24672283.1 07/13/2018

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

(Alexandria Division) 

In re: * 

 

WW Contractors Inc., * Case No: 18-12095-BFK 

 Debtor. * Chapter 11 

 

* * * * * * * * * * * * 

DEBTOR’S APPLICATION FOR AUTHORITY TO EMPLOY 

SAUL EWING ARNSTEIN & LEHR LLP AS SPECIAL LITIGATION COUNSEL

 WW Contractors Inc. (the “Debtor”) hereby files this Application for Authority to Employ 

Saul Ewing Arnstein & Lehr LLP as Special Litigation Counsel (the “Application”), and in 

support thereof states as follows: 

JURISDICTION AND VENUE 

1. The Court has jurisdiction over this Application pursuant to 28 U.S.C. §§ 157 and 

1334. Venue lies properly in this Court pursuant to 28 U.S.C. §§ 1408 and 1409. This matter is 

a core proceeding pursuant to 28 U.S.C. § 157. 

2. The relief sought pursuant to this application is based upon sections 327(a), 328, 

330 and 1107 of 11 U.S.C. § 101, et seq. (the “Bankruptcy Code”). 

THE CHAPTER 11 CASE 

3. On June 12, 2018, the Debtor filed a voluntary petition for relief under Chapter 11 

of the United States Code in the United States Bankruptcy Court for the District of Maryland, 

Case No. 18-17927. On June 14, 2018, the Bankruptcy Case was transferred to the United States 

Bankruptcy Court for the Eastern District of Virginia and was assigned Case No. 18-12095 (the 

“Bankruptcy Case”). 

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THE RETENTION OF SAUL EWING ARNSTEIN 

& LEHR LLP AS SPECIAL LITIGATION COUNSEL TO THE DEBTOR 

4. Prior to the Petition Date, the Debtor commenced litigation against Sarai 

Investment Corporation and related parties (collectively, the “Defendants”) in the Circuit Court 

of Maryland for Baltimore City (the “Litigation”) in which the Debtor alleged numerous causes 

of action against the Defendants. The Litigation was subsequently removed to the United States 

District Court for the District of Maryland, case no. 1:18-cv-01341-CCB, where the Litigation is 

currently pending. Pursuant to this Application, the Debtor seeks authority to retain Saul Ewing 

Arnstein & Lehr LLP (“Saul Ewing”) to provide legal services in connection with the 

prosecution of the pending Litigation on the terms and conditions set forth herein.1 

5. The Debtor selected Saul Ewing because of the firm’s experience, knowledge and 

familiarity with the issues presented in the Litigation. Toyja E. Kelley, a principal of Saul 

Ewing, regularly represents businesses such as the Debtor in complex commercial disputes and is 

well qualified to represent the Debtor in the Litigation. Saul Ewing will perform all legal 

services required by the Debtor in the Litigation and will be compensated on an hourly basis at 

the firm’s customary rates. Subject to the Court’s approval, Saul Ewing will charge the Debtor 

for its professional services based on the following rates: 

Partners - $360 - $975 

Counsel - $350-675 

Associates - $250 - $440 

Paralegals - $90 - $350 

Such compensation will be paid from the estate only after approval of this Court on proper 

application therefore pursuant to 11 U.S.C. §§ 330 and 331. 

 

1

 Prior to the Petition Date, the Debtor had retained Christopher S. Young, Esquire and Heather K. Young of the 

Business & Technology Law Group (“BTLG”) to represent the Debtor in the Litigation. The Debtor has decided to 

terminate BTLG’s representation and wishes to retain Saul Ewing going forward. 

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6. To the best of the Debtor’s knowledge, Saul Ewing has no connection with any 

creditor, the Debtor (other than this representation) or any other party in interest or their 

respective attorneys and accountants, the United States Trustee, or any person employed in the 

office of the United States Trustee, except as set forth in the Verified Statement of Counsel to be 

Employed by Debtor, which is attached hereto and incorporated herein. 

7. To the best of the Debtor’s knowledge, Saul Ewing represents no interest adverse 

to the Debtor or the estate. 

8. The Litigation represents a valuable asset of the Debtor’s estate, and the Debtor 

believes that continued prosecution of the Litigation will be in the best interests of the Debtor, its 

creditors and the estate. 

9. The Debtor submits that, pursuant to Local Bankruptcy Rule 9013-1, it will rely 

solely on the facts presented herein, and no memorandum of law will accompany this 

Application. 

WHEREFORE, the Debtor respectfully requests that this Court enter an order pursuant to 

11 U.S.C. § 327 approving the Debtor’s employment of Saul Ewing Arnstein & Lehr LLP to 

represent it in the Litigation. 

Dated: July 13, 2018 WW Contractors Inc. 

 BY: /s/ Warrren Wiggins 

 Warren Wiggins, President 

CERTIFICATE OF SERVICE 

 I hereby certify that on this 13th day of July, 2018, a copy of the foregoing pleading was 

served electronically to those parties on the Court’s CM/ECF notice list. 

 /s/ Aryeh E. Stein 

 Aryeh E. Stein 

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