Barbara A. Owen - Page 12

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          fees were allocated among petitioner and the other Hoyt investor            
          clients of petitioner’s attorneys.                                          
               On August 5, 2004, we filed respondent’s response to                   
          petitioner’s motion, in which respondent objected to an award of            
          costs.  Petitioner requested and was granted leave to file a                
          reply to respondent’s response to the motion.  On September 15,             
          2004, we filed petitioner’s reply to respondent’s response, which           
          included a supplemental declaration but did not provide any                 
          detailed information regarding petitioner’s counsel’s billing and           
          allocation arrangements with respect to the group fees.  On                 
          December 6, 2004, we ordered petitioner to submit, on or before             
          January 7, 2005, an additional declaration with supporting                  
          documentation to support her contention that the group fees were            
          reasonable and had been reasonably allocated and that her share             
          of the group fees was incurred in connection with this matter.              
          In the December 6, 2004, order, we also authorized respondent to            
          submit a supplemental response addressing the information                   
          contained in petitioner’s supplemental declaration, on or before            
          January 31, 2005.                                                           
               On January 10, 2005, we received and filed petitioner’s                
          supplemental declaration, which contained billing records for               
          fees and costs petitioner’s attorneys had charged to common                 
          accounts for two separate groups of Hoyt investor clients.  The             
          billing records provided specific information about the nature of           






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