ML031260402

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Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for March 1 Through March 31, 2003
ML031260402
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 04/30/2003
From: Rosenthal J
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: ML031260402 (4)


Text

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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-,, '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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