American Titanium Works LLC

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Case 24-06559 Doc 106 Filed 01/16/26
Entered 01/16/26 10:24:38 Desc Main Document Page 1 of 4
UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION
In re:
)
)
Case No. 24bk06559
American Titanium Works LLC,
) )
Chapter 7
Debtor.
)
) Judge Timothy A. Barnes
FINDINGS OF FACT AND CONCLUSIONS OF LAW IN SUPPORT OF ORDER AWARDING TO RAINES FELDMAN LITTRELL LLP, ATTORNEYS FOR THE CHAPTER 7 TRUSTEE, FOR ALLOWANCE AND PAYMENT OF FINAL COMPENSATION AND REIMBURSEMENT OF EXPENSES
TOTAL FEES REQUESTED: $ 38,930.00 TOTAL COSTS REQUESTED: $ 0.00
TOTAL FEES REDUCED: $ 365.70 TOTAL COSTS REDUCED: $ 0.00
TOTAL FEES ALLOWED: $ 38,564.30 TOTAL COSTS ALLOWED: $ 0.00
TOTAL FEES AND COSTS ALLOWED: $ 38,564.30
The attached time and expense entries have been underlined to reflect disallowance in whole or in part. The basis for each disallowance is reflected by numerical notations that appear on the left of each underlined entry. The numerical notations correspond to the enumerated paragraphs below. (1) Lumping - TOTAL of disallowed amounts (10% of affected entries): $ 365.70
The Court may impose a ten percent penalty on entries that appear to be "lumping." The Court will reduce each entry marked as such per the penalty. In re Wildman, 72 B.R. 700, 709 (Bankr. N.D. Ill. 1987) (Schmetterer, J.) ("Applicants may not circumvent the minimum time requirement or any of the requirements of detail by "lumping" a bunch of activities into a single entry. [citation omitted]. Each type of service should be listed with the corresponding specific time allotment.").
Dated: January 16, 2026
Timothy A. Barnes, Judge United States Bankruptcy Court
AUTHENTICATED U.S. GOVERNMENT INFORMATION GPO

Case 24-06559 Doc106 Filed 01/16/26 Entered 01/16/26 10:24:38-Desce Main
Document Page 2 of 4 EXHIBIT

1900 Avenue of the Stars, 19th Floor
Los Angeles, CA 90067

_ (310) 440-4100
RAINES FELDMAN LITTRELL LLP SUG SEInBSIURE AIT

Federal Tax ID: 20-4515337

Invoice Date: 9/22/2025
Invoice Number: 139380

American Titanium Works LLC
Thomas Sax

8344-004 / Claims

Professional Services Hours Rate Amount

03/19/2025 NBN Review insider proofs of claim filed by T. Sax, 0.40 800.00 320.00
Financial Relations, Inc. and Amer. Titanium
Works, Inc. for possible objections.

04/07/2025 NBN Telephone calls with T. Sax and A. Logan re: 0.30 800.00 240.00
debtor's accrual of expenses and amounts
owing to unsecured creditors.

05/06/2025 NBN Review recent filed Proofs of Claim and 0.40 800.00 320.00
discuss debts owed more than 10 years with
M. Radtke.

05/20/2025 NBN Correspond with M. Radtke re: claims bar date 1.00 800.00 800.00

and post-petition claims (.3). Telephone
conference and correspond with Clerk's Office
re: bar date notice to unpaid Chapter 11
claimants (.3). Correspond with A. Brief re:
UST's claim (.2). Review claim filed by Tronix

(.2).

05/29/2025 NAS Print claims register (.10) and compare claims 0.20 190.00 38.00
with bankruptcy petition (.10).

06/12/2025 NBN Review exhibits to proofs of claim filed by 0.40 800.00 320.00
Tronox and ATW, Inc. re: possible objections.

06/25/2025 JSP Brief initial conference with N. Newman; 0.50 690.00 345.00

download and review Rule 1019 report;
download and review claims register.

06/30/2025 NBN Review documents in support of proofs of 1.40 800.00 1,120.00
claim involving loans, interest claimed and
damages asserted for more than 7 years pre-
petition re: objections.

Case 24-06559 Doci106 Filed 01/16/26 Entered 01/16/26 10:24:38 Desc Main
Document Page 3 of 4

07/02/2025 JSP Email to counsel for Winston & Strawn.Claim 3 0.20 690.00 138.00
noting inability to discern timing of services of
provided nor how the asserted sum was
computed and requesting supporting .
documentation including ledger or
spreadsheet.

07/02/2025 JSP Review ledger attached to Claim 11 Financial . 0,40 690.00 276.00
Relations Inc; note no agreement or contract
and dates of advances and cut off date if no
note, for SOL purposes of lilinois law; email

| communication to T. Sax requesting note(s)

associated with loan advances asserted in

! claim; briefly review reply email from T. Sax

| with supporting documents.

Pa oe ne . G mee Ee ae os ‘
(1 ) 07/06/2025 JSP Review reply emall from Mr. Elkouh (relating 0.40 690.00 276.00
to Erigo Technologies claim); review contract
for services, review ledger and application of
. payments.to Invoices, email. communication to , ‘
N. Newman explaining issues

07/07/2025 NBN ‘Telephone call and correspond with J Pail re: 0.40 800.00 320.00
Winston & Strawn, Erigo and Tronix
objectionable claims,

}

Case 24-06559 Doci06 Filed 01/16/26 Entered 01/16/26 10:24:38

(1) 07/21/2025 JSP

07/22/2025 JSP

Follow up email to

Document Page 4 of 4

Analyze Sax/Debtor/American Titanium Works ; 2.30
lnc Employment Agreement, review Sax email
asserting position/argument in support of
proof of claim, analyze relevant clauses in
Debtor's LLC Agreement naming claimant as
manager, phone call with T. Sax, brief research
relating to contract beneficiary theory,
communication to N. Newman regarding
recommendation, phone call with N.
Newman, review claim ledger for calculation
of potential disallowed portion of claim due to
10-year SOL, explanatory email to T. Sax
regarding SOL with allowed claim calculations
with recommendation to have legal counsel
review.

ss .

Phone call with Mark Kaplan regarding New 0.20
York Titanium claim, whether engagement

letter or email can be found and forwarded,

and discrepancy between claim and scheduled

amount.

Call with T. Sax regarding Financial Relations
claim 10 and American Titanium Inc Claim 11,
analyze T. Sax email explaining basis for
position that Employment Agreement in
conjunction with LLC Agreement constitutes
was basis for determination that applicable
SOL is 10 years for Claim American Titanium
Inc claim and 5 years for Financial Relations
claim; confer with N. Newman regarding
same; follow up email to T. Sax regarding
revised calculation for allowable portions of
claim per applicable SOLs and where to find
balance on ledger.

he: aims.L8 ee : ne
CFO for Invest SC Inc 0.20
requesting to be connected to company
counsel to discuss SOL issue; review response
and reply to counsel with copy of claim and
SOL issue.

Froue

Desc Main

690.00 1,587.00

690.00 138.00

759.00

es a i
690,00 138,00