Case 15-10054-CSS
Doc 91
Filed 02/09/15
Page 1 of 2
`■ HANSON BRIDGETT LLP MOHAMMAD WALIZADEH, SBN 233390 2 425 Market Street, 26th Floor San Francisco, California 94105 3 Telephone: (415) 777-3200 Facsimile: (415) 541-9366 4
[email protected] 5
UNITED STATES BANKRUPTCY COURT
6
FOR THE DISTRICT OF DELAWARE
7 8 9 10
In re
Chapter 11
SUNTECH AMERICA, INC., et al.,
Case No. 15-10054 (CSS)
Debtors.
11
I Re: Docket No.883
12 13 ~L!
i[:~ 17 18 19 20 21 22 23 24 25 26 27 28
DECLARATION OF DISINTERESTEDNESS OF HANSON BRIDGETT LLP IN SUPPORT OF RETENTION AS AN ORDINARY COURSE PROFESSIONAL I, Mohammad Walizadeh, being duly sworn, state the following under penalty of perjury: 1.
I am a partner of Hanson Bridgett LLP (the "Firm"), which has a place of
business at 425 Market Street, 26t" Floor, San Francisco, CA 94105. 2.
The above-captioned debtor, Suntech America, Inc. (the "Debtor") has
requested that the Firm provide the following legal services to the Debtor: (a) legal representation and potential mediation in pursuit of amounts owed to Debtor under an EPC Agreement with Sempra; and (b) legal representation of Debtor pertaining to 0E-34 Solar Tile claims, which are the subject of several lawsuits and a class action litigation. The Firm has consented to provide such services. 3.
The Firm may have performed services in the past, may currently perform
services, and may perform services in the future in matters unrelated to these Chapter 11 Cases for persons that are parties in interest in these Chapter 11 Cases. The Firm does not perform services for any such person in connection with these Chapter 11 Cases or
10836380.3
Case 15-10054-CSS
1
Doc 91
Filed 02/09/15
Page 2 of 2
have any relationship with any such person, their attorneys or accountants that would be
2 ~ adverse to Suntech America and Suntech Arizona, Inc. (collectively, the "Debtors") or 3 their estates. 4
4.
As part of its customary practice, the Firm is retained in cases, proceedings,
5 ~ and transactions involving many different parties, some of whom may represent or be 6 ~ retained by the Debtors, claimants and parties in interest in these Chapter 11 Cases. 7
5.
Neither i nor any principal, partner, director, or officer of or professional
8 ~ retained by, the Firm has agreed to share or will share any portion of the compensation to 9 be received from the Debtors with any other person other than the principal and regular 10 .employees of the Firm. 11
6.
Neither I nor any principal, partner, director, or officer of, or professional
12 retained by the Firm, insofar as I have been able to ascertain, holds or represents any 13 interest adverse to the Debtors or their estates with respect to the matters) upon which 14 this Firm is to be retained. 15
7.
The Debtor owes the Firm $2,432.00 for prepetition services, the payment
16 ~ of which is subject to limitations contained in the Bankruptcy Code. The Firm 17 understands that its designation as an OCP does not entitle the Firm to payment for 18 services provided during the prepetition period outside of a confirmed plan. 19
8.
The Firm is conducting further inquiries regarding its retention by any
20 ~ creditors of the Debtors, and upon conclusion of that inquiry, or at any time during the 21
period of its retention, if the Firm should discover any facts bearing on the matters
22 described herein, the Firm will supplement the information contained in this Declaration. 23
9.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the
24 foregoing is true and correct to the best of my knowledge and belief. Executed on 25 February 4, 2015 26 27
--Mohammad Walizad h Hanson Bridgett LLP
28
10836380.32.