Case CSS Doc 741 Filed 01/13/17 Page 1 of 14. Chapter 11

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1 Case CSS Doc 741 Filed 01/13/17 Page 1 of 14 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: MAXUS ENERGY CORPORATION, et al., 1 Debtors. Chapter 11 Case No: (CSS) (Jointly Administered) Objection Deadline: February 3, 2017 at 4:00 p.m. (ET) SECOND CONSOLIDATED MONTHLY APPLICATION OF BDO USA, LLP, AS TAX SERVICES PROVIDER TO THE DEBTORS FOR INTERIM COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD SEPTEMBER 1, 2016 THROUGH NOVEMBER 30, 2016 Name of Applicant: Authorized To Provide Professional Services to: BDO USA, LLP Debtors Date of Retention: Order Entered September 2, 2016, Effective as of June 24, 2016 Period for which Compensation and Reimbursement is Sought: September 1, 2016 November 30, 2016 Amount of Compensation Sought as actual, reasonable and necessary: $69, (80% = $55,503.20) Amount of Expense Reimbursement sought as actual, reasonable and necessary: $0.00 This is a: X monthly interim final application 1 The Debtors in the above-captioned chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: Maxus Energy Corporation (1531), Tierra Solutions, Inc. (0498), Maxus International Energy Company (7260), Maxus (U.S.) Exploration Company (2439), and Gateway Coal Company (7425). The address of each of the Debtors is Richmond Avenue, Suite 1050, Houston, Texas

2 Case CSS Doc 741 Filed 01/13/17 Page 2 of 14 If this is not the first application filed, disclose the following for each prior application: None Requested Approved/Paid # Date Filed Period Covered Fees Expenses Fees Expense 1 10/14/16 06/24/16 08/31/16 $5, $4, TOTAL $5, $4, HOURS BY PROFESSIONAL 2 WITH BLENDED RATE Discounted Hourly Rate Amount Billed Professional Position Hours Lun, Ching Partner , McCullough, Steve Partner , Dabrowska, Anita Managing Director , Huynh, Rose Managing Director , Lowry, Jamie Senior Manager Ainsworth, Kevin Senior Manager , Vanderhoop, Naushon Manager , Mantey, Jessica Senior Khan, Adnan Associate SUBTOTAL , Flat Fee services 29, TOTAL $69, Blended Rate: $ (excludes hours related to Flat Fees) HOURS BY PROJECT CATEGORY CODE PROJECT CATEGORY Flat Fee 3 Hours Amount Billed Maxus Energy Corporation A1 Proforma U.S. Corporation Income Tax Return, $ 10, , Form 1120 A2 New Jersey Corporation Business Tax Return, $ 1, , Form CBT-100 A3 Texas Combined Franchise Tax Report, Forms $ 2, , , and A4 Oklahoma Corporation Income Tax Return, $ 1, , Form 512 A5 Oklahoma Annual Franchise Tax Return, Form 200 $ 1, , Hours billed by professional include time incurred related to Flat Fee services that will be billed upon completion of work; the amount billed includes only Additional Services (defined herein) that are being billed on an hourly basis. 3 Flat Fees will be billed upon completion of the related work. Hours incurred are included for the time period of this Application but billing will be deferred until work is completed. -2-

3 Case CSS Doc 741 Filed 01/13/17 Page 3 of 14 CODE PROJECT CATEGORY Flat Fee 3 Hours Amount Billed A6 Additional Services (Hourly) 4.0 2, Tierra Solutions, Inc. B1 Proforma U.S. Corporation Income Tax Return, $ 3, , Form 1120 B2 New Jersey Corporation Business Tax Return, $ 1, , Form CBT-100 B3 Additional Services (Hourly) , Maxus International Energy Company C1 Proforma U.S. Corporation Income Tax Return, $ 2, , Form 1120 C2 Additional Services (Hourly) - - Maxus (U.S.) Exploration Company D1 Proforma U.S. Corporation Income Tax Return, $ 3, , Form 1120 D2 Louisiana Corporation Income and Franchise $ 1, , Tax, Form CI FT-620 D3 Additional Services (Hourly) - - Gateway Coal Company - E1 Proforma U.S. Corporation Income Tax Return, $ 3, , Form 1120 E2 Pennsylvania Corporate Tax Report, Form RCT- $ 1, , E3 Additional Services (Hourly) - - Fee Applications F1 Fee Applications , TOTAL: $69, EXPENSE SUMMARY Expense Category Total Expenses Travel Lodging Meals Local Meals Local Travel Miscellaneous Outside Services TOTAL $

4 Case CSS Doc 741 Filed 01/13/17 Page 4 of 14 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: MAXUS ENERGY CORPORATION, et al., 1 Debtors. Chapter 11 Case No: (CSS) (Jointly Administered) Objection Deadline: February 3, 2017 at 4:00 p.m. (ET) SECOND CONSOLIDATED MONTHLY APPLICATION OF BDO USA, LLP, AS TAX SERVICES PROVIDER TO THE DEBTORS FOR INTERIM COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD SEPTEMBER 1, 2016 THROUGH NOVEMBER 30, 2016 TO THE HONORABLE CHRISTOPHER S. SONTCHI, UNITED STATES BANKRUPTCY JUDGE: BDO USA, LLP (together with its wholly owned subsidiaries, agents, independent contractors and employees, BDO ) hereby submits its Second Consolidated Monthly Application (the Application ) for Approval of Interim Compensation and Reimbursement of Expenses as Tax Services Provider to the above-captioned debtors and debtors in possession (collectively, the Debtors ) for the period September 1, 2016 through November 30, 2016 (the Application Period ). BDO respectfully represents: I. INTRODUCTORY STATEMENT 1. BDO specializes in accounting, auditing, tax, and consulting services. BDO s debtor advisory services have included a wide range of activities targeted at stabilizing and improving a company s financial position, including providing assistance in developing, 1 The Debtors in the above-captioned chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: Maxus Energy Corporation (1531), Tierra Solutions, Inc. (0498), Maxus International Energy Company (7260), Maxus (U.S.) Exploration Company (2439), and Gateway Coal Company (7425). The address of each of the Debtors is Richmond Avenue, Suite 1050, Houston, Texas

5 Case CSS Doc 741 Filed 01/13/17 Page 5 of 14 analyzing, evaluating, negotiating, and confirming bankruptcy plans of reorganization, as well as providing technical accounting impacted by bankruptcy matters. 2. Moreover, BDO is a leading full-service accounting, tax, and business advisory firm with over 64 offices and more than 4,000 partners and professional staff in the United States. BDO is a United States firm of a global network of separate, independent member firms that operate in 154 countries and over 1,400 offices throughout the world. BDO has considerable experience providing accounting, tax, auditing, and financial advisory services to businesses in a chapter 11 environment, and has been employed in numerous cases under the Bankruptcy Code. 3. On June 17, 2016 (the Petition Date ), each of the Debtors filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their business and manage their properties as debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. The Debtors chapter 11 cases are being jointly administered pursuant to Bankruptcy Rule 1015(b). On July 7, 2016, the Office of the United States Trustee for the District of Delaware (the U.S. Trustee ) appointed an official committee of unsecured creditors pursuant to section 1102 of the Bankruptcy Code (the Committee ). No party has requested the appointment of a trustee or examiner in these chapter 11 cases. 4. A detailed description of the Debtors and their business is set forth in the Declaration of Javier J. González in Support of Chapter 11 Petitions and Requests for First Day Relief filed on June 18, 2016 [Docket No. 2]. 5. On August 17, 2016, the Debtors filed the Debtors Application an Order Authorizing the Debtors to Retain and Employ BDO USA, LLP as Tax Services Provider Effective as of June 24, 2016 (the Retention Application ) [Docket No. 249]. On September 2, 2016, an order, effective as of June 24, 2016, was duly signed and subsequently entered by this Court -2-

6 Case CSS Doc 741 Filed 01/13/17 Page 6 of 14 authorizing the retention of BDO (the Retention Order ) [Docket No. 324] as their primary Tax Services Provider in accordance with the terms of the engagement letters between the respective Debtors and BDO USA, dated August 9, 2016 (collectively, the Engagement Letters ), copies of which are attached as Exhibits B1 through B5 to the Retention Application. 6. Pursuant to the terms of the Engagement Letters, the Debtors retained BDO to render certain tax services during these chapter 11 cases. BDO will provide the following services: (i) (ii) Preparing the 2015 tax returns for the entities listed in the Engagement Letters; and Providing any additional tax services for the Debtors pursuant to an addendum to an Engagement Letter. 7. This is BDO s Second Consolidated Monthly application for compensation for professional services rendered and for reimbursement of actual and necessary costs and expenses incurred on behalf of the Debtors. BDO makes this Application pursuant to sections 328(a), 330 and 1103(a) of the Bankruptcy Code, Rules 2014(a) and 2016(b) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ), Rule of the Local Rules of the United States Bankruptcy Court for the District of Delaware (the Local Rules ), and the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of Professionals entered on July 11, 2016 (the Interim Compensation Procedures ) [Docket No. 126], it s Retention Order and any additional orders entered by the Court. 8. Detailed statements itemizing the services rendered and expenses incurred by BDO are annexed hereto as Exhibits A through C and incorporated herein by reference. II. SUMMARY OF SERVICES RENDERED 9. By this Application, BDO seeks interim allowance for (a) compensation for services rendered from September 1, 2016 through November 30, 2016 (the Application Period ) -3-

7 Case CSS Doc 741 Filed 01/13/17 Page 7 of 14 in the total amount of $69,379.00, and (b) reimbursement for certain expenses incurred during the same period in the amount of $0.00, all as more fully set forth in the Application. Pursuant to the Interim Compensation Procedures, if no objections are filed in response to this Application before the objection deadline, the Debtors are authorized to pay BDO 80% of requested fees (80% = $55,503.20) and 100% of requested expenses ($0.00) after a certificate of no objection is filed with the Court. Except to the extent modified pursuant to the Retention Order, this Application complies with the Bankruptcy Code, the Bankruptcy Rules, the Local Rules and the Interim Compensation Procedures. 10. During the Application Period, BDO provided services of a general nature to the Debtors, as set forth below: CODE PROJECT CATEGORY Flat Fee Hours Amount Billed Maxus Energy Corporation A1 Proforma U.S. Corporation Income Tax Return, 10, , Form 1120 A2 New Jersey Corporation Business Tax Return, 1, , Form CBT-100 A3 Texas Combined Franchise Tax Report, Forms 2, , , and A4 Oklahoma Corporation Income Tax Return, 1, , Form 512 A5 Oklahoma Annual Franchise Tax Return, Form 1, , A6 Additional Services (Hourly): 4.0 2, General time for bankruptcy discussions with the engagement team and the attorneys. Tierra Solutions, Inc. B1 Proforma U.S. Corporation Income Tax Return, 3, , Form 1120 B2 New Jersey Corporation Business Tax Return, 1, , Form CBT-100 B3 Additional Services (Hourly): Work done researching the stock basis for Tierra Solutions ,

8 Case CSS Doc 741 Filed 01/13/17 Page 8 of 14 CODE PROJECT CATEGORY Flat Fee Hours Amount Billed Maxus International Energy Company C1 Proforma U.S. Corporation Income Tax Return, 2, , Form 1120 C2 Additional Services (Hourly) - - Maxus (U.S.) Exploration Company D1 Proforma U.S. Corporation Income Tax Return, 3, , Form 1120 D2 Louisiana Corporation Income and Franchise 1, , Tax, Form CI FT-620 D3 Additional Services (Hourly) - - Gateway Coal Company E1 Proforma U.S. Corporation Income Tax Return, 3, , Form 1120 E2 Pennsylvania Corporate Tax Report, Form RCT- 1, , E3 Additional Services (Hourly) - - F1 Fee Applications Fee Applications (Hourly) Preparation of fee applications. Preparation and review of monthly data, for submission to debtors , TOTAL: $29, $69, III. COMPENSATION STANDARDS 11. Pursuant to the Retention Order, BDO was retained pursuant to sections 327(a) and 328 of the Bankruptcy Code, and is required to file fee applications with the Court. Pursuant to the Retention Order, BDO s fees and expenses are subject to the standard of review set forth in section 328 of the Bankruptcy Code; provided, however, that the United States Trustee is entitled to review BDO s fees and expenses pursuant to the standards set forth in sections 330 and 331 of the Bankruptcy Code. 12. Section 328 of the Bankruptcy Code permits a professional to be retained on a fixed fee basis, but provides that this Court may allow compensation different from the compensation -5-

9 Case CSS Doc 741 Filed 01/13/17 Page 9 of 14 provided under such retention after the conclusion of such employment, if such terms and conditions prove to have been improvident in light of developments not capable of being anticipated at the time of the retention. Section 330(a)(3) of the Bankruptcy Code identifies factors that should be considered when determining the amount of reasonable compensation. These factors are: A. the time spent on such services; B. the rates charged for such services; C. whether the services were necessary to the administration of, or beneficial at the time at which the service was rendered toward the completion of, a case under this title; D. whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed; E. with respect to a professional person, whether the person is board certified or otherwise has demonstrated skill and experience in the bankruptcy field; and F. whether the compensation is reasonable based on customary compensation charged by comparably skilled practitioner in cases other than cases under this title. A. Improvident Standard 13. Certain of the services provided by BDO during this Application Period relate to the Flat Fee (as defined below). BDO is not aware of any developments in the Debtors chapter 11 cases which were not capable of being known at time the Retention Order was entered. B. Time Spent 14. The size and complexity of these chapter 11 cases as well as the numerous and complex issues that BDO addressed required substantial broad-based accounting and financial advisory expertise. As a consequence, the demands of these chapter 11 cases have been such that BDO s highly skilled professionals have devoted substantial time and effort to perform properly and expeditiously the required accounting, audit and advisory work. -6-

10 Case CSS Doc 741 Filed 01/13/17 Page 10 of During the Application Period, BDO professionals spent hours performing services for the benefit of the Debtors and their estates. 16. BDO s time records are recorded contemporaneously with the rendition of professional services. Exhibit B attached hereto contains a full and complete description of the services rendered by each partner, managing director, director, senior manager, manager, senior, and associate on a daily basis for the Application Period. BDO s time records are maintained in one-tenth of an hour (0.10) increments. C. Rates Charged 17. BDO customarily bills their professionals at rates commensurate with the experience of the person performing such services. The billing rates are the same for bankruptcy engagements as well as all other accounting and advisory work performed by BDO outside of bankruptcy. A detail of each professional s title and hours incurred is included in Exhibit A attached hereto and incorporated herein by reference. 18. In consideration of the services to be provided by BDO, the Debtors have agreed to compensate and reimburse BDO based on a combination of fixed fees and discounted hourly rates, as summarized below. 19. The base fee for tax return preparation services (the Flat Fee ) is $34,000, which includes the preparation of tax returns for the entities listed in the Engagement Letters. If additional tax returns are required, BDO will charge the Debtors an additional $2,500 for each federal proforma 1120 return, $2,000 for each additional unitary state return, and $1,750 for each non-unitary state return. The Debtors understand it is the general practice of providers of tax services to charge a flat fee for the preparation of tax returns. -7-

11 Case CSS Doc 741 Filed 01/13/17 Page 11 of In addition, if additional work is required on BDO s part to accumulate any schedules, information, or calculations to support the information required to be disclosed in the tax returns, additional fees will be charged at discounted hourly rates (the Additional Services ). The Flat Fee does not include services related to responding to notices or inquiries from federal or state taxing authorities, or research time spent related to non-recurring transactions. Reasonable costs and time spent in connection with filing this Application and fee applications with the Court, examinations by taxing authorities, legal matters, or other proceedings related to BDO s engagement, such as subpoenas, testimony, or consultation involving private litigation or arbitration at the Debtors request or by subpoena, are not included in the Flat Fee and also will be billed separately. 21. BDO s current hourly rates range as follows: Title Hourly Rate (Standard) Hourly Rate (Discounted) Partner/Senior Director $550 $650 $440 $520 Senior Manager $425 $525 $340 $420 Manager $325 $375 $260 $300 Senior Associate $225 $275 $180 $220 Associate $185 $225 $148 $ Each duty and task performed by BDO has been performed by the professional most qualified to render such services. 23. BDO s professionals have delegated authority where appropriate to prevent duplication of effort, to ensure that associates were used whenever possible and to utilize the services of professionals who bill at lower hourly rates as much as possible. -8-

12 Case CSS Doc 741 Filed 01/13/17 Page 12 of Where more than one person attended a meeting, such attendance was not a duplication of effort, but was necessary to adequately represent the interests of the Debtors, and to have the appropriate expertise available. D. Beneficial at the Time at Which the Service was Rendered 25. The Services BDO performed were the actual and necessary cost of the administration of the Debtors estates and have enabled these chapter 11 cases to proceed in a timely fashion. E. Performed in a Reasonable Amount of Time and at Reasonable Cost 26. BDO is a nationally recognized accounting, consulting and financial advisory firm and was selected by the Debtors for its ability to provide the required services in a timely fashion and at a reasonable cost. In these chapter 11 cases, the time frames were often short and required substantial effort by BDO professionals to resolve complex issues on an expedited basis. 27. The services in these chapter 11 cases were performed in a reasonable amount of time given the complex nature of the issues. F. BDO s Professionals 28. BDO s professionals have a variety of certifications and have demonstrated outstanding abilities in the accounting, consulting and advisory fields. G. Fees Outside of Bankruptcy 29. BDO charges the same rates both within and outside of the bankruptcy context. BDO s rates are commensurate with other firms of comparable skill. It is the general practice of providers of tax services to charge a flat fee for the preparation of tax returns. For this matter, the -9-

13 Case CSS Doc 741 Filed 01/13/17 Page 13 of 14 Debtors agreed to compensate and reimburse BDO based on a combination of fixed fees and discounted hourly rates, as summarized above. H. Other Compensation Issues 30. Section 330(a)(6) provides Any compensation awarded for the preparation of a fee application shall be based on the level and skill reasonably required to prepare the application. 31. During the Application Period, BDO incurred 18.3 hours and $5, in fees in the preparation of supporting data for this and prior applications. 32. There is no agreement or understanding between BDO and any other person, other than the members, associates and employees of BDO, for the sharing of compensation received for services rendered in connection with these chapter 11 cases. IV. CONCLUSION 33. For all of the reasons set forth in this application, BDO respectfully submits that the services it has rendered and the disbursements it has incurred on behalf of the Debtors during these chapter 11 cases were not improvident and have been reasonably expended in order to adequately represent and protect the interests of the Debtors in these chapter 11 cases. BDO submits further that it has provided such services in an economical and efficient manner. Accordingly, BDO requests that the relief requested in this Application be granted in all respects. -10-

14 Case CSS Doc 741 Filed 01/13/17 Page 14 of 14

15 Case CSS Doc Filed 01/13/17 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) Chapter 11 In re: ) ) Case No (CSS) MAXUS ENERGY CORPORATION, et al., 1 ) ) Jointly Administered Debtors. ) ) Objection Deadline: February 3, 2017 at 4:00 p.m. (ET) NOTICE OF FEE APPLICATION TO: (I) THE DEBTORS; (II) THE U.S. TRUSTEE; (III) COUNSEL TO THE COMMITTEE; AND (IV) YPF S.A. AND YPF HOLDINGS, INC. PLEASE TAKE NOTICE that BDO USA, LLP (the Applicant ) has filed its Second Consolidated Monthly Application of BDO USA, LLP as Tax Services Provider to the Debtors for Interim Compensation for Services Rendered and Reimbursement of Expenses for the Period September 1, 2016 through November 30, 2016 (the Application ) with the Court. The Application seeks allowance of interim fees in the amount of $69, and interim expenses in the amount of $0.00. PLEASE TAKE FURTHER NOTICE that objections to the Application, if any, are required to be filed on or before February 3, 2017 at 4:00 p.m. (ET) (the Objection Deadline ) with the Clerk of the United States Bankruptcy Court for the District of Delaware, 3rd Floor, 824 N. Market Street, Wilmington, Delaware You must also serve any such objection so as to be received by the following on or before the Objection Deadline: (i) the Debtors, Maxus Energy Corporation, Richmond Avenue, Suite 1050, Houston, Texas 77042; Attn: Javier González, Esq.; (ii) counsel to the Debtors, (a) Morrison & Foerster LLP, 250 West 55th Street, New York, New York 10019, Attn: Benjamin W. Butterfield, Esq., and (b) Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington, DE 19801, Attn: M. Blake Cleary, Esq. and Joseph M. Barry, Esq.; (iii) counsel to the Official Committee of Unsecured Creditors, (a) Schulte Roth & Zabel LLP, 919 Third Avenue, New York, New York 10022, Attn: Adam C. Harris, Esq., and (b) Cole Schotz P.C., 500 Delaware Avenue, Suite 1410, Wilmington, DE 19801, Attn: Norman L. Pernick, Esq. and J. Kate Stickles, Esq.; (iv) counsel to YPF S.A. and YPF Holdings, Inc., (a) Chadbourne & Parke LLP, 1301 Avenue of the Americas, New York, New York 10019, Attn: Francisco Vazquez, Esq. and Samuel S. Kohn, Esq., and (b) Landis Rath & Cobb LLP, 919 Market Street, Suite 1800, Wilmington, DE 19801, Attn: Adam G. Landis, Esq.; and (v) the U.S. Trustee, J. Caleb Boggs Building, 844 King Street, Suite 2207, Lockbox 35, Wilmington, Delaware 19801, Attn: Linda J. Casey, Esq. 01: The Debtors in the above-captioned chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: Maxus Energy Corporation (1531), Tierra Solutions, Inc. (0498), Maxus International Energy Company (7260), Maxus (U.S.) Exploration Company (2439), and Gateway Coal Company (7425). The address of each of the Debtors is Richmond Avenue, Suite 1050, Houston, Texas

16 Case CSS Doc Filed 01/13/17 Page 2 of 2 PLEASE TAKE FURTHER NOTICE THAT PURSUANT TO THE ORDER ESTABLISHING PROCEDURES FOR INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES OF PROFESSIONALS [DOCKET NO. 126], IF NO OBJECTIONS ARE FILED AND SERVED IN ACCORDANCE WITH THE ABOVE PROCEDURES, THE DEBTORS WILL BE AUTHORIZED TO PAY 80% OF REQUESTED INTERIM FEES AND 100% OF REQUESTED INTERIM EXPENSES, WITHOUT FURTHER ORDER OF THE COURT. PLEASE TAKE FURTHER NOTICE THAT ONLY IF AN OBJECTION IS PROPERLY AND TIMELY FILED IN ACCORDANCE WITH THE ABOVE PROCEDURES AND CANNOT BE CONSENSUALLY RESOLVED WILL A HEARING BE HELD ON THE APPLICATION. Dated: January 13, 2017 Wilmington, Delaware /s/ Justin P. Duda M. Blake Cleary (No. 3614) Joseph M. Barry (No. 4221) Justin P. Duda (No. 5478) Travis G. Buchanan (No. 5595) YOUNG CONAWAY STARGATT & TAYLOR, LLP Rodney Square 1000 North King Street Wilmington, Delaware Telephone: (302) Facsimile: (302) and- James M. Peck (admitted pro hac vice) Lorenzo Marinuzzi (admitted pro hac vice) Jennifer L. Marines (admitted pro hac vice) Jordan A. Wishnew (admitted pro hac vice) MORRISON & FOERSTER LLP 250 West 55th Street New York, New York Telephone: (212) Facsimile: (212) Counsel for Debtors and Debtors-in-Possession 01:

17 Case CSS Doc Filed 01/13/17 Page 1 of 22 Exhibit A MAXUS ENERGY CORPORATION, et al., Time Summary September 1, 2016 through November 30, 2016 Discounted Hourly Rate Amount Billed Professional Position Hours Lun, Ching Partner , McCullough, Steve Partner , Dabrowska, Anita Managing Director , Huynh, Rose Managing Director , Lowry, Jamie Senior Manager Ainsworth, Kevin Senior Manager , Vanderhoop, Naushon Manager , Mantey, Jessica Senior Khan, Adnan Associate SUBTOTAL $40, Flat Fee services $29, TOTAL $69,

18 Case CSS Doc Filed 01/13/17 Page 2 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A1 Maxus Energy Corporation Proforma U.S. Corporation Income Tax Return, Form 1120 Name Date Description Hours Mantey, Jessica 09/01/16 Performed detailed review of federal tax 0.8 workpapers for Maxus Energy. Huynh, Rose 09/07/16 Performed review federal return for Maxus 0.5 Energy. Mantey, Jessica 09/07/16 Performed detailed review of federal tax 2.0 workpapers for Maxus Energy. Khan, Adnan 09/07/16 Prepared tax return for Maxus Energy. 2.9 Khan, Adnan 09/22/16 Updated tax return workpaper in tax softwares 2.2 for Maxus Energy. Mantey, Jessica 09/26/16 Update tax return for Maxus Energy. 0.5 Lun, Ching 09/27/16 Performed review federal return review and 2.5 provide comments for Maxus Energy. Huynh, Rose 09/28/16 Update tax return for Maxus Energy. 0.5 Mantey, Jessica 09/28/16 Update tax return for Maxus Energy. 2.5 Huynh, Rose 09/29/16 Performed review federal return for Maxus 1.0 Energy. Khan, Adnan 09/29/16 Prepared tax return for Maxus Energy. 2.7 TOTAL 18.1 INDIVIDUAL TOTALS Professional Hours Lun, Ching 2.5 Huynh, Rose 2.0 Mantey, Jessica 5.8 Khan, Adnan 7.8 Total Hours 18.1 Flat Fee services $ 10, TOTAL $ 10,

19 Case CSS Doc Filed 01/13/17 Page 3 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A2 Maxus Energy Corporation New Jersey Corporation Business Tax Return, Form CBT-100 Name Date Description Hours Khan, Adnan 09/21/16 Updated Maxus Energy New Jersey tax return. 1.6 Mantey, Jessica 10/03/16 Performed detail review New Jersey return for 1.1 Maxus Energy. Huynh, Rose 10/05/16 Performed review New Jersey return for Maxus 0.5 Energy. Mantey, Jessica 10/07/16 Cleared points on New Jersey return for Maxus 0.5 Energy. Huynh, Rose 10/07/16 Performed review New Jersey return for Maxus 0.2 Energy. Mantey, Jessica 10/14/16 Processed New Jersey state return and routed 0.4 information for Maxus Energy. Mantey, Jessica 10/17/16 Validated New Jersey tax return e-file submission for Maxus Energy. 0.5 TOTAL 4.8 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 0.7 Mantey, Jessica 2.5 Khan, Adnan 1.6 Total Hours 4.8 Flat Fee services $ 1, TOTAL $ 1,

20 Case CSS Doc Filed 01/13/17 Page 4 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A3 Maxus Energy Corporation Texas Combined Franchise Tax Report, Forms , and Name Date Description Hours Huynh, Rose 09/15/16 Review Texas notice for Maxus Energy. 0.3 Mantey, Jessica 09/29/16 Prepared s to A. Kirchner regarding state 0.1 apportionments for Maxus Energy. Khan, Adnan 10/20/16 Prepared Maxus Energy Texas Combined 6.8 Franchise Tax Reports. Mantey, Jessica 10/24/16 Performed detail review of Maxus Energy Texas 0.9 Combined Franchise Tax Reports. Mantey, Jessica 10/26/16 Performed detail review of Maxus Energy Texas 2.7 Combined Franchise Tax Reports. Huynh, Rose 10/27/16 Performed review of Maxus Energy Texas 1.1 Combined Franchise Tax Reports. Huynh, Rose 10/28/16 Performed review of Maxus Energy Texas 0.6 Combined Franchise Tax Reports. Mantey, Jessica 10/28/16 Updated TX Franchise Tax Return for Review 0.6 Corrections for Maxus Energy. Lowry, Jamie 11/08/16 Reviewed 2016 Texas Franchise tax return. 2.1 Khan, Adnan 11/11/16 Discusses Texas Franchise tax return and 0.4 procedures with J. Lowry. TOTAL 15.6 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 2.0 Lowry, Jamie 2.1 Mantey, Jessica 4.3 Khan, Adnan 7.2 Total Hours 15.6 Flat Fee services $ 2, TOTAL $ 2,

21 Case CSS Doc Filed 01/13/17 Page 5 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A4 Maxus Energy Corporation Oklahoma Corporation Income Tax Return, Form 512 Name Date Description Hours Khan, Adnan 09/06/16 Prepared tax return for Maxus Energy. 2.1 Mantey, Jessica 09/13/16 Performed review of OK corporate income tax 0.4 return for Maxus Energy. Khan, Adnan 09/13/16 Updated tax return workpaper in tax softwares 0.7 for Maxus Energy. Mantey, Jessica 09/14/16 Performed review of OK corporate income tax 0.4 return for Maxus Energy. Huynh, Rose 09/14/16 Performed review of OK corporate income tax 0.7 return for Maxus Energy. Mantey, Jessica 09/15/16 Performed review of OK corporate income tax 0.2 return for Maxus Energy. Huynh, Rose 09/15/16 Provide OK corporate income tax return to 0.3 client for Maxus Energy. TOTAL 4.8 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 1.0 Mantey, Jessica 1.0 Khan, Adnan 2.8 Total Hours 4.8 Flat Fee services $ 1, TOTAL $ 1,

22 Case CSS Doc Filed 01/13/17 Page 6 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A5 Maxus Energy Corporation Oklahoma Annual Franchise Tax Return, Form 200 Name Date Description Hours Khan, Adnan 09/06/16 Prepared tax return for Maxus Energy. 2.1 Mantey, Jessica 09/13/16 Performed review of OK franchise tax return for 0.4 Maxus Energy. Khan, Adnan 09/13/16 Updated tax return workpaper in tax softwares 0.7 for Maxus Energy. Mantey, Jessica 09/14/16 Performed review of OK franchise tax return for 0.4 Maxus Energy. Huynh, Rose 09/14/16 Performed review of OK franchise tax return for 0.7 Maxus Energy. Mantey, Jessica 09/15/16 Performed review of OK franchise tax return for 0.2 Maxus Energy. Huynh, Rose 09/15/16 Provide OK franchise tax return to client for 0.3 Maxus Energy. TOTAL 4.80 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 1.0 Mantey, Jessica 1.0 Khan, Adnan 2.8 Total Hours 4.8 Flat Fee services $ 1, TOTAL $ 1,

23 Case CSS Doc Filed 01/13/17 Page 7 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 A6 Maxus Energy Corporation Additional Services (Hourly) Name Date Description Hours Standard Rate Discounted Rate Amount Lun, Ching 09/16/16 Phone meeting regarding 382(l)(5) and (I)(6) with attorneys. McCullough, Steve 09/21/16 Evaluated potential tax consequences of the , bankruptcy filing, including COD income and tax attribute reduction. Lun, Ching 09/26/16 Phone meeting with S. McCullough and R. Huynh regarding information required to prepare analysis for Morrison & Forrester TOTAL 4.0 2, INDIVIDUAL TOTALS Professional Hours Standard Hourly Rate Discounted Hourly Rate Amount Lun, Ching , McCullough, Steve , TOTAL 4.0 2,

24 Case CSS Doc Filed 01/13/17 Page 8 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 B1 Tierra Solutions, Inc. Proforma U.S. Corporation Income Tax Return, Form 1120 Name Date Description Hours Huynh, Rose 09/05/16 Performed review of federal tax workpapers for 0.3 Tierra Solutions. Khan, Adnan 09/06/16 Updated tax workpapers for Tierra Solutions. 1.8 Huynh, Rose 09/06/16 Performed review of federal tax workpapers for 0.5 Tierra Solutions. Mantey, Jessica 09/06/16 Performed detailed review of federal tax 1.3 workpapers for Tierra Solutions. Huynh, Rose 09/09/16 Performed review of federal tax workpapers for 0.5 Tierra Solutions. Khan, Adnan 09/13/16 Updated tax workpapers for Tierra Solutions. 0.8 Huynh, Rose 09/20/16 Performed review of federal tax return for Tierra 0.3 Solutions. Huynh, Rose 09/22/16 Performed review of fixed asset additions for 0.8 Tierra solution. Khan, Adnan 09/22/16 Updated tax workpapers for Tierra Solutions. 1.6 Huynh, Rose 09/28/16 Performed review of updated tax return for Tierra Solutions. 0.5 TOTAL 8.4 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 2.9 Mantey, Jessica 1.3 Khan, Adnan 4.2 Total Hours 8.4 Flat Fee services $ 3, TOTAL $ 3,

25 Case CSS Doc Filed 01/13/17 Page 9 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 B2 Tierra Solutions, Inc. New Jersey Corporation Business Tax Return, Form CBT-100 Name Date Description Hours Khan, Adnan 09/20/16 Updated tax return workpaper in tax software 1.8 for Tierra Solutions. Khan, Adnan 09/21/16 Updated tax return workpaper in tax software 1.1 for Tierra Solutions. Huynh, Rose 10/04/16 Performed review New Jersey return for Tierra 0.5 Solutions. Mantey, Jessica 10/04/16 Performed detailed review New Jersey return for 1.3 Tierra Solutions. Huynh, Rose 10/05/16 Performed review New Jersey return for Tierra 0.8 Solutions. Huynh, Rose 10/07/16 Performed review New Jersey return for Tierra Solutions. 0.2 TOTAL 5.7 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 1.5 Mantey, Jessica 1.3 Khan, Adnan 2.9 Total Hours 5.7 Flat Fee services $ 1, TOTAL $ 1,

26 Case CSS Doc Filed 01/13/17 Page 10 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 B3 Tierra Solutions, Inc. Additional Services (Hourly) Name Date Description Hours Standard Rate Discounted Rate Amount Huynh, Rose 09/20/16 Meeting to discuss stock basis for Tierra Solutions. Huynh, Rose 09/20/16 Provided stock basis information for Tierra Solution. Lun, Ching 09/20/16 Phone meeting with R. Huynh and S McCullogh to discuss stock basis calculation and entity structure for Tierra Solutions. Lun, Ching 09/22/16 Phone meeting with S. McCullough, R. Huynh, and A. Dabrowska regarding stock basis/contemplated transaction and impact for Tierra Solutions. Huynh, Rose 09/22/16 Meeting regarding stock basis for Tierra Solutions. Huynh, Rose 09/26/16 Meeting with Morrison & Forrester regarding stock basis for Tierra Solutions. Lun, Ching 09/26/16 Meeting with Morrison & Forrester regarding stock basis for Tierra Solutions. Dabrowska, Anita 10/01/16 Reviewed most recent financial statements and , tax returns. Dabrowska, Anita 10/01/16 Read about company background and bankruptcy-related filings. McCullough, Steve 10/01/16 Read financial statements and bankruptcyrelated filings to evaluate what schedules will need to be created. Dabrowska, Anita 10/02/16 Assessed information on tax returns for years , for purposes of evaluating Reg. Sec Dabrowska, Anita 10/02/16 Started NOL allocation schedules and stock , basis computation schedules for Tierra Solutions, Inc. McCullough, Steve 10/03/16 Reviewed the NOL allocation schedules and stock basis computation schedules that Anita Dabrowska setup. Huynh, Rose 10/04/16 Prepared information request regarding stock basis for Tierra Solutions. Dabrowska, Anita 10/04/16 Continued NOL allocation schedules and stock , basis computation schedules. Dabrowska, Anita 10/05/16 Updated the NOL allocation schedule for and 2010, given the IRS adjustment. Lun, Ching 10/11/16 Updated Morrison & Forrester on stock basis & NOL allocation calculation status for Tierra Solutions. Huynh, Rose 10/11/16 Requested information regarding basis adjustments for Tierra Solutions. Huynh, Rose 10/12/16 Received historical tax returns for stock basis computation for Tierra Solutions. Dabrowska, Anita 10/13/16 Evaluated pre-2004 workpapers and tax returns that were provided. Lun, Ching 10/13/16 Updated Morrison & Forrester on stock basis & NOL allocation calculation status for Tierra Solutions. Huynh, Rose 10/13/16 Requested additional historical tax returns for tax basis computation for Tierra Solutions

27 Case CSS Doc Filed 01/13/17 Page 11 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 B3 Tierra Solutions, Inc. Additional Services (Hourly) Name Date Description Hours Standard Rate Discounted Rate Amount Dabrowska, Anita 10/14/16 Started to update NOL allocation schedules and , stock basis computation schedules with the pre information. Huynh, Rose 10/18/16 Requested and saved historical tax returns for stock basis computation for Tierra Solutions Dabrowska, Anita 10/18/16 Continued to update NOL allocation schedules , and stock basis computation schedules with information. Huynh, Rose 10/19/16 Provided tax returns for stock basis adjustment for Tierra Solutions. Dabrowska, Anita 10/20/16 Continued to update NOL allocation schedules , and stock basis computation schedules with information. Dabrowska, Anita 10/21/16 Started evaluation of legal documentation to , understand historic corporate transactions, including liquidations, mergers, acquisitions and dispositions that occurred. Dabrowska, Anita 10/21/16 Finished evaluation of legal documentation to understand historic corporate transactions, including liquidations, mergers, acquisitions and dispositions that occurred. Dabrowska, Anita 10/22/16 Finalized NOL allocation schedules and stock basis computation schedules. Ainsworth, Kevin 10/23/16 Reviewed NOL allocation schedules and stock basis computation schedules. Huynh, Rose 10/24/16 Requested information for stock basis computation for Tierra Solutions. McCullough, Steve 10/24/16 Reviewed NOL allocation schedules, stock basis computation schedules, and Kevin Ainsworth's comments. Dabrowska, Anita 10/25/16 Added list of assumptions to the NOL , allocation schedules and stock basis computation schedules. Mantey, Jessica 10/26/16 Assisted A. Dabrowska with NOL questions for Tierra Solutions. Huynh, Rose 10/26/16 Reviewed 1998 tax return for stock basis calculation for Tierra Solutions. Ainsworth, Kevin 10/28/16 Evaluated list of assumptions that were added McCullough, Steve 10/28/16 Discussed list of assumptions with Kevin Ainsworth. Dabrowska, Anita 10/29/16 Updated assumptions and NOL allocation schedules and stock basis computation schedules based on feedback from Kevin Ainsworth. Dabrowska, Anita 11/02/16 Drafted deliverable, which summarized sources of information, key assumptions, outstanding items, and the calculation's results (i.e., consolidated NOL, NOL by entity, and stock basis computation for Tierra). Dabrowska, Anita 11/03/16 Finalized deliverable and sent to BDO's National Tax Office for review , , ,

28 Case CSS Doc Filed 01/13/17 Page 12 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 B3 Tierra Solutions, Inc. Additional Services (Hourly) Name Date Description Hours Standard Rate Discounted Rate Amount Dabrowska, Anita 11/08/16 Assessed the deliverable with Jamie Lowry and Ching Lun and incorpoated some edits thereafter. McCullough, Steve 11/08/16 Reviewed the deliverable and provided , comments thereto. McCullough, Steve 11/19/16 Spoke with the attorneys about the stock basis and the NOL allocations and reviewed the NOL allocation for the post-may 4, 2012 period Dabrowska, Anita 11/19/16 Spoke with the attorneys and updated the NOL allocation for the post-may 4, 2012 allocation Ainsworth, Kevin 11/22/16 Researched certain tax technical matters and discussed them with Anita. Dabrowska, Anita 11/23/16 Discussed the deliverable with Maxus and spoke with the attorneys regarding legal expense allocation. Dabrowska, Anita 11/29/16 In response to attorney's request to consider reg sec , researched potential implications and interplay of reg. sec and other provisions. Dabrowska, Anita 11/30/16 Spoke with BDO's National Tax Office regarding attorney's request and followed-up with the attorneys therafter. Ainsworth, Kevin 11/30/16 Read s that focused on stock basis-related matters TOTAL 70.0 $ 33, INDIVIDUAL TOTALS Professional Hours Standard Hourly Rate Discounted Hourly Rate Amount Lun, Ching , McCullough, Steve , Dabrowska, Anita , Huynh, Rose , Ainsworth, Kevin , Mantey, Jessica TOTAL 70.0 $ 33,

29 Case CSS Doc Filed 01/13/17 Page 13 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 C1 Maxus International Energy Company Proforma U.S. Corporation Income Tax Return, Form 1120 Name Date Description Hours Huynh, Rose 09/05/16 Performed review of federal tax workpapers for 1.0 Maxus International. Huynh, Rose 09/06/16 Performed review federal return for Maxus 1.0 International. Mantey, Jessica 09/07/16 Performed detailed review of federal tax 2.0 workpapers for Maxus International. Huynh, Rose 09/09/16 Performed review federal return for Maxus International. 0.5 TOTAL 4.5 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 2.5 Mantey, Jessica 2.0 Total Hours 4.5 Flat Fee services $ 2, TOTAL $ 2,

30 Case CSS Doc Filed 01/13/17 Page 14 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 D1 Maxus (U.S.) Exploration Company Proforma U.S. Corporation Income Tax Return, Form 1120 Name Date Description Hours Mantey, Jessica 09/05/16 Performed detail review federal return for 2.3 Maxus US Exploration. Huynh, Rose 09/06/16 Performed review of federal return workpaper 0.5 for Maxus US Exploration. Huynh, Rose 09/07/16 Performed review of federal return workpaper 1.0 for Maxus US Exploration. Khan, Adnan 09/08/16 Updated tax return work paper for Maxus US 0.9 Exploration. Huynh, Rose 09/09/16 Performed review of federal return workpaper 0.3 for Maxus US Exploration. Khan, Adnan 09/13/16 Updated tax return work paper for Maxus US 0.4 Exploration. Huynh, Rose 09/28/16 Performed review of federal return for Maxus US Exploration. 0.3 TOTAL 5.7 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 2.1 Mantey, Jessica 2.3 Khan, Adnan 1.3 Total Hours 5.7 Flat Fee services $ 3, TOTAL $ 3,

31 Case CSS Doc Filed 01/13/17 Page 15 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 D2 Maxus (U.S.) Exploration Company Louisiana Corporation Income and Franchise Tax, Form CI FT-620 Name Date Description Hours Khan, Adnan 09/20/16 Prepared Louisiana return for Maxus US 1.7 Exploration. Khan, Adnan 09/21/16 Updated Louisiana tax return workpaper in tax 0.6 softwares for Maxus US Exploration. Mantey, Jessica 09/29/16 Prepared s to A. Kirchner regarding state 0.1 apportionments for Maxus Energy. Mantey, Jessica 10/03/16 Performed detail review Louisiana return for 1.1 Maxus US Exploration. Huynh, Rose 10/05/16 Performed review Louisiana return for Maxus 1.0 (US) Exploration. Mantey, Jessica 10/07/16 Cleared points on Louisiana return for Maxus 0.5 US Exploration. Huynh, Rose 10/07/16 Performed review Louisiana return for Maxus 0.3 (US) Exploration. Mantey, Jessica 10/14/16 Processed Louisiana state return and routed 0.4 information for Maxus US Exploration. Mantey, Jessica 10/17/16 Validated Louisiana tax return e-file submission for Maxus US Exploration. 0.5 TOTAL 6.2 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 1.3 Mantey, Jessica 2.6 Khan, Adnan 2.3 Total Hours 6.2 Flat Fee services $ 1, TOTAL $ 1,

32 Case CSS Doc Filed 01/13/17 Page 16 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 E1 Gateway Coal Company Proforma U.S. Corporation Income Tax Return, Form 1120 Name Date Description Hours Huynh, Rose 09/05/16 Performed review of federal tax workpapers for 0.3 Gateway Coal. Huynh, Rose 09/09/16 Performed review of federal tax workpapers for 0.3 Gateway Coal. Khan, Adnan 09/20/16 Updated tax return workpaper in tax software 0.9 for Gateway Coal. Khan, Adnan 09/21/16 Updated Gateway Coal federal tax return. 1.6 Huynh, Rose 09/28/16 Performed review of federal tax workpapers for 0.3 Gateway Coal. Huynh, Rose 10/03/16 Followed up with C. Fitzgerald for Gateway 0.3 Coal. Huynh, Rose 10/04/16 Followed up with C. Fitzgerald regarding 0.3 workers compensation for Gateway Coal. Mantey, Jessica 10/12/16 Phone meeting with C. Fitzgerald regarding 1.4 outstanding questions for Gateway Coal. Huynh, Rose 10/13/16 Performed review of federal tax return for 0.2 Gateway Coal. TOTAL 5.6 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 1.7 Mantey, Jessica 1.4 Khan, Adnan 2.5 Total Hours 5.6 Flat Fee services $ 3, TOTAL $ 3,

33 Case CSS Doc Filed 01/13/17 Page 17 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 E2 Gateway Coal Company Pennsylvania Corporate Tax Report, Form RCT- 101 Name Date Description Hours Khan, Adnan 09/20/16 Prepared Pennsylvania return for Gateway Coal. 1.7 Khan, Adnan 09/21/16 Updated tax return workpaper in tax software 1.4 for Gateway Coal. Mantey, Jessica 09/29/16 Prepared s to A. Kirchner regarding state 0.1 apportionments for Maxus Energy. Huynh, Rose 10/05/16 Performed review of Pennsylvania tax return for Gateway Coal. 0.8 TOTAL 4.0 INDIVIDUAL TOTALS Professional Hours Huynh, Rose 0.8 Mantey, Jessica 0.1 Khan, Adnan 3.1 Total Hours 4.0 Flat Fee services $ 1, TOTAL $ 1,

34 Case CSS Doc Filed 01/13/17 Page 18 of 22 Exhibit "B" MAXUS ENERGY CORPORATION, et al., RECAP OF PROFESSIONAL SERVICES September 1, 2016 through November 30, 2016 F1 Fee Applications Name Date Description Hours Standard Rate Discounted Rate Amount Lun, Ching 09/28/16 Performed review of procedures and call with Benjamin on interim fee application. Khan, Adnan 10/10/16 Prepared first fee application Huynh, Rose 10/10/16 Phone meeting with J. Duda regarding the first fee application. Huynh, Rose 10/11/16 Corresponded with bankruptcy team for first fee application. Vanderhoop, Naushon 10/11/16 Prepared first fee application Vanderhoop, Naushon 10/11/16 Corresponded regarding draft of first fee application. Huynh, Rose 10/11/16 Prepared and reviewed first fee application Mantey, Jessica 10/12/16 Prepared and reviewed first fee application Mantey, Jessica 10/13/16 Prepared and reviewed first fee application Vanderhoop, Naushon 10/13/16 Updated draft of first monthly application and related exhibits. Lun, Ching 10/13/16 Prepared and reviewed first fee application Huynh, Rose 10/24/16 Prepared and reviewed data for next fee application. Huynh, Rose 10/26/16 Prepared and reviewed data for next fee application. TOTAL , INDIVIDUAL TOTALS Professional Hours Standard Hourly Rate Discounted Hourly Rate Amount Lun, Ching Huynh, Rose , Vanderhoop, Naushon , Mantey, Jessica Khan, Adnan TOTAL ,

35 Case CSS Doc Filed 01/13/17 Page 19 of 22 Exhibit C 1. PHOTOCOPYING a. Internal b. External 2. TELECOMMUNICATIONS a. Toll Charges b. Facsimile c. Out-of-State toll charges MAXUS ENERGY CORPORATION, et al. Schedule of Expenses September 1, 2016 through November 30, COURIER, FRIEGHT AND POSTAL SERVICES For overnight and hand delivery to Counsel and Committee members 4. RESEARCH 5. TECHNOLOGY SERVICES 6. OUT-OF-TOWN TRAVEL a. Transportation b. Lodging c. Meals 7. OUTSIDE SERVICES 8. LOCAL MEALS 9. LOCAL TRANSPORTATION, TOLLS, MILEAGE AND PARKING for cabs to/from meetings, car service for employees working after 8:00 p.m. and local mileage using personal auto 10. MISCELLANEOUS TOTAL $0.00 1

36 Case CSS Doc Filed 01/13/17 Page 20 of 22 BDO USA, LLP 2929 Allen Parkway Houston, TX Telephone: Tax Services Provider to the Debtors IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: MAXUS ENERGY CORPORATION, et al., 1 Debtors. Chapter 11 Case No: (CSS) (Jointly Administered) Objection Deadline: February 3, 2017 at 4:00 p.m. (ET) DECLARATION OF CHING LUN IN SUPPORT OF SECOND CONSOLIDATED MONTHLY APPLICATION OF BDO USA, LLP, AS TAX SERVICES PROVIDER TO THE DEBTORS FOR INTERIM COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD SEPTEMBER 1, 2016 THROUGH NOVEMBER 30, 2016 STATE OF TEXAS } }SS: COUNTY OF HARRIS } I, CHING LUN, declare under the penalty of perjury as follows: 1. I am a tax partner of the Houston office of the firm of BDO USA, LLP ( BDO USA ), a Delaware registered limited liability partnership, a national accounting, audit, financial advisory, tax, and consulting firm consisting, in part, of certified public accountants, with offices located at 2929 Allen Parkway, Houston, TX 77019, and in other locations throughout the United States. 1 The Debtors in the above-captioned chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are: Maxus Energy Corporation (1531), Tierra Solutions, Inc. (0498), Maxus International Energy Company (7260), Maxus (U.S.) Exploration Company (2439), and Gateway Coal Company (7425). The address of each of the Debtors is Richmond Avenue, Suite 1050, Houston, Texas

37 Case CSS Doc Filed 01/13/17 Page 21 of I have reviewed BDO s Second Consolidated Monthly Application for Compensation and Reimbursement of Expenses of BDO as Tax Services Provider to the Debtors and debtors in possession (the Debtors ) (the Application ) for the period September 1, 2016 to November 30, 2016 (the Application Period ) and this affidavit is submitted in support of the Application. 3. I have reviewed Delaware Bankruptcy Local Rule and submit that the Application substantially complies with such Rule. 4. To the best of my knowledge, information and belief formed after reasonable inquiry, the Application complies with the United States Trustees Guidelines issued March 22, 1995, by the U.S. Department of Justice (the UST Guidelines ). 5. In providing a reimbursable outside service expense, BDO does not make a profit on that service. 6. In charging for a particular service, BDO does not include the amortization of the cost of any investment equipment or capital outlay. 7. In seeking reimbursement for third party services, BDO requests reimbursement only for the amount billed to BDO by the third-party. 8. To the best of my knowledge, information and belief formed after reasonable inquiry, the fees and disbursements sought fall within the UST Guidelines, except as specifically noted herein and in the application. The fees and disbursements sought are billed at rates and in accordance with practices customarily employed by BDO and generally accepted by BDO s clients. 9. A summary of the fees and expenses incurred by BDO in these chapter 11 cases, during the Application Period as well as copies of the records maintained in the ordinary course of business by BDO are provided in Exhibits A through C annexed to the Application. -2-

38 Case CSS Doc Filed 01/13/17 Page 22 of 22