CALDERWOOD & HARKNESS LLP Attorneys at Law
599 Lexington Avenue, 34th Floor New York, New York 10022 Telephone: (212) 801-4400 Facsimile: (212) 801-4401 www.calderwoodharkness.com
September 11, 2023
VIA HAND DELIVERY AND ELECTRONIC MAIL
Mr. Jonathan R. Caldwell 440 East 72nd Street, Apt. 18D New York, New York 10021
Dear Mr. Caldwell:
Thank you for selecting Calderwood & Harkness LLP (the "Firm") to represent you in the matter described below. We are pleased that you have placed your confidence in our Firm, and we look forward to providing you with the highest quality of legal representation. The purpose of this letter is to confirm the terms and conditions of our engagement and to set forth the mutual understandings between you and the Firm regarding the scope of our representation, our fee arrangements, and the respective obligations of the parties. This letter memorializes the discussion we had during our initial consultation on September 5, 2023, during which you described in detail the circumstances giving rise to the claims outlined below. Upon your review and countersignature, this letter will constitute the binding agreement between you and the Firm governing our professional relationship in connection with this matter.
We encourage you to review the terms of this letter carefully. Should you have any questions or concerns regarding any of the provisions set forth below, please do not hesitate to contact me directly before signing.
1. SCOPE OF REPRESENTATION
1.1 Description of the Matter
The Firm will represent Jonathan R. Caldwell ("Client" or "you"), individually and in your capacity as the sole member and manager of Caldwell Urban Ventures LLC (EIN: 86-4031278), a New York single-member limited liability company (collectively, "Caldwell"), in connection with the prosecution of claims against the following parties (collectively, the "Adverse Parties"):
(a) Marcus D. Whitfield, individually, residing at 88 Montague Street, Penthouse B, Brooklyn, New York 11201; and
(b) Pinnacle Greystone Capital LLC (EIN: 83-2917465), a New York limited liability company with principal offices at 330 Furman Street, Suite 410, Brooklyn, New York 11201, of which Mr. Whitfield is the sole member and manager.
The claims to be prosecuted on your behalf include, but are not necessarily limited to, claims for common-law fraud, fraudulent inducement, constructive fraud, breach of fiduciary duty, unjust enrichment, and such other related claims as may be appropriate based on the facts as they develop during the course of the litigation (the "Claims"). The Firm reserves the right, in consultation with you, to add or modify causes of action as warranted by the evidence developed during discovery or otherwise.
The Claims arise from alleged material misrepresentations and the concealment of material information by Mr. Whitfield and Pinnacle Greystone Capital LLC in connection with a joint co-investment in the acquisition and development of real property located at 540-548 Atlantic Avenue, Brooklyn, New York 11217 (the "Subject Property"). The co-investment was structured through Atlantic Yards Development Partners LLC (EIN: 87-1253946), a New York limited liability company formed on April 22, 2021 (the "Development Entity"), in which Caldwell Urban Ventures LLC holds a forty percent (40%) membership interest and Pinnacle Greystone Capital LLC holds a sixty percent (60%) membership interest. The total co-investment for the acquisition of the Subject Property was Fourteen Million Eight Hundred Thousand Dollars ($14,800,000), with your total committed equity contribution amounting to Five Million Nine Hundred Twenty Thousand Dollars ($5,920,000), representing your forty percent (40%) share.
As described during our initial consultation and as reflected in the documents you have provided to date, the alleged fraudulent conduct of the Adverse Parties includes, without limitation, the following:
(a) The concealment of approximately One Million Three Hundred Forty Thousand Dollars ($1,340,000) in outstanding New York City real property tax liens encumbering the Subject Property, which liens were not disclosed to you prior to or at the time of the co-investment closing;
(b) The suppression of a Phase II environmental site assessment that revealed the need for approximately Six Hundred Twenty Thousand Dollars ($620,000) in required environmental remediation at the Subject Property, which assessment was in Mr. Whitfield's possession prior to the closing but was not shared with you or your advisors;
(c) The inflation of a pro forma rent roll for the Subject Property by approximately Five Hundred Eighty Thousand Dollars ($580,000) per year (representing an approximately 26.9% overstatement of projected rental income), upon which you relied in evaluating the economics of the co-investment; and
(d) The existence of an undisclosed consulting agreement between Pinnacle Greystone Capital LLC and Glenmore Realty Advisors Inc. in the amount of Three Hundred Seventy Thousand Dollars ($370,000), the terms and existence of which were not disclosed to you prior to or at the closing, and which created a material undisclosed conflict of interest.
The foregoing description of the Claims is based upon information currently known to us. As additional facts are developed during the course of the representation, the specific claims, theories of liability, and factual bases may be refined or supplemented in consultation with you.
1.2 Scope Limitations
Our representation is expressly limited to the prosecution of the Claims as described in Section 1.1 above. Without limiting the generality of the foregoing, the scope of this engagement does not include, and the Firm does not undertake to provide, representation or advice in connection with any of the following:
(a) Tax advice or tax planning of any kind, whether relating to Caldwell Urban Ventures LLC, Atlantic Yards Development Partners LLC, the Subject Property, or otherwise;
(b) Transactional matters relating to Caldwell Urban Ventures LLC, Atlantic Yards Development Partners LLC, the Subject Property, or any other business entity or real estate investment in which you hold an interest;
(c) Any dispute, claim, or proceeding involving Broadmark Commercial Lending Corp., the senior lender on the Subject Property, whether arising under the loan documents, any guaranty, or otherwise;
(d) Any regulatory matters, including without limitation matters involving the New York City Department of Buildings, the New York State Department of Environmental Conservation, or any other federal, state, or local governmental agency;
(e) Any criminal proceedings, investigations, or inquiries, whether related or unrelated to the subject matter of the Claims; and
(f) Any other matter not expressly described in Section 1.1 of this letter.
Any expansion of the scope of our representation beyond the Claims described in Section 1.1 will require a separate written agreement or a written amendment to this letter, executed by both parties. You should retain separate counsel for any matters falling outside the scope of this engagement. The Firm does not undertake to advise you on any business decisions regarding the Subject Property, the Development Entity, or the co-investment relationship with Mr. Whitfield and Pinnacle Greystone Capital LLC, except insofar as such matters are directly relevant to the litigation strategy in connection with the Claims.
1.3 Venue and Governing Law
Based upon our preliminary assessment of the Claims, we anticipate that the action will be commenced in the Supreme Court of the State of New York, Kings County, which we believe to be an appropriate forum given the location of the Subject Property, the domicile of the Adverse Parties, and the nature of the claims. The substantive law governing the Claims is expected to be the law of the State of New York. We will, of course, evaluate all jurisdictional and venue considerations as the matter develops and will consult with you before making any final determination regarding the forum in which the action will be filed.
2. ENGAGEMENT TEAM
2.1 Responsible Partner
Douglas Carmichael, Partner, will serve as the responsible partner overseeing all aspects of the engagement. Mr. Carmichael will be principally responsible for the overall litigation strategy, major client communications, significant court appearances, and the supervision of all work performed by other members of the engagement team. Mr. Carmichael will serve as your primary point of contact at the Firm with respect to this matter.
2.2 Billing Partner
Francesca Morano, Partner, will serve as the billing partner responsible for the review of all invoices and billing administration in connection with this engagement. In addition to her billing responsibilities, Ms. Morano will provide substantive legal work on the matter, drawing on her extensive experience in complex commercial litigation and real estate-related disputes. Ms. Morano will review and approve all monthly invoices before they are transmitted to you.
2.3 Lead Associate
Patrick Gallagher, Senior Associate, will serve as the lead associate responsible for the day-to-day management of the litigation. Mr. Gallagher's responsibilities will include legal research, the drafting of pleadings and motions, the management and conduct of discovery, preparation of deposition outlines and witness preparation, and general case preparation. Mr. Gallagher will work under the direct supervision of Mr. Carmichael and Ms. Morano.
2.4 Working Associate
Simone Laroche, Associate, will provide additional support in legal research, document review, and the preparation of litigation materials as needed throughout the course of the engagement. Ms. Laroche will work under the supervision of Mr. Gallagher and the partners assigned to the matter.
2.5 Additional Personnel
The Firm reserves the right to assign additional attorneys, paralegals, law clerks, or other support staff to the matter as the needs of the engagement require. Any additional personnel assigned to the matter will be billed at their applicable billing rates as set forth in Section 3 below. The Firm will provide you with prior notice of the assignment of any additional attorneys to the engagement team and will inform you of their applicable billing rates at that time.
3. FEES AND BILLING ARRANGEMENTS
3.1 Hourly Billing
The Firm will bill for its professional services on an hourly basis. The current hourly billing rates for the attorneys assigned to this matter are as follows:
In the event that paralegal or legal assistant time is required in connection with the matter, such time will be billed at rates ranging from $250.00 to $375.00 per hour, depending on the experience level and seniority of the individual performing the work.
The foregoing rates are the Firm's standard rates currently in effect for the individuals listed above. These rates are subject to annual adjustment, which typically takes effect on January 1 of each calendar year. The Firm will provide you with written notice of any changes to the applicable billing rates at least thirty (30) days prior to the effective date of any such change. Any rate adjustments will apply only to services rendered on or after the effective date of the new rates and will not be applied retroactively.
3.2 Billing Increments
Professional time will be recorded and billed in increments of one-tenth (0.1) of an hour (i.e., six-minute increments). Each task performed by an attorney or other timekeeper will be recorded separately with a description of the work performed sufficient to allow you to evaluate the nature and extent of the services rendered.
3.3 Disbursements and Expenses
In addition to professional fees for legal services, you will be responsible for the reimbursement of all reasonable disbursements and out-of-pocket costs incurred by the Firm in connection with the matter. Such disbursements and expenses include, but are not limited to, the following:
(a) Court filing fees, index number purchase fees, and related court costs;
(b) Process service fees, including fees charged by professional process servers or the United States marshals Service;
(c) Mediation fees, arbitration fees, and fees of any alternative dispute resolution provider, if applicable;
(d) Expert witness fees, including fees and costs of appraisers, forensic accountants, environmental consultants, real estate valuation experts, and any other experts retained in support of the litigation;
(e) Deposition costs, including court reporter fees, videographer fees, and transcript costs;
(f) Travel expenses reasonably incurred in connection with the matter, including transportation, lodging, and meals;
(g) Photocopying, printing, scanning, and document reproduction charges;
(h) Electronic legal research charges, including charges for Westmark Data Systems, Sundial Solutions, PACER, and similar services;
(i) Courier, overnight delivery, and postage charges; and
(j) Any other costs or expenses reasonably incurred in connection with the prosecution of the Claims.
The Firm will endeavor to exercise reasonable judgment and economy in incurring disbursements. No individual disbursement exceeding Five Thousand Dollars ($5,000.00) will be incurred without your prior written or verbal approval, except in circumstances where delay in incurring the expense would materially prejudice your interests in the litigation.
3.4 Invoicing and Payment Terms
The Firm will render monthly invoices, typically within fifteen (15) business days following the close of each calendar month. Each invoice will contain a detailed description of the professional services rendered and the disbursements incurred during the preceding billing period, including the date of each service, the identity of the timekeeper performing the work, a description of the work performed, and the time expended.
Payment of each invoice is due within thirty (30) calendar days of the invoice date. Payments should be made by wire transfer to the Firm's operating account or by check made payable to "Calderwood & Harkness LLP." Wire transfer instructions will be provided upon request.
Any balance remaining unpaid more than thirty (30) days after the invoice date may, at the Firm's discretion, accrue interest at the rate of one percent (1.0%) per month, which is equivalent to twelve percent (12%) per annum, calculated from the invoice date until the date of payment. The Firm reserves the right, in its sole discretion, to waive the imposition of interest in any particular instance.
In the event that invoices remain unpaid for more than sixty (60) days, the Firm reserves the right to suspend work on the matter and/or to withdraw from the representation in accordance with applicable rules of professional conduct, as further described in Section 8 below. The Firm will provide you with written notice and a reasonable opportunity to cure any payment delinquency before exercising such rights.
3.5 Retainer. No initial retainer deposit is required at the outset of this engagement. The Firm will rely on your timely payment of monthly invoices as set forth in Section 3.4 above. Notwithstanding the foregoing, the Firm reserves the right to request a retainer deposit at any point during the engagement if billing becomes irregular, if invoices remain outstanding beyond the payment terms set forth herein, or if substantial costs are anticipated in connection with trial preparation, expert retention, or other significant phases of the litigation. Any retainer deposit received will be held in the Firm's Interest on Lawyer Account (IOLA) trust account and will be applied against outstanding invoices in accordance with applicable ethical rules. Any unused portion of a retainer deposit will be returned to you upon conclusion or termination of the engagement.
3.6 No Guarantee of Outcome
You understand and acknowledge that the fee arrangement set forth in this engagement letter reflects compensation for professional legal services rendered by the Firm and does not constitute, and shall not be construed as, a guarantee, warranty, or representation regarding any particular result, recovery, judgment, settlement, or outcome in the matter. Litigation is inherently uncertain, and while the Firm will exercise its best professional judgment in prosecuting the Claims on your behalf, the Firm cannot and does not predict or guarantee the outcome of the litigation or any proceeding related thereto.
4. CLIENT RESPONSIBILITIES
In order to enable the Firm to represent your interests effectively and efficiently, you agree to the following:
(a) Cooperation and Information. You agree to cooperate fully with the Firm throughout the course of the engagement, including by providing all documents, information, correspondence, records, and data in your possession, custody, or control that are relevant to the Claims, whether favorable or unfavorable, in a timely manner upon request. Complete and candid communication between you and the Firm is essential to effective representation, and you agree to provide the Firm with truthful, accurate, and complete information at all times.
(b) Availability. You agree to make yourself reasonably available for meetings, telephone conferences, depositions, court appearances, mediation sessions, and any other proceedings or events requiring your participation. The Firm will endeavor to provide you with reasonable advance notice of all such commitments, and you agree to accommodate the schedule of the litigation to the extent practicable.
(c) Notification of Developments. You agree to promptly inform the Firm of any developments that may be relevant to the matter, including without limitation any communications from or with Marcus D. Whitfield, Pinnacle Greystone Capital LLC, Glenmore Realty Advisors Inc., Broadmark Commercial Lending Corp., Atlantic Yards Development Partners LLC, or any third party relating to the Subject Property, the co-investment, or the Claims. You further agree to refrain from discussing the substance of the Claims with any adverse party or their representatives without first consulting with the Firm.
(d) Decision-Making Authority. You retain full authority over all key decisions in the matter, including but not limited to decisions to accept or reject any settlement offer, to proceed to trial, and to pursue or forego any particular claim or remedy. The Firm will provide you with its professional advice and recommendations regarding such decisions, but the ultimate decision-making authority on all material aspects of the litigation rests with you.
5. CONFLICTS OF INTEREST
The Firm has conducted a thorough conflicts check in accordance with its internal procedures and the requirements of the New York Rules of Professional Conduct. Based upon that review, the Firm has identified no existing conflicts of interest that would preclude or limit the Firm's ability to undertake this representation as of the date of this letter.
Specifically, the Firm confirms that it has no current or prior attorney-client relationship with Marcus D. Whitfield, Pinnacle Greystone Capital LLC, or any entity known to be affiliated with Mr. Whitfield or Pinnacle Greystone Capital LLC. The Firm does not currently represent, and has not previously represented, Broadmark Commercial Lending Corp., Glenmore Realty Advisors Inc., or any other party known to be involved in the underlying transaction giving rise to the Claims. The Firm has also confirmed that no member of the engagement team has any personal or financial interest that would create a conflict with the representation.
In the event that a conflict of interest arises during the course of the engagement, whether actual or potential, the Firm will promptly notify you in writing and will take all appropriate steps in accordance with the New York Rules of Professional Conduct, including obtaining any necessary waivers or, if the conflict cannot be waived or cured, withdrawing from the representation in accordance with Section 8 of this letter.
6. CONFIDENTIALITY
All communications between you and the Firm, whether oral, written, or electronic, are protected by the attorney-client privilege and will be treated as strictly confidential by the Firm and all of its attorneys, staff, and personnel. The Firm recognizes the sensitive nature of the information you will share in connection with this engagement and is committed to safeguarding the confidentiality of that information at all times.
The Firm will not disclose any confidential information received from you or on your behalf to any third party without your prior written consent, except in the following limited circumstances:
(a) As required by law, court order, or subpoena;
(b) As reasonably necessary to carry out the representation, including in court filings, discovery responses, depositions, and other proceedings in which disclosure is required or appropriate in connection with the prosecution of the Claims; and
(c) As permitted under the applicable New York Rules of Professional Conduct.
The Firm's duty of confidentiality survives the termination of the engagement, regardless of the reason for termination, and will continue in perpetuity unless you provide written consent to disclosure or disclosure is otherwise required by law.
7. DOCUMENT RETENTION
The Firm will maintain your files relating to this matter, including both physical and electronic documents, for a period of seven (7) years following the closure of the matter. For purposes of this Section, the matter will be deemed "closed" upon the final resolution of all Claims, the exhaustion or expiration of all appeal periods, and the completion of any post-judgment proceedings.
Upon closure of the matter, the Firm will offer to return to you all original client documents contained in the file, including original contracts, agreements, correspondence, and other materials provided by you to the Firm during the course of the engagement. The Firm will provide you with written notice of its intent to dispose of the file, and you will have ninety (90) calendar days from the date of such notice to claim and retrieve your original documents. Documents not claimed within such ninety (90) day period may be disposed of by the Firm in accordance with its standard document retention and destruction policy, including secure shredding of physical documents and secure deletion of electronic files.
Notwithstanding the foregoing, the Firm may retain copies of all documents in the file, including work product, correspondence, pleadings, and other materials, subject to the Firm's continuing obligations of confidentiality as set forth in Section 6 of this letter. Such retained copies may be maintained for the Firm's internal records, conflict-checking purposes, and professional responsibility compliance.
8. TERMINATION OF ENGAGEMENT
8.1 Client's Right to Terminate
You may terminate this engagement at any time, for any reason or for no reason, upon written notice to the Firm. The Firm acknowledges that the decision to continue or discontinue the attorney-client relationship is ultimately yours to make, and the Firm will respect any such decision without condition. Upon termination by you, the Firm will take the steps described in Section 8.3 below to protect your interests and facilitate the transition to successor counsel, if applicable. Notwithstanding any such termination, you remain responsible for the payment of all fees for professional services rendered and all disbursements incurred or advanced by the Firm through the date of termination, in accordance with the fee arrangements set forth in Section 3 of this letter.
8.2 Firm's Right to Withdraw
The Firm may withdraw from the representation upon reasonable written notice to you and for good cause. Good cause for withdrawal includes, but is not limited to, the following:
(a) Non-payment of fees or failure to comply with the payment terms set forth in Section 3.4 of this letter, after written notice and a reasonable opportunity to cure;
(b) Failure to cooperate with the Firm or to comply with the client responsibilities set forth in Section 4 of this letter;
(c) The existence of an irreconcilable conflict of interest that cannot be waived or cured in accordance with the New York Rules of Professional Conduct;
(d) Your insistence upon a course of action that the Firm reasonably believes to be contrary to law or to the Firm's professional obligations; or
(e) Any other circumstance that would make continued representation unreasonably difficult or ethically impermissible.
Any withdrawal by the Firm will be effected in compliance with all applicable court rules and the New York Rules of Professional Conduct. If the matter is pending before any court at the time of the Firm's withdrawal, the Firm will file a motion for leave to withdraw as counsel of record and will continue to represent you until such motion is granted by the court or until successor counsel has entered an appearance on your behalf, unless otherwise directed by the court.
8.3 Obligations Upon Termination
Upon termination of the engagement by either party or withdrawal by the Firm, the Firm will take all reasonable steps to protect your interests, including:
(a) Promptly returning to you, or to your designated successor counsel, all original client documents and any client property in the Firm's possession;
(b) Providing you or your successor counsel with copies of all relevant work product, pleadings, correspondence, and other materials in the Firm's files that are reasonably necessary for the continuation of the matter;
(c) Cooperating with successor counsel to facilitate a smooth and orderly transition of the matter; and
(d) Complying with any applicable court orders or rules governing the substitution or withdrawal of counsel.
The Firm's obligations of confidentiality as set forth in Section 6 will continue in full force and effect following termination or withdrawal.
9. LIMITATION OF LIABILITY
To the fullest extent permitted by applicable law and the New York Rules of Professional Conduct, the Firm's aggregate liability to you for any and all claims arising out of or in connection with this engagement, whether based in contract, tort, negligence, professional malpractice, or otherwise, shall not exceed the total amount of fees actually paid by you to the Firm in connection with this matter, except in cases of the Firm's gross negligence or willful misconduct. This limitation of liability shall apply regardless of the form or nature of the claim and shall survive the termination of the engagement.
You further agree that you will not assert any claim against the Firm arising out of or in connection with this engagement more than two (2) years after the date of the act or omission giving rise to such claim, regardless of when the claim is discovered or could reasonably have been discovered, to the maximum extent permitted by applicable law.
Nothing in this Section is intended to limit or modify the Firm's obligations under the New York Rules of Professional Conduct or any non-waivable duties imposed by applicable law.
10. GOVERNING LAW AND DISPUTE RESOLUTION
This engagement letter shall be governed by and construed in accordance with the laws of the State of New York, without regard to its conflict of laws principles.
Any dispute, controversy, or claim arising out of or in connection with this engagement letter or the Firm's representation of you in the matter described herein, including any dispute regarding the Firm's fees or the quality of the Firm's services, shall be resolved by binding arbitration conducted in the Borough of Manhattan, New York, New York, in accordance with the Commercial Arbitration Rules of the American Arbitration Association then in effect, unless the parties mutually agree in writing to an alternative dispute resolution mechanism. The arbitration shall be conducted before a single arbitrator who shall be a retired judge or an attorney with at least twenty (20) years of experience in complex commercial litigation. Judgment upon the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. Each party shall bear its own costs and attorney's fees in connection with any such arbitration, unless the arbitrator determines otherwise.
Notwithstanding the foregoing, the Firm shall retain the right to pursue collection of unpaid fees and disbursements through the courts of competent jurisdiction, including the Supreme Court of the State of New York, New York County, without first submitting such claims to arbitration.
11. ENTIRE AGREEMENT AND AMENDMENTS
This engagement letter constitutes the entire agreement between you and the Firm with respect to the engagement described herein and sets forth the complete understanding of the parties regarding the terms and conditions of the Firm's representation. This letter supersedes all prior oral or written communications, discussions, understandings, representations, and agreements between the parties relating to the subject matter hereof.
This engagement letter may not be amended, modified, or supplemented except by a written instrument signed by both you and a duly authorized partner of the Firm. No waiver of any provision of this letter shall be effective unless made in writing and signed by the party against whom enforcement of the waiver is sought. The failure of either party to enforce any provision of this letter shall not constitute a waiver of such party's right to enforce that provision or any other provision in the future.
If the terms of this engagement letter are acceptable to you, please sign and date the acknowledgment below and return a signed copy of this letter to my attention at the address above, or via electronic mail to dcarmichael@calderwoodharkness.com. We will countersign the letter and return a fully executed copy to you for your records. We recommend that you retain the fully executed copy for your files.
We look forward to working with you on this matter and to vigorously advocating on your behalf. Please do not hesitate to contact me at any time if you have questions or wish to discuss any aspect of the engagement.
Very truly yours,
CALDERWOOD & HARKNESS LLP
By: ________
Name: Douglas Carmichael
Title: Partner
Direct Telephone: (212) 801-4418 Direct Facsimile: (212) 801-4419
Email: dcarmichael@calderwoodharkness.com
ACKNOWLEDGMENT AND AGREEMENT
I, Jonathan R. Caldwell, have read and understand the terms of this engagement letter dated September 11, 2023. I agree to be bound by its terms and conditions as set forth above, including the scope of representation, the fee and billing arrangements, the client responsibilities, the limitation of liability, and the arbitration provision. I acknowledge that I have had the opportunity to ask questions regarding the terms of this letter and that any such questions have been answered to my satisfaction. I further acknowledge that I have been advised of my right to consult with independent counsel regarding the terms of this engagement letter prior to signing.
AGREED AND ACCEPTED:
________________________________________
Jonathan R. Caldwell
Date: ________
Please return a signed copy of this letter to:
Douglas Carmichael, Partner Calderwood & Harkness LLP 599 Lexington Avenue, 34th Floor New York, New York 10022
Email: dcarmichael@calderwoodharkness.com
cc: Francesca Morano, Partner, Calderwood & Harkness LLP cc: Patrick Gallagher, Senior Associate, Calderwood & Harkness LLP
| Attorney | Position | Hourly Rate |
| Douglas Carmichael | Partner | $1,150.00 |
| Francesca Morano | Partner | $1,075.00 |
| Patrick Gallagher | Senior Associate | $725.00 |
| Simone Laroche | Associate | $550.00 |