document page 1 of 9 united states …litigation management group, ltd. and the anchor packing...
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UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA
Charlotte Division
IN RE: GARLOCK SEALING TECHNOLOGIES LLC, et al., Debtors1
Case No. 10-31607 Chapter 11 Jointly Administered
Sixteenth Interim Application of Schachter Harris, LLP For Allowance of Compensation and Reimbursement of
Expenses for Professional Services Rendered As Special Asbestos Defense Counsel for Debtors
For the Period from February 1, 2017 through May 31, 2017
Name of applicant: Schachter Harris, LLP Authorized to provide professional services to: Debtors Role in Case: Special Asbestos Defense Counsel Date of Retention: Order entered July 21, 2010, effective as of June 5, 2010 Period for which compensation and reimbursement is sought: February 1, 2017 through May 31, 2017 Amount of Compensation sought as actual, reasonable and necessary: $18,931.00 Amount of Expense Reimbursement sought As actual, reasonable and necessary: $13,308.00 Total amount of compensation and expense reimbursement sought as actual, reasonable and necessary: $32,239.00 This is the Sixteenth interim fee application filed by Schachter Harris, LLP. 1 The Debtors in these jointly administered cases are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd. and The Anchor Packing Company.
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UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA
Charlotte Division
IN RE: GARLOCK SEALING TECHNOLOGIES LLC, et al., Debtors1
Case No. 10-31607 Chapter 11 Jointly Administered
Sixteenth Interim Application of Schachter Harris, LLP for
Allowance of Compensation and Reimbursement of Expenses for Professional Services Rendered as
Special Asbestos Defense Counsel for Debtors for the Period from February 1, 2017 through May 31, 2017
Schachter Harris, LLP, special asbestos defense counsel, submits this Sixteenth interim
application (“Application”) for allowance of compensation and reimbursement of expenses from
February 1, 2017 through May 31, 2017 (“Compensation Period”) under sections 330 and 331 of
title 11 of the United States Code, Rule 2016 of the Federal Rules of Bankruptcy Procedure, and
this Court’s Administrative Order under 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for
Interim Compensation and Reimbursement Expenses for Professionals (“Fee Procedure
Order”) entered July 15, 2010 (Docket No. 233).
Schachter Harris moves for an order awarding it reasonable compensation for the
Compensation Period for professional legal services rendered to the Debtors in the amount of
$18,931.00 and reimbursement for actual and necessary expenses in the amount of $13,308.00 for
a total of $32,239.00. In support of this Application, Schachter Harris would show:
1 The Debtors in these jointly administered cases are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd. and The Anchor Packing Company.
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Background
1. This court has jurisdiction over this Application under 28 U.S.C. §§157 and 1334.
This is a core proceeding within the meaning of 28 U.S.C. §157 (b)(2).
2. On June 5, 2010 (the “Petition Date”), the Debtors filed voluntary petitions for
relief under Chapter 11 of the Bankruptcy Code.
3. On June 9, 2010, an Order Authorizing Joint Administration of Related Chapter 11
Cases (Docket No. 58) was entered authorizing the joint administration of all three debtor cases.
4. On July 21, 2010, the Court entered an Order Approving Employment of
Schachter Harris, LLP as Special Asbestos Defense Counsel as of the Petition Date (Docket No.
264) in the Chapter 11 cases.
5. After June 5, 2010, Schachter Harris has rendered services and incurred
reasonable expenses on behalf of Debtors.
6. Under the Fee Procedure Order, professionals may request monthly
compensation and reimbursement. Those requests are to be served on certain identified
interested parties for review. If no objection is received within ten (10) days of such request, the
Debtors are authorized to pay 90% of the fees and 100% of the expenses requested.
7. On December 24, 2014, the Court appointed W. Clarkson McDow as the Fee
Examiner in these cases (Docket No. 4291). On June 1, 2015, the Court entered the Order
Granting Fee Examiner’s Motion for Proposed Professional Guidelines (Docket No. 4634) (“Fee
Guidelines”).
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Compensation Received During Compensation Period
8. All services for which Schachter Harris seeks compensation were performed for or
on behalf of the Debtors. During the Compensation Period, Schachter Harris has received
monthly payments for 90% of fees and 100% of expenses from the Debtors under the Fee
Procedure Order as follows:
Date of Request
Period Covered Total Fees Total Expenses
Payment Received
Mar 20, 2017 February 1-28, 2017 $117.00 $2,376.77 $2,482.07
Apr 20, 2017 March 1-31, 2017 1,011.00 2,376.77 3,286.67
May 19, 2017 April 1-30, 2017 16,840.00 6,177.69 None to date
Jun 20, 2017 May 1-31, 2017 1,080.00 2,376.77 None to date
Total February 1, 2017 through May 31, 2017
$19,048.00(2) $13,308.00
Schachter Harris’s monthly fee requests were served upon certain interested parties for review as
directed by the Fee Procedure Order. As of the date of this Application, no interested party has
objected to these monthly fee requests.
Summary of Services Rendered
9. Schachter Harris has represented and advised the Debtor in its role as asbestos
defense counsel since 2003. The Debtor retained Schachter Harris to continue to represent the
Debtors in matters concerning the Debtors’ defenses and liability for asbestos related claims as
they concern various aspects of the Debtors’ restructuring plan and other proceedings in the
2 Schachter Harris has reduced the total amount of fees requested in this application to $18,931.00. See Exhibit B and paragraph 15 below.
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Cases. Schachter Harris also continues to represent Debtors in matters related to the cases in
which Schachter Harris’s lawyers represented Garlock and Anchor before the petition date.
10. Exhibits A-1 through A-4 to this application describe the services performed and
expenses incurred by Schachter Harris each month during the interim period. The exhibits
include the services performed, the project category of the services, the name of the professional
or paraprofessional that rendered the services, the date on which the services were rendered, the
amount of time spent performing the services, and the fee incurred. Each exhibit also includes a
summary of the costs, fees, and expenses incurred during that month, a summary of the time
spent on the separate project categories, and a summary of the professionals and
paraprofessionals that rendered services to the Debtors, which includes each professional’s or
paraprofessional’s title, hourly rate, total number of hours billed and the fees billed.
11. Billing Judgment. Schachter Harris does not bill the Debtor for tasks that do not
increase the value the Debtor receives from the firm’s services; the firm does not track this
unbilled time. In addition, Schachter Harris has reduced its compensation request by $117, as
discussed in paragraph 15 below. To the extent that charges for services rendered or expenses
incurred related to the Compensation Period but were not processed prior to the preparation of,
or otherwise included in this Application, Schachter Harris reserves the right to request
additional compensation for such services and reimbursement of such expenses in future
applications.
12. Attached as Exhibit B is a cumulative compensation summary broken down by
project category for the Compensation Period. This interim period included work in two project
categories: Litigation and Fee Proceedings.
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13. The vast majority of services Schachter Harris rendered fell within the Litigation
project category. This work was billed to the Confirmation subcategory, which included the
firm’s work responding to a request from Garrison regarding information needed for
confirmation, researching information related to a pre-petition appellate case that was necessary
for confirmation, preparing and presenting Mr. Magee for deposition and related follow-up and
analysis, and advising Debtors during a settlement conference with an insurer.
14. The Fee Proceedings project category includes work responding to the Fee
Examiner’s inquiries regarding the Fourteenth Interim Application. The Fee Proceedings
project category also includes Schachter Harris’s work preparing the Fifteenth Interim Fee
Application, which required 1.6 hours of associate and paralegal time and $309 in fees, or less
than 4% of the $8,959 in fees requested in the Fifteenth Application.
15. Schachter Harris has reduced its compensation request by $117, so as not to bill
Debtors for additional time drafting the Fourteenth Interim Application, a task which was
similarly reduced in Schachter Harris’s Fifteenth Interim Application in order to apply the
suggested 3-5% metric set forth in In re Mesa Air Group, Inc. 449 B.R. 441, 445-446 (Bankr.
S.D.N.Y. 2011). Accordingly, Schachter Harris’s request for compensation in the Fee
Proceedings project category totals $762.00, as shown on Exhibit B.
16. Attached as Exhibit C is a cumulative expense summary for the Compensation
Period. Schachter Harris incurred actual, reasonable, and necessary expenses totaling
$13,308.00, of which $9,507.08 was incurred on behalf of Debtors for ongoing record retrieval
and storage costs previously approved by the Fee Examiner. The remaining expenses were
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necessary to allow Mr. Harris to present Mr. Magee at deposition, and to attend a settlement
conference on behalf of Debtors.
17. A summary of the professionals and paraprofessionals that have rendered services
to the Debtors, which includes each professional’s or paraprofessional’s title, years of
experience, hourly rate, total number of hours billed, and fees billed for the Compensation
Period, is attached as Exhibit D. Schachter Harris believes its billing rates for the Interim Period
should be deemed reasonable for purposes of this Court’s determination of the reasonableness of
the fees.
18. Although a few timekeepers billed smaller amounts of time during this
Compensation Period due to the reduction in litigation work following the settlement Debtors
reached in March 2016, all professionals and paraprofessionals who rendered services during this
Compensation Period performed substantial work for Debtors in previous interim periods. Thus,
Schachter Harris does not consider these timekeepers to be “transitory professionals” as
contemplated by the Fee Guidelines.
19. Attached as Exhibit E is a background summary of each professional included in
this application, as required by the Local Guidelines.
20. No in-office conferences involving more than two professionals were billed during
the Interim Period. On two occasions during the Interim Period, Mr. Harris conferred with RBH
attorneys to analyze issues related to presenting Mr. Magee for deposition and for presenting
Debtor’s interests at a settlement conference. The perspectives of each professional attending
each meeting were both necessary and beneficial to the estate.
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Schachter Harris’s Fees and Expenses
21. Schachter Harris requests that the Court authorize (i) interim allowance of
compensation for professional services rendered during the Compensation Period in the amount
of $18,931.00 and (ii) the reimbursement of actual and necessary expenses and other charges
incurred by Schachter Harris in the connection with the rendition of such professional services in
the amount of $13,308.00.
22. The services that Schachter Harris rendered to Debtors during the Compensation
Period required 50.9 hours of the time of professionals and paraprofessionals.
Basis for Relief
23. The allowance of interim compensation for services rendered and reimbursement
of expenses incurred in bankruptcy matters is provided for in section 331 of the Bankruptcy Code,
“[a] debtor’s attorney, or any professional person… may apply to the court…for such
compensation for services rendered…as is provided under Section 330 of this title.”
24. Section 330(a)(1) of the Bankruptcy Code provides that a court may award to a
professional, including debtor’s attorney, “reasonable compensation for actual, necessary
services rendered by the …. professional person, or attorney and by any paraprofessional person
employed by any such person,” together with “reimbursement for actual, necessary expenses.”
11 U.S.C. § 330 (a)(1).
25. The services for which Schachter Harris seeks compensation were necessary and
beneficial to the estate, were not duplicative, and were performed within a reasonable amount of
time commensurate with the complexity, importance, and nature of the issues. 11 U.S.C. § 330
(a)(3)-(4).
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Notice
26. Schachter Harris represents to the Court that this Sixteenth Application and
accompanying Exhibits will be served upon the Notice Parties, and a Notice of Opportunity for
Hearing upon all other parties-in-interest as listed on the Certificate of Services filed with this
Court.
Conclusion
For the reasons submitted above, Schachter Harris requests that this Court enter an order
awarding Schachter Harris (i) interim compensation from the Debtors for services rendered for
the Compensation Period in the amount of $18,931.00, (ii) reimbursement of actual and
necessary expenses and other charges incurred in connection with the rendition of such services,
in the amount of $13,308.00, and (iii) such other relief as may be just and proper.
Dated: June 29, 2017.
Respectfully submitted, /S/ Raymond P. Harris, Jr. Raymond P. Harris, Jr. Esq. (admitted pro hac vice) [email protected] Cary Schachter, Esq. (admitted pro hac vice) [email protected] SCHACHTER HARRIS, LLP 909 Lake Carolyn Parkway Suite 1775 Irving, Texas 75039 (214) 999-5700 Special Asbestos Defense Counsel to the Debtors
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Exhibit A‐1
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SCHACHTER HARRIS LLP Trial Counsel
220 Canal Centre 400 East Las Colinas Blvd.
Irving, Texas 75039 (214) 999-5700
MONTHLY COMPENSATION STATEMENT
TO: See Notice Parties, attached FROM: Schachter Harris, LLP DATE: March 20, 2017 RE: Garlock Sealing Technologies LLC, et.al. Case No. 10-31607 (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of February 1, 2017 through February 28, 2017. During this period, SH incurred fees of $117.00 which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $2,376.77 for a total of $2,493.77.
Pursuant to the Order on Debtors’ Motion for Administrative Order Under 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the “Administrative Order”) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $2,482.07 calculated as follows: $ 117.00 x .90 $ 105.30 + 2,376.77 (100% of expenses) $ 2,482.07 A summary of the fees, costs, and expenses and SH’s billing records for the period of February 1, 2017 through February 28, 2017 are attached hereto and incorporated by reference.
Cumulative Holdback Analysis: Through February 28, 2017: $2,241.90
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NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. ([email protected]) 402 West Trade Street, Suite 200 Charlotte, NC 28202-1669 John R. Miller, Jr. ([email protected]) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC 28202-1672 Trevor W. Swett, Esq. ([email protected]) Kevin Davis ([email protected]; [email protected]; [email protected]) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C. 20005 Travis W. Moon, Esq. ([email protected]) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC 28244-2020 Deborah L. Fletcher, Esq. ([email protected]) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC 28210 C. Edward Dobbs ([email protected]) Parker Hudson Rainer & Dobbs, L.L.P. 1500 Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203 W. Clarkson McDow, Jr. ([email protected]) Attorney at Law 738 Myrtle Drive, Rock Hill, SC 29730
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FeesName Hours Rate Amount
Cary Schachter (Partner) 0 $400 0.00Ray Harris (Partner) 0 $400 0.00Laurie Fay (Partner) 0 $280 0.00Susan Ashmore (Of Counsel) 0 $260 0.00Erin Therrian (Associate) 0.3 $240 72.00Katrina Colwell (Associate) 0 $200 0.00Mary Helen Canaday (Sr Legal Asst) 0 $160 0.00Karina Robledo (Legal Assistant) 0 $150 0.00John Stanley (Paralegal) 0 $120 0.00Dena Farnsworth (Legal Assistant) 0.3 $150 45.00
0.6 117.00
Costs & Expenses AmountIn-house Copying (.10 per page) 0.00Machine Copywork 0.00Postage and Delivery Service 0.00Purchasing Third Party Research 0.00Record Retrieval & Storage 2,376.77Telephone Conference Fees 0.00Travel Expenses for Erin Therrian 0.00Travel Expenses for Cary Schachter 0.00Travel Expenses for Ray Harris 0.00
$2,376.77
Categories Hours AmountAnchor 0 0.00Asset Transactions 0 0.00Case Admin. Business Op. 0 0.00Claims Admin. 0 0.00Fee Proceedings 0.6 117.00Financing/Relief from Stay Proceedings 0 0.00Litigation 0 0.00Plan/Disclosure Stmt 0 0.00Other 0 0.00
0.6 117.00
Fees & Expenses of Experts Fees Travel AccommodationsOther
Expenses TotalConsulting Expert A 0 0 0 0 0Consulting Expert E 0 0 0 0 0Consulting Expert I 0 0 0 0 0
Total $0.00 $0.00 $0.00 $0.00 $0.00
Summary of Fees, Costs, and ExpensesSchachter Harris, LLP
February 1, 2017 through February 28, 2017
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 03/16/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-75Oc/o Liz Barry STATEMENT NO: 84349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Litigation
02/28/17 Statement from Iron Mountain for recordsmanagement 2,376.77
TOTAL ADVANCES 2,376.77
TOTAL CURRENT WORK 2,376.77
BALANCE DUE $2,376.77
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 03/16/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-77Oc/o Liz Barry STATEMENT NO: 40349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Fee Proceedings
HOURS02/16/17
ET FEE PROCEEDINGS: Finalize draft of 14thinterim fee application; exchangecorrespondence with Miller regarding same 0.30 72.00
DF FEE PROCEEDINGS: Revise exhibits for feeapplication 0.30 45.00
FOR CURRENT SERVICES RENDERED 0.60 117.00
RECAPITULATIONTIMEKEEPER HOURS HOURLY RATE TOTALErin Therrian 0.30 $240.00 $72.00Dena Farnsworth 0.30 150.00 45.00
TOTAL CURRENT WORK 117.00
BALANCE DUE $117.00
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Exhibit A‐2
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SCHACHTER HARRIS LLP Trial Counsel
220 Canal Centre 400 East Las Colinas Blvd.
Irving, Texas 75039 (214) 999-5700
MONTHLY COMPENSATION STATEMENT
TO: See Notice Parties, attached FROM: Schachter Harris, LLP DATE: April 20, 2017 RE: Garlock Sealing Technologies LLC, et.al. Case No. 10-31607 (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of March 1, 2017 through March 31, 2017. During this period, SH incurred fees of $1,011.00 which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $2,376.77 for a total of $3,387.77.
Pursuant to the Order on Debtors’ Motion for Administrative Order Under 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the “Administrative Order”) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $3,286.67 calculated as follows: $ 1,011.00 x .90 $ 909.90 + 2,376.77 (100% of expenses) $ 3,286.67 A summary of the fees, costs, and expenses and SH’s billing records for the period of March 1, 2017 through March 31, 2017 are attached hereto and incorporated by reference.
Cumulative Holdback Analysis: Through March 31, 2017: $2,343.00
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NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. ([email protected]) 402 West Trade Street, Suite 200 Charlotte, NC 28202-1669 John R. Miller, Jr. ([email protected]) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC 28202-1672 Trevor W. Swett, Esq. ([email protected]) Kevin Davis ([email protected]; [email protected]; [email protected]) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C. 20005 Travis W. Moon, Esq. ([email protected]) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC 28244-2020 Deborah L. Fletcher, Esq. ([email protected]) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC 28210 C. Edward Dobbs ([email protected]) Parker Hudson Rainer & Dobbs, L.L.P. 1500 Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203 W. Clarkson McDow, Jr. ([email protected]) Attorney at Law 738 Myrtle Drive, Rock Hill, SC 29730
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FeesName Hours Rate Amount
Cary Schachter (Partner) 0 $400 0.00Ray Harris (Partner) 0 $400 0.00Laurie Fay (Partner) 0 $280 0.00Susan Ashmore (Of Counsel) 0 $260 0.00Erin Therrian (Associate) 2.4 $240 576.00Katrina Colwell (Associate) 0 $200 0.00Mary Helen Canaday (Sr Legal Asst) 0 $160 0.00Karina Robledo (Legal Assistant) 1.5 $150 225.00John Stanley (Paralegal) 0 $120 0.00Dena Farnsworth (Legal Assistant) 1.4 $150 210.00
5.3 1,011.00
Costs & Expenses AmountIn-house Copying (.10 per page) 0.00Machine Copywork 0.00Postage and Delivery Service 0.00Purchasing Third Party Research 0.00Record Retrieval & Storage 2,376.77Telephone Conference Fees 0.00Travel Expenses for Erin Therrian 0.00Travel Expenses for Cary Schachter 0.00Travel Expenses for Ray Harris 0.00
$2,376.77
Categories Hours AmountAnchor 0 0.00Asset Transactions 0 0.00Case Admin. Business Op. 0 0.00Claims Admin. 0 0.00Fee Proceedings 3.7 762.00Financing/Relief from Stay Proceedings 0 0.00Litigation 1.6 249.00Plan/Disclosure Stmt 0 0.00Other 0 0.00
5.3 1,011.00
Fees & Expenses of Experts Fees Travel AccommodationsOther
Expenses TotalConsulting Expert A 0 0 0 0 0Consulting Expert E 0 0 0 0 0Consulting Expert I 0 0 0 0 0
Total $0.00 $0.00 $0.00 $0.00 $0.00
Summary of Fees, Costs, and ExpensesSchachter Harris, LLP
March 1, 2017 through March 31, 2017
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 04/19/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-75Oc/o Liz Barry STATEMENT NO: 85349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Litigation
HOURS03/27/17
ET CONFIRMATION: Review request from Niven(Garrison) regarding obtaining releases 0.10 24.00
KR CONFIRMATION: Research regardingGarrison's preliminary inquiry on thecollection of Garlock releases 1.50 225.00
FOR CURRENT SERVICES RENDERED 1.60 249.00
RECAPITULATIONTIMEKEEPER HOURS HOURLY RATE TOTALErin Therrian 0.10 $240.00 $24.00Karina Robledo 1.50 150.00 225.00
03/31/17 Statement from Iron Mountain for recordsmanagement 2,376.77
TOTAL ADVANCES 2,376.77
TOTAL CURRENT WORK 2,625.77
BALANCE DUE $2,625.77
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 04/19/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-77Oc/o Liz Barry STATEMENT NO: 41349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Fee Proceedings
HOURS03/17/17
ET FEE PROCEEDINGS: Exchange correspondencewith Jack Miller regarding next round ofinterim fee applications 0.10 24.00
03/20/17DF FEE PROCEEDINGS: Prepare exhibits and
detail for 15th interim fee application 1.10 165.00
03/22/17ET FEE PROCEEDINGS: Review fee examiner's
draft report regarding 14th interim feeapplication; prepare response 1.40 336.00
03/31/17ET FEE PROCEEDINGS: Draft 15th interim fee
application 0.50 120.00
FOR CURRENT SERVICES RENDERED 3.70 762.00
RECAPITULATIONTIMEKEEPER HOURS HOURLY RATE TOTALErin Therrian 2.30 $240.00 $552.00Dena Farnsworth 1.40 150.00 210.00
TOTAL CURRENT WORK 762.00
BALANCE DUE $762.00
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Exhibit A‐3
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SCHACHTER HARRIS LLP Trial Counsel
220 Canal Centre 400 East Las Colinas Blvd.
Irving, Texas 75039 (214) 999-5700
MONTHLY COMPENSATION STATEMENT
TO: See Notice Parties, attached FROM: Schachter Harris, LLP DATE: May 19, 2017 RE: Garlock Sealing Technologies LLC, et.al. Case No. 10-31607 (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of April 1, 2017 through April 30, 2017. During this period, SH incurred fees of $16,840.00 which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $6,177.69 for a total of $23,017.69.
Pursuant to the Order on Debtors’ Motion for Administrative Order Under 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the “Administrative Order”) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $21,333.69 calculated as follows: $ 16,840.00 x .90 $ 15,156.00 + 6,177.69 (100% of expenses) $ 21,333.69 A summary of the fees, costs, and expenses and SH’s billing records for the period of April 1, 2017 through April 30, 2017 are attached hereto and incorporated by reference.
Cumulative Holdback Analysis: Through April 30, 2017: $2,723.10
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NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. ([email protected]) 402 West Trade Street, Suite 200 Charlotte, NC 28202-1669 John R. Miller, Jr. ([email protected]) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC 28202-1672 Trevor W. Swett, Esq. ([email protected]) Kevin Davis ([email protected]; [email protected]; [email protected]) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C. 20005 Travis W. Moon, Esq. ([email protected]) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC 28244-2020 Deborah L. Fletcher, Esq. ([email protected]) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC 28210 C. Edward Dobbs ([email protected]) Parker Hudson Rainer & Dobbs, L.L.P. 1500 Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203 W. Clarkson McDow, Jr. ([email protected]) Attorney at Law 738 Myrtle Drive, Rock Hill, SC 29730
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FeesName Hours Rate Amount
Cary Schachter (Partner) 0.4 $400 160.00Ray Harris (Partner) 41.4 $400 16,560.00Laurie Fay (Partner) 0 $280 0.00Susan Ashmore (Of Counsel) 0 $260 0.00Erin Therrian (Associate) 0.5 $240 120.00Katrina Colwell (Associate) 0 $200 0.00Mary Helen Canaday (Sr Legal Asst) 0 $160 0.00Karina Robledo (Legal Assistant) 0 $150 0.00John Stanley (Paralegal) 0 $120 0.00Dena Farnsworth (Legal Assistant) 0 $150 0.00
42.3 16,840.00
Costs & Expenses AmountIn-house Copying (.10 per page) 0.00Machine Copywork 0.00Postage and Delivery Service 0.00Purchasing Third Party Research 0.00Record Retrieval & Storage 2,376.77Telephone Conference Fees 0.00Travel Expenses for Erin Therrian 0.00Travel Expenses for Cary Schachter 0.00Travel Expenses for Ray Harris 3,800.92
$6,177.69
Categories Hours AmountAnchor 0 0.00Asset Transactions 0 0.00Case Admin. Business Op. 0 0.00Claims Admin. 0 0.00Fee Proceedings 0 0.00Financing/Relief from Stay Proceedings 0 0.00Litigation 42.3 16,840.00Plan/Disclosure Stmt 0 0.00Other 0 0.00
42.3 16,840.00
Fees & Expenses of Experts Fees Travel AccommodationsOther
Expenses TotalConsulting Expert A 0 0 0 0 0Consulting Expert E 0 0 0 0 0Consulting Expert I 0 0 0 0 0
Total $0.00 $0.00 $0.00 $0.00 $0.00
Summary of Fees, Costs, and ExpensesSchachter Harris, LLP
April 1, 2017 through April 30, 2017
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 05/18/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-75Oc/o Liz Barry STATEMENT NO: 86349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Litigation
HOURS04/11/17
CS CONFIRMATION: Review Krisko request forcalculation of interest on Torresjudgement and confirm computations 0.40 160.00
ET CONFIRMATION: Research regardingpost-judgment interest on Torres matter,per Krisko request 0.50 120.00
04/14/17RH CONFIRMATION: Telephone conference with
Magee and Cassada regarding preparationfor Magee deposition 0.30 120.00
RH CONFIRMATION: Review materials from Worfregarding preparation for Mageedeposition 2.00 800.00
04/17/17RH CONFIRMATION: Review materials from
Cassada and Worf to prepare for Mageedeposition taken by Century 4.50 1,800.00
RH CONFIRMATION: Travel to Charlotte toprepare for and attend Magee deposition(billed at 1/2 time) 2.00 800.00
04/18/17RH CONFIRMATION: Prepare for meeting with
Magee 1.70 680.00RH CONFIRMATION: Attend conference with
Cassada and Worf to prepare for Mageedeposition taken by Century 3.50 1,400.00
RH CONFIRMATION: Attend conference withMagee, Cassada and Worf to prepare forMagee deposition 8.00 3,200.00
04/19/17RH CONFIRMATION: Prepare for Magee
deposition 1.20 480.00RH CONFIRMATION: Present Magee for
deposition 3.50 1,400.00RH CONFIRMATION: Return from Magee
deposition (billed at 1/2 time) 1.60 640.00
04/23/17RH CONFIRMATION: Travel to Century
settlement conference (billed at 1/2
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Page: 2Garlock 05/18/2017
ACCOUNT NO: 20015-75OSTATEMENT NO: 86
Bankruptcy--Litigation
HOURStime) 2.00 800.00
RH CONFIRMATION: Prepare for Centurysettlement conference 1.40 560.00
04/24/17RH CONFIRMATION: Attend Century settlement
conference with Magee and Cassada 6.50 2,600.00RH CONFIRMATION: Attend conference with SPX
counsel and Garlock insurance counselwith Cassada and Magee 1.00 400.00
04/25/17RH CONFIRMATION: Return from Century
settlement conference (billed at 1/2time) 2.00 800.00
04/28/17RH CONFIRMATION: Exchange correspondence
with Magee regarding errata sheet to hisdeposition 0.20 80.00
FOR CURRENT SERVICES RENDERED 42.30 16,840.00
RECAPITULATIONTIMEKEEPER HOURS HOURLY RATE TOTALCary Schachter 0.40 $400.00 $160.00Ray Harris 41.40 400.00 16,560.00Erin Therrian 0.50 240.00 120.00
04/19/17 Payment to Raymond Harris for parking, cab fares,meals, hotel and airfare to and from Charlotte,NC to attend deposition 1,780.03
04/25/17 Payment to Raymond Harris for parking, cab fares,meals, hotel and airfare to and from Washington,DC to attend meeting 2,020.89
04/30/17 Statement from Iron Mountain for recordsmanagement 2,376.77
TOTAL ADVANCES 6,177.69
TOTAL CURRENT WORK 23,017.69
BALANCE DUE $23,017.69
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Exhibit A‐4
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SCHACHTER HARRIS LLP Trial Counsel
220 Canal Centre 400 East Las Colinas Blvd.
Irving, Texas 75039 (214) 999-5700
MONTHLY COMPENSATION STATEMENT
TO: See Notice Parties, attached FROM: Schachter Harris, LLP DATE: June 20, 2017 RE: Garlock Sealing Technologies LLC, et.al. Case No. 10-31607 (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of May 1, 2017 through May 31, 2017. During this period, SH incurred fees of $1,080.00 which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $2,376.77 for a total of $3,456.77.
Pursuant to the Order on Debtors’ Motion for Administrative Order Under 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the “Administrative Order”) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $3,348.77 calculated as follows: $ 1,080.00 x .90 $ 972.00 + 2,376.77 (100% of expenses) $ 3,348.77 A summary of the fees, costs, and expenses and SH’s billing records for the period of May 1, 2017 through May 31, 2017 are attached hereto and incorporated by reference.
Cumulative Holdback Analysis: Through May 31, 2017: $2,831.10
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NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. ([email protected]) 402 West Trade Street, Suite 200 Charlotte, NC 28202-1669 John R. Miller, Jr. ([email protected]) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC 28202-1672 Trevor W. Swett, Esq. ([email protected]) Kevin Davis ([email protected]; [email protected]; [email protected]) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C. 20005 Travis W. Moon, Esq. ([email protected]) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC 28244-2020 Deborah L. Fletcher, Esq. ([email protected]) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC 28210 C. Edward Dobbs ([email protected]) Parker Hudson Rainer & Dobbs, L.L.P. 1500 Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203 W. Clarkson McDow, Jr. ([email protected]) Attorney at Law 738 Myrtle Drive, Rock Hill, SC 29730
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FeesName Hours Rate Amount
Cary Schachter (Partner) 0 $400 0.00Ray Harris (Partner) 2.7 $400 1,080.00Laurie Fay (Partner) 0 $280 0.00Susan Ashmore (Of Counsel) 0 $260 0.00Erin Therrian (Associate) 0 $240 0.00Katrina Colwell (Associate) 0 $200 0.00Mary Helen Canaday (Sr Legal Asst) 0 $160 0.00Karina Robledo (Legal Assistant) 0 $150 0.00John Stanley (Paralegal) 0 $120 0.00Dena Farnsworth (Legal Assistant) 0 $150 0.00
2.7 1,080.00
Costs & Expenses AmountIn-house Copying (.10 per page) 0.00Machine Copywork 0.00Postage and Delivery Service 0.00Purchasing Third Party Research 0.00Record Retrieval & Storage 2,376.77Telephone Conference Fees 0.00Travel Expenses for Erin Therrian 0.00Travel Expenses for Cary Schachter 0.00Travel Expenses for Ray Harris 0.00
$2,376.77
Categories Hours AmountAnchor 0 0.00Asset Transactions 0 0.00Case Admin. Business Op. 0 0.00Claims Admin. 0 0.00Fee Proceedings 0 0.00Financing/Relief from Stay Proceedings 0 0.00Litigation 2.7 1,080.00Plan/Disclosure Stmt 0 0.00Other 0 0.00
2.7 1,080.00
Fees & Expenses of Experts Fees Travel AccommodationsOther
Expenses TotalConsulting Expert A 0 0 0 0 0Consulting Expert E 0 0 0 0 0Consulting Expert I 0 0 0 0 0
Total $0.00 $0.00 $0.00 $0.00 $0.00
Summary of Fees, Costs, and ExpensesSchachter Harris, LLP
May 1, 2017 through May 31, 2017
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SCHACHTER HARRIS L.L.P. Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, TX 75039 (214) 999-5700 Fax (214) 999-5747 TAX ID# 20-0191571
Page: 1Garlock 06/19/2017Garrison Litigation Mgt Group, LTD ACCOUNT NO: 20015-75Oc/o Liz Barry STATEMENT NO: 87349 West Commercial St., Ste 3050East Rochester NY 14445
Bankruptcy--Litigation
HOURS05/02/17
RH CONFIRMATION: Review Magee deposition andincorporate Magee corrections into erratasheet 2.20 880.00
05/10/17RH CONFIRMATION: Exchange correspondence
with Magee deposition court reporterregarding original transcript 0.20 80.00
05/11/17RH CONFIRMATION: Draft correspondence to
Magee regarding errata sheet and signingdeposition 0.30 120.00
FOR CURRENT SERVICES RENDERED 2.70 1,080.00
RECAPITULATIONTIMEKEEPER HOURS HOURLY RATE TOTALRay Harris 2.70 $400.00 $1,080.00
05/31/17 Payment to Iron Mountain for records management 2,376.77
TOTAL ADVANCES 2,376.77
TOTAL CURRENT WORK 3,456.77
BALANCE DUE $3,456.77
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