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Full title: Objection to application for compensation by Trustee Patti J. Sullivan re: 359 Application for Compensation with hearing. An affidavit or verification, Proof of service. (Sullivan, Patti) (Entered: 07/28/2021)

Document posted on Jul 27, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The Continue Hearing is scheduled for Tuesday, August 3, 2021 at 9:30 A.M. at Courtroom 2B, 2nd Floor, 316 North Robert Street, St. Paul, MN 55101 before Judge William J. Fisher. The trustee has requested information from Copeland Buhl & Company PLLP regarding the apparent change in tax structure but has not received sufficient information for the trustee’s accountant to determine how to proceed or how to calculate tax liabilities resulting from the sale.I, Susan M. Tschann, declare that on July 28, 2021, I caused the following documents: Chapter 7 Trustee’s Objection to the First Application for Allowance of Fees and Expenses of Accountant February 24, 2021 through May 31, 2021 (Copeland Buhl & Company PLLP) be filed electronically with the Clerk of Court through ECF, and that the above documents will be delivered y automatic e-mail notification pursuant to the rules of ECF and this constitutes notice pursuant to Local Rule 006-1(a).Peoria, IL 61602 Bassford Remele PA Fredrikson & Byron PA Luis Salazar on behalf of Interested Party Official on behalf of Debtor 1 Tea Olive I, LLC Salazar Law Committee of Unsecured Creditors 200 South Sixth St., Ste.Minneapolis, MN 55402 Donna Boldt Jeffrey D Ganz Steeplechase Advisors, LLC Needleart World LLC on behalf of Second Avenue Capital Partners, 601 Carlson Pkwy

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UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA In Re: TEA OLIVE I, LLC Chapter 7 Bky Case No. 21-30037-WJF Debtor. CHAPTER 7 TRUSTEE’S OBJECTION TO FIRST APPLICATION FOR ALLOWANCE OF FEES AND EXPNESES OF ACCOUNTANT FEBRUARY 24, 2021 THROUGH MAY 31, 2021 (COPELAND BUHL & COMPANY PLLP) TO: THE COURT, UNITED STATES TRUSTEE, THE DEBTOR AND THEIR ATTORNEY AND OTHER PARTIES IN INTEREST SPECIFIED IN LOCAL RULE 9013-3: 1. Patti J. Sullivan, is the trustee of the Bankruptcy Estate of the above-named debtor. 2. At Docket 372 there was a Notice of Continue Hearing regarding Docket 359 “First Application for Allowance of Fees and Expenses of Accountant February 24, 2021 Through May 31, 2021 (Copeland Buhl & Company PLLP). The Continue Hearing is scheduled for Tuesday, August 3, 2021 at 9:30 A.M. at Courtroom 2B, 2nd Floor, 316 North Robert Street, St. Paul, MN 55101 before Judge William J. Fisher. 3. At Docket 367 filed on July 08, 2021, the U.S. Trustee filed an Objection to the “First Application for Allowance of Fees and Expenses of Accountant February 24, 2021 Through May 31, 2021 (Copeland Buhl & Company PLLP)”, filed at Docket 359. 4. Trustee Patti J. Sullivan hereby joins in the Objection of the U.S. Trustee’s Office as set forth in Paragraph 3 above for the same reasoning set forth in the objection filed at Docket 367 on July 08, 2021. 5. Trustee Patti J. Sullivan is attempting to determine the tax consequences, if any, resulting from the sale of the debtor’s assets during the Chapter 11, but has not been able to

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obtain information to determine if there will be taxes owed as a result of the sale. Apparently, based on all of the information the trustee has been able to obtain, a tax analysis had not been conducted prior to the sale during the Chapter 11. The trustee was advised by debtor’s accountant that the debtor converted from its pre-bankruptcy filing tax structure, apparently a partnership, to a C Corporation shortly before the Chapter 11 filing. The trustee has requested information from Copeland Buhl & Company PLLP regarding the apparent change in tax structure but has not received sufficient information for the trustee’s accountant to determine how to proceed or how to calculate tax liabilities resulting from the sale. WHEREFORE, the trustee Patti J. Sullivan requests that the Bankruptcy Court deny any distribution of the allowed fees through the application of the retainer or other such authorization for payment. Dated: July 28, 2021 /e/ Patti J. Sullivan Patti J. Sullivan Trustee in Bankruptcy Attorney ID No. 170124 1595 Selby Avenue Suite 205 Saint Paul, MN 55104 (651) 699-4825 VERIFICATION I, Patti J. Sullivan, Chapter 7 trustee, named in the foregoing Objection declare under penalty of perjury that the foregoing is true and correct according to the best of my knowledge, information and belief. Executed on: July 28, 2021 /e/ Patti J. Sullivan Patti J. Sullivan, Trustee

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DISTRICT OF MINNESOTA In the Matter of: TEA OLIVE I, LLC Bky No. 21-30037-WJF Chapter 7 Debtor. DECLARATION REGARDING ELECTRONIC FILING AND UNSWORN CERTIFICATE OF SERVICE I, Susan M. Tschann, declare that on July 28, 2021, I caused the following documents: Chapter 7 Trustee’s Objection to the First Application for Allowance of Fees and Expenses of Accountant February 24, 2021 through May 31, 2021 (Copeland Buhl & Company PLLP) be filed electronically with the Clerk of Court through ECF, and that the above documents will be delivered y automatic e-mail notification pursuant to the rules of ECF and this constitutes notice pursuant to Local Rule 006-1(a). I further certify that on July 28, 2021, I mailed a copy of the foregoing documents to each entity named elow at the address stated below for each entity by first class mail postage prepaid: ea Olive I, LLC 600 Eagan Woods Drive, Suite 120 agan, MN 55121 Roger Cornelius Clear Thinking Group LLC Heller Draper & Horn LLC 317 South Old US Hwy 24 401 Towne Centre Dr on behalf of Interested Party Official Watseka, IL 60970 Hillsborough, NJ 08844 Committee of Unsecured Creditors 650 Poydras St Ste 2500 New Orleans, LA 70130-6103 Jason Plummer Constellation New Energy Indera Mills Company R.P. Acquisition Corporation 1310 Point Street Attn: James Olson 514 E. Vandalia Street 12th Floor PO Box 309 Edwardsville IL 62025 Baltimore, MD 21231 Yadkinville, NC 27055 Bruce Riedle Donald L. Curtis Chantel Lambert 514 E. Vandalia Street MWI Veterinary Supply Cam2 International Edwardsville IL 62025 3041 W. Pasadena Drive PO Box 530 Boise, ID 83702 Roseland, LA 70456

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514 E. Vandalia Street PO Box 199043 Edwardsville IL 62025 Blythebourne Station Creditors Heller Draper & Horn LLC 650 Poydras St Ste 2500 Brooklyn, NY 11219 New Orleans, LA 70130 American Electric Power Nathan E Delman on behalf of Janaki Hannah Nair on behalf of 1 Riverside Plaza Interested Party Deck Commerce, Inc. Interested Party Illiana Realty, LLC & W13th Floor HMB Legal Counsel Crabtree Elias Meginnes & Seghetti PC 500 West Madison Ste 3700 416 Main St Ste 1400 Columbus, OH 43215 Chicago, IL 60661 Peoria, IL 61602 Bassford Remele PA Fredrikson & Byron PA Luis Salazar on behalf of Interested Party Official on behalf of Debtor 1 Tea Olive I, LLC Salazar Law Committee of Unsecured Creditors 200 South Sixth St., Ste. 4000 2121 SW 3rd Ave Suite 100 100 S 5th St. Ste. 1500 Minneapolis, MN 55402 Miami, FL 33129 Minneapolis, MN 55402 Donna Boldt Jeffrey D Ganz Steeplechase Advisors, LLC Needleart World LLC on behalf of Second Avenue Capital Partners, 601 Carlson Pkwy LLC and the benefit of CIT Northbridge LLC 4732 G. North Royal Atlanta Drive Minnetonka, MN 55343 Riemer & Braunstein LLP Tucker, GA 30084 100 Cambridge St 22nd FL Boston, MA 02114 Duane J. Brescia Scott Guilleaume Symmetry Energy Solutions on behalf of Interested Party Valassis Communications, Inc P.O. Box 4981 Epicor Software Corporation 19975 Victor Parkway Houston, TX 77210 720 Brazos St., Suite 700 Livonia, MI 48152 Austin, MN 78701 Commonwealth Edison Company Lyena Hale Kimberly Troast 2301 Market Street, S23-1 STORE Master Funding I, LLC Under Armour, Inc. Philadelphia, PA 19103 8377 E. Hartford Drive, Suite 100 1020 Hull Street Scottsdale, AZ 85255 Baltimore, MD 21230 Copeland Buhl And Heller Draper & Horn LLC Preston Waller Company PLLP 650 Poydras St Ste 2500 True Media, LLC Attn: Sean F. Hauenstein New Orleans, LA 70130 500 Business Loop 70 West 800 East Wayzata Blvd. Suite 300 Columbia, MI 65203 Wayzata, MN 55391 Dominick L Lanzito on behalf of Terri A. Running, Attorney Interested Party Rochelle Municipal Utilities Messerli Kramer Peterson Johnson & Murray Chicago LLC 1400 Fifth Street Towers 200 W Adams St Ste 2125 100 South Fifth Street Chicago, IL 60606-5213 Minneapolis, MN 55402 i i k i b h lf f A nd, I declare, under penalty of perjury, that the foregoing is true and correct. xecuted on: July 28, 2021 /e/ Susan M. Tschann

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