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PACHULSKI STANG ZIEHL & JONES LLP 10100 Santa Monica, Boulevard, 11th Floor Los Angeles, California 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 James I. Stang, Esq. (admitted pro hac vice) -and780 Third Avenue, 36th Floor New York, New York 10017 Telephone: (212) 561-7700 Facsimile: (212) 561-7777 Ilan D. Scharf, Esq. Counsel for the Official Committee of Unsecured Creditors of The Christian Brothers Institute and Christian Brothers of Ireland, Inc. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 Case THE CHRISTIAN BROTHERS INSTITUTE, et al., Debtors. Case No. 11-22820 (RDD) (Jointly Administered)

NOTICE OF PRESENTMENT OF APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANKR. P. 2014 FOR ENTRY OF AN ORDER AUTHORIZING AND APPROVING THE EMPLOYMENT OF THE LAW OFFICES OF PAUL A. RICHLER AS SPECIAL INSURANCE COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS NUNC PRO TUNC TO OCTOBER 31, 2011

PLEASE TAKE NOTICE that the undersigned will present the annexed Application of the Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. P. 2014 for Entry of an Order Authorizing and Approving the Employment of the Law Offices of Paul A. Richler as Special Insurance Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to

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October 31, 2011 (the Application) to the Honorable Robert D. Drain, United States Bankruptcy Judge, for signature on December 8, 2011 at 12:00 p.m.

PLEASE TAKE FURTHER NOTICE that responses or objections, if any, to the Application must be in writing, must conform to the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules) and the Local Rules of the Bankruptcy Court for the Southern District of New York (the Bankruptcy Court), must set forth the name of the objecting party, the nature and amount of claims or interests held or asserted by the objecting party against the Debtors estate or property, the basis for the objection and the specific grounds therefor and must be filed with the Bankruptcy Court, no later than December 7, 2011 at 12:00 p.m., electronically in accordance with applicable rules and orders of the Bankruptcy Court, and any objection must further be served upon and actually received by the following parties (with a copy to Chambers) no later than December 7, 2011 at 12:00 p.m.: (a) Pachulski Stang Ziehl & Jones LLP 780 Third Avenue, 36th Floor, New York, NY 10017-2024 (Attn: Ilan D. Scharf, Esq.); (b) Paul A. Richler, Esq. 15332 Antioch Street, Ste. 305, Pacific Palisades, CA 90272; and (c) the Office of the United States Trustee for the Southern District of New York, Office of the United States Trustee, 33 Whitehall Street, 21st Floor New York, NY 10004 (Attn: Paul K. Schwartzberg, Esq.).

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PLEASE TAKE FURTHER NOTICE that, if no objections to the Application are timely filed, served and received in accordance with this Notice, the Bankruptcy Court may approve the Application without further notice or hearing.

Dated:

New York, New York November 21, 2011

PACHULSKI STANG ZIEHL & JONES LLP /s/ Ilan D. Scharf James I. Stang, Esq. 10100 Santa Monica Boulevard, 11th Floor Los Angeles, California 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 - and Ilan D. Scharf, Esq. 780 Third Avenue, 36th Floor New York, New York 10017 Telephone: (212) 561-7700 Facsimile: (212) 561-7777 Counsel for the Official Committee of Unsecured Creditors of The Christian Brothers Institute and Christian Brothers of Ireland, Inc.

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 Case THE CHRISTIAN BROTHERS INSTITUTE, et al., Debtors. Case No. 11-22820 (RDD) (Jointly Administered)

APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANKR. P. 2014 FOR ENTRY OF AN ORDER AUTHORIZING AND APPROVING THE EMPLOYMENT OF THE LAW OFFICES OF PAUL A. RICHLER AS SPECIAL INSURANCE COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS NUNC PRO TUNC TO OCTOBER 31, 2011 TO: THE HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE The Official Committee of Unsecured Creditors (the Committee) appointed in the above-captioned cases (the Bankruptcy Cases) hereby submits this Application of the Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. P. 2014 for Entry of an Order Authorizing and Approving the Employment of The Law Offices of Paul A. Richler as Special Insurance Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to October 31, 2011 (the Application). In support of this Application, the Committee relies on the Declaration of Paul A. Richler (the Richler Declaration) attached hereto as Exhibit A and respectfully represents as follows:

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I. 1.

JURISDICTION

The Court has jurisdiction over this Application pursuant to 28

U.S.C. 157 and 1334. This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). Venue of this proceeding and this Application is proper in this District pursuant to 28 U.S.C. 1408 and 1409. 2. The statutory bases for the relief requested herein are sections 328,

504, 1102, and 1103 of title 11 of the United States Code (the Bankruptcy Code), and Rules 2014 and 2016 of the Federal Rule of Bankruptcy Procedure (the Bankruptcy Rules). II. 3. BACKGROUND

On April 28, 2011, the Christian Brothers Institute and Christian

Brothers of Ireland, Inc. (collectively, the Debtors) filed voluntary petitions for relief under chapter 11 of the Bankruptcy Code. 4. The Debtors have continued in the possession of their property and

have continued to operate and manage their business as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these Bankruptcy Cases. 5. On May 11, 2011, (the Committee Formation Date), the Office

of the United States Trustee (the U.S. Trustee) appointed the Committee pursuant to section 1102 of the Bankruptcy Code.

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6.

The Committee retained Pachulski Stang Ziehl & Jones LLP

(PSZJ) as counsel to represent the Committee in all matters during the pendency of the Bankruptcy Cases. The Court has approved the Committees retention of PSZJ. 7. The purpose of this Bankruptcy Cases is to address the Debtors

liabilities for abuse perpetrated by Christian Brothers or others for whom the Debtors are responsible. 8. The status of insurance coverage for the Debtors is a subject of

dispute. See, Corporation of the Catholic Archbishop of Seattle v. Congregation of Christian Brothers of Ireland (Bankr. S.D.NY, Adv. Pro. No. 11-08332-rdd) (the Archdiocese Coverage Action). In addition, the Committee has informed the Debtors of the existence of unscheduled liability insurance policies, and the Debtors testimony at the Section 341(a) hearing casts uncertainty of their interest in scheduled policies. Finally, PSZJs experience in other Church-affiliated cases is that debtors in these types of cases, whether represented in insurance coverage matters by defense counsel (as is the case here) or by special counsel, have a degree of conflict that warrants special Committee insurance counsel. 9. After the Committee Formation Date, and because of the foregoing

issues, the Committee determined to retain, subject to Court approval, the Law Offices of Paul A. Richler (the Richler Firm) as its special insurance counsel in these Bankruptcy Cases.

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III. 10.

RELIEF REQUESTED AND BASIS FOR RELIEF By this Application, the Committee seeks to employ and retain the

Richler Firm as its special insurance counsel on the terms set forth in this Application nunc pro tunc to October 31, 2011 because the Richler Firm began providing services to the Committee as of that date. The Committee understands that the Richler Firm will seek compensation from the Debtors estates and reimbursement of expenses incurred on the Committees behalf, subject to the Courts procedures in these Bankruptcy Cases. A. The Richler Firm as Special Insurance Counsel 11. The professional services that the Richler Firm will render to the

Committee in its capacity as special insurance counsel include, but shall not be limited to, advising the Committee regarding the following issues: a. Insurance issues relating to any proposed plan(s) of

reorganization(s), mediation(s), and/or settlement discussion(s); b. Negotiations with insurance companies having potential

liability for the Debtors tortious acts; c. A broad range of insurance issues, including, but not

limited to, triggers for insurance coverage for sex abuse, limits of coverage, calculation of the number of occurrences of sex abuse, expected or intended defenses (i.e., coverage may not be available if the Debtors expected or intended the injuries to occur), and other insurance defenses;

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d. insurance carriers; e.

Proposed insurance policy buybacks from the Debtors

Litigation of insurance coverage issue, including

intervention in the Archdiocese Coverage action, which was brought by the Archdiocese of Seattle against the Debtors and two of its insurers. The Archdiocese Coverage
Proceeding seeks a relief regarding the scope of coverage for all insurance policies that may cover claims in these Bankruptcy Cases irrespective of whether those policies are known to the Debtors or the Committee and prior to the expiration of the claims bar date in these cases when it will be possible to identify those polices. It is the Committees position that the

Debtors and their counsel appear to have conflicts of interest and split loyalties, as set forth in the Response of Official Committee of Unsecured Creditors to Motion of the Catholic
Archbishop of Seattle to Seek Determination of the Extent of 11 U.S.C. 362 Stay With Regard to Edmund Rice Congregation of Christian Brothers - North American Province [Docket No. 119]; and

f.

Other issues as necessary to assist the Committee with

respect to issues relating to the Debtors insurance. The Committee needs independent advice to evaluate all issues that impact insurance coverage for unsecured claims. Although the Committee and the Debtors technically share a common interest in pursuing insurance coverage to the extent that Debtors positions are unaffected by their split loyalties and its counsels apparent conflicts of interest, in all likelihood, the Debtors will

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be more constrained in pursuing coverage due to its duty to cooperate with its insurers. Unfortunately, insurers regularly (and unjustifiably) invoke that duty in order to hinder insureds aggressive pursuit of insurance coverage to which the insureds are entitled. The Committee cannot be dependent on advice from counsel for the Debtors that owes duties to its insurers, which may conflict with the Committees interest in pursuing those insurers. B. The Richler Firms Expertise 12. The Committee is familiar with the professional standing and

reputation of Paul A. Richler (Mr. Richler), the principal of the Richler Firm, and recognizes that Mr. Richler has experience providing legal assistance in the area of insurance, pension, and retiree health issues. Mr. Richler, formerly a partner at Morgan, Lewis & Bockius, LLP, had primary and lead responsibility as special counsel to the official committees of unsecured creditors in (i) In re Society of Jesus, Oregon Province (Bankr. D. Or., Case No. 09-30938-elp11) and (ii) In re Catholic Diocese of Wilmington, Inc. (Bankr. D. Del., Case No. 09-13560 (CSS)). The Richler Firm also is serving as special insurance counsel to the post-confirmation trustee in the Catholic Bishop of Northern Alaska, (Bankr. D. Alaska, Case No. 08-00110). 1 In addition, while at Morgan, Lewis & Bockius, LLP, Mr. Richler had been engaged as insurance counsel in nonbankruptcy cases involving sexual abuse survivors who sued the Archdiocese of Los Angeles, the Archdiocese of San Francisco and the Diocese of Orange (California).
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Committee counsel served as general bankruptcy counsel to the committees in these three cases.

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Mr. Richler became the principal of his own law firm, the Richler Firm, effective October 1, 2011. During the representations listed above, and until September 30, 2011, Mr. Richler was a partner at Morgan Lewis & Bockius, LLP. Mr. Richlers practice then and now focuses on complex litigation, including policyholder insurance recovery. Mr. Richler is also a seasoned trial lawyer. 13. In the course of these engagements, Mr. Richler has gained an

expertise in the analysis of insurance coverage in the context of Church-related sexual abuse, the conduct of settlement discussions associated with coverage claims, and the litigation of such matters. Based on these facts, the Committee believes that the Richler Firm is well-suited to render the services set forth in this Application. C. The Richler Firms Disinterestedness 14. Neither the Richler Firm nor any of its professionals or

paraprofessionals, insofar as the Committee has been able to ascertain, represent any interest adverse to the Debtors, their estates, their creditors, and the Committee in the matters upon which the Richler Firm is to be engaged. The Richler Firm is a disinterested person, as the Committee understands this term to be defined, within the meaning of section 101(14), as modified by section 1103(b), of the Bankruptcy Code. 15. To the best of the Committees knowledge, the Richler Firm has no

prior connection with the Debtors, their creditors, or any other party-in-interest, or their

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respective attorneys or accountants in the matters upon which it is to be engaged that would in any way disqualify it from representing the Committee. 16. The Richler Firm has indicated a willingness to act as special

insurance counsel on the Committees behalf, in accordance with the terms of this Application. IV. 17. COMPENSATION

Subject to Court approval in accordance with section 330(a) of the

Bankruptcy Code, compensation will be payable to the Richler Firm on an hourly basis, plus reimbursement of the Richler Firms actual, necessary expenses and other charges it incurs. Currently, the Richler Firms only attorney is Mr. Richler. Mr. Richlers current standard hourly rate for representations related to abuse survivors is $650.00. The Richler Firm periodically adjusts its rates to reflect economic and other conditions. The Richler Firm will provide notice to the Court of any adjustment of its hourly rates and will serve such notice upon the U.S. Trustee, the Debtors, and members of the Committee. The Richler Firm does plan on increasing its rates in these Bankruptcy Cases until January 2013. 18. The Richler Firm charges for all expenses incurred in connection

with its clients cases. These expenses include, among other things, conference call charges, computerized legal research changes, mail and express mail charges, special or hand delivery charges, document retrieval charges, photocopying charges, charges for

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mailing supplies (including, without limitation, envelopes and labels) that Richler provides to outside copying services for use in mass mailings, travel expenses, expenses for working meals, computerized research, transcription costs, and non-ordinary overhead expenses such as secretarial overtime and other staffing overtime. The Richler Firm will bill for these expenses in a manner and at rates consistent with those charged to other clients, and the rules and requirements of this Court. V. 19. NOTICE

Notice of this Application has been given to (i) the U.S. Trustee;

(ii) counsel to the Debtors; and (iii) those parties requesting notice pursuant to Bankruptcy Rule 2002. The Committee submits that, in light of the nature of the relief requested, no other or further notice need be given. VI. 20. PRIOR REQUEST

The Committee has not made a similar Application in this Court or

in any other court to employ the Richler Firm in these Bankruptcy Cases.

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WHEREFORE, the Committee requests entry of an Order substantially in the form attached hereto, authorizing the Committee to employ and retain the Richler Firm as special insurance counsel to the Committee, and granting such other and further relief as is just and proper.

Dated: Seattle, Washington November 18, 2011

/s/ Joseph Shanks Joseph Shanks, in his capacity as CoChairman of the Official Committee of Unsecured Creditors of The Christian Brothers Institute and The Christian Brothers of Ireland, Inc. /s/ Edwin Fowler Edwin Fowler, in his capacity as CoChairman of the Official Committee of Unsecured Creditors of The Christian Brothers Institute and The Christian Brothers of Ireland, Inc.

Dated: Newfoundland, Canada November 18, 2011

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 Case THE CHRISTIAN BROTHERS INSTITUTE, et al., Debtors. Case No. 11-22820 (RDD) (Jointly Administered)

DECLARATION OF PAUL A. RICHLER IN SUPPORT OF APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANKR. P. 2014 FOR ENTRY OF AN ORDER AUTHORIZING AND APPROVING THE EMPLOYMENT OF LAW OFFICES OF PAUL A. RICHLER AS SPECIAL INSURANCE COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS NUNC PRO TUNC TO OCTOBER 31, 2011 PAUL A. RICHLER, declares under penalty of perjury as follows: 1. I am the principal of the Law Offices of Paul A. Richler (the

Richler Firm).1 My business address is 15332 Antioch Street, Ste. 305, Pacific Palisades, CA 90272. I am authorized to make this Declaration in support of the Richler Firms employment as special insurance counsel for the Official Committee of Unsecured Creditors (the Committee) in the above-captioned bankruptcy cases (the Bankruptcy Cases). 2. I have personal knowledge of the facts stated in this declaration. If

called as a witness, I could and would testify competently to these facts, except where matters are stated on information and belief. As to those facts, I am informed and believe that they are true.

All terms not otherwise defined in this declaration shall have the meanings ascribed to them in the Application, defined below.
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3.

I submit this declaration in support of the Application of the

Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. P. 2014 for Entry of an Order Authorizing and Approving the Employment of the Law Offices of Paul A. Richler as Special Insurance Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to October 31, 2011 (the Application). 4. In the Bankruptcy Cases, the Richler Firm can provide the

Committee with particular expertise in insurance issues. 5. The Committee has asked the Richler Firm render the following

insurance-related services, among other things, to the Committee in these Bankruptcy Cases: a. Insurance issues relating to any proposed plan(s) of

reorganization(s), mediation(s), and/or settlement discussion(s); b. liability for the Debtors acts; c. A broad range of insurance issues, including, but not Negotiations with insurance companies having potential

limited to, triggers for insurance coverage for sex abuse, limits of coverage, calculation of the number of occurrences of sex abuse, expected or intended defenses (i.e., coverage may not be available if the Debtors expected or intended the injuries to occur), and other insurance defenses;

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d. insurance carriers; e. f.

Proposed insurance policy buybacks from the Debtors

Litigation of insurance coverage issues; and Other issues as necessary to assist the Committee with

respect to issues relating to the Debtors insurance. 6. Currently, I am the Richler Firms only attorney. My current

standard hourly rate for representations related to abuse survivors is $650.00. The Richler Firm periodically adjusts its rates to reflect economic and other conditions. The Richler Firm will provide notice to the Court of any adjustment of its hourly rates and will serve such notice upon the U.S. Trustee, the Debtors, and members of the Committee. The Richler Firm does plan on increasing its rates in these Bankruptcy Cases until January 2013. 7. The Richler Firm charges for all expenses incurred in connection

with its clients cases. These expenses include, among other things, conference call charges, computerized legal research changes, mail and express mail charges, special or hand delivery charges, document retrieval charges, photocopying charges, charges for mailing supplies (including, without limitation, envelopes and labels) that Richler provides to outside copying services for use in mass mailings, travel expenses, expenses for working meals, computerized research, transcription costs, and non-ordinary overhead expenses such as secretarial overtime and other staffing overtime. The Richler Firm will

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bill for these expenses in a manner and at rates consistent with those charged to other clients, and the rules and requirements of this Court. 8. The Richler Firm understands that all of its fees and expenses are

subject to Court approval. 9. The Committee is familiar with the professional standing and

reputation of the Richler Firm and myself, and recognizes that I have experience providing legal assistance in the area of insurance issues. I was formerly a partner at Morgan, Lewis & Bockius, LLP, and had primary and lead responsibility as special counsel to the official committees of unsecured creditors in (i) In re Society of Jesus, Oregon Province, Case No. 09-30938-elp11 (Bankr. D. Or.) and (ii) In re Catholic Diocese of Wilmington, Inc., Case No. 09-13560 (CSS) (Bankr. D. Del.). I am also is serving as special insurance counsel to the post-confirmation trustee in the Catholic Bishop of Northern Alaska, Case No. 08-00110 (Bankr. D. Alaska). In addition, while at Morgan, Lewis & Bockius, LLP, I had been engaged as insurance counsel in nonbankruptcy cases involving sexual abuse survivors suing the Archdiocese of Los Angeles, the Archdiocese of San Francisco and the Diocese of Orange (California). 10. The Richler Firm has not received any retainer from any person, or

any payment, or any promise of payment in relation to these Bankruptcy Cases, during the one-year period prior to the filing of the Debtors petition. No postpetition compensation has been paid or promised to be paid from a source other than the estate in

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these Bankruptcy Cases. Neither the Committee nor its members (or any of their representatives) are or will be liable for fees or costs that the Richler Firm incurs in its representation of the Committee. 11. The Richler Firm has made the following investigation of

disinterestedness prior to submitting this affidavit: in connection with the proposed retention of the Richler Firm as special counsel to the Committee, the Richler Firm received a list of the Debtors known insurance carriers. At my direction, the Richler Firm processed through its computerized conflict check system the Debtors names as well as the names of the members of the Committee and each of the Debtors property and casualty insurers that have been identified (the Conflicts Search List). A true and correct copy of the Conflicts Search List is attached hereto as Exhibit A. I reviewed the results of that processing. The Richler Firm has concluded that it does not have any conflicts with any of the entities listed on the Conflicts Search List. 12. Based on the process referred to above, to the best of my

knowledge, information, and belief, I am informed and believe as follows: a. the Debtors; b. The Richler Firm does not provide services to any entity The Richler Firm has had no previous contact or ties with

listed on the Conflicts Search List;

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c.

The Richler Firm is not a creditor, an equity security

holder, or an insider of the Debtors; d. The Richler Firm was not, within three years before the

Petition Date, an investment banker for a security of the Debtors, or an accountant or consultant to such investment banker in connection with the offer, sale, or issuance of any security of the Debtors; e. The Richler Firm is not and was not, within two years

before the Petition Date, a director, officer, or employee of the Debtors or of an investment banker of the Debtors; f. The Richler Firm does not have an interest materially

adverse to the interest of the Debtors or of any class of creditors or equity security holders by reason of any direct or indirect relationship with, connection with, or interest in, the Debtors or any investment banker, or for any other reason; g. Except with respect to certain other bankruptcy

engagements where I or the Richler Firm acted or acts as counsel to a debtor or a committee, the Richler Firm has no connection with the United States Trustee or persons employed by the Office of the United States Trustee; and h. The Richler Firm was not owed any sums by the Debtors

for services rendered or costs advanced on behalf of the Debtors prior to the Petition Date.

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13.

The Richler Firm may in the future provide legal services to parties

listed on the Conflicts Search List, or to other creditors or parties in interest in the Debtors Bankruptcy Cases, which services are unrelated to any matter involving these Bankruptcy Cases. However, to the best of my knowledge, none of those prior and current engagements or other dealings makes the Richler Firm an interested person under the bankruptcy laws. If the Richler Firm identifies a creditor or other party in interest of the Debtors bankruptcy estate that the Richler Firm has or is providing services to in connection with these Bankruptcy Cases, it will promptly disclose such information in writing to the Court and to the Office of the United States Trustee. 14. The Richler Firm is currently employed in unrelated cases,

including bankruptcy cases, as special counsel, for which other counsel associated with these Bankruptcy Cases may be involved. I believe that such connections do not give the Richler Firm an adverse interest to the Debtors and do not affect the Richler Firms disinterestedness under 11 U.S.C. 327. While I was a partner at Morgan, Lewis & Bockius, LLP, I served as committee counsel in various matters where PSZJ also served as committee counsel, including, but not limited to, the following: a. In re Society of Jesus, Oregon Province, Case No. 09-

30938-elp11 (Bankr. D. Or.) (PSZJ was counsel to the official committee of unsecured creditors; MLB firm was special counsel to that committee);

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b.

In re Catholic Diocese of Wilmington, Inc., Case No. 09-

13560 (CSS) (Bankr. D. Del.) (PSZJ was counsel to the official committee of unsecured creditors; MLB was special counsel to that committee); 15. In In re Catholic Bishop of Northern Alaska, Case No. 08-00110

(Bankr. D. Alaska) (PSZJ was counsel to the official committee of unsecured creditors and is counsel to the post-confirmation trustee; Richler is special insurance counsel to the trustee). 16. Exhibit B. A true and correct copy of my resume is attached hereto as

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Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true and correct.

Dated this 14th day of November, 2011.

/s/ Paul A. Richler____________ Paul A. Richler

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EXHIBIT A Conflict Search List 1. William Shanks 2. Thomas James 3. Joseph Shanks 4. Edwin Fowler 5. James J. Eason 6. William Williams 7. Patrick Cullinan 8. Christian Brothers Institute 9. Christian Brothers of Ireland
10. Edmund Rice Christian Brothers- North American Province 11. Congregation of Christian Brothers 12. Maryland Casualty Company (Zurich) 13. Pacific Indemnity Company (Chubb Group of Insurance Companies) 14. ODea High School 15. Briscoe Memorial School

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EXHIBIT B Resume of Paul A. Richler

Paul A. Richler is an attorney with over 30 years of experience. After almost 25 years, he retired from being a partner in Morgan, Lewis & Bockiuss (Morgan Lewis) litigation practice. Mr. Richler now practices law at the Law Offices of Paul A. Richler. His practice continues to focus on policyholder insurance recovery, insurance bad faith, and complex commercial disputes. At Morgan Lewis, Mr. Richler served on that firms Governing and Advisory Boards, and headed the Los Angeles litigation practice for several years. Mr. Richler's practice focuses on policyholder insurance recovery, insurance bad faith, and complex commercial disputes. Mr. Richler is a seasoned trial lawyer and has represented clients in numerous matters, including complex commercial disputes and insurance recovery disputes in asbestos and clergy abuse cases. Mr. Richler has successfully tried cases in state and federal courts, including both bench and jury trials. In the clergy abuse area, Mr. Richler, as special insurance counsel for the Committee of Unsecured Creditors of the Society of Jesus, Oregon Province bankruptcy case, helped to achieve the largest settlement against any single insurance company on behalf of clergy abuse victims. He has also served as special insurance counsel in the bankruptcies of the Catholic Diocese of Wilmington, Inc., and has also represented the settlement trustee in the Catholic Bishop of Northern Alaska, including the successful mediation of abuse claims against an insurer. He also worked on the Archdiocese of Los Angeles abuse cases. Mr. Richler is a member of the litigation sections of the State Bar of California and the American Bar Association. He is admitted to practice in California and before several U.S. District Courts and before the U.S. Circuit Courts of Appeals for the Ninth Circuit. Mr. Richler was born in Montreal, Canada. He attended McGill University in Montreal, Osgoode Hall Law School at York University in Toronto (LLB/JD, 1970) and the London School of Economics (LLM, 1971). Selected Representations Representation of the Catholic Diocese of Wilmington, Inc., and the Society of Jesus, Oregon Province as special insurance counsel in the bankruptcy cases of those entities. In the Society of Jesus, Oregon Province case, Mr. Richler was instrumental in negotiating a settlement of $118 million against one insurer, despite the fact that the insurer had previously entered into a

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settlement agreement with the Province that purported to release all rights to insurance for the claims of about half of the abuse claimants against the Province. Representing Fremont General Corporation in multi-month trial brought by the attorney-general of the State of California that led to the exoneration of Fremont General. Mr. Richler also successfully handled the appeal by the Attorney-General of an award of almost $1 million in costs. As part of team at Morgan Lewis, representing Thorpe Insulation Company in bankruptcy courts in asbestos litigation as special insurance counsel and in state court insurance recovery litigation against numerous insurers. The settlements with insurers in that case to date have totaled hundreds of millions of dollars. With another Morgan Lewis partner, as well as associate and paralegals, representing several clients at trial in San Francisco Superior Court, that are pursuing alter ego and other related claims against Zurich Insurance Company based on Zurichs recapitalization of the Home Insurance Company. That case has not yet been resolved. Representing the CEO of an investment incubator company in a multi-week jury trial of claims by shareholders for breach of fiduciary duty and other claims arising from market losses. The trial resulted in the complete exoneration of the client.

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: THE CHRISTIAN BROTHERS INSTITUTE, et al., Debtors. Chapter 11 Case No. 11-22820 (RDD)

ORDER GRANTING APPLICATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PURSUANT TO FED. R. BANKR. P. 2014 FOR ENTRY OF AN ORDER AUTHORIZING AND APPROVING THE EMPLOYMENT OF THE LAW OFFICES OF PAUL A. RICHLER AS SPECIAL INSURANCE COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS NUNC PRO TUNC TO OCTOBER 31, 2011 Upon consideration of the Application of the Official Committee of Unsecured Creditors Pursuant to Fed. R. Bankr. P. 2014 for Entry of an Order Authorizing and Approving the Employment of Paul A. Richler as Special Insurance Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to October 31, 2011 (the Application),1 filed by the Official Committee of Unsecured Creditors appointed in the above-captioned case (the Committee), and upon the Declaration of Paul A. Richler (the Richler Affidavit) in support of the Application; and the Court being satisfied based on the representations made in the Application and in the Richler Affidavit that the Law Offices of Paul A. Richler (the Richler Firm) represents no interest adverse to the Debtors estate with respect to the matters upon which it is to be engaged, that it is a disinterested person as that term is defined under Section 101(14) of the Bankruptcy Code, as modified by section 1103(b) of the Bankruptcy Code, and that its employment by the Committee is necessary; and the Court having jurisdiction to consider the Application and the relief requested therein pursuant to 28 U.S.C. 157 and 1334; and this

Capitalized terms not otherwise defined herein shall have the meanings set forth in the Application.

1
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matter being a core proceeding pursuant to 28 U.S.C. 157(b)(2); and venue being proper in this District pursuant to 28 U.S.C. 1408 and 1409; and it appearing that the relief requested in the Application is in the best interests of the Committee, the Debtors and other parties in interest; and the Committee having provided adequate and appropriate notice of the Application under the circumstances; and after due deliberation and good and sufficient cause appearing therefor; and it appearing to the Court that the said Application should be approved, it is HEREBY ORDERED THAT: 1. 2. The Application is GRANTED as set forth herein. In accordance with sections 328, 504, 1102, and 1103 of the Bankruptcy

Code, Bankruptcy Rules 2014 and 2016 and Local Bankruptcy Rules 2014-1 and 2016-1, the Committee is authorized to employ and retain the Richler Firms as its special insurance counsel nunc pro tunc to October 31, 2011 on the terms set forth in the Application and the Richler Declaration. 3. The Richler Firm shall apply for compensation for professional services

rendered and reimbursement of expenses incurred in connection with the Debtors Cases in compliance with the applicable provisions of the Bankruptcy Code, the Bankruptcy Rules, the U.S. Trustee Guidelines, and any other applicable procedures and orders of this Court, including General Order M-389, and the Order Granting Debtors Motion to Establish Procedures for Monthly Compensation and Reimbursement of Expenses of Professionals [Docket No. 64], and such other orders as this Court may direct. 4. The Richler Firm is authorized to render professional services to the

Committee as described in the Application. 2

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5.

The Richler Firm shall provide notice to the Court of any adjustments of

its hourly rates, and shall serve such notice upon the U.S. Trustees, the Debtors, and members of the Committee. 6. The Committee and The Richler Firm are authorized and empowered to

take all actions necessary to implement the relief granted in this Order. 7. The terms and conditions of this Order shall be immediately effective and

enforceable upon its entry. 8. This Court shall retain jurisdiction with respect to all matters arising from

or related to the implementation of this Order. Dated: White Plains, New York December __, 2011

UNITED STATES BANKRUPTCY JUDGE