1 United States Bankruptcy Court Southern District Of
Hearing Date and Time: August 18, 2009 at 9:45 a.m. (Eastern Time) Objection Deadline: August 13, 2009 at 4:00 p.m. (Eastern Time) UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------- X : In re: : Chapter 11 Case No.: : MOTORS LIQUIDATION COMPANY, et al. : 09-50026 (REG) f/k/a General Motors Corp., et al. : : Debtors. : (Jointly Administered) ---------------------------------------------------------- X APPLICATION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ENTRY OF ORDER AUTHORIZING THE RETENTION AND EMPLOYMENT OF FTI CONSULTING, INC., AS ITS FINANCIAL ADVISOR, NUNC PRO TUNC TO JUNE 3, 2009 The Official Committee of Unsecured Creditors (the “Committee”) appointed in the Chapter 11 cases of General Motors Corporation, debtors and debtors-in-possession herein (the “Debtors”), submits this application (the “Application”) for entry of an order, pursuant to sections 328, 1103(a) and 1103(b) of the United States Bankruptcy Code, 11 U.S.C. §§ 101- 1532, as amended (the “Bankruptcy Code”), Rules 2014(a) and 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Rule 2014-1 of the Local Bankruptcy Rules for the Southern District of New York (the “Local Bankruptcy Rules”), authorizing the retention and employment of FTI Consulting, Inc. (together with its wholly owned subsidiaries, agents, independent contractors and employees “FTI”), as financial advisor to the Committee nunc pro tunc to June 3, 2009. In support of this Application, the Committee relies upon the declaration of Michael Eisenband (the “Eisenband Declaration”), which is attached hereto as Exhibit A and incorporated herein by reference, and respectfully represents as follows: 1 KL2 2610869.4 JURISDICTION AND VENUE 1.
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