ML020450367

Notice of First and Final Fee Application of Ajalat, Polley & Ayoob and Barton, Klugman & Oetting Llp, (Applications & Declarations of Tod V. Bebe and Mark Penskar in Support Thereof Filed Separately.)

ML020450367
Person / Time
Site:	Diablo Canyon
Issue date:	01/09/2002
From:	Beebe T Ajalat, Polley & Ayoob, Barton, Klugman & Oetting, LLP, Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923-DM, 94-0742640
Download: ML020450367 (3)

Text

1 CHARLES R. AJALAT - State Bar No. 49994 TERRY L, POLLEY - State Bar No. 58038 rC 2 RICHARD J. AYOOB - State Bar No. 81500 AJALAT, POLLEY & AYOOB, A Partnership 3 Including Professional Corporations 643 South Olive Street, Suite 200 4 Los Angeles, CA 90014-1685 Telephone No.: (213) 622-7400 5 Facsimile No. : (213) 622-4738 6 TOD V. BEEBE - State Bar No. 100265 BARTON, KLUGMAN & OETTING, LLP 7 333 South Grand Avenue, Suite 3700 Los Angeles, CA 90071 8 Telephone No.: (213) 621-4000 Facsimile No. : (213) 625-1832 9

Special Taxation Counsel for Pacific Gas and 10 Electric Company, Debtor and Debtor in Possession 11 12 UNITED STATES BANKRUPTCY COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 SAN FRANCISCO DIVISION 15 16 In re Case No.: No. 01-30923-DM 17 PACIFIC GAS AND ELECTRIC Chapter 11 Case 18 COMPANY, a California corporation, NOTICE OF FIRST AND FINAL Debtor. FEE APPLICATION OF 19 Federal I.D. No. 94-0742640 AJALAT, POLLEY & AYOOB 20 AND BARTON, KLUGMAN &

OETTING LLP 21 22 [APPLICATIONS AND DECLARATIONS OF TOD V.

23, BEEBE AND MARK PENSKAR IN SUPPORT THEREOF FILED 24 SEPARATELY]

25 Hearing Date: February 26, 2002 26 Time: 9:30 a.m.

Place: 235 Pine Street, 2 2nd Floor 27 San Francisco, CA 28 WXWnnReehe\nidee S.......... nffinnt fee nn.dnt 4N JLT PLE Y N Wod-ReNOTICE OfeinF "IS IA E PLIAINO NOIEOF F]tSrT*D FINAL FEE APPLICATION OF AJALAT, POLLEY & AOBAND BARTON, KLUGMAN & OETTIijq LLP 24 ~0

1 2 PLEASE TAKE NOTICE that on February 26,2002, at 9:30 a.m., or as soon 3 thereafter as the matter may be heard, in the courtroom of the Honorable Dennis Montali, 4 located at 235 Pine Street, 2 2 nd Floor, San Francisco, California, Special Taxation 5 Counsel for the Debtor, the firms of Ajalat, Polley & Ayoob and Barton, Klugman &

6 Oetting LLP will and hereby do make application to the court for approval of their First 7 and Final Fee Application for services performed on behalf of the Debtor.

8 Ajalat, Polley & Ayoob and Barton, Klugman & Oetting LLP were engaged both 9 pre-petition and post-petition to prosecute certain litigation against the City and County 10 of San Francisco regarding the constitutionality of its business tax system. That litigation 11 has now been resolved in a settlement, approved by the court, under which the City and 12 County of San Francisco paid the Debtor in excess of $11,000,000. Pursuant to the terms 13 of the retainer agreement between the Debtor and Ajalat, Polley & Ayoob, that firm is 14 entitled to a final payment of contingent attorneys' fees in the amount of $124,599. The 15 Applicants also request final approval of interim attorneys' fees and costs paid pursuant 16 to the court's Order of August 16, 2001 totaling $35,109.99.

17 PLEASE TAKE FURTHER NOTICE that pursuant to Rule 9014-1(b)(2) of the 18 Bankruptcy Local Rules of the United States District Court for the Northern District of 19 California, any opposition to the application must be filed with the Bankruptcy Court and 20 served upon appropriate parties (including Ajalat, Polley & Ayoob and Barton, Klugman 21 & Oetting LLP) at least seven days prior to the scheduled hearing date. If there is no 22 timely objection to the Application, the court may enter an order approving the 23 Application without further hearing.

24 Copies of the Application, the Declarations of Tod V. Beebe and Mark Penskar in 25 support thereof may be obtained from Ajalat, Polley & Ayoob and Barton, Klugman &

26 Oetting LLP in one of the following two ways: (1) e-mail your request to 27 tbeebe(,bkolaw.com, in which event copies of such pleadings shall be transmitted to you 28 WA:Workdnj%%eebe, k of Wiafe ap,.da I'4LUIIJL_ ' }ri.*i AI'U) 'II*AL ILL, A~rLItAIIJuN UI' AJALAIrLjLLI

• Ax ULPýf ANl BARTON, KLUGMAN & OETTING LLP

1 via e-mail at the e-mail address specified in your e-mail (or, if you do not expressly 2 specify an e-mail address, then via a reply e-mail to your e-mail); or (2) fax your request 3 to Tod V. Beebe at (213) 625-1832, in which event such pleading shall be faxed to you at 4 the fax number you specify.

5 Dated: January In 2002.

6 AJALAT, POLLEY & AYOOB BARTON, KLUGMAN & OETTING LLP 7

By Z 8

9 Tod V. Beebe, A ProfessionalCorporation Special Taxation Counsel for PACIFIC GAS &

10 ELECTRIC COMPANY, Debtor and Debtor in Possession 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 W-WorUn-N-ý of fiW fee dot NOTICE OF FIRST AND FINAL FEE APPLICATION OF AJALAT, POLLEY & AYOOB AND

-3 BARTON, KLUGMAN & OETTING LLP