ML023110111

Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for September 1 Through September 30, 2002

ML023110111
Person / Time
Site:	Diablo Canyon
Issue date:	11/07/2002
From:	Rosenthal J Official Committee of Unsecured Creditors, Saybrook Capital
To:	Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923 DM, 94-0742640
Download: ML023110111 (4)

Text

JONP. SCHOTZ JONATHAN Y. THOMAS 2 JONATHAN ROSENTHAL.

JEFFREY M. WILSON 3 SAYBROOK CAPITAL, LLC "

401 Wilshire Blvd, Suite 850 Santa Monica,'CA 90401'

• Telephone: 310/899-9200

".5 Facsimile: 310/899-9101 Financial Advisors for Official Committee of Unsecured Creditors

-7

-UNITED STATES BANKRUPTCY COURT-9 __NORTHERN-DISTRICT-OF-CALIFOR}TIA 10 SAN FRANCISCO DIVISION 11 In re: . Case No..01-30923 DM 12 'PACIFIC GAS AND ELECTRIC Chaptier 1 1'Cash COMPANY, a California corporation, .

13 14 15 Federal I.D. No. 94-0742640 .

16 SAYBROOK CAPITAL, LLC COVER SHEET APPLICATION 17 -FOR ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION AND "REIMBURSEMENT OF EXPENSES FOR SEPTEMBER 1 THROUGH 18 -SEPTEMBER 30,2002,,,.,

19 20 Saybrook Capital, LLC (the "Firm") submits its Cover Sheet Application (the 21 "Application") for Allowance and Paymennfof InterinCo-_mpensatiosn and Reimbursement of Expenses for the Period September 1, 2002through September 30, 2002 (the "Application 22 ExessfrtePeriod"Spebr1,20)hoghSpebr30 02(h "plcto 23 In support of the Application, the Firm respectfully represents as follows:,

24 t *-:The Firmis a fiancial'advisorio the " ued ,-itors of Pacific Gas and S-. . . .- .- ' L. * .

25 Electric Company, debtor and d6btor-i -pbssession in the Aabove-referenced bankruptcy cdase 26 (the "Debtor"). The Firm hereby applies to the Court for allowance and payment of interim 27 compensation for services rendered and reimbursement of ekipns s-iiicufred'dtuiring ihe 28 Application Period. ' -

0,b' ON

1 2. The Firm billed a total of $217,111.90 in fees and expenses during the 2 Application Period. The Firm entered into an Engagement-Agreement covering the 3 Application Period (the "Agreement") with the Official Committee of Unsecured Creditors of 4 Pacific Gas and Electric Company (the "Committee"). The Agreement calls for a monthly 5 fee of $250,000.00 for the first six (6) months of the Engagement Period and a monthly fee of 6 $200,000.00 for each month of the engagement after, plus reimbursement of actual out-of 7 pocket expenses. The total fees incurred September 1 through September 30, 2002 represent 8 1 month of the monthly engagement during the Application Period. These fees and expenses 9 break down as follows:  :... . ..

10 11 Period Fees Expenses Total 12 September 1 - September 31 $200,000.00 $17,111.90 $217,111.90 13

3. Accordingly, the Firm seeks allowance of interim compensation in the total 14 amount of$187,111.90 at this time. This total is comprised as follows:

15

$170,000.00 (85%of the fees for services rendere'd)l 16

$ 17,111.90 (100%o ofthie exp'enses inýur-red).

17 4: With regard to the copies of this' A1phcation ferved on counsel for the 18 Committee, counsel for the Debtor and the Office of the'Unitedf States Trustee, attached as 19 Exhibit I hereto is the nmine of each professional who performed services in connection with

20. this base during theperiod covered by thin Appiicatidn -anda iiaratie su'mmarzingthe work 21 of each professional; and (b) attaclied as'Exiibit2 are tfiede't'iled expense siateiments'for the 22 Application' Periodthat comply with all, Northerri District ýrf California Bankruptcy'Local 23 Rules' and Compensatfi'n Guidelines and the Guidelines of theOffice of the United States 24.

Trustee.

25,

5. The Firm has'served a copy of this Applidation (without Exhibits) on the 26 27

'Payment of this amount would result in a "holdback" of $30,000.00 28 1 Special Notice List in this case:.- -. -- '.

2 ,6. 1Pursuant tb this Court's "SECOND AMENDED ORDER ESTABLISHING 3, INTERIM FEE APPLICATION AND EXPENSE kEIMBUtRSEMENT PROCEDURE'

4. which was entered on or about March 18,:2002, the"D'&bto" is authorized t6 make the payment 5 requested herein without a further hearing or order of this Court unless an objection to this 6 Application is filed with the Court by the Debtor, the Committee or the United States Trustee 7 and served by the fifteenth iday of the month following the service of this Application! if such

--- 8 "anobjection is filed, Debioris authorized to pay the amounts, if any, not subject to the 9 .objection. _The-Firm is informed and.believes that-this Cover Sheet-Application was mailed-10 by overnight mail on or about October 30, 2002.

11 7. The interim compensation and reimbursement of expenses sought in this 12 Application is on account and is not final. Upon the conclusion of this case, the Firm will 13 seek fees and reimbursement of the expenses incurred for the totality of the services rendered 14 in the case. Any interim fees or reimbursement of expenses approved by this Court and 15 received by the Firm will be credited against such final fees and expenses as may be allowed 16 by this Court. ,

17 8. The Firm represents and warrants that its ,billing practices comply with all 18, Northern District of California BankruptcyLocal Rules and Compensation Guidelines and 19 the Guidelines of the Office ofthe United States Trustee. Neither the Firm nor any members 120 of the Firm Jhas any agreement or understanding of any kind or nature to divide, pay over or

, 21 share any poition of the fees or expenses to be awarded to0,he,Firmn with any other personi or 22 attorney except as among the members and associates of the Firm.

23 24 25 26 I

27 28 1 WHEREFORE, the Firm respectfully requests that the Debtor pay compensation 2 to the Firm as requested herein pursuant to and in accordance with the terms of the 3 "SECOND AMENDED ORDER ESTABLISHING INTERIM FEE APPLICATION AND 4 EXPENSE REIMBURSEMENT PROCEDURE."

5 DATED:

6 SAYBROOK CAPITAL, LLC 7 f!,7 ý 8 B "- JONATHAN ROSENTHAL

-- 9 Financial Advisor for the Official Committee of 10 Unsecured Creditors of PACIFIC GAS AND ELECTRIC COMPANY 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28