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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
PROTEUS DIGITAL HEALTH, INC., Debtor.
Chapter 11
Case No. 20-11580 (BLS) (Jointly Administered)
Objection Deadline: November 4, 2020 at 4:00 p.m.
SECOND MONTHLY APPLICATION OF DUNDON ADVISERS, LLC
FOR COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES AS FINANCIAL ADVISER TO THE OFFICIAL COMMITTEE
OF UNSECURED CREDITORS FOR THE PERIOD AUGUST 1, 2020 THROUGH AUGUST 31, 2020
Pursuant to Sections 330 and 331 of title 11 of the United States Code, §§ 101-1532 (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), Dundon Advisers, LLC (“Dundon”), financial advisor to the official committee of unsecured creditors (the “Committee”) of the above-captioned debtor and debtor in possession (the “Debtor”), hereby filed this s econd monthly application (the “Application”). Pursuant to this Application, Dundon seeks allowance of compensation for professional services Dundon performed during the Fee Period in the amount of $25,045.00 less a twenty percent (20%) holdback in the amount of $5,009.00, for an immediately payable fee request of $20,036.00. No expenses were recorded during the fee period. In support of this Application, Dundon respectfully represents as follows:
Background
1. On June 15, 2020 (the “Petition Date”), the Debtor commenced this case (the “Chapter 11 Case”) under chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the District of Delaware (the “Court”). Pursuant to sections 1107 and 1108 of the
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Bankruptcy Code, the Debtor continues to operate its business as a debtor in possession. No trustee or examiner has been appointed in this case.
2. On June 29, 2020, the Committee was appointed in this Chapter 11 Case by the Office of the United States Trustee for the District of Delaware, consisting of the following members: (i) Romaco North America, Inc.; (ii) Workday, Inc.; and (iii) DeWinter Group. That same day, the Committee selected A.M. Saccullo Legal, LLC as its proposed counsel; and, on July 1, 2020, the Committee selected Dundon Advisers, LLC as its proposed financial advisor.
3. On August 7, 2020, upon prior application of the Committee, the Court entered the Order Approving Application of the Official Committee of Unsecured Creditors for Proteus Digital Health, Inc. for Entry of an Order Authorizing the Employment and Retention of Dundon Advisers, LLC as its Financial Advisor Nunc pro Tunc to July 1, 2020 [Docket No. 181] (the “Dundon Retention Order”).
4. On July 10, 2020, the Court entered the Order Authorizing Procedures for Interim Compensation and Reimbursement of Expenses of Professionals [Docket No. 107] (the “Administrative Order”).
Compensation Paid and Its Source
5. All services for which compensation is requested by Dundon were performed for or on behalf of the Committee.
6. Dundon has received no payment and no promises for payment from any source for services rendered or to be rendered in any capacity whatsoever in connection with the matters covered by this Application. There is no agreement or understanding between Dundon and any other person for the sharing of compensation to be received for services rendered in this Chapter 11 Case.
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7. The fee statement for the Compensation Period is attached hereto as Exhibit A. This statement contains daily time logs describing the time spent by each attorney for the Compensation Period. To the best of Dundon’s knowledge, this Application complies with sections 330 and 331 of the Bankruptcy Code, the applicable Bankruptcy Rules, Local Rule 2016-2, applicable Third Circuit law and the Administrative Order.
8. A summary of actual and necessary expenses and daily logs of expenses incurred by Dundon during the Compensation Period is attached hereto as Exhibit B.
Summary of Services Rendered
9. The Dundon professionals who have rendered professional services in this Chapter 11 Case are as follows: Matthew J. Dundon, Tabish Rizvi.
10. Dundon, by and through the above-named persons, has prepared and/or assisted in the preparation of retention applications and orders submitted to the Court for consideration, advised the Committee on a regular basis with respect to various matters in connection with this Chapter 11 Case and has performed all necessary professional services, which are described and narrated in detail hereinafter.
11. To provide a meaningful summary of Dundon’s services provided on behalf of the Committee, Dundon has established, in accordance with its internal billing procedures, certain subject project categories in connection with this Chapter 11 Case. The following chart is a summary of the fees and hours billed for each project category, before application of any discounts, in the Compensation Period:
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Project Category
Code
Project Category Description
Total Hours Billed Total Compensation Billed BA Business Analysis 21.7 $12,155.00 SP Sales Process 18.8 $10,840.00
CLAIM Claims Analysis 0.7 $385.00
PLN Plan and Disclosure Statement 1.4 $850.00
RET Retention and Fee Applications 1.3 $815.00
TOTAL BEFORE APPLICATION OF DISCOUNT: 43.9 $25,045.00 12. The following is a summary, by matter category, of the professional services provided by Dundon during the Compensation Period. This summary is organized in accordance with Dundon’s internal system of project category codes.
(a) Business Analysis (Project Category Code BA) Total Fees: $12,155.00
Total Hours: 21.7
13. This category includes time spent by Dundon completing myriad analyses to assess what recovery the Debtor’s creditors could expect at the end of the Chapter 11 Case. These analyses typically include, but are not limited to reviewing the Debtor’s: (1) financial affairs as presented in the Statement of Financial Affairs filed by the Debtor on July 27, 2020 [Docket No. 145]; (2) assets and liabilities as presented in the Statement of Assets and Liabilities filed by the Debtor on July 27, 2020 [Docket No. 146]; (3) motions, interim orders, and proposed orders related to Debtor’s use of cash collateral to fund expenses related to utilities, payroll, pre-petition obligations, debt service, and other operations; (4) ongoing liquidity by comparing the budget vs. actual cash-on-hand as presented in the Cash Collateral Order filed by the Debtor on July 14, 2020 [Docket No. 124]; and (5) pro forma liquidity by projecting future cash-on-hand based on knowledge expected collections, operational budget, and sales process developments. Time spent in this category also includes work completed by Dundon to understand and develop a narrative
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around the difficulties faced by the Debtor pre-petition and what events specifically triggered the Debtor to file a voluntary Chapter 11 petition.
(b) Sale Process (Project Category Code SP) Total Fees: $10,840.00
Total Hours: 18.8
14. Dundon spent significant time reviewing the proposed sale process and bid procedures, reviewing due-diligence materials shared with potential bidders, discussing sale prospects and terms with the Debtor and its advisors, negotiating fees payable to the investment bank retained by the Debtor in connection with the sale process, and reviewing any and sale documents.
(c) Claims Analysis (Project Category Code CLAIM) Total Fees: $385.00
Total Hours: 0.7
15. This category includes time spent all matters related to the analysis of admin, priority, secured, and general unsecured claims filed before and up until the bar date, including any issue, objections, and related contested matters.
(d) Plan and Disclosure Statement (PLN) Total Fees: $850.00
Total Hours: 1.4
16. This category includes time spent on all matters related to the review, formulation, negotiation, preparation, and promulgation of plans of reorganization, disclosure statements and related documentation and all research relating thereto.
(e) Retention/Fee Applications (Project Category Code RET) Total Fees: $815.00
Total Hours: 1.3
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compensation of Dundon, including the preparation and filing of retention and fee applications.
Valuation of Services
18. Dundon’s professionals expended a total of 43.9 hours in connection with this matter during the Compensation Period, as follows:
PROFESSIONALS: HOURS: HOURLY RATE:
Matthew J. Dundon 4.5 $750.00
Tabish Rizvi 39.4 $550.00
19. The nature of the work performed by these persons is fully set forth in Exhibit A attached hereto. These are Dundon’s normal hourly rates for work of this character. The reasonable value of the services rendered by Dundon to the Committee during the Compensation Period is $25,045.00.
20. When retained, Dundon agreed with the Committee that it would cap its fees at a blended average rate of $575 per hour.
21. In accordance with the factors enumerated in Section 330 of the Bankruptcy Code, it is respectfully submitted that the amount requested by Potter Anderson is fair and reasonable given (a) the complexity of this case, (b) the time expended, (c) the nature and extent of the services rendered, (d) the value of such services and (e) the costs of comparable services other than in a case under this title. Moreover, Dundon has reviewed the requirements of Local Rule 2016-2 and believes that this Application complies with that Rule.
WHEREFORE, Dundon respectfully requests that the Court authorize that for the Compensation Period, an allowance be made to Dundon pursuant to the terms of the Administrative Order, with respect to the sum of $25,045.00 as compensation for necessary professional services rendered (80% of which equals $20,036.00) and that such sum be authorized for payment and for such other and further relief as this Court may deem just and proper.
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Dated: October 14, 2020 DUNDON ADVISERS, LLC
/s/ Matthew J. Dundon Matthew J. Dundon
440 Mamaroneck Avenue, 5th Floor Harrison, New York 10528
Telephone: (914) 341-1188 Email: md@dundon.com
Financial Advisers for the Official Committee of Unsecured Creditors
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
PROTEUS DIGITAL HEALTH, INC.,1 Debtor.
Chapter 11
Case No. 20-11580 (BLS) (Jointly Administered)
Objection Deadline: November 4, 2020 at 4:00 p.m.
SUMMARY OF SECOND MONTHLY APPLICATION OF DUNDON ADVISERS, LLC FOR COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT
OF EXPENSES AS FINANCIAL ADVISER TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR THE PERIOD
AUGUST 1, 2020 THROUGH AUGUST 31, 2020
Name of Applicant: Dundon Advisers, LLC
Authorized to provide professional services to: The Official Committee of Unsecured Creditors
Petition Date: June 15, 2020
Date of Retention: August 7, 2020 effective as of July 1, 2020
Period for which compensation and
reimbursement are sought: August 1, 2020 through August 31, 2020
Amount of compensation sought as
actual, reasonable, and necessary: $25,045.00 (80% = $20,036.00) Amount of expense reimbursement sought
as actual, reasonable, and necessary: None
This is a(n): _ X _ monthly interim final application
1 The last four digits of the Debtor’s taxpayer identification number is 2680.
Case 20-11580-BLS Doc 308 Filed 10/14/20 Page 1 of 11
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20115802010140000000000012
SUMMARY OF PREVIOUSLY FILED APPLICATIONS Date Filed Period Covered Requested Fees Requested
Expenses Approved Fees (80%) Expenses (100%) Approved
September 9, 2020 July 1, 2020 –
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COMPENSATION BY PROFESSIONAL AUGUST 1, 2020 THROUGH AUGUST 31, 2020
TIMEKEEPER NAME POSITION
HOURLY RATE BILLED IN THIS FEE APPLICATION
HOURS BILLED IN THIS FEE
APPLICATION
FEES BILLED IN THIS FEE APPLICATION
Matthew J. Dundon Principal $750.00 4.5 $3,375.00
Tabish Rizvi Director $550.00 39.4 $21,670.00
TOTAL: 43.9 $25,045.00
Blended Hourly Rate: $570.50
Discount required to achieve agreed upon blended hourly rate: 0.00%
FEE WITH EFFECT OF DISCOUNT: $25,045.00
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COMPENSATION BY PROJECT CATEGORY AUGUST 1, 2020 THROUGH AUGUST 31, 2020 Project
Category Code
Project Category Description
Total Hours Billed Total Compensation Billed* BA Business Analysis 21.7 $12,155.00 SP Sales Process 18.8 $10,840.00
CLAIM Claims Analysis 0.7 $385.00
PLN Plan and Disclosure Statement 1.4 $850.00
RET Retention and Fee Applications 1.3 $815.00
Total 43.9 $25,045.00
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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE
In re:
PROTEUS DIGITAL HEALTH, INC., Debtor.
Chapter 11
Case No. 20-11580 (BLS) (Jointly Administered)
Objection Deadline: November 4, 2020 at 4:00 p.m. NOTICE OF SECOND MONTHLY APPLICATION OF DUNDON ADVISERS, LLC
FOR COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES AS FINANCIAL ADVISERS TO THE OFFICIAL COMMITTEE
OF UNSECURED CREDITORS FOR THE PERIOD AUGUST 1, 2020 THROUGH AUGUST 31, 2020
PLEASE TAKE NOTICE that the Official Committee of Unsecured Creditors (the “Committee”) filed the Second Monthly Application of Dundon Advisers, LLC for Compensation for Services Rendered and Reimbursement of Expenses as Financial Advisers to the Official Committee of Unsecured Creditors for the Period August 1, 2020 through August 31, 2020 (the “Application”) with the United States Bankruptcy Court for the District of Delaware (the “Court”).
PLEASE TAKE FURTHER NOTICE that objections to the Application, if any, are required to be filed on or before November 4, 2020 at 4:00 p.m. (ET) (the “Objection Deadline”) with the Clerk of the United States Bankruptcy Court for the District of Delaware, 3rd Floor, 824 North Market Street, Wilmington, Delaware 19801.
PLEASE TAKE FURTHER NOTICE that objections to the Application, if any, must be served upon and received by the following Application Recipients: (i) the Debtor: Proteus Digital Health, Inc., c/o SierraConstellation Partners LLC, 355 S. Grand Avenue, Suite 1450, Los Angeles, California 90071 (Attn: Lawrence R. Perkins, (lperkins@scpllc.com)); (ii) counsel to the Debtor, (a) Goodwin Procter LLP, 620 Eighth Avenue, New York, New York 10018 (Attn: Nathan A. Schultz (nschultz@goodwinlaw.com), Barry Z. Bazian (bbazian@goodwinlaw.com)) and (b) Potter Anderson & Corroon LLP, 1313 North Market Street, 6th Floor, Wilmington, Delaware
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19801 (Attn: L. Katherine Good (kgood@potteranderson.com)); (iii) the Office of the United States Trustee, J. Caleb Boggs Federal Building, 844 King Street, Suite 2207, Lockbox 35, Wilmington, DE 19801 (Attn: Benjamin A. Hackman (Benjamin.A.Hackman@usdoj.gov)); (iv) Counsel to the Official Committee of Unsecured Creditors, A.M. Saccullo Legal, LLC, 27 Crimson King Drive, Bear, Delaware 19701 (Attn: Anthony M. Saccullo (ams@saccullolegal.com), Thomas H. Kovach (kovach@saccullolegal.com); and Mary E. Augustine (meg@saccullolegal.com)); and (v) the Prepetition Lender’s Counsel: Pachulski Stang Ziehl & Jones LLP (a) 10100 Santa Monica Boulevard, 13th Floor, Los Angeles, California 90067 (Attn: Jeffrey H. Davidson (jdavidson@pszjlaw.com), Debra I. Grassgreen (dgrassgreen@pszjlaw.com); and (b) 919 N. Market Street, 17th Floor, P.O. Box 8705, Wilmington, Delaware 19899-8705 (Attn: James E. O’Neill (joneill@pszjlaw.com)).
PLEASE TAKE FURTHER NOTICE THAT PURSUANT TO THE ORDER AUTHORIZING PROCEDURES FOR INTERIM COMPENSATION AND REIMBURSEMENT OF EXPENSES OF PROFESSIONALS [DOCKET NO. 107], IF NO OBJECTIONS ARE FILED AND SERVED IN ACCORDANCE WITH THE ABOVE PROCEDURE, THE DEBTORS WILL BE AUTHORIZED TO PAY 80% OF THE REQUESTED FEES AND 100% OF THE REQUESTED EXPENSES WITHOUT FURTHER ORDER OF THE COURT.
Dated: October 14, 2020 A.M. SACCULLO LEGAL, LLC
/s/ Mary E. Augustine
Mary E. Augustine (No. 4477) 27 Crimson King Drive Bear, Delaware 19701 Telephone: (302) 836-8877 Facsimile: (302) 836-8787 Email: meg@saccullolegal.com
VERIFICATION
I, Matthew J. Dundon, pursuant to 28 U.S.C. § 1746, declare under penalty of perjury that the following statements are true and correct to the best of my knowledge and based on the information and records available to me:
(a) I am a principal with the applicant firm, Dundon Advisers LLC.
(b) I am familiar with the work performed on behalf of the Committee by the professionals in the firm.
(c) I have reviewed the foregoing Application, and the facts set forth therein are true and correct to the best of my knowledge, information, and belief. Moreover, I have reviewed Del. Bankr. L.R. 2016-2, and submit that the Application substantially complies with such rule.
/s/ Matthew J. Dundon Matthew J. Dundon
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Exhibit A Billing Detail
Staff Date Description Task Code Hours Rate Fee
Rizvi 08/01/2020 Reviewing items filed to docket since 07-28-2020 for major matters. Focused on DeWinter Group's, Integron, and Oracle’s limited rejection of cure costs.
Business Analysis 0.70 $550.00 $385.00 Rizvi 08/01/2020 Prepare materials for Committee update re: Statements and Schedules Analysis. Business Analysis 0.20 $550.00 $110.00 Rizvi 08/04/2020 Prepare materials for Committee update re: Statements and Schedules Analysis.
Layout template.
Business Analysis 0.70 $550.00 $385.00 Rizvi 08/04/2020 Prepare materials for Committee update re: Statements and Schedules Analysis.
Analyze assets categories.
Business Analysis 1.00 $550.00 $550.00 Rizvi 08/04/2020 Prepare materials for Committee update re: Statements and Schedules Analysis.
Breakout assets into sub-categories to provide UCC visibility into what made up various accounts on the balance sheet.
Business Analysis 2.30 $550.00 $1,265.00
Rizvi 08/04/2020 Prepare materials for Committee update re: Statements and Schedules Analysis. Preparing graphs and charts of disbursements made 90-days prior to petition date.
Business Analysis 1.30 $550.00 $715.00
Rizvi 08/04/2020 Prepare materials for Committee update re: Statements and Schedules Analysis. Prepare graphs and charts for insider payments 1 year prior to petition date.
Business Analysis 1.30 $550.00 $715.00 Rizvi 08/05/2020 Review stalking horse bid procedures and APA to starting preparing liquidation
analysis following receipt of no qualified bids.
Business Analysis 1.00 $550.00 $550.00 Dundon 08/08/2020 Review and discussion of equity objections to sales process Sales Process 0.80 $750.00 $600.00 Dundon 08/08/2020 Discussions with AMSL and Morris James regarding preferred equity objections
to sale process
Sales Process 0.60 $750.00 $450.00 Rizvi 08/10/2020 Calculate Interest Savings on OrbiMed Loan if we negotiate possible reduction
in interest
Business Analysis 0.40 $550.00 $220.00 Dundon 08/11/2020 Review of lease / executory contract assumptions and rejections tied to sales
process
Sales Process 0.70 $750.00 $525.00 Rizvi 08/11/2020 Analysis of economic savings tied to contracts assumed and rejected by Otsuka. Business Analysis 1.70 $550.00 $935.00 Rizvi 08/11/2020 Sale Hearing, Round 1. Business Analysis 0.70 $550.00 $385.00 Rizvi 08/11/2020 Analysis of economic savings tied to contracts assumed and rejected by Otsuka
(Cont'd).
Business Analysis 1.80 $550.00 $990.00 Rizvi 08/11/2020 Call with UCC Financial Advisors re: Contract Rejection Valuation Analysis. Claims Analysis 0.30 $550.00 $165.00
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Staff Date Description Task Code Hours Rate Fee
Rizvi 08/11/2020 Research mitigation procedures in states where largest contracts have been rejected by Otsuka.
Claims Analysis 0.30 $550.00 $165.00 Rizvi 08/11/2020 Call with UCC Counsel re: Contract Rejection Valuation Analysis. Claims Analysis 0.10 $550.00 $55.00 Rizvi 08/11/2020 Analysis of economic savings tied to contracts assumed and rejected by Otsuka
(Cont'd).
Business Analysis 0.90 $550.00 $495.00 Rizvi 08/12/2020 Conversation with SCP re: liquidity if JPIM and Preferred Equity groups delay
closing of stalking horse sale.
Business Analysis 0.40 $550.00 $220.00 Rizvi 08/12/2020 Conversation with UCC Professionals re: liquidity if JPIM and Preferred Equity
groups delay closing of stalking horse sale.
Business Analysis 0.40 $550.00 $220.00 Rizvi 08/12/2020 Prepare narrative around pro forma cash deficit if case drags on longer than
end of month; and, new parties disrupting timeline should be forced to "pay to play."
Business Analysis 0.90 $550.00 $495.00
Dundon 08/13/2020 Discussion of recovery structure implications of bid Plan and Disclosure Statement
0.40 $750.00 $300.00 Dundon 08/13/2020 UCC professionals discussion Business Analysis 0.60 $750.00 $450.00 Rizvi 08/13/2020 Call w/ UCC Professionals re: cash deficit and latest construct of sale following
up on narrative prepared and shared last night on the same subject.
Business Analysis 0.50 $550.00 $275.00 Rizvi 08/13/2020 Call w/ UCC Financial Advisors re: cash deficit and latest construct of sale
following up on narrative prepared and shared last night on the same subject.
Business Analysis 0.40 $550.00 $220.00 Rizvi 08/13/2020 Call w/ SCP re: expected severance payments that would translate into
additional unsecured claims.
Business Analysis 0.40 $550.00 $220.00 Rizvi 08/13/2020 Prepare pro forma liquidation analysis to determine pro forma unsecured
creditor recovery at maximum mitigation amounts.
Business Analysis 0.70 $550.00 $385.00 Rizvi 08/14/2020 Review 'Stalking Horse Bid Procedures' in advance of Sale Hearing scheduled for
Monday August 17, 2020.
Business Analysis 1.40 $550.00 $770.00 Dundon 08/16/2020 Discussion of sealed vs. unsealed versions of equity committee oppositions Sales Process 0.40 $750.00 $300.00 Rizvi 08/17/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with
Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580).
Sales Process 3.30 $550.00 $1,815.00
Rizvi 08/17/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580).
Sales Process 2.80 $550.00 $1,540.00
Rizvi 08/18/2020 Review Motion to Strike filed by ad-hoc equity committee. Plan and Disclosure Statement
1.00 $550.00 $550.00
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Staff Date Description Task Code Hours Rate Fee
Rizvi 08/18/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580).
Sales Process 1.50 $550.00 $825.00
Rizvi 08/18/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580).
Sales Process 4.20 $550.00 $2,310.00
Rizvi 08/19/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580). Day 3. Continuation of Sherwood Partners' Examination/Cross + Closing Arguments.
Sales Process 3.60 $550.00 $1,980.00
Rizvi 08/19/2020 Preparation pro forma cash uses for case administration netting for one-time expenses based on call collateral order provided by SierraConstellation if the case were to last an additional 13 weeks beyond original sale deadline.
Business Analysis 1.20 $550.00 $660.00
Rizvi 08/19/2020 Update other Financial Advisor team following participation in Day 3 of Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580). Continuation of Sherwood Partners' Examination/Cross + Closing Arguments.
Sales Process 0.40 $550.00 $220.00
Rizvi 08/19/2020 Participate on Sale Hearing in relation to Otsuka as stalking horse bidder with Honorable Brendan L. Shannon in the U.S. Bankruptcy Court-District of Delaware (Case No. 20-11580). Day 3. Ruling.
Sales Process 0.50 $550.00 $275.00
Rizvi 08/20/2020 Reconciliation of OrbiMed secured loan payoff amount. Business Analysis 0.30 $550.00 $165.00 Dundon 08/27/2020 Case status & strategy discussion with AMSL. Business Analysis 0.50 $750.00 $375.00 Dundon 08/31/2020 Edit and discussion of time entries Retention and Fee
Applications
0.50 $750.00 $375.00 Rizvi 08/31/2020 Reviewing and marking up AMSL’s Fee Application template for purposes of
Dundon's application.
Retention and Fee Applications
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Exhibit B Expense Detail
None.
