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Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 1 of 18 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: § § ECHO ENERGY PARTNERS I, LLC § Case No. 20-31920 (DRJ) § Debtor. § Chapter 11 FIRST AND FINAL FEE APPLICATION COVER SHEET Name of Applicant Bracewell LLP Applicant’s Professional Role Debtor’s Counsel Interim or a Final Application Final Effective Date of Professional’s Retention March 24, 2020 Beginning Period Ending Period Time Period Covered in March 24, 2020 October 16, 2020 Application Total Amount of Retainer Received $0 Total Fees Applied for in this Application and in all Prior $1,742,277.00 Applications (including any retainer amounts applied or to be applied) Total Fees Applied for in this Application (including any $1,742,277.00 retainer amounts applied or to be applied) Total Professional Fees Requested in this Application $1,734,344.00 Total Professional Hours Covered in this Application 2,679.00 Average Hourly Rate for Professionals $728.33 Total Paraprofessional Fees Requested in this Application $7,883.00 Total Paraprofessional Hours Requested in this 21.40 Application Average Hourly Rate for Paraprofessionals $335 Reimbursable Expenses Requested $9,108.59 If a plan has been proposed, total to be paid to unsecured $0 creditors under the plan Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 2 of 18 If a plan has been proposed, percentage dividend to be 0% paid to unsecured creditors under the plan If a plan has been proposed, total to be paid to all pre- $27,459,090.00 petition creditors under the Plan Date of Confirmation Hearing September 29, 2020 Indicate whether a plan has been confirmed Yes HOUSTON/2393483 2 Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 3 of 18 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: § § ECHO ENERGY PARTNERS I, LLC § Case No. 20-31920 (DRJ) § Debtor. § Chapter 11 FIRST AND FINAL EMERGENCY APPLICATION OF BRACEWELL LLP, AS COUNSEL TO THE DEBTOR, FOR COMPENSATION OF PROFESSIONAL SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD MARCH 24, 2020 THROUGH OCTOBER 16, 2020 Emergency relief has been requested. A hearing will be conducted on this matter on November 4, 2020 at 3:00 p.m. in Courtroom 400, 4th floor, 515 Rusk Street, Houston, Texas, 77002. You may participate in the hearing either in person or by audio/video connection. Audio communication will be by use of the Court’s dial-in facility. You may access the facility at (832) 917-1510. You will be responsible for your own long-distance charges. Once connected, you will be asked to enter the conference room number. Judge Jones conference room number is 205691. You may view video via GoToMeeting. To use GoToMeeting, the Court recommends that you download the free GoToMeeting application. To connect, you should enter the meeting code “JudgeJones” in the GoToMeeting app or click the link on Judge Jones’s home page on the Southern District of Texas website. Once connected, click the settings icon in the upper right corner and enter your name under the personal information setting. Hearing appearances must be made electronically in advance of the hearing. To make your electronic appearance, go to the Southern District of Texas website and select “Bankruptcy Court” from the top menu. Select “Judges’ Procedures,” then “View Home Page” for Judge Jones. Under “Electronic Appearance” select “Click here to submit Electronic Appearance”. Select the case name, complete the required fields and click “Submit” to complete your appearance. If you object to the relief requested or you believe that emergency consideration is not warranted, you must either appear at the hearing or file a written response prior to the hearing. Otherwise, the Court may treat the pleading as unopposed and grant the relief requested. Relief is requested not later than November 4, 2020. TO THE HONORABLE DAVID R. JONES, CHIEF UNITED STATES BANKRUPTCY JUDGE: Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 4 of 18 Bracewell LLP (“Bracewell”), bankruptcy counsel for the Debtor, files this First and Final Application for Compensation of Professional Services Rendered and Reimbursement of Expenses for the period March 24, 2020, through October 16, 2020 (the “Application”), and states the following in support thereof: INTRODUCTION 1. This Court has jurisdiction over this matter under 28 U.S.C. § 1334 and Article XIII of the Debtor’s Chapter 11 Plan of Liquidation [Dkt. No. 300] (the “Plan”). This is a core proceeding under 28 U.S.C. § 157(b) and venue is proper in this Court under 28 U.S.C. §§ 1408 and 1409. 2. On March 24, 2020, the Debtor filed a voluntary petition for relief under chapter 11 of Title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. With its original petition, the Debtor contemporaneously filed a Notice of Designation as Complex Chapter 11 Bankruptcy Case and this Court granted such status on March 27, 2020 [Docket No. 8]. 3. On May 21, 2020, the Court entered an order granting the application to employ Bracewell as Debtor’s counsel [Docket No. 163]. 4. On May 21, 2020, the Court entered the Order Establishing Uniform Procedures for Interim Compensation and Reimbursement of Expenses for Professionals (the “Procedures Order”)1 which establishes guidelines for payment of professional fees for services and expenses incurred on a monthly basis, subject to a 20% holdback on fees, and no holdback on expenses [Docket No. 162]. 5. On September 29, 2020, the Plan was confirmed and on October 16, 2020 the Plan became effective. 1 All terms capitalized herein and not otherwise defined shall have the meaning assigned to them in the Procedures Order. HOUSTON/2393483 4 Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 5 of 18 6. All professional services for which Bracewell requests compensation and allowance in this Application were performed for the period March 24, 2020, through October 16, 2020 (the “Application Period”), for and on behalf of the Debtor. No agreement or understanding exists between Bracewell and any other person with respect to the sharing of compensation sought herein, except that the compensation approved by the Court will be shared among Bracewell’s partners, associates, and personnel as authorized under the Bankruptcy Code. SUMMARY OF COMPENSATION REQUESTED 7. Bracewell submits this Application for approval and payment of fees and expenses incurred from March 24, 2020, through September 30, 2020 as well as payment of the 20% holdback for the period March 24, 2020, through September 30, 2020, and payment of 100% of fees incurred from October 1, 2020 to October 16, 2020. Pursuant to the Procedures Order, Bracewell has submitted monthly fee and expense statements (“Monthly Statements”) to the Debtor, counsel for Texas Capital Bank, N.A. (the “Agent”), and the United States Trustee for the Southern District of Texas (the “U.S. Trustee”) (collectively, the “Fee Parties”) during the Application Period, with the exception of the fees requested for the month of October. Set forth below is a summary of the fees and expenses requested in each of the monthly fee statements for the Application Period. Detailed summaries of the fees and expenses requested during this Application Period are also included in each of the monthly fee statements. Period Covered 100 Percent of 80 Percent of 100 Percent of Total Amount of Fees Fees Expenses Fees and Expenses March/April 2020 $461,044.50 $368,835.60 $401.90 $461,446.40 May 2020 $113,730.75 $90,984.60 $855.45 $114,616.20 June 2020 $594,568.00 $475,654.40 $7,693.23 $602,261.23 July 2020 $301,613.50 $241,290.80 $58.01 $301,671.51 HOUSTON/2393483 5 Case 20-31920 Document 368 Filed in TXSB on 10/28/20 Page 6 of 18 Period Covered 100 Percent of 80 Percent of 100 Percent of Total Amount of Fees Fees Expenses Fees and Expenses August 2020 $117,263.25 $93,810.60 $0 $117,263.25 September 2020 $102,519.00 $82,015.20 $100 $102,619.00 October 2020 $51,488.00 $41,190.402 $0 $51,488.00 Total $1,742,227.00 $1,393,781.60 $9,108.59 $1,751,365.59 8. The following is a comprehensive summary of each Bracewell professional who has worked on this chapter 11 case and for whom Bracewell seeks compensation. The summary includes each attorney’s name, position, area of practice, time expended, hourly billing rate, and fees incurred as part of the total amount of compensation requested herein: PROFESSIONAL POSITION GROUP/OFFICE HOURLY HOURS TOTAL RATE William A. Wood, III Partner Financial Restructuring $1,075.00 153.50 $165,012.50 Jason G. Cohen Partner Financial Restructuring $865.00 175.20 $151,548.00 Austin T. Lee Partner Oil & Gas $850.00 314.1 $266,985.00 Dewey J. Gonsoulin Partner Finance $1,100.00 15.20 $16,720.00 Rebecca L. Baker Partner Labor and Employment $800.00 5.50 $4,400.00 Scott C. Sanders Partner Tax $950.00 4.00 $3,800.00 Steven Lorch Partner Tax $950.00 26.20 $24,890.00 Whit Swift Partner Environmental $795.00 4.30 $3,418.50 W. Cleland Dade Partner Corporate & Securities $1,075.00 1.80 $1,935.00 Jennifer N. Dill Counsel Finance $800.00 27.30 $21,840.00 Andrew P. Mintz Associate Oil & Gas $515.00 270.80 $139,462.00 Andrew W.