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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Hearing Date: May 7, 2018 at 2:00 p.m. ) Objection Deadline: April 30, 2018 at 4:00 p.m.
COVER SHEET
APPLICATION FOR REIMBURSEMENT OF FEES ANDEXPENSES INCURRED BY THE PETITIONING CREDITORS
FOR THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018
Name of Applicants: CGM Partners, LLC, Howard Elias, and the Kelly Yang Living Trust (collectively, the “Petitioning Creditors”)
Date of Retention: March 19, 2018
Period for which compensation and reimbursement is sought: March 19, 2018 through March 27, 2018
Amount of compensation sought as actual, reasonable and necessary: $5,164.50
Amount of expense reimbursement sought as actual, reasonable and necessary: $1,722.80
Total amount of compensation and reimbursement sought: $6,887.30
This is a(n): interim ____ quarterly __ x__ final application
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 1 of 11
2
ATTACHMENT TO FEE APPLICATION
NAME OF PROFESSIONAL
POSITIONHELD
HOURLY BILLING RATE
TOTAL HOURSBILLED
TOTAL COMPENSATION
Kevin S. Mann Partner $475.00 10.6 $5,035.00 Stephanie MacDonald Legal Assistant $185.00 0.7 $129.5
TOTAL: 11.3 $5,164.50
Blended Hourly Rate: $457.04
EXPENSE SUMMARY
EXPENSE AMOUNT Photocopies $5.80 Filing fees $1,717.00 TOTAL $1,722.80
COMPENSATION BY PROJECT CATEGORY
CODE CATEGORY HOURS AMOUNT
AP Adversary Proceedings / Litigation 2.1 $968.50
CH Court Hearings 9.2 $4,196.00
TOTAL 11.3 $5,164.50
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 2 of 11
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Hearing Date: May 7, 2018 at 2:00 p.m. ) Objection Deadline: April 30, 2018 at 4:00 p.m.
APPLICATION FOR REIMBURSEMENT OF FEES ANDEXPENSES INCURRED BY THE PETITIONING CREDITORS FOR
THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018
Pursuant to 11 U.S.C. §§ 503(b)(3)(A) and 503(b)(4) of the United States Code (the
“Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure, and Bankruptcy
Local Rule 2016-2, CGM Partners, LLC, Howard Elias, and the Kelly Yang Living Trust
(collectively, the “Petitioning Creditors”), hereby apply for an order allowing and directing the
Trustee to pay to Cross & Simon, LLC, counsel for the Petitioning Creditors, (i) compensation in
the total amount of $5,164.50 for the reasonable and necessary legal services Cross & Simon,
LLC rendered to the Petitioning Creditors from March 19, 2018 through March 27, 2018 (the
“Application”) and (ii) reimbursement for the actual and necessary costs and expenses of
Petitioning Creditors in the amount of $1,722.80 for a total payment of $31,132.76. In support
of this Application, the Petitioning Creditors respectfully state as follows:
Jurisdiction & Venue
1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 157. This is a
core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper before this Court
pursuant to 28 U.S.C. §§ 1408 and 1409. The statutory predicate for relief is 11 U.S.C. § 503
and Bankruptcy Local Rule 2016-2.
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 3 of 11
Background
2. On March 23, 2018, Petitioning Creditors filed an involuntary petition (the
“Involuntary Petition”) for relief against Candi Controls, Inc. (“Debtor”) under section 301 of the
Bankruptcy Code.
3. On March 23, 2018, counsel to the Debtor contacted counsel to the Petitioning
Creditors to indicate that the Debtor would consent to the entry of an order for relief. The United
States Trustee objected to the Debtor consenting to the entry of an order for relief indicating the
United States Trustee’s belief that the Debtor did not have the requisite corporate authority to
consent to the entry of an order for relief.
4. On March 27, 2018, the Court held a hearing on the Debtor’s ability to consent to
the entry of an order for relief. After argument from counsel to the Debtor, counsel to the United
States Trustee, counsel to the Petitioning Creditors, and counsel to the Debtor’s post-petition
lender, the Court determined that the Debtor did have the requisite corporate authority to consent
to the entry of an order for relief and entered the Order for Relief in Involuntary Case [Docket
No. 13] (the “Order”).
5. Petitioning Creditors have incurred attorney fees and costs in connection with the
preparation and filing of the Involuntary Petition, investigating and researching the Petitioning
Creditors’ claims and the Debtor’s corporate authority to consent to the entry of an order for
relief, preparing for a contested hearing on the Involuntary Petition, and litigating the
Involuntary Petition in Court. These fees and costs total $6,887.30. A full and detailed
description of the time and expenses is attached as Exhibit “A”.
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 4 of 11
Relief Requested
6. Petitioning Creditors respectfully request entry of an order allowing the
reimbursement of fees and expenses incurred by the Petitioning Creditors in the amount of
$5,164.50 and $1,722.80 respectively, and directing the Debtor to immediately pay such
expenses.
Basis for Relief
7. Section 503(b) of the Bankruptcy Code provides:
After notice and a hearing, there shall be allowed administrative expenses, other than claims allowed under section 502(f) of this title, including -- (3) the actual, necessary expenses, other than compensation and reimbursement specified in paragraph (4) of this subsection, incurred by – (A) a creditor that files a petition under section 303 of this title.
11 U.S.C. §503(b)(3)(A). Section 503(b)(4) further provides for:
Reasonable compensation for professional services rendered by an attorney or an accountant of an entity whose expense is allowable under subparagraph (A)… of paragraph 3 of this subsection, based on the time, the nature, the extent, and the value of such services, and he cost of comparable services other than in a case under this title, and reimbursement for actual, necessary expenses incurred by such attorney or accountant.
11 U.S.C. §503(b)(4).
8. The expenses and attorney fees incurred in research and investigation prior to the
preparation of the involuntary petition should be an allowed administrative expense. See Matter
of Baldwin-United Corp., 79 B.R. 321 (Bankr.S.D. Ohio 1987) (holding that fees arising from
reasonable research and investigation prior to the preparation and filing of the involuntary
petition were allowable administrative expense). Courts have also held that expenses related to
the adjudication of an involuntary petition are compensable as administrative expenses under
section 503(b)(3). In re Crazy Eddie, Inc., 120 B.R. 273, 278 (Bankr.S.D.N.Y. 1990); see also,
In re Key Auto Liquidation Center, Inc., 384 B.R. 599, 605-606 (Bankr.N.D. Fla. 2008)
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 5 of 11
(“Attorney’s fees may be recovered under §§503(b)(3)(A) and 503(b)(4) for preparing and filing
the involuntary petition, contacting other creditors to join the petition, legal and factual research
regarding the grounds for filing the case, and litigating whether an order for relief should be
entered.”) In Crazy Eddie, the Court considered petitioning creditors’ request for compensation
and expenses relating to the preparation, filing and adjudication of an involuntary petition. Id. at
278 (citing In re Hanson Industries, Inc., 90 B.R. 405, 410 (Bankr.D. Minn. 1988)) The Court
further stated:
This reading of the Code recognizes that an involuntary proceeding can become an expensive and aggressively contested matter. See [S. Bernstein & L. King, Collier Bankruptcy Compensation Guide], ¶ 7.04[1] at 7-14. A more limited interpretation of the Code is indeed ‘out of step with the realities’ of today’s bankruptcy practice; it would be disingenuous to compensate for the filing of the petition but not its successful adjudication, particularly since the petitioning creditors are liable under §303(i) if the case is abandoned or dismissed.
Id. (emphasis added).
9. In Key Auto, the Court held that the purpose of §503 is “to reimburse petitioning
creditors for the costs associated with successfully filing and prosecuting an involuntary petition
– a valuable service that brings the debtor into court so that its assets can be equitably marshaled
before they are squandered.” In re Key Auto Liquidation Center, Inc., 384 B.R. at 604 (citing In
re J.V. Knitting Service, Inc., 22 B.R. 543, 545 (Bankr.S.D. Fla. 1982); In re Adam Furniture
Industries, Inc., 1993 WL 13004589, *3 (Bankr.S.D. Ga. 1993); Hanson Industries, 90 B.R. at
410.) In Key Auto, the Court found that the petitioning creditor’s attorney played a large, if not
predominant role in prosecuting the involuntary petition:
[H]e responded to the motion to dismiss, filed memoranda and supplements to the pleadings, appeared in court to prosecute the involuntary petition, and responded to discovery requests, all of which were necessary only because the Debtor and Objecting Creditors adamantly opposed the entry of an order for relief. The nature of expenses Ciano incurred are of the type that §§503(b)(3)(A) and 503(b)(4) were intended to compensate and Ciano has performed a valuable
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 6 of 11
service for the creditors and the estate by bringing the Debtor into court so that its assets would not be dissipated.
Id. at 605.1
10. The legal expenses incurred by the Petitioning Creditors fit squarely into the
category of administrative expense claims described by section 503(b)(4). The Petitioning
Creditors incurred these fees in preparing and filing of the Involuntary Petition, investigating and
researching the Petitioning Creditors’ claims and the Debtor’s corporate authority to consent to
the entry of an order for relief, preparing for a contested hearing on the Involuntary Petition, and
litigating the Involuntary Petition in Court. The details of legal work done on this case are
shown in specific time entries attached to this Application. To the extent counsel for Petitioning
Creditors had discussions with the Petitioning Creditors, the description of these conversations is
limited so as to preserve and protect the attorney-client privilege. Generally, counsel and the
Petitioning Creditors discussed facts giving rise to the Debtor’s insolvency and actions leading
up to the Involuntary Petition, the Petitioning Creditors’ claims, the Debtor’s corporate structure
and internal governing documents, and efforts to preserve and protect assets of the estate. The
Petitioning Creditors believe these and other charges are reimbursable as they are directly related
to preparing and filing the Involuntary Petition, monitoring and protecting assets of the Debtor’s
estate, legal and factual research regarding the grounds for filing the case, and litigating whether
an order for relief should have been entered.
11. In Crazy Eddie, the debtor initially filed a motion to dismiss and for sanctions
against the petitioning creditors. Like here, the debtor in Crazy Eddie did not allege that the
petitioning creditors failed to meet the statutory requirements of §303 for filing the petition, and
1 In Key Auto, the Court awarded $2,578.08 under §503(b)(3)(A) and $43,840.00 under §503(b)(4).
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 7 of 11
instead sought dismissal on the discretionary provisions of §305, in the “interests of creditors.”
Similar to the case at bar, the debtor eventually stipulated to the withdrawal of the motion to
dismiss and for sanctions, precluding any review of the merits of the involuntary filing. In re
Crazy Eddie, 120 B.R. at 277.2
12. As evidenced by the Debtor’s statements, and the record, the Involuntary Petition
and the Debtor’s entry into Chapter 11 will benefit general unsecured creditors; in fact, without
the Involuntary Petition, most general unsecured creditors, would have no chance of recovering
anything from the Debtor. Accordingly, pursuant to 11 U.S.C. § 503(b)(4), Petitioning Creditors
are entitled to an administrative expense claim for their reasonable attorney fees and costs
incurred in connection with prosecuting the Involuntary Petition.
13. Further, Petitioning Creditors should be entitled to immediate payment of their
actual and necessary expenses. “Courts have discretion to determine when an administrative
expense will be paid.” In re Garden Ridge Corp., 323 B.R. 136, 143 (Bankr. D. Del. 2005)
(Citing HQ Global Holdings, Inc., 282 B.R. 169, 173 (Bankr. D. Del. 2002)). “In determining
the time of payment, courts consider prejudice to the debtor, hardship to the claimant, and
potential detriment to other creditors.” Id. at 143.
14. Petitioning Creditors will be substantially prejudiced if their actual and necessary
expenses are not immediately paid. Petitioning Creditors were subject to attack for filing the
Involuntary Petition, and incurred additional attorney fees, costs and expenses for prosecuting
the Involuntary Petition, which fees, costs and expenses are due and owing. Without immediate
payment on account of their claims, Petitioning Creditors have been and will be forced to front
2 In Crazy Eddie (1990), the Court awarded $27,636.38 in legal fees and $2,077.26 in expenses.
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 8 of 11
expenses that resulted in the entry of the order of relief, without which, as discussed herein, no
creditor would have any chance of recovering from the Debtor’s estate.
15. The Debtor will suffer no prejudice if it must immediately pay the Petitioning
Creditors’ claims from available cash. The Debtor has obtained post-petition financing. Further,
while significant for Petitioning Creditors, the amount of the claim is small in relation to the
potential size of the Debtor’s estate. Additionally, the Debtor’s estate will likely incur and pay
certain administrative expense claims before other claims in this case, or before final
distribution. For instance, the Debtor’s professionals, will be eligible for compensation and
payment. If the Court authorizes the immediate payment of fees and expenses incurred by the
Debtor in administering this case, the Petitioning Creditors’ claim should be treated likewise, and
be timely paid too, as the work of both are benefitting all other creditors. Accordingly, since the
estate has cash, the Debtor will not be prejudiced by immediately paying certain administrative
expense claims, including reimbursing the Petitioning Creditors for their expenses and fees.
16. On information and belief, immediate payment of Petitioning Creditors’ claim
would not prejudice other claimants. Other administrative claimants are eligible for payments
upon Court approval. Immediate payment of Petitioning Creditors’ claims would merely put
Petitioning Creditors in the same position as these other administrative expense claimants,
including, for instance, the Debtor’s professionals, whose work will benefit other claimants.
Fee Statements
17. Cross & Simon, LLC devoted 11.3 hours of professional time to provide legal
services to the Petitioning Creditors for the period of March 19, 2018 through March 27, 2018.
The time record entries detailing that time, and the members of the firm providing it, are attached
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 9 of 11
hereto and marked as Exhibit A, and consist of a daily breakdown of the total time spent by each
person on each day, and of the disbursements during the applicable period.
18. During the applicable period, Cross & Simon, LLC performed legal services for
the Petitioning Creditors in the project categories described in Exhibit B. The following is a
summary of the work performed by Cross & Simon, LLC in each substantive area:
Adversary Proceedings / Litigation: Cross & Simon, LLC worked with the Petitioning Creditors in connection with the preparation, filing and prosecution of the Involuntary Petition.
Court Hearings: Cross & Simon, LLC prepared for, and attended a hearing in this case on behalf of the Petitioning Creditors wherein an order of relief was entered.
Actual and Necessary Expenses
19. A summary of the actual and necessary expenses incurred by Petitioning
Creditors for the applicable period is attached hereto as Exhibit A. When seeking reimbursement
from a bankruptcy estate, Cross & Simon, LLC charges 10¢ per page for duplication done in the
office. These charges are compliant with the Local Rules of this Bankruptcy Court. The other
costs incurred are actual costs billed to Cross & Simon, LLC and passed through to the
Petitioning Creditors.
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 10 of 11
WHEREFORE, Petitioning Creditors respectfully request that this Court enter an order in
substantial conformity with the proposed form of order attached hereto and grant such other and
further relief as this Court deems just and equitable.
Dated: April 12, 2018 CROSS & SIMON, LLC
By: /s/ Kevin S. Mann Kevin S. Mann (No. 4576)
1105 N. Market Street, Suite 901 Wilmington, DE 19801 (302) 777-4200
kmann@crosslaw.com
Counsel to the Petitioning Creditors
Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 11 of 11
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Hearing Date: May 7, 2018 at 2:00 p.m. ) Objection Deadline: April 30, 2018 at 4:00 p.m.
NOTICE OF APPLICATION
PLEASE TAKE NOTICE, that CGM Partners, LLC, Howard Elias, and the Kelly Yang
Living Trust (collectively, the “Petitioning Creditors”) filed the Application for Reimbursement
of Fees and Expenses Incurred by the Petitioning Creditors for the Period of March 19, 2018
through March 27, 2018 (the “Application”), with the United States Bankruptcy Court for the
District of Delaware (the “Bankruptcy Court”).
Objections to the Application, if any, must be filed on or before April 30, 2018 at 4:00
p.m. (the “Objection Deadline”) with the United States Bankruptcy Court for the District of
Delaware, 824 Market Street, 5th Floor, Wilmington, Delaware 19801. At the same time, you
must also serve a copy of the response upon the undersigned counsel to the Petitioning Creditors
so that the response is received on or before the Objection Deadline.
PLEASE TAKE FURTHER NOTICE that if an objection is properly filed in accordance
with the above procedure, a hearing on the Application will be held before the Honorable
Christopher S. Sontchi on May 7, 2018 at 2:00 p.m. Only those objections made in response to
the Application will be heard.
Case 18-10679-CSS Doc 71-1 Filed 04/12/18 Page 1 of 2
2
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT
MAY GRANT THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING.
Dated: April 12, 2018 CROSS & SIMON, LLC
By: /s/ Kevin S. Mann Kevin S. Mann (No. 4576)
1105 N. Market Street, Suite 901 Wilmington, DE 19801 (302) 777-4200
kmann@crosslaw.com
Counsel to the Petitioning Creditors
Case 18-10679-CSS Doc 71-1 Filed 04/12/18 Page 2 of 2
For Services Rendered
Date 4/11/2018
Invoice # 0207025-627Client
Mr. Paul M. LaveryCGM Partners LLCP.O. Box 4631El Dorado Hills, CA 95672
TotalRC - Richard H. Cross, Jr., Esq.CS - Christopher P. Simon, Esq.JG - Joseph Grey, Esq.KM - Kevin Mann, Esq.DH - David Holmes, Esq.NM - Nancy McClendon (Legal Assistant)ND - Nicole DiBiaso (Legal Assistant)SM - Stephanie MacDonald (Legal Assistant)KA - Kathy Abbott (Legal Assistant)
1105 North Market Street, Suite 901P.O. Box 1380
Wilmington, DE 19899-1380(302) 777-4200
DateItem Description Hours Rate Amount
3/19/2018KM - B AP - Review loan documents, corporategovernance documents and corporate disclosures
2 475.00 950.00
3/19/2018KM - B AP - Research re: issues related to involuntarypetition filing; multiple correspondence withclient re: same
1.5 475.00 712.50
3/21/2018KM - B AP - Multiple correspondence with P. Lavery re:strategy
0.2 475.00 95.00
3/21/2018KM - B AP - Teleconference with client re: strategy 0.4 475.00 190.003/22/2018KM - B AP - Multiple correspondence re: strategy 0.2 475.00 95.003/22/2018KM - B AP - Review H. Elias loan documents 0.7 475.00 332.503/22/2018KM - B AP - Multiple correspondence re: strategy 0.2 475.00 95.003/23/2018KM - B AP - Teleconference with S. Leonhardt re: case
status0.3 475.00 142.50
3/23/2018KM - B AP - Correspondence to clients re: corporategovernance
0.2 475.00 95.00
3/23/2018KM - B AP - Teleconference with D. Buchbinder re: casestatus
0.2 475.00 95.00
3/23/2018KM - B AP - Finalize petition and related pleadings;correspondence to client re: same
0.5 475.00 237.50
3/23/2018KM - B AP - Prepare summons and proposed order forrelief
0.3 475.00 142.50
3/23/2018KM - B AP - Multiple correspondence with P. Lavery re:strategy
0.3 475.00 142.50
3/23/2018KM - B AP - Prepare petition and corporate statement;correspondence to client re: same
0.7 475.00 332.50
3/23/2018SM AP - Prepare and e-file Involuntary Chapter 11Petition
0.6 185.00 111.00
3/26/2018KM - B AP - Review certification of counsel re: consent;correspondence to clients re: same
0.4 475.00 190.00
3/26/2018KM - B CH - Review notice of status conference;correspondence to client re: same
0.2 475.00 95.00
3/26/2018KM - B AP - Review Altair notice of appearance 0.1 475.00 47.503/26/2018KM - B CH - Prepare for status conference 0.2 475.00 95.003/26/2018SM CH - Update calendar with hearing dates 0.1 185.00 18.503/27/2018KM - B CH - Review exhibit list for status conference 0.1 475.00 47.503/27/2018KM - B CH - Attend status conference with Judge Sontchi 1.5 475.00 712.503/27/2018KM - B AP - Correspondence to clients re: case status 0.4 475.00 190.003/26/2018Photocopy expense on 03/26/2018 (58 copies @
$0.10 = $5.80)5.80 5.80
3/26/2018Filing fee on 3/23/18 1,717.00 1,717.00
$6,887.30
Case 18-10679-CSS Doc 71-2 Filed 04/12/18 Page 2 of 2
BANKRUPTCY DEBTOR/ESTATE/COMMITTEE PROJECT CATEGORIES
AA Asset Analysis and Recovery
AP Adversary Proceedings / Litigation
BO Business Operations
CA Case Administration
CH Court Hearings
CI Creditor Inquiries
CR Cash Collateral/DIP Financing
DS Disclosure Statement
EA1 Employment Application of Cross & Simon, LLC
EA2 Employment Application of Other Professionals
EB Employee Matters
EC Executory / Lease Contract Issues
FA1 Fee Application of Cross & Simon, LLC
FA2 Fee Application of Other Professionals
MA General Corporate Matters
MC Meetings of Creditors
MR Stay Relief Matters
PC Claims, Analysis, Objections & Resolutions
PL Plan
SA Use, Sale or Lease of Property
TR Trustee Reporting/Schedules
TV Non Working Travel
UM Utility Matters
Case 18-10679-CSS Doc 71-3 Filed 04/12/18 Page 2 of 2
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Re: Docket No. ____ )
ORDER APPROVING APPLICATION FOR REIMBURSEMENT OF FEES AND EXPENSES INCURRED BY THE PETITIONING CREDITORS
FOR THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018
UPON CONSIDERATION of the Application for Reimbursement of Fees and Expenses
Incurred by the Petitioning Creditors for the Period of March 19, 2018 through March 27, 2018
(the “Application”),
IT IS HEREBY ORDERED THAT
1. The Application is GRANTED, as modified by this Order.
2. The Petitioning Creditors are allowed an administrative expense claim in the
amount of $27,634.00 for legal fees and $1,722.80 for expenses incurred by the Petitioning
Creditors, pursuant to section 503(b)(4) of the Bankruptcy Code.
3. The Debtor shall pay to the Petitioning Creditors the amounts set forth in
paragraph 2 herein within ten (10) days of the date of this Order.
4. This Order shall be effective immediately upon entry.
Dated: _______________________
________________________________ The Honorable Christopher S. Sontchi United States Bankruptcy Judge
Case 18-10679-CSS Doc 71-5 Filed 04/12/18 Page 1 of 1
CERTIFICATE OF SERVICE
I, Kevin S. Mann, hereby certify that on this 12th day of April, 2018, I caused copies of
the Application for Reimbursement of Fees and Expenses Incurred by the Petitioning Creditors
for the Period of March 19, 2018 through March 27, 2018 to be served on the following parties
by first class mail:
Yardi Systems, Inc. 430 South Fairview Ave Santa Barbara, CA 93111
John and Denise Woods 316 Indian Trail Dr Franklin Lanes, NJ 07417
Patrick O'Leary 1549 Whitetail Ln Cedarburg, WI 53012
William Schur 14 Bono St #175 Great Neck, NY 10021
Paul Stamatis, Jr. 10406 Charter Lake Cir Katy, TX 77494
Helmut Albrecht 3350 SW 27th Ave Apt. 2203 Miami, FL 33133
Robert Mansell 683 Terrace Ave Half Moon Bay, CA 94019
Lone Star Ventures, LLC dba Corporate Finance Associates 774 Mays Blvd Ste 10-630 Incline Village, NV 89451
ACM Gierman-Van Gils Veldweg 16 8051 NR Hattem Netherlands
Jack Brazil, Jr. 2701 Pebble Stone Grapevine, TX 76051
Jorge Gerardo Perez Garza Circuito Chapulines 6 Las Villas, Torreon Coahuila 27420 Mexico
Alvaro Ramirez Carrera 4 #70A-82 Apt. 716 Bogota 110231 Colombia
Paul J. Feldman 51 Warwick Stone Way Great Falls, VA 22066
Joel and Joanne Shefflin 995 Lilac Dr Montecito, CA 93108
Kishore Ganji 100 Timber Ln Malboro, NJ 07746
Case 18-10679-CSS Doc 71-6 Filed 04/12/18 Page 1 of 2
Pulling Out of Here to Win, LLC 12906 SW 133 Ct #A Miami, FL 33186
Chris Leebelt 11630 Coeur D'Alene Dr Parker, CO 80138
Frederick B. Rosner, Esq.Scott J. Leonhardt, Esq.Jason A. Gibson, Esq.The Rosner Law Group LLC 824 N Market Street, Suite 810 Wilmington DE 19801
Jordan A. Kroop, Esq. Perkins Coie LLP 2901 N Central Ave, Suite 2000 Phoenix AZ 85012
David L. Buchbinder, Esq.Jaclyn Weissgerber, Esq. Office of the U.S. TrusteeJ. Caleb Boggs Federal BuildingSuite 2207Wilmington, DE 19801
Bruce D. Buechler, Esq.Lowenstein Sandler LLP One Lowenstein DriveRoseland, New Jersey 07068
Christopher M. Samis, Esq. L. Katherine Good, Esq. Aaron H. Stulman, Esq. Whiteford, Taylor & Preston LLC The Renaissance Centre405 North King Street, Suite 500 Wilmington, Delaware 19801
/s/ Kevin S. Mann Kevin S. Mann (No. 4576)
Case 18-10679-CSS Doc 71-6 Filed 04/12/18 Page 2 of 2
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