12-50073-lmc Doc#308 Filed 09/13/12 Entered 09/13/12 23:44:53 Main Document Pg 1 of 3

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

IN RE:

X X DELTA PRODUCE, L.P. X X DEBTOR X ____________________________________ X

CASE NO. 12-50073-LMC CHAPTER 11

MOTION FOR ATTORNEYS FEES BY LONDON FRUIT, INC. & TRIPLEH London Fruit, Inc. (London Fruit), and Triple H Produce, LLC. (Triple H) submit their Motion for Attorneys Fees, and in support thereof state: 1. 2. This Motion seeks an award of attorneys fees in the amount of $8,840.00. London Fruit has a qualified PACA trust claim against Delta Produce LP in the

amount of $30,724.92, and its invoices provide that Buyer agrees to pay all collection costs, including collection agency fees, reasonable attorneys fees, and court costs if this account is placed for collection. 3. Triple H has a qualified PACA trust claim against Delta Produce LP in the amount of

$5,278.00, and its invoices provide that . . . buyer agrees to pay all costs of collection, including attorneys fees, in the event collection action becomes necessary to recover any portion of this invoice amount or related costs, regardless of whether or not a lawsuit has been filed. 4. categories: a. b. c. For time spent solely for the benefit of London Fruit = $390.00 For time spent solely for the benefit of Triple H = $390.00 For time spent for the benefit of both = $8,060.00.
Page 1

The legal fees incurred by London Fruit and Triple H fall into the following

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5.

Legal fees of $16,120.00 were incurred for the time spent in both this case and the

jointly administered case of In re Superior Tomato-Avocado, Ltd. (Superior), since the Undersigned represents PACA trust beneficiaries in both cases who are entitled to recover attorneys fees. The two cases have common issues, and would be difficult to distinguish time spent in one case from the other. For example, a revision to the claims procedure order in one case would result in the same revision being made to the claims procedure order in the other case. Under the circumstances, it would be appropriate to divide the $16,120.00 into $8,060.00 in the Delta case, and $8,060.00 in the Superior case. 6. The Undersigned represents other PACA trust beneficiaries in this case who are not

named in this Motion since they did not have prevailing party attorneys fee language on their invoices, such as The Pumpkin Patch, which is owed $161,150.00, and Juniper Tomato Growers, which is owed $155,189.75. The Undersigned also represents PACA trust beneficiaries in the Superior case, including the largest PACA creditor the Willson Davis Co., which is owed $481,058.00. Due to the Undersigneds representation of large PACA trust beneficiary groups in both cases, the Undersigned has been heavily involved with matters that benefit the PACA trust beneficiary group in general, which it is submitted should be taken into consideration when evaluating the reasonableness of the legal fees of $16,120.00. 7. The attached Declaration of Undersigned provides evidentiary support for the request

for attorneys fees. WHEREFORE, it is requested that this Motion be GRANTED. RESPECTFULLY SUBMITTED,

By:

s/Robert E. Goldman ROBERT E. GOLDMAN, ESQ.

Page 2

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Law Office of Robert E. Goldman Admitted Pro Hac Vice 1 East Broward Blvd., Ste. 700 Fort Lauderdale, FL 33301 Tel: (954) 745-7450 Fax: (954) 745-7460

CERTIFICATE OF SERVICE I hereby certify that on September 13, 2012, I electronically filed the foregoing Motion for Attorneys Fees 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:

Robert E. Goldman Robert E. Goldman

Page 3

12-50073-lmc Doc#308-1 Filed 09/13/12 Entered 09/13/12 23:44:53 Affidavit of Robert E. Goldman Pg 1 of 13

DECLARATION OF ROBERT E. GOLDMAN I, Robert E. Goldman, declare as follows: 1. I am 50 years old. I make this Declaration based upon my own personal

knowledge. If called upon to testify as a witness, I could and would testify as follows. 2. I have been practicing law for over 24 years, and for the past 20 years have

specialized in agricultural law. I am licensed to practice law in Florida, California, Arizona, and Washington DC. For about the past 10 years I have been a panel arbitrator for the Fruit and Vegetable Dispute Resolution Corporation, and have served as an arbitrator on at least one case a year. 3. My regular hourly rate for representing agricultural companies is $325.00 per

hour, and that is the rate I charged in this case. 4. Attached to my Declaration are invoices for time spent in the In re Delta Produce,

LP. and In re Superior Tomato-Avocado, Ltd. cases. The time was recorded contemporaneously with the work being done, and accurately reflects the work done and time spent.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. September 14, 2012 By: s/Robert E. Goldman Robert E. Goldman

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Law Office of Robert E. Goldman

One East Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 robert@goldmanlaw.com 954-745-7450 954-745-7460

September 13, 2012 Superior Tomato / Delta Produce Invoice #: Our File # 12735 148.0

Re: Superior Tomato / Delta Produce

PROFESSIONAL SERVICES: Hours 1/3/12 Multiple T/C w/ Atty. Stokes re Both Companies Will File Bankruptcy Today, and Implications (.7 hrs); T/C w/ Local Counsel re Status (.2 hrs);T/C w/ Client re Status (.1 hrs); Receipt of Bankruptcy Filings (.2 hrs); Email to Clients re Same (.2 hrs); Several Emails to and from Atty. Jason re Status (.2 hrs) T/C w/ Stokes re What is Status of Inventory During the Last Week, and Status of Bankruptcy (.2 hrs); T/C w/ Atty. Stokes re Same (.1 hrs); T/C w/ Client re Same (.1 hrs); Email from Atty. Stokes re Attached Accounts Receivables for Both Companies (.2 hrs); T/C w/ Chris at Willson re Same(.2 hrs); T/C w/ Gary at Averitt re Same (.2 hrs); Receipt of Notice of Stay in District Court (.1 hrs); T/C w/ Atty. Stokes re Status of Upcoming Hearing in District Court, and Receipt of Draft of Motion to Ask District Court to Abstain, and T/C to Atty. Stokes re Comments to Same (.3 hrs); T/C w/ Bankruptcy Atty. Averly and Atty. Stokes re Goals in Bankruptcy Case, and Proposed Cash Collateral Order (.5 hrs); Revise Preliminary Injunction so that It can 1.60 Amount 520.00

1/4/12

2.80

910.00

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Hours become a Cash Collateral Motion, and Email to Atty. Averly re Same (.7 hrs); Email to Atty. Klinowski re Status (.2 hrs) 1/5/12 Multiple T/C w/ Atty. Stokes and Local Counsel re Upcoming Hearing re Motion for Abstention in District Court, Including Our Position that we can resume District Ct. case against Non-Bankruptcy Individual Defendant at our discretion,and Receipt of Filed Motion, and Email from Atty. Ackerly re Same Review Local Rules of Bankruptcy Court (a requirement to appear Pro Hac Vice), and Draft Motion to Appear Pro Hac Vice in Both Cases, and Draft Proposed Orders Granting Same T/C w/ Local Counsel re Results of Hearing in District Court re Abstention Email from Atty. Ayres re Need for Budget Email to Atty. Klinowski re Status 1/6/12 T/C w/ Atty. Ayres re We Should Not File a Motion re Cash Collateral Since the PACA Creditors are Different from the Bank, and instead we should file a "Motion to Use PACA Trust Funds to Pay Employees to Recover PACA Trust Assets" T/C w/ Atty. Ayres and Stokes re Forthcoming PACA Motion, and I Request Access to Speak to Employees (.3 hrs); Email to Atty. Stokes re List of Questions to Ask Employees (.1 hrs) Email from Atty. Ayres re a PACA Claims Procedure Order Previously Used in a Bankruptcy Case in El Paso, TX; Draft PACA Claims Procedure Order, and PACA Proof of Claim Form (Modify Template to Use in Bankruptcy Court), and Email to Atty. Stokes and Ayres re Attached Order 0.70

Amount

227.50

1.90

617.50

0.10

32.50

0.10 0.10 0.40

32.50 32.50 130.00

0.40

130.00

1.60

520.00

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Hours 1/9/12 Conference Call w/ Atty. Ayres, Stokes, and Others re Status and Proposed Abstention Order Email from Atty. Stokes re His Proposed Revisions to Claims Procedure Order, and Email from Atty. Ayres re His Bankruptcy Revisions to Claim Procedure Order, and Major Revision to Same, and Email to Atty. Stokes and Ayres Email from Atty. Ayres re His Attached Draft of Motion to Allow Use of PACA Trust Funds for Employees to Collect Receivables, and Substantial Revision to Same, and Email to Atty. Ayres re Same 1/10/12 T/C w/ Atty. Ayres and Stokes re Abstention Order Email from Atty. Stokes re His Revisions to PACA Claims Procedure Order; Revise Same to Add Paragraph re Appointment of Special PACA Counsel and Terms for Retention, and Email to Atty. Stokes re Same (.5 hrs); T/C w/ Atty. Stokes re Same (.2 hrs) 1/11/12 Email from Atty. Stokes re His Revisions to Claims Procedure Order; T/C w/ Atty. Ayres and Stokes re Same, and Substantial Further Revision, and Email to Atty. Stokes Email from Atty. Ayres re His Revisions to Proposed Motion to Allow Opening of DIP Accounts, to Allow Use of PACA Trust Funds, to Hire Employees, Etc., and Related Order, and Major Revisions to Both,and Emails to Atty's Ayres and Stokes re Same 1/12/12 Revise PACA Claims Procedure Order and Motion, and Email to Atty. Ayres and Stokes T/C w/ Atty. Stokes re Revised Order and Motion, and Further Revise Same, and Email to Atty. Ayres and Stokes re Same 0.50

Amount 162.50

1.20

390.00

0.80

260.00

0.30 0.70

97.50 227.50

0.70

227.50

2.40

780.00

0.80

260.00

0.30

97.50

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Hours 1/12/12 Email from Atty. Ayres re His Attached, Minor Revisions to Motion for Use of PACA Trust Funds Revise Motion to Permit Use of PACA Funds, and Email to Multiple Atty's Who Represent Produce Creditors re Same 1/13/12 Review Motion for Use of Cash Collateral (Why Employees for 3 Months?); T/C w/ Atty. Stokes re Same; Email to Atty. Ayres re Same Email from Atty. Ayres re Employee's Compensation Email from Atty. Ackerly re His Comments to Proposed Order; Email from Atty. Diaz re Same; Email to Atty. Stokes re Same Email to Atty. Ayres re Reminder of His Need to Complete Claims Procedure Order Email from Atty. Kelly re Status of Claims Procedure Order, and Email to Atty. Kelly re Same Email from Atty. Stokes re "Is Motion to Use PACA Trust Funds" Ready to File; T/C w/ Atty. Stokes "Yes" Email from Atty. Ayres re His Major Revisions to Claims Procedure Order, and T/C w/ Atty. Stokes re Review of Same Email from Atty. Batta re Payments to Employee in February; Email to Atty. Batta re Same Email to Atty. Ayres re Questions About Cash Collateral Motion (It Impacts the Unsecured, and Produce Supplier's May be Unsecued Due to Lack of Trust Funds) Email from Atty. Ayres re His Major Revisions to PACA Claims Procedure Orders for Delta and Superior; Email from Atty. Stokes re His Proposed Revision to Minimize Potential for Each Produce Supplier to Make Duplicate Objections; Major Revision to Same Which Addresses 0.20

Amount 65.00

0.50 0.30

162.50 97.50

0.10 0.10

32.50 32.50

0.10

32.50

0.10 0.20 0.40

32.50 65.00 130.00

0.10 0.20

32.50 65.00

1.90

617.50

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Hours Multiple Issues (e.g., Address Stokes Concern; PACA Claim Form v. Form 10; Service Issues); Email to Ayres and Stokes re Same,and Proposed Conference Call on Sunday to Review Same 1/13/12 Organize Folders and Files on Computer re Two Debtors and Categories T/C w/ Atty. Ayres and Stokes re My Latest Revisions to Proposed PACA Claims Procedure Order, and Make Changes During the Call (.5 hrs); Further Revise, Including Service Requirements, and Email to Atty. Stokes (.4 hrs); Email from Atty. Stokes re His Revisions to PACA Proof of Claim Form (Ex. "A"), and Revise Same, and Email Same to Atty. Stokes (.3 hrs); Draft PACA Distribution Chart (Ex. "B") (.2 hrs); Email to All Known Atty's for PACA Claimants re Attached Order (.5 hrs) Email from Atty. Ackerly re His Client's Opposition to Cash Collateral Motion re Funding Monthly Budget of Approx. $70,000; Further Review Cash Collateral Motion; Email to Atty. Ayres re Request that He Provide the Missing, Proposed Cash Collateral Order 1/17/12 Email from Atty. Ayres re Craig Will Call Me After His Meeting w/ Melinda Harper (.1 hrs); T/C w/ Willson Davis re Their Receipt of Motion to Pay Stokes to Collect PACA Assets ("We object to paying") (.3 hrs); Email to Atty. Ayres re Want to Resolve OUr Budget Objections Before Today's Hearing, Including Don't Want to Pay for Richard Medina Since He Took a New Job (.1 hrs) Email to Atty. Ayres re Request for Accounting re Inventory Sold in Final Days of Operations Email from Atty. Stokes re Accounting of Cash, and T/C w/ Atty. Stokes re Need Isolation on Inventory on the Last Week 1.70

Amount

552.50

1/15/12

1.90

617.50

0.30

97.50

0.50

162.50

0.10 0.20

32.50 65.00

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Hours 1/17/12 Email from Atty. Botta re His Proposed Revisions to PACA Claims Procedure Order Email from Atty. Kelly re His Numerous Proposed Revisions to PACA Claims Procedure Order T/C w/ Atty. Ayres and Stokes re Hearing Results, and 30 Day Budget for Delta of $12,500 and Superior of $3,000, and Still Need to Identify Employees Who Will Work, and Potential 3 Month Lease of Delta Cooler, and Status re Superior Cooler, and Responding to Atty. Kelly's Proposed Revisions to PACA Claims Procedure Order Email to Atty. Kelly re Response to His 8 Suggestions 1/18/12 Email to Atty. Ayres re Need Website Link to Insert into PACA Claims Procedure Order; Email from a Service Provider re Link, and Review Link, and Email to Service Provider re Need to Also Have one for Superior, and Email re Amended Link (.3 hrs); Further Revise Proposed PACA Order to Include Link, and Comments Made by Two Other Attorney's, and Email to Atty. Ayres re Same and When Will He Complete the Motion (.6 hrs) Receipt of IBC's Response to Motion re Use of PACA Funds, and Email to Atty. Ayres re Same, and Email from Atty. Ayres re Same T/C w/ Atty. Stokes re Hearing Tomorrow on Multiple Motions; T/C w/ Local Counsel re Attending Same 1/24/12 T/C w/ Atty. Stokes re Hearing Results (.2 hrs); T/C w/ Chris Peters re Status (.2 hrs) Review Numerous Emails to and from US Trusteee re Attached Revisions to PACA Claims Procedure Order (.4 hrs); Receipt of Signed Order; Email to Atty. Ayres re Still Need a Signed Claims Order in the Superior Bankruptcy 0.10

Amount 32.50

0.10 0.40

32.50 130.00

0.30 0.90

97.50 292.50

1/23/12

0.20

65.00

0.30 0.40

97.50 130.00

1/25/12

0.50

162.50

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Hours 1/26/12 Conference w/ Atty. Stokes re Which PACA Trust Assets to Proceed Against First (Real Estate or Trucks, Etc.) Email from Clerk re CM/ECF Access Information; Review Docket in Superior Case; Draft Notice of Appearance re Superior T/C w/ Atty. Stokes re Status of Collections, and Evidence to Support Disgorgement from Bank Email from Atty. Stokes re First Draft of Proposed Adversary Complaint against IBC; Revise Same, and Email to Atty. Stokes Ltr. from Atty. Ayres to Blue Book re His Continued Demand that BB Handle the Litigation, Since are "two simple claims"; Ltr. to BB re Why It Should Reject the Arbitration T/C w/ Atty. Stokes re Status of Adversary Complaint Email from Atty. Stokes re Bank's Proposed Cash Collateral Order; T/C w/ Atty. Stokes re Same Email from Atty. Stokes re Attached Adversary Complaint against IBC for Disgorgement of PACA Trust Assets, and Revise Same, and Email from Atty. Stokes re Attached Case re Whether a Trustee Has Standing to Sue a Third Party, T/C w/ Atty. Stokes re Same T/C w/ Atty. Stokes re Tomorrow's Status Conference w/ Court Review Objections to Claims of Multiple Clients by Two Law Firms, and T/C's w/ Clients to Request Documents to Overcome Objections Revise Adversary Complaint, and Email to Atty. Stokes 0.40

Amount 130.00

1/27/12

0.40

130.00

2/24/12 2/27/12

0.60 0.50

195.00 162.50

3/3/12

1.80

585.00

3/5/12 3/8/12

0.20 0.20

65.00 65.00

3/30/12

1.40

455.00

4/10/12 4/11/12

0.20 1.20

65.00 390.00

4/15/12

1.10

357.50

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Hours 5/1/12 Revise Adversary Complaint Against IBC, and Email to Atty. Stokes Revise Adversary Complaint Against IBC, and Email to Atty. Stokes, and T/C w/ Atty. Stokes re Same, and Email to Atty. Stokes Prima Facie Elements for "Declaratory Judgment" Claim Review Trustee's Motion to Covert Chapter 11 Case to Chapter 7 re Impact on PACA Claims Procedure 5/3/12 Further Revise Adversary Complaint Against IBC, and Email to Atty. Stokes Review Complaint by Superior Against De La Garza Wholesale Distribution for $216,299.52, and Email to Client re Same Receipt of Multiple Notice of Hearing re Trustee's Objections to Claims Conference Call w/ Atty. Stokes and Other Attys re Status and Strategy of IBC Complaint, and Assignments of Rights to Atty. Stokes to Pursue Claim Review Numerous Court Filings in Past Three Weeks re Upcoming Hearing on Multiple Motions, including Motion to Conver to Ch. 7, and Bank IBC's Motion to Use Cash Collateral, and Budgets Review Original PACA Trust Charts in Superior and Delta Cases, and Draft Objections to Same Draft Assignment of PACA Trust Claim Against IBC,and Email to Atty. Stokes T/C w/ Atty. Stokes re Results of Today's Hearing, and Email from Local Counsel re Same 1.40

Amount 455.00

5/2/12

1.40

455.00

0.20 0.70

65.00 227.50

5/11/12

0.30

97.50

5/12/12 6/18/12

0.20 0.50

65.00 162.50

6/21/12

1.40

455.00

6/22/12

0.90

292.50

6/23/12 6/28/12

1.20 0.30

390.00 97.50

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Hours 7/4/12 Draft Opposition to Debtor's Motion for Attorney Fees and Costs of $132,000 Email from Atty. Stokes re Counteroffer made to La Garza T/C w/ Atty. Stokes re Assignment of PACA Claims Against IBC; Review Docket re Status of Case; Revise Assignment Forms for Superior and Delta; Email to Multiple PACA Atty's re Request to Review and Comment to Forms Email from Atty. Stokes re Attached, Proposed Motion to Modify PACA Order re File for Atty's Fees Now, and Revise Same, and Email to Atty. Stokes Review Settlement Proposal re Superior's Claim Against Theinpoint for $164,000, and Review Theinpoint's Completed Financial Statements and Related Docs (.3 hrs); T/C w/ Atty. Stokes re Want Mtg. on Home w/ $302 Equity, and Faster Payback (.2 hrs); T/C w/ Theinpoint's Atty. Gindy re Same Claim, and Email to Atty. Gindy re Same (.4 hrs) T/C w/ Atty. Gindy re Theinpoint's Counter-Offer (Now payoff in about 14 months, $2k per month, mortgages on both Homestead and Unimproved Lot, etc.) Review Objection to Special PACA Counsel's Request for Fees by Rio Grande Produce For Professional Services Rendered: COSTS: 12/28/11 Filing Fee in US District Court Total Costs: 0.50

Amount 162.50

7/24/12 8/13/12

0.10 1.10

32.50 357.50

8/20/12

0.30

97.50

8/24/12

0.90

292.50

9/5/12

0.50

162.50

9/9/12

0.20

65.00

49.60 $16,120.00

350.00 $350.00

Total amount of this bill:

$16,470.00

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Amount BALANCE DUE: $16,470.00

PAYMENT DUE 10 DAYS AFTER INVOICE DATE

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Law Office of Robert E. Goldman

One East Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 robert@goldmanlaw.com 954-745-7450 954-745-7460

September 13, 2012 London Fruit, Inc. 9010 S. Cage Blvd. Pharr, TX 78557 Invoice #: Our File # 12733 148.7

Re: London Fruit, Inc. v. Delta Produce

PROFESSIONAL SERVICES: Hours 3/2/12 Review Client's Sale Documents; Draft PACA Proof of Claim; T/C w/ Client re Same and Interest Calculation, and Email from Client re Same, and File Same w/ Court Receipt of Bills of Lading, and Draft Response to Objection to Claim For Professional Services Rendered: BALANCE DUE: 0.70 Amount 227.50

4/16/12

0.50

162.50

1.20

$390.00 $390.00

PAYMENT DUE 10 DAYS AFTER INVOICE DATE

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Law Office of Robert E. Goldman

One East Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 robert@goldmanlaw.com 954-745-7450 954-745-7460

September 13, 2012 TripleH Produce, LLC. PO Box 3123 McAllen, TX 78502 Invoice #: Our File # 12732 148.10

Re: Triple H Prouduce, LLC v. Delta Produce

PROFESSIONAL SERVICES: Hours 1/13/12 Email from Hector re Documents He Received from Court, and Email to Hector re Same Email from Triple H re Their Attached Claim Documents; Email to Fabiola re Also Need a Statement 3/2/12 Draft Proof of Claim, and Email to Hector, and File Same For Professional Services Rendered: 0.10 0.40 0.70 1.20 Amount 32.50 130.00 227.50 $390.00

BALANCE DUE:

$390.00

PAYMENT DUE 10 DAYS AFTER INVOICE DATE