DeMarco•Mitchell, PLLC

Robert T. DeMarco

Michael S. Mitchell

1255 West 15th St., 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

IN THE UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

Eagle Trucklines, Inc.,

Debtor.1

Case No.: 23-42504-ELM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

IN RE:

Eagle Trans, Inc.,

Debtor.

Case No.: 23-42505-ELM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

IN RE:

Eagle Fast Ways, Inc.,

Debtor.

Case No.: 23-42506-MXM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

DEBTORS’ APPLICATION FOR ORDER AUTHORIZING EMPLOYMENT 

OF DEMARCO·MITCHELL, PLLC, AS COUNSEL FOR THE DEBTORS

[11 U.S.C. § 327(a) AND FEDERAL RULE 2014(a)]

14-DAY NEGATIVE NOTICE

NO HEARING WILL BE CONDUCTED HEREON UNLESS A WRITTEN RESPONSE IS FILED WITH THE 

CLERK OF THE UNITED STATES BANKRUPTCY COURT AT THE ELDON B. MAHON U.S. 

COURTHOUSE, 501 W. 10TH ST., FORT WORTH, TX 76102-3643 BEFORE CLOSE OF BUSINESS ON 

SEPTEMBER 14, 2023, 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

1 The Debtors in these proceedings (including the last four digits of their respective taxpayer identification numbers) 

are: Eagle Trucklines, Inc., (8689), Eagle Trans, Inc., (8027), and Eagle Fast Ways, Inc. (3935). The Debtors’ respective 

corporate headquarters are: 180 State Street, Southlake, Texas 76092; 4435 East Chandler Blvd., Phoenix, Arizona 

85048; and 525 Woodland Square Blvd., Conroe, Texas 77384.

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 1 of 24
Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC as 

Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)]

Page 2

TO THE HONORABLE UNITED STATES BANKRUPTCY JUDGE:

 COMES NOW, Eagle Trucklines, Inc, Eagle Trans, Inc., and Eagle Fast Ways, Inc., debtors 

and debtors in possession in the above-styled and numbered cases (collectively, the “Debtors”), 

and files this Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC 

as Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)] (the “Application”) by 

and through the undersigned attorney. By the Application, the Debtors request the entry of an 

order authorizing the Debtors to employ the firm of DeMarco·Mitchell, PLLC, (“DM”) as general 

counsel for the Debtors. In support of the Application, the Debtors would respectfully show the 

Court as follows:

I. JURISDICTION

1. The Court has jurisdiction over the subject matter of this Motion pursuant to 28 

U.S.C. §1334(b) and the standing order of reference of the District Court. This matter is a core 

proceeding. 28 U.S.C. §157(b).

2. Venue in this Court is proper under 28 U.S.C. §§ 1408 and 1409.

3. The bases for the relief requested herein include §§ 105(a), 327 and 330 of 11 

U.S.C. §§ 101-1532 (the “Bankruptcy Code”), Rule 2014 of the Federal Rules of Bankruptcy 

Procedure, and Local Rule 2014 of the Local Rules of Bankruptcy Procedure for the Eastern

District of Texas.

II. PROCEDURAL BACKGROUND

4. These bankruptcy cases were commenced by the filing of voluntary petitions for 

relief under Chapter 11 of the Bankruptcy Code on August 25, 2023 (the “Petition Date”).

5. Brad W. Odell has been appointed as the Subchapter V Chapter 11 bankruptcy 

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Document Page 2 of 24
Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC as 

Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)]

Page 3

trustee.

6. The Debtors conduct “over-the-road” trucking operations; transporting goods and 

products nationwide. The Debtors operate as a single economic unit. The sole shareholder of 

each of the Debtors is Gurinder Chouhan. Mr. Chohan also serves as the president of each 

Debtor. 

III. RELIEF REQUESTED

7. The Debtors desire to hire DM as counsel to perform extensive legal services as 

more fully set forth in paragraph 8 herein. The shareholders and/or associates of DM who will 

be engaged in these proceedings are duly admitted to practice before this Court.

8. The Debtors selected as its attorneys the law firm of DM because the firm has 

experience and knowledge in the field of debtors’ and creditors’ rights and because it has handled 

numerous bankruptcy cases and proceedings. Accordingly, Debtors believe DM is qualified to 

represent it in these proceedings.

9. Subject to the control and further order of this Court, DM will be required to 

render the following services to the Debtors:

a. To take all necessary action to protect and preserve the Estate, including 

the prosecution of actions on its behalf, the defense of any actions commenced against 

it, negotiations concerning all litigation in which it is involved, and objecting to claims;

b. To prepare on behalf of the Debtors all necessary motions, applications, 

answers, orders, reports, and papers in connection with the administration of the estate 

herein;

c. To formulate, negotiate, and propose a plan of reorganization; and

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Document Page 3 of 24
Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC as 

Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)]

Page 4

d. To perform all other necessary legal services in connection with these 

proceedings.

10. DM has indicated a willingness to act on the Debtors’ behalf.

11. Pursuant to the provisions of Bankruptcy Rule 2014(a), the Declaration of Robert 

T. DeMarco is attached hereto as Exhibit “A”. Except as may be stated herein and in the 

declaration of Mr. DeMarco, DM, its associates, shareholders, and other members, to the best of 

the Debtors’ knowledge, DM: (a) does not hold or represent any material interest adverse to the 

Debtors or their respective bankruptcy estates; and (b) is a “disinterested person” as that term 

is defined in section 101(14) of the Bankruptcy Code. Moreover, the Debtors believe the 

employment of DM is necessary and in the best interest of the Debtors and their respective

bankruptcy estates.

12. The Debtors desires to employ DM on an hourly basis for actual and necessary 

services rendered by DM, based upon the time, the nature, the extent, and the value of said 

services, in accordance with the firm’s usual rates for the cost of comparable services other than 

in a case under Chapter 11, together with any reimbursement of the firm’s actual and necessary 

expenses. The current rates effective on January 1, 2023, of the firm are set out in the schedule 

attached hereto as Exhibit “B”. The Disclosure of Compensation of Attorney for Debtorsrequired 

by Bankruptcy Rule 2016(b) is attached hereto as Exhibit “C”.

WHEREFORE, PREMISES CONSIDERED, the Debtors respectfully requests that it be

authorized to employ and retain the law firm of DeMarco·Mitchell, PLLC, in this case under 

Chapter 11 of the United States Bankruptcy Code; and for such other and further relief as this 

Court might deem just and proper.

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 4 of 24
Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC as 

Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)]

Page 5

Dated: August 31, 2023

Respectfully submitted,

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

Michael S. Mitchell, Texas Bar No. 00788065

Email mike@demarcomitchell.com

1255 W. 15th Street, 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

Proposed Counsel for Debtors and Debtorsin-Possession

CERTIFICATE OF SERVICE

The undersigned counsel herby certifies that true and correct copies of the foregoing 

pleading and all attachments were served upon all parties listed below in accordance with 

applicable rules of bankruptcy procedure on this 31st day of August, 2023. Where possible, 

service was made electronically via the Court’s ECF noticing system or via facsimile transmission 

where a facsimile number is set forth below. Where such electronic service was not possible, 

service was made via regular first class mail.

DEBTORS

Eagle Trucklines, Inc.,

180 State Street

Southlake, Texas 76092

Eagle Trans, Inc.,

4435 East Chandler Blvd.

Phoenix, Arizona 85048

Eagle Fast Ways, Inc.,

525 Woodland Square Blvd.

Conroe, Texas 77384

TRUSTEES

Office of the United States Trustee

1100 Commerce Street

Room 976

Dallas, TX 75202

Brad W. Odell-SBRA V

Mullin Hoard & Brown, L.L.P.

P.O. Box 2585

Lubbock, TX 79408

ADDITIONAL PARTIES IN INTEREST AND/OR PARTIES REQUESTING NOTICE

SEE ATTACHED MATRIX

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Document Page 5 of 24
Debtors’ Application for Order Authorizing Employment of DeMarco·Mitchell, PLLC as 

Counsel for the Debtors [11 U.S.C. § 327(a) and Federal Rule 2014(a)]

Page 6

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

1255 W. 15th Street, 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 6 of 24
EXHIBIT “A”

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Document Page 7 of 24
DeMarco•Mitchell, PLLC

Robert T. DeMarco

Michael S. Mitchell

1255 West 15th St., 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

IN THE UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

I, Robert T. DeMarco, hereby state that I am over eighteen (18) years of age, of sound 

mind, qualified and competent in all respects to make this Declaration, and do so of my own 

personal knowledge, and further state the following:

A. Background

1. I am an attorney at law admitted to practice in the State of Texas and the Federal 

District Courts for the Northern and Eastern Districts of Texas. I am a member of the law firm of 

DeMarco·Mitchell, PLLC (“DM”), which firm maintains offices for the practice of law at 1255 West 

1 The Debtors in these proceedings (including the last four digits of their respective taxpayer identification numbers) 

are: Eagle Trucklines, Inc., (8689), Eagle Trans, Inc., (8027), and Eagle Fast Ways, Inc. (3935). The Debtors’ respective 

corporate headquarters are: 180 State Street, Southlake, Texas 76092; 4435 East Chandler Blvd., Phoenix, Arizona 

85048; and 525 Woodland Square Blvd., Conroe, Texas 77384.

IN RE:

Eagle Trucklines, Inc.,

Debtor.1

Case No.: 23-42504-ELM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

IN RE:

Eagle Trans, Inc.,

Debtor.

Case No.: 23-42505-ELM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

IN RE:

Eagle Fast Ways, Inc.,

Debtor.

Case No.: 23-42506-MXM-11

Chapter: 11

JOINT ADMINISTRATION REQUESTED

DECLARATION IN SUPPORT OF

OF DEMARCO·MITCHELL, PLLC, AS COUNSEL FOR THE DEBTORS

[11 U.S.C. § 327(a) AND FEDERAL RULE 2014(a)]

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Document Page 8 of 24
Declaration in Support of Debtors’ Application for Order Authorizing Employment of 

DeMarco·Mitchell, PLLC, as Counsel for the Debtors

Page 2

15th Street, Suite 805, Plano, TX 75075.

2. DM, its associates, shareholders, and other members, to the best of my 

knowledge, do not have any connection with the Debtors, their creditors or any other party in 

interest, their respective attorneys and accountants, the United States Trustee, or any person 

employed in the office of the United States Trustee.

B. Disinterestedness

3. Except as otherwise stated herein, to the best of my knowledge, neither I nor any 

employee of DM have any connection with the Debtors, their known secured, priority and 

unsecured creditors, or any other parties in interest or their respective attorneys or accountants.

4. To the best of my knowledge, DM is a “disinterested person” as that term is 

defined in section 101(14) of the Bankruptcy Code in that DM:

a. is not a creditor, equity security holder or insider of the Debtors;

b. is not and was not, within two years before the date of the filing of the 

petition, a director, officer, or employee of the Debtors; and

c. does not have an interest materially adverse to the interest of the estates

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

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

5. To the best of my knowledge DM neither holds nor represents an interest adverse 

to the Debtors within the meaning of section 327(a) of the Bankruptcy Code, except as otherwise 

set forth herein.

6. Neither DM, nor any partner or associate thereof, has received or been promised 

any compensation for legal services rendered or to be rendered in any capacity in connection 

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Document Page 9 of 24
Declaration in Support of Debtors’ Application for Order Authorizing Employment of 

DeMarco·Mitchell, PLLC, as Counsel for the Debtors

Page 3

with these bankruptcy cases, other than as permitted by the Bankruptcy Code. DM has not 

agreed to share compensation received in connection with these cases with any other person, 

except as permitted by section 504(b) of the Bankruptcy Code and Bankruptcy Rule 2016(b) 

respecting the sharing of compensation among DM’s partners. 

7. If any new and relevant facts or relationships are discovered or arise, DM will 

promptly file a supplemental affidavit or declaration in accord with Bankruptcy Rule 2014(a).

C. Qualifications

8. DM has experience and knowledge in the field of bankruptcy and insolvency law. 

Personally, I have over 35 years of experience in these areas and am well–qualified to assist the 

Debtor with such needs. 

9. Personally, I hold a Bachelor of Arts in Political Science, and Political Philosophy,

from Syracuse University (1984). I also hold a Juris Doctor, from Pepperdine University School of 

Law (1988). 

10. Both I and DM have indicated a willingness to act on behalf of the Debtors and to 

subject ourselves to the jurisdiction and supervision of this Court.

D. Scope of Representation

11. DM anticipates providing the following services to the Debtors subject to further 

order of the Court:

a. To take all necessary action to protect and preserve the estates, including 

the prosecution of actions on its behalf, the defense of any actions commenced against 

it, negotiations concerning all litigation in which it is involved, and objecting to claims;

b. To prepare on behalf of the Debtors all necessary motions, applications, 

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Document Page 10 of 24
Declaration in Support of Debtors’ Application for Order Authorizing Employment of 

DeMarco·Mitchell, PLLC, as Counsel for the Debtors

Page 4

answers, orders, reports, and papers in connection with the administration of the estates

herein;

c. To formulate, negotiate, and propose a plan of reorganization; and

d. To perform all other necessary legal services in connection with these 

proceedings.

E. Compensation and Reimbursement of Expenses

Eagle Trucklines, Inc.

12. DM commenced representation of the Eagle Trucklines, Inc. (“Trucklines”) on 

August 23, 2023. To date, a retainer of $9,238.00 has been paid to DM on behalf of the 

Trucklines. DM has incurred fees of $2,042.55, costs and expenses of $0.00, and filing fees of 

$1,738.00 prior to the Petition Date. The remaining balance held in trust by DM is $5,458.45.

Eagle Trans, Inc.

13. DM commenced representation of the Eagle Trans, Inc. (“Trans”) on August 23, 

2023. To date, a retainer of $9,238.00 has been paid to DM on behalf of the Trans. DM has 

incurred fees of $2,042.55, costs and expenses of $0.00, and filing fees of $1,738.00 prior to the 

Petition Date. The remaining balance held in trust by DM is $5,458.45.

Eagle Fast Ways, Inc.

14. DM commenced representation of the Eagle Fast Ways, Inc. (“Fast Ways”) on 

August 23, 2023. To date, a retainer of $9,238.00 has been paid to DM on behalf of the Fast 

Ways. DM has incurred fees of $2,042.55, costs and expenses of $0.00, and filing fees of 

$1,738.00 prior to the Petition Date. The remaining balance held in trust by DM is $5,458.45.

15. Pursuant to 11 U.S.C. §329(a) and Federal Rule of Bankruptcy Procedure 2016(b), 

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Document Page 11 of 24
Declaration in Support of Debtors’ Application for Order Authorizing Employment of 

DeMarco·Mitchell, PLLC, as Counsel for the Debtors

Page 5

I certify that DM are the attorneys for the above-named debtors and that compensation paid to 

DM within one year before the filing of the petition in bankruptcy, or agreed to be paid to DM, 

for services rendered on behalf of the debtor in contemplation or in connection with the 

bankruptcy case is as disclosed above.

16. I further represent that any and all billing statements will separately reflect the 

work performed for each debtor and where the same work is performed for multiple debtors, 

the hourly rate will be pro-rated accordingly.

F. Verification

17. In accordance with the provisions of 28 U.S.C § 1746, I declare under penalty of 

perjury that the foregoing is true and correct. 

Dated: August 31, 2023 /s/ Robert T. DeMarco

Robert T. DeMarco

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Document Page 12 of 24
EXHIBIT “B”

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Document Page 13 of 24
DEMARCO · MITCHELL, PLLC

1255 West 15th Street, Suite 805

Plano, Texas 75075

RATE SCHEDULE

ATTORNEY RATE / HOUR

Robert T. DeMarco

Michael S. Mitchell

$400.00

$300.00

PARALEGAL

Barbara Drake $125.00

 

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Document Page 14 of 24
EXHIBIT “C”

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Document Page 15 of 24
DeMarco•Mitchell, PLLC

Robert T. DeMarco

Michael S. Mitchell

1255 West 15th St., 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

IN RE:

Eagle Fast Ways, Inc.,

Debtor.

Case No.: 23-42506-MXM-11

Chapter: 11

DISCLOSURE OF COMPENSATION OF ATTORNEY

[11 U.S.C. § 329(a)]

Pursuant to 11 U.S.C. § 329(a) and Rule 2016(b) of the Federal Rules of Bankruptcy 

Procedure, I certify that I am the attorney for the above named Debtor and that compensation 

paid to me or my law firm within one (1) year before the petition in bankruptcy, or agreed to be 

paid to me or my firm, for services (“Services”) rendered or to be rendered on behalf of the above 

referenced Debtor in contemplation of or in connection with the bankruptcy cases is as follows:

Prepetition Services: DeMarco Mitchell, PLLC, (“DM”) agreed to accept payment on an hourly 

basis plus costs for prepetition Services relating to the Debtor’s bankruptcy case. DM incurred 

fees in the amount of $2,042.55 and expenses in the amount of $1,738.00 prior to the 

commencement of the case sub judice (“Petition Date”).

Prepetition Retainer: DM received a retainer of $9,238.00 prior to the Petition Date. After 

deducting the total fees and expenses incurred by the Debtor Prepetition, the remainder held in 

trust by DM is $5,458.45.

Postpetition Services: DM has agreed to accept payment on an hourly basis plus costs for 

postpetition services subject to approval by this Court.

Sharing of Compensation: DM has not agreed to share the above disclosed compensation with 

any other person unless they are members or associates of DM.

CERTIFICATION

I hereby certify that the foregoing is a complete statement of any agreement or 

arrangement for payment to me or DM for representation of the Debtor in the above referenced 

bankruptcy case.

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Document Page 16 of 24
FORM 2016(b) Page 2

Dated: August 31, 2023

Respectfully submitted,

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

Michael S. Mitchell, Texas Bar No. 00788065

Email mike@demarcomitchell.com

1255 W. 15th Street, 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

Proposed Counsel for Debtor and Debtor-inPossession

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DeMarco•Mitchell, PLLC

Robert T. DeMarco

Michael S. Mitchell

1255 West 15th St., 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

IN RE:

Eagle Trans, Inc.,

Debtor.

Case No.: 23-42505-ELM-11

Chapter: 11

DISCLOSURE OF COMPENSATION OF ATTORNEY

[11 U.S.C. § 329(a)]

Pursuant to 11 U.S.C. § 329(a) and Rule 2016(b) of the Federal Rules of Bankruptcy 

Procedure, I certify that I am the attorney for the above named Debtor and that compensation 

paid to me or my law firm within one (1) year before the petition in bankruptcy, or agreed to be 

paid to me or my firm, for services (“Services”) rendered or to be rendered on behalf of the above 

referenced Debtor in contemplation of or in connection with the bankruptcy cases is as follows:

Prepetition Services: DeMarco Mitchell, PLLC, (“DM”) agreed to accept payment on an hourly 

basis plus costs for prepetition Services relating to the Debtor’s bankruptcy case. DM incurred 

fees in the amount of $2,042.55 and expenses in the amount of $1,738.00 prior to the 

commencement of the case sub judice (“Petition Date”).

Prepetition Retainer: DM received a retainer of $9,238.00 prior to the Petition Date. After 

deducting the total fees and expenses incurred by the Debtor Prepetition, the remainder held in 

trust by DM is $5,458.45.

Postpetition Services: DM has agreed to accept payment on an hourly basis plus costs for 

postpetition services subject to approval by this Court.

Sharing of Compensation: DM has not agreed to share the above disclosed compensation with 

any other person unless they are members or associates of DM.

CERTIFICATION

I hereby certify that the foregoing is a complete statement of any agreement or 

arrangement for payment to me or DM for representation of the Debtor in the above referenced 

bankruptcy case.

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FORM 2016(b) Page 2

Dated: August 31, 2023

Respectfully submitted,

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

Michael S. Mitchell, Texas Bar No. 00788065

Email mike@demarcomitchell.com

1255 W. 15th Street, 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

Proposed Counsel for Debtor and Debtor-inPossession

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DeMarco•Mitchell, PLLC

Robert T. DeMarco

Michael S. Mitchell

1255 West 15th St., 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

IN THE UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

IN RE:

Eagle Trucklines, Inc.,

Debtor.

Case No.: 23-42504-ELM-11

Chapter: 11

DISCLOSURE OF COMPENSATION OF ATTORNEY

[11 U.S.C. § 329(a)]

Pursuant to 11 U.S.C. § 329(a) and Rule 2016(b) of the Federal Rules of Bankruptcy 

Procedure, I certify that I am the attorney for the above named Debtor and that compensation 

paid to me or my law firm within one (1) year before the petition in bankruptcy, or agreed to be 

paid to me or my firm, for services (“Services”) rendered or to be rendered on behalf of the above 

referenced Debtor in contemplation of or in connection with the bankruptcy cases is as follows:

Prepetition Services: DeMarco Mitchell, PLLC, (“DM”) agreed to accept payment on an hourly 

basis plus costs for prepetition Services relating to the Debtor’s bankruptcy case. DM incurred 

fees in the amount of $2,042.55 and expenses in the amount of $1,738.00 prior to the 

commencement of the case sub judice (“Petition Date”).

Prepetition Retainer: DM received a retainer of $9,238.00 prior to the Petition Date. After 

deducting the total fees and expenses incurred by the Debtor Prepetition, the remainder held in 

trust by DM is $5,458.45.

Postpetition Services: DM has agreed to accept payment on an hourly basis plus costs for 

postpetition services subject to approval by this Court.

Sharing of Compensation: DM has not agreed to share the above disclosed compensation with 

any other person unless they are members or associates of DM.

CERTIFICATION

I hereby certify that the foregoing is a complete statement of any agreement or 

arrangement for payment to me or DM for representation of the Debtor in the above referenced 

bankruptcy case.

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Document Page 20 of 24
FORM 2016(b) Page 2

Dated: August 31, 2023

Respectfully submitted,

/s/ Robert T. DeMarco

DeMarco•Mitchell, PLLC

Robert T. DeMarco, Texas Bar No. 24014543

Email robert@demarcomitchell.com

Michael S. Mitchell, Texas Bar No. 00788065

Email mike@demarcomitchell.com

1255 W. 15th Street, 805

Plano, TX 75075

T 972-578-1400

F 972-346-6791

Proposed Counsel for Debtor and Debtor-inPossession

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USPS FIRST CLASS MAILING RECIPIENTS:

Parties whose names are struck through were not served via First Class USPS Mail Service.

CASE INFO

1LABEL MATRIX FOR LOCAL NOTICING

NCRS ADDRESS DOWNLOAD

CASE 23-42504

NORTHERN DISTRICT OF TEXAS

THU AUG 31 12-5-43 PST 2023

EXCLUDE

(U)BMO HARRIS BANK NA

EXCLUDE

(U)BANC OF AMERICA LEASING CAPITAL

LLC

DEBTOR

EAGLE TRUCKLINES INC

180 STATE STREET 225

SOUTHLAKE TX 76092-7632

MITSUBISHI HC CAPITAL AMERICA INC

CO KEMP SMITH LLP

221 N KANSAS STE 1700

EL PASO TX 79901-1401

EXCLUDE

501 W TENTH STREET

FORT WORTH TX 76102-3637

AMERICAN EXPRESS

CORRESPONDENCEBANKRUPTCY

PO BOX 981535

EL PASO TX 79998-1535

AMUR EQUIPMENT FINANCE

1324 N LAKE DRIVE

LEXINGTON SC 29072-7673

(P)ASCENTIUM CAPITAL

ATTN DOMINIC DILORETO

239070 US 59 NORTH

KINGWOOD TX 77339

ATTORNEY GENERAL OF THE UNITED STATES

MAIN JUSTICE BLDG RM 5111

10TH CONSTITUTION AVE NW

WASHINGTON DC 20503-0001

BCT CONSULTING

7910 N INGRAM AVE STE 101

FRESNO CA 93711-5828

BMO HARRIS BANK

PO BOX BOX 35707

BILLINGS MT 59107-5707

BMO HARRIS BANK NA

PO BOX 3040

CEDAR RAPIDS IA 52406-3040

BANK OF AMERICA

PO BOX 660441

DALLAS TX 75266-0441

BLUE BRIDGE

11921 FREEDOM DRIVE

RESTON VA 20190-6225

(P)COMMERCIAL CREDIT GROUP INC

525 N TRYON STREET

STE 1000

CHARLOTTE NC 28202-0210

(P)JPMORGAN CHASE BANK N A

BANKRUPTCY MAIL INTAKE TEAM

700 KANSAS LANE FLOOR 01

MONROE LA 71203-4774

CORCENTRIC LLC

62861 COLLECTIONS CENTER DRIVE

CHICAGO IL 60693-0001

CROSSROADS

9382 HAVEN AVE

RCH CUCAMONGA CA 91730

CROSSROADS FINANCIAL

9382 HAVEN AVENUE

RANCHO CUCAMONGA CA 91730

DALLAS COUNTY TAXASSESSOR COLLECTOR

500 ELM ST STE 2600

DALLAS TX 75202-3304

DALLAS COUNTY TAXASSESSOR COLLECTOR

500 ELM STREET

DALLAS TX 75202-3304

EFS LLC

PO BOX 630038

CINCINNATI OH 45263-0038

ENGS COMMERCIAL FINANCE

PO BOX 128

ITASCA IL 60143-0128

GURINDER CHOUHAN

12262 QUEENSTON BLVD C

HOUSTON TX 77095-5361

HUNTINGTON BANK

1405 XENIUM LANE NORTH PCC180

PLYMOUTH MN 55441-4408

INTERNAL REVENUE SERVICE

CENTRALIZED INSOLVENCY OPERATIONS

PO BOX 7346

PHILADELPHIA PA 19101-7346

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 22 of 24
USPS FIRST CLASS MAILING RECIPIENTS:

Parties whose names are struck through were not served via First Class USPS Mail Service.

EXCLUDE

(D)INTERNAL REVENUE SERVICE

CENTRALIZED INSOLVENCY OPERATIONS

PO BOX 7346

PHILADELPHIA PA 19101-7346

INTERSTATE BILLING SERVICE INC

DECATUR AL 35609

PO BOX 2208

DECATUR AL 35609-2208

LEE FINANCIAL

PO BOX 12346

FRESNO CA 93777-2346

LOVES TRAVEL STOPS COUNTRY STORES

PO BOX 842568

KANSAS CITY MO 64184-2568

OFFICE OF THE ATTORNEY GENERAL

BANKRUPTCYCOLLECTIONS DIVISION

PO BOX 12548

AUSTIN TX 78711-2548

OFFICE OF THE UNITED STATES TRUSTEE

EARLE CABELL FEDERAL BUILDING

1100 COMMERCE STREET ROOM 976

DALLAS TX 75242-1011

PACCAR

2892 E JENSEN AVENUE

SOUTHLAKE TX 76092

PACCAR

PO BOX 35707

BILLINGS MT 59107-5707

PNC EQUIPMENT FINANCE

655 BUSINESS CENTER DR SUITE 250

HORSHAM PA 19044-3448

PAPE KENWORTH

BOX 35144 5077

SEATTLE WA 98124-5144

SUMITMO MITSUI

666 THIRD AVENUE 8TH FLOOR

NEW YORK NY 10017-4033

TANDEM

3801 AUTOMATION WAY 207

FORT COLLINS CO 80525-5735

TEXAS ALCOHOLIC BEVERAGE COMMISSION

LICENSE AND PERMITS DIVISION

PO BOX 13127

AUSTIN TX 78711-3127

TEXAS ATTORNEY GENERALS OFFICE

BANKRUPTCY COLLECTION DIVISION

PO BOX 12548

AUSTIN TX 78711-2548

TEXAS COMPTROLLER OF PUBLIC ACCOUNT

CO OFFICE OF THE ATTORNEY GENERAL

BANKRUPTCY-COLLECTIONS DIVISION

PO BOX 12548 MC-008

AUSTIN TX 78711-2548

(P)TEXAS COMPTROLLER OF PUBLIC ACCOUNTS

REVENUE ACCOUNTING DIV BANKRUPTCY

SECTION

PO BOX 13528

AUSTIN TX 78711-3528

TEXAS WORKFORCE COMMISSION

TEC BUILDING BANKRUPTCY

101 E 15TH ST

AUSTIN TX 78778-1442

THERMO KING OF CENTRAL CALIFORNIA

PO BOX 2367

FRESNO CA 93745-2367

(P)HUD OGC REGION VI

TIMOTHY E FEELEY

307 W SEVENTH ST SUITE 1000

FT WORTH TX 76102-5108

US DEPT OF VETERANS AFFAIRS

REGIONAL OFFICE FINANCE SECTION 24

701 CLAY AVE

WACO TX 76799-0001

US SECURITIES EXCHANGE COMM

FORT WORTH REGIONAL OFFICE

801 CHERRY ST STE 1900 UNIT 18

FORT WORTH TX 76102-6819

US SMALL BUSINESS ADMINISTRATION

150 WESTPARK WAY STE 130

EULESS TX 76040-3705

UMPQUA BANK

3455 SOUTH 344TH WAY 300

AUBURN WA 98001-9546

UNITED STATES ATTORNEY

1100 COMMERCE STREET 3RD FL

DALLAS TX 75242-1074

UNITED STATES ATTORNEY

NORTHERN DISTRICT OF TEXAS

1100 COMMERCE STREET 3RD FL

DALLAS TX 75242-1074

UNITED STATES TRUSTEE

1100 COMMERCE STREET

ROOM 976

DALLAS TX 75242-0996

VOLVO VFS US LLC

PO BOX 26131

GREENSBORO NC 27402-6131

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 23 of 24
USPS FIRST CLASS MAILING RECIPIENTS:

Parties whose names are struck through were not served via First Class USPS Mail Service.

VERDANT

12301 WHITEWATER DR STE 80

HOPKINS MN 55343-4157

VOLVO

7025 ALBERT PICK ROAD 105

GREENSBORO NC 27409-9519

BRAD W ODELL SBRA V

MULLIN HOARD BROWN LLP

PO BOX 2585

LUBBOCK TX 79408-2585

ROBERT THOMAS DEMARCO

DEMARCOMITCHELL PLLC

1255 W 15TH ST STE 805

PLANO TX 75075-7225

Case 23-42504-elm11 Doc 15 Filed 08/31/23 Entered 08/31/23 16:08:46 Desc Main

Document Page 24 of 24