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Winston & Strawn's Cover Sheet Application for Allowance

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Winston & Strawn's Cover Sheet Application for Allowance 1 Donald K. Dankner (No. 0186536) Thomas Blakemore (No. 03121566) 2 David Agay (No. 06244314) WINSTON & STRAWN 35 West Wacker, Suite 4200 4 Chicago, IL 60601 312-558-5600 (Phone) 5 312-558-5700 (Facsimile) Debtors and Debtors in Possession 6 Counsel to 7 S STATES BANKRUPTCY COURT 9 UNITED DISTRICT OF CALIFORNIA 10 NORTHERN SAN FRANCISCO DIVISION 11 Case No. 01-30923 DM 12 In re Chapter 11 Case 13 PACIFIC GAS AND ELECTRIC COMPANY, a California corporation, [No Hearing Scheduled] 14 Debtor. 15 Federa-l I.D. No. 94-0742640 16 SHEET APPLICATION FOR 17 WINSTON & STRAWN'S COVER ALLOWANCE AND PAYMENT OF INTERIM COMPENSATION 18 AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD NOVEMBER 30, 2001 19 NOVEMBER 1, 2001 THROUGH (the "Application") "Firm") submits its Cover Sheet Application 20 Winston & Strawn (the for the Compensation and Reimbursement of Expenses 21 for Allo-.,vance and Payment of Interim (the "Application Period"). In support of the 22 Period o:f November 1, 2001- November 30, 2001 23 Application, the Firm respectfully represents as follows: to 24 1. Pursuant to the Amendment to the Amended Application for Authority 25 dated as of September 13, 2001, the Employ and to continue the Employment of Special Counsel 26 "Debtor"), employed under section to the debtor and debtor-in-possession (the 27 Firm is Counsel the Order Establishing 11 U.S.C. § 101 et. segi. Pursuant to 28 327(e) o f the Bankruptcy Code, C11-97563 .1 1 Interim Fee Application and Expense Reimbursement Procedure entered on July 26, 2001 (the 2 "Fee Order"), the Firm hereby applies to the Court for allowance and payment of interim 3 compensation for services rendered and reimbursement of expenses incurred during the 4 Application Period. 5 2. The Firm billed a total of $358,222.38 in fees and expenses during the 6 during the Application 7 Application Period. The Total fees represent 1,208.49 hours expended 8 Period. These fees and expenses break down as follows: 9 Period Fees Expenses Total 10 November 1, 2001- $334,099.20 $24,123.18 $358,222.38 11 November 30, 2001 12 3. Accordingly, the Firm seeks allowance of interim compensation in the 13 total amount of $308,107.50 at this time. This total is comprised as follows: 14 $283,984.32 (85% of the fees for services rendered)' plus $24,123.18 (100% of the expenses 15 incurred). 16 4. Pursuant to the Stipulation and Order Regarding Employment of Winston 17 18 & Strawn as Special Counsel to the Debtor in Possession dated September 24, 2001 (the 19 "Stipulation"), the Firm's reimbursement for all fees and expenses incurred by the Firm as special 20 counsel to Debtor through July 31, 2001, is governed by the Order entered on August 16, 2001, 21 approving the Amended Application for Authority to Employ and Continue the Employment of 22 Special Council (the "Omnibus Order"). Pursuant to the Stipulation and Omnibus Order, the 23 Firm has not and will not submit Applications for fees and expenses incurred through July 31, 24 25 2001 26 5. To date, the Firm has submitted invoices for the following post-petition 27 services directly to the debtor. 28 'Payment of this amount would result in a "holdback" of $50,144.88. 2 CI11:975637.1 Outstanding 1 A lication Period Amount Due Amount Paid Amount $0.00 $117,735.06 $117,494.31 2 June 1, 2001-June 30, $169,197.43 $0.00 3 July 1, 2001-July31, $169,199.53 $117,494.31 for the June 1, 2001 - June 4 6. To date, the Firm has been paid 5 30, 2001 period and $ 169,197.43 for the July 1, 2001 - July 31, 2001 period. 6 to the Court for the date, the Firm has submitted Applications 7 7. To owed pursuant to this application. 8 following post-petition services excluding amounts Expenses Total Application Period Fees $16,381.43 $197,679.18 10 10August Auust 31,2001 1, 2001 - $181,297.75 $8,320.04 $238,277.39 11 September 1, 2001- $229,957.35 Se tember 30 2001 2 0 0 $25,641.76 $332,233.61 12 October 1, 1 - $306,591.85 I October 31, 2001 for the August 1, 2001 13 8. To date, the Firm has been paid $169,672.07 and $0.00 14 August 30, 2001 period; $203,781.84 for the September 1, 2001-September 31, 2001 15 for the October 1, 2001- October 31, 2001 period. 16 is owed for the following post-petition services, 17 9. To date, the Firm 18 excluding amounts owed pursuant to this application. Owed 19 Owed Expenses Owed Total A plication Period Fees $27,194.77 31, 2001 $0.00 20 August 1,2001 - $27,194.77 $0.00 $34,493.61 21 September 1, 2001- $34,493.61 30, 2001 September $25,641.76 $332,233.61 22 October 1, 2001 - $306,591.85 October 31, 2001 23 served on counsel for the regard to the copies of this Application 24 10. With (a) attached as and the Office of the United States Trustee, 25 Committee, counsel for the Debtor who performed services in connection with this 26 Exhibit I hereto is the name of each professional rate for each such professional; 27 case during the period covered by this Application and the hourly 28 time and expense statements for the Application and (b) attached as Exhibit 2 are the detailed 3 I1C111:975637.1 and 1 Period that comply with all Northern District of California Bankruptcy Local Rules Trustee. 2 Compensation Guidelines and the Guidelines of the Office of the United States 3 11. The Firm has served a copy of this Application (without Exhibits) on the 4 Special Notice List in this case. 5 Fee Order, the Debtor is authorized to make the 6 12. Pursuant to this Court's order of this Court unless an objection to 7 payment requested herein without a further hearing or the United States 8 this Application is filed with the Court by the Debtor, the Committee or Application. If 9 Trustee and served by the fifteenth day of the month following the service of this 10 such an objection is filed, Debtor is authorized to pay the amounts, if any, not subject to the by objection. The Firm is informed and believes that this Cover Sheet Application was mailed 12 postage prepaid, on or about December 27, 2001. 13 first class mail, and reimbursement of expenses sought in this 14 13. The interim compensation conclusion of this case, the Firm will seek 15 Application is on account and is not final. Upon the rendered in the 16 fees and reimbursement of the expenses incurred for the totality of the services 17 case. Any interim fees or reimbursement of expenses approved by this Court and received by the 18 Finn will be credited against such final fees and expenses as may be allowed by this Court. 19 14. The Firm represents and warrants that its billing practices comply with all 20 the Bankruptcy Local Rules and Compensation Guidelines and 21 Northern District of California the Firm nor any members of the 22 Guidelines of the Office of the United States Trustee. Neither nature to divide, pay over or share any 23 Firm has any agreement or understanding of any kind or person or attorney 24 portion of the fees or expenses to be awarded to the Firm with any other 25 except as among the members and associates of the Firm. 26 WHEREFORE, the Firm respectfully requests that the Debtor pay compensation 27 Fee Order. to the Firm as requested herein pursuant to and in accordance with the terms of the 28 4 Ci11:975637.1 II I I I Dated:__"_____"___.__WINSTON & STRAWN 2 By: SOne of ts Attorneys. 327(e) Counsel to .ebiors and Debtors in Possession 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 Exhibit One Pacific Gas & Electric Company Time Keeper Summary Attorney/Other Prof Rate D. Dankner $375.00 F. Killion $350.00 G. Farano $350.00 I. Dennis $275.00 D. Repka $325.00 W. Horin $300.00 I. Whittaker $300.00 W. Madden $300.00 P. Campbell $235.00 S. Fallon $175.00 S. Hernandez $245.00 D. Agay $190.00 J. Dempsey $175.00 B. Poole $190.00 L Rafky $225.00 C. Fleming $190.00 C. Sisco $120.00 P. Stepan $125.00 N. Scaravalle $100.00 J. Liaw $110.00 I Criner $110.00 Ci0:977012.1 WINSTON & STRAWN EX H 181I 1400 L Street, N.W. Washington, DC 20005-3502 TAX ID NO. 36-1975990 Pacific Gas & Electric Company Invoice No. 1678708 Invoice Date 12/17/01 PG&E Law Department 101239 Attn: Ms. Theresa Lett Client Matter No. P.O. Box 7442 San Francisco, CA 94120 For Legal Services Rendered through November 30, 2001 In Connection With: 00046 FERC and NRC Regulatory Issues Legal Services: $317,061.00 $19,29520 For disbursements and other charges incurred: S336,856.20 Total of Services and Disbursements WINSTON & STRAWN Invoice No. 1678708 Pacific Gas & Electric Company Invoice Date 12/17/01 Page No. 2 00046 FERC and NRC Regulatory Issues Date Attorney/Other Prof Hours Description Work on decommissioning issue 11/07/01 G. Farano 2.50 decommissioning issue 11/08/01 G. Farano 2.50 Work on on decommissioning issue 11/09/01 G. Farano 2.50 Work decommissioning issue 11/12/01 G.
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