In re Vyaire Medical, Inc. — Berkeley Research Group Fee Statement Time Detail (Oct 2024)
Summary
Exhibit A, the time detail of Berkeley Research Group, LLC for the period 10/1/2024 through 10/31/2024, filed November 25, 2024 as Doc 799-2 in In re: Vyaire Medical, Inc., et al., Case 24-11217-BLS. The exhibit lists daily entries by professional with hours and a description of work, grouped by task code. Task codes include Asset Acquisition/ Disposition, with 26.8 hours largely on the Zoll transaction; Professional Retention/ Fee Application Preparation, with 27.9 hours; Interaction/ Meetings with Creditors/ Counsel, with 19.2 hours; Claim Analysis/ Accounting, with 8.1 hours; and Plan of Reorganization/ Disclosure Statement, with 7.7 hours. The 24-page exhibit reports total hours of 573.7.
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Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 1 of 24
In re: Vyaire Medical, Inc., et al.
Exhibit A: Time Detail
Berkeley Research Group, LLC
For the Period 10/1/2024 through 10/31/2024
Date Professional Hours Description
01. Asset Acquisition/ Disposition
10/1/2024 R. Zaidman 0.4 Reviewed latest cure costs contract assumption schedule in
connection with Zoll transaction.
10/1/2024 D. Galfus 0.2 Held call with K. Going, MWE re: status of sale.
10/2/2024 R. Zaidman 0.5 Summarized latest case developments for correspondence with MWE
re: sale closings.
10/4/2024 D. Galfus 0.8 Analyzed the proposed sale cures.
10/4/2024 R. Cohen 0.3 Reviewed finalized cure schedule for the Zoll sale.
10/7/2024 D. Galfus 0.8 Participated in a call with the advisors to the Debtors (C. Braley -
AlixPartners; Y. Salloum- Kirkland & Ellis) along with Counsel (K. Going)
to address certain sale issues.
10/7/2024 R. Zaidman 0.8 Participated in call with Kirkland & Ellis (Y. Salloum, S. Toth),
AlixPartners (C. Braley, M. Del Priore, R. Robbins), and MWE (K. Going,
M. Kandestin) re: latest sales status.
10/7/2024 R. Zaidman 0.5 Evaluated recent cure costs contract assumption schedule in
connection with Zoll transaction.
10/7/2024 D. Galfus 0.5 Held call with K. Going and M. Kandestin, Counsel re: sale issues.
10/7/2024 R. Zaidman 0.5 Participated in call with MWE (K. Going, M. Kandestin) re: post call
about latest sales status with Debtors' advisors.
10/7/2024 R. Zaidman 0.2 Corresponded with AlixPartners (C. Braley) re: Zoll sale transaction
and status.
10/8/2024 D. Galfus 1.4 Analyzed the Debtors' liquidity issues related to the sale.
10/8/2024 R. Cohen 0.8 Reviewed latest draft of amendment to Zoll APA.
10/8/2024 R. Zaidman 0.7 Analyzed financial components of APA amendment re: Zoll transaction.
10/8/2024 R. Zaidman 0.3 Reviewed draft APA amendment related to Zoll transaction as sent by
MWE (M. Kandestin).
10/8/2024 R. Zaidman 0.2 Corresponded with MWE (K. Going) re: APA amendment and UCC next
steps.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 2 of 24
Date Professional Hours Description
01. Asset Acquisition/ Disposition
10/8/2024 R. Zaidman 0.2 Participated in call with MWE (M. Kandestin) re: Zoll APA amendment.
10/9/2024 R. Zaidman 0.8 Reviewed updated BRG summary of certain activity since the sales
hearing re: sales and budget status.
10/9/2024 D. Galfus 0.7 Participated in a call with the Debtors' advisors (C. Braley; AlixPartners
and Y. Salloum; Kirkland & Ellis) along with K. Going, MWE to discuss
the status of a certain sale process.
10/9/2024 R. Zaidman 0.7 Participated in call with Kirkland & Ellis (Y. Salloum, S. Toth),
AlixPartners (C. Braley, M. Del Priore, R. Robbins), and MWE (K. Going,
M. Kandestin) re: latest sales status.
10/9/2024 D. Galfus 0.6 Reviewed the status of the Debtors' sale transactions.
10/9/2024 R. Zaidman 0.3 Reviewed latest status of certain potential sale of remaining asset
from PJT (D. Friesner).
10/10/2024 A. Kashanirokh 1.5 Prepared schedule of sources and uses related to closing sale of
Debtors' ventilation business.
10/10/2024 R. Cohen 0.8 Reviewed funds flow analysis for the Zoll transaction.
10/10/2024 R. Zaidman 0.6 Reviewed additional potential cure contract assumptions from
AlixPartners (R. Robbins).
10/10/2024 R. Zaidman 0.5 Reviewed draft funds flow received from AlixPartners (J. Amico) re:
Zoll transaction.
10/10/2024 R. Zaidman 0.5 Reviewed latest cure schedule from AlixPartners (R. Robbins) re: Zoll
transaction.
10/10/2024 R. Zaidman 0.4 Reviewed updated funds flow received from AlixPartners (J. Amico) re:
Zoll transaction.
10/11/2024 R. Zaidman 1.5 Reviewed first amendment to APA as sent by Kirkland & Ellis (S. Toth)
re: Zoll transaction.
10/11/2024 A. Kashanirokh 1.2 Prepared schedule related to key differences between the Debtors'
original and revised flow of funds schedule.
10/11/2024 R. Zaidman 0.8 Analyzed certain funds flow and impact to unsecured creditor
recoveries re: Zoll transaction.
10/11/2024 D. Galfus 0.4 Evaluated the status of the Debtors' sale transactions.
10/11/2024 D. Galfus 0.4 Reviewed the Debtors' sale funds flow.
10/11/2024 R. Zaidman 0.3 Corresponded with AlixPartners (C. Braley) re: Zoll sale closing.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 2 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 3 of 24
Date Professional Hours Description
01. Asset Acquisition/ Disposition
10/11/2024 R. Zaidman 0.3 Reviewed latest correspondence from MWE (K. Going) re: UCC
member and Zoll sale closing.
10/14/2024 R. Zaidman 0.7 Reviewed assumed contract assumptions list as filed with the
Bankruptcy Court re: Zoll sale.
10/14/2024 D. Galfus 0.6 Analyzed use of proceeds from the sale.
10/14/2024 R. Zaidman 0.4 Reviewed final APA amendment as filed with the Bankruptcy Court re:
Zoll transaction.
10/14/2024 R. Zaidman 0.3 Reviewed latest status of certain foreign related asset sale.
10/18/2024 R. Zaidman 0.8 Compared prior Zoll closing schedule to latest version as provided by
AlixPartners to assess changes.
10/18/2024 R. Zaidman 0.7 Reviewed Zoll closing schedule sources and uses as provided by
AlixPartners (J. Amico).
10/22/2024 D. Galfus 0.6 Reviewed the status of the sale process.
10/23/2024 R. Zaidman 0.7 Reviewed funds flow schedule from Zoll transaction to assess sources
and uses of funds received.
10/28/2024 R. Zaidman 0.6 Reviewed certain TSA provisions to assess cost and services
reimbursable by buyers.
Task Code Total Hours 26.8
05. Professional Retention/ Fee Application Preparation
10/1/2024 M. Haverkamp 1.3 Edited August fee application.
10/1/2024 H. Henritzy 1.1 Edited August fee application.
10/1/2024 E. Degnan 0.7 Prepared August fee application.
10/2/2024 M. Haverkamp 0.9 Edited August fee application.
10/2/2024 E. Degnan 0.4 Prepared August fee application.
10/7/2024 E. Degnan 0.8 Prepared first interim fee application.
10/7/2024 M. Haverkamp 0.6 Edited August fee application.
10/7/2024 E. Degnan 0.4 Prepared September fee application.
10/7/2024 E. Degnan 0.3 Prepared August fee application.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 3 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 4 of 24
Date Professional Hours Description
05. Professional Retention/ Fee Application Preparation
10/8/2024 E. Degnan 1.8 Prepared September fee application.
10/8/2024 E. Degnan 0.7 Prepared September fee application.
10/9/2024 E. Degnan 0.2 Prepared August fee application.
10/9/2024 M. Haverkamp 0.1 Finalized August fee application for filing.
10/10/2024 M. Haverkamp 0.5 Edited first interim fee application.
10/15/2024 E. Degnan 0.1 Prepared first interim fee application.
10/16/2024 E. Degnan 1.1 Prepared September fee application.
10/16/2024 M. Haverkamp 0.7 Edited September fee application.
10/16/2024 M. Haverkamp 0.1 Edited first interim application for filing.
10/17/2024 E. Degnan 1.5 Prepared September fee application.
10/17/2024 M. Haverkamp 1.1 Edited September fee application.
10/18/2024 E. Degnan 0.2 Integrated edits for September fee application.
10/21/2024 E. Degnan 2.3 Prepared September fee application.
10/21/2024 H. Henritzy 1.8 Reviewed September fee statement.
10/21/2024 M. Haverkamp 0.3 Edited September fee application.
10/28/2024 E. Degnan 0.2 Prepared September fee application.
10/29/2024 M. Haverkamp 0.9 Edited September fee application.
10/29/2024 E. Degnan 0.9 Prepared September fee application.
10/30/2024 E. Degnan 2.9 Prepared September fee application.
10/30/2024 M. Haverkamp 2.6 Edited September fee application.
10/31/2024 E. Degnan 0.6 Prepared June/July fee detail for the fee examiner.
10/31/2024 E. Degnan 0.5 Prepared August fee detail for the fee examiner.
10/31/2024 M. Haverkamp 0.2 Reviewed files to be sent to fee examiner.
10/31/2024 M. Haverkamp 0.1 Reviewed correspondence from newly appointed fee examiner.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 4 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 5 of 24
Date Professional Hours Description
05. Professional Retention/ Fee Application Preparation
Task Code Total Hours 27.9
07. Interaction/ Meetings with Debtors/ Counsel
10/1/2024 D. Galfus 0.5 Held call with M. Del Priore (AlixPartners) re: liquidity and other
matters.
10/1/2024 R. Zaidman 0.5 Participated in call with AlixPartners (M. Del Priore) re: latest sale
closing process, cash activity, and other case matters.
10/15/2024 R. Zaidman 0.2 Corresponded with PJT (D. Friesner) re: certain sale process status and
foreign operations.
10/15/2024 R. Zaidman 0.2 Participated in call with AlixPartners (R. Robbins) re: Zoll closing and
administrative payments.
10/18/2024 D. Galfus 0.8 Participated in a call with K. Going, MWE and the Debtors' advisors (C.
Braley, AlixPartners) (Y. Salloum, S. Toth - Kirkland & Ellis) re: various
matters related to the sale closings and liquidity forecast.
10/18/2024 R. Zaidman 0.8 Participated in call with Kirkland & Ellis (Y. Salloum, S. Toth),
AlixPartners (C. Braley, M. Del Priore, R. Robbins), and MWE (K. Going,
M. Kandestin) re: case status and Zoll closing matters.
10/31/2024 R. Zaidman 0.2 Participated in call with AlixPartners (R. Robbins) re: 503b9 claims and
other cash matters.
Task Code Total Hours 3.2
08. Interaction/ Meetings with Creditors/ Counsel
10/1/2024 R. Zaidman 1.0 Participated in call with MWE (K. Going, M. Kandestin, C. C.
Wurzelbacher) re: sale closing, cash, and UCC workstreams.
10/8/2024 D. Galfus 0.7 Participated in a call with Counsel (K. Going) in preparation for
upcoming Committee call.
10/8/2024 R. Zaidman 0.7 Participated in call with MWE (K. Going, M. Kandestin) re: case status,
UCC workstreams, and Zoll closing issues.
10/8/2024 R. Zaidman 0.5 Reviewed UCC motion for status conference to be filed with the
Bankruptcy Court.
10/9/2024 R. Zaidman 0.4 Reviewed correspondence from MWE (K. Going) re: Debtors and UCC
case status.
10/10/2024 D. Galfus 1.0 Participated in a call with K. Going, MWE and the Committee re: the
Debtors' sale process, other case matters, and timing.
10/10/2024 R. Zaidman 1.0 Participated in call with UCC and MWE (K. Going, M. Kandestin) re:
case status.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 5 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 6 of 24
Date Professional Hours Description
08. Interaction/ Meetings with Creditors/ Counsel
10/10/2024 R. Zaidman 0.6 Reviewed materials for UCC call circulated by MWE (R. Trickey) in
advance of UCC call.
10/11/2024 D. Galfus 1.0 Participated in a call with K. Going, MWE and a certain creditor re: the
state of the operations.
10/11/2024 D. Galfus 0.4 Held call with K. Going, MWE re: the Debtors' sale process and other
matters.
10/15/2024 R. Zaidman 1.3 Participated in call with MWE (K. Going, M. Kandestin) re: case status
and UCC workstreams.
10/15/2024 D. Galfus 0.8 Participated in a portion of a call with (K. Going and M. Kandestin;
MWE) re: sale closing and related matters.
10/16/2024 R. Zaidman 1.2 Participated in call with MWE (K. Going, M. Kandestin) re: case status
and UCC workstreams.
10/22/2024 D. Galfus 1.3 Participated in a call with Counsel (K. Going; M. Kandestin) re: a
potential settlement.
10/22/2024 R. Zaidman 1.3 Participated in call with MWE (K. Going, M. Kandestin) re: case status,
UCC pre call, and next steps.
10/23/2024 D. Galfus 0.9 Participated in a call with the Committee and Counsel (K. Going) re:
Plan issues, case status and next steps.
10/23/2024 R. Zaidman 0.9 Participated in call with UCC and MWE (K. Going, M. Kandestin) re:
case status.
10/24/2024 D. Galfus 0.5 Held call with K. Going, MWE re: discussions with the Debtors about
the settlement.
10/24/2024 R. Zaidman 0.5 Participated in call with MWE (K. Going) re: potential settlement.
10/28/2024 D. Galfus 0.2 Held call with Counsel (K. Going) re: settlement discussions with the
Debtors.
10/28/2024 R. Zaidman 0.2 Participated in call with MWE (K. Going) re: administrative costs and
discussions with Debtors' advisors.
10/29/2024 D. Galfus 0.2 Held call with K. Going, MWE re: status of settlement discussions with
the Debtors.
10/29/2024 R. Zaidman 0.2 Participated in call with MWE (M. Kandestin, C. Wurzelbacher, K.
Newsome) re: Plan supplement and case workstreams.
10/30/2024 D. Galfus 0.6 Participated in a call with MWE (M. Kandestin; K. Going) and the
Committee re: settlement discussion and next steps.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 6 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 7 of 24
Date Professional Hours Description
08. Interaction/ Meetings with Creditors/ Counsel
10/30/2024 D. Galfus 0.6 Participated in a call with MWE (M. Kandestin; K. Going) in
preparation for upcoming Committee call.
10/30/2024 R. Zaidman 0.6 Participated in call with MWE (K. Going-partial, M. Kandestin) re:
Committee pre call and Committee next steps.
10/30/2024 R. Zaidman 0.6 Participated in call with UCC and MWE (K. Going, C. Wurzelbacher) re:
Committee status and discussions with Debtors and lenders.
Task Code Total Hours 19.2
11. Claim Analysis/ Accounting
10/1/2024 R. Zaidman 2.1 Reviewed latest BRG analysis on claims pool range based on latest
filed claims.
10/1/2024 D. Galfus 1.1 Analyzed the Debtors' claims information.
10/1/2024 R. Cohen 0.8 Updated claims analysis to reflect comments from BRG team.
10/7/2024 R. Zaidman 0.9 Reviewed certain classification of filed claims re: claims pool sizing.
10/7/2024 R. Cohen 0.3 Analyzed priority unsecured claims.
10/8/2024 R. Zaidman 0.4 Reviewed potential draft Debtors' settlement with certain claimant as
sent by MWE (R. Trickey).
10/16/2024 R. Cohen 1.1 Analyzed schedule provided by the Debtors related to payment of
administrative claims.
10/21/2024 R. Zaidman 0.7 Analyzed latest contract rejection contract listing to assess potential
claims impact.
10/30/2024 R. Zaidman 0.3 Reviewed Zoll transactions funds flow to assess latest status of
503(b)(9) claim payments at the request of MWE (K. Going).
10/30/2024 R. Zaidman 0.2 Corresponded with AlixPartners (R. Robbins) re: payment of certain
prepetition claims.
10/31/2024 R. Zaidman 0.2 Corresponded with UCC member related to 503(b)(9) claims.
Task Code Total Hours 8.1
14. Executory Contracts/ Leases
10/18/2024 R. Zaidman 0.6 Reviewed second notice of contract rejections as filed with the
Bankruptcy Court.
10/18/2024 R. Zaidman 0.4 Reviewed third notice of contract rejections as filed with the
Bankruptcy Court.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 7 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 8 of 24
Date Professional Hours Description
14. Executory Contracts/ Leases
10/21/2024 D. Galfus 0.4 Reviewed status of contract rejections.
10/28/2024 R. Zaidman 0.4 Reviewed certain executory contract release notices as filed with the
Bankruptcy Court.
10/31/2024 R. Zaidman 0.4 Reviewed Bankruptcy Court filing from certain creditor re: motion to
compel and executory contract assumption or rejection.
Task Code Total Hours 2.2
18. Operating and Other Reports
10/22/2024 R. Zaidman 1.2 Reviewed Monthly Operating Reports filed by Debtors with
Bankruptcy Court for the month of September 2024.
10/23/2024 R. Zaidman 0.4 Reviewed MWE discussion materials as presented to the Committee
on various legal related case matters.
Task Code Total Hours 1.6
19. Cash Flow/Cash Management/ Liquidity
10/1/2024 A. Kashanirokh 2.8 Prepared weekly cash and liquidity report for the week ending 9/20
related to weekly UCC meeting.
10/1/2024 A. Kashanirokh 2.7 Prepared weekly cash variance report related to Debtors' variance
report for the week ended 9/20.
10/1/2024 R. Cohen 2.6 Edited 10/2 DIP and liquidity based on comments from BRG team.
10/1/2024 A. Kashanirokh 2.3 Edited weekly cash variance report related to Debtors' variance report
for the week ended 9/20.
10/1/2024 R. Cohen 1.5 Continued to edit 10/2 DIP and liquidity based on comments from BRG
team.
10/1/2024 R. Zaidman 1.3 Reviewed draft BRG reporting on latest cash activity through
September 20, 2024.
10/1/2024 R. Cohen 1.0 Reviewed updated liquidation analysis report prepared by junior staff.
10/2/2024 A. Kashanirokh 2.6 Edited liquidation analysis report to reflect comments from BRG team.
10/2/2024 R. Cohen 1.9 Updated 10/2 DIP and liquidity report to reflect comments form BRG
team.
10/2/2024 R. Zaidman 1.1 Reviewed updated BRG reporting on cash activity through September
20, 2024.
10/2/2024 R. Cohen 0.4 Reviewed updated liquidation analysis report prepared by junior staff.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 8 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 9 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/4/2024 R. Cohen 0.3 Reviewed variance report for the 16 weeks ended 9/27.
10/7/2024 A. Kashanirokh 2.8 Edited weekly cash and liquidity report related to 10/9 weekly UCC
meeting based on comments from BRG team.
10/7/2024 A. Kashanirokh 2.7 Prepared weekly cash and liquidity report related to 10/9 weekly UCC
meeting.
10/7/2024 R. Cohen 1.4 Reviewed draft of 10/9 DIP and liquidity report prepared by junior
staff.
10/7/2024 R. Zaidman 1.0 Analyzed certain potential wind down cost line items based on call
with Debtors' advisors.
10/7/2024 R. Cohen 0.4 Reviewed variance reporting for the week ended 9/27.
10/7/2024 R. Cohen 0.2 Participated in a call with AlixPartners (J. Zermeno) re: variance
reporting for the week ended 9/27.
10/7/2024 R. Zaidman 0.2 Participated in call with AlixPartners (J. Zermeno) re: cash results as of
September 27, 2024.
10/8/2024 R. Cohen 2.9 Continued to prepare presentation for Counsel related to changes to
obligations of the Debtors' estate.
10/8/2024 R. Cohen 2.9 Prepared presentation for Counsel related to changes to obligations of
the Debtors' estate.
10/8/2024 R. Cohen 2.7 Edited executive summary of 10/9 DIP and liquidity report based on
latest update provided by the Debtors.
10/8/2024 R. Cohen 2.1 Edited 10/9 DIP and liquidity report to reflect comments from BRG
team.
10/8/2024 R. Cohen 2.0 Continued to prepare presentation for Counsel related to changes to
obligations of the Debtors' estate.
10/8/2024 A. Kashanirokh 1.9 Prepared timeline of key events related to Debtors' financial position
over the last 5 weeks.
10/8/2024 A. Kashanirokh 1.7 Edited weekly cash and liquidity report related to 10/9 weekly UCC
meeting based on comments from BRG team.
10/8/2024 A. Kashanirokh 1.7 Prepared report related to the timeline of key events related to
Debtors' financial position over the last 5 weeks.
10/8/2024 R. Zaidman 1.2 Reviewed draft BRG reporting on cash activity through September 27,
2024 and latest case developments.
10/8/2024 R. Zaidman 0.7 Reviewed updated draft BRG reporting on cash activity through
September 27, 2024 and latest case developments.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 9 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 10 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/8/2024 D. Galfus 0.6 Revised BRG's 10/9 weekly presentation for the Committee re:
liquidity.
10/9/2024 R. Cohen 2.6 Edited 10/10 DIP and liquidity report to reflect latest updates from the
Debtors.
10/9/2024 A. Kashanirokh 1.7 Edited weekly cash and liquidity report related to 10/9 weekly UCC
meeting based on comments from BRG team.
10/9/2024 R. Zaidman 1.3 Reviewed updated draft BRG reporting on cash activity through
September 27, 2024 re: latest case developments.
10/9/2024 R. Zaidman 1.1 Reviewed latest diligence file provided by AlixPartners (J. Zermeno) re:
updated wind down budget estimate.
10/9/2024 R. Cohen 1.0 Edited 10/9 DIP and liquidity report to reflect updates from
discussions with the Debtors' advisors.
10/9/2024 D. Galfus 0.8 Evaluated the Debtors' current liquidity situation.
10/9/2024 R. Cohen 0.7 Reviewed draft revised holdback schedule provided by the Debtors.
10/10/2024 R. Cohen 2.7 Edited 10/10 DIP and liquidity report to reflect latest updates from the
Debtors and comments from BRG team.
10/10/2024 R. Zaidman 0.4 Participated in call with AlixPartners (J. Zermeno) re: liquidity and
wind down reserves.
10/10/2024 R. Zaidman 0.3 Reviewed updated draft BRG reporting on cash activity through
September 27, 2024 re: latest case developments.
10/11/2024 A. Kashanirokh 2.9 Prepared weekly cash and liquidity report related to 10/16 weekly
UCC meeting.
10/11/2024 R. Zaidman 1.3 Reviewed cash results activity through October 4, 2024 as sent by
AlixPartners (J. Zermeno).
10/11/2024 D. Galfus 0.9 Analyzed the Debtors' liquidity situation.
10/11/2024 A. Kashanirokh 0.7 Continued to prepare weekly cash and liquidity report related to
10/16 weekly UCC meeting.
10/11/2024 D. Galfus 0.7 Reviewed BRG's revised presentation for the Committee re: the
Debtors' liquidity.
10/11/2024 R. Zaidman 0.5 Reviewed variance reporting certificate sent by MWE (M. Kandestin)
re: cash reporting through September 27, 2024.
10/14/2024 A. Kashanirokh 2.8 Edited weekly cash and liquidity report related to 10/16 weekly UCC
meeting based on comments received from BRG team.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 10 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 11 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/14/2024 R. Zaidman 1.3 Analyzed potential go forward cash requirements beyond current
budget end date of October 18, 2024 based on latest cash activity
through October 4, 2024.
10/14/2024 R. Zaidman 0.8 Reviewed actual cash activity through October 4, 2024 as compared to
forecasted budget results.
10/14/2024 R. Cohen 0.5 Participated in a call with AlixPartners (J. Zermeno) re: variance report
for the 17 weeks ended 10/4.
10/14/2024 R. Zaidman 0.5 Participated in call with AlixPartners (J. Zermeno) re: cash results as of
October 4, 2024.
10/14/2024 R. Cohen 0.4 Reviewed variance report for the 17 weeks ended 10/4.
10/15/2024 A. Kashanirokh 2.7 Modified weekly cash and liquidity report related to 10/16 weekly UCC
meeting to reflect comments from BRG team.
10/15/2024 R. Cohen 2.4 Reviewed 10/16 DIP and liquidity report prepared by junior staff.
10/15/2024 R. Zaidman 1.1 Reviewed draft BRG analysis on cash activity through October 4, 2024
as compared to DIP budget.
10/16/2024 R. Zaidman 0.8 Analyzed alternative scenarios related to forecasted cash needs
through Plan confirmation.
10/16/2024 R. Zaidman 0.7 Reviewed updated draft BRG analysis on cash activity through October
4, 2024 as compared to DIP budget.
10/17/2024 R. Zaidman 0.9 Compared historical accounts payable schedule as of August 2024 to
latest post petition payments schedule.
10/17/2024 R. Zaidman 0.6 Reviewed updated draft of BRG reporting for the UCC with cash
activity through October 4, 2024.
10/17/2024 R. Zaidman 0.5 Reviewed forecasted payments to be made by Debtors in connection
with post petition accounts payable related to Zoll transaction.
10/17/2024 R. Zaidman 0.2 Corresponded with AlixPartners (R. Robbins) re: accounts payable
balances for certain creditors related to Zoll transaction.
10/18/2024 A. Kashanirokh 2.8 Prepared report for weekly UCC meeting related to the Debtors'
financial position as of 10/23.
10/18/2024 A. Kashanirokh 1.2 Prepared schedule related to the Debtors' estimated post petition
accounts payable balance.
10/18/2024 R. Cohen 0.9 Reviewed analysis prepared by junior staff related to post petition
payables.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 11 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 12 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/18/2024 R. Zaidman 0.9 Reviewed latest cash reporting activity through October 11, 2024 as
provided by AlixPartners (J. Zermeno).
10/18/2024 D. Galfus 0.5 Analyzed the Debtors' forecasted liquidity.
10/18/2024 R. Zaidman 0.5 Reviewed latest accounts payable balances for certain post-petition
vendors as sent by AlixPartners (C. Chen).
10/18/2024 R. Zaidman 0.2 Corresponded with AlixPartners (C. Chen) re: questions related to
accounts payable balances.
10/18/2024 R. Zaidman 0.2 Participated in call with MWE (K. Going) re: cash and wind down
reserves.
10/21/2024 R. Zaidman 0.9 Analyzed latest professional fee costs incurred as compared budgeted
escrow to date.
10/21/2024 R. Zaidman 0.7 Analyzed latest DIP reporting package of cash activity through October
11, 2024.
10/21/2024 R. Zaidman 0.6 Analyzed potential go forward budget cost requirements based on
latest cash activity.
10/21/2024 R. Zaidman 0.5 Participated in call with AlixPartners (J. Zermeno) re: cash activity
through October 11, 2024.
10/21/2024 R. Cohen 0.3 Reviewed extended DIP budget provided by the Debtors.
10/22/2024 A. Kashanirokh 2.8 Modified weekly cash report for UCC meeting on 10/23 to reflect
comments from BRG team.
10/22/2024 R. Cohen 2.3 Reviewed 10/23 DIP and liquidity report prepared by junior staff
related to the variance reporting for the week ended 10/13.
10/22/2024 R. Zaidman 0.8 Analyzed draft BRG analysis of cash activity through October 11, 2024.
10/22/2024 D. Galfus 0.7 Evaluated the Debtors' forecasted liquidity position.
10/22/2024 R. Zaidman 0.5 Reviewed latest escrowed detail through October 11, 2024 for
professional fees in diligence file sent by AlixPartners (J. Zermeno).
10/22/2024 R. Cohen 0.4 Updated analysis related to professional fees to reflect latest
information.
10/23/2024 A. Kashanirokh 2.6 Edited 10/23 weekly cash report to reflect comments received from
BRG team.
10/23/2024 R. Cohen 1.7 Edited 10/23 DIP and liquidity report to reflect comments from BRG
team.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 12 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 13 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/23/2024 R. Zaidman 0.6 Analyzed draft BRG analysis on certain disbursement lines items to
date at the request of MWE (M. Kandestin).
10/23/2024 R. Zaidman 0.5 Reviewed update draft of BRG analysis related to cash activity through
October 11, 2024.
10/23/2024 R. Zaidman 0.3 Corresponded with AlixPartners (J. Zermeno) re: escrowed funds for
Zoll transaction and forecasted payments.
10/24/2024 R. Zaidman 0.8 Compared prior wind down estimate detail provided by Debtors to
latest information communicated on the call with AlixPartners.
10/24/2024 R. Cohen 0.8 Participated in a call with AlixPartners (J. Zermeno and M. Del Priore)
re: extended DIP budget and wind down budget.
10/24/2024 D. Galfus 0.8 Participated in a call with AlixPartners (M. Del Priore) re: the go
forward budget.
10/24/2024 R. Zaidman 0.8 Participated in call with AlixPartners (J. Zermeno, M. Del Priore, J.
Amico) re: latest draft budget and cash.
10/24/2024 R. Zaidman 0.7 Corresponded with MWE (K. Going) re: call with AlixPartners on
budget extension and wind down.
10/24/2024 R. Zaidman 0.5 Reviewed potential transaction fee terms and amounts accrued by
Debtors.
10/25/2024 A. Kashanirokh 2.8 Prepared cash and liquidity report related to weekly UCC meeting on
10/30.
10/25/2024 A. Kashanirokh 0.9 Prepared schedule of Debtors' post petition accounts payable as of
10/28.
10/25/2024 R. Zaidman 0.8 Reviewed latest cash reporting activity through October 18, 2024 as
provided by AlixPartners (J. Zermeno).
10/25/2024 R. Zaidman 0.7 Reviewed Debtors' reporting on first day payments made for the
month of September 2024.
10/25/2024 R. Zaidman 0.6 Prepared draft analysis of projected wind down costs as compared to
prior version prepared by Debtors.
10/25/2024 R. Zaidman 0.5 Reviewed latest proposed administrative payments to be made by
Debtors as sent by AlixPartners (R. Robbins).
10/25/2024 R. Zaidman 0.4 Reviewed latest proposed assumed liabilities and payments from the
Zoll transaction.
10/25/2024 R. Zaidman 0.2 Drafted responses to questions from AlixPartners (R. Robbins) re:
questions related to payments to be made by Debtors.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 13 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 14 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/28/2024 A. Kashanirokh 2.6 Modified cash and liquidity report for UCC meeting on 10/30.
10/28/2024 R. Cohen 1.6 Reviewed draft of report prepared by junior staff related to variance
report for the week ended 10/18.
10/28/2024 R. Zaidman 1.1 Analyzed latest payments made by Debtors related to post petition
trade payables.
10/28/2024 R. Zaidman 0.9 Compared receipts collected in cash activity through October 18, 2024
to DIP budget.
10/28/2024 R. Zaidman 0.8 Reviewed disbursement line items in latest actual activity through
October 18, 2024.
10/28/2024 D. Galfus 0.6 Analyzed the Debtors' forecasted liquidity.
10/28/2024 R. Cohen 0.4 Reviewed variance report for the week ended 10/18.
10/28/2024 R. Zaidman 0.3 Corresponded with AlixPartners (C. Braley, M. Del Priore) re: diligence
questions related to extended cash budget.
10/28/2024 R. Zaidman 0.3 Corresponded with MWE (K. Going) re: administrative costs, post-
petition trade payables.
10/28/2024 R. Cohen 0.3 Participated in a call with AlixPartners (J. Zermeno) related to variance
report for the week ended 10/18.
10/28/2024 R. Zaidman 0.3 Participated in call with AlixPartners (J. Zermeno, C. Chen) re: cash
activity through October 18, 2024.
10/29/2024 R. Cohen 2.9 Continued to prepare Committee report related to extended DIP
budget through 11/15 and wind down budget.
10/29/2024 R. Cohen 2.9 Prepared Committee report related to extended DIP budget through
11/15 and wind down budget.
10/29/2024 A. Kashanirokh 2.7 Modified cash and liquidity report for 10/30 UCC meeting to reflect
BRG team comments.
10/29/2024 R. Zaidman 1.2 Reviewed draft BRG analysis related to extended budget through
November 15, 2024.
10/29/2024 R. Zaidman 1.1 Compared prior wind down holdback reserve detail to latest estimate
per Plan supplement.
10/29/2024 R. Zaidman 1.1 Reviewed diligence file provided by AlixPartners (J. Zermeno) re:
extended budget through November 15, 2024.
10/29/2024 R. Cohen 0.7 Continued to prepare Committee report related to extended DIP
budget through 11/15 and wind down budget.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 14 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 15 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/29/2024 R. Zaidman 0.6 Analyzed line item detail of international obligation adjustments from
Zoll transaction re: remaining obligations for the estate in wind down.
10/29/2024 R. Zaidman 0.2 Analyzed forecasted wind down budget included in the Plan
supplement as filed with the Bankruptcy Court.
10/29/2024 R. Zaidman 0.1 Corresponded with AlixPartners (C. Braley, M. Del Priore) re: diligence
questions related to extended cash budget.
10/30/2024 R. Cohen 2.9 Edited 10/30 liquidity report to reflect comments from BRG team.
10/30/2024 A. Kashanirokh 2.9 Edited cash and liquidity model to reflect changes in Debtors' new DIP
budget.
10/30/2024 A. Kashanirokh 2.8 Continued to edit cash and liquidity model to reflect changes in
Debtors' new DIP budget.
10/30/2024 A. Kashanirokh 2.8 Prepared schedule of Debtors' updated wind down budget in
comparison to previous version.
10/30/2024 A. Kashanirokh 2.7 Prepared cash variance model to reflect Debtors' updated DIP budget.
10/30/2024 D. Galfus 0.8 Revised BRG's 10/30 weekly presentation for the Committee re:
liquidity issues.
10/30/2024 R. Zaidman 0.7 Reviewed slides in the 10/30 draft report for the UCC related to
updated budget through November 15, 2024.
10/30/2024 R. Zaidman 0.6 Reviewed slides in the 10/30 draft report for the UCC related to wind
down budget.
10/30/2024 R. Zaidman 0.5 Reviewed updated version of BRG's 10/30 UCC reporting re: budget
through November 15, 2024 and wind down.
10/30/2024 R. Zaidman 0.4 Reviewed further updated version of BRG's 10/30 UCC reporting re:
budget through November 15, 2024 and wind down.
10/30/2024 D. Galfus 0.4 Reviewed the updated liquidity forecast from the Debtors.
10/30/2024 R. Cohen 0.2 Continued to edit 10/30 liquidity report to reflect comments from BRG
team.
10/31/2024 A. Kashanirokh 2.7 Reviewed documents related to Debtors' financial forecast for the
next three years.
10/31/2024 A. Kashanirokh 2.3 Reviewed Debtors' lender presentation materials related to liquidity.
10/31/2024 R. Zaidman 0.6 Analyzed latest status of administrative payments made to date versus
latest draft of operative cash budget through November 18, 2024.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 15 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 16 of 24
Date Professional Hours Description
19. Cash Flow/Cash Management/ Liquidity
10/31/2024 R. Zaidman 0.6 Reviewed underlying diligence file related to wind down reserve
budget.
10/31/2024 D. Galfus 0.3 Analyzed status of administrative payments in the budget.
Task Code Total Hours 167.0
25. Litigation
10/1/2024 J. Rogala 2.9 Reviewed investigation data room files pertaining to certain keyword
searches performed by Counsel.
10/1/2024 J. Rogala 2.9 Reviewed investigation data room files re: emails and email
attachments.
10/1/2024 J. Rogala 2.6 Continued to review investigation data room files pertaining to certain
keyword searches performed by Counsel.
10/1/2024 K. McColgan 0.9 Reviewed documents included in data room re: investigation.
10/1/2024 D. Galfus 0.9 Reviewed the status of the investigation.
10/1/2024 R. Cohen 0.7 Reviewed draft of report prepared by junior staff related to litigation
workstream.
10/1/2024 K. McColgan 0.6 Reviewed certain documents from investigation data room production.
10/1/2024 K. McColgan 0.6 Revised summary for transactions report.
10/2/2024 J. Rogala 2.9 Prepared summary of certain transactions as it relates to the
investigation workstream
10/2/2024 J. Rogala 2.9 Reviewed investigation data room files for certain emails and email
attachments.
10/2/2024 A. Kashanirokh 2.7 Prepared analysis as it relates to the investigation workstream
10/2/2024 J. Rogala 2.5 Continued to review investigation data room files for certain emails
and email attachments.
10/2/2024 J. Rogala 2.4 Continued to prepare summary of certain transactions as it relates to
the investigation workstream
10/2/2024 R. Zaidman 1.7 Reviewed latest production files related to certain financial statement
results and disclosures.
10/2/2024 A. Kashanirokh 1.6 Reviewed data room documents related to the Debtors' sponsor re:
investigation workstream
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 16 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 17 of 24
Date Professional Hours Description
25. Litigation
10/2/2024 K. McColgan 1.1 Reviewed documents included in data room related to prepetition
transactions re: investigation.
10/2/2024 K. McColgan 0.4 Reviewed financial statement disclosures re: investigation.
10/3/2024 J. Rogala 2.9 Reviewed investigation data room files pertaining to certain keyword
searches performed by Counsel.
10/3/2024 J. Rogala 2.9 Reviewed investigation data room files.
10/3/2024 J. Rogala 2.7 Continued to review investigation data room files pertaining to certain
keyword searches performed by Counsel.
10/3/2024 J. Rogala 1.7 Continued to review investigation data room files.
10/3/2024 K. McColgan 0.4 Reviewed documents included in data room related to prepetition
transactions re: investigation.
10/4/2024 J. Rogala 2.9 Reviewed investigation data room files re: emails and email
attachments.
10/4/2024 J. Rogala 2.8 Reviewed investigation data room files.
10/4/2024 J. Rogala 2.7 Continued to review investigation data room files re: emails and email
attachments.
10/7/2024 J. Rogala 2.9 Reviewed investigation data room files re: email exchanges.
10/7/2024 J. Rogala 2.7 Evaluated investigation data room files re: email exchanges.
10/7/2024 A. Kashanirokh 2.6 Analyzed historical presentation materials provided by the Debtors
related to investigations workstream.
10/7/2024 J. Rogala 2.5 Continued to evaluate investigation data room files re: email
exchanges.
10/7/2024 J. Rogala 1.4 Continued to evaluate investigation data room files re: email
exchanges.
10/8/2024 J. Rogala 2.9 Reviewed investigation data room files re: email exchanges.
10/8/2024 J. Rogala 2.8 Continued to review investigation data room files re: email exchanges.
10/8/2024 A. Kashanirokh 2.8 Reviewed data room document production re: investigation
10/8/2024 J. Rogala 2.7 Continued to review investigation data room files re: email exchanges.
10/8/2024 J. Rogala 0.7 Continued to review investigation data room files re: email exchanges.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 17 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 18 of 24
Date Professional Hours Description
25. Litigation
10/9/2024 J. Rogala 2.9 Reviewed email exchanges produced as part of the investigation
10/9/2024 J. Rogala 2.8 Reviewed investigation data room files using keyword searches from
UCC Counsel.
10/9/2024 A. Kashanirokh 2.4 Reviewed data room document production re: investigation
10/9/2024 J. Rogala 2.3 Continued to review email exchanges produced as part of the
investigation
10/9/2024 J. Rogala 1.8 Continued to review investigation data room files using keyword
searches from UCC Counsel.
10/9/2024 A. Kashanirokh 1.4 Analyzed supporting files provided by the Debtors related to
investigations workstream.
10/10/2024 J. Rogala 2.9 Reviewed email exchanges produced as part of the investigation
10/10/2024 J. Rogala 2.9 Reviewed investigation data room files using keyword searches from
UCC Counsel.
10/10/2024 A. Kashanirokh 2.7 Reviewed documents related to Debtors' email exchanges re:
investigation.
10/10/2024 A. Kashanirokh 2.6 Analyzed Debtors' historical financial documents related to
investigations workstream.
10/10/2024 J. Rogala 2.6 Continued to review investigation data room files using keyword
searches from UCC Counsel.
10/10/2024 J. Rogala 1.7 Continued to review email exchanges produced as part of the
investigation
10/10/2024 R. Zaidman 1.2 Analyzed certain litigation related workstream items re: diligence files.
10/11/2024 J. Rogala 2.9 Reviewed investigation related document production
10/11/2024 J. Rogala 2.8 Continued to review investigation related document production
10/11/2024 J. Rogala 2.5 Continued to review investigation related document production
10/11/2024 A. Kashanirokh 2.1 Analyzed Debtors' historical financial documents related to
investigations workstream.
10/14/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room on
10/14.
10/14/2024 A. Kashanirokh 2.9 Reviewed documents using keyword search provided by Counsel.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 18 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 19 of 24
Date Professional Hours Description
25. Litigation
10/14/2024 J. Rogala 2.8 Reviewed documents from new production uploaded to data room on
10/14 using keyword searches provided by Counsel.
10/14/2024 J. Rogala 2.6 Continued to review documents from new production uploaded to
data room on 10/14.
10/14/2024 A. Kashanirokh 2.6 Continued to review documents using keyword search provided by
Counsel.
10/15/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room on
10/14 using keyword searches provided by Counsel.
10/15/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room on
10/14.
10/15/2024 A. Kashanirokh 2.8 Reviewed key documents found in the data room related to email
exchanges re: investigation.
10/15/2024 J. Rogala 2.7 Continued to review documents from new production uploaded to
data room on 10/14 using keyword searches provided by Counsel.
10/15/2024 A. Kashanirokh 2.7 Reviewed documents found in the data room related to potential
transactions re: investigation.
10/15/2024 J. Rogala 1.6 Continued to review documents from new production uploaded to
data room on 10/14.
10/15/2024 R. Zaidman 1.2 Reviewed certain BRG analysis related to investigation at the request
of MWE re: certain historical transaction and activity.
10/15/2024 D. Galfus 0.9 Reviewed the status of the investigation of historical transactions.
10/16/2024 A. Kashanirokh 2.8 Analyzed Debtors' internal board presentation re: investigation
workstream.
10/16/2024 A. Kashanirokh 2.8 Reviewed interview notes found in data room for details related to a
certain historical transaction.
10/16/2024 A. Kashanirokh 2.6 Prepared report detailing a timeline of a certain historical transaction.
10/16/2024 J. Rogala 1.6 Revised investigation related presentation to incorporate comments
from BRG team.
10/16/2024 R. Zaidman 0.9 Reviewed certain BRG analysis related to the investigation to send to
MWE (M. Kandestin, K. Going, K. Newsome).
10/16/2024 R. Zaidman 0.7 Reviewed supporting data corresponding to BRG analysis related to
investigation workstream re: historical activity and transactions.
10/16/2024 K. McColgan 0.3 Attended call with K. Going, M. Kandestin (MWE) to review
investigation status updates and results of document review to date.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 19 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 20 of 24
Date Professional Hours Description
25. Litigation
10/16/2024 K. McColgan 0.3 Reviewed documents included in data room re: investigation.
10/16/2024 K. McColgan 0.3 Reviewed summary timeline and presentation draft to Counsel for call
today on document review investigation status to date.
10/17/2024 A. Kashanirokh 2.8 Reviewed data room document production using keyword search
provided by Counsel.
10/17/2024 A. Kashanirokh 2.7 Reviewed documents found in data room related to investigation
workstream.
10/17/2024 J. Rogala 2.6 Evaluated documents from new production uploaded to data room on
10/14.
10/17/2024 R. Zaidman 1.8 Reviewed additional supporting data related to investigation
workstream re: certain historical financial statements.
10/17/2024 R. Zaidman 0.7 Reviewed certain updated to BRG analysis related to investigation
workstream re: historical activity and transactions.
10/18/2024 J. Rogala 2.9 Reviewed certain investigation related documents from new
production uploaded to data room on 10/14.
10/18/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room on
10/14 based on keyword searches provided by Counsel.
10/18/2024 A. Kashanirokh 2.7 Reviewed Debtors' presentation materials related to investigation
workstream.
10/18/2024 J. Rogala 2.4 Continued to review certain investigation related documents from
new production uploaded to data room on 10/14.
10/21/2024 A. Kashanirokh 2.9 Analyzed email exchanges related to the Debtors' historical
transactions.
10/21/2024 J. Rogala 2.9 Evaluated documents from new production uploaded to data room on
10/14 using keyword searches provided by Counsel.
10/21/2024 J. Rogala 2.8 Reviewed documents produced re: investigation workstream.
10/21/2024 A. Kashanirokh 2.7 Continued to analyze email exchanges related to the Debtors'
historical transactions.
10/21/2024 J. Rogala 2.7 Continued to evaluate documents from new production uploaded to
data room on 10/14 using keyword searches provided by Counsel.
10/21/2024 A. Kashanirokh 2.5 Reviewed Debtors' presentation materials related to investigations
workstream.
10/21/2024 J. Rogala 1.4 Continued to review documents produced re: investigation
workstream.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 20 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 21 of 24
Date Professional Hours Description
25. Litigation
10/21/2024 K. McColgan 0.4 Reviewed timeline schedule and underlying documents.
10/22/2024 J. Rogala 2.9 Analyzed production documents uploaded to data room on 10/14
using keyword searches provided by Counsel.
10/22/2024 J. Rogala 2.9 Reviewed documents produced re: investigation workstream.
10/22/2024 A. Kashanirokh 2.7 Reviewed documents related to the historical sale transactions.
10/22/2024 J. Rogala 2.4 Continued to review documents produced re: investigation
workstream.
10/22/2024 A. Kashanirokh 2.4 Prepared analysis as it relates to the investigation workstream
10/22/2024 R. Zaidman 0.7 Reviewed latest BRG summary related to certain investigation
workstream items at the request of MWE.
10/22/2024 K. McColgan 0.6 Reviewed timeline schedule and underlying documents.
10/23/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room.
10/23/2024 J. Rogala 2.9 Reviewed new production documents uploaded to data room on
10/14 using keyword searches provided by Counsel.
10/23/2024 J. Rogala 2.8 Continued to review documents from new production uploaded to
data room.
10/23/2024 A. Kashanirokh 2.7 Reviewed data room documents related to certain transactions re:
investigation workstream
10/23/2024 A. Kashanirokh 2.4 Reviewed documents related to a transaction with respect to the
investigation workstream
10/23/2024 J. Rogala 1.6 Reviewed data room documents related to a certain transaction re:
investigation.
10/23/2024 K. McColgan 0.9 Reviewed relevant documents with respect to potential transaction re:
investigation.
10/24/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room.
10/24/2024 J. Rogala 2.8 Reviewed documents from new production uploaded to data room re:
investigation.
10/24/2024 A. Kashanirokh 2.8 Reviewed historical financial documents related to Debtors' financial
position in the last 3 years.
10/24/2024 A. Kashanirokh 2.7 Analyzed documents found in data room related to a certain historical
transaction re: Investigation.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 21 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 22 of 24
Date Professional Hours Description
25. Litigation
10/24/2024 J. Rogala 2.4 Continued to review documents from new production uploaded to
data room re: investigation.
10/24/2024 J. Rogala 1.8 Continued to review documents from new production uploaded to
data room.
10/24/2024 K. McColgan 0.6 Reviewed relevant documents with respect to potential transaction re:
investigation.
10/25/2024 A. Kashanirokh 2.9 Analyzed documents found in data room related to a certain historical
transaction re: Investigation.
10/25/2024 J. Rogala 2.9 Continued to review communications included in data room
production re: investigation workstream
10/25/2024 J. Rogala 2.9 Reviewed communications included in data room production re:
investigation workstream
10/25/2024 J. Rogala 2.4 Continued to review communications included in data room
production re: investigation workstream
10/25/2024 A. Kashanirokh 1.8 Continued to analyze documents found in data room related to a
certain historical transaction re: Investigation.
10/25/2024 R. Zaidman 0.9 Reviewed investigation related workstream items at the request of
MWE (M. Kandestin).
10/25/2024 K. McColgan 0.2 Corresponded with Counsel (M. Kandestin) re: document review
findings related to litigation.
10/28/2024 J. Rogala 2.9 Evaluated communications included in data room production re:
investigation workstream
10/28/2024 J. Rogala 2.8 Continued to evaluate communications included in data room
production re: investigation workstream
10/28/2024 A. Kashanirokh 2.8 Reviewed documents from new production uploaded to data room re:
investigation.
10/28/2024 J. Rogala 2.7 Continued to evaluate communications included in data room
production re: investigation workstream
10/28/2024 A. Kashanirokh 2.7 Reviewed emails produced as it relates to the investigation
10/28/2024 J. Rogala 1.9 Continued to evaluate communications included in data room
production re: investigation workstream
10/29/2024 J. Rogala 2.9 Reviewed documents uploaded to the data room re: investigation.
10/29/2024 J. Rogala 2.7 Reviewed documents from new production uploaded to data room re:
investigation.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 22 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 23 of 24
Date Professional Hours Description
25. Litigation
10/29/2024 A. Kashanirokh 2.6 Reviewed data room document production re: investigation
10/29/2024 J. Rogala 2.5 Continued to review documents uploaded to the data room re:
investigation.
10/29/2024 A. Kashanirokh 2.4 Reviewed Debtors' presentation materials related to investigation
workstream.
10/29/2024 J. Rogala 2.1 Continued to review documents uploaded to the data room re:
investigation.
10/30/2024 J. Rogala 2.9 Reviewed data room documents related to historical transactions re:
investigation.
10/30/2024 J. Rogala 2.6 Continued to review data room documents related to historical
transactions re: investigation.
10/30/2024 J. Rogala 2.5 Continued to review data room documents related to historical
transactions re: investigation.
10/30/2024 J. Rogala 1.9 Continued to review data room documents related to historical
transactions re: investigation.
10/31/2024 J. Rogala 2.9 Reviewed documents from new production uploaded to data room
using keyword searches provided by Counsel.
10/31/2024 J. Rogala 2.8 Reviewed data room documents related to historical transactions re:
investigation.
10/31/2024 A. Kashanirokh 2.8 Reviewed documents related to Debtors' historical email exchanges.
10/31/2024 J. Rogala 2.4 Continued to review documents from new production uploaded to
data room using keyword searches provided by Counsel.
Task Code Total Hours 310.0
27. Plan of Reorganization/ Disclosure Statement
10/3/2024 D. Galfus 0.7 Evaluated recovery Plan issues for the Committee.
10/24/2024 D. Galfus 0.7 Evaluated proposed settlement terms.
10/24/2024 R. Zaidman 0.7 Reviewed correspondence from MWE (K. Going) re: communications
with Debtors' counsel and unsecured creditors related to potential
settlement.
10/25/2024 D. Galfus 0.7 Assessed proposed settlement terms and related responses.
10/25/2024 R. Zaidman 0.5 Reviewed response from Debtors' counsel to MWE related to
potential settlement.
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 23 of 24
Case 24-11217-BLS Doc 799-2 Filed 11/25/24 Page 24 of 24
Date Professional Hours Description
27. Plan of Reorganization/ Disclosure Statement
10/25/2024 R. Zaidman 0.3 Reviewed correspondence by MWE (K. Going) to Committee re:
potential settlement.
10/25/2024 D. Galfus 0.1 Held call with K. Going, MWE re: discussions with the Debtors about
the settlement.
10/28/2024 R. Cohen 1.3 Reviewed Plan supplement that was filed with the Court.
10/29/2024 R. Zaidman 0.8 Reviewed Plan supplement as filed by the Debtors in the Bankruptcy
Court.
10/29/2024 D. Galfus 0.7 Analyzed the latest term sheet from Counsel.
10/29/2024 R. Zaidman 0.5 Reviewed potential settlement framework regarding unsecured
creditors re: Plan.
10/30/2024 R. Zaidman 0.3 Reviewed proposed change in executory contract language in Plan
from Cole Schotz (M. Percontino).
10/31/2024 D. Galfus 0.4 Evaluated certain settlement terms.
Task Code Total Hours 7.7
Total Hours 573.7
Berkeley Research Group, LLC Invoice for the 10/1/2024 - 10/31/2024 Period
Page 24 of 24
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