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CRAVATH, SWAINE & MOORE LLP 

Paul H. Zumbro (pro hac vice) 

(pzumbro@cravath.com) 

Kevin J. Orsini (pro hac vice) 

(korsini@cravath.com) 

Omid H. Nasab (pro hac vice) 

(onasab@cravath.com) 

Worldwide Plaza 

825 Eighth Avenue 

New York, NY 10019 

Tel: 212 474 1000 

Fax: 212 474 3700 

KELLER & BENVENUTTI LLP 

Tobias S. Keller (#151445) 

(tkeller@kellerbenvenutti.com) 

Jane Kim (#298192) 

(jkim@kellerbenvenutti.com) 

650 California Street, Suite 1900 

San Francisco, CA 94108 

Tel: 415 496 6723 

Fax: 650 636 9251 

Attorneys for Debtors 

and Debtors in Possession 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

In re: 

PG&E CORPORATION,

 - and - 

PACIFIC GAS AND ELECTRIC 

COMPANY,

Bankruptcy Case 

No. 19-30088 (DM) 

Chapter 11 

(Lead Case)(Jointly Administered) 

APPLICATION PURSUANT TO 11 U.S.C. 

§ 327(a) AND FED. R. BANKR. P. 2014(a) 

AND 2016 FOR AUTHORITY TO RETAIN 

AND EMPLOY COMPASS LEXECON, 

LLC AS ECONOMIC CONSULTANTS TO 

THE DEBTORS NUNC PRO TUNC TO 

PETITION DATE 

Date: May 9, 2019 

Time: 9:30 a.m. (Pacific Time) 

 Place: United States Bankruptcy Court, 

 Courtroom 17, 16th Floor 

 San Francisco, CA 94102

Debtors. 

 Affects PG&E Corporation 

 Affects Pacific Gas and Electric 

Company 

 Affects both Debtors 

* All papers shall be filed in the Lead Case, 

No. 19-30088 (DM). 

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PG&E Corporation (“PG&E Corp.”) and Pacific Gas and Electric Company (the 

“Utility”), as debtors and debtors in possession (collectively, “PG&E” or the “Debtors”) in the 

above-captioned chapter 11 cases (the “Chapter 11 Cases”), hereby submit this Application (the 

“Application”), pursuant to section 327(a) of title 11 of the United States Code (the “Bankruptcy 

Code”) and Rules 2014(a) and 2016 of the Federal Rules of Bankruptcy Procedure (the 

“Bankruptcy Rules”), for authority to retain and employ Compass Lexecon, LLC (“Compass”), 

through the Debtors’ litigation counsel, Cravath, Swaine & Moore LLP (“Cravath”), as economic 

consultants for the Debtors effective as of the Petition Date (as defined below) in accordance with 

the terms and conditions set forth in the Engagement Letter as amended (as defined below). 

In support of this Application, the Debtors submit the Declaration of Dr. Adel Turki, a 

Senior Managing Director of Compass (the “Turki Declaration”), and the Declaration of Paul H. 

Zumbro, a partner at Cravath (the “Zumbro Declaration”), filed concurrently herewith. A copy 

of the Engagement Letter as amended (defined below) is annexed as an exhibit to the Turki 

Declaration. A proposed form of order approving the retention and employment of Compass is 

annexed hereto as Exhibit A (the “Proposed Order”). 

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MEMORANDUM OF POINTS AND AUTHORITIES 

I. JURISDICTION 

The Court has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 1334, 

the Order Referring Bankruptcy Cases and Proceedings to Bankruptcy Judges, General Order 24, 

and Rule 5011-1(a) of the Bankruptcy Local Rules for the United States District Court for the 

Northern District of California (the “Bankruptcy Local Rules”). This is a core proceeding 

pursuant to 28 U.S.C. § 157(b). Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 

and 1409. 

II. BACKGROUND 

On January 29, 2019 (the “Petition Date”), the Debtors commenced with the Court 

voluntary cases under chapter 11 of the Bankruptcy Code. The Debtors continue to operate their 

businesses and manage their properties as debtors in possession pursuant to sections 1107(a) and 

1108 of the Bankruptcy Code. No trustee or examiner has been appointed in either of the Chapter 

11 Cases. The Debtors’ Chapter 11 Cases are being jointly administered for procedural purposes 

only pursuant to Bankruptcy Rule 1015(b). 

On February 12, 2019, the United States Trustee (the “U.S. Trustee”) appointed an Official 

Committee of Unsecured Creditors (the “Creditors Committee”). On February 15, 2019, the U.S. 

Trustee appointed an Official Committee of Tort Claimants (the “Tort Claimants Committee” 

and, together with the Creditors Committee, the “Committees”). 

Additional information regarding the circumstances leading to the commencement of the 

Chapter 11 Cases and information regarding the Debtors’ businesses and capital structure is set 

forth in the Amended Declaration of Jason P. Wells in Support of the First Day Motions and 

Related Relief [Docket No. 263] (the “Wells Declaration”). 

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III. CRAVATH’S RETENTION OF COMPASS 

Cravath is the Debtors’ lead coordinating counsel for all wildfire-related issues involving 

PG&E. Prior to the Petition Date, Cravath was lead counsel for PG&E in lawsuits and with respect 

to claims related to the 2017 North Bay fires and the 2018 Camp fire. In the Chapter 11 Cases, 

Cravath is also engaged to handle all litigation matters for PG&E concerning the 2015 Butte fire 

(together with the 2017 North Bay fires and the 2018 Camp fire, the “Northern California

Wildfires”). With respect to the 2017 Northern California Wildfires, Cravath retained Compass 

as its economic consultant on February 24, 2018, and memorialized Compass’ retention in the 

March 22, 2018 letter (together with the current 2019 Schedule of Fees and the April 29, 2019 

amendment, the “Engagement Letter”). The consulting work performed by Compass, and its 

communications with Cravath as part of such retention, is subject to the protections of attorneyclient privilege and the attorney work product doctrine. While such protections limit the extent to 

which Compass’ work may be disclosed or described, Compass’ work to this point has, as a general 

matter, included the evaluation and analysis of potential damages and losses associated with the 

Northern California Wildfires. 

IV. COMPASS’ QUALIFICATIONS 

Compass is a leading economic consulting firm with twenty-one (21) offices and more than 

425 employees globally. Compass has considerable experience providing a wide variety of 

consulting services, including economic and financial analysis, to businesses in various contexts. 

In particular, Compass has expertise evaluating and assessing damages and losses in mass tort 

litigation, including in matters pertaining to the BP Deepwater Horizon oil spill and the General 

Motors ignition switch recalls. 

Compass has been employed in numerous chapter 11 cases, including: In re Aeropostale, 

Inc., Case No. 16-11275 (SHL) (Bankr. S.D.N.Y.); In re AMR Corp., Case No. 11-15463 (SHL) 

(Bankr. S.D.N.Y.); In re GenOn Energy, Inc., Case No. 17-33695 (DRJ) (Bankr. S.D. Tex.); In 

re Lehman Bros. Holdings Inc., et al, 08-01355 (SCC) (Bankr. S.D.N.Y.); In re Lightsquared Inc., 

et al., Case No. 12-12080 (SCC) (Bankr. S.D.N.Y.); In re Motors Liquidation Co., Case No. 09-

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50026 (MG) (Bankr. S.D.N.Y.); In re MPM Silicones, LLC, Case No. 14-22503 (RDD) (Bankr. 

S.D.N.Y.); In re Nine West Holdings, Inc., Case No. 18-10947 (SCC) (Bankr. S.D.N.Y.); In re 

Paragon Offshore PLC, Case No. 16-10386 (CSS) (Bankr. D. Del.); In re Physiotherapy 

Holdings, Inc., Case No. 13-12965 (KG) (Bankr. D. Del.); In re Tribune Co., Case No. 08-13141 

(KJC) (Bankr. D. Del.); and In re Tronox Inc., Case No. 09-10156 (ALG) (Bankr. S.D.N.Y.). 

As described above, Compass performed a number of services for the Debtors prior to the 

Petition Date and as a result, has developed valuable institutional knowledge regarding the subject 

matter of its engagement, which will assist it in providing effective and efficient services in the 

Chapter 11 Cases. Accordingly, Compass is both well-qualified and uniquely able to provide 

certain services during the Chapter 11 Cases in an efficient and timely manner.

V. SCOPE OF SERVICES 

Pursuant to the terms and conditions of the Engagement Letter, the Debtors seek to 

continue to retain Compass, through Cravath, to serve as economic consultants to assist with 

Cravath’s representation of Debtors. The Debtors and Cravath contemplate the continuation of 

Compass’ engagement for a wide variety of services as have been, and may be, requested by 

Cravath and/or the Debtors (the “Services”), including (but not limited to) the following: 

 Analyzing the losses and potential damages associated with the Northern California 

Wildfires; 

 Assisting the Debtors in any claims estimation process in the Chapter 11 Cases, 

including performing economic analysis and data review pertaining to the 

estimation of potential liability in connection with the Northern California 

Wildfires; 

 Supporting the Debtors with related empirical analyses; and

 Providing expert testimony in connection with any of the foregoing services. 

To the extent that the Debtors and Compass later determine that Compass will perform 

additional services, deemed appropriate and necessary to benefit the Debtors’ estates, and going 

beyond those contemplated by the Application or reasonable extensions thereof, Compass and 

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the Debtors may enter into additional agreements with respect to such services and will seek 

separate retention orders with regard to any such additional agreements. 

VI. NO DUPLICATION OF SERVICES 

 The Debtors intend that the services of Compass will complement or be entirely separate 

from, and not duplicate, the services being rendered by other professionals retained by or on behalf 

of Debtors in the Chapter 11 Cases. Compass understands that the Debtors have retained and may 

retain additional professionals during the term of the engagement. Compass will, working together 

with the Debtors and Cravath, use reasonable efforts to avoid the duplication of services being 

rendered by Compass and other professionals in the Chapter 11 Cases, and agrees to work 

cooperatively with any additional professionals to integrate any respective work conducted by the 

professionals on behalf of the Debtors. 

VII. COMPASS’ DISINTERESTEDNESS 

Based upon the Turki Declaration, the Debtors submit that Compass is a “disinterested 

person” as that term is defined in section 101(14) of the Bankruptcy Code, as modified by section 

1107(b) of the Bankruptcy Code. 

Compass is not a “creditor” with respect to fees and expenses of any of the Debtors. See

11 U.S.C. Sections 101(10) and 101(14)(a). In the ninety (90) days before the Petition Date, the 

Debtors paid Compass $739,321.58 for services rendered. To the extent that there are any invoices 

for professional services provided and unpaid by the Debtors as of the Petition Date, Compass 

agrees to waive such unpaid prepetition fees or expenses. Accordingly, as of the Petition Date, 

Compass does not hold a prepetition claim against the Debtors for amounts owed or services 

rendered. 

Compass and the professionals assigned to these Chapter 11 Cases currently do not serve 

and have not served as a director, officer or employee of the Debtors within two years before the 

Petition Date. See 11 U.S.C. Section 101(14)(b). 

To the best of the Debtors’ knowledge, information, and belief, other than as set forth in 

the Turki Declaration and the exhibits thereto, Compass does not hold or represent any interest 

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adverse to the estates or any class of creditors or equity security holders. See 11 U.S.C. Section 

101(14)(c). The Debtors have been informed that Compass will conduct an ongoing review of its 

files to ensure that no disqualifying circumstances arise. If any new relevant facts or relationships 

are discovered, Compass will supplement its disclosure to the Court. 

A. Creditors Committee’s Proposed Retention of FTI 

The Debtors do not believe that the Creditors Committee’s proposed retention of FTI 

Consulting, Inc. (“FTI”)—which occurred long after Debtors retained Compass for purposes of 

the 2017 North Bay fires—impacts Compass’ disinterestedness in this matter. While Compass, a 

wholly owned subsidiary of FTI, constitutes an “affiliate” of FTI within the meaning of section 

101(2) of the Bankruptcy Code, there is nothing in the Bankruptcy Code stating that such 

affiliation, in and of itself, serves as a per se disqualifier for purposes of determining a 

professional’s disinterestedness. The Debtors also do not believe that either the Debtors’ retention 

of Compass or the Creditors Committee’s potential retention of FTI create an interest materially 

adverse to the interest of the estates pursuant to section 101(14)(c) of the Bankruptcy Code. 

Controlling Ninth Circuit precedent teaches that determining whether a party holds an interest that 

is materially adverse to the bankruptcy estate, so as not to qualify as disinterested under the 

Bankruptcy Code, necessarily requires an “objective and fact-driven inquiry” based on an 

examination of “the full panoply of events and elements” or “totality of the circumstances”. In re 

AFI Holding, Inc., 530 F.3d 832, 848 (9th Cir. 2008) (adopting the First Circuit’s standard for 

determining whether a particular conflict is “materially adverse” to the estate sufficient to find a 

lack of disinterestedness). Based on all of the facts and circumstances stated below,1

 Debtors do 

not believe that FTI’s affiliation with Compass creates any conflict sufficient to taint Compass’ 

disinterestedness in these Chapter 11 Cases. 

First, Compass, while owned by FTI, operates as a separate and independent corporate 

entity from FTI. FTI does not manage, oversee or control any aspect of Compass’ day-to-day 

 

1 See also Turki Declaration and Zumbro Declaration. 

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operations. Compass’ management, employees and information technology systems are wholly 

separate and in no way overlap with FTI’s management, employees or information technology 

systems. 

Second, specifically as it relates to the work that Compass has been and may be doing for 

Cravath and the Debtors related to the Northern California Wildfires, FTI has not had, and will 

continue to not have, any supervision or control over any of the work performed by Compass. 

Compass’ work related to the 2017 North Bay fires and the 2018 Camp fire was performed entirely 

by Compass personnel, who, as previously mentioned, share no overlap in any respect with FTI 

personnel and staff. 

Third, Compass has confirmed that FTI has no visibility into, or access to, and has not seen 

to date, any of the work, or the results thereof, that Compass has undertaken for Cravath and the 

Debtors related to the Northern California Wildfires. 

Fourth, FTI and Compass will not be working together, in any way, on any matters as to 

which Compass is being retained in the Chapter 11 Cases. 

The Creditors Committee and FTI have also confirmed and represented to the Debtors that 

FTI operates entirely separately and independently from Compass, as an entirely separate 

corporate entity with separate management and employees, and that FTI will not be privy to, or 

have access to, in any way, the work undertaken by Compass for or on behalf of Debtors. 

Statement of Debtors with Respect to Application of the Official Committee of Unsecured Creditors 

for Entry of an Order Pursuant to 11 U.S.C. §§328(a) and 1103 and Fed. R. Bankr. P. 2014(a) for 

Authorization to Retain and Employ FTI Consulting, Inc. as Financial Advisor Nunc Pro Tunc to 

February 12, 2019 [Docket No. 1560]. The Creditors Committee and FTI have further committed 

to protecting the confidentiality of their client information through the use of its “Ethical Wall 

procedures”. Declaration of Samuel E. Star in Support of Application of the Official Committee 

of Unsecured Creditors for Entry of an Order Pursuant to 11 U.S.C. §§328(a) and 1103 and Fed. 

R. Bankr. P. 2014(a) for Authorization to Retain and Employ FTI Consulting, Inc. as Financial 

Advisor Nunc Pro Tunc to February 12, 2019 [Docket 1212]. These procedures require, inter alia, 

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FTI to set up “electronic internal security walls to ensure that only FTI employees involved directly 

with or working on the FTI Committee Engagement [(i.e., no Compass professionals)] may have 

access to the information, databases, e-mails, schedules or any other information relating to that 

engagement”. Id (emphasis added). Compass will employ similar procedures to ensure that only 

Compass employees involved directly with or working on the Debtors’ engagement may have 

access to the information, databases, e-mails, schedules or any other information relating to that 

engagement. 

Based on these representations and further subject to the condition that the Creditors 

Committee’s retention of FTI would in no way prejudice or preclude, in any way, the Debtors’ 

ongoing ability to utilize Compass’ services, in any capacity, in the Chapter 11 Cases or any other 

context and would not present any conflicts for Compass or for the Debtors’ continuing retention 

and use of the services of Compass, the Debtors do not (and did not) object to the Creditors 

Committee’s proposed retention of FTI. However, as stated by Debtors’ counsel on the record 

before this Court at the hearing held on April 24, 2019, given all the valuable work Compass has 

done to date for the Debtors, it would be tremendously damaging to the Debtors and their estates 

if the Creditors Committee’s retention of FTI were to adversely impact the Debtors’ ability to 

continue to utilize Compass. For this reason and in furtherance of the guidance from the Court, 

the Debtors have submitted this Application at this time so that these important matters for the 

Debtors, the Creditors Committee and their respective professionals can be reviewed by the Court 

on a full record and resolved for all purposes at this time.2

Based on the foregoing, the Debtors do not believe that Compass has “an interest materially 

adverse to the interest of the estate or of any class of creditors” within the meaning of section 

101(14)(c) of the Bankruptcy Code. Importantly in the circumstances before the Court, the 

 

2

 Debtors had not previously filed a retention application for Compass because Debtors do not 

believe that Compass' post-petition work to date falls within the scope of section 327(a) of the 

Bankruptcy Code. However, in light of the Creditors Committee’s proposed retention of FTI, 

out of an abundance of caution and to preserve the Debtors' right to continue using Compass' 

services throughout the Chapter 11 Cases, the Debtors seek this Court's approval to retain 

Compass under section 327(a) of the Bankruptcy Code at this time. 

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Debtors believe this to be true regardless of whether or not the Court approves the Creditor 

Committee’s separate retention application for FTI. Accordingly, the Debtors submit that 

Compass is a “disinterested person” as that term is defined in section 101(14) of the Bankruptcy 

Code, as modified by section 1107(b) of the Bankruptcy Code. 

VIII. PROFESSIONAL COMPENSATION 

 As set forth in the Turki Declaration, Compass will apply to the Court for allowances of 

compensation and reimbursement of expenses in accordance with sections 330 and 331 of the 

Bankruptcy Code, the Bankruptcy Rules, the Bankruptcy Local Rules, the United States 

Bankruptcy Court Northern District of California Guidelines for Compensation and Expense 

Reimbursement of Professionals and Trustees, effective February 19, 2014 (the “Local 

Guidelines”), the U.S. Trustee Guidelines for Reviewing Applications for Compensation and 

Reimbursement of Expenses Filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases, 

effective November 1, 2013 (the “U.S. Trustee Guidelines,” and together with the Local 

Guidelines, the “Fee Guidelines”), the Order Pursuant to 11 U.S.C. §§ 331 and 105(a) and Fed. 

R. Bankr. P. 2016 for Authority to Establish Procedures for Interim Compensation and 

Reimbursement of Expenses of Professionals [Docket No. 701], and any further Orders of the 

Court in the Chapter 11 Cases regarding professional compensation and reimbursement of 

expenses (the “Orders”). 

 Subject to the provisions of the Bankruptcy Code, the Bankruptcy Rules, the Bankruptcy 

Local Rules, the Fee Guidelines, and the Orders, the Debtors propose to compensate Compass as 

contemplated in the Engagement Letter on an hourly basis. 

A. Hourly Fee Engagements: 

 The hourly rates set forth below are Compass’ current applicable hourly rates for 

the work of its professionals and staff members for certain of the engagements set forth in the 

Engagement Letter. These hourly rates reflect Compass’ normal and customary billing practices 

for engagements of this complexity and magnitude. Compass’ hourly rates are subject to periodic 

adjustment from time to time in accordance with Compass’ established billing practices and 

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procedures. Compass will provide reasonable notice of any changes to its hourly rates to the 

Debtors and the U.S. Trustee. 

Compass Professional Hourly Fee 

Senior Professionals $700-975 

Professional Staff $580-685 

Research Staff $220-605 

B. Expenses 

 Additionally, Compass will invoice the Debtors for its reasonable out-of-pocket expenses 

charged during the Chapter 11 Cases, which include, among other things, travel expenses and 

expenses for purchased data. Such out-of-pocket expenses are charged at actual cost. Compass 

will maintain records in support of any actual, necessary costs and expenses incurred in connection 

with the rendering of its services in these Chapter 11 Cases. 

 The Debtors respectfully submit that Compass’ rates and policies stated in the Turki 

Declaration are reasonable, particularly given the nature of the Chapter 11 Cases. 

IX. COMPENSATION, REIMBURSEMENT AND EXCULPATION PROVISIONS IN 

COMPASS’ ENGAGEMENT LETTER 

 By this Application, the Debtors also request that the Court approve the compensation 

(subject to the Court’s approval of Compass’ fee applications), exculpation and related provisions 

in the Engagement Letter (as amended by the April 29, 2019 addendum). 

 As described above, the Debtors retained Compass as their economic consultant on 

February 24, 2018 and memorialized Compass’ retention in the March 22, 2018 letter, using 

Compass’ standard form retention letter. Compass’ standard form retention letter contains a 

limitation of liability provision stating that “Compass shall not be liable under this agreement to 

[the Debtors], [their] counsel, or [their] respective successors, assigns, or affiliates except where 

damages result directly from the gross negligence or willful misconduct of Compass Lexecon or 

its employees. In no event shall Compass Lexecon be liable for punitive or consequential damages 

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of any kind. The terms of this paragraph shall survive the termination of this agreement and shall 

apply to any controlling person, director, officer, employee, subcontractor, independent contractor 

or affiliate of Compass Lexecon. In no event, regardless of whether Compass Lexecon has 

consented to such disclosure, shall Compass Lexecon assume any responsibility to any third party 

to which any advice or report is disclosed or otherwise made available.” 

In anticipation of the filing of this Application, the Debtors were able to negotiate a 

narrower limitation of liability provision in the April 29, 2019 addendum to the March 22, 2018 

letter, and carve out from the liability limitation damages caused by negligence. The addendum 

provides that “[the Debtors], Cravath and Compass Lexecon agree that the provisions governing 

limitation of liability in the [March 22, 2018 letter] are hereby replaced by their entirety by the 

following: 'Compass Lexecon shall not be liable under the Retention Letter to the Client, its 

counsel, or their respective successors, assigns, or affiliates except where damages result directly 

from the negligence, gross negligence or willful misconduct of Compass Lexecon or its 

employees.’” Debtors believe this narrower liability limitation is a reasonable and customary 

provision in agreements concerning the retention of economic consultants. 

X. BASIS FOR RELIEF REQUESTED 

 The Debtors seek authority to employ and retain Compass, through Cravath, as their 

economic consultants under section 327 of the Bankruptcy Code, which provides that a debtor is 

authorized to employ professional persons “that do not hold or represent an interest adverse to the 

estate, and that are disinterested persons, to represent or assist the [debtors] in carrying out the 

[debtors’] duties under this title.” 11 U.S.C. § 327(a). Section 1107(b) of the Bankruptcy Code 

elaborates upon sections 101(14) and 327(a) of the Bankruptcy Code in cases under chapter 11 of 

the Bankruptcy Code and provides that “a person is not disqualified for employment under section 

327 of [the Bankruptcy Code] by a debtor in possession solely because of such person’s 

employment by or representation of the debtor before the commencement of the case.” 11 U.S.C. 

§ 1107(b). 

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XI. NOTICE 

Notice of this Application will be provided to (i) the Office of the U.S. Trustee for Region 

17 (Attn: Andrew R. Vara, Esq. and Timothy Laffredi, Esq.); (ii) counsel to the Creditors 

Committee; (iii) counsel to Tort Claimants Committee; (iv) the Securities and Exchange 

Commission; (v) the Internal Revenue Service; (vi) the Office of the California Attorney General; 

(vii) the California Public Utilities Commission; (viii) the Nuclear Regulatory Commission; (ix) 

the Federal Energy Regulatory Commission; (x) the Office of the United States Attorney for the 

Northern District of California; (xi) counsel for the agent under the Debtors’ debtor in possession 

financing facility; and (xii) those persons who have formally appeared in the Chapter 11 Cases and 

requested service pursuant to Bankruptcy Rule 2002. The Debtors respectfully submit that no 

further notice is required. 

No previous request for the relief sought herein has been made by the Debtors to this or 

any other Court. 

WHEREFORE the Debtors respectfully request entry of an order granting (i) the relief 

requested herein as a sound exercise of the Debtors’ business judgment and in the best interests of 

their estates, creditors, shareholders, and all other parties interests, and (ii) such other and further 

relief as the Court may deem just and appropriate. 

 

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Dated: April 29, 2019 

 CRAVATH, SWAINE & MOORE LLP 

KELLER & BENVENUTTI LLP 

By: /s/ Jane Kim_________________ 

 Jane Kim 

Attorneys for Debtors 

and Debtors in Possession 

Case: 19-30088 Doc# 1756 Filed: 04/29/19 Entered: 04/29/19 18:26:34 Page 14

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