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Full title: Application to Employ with Affidavit of Disinterestedness FINAL Zobrio, Inc. as Computer Consultant Filed by C. Davin Boldissar of Locke Lord LLP on behalf of Official Committee of Unsecured Creditors (Attachments: # 1 Exhibit 1 # 2 Exhibit 2 # 3 Proposed Order) (Boldissar, C.) (Entered: 05/06/2021)

Document posted on May 5, 2021 in the bankruptcy, 7 pages and 0 tables.

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By this Application, the Committee respectfully requests that the Court enter an order, substantially in the form attached hereto, pursuant to sections 328 and 1103 of the Bankruptcy Code, Bankruptcy Rule 2014 and Local Rule 2014-1, authorizing the Committee to employ and retain ZI as computer consultant in this Case, effective as of April 19, 2021, for the limited scope of services as set forth herein.3 As explained in more detail below, the Committee seeks to retain ZI to assist BRG (at lower rates than those charged by BRG) to export and extract information from the native files produced from the Archdiocese’s accounting systems in Financial Edge, QuickBooks, and Microsoft Access (the “Accounting System Data”).a. Coordinating the export of the Debtor’s Accounting System Data with the Debtor and BRG; b. Extracting Accounting System Data; c. Rendering Accounting System Data readable to BRG; d. Running reports of Accounting System Data at the direction of the Committee, BRG, or Committee counsel at Locke Lord LLP or Pachulski Stang Ziehl & Jones LLP (together, “Committee Counsel”); and 3 This Application is filed in an abundance of caution.Consistent with ZI’s policy with respect to its other clients, ZI will charge for services provided, and for other charges and disbursements incurred in rendering services to the Committee.These customary items include, among other things, travel and lodging expenses to the extent applicable (not currently anticipated for this Case); business meals during travel; and costs of reproduction, research, communications, legal counsel, applicable sales or excise taxes, and other direct expenses.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA IN RE: § Case No. 20-10846 § THE ROMAN CATHOLIC CHURCH § Section “A” OF THE ARCHDIOCESE OF NEW § ORLEANS, § Chapter 11 § Debtor.1 § § THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS’ EXPEDITED APPLICATION FOR ENTRY OF AN ORDER AUTHORIZING THE RETENTION AND EMPLOYMENT OF ZOBRIO, INC., AS COMPUTER CONSULTANT, EFFECTIVE AS OF APRIL 19, 2021 EXPEDITED RELIEF HAS BEEN REQUESTED. IF EXPEDITED RELIEF IS GRANTED, A HEARING WILL BE CONDUCTED ON THIS MATTER ON MAY 20, 2021, 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 MAY 17, 2021 AT 5:00 P.M.2 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. The Official Committee of Unsecured Creditors (the “Committee”) in the above-captioned case concerning the debtor-in possession, the Roman Catholic Church of the Archdiocese of New Orleans (the “Debtor”), files this Application (the “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. 2 This is the response date requested by the Committee, subject to the entry of an order entering this date.

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authorizing the Committee to employ Zobrio, Inc. (“ZI”), as computer consultant pursuant sections 328(a), 330, and 1103 of Title 11 of the United States Code (the “Bankruptcy Code”), Rule 2014 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 2014-1 of the Local Rules of the Bankruptcy Practice and Procedure for the United States Bankruptcy Court for the Eastern District of Louisiana (the “Local Rules”). In support of this Application, the Committee files concurrently with this Application the declaration of John Varadian (the “Varadian Declaration”), attached hereto as Exhibit 1, and the Declaration of James Adams, attached hereto as Exhibit 2, all incorporated herein by reference for all purposes. 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. BACKGROUND 3. On May 1, 2020 (the “Petition Date”), the Archdiocese filed a voluntary petition under chapter 11 of title of the United States Code to commence the above-captioned bankruptcy case (the “Bankruptcy Case”). Pursuant to 11 U.S.C. §§ 1107(a) and 1108, the Archdiocese continues to operate its business and manage its property as a debtor in possession. 4. On May 20, 2020, the United States Trustee appointed the Committee. [ECF Nos. 94 and 114]. On June 10, 2020, the Committee was reconstituted. [ECF No. 151]. On October 8, 2020, the Committee was again reconstituted. [ECF No. 478]. 5. On August 25, 2020, the Court authorized the Committee’s employment and retention of Berkeley Research Group, LLC (“BRG”) as the Committee’s financial advisor.

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RELIEF REQUESTED 6. By this Application, the Committee respectfully requests that the Court enter an order, substantially in the form attached hereto, pursuant to sections 328 and 1103 of the Bankruptcy Code, Bankruptcy Rule 2014 and Local Rule 2014-1, authorizing the Committee to employ and retain ZI as computer consultant in this Case, effective as of April 19, 2021, for the limited scope of services as set forth herein.3 As explained in more detail below, the Committee seeks to retain ZI to assist BRG (at lower rates than those charged by BRG) to export and extract information from the native files produced from the Archdiocese’s accounting systems in Financial Edge, QuickBooks, and Microsoft Access (the “Accounting System Data”). SERVICES TO BE PROVIDED 7. By this Application, the Committee seeks to employ ZI as a computer consultant for a limited scope of work to assist the Committee’s financial advisor BRG, as follows to assist in preparing for mediation and for the Committee’s analysis of the Debtor’s financial information. 8. ZI’s work will include the following: a. Coordinating the export of the Debtor’s Accounting System Data with the Debtor and BRG; b. Extracting Accounting System Data; c. Rendering Accounting System Data readable to BRG; d. Running reports of Accounting System Data at the direction of the Committee, BRG, or Committee counsel at Locke Lord LLP or Pachulski Stang Ziehl & Jones LLP (together, “Committee Counsel”); and 3 This Application is filed in an abundance of caution. While the Committee believes that a formal application may not be required under these authorities due to the scope and type of services provided, after consultation with the Office of the United States Trustee and the Debtor, this Application has been filed and formal approval is requested in an abundance of caution.

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e. Providing such other services to the Committee and its professionals as may be necessary in the Case. 9. The Committee seeks to retain ZI due to its specific expertise with the accounting system used by the Debtor, Financial Edge. The Accounting System Data is an important component of the Committee’s investigation and the Debtor agreed to provide this data as part of the agreement stated in open court on April 15 concerning the motion to compel [Docket #804]. 10. The Committee seeks an initial cap of $50,000 in fees and expenses for ZI’s work in this case, subject to any additional request to increase that amount. ZI’S QUALIFICATIONS 11. ZI is a privately-held company that has provided software and technology support to clients since 1987. Its clients are non-profits, governmental organizations, and private businesses. The ZI team consists of Microsoft-certified engineers, among others, trained and experienced in providing the exporting and report-generating activities required on the Debtor’s Accounting System Data. The Committee understands and recognizes that ZI’s professionals are in the business of providing the type of work required (with specific expertise in the type of accounting system used by the Debtor) in order to make the Accounting System Data usable in the most cost-effective way. DISINTERESTEDNESS 12. To the best of its knowledge and except to the extent disclosed in the Declaration of John Varadian, filed concurrently herewith (the “Varadian Declaration”), ZI (a) is “disinterested” within the meaning of section 101(14) of the Bankruptcy Code; and (b) does not hold or represent an interest adverse to the Debtor or to other parties in interest in the Case. In addition, ZI is not a creditor or equity security holder of the Debtor. See Varadian Declaration at ¶¶6-12.

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13. ZI will conduct an ongoing review of its files to ensure that no conflicts or other disqualifying circumstances exit or arise. If any new material facts or relationships are discovered or arise, ZI will supplement its disclosure to the Court. TERMS OF RETENTION 14. ZI’s hourly rates are as follows: Function 2021 Hourly Rates Data extraction and report generation $ 210 Expert witness (preparation, and oral or $ 450 written testimony) These hourly rates are subject to periodic adjustment, which shall be noted on the invoices for the first time period in which the revised dates become effective. Under the proposed terms of retention, ZI would also receive reimbursement of actual and necessary expenses it incurs. 15. ZI has advised the Committee that its fees are commensurate with the fees charged to its other clients and in other cases of this size, for clients that are billed on an hourly basis. 16. ZI will make application to this Court for allowance of its compensation and reimbursement of expenses in accordance with applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and the terms of any order establishing procedures for interim compensation that has been or may be entered in this Case. ZI’s compensation for services rendered on behalf of the Committee shall be fixed by the Court after due application. 17. Consistent with ZI’s policy with respect to its other clients, ZI will charge for services provided, and for other charges and disbursements incurred in rendering services to the Committee. These customary items include, among other things, travel and lodging expenses to

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the extent applicable (not currently anticipated for this Case); business meals during travel; and costs of reproduction, research, communications, legal counsel, applicable sales or excise taxes, and other direct expenses. Internal costs or overhead costs, and document production services (including regular administrative assistance) will not be charged for separately. 18. ZI will charge a monthly hosting fee of $350 during the duration of the period it maintains the Accounting System Data to maintain an environment for the database of electronically stored information. NOTICE 19. Notice of this Motion has been provided to 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 [ECF #22]. NO PRIOR REQUEST 20. No previous request for the relief sought herein has been made by the Committee to this or any other court. WHEREFORE, the Official Committee of Unsecured Creditors respectfully requests that the Court enter the proposed order submitted herewith: (a) granting this Application, (b) authorizing it to retain and employ Zobrio, Inc. as computer consultant, effective as of April 19, 2021, and (c) for such other relief as this Court may deem just and proper. Dated: May 6, 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

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-and- James I. Stang (CA Bar No. 94435) Andrew W. Caine (CA Bar No. 110345) Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., Suite 1300 Los Angeles, CA 90067 Telephone: (310)-277-6910 Facsimile: (310)-201-0760 Email: jstang@pszjlaw.com acaine@pszjlaw.com Co-Counsel to the Official Committee of Unsecured Creditors CERTIFICATE OF SERVICE I hereby caused a true and correct copy of the foregoing Application to be served on May 6, 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. /s/ C. Davin Boldissar C. Davin Boldissar

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