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Case 1:20-bk-12043 Doc 107 Filed 07/27/20 Entered 07/27/20 15:07:21 Desc Main <br /> Document Page 10 of 13 <br /> for the previous month, which report would include the names and tasks filled by all Engagement <br /> Personnel involved in this matter. The Staffing Report (and Cambio's staffing for this matter) <br /> would be subject to review by the Court in the event so requested by any of the Notice Parties. <br /> 27. Cambio received $120,000 as a retainer in connection with preparing for and <br /> conducting the filing of these Chapter 11 cases, as described in the Engagement Letter. In the 90 <br /> days prior to the Petition Date, Cambio received payments totaling approximately $119,000 in <br /> the aggregate for services performed for the Debtors. Cambio has applied these funds to amounts <br /> due for services rendered prior to the Petition Date. <br /> 28. A precise disclosure of the amounts or credits held, if any, as of the Petition Date <br /> will be provided in Cambio's first report filed regarding compensation earned and expenses <br /> incurred. The unapplied residual retainer, which is estimated to total approximately $120,000, <br /> and will be held until the end of these Chapter 11 cases and applied to Cambio's finally approved <br /> fees in these proceedings, unless an alternate arrangement is agreed to by the Debtors. <br /> 29. Given the numerous issues which the Engagement Personnel may be required to <br /> address in the performance of their services, Cambio's commitment to the variable level of time <br /> and effort necessary to address all such issues as they arise, and the market prices for such <br /> services for engagements of this nature in an out-of-court context, as well as in chapter 11, the <br /> Debtors submit that the fee arrangements set forth in the Engagement Letter are reasonable. <br /> APPLICABLE AUTHORITY <br /> 30. The Debtors seek approval of the employment of Cambio pursuant to section 363 <br /> of the Bankruptcy Code, nunc pro tunc to the Petition Date. Section 363(b)(1) of the Bankruptcy <br /> Code provides in relevant part that "[t]he trustee, after notice and a hearing, may use, sell, or <br /> lease, other than in the ordinary course of business, property of the estate." 11 U.S.C. § <br /> 363(b)(1). Further, pursuant to section 105(a) of the Bankruptcy Code, the "court may issue any <br /> 10 <br />