2020-08-04_GENERAL DOCUMENTS - C1980004 (7)

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Case 1:20-bk-12043 Doc 122 Filed 07/29/20 Entered 07/29/20 15:35:30 Desc Main r Document Page 7 of 8 22. As set forth in the Boyko Declaration, FTI received a general retainer from the Debtors of$75,000 which was received on or about February 4, 2020 (the "FTI Retainer"). FTI has been advised that the FTI Retainer was paid through funds generated from the Debtors' ordinary business operations.As of the Petition Date,the balance of the FTI Retainer was$75,000. 23. As of the Petition Date, FTI has no accrued or unpaid fees or expenses owing by the Debtors. If FTI subsequently determines there is an amount of outstanding fees and expenses incurred in contemplation of and in connection with the preparation of these Chapter 11 Cases, FTI will seek payment and reimbursement in connection with the initial fee statement and interim fee application to be filed with this Court. 24. Payment of FTI as proposed Bankruptcy Consultant to the Debtors in these Chapter 11 Cases will be subject to the approval of FTI's fees and expenses in accordance with the applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules and any applicable administrative orders that may be entered by this Court. 25. A statement of the compensation paid for services rendered or to be rendered in contemplation of or in connection with these Chapter 11 Cases by FTI, and the source of such compensation, is included in the Boyko Declaration. 26. The Debtors believe that the retention of FTI is in the best interests of the Debtors and their estates and desires to employ FTI as Bankruptcy Consultant. MOTION PRACTICE 27. This Application includes citations to the applicable rules and statutory authorities upon which the relief requested herein is predicated and a discussion of their applicability to this Application. Accordingly,the Debtors submit that this Application satisfies Local Rule 9013-1(a). 7