48309625.1

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

www.flsb.uscourts.gov

In Re: CASE NO.: 21-18481-MAM

Chapter 7

NITV LLC

Debtor

___________________________________/

TRUSTEE'S EX PARTE APPLICATION FOR EMPLOYMENT OF ATTORNEY

Michael R. Bakst, Trustee in Bankruptcy for NITV, LLC, respectfully requests an Order 

of the Court authorizing the employment of Michael R. Bakst, Esq., and the law firm of 

Greenspoon Marder LLP, to represent the Trustee in this case and states:

A. THE SPECIFIC FACTS NECESSITATING EMPLOYMENT:

It will be necessary for the Trustee to retain counsel to pursue the recovery of assets of 

the estate and to possibly take Rule 2004 Examinations, as well as potential contested matters 

and/or adversary proceedings to be pursued. 

B. THE NAME OF THE PERSON TO BE EMPLOYED:

Attached to this application is the proposed attorney's affidavit demonstrating Michael R. Bakst, 

Esq., and the law firm of Greenspoon Marder LLP, are disinterested parties as required by 11 

U.S.C. § 327(a) and a verified statement as required under FRBP 2014.

C. THE REASON FOR SELECTING THE FIRM OR INDIVIDUAL:

The Trustee believes that the attorney is qualified to practice in the Bankruptcy Court 

and is qualified to advise the Trustee on its relations with and responsibilities to the Debtor, 

creditors and other parties.

D. THE PROFESSIONAL SERVICES TO BE RENDERED

All anticipated services normally performed by counsel for a Chapter 7 Trustee, 

including the bringing of adversary proceedings and taking the Rule 2004 examination.

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E. THE PROPOSED ARRANGEMENTS FOR COMPENSATION:

There is no separate written retainer agreement between the Trustee and prospective 

counsel. Counsel’s compensation shall be determined pursuant to the provisions of 11 U.S.C. 

§330.

F. THE PROFESSIONAL'S CONNECTIONS WITH THE TRUSTEE, DEBTOR, 

CREDITORS AND OTHER PARTIES IN INTEREST:

The attorney has stated that he has run a conflict check through a computerized data base 

maintained by his law firm and has made every effort to input the names of any known 

potentially adverse party, including the debtor, as well as known insiders of the debtor, whom he 

believes could potentially be adverse to the Trustee. The data base includes names of current and 

previous clients of the firm, current and previous adverse parties of such clients, and names of 

related parties within such matters. Where any potential names come up which indicate a 

possible conflict, he has reviewed the specifics of the matter to verify that any such involvement 

of his law firm or himself does not present any facts that would render himself or his firm to not 

be disinterested or create a conflict of interest. In appropriate situations he has also 

communicated with other attorneys at his law firm that may be more familiar with such client or 

matter in order to confirm that representation by himself and his law firm complies with §327. 

The law firm of Greenspoon Marder LLP has several offices throughout the State of 

Florida and the United States with more than 200 lawyers practicing in various legal fields. 

Among the firm's clients includes several banking institutions, some of which could be creditors 

in this estate. However, neither the attorney nor his law firm would be representing any such 

banking institution within this estate, and if it becomes necessary for the Trustee to be adverse to 

any such entity, neither the attorney nor his law firm would handle such matter, but instead the 

Trustee would obtain special counsel for pur poses of handling such contested matter. 

The attorney does not hold or represent any interest adverse to the estate, and the Trustee 

believes that the employment of this attorney would be in the best interest of the estate.

WHEREFORE, the Trustee respectfully requests an Order authorizing the employment of 

Michael R. Bakst, Esq., and the law firm of Greenspoon Marder LLP, to represent the Trustee 

on a general retainer, pursuant to 11 U.S.C. §327 and 330.

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I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 

by via the attached service list, on this the 1 day of October, 2021.

MICHAEL R. BAKST, TRUSTEE

/s/ MICHAEL R. BAKST

__________________________________

Michael R. Bakst, Trustee

P.O. Box 407

West Palm Beach, FL 33402

Telephone: (561) 838-4539

Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email notice/service 

for this case. 

• Michael R Bakst efilemrb@gmlaw.com, 

ecf.alert+Bakst@titlexi.com;efileu1084@gmlaw.com;efileu1086@gmlaw.com;efileu386

@gmlaw.com;efileu1857@gmlaw.com

• Julianne R. Frank julianne@jrfesq.com, G59511@notify.cincompass.com

• Mark A Levy mark.levy@brinkleymorgan.com, 

sandra.gonzalez@brinkleymorgan.com;brinkleymorganecf@gmail.com

• Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

Manual Notice List

The following is the list of parties who are not on the list to receive email notice/service for this 

case (who therefore require manual noticing/service 

(No manual recipients)

29511-0595 emb

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