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Case 1:20-bk-12043 Doc 107-2 Filed 07/27/20 Entered 07/27/20 15:07:21 Desc <br /> Exhibit B - Declaration of Thomas Fairfield Page 3 of 4 <br /> tunc to the Petition Date. Except as otherwise noted, I have personal knowledge of the matters <br /> set forth herein. <br /> 2. Cambio utilizes certain procedures to determine its relationships, if any, to parties <br /> that may have a connection to any of the Debtors in the Chapter I 1 Cases. The following actions <br /> were taken to identify parties that may have connections to the Debtors and to determine the <br /> Cambio's relationship with such parties: <br /> (a) Cambio requested and obtained from the Debtors lists of interested parties and <br /> significant creditors (the "Potential Parties in Interest"). The Potential Parties in <br /> Interest reviewed include, without limitation: (i) the Debtors and their affiliates; (ii) the <br /> Debtors' and their affiliates' former and current officers and directors; (iii) the Debtors' <br /> banks, lenders, lien parties and administrative agents; (iv) the Debtors' utility providers; <br /> (v) the Debtors' insurance providers, surety bond issuers, and surety bond obligees; (vi) <br /> the Debtors' landlords; (vii) potential and active litigation counterparties; (vin) the <br /> Debtors' professionals; (ix) the Debtors' vendors; (x) the Debtors' non-affiliate energy <br /> distribution companies; (xi) taxing authorities; (xii) regulatory agencies and <br /> governmental municipalities; (xiii) relevant bankruptcy professionals, including those <br /> professionals proposed to be retained in the chapter 11 cases; (xiv) the Debtors' top 40 <br /> unsecured creditors; and (xv) United States Trustee's Office for the Southern District of <br /> Ohio,judges and court personnel for the Southern District of Ohio. <br /> (b) Cambio then compared the names of each of the Potential Parties in Interest to the <br /> names of Cambio's current and former clients. <br /> 3. Based on the conflict search described above, I have thus far ascertained that, <br /> except as may be set forth herein, upon information and belief, if retained, Cambio: <br /> (a) is not a creditor of the Debtors (including by reason of unpaid fees for prepetition <br /> services) or an equity security holder of the Debtors; <br /> (b) is not and has not been, within 2 years before the date of the filing of the petition, a <br /> director, officer (other than by virtue of Cambio employees serving in the roles as <br /> Engagement Personnel (pre- and post-petition) as described in the Application), or an <br /> employee of the Debtors; and <br /> (c) does not have any interest materially adverse to the interests of the Debtors' <br /> estates, or of any class of creditors or equity security holders, by reason of any direct or <br /> 3 <br />