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Jeffrey M. Tillotson, P.C. (jmt@lynnllp.com) Texas Bar No. 20039200 Eric W. Pinker, P.C. (epinker@lynnllp.com) Texas Bar No. 16016550 John Volney (jvolney@lynnllp.com) Texas Bar No. 24003118 LYNN TILLOTSON PINKER & COX, L.L.P. 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE

IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION In re: § Chapter 11 § FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH § Debtor. § ______________________________________________________________________________

THIRD APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF COMPENSATION AND FOR REIMBURSEMENT OF EXPENSES

INCURRED FROM SEPTEMBER 1, 2012 THROUGH APRIL 30, 2014 ______________________________________________________________________________

NO HEARING WILL BE CONDUCTED ON THIS APPLICATION UNLESS A WRITTEN RESPONSE IS FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT, 1100 COMMERCE STREET, SUITE 1254, DALLAS, TEXAS 75242, BEFORE 5:00 P.M. PREVAILING CENTRAL TIME ON JUNE 27, 2014, (THE “OBJECTION DEADLINE”), WHICH IS AT LEAST TWENTY-FOUR DAYS AFTER THE DATE OF SERVICE OF THIS APPLICATION. ANY RESPONSE MUST BE IN WRITING AND FILED WITH THE CLERK, AND A COPY MUST BE SERVED UPON THE UNDERSIGNED COUNSEL PRIOR TO THE DATE AND TIME SET FORTH ABOVE. IF A RESPONSE IS TIMELY FILED, A HEARING MAY BE HELD WITH NOTICE ONLY TO THE OBJECTING PARTY. IF NO RESPONSE TO THIS APPLICATION IS TIMELY FILED, THE RELIEF SOUGHT HEREIN SHALL BE DEEMED TO BE UNOPPOSED, AND THE COURT MAY ENTER AN ORDER GRANTING SUCH RELIEF.

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Lynn Tillotson Pinker & Cox, LLP (“LTPC,” the “Firm” or the “Applicant”), special

litigation counsel to Matthew D. Orwig, the liquidating Trustee (“Trustee”) for the estate of

FirstPlus Financial Group, Inc. (the “Debtor”), files this Third Application of Lynn Tillotson

Pinker & Cox, LLP for Allowance of Compensation and for payment of Expenses Incurred from

September 1, 2012 through April 30, 2014 (this “Application”).

I. SUMMARY OF APPLICATION

By this Application, LTPC seeks approval for payment of its attorney’s fees in the

amount of $1,000,000.00, which reflects LTPC’s one-third contingency fee interest in the

Trustee’s settlement with Olshan Frome Wolosky LLP f/k/a Olshan Grundman Frome

Rozenzweig & Wolosky, LLP and David Adler (collectively “Olshan”), which has been filed for

approval by this Court pursuant to Bankruptcy Rule 9019. [Docket No. 1013]. In addition to its

contingency fee, LTPC requests reimbursement of its expenses incurred from September 1, 2012

through April 30, 2014 (the “Application Period”) in the amount of $2,958.01. The total amount

sought by LTPC in this Application is $1,002,958.01. For the reasons set out below, LTPC

respectfully requests that the Court grant this Application.

II. JURISDICTION AND VENUE

1. The Court has jurisdiction over the relief requested in this Application pursuant to

28 U.S.C. § 1334(a) and (b). Venue is proper in this District pursuant to 28 U.S.C. §§ 1408 and

1409(a).

2. The statutory predicates for the relief requested herein are 11 U.S.C. §§ 327-328

and 330 and Fed. R. Bankr. P. 2016.

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III. BACKGROUND

3. On June 23, 2009, FirstPlus Financial Group, Inc. (“Debtor”) filed its petition for

relief under Chapter 11 of the United States Code.

4. On July 24, 2009, the Court entered its Order appointing Matthew D. Orwig as

the Liquidating Trustee for the Debtor.

5. On April 29, 2011, the Trustee filed an application to employ LTPC as special

counsel to the Trustee in this Bankruptcy Case. [Docket No. 565].

6. On May 12, 2011, the Court entered its order granting the application and

authorizing employment of LTPC. [Docket No. 572]. As relevant to this Application, the

Court’s Order authorized the Trustee to employ LTPC as Special Litigation Counsel to evaluate

and pursue claims against the former professionals, fiduciaries and others affiliated with Debtor.

The Order provided that LTPC would be paid (1) a reduced hourly rate up to a total of $25,000

to evaluate the potential claims and then (2) one-third of any net monetary recovery by the Estate

pursuant to a standard contingency fee arrangement if claims were pursued. The Order further

provided that LTPC would credit the estate for any payment made pursuant to the reduced hourly

arrangement in the event that LTPC recovered under the contingency fee arrangement, which

credit was taken when the Court approved LTPC’s Second Application. [Docket No. 572].

Under the Court’s order, all compensation for fees and expenses were made subject to Court

approval under section 330 of the Bankruptcy Code, the federal and local rules of bankruptcy

procedures, and other applicable guidelines and case law. LTPC’s Application is supported by

the Affidavit of John Volney attached as Exhibit A.

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A. Summary of Work Performed and Results Achieved.

7. In June 2011, the Trustee (represented by LTPC) filed Adversary Proceeding

No. 11-03397 against former professionals and others affiliated with Debtor, including Olshan.

After responding to and arguing Olshan’s first round of motions to dismiss, and after filing his

First Amended Complaint and responding to Olshan’s second round of motions to dismiss, the

Trustee reached a monetary settlement with Mr. Adler and Olshan Grundman on May 19, 2014.

On May 28, 2014, the Trustee filed his motion for order approving the settlement. [Docket

No. 1013].

B. Summary of Expenses Incurred.

8. In providing professional services to the Trustee, LTPC has incurred actual and

necessary expenses in satisfaction of which LTPC has advanced and disbursed funds, and for

which LTPC now requests reimbursement.1 As set forth in the invoice attached as Exhibit B, the

actual and necessary expenses incurred by LTPC on behalf of the Trustee during the Application

Period amount to $2,958.01. The expenses incurred by LTPC are charged at the actual cost by

LTPC on a pass-through basis, with no mark-up or profit by LTPC. The expenses sought to be

reimbursed include the following categories:

• Transcripts from Crim. Trial $1,954.00 • Westlaw/Internet Search Service $ 522.94 • Copies/Duplication Costs $ 287.70 • Postage $ 136.99 • Courier Charges $ 55.27 • Long Distance Telephone $ 1.11

Total: $2,958.01

1 The Trustee previously reimbursed some of the expenses requested here by check in July 2012. LTPC refunded that amount to the Trustee upon determining that the reimbursement occurred without Court approval.

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The Invoice sets forth the date the expense was incurred or billed and the nature and

amount of the expense. No request is made for overhead expenses. The bulk of the expenses

sought to be reimbursed is related to obtaining transcripts of certain testimony from the parallel

criminal trial, which the undersigned counsel believed was necessary to successfully evaluate the

case for settlement. Copies were necessary to serve pleadings on various parties and to

disseminate documents to various interested parties as well as to prepare for the mediation

conducted with Olshan. Throughout this case, pleadings have been served on the parties in

interest. A copy service was used when it could provide services more cheaply than LTPC could

provide the same services in-house. Long distance phone calls were necessary to communicate

with various parties with interests in the case and in responding to requests for information from

various interested parties. LTPC incurred postage charges in connection with service of

documents on certain defendants who are not subscribers to the Court’s ECF system.

Computerized research has been utilized only when a professional believes that the benefits of

computerized research outweigh the cost of such research and that the costs will be less than

those incurred in utilizing more traditional research methods. Necessary computerized research

was extensive.

IV. RELIEF REQUESTED

9. By this Application, LTPC respectfully requests that the Court allow

compensation for professional services rendered by LTPC during the Application Period

pursuant to 11 U.S.C. § 330. In total, this Application requests allowance of compensation in the

amount of $1,000,000, along with expenses incurred during the Application Period of $2,958.01,

for a total requested allowance of $1,002,958.01.

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10. The Bankruptcy Code specifically authorizes the bankruptcy court to approve the

employment and compensation of special counsel on a contingency fee basis. 11 U.S.C.

§ 328(a); Daniels v. Barron (In re Barron), 325 F.3d 690 (5th Cir.2003) (“Under 11 U.S.C.

§ 330, attorneys’ fees are reviewed for their reasonableness after representation has concluded.

In contrast, Section 328 ... allows an attorney seeking to represent a bankruptcy estate to obtain

prior court approval of her compensation plan.”). As explained above, the Trustee (represented

by LTPC) filed suit against and then settled with Mr. Adler and his law firm for $1,000,000 in

cash. Upon approval of the settlement, the net monetary recovery to the Liquidating Trust will be

$3,000,000, with LTPC owed a contingent fee of $1,000,000.

11. To the extent that Court considers the factors listed in Johnson v. Georgia

Highway Express, Inc., 488 F.2d 714, 717–19 (5th Cir. 1974) (the “Johnson Factors”) in

evaluation LTPC’s requested contingent fee, those factors support the award.

12. The Time and Labor Required. LTPC’s fee was a contingent fee for the work

performed. LTPC provided its services efficiently to allow the Trustee to continue this

bankruptcy case without undue delay.

13. The Novelty and Difficulty of the Questions Presented. LTPC’s employment

required them to perform services within their area of expertise, namely litigating business tort

claims against Debtor’s former lawyer and his law firm.

14. The Skill Required to Perform the Services. LTPC believes that its skill in

litigating business tort claims such as the claims alleged against Mr. Adler and his firm

contributed substantially to the settlement.

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15. Preclusion of Other Employment Due to Acceptance of the Case. While

LTPC has devoted substantial time and effort to its representation of the Trustee in the adversary

proceeding, LTPC has not been precluded from accepting other employment.

16. The Customary Fee. The amount of compensation sought herein has been

computed pursuant to a customary contingent fee. The fee charged for LTPC’s services in this

case is equal to or less than the rates charged by other professionals of similar reputation.

17. Whether the Fee is Fixed or Contingent. LTPC’s fee is set according to

contingent, as previously approved by the Court.

18. Time Limitations Imposed by the Client or Other Circumstances. The best

interests of the creditors were served by pushing the case and settlement forward in order to

minimize expenses.

19. The Experience, Reputation, and Ability of the Applicant. LTPC submits that

it is respected for its skill in litigating business disputes. It is the Applicant’s belief that its

reputation is recognized and respected.

20. The “Undesirability” of the Case. Working on behalf of the Trustee in this case

has not been undesirable. However, LTPC’s fee is subject to approval by the Court and is

contingent upon a recovery.

21. The Nature and Length of the Professional Relationship with the Client.

LTPC worked with the Trustee throughout the existence of the adversary proceeding. LTPC had

no prior dealings with the Debtor or the Trustee.

22. The Amount Involved and the Results Obtained. The amount of LTPC’s

contingent fee is calculated pursuant to the methodology previously approved by the Court.

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V. COMPLIANCE WITH FED. R. BANK. P. 2016(a)

23. LTPC does not now hold or represent, and has not held or represented at any time

during the Application Period or otherwise, any interest adverse to the Trustee or the Estate with

respect to the matters for which it has been employed. LTPC is now, and has at all times

material hereto been, a “disinterested person” as that term is used and defined in the Bankruptcy

Code.

24. This is LTPC’s Third Application for payment of attorney’s fees and

reimbursement of expenses. LTPC received $250,221.80 in attorney’s fees and expenses

pursuant to its First and Second Applications.

25. No agreement or understanding exists between the Applicant and any other entity

for sharing of compensation received or to be received for services rendered in or in connection

with this Bankruptcy Case. Applicant shall not share or agree to share with any other entity the

compensation awarded in connection with this Application, if any.

26. No agreement or understanding prohibited by 18 U.S.C. § 155 has been made, or

will be made, by LTPC.

VI. NOTICE

27. A copy of this Application, together with exhibits, is being transmitted, inter alia,

(i) electronically by the Clerk of Court through the CM/ECF system to all parties receiving such

notice in this Bankruptcy Case and (ii) to the Office of the United States Trustee. A copy of this

Application without exhibits is being sent via regular United States mail, postage prepaid, to the

parties appearing on the master mailing matrix for this case. Accordingly, all parties entitled to

receive notice of this Application have received such notice. LTPC respectfully submits that no

additional notice of this Application is necessary under the circumstances.

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28. Any party that was not served with a copy of the exhibits to this Application

may obtain a copy of such exhibits by mailing a written request to the undersigned counsel

on or before the Objection Deadline set forth on the first page of this Application.

VII. PRAYER BASED UPON THE FOREGOING, LTPC respectfully requests that the Court enter an

order in substantially the form of that attached hereto as Exhibit C:

i. granting this Application;

ii. allowing compensation for professional services rendered by LTPC as special counsel to the Trustee during the Application Period in the total amount of $1,000,000;

iii. allowing reimbursement of LTPC’s expenses in the amount of $2,958.01; and

iv. awarding Applicant such other and further relief to which it may be justly entitled.

Date: June 3, 2014 Respectfully submitted,

/s/ John Volney Jeffrey M. Tillotson, P.C. (jmt@lynnllp.com) Texas Bar No. 20039200 Eric W. Pinker, P.C. (epinker@lynnllp.com) Texas Bar No. 16016550 John Volney (jvolney@lynnllp.com) Texas Bar No. 24003118 LYNN TILLOTSON PINKER & COX, L.L.P. 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile ATTORNEYS FOR MATTHEW D. ORWIG, LIQUIDATING TRUSTEE

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the above and foregoing document has been served either via ECF on counsel of record or via first class United States mail, prepaid, on the attached Limited Service List on June 3, 2014.

/s/ John Volney John Volney

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ERIN MARIE SCHMIDT OFFICE OF THE U.S. TRUSTEE 1100 COMMERCE ST., RM. 976 DALLAS, TX 75242

SECURITIES & EXCHANGE COMMISSION c/o ROSE L. ROMERO, REG. DIRECTOR BURNETT PLAZA, SUITE 1900 801 CHERRY STREET, UNIT 18 FORT WORTH, TX 76102

MATTHEW D. ORWIG CHAPTER 11 TRUSTEE JONES DAY 2727 NORTH HARWOOD STREET DALLAS, TEXAS 75201-1515

PETER FRANKLIN, DOUG SKIERSKI FRANKLIN SKIERSKI HAYWARD, 10501 N CENTRAL EXPY, STE 106 DALLAS, TX 75231

ARKADIY GRINSHPUN 7909 BUSTLETON AVENUE PHILADELPHIA, PA 19152

GARY B. FREEDMAN 7909 BUSTLETON AVENUE PHILADELPHIA, PA 19152

INTERNAL REVENUE SERVICE SPECIAL PROCEDURES - INSOLVENCY P.O. BOX 21126 PHILADELPHIA, PA 19114

OLSHAN GRUNDMAN FROME ROSENZWEIG &WOLOSKY LLP PARK AVENUE TOWER 65 EAST 55TH ST. NEW YORK, NY 10022

PATTON BOGGS ATTN: CASS WEILAND, ESQ. 2000 MCKINNEY AVE, SUITE 1700 DALLAS, TEXAS 75201

HULSE & STUCKI ATTN: JAY R. STUCKI 2912 WEST STORY ROAD IRVING, TX 75038

BASHEER GHORAYEB JONES DAY 2727 NORTH HARWOOD STREET DALLAS, TEXAS 75201-1515

DOWNEY BRAND LLP 427WEST PLUMB LN. RENO, NV 89509

JAMES W. PUZEY LAW OFFICES OF JAMES W. PUZEY P.O. BOX 70172 RENO, NV 89570

FIRSTLINE MORTGAGE v.RUTGERS C/O ROBERT JOHNSON LAW CORP 34197 PACIFIC COAST HIGHWAY STE 100 DANA POINT, CA 92629

SECORE &WALLER, LLP ATTN: WAYNE M. SECORE FOUR FOREST 12222 MERIT DR., #1350 DALLAS, TX 75251

JOHN CLARSON 4200 RANIER COURT FORTH WORTH, TX 76109

BUCKNO LISICKY &COMPANY ATTN: TONY BUCKNO 1524 LINDEN STREET ALLENTOWN, PA 18102-4251

RUTGERS INVESTMENT 3965 PHELAN BLVD, # 209 BEAUMONT, TX 77707-2232

PATRICK JOHN HETHCOAT 1365 WAYNE WAY SAN MATEO, CA 94403-1565

ROBERT O’NEAL 324 N. 23RD STREET BEAUMONT, TX 77707

ANGELA DODD SECURITIES AND EXCHANGE COMM 175 WEST JACKSON BLVD SUITE 900 CHICAGO, ILLINOIS 60604

GEORGE H. TARPLEY COX SMITH MATTHEWS INC. 1201 ELM ST., #3300 DALLAS, TX 75270

LAURIE SPINDLER HUFFMAN LINEBARGER GOGGAN BLAIR & SAMPSON, LLP 2323 BRYAN STREET, SUITE 1600 DALLAS, TX 75201

JAMES P. HANSON 5824 COLD WATER DRIVE CASTRO VALLEY, CA 94552-1807

ERIC A.LIEPINS ERIC A.LIEPINS, P.C. 12770 COIT ROAD, SUITE 950 DALLAS, TEXAS 75251

MICHAEL A. MCCONNELL KELLY HART &HALLMAN PC 201 MAIN STREET, SUITE 2500 FORT WORTH, TEXAS 76102

RONALD J. MILLER 772 WESTRAY DR. WESTERVILLE, OH 43081

JERRY C. CARTER JENKINS & CARTER 501 HAMMILL LANE RENO, NV 89511

NATHAN JENKINS JENKINS & CARTER 501 HAMMILL LANE RENO, NV 89511

DANIEL J. SHERMAN SHERMAN & YAQUINTO, LLP 509 N. MONTCLAIR AVENUE DALLAS, TEXAS 75208

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LEPERCQ CORPORATE INCOME FUND C/O DAVID F. STABER and CLAYTON D. KETTER AKIN GUMP, ET AL., LLP 1700 PACIFIC AVE., #4100 DALLAS, TX 75201

DUSTIN L. PAYNE, ATTORNEY 6777 CAMP BOWIE BLVD., SUITE 215 FORT WORTH, TEXAS 76116

WILLIAM MAXWELL C/O WILLIAM MAXWELL, PLLC 1300 MCGOWAN HOUSTON, TX 77004

DANIEL P. ELMS, HEATHER H. JOBE BELL NUNNALLY &MARTIN LLP 1400ONE MCKINNEY PLAZA 3232 MCKINNEY AVENUE DALLAS, TEXAS 75204-2429

JAMES HANSON C/O DANIEL J. SHERMAN SHERMAN & YAQUINTO, L.L.P. 509 N. MONTCLAIR AVENUE DALLAS, TX 75208-5498

DERREL LUCE LAW OFFICE OF DERREL LUCE 4600 BOSQUE BLVD., SUITE 2B WACO, TEXAS 76710

BOWNE OF DALLAS, L.P. C/O GAIL B. PRICE, BRONWEN PRICE 2600 MISSION ST., #206 SAN MARINO, CA91108

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION In re: § Chapter 11 § FIRSTPLUS FINANCIAL GROUP, INC., § Case No. 09-33918-HDH § Debtor. §

ORDER ALLOWING THIRD APPLICATION OF LYNN TILLOTSON PINKER & COX, LLP FOR ALLOWANCE OF

COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM SEPTEMBER 1, 2012 THROUGH APRIL 30, 2014

Came on for consideration this _____ day of _______________, 2014, the Third

Application of Lynn Tillotson Pinker & Cox, LLP for Allowance of Compensation and

Reimbursement of Expenses (the “Application”) filed on June 3, 2014 [Docket No. ___]. After

due notice and hearing, this Court having considered such Application, the representations of

Lynn Tillotson Pinker & Cox, LLP and all matters on file, the Court finds and concludes that the

fees and expenses set forth in the Application are reasonable and necessary and good cause exists

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for the allowance thereof. The Court finds that all necessary parties were served with notice of

the Application, that no further notice need be given, and that no objection or responsive

pleading was filed. It is therefore,

ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded Attorney’s

Fees in the amount of $1,000,000.00 representing its contingency fee interest of the Liquidating

Trust’s settlement with Olshan Frome Wolosky LLP f/k/a Olshan Grundman Frome Rozenzweig

& Wolosky, LLP and David Adler. It is further

ORDERED that Lynn Tillotson Pinker & Cox, LLP be and hereby is awarded

Reimbursement of Expenses in the amount of $2,958.01. It is further

ORDERED that the Trustee is hereby authorized to pay Lynn Tillotson Pinker & Cox,

LLP the amount of $1,002,958.01 as third interim payment.

### END OF ORDER###

Order drafted by: John Volney (jvolney@lynnllp.com) Lynn Tillotson Pinker & Cox, LLP 2100 Ross Avenue, Suite 2700 Dallas, Texas 75201 (214) 981-3800 Telephone (214) 981-3839 Facsimile Attorney for Matthew D. Orwig, Liquidating Trustee for the Estate of FirstPlus Financial Group, Inc.

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