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Full title: Application to Employ with Affidavit of Disinterestedness FINAL Stegall, Benton, Melancon & Associates, LLC as Real Estate Appraiser/Valuation Expert 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: 06/16/2021)

Document posted on Jun 15, 2021 in the bankruptcy, 8 pages and 0 tables.

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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”), authorizing the Committee to employ Stegall, Benton, Melancon & Associates, LLC (the “Expert Appraiser” or “Stegall Benton”) as real estate appraiser/valuation expert to provide the Committee with real estate appraisal and expert valuation services pursuant to 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 The statutory bases for the relief requested herein are Bankruptcy Code sections 1103(a) and 328(a) and Bankruptcy Rule 2014(a).By this Application, the Committee requests the entry of an order, pursuant to sections 1103(a) and 328(a) of the Bankruptcy Code, Bankruptcy Rule 2014(a), and Local Bankruptcy Rule 2014-1 authorizing the Committee to employ and retain the Expert Appraiser to provide real estate appraisal and expert valuation services to the Committee for the scope of services set forth below.Initially, the Services will consist of:  Advisory services concerning valuation at the rate of $225 per hour for time spent by Bush Benton and/or David Melancon of Stegall Benton; and  Providing a limited number of appraisals or opinions of value, as to some or all of the eight specific properties listed on Attachment “D” to the Benton Declaration, for flat fees not to exceed the amounts ranging from $2,000 to $6,250 per property as set forth in that Attachment “D.” 7.Specifically, Stegall Benton has performed past work entirely unrelated to this bankruptcy case or any proceedings in connection with this case, including the following: (i) work for the Debtor’s affiliates including St. Catherine of Sienna Church/School, Holy Cross School, Mount Carmel Academy and St. Anthony Gardens; (ii) work for parties in interest including Hancock/Whitney Bank, Ochsner, LCMC, Entergy, Jones Walker, LLC, River Parish Disposal, First Bank & Trust, Bourgeois Bennett, Mercier Realty and Locke Lord.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re: ) ) Case No. 20-10846 THE ROMAN CATHOLIC CHURCH OF ) THE ARCHDIOCESE OF NEW ) Section “A” ORLEANS ) ) Chapter 11 Debtor. ) APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ENTRY OF AN ORDER UNDER 11 U.S.C. §§ 1103(a) AND 328(a) AND FED. R. BANKR. P. 2014(a) AUTHORIZING THE RETENTION OF STEGALL, BENTON, MELANCON & ASSOCIATES, LLC, AS REAL ESTATE APPRAISER/VALUATION EXPERT A HEARING WILL BE CONDUCTED ON THIS MATTER ON JULY 22, 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 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. 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”), authorizing the Committee to employ Stegall, Benton, Melancon & Associates, LLC (the “Expert Appraiser” or “Stegall Benton”) as real estate appraiser/valuation expert to provide the Committee with real estate appraisal and expert valuation services pursuant to 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

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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 Bush Benton (the “Benton Declaration”), attached hereto as Exhibit “1” and the Declaration of James Adams (the “Adams Declaration”), attached hereto as Exhibit “2”, and incorporated herein by reference for all purposes. In further support of the Application, the Committee respectfully represents as follows: JURISDICTION AND VENUE 1. The United States Bankruptcy Court for the Eastern District of Louisiana (the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b). The Committee confirms their consent, pursuant to rule 7008 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), to the entry of a final order by the Court. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The statutory bases for the relief requested herein are Bankruptcy Code sections 1103(a) and 328(a) and Bankruptcy Rule 2014(a). BACKGROUND 3. On May 1, 2020, the Archdiocese filed a voluntary petition under chapter 11 of title of the United States Code to commence the above-captioned 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. On May 20, 2020, the U.S. Trustee appointed the Committee. [Docket #94 and 114]. On June 10, 2020, the Committee was reconstituted. [Docket #151]. On February 8, 2021, the Court ordered the United States Trustee to appoint an additional committee of commercial unsecured creditors. [Docket #746] On March 5, 2021, the United States Trustee

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filed a notice of appointment of the Official Committee of Unsecured Commercial Creditors. [Docket #772 and 792] RELIEF REQUESTED 4. By this Application, the Committee requests the entry of an order, pursuant to sections 1103(a) and 328(a) of the Bankruptcy Code, Bankruptcy Rule 2014(a), and Local Bankruptcy Rule 2014-1 authorizing the Committee to employ and retain the Expert Appraiser to provide real estate appraisal and expert valuation services to the Committee for the scope of services set forth below. 5. The Committee proposes to retain the Expert Appraiser for the purpose of providing real estate appraisal and expert valuation services concerning the value of certain of the Debtor’s real property. Specifically, the Expert Appraiser is to assist the Committee in valuing those real estate properties that are most relevant to negotiations towards case resolution and a potential plan of reorganization. The Committee intends to work with the Debtor, on as cooperative a basis as possible, to analyze such valuation. For the reasons set forth herein, the Committee submits that the relief requested is in the best interests of the Committee, unsecured creditors, and the Debtor’s estate, and, therefore, should be granted. SERVICES TO BE PROVIDED 6. The Committee seeks to retain the Expert Appraiser for the purpose of providing real estate appraisal and expert valuation services. This includes: (a) opinions and advice concerning valuation; (b) the preparation of restricted appraisals and/or full appraisals; and (c) if requested by the Committee, providing one or more expert opinions and reports, and, if necessary, deposition and/or trial/hearing testimony (collectively, the “Services”). Initially, the Services will consist of:

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 Advisory services concerning valuation at the rate of $225 per hour for time spent by Bush Benton and/or David Melancon of Stegall Benton; and  Providing a limited number of appraisals or opinions of value, as to some or all of the eight specific properties listed on Attachment “D” to the Benton Declaration, for flat fees not to exceed the amounts ranging from $2,000 to $6,250 per property as set forth in that Attachment “D.” 7. The Expert Appraiser will not duplicate any services performed by any other professionals retained by the Committee. Rather, the scope of retention is limited to real estate appraisal and valuation work, which task is not being performed by any of the Committee’s other professionals. 8. In light of the fact that the Debtor has substantial unencumbered real property assets (the Schedules alone disclose more than 200 properties, See Docket #198 at pp. 37 through 55 of the PDF), the Committee requires the services of seasoned and experienced experts who can enable the Committee to adequately assess valuation. 9. The Committee believes that the Expert Appraiser is well-qualified to provide the Services in a cost-effective, efficient, and timely manner. As described below and more fully in the Benton Declaration and attached CV, the Expert Appraiser has extensive experience in real estate appraisal and valuation. The Committee and the Expert Appraiser have identified an initial focus list as set forth in Attachment “D.” This is an initial list. If it is determined that valuation opinions are desirable for additional properties, additional disclosure will be made through a supplemental filing. DISINTERESTEDNESS 10. To the best of the Committee’s knowledge, as set forth in the Benton Declaration, the Expert Appraiser does not have an actual conflict with any of the Debtor’s creditors, and the Expert Appraiser has no connection to the Debtor, its creditors, or any other parties in interest

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herein, or their respective attorneys and accountants, the U.S. Trustee, any person employed in the Office of the U.S. Trustee, or any Bankruptcy Judge currently serving on the United States Bankruptcy Court in this District except as set forth in the Benton Declaration. (See Benton Declaration at ¶¶9-13.) Specifically, Stegall Benton has performed past work entirely unrelated to this bankruptcy case or any proceedings in connection with this case, including the following: (i) work for the Debtor’s affiliates including St. Catherine of Sienna Church/School, Holy Cross School, Mount Carmel Academy and St. Anthony Gardens; (ii) work for parties in interest including Hancock/Whitney Bank, Ochsner, LCMC, Entergy, Jones Walker, LLC, River Parish Disposal, First Bank & Trust, Bourgeois Bennett, Mercier Realty and Locke Lord. As set forth in the Benton Declaration, to the extent that any new relevant facts or relationships bearing on the matters described herein are discovered or arise, Mr. Benton will use reasonable efforts to promptly file a supplemental declaration, as required by Bankruptcy Rule 2014(a). TERMS OF RETENTION 11. The Expert Appraiser intends to seek compensation for services rendered and expenses incurred in accordance with the Bankruptcy Code, the Bankruptcy Rules, and any applicable Orders of the Court. 12. The Committee proposes to compensate the Expert Appraiser as follows: a. Compensation at the rate of $225 per hour for the Expert Appraiser’s professionals (Mr. Bush Benton and Mr. David Melancon) for review and analysis services, and if necessary and requested by the Committee, to the extent the Expert Appraiser provides expert testimony; and b. The flat fees ranging from $2,000 to $6,250 per property for the initial list of specific property appraisals set forth in Attachment “D” to the Benton Declaration. 13. As more fully described in the Benton Declaration, Stegall, Benton, Melancon & Associates, LLC is not a prepetition creditor of the Debtors. No promises have been received by

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the Expert Appraiser as to compensation or payment in connection with this retention other than in accordance with the provisions of the Bankruptcy Code, the Bankruptcy Rules, and Orders of this Court. The Expert Appraiser has no agreement with any non-affiliated person or entity to share with such entity any compensation received in connection with this retention except as set forth in the Benton Declaration. 14. In addition, the Committee requests that the requirements of Bankruptcy Rule 2016 be tailored to the nature of the Expert Appraiser engagement and compensation structure. The Expert Appraiser has requested, under section 328(a) of the Bankruptcy Code, payment of the appraisal flat fees on a fixed-rate basis, which is customary in the real estate appraisal industry. Additionally, it is not the practice of real estate appraisers to keep detailed time records similar to those customarily kept by attorneys for performing real estate appraisals. 15. Accordingly, the Committee requests modification of the requirements under Bankruptcy Rule 2016. For avoidance of doubt, however, to the extent Stegall Benton performs expert testimonial services to be compensated under an hourly rate as set forth above Stegall Benton will keep reasonably detailed time records in one-tenth (1/10) of an hour increments. APPLICABLE AUTHORITY 16. To assist a committee with its statutory rights and duties under section 1103(c) of the Bankruptcy Code, a committee may retain experts and consultants. See 11 U.S.C. §§ 328(a) and 1103(a). 17. Bankruptcy Rule 2014 requires that an application for retention of a professional person include: [S]pecific facts showing the necessity for the employment, the name of the person to be employed, the reasons for the selection, the professional services to be rendered, any proposed arrangement for compensation, and to the best of the applicant’s knowledge, all of the person’s connections with the debtor, creditors, any other party

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in interest, their respective attorneys and accountants, the United States trustee, or any person employed in the office of the United States trustee. Fed. R. Bankr. P. 2014(a). 18. Based on the foregoing and as further supported by the Benton Declaration, the Committee believes that the retention of the Expert Appraiser to provide real estate appraisal and expert valuation services is necessary and appropriate, and in the best interests of the Committee, the estates, and their creditors. 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 PREVIOUS REQUEST 20. No previous request for the relief sought herein has been made by the Committee to this Court or any other court. CONCLUSION WHEREFORE, the Committee respectfully requests that the Court enter an order granting the relief requested in the Application and such other and further relief as may be just and proper. Dated: June 16, 2021 Respectfully submitted, By: /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 and

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James I. Stang (CA Bar No. 94435) (admitted pro hac vice) Andrew W. Caine (CA Bar No. No.110345) (admitted pro hac vice) Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., Suite 1300 Los Angeles, CA 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 Co-Counsel to the Official Committee of Unsecure Creditors CERTIFICATE OF SERVICE I hereby caused a true and correct copy of the foregoing Application to be served on June 16, 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 June 17, 2021. /s/ C. Davin Boldissar C. Davin Boldissar

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