Compeer Financial, ACA v. Corporate America Lending, Inc.

Background

On March 27, 2025, U.S. District Judge Jerry W. Blackwell appointed T. Scott Avila as receiver over the assets of Corporate America Lending, Inc. The receiver’s assignment was to identify and recover assets to satisfy awards issued by an arbitration merits panel. The receivership order set the receiver’s compensation at $850 per hour and allowed reimbursement for reasonable business and travel expenses associated with the receivership.

The order also authorized the receiver to employ professionals to assist with his duties. The court later authorized the receiver’s retention of Katten Muchin Rosenman LLP as counsel and Paladin Management Group as financial advisor. Both firms received initial retainers of $375,000. The firms intended to offset approved fees and expenses against those retainers.

First Fee Motion

The receiver sought approval of $253,585.41 for Katten, consisting of $250,197.00 in fees and $3,388.41 in expenses. He also sought approval of $318,574.80 for Paladin, consisting of $301,357.50 in fees and $17,217.30 in expenses. The motion included monthly statements describing the work performed. The receiver certified that the work was performed and necessary and that unnecessary or duplicative services had been removed. No party objected.

The court held a status conference after identifying concerns about whether the receiver had followed the proposed fee-approval procedures. The receiver later clarified that the hourly rates charged by Katten matched its engagement letter and that an earlier rate table had incorrectly listed 2024 rather than 2025 billing rates.

Court’s Analysis and Ruling

The court applied a reasonableness standard as a safeguard for reviewing the requested payments. After reviewing the monthly statements, the court found the fees and expenses reasonable. It stated that the hourly rates were generally within the range contemplated by the orders authorizing Katten’s and Paladin’s employment and that the time spent was reasonable given the case’s complexity.

Judge Elizabeth Cowan Wright granted the receiver’s First Motion for Payment of Fees and Expenses. The court allowed Paladin $301,357.50 in compensation and $17,217.30 in expenses on a final basis, and allowed Katten $250,197.00 in compensation and $3,388.41 in expenses on a final basis. The receiver was authorized to pay Paladin $318,574.80 and Katten $253,585.41, with each payment offset by that firm’s $375,000 retainer.

The court also established procedures for future monthly fee motions. The receiver must file detailed monthly statements, provide notice to the specified parties, allow a 14-day objection period, and address any timely objections through a meet-and-confer process before the court conducts its review. The court cautioned Katten and Paladin to carefully consider staffing levels for future court proceedings and investigations.