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Category:Legal-Pleading
MONTHYEARML24263A2122024-09-19019 September 2024 Notice of Substitution of Counsel for the California Energy Commission ML24236A7752024-08-23023 August 2024 NRC Staff Brief in Opposition to the San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Appeal of LBP-24-6 ML24236A7902024-08-23023 August 2024 Pacific Gas and Electric Company Answer Opposing the Appeal of LBP-24-6 Filed by San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group ML24211A2872024-07-29029 July 2024 Notice of Appeal of LBP-24-06 by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group ML24211A2882024-07-29029 July 2024 Brief by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group on Appeal of LBP-24-06 ML24149A3152024-05-28028 May 2024 Notice of Supplemental Standing Declaration ML24116A1732024-04-25025 April 2024 Response by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group to Pacific Gas and Electric Companys Motion to Strike Portions of Their Reply ML24106A2992024-04-15015 April 2024 Pacific Gas and Electric Companys Motion to Strike Portions of the Reply Filed by San Luis Obispo Mothers for Peace Friends of the Earth and Environmental Working Group ML24096B7842024-04-0505 April 2024 Reply by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group to Oppositions to Request for Hearing on Pacific Gas and Electric Companys License Renewal Application for the Diablo Canyon Nuclear Plant ML24089A1102024-03-29029 March 2024 NRC Staff Answer Opposing the San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Hearing Request ML24089A2412024-03-29029 March 2024 Pacific Gas and Electric Companys Answer Opposing the Hearing Request Filed by San Luis Obispo Mothers for Peace Friends of the Earth and Environmental Working Group ML24080A5032024-03-20020 March 2024 Notice of Appearance for Devin Black ML24067A0662024-03-0707 March 2024 Petition by San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group for Shutdown of Diablo Canyon Nuclear Power Plant Due to Unacceptable Risk of Seismic Core Damage Accident ML24064A1322024-03-0404 March 2024 Request of the California Energy Commission to Participate as Non-Party Pursuant to 10 C.F.R. 2.315(c) ML23272A1952023-09-29029 September 2023 Motion by San Luis Obispo Mothers for Peace and Friends of the Earth for Leave to Reply to Oppositions to Request for Emergency Order Requiring Immediate Shutdown of Unit 1 Pending Completion of Tests and Inspections of Pressure Vessel, Pub ML23272A1962023-09-29029 September 2023 Reply by San Luis Obispo Mothers for Peace and Friends of the Earth to Oppositions to Request for Emergency Order Requiring Immediate Shutdown of Unit 1 Pending Completion of Tests and Inspections of Pressure Vessel, Public Disclosure of Re ML23268A4352023-09-25025 September 2023 Pacific Gas and Electric Company Response to the Request of San Luis Obispo Mothers for Peace and Friends of the Earth for an Emergency Order Requiring Immediate Shutdown of Diablo Canyon Nuclear Power Plant, Unit 1 ML23268A0552023-09-25025 September 2023 NRC Staff Answer to San Luis Obispo Mothers for Peace and Friends of the Earth Request for Emergency Order Requiring Immediate Shutdown ML23257A3012023-09-14014 September 2023 San Luis Obispo Mothers for Peace and Friends of the Earth Request for Hearing on NRC Staff Decision Effectively Amending Diablo Canyon 1 License, Request for Emergency Order Requiring Shutdown, and Errata ML23257A3022023-09-14014 September 2023 San Luis Obispo Mothers for Peace and Friends of the Earth Corrected Request for Hearing on NRC Staff Decision Effectively Amending Diablo Canyon 1 License, Request for Emergency Order Requiring Shutdown, and Errata ML23254A3872023-09-11011 September 2023 San Luis Obispo Mothers for Peaces Notice of Withdrawal of Contention a ML23248A2222023-09-0505 September 2023 NRC Staff Answer to Pacific Gas and Electric Companys Motion to Dismiss or for Summary Disposition of Contention a as Moot ML23236A4952023-08-24024 August 2023 Pacific Gas and Electric Company Motion to Dismiss or for Summary Disposition of Contention a as Moot ML23227A0152023-08-14014 August 2023 Pacific Gas and Electric Company Notice of Appeal and Brief in Support of Appeal of LBP-23-7 ML23212A9662023-07-31031 July 2023 Joint Unopposed Motion to Modify Timing of Mandatory Disclosures and Hearing File Obligations ML23103A3942023-04-13013 April 2023 Slomfp Reply Re DC ISFSI ML23097A1292023-04-0707 April 2023 Pacific Gas and Electric Company Answer Opposing San Luis Obispo Mothers for Peace Hearing Request and Petition to Intervene ML23097A0632023-04-0707 April 2023 NRC Staff Answer to San Luis Obispo Mothers for Peace Hearing Request and Petition to Intervene ML23094A1342023-04-0303 April 2023 Notice of Appearance for Diane Curran ML23073A3822023-03-14014 March 2023 Re-filed San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23074A1102023-03-13013 March 2023 Email Filing of Hearing Request from San Luis Obispo Mothers for Peace Regarding Diablo Canyon ISFSI License Renewal Application ML23074A2042023-03-13013 March 2023 San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23073A3072023-03-13013 March 2023 San Luis Obispo Mothers for Peaces Hearing Request and Petition to Intervene in License Renewal Proceeding for Diablo Canyon Spent Fuel Storage Installation ML23052A2032023-01-20020 January 2023 Notices of Appearance for Ryan Lighty, Paul Bessette, and Timothy Matthews on Behalf of Pacific Gas and Electric ML23052A2022023-01-20020 January 2023 Pacific Gas and Electric Response to the January 10, 2023 Extraprocedural Filing by San Luis Obispo Mothers for Peace, Friends of the Earth, and Environmental Working Group Regarding Diablo Canyon Units 1 and 2 ML23052A1932023-01-10010 January 2023 Notice of Appearance for Hallie Templeton on Behalf of Friends of the Earth ML23052A2042023-01-10010 January 2023 E-mail from Paul Bessette Dated 01/10/2023 Regarding Diablo Canyon ML23052A1942023-01-10010 January 2023 Notice of Appearance for Caroline Leary on Behalf of Environmental Working Group ML23052A1952023-01-10010 January 2023 Notice of Appearance for Diane Curran on Behalf of San Luis Obispo Mothers for Peace ML23052A1922023-01-10010 January 2023 San Luis Obispo Mothers for Peace, Friends of the Earth and Environmental Working Group Petition to Review Undocketed License Renewal Application for Diablo Canyon Unit 1 and Unit 2 Reactors and to Deny Request to Extend License Terms ML15345A4632015-12-11011 December 2015 Applicant Response Opposing Slomfp Appeal of LBP-15-29 ML15345A2212015-12-11011 December 2015 NRC Staff Answer to Slomfp Petition for Review of LBP-15-29 ML15321A4862015-11-17017 November 2015 NRC Staff Brief in Opposition to Foe'S Appeal of LBP-15-27 ML15321A4632015-11-17017 November 2015 Pacific Gas and Electric Response to Foe Appeal of LBP-15-27 ML15320A5652015-11-16016 November 2015 San Luis Obispo Mothers for Peace'S Petition for Review of LBP-15-29 ML15296A5502015-10-23023 October 2015 Friends of the Earth'S Notice of Appeal and Brief in Support of Appeal of LBP-15-27 ML15282A0492015-10-0909 October 2015 NRC Staff Answer to Slomfp Petition for Review of August 6, 2015 Board Order ML15282A4592015-10-0909 October 2015 Applicant Response Opposing Slomfp Petition for Review ML15257A5722015-09-14014 September 2015 San Luis Obispo Mothers for Peace'S Response to Pacific Gas & Electric Company'S Motion for Summary Disposition of Contention EC-1 ML15257A5702015-09-14014 September 2015 Petition for Review - San Luis Obispo Mothers for Peace'S Petition for Review of Memorandum and Order (Denying Motions to File New Contentions) 2024-09-19
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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 SAN FRANCISCO DIVISION 11 In re Case No. 01-30923 DM 12 PACIFIC GAS AND El2.ECTRIC 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 MARCH 1 THROUGH MARCH 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 March 1, 2002 through Mach 30, 2002 (the "Application Period").
23 In 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 Finn 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.
sIola2.
1 2. The Firm billed a total of $201,486.31 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 Engagement Period and a monthly fee of 6 $200,000.00for 6 h month of the engagement after, plus reimbursement of actual out-of 7 pocket expenses. The total monthly fees incurred March- 1 through March 30, 2002 "8 represen s 1 m6ith"bf the monthly engagemhent during the Application Period. These fees 9 and expenses break down as follows:
10 11 Period - Fees .xpe..ses Total 12 March 1-March30 $200,000.00 $1,486.31 $201,486.31 13
- 3. Accordingly, the Firm seeks allowance of interim compensation in the total 14 amount of $171,486.31 at this time. This total is comprised as follows:
15
$170,000.00 (85%of the fees for services rendered)'
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$ 1,486.31 (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 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 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 1 Special Notice List in this case.
2 6. Pursuant to this Court's 'ORDER ESTABLISHING INTERIM FEE 3 APPLICATION AND EXPENSE REIMBURSEMENT PROCEDURE" which was entered 4 on or about July 25, 2001, the Debtor is authorized to make the payment requested herein 5 without, a further hearing or order of this Court unless an objection to this Application is filed 6 with the Court by the Debtor, ,the Committee or the Unitd Trustee and served by the 7 fifteenth day of the month. following the:serice pfthisApplicatio. If such an objection is 8 filed, Debtor is a*!tlhprized to pay the amoqunts, 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 April 29, 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 i-Ncurred forlthe 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 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
By:
8 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