ML021620174

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

ML021620174
Person / Time
Site:	Diablo Canyon
Issue date:	06/10/2002
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: ML021620174 (5)

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 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 ELECTRIC Chapter 11 Case COMPANY, a California 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 APRIL 1 THROUGH APRIL 30, 2002 18 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 April 1, 2002 through April 30, 2002 (the "Application Period"). In 23 support of the Application, the Firm 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.

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1 2. The Firm billed a total of $201,330.52 in fees and expenses during the 2 Application Period. The Firm entered into0 n Engagement Agreement covering the 3 Application Period (the "Agreement") with the Official Committee of Unsecured Creditors of 4 Pacific Gas and ElectricCompany (the "Committee")., The Agreement calls for a monthly 5 fee of $250,000.00 forthie 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 monthly fees incurred April 1 through Apri 130, 2002 represents 1 8 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 April 1 - April 30 $200,000.00 $1,330.52 $201,330.52 13 12345678910 13 11 12

3. Accordingly, the Firm seeks allowance of interim compensation in the total 14 14 amount of $171,330.52 at this time. This total is comprised as follows:

15 $170,000.00 (85%of the fees forservices rendered)'

16 $ 1,330.52 (100% of the expenses incurred).

17

4. With regard to the copies of this App*licafion'served on counsel for the 18 Committee, counsel for the Debtor and the Office of the Uiited States Trustee, attached as 19 Exhibit 1 hereto is the name of each professional ýhoi performed services in connection with 20 this case during the period covered by this-Application and a narrative summarizing the work 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 Distfrict f 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 1 2. The Firm billed a total of $201,330.52 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:Officlal 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 monthly fees incurred April 1 through April 30, 2002 represents 1 8 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 April 1 - April 30 $200,000.00 $1,330.52 $201,330.52 13 3. Accordingly, the Firm seeks allowance of interim'compensation in the total 14 amount of $171,330.52 at this time. This total is comprised as follows:

15

$110,000.00' (85%of the fees for services rendered)'

16 $ 1,330.52 (100% of the expenses incurred).

17 4. With regard to the copies of this Application'served on counsel for the 18 Commrittee, counsel for the Debtor and the Ofceof the United States Trustee, attached as 19 Exhibit I hereto is the name of each professional whio performed services in connection with 20 this case during the period covered by this Application and a narrative summarizing the work 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 Districtdf 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 1 Special, Notice List. in this, case.

2 6. Pursuant to this Court's 'ORDER ESTABLISHING:INTERIM FEE 3 APPLICATION AND EXPENSE REIMBURSFMENTPROCEDUR' which Wa entered 4 on or about July 25, 2001, the Debtor is authorized to make the .payment requested herein 5ý, without a further hearing or order of this Cpurt unless aniobjection to this Application is filed 6 with the Court by the Debtor, the, Cor ittee or the -United States Trustee and served by the 7 fifteenth day of the month following the service of this Application. If such an objection is 8 filed, Debtor is authorized to pay the amounts, if any, not subject to the objection. The Firm 9 is informed and believes that this Cover Sheet Application was mailed by overnight mail on 10 or about May 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 seekfees and reimbursement ofthe expenses incurred for the totality Of the services renrdered 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 understandinig 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 ,". ~~~~~~~~~~~..

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26 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 "ORDER 3 ESTABLISHING INTERIM FEE APPLICATION AND EXPENSE REIMBURSEMENT 4 PROCEDURE."

5 DATED:

6 SAYBROOK CAPITAL, LLC 7 4 JONATHAN ROSENTHAL 9 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