IN THE UNITED STATES BANKRUPTCY COURT … Crazy Eddie, the Court considered petitioning creditors’ request for compensation and expenses relating to the preparation, filing and adjudication

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Hearing Date: May 7, 2018 at 2:00 p.m. ) Objection Deadline: April 30, 2018 at 4:00 p.m.

COVER SHEET

APPLICATION FOR REIMBURSEMENT OF FEES ANDEXPENSES INCURRED BY THE PETITIONING CREDITORS

FOR THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018

Name of Applicants: CGM Partners, LLC, Howard Elias, and the Kelly Yang Living Trust (collectively, the “Petitioning Creditors”)

Date of Retention: March 19, 2018

Period for which compensation and reimbursement is sought: March 19, 2018 through March 27, 2018

Amount of compensation sought as actual, reasonable and necessary: $5,164.50

Amount of expense reimbursement sought as actual, reasonable and necessary: $1,722.80

Total amount of compensation and reimbursement sought: $6,887.30

This is a(n): interim ____ quarterly __ x__ final application

Case 18-10679-CSS Doc 71 Filed 04/12/18 Page 1 of 11

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ATTACHMENT TO FEE APPLICATION

NAME OF PROFESSIONAL

POSITIONHELD

HOURLY BILLING RATE

TOTAL HOURSBILLED

TOTAL COMPENSATION

Kevin S. Mann Partner $475.00 10.6 $5,035.00 Stephanie MacDonald Legal Assistant $185.00 0.7 $129.5

TOTAL: 11.3 $5,164.50

Blended Hourly Rate: $457.04

EXPENSE SUMMARY

EXPENSE AMOUNT Photocopies $5.80 Filing fees $1,717.00 TOTAL $1,722.80

COMPENSATION BY PROJECT CATEGORY

CODE CATEGORY HOURS AMOUNT

AP Adversary Proceedings / Litigation 2.1 $968.50

CH Court Hearings 9.2 $4,196.00

TOTAL 11.3 $5,164.50




APPLICATION FOR REIMBURSEMENT OF FEES ANDEXPENSES INCURRED BY THE PETITIONING CREDITORS FOR

THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018

Pursuant to 11 U.S.C. §§ 503(b)(3)(A) and 503(b)(4) of the United States Code (the

“Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure, and Bankruptcy

Local Rule 2016-2, CGM Partners, LLC, Howard Elias, and the Kelly Yang Living Trust

(collectively, the “Petitioning Creditors”), hereby apply for an order allowing and directing the

Trustee to pay to Cross & Simon, LLC, counsel for the Petitioning Creditors, (i) compensation in

the total amount of $5,164.50 for the reasonable and necessary legal services Cross & Simon,

LLC rendered to the Petitioning Creditors from March 19, 2018 through March 27, 2018 (the

“Application”) and (ii) reimbursement for the actual and necessary costs and expenses of

Petitioning Creditors in the amount of $1,722.80 for a total payment of $31,132.76. In support

of this Application, the Petitioning Creditors respectfully state as follows:

Jurisdiction & Venue

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 157. This is a

core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue is proper before this Court

pursuant to 28 U.S.C. §§ 1408 and 1409. The statutory predicate for relief is 11 U.S.C. § 503

and Bankruptcy Local Rule 2016-2.


Background

2. On March 23, 2018, Petitioning Creditors filed an involuntary petition (the

“Involuntary Petition”) for relief against Candi Controls, Inc. (“Debtor”) under section 301 of the

Bankruptcy Code.

3. On March 23, 2018, counsel to the Debtor contacted counsel to the Petitioning

Creditors to indicate that the Debtor would consent to the entry of an order for relief. The United

States Trustee objected to the Debtor consenting to the entry of an order for relief indicating the

United States Trustee’s belief that the Debtor did not have the requisite corporate authority to

consent to the entry of an order for relief.

4. On March 27, 2018, the Court held a hearing on the Debtor’s ability to consent to

the entry of an order for relief. After argument from counsel to the Debtor, counsel to the United

States Trustee, counsel to the Petitioning Creditors, and counsel to the Debtor’s post-petition

lender, the Court determined that the Debtor did have the requisite corporate authority to consent

to the entry of an order for relief and entered the Order for Relief in Involuntary Case [Docket

No. 13] (the “Order”).

5. Petitioning Creditors have incurred attorney fees and costs in connection with the

preparation and filing of the Involuntary Petition, investigating and researching the Petitioning

Creditors’ claims and the Debtor’s corporate authority to consent to the entry of an order for

relief, preparing for a contested hearing on the Involuntary Petition, and litigating the

Involuntary Petition in Court. These fees and costs total $6,887.30. A full and detailed

description of the time and expenses is attached as Exhibit “A”.


Relief Requested

6. Petitioning Creditors respectfully request entry of an order allowing the

reimbursement of fees and expenses incurred by the Petitioning Creditors in the amount of

$5,164.50 and $1,722.80 respectively, and directing the Debtor to immediately pay such

expenses.

Basis for Relief

7. Section 503(b) of the Bankruptcy Code provides:

After notice and a hearing, there shall be allowed administrative expenses, other than claims allowed under section 502(f) of this title, including -- (3) the actual, necessary expenses, other than compensation and reimbursement specified in paragraph (4) of this subsection, incurred by – (A) a creditor that files a petition under section 303 of this title.

11 U.S.C. §503(b)(3)(A). Section 503(b)(4) further provides for:

Reasonable compensation for professional services rendered by an attorney or an accountant of an entity whose expense is allowable under subparagraph (A)… of paragraph 3 of this subsection, based on the time, the nature, the extent, and the value of such services, and he cost of comparable services other than in a case under this title, and reimbursement for actual, necessary expenses incurred by such attorney or accountant.

11 U.S.C. §503(b)(4).

8. The expenses and attorney fees incurred in research and investigation prior to the

preparation of the involuntary petition should be an allowed administrative expense. See Matter

of Baldwin-United Corp., 79 B.R. 321 (Bankr.S.D. Ohio 1987) (holding that fees arising from

reasonable research and investigation prior to the preparation and filing of the involuntary

petition were allowable administrative expense). Courts have also held that expenses related to

the adjudication of an involuntary petition are compensable as administrative expenses under

section 503(b)(3). In re Crazy Eddie, Inc., 120 B.R. 273, 278 (Bankr.S.D.N.Y. 1990); see also,

In re Key Auto Liquidation Center, Inc., 384 B.R. 599, 605-606 (Bankr.N.D. Fla. 2008)


(“Attorney’s fees may be recovered under §§503(b)(3)(A) and 503(b)(4) for preparing and filing

the involuntary petition, contacting other creditors to join the petition, legal and factual research

regarding the grounds for filing the case, and litigating whether an order for relief should be

entered.”) In Crazy Eddie, the Court considered petitioning creditors’ request for compensation

and expenses relating to the preparation, filing and adjudication of an involuntary petition. Id. at

278 (citing In re Hanson Industries, Inc., 90 B.R. 405, 410 (Bankr.D. Minn. 1988)) The Court

further stated:

This reading of the Code recognizes that an involuntary proceeding can become an expensive and aggressively contested matter. See [S. Bernstein & L. King, Collier Bankruptcy Compensation Guide], ¶ 7.04[1] at 7-14. A more limited interpretation of the Code is indeed ‘out of step with the realities’ of today’s bankruptcy practice; it would be disingenuous to compensate for the filing of the petition but not its successful adjudication, particularly since the petitioning creditors are liable under §303(i) if the case is abandoned or dismissed.

Id. (emphasis added).

9. In Key Auto, the Court held that the purpose of §503 is “to reimburse petitioning

creditors for the costs associated with successfully filing and prosecuting an involuntary petition

– a valuable service that brings the debtor into court so that its assets can be equitably marshaled

before they are squandered.” In re Key Auto Liquidation Center, Inc., 384 B.R. at 604 (citing In

re J.V. Knitting Service, Inc., 22 B.R. 543, 545 (Bankr.S.D. Fla. 1982); In re Adam Furniture

Industries, Inc., 1993 WL 13004589, *3 (Bankr.S.D. Ga. 1993); Hanson Industries, 90 B.R. at

410.) In Key Auto, the Court found that the petitioning creditor’s attorney played a large, if not

predominant role in prosecuting the involuntary petition:

[H]e responded to the motion to dismiss, filed memoranda and supplements to the pleadings, appeared in court to prosecute the involuntary petition, and responded to discovery requests, all of which were necessary only because the Debtor and Objecting Creditors adamantly opposed the entry of an order for relief. The nature of expenses Ciano incurred are of the type that §§503(b)(3)(A) and 503(b)(4) were intended to compensate and Ciano has performed a valuable


service for the creditors and the estate by bringing the Debtor into court so that its assets would not be dissipated.

Id. at 605.1

10. The legal expenses incurred by the Petitioning Creditors fit squarely into the

category of administrative expense claims described by section 503(b)(4). The Petitioning

Creditors incurred these fees in preparing and filing of the Involuntary Petition, investigating and

researching the Petitioning Creditors’ claims and the Debtor’s corporate authority to consent to

the entry of an order for relief, preparing for a contested hearing on the Involuntary Petition, and

litigating the Involuntary Petition in Court. The details of legal work done on this case are

shown in specific time entries attached to this Application. To the extent counsel for Petitioning

Creditors had discussions with the Petitioning Creditors, the description of these conversations is

limited so as to preserve and protect the attorney-client privilege. Generally, counsel and the

Petitioning Creditors discussed facts giving rise to the Debtor’s insolvency and actions leading

up to the Involuntary Petition, the Petitioning Creditors’ claims, the Debtor’s corporate structure

and internal governing documents, and efforts to preserve and protect assets of the estate. The

Petitioning Creditors believe these and other charges are reimbursable as they are directly related

to preparing and filing the Involuntary Petition, monitoring and protecting assets of the Debtor’s

estate, legal and factual research regarding the grounds for filing the case, and litigating whether

an order for relief should have been entered.

11. In Crazy Eddie, the debtor initially filed a motion to dismiss and for sanctions

against the petitioning creditors. Like here, the debtor in Crazy Eddie did not allege that the

petitioning creditors failed to meet the statutory requirements of §303 for filing the petition, and

1 In Key Auto, the Court awarded $2,578.08 under §503(b)(3)(A) and $43,840.00 under §503(b)(4).


instead sought dismissal on the discretionary provisions of §305, in the “interests of creditors.”

Similar to the case at bar, the debtor eventually stipulated to the withdrawal of the motion to

dismiss and for sanctions, precluding any review of the merits of the involuntary filing. In re

Crazy Eddie, 120 B.R. at 277.2

12. As evidenced by the Debtor’s statements, and the record, the Involuntary Petition

and the Debtor’s entry into Chapter 11 will benefit general unsecured creditors; in fact, without

the Involuntary Petition, most general unsecured creditors, would have no chance of recovering

anything from the Debtor. Accordingly, pursuant to 11 U.S.C. § 503(b)(4), Petitioning Creditors

are entitled to an administrative expense claim for their reasonable attorney fees and costs

incurred in connection with prosecuting the Involuntary Petition.

13. Further, Petitioning Creditors should be entitled to immediate payment of their

actual and necessary expenses. “Courts have discretion to determine when an administrative

expense will be paid.” In re Garden Ridge Corp., 323 B.R. 136, 143 (Bankr. D. Del. 2005)

(Citing HQ Global Holdings, Inc., 282 B.R. 169, 173 (Bankr. D. Del. 2002)). “In determining

the time of payment, courts consider prejudice to the debtor, hardship to the claimant, and

potential detriment to other creditors.” Id. at 143.

14. Petitioning Creditors will be substantially prejudiced if their actual and necessary

expenses are not immediately paid. Petitioning Creditors were subject to attack for filing the

Involuntary Petition, and incurred additional attorney fees, costs and expenses for prosecuting

the Involuntary Petition, which fees, costs and expenses are due and owing. Without immediate

payment on account of their claims, Petitioning Creditors have been and will be forced to front

2 In Crazy Eddie (1990), the Court awarded $27,636.38 in legal fees and $2,077.26 in expenses.


expenses that resulted in the entry of the order of relief, without which, as discussed herein, no

creditor would have any chance of recovering from the Debtor’s estate.

15. The Debtor will suffer no prejudice if it must immediately pay the Petitioning

Creditors’ claims from available cash. The Debtor has obtained post-petition financing. Further,

while significant for Petitioning Creditors, the amount of the claim is small in relation to the

potential size of the Debtor’s estate. Additionally, the Debtor’s estate will likely incur and pay

certain administrative expense claims before other claims in this case, or before final

distribution. For instance, the Debtor’s professionals, will be eligible for compensation and

payment. If the Court authorizes the immediate payment of fees and expenses incurred by the

Debtor in administering this case, the Petitioning Creditors’ claim should be treated likewise, and

be timely paid too, as the work of both are benefitting all other creditors. Accordingly, since the

estate has cash, the Debtor will not be prejudiced by immediately paying certain administrative

expense claims, including reimbursing the Petitioning Creditors for their expenses and fees.

16. On information and belief, immediate payment of Petitioning Creditors’ claim

would not prejudice other claimants. Other administrative claimants are eligible for payments

upon Court approval. Immediate payment of Petitioning Creditors’ claims would merely put

Petitioning Creditors in the same position as these other administrative expense claimants,

including, for instance, the Debtor’s professionals, whose work will benefit other claimants.

Fee Statements

17. Cross & Simon, LLC devoted 11.3 hours of professional time to provide legal

services to the Petitioning Creditors for the period of March 19, 2018 through March 27, 2018.

The time record entries detailing that time, and the members of the firm providing it, are attached


hereto and marked as Exhibit A, and consist of a daily breakdown of the total time spent by each

person on each day, and of the disbursements during the applicable period.

18. During the applicable period, Cross & Simon, LLC performed legal services for

the Petitioning Creditors in the project categories described in Exhibit B. The following is a

summary of the work performed by Cross & Simon, LLC in each substantive area:

Adversary Proceedings / Litigation: Cross & Simon, LLC worked with the Petitioning Creditors in connection with the preparation, filing and prosecution of the Involuntary Petition.

Court Hearings: Cross & Simon, LLC prepared for, and attended a hearing in this case on behalf of the Petitioning Creditors wherein an order of relief was entered.

Actual and Necessary Expenses

19. A summary of the actual and necessary expenses incurred by Petitioning

Creditors for the applicable period is attached hereto as Exhibit A. When seeking reimbursement

from a bankruptcy estate, Cross & Simon, LLC charges 10¢ per page for duplication done in the

office. These charges are compliant with the Local Rules of this Bankruptcy Court. The other

costs incurred are actual costs billed to Cross & Simon, LLC and passed through to the

Petitioning Creditors.


WHEREFORE, Petitioning Creditors respectfully request that this Court enter an order in

substantial conformity with the proposed form of order attached hereto and grant such other and

further relief as this Court deems just and equitable.

Dated: April 12, 2018 CROSS & SIMON, LLC

By: /s/ Kevin S. Mann Kevin S. Mann (No. 4576)

1105 N. Market Street, Suite 901 Wilmington, DE 19801 (302) 777-4200

[email protected]

Counsel to the Petitioning Creditors




NOTICE OF APPLICATION

PLEASE TAKE NOTICE, that CGM Partners, LLC, Howard Elias, and the Kelly Yang

Living Trust (collectively, the “Petitioning Creditors”) filed the Application for Reimbursement

of Fees and Expenses Incurred by the Petitioning Creditors for the Period of March 19, 2018

through March 27, 2018 (the “Application”), with the United States Bankruptcy Court for the

District of Delaware (the “Bankruptcy Court”).

Objections to the Application, if any, must be filed on or before April 30, 2018 at 4:00

p.m. (the “Objection Deadline”) with the United States Bankruptcy Court for the District of

Delaware, 824 Market Street, 5th Floor, Wilmington, Delaware 19801. At the same time, you

must also serve a copy of the response upon the undersigned counsel to the Petitioning Creditors

so that the response is received on or before the Objection Deadline.

PLEASE TAKE FURTHER NOTICE that if an objection is properly filed in accordance

with the above procedure, a hearing on the Application will be held before the Honorable

Christopher S. Sontchi on May 7, 2018 at 2:00 p.m. Only those objections made in response to

the Application will be heard.

Case 18-10679-CSS Doc 71-1 Filed 04/12/18 Page 1 of 2

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IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT

MAY GRANT THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING.

Dated: April 12, 2018 CROSS & SIMON, LLC

By: /s/ Kevin S. Mann Kevin S. Mann (No. 4576)

1105 N. Market Street, Suite 901 Wilmington, DE 19801 (302) 777-4200

[email protected]

Counsel to the Petitioning Creditors


Exhibit “A”


For Services Rendered

Date 4/11/2018

Invoice # 0207025-627Client

Mr. Paul M. LaveryCGM Partners LLCP.O. Box 4631El Dorado Hills, CA 95672

TotalRC - Richard H. Cross, Jr., Esq.CS - Christopher P. Simon, Esq.JG - Joseph Grey, Esq.KM - Kevin Mann, Esq.DH - David Holmes, Esq.NM - Nancy McClendon (Legal Assistant)ND - Nicole DiBiaso (Legal Assistant)SM - Stephanie MacDonald (Legal Assistant)KA - Kathy Abbott (Legal Assistant)

1105 North Market Street, Suite 901P.O. Box 1380

Wilmington, DE 19899-1380(302) 777-4200

DateItem Description Hours Rate Amount

3/19/2018KM - B AP - Review loan documents, corporategovernance documents and corporate disclosures

2 475.00 950.00

3/19/2018KM - B AP - Research re: issues related to involuntarypetition filing; multiple correspondence withclient re: same

1.5 475.00 712.50

3/21/2018KM - B AP - Multiple correspondence with P. Lavery re:strategy

0.2 475.00 95.00

3/21/2018KM - B AP - Teleconference with client re: strategy 0.4 475.00 190.003/22/2018KM - B AP - Multiple correspondence re: strategy 0.2 475.00 95.003/22/2018KM - B AP - Review H. Elias loan documents 0.7 475.00 332.503/22/2018KM - B AP - Multiple correspondence re: strategy 0.2 475.00 95.003/23/2018KM - B AP - Teleconference with S. Leonhardt re: case

status0.3 475.00 142.50

3/23/2018KM - B AP - Correspondence to clients re: corporategovernance

0.2 475.00 95.00

3/23/2018KM - B AP - Teleconference with D. Buchbinder re: casestatus

0.2 475.00 95.00

3/23/2018KM - B AP - Finalize petition and related pleadings;correspondence to client re: same

0.5 475.00 237.50

3/23/2018KM - B AP - Prepare summons and proposed order forrelief

0.3 475.00 142.50

3/23/2018KM - B AP - Multiple correspondence with P. Lavery re:strategy

0.3 475.00 142.50

3/23/2018KM - B AP - Prepare petition and corporate statement;correspondence to client re: same

0.7 475.00 332.50

3/23/2018SM AP - Prepare and e-file Involuntary Chapter 11Petition

0.6 185.00 111.00

3/26/2018KM - B AP - Review certification of counsel re: consent;correspondence to clients re: same

0.4 475.00 190.00

3/26/2018KM - B CH - Review notice of status conference;correspondence to client re: same

0.2 475.00 95.00

3/26/2018KM - B AP - Review Altair notice of appearance 0.1 475.00 47.503/26/2018KM - B CH - Prepare for status conference 0.2 475.00 95.003/26/2018SM CH - Update calendar with hearing dates 0.1 185.00 18.503/27/2018KM - B CH - Review exhibit list for status conference 0.1 475.00 47.503/27/2018KM - B CH - Attend status conference with Judge Sontchi 1.5 475.00 712.503/27/2018KM - B AP - Correspondence to clients re: case status 0.4 475.00 190.003/26/2018Photocopy expense on 03/26/2018 (58 copies @

$0.10 = $5.80)5.80 5.80

3/26/2018Filing fee on 3/23/18 1,717.00 1,717.00

$6,887.30


Exhibit B


BANKRUPTCY DEBTOR/ESTATE/COMMITTEE PROJECT CATEGORIES

AA Asset Analysis and Recovery

AP Adversary Proceedings / Litigation

BO Business Operations

CA Case Administration

CH Court Hearings

CI Creditor Inquiries

CR Cash Collateral/DIP Financing

DS Disclosure Statement

EA1 Employment Application of Cross & Simon, LLC

EA2 Employment Application of Other Professionals

EB Employee Matters

EC Executory / Lease Contract Issues

FA1 Fee Application of Cross & Simon, LLC

FA2 Fee Application of Other Professionals

MA General Corporate Matters

MC Meetings of Creditors

MR Stay Relief Matters

PC Claims, Analysis, Objections & Resolutions

PL Plan

SA Use, Sale or Lease of Property

TR Trustee Reporting/Schedules

TV Non Working Travel

UM Utility Matters




In re: ) Chapter 11 ) CANDI CONTROLS, INC., ) Case No. 18-10679 (CSS) ) Debtor. ) Re: Docket No. ____ )

ORDER APPROVING APPLICATION FOR REIMBURSEMENT OF FEES AND EXPENSES INCURRED BY THE PETITIONING CREDITORS

FOR THE PERIOD OF MARCH 19, 2018 THROUGH MARCH 27, 2018

UPON CONSIDERATION of the Application for Reimbursement of Fees and Expenses

Incurred by the Petitioning Creditors for the Period of March 19, 2018 through March 27, 2018

(the “Application”),

IT IS HEREBY ORDERED THAT

1. The Application is GRANTED, as modified by this Order.

2. The Petitioning Creditors are allowed an administrative expense claim in the

amount of $27,634.00 for legal fees and $1,722.80 for expenses incurred by the Petitioning

Creditors, pursuant to section 503(b)(4) of the Bankruptcy Code.

3. The Debtor shall pay to the Petitioning Creditors the amounts set forth in

paragraph 2 herein within ten (10) days of the date of this Order.

4. This Order shall be effective immediately upon entry.

Dated: _______________________

________________________________ The Honorable Christopher S. Sontchi United States Bankruptcy Judge


CERTIFICATE OF SERVICE

I, Kevin S. Mann, hereby certify that on this 12th day of April, 2018, I caused copies of

the Application for Reimbursement of Fees and Expenses Incurred by the Petitioning Creditors

for the Period of March 19, 2018 through March 27, 2018 to be served on the following parties

by first class mail:

Yardi Systems, Inc. 430 South Fairview Ave Santa Barbara, CA 93111

John and Denise Woods 316 Indian Trail Dr Franklin Lanes, NJ 07417

Patrick O'Leary 1549 Whitetail Ln Cedarburg, WI 53012

William Schur 14 Bono St #175 Great Neck, NY 10021

Paul Stamatis, Jr. 10406 Charter Lake Cir Katy, TX 77494

Helmut Albrecht 3350 SW 27th Ave Apt. 2203 Miami, FL 33133

Robert Mansell 683 Terrace Ave Half Moon Bay, CA 94019

Lone Star Ventures, LLC dba Corporate Finance Associates 774 Mays Blvd Ste 10-630 Incline Village, NV 89451

ACM Gierman-Van Gils Veldweg 16 8051 NR Hattem Netherlands

Jack Brazil, Jr. 2701 Pebble Stone Grapevine, TX 76051

Jorge Gerardo Perez Garza Circuito Chapulines 6 Las Villas, Torreon Coahuila 27420 Mexico

Alvaro Ramirez Carrera 4 #70A-82 Apt. 716 Bogota 110231 Colombia

Paul J. Feldman 51 Warwick Stone Way Great Falls, VA 22066

Joel and Joanne Shefflin 995 Lilac Dr Montecito, CA 93108

Kishore Ganji 100 Timber Ln Malboro, NJ 07746


Pulling Out of Here to Win, LLC 12906 SW 133 Ct #A Miami, FL 33186

Chris Leebelt 11630 Coeur D'Alene Dr Parker, CO 80138

Frederick B. Rosner, Esq.Scott J. Leonhardt, Esq.Jason A. Gibson, Esq.The Rosner Law Group LLC 824 N Market Street, Suite 810 Wilmington DE 19801

Jordan A. Kroop, Esq. Perkins Coie LLP 2901 N Central Ave, Suite 2000 Phoenix AZ 85012

David L. Buchbinder, Esq.Jaclyn Weissgerber, Esq. Office of the U.S. TrusteeJ. Caleb Boggs Federal BuildingSuite 2207Wilmington, DE 19801

Bruce D. Buechler, Esq.Lowenstein Sandler LLP One Lowenstein DriveRoseland, New Jersey 07068

Christopher M. Samis, Esq. L. Katherine Good, Esq. Aaron H. Stulman, Esq. Whiteford, Taylor & Preston LLC The Renaissance Centre405 North King Street, Suite 500 Wilmington, Delaware 19801

/s/ Kevin S. Mann Kevin S. Mann (No. 4576)


Documents

IN THE UNITED STATES BANKRUPTCY COURT … Crazy Eddie, the Court considered petitioning creditors’ request for compensation and expenses relating to the preparation, filing and adjudication