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APPLICATION BY DEBTORS FOR EMPLOYMENT OF LOCKETT + HORWITZ 

AS SPECIAL COUNSEL EFFECTIVE AS OF THE PETITION DATE 

 Beta Music Group, Inc. and Get Credit Healthy, Inc. (collectively, the “Debtors”), respectfully 

apply (the “Application”) for the entry an order of the Court authorizing the employment of Jessica 

M. Lockett, Esq. and the firm of Lockett +Horwitz (collectively, the “Firm”) to represent the Debtors 

in these chapter 11 cases as special counsel effective as of the Petition Date pursuant to 11 U.S.C. § 

327(e). In support of the Application, the Debtors state as follows: 

1. On March 5, 2021 (the “Petition Date”), the Debtors filed voluntary petitions under 

Chapter 11 of the United States Bankruptcy Code. 

2. The Debtors remain in possession and are operating their business pursuant to 11 

U.S.C. §§ 1106, 1182, and 1184. 

3. On March 6, 2021, the Court entered the Order Jointly Administering Chapter 11 

Cases [ECF No. 4]. 

4. Prior to the Petition Date, the Debtors employed the Firm as corporate and securities 

counsel in connection with various corporate and compliance matters relating to the Securities and 

Exchange Commission (the “SEC”) and OTC Markets. 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT LAUDERDALE DIVISION 

www.flsb.uscourts.gov 

In re: Chapter 11 

Beta Music Group, Inc. and      Case No. 21-12199-SMG 

Get Credit Healthy, Inc.,       Case No. 21-12201-SMG 

 (Jointly Administered) 

Debtors. 

_____________________________/ 

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5. As of the Petition Date, the Firm was owed $3,172.50 in fees and costs in connection 

with the pre-petition representation of the Debtors. 

6. The Debtors believe the Firm should continue to represent the Debtors given the 

Firm’s prior representation and familiarity with the Debtors, as well as the Firm’s skills, and 

experience. 

7. The Debtors will require the Firm to (i) advise the Debtors regarding various corporate 

issues; (ii) advise the Debtors with compliance and other matters relating to the SEC and OTC 

Markets; and (iii) and advise the Debtors regarding a possible sale regarding the assets of Beta Music 

Group, Inc. 

8. Given the pre-bankruptcy relationship between the Debtors and matters referenced 

above, the Debtors desire to employ the Firm as its special corporate and securities counsel in this 

case under section 327(e) of the Bankruptcy Code. 

9. The Firm is qualified to advise the Debtors on corporate and securities matters and 

has indicated a willingness to act on behalf of the Debtors, on the terms described herein, and to 

subject itself to the jurisdiction of the Court. 

10. The Debtors propose to compensate the Firm on an hourly basis on the terms set forth 

in the engagement agreement1 attached hereto as Exhibit “A.” The Debtors anticipate a sale of 

BEMG’s assets that will generate funds sufficient to pay the Firm’s fees and expenses. 

11. The Firm is aware that it will be required to submit fee applications to the Court in 

compliance with the Guidelines for Fee Applications for Professionals in the Southern District of 

Florida in Bankruptcy Cases and, and obtain approval of such applications prior to receiving payment 

for fees and expenses, and that the terms of the attached engagement letter regarding the timing of 

1

 The Firm changed its name from Horwitz + Armstrong to Lockett + Horwitz in January 2021. 

Case 21-12199-SMG Doc 87 Filed 04/22/21 Page 2 of 14
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payment and allowable reimbursements are subject to the requirement to file fee applications and 

approval of such applications. Further, the Firm understands that all payments are subject to the 

review and approval by this Court. 

12. Attached hereto as Exhibit “B” is the Declaration of Jessica Lockett (the 

“Declaration”) providing the disclosures required by Fed. R. Bankr. P. 2014. 

13. The Firm holds no adverse interest to the Debtors or to the estates with respect to the 

matters on which the Firm is being employed. 

14. Subject to the foregoing and to the best of the Debtors’ knowledge, neither the Firm 

or its attorneys have any connection with the creditors or other parties in interest or their respective 

attorneys. 

WHEREFORE, the Debtors respectfully request entry of an order in each of the abovecaptioned cases (a) approving the Application; (b) authorizing the retention of Ms. Lockett and the 

firm of Lockett + Horwitz as special corporate and securities counsel pursuant to 11 U.S.C. §§ 327(e) 

and 330 effective as of the Petition Date; and (c) granting such other and further relief as appropriate 

under the circumstances. 

CERTIFICATE OF SERVICE

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

Notice of Electronic Filing to those parties registered to receive electronic noticing in this case 

on April 22, 2021. 

 MARKOWITZ, RINGEL, TRUSTY & HARTOG, P.A.

 Counsel for the Debtors

 101 NE Third Avenue, Suite 1210 

 Fort Lauderdale, Florida 33301 

 T: 954.767.0030 // F: 954.767.0035 

 

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 9130 S. Dadeland Blvd., Suite 1800 

 Miami, FL 33156 

 T: 305.670.5000 //F: 305.670.5011 

 

 By: /s/ Grace E. Robson 

 GRACE E. ROBSON 

 Florida Bar No. 0178063 

 ALAN R. ROSENBERG 

 Florida Bar No. 92004 

 

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