Paddock Chapter 11 - Sixth Interim Fee Application of Latham & Watkins LLP For Allowance of Compensation For Services Rendered

Case 20-10028-LSS Doc 963 Filed 08/16/21 Page 1 of 3
IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
-------------------------------------------------------- x
:
In re: : Chapter 11
:
PADDOCK ENTERPRISES, LLC : Case No. 20-10028 (LSS)
:
1 Obj. Deadline: Sept.7, 2021 at 4:00 p.m. (ET)
Debtor. :
: Hearing Date: Nov. 4, 2021 at 10:30 a.m. (ET)
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SIXTH INTERIM FEE APPLICATION OF LATHAM & WATKINS LLP

FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED
AND FOR REIMBURSEMENT OF EXPENSES AS CO-COUNSEL TO THE
DEBTOR AND DEBTOR-IN-POSSESSION FOR THE PERIOD
APRIL 1, 2021 THROUGH JUNE 30, 2021
Name of Applicant: Latham & Watkins LLP
Authorized to Provide Professional Services

to: The above-captioned debtor and debtor-in-
possession
Date of Retention: May 26, 2020, nunc pro tunc to January 6, 2020
Period for which compensation

and reimbursement are sought: April 1, 2021 through June 30, 2021
Amount of Compensation sought as actual,

reasonable, and necessary: $1,631,822.50
Amount of Expense Reimbursement sought

as actual, reasonable, and necessary: $37,271.68
This is a(n): ___ monthly X interim ___ final application
1
The last four digits of the Debtor’s federal tax identification number are 0822. The Debtor’s mailing address is
One Michael Owens Way, Perrysburg, Ohio 43551.
1
US-DOCS\125856234.1
Summary of Fee Applications for the Interim Fee Period:
REQUESTED APPROVED HOLDBACK

Date Period Fees Expenses CNO/COC Approved Approved Holdback
Filed Covered Requested Requested Date & Fees (80%) Expenses (20%)
Docket (80%) Docket No. (100%)
No.
6/3/21 CNO
4/1/21
[Dkt. Approved
- $850,738.40 $36,021.29 $850,738.40 $36,021.29 $212,684.60
No. [Dkt. No.
4/30/21
881] 907]
7/6/21 CNO
5/1/21
[Dkt. Approved
- $160,763.20 $71.60 $160,763.20 $71.60 $40,190.80
No. [Dkt. No.
5/31/21
917] 936]
7/27/21
6/1/21
[Dkt. CNO
- $301,460.40 $1,178.79 – – –
No. Pending
6/30/21
934]
PLEASE TAKE NOTICE that, pursuant to the Order (I) Establishing Procedures for
Interim Compensation and Reimbursement of Expenses of Professionals and (II) Granting
Related Relief [Docket No. 94] (the “Interim Compensation Order”) objections, if any, to this
Interim Fee Application must be filed with the Court and served on Latham & Watkins LLP
(“Latham”) at the address set forth below and the Notice Parties (as defined in the Interim
Compensation Order) so as to be received by September , 2021 at 4:00 p.m. (Prevailing
Eastern Time).
PLEASE TAKE FURTHER NOTICE that a hearing to consider this Interim Fee
Application will be held before the Honorable Laurie Selber Silverstein at the United States
Bankruptcy Court for the District of Delaware, 824 North Market Street, 6th Floor, Courtroom 2,
Wilmington, Delaware 19801 on November 4, 2021 at 10:30 a.m. (Prevailing Eastern Time).
PLEASE TAKE FURTHER NOTICE that, (i) attached hereto as Exhibit A is
Latham’s summary cover sheet of the fee application and certain additional disclosures related to
the Interim Fee Application, (ii) attached hereto as Exhibit B is a summary of compensation by
each professional of Latham that worked on the above-captioned chapter 11 case (the “Chapter
2
US-DOCS\125856234.1
11 Case”), (iii) attached hereto as Exhibit C is a summary of compensation by project category,
(iv) attached hereto as Exhibit D is an expense summary, (v) attached hereto as Exhibit E are
Latham’s customary and comparable compensation disclosures, (vi) attached hereto as Exhibit F
is the Budget for Latham & Watkins LLP, Counsel to Debtor, for Period from April 1, 2021
Through June 30, 2021 and the Staffing Plan for Latham & Watkins LLP, Counsel to Debtor, for
the Period from April 1, 2021 Through June 30, 2021, (vii) attached hereto as Exhibit G is a
summary of fees and hours budgeted compared to fees and hours billed; and (viii) attached
hereto as Exhibit H is a certification of Jeffrey Bjork in support of this Interim Fee Application.
IF NO TIMELY OBJECTIONS ARE FILED TO THIS INTERIM FEE
APPLICATION, THE COURT, IN ACCORDANCE WITH THE TERMS OF THE
INTERIM COMPENSATION ORDER, MAY ENTER AN ORDER GRANTING THIS
INTERIM FEE APPLICATION WITHOUT A HEARING.
Dated: August 16, 2021 Respectfully Submitted,

Los Angeles, California
/s/ Jeffrey E. Bjork

Jeffrey E. Bjork (admitted pro hac vice)
Kimberly A. Posin (admitted pro hac vice)
Christina M. Craige (admitted pro hac vice)
Helena G. Tseregounis (admitted pro hac vice)
LATHAM & WATKINS LLP
355 South Grand Avenue, Suite 100
Los Angeles, California 90071
Telephone: (213) 485-1234
Facsimile: (213) 891-8763
Email: Jeff.Bjork@lw.com
Kim.Posin@lw.com
Chris.Craige@lw.com
Helena.Tseregounis@lw.com
Counsel for Debtor and Debtor-in-Possession
3
US-DOCS\125856234.1
Case 20-10028-LSS Doc 963-1 Filed 08/16/21 Page 1 of 1
Exhibit A
Summary Cover Sheet of Fee Application
Case Name: Paddock Enterprises, LLC

Case Number: 20-10028
Applicant’s Name: Latham & Watkins LLP
Interim or Final: Interim
Name of Applicant Latham & Watkins LLP

Name of Client Paddock Enterprises, LLC
Start: April 1, 2021
Time Period Covered by the Sixth Interim Fee Period
End: June 30, 2021
Total compensation sought for the Sixth Interim Fee Period $1,631,822.50
Total expenses sought for the Sixth Interim Fee Period $37,271.68
Petition date January 6, 2020
May 26, 2020 nunc pro
Retention date
tunc to January 6, 2020
Date of order approving employment May 26, 2020
Total allowed compensation to date $8,805,135.12
Total allowed expenses to date $442,932.81
Blended rate in the Sixth Interim Fee Period for all attorneys $1,137.61
Blended rate in the Sixth Interim Fee Period for all timekeepers $1,134.47
Compensation sought and already paid pursuant to a monthly
$1,011,501.60
compensation order but not yet allowed
Expenses sought and already paid pursuant to a monthly compensation
$36,092.89
order but not yet allowed
Number of professionals included in the Sixth Interim Application 33
If applicable, number of professionals in the Sixth Interim Application
01
not included in staffing plan approved by client
If applicable, difference between fees budgeted and compensation
($2,860,977.50)
sought for the Sixth Interim Fee Period
Number of professionals billing fewer than 15 hours to the case during
13
the Sixth Interim Fee Period
Are any rates higher than those approved or disclosed at retention? Yes
1
The staffing plan only accounts for professionals expected to bill at least 50 hours to the Chapter 11 Case. Of
the 33 professionals who billed time to the Chapter 11 Case, 10 billed 50 or more hours.
US-DOCS\125856234.1
Exhibit B
Compensation By Professional from April 1, 2021 through June 30, 2021
Position, Number of Years in Practice at Hourly Total

Name of Professional Total
Latham, Year of Obtaining License to Billing Hours
Individual Compensation
Practice Rate Billed
Partner. Joined firm in 1996. Member of
Wald, Peter A. $1,810 3.3 $5,973.00
the California Bar since 1979.
the New York Bar since 1988. Member of
DeNovio, Nicholas J. $1,810 24.9 $45,069.00
the Florida Bar since 1990. Member of the
District of Columbia Bar since 2006.
Bjork, Jeffrey E. $1,680 192.3 $323,064.00
California Bar since 1998.
Kronsnoble, Joseph M. $1,640 3.4 $5,576.00
the Illinois Bar since 1991.
Posin, Kimberly A. $1,495 56.6 $84,617.00
Parsigian, Kenneth J. $1,465 13.6 $19,924.00
Massachusetts Bar since 1988.
Edmonson, Tracy K. $1,435 5.5 $7,892.50
Perlman, Cary R. $1,395 7.9 $11,020.50
Illinois Bar since 1988.
Williams, U. Gwyn $1,360 31.9 $43,384.00
Virginia Bar since 2017. Member of New
Grant, Maximilian A. York Bar since 2016. Member of District $1,295 7.8 $10,101.00
of Columbia Bar since 2004. Member of
Thompson, Julia A. the Maryland Bar since 2009. Member of $1,240 20.5 $25,420.00
the District of Columbia Bar since 2010.
Karg, Karl A. $1,240 3.0 $3,720.00
Partner. Joined the firm in 2007. Member
Brown, Kegan A. of New York Bar since 2008. Member of $1,205 12.5 $15,062.50
New Jersey Bar since 2007.
Quartarolo, Amy C. $1,180 33.9 $40,002.00
US-DOCS\125856234.1

Counsel. Joined firm in 2019. Member of
Craige, Christina M. $1,205 256.9 $309,564.50
Counsel. Joined firm in 2012. Member of
Mohebbi, Nima H. $1,150 16.5 $18,975.00
Associate. Joined firm in 2018. Member of
Rothschild, Alexander P. Massachusetts Bar since 2019. Member of $1,095 85.3 $93,403.50
District of Columbia Bar since 2018.
Tseregounis, Helena G. $1,095 90.8 $99,426.00
McLaughlin, Timothy $1,095 53.7 $58,801.50
Townsend, Samuel A. $1,035 2.7 $2,794.50
the Massachusetts Bar since 2015.
Kochman, Christopher J. $995 39.9 $39,700.50
New York Bar since 2015.
Fellig, Shloime $930 15.8 $14,694.00
Tauber, M. Dixie $930 4.4 $4,092.00
von der Marwitz, Markus $850 22.4 $19,040.00
Rosen, Brian S. $850 129.6 $110,160.00
Weichselbaum, Jonathan Associate. Joined firm in 2018. Member of
$850 61.1 $51,935.00
J. New York Bar since 2019.
Schlossberg, Suzanne $725 43.2 $31,320.00
Irgi, A. Deniz $725 96.0 $69,600.00
Teresi, Joseph L. $725 53.7 $38,932.50
Kurzydlowski, Amanda Associate. Joined firm in 2020. Member of
$615 6.0 $3,690.00
R. New York Bar since 2019.
2
US-DOCS\125856234.1

Carbonaro, Allison M. $615 35.2 $21,648.00
Senior Litigation Paralegal. Joined firm in
Rico, Colleen M. $470 4.4 $2,068.00
2002.
Choi, Byung H. Summer Law Clerk. Joined firm in 2021. $480 2.4 $1,152.00
Total $1,631,822.50
Total Hours 1,437.1
Blended Rate1 $1,134.47
1
The blended rate is calculated based on the hourly rates for all professionals and paraprofessionals.
3
US-DOCS\125856234.1
Exhibit C
Compensation By Project Category from April 1, 2021 through June 30, 2021
Project Category Total Hours Total Fees

Asbestos Related Issues 71.3 $87,960.50
Automatic Stay Issues/Motions for Relief 0.3 $328.50
Business Operations/Strategic Planning 12.6 $13,931.00
Case Administration 53.2 $54,008.00
Claims Process/General Creditor Inquiries 15.3 $16,259.50
Corporate (Including Disclosure and Corporate Governance) 44.1 $51,957.50
Environmental Matters 67.0 $71,764.00
Litigation 479.4 $499,808.00
Plan of Reorganization and Disclosure Statement 548.9 $685,238.00
Reports and Schedules 10.2 $11,035.50
Retention/Fee Matters (L&W) 53.5 $42,112.50
Retention/Fee Matters/Objections (Others) 33.1 $28,635.00
Executory Contracts and Unexpired Leases 12.8 $11,107.00
Tax Matters 35.4 $57,677.50
Total 1,437.1 $1,631,822.50
US-DOCS\125856234.1
Exhibit D
Expense Summary from April 1, 2021 through June 30, 2021
Expense Category Total Expenses

Global Document Services $1,647.00
Practice Support $1,330.00
Westlaw - West Publishing $1,229.40
Lexis Nexis $883.80
Docket Research $561.70
Outside Services - Non-Attorney $107.79
Other Database Research $76.99
Docket $35.00
Binding $2.00
Expert/Consultant Services $31,398.00
TOTAL $37,271.68
US-DOCS\125856234.1
Exhibit E
Customary and Comparable Compensation Disclosures
Category of Timekeeper Blended Hourly Rate

Billed Firm-Wide for Preceding Billed April 1, 2021 through
Year (2020)1 June 30, 2021
Partner $1,275 $1,532
Counsel $1,101 $1,202
Senior Associate (7 years or
$1,039 $1,095
more since first admission)
Mid-level Associate (4-6 years
$894 $1,072
since first admission)
Junior Associate (0-3 years since
$682 $781
first admission)
Paralegals $397 $470
All timekeepers aggregated $971 $1,134
1
The billable rates for Latham attorneys are adjusted on January 1 of each year. Notice of Latham’s rate increase
effective as of January 1, 2021 was filed on December 11, 2020 [Docket No. 613]. The data in this column
excludes 2020 blended hourly rate information for members of the Restructuring and Special Situations practice
group.
US-DOCS\125856234.1
Exhibit F
Budget & Staffing Plan
US-DOCS\125856234.1

-------------------------------------------------------- x
:
In re: : Chapter 11
:
:
1
Debtor. :
:
-------------------------------------------------------- x
BUDGET FOR LATHAM & WATKINS LLP, COUNSEL TO DEBTOR,

FOR PERIOD FROM APRIL 1, 2021 THROUGH JUNE 30, 20212
Date Retention Approved: May 26, 2020 nunc pro tunc to January 6, 2020
Date Budget Approved by Client: March 15, 20213
PROJECT CATEGORY ESTIMATED ESTIMATED

HOURS FEES
Asbestos Related Issues 450 $468,000
Asset Dispositions 20 $20,800
Automatic Stay Issues/Motions for Relief 35 $36,400
Avoidance Power Issues/Actions 30 $31,200
Business Operations/Strategic Planning 50 $52,000
Case Administration 300 $312,000
Claims Process/General Creditor Inquiries 250 $260,000
1
2
This budget may be amended to reflect changed circumstances or unexpected developments. Any such amended
budget will be provided to the Debtor.
3
The estimated fees for each project category were calculated by multiplying the estimated number of hours by
$1,040, which is the approximate average hourly rate for the 32 attorneys expected to work on the matter during
the budget period as set forth in the accompanying Staffing Plan.
US-DOCS\125856234.1
PROJECT CATEGORY ESTIMATED ESTIMATED

HOURS FEES
Corporate (Including Disclosure and Corporate

75 $78,000
Governance)
Creditors Committee Matters 450 $468,000
Environmental Matters 250 $260,000
Executory Contracts and Unexpired Leases 30 $31,200
Financing 20 $20,800
Insurance 20 $20,800
Litigation 1,000 $1,040,000
Non-Working Travel4 20 $10,400
Plan of Reorganization and Disclosure Statement 950 $988,000
Regulatory Matters (Excluding Environmental) 30 $31,200
Reports and Schedules 50 $52,000
Retention (L&W) 75 $78,000
Retention (Others) 75 $78,000
Tax Matters 50 $52,000
U.S. Trustee Matters 100 $104,000
TOTAL 4,330 $4,492,800
4
Non-Working Travel Time billed at 50% rate.
US-DOCS\125856234.1

-------------------------------------------------------- x
:
In re: : Chapter 11
:
:
1
Debtor. :
:
-------------------------------------------------------- x
STAFFING PLAN FOR LATHAM & WATKINS LLP, COUNSEL TO DEBTOR,

FOR PERIOD FROM APRIL 1, 2021 THROUGH JUNE 30, 20212
Date Retention Approved: May 26, 2020 nunc pro tunc to January 6, 2020
Date Staffing Plan Approved by Client: March 15, 2021
CATEGORY OF TIMEKEEPER NUMBER OF TIMEKEEPERS APPROXIMATE

EXPECTED TO WORK ON THE HOURLY RATE
MATTER DURING THE BUDGET
PERIOD3
Senior Partner 5 $1,495-$1,680
Other Partner / Counsel 7 $1,180-$1,240
Associate 20 $615-$1,095
1
2
This staffing plan may be amended to reflect changed circumstances or unexpected developments. Any such
amended staffing plan will be provided to the Debtor.
3
These totals reflect the attorneys expected to bill at least 50 hours to the Chapter 11 Case.
US-DOCS\125856234.1
Exhibit G
Summary of Fees/Hours Budgeted Compared with Fees/Hours Billed
Budgeted Billed Budgeted

Project Category Billed Fees
Hours Hours Fees
Asbestos Related Issues 450 71.3 $468,000 $87,960.50
Asset Dispositions 20 – $20,800 –
Automatic Stay Issues/Motions for Relief 35 0.3 $36,400 $328.50
Avoidance Power Issues/Actions 30 – $31,200 –
Business Operations/Strategic Planning 50 12.6 $52,000 $13,931.00
Case Administration 300 53.2 $312,000 $54,008.00
Claims Process/General Creditor Inquiries 250 15.3 $260,000 $16,259.50
Corporate (Including Disclosure and

75 44.1 $78,000 $51,957.50
Corporate Governance)
Creditors Committee Matters 450 – $468,000 –
Environmental Matters 250 67.0 $260,000 $71,764.00
Executory Contracts and Unexpired Leases 30 12.8 $31,200 $11,107.00
Financing 20 – $20,800 –
Insurance 20 – $20,800 –
Litigation 1,000 479.4 $1,040,000 $499,808.00
Non-Working Travel1 20 – $10,400 –
Plan of Reorganization and Disclosure

950 548.9 $988,000 $685,238.00
Statement
Regulatory Matters (Excluding

30 – $31,200 –
Environmental)
Reports and Schedules 50 10.2 $52,000 $11,035.50
Retention/Fee Matters (L&W) 75 53.5 $78,000 $42,112.50
1
Non-Working Travel Time billed at 50% rate.
US-DOCS\125856234.1
Budgeted Billed Budgeted

Project Category Billed Fees
Hours Hours Fees
Retention/Fee Matters/Objections (Others) 75 33.1 $78,000 $28,635.00
Tax Matters 50 35.4 $52,000 $57,677.50
U.S. Trustee Matters 100 – $104,000 –
TOTAL 4,330 1,437.1 $4,492,800 $1,631,822.50
US-DOCS\125856234.1
Exhibit H
Certification Regarding Interim Fee Application
US-DOCS\125856234.1

-------------------------------------------------------- x
:
In re: : Chapter 11
:
:
1
Debtor. :
:
-------------------------------------------------------- x
CERTIFICATION OF JEFFREY E. BJORK IN SUPPORT OF

THE SIXTH INTERIM FEE APPLICATION OF LATHAM & WATKINS LLP
1. I am a partner with the applicant firm, Latham & Watkins LLP ( “Latham”), and
have been admitted to the bar of the State of California since 1998.
2. I make this certification regarding the Sixth Interim Fee Application of Latham &
Watkins LLP for Allowance of Compensation for Services Rendered and for Reimbursement of
Expenses as Co-Counsel to the Debtor and Debtor-in-Possession for the Period April 1, 2021
through June 30, 2021 (the “Interim Fee Application”) to certify matters addressed in the
Order (I) Establishing Procedures for Interim Compensation and Reimbursement of Expenses of
Professionals and (II) Granting Related Relief [Docket No. 94] (the “Interim Compensation
Order”).2 I have personally performed many of the legal services rendered by Latham as
counsel to the Debtor in the Chapter 11 Case, and am thoroughly familiar with the other work
performed on behalf of the Debtor by the lawyers in the firm.
3. Specifically, I have reviewed the Interim Fee Application and the monthly fee
applications relating to the period from April 1, 2021 through and including June 30, 2021 (the
1
2
Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such terms in the
Interim Compensation Order.
US-DOCS\125856234.1
“Interim Fee Period”), and I hereby certify that such applications comply with the Interim
Compensation Order and the applicable provisions of the Bankruptcy Code, the Bankruptcy
Rules, and the Local Rules. In addition, I hereby certify that, in accordance with the Interim
Compensation Order, and in connection with preparing the Interim Fee Application, Latham has
made a reasonable effort to comply with the U.S. Trustee’s requests for information and
additional disclosures set forth in the Guidelines for Reviewing Applications for Compensation
and Reimbursement of Expenses Filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11
Cases, effective November 1, 2013 (the “U.S. Trustee Guidelines”).
Disclosures Pursuant to the Revised U.S. Trustee Guidelines
4. By order dated May 26, 2020 [Docket No. 329] the (“Retention Order”) the
Court approved the Application for Debtor for Entry of Order Authorizing Employment and
Retention of Latham & Watkins LLP as Bankruptcy Co-Counsel Effective as of the Petition Date
[Docket No. 60] (the “Retention Application”) authorizing the Debtor to retain Latham as co-
counsel in the Chapter 11 Case.
5. Thirty-three (33) professionals are included in this Interim Fee Application. Of
those 33 professionals, 13 billed fewer than 15 hours during the Interim Fee Period.
6. Latham discussed its rates, fees, and staffing plan with the Debtor at the outset of
the Chapter 11 Case. Further, Latham provided the Debtor with the budget and the staffing plan
attached to the Interim Fee Application as Exhibit F. The difference between the fees budgeted
and the compensation sought for the Interim Fee Period is $2,860,977.50 (approximately 63.7%)
lower than the budgeted amount.
7. In accordance with the U.S. Trustee Guidelines, Latham responds to the questions
identified therein as follows:
Question 1: Did Latham agree to any variations from, or alternatives to,
US-DOCS\125856234.1
Latham’s standard or customary billing rates, fees, or terms for services

pertaining to this engagement that were provided during the application period?
If so, please explain.
Answer: No.
Question 2: If the fees sought in the Interim Fee Application as compared to

the fees budgeted for the time period covered by the Interim Fee Application are
higher by 10% or more, did Latham discuss the reasons for the variation with the
client?
Answer: The fees sought in the Interim Fee Application are less than
the fees budgeted for the time period covered by the Interim Fee Application.
Question 3: Have any of the professionals included in the Interim Fee

Application varied their hourly rate based on geographic location of the
bankruptcy case?
Answer: No.
Question 4: Does the Interim Fee Application include time or fees related to
reviewing or revising time records or preparing, reviewing or revising invoices?
Answer: No.
Question 5: Does the Interim Fee Application include time or fees for
reviewing time records to redact any privileged or other confidential information?
If so, please quantify hours and fees.
Answer: Yes, the total time expended for such matters during the
Compensation Period was 8 hours for fees of $5,800.
Question 6: Does the Interim Fee Application include any rate increases since
Latham’s retention in the case?
Answer: There are no rate increases to report since the filing of the
previous interim fee application.
/s/ Jeffrey E. Bjork

Jeffrey E. Bjork
US-DOCS\125856234.1

Paddock Chapter 11 - Sixth Interim Fee Application of Latham & Watkins LLP For Allowance of Compensation For Services Rendered

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Case 20-10028-LSS Doc 963 Filed 08/16/21 Page 1 of 3

IN THE UNITED STATES BANKRUPTCY COURT

SIXTH INTERIM FEE APPLICATION OF LATHAM & WATKINS LLP

Name of Applicant: Latham & Watkins LLP

Authorized to Provide Professional Services

Period for which compensation

Amount of Compensation sought as actual,

Amount of Expense Reimbursement sought

This is a(n): ___ monthly X interim ___ final application

Summary of Fee Applications for the Interim Fee Period:

REQUESTED APPROVED HOLDBACK

Interim Compensation and Reimbursement of Expenses of Professionals and (II) Granting

Compensation Order) so as to be received by September , 2021 at 4:00 p.m. (Prevailing

PLEASE TAKE FURTHER NOTICE that, (i) attached hereto as Exhibit A is

11 Case”), (iii) attached hereto as Exhibit C is a summary of compensation by project category,

IF NO TIMELY OBJECTIONS ARE FILED TO THIS INTERIM FEE

APPLICATION, THE COURT, IN ACCORDANCE WITH THE TERMS OF THE

INTERIM COMPENSATION ORDER, MAY ENTER AN ORDER GRANTING THIS

INTERIM FEE APPLICATION WITHOUT A HEARING.

Dated: August 16, 2021 Respectfully Submitted,

/s/ Jeffrey E. Bjork

Summary Cover Sheet of Fee Application

Case Name: Paddock Enterprises, LLC

Name of Applicant Latham & Watkins LLP

Compensation By Professional from April 1, 2021 through June 30, 2021

Position, Number of Years in Practice at Hourly Total

Position, Number of Years in Practice at Hourly Total

Position, Number of Years in Practice at Hourly Total

Project Category Total Hours Total Fees

Expense Summary from April 1, 2021 through June 30, 2021

Expense Category Total Expenses

Customary and Comparable Compensation Disclosures

Category of Timekeeper Blended Hourly Rate

Budget & Staffing Plan

IN THE UNITED STATES BANKRUPTCY COURT

BUDGET FOR LATHAM & WATKINS LLP, COUNSEL TO DEBTOR,

Date Budget Approved by Client: March 15, 20213

PROJECT CATEGORY ESTIMATED ESTIMATED

Asbestos Related Issues 450 $468,000

Asset Dispositions 20 $20,800

Automatic Stay Issues/Motions for Relief 35 $36,400

Avoidance Power Issues/Actions 30 $31,200

Business Operations/Strategic Planning 50 $52,000

Case Administration 300 $312,000

Claims Process/General Creditor Inquiries 250 $260,000

PROJECT CATEGORY ESTIMATED ESTIMATED

Corporate (Including Disclosure and Corporate

Creditors Committee Matters 450 $468,000

Environmental Matters 250 $260,000

Executory Contracts and Unexpired Leases 30 $31,200

Litigation 1,000 $1,040,000

Non-Working Travel4 20 $10,400

Plan of Reorganization and Disclosure Statement 950 $988,000

Regulatory Matters (Excluding Environmental) 30 $31,200

Reports and Schedules 50 $52,000

Retention (L&W) 75 $78,000

Retention (Others) 75 $78,000

Tax Matters 50 $52,000

U.S. Trustee Matters 100 $104,000

TOTAL 4,330 $4,492,800

IN THE UNITED STATES BANKRUPTCY COURT

STAFFING PLAN FOR LATHAM & WATKINS LLP, COUNSEL TO DEBTOR,

Date Staffing Plan Approved by Client: March 15, 2021

This is a(n): _ monthly X interim _ final application