Case 20-10755-BLS Doc 632 Filed 10/14/20 Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
RAVN AIR GROUP, INC. et al.,1 Case No. 20-10755 (BLS)
Debtors. (Jointly Administered)
Related Docket No.: 224
NOTICE OF EXCESS FEES BY PROFESSIONAL UTILIZED IN THE ORDINARY COURSE OF BUSINESS
This notice (the “Notice of Excess Fees”) is provided pursuant to the Order Authorizing the Employment and Compensation of Professionals Utilized in the Ordinary Course of Business,
Effective Nunc Pro Tunc to the Petition Date [Docket No. 224] (the “OCP Order”)2 by Ashburn &
Mason, P.C. (the “Applicant”), which submitted its Declaration of Disinterestedness of Ashburn
& Mason, P.C. in Support of Retention as Ordinary Course Professional on June 4, 2020 [Docket
No. 302].
PLEASE TAKE NOTICE THAT to the extent the Applicant seeks fees in excess of the
OCP Monthly Cap or OCP Case Cap, such excess fees are subject to this Notice of Excess Fees.
PLEASE TAKE FURTHER NOTICE THAT attached hereto as Schedule 1 (the “Fee
Schedule”) is a summary of the total fees earned and total expenses incurred for the period of June
1, 2020 to September 30, 2020 (the “Fee Period”), and any actual distributions made by the Debtors to the Applicant for these fees and expenses.
1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s U.S. tax identification number are as follows: Ravn Air Group, Inc. (3047), Ravn Air Group Holdings, LLC (5356), JJM, Inc. (4858), HoTH, Inc. (9957), Peninsula Aviation Services, Inc. (6859), Corvus Airlines, Inc. (7666), Frontier Flying Service, Inc. (8091), and Hageland Aviation Services, Inc. (2754). The notice address for all of the Debtors is 4700 Old International Airport Road, Anchorage, AK 99502. 2 Capitalized terms not herein defined shall have the meanings ascribed to them in the OCP Order.
146484.01601/123937133v.1 Case 20-10755-BLS Doc 632 Filed 10/14/20 Page 2 of 2
PLEASE TAKE FURTHER NOTICE THAT attached as Exhibit A (the “Invoices”) are invoices from the Applicant for the total fees earned and total expenses incurred for the Fee Period.
PLEASE TAKE FURTHER NOTICE THAT, pursuant to the OCP Order, the Notice
Parties have fifteen (15) days after the date of this Notice of Excess Fees (the “Objection
Deadline”) to object in writing to fees described in the attached Schedule 1 and Exhibit A.
PLEASE TAKE FURTHER NOTICE THAT any Objection to the Notice of Excess Fees must: (i) be in writing; (ii) set forth the name of the objecting party; (iii) provide the basis for the
Objection and the specific grounds therefor; and (iv) be served by electronic mail on Debtors’ counsel at the following addresses: Keller Benvenutti Kim LLP, Attn: Tobias S. Keller, Esq. and
Jane Kim, Esq., [email protected], [email protected]; and Blank Rome LLP, Attn: Victoria A.
Guilfoyle, Esq., Stanley B. Tarr, Esq., Jose F. Bibiloni, Esq., [email protected], [email protected], [email protected]; so as to be received on or before 4:00 p.m.
(prevailing Eastern Time) on the Objection Deadline.
PLEASE TAKE FURTHER NOTICE THAT, pursuant to the OCP Order, if no Objection is timely served to a Notice of Excess Fees, the fees requested in the Notice of Excess Fees shall be deemed approved, and the Applicant may be paid 100% of its fees and 100% of its expenses without the need for further action from such Applicant.
Dated: October 14, 2020 ASHBURN & MASON, P.C. Anchorage, AK By: /s/ Michael S. Schechter Michael S. Schechter 1227 West 9th Avenue, Suite 200 Anchorage, AK 99501 Telephone: (907) 276-4331 Facsimile: (907) 277-8235 Email: [email protected]
2 146484.01601/123937133v.1 Case 20-10755-BLS Doc 632-1 Filed 10/14/20 Page 1 of 2
Schedule 1
(Fee Schedule)
146484.01601/123937133v.1 Case 20-10755-BLS Doc 632-1 Filed 10/14/20 Page 2 of 2
Actual Dates Fees Expenses Disbursements
June 1, 2020 to June 30, 2020 $18,025.00 $469.15 $0
July 1, 2020 to July 31, 2020 $24,407.50 $320.36 $0
August 1, 2020 to August 31, $32,165.00 $3,580.59 $0 2020
September 1, 2020 to $25,987.50 $1,950.03 $0 September 30, 2020
146484.01601/123937133v.1 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 1 of 16
Exhibit A
(Invoices for Fee Period)
-2- 146484.01601/123937133v.1 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 2 of 16 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 3 of 16 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 4 of 16 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 5 of 16 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 6 of 16 Invoice # 4964 - 08/12/2020
07/24/2020 Draft Acceptance of Assignments. Heidi Wyckoff 0.60 $125.00 $75.00
07/24/2020 Attention to correspondence re assignment Michael Schechter 3.50 $350.00 $1,225.00 and real estate issues; draft assignment documents
07/26/2020 Attention to correspondence re assignment Michael Schechter 0.80 $350.00 $280.00 and real estate issues; draft assignment documents
07/27/2020 Witness and notarize Assignments of Leases. Heidi Wyckoff 1.00 $125.00 $125.00
07/27/2020 Discuss issues with John Mannion; finalize Michael Schechter 3.30 $350.00 $1,155.00 assignment documents for signature; attention to correspondence re assignment and real estate issues
07/28/2020 Attention to correspondence and documents Michael Schechter 1.90 $350.00 $665.00 for State Airport lease assignments and other real property transactions
07/29/2020 Attention to documents and correspondence Michael Schechter 1.60 $350.00 $560.00 re assignment of State airport leases
07/30/2020 Finalize Tatonduk Assignment of Lease packet Heidi Wyckoff 1.00 $125.00 $125.00 and transmit to Clark Cox.
07/30/2020 Attention to correspondence and application Michael Schechter 2.10 $350.00 $735.00 materials re assignment of State airport leases
07/31/2020 Attention to correspondence and application Michael Schechter 0.30 $350.00 $105.00 materials re assignment of State airport leases
Services Subtotal $24,407.50
Expenses
Date Notes Rate Total
07/29/2020 Federal express charges for delivery of documents to David Pfliger. $94.30 $94.30
07/29/2020 Federal express charges for delivery of documents to John Mannion. $90.39 $90.39
07/31/2020 Courier Service: July 2020 courier service. $75.69 $75.69
07/31/2020 Westlaw: July 2020 legal research charges. $59.98 $59.98
Expenses Subtotal $320.36
Subtotal $24,727.86
Total $24,727.86
Please make all checks payable to: Ashburn & Mason, P.C.
Page 3 of 4 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 7 of 16 Invoice # 4964 - 08/12/2020
You can pay securely online via https://secure.lawpay.com/pages/ashburnandmason/operating. Please include your invoice number in the "reference" field.
10.5% simple annual interest will be charged every 30 days after the invoice due date.
Page 4 of 4 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 8 of 16
1227 West 9th Avenue, Suite 200 Anchorage, AK 99501 United States INVOICE
Invoice # 5460A Date: 09/15/2020 Due On: 10/15/2020
Corvus Airlines, Inc. d/b/a Ravn Air Group
00001-Corvus Airlines, Inc. d/b/a Ravn Air Group: DOT Lease Review
DOT Lease Review
Services
Date Notes Attorney Quantity Rate Total
08/01/2020 Record Tatonduk Consent(s) to Assignment of Heidi Wyckoff 0.40 $125.00 $50.00 Lease.
08/03/2020 Attention to correspondence, documentation, Michael Schechter 6.90 $350.00 $2,415.00 and research in support of Bering Air, Grant Aviation, Yute, and Everts sales
08/04/2020 Draft assignment documents; attention to Michael Schechter 3.90 $350.00 $1,365.00 email correspondence re real estate transfers and documentation; review for King Salmon
08/05/2020 Research and analysis ; Michael Schechter 4.20 $350.00 $1,470.00 attention to correspondence re multiple sale lots; discuss sale issues with buyer's counsel for Yute; prepare leasehold assignment documentation
08/06/2020 Discuss assignment and real estate issues Michael Schechter 2.90 $350.00 $1,015.00 with Dave Pflieger and John Jackson; attention to assignment correspondence and documentation; discuss assignment issues with Statewide Aviation Leasing chief
08/07/2020 Research re ; draft Michael Schechter 8.10 $350.00 $2,835.00 memorandum of lease for St. Mary's airport
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property; attention to correspondence and documentation re lease assignments and other real estate issues
08/08/2020 Research re ; attention to Michael Schechter 2.70 $350.00 $945.00 correspondence and documentation re lease assignments and other real estate issues
08/10/2020 Discuss sale issues with Everts representative; Michael Schechter 3.50 $350.00 $1,225.00 research and review ; attention to correspondence and documentation re multiple sale lots
08/11/2020 Draft Quitclaim Deeds. Original documents to Heidi Wyckoff 0.80 $125.00 $100.00 Worldox.
08/11/2020 Attention to documentation and Michael Schechter 4.40 $350.00 $1,540.00 correspondence re ; research re issues; research re
08/12/2020 Research and analysis re Michael Schechter 6.50 $350.00 $2,275.00 ; discuss real estate issues with Dave Pflieger and John Jackson; attention to documentation and correspondence re State leasehold issues; discuss assignments with Float Alaska counsel; research re
08/13/2020 Prepare cover letter to State Leasing Agent. Heidi Wyckoff 0.20 $125.00 $25.00
08/13/2020 Research and analysis re Michael Schechter 7.90 $350.00 $2,765.00 ; attention to documentation and correspondence re State leasehold issues; research re ; review and revise Bethel quitclaim deeds; discuss Palmer issues with Toby Keller
08/14/2020 Discuss closing issues with Bering Air counsel; Michael Schechter 3.70 $350.00 $1,295.00 attention to state assignment documents and communications; research and analysis re
08/17/2020 Discuss sale issues with Bering Air counsel; Michael Schechter 1.60 $350.00 $560.00 attention to correspondence and documentation re multiple sale lots;
08/18/2020 Draft Tweto Quitclaim Deed. Heidi Wyckoff 0.20 $125.00 $25.00
08/18/2020 Revisions to Grant Air Quitclaim Deeds> Heidi Wyckoff 0.30 $125.00 $37.50
08/18/2020 Draft and revise real estate transfer Michael Schechter 7.20 $350.00 $2,520.00 documents (quitclaim deeds, memoranda of lease); discuss sale issues with Yute counsel and BK team; discuss state review issues with Aviation Leasing; attention to correspondence and documentation re various real estate
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issues; research re
08/19/2020 Attention to documentation and Michael Schechter 3.90 $350.00 $1,365.00 correspondence re State assignments and other Alaska real estate issues; phone conferences with BK team re ; research re
08/20/2020 Draft and revise real estate transfer Michael Schechter 2.10 $350.00 $735.00 documents (quitclaim deeds, memoranda of lease); discuss state review issues with Aviation Leasing; attention to correspondence and documentation re various real estate issues; research re
08/21/2020 Attention to documentation and Michael Schechter 4.40 $350.00 $1,540.00 correspondence re State assignments and other Alaska real estate issues; research re
08/23/2020 Attention to correspondence; review draft Michael Schechter 1.80 $350.00 $630.00 promissory note assignment; research re
08/24/2020 Discuss state review issues with Aviation Michael Schechter 2.00 $350.00 $700.00 Leasing; attention to correspondence and documentation re various real estate issues; attention to St. Mary's residential quitclaim deed issues
08/25/2020 Attention to documentation and Michael Schechter 1.30 $350.00 $455.00 correspondence re State assignments and other Alaska real estate issues
08/26/2020 Attention to documentation and Michael Schechter 3.70 $350.00 $1,295.00 correspondence re State assignments and other Alaska real estate issues; research and analysis
08/27/2020 Draft Quitclaim Deeds-Alex Virg-in and Heidi Wyckoff 0.40 $125.00 $50.00 Rosalind Schmeling.
08/27/2020 Draft Wright Air Service, Inc. Quitclaim Deeds Heidi Wyckoff 0.50 $125.00 $62.50 for Lot 3, Block 5, Resubdivision of Barrow Townsite and Lot 2, Block 12, Browerville Addn. No. 3.
08/27/2020 Attention to documentation and Michael Schechter 2.70 $350.00 $945.00 correspondence re State assignments and other Alaska real estate issues; research and analysis re
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08/28/2020 Attention to documentation and Michael Schechter 3.20 $350.00 $1,120.00 correspondence re State assignments and other Alaska real estate issues
08/31/2020 Attention to documentation and Michael Schechter 2.30 $350.00 $805.00 correspondence re State assignments and other Alaska real estate issues
Services Subtotal $32,165.00
Expenses
Date Notes Rate Total
08/20/2020 State of Alaska Recording Fees for Consent of Assignment of Lease. $50.00 $50.00
08/24/2020 State of Alaska Recording Fees for Consent to Assignment of Lease ADA $40.00 $40.00 03642.
08/24/2020 State of Alaska Recording Fees for recording Consent to Assignment of $45.00 $45.00 Lease ADA 70442.
08/24/2020 State of Alaska Recording Fees for recording Consent to Assignment of $45.00 $45.00 Lease ADA 00627.
08/24/2020 State of Alaska Recording Fees for recording Consent to Assignment of $40.00 $40.00 Lease ADA 71262.
08/24/2020 State of Alaska Recording Fees for recording Consent to Assignment of $40.00 $40.00 Lease ADA 71438.
08/25/2020 State of Alaska Recording Fees for Quitclaim Deed (Grant Aviation). $30.00 $30.00
08/25/2020 Ashburn & Check No. 26728 paid to Mohave County Constable-Kingman. $70.00 $70.00
08/27/2020 Ashburn & Mason check no. 26737 for to Yukon Title Company in payment $325.00 $325.00 of Invoice Y20-09853-2 for recording of documents re Lot 9A, Block 1, Replat of Lot 9 and Lot 38 Martina Oscar Subdiv Plat 92-1
08/27/2020 State of Alaska fees for recording Memorandum of Lease (Barrow). $40.00 $40.00
08/27/2020 State of Alaska recording fees for recording Memorandum of Lease (Bethel). $40.00 $40.00
08/31/2020 Federal express charges for documents sent via overnight to Roseann $80.72 $80.72 Schmeling and Alex Virg-in.
08/31/2020 Courier Service: August 2020 courier charges. $214.58 $214.58
08/31/2020 Postage: August 2020 postage charges. $90.60 $90.60
08/31/2020 Legal research charges for August 2020. $2,429.69 $2,429.69
Expenses Subtotal $3,580.59
Subtotal $35,745.59
Page 4 of 5 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 12 of 16 Invoice # 5460A - 09/15/2020
Total $35,745.59
Please make all checks payable to: Ashburn & Mason, P.C. You can pay securely online via https://secure.lawpay.com/pages/ashburnandmason/operating. Please include your invoice number in the "reference" field.
10.5% simple annual interest will be charged every 30 days after the invoice due date.
Page 5 of 5 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 13 of 16
1227 West 9th Avenue, Suite 200 Anchorage, AK 99501 United States INVOICE
Invoice # 5780A Date: 10/07/2020 Due On: 11/15/2020
Corvus Airlines, Inc. d/b/a Ravn Air Group
00001-Corvus Airlines, Inc. d/b/a Ravn Air Group: DOT Lease Review
DOT Lease Review
Services
Date Notes Attorney Quantity Rate Total
09/01/2020 Discuss assignment and real estate issues Michael Schechter 6.10 $350.00 $2,135.00 with State leasing office, Yuite Team, and Float team; draft sublease assignment materials; attention to correspondence and records research
09/02/2020 Participate in phone call with Wright counsel Michael Schechter 8.30 $350.00 $2,905.00 and BK team; draft trustee and quitclaim deeds for Wright Air; research re
09/03/2020 Draft trustee and quitclaim deeds for Wright Michael Schechter 3.90 $350.00 $1,365.00 Air; attention to Float sublease documents and correspondence; attention to ongoing real property and assignment issues
09/04/2020 Discuss with BK team Michael Schechter 0.30 $350.00 $105.00
09/06/2020 Draft assignment to Wright Air for Barrow Michael Schechter 2.70 $350.00 $945.00 residential lease; prepare and review material for lot closing; attention to corroespondence
09/09/2020 Attention to Yute Lot 3 closing details and Michael Schechter 4.70 $350.00 $1,645.00 management; research re ; participate in call re
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09/10/2020 Record Quitclaim Deeds. Heidi Wyckoff 0.20 $125.00 $25.00
09/10/2020 Research and analysis re Michael Schechter 7.70 $350.00 $2,695.00 ; attention to correspondence with State and buyers' counsel regarding open transactions; discuss with BK team and Ravn officers
09/11/2020 Attention to Cape Smythe deed of trust and Michael Schechter 6.80 $350.00 $2,380.00 title issues including research and emails; discuss open transactions with Statewide Aviation Northern Region; attention to correspondence regarding transaction issues and closeout; discuss sale issues with Wright counsel
09/11/2020 Record Trustee Deeds. Heidi Wyckoff 0.30 $125.00 $37.50
09/12/2020 Discuss with Michael Schechter 1.70 $350.00 $595.00 Jane Kim; research and analysis re same
09/13/2020 Research and analysis re ; Michael Schechter 2.50 $350.00 $875.00 revise draft substitution of counsel and reconveyance
09/14/2020 Attention to correspondence and Michael Schechter 2.30 $350.00 $805.00 documentation for remaining open sale lots
09/15/2020 Discuss with John Jackson; Michael Schechter 4.10 $350.00 $1,435.00 attention to correspondence re leasehold assignments and payments; attention to ; draft memorandum of lease
09/16/2020 Attention to real estate transactions and Michael Schechter 2.30 $350.00 $805.00 related correspondence
09/17/2020 Attention to real estate transactions and Michael Schechter 2.10 $350.00 $735.00 related correspondence
09/18/2020 Attention to real estate transactions and Michael Schechter 2.60 $350.00 $910.00 related correspondence; discuss FLOAT issues with AIAS controller
09/18/2020 Prepare and record Consent to Assignment of Heidi Wyckoff 0.10 $125.00 $12.50 Lease.
09/18/2020 Prepare and record Trustee's Deed. Heidi Wyckoff 0.10 $125.00 $12.50
09/21/2020 Attention to real estate transactions and Michael Schechter 1.40 $350.00 $490.00 related correspondence including ; follow-up with AIAS controller re FLOAT issues
09/22/2020 Attention to real estate transactions and Michael Schechter 2.30 $350.00 $805.00 related correspondence including
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09/23/2020 Attention to real estate transactions and Michael Schechter 1.50 $350.00 $525.00 related correspondence including
09/28/2020 Attention to real estate transactions and Michael Schechter 3.70 $350.00 $1,295.00 related correspondence and phone calls including
09/29/2020 Attention to real estate transactions and Michael Schechter 5.10 $350.00 $1,785.00 related correspondence and phone calls including
09/30/2020 Attention to real estate transactions and Michael Schechter 1.90 $350.00 $665.00 related correspondence and phone calls including
Services Subtotal $25,987.50
Expenses
Date Notes Rate Total
08/21/2020 USPS shipping charges for mailing documents to Penny Adler. $26.35 $26.35
09/01/2020 State of Alaska recording fees for Memorandum of Lease-ADA 71892-Lot 7A $40.00 $40.00 Block 100 Barrow Airport.
09/02/2020 State of Alaska Recording Fees for recording Consent to Assignment of Lease $40.00 $40.00 (Bethel).
09/02/2020 State of Alaska Recording Fees for recording Consent to Assignment of Lease $40.00 $40.00 (Bristol Bay).
09/02/2020 State of Alaska Recording fees for recording Consent to Assignment of Lease $40.00 $40.00 (Kvichak).
09/03/2020 State of Alaska Recording Fee charges for recording Memorandum of Lease $40.00 $40.00 ADA 72230-Nulato Recording District.
09/10/2020 State of Alaska recording fees for recordation of Quitclaim Deed for Lot 14 $30.00 $30.00 Block 6-Hageland Aviation.
09/10/2020 State of Alaska Recording fees for recordation of Quitclaim Deed for Lot 10 $35.00 $35.00 Block 6-Rosalind Schmeling to Hageland Aviation.
09/10/2020 State of Alaska Recording fees for recordation of Quitclaim Deed for Lot 10, $35.00 $35.00 Block 6-Alex Virg-in to Hageland Aviation.
09/11/2020 State of Alaska recording fees for Trustee Deed Lot 11 E. $35.00 $35.00
09/11/2020 State of Alaska recording fees for Trustee Deed Lot 4. $35.00 $35.00
09/15/2020 State of Alaska DNR charges for recording Substitution of Trustee and Full $40.00 $40.00 Reconveyance.
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09/18/2020 State of Alaska Recording Fees for recordation of Consent to Assignment of $45.00 $45.00 Lease.
09/18/2020 State of Alaska recording fees for Trustee's Deed. $35.00 $35.00
09/23/2020 State of Alaska Recording fees for recordation of Consent to Assignment of $40.00 $40.00 Lease ADA 71424.
09/23/2020 State of Alaska Recording Fees for recordation of Consent to Assignment of $40.00 $40.00 Lease ADA 72032.
09/28/2020 Alaska Air Cargo shipping charges for paperwork. $47.00 $47.00
09/30/2020 Courier Service: September 2020 courier charges. $321.56 $321.56
09/30/2020 Photocopying: September 2020 photocopy charges. $3.00 $3.00
09/30/2020 Postage: September 2020 postage charges. $7.15 $7.15
09/30/2020 Westlaw: September 2020 legal research charges. $969.05 $969.05
09/30/2020 September 2020 conference call charges. $5.92 $5.92
Expenses Subtotal $1,950.03
Subtotal $27,937.53
Total $27,937.53
Please make all checks payable to: Ashburn & Mason, P.C. You can pay securely online via https://secure.lawpay.com/pages/ashburnandmason/operating. Please include your invoice number in the "reference" field.
10.5% simple annual interest will be charged every 30 days after the invoice due date.
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