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Home Source documents In re Vyaire Medical, Inc. — Berkeley Research Group Fee Statement Time Detail (Sept 2024)

In re Vyaire Medical, Inc. — Berkeley Research Group Fee Statement Time Detail (Sept 2024)

Summary

Doc 735-2 in Case 24-11217-BLS, In re: Vyaire Medical, Inc., et al., filed November 13, 2024, is Exhibit A: Time Detail for Berkeley Research Group, LLC for the period 9/1/2024 through 9/30/2024. The 21-page exhibit lists each time entry by date, professional, hours and description, grouped by task code. Task codes include Asset Acquisition/ Disposition (Task Code Total Hours 45.6), Professional Retention/ Fee Application Preparation (25.3), Interaction/ Meetings with Creditors/ Counsel (22.8), Recovery/ SubCon/ Lien Analysis (19.3) and Plan of Reorganization/ Disclosure Statement (50.6). Entries describe review of Transition Services Agreements and asset purchase agreements, calls with counsel and the Committee, unsecured claims analysis, and review of the Debtors' liquidation analysis. The exhibit reports Total Hours 434.5.

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                           Case 24-11217-BLS   Doc 735-2       Filed 11/13/24         Page 1 of 21
In re: Vyaire Medical, Inc., et al.
Exhibit A: Time Detail
Berkeley Research Group, LLC
For the Period 9/1/2024 through 9/30/2024

Date          Professional             Hours     Description

01. Asset Acquisition/ Disposition

9/4/2024      A. Kashanirokh             1.2     Reviewed Transition Service Agreements related to sale of Debtors'
                                                 assets.

9/4/2024      R. Zaidman                 0.7     Reviewed correspondence from MWE (M. Kandestin) re: TSA
                                                 agreements related to sales process.

9/4/2024      R. Zaidman                 0.6     Reviewed certain data room postings related to sale process re:
                                                 contract assumptions.

9/10/2024     R. Zaidman                 0.2     Participated in call with AlixPartners (R. Robbins) re: contract
                                                 assumptions and TSA.

9/11/2024     R. Zaidman                 1.3     Analyzed TSA related agreements as sent by MWE (M. Kandestin).

9/11/2024     R. Zaidman                 0.8     Reviewed Debtors' assumptions related to certain TSA related costs.

9/12/2024     A. Kashanirokh             2.9     Prepared analysis of acquired non-Debtor liabilities related to
                                                 successful bidders.

9/12/2024     R. Cohen                   1.4     Reviewed analysis prepared by BRG (A. Kashanirokh) related to
                                                 acquired non-Debtors of Zoll and Trudell sales.

9/12/2024     A. Kashanirokh             1.2     Continued to prepare analysis of acquired non-Debtor liabilities
                                                 related to successful bidders.

9/12/2024     R. Zaidman                 0.5     Reviewed certain indication of interest received from PJT (D. Friesner)
                                                 re: miscellaneous asset category.

9/13/2024     A. Kashanirokh             1.4     Reconciled non-Debtor balance sheets to reflect assumed liabilities of
                                                 successful bidders.

9/13/2024     A. Kashanirokh             1.1     Reviewed asset sale agreement of certain non-Debtor entities.

9/13/2024     D. Galfus                  0.9     Evaluated a new sale opportunity.

9/13/2024     R. Cohen                   0.6     Reviewed list of entities and their acquisition status provided by the
                                                 Debtors.

9/15/2024     D. Galfus                  0.7     Analyzed an incremental sale opportunity.

9/16/2024     A. Kashanirokh             0.9     Revised non-Debtor historical balance sheets to reflect assumed
                                                 liabilities of successful bidder.


Berkeley Research Group, LLC                                                 Invoice for the 9/1/2024 - 9/30/2024 Period
                           Case 24-11217-BLS   Doc 735-2       Filed 11/13/24         Page 2 of 21
Date          Professional             Hours     Description

01. Asset Acquisition/ Disposition

9/16/2024     R. Cohen                   0.6     Analyzed potential liability assumptions of a potential transaction.

9/16/2024     R. Zaidman                 0.5     Prepared summary correspondence for MWE (K. Going, M. Kandestin)
                                                 re: sales related matters related to certain non-Debtor.

9/17/2024     A. Kashanirokh             1.2     Prepared historical balance sheet for non-Debtor entity related to
                                                 potential sale of entity.

9/18/2024     R. Zaidman                 0.2     Corresponded with PJT (D. Friesner) re: certain non-Debtor entity and
                                                 potential transaction.

9/19/2024     R. Zaidman                 1.1     Analyzed Vyaire remaining assets schedule diligence as provided by
                                                 AlixPartners (J. Zermeno).

9/19/2024     R. Zaidman                 0.8     Reviewed sale related task list for closing the Vents transactions with
                                                 buyer.

9/20/2024     R. Zaidman                 0.9     Reviewed diligence file provided by AlixPartners (R. Robbins) re:
                                                 Transition Services Agreement .

9/20/2024     D. Galfus                  0.8     Evaluated transition issues related to sale.

9/20/2024     R. Zaidman                 0.8     Reviewed APAs for Debtors' asset sales related to liability and cost
                                                 assumptions.

9/20/2024     R. Zaidman                 0.7     Analyzed Transition Services Agreement diligence material provided
                                                 by AlixPartners re: related estimated costs.

9/20/2024     R. Zaidman                 0.6     Reviewed latest update from PJT (D. Friesner) re: certain non-Debtor
                                                 potential sale.

9/20/2024     R. Zaidman                 0.3     Participated in call with AlixPartners (R. Robbins) re: Transition
                                                 Services Agreement and liability assumptions for sales process.

9/20/2024     R. Zaidman                 0.2     Participated in call with MWE (K. Going) re: liability assumptions by
                                                 buyers for sales.

9/20/2024     R. Zaidman                 0.2     Participated in call with MWE (K. Going) re: Transition Services
                                                 Agreement for sales.

9/23/2024     R. Zaidman                 0.7     Analyzed employee obligations as part of sales based on diligence file
                                                 provided by AlixPartners (J. Amico).

9/24/2024     R. Zaidman                 0.2     Corresponded with PJT (D. Friesner) re: latest potential sale of certain
                                                 non-Debtor operations.

9/26/2024     R. Cohen                   1.7     Analyzed revised cure cost schedule provided by the Debtors.

9/26/2024     R. Zaidman                 0.9     Analyzed draft APA disclosure schedule provided for the Vents sale to
                                                 Zoll.


Berkeley Research Group, LLC                                                 Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                               Page 2 of 21
                           Case 24-11217-BLS          Doc 735-2         Filed 11/13/24          Page 3 of 21
Date          Professional                  Hours         Description

01. Asset Acquisition/ Disposition

9/26/2024     R. Zaidman                      0.8         Reviewed draft assumptions schedule of contracts and cure amounts
                                                          for the Zoll transaction provided by MWE (K. Going).

9/26/2024     R. Zaidman                      0.7         Compared prior draft of cure assumptions schedule for asset sales to
                                                          latest version sent by MWE (K. Going) re: sales.

9/27/2024     R. Cohen                        2.9         Continued to prepare analysis related to proposed contract
                                                          assumptions.

9/27/2024     R. Cohen                        2.9         Continued to prepare analysis related to proposed contract
                                                          assumptions.

9/27/2024     R. Cohen                        2.9         Prepared analysis related to proposed contract assumptions.

9/27/2024     R. Cohen                        0.9         Continued to prepare analysis related to proposed contract
                                                          assumptions.

9/27/2024     R. Zaidman                      0.7         Reviewed estimated TSA schedule previously provided by AlixPartners
                                                          (J. Zermeno).

9/27/2024     D. Galfus                       0.6         Evaluated the status of the sale and updated cure schedule.

9/27/2024     R. Zaidman                      0.3         Corresponded with AlixPartners (R. Robbins) re: contracts,
                                                          assumptions for sale process.

9/30/2024     D. Galfus                       0.9         Evaluated the status of the sale timeline.

9/30/2024     R. Cohen                        0.9         Reviewed draft amendment to the Zoll APA.

9/30/2024     R. Cohen                        0.8         Evaluated certain sale documents to determine financial impact of
                                                          amendment to Zoll APA.

9/30/2024     R. Zaidman                      0.6         Reviewed draft proposed APA amendment for certain sale.

9/30/2024     R. Zaidman                      0.5         Reviewed BRG analysis of cure costs assumptions as compared to
                                                          prior draft list provided by Debtors.

9/30/2024     R. Zaidman                      0.4         Reviewed latest TSA parties being contacted as part of Debtors'
                                                          process as compared to prior draft list re: sales process.

Task Code Total Hours                        45.6

05. Professional Retention/ Fee Application Preparation

9/3/2024      E. Degnan                       1.9         Prepared June/July fee application.

9/4/2024      E. Degnan                       2.7         Prepared June/July fee application.

9/5/2024      E. Degnan                       0.6         Prepared June/July fee application.



Berkeley Research Group, LLC                                                          Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                       Page 3 of 21
                          Case 24-11217-BLS           Doc 735-2         Filed 11/13/24          Page 4 of 21
Date         Professional                   Hours         Description

05. Professional Retention/ Fee Application Preparation

9/6/2024      M. Haverkamp                    1.0         Edited first monthly fee application.

9/6/2024      E. Degnan                       0.8         Prepared June/July fee application.

9/9/2024      M. Haverkamp                    1.4         Edited first monthly fee application.

9/9/2024      E. Degnan                       1.0         Prepared June/July fee application.

9/10/2024     M. Haverkamp                    1.1         Edited first monthly fee application.

9/10/2024     E. Degnan                       1.1         Prepared June/July fee application.

9/10/2024     D. Galfus                       0.5         Reviewed BRG's July fee application.

9/11/2024     E. Degnan                       0.6         Prepared June/July fee application.

9/11/2024     E. Degnan                       0.4         Prepared August fee application.

9/12/2024     E. Degnan                       2.1         Prepared August fee application.

9/12/2024     M. Haverkamp                    1.3         Edited first monthly fee application.

9/12/2024     D. Galfus                       0.2         Reviewed BRG's July fee application.

9/12/2024     E. Degnan                       0.1         Prepared June/July reports.

9/13/2024     E. Degnan                       1.1         Prepared August fee application.

9/13/2024     M. Haverkamp                    0.1         Updated first monthly fee application for filing.

9/16/2024     M. Haverkamp                    2.2         Edited Vyaire August fee application.

9/16/2024     E. Degnan                       1.9         Prepared August fee application.

9/18/2024     E. Degnan                       0.4         Prepared August fee application.

9/18/2024     M. Haverkamp                    0.2         Edited second monthly fee application.

9/19/2024     E. Degnan                       1.5         Prepared August fee application.

9/19/2024     M. Haverkamp                    0.3         Edited August fee application.

9/23/2024     E. Degnan                       0.6         Prepared August fee application.

9/26/2024     E. Degnan                       0.2         Integrated edits for August fee application.

Task Code Total Hours                        25.3

Berkeley Research Group, LLC                                                          Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                     Page 4 of 21
                          Case 24-11217-BLS         Doc 735-2       Filed 11/13/24          Page 5 of 21
Date         Professional                   Hours     Description

07. Interaction/ Meetings with Debtors/ Counsel

9/13/2024    R. Zaidman                       0.4     Participated in call with AlixPartners (C. Braley) re: remaining asset
                                                      disposition, budget and Transition Services Agreements.

9/17/2024    R. Zaidman                       0.1     Participated in call with AlixPartners (J. Zermeno) re: DIP budget and
                                                      sale timing.

9/18/2024    D. Galfus                        0.3     Held call with C. Braley (AlixPartners) re: wind down, DIP budget, and
                                                      sale matters.

9/18/2024    R. Zaidman                       0.3     Participated in call with AlixPartners (C. Braley) re: DIP budget, sale
                                                      matters and other case activity.

9/25/2024    D. Galfus                        0.4     Held call with AlixPartners (C. Braley) re: status of sale closing.

9/25/2024    R. Zaidman                       0.4     Participated in call with AlixPartners (J. Amico, M. Del Priore, R.
                                                      Robbins-partial) re: sale closing status, cash activity, and other sale
                                                      related matters.

Task Code Total Hours                         1.9

08. Interaction/ Meetings with Creditors/ Counsel

9/3/2024     D. Galfus                        0.6     Participated in a call with Counsel (D. Azman; M. Kandestin) and the
                                                      Committee re: the sale hearing and next steps.

9/3/2024     R. Zaidman                       0.6     Participated in Committee meeting with MWE (D. Azman, M.
                                                      Kandestin) re: case status and post sale hearing.

9/3/2024     R. Cohen                         0.6     Participated in UCC meeting with MWE (D. Azman) re: DIP and
                                                      liquidity report and other case updates.

9/3/2024     D. Galfus                        0.4     Participated in a call with Counsel (D. Azman; M. Kandestin) in
                                                      preparation of the Committee call.

9/3/2024     R. Zaidman                       0.4     Participated in call with MWE (D. Azman, M. Kandestin) re: pre call
                                                      prior to Committee meeting.

9/3/2024     R. Cohen                         0.4     Participated on a call with MWE (D. Azman) re: pre call to Committee
                                                      meeting.

9/3/2024     R. Zaidman                       0.1     Participated in call with MWE (M. Kandestin) re: follow up items from
                                                      Committee call.

9/10/2024    R. Cohen                         0.7     Participated in a call with MWE (K. Going, M. Kandestin) re: case
                                                      issues.

9/10/2024    R. Zaidman                       0.7     Participated in call with MWE (K. Going, M. Kandestin) re: case status
                                                      and Plan.

9/10/2024    D. Galfus                        0.6     Participated in a portion of the call with Counsel (K. Going; M.
                                                      Kandestin; D. Azman) re: Plan.


Berkeley Research Group, LLC                                                       Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                     Page 5 of 21
                          Case 24-11217-BLS         Doc 735-2       Filed 11/13/24        Page 6 of 21
Date         Professional                   Hours     Description

08. Interaction/ Meetings with Creditors/ Counsel

9/11/2024    D. Galfus                        1.2     Participated in a call with the Committee and Counsel (K. Going; M.
                                                      Kandestin; D. Azman) re: various case matters.

9/11/2024    R. Zaidman                       1.2     Participated in call with MWE team (D. Azman, K. Going, M.
                                                      Kandestin) re: case update and UCC work streams.

9/11/2024    D. Galfus                        0.4     Held call with K. Going (Counsel) re: Committee call.

9/13/2024    R. Zaidman                       0.4     Corresponded with MWE (D. Azman, K. Going, M. Kandestin) re:
                                                      miscellaneous asset IOI and other case matters.

9/17/2024    D. Galfus                        1.1     Participated in a call with Counsel (K. Going; M. Kandestin) re: the
                                                      agenda for the upcoming Committee call.

9/17/2024    R. Zaidman                       1.1     Participated in call with MWE (K. Going, M. Kandestin) re: UCC work
                                                      streams, latest update on cash and sale closing, Plan.

9/17/2024    K. McColgan                      0.9     Attended portion of call with K. Going, K. Newsome, M. Kandestin
                                                      (MWE) to discuss case updates.

9/18/2024    R. Zaidman                       1.1     Participated in call with UCC and MWE (K. Going, M. Kandestin) re:
                                                      latest case activities, sale process update, and liquidity.

9/18/2024    D. Galfus                        1.1     Participated in the weekly Committee call along with Counsel (K.
                                                      Going; M. Kandestin) to discuss case status.

9/18/2024    D. Galfus                        0.8     Participated in a call with Counsel (K. Going; M. Kandestin) in
                                                      preparation for the weekly Committee call.

9/18/2024    R. Cohen                         0.8     Participated in a call with MWE (K. Going, M. Kandestin) re: case
                                                      updates.

9/18/2024    R. Zaidman                       0.8     Participated in call with MWE (K. Going, M. Kandestin) re: UCC work
                                                      streams and Committee call agenda.

9/18/2024    D. Galfus                        0.5     Held call with K. Going, MWE re: upcoming Committee call.

9/19/2024    D. Galfus                        0.5     Held call with K. Going, MWE re: next steps.

9/24/2024    K. McColgan                      0.6     Attended professionals update call with K. Going, K. Newsome, M.
                                                      Kandestin (MWE) to review investigation status and general case
                                                      summary update.

9/24/2024    D. Galfus                        0.6     Participated in a call with Counsel (K. Going) re: the Plan issues and
                                                      next steps.

9/24/2024    R. Zaidman                       0.6     Participated in call with MWE (K. Going, M. Kandestin, K. Newsome)
                                                      re: UCC work streams.




Berkeley Research Group, LLC                                                      Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                   Page 6 of 21
                          Case 24-11217-BLS         Doc 735-2       Filed 11/13/24        Page 7 of 21
Date         Professional                   Hours     Description

08. Interaction/ Meetings with Creditors/ Counsel

9/25/2024    D. Galfus                        1.0     Participated in a call with the Committee and Counsel (K. Going; M.
                                                      Kandestin) to discuss case status and Plan issues.

9/25/2024    R. Zaidman                       1.0     Participated in call with UCC and MWE (K. Going, M. Kandestin) re:
                                                      latest case activities, sale process update, and liquidity.

9/26/2024    D. Galfus                        1.0     Participated in a call with Counsel (K. Going; M. Kandestin) to discuss
                                                      Plan issues and next steps.

9/26/2024    R. Zaidman                       1.0     Participated in call with MWE (K. Going, M. Kandestin) re: Disclosure
                                                      Statement and UCC case issues.

Task Code Total Hours                        22.8

10. Recovery/ SubCon/ Lien Analysis

9/4/2024     R. Zaidman                       0.7     Reviewed potential miscellaneous asset recoveries not included as
                                                      part of sales process as sent by AlixPartners (J. Zermeno).

9/5/2024     R. Zaidman                       1.2     Reviewed additional diligence provided by AlixPartners (J. Tutty) re:
                                                      certain miscellaneous assets and potential recovery value.

9/6/2024     R. Cohen                         0.4     Reviewed analysis of recoverability of remaining assets provided by
                                                      the Debtors.

9/12/2024    R. Zaidman                       0.7     Reviewed certain miscellaneous assets identified by the Debtors re:
                                                      recovery value.

9/19/2024    A. Kashanirokh                   2.8     Prepared waterfall analysis to reflect recoveries for unsecured
                                                      creditors.

9/19/2024    R. Cohen                         2.6     Reviewed recovery analysis prepared by BRG (A. Kashanirokh).

9/19/2024    A. Kashanirokh                   1.2     Prepared report related to unsecured claims recoveries.

9/20/2024    R. Cohen                         1.6     Edited recovery analysis report.

9/20/2024    A. Kashanirokh                   0.8     Edited unsecured claims recoveries report to reflect comments from
                                                      BRG team.

9/23/2024    R. Cohen                         2.7     Edited recovery analysis report.

9/30/2024    A. Kashanirokh                   2.7     Prepared schedule detailing the comparison in recoveries between a
                                                      Chapter 7 liquidation and the Debtors' Chapter 11 Plan.

9/30/2024    A. Kashanirokh                   1.9     Modified claims and recovery report to reflect comments from BRG
                                                      team.

Task Code Total Hours                        19.3

11. Claim Analysis/ Accounting

Berkeley Research Group, LLC                                                      Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                  Page 7 of 21
                         Case 24-11217-BLS   Doc 735-2       Filed 11/13/24        Page 8 of 21
Date         Professional            Hours     Description

11. Claim Analysis/ Accounting

9/4/2024     A. Kashanirokh            2.3     Prepared analysis of unsecured claims.

9/5/2024     A. Kashanirokh            2.2     Prepared schedule categorizing unsecured claims.

9/6/2024     A. Kashanirokh            1.1     Prepared analysis estimating unsecured claims pool.

9/6/2024     R. Cohen                  0.9     Reviewed claims analysis prepared by BRG (A. Kashanirokh).

9/9/2024     A. Kashanirokh            2.9     Edited proofs of claims analysis based on comments from BRG team.

9/9/2024     A. Kashanirokh            2.3     Continued to edit proofs of claims analysis based on comments from
                                               BRG team.

9/9/2024     A. Kashanirokh            1.1     Drafted unsecured claims analysis report detailing claims pool as of
                                               9/9.

9/9/2024     R. Cohen                  0.9     Reviewed claims analysis prepared by BRG (A. Kashanirokh).

9/10/2024    A. Kashanirokh            2.9     Continued to edit unsecured claims report to reflect comments from
                                               BRG team.

9/10/2024    A. Kashanirokh            2.9     Edited unsecured claims report to reflect comments from BRG team.

9/10/2024    R. Cohen                  0.5     Reviewed draft report prepared by BRG (A. Kashanirokh) related to
                                               claims estimation.

9/10/2024    A. Kashanirokh            0.3     Continued to edit unsecured claims report to reflect comments from
                                               BRG team.

9/11/2024    A. Kashanirokh            2.6     Analyzed filed litigation claims.

9/11/2024    A. Kashanirokh            1.8     Prepared summary related to filed litigation claims.

9/11/2024    A. Kashanirokh            1.7     Analyzed filed trade claims.

9/12/2024    A. Kashanirokh            1.1     Updated unsecured claims report to reflect comments from BRG team.

9/13/2024    A. Kashanirokh            2.2     Revised Unsecured Claims Analysis report based on comments from
                                               BRG team.

9/13/2024    R. Cohen                  1.0     Reviewed draft of claims analysis prepared by BRG (A. Kashanirokh).

9/16/2024    R. Cohen                  0.4     Provided comments on claims report prepared by BRG (A.
                                               Kashanirokh).

9/17/2024    A. Kashanirokh            1.2     Revised proofs of claims analysis report to reflect comments from BRG
                                               team.

9/18/2024    A. Kashanirokh            2.6     Prepared summary of lease claims to include in claims analysis report.

Berkeley Research Group, LLC                                                Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                           Page 8 of 21
                            Case 24-11217-BLS   Doc 735-2       Filed 11/13/24        Page 9 of 21
Date           Professional             Hours     Description

11. Claim Analysis/ Accounting

9/19/2024      A. Kashanirokh             2.7     Edited proofs of claims analysis to reflect adjustments in claims
                                                  categories.

9/19/2024      R. Cohen                   2.7     Revised claims analysis report.

9/19/2024      R. Cohen                   1.2     Reviewed claims analysis report prepared by BRG (A. Kashanirokh).

9/25/2024      R. Zaidman                 2.1     Reviewed draft BRG analysis on potential claims ranges based on
                                                  proofs of claim filed.

9/30/2024      R. Zaidman                 0.8     Analyzed filed claims pool as compared to scheduled claims by
                                                  category.

9/30/2024      R. Zaidman                 0.5     Reviewed subset of claims pool from diligence file provided by
                                                  AlixPartners (R. Robbins).

Task Code Total Hours                    44.9

17. Analysis of Historical Results

9/5/2024       R. Zaidman                 0.6     Reviewed historical liabilities for certain non-Debtor entities based on
                                                  balance sheet as of May 31, 2024.

9/12/2024      R. Zaidman                 0.8     Analyzed data room for diligence files related to certain foreign entity
                                                  financial statement re: non-Debtors.

9/12/2024      R. Zaidman                 0.6     Analyzed historical foreign entity obligations balances as of May 31,
                                                  2024.

9/13/2024      R. Zaidman                 0.9     Analyzed historical foreign entity obligations balances as of May 31,
                                                  2024 re: potential wind down liabilities.

9/16/2024      A. Kashanirokh             2.7     Prepared analyses related to the Debtors' financial position over the
                                                  last three years.

9/17/2024      R. Cohen                   1.3     Analyzed historical financials of the Debtors.

9/17/2024      R. Zaidman                 0.9     Reviewed historical cash flow activity from financial statements in
                                                  2023 re: cash outflows.

9/17/2024      D. Galfus                  0.7     Analyzed historical transactions.

9/19/2024      R. Zaidman                 2.6     Analyzed certain historical payments in the Debtors' Statement of
                                                  Financial Affairs as filed.

9/24/2024      D. Galfus                  0.7     Evaluated the foreign non-Debtor issues.

9/27/2024      R. Zaidman                 1.1     Reviewed certain historical financial data points for certain asset
                                                  based on diligence files provided by Debtors.

Task Code Total Hours                    12.9

Berkeley Research Group, LLC                                                  Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                               Page 9 of 21
                          Case 24-11217-BLS        Doc 735-2      Filed 11/13/24          Page 10 of 21
Date         Professional                  Hours     Description

18. Operating and Other Reports

9/24/2024    R. Zaidman                      1.4     Reviewed Monthly Operating Reports as filed with the Bankruptcy
                                                     Court for the month of August 2024.

Task Code Total Hours                        1.4

19. Cash Flow/Cash Management/ Liquidity

9/2/2024     R. Cohen                        2.9     Prepared slides for 9/3 DIP and liquidity report related to payments of
                                                     administrative claims.

9/2/2024     R. Cohen                        2.8     Continued to prepare slides for 9/3 DIP and liquidity report related to
                                                     payments of administrative claims.

9/2/2024     R. Zaidman                      1.0     Reviewed draft BRG reporting on forecasted liquidity through wind
                                                     down period.

9/2/2024     R. Zaidman                      0.8     Reviewed draft BRG reporting on liquidity through August 23, 2024.

9/3/2024     R. Cohen                        1.9     Edited 9/3 DIP and liquidity report based on comments from BRG
                                                     team.

9/3/2024     R. Zaidman                      1.2     Reviewed updated draft BRG reporting on liquidity through August 23,
                                                     2024.

9/3/2024     R. Zaidman                      0.9     Reviewed draft BRG reporting on liquidity as of August 23, 2024.

9/3/2024     D. Galfus                       0.9     Reviewed the report on the Debtors' liquidity through 8/23.

9/3/2024     R. Zaidman                      0.8     Analyzed liquidity wind down reporting package from AlixPartners (J.
                                                     Zermeno).

9/3/2024     D. Galfus                       0.7     Participated in a call with AlixPartners (C. Braley) re: the liquidity
                                                     forecast.

9/3/2024     R. Cohen                        0.7     Participated in a call with AlixPartners (C. Braley, M. Del Priore, J.
                                                     Zermeno) re: outstanding liquidity diligence requests.

9/3/2024     R. Zaidman                      0.7     Participated in call with AlixPartners (C. Braley, M. Del Priore, J.
                                                     Zermeno) re: liquidity and holdback reserves.

9/4/2024     A. Kashanirokh                  2.1     Prepared summary of Debtors' monthly professional fees.

9/4/2024     R. Zaidman                      1.3     Reviewed Debtors' accounts payable aging as of August 30, 2024.

9/4/2024     R. Cohen                        0.3     Participated in a call with AlixPartners (J. Zermeno, M. Del Priore) re:
                                                     variance report for the 11 weeks ended 8/23.

9/4/2024     R. Zaidman                      0.3     Participated in call with AlixPartners (M. Del Priore, J. Zermeno) re:
                                                     liquidity, cash update through August 23, 2024.



Berkeley Research Group, LLC                                                      Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                   Page 10 of 21
                          Case 24-11217-BLS        Doc 735-2      Filed 11/13/24         Page 11 of 21
Date         Professional                  Hours     Description

19. Cash Flow/Cash Management/ Liquidity

9/6/2024     A. Kashanirokh                  2.9     Prepared cash and liquidity report for weekly Committee presentation.

9/6/2024     R. Zaidman                      0.8     Analyzed latest cash activity through August 30, 2024 as sent by
                                                     AlixPartners (J. Zermeno).

9/6/2024     R. Cohen                        0.7     Reviewed variance report for the 12 weeks ended 8/30.

9/6/2024     R. Zaidman                      0.5     Compared latest cash activity through August 30, 2024 to draft budget
                                                     refresh through October 18, 2024 potential sales closing date.

9/6/2024     A. Kashanirokh                  0.5     Continued to prepare cash and liquidity report for weekly Committee
                                                     presentation.

9/9/2024     R. Zaidman                      1.5     Analyzed latest cash activity through August 30, 2024 re: remaining
                                                     liabilities.

9/9/2024     R. Cohen                        1.4     Reviewed 9/11 DIP and liquidity report for the UCC prepared by BRG
                                                     (A. Kashanirokh).

9/9/2024     A. Kashanirokh                  0.9     Edited weekly cash and liquidity analysis report based on comments
                                                     form BRG team.

9/9/2024     R. Cohen                        0.8     Compared actual results to the Debtors' 10 week forecast through
                                                     10/18.

9/9/2024     M. Haverkamp                    0.6     Developed August fee estimate for Debtors.

9/9/2024     D. Galfus                       0.4     Reviewed the Debtors' liquidity.

9/9/2024     R. Cohen                        0.2     Participated in a call with AlixPartners (J. Zermeno) re: variance report
                                                     for the 12 weeks ended 8/30.

9/9/2024     R. Zaidman                      0.2     Participated in call with AlixPartners (J. Zermeno) re: liquidity and cash
                                                     update through August 30, 2024.

9/10/2024    R. Zaidman                      1.9     Analyzed BRG analysis of certain wind down costs post sales closing.

9/10/2024    R. Cohen                        1.4     Edited 9/11 DIP and liquidity report for the UCC based on comments
                                                     from BRG team.

9/10/2024    R. Zaidman                      1.2     Reviewed draft BRG reporting on cash activity through August 30,
                                                     2024.

9/10/2024    A. Kashanirokh                  1.1     Edited weekly cash and liquidity analysis report based on comments
                                                     from BRG team.

9/10/2024    D. Galfus                       0.9     Evaluated the Debtors' latest liquidity information.

9/10/2024    R. Cohen                        0.8     Edited 9/11 DIP and liquidity report for the UCC based on comments
                                                     from BRG team.

Berkeley Research Group, LLC                                                     Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                 Page 11 of 21
                          Case 24-11217-BLS        Doc 735-2      Filed 11/13/24          Page 12 of 21
Date         Professional                  Hours     Description

19. Cash Flow/Cash Management/ Liquidity

9/10/2024    R. Zaidman                      0.8     Reviewed updated draft BRG reporting on cash activity through
                                                     August 30, 2024.

9/11/2024    A. Kashanirokh                  0.9     Updated summary of Debtors' monthly professional fees based on
                                                     comments from BRG team.

9/11/2024    A. Kashanirokh                  0.8     Revised weekly cash and liquidity report to reflect comments from
                                                     BRG team.

9/11/2024    D. Galfus                       0.4     Held call with C. Braley (AlixPartners) re: state of liquidity.

9/11/2024    R. Zaidman                      0.4     Reviewed draft BRG analysis of professional fee costs case to date.

9/12/2024    R. Zaidman                      0.5     Analyzed diligence information provided by AlixPartners (J. Zermeno)
                                                     re: certain disbursement category actual to budget to date.

9/12/2024    R. Zaidman                      0.3     Corresponded with MWE (D. Azman, K. Going, M. Kandestin) re:
                                                     certain disbursement line item in budget.

9/12/2024    D. Galfus                       0.3     Reviewed the Debtors' liquidity.

9/13/2024    A. Kashanirokh                  1.2     Drafted weekly Committee cash report detailing the Debtor's financial
                                                     position as of 9/6.

9/13/2024    R. Zaidman                      1.1     Analyzed latest DIP reporting package as sent by AlixPartners (J.
                                                     Zermeno) with cash activity through September 6, 2024.

9/13/2024    R. Cohen                        0.4     Reviewed variance report for the week ending 9/6.

9/13/2024    R. Zaidman                      0.2     Corresponded with AlixPartners (J. Zermeno) re: DIP budget extended
                                                     period.

9/16/2024    A. Kashanirokh                  2.8     Edited Committee report on budget through 10/18 based on
                                                     comments from BRG team.

9/16/2024    R. Cohen                        2.8     Reviewed 9/18 DIP and liquidity report prepared by BRG (A.
                                                     Kashanirokh).

9/16/2024    A. Kashanirokh                  2.6     Prepared variance report based on revised budget through 10/18.

9/16/2024    R. Zaidman                      1.2     Analyzed potential accounts payable roll forward based on latest cash
                                                     payments through September 6, 2024.

9/16/2024    R. Zaidman                      0.9     Participated in call with AlixPartners (J. Zermeno, M. Del Priore) re:
                                                     cash activity through September 6, 2024 and other wind down
                                                     activities.

9/16/2024    R. Cohen                        0.9     Participated on a call with AlixPartners (J. Zermeno, M. Del Priore) re:
                                                     variance reporting for the week ended 9/6.



Berkeley Research Group, LLC                                                      Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                       Page 12 of 21
                          Case 24-11217-BLS        Doc 735-2     Filed 11/13/24         Page 13 of 21
Date         Professional                  Hours     Description

19. Cash Flow/Cash Management/ Liquidity

9/16/2024    R. Zaidman                      0.8     Reviewed holdback schedule for wind down activities based on latest
                                                     cash balances and payments made.

9/17/2024    A. Kashanirokh                  2.8     Prepared slide to include in weekly Committee liquidity report
                                                     reflecting other case updates.

9/17/2024    A. Kashanirokh                  2.7     Edited weekly Committee report detailing the Debtors' liquidity
                                                     position as of 9/6 based on comments received from BRG team.

9/17/2024    R. Cohen                        1.7     Prepared analysis related to professional fees.

9/17/2024    R. Cohen                        1.4     Analyzed draft updated 13 week budget provided by the Debtors.

9/17/2024    R. Cohen                        1.2     Edited executive summary of 9/18 DIP and liquidity report based on
                                                     comments from BRG team.

9/17/2024    R. Zaidman                      1.2     Reviewed draft DIP Budget provided by AlixPartners (J. Zermeno)
                                                     through October 18, 2024.

9/17/2024    R. Zaidman                      0.7     Reviewed draft of BRG report on cash activity through September 6,
                                                     2024.

9/17/2024    R. Cohen                        0.6     Prepared slide for 9/18 DIP and liquidity report related to the
                                                     updated 13 week budget provided by the Debtors.

9/17/2024    D. Galfus                       0.6     Reviewed BRG's weekly cash and liquidity presentation for the
                                                     Committee.

9/17/2024    R. Cohen                        0.4     Edited 9/18 DIP and liquidity report based on comments from BRG
                                                     team.

9/18/2024    R. Cohen                        1.9     Edited 9/18 DIP and liquidity report based on comments from BRG
                                                     team.

9/18/2024    R. Zaidman                      0.8     Reviewed updated draft of BRG reporting re: cash activity and latest
                                                     budget through October 18, 2024.

9/18/2024    D. Galfus                       0.7     Reviewed weekly presentation for the Committee re: liquidity.

9/18/2024    R. Cohen                        0.4     Compared size of recent vendor payments to 13 week average.

9/18/2024    R. Zaidman                      0.4     Reviewed certain diligence provided by AlixPartners (J. Zermeno) re:
                                                     certain disbursement line items in latest draft DIP budget through
                                                     October 18, 2024.

9/18/2024    R. Zaidman                      0.3     Corresponded with AlixPartners (J. Zermeno) re: latest cash activity for
                                                     week ended September 13, 2024.

9/20/2024    A. Kashanirokh                  2.8     Prepared cash and liquidity report for 9/25 UCC meeting.



Berkeley Research Group, LLC                                                    Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                Page 13 of 21
                          Case 24-11217-BLS        Doc 735-2      Filed 11/13/24         Page 14 of 21
Date         Professional                  Hours     Description

19. Cash Flow/Cash Management/ Liquidity

9/20/2024    R. Zaidman                      1.4     Analyzed cash activity through September 13, 2024 as sent by
                                                     AlixPartners (J. Zermeno).

9/20/2024    D. Galfus                       0.4     Analyzed the Debtors' liquidity.

9/23/2024    R. Cohen                        2.9     Reviewed 9/25 DIP and liquidity report prepared by BRG (A.
                                                     Kashanirokh) re: variance report for the week ended 9/13.

9/23/2024    A. Kashanirokh                  2.7     Revised weekly cash report for 9/25 UCC meeting to reflect comments
                                                     form BRG team.

9/23/2024    A. Kashanirokh                  1.8     Prepared post-petition Accounts Payable schedule representing
                                                     outstanding vendor payments.

9/23/2024    R. Zaidman                      1.1     Analyzed accounts payable roll forward through September 2024 as
                                                     sent by AlixPartners (R. Robbins).

9/23/2024    R. Cohen                        0.7     Reviewed variance report for the 14 weeks ended 9/13.

9/23/2024    R. Cohen                        0.4     Continued to review 9/25 DIP and liquidity report prepared by BRG (A.
                                                     Kashanirokh) re: variance report for the week ended 9/13.

9/23/2024    R. Cohen                        0.4     Participated in a call with AlixPartners (J. Zermeno, M. Del Priore) re:
                                                     variance report for the 14 weeks ended 9/13.

9/23/2024    R. Zaidman                      0.4     Participated in call with AlixPartners (J. Zermeno, M. Del Priore) re:
                                                     cash activity through September 13, 2024.

9/23/2024    R. Zaidman                      0.3     Participated in call with AlixPartners (R. Robbins) re: cash, accounts
                                                     payable and cure costs.

9/23/2024    R. Zaidman                      0.2     Corresponded with AlixPartners (J. Zermeno) re: DIP draws.

9/24/2024    R. Cohen                        2.1     Edited 9/25 DIP and liquidity report to reflect comments from BRG
                                                     team.

9/24/2024    A. Kashanirokh                  1.4     Developed schedule of post-petition payables related to Debtors'
                                                     August Monthly Operating Report.

9/24/2024    R. Zaidman                      1.2     Reviewed draft BRG reporting on DIP variance reporting through
                                                     September 13, 2024.

9/24/2024    D. Galfus                       0.7     Reviewed BRG's 9/25 weekly report on liquidity.

9/24/2024    R. Zaidman                      0.2     Corresponded with AlixPartners (J. Zermeno) re: post-petition services
                                                     provided by Debtors to certain vendors.

9/24/2024    R. Zaidman                      0.1     Participated in call with AlixPartners (J. Zermeno) re: post-petition
                                                     cash activity.



Berkeley Research Group, LLC                                                     Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                 Page 14 of 21
                              Case 24-11217-BLS    Doc 735-2      Filed 11/13/24           Page 15 of 21
Date             Professional              Hours     Description

19. Cash Flow/Cash Management/ Liquidity

9/24/2024        R. Zaidman                  0.1     Participated in call with AlixPartners (R. Robbins) re: administrative
                                                     costs and accounts payable.

9/25/2024        D. Galfus                   0.7     Analyzed the Debtors' updated liquidity forecast.

9/25/2024        R. Zaidman                  0.7     Reviewed BRG cash reporting through September 13, 2024 as sent to
                                                     the Committee in advance of Committee call.

9/27/2024        R. Zaidman                  1.1     Reviewed post-petition accounts payable balances as of August 31,
                                                     2024 as compared to potential prepetition claims at the request of
                                                     MWE (K. Going).

9/30/2024        R. Cohen                    1.9     Reviewed 10/2 DIP and liquidity report prepared by BRG (A.
                                                     Kashanirokh).

9/30/2024        R. Zaidman                  1.1     Reviewed latest DIP variance results as of September 20, 2024.

9/30/2024        R. Zaidman                  0.6     Participated in call with AlixPartners (J. Zermeno) re: cash results as of
                                                     September 20, 2024.

9/30/2024        R. Cohen                    0.6     Participated on a call with AlixPartners (J. Zermeno) re: variance
                                                     reporting for the week ended 9/20.

Task Code Total Hours                      103.1

25. Litigation

9/3/2024         K. McColgan                 0.6     Analyzed certain historical transaction related files.

9/3/2024         K. McColgan                 0.6     Reviewed documents pertaining to an investigation related interview.

9/4/2024         K. McColgan                 1.6     Reviewed documentation pertaining to interviews related to the
                                                     investigation.

9/5/2024         D. Galfus                   0.3     Evaluated the investigation issues.

9/6/2024         K. McColgan                 1.6     Reviewed historical transaction related documents.

9/6/2024         D. Galfus                   0.9     Evaluated the status of the investigation.

9/6/2024         R. Zaidman                  0.5     Reviewed draft investigations related update from Counsel.

9/6/2024         K. McColgan                 0.4     Reviewed financial analysis related to a prepetition transaction.

9/6/2024         R. Cohen                    0.4     Reviewed MWE's summary of the investigation analysis.

9/9/2024         K. McColgan                 2.1     Reviewed certain historical transaction related documents produced.

9/9/2024         K. McColgan                 1.5     Reviewed certain historical operations materials.


Berkeley Research Group, LLC                                                     Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                  Page 15 of 21
                              Case 24-11217-BLS   Doc 735-2      Filed 11/13/24          Page 16 of 21
Date             Professional             Hours     Description

25. Litigation

9/9/2024         K. McColgan                1.1     Reviewed notes of an interview related to the investigation.

9/9/2024         K. McColgan                0.6     Commented on Counsel's draft investigations analysis document.

9/9/2024         D. Galfus                  0.6     Reviewed the investigation status.

9/9/2024         K. McColgan                0.3     Analyzed historical financial information related to the investigation.

9/9/2024         R. Zaidman                 0.3     Reviewed Counsel's investigations update edits.

9/10/2024        R. Cohen                   0.5     Reviewed draft analysis of causes of action provided by the Debtors.

9/11/2024        K. McColgan                0.4     Reviewed MWE draft investigation presentation.

9/11/2024        R. Zaidman                 0.3     Corresponded with MWE (R. Trickey) re: investigations workstream
                                                    and historical payments.

9/12/2024        D. Galfus                  0.7     Evaluated the investigation issues and status.

9/12/2024        R. Zaidman                 0.6     Reviewed investigations update from MWE.

9/13/2024        K. McColgan                0.3     Reviewed draft discovery request received from Counsel.

9/17/2024        K. McColgan                0.4     Researched historical transaction information.

9/17/2024        K. McColgan                0.2     Evaluated data related to a prepetition transaction.

9/18/2024        A. Kashanirokh             2.7     Prepared analysis related to investigation workstream.

9/18/2024        A. Kashanirokh             1.8     Prepared historical financial analyses related to the investigation.

9/18/2024        K. McColgan                0.9     Compared historical payments between two source files.

9/18/2024        R. Cohen                   0.8     Prepared summary of payments related to investigation workstream.

9/18/2024        R. Cohen                   0.6     Analyzed payments identified by the Debtors in their investigation.

9/18/2024        R. Zaidman                 0.6     Reviewed MWE investigation related materials sent to the Committee.

9/18/2024        R. Zaidman                 0.5     Reviewed draft BRG analysis related to investigations workstream.

9/19/2024        A. Kashanirokh             1.4     Prepared work product related to investigation workstream.

9/19/2024        R. Zaidman                 0.9     Analyzed certain investigations related file production related to
                                                    historical transactions.

9/19/2024        R. Cohen                   0.8     Edited summary of payments related to investigation workstream
                                                    based on comments from BRG team.

Berkeley Research Group, LLC                                                    Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                Page 16 of 21
                              Case 24-11217-BLS   Doc 735-2     Filed 11/13/24         Page 17 of 21
Date             Professional             Hours     Description

25. Litigation

9/19/2024        D. Galfus                  0.7     Evaluated the status of the investigation.

9/19/2024        K. McColgan                0.6     Reviewed documents received from Counsel related the investigation.

9/19/2024        D. Galfus                  0.6     Reviewed the Debtors' Statements and Schedules.

9/19/2024        K. McColgan                0.4     Analyzed certain payments information.

9/19/2024        K. McColgan                0.4     Reviewed summary of historical payments.

9/20/2024        A. Kashanirokh             1.5     Analyzed historical operations materials produced.

9/20/2024        K. McColgan                1.1     Reviewed documents production for relevant search terms.

9/23/2024        K. McColgan                0.6     Evaluated potential data sources related to the investigation at the
                                                    request of Counsel.

9/24/2024        A. Kashanirokh             2.7     Reviewed historical financial information.

9/24/2024        J. Rogala                  2.7     Reviewed materials related to the investigation workstream.

9/24/2024        A. Kashanirokh             2.3     Analyzed documents related to historical transactions.

9/24/2024        K. McColgan                1.9     Reviewed financial documents produced related to the investigation.

9/24/2024        R. Cohen                   1.9     Reviewed investigation related documents produced by the Debtors.

9/24/2024        R. Zaidman                 1.7     Analyzed latest investigation workstream production files at the
                                                    request of MWE.

9/24/2024        K. McColgan                1.2     Analyzed financial documents produced related to the investigation.

9/24/2024        K. McColgan                1.1     Evaluated documents identified in production pursuant to keyword
                                                    searches.

9/24/2024        K. McColgan                0.3     Summarized certain investigation related materials.

9/25/2024        J. Rogala                  2.9     Prepared summary of investigation related information.

9/25/2024        J. Rogala                  2.9     Reviewed investigation data room files pertaining to certain keyword
                                                    searches.

9/25/2024        A. Kashanirokh             2.8     Reviewed materials provided by the Debtors related to investigations
                                                    workstream.

9/25/2024        A. Kashanirokh             2.7     Reviewed historical financial information in connection with the
                                                    investigation.



Berkeley Research Group, LLC                                                    Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                              Page 17 of 21
                              Case 24-11217-BLS   Doc 735-2     Filed 11/13/24         Page 18 of 21
Date             Professional             Hours     Description

25. Litigation

9/25/2024        A. Kashanirokh             2.6     Prepared work product related to investigation workstream.

9/25/2024        K. McColgan                1.5     Reviewed document search results for certain search terms.

9/25/2024        K. McColgan                0.9     Reviewed data related to investigation workstream.

9/26/2024        J. Rogala                  2.9     Prepared summary of investigation related information.

9/26/2024        J. Rogala                  2.8     Reviewed document production materials related to the investigation
                                                    workstream.

9/26/2024        K. McColgan                2.8     Reviewed documents identified in production pursuant to keyword
                                                    searches.

9/26/2024        J. Rogala                  2.6     Prepared exhibits for reporting related to the investigation
                                                    workstream.

9/26/2024        A. Kashanirokh             2.4     Developed reporting for Counsel related to the investigation
                                                    workstream.

9/26/2024        R. Zaidman                 1.3     Reviewed certain document production files as sent by MWE.

9/27/2024        J. Rogala                  2.9     Evaluated production documents responsive to certain search terms.

9/27/2024        J. Rogala                  2.8     Reviewed investigation data room files pertaining to investigation
                                                    workstream.

9/27/2024        A. Kashanirokh             2.6     Aggregated relevant production documents related to investigations
                                                    workstream.

9/27/2024        J. Rogala                  2.6     Prepared exhibits for reporting related to the investigation
                                                    workstream.

9/27/2024        K. McColgan                2.3     Evaluated production documents responsive to keyword searches.

9/27/2024        K. McColgan                0.4     Revised work product prepared by BRG staff related to investigation
                                                    workstream.

9/30/2024        J. Rogala                  2.9     Reviewed investigation data room files pertaining to certain keyword
                                                    searches.

9/30/2024        J. Rogala                  2.8     Evaluated data room document production related to the
                                                    investigation workstream.

9/30/2024        J. Rogala                  2.7     Edited reporting related to investigation workstream.

9/30/2024        A. Kashanirokh             1.7     Edited work product related to investigation workstream.

9/30/2024        K. McColgan                1.5     Reviewed certain files produced related to the investigation.


Berkeley Research Group, LLC                                                   Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                               Page 18 of 21
                              Case 24-11217-BLS     Doc 735-2     Filed 11/13/24         Page 19 of 21
Date             Professional              Hours      Description

25. Litigation

9/30/2024        K. McColgan                  0.9     Analyzed certain financial information produced.

Task Code Total Hours                       106.7

27. Plan of Reorganization/ Disclosure Statement

9/5/2024         R. Zaidman                   1.6     Reviewed draft Plan related document received from MWE (M.
                                                      Kandestin).

9/5/2024         R. Zaidman                   1.4     Reviewed draft Disclosure Statement document received from MWE
                                                      (M. Kandestin).

9/5/2024         R. Zaidman                   1.1     Analyzed Debtors' wind down holdback schedule in context of draft
                                                      Plan and Disclosure Statement materials.

9/5/2024         D. Galfus                    0.7     Evaluated the Debtors' Plan issues.

9/5/2024         R. Zaidman                   0.7     Reviewed draft Plan related issues list from MWE (M. Kandestin).

9/5/2024         R. Zaidman                   0.4     Corresponded with MWE (M. Kandestin) re: certain financial related
                                                      Plan matters.

9/5/2024         R. Zaidman                   0.4     Reviewed correspondence from MWE (M. Gibson, R. Trickey) re: Plan
                                                      related matters.

9/6/2024         R. Cohen                     2.2     Reviewed draft of Plan of Liquidation.

9/6/2024         D. Galfus                    1.6     Reviewed the draft Plan from the Debtors.

9/6/2024         R. Zaidman                   1.2     Reviewed Plan related comments from MWE (M. Kandestin) re: draft
                                                      Committee advisors' markup.

9/6/2024         R. Zaidman                   0.8     Reviewed updated draft Plan markup from MWE (M. Kandestin).

9/6/2024         R. Zaidman                   0.2     Participated in call with MWE (M. Kandestin) re: draft Plan related
                                                      discussions.

9/9/2024         R. Zaidman                   1.6     Reviewed markup from lenders on Plan as sent by MWE (M.
                                                      Kandestin).

9/9/2024         R. Zaidman                   0.8     Reviewed UCC advisors' comments to the draft Plan.

9/9/2024         D. Galfus                    0.7     Evaluated the draft Plan.

9/10/2024        R. Zaidman                   1.1     Reviewed certain diligence provided by the Debtors as sent by MWE
                                                      (M. Kandestin) re: Plan materials.

9/10/2024        D. Galfus                    0.6     Reviewed issues with the draft Plan.




Berkeley Research Group, LLC                                                      Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                Page 19 of 21
                          Case 24-11217-BLS         Doc 735-2     Filed 11/13/24           Page 20 of 21
Date         Professional                  Hours      Description

27. Plan of Reorganization/ Disclosure Statement

9/10/2024    R. Zaidman                       0.2     Participated in call with MWE (M. Kandestin) re: Plan related
                                                      comments.

9/11/2024    R. Zaidman                       1.5     Reviewed certain legal entities referenced in the Plan re: non-Debtor
                                                      liabilities.

9/11/2024    R. Zaidman                       1.1     Reviewed certain Plan material provided by Debtors re: RSA.

9/11/2024    D. Galfus                        0.6     Reviewed issues from Counsel related to the Plan.

9/12/2024    R. Zaidman                       1.3     Reviewed Debtors' Chapter 11 Plan as filed with the Bankruptcy Court.

9/13/2024    R. Zaidman                       1.2     Reviewed Debtors' Disclosure Statement as filed with the Bankruptcy
                                                      Court.

9/18/2024    R. Zaidman                       0.6     Reviewed Plan related materials prepared by MWE for Committee
                                                      update meeting.

9/19/2024    D. Galfus                        0.8     Reviewed Plan issues impacting the unsecured creditors.

9/19/2024    R. Zaidman                       0.7     Analyzed liquidation analysis filed with the Bankruptcy Court.

9/23/2024    A. Kashanirokh                   1.8     Prepared report related to the Debtors' liquidation analysis.

9/23/2024    R. Zaidman                       1.3     Analyzed liquidation analysis as prepared by Debtors for Disclosure
                                                      Statement.

9/23/2024    A. Kashanirokh                   0.8     Analyzed the Debtors' liquidation analysis.

9/23/2024    D. Galfus                        0.5     Evaluated Plan issues.

9/24/2024    D. Galfus                        0.6     Evaluated the various Plan issues.

9/25/2024    R. Zaidman                       0.6     Reviewed MWE comments to Plan as sent by MWE (R. Trickey).

9/25/2024    R. Zaidman                       0.5     Reviewed MWE comments to Disclosure Statement as sent by MWE
                                                      (R. Trickey).

9/26/2024    A. Kashanirokh                   2.8     Analyzed Debtors' liquidation analysis.

9/26/2024    A. Kashanirokh                   2.3     Modified liquidation analysis report based on comments from BRG
                                                      team.

9/26/2024    R. Cohen                         2.2     Analyzed the Debtors' liquidation analysis.

9/26/2024    R. Zaidman                       1.4     Analyzed additional diligence supporting model provided by
                                                      AlixPartners (J. Amico) re: liquidation analysis.

9/26/2024    D. Galfus                        0.7     Reviewed the Debtors' Disclosure Statement.

Berkeley Research Group, LLC                                                     Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                Page 20 of 21
                           Case 24-11217-BLS        Doc 735-2     Filed 11/13/24        Page 21 of 21
Date          Professional                 Hours      Description

27. Plan of Reorganization/ Disclosure Statement

9/26/2024     D. Galfus                       0.4     Evaluated the Debtors' liquidation analyses.

9/27/2024     A. Kashanirokh                  1.5     Modified liquidation analysis report based on comments from BRG
                                                      team.

9/27/2024     R. Zaidman                      0.8     Reviewed draft UCC draft objection to the Disclosure Statement as
                                                      sent by MWE (C. Wurzelbacher).

9/27/2024     D. Galfus                       0.7     Evaluated the Debtors' Plan and implications on the unsecured
                                                      creditors.

9/27/2024     D. Galfus                       0.5     Held call with K. Going, MWE re: the Plan and next steps.

9/30/2024     R. Cohen                        2.3     Analyzed the Debtors' liquidation analysis and related assumptions.

9/30/2024     R. Cohen                        1.3     Reviewed report prepared by BRG (A. Kashanirokh) related to the
                                                      Debtors' liquidation analysis.

9/30/2024     R. Cohen                        1.1     Edited report prepared by BRG (A. Kashanirokh) related to the
                                                      Debtors' liquidation analysis.

9/30/2024     R. Zaidman                      0.7     Reviewed latest revisions to Plan and Disclosure Statement as sent by
                                                      MWE (K. Going).

9/30/2024     D. Galfus                       0.7     Reviewed the Plan and related reservation filed.

Task Code Total Hours                        50.6

Total Hours                                 434.5




Berkeley Research Group, LLC                                                     Invoice for the 9/1/2024 - 9/30/2024 Period
                                                                                                                  Page 21 of 21


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