I.

NARRATIVE IN SUPPORT OF FIRST FEE APPLICATION

PREPARED BY McKINDLES LAW FIRM, PLLC

CHAPTER 11 DEBTORS/ARIZONA APPLE ORCHARD, INC.

ADMINISTRATIVE:

During the reporting period, special counsel for the Debtor assisted Debtor and its

responsible party in the defense of an adversary action involving summary judgment proceedings

regarding the secured position of an estate creditor: Valley Farms, Ltd; and proceedings

regarding Debtor’s objection to the proof of claim filed by Valley Farms, Ltd, culminating in a

five (5) day Trial before the Honorable George Nielson.

FEE APPLICATION:

Special Counsel has prepared this Application in accordance with the Guidelines set forth

by the United States Trustee. In order to comply, Counsel had to confirm that all billing

statements and time entries were accurate and listed within the appropriate category order. A

complete description of Special Counsel’s fees by his hourly rate and a complete and detailed

listing of all costs incurred during this reporting period has been attached as Exhibit “A”. A

narrative summary had to be created and tailored to the specific facts of this case, including

information to provide that the services rendered were of benefit to the estate.