NO PRIOR REQUEST. 51. No previous request for the relief sought herein has been made to this or to any other Court.
NO PRIOR REQUEST. 24. No prior request for the relief sought in this Motion has been made to this or any other court. [The remainder of this page is left intentionally blank] WHEREFORE, the Debtors request entry of an order, in the form annexed hereto as Exhibit C, authorizing Epiq Corporate Restructuring, LLC to act as claims and noticing agent for the maintenance and processing of claims and the distribution of notices. Dated: August 27, 2018 Respectfully submitted, New York, New York /s/ Xxxxxxx X. Xxxxxxx Xxxxxxx X. Xxxxxxx XXXXX & XXXXXXX LLP 00 Xxxx Xxxxxx Xxx Xxxx, Xxx Xxxx 00000-0000 Telephone: (000) 000-0000 Facsimile: (000) 000-0000 Email: xxxxxxxx@xxxxx.xxx - and - Xxxx X. Xxxxx (pro hac vice pending) XXXXX & LARDNER LLP 0000 Xxxxxxxxx Xxxxxx, Xxxxx 0000 Xxxxxxx, XX 00000-0000 Telephone: (000) 000-0000 Facsimile: (000) 000-0000 Email: xxxxxx@xxxxx.xxx Proposed Counsel for Debtors and Debtors in Possession XXXXXX XXXXXX, INC. (for itself and on behalf of its affiliates as Debtors and Debtors in Possession) By: /s/ Xxxxx X. Fleet Name: Xxxxx X. Fleet Title: Chief Restructuring Officer 18-23302-rdd Doc 9-1 Filed 08/27/18 Entered 08/27/18 18:26:54 Exhibit A Pg 1 of 15 EXHIBIT A Engagement Agreement EPIQ CORPORATE RESTRUCTURING STANDARD SERVICES AGREEMENT This Standard Services Agreement is being entered into by and between the undersigned parties, referred to herein as “Epiq” and “Client” as of the Effective Date, as defined below. In consideration of the premises herein contained and of other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows:
NO PRIOR REQUEST. 31. No prior motion for the relief requested has been made to this or any other Court.
NO PRIOR REQUEST. 10. No prior application seeking the relief requested in this Application has been made to this or any other court.
NO PRIOR REQUEST. 14. Xxxxxx has not made any previous application for the relief requested herein to this or any other court. WHEREFORE, Xxxxxx respectfully requests entry of an order in the form of the Proposed Order: (i) authorizing Xxxxxx to file under seal and make part of his Proof of Claim the Settlement Agreement; and (ii) directing that the sealed information shall remain under seal and not be made available to anyone, except as specifically provided for in the Proposed Order. Dated: July 12, 2017 Pittsburgh, PA Respectfully Submitted: Minto Law Group, LLC /s/ Xxxxx X. Xxxxx Xxxxx X. Xxxxx PA I.D. # 62133 Two Gateway Center 000 Xxxxxxx Xxxxxx, Xxxxx 0000 Telephone: (000) 000-0000 Facsimile: (000) 000-0000 xxxxxx@xxxxxxxx.xxx Attorney for Xxx Xxxxxx EXHIBIT A Minto Law Group, LLC Two Gateway Center 000 Xxxxxxx Xxxxxx, Xxxxx 0000 Telephone: (000) 000-0000 Facsimile: (000) 000-0000 Xxxxx X. Xxxxx Attorney for Xxx Xxxxxx UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------x In re : : Chapter 11 WESTINGHOUSE ELECTRIC : COMPANY LLC, et al., : Case No. 17-10751 (MEW) :
