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UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION 

In re: Chapter 11 

Vandewater International, Inc., Case No. 21-14098-PDR

 Debtor. 

_____________________________________/ 

EMERGENCY APPLICATION TO EMPLOY 

BRADLEY S. SHRAIBERG, ESQ. AND SHRAIBERG, LANDAU & PAGE, P.A. 

AS GENERAL BANKRUPTCY COUNSEL EFFECTIVE AS OF THE PETITION DATE

** Emergency Hearing Requested Pursuant to Local Rule 9075-1 **

Basis for Emergency Relief

The Debtor is a Florida corporation that cannot represent 

itself in the above-captioned chapter 11 case without counsel. 

The Debtor risks irreparable harm if it does not immediately 

employ general bankruptcy counsel. As such, the Debtor 

requests that the Court schedule this application for hearing 

on an emergency basis on or before Friday, April 30, 2021 to 

be heard with the Debtor’s emergency motion for authority to 

pay prepetition wages. 

Vandewater International, Inc. (the “Debtor”), pursuant to 11 U.S.C. § 327(a), Fed. R. 

Bankr. P. 2014, and Local Rules 2014-1(A) and 9075-1, requests authorization to employ 

Bradley S. Shraiberg, Esq. and the law firm of Shraiberg, Landau & Page, P.A. (together, “SLP”) 

as general bankruptcy counsel effective as of the petition date. In support, the Debtor states as 

follows: 

1. On April 28, 2021 (the “Petition Date”), the Debtor filed a voluntary petition for

relief under Subchapter V of Chapter 11 of Title 11 of the U.S. Code (the “Bankruptcy Code”). 

The Debtor is operating its business and managing its affairs as a debtor-in-possession pursuant 

to section 1184 of the Bankruptcy Code. 

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2. The Debtor is a Florida corporation specializing in the fire protection fitting 

business. Specifically, the Debtor offers customers a wide range of steel pipe fittings and valves 

used in fire protection sprinkler systems. 

3. The Debtor believes that it is in the best interest of its estate to retain SLP as 

general bankruptcy counsel. An executed copy of SLP’s retainer letter is attached as Exhibit A. 

4. The attorneys of SLP have considerable experience in matters of this character 

and are qualified to practice in this Court and to advise the Debtor on its relations with, and 

responsibilities to, the creditors and other interested parties. The professional services SLP will 

render are summarized as follows: 

a. To advise the Debtor generally regarding matters of bankruptcy law in 

connection with this case; 

b. To advise the Debtor of the requirements of the Bankruptcy Code, the 

Federal Rules of Bankruptcy Procedure, applicable bankruptcy rules, 

including local rules, pertaining to the administration of the case and U.S. 

Trustee Guidelines related to the daily operation of its business and 

administration of the estate; 

c. To represent the Debtor in all proceedings before this Court; 

d. To prepare and review motions, pleadings, orders, applications, adversary 

proceedings, and other legal documents arising in the case; 

e. To negotiate with creditors, prepare and seek confirmation of a plan of 

reorganization and related documents, and assist the Debtor with 

implementation of any plan; and 

f. To perform all other legal services for the Debtor, which may be necessary 

herein. 

5. SLP has agreed to perform said services at the following hourly rates: $275.00 for 

legal assistants and $350.00 to $600.00 for attorneys. The hourly rate of attorney Bradley S. 

Shraiberg is $600.00. The hourly rate of Joshua Lanphear is $350.00. Under the applicable 

provisions of the Bankruptcy Code, and subject to Court approval, the Debtors propose to pay 

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SLP the aforementioned standard hourly rates and reimburse SLP for expenses according to 

SLP’s customary reimbursement policies. 

6. The hourly rates discussed above are SLP’s standard hourly rates charged to all 

clients. These rates are subject to adjustment, generally on an annual basis, to reflect, among 

other things, experience, and seniority. 

7. Prior to the Petition Date, on January 28, 2021, the Debtor’s President and 100% 

owner, Neil Ruebens, provided SLP with a $41,738.00 retainer as security for SLP representing 

the Debtor in this chapter 11 case, inclusive of the $1,738.00 filing fee. 

8. Prior to the filing of the Debtor’s voluntary petition, SLP incurred fees in the 

amount of $33,782.50 for 76.10 hours of legal services rendered to the Debtor prior to the 

Petition Date, including extensive communications with the Debtor, Mr. Reubens and Mr. 

Reubens’ personal bankruptcy counsel,1

 preparation of all paperwork required to file this chapter 

11 case including a complete set of bankruptcy schedules, and drafting the Debtor’s joint plan of 

reorganization. Accordingly, prior to the filing of the Debtor’s voluntary petition, SLP applied 

$33,782.50 of the $41,738.00 retainer. 

9. Section 327(a) of the Bankruptcy Code permits the employment of professionals 

“that do not hold or represent an interest adverse to the estate, and that are disinterested 

persons[.]” Section 101(14) of the Bankruptcy Code defines a “disinterested person” as, inter 

alia: (a) one who is not a creditor, equity security holder or insider; (b) one who is not, and was 

not within the two years preceding the petition date, a director, officer or employee of the debtor; 

and (c) one who does not have an interest materially adverse to the estate. 

1 On the Petition Date, the Debtor’s President and 100% owner, Neil Reubens, filed his own voluntary chapter 11 

petition, Case No. 21-14089-EPK, pending before this Court. 

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ATTORNEY CERTIFICATION 

I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court 

for the Southern District of Florida and I am in compliance with the additional qualifications to 

practice in this Court set forth in Local Rule 2090-1(A). 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via 

Notice of Electronic Filing by CM/ECF to all parties registered to receive such service on April 

28, 2021.

 Respectfully submitted, 

SHRAIBERG, LANDAU & PAGE, P.A.

Proposed Attorneys for the Debtor 

2385 NW Executive Center Drive, Suite 300 

Boca Raton, Florida 33431 

Telephone: 561-443-0800 

Facsimile: 561-998-0047 

Email: bss@slp.law 

 Email: jlanphear@slp.law 

By: /s/ Bradley S. Shraiberg 

 Bradley S. Shraiberg 

 Florida Bar No. 121622 

 Joshua Lanphear 

 Florida Bar No. 125421 

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Exhibit A 

Retainer Letter

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{2360/000/00507256} 

Exhibit B 

Affidavit

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

In re: Chapter 11 

Vandewater International, Inc., Case No. 21- 14098-PDR

Debtor.

_____________________________________/

AFFIDAVIT OF PROPOSED ATTORNEY FOR DEBTOR

Bradley S. Shraiberg, being duly sworn states:

1. My name is Bradley S. Shraiberg. I am an attorney admitted to practice in the

State of Florida and the United States District Court for the Southern District of Florida.

2. I am a Partner and Shareholder of Shraiberg, Landau & Page, P.A. (“SLP”), with

offices located at 2385 N.W. Executive Center Drive, Suite 300, Boca Raton, Florida 33431. 

3. I am familiar with the matters set forth herein and make this Affidavit in support

of the Emergency Application to Employ SLP as General Bankruptcy Counsel (the “Application

to Employ”) filed by Vandewater International, Inc. (the, “Debtor”).

4. Unless it otherwise states, this Affidavit is based upon facts of which I have

personal knowledge. In preparing this Affidavit, I have reviewed a list of the Debtor’s secured 

and unsecured creditors. I compared this information with the information contained in our law 

firm’s client and adverse party conflict check index system. The facts stated in this Affidavit as 

to the relationship between other lawyers in our law firm and the Debtors, the Debtors’ creditors 

and the United States Trustee, and other persons employed by the Office of the United States 

Trustee, and those persons and entities who are defined as disinterested persons in section 

101(14) of the Bankruptcy Code are based on the results of my review of our firm’s conflict 

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check index system. Specifically, I have conducted a search of our firm’s records and 

disseminated a request for information to all the attorneys in our firm regarding connections to 

the Debtor’s creditors. 

5. Our law firm’s client and adverse party conflict check index system is comprised 

of records regularly maintained in the course of business of the firm and it is a regular practice of 

the firm to make and maintain these records. It reflects entries that are noted in the system at the 

time the information becomes known by persons whose regular duties include recording and 

maintaining the information. I regularly use and rely upon the information contained in the 

system in the performance of my duties with the law firm and in my practice of law. 

6. Except as otherwise may be disclosed herein, a search of our firm’s conflict check 

index system reveals that our firm does not presently represent any parties with interests adverse 

to the Debtor’s estate. 

7. The professional fees and costs incurred by SLP, incurred post-petition in the 

course of its representation of the Debtor, shall be subject in all respects to the application and 

notice requirements of sections 330 and 331 of the Bankruptcy Code and Rules 2014 and 2016 of 

Federal Rules of Bankruptcy Procedure. 

8. The hourly rates for the attorneys at SLP range from $350.00 to $600.00. The 

hourly rate for Bradley S. Shraiberg, the primary attorney on this case, is $600.00. The hourly 

rate for Joshua Lanphear is $350.00. The hourly rate of the legal assistants at SLP are $275.00. 

9. Prior to the filing of the Debtor’s voluntary petition, on January 28, 2021, the 

Debtor’s President and 100% owner, Neil Ruebens, provided SLP with a $41,738.00 retainer as 

security for SLP representing the Debtor in this chapter 11 case, inclusive of the $1,738.00 

chapter 11 filing fee. 

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10. Also prior to the filing of the Debtor’s voluntary petition, SLP incurred fees in the 

amount of $33,782.50 for 76.10 hours of legal services rendered to the Debtor prior to the 

Petition Date, including extensive communications with the Debtor, Mr. Reubens and Mr. 

Reubens’ personal bankruptcy counsel,1

 preparation of all paperwork required to file this chapter 

11 case including a complete set of bankruptcy schedules, and drafting the Debtor’s joint plan of 

reorganization. Accordingly, prior to the filing of the Debtor’s voluntary petition, SLP applied 

$33,782.50 of the $41,738.00 retainer. 

11. There is no agreement of any nature, other than the partnership agreement of SLP, 

as to the sharing of any compensation to be paid to SLP. 

12. No promises have been received by SLP, nor any partner or associate thereof, as 

to the compensation in connection with these cases other than in accordance with the provisions 

of the Bankruptcy Code. 

13. No attorney at SLP holds a direct or indirect claim or equity interest in any of the 

Debtors or has a right to acquire such interest. 

14. Except as set forth herein, no attorney at SLP has had or presently has any 

connection with the Debtor’s creditors on any matter in which the firm is to be engaged, except 

that I, our law firm, its partners and associates: (a) may have appeared in the past, and may 

appear in the future, in other cases in which one or more of said parties may be involved; and (b) 

may represent or may have represented certain of the Debtor’s creditors in matters unrelated to 

this case. 

1 On the Petition Date, the Debtor’s President and 100% owner, Neil Reubens, filed his own voluntary chapter 11 

petition, Case No. 21-14089-EPK, pending before this Court. 

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