IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN

Transcription

1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: ARCHDIOCESE OF MILWAUKEE, Debtor. Case No svk Chapter 11 Hon. Susan V. Kelley APPLICATION OF LEVERSON LUCEY & METZ S.C. FOR INTERIM ALLOWANCE OF COMPENSATION Leverson Lucey & Metz S.C., f/k/a Leverson & Metz S.C. ( LL&M ), hereby applies to the Court pursuant to Bankruptcy Code 330, Federal Rule of Bankruptcy Procedure 2016, Local Rule 2016 of the United States Bankruptcy Court for the Eastern District of Wisconsin, the Court s Order Granting Debtor s Motion to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 158], the Court s Order Granting Modification of Debtor s Motion to Establish Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 1784], and the Stipulated Motion to Permit the Debtor to Make an Interim Compensation Payment to Professionals [Docket No. 3078] (the Interim Compensation Stipulation ) for an order awarding it $60,030.50, which consists of the fees that LL&M incurred during the period of January 4, 2011, through March 31, 2015, for its services to the Debtor and the bankruptcy estate in this case, to be paid on a pro rata basis from the $2,000,000 distribution to professionals as provided for in the Interim Compensation Stipulation. In support of this application, LL&M respectfully represents as follows: Mark L. Metz Olivier H. Reiher Leverson Lucey & Metz S.C W. Highland Blvd. Milwaukee, WI Phone: (414) mlm@levmetz.com Case svk Doc 3102 Filed 05/08/15 Page 1 of 14

2 1. The Archdiocese of Milwaukee, the debtor and debtor-in-possession (the Debtor ) commenced this case by filing a voluntary petition under Chapter 11 of the Bankruptcy Code on January 4, 2011 (the Petition Date ). 2. On January 27, 2011, this Court entered an order authorizing the Debtor to retain LL&M as its special counsel, with a fee cap of $25,000, and with retroactive effect to the Petition Date. 3. On or about November 30, 2012, this Court entered an order increasing LL&M s fee cap to $65, Until today, LL&M had never filed an interim fee application in this case. 5. This application seeks compensation for services rendered for the benefit of the Debtor and its Chapter 11 estate from the Petition Date through March 31, However, all of the services for which LL&M seeks compensation were actually provided to the Debtor and its estate between May 25 and August 15, 2012 (the Covered Period ). 6. In this application, LL&M seeks allowance, on an interim basis, of $60, in fees incurred during the Covered Period, as well as authorization for the Debtor to pay LL&M the amounts so allowed on a pro rata basis from the $2,000,000 as provided for in the Interim Compensation Stipulation. LL&M is not requesting the reimbursement of any expenses. 7. During the Covered Period, LL&M expended a total of hours for professional services rendered on behalf of the Debtor. The professionals providing those services to the estates, their positions at LL&M, their hourly rates, the total time each professional spent, and the resulting fees were as follows: TIMEKEEPER POSITION RATE HOURS FEES Mark L. Metz (MLM) Shareholder $ $21, Trevor C. Leverson (TCL) Associate $ $54, Case svk Doc 3102 Filed 05/08/15 Page 2 of 14

3 8. Based on the firm s normal hourly rates as set forth above, the value of the professional services that LL&M rendered to the Debtor and its estate during the Covered Period is $76,518.50, which is well in excess of the firm s fee cap of $65, However, LL&M has voluntarily reduced the amount it is charging the estate for certain services, and is requesting less than the $65,000 fee cap. Attached as Exhibit A is a complete chronological listing of all the LL&M s time charges during the Covered Period, which provides detailed descriptions of the services rendered and the time billed for each task by the two LL&M attorneys who worked on this matter. As indicated by the notation N.C. in numerous places in the last column of Exhibit A, LL&M is not charging the estate for about 51 hours of services (or $10,197) that its lawyers provided to the Debtor, and have reduced the firm s charges for other services by $6, The voluntary reductions by LL&M total $16,488, or about 21.5% of the total fees billablte to the Debtor s estate. In addition, LL&M is not billing the estate for (a) any of its time spent after August 15, 2012, estimated to be at least 20 hours, (b) any of its time spent preparing this fee application, or (c) any expenses (on-line research, photocopies, etc.) that LL&M incurred in connection with its services to the Debtor. Moreover, LL&M does not anticipate performing any further services for the Debtor, so at the appropriate time the firm will file its final application for compensation in the same amount as this interim application. 11. Because LL&M has voluntarily reduced its fees by more than 21%, and is waiving its right to request an increase in the fee cap applicable to its retention, LL&M requests that the full amount of its fee request i.e., $60, be allowed on an interim basis and used for calculating LL&M s pro rata share of the contemplated partial distribution, as opposed to imposing an additional 20% hold-back at this time against the already reduced amount. LL&M does 3 Case svk Doc 3102 Filed 05/08/15 Page 3 of 14

4 recognize and acknowledge that the full amount of any fees now allowed on an interim basis will remain subject to final review and allowance at the conclusion of this case, and that any interim distribution LL&M receives remains subject to recoupment under certain circumstances. 12. The services LL&M rendered to the Debtor and its estate all related to a single and discrete project, which cannot readily be broken into separate sub-categories. In May 2102, the Debtor requested that LL&M analyze and file appropriate objections to certain interim fee requests that had been filed by counsel to the Creditors Committee in this case. LL&M performed those services with the diligence and expertise consistent with its standard billing rates. WHEREFORE, Leverson Lucey & Metz S.C. applies to the Court for the entry of an order: A. Allowing, on an interim basis, compensation in the amount of $60,030.50, which represents the totality of the fees for which LL&M will seek reimbursement from the Debtor and the estate for the firm s services in this case; and B. Authorizing the Debtor to pay make a partial payment of those fees to LL&M on a pro rata basis from the $2,000,000 provided for in the Interim Compensation Stipulation. Dated this 8th day of May, LEVERSON LUCEY & METZ S.C. /s/ Mark L. Metz Mark L. Metz Olivier H. Reiher Attorneys for the Debtors 3030 W. Highland Blvd Milwaukee, WI (414) mlm@levmetz.com 4 Case svk Doc 3102 Filed 05/08/15 Page 4 of 14

5 EXHIBIT A to the Fee Application of Leverson Lucey & Metz S.C. Case svk Doc 3102 Filed 05/08/15 Page 5 of 14

6 ATTY DATE DESCRIPTION HRS FEES BILLED MLM 05/25/12 MLM 05/28/12 Discuss with D. Diesing the Debtor's concerns about excessive fees being billed by Committee counsel and need for a thorough review to protect the estate. Discuss Debtor's needs with T. Leverson and assign to him various research projects. 0.6 $ $ $ $ MLM 05/28/12 MLM 05/28/12 Review docket and case filings to develop a context for fees being charged by all parties and the possibility that Committee counsel is overbilling the estate. Develop methodology for reviewing the fees billed by Committee counsel, including ways to identify redundancies, inefficiencies, and situations where Committee may be working on behalf of particular creditors. 1.5 $ N.C. 1.2 $ $ TCL 05/28/12 Discuss case issues and research topics with M. Metz. 0.3 $58.50 N.C. TCL 05/28/12 Review filings/materials related to the Committee's motion for relief from automatic stay to conduct discovery in state court. 2.5 $ $ TCL 05/28/12 Being review of fee applications submitted by PSZJ and HSW. 1.3 $ $ TCL 05/28/12 Research 1103 regarding scope of Committee's duties/function. 1.1 $ $ MLM 05/29/12 TCL 05/29/12 TCL 05/29/12 TCL 05/29/12 TCL 05/29/12 TCL 05/30/12 Conference call with D. Diesing and T. Leverson to discuss scope of our review. Conference call with M. Metz and D. Diesing to discuss the scope of review into Committee counsel billing practices. Research 1103, 1109(b) regarding scope of Committee's duties and function. Research fiduciary duties of creditor committee and its counsel to constituents. Research limitations on fees allowable from an estate to creditors committee counsel. Research fee application issues regarding sufficiency of descriptions for various tasks (1.5), and local rules regarding same (.3). 0.5 $ $ $97.50 N.C. 1.9 $ $ $ $ $ $ $ N.C. TCL 05/30/12 Review fee request history of HSW. 1.5 $ N.C. TCL 05/30/12 Review fee request history of PSZJ. 3.5 $ $ TCL 05/30/12 Further review of fee request history for HSW. 0.9 $ N.C. TCL 06/01/12 Continue reviewing and summarizing HSW fee request history. 1.8 $ N.C. TCL 06/01/12 Continue reviewing and summarizing PSZJ fee request history. 5.5 $1, $1, TCL 06/04/12 Review case documents (applications for employment, etc.). 1.2 $ N.C. 2 Case svk Doc 3102 Filed 05/08/15 Page 6 of 14

7 TCL 06/04/12 Review numerous Committee filings and Debtor's responses thereto, to identify areas in which Committee may be performing services on behalf of individual creditors. 1.6 $ $ TCL 06/04/12 TCL 06/05/12 TCL 06/05/12 Review coordinated efforts by Attorney Anderson and PSZJ relating to joinders. Review PSZJ filings on behalf of abuse claimants in the CDOW case regarding relief from stay similarities to this case. Summarize similarities between PSZJ's efforts on relief from stay and Rule 2004 issues in this case compared to CDOW case. 3.1 $ $ $ $ $ $ TCL 06/06/12 Research 330(a) regarding necessary services. 1.5 $ $ TCL 06/06/12 Research 330(a) regarding reasonable compensation. 3.8 $ N.C. TCL 06/06/12 Drafting summary of research on 330(a) issues. 0.5 $97.50 $97.50 TCL 06/07/12 Research background and prior relationships between PSZJ, Jeff Anderson, and Committee members. 1.1 $ N.C. TCL 06/07/12 Research 1103 regarding adverse interest. 0.8 $ $ TCL 06/07/12 Research 328(b) regarding disinterestedness. 1.2 $ N.C. TCL 06/07/12 Research and review objections to PSZJ fees in other cases. 1.0 $ N.C. TCL 06/07/12 TCL 06/08/12 TCL 06/08/12 TCL 06/12/12 Begin preparing memo about bases for objecting to PSZJ fees under 330(a) for their work on a motion for relief from stay for the benefit of abuse claimants only. Continue drafting section in memo relating to inappropriate work by the Committee in seeking relief from stay for particular claimants. Research fiduciary duties owed by the members of an unsecured creditors committee and its counsel, as opposed to special interest committees. Research concerning fiduciary duties owed by committee members and counsel to all constituents, and the fees/expenses compensable from the estate under $ $ $ $ $ $ $ $ TCL 06/12/12 Research regarding duplication of services under 330(a)(4)(A)(i). 5.5 $1, $1, TCL 06/13/12 TCL 06/13/12 TCL 06/13/12 TCL 06/13/12 Research definition of "necessary" services under 330(a), as well as necessary expenses. Explore case law that interprets "reasonable compensation" as it relates to specific instances. Research excessive billing practices regarding specific instances, court's duty to reduce, and related subject of 330(a)(4)(A)(i). Research about circumstances when courts will reduce fees based on poor billing judgment. 1.4 $ $ $ $ $ $ $ $ Case svk Doc 3102 Filed 05/08/15 Page 7 of 14

8 TCL 06/13/12 Research objections made to PSZJ fees in other cases. 0.7 $ N.C. TCL 06/14/12 TCL 06/14/12 TCL 06/14/12 TCL 06/15/12 TCL 06/15/12 TCL 06/15/12 TCL 06/15/12 TCL 06/18/12 TCL 06/18/12 TCL 06/19/12 TCL 06/19/12 Research specific rules and examples of excessiveness under the 330(a) standards. Research 330(a)(4)(A)(ii) regarding its applicability to committee counsel. Draft memo about specific rules regarding applicability of research to this case. Draft fee objection memo about excessive billing and lawyers' duty to use good billing judgment. Research regrading intra-office conferencing and multiple attorneys billing for same (.7); prepare short memo regarding same (.4) Review PSZJ's first, second, and third monthly fee applications to identify excessive and duplicative intra-office conferring; calculations regarding same. Analyze PSZJ's fee applications from the perspective of possible breach of fiduciary duty issue. Research fiduciary duty issue (.7); analyze PSZJ's fee applications regarding same (1.6). Draft memo regarding PSZJ's services for individual claimants who were adversely affected by Judge Kelley's decision on the Debtor's summary judgment motion. Review docket and pleadings related to Rule 2004 examinations and PSZJ's corresponding fee applications. Draft sections in a memo regarding breach of fiduciary duty and the application of 330(a)(4)(A)(i) and (A)(ii). 2.4 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $1, $ $ $ $ $ TCL 06/19/12 Draft memo to M. Metz for fee objection. 2.1 $ $ TCL 06/20/12 Research regarding compensability of non-working travel. 1.9 $ $ TCL 06/20/12 Review PSZJ fee applications and locate numerous instances of nonworking travel billed at full hourly rates. 2.4 $ $ TCL 06/20/12 Analyze PSZJ non-working travel, draft memo regarding same. 2.9 $ $ TCL 06/21/12 TCL 06/21/12 Review PSZJ fee applications to isolate firm's overkill response to Debtor's objection to Marci Hamilton employment, resulting in fees for retention 3x greater than the proposed fee cap for Hamilton's own services. Draft memo for fee objection regarding excessive fees incurred in recovering from initial non-disclosures in connection with retention of Marci Hamilton. 4.1 $ $ $ $ TCL 06/21/12 Additional research regarding 330(a)(4)(A)(i). 0.9 $ $ Case svk Doc 3102 Filed 05/08/15 Page 8 of 14

9 TCL 06/21/12 Draft memo regarding unnecessarily duplicative work performed by PSZJ relating to Seventh Circuit RFRA cases. 1.3 $ N.C. TCL 06/22/12 Research compensability of clerical services. 0.8 $ $ TCL 06/22/12 TCL 06/22/12 TCL 06/22/12 TCL 06/22/12 TCL 06/23/12 TCL 06/23/12 Analyze PSZJ's use of paralegals to update calendars and perform other clerical work (.7); draft memo regarding same (1.0). Analyze PSZJ fee requests for duplicative legal research relating to derivative-standing motion, RFRA, trusts, alter ego. Draft memo about excessive and duplicative billings in connection with the Committee's May 2012 derivative-standing motion. Locate, gather and analyze PSZJ fee applications in other religious order cases, especially with respect to the firm's previous billings for research on the identical issues now being billed to this case. Continue to gather and review data from PSZJ's fee applications in the CDOW, Spokane, S.J. Oregon cases regarding the similar legal research and largely overlapping briefs in this case. Research compensability of computer-assisted legal research under $ $ $ $ $ $ $ $ $ $ $ $ TCL 06/23/12 Analyze PSZJ's reimbursement requests for Westlaw. 0.9 $ $ TCL 06/23/12 TCL 06/24/12 TCL 06/25/12 TCL 06/26/12 TCL 06/26/12 TCL 06/27/12 TCL 06/27/12 TCL 06/27/12 Prepare a memo regarding expenses billed to the estate by PSZJ for Westlaw/Lexis. Continue to gather and review data from PSZJ's fee applications in the CDOW, Spokane, S.J. Oregon cases regarding the similar legal research and largely overlapping briefs in this case. Review and compile data from PSZJ's fee applications in this case regarding excessive or duplicative research on repeat issues (5.2); draft memo regarding same (2.4). Synthesize observations from review of PSZJ's fee applications in other chapter 11 proceedings for comparison across PSZJ religious order cases. Draft memo regarding excessive or duplicative legal research done by PSZJ on alter ego issues and trust issues, considering hundreds of hours of recent research on the same issues in other cases. Continue to analyze PSZJ fee applications and calculate potentially excessive or duplicative hours billed in January through April Draft memo on PSZJ duplicated work researching again the burden of proof for establishing trusts, when it researched the same issue in other cases. Review PSZJ fee applications, i.e. PSZJ double-billing for travel and work done in a day. 1.1 $ $ $ $ $1, $1, $ $ $ $ $ $ $ $ $ N.C. 5 Case svk Doc 3102 Filed 05/08/15 Page 9 of 14

10 TCL 06/28/12 Review PSZJ's work and bills relating to Anderson's denied motion to unseal (2.0); incorporate those findings into memo about appeal fees (.4) 2.4 $ $ TCL 06/28/12 TCL 06/29/12 TCL 06/29/12 TCL 06/29/12 TCL 07/01/12 TCL 07/01/12 Internet searches researching background and connections between Anderson and PSZJ in religious order cases (.7); incorporate those findings into fiduciary duty memo (.8). Draft memo about possible breaches of fiduciary duty owed by the Committee and its counsel to non-abuse claimants in this case. Research regarding excessive or duplicated work in situations where parties-in-interest have both local and out-of-district counsel. Draft memo regarding PSZJ's failure to optimize the use of its local counsel HSW in this case to limit cost to the estate. Calculate PSZJ's hours and fees billed for various categories over extended billing periods, including its derivative-standing motion, first in July/August, 2011 and again in April/May of 2012 (2.2); the Marci Hamilton project (1.0); trusts and other research issues (1.3); appeal work (.8); non-working travel time (.6); and relief from stay (.5). Calculate PSZJ's hours billed for researching the same issues and preparing largely overlapping motions in other cases, in order to determine how much was potentially unnecessary in this case. 1.5 $ $ $ $ $ $ $ $ $1, $1, $ $ MLM 07/01/12 Prepare brief in support of objection to Committee counsel's fees. 6.8 $2, $2, TCL 07/02/12 Recheck and update calculations and work from yesterday. 3.2 $ N.C. TCL 07/02/12 Cite check case law in memos for incorporation into objection. 1.0 $ $ TCL 07/02/12 Review/revise/edit memos in light of new knowledge about PSZJ's billing practices and activities in this and other cases. 4.3 $ $ MLM 07/02/12 Continue drafting brief in support of objection to PSZJ fees. 6.5 $2, $2, MLM 07/02/12 TCL 07/03/12 TCL 07/03/12 MLM 07/03/12 Review and analyze PSZJ fees in other religious order reorganizations, especially time spent on re-doing same research in multiple cases. Continue reviewing and revising memos from the perspective of persuasiveness with more complete knowledge of facts and law. Review derivative-standing motions and demand letters PSZJ filed in other cases. Review T. Leverson memo with analysis of the time spent by PSZJ lawyers working on appeals for individual claimants; incorporate same into brief. 3.3 $1, $1, $ $ $ $ $1, $1, MLM 07/04/12 Continue drafting brief in support of objection to PSZJ fees. 7.4 $2, $1, Case svk Doc 3102 Filed 05/08/15 Page 10 of 14

11 TCL 07/04/12 MLM 07/05/12 Calculate time PSZJ spent working on answer/counterclaims to the amended complaint in cemetery trust litigation (1.3); discuss findings with M. Metz (.8); review derivative-standing motions and demand letters PSZJ filed in other cases (1.2); review firm's bills/time spent regarding same (3.5); draw comparisons between those cases and this case (1.2). Confer with T. Leverson, and separately with WHD attorneys, about need for additional time and longer brief to cover the many areas of questionable billings. 8.0 $1, $1, $ $ MLM 07/05/12 MLM 07/05/12 TCL 07/05/12 TCL 07/05/12 MLM 07/06/12 TCL 07/06/12 Review and revise motion to extend time and page limits; oversee filing of same. Continue working on brief to support Debtor's objection to PSZJ fees, including review of fees being billed simultaneously by the same lawyers in other cases. Draft and edit notice of motion and motion to extend time and page limits for brief supporting objection to PSZJ fees. Draft and edit objection to PSZJ's fifth quarterly and April 2012 fee applications. Review order denying extension of page limits (.1); phone call with Attorney Diesing regarding same (.2); begin refocusing arguments in the brief to comply with limits (2.2) Draft an outline to assist M. Metz in consolidating his brief from 30 pages to 15 pages based on order denying extension of page limits. 0.7 $ $ $2, $2, $ N.C. 3.1 $ $ $ $ $ $ TCL 07/06/12 Research 328(a)'s unforeseeably improvident standard. 3.3 $ N.C. TCL 07/06/12 Summarize 328(a) interplay with our issues. 0.8 $ $ MLM 07/07/12 Work on brief supporting the Debtor's objection to PSZJ fees. 6.6 $2, $2, TCL 07/07/12 MLM 07/08/12 MLM 07/08/12 MLM 07/08/12 TCL 07/08/12 MLM 07/09/12 MLM 07/09/12 Analyze and calculate data regarding PSZJ fee applications and total requests/macro-trends/april Continue to refine and condense arguments in brief; prepare exhibits summarizing certain billing excesses. Circulate draft of brief and obtain feedback from both the client and Attorney Diesing. Attempt to confirm that PSZJ ghost-wrote the Rule 54(b) motion filed by Anderson; review rules and sanctions for ghost-writing pleadings. Research into the fiduciary duty of a committee to serve as gatekeepers for objectionable claims. Based on comments from client, make revisions to the brief and strengthen the objection to PSZJ computerized research charges, including revision of case law regarding same. Finalize and file brief supporting objection to PSZJ fees, along with three exhibits. 1.7 $ $ $1, $1, $ $ $ $ $ $ $ $ $ $ Case svk Doc 3102 Filed 05/08/15 Page 11 of 14

12 TCL 07/09/12 Review/revise/edit brief supporting objection to fifth quarter and April 2012 fee applications. 2.1 $ N.C. TCL 07/09/12 Analyze PSZJ's fee application for May 2012, not included in current objection but to confirm continuation of the same problems cited in Debtor's brief. 1.8 $ $ MLM 07/10/12 Exchange s with Attorney Solochek regarding hearing dates. 0.3 $ $ TCL 07/10/12 TCL 07/10/12 MLM 07/11/12 TCL 07/11/12 TCL 07/12/12 TCL 07/16/12 TCL 07/16/12 TCL 07/17/12 MLM 07/17/12 MLM 07/18/12 MLM 07/19/12 TCL 07/23/12 Draft memo regarding May 2012 fee application issues about PSZJ apparent ghostwriting of Attorney Finnegan's opposition to Debtor's motion to withdraw the reference. Draft memo regarding May 2012 fee application by PSZJ with even more excessive hours dedicated to derivative-standing issues that have been fully researched in the firm's other cases. Prepare and circulate draft order from the preliminary hearing (.6); receive comments from various parties (.2); make revisions and confirm that order is acceptable to all involved (.3) Review PSZJ's fee applications in San Diego case to identify time billed for research, drafting, editing, finalizing its demand letter and derivative standing motion in that case, and compare the degree of work product overlap with similar filings in this case. Complete review, double check math and revise numbers regarding PSZJ derivative standing effforts in San Diego (.5); same process for PSZJ's Alaska bills (.8); same process for PSZJ's Oregon bills (.2); same process with respect to Attorney G. Brown's derivative standing motion in July/August 2011 in this case, recently redone by other PSZJ lawyers in March through May 2012 in this case (1.1). Create graphs regarding an hours and fees comparison for PSZJ continuously researching the same derivative-standing issues in multiple cases. Draft objection about excessive hours billed to research the ancient document hearsay exception. Prepare memo summarizing objection to PSZJ's fees in May 2012, based on continuation of same issues raised in Debtor's brief. Various phone calls with Attorney Asbach about issues raised in the Debtor's objection to PSZJ fees and possibility of US Trustee helping secure information from other cases for cross-comparison. More phone calls with Attorney Asbach regarding recycling of work product and billing two open estates for the same research. Exchange s with Attorney Asbach regarding updated PSZJ fee information from the Christian Brothers case; review those fees. Continue drafting additional objections to PSZJ fees and documenting excesses by comparison to other cases. 3.7 $ $ $ $ $ $ $ $ $ $ $97.50 $ $78.00 $ $ $ $ $ $ $ $ $ $ $ Case svk Doc 3102 Filed 05/08/15 Page 12 of 14

13 TCL 07/24/12 Analyze PSZJ's May 2012 fee application regarding clerical work, Westlaw fees, updating objection figures. 0.9 $ $ TCL 07/24/12 TCL 07/24/12 TCL 07/24/12 TCL 07/24/12 TCL 07/24/12 TCL 07/25/12 TCL 07/25/12 TCL 07/25/12 TCL 07/25/12 TCL 07/25/12 TCL 07/26/12 TCL 07/26/12 TCL 07/26/12 TCL 07/26/12 TCL 07/26/12 TCL 07/30/12 Analyze PSZJ's May 2012 fee application from the persepective of firm's role in assisting Anderson to draft opposition papers. Research concerning ghostwriting, from both a compensability and an ethical perspective. Review docket materials regarding Debtor's motion to withdraw the reference. Research withdrawing the reference, and discuss the same with L. Leverson. Draft memo regarding a future objection to PSZJ's fees based on ghostwriting of pleadings for Anderson's opposition. Review and revise memo about objection to PSZJ's fees for ghostwriting on behalf of Anderson and his clients. Draft memo regarding objection to PSZJ's motion for relief from stay and Rule 2004 joint motion, again with an emphasis on Committee giving legal assistance to a sub-group of claimants. Analyze PSZJ's May 2012 fee application with respect to additional research into issues of burden of proof and trusts, with same issues being researched and billed in other cases. Draft memo regarding duplicative and excessive research by PSZJ on burden of proof regarding trusts objection. Analyze PSZJ fee application regarding resulting trusts research and draft section objecting to excessive hours. Analyze PSZJ bills from the Christian Brothers' Institute case, and compare dates and entries regarding legal research with those in ADOM case. Revise memo/objection about excessive/duplicative hours billed for legal research into the alter ego doctrine in light of Attorney Gray's numerous hours of research about the same topic in the Christian Brothers case. Analyze PSZJ fee applications regarding other instances of legal research, alter ego or self-settled trusts. Revise memo/objection regarding excessive/duplicative hours billed for legal research, self-settled trusts in light of Attorney Gray's hours of research in May 2012 in this case. Analyze PSZJ hours billed at lawyer rates to answer hotlines and draft section objecting to same. Analyze Attorney G. Brown's August 2011 draft motion for standing (.9), hours she billed to research and draft it (.1); s responding to the demand letter (.3); prepare section of memo objecting to fees requested for those services (.8). 1.6 $ $ $78.00 $ $ N.C. 1.0 $ N.C. 0.7 $ $ $ N.C. 0.8 $ $ $ $ $ $ $97.50 $ $ $ $ $ $ $ $ $ $ $ $ $ Case svk Doc 3102 Filed 05/08/15 Page 13 of 14

14 TCL 07/30/12 Update section in fee objection about 2012 motion for standing to reflect fact that Attorney Egan used it as a template, copied/pasted portions of Brown's draft and case law citations, but billed as if new work product. 0.7 $ $ TCL 08/01/12 Incorporate new findings/details into prior analysis. 5.4 $1, $ TCL 08/02/12 Research Westlaw subscription rates for firm PSZJ's size in light of PSZJ's high reimbursement requests since January $ $ TCL 08/02/12 Telephone calls with Westlaw representative. 0.3 $58.50 $58.50 TCL 08/02/12 Update objection/memo. 0.2 $39.00 $39.00 TCL 08/10/12 Research under 330 to see how courts treat routine legal research by senior lawyers with high hourly rates. 4.0 $ $ TCL 08/13/12 Revise objection/memo in light of latest research. 4.0 $ N.C. TCL 08/14/12 Edit objection/memo. 6.4 $1, N.C. TCL 08/15/12 Edit objection/memo. 4.5 $ N.C. 10 Case svk Doc 3102 Filed 05/08/15 Page 14 of 14