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Full title: Monthly Application for Compensation (Eleventh) of Morris Nichols Arsht & Tunnell LLP, as Bankruptcy Co-Counsel and Delaware 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 May 1, 2021 to May 31, 2021. Filed by Morris Nichols Arsht & Tunnell LLP. Objections due by 7/13/2021. (Attachments: # 1 Notice # 2 Exhibit A # 3 Exhibit B) (Amer, Nader) (Entered: 06/22/2021)

Document posted on Jun 21, 2021 in the bankruptcy, 13 pages and 0 tables.

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Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”), as bankruptcy co-counsel and Delaware counsel for the debtor and debtor in possession in the above-captioned case (the “Debtor”), submits this application (the “Application”) for monthly and interim allowance of compensation for professional services rendered by Morris Nichols to the Debtor for the period of May 1, 2021 through May 31, 2021 (the “Application Period”) and reimbursement of actual and necessary expenses incurred by Morris Nichols 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 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 5 On June 25, 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 Morris, Nichols, Arsht & Tunnell LLP as Bankruptcy Co-Counsel and Delaware Counsel for the Debtor Nunc Pro Tunc to the Petition Date (D.I. 29) (the “Morris Nichols Retention Application”).Court granted the Morris, Nichols 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 Authorizing Retention and Employment of Morris, Nichols, Arsht & Tunnell LLP as Bankruptcy Co-Counsel and Delaware Counsel for the Debtor Nunc Pro Tunc to the Petition Date (D.I. 51) (the “Morris Nichols Retention Order”).Set forth on the foregoing “Compensation by Project Category” is a summary, by subject matter category, of the time expended by Morris Nichols timekeepers billing time to the Debtor’s case during the Application Period.In addition, Morris Nichols’s hourly rates for bankruptcy services are comparable to the rates charged by Morris Nichols, 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.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re Case No. 20-11518 (KBO) KLAUSNER LUMBER TWO LLC, Objection Deadline: Debtor.1 July 13, 2021 at 4:00 p.m. ELEVENTH MONTHLY FEE APPLICATION OF MORRIS, NICHOLS, ARSHT & TUNNELL LLP, AS BANKRUPTCY CO-COUNSEL AND DELAWARE COUNSEL FOR 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 MAY 1, 2021 THROUGH MAY 31, 2021 Name of Applicant: MORRIS, NICHOLS, ARSHT & TUNNELL LLP Authorized to Provide Professional Services to: Debtor Date of Retention: July 14, 2020, nunc pro tunc to June 10, 2020 Period for which compensation and reimbursement is sought: May 1, 2021 through May 31, 2021 Amount of compensation sought as actual, reasonable and necessary: $63,962.00 Amount of reimbursement sought as actual, reasonable and necessary: $548.77 This is a x monthly application final application The total time expended for fee application preparation is approximately 7.0 hours and the corresponding compensation requested is approximately $2,935.002 1 The last four digits of the Debtor’s EIN are 4897. The Debtor’s mailing address is P.O. Box C, Redding Ridge CT, 06876. 2 Allowance for compensation for such time is not requested in this application but will be sought in a subsequent fee application.

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If this is not the first application filed, disclose the following for each prior application: DATE PERIOD REQUESTED APPROVED FILED COVERED FEES/EXPENSES FEES/EXPENSES 10/06/20 6/10/20-7/31/20 $243,114.50/$2,033.27 $243,114.50/$2,033.27 D.I. 290 10/7/20 8/1/20-8/31/20 $138,082.50/$1,462.38 $138,082.50/$1,462.38 D.I. 294 10/21/20 9/1/20-9/30/20 $149,436.50/$327.83 $149,001.003/$327.83 D.I. 345 11/23/20 10/1/20-10/31/20 $189,626.50/$2,412.88 $188,980.504/$2,412.88 D.I. 428 1/20/21 11/1/20-11/30/20 $160,120.50/$1,169.60 $160,120.50/$1,169.60 D.I. 564 1/21/21 12/1/20-12/31/20 $101,329.00/$250.50 $101,329.00/$250.50 D.I. 566 3/1/21 1/1/21-1/31/21 $96,500.50/$304.92 $96,500.50/$304.92 D.I. 649 4/8/21 2/1/21-2/28/21 $51,815.00/$124.54 $51,815.00/$124.54 D.I. 712 4/20/21 3/1/21-3/31/21 $64,340.00/$34.91 $64,340.00/$34.91 D.I. 728 6/22/21 4/1/21-4/30/21 $68,746.00/$93.91 Pending D.I. 824 3 Includes a voluntary reduction of $435.50 in fees and 0.9 hours agreed with the US Trustee. 4 Includes a voluntary reduction of $646.00 in fees agreed with the US Trustee, as reflected in D.I. 715.

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COMPENSATION BY PROFESSIONAL KLAUSNER LUMBER TWO, LLC (Case No. 20-11518 (KBO)) May 1, 2021 through May 31, 2021 Name of Professional Position of the Applicant, Area of Hourly Total Total Expertise, Number of Years in that Billing Billed Compensation Position, Year of Obtaining License Rate Hours to Practice Eric D. Schwartz Partner/Bankruptcy. Partner since 2002. 995 27.3 27,163.50 Joined firm as an associate in 1999. Member of the DE Bar since 1992. Daniel B. Butz Special Counsel/Bankruptcy. Joined the 795 33.6 26,712.00 firm as an associate in 2002. Member of the DE Bar since 2002. Nader A. Amer Associate/Bankruptcy. Joined the firm 495 5.7 2,821.50 as an associate in 2019. Member of the DE Bar since 2019. Michelle M. Fu Associate/Bankruptcy. Joined the firm 495 7.5 3,712.50 as an associate in 2019. Member of the DE Bar since 2019. Byron Poland Litigation Support 350 0.4 140.00 Desiree M. Vale Paralegal 345 4.3 1,483.50 Meghan E. Leyh Paralegal 345 1.2 414.00 Vicki L. O'Neill Paralegal 345 4.1 1,414.50 Cherie L. Hare Legal Assistant 335 0.3 100.50 Total 757.84 84.4 $63,962.00 GRAND TOTAL: $63,962.00 BLENDED RATE: $757.84 ATTORNEY BLENDED RATE: $815.24

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COMPENSATION BY PROJECT CATEGORY KLAUSNER LUMBER TWO, LLC (Case No. 20-11518 (KBO)) May 1, 2021 through May 31, 2021 Project Category Total Hours Total Fees Case Administration 9.40 4,482.00 Fee Applications (MNAT - Filing) 1.70 1,166.50 Fee Applications (Others - Filing) 5.70 2,511.50 Other Contested Matters 36.30 31,218.50 Financing Matters/Cash Collateral 0.40 288.00 Tax Matters 0.20 179.00 Insurance Matters 0.10 99.50 Court Hearings 1.10 544.50 Claims Objections and Administration 20.60 17,387.00 Plan and Disclosure Statement 0.20 199.00 Litigation/Adversary Proceedings 3.60 2,432.00 General Case Strategy 4.50 2,987.50 Schedules/SOFA/U.S. Trustee Reports 0.60 467.00 TOTAL 84.40 $63,962.00

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EXPENSE SUMMARY KLAUSNER LUMBER TWO, LLC (Case No. 20-11518 (KBO)) May 1, 2021 through May 31, 2021 Expense Category Total Expenses In-House Printing - black & white 27.70 Courier/Delivery Service 12.15 Pacer 5.40 Court Costs 350.00 Conference Calls 153.52 Grand Total Expenses $548.77

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 In re Case No. 20-11518 (KBO) KLAUSNER LUMBER TWO LLC, Objection Deadline: Debtor.5 July 13, 2021 at 4:00 p.m. ELEVENTH MONTHLY FEE APPLICATION OF MORRIS, NICHOLS, ARSHT & TUNNELL LLP, AS BANKRUPTCY CO-COUNSEL AND DELAWARE COUNSEL FOR 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 MAY 1, 2021 THROUGH MAY 31, 2021 Morris, Nichols, Arsht & Tunnell LLP (“Morris Nichols”), as bankruptcy co-counsel and Delaware counsel for the debtor and debtor in possession in the above-captioned case (the “Debtor”), submits this application (the “Application”) for monthly and interim allowance of compensation for professional services rendered by Morris Nichols to the Debtor for the period of May 1, 2021 through May 31, 2021 (the “Application Period”) and reimbursement of actual and necessary expenses incurred by Morris Nichols 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 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 5 The last four digits of the Debtor’s EIN are 4897. The Debtor’s mailing address is P.O. Box C, Redding Ridge CT, 06876.

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Professionals (D.I. 235) (the “Interim Compensation Procedures Order”). In support of this Application, Morris Nichols 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. On April 30, 2020 (the “Affiliate Petition Date”), the Debtor’s affiliate, Klausner Lumber One LLC, filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code, which is being administered separate and apart from the Debtor’s case 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. 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”). MORRIS NICHOLS’S RETENTION 4. Before commencing this chapter 11 case, the Debtor retained Morris Nichols to assist in advising, preparing for, and commencing its case under chapter 11 of the Bankruptcy Code. On June 25, 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

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and 2016, and Local Rules 2014-1 and 2016-1 Authorizing Retention and Employment of Morris, Nichols, Arsht & Tunnell LLP as Bankruptcy Co-Counsel and Delaware Counsel for the Debtor Nunc Pro Tunc to the Petition Date (D.I. 29) (the “Morris Nichols Retention Application”). 5. On July 14, 2020, this Court granted the Morris, Nichols 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 Authorizing Retention and Employment of Morris, Nichols, Arsht & Tunnell LLP as Bankruptcy Co-Counsel and Delaware Counsel for the Debtor Nunc Pro Tunc to the Petition Date (D.I. 51) (the “Morris Nichols Retention Order”). INTERIM COMPENSATION PROCEDURES ORDER 6. The Court entered the Interim Compensation Procedures Order on September 14, 2020. The Interim Compensation Procedures Order sets forth the procedures for interim compensation and reimbursement of expenses for all Professionals in this case. 7. 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.

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8. 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. RELIEF REQUESTED 9. Morris Nichols submits this Application for (a) allowance of reasonable compensation for the actual, reasonable, and necessary professional services that it has rendered as bankruptcy co-counsel and Delaware counsel for the Debtor in this case during the Application Period and (b) reimbursement of actual, reasonable, and necessary expenses incurred by Morris Nichols in representing the Debtor during the Application Period. 10. During the Application Period, Morris Nichols incurred fees in the amount of $63,962.00. For the same period, Morris Nichols incurred actual, reasonable, and necessary expenses totaling $548.77. As of the date of this Application, Morris Nichols has received no payments with respect to these amounts. 11. Set forth on the foregoing “Compensation by Project Category” is a summary, by subject matter category, of the time expended by Morris Nichols timekeepers billing time to the Debtor’s case during the Application Period. 12. Exhibit A attached hereto contains logs, sorted by case project category, which show the time recorded by professionals, paraprofessionals, and other support staff, as well as descriptions of the services provided. 13. Exhibit B attached hereto contains a breakdown of actual, reasonable, and necessary expenses incurred by Morris Nichols during the Application Period.

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14. Morris Nichols charges $.10 per page for photocopying and $0.05 per page for printing. 15. Morris Nichols does not charge for outgoing domestic facsimiles or incoming facsimiles. 16. In accordance with Local Rule 2016-2, Morris Nichols has reduced its request for compensation for non-working travel, if any, to 50% of its normal rate. 17. Morris Nichols 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 Morris Nichols 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, Morris Nichols has endeavored to coordinate with Westerman Ball Ederer Miller Zucker & Sharfstein, LLC and 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. Morris Nichols believes it has been successful in this regard. 18. No agreement or understanding exists between Morris Nichols 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. Morris Nichols provides the following information pursuant to the Appendix B Guidelines for Reviewing Applications for Compensation and Reimbursement of

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Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Case (the “Revised U.S. Trustee Guidelines”). 21. Morris Nichols’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, Morris Nichols’s hourly rates for bankruptcy services are comparable to the rates charged by Morris Nichols, 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 Morris Nichols timekeepers who worked on this case is approximately the same as the firm’s blended rate for all timekeepers over a Comparable Period (defined below). In particular, the blended hourly rate for all Morris Nichols 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 May 31, 2020 and ending on May 31, 2021 (the “Comparable Period”) was, in the aggregate, approximately $678.96. By comparison, the blended hourly rate for all Morris Nichols timekeepers (including both professionals and paraprofessionals) who worked on this case during the Application Period was, in the aggregate, $757.84. 23. The following table shows blended hourly rates by category of professional and paraprofessional (rounded to the nearest dollar):
Table 1 on page 11. Back to List of Tables
Position at Morris Nichols Blended Hourly Rate for
Application Period
Blended Hourly Rate Non-
Chapter 11 Matters
Partner $995 $885
Associate $495 $526
Special Counsel $795 $678
Paralegal $345 $283
Legal Assistants $335 $293
All Timekeepers $758 $679

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24. In addition, Morris Nichols 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, or revising 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. No. Morris Nichols reserves the right to seek such fees in subsequent applications. e. Does this fee application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees. No. f. 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? 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 Effective January 1, 2021, Morris Nichols has implemented firm-wide rate increases. These rate increases are consistent with the Engagement Letter, which provides that the rates included therein are adjusted from time to time and specifically at the beginning of each year. The Notice of Rate Change was filed on December 14, 2020 (D.I. 493). [Remainder of Page Intentionally Left Blank]

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WHEREFORE, Morris Nichols respectfully requests that this Court (a) allow Morris Nichols (i) interim compensation in the amount of $63,962.00 for actual, reasonable, and necessary professional services rendered on behalf of the Debtor during the Application Period; and (ii) interim reimbursement in the amount of $548.77 for actual, reasonable, and necessary expenses incurred during the Application Period; (b) authorize and direct the Debtor to pay to Morris Nichols the amount of $51,718.37, which is equal to the sum of 80% ($51,169.60) of Morris Nichols’s allowed interim compensation and 100% ($548.77) of Morris Nichols’s allowed expense reimbursement; and (c) grant such other and further relief as is just and proper. Dated: June 22, 2021 MORRIS, NICHOLS, ARSHT & TUNNELL LLP Wilmington, Delaware /s/ Nader A. Amer Robert J. Dehney (No. 3578) Eric D. Schwartz (No. 3134) Daniel B. Butz (Bar No. 4227) Nader A. Amer (Bar No. 6635) 1201 North Market Street, 16th Floor P.O. Box 1347 Wilmington, Delaware 19899-1347 Telephone: (302) 658-9200 Facsimile: (302) 658-3989 Email: dbutz@morrisnichols.com namer@morrisnichols.com - and – WESTERMAN BALL EDERER MILLER ZUCKER & SHARFSTEIN, LLP Thomas A. Draghi (admitted pro hac vice) Alison M. Ladd (admitted pro hac vice) 1201 RXR Plaza Uniondale, NY 11556 Tel: 516-622-9200 Email: tdraghi@westermanllp.com aladd@westermanllp.com Counsel for Debtor and Debtor in Possession

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