UNITED STATES BANKRUPTCY COURT

WESTERN DISTRICT OF TEXAS

SAN ANTONIO DIVISION
In re:
DELTA PRODUCE, L.P.,
Debtor,
)
)
)
)
)
)
)
)

Chapter 11
Case No.: 12-50073-LMC

Jointly Administered
Hon. Leif M. Clark
THE KINGDOM FRESH GROUP AND RIO BRAVO GROUPS
OBJECTION TO THE SPECIAL COUNSELS FIRST INTERIM
APPLICATION FOR ATTORNEYS FEES & COSTS (D.E. # 284)

Kingdom Fresh Produce, Inc., I. Kunik Company, Inc. and Five Brothers Jalisco Produce Co.
Inc d/b/a Bonanza 2001 (collectively the Kingdom Fresh Group) and Rio Bravo Produce Limited,
LLC. and G.R. Produce, Inc. (collectively the Rio Bravo Group) PACA Creditors in associated case
In re: Superior Tomato-Avocado, Case No. 12-50074 (the Superior Bankruptcy)(the Kingdom Fresh
Group and the Rio Bravo Group collectively referred to as the K&R Group), by and through their
undersigned counsel, jointly object to the Special PACA Counsels First Interim Application for
Attorneys Fees & Costs (D.E. # 284). In support of this Objection, the K&R Group states as follows:
STATEMENT OF FACTS
1. On December 28, 2011, Rio Bravo initially filed a claim against Delta Produce, LLP.
(Delta) and Superior Tomato-Avocado Ltd., Inc. (Superior Tomato) (Delta and Superior Tomato
are collectively referred to here as the Debtors) to enforce its trust rights under the Perishable
Agricultural Commodities Act, 1930, 7 U.S.C. 499a-499t (2009 & Supp. 2011)(the PACA), in
Case No. 5:11-cv-01126-XR, before the Honorable Xavier Rodriguez (District Court Action).
2. Delta filed this voluntary petition for Chapter 11 Bankruptcy (the Petition) and
Superior Tomato the Superior Bankruptcy, on January 3, 2012.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 1 of
13
2
3. On January 25, 2012, this Honorable Court entered the Order Establishing: a Deadline
to File PACA Trust Claims, For Procedures to Resolve Those Claims, and for Appointment of Special
PACA Counsel: Delta Produce (D.E. # 52) (the Claims Procedure), to preserve PACA trust assets.
4. This Honorable Court entered a nearly identical claims procedure, in the Superior
Tomato Bankruptcy (D.E.#43 of the Superior Bankruptcy docket), to preserve Superior Tomato-
Avocado, LLCs PACA trust assets.
5. Paragraph 14 (fourteen) of the Claims Procedure designated Attorney Craig A. Stokes
as Special Counsel for the Debtor (Special Counsel) and authorized [Special Counsel] to take those
steps reasonably necessary to preserve and collect the PACA trust assets. (D.E. # 52 14(B))
6. Specifically, the Claims Procedure allowed Special Counsel to file or defend adversary
proceedings on behalf of the Debtor. (D.E. # 52 14(B)(a)) The same order also empowered Special
Counsel to examine and object to filed PACA Trust claims on behalf of the Debtors. (D.E. # 52
14(B)(b))
7. On August 14, 2012, Special PACA Counsel filed his First Interim Application for
Attorneys Fees and Costs (D.E. # 284)(Fee Application) for fees and costs he incurred in defending
the Debtors, in this matter.
SUMMARY OF ARGUMENT
The K&R Group has no objection to the allowance of the Fee Application of the Debtors
Special Counsel. However, the K&R Group objects to any order directing payment of these
administrative expenses from trust asset, outside the scope of property of the estate. First, the PACA
trust assets are non-bankruptcy assets and this Honorable Court lacks jurisdiction to disburse non-
estate assets to administrative expense claims. Courts have widely upheld the PACA Trust exists
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 2 of
13
3
outside of the bankruptcy estate, with explicit jurisdiction reserved for the District Courts. Second,
Special Counsel is counsel of record for the Debtors and is limited to payment of his fees from the
Debtors assets, and is unable to seek attorneys fees from the PACA trust assets. Finally, as counsel
of record for the Debtors, Special Counsel has the same pre-existing duty as the Debtors to safeguard
the PACA Trust with an obligation to preserve PACA trust assets for the benefit of all PACA
Creditors. Thus, Special Counsels Fee Application, can be allowed but cannot be paid from non
estate property, like the PACA trust assets in this case.
I. THE PACA TRUST ASSETS ARE NOT PROPERTY OF THE ESTATE
AND BEYOND THE REACH OF SPECIAL PACA COUNSELS CLAIMS
1. NON-BANKRUPTCY ESTATE ASSETS
Because the PACA trust assets are not property of the estate, these assets cannot be used to
satisfy estate claims like administrative expenses. The Claim Procedure order cannot expand this
Honorable Courts subject matter jurisdiction as Special Counsel seems to imply it does. PACA
establishes a scheme in which a purchaser of produce on credit (a Produce Debtor) is required to hold
the Produce and its derivatives or proceeds in trust for the unpaid seller. Ordinary principles of trust
law apply to the trusts created by [PACA], so that the Produce Debtor holds the legal title to the
Produce and its derivatives or proceeds but the seller retains an equitable interest in the trust property
pending payment. Endico Potatoes, v. CIT Group/Factoring, 67 F.3d 1063, 1067 (2
nd
Cir.1995).
Accordingly, in the event of the Produce Debtor's bankruptcy, the Bankruptcy Code excludes PACA
trust assets from the bankruptcy estate. See Morris Okun, v. Harry Zimmerman, 814 F. Supp. 346, 348
(S.D.N.Y. 1993) (PACA trust assets not part of bankruptcy estate); see also 11 U.S.C. 541(d)
("Property in which the debtor holds . . . only legal title and not an equitable interest . . . becomes
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 3 of
13
4
property of the estate . . . only to the extent of the debtor's legal title to such property, but not to the
extent of any equitable interest in such property that the debtor does not hold."); United States v.
Whiting Pools, Inc., 462 U.S. 198, 205 n. 10, (1983) (Bankruptcy Code "plainly excludes [from the
bankruptcy estate] property of others held by the debtor in trust at the time of the filing of the
[bankruptcy] petition"). William E. McBryde, v. Rodriguez, 2007 U.S. Dist. LEXIS 12272,13-14
(W.D. Tex. Feb. 13, 2007)
The PACA gives express jurisdiction to the District Court and not the Bankruptcy Court. (see
Rajala v. Guaranty Bank & Trust (In re United Fruit & Vegetable, Inc.), 191 B.R. 445, 452 (Bankr. D.
Kan. 1996)) The PACA contains no mechanism for administering and distributing PACA trust assets,
like those described in the Claims Procedure. Distribution of PACA trust assets is inherently an action
for the District Court. Rio Bravo filed the District Court action to enforce its trust rights as a PACA
Trust creditor against the Debtors. Also, Mueller Trading Company, Inc. and the Wilson Davis
Company, additional PACA Creditors, filed separate actions for PACA Trust enforcement in the
Federal District Court on the same day as Rio Bravo (Case Nos. 1:11-cv-01114-SS and 5:11-cv-01125-
XR, respectfully). If not for the filing of the Debtors Petition, Rio Bravo or any other PACA Creditor
could have pursued its claims against the Debtors for PACA Trust violations in the District Court. The
Bankruptcy Court can act as a forum for the distribution of the PACA Trust assets but it cannot
disburse non-estate trust assets to any creditors other than qualified trust beneficiaries.
2. PACA TRUST ASSETS ARE NON-BANKRUPTCY ASSETS UNDER 11 USCS 541
Further, the PACA trust assets do not qualify as Bankruptcy assets under 11 USCS 541 (d),
which states [p]roperty in which the debtor holds . . . only legal title and not an equitable interest .
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 4 of
13
5
. . becomes property of the estate . . . only to the extent of the debtor's legal title to such property, but
not to the extent of any equitable interest in such property that the debtor does not hold.
The Debtors are only holding PACA trust assets for the benefit of all qualifying PACA
creditors. The Debtors had a duty to preserve trust assets for all beneficiaries, from the sale of
Produce, but have failed to do so. Until disbursement of PACA trust assets are made, pursuant to the
Claims Procedure order, the Debtors may still retain legal title over the qualifying PACA trust assets.
However, the Debtors are unable to use these assets for any purpose other than repaying the qualifying
PACA creditors their portions of the PACA Trust assets. The restriction on PACA trust assets
particularly includes any administrative expenses, such as payments made to Special Counsel for fees
and costs contributed to the Debtors defense and preservation of the PACA Trust. Therefore, the
PACA trust is non-estate property under 11 USCS 541 (d) and this Honorable Court is limited to
only disbursing PACA trust assets to qualifying PACA Creditors. Special Counsels Fee Application
must be denied as it relates to payment from the PACA trust assets.
II. PACA TRUST ASSETS CANNOT BE USED TO PAY DEBTORS
ADMINISTRATIVE FEES, PARTICULARLY SPECIAL COUNSELS FEES
Special Counsel represents the Debtors making him a trustee of the PACA Trust, with a duty
not to dissipate PACA trust assets. Awarding Special Counsels fees, from the PACA trust assets, and
not the Bankruptcy estates assets, will only further dissipate the PACA Trust in violation of PACA.
The purpose of PACA is to have the trustees preserve Trust assets for the protection of all unpaid
sellers of produce. Courts have recognized that the intent of Congress in enacting PACA's trust
provision was to provide unpaid produce sellers with greater protection from the risk of default by
buyers. Endico Potatoes, 67 F.3d at 1067; In re Kornblum, 81 F.3d at 283 (Congress enacted the trust
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 5 of
13
6
provision to broaden the protections afforded to produce suppliers). See also Tanimura & Antle, v.
Packed Fresh Produce, 222 F.3d 132, 135-136 (3
rd
Cir. 2000); Hiller Cranberry Products, v.
Koplovsky, 165 F.3d 1, 6 (1
st
Cir. 1999); In re Southland + Keystone, 132 B.R. 632, 639 (B.A.P. 9th
Cir. 1991)(PACA was established by Congress to protect sellers and suppliers of perishable
agricultural commodities until full payment of sums due have been received). Allowing a defunct
PACA trustee to pay other creditors with PACA funds before the seller is paid in full would frustrate
this purpose, and would be contrary to the language of PACA and its accompanying regulations.
PACA trust beneficiaries are entitled to full payment before trustees may lawfully use trust funds to
pay other creditors. . . PACA trustees have a duty under PACA to pay the full amount of the debt owed
to their produce suppliers. The regulations define dissipation of trust assets as any act or failure to
act which could result in the diversion of trust assets or which could prejudice or impair the ability of
unpaid [sellers] to recover money owed in connection with produce transactions. C.H. Robinson
Co. v. Alanco Corp., 239 F.3d 483, 487-488 (2
nd
Cir. N.Y. 2001)
The Debtors retained Attorney R. Glen Ayers of Langley & Banack, Inc. and Special Counsel
as Counsel of Record. Special Counsels function was to handle the defense of the PACA Trust for
the Debtors. Through the Claims Procedure, Special Counsel created an unique position allowing him
to defend PACA Trust claims, on behalf of the Debtors, and at the same time, preserve PACA trust
assets for the benefit of all PACA Creditors. Essentially, Special Counsel became counsel for all
PACA creditors and the Debtors combined. Then, Special Counsel submitted the Fee Application for
all work done in the defense of his clients AND for all work done to preserve the PACA Trust, with
fees to be paid from the PACA trust assets.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 6 of
13
7
Awarding Special Counsels fees from the PACA Trust will be counterintuitive to the purpose
of PACA and will dissipate Trust assets at the PACA creditors expense. Particularly, Special Counsel
is asking for payment, of the Debtors attorneys fees from PACA trust assets. Counsel for the K&R
Group estimates Special Counsel spent 303.32 hours and requests fees totaling $70,204.00 for the
defense of the Debtors alone, as set forth in the chart attached hereto as Exhibit A and incorporated
herein by this reference. This amount includes routine work done for the preparation and advancement
of the Debtors Bankruptcy along with time Special Counsel spent defending the PACA Trust against
PACA Creditors. In section B, paragraph 1 of the Fee Application (page 6), Special Counsel admits
work done in support of the Debtors defense, this includes: (b.) Review of PACA Claims, (c.) Filed
Motion Objecting to Various PACA Claims; (d.) Reviewed Responses to Objections and Negotiated
Compromise Resolution of Objections; and (f.) Compromised and Negotiated with Debtors. The
Debtors had a duty to preserve PACA trust assets but failed to do so, thus resulting in the District
Court Action and ultimatel y this proceeding. Awarding the Debtors attorneys fees, from the PACA
Trust, will further dissipate the PACA Trust, and essentially reward Debtors for their failures to
preserve PACA trust assets. Special Counsel is seeking attorneys fees, for the Debtors, from the same
Trust Assets the Debtors were obligated to protect. This is in stark contrast to the spirit of PACA and
only further benefits the Debtors at the expense of all PACA Creditors. Special Counsel is asking for
fees for time spent defending the Debtors rights against the PACA Creditors, which is contradictory
to PACA; therefore, Special Counsel cannot claim $95,978.00 in fees, from PACA trust assets, for
the Debtors Defense. Special Counsels request for attorneys fees must be denied.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 7 of
13
8
III. ALL OF SPECIAL COUNSELS SAFEGUARDING THE TRUST ASSETS
EFFORTS CAN BE ALLOWED, BUT NOT COMPENSABLE FROM THE
TRUST ASSETS DUE TO THE DEBTORS PRE-EXISTING DUTY TO
SAFEGUARD THEM
Special Counsel, as a trustee of the PACA Trust, is even prohibited from collecting attorneys
fees for work done to preserve the PACA trust assets. The C.H. Robinson court further held, a PACA
trustee has a fiduciary obligation under PACA to repay the full amount of the debt owed to the PACA
beneficiary. Bankruptcy trustees and other collecting agents may not owe the same fiduciary duties to
PACA beneficiaries, and therefore the law governing them is inapplicable. A PACA trustee may use
trust assets to pay ordinary business expenses as long as it does not do so at the expense of its PACA
beneficiaries, or in any way impair the ability of the beneficiaries to collect money owed in connection
with produce sales. . .(Trust assets are available for other uses by the buyer or receiver. For example,
trust assets may be used to pay other creditors. It is the buyer's or receiver's responsibility as a trustee
to insure that it has sufficient assets to assure prompt payment for produce and that any beneficiary
under the trust will receive full payment. . . .see Department of Agriculture Explanation of the
Regulations Under PACA, 49 F.R. 45735, 45738 ). To satisfy its obligations under PACA, a produce
buyer must simply maintain trust assets in a manner that such assets are freely available to satisfy
outstanding obligations to sellers of perishable agricultural commodities. 7 C.F.R. 46.46(d)(1). . .We
hold that a PACA trustee may not use PACA funds to pay attorney's fees incurred in collecting
accounts receivable held in trust for a seller of perishable agricultural commodities. Id. 488-489. The
conclusion reached in C.H. Robinson Co. was also upheld in the: U.S. Court of Appeal for the 3
rd
Circuit in Pac. Int'l Mktg., v. A & B Produce, 462 F.3d 279 (3
rd
Cir. Pa. 2006);U.S. District Court for
the District of Tennessee in Overton Distribs. v. Heritage Bank, 179 F. Supp. 2d 818 (M.D. Tenn.
2002)(over turned on other grounds); U.S. District Court for the Northern District of California in
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 8 of
13
9
Nickey Gregory Co., v. AgriCap, 2011 U.S. Dist. LEXIS 50221 (N.D. Cal. May 9, 2011) and
reaffirmed by the U.S. Court of Appeal for the 2
nd
Circuit in "R" Best Produce, v. Shulman-Rabin
Mktg., 467 F.3d 238 (2
nd
Cir. N.Y. 2006)
Counsel for the K&R Group estimates Special Counsel spent 73.94 hours and requests
$24,028.00 in fees for work done to preserve PACA Trusts, as shown in Exhibit A. In section B,
paragraph 1 of the Fee Application (page 6), Special Counsel seeks fees for work done to preserve the
PACA trust assets, this work includes: (a.) Notice of PACA Claims Procedures; (e.) Preparation of
PACA Trust Chart: (g.) Commenced Adversary Proceedings. Even though Special Counsels work
benefitted the PACA Trust, as counsel for the Debtors, Special Counsel already had the pre-existing
duty to preserve PACA trust assets. Special Counsel virtually stepped into the shoes of the Debtors
who already were obligated to preserve PACA trust assets and provide PACA creditors with the
maximum amount of payment for the sale of produce. Awarding Special Counsels fees from the
PACA trust assets will only decrease the amounts the PACA Creditors are to receive from the PACA
trust. Therefore, Special Counsels Fee Application must be denied because it will hinder the PACA
trust amount available, at the expense of all PACA creditors.
IV. SPECIAL COUNSELS FEES ARE UNREASONABLE AND SHOULD
BE DENIED
To the extent this Honorable Court believes it has the jurisdiction to disburse non-estate trust
assets to the Debtors hired professionals, the K&R Group still objects to the amounts requested.
Special Counsels fees fail the standard for reasonable fees and should be denied. The Fee Application
cites, In re First Colonial Corp., 544 F.2d 1291, 1298 (5th Cir. La. 1977), which holds [i]n order to
establish an objective basis for determining the amount of compensation that is reasonable for an
attorney's services, and to make meaningful review of that determination possible on appeal, we held
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 9 of
13
10
in Johnson v. Georgia Highway Express,, 488 F.2d at 717-19, that a district court must consider the
following twelve factors in awarding attorneys' fees: (1) The time and labor required; (2) The novelty
and difficulty of the questions; (3) The skill requisite to perform the legal service properly; (4) The
preclusion of other employment by the attorney due to acceptance of the case; (5) The customary fee;
(6) Whether the fee is fixed or contingent; (7) Time limitations imposed by the client or other
circumstances; (8) The amount involved and the results obtained; (9) The experience, reputation, and
ability of the attorneys; (10) The "undesirability" of the case; (11) The nature and length of the
professional relationship with the client; (12) Awards in similar cases. Although Johnson involved a
suit brought under 42 U.S.C.A. 2000e, the guidelines we established there are equally useful
whenever the award of reasonable attorneys' fee is authorized by statute. Id. at 1298-1299. The K&R
Group only objects to Special Counsels Time and Labor Required and Amount of Time Involved
and the Results Obtained elements.
1. TIME AND LABOR REQUIRED:
Special Counsel is requesting fees for BOTH the defense of the Debtors AND the preservation
of PACA Trust. Special Counsel fails to separate the difference between time and fees spent
Defending the Debtors and time and fees spent Preserving the PACA Trust. As stated above in
Section 2, Special Counsels efforts for the Debtor can be allowed but cannot be paid from non-estate
assets. Similarly, Special Counsels efforts for preserving the PACA trust assets cannot be paid from
non-trust assets because the Debtors pre-existing duty is applicable to Special Counsel. Thus, either
way, Debtors cannot dip into non-estate property to pay their professionals in this case.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 10
of 13
11
2. AMOUNT OF TIME INVOLVED AND THE RESULTS OBTAINED:
Special Counsel is unable to seek administrative and clerical costs as in the Fee Application.
Even though separately billed to the client, paralegal expenses are not costs within the meaning of
[Civ. P. Fed. R.] 54(d). Such expenses are separately recoverable only as part of a prevailing party's
award for attorney's fees and expenses, and even then only to the extent that the paralegal performs
work traditionally done by an attorney. Otherwise, paralegal expenses are separately unrecoverable
overhead expenses. Jones v. Armstrong Cork Co., 630 F.2d 324, 325 & n.1 (5th Cir. 1980). Allen
v. United States Steel Corp., 665 F.2d 689, 697 (5
th
Cir. Ala. 1982). Special Counsel seeks $9,490.00
for clerical work done in relation to this matter. This amount is separate from traditional legal work
and cannot be included in the Fee Application. Therefore, Special Counsels request for clerical fees
should be denied, in the amount of $9,490.00.
MISCELLANEOUS OBJECTIONS
1. The K&R Group objects to Special Counsels time entry, for February 21, 2012. The
Hour/Rate column incorrectly states 9.80 hours performed as opposed to the 0.80 hours of work
described. The Corrected Amount charge should read $280.00 instead of $3,430.00.
2. The K&R Group objects to Special Counsels break down of Attorney Jessie Lopezs
total time worked. Attorney Lopez worked a total of 86.64 hours at the rate of $200/hr for a total of
$17,328.00.
3. Included in Exhibit A is a corrected breakdown of Special Counsels fee application.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 11
of 13
12
WHEREFORE the K&R Group requests this Honorable Court to deny Special PACA
Counsels First Interim Application for Attorneys Fees & Costs from being paid from PACA trust
assets:
(1) Because the PACA trust is a non-estate assets and this Honorable Court is only able to
disburse bankruptcy assets;
(2) The Special PACA Counsel, as counsel to the Debtors cannot receive compensation
from the PACA trust assets, for defending the Debtors;
(3) Special Counsel already has a pre-existing duty to preserve PACA trust assets and
therefore cannot seek attorneys fees from PACA trust assets;
(4) Because the amount the Special PACA Counsel claims is unreasonable; and,
(5) Provide such other and further relief as the Court deems appropriate upon consideration
of this matter.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 12
of 13
13
Dated: September 4, 2012 Respectfully Submitted,
KINGDOM FRESH PRODUCE, INC.,
I.KUNIK CO., INC., FIVE BROTHERS
JALISCO PRODUCE CO. INC d/b/a
BONANZA 2001, RIO BRAVO PRODUCE
LTD. CO., LLC, & G.R. PRODUCE, INC.
By: /s/ Kevin P. Kelley, Esq.
One of Their Attorneys
Kevin P. Kelley, Esq.
KEATON & ASSOCIATES, P.C.
1278 W. Northwest Highway, Suite 903
Palatine, Illinois 60067
Tel: 847/934-6500
Fax: 847/ 934-6508
E-mail: kelley@pacatrust.com
Counsel for the K&R Group
Louis T. Rosenberg, Esq.
LAW OFFICES OF LOUIS T.
ROSENBERG, P.C.
De Mazieres Building
322 Martinez Street
San Antonio, Texas 78205
Tel: 210/ 225-5454
Fax: 210/ 225-5450
E-mail: firm@ltrlaw.com
Counsel for the K&R Group
CERTIFICATE OF SERVICE
I hereby certify that on September 4, 2012, I electronically filed the foregoing with the Clerk
of the Court using the CM/ ECF system which will send a notice of electronic filing to all parties of
record.
By: / s/ Kevin P. Kelley, Esq.
12-50073-lmc Doc#294 Filed 09/04/12 Entered 09/04/12 20:18:46 Main Document Pg 13
of 13
12-50073-lmc Doc#294-1 Filed 09/04/12 Entered 09/04/12 20:18:46 Exhibit Pg 1 of 1
EXHIBIT A
BREAKDOWN OF SPECIAL COUNSEL'S FIRST INTERIM APPLICATION FOR ATTORNEY'S FEES AND
COSTS
Craig Stokes
HOURS IN DEFENSE OF DEBTORS* 127.00
HOURLY RATE $ 350.00
TOTAL FEES FOR DEBTORS
$ 44,450.00
HOURS PRESERVING PACA TRUST 61.60
HOURLY RATE $ 350.00
TOTAL FEES FOR PACA TRUST
$ 21,560.00
TOTAL INDVIDUAL'S FEE
$ 66,010.00
PROFESSIONALS' TOTAL HOURS
DEBTORS DEFENSE 127.00
PRESERVING PACA TRUST 61.60
PROFESSIONAL'S TOTAL HOURS
PROFESSIONAL FEES
DEBTORS DEFENSE
PRESERVING PACA TRUST
TOTAL PROFESSIONAL FEES
COSTS INCURRED
SPECIAL COUNSEL'S TOTAL FEES & COSTS
*Special Counsel's Computation errors are corrected
Jessie Lopez
$
$
$
$
$
81.32
200.00
16,264.00
5.32
200.00
1,064.00
17,328.00
81.32
5.32
86.64
Rosa Barrera
$
$
$
$
$
94.90
100.00
9,490.00
0.00
9,490.00
94.9
0
94.9
$
$
$
$
$
$
$
$
TOTAL
303.22
70,204.00
66.92
22,624.00
92,828.00
303.22
66.92
275.24
70,204.00
22,624.00
92,828.00
2,492.97
95,320.97