Fee application (first monthly) — Richards, Layton & Finger — In re KServicing (Bankr. D. Del.)

Record facts

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 327 · 2022-12-02 · Docket on CourtListener

Full text

RLF1 28301713v.1 
UNITED STATES BANKRUPTCY COURT 
DISTRICT OF DELAWARE 
------------------------------------------------------------ x 
 
In re 
: 
Chapter 11 
 
: 
 
KABBAGE, INC. d/b/a KSERVICING, et al., : 
Case No. 22-10951 (CTG) 
 
: 
 
 
: 
(Jointly Administered) 
 
 
Debtors.1 
: 
 
 
: 
Obj. Deadline: Dec. 22, 2022 at 4:00 p.m. (ET) 
------------------------------------------------------------ x 
 
FIRST MONTHLY APPLICATION OF RICHARDS, LAYTON & FINGER, P.A. FOR 
ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND FOR 
REIMBURSEMENT OF EXPENSES AS CO-COUNSEL TO THE DEBTORS  
FOR THE PERIOD FROM OCTOBER 3, 2022 THROUGH OCTOBER 31, 2022 
 
Name of Applicant: 
 
 
 
 
Richards, Layton & Finger, P.A. 
 
 
 
Authorized to Provide Professional Services to: 
the above-captioned debtors and 
 
 
 
 
 
 
 
 
 
debtors in possession  
 
 
 
 
Date of Retention:  
 
 
 
 
October 28, 2022, nunc pro tunc  
 
 
 
 
 
 
 
 
 
to October 3, 2022 
 
 
 
 
Period for which compensation 
and reimbursement are sought: 
 
 
October 3, 2022 through October 31, 2022  
 
Amount of Compensation sought as actual, 
reasonable, and necessary: 
 
 
 
$275,330.80 (80% of $344,163.50)  
 
 
Amount of Expense Reimbursement sought 
as actual, reasonable, and necessary:  
 
$2,605.35 
 
 
 
 
 
 
This is a(n):   X   monthly  
___  interim 
        
  final application 
 
Prior Applications Filed:  None. 
 
 
 
 
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 
number, as applicable are: Kabbage, Inc. d/b/a KServicing (3937); Kabbage Canada Holdings, LLC (N/A); Kabbage 
Asset Securitization LLC (N/A); Kabbage Asset Funding 2017-A LLC (4803); Kabbage Asset Funding 2019-A 
LLC (8973); and Kabbage Diameter, LLC (N/A). Kabbage is a trademark of American Express used under license; 
Kabbage, Inc. d/b/a KServicing is not affiliated with American Express.  The Debtors’ mailing and service address 
is 925B Peachtree Street NE, Suite 383, Atlanta, GA 30309. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 1 of 17

 
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RLF1 28301713v.1 
COMPENSATION BY PROFESSIONAL 
OCTOBER 3, 2022 THROUGH OCTOBER 31, 2022 
 
Name of Professional 
Individual 
Position, year assumed 
position, prior relevant 
experience, year of 
obtaining relevant 
license to practice 
Hourly 
Billing Rate 
(including 
changes) 
Total 
Hours 
Billed 
Total 
Compensation 
Daniel J. DeFranceschi 
Joined firm as associate 
in 1990.  Director in 
2000. Member of DE 
Bar since 1989. 
$1,100  
26.1 
$28,710.00 
Amanda R. Steele 
Joined firm as associate 
in 2010. Director in 
2018. Member of DE 
Bar since 2010. 
$875  
72.8 
$63,700.00 
Zachary I. Shapiro 
Joined firm as associate 
in 2007. Director in 
2019. Member of DE 
Bar since 2008. 
$850  
155.5 
$132,175.00 
Cory D. Kandestin 
Joined firm as associate 
in 2007. Counsel in 
2015. Member of DE 
Bar since 2007. 
$750  
23.8 
$17,850.00 
Matthew P. Milana 
Joined firm as associate 
in 2022. Member of DE 
Bar since 2019. 
$600  
61.6 
$36,960.00 
Sarah E. Silveira 
Joined firm as associate 
in 2018.  Member of DE 
Bar since 2018. 
$600  
14.4 
$8,640.00 
Huiqi Vicky Liu 
Joined firm as associate 
in 2020. Member of DE 
Bar since 2022. 
$475  
40.5 
$19,237.50 
James F. McCauley 
Joined firm as associate 
in 2020. Member of the 
DE Bar since 2022. 
$475  
2.1 
$997.50 
Ashly L. Riches 
Joined firm as associate 
in 2022. 
$425  
16.6 
$7,055.00 
Zachary J. Javorsky 
Joined firm as associate 
in 2022. 
$425  
7.5 
$3,187.50 
Barbara J. Witters 
Paralegal since 2000. 
Joined firm in 2000. 
$315  
8.2 
$2,583.00 
M. Lynzy McGee 
Paralegal since 2007. 
Joined firm in 2016. 
$315  
63.8 
$20,097.00 
Rebecca V. Speaker 
Paralegal since 2002. 
Joined firm in 2001. 
$315  
6.0 
$1,890.00 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 2 of 17

 
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RLF1 28301713v.1 
Name of Professional 
Individual 
Position, year assumed 
position, prior relevant 
experience, year of 
obtaining relevant 
license to practice 
Hourly 
Billing Rate 
(including 
changes) 
Total 
Hours 
Billed 
Total 
Compensation 
Sherry L. Pitman 
Paralegal since 2021. 
Joined the firm in 2016. 
$315  
2.9 
$913.50 
Sean F. Quigley 
MIS Department.  
Joined firm in 2021 
$295  
0.2 
$59.00 
Sandra I. Roberts 
Case Management 
Assistant since 2020. 
Joined the firm in 2019. 
$155  
0.7 
$108.50 
TOTAL 
 
 
502.7 
$344,163.50 
 
 
 
Grand Total 
 
 
$344,163.50 
 
 
Attorney Compensation 
$318,512.50 
 
 
Total Attorney Hours  
420.9 
 
 
Blended Rate  
 
$756.74 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 3 of 17

 
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RLF1 28301713v.1 
COMPENSATION BY PROJECT CATEGORY 
OCTOBER 3, 2022 THROUGH OCTOBER 31, 2022 
 
Project Category 
Total Hours 
Total Fees 
Case Administration (A) 
55.8 
$32,674.50  
Creditor Inquiries (B) 
0.3 
$207.50  
Meetings (C) 
39.5 
$32,592.50  
Executory Contracts/Unexpired Leases (D) 
5.2 
$2,210.00  
Automatic Stay/Adequate Protection (E) 
2.8 
$2,087.50  
Chapter 11 Plan/Disclosure Statement (F) 
47.1 
$34,371.50  
Use, Sale, Lease of Assets (G) 
12.8 
$5,932.00  
Cash Collateral/DIP Financing (H) 
23.6 
$17,705.00  
Claims Administration (I) 
27.0 
$14,941.00  
Court Hearings (J) 
98.6 
$67,149.50  
General Corporate/Real Estate (K) 
0.0 
$0.00  
Schedules/SOFA/U.S. Trustee Reports (L) 
39.6 
$29,461.00  
Employee Issues (M) 
10.3 
$7,884.00  
Environmental (N) 
0.0 
$0.00  
Tax Issues (O) 
2.6 
$933.00  
Litigation/Adversary Proceedings (P) 
61.8 
$45,642.00  
RL&F Retention (Q-1) 
35.0 
$26,580.00  
Retention of Others (Q-2) 
31.0 
$19,322.00  
RL&F Fee Applications (R-1) 
0.3 
$255.00  
Fee Applications of Others (R-2) 
3.6 
$1,839.50  
Vendor/Supplies (S) 
0.0 
$0.00  
Non-Working Travel (T) 
0.0 
$0.00  
Utilities (U) 
2.7 
$1,043.00  
Insurance (V) 
3.1 
$1,333.00  
TOTAL 
502.7 
$344,163.50 
 
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RLF1 28301713v.1 
EXPENSE SUMMARY 
OCTOBER 3, 2022 THROUGH OCTOBER 31, 2022 
 
Expense Category 
Service Provider  
(if applicable) 
Total Expenses 
Facsimile 
 
$0.00 
Conference Calling 
 
$0.00 
Long Distance Telephone 
 
$0.00 
In-House Reproduction 
(Duplication/Printing) 
Duplicating: 0 @ $0.10 pg.   
Printing: 2,630 @ $0.10 pg.   
$26.30 
Outside Reproduction 
Parcels, Inc. 
$659.30 
Legal Research  
Westlaw 
$1,073.30 
Filing/Court Fees 
Pro hac vice motion filing fees 
$100.00 
Court Reporting 
Reliable Wilmington 
$514.75 
Travel Expenses 
 
$0.00 
Inside Courier & Expense 
Carriers 
 
$0.00 
Outside Courier & Expense 
Carriers 
 
$0.00 
Postage 
 
$0.00 
Binding 
 
$0.00 
Business Meals 
 
$0.00 
Document Retrieval 
PACER 
$231.70 
Record Retrieval 
 
$0.00 
Professional Services 
 
$0.00 
Overtime 
 
$0.00 
Room Rental 
 
$0.00 
Equipment Rental 
 
$0.00 
Stationery Supplies 
 
$0.00 
TOTAL 
 
$2,605.35 
 
 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 5 of 17

 
 
RLF1 28301713v.1 
UNITED STATES BANKRUPTCY COURT 
DISTRICT OF DELAWARE 
------------------------------------------------------------ x 
 
In re 
: 
Chapter 11 
 
: 
 
KABBAGE, INC. d/b/a KSERVICING, et al., : 
Case No. 22-10951 (CTG) 
 
: 
 
 
: 
(Jointly Administered) 
 
 
Debtors.1 
: 
 
 
: 
Obj. Deadline: Dec. 22, 2022 at 4:00 p.m. (ET) 
------------------------------------------------------------ x 
 
FIRST MONTHLY APPLICATION OF RICHARDS, LAYTON & FINGER, P.A. FOR 
ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND FOR 
REIMBURSEMENT OF EXPENSES AS CO-COUNSEL TO THE DEBTORS  
FOR THE PERIOD FROM OCTOBER 3, 2022 THROUGH OCTOBER 31, 2022 
Pursuant to sections 330 and 331 of title 11 of the United States Code, §§ 101-1532 
(the “Bankruptcy Code”), rule 2016 of the Federal Rules of Bankruptcy Procedure (the 
“Bankruptcy Rules”), rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure of 
the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), and the 
Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of 
Professionals, dated October 21, 2022 [Docket No. 136] (the “Interim Compensation Order”), 
Richards, Layton & Finger, P.A. (“RL&F”) hereby files this First Monthly Application of 
Richards, Layton & Finger, P.A. for Allowance of Compensation for Services Rendered and for 
Reimbursement of Expenses as Co-Counsel to the Debtors for the Period from October 3, 2022 
through October 31, 2022 (the “Application”).  By the Application, RL&F seeks a monthly 
allowance pursuant to the Interim Compensation Order with respect to the sums of $344,163.50 
 
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 
number, as applicable are: Kabbage, Inc. d/b/a KServicing (3937); Kabbage Canada Holdings, LLC (N/A); Kabbage 
Asset Securitization LLC (N/A); Kabbage Asset Funding 2017-A LLC (4803); Kabbage Asset Funding 2019-A 
LLC (8973); and Kabbage Diameter, LLC (N/A). Kabbage is a trademark of American Express used under license; 
Kabbage, Inc. d/b/a KServicing is not affiliated with American Express.  The Debtors’ mailing and service address 
is 925B Peachtree Street NE, Suite 383, Atlanta, GA 30309. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 6 of 17

 
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RLF1 28301713v.1 
as compensation and $2,605.35 for reimbursement of actual and necessary expenses, for a total of 
$346,768.85 for the period October 3, 2022 through and including October 31, 2022 (the 
“Compensation Period”).  In support of this Application, RL&F respectfully represents as 
follows: 
Background 
1. 
On October 3, 2022 (the “Petition Date”), the Debtors each commenced with this 
Court a voluntary case under chapter 11 of the Bankruptcy Code (the “Chapter 11 Cases”).  The 
Debtors are authorized to continue to operate their business as debtors in possession pursuant to 
sections 1107(a) and 1108 of the Bankruptcy Code.  No trustee, examiner, or statutory committee 
of creditors has been appointed in these Chapter 11 Cases. 
2. 
RL&F was retained effective as of the Petition Date by this Court’s order, entered 
on October 28, 2022 [Docket No. 175] (the “Retention Order”).  The Retention Order authorized 
RL&F to be compensated on an hourly basis and to be reimbursed for actual and necessary out-
of-pocket expenses. 
Compensation Paid and Its Source 
3. 
All services for which compensation is requested by RL&F were performed for or 
on behalf of the Debtors. 
4. 
Except to the extent of the retainer paid to RL&F as described in the application 
seeking approval of RL&F’s employment by the Debtors during the period covered by this 
Application, RL&F has received no payment and no promises for payment from any source for 
services rendered or to be rendered in any capacity whatsoever in connection with the matters 
covered by this Application.  There is no agreement or understanding between RL&F and any 
other person other than the directors of RL&F for the sharing of compensation to be received for 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 7 of 17

 
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RLF1 28301713v.1 
services rendered in these cases. 
Fee Statements 
5. 
The fee statement for the Compensation Period is attached hereto as Exhibit A.  
This statement contains daily time logs describing the time spent by each attorney and 
paraprofessional for this period.  To the best of RL&F’s knowledge, this Application complies 
with sections 330 and 331 of the Bankruptcy Code, the applicable Bankruptcy Rules, the 
Guidelines adopted by the Office of the United States Trustee, Local Rule 2016-2, and the Interim 
Compensation Order. 
Actual and Necessary Expenses 
6. 
A summary of actual and necessary expenses and daily logs of expenses incurred 
by RL&F during the Compensation Period is attached hereto as Exhibit B.  RL&F charges all of 
its bankruptcy clients $0.10 per page for photocopying expenses and $0.10 per page for printing 
jobs. 
7. 
Regarding providers of on-line legal research (e.g., LEXIS and WESTLAW), 
RL&F charges all of its clients the standard usage rates these providers charge, which, due to 
contractual flat fees, may not always equal RL&F’s actual cost.  RL&F currently is under contract 
to pay these providers a flat fee every month.  Charging its clients the on-line providers’ standard 
usage rates allows RL&F to cover adequately the monthly flat fees it must pay to these types of 
providers. 
8. 
RL&F believes the foregoing rates are the market rates that the majority of law 
firms charges clients for such services.  In addition, RL&F believes that such charges are in 
accordance with the American Bar Association’s (“ABA”) guidelines, as set forth in the ABA’s 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 8 of 17

 
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RLF1 28301713v.1 
Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other 
charges. 
Summary of Services Rendered  
9. 
The directors, counsel, and associates of RL&F who have rendered professional 
services in these cases are as follows: Daniel J. DeFranceschi, Amanda R. Steele, Zachary I. 
Shapiro, Cory D. Kandestin, Matthew P. Milana, Sarah E. Silveira, Huiqi Vicky Liu, James F. 
McCauley, Ashly L. Riches, and Zachary J. Javorsky.  The paraprofessionals of RL&F who have 
provided service to these attorneys in these cases are as follows: Barbara J. Witters, M. Lynzy 
McGee, Rebecca V. Speaker, Sherry L. Pitman, Sean F. Quigley, and Sandra I. Roberts.  
10. 
RL&F, by and through the above-named persons, has prepared and/or assisted in 
the preparation of various applications and orders submitted to the Court for consideration, advised 
the Debtors on a regular basis with respect to various matters in connection with these cases, and 
has performed all necessary professional services which are described and narrated in detail 
hereinafter. 
Summary of Services By Project 
11. 
The services rendered by RL&F during the Compensation Period can be grouped 
into the categories set forth below.  These categories are generally described below, with a more 
detailed identification of the actual services provided set forth on the attached Exhibit A.  The 
attorneys and paraprofessionals who rendered services relating to each category are identified, 
along with the number of hours for each individual and the total compensation sought for each 
category, in Exhibit A attached hereto. 
A. 
Case Administration/Miscellaneous Matters 
Fees:  $32,674.50 
Total Hours:  55.8 
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RLF1 28301713v.1 
This category includes all matters related to filing documents with the Court, 
service thereof, maintenance of calendars, communications with the U.S. Trustee, review of work 
in process reports, review of notices of appearance and maintaining service lists. 
B. 
Creditor Inquiries 
Fees:  $207.50  
Total Hours:  0.3 
This category includes all matters related to responding to creditor inquiries. 
C. 
Meetings 
Fees:  $32,592.50 
Total Hours:  39.5 
This category includes all matters related to preparing for and attending meetings 
with the Debtors, individual creditors, the U.S. Trustee and the Debtors’ other professionals. 
D. 
Executory Contracts/Unexpired Leases 
Fees:  $2,210.00 
Total Hours:  5.2 
This category includes all matters related to contract and lease analysis and matters 
related to assumption, assignment or rejection of executory contracts and unexpired leases. 
E. 
Automatic Stay/Adequate Protection 
Fees:  $2,087.50 
Total Hours:  2.8 
This category includes all matters related to and including all motions to modify 
the automatic stay, issues related to the effect of the automatic stay or pending matters, and all 
other types of actions where adequate protection is the central issue. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 10 of 17

 
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RLF1 28301713v.1 
F. 
Chapter 11 Plan/Disclosure Statement 
Fees:  $34,371.50 
Total Hours:  47.1 
This category includes all matters related to review, formulation, negotiation, 
preparation and promulgation of chapter 11 plans, disclosure statements, and related corporate 
documentation and research relating thereto. 
G. 
Use, Sale, Lease of Assets 
Fees:  $5,932.00 
Total Hours:  12.8 
This category includes all matters relating to acquisitions, dispositions and other 
postpetition uses of property of the estate. 
H 
Cash Collateral/DIP Financing 
Fees:  $17,705.00 
Total Hours:  23.6 
This category includes all matters relating to negotiation and documentation of 
debtor-in-possession financing and related issues. 
I. 
Claims Administration 
Fees:  $14,941.00 
Total Hours:  27.0 
This category includes all matters related to and including claims administration 
matters and bar date matters, including claims objections and related contested matters. 
J. 
Court Hearings 
Fees:  $67,149.50 
Total Hours:  98.6 
This category includes all matters related to preparation for and attendance at court 
hearings. 
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RLF1 28301713v.1 
K. 
General Corporate/Real Estate 
Fees:  $0.00 
 
Total Hours:  0.0 
This category includes all matters relating to transactional, corporate governance 
and related matters involving the Debtors’ business operations that are not part of a chapter 11 
plan or disclosure statement. 
L. 
Schedules/SOFA/U.S. Trustee Reports 
Fees:  $29,461.00 
Total Hours:  39.6 
This category includes preparation of schedules and amendments, statements of 
financial affairs and amendments, operating reports and other reports required by the U.S. Trustee 
or the Court. 
M. 
Employee Issues 
Fees:  $7,884.00 
Total Hours:  10.3 
This category includes all matters related to employee wages, benefits, collective 
bargaining issues, other employee relations matters, ERISA, and retirement benefits. 
N. 
Environmental 
Fees:  $0.00 
 
Total Hours:  0.0 
This category includes all environmental matters, other than environmental aspects 
of the chapter 11 plan. 
O. 
Tax Issues 
Fees:  $933.00  
Total Hours:  2.6 
This category includes all federal and state income, property, employment, excise 
and other tax matters, other than the tax aspects of the chapter 11 plan. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 12 of 17

 
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RLF1 28301713v.1 
P. 
Litigation/Adversary Proceedings 
Fees:  $45,642.00 
Total Hours:  61.8 
This category includes all matters related to litigation and adversary proceedings. 
Q-1. 
RL&F Applications 
Fees:  $26,580.00 
Total Hours:  35.0 
This category includes all matters related to preparing applications to retain RL&F 
and supplements thereto. 
Q-2. 
Retention of Others 
Fees:  $19,322.00 
Total Hours:  31.0 
This category includes time spent reviewing applications for retention of other 
professionals, objecting to the retention of other professionals and assisting other professionals 
with preparing and filing retention applications. 
R-1. 
RL&F Fee Applications 
Fees:  $255.00  
Total Hours:  0.3 
This category includes all time spent preparing, reviewing, filing and circulating 
monthly invoices and fee applications for RL&F. 
R-2. 
Fee Applications of Others 
Fees:  $1,839.50 
Total Hours: 3.6 
This category includes time spent reviewing invoices or applications of other 
professionals, objecting to fees of other professionals and assisting other professionals with filing 
and circulating monthly invoices and applications. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 13 of 17

 
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RLF1 28301713v.1 
S. 
Vendor/Suppliers 
Fees:  $0.00 
 
Total Hours:  0.0 
This category includes all matters related to vendors and suppliers, including 
reclamation issues. 
T. 
Non-Working Travel 
Fees:  $0.00 
 
Total Hours:  0.0 
This category includes all travel time not otherwise chargeable. 
U. 
Utilities 
Fees:  $1,043.00 
Total Hours:  2.7 
This category includes all matters related to utility issues. 
V. 
Insurance 
Fees:  $1,333.00 
Total Hours:  3.1 
This category includes all matters related to insurance policies or coverage. 
Valuation of Services 
12. 
Attorneys and paraprofessionals of RL&F have expended a total of 502.7 hours in 
connection with this matter during the Compensation Period, as follows: 
ATTORNEYS 
 
 
HOURS 
HOURLY RATE 
 
 
Daniel J. DeFranceschi 
 
26.1 
 
$1,100 
 
 
Amanda R. Steele 
 
 
72.8 
 
$875 
 
 
Zachary I. Shapiro 
 
 
155.5  
$850 
 
 
Cory D. Kandestin 
 
 
23.8 
 
$750 
 
 
Matthew P. Milana 
 
 
61.6 
 
$600 
 
 
Sarah E. Silveira 
 
 
14.4 
 
$600 
 
 
Huiqi Vicky Liu 
 
 
40.5 
 
$475 
 
 
James F. McCauley 
 
 
2.1 
 
$475 
 
 
Ashly L. Riches 
 
 
16.6 
 
$425 
 
 
Zachary J. Javorsky  
 
7.5 
 
$425 
 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 14 of 17

 
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RLF1 28301713v.1 
 
 
PARAPROFESSIONALS 
 
HOURS 
HOURLY RATE 
 
 
Barbara J. Witters 
 
 
8.2 
 
$315 
 
 
M. Lynzy McGee 
 
 
63.8 
 
$315 
 
 
Rebecca V. Speaker  
 
6.0 
 
$315 
 
 
Sherry L. Pitman 
 
 
2.9 
 
$315 
 
 
Sean F. Quigley 
 
 
0.2 
 
$295 
 
 
Sandra I. Roberts 
 
 
0.7 
 
$155 
 
The nature of the work performed by these persons is fully set forth in Exhibit A attached hereto.  
These are RL&F’s normal hourly rates for work of this character.  The reasonable value of the 
services rendered by RL&F to the Debtors during the Compensation Period is $344,163.50. 
13. 
In accordance with the factors enumerated in Section 330 of the Bankruptcy Code, 
it is respectfully submitted that the amount requested by RL&F is fair and reasonable given (a) the 
complexity of these cases, (b) the time expended, (c) the nature and extent of the services rendered, 
(d) the value of such services, and (e) the costs of comparable services other than in a case under 
this title.  Moreover, RL&F has reviewed the requirements of Local Rule 2016-2 and believes that 
this Application complies with that Rule. 
WHEREFORE, RL&F respectfully requests that the Court authorize that for the 
Compensation Period, an allowance be made to RL&F pursuant to the terms of the Interim 
Compensation Order, with respect to the sum of $344,163.50 as compensation for necessary 
professional services rendered (80% of which equals $275,330.80), and the sum of $2,605.35 as 
100% reimbursement of actual necessary costs and expenses, for a total of $346,768.85 and that 
such sums be authorized for payment and for such other and further relief as this Court may deem 
just and proper. 
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 15 of 17

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RLF1 28301713v.1
Dated: 
December 2, 2022 
 
Wilmington, Delaware 
/s/ Amanda R. Steele  
RICHARDS, LAYTON & FINGER, P.A. 
Daniel J. DeFranceschi, Esq. (No. 2732) 
Amanda R. Steele (No. 5530) 
Zachary I. Shapiro (No. 5103) 
Matthew P. Milana (No. 6681) 
One Rodney Square 
920 North King Street 
Wilmington, Delaware 19801 
Telephone: (302) 651-7700 
E-mail: defranceschi@rlf.com
             steele@rlf.com 
             shapiro@rlf.com 
             milana@rlf.com 
Attorneys for the Debtors and Debtors in 
Possession  
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 16 of 17

RLF1 28301713v.1
CERTIFICATION OF COMPLIANCE WITH DEL. BANKR. L.R. 2016-2 
I, Amanda R. Steele, on this 2nd day of December, 2022, certify as follows: 
a)
I am director with the applicant firm, Richards, Layton & Finger, P.A.,
(“RL&F”) and have been admitted to appear before this Court. 
b)
I have personally performed many of the legal services rendered by RL&F,
as counsel to the Debtors, and am thoroughly familiar with the other work performed on behalf of 
the Debtors by the lawyers and other professionals of RL&F. 
c)
I have reviewed the foregoing Application and the facts set forth therein are
true and correct to the best of my knowledge, information and belief.  Moreover, I have reviewed 
Local Rule 2016-2, and submit that the Application substantially complies with such rule. 
/s/ Amanda R. Steele  
Amanda R. Steele (No. 5530)
Case 22-10951-CTG    Doc 327    Filed 12/02/22    Page 17 of 17

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