Hearing Date: TBD, if necessary.

Objection Deadline: May 12, 2011 at 4:00 p.m. (Prevailing Eastern Time)
1712916 v1/NY
COOLEY LLP
1114 Avenue of the Americas
New York, New York 10036
Telephone: (212) 479-6000
Facsimile: (212) 479-6275
James A. Beldner
Lawrence C. Gottlieb
Lesley A. Kroupa
Attorneys for Debtor and Debtor-in-Possession

UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
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In re

LEHR CONSTRUCTION CORP.,

Debtor.
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:
:
:
:
:


Chapter 11


Case No. 11-10723 (SHL)

Re: Docket No. 98

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NOTICE OF SUPPLEMENT TO LIST OF ORDINARY COURSE PROFESSIONALS

PLEASE TAKE NOTICE that, in accordance with the procedures set forth in the Order
Pursuant to Sections 105(a), 327, 328, and 330 of the Bankruptcy Code Authorizing the Debtor
to Employ Professionals Utilized in the Ordinary Course of Business Nunc Pro Tunc to the
Petition Date (Docket No. 98) (the OCP Order)
1
, Lehr Construction Corp., as debtor and
debtor-in-possession (the Debtor)
2
, hereby files the attached supplement to Exhibit A to the
OCP Order for purposes of retaining the Additional Ordinary Course Professional listed therein.
PLEASE TAKE FURTHER NOTICE that the attached supplement also includes the
Ordinary Course Professional Affidavit and Retention Questionnaire for the Additional Ordinary
Course Professional. Pursuant to the terms of the OCP Order, objections to the retention of the

1
All capitalized terms used but not otherwise defined herein shall have the meanings ascribed to
such terms in the OCP Order.
2
The last four digits of the Debtors federal tax identification number are 3507. The Debtors
mailing address is 902 Broadway, New York, NY 10010.
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Additional Ordinary Course Professional must be filed and served on the Debtor within fifteen
(15) days after service of the Supplemental Notice of Ordinary Course Professionals (the
Objection Deadline). If no objections are received by the Objection Deadline, the
retention of the Additional Ordinary Course Professional will be deemed approved by the
OCP Order, without the need for a hearing or further order of the Court.

Dated: April 27, 2011
New York, New York
Respectfully submitted,

By: /s/ James A. Beldner
James A. Beldner

COOLEY LLP
1114 Avenue of the Americas
New York, New York 10036
Telephone: (212) 479-6000
Facsimile: (212) 479-6275
James A. Beldner (JB 7166)
Lawrence C. Gottlieb (LG 2565)
Lesley A. Kroupa (LK 2620)

Attorneys for Debtor and Debtor in Possession


1712916 v1/NY
Exhibit A

List of Additional Ordinary Course Professionals



Name: Goetz Group, PC

Address: 529 West 42
nd
St., New York, NY 10036

Services Provided to Debtor: General legal services regarding construction law issues in New
York, including limited litigations and matters related to mechanics liens.
UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------- ][
In re
Chapter
I
Case No.ll-10723 (SHL)
= I .
Debtor.
LEHR CONSTRUCTION CORP.,
---------------------------------------------------------------- j
DECLARATION AND DISCLOSURE STATEMENT F JANE GOETZ,
ON BEHALF OF GOETZ GROUP,
JANE GOETZ, an attorney duly authorized to practlce law in the State of New
I
York, pursuant to 28 U.S. C 1 7 46, declares under the penalty of perjry that the foregoing is true
and correct. l
1. I am the principal of Goetz Group, PC, loca ed at 529 West 42"d Street,
New York, NY 10036 (the "Firm").
2. Lehr Construction Corp., as debtor and I debtor in possession (the
"Debtor"),
1
has requested that the Firm provide limited legal to the Debtor, and the Firm
has consented to provide such services.
3. The Firm may have performed services in the past and may perform
services in the future, in matters unrelated to this chapter 11 case, persons that are parties in
I
interest in the Debtor's chapter 11 case. As part of its customary prttice, the Firm is retained in
cases, proceedings, and transactions involving many different p ies, some of whom may
represent or be claimants or employees of the Debtor, or other partles in interest in this chapter
11 case. The Firm does not perform services for any such person inl connection with this chapter
' The last fmu digits of the Debtor'' fudern! tax identifioation number are 3507. Je Debtor'' mailing addre" i' 902
Broadway, New York, NY 10010.
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I
II case. In addition, the Firm does not have any relationship ~ t h any such person, their
attorneys, or accountants that would be adverse to the Debtor or its ettate.
4. Neither I, nor any principal of, or profession,! employed by the Firm has
agreed to share or will share any portion of the compensation to , e received from the Debtor
with any other person other than the principals and regular employeef of the Firm.
5. Neither I, nor any principal of, or professiJnal employed by the Firm,
I
insofar as I have been able to ascertain, holds or represents any intetest adverse to the Debtor or
its estate.
6. The Firm has not and does not represent any siders of the Debtor as such
term is defined in section 101 of chapter 11 of title 11 of the United tates Code.
7. The Firm has no prepetition claims against thj Debtor.
8. At any time during the period of its empllyment, if the Finn should
discover any facts bearing on the matters described herein, t h ~ Finn will supplement the
information contained in this Affidavit.
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1715618 v1/NY
LEHR CONSTRUCTION CORP.
Chapter 11 Case No. 11-10723 (SHL) I
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RETENTION QUESTIONNAIREY
TO BE COMPLETED BY PROFESSIONALS EMPLOYED B I LEHR CONSTRUCTION
CORP., AS DEBTOR AND DEBTOR IN POSSESSION (THE "DEBTOR").
1
I
DO NOT FILE THIS QUESTIONNAIRE WITH THE COURT.
RETURN IT FOR FILING BY THE DEBTOR, TO:
Cooley LLP
1114 A venue of the Americas
New York, New York 10036
Attn: Lesley A. Kroupa, Esq.
lkroupa@cooley.com
All questions must be answered. Please use "none," "not applicable,!' or "N/A," as appropriate.
If more space is needed, please complete on a separate page and attadh.
I. Name and address of firm:
2.
3.
Goetz Group, PC
529 West 42nd Street
I
New York, NY 10036
Date of retention: Approximately July 7, 2009 I
Type of services provided: General legal services reglrding construction
law issues in New York including limited litigations and matters
related to mechanic's liens.
4. Brief description of services to be provided:
To close out a pending litigation known as Lehr Constru tion Corp. v. Seniorbridge
Family Companies, Inc. filed in the Civil Court of of New York (Index
Number 054755/10). The Debtor's cause of action in or breach of contract in
connection with construction services rendered for th fit-out of SeniorBridge's
office located in New York, NY. The total amount of the Debtor's claim against
Seniorbridge is $19,965.00. Immediately prior to the Del)tor's chapter 11 filing, the
Debtor and Seniorbridge had reached an understanding this matter would
be settled. The Debtor agreed to perform minor punch list items at SeniorBridge's
office and upon completion of said punch list by Debtor, Seniorbridge agreed to pay
1
The last four digHs of the Debtor's federal tax identification number are
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1 I
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I
!
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Debtor approximately $19,000.00 and upon Debtor's receipt of payment,
will be discontinued with prejudice. I
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the action
5. Arrangements for compensation (hourly, contingent, etc.)
(a) Average hourly rate (if applicable): $250.00 I
(b) Estimated average monthly compensation baked on prepetition retention
(if firm was employed prepetition): I
6.
7.
8.
9.
10.
Less than $5,000.00 including reimbursement for rxpenses.
Prepetition claims against the Debtor held by the firm: None I
Prepetition claims against the Debtor held individually by any member, associate, or
professional employee ofthe firm: None
Stock of the Debtor currently held by the firm: None.
Stock of the Debtor currently held individually by any m e m ~ e r , associate, or professional
employee of the firm: None I
Disclose the nature and provide a brief description of any i4terest adverse to the Debtor
or to its estate with respect to the matters on which the 1above-named firm is to be
employed. Not Applicable. l
Name:
Title:
Date:
2
1715618 v1/NY