IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) Debtor.

Transcription

1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: ARCHDIOCESE OF MILWAUKEE, Debtor. ) ) ) ) ) ) ) Chapter 11 Case No SVK ELEVENTH INTERIM FEE APPLICATION OF BERKELEY RESEARCH GROUP, LLC, FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR THE PERIOD AUGUST 1, 2015 THROUGH SEPTEMBER 30, 2015 By this eleventh interim fee application (the Application ), Berkeley Research Group, LLC ( BRG or Applicant ), financial advisor to the Official Committee of Unsecured Creditors (the Committee ), respectfully requests issuance of an order pursuant to 11 U.S.C. 330, Federal Rule of Bankruptcy Procedure 2016, Local Rule 2016 of the United States Bankruptcy Court for the Eastern District of Wisconsin, and this Court s Order Granting Debtor s Motion to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 158]: 1. On January 4, 2011 (the Petition Date ), the Archdiocese of Milwaukee (the Debtor ) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code (the Code ). 1 Case svk Doc 3333 Filed 11/17/15 Page 1 of 27

2 2. On or about January 24, 2011, the United States Trustee appointed the Committee to represent the Debtor s unsecured creditors pursuant to 11 U.S.C. 1102(a)(1). 3. On April 11, 2011, the Committee filed an application with this Court for authorization to employ BRG pursuant to 11 U.S.C. 328, 504, 1102 and 1103 and Federal Rules of Bankruptcy Procedure 2014 and On July 19, 2011, this Court entered an order authorizing the Committee to employ BRG as financial advisor for the Committee effective as of March 3, BRG has rendered services during the period from August 1, 2015 through September 30, 2015 (the Compensation Period ) totaling 7.2 hours. 6. BRG maintains contemporaneous records of the time expended for the professional services and expenses performed in connection with this chapter 11 case. These records are maintained in the ordinary course of BRG s business. These records provide a detailed description of the services rendered and expenses incurred during the period for which this Application is being made. A summary of BRG s fees and expenses during the Compensation Period totaling $3, ($3, in fees and no expenses) is marked as Exhibit A. BRG notes that its fees and expenses are customary charges made to other firm clients in the ordinary course of BRG s billing practice. 2 Case svk Doc 3333 Filed 11/17/15 Page 2 of 27

3 7. Exhibit B contains the detailed time entries for the services provided by category by BRG as accountants and consultants to the Committee during the Compensation Period, as well as the detail of all costs expended. 8. Exhibit C is the summary of the monthly fees, by category of service, as well as a summary of the expenses incurred. 9. Exhibit D is a schedule that sets forth the total hours each BRG professional and paraprofessional has expended in this case during the Compensation Period and the hourly rates for those services. The average hourly billing rate for BRG was $ All travel by BRG professionals in this case was billed at 50% of the professionals hourly rates. 10. Exhibit E includes the resumes that describe the education and qualifications of the BRG professionals and paraprofessionals who billed time during the Compensation Period. 11. Exhibit F is a schedule of Applicant s hourly billing rates for 2015 for this market. These were the rates charged by Applicant s personnel to solvent clients where Applicant ordinarily receives payment in full within less than 90 days. Applicant carefully reviewed all time charges to ensure they were reasonable and non-duplicative. Costs and disbursements were also reviewed. Time was billed in tenths of an hour. 12. It is the practice of the BRG bankruptcy group ( Group ) involved in this chapter 11 matter to conduct the initial evaluation of case issues and perform the related analysis at a director or senior manager level. The Group follows this practice in 3 Case svk Doc 3333 Filed 11/17/15 Page 3 of 27

4 order to ensure that the key issues are identified and relevant areas of analysis are determined prior to assigning lower level staff. Based on the Group s past experience, this approach provides the most efficient, cost-effective results. 13. As previously referenced, Exhibit C to this Application contains a summary of BRG s bill for the period from August 1, 2015 through September 30, 2015, separated into the following billing categories: a. General Accounting Analysis (Task Code ) [Total hours: 1.6, total fees: $688.00]: During the Compensation Period, BRG evaluated outstanding case accounting matters and reviewed related case files and records. b. Document Analysis (Bankruptcy Filings / Motions) (Task Code ) [Total hours: 1.1, total fees: $473.00]: BRG analyzed the Debtor s Monthly Financial Reports ( MFR ) (and additional supporting documentation including bank account statements and receipt and disbursement transaction reports) for the months of May 2015 through August BRG performed these services in order to monitor post-petition financial activities, including assets and cash receipt and disbursement activity. c. Fee Application Preparation and Hearing (Task Code ) [Total hours: 4.5, total fees: $1,944.50]: During the Compensation Period, BRG prepared, finalized and filed its tenth interim fee application covering the time period from April 1, 2015 through July 31, Case svk Doc 3333 Filed 11/17/15 Page 4 of 27

5 14. BRG had no expenses during the Compensation Period. 15. BRG states that it has not received any compensation for services rendered and expenses incurred during the Compensation Period. 16. Without regard to the Compensation Period, BRG has not represented any entity in this case having an adverse interest to the Committee. WHEREFORE, BRG prays this Court to enter an Order in the form attached hereto as Exhibit G granting BRG compensation for the period from August 1, 2015 through September 30, 2015 in the amount of $3, (which constitutes 100% of the total amount of BRG fees incurred during the Compensation Period) and no expenses. Dated: November 16, 2015 Respectfully submitted, BERKELEY RESEARCH GROUP, LLC By /s/ Matthew K. Babcock Berkeley Research Group, LLC 201 South Main Street, Suite 450 Salt Lake City, UT Telephone: (801) Facsimile: (801) mbabcock@brg-expert.com Financial Advisor to the Official Committee of Unsecured Creditors 5 Case svk Doc 3333 Filed 11/17/15 Page 5 of 27

6 EXHIBIT A Case svk Doc 3333 Filed 11/17/15 Page 6 of 27

7 ARCHDIOCESE OF MILWAUKEE August 1, 2015 through September 30, 2015 SUMMARY OF PROFESSIONAL SERVICES & EXPENSES TASK CODE DESCRIPTION AVERAGE RATE HOURS AMOUNT General Accounting Analysis $ $ Document Analysis (Bankruptcy Filings / Motions) Fee Application Preparation & Hearing , Total Professional Services $ $ 3, Total Expenses $ - Total Professional Services & Expenses $ 3, Case svk Doc 3333 Filed 11/17/15 Page 7 of 27

8 EXHIBIT B Case svk Doc 3333 Filed 11/17/15 Page 8 of 27

9 ARCHDIOCESE OF MILWAUKEE August 1, 2015 through September 30, 2015 PROFESSIONAL SERVICES - TIME DESCRIPTIONS DATE NAME DESCRIPTION HOURS RATE AMOUNT Task Code: General Accounting Analysis 08/12/15 M Babcock Reviewed status of case, including correspondence and 1.00 $ $ accounting files / records. 08/14/15 M Babcock Reviewed and organized accounting files and records Total for Task Code $ Task Code: Document Analysis (Bankruptcy Filings / Motions) 09/16/15 M Babcock Examined monthly financial reports and related supporting documentation (May 2015 through August 2015) $ $ Total for Task Code $ Task Code: Fee Application Preparation & Hearing 08/10/15 M Babcock Prepared 10th interim fee application, including review and categorization of time descriptions and preparation of narrative $ $ /11/15 M Babcock Updated 10th interim fee application /14/15 P Shields Reviewed sections in fee application relating to solvency and claims analysis. 08/24/15 M Babcock Finalized 10th interim fee application and provided to local counsel for filing Total for Task Code $ 1, Total Professional Services 7.2 $ 3, Case svk Doc 3333 Filed 11/17/15 Page 9 of 27

10 ARCHDIOCESE OF MILWAUKEE August 1, 2015 through September 30, 2015 EXPENSES DATE DESCRIPTION AMOUNT $ - Total Expenses $ - 3 Case svk Doc 3333 Filed 11/17/15 Page 10 of 27

11 EXHIBIT C Case svk Doc 3333 Filed 11/17/15 Page 11 of 27

12 Case svk Doc 3333 Filed 11/17/15 Page 12 of 27 ARCHDIOCESE OF MILWAUKEE August 1, 2015 through September 30, 2015 SUMMARY OF PROFESSIONAL SERVICES & EXPENSES - MONTHLY Category Hours General Accounting Analysis $ $ - $ Document Analysis (Bankruptcy Filings / Motions) Fee Application Preparation & Hearing 1, , Total Monthly Fees Aug Expenses Amount $ 2, $ $ 3, $ - Total $ - Sep Total Category Fees Total Category TOTAL FEES $ 3, TOTAL HOURS 7.2 TOTAL FEES & EXPENSES $ 3, BRG, LLC Fed ID No AVERAGE BILLING RATE $ Matter #908 4

13 EXHIBIT D Case svk Doc 3333 Filed 11/17/15 Page 13 of 27

14 ARCHDIOCESE OF MILWAUKEE August 1, 2015 through September 30, 2015 PROFESSIONAL SERVICES - TIMEKEEPER SUMMARY Director 2015 RATE HOURS AMOUNT Paul Shield $ $ Senior Managing Consultant Matt Babcock , TOTAL FEES 7.2 $ 3, AVERAGE BILLING RATE $ Case svk Doc 3333 Filed 11/17/15 Page 14 of 27

15 EXHIBIT E Case svk Doc 3333 Filed 11/17/15 Page 15 of 27

16 Curriculum Vitae PAUL N. SHIELDS BERKELEY RESEARCH GROUP, LLC 201 South Main Street, Suite 450 Salt Lake City, UT Direct: SUMMARY Paul N. Shields is a Managing Director at Berkeley Research Group. He has over twenty years of experience as a financial analyst and valuation expert. His professional designations include Chartered Financial Analyst (CFA), Certified Public Accountant (CPA), Certification in Distressed Business Valuation (CDBV), and Accredited in Business Valuation (ABV). Mr. Shields has expertise in business valuation, damage assessments and the evaluation of earnings capacity particularly in the context of financial distress and bankruptcy. Mr. Shields has performed numerous solvency studies, and has evaluated business interests and assets for corporate reorganizations and distressed sales. He has testified in federal and state courts, and has performed services as a special master and mediator. CASE EXAMPLES Bankruptcy Estate of Vickie Lynn Marshall (a/k/a Anna Nicole Smith) Supervised the valuation of Koch Industries, Inc., the second largest closely held business in the United States. The valuation was performed to assist counsel representing Ms. Marshall in her litigation against E. Pierce Marshall, the son of J. Howard Marshall II. The IT Group, Inc. Assessed the reorganization value of The IT Group for purposes of plan confirmation. At the time, The IT Group had annual revenues in excess of $1.3 billion and was a leading provider of diversified environmental consulting, engineering, construction, remediation, and facilities management services. Bonneville Pacific Corporation Assisted in supervising the damage study involving a bankrupt independent power producer. Responsibilities included tracing funds and analyzing transactions in excess of $5.5 billion over a six-year period. Webvan Group, Inc. Supervised the solvency analysis of a leading online e-grocer. Funding received by the company from public and private sources exceeded $800 million. The solvency analysis was performed in the context of avoidance actions. Arthur D. Little, Inc. Supervised the solvency analysis of an international technology and management consulting firm with annual revenues in excess of $450 million. The solvency analysis was performed in the context of avoidance actions. Case svk Doc 3333 Filed 11/17/15 Page 16 of 27

17 Vann s, Inc. Assessed the solvency of, and evaluated alleged damages incurred by, a consumer electronics retailer with annual revenue in excess of $100 million. The solvency analysis was performed in the context of avoidance actions. JD Services, Inc. Assessed the solvency of a full-service prepaid long distance phone company. The company s annualized revenues were in excess of $100 million. The solvency analysis was performed in the context of avoidance actions. Case Name Withheld Performed services as a consulting expert in the context of a contested, leveraged transaction. At issue, among other things, was the solvency of the combined entities subsequent to a leveraged transaction. Case Name Withheld Prepared the valuation of a grocery store chain with annual revenues in excess of $100 million. Case Name Withheld Prepared the valuation of an aftermarket auto parts distributor with annual revenues of approximately $70 million. Case Name Withheld Prepared the valuation of a mechanical contractor with annual revenues in excess of $50 million. Michael Gerard Mike Tyson Prepared the valuation of assets transferred to a liquidation trust in accordance with IRS Revenue Procedure in the context of a bankruptcy proceeding. Le-Nature s, Inc. Prepared the valuation of assets transferred to a liquidation trust in accordance with IRS Revenue Procedure in the context of a bankruptcy proceeding. Calcor Space Facility, Inc. Assessed the solvency of an aircraft parts manufacturer. The company s annual revenues were approximately $50 million. The solvency analysis was performed in the context of avoidance actions. G.I. Industries, Inc. Assessed the reorganization value of Conejo Enterprises, Inc., a wholly owned subsidiary of G.I. Industries, Inc., for purposes of plan confirmation. Conejo Enterprises, Inc. was a solid waste disposal company with annual revenues of $17 million. EDUCATION Bachelor of Arts in Accounting, University of Utah Master of Business Administration, University of Utah Case svk Doc 3333 Filed 11/17/15 Page 17 of 27 2

18 PROFESSIONAL AFFILIATIONS CFA Institute Association of Insolvency and Restructuring Advisors American Bankruptcy Institute American Institute of Certified Public Accountants Utah Association of Certified Public Accountants INSTRUCTION, PRESENTATIONS & PUBLICATIONS Mr. Shields has provided instruction on valuation in the context of financial distress and bankruptcy at conferences for the American Bankruptcy Institute, the Association of Insolvency and Restructuring Advisors, the American Institute of Certified Public Accountants, and the Utah Association of Certified Public Accountants. Co-author of Business Valuation in Bankruptcy, a Consulting Services Practice Aid published by the American Institute of Certified Public Accountants in Case svk Doc 3333 Filed 11/17/15 Page 18 of 27 3

19 Curriculum Vitae MATTHEW K. BABCOCK SENIOR MANAGING CONSULTANT BERKELEY RESEARCH GROUP, LLC 201 South Main Street, Suite 450 Salt Lake City, Utah Direct: Fax: SUMMARY Matthew K. Babcock is a Senior Managing Consultant with Berkeley Research Group, LLC ( BRG ). Mr. Babcock is a Certified Public Accountant, Certified in Financial Forensics (CPA / CFF), a Certified Fraud Examiner (CFE) and a Certified Insolvency and Restructuring Advisor (CIRA) with over 17 years of experience providing services in bankruptcy, forensic / investigative accounting, and litigation support. Prior to BRG, Mr. Babcock worked with LECG LLC, Neilson Elggren LLP, Arthur Andersen, Neilson Elggren Durkin & Company and the Federal Bureau of Investigation ( FBI ). As an Honors Intern with the FBI, Mr. Babcock was assigned to work with the Office of Independent Counsel investigating former Secretary of Agriculture Mike Espy. Mr. Babcock has served in numerous bankruptcy and insolvency matters, including court appointments as Receiver, Accountant to the Trustee, Accountant to the Liquidating Estate Manager, Accountant to the Debtor and Financial Advisor to the Official Committee of Unsecured Creditors. His experience includes the investigation of alleged insider dealings, investigation and pursuit of preferences, fraudulent transfers and other causes of action, tracing of funds, financial data reconstruction, liquidation and substantive consolidation analyses, plan feasibility analyses, plan preparation, solvency analyses, claims analysis / resolution and liquidation of assets. He has assisted Trustees in operating Chapter 11 companies, including analyzing prior and on-going operations, developing cash flow projections, budgeting, and managing other day-to-day accounting activity. Mr. Babcock has provided both civil and criminal litigation support services, including the investigation of fraud and mismanagement, tracing of funds, partner disputes, lost profit damages, patent infringement damages, breach of contract, economic analyses, and financial record reconstruction. Mr. Babcock has significant training and experience investigating fraud and mismanagement, including financial statement fraud, Ponzi schemes, embezzlement schemes, check kiting, bank fraud, and bankruptcy fraud. He has conducted numerous presentations relating to business fraud, financial statement fraud, bankruptcy fraud, and other fraud schemes. He has also served as a professional faculty member at the University of Utah, assisting in the instruction of the University s "Fraud Examination & Forensic Accounting" course. 8/21/ Page 1 of 4 Case svk Doc 3333 Filed 11/17/15 Page 19 of 27

20 Curriculum Vitae CASE EXAMPLES Albright et al v. Attorneys Title Insurance Fund et al: Litigation Experts (damage study) Archdiocese Of Milwaukee: Financial Advisor to the Official Committee of Unsecured Creditors (services included asset identification / tracing) Beehive State, LLC: State Court Receiver Benson Bolt v. Zions First National Bank: Litigation Experts (damage study) Bruce P. McNall: Accountants to the Trustee C3 Investments: Accountants to the Debtor Case Name Withheld: Financial Advisor to a Prince of a Royal Family (services included asset identification / tracing) Case Name Withheld: Forensic Accountant (services included investigation of alleged embezzlement / fraud) Castle Arch Real Estate Investment Company LLC: Accountants to the Trustee Catholic Diocese Of Wilmington, Inc.: Financial Advisor to the Official Committee of Unsecured Creditors (services included asset identification / tracing) Diocese Of Stockton: Financial Advisor to the Official Committee of Unsecured Creditors (services included asset identification / tracing) DVI, Inc.: Accountants to the Examiner Husting Land & Development, Inc.: Accountants to the Trustee JD Services, Inc.: Accountants to the Trustee Le-Nature s, Inc.: Accountants to the Trustee Marshall v. Marshall: Litigation Experts (damage study) National School Fitness Foundation: Accountants to the Trustee Natural Wonders, Inc. / World Of Science, Inc.: Accountants to the Liquidating Estate Manager Promega v. Lifecodes: Litigation Experts (patent infringement damage study) Revolution Dairy LLC et al: Financial Advisor to the Official Committee of Unsecured Creditors Rich International Airways, Inc.: Accountants to the Liquidating Trustee Semnani v. USPCI: Litigation Experts (damage study) Society of Jesus Oregon Province: Financial Advisor to the Official Committee of Unsecured Creditors (services included asset identification / tracing) Tri-Valley Distributing, Inc.: Accountants to the Examiner William J. Del Biaggio III: Accountants to the Trustee Wolf Creek Properties LC: Financial Advisors to the Unsecured Creditors Committee INDUSTRY EXPERIENCE Automotive Construction Dairy Financial / Securitizations Internet / Telecommunications Manufacturing Not-For-Profit / Religious Institutions Professional Sports Retail Real Estate Transportation Waste Disposal 8/21/ Page 2 of 4 Case svk Doc 3333 Filed 11/17/15 Page 20 of 27

21 Curriculum Vitae EMPLOYMENT HISTORY 2011 Present BRG, LLC Senior Managing Consultant LECG, LLC Senior Managing Consultant ( ) Managing Consultant ( ) Neilson Elggren LLP Senior Manager (2005) Manager ( ) Senior Accountant ( ) Arthur Andersen Senior Accountant ( ) Staff Accountant ( ) Neilson Elggren Durkin & Company Staff Accountant (1998) Intern ( ) Summer 1996 Summer 1995 Federal Bureau of Investigation Honors Intern (Washington DC) Federal Bureau of Investigation Intern (Albuquerque, New Mexico) EDUCATION Bachelor of Science in Accounting (Magna Cum Laude), Brigham Young University, April 1998 Master of Professional Accountancy, Brigham Young University, April 1998 LICENSES & CERTIFICATIONS Certified Public Accountant Utah Certified Fraud Examiner (CFE) Certified Insolvency & Restructuring Advisor (CIRA) Certified In Financial Forensics (CFF) 8/21/ Page 3 of 4 Case svk Doc 3333 Filed 11/17/15 Page 21 of 27

22 Curriculum Vitae PROFESSIONAL MEMBERSHIPS American Institute of Certified Public Accountants Utah Association of Certified Public Accountants Association of Insolvency and Restructuring Advisors Association of Certified Fraud Examiners American Bankruptcy Institute INSTRUCTION, PRESENTATIONS & PUBLICATIONS Brigham Young University Business Fraud (March 1999) Brigham Young University Business and Financial Statement Fraud (March 2000) Brigham Young University Financial Statement Fraud and the Role of the Forensic Accountant (March 2001, April 2002, April 2003, April 2004 and November 2005) Brigham Young University Forensic Accounting (January 2006 & October 2010) Utah State University Forensic Accounting (October 2010) Turnaround Management Association Professional Ethics (November 2011) Brigham Young University Forensic Accounting and Fraud Investigations (December 2011) Association Of Certified Fraud Examiners (Utah Chapter) Bankruptcy and Ponzi Schemes (December 2012) Brigham Young University Life as a Forensic Accountant (April 2013) Brigham Young University Ethical Dilemmas and Fraud (March 2014) California Bankruptcy Forum / California Bankruptcy Conference Where the Rubber Hits the Road: Claims and Claims Objections (May 2014) University Of Utah Fraud Examination and Forensic Accounting (Accounting 6540) / Professional Faculty (Spring Semester 2011 through Spring Semester 2015) 8/21/ Page 4 of 4 Case svk Doc 3333 Filed 11/17/15 Page 22 of 27

23 EXHIBIT F Case svk Doc 3333 Filed 11/17/15 Page 23 of 27

24 Berkeley Research Group, LLC ("BRG") Schedule of Billing Rates 2015 Position Rate Director $ Managing Consultant Consultant Junior Staff Paraprofessional Case svk Doc 3333 Filed 11/17/15 Page 24 of 27

25 EXHIBIT G Case svk Doc 3333 Filed 11/17/15 Page 25 of 27

26 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: ARCHDIOCESE OF MILWAUKEE, Debtor. ) ) ) ) ) ) Chapter 11 Case No SVK [PROPOSED] ORDER GRANTING ELEVENTH INTERIM FEE APPLICATION OF BERKELEY RESEARCH GROUP, LLC, FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS, FOR THE PERIOD AUGUST 1, 2015 THROUGH SEPTEMBER 30, 2015 The Court having considered the Eleventh Interim Fee Application of Berkeley Research Group, LLC, Financial Advisor to the Official Committee of Unsecured Creditors, for Interim Compensation and Reimbursement of Expenses For The Period August 1, 2015 Through September 30, 2015 (the Application ), and good cause appearing therefore: IT IS HEREBY ORDERED: 1. The Application is approved. 2. Pursuant to the Order Granting Debtor s Motion to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 158], the Debtor Archdiocese of Milwaukee is authorized to pay Berkeley Research Group, LLC ( BRG ) the sum of $3, in compensation of 100% of BRG s fees and no expenses for a total of $3, for the period from August 1, 2015 through September 30, Pursuant to the Order Granting Modification of Debtor s Motion to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Case svk Doc 3333 Filed 11/17/15 Page 26 of 27

27 Professionals [Docket No. 1784], the Debtor Archdiocese of Milwaukee s duty to pay professionals has been suspended. 4. The fees awarded herein are subject to final review and recoupment. ###### Case svk Doc 3333 Filed 11/17/15 Page 27 of 27

28 UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: Archdiocese of Milwaukee Case No SVK Chapter 11 Debtor in Possession, NOTICE OF ELEVENTH INTERIM APPLICATION OF BERKELEY RESEARCH GROUP, LLC, FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES (FOR THE PERIOD AUGUST 1, 2015 THROUGH SEPTEMBER 30, 2015 TO: Interested Parties PLEASE TAKE NOTICE that Berkeley Research Group, LLC ( BRG ), Financial Advisor for the Official Committee of Unsecured Creditors, has filed their Application for Interim Compensation and Reimbursement of Expenses for the period August 1, 2015 Through September 30, The Fees and Expenses are as follows: Applicant Fees Expenses Total Berkeley Research Group, LLC $3, $0.00 $3, Your rights may be affected. You should read these papers carefully and discuss them with your attorney, if you have one in this bankruptcy case. (If you do not have an attorney, you may wish to consult one.) Prepared By: Albert Solochek Jason R. Pilmaier 1845 N. Farwell Ave., Suite 301 Milwaukee, WI (414) Telephone (414) Facsimile alsolochek@hswmke.com jpilmaier@hswmke.com Case svk Doc Filed 11/17/15 Page 1 of 3

29 If you do not want the Court to approve the application, or if you would like the Court to consider your views on it, then within 14 days of the date of this notice, you or your attorney must: 1. File with the court a written objection to the motion and a request for a hearing at: Clerk, U. S. Bankruptcy Court Room 126, Federal Courthouse 517 E. Wisconsin Avenue Milwaukee, WI If you mail your objection to the court for filing, you must mail it early enough so the court will receive it on or before the date stated above. You must also mail a copy to: Berkeley Research Group, LLC Attn: Matthew Babcock 201 S. Main Street, Suite 450 Salt Lake City, UT If you mail your Response to the Court for filing, you must mail it early enough so the Court will receive it on or before the date stated above. If you or your attorney do not take these steps, the Court may decide that you do not oppose the motion and may enter an order approving it without further notice or hearing. Case svk Doc Filed 11/17/15 Page 2 of 3

30 Dated: November 17, 2015 Respectfully submitted, PACHULSKI STANG ZIEHL & JONES LLP By /s/albert Solochek James I. Stang (CA Bar No ) Kenneth H. Brown (CA Bar No ) Gillian N. Brown (CA Bar No ) Pachulski Stang Ziehl & Jones LLP Santa Monica Blvd., 13 th Floor Los Angeles, CA Telephone: (310) Facsimile: (310) and- Albert Solochek (State Bar No ) Jason R. Pilmaier (State Bar No ) Howard, Solochek & Weber, S.C N. Farwell Ave., Suite 301 Milwaukee, WI Telephone: (414) Facsimile: (414) Attorneys for the Committee of Unsecured Creditors Case svk Doc Filed 11/17/15 Page 3 of 3

31 UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: Archdiocese of Milwaukee Case No SVK Chapter 11 Debtor in Possession, CERTIFICATE OF SERVICE Jason R. Pilmaier, being first duly sworn on oath deposes and says that on November 17, 2015, I caused to be served to the parties listed on the attached Exhibit A as electronic mail recipients via , and I caused to be served to the parties listed on the attached Exhibit A as U.S. mail recipients via first class mail, postage prepaid, a copy of the following documents filed: (i) (ii) Eleventh Interim Fee Request of Berkeley Research Group, LLC, Financial Advisor to the Official Committee of Unsecured Creditors for the Period August 1, 2015 Through September 30, 2015 Notice of Eleventh Interim Fee Request of Berkeley Research Group, LLC, Financial Advisor to the Official Committee of Unsecured Creditors for the Period August 1, 2015 Through September 30, 2015 /s/ Jason R. Pilmaier Howard Solochek & Weber, S.C N. Farwell Ave., Suite 301 Milwaukee, WI (414) (414) asolochek@hswmke.com jpilmaier@hswmke.com Prepared by: Albert Solochek Jason Pilmaier Howard Solochek & Weber, S.C N. Farwell Ave., Suite 301 Milwaukee, WI (414) (414) asolochek@hswmke.com jpilmaier@hswmke.com Case svk Doc Filed 11/17/15 Page 1 of 3

32 In re Archdiocese of Milwaukee November 2015 Electronic Mail Service Recipients PARTY NAME PARTY NOTICE NAME ADDRESS 1 ADDRESS 2 CITY STATE ZIP PHONE FAX PARTY DESCRIPTION Co-counsel to Jeff Anderson & Associates, paul@aikenandscoptur.com; Aiken & Scoptur SC Paul J Scoptur & James P Scoptur 2600 N Mayfair Rd Ste 1030 Milwaukee WI PA james@aikenandscoptur.com Archdiocese of Milwaukee Attn John Marek CFO 3501 S Lake Dr Milwaukee WI Debtor and Debtor in Possession marekj@archmil.org Archdiocese of Milwaukee Julie A Wolf Dir of Communications 3501 S Lake Dr Milwaukee WI Debtor and Debtor in Possession wolfj@archmil.org Becket & Lee LLP Gilbert B Weisman POB 3001 Malvern PA Attorneys for American Express Travel Related Services Co, Inc notices@becket-lee.com David Christian Attorneys LLC Darin J. Van Thournout 3515 W 75th St Ste 208 Prairie Village KS Counsel for Continental Casualty Co. dvanthournout@davidchristianattorneys.com David Christian Attorneys LLC David Christian 3515 W 75th St Ste 208 Prairie Village KS Counsel for Continental Casualty Co. dchristian@davidchristianattorneys.com Duane Morris LLP Russell W Roten & Jeff D. Kahane 865 S. Figueroa St, Suite 3100 Los Angeles CA Counsel for Certain Underwriters at Lloyd's, London and Certain London Market Companies jkahane@duanemorris.com Foley & Lardner LLP Rachel M. Blise 777 East Wisconsin Avenue Milwaukee WI Counsel for Milwaukee Bucks, Inc. rblise@foley.com Godfrey & Kahn SC Timothy F Nixon 780 N Water St Milwaukee WI Howard, Solochek & Weber, S.C. Howard, Solochek & Weber, S.C. Jacobs & Crumplar, PA Albert Solochek Jason Pilmaier Counsel for Archdiocese of Milwaukee Catholic Cemetery Perpetual Care Trust tnixon@gklaw.com 324 E. Wisconsin Avenue, Suite 1100 Milwaukee WI alsolochek@hswmke.com 324 E. Wisconsin Avenue, Suite 1100 Milwaukee WI jpilmaier@hswmke.com Thomas C Crumplar & Raeann Warner 2 E. 7th St PO Box 1271 Wilmington DE Counsel for Claimant A-96 Tom@jcdelaw.com; Raeann@jcdelaw.com; Regina@jcdelaw.com Counsel to Certain Creditors listed on Jeff Anderson & Associates PA Attn Jeff Anderson 366 Jackson St Ste 100 St Paul MN Debtor s 20 Largest jeff@andersonadvocates.com Joseph E Fenzel SC 757 N Broadway Ste 600 Milwaukee WI Counsel to Secured Lender Park Bank jfenzel@fenzellaw.com Law Office of William J. Factor, Ltd. William J. Factor & Jeffrey K. Paulsen 105 W. Madison St, Ste 1500 Chicago IL Nelson, Connell, Conrad, Tallmadge & Slein, S.C. Philip J. Tallmadge & Mark S. Nelson N14 W23755 Stone Ridge Drive, Suite 150 P.O. Box 1109 Waukesha WI Pachulski Stang Ziehl & Jones Attn Gillian N Brown Esq Santa Monica Blvd 13th Floor Los Angeles CA Pachulski Stang Ziehl & Jones Attn James I Stang Esq Santa Monica Blvd 13th Floor Los Angeles CA Pachulski Stang Ziehl & Jones Attn Ken Brown Esq 150 California St 15th Fl San Francisco CA Peterson Johnson & Murray SC James T Murray Jr 733 N Van Buren St 6th Fl Milwaukee WI Counsel for Stonewall Insurance Co. and Commercial Union Insurance Co. nka OneBeacon Insurance Co. Counsel for Stonewall Insurance Co. and Commercial Union Insurance Co. nka OneBeacon Insurance Co. Counsel to Official Committee of Unsecured Creditors Counsel to Official Committee of Unsecured Creditors Counsel to Official Committee of Unsecured Creditors Counsel to Archbishop Rembert G. Weakland wfactor@wfactorlaw.com slorber@wfactorlaw.com jpaulsen@wfactorlaw.com ptallmadge@ncctslaw.com; mnelson@ncctslaw.com gbrown@pszjlaw.com jstang@pszjlaw.com kbrown@pszjlaw.com jmurray@pjmlaw.com PREVIANT GOLDBERG UELMEN GRATZ MILLER & BRUEGGEMAN SC Christopher J Ahrens 1555 N RiverCenter Dr Ste 202 PO Box Milwaukee WI Counsel for Milwaukee Laborer s Local 113 cja@previant.com Special Counsel to the Debtor and Debtor in jar@quarles.com Quarles & Brady LLC John A Rothstein 411 E Wisconsin Ave Ste 2040 Milwaukee WI Possession dpm@quarles.com Robert L Elliott Attorney at Law 735 N Water St #1212 Milwaukee WI Counsel to four creditors rle@attorneyelliott.com Sedgwick LLP Smith Gunderson & Rowen SC Catalina J Sugayan & Marcos G Cancio One North Wacker Dr Ste 4200 Chicago IL James S Smith & Wendy G Gunderson & Michele Marsh W Capitol Dr Ste 100 Brookfield WI State of Wisconsin Department of Public Instruction Ann C Murphy Asst Atty Gen Wisconsin Dept of Justice PO Box 7857 Madison WI Counsel for Certain Underwriters at Lloyd's, London and Certain London Market Companies Attorneys for Certain Personal Injury Claimants; Counsel for Claimant A-61 State of Wisconsin Department of Public Instruction US Trustees Office David W Asbach 517 E Wisconsin Ave Room 430 Milwaukee WI Office of the United States Trustee von Briesen & Roper, s.c. Christopher J Schreiber Esq 411 E Wisconsin Ave Ste 700 Milwaukee WI von Briesen & Roper, s.c. Randall D Crocker Esq 411 E Wisconsin Ave Ste 700 Milwaukee WI Attorneys for Mork Mausoleum Construction, Inc. Attorneys for De Sales Preparatory Seminary, Inc. and Saint Francis De Sales Seminary, Inc. catalina.sugayan@sedgwicklaw.com marcos.cancio@sedgwicklaw.com jsmith@sgr-law.com wgunders@sgr-law.com mmarsh@sgr-law.com murphyac@doj.state.wi.us dave.w.asbach@usdoj.gov debra.schneider@usdoj.gov cschreib@vonbriesen.com rcrocker@vonbriesen.com Case svk Doc Filed 11/17/15 Page 2 of 3 Page 1 of 2

33 In re Archdiocese of Milwaukee November 2015 Electronic Mail Service Recipients PARTY NAME PARTY NOTICE NAME ADDRESS 1 ADDRESS 2 CITY STATE ZIP PHONE FAX PARTY DESCRIPTION Whyte Hirschboeck Dudek SC ddiesing@whdlaw.com Attn Daryl L Diesing & Bruce G Arnold & Michael E Gosman & Francis H LoCoco 555 E Wells St Ste 1900 Milwaukee WI barnold@whdlaw.com mgosman@whdlaw.com Counsel to Debtor and Debtor in Possession flococo@whdlaw.com Wisconsin Department of Revenue Special Procedures Unit 2135 Rimrock Road 5-SPU Attn Hiram F Cutting Madison WI Wisconsin Department of Revenue hiram.cutting@revenue.wi.gov U.S. Mail Service Recipients Brennan Law Offices, LLC Patrick Cavanaugh Brennan 1110 N. Old World 3rd Street Suite 200 Milwaukee WI Attorney fo Claimant A-157 Charles Linneman (Acting Chairperson) c/o Jeff Anderson 366 Jackson Street St. Paul MN Dean Weissmueller c/o Jeff Anderson 366 Jackson Street St. Paul MN Department of Workforce Development Division of Unemployment Insurance PO Box 8914 Madison WI Department of Workforce Development Division of Unemployment Insurance Attn Maie Griner Data IKON Financial Services Bankruptcy Administration PO Box Coordinator Macon GA IKON Financial Services Internal Revenue Service Advisor/Reviewer 3101 Constitution Dr AIQ West T7 Group 5 Springfield IL Internal Revenue Service James, Vernon & Weeks PA Craig K Vernon & Leander L James 1626 Lincoln Way Coeur dalene ID Attorney for Various Creditors Karen Konter c/o Jeff Anderson 366 Jackson Street St. Paul MN Kevin Wester c/o Jeff Anderson 366 Jackson Street St. Paul MN Kosnoff Fasy Timothy D. Kosnoff & Daniel Fasy 295 Palmas Inn Way, Suite 130 PMB 178 Humacao PR Attorneys for Various Creditors Peter Neels c/o Jeff Anderson 366 Jackson Street St. Paul MN Recovery Business Solutions Recovery & Bankruptcy Group 3920 Arkwright Rd Ste 400 Macon GA Counsel for Ricoh Business Solutions tw telecom inc Linda Boyle Park Meadows Dr No 400 Littleton CO Counsel for tw telecom inc Wisconsin Department of Justice Office of the Attorney General PO Box 7857 Madison WI Wisconsin Department of Justice Case svk Doc Filed 11/17/15 Page 3 of 3 Page 2 of 2