HTML Document View

Full title: Document: Amendment to Descriptions for Certain Time Entries Included in Second Interim Application of Pachulski Stang Ziehl & Jones LLP as Counsel to the Official Committee of Unsecured Creditors for Allowance and Payment of Compensation and Reimbursement of Expenses for the Period December 1, 2020 through April 30, 2021. (RE: related document(s)706 Application for Compensation). Filed by Creditor Committee Official Committee of Unsecured Creditors (Fiero, John) (Entered: 08/02/2021)

Document posted on Aug 1, 2021 in the bankruptcy, 7 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

PACHULSKI STANG ZIEHL & JONES LLP 3 150 California Street, 15th Floor San Francisco, CA 94111 4 Telephone: (415) 263-7000 C ,O 14 Debtors. AMENDMENT TO DESCRIPTIONS FOR C CIS CERTAIN TIME ENTRIES INCLUDED I 24 25 Pachulski Stang Ziehl & Jones LLP (“PSZJ” or the “Firm”) hereby submits its Amendment26 to Descriptions for Certain Time Entries Included in Second Interim Application for Allowance27 and Payment of Compensation and Reimbursement of Expenses for the Period December 1, 202028 1 through April 30, 2021 (the “Amendment”) as counsel to the Official Committee of Unsecured2 6 After the OUST reviewed the Application and provided PSZJ with a detailed spreadsheet7 of time entries that were subject to objection, PSZJ either revised such time entries, provided8 clarification as to why such time entries were in compliance with applicable fee guidelines, or9 agreed to write off those entries or portions thereof.A FR 15 $1,037,135.60 (net of 18.5% discount) inclusive of all fees and costs for the period from DecemberN A S 16 1, 2020 through April 30, 2021, consisting of $1,035,651.15 of fees and $1,484.45 of expenses,17 and (c) grant such other and further relief as may be appropriate under the circumstances.

List of Tables

Document Contents

1 Debra I. Grassgreen (CA Bar No. 169978) John D. Fiero (CA Bar No. 136557) 2 Cia H. Mackle (admitted pro hac vice) PACHULSKI STANG ZIEHL & JONES LLP 3 150 California Street, 15th Floor San Francisco, CA 94111 4 Telephone: (415) 263-7000 Facsimile: (415) 263-7010 5 E-mail: dgrassgreen@pszjlaw.com jfiero@pszjlaw.com 6 cmackle@pszjlaw.com 7 Counsel for the Official Committee of Unsecured Creditors 8 UNITED STATES BANKRUPTCY COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 In re: Case No. 20-30604 (HLB) 12 (Jointly Administered) PROFESSIONAL FINANCIAL INVESTORS, A RNI 13 INC. , a California corporation, et al., Chapter 11 O ALIF C ,O 14 Debtors. AMENDMENT TO DESCRIPTIONS FOR C CIS CERTAIN TIME ENTRIES INCLUDED I N A FR 15 SECOND INTERIM APPLICATION OF N SA PACHULSKI STANG ZIEHL & JONES 16 LLP AS COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED 17 CREDITORS FOR ALLOWANCE AND PAYMENT OF COMPENSATION AND 18 REIMBURSEMENT OF EXPENSES FOR THE PERIOD DECEMBER 1, 2020 19 THROUGH APRIL 30, 2021 20 Date: August 19, 2021 Time: 10:00 a.m. 21 Judge: Hannah L. Blumenstiel Place: Telephonic/Video Appearances Only 22 450 Golden Gate Avenue 16th Floor, Courtroom 19 23 San Francisco, CA 94102 24 25 Pachulski Stang Ziehl & Jones LLP (“PSZJ” or the “Firm”) hereby submits its Amendment26 to Descriptions for Certain Time Entries Included in Second Interim Application for Allowance27 and Payment of Compensation and Reimbursement of Expenses for the Period December 1, 202028

1

1 through April 30, 2021 (the “Amendment”) as counsel to the Official Committee of Unsecured2 Creditors (“Committee”) of Professional Financial Investors, Inc. 3 This Amendment is the product of discussions with the Office of the United States Trustee4 (“OUST”) regarding the sufficiency and appropriateness of certain time entries contained in5 PSZJ’s second interim fee application [Docket No. 706] (the “Application”). 6 After the OUST reviewed the Application and provided PSZJ with a detailed spreadsheet7 of time entries that were subject to objection, PSZJ either revised such time entries, provided8 clarification as to why such time entries were in compliance with applicable fee guidelines, or9 agreed to write off those entries or portions thereof. PSZJ’s amended time entries are attached10 hereto in Exhibit A. In three instances, as reflected in the attached, PSZJ has agreed to write off11 the fees associated with the challenged entries, or portions thereof, for a total write off of12 $1,578.15. A RNI 13 WHEREFORE, PSZJ respectfully requests that this Court (a) authorize interim allowanceO ALIF C ,O 14 and payment of fees and costs, (b) award interim compensation to the Firm in the amount ofC CIS N A FR 15 $1,037,135.60 (net of 18.5% discount) inclusive of all fees and costs for the period from DecemberN A S 16 1, 2020 through April 30, 2021, consisting of $1,035,651.15 of fees and $1,484.45 of expenses,17 and (c) grant such other and further relief as may be appropriate under the circumstances. 18 19 Dated: August 2, 2021 PACHULSKI STANG ZIEHL & JONES LLP 20 By: /s/ John D. Fiero 21 John D. Fiero Debra I. Grassgreen 22 Counsel for the Official Committee of Unsecured 23 Creditors 24 25 26 27 28

2

EXHIBIT A
Table 1 on page 3. Back to List of Tables
Date Timekeeper Original Time Entry
Description
Billing
Category
Hours
Billed
Revisions to Time Entry
1/25/2021 John D.
Fiero
Conference call to
discuss questions to be
presented
INVC - Investor
Communication
0.70 Revision to Description:
Telephone conference with
D. Grassgreen and M.
Goldberg to discuss
submitted questions in
preparation for all investor
call
2/22/2021 John D.
Fiero
Prepare for weekly "all
professionals" call (.3);
Attend all professionals
call re weekly task list
(1.5)
CA - Case
Administration
2.00 Revision to Hours Billed: 1.8
3/1/2021 John D.
Fiero
Attend Zoom call PD - Plan and
Disclosure
Statement
1.30 Revision to Hours Billed:
0.00
4/28/2021 John D.
Fiero
Review and revise form
of stipulated judgment
BL -
Bankruptcy
Litigation
0.50 Revision to Description:
Review and revise form of
stipulated judgment re Ponzi
finding.
1/19/2021 Debra
Grassgreen
Confer with J. Fiero re:
meeting tomorrow and
key topics
MC - Meeting
of Creditors
0.20 Revision to Description:
Confer with J. Fiero re
weekly UCC call meeting
agenda for the following day.
2/1/2021 Debra
Grassgreen
Call with Michael
Goldberg and
committee
professionals re:
Monday meeting and
plan discussion (.5);
revise slides (.3);
review questions and
confer with Michael
Goldberg (.6); attend
weekly all investor
meeting and present
timeline (2.2)
INVC - Investor
Communication
3.60 Revision to Description: Call
with Michael Goldberg and
committee professionals re:
Monday meeting and plan
discussion (.5); revise slides
(.3); confer with Michael
Goldberg re questions
submitted for all investor call
(.6); attend weekly all
investor meeting and present
timeline (2.2)
2/22/2021 Debra
Grassgreen
Call with forensic team
from FTI , PFI counsel
and Ad Hoc counsel re:
status of netting
analysis and scope
going forward
FOR - Forensic 1.30 Revision to Hours Billed: 1.0

3

Table 1 on page 4. Back to List of Tables
4/14/2021 Debra
Grassgreen
Review disclosure
statement objections;
revised documents and
related pleadings in
preparation for
disclosure statement
hearing
PD - Plan and
Disclosure
Statement
4.50 Revision to Description:
Review pleadings in
preparation for disclosure
statement hearing, including
disclosure statement
objections, revised
documents and related
pleadings.
2/4/2021 Jonathan
Kim
Emails Grassgreen, et
al., re: trust agreement;
analyze trust issues and
prepare trust agreement
draft.
PD - Plan and
Disclosure
Statement
2.50 Revision to Description:
Emails Grassgreen, et al., re:
trust agreement (.2); analyze
trust issues and prepare trust
agreement draft (2.3).
2/10/2021 Jonathan
Kim
Analyze/research plan
issues; review plan and
DS and further
revisions.
PD - Plan and
Disclosure
Statement
4.70 Revision to Description:
Analyze/research plan issues
(3.7); review plan and DS and
further revisions (.5).
2/11/2021 Jonathan
Kim
Plan analysis and
review of conf. issues;
revise plan and DS.
PD - Plan and
Disclosure
Statement
4.20 Revision to Description: Plan
analysis and review of conf.
issues (2.0); revise plan and
DS (2.2).
2/15/2021 Jonathan
Kim
Emails Debtors' counsel
on plan
comments/issues;
review numerous
issues/comments to
plan and DS; and revise
plan and DS based on
same.
PD - Plan and
Disclosure
Statement
5.60 Revision to Description:
Emails Debtors' counsel on
plan comments/issues (.2);
review numerous
issues/comments to plan and
DS (1.0); and revise plan and
DS based on same (4.4).
2/24/2021 Jonathan
Kim
Review PFI plan
related docs; revise
disclosure statement;
and prepare exhibit
templates.
PD - Plan and
Disclosure
Statement
1.00 Revision to Description:
Review PFI plan related docs
(.3); revise disclosure
statement (.4); and prepare
exhibit templates (.3).
2/26/2021 Jonathan
Kim
Prepare DS and plan
exhibit drafts; review
plan and conf. issues;
revise plan on various
issues; review plan
summary.
PD - Plan and
Disclosure
Statement
4.90 Revision to Description:
Prepare DS and plan exhibit
drafts (1.0); review plan and
conf. issues (1.4); revise plan
on various issues (1.2);
review plan summary (1.3).
3/2/2021 Jonathan
Kim
Emails Grassgreen,
Fiero on plan/DS
issues; review Fiero's
comments and
additional research re:
plan issues.
PD - Plan and
Disclosure
Statement
5.20 Revision to Description:
Emails Grassgreen, Fiero on
plan/DS issues (.2); review
Fiero's comments and
additional research re: plan
issues (5.0).
3/2/2021 Jonathan
Kim
Review draft complaint
re: Ponzi findings and
consider issues; review
solict. proc. order and
consider issues.
PD - Plan and
Disclosure
Statement
1.00 Revision to Description:
Review draft complaint re:
Ponzi findings and consider
issues (.4); review solict.
proc. order and consider
issues (.6).

4

Table 1 on page 5. Back to List of Tables
3/2/2021 Jonathan
Kim
Research plan matters;
further revisions to
plan, DS, exhibits.
PD - Plan and
Disclosure
Statement
2.50 Revision to Description:
Research plan matters (1.5);
further revisions to plan, DS,
exhibits (1.0).
3/16/2021 Jonathan
Kim
Emails Debtors' counsel
on plan/DS matters;
emails Grassgreen re
plan/DS matters; emails
FTI on same; revise
plan and disclosure
statement.
PD - Plan and
Disclosure
Statement
3.10 Revision to Description:
Emails Debtors' counsel on
plan/DS matters (.2); emails
Grassgreen re plan/DS
matters (.1); emails FTI on
same (.1); revise plan and
disclosure statement (2.7).
3/18/2021 Jonathan
Kim
Emails plan team re:
plan changes, and
revise plan and
disclosure statement;
emails plan team on
disclosure statement
issues and plan
revisions.
PD - Plan and
Disclosure
Statement
2.60 Revision to Description:
Emails plan team re: plan
changes (.2), and revise plan
and disclosure statement
(2.2); emails plan team on
disclosure statement issues
and plan revisions (.2).
3/18/2021 Jonathan
Kim
Review proposed
plan/DS revisions;
revise plan and
disclosure statement;
emails plan working
group on revisions.
PD - Plan and
Disclosure
Statement
2.2 Revision to Description:
Review proposed plan/DS
revisions (.4); revise plan and
disclosure statement (1.7);
emails plan working group on
revisions (.1).
3/20/2021 Jonathan
Kim
Emails Mackle, Itkin, et
al. re plan/DS changes,
and exhibits matters;
revise plan and
disclosure statement.
PD - Plan and
Disclosure
Statement
1.1 Revision to Description:
Review proposed plan/DS
revisions (.3); revise plan and
disclosure statement (.7);
emails plan working group on
revisions (.1).
12/8/2020 Cia Mackle Review and shepardize
Vaughan decision and
review of cases; emails
with D. Grassgreen and
J. Fiero re same.
PD - Plan and
Disclosure
Statement
1.40 Revision to Description:
Review and shepardize
Vaughan decision and review
of cases (1.3); emails with D.
Grassgreen and J. Fiero re
same (.1).
12/11/2020 Cia Mackle Review comments from
J. Fiero, reply and
update memo re same.
PD - Plan and
Disclosure
Statement
0.20 Revision to Description:
Review emailed comments
from J. Fiero and reply (.1);
update memo re same (.1).
12/1/2020 Cia Mackle Draft call notes from all
investor call; email
same to counsel.
INVC - Investor
Communication
0.90 Revision to Description:
Draft detailed minutes notes
from all investor call for
circulation to investors (.8);
email same to counsel (.1).

5

Table 1 on page 6. Back to List of Tables
1/21/2021 Cia Mackle Review plan
documents, update plan
scenarios timelines and
begin drafting plan
presentation;
correspond with O.
Katz, B. Marum, D.
Grassgreen and J. Fiero
re same.
PD - Plan and
Disclosure
Statement
5.20 Revision to Description:
Review plan documents (2.0),
update plan scenarios
timelines (.5) and begin
drafting plan presentation
(2.5); correspond with O.
Katz, B. Marum, D.
Grassgreen and J. Fiero re
same (.2).
1/29/2021 Cia Mackle Finalize call notes and
email to R. Hannah.
INVC - Investor
Communication
1.7 Revision to Description:
Draft detailed minutes notes
from all investor call for
circulation to investors (1.6);
email same to R. Hannah (.1).
2/18/2021 Cia Mackle Finalize investor call
notes and email same to
R. Hannah.
INVC - Investor
Communication
0.80 Revision to Description:
Draft detailed minutes notes
from all investor call for
circulation to investors (.7);
email same to R. Hannah (.1).
2/3/2021 Cia Mackle Prepare for and attend
hearing.
HE - Hearing 1.2 Revision to Description:
Attended Court hearing on
debtors' status conference and
insurance financing motion.
3/19/2021 Cia Mackle Confer with K. Frazier
and B. Marum
(multiple emails and
telephone conferences)
re solicitation
procedures.
PD - Plan and
Disclosure
Statement
1.00 Revision to Description:
Review and consider email
from K. Frazier re solicitation
procedures (.3); review
solicitations procedures
motion and exhibits re issues
raised (.5); review and
respond to additional emails
with professionals group re
same (.2).
4/7/2021 Cia Mackle Update Plan to
incorporate TIC
optionality; review plan
for lien and lender
issues and consistency.
PD - Plan and
Disclosure
Statement
4.40 Revision to Description:
Update Plan to incorporate
TIC optionality (2.0); review
plan for lien and lender issues
and consistency (2.4).
4/19/2021 Cia Mackle Update powerpoint
presentation and email
same to D. Grassgreen.
INVC - Investor
Communication
0.30 Revision to Description:
Update powerpoint
presentation to be presented
on all investor call re plan
issues and email same to D.
Grassgreen.
4/26/2021 Cia Mackle Review emails sent
after call and reply.
INVC - Investor
Communication
0.10 Revision to Description:
Review emails sent after all
investor call re issues raised
thereon and reply.
4/29/2021 Cia Mackle Emails and telephone
conferences with B.
Marum re various
investor issues.
INVC - Investor
Communication
1.30 Revision to Description:
Telephone conference with
investor re electronic ballot
issue (.1); investigation re
same (.3); telephone
conference with B. Marum re

6

Table 1 on page 7. Back to List of Tables
ballot issues (.1); multiple
emails with B. Marum re
same (.3); review email from
investor re potential claim
(.1); email B. Marum re same
(.1); emails with B. Marum re
investor receipt of non-
investor claim form and next
steps re same. (.3).
2/17/2021 Richard
Pachulski
Prepare for and
participate on
background call with
Gotthardt re asset
issues and then with
team re alternatives and
then follow-up with D.
Grassgreen.
AD - Asset
Disposition
2.60 Revision to Description:
Prepare for (.2) and
participate on (a) background
call with Gotthardt re asset
issues (1.0) and then (b) with
team re alternatives (1.2) and
then follow-up with D.
Grassgreen (.2).
2/19/2021 Richard
Pachulski
Prepare for and
participate on
professional call re
asset issues and follow‐
up with D. Grassgreen
re same.
AD - Asset
Disposition
1.20 Revision to Description:
Prepare for (.2) and
participate on professional
call re asset issues (.9) and
follow‐up with D. Grassgreen
re same (.1).
4/27/2021 Richard
Pachulski
Prepare for and
participate on
professional call re
stalking horse and
follow‐up with
Gotthardt re same.
AD - Asset
Disposition
1.30 Revision to Description:
Prepare for (.2) and
participate on (1.0)
professional call re stalking
horse and follow‐up with
Gotthardt re same (.1).
2/19/2021 Daryl
Parker
Legal research re, and
consideration of,
conflict between
recorded deed and
agreement among
tenants in common as
to percentage interest in
real property; telephone
conference with Mr.
Fiero re same
AD - Asset
Disposition
2.40 Revision to Description:
Legal research re, and
consideration of, conflict
between recorded deed and
agreement among tenants in
common as to percentage
interest in real property (2.2);
telephone conference with
Mr. Fiero re same (.2)

7