To: scion who wrote (11703 ) 11/15/2007 2:47:20 PM From: scion Read Replies (1) | Respond to of 12518 11/15/2007 307 Proposed Order submitted by Philip Hanrahan (RE: related document(s)281 Application for Administrative Expenses/Compensation, filed by Debtor Plasticon International, Inc., 285 Order on Application to Employ,, 175 Order on Application to Employ). (Hanrahan, Philip) (Entered: 11/15/2007) ----------------------- Doc 307 In re: Case No. 07-50934 Chapter 11 PLASTICON INTERNATIONAL, INC Debtor AGREED ORDER REGARDING FEE APPLICATION OF WYATT, TARRANT & COMBS, LLP Richard F. Clippard, United States Trustee, (“United States Trustee”) by counsel, and Wyatt, Tarrant & Combs, LLP (“WTC”), by counsel, being in agreement as evidenced by their signatures below regarding the (First and) Final Application of Wyatt, Tarrant & Combs, LLP, for Allowance of Professional Fees and Reimbursement of Expenses (the “Fee Application”), Document No. 281, the Court having reviewed the record and being otherwise sufficiently advised, it is hereby AGREED, ORDERED AND ADJUDGED AS FOLLOWS: 1. WTC hereby waives its claim to any fees in this case including but not limited to the request for fees set forth in the Fee Application. 2. The United States Trustee agrees not to object to WTC’s request for reimbursement of expenses as set forth in the Fee Application in the amount of $3,463.54. 3. In the event any other party files an objection to the Fee Application, this Agreed Order shall be null and void and the United States Trustee shall have through and including December 4, 2008 to file an Objection to the Fee Application. 4. Pursuant to the Court’s Order dated August 27, 2007, (Document No. 175) (the “WD Employment Order”), after paying itself the $3,463.54 set forth above and after paying itself the amount set forth in the Fee Application Agreed Order in the Pro Mold Chapter 11 case (Case No. 07-50935 currently pending before this Court), WTC shall pay the remaining balance of the funds WTC is currently holding as a retainer in this case to the law firm of Wise Delcotto (“WD”) as set forth in the WD Employment Order. WD shall hold all such amounts in escrow pending the entry of further Orders of this Court determining the matters more particularly described in the WD Employment Order and the Order as to Security Retainer dated October 31, 2007 (the “Security Order”), the terms of both of which are incorporated herein by reference. Nothing in this Agreed Order shall be deemed as determining the issues set forth in the WD Employment Order and/or the Security Order. 5. Pursuant to Bankruptcy Rule 7054, this is a final and appealable Order. There is no just reason for delay and the Clerk is directed to enter this Order. 6. The United States Trustee shall serve a copy of this Agreed Order on the parties set forth below. Service as set forth constitutes adequate and sufficient notice in light of the relief granted. HAVE SEEN AND AGREED TO: Richard F. Clippard United States Trustee By Counsel /s/ Philip L. Hanrahan Philip L. Hanrahan Trial Attorney 100 East Vine St., Suite 500 Lexington, KY 40507 (859) 233-2822 /s/ Robert J. Brown, by PLH per authorization Robert J. Brown Wyatt, Tarrant & Combs, LLP 250 West Main Street, Suite 1600 Lexington, KY 40507-1746 (859) 233-2012 On behalf of WTC Pursuant to Local Rule 9022-1(c), The U.S. Trustee shall cause a copy of this Order to be served on each of the parties designated to receive this Order pursuant to Local Rule 9022-1(a) and shall file with the court a certificate of service of the Order upon such parties within ten (10) days hereof. Copies to: Philip L. Hanrahan (To Serve) Trial Attorney Office of the United States Attorney 100 E. Vine St., Suite 500 Lexington, KY 40507 And on those parties who receive electronic notice in this case