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an order approving the professional fees of Kelly T. Smith, CPA of the firm of Smith, Elliot

Date
2020-10-16

Summary

A Supplemental Fee Application for Payment of Professional Fees of Kelly T. Smith, CPA, filed September 20, 2022 as Doc 410 in In re Panthera Enterprises, LLC, Case No. 19-00787, a Chapter 7 case in the United States Bankruptcy Court for the Northern District of West Virginia. Trustee Aaron C. Amore asks the court to approve the fees of Smith, Elliot, Kearns & Company, LLC under Bankruptcy Rule 2016. The application states that the court approved the firm's employment on October 16, 2020 and approved an earlier fee application by order entered February 16, 2021. It states that a June 25, 2021 order under 11 U.S.C. § 363 authorized the trustee to novate certain government contracts, and that the firm prepared financial compilations for that process. It requests approval of fees of $1,914.00 and closes with a certificate of service.

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No. 2:19-bk-00787      Doc 410     Filed 09/20/22     Entered 09/20/22 14:45:14        Page 1 of 4

                         UNITED STATES BANKRUPTCY COURT
                 FOR THE NORTHERN DISTRICT OF WEST VIRGINIA


IN RE:

       PANTHERA ENTERPRISES, LLC                                    Case No. 19-00787

       Debtor.                                                      Chapter 7



         SUPPLEMENTAL FEE APPLICATION FOR PAYMENT OF PROFESSIONAL
                      FEES OF KELLY T. SMITH, CPA

       Now comes Aaron C. Amore, the duly appointed Trustee of the above-name Debtor with

a Supplemental Fee Application for Payment of Professional Fees and requests this Court enter

an order approving the professional fees of Kelly T. Smith, CPA of the firm of Smith, Elliot,

Kearns & Company, LLC (hereafter “Smith”) pursuant to Bankruptcy Rule 2016.

       This Court entered an order approving the Trustee’s employment of Smith on October 16,

2020. See Exhibit A. Smith was retained to investigate and prepare a report as directed by the

Trustee related to his review of Panthera Training, LLC financial reports as part of the Trustee’s

investigation of claims alleged by the Debtor in adversary proceeding 2:19-ap-51. Smith

completed the work and prepared a report to the Trustee pursuant to the terms of his

employment. A fee application for preparation of this report was filed on December 28, 2020 and

approved by Court order entered February 16, 2021. See Exhibit B.

       On June 25, 2021, the Court entered an Order granting the Trustee’s Motion for an Order

Approving the Sale of the Debtor’s Real Property and Novating Certain Government Contracts

Free and Clear of Liens, Claims, Interests, and Encumbrances Pursuant to 11 U.S.C. § 363. See

Exhibit C. Under the terms of this Order, the Trustee is authorized to take actions necessary to

novate certain government contracts on behalf of Debtor. In order to meet the contract novation
No. 2:19-bk-00787     Doc 410      Filed 09/20/22     Entered 09/20/22 14:45:14        Page 2 of 4

requirements of the federal government entities, the Trustee was required to prepare certain

financial compilations related to Panthera Enterprises, LLC as of the day before the sale of the

Debtor’s real property.

       Smith performed said required compilations on behalf of the Trustee, under the terms of

his employment as approved by this Court. These compilations were submitted to the

governmental agencies as part of the contract novation process. In doing so, Smith expended

time and incurred professional fees in the amount of $1,914.00 (One Thousand Nine Hundred

Fourteen Dollars and Zero Cents). See Exhibit D.

       Wherefore, the Trustee asks for approval of Smith’s fees as reflected on Exhibit D to this

fee application in the amount of $1,914.00 and grant any further relief this Court deems just and

necessary.




                                             Respectfully submitted,

                                             /s/ Aaron C. Amore
                                             Aaron C. Amore, Trustee
                                             WVSB No. 6455
                                             206 West Liberty Street
                                             P.O. Box 386
                                             Charles Town, WV 25414
                                             Phone: 304-885-4111
                                             Facsimile: 866-417-8796
                                             E-mail: aaron@amorelaw.com
No. 2:19-bk-00787      Doc 410     Filed 09/20/22     Entered 09/20/22 14:45:14        Page 3 of 4

                                 CERTIFICATE OF SERVICE

I hereby certify that the foregoing SUPPLEMENTAL FEE APPLICATION FOR

PAYMENT OF PROFESSIONAL FEES OF KELLY T. SMITH, CPA was served upon the

following individuals at the addresses listed below, by placing a true and correct copy thereof in

the United States mail, postage prepaid or via email or CM/ECF, on this 20th day of September

2022.



Via Email:
Kelly T. Smith                               ksmith@sek.com
Jack Lantzy                                  jlantzy@sek.com
Mark A. Lindsay                              mlindsay@bernsteinlaw.com
Rob Duncan                                   tarpon777@yahoo.com
Rob Duncan as manager of TR&L         tkelsey@woodsrogers.com
Bruce & Stacie Hardy                         bsrhardy@comcast.net

Via CM/ECF
Debra Lee Allen        dallen@spilmanlaw.com
Aaron C. Amore         aaron@amorelaw.com,
jackie@amorelaw.com;c.ar70274@notify.bestcase.com;alaina@amorelaw.com
Aaron C. Amore         amorewvt@gmail.com,
aca@trustesolutions.net;jackiewvt@gmail.com;annwvt@gmail.com
Robert S. Bernstein       rbernstein@bernsteinlaw.com,
cwirick@bernsteinlaw.com;cwirick@ecf.courtdrive.com;rbernstein@ecf.courtdrive.com
Elizabeth B. Carroll       elizabeth_carroll@vawb.uscourts.gov
Julia A. Chincheck       jchincheck@bowlesrice.com
Spencer D. Elliott      selliott@lgcr.com
Douglas Kahle       dkahle@basnightkinser.com
Gary O. Kinder       gary.o.kinder@usdoj.gov
Travis Alan Knobbe         tknobbe@spilmanlaw.com, dambrose@spilmanlaw.com
Sabrina B. Lee      sabrina_lee@vawb.uscourts.gov
William J. Leon       jayleon@comcast.net
Salene Rae Mazur Kraemer           skraemer@bernsteinlaw.com, salene@ecf.courtdrive.com,
Michael R. Proctor       mproctor@bowlesrice.com, lcrown@bowlesrice.com
Brandy M. Rapp         brapp@wtplaw.com, twhitt@wtplaw.com
John J. Richardson       jrichardson@bernsteinlaw.com
Zachary James Rosencrance           zrosencrance@bowlesrice.com, ajones@bowlesrice.com
Kathy M. Santa Barbara          ksantabarbara@yahoo.com, cmarshsblo@yahoo.com
Robert Sellards      rms@bcyon.com
James E. Smith       jes2esq@frontiernet.net
No. 2:19-bk-00787     Doc 410     Filed 09/20/22    Entered 09/20/22 14:45:14       Page 4 of 4

Anita M. Swaton       Anita_Swaton@wvnb.uscourts.gov
Steven L. Thomas       sthomas@kaycasto.com,
lwalker@kaycasto.com;abrewster@kaycasto.com;nball@kaycasto.com
Stephen L. Thompson         sthompson@barth-thompson.com, office@barth-
thompson.com;chris@barth-thompson.com
United States Trustee      ustpregion04.ct.ecf@usdoj.gov
Eric Michael Wilson       eric.m.wilson@wv.gov, lora.l.rutledge@wv.gov

Manual Notice List

Notice was not mailed to the parties below as no addresses were provided. To the extent the
Trustee has email addresses the below notice parties, they were emailed.

Rob Duncan          Manager/Duncan Development Group, LLC
Rob Duncan          Manager/TR&L, LLC, a Virginia Limited Liability Company
Successor to SMI, LLC, a Virginia Limited Liability Company
Bruce Hardy
Stacie Hardy
Anthony McIntyre
Timothy Miller

                                                    /s/ Aaron C. Amore
                                                    Aaron C. Amore


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