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Full title: Monthly Application for Compensation (Eighth) of Dinsmore & Shohl LLP, as Supplemental Bankruptcy Counsel and Specialized Counsel for the Debtor and Debtor in Possession, for Allowance of Monthly Compensation and for Monthly Reimbursement of All Actual and Necessary Expenses for the period March 1, 2021 to March 31, 2021. Filed by Dinsmore & Shohl LLP. Objections due by 5/12/2021. (Attachments: # 1 Notice # 2 Exhibit A) (Amer, Nader) (Entered: 04/21/2021)

Document posted on Apr 20, 2021 in the bankruptcy, 12 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Shohl LLP (“Dinsmore”), as supplemental bankruptcy counsel and specialized counsel for the debtor and debtor in possession in the above-captioned case (the “Debtor”), submits this application (this “Application”) for monthly and interim allowance of compensation for professional services rendered by Dinsmore to the Debtor for the period of March 1, 2021 through and including March 31, 2021 (the “Application Period”) and reimbursement of actual and necessary expenses incurred by Dinsmore during the Application Period, pursuant to sections 330 and 331 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the United States Trustee’s Guidelines for 1 On July 30, 2020, the Debtor filed the Debtor’s Application for Entry of an Order Under Sections §§ 327(a), and 1107(b) of the Bankruptcy Code, Bankruptcy Rules 2014 and 2016, and Local Rules 2014-1 and 2016-1 Authorizing Retention and Employment of Dinsmore & Shohl LLP as Bankruptcy Conflicts Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 105)and on August 17, 2020, the Debtor filed Amended Declaration of Kim Martin Lewis in Support of the Debtor’s Application for Entry of an Order Under Sections 327(a) and 1107(b) of the Bankruptcy Code, Bankruptcy Rules 2014 and 1026, and Local Rules 2014- and 2016-1 Authorizing Retention and Employment of Dinsmore & Shohl LLP as Bankruptcy Conflicts Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 137)Authorizing Retention and Employment of Dinsmore & Shohl LLP as Supplemental Bankruptcy Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 146) (the “Dinsmore Retention Order”).Upon the filing of a Certificate of No Objection, the Debtor is authorized to pay such Professional 80 percent of the fees and 100 percent of the expenses requested in such Monthly Fee Application.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 KLAUSNER LUMBER TWO LLC Case No. 20-11518 (KBO) Debtor.1 Objection Deadline: May 12, 2021 at 4:00 p.m. (ET) EIGHTH MONTHLY FEE APPLICATION OF DINSMORE & SHOHL LLP, AS SUPPLEMENTAL BANKRUPTCY COUNSEL AND SPECIALIZED COUNSEL TO THE DEBTOR AND DEBTOR IN POSSESSION, FOR ALLOWANCE OF MONTHLY COMPENSATION AND FOR MONTHLY REIMBURSEMENT OF ALL ACTUAL AND NECESSARY EXPENSES INCURRED FOR THE PERIOD MARCH 1, 2021 THROUGH MARCH 31, 2021 Name of Applicant Dinsmore & Shohl LLP Authorized to Provide Professional Services Klausner Lumber Two, LLC (Debtor) to: Date of Retention: August 18, 2020 nunc pro tunc to July 1, 2020 Period for which compensation and March 1, 2021 through March 31, 2021 reimbursement is sought: Amount of compensation sought as actual, $39,591.00 reasonable and necessary: Amount of reimbursement of expenses sought $0.00 as actual, reasonable and necessary: This is a x monthly ____ interim ____ final application. The total time expended for fee application preparation is approximately 3.10 hours and the corresponding compensation requested is approximately $1,710.50. 1 The last four digits of the Debtor’s federal EIN are 4897. The Debtor’s mailing address is Klausner Lumber Two LLC, P.O. Box C, Redding Ridge, CT 06876.

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KLAUSNER LUMBER TWO LLC (Case No. 20-11518 (KBO)) March 1, 2021 through March 31, 2021 Name of Position of the Applicant, Hourly Total Total Professional Area of Expertise, Number of Billing Billed CompensationYears in that Position, Year Rate Hours of Obtaining License to Practice Travis M. Bayer Partner; Bankruptcy; 2 years; $695 30.40 $21,128.002012 Allison W. Bungard Partner; Labor and Employment; $505 2.10 $1,060.5014 years; 2000 John M. Spires Partner; Bankruptcy; 14 years; $420 23.70 $9,954.002006 Lisa G. Hodgdon Partner Of Counsel; Labor and $420 15.80 $6,636.00Employment; 6 months; 1997 Ryan M. Trombley Associate; Bankruptcy; 5 months; $325 2.50 $812.502018 Total: --- --- 74.50 $39,591.00 GRAND TOTAL: $39,591.00 BLENDED RATE: $531.42 ATTORNEY BLENDED RATE: $531.42

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KLAUSNER LUMBER TWO LLC (Case No. 20-11518 (KBO)) March 1, 2021 through March 31, 2021 Project Category Total Hours Total Fees Conflicts Counsel (General) 0.00 $0.00 Asset Disposition 0.00 $0.00 Assumption and Rejection of Leases and Contracts 0.00 $0.00Avoidance Actions 0.00 $0.00 Business Operations and Corporate Governance 0.00 $0.00 Case Administration 2.90 $2,015.50 Claims Administration 47.30 $25,875.00 Labor/ERISA 21.20 $9,990.00 Employment and Fee Applications and Objections 3.10 $1,710.50Financing and Cash Collateral 0.00 $0.00 Litigation 0.00 $0.00 Communications with Creditors 0.00 $0.00 Non-Working Travel 0.00 $0.00 Plan and Disclosure Statement 0.00 $0.00 Real Estate 0.00 $0.00 Relief From Stay and Adequate Protection 0.00 $0.00 TOTAL 74.50 $39,591.00

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 KLAUSNER LUMBER TWO LLC Case No. 20-11518 (KBO) Debtor.1 Objection Deadline: May 12, 2021 at 4:00 p.m. (ET) EIGHTH MONTHLY FEE APPLICATION OF DINSMORE & SHOHL LLP, AS SUPPLEMENTAL BANKRUPTCY COUNSEL AND SPECIALIZED COUNSEL TO THE DEBTOR AND DEBTOR IN POSSESSION, FOR ALLOWANCE OF MONTHLY COMPENSATION AND FOR MONTHLY REIMBURSEMENT OF ALL ACTUAL AND NECESSARY EXPENSES INCURRED FOR THE PERIOD MARCH 1, 2021 THROUGH MARCH 31, 2021 Dinsmore & Shohl LLP (“Dinsmore”), as supplemental bankruptcy counsel and specialized counsel for the debtor and debtor in possession in the above-captioned case (the “Debtor”), submits this application (this “Application”) for monthly and interim allowance of compensation for professional services rendered by Dinsmore to the Debtor for the period of March 1, 2021 through and including March 31, 2021 (the “Application Period”) and reimbursement of actual and necessary expenses incurred by Dinsmore during the Application Period, pursuant to sections 330 and 331 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the United States Trustee’s Guidelines for 1 The last four digits of the Debtor’s federal EIN are 4897. The Debtor’s mailing address is Klausner Lumber Two LLC, P.O. Box C, Redding Ridge, CT 06876.

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Reviewing Applications for Compensation and Reimbursement of Expenses filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Case, effective November 1, 2013 (the “U.S. Trustee Guidelines”), and the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals (D.I. 235) (the “Interim Compensation Procedures Order”). In support of this Application, Dinsmore represents as follows: JURISDICTION 1. This Court has jurisdiction over this Application pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The statutory predicates for the relief requested herein are sections 330 and 331 of the Bankruptcy Code, as supplemented by Bankruptcy Rule 2016, Local Rule 2016-2, the U.S. Trustee Guidelines, and the Interim Compensation Procedures Order. BACKGROUND 3. On June 10, 2020 (the “Petition Date”), the Debtor filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtor is operating its business and manages its properties as debtor in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 4. On June 25, 2020, the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”) appointed the Committee of Unsecured Creditors (the “Committee”).

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DINSMORE’S RETENTION 5. After commencing this chapter 11 case, the Debtor engaged Dinsmore to assist in reviewing and prosecuting causes of action that may exist which the Debtor’s Bankruptcy Counsel2 are unable to prosecute due to certain conflicts of interest arising either from their representation of an affiliate of the Debtor, Klausner Lumber One LLC, or their representation of certain other clients in the ordinary course of business. In addition, Dinsmore was engaged to assist with certain matters requiring specialized knowledge and experience in specific subject areas in which the Debtor’s Bankruptcy Counsel do not engage and certain other matters where the Debtor or Bankruptcy Counsel seek additional support from Dinsmore, either because of capacity constraints or otherwise. On July 30, 2020, the Debtor filed the Debtor’s Application for Entry of an Order Under Sections §§ 327(a), and 1107(b) of the Bankruptcy Code, Bankruptcy Rules 2014 and 2016, and Local Rules 2014-1 and 2016-1 Authorizing Retention and Employment of Dinsmore & Shohl LLP as Bankruptcy Conflicts Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 105) (the “Dinsmore Retention Application”) and on August 17, 2020, the Debtor filed Amended Declaration of Kim Martin Lewis in Support of the Debtor’s Application for Entry of an Order Under Sections 327(a) and 1107(b) of the Bankruptcy Code, Bankruptcy Rules 2014 and 1026, and Local Rules 2014- and 2016-1 Authorizing Retention and Employment of Dinsmore & Shohl LLP as Bankruptcy Conflicts Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 137) (the “Amended Declaration”). 6. On August 18, 2020, this Court granted the Dinsmore Retention Application pursuant to the Order Under Sections 327(a) and 1107(b) of the Bankruptcy Code, Rules 2014 and 2016, of the Federal Rules of Bankruptcy Procedure, and Local Rules 2014-1 and 2016-1 2 Capitalized terms not defined herein are defined in the Dinsmore Retention Application.

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Authorizing Retention and Employment of Dinsmore & Shohl LLP as Supplemental Bankruptcy Counsel and Specialized Counsel for the Debtor Nunc Pro Tunc to July 1, 2020 (D.I. 146) (the “Dinsmore Retention Order”). INTERIM COMPENSATION PROCEDURES ORDER 7. The Court entered the Interim Compensation Procedures Order on September 14, 2020 (D.I. 235). The Interim Compensation Procedures Order sets forth the procedures for interim compensation and reimbursement of expenses for all Professionals in this case. 8. In particular, the Interim Compensation Procedures Order provides that Professionals may file and serve a Monthly Fee Application no earlier than the 20th day of each month following the month for which compensation is sought, for interim approval and allowance of compensation for services rendered and reimbursement of expenses incurred during the immediately preceding month. Parties in interest will have 21 days (or the next business day if such day is not a business day) after the service of a Monthly Fee Application to object to the requested compensation for services rendered and reimbursement of expenses incurred. Provided that there are no objections to such Monthly Fee Application filed within 21 days after the service of the Monthly Fee Application, the Professional may file a certificate of no objection (the “Certificate of No Objection”) with the Court. 9. Upon the filing of a Certificate of No Objection, the Debtor is authorized to pay such Professional 80 percent of the fees and 100 percent of the expenses requested in such Monthly Fee Application. If a partial objection to the Monthly Fee Application is filed, then the Debtor is authorized to pay 80 percent of the fees and 100 percent of the expenses not subject to an objection.

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RELIEF REQUESTED 10. Dinsmore submits this Application for (a) allowance of reasonable compensation for the actual, reasonable, and necessary professional services that it has rendered as supplemental bankruptcy counsel and specialized counsel for the Debtor in this case during the Application Period, and (b) reimbursement of actual, reasonable, and necessary expenses incurred by Dinsmore in representing the Debtor during the Application Period. 11. During the Application Period, Dinsmore incurred fees in the amount of $39,591.00. As of the date of this Application, Dinsmore has received no payments with respect to this amount. 12. Set forth on the foregoing “Compensation by Project Category” is a summary, by subject matter category, of the time expended by Dinsmore timekeepers billing time to the Debtor’s case during the Application Period. 13. Exhibit A attached hereto contains logs, sorted by case project category, which show the time recorded by professionals, paralegals, and other support staff, as well as descriptions of the services provided. 14. Dinsmore charges $.10 per page for photocopying. 15. Dinsmore does not charge for outgoing domestic facsimiles or incoming facsimiles. 16. In accordance with Local Rule 2016-2, Dinsmore has reduced its request for compensation for non-working travel, if any, to 50% of its normal rate. 17. Dinsmore has endeavored to represent the Debtor in the most expeditious and economical manner possible. Tasks have been assigned to attorneys, paralegals, and other support staff at Dinsmore so that work has been performed by those most familiar with the particular matter or task and, where attorney or paralegal involvement was required, by the lowest hourly rate professional appropriate for a particular matter. Moreover, Dinsmore has endeavored to coordinate

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with the other professionals involved in this case so as to minimize any duplication of effort and to minimize attorneys’ fees and expenses to the Debtor. Dinsmore believes it has been successful in this regard. 18. No agreement or understanding exists between Dinsmore and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this case. 19. The undersigned has reviewed the requirements of Local Rule 2016-2 and certifies to the best of his or her information, knowledge, and belief that this Application complies with that Rule. INFORMATION RELATED TO THE REVISED U.S. TRUSTEE GUIDELINES 20. Dinsmore provides the following information pursuant to the Appendix B Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Case (the “Revised U.S. Trustee Guidelines”). 21. Dinsmore’s hourly rates for bankruptcy services are comparable to the hourly rates charged in complex chapter 11 cases by comparably skilled bankruptcy attorneys. In addition, Dinsmore’s hourly rates for bankruptcy services are comparable to the rates charged by Dinsmore, and by comparably skilled practitioners in other firms, for complex corporate and litigation matters, whether in court or otherwise, regardless of whether a fee application is required. 22. The blended hourly rate for all Dinsmore timekeepers (including both professionals and paraprofessionals) who billed to matters excluding chapter 11 representations (collectively, the “Non-Chapter 11 Matters”) during the 12-month period beginning March 31, 2020 and ending on March 31, 2021 (the “Comparable Period”) was, in the aggregate, approximately $252.19. By comparison, the blended hourly rate for all Dinsmore timekeepers (including both professionals

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and paralegals) who worked on this case during the Application Period was, in the aggregate, $531.42. 23. The following table shows blended hourly rates by category of professional and paralegals (rounded to the nearest dollar):
Table 1 on page 10. Back to List of Tables
Position at Dinsmore Blended Hourly Rate for
Application Period
Blended Hourly Rate Non-
Chapter 11 Matters
Partner $538.59 $311.33
Associate $325.00 $220.20
Paralegal N/A $126.89
24. In addition, Dinsmore provides the following responses to the inquiries stated in section C.5 of the Revised U.S. Trustee Guidelines: a. Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees or terms for services pertaining to this engagement that were provided during the application period? If so, please explain. No. b. If the fees sought in this fee application as compared to the fees budgeted for the time period covered by this fee application are higher by 10% or more, did you discuss the reasons for the variation with the client? Not applicable. c. Have any of the professionals included in this fee application varied their hourly rate based on the geographic location of the bankruptcy case? No. d. Does the fee application include time or fees related to reviewing or revising time records or preparing, reviewing, revising, or redacting invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not include reasonable fees for preparing a fee application). If so, please quantify by hours and fees. Dinsmore is seeking compensation with respect to approximately 0.70 hours and $486.50 in fees spent reviewing or revising time records and preparing, reviewing, and revising invoices during the application period. Dinsmore concurrently revised invoices for privileged information and confidential information and accordingly did not spend any additional time reviewing time records to redact such privileged or confidential information. e. If the fee application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? and (ii) Did your client agree when retaining the law firm to accept all future rate increases?

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If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation, consistent with ABA Formal Ethics Opinion 11–458? Not Applicable. WHEREFORE, Dinsmore respectfully requests that this Court (a) allow Dinsmore (i) interim compensation in the amount of $39,591.00 for actual, reasonable, and necessary professional services rendered on behalf of the Debtor during the Application Period; (b) authorize and direct the Debtor to pay to Dinsmore the amount of $31,672.80, which is equal to 80% of Dinsmore’s allowed interim compensation; and (c) grant such other and further relief as is just and proper. [Remainder of Page Intentionally Left Blank; Signature Page Follows]

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Dated: April 21, 2021 DINSMORE & SHOHL LLP Cincinnati, Ohio /s/ Travis M Bayer Travis M. Bayer (admitted pro hac vice) Kim Martin Lewis (admitted pro hac vice) 255 East 5th St., Suite 1900 Cincinnati, OH 45202 Tel: 513-977-8200 travis.bayer@dinsmore.com kim.lewis@dinsmore.com Counsel for Debtor and Debtor in Possession

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