`
`SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
`ONE R ODNEY SQUARE
`P.O. BOX 636
`WILMINGTON, DELA WARE 19899-0636
`
`________
`
`
`TEL: (302) 651-3000
`FAX: (302) 651-3001
`www.skadden.com
`
`DIRECT DIAL
`(302) 651-3230
`DIRECT FAX
`(302) 552-3230
`EMAIL ADDRESS
`Jennifer.Voss@skadden.com
`
`
`May 12, 2021
`
`FIRM/AFFILIATE OFFICES
`-----------
`BOSTON
`CHICAGO
`HOUSTON
`LOS ANGELES
`NEW YORK
`PALO ALTO
`WASHINGTON, D.C.
`-----------
`BEIJING
`BRUSSELS
`FRANKFURT
`HONG KONG
`LONDON
`MOSCOW
`MUNICH
`PARIS
`SÃO PAULO
`SEOUL
`SHANGHAI
`SINGAPORE
`TOKYO
`TORONTO
`
`
`
`
`BY HAND DELIVERY & EFILING
`The Honorable Kathaleen St. J. McCormick
`Chancellor
`Court of Chancery
`Leonard L. Williams Justice Center
`500 N. King Street, Suite 11400
`Wilmington, Delaware 19801
`
`RE:
`
`TransPerfect Global, Inc.,
`C.A. Nos. 9700-CM, 10449-CM (Del. Ch.)
`
`Dear Chancellor McCormick:
`
`I write on behalf of Robert B. Pincus, Esquire regarding the
`
`Court’s April 30, 2021 Order in the above-referenced actions, requiring
`
`Mr. Pincus to submit any fee petition that he intends to make for fees
`
`and expenses incurred in February 2021 and/or March 2021 by Saturday,
`
`
`
`EFiled: May 12 2021 02:22PM EDT
`Transaction ID 66594661
`Case No. Multi-Case
`
`
`
`The Honorable Kathaleen St. J. McCormick
`May 12, 2021
`Page 2
`
`
`
`
`
`May 15, 2021. (Dkt. 16051 (the “April 30 Order”))2 We are in the
`
`process of preparing the petition for fees and expenses incurred during
`
`those periods (the “Petition”), including incorporating guidance from the
`
`Court’s April 30 opinion (Dkt. 1604), and will submit the Petition no
`
`later than May 15, 2021.
`
`We wanted to advise the Court about a scheduling matter. Under
`
`the discharge order that the Court entered on April 14, 2021, Mr. Pincus
`
`is required to provide TransPerfect Global, Inc. (the “Company”) with a
`
`copy of the billing records with respect to any payment sought and an
`
`affidavit containing the information described by the Court during the
`
`hearing held on March 2, 2021. (Dkt. 1601 (the “Discharge Order”) ¶ 7)
`
`In accordance with that directive, we will be providing the billing
`
`records and affidavit to counsel for the Company shortly.
`
`
`1 Citations to “Dkt.” refer to docket C.A. No. 9700-CM.
`
`2 On March 2, 2021, the Court instructed Mr. Pincus not to submit any
`further fee petitions until the Court resolved the pending fee petitions.
`(Dkt. 1600 at 7, n.16)
`
`
`
`
`
`The Honorable Kathaleen St. J. McCormick
`May 12, 2021
`Page 3
`
`
`
`
`
`The Discharge Order also requires that the parties attempt to
`
`resolve any dispute over the fees and expenses sought “within fifteen
`
`business days” of when Mr. Pincus provides the billing records and
`
`affidavit to the Company. (Id.) Unfortunately, Mr. Pincus does not
`
`anticipate a consensual resolution regarding the fees and expenses,
`
`particularly in light of the positions that the Company has taken and its
`
`stated intent to appeal the April 30 Order; nevertheless, Mr. Pincus will
`
`attempt to engage in a meet and confer to resolve any disputes.
`
`We note that the Discharge Order states that Mr. Pincus may file
`
`with the Court a petition for fees and expenses “[i]f the matter is not
`
`resolved within such fifteen-day period.” (Id. (emphasis added))
`
`However, the fifteenth business day after April 30th is May 21st, six (6)
`
`days after the deadline established by the April 30 Order for submitting
`
`the Petition. As such, Mr. Pincus will be submitting the Petition no later
`
`than the date set forth in the April 30 Order – May 15, 2021 – even
`
`though the parties may not have had an opportunity to meet and confer
`
`by May 15th.
`
`
`
`
`
`The Honorable Kathaleen St. J. McCormick
`May 12, 2021
`Page 4
`
`
`
`
`
`I remain available at the call of the Court should Your Honor have
`
`any questions.
`
`Respectfully,
`
`/s/ Jennifer C. Voss
`
`Jennifer C. Voss (ID No. 3747)
`
`Words: 430
`
`cc:
`
`
`
`
`
`by eFile
`Register in Chancery
` Frank E. Noyes, II, Esq.
` Charles A. McCauley III, Esq.
` Jeremy D. Eicher, Esq.
` Kevin R. Shannon, Esq.
` Berton W. Ashman, Jr., Esq.
` Christopher N. Kelly, Esq.
` Jaclyn C. Levy, Esq.
`Mathew A. Golden, Esq.
`
`
`891872-WILSR01A - MSW
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
