Case 18-33967-bjh11 Doc 338 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 1 of 2 GREENBERG TRAURIG, LLP Shari L. Heyen Nancy A. Peterman Texas Bar No. 09564750 Admitted Pro Hac Vice HeyenS@gtlaw.com PetermanN@gtlaw.com 1000 Louisiana St., Suite 1700 77 West Wacker Dr., Suite 3100 Houston, Texas 77002 Chicago, Illinois 60601 Telephone: (713) 374-3564 Telephone: (312) 456-8410 Facsimile: (713) 374-3505 Facsimile: (312) 456-8435 Proposed Counsel for the Official Committee of Unsecured Creditors of Senior Care Centers, LLC, et al. IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: SENIOR CARE CENTERS, LLC, et al., Debtors. CHAPTER 11 CASE NO. 18-33967 (BJH) Jointly Administered NOTICE OF REVISED PROPOSED ORDER AUTHORIZING EMPLOYMENT AND RETENTION OF GREENBERG TRAURIG, LLP AS COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF SENIOR CARE CENTERS, LLC, ET AL. PLEASE TAKE NOTICE THAT the Official Committee of Unsecured Creditors of Senior Care Centers LLC, et al. (the Committee ) has filed the revised proposed Order Authorizing Employment And Retention Of Greenberg Traurig, LLP As Counsel For The Official Committee Of Unsecured Creditors Of Senior Care Centers, LLC, et al. (the Order ) attached hereto as Exhibit 1 reflecting comments from the Office of the United States Trustee and a blackline attached hereto as Exhibit 2 reflecting the revisions from the prior order filed at Docket No. 181. HOU 408928638v1
Case 18-33967-bjh11 Doc 338 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 2 of 2 Dated: January 11, 2019 Respectfully submitted, GREENBERG TRAURIG, LLP /s/ Shari L. Heyen Shari L. Heyen Texas Bar No. 09564750 HeyenS@gtlaw.com 1000 Louisiana St., Suite 1700 Houston, Texas 77002 Telephone: (713) 374-3564 Facsimile: (713) 374-3505 and Nancy A. Peterman Admitted Pro Hac Vice PetermanN@gtlaw.com 77 West Wacker Dr., Suite 3100 Chicago, Illinois 60601 Telephone: (312) 456-8410 Facsimile: (312) 456-8435 Proposed Counsel for the Official Committee of Unsecured Creditors of Senior Care Centers, LLC, et al. CERTIFICATE OF SERVICE The undersigned hereby certifies that on January 11, 2019, a true and correct copy of the foregoing pleading was served by electronic mail via the Court s ECF system to all parties authorized to receive notice in this case. /s/ Shari L. Heyen Shari L. Heyen HOU 408928638v1 2
Case 18-33967-bjh11 Doc 338-1 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 1 of 4 EXHIBIT 1
Case 18-33967-bjh11 Doc 338-1 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 2 of 4 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: SENIOR CARE CENTERS, LLC, et al., Debtors. CHAPTER 11 CASE NO. 18-33967 (BJH) Jointly Administered ORDER AUTHORIZING EMPLOYMENT AND RETENTION OF GREENBERG TRAURIG, LLP AS COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF SENIOR CARE CENTERS, LLC, ET AL. [RELATES TO DKT. NO. ] Upon the application (the Application ) 1 of the Official Committee of Unsecured Creditors (the Committee ) appointed in the chapter 11 cases of Senior Care Centers, LLC, et al. (collectively, the Debtors ) for entry of an Order, pursuant to sections 328(a) and 1103(a) of the Bankruptcy Code and Bankruptcy Rules 2014(a) and 2016(b), authorizing the retention and employment of Greenberg Traurig, LLP as counsel for the Committee; and upon reviewing and considering the Heyen Declaration and the Application; and it appearing that the Court has 1 All capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the Application.
Case 18-33967-bjh11 Doc 338-1 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 3 of 4 jurisdiction over the Application pursuant to 28 U.S.C. 1334; and this being a core proceeding pursuant to 28 U.S.C. 157(b)(2)(A); and due and adequate notice of the Application having been given; and it appearing that no other or further notice need be given; and this Court having determined that based upon the representations in the Application and the Heyen Declaration, Greenberg Traurig represents no interest adverse to the Debtors estates or their creditors, Greenberg Traurig is a disinterested person under section 101(14) of the Bankruptcy Code, and Greenberg Traurig s employment is in the best interests of the Debtors estates and creditors; and after due deliberation and sufficient cause appearing therefor; IT IS HEREBY ORDERED THAT: 1. The Application shall be, and hereby is, granted and approved. 2. The Committee is authorized to retain Greenberg Traurig as its counsel, pursuant to Sections 328(a) and 1103(a) of the Bankruptcy Code, effective as of December 14, 2018, to perform the services set forth in the Application. 3. Greenberg Traurig shall be compensated under the fee arrangement set forth in this Application and in accordance with sections 330 and 331 of the Bankruptcy Code, any applicable Bankruptcy Rules, Local Rules and any orders of this Court. 4. The Committee and Greenberg Traurig are authorized to take all actions necessary to effectuate the relief granted pursuant to this Order in accordance with the Application. 5. Greenberg Traurig shall comply in all respects with N.D. TX L.B.R. 2016-1 and the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. 330 by Attorneys in Large Chapter 11 Cases. 2
Case 18-33967-bjh11 Doc 338-1 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 4 of 4 6. Notice of the Application as provided therein is deemed to be good and sufficient notice of such Application, and the requirements of the Bankruptcy Local Rules are satisfied by the contents of the Application. 7. Notwithstanding any Bankruptcy Rule to the contrary, this Order shall be immediately effective and enforceable upon its entry. 8. The Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order. # # # END OF ORDER # # # 3
Case 18-33967-bjh11 Doc 338-2 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 1 of 5 EXHIBIT 2
Case 18-33967-bjh11 Doc 338-2 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 2 of 5 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: SENIOR CARE CENTERS, LLC, et al., Debtors. CHAPTER 11 CASE NO. 18-33967 (BJH) Jointly Administered ORDER AUTHORIZING EMPLOYMENT AND RETENTION OF GREENBERG TRAURIG, LLP AS COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF SENIOR CARE CENTERS, LLC, ET AL. [RELATES TO DKT. NO. ] Upon the application (the Application ) 1 of the Official Committee of Unsecured Creditors (the Committee ) appointed in the chapter 11 cases of Senior Care Centers, LLC, et al. (collectively, the Debtors ) for entry of an Order, pursuant to sections 328(a) and 1103(a) of the Bankruptcy Code and Bankruptcy Rules 2014(a) and 2016(b), authorizing the retention and employment of Greenberg Traurig, LLP as counsel for the Committee; and upon reviewing and considering the Heyen Declaration and the Application; and it appearing that the Court has 1 All capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the Application.
Case 18-33967-bjh11 Doc 338-2 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 3 of 5 jurisdiction over the Application pursuant to 28 U.S.C. 1334; and this being a core proceeding pursuant to 28 U.S.C. 157(b)(2)(A); and due and adequate notice of the Application having been given; and it appearing that no other or further notice need be given; and this Court having determined that based upon the representations in the Application and the Heyen Declaration, Greenberg Traurig represents no interest adverse to the Debtors estates or their creditors, Greenberg Traurig is a disinterested person under section 101(14) of the Bankruptcy Code, and Greenberg Traurig s employment is in the best interests of the Debtors estates and creditors; and after due deliberation and sufficient cause appearing therefor; IT IS HEREBY ORDERED THAT: 1. 2. The Application shall be, and hereby is, granted and approved. The Committee is authorized to retain Greenberg Traurig as its counsel, pursuant to Sections 328(a) and 1103(a) of the Bankruptcy Code, effective as of December 14, 2018, to perform the services set forth in the Application. 3. Greenberg Traurig shall be compensated under the fee arrangement set forth in this Application and in accordance with sections 328, 330 and 331 of the Bankruptcy Code, any applicable Bankruptcy Rules, Local Rules and any orders of this Court. 4. The Committee and Greenberg Traurig are authorized to take all actions necessary to effectuate the relief granted pursuant to this Order in accordance with the Application. 5. Greenberg Traurig shall comply in all respects with N.D. TX L.B.R. 2016-1 and the Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C. 330 by Attorneys in Large Chapter 11 Cases. 2
Case 18-33967-bjh11 Doc 338-2 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 4 of 5 6. Notice of the Application as provided therein is deemed to be good and sufficient notice of such Application, and the requirements of the Bankruptcy Local Rules are satisfied by the contents of the Application. 7. Notwithstanding any Bankruptcy Rule to the contrary, this Order shall be immediately effective and enforceable upon its entry. 8. The Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order. # # # END OF ORDER # # # 3
Case 18-33967-bjh11 Doc 338-2 Filed 01/11/19 Entered 01/11/19 16:18:50 Page 5 of 5 Document comparison by Workshare 9.5 on Thursday, January 10, 2019 6:11:49 PM Input: Document 1 ID Description Document 2 ID Description Rendering set Legend: Insertion Deletion Moved from Moved to Style change Format change Moved deletion Inserted cell Deleted cell Moved cell Split/Merged cell Padding cell Statistics: file://c:\users\jacobsenk\desktop\408922936_v 1_Application to Employ GT as Committee Counsel.DOC 408922936_v 1_Application to Employ GT as Committee Counsel interwovensite://dms-central/hou/408927973/1 #408927973v1<HOU> - New GT-1 Count Insertions 0 Deletions 1 Moved from 0 Moved to 0 Style change 0 Format changed 0 Total changes 1