1

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

IN RE: CASE NO. 5:12-BK-50073-LMC
(CHAPTER 11)
DELTA PRODUCE, L.P.,
1
JOINTLY ADMINISTERED

DEBTOR.

____________________________________________________________________________

OMNIBUS CLAIM FOR ATTORNEYS FEES AND COSTS
____________________________________________________________________________

Eco-Farms Sales, Inc., Gargiulo, Inc., Henry Avocado Corp. and Rio Queen
Citrus, Inc., trust beneficiaries of Delta Produce, L.P. (the Debtor) under the trust
provisions of the Perishable Agricultural Commodities Act, 1930, as amended
(PACA), 7 U.S.C. 499e(c), by and through their undersigned attorneys and pursuant
to the Order on Ex Parte Motion by Special PACA Trust Counsel to Modify Claims
Procedure [DE 288], submit this omnibus claim for attorneys fees and costs, stating as
follows:
1. Debtor filed its Voluntary Petition for protection under Chapter 11 of the
Bankruptcy Code on January 3, 2012 [DE 1].
PROCEDURAL HISTORY
2. On January 25, 2012, the Court entered an Order Establishing a Deadline
to File PACA Trust Claims, for Procedures to Resolve Those Claims, and for
Appointment of Special PACA Counsel [DE 52].
1
Debtors are the following entities: Delta Produce, L.P. Case No. 12-50073-LMC, Superior Tomato-
Avocado, Ltd. Case No. 12-50074-LMC, Atled, Ltd. Case No. 12-50075-LMC and Staci Properties, Ltd.
Case No. 12-50110-LMC.
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3. On February 29, 2012, the Court entered an Amended Order Establishing
a Deadline to File PACA Trust Claims, for Procedures to Resolve Those Claims, and for
Appointment of Special PACA Counsel [DE 124] (the Claims Procedure Order),
setting a deadline of March 2, 2012 for any supplier of perishable agricultural
commodities of Debtor to file a PACA trust claim The Claims Procedure Order stated
that the PACA trust beneficiaries of Debtor would receive separate notice of a deadline
within which claims for attorneys fees and costs could be filed.
4. On March 1, 2012, Eco-Farms Sales, Inc. (Eco-Farms) filed its PACA
Proof of Claim with supporting documentation for its principal and interest claim in the
amount of $25,815.10 [Claim #50].
5. On March 1, 2012, Gargiulo, Inc. (Gargiulo) filed its PACA Proof of
Claim with supporting documentation for its principal and interest claim in the amount
of $9,998.87 [Claim #51].
6. On March 1, 2012, Henry Avocado Corp. (Henry Avocado) filed its
PACA Proof of Claim with supporting documentation for its principal and interest
claim in the amount of $50,847.47 [Claim #52].
7. On March 1, 2012, Rio Queen Citrus, Inc. (Rio Queen) filed its PACA
Proof of Claim with supporting documentation for its principal and interest claim in the
amount of $32,518.04 [Claim #53].
8. Special PACA Counsel filed his Objections to Claims on March 22, 2012
[DE 159].
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9. Eco-Farms, Gargiulo, Henry Avocado and Rio Queen filed their Omnibus
Response to Special PACA Counsels Objections to Claims on April 16, 2012 [DE 206].
10. On August 21, 2012, Special PACA Counsel filed an Ex-Parte Motion to
Modify Claims Procedure, requesting the Court to set a deadline by which all PACA
trust beneficiaries claiming a right to attorneys' fees would be required to submit claims
[DE 285].
11. On August 23, 2012, the Court entered an Order modifying the Claims
Procedure Order as requested by Special PACA Counsel [DE 288]. Pursuant to the
Order, all PACA trust beneficiaries claiming a right to attorneys fees were required to
file such claims within 21 days of entry of the Order.
12. Eco-Farms, Gargiulo, Henry Avocado and Rio Queen hereby submit their
claims for attorneys fees and costs.
13. The PACA provides that a dealer who receives perishable agricultural
commodities, or produce, must hold the produce, all inventories derived from the
produce and receivables from the sale of such produce in trust "for the benefit of all
unpaid suppliers or sellers of such commodities ... until full payment of the sums owing
in connection with such transaction has been received." See, 7 U.S.C. 499e(c)(2).
FACTUAL AND LEGAL ARGUMENTS
14. The Second, Ninth and Eleventh Circuits have held that if provisions for
the payment of attorneys fees are included in the produce sales contract, they are sums
owing in connection with the transactions and are included as part of the sellers
underlying PACA trust claim. Country Best v. Christopher Ranch, LLC, 361 F.3d 629 (11th
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5
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Cir. 2004); Coosemans Specialties, Inc. v. Gargiulo, 2007 U.S. App. Lexis 10520 (2d Cir.,
2007); and, Middle Mountain Land and Produce, Inc. v. Sound Commodities, Inc., 307 F.3d
1220 (9th Cir. 2002).
15. Here, Eco-Farms, Gargiulo, Henry Avocado and Rio Queen all included
provisions on their invoices their sales contracts entitling them to recover attorneys
fees from the Debtor, in the event collection of their outstanding invoices became
necessary. See, Exhibits A to Claim ##50-53. Thus, each has a valid claim for
recovery of its attorneys fees and cost in connection with its collection efforts.
16. Eco-Farms has incurred fees and costs of $5,846.45; Gargiulo has incurred
fees and costs of $2,244.27; Henry Avocado has incurred fees and costs of $11,692.90;
and, Rio Queen has incurred fees and costs of $7,565.51.
17. In support of their claims, Eco-Farms, Gargiulo, Henry Avocado and Rio
Queen submit the Declaration of Counsel filed herewith as Exhibit A.
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WHEREFORE, Eco-Farms, Gargiulo, Henry Avocado and Rio Queen respectfully
request that their claims for attorneys fees and costs in the aggregate amount of
$27,349.13 be paid in full.
Respectfully submitted on Thursday, September 13, 2012.




MEUERS LAW FIRM, P.L.

/s/Steven E. Nurenberg
Steven E. Nurenberg
Pro Hac Vice
2
5395 Park Central Court

Naples, FL 34109-5932
Telephone: (239) 513-9191
Facsimile: (239) 513-9677
snurenberg@meuerslawfirm.com

Attorneys for Rio Queen Citrus, Inc., Gargiulo,
Inc., Eco Farms Sales, Inc. and Henry Avocado
Corp.


CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this Omnibus Claim was filed with the Clerk of the
Court and served via the Courts CM/ECF system upon all attorneys of record and
parties receiving such service this Thursday, September 13, 2012.

By: /s/Steven E. Nurenberg
Steven E. Nurenberg


2
Steven E. Nurenberg is admitted pro hac vice in the jointly administered cases of In re Delta Produce,
Inc., Case No. 12-50073-LMC, In re Superior Tomato-Avocado, Ltd., Case No. 12-50074-LMC, In re Alted,
Ltd., Case No. 12-50075-LMC, and In re Staci Properties, Ltd., Case No. 12-50110-LMC.
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Exhibit A
12-50073-lmc Doc#303-1 Filed 09/13/12 Entered 09/13/12 13:28:21 Exhibit Declaration
Pg 1 of 7
1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION

IN RE: CASE NO. 5:12-BK-50073-LMC
(CHAPTER 11)
DELTA PRODUCE, L.P.,
1
JOINTLY ADMINISTERED

DEBTOR.

____________________________________________________________________________

DECLARATION OF STEVEN E. NURENBERG IN SUPPORT OF OMNIBUS
CLAIM FOR ATTORNEYS FEES AND COSTS
____________________________________________________________________________

I, Steven E. Nurenberg, declare:
1. I am an attorney with Meuers Law Firm, P.L., counsel for Eco-Farms Sales,
Inc., Gargiulo, Inc., Henry Avocado Corp. and Rio Queen Citrus, Inc., in the above-
captioned matter.
2. I am licensed to practice before all courts in the States of Florida, Michigan
and New York. Additionally, I am admitted to practice in several of the United States
District Courts and the United States Supreme Court.
3. I am over 18 years of age, have personal knowledge of all matters stated in
this Affidavit and if called as a witness, I could competently testify as to the facts stated
herein.
3. This Declaration is submitted in support of the Omnibus Claim for
Attorneys Fees and Costs filed by Eco-Farms Sales, Inc., Gargiulo, Inc., Henry Avocado
1
Debtors are the following entities: Delta Produce, L.P. Case No. 12-50073-LMC, Superior Tomato-
Avocado, Ltd. Case No. 12-50074-LMC, Atled, Ltd. Case No. 12-50075-LMC and Staci Properties, Ltd.
Case No. 12-50110-LMC.
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Pg 2 of 7
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Corp. and Rio Queen Citrus, Inc. (the Omnibus Claim).
4. Delta Produce, L.P. (the Debtor) filed its Voluntary Petition for
protection under Chapter 11 of the Bankruptcy Code on January 3, 2012 [DE 1].
5. Meuers Law Firm, P.L. was retained by Eco-Farms Sales, Inc., Gargiulo,
Inc., Henry Avocado Corp. and Rio Queen Citrus, Inc. to protect their trust rights
against the Debtor under the Perishable Agricultural Commodities Act of 1930, 7 U.S.C.
499a-499t (the PACA).
6. Since Meuers Law Firm, PL is located in Naples, Florida, we retained
attorney Michael J. Burns of Burns & Black, PLLC, who is a member of the bar of this
Court, to act as local counsel.
7. In the instant matter, I performed services at my normal hourly rate of
$280.00. Assisting me were attorneys Lawrence H. Meuers, who performed services at
his normal hourly rate of $350.00, and Steven M. De Falco, who performed services at
his normal hourly rate of $270.00.
8. A true and correct copy of the itemized billing statement for services
rendered by Meuers Law Firm, P.L. is attached to the Omnibus Claim as Exhibit B.
The invoice was prepared under my control and supervision in the ordinary course of
business by an employee whose duty it is to prepare such documents, and the entries
contained therein were made at or near the time of the occurrence of the event of which
they are a record.
9. Attached to the Omnibus Claim as Exhibit C is a true and correct copy
of the itemized billing statement for services rendered by Burns & Black, PLLC.
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Pg 3 of 7
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10. Further, I submit that the following analysis of the factors set forth in In re
First Colonial Corporation of America, 544 F.2d 1291 (5th Cir. 1977), cert. denied 431 U.S.
904 (1977), support the reasonableness of the fees:
a. Time and labor required
b.
: Exhibits B and C include copies of the
billing statements of Meuers Law Firm, P.L and Burns & Black, PLLC.
The statements detail the legal services for which compensation is
being sought as well as the individual attorneys description of the
services provided. As stated above, the records were made at or near
the time of the occurrence of the event of which they are a record.
Novelty and difficulty of the questions presented
c.
: Meuers Law Firm,
P.L. specializes in the area of PACA trust enforcement litigation. In
that respect, the issues presented in this case are not novel for Meuers
Law Firm, P.L.
Skill requisite to perform the legal services properly
d.
: Meuers Law
Firm, P.L. was retained by Eco-Farms Sales, Inc., Gargiulo, Inc., Henry
Avocado Corp. and Rio Queen Citrus, Inc. specifically for its
knowledge and skill in handling PACA issues.
Preclusion of other employment due to the acceptance of this case:
Meuers Law Firm, P.L. has not been required to refuse other matters in
order to provide representation to Eco-Farms Sales, Inc., Gargiulo, Inc.,
Henry Avocado Corp. and Rio Queen Citrus, Inc. in this matter.
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Pg 4 of 7
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e. Customary fee
f.
: The fees charged in this case are the customary fees
charged for similar cases involving PACA trust claims and consistent
with those prescribed in the PACA Order.
Whether fee is fixed or contingent
g.
: The fees charged in this case were
neither fixed nor contingent. Eco-Farms Sales, Inc., Gargiulo, Inc.,
Henry Avocado Corp. and Rio Queen Citrus, Inc. have all been
charged on an hourly basis.
Time limitations imposed by the client or other circumstances
h.
: Certain
time limitations were imposed by the Order Establishing a Deadline to
File PACA Trust Claims, for Procedures to Resolve Those Claims, and
for Appointment of Special PACA Counsel (the Claims Procedure
Order) [DE 52] and this Courts Order modifying the Claims
Procedure Order [DE 288]. Meuers Law Firm, P.L. has abided by these
limitations in fully protecting the rights of Eco-Farms Sales, Inc.,
Gargiulo, Inc., Henry Avocado Corp. and Rio Queen Citrus, Inc. under
PACA.
Amount of time involved and the results obtained: The amount of
time involved in representing and protecting the interests of Eco-
Farms Sales, Inc., Gargiulo, Inc., Henry Avocado Corp. and Rio Queen
Citrus, Inc. is detailed in the attached exhibits. As a result of the efforts
of Meuers Law Firm, P.L. and Burns & Black, PLLC, the PACA trust
claims of Eco-Farms Sales, Inc., Gargiulo, Inc., Henry Avocado Corp.
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Pg 5 of 7
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and Rio Queen Citrus, Inc. have been preserved and validated in full
for payment by the Debtor.
i. The experience, reputation, and ability of the attorneys
j.
: Meuers Law
Firm, P.L. is a small, specialized firm that represents agricultural
producers and distributors throughout the United States in the area of
trust enforcement litigation under PACA. Meuers Law Firm, P.L. is
among a small number of firms in the United States that specialize in
this area of practice and its members and associates are well-versed in
all areas of PACA litigation.
Undesirability of the case
k.
: The subject matter of this case is within
Meuers Law Firm, P.L.s expertise and is, therefore, not undesirable.
The nature and length of the professional relationship with the client
l.
:
Meuers Law Firm, P.L. has enjoyed lengthy professional relationships
with Eco-Farms Sales, Inc., Gargiulo, Inc., Henry Avocado Corp. and
Rio Queen Citrus, Inc.
Award in similar cases
26. Based upon the above analysis, it is my opinion that the rates set forth in
the billing attached hereto constitute reasonable hourly rates and that the following fees
and expenses are reasonable:
: Meuers Law Firm, P.L.s request for fees and
expenses in this matter is consistent with such fees and expenses it has
incurred and recovered in similar cases.
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Pg 6 of 7
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Pg 7 of 7

FIRM AMOUNT
Meuers Law Firm, P.L. $26,370.00
Burns & Black, PLLC $979.13
TOTAL $27,349.13
Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the above
statements are true and correct.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that this Declaration was filed with the Clerk of the Court
and served via the Court's CM/ECF system upon all attorneys of record and parties
receiving such service this Thursday, September 201 . /
6
Exhibit B
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1 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
Component: Local
3/31/2012 Local 979.13 1.00 979.13 Local Counsel
979.13 1.00 Component: Local
Component: T
12/30/2011 T 350.00 LHM 1.00 350.00 Telephone conference with clients regarding
facts and their claims.
1/3/2012 T 350.00 LHM 1.00 350.00 Receipt and review of of client documents;
case strategy; meeting with attorney
Nurenberg.
12/29/2011 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
new matter.
12/29/2011 T 112.00 SEN 0.40 280.00 Preparation and exchange of
correspondences with debtor's counsel
regarding matter.
12/29/2011 T 112.00 SEN 0.40 280.00 Receipt and review of client invoices and
statement; Review invoices for trust
compliance.
12/29/2011 T 56.00 SEN 0.20 280.00 Telephone call to C&R Fresh regarding claim.
12/29/2011 T 112.00 SEN 0.40 280.00 Preparation and exchange of
correspondences with counsel for PACA
creditor regarding claims.
9/13/2012 1:26 PM Page: 1
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2 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
1/4/2012 T 350.00 LHM 1.00 350.00 Receipt and review of of bankruptcy filing
documents; correspondence with clients
regarding their claims; Receipt and review of
of client documents; meeting with attorneys
regarding strategy.
1/5/2012 T 81.00 SMD 0.30 270.00 Exchange correspondences with clients
about their claims and potential recovery.
1/3/2012 T 168.00 SEN 0.60 280.00 Telephone conference with Debtor's counsel
regarding claims and bankruptcy procedure.
1/3/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
counsel regarding anticipated recovery.
1/4/2012 T 112.00 SEN 0.40 280.00 Telephone conference with client regarding
bankruptcy (x2).
1/4/2012 T 56.00 SEN 0.20 280.00 Review correspondence to client regarding
case and recovery.
1/4/2012 T 112.00 SEN 0.40 280.00 Receipt and review of correspondence from
client with additional information regarding
bankruptcy.
1/5/2012 T 112.00 SEN 0.40 280.00 Telephone conference with client regarding
potential claims procedure.
1/5/2012 T 504.00 SEN 1.80 280.00 Receipt and review of multiple documents
substantiating claims; Preparation of claims
chart; Telephone call with counsel regarding
claims.
9/13/2012 1:26 PM Page: 2
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3 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
1/5/2012 T 56.00 SEN 0.20 280.00 Telephone conference with Fresh Start
regarding claim.
1/5/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Eco Farms invoices;
Review invoices for compliance with PACA;
Calculation of valid trust claim.
1/6/2012 T 560.00 SEN 2.00 280.00 Review Docket Report on main bankruptcy
case; Review Associated bankruptcy cases;
Review Docket Report for Superior Produce
Bankruptcy Case; Review Local Rules
regarding Appearances; Review Rules on
Admission.
1/6/2012 T 112.00 SEN 0.40 280.00 Telephone conference with local counsel
regarding representation.
1/6/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
client regarding Unsecured Creditors
Committee.
1/6/2012 T 112.00 SEN 0.40 280.00 Review Unsecured Creditors Committee
document; Preparation of correspondence to
client.
1/6/2012 T 112.00 SEN 0.40 280.00 Review Docket Report and filings of Delta v.
H.E.B.
1/5/2012 T 175.00 LHM 0.50 350.00 Telephone conference with clients regarding
their claims; Receipt and review of
documents.
12/29/2011 T 175.00 LHM 0.50 350.00 Telephone conference with Clients regarding
facts of company closing and issues
regarding claims; Correspondence from
Delta's attorney.
9/13/2012 1:26 PM Page: 3
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4 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
1/9/2012 T 168.00 SEN 0.60 280.00 Organization of invoices and preparation of
chart.
1/9/2012 T 56.00 SEN 0.20 280.00 Preparation of correspondence to The Packer
regarding inquiry about claims.
1/9/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
counsel regarding Hearing.
1/10/2012 T 112.00 SEN 0.40 280.00 Review Docket Report regarding Proof of
Claim deadline and filings.
1/10/2012 T 56.00 SEN 0.20 280.00 Telephone conference with local counsel
regarding filing.
1/10/2012 T 168.00 SEN 0.60 280.00 Preparation of Notice of Appearance.
1/10/2012 T 168.00 SEN 0.60 280.00 Receipt and review of Divine Ripe invoices;
Review to confirm compliance with PACA;
Calculation of valid claim.
1/10/2012 T 84.00 SEN 0.30 280.00 Preparation of correspondence to local
counsel with enclosure.
1/12/2012 T 56.00 SEN 0.20 280.00 Telephone conference with Henry Avocado
regarding claim.
1/12/2012 T 448.00 SEN 1.60 280.00 Preparation of Motion for Admission Pro Hac
Vice; Review Local Rules and procedures for
Admission.
9/13/2012 1:26 PM Page: 4
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5 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
1/12/2012 T 112.00 SEN 0.40 280.00 Receipt and review of henry Avocado
invoices; Review invoices for compliance with
PACA; Calculate valid principal claim.
1/12/2012 T 112.00 SEN 0.40 280.00 Receipt and review of correspondence from
counsel; Review proposed Motion to Permit
use of Funds; Review Proposed Order.
1/13/2012 T 56.00 SEN 0.20 280.00 Telephone conference with local counsel
regarding filings.
1/13/2012 T 56.00 SEN 0.20 280.00 Telephone conference with counsel regarding
claims of bank.
1/19/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
filings.
1/20/2012 T 280.00 SEN 1.00 280.00 Review Docket Report regarding status of
consolidation of Superior Tomato case;
Revision to Pro Hac Vice Motion based upon
Joint Administration; Preparation of
correspondence to local counsel.
1/24/2012 T 140.00 SEN 0.50 280.00 Review Docket Report; Preparation of
correspondence to clients regarding Hearing
on Claims Procedure.
1/24/2012 T 56.00 SEN 0.20 280.00 Telephone conference with Co-Plaintiff's
counsel regarding Hearing.
1/24/2012 T 56.00 SEN 0.20 280.00 Preparation of correspondence to local
counsel regarding Hearing.
9/13/2012 1:26 PM Page: 5
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6 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
1/31/2012 T 112.00 SEN 0.40 280.00 Review Docket Report regarding Claims
Deadline; Preparation of correspondence to
client.
1/16/2012 T 112.00 SEN 0.40 280.00 Receipt and review of Proposed Claims
Procedure Order, Proof of Claim form and
distribution chart.
1/17/2012 T 168.00 SEN 0.60 280.00 Receipt, review and exchange of multiple
correspondence from counsel regarding
proposed Claim Procedure Order.
1/26/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence
regarding results of hearing on motions.
2/2/2012 T 56.00 SEN 0.20 280.00 Telephone conference with local counsel
regarding Pro Hac Vice Motion.
2/2/2012 T 112.00 SEN 0.40 280.00 Revise Motion for Admission Pro Hac Vice;
Preparation of correspondence to local
counsel.
2/2/2012 T 140.00 SEN 0.50 280.00 Preparation of correspondence to clients
regarding Claims Procedure.
2/14/2012 T 112.00 SEN 0.40 280.00 Telephone conference with counsel regarding
Proof of Claim.
2/14/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
clerk's office regarding ECF access.
2/15/2012 T 168.00 SEN 0.60 280.00 Receipt of ECF authorization; Update Pro
Hac Vice Motion; ECF filing of Motion.
9/13/2012 1:26 PM Page: 6
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7 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
2/15/2012 T 392.00 SEN 1.40 280.00 Review Henry Avocado invoices for
information to complete Trust Chart; Prepare
Trust Chart; Prepare Proof of Claim.
2/15/2012 T 224.00 SEN 0.80 280.00 Research Secretary of State records
regarding relationship between Delta
Produce, L.P. and Delta Produce Marketing,
Inc.
2/15/2012 T 112.00 SEN 0.40 280.00 Telephone conference with Court (x2)
regarding ECF access and Pro Hac Vice
Motion.
2/16/2012 T 392.00 SEN 1.40 280.00 Review Eco invoice for information to
complete Trust Chart; Preparation of Trust
Chart; Calculation of fees and interest;
Preparation of Proof of Claim.
2/16/2012 T 560.00 SEN 2.00 280.00 Review Rio Queen invoices for information to
complete Trust Chart; Preparation of Trust
Chart; Calculation of fees and interest;
Preparation of Proof of Claim.
2/16/2012 T 448.00 SEN 1.60 280.00 Review Gargiulo invoices for information to
complete Trust Chart; Preparation of Trust
Chart; Calculation of fees and interest;
Preparation of Proof of Claim.
2/17/2012 T 56.00 SEN 0.20 280.00 Receipt and review of signed Proof of Claim
and Bills of Lading from Rio Queen.
2/21/2012 T 280.00 SEN 1.00 280.00 Final review and edit of remaining Proofs of
Claim; Preparation of correspondence to
clients with enclosure.
2/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of signed Proof of Claim
from client.
2/28/2012 T 280.00 SEN 1.00 280.00 Receipt and review of Proofs of Claim (x5);
Review claims for validity of trust protection.
9/13/2012 1:26 PM Page: 7
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8 of 23
Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
3/1/2012 T 270.00 SMD 1.00 270.00 Final review of clients' Proofs of Claim (x4).
3/1/2012 T 280.00 SEN 1.00 280.00 Filing of Proofs of Claim and all supporting
exhibits.
3/1/2012 T 280.00 SEN 1.00 280.00 Review Proofs of Claim (x5) filed by PACA
Trust creditors for compliance of trust
requirements; Review invoices and verify
claims; Determine basis for objections.
3/2/2012 T 280.00 SEN 1.00 280.00 Review Claims Procedure Order to confirm
compliance with procedures; Review all filed
claims to confirm proper upload onto system.
3/2/2012 T 224.00 SEN 0.80 280.00 Preparation of Case Status Update.
3/2/2012 T 448.00 SEN 1.60 280.00 Continued review of Proofs of Claim filed by
non-client trust creditors (x8) for compliance
with trust requirements; Review invoices;
Determine if any claims are subject to
objection.
3/5/2012 T 56.00 SEN 0.20 280.00 Finalize an distribute Case Status Update.
3/5/2012 T 448.00 SEN 1.60 280.00 Continued review of non-client Proofs of Claim
(x8) for objections; Review invoices for trust
compliance.
3/6/2012 T 392.00 SEN 1.40 280.00 Review remaining non-client Proofs of Claim
(x7) for compliance with trust requirements;
Review invoices to confirm compliance;
Determine if any objections are necessary.
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
3/13/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
client regarding transportation costs.
3/15/2012 T 112.00 SEN 0.40 280.00 Review Claims Procedure Order and
deadlines for objections to claims; Review
Order on Special PACA counsel's procedure
for objections.
3/19/2012 T 224.00 SEN 0.80 280.00 Receipt and review of documentation from
client with correspondence from Special
PACA counsel regarding set-off; Review
spreadsheet of changes and totals.
3/20/2012 T 168.00 SEN 0.60 280.00 Receipt and review of Proof of Claim and
Notice of Filing; Review claim for PACA trust
compliance and validity.
3/20/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion by Special
PACA counsel to extend deadline for
objections to claims.
3/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to extend time
to object to claims.
3/21/2012 T 56.00 SEN 0.20 280.00 Review Docket Report regarding Objections
to claims.
3/22/2012 T 224.00 SEN 0.80 280.00 Receipt and review of objections to multiple
PACA claims filed by Special PACA counsel;
Review basis for objections; Verify validity of
objections and potential defenses.
3/22/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Amended Objections to
Chart.
3/23/2012 T 112.00 SEN 0.40 280.00 Telephone conference with Special PACA
counsel regarding Objections to claims.
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
3/23/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Extend
Deadline for Objection to Claims.
3/23/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Special PACA counsel regarding Withdrawal
of Objection.
3/26/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Extend
Deadlines by Special PACA counsel.
3/27/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order Extending
Deadlines.
3/28/2012 T 224.00 SEN 0.80 280.00 Review correspondence from Special PACA
counsel regarding offset of claim; Review
Account detail regarding invoices and
payments.
3/29/2012 T 168.00 SEN 0.60 280.00 Review deadline for Response to Objections;
Review terms of proposed resolution of PACA
counsel.
3/29/2012 T 392.00 SEN 1.40 280.00 Initial preparation of Response to Objection.
3/29/2012 T 56.00 SEN 0.20 280.00 Preparation of correspondence to client
regarding claimed set-off.
3/30/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
documentation to address set-off claim.
3/30/2012 T 112.00 SEN 0.40 280.00 Telephone conference with PACA counsel
regarding set-off claim.
9/13/2012 1:26 PM Page: 10
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
3/30/2012 T 112.00 SEN 0.40 280.00 Preparation of correspondence to PACA
counsel regarding claim against bank.
3/30/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Omnibus Objections to
PACA claims.
3/30/2012 T 56.00 SEN 0.20 280.00 Receipt and review of accounts payable
documentation from client for objection
response.
3/21/2012 T 175.00 LHM 0.50 350.00 Correspondence with Delta's attorney
regarding various issues and assets held by
Bank.
4/12/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
set-off of claim.
4/12/2012 T 224.00 SEN 0.80 280.00 Review summary of claims; Calculation of
reductions and verification of distributions.
4/13/2012 T 112.00 SEN 0.40 280.00 Review Docket report and text for Responses
to Objections; Review Notice of Hearing on
Objections.
4/13/2012 T 504.00 SEN 1.80 280.00 Preparation of Response to Objections.
4/13/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Responses to
Objections.
4/16/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Response to Claims
Objections by Mecca.
9/13/2012 1:26 PM Page: 11
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
4/16/2012 T 56.00 SEN 0.20 280.00 Review Amended Summary of Claims,
Objections and Allowances.
4/16/2012 T 224.00 SEN 0.80 280.00 Revise draft Response to Objections;
Preparation of final draft for filing; ECF filing of
Response.
4/16/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Response to
Objections filed by Muller.
4/16/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of hearing on
Objections.
4/17/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
local counsel regarding Pleadings.
4/20/2012 T 112.00 SEN 0.40 280.00 Receipt and review of multiple Notices of
Hearing regarding Objections to Claims.
5/2/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to convert case
to Chapter 7.
5/3/2012 T 448.00 SEN 1.60 280.00 Receipt and review of Multiple Proofs of Claim
(x10); Review for PACA claims.
5/7/2012 T 112.00 SEN 0.40 280.00 Telephone conference with opposing counsel
regarding Bills of Lading.
5/8/2012 T 168.00 SEN 0.60 280.00 Receipt and review of Accounts Receivable
Reconciliation of all claims from opposing
counsel; Review reconciliation of clients'
claims.
9/13/2012 1:26 PM Page: 12
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
5/8/2012 T 728.00 SEN 2.60 280.00 Receipt and review of multiple invoices (x20)
from opposing counsel with supporting
Purchase Orders and Bills of Lading
regarding Claim for offset; Development of
defense strategy for response to claim for
offset.
5/9/2012 T 168.00 SEN 0.60 280.00 Review proposed Motion to Compromise
Objections; Preparation of correspondence to
Special PACA Counsel regarding revisions to
Motion.
5/9/2012 T 224.00 SEN 0.80 280.00 Telephone conference with Special PACA
Counsel regarding offset; Review documents
prepared by counsel and compare to client
records.
5/9/2012 T 168.00 SEN 0.60 280.00 Telephone conference with client regarding
outstanding Accounts Payable to Delta;
Forward all invoices and documentation to
client for review; Telephone conference with
client (2d call) regarding invoices.
5/9/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Special PACA
Counsel's Motion to Approve Compromises
and to Set Trial as to disputes.
5/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Motion to
Convert case from U.S. Trustee.
5/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Resetting
Hearing on Special PACA Counsel's
Objections to Claims.
5/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Hearing to act
upon Compromises.
5/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion for Relief from
Stay fled by secured creditor; Receipt and
review of Affidavit in Support.
9/13/2012 1:26 PM Page: 13
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
5/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Adversary Complaint
filed by Superior Tomato.
5/15/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
client regarding deadline to respond.
5/15/2012 T 56.00 SEN 0.20 280.00 Review Docket regarding deadline;
Preparation of correspondence to client.
5/15/2012 T 112.00 SEN 0.40 280.00 Receipt of Operating Report Summary for
Month; Review Comparative Balance Sheets;
Review Cash receipts, disbursements and
reconciliation.
5/17/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order regarding
allowance of fees with claims.
5/17/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Debtor's Response to
Trustee's Motion to Convert case to Chapter
7.
5/18/2012 T 168.00 SEN 0.60 280.00 Review Adversary Complaint; Preparation of
correspondence to counsel regarding
Pleading.
5/18/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Thienpoint Produce regarding Third-Party
debt.
5/18/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Special PACA Counsel regarding Thienpoint
Produce.
5/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Special PACA counsel regarding Adversary
Complaint against International Bank of
Commerce.
9/13/2012 1:26 PM Page: 14
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
5/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Approve
Compromise of Claims.
5/23/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Hearing and
Motion to Convert Cases to Chapter 7.
5/24/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
reconciliation of claim.
5/24/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Special PACA Counsel regarding Adversary
case.
5/24/2012 T 56.00 SEN 0.20 280.00 Receipt and review of confirmation of
docketing Adversary case.
5/25/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Expedite
Hearing and Motion to Sell Property Free and
Clear of Liens.
5/25/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Sell Property
Free and Clear of Liens.
5/29/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Sell Property
Free and Clear of Liens.
5/29/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Cash Balance Report
from Special PACA counsel.
5/30/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order on Motion to
Expedite Hearings.
9/13/2012 1:26 PM Page: 15
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
5/31/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order granting Motion
to Sell Property.
6/5/2012 T 112.00 SEN 0.40 280.00 Exchange of correspondence with Special
PACA counsel regarding claims.
6/5/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of filing First
PACA Trust Chart.
6/6/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order allowing sale of
property.
6/7/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order regarding Motion
for Relief from Stay.
6/8/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
offset.
6/11/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion to Continue use
of Cash Collateral by Debtor.
6/12/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order regarding
continued use of Cash Collateral by Debtor.
6/15/2012 T 56.00 SEN 0.20 280.00 Receipt and review of IBC Motion to Dismiss
Adversary Complaint.
6/15/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion by IBC for
determination that Adversary case is a
non-core proceeding.
9/13/2012 1:26 PM Page: 16
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
6/15/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence
regarding conference on Motion to Dismiss
and Motion for Determination of Non-Core
Proceeding.
6/18/2012 T 224.00 SEN 0.80 280.00 Preparation for conference regarding Motion
to Dismiss; Telephone appearance for
conference.
6/18/2012 T 280.00 SEN 1.00 280.00 Review of Motion for Determination of
Non-Core Proceeding and outline arguments.
6/18/2012 T 112.00 SEN 0.40 280.00 Receipt and review of multiple
correspondence regarding conference and
Reply to Motion to Dismiss.
6/20/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
Special PACA counsel regarding setoff of
claim.
6/21/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
Reconciliation.
6/21/2012 T 224.00 SEN 0.80 280.00 Receipt and review of Reconciliation; Review
line items in Reconciliation.
6/21/2012 T 112.00 SEN 0.40 280.00 Telephone conference with client regarding
Reconciliation of set-off.
6/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Objection to First Trust
Chart.
6/22/2012 T 168.00 SEN 0.60 280.00 Extended telephone conference with Special
PACA counsel regarding offset.
9/13/2012 1:26 PM Page: 17
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
6/22/2012 T 112.00 SEN 0.40 280.00 Telephone conference with Special PACA
counsel (2d call) regarding offset.
6/22/2012 T 112.00 SEN 0.40 280.00 Preparation of correspondence to client
regarding offset.
6/22/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Hearing on
Motion for Approval of Trust Chart.
6/22/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Objection to Trust
Chart (2d objection).
6/25/2012 T 224.00 SEN 0.80 280.00 Review proposed Notice to Resolve Claim
Objection; Edit and revise terms of
Stipulation.
6/25/2012 T 112.00 SEN 0.40 280.00 Preparation of correspondence to client
regarding Motion.
6/25/2012 T 112.00 SEN 0.40 280.00 Preparation of correspondence to Special
PACA counsel with proposed changes and
Stipulation.
6/26/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion filed by Special
PACA counsel regarding compromise.
6/26/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
Motion.
6/26/2012 T 112.00 SEN 0.40 280.00 Extended Telephone conference with Special
PACA counsel regarding Motion.
9/13/2012 1:26 PM Page: 18
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
6/27/2012 T 56.00 SEN 0.20 280.00 Telephone conference with client regarding
offset.
6/27/2012 T 56.00 SEN 0.20 280.00 Preparation of correspondence to client
confirming authorization to resolve claim.
6/27/2012 T 224.00 SEN 0.80 280.00 Revise proposed Motion to Resolve
Objection; Preparation of correspondence to
Special PACA counsel with enclosure.
6/27/2012 T 224.00 SEN 0.80 280.00 Receipt and review of second revise proposed
Motion to Resolve Objection; Edit and revise
proposal.
6/27/2012 T 56.00 SEN 0.20 280.00 Preparation of correspondence to Special
PACA counsel with enclosure.
6/27/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Cash Receipts
Summary fro Special PACA counsel.
6/27/2012 T 112.00 SEN 0.40 280.00 Receipt and review of Special PACA
counsel's Motion to Approve Compromises
and Withdraw Objections; Receipt and review
of Creditor's Motion to Withdraw Objections.
6/28/2012 T 56.00 SEN 0.20 280.00 Receipt and review of multiple Orders
regarding Resetting Hearing; Default as to
JRJ Company; Compromise of Claims;
Withdrawal of Objections; Entry of Agreed
Order.
6/29/2012 T 168.00 SEN 0.60 280.00 Receipt and review of correspondence from
Special PACA counsel regarding Proposed
Order to Approval of Compromises of Claim
Objections; Review proposed resolutions and
confirm accuracy of client claims;
Preparation of correspondence to counsel
with consent.
9/13/2012 1:26 PM Page: 19
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
6/29/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Agreed Order
converting case to Chapter 7.
7/9/2012 T 112.00 SEN 0.40 280.00 Receipt and review of Order approving Motion
to Approve Compromises; Receipt and review
of Order regarding setting objections for Trial.
7/9/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Resetting
Hearing on Objections to Claims.
7/13/2012 T 112.00 SEN 0.40 280.00 Receipt and review of Report of Operations for
May, 2012; Review Comparative Balance
Sheets and amendments to liabilities.
7/20/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Motion for continued
use of Cash Collateral by Debtor.
7/26/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Operating Report for
June filed by Debtor.
7/26/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order authorizing
continued use of cash collateral by Debtor.
8/10/2012 T 112.00 SEN 0.40 280.00 Receipt and review of Report of Operations for
July; Review Comparative Balance Sheetsw;
Review Statement of Income.
8/13/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondence from
PACA counsel regarding Assignment of
Claims.
8/14/2012 T 56.00 SEN 0.20 280.00 Telephone conference with Special PACA
counsel regarding Assignment of Claims.
9/13/2012 1:26 PM Page: 20
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
8/14/2012 T 112.00 SEN 0.40 280.00 Review correspondence from counsel; Review
proposed Assignment; Preparation of
correspondence to Special PACA counsel.
8/14/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Application for Interim
Compensation by Special PACA counsel.
8/15/2012 T 56.00 SEN 0.20 280.00 Telephone conference with local counsel
regarding Hearing on claims.
8/21/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Special PACA
counsel's Motion to Modify Claims Procedure
Order.
8/22/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Notice of Special
PACA counsel's First Interim Application for
Compensation.
8/23/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order Setting Deadline
for Attorney Fees Petitions.
8/23/2012 T 56.00 SEN 0.20 280.00 Receipt and review of Order Terminating
Automatic Stay.
8/28/2012 T 168.00 SEN 0.60 280.00 Telephone call from client; Review Stipulation
to Resolve Objections; Preparation of
correspondence to client with adjusted
calculation of debt.
8/29/2012 T 56.00 SEN 0.20 280.00 Receipt and review of correspondnece from
client regarding Notice to File Petition for
Fees.
8/30/2012 T 56.00 SEN 0.20 280.00 Receipt and review of corresponden Compile
exhibits from client regarding distribution
date.
9/13/2012 1:26 PM Page: 21
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Transactions Detail
matter id='3681-3681-e' and component not 'AE'
Date Narrative
Component
Task Code Price Units Value Prof
26,370.00 93.10 Component: T
27,349.13 94.10 Grand Total
9/13/2012 1:26 PM Page: 22
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Exhibit C

12-50073-lmc Doc#303-3 Filed 09/13/12 Entered 09/13/12 13:28:21 Exhibit Statement Pg
1 of 3
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2 of 3
Burns & Black. PLLC
750 Rittiman Road San Antonio, TX 78209-5500
The Meuers Law Firm, P .L.
5395 Park Central Court
Naples, FL 34109
Attention: Mr. Steven E. Nurenberg
In Reference To: Delta Produce, L.P ., et al
File No. 10028.01
Professional Services
(21 0) 829-2022
INVOICE NO. 13344
April17, 2012
1/10/2012 Discussions with Steve Nurenberg regardi ng PACA claims, bankruptcy proceedings, local
counsel matters. Review and approval of notice of appearance as local counsel.
1/11/2012 Research bankruptcy matters and court standing orders/procedures on PACER. Filing of
notices of appearance/requests for notice in Delta Produce, LP bankruptcy proceedings.
Correspondence to Steve Nurenberg regarding same.
1/12/2012 Additional research on PACER regarding the Delta Produce, LP bankruptcy proceedings.
Correspondence to Steve Nurenberg regarding case documents.
1/13/2012 Correspondence to Steve Nurenberg regarding case activities/filings in the Delta Produce,
LP bankruptcy proceedings.
1/17/2012 Additional correspondence to Steve Nurenberg regarding case activities/filings in the Delta
Produce, LP proceeding.
2/2/2012 Lengthy discussions with bankruptcy court deputy clerk regarding proofs of claim, filing of
motions/proposed orders. Correspondence to Steve Nurenberg regarding case
activities/filings in the jointly administered Delta Produce, LP bankruptcy proceeding.
For professional services rendered
Amount
$866.25
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The Meuers Law Firm, P.l.
File No. 10028.01
Invoice Date: 4/17/2012
Additional Charges :
Delivery Service
Postage
Total costs
Total amount of this bill
Balance due
Page 2
Amount
90.34
22.54
$112.88
$979.13
$979.13
THANK YOU!