WHEREFORE, applicant respectfully requests that the Court enter an Order
- Date
- 2020-07-22
Summary
An Application to Employ Attorney for Trustee, filed July 23, 2020 as Doc 206 in In re Panthera Enterprises, LLC, Case No. 19-00787, a Chapter 7 case in the United States Bankruptcy Court for the Northern District of West Virginia. Aaron C. Amore, who states he was appointed Trustee on or about July 22, 2020, asks the Court to authorize him to employ himself and Amore Law, PLLC as counsel for the Trustee. The application lists the purposes of the engagement, including preparing pleadings, filing suit to collect amounts owed to the Debtor, recovering assets and seeking approval to liquidate assets. It proposes a rate of $400.00 an hour for attorney time and $100.00 an hour for paralegal time plus necessary expenses, and states the attorney has no conflict of interest. A certificate of service dated July 23, 2020 is attached.
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Cite this document
“WHEREFORE, applicant respectfully requests that the Court enter an Order.”
Original at ecf.wvnb.uscourts.gov, dated 2020-07-22. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-07-22-wherefore-applicant-respectfully-requests-that-the-court-enter-an-order/
, SHA-256 0a2cd1fb58696977ba272490807f22063b48b631e150c383276f4f52b37d1bf1.Full text
No. 2:19-bk-00787 Doc 206 Filed 07/23/20 Entered 07/23/20 11:49:21 Page 1 of 4
UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA
IN RE:
PANTHERA ENTERPRISES, LLC Case No. 19-00787
Debtor. Chapter 7
APPLICATION TO EMPLOY ATTORNEY FOR TRUSTEE
The application of Aaron C. Amore respectfully shows that he was appointed
Trustee of the Bankruptcy Estate of the above-named Debtor on or about July 22,
2020, is duly qualified and is acting as such. Applicant further represents that in the
administration of said Estate and in the performance of his duties as Trustee, it will
be necessary for him to employ counsel for the following purposes: representing the
Trustee in preparing pleadings and attending hearings, if any; file suit to collect
amounts owed to the Debtor; to recover assets and pursue claims on behalf of the
Estate; to seek Bankruptcy Court approval to liquidate assets of the Debtor; and any
and all other matters which may arise in connection with the administration of this
case.
Applicant also represents that professional services of an attorney are
advisable and necessary for the proper administration of the Estate, and applicant
desires that Aaron C. Amore and Amore Law, PLLC, be appointed counsel for the
Trustee and that he believes they are well qualified to act as his counsel in this
matter. Aaron C. Amore of Amore Law, PLLC, is duly licensed to practice in the
United States District Court of this District; is a member of the Bar of the State of
West Virginia since 1994, and is well qualified to act in the capacity for the Trustee.
The Trustee proposes retaining of his firm based upon the fee structure below
No. 2:19-bk-00787 Doc 206 Filed 07/23/20 Entered 07/23/20 11:49:21 Page 2 of 4
that should result in a recovery of funds for the unsecured creditors of the Estate.
Applicant further represents that the employment of Aaron C. Amore and Amore
Law, PLLC, as aforesaid, would be in the best interest of this Estate and that the
attorney is qualified and has no conflict of interest.
Aaron C. Amore of Amore Law, PLLC agrees to be employed at a rate of Four
Hundred Dollars ($400.00) an hour with paralegal time billed at One Hundred
Dollars ($100.00) an hour plus necessary expenses. The costs of any litigation
advanced by Amore Law, PLLC will be reimbursed.
WHEREFORE, applicant respectfully requests that the Court enter an Order
authorizing and permitting him to employ Aaron C. Amore and Amore Law, PLLC,
as counsel for the Trustee in this proceeding.
/s/ Aaron C. Amore
Aaron C. Amore, Trustee
WVSB #6455
206 West Liberty Street
P.O. Box 386
Charles Town, WV 25414
(304) 885-4111
aaron@amorelaw.com
No. 2:19-bk-00787 Doc 206 Filed 07/23/20 Entered 07/23/20 11:49:21 Page 3 of 4
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he served a copy of the foregoing
APPLICATION TO EMPLOY ATTORNEY FOR TRUSTEE on each of the parties at
the addresses set forth below either electronically where noted, or via U.S. mail,
postage prepaid, on this 23rd day of July, 2020.
Electronically via CM/ECF:
• Debra Lee Allen dallen@spilmanlaw.com
• Aaron C. Amore amorewvt@gmail.com,
aca@trustesolutions.net;jackiewvt@gmail.com;annwvt@gmail.com
• Robert S. Bernstein rbernstein@bernsteinlaw.com,
cwirick@bernsteinlaw.com;cwirick@ecf.courtdrive.com;rbernstein@ecf.courtdrive.com
• Julia A. Chincheck jchincheck@bowlesrice.com
• Spencer D. Elliott selliott@lgcr.com
• Leslie Gallian leslie_gallian@wvsb.uscourts.gov
• Douglas E. Kahle dkahle@basnightkinser.com
• Gary O. Kinder gary.o.kinder@usdoj.gov
• Travis Alan Knobbe tknobbe@spilmanlaw.com, dambrose@spilmanlaw.com
• William J. Leon jayleon@comcast.net
• Salene Rae Mazur Kraemer skraemer@bernsteinlaw.com, salene@ecf.courtdrive.com,
• John J. Richardson jrichardson@bernsteinlaw.com
• Zachary James Rosencrance zrosencrance@bowlesrice.com, ajones@bowlesrice.com
• Lisa Smolder lisa_smolder@wvsb.uscourts.gov
• United States Trustee ustpregion04.ct.ecf@usdoj.gov
• Eric Michael Wilson eric.m.wilson@wv.gov, lora.l.rutledge@wv.gov
Via U.S. Mail:
Rob Duncan
Manager/Duncan Development Group, LLC
Rob Duncan
Manager/TR&L, LLC,
a Virginia Limited Liability Company
Successor to SMI, LLC,
a Virginia Limited Liability Company
No. 2:19-bk-00787 Doc 206 Filed 07/23/20 Entered 07/23/20 11:49:21 Page 4 of 4
Bruce Hardy
Stacie Hardy
Mark A. Lindsay
707 Grant Street, Suite 2200
Pittsburgh, PA 15219
Anthony McIntyre
Timothy Miller
John J. Richardson
Bernstein-Burkley, P.C
707 Grant Street, Ste. 2200
Pittsburgh, PA 15219
/s/ Aaron C. Amore
Aaron C. Amore, Trustee
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