Daniel M. Press, VSB# 37123 

Chung & Press, P.C. 

6718 Whittier Ave., Suite 200 

McLean, VA 22101 

(703) 734-3800 

Counsel for Debtor

UNITED STATES BANKRUPTCY COURT 

EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division)

---------------------------------------------------------------X 

In re: : Chapter 11 

 : 

Timothy E. Cliggott : No. _________ 

 : 

Debtor. : 

 : 

---------------------------------------------------------------X 

APPLICATION FOR ORDER AUTHORIZING THE EMPLOYMENT OF 

CHUNG & PRESS, P.C. AS COUNSEL 

 FOR THE DEBTOR AND DEBTOR-IN-POSSESSION 

Timothy E. Cliggott, debtor and debtor-in-possession (the "Debtor"), submits 

this application (the “Application”) pursuant to section 327(a) of title 11 of the United 

States Code (the “Bankruptcy Code”) and Federal Rule of Bankruptcy Procedure (the 

“Bankruptcy Rules”) 2014(a) for an order authorizing the Debtor to employ and retain 

the firm of Chung & Press, P.C. (“Chung & Press”) as his attorneys in this chapter 11 

case. In support of this Application, the Debtor respectfully represents to this Honorable 

Court as follows: 

1. On August 24, 2015, this case was commenced by the filing of a voluntary 

petition for relief under chapter 11 of the Bankruptcy Code in the United States 

Bankruptcy Court for the Eastern District of Virginia (the “Bankruptcy Court”). 

2. The Debtor has continued and intends to continue in the possession of his 

property as debtor-in-possession pursuant to sections 1107 and 1108 of the Bankruptcy 

Code. 

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3. The Debtor is an individual resident of Prince William County, Virginia. 

4. The Debtor desires to retain and employ Chung & Press pursuant to 

section 327(a) of the Bankruptcy Code and Bankruptcy Rule 2014(a) to perform all legal 

services in these proceedings as more fully set forth below. 

5. In order to enable the Debtor to perform his duties as debtor-in-possession 

and to effect the proper and expeditious administration of this case, Chung & Press will 

be required to render legal services to the Debtor in connection with this proceeding, 

including, but not limited to, the following: 

a) Assisting and advising the Debtor relative to the administration 

of this proceeding; 

b) Representing the Debtor before the Bankruptcy Court and 

advising the Debtor on all pending litigations, hearings, motions, and of the decisions of 

the Bankruptcy Court; 

c) Reviewing and analyzing all applications, orders, and motions 

filed with the Bankruptcy Court by third parties in this proceeding and advising the 

Debtor thereon; 

d) Attending all meetings conducted pursuant to section 341(a) of 

the Bankruptcy Code and representing the Debtor at all examinations; 

e) Communicating with creditors and all other parties in interest; 

f) Assisting the Debtor in preparing all necessary applications, 

motions, orders, supporting positions taken by the Debtor, and preparing witnesses and 

reviewing documents in this regard; 

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 g) Conferring with all other professionals, including any 

accountants and consultants retained by the Debtor and by any other party in interest; 

h) Assisting the Debtor in negotiations with creditors or third

parties concerning the terms of any proposed plan of reorganization; 

i) Preparing, drafting and prosecuting the plan of reorganization 

and disclosure statement; and 

j) Assisting the Debtor in performing such other services as may 

be in the interest of the Debtor and the Estate and performing all other legal services 

required by the Debtor. 

6. The Debtor believes that Chung & Press is well-qualified to be counsel to 

the Debtor, having ample experience in bankruptcy and insolvency matters. Chung & 

Press’s attorneys have had considerable experience in matters of this nature and are 

capable of rendering the services required. 

7. As set forth in the Affidavit of Daniel M. Press, (the “Affidavit”), annexed 

hereto and made a part hereof, Chung & Press represents no interest adverse to the estate 

regarding the matters upon which it is to be engaged, and is “disinterested” as such term 

is defined in section 101(14) of the Bankruptcy Code, as modified by section 1107(b). 

Chung & Press will not, while retained by the Debtor, represent any other party in 

interest in connection with this case. 

8. The members and associates of Chung & Press do not have any 

connection with the Debtor (other than as her attorneys), his affiliates, creditors, relatives, 

or any other party in interest, the United States trustee, or any person employed in the 

office of the United States trustee. 

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9. The employment of Chung & Press is in the best interests of the Debtor, 

his creditors and the estate. 

10. Chung & Press will charge fees and expenses incurred in representing the 

Debtor in these proceedings based on the normal rates charged by the attorneys and 

paralegals of Chung & Press for similar clients, currently $495/hr. for Daniel M. Press 

and Brett Weiss. Such rates are subject to periodic review and change, usually on an 

annual basis. Chung & Press will seek compensation for services rendered and expenses 

incurred upon appropriate application to the court pursuant to sections 330 and 331 of the 

Bankruptcy Code and Bankruptcy Rules. 

11. Chung & Press, P.C., has received a payment of $20,000 from the Debtor 

(of which $5000 was applied to prepetition services), plus the filing fee, but has not 

received an advance for postpetition services. 

 WHEREFORE, the Debtor requests that he be authorized to retain and employ 

the law firm of Chung & Press, P.C. as counsel to assist in the performance of her 

functions as DIP and otherwise with respect to this case pursuant to section 327(a) of the 

Bankruptcy Code and Bankruptcy Rule 2014(a); and for such other relief as the Court 

deems just and proper. 

Dated: August 24, 2015. 

 Respectfully submitted, 

 _/s/ Daniel M. Press_____________ 

 Daniel M. Press, VSB 37123 

 Chung & Press, P.C. 

 6718 Whittier Ave., Suite 200 

 McLean, VA 22101 

 (703) 734-3800 

 (703) 734-0590 fax 

 dpress@chung-press.com 

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CERIFICATE OF SERVICE 

 This is to certify that on this 24th day of August, 2015, I caused to be served on 

all creditors and parties in interest, as set forth on the attached matrix, by first class mail, 

postage prepaid (and by CM/ECF upon the United States Trustee and any parties 

receiving notice in such manner) the following documents: 

 Application to Employ of Chung & Press, P.C., as Counsel to the Debtor 

 _/s/ Daniel M. Press__________ 

 Daniel M. Press, VSB 37123 

 Chung & Press, P.C. 

 6718 Whittier Ave., Suite 200 

 McLean, VA 22101 

 (703) 734-3800 

 (703) 734-0590 fax 

 dpress@chung-press.com 

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 Label Matrix for local noticing United States Bankruptcy Court American Medical Collection Agency 

 0422-1 200 South Washington Street 4 Westchester Plz Ste 110 

 Case 15-12929 Alexandria, VA 22314-5405 Elmsford, NY 10523-1615 

 Eastern District of Virginia 

 Alexandria 

 Mon Aug 24 11:32:55 EDT 2015 

 Best Buy Bill LeMaster & Diane L. LeMaster (p)CAPITAL ONE 

 PO Box 1802 12950 LeMaster Drive PO BOX 30285 

 Dayton, OH 45401-1802 Nokesville, VA 20181-2457 SALT LAKE CITY UT 84130-0285 

 

 Carrington Mortgage Services, LLC Chase Bankcard Svcs Inc Chex System, Inc. 

 599 W. Putnam Avenue PO Box 30755 Attn: Consumer Relations 

 Greenwich, CT 06830-6005 Tampa, FL 33630-3755 7805 Hudson Road, Suite 100 

 Saint Paul, MN 55125-1595 

 ECMC Emerald AR Systems Equifax 

 1 Imation Place, Building 2 1850 N Central Ave, #1010 P.O. Box 740241 

 Saint Paul, MN 55128-3422 Phoenix, AZ 85004-3948 Atlanta, GA 30374-0241 

 Experian Fredericksburg Credit Bureau Georgetown Univ. Hosp. 

 PO Box 9701 10506 Wakeman Dr PO Box 32233 

 Allen, TX 75013-9701 Fredericksburg, VA 22407-8040 Washington, DC 20007-0533 

 IC Systems Inc. Internal Revenue Service JPMorgan Chase Bank 

 PO Box 64886 Centralized Insolvency Operation 501 Bleeker Street 

 Saint Paul, MN 55164-0886 Philadelphia, PA 19101-7346 Utica, NY 13501-2401 

 Law office of Mitchell Kitroser Mary Washington Hospital Medical Data Systems, Inc. 

 631 US Highway 1 Suite 410 1001 Sam Perry Boulevard 2001 9th Svenue, #312 

 North Palm Beach, FL 33408-4621 Fredericksburg, VA 22401-3354 Vero Beach, FL 32960-6413 

 Medical Imaging of Fredericksburg Natalie Corneuille Novant Health 

 1300 Hospital Drive, #100 650 Potomac Avenue 8700 Sudley Road 

 Fredericksburg, VA 22401-8451 Alexandria, VA 22301-3064 Manassas, VA 20110-4418 

 Prince William County, Virginia Receivables Management Systems Receivables Outsourcing, LLC 

 1 County Complex Court PO Box 8630 1920 Greenspring Drive, #200 

 Woodbridge, VA 22192-9202 Richmond, VA 23226-0630 Lutherville Timonium, MD 21093-4156 

 Robert Barlow TransUnion Consumer Solutions USAA Savings Bank 

 3516 Plank Rd Ste 104 PO Box 2000 PO Box 14050 

 Fredericksburg, VA 22407-6861 Crum Lynne, PA 19022 Las Vegas, NV 89114-4050 

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 Verizon Vintage Security Daniel M. Press 

 500 Technology Dr Ste 300 8220 Stayton Dr Ste A Chung & Press, P.C. 

 Saint Charles, MO 63304-2225 Jessup, MD 20794-9618 6718 Whittier Ave., Suite 200 

 McLean, VA 22101-4531 

 

 Judy A. Robbins Timothy E. Cliggott 

 Office of the U.S. Trustee - Region 4 12849 LeMaster Drive 

 115 South Union Street, Room 210 Nokesville, VA 20181-2443 

 Alexandria, VA 22314-3361 

 The preferred mailing address (p) above has been substituted for the following entity/entities as so specified 

 by said entity/entities in a Notice of Address filed pursuant to 11 U.S.C. 342(f) and Fed.R.Bank.P. 2002 (g)(4). 

 Capital One Bank End of Label Matrix 

 PO Box 85015 Mailable recipients 34 

 Richmond, VA 23285-5015 Bypassed recipients 0 

 Total 34

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