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Case 1:20-bk-12043 Doc 436-1 FiL-d 09/18/20 Entered 09/18/20 15:58:33 Desc <br />Exhibit A Proposed Conversion Order Page 5 of 6 <br />Court, the Debtors, the chapter 7 trustee (once appointed), or any parry in <br />interest with respect to the Debtors' Chapter 11 Cases or the chapter 7 <br />cases. Furthermore, Epiq is authorized to shred or otherwise dispose of all <br />noticing and other dements that have been returned by the post office as <br />undeliverable mail. <br />6. Notwithstanding anything to the contrary in the Final DIP Order, the Funded <br />Reserve Account, which is being held by Epiq as escrow agent, shall be disbursed by Epiq only <br />upon entry of, and in accordance with the harms of, such further order or orders of the Court as <br />may be entered following the filing of Fiscal Fee Applications and notice and opportunity to <br />object thereto in accordance with the proeednnres set forth in Paragraph 3(a) above. No chapter 7 <br />trustee or any party in interest (other than tke applicable Professionals) shall have any rights or <br />claims to the Funded Reserve Account. <br />7. The Carve Out in the amount of $20,000.00 for a chapter 7 trustee, as provided by <br />Paragraph 10(b) of the Final DIP Order, slftl be deemed funded by allowing $20,000.00 of the <br />Debtors' funds to remain in a bank acc mmt of the Debtors where such funds shall remain <br />available to satisfy the reasonable fees and expenses of any interim or permanent chapter 7 <br />trustee, as applicable, for the Debtors' bankniptcy cases. <br />8. Notwithstanding anything in the Bankruptcy Code, the Bankruptcy Rules, or the <br />Local Bankruptcy Rules for the United States Bankruptcy Court for the Southern District of <br />Ohio to the contrary, but subject in all respects to this Conversion Order, all prior orders, rulings <br />and judgments of this Court made during the course of the Debtors' Chapter 11 Cases and any <br />related adversary proceedings, including, without limitation, the Final DIP Order and the Sale <br />Order, shall remain in full force and effect, shall be unaffected by the conversion of these <br />Chapter 11 Cases, and are specifically preserved for purposes of finality of judgment and res <br />judicata, as applicable. <br />M <br />