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Full title: Interim Application for Compensation (Fourth) of Ellis & Winters LLP as North Carolina Counsel for the Debtor and Debtor In Possession, for Allowance of Compensation and Reimbursement of Actual and Necessary Expenses for the period April 1, 2021 to June 30, 2021. Filed by Ellis & Winters LLP. Hearing scheduled for 9/16/2021 at 01:00 PM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware. Objections due by 8/20/2021. (Attachments: # 1 Notice # 2 Exhibit A # 3 Exhibit B # 4 Exhibit C) (Fu, Michelle) (Entered: 07/30/2021)

Document posted on Jul 29, 2021 in the bankruptcy, 6 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

In accordance with the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals (D.I. 235) (the “Compensation Order”), Ellis & Winters LLP (“Ellis & Winters” or “Applicant”) hereby submits its fourth interim fee application request, as North Carolina counsel for the above-captioned debtor and debtor in possession Exhibits A, B, and C attached hereto, contain certain schedules 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 Cases (the “UST Guidelines”).Does the fee application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices?Does this fee application include time or fees for reviewing time records to redact any privileged or other confidential information?Winters LLP, in accordance with the Compensation Order, respectfully requests that the Court approve the full amount of fees and expenses requested in the above-referenced fee applications, payment by the Debtor of the amounts requested in such fee applications in full, and such other and further relief as is just and proper.

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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, Hearing Date: September 16, 2021 at 1:00 p.m. Debtor.1 (ET) Obj. Deadline: August 20, 2021 at 4:00 p.m. (ET) FOURTH INTERIM FEE APPLICATION OF ELLIS & WINTERS LLP AS NORTH CAROLINA COUNSEL FOR THE DEBTOR AND DEBTOR IN POSSESSION, FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF ACTUAL AND NECESSARY EXPENSES INCURRED FOR THE PERIOD APRIL 1, 2021 THROUGH JUNE 30, 2021 In accordance with the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals (D.I. 235) (the “Compensation Order”), Ellis & Winters LLP (“Ellis & Winters” or “Applicant”) hereby submits its fourth interim fee application request, as North Carolina counsel for the above-captioned debtor and debtor in possession (the “Debtor”), for allowance of monthly compensation and for monthly reimbursement of all actual and necessary expenses incurred for the period of April 1, 2021, through and including June 30, 2021 (the “Application Period”). Exhibits A, B, and C attached hereto, contain certain schedules 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 Cases (the “UST Guidelines”). In addition, Ellis & Winters LLP respectfully states as follows to address the questions set forth under paragraph C.5 of the UST 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 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.

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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? The attorneys seeking compensation in this Application varied their hourly rates in this matter. The departure from customary hourly rates was not based solely on the geographic location of the case, but was instead due to the complex nature of the Debtor’s case, the difficulty and novelty of issues presented, and experience and ability of the attorneys performing the services. 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. 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? Not applicable. The fee application does not include any rate increases since retention.

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Ellis & Winters seeks approval for the following fee applications that were filed in the Application Period: Fee Period Total Fees Total Certification Amount of Amount of Amount of pplication Covered By Requested Expenses of No Fees Allowed Expenses Holdback Feeiling Date, Application Requested Objection, (80%) Allowed Sought ocket No. Filing Date, (100%) Docket No. 7/26/2021 4/1/21- $13,542.50 $214.58 Pending $0.00 $0.00 $13,542.50 D.I. 879 6/30/21 TOTAL $13,542.50 $214.58 $0.00 $0.00 $13,542.50 WHEREFORE, Ellis & Winters LLP, in accordance with the Compensation Order, respectfully requests that the Court approve the full amount of fees and expenses requested in the above-referenced fee applications, payment by the Debtor of the amounts requested in such fee applications in full, and such other and further relief as is just and proper. Dated: July 30, 2021 Raleigh, North Carolina /s/ Charles N. Anderson, Jr. Charles N. Anderson, Jr. N.C. State Bar No. 13396 Leslie C. Packer N.C. State Bar No. 13640 ELLIS & WINTERS LLP 4131 Parklake Avenue, Suite 400 Raleigh, NC 27612 Telephone: (919) 865-7000 Facsimile: (919) 865-7010 chuck.anderson@elliswinters.com North Carolina Counsel for Debtor Klausner Lumber Two LLC

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CUMULATIVE COMPENSATION SUMMARY BY PROFESSIONAL KLAUSNER LUMBER TWO LLC (Case No. 20-11033 (KBO)) April 1, 2021 to June 30, 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 Charles N. Anderson, Jr. Partner/Creditors’ Rights. Joined firm as a $500 13.9 $6,950.00 partner in 2000; member of the N.C. Bar since August 1986; N.C. State Bar No. 13396. Pamela W. McAfee Of Counsel/Creditors’ Rights. Joined firm $425 7.1 $3,017.50 in 2020; member of N.C. Bar since August 1994; N.C. State Bar No. 21096. Teresa K. Rodriguez Bankruptcy Paralegal $250 9.5 $2,375.00 Brian Flatley Litigation Paralegal $250 3.9 $975.00 Cathy Adams Real Estate Paralegal $250 .9 $225.00 Total 35.3 $13,542.50 GRAND TOTAL: $13,542.50 BLENDED RATE: $383.64 ATTORNEY BLENDED RATE: $474.64

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CUMULATIVE COMPENSATION BY PROJECT CATEGORY KLAUSNER LUMBER TWO LLC (Case No. 20-11518 (KBO)) April 1, 2021 through June 30, 2021 Project Category Total Hours Total Fees Professional Retention Matters 3.5 $1,750.00 Litigation/Adversary Proceedings 30.8 $11,292.50 Claims Matters 1.0 $500.00 TOTAL 35.3 $13,542.50

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CUMULATIVE EXPENSE SUMMARY KLAUSNER LUMBER TWO LLC (Case No. 20-11518 (KBO)) April 1, 2021 to June 30, 2021 Expense Category Total Expenses Overnight Delivery Charges $214.58 Grand Total Expenses $214.58

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