In Re Financial News Network Inc.
This memorandum decision addresses motions by Gibson, Dunn & Crutcher and Kramer, Levin, Nessen, Kamin & Frankel, counsel for the debtor (Financial News Network, FNN) and the equipment lessors committee respectively, seeking payment of prepetition fees in FNN's Chapter 11 bankruptcy case. Gibson, Dunn sought payment through the assumption of an employment agreement at a premium rate, while Kramer, Levin sought compensation under Section 503(b) for substantial contribution. The court denied Gibson, Dunn's motion, ruling that professional compensation is governed by Sections 327-330 of the Bankruptcy Code, not Section 365, and rejected the "doctrine of necessity" in this context. Kramer, Levin's motion for prepetition fees was also denied, without prejudice, as the court deemed the determination of "substantial contribution" premature and best addressed at the conclusion of the case.