UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF NEW YORK
In re:
The Diocese of Buffalo, N.Y.,
Debtor.

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Case No. 20-10322
Chapter 11

SUPPLEMENTAL DECLARATION OF GREGORY TUCKER IN SUPPORT OF
THE APPLICATION FOR AN ORDER AUTHORIZING RETENTION OF THE
TUCKER GROUP, LLC, AS COMMUNICATIONS CONSULTANT TO THE DIOCESE
Pursuant to 28 U.S.C. § 1746, I, Gregory Tucker, declare under penalty of perjury that
the following is true and correct to the best of my information, knowledge and belief:
1.

I am a founder and principal of The Tucker Group, LLC (“Tucker Group”), a

specialized communications consultancy with an office located at 101 Wendover Road,
Baltimore, Maryland.
2.

I am duly authorized to make and submit this Supplemental Declaration on behalf

of Tucker Group in connection with the Application For Entry Of An Order Authorizing The
Retention Of The Tucker Group, LLC, as Communications Consultant for the Diocese (the
“Application”),1 effective as of the Petition Date. Except as otherwise noted, I have personal
knowledge of the matters set forth herein and, if called as a witness, I would testify competently
thereto.
3.

In late 2019, the Diocese interviewed several potential communications

consultants and ultimately selected and engaged Tucker Group to provide guidance and
professional advice with respect to the Diocese’s messaging and media relations. Following the
departure of the Diocese’s former in-house director of communications in December 2019,

1

Capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the Application.

3562809.2

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 Tucker Group’s role has evolved to include overseeing all of the Diocese’s communications
activities. This includes, among other duties:
(a)

Arranging press conferences and assisting the Diocese in drafting clear
and concise press releases and public statements;

(b)

Responding to media inquiries regarding all aspects of the Diocese;

(c)

Facilitating the dissemination of news and information regarding the
Diocese’s mission, programs, operations and initiatives;

(d)

Monitoring and consulting with Diocesan leadership regarding media
coverage of the Diocese and the Catholic Church generally;

(e)

Advising Diocesan leadership regarding public perception of the Diocese
and its existing and proposed policies, practices or initiatives;

(f)

Coordinating communications between the Diocese and its clergy,
employees, parishes, schools and other Catholic entities in support of the
Diocese’s mission;

(g)

Assisting the Diocese in maintaining the goodwill of the Catholic faithful
and the public at large by ensuring clear and consistent messaging with
respect to the Diocese’s mission, management and operations, including,
without limitation, updates regarding the Diocese’s restructuring process
and developments in this Chapter 11 Case; and

(h)

Generally overseeing all internal and external Diocesan communications
plans and efforts.
Professional Compensation

4.

After discussions with the Diocese, Tucker Group has agreed to reduce its flat fee

of $15,000 per month to $10,000 per month as payment for its services, plus reimbursement of
out of pocket expenses to be capped at $3,500. Tucker Group received payment for services
rendered and expenses incurred in the 90 days prior to the Petition Date as follows:
(a)

On October 21, 2019, Tucker Group issued an invoice for October 2019
fees plus expenses incurred through the date of invoice. On December 13,
2019, Tucker Group received payment of $17,079.71 in satisfaction of that
invoice.

(b)

On November 26, 2019, Tucker Group issued an invoice for November
2019 fees plus expenses incurred through the date of invoice. On
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 December 20, 2019, Tucker Group received payment of $18,789.75 in
satisfaction of that invoice.

5.

(c)

On January 13, 2020, Tucker Group issued an invoice for December 2019
fees plus expenses incurred through the date of invoice. On January 31,
2020, Tucker Group received payment of $19,391.21 in satisfaction of that
invoice.

(d)

On February 10, 2020, Tucker Group issued an invoice for January 2020
fees plus expenses incurred through the date of invoice. On February 25,
2020, Tucker Group received payment of $20,370.93 in satisfaction of that
invoice.

(e)

The Diocese paid Tucker Group’s February fees and expenses in the
amount of $17,917.10 by wire transfer on February 27, 2020.2

Accordingly, Tucker Group is not owed any prepetition fees or expenses and is a

disinterested person in accordance with 11 U.S.C. § 101(14).
6.

In reviewing the prepetition payments received by Tucker Group in connection

with preparing this Supplemental Declaration, Tucker Group identified $8,785.19 in prepetition
overpayments by the Diocese, due to a clerical error caused by a double counting of expenses
incurred. Tucker Group will credit these overpayments against its postpetition invoices.
7.

Tucker Group intends to apply to the Court for payment of compensation and

reimbursement of fees and expenses in accordance with applicable provisions of the Bankruptcy
Code, the Bankruptcy Rules, the Local Rules and the Orders of this Court.
[signature page follows]

2

The calculation of fees and expenses paid prior to the Petition Date set forth in my initial declaration in support of
the Application included an initial payment in the amount of $1,152.08 which was received on November 5, 2019,
more than 90 days prior to the Petition Date, but inadvertently omitted the February 27, 2020 wire.

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 Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct.
Dated: June 29, 2020
The Tucker Group, LLC
By:

/s/ Gregory Tucker
Gregory Tucker
Founder/Principal

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