2020-08-04_GENERAL DOCUMENTS - C2010088 (4)

Home Browse Search

Case 1:20-bk-12043 Doc 122-3 Filed 07/29/20 Entered 07/29/20 15:35:30 Desc Exhibit C - Declaration of Alan Boyko Page 3 of 25 Southern District of Ohio, dated December 4, 2019 (the "General Order"). Except as otherwise indicated, I have personal knowledge of the matters set forth herein, and, if called as a witness, would testify competently thereto. Oualifications 2. FTI is well qualified to represent the Debtors. In preparing for these chapter 11 cases, FTI has become familiar with the Debtors' business affairs and many of the potential financial and economic issues that may arise in connection with these chapter 11 cases. FTI has also acquired knowledge of the Debtors'businesses, financial affairs and capital structure. FTI has an intimate knowledge of the Debtors' operations and finances and FTI has expertise and experience in reorganizations and bankruptcy, particularly as it applies to financial considerations for business debtors. FTI has served as a consultant, chief executive officer, chief financial officer and chief restructuring officer for multiple companies, both in bankruptcy and non-bankruptcy situations. 3. FTI has a depth of experience in business reorganizations and financial management and is familiar with the Debtors, such that it is uniquely qualified to deal effectively with the legal issues that may arise in the context of the Debtors' reorganization. Services to be Rendered 4. Subject to this Court's approval of the Application, FTI is willing to serve as the Bankruptcy Consultant for the Debtors in these chapter 11 cases and to perform the following services for the Debtors: a. Assist the Debtors and their professionals, as requested, to support and maintain a 13-week debtor-in-possession budget and forecast; b. Assist the Debtors and their professionals, as requested, to prepare the Debtors to meet the requirements of filing for bankruptcy court protection;