Case KG Doc 1004 Filed 10/24/16 Page 1 of 19

Transcription

1 Case KG Doc 1004 Filed 10/24/16 Page 1 of 19 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., l ) Case No (KG) Debtors. ) (Jointly Administered) Objection Deadline: November 14, 2016, at 4:00 p.m. EST.Hearing Date: Scheduled only if I~Tecessary SUMMARY OF TWELFTH MONTHLY APPLICATION FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES OF PACHULSKI STANG ZIEHL &JONES LLP, AS COITI~ISEI, FOIZZ DEBT'Q~tS FOR THE PERIOD FROM SEPTEMBER 1, 201b, THROUGgi SEPTEMBER 30, 2a16 Name of Applicant: Authorized to Provide Professional Services to: Date of Retention: Period for which Compensation and Reimbursement is Sou ht: Amount of Compensation Sought as Actual, Reasonable and Necessa Amount of Expense Reimbursement Sought as Actual, Reasonable and Necessa Pachulski Stang Ziehl &Jones LLP Debtors and Debtors in Possession Effective nzsnc pro tunc to October 8, 2015, by order si ned on or about November 4, 2015 September 1, 2016 September 30, 2016 a $151, $ This is a: x monthly interim final application. The total time expended for fee application preparation is approximately 2.0 hours and the corresponding compensation requested is approximately $1, The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corporation (9246); NC Estate Corporation (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is P.O. Bax 5960, Frisco, TX The applicant reserves the right to include any time expended. in the time period indicated above in future applications) if it is not included herein. DOGS SF; /002

2 Case KG Doc 1004 Filed 10/24/16 Page 2 of 19 PRIOR MONTHLY APPLICATIONS FILEDI 11/25/1.5 10/08/15-10/31/15 $481, $23, $385, $23, $96, $505, /23/15 11/O1/15-11/30/15 $449, $40, $359, $40, $89, $489, /25/16 12/01/15-12/31/ , $3, $155, $3, $38, $197, First Interim 10/08/15 - z $1,125, $67, $900, $64, $225, $1,189, Fee 12/31/15 [llkt.496] A lication.. 03/14/16 04/07/16 05/03/16 01/01/16-01/31/16 02/01/16-02/29/ 16 03/01/16 - nziziiiti Second Interim 01/01/16 - Fee 03/31/16 A lication 06/07/16 06/28/16 07/13/16 04/01/16-04/30/16 05/01/16-05/3 U16 06/01/16 - n~iznii ti Third Interim 04/01/16 - Fee 06/30/16 A lication $189, $3, $151, $3, $37, $192, $23, $10, $218, $10, $54, $284, $2g~~g~0.50 $5, $230, $5, $57, $293, $50, $19, $600, s $19, $150, $770, [Dkt.844] $240, $11, $192, $11, $48, $252, X302, $12, $242, $12, $60, $314, $212, $6, $169, $6, $42, $218, ~~55, X30, $604, $30, $151, $785, ~Dkt 946] 08/25/1.6 09/23/16 07/01/16-07/31/16 08/01/16-08/31/16 $201, $13, $160, $13, $40, $219, $5, $175, $5, $43, ' Each of the three monthly fee statements for October, November and December filed on behalf of ODC, MLC and NCEC have been combined here to represent one monthly fee statement for each time period for all Debtors. Z This amount was reduced by $2, per agreement with the Office of the United States Trustee. 3 This amount was reduced by $ per agreement with the Office of the United States Trustee. 1 DOCS SF: /002

3 Case KG Doc 1004 Filed 10/24/16 Page 3 of 19 As more fully set forth in the Application punsuant to Section 327(a) of the Bankruptcy Code, Rule 2014 of the Federal Rules of BankNuptcy PNoceduNe ccnd Local Rule fog Authorization to Employ and Retain Pachulski Stang Ziehl &Jones LLP as Counsel,for the Debtors and Debtors in Possession Nunc Pro Tunc to the Petition Date [Docket No. 62] (the "Retention Application"), the Firm bills fees and expenses directly related to the each of the Debtors' estates. The Retention Application, as supplemented by the Supplemental Declaration of Jeffrey N. Pomerantz in Support of Application Pursuant to Section 327(a) of the Bankruptcy Code, Rule 2014 of the Federal pules of Bankruptcy P~ocedu~ e and Local Rule for Authorization to Employ and Retain Pachz~lski Stang Ziehl &-Jones LLP as Counsel for the Debtors and Debtors in Possession nunc pro tune to the Petition Date [Docket No. 338] (the"supplemental Retention Declaration"), also provides that for services and expenses that benefit all Debtors, the Firm will allocate such fees and expenses based on anticipated level of activity in the cases. On September 30, 2016, the Court entered an ONder Authorizing the Use of Cash CollateNal on a Consolidated Basis [Docket No. 961 ](the "Consolidated Cash Collateral Order"), thereby alleviating the need to allocate fees and expenses among the different Debtors. Therefore, upon the entry of the Consolidated Cash Collateral Order, the Firm is now billing the Debtors on a consolidated basis. DOCS SF: /002 2

4 Case KG Doc 1004 Filed 10/24/16 Page 4 of 19 PSZ&J PROFESSIONALS {3S1~iCFT1(3~'~~1E'l~~}~~~ICs`~tlt, ~~Qiit'~1 _ 1 I3illi~~ N~rnevfl'~~a~~ssiot~al ~'eat ofut~t~~i~~ii~~li~ctti~~e ~I'r~t~il ~t<ttc~ ~~xciir~~i~uai tc~ 't~~~:yi~e, ~~~i~~~ l~il[ii"~ Andrew W. Caine Jeffrey N. Pomerantz ~lllt'.~i~cjil1~~ 1'~ ~Illl~~$t~ eft ~T'itC~it'C ~ ~..... ~.~ `I~nt~~l ~~.; t.~(3etl()t'ils:ilti)11 - _ Partner 1989; Member CA $ $ Bar 1983 Partner 1995; Member of CA Bar 1989 $ $21, $ $2, Partner 1999; Member of Iain A.W. Nasatir NY Bar 1983; Member of $$ $14, CA Bar 1990 Partner 2005; Member of PA James E. O'Neill Bar 1985; Member of DE $ $12, Bar 2001 Joshua M. Fried Partner 2006; Member of CA Bar 1995; Member of NY Bar 1999; Member of NJ Bar 2000 ~~ $62, $ $1, Jeffrey P, Nolan Of Counse12001; Member of CA Bar 1992 X $17, Partner 2003; Member DC Michael R. Seidl Bar 1996; Member DE Bar $ $ Cia H. Mackle Of Counse12Q07; Member of FL Bar 2006 $ $ Of Counse12010; Member Jason H. Rosell of CA Bar 2010; Member of $ $2, NY Bar 2011 Kathe F. Finlayson Paralega12000 $ $5, Elizabeth C. Thomas Paralega12016 $ $32.50 Patricia J. Jeffries Paralegal 1999 $ $6, DOCS SF: /002

5 Case KG Doc 1004 Filed 10/24/16 Page 5 of 19..~. _ ~4SI~lf?II ~0~~~1~ ~j1~~~lciijlt, I ~ttitt'~v, a' >itl~n~~ i"~~~t~~e of Pra~es~ion~i 'Y~~~ ref~~tati~in Li~tr~se ~ ~ It~~~~ tt~ii~ iclual ~ fir 1' '~~cf~c~t ~t.~tes (ittel~i~liitt;, ;~~cii~zi~tccl t+~ f~e~actice ~~~~n es.i`ot<~~ Ii~~t3t ~... _.._...~...c,,,,._..,,.~ _.~,..._.. ~~ ~t'«t~~i C~~,~n~~e~~~~~~~~ `~~ a : ~I ~ Andrea R. Paul Case Management Assistant $ $ Karen S. Neil Case Management Assistant $ $ Sheryle L. Pitman Case Management Assistant $ $ Total: $151, Total Hours: Blended Rate: $ COIVIP~I~TSATI01>1 BY CAT~G~RY P~ a,~~~t ~~~fegc~rie~ "'a~~i ~cu~s T+~t~t tees Asset Analysis 7.70 ~ $ 4, Avoidance Actions 1.60 $ 1, Asset J~ispasition 0.50 $ Bankruptcy Litigation $ 6, Case Administration 8.90 $ 2, Claims Administration/Objections $SS, Compensation of Professionals $ 7, Compensation of Professionals/Others 8.40 $ 4, Fee/Employment Application 0.10 $ Financing $15, Non-Working Travel $ 4, Plan and Disclosure Statement $39, Stay Litigation $ 8, Tax Issues 0.40 $ Total $151, DOCS SF: /002 4

6 Case KG Doc 1004 Filed 10/24/16 Page 6 of 19 EXPENSE SUMMARY _. 5~~=vice~'t c~~rit~~~ Tt~~~l ~~~~~.~»es E~~c~~se ~ate~o~~;v ~, ~i~ ~t ~lt'~i~'?ie'} - Auto Travel Expense IMT, DFW Taxi, Uber $ Dallas Worthington, Four Seasons Hotel Expense Houston $1, Secretarial Overtime H. Phan $ Reproduction $ Reproduction/Scan Copy $ Travel Expense Hertz $ Phirahna Killer, Dallas Worthington, Working Meals Starbucks, Salata $ g9.24 Total $2, PSZ&J may use one or more service providers. The service providers identified herein below are the primary service providers for the categories described. DOGS SF: /002

7 Case KG Doc 1004 Filed 10/24/16 Page 7 of 19 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., l ) Case No (KG) Debtors. ) (Jointly Administered) abjection Deadline: November 14, 2016, at 4:00 p.m. EST Hearing Date: Scheduled only if Necessary TWELFTH MONTHLY APPLICATION FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES OF PACHULSKI STANG ZIEHL & JONES LLP, AS COUNSEL FOR DEBTORS FOR THE PERIOD FRONT SEPTEMBER 1, 2016, THROUGH SEPTEMBER 30, 2016 Pursuant to sections 330 and 331 of Title 11 of the United States Code (the `Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (collectively, the "Bankruptcy Rules"), and the Court's Order Pursuant to Sections 1OS(a) and 331 of the Bankruptcy Code and Bankruptcy Rule 2016(a) and Local Rule Establishing PNocedures for Interim Compensation and Reimbursement of Expenses of Professionals, signed an or about November 4, 2015 (the "Administrative Order"), Pachulski Stang Ziehl &Jones LLP ("PSZ&J" or the "Firm"), counsel for the debtors and debtors in possession, hereby submits its Twelfth Monthly Application fog Compensation and for Reimbursement of Expenses of Pachulski Stang Ziehl &Jones LLP as Counsel,for Debtors for the Period fnom SeptembeN 1, 2016, thnough September 30, 2016 (the "Application") By this Application, PSZ&J seeks a monthly interim allowance of compensation in the amount of $151, and actual and necessary expenses in the amount of $2, for ~ The Debtors, together with the last four digits of each. Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corporation (9246); NC Estate Corporation (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' headquarters and service address is P.O. Box 5960, Frisco, TX DOCS SF: /002

8 Case KG Doc 1004 Filed 10/24/16 Page 8 of 19 a total allowance of $153, and payment of $121, (80% of the allowed fees) and reimbursement of $2, (100% of the allowed expenses) for a total payment of $123, for the period September 1, 2016, through September 30, 2016 (the "Interim Period"). In support of this Application, PSZ&J respectfully represents as follows: Background On October 8, 2015 (the "Petition Date"), the Debtors each filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtors continue in possession of their property and continue to operate and manage their businesses as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in the Debtors' chapter 11 cases. 2. The Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). On October 20, 2015, the United States Trustee for Region 3 appointed the Official Committee of Unsecured Creditors (the"committee") to represent the interests of all unsecured creditors in this Case pursuant to section 1102 of the Bankruptcy Code. 4. On or about November 4, 2015, the Court signed the Administrative Order, authorizing certain professionals and members of any official committee ("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. If no objections are made within twenty-one (21) days after service of the monthly fee application the Debtors DOCS SF; /002 2

9 Case KG Doc 1004 Filed 10/24/16 Page 9 of 19 are authorized to pay the Professional eighty percent (80%) of the requested fees and one hundred percent (1 QO%) of the requested expenses. Beginning with the period ending December 31, 2015., and at three-month intervals or such other intervals convenient to the Court, each Professional shall file 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. 5. The retention of PSZ&J, as counsel to the Debtors, was approved effective as of October 8, ZO l 5, by this Court's Order Pursuant to Section 327(a) of the Bankruptcy Code, Rule 2014 of the FedeNal Rules of Bankruptcy Procedure and Local Rule Authorizing the Employment and Retention of Pachulski Stang Ziehl &Jones LLP as Counsel fog the DebtoNs and Debtors in Possession nunc pro tune to -the Petition Date, signed on or about November 4, (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 AND FOR REIMBURSEMENT OF EXPENSES Compensation Paid and Its Source 6. All services for which PSZ&J requests compensation were performed for or on behalf of the Debtors. 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. Docs sr:9a~s3.a iosavooa 3

10 Case KG Doc 1004 Filed 10/24/16 Page 10 of 19 Fee Statements 7. The fee statement for the Interim Period is attached hereto as Exhibit A. This statement contains daily time logs describing the time spent by each attorney and paraprofessional during the Interim Period. To the best of PSZ&J's knowledge, this Application complies with sections 330 and 331 of the Bankruptcy Code, the Bankruptcy 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 particularly sensitive to issues of"lumping" and, unless time was spent in one time frame on a variety of different matters for a particular client, separate time entries 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 Bankruptcy Code. PSZ&J has reduced its charges related to any non-working travel time to fifty percent (50%) of PSZ&J's standard hourly rate. To the extent it is feasible, PSZ&J professionals attempt to work during travel. Actual and Necessary Expenses A summary of actual and necessary expenses incurred by PSZ&J for the Interim Period is attached hereto as part of Exhibit A. PSZ&J customarily charges $0.10 per page for photocopying expenses related to cases, such as this, arising 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 attached to the photocopier. PSZ&J sumryarizes each client's photocopying charges on a daily basis. DOCS SF: /002 4

11 Case KG Doc 1004 Filed 10/24/16 Page 11 of 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 of the actual costs incurred by PSZ&J for the machines, supplies and extra labor expenses associated with sending telecopies and are 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 (e.g., LEXIS and WESTLAW), PSZ&J charges the standard usage rates these providers charge for computerized legal research. PSZ&J bills 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 axe 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 forth in the ABA's Statement of Principles, dated April 12, 1995, regarding billing for disbursements and other charges. Summary of Services Rendered 12. The names of the timekeepers of PSZ&J who have rendered professional services in this case during the Interim Period are set forth in the attached Exhibit A. PSZ&J, by and through such persons, has prepared and assisted in the preparation of various motions and orders submitted to the Court for consideration, advised the Debtors on a regular basis with respect to various matters in connection with the Debtors' chapter 11 cases, and performed all Docs sr:9ais3.z iosaliooz 5

12 Case KG Doc 1004 Filed 10/24/16 Page 12 of 19 necessary professional services which are described and narrated in detail below. PSZ&J's efforts have been extensive due to the size and complexity of the Debtors' chapter 11 cases. Summary of Services by Proiect 13. The services rendered by PSZ&J during the Interim Period can be grouped into the categories set forth 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 forth on the attached Exhibit A. Exhibit A identifies the attorneys and paraprofessionals. who rendered services relating to each category, along with the number of hours fox each individual and the total compensation sought for each category. A. Asset Analysis/Recovery 14. Time billed to this category relates to the review and analysis of the Debtors' assets. During the Interim Period, the Firm, among other things: (i) reviewed the Debtors' adequate assurance utility deposits and prepared letters to each of the utility providers regarding the release and return, as applicable, of such deposits; (ii) reviewed and analyzed intellectual property sales and patent issues; (iii) corresponded with counsel regarding Expeditors inventory release issues; and (iv) conferred with counsel regarding certain preference analysis issues. Fees: $4, Hours: 7.70 DOCS SF: /002 6

13 Case KG Doc 1004 Filed 10/24/16 Page 13 of 19 B. Asset Disposition 15. Timed billed to this category relates to the disposition of the Debtors' assets. During the Interim Period, the Firm reviewed the list of proposed goods to be sold by Expeditors and communicated with counsel regarding attendees at the IP auction. Fees: $ Hours:.70 C. Avoidance Actions 16. The Firm billed time to this category communicating with counsel regarding the resolution of certain unresolved litigation claims, as well as reviewing and analyzing related preference analysis. Fees: $1, Hours: 1.60 D. Bankruptcy Lit~ation 17. Time billed to this category relates to, among other things: (i) preparing hearing agendas and binders for Chambers; (ii) preparing certificates of no objection regarding various motions; (iii). preparing memoranda and documents concerning pending litigation and pending motions and the preparation of orders regarding the same; (iv) coordinating service and filing of various pleadings; and (v) reviewing various pleadings prior to hearings. Fees: $6, Hours: E. Case Administration 18. This category relates to work regarding administration of these cases. During the Interim Period, the Firm, among other things: (i) conferred with counsel regarding scheduling issues; (ii) reviewed correspondence and pleadings and forwarded them to DOCS SF: /002 7

14 Case KG Doc 1004 Filed 10/24/16 Page 14 of 19 appropriate parties; (iii) maintained a memorandum of critical dates; (iv) maintained document control; (v) maintained service lists; and (vi) conferred and corresponded regarding case administration issues. Fees: $2, Hours: 8.90 F. Claims Administration and Ob.iections 19. This category relates to work regarding claims administration and claims objections. These objections covered a variety of claims, including (i) objections to and resolution of claims asserted by taxing authorities; (ii) resolutions of personal injury claims asserted by various litigants; (iii) analysis of large litigation claims asserted by certain farmer vendors and customers; and (iv) resolution of the pending claims previously objected to in the Debtors second and third omnibus objections to claims. Specifically, the Firm addressed multiple tax claim asserted by various entities. These objections were subsequently filed and are currently pending before the Court as of the date hereof. Concurrently, the Firm and the Debtors' advisors continued their efforts to resolve pending issues with certain taxing authorities to potentially avoid the time and expense of having to litigate objections to these tax claims. The Firm. also assisted the Debtors in analyzing the various claims asserted by alleged personal injury and litigation claimants, as well as overlapping issues with the Debtors' respective insurers. The Firm. assisted the Debtors in analyzing several large claims asserted by former customers, vendors and litigants. These claims are complex and involve many issues regarding the ultimate liquidation and allowance of these claims as well as the Debtors' various defenses that could reduce the affirmative amounts- alleged in these claims. Finally, the Firm. assisted the Debtors DOCS SF: /002

15 Case KG Doc 1004 Filed 10/24/16 Page 15 of 19 with issues resulting in the disallowance and modification of the claims in the Debtors' second and third omnibus objections to claims, which objections were sustained by the Bankruptcy Court by orders_ entered on September 13, During this period, lawyers from the Firm also attended a meeting in Fort Warth, Texas with the advisors of the Debtors' principal to develop a framework and strategy by which the cases may be concluded through a chapter 11 plan. Fees: $55, Hours: G. Compensation of ~'rofessionals/~'ee Ernplovment Application 20. Time billed to these categories relate to (i) the preparation of the Firm's August fee statement and preparation of CNO's regarding the Firm's July fee statement and third interim application.. Fees: $7, Hours: H. Compensation of Professionals/Others 21. Time billed to this category relates to: (i) the review and preparation of Aurora's monthly staffing report; (ii) preparation of the notice of hearing on third interim fee applications; (iii) review and reconciliation of the professional fee payment schedule; and (iv) preparation of an exhibit chart of estate professionals for the third interim fee period. Fees: $4, Hours: 7.70 L Financing 22. Time billed to this category relates to, among other things: (i) reviewing and analyzing cash collateral issues; (ii) preparation of a motion to approve use of cash collateral DOGS SF: /002 9

16 Case KG Doc 1004 Filed 10/24/16 Page 16 of 19 on a consolidated basis; and (iii) reviewing and assisting with the preparation of a consolidated budget. Fees: $15, Hours: J. Non-Working Travel 23. During the Interim Period, the Firm incurred non-working time while traveling on case matters. Such time is billed at one-half the normal rate. Fees: $4, Hours: K. Plan &Disclosure Statement 24. During the Interim Period the Firm, among other things: (i) continued to prepare a disclosure statement and related plan; (ii) prepared a motion to extend exclusivity, which the Court granted; (iii) prepared a liquidation trust agreement; and conferred with counsel and estate professionals regarding a liquidating plan. Fees: $39, Hours: L. Stay Litigation 25. Time billed to this category relates to addressing stay relief issues. During the Interim Period, the Firm, among other things: (i) reviewed, analyzed and performed research regarding Tennessee Mutual's stay relief motion (which motion was eventually continued); (ii) prepared a response to Tennessee Mutual's motion; and (iii) corresponded with counsel regarding same. Fees: $8, Hours: POCS SF: /002 l~

17 Case KG Doc 1004 Filed 10/24/16 Page 17 of 19 M. Tar Issues 26. Time billed to this category relates to the status of the Debtors' tax refunds and issues regarding certain Ohio tax claims. Fees: $ Hours:.40 Valuation of Services 27. Attorneys and paraprofessionals of PSZ&J expended a total of hours in connection with their representation of the Debtors during the Interim Period as set forth above. 28. The nature of work. performed by these persons in connection with services related to the Debtors is fully set forth on Exhibit A attached hereto. These are PSZ&J's normal hourly rates for work of this nature. The reasonable value of the services rendered by PSZ&J for the Debtors during the Interim Period is $151, In accordance with the factors enumerated in section 330 of the Bankruptcy 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 Bankruptcy Code. Moreover, PSZ&J has reviewed the requirements of Del. Bankr. LR and the Administrative Order and believes that this Application complies with such Rule and Order. WHEREFORE, PSZ&J respectfully requests that, for the period September 1, 2016 through September 30, 2016, an interim allowance be made to PSZ&J for compensation in DOGS SF: /002 11

18 Case KG Doc 1004 Filed 10/24/16 Page 18 of 19 the amount of $151, and actual and necessary expenses in the amount of $2, for a total allowance of $153, and payment of $121, (80% of the allowed fees) and reimbursement of $2, (100% of the allowed expenses) for a total payment of $123,316.36, and for such other and further relief as this Court may deem just and proper. Dated: October 24, 2016 PACHULSKI STANG ZIEHL &JONES LLP /s/james E. O'Neill Jeffrey N. Pomerantz (CA Bar No ) Maxim B. Litvak (CA Bar No ) James E. O'Neill (DE Bar No. 4042) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE Telephone: 3 02/ Facsimile: 3 02/ E-mai l: j pamerantz@pszj law. com mlitvak@pszjlaw.com joneill@pszjlaw.com Counsel for the Debtors DOCS SF: /002 l2

19 Case KG Doc 1004 Filed 10/24/16 Page 19 of 19 STATE OF DELAWARE COUNTY Or NEW CASTLE DECLARATION James E. O'Neill, after being duly sworn according to law, deposes and says: a) I am a partner with the applicant law firm Pachulski Stang Ziehl &Jones LLP, and have been admitted to appear before this Court. b) I am familiar with many of the legal services rendered by Pachulski Stang Ziehl &Jones LLP as counsel to the Debtors. 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. Bankr. LR and the Administrative Order signed on or about November 4, 2015, and submit that the Application substantially complies with such Rule and Order. /s/james E. O'Neill James E. O'Neill DOGS SF: /002

20 Case KG Doc Filed 10/24/16 Page 1 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 MALIBU LIGHTING CORPORATION, et al., I) Case No (KG) Debtors. ) (Jointly Administered) Hearing Date: Scheduled only if I~Iecessary Objection Deadline: November 14, 2016, at 4:00 p.m. NO'T'ICE OF FILING OF TWELFTH MONTHLY APPLICATION FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES OF PACHULSKI STANG ZIEHL &JONES LLP, AS COUNSEL FOR DEBTORS FOR THE PERIOD FROM SEPTEMBER 1, 2016, THROUGH SEPTEMBER 30, 2Q16 TO: (a) the Office of the United States Trustee for the District of Delaware; (b) counsel to the Debtors' Prepetition and Postpetition Lenders; and (c) counsel to the Official Committee of Unsecured Creditors (the "Notice Parties"). PLEASE TAKE NOTICE THAT Pachulski Stang Ziehl &Jones LLP ("PSZJ"), as counsel to the debtors and debtors in possession in the above-captioned cases (the "Debtors") has filed the attached Twelfth Monthly Applic~rtion for Compensation and ReimbuNsenZent of Expenses of Pachulski Stang Ziehl &Jones LLP, as Counsel fon Debtors fof the Period froyn SeptembeN 1, 2016, thnough September 30, 2016 (the "Application"), with the United States Bankruptcy Court for the District of Delaware,_ 824 North Market Street, Wilmington, Delaware (the "Bankruptcy Court"). Pursuant to the Application, PSZJ seeks compensation for services rendered to the Debtors in the amount of $151, and reimbursement of costs incurred in the amount of $2, ' The Debtors, together with the last four digits of each Debtor's tax identification number, are: Malibu Lighting Corporation (0556); Outdoor Direct Corporation f/k/a The Brinkmann Corporation (9246); NC Estate Corporation (1153); Q-Beam Corporation (1560); Smoke `N Pit Corporation (9951); Treasure Sensor Corporation (9938); and Stubbs Collections, Inc. (6615). The location of the Debtors' service address is P.O. Box 5960, Frisco, TX

21 Case KG Doc Filed 10/24/16 Page 2 of 3 PLEASE TAKE FURTHER NOTICE THAT OBJECTIONS AND RESPONSES TO THE APPLICATION, IF ANY, MUST BE IN WRITING AND FILED WITH THE BANKRUPTCY COURT NO LATER THAN NOVEMBER 14, 2016, AT 4:00 P.M., PREVAILING EASTERN TIME. Objections or other responses to the Application, if any, must also be served so that they are received not later than November 14, 2Q16, 4:OQ p.m., prevailing Eastern Time by: (i) counsel to the Debtors: (a) Pachulski Stang Ziehl &Jones LLP, 919 North Market Street, 17t~' Floor, Wilmington, DE 19801, Attn: James E. O'Neill, Esq., joneill@pszjlaw.com, and (b) Pachulski Stang Ziehl &Jones LLP, Santa Monica Blvd., 13th Floor, Los Angeles, California 90067, Attn: Jeffrey N. Pomerantz, Esq., jpomerantz@pszjlaw.com; (ii) Office of the U.S. Trustee, 844 North King Street, Suite 2207, Lockbox 35, Wilmington, DE 19801, Attn: Linda Casey, Esq., linda.casey@usdoj.gov; (iii) counsel to the Official Committee of Unsecured Creditors: (a) Lowenstein Sandler LLP, 65 Livingston Avenue, Roseland, NJ 07068, Attn: Kenneth A. Rosen, Esq., krosen@lowenstein.com; and Eric S. Chafetz, Esq., echafetz@lowenstein.com; and (b) Blank Rome LLP, 1201 North Market Street, Suite 800, Wilmington, DE 19801, Attn: Bonnie Glantz Fatell, Esq., Fatell@B1ankRome.com; and (iv) counsel to the Debtors' prepetition and postpetition lenders: (a) Bank of America, N.A., as Agent, Issuer, and Guaranty Agent, (i) Buchanan Ingersoll &Rooney, PC, 919 North Market Street, Suite 1500, Wilmington, DE 19801, Attn: Kathleen A. Murphy, Esq.; kathleen.murphy@bipc.com; and (ii) Bryan Cave LLP, Two North Central Avenue, Suite 2200, Phoenix, AZ, Attn: Robert J. Miller, Esq., rjmiller@bryancave.com and Brian C. Walsh, Esq., brian.walsh@briancave.com; and (b) counsel for Comerica Bank: (i) Jackson Walker L.L.P., McKinney Street, Suite 1900, Houston, TX 77010, Attn: Bruce J. Ruzinsky, Esq., bruzinsky@jw.com; (ii) Jackson Walker L.L.P.,

22 Case KG Doc Filed 10/24/16 Page 3 of 3 Ross Avenue, Suite 600, Dallas, TX 75201, Attn: David S. Stolle, Esq., dstolle@jw.com; and (iii) Buchanan Ingersoll &Rooney PC, 919 North Market Street, Suite 1500, Wilmington, DE , Attn: Peter J. Duhig, Esq., peter.duhig@bipc.com. PLEASE TAKE FURTHER NOTICE that if any responses or objections to the Application are timely filed, served and received, a hearing on the Application will be held at the convenience of the Bankruptcy Court. Only those objections made in writing and timely filed and received in accordance with the Administrative Order and the procedures described herein will be considered by the Bankruptcy Court at such hearing. PLEASE TAKE FURTHER NOTICE that, pursuant to the Administrative Order, if no objection to the Application is timely filed, served and received by the Objection Deadline, the Applicant may be paid an amount equal to the lesser of (i) 80 percent of the fees and 100 percent of expenses requested in the Application or (ii) 80 percent of the fees and 100 percent of the expenses not subject to an objection without the need for further order of the Bankruptcy Court. Dated: October 24, 2016 PACHULSKI STANG ZIEHL &JONES LLP /s/jarraes E. O'Neill Jeffrey N. Pomerantz (CA Bar No ) James E. O'Neill (DE Bar No. 4042) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE Telephone: 302/ Facsimile: 302/ jpomerantz@pszjlaw.com joneill@pszjlaw.com Counsel to the Debtors and DebtoNs in Possesszon DOCS D~ /007 3

23 Case KG Doc Filed 10/24/16 Page 1 of 32 t ~ t--~ - ~ DOCS SF: /002

24 Case KG Doc Filed 10/24/16 Page 2 of 32 Pachuls~i Stang Ziehl &Jones LLP Santa Monica Blvd. 13th Floor Los Angeles, CA September 30, 2016 David Baker Invoice Chief Restructuring Officer Client The Brinkman Corporation Dallas Manufacturing Corporation Matter Malibu Lighting JNP RE: Consolidated Debtors STATEMENT OF PROFESSIONAL SERVICES RENDERED THROUGH 09/30/2016 FEES $151,482,25 EXPENSES $2, TOTAL CURRENT CHARGES $153, TOTAL BALANCE DUE $153,612.81

25 Case KG Doc Filed 10/24/16 Page 3 of 32 Pachulski Stang Ziehl &Jones LLP Brinl<mann Corporation, The Paga: 2 Invoice September 30, 2016 Summary of Services by Task Code Task Code Description Hours Amount AA Asset Analysis/Recovery[B120] ~ ~~ $4, AC Avoidance Actions 1.60 $1, AD Asset Disposition [B130] 0.50 $ BL Bankruptcy Litigation [L430] $6, CA Case Administration [8110] 8.90 $2, CO Claims Admin/Objections[B310] $55, CP Compensation Prof. [B 160] $7, CPO Comp, of Pro /Others 840 $4, FE Fee/Employment Application 0.10 $32.50 FN Financing [B230] $15, NT Non-Working Travel $4, PD Plan &Disclosure Stmt. [B320J 48 ~~ $39, SL Stay Litigation [B140] $8, TI Tax Issues (8240] 0.40 $ $151, Summary of Services by Professon al ID Name Title Rate Hours Amount ARP Paul, Andrea R. Case Man. Asst $ AWC Caine, Andrew W. Partner $ CI-IM Mackle, Cia H. Counsel $ IAWN Nasatir, Iain A. W. Partner $14, JEO O'Neill, James E. Partner $12, JHR Rosell, Jason H. Counsel $2, JMT Fried, Joshua M. Partner $1, JMF Fried, Joshua M. Partner $62, JNP Pomerantz, Jeffrey N. Partner $2, JNP Pomerantz, Jeffrey N. Partner $21, JPN Nolan, Jeffrey P. Counsel $17, KFF Finalyson, ICathe F. Paralegal $5, KSN Neil, Karen S. Case Man. Asst $400.00

26 Case KG Doc Filed 10/24/16 Page 4 of 32 Pachulski Stang Ziehl &Jones LLP Brinkmann Corporation, The Page: 3 Invoice September 30, 2016 LCT Thomas, Elizabeth C. Paralegal $32.50 MRS Seidl, Michael R. Partner $ PJJ Jeffries, Patricia J. Paralegal $6, SLP Pitman, L, Sheryle Case Man. Asst, 250, $ $151, Summary of Expenses DeI7 scription Amount Auto Travel expense [E109] $ Working Meals [E111] $89.24 Hotel Expense [E110] $1, Reproduction Expense [E101] $ Reproduction/ Scan Copy $ Overtime $36.16 Travel Expense [E110] $70.12 $2,130.56

27 Case KG Doc Filed 10/24/16 Page 5 of 32 Pachulski Stang Ziehl &Jones LLP Page; 4 Brinkmann Corporation, The Invoice September 30, 2016 Asset Analysis/Itecovery[B120] Hours Rate Amount 09/02/2016 JMr AA Review utility deposit issues &internal ernails re $ same. 09/02/2016 JMF AA Telephone call with J.N. Pomerantz & J. Nolan re $ litigation claims. 09/04/2016 JMF AA Review utility motion &documents re deposit $ returns. 09/15/2016 JNP AA Review and respond to s regarding $ maintenance of health care reserve. 09/15/2016 JMF AA Review IP sales &patent issues re ODC property $ /15/2016 JMF AA Review utility order s re same $ /16/2016 PJJ AA Prepare form letters to Utility Companies re return $ of deposits. 09/16/2016 JMF AA Draft letters re utility deposit refund &internal $556,50 s re same. 09/19/2016 JNP AA s regarding planning IP issues $ /19/2016 PJJ AA Prepare utility letters for Aurora review $ /19/2016 JMF AA Internal s re IP issues, $ /20/2016 PJJ AA Prepare Utility letters for mailing. l $ /20/2016 PJJ AA Revise utility letter to CenterPoint Energy $97,50 09/20/2016 JMF AA Draft utility letter re refund of deposit $ /28/2016 JNP AA s to Jason H. Rosen regarding expeditors $92.50 inventory. 09/28/2016 JNP AA to M. Warner and M, Fayhee regarding $92.50 expeditors inventory. 09/30/2016 AWC AA s with team regarding Halian preference $ analysis issues $4, Avoidance Actions 09/2$/2016 JPN AC Telephone conference with Iain A. W. Nasatir $ regarding insurance issues with West Marine; Exchange s regarding same. 09/28/2016 JPN AC Telephone conference with L. Kendall regarding $ /27/16 data and updated Hailian Transport data; Exchange s. 09/28/2016 JPN AC Draft terms with West Marine to resolve Claim No $ /29/2016 AWC AC Review new Aurora spreadsheets and discussions ,00 $ with team regarding preference

28 Case KG Doc Filed 10/24/16 Page 6 of 32 Pachulski Stang Ziehl &Jones LLP Page: 5 Brinkmann Corporation, The Invoice September 30, 2016 data analyses/issues/strategy. Hours Rate Amount 1.60 $1, Asset Disposition [B130] 09/28/2016 JHR AD Research proposed goods to be sold by Expeditors $ /29/2016 JNP AD s to and from M. Warner regarding Brinkmann $ IP auction attendees and research regarding same. Bankruptcy Litigation [L430] 0.50 $ /01/2016 KFF BL Revise agenda for September 15 hearing $ /02/2016 KFF BL Prepare Third Motion to Extend Exclusivity for $ filing and service (.Z), including drafting Notice (.2) and drafting affidavit of service and service documents (.2) 09/02/2016 KFF BL Review updated Court docket and recently filed $97.50 pleadings and draft critical dates memo 09/06/2016 KFF BL Revise, finalize and distribute critical dates memo $ /06/2016 KFF BL Draft certification of no objection for Third Motion $32.50 to Extend Exclusivity 09/07/2016 KFF B~ Revise agenda for September 15 hearing and $65.00 circulate to counsel 09/08/2016 KFF BL Revise agenda for September 15 hearing to include $65.00 opposition to Tennessee Farmers Mutual's Motion 09/08/2016 KFF BL Prepare Debtors' Opposition to Motion of Tennessee $65.00 Farmers Mutual's Motion for Relief for filing and service 09/08/2016 KFF BL Draft service documents and special service list for 0, $65.00 Debtors' Opposition to Motion of Tennessee Farmers Mutual's Motion for Relief 09/08/2016 KFF BL File and serve Debtors' Opposition to Motion of $97.50 Tennessee Farmers Mutual's Motion for Relief 09/09/2016 KFF BL Update agenda for September 15 hearing several $ times (.S) and circulate to counsel (.1) 09/12/2016 KFF BL Draft pro hac vice motion for Iain Nasatir (.2), $ including obtaining receipt number (.1) and preparing for filing with Court (.1) 09/12/2016 KFF BI. Revise agenda for September 15 hearing, including $97.50 organizing additional documents for hearing binders 09/12/2016 KFF BL Revise critical dates memo (.1) and prepare for $97.50 distribution to client and counsel (.2)

29 Case KG Doc Filed 10/24/16 Page 7 of 32 Pachuls]<i Stang Ziehl &Jones LLP Brinkmann Corporation, The Page: 6 Invoice September 30, 2016 Hours Rate Amount 09/12/2016 JEO BL Review draft agenda for 9.15 hearing and circulate $ to PSZJ team. 09/12/2016 JMF B~ Review agenda re 9/15 hearing $ /12/2016 JHR BL Correspondence with J. Pomerantz and J. Fried re: $ budget issues 09/13/2016 KFF BL Revise, finalize and prepare for ding and service the $97.50 agenda for the September 15 hearing 09/13/2016 ICFF BL Review and revise hearing binders and submit to OQ $ chambers in connection with September 15 hearing 09/13/2016 KFF BL Draft Notice for Cash Collateral Motion on a $65.00 Consolidated Basis 09/13/2016 KFF BL Draft Affidavit of Service and service documents 0.20 (.2), including drafting special service list (.2) for $65.00 Cash Collateral Motion (Consolidated Basis) 09/13/2016 KFF ~~ Review updated Court docket and revise critical $65.00 dates memo 09/13/2016 JEO BL Finalize agenda for 9/15 hearing $ /14/2016 ICFF BL Serve orders, including drafting affidavits of service 1.80 for filing with Court and draft service documents for $ the following orders: (1) Admission pro hac vice for Iaim Nasitir; (2) Second Omnibus Objection to Claims; (3) Third Omnibus Objection to Claims; (4) Objection Disallowing Claim of Henderson County, Texas and (5) Objection Disallowing Claim of Oklahoma Tax Commission 09/14/2016 KFF BL Draft amended agenda far September 15 hearing $ (.3), draft affidavit of service and service documents (.2), ~ 3~ file and serve agenda and submit to chambers 09/14/2016 KFF ~1- Review updated Court docket and revise critical O $32.50 dates memo 09/14/2016 ICFF BL Review recently received documents and prepare for $65.00 distribution to client and counsel 09/14/2016 JEO BL Review agenda canceling 9/IS hearing $ /14/201.6 JEO BL to Laura Kendall re cancellation of 9/ $ hearing. 09/15/2016 KFF BL Serve omnibus order approving third quarter fees, 0.30 including drafting affidavit of service and service $97.50 documents 09/15/2016 KFF ~L Review recently received documents and prepare for $32.50 distribution to client and counsel 09/19/2016 KFF ~~- Review updated Court docket and recently received 0.30 documents and draft critical dates memo (.1) and $97.50 prepare for distribution to client and counsel (.2)

30 Case KG Doc Filed 10/24/16 Page 8 of 32 Pachulski Stang Ziehl &Jones LLP Brinkmann Corporation, The Page: 7 Invoice September 30, 2016 Hours Rate Amount 09/21/2016 KFF BL Draft agenda for October 4 hearing (.2), including $ drafting affidavit of service and service documents ~ 2) 09/21/2016 KFF BL Review recent pleadings and revise agenda for $ October 18 hearing 09/21/2016 KFF BL Review updated Court docket and draft critical dates ,00 $65.00 memo 09/21/2016 JEO BL Contact court to get November hearing date $ /26/2016 KFF BIa Finalize and distribute critical dates memo to client $65.00 and counsel 09/27/2016 KFF BL. Review vcourt docket and recently filed documents $65.00 and update agenda for October 18 hearing 09/27/2016 KFF BL Draft certification of no objection regarding Motion $32.50 for Use of Cash Collateral on a Consolidated Basis 09/28/2016 KFF BL Draft affidavit of service and service documents for $65.00 October 4 hearing 09/29/2016 KFF BL Revise agenda for October 4 hearing $ /29/2016 KFF BL Finalize and prepare for filing and service the $ agenda for the October 4 hearing (.2), including reviewing hearing binder and preparing order for judge's signature and submitting to chambers (.2) 09/29/2016 JEO BL Finalize agenda for 10/4 hearing $ /29/2016 JMF BL Review agenda &internal s re same $ /30/2016 KFF BL Draft, file and serve amended agenda for October $162:50 hearing (.3), including submitting to chambers (.2) 09/30/2016 KFF BL Serve Order Authorizing Use of Cash Collateral on a $97.50 Consolidated Basis, including drafting affidavit of service for filing with Court and service documents 09/30/2016 KFF BL Review recently received documents and prepare for $32.50 distribution to client and counsel 09/30/2016 KFF BL Review updated Court dockets and recently filed $65.00 documents and draft critical dates memo 09/30/2016 JEO BI, Review status of matters scheduled for 10/4 hearing $ and review/sign agenda canceling hearing. is.60 $6, Case Administration [B110] 09/01/2016 SLP CA Maintain document control $ /02/2016 PJJ CA Update critical dates memo, calendar entries and $32.50 reminders. 09/07/2016 PJJ CA Update critical dates, calendar entries and reminders $130.00

31 Case KG Doc Filed 10/24/16 Page 9 of 32 Pachulski Stang Ziehl &Jones LLP Brinkmann Corporation, The Page: 8 Invoice September 30, 2016 Hours Rate Amount 09/07/2016 ARP CA Maintain document control $ /Q8/2016 ARP CA Maintain document control $ /09/2016 ARP CA Maintain documept control $ /12/2016 PJJ CA Update critical dates memo, calendar entries and $65.00 reminders. 09/12/2016 SLP CA Maintain document control $ /12/2016 ARP CA Maintain document control $ /12/2016 KSN CA Maintain document control $ /12/2016 Tf-IR CA Review critical dates memorandum $ /13/2076 SLP CA Maintain document control $ /13/2016 KSN CA Maintain document control $ /14/201.6 SLP CA Maintain docket control. 0, $ /14/2016 KSN CA Maintain document control $ /15/2016 SLP CA Maintain document control $ /1 S/2016 ARP CA Maintain document control $ /16/2016 SLP CA Maintain document control $ /16/2016 l~rp CA Maintain document control $ /]6/2016 KSN CA Maintain document control $ /19/2016 SLP CA Maintain document control $ /19/2016 JHR CA Review critical dates memorandum $ /20/2016 PJJ ~A Update critical dates, calendar entries and reminders $ /21/2016 SLP CA Maintain document control $ /21/2016 ARP CA Maintain document control $ /22/2016 ARP CA Maintain document control $ /23/2016 KSN CA Maintain document control $ /26/2016 JNP CA Conference with NI. Warner regarding meeting with $ Committee (2x). 09/26/2016 PJJ CA Update critical dates, calendar entries and reminders $ /26/2016 KSN CA Maintain document control $ /27/2016 SLP CA Maintain document control, $ /29/2016 KSN CA Maintain document control $ /30/2016 SLP CA Maintain document control $ /30/2016 KSN CA Maintain document control $ $2,637.50

32 Case KG Doc Filed 10/24/16 Page 10 of 32 Pachulski Stang Ziehl &Jones LLP Brinkmann Corporation, The Page: 9 Invoice September 30, 2016 Hours Rate Amount Claims Admin/Objections[B310] 09/01/2016 CHM CO Review from P. Jeffries re J. Eisch and reply. 0, $ /01/2016 CI-1M CO L. Kendall re status of Mississippi and $55.00 Missouri objections. 09/01/2016 CHM CO J. O'Neill re review of Missouri objection $SS.00 09/01/2016 IAWN CO Exchange s with Jeffrey N Pomerantz and Josh $ Fried re call,.l, telephone conference with Josh Fried and Jeffrey N Pomerantz re stay motion by Tennessee,.4 09/01/2016 JNP GO Participate in meeting with Brinkmann 3.SQ $3, representatives, Aurora and Joshua M. Fried. 09/01/2016 KFF CO Submit claim binder for Third Omnibus Objection to $32.50 Claims to chambers 09/01/2016 PJJ CO Review Committee questions regarding open claims $65.00 (.1); Bmail Josh Fried re same (.1). 09/01/2016 JEO CO Review notice of submission of claim for 3rd $ omnibus claim objection. 09/01 /2016 JMF CO Telephone call with E. Chefetz & J. Cashel re claims $ analysis. 09/01/2016 JMF CO Meet with M. Fayhee, D Baker, M Warner, J $4, Pomerantz, L Kendall, J Eisch, R Hollander re all hands meeting. 09/01/2016 JMF CO Review claims memo &litigation claims for $ meeting. 09/02/2016 JNP CO Conference with Jeffrey P. Nolan and Joshua M $ Fried regarding claims issues and authorization. 09/02/2016 JPN CO Conference call with Jeffrey N. Pomerantz and $ Joshua M. Fried regarding outcome of 9/1/16 meeting; Settlement authority and future handling of claims. 09/02/2016 JPN CO Receive correspondence form L. Kendall and $69.50 coordinate conference call. 09/02/2016 ICFF CO Revise and prepare Objection to Mississippi $ Department of Revenue's Claims for filing and service (.6), including drafting Notice (.2) and drafting affidavit of service and service documents ~ 2) 09/06/2016 CHM CO Review from J. O'Neill re Henderson County $55.00 and Oklahoma and reply. 09/06/2016 JPN CO Conference call with Aurora regarding discussion of $ document retrieval for transfers to Hailian, fact pattern and avoidance analysis. 09/06/2016 JPN CO Review Hailian pre-preference data; Draft $139.00