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Full title: Application for Compensation -- Fourth Interim Fee Application of Foley & Lardner LLP, Lead Counsel to the Official Committee of Unsecured Creditors, for the period February 1, 2021 to April 30, 2021 Filed by Official Committee of Unsecured Creditors. Hearing scheduled for 7/15/2021 at 02:00 PM at US Bankruptcy Court, 824 Market St., 6th Fl., Courtroom #3, Wilmington, Delaware. Objections due by 6/22/2021. (Attachments: # 1 Notice # 2 Exhibits # 3 Verification # 4 Certificate of Service) (Keilson, Brya) (Entered: 06/01/2021)

Document posted on May 31, 2021 in the bankruptcy, 12 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

FOURTH INTERIM FEE APPLICATION OF FOLEY & LARNDER LLP FOR COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF KLAUSNER LUMBER ONE LLC FOR THE PERIOD FEBRUARY 1, 2021 THROUGH APRIL 30, 2021 Foley & Lardner LLP (“Foley” or the “Applicant”), counsel to the Official Committee of Unsecured Creditors (the “Committee”) of Klausner Lumber One LLC (the “Debtors”), hereby files its Third Interim Fee Application of Foley & Lardner LLP, Counsel for the Official Committee of Unsecured Creditors for Allowance of Compensation and Reimbursement of Expenses for the Period from February 1, 2021 through April 30, 2021 (the “Application”) for entry of an order pursuant to section 331 of title 11 of the United States Code, 11 U.S.C. §§101 et seq., as amended (the “Bankruptcy Code”) for allowance of interim compensation for professional in the amount of $167,096.00 and reimbursement of expenses in the amount of $689.43 for the period from February 1, 2021 through April 30, 2021 (the “Interim Compensation Period”), in support thereof, Foley respectfully represents as follows: JURISDICTION AND VENUE 1. Since its retention, Foley, in its capacity as lead counsel for the committee, undertook the following: • Reviewed, revised, and filed and served, all papers filed by the Committee in these cases, including without limitation relating to the bidding procedures and sale schedule, and sale and plan support agreement; • Reviewed substantially all of the papers filed by the Debtors and others in these cases; • Prepared applications for compensation and/or reimbursement of expenses on behalf of Committee professionals and members; • Attended Committee meetings, and responded to inquiries from individual creditors; • Communicated with counsel to the Debtors, the United States Trustee, and lenders regarding issues, as necessary; and • By the Sixth Monthly Application, Foley sought approval of compensation of $182,554.00 and reimbursement of expenses in the amount of $1,550.59 for the period of October 1, 2020 through October 31, 2020.By the Seventh Monthly Application, Foley sought approval of compensation of $116,316.50 and reimbursement of expenses in the amount of $1,019.04 for the period of November 1, 2020 through November 30, 2020.On January 22, 2021, Foley filed its eighth monthly application for compensation and reimbursement of expenses [Docket No. 674] (the “Eighth Monthly Application”).

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter: 11 KLAUSNER LUMBER ONE LLC, Case No. 20-11033 (KBO) Debtor.1 Objection Deadline: June 22, 2021 at 4:00 p.m. (ET) Hearing Date: July 15, 2021 at 2:00 p.m. (ET) FOURTH INTERIM FEE APPLICATION OF FOLEY & LARDNER LLP FOR COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS LEAD COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF KLAUSNER LUMBER ONE LLC, FOR THE PERIOD FEBRUARY 1, 2021 THROUGH APRIL 30, 2021 Name of Applicant: Foley & Lardner LLP Authorized to Provide Professional Services to: Official Committee of Unsecured Creditors Date of Retention: Nunc pro tunc to May 26, 2020 Period for which compensation and reimbursement are sought: February 1, 2021 through April 30, 2021 Amount of Compensation sought as actual, reasonable and necessary: $167,096.00 Amount of Expense Reimbursement sought as actual, reasonable and necessary: $689.43 This is a(n): monthly X interim ___ final application 1 The last four digits of the Debtor’s federal EIN is 9109. The Debtor’s mailing address is Klausner Lumber One LLC, P.O. Box 878, Middleburg, VA 20118.

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Table 1 on page 2. Back to List of Tables
Monthly Fee
Application
Filing Date
& Docket
No.
Period
Covered
Total Fees
Requested
Total
Expenses
Requested
CNO
Filing
Date &
Docket
No.
Amount of
Fees
Authorized
to be Paid
[80%]
Amount of
Expenses
Authorized to
be Paid
[100%]
3/22/2021
[ECF No.
809]
2/1/2021-
2/28/2021
$100,760.50 $689.43 4/13/2021
[ECF No.
847]
$80,608.40 $689.43
4/20/2021
[ECF No.
865]
3/1/2021 –
3/31/2021
$25,635.00 $0.00 5/12/2021
[ECF No.
893]
$20,508.00 $0.00
5/20/2021
[ECF No.
919]
4/1/2021 –
4/30/2021
$40,700.50 $0.00 $32,560.40 $0.00
TOTAL None $167,096.00 $689.43 $133,676.80 $689.43

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter: 11 KLAUSNER LUMBER ONE LLC, Case No. 20-11033 (KBO) Debtor.1 Objection Deadline: June 22, 2021 at 4:00 p.m. (ET) Hearing Date: July 15, 2021 at 2:00 p.m. (ET) FOURTH INTERIM FEE APPLICATION OF FOLEY & LARNDER LLP FOR COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF KLAUSNER LUMBER ONE LLC FOR THE PERIOD FEBRUARY 1, 2021 THROUGH APRIL 30, 2021 Foley & Lardner LLP (“Foley” or the “Applicant”), counsel to the Official Committee of Unsecured Creditors (the “Committee”) of Klausner Lumber One LLC (the “Debtors”), hereby files its Third Interim Fee Application of Foley & Lardner LLP, Counsel for the Official Committee of Unsecured Creditors for Allowance of Compensation and Reimbursement of Expenses for the Period from February 1, 2021 through April 30, 2021 (the “Application”) for entry of an order pursuant to section 331 of title 11 of the United States Code, 11 U.S.C. §§101 et seq., as amended (the “Bankruptcy Code”) for allowance of interim compensation for professional in the amount of $167,096.00 and reimbursement of expenses in the amount of $689.43 for the period from February 1, 2021 through April 30, 2021 (the “Interim Compensation Period”), in support thereof, Foley respectfully represents as follows: JURISDICTION AND VENUE 1. This Court has jurisdiction over this Application pursuant to 28 U.S.C. §1334. This is a core proceeding pursuant to 28 U.S.C. §157(b)(2)(A) and (B). 1 The last four digits of the Debtor’s federal EIN is 9109. The Debtor’s mailing address is Klausner Lumber One LLC, P.O. Box 878, Middleburg, VA 20118.

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2. Venue of this proceeding and this Application is proper in this District pursuant to 28 U.S.C. §§1408 and 1409. 3. 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 UST Guidelines, and the Interim Compensation Procedures Order. BACKGROUND A. The Bankruptcy Case 4. On April 30, 2020 (the “Petition Date”), the above-captioned debtor and debtor in possession (collectively, the “Debtor”) filed voluntary petition with this Court for relief under chapter 11 of the Bankruptcy Code. The Debtor manage and operate its business as debtor in possession under sections 1107(a) and 1108 of the Bankruptcy Code. 5. On May 21, 2020, the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”) appointed the Official Committee of Unsecured Creditors (the “Committee”), consisting of the following three members: (i) Sunbelt Rentals, Inc., (ii) M.A. Rigoni, Inc., (iii) Peninsula Pipeline Company, Inc., (iv) Mahild Drying Technologies and (v) Warn Act Plaintiffs. [Docket No. 82]. 6. On May 26, 2020, the Committee selected Foley and Morris James to serve as co-counsel to the Committee. 7. On May 22, 2020, the Debtor filed a Motion for Entry of an Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of Professionals (the “Administrative Compensation Motion”) [Docket No. 88], and on June 5, 2020, the Court entered an Order approving the Administrative Compensation Motion (the “Administrative Compensation Order”) [Docket No. 132].

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8. On July 14, 2020, the Court entered the Order Authorizing the Employment and Retention of Foley and Lardner LLP as Counsel to the Official Committee of Unsecured Creditors of Klausner Lumber One LLC, nunc pro tunc to May 26, 2020 [Docket No. 200]. SUMMARY OF SERVICES RENDERED 9. Since its retention, Foley, in its capacity as lead counsel for the committee, undertook the following: • Reviewed, revised, and filed and served, all papers filed by the Committee in these cases, including without limitation relating to the bidding procedures and sale schedule, and sale and plan support agreement; • Reviewed substantially all of the papers filed by the Debtors and others in these cases; • Prepared applications for compensation and/or reimbursement of expenses on behalf of Committee professionals and members; • Attended Committee meetings, and responded to inquiries from individual creditors; • Communicated with counsel to the Debtors, the United States Trustee, and lenders regarding issues, as necessary; and • Attended hearings on behalf of the Committee. MONTHLY APPLICATIONS 1. On July 16, 2020, Foley filed its first monthly application for compensation and reimbursement of expenses [Docket No. 213] (the “First Monthly Application”). By the First Monthly Application, Foley sought approval of compensation of $47,544.00 and reimbursement of expenses in the amount of $1.20 for the period of May 26, 2020 through May 31, 2020. On August 11, 2020, the Committee filed a certificate of no objection to the First Monthly Application [Docket No. 274].

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2. On July 20, 2020, Foley filed its second monthly application for compensation and reimbursement of expenses [Docket No. 218] (the “Second Monthly Application”). By the Second Monthly Application, Foley sought approval of compensation of $161,440.40 and reimbursement of expenses in the amount of $143.10 for the period of June 1, 2020 through June 30, 2020. On August 11, 2020, the Committee filed a certificate of no objection to the Second Monthly Application [Docket No. 275]. 3. On August 21, 2020, Foley filed its third monthly application for compensation and reimbursement of expenses [Docket No. 307] (the “Third Monthly Application”). By the Third Monthly Application, Foley sought approval of compensation of $176,976.80 and reimbursement of expenses in the amount of $593.48 for the period of July 1, 2020 through July 31, 2020. On September 18, 2020, the Committee filed a certificate of no objection to the Third Monthly Application [Docket No. 404]. 4. On September 24, 2020, Foley filed its fourth monthly application for compensation and reimbursement of expenses [Docket No. 409] (the “Fourth Monthly Application”). By the Fourth Monthly Application, Foley sought approval of compensation of $362,260.00 and reimbursement of expenses in the amount of $5,427.68 for the period of August 1, 2020 through August 31, 2020. 5. On October 20, 2020, Foley filed its fifth monthly application for compensation and reimbursement of expenses [Docket No. 465] (the “Fifth Monthly Application”). By the Fifth Monthly Application, Foley sough approval of compensation of $236,361.00 and reimbursement of expenses in the amount of $3,364.87 for the period of September 1, 2020 through September 30, 2020. On November 11, 2020, the Committee filed a certificate of no objection to the Fifth Monthly Application [Docket No. 532].

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6. On November 23, 2020, Foley filed its sixth monthly application for compensation and reimbursement of expenses [Docket No. 557] (the “Sixth Monthly Application”). By the Sixth Monthly Application, Foley sought approval of compensation of $182,554.00 and reimbursement of expenses in the amount of $1,550.59 for the period of October 1, 2020 through October 31, 2020. On December 15, 2020, the Committee filed a certificate of no objection to the Sixth Monthly Application [Docket No. 603]. 7. On December 21, 2020, Foley filed its seventh monthly application for compensation and reimbursement of expenses [Docket No. 619] (the “Seventh Monthly Application”). By the Seventh Monthly Application, Foley sought approval of compensation of $116,316.50 and reimbursement of expenses in the amount of $1,019.04 for the period of November 1, 2020 through November 30, 2020. On January 12, 2021, the Committee filed a certification of no objection to the Seventh Monthly Application [Docket No. 656]. 8. On January 22, 2021, Foley filed its eighth monthly application for compensation and reimbursement of expenses [Docket No. 674] (the “Eighth Monthly Application”). By the Eighth Monthly Application, Foley sought approval of compensation of $159,627.50 and reimbursement of expenses in the amount of $179.60 for the period of December 1, 2020 through December 31, 2020. On February 17, 2021, the Committee filed a certification of no objection to the Eighth Monthly Application [Docket No. 727]. 9. On February 22, 2021, Foley filed its ninth monthly application for compensation and reimbursement of expenses [Docket No. 729] (the “Ninth Monthly Application”). By the Ninth Monthly Application, Foley sought approval of compensation of $128,630.50 and reimbursement of expenses in the amount of $232.06 for the period of January 1, 2021 through January 31, 2021.

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10. On March 22, 2021, Foley filed its tenth monthly application for compensation and reimbursement of expenses [Docket No. 809] (the “Tenth Monthly Application”). By the Tenth Monthly Application, Foley sought approval of compensation of $100,760.50 and reimbursement of expense in the amount of $689.43 for the period of February 1, 2021 through February 28, 2021. 11. On April 20, 2021, Foley filed its eleventh monthly application for compensation and reimbursement of expenses [Docket No. 865] (the “Eleventh Monthly Application”). By the Eleventh Monthly Application, Foley sought approval of compensation of $25,635.00 and reimbursement and expense in the amount of $0.00 for the period of March 1, 2021 through March 31, 2021. 12. On May 20, 2021, Foley filed its twelfth monthly application for compensation and reimbursement of expenses [Docket No. 919] (the “Twelfth Monthly Application”). By the Twelfth Monthly Application, Foley sought approval of compensation of $40,700.50 and reimbursement and expense in the amount of $0.00 for the period of April 1, 2021 through April 30, 2021. 13. The total sum due to Foley for professional services rendered on behalf of the Committee during the Interim Compensation Period is $167,096.00. A chart detailing the fees in each of the applications during the Interim Compensation Period, by professional and by category is attached as Exhibit A. Foley submits that the professional services it rendered on behalf of the Committee during this time were both reasonable and necessary. 14. Foley incurred $689.43 of expenses during the Interim Compensation Period. A chart detailing the specific disbursements during the Interim Compensation Period is attached hereto as Exhibit B.

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15. The undersigned hereby attests that she has reviewed the requirements of Local Rule 2016-1 and this Application conforms to such requirements, including that travel time was not billed at more than half rate and copying charges were only $.10 per page. 16. Foley has endeavored to represent the Committee in the most expeditious and economical manner possible. 17. Tasks have been assigned to attorneys, paralegals, and other support staff at Foley 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. 18. Moreover, Foley has endeavored to coordinate 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 Committee, and Foley all believes it has been successful in this regard. 19. No agreement or understanding exists between Foley and any other person for the sharing of compensation received or to be received for services rendered in or in connection with this case. 20. 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.

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INFORMATION RELATED TO THE REVISED U.S. TRUSTEE GUIDELINES 21. Foley 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 Cases (the “Revised U.S. Trustee Guidelines”). 22. In according with the Revised U.S. Trustee Guidelines, attached are the following exhibits: a. Exhibit C is a disclosure of “customary and comparable compensation” charged by Foley professionals and paraprofessionals. As requested in the UST Guidelines, Exhibit C provides a summary of the blended hourly rates of the timekeepers (segregated by rank) included in the Final Fee Application as compared to the blended hourly rates for similar non-bankruptcy timekeepers in Foley’s U.S. Offices. b. Exhibit D is Budget for the Third Interim Fee Period Compared to Actual Hours and Fees Incurred by Foley & Lardner for the Third Interim Fee Period and the Proposed and Actual Staffing Plan. 23. Foley’s hourly rates for bankruptcy services are comparable to the hourly rates charged in complex chapter 11 cases by comparably skilled bankruptcy attorneys. 24. Foley’s hourly rates for bankruptcy services are also comparable to the rates charged by Foley, 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. 25. In addition, Foley 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

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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. Foley 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? Not Applicable. The fee application does not include any rate increases since retention. NOTICE AND NO PRIOR APPLICATION 26. Notice of this application has been given to (a) the Debtor; (b) counsel to the Debtor; (c) co-counsels to the Debtor; (d) counsel to the Creditors’ Committee; and (e) the United States Trustee for the District of Delaware appointed in these Chapter 11 Cases. In light of the nature of the relief requested herein, Foley submits that no further or other notice is required. WHEREFORE, Foley respectfully requests pursuant to the procedures allowed in the Administrative Compensation Order: (i) approval of allowance of interim compensation for necessary and valuable legal services rendered by Foley to the Committee in the sum of $167,096.00 and reimbursement of expenses in the sum of $689.43 for the period February 1, 2021 through April 30, 2021 on an interim basis; (ii) payment of any 20% holdback that was withheld

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from payment under the monthly fee application; and (iii) such other and further relief as is just and proper. Dated: June 1, 2021 Respectfully submitted, /s/ Brya M. Keilson . Eric J. Monzo (DE Bar No. 5214) Brya M. Keilson (DE Bar No. 4643) MORRIS JAMES LLP 500 Delaware Avenue, Suite 1500 Wilmington, DE 19801 Telephone: (302) 888-6800 Facsimile: (302) 571-1750 E-mail: emonzo@morrisjames.com E-mail: bkeilson@morrisjames.com - and - Alissa M. Nann, Esq. FOLEY & LARDNER LLP 90 Park Avenue New York, New York 10016 Telephone: (212) 682-7474 Facsimile: (212) 687-2329 Email: anann@foley.com Counsel for the Official Committee of Unsecured Creditors

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