UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION MONTHLY FEE STATEMENT NOTICE OF SUSAN N. GOODMAN

Transcription

1 Case Document 514 Filed in TXSB on 09/20/18 Page 1 of 13 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: NEIGHBORS LEGACY HOLDINGS, INC., et al., Debtors. 1 Chapter 11 Case No.: MI (Jointly Administered) MONTHLY FEE STATEMENT NOTICE OF SUSAN N. GOODMAN FOR COMPENSATION OF SERVICES AS PATIENT CARE OMBUDSMAN FOR PERIOD AUGUST 9-31, 2018 Pursuant to this Court s Order Granting Debtors Motion for an Order Under U.S.C. 105(A) and 331 Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Professionals [Docket No. 342] entered September 4, 2018 (the Interim Compensation Order), Susan N. Goodman, the Patient Care Ombudsman ( PCO ) submitted her monthly statement for services rendered from appointment on August 9, 2018 through August 31, 2018 (the Statement Period ). All PCO s services fall under general case administration. The Statement Period reflected initial efforts from appointment and completion of site visits and reports for facilities included in the West Texas Locations, Austin, and South Texas Locations. PCO spent 61.5 hours engaged in these efforts, with administrative support engagement of 1.9 hours. The Monthly Statement Letter, Summary, and Itemized Billing submitted to the interested professionals is attached to this Notice herein. 1 Due to the large number of Debtors in these chapter 11 cases, a complete list of the Debtors and the last four digits of their tax identification numbers are not provided herein. A complete list of such information may be obtained on the website of the Debtors proposed claims and noticing agent at The location of Debtors principal place of business and the Debtors service address is Richmond Avenue. Houston, Texas

2 Case Document 514 Filed in TXSB on 09/20/18 Page 2 of 13 WHEREFORE, pursuant to the Interim Compensation Order, PCO requests payment of compensation in the amount of $18, (80% of $23,338.00) and expense reimbursement in the amount of $3,222.52, totaling $21, Dated: September 20, 2018 MESCH CLARK ROTHSCHILD By: /s/ Susan N. Goodman, AZ Bar # Susan N. Goodman Arizona State Bar No North Meyer Avenue Tucson, Arizona Phone: (800) ext 141 Fax: (520) sgoodman@mcrazlaw.com Patient Care Ombudsman CERTIFICATE OF SERVICE I hereby certify that on September 20, 2018, a true and correct copy of the foregoing document was served by the Electronic Case Filing System for the United States Bankruptcy Court for the Southern District of Texas on those parties registered to receive electronic notices. /s/susan N. Goodman, AZ Bar # Susan N. Goodman 25K2589

3 Case Document 514 Filed in TXSB on 09/20/18 Page 3 of 13 sgoodman@mcrazlaw.com Our File No RECIPIENTS LISTED ON EXHIBIT A, Via or Mail Re: First Fee Statement - Patient Care Ombudsman In re: Neighbors Legacy Holdings, Inc., et al. Case No in the Southern District of Texas, Houston Division Interested Parties: The Patient Care Ombudsman ( PCO ) submits this First Fee Statement encompassing the period from appointment through August 31, The total fee amount owed for this period is $23, Fees included initial site visits and reports for West Texas, Austin, and South Texas locations (nine in all). Expenses for this period are $3, PCO s rate is competitive with rates charged by other professionals who engage in ombudsman work, with the added benefit of fee economy from PCO s ability to engage as a single professional given her operational, clinical, and legal healthcare experience. PCO s economy is apparent from an average per location site visit cost of less than $2, per location. PCO s fee statement summary is detailed in Exhibit B with itemized billing statements attached in Exhibit C. Accordingly, PCO requests that 80% of fees and 100% expenses, totaling $21, be paid in the ordinary due course to Mesch Clark Rothschild. Sincerely, Susan N. Goodman, RN JD 259 N. MEYER AVENUE TUCSON AZ PH: FAX: YEARS SERVING OUR CLIENTS AND OUR COMMUNITY

4 Case Document 514 Filed in TXSB on 09/20/18 Page 4 of 13 Page 2 MESCH CLARK ROTHSCHILD EXHIBIT A John F Higgins, IV Porter Hedges LLP 1000 Main Street 36th Floor Houston, TX jhiggins@porterhedges.com Attorneys for Debtor Chad Shandler Neighbors Legacy Holdings, Inc Richmond Ave. Houston, Texas chad.shandler@neighborshealth.com Interim CEO and Restructuring Officer for Debtors Hector Duran Office of the United States Trustee 515 Rusk, Suite 3516 Houston, Tx Hector.Duran.Jr@usdoj.gov Trial Attorney for the United States Trustee Region 7 Michael Warner Cole Schotz, P.C. 301 Commerce Street, Suite 1700 Fort Worth, Texas mwarner@coleschotz.com Attorneys for Unsecured Creditors Committee Matthew Tashman Reed Smith LLP 1717 Arch Street, Suite 3100 Philadelphia, PA mtashman@reedsmith.com Attorneys for KeyBank, N.A. 25K0508

5 Case Document 514 Filed in TXSB on 09/20/18 Page 5 of 13 Page 3 MESCH CLARK ROTHSCHILD EXHIBIT B Fee Statement Summary Case Name: Neighbors Legacy Holdings, Inc. Case No: SD TX /9/2018 to 8/31/2016 Cumulative Totals to Date FEES BILLED COSTS BILLED HOLDBACK FEES PAID COSTS PAID $23, $3, $4, $0.00 $0.00 Date: 18-Sep-18 Objection Deadline: 2-Oct-18 MO/YR PROFESSIONAL RATE/HR HOURS BILLED TOTAL HOLDBACK AMT DUE Aug-18 SUSAN N. GOODMAN $ $23, $4, $18, Aug-18 DANIELLE OESTERLE $ $ $55.10 $ TOTAL FEES $23, $4, $18, TOTAL COSTS $3, $0.00 $3, AMOUNT DUE $4, $21,892.92

6 Case Document 514 Filed in TXSB on 09/20/18 Page 6 of 13 Page 4 MESCH CLARK ROTHSCHILD EXHIBIT C Itemized Invoice(s)

7 Case Document 514 Filed in TXSB on 09/20/18 Page 7 of North Meyer Avenue, Tucson, AZ Phone: Fax: Tax ID No Invoice No Neighbors Legacy Holdings, Inc. Client: Matter: Neighbors Legacy Holdings, Inc NEC PCO For Services Rendered Through August 31, 2018 Total for Services Total for Expenses 23, , Total for Services and Expenses Past Due Balance Payments Since Last Bill Amount Due

8 Case Document 514 Filed in TXSB on 09/20/18 Page 8 of 13 Mesch Clark Rothschild Client Ref: Invoice No Label113 Page 1 Re: 0001 NEC PCO Date Services Professional Services Hours Amount 08/08/18 SNG Call with Hector re PCO order language /09/18 SNG pro hac application (admin rate) /09/18 DO Draft Notice of Appearance of Susan N. Goodman /09/18 SNG Introduction to CRO and initial connection with site leadership; introductory call scheduled /09/18 SNG docket management for items relevant to PCO role /09/18 SNG Initial travel strategy by area with specific detail for west TX - high level plan developed for DON discussion/approval /10/18 DO Finalize PCO's Notice of Appearance /10/18 SNG Introductory call with Lauren re role and visit plan /10/18 SNG Introductory call with Debtor counsel - budget, coverage process, tentative visit plan, number reports 08/10/18 SNG Follow up call with Lauren Cotton re visit plan, physician DE letters, /10/18 SNG manage travel remaining site locations /10/18 SNG Draft posting to team /10/18 SNG EML exchanges with Debtor counsel re scope of role and plan forward 08/13/18 SNG Review EML Lauren re clinic managers and organizational chart; finalize travel west tx, south tx, austin; docket review for items related to PCO role (rejection telehealth); gather TX Admin Code related to free standing ECs 08/14/18 SNG Site visit 1 West TX area: 1/2 rate non-working travel (TUS-AMA by plane) and AMA to LUB by auto , /14/18 SNG Site visit #1: AMA /14/18 SNG Site visit #1: LUB /14/18 SNG Calls: Veronica and Jennifer /15/18 SNG 1/2 rate non working travel (Midland; Odessa, El Paso) 08/15/18 SNG Site visit: Midland location - observe care, review documentation, supplies, processes, interview staff/physician ,

9 Case Document 514 Filed in TXSB on 09/20/18 Page 9 of 13 Mesch Clark Rothschild Client Ref: Invoice No Label113 Page 2 Date Services Professional Services 08/15/18 SNG Site visit Odessa: observe care, review documentation, supplies, processes, interview staff/physician Hours Amount /15/18 SNG Follow up call with Lauren C re El Paso visit /16/18 DO Draft background of PCO's First Interim Report for West Texas, Austin Metro and South Texas lactations /16/18 DO Draft PCO's First Consolidated Notice /16/18 DO Draft background of PCO's Second Interim Reports for Houston Metro, Beaumont/Orange Metro, and Northeast Texas /16/18 SNG 1/2 rate non working travel (to location; ELP to TUS) , /16/18 SNG Site visit El Paso: observe care, review documentation, supplies, processes, interview staff/physician , /16/18 SNG Site visit: additional discussion with physician /16/18 SNG Calls with Victoria and Lisa re site visit /17/18 SNG follow up call Lisa - NC - inadvertent dial (some additional site visit discussion) 08/17/18 SNG Docket management - for items potentially related to PCO role (contract assumption; employment, interim fees) /17/18 SNG Expense tracking SV1 West Texas (Exhib B) /17/18 SNG Update UST re West TX site visits /21/18 SNG TXT interaction Lauren Cotton re upcoming visits; follow up re West Texas concerns r/t equipment/lab 08/21/18 SNG review docket and revised assumed contracts for services and supplies related to patient care and safety /22/18 SNG 1/2 rate NW travel to AUS /22/18 SNG Site visit: AUS facility - interact with staff, interview physician, observe care interaction, review processes /22/18 SNG 1/2 rate NW travel AUS to HRL /22/18 SNG Site visit: HRL facility - interact with staff, interview physician, observe care interaction, review processes , /23/18 SNG 1/2 rate non working travel HRL to McAllen

10 Case Document 514 Filed in TXSB on 09/20/18 Page 10 of 13 Mesch Clark Rothschild Client Ref: Invoice No Label113 Page 3 Date Services Professional Services 08/23/18 SNG Site Visit: McAllen including discussion with medical director in addition to staff/physician interview; observe care; review processes Hours Amount , /23/18 SNG 1/2 rate non working travel McAllen to Brownsville /23/18 SNG Site visit: Brownsville - interview physicians/staff; observe care; review processes 08/23/18 SNG 1/2 rate non working travel Brownsville to HRL (auto) to AUS to ONT (divert weather) to PHX (air) to TUS (auto) - 10 hours less 1 hour writing report , /23/18 SNG Begin drafting West Texas report /23/18 SNG Docket management - various objections, schedules, stipulations for relevance to PCO role 08/29/18 SNG Docket management - hearing changes; notice of highest/best bidders /29/18 SNG Finish drafting West TX locations initial report , /30/18 SNG Follow up Lauren Cotton re West Texas Report Draft; Draft Austin Report to Michelle for initial review 08/30/18 SNG Manage travel for site visit Houston Metro and Beaumont DO to Interested Parties attaching Patient Care Ombudsman s First Reports for West Texas - Amarillo, Lubbock, Midland, Odessa, and El Paso Locations; Austin/Mueller Location; and South Texas - Harlingen, McAllen, and Brownsville Locations DO Finalize PCO's First Report for West Texas - Amarillo, Lubbock, Midland, Odessa DO Finalize PCO's First Report for South Texas - Harlingen, McAllen, and Brownsville Locations SNG EML follow up with Michelle re Austin report; Draft South Tx report - to managers for review; response from Sara; EML/TXT exchanges Lauren re report filing; filing report DO to Admin attaching PCO's First Report for West Texas Locations DO to Admin attaching PCO's First Report for Austin Location ,

11 Case Document 514 Filed in TXSB on 09/20/18 Page 11 of 13 Mesch Clark Rothschild Client Ref: Invoice No Label113 Page 4 Professional Services Date Services DO to Admin attaching PCO's First Report for South Texas Locations GC Review Bankruptcy Court filings; docket Notice of Hearing on Motion for Entry of Order Approving Auction & Bid Procedures and Scheduling an Auction for Sale of Debtors' Assets, etc. Hours Amount Summary of Services Rate Hours Amount SNG Susan N. Goodman SNG Susan N. Goodman , GC Grelda Castro DO Danielle Oesterle Total for Services $23, Disbursements Date Expenses Travel Meal El Tejavan 2 - Alliance Bank of Arizona Travel - Car Rental Rental Car - Fuel - Alliance Bank of Arizona Travel - Car Rental Gourmet Burritos - Meals - Alliance Bank of Arizona Travel Meal Great American Land & Cat - Meals - Alliance Bank of Arizona Travel - Car Rental Circle K - Fuel Rental - Alliance Bank of Arizona Travel - Car Rental Fuel Rental - Alliance Bank of Arizona Travel - Car Rental National Car Rental - Alliance Bank of Arizona Travel Hotel Hampton Inns Lubbock - Alliance Bank of Arizona Travel Hotel Hampton Inns El Paso - Alliance Bank of Arizona Travel - Car Rental Fuel - Rental Car - Alliance Bank of Arizona Travel - Car Rental Fuel - Rental Car - Alliance Bank of Arizona Travel - Car Rental Tucson Airport - Parking - Alliance Bank of Arizona Travel - Car Rental National Rental Car - Alliance Bank of Arizona Travel - Car Rental Gasoline - Rental Car - Alliance Bank of Arizona Travel - Car Rental Gasoline - Rental Car - Alliance Bank of Arizona Amount

12 Case Document 514 Filed in TXSB on 09/20/18 Page 12 of 13 Mesch Clark Rothschild Client Ref: Invoice No Label113 Page 5 Disbursements Date Expenses Amount Travel Expense - Misc. Parking - Sky Harbor Phoenix - Alliance Bank of Arizona Travel Meal Food - Alliance Bank of Arizona 8.71 Travel Meal Food - Alliance Bank of Arizona 3.51 Travel - Car Rental National Car Rental - Alliance Bank of Arizona Travel - Car Rental PCC Car Rental - Alliance Bank of Arizona Travel Hotel Hampton Inns - Alliance Bank of Arizona Total Expenses $3, Total for Services and Expenses Past Due Balance Payments Since Last Bill Amount Due

13 Case Document 514 Filed in TXSB on 09/20/18 Page 13 of 13 Please return this page with remittance to Mesch Clark Rothschild 259 N. Meyer Ave. Tucson, AZ Tucson, AZ Invoice No. Bill Date: Client Code: Client Name: Neighbors Legacy Holdings, Inc. Matter Code: 0001 Matter Name: NEC PCO Total for Services and Expenses Past Due Balance Payments Since Last Bill Amount Due Amount enclosed: Pay by Credit Card Label148 VISA Exp.Date: CVC: MC Exp.Date: CVC: AMEX Exp.Date: CVC: Address & Zip Code of Card Holder: Signature: Must have the CVC numbers from the back of the VISA or MC or the four numbers on the front of the AMEX cards for processing. Thank you.