207868094 v1 IMPAC 6317231v.1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: VG Liquidation, Inc., et al., Debtors. 1 Chapter 11 Case No. 18-11120 (JTD) (Jointly Administered) Objection Deadline: August 12, 2019 at 4:00 p.m. (ET) COVER SHEET TO THE FOURTEENTH MONTHLY APPLICATION OF COOLEY LLP, LEAD COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF VG LIQUIDATION, INC., ET AL. FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD OF JUNE 1, 2019 THROUGH JUNE 30, 2019 Name of Applicant Cooley LLP Authorized to Provide Professional Services to: Official Committee of Unsecured Creditors of VG Liquidation, Inc., et al. Retention Date June 28, 2018 nunc pro tunc to May 17, 2018 Period for which compensation and reimbursement is sought: June 1, 2019 through June 30, 2019 Total Compensation sought as actual, reasonable and necessary: $86,208.50 80% of Compensation sought as actual, reasonable and necessary: $68,966.80 Amount of Expense Reimbursement sought as actual, reasonable, and necessary: $1,700.91 1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: VG Liquidation, Inc. (f/k/a Videology, Inc.) (2191), Collider Media, Inc. (8602), VG MT Liquidation LLC (f/k/a Videology Media Technologies, LLC) (6243), LucidMedia Networks, Inc. (8566) and VG Liquidation Ltd. (f/k/a Videology Ltd.), a company organized under the laws of England and Wales. The address of the Debtors’ corporate headquarters is 1500 Whetstone Way, Suite 500, Baltimore, MD 21230. Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 1 of 17
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE … · Videology Media Technologies, LLC) (6243), LucidMedia Networks, Inc. (8566) and VG Liquidation Ltd. (f/k/a Videology Ltd.), a
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207868094 v1
IMPAC 6317231v.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
VG Liquidation, Inc., et al.,
Debtors.1
Chapter 11
Case No. 18-11120 (JTD)
(Jointly Administered)
Objection Deadline: August 12, 2019 at 4:00 p.m. (ET)
COVER SHEET TO THE FOURTEENTH MONTHLY APPLICATION OF COOLEY LLP, LEAD COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF VG LIQUIDATION, INC., ET AL. FOR COMPENSATION
AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD OF JUNE 1, 2019 THROUGH JUNE 30, 2019
Name of Applicant Cooley LLP
Authorized to Provide Professional Services to:
Official Committee of Unsecured Creditors of VG Liquidation, Inc., et al.
Retention Date June 28, 2018 nunc pro tunc to May 17, 2018
Period for which compensation and reimbursement is sought:
June 1, 2019 through June 30, 2019
Total Compensation sought as actual, reasonable and necessary:
$86,208.50
80% of Compensation sought as actual, reasonable and necessary:
$68,966.80
Amount of Expense Reimbursement sought as actual, reasonable, and necessary:
$1,700.91
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: VG Liquidation, Inc. (f/k/a Videology, Inc.) (2191), Collider Media, Inc. (8602), VG MT Liquidation LLC (f/k/a Videology Media Technologies, LLC) (6243), LucidMedia Networks, Inc. (8566) and VG Liquidation Ltd. (f/k/a Videology Ltd.), a company organized under the laws of England and Wales. The address of the Debtors’ corporate headquarters is 1500 Whetstone Way, Suite 500, Baltimore, MD 21230.
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Total Compensation approved by interim order to date:
$1,200,507.50
Total Expenses Approved by interim order to date:
$21,959.022
Total Allowed compensation paid to date: $1,482,563.60
Total Allowed expenses paid to date: $25,084.17
Blended Rate in this application for all timekeepers $899.88
Blended Rate in this application for all attorneys $922.17
This is Cooley LLP’s fourteenth monthly fee application in these cases.
The total time expended in connection with the preparation of this fee application is not included herein as such time was expended after the Compensation Period.
2 This amount includes $338.00 in expense reimbursement requests by individual Committee members.
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 2 of 17
3 Applicant did not incur any expenses. This amount is for Committee member expense reimbursements only. 4 A Certificate of No Objection was filed on July 20, 2018 [D.I. 360]. 5 A Certificate of No Objection was filed on August 14, 2018 [D.I. 405]. 6 A Certificate of No Objection was filed on September 14, 2018 [D.I. 456]. 7 A Certificate of No Objection was filed on November 1, 2018 [D.I. 549]. 8 A Certificate of No Objection was filed on November 27, 2018 [D.I. 591]. 9 This amount includes $2,706.67 in individual Committee member expense reimbursement requests. 10 A Certificate of No Objection was filed on December 11, 2018 [D.I. 608]. 11 A Certificate of No Objection was filed on January 11, 2019 [D.I. 669]. 12 A Certificate of No Objection was filed on February 12, 2019 [D.I. 712]. 13 A Certificate of No Objection was filed on March 13, 2019 [D.I. 747].
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TOTAL $1,645,873.50 $29,538.48 $1,316,698.80 $29,538.48 $329,174.70
14 A Certificate of No Objection was filed on April 23, 2019 [D.I. 857]. 15 A Certificate of No Objection was filed on May 14, 2019 [D.I. 962]. 16 A Certificate of No Objection was filed on June 11, 2019 [D.I. 1043]. 17 A Certificate of No Objection was filed on July 19, 2019 [D.I. 1138].
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COMPENSATION BY TIMEKEEPER DURING THE COMPENSATION PERIOD
Name of Professional
Person
Position of the Applicant, Year of Obtaining License to
Practice, Area of Expertise
Hourly Billing Rate
Total Billed Hours
Total Compensation
Jonathan Kim Partner; Member of New York Bar since 1997; Area of Expertise: Business Litigation
$1,005 4.5 $4,522.50
Seth Van Aalten Partner; Member of New York Bar since 2004; Area of Expertise: Bankruptcy
$995 38.8 $38,606.00
Michael Klein Special Counsel; Member of New York Bar since 2005; Area of Expertise: Bankruptcy
$955 16.5 $15,757.50
Clint Massengill Special Counsel; Member of New York Bar since 2002; Area of Expertise: Tax
$950 2.7 $2,565.00
David Kupfer Associate; Member of New York Bar since 2012; Area of Expertise: Business Litigation
$955 6.0 $5,730.00
Evan Lazerowitz Associate; Member of New York Bar since 2014; Area of Expertise: Bankruptcy
$755 24.0 $18,120.00
Mollie Canby Paralegal $275 3.3 $907.50
Total 95.8 $86,208.50Blended Hourly Rate for all Timekeepers $899.88Blended Hourly Rate for all Attorneys $922.17
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TIME BILLED BY PROJECT CATEGORY DURING THE COMPENSATION PERIOD
Subject Matter Categories Hours Spent
Fees
B02 Asset Disposition 0.3 $298.50
B04 Case Administration 1.2 $906.00
B05 Claims 9.7 $8,731.50
B07 Fee/Employment Applications 5.1 $2,782.50
B10 Litigation 17.1 $16,411.50
B11 Meetings 3.2 $3,128.00
B12 Plan and Disclosure Statement 51.6 $46,510.00
B14 Travel 1.6 $1,592.00
B19 Preparation For and Attendance at Court Hearings
3.3 $3,283.50
B21 Tax Issues 2.7 $2,565.00
Total 95.8 $86,208.50
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Date Total Amount Description Professional 6/26/19 $12.85 Working meal D. Kupfer Total $12.85
TRAVEL EXPENSE DETAIL
Dept. Date Total Description Traveler 5/15/19 $404.00 Train fare (roundtrip) from NY, NY to Wilmington, DE to
attend the Disclosure Statement hearing S. Van Aalten
Total $404.00
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 7 of 17
207868094 v1
IMPAC 6317231v.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
VG Liquidation, Inc., et al.,
Debtors.1
Chapter 11
Case No. 18-11120 (JTD)
(Jointly Administered)
Objection Deadline: August 12, 2019 at 4:00 p.m. (ET)
FOURTEENTH MONTHLY APPLICATION OF COOLEY LLP, LEAD COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF VG
LIQUIDATION, INC., ET AL. FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR
THE PERIOD OF JUNE 1, 2019 THROUGH JUNE 30, 2019
Cooley LLP (“Applicant”), lead counsel to the Official Committee of Unsecured
Creditors (the “Committee”) of VG Liquidation, Inc., et al. (f/k/a Videology, Inc., et al.) (the
“Debtors”), in the above-captioned chapter 11 cases, respectfully represents:
INTRODUCTION
1. This is Applicant’s fourteenth monthly application (the “Application”) for
compensation and reimbursement of expenses pursuant to § 331 of chapter 11 of title 11 of the
United States Code (the “Bankruptcy Code”), the Federal Rules of Bankruptcy Procedure (the
“Bankruptcy Rules”), the Local Rules of Bankruptcy Practice and Procedure of the United
States Bankruptcy Court for the District of Delaware (the “Local Rules”), the Guidelines for
Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11
U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases (the “U.S. Trustee Guidelines”), and the
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: VG Liquidation, Inc. (f/k/a Videology, Inc.) (2191), Collider Media, Inc. (8602), VG MT Liquidation LLC (f/k/a Videology Media Technologies, LLC) (6243), LucidMedia Networks, Inc. (8566) and VG Liquidation Ltd. (f/k/a Videology Ltd.), a company organized under the laws of England and Wales. The address of the Debtors’ corporate headquarters is 1500 Whetstone Way, Suite 500, Baltimore, MD 21230.
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Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of
Professionals (the “Interim Compensation Order”) [D.I. 234].
2. This Application seeks an interim payment of compensation for legal services
rendered by Applicant in the total amount of $68,966.80 representing 80% of total services
rendered, and reimbursement of certain expenses incurred (or first billed by outside vendors to)
Applicant in the amount of $1,700.91 for the period June 1, 2019 through June 30, 2019 (the
“Compensation Period”) Pursuant to the Interim Compensation Procedures Order, if no
objections are filed to this Application, the Debtors are authorized to pay Applicant 80% of its
fees and 100% of its expenses for a total of $70,667.71. This Application complies with the
Bankruptcy Code, the Bankruptcy Rules, the Local Rules, the U.S. Trustee Guidelines, and the
Interim Compensation Order.
BACKGROUND
3. On May 10, 2018, each of the Debtors filed a voluntary petition with this Court
for relief under chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses
and managing their properties as debtors-in-possession pursuant to sections 1107(a) and 1108 of
the Bankruptcy Code. No trustee or examiner has been appointed in these cases by the Office of
the United States Trustee for the District of Delaware (the “U.S. Trustee”).
4. On May 17, 2018, the U.S. Trustee appointed the Committee, consisting of the
following seven members: (i) GroupM UK Digital Ltd.; (ii) Beachfront Media, LLC; (iii)
28 Walker Development; (vi) Teads France SAS; and (vii) Telaria, Inc.2
2 Chesapeake Paperboard Centre LLC resigned from the Committee on October 10, 2018 and Beachfront Media LLC resigned on June 5, 2019. See Dkt. Nos. 502 & 1033.
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 9 of 17
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5. On June 11, 2018, the Committee filed the Application of the Official Committee
of Unsecured Creditors of Videology, Inc., et al., for Entry of an Order Authorizing the
Employment and Retention of Cooley LLP as Lead Counsel Nunc Pro Tunc to May 17, 2018
[D.I. 186]. This Court approved the Committee’s retention of Applicant pursuant to an order
entered on June 28, 2018 [D.I. 254].
6. On January 31, 2019, the Court appointed Justin H. Rucki of Rucki Fee Review,
LLC, as the fee examiner in these cases (the “Fee Examiner Order”) [D.I. 701].
7. Pursuant to the Interim Compensation Order and the Fee Examiner Order,
Applicant may file monthly fee applications with this Court. This is Applicant’s fourteenth
monthly fee application in these cases.
JURISDICTION AND STATUTORY PREDICATES
8. This Court has jurisdiction to consider this Application pursuant to 28 U.S.C. §
1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2). Venue is proper before this
Court pursuant to 28 U.S.C. §§ 1408 and 1409. Pursuant to Local Rule 9013-1(f), Applicant
consents to the entry of a final judgment or order with respect to this Application if it is
determined that the Court would lack Article III jurisdiction to enter such final order or judgment
absent consent of the parties. The statutory predicates for the relief requested herein are §§
105(a), 330 and 331 of the Bankruptcy Code and Bankruptcy Rule 2016.
SERVICES RENDERED DURING THE COMPENSATION PERIOD
9. During the Compensation Period, Applicant’s services to the Committee included
professional advice and representation in connection with discrete categories in these chapter 11
proceedings. The aggregate hours and amount for each category are set forth on the cover page
to this Application.
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 10 of 17
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10. To apprise this Court of the legal services provided during the Compensation
Period, Applicant sets forth the following summary of legal services rendered. The summary is
intended only to highlight the general categories of services performed by Applicant on behalf of
the Committee; it is not intended to set forth each and every item of professional services which
Applicant performed.
Case Administration
This category includes time expended by Applicant on a variety of activities
relating to the day-to-day management and prosecution of these chapter 11 cases. Services
rendered in this project category include, among other things, communicating with the U.S.
Trustee and estate professionals regarding administrative matters and judge reassignment,
managing the critical dates calendar, and attending to miscellaneous tasks that did not properly
fall into other project categories.
Applicant expended 1.2 hours of time for a charge of $906.00 for services
rendered in connection with case administration.
Claims
This category includes time expended by Applicant regarding claims against the
Debtors’ estates. Applicant spent time during the Compensation Period, reviewing and
commenting on stipulations regarding the claims of Video Intelligence AG and Rocky Point
Claims LLC, reviewing and analyzing claims data in contemplation of filing claims objections,
attending to the voting objection to the claim filed by Pinnacle Ventures, L.L.C., and
corresponding with the Debtors and estate professionals concerning objections to claims and
voting matters.
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 11 of 17
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Applicant expended 9.7 hours of time for a charge of $8,731.50 with respect to
claims against the Debtors’ estates.
Fee/Employment Applications
This category includes time expended by Applicant regarding the compensation
of various professionals in the Debtors’ bankruptcy proceedings. Applicant spent time during
the Compensation Period, among other things, reviewing the other professionals’ fee
applications and the fee auditor’s reports, and preparing its combined thirteenth monthly and
fourth interim fee application.
Applicant expended 5.1 hours of time for a charge of $2,782.50 with respect to
fee/employment applications matters.
Litigation
This category includes time expended by Applicant related to litigation matters.
During the Compensation Period, Applicant spent time attending to the investigation of the
Debtors’ prepetition secured lenders.
Applicant expended 17.1 hours of time during the Compensation Period for a
charge of $16,411.50 with respect to litigation.
Meetings
This category includes time expended by Applicant preparing for and attending
meetings with estate professionals in connection with general case status, confirmation of the
Debtors’ plan, and related matters.
Applicant expended 3.2 hours of time for a charge of $3,128.00 with respect to
preparation for and attendance at meetings.
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Plan and Disclosure Statement
This category includes time expended by Applicant in connection with the plan
and disclosure statement. During the Compensation Period, Applicant spent time (i) reviewing
and analyzing the voting status reports and ballots; (ii) conducting legal research on tax issues;
(iii) revising a liquidating trust agreement; (iv) responding to creditor inquiries; (v) reviewing
and analyzing objections to the plan, (vi) reviewing the Debtors’ plan supplement and list of
assumed executory contracts, (vii) attending to plan voting issues, and (viii) communicating with
the Committee, the Debtors, other estate professionals, and other interested parties concerning
same.
Applicant expended 51.6 hours of time for a charge of $46,510.00 with respect to
the Debtors’ Plan and disclosure statement
Travel
This category is for travel time expended by Applicant in connection with the
status conference hearing on June 21, 2019 in Wilmington, Delaware. Non-working travel is
billed at one-half time.
Applicant billed 1.6 hours of non-working travel time for a charge of $1,592.
Preparation For and Attendance at Court Hearings
This category includes, inter alia, time expended by Applicant with respect to
preparation for, and attendance at, the status conference hearing held on June 21, 2019.
Applicant expended 3.3 hours of time for a charge of $3,283.50 for services
rendered with respect to preparation for and attendance at Court hearings.
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Tax Issues
This category includes time expended by Applicant with respect to tax matters.
During the Compensation Period, Applicant spent time reviewing the proposed liquidating trust
agreement and conducting legal research on related tax issues.
Applicant expended 2.7 hours of time for a charge of $2,565.00 for services
rendered with respect to tax matters.
MATTERS PERTAINING TO APPLICANT DURING THE COMPENSATION PERIOD
Applicant has maintained contemporaneous time records which indicate the time
that each attorney has spent working on a particular matter and the nature of the work performed.
Copies of these time records are annexed to this Application as Exhibit A. The total number of
hours expended by Applicant’s attorneys and para-professionals during the Compensation Period
in conjunction with these cases is 95.8. All of the services have been rendered by those
individuals at Applicant’s firm.
The personnel who have expended time on this matter during the Compensation
Period are as follows: (a) Seth Van Aalten and Michael Klein have been actively involved in all
aspects of these cases, (b) Evan Lazerowitz was responsible for various day-to-day issues that
arose during the Compensation Period, (c) Jonathan Kim and David Kupfer were responsible for
litigation matters during the Compensation Period, and (d) Clint Massengill was responsible for
tax matters during the Compensation Period.
Applicant has extensive experience representing creditors’ committees in chapter
11 cases throughout the United States, having represented official committees in cases such as
American Apparel, Aerogroup International, Avenue Stores, Atari, Big M, Blockbuster, Bob’s
Stores, Brookstone, Charming Charlie, City Sports, Claire’s, Eastern Outfitters, Eddie Bauer,
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 14 of 17
Camera, Rockport Company, rue21, Sbarro’s, Steve & Barry’s, Sharper Image, SkyMall, The
Athlete’s Foot, The Wet Seal, Today’s Man, True Religion, and Vestis, among others.
Applicant rendered all the professional services for which compensation is
requested herein in connection with the Debtors’ chapter 11 cases in furtherance of Applicant’s
professional responsibilities as attorneys for the Committee.
During the Compensation Period, the partners, special counsels, associates and
para-professionals of Applicant devoted substantial time, 95.8 hours, in rendering professional
services to the Committee, all of which time was reasonable and necessary.
Applicant, by experience, training, and ability, is fully qualified to perform the
services for which compensation is sought here. Applicant represents or holds no interest
adverse to the Committee with respect to the matters upon which it is engaged.
No agreement or understanding exists between Applicant and any other entity for
the sharing of compensation to be received for services rendered in or in connection with these
chapter 11 cases.
EXPENSES INCURRED DURING THE COMPENSATION PERIOD
Annexed as part of the cover sheet is a list of the necessary and actual
disbursements incurred during the Compensation Period in connection with the above-described
work. The list is derived from the information found in Exhibit A. These records indicate that
Applicant has advanced during the Compensation Period the sum of $1,700.91 in necessary and
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 15 of 17
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actual out-of-pocket expenses. In connection with said expenses, it should be noted that
Applicant charges 25¢ per page for outgoing facsimiles with no charge for incoming facsimiles,
10¢ per page for photocopying and charges for meals only necessitated by meetings with the
Debtors, the Committee, or when Applicant’s personnel would work on these cases through a
normal meal period.
NOTICE, PRIOR APPLICATION AND CERTIFICATION
Notice of this Application has been provided in accordance with the Interim
Compensation Order. Applicant submits that the foregoing constitutes good and sufficient notice
and that no other or further notice need be provided.
No previous application for the relief sought herein has been made to this or any
other court.
Applicant has reviewed the requirements of the Local Rules, and this Application
complies with those rules and guidelines.
[Remainder of page intentionally left blank]
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WHEREFORE, Applicant hereby respectfully requests interim payment of fees in the
amount of $68,966.80 which is equal to the sum of 80% of Applicant’s allowed compensation
for duly authorized, necessary and valuable professional services to the Committee incurred
during the Compensation Period, and reimbursement to Applicant for actual and necessary
expenses incurred during the Compensation Period in connection with the aforesaid services in
the aggregate amount of $1,700.91.
Dated: July 22, 2019 COOLEY LLP
/s/ Seth Van Aalten Seth Van Aalten Michael Klein Evan Lazerowitz 1114 Avenue of the Americas New York, New York 10036 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Email: [email protected]; [email protected]; [email protected]
Lead Counsel For The Official Committee Of Unsecured Creditors
Case 18-11120-JTD Doc 1141 Filed 07/22/19 Page 17 of 17
IMPAC 6310713v.1
IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
VG Liquidation, Inc., et al.,
Debtors.1
Chapter 11
Case No. 18-11120 (JTD)
(Jointly Administered)
Hearing Date: Only if Objections are Filed Objection Deadline: August 12, 2019 at 4:00 p.m. (ET)
NOTICE OF FOURTEENTH MONTHLY APPLICATION OF COOLEY LLP, LEAD COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF VG
LIQUIDATION, INC., ET AL. FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD JUNE 1, 2019 THROUGH JUNE 30, 2019
PLEASE TAKE NOTICE that the Official Committee of Unsecured Creditors
appointed in the chapter 11 cases of VG Liquidation, Inc., et al. (the “Committee”) filed the
Fourteenth Monthly Application of Cooley LLP, Lead Counsel to the Official Committee of
Unsecured Creditors of VG Liquidation, Inc., et al. for Compensation and Reimbursement
of Expenses for the Period June 1, 2019 Through June 30, 2019 (the “Application”).
PLEASE TAKE FURTHER NOTICE that objections to the Application, if any, are
required to be filed on or before August 12, 2019 at 4:00 p.m. (ET) (the “Objection Deadline”)
with the Clerk of the United States Bankruptcy Court for the District of Delaware, 3rd Floor, 824
Market Street, Wilmington, Delaware, 19801.
PLEASE TAKE FURTHER NOTICE that at the same time, you must also serve a
copy of the objection so as to be received by the following on or before the Objection Deadline:
(i) the Debtors, 1500 Whetstone Way, Suite 500, Baltimore, Maryland 21230, Attn: Dan Smith;
1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, are: VG Liquidation, Inc. (f/k/a Videology, Inc.) (2191), Collider Media, Inc. (8602), VG MT Liquidation LLC (f/k/a Videology Media Technologies, LLC) (6243), LucidMedia Networks, Inc. (8566) and VG Liquidation Ltd. (f/k/a Videology Ltd.), a company organized under the laws of England and Wales. The address of the Debtors’ corporate headquarters is 145 West Ostend Street, Suite 623, Baltimore, MD 21230.
Case 18-11120-JTD Doc 1141-1 Filed 07/22/19 Page 1 of 3
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(ii) counsel to the Debtors, Cole Schotz P.C., 300 East Lombard Street, Suite 1450, Baltimore,
Maryland 21202, Attn: Irving E. Walker, Esq. and 500 Delaware Avenue, Suite 1410,
Wilmington, Delaware 19801, Attn: Patrick J. Reilley, Esq.; (iii) counsel to the lender under the
Debtors’ secured post-petition debtor in possession financing facility, Arent Fox LLP, 1675
Broadway, New York, New York 10019, Attn: Robert M. Hirsh, Esq. and Jordana L. Renert,
Esq. and Bayard LLP, 600 North King Street, Suite 400, Wilmington, Delaware 19801, Attn:
Justin R. Alberto, Esq.; (iv) counsel to the Committee, Cooley LLP, 55 Hudson Yards, New
York, New York 10001, Attn: Seth Van Aalten, Esq. and Michael Klein, Esq. and Potter
Anderson & Corroon LLP, 1313 N. Market Street, 6th Floor, Wilmington, Delaware 19801, Attn:
Christopher S. Samis, Esq. and L. Katherine Good, Esq.; and (v) the Office of the United States
Trustee for the District of Delaware, 844 King Street, Suite 2207, Lockbox 35, Wilmington,
Delaware 19801, Attn: David L. Buchbinder.
PLEASE TAKE FURTHER NOTICE THAT PURSUANT TO THE ORDER
ESTABLISHING PROCEDURES FOR INTERIM COMPENSATION AND
REIMBURSEMENT OF EXPENSES OF PROFESSIONALS [DOCKET NO. 234], IF NO
OBJECTIONS ARE FILED AND SERVED IN ACCORDANCE WITH THE ABOVE
PROCEDURE, THE DEBTORS WILL BE AUTHORIZED TO PAY 80% OF THE
REQUESTED FEES AND 100% OF THE REQUESTED EXPENSES WITHOUT FURTHER
ORDER OF THE COURT.
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Dated: July 22, 2019 Wilmington, Delaware
Respectfully submitted,
/s/ Aaron H. Stulman Christopher M. Samis (No. 4909) L. Katherine Good (No. 5101) Aaron H. Stulman (No. 5807) POTTER ANDERSON & CORROON LLP 1313 N. Market Street, 6th Floor Wilmington, Delaware 19801-3700 Telephone: (302) 984-6000 Facsimile: (302) 658-1192 Email: [email protected]
Seth Van Aalten, Esq. Michael Klein, Esq. Evan Lazerowitz, Esq. COOLEY LLP 55 Hudson Yards New York, New York 10001 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Email: [email protected]