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Full title: Response United States Trustee's Omnibus Reservation of Rights with Respect to Second Interim Fee Applications (RE: related document(s)694 Application for Compensation, 695 Application for Compensation, 696 Application for Compensation, 697 Application for Compensation, 698 Application for Compensation, 701 Application for Compensation, 702 Application for Compensation, 703 Application for Compensation, 704 Application for Compensation, 705 Application for Compensation, 706 Application for Compensation, 707 Application for Compensation). Filed by U.S. Trustee Office of the U.S. Trustee / SF (Attachments: # 1 Exhibit A # 2 Certificate of Service) (Day, Jared) (Entered: 08/05/2021)

Document posted on Aug 4, 2021 in the bankruptcy, 2 pages and 0 tables.

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Assistant United States Trustee 2 CAMERON GULDEN (SBN MN 310931) Attorneys for TRACY HOPE DAVIS 10 United States Trustee for Region 17 11 UNITED STATES BANKRUPTCY COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 In re ) UNITED STATES TRUSTEE’S OMNIBUS RESERVATION OF RIGHTS WITH RESPECT TO SECOND INTERIM FEE APPLICATIONS 23 Tracy Hope Davis, United States Trustee for Region 17, by and through her 24 undersigned counsel, hereby files this omnibus reservation of rights with respect to the Second 25 Interim Fee Applications filed in the above-captioned cases [ECF Nos.As 10 indicated in the attached Exhibit A, this resulted in each professional either (1) filing a 11 supplement to address Guideline issues; (2) agreeing to a voluntary reduction instead of filing 12 of a supplement; or (3) a combination of (1) and (2) by filing a supplement to address some 13 issues and agreeing to a voluntary reduction to address other issues.Although the United States Trustee does not object to the requested interim fees 15 at this time, the United States Trustee reserves the right to object to fees on any and all grounds 16 in connection with subsequent interim and final fee applications.

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1 TIMOTHY S. LAFFREDI (SBN WI 1055133) Assistant United States Trustee 2 CAMERON GULDEN (SBN MN 310931) 3 Trial Attorney JARED A. DAY (SBN CA 275687) 4 Trial Attorney United States Department of Justice 5 Office of the U.S. Trustee 6 450 Golden Gate Ave., Ste #05-0153 San Francisco, CA 94102 7 Telephone: (415) 252-2065 Facsimile: (415) 705-3379 8 Email: cameron.m.gulden@usdoj.gov 9 Attorneys for TRACY HOPE DAVIS 10 United States Trustee for Region 17 11 UNITED STATES BANKRUPTCY COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 In re ) Case No. 20-30604 15 ) (Jointly Administered) PROFESSIONAL FINANCIAL ) 16 INVESTORS, INC., a California ) Chapter 11 Corporation, et al ) 17 ) ) 18 Debtors. ) ) 19 ) Date: August 19, 2021 ) Time: 10:00 a.m. 20 ) Place: Telephone or Video Conference Only ) Judge: Hon. Hannah L. Blumenstiel 21 ) 22 UNITED STATES TRUSTEE’S OMNIBUS RESERVATION OF RIGHTS WITH RESPECT TO SECOND INTERIM FEE APPLICATIONS 23 Tracy Hope Davis, United States Trustee for Region 17, by and through her 24 undersigned counsel, hereby files this omnibus reservation of rights with respect to the Second 25 Interim Fee Applications filed in the above-captioned cases [ECF Nos. 694-698, 701-707, 709 26 and 726] (the “Applications”). 27 28

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1 In support of her reservation of rights, the United States Trustee respectfully represents 2 as follows: 3 1. The fee applicants bear the burden of proof to show entitlement to the requested 4 fees under 11 U.S.C. § 330. See In re Eliapo, 298 B.R. 392, 402 (B.A.P. 9th Cir. 2003), rev'd 5 in part on other grounds, 468 F.3d 592 (9th Cir. 2006); In re Ginji Corp., 117 B.R. 983, 990 6 (Bankr. D. Nev. 1990) (“The applicant … has the burden of proof to show the reasonableness 7 of the fees sought”). 8 2. The United States Trustee has reached agreements with all professionals to 9 resolve informal objections to the second interim fee applications prior to the hearing. As 10 indicated in the attached Exhibit A, this resulted in each professional either (1) filing a 11 supplement to address Guideline issues; (2) agreeing to a voluntary reduction instead of filing 12 of a supplement; or (3) a combination of (1) and (2) by filing a supplement to address some 13 issues and agreeing to a voluntary reduction to address other issues. 14 3. Although the United States Trustee does not object to the requested interim fees 15 at this time, the United States Trustee reserves the right to object to fees on any and all grounds 16 in connection with subsequent interim and final fee applications. See In re Strand, 375 F.3d 17 854, 858 (9th Cir. 2004) (interim fee awards are always subject to reexamination during the 18 course of the case). 19 20 Dated: August 5, 2021 TRACY HOPE DAVIS UNITED STATES TRUSTEE 21 /s/ Cameron M. Gulden 22 Cameron M. Gulden Trial Attorney for the United States Trustee 23 24 25 26 27 28

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