EXHIBIT: FINANCIAL RECONCILIATION MATRIX
Case No: 49D11-2501-MF-00xxxx Source: Comparison of Plaintiff’s Affidavit (May 2025) vs. Sheriff’s Sale Report (Sept 2025)
I. REVENUE DISCREPANCY SUMMARY (THE “SURPLUS KILLER”)
| ITEM | PLAINTIFF ACCOUNTING | DEFENDANT AUDIT | DISCREPANCY (OVERCHARGE) | RATIONALE |
|---|---|---|---|---|
| Accrued Interest | $10,725.27 | $7,384.05 | $3,341.22 | Based on Plaintiff’s own $27.45/day per diem. |
| Property Taxes | $7,681.00 | $2,951.94 | $4,729.06 | Includes “Fall 2025” taxes not due until 11/10/25. |
| Pub/Admin Fees | $1,094.35 | $284.28 | $810.07 | Plaintiff claim vs. actual Sheriff Invoice. |
| Attorney Fees | $4,750.00 | $3,000.00 | $1,750.00 | Variance from sworn affidavit of 12 hours. |
| TOTAL | $24,250.62 | $13,620.27 | $10,630.35 | Total Funds Withheld from Defendant |
II. LINE-ITEM AUDIT NOTES
1. The Per Diem Calculation
- Plaintiff Per Diem: 4.31 (Note 2) = $27.45 Total Daily.
- Days Elapsed: 11/19/2024 to 08/15/2025 = 269 days.
- Calculated Interest: 7,384.05**.
- Plaintiff Claim: $10,725.27.
- Verdict: Plaintiff inflated the interest charge by 45% without providing a basis for the increase.
2. The Premature Tax Payment
- Plaintiff paid $7,681.00 on 08/04/2025.
- This amount included the Fall 2025 Installment ($4,729.06) which was not delinquent and not due for over 3 months.
- By paying ahead and charging it to the User’s judgment, the Plaintiff artificially reduced its cash liability to the Sheriff and effectively “stole” the User’s home equity to pay its own future taxes on the property it intended to buy.
3. Attorney Fees Conflict
- Plaintiff’s Attorney Michael Fair swore on May 13, 2025, that $3,000.00 was a “reasonable and customary” fee based on 12 hours of work.
- Final accounting shows total attorney-related charges of $4,750.00.
- Verdict: Recovery of attorney fees is limited to “actual and reasonable” fees incurred. Plaintiff overshot its own sworn “reasonable” limit by $1,750.00.
III. CONCLUSION
Plaintiff used “lazy” or “strategic” accounting to arrive at a sale price of 231,000, leaving a SURPLUS of ~$9,000 owed to the Defendant. This surplus represents the difference between a mitigated transition and the current state of homelessness.