ML023180568
| ML023180568 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/31/2002 |
| From: | Lumsden T Official Committee of Unsecured Creditors |
| To: | Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California |
| References | |
| 01-30923 DM, 94-0742640 | |
| Download: ML023180568 (26) | |
Text
ThomasLumsden-FTI Consulting Inc.
199Fremont Street-"
San Francisco, CA 94105 Telephone:
(415) 498-5000 Facsimile:
(415) 498-6699 Accountants and Financial Advisors-for Official Committee of Unsecured Creditors OCT z~o t IMtt spýýPT 1
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-In re PACIFIC GAS AND I COMPANY, a Califor Dc UNITED STATES BANKRUPTCY COURT
-NORTHERN DISTRICT OF, CALIFORNIA' SAN FRANCISCO DIVISION-'
Case No. 01-30923 DM
- LECTRIC Chapter 11 Case nia corporation,
[No*He-1arifig Scheduled]
ebtor.
Federal I.D. No. 94-0742640 FTI CONSULTING INC. COVER SHEET 'APPLICATION FOR ALLOWANCE AND
-PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SEPTEMBER 1, 2002 TO SEPTEMBER 30, 2002 FTI Consulting, (the "Firm"), submits its Cover Sheet Application (the "Application")
for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period September 1, 2002 to September 30, 2002 (the "Application Period"). In support of the Application, the Firm respectfully represents as follows:
.1.,
The Firm serves as Accountants and Financial Advisors to the Official
,Committee of Unsecured Creditors. The Firm submitted an Application for appointment as Accountants and Financial Advisors to the Official Committee of Unsecured Creditors on September 27, 2002. An Order for Appointment of the Firm as Accountants and Financial Advisors to the Official Committee of Unsecured Creditors is pending. The Firm hereby applies to the Court forfallowance and tiaymefit of interim compensation for services WD 071701/1-1419903/42/931767/vl KibL0 r**
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56VI2
rendered and reimbursement of expenses incurred during the Application Period.
- 2.
The Firm billed a total of $99,400 in fees and expenses during the Application Period. The Total fees represent 246.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />'expended during the Application Period. These fees and expenses break down as follows:
1 2
3 4
5 6
8 9
10 11 12 13 3.,
Accordingly, the Finnfseeks allowance of interim compensation in the total amount of $84,985 at this time., This total is comprised as follows:
$81,682 (85% of the fees for services rendered)' plus $3,303 (100% of the expenses T,
incurred).
- 4.
For the post-petition period, the Firm hi*s been Ipaid to date as follows:
Application Period Amount Description
-Amount Paid AppliedFor First (April 11, 2001'-
$8 3;642
,90%
of fees and
$803,642 May 31,2001) 100% of expenses Second (June 1, 200-
$870,002-90/o of fees and
'- -$870,002 July 31, 2001)'-
100% of expenses First Interim Fee
$2,408 10% fee holdback ($179,012) net
$2,408 Application ofPricewaterhouseCoojpers LLP and Court Adjustmneifs ($176,604)
Third (AuIgust 12001'-
'$358,024" 85% of fees and
$358,024 August 30, 2001)
A 100% of expenses
'Payment of this amount would result in a "holdback" of $14,415
- 'D 071701/l-1 4 19903/42/931767/vl -
II Period "
Fees Expenses Total September 1, 2001 -
$96,097
$3,303
$99,400 September 30, 2002.
14 15 16 17 18 19 20 21 22 23 24 25 26 27 "28 A
l
1 2
3 4
5 6
. 7 8'_
9 10 11 12 13 14 15 16 17 18 19 20 21, 22 23 24 25 26 27 28
.. -, I-WD 071701/1-1419903/42/931767/vl Fourth (September 1,
$293,871-85% of fees and
$293,871 2001-September 30;--.
100% of expenses 2001)
Fifth (October 1,2001
$307;809:.
85% of fees ad
$307,809 October 31, 2001) 100%of expenses Sixth(November
$215,596 85% offees and.
$215,596 120 1
-Novembe 1,2001-Noember 100% of expenses 2001)
Second Interim Fee
$145,54.
15% fee holdback ($198,105) net
$145,541 Application of Pric waferhouseCoopers LLP adjustments ($52,564)
Seventh (December 1,-
$192,887
-85%'of fees and,'
$192,887 2001-December 31, 100% of expenses 2001)
Eight (January 1, 2002-2. $223,013 85% of fees and
$223,013 a'Jnuary31,2002)
-I G O0%-fexpense"'
Ninth (February 1, 2002
$197,888 85% of fees and
$197,888
-'February 28, 2002) 100% of expeises Tenth (Marchl, 2002-
$189,814 85% of fees and V0
$189,814 March31, 2002) 100% of expenses Third Interim Fee
--...... $114;300 :-
15% fee holdback ($128,506)_net
$114)300 Application.
of PricewaterhouseCoopers LLP Write-offs ($3,705) -and expense 9
- i-djustments ($10,500)"
Eleventh_(April 1 2002
-$185,003i 85%'offees and,-,'
$185,003
-April 30,2002),
100%ofexpenses
- 1 2
3 4
5 6
'7 8
9'
-'10 11 12 13 14 15 17 S 18
-19 20 21 22 23 24 25 26 27 28 Twelfth (May 1, 2002
$183,784 85% of fees and
$183,784 May31, 2002) 100%of expenses
_______+___
Thirteenth (June 1, 2002
$81,860 85% of fees and
$81,860
-June 30, 2002) 100% of expenses Fourteenth (July 1, 2002- $204,553, 85% of fees and
$204,553
-July 31, 2002)
J 100%'of expenses Fifteenth (August 1,
$127,849:;r*
85% of fees and M.
,$127,849 2002 - August 3 1, 100% of expenses 2002)
Total Paid to the
$4,697,844,,
$4,697,844 Firm to Date
- 5.
To date, the Firm is owed as -follows (excluding amounts owed pursu'ant to this Application).
" +
Application Period A.
ount Descriptioi" Fourth Interim (April -1, 2002 -July 31,
$109,606 4 15% fee holdbacli 2002)
+
-4
+
Fifteenth (August 1, 2002 - August 31;
$21,147 5 615%
fee holdback 2002)
Total Owed to Firm to Date
$130,753
.6.
With regard to the copies of this Application served on counselTor the Committee, counsel for the Debtor and the Office of the United States Trustee, atta~hed as Exhibit 1 -hereto is the'name of each professional who performed services in connection with this' case during the period covered :by this Application and the hourly rate for each such
-I professional; and (b) attached as Exhibits 2-1 +and-2-2 are the detailed time and expense statements for the Application Period that comply with all Northern District of California Bankruptcy Local Rules and Compensation Guidelines and the Guidelines of the Office of
-.1 WD 071701/1-1419903/42/931767/v 4,-
4 a
. 4' -
_(.
, I,
4 2
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5 6
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9 10 11 12 13 14 16 17 18 19 20 21 22
-23 24 25 26 27 28 WD 071701/1-1 4 19903/ 42/931767/vi
'the United States Trustee.'
-7:
The Firm has Served a copy of this Apjlication (without Exhibits) on the Special Notice List in this c.ase.
- 8.
Pursuant to this Court's 'ORDER ESTABLISHING INTERIM FEE' APPLICATION AND EXPENSE REIMBURSEMENT PROCEDURE" which was entered on or about July 26, 2001, the Debtor.is authorized to make the payment requested herein without a further hearing or order of Utis Court unless an objection to this Applicatiodis
-filed -with the Court by'the Debtor, the Committee or the United States Trustee and served by the fifteenth day of the month following the service of this Application. If such an objection is filed, Debtor is authorized to pay the amounts, if any, not subject to the objection. The Firm is informed and believes that this Cover Sheet Application was mailed by first class mail, postage prepaid, on or about October 31, 2002.
- 9.
The interim compensation and reimbursement of expenses sought in this Application is on account and is not final. Upon the conclusion of this case, the Firm will seek fees and reimbursement of the expensds incurred for the totality of the services rendered in the case. Any interim fees or reimbursement of expenses approved by this Court and received by the Firm will be credited against such final fees and expenses as may be allowed by this Court.
- 10.
The Firm represents and warrants that its billing practices comply'with' all Northern District of California Bankruptcy Local Rules and Compensation Guidelinies and the Guidelines of the Office of the United States Trustee. Neither the Firm nor any members of the Firm has any agreement or understanding of any kind or nature to divide, pay over or "share any portion of the fees or expenses to be awarded to the Firm with any other person or attorney except as among the members and associates of the Firm.
/d/
III WHEREFORE, the Firm respectfully requests that the Debtor pay compensation to the Firm as requested herein pursuant to and in accordance with the terms of the 'ORDER ESTABLISHING INTERIM FEE APPLICATION AND EXPENSE REIMBURSEMENT PROCEDURE."
Dated: October 31, 2002 FTI Consulting Inc.
1 2
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 By Thomas E. Lumsden, Senior Managing Director' WD 071701/1-1419903/421931767/vl
.9%
Exhibit I Professional Ho, Rocky Wking, Floris Kitchin, Jennifer Lumsden, Tom Perfit,'Ryan Reiss, Freddie Sin, Theresa" Young, Allison Tota
.Pacific Gas and Electric Summary-of Time'By Professional For the Period September 1,'2002 Through September 30, 2002 Title i
Time Total Billing Rate Director 46.0 475 Associate 4.5 250 Manager 17.4 425 Partner 35.4 595
-* Associate 22.5 215'
'Partner 14.7 595 Associate 40.4 185 Manager 65.9 425 Is 246.8 Fee Total
-$21,850
$1,305
$6,438
$21,063
'$4,838
-$8,747
$7,474
$24,383
$96,097' Page I of)
Exhibit 2 Pacific Gas and Electric Summary of Time By Task Code September 1, 2002 through September 30, 2002 Task Code Asset Sales/Valuation Issues Bankruptcy Reporting/Operations Cash Flow Analysis Claims Analysis Coordinating with Debtor CPUC Plan of Reorganization CPUC Review DWR Contracts/Analysis Executory Contracts (QF)
Fee Application FERC Review Financial Statement Modeling General Committee Matters Legislative Review OCC Plan of Reorganization Plan of Reorganization/Negotiations Professional Compensation Matters Subcommittee Matters Totals Time Total 0.6 23.4 1.0 4.9 0.5 18.1 29.5 35.8 5.4 58.1 1.8 2.7 17.6 1.0 11.6 2.8 21.6 10.4 246.8 Fee Total
$357
$11,645
$475
$2,328
$185
$10,144
$11,201
$10,853
$2,565
$16,355
$1,071
$999
$7,622
$595
$4,555
$1,534
$7,968
$5,648
$96,097 Page I of I
Exhibit 2-1 Pacific Gas and Electric Time Reporting Detail Reporting by Task Code September 1, 2002 through September 30, 2002 Professional Date Hours Billing Rate Fees Description Task Code:
Asset Sales/Valuation Issues Lumsden, Tomn SubTotal:
Lumsden, Tom
/2712002 06
$595
,06
$357.00 Discussions with potential acquirers of PG&E assets on alternate structure or funding of Joint Plan.
$357.00 1
1, %-
Total: Asset SaleslValuation Issue 0.6 Task Code:
Bankruptcy Reporting/Operations
-9/3/2002
.0.8,
$475 91312002 0.9
$475 9/3/2002 1.1
$475 Ho, Rocky 9/4/2002 1.4 - -
$475 9/11/2002 24
$475
$380.00 Review and analyze joint motion of CPUC/OCc proposed order shortening time frame for hearing.
$427.50 Review supporting declarations of Lance Maeda. My Nguyen and Eric Kirkpatrick in support of authority to
-incur misc implementation expenses.
$522.50 Review and analyze notice of motion and motion for
'authority to incur miscellaneous Implementation expenses; memorandum of points and authorities in S....
support thereof....
$665 00 Review support'frorm debtor for the proposed Metcalf Fourth 230/115 Transformer project re: cost "recovery and regulatory issues.
$1,140 00 Review CPUC TRO papers for injunctive relief:.
against PG&E disseminating false information during the solicitation process.
9116/2002 1.1
"$475....
$522 50 - Review objections from certain financial creditors to the re-solicitation motion of the joint CPUC I OCC plan.
'9116/2002 1.7,
9/16/2002 1.3
$475
$475 9/20/2002 1.1
$475
$807.50 Review various declarations (Sullivan, Novak, '
Lafferty and Kelly) In support of debtor's opposition to the re-solicitation of votes.
$617.50 Review and analyze debtors opposition to joint "motion of CPUC/OCC for order authorizing the re solicitation of votes and preferences for Movants' amended plan of reorganization.
$522.50 Prepare for hearing on re-solicitation motions and various other issues:*
9/20/2002 3.4
$475
$1,615 00. Attend court heanng on re-solicitation motion.
9/23/2002 2.1
$475
$997.50 Review the 9th Circuit Opinion in SCE v. Lynch - and the certification questions as submitted to the the CA Supreme Court.
Wednesday, October 30,'2002 Ho, Rocky
$357.00 Ho, Rocky Ho, Rocky Ho, Rocky Ho, Rocky H6, Rocky Ho, Rocky Ho, Rocky Ho, Rocky Ho, Rocky Piage I of.14
Professional Da SubTotal:
Ho, Rocky Kitchin, Jennifer Kitchin, Jennifer 9/
SubTotal:
Kitchin, Jennifer Lumsden, Tom Lumsden, Tom te Hours Billing Rate 17.3 9/3/2002 03
$370
'2512002 06
$370 9113/20 9/24120 SubTotal:
Lumsden, Tom Reiss, Freddie Reiss, Freddie SubTotal:
- Reiss, Total: Bankruptcy Task Code:
Ho, Rocky SubTotal:
HO, Rocky Total: Cash Flow Analysis 9/20/20 9/23120 0.9 02 0.4
$595 02 1.2
$595 1.6 02 2.1
$595 02 15
$595 5
I I
Task Code:
Claims Analysis 9/3/2002 1.3
$475 9/3/2002 0 8
$475 9/4/2002 0 5
$475 9/4/2002 09
$475
$617.50 Review and analyze notice of motion and motion of Pacific Gas & Electric Company for an order authorizing assumption of power agreements and compromise of claims with Sierra Pacific Industries.
$380 00 Review and analyze declaration of Charles R.
Middlekauff in support of order authorizing assumption of power agreements and compromise of claims with Sierra Pacific Industries.
$237.50 Review and analyze declaration of David W. Philips in support of motion to refund certain project deposits.
$427.50 Review and analyze debtor's motion for order authorizing refund of certain project deposits.
Wednesday, October 30, 2002
, Freddie 3.6 Reporting/Opera 23.4 Cash Flow Analysis 9117/2002 1
$47 Ho, Rocky Ho, Rocky Ho, Rocky Ho. Rocky Page 2 of 14 Fees Description
$8,217.50
$111.00 Review industry article on case.
$222 00 Review memo re: 9th Circuit Rulings
$333.00
$238 00 Review motion by FG&E for Metcalf project approval.
$714.00 Review 9th Circuit court of appeals ruling on Turn appeal to SCE settlement.
$952.00
$1,249.50 Review objections to re-solicitation court hearing.
$892.50 Court ruling regarding Southern California Edison; updates regarding PG&E Plan.
$2,142.00
$11,644.50
$475.00 Discuss with debtor upcoming capex projects.
$475.00
$475.00
Date,
Hours Billing Ra'te 'Fees Decaiipton Ho, Rocky SubTotal:
Ho, Rocky Total: Clairms Analysis 9123/2002
' 1.4 4.9 I
- -. "4.9
$475
$665.00 Review and analyze debtors filed notice on various'-'
settlement of claims - (Standard Pacific Gas Line,
-.Allstate Insurance and Heinz).
$2,327.50
$2,327.50 Task Code:
'Coordinating with Debtor 9/11/2002 05
,$370
$185 00 Coordinate with PG&E on new data requests.
- $185 00
"$185 00 CPUC Plan of Reorganization 9113/2002 1.3
$475 9/16/2002 09
$475 9/23/2002 0.9
$475 9125/2002 0.8
$475 Kitchin, Jennifer 3.9
$617.50 Review draft of OCC Committee report re. co "proponent of plan to be sent out to creditors.
$427.50
'Review revised draft of OCC report letter re: joint "CPUCIOCC plan.
$427.50 Review revised financial projections of joint plan.
$380.00, Review counsel's draft on implications relating to the
-Turn appeals decision.
$ 1,8i52.0 91612002 0.2
$370.
$74 00,
-Review email re: UBS retention.
SubTotal: Kitchin, Jennifer 0.2 Lumsden, Tom 9/4/2002 0.3 Lumsden, Tom. -
=
,914/2002
.09,
Lumsden. Tom '.
9./42002
.2.!
-,. 9 2()02
..1 Lumsden, Tom
- 9/10/2002 "0.5 Lumsden, Tom
,9110/2002 0.3
$74.00
$595
$178.50 Review UBS engagement letter modifications
$595
$535.50, - Review CPUC and PG&E materials and filings on plan re-solicitation, read UBS letter and chart on employment.
$595
$1,249.60 Attend hearingin curt on plan re-solicitation and UBS retention, meet with P. Aronzon and discuss preemption issues and impact of appeal orders.
$595
$297.50 Review UBS engagement letter and edits to same for scope of work and fee structure,
$595
$178.50 Review re voting and re-solicitation.
Lumsden, Tom 9/11/2002
_.04
$595
$238 00 Review emails on solicitation challenges by CPUC from PG&E.
Wednesday, OctIber 30,2002 Young, Allison SubTotal: _Young, Allison,,
0.5 Total
Coordinating with Debtor Task Code:
Ho, Rocky Ho, Rocky Ho, Rocky Ho, Rocky SubTotal:
Ho. Rocky Professional
'Page 3 -of 14
Professional Date Hours Billing Rate Fees Description Lumsden, Tom Lumsden, Tom Lumsden, Tom Lumsden, Tom SubTotal:
Lumsden, Tom Reiss, Freddie Reiss, Freddie Reiss, Freddie Reiss, Freddie Reiss, Freddie SubTotal:
Reiss, Freddie Young, Allison SubTotal:
Young, Allison Total: CPUC Plan of Reorgz 9/13/2002 9/13/2002 9/23/2002 03 0.4 1.3
$595
$595
$595 1/30/2002 0.7
$595 7.2 9/4/2002 2
$595 9/6/2002 919/2002 9/10/2002 9/20/2002 09 1
$595
$595
$595 1.4
$595 63 919/2002 0.5
$370 0.5 nizatlo 18 1
$178 50 Review re bondholder group questions on Joint plan
$23800 Review motion by CPUC re vote re-solicitation.
$773.50 Review emails on UBS agreement, plan re solicitation, questions on plan structure and support for OCC modeling.
$41650 Review ratings of Moodys and Fitch on DWR bonds and impact on joint plan financing structure and market risk perception.
$4,284.00
$1,190 00 Additional review of Plan projections and CPUC plan update.
$535.50 Review UBS engagement.
$595 00 Review UBS letter, prepare for conference call.
$595 00 Review press release; update regarding UBS and plan issues.
$833 00 Listen in on CPUC court hearing.
$3,748 50
$18500 Review preliminary court filing on UBS retention.
$18500
$10,144.00 Task Code:
CPUC Review Ho, Rocky Ho, Rocky Ho, Rocky Ho, Rocky SubTotal:
Ho, Rocky Kitchin, Jennifer 9/10/2002 08
$475 9/13/2002 06
$475 9/13/2002 1.1
$475 9/17/2002 1.4
$475 39 9/16/2002 03
$370
$38000 Review CPUC memo on Direct Access charges response to various objections to the proposed surcharge methodology.
$285.00 Review debtor's proposed 2003 DWR revenue allocation methodology to the PUC
$522 50 Review and analyze CPUC's decision re: ISO disputed charges between PG&E and the PUC.
$665 00 Review motion on direct access fees and related issues - PG&E and SCE.
$1,852.50
$111.00 Review email correspondence re: CPUC regulatory proceedings.
Wednesday, October30, 2002 Description Professional Date,
Hours Billing Rate Fees Page 4ofl14
Professional Date Hours BillingRate
-Fees".
Description -
SubTotal:
Kitchin, Jennifer 0.3 Lumsden, Tom 9/18/2002 1.2
$595 Lumsden, Tom
" 9/19/2002' 1.7-
$595 Lumsden, Tom 9/26/2002 0.5
$595 Lumsden, Tom 9/26/2002-0.9
$595 -
Lumsden, Tom 9/27/2002 1.1
$595
- r Lumsden, Tom 9/30/2002 09
$595 Lumsden, Tom 9/30/2002 06
$595 SubTotal:
Lumsden, Tom 6.9 Reiss, Freddie 9/3/2002 2.5
$595 SubTotal: Reiss, Freddie 2.5 Sin, Theresa 9/9/2002 5.6.
. $185 Sin, Theresa 9/12/2002 2.5
$185 Sin, Theresa 9113/2002 4
$185 SubTotal:
Sin, Th*e*ia 12.1 Young, Allison 9/3/2002 0.7
$370 Young, Allison 91912002 1
$370 Young, Allison 9/10/2002 2.1
$370 SubTotal:
Young, Allison 3.8 "29.5 Total: CPUC Review
$111.00
$714.00 Review CPUC order on interim procurement of DWR net short for SCE and PG&E
$1,011.50 Continued review of commission staff analysis of net short procurement interim order.
$297.50,'
Discussions with G. Cohen re alternatives to 9th Circuit Court decision on plans for PG&E.'
$535.50 Read CPUC decision re GRC review and impact on, rates and return.
$654.50 Review CPUC decision re net short and IOU's purchasing with DWR dated 8-22-02
$535.50 Review CPUC materials and research net short purchasing options for PG&E.
$357.00 Telephone call with P. Douglas of CPUC re questions on URG segments of OCC model.
$4,105.50
$1,487.50 Read district court opinion on preemption; review final CPUC amendments
$1,487.50
$1,036.00 CPUC review, review update from CPUC proceedings Review contract allocation info. for workshop on Thursday.
$462.50 Attend workshop for contract allocation, review brief on Gottstein decision, review notes from hearing.
$740.00 Review and summarize CPUC filings. Review recent events from GRC proceeding.
$Z238.50
$25900 Review CPUC order on DWR contract allocations
... I between the State's 3 IOU's
$370 00 Review CPUC order on DWR contract allocation and try to tie with PwCs record of DWR contracts.
$777.00 Continue review of CPUC order to allocated DWR contracts and try to reconcile to CPUC data.
S$1,40600,)
$11,201.00, Task Code:
,DWRConitracts/Analysis Wednesday, Ociober 30, 2002 "Paged5if14 "
I
Professional Date Hours Billing Rate Fees Descruption Ho, Rocky 9/27/2002 SubTotal:
HO, Rocky Kitchin, Jennifer Kitchin, Jennifer Kitchin, Jennifer Kitchin, Jennifer Kitchin, Jennifer 1
$475 1
9/4/2002 3 3
$370 9/6/2002 9/6/2002 9/9/2002 9/10/2002 Kitchin, Jennifer 9/10/2002 Kitchin, Jennifer 9/12/2002 Kitchin, Jennifer 9/17/2002 SubTotal:
Kitchin, Jennifer Lumsden, Tom 9/3/2002 Lumsden, Tom 9/3/2002 Lumsden. Tom 9/13/2002 SubTotal:
Lumsden, Tom Perfit, Ryan 9/4/2002 Perfit, Ryan 9/5/2002 Perfit, Ryan 9/9/2002 Perfit, Ryan 9/13/2002 Perfit, Ryan 9/15/2002 Perfit, Ryan 9/16/2002 0.6 02 03 2.2 0.2 02 02
$370
$370
$370
$370
$370
$370
$370 72 06
$595 03 07
$595
$595 1.6 2.7
$215 31
$215 0.9
$215 0.8
$215 65
$215 1.1
$215 Wednesday, October 30, 2002
$475 00 Review S&P presentation on the proposed California bond sale.
$475.00
$1,221 00 Research DWR Contract Model adjustments based on CPUC 8/21 Interim Order re: DWR Contract Allocation.
$222.00 Discuss DWR Contract Allocation methodology.
$74.00 Review email re: CPUC DWR Revenue Requirement Workshop
$111 00 Discuss obtaining DWR information with P. Douglas at CPUC.
$814 00 Review DWR website for standard NDA and ref.
Navigant NDA re, applicability to latest DWR contract analyses.
$74 00 Call with P. Douglas at CPUC re* obtaining DWR Contract Analyses.
$74 00 Discuss conclusions from CPUC DWR Revenue Requirement Workshop.
$74.00 Call to MTHM re: DWR NDA to obtain information.
$Z,664 00
$357.00 Read materials on FERC proceedings on generator contracts and modifications for certain contracting parties to DWR. impact on DWR contract obligations and plan numbers.
$178 50 Review notices on FERC hearings in state power contracts.
$416.50 Review update of DWR Revenue Requirement and correspondence on structure for review.
$952.00
$580.50 Review the DWR Contract model and revise to include for contract assignment.
$666.50 Review and revise the DWR contract model.
$193.50 Review the DWR Contract model.
$172 00 Review and revise the DWR Contract model.
$1,397.50 Create a reconciliation of the DWR Contract model to the DWR contract totals.
$236 50 Revise the reconciliation of the DWR Contract model and the DWR contract totals.
Page 6 of 14 Professional Date Hours Billing Rate Fees Description
Irfsinl Dt or ihnRae Fe ecito SubTotal:
Perfit, Ryan 15.1 Sin, Theresa 9/1212002 T-2.8
$185 SubTotal:
Sin, Theresa 2.8 Young, Allison 9/3/2002 1.1
$370 Young, Allison 9/4/2002 1 8
$370 Young, Alison 9/512002.
1.2
$370 Young, Allison 9/6/2002 07
$370 Young, Allison 9111/2002 1 4
$370 Young, Allison 9/12/2002 0.7
$370 Young, Allison
-9/16/2002 1.2
$370 SubTotal:
Young, Allison Total: -DWR. Contracts/Analysis.,
358 Task Code:
Executory Contracts (QF)
Ho, Rocky 9/19/2002 1.2
$475 Ho, Rocky 9/23/2002
,. 2.1, -.
$475 Ho, Rocky 9124/2002 1.4
$475 Ho, Rocky 9/24/2002 0.7
$475 1
.SubTotal:
Ho, Rocky 5.4
5.4 Total
Executory Contracts (QF9 5.4 Task Code:
Fee Application Ho, Rocky 9/1312002 1.1
$475 Wednesday, October.YO, 2002
$3,246 50
$518 0)
Review FTr's D6A*R contracts model.
-$51800
$407.00--
Model PG&E's projected share of DWR costs based, on recent CPUC decision on direct allocation of DWR contracts.
$666.00 Review DWR contracts model to determine application of DWR contracts to PG&E.
$444 00 Continue review of DWR contracts model to determine costs to PG&E of CPUC order.
$259.00 Review model of DWR contract allocations to the Califomia IOUs.
$518.00 Analyze allocation of contract costs and volumes between the States 3 IOU's.
$259.00
- Review new information received from CPUC on DWR Contract allocations.
$444.00 Review DWR contract analysis and Impact of cash flows on OCC and PG&E PORs.
$2,997.00
$10,852.50,
$570.00-Review and analyze debtor's proposed Ridgewood agreement.
$997.50 Review and analyze Sunnyside stipulated agreement with debtor - cost recovery, junsdiction and other potential issues.
$665 00 Review and analyze stipulation and order authorizing compromise of claims with certain qualifying facilities and their assignee.
$332.50 Review stipulation between Sunnyside and debtor.
$2,565.00
$2,565.00
$522.50 Review draft and time detail exhibits re.4th interim fee application Page7 of 714
- Date Htours BilingRa'te De-s'&riptton_"'
"Fees Professional
Professional Date SubTotal:
Ho, Rocky king, Flons 9/30/200:
SubTotal:
Iking, Flons Lumsden, Tom 9/10/200:
Lumsden, Tom 9110/200, Lumsden, Tom 9113/200, Lumsden, Tom 9/13/200, SubTotal:
Lumsden, Tom Perfit, Ryan 9/4/2002 Perfit, Ryan 9/5/2002 Perfit, Ryan 9/5/2002 SubTotal:
Perfit, Ryan Sin, Theresa 9/6/2002 Sin, Theresa 9/13/2002 Sin, Theresa 9/23/2002 Sin, Theresa 9124/2002 Sin, Theresa 9/24/2002 Sin, Theresa 9/25/2002 Sin, Theresa 9125/2002 Sin, Theresa 9/26/2002 Sin, Theresa 9/27/2002 Sin, Theresa 9/3012002 Hours Billing Rate 1.1 2
1.7
$290 1.7 2
04
$595 0.3
$595 0.9
$595 1.7
$595 3.3 51
$215 1.1
$215 12
$215 74 36
$185 29
$185 08
$185 2.9
$185 1.3
$185 13
$185 1
$185 66
$185 1 5
$185 18
$185 Wednesday, October 30, 2002 Fees Description
$522.50
$493 00 Finalize and file Monthly Fee Application for August 2002.
$493.00
$238 00 Review fourth interim fee application for approval.
$178.50 Review fourth interim fee application.
$535 50 Sign and review exhibits to Interim fee application.
$1.011.50 Review fourth interim fee application and edits.
$1,963.50
$1,096 50 Accumulate time and expense for 4th Intenm fee application.
$236 50 Accumulate time and expense for 4th Interim fee application.
$258.00 Accumulate time and expense for 4th Interim fee application.
$1,591.00
$666.00 Review fee application exhibits for 4th Interim fee app.
$536 50 Prepare and file 4th Interim Fee application. Also create cover letter for Clara Strand Declaration.
$148 00 Review cover letter application for September, start time detail compilation.
$536.50 Compile exhibits for Sept cover letter application.
$240.50 Review time detail submitted for Sept. cover letter application.
$240 50 Create summary of professionals in multiple meetings.
$185.00 Review cover letter application for September fee application.
$1,221.00 Review time detail and expenses detail for adequate compliance with bankruptcy rules.
$277.50 Create meetings schedule from detail.
$333.00 Review status of Fourth Interim ASCII filing.
Contact P. Mathews regarding status.
Page 8 of 14
Professional Date Hours Býiling Rate ees' Dekcription Sin, Theresa 9/30/2002 1 8
$1'85
$333.000" Make final edits to exhibits - time detail and write-off additional expenses. Make changes to cover letter.
SubTotal:
Sin, Theresa 255
$4,717.50 9/412002 1.7
$370
$629.00
, Review time and expense details for the fourth interim fee application.
Young, Allison 9/512002 2.7
$370
$999.00 Begin to draft 4th Interim fee application.
Young, Allison 9/5/2002 0.6
$370
$222.00 Contnue review of time and expense details for 4th interim fee application.
Young, Allison 9/612002 2.1
- $370
$777.00 Create exhibit 4 - meetings with multiple PwC professionals for fee application.
Young, Allison 9/6/2002 3.7
$370
$1,369.00 Continue draft of 4th interim fee application.
Young, Allison 919/2002 1.6
$370
$592.00 Update 4th interim fee application filing.
Young, Allison 9/10/2002 0.7
$370
$259.00 Update fee application filing for 4th interim fee application and exhibits.
Young, Allison 9/12/2002 1.3'
- $370
$481.00 Update PG&E fee app for feedback from T. Lumsden review.
Young, Allison 9/13/2002 2.5
$370
$925.00 Update PG&E fee app for feedback from T. Lumsden review.
Young, Allison 9126/2002 -
0.9
$370
$333.00
-Review monthly cover letter time details.
Young, Allison 9/2712002 "1.3
$370
$481.00'-
Review September cover letter application and supporting exhibits.
SubTotal:
Young, Allison 19.1 - -
- $7,067.00" -
Total: Fee Apphcation 58.1
$16,354.50, Task Code:
FERC Review Lumsden, Tom 9/3/2002 r 1.2
$595
$714.00 Review PG&E materials on FERC hearings on Sbilateral contract and status of hearings.
Lumsden, Tom 9/2412002 0.6
$595
$357.00 Review reports on status of FERC ALJ review of power contracts and market behavior by El Paso on pipeline operations.
SubTotal: Lumsden,'Tom -
1.8
$1,071.00 Total: FERC Review 1.8
$1,071.00 "
.s
,o -
Fiani" SttmetModeli Task Code :
Financial Statement Modeling':
Wednesday, October30,' 2002 Young, Allison Page 9 qf14
Professional Date Hours Billing Rate Fees Description Young, Allison 9125/2002 2.7
$370
$999 00 SubTotal:
Young. Allison
2.7 Total
Financial Statement Modelin 2.7 Task Code:
General Committee Matters Ho, Rocky 9/6/2002 0.7
$475
$332.50 Ho, Rocky 9/13/2002 07
$475
$33250 Ho, Rocky 9/30/2002 0 6
$475
$285 00 SubTotal:
Ho, Rocky 2
Kitchin, Jennifer 9/10/2002 0 6
$370
$222 00 Kitchin, Jennifer 9/11/2002 28
$370
$1,036 00 Kitchin, Jennifer 9/111/2002 0.3
$370
$111 00 Kitchin, Jennifer 9/25/2002 1.1
$370
$407.00 SubTotal:
Kitchin, Jennifer 4.8
$1, Lumsden, Tom 9/20/2002 03
$595
$17850 Lumsden, Tom 9/23/2002 0.3
$595
$178 50 Lumsden, Tom 9/25/2002 1.1
$595
$654 50 SubTotal:
Lumsden, Tom 1.7
$1*
Reiss, Freddie 9/6/2002 06
$595
$357.00 Reiss, Freddie 9/11/2002 1 5
$595
$89250 Reiss, Freddie 9/30/2002 02
$595
$11900 SubTotal:
Reiss, Freddie 2.3
$1, Young, Allison 9/9/2002 0.7
$370
$259.00 Calculate FTI estimate of PG&E overcollections since 2001 and evaluate possible refund to ratepayers.
$999 00
$999.00 Review various status emails re: UBS retention issue and possible outcomes.
Respond to CPUC inquiry regarding bank members that are creditors.
Review various email correspondence on plan issues.
- 950.00 Review responses to bondholder questions for conference call.
Participate in conference call with bondholders re:
questions on OCC/CPUC POR.
Follow-up discussion on questions from bondholder conference call.
Participate in conference call re: update for OCC.
77600 Review telephone messages and emails re PG&E.
Plan scheduling matters on case.
Participate in PG&E committee call re 9th circuit decision and impact. Address alternatives.
011.50 Update regarding PGE/CPUC Plan status.
Review correspondence from counsel and read press releases on case activities.
Updates on case status.
368.50 Review emails on case updates Wednesday, October 30, 2002 I
Professional Date Houirs Billing Rate Fees Description Page 10 of 14
PrfI inl Dt or ilgae Fe ecito Young, Allison Young, Allison Young, Allison Young, Allison 9/16/2002 'a 9123/2002 "9/2412002,
9/25/2002 0.7 1.4 2.9 1.1*
$370*
$370
$370
"$370 SubTotal:
Young, Allison
6.8 Total
General Committee Matters 17,6 Task Code:
Legislative Review
Lumsden, Tom 9/25/2002
--1
$595 SubTotal:
LiLumsden, Tom
-1 Total:" Legislabvi Review Task Code:'
OCC Plan of Reorganization Ho, Rocky 9/3/2002 2.5
$475 SubTotal:
HO, Rocky 2.5 Kitchin, Jennifer 9/3/2002 02
$370 Kitchin, Jennifer 9/5/2002 0.8
$370 K Ithn Je nie a- -
Kitchin, Jennifer 9/17/2002
- 03
$370 Kitchin, Jennifer 9/25/2002 0.3
$370 SubTotal:' Kitchin, Jennifer Young, Allison 9/3/2002 -,
1.7
'$370 Young, Allison 9/11/2002 1.9
-, $370 Young, Allison 9/16/2002 1.2
- $370
$259 00 Review emails on proposed OCC court filings.
$518 00 Review latest emails on court happenings related to the PG&E case.
$1,073.00" Review recent court orders with regard to the PG&E case and Milbank's summary of results.
$407.00
-Participate in Committee conference re: court'
-decision regarding the CPUC's settlement with SCE and potential impact on both POR's.
$Z516.00
$7,622.00
$595.00 Review AB 1890 terms and potential for rate freeze end in light of 9th circuit decision.
$595.00
$595.00'.
$1,187.50
-Review final draft of joint CPUC / OCC plaIn of
,reorganization and disclosure statement.
$1,187.50
$74 00 Review Chanin's questions re: OCC Plan Capital Structure
$296.00 Review Chanin's questions re: OCC Plan
$111.00 Review OCC draft supplemental report and recommendations re: competing PORs"
$111.00 Review next steps re: OCC POR after 9th Circuit ruling.
"--$592.00
$629.00 Review emailed files on the OCC POR and court filings related to such.
$703.00 Conference call with PG&E bondholder group to discuss financial elements of OCC/CPUC revised plan of reorganization.
$444 00 Discuss OCC/CPUC plan with Chanin.
Wednesday, October 30,'2002
".Fe~es Date,
- ours Billing'Rate
,Description Professional
ýRaje j] bf 14 '
Professional Dale Hours Billing Rate Young, Allison 9/17/2002 1 5
$370 Young, Allison 9118/2002 0.6
$370 Young, Allison 9/18/2002 06
$370 SubTotal:
Young, Allison
7.5 Total
OCC Plan of Reorganization 11.6 Task Code:
Plan of Reorganization/Negotiation Ho, Rocky 9/2/2002 1 1
$475 SubTotal: Ho, Rocky 1.1 Lumsden, Tom 913/2002 1.1
$595 Lumsden, Tom 9/10/2002 0 3
$595 Lumsden, Tom 9/10/2002 03
$595 SubTotal: Lumsden, Tom
1.7 Total
Plan of Reorganizahon/Nego 2.8 Task Code:
Professional Compensation Matters Ho, Rocky 9/13/2002 08
$475 Ho, Rocky 9/23/2002 1.1
$475 SubTotal:
Ho, Rocky 1.9 Iking, Floris 913/2002 1.2
$290 Iking, Floris 9/27/2002 1.6
$290 SubTotal:
hIIng, Floris 28 Young, Allison 9/20/2002 3
$370 Fees Description
$555 00 Review pending document filings on amended CPUC/OCC POR.
$222.00 Review latest assumptions in OCC POR.
$222 00 Review articles on PG&E's problems at NEG and their potential impact on the utility
$2,775. 00
$4,554.50 S
$522 50 Review and analyze US District court's reversal of Judge Montali's express preemption ruling.
$522 50
$654.50 Review appellate court decision on preemption and impact on PG&E plan and impact on rates and headroom.
$17850 Review press articles on voting of plans and results.
$17850 Review voting results and status of PG&E plan
$1,011 50
$1,534.00
$380 00 Review disclosure items in revised employment application.
$522 50 Review revised draft of employment application and supporting declaration.
$902.50
$348 00 Prepare and file supplemental employment affidavit of T.E. Lumsden.
$464.00 Prepare and serve FTI Employment Application, Declaration of T. E. Lumsden, and Proof of Services.
$812.00
$1,110 00 Update revised application of committee to hire FTI, as successor to PwC, as accountants and financial advisors of the committee.
Wednesday, October 30, 2002 Page 12 of14
Professional Date Ho:A Billing Rate Fees Description Young, Allison 9/23/2002
'- 2.9 Young, Allison 9123/20 Young, Allison
-9/24/20 Young, Allison 9/25/20 Young, Allison 9/25/20 Young, Allison 9/26/20 Young, Allison 9127/20q Young. Allison
-,9/27/20*
SubTotal:
Young, Allison Total: Professional Compensation Task Code:
02 02 02 02 02 02
- 2.
1.9 08 1.9 1.5 2.9
"$370
$370
$370
$370
$370
"-$370
$370 16.9
- 21.
21.6
$1,073 600 Continue to update application of employment for Fri.
$740 00 Create exhibits to employment application, document results of relationship check.
$703.00 Coordinate review of employment app and update application for Milbank feedback.
$296.00 Update employment application for feedback from T.
Lumsden.
$703.00 - Update FTI employement application.
$555 00 Complete relationship check on PG&E I FTI and update filings as appropriate.'
$1,073 00, Finalize FTI emplyemnt application and file with courts
$6,253.00
$7,967.50 Subcommittee Matters Kitchin, Jennifer 9/5/2002 Kitchin, Jennifer 9/5/2002 Kitchin, Jennifer 9/10/2002 SubTotal:
K0tchin, Jennifer Lumsden, Tom 915/2002 Lumsden, Tom 9/10/2002 Lumsden, Tom 9/10/2002 Lumsden, Tom Lumsden, Tom Lumsden, Tom Lumsden, Tom 9/11/2002 9/12/2002 9/13/2002 0.1 0.8 1.5
$370
$370
$370 2.4 08
$595 0.4
$595 1.5
$595 2.7
$595 0.3 03
$595
$595 9/25/2002
, 04
$595 Wednesday, Oat~ber'3O,'2002
$37.00 Call to Saybrook to discuss UBS retention.
$296 00 Participate in OCC Professionals conference call re UBS retention.
$555 00 Participate in OCC Professionals; update conference call.
$888.00
$476 00 Participate in call with CPUC and UBS on scope of work and assignments for joint plan
$238 00 Telephone call with J. Wilson re UBS letter and voting results, and preference.
$892.50 Participate in conference call with Milbank and CPUC representatives on UBS engagement letter terms and conditions.
$1,606 50 Participate in conference call with bondholder representatives and A.Young and J. Wilson and J Kitchen re Joint Plan and structure. Response to questions regarding plan.
$178.50 Telephone call with J. Wilson re Joint p!an
'developments.
$178.50 Telephone call with P.Aronzon re bondholder group
, questions, research files and plan.
$238.00 Telephone call with J. Wilson and W.Hulse re UBS structuring and request to review model.
Page 13 of 14 Date
]-'
Hors Billing Rate Fees Deý&'Iptlon,-`
Professional
Professional Date Hours Billing Rate Fees Description 9/25/2002 1.1
$595 9/30/2002 0 5
$595 SubTotal:
Lumsden, Tom Total: Subcornmmttee Matters Total Project :
8 10.4
]- 246.8]
$654.50 Telephone call with J. Wilson re 9th Circuit ruling, impact on cash, alternatives, discuss DWR bond offering, and models for Joint plan and financing structure.
$297.50 Telephone call with P. Aronzon re options in joint plan with 9th circuit decision.
$4,760.00
$5,64800
$96,097.00 Wednesday, October 30, 2002 Lumsden, Tom Lumsden, Tom Professional Date Hours Billing Rate Fees Description Page 14 ofl14
Pacific Gas and Electric Detail of Expenses September 1, 2002 through September 30, 2002 "Date Category Amount Description Lumden, Tom 9/2212002 Sundry Lumden, Tom 9123/2002 Lumden, Tom 9/24/2002 Lumden. Tom 9/26/2002 Lumden, Tom 9/27/2002 Pitney Bowes Managem 91412002 Pitney Bowes Managem 1014/2002 Sundry Sundry Sundry Sundry Sundry Sundry
$12.70 Telephone and email expenses for PG&E
$47.00 Phone calls for PG&E
$1.95 Telephone calls for PG&E
$12.00 City Parking - CPUC meeting - PGE
$12.00 City Parking - CPUC meeting - PGE
$1,112.28 Printing and service of Eighth Supplemental Declaration of T.E.
Lumsden.
$2,105.38 Printing and service of Application Authorizing the Retention of FTI Consulting
$3,303.31 Wednesday, October30, 2002 Page) of)
Exhibit 2-2 Name Wednesday, October 30, 2002 Page I of I
PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO I am employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action; my business address is 199 Fremont Street, 8t Floor, San Francisco, California.
On October 31, 2002, I served on the parties listed on the attached Service List, the foregoing document(s) described as:
F-1 CONSULTING INC. COVER SHEET APPLICATION FOR ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SEPTEMBER 1, 2002 TO SEPTEMBER 30, 2002 X
by placing the _ original X a true copy thereof enclosed in sealed envelopes addressed as stated on the attached service list:
(BY UPS NEXT DAY AIR DELIVERY)
X Following ordinary business practices at the San Francisco office of PricewaterhouseCoopers LLP, I placed the sealed envelope(s) for collection and mailing with UPS on that same day. I am readily familiar with the firm's practice for collection and processing of correspondence for mailing. Under that practice, such correspondence would be deposited with UPS on' that same day, with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business.
(FEDERAL)
I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.
Executed on October 31, 2002, San Francisco, Cali ia.
Catherine Dolan Type or Print Name 10/31/02 3:30 PM
Proof of Service by UPS Next Day Air James L. Lopes, Esq.
Howard, Rice, Nemerovski, Canady, Falk & Rabkin Three Embarcadero Center, 7t" Floor San Francisco, CA 94111-4065
[Counsel to Debtor]
Robert Jay Moore Paul S. Aronzon Milbank, Tweed, Hadley & McCloy LLP 601 South Figueroa Street Los Angeles, CA 90017
[Counsel for Official Committee of Unsecured Creditors]
Office of the U.S. Trustee Attn: Stephen Johnson 250 Montgomery Street, Suite 1000 San Francisco, CA 94104-3401
PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO I am employed in the County of San Francisco, State of California. I am over the age of 18 and not a party to the within action; my business address is 199 Fremont Street, 8th Floor, San Francisco, California.
On October 31, 2002, I served on the parties listed on the attached Service List, the foregoing document(s) without exhibits described as:
FTI CONSULTING INC. COVER SHEET APPLICATION FOR ALLOWANCE AND
"-PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SEPTEMBER 1, 2002 TO SEPTEMBER 30, 2002 X
by placing the _ original X a true copy thereof enclosed in sealed envelopes addressed as stated on the attached service list:
(BY MAIL)
X Following ordinary business practices at the San Francisco office of PricewaterhouseCoopers LLP, I placed the sealed envelope(s) for collection and mailing with the United States Postal Service on that same day. I am readily familiar with the firm's practice for collection and processing of correspondence for mailing. Under that practice, such correspondence would be deposited with the United States Postal Service on that same day, with postage thereon fully prepaid at San Francisco, California, in the ordinary course of business.
(FEDERAL)
I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made.
Executed on October 31, 2002 San Francisco, California.
Catherine Dolan Type or Print Name Signaf 10/31/02 3 29 PM