MOTION TO EMPLOY WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

WICHITA FALLS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, 

LLC,

§

§

CASE NO. 24-70089-swe11V

§

DEBTOR. § HEARING SET:

MAY 28, 2024 AT 1:30 p.m.

MOTION TO EMPLOY WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

AS ATTORNEYS FOR THE DEBTOR

NO HEARING WILL BE CONDUCTED HEREON UNLESS A WRITTEN RESPONSE 

IS FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT AT

EARLE CABELL FEDERAL BUILDING, 1100 COMMERCE ST., RM. 1254, DALLAS, 

TX 75242-1496. BEFORE CLOSE OF BUSINESS ON MAY 16, 2024, WHICH IS AT 

LEAST 21 DAYS FROM THE DATE OF SERVICE HEREOF.

ANY RESPONSE SHALL BE IN WRITING AND FILED WITH THE CLERK, AND A 

COPY SHALL BE SERVED UPON COUNSEL FOR THE MOVING PARTY PRIOR TO 

THE DATE AND TIME SET FORTH HEREIN. IF A RESPONSE IS FILED A 

HEARING MAY BE HELD WITH NOTICE ONLY TO THE OBJECTING PARTY.

IF NO HEARING ON SUCH NOTICE OR MOTION IS TIMELY REQUESTED, THE 

RELIEF REQUESTED SHALL BE DEEMED TO BE UNOPPOSED, AND THE COURT 

MAY ENTER AN ORDER GRANTING THE RELIEF SOUGHT OR THE NOTICED 

ACTION MAY BE TAKEN.

TO THE HONORABLE SCOTT W. EVERETT, U.S. BANKRUPTCY JUDGE:

HIGH PLAINS RADIO NETWORK, LLC, debtor and debtor in possession (“HPRN” or 

the “Debtor”), files this Motion to Employ Weycer, Kaplan, Pulaski & Zuber, P.C. as Attorneys 

for the Debtor (the “Motion to Employ WKPZ”) seeking entry of an order authorizing the 

employment of Weycer, Kaplan, Pulaski, & Zuber, P.C. (“WKPZ”) as the attorneys for the 

Debtor in this Chapter 11 reorganization case nunc pro tunc to March 26, 2024 (the “Petition 

Date”). In support of this Motion to Employ WKPZ, the Debtor submits the Declaration of Jeff 

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Carruth, an attorney at WKPZ (the “Carruth Declaration”), attached hereto as Exhibit HXXX

and incorporated herein by reference.

I. Jurisdiction and Venue

1. This Court has jurisdiction to consider this Motion to Employ WKPZ under the 

provisions of 28 U.S.C. §§ 1334 and 157. This matter involves the administration of a 

bankruptcy estate and, thus, is a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A). Venue of 

this proceeding is proper in this district pursuant to 28 U.S.C. §§ 1408 and 1409.

II. Introduction

2. The Debtor filed a voluntary petition under Chapter 11 of the United States 

Bankruptcy Code, 11 U.S.C. §101 et seq. (the “Code” or the “Bankruptcy Code”) on March 26, 

2024 (the “Petition Date”).

III. Relief Requested

3. Subject to approval of this Court, the Debtor has employed WKPZ as of March 

26, 2024 pre-petition and seeks approval of employment effective as the Petition Date for the 

prosecution of this case, as Debtor’s counsel in connection with the prosecution of this case 

under Chapter 11.

4. Pursuant to Code § 327(a), the Debtor requests that the Court approve the 

employment of WKPZ as Debtor’s counsel to perform the legal services for the Debtor in this 

Chapter 11 case.

5. A proposed form of order is submitted with this Motion to Employ WKPZ and is 

incorporated by reference herein.

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IV. Qualifications of WKPZ

6. The Debtor has selected WKPZ because of WKPZ's extensive experience and 

knowledge in the field of debtor and creditor rights and business reorganizations under 

Chapter 11 of the Code, and WKPZ’s knowledge of the local practice and procedures of this 

Court. In preparing for entry into this Chapter 11 case, WKPZ has become generally familiar 

with the business of the Debtor. Accordingly, the Debtor believes that WKPZ has the necessary 

background to deal effectively with the legal issues that may arise during this Chapter 11 case, 

and that WKPZ is qualified and able to represent the Debtor in the Chapter 11 case.

V. Services to be Provided by WKPZ

7. The services of WKPZ are necessary to enable the Debtor to execute faithfully the 

duties of the Debtor as Debtor in Possession and to develop, propose, and confirm a plan of 

reorganization and/or achieve a successful exit from Chapter 11.

8. Subject to further order of this Court, WKPZ will render, inter alia, and without 

limitation, the following professional services:

(a) advise the Debtor of the rights, powers, duties, and obligations of the 

Debtor as debtor and debtor-in-possession in this Chapter 11 case;

(b) take all necessary actions to protect and preserve the estates of the Debtor, 

including the prosecution of actions on the Debtor’s behalf, the defense of actions 

commenced against the Debtor, the negotiation of disputes in which the Debtor are

involved, and the preparation of objections with respect to claims that are filed against 

the estate;

(c) to the extent necessary, assist the Debtor in the investigation of the acts, 

conduct, assets, and liabilities of the Debtor, and any other matters relevant to the case;

(d) investigate and potentially prosecute preference, fraudulent transfer, and 

other causes of action arising under the Debtor’s avoidance powers and/or which are 

property of the estate;

(e) prepare on behalf of the Debtor, as debtor-in-possession, all necessary 

motions, applications, answers, orders, reports, and papers in connection with the 

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representation of the Debtor and the administration of the estates and this Chapter 11

case;

(f) negotiate, draft, and present on behalf of the Debtor a plan for the 

reorganization of the Debtor’s financial affairs, and the related disclosure statement, and 

any revisions, amendments, and so forth, relating to the foregoing documents, and all 

related materials; and

(g) perform all other necessary legal services in connection with this Chapter 

11 case and any other bankruptcy-related representation that the Debtor require.

9. WKPZ will not advise the Debtor with respect to nor render opinions regarding 

tax matters or securities matters.

10. WKPZ will not advise the Debtor with respect to any matters involving the 

Federal Communications Commission (“FCC”).

VI. Disclosure Concerning Conflicts of Interest or Prior Relationships

11. To the best of the Debtor’s knowledge, information, and belief, other than as set 

forth herein and/or in the Carruth Declaration and in connection with this case, WKPZ has no 

connection with the Debtor’s creditors, the United States Trustee, or any other party with an 

actual or potential interest in this case or any of their respective attorneys or accountants.

12. To the best of the Debtor’s knowledge, information, and belief, WKPZ represents 

no other interest adverse to the Debtor’s or the Debtor’s estate. The Debtor believes and 

represents that, to the best of the Debtor’s knowledge, WKPZ is a “disinterested person” as that 

term is defined in Code §101(14).

13. The Debtor submits that the Debtor’s employment of WKPZ would be in the best 

interests of the Debtor, the estate, and all creditors. The Debtor’s knowledge, information, and 

belief regarding the matters set forth herein are based and made in reliance upon the Carruth 

Declaration.

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VII. Payment of Fees and Expenses

14. Subject to the Court's approval, WKPZ will charge for legal services on an hourly 

basis in accordance with WKPZ’s ordinary and customary hourly rates as in effect on the date 

services are rendered. The current minimum hourly rates for the primary attorney who will be 

performing substantially all of the services to the Debtor are listed below. 

Jeff Carruth, Shareholder: $585.00

Other Shareholders $525 or less

Associates $300 or less

Paralegals: $150

These rates may change from time to time in accordance with WKPZ's established billing 

practices and procedures. Also, notably, WKPZ will not charge for non-working travel time 

with respect to the representation of the Debtor. Rates may adjust automatically every January in 

accordance with normal firm and industry practice.

15. Additional attorneys and/or paralegals of WKPZ may perform services from time 

to time under the employment sought to be approved this Motion to Employ WKPZ.

16. In addition, WKPZ may obtain the assistance of local counsel or appearance 

counsel to make limited in-person appearances for announcements and other routine matters 

when necessary (and in the unlikely event that WKPZ is unable to attend an in-person hearing), 

with any such counsel’s fees being passed through to the Debtor with the invoices of WKPZ.

17. WKPZ will maintain detailed, contemporaneous records of time and any actual 

and necessary expenses incurred in connection with the rendering of the legal services described 

above by category and nature of the services rendered.

18. In addition to compensation for professional services rendered, WKPZ shall seek 

reimbursement for reasonable and necessary expenses incurred in connection with this 

proceeding, including, but not limited to, filing fees, deposition and other transcript costs, 

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Lexis/Westlaw, PACER and other electronic research, data management and/or download 

products, mileage and other travel expenses, long distance and fax charges, messenger services, 

postage and mail-out services, and reproduction costs.1

19. On March 26, 2024, the Debtor executed and delivered the current, bankruptcy

engagement letter to WKPZ.

20. Debtor has made the following payments to WKPZ, and WKPZ has paid the

following pre-petition invoices and expenses, as shown in the table below. A total initial retainer

in the amount of $52,000 was agreed, and a balance of $21,000 remains.

21. The engagement letter between WKPZ and the Debtor provides that (1) the 

Debtor will provide a post-petition retainer to WKPZ of $21,000, and that WKPZ may seek to 

withdraw if the post-petition retainer is not received, and (2) WKPZ is not obligated to work 

beyond the ability of HPRN to pay for the services of WKPZ, and that WKPZ may seek to 

withdraw from the bankruptcy case and/or any other litigation if HPRN is or will be unable to 

pay for the fees and expenses incurred by WKPZ and/or that may be approved by the bankruptcy 

court.

1 The Debtor may undertake direct payment of reproduction and mailing costs associated with these cases in the 

ordinary course; however, it also possible that WKPZ shall incur such expenses.

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VIII. Fee Applications and Interim Payments

22. WKPZ intends to periodically apply to this Court for payment of interim 

compensation and reimbursement of expenses in accordance with applicable provisions of the 

Bankruptcy Code, the Bankruptcy Rules, the Guidelines promulgated by the Office of the United 

States Trustee and the local rules and orders of this Court, and pursuant to any additional 

procedures that may be established by this Court in this case.

IX. Direct Payments to Mail-out Vendor

23. WKPZ also requests that WKPZ be permitted to make direct payments to its mailout vendor, from the retainer funds on hand, for the costs of copying, postage, and processing 

related to the voluminous service of notices, orders, pleadings, and other items in this case, as 

such expenses are incurred and without further notice or order.

24. Such expenses are required to be incurred under the bankruptcy rules. In larger

cases, the Debtor often pays these expenses directly through the claims agent and noticing

vendor.

25. The burden and necessity of payment substantively are the same in smaller cases, 

expect that the relative burden to counsel to carry the noticing expenses is much greater,

relatively speaking.

26. Accordingly, WKPZ requests the authority to pay these expenses immediately

and directly as incurred, without further notice or order of the Court.

27. WKPZ will report the payment of these expenses with each interim and final fee 

application.

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X. Conclusion

28. Debtor believes that the employment of WKPZ will be in the best interest of the 

estate and, accordingly, Debtor requests that WKPZ be employed as counsel for Debtor.

WHEREFORE, based upon the foregoing, the Debtor respectfully requests that this Court 

enter an order (a) authorizing the Debtor to retain and employ WKPZ as Debtor’s counsel in this 

Chapter 11 case effective nunc pro tunc to March 26, 2024 (the petition date) pursuant to Code 

§ 327(a), and (b) granting such other and further relief as the Court may deem just and proper.

Dated: April 25, 2024

APPROVED:

HIGH PLAINS RADIO NETWORK, LLC

By: /s/ Monte L. Spearman

Monte L. Spearman, Manager / President

Proposed Counsel to the Debtor and

Debtor in Possession:

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

Jeff Carruth (SBT #24001846)

2608 Hibernia Street, Suite 105

Dallas, TX 75204

(713) 341-1158

(713) 961-5341 (fax)

E-mail: jcarruth@wkpz.com

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing was served 

on April 25, 2024 (1) by electronic notice to all ECF users who have appeared in this case to date 

(2) by regular mail to all parties appearing in the attached address list (i.e. mailing matrix) 

obtained from the Court’s PACER facility, as set forth in the attached lists.

ANY PARTY REQUESTED A FULL-SIZED COPY OF THIS PLEADING OR COPIES 

OF ANY EXHIBITS SHOULD CONTACT THE UNDERSIGNED.

/s/ Jeff Carruth

JEFF CARRUTH

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ECF Service List

24-70089-swe11 Notice will be electronically mailed to: 

Jeffery D. Carruth on behalf of Debtor High Plains Radio Network, LLC

jcarruth@wkpz.com, 

jcarruth@aol.com;atty_carruth@trustesolutions.com;carruthjr87698@notify.bestcase.com;ATTY_CARRUTH@blu

estylus.com

Paul H. Cross on behalf of Creditor Hanmi Bank

phclease@msn.com

Shanna M. Kaminski on behalf of Interested Party Union Funding Source, Inc.

skaminski@kaminskilawpllc.com

Sherrel K. Knighton on behalf of Creditor Malakoff ISD

Sherrel.Knighton@lgbs.com, Dora.CasianoPerez@lgbs.com;Sean.French@lgbs.com;Eva.Parker@lgbs.com;Alexis.Hall@lgbs.com;Dallas.Bankruptcy@lgbs.co

m

Julie Anne Parsons on behalf of Creditor Eastland County Appraisal District

jparsons@mvbalaw.com, kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Julie Anne Parsons on behalf of Creditor The County of Henderson, Texas

jparsons@mvbalaw.com, kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Julie Anne Parsons on behalf of Creditor The County of Stephens, Texas

jparsons@mvbalaw.com, kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Scott M. Seidel -SBRA V

scott@scottseidel.com, csms11@trustesolutions.net;susan.seidel@earthlink.net

Dawn Whalen Theiss on behalf of Creditor Small Business Administration

dawn.theiss@usdoj.gov, brooke.lewis@usdoj.gov;CaseView.ECF@usdoj.gov

United States Trustee

ustpregion06.da.ecf@usdoj.gov

David Weitman on behalf of Creditor Vertical Bridge REIT, LLC

david.weitman@klgates.com

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REGULAR MAIL LIST

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DECLARATION OF JEFF CARRUTH — Page 1

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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, 

LLC,

§

§

CASE NO. 24-70089-swe11V

§

DEBTOR. §

DECLARATION OF JEFF CARRUTH IN SUPPORT OF MOTION TO 

EMPLOY WEYCER, KAPLAN, PULASKI & ZUBER, P.C. AS 

ATTORNEYS FOR THE DEBTOR

Pursuant to 28 U.S.C. § 1746, Jeff Carruth, hereby declares the following under penalty 

of perjury of the laws of the United States that the following statements are true and correct.

1. My name is Jeff Carruth. I am more than twenty-one (21) years of age and am 

competent and authorized to make this declaration. I have personal knowledge of the facts set 

forth herein and they are true and correct.

2. I have been licensed to practice law in the State of Texas since 1997. I am 

admitted to practice law and am in good standing in multiple jurisdictions including all of the 

federal district courts in Texas, Oklahoma, and Arkansas as well as at least the following districts 

and courts: the District of Colorado, the Central District of Illinois, and the Fifth Circuit Court of 

Appeals. I also hold ECF filing privileges in the bankruptcy courts of at least one dozen other 

districts.

3. I am an attorney with the law firm of Weycer, Kaplan, Pulaski & Zuber, P.C. 

(“WKPZ”). I and WKPZ have been requested by the above-captioned debtor and debtor in 

possession (the “Debtor”) to represent it in this Chapter 11 case.

4. This declaration was prepared and is being submitted as an exhibit to the Motion 

to Employ Weycer, Kaplan, Pulaski & Zuber, P.C. as Attorneys for the Debtor (the “Motion to 

Employ WKPZ”). I have read the Motion to Employ WKPZ and WKPZ agrees to the terms of 

employment set forth therein.

5. The above-captioned Debtor desires to employ WKPZ to provide general legal 

services as needed throughout the course of this case. The legal services that WKPZ will render 

to the Debtor may be summarized as follows: 

(a) advise the Debtor of the rights, powers, duties, and obligations of the 

Debtor as debtor and debtor-in-possession in this Chapter 11 case;

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(b) take all necessary actions to protect and preserve the estates of the Debtor, 

including the prosecution of actions on the Debtor’s behalf, the defense of actions 

commenced against the Debtor, the negotiation of disputes in which the Debtor are 

involved, and the preparation of objections with respect to claims that are filed against 

the estate;

(c) to the extent necessary, assist the Debtor in the investigation of the acts, 

conduct, assets, and liabilities of the Debtor, and any other matters relevant to the case;

(d) investigate and potentially prosecute preference, fraudulent transfer, and 

other causes of action arising under the Debtor’s avoidance powers and/or which are 

property of the estate;

(e) prepare on behalf of the Debtor, as debtor-in-possession, all necessary 

motions, applications, answers, orders, reports, and papers in connection with the 

representation of the Debtor and the administration of the estates and this Chapter 11

case;

(f) negotiate, draft, and present on behalf of the Debtor a plan for the 

reorganization of the Debtor’s financial affairs, and the related disclosure statement, and 

any revisions, amendments, and so forth, relating to the foregoing documents, and all 

related materials; and

(g) perform all other necessary legal services in connection with this Chapter 

11 case and any other bankruptcy-related representation that the Debtor require.

6. WKPZ will not advise the Debtor with respect to nor render opinions regarding 

tax matters or securities matters.

7. WKPZ will not advise the Debtor with respect to any matters involving the 

Federal Communications Commission ("FCC").

8. Subject to the Court's approval, WKPZ will charge the Debtor for legal services 

on an hourly basis in accordance with the ordinary and customary hourly rates of WKPZ that are 

in effect on the date services are rendered.

9. The current minimum hourly billing rates for the attorney who will be providing 

substantially all of the services to the Debtor in this case are as follows.

Jeff Carruth, Shareholder: $585.00

Other Shareholders $525.00 or less

Associates: $300.00 or less

Paralegals: $150.00

10. In addition to compensation for professional services rendered, WKPZ shall seek 

reimbursement for reasonable and necessary expenses incurred in connection with this 

proceeding, including, but not limited to, filing fees, deposition and other transcript costs, 

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Lexis/Westlaw, PACER and other electronic research, data management and/or download 

products, mileage and other travel expenses, long distance and fax charges, messenger services, 

postage, and reproduction costs.

11. Also, notably, WKPZ will not charge for non-working travel time with respect to

the representation of the Debtor.

12. In addition to compensation for professional services rendered, WKPZ shall seek 

reimbursement for reasonable and necessary expenses incurred in connection with this 

proceeding, including, but not limited to, filing fees, deposition and other transcript costs, 

Lexis/Westlaw, PACER and other electronic research, data management and/or download 

products, mileage and other travel expenses, long distance and fax charges, messenger services, 

postage and mail-out services, and reproduction costs.1

13. On March 26, 2024, the Debtor executed and delivered the current, bankruptcy

engagement letter to WKPZ.

14. Debtor has made the following payments to WKPZ, and WKPZ has paid the

following pre-petition invoices and expenses, as shown in the table below. A total initial retainer

in the amount of $52,000 was agreed, and a balance of $21,000 remains.

15. The engagement letter between WKPZ and the Debtor provides that (1) the 

Debtor will provide a post-petition retainer to WKPZ of $21,000, and that WKPZ may seek to 

withdraw if the post-petition retainer is not received, and (2) WKPZ is not obligated to work 

beyond the ability of HPRN to pay for the services of WKPZ, and that WKPZ may seek to 

withdraw from the bankruptcy case and/or any other litigation if HPRN is or will be unable to 

pay for the fees and expenses incurred by WKPZ and/or that may be approved by the bankruptcy 

court.

1 The Debtor may undertake direct payment of reproduction and mailing costs associated with these cases in the 

ordinary course; however, it also possible that WKPZ shall incur such expenses.

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16. WKPZ may request additional, post-petition retainer s from the Debtor and/or an 

insider of the Debtor depending on the circumstances which may arise in this case and only in 

the event that such retainers would not cause WKPZ to lose its disinterested status in this matter.

17. WKPZ understands that compensation for services rendered to the Debtor and 

reimbursement of expenses will be subject to interim and final allowance by this Court pursuant 

to a fee Motion to Employ WKPZ to be filed by WKPZ.

18. I have reviewed the records of WKPZ to determine the existence of any interest 

held or represented by WKPZ that is adverse to the Debtor’s estate or the Debtor’s creditors. 

Based on that review, I am informed and believe that:

(a) WKPZ is not and was not a creditor of the Debtor in this case and is not 

and was not an equity security holder or an insider of the Debtor;

(b) within two years before the Petition Date, no one at WKPZ was a director, 

officer, or employee of the Debtor;

(c) WKPZ does not have an interest materially adverse to the interest of the 

estate or any class of creditors or equity security holders, by reason of any direct or 

indirect relationship to, connection with, or interest in, the Debtor, or for any other reason.

19. Based on that review, WKPZ does not have any relationship to or connection with 

or interest in (i) the United States Trustee or any person employed by the office of the United 

States Trustee or (ii) any attorneys, accountants, financial consultants, and investment bankers 

who represent or may represent claimants or other parties in interest in this case. 

20. Except as provided below, WKPZ does not represent any creditors or other 

parties-in-interest in this case.

21. To the best of the Debtor's knowledge, information, and belief, other than as set 

forth in the Carruth Declaration and in connection with this case, WKPZ has no connection with 

the Debtor’s creditors, the United States Trustee, or any other party with an actual or potential 

interest in this case or any of their respective attorneys or accountants.

22. Consistent with its professional responsibility, WKPZ has evaluated potential 

conflicts of interest and believes that none exist, except as disclosed herein. If, and when, 

additional information with respect to any other relationships which may exist between WKPZ,

its shareholders, principals, and staff members and the Debtor or any other party in interest in 

this case arises, supplemental declarations describing such information shall be filed with the 

Court.

23. Accordingly, except as set forth herein, and based upon the information available 

to me, neither I, WKPZ, nor any shareholder or associate thereof, insofar as I have been able to 

ascertain, holds or represents any interest adverse to the Debtor or the Debtor’s estate in the 

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motion employ WKPZ 4890-0349-7650 v.5.docx[4]/4857-5070-2777, v. 1

matters upon which WKPZ is to be employed. Based upon the information available to me, I 

believe that WKPZ is a “disinterested person” as that term is defined in Code §101(14).

24. No promises have been received by WKPZ, or by any employee thereof, to 

receive compensation in this case other than in accordance with the provisions of the Bankruptcy 

Code, the Bankruptcy Rules of Procedure, and the Local Bankruptcy Rules. No one employed at 

WKPZ has agreed to share compensation received in this case with any other person or entity not 

a member or regular associate of WKPZ.

25. Carrying noticing and mailing expenses in this case until approval of an interim

for final fee application would impose an undue and unnecessary hardship on WKPZ.

Accordingly, WKPZ requests the authority to pay these expenses immediately and directly as 

incurred, without further notice or order of the Court.

FUTHER DECLARANT SAYETH NOT

DATED: April 25, 2024 Respectfully Submitted:

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

By: /s/ Jeff Carruth

JEFF CARRUTH

State Bar No. 24001846

2406 Hibernia, Suite 105

Dallas, Texas 75204

Phone: (713) 341-1058

Facsimile: (866) 666-5322

jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR

HIGH PLAINS RADIO NETWORK, LLC

DEBTOR 

Case 24-70089-swe11 Doc 57 Filed 04/25/24 Entered 04/25/24 23:32:32 Desc Main

Document Page 16 of 18
ORDER GRANTING MOTION TO EMPLOY WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

AS ATTORNEYS FOR THE DEBTOR (RE: DOCKET NO. 57) — Page 1

motion employ WKPZ 4890-0349-7650 v.5.docx[5]/4857-5070-2777, v. 1

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, 

LLC,

§

§

CASE NO. 24-70089-swe11V

§

DEBTOR. §

ORDER GRANTING MOTION TO EMPLOY WEYCER, KAPLAN, 

PULASKI & ZUBER, P.C. AS ATTORNEYS FOR THE DEBTOR (RE: 

DOCKET NO. 57)

On this day came on for consideration the Motion to Employ Weycer, Kaplan, Pulaski & 

Zuber, P.C. (Docket No. 57) (the “Motion to Employ WKPZ”) of HIGH PLAINS RADIO 

NETWORK, LLC, debtor and debtor in possession (the “Debtor”), filed on April 25, 2024 in the 

above-styled and numbered case(s), seeking approval of the employment of the firm of Weycer,

Kaplan, Pulaski, & Zuber, P.C. (“WKPZ”) as counsel for the Debtor as more particularly set 

forth in the Motion to Employ WKPZ and Declaration on file in this case.

The Court finds that the Motion to Employ WKPZ contained the appropriate notice and 

was served upon the parties contained within the Master Service List of the Debtor. No 

objections to the Motion to Employ WKPZ were filed. Upon review of the Motion to Employ 

WKPZ, it appears to the Court that the proposed professional is “disinterested” as that term is 

defined in Code §101(14) and that the proposed professional represents or holds no interest 

adverse to the Debtor.

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ORDER GRANTING MOTION TO EMPLOY WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

AS ATTORNEYS FOR THE DEBTOR (RE: DOCKET NO. 57) — Page 2

motion employ WKPZ 4890-0349-7650 v.5.docx[5]/4857-5070-2777, v. 1

IT IS THEREFORE ORDERED THAT

1. The Motion to Employ WKPZ is GRANTED and that the Debtor is authorized to 

employ WKPZ as attorneys to the Debtor and the related Chapter 11 estate(s)

pursuant to 11 U.S.C. § 327(a), nunc pro tunc and effective as of March 26, 2024, 

the Petition Date, as set forth in the Motion to Employ WKPZ, with all fees 

payable with such compensation as may be awarded by the Court upon proper 

motion or application.

2. WKPZ may directly pay from funds supplied by the Debtor the vendor invoices 

for mail out services (copying, postage processing, etc.) without further notice or 

order, provided that such payments are disclosed in the interim and/or final fee 

applications of WKPZ.

###END OF ORDER###

Submitted by:

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

By: /s/ Jeff Carruth

JEFF CARRUTH (TX SBN: 24001846)

2608 Hibernia, Suite 105

Dallas, TX 75204-2514

Telephone: (713) 341-1158

Fax: (713) 961-5341

E-mail: jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR 

HIGH PLAINS RADIO NETWORK, LLC,

DEBTOR AND DEBTOR IN POSSESSION

Case 24-70089-swe11 Doc 57 Filed 04/25/24 Entered 04/25/24 23:32:32 Desc Main

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