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Full title: Application for Administrative Expenses for Post-Petition Transition Services. Objections/Request for Hearing Due in 21 days. Filed by Interested Party BOXLEY GROUP, LLC Hearing scheduled for 10/6/2021 at 09:00 AM at Houston, Courtroom 404 (MI). (Attachments: # 1 Exhibit A # 2 Exhibit B # 3 Exhibit C # 4 Exhibit D) (Pappas, Gus) (Entered: 08/20/2021)

Document posted on Aug 19, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

COMES NOW, Boxley Group, LLC, (“Applicant” or “Boxley Group”), the companyproviding financial/consulting services for debtor’s transition services team managing the Debtors’estate, and files this its Application Pursuant to Section 503(b) of Title 11 of the United States Codefor an entry of an order directing the Trustee’s payment of Applicant’s administrative claim forpost-petition consulting services in the amount of $68,071.21.Applicant is a consulting company offering financial consulting services, which in this caseconstituted financial transition services for the Debtors after the Debtors filed for Chapter11 bankruptcy.A true and correct copy of the Boxley Groupweekly summaries of the services rendered to the Transition Services Agreement Team isattached hereto as Exhibit A. A true and correct copy of the Boxley Group invoices for theservices rendered to the Transition Services Agreement Team is attached hereto as ExhibitB. Also included is a string of emails regarding Boxley Group’s Invoices sent to the Trusteeand attached hereto as Exhibit C. 2. Applicant requests that the Court enter an Order allowing the post-petition administrativeexpense priority under Section 503(b) of the Bankruptcy Code in the total amount of $68,071.21, and authorizing the Chapter 7 Trustee to pay the balance of the Applicant’sadministrative claim at such time as distributions are made to other administrative creditors,and in accordance with the priorities under the Bankruptcy Code.Wherefore, Boxley Group, LLC respectfully requests that the Court enter an order allowingits post-petition administrative expense claim in the amount of $68,071.21, and authorizing theChapter 7 Trustee to pay the balance of the Applicant’s administrative claim at such time asdistributions are made to other administrative creditors and in accordance with the priorities underthe Bankruptcy Code, and for all other relief, at law and in equity, to which Boxley Group, LLC maybe entitled.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION IN RE: § CHAPTER 7 § COUNTRY FRESH HOLDING COMPANY § CASE NO. 21-30574 INC., et. al., § § DEBTORS § JOINTLY ADMINISTERED BOXLEY GROUP LLC’S APPLICATION FOR PAYMENT OF ADMINISTRATIVE CLAIM FOR POST-PETITION TRANSITION SERVICES [RELATED TO DOCKET NO. 787] THIS APPLICATION SEEKS AN ORDER THAT MAY ADVERSELY AFFECT YOU. IF YOU OPPOSE THE APPLICATION, YOU SHOULD IMMEDIATELY CONTACT THE APPLICANT PARTY TO RESOLVE THE DISPUTE. IF YOU AND THE APPLICANT CANNOT AGREE, YOU MUST FILE A RESPONSE AND SEND A COPY TO THE APPLICANT. YOU MUST FILE AND SERVE YOUR RESPONSE WITHIN 21 DAYS OF THE DATE THIS WAS SERVED ON YOU. YOUR RESPONSE MUST STATE WHY THE APPLICATION SHOULD NOT BE GRANTED. IF YOU DO NOT FILE A TIMELY RESPONSE, THE RELIEF MAY BE GRANTED WITHOUT FURTHER NOTICE TO YOU. IF YOU OPPOSE THE APPLICATION AND HAVE NOT REACHED AN AGREEMENT, YOU MUST ATTEND THE HEARING. UNLESS THE PARTIES AGREE OTHERWISE, THE COURT MAY CONSIDER EVIDENCE AT THE HEARING AND DECIDE THE APPLICATION AT THE HEARING. REPRESENTED PARTIES SHOULD ACT THROUGH THEIR ATTORNEY. TO THE HONORABLE UNITED STATES BANKRUPTCY JUDGE: COMES NOW, Boxley Group, LLC, (“Applicant” or “Boxley Group”), the companyproviding financial/consulting services for debtor’s transition services team managing the Debtors’estate, and files this its Application Pursuant to Section 503(b) of Title 11 of the United States Codefor an entry of an order directing the Trustee’s payment of Applicant’s administrative claim forpost-petition consulting services in the amount of $68,071.21. In support thereof, Applicant would1

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respectfully show unto this Honorable Court as follows: I. BACKGROUND 1. Applicant is a consulting company offering financial consulting services, which in this caseconstituted financial transition services for the Debtors after the Debtors filed for Chapter11 bankruptcy. Boxley Group consultants provided services to the Transition ServicesAgreement Team of the “Fresh Food Group.” A true and correct copy of the Boxley Groupweekly summaries of the services rendered to the Transition Services Agreement Team isattached hereto as Exhibit A. A true and correct copy of the Boxley Group invoices for theservices rendered to the Transition Services Agreement Team is attached hereto as ExhibitB. Also included is a string of emails regarding Boxley Group’s Invoices sent to the Trusteeand attached hereto as Exhibit C. 2. Specifically, Robert Gilbert of Boxley Group performed CFO level services to Debtors. 3. Lee Knape, a senior financial consultant with Boxley Group, performed controller levelaccounting work to support the Transition Services Agreement Team. Mr. Knape served asthe controller of the Transition Services Agreement Team and reported directly to the “FreshFood Group” CEO and President Bill Andersen. A true and correct copy of theorganizational chart of the Fresh Food Group Transition Services Team is attached heretoas Exhibit D. 4. For the period beginning on 05/10/21 and ending on 05/23/21, Boxley Group renderedservices in the amount of $9,982.50. (Invoice No 4131, Exhibit B). 5. For the period ending on 05/30/21, Boxley Group rendered services in the amount of2

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$10,882.50. (Invoice No 4140, Exhibit B). 6. For the period ending on 06/06/21, Boxley Group rendered services in the amount of$9,825.00. (Invoice No 4145, Exhibit B). 7. For the period ending on 06/13/21, Boxley Group rendered services in the amount of$9,915.00. (Invoice No 4156, Exhibit B). 8. For the period ending on 06/20/21, Boxley Group rendered services in the amount of$9,285.00. (Invoice No 4167, Exhibit B). 9. For the period ending on 06/27/21, Boxley Group rendered services in the amount of$10,103.71. (Invoice No 4180, Exhibit B). 10. For the period ending on 07/01/21, Boxley Group rendered services in the amount of$5,272.50. (Invoice No 4190, Exhibit B). 11. For the period ending on 07/06/21, Boxley Group rendered services in the amount of$1,897.50. (Invoice No 4191, Exhibit B) 12. For the period ending on 07/11/21, Boxley Group rendered services in the amount of$907.50. (Invoice No 4214, Exhibit B) 13. The Boxley Group weekly summaries set forth attached to Exhibit A identify the consultantsdoing the work for the Transition Services Team, their weekly accomplishments, theirplanned tasks and their identified obstacles. The work started on May 10, 2021. CountryFresh Holding Company, Inc., filed for Chapter 11 bankruptcy on February 15, 2021, and thematter was converted to a Chapter 7 petition on June 21, 2021. 3

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II. REQUESTED RELIEF 14. Section 503(b) of the Bankruptcy Code provides for the allowance of an administrativeexpense priority for “the actual, necessary costs and expenses of preserving the estate.”15. Section 503(b)(1)(A)(i) of the Bankruptcy Code provides for the allowance of anadministrative expense priority for “wages, salaries, and commissions for services renderedafter the commencement of the case.” 16. Applicant requests that the Court enter an Order allowing the post-petition administrativeexpense priority under Section 503(b) of the Bankruptcy Code in the total amount of $68,071.21, and authorizing the Chapter 7 Trustee to pay the balance of the Applicant’sadministrative claim at such time as distributions are made to other administrative creditors,and in accordance with the priorities under the Bankruptcy Code. III. CONCLUSION AND PRAYER Wherefore, Boxley Group, LLC respectfully requests that the Court enter an order allowingits post-petition administrative expense claim in the amount of $68,071.21, and authorizing theChapter 7 Trustee to pay the balance of the Applicant’s administrative claim at such time asdistributions are made to other administrative creditors and in accordance with the priorities underthe Bankruptcy Code, and for all other relief, at law and in equity, to which Boxley Group, LLC maybe entitled. 4

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Respectfully submitted, DABNEY PAPPAS /s/ Gus E. Pappas Gus E. Pappas State Bar No. 15454850 1776 Yorktown, Suite 425 Houston, Texas 77056 713-621-2678 Telephone 713-621-0074 Facsimile ATTORNEY FOR BOXLEY GROUP, LLC CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing MOTION FORPAYMENT OF ADMINISTRATIVE CLAIM FOR POST-PETITION TRANITION SERVICEShas been electronically filed in this case with the Clerk of the United States Bankruptcy Court byusing the CM/ECF system and was served upon all parties via the Court’s electronic case filingsystem (ECF) on this the 20th day of August, 2021. /s/ Gus E. Pappas Gus E. Pappas 5

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