ROBBIN L. ITKIN (SBN 117105) Chapter 7 Trustee UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF...

DLA PIPER LLP (US)LOS A NG EL ES

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ROBBIN L. ITKIN (SBN 117105) [email protected] DLA PIPER LLP (US) 2000 Avenue of the Stars Suite 400 North Tower Los Angeles, California 90067-4704 Tel: (310) 595-3000 Fax: (310) 595-3300

JOHN K. LYONS (Pro Hac Vice) [email protected] KATIE ALLISON (Pro Hac Vice) [email protected] DLA PIPER LLP (US) 444 West Lake Street, Suite 900 Chicago, Illinois 60606-0089 Tel: (312) 368-4000 Fax: (312) 236-7516

Attorneys for Jonathan D. King as Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURTCENTRAL DISTRICT OF CALIFORNIA

LOS ANGELES DIVISION

In re:

ZETTA JET USA, INC., a California corporation,

Debtor.

Lead Case No.: 2:17-bk-21386-SK

Chapter 7

Jointly Administered With: Case No.: 2:17-bk-21387-SK

CHAPTER 7 TRUSTEE’S APPLICATION TO EMPLOY OON & BAZUL LLP AS SPECIAL COUNSEL, PURSUANT TO SECTIONS 327(a) AND 330 OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 2014 AND LOCAL BANKRUPTCY RULE 2014-1, NUNC PRO TUNC TO DECEMBER 6, 2017; DECLARATION OF TAN MEI YEN IN SUPPORT THEREOF

[No Hearing Required Unless Requested – Pursuant to Local Bankruptcy Rule 2014-1]

In re:

ZETTA JET PTE, LTD., a Singaporean corporation,

Debtor.

☐ Affects Both Debtors

☐ Affects Zetta Jet USA, Inc., a California corporation, only ☒ Affects Zetta Jet PTE, Ltd., a Singaporean corporation, only

Case 2:17-bk-21386-SK Doc 612 Filed 02/09/18 Entered 02/09/18 19:53:03 Desc Main Document Page 1 of 58


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TO THE HONORABLE SANDRA R. KLEIN, UNITED STATES BANKRUPTCY JUDGE, THE UNITED STATES TRUSTEE, THE TWENTY LARGEST UNSECURED CREDITORS, THE AIRCRAFT FINANCING PARTIES, AND SPECIAL SERVICE PARTIES:

Jonathan D. King, solely in his capacity as the duly appointed chapter 7 trustee (the

“Chapter 7 Trustee”) in the above-captioned, jointly administered bankruptcy cases (the “Chapter

7 Cases”) of Zetta Jet USA, Inc. (“Zetta Jet USA”) and Zetta Jet PTE, Ltd. (“Zetta Jet PTE,” and

together with Zetta Jet USA, the “Debtors”), hereby applies (the “Application”) to this Court for

an order, pursuant to Sections 327(a) and 330 of title 11 of the United States Code (the

“Bankruptcy Code”), Rule 2014 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy

Rules”), and Rule 2014-1 of the Local Bankruptcy Rules of the United States Bankruptcy Court

for the Central District of California (the “Local Bankruptcy Rules”), authorizing the Chapter 7

Trustee’s retention and employment of Oon & Bazul LLP (the “Firm”) as special counsel to the

Chapter 7 Trustee in Singapore. More specifically, contemporaneously herewith, the Chapter 7

Trustee is filing retention papers for KordaMentha, which will, among other things, serve as the

Chapter 7 Trustee’s Singapore-based representative to assist him in carrying out his duties as

foreign representative (the “Singapore Liquidators”).1 The Singapore court has granted limited

recognition to the Chapter 7 Trustee to apply to set aside or appeal an injunction obtained by Asia

Aviation Holdings Pte Ltd in Singapore, and has deferred the Chapter 7 Trustee’s recognition

application, which is to be reinstated after the injunction has been disposed of.2 If the Singapore

1 Under Singapore law, liquidators are akin to foreign representatives under Chapter 15 of the Bankruptcy Code. 2 As stated above, on September 15, 2017, the Chapter 11 cases were filed. Three days later, on September 18, 2017, together, Geoffrey Cassidy (“Cassidy”), through his company Asia Aviation Holdings Pte. Ltd., and Li Qi, through his company Truly Great Global Limited, filed an ex parte application for an injunction in Singapore to enjoin Debtor Zetta Jet PTE and its officers from continuing the Chapter 11 Cases. In support of this application, Cassidy signed an affidavit that falsely asserted, among other things, that he was wrongfully accused of misappropriating millions of dollars from the Debtors (which the Chapter 7 Trustee’s investigation has since confirmed) and had a “rescue plan” that could have staved off the Chapter 11 filings (which also was fictitious).

Relying on Cassidy’s misleading affidavit, Judicial Commissioner Valerie Thean of the Singapore Court in case number Case No.: HC/S 864/2017 (the “Singapore Original Proceeding”) granted the ex parte application and entered the injunction (the “Ex Parte Injunction”).

On September 29, 2017, after briefing by the Debtors, Li Qi , and other interested parties, the Bankruptcy Court found that the Ex Parte Injunction violated the automatic stay and was void. See H’rg. Tr., Sept. 29, 2017, at 44:4-8.



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Court grants the Chapter 7 Trustee’s recognition application, and if the Singapore Liquidators are

appointed by the Singapore Court, the Singapore Liquidators will provide services to assist the

Chapter 7 Trustee in the carrying out his duties as foreign representative.

Under Singapore law, the Chapter 7 Trustee requires local counsel from Singapore to

assist him and his local representatives in the performance of his duties and appear in Singapore

courts. Accordingly, the Chapter 7 Trustee has selected the Firm to serve as local counsel to him

and the Singapore Liquidators as local representatives in connection with the insolvency

proceedings pending in Singapore with respect to Zetta Jet PTE. In addition, the Firm is

providing special local counsel services to the Chapter 7 Trustee in connection with the

recognition proceedings. Specifically, Singapore courts impose restrictions on foreign law firms

(even those with offices in Singapore) appearing before them and require that a local firm appear

instead. The Chapter 7 Trustee has selected the Firm to undertake this task, and the Firm is

working in conjunction with DLA Piper Singapore Pte. Ltd. on this matter to coordinate services

on a cost-effective basis.3

The Chapter 7 Trustee is seeking appointment of the Firm effective as of December 6,

2017, the date when the Firm commenced performing services for the Chapter 7 Trustee, upon the

On December 13, 2017, the Chapter 7 Trustee sought recognition in Singapore of the Bankruptcy Cases. After briefing by the parties, on January 26, 2018, Judge Aedit Abdullah of the High Court of the Republic of Singapore ( the “Singapore Recognition Court”) granted in part and deferred in part the Chapter 7 Trustee’s recognition application.

In its ruling (attached hereto as Exhibit A), the Singapore Recognition Court found that public policy exception under Article 6 of the UNCITRAL Model Law on Cross-Border Insolvency, as enacted in Singapore under the Tenth Schedule of the Companies Act, precluded full recognition due the pendency of the Ex Parte Injunction. However, the Singapore Recognition Court granted limited recognition to allow the Chapter 7 Trustee to apply to lift the Ex Parte Injunction in the Singapore Original Proceeding and, if successful, return to the Singapore Recognition Court for further relief.

The Chapter 7 Trustee intends to seek relief from the Singapore Original Proceeding to vacate the Ex Parte Injunction based upon, among other grounds, Cassidy’s submission of an affidavit of materially false representations designed to deceive the Court in the Singapore Original Proceeding to grant the Ex Parte Injunction.

3 The lead attorney at the Firm who worked on the recognition proceedings in conjunction with DLA Piper Singapore Pte. Ltd. moved to the Firm from the Singapore firm of WongPartnership LLP. Give this attorney’s institutional knowledge of the recognition proceedings, the Chapter 7 Trustee determined, in the exercise of his business judgment, to retain the Firm to handle the recognition matters.



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terms and conditions described below.4 In support of this Application, the Chapter 7 Trustee

relies upon the Declaration of Tan Mei Yen (the “Declaration”), which is incorporated herein by

reference. In further support of this Application, the Chapter 7 Trustee respectfully states as

follows:

I. STATUS OF CASE AND JURISDICTION

1. On September 15, 2017 (the “Petition Date”), the Debtors commenced bankruptcy

proceedings by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code (the

“Chapter 11 Cases”).

2. On September 29, 2017, the Court entered the Order Granting Debtors’

Emergency Motion to Approve Stipulation for Appointment of Chapter 11 Trustee Pursuant to §

1104 [Docket No. 120]. On October 5, 2017, the Office of the United States Trustee (“U.S.

Trustee”) filed the Notice of Appointment of Chapter 11 Trustee, indicating that the U.S. Trustee

had appointed Mr. King as the chapter 11 trustee (the “Chapter 11 Trustee”) in the Chapter 11

Cases [Docket No. 155].

3. On October 12, 2017, the U.S. Trustee appointed an official committee of

unsecured creditors (the “Committee”).

4. On November 30, 2017 (the “Shutdown Date”), based upon a lack of funds to

operate the Debtors’ business, the Chapter 11 Trustee shut down operations, terminated all

employees, and, on December 4, 2017, this Court entered the orders granting the Chapter 11

Trustee’s motions to convert the Debtors’ Chapter 11 Cases to cases under Chapter 7 of the

Bankruptcy Code (the “Conversion Date”) [Docket No. 452 for Zetta Jet USA and Docket No. 52

for Zetta Jet PTE]. Upon entry of the orders converting the cases, the Committee was effectively

disbanded and ceased to exist.

5. On December 5, 2017, the Notice of Appointment of Trustee and Fixing of Bond

was filed, pursuant to which the U.S. Trustee appointed Mr. King to serve as the Chapter 7

4The Firm has been providing critical services since the Conversion Date (as defined below). Due to delays

associated with conflicts checks and assignment of tasks and coordination of services among each of the Chapter 7 Trustee’s professionals, this Application was filed as soon as possible.



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Trustee in these Chapter 7 Cases [Docket No. 458 for Zetta Jet USA and Docket No. 53 for Zetta

Jet PTE]. After the Section 341(a) meeting of creditors that was held on January 8, 2018, Mr.

King was made the permanent Trustee in the Debtors’ Chapter 7 Cases.

6. This Court has jurisdiction over these Chapter 7 Cases, the Debtors’ estates, and

this matter pursuant to 28 U.S.C. §§ 1334(a), 1334(b) and 1334(e). This matter is a core

proceeding within the meaning of 28 U.S.C. § 157. Venue of these cases and these proceedings

in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409. The basis for the relief

requested herein are Sections 327(a) and 330 of the Bankruptcy Code, Bankruptcy Rule 2014,

and Local Bankruptcy Rule 2014-1.

A. Employment of Oon & Bazul LLP as Special Counsel to the Chapter 7 Trustee

7. As the Chapter 7 Trustee appointed in these Chapter 7 Cases, Mr. King is

responsible for the performance of certain duties, as set forth in Section 704 of the Bankruptcy

Code. To assist him in the performance of his duties, the Chapter 7 Trustee has determined, in

the exercise of his business judgment, to retain certain professionals.

8. As noted above, contemporaneously herewith, the Chapter 7 Trustee is filing

retention pleadings for KordaMentha, which will, among other things, serve as the Chapter 7

Trustee’s Singapore Liquidators, and will provide services to assist the Chapter 7 Trustee in

carrying out his duties as foreign representative. Under Singapore law, the Chapter 7 Trustee

requires local counsel from Singapore to assist him and his local representatives in the

performance of his duties and appear in Singapore courts. Accordingly, the Chapter 7 Trustee has

selected the Firm to serve as local counsel to him and the Singapore Liquidators in connection

with the insolvency proceedings pending in Singapore with respect to Zetta Jet PTE, as required

by Singapore law.

9. In addition, Singapore courts impose restrictions on foreign law firms (even those

with offices in Singapore) appearing before them and require that a local firm appear

instead. The Chapter 7 Trustee has selected the Firm to assist him with the recognition

proceedings. The Firm is working in conjunction with DLA Piper Singapore Pte. Ltd. to



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coordinate services on a cost-effective basis.5

10. The proposed Services outlined hereunder are necessary to carry out asset recovery

and wind down efforts in Singapore and will not involve duplication of services of other

professionals retained by the Chapter 7 Trustee such as KCP Advisory Group LLC and Michael

Goldman & Associates LLC (focusing on US based accounting and financial services and tax

return preparation and filing, respectively), PricewaterhouseCoopers Advisory Services LLC

(focusing on forensic services in Singapore), Braunco, Inc. (focusing on U.S. asset liquidation

services), Seabury Corporate Finance LLC, together with its broker-dealer affiliate, Seabury

Securities LLC (providing limited interim financial services pending transition to KCP Advisory

Group LLC), and KordaMentha (serving as the Chapter 7 Trustee’s local representative and

liquidation agent in Singapore). The Chapter 7 Trustee will continue to monitor professionals to

ensure cost effective delivery of services.

B. Scope of Services to be Provided

11. As set forth below, the Firm will provide certain complementary legal services in

connection with the Chapter 7 Trustee’s recovery efforts in the Singapore courts and under

Singapore law generally, and assist, and serve as local counsel to, the Singapore Liquidators, if

appointed (collectively, the “Services”), pursuant to an engagement letter entered into between

the Firm and the Chapter 7 Trustee, effective as of December 6, 2017, which was amended and

superseded by an engagement letter dated as of December 18, 2017 (together, the “Engagement

Agreement”).

12. Pursuant to the Engagement Agreement, the Firm will

advise on matters of Singapore law relating to the Chapter 7 Trustee’s wind down efforts in Singapore and those of the Singapore liquidators, if appointed;

5 The lead attorney at the Firm who worked on the recognition proceedings in conjunction with DLA Piper Singapore Pte. Ltd. moved to the Firm from the Singapore firm of WongPartnership LLP. Give this attorney’s institutional knowledge of the recognition proceedings, the Chapter 7 Trustee determined, in the exercise of his business judgment, to retain the Firm to handle the recognition matters.



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represent the Chapter 7 Trustee, and by extension, the Singapore Liquidators, in respect of proceedings brought in Singapore courts or in other legal matters in Singapore;

provide such other related services at the request of the Chapter 7 Trustee and the Singapore Liquidators, as requested by the Chapter 7 Trustee; and

represent the Chapter 7 Trustee in certain litigation pending before the Singapore court.

C. Disclosures Under Bankruptcy Rule 2014

13. As discussed in further detail below, the Debtor seeks an order pursuant to Section

327(a) of the Bankruptcy Code authorizing the Chapter 7 Trustee to engage the Firm to provide

the above-described legal services, as contemplated by the Engagement Agreement.

14. Based upon the Declaration, to the best of the Chapter 7 Trustee’s knowledge, the

Firm and its personnel to be retained by the Chapter 7 Trustee: (a) are not equity security holders,

or insiders of the Debtors; (b) are not and were not, within the two years before the petition date,

directors, officers, or employees of the Debtors; and (c) do not have an interest materially adverse

to the interests 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 Debtors. The Firm is not a

creditor of the Debtors’ estates.

15. Further, based upon the Declaration, and except as set forth herein and therein, to

the best of the Chapter 7 Trustee’s knowledge, the Firm and its personnel to be retained by the

Chapter 7 Trustee are disinterested persons, who do not hold or represent an interest adverse to

the Debtors’ estates, and, except as set forth in the Declaration, do not have any connection either

with the Debtor, its creditors, or any other parties in interest in this case, with their respective

attorneys or accountants, with any judge of this Court, with the U.S. Trustee, or with any person

employed in the Office of the U.S. Trustee.

16. The Firm will periodically review their respective files during the pendency of

these Chapter 7 Cases to ensure that no conflicts or other disqualifying circumstances exist or

arise. If any new relevant facts or relationships are discovered or arise, the Firm will use



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reasonable efforts to identify such further developments and will file promptly a supplemental

declaration, as required by Bankruptcy Rule 2014(a).

D. Compensation Terms

17. The Firm has not received a retainer or any payments in connection with this

engagement and has not agreed to share any compensation received or to be received on account

of services performed in connection with these Chapter 7 Cases with any other party other than

among its partners and members. As set forth in the Engagement Agreement, the Firm will

perform its Services for which it shall bill the Debtors at the following hourly rates: Tan Mei Yen,

the partner in charge of the matter, at SGD $690 per hour,6 Ng Wei Long, associate, at SGD $390

per hour,7 and trainees at SGD $120 per hour8 (the “Fee Structure”).

18. Subject to approval of the Court through the filing of fee applications, the Chapter 7

Trustee will reimburse the Firm for services rendered and reasonable out-of-pocket

expenses incurred by the Firm in connection with the services to be rendered under the

Engagement Agreement. The Firm shall be reimbursed for economy class travel (or its

equivalent) except for international travel greater than five (5) hours in duration, in which case

the Firm’s personnel may be permitted to book in business class.

19. Upon termination of this Engagement Agreement, and subject to approval

of the Court , the Chapter 7 Trustee shall reimburse the Firm only for such out-of-pocket

expenses reasonably incurred or accrued prior to termination. Invoices submitted to the

Chapter 7 Trustee will, in each case, include adequate detail including employee name, date of

expense charge, type of expense and amount.

20. The Fee Structure is consistent with and typical of arrangements entered into by

other advisors of comparable standing in connection with the rendering of similar services to

clients such as the Chapter 7 Trustee. The Firm and the Chapter 7 Trustee believe that the

foregoing compensation arrangement is both reasonable and market-based.

6 As of January 30, 2018, this is the approximate equivalent of USD$525.95. 7 As of January 30, 2018, this is the approximate equivalent of USD$297.28. 8 As of January 30, 2018, this is the approximate equivalent of USD$91.47.



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II. INDEMNIFICATION

21. Paragraph 14 of Appendix 1 to the Engagement Agreement also provides that the

estates will indemnify the Firm in certain circumstances and on certain terms, and more

specifically, in the event of the Chapter 7 Trustee’s fault, negligence, or lack of care. Similar

indemnification provisions have been approved by this Court with respect to other retained

professionals.

III. BASIS FOR RELIEF REQUESTED

22. Pursuant to Section 327(a) of the Bankruptcy Code, a trustee 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 trustee in carrying out its duties under [the

Bankruptcy Code.]” 11 U.S.C. § 327(a).

23. The Chapter 7 Trustee seeks approval of the Fee Structure under Section 328(a) of

the Bankruptcy Code, which provides, in relevant part, that the Chapter 7 Trustee “with the

court’s approval, may employ or authorize the employment of a professional person under

Section 327 . . . on any reasonable terms and conditions of employment, including on a retainer,

on an hourly basis, on a fixed or percentage fee basis, or on a contingency fee basis . . . “ 11

U.S.C. § 328(a). Section 328 of the Bankruptcy Code permits the compensation of professionals,

including auditors, accountants, and financial advisors, on more flexible terms that reflect the

nature of their services and market conditions, which is a significant departure from prior

bankruptcy practice relating to the compensation of professionals. As the United States Court of

Appeals for the Fifth Circuit recognized in In re National Gypsum Co., 123 F.3d 861, 862 (5th

Cir. 1997) (citations omitted):

[p]rior to 1978, the most able professionals were often unwilling to work for bankruptcy estates where their compensation would be subject to the uncertainties of what a judge thought the work was worth after it had been done. The uncertainty continues under the present §330 of the Bankruptcy Code, which provides that the court award to professional consultants reasonable compensation based on relevant factors of time and comparable costs, etc. Under present § 328 the professionals may avoid that uncertainty by obtaining court approval of compensation agreed to with the trustee (or debtor or committee).



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Id. at 862. Owing to this inherent uncertainty, courts in this jurisdiction have approved similar

arrangements that contain reasonable terms and conditions under Section 328 of the Bankruptcy

Code. See, e.g., In re Aspect Software Parent, Inc., Case No. 16-10597 (MFW) (Bankr. D. Del.

Apr. 21, 2016); In re EveryWare Global, Inc., Case No. 15-10743 (LSS) (Bankr. D. Del. May 20,

2015.

24. Thus, Section 328(a) of the Bankruptcy Code permits this Court to approve the

terms and conditions of the Firm’s engagement as set forth in the Engagement Agreement. The

Fee Structure appropriately reflects the nature and scope of services to be provided by the Firm,

and the fee structures typically utilized by the Firm and other similar firms outside of chapter 7.

The retention of the Firm is an exercise of the reasonable business judgment of the Chapter 7

Trustee.

25. The Firm will file fee applications consistent with all applicable orders of the

Court.

IV. CONCLUSION

WHEREFORE, the Chapter 7 Trustee respectfully requests that the Court grant

this Application, and such other and further relief that the Court deems just and proper.

DATED: February 9, 2018 DLA PIPER LLP (US)

By: /s/ Robbin L. Itkin ROBBIN L. ITKIN (SBN 117105) JOHN K. LYONS (Pro Hac Vice) KATIE ALLISON (Pro Hac Vice)

Attorneys for the Chapter 7 Trustee






















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DECLARATION OF TAN MEI YEN

I, TAN MEI YEN, declare:

1. I have personal knowledge of the facts set forth below and, if called upon to

testify, would and could competently testify to the matters set forth in this declaration (the

“Declaration”).

2. I am a Partner and the Head of the Restructuring and Insolvency Practice at the

Oon & Bazul LLP (the “Firm”). I submit this Declaration in support of the Chapter 7 Trustee’s

Application to Employ Oon & Bazul LLP as Special Counsel, Pursuant to Sections 327(a) and

328 of the Bankruptcy Code, Bankruptcy Rule 2014, and Local Bankruptcy Rule 2014-1, Nunc

Pro Tunc to December 6, 2017 (the “Application”).1

3. The Chapter 7 Trustee has requested that the Firm provide certain complementary

legal services in connection with the Chapter 7 Trustee’s recovery efforts in the Singapore courts

and under Singapore law generally, and assist, and serve as local counsel to, the Singapore

Liquidators, if appointed, and to serve as counsel to the Chapter 7 Trustee in connection with the

recognition proceedings pending before the Singapore court (collectively, the “Services”),

pursuant to an engagement letter entered into between the Firm and the Chapter 7 Trustee,

effective as of December 6, 2017, which was amended and superseded by an engagement letter

dated as of December 18, 2017 (together, the “Engagement Agreement”), which is attached

hereto as Exhibit 1.

4. Pursuant to the Engagement Agreement, the Firm will:

advise on matters of Singapore law relating to the Chapter 7 Trustee’s wind down efforts in Singapore and those of the Singapore Liquidators, if appointed;

represent the Chapter 7 Trustee, and by extension, the Singapore Liquidators, in respect of proceedings brought in Singapore courts or in other legal matters in Singapore;

provide such other related services at the request of the Chapter 7 Trustee and the Singapore Liquidators, as requested by the Chapter 7 Trustee; and

1 Capitalized terms used but not defined herein shall have the meanings ascribed in the Application.



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represent the Chapter 7 Trustee in certain litigation pending before the Singapore court.

5. The Firm will provide critical services that complement, not duplicate, the services

provided by the Chapter 7 Trustee’s counsel and other professionals.

6. Summaries of my experience and qualifications, along with the personnel who will

be primarily responsible for this engagement, are attached hereto collectively as Exhibit 2.

26. The Firm has not received a retainer or any payments in connection with this

engagement and has not agreed to share any compensation received or to be received on account

of services performed in connection with these Chapter 7 Cases with any other party other than

among its partners and members. As set forth in the Engagement Agreement, the Firm will

perform its Services for which it shall bill the Debtors at the following hourly rates Tan Mei Yen,

the partner in charge of the matter, at SGD $690 per hour,2 Ng Wei Long, associate, at SGD $390

per hour,3 and trainees at SGD $120 per hour4 (the “Fee Structure”).

7. Subject to approval of the Court through the filing of a fee application, the Chapter

7 Trustee will reimburse the Firm for services rendered and reasonable out-of-pocket

expenses incurred by the Firm in connection with the services to be rendered under the

Engagement Agreement. The Firm shall be reimbursed for economy class travel (or its

equivalent) except for international travel greater than five (5) hours in duration, in which case

the Firm’s personnel may be permitted to book in business class.

8. Upon termination of this Engagement Agreement, and subject to approval

of the Court , the Chapter 7 Trustee shall reimburse the Firm only for such out-of-pocket

expenses reasonably incurred or accrued prior to termination. Invoices submitted to the

Chapter 7 Trustee will, in each case, include adequate detail including employee name, date of

expense charge, type of expense and amount.

9. The Fee Structure is consistent with and typical of arrangements entered into by

other advisors of comparable standing in connection with the rendering of similar services to

2 As of January 30, 2018, this is the approximate equivalent of USD$525.95. 3 As of January 30, 2018, this is the approximate equivalent of USD$297.28. 4 As of January 30, 2018, this is the approximate equivalent of USD$91.47.



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clients such as the Chapter 7 Trustee. I believe that the foregoing compensation arrangement is

both reasonable and market-based.

10. To the best of my knowledge, except as otherwise set forth below, based upon a

review of the Firm’s regular computerized records, (a) neither I, nor any partner, associate, or

employee of the Firm has a connection with the Debtors, their creditors, the Office of the United

States Trustee for the Central District of California, Los Angeles Division, any person employed

in the office of the U.S. Trustee or any other party with an actual or potential interest in these

Chapter 7 Cases or their respective attorneys or accountants; (b) neither I, nor any nor any

partner, associate, or other personnel of the Firm is an equity security holder or insider of the

Debtors or the Chapter 7 Trustee; (c) the Firm is not and was not, within two years of the Petition

Date, a director, officer or employee of the Debtors; and (d) the Firm does not have an interest

adverse to the Debtors, their respective estates or 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. The Firm is not a creditor of the Debtors’ estates. Accordingly, the Frim is

a “disinterested person,” as defined in Section 101(14) of the Bankruptcy Code and as required by

Section 327(a) of the Bankruptcy Code.

11. The Firm represents World Fuel Services, a creditor of one or more of the Debtors,

in matters wholly unrelated to these Chapter 7 Cases or the matters described in the Application

for which the Firm is providing services.

12. The Firm and its personnel are not related to or employees of the Office of the

United States Trustee or the United States Bankruptcy Judge herein.

[Signature Page Follows]




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Exhibit 1

[Engagement Letter]
















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EAST\150446317.14

Exhibit 2

[Biographies]


Particulars

Mei Yen Tan

Partner, Head of Restructuring and Insolvency Practice

[email protected]

Credentials

University of Warwick

Bachelor of Laws (LL.B)

Admissions

Advocate & Solicitor (Singapore)

Advocate & Solicitor (Malaysia)

Barrister-At-Law (Middle Temple)

Solicitor, England and Wales

Professional Experience

Mei Yen’s main areas of practice include cross-border disputes, consensual and non-

consensual insolvency and restructuring, corporate fraud and investigations. She has acted

for and advised individuals, multi-national corporations, court-appointed administrators,

distressed and special situations funds and banks in Singapore and abroad. Prior to joining

Oon & Bazul, Mei Yen was a partner at one of the Big Four domestic law practices in

Singapore.

Professional Memberships

She is one of the founding members of the Singapore Network of the International Women’s

Insolvency and Restructuring Confederation (IWIRC) and is currently the Co-Chairperson of

the Singapore Network.


Particulars

Ng Wei Long

Associate

[email protected]

Credentials

Singapore Management University

LLB (Hons)

Admissions

Advocate & Solicitor (Singapore)

Professional Experience

Wei Long was called to the Singapore Bar in 2015. He presently practices in Oon & Bazul as

part of the Restructuring and Insolvency Practice Group. Prior to joining the Restructuring

and Insolvency Practice at Oon & Bazul LLP, Wei Long’s primary area of practice was in

litigation and dispute resolution with a focus on shipping and maritime matters.


Particulars

Shannen Tan

Trainee

[email protected]

Education

University of Exeter (2016)

Bachelor of Laws (LL.B), First Class Honours

Experience

Prior to joining Oon & Bazul LLP’s restructuring and insolvency practice, Shannen completed her first stint of training with the firm’s international trade and commercial litigation practice groups.

Shannen was also a Senior Officer’s Law Clerk at the State Courts of Singapore where she shadowed the District Court Judges of the Civil Justice Division during her days as an undergraduate.


This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE EAST\151263638.1

PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:

DLA Piper LLP (US) 2000 Avenue of the Stars, Suite 400 North Tower

Los Angeles, CA 90067-4704 A true and correct copy of the foregoing document entitled CHAPTER 7 TRUSTEE’S APPLICATION TO EMPLOY OON & BAZUL LLP AS SPECIAL COUNSEL, PURSUANT TO SECTIONS 327(a) AND 330 OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 2014 AND LOCAL BANKRUPTCY RULE 2014-1, NUNC PRO TUNC TO DECEMBER 6, 2017; DECLARATION OF TAN MEI YEN IN SUPPORT THEREOF will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below: 1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On February 9, 2018, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below: John-Patrick M. Fritz Zetta Jet USA, Inc. [email protected] John-Patrick M. Fritz Zetta Jet PTE Ltd. [email protected] Juliet Y. Oh Zetta Jet USA, Inc. [email protected] Ron Bender Zetta Jet PTE Ltd. [email protected] Ron Bender Zetta Jet USA, Inc. [email protected] Jeanne M. Jorgensen Universal Weather & Aviation [email protected] Jeanne M. Jorgensen Universal Fuels, Inc. [email protected] Dawn M. Coulson Scout Aviation II, LLC [email protected] William W. Huckins Ample United Limited [email protected] Michael S. Greger Ample United Limited [email protected] Matthew S. Walker Bombardier Aerospace [email protected] Alan I. Nahmias NEF Request [email protected] Mary H. Rose NEF Request [email protected] Michael D. Breslauer Big Fly LLC [email protected] Stephen F. Biegenzahn NEF Request [email protected] David W. Meadows NEF Request [email protected] Andrew Troop Bombardier Aerospace [email protected] Dare Law U.S. Trustee [email protected] Michael L. Bernstein Li Entities [email protected] Charles A. Malloy Li Entities [email protected] Lisa Hill Fenning Li Entities [email protected] Tiffany M. Ikeda Li Entities [email protected] Michael B. Lubic New Target Investments [email protected] Victor A. Vilaplana ARINC Direct, LLC [email protected] Jeffrey N. Pomerantz Creditor Committee [email protected] Debra I. Grassgreen Creditor Committee [email protected] John W. Lucas Creditor Committee [email protected] Paul Laurin Rolls-Royce Deutschland [email protected] Michael K. McCrory Rolls-Royce Deutschland [email protected] Jonathan Sundheimer Rolls-Royce Deutschland [email protected] Michael A. Sweet Associated Energy Group [email protected] Rebecca J. Winthrop CAE SimuFlite, Inc. [email protected] Scott M. Ewing Rust Consulting/Omni Bankruptcy [email protected]; [email protected] Nolan Thomas New Target Investments Limited [email protected]




� Service information continued on attached page 2. SERVED BY UNITED STATES MAIL: On February 9, 2018, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed. � Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on February 9, 2018, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. VIA HAND DELIVERY Honorable Sandra R. Klein United States Bankruptcy Court for the Central District of California 255 East Temple Street, Suite 1582 Los Angeles, California 90012 Ron Maroko Office of the United States Trustee 915 Wilshire Boulevard, Suite 1850 Los Angeles, CA 90017 VIA ELECTRONIC MAIL (Party, who is being served if different, and email address for each) � Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. February 9, 2018 Stephanie Lisko /s/ Stephanie Lisko Date Printed Name Signature




TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF) (Continued):

Matthew A. Lesnick NEF Request [email protected] Daniel H. Slate NEF Request [email protected] Douglas A. Plazak NEF Request [email protected] Ron Maroko US Trustee [email protected] Kimberly S. Winick Chelsea Jets [email protected] Robert Labate AVIC International Leasing Co. Ltd. [email protected] Alan Watson AVIC International Leasing Co. Ltd. [email protected] Michael McCollum New Jubilee Global Limited [email protected]

20 Largest Creditors Served via Electronic Mail

Bombardier Aerospace Corporation

c/o Matthew S. Walker Email: [email protected]

c/o Andrew Troop Email: [email protected]

Rolls-Royce Deutschland Ltd & Co KG

c/o Paul Laurin Email: [email protected]

c/o Michael K. McCrory Email: [email protected]

c/o Jonathan Sundheimer Email: [email protected]

World Fuel Services (Singapore) Pte. Ltd.

Attn.: Calvin Chia [email protected]

Universal Fuels, Inc. (UVAir)

c/o Jeanne M. Jorgensen Email: [email protected]

Rainbow Aviation Limited

Attn.: Benedict Tan [email protected]

CAE Simuflite, Inc.

c/o Rebecca J. Winthrop Email: [email protected]

Hongkong & Shanghai Banking Corp Ltd

c/o Jennifer W. Crastz [email protected]

Scout Aviation II, LLC

c/o Dawn M. Coulson Email: [email protected]

Universal Weather & Aviation Inc. (UWA)


Festin Management

c/o James Torrey at Jimmy Jets Email: [email protected]

Hanergy [Yoda Aviation]

Attn.: John Zhang Email: [email protected]

Corporate Jet Support

Attn.: Whitne Keenan Email: [email protected]




Eurocontrol

Attn.: Nancy Coveliers Email: [email protected] [email protected]

Associated Energy Group, LLC (AEG Fuel)

Attn.: Christopher Clementi Email: [email protected]

c/o Michael A. Sweet Email: [email protected]

c/o Jack Praetzellis Email: [email protected]

Tongda Air Service

Attn.: Fuhua Mansion [email protected]

Wex Bank

Attn.: Kiran Patel [email protected]

Jeppesen Sanderson, Inc.

Attn.: Doris Fuller [email protected]

UVAir European Fuelling Services Ltd


ARINC Direct

c/o Victor A. Vilaplana Email: [email protected]

c/o Erika L. Morabito Email: [email protected]

c/o Brittany J. Nelson Email: [email protected]

SN 1360, LLC

c/o James Torrey at Jimmy Jets Email: [email protected]

Aircraft Finance and Aircraft Lease Parties by Electronic Mail

Angus Marine Ventures, Ltd.

c/o Stephen G. Larson Email: [email protected]

Jet Support Services (JSSI)

c/o Richard Schumacher Email: [email protected]

AVIC International Leasing Co., Ltd.

Attn.: Wayne Wong Email: [email protected]

c/o Robert J. Labate Email: [email protected]

c/o Alan J. Watson Email: [email protected]

New Target Investments Limited

c/o Michael Lubic Email: [email protected]




Big Fly LLC

c/o Michael D. Breslauer Email: [email protected]

Tony Robbins

c/o Alan I. Nahmias Email: [email protected]

c/o Stephen F. Biegenzahn Email: [email protected]

TVPX ARS, Inc.

Attn.: David Wall Email: [email protected]

Attorneys for Ample United Limited

c/o William W. Huckins [email protected]

c/o Michael S. Greger [email protected]

Attorney for Jet Aviation

c/o Sarah R. Borders [email protected]

SN 1360, LLC and SN 1372, LLC

Attn.: James Torrey at Jimmy Jets Email: [email protected]

Attorney for Scout Aviation II, LLC

c/o Dawn M. Coulson Email: [email protected]

Attorney for Bombardier Aerospace

c/o Matthew S. Walker Email: [email protected]

c/o Andrew Troop Email: [email protected]

Element Financial Corp.

Attn.: Michael O’Keefe Email: [email protected]

PTJ Associates LLC

Attn.: Stephen Hofer Email: [email protected]

Attorneys for Yuntian 3 Leasing Company Limited and Yuntian 4 Leasing Company Limited

Philip S. Warden Email: [email protected]

M. David Minnick Email: [email protected]

ECN Aviation Inc. (f/k/a Element Aviation)

Attn.: Michael O’Keefe Email: [email protected]




Other Requests for Service by Electronic Mail

Attorneys for the Debtors

c/o John-Patrick M. Fritz Email: [email protected]

c/o Juliet Y. Oh Email: [email protected]

c/o Ron Bender Email: [email protected]

Attorney for the Li Entities

c/o Michael L. Bernstein Email: [email protected]

c/o Charles A. Malloy Email: [email protected]

c/o Lisa Hill Fenning Email: [email protected]

c/o Tiffany M. Ikeda Email: [email protected]

United States Trustee

Attn.: Dare Law Email: [email protected]

Attn.: Ron Maroko Email: [email protected]

Attorney for Universal Weather & Aviation and Universal Fuels, Inc.


Attorney for Rolls-Royce Deutschland

c/o Paul Laurin Email: [email protected]

c/o Michael K. McCrory Email: [email protected]

c/o Jonathan Sundheimer Email: [email protected]

Attorneys for ARINC Direct, LLC

c/o Victor A. Vilaplana Email: [email protected]

c/o Erika L. Morabito Email: [email protected]

c/o Brittany J. Nelson Email: [email protected]

Advanced Air Management, Inc.

Attn.: James Seagrim Email: [email protected]

Attorney for CAE Simuflite, Inc.

c/o Rebecca J. Winthrop Email: [email protected]

Attorney for Hongkong & Shanghai Banking Corp Ltd.

c/o Jennifer W. Crastz [email protected]

Bank of Utah, Owner / Trustee

Attn.: Colleen Schulthies Email: [email protected]

Export Development Canada

Attn.: Jeff Blattman Email: [email protected]

WEX Bank

Attn.: Kiran Patel [email protected]




Hanergy (Yoda Aviation)

Attn.: John Zhang Email: [email protected]

Jeppesen Sanderson, Inc.

Attn.: Doris Fuller [email protected]

Corporate Jet Support

Attn.: Whitne Keenan Email: [email protected]

Attorney for New Jubilee Global Limited

c/o Michael B. McCollum Email: [email protected]


Date post:	27-Mar-2018
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