In re: American Titantum Works LLC

Opinion

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) In re: ) Case No. 24bk06559 American Titantum 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 TOTALCOSTS 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. I” 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 PRES \ Timothy A Barnes, Judge United States Bankruptcy Court

1900 Avenue of the Stars, 19th Floor Los Angeles, CA 90067 (310) 440-4100 RAINES FELDMAN LITTRELL LLP Www.raineslaw.com 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. see 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.

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1) 07/21/2025 JSP Analyze Sax/Debtor/American Titanium Works . 2.30 690.00 1,587.00 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. es Co 8 BRAGG seaon ie, a ee es □ □□ ae ee oe ee oe 07/21/2025 JSP Phone call with Mark Kaplan regarding New 0.20 690.00 138.00 York Titanium claim, whether engagement letter or email can be found and forwarded, and discrepancy between claim and scheduled amount. Nene Ta EE □□ —CCOWiths Bailie: Tronox, ATW, Inc and ERE CC ) 07/22/2025 JSP Call with T. Sax regarding Financial Relations 1.10 690.00 759.00 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. rr respond with cont a ee a ae cL ales rer ee a 07/22/2025 JSP Follow up email to CFO for Invest SC Inc 0.20 690.00 138,00 requesting to be connected to company counsel to discuss SOL issue; review response and reply to counsel with copy of claim and _ SOLissue. .