California Independent Petroleum Association

CourtUnited States Bankruptcy Court, E.D. California
DecidedJanuary 18, 2022
Docket21-23169
StatusUnknown

This text of California Independent Petroleum Association (California Independent Petroleum Association) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
California Independent Petroleum Association, (Cal. 2022).

Opinion

1 UNITED STATES BANKRUPTCY COURT 2 EASTERN DISTRICT OF CALIFORNIA 3 In re: ) Case No. 21-23169-B-11 ) 4 CALIFORNIA INDEPENDENT ) DC No. SK-8 PETROLEUM ASSOCIATION, ) 5 ) ) 6 Debtor(s). ) ________________________________) 7 8 MEMORANDUM DECISION GRANTING DEBTOR’S MOTION FOR AUTHORITY TO RETAIN AND COMPENSATE CONSULTANTS UNDER 11 U.S.C. § 363 9 Before the court is the Debtor’s Motion for Authority to 10 Retain and Compensate Consultants Utilized in the Ordinary Course 11 of Business filed by chapter 11 debtor and debtor in possession 12 California Independent Petroleum Association (“Debtor”). The 13 motion is supported by the declaration and supplemental 14 declaration of the Debtor’s Chief Executive Officer, declarations 15 of the entities that the Debtor moves to retain as consultants, a 16 reply, and supplemental points and authorities. 17 Creditors Youth for Environmental Justice, South Central 18 Youth Leadership Coalition, and Center for Biological Diversity 19 (collectively, “NPC”) filed an initial opposition and a 20 supplemental response. Other than references to the docket, 21 NPC’s initial opposition and the supplemental response are not 22 supported by other evidence. Notably, NPC submitted no evidence 23 that contradicts or otherwise refutes the Debtor’s written 24 evidence. 25 The United States trustee also filed a limited objection to 26 the motion. The limited objection references the docket and 27 includes no additional supporting evidence. 28 The motion was filed, set, and served under Local Bankr. R. 1 9014-1(f)(2). It was initially before the court on November 23, 2 2021, at which time the court ordered a briefing schedule 3 pursuant to Local Bankr. R. 9014-1(f)(2)(C) at NPC’s request. 4 The court has reviewed all relevant documents, declarations, 5 and exhibits. The court has also reviewed and takes judicial 6 notice of the docket. See Fed. R. Evid. 201(c)(1). 7 The motion is appropriate for disposition without oral 8 argument which will not assist in the decision-making process. 9 See Local Bankr. R. 1001-1(f), 9014-1(h). The continued hearing 10 on January 25, 2022, will be vacated. Findings of fact and 11 conclusions of law are set forth below. See Fed. R. Civ. P. 12 52(a); Fed. R. Bankr. P. 7052, 9014(c). 13 14 Prefatory Comment 15 The Debtor moves for authorization under 11 U.S.C. § 363 to 16 retain and collectively compensate at $50,000.00 per month 17 several entities that provided the Debtor with policy and 18 legislative-related advice, advocacy, guidance, communication, 19 monitoring, research, consulting, and lobbying services in the 20 years and months before this bankruptcy case was filed. The 21 court will refer to the entities as “Consultants” because, as 22 discussed below, that is what the evidence overwhelmingly 23 establishes the entities are. 24 NPC’s initial opposition questions whether the Debtor may 25 retain and compensate the Consultants under § 363. The initial 26 opposition strongly suggests that the Consultants are 27 “professional persons” who must be employed under 11 U.S.C. § 28 327(a) and compensated under 11 U.S.C. § 330. It also requests - 2 - 1 that the court “either deny the Motion in its entirety or set a 2 briefing schedule[.]” Docket 106 at 4:16-17. And it essentially 3 requests injunctive relief insofar as it asks the court to “order 4 the Debtor to stop paying the consultants who are the subject of 5 the Motion pending the Court’s ruling on the Motion[.]” Id. at 6 4:13-14. 7 NPC has apparently decided to retreat from its initial 8 opposition. Although NPC asks the court to reduce the 9 Consultants’ collective monthly compensation by $10,000.00, as 10 does the United States trustee, it now states in its supplemental 11 response that it will defer to the court and the United States 12 trustee on the issue of whether the Consultants are “professional 13 persons” under § 327(a) of the Bankruptcy Code.1 NPC also states 14 that it reserves the right to revisit the Consultants’ 15 compensation, which it characterizes as discretionary spending, 16 in the context of plan confirmation. 17 18 Background 19 NPC consists of “three nonprofit environmental and social 20 justice organizations[.]” Youth for Environmental Justice v. 21 City of Los Angeles, 2019 WL 642452 at *1 (Cal. App. 2d Div., 22 Feb. 15, 2019). NPC’s mission and its message differ 23 dramatically from the Debtor’s core mission and message. NPC and 24 the Debtor are also litigation adversaries. 25 The Debtor is a California corporation incorporated pursuant 26 to Internal Revenue Code § 501(c)(6). The Debtor filed this 27 28 1The United States trustee takes no position on the issue. - 3 - 1 subchapter v chapter 11 case on September 5, 2021. The Debtor 2 continues to operate and manage its affairs as a debtor in 3 possession under 11 U.S.C. § 1184. 4 The Debtor’s mission, and its core business purpose, is to 5 promote greater understanding and awareness of the unique nature 6 of California’s independent oil and natural gas producers and the 7 marketplace in which they operate including the economic 8 contributions made by California independents to local, state, 9 and national economies, to otherwise foster the efficient 10 utilization of California’s petroleum resources, and to promote a 11 balanced approach to resource development and environmental 12 protection in order to improve business conditions for the 13 Debtor’s members. The Debtor generates revenue by performing its 14 core mission. As a matter of internal operations, the Debtor has 15 determined that the postpetition retention of the Consultants is 16 critical to its ability to continue to perform its core mission. 17 Retention of the Consultants also benefits creditors. In 18 the two years before the Debtor filed its chapter 11 petition it 19 reduced its workforce from eight staff members to four. This 20 resulted in a reduction in payroll costs from $1,658,000.00 for 21 fiscal year 2019 to approximately $1,052,000.00 expected in 2021. 22 The Debtor has used the Consultants to fill the gap resulting 23 from the workforce reduction. In that regard, the Consultants 24 provide services that are otherwise performed by employees 25 without the need for the Debtor to incur insurance, travel, 26 overhead, and other auxiliary costs associated with additional 27 employees. Use of the Consultants in this capacity has resulted 28 in a cost-effective alternative to hiring additional employees. - 4 - 1 The Debtor has identified eight Consultants.2 Each 2 Consultant has submitted a declaration that describes in detail 3 its pre- and postpetition services, and which further confirms 4 that the services provided are no different than services that an 5 employee of the Debtor would perform. The Consultants and their 6 respective services are as follows: 7 (1) Geosyntech Consultants, Inc. [Docket #120] 8 • Biweekly Member Meetings: Prepare for and attend biweekly meetings with the Firm, Catalyst Environmental 9 Solutions (Catalyst), and CIPA members. Preparation for biweekly meetings consists of updating graphics, 10 processing data received from data requests, and updating meeting agendas.

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California Independent Petroleum Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/california-independent-petroleum-association-caeb-2022.