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Case 1:20-bk-12043 Doc 436-1 Filed 09/18/20 Entered 09/18/20 15:58:33 Desc <br />Exhibit A Proposed Conversion Order Page 3 of 6 <br />to section 1112(a) of the Bankruptcy Code, (i) converting the Debtors' Chapter l I Cases to cases <br />under chapter 7 of the Bankruptcy Code, (ii) establishing a deadline for filing final chapter 11 fee <br />applications, and (iii) granting related relief, and it appearing that this Court has jurisdiction to <br />consider the Motion pursuant to 28 U.S.C. §§ 1334 and 157; and it appearing that this is a core <br />matter pursuant to 28 U.S.C. § 157(b)(2) and that this Court may enter a final order consistent <br />with Article III of the United States Constitution; and it appearing that venue of these Chapter 1 I <br />Cases and of the Motion is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and it appearing that <br />due and adequate notice of the Motion has been given under the circumstances, and that no other <br />or further notice need be given; and this Court having determined that the relief requested in the <br />Motion is in the best interests of the Debtors, their estates, their creditors, and other parties in <br />interest; and after due deliberation and sufficient cause appearing therefor, <br />IT IS HEREBY ORDERED THAT: <br />1. The Motion is GRANTED, as set forth herein. <br />2. Effective as of October 13, 2020 (the "Conversion Date"), the Cuter 11 Cases <br />shall be converted to cases under chapter 7 of the Bankruptcy Code. <br />3. The following Conversion Procedures are hereby approved: <br />a. Professional Fees. To the extent Professionals have not already <br />submitted final fee applications to the Court (the "Final Fee <br />Applications"), all professionals shall submit Final Fee Applications in <br />accordance with the Bankruptcy Code, Bankruptcy Rules, Local Rules, <br />and the Interim Compensation Order, by no later than thirty (30) days after <br />the Conversion Order is entered (the "Final Fee Application Deadline"). <br />Objections, if any, to the Final Fee Applications shall be filed and served <br />by no later than twenty-one (21) days after the Final Fee Application <br />Deadline. The Court will schedule a hearing, if necessary, at the Court's <br />convenience and subject to the Court's availability, on such Final Fee <br />Applications within fourteen (14) days thereafter or such later date as the <br />Court determines. To the extent no objections are filed to a given <br />Professional's Final Fee Application, such Professional may file a <br />Certificate of No Objection, and the Court may enter an order approving <br />2 <br />