*1 BRANDON HEITMANN, Case No. 24-41956-MAR
/ EXHIBIT
PROPOSED ORDER AUTHORIZING EMPLOYMENT OF KOTZ
SANGSTER AS SPECIAL COUNSEL
Respectfully submitted:
/s/ Robert N. Bassel_______
Robert N. Bassel (P48420)
Attorney for Debtor
PO Box T
Clinton, MI 49236
248.677.1234/bbassel@gmail.com
PROPOSED ORDER
Case No. 24-41956 Brandon Heitmann,
___________________________________/
ORDER GRANTING FURTHER APPLICATION OF THE DEBTOR TO EMPLOY KOTZ SANGSTER WYSOCKI, P.C. AS
SPECIAL COUNSEL
Upon the Application Of The Debtor to Employ Special Counsel, the waiver of claims by Amanda Pisarski, Debtor’s spouse, the Amended Declaration by Tyler Phillips, and the Stipulation in Support of Entry of this Proposed Order by Kotz Sangster, Brandon Heitmann, Amanda Pisarski, Debtor’s spouse, and Ann Heitmann, Debtor’s mother and the guarantor (“Guarantor”) under the engagement agreements between Debtor, Amanda Pisarski and Kotz Sangster, it appearing that KOTZ SANGSTER WYSOCKI, P.C. does not represent or hold any interest adverse to the debtor or to the estate with respect to the matter on which such attorney is to be employed, and has no *3 interest adverse to the estate and sufficient cause exists to grant the application,
NOW, THEREFORE, IT IS HEREBY ORDERED that the Application is granted subject to the requirements in the Application, and subject to the following:
During the pendency of the chapter 13 bankruptcy case, Guarantor shall pay all legal fees and expenses of Kotz Sangster, and neither Debtor nor his spouse nor her company, Resilient Outdoor Living, shall pay those legal fees and expenses, and Guarantor shall not seek reimbursement or contribution from the bankruptcy estate or from the debtor or debtor’s spouse or her company, Resilient Outdoor Living.