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Category:Legal-Affidavit
MONTHYEARML24162A0792024-06-0707 June 2024 OEDO-24-00083 - 10 CFR 2.206 - Diablo Canyon Units 1 and 2 Seismic CDF - Supplemental Declaration 6-7-2024 - DCL-23-022, 2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant2023-03-29029 March 2023 2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant DCL-19-082, Submittal of Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019 Submittal of Site-Specific Decommissioning Cost Estimate DCL-18-100, License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology2018-12-26026 December 2018 License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology ML16061A4522016-02-11011 February 2016 Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement DCL-16-020, Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement2016-02-11011 February 2016 Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement ML16026A3882016-01-0505 January 2016 Westinghouse Electric Company, LLC, Submittal of Proprietary Version of LTR-DCPPS-15-008 Response to NRC RAI 73 (Open Item 129). ML15090A2752015-03-26026 March 2015 Independent Spent Fuel Storage Installation - Consent and Hearing Waiver Form ML14171A2372014-06-11011 June 2014 Submittal of Supplemental Analysis for Inservice Inspection Program Relief Request SWOL-REP-1 U2 DCL-14-034, Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal2014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal ML14205A0352014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal DCL-13-061, CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 22013-04-25025 April 2013 CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 2 ML13078A2922013-03-0505 March 2013 Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz DCL-13-021, Areva Affidavit for Areva Calculations 32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and 32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer N2013-03-0505 March 2013 Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz DCL-12-069, Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T2012-08-0202 August 2012 Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12222A0942012-08-0202 August 2012 Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12137A0242012-05-15015 May 2012 Diablo Canyon - May Hearing File Update ML11297A0562011-10-18018 October 2011 Diablo Canyon - October Hearing File Update ML0715501312007-05-23023 May 2007 SER Compliance with WCAP-16260-P-A the Spatially Corrected Inverse Count Rate (Scicr) Method for Subcritical Reactivity Measurement DCL-05-121, Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.'2005-12-23023 December 2005 Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.' DCL-05-018, License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria.2005-03-11011 March 2005 License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria. DCL-04-149, License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack2004-11-0303 November 2004 License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack DCL-04-123, License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports2004-11-0101 November 2004 License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports DCL-04-104, Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant.2004-08-18018 August 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant. DCL-04-089, Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10.2004-07-30030 July 2004 Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10. DCL-04-095, 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors2004-07-27027 July 2004 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors DCL-04-066, Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.'2004-06-0404 June 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.' ML0412804352004-04-30030 April 2004 Notice of Change of Address ML0409704212004-03-31031 March 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 1 Through February 29, 2004 ML0409805912004-03-18018 March 2004 Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expense for February 1, 2004 Through February 29, 2004 ML0406204532004-02-23023 February 2004 Declaration of Sandip Sen in Support of Debtor'S Motion for Authority to Establish Cash-collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto (the Motion)' ML0403706042004-01-29029 January 2004 Declaration of Michael J. Donnelly in Support for Authority to Establish Cash-Collaterized Letter of Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0403706012004-01-29029 January 2004 Declaration of Raymond X. Welch in Support of Motion for Authority to Establish Cash-Collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0400700982003-12-30030 December 2003 Howard, Rice Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for November, 2003 ML0400200602003-12-22022 December 2003 Declaration of Grant Guerra in Support of Motion for Order Authorizing the Debtor to Settle Claim No. 13377 Filed by the Presidio Trust ML0333810452003-11-26026 November 2003 Cooley Godward Llp'S Twenty-Ninth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period October 1, 2003 - October 31, 2003 ML0331800932003-11-0606 November 2003 Proof of Service ML0331701792003-10-31031 October 2003 Declaration of Michael J. Donnelly in Support of Pg&E'S Application for Authority to Incur Plan Implementation Expenses in Connection with Certain Financings DCL-03-133, Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038)2003-10-28028 October 2003 Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038) ML0331800902003-10-23023 October 2003 Declaration of Jennifer A. Becker in Support of City of Oakland and Port of Oakland'S Motion for Relief from Automatic Stay ML0331800862003-10-23023 October 2003 Relief from Stay Cover Sheet ML0328703662003-09-29029 September 2003 Skadden, Arps, Slate, Meagher & Flom Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period August 1, 2003 Through August 31, 2003 ML0327312982003-09-24024 September 2003 (Reorganized) California Power Exchange Corporation'S Limited Objection to Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alia and to Enter Into Agreements Resolving ML0327314402003-09-23023 September 2003 Fact Witness Disclosure of Satellite Senior Income Fund, Satellite Senior Income Fund II and Deutsche Bank Trust Company Americas to Objection to Confirmation of Plan of Reorganization Under Chapter 11 of the Bankruptcy Code for Pacific Gas ML0327313322003-09-22022 September 2003 Notice of Hearing on Interim Compensation Applications of Professionals and Final Expense Application of Creditors' Committee Members ML0326810702003-09-16016 September 2003 Declaration of Michael J. Donnelly in Support of Debtor'S Notice of Motion and Motion for Order Approving Debtor'S Execution and Performance Under the Amendment to First Amended and Restated Summary of Terms with Respect to Forbearance and ML0325412082003-09-11011 September 2003 Order Re Ex Parte Application of Pacific Gas and Electric Company Authorizing Settlement and Withdrawal of Claim of Laguna Irrigation District ML0325911092003-09-0505 September 2003 Declaration of Joshua Bar-Lev in Support of Debtor'S Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alla and to Enter Into Agreements Resolving the Claims ML0325411442003-09-0404 September 2003 Relief from Stay Cover Sheet - Motion & Notice of Motion of Smud for Relief from Automatic Stay in Litigation ML0325213432003-08-29029 August 2003 Declaration of Joseph Sauvage in Support of Motion for Authority to Enter Into Certain Hedging Transactions in Connection with Financing Under Proposed Plan of Reorganization, and to Incur Secured Debt Related Thereto 2024-06-07
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1 JON P. SCHOTZ JONATHAN Y. THOMAS s50 I 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 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 AND El-ECTRIC - Chapter 11 Case COMPANY, a Californ.ia corporation, 13
- l Delbtor.
14 15 Federal I.D. No. 94-0742640 16 SAYBROOK CAPITAL, LLC
- 1, COVER SHEET APPLICATION f 17 FOR ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR MARCH 1THROUGH 18 MARCH 31. 2003 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 March 1, 2003 through March 31, 2003 (the "Application Period").
23 In support of the Application, the Firm respectfully represents as follows:
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24 1. The Firm is a finiancial 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 liereby 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.
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. _L 1 2. The Firm billed a total of $203,827.64 in fees and expenses during the 2 Application Period. The Firm enitered into an Engagemrnt-Agreement covering the 3 Application Period (tfie "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 March 1 through March 31; 2003 represent I month 8 of the monthly engagement during the Application Period. These fees and expenses break 19 -down as follows:-
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11 Period Total I LI 12 March 1 - March 31 13 I iA
- 3. Accordingly, the Firm seeks allowance of interim compensation in the total 14 amount of $173,827.64 at this time. This total is comprised as follows:
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$170,000.00 (85%of the fees for services rendeied)' rf 16
$ 3,827.64 (100% of the expenses incurred).
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- 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
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- this case during the period covered by this Applicati6ii and a narrative-summarizing the work
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21 of each professional; and (b) attached as Exhibit 2 are the'detailed expense statements for the 22 Application Period that comply with all Northern District of Califomia Bankruptcy Local 23 Rules and Compensation Guidelines and the Guidelines of the Office of the United States 24 Trustee.
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- 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 I Special Notice List in this case. a-
,; 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 objection. The Firm is informed and believes that this Cover Sheet Application was mailed 10 by overnight mail on or about April 29, 2003.
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.
I 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.
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- 24 25 II :: , , ,I II I C w . - ; H e ff
-,, 'N 26 27 28 I 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: April 30,2003 6 SAYBR OK CAPITAL, LLC By:V 8 JONATHAN ROSENTHAL 9- Financial Advisor for the Official Committee of Unsecured Creditors of PACIFIC GAS AND 10 ELECTRIC COMPANY 11I 12 13 14 15 Is', ,a 16 17 18 19 20 .A -....- _
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23 24 25 26 27 28