In re: Chapter 11 ALLIED SYSTEMS HOLDINGS, INC., eta/.,' Case No. 12-11564 (CSS) Debtors. (Jointly Administered) Objection Deadline: October 22, 2012 at 4:00 p.m. (EDT) THIRD MONTHLY APPLICATION OF GOWLING LAFLEUR HENDERSON LLP FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS CANADIAN COUNSEL TO THE DEBTORS AND DEBTORS-IN-POSSESSION FOR THE PERIOD FROM AUGUST 1, 2012 THROUGH AUGUST 31,2012 Name of Applicant: Authorized to Provide Professional Services to: Date of Retention: Period for which compensation and reimbursement are sought: Amount of Compensation sought as actual, reasonable, and necessary: Amount of Expense Reimbursement sought as actual, reasonable, and necessary: This is a(n): ___x_ monthly interim Gowling Lafleur Henderson LLP the above-captioned debtors and debtors-in- possession August 7, 2012, nunc pro tunc to June 10, 2012 August 1, 2012 through August 31,2012 $51,598.51 (80% of$64,498. 14) $1,399.52 (100% of $1 ,399.52) final application The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90- 0 169283); Allied Systems, Ltd. (L.P.) (58-171 0028); Axis Areta, LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38- 2918187); Cord in Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-03651 00); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, lnc. (59- 2876863); RMX LLC (31-096 1359); Transport Support LLC (38-2349563); and Terminal Services LLC (91- 0847582). The location of the Debtors' corporate headquarters and the Debtors' address for service of process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345. Prior Applications Filed: Date Filed Period Covered Fees Expenses September 5, 2012 June 10,2012 to $243,991.86 $4,787.55 June 30, 2012 September 20, 2012 July 1, 2012 to $138,011.42 $3,715.44 July 31, 2012 2 COMPENSATION BY PROFESSIONAL AUGUST 1, 2012 THROUGH AUGUST 31, 2012 Name of Professional Position, year assumed Hourly Total Individual Paul Dempsey Hugh Christie Cliff Prophet Chris Eustace Boyd Balogh Jennifer Starn Ronald Snyder Heather Gray Ava Kim Nadia Conforti Jason McMurtrie Katie Parent Lauren Enquist TOTAL position, prior relevant Billing Rate Hours experience, year of (including Billed obtaining relevant changes) license to practice Partner $790.00 2.50 Partner $760.00 1.90 Partner $750.00 2.0 Partner $725.00 20.10 Partner $650.00 3.20 Partner $640.00 21.70 Partner $370.00 5.30 Associate $525.00 6.0 Associate $370.00 28.70 Associate $170.00 3.80 Law Clerk $375.00 0.50 Law Clerk $300.00 16.40 Student-at-law $225.00 0.60 112.70 Total Harmonized Sales Tax ("HST") Grand Total Professionals Compensation Total Hours Blended Rate Dated: October f@-, 2012 Toronto, Ontario 3 Total Compensation $1,975.00 $1,444.00 $1,500.00 $14,572.50 $2,080.00 $13,888.00 $1,961.00 $3,150.00 $10,619.00 $646.00 $187.50 $4,920.00 $135.00 $57,078.00 $57,078.00 $7,420.14 $64,498.14 $51,835.50 112.70 $511.54 COMPENSATION BY PROJECT CATEGORY AUGUST l, 2012 THROUGH AUGUST 31, 2012 Pro.iect Category Total Hours Case Administration (A) 1.60 Creditor Inquiries (B) 0 Meetings (C) 0 Executory Contracts/Unexpired Leases (D) 0 Automatic Stay/ Adequate Protection (E) 0 Plan of Re-Organization/Disclosure Statement (F) 0 Use, Sale, Lease of Assets (G) 0 Cash Collateral/DIP Financing (H) 0 Claims Administration (I) 1.80 Court Hearings (J) 0 General Corporate/Real Estate (K) 7.10 Schedules/SOFA/U. S. Trustee Reports (L) 0 Employee Issues (M) 58.50 Environmental (N) 0 Tax Issues (0) 0 Litigation/Adversary Proceedings (P) 0.20 Gowlings Retention (Q-1) 1.80 Retention of Others (Q-2) 2.30 Gowlings Fee Applications (R-1) 35.60 Fee Applications of Others (R-2) 0 Vendor/Supplies (S) 0 Non-Working Travel (T) 0 Utilities (U) 0 Insurance (V) 3.80 TOTAL 112.70 4 Total Fees $559.50 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $666.00 $0.00 $5,020.00 $0.00 $34,104.00 $0.00 $0.00 $128.00 $1,163.00 $1,099.50 $13,692.00 $0.00 $0.00 $0.00 $0.00 $646.00 $57,078.00 EXPENSE SUMMARY AUGUST 1, 2012 THROUGH AUGUST 31, 2012 Expense Category Service Provider Total Expenses (if applicable) Taxable Expenses Long Distance Telephone $3.22 Conference Calling Confer Tel $6.44 In-House Reproduction Photocopying: 259 @ $.10/pg. $30.10 Scanning: 42 @J $.1 0/pg. Outside Reproduction $0.00 Legal Research Quicklaw $252.17 Westlaw eCarswell Court Reporting $0.00 Travel Expenses Taxis $82.99 Inside Courier & Expense Blizzard Courier Service $20.33 Carriers Outside Courier & Expense Federal Express $38.03 Carriers Postage $0.00 Binding $45.40 Business Meals $0.00 Document Retrieval $0.00 Record Retrieval $0.00 Room Rental $0.00 Professional Services Vendor: Field LLP, Northwest $255.50 Territories Agent Office Supplies & Corporate $415.84 Records Overtime $0.00 SUBTOTAL $1,150.02 HST $149.50 TOTAL, including taxes $1,299.52 5 EXPENSE SUMMARY -CONTINUED AUGUST 1, 2012 THROUGH AUGUST 31. 2012 Non-Taxable Expenses Filing of Annual Return - August 22, 2012 TOTAL GRAND TOTAL 6 $100.00 $100.00 $1!322.52 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 ALLIED SYSTEMS HOLDINGS, INC., et al., 1 Case No. 12-11564 (CSS) Debtors. (Jointly Administered) Objection Deadline: October 22, 2012 at 4:00 p.m. (EDT) THIRD APPLICATION OF GOWLING LAFLEUR HENDERSON LLP FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF EXPENSES AS CO-COUNSEL TO THE DEBTORS AND DEBTORS-IN-POSSESSION FOR THE PERIOD FROM AUGUST 1, 2012 THROUGH AUGUST 31, 2012 Pursuant to sections 330 and 331 of title 11 of the United States Code (the "Bankruptcy Code"), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and Official Committee Members [Docket No. 215] (the "Administrative Order"), Gowling Lafleur Henderson LLP ("Gowlings") hereby files this Third Monthly Application for Allowance of Compensation for Services Rendered and for Reimbursement of Expenses as Canadian Counsel to the Debtors and Debtors-in-Possession for the Period From August 1, 2012 through August 31, 2012 (the "Application"). By this Application, Gowlings seeks a monthly allowance pursuant to the Administrative Order with respect to the sums of $64,498.14 (80% of which equals $51,598.51) as compensation and $1,399.52 for reimbursement of actual and necessary expenses for a total of $52,998.03 for the The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-220 I 081 ); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90- 0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38- 2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59- 2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91- 0847582). The location of the Debtors' corporate headquarters and the Debtors' address for service of process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345. period August 1, 2012 through to and including August 31, 2012 (the "Compensation Period"). ln support of this Application, Gowlings respectfully represents as follows: Background I. On May 17, 2012 (the "Involuntary Petition Date"), involuntary petitions were filed against All ied Systems Holdings, Inc. ("Allied Holdings") and its subsidiary Allied Systems, Ltd. (L.P .) ("Allied Systems") under chapter 11 of the Bankruptcy Code in this Court. On June 10, 2012 (the "Voluntary Petition Date," and together with the Involuntary Petition Date, the "Petition Date," as applicable to the particular Debtor), the remaining Debtors filed voluntary petitions in this Court and, in connection therewith, Allied Holdings and Allied Systems consented to the involuntary petitions filed against them. Additional information regarding the Debtors' business and the background relating to events leading up to the above- captioned chapter 11 cases can be found in the Declaration of Scott D. Macaulay in Support of First-Day Pleadings [Docket No. 80] which was filed on the Voluntary Petition Date. 2. Gowlings was retained effective as of the Voluntary Petition Date by this Court's Order dated August 7, 2012 (the "Retention Order"). The Retention Order authorized Gowlings to be compensated on an hourly basis and to be reimbursed for actual and necessary out-of-pocket expenses. Compensation Paid and Its Source 3. All services for which compensation is requested by Gowlings were performed for or on behalf of the Debtors. 4. Except to the extent of the retainer paid to Gowlings as described in the application seeking approval ofGowlings' employment by the Debtors during the period covered by this Application, Gowlings has received no payment and no promises for payment from any - 2- source for services rendered or to be rendered in any capacity whatsoever in connection with the matters covered by this Application. There is no agreement or understanding between Gowlings and any other person for the sharing of compensation to be received for services rendered in these cases. Fee Statements 5. The fee statement for the Compensation Period is attached hereto as Exhibit B. This statement contains daily time logs describing the time spent by each professional and paraprofessional for this period. To the best of Gowlings' knowledge, this Application complies with sections 330 and 331 of the Bankruptcy Code, the Federal Rules of Bankruptcy Procedure, the Guidelines adopted by the Office of the United States Trustee, Del. Bankr. L.R. 2016-2, and the Administrative Order. Actual and Necessary Expenses 6. A summary of actual and necessary expenses and daily logs of expenses incurred by Gowlings during the Compensation Period is attached hereto as Exhibit B. Gowlings charges all of its bankruptcy clients $.10 per page for photocopying expenses and $. 10 per page for printing. Actual long-distance carrier charges for outgoing facsimile transmissions are reflected in the long-distance telephone charges. 7. Regarding providers of on-line legal research ~ . LEXIS and WESTLA W), Gowlings charges all of its clients the standard usage rates these providers charge, which, due to contractual flat fees, may not always equal Gowlings' actual cost. Gowlings currently is under contract to pay these providers a flat fee every month. Charging its clients the on-line providers' standard usage rates allows Gowlings to cover adequately the monthly flat fees it must pay to these types of providers. - 3- 8. Gowlings believes the foregoing rates are the market rates that the majority of Canadian law firms charges clients for such services. Summary of Services Rendered 9. The partners and associates of Gowlings who have rendered professional services in these cases are as follows: Paul Dempsey, Hugh Christie, Cliff Prophet, Chris Eustace, Boyd Balogh, J ennifer Starn, Ronald Snyder, Heather Gray, Ava Kim and Nadia Conforti. The paraprofessionals of Gowlings who have provided service to these professionals in these cases is as follows: Jason McMurtrie, Katie Parent and Lauren Enquist. 1 0. Gowlings, by and through the above-named persons, has prepared and/or assisted in the preparation of various applications and orders submitted to the Court for consideration, advised the Debtors on a regular basis with respect to various matters in connection with these cases, and has performed all necessary professional services which are described and narrated in detail hereinafter. Summary of Services By Project 11. The services rendered by Gowlings during the Compensation Period can be grouped into the categories set fmth below. These categories are generally described below, with a more detailed identification of the actual services provided set forth on the attached Exhibit A. The professionals and paraprofessionals who rendered services relating to each category are identified, along with the number of hours for each individual and the total compensation sought for each category, in Exhibit A attached hereto. A. Case Administration/Miscellaneous Matters Fees: $559.50 Total Hours: 1. 60 This category includes all matters related to filing documents with the Court, - 4- service thereof, maintenance of calendars, review of work in process reports, review of notices of appearance and maintaining service lists. B. Creditor Inquiries Fees: $0.00 Total Hours: 0.0 This category includes all matters related to responding to creditor inquiries. C. Meetings Fees: $0.00 Total Hours: 0.0 This category includes all matters related to preparing for and attending meetings with Debtors, the creditors' committees, individual creditors, the U.S. Trustee and co-counsel. D. Executory Contracts/Unexpired Leases Fees: $0.00 Total Hours: 0.0 This category includes all matters related to contract and lease analysis and matters related to assumption, assignment or rejection of executory contracts and unexpired leases. E. Automatic Stay/ Adequate Protection Fees: $0.00 Total Hours: 0.0 This category includes all matters related to and including all motions to modify the automatic stay, issues related to the effect of the automatic stay or pending matters, and all other types of actions where adequate protection is the central issue. F. Plan of Reorganization/Disclosure Statement Fees: $0.00 Total Hours: 0.0 - 5 - This category includes all matters related to review, formulation, negotiation, preparation and promulgation of plans of reorganization, disclosure statements, and related corporate documentation and research relating thereto. G. Use. Sale. Lease of Assets Fees: $0.00 Total Hours: 0.0 This category includes all matters relating to acquisitions, dispositions and other post petition uses of property of the estate. H. Cash Collateral/DIP Financing Fees: $0.00 Total Hours: 0.0 This category includes all matters relating to negotiation and documentation of debtor in possession financing and post-confirmation financing, all cash collateral issues and related pleadings. I. Claims Administration Fees: $666.00 Total Hours: 1.80 This category includes all matters related to and including claims administration matters and bar date matters, including claims objections and related contested matters. J. Court Hearings Fees: $0.00 Total Hours: 0.0 This category includes all matters relating to preparation for and attendance at court hearings. K. General Corporate/Real Estate Fees: $5,020.00 Total Hours: 7. 10 - 6- This category includes all matters relating to transactional, corporate governance and related matters involving the debtors' business operations that are not part of a plan of reorganization or disclosure statement. L. Schedules/SOF AIU .S. Trustee Reports Fees: $0.00 Total Hours: 0.0 This category includes preparation of schedules and amendments, statements of financial affairs and amendments, operating reports and other reports required by the U.S. Trustee or Bankruptcy Court. M. Employee Issues Fees: $34,104.00 Total Hours: 58.50 This category includes all matters related to employee wages, benefits, collective bargaining issues, other employee relations matters, ERISA, and retirement benefits. N. Environmental Fees: $0.00 Total Hours: 0.0 This category includes all environmental matters, other than environmental aspects of plan of reorganization. 0. Tax Issues Fees: $0.00 Total Hours: 0.0 This category includes all federal and state income, property, employment, excise and other tax matters, other than the tax aspects of plan of reorganization. P. Liti gation/Adversary Proceedings Fees: $128.00 Total Hours: 0.20 This category includes all matters relating to litigation and adversary proceedings. - 7- Q-1. Gowlings Applications Fees: $1,163.00 Total Hours: 1.80 This category includes all matters related to preparing applications to retain Gowlings and supplements thereto. Q-2. Retention of Others Fees: $1099.50 Total Hours: 2.30 This category includes time spent reviewing applications for retention by other professionals, objecting to the retention of other professionals and assisting other professionals with preparing and filing retention applications. R-1. Gowlings Fee Application Fees: $13,692.00 Total Hours: 35.60 This category includes all time spent preparing, reviewing, filing, circulating and/or relating to monthly invoices and fee applications for Gowlings. R-2. Fee Application of Others Fees: $0.00 Total Hours: 0.0 This category includes time spent reviewing invoices or applications of other professionals, objecting to fees of other professionals and assisting other professionals with filing and circulating monthly invoices and applications. S. Vendor/Supplies Fees: $0.00 Total Hours: 0.0 This category includes all matters related to vendors and suppliers, including reclamation issues. - 8 - T. Non-Working Travel Fees: $0.00 Total Hours: 0.0 This category includes all travel time not otherwise chargeable. U. Utilities Fees: $0.00 Total Hours: 0.0 This category includes all matters related to utility issues. V. Insurance Fees: $646.00 Total Hours: 3.80 This category includes all matters related to insurance policies or coverage. Valuation of Services 12. Professionals and paraprofessionals of Gowlings have expended a total of 112.70 hours in connection with this matter during the Compensation Period, as follows: PROFESSIONALS HOURS HOURLY RATE Paul Dempsey 2.50 $790.00 Hugh Christie 1.90 $760.00 Cliff Prophet 2.0 $750.00 Chris Eustace 20.10 $725.00 Boyd Balogh 3.20 $650.00 Jennifer Starn 21.70 $640.00 Ronald Snyder 5.30 $370.00 Heather Gray 6.0 $525.00 Ava Kim 28.70 $370.00 Nadia Conforti 3.80 $170.00 - 9- PARA PROFESSIONALS Jason McMurtrie Katie Parent Lauren Enquist HOURS 0.50 16.40 0.60 HOURLY RATE $375.00 $300.00 $225.00 The nature of the work performed by these persons is fully set forth in Exhibit A attached hereto. These are Gowlings' normal hourly rates for work of this character. The reasonable value of the services rendered by Gowlings to the Debtors during the Compensation Period is $64,498. 14 ($57,078.00 plus HST in the amount of$7,420.14). 13. In accordance with the factors enumerated m section 330 of the Bankruptcy Code, it is respectfully submitted that the amount requested by Gowlings is fair and reasonable given (a) the complexity of these cases, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services, and (e) the costs of comparable services other than in a case under this title. Moreover, Gowlings has reviewed the requirements of Del. Bankr. L.R. 2016-2 and believes that this Application complies with that Rule. WHEREFORE, Gowlings respectfully requests that the Court authorize that for the period August 1, 2012 through August 31,2012, an allowance be made to Gowlings pursuant to the terms of the Administrative Order, with respect to the sum of $64,498.14 as compensation for necessary professional services rendered (80% of which equals $51,598.51 ), and the sum of $1 ,3 99.52 as 1 00% reimbursement of actual necessary costs and expenses, for a total of $52,998.03 and that such sums be authorized for payment and for such other and further relief as this Court may deem just and proper. - 10- Dated: October I ~ 2012 Toronto, Ontario Respectful Is/ Cfi'fif ust SUC o.410700U) Jennifer Starn (LSUC No. 467351) Ava Kim (LSUC No. 57256C) Gowling Lafleur Henderson LLP One First Canadian Place 100 King Street West, Suite 1600 Toronto, Ontario, MSX 1 G5 Telephone: ( 416) 862-4467 Facsimile: ( 416) 863-3467 E-mail: chris.eustace@gowlings.com E-mail: jennifer.stam@gowlings.com E-mail: ava.kim@gowlings.com Canadian Counselfor the Debtors - 11 - VERIFICATION PROVINCE OF ONT ARlO ) ) SS: CITY OF TORONTO ) Ava Kim, after being duly sworn according to law, deposes and says: a) I am an associate with the applicant firm, Gowling Lafleur Henderson LLP. b) I am familiar with the work performed on behalf of the Debtors by the lawyers in the firm. c) I have reviewed the foregoing Application and the facts set forth therein are true and correct to the best of my knowledge, infonnation and belief. Moreover, I have reviewed Del. Bankr. L.R. 2016-2, and submit that the Application substantially complies with such order. S W O R ~ \ AND SUBSCRIBED before me th;s_:ay of:tober, 2012.
RLF1 7292267v.1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: ALLIED SYSTEMS HOLDINGS, INC., et al., 1
Debtors. Chapter 11 Case No. 12-11564 (CSS) (Jointly Administered) Objection Deadline: October 22, 2012 at 4:00 p.m. (EDT)
NOTICE OF THIRD MONTHLY FEE APPLICATION OF GOWLING LAFLEUR HENDERSON LLP
PLEASE TAKE NOTICE that Gowling Lafleur Henderson LLP (the "Applicant") has today filed the attached Third Monthly Application of Gowling Lafleur Henderson LLP for Allowance of Compensation for Services Rendered and for Reimbursement of Expenses as Canadian Counsel to the Debtors and Debtors-in- Possession for the Period from August 1, 2012 through August 31, 2012 (the Application) with the United States Bankruptcy Court for the District of Delaware, 824 Market Street, 3rd Floor, Wilmington, Delaware 19801 (the Bankruptcy Court). PLEASE TAKE FURTHER NOTICE that objections, if any, to the Application must be made in accordance with the Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and Official Committee Members (the Interim Compensation Order), entered July 10, 2012 [Docket No. 215], and must be filed
1 The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90- 0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38- 2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59- 2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91- 0847582). The location of the Debtors corporate headquarters and the Debtors address for service of process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.
- 2 - RLF1 7292267v.1 with the Clerk of the Bankruptcy Court, and be served upon and received by: (i) the Debtors, Allied Systems Holdings, Inc., 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345 (Attn: John A. Blount); (ii) co-counsel to the Debtors, Troutman Sanders LLP, Bank of America Plaza, 600 Peach Street, Suite 5200, Atlanta, Georgia 30308 (Attn: Jeffrey W. Kelley) and Richards, Layton & Finger, P.A., One Rodney Square, 920 N. King Street, Wilmington, Delaware 19801 (Attn: Mark D. Collins); (iii) the Office of the United States Trustee for the District of Delaware, 844 N. King Street, Suite 2207, Lockbox 35, Wilmington, Delaware 19801 (Attn: David L. Buchbinder); and (iv) co-counsel to the Committee, Sidley Austin LLP, 787 Seventh Avenue, New York, New York 10019 (Attn: Michael G. Burke) and Sullivan Hazeltine Allinson LLC, 901 North Market Street, Suite 1300, Wilmington, Delaware 19801 (Attn: William D. Sullivan); (collectively, the Notice Parties) so as to be received no later than October 22, 2012 at 4:00 p.m. (the Objection Deadline). PLEASE TAKE FURTHER NOTICE that if no objections are received by the Notice Parties prior to the Objection Deadline, in accordance with the Interim Compensation Order, the Applicant may be paid certain fees and expenses pursuant to the terms of the Interim Compensation Order, without further notice or hearing. If an objection is properly filed and served and such objection is not otherwise resolved, or the Bankruptcy Court determines that a hearing should be held in respect of the Application, a hearing will be held at a time convenient to the Bankruptcy Court. Only those objections made in writing and timely filed, served and
- 3 - RLF1 7292267v.1 received in accordance with the Interim Compensation Order will be considered by the Bankruptcy Court at the hearing. Dated: October 2, 2012 Wilmington, Delaware /s/ Marisa A. Terranova _____________________ Mark D. Collins (No. 2981) Christopher M. Samis (No. 4909) Marisa A. Terranova (No. 5396) RICHARDS, LAYTON & FINGER, P.A. One Rodney Square 920 North King Street Wilmington, Delaware 19801 Telephone: (302) 651-7700 Facsimile: (302) 651-7701 E-mail: collins@rlf.com E-mail: samis@rlf.com E-mail: terranova@rlf.com
-and-
Jeffrey W. Kelley (GA Bar No. 412296) Ezra H. Cohen (GA Bar No. 173800) TROUTMAN SANDERS LLP Bank of America Plaza 600 Peachtree Street, Suite 5200 Atlanta, Georgia 30308-2216 Telephone: (404) 885-3000 Facsimile: (404) 885-3900 E-Mail: jeffrey.kelley@troutmansanders.com E-Mail: ezra.cohen@troutmansanders.com
Counsel for Debtors and Debtors-in-Possession EXHIBIT "A" A. CASE ADMINISTRA TIONIMISCELLANEOUS MATTERS Professional Name Billed Amount Billed Hours Ava Kim $222.00 0.60 Jason McMurtrie $187.50 0.50 Katie Parent $150.00 0.50 Grand Total $559.50 1.60 B. CREDITOR INQUIRIES N/A C. MEETINGS NIA D. EXECUTORY CONTRACTS/UNEXPIRED LEASES NIA E. AUTOMATIC STAY/ADEQUATE PROTECTION N/A F. PLAN OF REORGANIZATION/DISCLOSURE STATEMENT N/A G. USE, SALE, LEASE OF ASSETS N/A H. CASH COLLATERAL/DIP FINANCING NIA I. CLAIMS ADMINISTRATION Professional Name Billed Amount Billed Hours Ava Kim $666.00 1.80 Grand Total $666.00 1.80 J. COURT HEARINGS N/A K. GENERAL CORPORATE/REAL ESTATE Professional Name Billed Amount Billed Hours Chris Eustace $4,060.00 5.60 Jennifer Starn $960.00 1.50 Grand Total $5,020.00 7.10 L. SCHEDULES/SOFA/U.S. TRUSTEE REPORTS N/A M. EMPLOYEE ISSUES Professional Name Billed Amount Billed Hours Paul Dempsey $1,975.00 2.50 Hugh Christie $1,444.00 1.90 Cliff Prophet $1,500.00 2.0 Chris Eustace $5,655.00 7.80 Boyd Balogh $2,080.00 3.20 Jennifer Starn $12,800.00 20.0 Ronald Snyder $1,961.00 5.30 Heather Gray $3,150.00 6.0 Ava Kim $3,404.00 9.20 Lauren Enquist $135.00 0.60 Grand Total $34,104.00 58.50 N. ENVIRONMENTAL N/A 0 . TAX ISSUES N/A 14 P. LITIGATION/ADVERSARY PROCEEDINGS Professional Name Billed Amount Billed Hours Je1mifer Starn $128.00 0.20 Grand Total $128.00 0.20 Q-1. GOWLINGS APPLICATIONS Professional Name Billed Amount Billed Hours Chris Eustace $1,015.00 1.40 Ava Kim $148.00 0.40 Grand Total $1,163.00 1.80 Q-2. RETENTION OF OTHERS Professional Name Billed Amount Billed Hours Chris Eustace $507.50 .70 Ava Kim $592.00 1.60 Grand Total $1,099.50 2.30 R-1. GOWLINGS FEE APPLICATION Professional Name Billed Amount Billed Hours Chris Eustace $3,335.00 4.60 Ava Kim $5,587.00 15.10 Katie Parent $4,770.00 15.90 Grand Total $13,692.00 35.60 R-2. FEE APPLICATION OF OTHERS N/A s. VENDOR/SUPPLIES N/A T. NON-WORKING TRAVEL N/A u. UTILITIES N/A 15 V. INSURANCE Professional Name Billed Amount Billed Hours Nadia Conforti $646.00 3.80 Grand Total $646.00 3.80 16 EXHIBIT "B" See attached. TOR_LAW\ 8005053\1 gowlings montreal ottawa toronto hamilton waterl oo region calgary vancouver beijing moscow london Allied Systems. (Canada) Company ATTN: John Blount and Scott Macaulay 2302 Parklake Drive Building 15, Suite 600 Atlanta GA 30345 USA Our Matter: RE: T927136.25 I 104699 Restructuring (Post Filing) TOOURFEE: Fees for Professional Services HSTonFees Total Fees and Taxes DISBURSEMENTS: Disbursements (Ta.'\able) Disbursements (Non-Taxable) HST on Disbursements Total Disbursements and Taxes TOTAL INVOICE BALANCE: Total for this Invoice [ Total HST: $7,569.64 ] September 21,2012 INVOICE: 17562496 $57,078.00 7.420.14 64,498.14 1,150.02 100.00 149.50 1,399.52 65,897.66 Please remit total invoice balance due: In Canadian Dollars I rms: due upon rocolpl lnte<cst at the rate ol1.3'llt per annum willlle chnrgc'tl on all amount5 not paid within one n1onth from the date of this Invoice cnors and omissions GST/ HST: 11.936 4511. RT Gowling Lafleur HendetSOn LLP Lawyers Patent and Trode-mark Agents pace 1.of9 l. First Canadian Place .1.00 King Street West Suite 1600 Toronto Ontario. M5X 1G5 Cana<la T 416-862-7525 F 416-862-7661 gowllngs.com gowling; Allied Systems (Canada) Company Our Matter: T927136.25 Restructuring (Post Filing) PROFESSIONAL SERVICES Date Hours Timekeeper Ol/08/2012 0.70 Hugh A Christie Ol/08/2012 2.40 Chris J. Eustace Ol/08/2012 3. 10 Jennifer Stam 02/08/2012 1.20 Hugh A Christie 02/08/2012 0.90 Chris J. Eustace 02/08/2012 0.30 Ava Kim 02/08/2012 0.70 Jennifer Starn 03/08/2012 3.10 Chris J. Eustace 03/08/2012 1.20 Jennifer Stam 06/08/2012 0.70 Chris J. Eustace 06/08/2012 5.30 Ronald M. Snyder 07/08/2012 1.00 Chris J. Eustace 07/08/2012 1.10 Ava Kim Description September 21, 2012 INVOICE: 17562496 Review KERP and telephone attendance with J. Stam/C. Eustace (.50); telephone attendance with R. Snyder (.1 0); Review Key Employee Retention Plan and correspondence with Hugh Cluistie and J. Starn re same (0.90); emails from/to Marisa A. Temmova, Esq. re Gowlings Revised Retention order (0.20); various emails Jennifer Stam, Cluistopher Samis and Ava Kim re Revised Retention Order (0.30); attendances re Nova Scotia corporate Jaw govcrance (0.9); Conference call with Ezra Cohen, C. Eustace and Charles Reagh re Nova Scotia law matters (1.0); drafting settlement proposal re D&O ( 1.6); conversation with Hugh Christie/C. Eustace re proposed KERP (.5). Revise KERP for Canadian employment law (.80); telephone attendance G. Geddes (.40); Review H. Christie emai ls and attachments re KERP (0.5); vari ous attendances including execution of Supplemental Retention Affidavit (0.4); Anendancc to execution and filing of amended supplemental retention affidavit of C. Eustace; Reviewing draft KERP (.5); correspondence redraft KERP (.2). Review email from Jennifer Starn rc Gowlings comments on KERP to Jeffery Cavender (0.2); various emails reproposed conference call tomorrow (0.3); attendances re D&O strategy (0.8); review email/attachments re Canadian real estate (0.7); review email/attachments re Canadian PPSA issues (0.7); various discussion re Retention issues (0.4); Conversation re D&O Charge strategy ( 1.0); follow up correspondence re D&O strategy (.2) Update re Canada Labour Code issues (0.7) Telephone calls from E. Cohen to discuss multiple Director liability issues pursuant to the Canada Labour Code (1.0); review jurisprudence and commence drafting of Memorandums (3.8); telephone call wit11 J. Starn and C. Eustace advising of same (.50); Various attendances re labour law matters (0.5); review J. Stam settlement points (0.5); Reviewing administrative order of Delaware Court re fee applications (.80); correspondence regarding same (.30); torms: duo upon receipt Interest at the rotc or 1.3% por annum will be charged on all amount& not paid within one month trom the date of this invoice errors and omissions excluded page2of9 gowling; September 21,2012 INVOICE: 17562496 Date Hours Timekeeper Description 07/08/2012 0.70 Cliff Prophet Discussion with J. Starn re approaches to bargainning unit employees; 07/08/2012 4.00 Jennifer Stam Conversation with Ezra Cohen re D&O charge issue (.5); conversation with Ron Snyder re labour law issues (.5); follow up correspondence with Ezra Cohen rc labour law issues (.4); conversation with John Blount re CAW settlement options (.5); drafting settlement talking points for CAW meeting (l . 7); follow up conversation with John Blount on CAW settlement points (.4). 08/08/2012 1.00 Chris J. Eustace Instmctions and correspondence re fee application (0.6); updates re settlement terms and related matters (0.4); 08/08/2012 5.50 Ava Kim Preparation of first monthly fee application for June fees (2.50); preparation of summaries of fees by categories (2.8); correspondence regarding same (.20); 08/08/2012 1.80 Jennifer Starn Drafting settlement term sheet and order (.8); conversation with John Blount re CAW meeting (.3); considering settlement terms (.5); correspondence reinsurance litigation (.2). 09/08/2012 1.10 Chris J. Eustace Further attendances re CAW settlement (0.5); correspondence re fee application (0.5); 09/08/2012 3.90 Ava Kim Preparation of draft letter directing claims holders to claims agent and correspondence regarding same ( 1. 80); preparation of first monthly fee application for June fees and summaries of fees by category (2. I 0); 09/08/2012 0.30 Cliff Prophet Further discussion re termination and severance claim issues; 09/08/2012 2.80 Jennifer Stam Working on settlement term sheet and order (1.8); reviewing background documents for help on drafting settlement term sheet (.8); correspondence re CAW settlement (.2). 10/08/2012 1.00 Chris J. Eustace Receipt and review first monthly fee application from Ava Kim; 10/08/2012 1.30 Ava Kim Finalizing and circulating first monthly fee application for June fees and exhibits thereto; 10/08/2012 1.40 Jennifer Starn Revising proposed settlement with CAW (.7); conversation with Bany Wads>.vorth at the CAW re proposed settlement ( .5); follow up correspondence with Allied and Duff & Phelps re severance calculations (.2). 13/08/2012 1.50 Chris J. Eustace Attend to fee application review (0.3); review issues re ASC D&O issues (0.4); receipt of various ASC/Axis provincial filings and complete same (0.8); 13/08/2012 2.50 Heather M. Gmy Review US case provided by counsel (.50); review Term Sheet and related Order (.30); consider issue of agreement not to execute with regard to existing policies (.30); review and consider Allied Canada D&O policies ( 1.40); 13/08/2012 0.50 Jemtifer Starn Conversation with Ezra Cohen re D&O settlement (.5). 14/08/2012 1.30 Chris J. Eustace Emailslcorrespondence re Order, reviewing US Orders (0.2); emails re Canadian real estate/mortgages and attendances re terms: due upon receipt Interest at the rate of 1.3% per annum will bo cl\arged on nil amounts not pnld within one monll\ ftom the dnte of this Invoice errors and omisSions oxclullcd pago3 ot9 gowlings Date Hours 14/0812012 3.50 14/08/2012 0.60 14/08/2012 1.60 15/08/2012 3.20 15/08/2012 0.60 15/08/2012 1.00 15/08/2012 0.80 16/08/2012 3.00 16/08/2012 1.70 16/08/2012 2.80 16/08/2012 0.40 Timekeeper Heather M. Gray Ava Kim Jennifer Stam Boyd Balogh Lauren Enquist Chris J. Eustace Jennifer Stam Nadia Conforti Chris J. Eustace Ava Kim Katie Parent Description September 21, 2012 INVOICE: 17562496 same (0.8); emails/correspondence re D&O Settlement and status/issues (0.3); Conduct additional research on US case law dealing with agreements not to execute (I .0); review additional case law considering the policy language in the Allied Canada policies (.50); consider Term Sheet (.50); consider applicability of Side B and C (.50); draft memorandum to B. Balogh and revise and finalize memorandum (1.0); Reviewing and responding to email correspondence re order recognizing final US orders; Conversation with John Blount re D&O issue (.4); revising term sheet and order re D&O settlement (.3); conversation with Barry Wadsworth re D&O settlement (.4); correspondence with Adam Harris and Joe Latham resettlement terms (.3); correspondence with Steven Golick resettlement terms (.3). Review US and Canadian law rc: validity of limiting liabili ty to policy coverage afforded; Translating French letter to English; Further attendances re ASCI Axis provincial filings (0.5); attendances re Canadian real estate/liens (0.2); update re D&O Settlement (0.3) Conversation with Steven Golick re D&O settlement (.4); conversation with Alex Rose re D&O settlement and security review (.4). Reviewing in detail the Insurance Act (Alberta) (1.50); researching case commentary re: effect on policy coverage of non-payment of deductible (.50); review of standard Alberta auto policy and general statutory provisions (1.0); Communications A. Kim!J. Starn re fee application (0.3); emaiJs re Nova Scotia agent retainer (0.3); communications with C. Reagh/C. Daniel re same (0.4); finalize certain /Ws/ASC corporate filings (0.5);updates resettlement/proposal (0.2); Telephone call with C. Eustace and J. Starn re fee application (0.30); correspondence with C. Eustace and C. Reagh re Nova Scotia counsel's fees (0.30); correspondence with US counsel re retention ofNova Scotia counsel and compensation of fees (0.40); reviewing fee application for month of June and relevant invoice (0.80); correspondence with K. Parent re fee application (0.30); reviewing and considering letter received from Regie du Quebec rc pension liabilities and affidavit of J. Blount re D&O motion (0. 70); Office conference with A. Kim regarding the preparation of the first fee application for filing with the Delaware Court (.30); beginning review of materials for revising and finalizing same (.10) terms: due upon receipt Interest at th& rate of 1.3% per annum will be charged on au amounts not paid within one month from the date of this Invoice errors and omissions excluded p11Co4ol9 gowlings Date Hours Timekeeper 16/08/2012 1.30 Jennifer Starn 17/08/2012 0.80 Nadia Conforti 17/08/2012 0.30 Chris J. Eustace 17/08/2012 1.00 Ava Kim 17/08/2012 0.50 Jason R. McMurtrie 17/08/2012 3.30 Katie Parent 17/08/2012 0.90 Jennifer Starn 20/08/2012 0.50 Cbris J. Eustace 20/08/2012 0.80 Ava Kim 20/08/2012 0.30 Katie Parent 20/08/2012 0.20 Cliff Prophet 21/08/2012 2.50 Paul Dempsey Description September 21, 20 12 INVOICE: 17562496 Conversation with Joe Latham re settlement proposal (.5); revising draft settlement documents per conversation with Joe Latham (.6); correspondence resettlement documents with John Blount and Ezra Cohen (.2). Researching and drafting memo re: insurance coverage effected by non-payment of deductible; Further communications resettlement order and related matters (0.3); Conferring with K. Parent re fee application for month of June (0.30); correspondence regarding same (0.30); reviewing docketing guidelines (0.40); Speaking and meeting with K. Parent regarding transition of fi Ie and status. Office conference with J. McMurtrie regarding status of file (.50); reviewing and considering memorandum from C. Eustace dated June 18,2012 regarding docketing procedures for Allied matters (.20); reviewing and considering the draft first fee application (.70); reviewing June account for compliance with Delaware Court docketing procedures in advance of revising and finalizing first monthly fee application (1.0); office conference with A. Kim regarding fee application (.30); drafting and revising email to professionals team regarding corrections required for June invoice prior to submitting accounts with the fee application (.30); correspondence with Finance department regarding invoice procedures (.30). Conference call with Ezra Cohen and John Blount re Allied Settlement Order and insurance issues (.7); correspondence re settlement (.2). Email from Cade Daniel re Allied list of real property owned or leased as of April 2012 and attendances thereto (0.5); Internal discussion with K. Parent re preparation of monthly fcc applications for June and July (0.20); email to C. Eustace re June and July invoices and preparation of fee applications (0.40); internal discussion with C. Prophet re Quebec registered pensions (0.20); Telephone conference with C. Eustace assistant regarding the preparation of pre-bills and invoices for fee applications (.10); office conference with A. Kim regarding same and email to professionals regarding docketing procedures (.20); Instructions to A. Kim re issues concerning characterization of multi-employer pension plan with employees in Quebec; Telephone call between P. Dempsey and C. Prophet regarding Quebec rules regarding MEPP funding upon withdrawal of employer (.80); research Quebec rules regarding MEPP funding (1.70); terms: due upon roc:olpt Interest at the rate or 1.3% per annum will bo '1\arged on all anwunts not paid within one month from the date or Ulls lnvok:e errors and omissions ex,luded pege 6of 9 gowlings September 21, 2012 INVOICE: 17562496 Date Hours Timekeeper Description 21/08/2012 0.70 Chris J. Eustace Emails from Ava Kim re Gowlings billings and review same (0.5); discuss re fee applications and K. Parent requests (0.2); 21/08/2012 3.10 Ava Kim Internal discussion with C. Prophet re Quebec registered pension plans and claim of Regie des Rentes du Quebec (0.50); reviewing letter and correspondence received ti'om the Regie and considering implications ( 1.50); reviewing draft bargaining employee term sheet and corresponding order ( 1.10); 21/08/2012 0.80 Cliff Prophet Instructions concerning response to letter from lawyers for Regie des Rents re characterization of pension plans; 22/08/2012 0.20 Chris J. Eustace Further attendances re Gowlings fee application (0.2) 22/08/2012 1.20 Ava Kim Correspondence re retention affidavit of Nova Scotia counsel (0.20); reviewing and revising retention affidavit of Nova Scotia counsel (0.70); correspondence re Gowlings fee applications for June and July (0.30); 24/08/2012 3.40 Ava Kim Revising June and July invoice docket entries for attachment to fee application (1.90); discussions with C. Prophet and P. Dempsey reapplication of Quebec Supplemental Pension Plan Act pursuant to claim of the Regie des Rentes du Quebec (0.30); verifying jurisdiction of registration of Allied's pension plans (1.20); 24/08/2012 0.50 Katie Parent Correspondence with A. Kim regarding revisions to June and July pre-bills for inclusion in June fee application (.10); revising email and circulating same to professionals regarding docketing procedures and guidelines (.30); correspondence with C. Jasper regarding revisions to be made to June and July pre-bill narratives (.1 0); 27/08/2012 0.60 Katie Parent Correspondence with C. Jasper regarding pre-bill narrative revisions for fee application (.1 0); revising pre-bill narratives for fee application (.SO); 29/08/2012 0.30 Chris J. Eustace Review correspondence A. Kim re pension matter (0.3); 29/0812012 3.70 Ava Kim Reviewing and considering relevant pension leg1slation in Canada and Quebec re pension plans registered with the Regie des Rentcs du Quebec (2.1 0); preparation of response letter to Regie (1.60); 29/08/2012 3.00 Katie Parent Revising and updating pre-bill narratives for compliance with Delaware Court guidelines for fee applications (2.5); correspondence to A Kim regarding outstanding revisions(.30); follow up with professionals regarding outstnnding revisions (.10); telephone conference with C. Eustace regarding fee application (.10} 29/08/2012 0.30 Jennifer Starn Correspondence with Joe Latham and others re D&O settlement (.3). 30/0812012 0.40 Chris J. Eustace Updates from J. Slam re various updates (0.4) 30/08/2012 2.70 Katie J>arent Revising July pre-bill narratives for compliance with Delaware court guidelines ( 1.20); correspondence with C. Jasper regarding terms: due upon receipt Interest ot the rate of 1.3% per onnum will be charged on all amounts not paid within one month from the dotu of this Invoice orrol6 and omissions uxcludcd page6of9
Date Hours 30/08/2012 1.30 31/08/2012 1.00 31108/2012 5.60 Timekeeper Jennifer Stam Chris J. Eustace Katie Parent Description September 21, 2012 INVOICE: 17562496 pn:bills (.1 0); correspondence with A. Kim regarding ftrst monthly fee application (.20); reviewing and finalizing June pre- bill for fee application (.40); reviewing draft offtrst monthly fee application (.30); revising same (.50); Conference call with Joe Latham and Ezra Cohen re Black Diamond concerns on union proposal (.5); follow up correspondence to counsel to the committee re same (.3); conference call with Scott Macaulay and Mitch Vininsky re status of proceedings and sale process (.5). Receipt from K. Parent and review draft Fee Application ( 1.0); Revising and finalizing the first monthly fee application (5.40); correspondence with A. Kim regarding same (.l 0); circulating fee application to C. Eustace, J. Starn and A. Kim for review and comment (. 10); Total Fees for Professional Services $57.078.00 SUMMARY OF FEES TK# TKName 9427 Balogh, Boyd 9065 Christie, Hugh A. 497l Conforti, Nadia 3486 Dempsey, Paul 8275 Enquist, Lauren 2260 Eustace, Chris 3292 Gray, Heather M. 4180 Kim, Ava 4920 McMurtrie, Jason R. 8438 Parent, Katie 1892 Prophet, Cliff 4058 Snyder, Ronald M. 8712 Starn, Jennifer Totals Billed Rate 650.00 760.00 170.00 790.00 225.00 725.00 525.00 370.00 375.00 300.00 750.00 370.00 640.00 DISBURSEMENTS Non-Taxable Costs 22/08/2012 Filing of Annual Return - Agency VENDOR: Field LLP; INVOICE#: 90211-l/2011A; DATE: 08/22/2012 - T927136- Nortwest Territories Agent Account - tenns: due upon receipt Hours 3.20 1.90 3.80 2.50 0.60 20.10 6.00 28.70 0.50 16.40 2.00 5.30 21.70 112.70 Interest at the rate of 1.3% per annum will be charged on oil amounts not paid withi n one month from tho date of this lnvolee errors and omissions excluded Amount 2,080.00 1,444.00 646.00 1,975.00 135.00 14,572.50 3,150.00 10,619.00 187.50 4,920.00 1,500.00 1,961.00 13,888.00
$100.00 gowlings Taxable Costs Copying Scanning Service Allied Systems (Canada) Company - C. Craig Total Non-Taxable Disbursements Long Distance Telephone Binding Courier Courier- Fed Ex Office Supplies & Corporate Records Taxis - Local Travel Conferenc.e Call Expenses Quick Law: Research WestlaweCarswell 22/08/2012 Agent Fees- Taxable VENDOR: Field LLP; INVOICE#: 90211-l /2011A; DATE: 08/2212012 - T927136 - Nortwesl Territories Agent Account - Allied Systems (Canada) Company- C. Craig Total Taxable Disbursements terms: due upoo1 receipt September 21, 2012 INVOICE: 17562496 $100.00 $25.90 $4.20 $3.22 $45.40 $20.33 $38.03 $415.84 $82.99 $6.44 $121.17 $ 131.00 $255.50 $l.l50.02 Interest at the rate of 1.3% per annum will be charged on all amounts not paid within ono month from the date of this i nvoice errors and omissions excluded pege8of9 gowlings September 21, 20 12 INVOICE: 17562496 Remittance Copy Client: 104699 Allied Systems (Canada) Company T927136.25 Matter: RE: Amount Due: Restmcturing (Post Filing) $65,897.66 PAYMENT BY CHEQUE: Please return this page with your payment payable to Gowling Lafleur Henderson LLP Remit to: PAYMENT BY WIRE TRANSFER: Pay by Swift MT 103 Direct to: Gowling Lafleur Henderson LLP PO Box 466, STN D Ottawa, ON KIP 1C3 Canada SWIFTCODE: CIBCCATT BENEFICIARY BANK: Canadian Imperial Bank of Commerce 119 Sparks Street, Ottawa, ON KIP 585 TRANSIT NUMBER: 0010-00006 BThTEFICIARY ACCOUNT NAME: Gowling Lafleur Henderson LLP 160 Elgin Street, Suite 2600, Ottawa ,ON KIP l C3 BENEFICIARY ACCOUNT NUMBER(S): CDN Account: 41-02916 USD Account: 02-21015 International payments intermediary banking information: USD WELLS FARGO BANK, N.A. PNBPUS3NNYC (ABA 026005092) * if paying by wire or EFT please e-mail the remittance details to payments@gowlings.com terms: due upon rerelpt Interest at the rate of 1..3% per annum will be charged on all amounts not pnid within one month from the date of this invoice errors and omissions excluded pago9of9
/Debtors Motion for Entry of Interim and Final Orders Pursuant to 11 U.S.C. Sections 105, 361, 362, 363 and 507, Rules 2002, 4001, 9014 of the Federal Rules of Bankruptcy Procedure for an Order (1) Authorizing Use of Cash Collateral, (II) Granting Adequate Protection, (III) Modifying the Automatic Stay, and (IV) Scheduling a Final Hearing filed by Albert Togut on behalf of Dewey & LeBoeuf LLP. (Attachments: # (1) Pleading Declaration of Jonathan A. Mitchell In Support of Debtors Motion# (2) Exhibit 1: Proposed Interim Order# (3) Exhibit A: Budget)