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Full title: Third Application for Compensation and Reimbursement of Expenses for the Period from February 1, 2021 through May 31, 2021 for Locke Lord LLP, Creditor Comm. Aty, Fee: $314,147.50, Expenses: $8,280.95. Filed by Locke Lord LLP (Attachments: # 1 Exhibit 1 # 2 Proposed Order) (Boldissar, C.) (Entered: 08/24/2021)

Document posted on Aug 23, 2021 in the bankruptcy, 27 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

All compensation for services rendered, and reimbursement for expenses incurred, are subject to this Court’s approval in accordance with the Retention Order, Bankruptcy Code §§ 330 and 331, the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the Local Bankruptcy Rules of the Eastern District of Louisiana (the “Local Bankruptcy Rules”), and other procedures that this Court may fix.the sharing of any compensation or reimbursement (i) that the Firm may receive for services rendered in, or in connection with, this Bankruptcy Case or (ii) that such other entity has already received or may receive for services that entity rendered in, or in connection with this Bankruptcy Case, except that the Firm will share any compensation or reimbursement it receives in connection with this Bankruptcy Case with its members, partners, associates, and other Firm employees (as originally disclosed in the Retention Application).Section 330 of the Bankruptcy Code authorizes the Court to award the Firm reasonable compensation for its actual and necessary legal services rendered and reimbursement of actual and necessary expenses incurred in the rendering of those legal services as counsel to the Committee in these Bankruptcy Cases.The Application and the Firm’s request for payment meet all the criteria for granting an interim 19 award of fees and expenses to the Firm, as set forth in the Retention Orders, the Fee Procedures Order, Bankruptcy Code §§ 330 and 331, the Bankruptcy Rules, the Local Bankruptcy Rules, and this Court’s procedures. WHEREFORE LOCKE LORD LLP respectfully requests that the Court enter an order: (i) approving this Application; (ii) allowing, on an interim basis, the reasonable and necessary attorneys’ fees and expenses claimed herein as allowed administrative expenses of the Debtors’ estate under Bankruptcy Code § 503; (iii) directing the Archdiocese to pay these amounts on an interim basis; and (iv) granting the Firm such other and further relief to which it may be justly entitled.

List of Tables

Document Contents

UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: § Case No. 20-10846 § THE ROMAN CATHOLIC CHURCH OF § Section “A” THE ARCHDIOCESE OF NEW § ORLEANS § Chapter 11 § Debtor. § § FEE APPLICATION COVER SHEET THIRD INTERIM APPLICATION OF LOCKE LORD LLP AS CO-COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM FEBRUARY 1, 2021 THROUGH MAY 31, 2021 Name of Applicant: Locke Lord LLP Authorized to Provide Professional Services to: The Official Committee of Unsecured CreditorsPetition Date: May 1, 2020 Date of Retention: Effective nunc pro tuncto May 22, 2020 Date Order Signed Authorizing Employment: July 17, 2020 [Docket #256]Dates and Amounts of Compensation Approved in December 29, 2020 / $616,628.22Previous Requests: May 20, 2021 / $498,601.19 Period for which compensation and February 1, 2021 through May 31, 2021reimbursement is sought: (the “Application Period”) Total Amount of Compensation sought as actual, $314,147.50 reasonable, and necessary: Total Amount of Expense Reimbursement sought as $8,280.95 actual, reasonable, and necessary: Fee Application: Third Interim Fee Application Total: $322,428.45 Locke Lord LLP professionals who rendered services for The Official Committee of Unsecured Creditors (the “Committee”) in this Chapter 11 case concerning the above captioned debtor and debtor-in-possession (the “Debtor”) during the Application Period are: 1

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Table 1 on page 2. Back to List of Tables
Professional Title Hourly Rate Hours Fees
C. Davin Boldissar Partner $500.00 460.8 $230,400.00
O. F. Kuebel Partner $500.00 138 $69,000.00
W. Steven Bryant Partner $500.00 1 $500.00
B. C. Knapp Partner $425.00 1.2 $510.00
A. H. Katz Of Counsel $450.00 8.5 $3,825.00
C. Rosenbloom Associate $375.00 2.3 $862.50
Ashley L. Lohr Paralegal $125.00 72.4 $9,050.00
The total hours and fees incurred by Task Code forthe Committeeduring the Application Period are:
Table 2 on page 2. Back to List of Tables
Task
Code
Subject Matter Category Total Hours Total Fees
B110 CASE ADMINISTRATION 17.5 $4,337.50
B120 ASSET ANALYSIS AND RECOVERY 37.4 $18,625.00
B130 ASSET DISPOSITION 0.8 $400.00
B140 RELIEF FROM STAY/ADEQUATE PROTECTION PROCEEDINGS 4.5 $2,250.00
B150 MEETINGS &COMMUNICATIONS WITH CREDITORS 94.9 $47,450.00
B160 FEE/EMPLOYMENT APPLICATIONS 27.9 $5,362.50
B170 FEE/EMPLOYMENT OBJECTIONS 2.8 $1,400.00
1 In addition to the professional hours of 684.20 on the invoices, an additional 72.3 hours were worked but are marked as “no charge” and are voluntary reductions already reflected in the invoices, for a total of 756.5 hours worked. 2 These invoice amounts total $314,147.50, but as discussed below, additional voluntary reductions of $34,500.00 are marked as “no charge” and are voluntary reductions already reflected in the invoices, for a total of $348,647.50. 2

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Table 1 on page 3. Back to List of Tables
Task
Code
Subject Matter Category Total Hours Total Fees
B180 AVOIDANCE ACTION ANALYSIS 0.6 $300.00
B190 OTHER CONTESTED MATTERS 46.7 $11,425.00
B195 NON-WORKING TRAVEL 0.6 $75.00
B210 BUSINESS OPERATIONS 39.9 $19,950.00
B250 REAL ESTATE 31.8 $15,450.00
B310 CLAIMS ADMINISTRATION AND OBJECTIONS 56 $26,740.00
B320 PLAN AND DISCLOSURE STATEMENT 317.3 $158,122.50
C2003 RESEARCHING LAW 3.8 $1,710.00
L140 DOCUMENT/FILE MANAGEMENT 0 0
L3204 DOCUMENT PRODUCTION 0.8 $100.00
P2405 REAL AND PERSONAL PROPERTY 0.9 $450.00
The total amount of expenses by expense type for the Committee during the Application Period are: 3 As discussed below, the task code of C200 was used through a clerical error and should be considered as B210. 4 As discussed below, the task code of L320 was used through a clerical error and should be considered as B120. 5 As discussed below, the task code of P240 was used through a clerical error and should be considered as B250. 6 In addition to the professional hours of 684.20 on the invoices, an additional 72.3 hours were worked but are marked as “no charge” and are voluntary reductions already reflected in the invoices, for a total of 756.50 hours worked. 7 These invoice amounts total $314,147.50, but as discussed below, additional voluntary reductions of $34,500.00 are marked as “no charge” and are voluntary reductions already reflected in the invoices, for a total of $348,647.50. 3

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Table 1 on page 4. Back to List of Tables
Expense Category Amount
PACER Online Research $440.20
Westlaw Research $3,182.63
Postage $27.00
Filing Fees 05/25/2021, Payment of two (2) invoices which a $885.00
Messenger Service 46589, Alliance Overnight Document Service LLC, $4.50
Depositions and Court Reporters 02/26/21, Patricia Moody on 12-09-2020 $880.08
Tax (Soft Cost) 03/17/21, Mail out of Committee's Limited Respon $5.39
VAT Tax 47222, Alliance Overnight Document Service LLC, Mail out of the Committee's Reply to Debtor's
Opposition to MTC on Rule 2004 Order (Docket# 821)
$10.49
Outside Copy Costs 46634, Alliance Overnight Document Service LLC, $81.76
Outside Copy Costs 02/17/21, Mail out of Committee's Limited Respon $76.16
Outside Copy Costs 02/17/21, Mail out of Committee's Limited Respon $4.50
Outside Copy Costs 02/28/21, Mail out of the Agreed Order on the Co $81.76
Outside Copy Costs 03/17/21, Mail out of Committee's Limited Respon $87.60
Outside Copy Costs 03/17/21, Mail out of Consent Order on Motion fo $81.60
Outside Copy Costs 46589, Alliance Overnight Document Service LLC, $75.60
Outside Copy Costs 46701, Alliance Overnight Document Service LLC, $271.60
Outside Copy Costs 46838, Alliance Overnight Document Service LLC, $397.30
Outside Copy Costs 47031, Alliance Overnight Document Service LLC, $393.45
Outside Copy Costs 47149, Alliance Overnight Document Service LLC, Mail out of Committee's Response
to Debtor's Motion for Relief for Willful Violation of Sate (Doc #815)
$82.96
Outside Copy Costs 47222, Alliance Overnight Document Service LLC, Mail out of the Committee's Reply to
Debtor's Opposition to MTC on Rule 2004 Order (Docket# 821)
$153.60
Outside Copy Costs 47268, Alliance Overnight Document Service LLC, Mail out of Locke Lord's Second Fee
Application and Notice of Hearing Docket 840 and 841
$25.23
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Table 1 on page 5. Back to List of Tables
Expense Category Amount
Outside Copy Costs 47268, Alliance Overnight Document Service LLC, Mail out of Locke Lord's Second Fee
Application and Notice of Hearing Docket 840 and 841
$399.00
Outside Copy Costs 47380, Alliance Overnight Document Service LLC, Mail out of the Committee's
Application to Employ Zobrio (Doc# 850) and Motion to Expedite Hearing on Zobrio Employment Application
(Doc # 851)
$12.76
Outside Copy Costs 47380, Alliance Overnight Document Service LLC, Mail out of the Committee's
Application to Employ Zobrio (Doc# 850) and Motion to Expedite Hearing on Zobrio Employment Application
(Doc # 851)
$219.00
Outside Copy Costs 47384, Alliance Overnight Document Service LLC, Mail out of Order Granting Motion to
Expedite Hearing on Zobrio Application (Doc# 853)
$4.82
Outside Copy Costs 47384, Alliance Overnight Document Service LLC, Mail out of Order Granting Motion to
Expedite Hearing on Zobrio Application (Doc# 853)
$81.60
Outside Copy Costs 47392, Alliance Overnight Document Service LLC, Mail out of Committee's Limited
Response to Financial Advisor Employment Application Doc# 869
$4.82
Outside Copy Costs 47392, Alliance Overnight Document Service LLC, Mail out of Committee's Limited
Response to Financial Advisor Employment Application Doc# 869
$81.60
Outside Copy Costs 47393, Alliance Overnight Document Service LLC, Mail out of Order re: Locke Lord's
Second Fee Application (Doc 875), Order re: PSZJ's Second Fee Application (Doc 876) and Order re:
Zobrio Employment Application (Docket #877)
$5.95
Outside Copy Costs 47393, Alliance Overnight Document Service LLC, Mail out of Order re: Locke Lord's
Second Fee Application (Doc 875), Order re: PSZJ's Second Fee Application (Doc 876) and Order re:
Zobrio Employment Application (Docket #877)
$93.60
Services Rendered 02/15/21, $20.00
Services Rendered 02/28/21, Mail out of the Agreed Order on the Co $5.03
Services Rendered 03/17/21, Mail out of Consent Order on Motion fo $4.82
Services Rendered 04012126.0, Orleans Parish Clerk of Court, Retrieval of court documents. $3.00
Services Rendered 46634, Alliance Overnight Document Service LLC, $5.03
Services Rendered 46701, Alliance Overnight Document Service LLC, $16.14
Services Rendered 46838, Alliance Overnight Document Service LLC, $25.49
Services Rendered 47031, Alliance Overnight Document Service LLC, $24.50
Services Rendered 47149, Alliance Overnight Document Service LLC, Mail out of Committee's Response to
Debtor's Motion for Relief for Willful Violation of Sate (Doc #815)
$4.90
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Table 1 on page 6. Back to List of Tables
Expense Category Amount
Services Rendered REQ051121 33087, St. Tammany Parish Clerk of Court, Retrieval of court records. $20.48
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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: § Case No. 20-10846 § THE ROMAN CATHOLIC CHURCH OF § Section “A” THE ARCHDIOCESE OF NEW ORLEANS § § Chapter 11 Debtor. § § § THIRD INTERIM APPLICATION OF LOCKE LORD LLP AS CO-COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM FEBRUARY 1, 2021 THROUGH MAY 31, 2021 A HEARING WILL BE CONDUCTED ON THIS MATTER ON SEPTEMBER 14, AT 1:30 P.M. BY TELEPHONE THROUGH THE DIAL- IN FOR SECTION A 1-888-684-8852; CONFERENCE CODE 9318283. IF YOU OBJECT TO THE RELIEF REQUESTED IN THIS PLEADING, YOU MUST RESPOND IN WRITING. UNLESS DIRECTED OTHERWISE BY THE COURT, YOU MUST FILE YOUR RESPONSE WITH THE CLERK OF THE BANKRUPTCY COURT NO LATER THAN SEVEN (7) DAYS BEFORE THE HEARING DATE. YOU MUST SERVE A COPY OF YOUR RESPONSE ON THE PERSON WHO SENT YOU THE NOTICE; OTHERWISE, THE COURT MAY TREAT THE PLEADING AS UNOPPOSED AND GRANT THE RELIEF REQUESTED. LOCKE LORD LLP (the “Firm”) files its Third Interim Application of Locke Lord LLP as Counsel to the Official Committee of Unsecured Creditors for Allowance of Compensation and Reimbursement of Expenses for the Period from February 1, 2021 through May 31, 2021 (the “Application”). In support of this Application covering February 1, 2021 through May 31, 2021 (the “Application Period”), the Firm respectfully states as follows: I. INTRODUCTION In this Application, the Firm seeks the amounts set forth below for work performed between February 1, 2021 through May 31, 2021: 1

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(Reductions (Further Expenses Fees (at Final due to Voluntary Standard Amounts Standard Reductions on Rates) Sought Rates) Invoices) February $125,996.00 ($45,951.00) ($7,625.00) $3,555.77 $75,975.77 2021 March $147,644.00 ($54,329.00) ($7,300.00)1 $614.16 $86,629.16 2021 April $143,619.00 ($48,971.50) ($8,575.00) $1,415.68 $87,488.18 2021 May 2021 $121,507.50 ($40,867.50) ($11,000.00) $2,695.34 $72,335.34 TOTAL = $322,428.45 II. JURISDICTION AND VENUE 1. The Court has jurisdiction to consider this Application pursuant to 28 U.S.C. §§ 157 and 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). 2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. III. BACKGROUND FACTS A. Introduction 3. On May 1, 2020 (the “Petition Date”), The Roman Catholic Church of the Archdiocese of New Orleans (the “Archdiocese” or the “Debtor”) filed a voluntary petition for relief under the Bankruptcy Code. 4. The Debtor remains in possession of its property and is managing its business as a debtor in possession pursuant to §§ 1107(a) and 1108 of the Bankruptcy Code, 11 U.S.C. §101 1 The reduction calculations set forth in the fee statement previously circulated were in error and differ from these amounts (Specifically, the statement stated, in error, total fees at standard rates of $155,134.00, reductions due to standard rates of $56,469.00 and voluntary reductions of $12,650.00). The errors impacted only the reduction calculations and the amounts of billed fees and expenses were stated correctly in the fee statement, and have not changed. 2

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et. seq. 5. On May 20, 2020, the Office of the United States Trustee for Region 5 (the “U.S. Trustee”) appointed the Committee pursuant to section 1102(a)(1) of the Bankruptcy Code [Docket #94]. 6. On May 22, 2020, the Committee conducted its first meeting and at that meeting unanimously selected Locke Lord and Pachulski Stang Ziehl & Jones (“PSZJ”) to serve as co-counsel. C. Employment of the Firm 7. On June 22, 2020, the Committee filed an Application to Employ Locke Lord LLP as Co-Counsel [Docket # 179] (the “Retention Application”). As more fully described in the Retention Application, the Committee retained the Firm to render legal services to the Committee in the Bankruptcy Case. 8. On July 17, 2020, this Court entered the Order Authorizing the Employment and Retention of Locke Lord LLP as Co-Counsel for the Official Committee of Unsecured Creditors [Docket # 256] (the “Retention Order”). The Retention Order approved the Firm’s retention as the Committee’s co-counsel in the Bankruptcy Case. IV. WORK PERFORMED AND RESULTS OBTAINED / EXTRAORDINARY CIRCUMSTANCES 9. The Firm provided, and continues to provide, extensive legal services to the Committee in this Bankruptcy Case. The Firm has attached to this Application copies of the Firm’s Invoices (the “Invoices”) setting forth the time-keeping entries generated by those Firm personnel who worked on this matter during the Application Period.2 2 True and correct copies of the Invoices are attached to the Application as Exhibit “1” and are incorporated by reference herein. 3

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10. The Committee and its counsel have undertaken strenuous efforts to move this case forward towards a resolution of creditor claims, to achieve the goal of the most favorable resolution to unsecured creditors possible. 11. The actions undertaken include the following: A. Action to Move Forward Resolution of Claims and Plan Negotiations12. The Committee recognizes that the most likely outcome and resolution of claims will come through a plan of reorganization.3 To that end, the Committee has worked to move this process forward, beginning with a comprehensive investigation and analysis of the Debtor’s financial circumstances and structure, which is necessary to inform negotiations and mediation concerning potential resolution of claims. 13. The Committee, together with its counsel, has undertaken significant work in this regard, including without limitation during the Application Period:  Investigation, including through analysis of information and documents provided by the Debtor. During the Application Period, the Committee briefed and resolved a Rule 2004 motion to formalize comprehensive document and information requests. The Committee negotiated with the Debtor concerning the requests and addressed numerous objections and limitations proposed. The Committee also continued to work on document and information requests to, and responses, from, the more than 150 affiliates of the Debtor.  Filing and work on a motion to compel and proceedings under the Rule 2004 requests.  Analysis and preliminary review of non-abuse and abuse claims.  Review and interviews of potential mediator candidates and mediation structure.  Analysis and valuation of numerous real estate properties.  Review and investigation of potential plan structuring and terms including 3 All rights are reserved in connection with the Court’s recent order denying the motion to dismiss filed by the Committee. 4

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financial and non-monetary terms, and legal analysis in anticipation of mediation.  Work on financial analysis and work with financial advisors on same. B. Other Motions and Requests for Relief 14. Additional matters include:  Addressing motions on plan exclusivity and a motion for relief based on allegations of willful violation of the automatic stay.  Addressing claims access issues and a motion to expand claims access and resolution and negotiations regarding same. V. PROJECT CATEGORIES 15. The Invoices break down the legal services rendered into project categories as required by the Office of the United States Trustee. The seventeen (17) pertinent project categories are: (1) Case Administration (B110), (2) Asset Analysis and Recovery (B120), (3) Asset Disposition (B130), (4) Relief from Stay/Adequate Protection Proceedings (B140), (5) Meetings & Communications with Creditors (B150), (6) Fee/Employment Applications (B160), (7) Fee/Employment Objections (B170), (8) Avoidance Action Analysis (B180), (9) Other Contested Matters (B190), (10) Non-Working Travel (B195), (11) Business Operations (B210), (12) Real Estate (B250), (13) Claims Administration and Objections (B310), (14) Plan and Disclosure Statement (B320), (15) Researching Law (C200)4, (16) Document Production (L320)5, and (17) Real and Personal Property (P240).6 16. The Invoices identify each Firm attorney, paraprofessional, or staff person who 4 Due to a clerical error, the matters billed under task code C200 was used through a clerical error and should be considered as B210. 5 Due to a clerical error, the matters billed under task code L320 was used through a clerical error and should be considered as B120. 6 Due to a clerical error, the matters billed under task code P240 should have been categorized under task code B250 (Real Estate) and should be considered to be as such. 5

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provided services during the Application Period. The Invoices reflect the name of the person as well as the following: (1) his or her billing rate, (2) the total number of hours expended by that person, and (3) the total fees incurred. The Invoices also provide this information by project category. The following narrative summarizes the services rendered by the Firm to the Committee in each of the fifteen (15) project categories during the Application Period: A. Case Administration (Category Code B110) 17. The category of Case Administration concerns activities arising out of compliance with Chapter 11 requirements. 18. The Firm expended 17.5 hours of professional time on services in this category. The Firm’s professional fees in this category total $4,337.50. Therefore, the Firm’s blended hourly rate is $247.86/hour.7 B. Asset Analysis and Recovery (Category Code B120) 19. The category of Asset Analysis and Recovery concerns the identification and review of potential assets of the Debtors’ bankruptcy estates. 20. The Firm expended 37.4 hours of professional time on services in this category. The Firm’s professional fees in this category total $18,625.00. Therefore, the Firm’s blended hourly rate is $497.99/hour. C. Asset Disposition (Category Code B130) 21. The category of Asset Disposition concerns sales of estate assets under Bankruptcy Code § 363, abandonment of estate assets, and other matters related to transactions involving Chapter 11 debtors and their estates. 7 The blended rates as broken out by project categories do not reflect the substantial voluntary discounts and “no charge” entries on the invoices. Therefore the actual blended rates are lower. As noted in Paragraph 61 below, the overall blended rate, when taking into account all voluntary reductions, is $415.26 per hour. 6

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22. The Firm expended 0.80 hours of professional time on services in this category. The Firm’s professional fees in this category total $400.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. D. Relief from Stay/Adequate Protection Proceedings (Category Code B140)23. The category of Relief from Stay/Adequate Protection Proceedings covers the termination or continuation of the automatic stay in the Bankruptcy Cases under 11 U.S.C. § 362 as well as motions for adequate protection under 11 U.S.C. § 361. 24. The Firm expended 4.5 hours of professional time on services in this category. The Firm’s professional fees in this category total $2,250.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. E. Meetings & Communications with Creditors (Category Code B150) 25. The category of Meetings & Communications with Creditors encompasses all services related to communicating with the Debtor’s creditors and the Committee, including without limitation all consultation with the Committee including its regular meetings. 26. The Firm expended 94.9 hours of professional time on services in this category. The Firm’s professional fees in this category total $47,450.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. F. Fee/Employment Applications (Category Code B160) 27. The category of Fee/Employment Applications involves, inter alia, preparing and filing employment and fee applications. 28. The Firm expended 27.9 hours of professional time on services in this category. The Firm’s professional fees in this category total $5,362.50. Therefore, the Firm’s blended hourly rate is $192.20/hour. 7

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G. Fee/Employment Objections (Category Code B170) 29. The category of Fee/Employment Objections involves, preparing and filing objections to employment and fee applications. 30. The Firm expended 2.8 hours of professional time on services in this category. The Firm’s professional fees in this category total $1,400.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. H. Avoidance Action Analysis (Category Code B180) 31. The Firm expended 0.60 hours of professional time on services in the category of Avoidance Action Analysis. The Firm’s professional fees in this category total $300.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. I. Other Contested Matters (Category Code B190) 32. The category of Other Contested Matters covers litigation and contested matters that do not properly fall within any other project categories. 33. The Firm expended 46.7 hours of professional time on services in this category. The Firm’s professional fees in this category total $11,425.00. Therefore, the Firm’s blended hourly rate is $244.65/hour. J. Non-Working Travel (Category Code B195) 34. This code was used in error and should be considered to be under B210 (Business Operations). The Firm expended 0.60 hours of professional time on services in this category. The Firm’s professional fees in this category total $75.00. Therefore, the Firm’s blended hourly rate is $125.00/hour. K. Business Operations (Category Code B210) 35. The category of Business Operations consists of all matters that concern the 8

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Debtor operating as a debtor-in-possession under Chapter 11 of the Bankruptcy Code and its operations, including issues, objections, and resolution of “first day” motions and other motions concerning operations. 36. The Firm expended 39.9 hours of professional time on services in the category of Business Operations. The Firm’s professional fees in this category total $19,950.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. L. Real Estate (Category Code B250) 37. The category of Real Estate covers real estate-related matters. 38. The Firm expended 31.8 hours of professional time on services this category. The Firm’s professional fees total $15,450.00. Therefore, the Firm’s blended hourly rate is $485.85/hour. M. Claims Administration & Objections (Category Code B310) 39. The category of Claims Administration and Objections includes all legal services that relate to claims against the Debtor. 40. The Firm expended 56 hours of professional time on services in this category. The Firm’s professional fees in this category total $26,740.00. Therefore, the Firm’s blended hourly rate is $477.50/hour. N. Plan and Disclosure Statement (Category Code B320) 41. The category of Plan and Disclosure Statement encompasses matters related to the formulation and presentation of a Chapter 11 plan. 42. The Firm expended 317.3 hours of professional time on services in this category. The Firm’s professional fees in this category total $158,122.50. Therefore, the Firm’s blended hourly rate is $498.34/hour. 9

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O. Researching Law (Category Code C200) 43. The time under the task code C200 should be considered as under task code B210 (Business Operations). The Firm expended 3.8 hours of professional time in this category. The Firm’s professional fees in this category total $1,710.00. Therefore, the Firm’s blended hourly rate is $450.00/hour. P. Document Production (Category Code L320) 44. The time under the task code L320 should be considered as under task code B120 (Asset Analysis and Recovery). The Firm expended 0.80 hours of professional time in this category. The Firm’s professional fees in this category total $100.00. Therefore, the Firm’s blended hourly rate is $125.00/hour. Q. Real and Personal Property (Category Code P240) 45. The time under the task code P240 should be considered as under task code B250 (Real Estate). The Firm expended 0.90 hours of professional time in this category. The Firm’s professional fees in this category total $450.00. Therefore, the Firm’s blended hourly rate is $500.00/hour. VI. REQUEST FOR REIMBURSEMENT OF EXPENSES INCURRED 46. In addition to providing legal services, the Firm also incurred out-of-pocket expenses while representing the Committee. A detailed record of these expenses appears in the Invoices (the “Expense Record”). Expenses for computerized research and miscellaneous business expenses were billed at actual cost. The Firm has made no request for general overhead expenses. 47. The Firm’s various expenses were necessary and reasonable. For instance, 10

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copying and postage charges were incurred serving pleadings and other relevant documents on interested parties in this Bankruptcy Case—a significant expense given the large number of parties on the Debtor’s service list and the multiple pleadings and other filings made in these cases. 48. In general, the Firm strived to minimize all expenses. Online and PACER research was utilized only when an attorney believed that the benefits of computerized research outweighed the cost of such research and that the costs would be less than those incurred in utilizing traditional research methods. 49. The Firm’s specific expenses are as outlined below:
Table 1 on page 17. Back to List of Tables
Expense Category Amount
PACER Online Research $440.20
Westlaw Research $3,182.63
Postage $27.00
Filing Fees 05/25/2021, Payment of two (2) invoices which a $885.00
Messenger Service 46589, Alliance Overnight Document Service LLC, $4.50
Depositions and Court Reporters 02/26/21, Patricia Moody on 12-09-2020 $880.08
Tax (Soft Cost) 03/17/21, Mail out of Committee's Limited Respon $5.39
VAT Tax 47222, Alliance Overnight Document Service LLC, Mail out of the Committee's Reply to Debtor's
Opposition to MTC on Rule 2004 Order (Docket# 821)
$10.49
Outside Copy Costs 46634, Alliance Overnight Document Service LLC, $81.76
Outside Copy Costs 02/17/21, Mail out of Committee's Limited Respon $76.16
Outside Copy Costs 02/17/21, Mail out of Committee's Limited Respon $4.50
Outside Copy Costs 02/28/21, Mail out of the Agreed Order on the Co $81.76
Outside Copy Costs 03/17/21,Mail out of Committee's Limited Respon $87.60
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Table 1 on page 18. Back to List of Tables
Expense Category Amount
Outside Copy Costs 03/17/21, Mail out of Consent Order on Motion fo $81.60
Outside Copy Costs 46589, Alliance Overnight Document Service LLC, $75.60
Outside Copy Costs 46701, Alliance Overnight Document Service LLC, $271.60
Outside Copy Costs 46838, Alliance Overnight Document Service LLC, $397.30
Outside Copy Costs 47031, Alliance Overnight Document Service LLC, $393.45
Outside Copy Costs 47149, Alliance Overnight Document Service LLC, Mail out of Committee's Response
to Debtor's Motion for Relief for Willful Violation of Sate (Doc #815)
$82.96
Outside Copy Costs 47222, Alliance Overnight Document Service LLC, Mail out of the Committee's Reply to
Debtor's Opposition to MTC on Rule 2004 Order (Docket# 821)
$153.60
Outside Copy Costs 47268, Alliance Overnight Document Service LLC, Mail out of Locke Lord's Second Fee
Application and Notice of Hearing Docket 840 and 841
$25.23
Outside Copy Costs 47268, Alliance Overnight Document Service LLC, Mail out of Locke Lord's Second Fee
Application and Notice of Hearing Docket 840 and 841
$399.00
Outside Copy Costs 47380, Alliance Overnight Document Service LLC, Mail out of the Committee's
Application to Employ Zobrio (Doc# 850) and Motion to Expedite Hearing on Zobrio Employment Application
(Doc # 851)
$12.76
Outside Copy Costs 47380, Alliance Overnight Document Service LLC, Mail out of the Committee's
Application to Employ Zobrio (Doc# 850) and Motion to Expedite Hearing on Zobrio Employment Application
(Doc # 851)
$219.00
Outside Copy Costs 47384, Alliance Overnight Document Service LLC, Mail out of Order Granting Motion to
Expedite Hearing on Zobrio Application (Doc# 853)
$4.82
Outside Copy Costs 47384, Alliance Overnight Document Service LLC, Mail out of Order Granting Motion to
Expedite Hearing on Zobrio Application (Doc# 853)
$81.60
Outside Copy Costs 47392, Alliance Overnight Document Service LLC, Mail out of Committee's Limited
Response to Financial Advisor Employment Application Doc# 869
$4.82
Outside Copy Costs 47392, Alliance Overnight Document Service LLC, Mail out of Committee's Limited
Response to Financial Advisor Employment Application Doc# 869
$81.60
Outside Copy Costs 47393, Alliance Overnight Document Service LLC,Mail out of Order re: Locke Lord's
Second Fee Application (Doc 875), Order re: PSZJ's Second Fee Application (Doc 876) and Order re:
Zobrio Employment Application (Docket #877)
$5.95
Outside Copy Costs 47393, Alliance Overnight Document Service LLC, Mail out of Order re: Locke Lord's
Second Fee Application (Doc 875), Order re: PSZJ's Second Fee Application (Doc 876) and Order re:
Zobrio Employment Application (Docket #877)
$93.60
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Table 1 on page 19. Back to List of Tables
Expense Category Amount
Services Rendered 02/15/21, $20.00
Services Rendered 02/28/21, Mail out of the Agreed Order on the Co $5.03
Services Rendered 03/17/21, Mail out of Consent Order on Motion fo $4.82
Services Rendered 04012126.0, Orleans Parish Clerk of Court, Retrieval of court documents. $3.00
Services Rendered 46634, Alliance Overnight Document Service LLC, $5.03
Services Rendered 46701, Alliance Overnight Document Service LLC, $16.14
Services Rendered 46838, Alliance Overnight Document Service LLC, $25.49
Services Rendered 47031, Alliance Overnight Document Service LLC, $24.50
Services Rendered 47149, Alliance Overnight Document Service LLC, Mail out of Committee's Response to
Debtor's Motion for Relief for Willful Violation of Sate (Doc #815)
$4.90
Services Rendered REQ051121 33087, St. Tammany Parish Clerk of Court, Retrieval of court records. $20.48
50. The Firm requests that the Court grant it reimbursement for $8,280.95 in reimbursable expenses it incurred on the Committee’s behalf during the Application Period. VII. VOLUNTARY REDUCTIONS 51. For purposes of this Application, the Firm made certain voluntary reductions from the award sought. The invoices reflect reductions of $34,500.00 (72.3 billable hours) for work performed but not charged to the Committee during the Application Period, with such entries being marked as “No Charge.”8 VIII. STATEMENT IN COMPLIANCE WITH RULE 2016 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE 52. As more fully described in the Retention Application, the Committee agreed to 8 As noted above, the reduction calculations set forth in the March invoice fee statement previously circulated were in error, and have been corrected in this fee application. The errors impacted only the reduction calculations and the amounts of billed fees and expenses were stated correctly in the fee statement, and have not changed. 13

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retain the Firm as its co-counsel and to compensate the Firm on an hourly basis in accordance with the Firm’s ordinary and customary rates (discounted as set forth in the Retention Application), plus reimbursement of the actual and necessary expenses that the Firm incurred in connection with the Bankruptcy Case. All compensation for services rendered, and reimbursement for expenses incurred, are subject to this Court’s approval in accordance with the Retention Order, Bankruptcy Code §§ 330 and 331, the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the Local Bankruptcy Rules of the Eastern District of Louisiana (the “Local Bankruptcy Rules”), and other procedures that this Court may fix. No entity has promised to compensate the Firm for any services rendered, or reimburse it for expenses incurred, in connection with these Bankruptcy Cases except as this Court may approve. 53. As of today’s date, the Firm has received $1,246,146.84 as approved by the Court (on December 29, 2020 and May 20, 2021) on the Firm’s first and second interim applications, and in addition, the following payments from the Debtor under Section XIII(B) of the Court’s December 4, 2019 General Order Regarding Procedures for Complex Chapter 11 Cases, on account of the following invoices: Invoice Invoice Date Invoice Amount Payment Date Payment Amount Number ($61,491.77) 1651943 5/19/2021 $75,975.77 7/14/2021 ($69,425.66) 1651946 5/19/2021 $86,629.16 7/14/2021 ($70,273.68) 1651954 5/19/2021 $87,488.18 7/30/2021 ($58,407.34) 1660766 7/6/2021 $72,335.34 7/30/2021 TOTAL = $259,598.45 54. No agreement or understanding exists between the Firm and any other entity for 14

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the sharing of any compensation or reimbursement (i) that the Firm may receive for services rendered in, or in connection with, this Bankruptcy Case or (ii) that such other entity has already received or may receive for services that entity rendered in, or in connection with this Bankruptcy Case, except that the Firm will share any compensation or reimbursement it receives in connection with this Bankruptcy Case with its members, partners, associates, and other Firm employees (as originally disclosed in the Retention Application). IX. STANDARDS RELEVANT TO AWARDING REASONABLE COMPENSATION AND REIMBURSEMENT OF EXPENSES 55. Section 330 of the Bankruptcy Code authorizes the Court to award the Firm reasonable compensation for its actual and necessary legal services rendered and reimbursement of actual and necessary expenses incurred in the rendering of those legal services as counsel to the Committee in these Bankruptcy Cases. Bankruptcy Code § 330(a)(1) provides as follows: (a)(1) After notice to the parties in interest and the United States Trustee and a hearing, and subject to sections 326, 328, and 329, the court may award to a trustee, a consumer privacy ombudsman appointed under section 332, an examiner, an ombudsman appointed under section 333, or a professional person employed under section 327 or 1103— (A) reasonable compensation for actual, necessary services rendered by the trustee, examiner, ombudsman, professional person, or attorney and by any paraprofessional person employed by any such person; and (B) reimbursement for actual, necessary expenses. 11 U.S.C. § 330(a)(1). 56. This Application substantiates the total amount the Firm seeks for fees and expenses in accordance with this Court’s standards applied to fee applications. The factors that courts in this jurisdiction consider when making a discretionary award of reasonable attorneys’ fees and reimbursable expenses were originally described in Johnson v. Georgia Highway Express, Inc., 488 F.2d 714, 717-19 (5th Cir. 1974) (the “Johnson Factors”). The Fifth Circuit has applied the Johnson Factors to the determination of awards of attorneys’ fees and expenses 15

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in bankruptcy cases. In re First Colonial Corp. of Am., 544 F.2d 1291 (5th Cir. 1977), cert. denied 431 U.S. 904 (1977). Many of these Johnson Factors have now been codified at Bankruptcy Code § 330(a)(3). 11 U.S.C. § 330(a)(3). 57. The Johnson Factors are summarized as follows: (1) the time and labor required; (2) the novelty and difficulty of the questions presented; (3) the skill required to perform the legal services; (4) the preclusion of other employment by the attorneys due to acceptance of the bankruptcy case; (5) the customary fee; (6) whether the fee is fixed or contingent; (7) time limitations imposed by the client or circumstances; (8) the amounts involved and the results obtained; (9) the experience, reputation and ability of the attorneys; (10) the “undesirability” of the case; (11) the nature and length of the professional relationship with the client; and (12) awards in similar cases.9 Based upon the services described in this Application, the Firm respectfully represents that it has fully satisfied the standards prescribed by the Johnson Factors. The Time and Labor Required 58. Firm attorneys and paraprofessionals, in the performance of legal services, expended 756.5010 hours during the Application Period for a total fee of $314,147.50. Including the 72.3 hours worked but not charged, the blended hourly rate is therefore $415.26/hour. The names of the professionals who worked on these Bankruptcy Cases during the Application Period appear in the Invoices and on the cover sheet attached to this Application. The Firm submits that the time and labor these professionals expended in the Bankruptcy Case are appropriate and reasonable and that this Johnson Factor supports the Firm’s requested award. 9 The factors enunciated in Johnson have been adopted by four other courts of appeals. See Boston & Maine Corp. v. Sheehan, Phinney, Bass & Green, 778 F.2d 890, 896 (1st Cir. 1985); Harman v. Levin, 772 F.2d 1151, 1152-53 (4th Cir. 1985); Mann v. McCombs, 751 F.2d 286, 287-88 (8th Cir. 1984); Yermakov v. Fitzsimmons, 718 F.2d 1465, 1471 (9th Cir. 1983). 10 This includes the 72.3 hours worked but not charged. 16

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The Novelty and Difficulty of the Questions Presented 59. This Bankruptcy Case present many novel and difficult questions as described above. Addressing all these issues necessitated considerable legal expertise. The Skill Required to Perform the Services 60. Representing the Committee in this Bankruptcy Case required considerable skill and expertise in bankruptcy. The Firm employed attorneys and staff persons of varying levels of such skill and expertise to efficiently resolve these issues. The Firm strived to limit the number of attorneys who worked on this case and to use the most appropriate attorney or staff person for any given task. For this reason, the compensation the Firm is requesting for the services rendered by its attorneys and staff persons compares favorably to the compensation awarded in other bankruptcy cases of a similar size and complexity. This factor therefore supports the award the Firm has requested. Preclusion of Other Employment Due to Acceptance of the Case 61. The Firm has not declined any representation solely because it served as counsel for the Committee in this Bankruptcy Case. Nonetheless, the Firm did shift certain resources from matters involving other clients to address issues arising in the Bankruptcy Case. For this reason, this factor favors granting the award the Firm has sought. The Customary Fee 62. The Firm computed the amount of compensation it seeks in this Application according to its customary rates, which rates the Firm previously disclosed in the Retention Application. The Firm also maintained detailed time and disbursement records for all legal services for which it seeks compensation. The rates charged for the Firm’s legal services in this Bankruptcy Case are comparable to other similar-situated firms. These rates also reflect 17

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substantial voluntary reductions of $34,500.00 63. Thus, the blended hourly rate on this matter of $415.26/hour is reasonable and reflects market rate or below-market rate for legal services in Chapter 11 bankruptcy cases of this size and complexity. Similarly, the amounts sought for the reimbursement of expenses reflect the prevailing rates for expense reimbursement by law firms similar in size and reputation to the Firm. Whether the Fee is Fixed or Contingent 64. The Firm’s fees for services rendered in this Bankruptcy Case are based on its regular hourly rates, discounted as set forth in the Retention Application and subject in all respects to this Court’s approval. The Firm has not requested any contingent fee in this Bankruptcy Case. Time Limitations Imposed by the Client or Other Circumstances 65. The Firm has had to respond to tight time-constraints arising in this Bankruptcy Case. Matters often arose throughout the Application Period that required the Firm’s immediate attention. Again, the emergency nature of these matters demanded that the Firm’s professionals respond on very short notice to complicated and developing events as they unfolded. The Amount Involved and the Results Obtained 66. The Invoices summarize the individual tasks that Firm personnel performed during the Application Period as well as the amounts charged for those tasks. The total fees the Firm seeks to approve in this Application are commensurate with the issues in this case. The Experience, Reputation, and Ability of the Attorneys 67. The Firm’s attorneys have significant experience in bankruptcy and other areas of the law, possess a high level of expertise, and have excellent reputations in their communities. In 18

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particular, the Firm’s bankruptcy attorneys have appeared in bankruptcy cases throughout the United States and have provided services to secured creditors, unsecured creditors, creditors’ committees, and debtors-in-possession. In addition, the Firm’s attorneys also speak and write on various legal topics in Texas, Louisiana, and elsewhere. The “Undesirability” of the Bankruptcy Cases 68. From the Firm’s perspective, serving as co-counsel to the Committee poses challenges and difficulties. The effective rates charged are far below the Firm’s standard rates. The complex, risky, and complicated nature of this Bankruptcy Case continued throughout the Application Period. The Nature and Length of the Professional Relationship with the Client 69. The Firm’s engagement by the Committee commenced shortly after the Committee was formed. Awards in Similar Cases 70. The fee award the Firm seeks compares favorably to awards granted in other bankruptcy cases with a size and complexity similar to this Bankruptcy Case. In addition, the fees sought by Committee counsel are substantially less than the fees sought by the Debtor’s professionals. 71. In conclusion, the Johnson Factors favor granting the Firm the fee and expense award it seeks. X. CONCLUSION 72. The fee and expense award the Firm seeks in this Application is justifiable and appropriate. This Application demonstrates that the Firm is entitled to this award. The Application and the Firm’s request for payment meet all the criteria for granting an interim 19

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award of fees and expenses to the Firm, as set forth in the Retention Orders, the Fee Procedures Order, Bankruptcy Code §§ 330 and 331, the Bankruptcy Rules, the Local Bankruptcy Rules, and this Court’s procedures. 73. The Firm therefore requests that this Court allow to the Firm, on an interim basis, an award for fees and expenses incurred during the Application Period equal to $322,428.45. The requested award (the “Award”) consists of $314,147.50 in fees and $8,280.95 in expenses for the Application Period. WHEREFORE LOCKE LORD LLP respectfully requests that the Court enter an order: (i) approving this Application; (ii) allowing, on an interim basis, the reasonable and necessary attorneys’ fees and expenses claimed herein as allowed administrative expenses of the Debtors’ estate under Bankruptcy Code § 503; (iii) directing the Archdiocese to pay these amounts on an interim basis; and (iv) granting the Firm such other and further relief to which it may be justly entitled. Dated: August 24, 2021. Respectfully submitted, /s/ C. Davin Boldissar Omer F. Kuebel, III (La #21682) C. Davin Boldissar (La. #29094) Locke Lord LLP 601 Poydras Street, Suite 2660 New Orleans, Louisiana 70130-6036 Telephone: (504) 558-5111 Facsimile: (504) 558-5200 Email: dboldissar@lockelord.com Co-Counsel to the Official Committee of Unsecured Creditors 20

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CERTIFICATE OF SERVICE I hereby caused a copy of the foregoing Application to be served on August 24, 2021 upon all parties by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and on all other parties requiring service under the Special Notice List as defined and required under the Court’s May 1, 2020 Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures via first-class United States mail, postage prepaid, to be sent on August 25, 2021. /s/ C. Davin Boldissar C. Davin Boldissar 21

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