Court filing
Monthly Fee Application (Richards, Layton & Finger, Sixth) — In re KServicing
Summary
The Sixth Monthly Application of Richards, Layton & Finger, P.A., co-counsel to the debtors, filed May 15, 2023 as Doc 819 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware. It seeks compensation for March 1, 2023 to March 31, 2023: $371,399.20 (80% of $464,174.00) in fees and $19,273.78 in expenses, for a total of $483,447.78. Summary tables list prior monthly applications, hours and rates by professional (632.3 hours in total), fees by project category, with Court Hearings at $174,135.00 the largest, and an expense breakdown including business meals. The application sets an objection deadline of June 5, 2023 and ends with a certification of compliance with Local Rule 2016-2 signed by Amanda R. Steele.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
No. 22-10951 · Doc. 819 · Docket on CourtListener
Full text
Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 1 of 19
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)
1
Debtors. :
: Obj. Deadline: June 5, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x
SIXTH 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 MARCH 1, 2023 THROUGH MARCH 31, 2023
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: March 1, 2023 to March 31, 2023
Amount of Compensation sought as actual,
reasonable, and necessary: $371,399.20 (80% of $464,174.00)
Amount of Expense Reimbursement sought
as actual, reasonable, and necessary: $19,273.78
This is a(n): X monthly ___ interim final application
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.
RLF1 29011498v.1
Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 2 of 19
Prior Applications Filed:
Date Period Docket No. Fees Expenses
12/2/22 10/3/22 – 10/31/22 327 $344,163.50 $2,605.35
1/4/23 11/1/22 – 11/30/22 407 $288,304.50 $9,556.64
2/1/23 12/1/22 – 12/31/22 511 $202,611.50 $1,594.74
3/8/23 1/1/23 – 1/31/23 621 $323,673.50 $10,333.27
4/13/23 2/1/23 – 2/28/23 767 $231,181.00 $3,901.88
2
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 3 of 19
COMPENSATION BY PROFESSIONAL
MARCH 1, 2023 THROUGH MARCH 31, 2023
Name of Professional Position, year assumed Hourly Total Total
Individual position, prior relevant Billing Rate Hours Compensation
experience, year of (including Billed
obtaining relevant changes)
license to practice
Daniel J. DeFranceschi Joined firm as associate $1,300 17.1 $22,230.00
in 1990. Director in
2000. Member of DE
Bar since 1989.
Amanda R. Steele Joined firm as associate $995 102.6 102,087.00
in 2010. Director in
2018. Member of DE
Bar since 2010.
Zachary I. Shapiro Joined firm as associate $995 136.5 $135,817.50
in 2007. Director in
2019. Member of DE
Bar since 2008.
Cory D. Kandestin Joined firm as associate $875 32.2 28,175.00
in 2007. Counsel in
2015. Member of DE
Bar since 2007.
Robert C. Maddox Joined firm as associate $875 15.8 $13,825.00
in 2009. Counsel in
2021. Member of DE
Bar since 2009.
Brendan J. Schlauch Joined firm as associate $775 0.3 $232.50
in 2014. Member of DE
Bar since 2015.
Matthew P. Milana Joined firm as associate $675 103.4 $69,795.00
in 2022. Member of DE
Bar since 2019.
Huiqi Vicky Liu Joined firm as associate $595 57.5 $34,212.50
in 2020. Member of DE
Bar since 2022.
Emily R. Mathews Joined firm as associate $550 0.7 $385.00
in 2021. Member of DE
Bar since 2022.
Alexander R. Steiger Joined firm as associate $550 7.9 $4,345.00
in 2022. Member of DE
Bar since 2023.
Zachary J. Javorsky Joined firm as associate $495 4.8 $2,376.00
in 2022. Member of DE
Bar since 2022.
3
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 4 of 19
Name of Professional Position, year assumed Hourly Total Total
Individual position, prior relevant Billing Rate Hours Compensation
experience, year of (including Billed
obtaining relevant changes)
license to practice
Barbara J. Witters Paralegal since 2000. $375 8.3 $3,112.50
Joined firm in 2000.
Ann Jerominski Paralegal since 1995. $375 12.6 $4,725.00
Joined firm in 2000.
Rebecca V. Speaker Paralegal since 2002. $375 9.8 $3,675.00
Joined firm in 2001.
M. Lynzy McGee Paralegal since 2007. $375 66.9 $25,087.50
Joined firm in 2016.
Daniel D. White Trial Services Manager, $350 10.6 $3,710.00
MIS Department.
Joined firm in 2003.
Sean F. Quigley MIS Department. $350 10.0 $3,500.00
Joined firm in 2021.
Lesley Morris Case management $195 33.5 $6,532.50
assistant since 2015.
Joined firm in 1999.
Tesia S. Smith Case management $195 1.8 $351.00
assistant since 2016.
Joined firm in 1996.
TOTAL 632.3 $464,174.00
Grand Total $464,174.00
Attorney Compensation $413,480.50
Total Attorney Hours 478.8
Blended Rate 863.58
4
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 5 of 19
COMPENSATION BY PROJECT CATEGORY
MARCH 1, 2023 THROUGH MARCH 31, 2023
Project Category Total Hours Total Fees
Case Administration (A) 7.0 $3,827.50
Creditor Inquiries (B) 5.9 $3,510.50
Meetings (C) 29.6 $27,564.00
Executory Contracts/Unexpired Leases (D) 20.2 $14,972.50
Automatic Stay/Adequate Protection (E) 0.0 $0.00
Plan of Re-Organization/Disclosure Statement (F) 176.6 $146,044.00
Use, Sale, Lease of Assets (G) 17.1 $13,981.00
Cash Collateral/DIP Financing (H) 0.7 $616.50
Claims Administration (I) 10.7 $8,877.50
Court Hearings (J) 259.0 $174,135.00
General Corporate/Real Estate (K) 0.0 $0.00
Schedules/SOFA/U.S. Trustee Reports (L) 2.9 $1,795.50
Employee Issues (M) 0.0 $0.00
Environmental (N) 0.0 $0.00
Tax Issues (O) 0.0 $0.00
Litigation/Adversary Proceedings (P) 51.0 $41,176.00
RL&F Retention (Q-1) 0.0 $0.00
Retention of Others (Q-2) 3.9 $2,860.50
RL&F Fee Applications (R-1) 15.6 $8,284.00
Fee Applications of Others (R-2) 32.1 $16,529.50
Vendor/Supplies (S) 0.0 $0.00
Non-Working Travel (T) 0.0 $0.00
Utilities (U) 0.0 $0.00
Insurance (V) 0.0 $0.00
TOTAL 632.3 $464,174.00
5
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 6 of 19
EXPENSE SUMMARY
MARCH 1, 2023 THROUGH MARCH 31, 2023
Expense Category Service Provider Total Expenses
(if applicable)
Binding $0.00
Business Meals See attached chart $3,308.46
Conference Calling $0.00
Court Reporting Reliable $2,001.00
Document Retrieval PACER $145.60
AQUIPT: Monitors for co-counsel
Equipment Rental $2,661.72
use for confirmation hearing
Facsimile $0.00
Filing/Court Fees $0.00
Duplicating: 0 $.10 pg
In-House Reproduction $337.80
Printing: 3,378 @ $.10 pg
(Duplication/Printing)
Inside Courier & Expense $0.00
Carriers
Legal Research Westlaw $3,680.40
Long Distance Telephone $0.00
Outside Courier & Expense Parcels, Inc. $745.20
Carriers
Outside Reproduction Parcels, Inc. $6,393.60
Overtime $0.00
Postage $0.00
Professional Services $0.00
Record Retrieval $0.00
RLF Service Corp $0.00
Room Rental $0.00
Stationery Supplies $0.00
Travel Expenses $0.00
TOTAL $19,273.78
6
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 7 of 19
BUSINESS MEAL DETAIL
Date Provider Meal & Description Amount
Number of
people
3/11/23 The Quoin Dinner for 8 Preparation for 3/13/23 hearing $450.00
3/12/23 Manhattan Bagel Breakfast for 20 Preparation for 3/13/23 hearing $453.42
3/13/23 Panera Bread Lunch for 20 Preparation for 3/13/23 hearing $287.53
3/12/23 The Meat House Dinner for 20 Preparation for 3/13/23 hearing $484.94
3/13/23 Manhattan Bagel Breakfast for 20 Preparation for 3/13/23 hearing $246.77
3/19/23 Starbucks Drinks for 10 Preparation for 3/20/23 hearing $36.96
3/19/23 Panera Bread Lunch for 10 Preparation for 3/20/23 hearing $307.40
3/19/23 Brio Dinner for 10 Preparation for 3/20/23 hearing $528.32
3/20/23 Manhattan Bagel Coffee and Juices Preparation for 3/20/23 hearing $43.45
or 10
3/19/23 Rodney Grill Snacks for 10 Preparation for 3/20/23 hearing $16.50
3/20/23 Panera Bread Breakfast for 10 Preparation for 3/20/23 hearing $153.18
3/20/23 Delaware Duck Cafe Lunch for 10 Preparation for 3/20/23 hearing $299.99
& Catering
TOTAL $3,308.46
7
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 8 of 19
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)
1
Debtors. :
: Obj. Deadline: June 5, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x
SIXTH 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 MARCH 1, 2023 THROUGH MARCH 31, 2023
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 Sixth 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 March 1, 2023
through March 31, 2023 (the “Application”). By the Application, RL&F seeks a monthly
allowance pursuant to the Interim Compensation Order with respect to the sums of $464,174.00
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.
RLF1 29011498v.1
Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 9 of 19
(80% of which equals $371,399.20), as compensation and $19,273.78 for reimbursement of actual
and necessary expenses, for a total of $483,447.78 for the period March 1, 2023 through and
including March 31, 2023 (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
2
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 10 of 19
other person other than the directors of RL&F for the sharing of compensation to be received for
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
3
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 11 of 19
Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other
charges.
Summary of Services Rendered
9. The directors, counsels, 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, Robert C. Maddox, Brendan J. Schlauch, Matthew P. Milana, Huiqi
Vicky Liu, Emily R. Mathews, Alexander R. Steiger 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, Ann Jerominski, Rebecca V. Speaker, M. Lynzy McGee, Daniel D.
White, Sean F. Quigley, Lesley Morris and Tesia S. Smith.
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.
4
RLF1 29011498v.1
Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 12 of 19
A. Case Administration/Miscellaneous Matters
Fees: $3,827.50 Total Hours: 7.0
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: $3,510.50 Total Hours: 5.9
This category includes all matters related to responding to creditor inquiries.
C. Meetings
Fees: $27,564 .00 Total Hours: 29.6
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: $14,972.50 Total Hours: 20.2
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: $0.00 Total Hours: 0.0
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.
5
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 13 of 19
F. Plan of Reorganization/Disclosure Statement
Fees: $146,044.00 Total Hours: 176.6
This category includes all matters related to review, formulation, negotiation,
preparation and promulgation of plans of reorganization, disclosure statements, and related
corporate documentation and research relating thereto.
G. Use, Sale, Lease of Assets
Fees: $13,981.00 Total Hours: 17.1
This category includes all matters relating to acquisitions, dispositions and other
postpetition uses of property of the estate.
H Cash Collateral/DIP Financing
Fees: $616.50 Total Hours: 0.7
This category includes all matters relating to negotiation and documentation of
debtor-in-possession financing and related issues.
I. Claims Administration
Fees: $8,877.50 Total Hours: 10.7
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: $174,135.00 Total Hours: 259.0
This category includes all matters related to preparation for and attendance at court
hearings.
6
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 14 of 19
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 plan of
reorganization or disclosure statement.
L. Schedules/SOFA/U.S. Trustee Reports
Fees: $1,795.50 Total Hours: 2.9
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: $0.00 Total Hours: 0.0
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 plan of reorganization.
O. Tax Issues
Fees: $0.00 Total Hours: 0.0
This category includes all federal and state income, property, employment, excise
and other tax matters, other than the tax aspects of the plan of reorganization.
7
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 15 of 19
P. Litigation/Adversary Proceedings
Fees: $41,176.00 Total Hours: 51.0
This category includes all matters related to litigation and adversary proceedings.
Q-1. RL&F Applications
Fees: $0.00 Total Hours: 0.0
This category includes all matters related to preparing applications to retain RL&F
and supplements thereto.
Q-2. Retention of Others
Fees: $2,860.50 Total Hours: 3.9
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: $8,284.00 Total Hours: 15.6
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: $16,529.50 Total Hours: 32.1
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.
8
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 16 of 19
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: $0.00 Total Hours: 0.0
This category includes all matters related to utility issues.
V. Insurance
Fees: $0.00 Total Hours: 0.0
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 632.3 hours in
connection with this matter during the Compensation Period, as follows:
ATTORNEYS HOURS HOURLY RATE
Daniel J. DeFranceschi 17.1 $1,300
Amanda R. Steele 102.6 $995
Zachary I. Shapiro 136.5 $995
Cory D. Kandestin 32.2 $875
Robert C. Maddox 15.8 $875
Brendan J. Schlauch 0.3 $775
Matthew P. Milana 103.4 $675
Huiqi Vicky Liu 57.5 $595
Emily R. Mathews 0.7 $550
Alexander R. Steiger 7.9 $550
Zachary J. Javorsky 4.8 $495
9
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 17 of 19
PARAPROFESSIONALS HOURS HOURLY RATE
Barbara J. Witters 8.3 $375
Ann Jerominski 12.6 $375
Rebecca V. Speaker 9.8 $375
M. Lynzy McGee 66.9 $375
Daniel D. White 10.6 $350
Sean F. Quigley 10.0 $350
Lesley Morris 33.5 $195
Tesia S. Smith 1.8 $195
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 $464,174.00.
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 $464,174.00 as compensation for necessary
professional services rendered (80% of which equals $371,399.20), and the sum of $19,273.78 as
100% reimbursement of actual necessary costs and expenses, for a total $483,447.78 and that such
sums be authorized for payment and for such other and further relief as this Court may deem just
and proper.
10
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 18 of 19
Dated: May 15, 2023
Wilmington, Delaware
/s/ Amanda R. Steele
RICHARDS, LAYTON & FINGER, P.A.
Daniel J. DeFranceschi, Esq. (No. 2732)
Amanda R. Steele, Esq. (No. 5530)
Zachary I. Shapiro, Esq. (No. 5103)
Matthew P. Milana, Esq. (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
11
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Case 22-10951-CTG Doc 819 Filed 05/15/23 Page 19 of 19
CERTIFICATION OF COMPLIANCE WITH DEL. BANKR. L.R. 2016-2
I, Amanda R. Steele, on this 15th day of May, 2023, 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)
RLF1 29011498v.1
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- 6e6c62b18cca2e47785568905710ea2b5ca3d8a8aff46978d7d3d371367c384f
- Original
- archive.org