2025-01-23 ParshmanStein, WalderHayden - Whiteford LQ Engagement Ltr for SDC BK Chapter 11 CaseRichard W. Riley
Counsel
rriley@pashmanstein.com
Direct: 302.327.6790
January 14, 2025
Via Electronic Mail (jmcmillen(i laquintaca.gov)
Jon McMillen
City Manager
City of La Quinta
78-495 Calle Tampico,
La Quinta, CA 92253
Re: Engagement Letter with Pashman Stein
Dear Jon:
PashmanStein
WalderHayden
A Professional Corporation
We are delighted that you have asked Pashman Stein Walder Hayden, P.C. ("PashmanStein" or
the "firm") to act as Delaware counsel, with Whiteford Taylor & Preston, LLP ("Whiteford")
acting as your primary counsel, in representing and advising the City of LaQuinta (the "Client")
in connection with the chapter 11 bankruptcy cases (the "Bankruptcy Cases") of SilverRock
Development Company, LLC and its related debtor (the "Debtors") pending in the United States
Bankruptcy Court for the District of Delaware (the "Engagement").
This agreement shall provide the terms of our engagement and our billing arrangements for our
work on this matter. PashmanStein's engagement in this matter shall be effective as of January
13, 2025.
1. Scope of Engagement
You have engaged PashmanStein to represent the Client in connection with the above referenced
Engagement, and such other matters as may be agreed to in writing in the future between Client
and PashmanStein.
2. Staffing
We staff matters with the goal of providing legal services of the highest quality on the most cost-
effective basis possible. In the interest of efficiency, we may draw upon the talents and experience
of lawyers throughout our firm.
Our firm's work on this matter will be led by me. As this matter proceeds, we may need to add
additional attorneys to our team as necessary to meet time demands and to draw upon relevant
824 North Market Street
Suite 800
Wilmington, DE 19801
Phone: 302.327.6790
Fax: 201.488.5556
www.pashmanstein.com
January 14, 2025
Page 2
PashmanStein
WalderHaydenn
A Professional Corporation
expertise and skillsets in our firm. We will work closely with Whiteford, as the Client's primary
counsel.
3. Billing Policies and Procedures
We will bill for services rendered based on a number of factors, including the time spent on the
matter (billed in 0.1 hour increments) and our normal hourly rates in effect at the time the bill is
rendered. The hourly rates for people working on matters vary in accordance with their experience
and expertise. My time will be billed at my current rate of $650 per hour. Our associate rates are
currently $485 to $545 per hour, and our paralegal rate is currently $430 per hour. Our hourly
rates are subject to adjustment by the firm from time to time, and it is not our practice to notify
clients of such changes.
The overall cost of an assignment reflects staffing, experience and efficiency. We seek to manage
projects so that lawyers with experience relating to a particular project can bring that experience
to bear, and so that each task is performed as cost-effectively as possible by a lawyer who is
appropriate for the task. I will be happy to discuss project management and staffing matters with
you at any time.
We also bill for out-of-pocket disbursements and certain other expenses and service charges,
including photocopying, word processing, telecopying, filing fees, required secretarial overtime,
and amounts paid to outside vendors (e.g., messenger services). We usually require our clients to
pay substantial disbursements in advance, or to pay them directly to outside vendors.
In accordance with our standard billing practice, we expect to bill on a monthly basis. All bills are
payable upon receipt and payment is not contingent upon the outcome of a matter. In our
experience, clients find monthly billing to be helpful in monitoring the nature and amount of
services. We understand for this matter we will send our bills to Whiteford to be submitted to you
for payment with their bills and we will be paid when Whiteford receives payment for the bills.
In addition to keeping you informed currently through monthly billing, we would seek to consult
you in advance before undertaking any major new task in our representation, and to keep you
informed where our fees, disbursements and other charges stand on an ongoing basis, if you so
request.
If a dispute arises as to the amount of the fee being charged, you may have the right to seek
arbitration of the fee dispute. We will provide you with the necessary information regarding such
processes in the event of a dispute, or at any time upon your request.
824 North Market Street
Suite 800
Wilmington, DE 19801
Phone: 302.327.6790
Fax: 201.488.5556
www.pashmanstein.com
January 14, 2025
Page 3
4. Retainer
We do not require a retainer for this engagement.
5. Conflict Waiver
PashmanStein
WalderHaydenn
A Professional Corporation
The Client acknowledges that from time to time the firm, which regularly represents clients in
distressed, bankruptcy and restructuring matters, may be engaged and/or has already been engaged
and will be, or has been, acting on behalf of entities taking positions that are actually or potentially
adverse to the Client's interests in past, present and future bankruptcy and restructuring matters
unrelated to the subject matter of Engagement where the Client may be a creditor or interested
party ("Unrelated Matters"). The Client hereby waives, to the fullest extent permitted by law, any
claim that the firm's representation of the Client pursuant to the Engagement has or will have given
rise to any actual or potential conflict -of -interest in connection with the firm's involvement in any
Unrelated Matters on behalf of clients that are not the Client, even if the interests of such clients
in such Unrelated Matters are directly adverse to you or the Client.
6. Termination of Representation
Above all, our relationship with you must be based on trust, confidence and clear understanding.
If you have any questions about this agreement or about any aspect of the work that the firm, or
any of the firm's lawyers is performing on your behalf, please call Henry or me directly to discuss
the matter. We encourage you to inquire about any matter concerning the attorney -client
relationship that is in any way unclear or unsatisfactory. You may, of course, terminate our
representation at any time for any reason. Subject to ethical obligations, we reserve the right to
withdraw from an engagement if our statements are not being paid in a timely manner or if for any
other reason the lawyer -client relationship is not proceeding in a satisfactory manner.
If the foregoing correctly sets forth our agreement, please so indicate by signing in the space
provided below and return an executed copy of this letter to us. Please also maintain a copy of
this agreement in your files.
We invite you to consult with us at any time and on any topic. We look forward to working with
you on this important matter.
Very truly yours,
/s/ Richard W. Riley
Richard W. Riley
824 North Market Street
Suite 800
Wilmington, DE 19801
Phone: 302.327.6790
Fax: 201.488.5556
www.pashmanstein.com
January 14, 2025
Page 4
Agreed to and accepted on this
23 day of January, 2025
Name: Jon McMillen
Title: City Manager
City of La Quinta
cc: Brad Englander (benglander@whitefordlaw.com)
824 North Market Street
Suite 800
Wilmington, DE 19801
Phone: 302.327.6790
Fax: 201.488.5556
www.pashmanstein.com
PashmanStein
WalderHaydenn
A Professional Corporation