Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 1 of 10

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1 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 1 of 10 UNITED STATES BANUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division IN RE: GARLOCK SEALING TECHNOLOGIES LLC, et al., Debtors 1 Case No Chapter 11 Jointly Administered Tenth Interim Application of Schachter Harris, LLP For Allowance of Compensation and Reimbursement of Expenses for Professional Services Rendered As Special Asbestos Defense Counsel for Debtors For the Period from August 1, 2014 through June 30, 2015 Name of applicant: Authorized to provide professional services to: Role in Case: Date of Retention: Schachter Harris, LLP Debtors Special Asbestos Defense Counsel Order entered July 21, 2010, effective as of June 5, 2010 Period for which compensation and reimbursement is sought: Aug. 1, 2014 through June 30, 2015 Amount of Compensation sought as actual, reasonable and necessary: $169, Amount of Expense Reimbursement sought As actual, reasonable and necessary: $653, Total amount of compensation and expense reimbursement sought as actual, reasonable and necessary: $823, This is the tenth interim fee application filed by Schachter Harris, LLP. 1 The Debtors in these jointly administered cases are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd. and The Anchor Packing Company. 1

2 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 2 of 10 UNITED STATES BANUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division IN RE: GARLOCK SEALING TECHNOLOGIES LLC, et al., Debtors 1 Case No Chapter 11 Jointly Administered Tenth Interim Application of Schachter Harris, LLP for Allowance of Compensation and Reimbursement of Expenses for Professional Services Rendered as Special Asbestos Defense Counsel for Debtors for the Period from August 1, 2014 through June 30, 2015 Schachter Harris, LLP, special asbestos defense counsel, submits this tenth interim application ( Application ) for allowance of compensation and reimbursement of expenses from August 1, 2014 through April 30, 2015 ( Compensation Period ) under sections 330 and 331 of title 11 of the United States Code, Rule 2016 of the Federal Rules of Bankruptcy Procedure, and this Court s Administrative Order under 11 U.S.C. 105(a) and 331 Establishing Procedures for Interim Compensation and Reimbursement Expenses for Professionals ( Fee Procedure Order ) entered July 15, 2010 (Docket No. 233). Schachter Harris moves for an order awarding it reasonable compensation for the Compensation Period for professional legal services rendered to the Debtors in the amount of $169, and reimbursement for actual and necessary expenses in the amount of $653, for a total of $823, In support of this Application, Schachter Harris would show: 1 The Debtors in these jointly administered cases are Garlock Sealing Technologies LLC, Garrison Litigation Management Group, Ltd. and The Anchor Packing Company. 1

3 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 3 of 10 Background 1. This court has jurisdiction over this Application under 28 U.S.C. 157 and This is a core proceeding within the meaning of 28 U.S.C. 157 (b)(2). 2. On June 5, 2010 (the Petition Date ), the Debtors filed voluntary petitions for relief under Chapter 11 of the Bankruptcy Code. 3. On June 9, 2010, an Order Authorizing Joint Administration of Related Chapter 11 Cases (Docket No. 58) was entered authorizing the joint administration of all three debtor cases. 4. On July 21, 2010, the Court entered an Order Approving Employment of Schachter Harris, LLP as Special Asbestos Defense Counsel as of the Petition Date (Docket No. 264) in the Chapter 11 cases. 5. After June 5, 2010, Schachter Harris has rendered services and incurred reasonable expenses on behalf of Debtors. 6. Under the Fee Procedure Order, professionals may request monthly compensation and reimbursement. Those requests are to be served on certain identified interested parties for review. If no objection is received within ten (10) days of such request, the Debtors are authorized to pay 90% of the fees and 100% of the expenses requested. 7. On December 24, 2014, the Court appointed W. Clarkson McDow as the Fee Examiner in these cases (Docket No. 4291). On June 1, 2015, the Court entered the Order Granting Fee Examiner s Motion for Proposed Professional Guidelines (Docket No. 4634) ( Fee Guidelines ). 2

4 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 4 of 10 Compensation Received During Compensation Period 8. All services for which Schachter Harris seeks compensation were performed for or on behalf of the Debtors. During the Compensation Period, Schachter Harris has received monthly payments for 90% of fees and 100% of expenses from the Debtors under the Fee Procedure Order as follows: Date of Request Period Covered Total Fees Total Expenses Payment Received Sep 19, 2014 August 1-31, 2014 $15, $125, $139, Oct 20, 2014 September 1-30, , , , Nov 20, 2014 October 1-31, , , , Dec 19, 2014 November 1-30, , , , Jan 20, 2015 December 1-31, , , , Feb 20, 2015 January 1-31, , , , Mar 20, 2015 February 1-28, , , , Apr 20, 2015 March 1-31, , , , May 20, 2015 April 1-30, , , , June 19, 2015 May 1-31, , , , July 20, 2015 June 1-30, , , None to date Total August 1, 2014 through June 30, 2015 $169, $653, Schachter Harris s monthly fee requests were served upon certain interested parties for review as directed by the Fee Procedure Order. As of the date of this Application, no interested party has objected to any of Schachter Harris s monthly fee requests. 3

5 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 5 of 10 Summary of Services Rendered 9. Schachter Harris has represented and advised the Debtor in its role as asbestos defense counsel since The Debtor retained Schachter Harris to continue to represent the Debtors in matters concerning the Debtors defenses and liability for asbestos related claims as they concern various aspects of the Debtors restructuring plan and other proceedings in the Cases. Schachter Harris also continues to represent Debtors in matters related to the cases in which Schachter Harris s lawyers represented Garlock and Anchor before the petition date. 10. Attached as Exhibits A-1 through A-11 are detailed descriptions of the services performed and expenses incurred by Schachter Harris broken down by month. Those descriptions include not only the services performed, but also the project category of the services, the name of the professional or paraprofessional that rendered the services, the date on which the services were rendered, the amount of time spent performing the services, and the fee incurred. Each exhibit also includes a summary of the costs, fees, and expenses incurred during that month, a summary of the time spent on the separate project categories, and a summary of the professionals and paraprofessionals that rendered services to the Debtors, which includes each professional s or paraprofessional s title, hourly rate, total number of hours billed and the fees billed. Schachter Harris does not bill the Debtor for tasks that do not increase the value the Debtor receives from the firm s services; the firm does not track this unbilled time. To the extent that charges for services rendered or expenses incurred related to the Compensation Period but were not processed prior to the preparation of, or otherwise included in this Application, Schachter Harris reserves the right to request additional compensation for such services and reimbursement of such expenses in future applications. 4

6 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 6 of Attached as Exhibit B is a cumulative compensation summary broken down by project category for the Compensation Period. The vast majority of services rendered by Schachter Harris were within the project category of Litigation. The Litigation services Schachter Harris has provided for the Debtors include, among other things: 2 (i) Research and analysis of legal and scientific issues related to estimation of claims other than mesothelioma. (ii) Conferring with consulting experts on scientific issues related to nonmesothelioma estimation. (iii) Responding to multiple requests from Robinson Bradshaw & Hinson, P.A. for files and information from several pre-petition cases in which Schachter Harris was involved, to assist RBH in preparing potential objections to proofs of claim. Schachter Harris s work on this project (noted as discovery project in October and November 2014 time entries) included paralegal time for locating, organizing, and preparing the case files, associate time for conducting privilege and work product reviews, and partner time for supervising the project. A similar project involving additional pre-petition cases occurred in March and April 2015 (time entries reference Krisko inquiry or inquiry from Krisko ). (iv) Responding to additional requests from RBH for our firm s files from several pre-petition cases that are expected to be at issue in the adversary proceedings. Schachter Harris s work on this project (noted as RBH request for pre-petition case 2 Schachter Harris details the projects in subparagraphs iii, iv, and v, in an effort to provide the Fee Examiner with sufficient information to discern the relevancy, necessity, and scope of the projects so that he can understand why multiple professionals undertook the projects. None of these projects exceeded $50,000 in fees and, thus, did not warrant billing as a separate sub-category under the Fee Guidelines. 5

7 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 7 of 10 files in May and June 2015 time entries) involved paralegal time for locating, organizing, and preparing files from pre-petition cases, associate and of counsel time for conducting privilege and work product reviews, and partner time for supervising the project. (v) Responding to subpoenas served on Schachter Harris in the ancillary proceedings. This project (noted as subpoena response project in January 2015 time entries) also involved paralegal time for locating, organizing, and preparing files from prepetition cases, associate time for conducting privilege and work product reviews, and partner time for supervising the project. (vi) Analysis of claims resolution procedures affecting scientific issues and conferring with consulting experts regarding feasibility of the claims resolution procedures. 12. Attached as Exhibit C is a cumulative expense summary for the Compensation Period. Schachter Harris incurred actual, reasonable, and necessary expenses totaling $653,687.47, of which $586, were incurred for or by consulting experts on behalf of the Debtors and $26, were incurred in record retrieval and storage costs for Debtors. Expenses for machine copying were billed at the rate of $0.10 per page. 13. A summary of the professionals and paraprofessionals that have rendered services to the Debtors, which includes each professional s or paraprofessional s title, years of experience, agreed special reduced hourly rate, total number of hours billed and fees billed for the Compensation Period is attached as Exhibit D. Schachter Harris did not increase its billing rates during the Interim Period. This Application does not include time of transitory professionals, as defined by the Fee Guidelines. Schachter Harris believes its billing rates for the Interim Period 6

8 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 8 of 10 should be deemed reasonable for purposes of this Court s determination of the reasonableness of the fees. 14. Attached as Exhibit E is a background summary of each professional included in this application, as required by the Local Guidelines. 15. No inter-office conferences involving more than two professionals were billed during the Interim Period. On multiple occasions during the Interim Period, Mr. Schachter and Mr. Harris conferred with RBH attorneys to analyze complex issues and strategies for moving the case toward confirmation, including plans for presenting evidence at the confirmation trial, nonmesothelioma claims estimation, and discovery issues. These matters require the coordination of both firms to ensure efficient and effective presentation of evidence to the Court, and the perspectives of each professional attending each meeting or conference call were both necessary and beneficial to the estate. A few meetings with RBH attorneys also included consulting experts, whose research and input on issues related to the non-mesothelioma claims estimation and the plan confirmation are essential to protecting the Debtor s interests. Schachter Harris s Fees and Expenses 16. Schachter Harris requests that the Court authorize (i) interim allowance of compensation for professional services rendered during the Compensation Period in the amount of $169, and (ii) the reimbursement of actual and necessary expenses and other charges incurred by Schachter Harris in the connection with the rendition of such professional services in the amount of $653, The services that Schachter Harris rendered to Debtors during the Compensation Period required 1,082.0 hours of the time of professionals and paraprofessionals. 7

9 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 9 of 10 Basis for Relief 18. The allowance of interim compensation for services rendered and reimbursement of expenses incurred in bankruptcy matters is provided for in section 331 of the Bankruptcy Code, [a] debtor s attorney, or any professional person may apply to the court for such compensation for services rendered as is provided under Section 330 of this title. 19. Section 330(a)(1) of the Bankruptcy Code provides that a court may award to a professional, including debtor s attorney, reasonable compensation for actual, necessary services rendered by the.professional person, or attorney and by any paraprofessional person employed by any such person, together with reimbursement for actual, necessary expenses. 11 U.S.C. 330 (a)(1). 20. The services for which Schachter Harris seeks compensation were necessary and beneficial to the estate, were not duplicative, and were performed within a reasonable amount of time commensurate with the complexity, importance and nature of the issues. 11 U.S.C. 330 (a)(3)-(4). Notice 21. Schachter Harris represents to the Court that it will serve this Tenth Application and accompanying Exhibits upon the Notice Parties, and a Notice of Opportunity for Hearing upon all other parties-in-interest as listed on the Certificate of Services filed with this Court. Conclusion For the reasons submitted above, Schachter Harris requests that this Court enter an order awarding Schachter Harris (i) interim compensation from the Debtors for services rendered for the Compensation Period in the amount of $169,973.00, (ii) reimbursement of actual and 8

10 Case Doc 4756 Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Main Document Page 10 of 10 necessary expenses and other charges incurred in connection with the rendition of such services, in the amount of $653,687.47, and (iii) such other relief as may be just and proper. Dated: August 12, Respectfully submitted, /S/ Ray Harris Ray Harris, Esq. (admitted pro hac vice) Cary Schachter, Esq. (admitted pro hac vice) SCHACHTER HARRIS, LLP 220 Canal Centre 400 E. Las Colinas Blvd. Irving, Texas (214) ; Fax (214) Special Asbestos Defense Counsel to the Debtors 9

11 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 1 of 104 Exhibit A 1

12 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 2 of 104 SCHACHTER HARRIS LLP Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, Texas (214) MONTHLY COMPENSATION STATEMENT TO: FROM: See Notice Parties, attached Schachter Harris, LLP DATE: September 19, 2014 RE: Garlock Sealing Technologies LLC, et.al. Case No (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of August 1, 2014 through August 31, During this period, SH incurred fees of $15, which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $6, for a total of $22, In addition, SH received statements in the amount of $118, for professional services and expenses from consulting experts hired for an estimation hearing. Pursuant to the Order on Debtors Motion for Administrative Order Under 11 U.S.C. 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the Administrative Order ) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $20, calculated as follows: $ 15, x.90 $ 14, , (100% of expenses) $ 20, SH also requests payment of $118, to pay the fees and expenses of the consulting experts. A summary of the fees, costs, and expenses and SH s billing records for the period of August 1, 2014 through August 31, 2014 are attached hereto and incorporated by reference. Cumulative Holdback Analysis: Through August 31, 2014: $32,188.00

13 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 3 of 104 NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. (linda_simpson@ncwba.uscourts.gov) 402 West Trade Street, Suite 200 Charlotte, NC John R. Miller, Jr. (jmiller@rcdlaw.net) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC Trevor W. Swett, Esq. (tws@capdale.com) Rita Tobin (rct@capdale.com; eb@capdale.com) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C Travis W. Moon, Esq. (tmoon@lawhms.com) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC Deborah L. Fletcher, Esq. (fletcher@fsblegal.com) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC C. Edward Dobbs(edobbs@phrd.com) Parker Hudson Rainer & Dobbs, L.L.P Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203

14 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 4 of 104 Schachter Harris, LLP Summary of Fees, Costs, and Expenses August 1, 2014 through August 31, 2014 Fees Name Hours Rate Amount Cary Schachter (Partner) 10.4 $300 3,120 Ray Harris (Partner) 28.1 $280 7,868 Laurie Fay (Partner) 0 $210 0 Susan Ashmore (Of Counsel) 0 $200 0 Erin Therrian (Associate) 0.5 $ Katrina Colwell (Associate) 0 $160 0 Mary Horsechief (Legal Assistant) 15.7 $90 1,413 Dena Farnsworth (Legal Assistant) 2.7 $ Karina Robledo (Legal Assistant) 33.2 $90 2, $15,712 Costs & Expenses Amount In-house Copying (.10 per page) Postage and Delivery Service Purchasing Third Party Research 0.00 Record Retrieval & Storage 2, Telephone Conference Fees Travel Expenses for Cary Schachter 2, Travel Expenses for Ray Harris 1, $6, Categories Hours Amount Asset Transactions 0 0 Case Admin. Business Op. 0 0 Claims Admin. 0 0 Fee Proceedings Financing/Relief from Stay Proceedings 0 0 Litigation ,469 Plan/Disclosure Stmt 0 0 Other $15,712 Fees & Expenses of Experts Fees Travel Accommodations Other Expenses Total Consulting Expert E--August Consulting Expert I--August Total $118, $0.00 $0.00 $0.00 $118,386.00

15 SCHACHTER HARRIS L.L.P. Case Doc Trial Counsel Filed 08/13/15 Entered 08/13/15 09:47:22 Desc 220 Canal Exhibits Centre A - E Page 5 of East Las Colinas Blvd. Irving, TX (214) Fax (214) TAX ID# Page: 1 Garlock 09/22/2014 Garrison Litigation Mgt Group, LTD ACCOUNT NO: O c/o Paul Grant STATEMENT NO: West Commercial St., Ste 3050 East Rochester NY Bankruptcy--Litigation HOURS 08/01/14 CS LITIGATION: Review Dexter Holding LITIGATION: Review third party documents regarding estimation proceedings LITIGATION: Review third party documents regarding estimation proceedings /06/14 MH LITIGATION: Update summary of data regarding estimation issues LITIGATION: Research estimation issues /07/14 MH LITIGATION: Update summary of data regarding estimation issues LITIGATION: Review third party documents regarding bankruptcy LITIGATION: Research estimation issues /08/14 MH LITIGATION: Research trial transcripts for Fay and Colwell LITIGATION: Research estimation issues /11/14 MH CS LITIGATION: Review materials and prepare deposition transcripts for review by consulting expert LITIGATION: Draft correspondence and planning regarding consulting expert preparation for estimation hearing LITIGATION: Review information from consulting expert and research issues raised LITIGATION: Review information from co-counsel regarding Dexter appeal LITIGATION: Draft correspondence to Magee regarding preparation for estimation hearing LITIGATION: Review third party documents regarding bankruptcy /12/14 LITIGATION: Prepare for and attend

16 Page: 2 Garlock Case Doc Filed 08/13/15 Entered 09/22/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 6 of 104 STATEMENT NO: 52 Bankruptcy--Litigation 08/13/14 MH HOURS telephone conference with Magee and others regarding Dexter appeal LITIGATION: Research estimation issues /14/14 MH MH 08/15/14 08/18/14 MH 08/19/14 LITIGATION: Communications with co-counsel regarding materials needed for expert review LITIGATION: Research regarding preparation for confirmation hearing LITIGATION: Review third party documents regarding bankruptcy LITIGATION: Review third-party documents regarding bankruptcy LITIGATION: Prepare materials for review by consulting expert LITIGATION: Communications with expert regarding materials for review in preparation for confirmation hearing LITIGATION: Review third party documents regarding estimation LITIGATION: Update summary of data regarding estimation issues LITIGATION: Review third party documents regarding estimation LITIGATION: Research regarding estimation issues , /20/14 CS LITIGATION: Prepare for meeting with consulting expert LITIGATION: Prepare for meeting with consulting expert LITIGATION: Research estimation issues /21/14 CS LITIGATION: Prepare for and attend meeting with consulting expert , CS LITIGATION: Review issues regarding meeting with consulting expert LITIGATION: Prepare for and attend meeting with consulting expert , LITIGATION: Respond to inquiry from Niven LITIGATION: Review third party documents regarding bankruptcy /22/14 LITIGATION: Attend hearing on ACC emergency motion LITIGATION: Research regarding medical issues LITIGATION: Review third party documents

17 Page: 3 Garlock Case Doc Filed 08/13/15 Entered 09/22/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 7 of 104 STATEMENT NO: 52 Bankruptcy--Litigation HOURS regarding estimation proceedings /25/14 LITIGATION: Review third party documents regarding estimation proceedings LITIGATION: Research estimation issues /26/14 08/27/14 08/28/14 MH 08/29/14 MH MH LITIGATION: Research regarding estimation issues LITIGATION: Review third party documents regarding bankruptcy LITIGATION: Review third party documents regarding bankruptcy LITIGATION: Update summary of data regarding estimation issues LITIGATION: Update summary of data regarding estimation issues LITIGATION: Review third party materials regarding bankruptcy LITIGATION: Review notices of deadlines for filing proofs of claim in EFHC bankruptcy FOR CURRENT SERVICES RENDERED , RECAPITULATION TIMEKEEPER HOURS HOURLY RATE TOTAL Cary Schachter $ $3, Mary Horsechief , Ray Harris , Erin Therrian Karina Robledo , /31/14 Machine Copywork TOTAL EXPENSES /22/14 Statement from Fed Ex for delivery service /12/14 Statement from Level 3 for telephone conference fee /21/14 Payment to Ray Harris for parking, meal, hotel and airfare to attend meeting with consulting expert 1, /21/14 Payment to Cary Schachter for parking, car rental, hotel and airfare to attend meeting with consulting expert 2, /26/14 Statement from Iron Mountain for records management 2,095.01

18 Page: 4 Garlock Case Doc Filed 08/13/15 Entered 09/22/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 8 of 104 STATEMENT NO: 52 Bankruptcy--Litigation 08/29/14 Statement from consulting expert for professional services 111, /30/14 Statement from consulting expert for professional services 6, TOTAL ADVANCES 124, TOTAL CURRENT WORK 140, BALANCE DUE $140,657.84

19 SCHACHTER HARRIS L.L.P. Case Doc Trial Counsel Filed 08/13/15 Entered 08/13/15 09:47:22 Desc 220 Canal Exhibits Centre A - E Page 9 of East Las Colinas Blvd. Irving, TX (214) Fax (214) TAX ID# Page: 1 Garlock 09/22/2014 Garrison Litigation Mgt Group, LTD ACCOUNT NO: O c/o Paul Grant STATEMENT NO: West Commercial St., Ste 3050 East Rochester NY Bankruptcy--Fee Proceedings 08/26/14 DF HOURS FEE PROCEEDINGS: Review and revise ninth interim fee application FOR CURRENT SERVICES RENDERED RECAPITULATION TIMEKEEPER HOURS HOURLY RATE TOTAL Dena Farnsworth 2.70 $90.00 $ TOTAL CURRENT WORK BALANCE DUE $243.00

20 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 10 of 104 Exhibit A 2

21 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 11 of 104 SCHACHTER HARRIS LLP Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, Texas (214) MONTHLY COMPENSATION STATEMENT TO: FROM: See Notice Parties, attached Schachter Harris, LLP DATE: October 20, 2014 RE: Garlock Sealing Technologies LLC, et.al. Case No (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of September 1, 2014 through September 30, During this period, SH incurred fees of $6, which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $2, for a total of $9, In addition, SH received statements in the amount of $71, for professional services and expenses from consulting experts hired for an estimation hearing. Pursuant to the Order on Debtors Motion for Administrative Order Under 11 U.S.C. 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the Administrative Order ) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $8, calculated as follows: $ 6, x.90 $ 6, , (100% of expenses) $ 8, SH also requests payment of $71, to pay the fees and expenses of the consulting experts. A summary of the fees, costs, and expenses and SH s billing records for the period of September 1, 2014 through September 30, 2014 are attached hereto and incorporated by reference. Cumulative Holdback Analysis: Through September 30, 2014: $32,887.90

22 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 12 of 104 NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. (linda_simpson@ncwba.uscourts.gov) 402 West Trade Street, Suite 200 Charlotte, NC John R. Miller, Jr. (jmiller@rcdlaw.net) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC Trevor W. Swett, Esq. (tws@capdale.com) Rita Tobin (rct@capdale.com; eb@capdale.com) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C Travis W. Moon, Esq. (tmoon@lawhms.com) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC Deborah L. Fletcher, Esq. (fletcher@fsblegal.com) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC C. Edward Dobbs(edobbs@phrd.com) Parker Hudson Rainer & Dobbs, L.L.P Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203

23 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 13 of 104 Schachter Harris, LLP Summary of Fees, Costs, and Expenses September 1, 2014 through September 30, 2014 Fees Name Hours Rate Amount Cary Schachter (Partner) 0.3 $ Ray Harris (Partner) 4.4 $280 1,232 Laurie Fay (Partner) 0 $210 0 Susan Ashmore (Of Counsel) 0 $200 0 Erin Therrian (Associate) 1 $ Katrina Colwell (Associate) 0 $160 0 Mary Horsechief (Legal Assistant) 10.1 $ Dena Farnsworth (Legal Assistant) 0 $90 0 Karina Robledo (Legal Assistant) 51.2 $90 4, $6,999 Costs & Expenses Amount In-house Copying (.10 per page) Postage and Delivery Service 0.00 Purchasing Third Party Research 0.00 Record Retrieval & Storage 2, Telephone Conference Fees 0.00 Travel Expenses for Cary Schachter Travel Expenses for Ray Harris 0.00 $2, Categories Hours Amount Asset Transactions 0 0 Case Admin. Business Op. 0 0 Claims Admin. 0 0 Fee Proceedings Financing/Relief from Stay Proceedings 0 0 Litigation 65 6,819 Plan/Disclosure Stmt 0 0 Other $6,999 Fees & Expenses of Experts Fees Travel Accommodations Other Expenses Total Consulting Expert E--September Consulting Expert I--September Total $71, $0.00 $0.00 $0.00 $71,580.50

24 SCHACHTER HARRIS L.L.P. Case Doc Trial Counsel Filed 08/13/15 Entered 08/13/15 09:47:22 Desc 220 Canal Exhibits Centre A - E Page 14 of East Las Colinas Blvd. Irving, TX (214) Fax (214) TAX ID# Page: 1 Garlock 10/20/2014 Garrison Litigation Mgt Group, LTD ACCOUNT NO: O c/o Paul Grant STATEMENT NO: West Commercial St., Ste 3050 East Rochester NY Bankruptcy--Litigation HOURS 09/02/14 MH LITIGATION: Update summary regarding other cancer issues LITIGATION: Respond to inquiry from Worf regarding motion to seal LITIGATION: Research recent case law developments in non-mesothelioma claims LITIGATION: Research estimation issues /03/14 MH LITIGATION: Update summary regarding other cancer issues LITIGATION: Research estimation issues /04/14 MH LITIGATION: Review correspondence regarding Garlock co-defendants LITIGATION: Review request for information from Senn and plan response LITIGATION: Research regarding master list of co-defendants LITIGATION: Research notice issues /05/14 MH LITIGATION: Prepare references to reports to send to consulting expert LITIGATION: Research notice issues /06/14 09/08/14 MH LITIGATION: Review consulting expert materials LITIGATION: Update summary regarding other cancers issues LITIGATION: Review third party documents regarding bankruptcy LITIGATION: Research regarding debtor's information brief /09/14 LITIGATION: Research notice issues /10/14 LITIGATION: Review third party documents regarding bankruptcy

25 Page: 2 Garlock Case Doc Filed 08/13/15 Entered 10/20/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 15 of 104 STATEMENT NO: 53 Bankruptcy--Litigation HOURS 09/11/14 LITIGATION: Research estimation issues /16/14 CS LITIGATION: Draft correspondence regarding recent case law CS LITIGATION: Review case law LITIGATION: Prepare for and attend telephone conference with counsel regarding preparation for confirmation hearing LITIGATION: Review materials from co-counsel LITIGATION: Review third party documents regarding bankruptcy /17/14 LITIGATION: Analyze recent case law LITIGATION: Research estimation issues LITIGATION: Prepare master service list of co-defendants LITIGATION: Prepare master service list of co-defendants LITIGATION: Review third party documents regarding bankruptcy /18/14 LITIGATION: Prepare master service list of co-defendants /19/14 LITIGATION: Research estimation issues LITIGATION: Review third party documents regarding bankruptcy /22/14 09/23/14 MH LITIGATION: Prepare master service list of co-defendants LITIGATION: Research regarding estimation trial exhibits /25/14 LITIGATION: Revise list of co-defendants LITIGATION: Prepare master service list of co-defendants LITIGATION: Prepare master service list of co-defendants LITIGATION: Research estimation issues /26/14 09/29/14 LITIGATION: Research materials regarding various co-defendants LITIGATION: Research materials regarding various co-defendants LITIGATION: Research materials regarding various co-defendants

26 Page: 3 Garlock Case Doc Filed 08/13/15 Entered 10/20/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 16 of 104 STATEMENT NO: 53 Bankruptcy--Litigation HOURS LITIGATION: Research materials regarding various co-defendants /30/14 MH LITIGATION: Update summary regarding other cancers LITIGATION: Telephone conference with co-counsel regarding document collection request FOR CURRENT SERVICES RENDERED , RECAPITULATION TIMEKEEPER HOURS HOURLY RATE TOTAL Cary Schachter 0.30 $ $90.00 Mary Horsechief Ray Harris , Erin Therrian Karina Robledo , /30/14 Machine Copywork TOTAL EXPENSES /21/14 Payment to Cary Schachter for meal for Schachter and others while attending meeting with consulting expert /29/14 Statement from consulting expert for professional services 11, /30/14 Statement from consulting expert for professional services 60, /30/14 Statement from Iron Mountain for records management 2, TOTAL ADVANCES 73, TOTAL CURRENT WORK 80, BALANCE DUE $80,830.10

27 SCHACHTER HARRIS L.L.P. Case Doc Trial Counsel Filed 08/13/15 Entered 08/13/15 09:47:22 Desc 220 Canal Exhibits Centre A - E Page 17 of East Las Colinas Blvd. Irving, TX (214) Fax (214) TAX ID# Page: 1 Garlock 10/20/2014 Garrison Litigation Mgt Group, LTD ACCOUNT NO: O c/o Paul Grant STATEMENT NO: West Commercial St., Ste 3050 East Rochester NY Bankruptcy--Fee Proceedings 09/16/14 MH MH 09/17/14 MH HOURS FEE PROCEEDINGS: Review Schachter Harris fee analysis for June and July FEE PROCEEDINGS: Prepare chart regarding Schachter Harris fee analysis for June and July FEE PROCEEDINGS: Research questions regarding fee analyses for June and July FOR CURRENT SERVICES RENDERED RECAPITULATION TIMEKEEPER HOURS HOURLY RATE TOTAL Mary Horsechief 2.00 $90.00 $ TOTAL CURRENT WORK BALANCE DUE $180.00

28 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 18 of 104 Exhibit A 3

29 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 19 of 104 SCHACHTER HARRIS LLP Trial Counsel 220 Canal Centre 400 East Las Colinas Blvd. Irving, Texas (214) MONTHLY COMPENSATION STATEMENT TO: FROM: See Notice Parties, attached Schachter Harris, LLP DATE: November 20, 2014 RE: Garlock Sealing Technologies LLC, et.al. Case No (Jointly Administered) United States Bankruptcy Court Western District of North Carolina, Charlotte Division Schachter Harris LLP ("SH") submits this Monthly Compensation Statement for compensation and reimbursement as Special Asbestos Defense Counsel for Garlock Sealing Technologies LLC, et.al. (the "Debtors"), for the period of October 1, 2014 through October 31, During this period, SH incurred fees of $17, which amount is billed at its usual and customary hourly rates (subject to any agreed special reduced rates for this engagement) and costs and expenses of $2, for a total of $20, In addition, SH received statements in the amount of $101, for professional services and expenses from consulting experts hired for an estimation hearing. Pursuant to the Order on Debtors Motion for Administrative Order Under 11 U.S.C. 105(a) and 331 Establishing Procedures for Interim Compensation and reimbursement of Expenses for Professionals (the Administrative Order ) entered on July 15, 2010 in these cases, retained professionals may request ninety (90%) percent of their fees and one hundred (100%) of their expenses at this time. Accordingly, SH requests payment from the Debtor of $18, calculated as follows: $ 17, x.90 $ 16, , (100% of expenses) $ 18, SH also requests payment of $101, to pay the fees and expenses of the consulting experts. A summary of the fees, costs, and expenses and SH s billing records for the period of October 1, 2014 through October 31, 2014 are attached hereto and incorporated by reference. Cumulative Holdback Analysis: Through October 31, 2014: $34,675.60

30 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 20 of 104 NOTICE PARTIES U.S. Bankruptcy Administrator Attn: Linda W. Simpson, Esq. (linda_simpson@ncwba.uscourts.gov) 402 West Trade Street, Suite 200 Charlotte, NC John R. Miller, Jr. (jmiller@rcdlaw.net) Rayburn Cooper & Durham, P.A. 227 West Trade Street, Suite 1200 Charlotte, NC Trevor W. Swett, Esq. (tws@capdale.com) Rita Tobin (rct@capdale.com; eb@capdale.com) Caplin&Drysdale, Chartered One Thomas Circle, N.W., Suite 1100 Washington, D.C Travis W. Moon, Esq. (tmoon@lawhms.com) Hamilton Moon Stephens Steele & Martin, PLLC 201 South College Street, Suite 2020 Charlotte, NC Deborah L. Fletcher, Esq. (fletcher@fsblegal.com) FSB FisherBroyles, LLP 6000 Fairview Road, Suite 1200 Charlotte, NC C. Edward Dobbs(edobbs@phrd.com) Parker Hudson Rainer & Dobbs, L.L.P Marquis Two Tower 285 Peachtree Center Avenue, N.E. Atlanta, GA 30203

31 Case Doc Filed 08/13/15 Entered 08/13/15 09:47:22 Desc Exhibits A - E Page 21 of 104 Schachter Harris, LLP Summary of Fees, Costs, and Expenses October 1, 2014 through October 31, 2014 Fees Name Hours Rate Amount Cary Schachter (Partner) 0.3 $ Ray Harris (Partner) 2.4 $ Laurie Fay (Partner) 0 $210 0 Susan Ashmore (Of Counsel) 0 $200 0 Erin Therrian (Associate) 18.3 $160 2,928 Katrina Colwell (Associate) 22.8 $160 3,648 Mary Horsechief (Legal Assistant) 29.4 $90 2,646 Dena Farnsworth (Legal Assistant) 10.7 $ Karina Robledo (Legal Assistant) 77 $90 6, $17,877 Costs & Expenses Amount In-house Copying (.10 per page) 0.00 Postage and Delivery Service 0.00 Purchasing Third Party Research 0.00 Record Retrieval & Storage 2, Telephone Conference Fees 0.00 Travel Expenses for Cary Schachter 0.00 Travel Expenses for Ray Harris 0.00 $2, Categories Hours Amount Asset Transactions 0 0 Case Admin. Business Op. 0 0 Claims Admin. 0 0 Fee Proceedings 0 0 Financing/Relief from Stay Proceedings 0 0 Litigation ,877 Plan/Disclosure Stmt 0 0 Other $17,877 Fees & Expenses of Experts Fees Travel Accommodations Other Expenses Total Consulting Expert A--September Consulting Expert E--October Consulting Expert I--October Total $100, $0.00 $0.00 $1, $101,835.00

32 SCHACHTER HARRIS L.L.P. Case Doc Trial Counsel Filed 08/13/15 Entered 08/13/15 09:47:22 Desc 220 Canal Exhibits Centre A - E Page 22 of East Las Colinas Blvd. Irving, TX (214) Fax (214) TAX ID# Page: 1 Garlock 11/20/2014 Garrison Litigation Mgt Group, LTD ACCOUNT NO: O c/o Paul Grant STATEMENT NO: West Commercial St., Ste 3050 East Rochester NY Bankruptcy--Litigation 10/01/14 10/02/14 MH CS 10/03/14 10/06/14 10/07/14 MH HOURS LITIGATION: Review third party materials regarding estimation issues LITIGATION: Review correspondence regarding discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review correspondence regarding case review project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review recent case law; review documents regarding disclosure statement hearing LITIGATION: Review third party documents regarding estimation issues LITIGATION: Review various case files for Garlock discovery project LITIGATION: Update chart regarding cohort comparison LITIGATION: Exchange correspondence with Cassada regarding discovery LITIGATION: Research regarding recent WDNC opinion LITIGATION: Review expert deposition from local counsel LITIGATION: Review recent case law "narrowing" the estimation decision; draft memorandum to co-counsel LITIGATION: Review third-party documents regarding estimation LITIGATION: Review various case files for Garlock discovery project /08/14 LITIGATION: Review third-party documents regarding estimation LITIGATION: Communications with Sarah,

33 Page: 2 Garlock Case Doc Filed 08/13/15 Entered 11/20/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 23 of 104 STATEMENT NO: 54 Bankruptcy--Litigation HOURS judicial assistant regarding fee examiner's hearing LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project /09/14 KLC LITIGATION: Work on discovery project LITIGATION: Review various case files for Garlock discovery project /13/14 10/14/14 LITIGATION: Review new scientific literature for estimation LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project /15/14 LITIGATION: Review various case files for Garlock discovery project KLC LITIGATION: Work on discovery project /16/14 LITIGATION: Review correspondence regarding bankruptcy hearing LITIGATION: Review various case files for Garlock discovery project KLC LITIGATION: Work on discovery project LITIGATION: Review materials for discovery project /20/14 10/21/14 10/22/14 LITIGATION: Exchange correspondence with consulting expert regarding assignment LITIGATION: Review recent case law in preparation for non-mesothelioma estimation LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for discovery project

34 Page: 3 Garlock Case Doc Filed 08/13/15 Entered 11/20/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 24 of 104 STATEMENT NO: 54 Bankruptcy--Litigation 10/23/14 10/24/14 MH MH 10/27/14 MH MH MH MH MH MH 10/28/14 MH HOURS LITIGATION: Review various case files for Garlock discovery project LITIGATION: Communications with consulting expert regarding preparation for confirmation hearing LITIGATION: Research additional materials for expert review in preparation for confirmation hearing LITIGATION: Review materials for expert review in preparation for confirmation hearing LITIGATION: Communications with co-counsel regarding materials for expert review in preparation for confirmation hearing LITIGATION: Communications with co-counsel regarding materials for review by consulting expert LITIGATION: Communications with consulting expert regarding materials for review in preparation for confirmation hearing LITIGATION: Communications with co-counsel regarding materials for expert review in preparation for confirmation hearing LITIGATION: Communications with consulting exeprt regarding additional materials for review in preparation for confirmation hearing LITIGATION: Review third party documents regarding estimation LITIGATION: Review various case files for Garlock discovery project LITIGATION: Research additional materials for expert review in preparation for confirmation hearing MH LITIGATION: Update research with new data MH LITIGATION: Review additional materials for expert review in preparation for confirmation hearing MH LITIGATION: Communications with consulting expert regarding additional materials for review in preparation for confirmation hearing LITIGATION: Coordinate discovery project LITIGATION: Review various case files for Garlock discovery project /29/14 LITIGATION: Coordinate discovery project MH LITIGATION: Review correspondence regarding multiple cases in response to

35 Page: 4 Garlock Case Doc Filed 08/13/15 Entered 11/20/ /13/15 09:47:22 Desc ACCOUNT NO: O Exhibits A - E Page 25 of 104 STATEMENT NO: 54 Bankruptcy--Litigation HOURS discovery project LITIGATION: Review various case files for Garlock discovery project LITIGATION: Review various case files for Garlock discovery project /30/14 MH MH MH DF 10/31/14 LITIGATION: Coordinate and work on discovery project LITIGATION: Review case files and prepare documents in response to project LITIGATION: Review case file for documents in response to project LITIGATION: Review case file for documents in response to project LITIGATION: Review correspondence regarding various plaintiffs for project KLC LITIGATION: Attend meeting with co-counsel to review strategy for discovery project KLC LITIGATION: Review requested document production for discovery project , MH MH DF DF LITIGATION: Coordinate and work on discovery project , LITIGATION: Review case file for documents in response to project LITIGATION: Review case files for documents related to various matter in response to project LITIGATION: Review correspondence regarding various plaintiffs for project LITIGATION: Review case materials for various plaintiffs for project KLC LITIGATION: Review requested document production for discovery project , FOR CURRENT SERVICES RENDERED , RECAPITULATION TIMEKEEPER HOURS HOURLY RATE TOTAL Cary Schachter 0.30 $ $90.00 Mary Horsechief , Ray Harris Katrina L. Colwell , Erin Therrian , Karina Robledo , Dena Farnsworth /30/14 Statement from consulting expert for professional services 21, /25/14 Statement from consulting expert for professional services 9, /31/14 Statement from Iron Mountain for records management 2, /31/14 Statement from consulting expert for professional