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Case 1:20-bk-12043 Doc 115 Filed 07/28/20 Entered 07/28/20 14:14,41 Desc Main <br /> Document Page 4 of 8 <br /> 9. Prior to the commencement of the Chapter 11 Cases, WTP consulted with Lead <br /> Counsel and the Debtors regarding the possibility of filing these Chapter 11 Cases and potential <br /> conflict issues. WTP quickly acquired knowledge of the Debtors, their operations, and their <br /> businesses and legal/financial affairs. As a result, WTP is well-positioned to complement, assist <br /> and support Lead Counsel in providing the legal services required of it. Because of the necessity <br /> of WTP's services upon the filing of the Chapter 1 1 Cases and their contemplated pace,the Debtors <br /> seek for WTP to be retained nunc pro tunc to the Petition Date. <br /> 10. Section 327(e) of the Bankruptcy Code provides: <br /> The trustee, with the court's approval, may employ, for a specified <br /> special purpose,other than to represent the trustee in conducting the case, <br /> an attorney that has represented the debtor, if in the best interest of the <br /> estate,and if such attorney does not represent or hold any interest adverse <br /> to the debtor or to the estate with respect to the matter on which such <br /> attorney is to be employed. <br /> The Debtors submit that cause exists to retain WTP for the conflict issues that Lead Counsel may <br /> face in the Chapter 11 Cases and that such retention is in the best interests of the Debtors' estates. <br /> The Debtors must have the ability to address case issues swiftly in these Chapter 11 Cases, <br /> especially when Lead Counsel is unable to do so due to conflicts. <br /> SERVICES TO BE RENDERED <br /> 11. Subject to further order of this Court, WTP will provide specialized services to the <br /> Debtors regarding: <br /> (a) Matters that the Debtors may encounter in which Lead Counsel has, or <br /> believes it may have, an actual or potential conflict; <br /> (b) Such other tasks and matters as they arise and as specifically requested or <br /> assigned by the Debtors which, in their business judgment, would best <br /> serve the needs of the Chapter 11 Cases; and <br /> (c) Assisting, as needed and as requested, in any hearing in the Chapter 11 <br /> Cases related to the foregoing. <br /> 4 <br />