HTML Document View

Full title: Application for Compensation Second Monthly Fee Application of Red Banyan Group, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Public Relations Consultant to the Debtors for the period December 1, 2020 to December 31, 2020 Filed by YouFit Health Clubs, LLC. Objections due by 3/5/2021. (Attachments: # 1 Exhibit A & B # 2 Notice of Fee Application) (Meloro, Dennis) (Entered: 02/19/2021)

Document posted on Feb 18, 2021 in the bankruptcy, 8 pages and 2 tables.

Bankrupt11 Summary (Automatically Generated)

The objection period for the First Monthly Application of Red Banyan Group, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Public Relations Consultant to the Debtors for the Period November 9, 2020 Through November 30, 2020202] entered on December 3, 2020 (the “Administrative Fee Order”), Red Banyan Group, LLC (“Red Banyan”) hereby submits this second monthly application (the “Second Monthly Application”) for compensation of services rendered as public relations consultant for the above-captioned debtors and debtors-in-possession (the “Debtors”), seeking interim allowance of fees in the amount of $25,412.50 and payment of professional fees in the amount of $20,330.00 (80% of 1 On November 13, 2020, the Debtors filed the Application of the Debtors for Entry of an Order Authorizing Retention and Employment of Red Banyan Group, LLC as Public Relations Consultant to the Debtors Nunc Pro Tunc as of the Petition Date [Docket No. 78].On February 10, 2021, Red Banyan filed the First Monthly Application of Red Banyan Group, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Public Relations Consultant to the Banyan seeks interim allowance of fees in the amount of $25,412.50 for services rendered on behalf of the Debtors during the Compensation Period, payment of 80% of such fees in the amount of $20,330.00, and reimbursement of actual necessary costs and expenses in the amount of $560.00.

List of Tables

Page 1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 YOUFIT HEALTH CLUBS, LLC, et al.,1 Case No. 20-12841 (MFW) Debtors. (Jointly Administered) Objection Deadline: March 5, 2021 at 4:00 p.m. (ET) Hearing Date: To be determined if any objection is filed SUMMARY OF SECOND MONTHLY APPLICATION OF RED BANYAN GROUP, LLC, FOR COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES AS PUBLIC RELATIONS CONSULTANT TO THE DEBTORS FOR THE PERIOD DECEMBER 1, 2020 THROUGH DECEMBER 31, 2020 Name of Applicant: Red Banyan Group, LLC Authorized to Provide Professional Services to: YouFit Health Clubs, LLC, et al. Date of Retention: December 3, 2020 nunc pro tunc to November 9, 2020 Period for Which Compensation and December 1, 2020 through December 31, 2020 Reimbursement sought: Amount of Compensation Sought as Actual, $25,412.502 Reasonable and Necessary: Amount of Compensation for Which Payment is $20,330.00 (80% of fees) Sought Pursuant to this Application: Amount of Expense Reimbursement Sought as $560.00 Actual, Reasonable and Necessary: This is a(n): X Monthly Interim Final Application 1 The last four digits of YouFit Health Clubs, LLC’s tax identification number are 6607. Due to the large number of debtor entities in these chapter 11 cases, a complete list of the debtor entities and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the claims and noticing agent at www.donlinrecano.com/yfhc. The mailing address for the debtor entities for purposes of these chapter 11 cases is: 1350 E. Newport Center Dr., Suite 110, Deerfield Beach, FL 33442. 2 December fees have been deducted from the $70,000.00 retainer and no payment is due at this time.

Page 2

This Application (as defined below) does not include any hours incurred in connection with the preparation of this Application. PRIOR APPLICATION
Table 1 on page 2. Back to List of Tables
Date Filed,
Docket No.
Period
Covered
Requested
Fees
Requested
Expenses
Approved
Fees
Approved
Expenses
Order
Entered
February 11,
2021 (Docket
No. 746)
November 9
to 30, 2020
$15,627.50 $0.00 N/A3 N/A3 N/A3
This Application (as defined below) does not include any hours incurred in connection with the preparation of this Application. PRIOR APPLICATION COMPENSATION BY INDIVIDUAL
Table 2 on page 2. Back to List of Tables
Name of
Professional Person
Position Hourly
Billing
Rate
Total
Billed
Hours
Total
Compensation
Adina Pollak Communications Consultant $475.00 2.10 $997.50
Jodie Singer Communications Consultant $475.00 31.30 $14,867.50
Kelcey Kintner Communications Consultant $475.00 20.10 $9,547.50
Total: None None 53.50 $25,412.50
Blended Rate: $475.00 None None None None
This Application (as defined below) does not include any hours incurred in connection with the preparation of this Application. PRIOR APPLICATION COMPENSATION BY INDIVIDUAL COMPENSATION BY PROJECT CATEGORY
Table 3 on page 2. Back to List of Tables
Project Category Total Hours Total Fees
Administrative Tasks .30 $142.50
Calls 17.00 $8,075.00
Emails 2.70 $1,298.50
Media Monitoring 7.50 3562.50
Planning/Preparation 5.80 $2,755.00
Press Outreach .30 $142.50
Research .30 $142.50
Writing/Editing 19.60 $9,310.00
Total: 53.50 $25,412.50
3 The objection period for the First Monthly Application of Red Banyan Group, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Public Relations Consultant to the Debtors for the Period November 9, 2020 Through November 30, 2020 [Docket No. 746] runs on February 25, 2021.

Page 3

EXPENSE SUMMARY
Table 1 on page 3. Back to List of Tables
Expense Category Service Provider
(if applicable)
Total Expenses
Two press releases published
online through Cision/PRWEB
Cision/PRWEB $560.00
Total Disbursements: None $560.00

Page 4

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 YOUFIT HEALTH CLUBS, LLC, et al.,1 Case No. 20-12841 (MFW) Debtors. (Jointly Administered) Objection Deadline: March 5, 2021 at 4:00 p.m. (ET) Hearing Date: To be determined if any objection is filed SECOND MONTHLY APPLICATION OF RED BANYAN GROUP, LLC FOR COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES AS PUBLIC RELATIONS CONSULTANT TO THE DEBTORS FOR THE PERIOD DECEMBER 1, 2020 THROUGH DECEMBER 31, 2020 Pursuant to sections 330 and 331 of title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”) and the Administrative Order Establishing Procedures for Monthly, Interim, and Final Compensation and Reimbursement of Expenses of Professionals Retained in these Chapter 11 Cases [Docket No. 202] entered on December 3, 2020 (the “Administrative Fee Order”), Red Banyan Group, LLC (“Red Banyan”) hereby submits this second monthly application (the “Second Monthly Application”) for compensation of services rendered as public relations consultant for the above-captioned debtors and debtors-in-possession (the “Debtors”), seeking interim allowance of fees in the amount of $25,412.50 and payment of professional fees in the amount of $20,330.00 (80% of 1 The last four digits of YouFit Health Clubs, LLC’s tax identification number are 6607. Due to the large number of debtor entities in these chapter 11 cases, a complete list of the debtor entities and the last four digits of their federal tax identification numbers is not provided herein. A complete list of such information may be obtained on the website of the claims and noticing agent at www.donlinrecano.com/yfhc. The mailing address for the debtor entities for purposes of these chapter 11 cases is: 1350 E. Newport Center Dr., Suite 110, Deerfield Beach, FL 33442.

Page 5

$25,412.50) together with reimbursement of actual and necessary expenses incurred in the amount of $560.00, for the period from December 1, 2020 through December 31, 2020 (the “Compensation Period”). In support of this First Monthly Application, Red Banyan respectfully represents as follows: JURISDICTION 1. This Court has jurisdiction over this matter pursuant to the provisions of 28 U.S.C. §§ 157 and 1334, and the Amended Standing Order of Reference from the United States District Court for the District of Delaware dated as of February 29, 2012. Venue is proper in this District pursuant to 28 U.S.C. §§ 1408 and 1409. The statutory predicates for the relief sought herein are sections 330 and 331 of the Bankruptcy Code, Bankruptcy Rule 2016 and Local Rule 2016-2. BACKGROUND 2. On November 9, 2020, each of the Debtors filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code (the “Petition Date”). 3. The Debtors have continued in possession of their properties and are operating and managing their businesses as debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 4. The Debtors’ cases are being jointly administered for procedural purposes only, pursuant to the Order Authorizing and Directing the Joint Administration of the Debtors’ Chapter 11 Cases for Procedural Purposes Only [Docket No. 37] entered on November 10, 2020. 5. On November 13, 2020, the Debtors filed the Application of the Debtors for Entry of an Order Authorizing Retention and Employment of Red Banyan Group, LLC as Public Relations Consultant to the Debtors Nunc Pro Tunc as of the Petition Date [Docket No. 78]. 6. On November 18, 2020, an official committee of unsecured creditors was appointed in these chapter 11 cases. No request has been made for the appointment of a trustee or examiner.

Page 6

7. On December 3, 2020, the Court entered the Order Authorizing Retention and Employment of Red Banyan Group, LLC as Public Relations Consultant to the Debtors Nunc Pro Tunc as of the Petition Date [Docket No. 197]. 8. Pursuant to the Administrative Fee Order, professionals employed by the estate may file and serve a monthly fee statement seeking interim approval and allowance of compensation for services rendered and reimbursement of expenses incurred during the preceding month. If no objections are raised prior to the expiration of a 14-day objection period, the Debtors are authorized to pay each professional an amount equal to the lesser of (i) 80% of the fees and 100% of the expenses requested in the monthly fee statement or (ii) 80% of the fees and 100% of the expenses requested in the monthly fee statement that are not subject to an objection. 9. On February 10, 2021, Red Banyan filed the First Monthly Application of Red Banyan Group, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Public Relations Consultant to the Debtors for the Period November 9, 2020 Through November 30, 2020 [Docket No. 746] (the “First Monthly Fee Application”). The 14-day objection period for the First Monthly Fee Application expires on February 25, 2021. RELIEF REQUESTED 10. Through this Second Monthly Application, and in accordance with the Administrative Fee Order, Red Banyan seeks interim allowance of fees in the amount of $25,412.50 for services rendered on behalf of the Debtors during the Compensation Period, payment of 80% of such fees in the amount of $20,330.00, and reimbursement of actual necessary costs and expenses in the amount of $560.00. 11. Red Banyan has received no payment and no promises for payment from any source other than the Debtors for services rendered during the Compensation Period in connection with these chapter 11 cases. There exists no agreement or understanding between Red Banyan and any

Page 7

other person for the sharing of any compensation to be received for services rendered by Red Banyan in these chapter 11 cases. 12. All services for which compensation is requested by Red Banyan pursuant to this Application were performed for or on behalf of the Debtors in these chapter 11 cases. 13. This is Red Banyan’s second monthly application seeking interim allowance of fees, partial payment thereof, and reimbursement of expenses. SUMMARY OF SERVICES RENDERED 14. Red Banyan has maintained detailed records of the time spent in the rendition of professional services to the Debtors during the Compensation Period. Attached hereto as Exhibit A and incorporated herein by reference is a true and correct copy of the monthly billing statement prepared for the services rendered in these cases by Red Banyan. The billing statement is in the same form regularly used by Red Banyan to bill its clients for services rendered and includes the date that the services were rendered, a detailed, contemporaneous narrative description of the services provided, the amount of time spent for each service, and the designation of the professional who performed the service. 15. In total, Red Banyan rendered 53.50 hours of professional services during the Compensation Period, resulting in fees totaling $25,412.50, and incurred reasonable and necessary expenses totaling $560.00. 16. The general areas in which Red Banyan has rendered services to the Debtors during the Compensation Period may be broadly characterized as follows: (a) Red Banyan professionals strategized, engaged in press outreach, drafted critical communications, and provided ongoing reporting. Red Banyan also: created a comprehensive communications plan for the entire bankruptcy process; conducted daily press outreach and social media monitoring; and drafted critical external bankruptcy communications to notify members of the filing and created communications for the staff and members of Philadelphia club when it was forced to close temporarily due to a COVID-19 government mandate.

Page 8

17. The generality of the foregoing description is amplified on a day-to-day basis by the billing statement attached as Exhibit A. 18. Attached as Exhibit B and made part hereof is the Certification of Robbin Lubbehusen, pursuant to section 504 of the Bankruptcy Code. 19. Pursuant to the Administrative Fee Order, professionals are entitled to compensation from the Debtors’ estates and may be paid 80% of their allowed monthly fees and 100% of allowed expenses. The Administrative Fee Order specifically provides that all fees and expenses received remain subject to the Court’s final approval and allowance. Thus, through this Second Monthly Application, Red Banyan seeks interim allowance of its fees in the amount of $25,412.50, payment of $20,330.00 (80% of $25,412.50) of those fees, and reimbursement of $560.00 in expenses. CONCLUSION WHEREFORE, Red Banyan respectfully requests (a) interim allowance of its fees for services rendered during the Compensation Period in the amount of $25,412.50, (b) payment for services rendered during the Compensation Period in the amount of $20,330 (80% of $18,762.50), and (c) allowance and reimbursement of $560.00 in actual and necessary expenses incurred during the Compensation Period. Dated: February 19, 2021 RED BANYAN GROUP, LLC Robbin Lubbehusen Robbin Lubbehusen, MBA Chief Operating Officer Red Banyan Group, LLC 500 W. Cypress Creek Rd., #560 Fort Lauderdale, FL 33309 Telephone: (954) 379-2115, ext. 101 Email: robbin@redbanyan.com