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Full title: Monthly Fee Statement. For the Month of December 2021. Objection Date is January 13, 2022. Filed by Brett Kahn on behalf of McCarter & English, LLP. (Attachments: # (1) Exhibit Ex. A - Retention Order # (2) Exhibit Ex. B - Invoices) (Kahn, Brett)

Document posted on Dec 29, 2021 in the bankruptcy, 7 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

No. 1 or  Final Fee Application Summary of Amounts Requested for the Period from October 14, 2021 through November 30, 2021 (the “First Statement Period”).Total Received by Applicant: 0 0 SECTION II SUMMARY OF SERVICES SECTION III SUMMARY OF DISBURSEMENTS DISBURSEMENTS AMOUNT Summary explaining the nature of the work performed and the results achieved:2During the First Statement Period, McCarter & English professionals and paraprofessionals performed the following work on behalf of the Debtor: Assisted with preparation for hearings and preparation of motions and other documents, as related to insurance coverage issues, in connection with commencement of this chapter 11 bankruptcy case;  Assisted with responses to discovery demands relating to insurance coverage issues in bankruptcy case;  Reviewed, analyzed and prepared documents relating to insurance coverage issues for production in bankruptcy case and communicating with other Debtor counsel regarding same;  Analyzed insurance policies and related case materials with respect to insurance coverage issues arising in bankruptcy;  Analyzed bankruptcy case materials with respect to issues impacting New Jersey coverage litigation;  Analyzed insurer document productions with respect to issues impacting insurance recovery; Drafted, revised and prepared for filing retention application and communicating with U.S. Trustee regarding issues relating to same;  Communicated with other Debtor counsel as appropriate regarding various insurance coverage issues and related strategy; and  Conducted legal research on discrete insurance coverage issues arising in bankruptcy and issues impacting New Jersey coverage litigation.

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Document Contents

UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY FEE APPLICATION COVER SHEET FOR THE PERIOD OCTOBER 14, 2021 THROUGH NOVEMBER 30, 2021 Debtor: LTL Management LLC Applicant: McCarter & English, LLP Case No.: 21-30589-MBK Client: LTL Management LLC Chapter: 11 Case Filed: October 14, 2021 (the “Petition Date”) SECTION 1 FEE SUMMARY  Interim Fee Application No. 1 or  Final Fee Application Summary of Amounts Requested for the Period from October 14, 2021 through November 30, 2021 (the “First Statement Period”). Total Fees: $119,570.27 Total Disbursements: $19.81 Total Fees Plus Disbursements: $119,590.08 Minus 20% Holdback of Fees: $23,914.05 Amount Sought at this Time: $95,676.03 FEES EXPENSES Total Previous Fees Requested: 0 0 Total Fees Allowed to Date: 0 0 Total Retainer (If Applicable): 0 0 Total Holdback (If Applicable): 0 0 Total Received by Applicant: 0 0

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Table 1 on page 2. Back to List of Tables
Name of Professional
& Title
Year
Admitted
Hours Rate
(discounted
from standard)
Fees
Thomas W. Ladd, Esq.,
Partner
1986 60.8 $688 $41,830.40
Brett Kahn, Esq.,
Partner
2008 124.2 $446 $55,393.20
Jennifer Farina, Esq.,
Partner
2005 23.5 $446 $11,635.40
Geoffrey Lynott, Esq.,
Associate
2019 28.1 $366 $10,132.80
Andrew G. Heckler,
Esq., Associate
2019 46.4 $342 $15,868.80
Ashley D. McWilliams,
Esq., Associate
2019 48 $303 $14,544.00
Darren Smolarski, Esq.,
Associate
2019 43.5 $342 $14,877.00
Georgia Bender, Esq.,
Associate
2021 11.7 $320 $3,744.00
Deborah Brown,
Paralegal
39.1 $248 $9,696.80

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SECTION II SUMMARY OF SERVICES
Table 1 on page 3. Back to List of Tables
SERVICES RENDERED HOURS FEES
a) Asset Analysis and Recovery: Identification and
review of potential assets including causes of action
and non-litigation recoveries.
b) Asset Disposition: Sales, leases, abandonment and
related transaction work.
c) Avoidance Action Litigation: Preference and
fraudulent transfer litigation.
d) Business Operations: Issues related to debtor-in-
possession operating in chapter 11 such as employee,
vendor, tenant issues and other similar problems.
e) Case Administration: Coordination and compliance
activities, including preparation of statement of
financial affairs, schedules, list of contracts, United
States Trustee interim statements and operating
reports; contacts with the United States Trustee;
general creditor inquires.
f) Claims Administration and Objections: Specific claim
inquiries; bar date motions; analyses, objections and
allowance of claims.
g) Employee Benefits/Pensions: Review issues such as
severance, retention, 401K coverage and continuance
of pension plan.
h) Fee/Employment Applications: Preparations of
employment and fee applications for self or others;
motions to Establish interim procedures.
46.4 20,834.40
i) Fee/Employment Objections: Review of an objections
to the employment and fee applications of others.
j) Financing: Matters under 361, 363 and 364 including
cash collateral and secured clams; loan document
analysis.
k) Litigation: Other than Avoidance Action Litigation
(there should be a separate category established for
each major matter).

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Table 1 on page 4. Back to List of Tables
SERVICES RENDERED HOURS FEES
l) Meetings of Creditors: Preparing for and attending the
conference of creditors, the 341(a) meeting and other
creditors’ committee meetings.
m) Plan and Disclosure Statement: Formulation,
presentation and confirmation; compliance with the
plan confirmation order, related orders and rules;
disbursement and case closing activities, except those
related to allowance and objections to allowance of
claims.
n) Relief from Stay Proceedings: Matters relating to
termination or continuation of automatic stay under
362.
o) Accounting/Auditing: Activities related to
maintaining and auditing books of account,
preparation of financial statements and account
analysis.
p) Business Analysis: Preparation and review of
company business plan; development and review of
strategies; preparation and review of cash flow
forecasts and feasibility studies.
q) Corporate Finance: Review financial aspects of
potential mergers, acquisitions and disposition of
company or subsidiaries.
r) Data Analysis: Management information systems
review, installation and analysis, construction,
maintenance and reporting of significant case financial
data, lease rejection, claims, etc.
s) Litigation Consulting: Providing consulting and expert
witness services related to various bankruptcy matters
such as insolvency, feasibility, avoiding actions;
forensic accounting, etc.
378.9 $98,735.87
t) Reconstruction Accounting: Reconstructing books and
records from past transactions and brining accounting
current.
u) Tax Issues: Analysis of tax issues and preparation of
state and federal tax returns.

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Table 1 on page 5. Back to List of Tables
SERVICES RENDERED HOURS FEES
v) Valuation: Appraise or review appraisals of assets.
w) Travel Time: Please note that non-working travel time
must be billed at 50% of cost.
SERVICE TOTALS 425.3 119,570.27

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SECTION III SUMMARY OF DISBURSEMENTS DISBURSEMENTS AMOUNT Federal Express $19.81 DISBURSEMENTS TOTALS $19.81

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SECTION IV CASE HISTORY 1. Date of Retention: December 16, 2021, effective as of the Petition Date [Dkt. 861] (the “Retention Order”).1 2. Summary explaining the nature of the work performed and the results achieved:2During the First Statement Period, McCarter & English professionals and paraprofessionals performed the following work on behalf of the Debtor:  Assisted with preparation for hearings and preparation of motions and other documents, as related to insurance coverage issues, in connection with commencement of this chapter 11 bankruptcy case;  Assisted with responses to discovery demands relating to insurance coverage issues in bankruptcy case;  Reviewed, analyzed and prepared documents relating to insurance coverage issues for production in bankruptcy case and communicating with other Debtor counsel regarding same;  Analyzed insurance policies and related case materials with respect to insurance coverage issues arising in bankruptcy;  Analyzed bankruptcy case materials with respect to issues impacting New Jersey coverage litigation;  Analyzed insurer document productions with respect to issues impacting insurance recovery;  Drafted, revised and prepared for filing retention application and communicating with U.S. Trustee regarding issues relating to same;  Communicated with other Debtor counsel as appropriate regarding various insurance coverage issues and related strategy; and  Conducted legal research on discrete insurance coverage issues arising in bankruptcy and issues impacting New Jersey coverage litigation. I certify under penalty of perjury that the above is true. Date: December 30, 2021 /s/ Thomas W. Ladd Thomas W. Ladd 1 The Retention Order is attached hereto as Exhibit A. 2 The summary set forth below is qualified in its entirety by reference to the time and services detail in the invoices attached hereto as Exhibit B.

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