Laserfiche WebLink
Case 1:20-bk-12043 Doc 109-1 Filed 07/27/20 Entered 07/27/20 15:11:53 Desc <br /> Exhibit A - Declaration of Douglas L. Lutz Page 8 of 16 <br /> the Debtors or the estates, the Debtors' creditors, or any other party in interest, its respective <br /> attorneys and accountants, the United States Trustee or any person employed in the Cincinnati <br /> office of the United States Trustee. <br /> 18. From February 2003 to May 2011, Hon. Beth A. Buchanan, Judge for the United <br /> States Bankruptcy Court for the Southern District of Ohio, was employed by Frost Brown Todd <br /> as a Member. Such employment does not render Frost Brown Todd's retention as "improper" <br /> under Rule 5002(b) of the Bankruptcy Rules. <br /> 19. A substantial effort has been and will continue to be made to identify all of FBT's <br /> connections with the Potential Parties in Interest. FBT will maintain an ongoing inquiry regarding <br /> the Potential Parties in Interest and, if appropriate, will file promptly with this Court any <br /> appropriate supplemental disclosure to the Client Match List that becomes necessary. <br /> 20. In view of the foregoing, FBT is a"disinterested person" within the meaning of 11 <br /> U.S.C. § 101(14). <br /> COMPENSATION <br /> 21. Pursuant to the Engagement Letter, FBT has received a retainer from the Debtors <br /> in the aggregate amount of $250,000, which was received on March 20, 2020 (the "FBT <br /> Retainer"). I understand that the funds for the FBT Retainer were obtained by the Debtors through <br /> their normal and ordinary business operations. In accordance with the Engagement Letter, the <br /> Debtors agreed that FBT would periodically invoice the Debtors prepetition and that the Debtors <br /> would replenish the FBT Retainer. From March 20, 2020 to the Petition Date, FBT invoiced the <br /> Debtors and the Debtors replenished the FBT Retainer as follows: <br /> 7 <br />