First Brands Group, LLC and WEM US Co. — Entry #3994: Application for Compensation for Guidepost Solutions, LLC, Financial Advisor, Period: 1/5/2026 to 5/31/2026, Fee: $1276730, Expenses: $5521714
Case: First Brands Group, LLC and WEM US Co. txsb · 25-90399
filed September 28, 2025
What this document is
Docket entry #3994 · filed October 26, 2026
Application for Compensation for Guidepost Solutions, LLC, Financial Advisor, Period: 1/5/2026 to 5/31/2026, Fee: $1276730, Expenses: $5521714. Objections/Request for Hearing Due in 21 days. Filed by Other Prof. Guidepost Solutions, LLC (Attachments: (1) Exhibit A (2) Exhibit B (3) Exhibit C (4) Exhibit D (5) Proposed Order) (Okin, Matthew)
Who is involved
- Airtex Industries, LLC
- Airtex Products, LP
- APC Intermediate Holdings, LLC
- APC Parent, LLC
- ASC Industries, Inc.
- Autolite Operations LLC
- AVM Export, Inc.
- BPI Acquisition Company, LLC
- BPI EC, LLC
- BPI Holdings International, LLC
- Brake Parts Inc China LLC
- Brake Parts Inc India LLC
- Brake Parts Inc LLC
- Broad Street Financial Holdings, LLC
- Broad Street Financial, LLC
- Cardone Industries, Inc.
- Carnaby Capital Holdings, LLC
- Carnaby Capital, LLC
- Carnaby FA Holdings, LLC
- Carnaby FA, LLC
- Carnaby Inventory Holdings II, LLC
- Carnaby Inventory Holdings III, LLC
- Carnaby Inventory Holdings IV, LLC
- Carnaby Inventory II, LLC
- Carnaby Inventory III, LLC
- Carnaby Inventory IV, LLC
- Carrand Companies, Inc.
- Carter Carburetor Holdings, LLC
- Carter Carburetor, LLC
- Carter Fuel Export, Inc.
- Carter Fuel Systems, LLC
- Champion Laboratories, Inc.
- CWD Holding, LLC
- CWD Intermediate Holdings I, LLC
- CWD Intermediate Holdings II, LLC
- CWD, LLC
- Dalton Corporation
- Dalton Corporation, Ashland Manufacturing Facility
- Dalton Corporation, Kendallville Manufacturing Facility
- Dalton Corporation, Stryker Machining Facility Co.
- and 77 more on the docket page
Why we have it
We follow this case because it names a company we track, although that company is not a party:
- Core Scientific: its name “Core Scientific, Inc.” appears in a filing in this case.
…PacificCo Inc.; Serta Simmons Bedding, LLC; Core Scientific, Inc.; Kabbage, Inc.; Phoenix Services Topco…
A free copy from the RECAP archive of federal court filings (mirrored at the Internet Archive), retrieved October 28, 2026. Federal court filings are public records.
Document text
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Full text
Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 1 of 20
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
:
In re: : Chapter 11
:
FIRST BRANDS GROUP, LLC et al., : Case No. 25-90399 (CML)
:
Debtors.1 : (Jointly Administered)
:
SUMMARY COVERSHEET TO FIRST AND FINAL FEE
APPLICATION OF GUIDEPOST SOLUTIONS, LLC, AS
FORENSIC ACCOUNTANT TO THE EXAMINER,
MARTIN DE LUCA, FOR THE PERIOD FROM
JANUARY 5, 2025 THROUGH AND INCLUDING MAY 31, 2026
Name of Applicant: Guidepost Solutions, LLC (“Guidepost”)
Applicant’s Role in Case: Forensic Accountant to the Examiner
Docket No. of Employment Order(s): Docket Nos. 2077 and 1910
Interim Application ( )
Final Application (x)
Beginning Date End of Period
Time period covered by this Application for
which interim compensation has not previously January 5, 2026 May 31, 2026
been awarded:
Were the services provided necessary to the administration of or beneficial at the time rendered toward
the completion of the case? (Y)
Were the services performed in a reasonable amount of time commensurate with the complexity,
importance and nature of the issues addressed? (Y)
Is the requested compensation reasonable based on the customary compensation charged by
comparably skilled practitioners in other non-bankruptcy cases? (Y)
Do expense reimbursements represent actual and necessary expenses incurred? (Y)
Compensation Breakdown for Time Period Covered by this Application
1 A complete list of the Debtors in the Chapter 11 Cases may be obtained on the website of the Debtors’ claims and
noticing agent at https://restructuring.ra.kroll.com/firstbrands.
Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 2 of 20
Total professional fees covered in this Application: $1,276,730.00
Total professional hours covered by this Application: 2,259.00
Average hourly rate for professionals: $565.18
Total expense reimbursements requested in this Application: $55,217.14
Total fees and expenses requested in this Application: $1,331,947.14
Total fees and expenses awarded in all prior Applications: $0.00
Plan Status: On September 1, 2026, the Court entered its order converting the Debtors’ chapter 11
cases to cases under chapter 7 of the Bankruptcy Code (Docket No. 3748. This Application is filed
pursuant to paragraph 2 of said order.
Primary Benefits: As discussed below, during the Application Period, Guidepost Solutions assisted the
Examiner with conducting a complex and intensive international investigation and evidence-preservation
exercise, resulting in the Examiner’s Report filed on April 27, 2026 (Docket No. 2538) and the creation of
an extensive database comprising documents, communications, and other information related to the
Examiner’s investigation. Guidepost’s professionals assisted the Examiner by conducting forensic
accounting analyses, investigative asset tracing, financial and communications analysis, third party meetings
and data analysis, and witness interviews.
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Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 3 of 20
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
:
In re: : Chapter 11
:
FIRST BRANDS GROUP, LLC et al., : Case No. 25-90399 (CML)
:
Debtors. : (Jointly Administered)
:
FIRST AND FINAL FEE APPLICATION OF GUIDEPOST
SOLUTIONS, LLC, AS FORENSIC ACCOUNTANT TO THE
EXAMINER, MARTIN DE LUCA, FOR THE PERIOD FROM
JANUARY 5, 2025 THROUGH AND INCLUDING MAY 31, 2026
IF YOU OBJECT TO THE RELIEF REQUESTED, YOU MUST RESPOND IN
WRITING. UNLESS OTHERWISE DIRECTED BY THE COURT, YOU MUST FILE
YOUR RESPONSE ELECTRONICALLY AT HTTPS://ECF.TXSB.USCOURTS.GOV/
WITHIN TWENTY-ONE DAYS FROM THE DATE THIS APPLICATION WAS FILED.
IF YOU DO NOT HAVE ELECTRONIC FILING PRIVILEGES, YOU MUST FILE A
WRITTEN OBJECTION THAT IS ACTUALLY RECEIVED BY THE CLERK WITHIN
TWENTY-ONE DAYS FROM THE DATE THIS APPLICATION WAS FILED.
OTHERWISE, THE COURT MAY TREAT THE PLEADING AS UNOPPOSED AND
GRANT THE RELIEF REQUESTED.
Guidepost Solutions, LLC, forensic accountant to Martin De Luca (the “Examiner”), the
Examiner in the above-captioned jointly administered chapter 11 cases (the “Chapter 11 Cases”)
of First Brands Group, LLC and its affiliated debtors and debtors in possession (collectively, the
“Debtors” or “FBG”), hereby file their first and final application (this “Application”) for
allowance of compensation for services performed during the
2
A complete list of the Debtors in the Chapter 11 Cases may be obtained on the website of the Debtors’ claims and
noticing agent at https://restructuring.ra.kroll.com/firstbrands.
3
Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 4 of 20
period commencing January 5, 2026 through and including May 31, 2026 (the “Compensation
Period”) in the amount of $1,276,730.00, and for reimbursement of actual and necessary expenses
in the amount of $55,217.14 incurred during the Compensation Period, and respectfully represent
as follows:
JURISDICTION, VENUE, AND STANDING
1. This Court has jurisdiction to consider this Application pursuant to 28
U.S.C. § 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b).
2. Venue in this Court is proper pursuant to 28 U.S.C. §§ 1408 and 1409.
3. The statutory bases and other authority for the relief requested herein include
sections 330(a) and 503(b) of title 11 of the United States Code (the “Bankruptcy Code”), Rule
2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the Court’s Local
Rule 2016-1, the Court’s Order Directing Appointment of an Examiner entered on November 19,
2025 (Docket No. 726) (the “Examiner Order”), the Court’s Order Authorizing the Employment and
Retention of Guidepost Solutions, LLC as Forensic Accountant to the Examiner entered on March 9,
2026 and effective as of January 5, 2026 (Docket 2077) and the Court’s Order Establishing
Procedures for Interim Compensation and Reimbursement of Expenses for Professionals entered
on November 17, 2025 (Docket No. 699) (the “Interim Compensation Order”).
BACKGROUND
4. On October 8, 2025, Raistone Capital LLC and Raistone Purchasing LLC – Series
XXXII filed an Emergency Motion for the Appointment of an Examiner Pursuant to Section
1104(c) of the Bankruptcy Code (Docket No. 307). Subsequently, on October 15, 2025, the United
States Trustee (the “U.S. Trustee”) filed an Expedited Motion for Entry of an Order Directing the
Appointment of an Examiner (Docket No. 340).
4
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5. On November 19, 2025, the Court entered the Examiner Order, finding, among other
things, that there was sufficient cause for the appointment of an examiner pursuant to section
1104(c) of the Bankruptcy Code for the purposes set forth in section 1106(a)(3) and 1106(a)(4) of
the Bankruptcy Code and specifically to:
a. Investigate the facts and circumstances, including general corporate
practices, concerning the Debtors’ prepetition factoring processes and factoring
transactions related to:
a. Allegations that the Debtors’ prepetition third-party
factoring transactions (“Factoring Transactions”) included (A) fraudulent
or inaccurate invoices and the related accounts receivable in the Debtors’
books and records and audit reports; and (B) accounts receivable factored
more than once and, in each case of (A) and (B), the persons or entities
responsible for any of the Factoring Transactions;
b. Transactions and/or transfers between any of (A) the
Debtors, (B) any insiders or affiliates of the Debtors, and (C) entities owned
or controlled by an insider or affiliates, and (D) the unaffiliated third party
factors (the “Third-Party Factors”) concerning (X) the Factoring
Transactions and the transfers and use of the proceeds of such Factoring
Transactions; and,
c. Any accounting with respect to the proceeds of the Factoring
Transactions and any property of third parties received by the Debtors that the
Examiner deems appropriate.
b. Investigate the facts and circumstances, including general corporate
practices, concerning the Debtors’ Off-Balance Sheet Financing Transactions,
as defined in the Examiner Order, related to any transactions and/or transfers in
connection therewith. Examiner Order ¶ 3.
6. The Examiner Order also directs the Examiner to “perform the duties set forth in
section 1106(a)(3) and 1106(a)(4), subject to the terms of this Order.” Examiner Order ¶ 2.
7. Paragraph 5 of the Examiner Order authorizes the Examiner to retain professionals
pursuant to the standards under section 327 of the Bankruptcy Code and for the Examiner and his
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retained professionals to seek payment of compensation and expense reimbursement pursuant to
the Interim Compensation Order and section 330 of the Bankruptcy Code. Paragraph 4 of the
Examiner Order provides a $7 million budget for the aggregate fees and expenses of the Examiner
and his professionals (the “Examination Budget”), without prejudice to the Examiner’s right to
seek an increase in the Examination Budget.
8. On January 21, 2026, as required under the Examiner Order, the Examiner filed his
proposed Work Plan (the “Work Plan”) (Docket No. 1650), outlining the topics, details, and
timeline for an investigation in accordance with the Examiner Order.
9. On January 29, 2026, the Court entered an order approving the Work Plan (Docket
No. 1819).
10. Pursuant to the Work Plan, the intensive transnational investigation by the Examiner
and his professionals built significant momentum in developing a detailed factual record that bears
on the overriding concerns of the Chapter 11 Cases, namely to determine how the Debtors’
“corporate practices” enabled the apparent financial frauds to occur prepetition and who was
responsible.
11. However, in late February, the Examiner substantially scaled down his investigation
due to: (i) the imminent exhaustion of the Court‑approved $7 million Examination Budget; (ii) the
announced lack of additional debtor-in-possession funding by the Ad Hoc Lenders or any other
source; (iii) the refusal of the Ad Hoc Lenders to include the Examiner and his professionals in the
collateral carve-out—that now covers the other major professionals in the Chapter 11 Cases under
the DIP financing order—or to fund an increase in the Examination Budget; and (iv) the apparent
likelihood of an administrative insolvency in the Chapter 11 Cases.
12. The Examiner therefore prioritized the collection and preservation of documents,
data, and other evidence critical to the investigation, evaluation, and later prosecution of claims
6
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against non-Debtor third parties or assets on behalf of the Debtors by estate representatives. The
volume and complexity of the information gathered to date and the discovery of additional areas
of inquiry that were not fully anticipated at the outset of the examination led the Examiner to
conclude that a comprehensive investigation would require substantially more time and resources
than allocated under the Examination Budget.
13. The precipitous events of the Chapter 11 Cases created a difficult choice for the
Examiner: either stop work and not complete the report contemplated by the Court-approved Work
Plan, or continue his investigation on a highly tailored, limited basis and complete an initial report
knowing that the Examiner’s and his professionals’ fees and expenses would likely exceed the
Examination Budget before there was any assurance that fees and expenses exceeding the
Examination Budget would have a source of funding. Indeed, the Examiner raised concerns about
the adequacy of the Examination Budget in pleadings on at least two occasions. ECF No. 1354 ¶
15; ECF No. 1724 at 12–13. The Examiner’s counsel also reported those concerns to the Court at
a hearing on January 22, 2026.
14. Notwithstanding the lack of DIP funding or the protection of a collateral carve-out,
and the resulting financial risks, the Examiner and his professionals determined that, in order for
the Court, the Debtors’ estates, and parties in interest to have the benefit of the Examiner’s
investigative efforts and initial findings and impressions, they would complete and file the
Examiner Report. The alternative would have been resources expended on an investigation that
physically spanned the globe, with valuable evidence collected, maintained and organized with an
e-discovery vendor, and no report for the benefit of the estate and financial fraud victims to guide
them through the evidence amassed. Completing the Examiner Report was the only appropriate
choice for the benefit of the Debtors’ estates.
15. On April 17, 2026, the Examiner filed his Examiner Report under seal.
7
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16. Following the filing of the Report, the Examiner conferred with the Debtors and
other information-producing parties regarding the treatment of information designated as Highly
Confidential and Confidential Material contained in the Report. Following those consultations, the
Examiner reached agreement with producing parties that certain confidential information should
remain sealed and finalized the Report.
17. Accordingly, the Examiner filed a revised Examiner Report on April 27, 2026,
which remains under seal.
18. Also on April 27, 2026, a redacted version of the revised Report was filed on the
public docket (Docket No. 2538).
19. The Examiner Report describes the work performed, the Examiner’s initial
impressions, open questions that warrant further investigation, and the high-value work streams
that have not yet been completed.
20. Due to the exigencies of the Investigation, in order to fulfill the Examiner’s mandate
notwithstanding the constraints of the Examination Budget, the Examiner’s professionals rendered
services and incurred fees and expenses that, in the aggregate, exceeded the Examination Budget.
21. To date, the Debtors have disbursed the entire $7 million Examination Budget to the
Examiner and his professionals, including local co-counsel, the forensic investigations firm and
the e-discovery vendor, on a pro rata basis.
22. Through May 31, 2026 (i.e., the Compensation Period), Guidepost incurred a total
of $1,276,730.00 in fees and has received a total of $1,001,724 in compensation and has received
100% reimbursement of its expenses in the total amount of $55,217.14. The payments made to
Guidepost cover only time and expense charges billed through March 2026 pursuant to the Interim
Compensation Order.
8
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23. On July 27, 2026, the Debtors filed the last iteration of their Joint Chapter 11 Plan
of First Brands Group, LLC and Certain Affiliated Debtors (Docket No. 3448) (the “Plan”).
24. On August 24, the Court entered its Order Denying Plan Confirmation (Docket No.
3710). On September 1, 2026, the Court entered an order converting the Chapter 11 Cases to cases
under chapter 7 of the Bankruptcy Code (Docket No. 3748) (the “Conversion Order”).
RELIEF REQUESTED
25. This Application has been prepared in accordance with section 330(a) of the
Bankruptcy Code, Bankruptcy Rule 2016, Bankruptcy Local Rule 2016-1, the Court Procedures
for Judge Christopher M. Lopez, the U.S. Trustee Guidelines for Reviewing Applications for
Compensation and Reimbursement of Expenses Filed under 11 U.S.C. § 330 by Attorneys in
Larger Chapter 11 Cases, and the Interim Compensation Order.
26. By this Application, Guidepost seeks entry of an order substantially in the form
submitted concurrently herewith, pursuant to section 330(a) of the Bankruptcy Code, the Interim
Compensation Order, and the Conversion Order, approving fees and expenses incurred throughout
the Compensation Period but approving compensation and expense reimbursement limited to the
amounts previously paid to Guidepost for time and expense charges pursuant to the Interim
Compensation Order.
27. There is no agreement or understanding between the Guidepost and any other person
for the sharing of compensation to be received for services rendered in the Chapter 11 Cases.
During the Compensation Period, other than payment received by Guidepost on account of
monthly fee statements in accordance with the Interim Compensation Procedures Order, Guidepost
received no payment or promises of payment from any source for services rendered, or to be
rendered, in any capacity whatsoever in connection with the matters covered by this Application.
9
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28. The fees charged by the Guidepost in the Chapter 11 Cases are billed in accordance
with its existing billing rates and procedures in effect during the Compensation Period. The rates
charged for the services rendered by their professionals and paraprofessionals in these chapter 11
cases are no greater than the rates they charge for professional forensic accounting services
rendered in comparable bankruptcy and non-bankruptcy related matters. Such fees are reasonable
based on the customary compensation charged by comparably skilled practitioners in comparable
bankruptcy and non-bankruptcy matters in a competitive national consulting market.
SUPPORTING DOCUMENTS
29. Attached hereto as Exhibit A is the Certification of Santiago Batista, Senior
Managing Director of Guidepost (the “Batista Certification”), regarding compliance with the Fee
Guidelines and the Court’s General Order 2018-5 for Complex Chapter 11 Cases.
30. Attached hereto as Exhibit B is a schedule of all Guidepost professionals who
performed services during the Compensation Period, together with summary information
regarding hours, rates, and fees.
31. Guidepost has not attached detailed time entries or detailed expense backup to this
Application. Such detail was provided to all parties required to receive monthly submissions under
the Interim Compensation Order for each month through March 2026 (the “Monthly
Submissions”). The payments already made to Guidepost were made on the basis of those
Monthly Submissions and cover only time and expense charges through March 2026. None of the
parties upon whom the Monthly Submissions were served, including the United States Trustee,
objected to any of the Monthly Submissions. If the Court wishes to review detailed time records
and expense details through May 2026, Guidepost can provide that information to the Court under
seal or in such other manner as the Court orders.
32. Maintaining the confidentiality of the detailed time records and expense information
10
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is in the interests of the Debtors’ chapter 7 estates because the descriptions may reveal investigative
priorities, witness-related information, discussions with BSF regarding litigation strategy, work-
product, or other information relevant to claims and causes of action that may be pursued by or for
the benefit of creditors.
33. Attached hereto as Exhibit C is a summary and comparison of the aggregate blended
hourly rates billed by BSF timekeepers in BSF’s U.S. offices to non-bankruptcy matters during
the prior twelve-month period ending April 30, 2026, and the blended hourly rates billed to the
Debtors’ estates during the Compensation Period (the “Blended Rate Comparison Chart”).
SUMMARY OF PROFESSIONAL
SERVICES RENDERED DURING
THE COMPENSATION PERIOD
34. During the Compensation Period, Guidepost spent significant time and effort in
rendering forensic accounting services to the Examiner. The below summary of services rendered
and reflected in the Time Records is organized by project or task category; certain services
performed may overlap between, or may appropriately be allocated to, more than one category,
but a good-faith effort was made by all timekeepers to categorize work performed in a consistent
manner across all timekeepers.
Task Description Hours Fees
Case administration 91.20 $ 56,102.50
Document analysis 198.00 $ 123,525.00
Internal meetings, correspondence, and data requests 200.10 $ 110,450.00
Interviews 383.75 $ 233,200.00
Investigation - Cash flow 313.85 $ 187,742.50
Investigation - Factoring 173.90 $ 87,702.50
Investigation - Related Parties 57.75 $ 23,537.50
Investigation - SPV 135.65 $ 78,037.50
Investigation - Acquisitions 124.35 $ 74,022.50
Meetings and Correspondence with BSF 150.10 $ 95,300.00
Meetings with Third Parties and BSF 183.95 $ 123,060.00
Non-working travel 230.30 $ 73,585.00
Drafting observations and assisting BSF with draft report 16.10 $ 10,465.00
TOTAL 2,259.00 $ 1,276,730.00
11
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a. Case Administration: General administrative and organizational work
necessary to support the Examiner’s engagement and to ensure the orderly
conduct of the examination. This work included maintaining internal case files
and investigative materials, scheduling meetings and interviews, coordinating
travel and logistics, monitoring deadlines, organizing work streams among team
members, and addressing routine but necessary operational matters related to
the administration of the engagement. Time in this category also included
coordinating and accomplishing the transfer of and access to data, including access to
financial systems for further analysis.
b. Document Analysis: Identifying, accessing, and analyzing relevant
accounting records, financial systems, and document repositories. Reviewed
financial information maintained in the Debtors’ consolidation and reporting
systems together with treasury records, bank statements, general ledger
information, and supporting transaction documentation, to understand the
Debtors’ financial activities and identify matters requiring further
investigation. Reviewing accounting practices encountered during the
investigation, including consolidation adjustments, manual journal entries,
bridge spreadsheets, and differences between underlying accounting records
and reported financial results.
c. Internal Meetings, Correspondence, and Data Requests: Coordinated
among multiple workstreams, including meetings with third parties and
witness interviews. Prepared data requests and coordinated electronic data
requests and access to accounting systems and financial systems and
databases.
12
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d. Interviews and Investigative Coordination: Supported the Examiner’s
interviews and consultations with current and former employees, finance and
accounting personnel, information technology personnel, restructuring
professionals, and third-party advisors and counterparties. Assisted with
identifying relevant financial issues, reviewing supporting records, and
evaluating witness information in conjunction with transaction data and other
evidence. Participated in meetings concerning data access, financial systems,
financing arrangements, and investigative findings.
e. Investigation – Cash Flow and Related-Party Transactions: Tracing
proceeds from third-party factoring and off-balance sheet financing
transactions and examining the subsequent movement and use of those funds.
Analyzed transfers among the Debtors, special purpose vehicles, insiders,
trusts, and affiliated entities to identify potentially improper transfers and
develop the factual record concerning the disposition of value generated by
the Debtors.
f. Investigation – Acquisitions: Reviewing acquisition-related transactions,
including discrepancies between internally reported acquisition consideration
and transaction payments, potential side payments, and the separation of
assets from acquired operating businesses. Examined available records assets
held by or transferred to affiliated non-Debtor entities, together with evidence
of commingling and transfers of operating resources.
g. Investigation - Third-Party Factoring: Reviewing the Debtors’ prepetition
factoring processes, financing arrangements, and related payment flows.
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Analyzed available receivables data, factoring schedules, supporting
spreadsheets, and witness information concerning invoice origination,
approval, submission, and verification. Examined evidence relating to
allegedly inflated, fabricated, or repeatedly factored receivables and the
processes and personnel involved in those transactions.
h. Investigation – Special Purpose Vehicles and Off-Balance Sheet
Financing: Examining financing arrangements involving special purpose
vehicles, inventory transactions, sale-leaseback structures, and related
transfers. Reviewed financial records and transaction documentation
concerning funding flows, asset ownership, collateral, and relationships
among the Debtors, financing counterparties, and affiliated entities to assist
the Examiner in evaluating how the arrangements operated in practice.
i. Meetings and Correspondence with the Examiner and BSF: Meet and
discuss work plan, information requests, access to data and accounting
systems, observations to date, and open items.
j. Meetings with Third Parties and BSF: Participate in meetings with
Debtors’ management, creditors, lenders, investors, and other third parties
along with their respective advisors. Coordinated data collection and analysis
of work performed by financial advisors for the various third parties.
k. Non-Working Travel: Services rendered under this task category consisted
of non-working travel time incurred in connection with the Examiner’s
investigation, including travel to witness interviews, site visits, meetings with
relevant parties, and other necessary in-person investigative activities in the
United States and abroad. Given the international nature of the relevant
14
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operations, records, and witnesses, certain travel was unavoidable to preserve
evidence, assess business locations and recordkeeping environments, and
advance the examination efficiently. The travel reflected in this category was
reasonable and necessary under the circumstances and was closely tied to
substantive investigative work.
l. Drafting Observations and Support of Examiner’s Report: Analyzing and
evaluating financial documentary evidence and developing the preliminary
financial findings reflected in the Examiner’s report. Analyzed available
documents and witness accounts concerning financial reporting to lenders and
auditors, the treatment of affiliated special purpose vehicles, and potential
accounting irregularities. Provided summary analysis concerning funds flows,
related-party transfers, financing structures, and accounting practices, and
assisted with identifying unresolved financial questions and targeted
investigative steps requiring additional records or analysis. This category also
included editing and source citation checking for accuracy, consistency, and
clarity.
35. The foregoing professional services were necessary and appropriate to the
Examiner’s investigation pursuant to the Work Plan. The professional services performed by
Guidepost were in the best interests of the Debtors’ estates. Compensation for such services is
commensurate with the complexity, importance, and nature of the issues and tasks involved. All
of Guidepost’s professional services were performed skillfully and efficiently.
36. The professional services performed by Guidepost during the Compensation Period
required an aggregate expenditure of approximately 2,259 hours.
15
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37. During the Compensation Period, Guidepost billed for time expended by
professionals based on hourly rates ranging from $325 to $700 per hour. Allowance of
compensation in the amount requested results in a blended hourly billing rate of $565.17.
ACTUAL AND NECESSARY EXPENSE DISBURSEMENTS
38. As set forth in Exhibit D attached hereto, Guidepost has disbursed $55,217.14 as
expenses incurred in providing professional services during the Compensation Period. These
expenses are substantially related to necessary travel-related transportation, lodging and meal
costs. The expenses were reasonable and essential to the Examiner’s investigation pursuant to the
Work Plan.
39. Guidepost’s regular practice is not to include components of those charges in
overhead when establishing billing rates and to charge its clients for these and all other out-of-
pocket disbursements incurred during the regular course of the rendition of services. The
reimbursement amounts do not exceed those set forth in the Fee Guidelines or the Bankruptcy
Local Rules.
40. Guidepost complied with the Fee Guidelines and Bankruptcy Local Rule 2016-1.
41. The actual expenses incurred in providing professional services were those that were
necessary, reasonable, and justified under the circumstances to facilitate the Examiner’s
investigation in accordance with the Work Plan.
THE REQUESTED COMPENSATION AND EXPENSE REIMBURSEMENT
SHOULD BE ALLOWED
42. Section 330(a)(1) of the Bankruptcy Code provides that a Court may award a
professional employed under (or, in this case, pursuant to the standards of) section 327 of the
Bankruptcy Code “reasonable compensation for actual, necessary services rendered…[and]
reimbursement for actual, necessary expenses.” 11 U.S.C. § 330(a)(1)(A)–(B).
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43. The Fifth Circuit Court of Appeals has held that lower courts should consider the
six factors found in section 330(a)(3) of the Bankruptcy Code when awarding compensation to
professionals. See In re Crager, 691 F.3d 671, 676 (5th Cir. 2012). Specifically, under section 330
of the Bankruptcy Code, courts “shall consider the nature, the extent, and the value of such
services, taking into account all relevant factors,” including:
(A) the time spent on such services;
(B) the rates charged for such services;
(C) whether the services were necessary to the administration
of, or beneficial at the time at which the service was
rendered toward the completion of, a case under this title;
(D) whether the services were performed within a reasonable
amount of time commensurate with the complexity,
importance, and nature of the problem, issue, or task
addressed;
(E) with respect to a professional person, whether the person
is board certified or otherwise has demonstrated skill and
experience in the bankruptcy field; and
(F) whether the compensation is reasonable based on the
customary compensation charged by comparably skilled
practitioners in cases other than cases under this title.
44. In the instant case, Guidepost submits that the services for which they seek
compensation and the expenditures for which they seek reimbursement in this Application were
necessary for and beneficial to facilitating the important work of the Examiner and his
professionals under the Work Plan, ultimately resulting in the Examiner Report. The compensation
requested herein is reasonable considering the nature, extent, and value of such services to the
Debtors’ estates.
45. The requested compensation for the foregoing services is commensurate with the
complexity, importance, and nature of the issues and tasks involved. Not only were the
professional services performed skillfully and efficiently, but whenever possible, they sought to
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Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 18 of 20
minimize the cost of services by utilizing talented junior staff to handle various aspects of the work
commensurate with their skill levels.
46. Accordingly, approval of the compensation for professional services and
reimbursement of expenses already paid to Guidepost pursuant to the Interim Compensation Order
is warranted. While Guidepost seeks allowance of all fees and expenses incurred during the
Application Period, it does not seek, through this Application, compensation or expense
reimbursement above amounts already paid to Guidepost.
NOTICE
47. Notice of this Application will be served on any party entitled to notice pursuant to
Bankruptcy Rule 2002 and any other party entitled to notice pursuant to Bankruptcy Local Rule
9013-l(d).
CONCLUSION
48. Guidepost respectfully requests that the Court enter an order pursuant to section
330(a) of the Bankruptcy Code and the Interim Compensation Order: (i) approving the fees and
expenses incurred by Guidepost during the Compensation Period; (ii) approving the compensation
and expense reimbursement already paid to Guidepost pursuant to the Interim Compensation
Order; and (iii) granting such other and further relief as the Court may deem just and proper.
[Signature block on next page]
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Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 19 of 20
Dated: October 26, 2026
Respectfully submitted,
/s/ Jesse Panuccio
BOIES SCHILLER FLEXNER LLP
Jesse Panuccio (admitted pro hac vice)
401 East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 33301
(954) 356-0011
jpanuccio@bsfllp.com
BOIES SCHILLER FLEXNER LLP
Robert D. Gordon (admitted pro hac vice)
55 Hudson Yards
New York, NY 10001
(212) 446-2300
rgordon@bsfllp.com
BOIES SCHILLER FLEXNER LLP
Benjamin Waisbren (admitted pro hac vice)
1401 New York Ave, NW
Washington, DC 20005
(202) 237-2727
bwaisbren@bsfllp.com
-and-
OKIN ADAMS BARTLETT CURRY LLP
Matthew S. Okin
Texas Bar No. 00784695
Email: mokin@okinadams.com
Ryan A. O’Connor
Texas Bar No. 24098190
Email: roconnor@okinadams.com
Madeline M. Schmidt
Texas Bar No. 24130309
Email: mschmidt@okinadams.com
1113 Vine Street, Suite 240
Houston, Texas 77002
Tel: 713.228.4100
Fax: 346.247.7158
Counsel to the Examiner
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Case 25-90399 Document 3994 Filed in TXSB on 10/26/26 Page 20 of 20
CERTIFICATE OF SERVICE
I hereby certify that on October 26, 2026, a true and correct copy of the foregoing Application
was served via the Court’s CM/ECF system to all parties consenting to service through the same.
By: /s/ Matthew S. Okin
Matthew S. Okin
20