the Employment and Compensation of Professionals Utilized ......Case 20-10755-BLS Doc 518 Filed...

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re:

RAVN AIR GROUP, INC. et al.,1

Debtors.

Chapter 11

Case No. 20-10755 (BLS)

(Jointly Administered)

Related Docket No.: 224

NOTICE OF EXCESS FEES BY PROFESSIONAL UTILIZED IN THE ORDINARY COURSE OF BUSINESS

This notice (the “Notice of Excess Fees”) is provided pursuant to the Order Authorizing

the Employment and Compensation of Professionals Utilized in the Ordinary Course of Business,

Effective Nunc Pro Tunc to the Petition Date [Docket No. 224] (the “OCP Order”)2 by KMA

Zuckert LLC (the “Applicant”), which submitted its Declaration of Disinterestedness of KMA

Zuckert LLC in Support of Retention as Ordinary Course Professional on May 20, 2020 [Docket

No. 234].

PLEASE TAKE NOTICE THAT to the extent the Applicant seeks fees in excess of the

OCP Monthly Cap or OCP Case Cap, such excess fees are subject to this Notice of Excess Fees.

PLEASE TAKE FURTHER NOTICE THAT attached hereto as Schedule 1 (the “Fee

Schedule”) is a summary of the total fees earned and total expenses incurred for the period of July

1, 2020 to July 31, 2020 (the “Fee Period”), and any actual disbursements made by the Debtors to

the Applicant for these fees and expenses.

1 The Debtors in these chapter 11 cases and the last four digits of each Debtor’s U.S. tax identification number are as follows: Ravn Air Group, Inc. (3047), Ravn Air Group Holdings, LLC (5356), JJM, Inc. (4858), HoTH, Inc. (9957), Peninsula Aviation Services, Inc. (6859), Corvus Airlines, Inc. (7666), Frontier Flying Service, Inc. (8091), and Hageland Aviation Services, Inc. (2754). The notice address for all of the Debtors is 4700 Old International Airport Road, Anchorage, AK 99502. 2 Capitalized terms not herein defined shall have the meanings ascribed to them in the OCP Order.

Case 20-10755-BLS Doc 518 Filed 08/13/20 of 2

2

PLEASE TAKE FURTHER NOTICE THAT attached as Exhibit A (the “Invoice”) is an

invoice from the Applicant for the total fees earned and total expenses incurred for the Fee Period.

PLEASE TAKE FURTHER NOTICE THAT, pursuant to the OCP Order, the Notice

Parties have fifteen (15) days after the date of this Notice of Excess Fees (the “Objection

Deadline”) to object in writing to fees described in the attached Schedule 1 and Exhibit A.

PLEASE TAKE FURTHER NOTICE THAT any Objection to the Notice of Excess Fees

must: (i) be in writing; (ii) set forth the name of the objecting party; (iii) provide the basis for the

Objection and the specific grounds therefor; and (iv) be served by electronic mail on Debtors’

counsel at the following addresses: Keller Benvenutti Kim LLP, Attn: Tobias S. Keller, Esq. and

Jane Kim, Esq., [email protected], [email protected]; and Blank Rome LLP, Attn: Victoria A.

Guilfoyle, Esq., Stanley B. Tarr, Esq., Jose F. Bibiloni, Esq., [email protected],

[email protected], [email protected]; so as to be received on or before 4:00 p.m.

(prevailing Eastern Time) on the Objection Deadline.

PLEASE TAKE FURTHER NOTICE THAT, pursuant to the OCP Order, if no Objection

is timely served to a Notice of Excess Fees, the fees requested in the Notice of Excess Fees shall

be deemed approved, and the Applicant may be paid 100% of its fees and 100% of its expenses

without the need for further action from such Applicant.

Dated: August 13, 2020 Washington, D.C.

KMA ZUCKERT LLC By: Jonathon H. Foglia 888 17th Street NW, Suite 800 Washington, D.C. 20006 Telephone: (202) 298-8660 Facsimile: (202) 342-0683 Email: [email protected]

Case 20-10755-BLS Doc 518 Filed 08/13/20 of 2

Schedule 1

(Fee Schedule)

Case 20-10755-BLS Doc 518-1 Filed 08/13/20 Page 1 of 2

Dates Fees Expenses Actual Disbursements

July 1, 2020 to July 31, 2020 $13,975.00 $6.80 $0


-2-

Exhibit A

(Invoice for Fee Period)


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