers and small businesses with taxes in Jupiter, Florida and Islamic communities. Whether you are an individual or a local business in around Jupiter, Florida, Carlos A. Cerezo, Jr., CPA has years of valuable experience as an IRS registered tax preparer. So that's all the information I could find on Mr. Cerezo. And then with respect to Mr. Wieseneck, he's with a company called Fuoco Group. And I'm reading part of his CV on the website. In addition to being a CPA he also holds a license for insurance sales. Besides tax preparation OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

305 Page and planning, Paul has been very successful in representing numerous clients in front of the IRS, as 3 well as State and local tax agencies. Working with small business owners and retirement age clients in succession, estate planning has been a passion Paul has enjoyed over the years. And then I had Judge Williamson's treatise on proper evidence, and he has a whole section on 9 admissibility of experts. And the Court is familiar with it. I can cite chapter and verse. And maybe Mr. Elam can provide a little 12 additional information on these individuals. But my sense of it is, Your Honor, we're going to get here, if the Court doesn't grant the motion to dismiss, and these two gentlemen are not going to be qualified to provide valuation. First of all, I don't know what they got basis to put on, because I don't think it's the proper 19 documentation for them to even reply upon. And I don't think they're going to ever qualify as having the experience, the knowledge, the ability to value businesses based upon the various treatises and getting by Daubert and Kumotia (phonetic) And again, maybe Mr. Elam can educate us on that. 25 But in respect to the Honduras property, I OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

306 Page was surprised to hear Mr. Elam, because all paragraph 12 in this report, this road map says, is, as for the Honduras real property the debtor has inquired about the valuation of other parcels of real property located in the Honduras on the Island of Roatan. The comparable parcels of real property shall establish the value of the Honduras real property. So it talks about comparables, plural, not one comparable. It goes on, based upon these comparables the Honduras real property is valued at approximately $240,000, of which the debtor is entitled to $120,000. So this road map provides us no information, as the Court brought up, how the debtor is going to establish the value of that property. She certainly is not a valuation expert on real property in Roatan. There's nobody identified. At least they identified two folks in respect to the businesses. There's no person identified. And the Court was strict about this saying, how are you going to show me, how are you going to present the value of that property. And still, as of today, there's no showing of that. I do also want to add, and I'm not sure if the Court saw this, they also filed a supplement to our motion to dismiss. And that is docket entry 294. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

307 Page And maybe we'll get an explanation for this today. But when I received the debtor's monthly operating report for March, and I received it on or about April, 2017, I was going through it, and all of a sudden I saw that the account dropped from $140,000 down to about $100,000. And I saw a disbursement for $34,400. And as I drilled through it a bit - THE COURT: Attorneys fees. MR. FREEDMAN: Attorneys fees. Okay. THE COURT: I saw it. MR. FREEDMAN: Okay. And you'll see the exchanges I had with Mr. Elam basically pleading with him, tell me what this is for, show me that you have always maintained the $34,400 in your trust account. Because the Court has never awarded -- it was brought up at the March 15th hearing. And I said, Judge, it's too early, too premature to determine the reasonable value of the services, let's roll it. And typically in Chapter lls you file a notice, and you show what moneys that the attorney is holding. That wasn't filed. And I even ed him yesterday, because I really didn't want -- I didn't want to bring this up. I have it. And ask him one more time, show me that it was always in your trust account. And I still haven't OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

308 Page received that information. And then as I was preparing for this morning I knew that his fee applications were rolled to today. So I looked at his final application for compensation, 5 docket entry 175. So his explanation was that, I asked my client for the $34,400 to deal with my outstanding fees. And when I looked at 175, I see that he had received a $5,000 retainer, so that would drop the - balance of what he was requesting down to $29,400. And then when I looked at the fee application summary chart, I saw it, because the Court knows I'm just into this case in, I think it was December of 2016, but I saw that he applied for fees of $14,350, which the Court awarded back in March, 2015, of which he was paid $10,000. So that would leave the balance owed to him, if this application was awarded, of approximately $24,000. So I'm seeing it like, why are you taking disbursement from the debtor of $34,000, when even based on your own fee application, you're only owed $24,000. You've already been paid $10,000. And you should be sitting on another $5,000 retainer. I know that Mr. El am, as I was driving up, amended the March monthly operating report, showing OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

309 Page 16 1 that the money is in his trust account, but I still 2 haven't seen anything demonstrating that it's always 3 there. 4 And what bothers me, Your Honor, is, since 5 I've been involved in this case, if it wasn't for my 6 digging on behalf of my client, a lot of the 7 information that has been filed with the court would 8 have never been fleshed out. 9 The Court will recall, the debtor valued the 10 Roatan property at zero. She valued her interest in 11 the various corporations at zero. I believe she 12 valued her interest in any retirement account at zero. 13 It's only because I took discovery, kept 14 pushing for documents, took depositions, that now 15 we're hearing, well, these assets are at least worth 16 $150,000, and we know of another $30,000 in annuity, 17 and we know there's $150,000 in the DIP account. And 18 if I hadn't dug through the monthly operating report, 19 we would have never known that it was reduced by 20 $34, And even if Mr. Elam was holding the $34, in trust, it's not a deduction to the debtor's cash. 23 It's being held on her behalf. 24 We went through confirmation a month and a 25 half ago, two months ago almost. Okay. It was the OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

310 Page debtor's burden to carry the evidence that day to confirm. We're here today. It doesn't sound like we're even proceeding on the plan that's filed. And I 5 submit to the Court that there is no road map. We're going to come back before the Court, if the Court will allow it, and it's going to be based upon this road map, we're going to be exactly in the same position. And the only other comment I wanted to make to the Court, if I may, is, if the Court allows this to proceed, at least, at least make these purported experts provide reports prior to confirmation, and allow me to take depositions. But again, unless Mr. Elam knows more about these individuals and their purported expertise on business valuations, we're going to be here and it's going to be for naught. THE COURT: Additional comments? Mr. Kouri, Mr. Powrozek. MR. POWROZEK: No, Your Honor. THE COURT: Mr. Elam. Why isn't, first of all, the money in the debtor's DIP account, and the money held in escrow by you, not part of the distribution to be made to creditors? 25 MR. ELAM: Your Honor, the amount that was OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

311 Page 18 1 paid was put in my trust account, and it was the 2 monthly operating reports had been amended to reflect 3 that that is an asset of the estate. That money was 4 put there based upon a pending confirmation hearing. 5 I don't know what Mr. Freedman is talking 6 about about deducting this and that from my fee 7 application. There were supplements to fee 8 applications that were filed. That was not - it was 9 not just one fee app. 10 I have never intended to mislead this Court. 11 I'm the one that instructed Ms. Crawford to make sure 12 that that was on the monthly operating report, because 13 I wanted it to be shown there. 14 THE COURT: That's not the question. Why is 15 not why are those - why is cash not reflected in 16 the proposed distribution to the creditors? 17 MR. ELAM: Well, Your Honor, the cash, 18 whatever administrative costs would be allowed by the 19 Court, would be deducted from those that cash. And 20 obviously if 21 THE COURT: You're going to spend $150, in attorneys fees getting - 23 MR. ELAM: I would like to (laughter). It 24 probably wouldn't be approved. 25 THE COURT : No. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

312 Page MR. ELAM: I don't mean that, Your Honor. In all seriousness, that cash would be available to pay down the -- whatever that we need to do. Ms. Crawford is a small business - THE COURT: Go back. You said, proposed distribution is going to be $150,000. MR. ELAM: Yes. THE COURT: Why is it not $300,000, or $250,000, or whatever? MR. ELAM: Whatever that Ms. Crawford needs to do is what we would do, and - THE COURT: This is not a negotiation. MR. ELAM: I understand, Your Honor. And we are willing to put that money toward confirmation. And all I've asked, and I've asked a million times, what does Bank of New York Mellon want. We are sitting here going against ourselves because we've got a case where everything else is settled, satisfied. We are simply waiting on one entity that -- if they could tell us what they want, we'll try to make that happen. THE COURT: That's not the test here. The test is, how much legally the debtor must pay under a plan, and whether the future payments are feasible. That's the test. It's not a negotiation. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

313 Page MR. ELAM: THE COURT: Yes, sir. It can be in negotiation with Mr. Freedman's client, but not with me. MR. ELAM: Your Honor, I wasn't -- wasn't trying to negotiate with the Court. I apologize if it came off like that. THE COURT: I have to tell you, at the last hearing you said something to the effect, Your Honor, 9 tell us what we need to pay. And in essence, you're saying to Mr. Freedman, tell us what we need to pay. That's not the way you proceed. MR. ELAM: Right. And Your Honor, when I say that -- and I'm sorry if I was not formal with the 14 Court. I didn't mean it like that. More along the lines of, we believe the businesses are worth X, and if someone else has documentation or an expert that says it's something different, then tell us. I mean, we're trying to prove the value of something and - 19 THE COURT: You've got the burden of proof. 20 Tell me about the retirement account MR. ELAM: sorry, Your Honor. THE COURT: The retirement account was -- I'm Are you asserting it's exempt? 24 Mr. Freedman keeps saying it's not exempt. 25 MR. ELAM: I am asserting it's exempt, yes, OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

314 Page 21 1 sir. It's -- 2 THE COURT: Mr. Freedman, what's the basis 3 for asserting it's not exempt? 4 5 MR. FREEDMAN: Schedule c, Your Honor. It's not listed under This case has been pending 6 since August, I've raised this in depositions. 7 I've asked about it in depositions, attach the monthly 8 operating report. Never been identified as an exempt 9 Schedule C asset, as far as I know THE COURT: MR. ELAM: He's about to answer that. Your Honor, I don't have it on my 12 Schedule C, but that's the original. And I don't know 13 if it's not been amended, and if it hasn't, obviously 14 it will be, because it is an absolute exempt asset. 15 It is maintained pursuant to the Internal Revenue Code 16 by a third party, and it is a typical IRA. 17 THE COURT: Well, Mr. Freedman, there's 18 nothing in the Code that restricts the debtor's 19 ability to amend a plan, other than the requirement of 20 good faith. 21 MR. FREEDMAN: Yes, Your Honor, I understand 22 that. 23 But there is concepts of waiver, latches. 24 And this is an issue that I've been bringing up for 25 months. I've identified it. The debtor has done OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

315 Page 22 1 nothing to remedy it or rectify it. I brought it up 2 at the last hearing. Still hasn't been amended. 3 If the debtor does attempt to exempt it, I 4 will do the research and determine that there's law 5 that supports their inability to do it three years 6 later when they've been negligent and they were on 7 notice. 8 THE COURT: And finally, Mr. Elam, what 9 about the qualifications of the three expert 10 witnesses 11 MR. ELAM: Your Honor - I'm sorry. 12 THE COURT: - the CPAs and the real estate 13 broker, I think you called her. 14 MR. ELAM: One, Your Honor, I believe Mr. 15 Cerezo recently retired as the accountant for Palm 16 Beach County. And I believe he would be fully 17 qualified to attest to the liquidation value of a 18 company that he is familiar with and has done the 19 books and records for. He was actually approved by 20 this court as the accountant for Ms. Crawford. 21 So I believe that we don't have to have a 22 business valuation per se. But we need to have a 23 liquidation value of that business entity, because 24 that is the test, is that, did we pay more than 25 creditors would receive in a Chapter 7 liquidation. OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

316 Page That does not take into account income revenue stream. that takes into account a Chapter 7 trustee walking into the company and shutting it down and selling it. And if that is the case, I don't personally believe the company is worth anything, or any of them, because Ms. Crawford has to be present for those 7 companies to work. And if a trustee walks in and shuts them down, all it is is the hard assets. THE COURT: Mr. Freedman, refresh my recollection, why is your client not seeking client is a secured creditor; correct? your MR. FREEDMAN: Yes, sir. THE COURT: Why are they not seeking relief 14 from stay? 15 MR. FREEDMAN: You granted it last hearing It becomes effective today. that I needed. THE COURT: Okay. That's the refreshing 19 MR. FREEDMAN: Yes, sir. 20 And if I may, Your Honor THE COURT: Court foreclosure? What is the status of your State 23 MR. FREEDMAN: Obviously it's been stayed. 24 THE COURT: Prior to the petition, what was 25 the - OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

317 Page 24 1 MR. FREEDMAN: I'm sorry, Your Honor, I 2 don't -- I was not counsel of record. I would have to 3 go back and look. I know it 4 THE COURT: Do you know if your client has a 5 judgment? 6 MR. FREEDMAN: No, it doesn't have a judgment. I can tell you that possession of the original note, as it becomes an issue in these type of cases from time to time, is not an issue. I am holding the original note on behalf of my client. I know at one time that we spent a lot of time and money with the debtor claiming that my client 13 didn't have standing even to assert the claim. I have the original note. issue. So that's not going to be an She's testified that she hasn't made a payment on this since 2008, so that's not going to be an issue. And one, I guess mischaracterization that I want to clarify, a trustee coming in, as Mr. Elam says, Ms. Crawford owns 50 percent of these businesses. So a valuation expert would have to come in and value the business, okay, make whatever adjustments a business valuator would have to make for a liquidation of the asset, given an accelerated time OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

318 Page 25 1 frame, and then assign a value to Ms. Crawford's 50 2 percent interest. 3 So there's nothing of record that would 4 establish that all of a sudden these companies would 5 just shut down. Ms. Crawford has a long time partner 6 in all of these companies. The companies have been 7 operating for a long period of time. So I think that 8 that's a misconception. 9 THE COURT: That's an evidentiary issue. 10 MR. FREEDMAN: Okay. But I still haven't 11 heard the - I mean, again, qualifications. Mr. 12 Cerezo was accountant for the County of West Palm 13 Beach. That doesn't make him a valuation expert. It 14 doesn't even qualify him. It tells us that perhaps he 15 was good at administration of the counties 16 accountants. 17 MR. ELAM: Your Honor, if I may. As far as 18 Mr. Cerezo goes, it doesn't tell us he's not an expert 19 either. And just by Mr. Freedman coming in and saying 20 that he's not, he doesn't know that. He's never met 21 the man. 22 And as far as the State Court proceeding by 23 his client, if I'm not mistaken, it's been pending for 24 numerous years. 25 THE COURT: That's not the issue. The OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

319 Page 26 1 question is, how far is he away from a sale of the 2 asset? 3 MR. ELAM: I think it's a long way, Your 4 Honor, to be honest. 5 THE COURT: This is what I'm going to do. 6 I'm going to grant Mr. Freedman's client relief from 7 the automatic stay. Going to deny without prejudice 8 the motion to dismiss. Mr. Elam -- 9 I take it back. I'm going to grant relief 10 from stay through judgment, not through sale. 11 Mr. Elam, that gives your client the 12 opportunity to file an amended plan, to attempt to 13 obtain confirmation MR. ELAM: THE COURT: Yes, sir. I will give Mr. Freedman's 16 client complete relief from the automatic stay 17 effective July 28th. That means you've got to have 18 your plan confirmed, Mr. Elam, prior to that date. 19 MR. ELAM: Yes, sir. 20 THE COURT: Or Mr. Freedman's client is 21 going to be entitled to then set the foreclosure sale. 22 MR. ELAM: Yes, sir. 23 THE COURT: Obviously all rules of discovery 24 are applicable. Mr. Freedman is entitled to take your 25 client's expert's depositions. When will you have a OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

320 Page report ready, expert report? MR. ELAM: days. THE COURT: Your Honor, if we could have ten That's not a problem at all. That means all three, the accountant and the real estate broker. MR. ELAM: THE COURT: Yes, sir. As far as the admissibility of 9 the real estate agent, its deposition, I'm not ruling 10 on that yet. But obviously, there's grounds, Mr Freedman, if she's unavailable to allow her telephonic -- or not telephonic, video taped deposition into evidence theoretically. MR. FREEDMAN: If I may, Your Honor. One point, and I don't intend to be argumentative on this point, and it may be moot at the end of the day, the last time the Court granted stay relief the Court made it effective as of the time we were going to come back 19 to the status conference. I moved to extend so I could attend to a family vacation. THE COURT: Right. I understand. MR. FREEDMAN: And the Court was kind enough to grant it, and made it effective as of today. And now the Court is making it through judgment. I just want to remind the Court that the OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

321 Page debtor has conceded that she will need to surrender the property because she is unable to modify the loan as it's a loan on a principal residence. That has already been made of record. So I hear the Court, but I don't think it really matters, because there's nothing that this debtor is proposing that's going to allow her to deal with the mortgage. She claims the house is worth 800,000 THE COURT: That's a good point. Tell me how the debtor is going to - MR. ELAM: Your Honor, I'm not sure what Mr. Freedman means by we conceded that we would surrender the property. We're still involved in an MMM process for modification of the mortgage. And we have through June 1st to provide, yet again, more documents that were requested. So while I understand what Mr. Freedman is saying per se, in this situation I don't think it applies THE COURT: And frankly, Mr. Freedman, sounds to me like your client is not going to get a sale prior to, what did I say, July 28th. MR. FREEDMAN: Again, I think that's fair, Your Honor, and that's why I hesitated when I came. I OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

322 Page 29 1 just wanted to remind the Court that, as things stand, 2 there is no plan modification of the primary mortgage, 3 but for practical purposes, I don't think it's going 4 to matter. 5 THE COURT: Right. And frankly, if the MMM 6 process is not successful, the plan is not going to be 7 confirmable, Mr. Elam. So you ought to take that into B account, if that's your plan. 9 MR. ELAM: Yes, sir. 10 MR. FREEDMAN: Thank you. 11 THE COURT: I think you and the debtor ought 12 to have a heart to heart whether the house is even 13 worth keeping versus some other avenue here. 14 MR. ELAM: Well, Your Honor, the issue is, 15 even if we surrender, Mr. Freedman is still objecting 16 on behalf of the unsecured creditors. So I mean 17 THE COURT: I understand. But that -- if 18 they don't agree to modification of the mortgage, why 19 are you wasting all the debtor's money instead of 20 finding other space -- I understand she uses the home 21 for some of her business operations, but it may be 22 more economical to do something elsewhere. 23 MR. ELAM: Well, and that's our main issue, 24 Your Honor, is that the home -- if we could surrender 25 the home and confirm the plan otherwise, we would be OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

323 Page 30 1 done, we wouldn't be standing here right now. Because 2 these two creditors are the ones that we have to stick 3 a deal with because of the other property she owns. 4 So by this mortgage holding us over a barrel, we're in 5 no man's land. 6 THE COURT: Well, there's one way to get rid 7 of the mortgage, not the deficiency claim, but the 8 mortgage. 9 MR. ELAM: True. 10 THE COURT: Get rid of that issue. Just 11 making that observation. 12 MR. ELAM: Yes, sir. 13 THE COURT: I'm giving the debtor one last 14 chance to do what they can. 15 MR. ELAM: Thank you, Your Honor. 16 THE COURT: And the only reason I'm doing it 17 frankly, is because of the inadequate evidence, not at 18 the last hearing, not the inability of the debtor 19 potentially to obtain an order confirming the plan. 20 MR. ELAM: Thank you, Your Honor. 21 THE COURT: That's really why. 22 MR. FREEDMAN: Your Honor, one final point. 23 And I'm going to leave this totally to the discretion 24 of the Court. 25 As I mentioned earlier - OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

324 Page 31 1 THE COURT: Aren't you always leaving things 2 to the discretion (laughter) 3 MR. FREEDMAN: That's a fair comment, Your 4 Honor. 5 THE COURT: Anyway, what is it you would 6 like? What is the request that I will exercise my 7 discretion on? 8 MR. FREEDMAN: Yes, sir. I have now for 9 three weeks asked Mr. Elam for some evidence that the 10 $34,400 had always been - 11 THE COURT: Oh, that's easy. I'll give 12 I'll make him show his trust account records by 13 Friday. 14 MR. FREEDMAN: Thank you, sir. 15 MR. ELAM: Yes, sir. 16 THE COURT: Obviously not other clients' 17 trust account records, just this account, you know, 18 something in your bank records that show the deposit 19 of the $34,000 into your trust account. 20 MR. ELAM: That's been provided. 21 MR. FREEDMAN: That stayed there, Your 22 Honor. It wasn't dispersed. 23 THE COURT: Of course. It's current 24 information. 25 MR. ELAM: Right. He's been provided - oh, OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

325 Page 32 1 okay, I was going to say, I provided him with the 2 information that it went in and that's - but I'll 3 give him the rest. 4 THE COURT: That's fine. Anything else? 5 MR. FREEDMAN: No, sir. 6 THE COURT: So I'm denying the motion to 7 dismiss, granting relief from stay for all the way 8 through sale, and effective July 28th. The creditor 9 will have complete relief from stay through 10 foreclosure. I mean, to conclude the foreclosure 11 completely. 12 Now, what about the motion to compel 13 sanctions for failure to comply with court order? 14 MR. FREEDMAN: Your Honor, we've rolled 15 that, but 16 THE COURT: I know. 17 MR. FREEDMAN: I'm satisfied with the 18 conclusion that if the debtor hasn't produced 19.documents at this point, that she can't - you know, 20 that I would move to limit the attempt to admit any 21 documents that had not previously been produced, and 22 preclude the use by any expert in respect of those 23 documents. 24 THE COURT: Mr. Elam, you agree? 25 MR. ELAM: Your Honor, if in the expert OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

326 Page report there are other documents that are created that I don't have possession of, I will provide them to Mr. 3 Freedman. But what we have provided, is what we're 4 5 going to use, and that was stated at the last hearing as well. 6 THE COURT: The answer is, your client has 7 an obligation to produce the documents. To the extent they have not produced the documents, other than the report or documents generated by the experts, they will not be admissible. MR. ELAM: Yes, sir. MR. FREEDMAN: Can I prepare an order on that, Your Honor? THE COURT: Yes, sir. On that motion. MR. FREEDMAN: Thank you. Yes, sir. THE COURT: Okay. Good. 17 MR. FREEDMAN: Thank you THE COURT: MR. ELAM: THE COURT: You're welcome. Thank you, Your Honor. You're welcome. 21 (The proceedings were concluded.) OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

327 Page C E R T I F I C A T E I, JACQUELYN ANN JONES, Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that the foregoing proceedings were transcribed by me from a digital recording held on the date and from the place as stated in the caption hereto on page 1, to the best of my ability In witness whereof I have hereunto set my hand and seal this 22nd day of December, JACQUELYN ANN JONES Commission GG Expires Feb. 18, OUELLETTE & MAULDIN COURT REPORTERS, INC. (305)

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