notice of first monthly fee application of klett rooney ...klett rooney expended 114.0 hours during...

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In Re: ) Chapter 11 )

FANSTEEL, INC., et al. ) 02-10109 (JJF) )

Debtors. ) Jointly Administered ) ) Hearing Date: (Only if Objections Are Received) ) Objection Deadline: April 15, 2002 at 4:00 p.m.

NOTICE OF FIRST MONTHLY FEE APPLICATION OF

KLETT ROONEY LIEBER & SCHORLING, A PROFESSIONAL CORPORATION

PLEASE TAKE NOTICE that pursuant to an Administrative Order Under 11

U.S.C. § § 105(a) and 331 Establishing Procedures for Interim Compensation and Reimbursement

ofExpenses for Professionals and Committee Members of this Court entered February 20,2002, (the

"Administrative Order"), on March 26, 2002, Klett Rooney Lieber & Schorling, (the "Applicant")

filed and served upon the parties indicated in the Administrative Order its First Monthly Application

ofKlett Rooney Lieber & Schorling, Co-Counsel to Official Committee of Unsecured Creditors, for

Compensation and Reimbursement of Expenses Pursuant to 11 U.S.C. §§ 330 and 331 (the

"Application"). The Applicant seeks allowance of compensation in the total amount of $30,451.50

(and payment of 80% of that amount, or $24,361.20) and reimbursement of expenses in the total

amount of $4,055.42 during the Application period.

PLEASE TAKE FURTHER NOTICE that any party who wishes to be served with

a copy of the Application may contact the Applicant directly. c

PLEASE TAKE FURTHER NOTICE that any responses or objections to the

Application must be filed with the Clerk of the Court, United States Bankruptcy Court for the

District of Delaware, 824 Market Street, Wilmington, Delaware 19801, on or before 4:00 p.m. on

/~ /

April 15, 2002 (the "Objection Deadline"). If you file an objection or response to the Application,

it must also be served so as to be received on or before the Objection Deadline on the Applicant.

PLEASE TAKE FURTHER NOTICE that any timely objections or responses to

the Application will be scheduled at the convenience of the Court to consider the Application.

PLEASE TAKE FURTHER NOTICE if no responses or objections are filed and

served in accordance with this Notice, the Application may be granted by the Court without further

notice or hearing.

KLETT ROONEY LIEBER & SCHORLING a Professional Corporation

By: 4a / Adam G. Landis (#3407) Jeffrey M. Carbino (#4062) Klett Rooney Lieber & Schorling The Brandywine Building 1000 West Street - Suite 1410 Wilmington, DE 19801 (302) 552-4200 alandis(klettrooney.com icarbino@,klettrooney.com

Co-Counsel to the Official Committee ofUnsecured Creditors

Date: March 26, 2002

WLM 30435.1 2



FANSTEEL, INC., et al. ) 02-10109 (JJF) )

Debtors. ) Jointly Administered ) ) Hearing Date: (Only if Objections Are Received)

Objection Deadline: April 15, 2002 at 4:00 p.m.

FIRST MONTHLY APPLICATION OF KLETT ROONEY LIEBER & SCHORLING, CO-COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS,

FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES PURSUANT TO 11 U.S.C. §§ 330 AND 331

Klett Rooney Lieber & Schorling ("Klett Roonev'), co-counsel to the Official

Committee ofUnsecured Creditors (the "Committee"), hereby submits this first monthly application

(the "Application") for compensation and reimbursement of expenses pursuant to 11 U.S.C. §§ 330

and 331 for legal services performed during the period commencing January 28, 2002 through and

including February 28, 2002 (the "Application Period") as counsel to the Official Committee of

Unsecured Creditors in this proceeding. In support hereof, Klett Rooney respectfully represents as

follows:

Introduction

1. On January 15, 2002 (the "Petition Date"), the Debtors commenced their

respective reorganization cases by filing voluntary petitions for relief under Chapter 11 of Title 11

of the United States Code, 11 U.S.C. § 101 et seq. (the "Bankruptcy Code"), in the United States

Bankruptcy Court for the District of Delaware (the "Court").

KRLSWIL:30436.1

2. The Debtors are continuing in possession of their respective properties and

are operating and managing their businesses as debtors-in-possession pursuant to Sections 1107 and

1108 of the Bankruptcy Code.

3. The Official Committee oflUnsecured Creditors (the "Creditors' Committee")

was appointed by the Office of the United States Trustee in these cases on January 28, 2002. The

Creditors' Committee subsequently selected Klett Rooney and Freeborn & Peters ("Freeborn") as

its co-counsel and Navigant Consulting ("Navigant") as its financial advisors.

4. By order of the Court entered on March 14,2002, Klett Rooney was employed

as co-counsel to the Creditors' Committee nunc pro tunc to January 28, 2002.

Jurisdiction

5. This Court has jurisdiction over the Application under 28 U.S.C. § 1334.

This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(A) and (M).

6. The statutorybases for the relief requested herein are Sections 105(a), 330 and

331 of the Bankruptcy Code.

TERMS AND CONDITIONS OF COMPENSATION OF KLETT ROONEY

7. Subject to Bankruptcy Court approval, Klett Rooney seeks payment for

compensation on an hourly basis, plus reimbursement of actual, necessary expenses incurred by Klett

Rooney during the Application Period. The rates charged by Klett Rooney in this case do not differ

from the rates charged to Klett Rooney's non-bankruptcy clients.

8. A summary of the hours spent, the names of each professional and

paraprofessional rendering services to the Debtors during the Application Period, the regular

customary billing rates and the total value of time incurred by each of the Klett Rooney attorneys

rendering services to the Creditors' Committee is attached hereto as Exhibit "A." A copy of the

KRLSWIL:30436.1 2

computer generated time entries reflecting the time recorded for these services, organized in project

billing categories in accordance with the United States Trustee's Guidelines For Reviewing

Applications For Compensation And Reimbursement of Expenses Filed Under 11 U.S.C. § 330 (the

"Guidelines"), is attached hereto as Exhibit "B." A statement of expenses incurred by Klett Rooney

during the Application Period is attached hereto as Exhibit "C." All time entries and requested

expenses are in compliance with Local Rule No. 2016-2'

9. On February 20, 2002, this Court entered an Administrative Order, Pursuant

to 105 and 331 of The Bankruptcy Code, Establishing Procedures For Allowance and Payment of

Interim Compensation and Reimbursement of Expenses of Professionals (the "Administrative

Order"). Pursuant to the Administrative Order, Klett Rooney and other professionals retained in this

case are authorized to file and to serve upon the Debtors and the parties identified in the

Administrative Order monthly fee applications every month (a "Fee Application") of their fees and

expenses. After the expiration of a twenty (20) day objection period, the Debtors are authorized to

promptly pay eighty (80%) percent of the fees and one hundred (100%) percent of the expenses

requested in the Application, unless an objection has been lodged against specific fees and/or

expenses, or the Court orders otherwise.

10. In accordance with the Administrative Order, Klett Rooney has filed and

served upon the Debtors and the other parties identified in the Administrative Order this Application

Klett Rooney has also attempted to ensure that this Application complies with the Guidelines. To the extent the Guidelines conflict with local rules, in particular, Local Rule 2016-2, Klett Rooney has chosen to comply with such local rule. Klett Rooney will supplement this Application with additional detail or information upon request.

KRLSWIL:30436.1 3

with respect to fees and expenses incurred during the Application Period; to wit, fees in the amount

of $30,451.50 and expenses in the amount of $4,055.42 during the Application Period.

11. All services and costs for which compensation is requested by Klett Rooney

in this Application were reasonable and necessary and were performed for and on behalf of the

Creditors' Committee during the Application Period.

CASE STATUS

12. Klett Rooney currently is not aware of (a) the amount of cash on hand or on

deposit in the Debtors' estates; (b) the amount and nature of accrued unpaid administrative expenses;

(c) the Debtors' operating profit or loss; or (d) the amount of unencumbered funds in the Debtors'

estate.

13. The Debtors have not filed a plan of reorganization or a disclosure statement

in connection with these cases.

NARRATIVE SUMMARY DESCRIPTION OF SERVICES RENDERED ON A PROJECT SUMMARY BASIS

14. From the outset of this case, Klett Rooney has taken an active role as co

counsel to the Creditors' Committee. All of the professional services that Klett Rooney rendered

to the Creditors' Committee during the Application Period are set forth in detail in Exhibit "B,"

segregated according to project billing categories pursuant to the Guidelines. A brief description of

certain services deserving specific mention are highlighted below, by project category:

(A) Business Analysis: (Total Hours: .9, Total Fees: $126.00)

15. During the Application Period, Klett Rooney reviewed and coordinated the

filing of the Debtors' Stipulation to Extend the Time to file Schedules and Statements of Financial

Affairs.

KRLSWIL:30436.1 4

(B) Case Administration - (Total Hours: 33.6, Total Fees: $9,265.00)

16. This category includes Klett Rooney's regular and prompt review of dockets

in the case and maintenance and organization of pleadings, often through the efficient use of

paralegal time. In its role as a "clearinghouse" for information and communications to the Creditors'

Committee, Klett Rooney has been able to keep the Creditors' Committee informed, on a regular

basis, as to important developments in these cases.

(C) Claims Administration - (Total Hours: 3.2, Total Fees: $783.00)

17. This category includes Klett Rooney's review and analysis of the Debtors'

motion to pay certain critical vendors and the preparation and filing of the Creditors' Committee's

motion to reconsider the critical vendor order entered by the Court.

(D) Fee/Employment Applications - (Total Hours: 49.7, Total Fees: $11,324.00)

18. During the Application Period, Klett Rooney prepared, filed and served the

Notice and Motion to Approve Employment and Retention of Klett Rooney as Co-Counsel to the

Official Committee of Unsecured Creditors (the "Klett Rooney Retention Application"). In

connection with the Klett Rooney Retention Application, Klett Rooney performed research regarding

"disinterestedness" under the Bankruptcy Code and Bankruptcy Rules. Klett Rooney also

participated in conferences with Freeborn and Navigant regarding applications to retain those firms

as co-counsel and financial advisors to the Creditors' Committee, and regarding the United States

Trustee's objection to the Creditors' Committee retention of Klett Rooney and Freeborn.

(E) Fee/Employment Objections - (Total Hours: 1.6, Total Fees: $192.00)

KRLSWIL:30436.1 5

19. During this Application Period, review was made of the United States

Trustee's Objection to the retention of Klett Rooney Lieber & Schorling and research and

preparation of our reply brief in response to said objection.

(F) Financing - (Total Hours: 8.5, Total Fees: $2,868.00)

20. This category includes Klett Rooney's review and analysis of the Debtors'

various proposals regarding financing, including the Debtors' proposed sale of accounts receivable

to CIT, motions to approve "bridge" debtor-in-possession financing, and proposal regarding

"permanent" debtor-in-possession financing from Congress Financial.

(G) Meetings of Creditors - (Total Hours: 16.6, Total Fees: $5,893.00)

21. This category includes Klett Rooney's participation in periodic Creditors'

Committee meetings and conference calls.

COMPENSATION REQUESTED

22. Klett Rooney expended 114.0 hours during the Application Period in

furtherance of its efforts on behalf of the Creditors' Committee. Klett Rooney requests allowance

of compensation in the amount of $30,451.50 for legal services rendered during the Application

Period at a blended hourly rate of $266.88. Pursuant to the Administrative Order, Klett Rooney

requests payment of 80% of the total fees requested, or $24,361.20. None of the requested fees

detailed herein have been paid.

REIMBURSEMENT OF EXPENSES

23. During the Application Period, Klett Rooney incurred certain necessary

expenses in rendering legal services to the Creditors' Committee as set forth in Exhibit "C".

Telecopying expenses that were carried out in-house by Klett Rooney were charged at $0.75 per

KRLSWIL:30436.1 6

page. In order to more efficiently handle the voluminous copying of pleadings served and filed in

this case, Klett Rooney on occasion retained third-party duplication serviceproviders. Klett Rooney

seeks reimbursement only for the actual expenses charged by and owed to such third-party services.

Express mail costs were also incurred in the administration of the Debtors' cases. In addition, Klett

Rooney incurred costs associated with computer research during the Application Period in

connection with the drafting of various motions and to aid in advising the Creditors' Committee on

numerous issues.

24. Klett Rooney seeks reimbursement for its reasonable, necessary and actual

expenses incurred during the Application Period in the total amount of $4,055.42.

LEGAL STANDARD

25. Section 330(a)(1) of the Bankruptcy Code allows the payment of:

(a) reasonable compensation for actual, necessary services rendered by the trustee, examiner, professional person, or attorney and by any paraprofessional person employed by any such person; and

(b) reimbursement for actual, necessary expenses.

11 U.S.C. § 330(a)(1). Reasonableness of compensation is determined by the "market-driven

approach" which considers the nature, extent and value of the services provided by the professional

and the cost of comparable services in non-bankruptcy contexts. See Zolfo Cooper & Co., v.

Sunbeam-Oster Co., 50 F.3d 253,258 (3d Cir. 1995); In re Busy Beaver Building Ctr., Inc., 19 F.3d

833, 849 (3d Cir. 1994). Thus, "the baseline rule is for firms to receive their customary rates."

Zolfo Cooper, 50 F.3d at 259.

26. In accordance with its practice in non-bankruptcy matters, Klett Rooney has

calculated its compensation requested in this Application by applying its standard hourly rates. Klett

KRLSWIL:30436.1 7

Rooney's calculation is based upon hourly rates that are well within the range of rates that are

charged by comparable firms in similar bankruptcy cases. Accordingly, Klett Rooney's rates should

be determined to be reasonable under Section 330 of the Bankruptcy Code.

27. Klett Rooney's fees during the Application Period are also reasonable under

the prevailing legal standard and should be allowed. The amount of these fees is not unusual given

the complexity and size of the Debtors' Chapter 11 cases. Klett Rooney's fees are commensurate

with fees that other attorneys of comparable experience and expertise have charged and been

awarded in similar Chapter 11 cases. Accordingly, Klett Rooney's fees are reasonable pursuant to

Section 330 of the Bankruptcy Code.

28. Section 330(a)(1)(B) of the Bankruptcy Code permits reimbursement for

actual, necessary expenses. Klett Rooney's legal services and expenses incurred during the

Application Period are set forth in this Application and constitute only those necessary expenses that

were incurred for the benefit of the Debtors' estates. Klett Rooney has properly requested

reimbursement only of actual, necessary and appropriate legal expenses.

29. Except as permitted by Bankruptcy Rule 2016, no agreement or understanding

exists between Klett Rooney and or any third person for the sharing or division of compensation.

All of the services for which compensation is requested in this Application were rendered at the

request of and solely on behalf of the Debtors.

30. Pursuant to the standards set forth in Sections 330 and 331 of the Bankruptcy

Code, Klett Rooney submits that the compensation requested is for actual and necessary services and

expenses, and is reasonable, based upon the nature, extent and value of such services, the time spent

thereon, and the costs of comparable services in a case under the Bankruptcy Code.

KRLSWIL:30436.1 8

31. The time records annexed to this Application constitute only a general

statement of the services rendered and time expended without description of the pressure and

constraints under which Klett Rooney actually rendered these services. The considerable challenge

of these cases have been attended to and managed by Klett Rooney at all levels, promptly, expertly,

and often to the exclusion of other matters in Klett Rooney's office. Klett Rooney submits,

therefore, that its fees and expenses were actual, necessary, reasonable, and justified, and should be

allowed in full.

NOTICE

32. No trustee or examiner has been appointed in these Chapter 11 cases. Notice

of this Application has been given to: (a) the United States Trustee; (b) counsel to the Debtors; and

(c) parties required to be given notice in the Administrative Order. In light of the nature of the relief

requested herein, Klett Rooney submits that no other or further notice is required.

NO PRIOR REQUEST

33. No prior request for the relief sought in this Application has been made to this

or any other court.

KRLSWIL:30436.1 9

WHEREFORE, Klett Rooney respectfully requests that the Court enter an order,

substantially in the form attached hereto: (i) granting the Application; and (ii) granting such further

relief as may be appropriate.

KLETT ROONEY LIEBER & SCHORLING A Professional Corporation

By: Ad -G. Landis (No. 3467) Jeffrey M. Carbino (No. 4062) The Brandywine Building 1000 West Street, Suite 1410 Wilmington, DE 19801 [email protected] [email protected]

Co-Counsel to Official Committee of Unsecured Creditors

Dated: March 26, 2002

KRLSWIL:30436.1 10



FANSTEEL, INC., et al., ) 02-10109 (JJF) )

Debtors. ) Jointly Administered ) ) Hearing Date: (Only if Objections Are Received) ) Objection Deadline: April 15, 2002 at 4:00 p.m.

CERTIFICATION

Adam G. Landis, an attorney-at-law, duly admitted and in good standing to practice

in the States of Delaware and New York, the Commonwealth of Massachusetts, the United States

District Courts for the Southern District of New York, the Eastern District of New York, the District

of Delaware, and the United States Court of Appeals for the Third District, hereby certifies that:

1. I am a Shareholder of Klett Rooney Lieber & Schorling, a Professional

Corporation, ("Klett Rooney"). Klett Rooney was retained by the Official Committee of Unsecured

Creditors as co-counsel pursuant to an order of this Court. This certification is made in support of

the First Monthly Application of Klett Rooney Lieber & Schorling, Co-Counsel to the Official

Committee of Unsecured Creditors, for Compensation and Reimbursement of Expenses Pursuant

to 11 U.S.C. §§ 330 and 331 dated March 26, 2002 (the "Application") and in compliance with

Local Rule 2016-2 of this Court, setting forth the Contents of Application for Compensation and

Expenses (the "Guidelines").

KRLSWIL:30436.1

2. I have read the Application and I certify that the Application complies with

the Guidelines.

KLETT ROONEY LIEBER & SCHORLING A Professional Corporation

By:Adam G. Landis (No. 3407) Klett Rooney Lieber & Schorling A Professional Corporation Two Logan Square, 12 th Floor Philadelphia, PA 19103 Tel. (302) 552-4200 Fax: (302) 552-4295

Co-Counsel to the Official Committee of Unsecured Creditors

Dated: March 26, 2002

KRLSWIL:30436.1 2

EXHIBIT A

Name of Professional Position with Klett Rooney Hourly Total Total Individual and Year of Obtaining Billing Billed Compensation

License(s) to Practice Rate Hours Adam Landis Shareholder, admitted DE 355/hr. 57.2 $20,306.00

1995, NY 1992 and MA 1992

Jeffrey Carbino Associate, admitted PA 1994, 240/hr. 16.0 $3,840.00 TN 1992, NJ 1997, admitted DE 2001.

Denise Adamucci Associate, admitted PA and NJ 165/hr. 30.3 $4,999.50 1998, not admitted in DE

Mark Owens Associate, admitted PA 1999, 150/hr. .7 $105.00 not admitted in DE

Kerri K. Mumford Associate, admitted PA 2001, 140/hr. 3.5 $490.00 not admitted in DE

Kathleen P. Makowski Associate, admitted PA 1996, 190/hr. .5 $95.00 admitted DE 1997

Frances Panchak B.A. Widener University - 120/hr. .5 $60.00 Associate Degree - Paralegal Studies

Patricia Jackson B.S. Rutgers University 120/hr. 2.0 $240.00 Raelena Taylor A.A.S. Widener University 120/hr. 1.1 $132.00 Barbara Rost Legal Assistant 80/hr. 1.2 $96.00 Maryann Zickgraf Legal Assistant 80/hr. 1.1 $88.00

Grand Totals: 114.1 $30,451.50

KRLSWIL:30436.1

FANSTEEL, INC. EXHI-BIT "B" SUMMARY SHEET January 28, 2002 Through and Including February 28, 2002

KRLSWIL:30436.1

PROJECT BILLING HOURS VALUE

CATEGORY

Business Analysis .9 $126.00

Case Administration 33.6 $9,265.00

Claims Administration 3.2 $783.00

Fee/Employment Applications 49.7 $11,324.00

Fee/Employment Objections 1.6 $192.00

Financing 8.5 $2,868.00

Meeting of Creditors 16.6 $5,893.00

TOTAL 114.1 $30,451.50

TOTAL COMPENSATION DUE: $30,451.50

TOTAL HOURS: 114.1

BLENDED RATE: $266.88

KLETT RooNEY LIEBER & SCHORLING A PROLESSIONA1L COZ.PORATION

40TH FLOR, ONE 021ORD I•) TIL PiS-URGH, EINNSYLVANIA 152 194-98

TELEPHONE (412) 392-.000 FACSIML-S (412) 392-2128

COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER P0810-005 INVOICE 134184

PROFESSIONAL SERVICES RENDERED THROUGH: 02/28/02

BUSINESS ANALYSIS

AL

DATE ATTY

Z/27/02 KKM

Z/27/02 KKM

2/27/02 KKM

2/27/02 KKM

2/27/02

2/27/02

2/27/02

2/28/02

KKM

KIK4

KKM

DESCRIPTION OF SERVICES RENDERED

REVISE STIPULATION TO EXTEND TIME TO FILE SCHEDULES

REVIEW EMAILS RE: STIPULATION TO EXTEND TIME TO FILE SCHEDULES

REVIEW STIPULATION TO EXTEND TIME TO FILE SCHEDULES

CALL TO ROSALIE SPELMAN RE: STIPULATION TO

EXTEND TIME TO FILE SCHEDULES

CALL TO JC RE: STIPULATION AND CHANGES

EMAIL TO ROSALIE AT PACHRULSKI RE: STIPULATION TO EXTEND TIME TO FILE SCHEDULES

VM FROM ROSALIE SPELMAN RE SCHEDULES

CALL FROM MARLENE RE- STIPULATION TO EXTEND TIME TO FILE SCHEDULES

TIME SUMMARY

RATE HOURS

K K MUMFORDTOTALS

140.00 .90 .90

TOTAL FEES :

DELAWARE * NEW JERSEY * WASHINGTON D.C.

OFFICIAL

FOR

RE:

HOURS

.10

.10

.20

.10

.10

.10

.10

.10

TOTALS

126.00 126.00

126.00

PENNSYLVANIA a

KLETT ROONEY LIEBER & SCHORLING A PROFESSIONAL CORPORATION

40MH FLOOR, ONE OXFORD CENTRE PITTSBURGH, PBNNYLVANIA 15219-6498

ITLEPHONE (412) 392-2000 ]ACSIMILE (412) 392,2128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER F0810-005 INVOICE : 134184

FOR PROFESSIONAL SERVICES RENDERED THROUGH: 02/28/02 AL

RE: BUSINESS ANALYSIS

TOTAL DUE : 126.00

NDELAWARE 0 NEW JERSEYPENNSYLVANIA o 0 WASHINGTON D.C.


40TH FLOOR, ONE OXFORD CENTRE PITTSBURGH, PENNSYLVANIA 15219-6498

TELEPHONE (412) 392-2000 FACSIMME (412) 39-2,1Z8

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MATTER INVOICE

FOR PROFESSIONAL SERVICES RENDERED THROUGH: 01/31/02

RE: CASE ADMINISTRATION

DATE ATTY

1/29/02 AGL

1/29/02 AGL

1/30/02 AGL

1/30/02 JMC

1/30/02 JMC

1/30/02 JMC

MARCH 4, 2002 F0810-007 134183

A L


REVIEW ALL FIRST DAY PLEADINGS AND PAPERS (3.4); CALENDAR UPCOMING HEARING DATES (.4);

TELEPHONE CALLS WITH SABIN AND JONES RE: COMMITTEE REPRESENTATION (.3); CONFERENCES WITH CARBINO RE: ASSIGNMENTS GOING FORWARD (.3)

CONFERENCES WITH CARBINO AND ADAMUCCI RE: ASSIGNMENTS AND ISSUES (.6); TELEPHONE CALL WITH GECRER RR: RECENT DEVELOPMENTS REVIEW A:TD REVISE MEMO TO COMMITTEE RE: MATERIALS (.4); TELEPHONE CALL TO UST (.1) AND DALUZ RE: CASE ISSUES (.1); REVIEW AND REVISE MEMO TO COMMITTEE RE: MATERIALS (.6); REVIEW AND REVISE CONTACT LIST (.3); CONTINUE REVIEW OF DEBTORS' CORPORATE AND CREDITOR STRUCTURE (2.1)

TELEPHONE CALLS WITH PETER CLARK RE: COMMITTEE FORMATION ISSUES

ATTEND COMMITTEE CONFERENCE CALL REGARDING BYLAWS, PINANCIAL ADVISORS, POTENTIAL OBJECTIONS TO PENDING.MOTIONS

REVIEW PLEADINGS TO PREPARE FOR CONFERENCE CALL: DIP MOTION, ACCOUNTS RECEIVABLE SALE AND BIDDING PROCEDURES MOTION, CRITICAL VENDORS MOTION

PREPARE LIST OF DEADLINES FOR FILING OBJECTIONS AND LIST OF UPCOMING CRITICAL/HEARING DATES

HOURS

4.40

4.20

.40

2.20

1.40

.40

DELAWARE 0 NEW -RSWSNEY

t

PENN$SYLVANIIA 0 WASHI3NGTON D.C.

KLETT ROONEY LiEBER & SCHORLING A [ROPESSIONAL CORPORATION

4MT1 PLOOR, ONE OXFORD CENTM P1TTSrVRGH, PENNSYLVANUA 15219-6498

"TEL•IPONI (412) 39272000 FACSIUM1A1 (412) 392-2128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE ; MATTER INVOICE



.130/02 MRO

L/31/02 AGL

L/31/02 JMC

MARCH 4, 2002 F0P10-007 134183

A.L

PREPARATION OF MOTIONS FOR ADMISSION PRO HAC VICE FOR FRANCES GECKER AND JOSEPH FRANK. ALSO, PREPARATION OF AN ENTRY OF APPEARANCE FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS.

TELEPHONE CALL WITH GECKER RE: CASE STATUS AAD ASSIGNMENTS

PREPARE DETAILED MEMORANDUM TO INTERPRETING THE DEBTORS' AUCTION SALE MOTION RE ACCOUNTS RECEIVABLE, APPLICATION TO EMPLOY LINCOLN PARTNERS AS INVESTMENT BANKERS AND CRITICAL VENDORS MOTION; RAISING ISSUES AND POTENTIAL BASES FOR OBJECTION, NECESSITY FOR SPECIFIC INFORMATION AND PROCEDURAL ADVICE

.70

-50

7.90

TIME StUMMARy

RATE HOURS

A G LANDIS J M CARBINO M R OWENS

TOTALS

355.00 240.00 150.00

9.50 11.90

.70 22.10

TOTAL FEES

TOTAL DUE

E DELAWARE * NEW JERSEY

TOTALS

3372.50 2856.00

105.00 6333.50

6,333.50

6,333.50

I

PENNSYLVANIA & WASMINGTON D.C-


40TH FLOOR, ONE OXFORD CENTIlE pITTsURGH, PENNSYLVANIA I5Z19-6498

TELEPHONE (412) 39242000 FACSfUAT- (412) 392-212.8

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE ; MARCH 18, 2002 MATTER F0810-007 INVOICE 134182

FOR PROFESSIONAL SERVICES RENDERED THROUGH; 02/28/02


DATE ATTY

:/04/02 AGL

!/04/02 KKM

!/o5/02 KKM

1/06/02 AGL

>/07/02 AGL

ý/07/02 AGL

2/07/02 AGL

2/07/02 KKM

2/07/02 KKM

2/07/02 MMZ

2/08/02 AGL

2/11/02 AGL


REVIEW COMMITTEE BYLAWS AND FORM OF MINUTES OF 1/30 MEETING

MEET W/AGL RE: CASE ASSIGNMENT

MEET W/AGL AND BR RE: NOTICES AND HEARING DATES

REVIEW UPDATED CONTACT LISTS AND CALENDAR OF UPCOMING EVENTS

ATTEND HEARING

TELEPHONE CALL WITH GECKER RE: HEARING AND COMMITTEE OBJECTION ISSUES (.3); TELEPHONE CALLS TO SABIN AND BROUDE RE: COMMITTEE OBJECTION ISSUES

MEETING WITH BROUDE RE: VARIOUS ISSUES IN CASE

MEET W/AGL RE: ENTRY OF APPEARANCE AND PRO HACS

DRAFT ENTRY OF APPEARANCE; PREPARE FOR FILING

PREPARATION FOR, FILE AND SERVE NOTICE OF APPEARANCE WITH DISTRICT COURT (0.9); CORRESPONDENCE TO COUNSEL RE SAME (0.2).

REVIEW AND REVISE CONFIDENTIALITY STIPLUTATION" AND E-MAILS TO AND FROM GECKBR RE: SAME

E-MAILS TO AND FROM AND TELEPHONE CALLS WITH GECKER RE: OBJECTION DEADLINE AND ADJOURNMENT/SETTLEMENT ISSUES

N DELAWARE * NEW JERSEY

AL

HOURS

.30

.10

.10

.50

.70

.30

.(50

.10

.40

1.10

1.10

.30

0 WASHINGTON D.C.PENNSYLVANIA

KLETTL ROONEY LIEBER & SCHORLING A PPOFSSlONAL CORPORATION

40TH FLOOR. ONE OXFORD CENTRE ?rrTSBURtO, PINNSYLVANUA 1219-649a

TELSPHONE (412) 3924000 FACSMIL. (412) 392,.126

)FFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER F0810-007 INVOICE 134182



/13/02 AGL

/14/02 AGL

/14/02 JMC

/14/02

:/14/02

'/14/02

!/14/02

ý/14/02

J1/l0/2

KKM

KKM

KKM

K(KM

KKA

AGLJ

ý/15/02 PAP

a/18/02 JMC

2/18/02

2/19/02

2/19/02

2/20/02

RTT

KKM

RTT

AGL

REVIEW AGENDA LETTERS AND LETTERS TO COURT RE: HEARING CANCELLATIONS/ADJOURNMENT S

REVIEW AND REVISE CRITICAL DATES MEMO AND COMPARE SAME WITH PACHULSKI'S

FOLLOW-UP WITH K. MUMFORD ON PRO HACS FOR CO- COUNSEL

EMAIL FROM JC RE: PRO HACS

MEET W/BR RE: CERT. FOR PRO HACS; EMAIL JC RE: SAME

CALL FROM CO-COUNSEL RE: PRO MACS

MEET W/BR RE: PRO HACS

CALL TO FRANCES G. RE: PRO HACS

E-MAILS TO AND FROM GROUP RE: SCHEDULING MEETINGS WITH DEBTORS AND COUNSEL

ACCESS WEBSITE, DOWNLOAD UPDATED DOCKET FROM DISTRICT COURT AND REVIEW.

REVIEW MOTION FOR RECONSIDERATION OF CRITICAL VENDOR MOTION AND ATTEMPT TO IDENTIFY TOTAL CLAIMS

REVIEW AND ORGANIZE' PLEADINGS

MEET W/AGL AND BR TO DISCUSS PRO HACS

REVIEW AND ORGANIZE PLEADINGS FILE

"TELEPHONE CALLS TO AND FROM BROUDE RE: CASE ISSUE

DELAWARE NEW JERSEY o WASHINGTON D.C.

AL

.20

.50

.10

.10

.10

.10

.10

.10

.30

.10

.50

.10

.10

.20

.50

PENNSYLVANIA

KLETr ROONEY LIEBER & SCHORLING A PROnES$ONAL CORPORATION

40Th FLOOR, ONE OXFORD CENTRE P1TrSBURcG-, PENNSYLVANIA 1S219-6498

"TELEPHONE (41Z) 39=2000 FACSIMILE (422) 39-21-28

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE . MARCH 18, 2002 MATTER : F0.810-007 INVOICE 134182



/20/02 PJ

/21/02 AGL

./21/02

:/25/02

RTT

JMC

ý/25/02 JMC

!/26/02 K"M

!/26/02 KKM

!/26/02 RTT

Z/28/02 RTT

CORRES TO CO-COUNSEL VIA FEDERAL EXPRESS RE CLOCKED COPY OF MTN FOR RECONSIDERATION RE: CRITICAL VENDORS

TELEPHONE CALL WITH GECXER RE: CASE ISSUES AND UPCOMING HEARINGS

REVIEW AND ORGANIZE PLEADINGS FILE

RECEIPT AND REVIEW OF COMMITTEE MEETING NOTES IN PREPARATION FOR COMMITTEE CONFERENCE CALL

CALL TO DEBTOR'S LOCAL COUNSEL RE SCHEDULING ISSUES FOR 2/28 HEARING

VM AND EMAIL FROM JC RE: STIPULATION

CALL W/JEFF C. RE: STIPULATION

REVIEW SEVERAL NOTICE OF APPEARANCES AND UPDATE 2002 LIST

TELEPHONED ANICE WALKER @ AMERICAN NATIONAL BANK IN RE: CHANGE OF ADDRESS FOR SUSAN KRUESI AND MARC FENTON(.1); (.3) REVIEW AND UPDATE 2002 LIST

DELAWARE e NEW JERSEY * WASHINGTON D.C.

AL

.50

.50

.20

-30

.10

.10

.10

.20

.40

PENNSYLVANIA

KLETT RooNEY LIEBER & SCHORLING A PROFBSSIONAL CORPORATION


TELEPHONE (412) 392-2000 FACSIM."E (412) 392-ZIZ$

DFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MATTER INVOICE

FOR PROFESSIONAL SERVICES RENDERED THROUGH- 02/28/02


TIME SUMMARY

RATE HOURS

LANDIS 355.00 5.80 2 PANCHAK 120.00 .10 CARBINO 240.00 1.00 MUMFORD 140.00 1.50 ZICKGRAF 80.00 1.10 JACKSON 120.00 .50 TAYLOR 120.00 1.10

TOTALS 11.10

MARCH 18, 2002 FO810-007 134182

AL

TOTALS

:059.00 12.00

240.00 210.00 88.00 60.00

132.00 2801.00

TOTAL FEES 2,801.00

2,801.00TOTAL DUE

DELAWARE * NEW JERSEY

A F J K M P R

G A M K M A T

PENNS'YL[VANIA e 0 WASHINGTON D.C.

KLETT ROONEY LiEBER & SCHORLING A PROFESSIONAL CORPORATION

40TH FLOOR, ONE OXFORD CENTRE PITTSBURGH, FENNSYLVANIA 15Z19,4498

TEL•IPHONE (41Z) 3922000 FACSIMILE (412) 392-ZIZS




DATE ATTY DESCRIPTION OF SERVICES RENDERED --------- ---- ---------------------- m-----------

2/11/02 AGL

2/28/02 JMC

MAI;CH 18, 2002 F0810-007 134185

AL

HOURS

E-MAILS TO AND FROM GECKER RE: CONFIDENTIALITY AGREEMENT (.1); REVIEW AND EXECUTE SAME (.2)

RECEIPT MEETING

.30

.10AND REVIEW OF NOTICE OF RESCHEDULED 341

TIME SUMMARY

RATE

A G LANDIS LJ M CARBINO

TOTALS

355.00 240.00

TOTAL FEES

TOTAL DUE

DELAWARE * NEW JERSEY

HOURS

.30

.10 .40

TOTALS

106.50 24.00

130.50

130.50

130.50

PENNSYLVANIA 0 & WASHIfNGTON D.C.

KLETT ROONEY LIEBER & SCHORLwNG A PROFBSSIONAL CORPORATION

40TH FLOOR, ONE OXFORD CNITRE PITTSBURGH, ?BWNSYLVANIA 15219.6498

TELEPHONE (412) 392.2000 FACSDI).LE (412) 392-2128

DFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MATTER INVOI CE


RE: CLAIMS ADMINISTRATION

DATE ATTY DESCRIPTION OF SERVICES RENDERED

/18/02 AGL

/19/02 PJ

:/21/02 AGL

REVIEW AND REVISE MOTION TO RECONSIDER CRITICAL VENDORS ORDER

DISCUSSION OF AGL RE: FILING AND SERVICE OF MOTION TO RECONSIDER ORDER TO PAY PREPETITION CRITICAL VENDOR CLAIMS (.2); DRAFT/REVISE NOTICE RE: SAME (.5); FILE AND SERVE SAME (.8)

TELEPHONE CALLS WITH BROUDE RE: CRITICAL VENDORS AID MOTION TO RECONSIDER (-3)

MARCH 18, 2002 F0810-008 134186

AL

HOURS

1.40

1.50

.30

TIME SUMMARY

RATE HOURS

A G LANDIS P A JACKSON

TOTALS

355.00 L.70 120.00 1.50

3.20

TOTAL FEES

TOTAL DUE

N DELAWARE o NEW JERSEY

TOTALS

603.50 180.00 783.50

783.50

783.50

PENNSYLVANIA 0 WASHINGTON D.C.

KLETT RooNEY LEBER & SCHORLING A PROFESSIONAL CORPO"&TION

40TH FLOOR. ONE OXFORD CENTRE PITTSBURGH, PENNSYLVANIA 15Z19-6498

TELEPHONE (412) 3924000 FACSD41LE (412) 3924-128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE MATTER INVOICE


RE: FEE/EMPLOYMENT APPLICATIONS

DATE ATTY DESCRIPTION OF SERVICES RENDERED

./29/02 DA

./30/02 DA

./31/02 AGL

-/31/02 DA

COMMUNICATIONS WITH ADAM LANDIS (.1); PREPARATION OF RETENTION DOCUMENTS (.2)

PREPARATION OF RETENTION APPLICATION (.7); PREPARATION OF ORDER RE: SAME (.3), PREPARATION OF AFFIDAVIT RE: SAME (.5); PREPARATION OF NOTICE RE: SAME (.2)

REVIEW AND REVISE APPLICATION TO RETAIN KRLS (.9); REVIEW AND REVISE LANDIS AFFIDAVIT (1.2);

TELEPHONE CALL WITH ADAMUCCI RE: SAME (.1)

COMMUNICATION WITH COURT (.2); ANALYSIS OF DOCKETS FOR DISTRICT AND BANKRUPTCY COURTS (.4); COMMUNICATION WITH ADAM LANDIS' OFFICE (.4); REVISIONS TO RETENTION DOCUMENTS (1.6)

MARCH 4, 2002 FOSI0-010 134175

AL

HOURS

.30

1.70

2.20

2.60

TIME SUMMARY

A G LANDIS D ADAMUCCI

TOTALS

RATE HOURS

355.00 2.20 165.00 4.90

6.80

TOTAL FEES :

TOTAL DUE :

N * DELAWARE . NEW JERSEY

TOTALS

781.00 759.00

1540,00

1,540.00

1,540.00

PENNSYLVANIA 0 WASHINGTON D.C.

KLETT ROONEY LIEBER & SCHORLING A PROFMIESONAL CORPORATION

40TH FLOOR, ONE OXFORD CENTRE PITTSBURGH, PENNS'MVAN1A 15219-6498

TELEPHONE (41Z) 392-Zooo FACS34LE (412) 392-2128

)FFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER : FOS1O-010 INVOICE : 134187



DATE ATTY

/01/02 AGL

/01/02 AGL

/01/02 DA

/02/02 AGL

/02/02 DA

/04/02 AGL

/04/02 DA

/04/02. KKM

:/04/02KKJM

:/04/02 KKM


REVIEW AND REVISE AFFIDAVIT OF DISINTERESTEDNESS

TELEPHONE CALLS AND E-MAILS TO AND FROM ADAMUCCI RE: RETENTION ISSUES

RESEARCH CASE LAW 5002 FOR MEMORANDUM (8.9; PREPARATION OF MEMORANDUM (1.9); COMMUNICATION WITH ADAM LANDIS (.1) REVIEW AND REVISE ADAMUCCI MEMO RE: RETENTION

ISSUES

PREPARATION OF MEMORANDUM RULE 5002

REVIEW AND REVISE AFFIDAVIT AND E-MAILS TO AND FROM KOPP AND GECKER RE: SAME

REVISIONS AND ADDITIONS TO MEMORANDUM RE: DISINTERESTEDNESS ISSUES

CALLS W/JC, MO AND MEET W/AGL RE: NOTICE OF

RETENTION

CMAL TO JC RE: NEGATIVE NOTICE

REVIEW NOTICES OF RETENTION APPLICATION; REVIEW DOCKET FOR HEARING DATES AND DEBTOR'S RETENTION APPLICATIONS

REVIEW EMAILS FROM JC AND AGL RE: RETENTION APPLICATIONS


AL

HOURS

.70

.30

10.90

.70

2.90

.70

6-90

.50

.10

.20

.10

PENN•SYLVANIA *

KLETIT ROONEY LIEBER & SCHORLING A PROn$S102AL CORPORATION

4OT• PLOOR, ONE OXFORD CBNTRE PITTSBURGH, PENNSYLVANIA 15219-6498

TELPHO1N (412) 392,2000 FACS(TKLE (412) 392-2128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER P0810-010 INVOICE 134187



!/04/o2 KPM

?/05/02 AGL

?/05/02

ý/08/02

2/08/02

Z/12/02

KKM

FAP

KKM

AGL

2/12/02 FAP

2/13/02 AGL

2/13/02 AGL

2/14/02 AGL

2/14/02 AGL

2/14/02 AGL

CONFERENCE WITH K. MUMFORD AMD A. LANDIS RE: NOTICE PROVISIONS FOR RETENTION APPLICATIONS

REVIEW AID REVISE NOTICES AND FORMS OF ORDER RE: RETENTION OF FREEBORN AND KLETT

CALL TO PACHULSKI RE: HEARING DATES

CORRESPONDENCE TO ACCOUNTING RE: PRE-BILLS

REVIEW EMAIL FROM AGL REt FEE APPLICATIONS

REVIEW APPLICATION TO RETAIN EARTH SCIENCES CORP (.4); MEMO TO FILE RE: SAME (.2)

REVIEW JANJUARY PRE-BILLS AND CORRESPONDENCE TO ACCOUNTING RE: SAME (.1); E-MAILS TO/FROM D. ADAMUCCI RE: SAME (.1)

REVIEW NAVIGANT FMAILS RE: RETENTION AND AFFIDAVIT (.2) AND E-MAILS TO AND FROM CARBINO RE: RETENTION OF NAVIGANT (.1)

TELEPHONE CALLS WITH ROSALIE SPELMAN RE: TERMS OF LINCOLN ORDER

REVIEW AND REVISE LINCOLN PARTNERS ORDER (.8); E-MAILS TO AND FROM SPELMAN AND GECKER RE: SAME (,3)

E-MAILS TO AND FROM SPELMAN RE: CHANGES TO ORDER APPROVING LINCOLN RETENTION

REVIEW NAVIGANT AFFIDAVIT (.4), ENGAGEMENT LETTER (.3) AND DRAFT PROPOSED REVISIONS TO

.SAME (.4)

DELAWARE o NEW JERSEY

AL

.50

.90

.10

.10

.10

.60

.20

.30

.20

1iI.0

.30

1.10

PENNSYLVANIA * 0 WASHINGTON D.C.

KLETT ROONEY LIEBER & SCHORLING A PROFsiONAL CoRtPoAntoN

40TH FLOOR. ONE OXFORD CENTRE PITTSBURGH, PENNSYLVANIA i5219-6498

TELEPHONE (412) 392-2000 FACSIMILE (412) 392-2128

)FFICIAL COMMITTEE OF UNSECURED CREDITORS DATE MARCH 18, 2002 MATTER F0810-010 INVOICE : 134187



AL

(14/02 DA

/14/02 JMC

/15/02 AGL

/15/02 AGL

/15/02 DA

/15/02 FAP

02

02

AGL

AGL

/20/02 AGL

/20/02 DA

ANALYSIS OF, AND REVISIONS TO AFFIDAVIT FOR RETENTION OF NAVIGANT (1)'; ANALYSIS OF, AND REVISIONS TO RETENTION LETTER FOR SAME (1); PREPARATION OF APPLICATION FOR SAME (2.1); PREPARATION OF PROPOSED ORDER FOR SAME (.3); PREPARATION OF RETENTION NOTICE FOR SAME (.2).

REVIEW AFFIDAVIT FOR NAVIGANT RETENTION; CONFERENCE WITH D. ADAMUCCI RE STATUS OF RETENTION APPLICATION

REVIEW UST OBJECTION TO RETENTION OF FREEBORN AND KLETT (1.0); TELEPHONE CALLS WITH FRANK AND GECKER RE: SAME (.5); REVIEW RESEARCH RE: 101(14) (.6)

LONG EMAIL TO KEN MALIK RE: CHANGES TO AFFIDAVIT AND ENGAGEMENT LETTER

ANALYSIS OF E MAIL COMMUNICATION (.2); REVISION TO APPLICATION RE: SAME (.1)

DISCUSSION WITH AGL RE: CERTIFICATES OF NO OBJECTION TO KIJLS' AND FREEBORN RETENTION APPLICATIONS

RESEARCH RE. CONFLICTS ISSUES

ADDITIONAL RESEARCH RE: DISINTERESTEDNESS ISSUE

TELEPHONE CALLS WITH PACKMAN (.2) AND DRAFT LETTER TO UST RE: AUTHORITY TO SPEAK TO COMMITTEE MEMBER (.2)

ANALYSIS OF R MAILS FROM ADAM LANDIS

DELAWARE s NEW JERSEY

4.60

.40

2 .10

.40

.30

.10

1.60

.80

.40

. WASAEINGTON D.C.PENNSYLVANIA 0


40TH PLOOR, ONE OXPORD CENTRE PITTOSURGH, PENNSYLVANIA 157194498

TELEPHONE (412) 392-2000 FACSIMILE (412) 392-2128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE ; MATTER INVOICE

MARCH 18, 2002 F0810-010 134187

FOR PROPESSIONAL SERVICES RENDERED THROUGH: 02/28/02


2/22/02 AGL

2/22/02 AGL

2/25/02 JMC

E-MAILS TO AND FROM MALEK AND GROUP RE: NAVIGANT RETENTION ISSUES (.2); REVIEW REVISED MALEK AFFIDAVIT AND RETENTION AGREEMENT

DRAFT SUPPLEMENTAL AFFIDAVIT (1) AND E-MAILS TO AND FROM GECKER AND KOPP RE- SAME

ATTEND COMMITTEE CONFERENCE CALL LINCOLN PARTNERS APPLICATION, A/R MOTION AND UPCOMING HEARINGS

TIME SUMMARY

A G LANDIS D ADAMUCCI F A PANCHAK J M CARBINO K K MUMFORD K P MAKOWSKI

TOTALS

325.00 165.00 120.00 240.00 140.00 190.00

TOTAL FEES z

TOTAL DUE :

N DELAWARE o NEW JERSEY

AL

.50

1.20

'90

RATE HOURS

13.90 25.70

.40 1.30 1.10

.50 42.90

TOTALS

4934.50 4240.50

48.00 312.00 154.00 95.00

9784.00

9,784.00

9,784.00

I

PENNSYLVANIA 0 WASEEINGTON D.C.


40TH FLOOR., ONE OXFORD CENTRE PITTSBURGH. PENNSYLVANIA 15219-6498

"TELEPHONE (412) 394-2000 FACSIMILD (412) 392,2128


FOR PROFESSIONAL SERVICES RENDERED THROUGHt 02/28/02

RE: FEE/EMPLOYMENT OBJECTIONS

DATE ATTY

/15/02 ,MC

/18/02 BR

MARCH 18, F0810-QII 133920

AL

DESCRIPTION OF SERVICES RENDERED -----------------------------------------

REVIEW US TRUSTEE OBJECTION TO RETENTION OF KRLS AND CO-COUNSEL

SEARCH PACER AND ECF FOR SAMPLE BRIEF IN REPLY TO OBJECTION TO KRLS RETENTION. PRINT OUT DOCKET.

TIME SUMMARY ----------------------

RATE HOURS

B ROST J M CARBINO

TOTALS

80.00 1.20 240.00 .40

1.60

TOTAL FEES

TOTAL DUE

N DELAWARE * NEW JERSEY * WAWHINGTON D.C.

2002

HOURS

.40

1.20

TOTALS

96.00 96.00

192.00

192.00

192,00

A-- _

PENNSYLVANIA

KLETTROONEY LIEBER & SCHORLING A PROYESSIONAL CORPORATION

4oTH FLOOR, ONE OXFORD CENTRE PITTSBURGH, PENNSYLVANIA 15219o6498

TELEPHONE (412) 392-2000 FACSIMILE (41Z) 392-2128

)FFICIAA COMMITTEE OF UNSECURED CREDITORS DATE . MATTER INVOICE

MARCH' 18, 2002 P0810-012 134188


RE: FINANCING

)ATE ATTY DESCRIPTION OF SERVICES RENDERED --------- ---- --------------------------------

/01/02 AGL

/03/02 AGL

/04/02 AGL

/05/02 AGL

/06/02 AGL

(07/02 AGL

/08/02 AGL

/15/02 JMC

/15/02 JMC

REVIEW CREDIT AGREEMENT AND FINAL ORDER AND MARK UP SAME (1.3); TELEPHONE CALLS WITH GECKER (.5) AND BROUDE AND LENDERS' COUNSEL RE: SAME (.9)

DRAFT MODIPICATIONS TO DIP ORDER

FINALIZE DRAFT RIDERS TO FINANCING ORDER (.4); TELEPHONE CALL WITH PROUDE AND GECKER RE: SAME (.2)

REVIEW DIP ORDER AND TELEPHONE CALLS TO AND FROM BROUDE, GECKER AND MICHAELSON RE: COMMENTS TO SAME (.5)

E-MAILS TO AND FROM GECKER, BROUDE, MICHAELSON RE: FINAL DIP ORDER

REVIEW CONGRESS FINANCIAL PROPOSAL

REVIEW AND REVISE PROPOSAL LETTER AND E-MAILS TO AND FROM GECKER RE: SAME

REPORT TO A LANDIS ON CONFERENCE CALL RE DIP FACILITY

REVIEW OF MOTION FOR ORDER AUTHORIZING DUE DILIGENCE FEES AND RELATED CONGRESS FINANCIAL LETTER PROPOSAL AND PROPOSED FORM OF ORDER IN PREPARATION FOR COMMITTEE CALL REGARDING, AMONG OTHER ISSUES, THE DUE DILIGENCE FEES

NEW JERSEY * WASHINGTOND.C.

AL

HOURS

2,70

.70

.60

.60

.50

.70

1.10

-20

.70

PENNSYLV.ANLA e DELAWARX. *

KLETT ROONEY LIEBER & SCHORLING A PRoFESs1oNAL COkPORATION

4MTh FLOOR, ONE OXFORD CENT1" PITTS9URGH. PENNSYLVANIA 1S219-649s

TELEHON (412) 39212000 FACSIMILE (412) 392-128

)FFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MATTER INVOICE


RE: FINANCING

MARCH' 18, 2002 F0810-012 134188

AL

/15/02 JMC

/19/02 AGL

ATTEND CONFERENCE CALL WITH COMMITTEE CO-COUNSEL, FANSTEEL REP AND NAVIGANT FACILITY ISSUES

REVIEW CONGRESS FEE LIMITATION LETTER

TIME SUMMARY ----------------------

RATE HOURS

, G LANDIS I M CARPINO

TOTALS

355.00 7.20 240.00 1.30

8.50

TOTAL FEES

TOTAL DUE

N DELAWARE * NEW JERSEY

CHAIR, RE D-I-P

.40

.30

TOTALS

2556.00 312.00

2868.00

2,868.00

2,868.00

PENNSYLVANIA0 WASHINGTON D.C.

KLETT ROONEY LIEBER & SCHORLING A POP.Ess$oiAL CORPORATION 40TH FLOOR, ONI OXFORD CENTRE

PITTSBURGH. PENNSYLVANqlg 1219-6496 TELEPHONE (412) 392-2000. FACSOtILZ (412) 392-2128

OFFICIALj COMMITTEE OF UNSECURED CREDITORS DATE - MARCH 4, 2002 MATTER F0810-014 INVOICE 132494


RE: MEETINGS OF CREDITORS

AL

DATE ATTY

/30/02 AGL

/31/02 AGL

DESCRIPTION OF SERVICES RENDERED -------------------------

ATTEND COMMITTEE CONFERENCE CALL

REVIEW AND REVISE MEMO TO COMMITTEE RE:PENDING MOTIONS

TIME SUMMARY -------------------------------------

RATE HOURS

A G LANDISTOTALS

355.00 5.60

TOTAL FEES t

TOTAL DUE


HOURS

2.20

3.40

TOTALS

1988.00 1988.00

1,988.00

1,988.00

PENNSYLVANIA o



TEIEPHONE (412) 392,2000 FACSDIME (412) 392-2128

)FFICIAL COMMITTEE OF UNSECURED CREDITORS DATE - MARCH 18, 2002 MATTER F0810-014 INVOICE 134179

FOR PROFESSIONAL SERVICES RENDERED THROUGH: 02/28/02 .A L

RE: MEETINGS OF CREDITORS

DATE ATTY

/04/02 AGL

/07/02

/07/02

/13/02

/14/02

/19/02

AGL

AGL

AGL

AGL

AGL

/19/02 AGL

DESCRIPTION OF SERVICES RENDERED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

ATTEND BY CONFERENCE CALL COMMITTEE MEETINGS WITH FINANCIAL ADVISORS AND DEBTORS


REVIEW AGENDA FOR COMMITTEE MEETING, NAVIGANT DOC REQUEST FOR MEETING

REVIEW MINUTES OF COMMITTEE MEETING


REVIEW COMMITTEE MEETING MINUTES AND AGENDA MEETING


TIME SUMMARY

RATE HOURS

k G LANDISTOTALS

355.00 11.00 11.00

TOTAL FEES :

TOTAL DUE 3,905.00

DELAWARE * NEW JERSEY WAHNGTON D.C.

HOURS

6.00

1.20

.60

1.50

.20

1.40

TOTALS

3905.00 3905.00

1 3,905.00

PENNSYLVANIA 9

FANSTEEL, INC. EXHIBIT "C" EXPENSE SUMMARY SHEET January 28, 2002 Through and Including February 28, 2002

EXPENSE BILLING CATEGORY VALUE

Telecopy Expenses $28.64

Reproduction of Documents $52.60

Messenger Services $120.00

Computer Research $185.35

Duplicating Services $3,668.83*

TOTAL $4,055.42

*Note: Klett Rooney has voluntarily reduced the total amount sought for expenses incurred to reflect a rate of 15 cents per copy for printing and duplication.

KRLSWIL:30436.1 5

KLETT RooNEY LIEBER & SCHORLING A PROMSIONAL CORPORATION

40M11 FLOOR, ONE OXFORD CENTRE PITTSBURGH, PENNSYLVANIA 15219-6498

TELEPHONE (412) 392-2000 FACSNILE (412) 392-2128

OFFICIAL COMMITTEE OF UNSECURED CREDITORS DATE : MARCH 18, 2002 MATTER F0gl0-001 INVOICE 133912

FOR PROFESSIONAL SERVICES RENDERED THROUGH: 02/28/02 A L

RE: FANSTEEL, INC. BANKRUPTCY EXPENSES

DESCRIPTION OF EXPENSE ADVANCES AMOUNT

REPRODUCTION OF DOCUMENTS TELECOPY EXPENSES MESSENGER SERVICES DUPLICATING SERVICES - FANTSTEEL, - DELAWARE DOCUMENT IMAGING DUPLICATING SERVICES - FANSTEEL - DELAWARE DOCUMENT IMAGING DUPLICATING SERVICES - FANTSTEEL - DELAWARE DOCUMENT IMAGING DUPLICATING SERVICES - FANSTEEL - DELAWARE DOCUMENT IMAGING DUPLICATING SERVICES - FANSTEEL - DELAWARE DOCUMENT IMAGING COMPUTER RESEARCH-ADAMUCCI-2/1/02 COMPUTER RESEARCH-ADAMUCCI-2/4/02 DUPLICATING SERVICES - DELAWARE DOCUMENT IMAGING COMPUTER RESEARCH-ADAMUCCI-2/4/02

TOTAL EXPENSE ADVANCES

TOTAL DUE

52.60 28.64

120-00 143.05

873.28

443.43

263.67

1369.69

40.00 50.60

575.71

94.75

4,055.42

4,055.42

DELAWARE * NEW JERSEY o WASHINGTON D.C.PENNSYLVANIA o


In re: Chapter 11

FANSTEEL INC., et al., 02-10109 (JJF)

Debtors. (Jointly Administered)

AFFIDAVIT OF PATRICIA A. JACKSON, PARALEGAL

STATE OF DELAWARE: SS:

NEW CASTLE COUNTY:

I, Patricia A. Jackson, certify that I am, and at all times during the service of process, have been, an employee of Klett, Rooney, Lieber and Schorling, P.C., not less than 18 years of age and not a party to the matter concerning which service of process was made on March 26,2002. I certify further that the service of the attached:

NOTICE OF FIRST MONTHLY FEE APPLICATION

FIRST MONTHLY APPLICATION OF KLETT ROONEY LIEBER & SCHORLING, CO-COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS,

FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM JANUARY 28, 2002 THROUGH FEBRUARY 28, 2002

was made on the following parties on the attached list by Hand Delivery (City of Wilmington addresses only) and by First Class United States M il, postage prepaid, o 11 others.

S NiW N SB Etricia A. Ja c kson

SWORN AND SUBSCRIBED before me this 26t0 day of March, 2002.

KRLSWIL:30552.1

FANSTEEL, INC. et al. Fee Application Service List

Via Hand Delivery:

David L. Buchbinder, Esquire Office of the United States Trustee J. Caleb Boggs Federal Building 844 King Street, Suite 2313 Lockbox 35 Wilmington, DE 19899-3519

Laura Davis Jones, Esquire Rosalie L. Spelman, Esquire Pachulski, Stang, Ziehl, Young & Jones, PC 919 Market Street, 16t' Floor P.O. Box 8705 Wilmington, DE 19899-8705 Co-Counsel to Debtors

Via First Class Mail:

Jeffrey S. Sabin, Esquire Mark A. Broude, Esquire Schulte, Roth & Zabel LLP 919 Third Avenue New York, NY 10022 Co-Counsel to Debtors

Frances Gecker, Esquire Joseph D. Frank, Esquire Freeborn & Peters 311 South Wacker Drive, Suite 3000 Chicago, IL 60606-6677 Co-Counsel to Official Committee of Unsecured Creditors

Robert Michaelson, Esquire Kirkpatrick & Lockhart Henry W. Oliver Building 535 Smithfield Street Pittsburgh, PA 15222 Counsel to Postpetition Lenders

Fansteel, Inc. Attn: Gary L. Tessitore Number One Tantalum Place North Chicago, IL 60064

KRLSWIL:30553.1