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Full title: Monthly Application for Compensation First Monthly Fee Application of Neubert, Pepe & Monteith, P. C. as Counsel to the Patient Care Ombudsman for Payment of Compensation and Reimbursement of Expenses for the period October 25, 2021 to November 30, 2021 Filed by Daniel T. McMurray, the Patient Care Ombudsman. Objections due by 1/25/2022. (Attachments: # (1) Notice # (2) Certificate of Service) (Lemisch, Raymond)

Document posted on Jan 3, 2022 in the bankruptcy, 21 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

PEPE & MONTEITH, P. C. FOR PAYMENT OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE PATIENT CARE OMBUDSMAN FOR THE PERIOD FROM OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021 Neubert Pepe & Monteith, P. C. (“NPM”), counsel to Daniel T. McMurray, Patient Care Ombudsman appointed in the above-captioned chapter 11 cases (the “PCO”), hereby submits its first monthly fee application (the “Application”) for entry of an order pursuant to section 331 of title 11 of the United States Code, 11 U.S.C. §§101 et seq, as amended (the “Bankruptcy Code”) and the order of this Court granting it payment of interim compensation and reimbursement of expenses for the period from October 25, 2021 through November 30, 2021. On October 25, 2021, the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”) appointed an Official Committee of Unsecured Creditors in the Chapter 11 Cases (the “Committee”) pursuant to Bankruptcy Code section 1102(a) WHEREFORE, NPM hereby requests: (a) allowance of compensation for necessary and valuable professional services rendered to the Ombudsman in the sum of $42,070.00 for the period from October 25, 2021 through November 30, 2021; (b) payment in the total amount of $33,656.00, which represents 80% of the total fees billed ,as provided under the Interim Compensation Order; and (c) granting such other relief as this Court deems just and proper.In accordance with Rule 2016(a) of the Federal Rules of Bankruptcy Procedure and Section 504 of Title 11, United States Code, no agreement or understanding exists between NPM and any other person for the sharing of compensation to be received in connection with the above-captioned cases.None of the professionals at NPM included in the proposed engagement by the Ombudsman pursuant to the Application vary their rates based on geographic location of the bankruptcy case except that, as a Connecticut-based attorney, Mark I. Fishman’s hourly rate for non-Connecticut matters is $425.00 instead of $400.00.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) GULF COAST HEALTH CARE LLC, et al.,1 ) Case No. 21-11336 (KBO) ) Debtors. ) (Jointly Administered) ) ) Obj. Deadline: January 25, 2022 at 4:00 p.m. ) Hearing Date: Only if objection is timely filed FIRST MONTHLY FEE APPLICATION OF NEUBERT PEPE & MONTEITH, P. C. FOR PAYMENT OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE PATIENT CARE OMBUDSMAN FOR THE PERIOD FROM OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021 Name of Applicant: Neubert Pepe & Monteith, P. C. Authorized to Provide Professional Patient Care Ombudsman Services to: Date of Retention: nunc pro tunc to October 25, 2021 Period for which compensation and October 25, 2021 through November 30, 2021 reimbursement is sought: Amount of Compensation sought as $42,070.00 actual, reasonable and necessary: (80 % of which is $33,656.00) Amount of Expense Reimbursement sought as actual, reasonable and $0 necessary: This is a(n):  Monthly ___ Interim ___ Final application This is the first monthly fee application filed in this case. Prior Applications: N/A 1 The last four digits of Gulf Coast Health Care, LLC’s federal tax identification number are 9281. There are 62 Debtors in these chapter 11 cases, for which the Debtors have requested joint administration. A complete list of the Debtors and the last four digits of their federal tax identification numbers are not provided herein. A complete list of such information may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://dm.epiq11.com/GulfCoastHealthCare. The location of Gulf Coast Health Care, LLC’s corporate headquarters and the Debtors’ service address is 40 South Palafox Place, Suite 400, Pensacola, FL 32502.

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TIME AND COMPENSATION BREAKDOWN OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021
Table 1 on page 2. Back to List of Tables
NAME OF
PROFESSIONAL
PERSON
POSITION/
NUMBER OF YEARS
HOURLY
BILLING
RATE
TOTAL
HOURS
BILLED
TOTAL
COMPENSATION
Mark I. Fishman Bankruptcy & Restructuring
Senior Counsel
Admitted to the Bar 1970
$425.00 94.3 $40,077.50
Patrick Linsey Bankruptcy and Litigation
Associate
Admitted to the Bar 2010
$275.00 5.50 $1,512.50
Stephanie Gibbons Paralegal $120.00 4.00 $480.00
TOTALS 38.60 $42,070.00
BLENDED RATE $405.30

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COMPENSATION BY PROJECT CATEGORY OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021
Table 1 on page 3. Back to List of Tables
PROJECT CATEGORY TASK
CODES
TOTAL
HOURS
BILLED
TOTAL
COMPENSATION
Case Administration B110 51.5 $21,062.50
Employment and Fee Applications B160 18.5 $6,642.50
Financing and Cash Collateral B230 33.5 $14,237.50
Ombudsman Report B320 0.3 $127.50
TOTAL 103.8 $42,070.00

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EXPENSE SUMMARY OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021 None

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) GULF COAST HEALTH CARE LLC, et al.,1 ) Case No. 21-11336 (KBO) ) Debtors. ) (Jointly Administered) ) FIRST MONTHLY FEE APPLICATION OF MNEUBERT PEPE & MONTEITH, P. C. FOR PAYMENT OF COMPENSATION AND REIMBURSEMENT OF EXPENSES AS COUNSEL TO THE PATIENT CARE OMBUDSMAN FOR THE PERIOD FROM OCTOBER 25, 2021 THROUGH NOVEMBER 30, 2021 Neubert Pepe & Monteith, P. C. (“NPM”), counsel to Daniel T. McMurray, Patient Care Ombudsman appointed in the above-captioned chapter 11 cases (the “PCO”), hereby submits its first monthly fee application (the “Application”) for entry of an order pursuant to section 331 of title 11 of the United States Code, 11 U.S.C. §§101 et seq, as amended (the “Bankruptcy Code”) and the order of this Court granting it payment of interim compensation and reimbursement of expenses for the period from October 25, 2021 through November 30, 2021. In support hereof, NPM respectfully represents as follows: 1 The last four digits of Gulf Coast Health Care, LLC’s federal tax identification number are 9281. There are 62 Debtors in these chapter 11 cases, for which the Debtors have requested joint administration. A complete list of the Debtors and the last four digits of their federal tax identification numbers are not provided herein. A complete list of such information may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://dm.epiq11.com/GulfCoastHealthCare. The location of Gulf Coast Health Care, LLC’s corporate headquarters and the Debtors’ service address is 40 South Palafox Place, Suite 400, Pensacola, FL 32502.

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I. JURISDICTION, VENUE AND STATUTORY PREDICATES FOR RELIEF SOUGHT 1. This Court has jurisdiction over this Application pursuant to 28 U.S.C. §1334. This is a core proceeding pursuant to 28 U.S.C. §157(b)(2)(A) and (B). Venue of this proceeding and this Application is proper in this District pursuant to 28 U.S.C. §§1408 and 1409. The statutory predicate for the relief sought herein is section 331 of the Bankruptcy Code. II. BACKGROUND 2. On October 14, 2021 (the “Petition Date”), each Debtor commenced a case by filing a petition for relief under chapter 11 of the Bankruptcy Code (collectively, the “Chapter 11 Cases”). 3. The Chapter 11 Cases are being jointly administered. 4. The Debtors continue to operate their businesses and manage their properties as debtors and debtors-in-possession pursuant to Bankruptcy Code sections 1107(a) and 1108. 5. On October 25, 2021, the Office of the United States Trustee for the District of Delaware (the “U.S. Trustee”) appointed an Official Committee of Unsecured Creditors in the Chapter 11 Cases (the “Committee”) pursuant to Bankruptcy Code section 1102(a) [Docket No. 111]. 6. No trustee or examiner has been appointed in the Chapter 11 Cases. 7. Additional information regarding the Debtors and the Chapter 11 Cases, including the Debtors’ business operations, capital structure, financial condition, and the reasons for and objectives of the Chapter 11 Cases, is set forth in the Declaration of M. Benjamin Jones in Support of Chapter 11 Petitions and First Day Pleadings [Docket No. 16] (the “First Day Declaration”). 8. On October 20, 2021, this Court entered an Order directing the appointment of a patient care ombudsman under Section 333 of the Bankruptcy Code (the “Appointment Order”) [D.I. 91].

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9. On October 25, 2021, the Office of the United States Trustee for this district filed a notice of appointment of the Ombudsman (the “Notice,”) [D.I. 112]. 10. The Ombudsman is a Senior Managing Director of Focus Management Group USA, Inc., which specializes, inter alia, in the management and turnaround of distressed health care businesses. Although the Ombudsman has vast experience in the health care field, the Ombudsman is not an attorney and requires the assistance of bankruptcy counsel. 11. NPM continuously rendered services to and on behalf of the Ombudsman for the period from October 25, 2021 through November 30, 2021 (the “Compensation Period”), totaling 103.8 hours of professional time. 12. Attached hereto as Exhibit “A” is a full and detailed statement describing the professional services rendered by each NPM attorney and paraprofessional during the Compensation Period. In submitting Exhibit A, both the Ombudsman and NPM reserve all rights, privileges, and doctrines such as the attorney-client privilege, work product doctrine and other or similar rights, privileges and doctrines and do not waive any such rights, privileges or doctrines. 13. The total sum due to NPM for professional services rendered on behalf of the Ombudsman for the Compensation Period is $42,070.00. NPM submits that the professional services it rendered on behalf of the Ombudsman during this time were reasonable and necessary. Among the services performed by NPM were the following: a. Case Administration, to which NPM devoted approximately half of its time: NPM, from the outset, continually monitored proceedings and the voluminous pleadings in order to detect any developments which could have an adverse effect on patient care. NPM kept the Ombudsman informed as to any such matters. This effort was conducted in a highly efficient manner, as NPM has sufficient bankruptcy experience to make prompt and expeditious determinations as to which pleadings merit further review and is able to rule out many pleadings from further review. NPM was also continually in communication with the Ombudsman regarding the Ombudsman’s responsibilities and the scope and timing of his duties in the Case and continually interfaced for the Ombudsman with the bankruptcy process, including communications with Debtors’ counsel.

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Central to the reorganization was a series of MOTA’s to be entered into. NPM reviewed and analyzed the MOTA agreements and consulted with the Ombudsman on the position to be taken by him, if any. NPM participated with the Ombudsman in an informational conference call with Debtors’ counsel and the officers of the proposed New Manager. Finally with respect to the MOTA’s, NPM analyzed the intersection of the MOTA’s with the Appointment Order and with section 333 of the Bankruptcy Code and discussed such issues with counsel for other parties. b. Fee/Employment Applications: NPM’s services in this category included the application and supporting declaration for retention of NPM, involving extensive conflict searches, analysis of the results of those searches and subsequent disclosures of multiple connections or contacts with creditors and others. c. Financing and Cash Collateral: NPM engaged in extensive review, consultation, analysis, coordination, negotiation, preparation and attendance at a hearing regarding issues and concerns in the debtor-in-possession financing and cash collateral order that was eventually entered by this Court on or about December 2, 2021. d. Ombudsman Report: NPM spent minimal time during this time period on issues relating to the Ombudsman’s reports. In particular, NPM addressed issues relating to the due date of the Ombudsman’s first report, since the due date, 60 days after appointment on October 25, 2021, was December 24, which was a Court holiday. 14. NPM does not seek any reimbursement of expenses in this Application. 15. NPM seeks allowance of the sum of $42,070.00 of fees and immediate payment of 80 percent of that amount, which is $33,656.00. 16. The undersigned hereby attests that he has reviewed the requirements of Local Rule 2016 and this Application substantially conforms to such requirements.

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WHEREFORE, NPM hereby requests: (a) allowance of compensation for necessary and valuable professional services rendered to the Ombudsman in the sum of $42,070.00 for the period from October 25, 2021 through November 30, 2021; (b) payment in the total amount of $33,656.00, which represents 80% of the total fees billed ,as provided under the Interim Compensation Order; and (c) granting such other relief as this Court deems just and proper. /s/ Mark I. Fishman Mark I. Fishman (admitted pro hac vice) NEUBERT PEPE & MONTEITH, P. C. 195 Church Street New Haven, CT 06510 Telephone: (203) 781-2898 Email: mfishman@npmlaw.com Counsel to the Patient Care Ombudsman

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) GULF COAST HEALTH CARE, LLC, et al.,1 ) Case No. 21-11336 (KBO) ) Debtors. ) (Jointly Administered) ) CERTIFICATION OF MARK I. FISHMAN I, Mark I. Fishman, under penalty of perjury, declare as follows: 1. I am a senior counsel in the law firm of Neubert Pepe & Monteith, P. C. (“NPM”), Counsel to the Patient Care Ombudsman appointed in these cases (the “Ombudsman”). 2. I have read the foregoing First Monthly Fee Application filed by NPM for the Period from October 25, 2021 through November 30, 2021 and know the contents thereof. The same contents are true to the best of my knowledge, except as to matters therein alleged to be upon information and belief, and as to those matters, I believe them to be true. I have personally performed many of the legal services rendered by NPM and am thoroughly familiar with all other work performed by the attorneys and paraprofessionals in NPM. 3. In accordance with Rule 2016(a) of the Federal Rules of Bankruptcy Procedure and Section 504 of Title 11, United States Code, no agreement or understanding exists between NPM and any other person for the sharing of compensation to be received in connection with the above-captioned cases. 1 The last four digits of Gulf Coast Health Care, LLC’s federal tax identification number are 9281. There are 62 Debtors in these chapter 11 cases, for which the Debtors have requested joint administration. A complete list of the Debtors and the last four digits of their federal tax identification numbers are not provided herein. A complete list of such information may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://dm.epiq11.com/GulfCoastHealthCare. The location of Gulf Coast Health Care, LLC’s corporate headquarters and the Debtors’ service address is 40 South Palafox Place, Suite 400, Pensacola, FL 32502.

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4. I have reviewed the requirements of Local Rule 2016 of the United States Bankruptcy Court for the District of Delaware, and to the best of my knowledge, information and belief, this Application complies substantially with Local Rule 2016. 6. NPM did not agree to any variations from, or alternatives to, its standard and customary billing arrangements for the proposed engagement by the Ombudsman pursuant to the Application. 7. None of the professionals at NPM included in the proposed engagement by the Ombudsman pursuant to the Application vary their rates based on geographic location of the bankruptcy case except that, as a Connecticut-based attorney, Mark I. Fishman’s hourly rate for non-Connecticut matters is $425.00 instead of $400.00. There is no variance related to the Delaware venue in particular. That rate has been allowed by Bankruptcy Courts, including this Court, and is charged to non-bankruptcy clients as well. 8. Other than a possible rate increase each calendar year, during the twelve months prior to the filing of the Debtors’ chapter 11 petitions, the billing rates of NPM in this matter were not different than those sought under the Application. The rate for Mr. Fishman effective as of January 1, 2021 is the rate charged in the Application. The other persons whose time is billed were, respectively, not employed by NPM on January 1, 2021 or not employed in the same position. 9. The Application does not include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 4, 2022 /s/ Mark I. Fishman Mark I. Fishman (admitted pro hac vice)

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EXHIBIT A

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