in the united states bankruptcy court for the … · 2020. 9. 21. · 74812014.1 proceeding and...

74812014.1

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: LUCKY’S MARKET PARENT COMPANY, LLC, et al.,1

Debtors.

Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered) Objection Deadline: October 12, 2020 at 4:00 p.m. Hearing Date: Only if an objection is filed.

SEVENTH MONTHLY FEE APPLICATION OF POLSINELLI PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES

AS COUNSEL TO THE DEBTORS AND DEBTORS IN POSSESSION FOR THE PERIOD FROM AUGUST 1, 2020 THROUGH AUGUST 31, 2020

Name of Applicant: POLSINELLI PC

Authorized to Provide Professional Services to:

Debtors and Debtors in Possession

Date of Retention: February 26, 2020, nunc pro tunc to January 27, 2020

Period for which compensation and reimbursement is sought:

August 1, 2020 through August 31, 2020

Amount of Compensation sought as actual, reasonable and necessary:

$349,701.85

80% of Amount of Compensation sought as actual, reasonable and necessary:

$279,761.48

Amount of Expense Reimbursement sought as actual, reasonable and necessary:

$15,820.39

1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, are Lucky’s Market Parent Company, LLC (2055), Lucky’s Farmers Market Holding Company, LLC (5480), Lucky’s Market Operating Company, LLC (7064), LFM Stores LLC (3114), Lucky’s Farmers Market, LP (0828), Lucky’s Farmers Market Resource Center, LLC (7711), Lucky’s Market Holding Company 2, LLC (0607), Lucky’s Market GP 2, LLC (9335), Lucky’s Market 2, LP (8384), Lucky’s Market of Longmont, LLC (9789), Lucky’s Farmers Market of Billings, LLC (8088), Lucky’s Farmers Markets of Columbus, LLC (3379), Lucky’s Farmers Market of Rock Hill, LLC (3386), LFM Jackson, LLC (8300), Lucky’s Farmers Market of Ann Arbor, LLC (4067), Lucky’s Market of Gainesville, LLC (7877), Lucky’s Market of Bloomington, LLC (3944), Lucky’s Market of Plantation, LLC (4356), Lucky’s Market of Savannah, GA, LLC (1097), Lucky’s Market of Traverse, City, LLC (2033), Lucky’s Market of Naples, FL, LLC (8700), Sinoc, Inc. (0723), Lucky’s Farmers Market of Ellisville, LLC (2875), and Lucky’s Farmers Market of Lexington, KY, LLC (3446).

Case 20-10166-JTD Doc 1063 Filed 09/21/20 Page 1 of 10

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Number of Professionals Included in this Application:

13

Number of Professionals Billing Less Than 15 Hours to the Case During this Period:

4

Blended Rate for All Attorneys in this Application:

$534.88

Blended Rate for All Timekeepers in this Application:

$512.98

This is a(n): Monthly Interim ___ Final application

This is the SEVENTH monthly fee application filed by Polsinelli in this case.

Summary of Polsinelli’s Monthly Fee Applications

Compensation Period

100% Fees2 80% Fees 100% Expenses Total

January 27, 2020 – February 29, 2020

$504,280.75 $403,424.60 $6,952.88 $511,233.63

March 1, 2020 – March 31, 2020

$578,179.85 $462,543.60 $55,959.15 $634,139.00

April 1, 2020 – April 30, 2020

$450,105.10 $360,084.08 $37,774.79 $487,879.89

May 1, 2020 – May 31, 2020

$368,553.15 $294,842.52 $9,223.60 $377,776.75

June 1, 2020 – June 30, 2020

$359,907.55 $287,926.04 $10,581.29 $370,488.84

July 1, 2020 – July 31, 2020

$313,097.80 $250,478.24 $8,771.01 $313,097.80

August 1, 2020 – August 31, 2020

$349,701.85 $279,761.48 $15,820.39 $365,522.24

2 Inclusive of 50% reduction for travel time fees, where applicable.


74812014.1

SUMMARY OF TIMEKEEPERS INCLUDED IN FEE APPLICATION

Name Title Section

Date of First

Admission Fees Billed Hours Billed

Hourly Rate

Billed in This

Application

Barlow, Savanna Associate

FR Financial

Services

Litigation 5/1/2018 $ 6,349.50 16.60 $ 382.50

Boydston, Liz N Shareholder

FR Bankruptcy

and Restructuring 11/1/2007 $ 70,148.00 98.80 $ 710.00

Dolphin, Brenna A Associate

FR Bankruptcy


Green, Trinitee G. Associate

FR Bankruptcy


Katona, Shanti M. Shareholder

FR Bankruptcy


Loh, Jillian Associate

FR Real Estate

Finance 11/1/2017 $ 842.40 2.40 $ 351.00

Martin, James P. Shareholder

FR Bankruptcy


Robbins, William S. Shareholder

LE Employment

Litigation 1/1/1984 $ 2,670.30 4.60 $ 580.50

Scott, Anaston Litigation Serv

FM Litigation

Services $ 450.00 2.00 $ 225.00

Suprum, Lindsey M. Paralegal

FR Bankruptcy

and Restructuring $ 19,125.00 62.50 $ 306.00

Terr, Amanda L. Associate

BU Corporate and

Transactional 11/1/2014 $ 42,219.45 103.10 $ 409.50

Wang, Caryn Associate

FR Bankruptcy


Ward, Chris A. Shareholder

FR Bankruptcy


$ 349,701.85 681.70 $ 512.98


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SUMMARY OF COMPENSATION BY PROJECT CATEGORY

Project Category Hours Billed Fees Sought

Asset Analysis & Recovery 0.50 $ 213.75

Asset Disposition & Sales 160.20 $ 74,943.95

Assumption/Rejection of Leases & Contracts 68.90 $ 37,992.15

Avoidance Action Analysis 0.40 $ 170.00

Bankruptcy-Related Advice 17.80 $ 9,457.90

Business Operations 3.20 $ 2,161.00

Case Administration 17.10 $ 6,721.35

Claims 1.30 $ 723.55

Claims Administration & Objections 47.40 $ 23,396.50

Corporate Governance & Board Matters 5.00 $ 3,713.00

Court Hearings 12.80 $ 5,620.50

Creditor Committee Meetings 0.20 $ 142.00

Creditor Inquiries 0.70 $ 542.00

Employment/Fee Applications 4.40 $ 3,470.60

Financing & Cash Collateral 3.20 $ 2,560.00

Litigation & Other Contested Matters 262.20 $ 139,179.65

Other Professional Fee Application 2.70 $ 826.20

Plan & Disclosure Statement (including business plan) 66.00 $ 34,968.15

Polsinelli Fee Applications 6.30 $ 1,927.80

Relief from Stay/Adequate Protection Proceedings 0.60 $ 480.00

Schedules/SOFAS/UST Reports 0.80 $ 491.80

681.70 $ 349,701.85

EXPENSE SUMMARY

Category Amount

Client Advance (Certified Copy) 11.00$

Deposition Transcript 436.25$

Filing Fees 531.00$

Miscellaneous (CourtCall) 166.50$

On-Line Searches 257.50$

Relativity-Searchable Data Hosting 3,470.13$

Tiff Creation/Production Images 31.50$

Westlaw Computer Research 10,916.51$

15,820.39$


74812014.1



Debtors.


SEVENTH MONTHLY FEE APPLICATION OF POLSINELLI PC FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES

AS COUNSEL TO THE DEBTORS AND DEBTORS IN POSSESSION FOR THE PERIOD FROM AUGUST 1, 2020 THROUGH AUGUST 31, 2020

POLSINELLI PC (“Polsinelli”), counsel to the debtors and debtors in possession (the

“Debtors”) in the above-captioned cases (the “Cases”), submits its seventh monthly fee

application (the “Application”) for approval pursuant to 11 U.S.C. §§ 330 and 331 of its

monthly compensation and reimbursement of expenses for the period from August 1, 2020

through August 31, 2020 (the “Compensation Period”). In support thereof, Polsinelli

respectfully represents as follows:

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



74812014.1

proceeding and this Application is proper in this District pursuant to 28 U.S.C. §§ 1408 and

1409. The statutory predicates for the relief sought are sections 105(a) and 331 of the

Bankruptcy Code and the Order Establishing Procedures for Interim Compensation and

Reimbursement of Expenses of Professionals [Docket No. 259] entered in these Cases.

II. BACKGROUND

2. On January 27, 2020 (the “Petition Date”), each of the Debtors filed

voluntary petitions for relief under chapter 11 of the Bankruptcy Code with the United States

Bankruptcy Court for the District of Delaware (the “Court”) commencing the above-captioned

chapter 11 Cases. The factual background regarding the Debtors, including their business

operations and the events leading to the filing of these Cases, is set forth in detail in the Amended

Declaration of Andrew T. Pillari, Chief Financial Officer of Lucky’s Market Parent Company,

LLC, in Support of Chapter 11 Petitions and First Day Pleadings [Docket No. 47], fully

incorporated by reference therein. The Debtors have continued in the management and operation

of their businesses and properties as debtors in possession pursuant to sections 1107(a) and 1108

of the Bankruptcy Code.

3. No trustee or examiner has been appointed in these Cases. On February 4,

2020, the Office of the United States Trustee appointed an official committee of unsecured

creditors pursuant to section 1102 of the Bankruptcy Code.

4. On February 26, 2020, this Court entered an order approving the retention

of Polsinelli as counsel to the Debtors, nunc pro tunc to the Petition Date [Docket No. 277].

III. FEES AND EXPENSES

5. Polsinelli has continuously rendered services to the Debtors during the

Compensation Period, totaling 681.70 of actually billable hours of professional time, comprising

617.20 hours of professional services and 64.50 hours of paraprofessional services. The services


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of Polsinelli are necessary to enable the Debtors to execute faithfully their duties as debtors and

debtors in possession. Polsinelli has provided, and will continue to provide, services to the

Debtors including the following:

a. taking all necessary action to protect and preserve the estates of the Debtors, including the negotiation of disputes in which the Debtors are involved, the prosecution of actions on the Debtors’ behalf, the defense of any actions commenced against the Debtors, and the preparation of objections to claims filed against the Debtors’ estates;

b. reviewing all pleadings filed in the Cases;

c. providing legal advice with respect to the Debtors’ powers and duties as debtors in possession in the continued operation of their business;

d. preparing on behalf of the Debtors, as debtors in possession, necessary motions, applications, answers, orders, reports, and other legal papers in connection with the administration of the Debtors’ estates;

e. appearing in court and protecting the interests of the Debtors before this Court;

f. assisting with any disposition of the Debtors’ assets, by sale or otherwise;

g. taking all necessary or appropriate actions in connection with any plan of reorganization and related disclosure statement and all related documents, and such further actions as may be required in connection with the administration of the Debtors’ estates; and

h. performing all other legal services in connection with the Cases as may reasonably be required.

6. The total sum due to Polsinelli for professional services rendered on

behalf of the Debtors for the Compensation Period is $349,701.85, 80% of which will be due and

payable immediately upon approval of this Application. Polsinelli submits that the professional

services it rendered on behalf of the Debtors during this time were reasonable and necessary

under the circumstances.

7. Polsinelli also expended costs on behalf of the Debtors during the

Compensation Period in the sum of $15,820.39, 100% of which will be due and payable

immediately upon approval of this Application. In accordance with Rule 2016-2(e)(iii) of the


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Local Rules of Practice and Procedure for the United States Bankruptcy Court for the District of

Delaware, all copying charges are billed at no more than $0.10 per page.

8. Attached hereto as Exhibit A is the detailed invoice of Polsinelli’s fees and

expenses for the Compensation Period.2

9. The undersigned hereby attests that he has reviewed the requirements of

Local Rule 2016-2 and this Application conforms to such requirements.

WHEREFORE, Polsinelli requests that the Court approve the Application, pursuant to 11

U.S.C. §§ 105(a) and 331, granting it interim compensation for professional services rendered in

the amount of $349,701.85, 80% of which is to be paid upon the filing of a certificate of no

objection, and the sum of $15,820.39 for reimbursement of actual and necessary costs expended

as counsel to the Debtors for the period from August 1, 2020 through August 31, 2020.

Dated: September 21, 2020 Wilmington, Delaware

Respectfully submitted,

POLSINELLI PC

/s/ Christopher A. Ward Christopher A. Ward (Del. Bar No. 3877)

222 Delaware Avenue, Suite 1101 Wilmington, Delaware 19801 Telephone: (302) 252-0920 Facsimile: (302) 252-0921 [email protected] -and- Liz Boydston (Admitted Pro Hac Vice) 2950 N. Harwood, Suite 2100 Dallas, TX 75201 Telephone: (214) 661-5557 [email protected]

Counsel to the Debtors and Debtors in Possession

2 Electronic research is charged at standard Westlaw rates less a percentage discount that is assessed and adjusted periodically based on market terms.


mailto:[email protected]

74812014.1



Debtors.

Chapter 11 Case No. 20-10166 (JTD) (Jointly Administered)

VERIFICATION OF CHRISTOPHER A. WARD

1. I am a Shareholder in the Wilmington, Delaware office of Polsinelli PC

(“Polsinelli”), which maintains offices for the practice of law at 222 Delaware Avenue, Suite

1101, Wilmington, Delaware 19801, among other locations across the country. I am an attorney-

at-law, duly admitted, and in good standing to practice in the State of Delaware, as well as the

United States Court of Appeals for the Third Circuit, and the United States District Court for the

District of Delaware.

2. I have personally performed many of the legal services rendered by Polsinelli as

counsel to the above-captioned debtors and debtors in possession (the “Debtors”) and am

familiar with all other work performed on behalf of the Debtors by the lawyers and other

employees at Polsinelli.

3. The facts set forth in the foregoing Application are true and correct to the best of

my knowledge, information, and belief.



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4. I have reviewed Rule 2016-2 of the Local Rules of Bankruptcy Practice and

Procedure of the United States Bankruptcy Court for the District of Delaware and believe that

the Application for Polsinelli complies with same.

5. Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the

foregoing is true and correct.

Dated: September 21, 2020 Respectfully submitted,

/s/ Christopher A. Ward Christopher A. Ward (Del. Bar. No. 3877)


74812014.1



Debtors.


NOTICE OF APPLICATION

PLEASE TAKE NOTICE that POLSINELLI PC (the “Applicant”), counsel to the debtors

and debtors in possession in the above-captioned bankruptcy cases (the “Debtors”), has filed the Seventh Monthly Fee Application of Polsinelli PC for Compensation and Reimbursement of Expenses as Counsel to the Debtors and Debtors in Possession for the Period from August 1, 2020 through August 31, 2020 (the “Application”) with the United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”), 824 N. Market Street, Wilmington, Delaware 19801.

PLEASE TAKE FURTHER NOTICE that any responses or objections to the Application

must be filed with the Bankruptcy Court in accordance with the local rules and the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 259] (the “Compensation Order”) and served on or before October 12, 2020 at 4:00 p.m. (Eastern Time) (the “Objection Deadline”) upon the following parties: (a) the Debtors; (b) counsel for the Debtors; (c) the Office of the United States Trustee for the District of Delaware; (d) counsel to the Prepetition Secured Lender; and (e) counsel to the Official Committee of Unsecured Creditors.

PLEASE TAKE FURTHER NOTICE that if any responses or objections to the

Application are timely filed, served, and received, a hearing on the Application will be held at a date and time convenient to the Bankruptcy Court. Only those objections made in writing and timely filed and received in accordance with the Compensation Order and the procedures set forth herein will be considered by the Bankruptcy Court at such hearing.


Case 20-10166-JTD Doc 1063-1 Filed 09/21/20 Page 1 of 2

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IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE APPLICATION WILL BE DEEMED APPROVED AND THE APPLICANT WILL BE ENTITLED TO PAYMENT OF 80% OF ITS REQUESTED FEES AND 100% OF ITS REQUESTED EXPENSES WITHOUT FURTHER NOTICE OR HEARING.

Dated: September 21, 2020 Wilmington, Delaware

Respectfully submitted,

POLSINELLI PC

/s/ Christopher A. Ward Christopher A. Ward (Del. Bar No. 3877)

222 Delaware Avenue, Suite 1101 Wilmington, Delaware 19801 Telephone: (302) 252-0920 Facsimile: (302) 252-0921 [email protected] -and- Liz Boydston (Admitted Pro Hac Vice) 2950 N. Harwood, Suite 2100 Dallas, TX 75201 Telephone: (214) 661-5557 [email protected]

Counsel to the Debtors and Debtors in Possession


mailto:[email protected]

74812014.1

EXHIBIT A

POLSINELLI PC Detailed Monthly Invoice


Lucky's Market Parent Company, LLCBo Sherman6328 Monarch Park Place, Ste 100Niwot, CO 80503

Invoice Date:Invoice No:Matter No:

September 9, 20201839103

106414-646376

As of the above date, we are showing the above balances are open and unpaid.This may not reflect other matters with alternative billing arrangements and does not reflect any unbilled fees and expenses.

Questions regarding your account, please call1 (877) 577-7455 or [email protected] other inquiries, please contact Chris A. Ward at (302) 252-0920 or [email protected]

Electronic remittance detail can be sent to [email protected]

Please make checks payable toPolsinelli PCP.O. Box 878681Kansas City, MO 64187-8681

222 Delaware Avenue, Suite 1101, Wilmington, DE 19801 | Phone: (302) 252-0920 www.polsinelli.com

For Professional Services Through August 31, 2020

Client: Lucky's Market Parent Company, LLCMatter: Restructuring

Total Current Fees $ 349,701.85

Total Costs $ 15,820.39

Total Current Invoice $ 365,522.24


Lucky's Market Parent Company, LLCRestructuring

Invoice Date:Invoice No.:Matter No.:

September 9, 20201839103

106414-646376

Page Number 2

Time Detail

B110 Case Administration

Date Description Initials Hours Amount08/03/20 Gave access to workspace per request from Liz Boydston. ASCOT 0.10 $22.5008/04/20 Weekly update call with working group. TGGR 1.00 427.5008/05/20 Correspondence with C. Ward regarding request for hearing date

for interim fee application and confirmationLMSUP 0.10 30.60

08/06/20 Correspondence with chambers and C. Ward to schedule October hearing date for confirmation and interim fee applications

LMSUP 0.20 61.20

08/06/20 Correspondence with C. Ward and T. Green regarding adjournment of hearing on Woolbright's motion to compel and extension of deadlines regarding same

LMSUP 0.10 30.60

08/06/20 Created searches for PROD002. Tagged documents included in PROD002 as Responsive. Created LS Admin tags for PROD002.

ASCOT 0.90 202.50

08/06/20 Processed two documents for production per request from Caryn Wang.

ASCOT 0.30 67.50

08/07/20 Review dockets, update critical dates memo and distribute; update calendar; correspondence regarding same.

LMSUP 1.50 459.00

08/07/20 Review and related communications with Lindsey Suprum regarding updated critical dates calendar.

ENBOY 0.10 71.00

08/10/20 Prepared the 20200810_Prod0023 production. ASCOT 0.70 157.5008/10/20 Confer with Chris Ward and Caryn Wang regarding Louisville

litigation strategy (.1); communications with Isaac Gabriel regarding discovery and tomorrow's deposition (.2); numerous communications with Lexitas regarding upcoming deposition logistics and follow-up with Landlord's counsel, Committee counsel, Lucky's team, and Polsinelli core team (.5).

ENBOY 0.80 568.00

08/11/20 Weekly conference call with Lucky's team and all professionals. ENBOY 1.00 710.0008/12/20 Advise L. Suprum re omnibus hearing dates. SMKAT 0.10 53.1008/14/20 Correspondence with C. Ward and T. Green regarding further

extension of briefing deadlines for Woolbright motion to compel; document same.

LMSUP 0.20 61.20

08/14/20 Review dockets, update critical dates memo and distribute; update calendar; correspondence regarding same.

LMSUP 1.50 459.00

08/14/20 Draft, finalize and file certification of counsel and order scheduling omnibus hearing dates; finalize and upload proposed order; correspondence regarding same.

LMSUP 0.70 214.20

08/14/20 Review and comment on updated critical dates. SMKAT 0.10 53.1008/18/20 Participate in weekly all-hands team and professionals call

regarding outstanding case issues, objections, claims, closings, Louisville Litigation, and plan/disclosure statement.

ENBOY 1.00 710.00




September 9, 20201839103

106414-646376

Page Number 3

Date Description Initials Hours Amount08/19/20 Correspondence with B. Dolphin regarding upcoming filings LMSUP 0.10 30.6008/19/20 Telephone conference with B. Dolphin regarding pending tasks

and next steps (0.5); review outline of open tasks and provide comments to same (0.4).

TGGR 0.90 384.75

08/20/20 Multiple correspondence with Polsinelli team and chambers regarding revised confirmation schedule and rescheduling evidentiary hearing

LMSUP 0.60 183.60

08/21/20 Various correspondence with chambers and Polsinelli team regarding scheduling and moving certain omnibus hearing dates

LMSUP 0.40 122.40

08/21/20 Work with L. Suprum on omnibus hearing schedule and address critical case management re same.

SMKAT 0.20 106.20

08/24/20 Correspondence with chambers regarding cancellation of August 27 hearing

LMSUP 0.10 30.60

08/26/20 Correspondence with chambers regarding interim fee hearing and rescheduling October 26 hearing

LMSUP 0.10 30.60

08/26/20 Weekly team meeting with B. Dolphin (0.5); follow on with comments regarding additional deadlines (0.1).

TGGR 0.60 256.50

08/27/20 Various correspondence with Polsinelli team and chambers regarding rescheduling October 26 hearing

LMSUP 0.20 61.20

08/28/20 Review dockets, update critical dates memo and distribute; update calendar.

LMSUP 3.20 979.20

08/28/20 Review updated critical dates memo and comment on same. SMKAT 0.20 106.2008/31/20 Review second motion to extend exclusivity and confer with

Trinitee Green regarding same.ENBOY 0.10 71.00

SUBTOTAL FOR B110 Case Administration 17.10 $6,721.35

B120 Asset Analysis & Recovery

Date Description Initials Hours Amount08/10/20 Group meeting to prepare for auction. TGGR 0.50 $213.75SUBTOTAL FOR B120 Asset Analysis & Recovery 0.50 $213.75

B130 Asset Disposition & Sales

Date Description Initials Hours Amount08/01/20 Correspondence with T. Green regarding lien releases in

connection with construction lien claims related to Aldi's acquisition of Venice location.

ALTER 0.50 $204.75

08/03/20 Review description of general contractors and subcontractors contained within the schedules

BADOL 1.50 637.50

08/03/20 Preparation for and call with T. Greene regarding treatment of lien claims in connection with Aldi sales.

ALTER 0.60 245.70




September 9, 20201839103

106414-646376

Page Number 4

Date Description Initials Hours Amount08/03/20 Call with Aldi counsel regarding status of deal negotiations on

Cape Coral, Clearwater and Neptune Beach.ALTER 0.60 245.70

08/03/20 Finalized Publix closing binder and circulated to Lucky's team for inclusion in records.

ALTER 1.30 532.35

08/03/20 Correspondence with Oryana counsel regarding TVC flooding events.

ALTER 0.10 40.95

08/03/20 Correspondence with Aldi counsel regarding status of offers on Neptune, Coral Springs and Cape Coral

ALTER 0.10 40.95

08/03/20 Continued preparation of Aldi sale transaction closing binder. ALTER 0.20 81.9008/03/20 Preparation for and call with T. Green and J. Galaz (A&M)

regarding treatment of mechanic's liens on Kroger guaranteed leases.

ALTER 0.90 368.55

08/03/20 Correspondence with T. Green regarding details of Case Contracting M&M lien.

ALTER 0.50 204.75

08/03/20 Review CBRE update on Panama City and correspondence re same

CAWAR 0.10 80.00

08/04/20 Preparation for and call with LMPC professionals regarding asset sales (Panama City, Neptune Beach, Cape Coral, Clearwater), Bonita Springs SEG litigation process, claims reconciliations, and contract rejections.

ALTER 1.30 532.35

08/04/20 Preparation of M&M lien spreadsheet for all Aldi sales (completed and prospective).

ALTER 0.70 286.65

08/04/20 Weekly teleconference with Lucky's professionals regarding remaining asset sales, SEG litigation, claims reconciliations, and contract rejections.

ENBOY 1.00 710.00

08/04/20 Correspondence with counsel to Schnucks and Polsinelli core team Re closing issues

CAWAR 0.10 80.00

08/05/20 Request court reporter for August 12 auction; correspondence regarding same.

LMSUP 0.20 61.20

08/06/20 Correspondence with C. Ward regarding logistics for virtual auction

LMSUP 0.20 61.20

08/06/20 Correspondence with B. Dolphin regarding Snyder lien releases in connection with Fort Myers location. Review of files for same.

ALTER 0.40 163.80

08/06/20 Correspondence with C. Ward regarding update on Bonita Springs and Panama City sale status.

ALTER 0.10 40.95

08/06/20 Correspondence with Committee counsel re ALDI interest, correspondence with Polsinelli core team re same

CAWAR 0.20 160.00

08/06/20 Correspondence with Lindsey Suprum re court reporter for virtual auction

CAWAR 0.10 80.00

08/06/20 Correspondence with Debtors and their professionals re Panama City Auction, set up Zoom auction room and discuss logistics

CAWAR 0.40 320.00

08/06/20 Correspondence with client team and professionals re sale of liquor licenses

CAWAR 0.10 80.00




September 9, 20201839103

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Page Number 5

Date Description Initials Hours Amount08/06/20 Correspondence with Caryn Wang re Panama City auction

outlineCAWAR 0.10 80.00

08/07/20 Correspondence with Reliable regarding court reporter assigned for August 12 auction

LMSUP 0.10 30.60

08/07/20 Confer with Chris Ward regarding drafting a motion to approve the private sale of a Bloomington liquor license

BADOL 0.10 42.50

08/07/20 Correspondence with Debtors and their professionals re Panama City auction

CAWAR 0.10 80.00

08/07/20 Correspondence with client team and professionals re sale of Bloomington liquor license, review and comment on sale agreement, correspondence with Polsinelli core team re drafting sale motion

CAWAR 0.40 320.00

08/10/20 Draft notice of virtual auction and correspondence with C. Ward and L. Suprum regarding same (0.7).

CEWAN 0.70 283.50

08/10/20 Discuss the recorded release of claim of lien received from Snyder Construction related to the Fort Myers store lease with counsel to Winn-Dixie

BADOL 0.10 42.50

08/10/20 Participate in Zoom meeting with Polsinelli core team regarding Panama City auction (.5); communications to and from CBRE team regarding Panama City bids and follow-up with Lucky's team (.2).

ENBOY 0.70 497.00

08/10/20 Correspondence with Aldi counsel regarding status of offer on Neptune, Clearwater and Cape Coral.

ALTER 0.10 40.95

08/10/20 Communicate with counsel to Snyder Construction regarding the recording of a release of lien against the Fort Myers location as part of the Winn-Dixie sale (.2); provide recorded release of lien form to Chris Ward, Amanda Terr, and Trinitee Green (.2)

BADOL 0.40 170.00

08/10/20 Discussion with Andy Pillari, Maria Woods, A&M, CBRE and Polsinelli teams about Panama City assets and bidding

BADOL 0.40 170.00

08/10/20 Call with M. Woods regarding status of Panama City bids, Neptune Beach hearing, Aldi interest in Clearwater and Cape Coral locations.

ALTER 0.50 204.75

08/10/20 Receipt and review of Panama City bid package and PSA from Mobama LLC. Correspondence with M. Woods regarding same.

ALTER 0.70 286.65

08/10/20 Lucky's team meeting prep in anticipation of Panama City Auction.

ALTER 0.50 204.75

08/10/20 Receipt and review of Snyder Construction lien release recorded in connection with the Ft Myers location. Correspondence with SEG counsel and B. Dolphin regarding necessity of corrective instrument related to same.

ALTER 0.60 245.70

08/10/20 Participate in team meeting to address open issues re Panama City auction.

SMKAT 0.50 265.50

08/10/20 Correspondence with Caryn Wang re auction rules CAWAR 0.10 80.00




September 9, 20201839103

106414-646376

Page Number 6

Date Description Initials Hours Amount08/10/20 Correspondence with CBRE team re Panama City bids,

correspondence with Debtors and their professionals re same, correspondence with counsel to Committee, correspondence with counsel to Kroger, reach out to interested parties

CAWAR 0.50 400.00

08/10/20 Participate in Zoom meeting with Polsinelli core team to discuss open issues and Panama City auction

CAWAR 0.50 400.00

08/10/20 Review bid package from interested party CAWAR 0.40 320.0008/10/20 Correspondence with Debtors and their professionals re Neptune

Beach zoning hearingCAWAR 0.10 80.00

08/11/20 Coordinate logistics for August 12 virtual auction LMSUP 0.30 91.8008/11/20 Review, revise, finalize, file and serve notice of virtual auction;

correspondence regarding same.LMSUP 0.40 122.40

08/11/20 Draft, finalize and file certificate of no objection regarding private sale motion; finalize and upload proposed order; correspondence regarding same.

LMSUP 0.90 275.40

08/11/20 Preparation for and call with LMPC professionals regarding Panama City auction; Neptune Beach hearing; Bonita Springs litigation; remaining asset sales; claims reconciliations.

ALTER 1.30 532.35

08/11/20 Draft motion to approve private sale of liquor permit (Bloomington) and proposed form of order

BADOL 3.00 1,275.00

08/11/20 Prepare to attend the virtual Panama City auction and review information related to received bids and auction rules

BADOL 1.60 680.00

08/11/20 Discuss motion to approve private sale of liquor license (Ann Arbor) with Chris Ward (.1); provide draft motion to counsel for the prepetition secured lender (.2) and counsel to the purchaser (.2) for review and comment

BADOL 0.50 212.50

08/11/20 Communicate with counsel to Snyder Construction (.2) regarding recorded release of claim of lien against the Fort Myers store lease sold to Winn-Dixie; review the recorded release of lien (.1); provide recorded release of lien to counsel for Winn-Dixie (.2); update counsel to Snyder Construction with request related to re-recording the release of claim of lien (.2)

BADOL 0.70 297.50

08/11/20 Review of Panama City APA terms in preparation for auction. ALTER 1.10 450.4508/11/20 Receipt and review of Panama City Auction Rules. ALTER 0.50 204.7508/11/20 Call with Aldi counsel regarding Kroger assumption of its

guaranteed leases.ALTER 0.50 204.75

08/11/20 Correspondence with counsel to MBD re August 12 virtual auction

CAWAR 0.10 80.00

08/11/20 Correspondence with Polsinelli core team re no responses to private vehicle sale motion and copy of Certificate of No Objection

CAWAR 0.20 160.00

08/11/20 Draft outline for presentation at Panama City auction CAWAR 0.50 400.0008/11/20 Correspondence with buyer and Polsinelli core team re motion to

sell liquor licenseCAWAR 0.10 80.00




September 9, 20201839103

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Page Number 7

Date Description Initials Hours Amount08/11/20 Correspondence with Debtors and their professionals re Panama

City auction logisticsCAWAR 0.10 80.00

08/11/20 Review and comment on draft of notice of virtual auction, correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.40 320.00

08/11/20 Correspondence with client team and professionals re Neptune Beach zoning hearing and issues

CAWAR 0.10 80.00

08/11/20 Correspondence with Lindsey Suprum re court reporter for auction

CAWAR 0.10 80.00

08/11/20 Correspondence with client team and Polsinelli core team re motion to sell liquor license

CAWAR 0.10 80.00

08/11/20 Correspondence with counsel to Kroger and Brenna Dolphin re motion to sell liquor license

CAWAR 0.10 80.00

08/12/20 Attend virtual auction for Panama City property (0.5); draft notice of successful bidder for same (1.1); begin drafting CBRE declaration in support of Panama City Sale Motion (0.7); revise sale order to reflect outcome of auction (2.1).

CEWAN 3.90 1,579.50

08/12/20 Review, revise, finalize, file and serve notice of successful bidder; correspondence regarding same.

LMSUP 0.40 122.40

08/12/20 Prepare for, discussions with consultation parties, and participate in Panama City auction.

ENBOY 0.70 497.00

08/12/20 Attend virtual auction of Panama City assets BADOL 0.90 382.5008/12/20 Receipt and review of Aldi's diligence request pertaining to

Clearwater, Neptune and Cape Coral. Consolidation of resources and responses to same.

ALTER 2.40 982.80

08/12/20 Review of MBD Exhibits to PSA and preparation of outstanding items list. Correspondence with M. Woods and A. Pillari regarding same.

ALTER 1.00 409.50

08/12/20 Correspondence with Neptune Beach City Council regarding CDB meeting agenda. Subsequent discussion with LMPC professionals regarding same.

ALTER 1.30 532.35

08/12/20 Preparation for and attendance of Lucky's Panama City auction. ALTER 1.60 655.2008/12/20 Review outcome correspondence re sale of Panama City

location.SMKAT 0.10 53.10

08/12/20 Review and comment on draft Notice of Successful Bidder, correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.50 400.00

08/12/20 Participate in and host Panama City virtual auction CAWAR 1.50 1,200.0008/12/20 Review Order (I) Authorizing the Private Sale of Certain of the

Debtors' Assets Free and Clear of All Liens, Claims, Encumbrances and Interests, (II) Authorizing the Assumption and Assignment of Contracts and Leases, and (III) Granting Related Relief (VW Credit Leasing, LTD)

CAWAR 0.10 80.00

08/12/20 Finalize notes and prepare for Panama City virtual auction CAWAR 0.50 400.00




September 9, 20201839103

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Page Number 8

Date Description Initials Hours Amount08/12/20 Correspondence with successful bidder and Debtors'

professionals re additional deposit and closingCAWAR 0.10 80.00

08/12/20 Draft email update to special committee re Panama City sale and plan and disclosure statement, correspondence with special committee, client team, and professionals re same

CAWAR 0.20 160.00

08/12/20 Correspondence with client team and Polsinelli core team re Neptune Beach situation and related issues

CAWAR 0.20 160.00

08/12/20 Correspondence with bidder re auction logistics CAWAR 0.10 80.0008/13/20 Continue drafting CBRE declaration in support of Panama City

Sale Motion (2.5).CEWAN 2.50 1,012.50

08/13/20 Discussion with A&M team regarding prepaid deposits incorporated into MBD PSA.

ALTER 0.20 81.90

08/13/20 Confer with Chris Ward and Amanda Terr regarding the Neptune Beach store lease

BADOL 0.30 127.50

08/13/20 Call with Aldi counsel regarding tentative offer on Lucky's locations.

ALTER 0.40 163.80

08/13/20 Correspondence with B. Dolphin regarding status of Neptune Beach stipulation and transaction

ALTER 0.20 81.90

08/13/20 Correspondence with M. Woods and Neptune Beach landlord regarding Neptune Beach city council meeting.

ALTER 0.60 245.70

08/13/20 Call with MBD counsel regarding revised APA terms. ALTER 0.30 122.8508/13/20 Correspondence with C. Wang regarding Panama City sale

hearing and order. Brief review of same.ALTER 0.40 163.80

08/13/20 Call with Aldi counsel regarding interest in Clearwater and Coral Springs properties

ALTER 0.50 204.75

08/13/20 Review and comment on draft Neil Kelly declaration in support of Panama City sale

CAWAR 0.50 400.00

08/13/20 Correspondence with Caryn Wang re Panama City sale order CAWAR 0.10 80.0008/13/20 Correspondence with counsel to MBD and Polsinelli core team

re APA and sale orderCAWAR 0.10 80.00

08/13/20 Review and comment on draft clean and redline Panama City sale order, correspondence with purchaser's counsel, correspondence with Committee counsel, correspondence with counsel to Kroger, correspondence with Polsinelli core team

CAWAR 0.50 400.00

08/13/20 Review transcript from virtual auction and correspondence re same

CAWAR 0.40 320.00

08/13/20 Correspondence with client team and Polsinelli core team re Neptune Beach situation

CAWAR 0.10 80.00

08/14/20 Correspondence with C. Ward regarding status of filing declaration of proposed order for Panama City sale

LMSUP 0.10 30.60

08/14/20 Receipt of Aldi offer for Cape Coral and Clearwater locations. Call with Aldi regarding same. Subsequent discussion with LMPC professionals and Kroger regarding deal terms.

ALTER 1.20 491.40




September 9, 20201839103

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Page Number 9

Date Description Initials Hours Amount08/14/20 Provide order approving private sale of motor vehicle and

assignment of motor vehicle leases to Andy Pillari and Maria Woods for closing

BADOL 0.20 85.00

08/14/20 Correspondence with M. Woods regarding Neptune Beach transaction strategy.

ALTER 0.30 122.85

08/14/20 Revised MBD Properties PSA per auction results and circulated to Buyer for review.

ALTER 0.60 245.70

08/14/20 Review bid for 2 store locations, correspondence with Debtors and their professionals, correspondence with counsel to Kroger

CAWAR 0.40 320.00

08/14/20 Correspondence re MBD closing CAWAR 0.10 80.0008/14/20 Review and comment on further revised CBRE declaration in

support of Panama City sale and correspondence with Debtors and their professionals re same

CAWAR 0.50 400.00

08/14/20 Correspondence with Debtors and their professionals re Neptune Beach community development meeting

CAWAR 0.10 80.00

08/14/20 Correspondence with CBRE team and Polsinelli core team re Panama City sale declaration

CAWAR 0.10 80.00

08/14/20 Correspondence with client team and professionals re VW vehicle sale order and closing

CAWAR 0.10 80.00

08/17/20 Correspondence with Polsinelli core team regarding Panama City Sale Order, preparation for hearing, and status of Panama City APA (0.2).

CEWAN 0.20 81.00

08/17/20 Review, finalize, file and serve declaration in support of Panama City sale; correspondence regarding same.

LMSUP 0.40 122.40

08/17/20 Draft, finalize and file certification of counsel regarding Panama City sale order; finalize and upload proposed order with the Court; various correspondence regarding same.

LMSUP 1.50 459.00

08/17/20 Correspondence with B. Dolphin and L. Suprum regarding filing of MBD Properties PSA alongside sale order. Correspondence and call with MBD counsel regarding same. Finalized and compiled fully executed agreement and circulated to all parties.

ALTER 1.00 409.50

08/17/20 Correspondence with K. Noone and A. Pillari regarding Aldi Clearwater diligence request. Initial review of Clearwater lease agreement.

ALTER 0.80 327.60

08/17/20 Review certification of counsel regarding the Panama City sale order before submitting it to the Court

BADOL 0.10 42.50

08/17/20 Correspondence with CBRE team re August 17 hearing CAWAR 0.10 80.0008/17/20 Review and comment on final draft of Neil Kelly declaration in

support of Panama City sale, correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.40 320.00

08/17/20 Correspondence with Debtors and their professionals re ALDI bid

CAWAR 0.10 80.00

08/17/20 Correspondence with client team and professionals re sale of vehicles

CAWAR 0.10 80.00




September 9, 20201839103

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Page Number 10

Date Description Initials Hours Amount08/17/20 Review and comment on amended agenda for August 17

hearing, correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.40 320.00

08/17/20 Correspondence with Committee counsel re ALDI bid CAWAR 0.10 80.0008/17/20 Review and comment on draft certification of counsel re Panama

City sale order, correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.40 320.00

08/17/20 Review updated MBD purchase agreement and correspondence re same

CAWAR 0.10 80.00

08/17/20 Correspondence with special committee re court approval of Panama City sale

CAWAR 0.10 80.00

08/17/20 Review email memo to special committee re ALDI bid and correspondence re same

CAWAR 0.10 80.00

08/18/20 Correspondence with Lucky's team regarding Aldi's Clearwater diligence request. Compilation of same.

ALTER 0.80 327.60

08/18/20 Preparation for and call with LMPC professionals regarding APA asset sales, claims reconciliations, contract rejections, and Lucky's transition.

ALTER 1.20 491.40

08/18/20 Review of Clearwater and Cape Coral leases for landlord information. Sent same to B. Dolphin.

ALTER 0.30 122.85

08/18/20 Correspondence with Debtors and their professionals re ALDI bid

CAWAR 0.10 80.00

08/18/20 Review Order (I) Approving the Sale of Certain of the Debtors Assets Free and Clear of All Liens, Claims, Encumbrances, and Interests, and (II) Granting Related Relief

CAWAR 0.10 80.00

08/18/20 Correspondence with A&M team and counsel to Kroger re ALDI bid

CAWAR 0.10 80.00

08/19/20 Communicate with Lindsey Suprum regarding expected motion to approve the private sale of the Cape Coral lease and the Clearwater lease and filing date

BADOL 0.10 42.50

08/19/20 Correspondence with LMPC professionals regarding M&M liens in connection with Aldi offer on Clearwater and Cape Coral,

ALTER 0.60 245.70

08/19/20 Call with Aldi counsel to discuss deal mechanics and terms regarding Cape Coral and Clearwater offer. Subsequent discussion with LMPC professionals regarding timing of same.

ALTER 1.00 409.50

08/19/20 Correspondence with B. Dolphin and C. Ward regarding disclosures to Clearwater landlord in connection with Aldi deal.

ALTER 0.20 81.90

08/19/20 Compilation and review of Clearwater and Cape Coral diligence in connection with Aldi request. Correspondence with Aldi counsel and Lucky's team regarding same.

ALTER 1.90 778.05

08/19/20 Call with R. Lawlor (HillCo) regarding strategy for assignment of Clearwater and Cape Coral leases to Aldi.

ALTER 0.70 286.65

08/19/20 Correspondence with MBD Properties counsel regarding closing mechanics and timeframe in connection with Panama City.

ALTER 0.40 163.80




September 9, 20201839103

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Page Number 11

Date Description Initials Hours Amount08/19/20 Call with M. Woods regarding status of Neptune, Clearwater and

Cape Coral sales; status of MBD closing and status of Louisville litigation.

ALTER 0.60 245.70

08/19/20 Communicate with Chris Ward and Amanda Terr regarding strategy and time line for private sale motion related to Cape Coral lease and Clearwater lease

BADOL 0.60 255.00

08/19/20 Correspondence with Amanda Terr re ALDI strategy CAWAR 0.10 80.0008/19/20 Correspondence with buyer and client and professionals re liquor

license saleCAWAR 0.10 80.00

08/19/20 Correspondence with client team and professionals re sale strategy with ALDI

CAWAR 0.10 80.00

08/19/20 Correspondence with Debtors and their professionals re ALDI offer

CAWAR 0.10 80.00

08/19/20 Correspondence with Philco and Debtors' professionals re ALDI issues

CAWAR 0.10 80.00

08/19/20 Correspondence with counsel to ALDI and Debtors team re revised offer

CAWAR 0.10 80.00

08/20/20 Correspondence with B. Dolphin regarding updated status of filing of Aldi private sale motion

LMSUP 0.10 30.60

08/20/20 Call with R. Lawlor (Hilco) regarding status of Clearwater and Cape Coral assignment to Aldi.

ALTER 0.40 163.80

08/20/20 Discuss deal structure with Chris Ward and Amanda Terr related to the possible sale of the Cape Coral lease and Clearwater lease to Aldi

BADOL 0.40 170.00

08/20/20 Begin drafting motion to approve private sale of the Clearwater and Cape Coral store leases to Aldi

BADOL 3.50 1,487.50

08/20/20 Correspondence with counsel for MBD Properties regarding timing of transaction closing. Receipt and review of corporate documents and newly formed LLC assignment agreement.

ALTER 0.30 122.85

08/20/20 Call with Aldi counsel regarding assignment and purchase agreement for Cape Coral and Clearwater. Subsequent review and revision of same.

ALTER 1.50 614.25

08/20/20 Preparation for and call with Aldi counsel regarding strategy for assignment and sale of Clearwater and Cape Coral leases. Subsequent discussion regarding format of assignment and purchase agreement for same.

ALTER 1.40 573.30

08/20/20 Preparation for and call with counsel for MBD properties regarding Panama City closing items, mechanics and timing.

ALTER 1.40 573.30

08/20/20 Correspondence with Lucky's team regarding Coral Springs tax reconciliation. Review of Aldi APA for treatment of same.

ALTER 0.40 163.80

08/20/20 Correspondence with Brenna Dolphin re ALDI sale motion CAWAR 0.10 80.0008/20/20 Conference call with counsel to ALDI and Debtors and their

professionals re assumption and assignment to ALDI of Cape Coral and Clearwater

CAWAR 0.50 400.00




September 9, 20201839103

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Page Number 12

Date Description Initials Hours Amount08/20/20 Correspondence with client team and professionals re Panama

City closingCAWAR 0.10 80.00

08/21/20 Communicate and discuss potential cure amounts related to the Cape Coral lease and Clearwater lease and the motion to approve a private sale to Aldi with Chris Ward, Amanda Terr ,and Jonah Galaz (1.5); review cure schedules provided by Jonah Galaz (.3)

BADOL 1.80 765.00

08/21/20 Discussion with J. Galaz regarding cure costs associated with Clearwater and Cape Coral properties.

ALTER 0.40 163.80

08/21/20 Discuss draft lease amendments and assignment agreements received from Aldi with Amanda Terr

BADOL 0.80 340.00

08/21/20 Continue drafting motion to approve private sale of two lease agreements to Aldi and proposed form of order

BADOL 4.50 1,912.50

08/21/20 Discussion with LMPC team regarding back-up bidder allocation for Clearwater and Cape Coral leases.

ALTER 0.70 286.65

08/21/20 Receipt and review of Debtors initial disclosure in Winn-Dixie litigation (Bonita Springs).

ALTER 0.70 286.65

08/21/20 Discussion with Aldi counsel regarding revisions to assignment and assumption agreement.

ALTER 0.60 245.70

08/21/20 Receipt and review of Aldi Assignment and Assumption Agreement. Revision of same and subsequent call with M. Woods

ALTER 2.40 982.80

08/21/20 Receipt and review of Aldi's Cape Coral and Clearwater lease amendments

ALTER 0.80 327.60

08/21/20 Call with B. Dolphin regarding terms of Aldi assignment agreement in relation to lease agreements.

ALTER 0.50 204.75

08/21/20 Receipt and review of Sanitas revisions to Orlando NDA. ALTER 0.50 204.7508/21/20 Extensive review and revisions to motion to approve sale and

assumption and assignment of Cape Coral and Clearwater leases to Kroger and order approving same, correspondence with client team and A&M, correspondence with Polsinelli core team, correspondence with counsel to ALDI, correspondence with counsel to Kroger

CAWAR 1.50 1,200.00

08/21/20 Correspondence with client team and professionals re ALDI situation

CAWAR 0.10 80.00

08/21/20 Review ALDI draft of assumption and assignment agreement and correspondence with Polsinelli core team re revisions

CAWAR 0.40 320.00

08/22/20 Call with M. Woods regarding Aldi assumption of Clearwater and Cape Coral leases and further revision of same. Circulated to Aldi for comment.

ALTER 1.30 532.35

08/22/20 Receipt review and revision of Aldi (Cape Coral/Clearwater) Lease Assignments, Lease Amendments and Guaranties. Circulated same to M. Woods and Kroger team for further review and comment.

ALTER 2.90 1,187.55




September 9, 20201839103

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Page Number 13

Date Description Initials Hours Amount08/22/20 Receipt and review of Aldi's proposed amendments to

Clearwater and Cape Coral leases. Correspondence with Aldi counsel and B. Dolphin regarding circulation to landlords.

ALTER 0.40 163.80

08/22/20 Review further revised ALDI Assumption and Assignment Agreement, correspondence with Polsinelli core team re same, correspondence with counsel to Kroger re same, correspondence with counsel to ALDI re same

CAWAR 0.40 320.00

08/22/20 Correspondence with counsel to Kroger and Polsinelli core team re SPE entity that will take assignment of the leases

CAWAR 0.10 80.00

08/23/20 Confer with Maria Woods, Andy Pillari, Chris Ward and Amanda Terr regarding the draft motion to approve private sale of the Cape Coral and Clearwater lease to Aldi (.5); revise draft motion (.3); circulate revised draft (.2)

BADOL 1.00 425.00

08/23/20 Receipt of Clearwater and Cape Coral assignment agreements from Aldi. Correspondence with Aldi counsel regarding same.

ALTER 0.40 163.80

08/23/20 Discussion with Kroger and Lucky's team regarding Aldi assignment agreement deadlines (Cape Coral and Clearwater) and terms.

ALTER 2.00 819.00

08/24/20 Revise and finalize motion to approve private sale of the Cape Coral lease and Clearwater lease to Aldi to include comments received from Kroger and Aldi, the proposed form of order approving the private sale, the assigned leases exhibit, and the cure amount exhibit

BADOL 5.00 2,125.00

08/24/20 Draft notice for filing with Aldi private sale motion; review, revise, finalize, file and serve motion; various correspondence regarding same.

LMSUP 1.20 367.20

08/24/20 Receipt, review and revision of Cape Coral and Clearwater assignments to Aldi. Preparation and circulation of issues list regarding same.

ALTER 1.20 491.40

08/24/20 Provide recorded Release of Claim of Lien received from counsel to Snyder Construction to counsel for Winn-Dixie, the purchaser of the Fort Myers store lease

BADOL 0.10 42.50

08/24/20 Preparation for and call with Kroger counsel and LMPC team regarding assumption of Kroger guaranteed leases and Aldi sale motion.

ALTER 0.60 245.70

08/24/20 Participate on conference call with the Aldi legal team to discuss the private sale motion and Cape Coral and Clearwater store leases

BADOL 0.20 85.00

08/24/20 Review, revise, and finalize the stipulation with the Neptune Beach landlord, the certification of counsel, and proposed form of order approving stipulation to extend the deadline by which the debtors must assume or reject the Neptune Beach lease

BADOL 0.40 170.00

08/24/20 Correspondence with C. Ward and Kroger counsel regarding flexibility of entities paying Cape Coral and Clearwater cure costs. Revised assignment agreements to account for this concept. Circulated same.

ALTER 1.10 450.45




September 9, 20201839103

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Page Number 14

Date Description Initials Hours Amount08/24/20 Ongoing discussion with LMPC team regarding open items in

Aldi assignment agreements and sale motion; lease rejections and assignments to Kroger.

ALTER 0.90 368.55

08/24/20 Receipt and review of Kroger and Aldi comments to Aldi sale motion. Discussion with M. Woods, B. Dolphin, LMPC team, and Aldi counsel regarding same.

ALTER 2.50 1,023.75

08/24/20 Review of Cape Coral and Clearwater Lease Amendments in connection with Aldi assignment. Correspondence with B. Dolphin regarding landlord's comments to same.

ALTER 0.30 122.85

08/24/20 Preparation for and call with Aldi counsel regarding Clearwater and Cape Coral assignments and sale motions. Subsequent revision and circulation of same.

ALTER 2.00 819.00

08/24/20 Correspondence with LMPC team regarding lease rejection documents and Aldi's assignment language to be included in the Sale Motion for Clearwater and Cape Coral.

ALTER 0.70 286.65

08/24/20 Correspondence with Aldi counsel regarding Clearwater and Cape Coral sale motion update. Subsequent correspondence with B. Dolphin regarding lease amendments and guaranties for same.

ALTER 0.50 204.75

08/24/20 Receipt and review of Snyder Construction lien release related to Ft. Myers property leased to SEG.

ALTER 0.10 40.95

08/24/20 Review ALDI's comments to sale and assumption motion and correspondence with all parties re same

CAWAR 0.40 320.00

08/24/20 Review and comment on issues list for ALDI assignment and correspondence re same

CAWAR 0.20 160.00

08/24/20 Final review of ALDI sale motion, exhibits, and order, correspondence with all parties re same, review filed copy

CAWAR 0.50 400.00

08/25/20 Discussion with Publix counsel regarding Neptune Beach stipulation serving to extend the 365(d)(4) lease rejection deadline.

ALTER 0.80 327.60

08/25/20 Read communication from counsel to Captive-Aire regarding two alleged construction liens asserted against the Cape Coral leasehold interest and Clearwater leasehold interest, which are the subject of the motion to approve the private sale of each to Aldi

BADOL 0.30 127.50

08/25/20 Call with M. Woods regarding status of Panama City closing to MBD Properties.

ALTER 0.50 204.75

08/25/20 Review and revision of Beall's tenant estoppel certificate. Correspondence with Beall's team regarding revisions and execution of same.

ALTER 1.10 450.45

08/25/20 Circulated filed stamped Aldi sale motion to Aldi counsel. Subsequent correspondence regarding strategy for next steps, landlord, and architect communications.

ALTER 1.00 409.50

08/25/20 Preparation for and call with LMPC professionals regarding asset sales, contract rejections, and claims reciliations.

ALTER 0.90 368.55




September 9, 20201839103

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Page Number 15

Date Description Initials Hours Amount08/25/20 Correspondence with counsel to ALDI and Polsinelli core team

re sale motionCAWAR 0.10 80.00

08/25/20 Review CBRE invoice for Panama City sale CAWAR 0.10 80.0008/26/20 Review of tax invoices, receipts, lease and use agreements.

Subsequent reparation, review and finalization of Panama City closing statement based. Discussion with LMPC professionals regarding same.

ALTER 2.20 900.90

08/26/20 Review of Clearwater lease to determine proper site addresses in light of Captive-Aire lien discrepancy. Correspondence with B. Dolphin regarding same.

ALTER 0.40 163.80

08/26/20 Respond to email from counsel to Captive-Aire about cure amounts and store leases, which comprise the subject matter of the motion to approve the private sale of two store leases, Cape Coral and Clearwater, to Aldi

BADOL 0.10 42.50

08/26/20 Read the demand for adequate assurance of future performance made by Dania Live 1748, LLC related to the motion to assume and assign certain store leases to Kroger

BADOL 0.20 85.00

08/26/20 Confer internally with Amanda Terr regarding issues raised by counsel to Captive-Aire related to the motion to approve the private sale of the Cape Coral lease and the Clearwater lease to Aldi (.2); review the first amendment to the Clearwater lease agreement (.1)

BADOL 0.30 127.50

08/26/20 Receipt and review of finalized tenant estoppel from Beall's counsel. Correspondence with LMPC team regarding same.

ALTER 0.20 81.90

08/26/20 Correspondence with Beall's team regarding tenant estoppel certificate.

ALTER 0.20 81.90

08/26/20 Preparation and revision of assignment agreements, special warranty deed, FIRPTA affidavit, and seller and buyers certificates ahead of Panama City closing with MBD. Circulation to all parties and subsequent discussion with M. Woods regarding same.

ALTER 3.00 1,228.50

08/26/20 Call with MBD counsel regarding closing documents for Panama City transaction. Circulated same to Lucky's for signature.

ALTER 0.50 204.75

08/26/20 Continued correspondence with MBD counsel regarding Panama City closing documents and signature blocks. Subsequent correspondence with M. Woods regarding warranty assignment at the location.

ALTER 0.90 368.55

08/26/20 Correspondence with Debtors and their professionals re Neptune Beach extension

CAWAR 0.10 80.00

08/26/20 Correspondence with Debtors' and their professionals re Panama City closing, correspondence with escrow agent. discuss closing sheet and open issues

CAWAR 0.50 400.00

08/27/20 Finalized and circulated Panama City closing statement for review and execution.

ALTER 0.20 81.90

08/27/20 Compilation of Panama City closing documents and signatures. Circulation of same.

ALTER 1.50 614.25




September 9, 20201839103

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Page Number 16

Date Description Initials Hours Amount08/27/20 Call with M. Woods regarding status of Panama City closing and

Publix's Neptune Beach APA extension.ALTER 0.50 204.75

08/27/20 Summarize questions and issues raised by Captive-Aire related to the motion to approve the private sale of the Cape Coral lease and the Clearwater lease to Aldi and provide summary to Jonah Galaz, Amanda Terr, and Chris Ward

BADOL 0.80 340.00

08/27/20 Communicate internally with Chris Ward, Shanti Katona, Caryn Wang, and Amanda Terr regarding outstanding items needed to close the Panama City sale to M.B.D.

BADOL 0.20 85.00

08/27/20 Respond to communication received from counsel to Captive-Aire regarding the motion to assume and assign the Cape Coral lease and the Clearwater lease to Aldi (.4); request information related to asserted construction liens (.1); review paperwork provided by Captive-Aire (.4)

BADOL 0.90 382.50

08/27/20 Finalized and circulated Panama City closing statement and authorizing resolution to Buyer.

ALTER 0.40 163.80

08/27/20 Preparation of Panama City Lease Termination Agreement between LMOC and LMPC. Circulated same to M. Woods for comment.

ALTER 1.00 409.50

08/27/20 Call with MBD counsel regarding closing logistics, UCC filings, closing statement, and Lucky's authorizing documents.

ALTER 0.60 245.70

08/27/20 Review of Lucky's organizational documents and Panama City sale order and motion. Subsequent preparation of special committee authorizing resolution for Panama City sale to MBD.

ALTER 1.10 450.45

08/27/20 Review of Lucky's previous UCC filings. Preparation of UCC termination statement for Panama City transaction.

ALTER 1.30 532.35

08/27/20 Finalized and fully compiled all Panama City transaction documents. Circulated same and sent originals to Buyer's counsel. Correspondence with LMPC and Buyer's team regarding closing logistics.

ALTER 0.90 368.55

08/27/20 Receipt and review of Panama City UCC statement. Correspondence with C. Ward and Buyer's counsel regarding resolution of same.

ALTER 0.60 245.70

08/27/20 Advise A. Terr on authorizing resolutions re Panama City sale closing.

SMKAT 0.30 159.30

08/27/20 Correspondence with counsel to Kroger and Polsinelli core team Re Panama City closing and termination statement

CAWAR 0.10 80.00

08/27/20 Review and comment on draft board resolution for Panama City sale and correspondence re same

CAWAR 0.40 320.00

08/27/20 Correspondence with Debtors and their professionals re Panama City closing

CAWAR 0.10 80.00

08/27/20 Review proposed UCC-3 termination statement for Panama City and correspondence re same

CAWAR 0.20 160.00

08/27/20 Review final Panama City closing statement and correspondence with client team and professionals re same

CAWAR 0.40 320.00




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Date Description Initials Hours Amount08/27/20 Correspondence with all parties re Panama City location and

confirm closingCAWAR 0.40 320.00

08/28/20 Revision of Panama City Lease Termination Agreement. ALTER 0.60 245.7008/28/20 Respond to inquiry from counsel to landlord SB-VETS-1, LLC

regarding the motion to approve the private sale of two store leases, including the Cape Coral lease, to Aldi

BADOL 0.60 255.00

08/28/20 Receipt and review of 10th addendum to Publix APA. Correspondence with M. Woods regarding same.

ALTER 0.60 245.70

08/28/20 Receipt, review and revision of the asset sale provisions within the LMPC Disclosure Statement. Correspondence with T. Green regarding same.

ALTER 1.80 737.10

08/28/20 Correspondence with counsel to landlord and Brenna Dolphin re LAID sale motion

CAWAR 0.10 80.00

08/28/20 Correspondence with client team and professionals re extension of Publix deadlines on Neptune Beach and review draft 10th amendment to Publix APA

CAWAR 0.40 320.00

08/29/20 Continued review and revision of asset sale related sections of LMPC disclosure statement.

ALTER 1.50 614.25

08/29/20 Research regarding obligations and defenses of primary and secondary guarantors in relation to replacement Aldi guaranty.

ALTER 0.40 163.80

08/29/20 Receipt and review of 10th Addendum to Publix APA. Correspondence with S. Lieb (Publix counsel) regarding same.

ALTER 0.40 163.80

08/30/20 Read update from Jonah Galaz regarding the motion to approve private sale of the Cape Coral lease and the Clearwater lease to Aldi and information about the Captive-Aire cure amounts

BADOL 0.30 127.50

08/30/20 Review final draft of 10th amendment to Publix APA, correspondence with client team and professionals re same, review executed copy

CAWAR 0.40 320.00

08/31/20 Respond to inquiry from counsel to Captive-Aire regarding the motion to approve private sale of the Cape Coral lease and Clearwater lease to Aldi

BADOL 0.80 340.00

08/31/20 Correspondence with CBRE team regarding release of escrow funds in conjunction with Panama City sale. Preparation of escrow release letter accounting for same. Circulated to Signature Bank.

ALTER 0.90 368.55

08/31/20 Review communication from counsel to GLL Selection II Florida LP related to the North Naples store lease and motion to assume and assign same to Kroger LM (.2); communicate internally with Andy Pillari, Kathy Noone, and Kristin Froehlich regarding cure (.3)

BADOL 0.50 212.50

08/31/20 Correspondence with YCST team re Kroger assumption motion CAWAR 0.10 80.0008/31/20 Correspondence with counsel to Captive-Aire and Brenna

Dolphin re revised proposed form of sale orderCAWAR 0.10 80.00

08/31/20 Correspondence with Polsinelli core team re escrow release letter

CAWAR 0.10 80.00




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Date Description Initials Hours Amount08/31/20 Review escrow release letter to Signature Bank and

correspondence re sameCAWAR 0.20 160.00

SUBTOTAL FOR B130 Asset Disposition & Sales 160.20 $74,943.95

B140 Relief from Stay/Adequate Protection Proceedings

Date Description Initials Hours Amount08/04/20 Review Certification of Counsel with Respect to Agreed Order in

Connection with Motion of Doris Baugh and Roy Baugh for Relief from the Automatic Stay and order approving same

CAWAR 0.20 $160.00

08/04/20 Correspondence with John Demmy re lift stay order CAWAR 0.10 80.0008/20/20 Correspondence with counsel to Salerno and Brenna Dolphin re

form of agreed stay relief orderCAWAR 0.10 80.00

08/20/20 Review Salerno motion for relief from stay and correspondence re same

CAWAR 0.20 160.00

SUBTOTAL FOR B140 Relief from Stay/Adequate Protection Proceedings 0.60 $480.00

B145 Court Hearings

Date Description Initials Hours Amount08/05/20 Correspondence with Lindsey Suprum re additional omnibus

hearing datesCAWAR 0.10 $80.00

08/07/20 Draft, finalize and file certification of counsel and order scheduling omnibus hearing date; upload proposed order; correspondence regarding same.

LMSUP 0.50 153.00

08/07/20 Review Certification of Counsel Regarding Scheduling of Omnibus Hearing Date and order approving same

CAWAR 0.20 160.00

08/12/20 Draft agenda for August 17 hearing LMSUP 1.70 520.2008/12/20 Review and comment on draft agenda for August 17 pretrial

conference.SMKAT 0.10 53.10

08/12/20 Correspondence with Chambers and Polsinelli core team re re-scheduling hearing dates

CAWAR 0.10 80.00

08/13/20 Revise, finalize, file and serve agenda for August 17 hearing; correspondence regarding same; add hyperlinks to pleadings on agenda and email to chambers per the Court order re: cessation of all hand deliveries.

LMSUP 1.20 367.20

08/13/20 Further comment on revised agenda for August 17 pretrial conference.

SMKAT 0.10 53.10

08/13/20 Correspondence with Polsinelli core team re additional omnibus hearing dates

CAWAR 0.10 80.00

08/13/20 Review and comment on draft agenda for August 17 hearing ,correspondence with Polsinelli core team re same, review filed copy

CAWAR 0.50 400.00




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Date Description Initials Hours Amount08/14/20 Correspondence with Debtors' professionals re August 17

hearingCAWAR 0.10 80.00

08/14/20 Review Certification of Counsel Regarding Scheduling of Omnibus Hearing Dates and order approving same

CAWAR 0.10 80.00

08/17/20 Read the agenda of matters scheduled to be heard today and confirm with Lindsey Suprum the status of the adversary proceeding

BADOL 0.30 127.50

08/17/20 Coordinate and collaborate with Chris Ward, Amanda Terr, Caryn Wang, and Lindsey Suprum on submitting the final version of the Panama City sale order under certification of counsel with the purchase agreement

BADOL 0.70 297.50

08/17/20 Prepare to handle hearing scheduled for today in the event it goes forward and is not canceled

BADOL 0.50 212.50

08/17/20 Schedule telephonic appearances for today's hearing; correspondence regarding same.

LMSUP 0.60 183.60

08/17/20 Correspondence with chambers regarding cancellation of August 17 hearing; draft, finalize, file and serve second amended hearing agenda; correspondence regarding same.

LMSUP 0.60 183.60

08/17/20 Draft, finalize, file and serve August 17 amended agenda; add hyperlinks to pleadings on agenda and email to chambers per the Court order re: cessation of all hand deliveries; correspondence regarding same.

LMSUP 0.90 275.40

08/17/20 Correspondence with counsel to Kroger re August 17 hearing CAWAR 0.10 80.0008/17/20 Correspondence with Committee counsel re August 17 hearing CAWAR 0.10 80.0008/17/20 Correspondence with Chambers re cancellation of August 17

hearing, correspondence with Polsinelli core team re same, review seconded amended agenda canceling hearing and correspondence re same

CAWAR 0.40 320.00

08/21/20 Draft August 27 hearing agenda LMSUP 1.30 397.8008/21/20 Review Notice of Rescheduled Omnibus Hearing CAWAR 0.10 80.0008/21/20 Correspondence with Chambers and Polsinelli core team re

coordination of hearing datesCAWAR 0.10 80.00

08/21/20 Review Certification of Counsel Regarding Scheduling of Omnibus Hearing Dates and order approving same

CAWAR 0.10 80.00

08/24/20 Review draft agenda of matters scheduled to be heard on August 27, 2020

BADOL 0.40 170.00

08/24/20 Schedule telephonic appearances for August 26 status conference; correspondence regarding same.

LMSUP 0.30 91.80

08/24/20 Update, finalize, file and serve August 27 hearing agenda; email courtesy copy to chambers; correspondence regarding same.

LMSUP 0.70 214.20

08/24/20 Review and comment on draft agenda for August 27 hearing, correspondence with Polsinelli core team re same

CAWAR 0.40 320.00

08/25/20 Review amended notice of hearing on August 24 motions CAWAR 0.10 80.00




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Date Description Initials Hours Amount08/27/20 Review Certification of Counsel Regarding Scheduling of

Omnibus Hearing Dates and correspondence re sameCAWAR 0.10 80.00

08/27/20 Review notice of rescheduled hearing CAWAR 0.10 80.0008/27/20 Correspondence with Polsinelli core team re hearing dates CAWAR 0.10 80.00SUBTOTAL FOR B145 Court Hearings 12.80 $5,620.50

B150 Creditor Committee Meetings

Date Description Initials Hours Amount08/12/20 Communications with Committee counsel and Chris Ward

regarding leases.ENBOY 0.20 $142.00

SUBTOTAL FOR B150 Creditor Committee Meetings 0.20 $142.00

B155 Creditor Inquiries

Date Description Initials Hours Amount08/04/20 Call from unsecured claimant asking about case status and

timing of distributions.ENBOY 0.10 $71.00

08/05/20 Attention to creditor inquiries including telephone calls and correspondence from parties-in-interest, forward to appropriate individuals to address

CAWAR 0.10 80.00

08/06/20 Call from claim holder requesting information relating to bankruptcy case.

ENBOY 0.10 71.00


CAWAR 0.10 80.00

08/11/20 Correspondence with client team and professionals re creditor communications

CAWAR 0.10 80.00


CAWAR 0.10 80.00


CAWAR 0.10 80.00

SUBTOTAL FOR B155 Creditor Inquiries 0.70 $542.00

B160 Employment/Fee Applications

Date Description Initials Hours Amount08/04/20 Review and comment on A&M draft May fee application,

correspondence re sameCAWAR 0.30 $240.00




September 9, 20201839103

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Date Description Initials Hours Amount08/05/20 Review Fourth Monthly Fee Application of Alvarez & Marsal

North America, LLC for Payment of Compensation and Reimbursement of Expenses as Financial Advisor to the Debtors for the period from May 1, 2020 to May 31, 2020 and correspondence re same

CAWAR 0.20 160.00

08/05/20 Review detailed Polsinelli time entries for previous month for accuracy and privilege, correspondence with accounting re monthly invoice

CAWAR 0.50 400.00

08/06/20 Correspondence with Polsinelli core team re July monthly fee application

CAWAR 0.10 80.00

08/11/20 Correspondence with Lindsey Suprum re confirming no objection to Polsinelli fee application and review Certificate of No Objection

CAWAR 0.20 160.00

08/11/20 Correspondence with client team re professional fees CAWAR 0.10 80.0008/17/20 Review certificates of no objection to Committee professionals

fee applications and correspondence re sameCAWAR 0.10 80.00

08/20/20 Review and comment on draft Polsinelli July monthly fee application, correspondence with Lindsey Suprum re same, review filed copy

CAWAR 0.40 320.00

08/20/20 Review Monthly Application for Compensation of Norton Rose Fulbright US LLP as Special Litigation Counsel for the Official Committee of Unsecured Creditors for the period July 1, 2020 to July 31, 2020 (Sixth Monthly)

CAWAR 0.10 80.00

08/24/20 Review Combined Sixth Monthly & Second Interim of Province, Inc. as Financial Advisor to the Official Committee of Unsecured Creditors for the period May 1, 2020 to July 31, 2020

CAWAR 0.10 80.00

08/25/20 Review draft of A&M June monthly fee application and correspondence re same

CAWAR 0.20 160.00

08/25/20 Correspondence with Lindsey Suprum re second interim fee application

CAWAR 0.10 80.00

08/25/20 Review PJS second interim fee app and correspondence re same

CAWAR 0.20 160.00

08/26/20 Review Fifth Monthly Fee Application of Alvarez & Marsal North America, LLC for Payment of Compensation and Reimbursement of Expenses as Financial Advisor to the Debtors for the period from June 1, 2020 to June 30, 2020

CAWAR 0.10 80.00

08/26/20 Review and comment on draft second interim Polsinelli fee application and all exhibits thereto

CAWAR 0.50 400.00

08/26/20 Correspondence with Polsinelli core team re second interim fee application

CAWAR 0.10 80.00

08/27/20 Correspondence with counsel to PJS re interim fee applications CAWAR 0.10 80.0008/27/20 Review CNO to Alvarez monthly fee application and

correspondence re sameCAWAR 0.10 80.00

08/28/20 Correspondence with Chris Lewis at Womble regarding interim fee applications and hearing on same

LMSUP 0.10 30.60




September 9, 20201839103

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Date Description Initials Hours Amount08/28/20 Review final draft of Second Interim Fee Application of Polsinelli

PC for Compensation and Reimbursement of Expenses as Counsel to the Debtors and Debtors In Possession for the Period From May 1, 2020 Through July 31, 2020, correspondence with Lindsey Suprum re same, review filed copy

CAWAR 0.40 320.00

08/28/20 Review Second Interim Application of PJ Solomon, L.P. and PJ Solomon Securities, LLC for Compensation for Services Rendered and for Reimbursement of Expenses as Investment Banker to the Debtors and Debtors In Possession for the Period From May 1, 2020 to and Including July 31, 2020

CAWAR 0.10 80.00

08/31/20 Review Interim Application for Compensation of Norton Rose Fulbright US LLP as Special Litigation Counsel for the Official Committee of Unsecured Creditors for the period May 1, 2020 to July 31, 2020 (Second Interim)

CAWAR 0.10 80.00

08/31/20 Review Notice of Hearing Regarding Combined Sixth Monthly & Second Interim Application for Compensation and Reimbursement of Expenses of Province, Inc., as Financial Advisor to the Official Committee of Unsecured Creditors, for the (i) Monthly Period from July 1, 2020 through July 31, 2020, and (ii) Interim Period from May 1, 2020 through July 31, 2020

CAWAR 0.10 80.00

08/31/20 Review Interim Application for Compensation of Womble Bond Dickinson (US) LLP as Counsel for the Official Committee of Unsecured Creditors for the period May 1, 2020 to July 31, 2020 (Second Interim)

CAWAR 0.10 80.00

SUBTOTAL FOR B160 Employment/Fee Applications 4.40 $3,470.60

B164 Polsinelli Fee Applications

Date Description Initials Hours Amount08/06/20 Review Polsinelli July invoice; correspondence with C. Ward

regarding preparation of monthly fee applicationLMSUP 0.30 $91.80

08/11/20 Draft, finalize and file certificate of no objection regarding Polsinelli fifth monthly fee application; email with client regarding payment; correspondence regarding same.

LMSUP 0.50 153.00

08/19/20 Draft Polsinelli sixth monthly fee application; correspondence with C. Ward regarding same.

LMSUP 1.20 367.20

08/20/20 Update, finalize, file and serve Polsinelli sixth monthly fee application; correspondence regarding same.

LMSUP 0.70 214.20

08/26/20 Draft Polsinelli second interim fee application; correspondence with C. Ward regarding same.

LMSUP 2.80 856.80

08/28/20 Review, update, finalize, file and serve Polsinelli secon

in the united states bankruptcy court for the … · 2020. 9. 21. · 74812014.1 proceeding and...

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