seventh quarterly application for compensation and
TRANSCRIPT
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELA W ARE
In re: Chapter 11
Debtors.
)))))
Objection Deadline: October 12,2009 at 4:00 p.m.Hearing Date: To be scheduled
Case No. 07-11119 (BLS)(Jointly Administered)
AEGIS MORTGAGE CORPORATION, et aI., 1
SEVENTH QUARTERLY APPLICATION FOR COMPENSATIONAND REIMBURSEMENT OF EXPENSES OF
PACHULSKI STANG ZIEHL & JONES LLP, AS COUNSELTO THE DEBTORS AND DEBTORS IN POSSESSION, FOR
THE PERIOD FROM MARCH 1, 2009 THROUGH MAY 31, 2009
Name of Applicant: Pachulski Stang Ziehl & Jones LLP
Authorized to Provide Professional Debtors and Debtors in PossessionServices to:
Date of Retention:Nunc Pro Tunc to August 13,2007 by ordersigned September 4, 2007
Period for which Compensation and March 1, 2009 through May 31, 20092Reimbursement is Sought:Amount of Compensation Sought as Actual, $389,356.50Reasonable and Necessar:
Amount of Expense Reimbursement Sought as$ 27,455.74
Actual, Reasonable and Necessary:
This is a: _ monthly -L interim _ final application.
The total time expended for fee application preparation is approximately 3.0 hours
and the corresponding compensation requested is approximately $1,000.00.
1 The Debtors in these cases, along with the last four digits of each Debtor's federal tax identification number, are:
Aegis Mortgage Corporation (9883); Aegis Wholesale Corporation (9888); Aegis Lending Corporation (9884);Aegis Correspondent Corporation (0359); Aegis Funding Corporation (9886); Aegis Mortgage Loan ServicingCorporation (0515); Solutions Settlement Services of America Corporation (6879); Solutions Title of AmericaCorporation (7045); and Aegis REIT Corporation (3436). The address for all Debtors is 3250 Briarpark, Suite 400,Houston, TX 77042.2 This Application may include time expended before the time period indicated above that has not been included in
any prior application. The applicant reserves the right to include any time expended in the time period indicatedabove in future application(s) ifit is not included herein.
00233-001 \DOCS _DE: i 52652.1
PRIOR APPLICATIONS FILED
Date Period Covered i Requested Requested Approved ApprovedFiled Fees Expenses Fees Expenses
12/1 0/07 08/13/07 - 08/31/07 $255,858.50 $20,338.58 $255,858.50 $20,338.58
01/09/08 09/01/07 - 09/30/07 $357,200.75 $29,782.63 $357,200.75 $29,782.63
01/14/08 10/01/07 -10/31/07 $306,623.75 $34,713.05 $306,623.75 $34,713.05
01/22/08 11/01/07 - 11/30/07 $191,184.50 $12,936.81 $191,184.50 $12,936.81
01/28/08 12/01/07 - 12/31/07 $161,195.50 $19,221.26 $161,195.50 $19,221.26
04/08/08 01/01/08 - 01/31/08 $275,758.50 $20,835.89 $275,758.50 $20,835.89
04/21/08 02/01/08 - 02/29/08 $258,448.75 $14,252.07 $258,448.75 $14,252.07
OS/22/08 03/01/08 - 03/31/08 $224,043.50 $16,234.35 $224,043.50 $16,234.35
06/13/08 04/01/08 - 04/30/08 $218,651.25 $20,392.42 $218,651.25 $20,392.42
08/05/08 05/01/08 - 05/31/08 $196,660.50 $22,835.33 $196,660.50 $22,835.33
09/08/08 06/01/08 - 06/30/08 $192,297.00 $ 8,665.47 $192,297.00 $ 8,665.47
10/24/08 07/01/08 - 07/31/08 $112,995.00 $ 5,939.02 $112,995.00 $ 5,939.02
11/13/08 08/01/08 - 08/31/08 $148,671.50 $ 7,970.16 $148,671.50 $ 7,970.16
12/12/08 09/01/08 - 09/30/08 $182,178.00 $ 9,119.30 $182,178.00 $ 9,119.30
12/23/08 1 % 1/08 - 10/31/08 $277,314.00 $29,970.67 $277,314.00 $29,970.67
01/26/09 11/01/08 - 11/30/08 $165,001.50 $16,774.51 $165,001.50 $16,774.51
02/03/09 12/01/08 - 12/31/08 $112,302.50 $ 3,120.19 $ 89,842.00 $ 3,120.19
04/14/09 01/01/09 - 01/31/09 $160,469.50 $ 4,906.07 $128,375.60 $ 4,906.07
04/24/09 02/01/09 - 02/28/09 $ 97,272.50 $ 4,929.92 $ 77,818.00 $ 4,929.92
07/13/09 03/01/09 - 03/31/09 $160,978.00 $ 8,590.71 $128,782.40 $ 8,590.71
08/13/09 04/01/09 - 04/30/09 $122,474.50 $10,477.28 $ 97,979.60 $10,477.28
09/14/09 05/01/09 - 05/31/09 $105,904.00 $ 8,387.75 Pending Pending
00233-001\DOCS_DE: 152652.1 2
PSZ&J PROFESSIONALS
Name of Professional Position .ofthe Applicant, Hourly Total TotalIndividual Number of Years in that Biling Hours Compensation
.. Position, Prior Relevant Rate BiledExperience, Year of Obtaining (including
License.to Practice, Area of Changes)Expertise
Laura Davis Jones Parner 2000; Joined Firm 2000; $795.00 94.00 $74,730.00Member of DE Bar since 1986
Ira D. Kharasch Partner 1987; Member of CA Bar $750.00 4.30 $ 3,225.00since 1982
Alan J. Kornfeld Partner 1996; Member of CA Bar $725.00 0.80 $ 580.00since 1987
Henry C. Kevane Partner 1997; Member ofCa Bar $675.00 126.60 $85,455.00since 1986
lain A. W. Nasitir Parner 1999; Member of NY Bar $675.00 6.30 $ 4,252.50
since 1983; Member of CA Barsince 1990
David M. Bertenthal Parner 1999; Member of CA Bar $645.00 103.20 $66,564.00since 1993 $322.50 11.20 $ 3,612.00
Kenneth H. Brown Partner 2001; Member of CA Bar $650.00 22.00 $14,300.00since 1981
James E. O'Neil Partner 2005; Member of P A Bar $535.00 12.80 $ 6,848.00
since 1985; Member of DE Barsince 2001
Joshua M. Fried Partner 2006; Member of CA Bar $535.00 112.40 $60,134.00since 1994; Member of NY Bar $267.50 15.00 $ 4,012.50
since 1999Scotta E. McFarland Of Counsel 2000; Member of CA $525.00 0.30 $ 157.50
Bar since 1993; Member of DE
Bar since 2002Michael R. Seidl Parner 2003; Member of DE Bar $495.00 0.40 $ 198.00
since 2000; Member ofWashington, D.C. Bar since 1996
Curtis A. Hehn Partner 2006; Member ofPA and $475.00 3.30 $ 1,567.50
NJ Bars since 1997; Member ofDE Bar since 2002
Gilian N. Brown Parner 2007; Member ofCA Bar $475.00 7.20 $ 3,420.00
Since 1999; Member ofWashington D.C. Bar since 2008
Willam L. Ramseyer Of Counsel; Member of CA Bar $475.00 6.00 $ 2,850.00
since 1980Miriam Khatiblou Of Counsel 2008; Member of CA $425.00 0.10 $ 42.50
Bar since 1995
00233-001\DOCS_DE: 152652. i 3
NalDe ofPtofessional P()sitip.ilnf the Applicant, H()urly Total T()talIndividual Number of Years in that iiiling H()urs Compensation
P()siti()Il,Pri()r Relevant Rate BiledExperience, Year of Obtaining (iiicluding
License to Practice, Area of Changes)Expertse
. .
Timothy P. Cairns Associate 2007; Member of DE $395.00 1.10 $ 434.50
Bar since 2002Kathleen P. Makowski Of Counsel 2008; Member of P A $395.00 75.60 $29,862.00
Bar since 1996; Member of DE
Bar since 1997Mark M. Bilion Associate 2009; Member of NY $325.00 1.90 $ 617.50
Bar since 2007; Member of DE
Bar since 2009Leslie F. Forrester Law Library Director $250.00 5.60 $ 1,400.00
Patricia 1. Jeffries Paralegal 1999 $225.00 6.00 $ 1,350.00
Kathe F. Finlayson Paralegal 2000 $225.00 85.60 $19,260.00
Louise R. Tuschak Paralegal 2000 $215.00 2.40 $ 516.00
Cheryl A. Knotts Paralegal 2000 $205.00 4.70 $ 963.50
Jorge E. Rojas Paralegal 2002 $195.00 1.60 $ 312.00
Kati L. Suk Paralegal 2009 $175.00 1.40 $ 245.00
John F. Bass Paralegal 2008 $150.00 0.40 $ 60.00
Sheryle L. Pitman Case Management Assistant 2001 $125.00 16.1 0 $ 2,012.50
Beatrice M. Koveleski Case Management Assistant 2009 $125.00 1.40 $ 175.00
Ida L. Lane Case Management Assistant 2009 $125.00 1.60 $ 200.00
Grand Total:Total Hours:Blended Rate: $
$ 389,356.50731.30532.27
00233-00 i \DOCS _DE: 152652.1 4
COMPENSATION BY CATEGORY
........ ....... "' ~.F........;i. ;".i,'':... "
.......f.,....'O;,. .......... \;Asset Analysis/Recovery 5.90 $ 3,814.50Asset Disposition 1.40 $ 442.00Appeals 0.20 $ 95.00Banptcy Litigation 72.90 $ 32,777.00
Case Administration 31.50 $ 5,222.50Claims Admin/Objections 287.80 $152,308.50Compensation of Professional 18.60 $ 6,623.00Compensation of Prof.lOthers 19.10 $ 5,283.50Employee Benefit/Pension 32.40 $ 20,146.50
Executory Contracts 2.80 $ 1,084.00
Financial Filngs 3.10 $ 847.50
Litigation (Non-Bankruptcy) 1.50 $ 802.50
Operations 0.50 $ 352.50Plan & Disclosure Statement 215.30 $146,382.50Retention of Prof./Others 9.00 $ 4,460.00Stay Litigation 3.10 $ 1,090.50
Travel 26.20 $ 7,624.50
00233-00 1 \DOCS_DE: 152652.1 5
Air FareAuto Travel Ex enseWorking Meals
Conference CallDelivery/Courier Service
Express MailFax TransmittalGuest ParkingHotel ExpenseLegal ResearchOutside Services
Court ResearchPostageReproduction ExpenseReproduction/Scan CopyOvertimeTravel ExpenseTranscript
EXPENSE SUMMARY
Continental Airlines; United AirlinesAMS Pacific TransportationExchange on the Market; Go Bistro; Pappas BrosSteakhouse; Meal at airportAT&T Conference CallTristateDHL and Federal ExpressOutgoing onlyCentral Lot ParkingHilton HotelLexis/Nexis and WestlawDigital Legal ServicesPacerUS Mail
$3,369.10$ 674.88
$ 170.60
$ 305.89
$2,360.35$ 276.68
$5,746.00$ 168.00
$1,953.45$ 339.31
$3,343.44$ 241.84
$1,831.98$5,317.40$ 606.30
$ 125.02
$ 580.00
$ 45.50
A. ZaragozaTravel Agency Fee; Lawyer's travel fee; Petty CashJ. Ryan
3 PSZ&J may use one or more service providers. The service providers identified herein below are the primary
service providers for the categories described.
00233-00 1 \DOCS_DE: i 52652.1 6
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11)
AEGIS MORTGAGE CORPORATION, et aI., 1) Case No. 07-11119 (BLS)) (Jointly Administered)Debtors. )
Objection Deadline: October 12, 2009 at 4:00 p.m.Hearing Date: To be scheduled
SEVENTH QUARTERL Y APPLICATION FOR COMPENSATIONAND REIMBURSEMENT OF EXPENSES OF
PACHULSKI STANG ZIEHL & JONES LLP, AS COUNSELTO THE DEBTORS AND DEBTORS IN POSSESSION, FOR
THE PERIOD FROM MARCH 1,2009 THROUGH MAY 31, 2009
Pursuant to sections 330 and 331 of Title 11 of the United States Code (the
"Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankptcy Procedure (collectively, the
"Banruptcy Rules"), and the Court's "Administrative Order Under 11 U.S.C. §§ 105(a) and 331
Establishing Procedures for Interim Compensation and Expense Reimbursement of Professionals
and Committee Members," entered on or about September 5, 2007 (the "Administrative Order"),
Pachulski Stang Ziehl & Jones LLP ("PSZ&J" or the "Firm"), counsel to the Debtors and
Debtors in Possession ("Debtors"), hereby submits its Seventh Quarterly Application for
Compensation and for Reimbursement of Expenses for the Period from March 1, 2009 through
May 31, 2009 (the "Application").
i The Debtors in these cases, along with the last four digits of each Debtor's federal tax identification number, are:
Aegis Mortgage Corporation (9883); Aegis Wholesale Corporation (9888); Aegis Lending Corporation (9884);Aegis Correspondent Corporation (0359); Aegis Funding Corporation (9886); Aegis Mortgage Loan ServicingCorporation (05 i 5); Solutions Settlement Services of America Corporation (6879); Solutions Title of AmericaCorporation (7045); and Aegis REIT Corporation (3436). The address for all Debtors is 3250 Briarpark, Suite 400,Houston, TX 77042.
00233-001 \DOCS _DE: i 52652, i
By this Application PSZ&J seeks a quarterly interim allowance of compensation
in the amount of$389,356.50 and actual and necessary expenses in the amount of $27,455.74 for
a total allowance of$416,812.24 and payment of the unpaid portion of such fees and costs for
the period March 1, 2009 through May 31, 2009 (the "Interim Period"). In support of this
Application, PSZ&J respectfully represents as follows:
Background
1. On August 13, 2007 (the "Petition Date"), the Debtors fied voluntary
petitions for relief under chapter 11 of the Banptcy Code. The Debtors continue in possession
of their properties and continues to operate and manage their business as debtors in possession
pursuant to sections 1 107(a) and 1108 of the Banruptcy Code. A Committee of Unsecured
Creditors ("Committee") was appointed on or about August 24,2007, and an amended Notice of
Appointment filed on or about September 13,2007. No trustee or examiner has been appointed
in the Debtors' chapter 11 cases.
2. The Cour has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157
and 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b )(2).
3. On or about September 5,2007, the Court entered the Administrative
Order, authorizing certain professionals ("Professionals") to submit monthly applications for
interim compensation and reimbursement for expenses, pursuant to the procedures specified
therein. The Administrative Order provides, among other things, that a Professional may submit
monthly fee applications. Ifno objections are made within twenty (20) days after service of the
monthly fee application the Debtors are authorized to pay the Professional eighty percent (80%)
of the requested fees and one hundred percent (100%) of the requested expenses. Beginning
00233-001\DOCS_DE: 152652. i 2
with the period ending October 31, 2007, and continuing at three-month intervals or such other
intervals convenient to the Court, each Professional shall fie and serve an interim application for
allowance of the amounts sought in its monthly fee applications for that period. All fees and
expenses paid are on an interim basis until final allowance by the Court.
4. The retention ofPSZ&J, as co-counsel to the Debtors, was approved
effective as of the Petition Date by this Court's "Order Under Section 327(a) of the Bankptcy
Code and Rule 2014 of the Federal Rules of Banruptcy Procedure and Local Rule 2014-1
Authorizing the Employment and Retention of Pachulski Stang Ziehl Young Jones & Weintruab
LLP as Counsel for the Debtors and Debtors in Possession Nunc Pro Tunc to the Petition Date,"
signed on or about September 4,2007 (the "Retention Order"). The Retention Order authorized
PSZ&J to be compensated on an hourly basis and to be reimbursed for actual and necessary out-
of-pocket expenses.
PSZ&J's APPLICATION FOR COMPENSATION ANDFOR REIMBURSEMENT OF EXPENSES
Monthlv Fee Applications Covered Herein
5. The Monthly Fee Applications for the periods March 1, 2009 through May
31, 2009 of PSZ&J have been filed and served pursuant to the Administrative Order.
6. On July 13,2009, PSZ&J fied its Twentieth Monthly Application of
Pachulski Stang Ziehl & Jones LLP for Compensation and for Reimbursement of Expenses as
Counsel to the Debtors and Debtors in Possession for the Period from March 1, 2009 through
March 31, 2009 ("Twentieth Monthly Fee Application") requesting $160,978.00 in fees and
$8,590.71 in expenses. Pursuant to the Administrative Order, PSZ&J has been paid $129,776.10
00233-001\DOCS_DE: 152652.1 3
of the fees and $7,597.01 of the expenses requested in the Twentieth Monthly Fee Application.
A true and correct copy of the Twentieth Monthly Fee Application is attached hereto as Exhibit
A.
7. On August 13,2009, PSZ&J fied its Twenty-First Monthly Application of
Pachulski Stang Ziehl & Jones LLP for Compensation and for Reimbursement of Expenses as
Counsel to the Debtors and Debtors in Possession for the Period from April 1, 2009 through
April 30, 2009 ("Twenty-First Monthly Fee Application") requesting $122,474.50 in fees and
$10,477.28 in expenses. Pursuant to the Administrative Order, PSZ&J has been paid $97,979.60
of the fees and $10,477.28 of the expenses requested in the Twenty-First Monthly Fee
Application. A true and correct copy of the Twenty-First Monthly Fee Application is attached
hereto as Exhibit B.
8. On September 14,2009, PSZ&J fied its Twenty-Second Monthly
Application of Pachulski Stang Ziehl & Jones LLP for Compensation and for Reimbursement of
Expenses as Counsel to the Debtors and Debtors in Possession for the Period from May 1, 2009
through May 31, 2009 ("Twenty-Second Monthly Fee Application") requesting $105,904.00 in
fees and $8,387.75 in expenses. The Twenty-Second Monthly Fee Application is pending. A
true and correct copy of the Twenty-Second Monthly Fee Application is attached hereto as
Exhibit C.
9. The Monthly Fee Applications covered by this Application contain
detailed daily time logs describing the actual and necessary services provided by PSZ&J during
the Interim Period as well as other detailed information required to be included in fee
applications.
00233-001 \DOCS _DE: i 52652.1 4
ReQuested Relief
10. By this Application, PSZ&J requests that the Cour approve payment of
one-hundred percent (100%) of the fees and expenses incurred by PSZ&J during the Interim
Period of March 1, 2009 through May 31, 2009.
11. At all relevant times, PSZ&J has been a disinterested person as that term is
defined in § 1 0 1 (14) of the Banruptcy Code and has not represented or held an interest adverse
to the interest of the Debtors.
12. All services for which compensation is requested by PSZ&J were
performed for or on behalf of the Debtors and not on behalf of any committee, creditor or other
person.
13. PSZ&J has received no payment and no promises for payment from any
source other than the Debtors for services rendered or to be rendered in any capacity whatsoever
in connection with the matters covered by this Application. There is no agreement or
understanding between PSZ&J and any other person other than the partners of PSZ&J for the
sharing of compensation to be received for services rendered in this case. PSZ&J has received
payments from the Debtors during the year prior to the Petition Date in the amount of
$838,571.00 plus the Debtors' aggregate filing fees of$II,429.00 in connection with the
preparation of initial documents and its prepetition representation of the Debtors. PSZ&J was
current as of the Petition Date, subject to a final reconciliation of the amount actually expended
prepetition. Upon final reconcilation of the amount actually expended prepetition, any balance
remaining from the prepetition payments to PSZ&J was credited to the Debtors and utilized as
00233-001 \DOCS_DE: 152652.1 5
PSZ&J's retainer to apply to postpetition fees and expenses pursuant to the compensation
procedures approved by this Cour and the Banptcy Code.
14. The professional services and related expenses for which PSZ&J requests
interim allowance of compensation and reimbursement of expenses were rendered and incurred
in connection with this case in the discharge of PSZ&J' s professional responsibilties as
attorneys for the Debtors in their chapter 11 case. PSZ&J's services have been necessary and
beneficial to the Debtors and their estate, creditors and other parties in interest.
In accordance with the factors enumerated in section 330 of the Banptcy Code,
it is respectfully submitted that the amount requested by PSZ&J is fair and reasonable given
(a) the complexity of the case, (b) the time expended, (c) the nature and extent of the services
rendered, (d) the value of such services, and (e) the costs of comparable services other than in a
case under the Bankptcy Code. Moreover, PSZ&J has reviewed the requirements of DeL.
Bank. LR 2016-2 and the Administrative Order and believes that this Application complies with
such Rule and Order.
WHEREFORE, PSZ&J respectfully requests that the Court enter an order, in the
form attached hereto, providing that an interim allowance be made to PSZ&J for the period from
March 1,2009 through May 31, 2009 in the sum of$389,356.50, as compensation for necessary
professional services rendered, and the sum of $27,455.74, for reimbursement of actual
necessary costs and expenses, for a total of$416,812.24; that the Debtors be authorized and
00233-001 \DOCS_DE: 152652.1 6
directed to pay to PSZ&J the outstanding amount of such sums; and for such other and further
relief as may be just and proper.
Dated: SeptemberZO , 2009
00233-00 i \DOCS _DE: i 52652.1
./aura Davis J (Bar No. 2436)
David M. ertenthal (CA Bar No. 167624)James E. O'Neil (Bar No. 4042)
Joshua M. Fried, (CA Bar No. 181541)Curtis A. Hehn (Bar No. 4264)Timothy P. Cairns (Bar No. 4228)919 North Market Street, 1 ih FloorP.O. Box 8705Wilmington, DE 19899-8705Telephone: (302) 652-4100Facsimile: (302) 652-4400
Counsel to the Debtors and Debtors in Possession
7
VERIFICATION
STATE OF DELAWARE
COUNTY OF NEW CASTLE
Laura Davis Jones, after being duly sworn according to law, deposes and says:
a) I am a partner of the applicant law firm Pachulski Stang Ziehl & Jones
LLP, and have been admitted to appear before this Court.
b) I am familiar with the work performed on behalf of the Debtors by the
lawyers and paraprofessionals ofPSZ&J.
c) I have reviewed the foregoing Application and the facts set forth therein
are true and correct to the best of my knowledge, information and belief. Moreover, I have
reviewed DeL. Bank. LR 2016-2 and the Administrative Order entered on or about September 5,
2007, and submit that the Application substantially complies with such Rule and Order.
SWORN AND ~UiJCRIBbefore me this 1J .'y of
(Notary 'ublicMy Commission Expires: t( /4/ or
MARY E. CORCORANNOTARY PUBLIC
STATE OF DELAWARE
My commission expires Nov. 4, 2009
00233-001 \DOCS_DE: 152652. i
.~--
IN THE UNITED STATES BANUPTCY COURT
FOR THE DISTRICT OF DELA WARE
In re: Chapter 11
Debtors.
)))))
Objection Deadline: August 3, 2009 at 4:00 p.m.Hearing Date: Only If Objections Are Timely Filed
Case No. 07-11119 (BLS)(Jointly Administered)
AEGIS MORTGAGE CORPORATION, et aI., 1
TWENTIETH MONTHLY APPLICATION FOR COMPENSATIONAND REIMBURSEMENT OF EXPENSES OF
PACHULSKI STANG ZIEHL & JONES LLP, AS COUNSELTO THE DEBTORS AND DEBTORS IN POSSESSION, FOR
THE PERIOD FROM MARCH 1,2009 THROUGH MARCH 31. 2009
Name of Applicant: Pachulski Stang Ziehl & Jones LLP
Authorized to Provide Professional Debtors and Debtors in PossessionServices to:
Date of Retention:Nunc Pro Tunc to August 13,2007 by ordersigned September 4, 2007
Period for which Compensation and March 1, 2009 through March 31, 20092Reimbursement is Sought:Amount of Compensation Sought as Actual, $160,978.00Reasonable and Necessar:
Amount of Expense Reimbursement Sought as$ 8,590.71
Actual, Reasonable and Necessar:
This is a: -l monthly interim _ final application.
The total time expended for fee application preparation is approximately 3.0 hours
and the corresponding compensation requested is approximately $1,000.00.
i The Debtors in these cases, along with the last four digits of each Debtor's federal ta identification number, are:
Aegis Mortgage Corporation (9883); Aegis Wholesale Corporation (9888); Aegis Lending Corporation (9884);Aegis Correspondent Corporation (0359); Aegis Funding Corporation (9886); Aegis Mortgage Loan ServicingCorporation (0515); Solutions Settlement Services of America Corporation (6879); Solutions Title of AmericaCorporation (7045); and Aegis REIT Corporation (3436). The address for all Debtors is 3250 Briarark, Suite 400,Houston, TX 77042.2 This Application may include time expended before the time period indicated above that has not been included in
any prior application. The applicant reserves the right to include any time expended in the time period indicatedabove in futue application(s) ifit is not included herein.
00233-001\DOCS_DE: 148236.2
/~ l-7J5
~l;T:,,~.__~l~§'~, ',~
PRIOR APPLICATIONS FILED
Date . PeriodC()vered,d. R~quésted
Requested · " ,Approved ApprovedFiìed .' ,.,:Fees EXDenses Fees Expenses
12/10/07 08/13/07 - 08/31/07 $255,858.50 $20,338.58 $255,858.50 $20,338.5801/09/08 09/01/07 - 09/30/07 $357,200.75 $29,782.63 $357,200.75 $29,782.6301/14/08 1 % 1/07 - 10/31/07 $306,623.75 $34,713.05 $306,623.75 $34,713.0501/22/08 11/01/07 - 11/30/07 $191,184.50 $12,936.81 $191,184.50 $12,936.8101/28/08 12/01/07 - 12/31/07 $161,195.50 $19,221.26 $161,195.50 $19,221.2604/08/08 01/01/08 - 01/31/08 $275,758.50 $20,835.89 $275,758.50 $20,835.8904/21/08 02/01/08 - 02/29/08 $258,448.75 $14,252.07 $258,448.75 $14,252.07OS/22/08 03/01/08 - 03/31/08 $224,043.50 $16,234.35 $224,043.50 $16,234.3506/13/08 04/01/08 - 04/30/08 $218,651.25 $20,392.42 $218,651.25 $20,392.4208/05/08 05/01/08 - 05/31/08 $196,660.50 $22,835.33 $196,660.50 $22,835.3309/08/08 06/01/08 - 06/30/08 $192,297.00 $ 8,665.47 $192,297.00 $ 8,665.47
10/24/08 07/01/08 - 07/31/08 $112,995.00 $ 5,939.02 $112,995.00 $ 5,939.02
11/13/08 08/01/08 - 08/31/08 $148,671.50 $ 7,970.16 $148,671.50 $ 7,970.16
12/12/08 09/01/08 - 09/30/08 $182,178.00 $ 9,119.30 $182,178.00 $ 9,119.30
12/23/08 1 % 1/08 - 10/31/08 $277,314.00 $29,970.67 $277,314.00 $29,970.6701/26/09 11/01/08 - 11/30/08 $165,001.50 $16,774.51 $165,001.50 $16,774.5102/03/09 12/01/08 - 12/31/08 $112,302.50 $ 3,120.19 $ 89,842.00 $ 3,120.19
04/14/09 01/01/09 - 01/31/09 $160,469.50 $ 4,906.07 $128,375.60 $ 4,906.07
04/24/09 02/01/09 - 02/28/09 $ 97,272.50 $ 4,929.92 $ 77,818.00 $ 4,929.92
PSZ&J PROFESSIONALS,Name of Professional PosItl()u()fthe Applicant; H()urly T()tal Total
Individual Nûû),))er'of Years in tbat ' . Billig " Hours CompensationPosition, Prior Relevant . Rate' Biled
Experience, Year of Obtaining (includingLicense to Practice, .lrea of Changes)
Expertise'. ' ; ,Laura Davis Jones Parer 2000; Joined Finn 2000; $795.00 59.40 $47,223.00
Member of DE Bar since 1986Ira D. Kharasch Parer 1987; Member ofCA Bar $750.00 1.00 $ 750.00
since 1982Alan J. Kornfeld Parer 1996; Member of CA Bar $725.00 0.50 $ 362.50
since 1987Henr C. Kevane Parer 1997; Member ofCa Bar $675.00 55.90 $37,732.50
since 1986lain A. W. Nasitir Parer 1999; Member of NY Bar $675.00 2.20 $ 1,485.00
since 1983; Member ofCA Barsince 1990
00233-001 \DOCS_DE: i 48236,2 2
N àmeof Professional P()siti()nof the'Appli~ánt, . ." Hourly T()tal TotalIndivdual Number()f Year$in that- .1:. . Bn~ing Hours Compen$ation
Positi()n, Prior Releyant . .. ...,.Râte BiledExperience, Year ()f Obtaining. (incl1lding
License to Practice, Area ,of.
Changes) . '
Expèrtse,
David M. Bertenthal Parner 1999; Member of CA Bar $645.00 46.10 $29,734.50since 1993
Kenneth H. Brown Parer 2001; Member of CA Bar $650.00 4.70 $ 3,055.00
since 1981
James E. O'Neil Parer 2005; Member ofPA Bar $535.00 6.40 $ 3,424.00
since 1985; Member of DE Barsince 2001
Joshua M. Fried Parer 2006; Member of CA Bar $535.00 44.90 $24,021.50since 1994; Member of NY Barsince 1999
Scotta E. McFarland Of Counsel 2000; Member of CA $525.00 0.30 $ 157.50
Bar since 1993; Member of DE
Bar since 2002Curis A. Hehn Parner 2006; Member of P A and $475.00 2.30 $ 1,092.50
NJ Bars since 1997; Member ofDE Bar since 2002
Gillan N. Brown Parer 2007; Member of CA Bar $475.00 3.00 $ 1,425.00
Since 1999; Member ofWashington D.C. Bar since 2008
Wiliam L. Ramseyer Of Counsel; Member of CA Bar $475.00 2.40 $ 1,140.00
since 1980Miriam Khatiblou Of Counsel 2008; Member ofCA $425.00 0.10 $ 42.50
Bar since 1995
Timothy P. Cairns Associate 2007; Member of DE $395.00 1.00 $ 395.00Bar since 2002
Kathleen P. Makowski Of Counsel 2008; Member of P A $395.00 5.40 $ 2,133.00
Bar since 1996; Member of DE
Bar since 1997
Leslie A. Forrester Law Librar Director 2003 $250.00 0.30 $ 75.00
Patrcia J. Jeffries Paralegal 1999 $225.00 0.80 $ 180.00
Kathe F. Finlayson Paralegal 2000 $225.00 22.50 $ 5,062.50
Cheryl A. Knotts Paralegal 2000 $205.00 1.90 $ 389.50
John F. Bass Paralegal 2008 $150.00 0.40 $ 60.00
Sheryle L. Pitman Case Management Assistant 2001 $125.00 8.30 $ 1,037.50
Grand Total:Total Hours:Blended Rate: $
$ 160,978.00269.80596.66
00233-001 \DOCS_DE: 148236,2 3
COMPENSATION BY CATEGORY
EXPENSE SUMMAY
1.800.20
33.5012.2084.60
5.607.508.000.901.50
105.009.00
$ 1,161.00
$ 95.00$17,380.00$ 1,947.00
$53,140.00$ 2,337.00
$ 2,022.50
$ 4,494.50
$ 277.50$ 802.50$72,861.00$ 4,460.00
Air FareConference CallDelive /Courer Service
Ex ress MailFax Transmittl
Le al ResearchCour Research
PostageRe roduction Ex enseRe roduction/Scan CoOvertimeTravel Ex enseTranscript
Continental AirlinesAT&T Conference CallTristateFederal Express
Lexis/Nexis and WestlawPacerUS Mail
A. Zara ozaTravel A ency Fee; Lawyer's travel feeJ. Ryan
$2,151.40$ 261.98
$ 419.20
$ 162.60
$ 310.00
$ 315.13
$ 67.28$1,474.20$2,763.50$ 314.90
$ 125.02
$ 180.00
$ 45.50
3 PSZ&J may use one or more service providers. The service providers identified herein below are the primary
service providers for the categories described.
00233-00 1 \DS_DE: 148236.2 4
IN THE UNITED STATES BANKUPTCY COURT
FOR THE DISTRICT OF DELAWAR
In re:
Debtors.
)))))
Objection Deadline: August 3, 2009 at 4:00 p.m.Hearing Date: Only If Objections Are Timely Filed
Case No. 07-11119 (BLS)(Jointly Administered)
Chapter 11
AEGIS MORTGAGE CORPORATION, et aI., i
TWENTIETH MONTHLY APPLICATION FOR COMPENSATIONAND REIMBUREMENT OF EXPENSES OF
PACHULSKI STANG ZIEHL & JONES LLP, AS COUNSELTO THE DEBTORS AND DEBTORS IN POSSESSION, FOR
THE PERIOD FROM MARCH 1.2009 THROUGH MARCH 31. 2009
Pursuant to sections 330 and 331 of Title 11 of the United States Code (the
"Banptcy Code"), Rule 2016 of the Federal Rules of Banptcy Procedure (collectively, the
"Banptcy Rules"), and the Cour's "Administrative Order Under 11 U.S.C. §§ 105(a) and 331
Establishing Procedures for Interim Compensation and Expense Reimbursement of Professionals
and Committee Members," entered on or about September 5,2007 (the "Administrative Order"),
Pachulski Stang Ziehl & Jones LLP ("PSZ&J" or the "Firm"), counsel to the Debtors and
Debtors in Possession ("Debtors"), hereby submits its Twentieth monthly Application for
Compensation and for Reimbursement of Expenses for the Period from March 1,2009 through
March 31, 2009 (the "Application").
i The Debtors in these cases, along with the last four digits of each Debtor's federal tax identification number, are:
Aegis Mortgage Corporation (9883); Aegis Wholesale Corporation (9888); Aegis Lending Corporation (9884);Aegis Correspondent Corporation (0359); Aegis Funding Corporation (9886); Aegis Mortgage Loan ServicingCorporation (0515); Solutions Settlement Services of America Corporation (6879); Solutions Title of AmericaCorporation (7045); and Aegis REIT Corporation (3436). The address for all Debtors is 3250 Briarark, Suite 400,Houston, TX 77042.
00233-00 I \DOCS_DE: 148236.2
By this Application PSZ&J seeks a monthly interim allowance of compensation
in the amount of$160,978.00 and actual and necessa expenses in the amount of$8,590.71 for
a total allowance of$169,568.71 and payment of$128,782.40 (80% of the allowed fees) and
reimbursement of$8,590.71 (100% of the allowed expenses) for a tota payment of$137,373.11
for the period March 1,2009 through March 31, 2009 (the "Interim Period"). In support of ths
Application, PSZ&J respectfully represents as follows:
Back2round
1. On August 13, 2007 (the "Petition Date"), the Debtors fied voluntar
petitions for relief under chapter 11 of the Banptcy Code. The Debtors continue in possession
of their properties and continues to operate and manage their business as debtors in possession
pursuant to sections 1107(a) and 1108 of the Banptcy Code. A Committee of Unsecured
Creditors ("Committee") was appointed on or about August 24, 2007, and an amended Notice of
Appointment filed on or about September 13,2007. No trstee or examiner has been appointed
in the Debtors' chapter II cases.
2. The Cour has jursdiction over this matter pursuant to 28 U.S.C. §§ 157
and 1334. This is a core proceeding pursuant to 28 V.S.C. § 157(b)(2).
3. On or about September 5, 2007, the Cour entered the Administrative
Order, authorizing certin professionals ("Professionals") to submit monthly applications for
interim compensation and reimbursement for expenses, pursuant to the procedures specified
therein. The Administrative Order provides, among other things, that a Professional may submit
monthly fee applications. Ifno objections are made withn twenty (20) days afer service of the
monthly fee application the Debtors are authorized to pay the Professional eighty percent (80%)
00233-00 1 \DCS_DE: i 48236.2 2
of the requested fees and one hundred percent (100%) of the requested expenses. Beginnng
with the period ending October 31, 2007, and continuing at three-month intervals or such other
intervals convenient to the Court, each Professional shall fie and serve an interim application for
allowance ofthe amounts sought in its monthly fee applications for that period. All fees and
expenses paid are on an interim basis until final allowance by the Cour.
4. The retention ofPSZ&J, as co-counsel to the Debtors, was approved
effective as of the Petition Date by ths Cour's "Order Under Section 327(a) of the Banptcy
Code and Rule 2014 of the Federal Rules of Banptcy Procedure and Local Rule 2014-1
Authorizing the Employment and Retention of Pachulski Stag Ziehl Young Jones & Weintruab
LLP as Counsel for the Debtors and Debtors in Possession Nunc Pro Tunc to the Petition Date,"
signed on or about September 4, 2007 (the "Retention Order"). The Retention Order authorized
PSZ&J to be compensated on an hourly basis and to be reimbursed for actual and necessary out-
of-pocket expenses.
PSZ&J's APPLICATION FOR COMPENSATION ANDFOR REIMBURSEMENT OF EXPENSES
Compensation Paid and Its Source
5. All services for which PSZ&J requests compensation were performed for
or on behalf of the Debtors.
6. PSZ&J has received no payment and no promises for payment from any
source other than the Debtors for services rendered or to be rendered in any capacity whatsoever
in connection with the matters covered by this Application. There is no agreement or
understanding between PSZ&J and any other person other than the partners of PSZ&J for the
00233-001\DOCS_DE: 148236.2 3
sharng of compensation to be received for services rendered in this case. PSZ&J has received
payments from the Debtors durng the year prior to the Petition Date in the amount of
$838,571.00 plus the Debtors' aggregate fiing fees of$l 1,429.00 in connection with the
preparation of initial documents and its prepetition representation of the Debtors. PSZ&J was
curent as of the Petition Date, subject to a final reconcilation of the amount actually expended
prepetition. Upon final reconcilation of the amount actually expended prepetition, any balance
remaining from the prepetition payments to PSZ&J was credited to the Debtors and utilzed as
PSZ&J's retainer to apply to postpetition fees and expenses pursuant to the compensation
procedures approved by this Cour and the Banptcy Code.
Fee Statements
7. The fee statements for the Interim Period are attched hereto as Exhbit A.
These statements contain daily time logs describing the time spent by each attorney and
paraprofessional during the Interim Period. To the best ofPSZ&J's knowledge, this Application
complies with sections 330 and 331 of the Banptcy Code, the Banptcy Rules and the
Administrative Order. PSZ&J's time reports are initially handwritten by the attorney or
paralegal performing the described services. The time reports are organized on a daily basis.
PSZ&J is paricularly sensitive to issues of "lumping" and, unless time was spent in one time
frame on a varety of different matters for a paricular client, separate time entres are set forth in
the time reports. PSZ&J's charges for its professional services are based upon the time, nature,
extent and value of such services and the cost of comparable services other than in a case under
the Banptcy Code. PSZ&J has reduced its charges related to any non-working "travel time"
00233-001 \DOCS_DE: 148236,2 4
to fift percent (50%) ofPSZ&J's standard hourly rate. To the extent it is feasible, PSZ&J
professionals attempt to work during travel.
Actual and Necessary Expenses
8. A sumar of actual and necessary expenses incured by PSZ&J for the
Interim Period is attched hereto as par of Exhbit A. PSZ&J customarly charges $0.10 per
page for photocopying expenses related to cases, such as ths one, arsing in Delaware. PSZ&J's
photocopying machines automatically record the number of copies made when the person that is
doing the copying enters the client's account number into a device attched to the photocopier.
PSZ&J sumarzes each client's photocopying charges on a daily basis.
9. PSZ&J charges $1.00 per page for out-going facsimile transmissions.
There is no additional charge for long distance telephone calls on faxes. The charge for outgoing
facsimile transmissions reflects PSZ&J's calculation ofthe actul costs incurred by PSZ&J for
the machines, supplies and extra labor expenses associated with sending telecopies and is
reasonable in relation to the amount charged by outside vendors who provide similar services.
PSZ&J does not charge the Debtors for the receipt of faxes in this case.
10. With respect to providers of on-line legal research services (~, LEXIS
and WESTLA W), PSZ&J charges the standard usage rates these providers charge for
computerized legal research. PSZ&J bils its clients the actual amounts charged by such
services, with no premium. Any volume discount received by PSZ&J is passed on to the client.
11. PSZ&J believes the foregoing rates are the market rates that the majority
of law firms charge clients for such services. In addition, PSZ&J believes that such charges are
in accordance with the American Bar Association's ("ABA") guidelines, as set fort in the
00233-00 1 \DOCS_DE: 148236.2 5
ABA's Statement of Principles, dated Januar 12, 1995, regarding biling for disbursements and
other charges.
Summarv of Services Rendered
12. The names of the parers and associates ofPSZ&J who have rendered
professional services in these cases during the Interim Period, and the paralegals and case
management assistats of PSZ&J who provided services to these attorneys during the Interim
Period, are set forth in the attched Exhibit A.
13. PSZ&J, by and through such persons, has prepared and assisted in the
preparation of varous motions and orders submitted to the Cour for consideration, advised the
Debtors on a regular basis with respect to various matters in connection with the Debtors'
banptcy cases, and performed all necessar professional services which are described and
narated in detail below. PSZ&J's efforts have been extensive due to the size and complexity of
the Debtors' banptcy cases.
Summarv of Services bv Project
14. The services rendered by PSZ&J durng the Interim Period can be grouped
into the categories set fort below. PSZ&J attempted to place the services provided in the
category that best relates to such services. However, because certain services may relate to one
or more categories, services pertaining to one category may in fact be included in another
category. These services performed, by categories, are generally described below, with a more
detailed identification of the actual services provided set fort on the attched Exhibit A.
Exhbit A identifies the attorneys and paraprofessionals who rendered services relating to each
00233-001 \DOCS_DE: i 48236.2 6
category, along with the number of hours for each individual and the total compensation sought
for each category.
A. Asset Analvsis and Recoverv
15. During the Interim Period, the Firm, among other things, reviewed and
analyzed documents and pedormed work regarding insurance refud issues.
Fees: $1,161.00;
B. Appeals
16. During the Interim Period, the Firm, among other things, corresponded
Hours: 1.80
regarding appellate issues.
Fees: $95.00; Hours: 0.20
c. Bankruptcv Litie:ation
17. Durg the Interim Period, the Firm, among other things: (1) pedormed
work regarding a stipulation in the RFC matter; (2) performed work regarding a Class Action
Fairness Act Notice; (3) attended to issues regarding Ocwen; (4) attended to issues regarding
Bear Stears; (5) performed work regarding the Thompson matter; (6) performed work regarding
an extension of the removal deadline; (7) pedormed work regarding Agenda Notices and
Hearng Binders; (8) performed work regarding the Rommel matter; (9) performed work
regarding exhbits; (10) reviewed and analyzed documents; (11) pedormed work regarding
orders; and (12) corresponded and conferred regarding litigation issues.
Fees: $17,380.00; Hours: 33.50
00233.001\DOCS_DE:148236.2 7
D. Case Administration
18. Durng the Interim Period, the Firm, among other thngs: (1) maintained a
memorandum of Critical Dates; (2) prepared Hearng Binders; and (3) reviewed documents and
pleadings and forwarded them to appropriate paries.
Fees: $1,947.00; Hours: 12.20
E. Claims Administration and Obiections
19. During the Interim Period, the Firm, among other things: (1) reviewed
and analyzed documents; (2) performed work regarding a claims analysis; (3) attended to claims
reconcilation issues; (4) performed work regarding a stipulation in the RFC matter;
(5) performed work regarding claims objections; (6) attended to potential settlement issues in the
Countrde matter; (7) attended to discovery issues; (8) attended to scheduling issues;
(9) performed work regarding the resolution of claims objections; (10) performed work regarding
a Thd Omnbus objection to claims; (11) attended to claim objection withdrawal issues;
(12) erformed work regarding a stipulation in the Thompson matter; (13) attended to landlord
claim issues; (14) drafted a settlement stipulation in the Countrde matter; (15) performed
work regarding the Seminole County matter; and (16) corresponded and conferred regarding
claim issues.
Fees: $53,140.00; Hours: 84.60
F. Compensation of Professionals
20. This category includes work related to the fee applications of the Firm.
During the Interim Period, the Firm, among other things: (1) drafted the Firm's Januar 2009 fee
00233-00 1 \DCS_DE: 148236.2 8
application; (2) performed work regarding the Firm's Fifth quarerly fee application; and
(3) monitored the status and timing of fee matters.
Fees: $2,337.00; Hours: 5.60
G. Compensation of Professionals--Others
21. This category includes work related to the fee applications of
professionals, other than the Firm. Durng the Interim Period, the Firm, among other things,
performed work regarding the Deloitte fee matter.
Fees: $2,022.50; Hours: 7.50
H. Emplovee Benefits and Pensions
22. This category includes work related to employee benefits and pension
plans. Durng the Interim Period, the Firm, among other things: (1) performed work regarding a
WARN Act class action settlement; (2) reviewed and analyzed employee claims; (3) prepared for
and attended a hearng on WARN Act settlement issues on March 17,2009; (4) attended to
employee compensation issues; and (5) corresponded and conferred regarding employee issues.
Fees: $4,494.50; Hours: 8.00
I. Financial Filne:s
23. This category includes work related to compliance with reporting
requirements. During the Interim Period, the Firm, among other things, performed work
regarding Monthly Operating Reports.
Fees: $277.50; Hours: 0.90
00233-00 1 \DOCS_DE: 148236.2 9
J. Liti!!ation (Non-Bankruotcv)
24. This category includes work related to litigation in forus other than the
Banptcy Cour. Durng the Interim Period, the Firm, among other things, attended to issues
regarding Arizona litigation.
Fees: $802.50; Hours: 1.50
K. Plan and Disclosure Statement
25. This category includes work related to a Plan of Reorganization ("Plan")
and Disclosure Statement. Durng the Interim Period, the Firm, among other things:
(1) reviewed and analyzed documents; (2) attended to subordination issues; (3) attended to Plan-
related claim issues; (4) pedormed research; (5) attended to classification issues; (6) performed
work regarding a stipulation in the RFC matter; (7) reviewed and revised a Plan; (8) responded to
Committee comments regarding the Plan; (9) attended to disbursing agent issues; (10) attended
to REIT issues; (11) attended to release issues; (12) prepared for and participated in a conference
call with class action counsel regarding Plan issues; and (13) conferred and corresponded
regarding Plan issues.
Fees: $72,861.00; Hours: 105.00
L. Retention of Professionals-Others
26. This category includes work related to the retention of professionals, other
than the Firm. During the Interim Period, the Firm, among other things, pedormed work
regarding the Emphasys and Deloitte retention matters.
Fees: $4,460.00; Hours: 9.00
00233-001 \DS _DE: 148236,2 10
Valuation of Services
27. Attorneys and parprofessionals ofPSZ&J expended a tota269.80 hours
in connection with their representation of the Debtors durng the Interim Period, as follows:
Nämèof.Jlrof~$sio"arIndiVdtîat: ,d
"
Laura Davis Jones
Ira D. Kharasch
Alan J. Korneld
Henr C. Kevane
lain A. W. Nasitir
David M. Bertenthal
Kenneth H. Brown
James E. O'Neil
Joshua M. Fried
Scott E. McFarland
Curis A. Hehn
Gillan N. Brown
Wiliam L. Ramseyer
Miriam Khatiblou
00233-001 \DOCS_DE: 148236,2
" ,PósitiôïtollhêA' "liêánf:;,.\,
.~:trlÎ~~!t~t; .... ...'Experiênce, YeärolObtammg ..,'
License to Praçtice,Area of ,'.,Experte
Parner 2000; Joined Firm 2000;
Member of DE Bar since 1986Parer 1987; Member of CA Bar
since 1982Parer 1996; Member of CA Bar
since 1987Parner 1997; Member ofCa Barsince 1986Parner 1999; Member of NY Barsince 1983; Member of CA Barsince 1990Parer 1999; Member of CA Bar
since 1993Parner 2001; Member of CA Barsince i 981Parner 2005; Member of P A Barsince 1985; Member of DE Barsince 2001Parner 2006; Member of CA Barsince 1994; Member of NY Barsince 1999Of Counsel 2000; Member of CABar since 1993; Member of DEBar since 2002Parner 2006; Member of P A andNJ Bars since 1997; Member ofDE Bar since 2002Parner 2007; Member of CA BarSince 1999; Member ofWashington D.C. Bar since 2008Of Counsel; Member of CA Barsince 1980Of Counsel 2008; Member of CABar since 1995
11
:'d~H()Ûl'IY, '."., :;:'f()läl: :~;;'d:Tòtaln .,", . BiD . llôurs"C()mpensation" " ,.g" 'Rate' íJiled ' , '.,..,(ipcIliding,
. "'.
ChangèS)
$795.00 59.40 $47,223.00
$750.00 1.00 $ 750.00
$725.00 0.50 $ 362.50
$675.00 55.90 $37,732.50
$675.00 2.20 $ 1,485.00
$645.00 46.10 $29,734.50
$650.00 4.70 $ 3,055.00
$535.00 6.40 $ 3,424.00
$535.00 44.90 $24,021.50
$525.00 0.30 $ 157.50
$475.00 2.30 $ 1,092.50
$475.00 3.00 $ 1,425.00
$475.00 2.40 $ 1,140.00
$425.00 0.10 $ 42.50
Name ()fPl'ofé$sIolIål 'P " .ti"nh 'A ,. Ii "t HoUrly' ',', røtat Tòtal .'., OSt.,OlrO".. ~'P:P, ci¡tt,,",. ' .
IndiVd'aat", .,'. ".~!',;d,~:::lí~lff:~~e~2!nl..~'~.:',d..:,' ..~..:.i ,Bining /"; ;~;iløqr$.."" .:C~~pênsåtion '.
.' '.llåte ',' . " ømê(i' . . ,Experjènct',Y~arof 01ltâiimg. . (including
License fòPractice, Area' of . ' ChångeS) ., Expertse
,
Timothy P. Cairns Associate 2007; Member of DE $395.00 1.00 $ 395.00Bar since 2002
Kathleen P. Makowski Of Counsel 2008; Member of P A $395.00 5.40 $ 2,133.00Bar since 1996; Member of DE
Bar since 1997Leslie A. Forrester Law Librar Director 2003 $250.00 0.30 $ 75.00Patrcia J. Jeffes Paralegal 1999 $225.00 0.80 $ 180.00Kathe F. Finlayson Paralegal 2000 $225.00 22.50 $ 5,062.50Cheryl A. Knotts Paralegal 2000 $205.00 1.90 $ 389.50John F. Bass Paralegal 2008 $150.00 0.40 $ 60.00Sheryle L. Pitman Case Management Assistat 2001 $125.00 8.30 $ 1,037.50
Grand Total:Total Hours:Blended Rate: $
$ 160,978.00269.80596.66
28. The natue of work performed by these persons is fully set forth in
Exhibit A attched hereto. These are PSZ&J's normal hourly rates for work of this character.
The reasonable value of the services rendered by PSZ&J for the Debtors during the Interim
Period is $160,978.00.
29. In accordance with the factors enumerated in section 330 of the
Banptcy Code, it is respectfully submitted that the amount requested by PSZ&J is fair and
reasonable given (a) the complexity of the case, (b) the time expended, (c) the natue and extent
of the services rendered, (d) the value of such services, and (e) the costs of comparable services
other than in a case under the Banptcy Code. Moreover, PSZ&J has reviewed the
requirements of DeL. Ban. LR 2016-2 and the Administrative Order and believes that this
Application complies with such Rule and Order.
00233-00 1 \DCS_DE: 148236.2 12
WHEREFORE, PSZ&J respectfuly requests that, for the period March 1, 2009
through March 31, 2009, an interim allowance be made to PSZ&J for compensation in the
amount of$160,978.00 and actual and necessar expenses in the amount of$8,590.71 for a total
allowance of$169,568.71, and payment of$128,782.40 (80% of the allowed fees) and
reimbursement of$8,590.71 (100% of the allowed expenses) be authorized for a total payment of
$137,373.11 and for such other and fuher relief as this Cour may deem just and proper.
Dated: July JI 2009
aura Davis Jon Bar No. 2436)David M. Bettenthal (CA Bar No. 167624)James E. O'Neil (Bar No. 4042)
Joshua M. Fried, (CA Bar No. 181541)Curis A. Hehn (Bar No. 4264)
Timothy P. Cairns (Bar No. 4228)919 North Market Street, 17th FloorP.O. Box 8705Wilmington, DE 19899-8705Telephone: (302) 652-4100Facsimile: (302) 652-4400
Counsel to the Debtors and Debtors in Possession
00233-001 \DOCS_DE: 148236,2 13
VERIFICATION
STATE OF DELA WARE
COUNTY OF NEW CASTLE
Laura Davis Jones, after being duly sworn according to law, deposes and says:
a) I am a parner of the applicant law firm Pachulski Stag Ziehl & Jones
LLP, and have been admitted to appear before this Cour.
b) I am familar with the work performed on behalf of the Debtors by the
lawyers and paraprofessionals of PSZ&J.
c) I have reviewed the foregoing Application and the facts set fort therein
are tre and correct to the best of my knowledge, information and belief. Moreover, I have
reviewed DeL. Ban. LR 2016-2 and the Administrative Order entered on or about September 5,
2007, and submit that the Application substantially complies with such Rule and Order.
JSWORN AND Slp~SCRIBEDbefore . is J1dã of
otar Public
My Commission Expires:
NESSA A. ~RESTON'NOTARY PUBLIC. , OF DELAWARE
~ flFf8" ~xpires March 21, 2010
00233-00 1 \DOCS_DE: 148236.2