Objections to Price and Associates Fee Applications€¦ · through June 30, 2011 and Memorandum of Law [DK 1890] ("Final Fee Application") (collectively, the "Fee Applications")

IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

In re: § § MILLENNIUM MULTIPLE § EMPLOYER WELFARE BENEFIT § Case No. 10-13528 PLAN, § (Chapter 11) § Debtor. §

CORRECTED OBJECTIONS BY THE PLAN COMMITTEE OF THE MILLENNIUM MULTIPLE EMPLOYER WELFARE BENEFIT PLAN TO

THE APPLICATIONS FOR ALLOWANCE OF COMPENSATION AND REIMBURSEMENT OF EXPENSES FILED BY

PRICE & ASSOCIATES, LLC Pursuant to Section 14.9 of Debtor's Third Amended Chapter 11 Plan of

Liquidation, as Modified, the Plan Committee ("Plan Committee") of The

Millennium Multiple Employer Welfare Benefit Plan ("Debtor" or the "Plan")

submits these objections to the Corrected First, Second, Third, and Fourth

Monthly Applications for Allowance of Compensation and Reimbursement filed

by Price & Associates, LLC ("P&A"), special counsel to the Official Committee

of Unsecured Creditors ("Committee") covering the periods June 25, 2010 through

December 31, 2010 and Memorandum of Law [DK 646, DK 647, DK 648 and

DK 783], and the Second [sic] and Final Application for Allowance of

Compensation and Reimbursement filed by P&A For the Period January 1, 2011

Case: 10-13528 Doc: 1955 Filed: 08/18/11 Page: 1 of 17

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1013528110819000000000004

Docket #1955 Date Filed: 8/18/2011

through June 30, 2011 and Memorandum of Law [DK 1890] ("Final Fee

Application") (collectively, the "Fee Applications").1

BACKGROUND

1. On June 9, 2010, the Debtor filed a voluntary petition for relief

under Chapter 11 of the Bankruptcy Code with the United States Bankruptcy

Court for the Western District of Oklahoma.

2. After its Chapter 11 filing, the Debtor remained in possession of its

assets pursuant to 11 U.S.C, §§ 1107(a) and 1108 as a debtor and debtor-in-

possession. The Plan Committee continued to operate the Plan pursuant to the

terms and conditions of the Plan's governing documents.

3. On June 16, 2011, the Court entered an Order Confirming Modified

Plan [DK 1567] that confirmed Debtor's Third Amended Chapter 11 Plan of

Liquidation, as Modified, filed June 7, 2011 ("Chapter 11 Plan") [DK 1243].

4. Under the terms of Debtor's Chapter 11 Plan, on the Effective Date

(July 1, 2011), the Plan Committee "shall cease operating and dissolve…;

provided, however, that notwithstanding said dissolution, the…Plan Committee

shall remain in existence and have standing for the purposes of …litigating…

1 As is stated on pages 6-7 of the Final Fee Application, P&A filed nine monthly applications, the first four of which it subsequently corrected, before filing its Final Fee Application. As the Final Fee Application includes detailed invoices that also are included in the fifth, sixth, seventh and eighth monthly fee application, the Plan Committee refers to the Final Fee Application as appropriate rather than referring back to the fifth through eighth applications separately.


Allowed Administrative Claims asserted by …the Committee's…professionals."

Chapter 11 Plan, § 14.9.

5. Pursuant to § 14.9 of the Chapter 11 Plan, the Plan Committee now

submits its objections to P&A's Fee Applications.

OBJECTIONS

6. There should be no question that all creditors to the estate –

Participants, covered employers, and insurance companies alike – have a common

interest in the Millennium Plan being considered tax-compliant. The only persons

who do not share that goal are the Litigants and their counsel because a large

portion of their alleged damages is based on their alleged exposure to tax

penalties. In light of the importance of the tax issues to the creditors, it was

essential that the Committee be represented by tax counsel that could act in their

interest. However, when seeking retention as special counsel to the Committee,

P&A failed to fully disclose to the Court its conflicts of interest, which clearly

have influenced the services it has provided (or has not provided) to the

Committee. That omission alone warrants a significant reduction in P&A's

requested fees.

7. The Plan Committee of the Debtor was familiar with Adria Price of

P&A from its representation of two Participants, Dr. and Mrs. White, and their

business, Diogenes Holdings, in a case pending in tax court against the Internal

Revenue Service. The Plan Committee had asked Dewey and LeBoeuf to assist

P&A with this case as part of its ultimately successful strategy to obtain a


comprehensive settlement with the IRS. The Plan Committee was also aware that

Ms. Price was representing certain Participants in audit proceedings with the IRS.

While it was not privy to what was being said in the audits, it assumed that P&A

was not undermining their clients by adopting the IRS's position that the Plan was

not compliant, and, of course, Ms. Price was opposed to the IRS in the tax court

case. Accordingly, it did not object to the Committee's choice of counsel.

8. However, Ms. Price failed to inform the Court of her prior

relationship with Mr. Malesovas, who was Co-Chair of the Committee and with

Lenny Vitullo, Mr. Malesovas' co-counsel in the various state tort actions. This

relationship apparently includes accepting direct referrals from them, and serving

as their co-counsel in the Passons case, one of the state tort actions now pending

before this Court. See, e.g., April 22, 2010 Deposition of Timothy Johnston in

Westfall, et. al v. Bevan, et. al at pp. 162-163 (testifying that Mr. Vitullo advised

him to hire Mr. Price as tax counsel to his company Chapter II) (excerpts attached

as Exhibit 1, hereto); July 13, 2010 Docket in Passons, et al. v. Aviva Life and

Annuity Co., et al, p. 1 (listing Adria Price as the first plaintiffs' counsel) (copy

attached as Exhibit 2, hereto). Ms. Price's representation in her Affidavit seeking

employment in this matter that "Price & Associates may have referred matters to

other professionals involved in this case, and it may have been referred matters by

such parties" but has no other connection to creditors or their attorneys is thus

misleading as best. Application for Entry of an Order Authorizing Employment of

Price & Associates, LLC, As Special Counsel for the Official Committee of


Unsecured Creditors, Nunc Pro Tunc to June 25, 2010 (filed July 19, 2010)[DK

189],2 Affidavit ¶¶ 5, 6 (emphasis added). See also id. at ¶ 6 (stating that P&A

represents eight groups of Plan participants and Covered Employers before the

Internal Revenue Service without also disclosing that it represents these same

persons as Litigants). Ms. Price should have disclosed these relationships, as well

as any formal or informal agreements between herself and Mr. Vitullo relating to

the referral of clients and/or her participation as co-counsel with them in tort

actions. Her failure to do so justifies a material reduction in the fees requested.

9. It is doubtful that the Debtor would have agreed to the retention of

P&A had it known of the troubling issues of conflict of interest and professional

conduct raised by Ms. Price simultaneously taking inconsistent positions regarding

the Millennium Plan and its tax status. For example, in the White tax court case,

Ms. Price argued, among other things, that the Millennium Plan was a valid

welfare benefit plan that complies with the requirements of Internal Revenue Code

§ 419A(f)(6), and she urged the United States Tax Court to so find as a matter of

fact and law. See Opening Brief for Petitioners, dated November 11, 2009, pp.

62-70 (excerpts attached as Exhibit 3, hereto). Conversely, as counsel of record in

the Passons tort case, Ms. Price endorses the view that the Millennium Plan is an

"insurance sales gimmick" that does not comply with the requirements of IRC

2 The Plan Committee was aware of the relationship between Diamond McCarthy and P&A because both represent the Whites. It assumed that the disclosure was meant to refer that relationship, not the relationship between Ms. Price and Mr. Vitullo.


§ 419A(f)(6). See Second Amended Complaint in Passons dated March 19, 2010,

pp. 27-28, 49, 51 (excerpts attached as Exhibit 4, hereto).

10. This Court has already found that the Committee was dominated by

the Litigants to the detriment of the non-Litigants. Now we know that the

Committee's tax counsel was an integral part of that problem. It is bad enough that

the non-Litigants were deprived of unbiased advice on tax issues, but now they are

being asked to pay for the Litigants' tax counsel.

11. The fact that the Litigants and P&A were unable to prevent the

Debtor from consummating the IRS settlement is not a mitigating factor for P&A.

Nor does it excuse P&A's participation in Diamond & McCarthy's breach of its

responsibilities under the Confidentiality Agreement which the Debtor insisted

upon precisely because of its concern about the Litigants' opposition to any

resolution of the tax issues.3 Ms. Price had reviewed the confidentiality

agreement, and P&A's time entries show that it knew that Diamond McCarthy

intended to file objections to Debtor's Disclosure Statement that revealed

confidential discussions with the Internal Revenue Service, and either consented to

or did nothing to stop that unauthorized disclosure.

12. Finally, the Plan Committee objects to specific P&A time entries for

services that were not reasonable or necessary, or which violate the United States

Trustee's Fee Guidelines. For example, Ms. Price has billed Debtor to review 3 As noted in its Objections to Diamond McCarthy, that firm disclosed in a pleading details of the settlement agreement in contravention of the Confidentiality Agreement.


matters (such as case law and the contents of Plan documents) as to which she

already had or should have had knowledge and expertise as lead counsel in the

White tax court case. Similarly, as evidenced by the Corrected [First] Monthly

Fee Application, she also billed Debtor for matters such as preparing her

employment application. Finally, Ms. Price has billed Debtor thousands of dollars

for leaving voice mail messages.

Conclusion

For the foregoing reasons, the Plan Committee urges the Court to make a

significant reduction in the fees sought by Price and Associates.

Dated: August 18, 2011 Respectfully submitted,

/s/ Katherine S. Kamen

KATHERINE S. KAMEN Admitted pro hac vice [email protected] Edward A. Scallet Admitted pro hac vice [email protected] Lars C. Golumbic Admitted pro hac vice [email protected] HISHAM M. AMIN Admitted pro hac vice [email protected] Groom Law Group, Chartered 1701 Pennsylvania Avenue, N.W. Suite 1200 Washington, D.C. 20006 Phone: (202) 857-0620 Fax: (202) 659-4503


CERTIFICATE OF SERVICE

I hereby certify that on the date of filing of Corrected Objections by the Plan Committee of the Millennium Multiple Employer Welfare Benefit Plan to the Applications for Allowance of Compensation and Reimbursement of Expenses filed by Price & Associates, LLC, I caused a true and correct copy of the above and foregoing instrument to be electronically filed through the CM/ECF System maintained by the U.S. Bankruptcy Court for the Western District of Oklahoma and understands that said CM/ECF System generated a "Notice of Electronic Filing" transmitting a true and correct copy of said filing to the following counsel for parties in this proceeding who consented to such electronic service. Regan Strickland Beatty on behalf of Creditor American General Life Insurance Company [email protected], [email protected], [email protected], [email protected] Elizabeth Berke-Dreyfuss on behalf of Creditor The Pasha Group [email protected], [email protected] Brandon C Bickle on behalf of Creditor A&S Masonry, Inc. d/b/a D&R Masonry [email protected], [email protected] Julie Brower on behalf of Creditor Milliman Inc. [email protected], [email protected],[email protected], [email protected], [email protected] Irena Damnjanoska on behalf of Creditor Aviva USA Corp. [email protected], [email protected], [email protected] Layla J Dougherty on behalf of Debtor Millennium Multiple Employer Welfare Benefit Plan [email protected], [email protected] Herbert M Graves on behalf of Creditor Expert Radiology Network, PA [email protected], [email protected] Joel C. Hall on behalf of Creditor The Pasha Group [email protected], [email protected] Robert J. Haupt on behalf of Creditor Republic Bank & Trust [email protected], [email protected], [email protected]


John B. Heatly on behalf of Creditor Penn Mutual Life Insurance [email protected], [email protected], [email protected] G. Rudy Hiersche on behalf of Creditor Scott Ridge [email protected], [email protected] William H. Hoch on behalf of Creditor American General Life Insurance Company [email protected], [email protected], [email protected], [email protected] John E. Howland on behalf of Creditor Guardian Life Insurance Company of America [email protected] R. Keith Johnston on behalf of Creditor Aviva USA Corp. [email protected], [email protected], [email protected], [email protected] Timothy Kline on behalf of Creditor Milliman Inc. [email protected], [email protected], [email protected] Kyung S Lee on behalf of Creditor Diamond McCarthy LLP [email protected], [email protected], [email protected] Fred A. Leibrock on behalf of Creditor Republic Bank & Trust [email protected], [email protected], [email protected] Erin K Lovall on behalf of Debtor Millennium Multiple Employer Welfare Benefit Plan [email protected], [email protected], [email protected], [email protected] Eric D Madden on behalf of Creditor Diamond McCarthy LLP [email protected], [email protected], [email protected], [email protected] John M Malesovas on behalf of Creditor A&S Masonry, Inc. d/b/a D&R Masonry [email protected], [email protected] Robert B Millner on behalf of Creditor American General Life Insurance Company [email protected] Stephen J. Moriarty on behalf of Creditor Aviva USA Corp. [email protected], [email protected]


Kiran A. Phansalkar on behalf of Creditor Committee Official Unsecured Creditors' Committee [email protected], [email protected], [email protected] Ivan J Reich on behalf of Creditor Covered Employers [email protected], [email protected], [email protected] G. Blaine Schwabe on behalf of Debtor Millennium Multiple Employer Welfare Benefit Plan [email protected], [email protected] Robert N. Sheets on behalf of Creditor Republic Bank & Trust [email protected], [email protected] Jeffrey E. Tate on behalf of Creditor The Pasha Group [email protected] Mark B. Toffoli on behalf of Creditor Charles J. Monier, Jr., M.D., LLC [email protected] U.S. Trustee [email protected] Anthony L. Vitullo on behalf of Creditor A&S Masonry, Inc. d/b/a D&R Masonry [email protected], [email protected], [email protected], [email protected] Richard D. White on behalf of Creditor A California LLC [email protected], [email protected] Additionally, a true and correct copy of the foregoing pleading was sent to all parties on the attached Updated Service List (as of June 28, 2011) by first class mail, postage prepaid, this 18th day of August, 2011.

/s/ Katherine S. Kamen Katherine S. Kamen


Anderson Kill & Olick LLP Rhonda D Orin & Matthew T Baskir 1717 Pennsylvania Ave NW Ste 200 Washington, DC 20006 Andrews Davis APC Mark B Toffoli 100 N Broadway Ave Ste 3300 Oklahoma City, OK 73102 Bailey & Bailey PC Johnathan M Bailey 230 Pereida St San Antonio, TX 78210 Baker Botts LLP Jack Kinzie & Ian E Roberts 2001 Ross Ave Dallas, TX 75201 Barber & Bartz Richard D White Jr 525 S Main Ste 800 Tulsa, OK 74103 Barber & Bartz David vonHartitzsch 525 S Main St Ste 800 Tulsa, OK 74103 Barnett, Kathryn E 1650 One Nashville Pl 150 Fourth Ave N Nashville, TN 37219 Bellingham & Loyd PC Janice D Loyd 620 N Robinson Ste 207 Oklahoma City, OK 73102-6217 Brown Sims PC Nelson Skyler & Tarush R Anand 1177 W Loop S 10th Fl Houston, TX 77027-9007

Burke, D Michael 1603 Cambridge Oaks Cir Houston, TX 77094 Chamberlain Hrdlicka White Williams & Martin C Larry Carbo III 1200 Smith St Ste 1400 Houston, TX 77002 Cohen & Grigsby PC William E Kelleher Jr 625 Liberty Ave Pittsburgh, PA 15222-3152 Conner & Winters LLP Kiran A Phansalkar & Crystal A Johnson 211 N Robinson Ave Ste 1700 Oklahoma City, OK 73102 Cox Smith Matthews Incorporated Carol E Jendrzey 112 E Pecan St Ste 1800 San Antonio, TX 78205-1521 Crowe & Dunlevy PC William H Hoch III & Regan Strickland Beatty 20 N Broadway Ste 1800 Oklahoma City, OK 73102 Crowe & Dunlevy PC Brandee L Bruening 20 N Broadway Ste 1800 Oklahoma City, OK 73102 Curti, Benjamin A 2228 W Zumwalt Tulare, CA 93274 Curti, Ken J 5849 W Elowin Dr Visalia, CA 93291


Curti, Phillip A 3235 Ave Ste 199B Tulare, CA 93274 Department of Labor, Employee Benefit Security Administration Office of Enforcement Director, Virginia Smith 200 Constitution Ave Ste 600 Washington, DC 20210 Dewey & LeBoeuf LLP George R Abramowitz & Mark Allison 1101 New York Ave NW Washington, DC 20005-4213 Dewey & LeBoeuf LLP Timothy Quaid Karcher 1301 Ave of the Americas New York, NY 10019 Diamond McCarthy LLP Eric D Madden & Brandon Lewis 1201 Elm St Ste 3400 Dallas, TX 75270 Diamond McCarthy LLP Kyung S Lee 909 Fannin Ste 1500 Houston, TX 77010 Douglas N Gould PLC Douglas Gould 6303 Waterford Blvd Ste 260 Oklahoma City, OK 73118 Dunham, Jeffrey Alan 10251 Vista Sorrento Pkwy No 200 San Diego, CA 92121 Epstein, Jeffrey 1015 Redcedar Ln Houston, TX 77094

Epstein, Pamela 1015 Redcedar Ln Houston, TX 77094 Fee Smith Sharp & Vitullo Anthony L Vitullo Three Galleria Tower 13155 Noel Rd Ste 1000 Dallas, TX 75240 Fellers Snider Blankenship Bailey & Tippens Stephen J Moriarty & Irena Damnjanoska & John B Heatly 100 N Broadway Ave Ste 1700 Oklahoma City, OK 73102 Franklin Skierski Lovall Hayward LLP Peter Franklin & Doug Skierski & Erin Lovall 10501 N Central Expressway Ste 106 Dallas, TX 75231 GableGotwals PC Brandon C Bickle Sidney K Swinson Mark DG Sanders 100 W 5th St Ste 1100 Tulsa, OK 74103-4217 Gilbert Russell McWherter PLC J Brandon McWherter 101 N Highland Ave Jackson, TN 38301 Gluckman, Thomas S 16 E 34th St 5th Fl New York, NY 10016 Gordon & Rees LLP Jeffrey K Work 1900 West Loop S Ste 1000 Houston, TX 77027


Gordon & Rees LLP Jeffrey D Cawdrey 101 W Broadway Ste 2000 San Diego, CA 92101 Goyak, John 6720 Via Austin Pkwy Ste 400 Las Vegas, NV 89119 Graves & Graves Attorneys at Law Herbert M Graves 8265 S Walker Ave Oklahoma City, OK 73139-9451 Gray Robinson PA Ivan J Reich 401 E Las Olas Blvd Ste 1850 Ft Lauderdale, FL 33131 Groom Law Group Will Wilder & Hisham Amin & Lars Golumbic & Katy Kamen & Edward Scallet 1701 Pennsylvania Ave NW Washington, DC 20006 Harrod & Harrod Chet Harrod & Rebecca H Harrod PO Box 2303 Monroe, LA 71207-2303 Hassoun, Basel 5617 Normandy Terr Oklahoma City, OK 73142 Hiersche Law Firm G Rudy Hiersche Jr 105 N Hudson Hightower Bldg Ste 300 Oklahoma City, OK 73102 Hoover Slovacek LLP Melissa A Haselden & Edward L Rothberg 5847 San Felipe Ste 2200 Houston, TX 77042

Hugh M Cunningham Inc c/o Dan Townsend 13755 Benchmark Dr Dallas, TX 75234 Internal Revenue Service Ogden, UT 20224 Internal Revenue Service Mailstop 5024 OKC 55 N Robinson Oklahoma City, OK 73102 Internal Revenue Service PO Box 21125 Philadelphia, PA 19114 Internal Revenue Service PO Box 21126 Philadelphia, PA 19114 Internal Revenue Service PO Box 7346 Philadelphia, PA 19101-7346 Internal Revenue Service 2970 Market St Mail Stop 5 Q30 133 Philadelphia, PA 19104-5016 Jack Nelson Jones Jiles & Gregory PA Randy Coleman 2800 Cantrell Rd Ste 500 Little Rock, AR 72202-2043 Jackson Lewis LLP Kathleen Barrow 1415 Louisiana Ste 3325 Houston, TX 77002-7360 Jesson, Juli c/o Christina Economou 370 S Main St Yuma, AZ 85364


John F Redwine 13155 Noel Rd Ste 1000 Dallas, TX 75240 Kane Russell Coleman & Logan PC Joseph A Friedman Jason B Binford 3700 Thanksgiving Tower 1601 Elm St Dallas, TX 75201 Khetpal, Vivek 1275 Mockingbird Ln Durant, OK 74701 Kline Kline Elliott & Bryant PC Timothy D Kline & Julie Brower 720 NE 63rd St Oklahoma City, OK 73105 Kurtzman Carson Consultants 2335 Alaska Ave El Segundo, CA 90245 Legal Reprographics Inc c/o Steven Beaver 13151 Stone Canyon Rd Poway, CA 92064-2175 Lewis, Lester 9821 Spring Hill Dr Anchorage, AK 99507 Little Pedersen Fankhauser LLP John J Little 901 Main St Ste 4110 Dallas, TX 75202 Malesovas, John 816 Congress Ave Ste 1265 Austin, TX 78701 Marcus & Cinelli LLP 2821 Wehrle Dr Ste 3 Williamsville, NY 14221

Maynard Cooper & Gale PC Lee E Bains Jr & Stephen C Jackson 1901 Sixth Ave N Ste 2400 Regions Harbert Plz Birmingham, AL 35203 Mee Mee Hoge & Epperson PLLP John W Mee III 50 Penn Place 1900 NW Expressway Ste 1400 Oklahoma City, OK 73118 Meyers, Larry J 2269 Horizons Dr Ooltewah, TN 37363 Mitchell Williams Selig Gates & Woodyard PLLC 5414 Pinnacle Point Dr Ste 500 Rogers, AR 72758-8131 Mock Schwabe Waldo Elder Reeves & Bryant G Blaine Schwabe & Gary A Bryant & Sarah Hall 211 N Robinson Two Leadership Sq 14th Fl Oklahoma City, OK 73102 Mulinix Ogden Hall Andrews & Ludlam APLLC Joel C Hall & Jeffrey E Tate 3030 Oklahoma Tower 210 Park Ave Oklahoma City, OK 73102 Office of the United States Trustee Charles E Snyder 215 Dean A McGee Fourth Fl Oklahoma City, OK 73102 Ogden Gibson Broocks Longoria & Hall LLP 711 Louisiana St 1900 Penzoil S Tower Houston, TX 77002


Okin Adams & Kilmer LLP Brian A Kilmer & John Meritt Crosby 3102 Maple Ave Ste 240 Dallas, TX 75201 Okin Adams & Kilmer LLP Matthew S Okin 1113 Vine St Ste 201 Houston, TX 77002 Oklahoma Insurance Department Ms Kim Holland Commissioner 3625 NW 56th St Ste 100 Oklahoma City, OK 73112-4511 Oklahoma Tax Commission Withholding Tax PO Box 26860 Oklahoma City, OK 73126-0860 Oklahoma Tax Commission PO Box 26850 Oklahoma City, OK 73126-0850 Oklahoma Tax Commission Legal Division 2501 N Lincoln Blvd Oklahoma City, OK 73194 Oklahoma Tax Commission PO Box 26920 Oklahoma City, OK 73126-0920 Pasha, Janet 5725 Paradise Dr Ste 1000 Corte Madera, CA 94925 Phillips Murrah PC Fred A Leibrock & Robert J Haupt & Robert M Sheets Corporate Tower 13th Fl 101 N Robinson Ave Oklahoma City, OK 73102

Price & Associates LLC Adria S Price PO Box 100 43 N Kringle Pl Santa Claus, IN 47579 Pryor Robertson Beasley & Smith PLLC Thomas E Robertson Jr PO Drawer 848 Fort Smith, AR 72902 Rattet Pasternak & Gordon Oliver LLP Robert L Rattet & Scott A Steinberg 550 Mamaroneck Ave Ste 510 Harrison, NY 10528 Reinhart Boerner Van Deuren sc R Timothy Muth 1000 N Water St Ste 1700 Milwaukee, WI 53202 Republic Bank & Trust PO Box 5369 Norman, OK 73070 Robert D Goldstein CPA 2603 Augusta Dr Ste 1100 Houston, TX 77057-5639 Robert J Haeger 11403 Seneca Forest Cir Germantown, MD 20876 Roberts Markel PC Gregg S Weinberg & David Mark Kriewaldt & Mark B Rabe 2800 Post Oak Blvd 57th Fl Houston, TX 77056 Rosenstein Fist & Ringold John E Howland Esq 525 S Main Ste 700 Tulsa, OK 74103


SecurePlan Administrators LLC PO Box 5369 Norman, OK 73070 Sonnenschein Nath & Rosenthal LLP Robert B Millner & Thomas Labuda Jr & Christoper D Soper 233 S Wacker Dr Ste 7800 Chicago, IL 60606 Soyka, James M 4658 White Oak Ln Raccine, WI 53403 Steinberg, Fred 3848 Fau Blvd Ste 200 Boca Raton, FL 33431 Stutzman Bromberg Esserman & Plifka Jacob L Newton & Steven A Felsenthal 2323 Bryan St Ste 2200 Dallas, TX 75201 T David Cowart 2000 McKinney Ave Ste 1900 Dallas, TX 75201 T Matera & Associates Inc c o Tom Matera 1518 Herbert St Downers Grove, IL 60515 The Department of Labor, Employee Benefit Security Administration Assistant Secretary, Phyllis C. Borzi 200 Constitution Ave Ste S-2524 Washington, DC 20210 The Johnson Firm PLLC Dale Ossip Johnson Esq PO Box 427 Cedar Park, TX 78630-0427

The Malesovas Law Firm John Malesovas 816 Congress Ave Ste 1265 Austin, TX 78701 Thompson & Knight LLP Marc E Grossberg & David Furlow 333 Clay St Ste 3300 Houston, TX 77002 Triplett, Marvin 1115 Gemini Ave Houston, TX 77058 Triplett, Rosalind D 1115 Gemini Ave Houston, TX 77058 Urquhart, Edward 8811 Westheimer Ste 206 Houston, TX 77063 US Attorneys Office Western Dist of OK 210 Park Ave Ste 400 Oklahoma City, OK 73102 US Department of Labor Ms Hilda Solis Secretary of Labor 200 Constitution Ave NW Washington, DC 20210 US Department of Labor Timothy Hauser Assoc Solicitor Plan Benefits Security Division 200 Constitution Ave NW Washington, DC 20210 Vartivarian, Shahe E c o Salpi Vartivarian 7777 Southwest Fwy Ste 610 Houston, TX 77074 Vartivarian, Shahe E 15655 Walkwood Dr Houston, TX 77079


Walters Bender Strohbehn Vaughan PC R Keith Johnston & David M Skeens & J Michael Vaughan 1100 Main St Ste 2500 City Center Sq Kansas City, MO 64105 Watts & Watts Philip O Watts 210 Park Ave Ste 1100 Oklahoma City, OK 73102 Wendel Rosen Black & Dean LLP Elizabeth Berke Dreyfuss 1111 Broadway 24th Fl Oakland, CA 94607-4036


Case: 10-13528 Doc: 1955-1 Filed: 08/18/11 Page: 1 of 7




























































Documents

Objections to Price and Associates Fee Applications€¦ · through June 30, 2011 and Memorandum of Law [DK 1890] ("Final Fee Application") (collectively, the "Fee Applications")