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BERMAN AND TODDERUD LLP

Stan Berman 

(stan@btlawllp.com)

Eric Todderud

(eric@btlawllp.com) 

701 Fifth Avenue

Suite 4200

Seattle, WA 98104

Tel: (206) 262-7682

Special Counsel for Debtors and Debtors in Possession

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

- and –

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

 Affects PG&E Corporation

 Affects Pacific Gas and Electric 

Company

: Affects both Debtors

* All papers shall be filed in the Lead Case 

No. 19-30088 (DM).

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

SUMMARY SHEET TO FIRST INTERIM FEE 

APPLICATION OF BERMAN AND TODDERUD 

LLP FOR ALLOWANCE AND PAYMENT OF 

COMPENSATION AND REIMBURSEMENT OF 

EXPENSES (FEBRUARY 1, 2019 THROUGH 

MAY 31, 2019)

Date: TBD 

Time: TBD

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Judge: Hon. Dennis Montali

Objection Deadline: November 12, 2019 4:00 p.m. (Pacific Time)

GENERAL INFORMATION

Name of Applicant: Berman and Todderud LLP (“Berman and Todderud” or the 

“Firm”) 

Authorized to Provide 

Professional Services to: Special Counsel for Debtors and Debtors in Possession

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Petition Date: January 29, 2019 

Retention Date: July 3, 2019, effective February 1, 2019 

Prior Applications: None

SUMMARY OF FEES AND EXPENSES SOUGHT IN THIS APPLICATION

Amount of Compensation Sought as Actual, Reasonable, and Necessary: $396,292.40

Amount of Expense Reimbursement Sought as Actual, Reasonable, and Necessary: $0

Total Compensation and Expenses Requested for the Compensation Period: $396,292.40

SUMMARY OF PRIOR MONTHLY FEE STATEMENTS

Date Filed Period 

Covered

Requested 

Fees

Requested 

Expenses

Paid Fees Paid 

Expenses

Holdback 

Fees 

Requested

9/11/19

[Dkt. No. 3877]

2/1/19 –

2/28/19

$76,805.60 $0 $61,444.48 $0 $15,361.12

9/11/19

[Dkt. No. 3877]

3/1/2019-

3/31/2019

$86,127.60 $0 $68,902.08 $0 $17,225.52

9/11/19

[Dkt. No. 3877]

4/1/2019-

4/30/2019

135,308.80 $0 $108,247.04 $0 $27,061.76

9/11/19

[Dkt. No. 3877]

5/1/2019-

5/31/2019

98,050.40 $0 $78,440.32 $0 $19,610.08

$396,292.40 $0 $317,033.92 $0 $79,258.48

Summary of Any Objections to Monthly Fee Statements: None.

Compensation and Expenses Sought in this Interim Application Not Yet Paid: $79,258.48

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COMPENSATION BY PROFESSIONAL

FEBRUARY 1, 2019 THROUGH MAY 31, 2019

The attorneys and paraprofessionals who rendered legal services in these Chapter 11 Cases 

during the Interim Fee Period are:

NAME OF 

PROFESSIONAL: POSITION

YEAR

ADMITTED

HOURLY

RATE

TOTAL

HOURS

BILLED

TOTAL

COMPENSATION

Stan Berman Partner 1988 $920 213.60 $196,512.00

Eric Todderud Partner 1987 $692 288.70 $199,780.40

Total Professionals: 502.30 $396,292.40

1 Member of the California Bar since 2014

2 Member of the Texas Bar.

PROFESSIONALS

TOTALS:

BLENDED RATE

(rounded to nearest 

dollar)

TOTAL HOURS 

BILLED

TOTAL 

COMPENSATION

Partners and Counsel $789 502.3 $396,292.40

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COMPENSATION BY WORK TASK CODE

FEBRUARY 1, 2019 THROUGH MAY 31, 2019

Nearly all time billed by Berman and Todderud during the period February 1, 2019 through 

May 31, 2019 was for work in connection with a single project: pursuing litigation before the Federal 

Energy Regulatory Commission to recover refunds for the electric ratepayers of Pacific Gas and 

Electric Company for overcharges that occurred during the 2000-2001 California energy crisis. The 

work has been going on for many years, and resulted in several dozen settlement agreements and 

billions of dollars in recoveries, and the work has largely focused on implementing those agreements in 

a way that will allow the books to be finally closed out after the 2000-2001 California energy crisis. 

Because of the narrow scope of our work, it is difficult to segregate the billable time into discrete 

project codes. 

Separating our time into overlapping and subjective “project” categories would not 

meaningfully aid in the review of our bills. Rather, we provide a description of our work under the 

heading Project Billing and Narrative Statement of Services Rendered of the Fee Application.

EXPENSE SUMMARY

FEBRUARY 1, 2019 THROUGH MAY 31, 2019

Berman and Todderud did not incur any recoverable expenses during the relevant period. 

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BERMAN AND TODDERUD LLP

Stan Berman 

(stan@btlawllp.com)

Eric Todderud

(eric@btlawllp.com) 

701 Fifth Avenue, Suite 4200

Seattle, WA 98104

Tel: (206) 262-7682

Special Counsel for Debtors and Debtors in Possession

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION

In re:

PG&E CORPORATION,

- and –

PACIFIC GAS AND ELECTRIC 

COMPANY,

Debtors.

 Affects PG&E Corporation

 Affects Pacific Gas and Electric 

Company

: Affects both Debtors

* All papers shall be filed in the Lead Case 

No. 19-30088 (DM).

Bankruptcy Case No. 19-30088 (DM)

Chapter 11

(Lead Case) (Jointly Administered)

FIRST INTERIM FEE APPLICATION OF

BERMAN AND TODDERUD LLP FOR 

ALLOWANCE AND PAYMENT OF 

COMPENSATION AND REIMBURSEMENT OF 

EXPENSES (FEBRUARY 1, 2019 THROUGH 

MAY 31, 2019)

Date: TBD

Time: TBD

Place: United States Bankruptcy Court

Courtroom 17, 16th Floor

San Francisco, CA 94102

Judge: Hon. Dennis Montali

Objection Deadline: November 12, 2019

 4:00 p.m. (Pacific Time)

Berman and Todderud LLP (“Berman and Todderud” or the “Firm”), Special Counsel for 

PG&E Corporation and Pacific Gas and Electric Company (collectively, the “Debtors”) in the abovecaptioned chapter 11 cases (the “Chapter 11 Cases”), submits this First Interim Fee Application (the

“Interim Application”) for allowance and payment of compensation for professional services 

rendered for the period commencing February 1, 2019, through May 31, 2019 (the “Interim Fee 

Period”), pursuant to the Order Pursuant to 11 U.S.C §§ 331 and 105(a) and Fed. R. Bankr. P. 2016 

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for Authority to Establish Procedures for Interim Compensation and Reimbursement of Expenses of 

Professionals, entered on February 27, 2019 [Docket No. 701] (the “Interim Compensation 

Procedures Order”), sections 330 and 331 of title 11 of the United States Code (the “Bankruptcy 

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

Guidelines for Compensation and Expense Reimbursement of Professionals and Trustees (the 

“Northern District Guidelines”), the United States Trustee Guidelines for Reviewing Applications for 

Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. § 330 (the “UST Guidelines”), 

and the Local Bankruptcy Rules for the Northern District of California.

The Interim Application is based upon the points and authorities cited herein, the Declaration 

of Eric Todderud filed concurrently herewith, the exhibits attached hereto and thereto, the pleadings, 

papers, and records on file in this case, and any evidence or argument that the Court may entertain at 

the time of the hearing on the Interim Application.

CASE BACKGROUND AND STATUS

A. The Debtors’ Bankruptcy Proceedings

The Debtors filed voluntary petitions for relief under Chapter 11 of the Bankruptcy Code on 

January 29, 2019 (the “Petition Date”). The Debtors continue to operate their businesses and manage 

their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy 

Code. No trustee or examiner has been appointed. 

On February 12, 2019, the Office of the United States Trustee for the Northern District of 

California (the “U.S. Trustee”) appointed an Official Committee of Unsecured Creditors in the 

Debtors’ cases (the “Creditors’ Committee”). On February 15, 2019, the U.S. Trustee appointed an 

Official Committee of Tort Claimants (the “TCC”). On May 29, 2019, upon the request of the U.S. 

Trustee, the Court appointed Professor Bruce A. Markell as the fee examiner in these Chapter 11 Cases 

(the “Fee Examiner”).

A description of the Debtors’ business, capital structure, and the circumstances leading to the 

filing of these Chapter 11 Cases is set forth in the Amended Declaration of Jason P. Wells in Support 

of First Day Motions and Related Relief [Docket No. 263]. 

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B. The Debtors’ Retention of Berman and Todderud 

On July 3, 2019, the Court entered the Order Pursuant to 11 U.S.C. § 327(e) and Fed. R. 

Bankr. P. 2014(a) and 2016 for Authorizing the Retention and Employment Berman and Todderud 

LLP as Special Counsel for the Debtors Effective as of February 1, 2019, [Docket No. 2860] (the 

“Retention Order”). A copy of the Retention Order is attached hereto as Exhibit A.

The Retention Order authorizes the Debtors to compensate and reimburse the Firm pursuant to 

the Bankruptcy Code, the Bankruptcy Rules, the Northern District Guidelines, and any orders of the 

Bankruptcy Court. Subject to the Firm’s application to the Court, the Debtors also are authorized by 

the Retention Order to compensate Berman and Todderud at the Firm’s normal hourly rates for 

services performed and to reimburse it for actual and necessary expenses incurred in accordance with 

the disbursement policies of Pacific Gas and Electric Company (the “Utility”). The Retention Order 

authorizes Berman and Todderud to “provide legal services with respect to legal issues related to the 

California energy crisis of 2000-2001, including but not limited to, litigation at the Federal Energy 

Regulatory Commission, and in various appellate courts, and with respect to other electric regulatory 

matters that may arise.”1 

C. Professional Compensation and Reimbursement of Expenses Requested

By this Interim Application, the Firm seeks interim allowance of compensation in the amount 

of $396,292.40, for a total allowance of $396,292.40, and payment of $79,258.48 (20% of the allowed 

fees) for the Interim Fee Period. 

All services for which Berman and Todderud requests compensation were performed for or on 

behalf of the Debtors. Berman and Todderud has received no payment and no promises for payment 

from any source other than the Debtors for services rendered or to be rendered in any capacity 

whatsoever in connection with the matters covered by this Interim Application. 

There is no agreement or understanding between Berman and Todderud and any other person 

other than the partners of Berman and Todderud for the sharing of compensation to be received for 

services rendered in these cases. As of this date Berman and Todderud has been paid $317,0333.92 in 

fees for the Interim Fee Period and has not received any reimbursement for expenses. These amounts 

1 Retention Order ¶ 3.

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have been paid pursuant to the Interim Compensation Order but not yet allowed.

The Firm has billed the Debtors in these Chapter 11 Cases in accordance with its existing 

billing rates and procedures in effect during the Interim Fee Period. These rates are discounted from 

the ordinary rates that Berman and Todderud charges for services rendered by its attorneys in 

comparable matters and are reasonable given the compensation charged by comparably skilled 

practitioners in similar matters in both the California and national markets. The Summary Sheet filed 

herewith contains tables listing the Berman and Todderud attorneys who have performed services for 

the Debtors during the Interim Fee Period, including their job titles, hourly rates, aggregate number of 

hours worked in this matter, and the year in which each attorney was licensed to practice law. Berman 

and Todderud maintains computerized time records, which have been filed in the docket with the 

Firm’s monthly fee statements, furnished to the Debtors, and served on counsel for the Creditors’ 

Committee and the TCC, the U.S. Trustee, and the Fee Examiner in the format specified by the Interim 

Compensation Order.

D. Budget and Budget-to-Actual Performance

For the eleven months of February 2019 through December 2019, the budget established by the 

Utility for the services of Berman and Todderud is $1.375 million. In late 2018, the Utility agreed to a 

budget of $1.5 million for the work done by Mr. Berman and Mr. Todderud at their prior firm, Sidley 

Austin LLP for the calendar year 2019. The budget amount of $1.375 million reflects 11/12 of the 

entire year’s budget to which the Utility agreed, reflecting the fact that Mr. Berman and Mr. Todderud 

left their prior firm to establish Berman and Todderud one month into 2019. 

Berman and Todderud’s fees are within the budget. Fees billed for the months of February 

through May total less than $400,000. The budget amount for that period (that is, 4/11 of the budget 

established for the eleven months of 2019 that Berman and Todderud will be working for the Utility) is 

$500,000. 

JURISDICTION

This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. sections 157 and 1334. 

This is a core proceeding pursuant to 28 U.S.C. section 157(b). Venue is proper before this Court 

pursuant to 28 U.S.C. sections 1408 and 1409.

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PROJECT BILLING AND NARRATIVE STATEMENT OF SERVICES RENDERED

During the Interim Fee Period, Berman and Todderud attorneys expended 502.3 hours on 

behalf of the Debtors. Mr. Berman bills the Utility at a rate of $920 per hour, and Mr. Todderud bills

the Utility at a rate of $692 per hour, for a blended attorney rate of $789 during the Interim Fee Period. 

A. Overview of the Nature of the Work of Berman and Todderud

During the California energy crisis of 2000-2001, multiple wholesale power suppliers2 engaged 

in market manipulation and other illegal conduct, resulting in billions of dollars of overcharges.3 

Numerous proceedings ensued, mostly before the Federal Energy Regulatory Commission, to recover 

overcharges from the eighty or so suppliers that were selling electricity into the California wholesale 

markets at inflated prices. The Utility has been a lead complainant in most of those proceedings since 

2000.4 

Stan Berman has been the lead attorney for the Utility in these matters since 2000. Eric 

Todderud became involved in or about 2004. Both attorneys have been the Utility’s principal outside 

counsel in the proceedings related to the energy crisis since that time.

Efforts to recover overcharges have been extremely successful. The California Parties have 

entered into settlements with more than sixty suppliers. Through those settlements, the Utility and its 

co-plaintiffs have recovered in excess of five billion dollars. Amounts that the Utility has recovered, 

less expenses such as attorney fees, are paid directly to the Utility’s ratepayers. 

Despite past successes, substantial work remains to be done. A few proceedings before FERC 

2 The Utility, along with Southern California Edison and San Diego Gas & Electric, were primarily 

viewed as retail power suppliers serving millions of end-use customers. Companies such as Enron, 

which did not have end-use customers but sold power to utilities that in turn sold the power to end-use 

customers, are wholesale power suppliers.

3 Descriptions of the types of manipulation that occurred and the devastation they caused are found in 

Public Utils. Comm’n of California v. FERC, 462 F.3d 1027 (9th Cir. 2006); MPS Merch. Svcs. Inc. v. 

FERC, 836 F.3d 1155 (9th Cir. 2016).

4 Joining the Utility in these litigation efforts are Southern California Edison Company and San Diego 

Gas and Electric Company, along with state agencies the Public Utilities Commission of the State of 

California, the California Attorney General, and the California Energy Resources Scheduling Division 

of the California Department of Water Resources. These entities are collectively referred to in that 

litigation as the “California Parties.”

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are still pending, and market clearing efforts are underway. Mr. Berman and Mr. Todderud are 

significantly involved in these and all other efforts related to the refund litigation. But it is difficult, if 

not impossible, to segregate activities into discrete categories.

The following sections describe in general terms the categories of the work that Berman and 

Todderud has performed during the Interim Period. 

B. Description of Work Performed 

The work of Berman and Todderud in connection with the litigation is now limited to a single 

set of litigation cases pending before FERC (and related appeals) that truly constitutes a single project 

or task. That litigation is in a phase referred to as the “settlement overlay,” and the vast majority of the 

work of Berman and Todderud during the interim fee period relates to the settlement overlay. 

Nonetheless, the following subsections describe and categorize the legal work we performed during the 

Interim Fee Period and the amount of time spent on that work. 

1. Settlement Overlay

Through various orders over the past nineteen years, FERC has reset prices that were charged 

in wholesale power markets during the energy crisis. It has adopted a formula to calculate a proxy 

price intended to reflect the prices that would have prevailed in the California power markets had there 

not been market manipulation and other illegal conduct. And, it has ordered suppliers to pay refunds 

based on the difference between the price charged and the proxy price. 

Implementing those price adjustments, as well as other changes that FERC ordered, required a 

“rerun” of the markets-recalculating who owes what to whom. The California Independent System 

Operator (“ISO”) and the California Power Exchange (“PX”) operated the wholesale power markets 

that were manipulated, and FERC ordered those entities to perform the initial refund rerun to reset 

prices and calculate refunds based on the revised prices. That work required adjusting the prices in 

millions of transactions that occurred during the energy crisis and reconciling the accounts to reflect 

those adjustments. The ISO and PX filed the refund rerun results with FERC in 2016. 

Once the refund rerun was completed, the California Parties, working in conjunction with the 

ISO and PX, undertook the “settlement overlay” process—taking the refunds amounts and account 

balances that the ISO and PX calculated in the refund rerun, and “overlaying” the refunds and other 

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adjustments established in the sixty-plus settlements that the California Parties have reached. 

Although consultants are performing the necessary calculations, considerable legal work is 

required as part of the settlement overlay process. Mr. Berman and Mr. Todderud have been reviewing 

those calculations to ensure that the methodology is consistent with FERC orders and the relevant 

settlement provisions. The attorneys must address, in a fair and reasonable way, numerous categories 

of funding shortfalls, shortfalls arising from defaults, and twenty years of FERC orders determining 

how market clearing should be done. A significant portion of their work involves the interpretation 

and implementation of the sixty-plus settlements that are part of the overlay. Indeed, questions 

involving tens of millions of dollars have arisen over settlement-related issues and the attorneys have 

worked to resolve those questions. 

The settlement overlay process will culminate in a filing at FERC, which the parties plan to 

submit at the end of January 2020. The California Parties currently are working with other market 

participants to resolve issues and foreclose objections to the upcoming filing. 

Work on the settlement overlays constitutes the largest portion of the billable time for the 

Interim Period, and much of the work described in the following of this Fee Application relates to the 

settlement overlay. Once the settlement overlay filing is complete in early 2020, the focus of our work 

will shift to resolving issues raised by market participants and ensuring the timely approval of the 

filing.

2. Settlement Negotiations

Berman and Todderud is also involved in active negotiations with remaining suppliers 

concerning claims that have not settled, and that are awaiting resolution at FERC. The amounts at 

stake are in excess of a billion dollars for California ratepayers. Because the settlement negotiations 

are confidential, Berman and Todderud cannot reveal details of the negotiations. 

Generally speaking, settlement negotiations require considerable research to assess the value of 

claims, conferences among the California Parties to establish negotiating positions, and multiple outof-town meetings with the supplier counterparties.

3. Settlement Implementation/Escrows

As part of the settlement process, the California Parties have created dozens of escrow 

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accounts, holding millions of dollars. The funds are retained in escrow because the settlements did not 

resolve all aspects of the market, and thus funds needed to be retained until final market clearing –

which we are trying to implement through the settlement overlay process described above. Mr. 

Todderud has had primary responsibility for overseeing administration of the escrows for close to 

fifteen years. Work involved in administering escrows includes coordinating the escrow agent and the 

escrow accountant’s work, ensuring that the utilities are reviewing escrow statements, and drafting 

disbursement instructions. 

4. Settlement Implementation/Allocation Agreements

Many of the sixty-plus settlements that the California Parties entered into over the past two 

decades include payments that are made to the California Parties generally but not to individual 

California Parties. The settlements permit the California Parties to allocate such payments among 

themselves, and to re-allocate other settlement consideration among themselves. 

To accomplish this allocation of funds, which total hundreds of millions of dollars, the 

California Parties have entered into allocation agreements among themselves. Negotiating such 

agreements has been time-consuming and sometimes contentious. Eric Todderud has had primary 

responsibility for drafting and implementing such agreements during the Interim Fee Period. 

5. FERC Pleadings

A portion of the work done during the Interim Fee Period has been to prepare pleadings in 

connection with FERC dockets that remain active. Those pleadings are in the nature of updates to 

FERC and litigants or are directed at litigation parties that have not settled with the California Parties. 

6. Retention Application

Time billed for preparing materials related to professional retention is less than 5% of the total 

time billed during the Interim Fee Period. Berman and Todderud billed a total of 17.8 hours in 

connection with the retention application in April 2019. The attorneys did not bill any time to such 

activities in February, March and May 2019, nor did the attorneys bill any time for fee collection 

during the Interim Fee Period. 

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EXPENSE SUMMARY

FEBRUARY 1, 2019 THROUGH MAY 31, 2019

Berman and Todderud incurred no reimbursable expenses for the Interim Period. 

LEGAL BASIS FOR INTERIM COMPENSATION

The professional services for which Berman and Todderud requests interim allowance of 

compensation and reimbursement of expenses were rendered and incurred in connection with the 

energy crisis litigation work on behalf of the Utility described above. Berman and Todderud’s services 

have been necessary and beneficial to the Debtors and their ratepayers. Because their fees are 

deducted from recoveries that are then flowed to ratepayers, there is no impact on the estate or other 

creditors. 

In accordance with the factors enumerated in section 330 of the Bankruptcy Code, Berman and 

Todderud respectfully submits that the amount requested by Berman and Todderud is fair and 

reasonable given the complexity of these Chapter 11 Cases, the time expended, the nature and extent of 

the services rendered, the value of such services, and the costs of comparable services other than in a 

case under the Bankruptcy Code. Moreover, Berman and Todderud has reviewed the requirements of 

the Interim Compensation Procedures Order, the Northern District Guidelines, and the UST Guidelines 

and believes that the Interim Application complies with all of them. We also understand that questions 

have been raised by the Fee Examiner about certain categories of fees. In response to those concerns 

we note that Mr. Berman and Mr. Todderud’s work is not in any way duplicative of the work 

performed by other professionals working for Utility–no other law firm is representing the Utility in 

the crisis proceedings. We also note that Mr. Berman and Mr. Todderud have not sought 

compensation for non-working travel time, and that Mr. Berman and Mr. Todderud have not redacted 

any of their time records.

AVAILABLE FUNDS

The Firm understands that the Debtors’ estate has sufficient funds available to pay the fees and 

costs sought herein.

NOTICE

Notice of the Interim Application has been provided to parties in interest in accordance with the 

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procedures set forth in the Interim Compensation Order. Berman and Todderud submits that, in view 

of the facts and circumstances of these Chapter 11 Cases, such notice is adequate and no other or 

further notice need be provided.

CONCLUSION

Berman and Todderud respectfully requests an interim allowance to Berman and Todderud for 

compensation in the amount of $396,292.40, and an authorization for payment of $79,258.48 (20% of 

the allowed fees); and for such other and further relief as this Court deems proper.

Dated: October 22, 2019 Respectfully submitted,

BERMAN AND TODDERUD LLP

By: /s/ Eric Todderud

 Eric Todderud

Special Counsel to Debtors and Debtors in Possession

Case: 19-30088 Doc# 4383 Filed: 10/22/19 Entered: 10/22/19 13:44:03 Page 14

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Notice Parties

PG&E Corporation 

c/o Pacific Gas & Electric Company

Attn: Janet Loduca, Esq. 

77 Beale Street

San Francisco, CA 94105 

Weil, Gotshal & Manges LLP

Attn: Stephen Karotkin, Esq. 

 Jessica Liou, Esq. 

Matthew Goren, Esq.

767 Fifth Avenue 

New York, NY 10153 

The Office of the United States Trustee for Region 17 

Attn: Andrew Vara, Esq.

Timothy Laffredi, Esq.); 

450 Golden Gate Avenue, 5th Floor, Suite #05-0153 

San Francisco, CA 94102 

Milbank LLP 

Attn: Dennis F. Dunne, Esq. 

 Sam A. Khalil, Esq. 

55 Hudson Yards 

New York, NY 10001-2163 

Milbank LLP 

Attn: Paul S. Aronzon, Esq., 

 Gregory A. Bray, Esq., 

 Thomas R. Kreller, Esq. 

2029 Century Park East, 33rd Floor 

Los Angeles, CA 90067 

Baker & Hostetler LLP

 Attn: Eric Sagerman, Esq. and 

 Cecily Dumas, Esq. 

11601 Wilshire Boulevard, Suite 1400 

Los Angeles, CA 90025-0509 

Bruce A. Markell, Fee Examiner 

541 N. Fairbanks Ct., Ste 2200 

Chicago, IL 60611-3710 

Scott H. McNutt 

324 Warren Road 

San Mateo, California 94402 

Case: 19-30088 Doc# 4383 Filed: 10/22/19 Entered: 10/22/19 13:44:03 Page 15

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