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KLESTADT & WINTERS, LLP Tracy Klestadt, Esq. Sean Southard, Esq. Fred Stevens, Esq.

570 Seventh Avenue, 17th floor New York, New York 10018 (212) 972-3000 (Telephone) (212) 972-2245 (Facsimile)

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

In re: Lehr Construction Corp.

Case No. 11-10723 (SHL) Chapter 11

APPLICATION FOR ORDER PURSUANT TO 11 U.S.C. 1103 AND FED. R. BANKR. P. 2014(a) AUTHORIZING THE RETENTION OF J.H. COHN LLP AS FINANCIAL ADVISORS AND FORENSIC ACCOUNTANTS TO THE COMMITTEE OF UNSECURED CREDITORS The Committee of Unsecured Creditors (the Committee) of Lehr Construction Corp. (Debtor), submits this application (the Application) for the entry of an Order pursuant to 11 U.S.C. 1103 and Federal Rule of Bankruptcy Procedure 2014(a) (the Bankruptcy Rules) authorizing the retention of J.H. Cohn LLP (JHC) as financial advisors and forensic accountants to the Committee, effective as of March 15, 2011. In support of this Application, the Committee respectfully represents as follows: JURISDICTION 1. This Court has jurisdiction over this Application pursuant to 28 U.S.C. 157 and

1334. This is a core proceeding pursuant to 28 U.S.C. 157(b)(2)(A). Venue of this proceeding and the within Application in this District is proper pursuant to 28 U.S.C. 1408 and 1409(a). The statutory predicates for the relief requested herein are 328 and 1103(a) of the Bankruptcy Code, as complemented by Bankruptcy Rule 2014.

BACKGROUND 2. On February 21, 2011 (the Petition Date), the Debtor filed with the United States

Bankruptcy Court for the Southern District of New York (the Court) a voluntary petition for relief under Chapter 11 of Title 11 of the United States Code, 11 U.S.C. 101-1532 (as amended, the Bankruptcy Code), commencing the above-captioned Chapter 11 case. The Debtor continues to operate its business and manage its properties as a debtor-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. 3. 4. No trustee or examiner has been appointed in the Debtors bankruptcy case. On March 11, 2011, the Office of the United States Trustee appointed the Committee

pursuant to 11 U.S.C. 1102. The Committee selected Klestadt & Winters, LLP to serve as its counsel. On March 15, 2011, the Committee selected JHC to serve as its financial advisors and forensic accountants. RELIEF REQUESTED 5. By this Application, the Committee seeks entry of an Order pursuant to section 1103

of the Bankruptcy Code authorizing the Committee to retain JHC as its financial advisors and forensic accountants in these chapter 11 cases, effective as of March 15, 2011. The Committee requests that such order be substantially in the form annexed hereto as Exhibit A. 6. JHC is a financial advisory/consulting firm which maintains offices at 1212 Avenue

of the Americas, New York, New York 10036 and 333 Thornall Street, 6th Floor, Edison, New Jersey. JHCs professionals have extensive experience working with financially troubled companies in complex chapter 11 cases. Their professionals have advised debtors, creditors, equity constituencies, purchasers, and government agencies in more than two hundred (200) bankruptcies. JHC has an excellent reputation for services it has rendered in chapter 11 cases on behalf of debtors, creditors and creditors committees. 7. The Committee has determined that it is in the best interests of all creditors and the

estate to retain financial advisors to assist the Committee in this chapter 11 case. The Committee desires to retain JHC to provide such financial professional services as JHC and the Committee deem 2

necessary and beneficial to the Committee and all unsecured creditors. The services that the Committee may request include, but are not limited to, the following: a) Analyze and review key motions to identify strategic case issues. b) Gain an understanding of Debtors corporate structure and related parties. c) Perform a preliminary assessment of the Debtors financial condition. d) Establish reporting procedures that will allow for the monitoring of the Debtors post-petition operations. e) Evaluate alternative strategies. f) Prepare a preliminary dividend analysis to determine potential return to unsecured creditors. g) Perform an assessment of the Debtors wind down plan. h) Ascertain net cash flow available from completion of contracts. i) Scrutinize proposed transactions, including the assumption and/or rejection of executory contracts. j) Identify, analyze and investigate transactions with non-debtor entities and other related parties. k) Monitor Debtors weekly operating results. l) Analyze Debtors budget to actual results on an ongoing basis for reasonableness and cost control. m) Communicate findings to the Committee. n) Perform forensic accounting procedures, as directed by the Committee. o) Assist the Committee in negotiating the key terms of a Plan of Liquidation. p) Review the nature and origin of other significant claims asserted against the Debtor. q) Prepare and update dividend analysis. r) Review and analyze proposed Plan of Liquidation and Disclosure Statement.

s) Render such assistance as the Creditors' Committee and its counsel may deem necessary. 8. It is essential that the Committee employ a financial advisor and forensic accountant

to render the foregoing professional services in order to assist the Committee with its duties and to handle the many issues that may arise in the context of this case. The Committee believes that JHC is qualified to serve it in this chapter 11 case and that the retention of JHC is in the best interests of the creditors and the estate. Because of the number of emergent matters pending with the Court in this case, JHC was requested to immediately begin many of the tasks outlined in paragraph 7 above. The services to be rendered by JHC will not duplicate the services to be rendered by any other professionals retained by the Committee in this bankruptcy case, and every effort will be made to ensure that JHCs services are rendered in the most cost-effective manner possible. 9. JHCs proposed compensation is set forth in the accompanying Certification of

Howard L. Konicov (the Konicov Certification), annexed hereto as Exhibit B. In summary, the Debtors estate shall reimburse JHC for its hourly professional charges and disbursements. The Committee and JHC understand that any compensation or reimbursement of expenses paid to JHC must be approved by this Court upon application consistent with the Bankruptcy Code and applicable Bankruptcy Rules. 10. 11. JHC is not owed any amounts with respect to pre-petition fees and expenses. No agreement or understanding in any form exists to share any compensation

received by JHC for its services to the Committee with any other person or firm, other than as permitted by the Bankruptcy Code. 12. To the best of the Committees knowledge and subject to the Konicov Certification,

JHC represents no other entity in connection with this case, is a disinterested person as that term is defined in section 101(14) of the Bankruptcy Code, and does not hold or represent any interest adverse to the Debtors estate with respect to the matters upon which it is to be employed.

NOTICE AND PRIOR APPLICATIONS 13. Notice of this Application has been given to (i) the Office of the United States

Trustee, (ii) counsel to the Debtor, and (iii) all parties who have filed a notice of appearance pursuant to Bankruptcy Rule 2002. The Committee respectfully submits that no further notice of the relief requested herein is necessary. 14. Court. 15. Because this Application presents no novel issues of law and the authorities relied No prior Application for the relief requested herein has been made to this or any other

upon by the Committee are set forth herein, the Committee respectfully requests that the Court waive the requirement for the filing of a separate memorandum of law in support of this Application pursuant to Local Rule 9013-1(b), but the Committee reserves the right to file a brief in reply to any objection to this Application.

WHEREFORE, the Committee respectfully requests that this Court enter an Order (i) authorizing the retention of J.H. Cohn LLP as its financial advisors and forensic accountants, effective as of March 15, 2011 on the terms and conditions set forth herein, with fees and expenses to be paid pursuant to the Bankruptcy Rules, the Local Rules of this Court, and such other orders as the Court may direct, and (ii) for such other and further relief as the Court deems necessary and just. THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS OF LEHR CONSTRUCTION CORP. By: ____/s/David Samuels, Chairperson________ By: ____________________________________ By: ____________________________________ Dated: March 24, 2011

KLESTADT & WINTERS, LLP Tracy Klestadt, Esq. Sean Southard, Esq. Fred Stevens, Esq. 570 Seventh Avenue, 17th floor New York, New York 10018 (212) 972-3000 (Telephone) (212) 972-2245 (Facsimile)

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

In re: Lehr Construction Corp.

Case No. 11-10723 (SHL) Chapter 11

CERTIFICATION OF HOWARD L. KONICOV IN SUPPORT OF APPLICATION FOR AN ORDER PURSUANT TO 11 U.S.C. 1103 AUTHORIZING THE RETENTION OF J.H. COHN LLP AS FINANCIAL ADVISORS AND FORENSIC ACCOUNTANTS TO THE COMMITTEE OF UNSECURED CREDITORS

Howard L. Konicov hereby certifies as follows: 1. I am a Certified Public Accountant, licensed under the laws of the State of New

York, and a member of the accounting and consulting firm of J.H.Cohn LLP (JHC or the Firm), maintaining offices at 333 Thornall Street, Edison, New Jersey 08837 and 1212 Avenue of the Americas, New York, New York 10036. 2. This Certification is submitted in support of the application (the Application) of

the Committee of Unsecured Creditors (the Committee) of the above-captioned debtor and debtor-in-possession (the Debtor) for entry of an Order authorizing and approving the employment and retention of JHC as forensic accountants and financial advisors to the Committee, effective as of March 15, 2011.

3.

JHC has conducted an extensive conflicts check of the parties named and identified

in Debtors petition, initial pleadings, their interest holders, a consolidated list of their top 40 unsecured creditors, Debtors secured creditor, its law firms and its vendors. 4. Insofar as I have been able to ascertain through diligent inquiry, except as set forth

below, neither I, JHC, nor any partner, principal or professional employee of JHC have any connection with the Debtor, its creditors, any other party-in-interest, their current attorneys or professionals, the United States Trustee or any person employed in the office of the United States Trustee, nor do we hold or represent any entity having an adverse interest in connection with the Debtors Chapter 11 cases, except as follows: a) From time to time, JHC has performed consulting and/ or forensic accounting services for Capital One Bank in matters unrelated to the Debtors chapter 11 case. b) JHC performs accounting and tax services for Consolidated Carpet Workroom, a creditor in the Debtors chapter 11 case. Fees for JHCs services in this matter represent less than one percent of JHCs revenues for the past fiscal year. c) JHC performs accounting, tax and consulting services for Burgess Steel LLC, a related entity to Burgess Steel Erectors NY, a creditor in the Debtors chapter 11 case. Fees for JHCs services in this matter represent less than one percent of JHCs revenues for the past fiscal year. d) JHC performs accounting and tax services for Patella Woodworking and related entities. Patella Woodworking is a creditor in the Debtors chapter 11 case. Fees for JHCs services in this matter represent less than one percent of JHCs revenues for the past fiscal year. e) JHC maintains bank accounts with Capital One Bank.

f) JHC has not provided services to creditors or other parties in interest which could impact their rights in the case, nor does JHCs involvement in the case compromise its ability to continue such various consulting services to such third parties. g) Due to the size and diversity of its practice, JHC and its partners and staff may have represented in the past, and may represent in the future, parties in interest in matters unrelated to this chapter 11 case, where the Debtor, creditors, or other parties in interest may have been or may be involved. 5. JHC has no relationship with attorneys and accountants representing creditors and

other parties in interest, other than normal professional relationships. 6. JHC has in the past worked with, continues to work with, and has mutual clients

with certain law firms who may represent parties-in-interest in the case. None of these engagements or relationships relate to this case. 7. No employee of JHC is related to any bankruptcy judge for the United States

Bankruptcy Court for the Southern District of New York, to any judge for the United States District Court for the Southern District of New York, or to the United States Trustee or the Assistant United States Trustee. 8. I hereby represent that no conflict of interest exists relating to JHCs role as

financial advisor and forensic accountants in this case. I shall amend this statement immediately upon my learning that any of the representations contained herein are incorrect or if there are any changes of circumstance relating to said representations. 9. Therefore, JHC is a disinterested person within the meaning 101(14) and 328

of the Bankruptcy Code. It has no business, professional or other connection with the Debtor herein or with its attorneys, and does not represent, nor will it represent, any interest adverse to the estate in the matters in which it is to be engaged. 3

10.

JHC has been asked to act as financial advisors and forensic accountants to the

Committee, which services consist of those detailed in the Application. 11. JHC will be rendering services on an hourly basis and will charge its customary

hourly rates, subject to this Courts approval in accordance with 330 of the Bankruptcy Code. The customary hourly rates for the partners and professionals most likely to render services in this matter are:

Partner Managers, Senior Managers, Directors Other Professional Staff Paraprofessionals

$580 - $790 $420 - $610 $260- $400 $180

JHC has agreed to provide a ten percent (10%) discount off its customary hourly rates above. In the normal course of business, the Firm revises its hourly rates on February 1 of each year. Expenses for actual costs incurred (including copying, telephone, travel, faxes, etc.) will be charged in accordance with the applicable Rules and Guidelines of this Court. 12. I am aware that the services rendered by JHC will be compensated only as

authorized by further order of this Court following the making of a proper application therefor pursuant to the applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the Local Bankruptcy Rules, the United States Trustees Guidelines For Fees and Disbursements issued by the United States Trustee, and such other procedures as may be fixed by order of this Court. 13. No agreement exists, nor will any be made, to share any compensation received by

JHC for the services it renders to the Committee with any other person or firm (except members of the Firm). 14. I have read the Application accompanying this Certification and, to the best of my

knowledge, information and belief, the contents of the Application are true and correct.

I hereby certify that the foregoing factual statements made by me are true under penalty of perjury. Dated: March 24, 2011

____/s/ Howard L. Konicov Howard L. Konicov

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

In re: Lehr Construction Corp.

Case No. 11-10723 (SHL) Chapter 11

ORDER AUTHORIZING THE RETENTION OF J.H. COHN LLP AS FINANCIAL ADVISORS AND FORENSIC ACCOUNTANTS TO THE COMMITTEE OF UNSECURED CREDITORS, EFFECTIVE AS OF MARCH 15, 2011 Upon consideration of the application (the Application) of the Committee of Unsecured Creditors (the Committee) of the above-captioned debtors and debtors-inpossession (the Debtor) for an order pursuant to 328 and 1103(a) of chapter 11 of title 11 of the United States Code (the Bankruptcy Code) and Rule 2014 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), authorizing them to retain J.H. Cohn LLP (JHC) to serve as financial advisors and forensic accountants to the Committee; and upon consideration of the Certification of Howard L. Konicov in support of the Application; and the Court being satisfied that JHC represents no adverse interest in the matter with respect to which it is to be employed; and notice of the Application being sufficient; and good cause appearing therefor; IT IS HEREBY: ORDERED, that the Application is approved to the extent provided herein; and it is further ORDERED, that notice of said Application is sufficient; and it is further ORDERED, that pursuant to 328 and 1103(a) of the Bankruptcy Code, the Committee is authorized to retain J.H. Cohn LLP, effective as of March 15, 2011, to serve as its financial advisors and forensic accountants in the above-captioned case; and it is further

ORDERED, that J.H. Cohn shall be compensated in accordance with and will file interim and final fee applications for allowance of its compensation and expenses and shall be subject to sections 330 and 331 of the Bankruptcy Code, the Bankruptcy Rules, the Local Rules, the Amended Order Establishing Procedures for Monthly Compensation and Reimbursement of Expenses of Professionals, dated November 25, 2009, the Amended Guidelines for Fees and Disbursements for Professionals in the Southern District of New York, dated November 25, 2009, and the United States Trustee Fee Guidelines, and the monthly compensation order, if any; and it is further ORDERED, that the requirement of Local Bankruptcy Rule 9013-1(b) that the Committee file a memorandum of law in support of the Application be, and hereby is, waived. ORDERED that this Court shall retain jurisdiction over any and all matters arising from or related to the interpretation or implementation of this Order. ORDERED, that ten business days notice must be provided by J.H. Cohn to the Debtor, the United States Trustee and any official committee prior to any increases in the rates set forth in the Application, and such notice must be filed with the Court. ORDERED, that J.H. Cohn is hereby authorized to keep reasonably detailed time records in half-hour increments and will submit, with any interim or final fee application, together with the time records, a narrative summary, by project category, of services rendered and will identify each professional rendering services, the category of services rendered and the amount of compensation requested.

ORDERED, that to the extent the Application is inconsistent with this Order, the terms of this Order shall govern. Dated: New York, New York March ___, 2011

___________________________________ United States Bankruptcy Judge

NO OBJECTION: /s/Susan Golden_________________ United States Trustee