ML030100179

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

ML030100179
Person / Time
Site:	Diablo Canyon
Issue date:	11/30/2002
From:	John Thomas Pacific Gas & Electric Co, Saybrook Capital
To:	Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923 DM, 94-0742640
Download: ML030100179 (4)

Text

1 JON P. SCHOTZ JONATHAN Y. THOMAS 2 JONATHAN ROSENTHAL JEFFREY M. WILSON 3 SAYBROOK CAPITAL, LLC 401 Wilshire Blvd, Suite 850 4 Santa Monica, CA 90401 Telephone: 310/899-9200 5 Facsimile: -310/899-9101 6 Financial Advisors for Official Committee of' Unsecured Creditors I 7

8 UNITED STATES BANKRUPTCY COURT

--- 9 -. NORTHERN DISTRICT OF CALIFORNIA --,------ -....

10 SAN FRANCISCO DIVISION 11 In re Case No. 01-30923 DM 12 PACIFIC GAS AN.D ELECTRIC Chapter 11, Case COMPANY, a Califormia corporation, 13 Debtor.

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 NOVEMBER 1 THROUGH 18 NOVEMBER 30, 2002 19 20 -Saybrook Capital, LLC (the "Firm") submits its Cover Sheet Application (the

- 21 "Application") for Allowance and Payment of Interim Compensation and Reimbursement of 22 Expenses for the Period November 1, 2002 through November 30, 2002 (the "Application 23 Period"). In support of the Application, the Finn respectfully represents as follows:

24 1. The Firm is a financial advisor to the unsecured creditors of Pacific Gas and 25 Electric Company, debtor and debtor-in-possession in the above-referenced bankruptcy case 26 (the "Debtor"). The Firm hereby applies to the Court for allowance and payment of interim 27 compensation for services rendered and reimbursement of expenses incurred during the 28 Application Period.

1 2. The Firm billed a total of $201,810.11 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 Engagemnent 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 November 1 through November 30, 2002 represent 8 1 month of the monthly engagement during the Application Period. These fees and expenses break down as follows: --.. -- -.-.-. --...- -

. ? .-.-.-------..... ....... - . ..

10 11 Period Fees Expenses Total 12 October 1 - October 31 $200,000.00 $1,810.11, $201,810.11 13

3. Accordingly, the Firm seeks allowance of interim compensation in the total 14 amount of $171,810.11 at this time. This total is comprised as follows:

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$170,000.00 (85%of the fees for services rendered)'

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$ 1,810.11 (100%,of the expenses incurred).

17

4. With regard to the copies of this Application served on counsel for the 18 Committee, counsel for the Debtor and the Office of the United States Trustee, attached as 19 Exhibit 1 hereto is the name of each professional who performed. services in connection with 20 this case during the perioctcovered, by this Application'and a narrative summarizing the-work "21 of each professional; and (b) attached as Exhibit 2 ar~e the detailed expense statements for the 22 Application Period that comply with all Northern District of California Bankruptcy Local 23 Rules and Compensation Guidelines and the Guidelines of the Office of the United States 24 Trustee.

25,

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

'Payment of this amount would result in a "holdback" of $30,000.00 28 V.

1 Special Notice'List in this case.

2 6. Pursuant to this Court's "SECOND AMENDED ORDER ESTABLISHING 3 INTERIM FEE APPLICATION AND EXPENSE REIMBURSEMENT PROCEDURE" 4 which was entered on or about March 18, 2002, the Debtor is authorized to 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 day of the month following the service of this Application. If such 8 an objection is filed, Debtor is authorized to pay the amounts, if any, not subject to the 9 -objection. -TheFirm -is informed and believes that this Cover-Sheet Application -was mailed 10 by overnight mail on or about December 27, 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 Bankruptcy Local Rules and Compensation Guidelines and 19 the Guidelines of the Office of the United States Trustee. Neither the Firm nor any members

__20 of the Firm has any agreement or understanding of any kind or nature to divide, pay over or 21 share any portion of the fees or expenses to be awarded to the Firm with any other person or 22 attorney except as among the members and associates of the Firm.

23 24 25 26 27 28

,r.

'4 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

By: JONATHAN THOMAS 8

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