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Case 1:20-bk-12043 Doc 436 Filed 09/18/20 Entered 09/18/20 15:58:33 Desc Main <br />Document Page 4 of 8 <br />B. Other Administrative Matters. <br />8. On July 24, 2020, this Court entered the Order Implementing Certain Notice and <br />Case Management Procedures (Docket No. 89) pursuant to which this Court approved <br />procedures governing applications for and payments of fees and expenses requested by <br />Professionals (the "Interim Compensation Procedures"). A Funded Reserve Account was <br />established in order to provide funding to pay accrued Professional fees, and the Funded Reserve <br />Account is defined and more fully described in Paragraph 10 of this Court's Final Order (I) <br />Authorizing the Debtors to (A) Obtain Postpetition Financing and (B) Use Cash Collateral, (II) <br />Granting Liens and Providing Superpriority Administrative Expense Status, (III) Granting <br />Adequate Protection to the Prepetition Secured Parties, (IV) Modifying the Automatic Stay, and <br />(V) Granting Related Relief (Docket No. 238) (the "Final DIP Order"). Pursuant to Paragraph <br />10 of the Final DIP Order, "no cost or expense of administration under the Bankruptcy Code or <br />otherwise, shall be senior to, or pari passu with, the payments that are authorized and consented <br />to in this Paragraph 10 [of the Final DIP Order]." <br />RELIEF REQUESTED <br />9. By this motion, the Debtors request entry of the Conversion Order, substantially <br />in the form attached hereto as Exhibit A, providing the conversion of the Debtors' Chapter 11 <br />Cases to cases under chapter 7 pursuant to section 1112(a) of the Bankruptcy Code and <br />Bankruptcy Rule 1017(f), effective as of the Conversion Date, and approving the following <br />Conversion Procedures in connection with the conversion of these Chapter 11 Cases to chapter 7 <br />of the Bankruptcy Code: <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 />11 <br />