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Full title: Expedited Application for Compensation Expedited Third Interim Application of Blank Rome LLP for Allowance of Compensation and Reimbursement of Expenses, as Special Insurance Counsel to the Debtor, for the Period February 1, 2021 through May 31, 2021 for Blank Rome LLP, Special Counsel, Fee: $137,697.55, Expenses: $0.00. Filed by Laura F. Ashley (Attachments: # 1 Exhibit A - Summary of Total Hours and Fees by Professional # 2 Exhibit B - Summary of Compensation by Task Category # 3 Exhibit C - Expense Summary # 4 Exhibit D - Blended Hourly Rates # 5 Exhibit E - Budget and Staffing Plan # 6 Exhibit F - Blank Rome's Sixth Monthly Fee Statement # 7 Exhibit G - Blank Rome's Seventh Monthly Fee Statement # 8 Exhibit H - Proposed Order) (Ashley, Laura) (Entered: 08/26/2021)

Document posted on Aug 25, 2021 in the bankruptcy, 15 pages and 0 tables.

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COMES NOW, Blank Rome LLP (“Blank Rome”), pursuant to §§ 105(a), 330, and 331 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-1 of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana (the “Local Rules”), the U.S. Trustee 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 “UST Guidelines”), General Order 2019-4, section XIII, which establishes procedures for Professional Retention, Compensation, and Reimbursement of Expenses (the “Complex Case Procedures”), and the Order Authorizing the Retention and Employment of Blank Rome LLP as Special Insurance Counsel for the Debtor and Debtor in Possession, Nunc Pro Tunc to May 27, 2020 [Doc.On November 25, 2020, Blank Rome filed its First Interim Application of Blank Rome LLP for Allowance of Compensation and Reimbursement of Expenses, as Special Insurance Counsel to the Debtor, for the Period June 1, 2020 through September 30, 2020 [Doc.On March 24, 2021, Blank Rome filed its Second Interim Application of Blank Rome LLP for Allowance of Compensation and Reimbursement of Expenses, as Special Insurance Counsel to the Debtor, for the Period October 1, 2020 through January 31, 2021 [Doc.In accordance with the factors enumerated in § 330 of the Bankruptcy Code, Blank Rome respectfully submits that the foregoing amounts requested are fair and reasonable given (a) the complexity of this Chapter 11 Case, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services, and (e) the costs of comparable services other for non-bankruptcy cases. Blank Rome respectfully submits that the professional fees sought herein are not unusual given the magnitude and complexity of this case and the time expended in attending to the representation of the Debtor, and are commensurate with fees Blank Rome has been awarded in other cases, as well as with professional fees charged by other attorneys of comparable experience.

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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.1 EXPEDITED THIRD INTERIM APPLICATION OF BLANK ROME LLP FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES, AS SPECIAL INSURANCE COUNSEL TO THE DEBTOR, FOR THE PERIOD FEBRUARY 1, 2021 THROUGH MAY 31, 2021 EXPEDITED RELIEF HAS BEEN REQUESTED. IF EXPEDITED CONSIDERATION IS GRANTED, A HEARING WILL BE CONDUCTED ON THIS MATTER ON TUESDAY, SEPTEMBER 14, 2021, AT 1:30 P.M. (OR AT ANOTHER TIME ORDERED BY THE COURT), BY TELEPHONE THROUGH THE DIAL-IN FOR SECTION A: 1-888-684-8852; ACCESS CODE: 9318283. IF YOU OBJECT TO THE RELIEF REQUESTED OR YOU BELIEVE THAT EXPEDITED CONSIDERATION IS NOT WARRANTED, YOU MUST FILE A WRITTEN RESPONSE ON OR BEFORE TUESDAY, SEPTEMBER 7, 2021 (PROVIDED THAT THE HEARING IS SCHEDULED FOR SEPTEMBER 14, 2021). OTHERWISE, THE COURT MAY TREAT THE PLEADING AS UNOPPOSED AND GRANT THE RELIEF REQUESTED. 1 The last four digits of the Debtor’s federal tax identification number are 8966. The Debtor’s principal place of business is located at 7887 Walmsley Ave., New Orleans, LA 70125.

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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.1 SUMMARY SHEET FOR EXPEDITED THIRD INTERIM APPLICATION OF BLANK ROME LLP FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES, AS SPECIAL INSURANCE COUNSEL TO THE DEBTOR, FOR THE PERIOD FEBRUARY 1, 2021 THROUGH MAY 31, 2021
Table 1 on page 2. Back to List of Tables
Name of Applicant: Blank Rome LLP
Authorized to Provide Services to: The Debtor and Debtor-in-Possession
Petition Date: May 1, 2020
Retention Date: June 19, 2020 nunc pro tunc to May 27, 2020
Time Period Covered by this Application: February 1, 2021 – May 31, 2021
Total Fees Sought to be Allowed in this Application: $137,697.55
Total Expenses Sought to be Allowed in this
Application:
$0.00
Total Fees Approved by Interim Order to Date: $106,474.55
Total Expenses Approved by Interim Order to Date: $0.00
Total Fees Paid Pursuant to Prior Fee Statements: $163,355.14
Total Expenses Paid Pursuant to Prior Fee
Statements:
$0.00
Blended Rate in this Application for all Attorneys: $559.57
Blended Rate in this Application for all Timekeepers: $452.51
Number of Professionals in this Application : 8
If Applicable, Number of Professionals Included in
this Application but not Included in Staffing Plan:
0
Number of Professionals Billing Fewer than 15
Hours in Connection with this Application:
2
Are Any Rates Higher than Those Approved or
Disclosed at Retention?
No
Amount of Retainer Received in Case: N/A
This is a(n): ___ monthly _X_ interim ___ final application 1 The last four digits of the Debtor’s federal tax identification number are 8966. The Debtor’s principal place of business is located at 7887 Walmsley Ave., New Orleans, LA 70125.

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COMES NOW, Blank Rome LLP (“Blank Rome”), pursuant to §§ 105(a), 330, and 331 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-1 of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana (the “Local Rules”), the U.S. Trustee 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 “UST Guidelines”), General Order 2019-4, section XIII, which establishes procedures for Professional Retention, Compensation, and Reimbursement of Expenses (the “Complex Case Procedures”), and the Order Authorizing the Retention and Employment of Blank Rome LLP as Special Insurance Counsel for the Debtor and Debtor in Possession, Nunc Pro Tunc to May 27, 2020 [Doc. 172] (the “Retention Order”), and who hereby submits this application (the “Third Fee Application”), seeking interim approval and allowance of compensation and reimbursement of expenses incurred as special insurance counsel to the debtor and debtor in possession in the above-captioned chapter 11 case (the “Debtor”), for the period from February 1, 2021 through May 31, 2021. In support of this Third Fee Application, Blank Rome respectfully represents as follows: JURISDICTION AND VENUE 1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). 2. Venue is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409. BACKGROUND 3. On May 1, 2020 (the “Petition Date”), the Debtor filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtor remains in possession of its property and

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is managing its business as a debtor in possession pursuant to §§ 1107(a) and 1108 of the Bankruptcy Code. 4. The Debtor retained Blank Rome as its special insurance counsel, nunc pro tunc to May 27, 2020, pursuant to the Retention Order, which was entered on June 19, 2020. [Doc. 172]. 5. The Retention Order authorizes Blank Rome to apply for compensation for professional services rendered and reimbursement of expenses incurred in compliance with §§ 330 and 331 of the Bankruptcy Code and the applicable provisions of the Bankruptcy Rules, the Local Rules, the Complex Case Procedures, and any other applicable procedures and orders of the Court. The Retention Order also directs Blank Rome to make a reasonable effort to comply with the requests for information and additional disclosures as set forth in the UST Guidelines. 6. As further explained in the Expedited Application for Entry of an Order Authorizing the Retention and Employment of Blank Rome LLP as Special Insurance Counsel for the Debtor and Debtor in Possession, Nunc Pro Tunc to May 27, 2020 [Doc. 123] (the “Retention Application”), at engagement, Blank Rome agreed to be compensated on an hourly basis at discounted rates. No retainer was, or has been, paid to Blank Rome in connection with this Chapter 11 Case. 7. On November 25, 2020, Blank Rome filed its First Interim Application of Blank Rome LLP for Allowance of Compensation and Reimbursement of Expenses, as Special Insurance Counsel to the Debtor, for the Period June 1, 2020 through September 30, 2020 [Doc. 567] (the “First Fee Application”) seeking reimbursement of fees in the amount of $84,769.32. This Court granted the First Fee Application on an interim basis on December 23, 2020 [Doc. 681]. 8. On March 24, 2021, Blank Rome filed its Second Interim Application of Blank Rome LLP for Allowance of Compensation and Reimbursement of Expenses, as Special Insurance

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Counsel to the Debtor, for the Period October 1, 2020 through January 31, 2021 [Doc. 796] (the “Second Fee Application”) seeking reimbursement of fees in the amount of $21,705.23. This Court granted the Second Fee Application on an interim basis on April 14, 2021. 9. This Third Fee Application covers the period from February 1, 2021 through May 31, 2021 (the “Third Interim Fee Period”). By this Third Fee Application, Blank Rome seeks interim approval and allowance of fees in the amount of $137,697.55 and reimbursement of expenses in the amount of $0.00. The total number of hours expended during the Third interim Fee Period for which compensation is sought is approximately 304.30 hours. PRIOR MONTHLY FEE STATEMENTS 10. In accordance with this Court’s Complex Case Procedures, Blank Rome has submitted to the Debtor and to other Professional Fee Notice Parties (as defined in the Complex Case Procedures) its Sixth and Seventh Monthly Fee Statements (each a “Monthly Fee Statement”) during the Third interim Fee Period. 11. The Complex Case Procedures authorizes the Debtor to pay Blank Rome 80% of fees and 100% of expenses identified in each Monthly Fee Statement to which no objection has been served. The applicable objection periods have expired in connection with Blank Rome’s Sixth and Seventh Monthly Fee Statements, and no formal objections have been served. As of the date of this Application, Black Rome has received payment under the Sixth Fee Statement, but has not received payment under the Seventh Fee Statement. 12. The following is a summary of the amounts requested by Blank Rome pursuant to Monthly Fee Statements relating to the Third Interim Fee Period.

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Table 1 on page 6. Back to List of Tables
Monthly
Fee Statement
(Period)
Fees
Requested
Expenses
Requested
Fees
Paid
Expenses
Paid
Sixth Monthly
Fee Statement
(02/1/2021 –
03/31/2021)
$56,880.35
(80% of $71,100.44)
$0.00 $56,880.35 $0.00
Seventh Monthly
Fee Statement
(04/1/2021 –
05/31/2021)
$53,277.69
(80% of $66,597.11)
$0.00 $0.00 $0.00
FEES AND EXPENSES 13. Attached hereto as Exhibit A is a summary sheet, which includes a list of the Blank Rome professionals performing legal services on behalf of the Debtor during the Third Interim Fee Period, along with their respective titles, departments, years of admission, hourly rates, aggregate hours, and total fees billed. 14. Attached hereto as Exhibit B is a summary sheet, which includes a breakdown, by task category, of the services rendered and compensation sought by Blank Rome during the Third Interim Fee Period. 15. Attached hereto as Exhibit C is a summary of Blank Rome’s expenses incurred and reimbursement sought, by expense category, during the Third Interim Fee Period. Blank Rome did not incur any out-of-pocket disbursements in connection with its representation of the Debtor during the Third Interim Fee Period. 16. Attached hereto as Exhibit D is a chart that reflects the blended hourly rates, by timekeeper category, of the Blank Rome professionals performing legal services on behalf of the Debtor during the Third Interim Fee Period. 17. Attached hereto as Exhibit E is a budget and staffing plan for the Third Interim Fee Period.

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18. Attached hereto as Exhibit F is a copy of the Sixth Monthly Fee Statement submitted by Blank Rome, which contains records of Blank Rome’s fees incurred during the period from February 1, 2021 through March 31, 2021, consisting of contemporaneously maintained time entries for each professional in increments of tenths (1/10) of an hour. 19. Attached hereto as Exhibit G is a copy of the Seventh Monthly Fee Statement submitted by Blank Rome, which contains records of Blank Rome’s fees incurred during the period from April 1, 2021 through May 31, 2021, consisting of contemporaneously maintained time entries for each professional in increments of tenths (1/10) of an hour. 20. Finally, attached hereto as Exhibit H is a proposed order granting the relief requested herein. SUMMARY OF SERVICES RENDERED TO THE DEBTOR DURING THE THIRD INTERIM FEE PERIOD 21. During the Third Interim Fee Period, Blank Rome’s services provided to the Debtor included continued analysis of the Debtor’s historical insurance liability policies and secondary evidence of such policies. 22. Further, Blank Rome continued to assist the Debtor in responding to the Committee’s Rule 2004 document requests. Specifically, Blank Rome reviewed and prepared relevant insurance documents for production. 23. In addition, Blank Rome advised the Debtor in connection with insurance coverage for sexual abuse claims and the Debtor’s insurers’ correspondence and coverage positions in response to such claims. 24. Blank Rome also advised and assisted the Debtor in connection with written and oral communications and meetings with insurance companies and/or their counsel, as well as other parties in interest in this case.

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25. The professional primarily responsible for representing the Debtor in connection with this Chapter 11 Case is James Murray. Mr. Murray’s practice involves representing policyholder clients in all aspects of insurance recovery matters. Mr. Murray has practiced before state and federal courts for over thirty (30) years. Additionally, Mr. Murray was retained as special insurance counsel in the Diocese of Spokane, the Oregon Province, Society of Jesus (Jesuits), Diocese of Helena, Diocese of Duluth, Diocese of New Ulm, Archdiocese of Santa Fe, Diocese of Syracuse, Diocese of Buffalo, Diocese of Rochester, and Archdiocese of Agana cases. 26. All of the services for which compensation is requested by Blank Rome were performed for, or on behalf of, the Debtor, and not on behalf of any creditor, examiner, trustee, or any other entity. In addition, Blank Rome has not entered into any agreements to fix fees or to share compensation as prohibited by 18 U.S.C. § 155 and 11 U.S.C. § 504. REASONABLENESS OF FEES AND EXPENSES 27. As set forth in the chart attached hereto as Exhibit A and further detailed in the itemized time records attached hereto as Exhibits F-G, the professionals of Blank Rome expended a total of 304.30 hours during the Third Interim Fee Period. Blank Rome has charged discounted hourly rates for work of this character. The reasonable value of the services rendered by Blank Rome to the Debtor during the Third Interim Fee Period is $137,697.55. 28. In accordance with the factors enumerated in § 330 of the Bankruptcy Code, Blank Rome respectfully submits that the foregoing amounts requested are fair and reasonable given (a) the complexity of this Chapter 11 Case, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services, and (e) the costs of comparable services other for non-bankruptcy cases. Moreover, Blank Rome has reviewed the requirements set forth in Local Rule 2016-1 and believes this Application complies with such Rule.

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ACTUAL AND NECESSARY DISBURSEMENTS 29. As set forth in Exhibit C, a total of $0.00 of actual, necessary expenses were incurred by Blank Rome during the Third Interim Fee Period. Blank Rome’s disbursement policies pass through all expenses at actual cost or an estimated actual cost when the actual cost is difficult to determine. FACTORS TO BE CONSIDERED IN AWARDING ATTORNEY’S FEES 30. Bankruptcy Code § 330 authorizes the Court to award professional persons employed pursuant to Bankruptcy Code § 327 reasonable compensation for actual and necessary services rendered and reimbursement for actual and necessary expenses incurred. See 11 U.S.C. § 330. Specifically, Bankruptcy Code § 330(a) provides: (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 . . . * * * (3) In determining the amount of reasonable compensation to be awarded to an examiner, trustee under chapter 11, or professional person, the court shall consider the nature, the extent, and the value of such services, taking into account all relevant factors, including- (A) the time spent on such services; (B) the rates charged for such services; (C) whether the services were necessary to the administration of, or beneficial at the time at which the service was rendered toward the completion of, a case under this title; (D) whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed;

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(E) with respect to a professional person, whether the person is board certified or otherwise has demonstrated skill and experience in the bankruptcy field; and (F) whether the compensation is reasonable based on the customary compensation charged by comparably skilled practitioners in cases other than cases under this title. 11 U.S.C. § 330(a)(1) and (a)(3). 31. The Fifth Circuit traditionally has used the lodestar method to calculate reasonable attorneys’ fees. See Combs v. City of Huntington Texas, 829 F.3d 388, 392 (5th Cir. 2016); see also In re Fender, 12 F.3d 480, 487 (5th Cir. 1994). The lodestar is derived by multiplying the number of hours an attorney would reasonably spend for the same type of work by the prevailing hourly rate in the community. See Shipes v. Trinity Indus., 987 F.2d 311, 319 (5th Cir. 1993). A court then may adjust the lodestar up or down based on the factors contained in Johnson v. Georgia Highway Express, Inc., 488 F.2d 714, 717-19 (5th Cir. 1974). See Am. Benefit Life Ins. Co. v. Braddock (In re First Colonial Corp. of Am.), 544 F.2d 1291, 1298 (5th Cir. 1977) (applying the Johnson factors in the bankruptcy context). The Johnson factors include: (1) time and labor required; (2) the novelty and difficulty of the questions involved; (3) the skill required to perform the professional services properly; (4) the preclusion of other employment by the professional due to acceptance of the case; (5) the customary fee; (6) whether the fee is fixed or contingent; (7) time limitations imposed by the client or the circumstances; (8) the amount involved and the results obtained; (9) the experience, reputation and ability of the professionals; (10) the undesirability of the case; (11) the nature and length of the professional relationship with the client; and (12) awards in similar cases. See Johnson, 488 F.2d at 717-19; see also In re ASARCO LLC, No. 05-21207, 2011 WL 2975691, at *7 (Bankr. S.D. Tex. July 20, 2011) (applying the Johnson factors). 32. As more fully set forth below, Blank Rome respectfully submits that the Johnson factors and the elements governing awards of compensation pursuant to Bankruptcy Code §§ 330

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and 331 justify the allowance of the fees and expenses incurred in its representation of the Debtor during the Third Interim Fee Period. APPLICATION OF THE JOHNSON FACTORS 33. The professional services rendered by Blank Rome during the Third Interim Fee Period required a high degree of professional competence and expertise. Blank Rome submits that the services rendered to the Debtor were performed efficiently and effectively, and that the results obtained have provided tangible, identifiable, and material benefits to the Debtor’s estate. I. The Time and Labor Required. 34. As stated above, Blank Rome’s professionals have expended 304.30 hours during the Third Interim Fee Period in the representation of the Debtor. All of the time spent was necessary and appropriate for the representation of the Debtor in this Chapter 11 Case. This is especially true when considering the nature and urgency of the issues and tasks that arose in this Chapter 11 Case, including, among other things, the time and skill required to advise the Debtor in connection with insurance related issues on an as needed, and at times expedited, basis. 35. Blank Rome’s representation of the Debtor has required it to balance the need to provide quality services with the need to act quickly and to represent the Debtor in an effective, efficient and timely manner. Blank Rome submits that the hours spent were reasonable given the size and complexity of this case, and the significant, and often times urgent, legal issues raised. II. The Novelty and Difficulty of the Questions Involved. 36. This Chapter 11 Case is designated as a “complex” case and involves a significant number of complex issues in the areas of restructuring, finance, insurance coverage, and tort law. See Order Granting Complex Chapter 11 Bankruptcy Case Treatment [Doc. 18]. Blank Rome’s

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representation of the Debtor has involved the continued analysis of many historical insurance liability policies and secondary evidence of such policies. III. The Skill Required to Perform the Professional Services Properly. 37. Blank Rome believes that its recognized expertise in the area of insurance recovery matters has facilitated the resolution of certain matters in connection with this Chapter 11 Case and benefited the Debtor’s estate. Due to the nature and complexity of the legal issues presented in this case, Blank Rome was required to exhibit a high degree of legal skill in areas related to insurance coverage and recovery. Additionally, Blank Rome’s strong working relationship with various interested parties enabled Blank Rome to work with such professionals towards resolution of many salient issues. Blank Rome respectfully submits that its professionals have provided significant benefits to the Debtor during the Third Interim Fee Period. IV. The Preclusion of Other Employment by the Professional Due to Acceptance of the Case. 38. Blank Rome’s representation of the Debtor has not precluded its acceptance of new clients. V. The Customary Fee. 39. The rates charged by the Blank Rome’s professionals in this Chapter 11 Case are similar to the rates charged by Blank Rome in connection with non-bankruptcy work. The professional fees sought herein are based upon Blank Rome’s discounted hourly rates for services of this kind. 40. Blank Rome respectfully submits that the professional fees sought herein are not unusual given the magnitude and complexity of this case and the time expended in attending to the representation of the Debtor, and are commensurate with fees Blank Rome has been awarded in other cases, as well as with professional fees charged by other attorneys of comparable experience.

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VI. Whether the Fee is Fixed or Contingent. 41. Pursuant to Bankruptcy Code §§ 330 and 331, all fees sought by professionals employed under Bankruptcy Code § 327 are contingent pending final approval by this Court, and are subject to adjustment dependent upon the services rendered and the results obtained. The collective efforts of the various parties in interest and their respective professionals, including Blank Rome, have contributed to the resolution of many issues in this case in a relatively short period of time. Blank Rome’s expectation upon accepting this representation was that it would receive compensation for professional services rendered at the discounted rates. VII. Time Limitations Imposed by the Client or the Circumstances. 42. As previously set forth herein, Blank Rome was, at times, required to attend to certain issues arising in this Chapter 11 Case on an expedited basis. VIII. The Amount Involved and the Results Obtained. 43. During the Third Interim Fee Period, Blank Rome was instrumental in document production and facilitating the resolution of certain contested matters predicated on questions of insurance coverage. Further, Blank Rome submits that the fees requested in this Application are reasonable and appropriate when considering the results obtained on behalf of the Debtor. IX. The Experience, Reputation and Ability of the Professionals. 44. Blank Rome believes and respectfully submits that its professionals are highly regarded as experts in the field of insurance litigation. Blank Rome’s attorneys, over many years, have appeared in state and federal courts providing legal representation in all aspects of insurance recovery matters. Further, Mr. Murray, in particular, has been retained as special insurance counsel in approximately 11 other diocesan-type bankruptcy cases. X. The Undesirability of the Case.

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45. This matter was not undesirable for Blank Rome. XI. The Nature and Length of the Professional Relationship with the Client. 46. Blank Rome was appointed to serve as special insurance counsel to the Debtor on June 19, 2020, nunc pro tunc to May 27, 2020. XII. Awards in Similar Cases. 47. Blank Rome respectfully submits that the foregoing amounts requested are fair and reasonable based on the customary compensation charged by comparably skilled practitioners at Blank Rome and other firms in comparable bankruptcy and non-bankruptcy cases. The services provided in connection with the fees requested by Blank Rome during the Third Interim Fee Period are more fully described in the invoices attached hereto as Exhibits F-G. NO PRIOR REQUEST 48. Except for the submission of the Monthly Fee Statements, no prior application for the relief requested herein has been made to this or any other court. WHEREFORE, Blank Rome respectfully requests that the Court enter an Order (i) approving and allowing on an interim basis compensation in the amount of $137,697.55 for the reasonable and necessary legal services that Blank Rome rendered to the Debtor during the Third Interim Fee Period, and reimbursement of actual and necessary expenses incurred in the sum of $0.00; (ii) directing that Blank Rome be paid, from the Debtor’s estate, all such allowed fees and expenses which have not previously been paid pursuant to the Complex Case Procedures; and (iii) granting such other and further relief as the Court may deem just and proper.

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Dated: August 26, 2021 Respectfully submitted, Washington, D.C. /s/ James R. Murray JAMES R. MURRAY Blank Rome LLP 1825 Eye Street NW Washington, D.C. 20006 Telephone: (202) 420-2200 Facsimile: (202) 420-2201 Email: JMurray@BlankRome.com SPECIAL INSURANCE COUNSEL TO THE ROMAN CATHOLIC CHURCH OF THE ARCHDIOCESE OF NEW ORLEANS CERTIFICATION OF COMPLIANCE I, James R. Murray, pursuant to 28 U.S.C. § 1746, hereby declare under penalty of perjury that the following is true and accurate to the best of my knowledge and belief: (A) I am a partner with the applicant firm, Blank Rome LLP, and have been admitted to the bar of the District of Columbia since 1982. (B) I personally performed many of the legal services rendered by Blank Rome LLP as special insurance counsel to the Debtor and am familiar with the other work performed on behalf of the Debtor by the professionals at Blank Rome LLP. (C) I have reviewed the foregoing Application, and the facts set forth therein are true and correct to the best of my knowledge, information, and belief. Moreover, I have reviewed Local Rule 2016-1, the Complex Case Procedures, and the UST Guidelines and submit that this Application substantially complies with the same. Dated: August 26, 2021 Washington, D.C. /s/ James R. Murray__________________ James R. Murray

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