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 Page 1 of 5 Case 20-10755-BLS Doc 632-2 Filed 10/14/20 Page 9 of 16 Invoice # 5460A - 09/15/2020 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.