IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

In re:
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
Debtors.
Chapter 11
) Case No. 12-11564 (CSS)
(Jointly Administered)
Objection Deadline: Nov. 14, 2012 at 4:00p.m.
) Hearing Date: Only if an objection is filed
SUMMARY OF THIRD MONTHLY APPLICATION OF
SULLIVAN HAZELTINE ALLINSON LLC FOR COMPENSATION
FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES
AS CO-COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS
FOR THE PERIOD FROM SEPTEMBER 1, 2012 THROUGH SEPTEMBER 30, 3012
Name of Applicant: Sullivan Hazeltine Allinson LLC ("SHA-LLC")
Authorized to Provide
Professional Services to: Official Committee of Unsecured Creditors (the "Committee")
Date ofRetention: June 19,2012 (nunc pro tunc)
Period for which compensation and
reimbursement is sought: Sept. 1, 2012 through Sept. 30,2012 (the "Compensation Period")
Amount of Compensation sought
as actual, reasonable and necessary: _________________ _
Amount of Expense Reimbursement sought
as actual, reasonable and necessary:

__________________ _
This is an: ___x_ interim _ final application.
The total time expended for preparation of this fee application is approximately 2.1 0 hours and
the corresponding compensation of approximately $477.00 will be requested in a subsequent fee
application.
1
The debtors in the above-captioned cases (collectively, the "Debtors"), along with the federal tax identification number (or
Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied
Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0 169283); Allied Systems, Ltd. (L.P.) (58-171 0028); Axis Areta, LLC (45-5215545); Axis Canada Company 87568828); Axis
Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-2918187); Cordin Transport LLC (38-
1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751);
Logistic Technology, LLC (45-4242057); QAT, Inc. (59-2876863); RMX LLC (31-0961359); Transport Support LLC (38-
2349563); and Terminal Services LLC (91-0847582). The location of the Debtors' corporate headquarters and the Debtors'
address for service of process is 2302 Park lake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.
2
This amount includes unreimbursed expenses from July 2012 that were inadvertently omitted.
This is SHA-LLC's fifth fee application and fourth monthly fee application in this case.
Prior Applications
Date Filed Period Covered Requested Fees and Date Approved
Expenses Approved
Aug. 15,2012 June 19,2012- $6,019.00 (fees) Sept. 6, 20 12 $4,815.20
June 30,2012 $246.67 (exp) (CNO) $246.67 ( exp)
Aug. 31,2012 July 1, 2012- $23,621.25 (fees) Sept. 24,2012 $18,897.00
July31,2012
$2,385.04 (exp)
(CNO)
$2,385.04 (exp)
Oct. 2, 2012 Aug. 1, 2012- $7,238.00 (fees) Oct. 24, 2012 $5,790.40 (fees)
Aug. 31. 2012
$372.14 (exp)
(CNO)
$372.14 (exp)
Oct. 10, 2012 June 19,2012- $36,878.25 (fees)
Pending 20% Holdback
Aug. 31, 2012
$3,003.85 (exp)
The SHA-LLC professionals who rendered professional services in these cases during the
Compensation Period are:
Name of Position Number Hourly Total Total
Professional Person with the of years Department billing billed Compensation
applicant as an
attorney
William D. Sullivan Member 21
William A. Hazeltine Member 17
Seth S. Brostoff Associate 2
Heidi M. Coleman Paralegal -
TOTAL
rate hours
Bankruptcy $425.00 13.30 $5,652.50
Bankruptcy $360.00 10.70 $3,852.00
Bankruptcy $250.00 4.30 $1,075.00
Bankruptcy $150.00 5.40 $810.00
33.70 $11,389.50
GRAND TOTAL: $11,389.50 Fees
33.70 Hours
BLENDED RATE: $ 337.96 Per Hour
COMPENSATION BY PROJECT CATEGORY
Pro.iect Category Total Hours Billed Total Compensation
Business and Finance 0.60 $90.00
Case Administration 0.20 $85.00
Contested Matters 15.30 $5,191.00
Fee Applications 10.10 $3,141.50
Financing and Cash Collateral 3.40 $1,354.00
Hearings 3.30 $1,220.50
Review of Pleadings and Documents 0.80 $307.50
TOTAL 33.70 $11,389.50
2
This interim fee application also seeks the reimbursement of the following expenses advanced on
behalf of the Debtors in this matter.
Description
Case Administration
Courier Service
Federal Express
Dated: October 25, 2012
Wilmington, Delaware
Amount
$100.00
$293.34
TOTAL $393.34
SULLIVAN HAZEL TINE ALLINSON LLC
Is/ William A. Hazeltine
William A. Hazeltine (No. 3294)
901 North Market Street, Suite 1300
Wilmington, DE 19801
Tel: (302) 428-8191
Fax: (302) 428-8195
Email: whazeltine@sha-llc.com
Attorneys for the Official Committee of Unsecured
Creditors
3
In re:
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
j Chapter 11
) Case No. 12-11564 (CSS)
j (Jointly Administered)
Debtors.
j Objection Deadline: Nov. 14, 2012 at 4:00p.m.
) Hearing Date: Only if an objection is filed
FOURTH MONTHLY APPLICATION OF SULLIVAN HAZELTINE
ALLINSON LLC FOR COMPENSATION FOR SERVICES
RENDERED AND REIMBURSEMENTOF EXPENSES AS CO-COUNSEL
TO THE OFFICICAL COMMITTEE OF UNSECURED CREDITORS
FOR THE PERIOD FROM SEPTEMBER 1, 2012 THROUGH SEPTEMBER 30, 2012
Sullivan Hazeltine Allinson LLC ("SHA-LLC" or "Applicant"), counsel to the Official
Committee of Unsecured Creditors of Allied Systems Holdings, Inc., et al.(the "Committee"),
hereby submits its application, pursuant to 11 U.S.C. 330, 331 and 503(b)(4), Rule 2016 of
the Federal Rules of Bankruptcy Procedure and Del. Bankr. L.R. 2016-2, for interim allowance
of compensation for services rendered and for reimbursement of expenses incurred solely for the
Committee, and in further explanation respectfully represents:
I. INTRODUCTION
1. By this application, SHA-LLC seeks (i) interim allowance and award of
compensation for professional services rendered by SHA-LLC as counsel for the Committee for
1
The debtors in the above-captioned cases (collectively, the "Debtors"), along with the federal tax identification
number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc.
(58-0360550); Allied Automotive Group, Inc. (58-220 1081 ); Allied Freight Broker LLC (59-2876864); Allied
Systems (Canada) Company (90-0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-
5215545); Axis Canada Company 87568828); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-
0436930); CT Services, Inc. (38-2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-
0365100); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-
4242057); QAT, Inc. (59-2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563 ); and Terminal
Services LLC (91-0847582). The location of the Debtors' corporate headqumiers and the Debtors' address for
service of process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.
the period from September 1, 2012 through and including September 30,2012 (the
"Compensation Period") in the amount of$11,389.50, representing 33.70 hours in professional
services rendered on behalf of the Committee; and (ii) reimbursement of actual and necessary
expenses incurred by SHA-LLC during the Compensation Period in connection with the
rendition of such professional services in the amount of $393.34 (the "Application").
2. This Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334. This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). Venue ofthis proceeding
and this application is proper in this district pursuant to 28 U.S.C. 1408 and 1409. The
statutory predicates for the relief sought herein are 11 U.S.C. 330, 331, 503(b)(4), Federal
Rule ofBankruptcy Procedure 2016 and Del. Bankr. L.R. 2016-2.
II. BACKGROUND
3. On May 17, 2012, certain ofthe Debtors' prepetition lenders filed involuntary
bankruptcy petitions against Allied Systems Holdings, Inc. ("Allied") and its subsidiary, Allied
Systems, Ltd. (L.P.) Systems under chapter 11 of title 11 ofthe United States Code in this
Bankruptcy Court. On June 10, 2012, the remaining Debtors filed voluntary petitions in this
Court, and, in connection therewith, Allied and Systems consented to the involuntary petitions
filed against them. The Debtors have continued in possession of their property and have
continued to operate and manage their businesses as debtors in possession pursuant to sections
1107(a) and 1108 of the Bankruptcy Code. On June 11, the Court entered an order jointly
administering the Chapter 11 Cases pursuant to Rule 1015(b) ofthe Federal Rules of Bankruptcy
Procedure (the "Bankruptcy Rules") for procedural purposes only.
4. On June 19, 2012, the United States Trustee (the "Trustee") appointed the
following creditors to the Committee pursuant to Bankruptcy Code Section 11 02: (a) Pension
2
Benefit Guaranty Corporation; (b) Central States, Southeast and Southwest Areas Pension Fund;
(c) Teamsters National Automobile Transporters Industry Negotiating Committee; and (d)
General Motors, LLC.
5. On June 19, 2012, the Committee selected SHA-LLC as its co-counsel with
Sidley Austin LLP ("Sidley"), subject to the approval of the Court. This Court approved the
retention of SHA-LLC as counsel to the Committee nunc pro tunc to June 19, 2012 (the
"Retention Date") by order dated August 7, 2012 (Docket No. 328).
6. Applicant has received no payments or promises of payment from any source
other than as provided in the Bankruptcy Code for services rendered or to be rendered in any
capacity whatsoever in these cases. There is no agreement or understanding between SHA-LLC
and any other person for the sharing of compensation in connection with this case other than in
accordance with the provisions of the Bankruptcy Code.
7. The services for which compensation is being sought by SHA-LLC were rendered
for and on behalf of the Committee and not for or on the behalf of any other interested party in
this bankruptcy proceeding.
III. TIME RECORDS AND HOURLY RATES
8. William D. Sullivan, William A. Hazeltine, Seth S. Brostoff and Heidi M.
Coleman of SHA-LLC provided services for the Committee during the Compensation Period.
Mr. Sullivan was admitted to the Bar of the Supreme Court of Delaware in 1989. Mr. Sullivan
became an associate with the Wilmington, Delaware law firm of Elzufon, Austin, Reardon,
Tarlov & Mondell, P.C. in 1989 and established the firm's bankruptcy practice in 1995. He
became a partner in 1998. In 2004, Mr. Sullivan joined Buchanan Ingersoll, P.C. as a partner in
the bankruptcy practice group of its Wilmington, Delaware office. In July of2006, Mr. Sullivan
3
founded William D. Sullivan, LLC. On January 1, 2008, Mr. Sullivan became a member of
SHA-LLC. Applicant charged $425.00 per hour for services rendered by Mr. Sullivan during the
period covered by this Application.
9. Mr. Hazeltine was admitted to the Bar ofthe Supreme Court of Delaware in 1994.
Mr. Hazeltine became an associate with the Wilmington, Delaware law firm of Potter Anderson
& Corroon LLP on August 15, 1994 and became a partner at Potter Anderson & Corroon LLP
effective January 1, 2003. Mr. Hazeltine left Potter Anderson & Corroon LLP in 2004 and
began his own practice in 2005. On January 1, 2008, Mr. Hazeltine became a member of SHA-
LLC. Applicant charged $360.00 per hour for services rendered by Mr. Hazeltine during the
Compensation Period.
10. Mr. Brostoffwas admitted to the Bar ofthe Supreme Court ofDelaware in
December of2009. In 2009, Mr. Brostoffjoined Morris, Nichols, Arsht & Tunnell LLP as an
associate in the Business Reorganization and Restructuring Department. On September 1, 2011,
Mr. Brostoffbecame an associate ofSHA-LLC. Applicant charged $250.00 per hour for
services rendered by Mr. Brostoff during the period covered by this Application.
11. Ms. Coleman is a paralegal with SHA-LLC and has 13 years of experience as a
paralegal. Applicant charged $150.00 per hour for services rendered by Ms. Coleman during the
period covered by this Application.
12. The total time spent by SHA-LLC representing the Committee during the
Compensation Period was 33.70 hours and the compensation sought for the Compensation
Period is $11,389.50. This equates to a blended rate of$337.96 per hour.
13. Attached hereto as Exhibit A and incorporated herein by reference are SHA-
LLC's time records showing a daily log of all time spent by SHA-LLC providing services for the
4
Committee during the Compensation Period by Project Category. The attached time records
provide a detailed, day-by-day explanation of the services rendered by SHA-LLC in connection
with this matter during that time. Applicant certifies that Applicant has reviewed Del. Bankr.
L.R. 2016-2 and believes that the Application complies therewith.
14. Also included in Exhibit A, and incorporated herein by reference, is a summary of
the expenses incurred by SHA-LLC during the Compensation Period on behalf of the
Committee. Expenses that SHA-LLC bills to its clients include charges for photocopying,
postage, courier services, Federal Express, court costs and transcript fees. The total expense for
which reimbursement is sought in the Application is $393.34.
2
In a future fee application, SHA-
LLC may seek reimbursement of additional expenses advanced or incurred on behalf of the
Committee during this Compensation Period that do not appear on Exhibit A.
III. SUMMARY OF SERVICES BY PROJECT
15. The services rendered by SHA-LLC during the Compensation Period can be
grouped into the categories set forth below. These categories are generally described below,
with a more detailed identification of the actual services provided set forth on the attached
Exhibit A. The attorneys and paraprofessionals who rendered services relating to each category,
along with the number of hours for each individual and the total compensation sought for each
category, are identified in Exhibit A attached hereto.
IV. GENERAL DESCRIPTION OF SERVICES RENDERED
16. The services rendered by SHA-LLC that are the subject of this Application
include the following:
(a) Business and Finance.
2
This amount includes unreimbursed expenses from July 2012 that were inadvertently omitted.
5
Fees: $90.00 Total Hours: 0.60
This category includes all matters related to reviewing the Debtors' Statement of
Financial Affairs.
(b) Case Administration.
Fees: $85.00 Total Hours: 0.20
This category includes all matters related to communicating with counsel for a creditor
regarding case issues and timelines.
(c) Contested Matters.
Fees: $5,191.00 Total Hours: 15.30
This category includes all matters related to (i) reviewing several relief from stay
motions; (2) review of KERP motion, researching, and reviewing an objection to the KERP
motion and; (3) corresponding with co-counsel and parties in interest regarding KERP issues.
(d) Fee Applications.
Fees: $3,141.50 Total Hours: 10.10
This category includes all matters related to (i) preparing certificates of no objection for
SHA-LLC's first and second fee applications; (ii) reviewing and filing the Committee
professionals' fee application and discussing the fee cap issue; and (iii) reviewing fee
applications of the Debtors' retained professionals.
(e) Financing and Cash Collateral.
Fees: $709.50 Total Hours: 1.70
This category includes all matters related to the DIP credit facility and an extension of the
challenge period.
6
(f) Hearings.
Fees: $1,220.50 Total Hours: 3.30
This category includes all matters related to reviewing agenda items and preparing for
and attending a hearing regarding the KERP motions and relief from stay motions.
(g) Review of Pleadings and Documents.
Fees: $307.50 Total Hours: 0.80
This category includes all matters related to reviewing pleadings related to the case.
V. CONCLUSION
17. The compensation sought by Applicant is based on the normal hourly rates
charged by Applicant for work of this character. The services rendered by Applicant to the
Committee were necessary and appropriate. The amount of compensation sought by SHA-LLC
is consistent with the factors enumerated in 11 U.S.C. 330, in that the amount sought is
reasonable compensation for actual, necessary services rendered by the Applicant taking into
account all relevant factors, including time spent on such services; the rates charged for such
services; the complexity, importance, and nature of the problem, issue or task addressed; and the
customary compensation charged by comparably skilled practitioners in cases other than cases
under the Bankruptcy Code.
WHEREFORE, Applicant respectfully requests that this Court enter an order:
(a) approving the allowance of compensation for professional services that
were rendered by SHA-LLC to the Committee during the period from September 1, 2012
through and including September 30, 2012 in the amount of$11,389.50;
(b) approving the reimbursement of SHA-LLC's expenses incurred m
connection with the rendering of such services in the amount of $3 93 .34; and
7
(c) granting to SHA-LLC such other relief as this Court may deem just and
proper.
Dated: October 25, 2012
Wilmington, Delaware
SULLIVAN HAZELTINE ALLINSON LLC
n J ~
William A. Hazeltine (No. 3294)
901 North Market Street, Suite 1300
Wilmington, DE 19801
Tel: (302) 428-8191
Fax: (302) 428-8195
Email: whazeltine@sha-llc.com
Attorneys for the Official Committee of Unsecured
Creditors
8
In re:
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
j Chapter 11
) Case No. 12-11564 (CSS)
j (Jointly Administered)
Debtors.
j Objection Deadline: Nov. 14, 2012 at 4:00p.m.
) Hearing Date: Only if an objection is filed
NOTICE OF APPLICATION
PLEASE TAKE NOTICE THAT on October 25,2012, Sullivan Hazeltine Allinson LLC
filed the attached Fourth Monthly Application of Sullivan Hazeltine Allinson LLC for Compensation
for Services Rendered and Reimbursement of Expenses as Co-Counsel to the Official Committee of
Unsecured Creditors for the Period from September I, 2012 through September 30, 2012 (the
"Application") with the United States Bankruptcy Court for the District of Delaware (the
"Bankruptcy Court").
PLEASE TAKE FURTHER NOTICE that any objections to the Application must be made
in writing, filed with the Bankruptcy Court, 824 Market Street, Wilmington, Delaware 19801, and
served so as to actually be received on or before November 14, 2012 at 4:00p.m. Prevailing
Eastern Time by the following: (1) the Debtors, Allied Systems Holdings, Inc., 2302 Parklake
Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345 (Attn: John A. Blount); (2) co-counsel to the
Debtors, Troutman Sanders LLP, Bank of America Plaza, 600 Peach Street, Suite 5200, Atlanta,
Georgia, 30308 (Attn: Jeffrey W. Kelley) and Richards, Layton & Finger, P.A., One Rodney
Square, 920 N. King Street, Wilmington, Delaware 19801 (Attn: Mark D. Collins); (3) the Office of
1
The debtors in the above-captioned cases (collectively, the "Debtors"), along with the federal tax identitkation number (or Canadian business
number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081);
Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-0 169283); Allied Systems, Ltd. (L.P.) (58-171 0028); Axis Areta,
LLC (45-5215545); Axis Canada Company 87568828); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc.
(38-2918187); Cord in Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-03651 00); GACS Incorporated (58-1944 786); Logistic
Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-2876863); RMX LLC (31-0961359); Transport Support LLC
(38-2349563); and Terminal Services LLC (91-084 7582). The location of the Debtors' corporate headquarters and the Debtors' address for service of
process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.
the United States Trustee for the District of Delaware, 844 N. King Street, Suite 2207, Lockbox 35,
Wilmington, Delaware 19801 (Attn: David L. Buchbinder); and (4) co-counsel to the Committee,
Sidley Austin LLP, 787 Seventh Avenue, New York, New York 10019 (Attn: Michael G. Burke)
and Sullivan Hazeltine Allinson LLC, 901 North Market Street, Suite 1300, Wilmington, Delaware
19801 (Attn: William A. Hazeltine).
PLEASE TAKE FURTHER NOTICE that, pursuant to the Order Establishing Procedures
for Interim Compensation and Reimbursement of Expenses for Professionals and Official
Committee Members (D.I. 215), if no Objection is filed and served in accordance with the above
procedure, the Debtors will be authorized to pay 80% of the requested fees and 1 00% of the
requested expenses without further order of the Court.
Dated: October 25, 2012
Wilmington, Delaware
SULLIVAN HAZELTINE ALLINSON LLC
Is/ William A. Hazeltine
William A. Hazeltine (No. 3294)
901 North market Street, Suite 1300
Wilmington, DE 19801
Tel: (302) 428-8191
Fax: (302) 428-8195
Email: whazeltine@sha-llc.com
Attorneys for the Official Committee of Unsecured
Creditors
2
Exhibit A
SULLIVAN HAZELTINE ALLINSON LLC
Attorneys and Counselors at Law
901 North Market Street, Suite 1300
Wilmington, DE 19801
Tax ID # 20-5238500
Tel: (302) 428-8191
Fax:(302) 428-8195
The Official Committee of Unsecured Creditors
c/o Dennis Kao, Esq.
Sidley Austin LLP
787 Seventh Avenue
New York, NY 10019
In Reference To: Allied Systems Holdings, Inc., et al.
Case No. 12-11564 (CSS)
Professional Services
Business and Finance
9/28/2012 HMC Review of statement of financial affairs; meeting with WDS
SUBTOTAL:
Case Administration
9/26/2012 WDS Telephone conversation with counsel for Creditor re: case issues and
expedited timeline for events
SUBTOTAL:
Contested Matters
9/17/2012 WDS Review Smodic stay relief motion, conference with co-counsel re: standards
applicable
WDS Correspondence with co-counsel re: KERP standards; review and analyze
proof standards for KERP motions, review applicable case law
WDS Correspondence with co-counsel, coordinate review of KERP Motion
SSB Research KERP objections; e-mail correspondence with WDS re: same
9/18/2012 WAH Additional research re: KERP issues (.9); discussion with B. Sullivan and S.
Brostoff re: same (.2)
SSB Research Neilson docket items and review transcript for precedent re:
challenging KERP retention in Chapter 11
October 23, 2012
Invoice # 14598
Hours Amount
0.60 90.00
0.60 90.00]
0.20 85.00
0.20 85.00]
0.30 127.50
1.50 637.50
0.30 127.50
2.90 725.00
1.10 396.00
1.40 350.00
Allied Systems Committee
9/18/2012 WDS Review KERP standards from prior cases and analyze application to current
motion
WDS Correspondence with co-counsel re: KERP matters
WDS Telephone conversation with D. Buchbinder re: KERP Standards
WDS Telephone conversation with co-counsel, correspondence with M. Burke re:
KERP standards in DE Bankruptcy Court
9/21/2012 WAH Review and comment on objection to KERP motion
WDS Correspondence with co-counsel re: objection to KERP Motion; review filing
and service issues with firm; including potential seal motion
HMC Meeting with WAH; draft motion, order, notice and certificate of service to
file under seal exhibit A to Certification of counsel
9/24/2012 WAH Review and comment on revised objection to KERP motion and prepare for
filing
HMC Finalize objection to KERP motion; prepare certificate of service; file and
serve same
9/25/2012 WAH Communications re: joinder to debtors' objection to relief from stay motions
WDS Correspondence with co-counsel re: response to stay relief motions
WDS Review joinder language and forward draft to co-counsel
WDS Review and analyze Debtor's objection to stay relief motion
9/26/2012 WAH Communications re: objection to lift stay motions
WDS Draft analysis of deduction issues for lift stay motion, impact of federal law
requirements, forward to co-counsel
SUBTOTAL:
Fee Applications
9/6/2012 WAH Certificate of No Objection for SHA June fee application
9/7/2012 WDS Review Sidley June Fee Application, coordinate preparation for filing,
telephone conversation with co-counsel re: same
HMC Draft notice and certificate of service for co-counsel's first fee application;
file and service same
9/13/2012 WDS Telephone conversation with co-counsel re: Committee fee cap issue
WAH Discussion with B. Sullivan re: fee cap issues
WDS Review transcripts re: prior ruling on Committee fee cap, summarize for
co-counsel
9/14/2012 WAH Discussion with M. Burke re: fee cap issues
Page 2
Hours Amount
0.60 255.00
0.20 85.00
0.30 127.50
0.60 255.00
0.80 288.00
0.40 170.00
0.70 105.00
0.80 288.00
0.60 90.00
0.20 72.00
0.20 85.00
0.60 255.00
0.60 255.00
0.20 72.00
1.00 425.00
15.30 5, 191.00]
0.20 72.00
0.50 212.50
0.70 105.00
0.40 170.00
0.30 108.00
1.50 637.50
0.20 72.00
Allied Systems Committee
9/14/2012 WDS Telephone conversation with co-counsel re: investigation fee cap issues
9/17/2012 WAH Review Growling LeFieur and Rust Omni June fee applications
WAH Review and comment on Conway McKenzie June fee application and
prepare for filing
HMC Review and revise summary and fee application for Conway MacKenzie's
first fee application; draft notice and certificate of service; file and serve
same
9/18/2012 WAH Review and comment on CM July fee application and prepare for filing
HMC Review and revise summary and fee application for Conway MacKenzie's
second fee application; draft notice and certificate of service; file and serve
same
9/24/2012 HMC Draft Certificate of No Objection for SHA second fee application; file and
serve same
WAH Certificate of No Objection for SHA July fee application
9/26/2012 WDS Telephone conversation with M. Burke, review Strikeman Fee Application
and outline suggested revisions per local practice
WDS Telephone conversation with Canadian counsel re: fee application issues
9/27/2012 WAH Review and comment on Stikeman's July/August fee application and
prepare for filing
HMC Draft notice and certificate of service for Stikeman Elliott's first fee
application; file and serve same
WDS Correspondence with co-counsel re: handling of Stikeman fee application
SUBTOTAL:
Financing and Cash Collateral
9/14/2012 WDS Follow-up on review of preservation of investigation rights
9/21/2012 WAH Review and comment on stipulation and certification of counsel re:
extension of challenge deadline
WAH Revise motion to seal re: challenge period stipulation
9/22/2012 WAH Revise certification of counsel, stipulation and proposed order re: extension
of challenge period and prepare for filing
9/26/2012 WDS Review operations report and DIP loan status
9/28/2012 WDS Review tort claim list, confer with co-counsel re: impact of claims on Plan
and DIP repayment, analyze Debtors insurance representations
SUBTOTAL:
Page 3
Hours Amount
0.30
0.30
0.60
0.90
0.40
0.90
0.40
0.20
0.50
0.30
0.70
0.60
0.20
10.10
127.50
108.00
216.00
135.00
144.00
135.00
60.00
72.00
212.50
127.50
252.00
90.00
85.00
3,141.50]
0.50 212.50
0.20 72.00
0.60 216.00
0.60 216.00
0.30 127.50
1.20 510.00
3.40 1,354.00]
Allied Systems Committee
Hearings
9/28/2012 WDS Review status of matters and hearing preparation with W. Hazeltine
WAH Attend hearing re: relief from stay motion and KERP motions
SUBTOTAL:
Review of Pleadings and Documents
9/17/2012 WAH Review motion to extend time to remove related proceedings, motion to
extend exclusive periods, motion to extend time to assume or reject leases,
stay relief motions and employee incentive plan motion
9/26/2012 WDS Review pleadings for September 28 hearing, coordinate binder preparation
SUBTOTAL:
For professional services rendered
Additional Charges :
Case Administration
7/27/2012 Courier Service
9/6/2012 FedEx
9/7/2012 Courier Service
9/12/2012 FedEx
9/17/2012 Courier Service
9/19/2012 Courier Service
9/20/2012 FedEx
9/21/2012 FedEx
9/24/2012 Courier Service
Courier Service
9/27/2012 Courier Service
Fed Ex
9/30/2012 FedEx
SUBTOTAL:
Total additional charges
Total amount of this bill
Page 4
Hours Amount
0.50 212.50
2.80 1,008.00
3.30 1 ,220.50]
0.50 180.00
0.30 127.50
0.80 307.50]
33.70 $11,389.50
10.00
48.34
18.75
49.00
18.75
10.00
49.00
49.00
5.00
18.75
18.75
49.00
49.00
393.34]
$393.34
$11,782.84
Allied Systems Committee
Name
William D. Sullivan
Heidi M. Coleman
Seth S. Brostoff
William A Hazeltine
Timekeeper Summary
Hours
13.30
5.40
4.30
10.70
Rate
425.00
150.00
250.00
360.00
Page 5
Amount
$5,652.50
$810.00
$1,075.00
$3,852.00
CERTIFICATE OF SERVICE
I, William A. Hazeltine, hereby certify that on the, hereby certify that, on October 25,
2012, I caused one copy of the foregoing to be served upon the parties listed below in the manner
indicated.
Via Federal Express
John A. Blount
Allied Systems Holdings, Inc.
2302 Parklake Drive, Bldg. 15, Ste. 600
Atlanta, Georgia 30345
Via Federal Express
Jeffrey W. Kelley, Esq.
Troutman Sanders LLP
Bank of America Plaza
600 Peach Street, Suite 5200
Atlanta, Georgia, 30308
Via Hand Delivery
Mark D. Collins, Esq.
Richards, Layton & Finger, P.A.
One Rodney Square
Wilmington, Delaware 19801
Via Hand Delivery
David L. Buchbinder, Esq.
United States Trustee for the District of
Delaware, 844 N. King Street, Suite 2207,
Lockbox 35 Wilmington, Delaware 19801
Under penalty of perjury, I declare the foregoing to be true and correct.
October 25, 2012 Is/ William A. Hazeltine
Date William A. Hazeltine