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Full title: Reply to Omnibus Response by the U.S. Securities and Exchange Commission to Various Interim Fee Applications Filed By Professionals to be Paid from Debtors' Estates, and Reservation of Rights (RE: related document(s)803 Response). Filed by Creditor Committee Official Committee of Unsecured Creditors (Grassgreen, Debra) (Entered: 08/12/2021)

Document posted on Aug 11, 2021 in the bankruptcy, 2 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 INC. , a California corporation, et al., 13 Chapter 11 14 Debtors. APPLICANT PACHULSKI STANG ZIEHL & JONES LLP’S REPLY TO 15 OMNIBUS RESPONSE BY THE U.S. SECURITIES AND EXCHANGE 16 COMMISSION TO VARIOUS INTERIM FEE APPLICATIONS FILED BY 17 PROFESSIONALS TO BE PAID FROM DEBTORS’ ESTATES, AND 18 RESERVATION OF RIGHTS 19 Unsecured Creditors (“Committee”) of Professional Financial Investors, Inc. hereby submits its26 reply to the Omnibus Response by the U.S. Securities and Exchange Commission to Various Interim27 Fee Applications Filed by Professionals to Be Paid from Debtors’ Estates, and Reservation of28 The SEC objects to PSZJ’s Second Interim Application of Pachulski Stang Ziehl & Jones2 LLP as Counsel to the Official Committee of Unsecured Creditors for Allowance and Payment of3 Compensation and Reimbursement of Expenses for the Period December 1, 2020 through April 30,4 2021 (the “Application”) and demands that the interim award be authorized for payment only at5 80% of the allowed fees pending the final fee application.

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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, INC. , a California corporation, et al., 13 Chapter 11 14 Debtors. APPLICANT PACHULSKI STANG ZIEHL & JONES LLP’S REPLY TO 15 OMNIBUS RESPONSE BY THE U.S. SECURITIES AND EXCHANGE 16 COMMISSION TO VARIOUS INTERIM FEE APPLICATIONS FILED BY 17 PROFESSIONALS TO BE PAID FROM DEBTORS’ ESTATES, AND 18 RESERVATION OF RIGHTS 19 Date: August 19, 2021 Time: 10:00 a.m. 20 Judge: Hannah L. Blumenstiel Place: Telephonic/Video Appearances Only 21 450 Golden Gate Avenue 16th Floor, Courtroom 19 22 San Francisco, CA 94102 23 24 Pachulski, Stang, Ziehl, & Jones (“PSZJ”) as counsel to the Official Committee of25 Unsecured Creditors (“Committee”) of Professional Financial Investors, Inc. hereby submits its26 reply to the Omnibus Response by the U.S. Securities and Exchange Commission to Various Interim27 Fee Applications Filed by Professionals to Be Paid from Debtors’ Estates, and Reservation of28 Rights [Dkt No. 803] (the “SEC Objection”).

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1 The SEC objects to PSZJ’s Second Interim Application of Pachulski Stang Ziehl & Jones2 LLP as Counsel to the Official Committee of Unsecured Creditors for Allowance and Payment of3 Compensation and Reimbursement of Expenses for the Period December 1, 2020 through April 30,4 2021 (the “Application”) and demands that the interim award be authorized for payment only at5 80% of the allowed fees pending the final fee application. 6 The Application sought approval and payment of 100% of the amounts described therein. 7 However, the omnibus notice for all professionals filed in connection with the Application sought8 authority for payment of 80% of the fees. For this reason, PSZJ is willing accept an order9 approving payment of its fees at the 80% level. 10 PSZJ and the other active chapter 11 professionals have not been paid any fees on account11 of more than one years’ services to date. This delay in payment significantly enhanced the liquidity12 of the enterprise and allowed cash to be used to improve the assets of the estate for the benefit of13 the victims of this Ponzi scheme. PSZJ has also provided voluntary discounts during the cases of14 $297,287.10, in addition to services performed gratis prior to the filing totaling $228,412.00,15 collectively representing approximately 25% of the total fees incurred. In light of these discounts,16 PSZJ does not see any justification for a holdback. 17 Nonetheless, PSZJ will agree to the 20% holdback in light of the language in the omnibus18 notice. However, PSZJ intends to seek payment of all approved fees, including amounts held back19 on the Application, in a future application to filed after the sale proceeds are received by the20 Debtors’ estates. 21 Dated: August 12, 2021 PACHULSKI STANG ZIEHL & JONES LLP 22 By: /s/ Debra I. Grassgreen 23 Debra I. Grassgreen 24 Counsel for the Official Committee of Unsecured Creditors 25 26 27 28

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