In re:

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
)
) Chapter II
)
CRDENTIA CORP., et al
1
, ) Case No. I 0-10926 (BLS)
)
Debtors. ) Jointly Administered
)
) Hearing Date: April29, 2010 at 9:30a.m.
) Objection Deadline: April 26,2010 at 4:00p.m.
----------------------------------
APPLICATION FOR AN ORDER PURSUANT TO 11 U.S.C. 1103(a) AND FED. R.
BANKR. P. 2014(a) AUTHORIZING AND APPROVING THE EMPLOYMENT
AND RETENTION OF FURTEK & ASSOCIATES, LLC, AS FINANCIAL ADVISOR
TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS
NUNC PRO TUNC TO APRIL 1, 2010
The Official Committee of Unsecured Creditors (the "Committee") of Crdentia Corp., et
al, (the "Debtors") hereby files this application for entry of an order authorizing the Committee
to retain and employ Furtek & Associates, LLC ("Furtek") as Financial Advisor to the
Committee nunc pro tunc, effective as of April I, 2010, pursuant to II U.S.C. 11 03(a), 327(a)
and 328(a), Federal Rule of Bankruptcy Procedure 2014(a), and Delaware Local Bankruptcy
Rule 2014-1. In support of this application (the "Application"), the Committee submits the
Affidavit of Richard E. Furtek, a copy of which is attached as "Exhibit A" hereto (the "Furtek
Affidavit") and respectfully represents as follows:
BACKGROUND
I. This Court has jurisdiction over this Application pursuant to 28 U.S.C. !57 and
1334. Venue of the Debtors' chapter II case is claimed to exist pursuant to 28 U.S.C. 1408
1
The Debtors are:Crdentia Corp., A TS Universal, LLC, Baker Anderson Christie, Inc., CRDE Corp., GHS
Acquisition Corporation, Health Industry Professionals, LLC, HIP Holding, Inc., MP Health Corp., New Age
Staffing, Inc. and Nurses Network, Inc.
DELl 74654-1
and 1409. The statutory predicates for the relief sought herein are sections 1103(a) and 328(a) of
the Bankruptcy Code.
2. On March 17, 2010 (the "Petition Date"), the Debtors each filed a voluntary
petition for relief under chapter II of title II of the United States Code, II U.S.C. 101 et seq.
(the "Bankruptcy Code"). The Debtors have continued in the management and operation of their
business and property pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee
or examiner has been appointed in this case.
3. In accordance with section 1102(b) of the Bankruptcy Code, on March 25, 2010
(the "Formation Date"), the United States Trustee appointed the Committee in the Debtors' case,
comprised of the following three members: Alpha Capital AG, ARM Holdings and AXSA
Document Solutions. After its formation, the Committee duly selected Furtek as its financial
advisor to assist it in financial matters during the pendency of this case, subject to Court
approval.
RELIEF REQUESTED AND THE BASIS THEREFORE
4. In order for the Committee to perform properly the functions and duties vested in
it by the Bankruptcy Code, it is essential that it have the expertise and advice of an experienced
financial advisor. The professional services for which the Committee desires to employ Furtek
include, without limitation, the following:
Review reasonableness of cash collateral/DIP financing arrangements as to its cost to the
Debtors and the likelihood that the Debtors will be able to comply with the terms of the
Order thereon;
Analyze and review key motions to identify strategic case issues;
Gain an understanding of Debtors' corporate structure, including non-debtor entities;
Perform an assessment of Debtors' budget(s);
2
DELl 74654-1
Establish reporting procedures that will allow for the monitoring of the Debtors' sale and
wind-down activities;
Develop and evaluate alternate sale strategies;
Scrutinize the proposed sale transactions;
Identify, analyze and investigate transactions with non-debtor entities and other related
parties;
Monitor Debtors' weekly operating results, availability and borrowing base certificates, if
applicable;
Monitor the sales process and supplement list of potential buyers;
Analyze Debtors' budget to actual results on an ongoing basis for reasonableness and
cost control;
Communicate findings to the Committee;
Perform forensic accounting procedures as directed by the Committee;
Assist the Committee in negotiating key terms of the Plan;
Review the nature and origin of significant claims asserted against the Debtors, if any;
and
Render such assistance as the Committee and its counsel may deem necessary.
5. The Committee respectfully requests entry of an order authorizing it to employ
and retain Furtek as financial advisor to the Committee nunc pro tunc, effective as of April I,
2010, pursuant to sections 1103(a) and 328(a) of the Bankruptcy Code.
6. Furtek's proposed compensation is set forth in the Furtek Affidavit. In summary,
the Debtors' estates shall reimburse Furtek for its hourly professional charges and disbursements.
The Committee and Furtek understand that any compensation or reimbursement of expenses paid
to Furtek must first be approved by this Court upon application consistent with the Bankruptcy
Code and applicable Bankruptcy Rules.
3
DEL I 74654-1
7. The Committee believes that Furtek possesses extensive knowledge and expertise
in the areas of finance relevant to this Chapter 11 case and related proceedings and that Furtek is
well-qualified to act as its financial advisor in such matters. Furtek has considerable experience
in the healthcare industry including in chapter 11 reorganization cases.
8. Upon information and belief, Furtek does not represent and does not hold any
interest adverse to the Debtors' estate or its creditors. The Committee has been advised that
Furtek has no connection with the Debtors, their creditors, the United States Trustee or anyone
employed in the Office of the United States Trustee, or other parties in interest in this case, other
than as described in the Furtek Affidavit. However, Furtek is a large firm and may represent or
have represented certain of the Debtors' creditors in matters unrelated to this case.
9. Furtek has agreed to make appropriate applications to this Court for compensation
and reimbursement of expenses in compliance with the Bankruptcy Code, the Bankruptcy Rules,
the Local Rules of this Court and any Order entered by this Court in this case modifying the
timing and/or procedures applicable to the payment of interim compensation and reimbursement
of expenses. Furtek will bill at its normal hourly rates (Principal $395; Senior Directors $300-
$350; Directors $200-$275; and Paraprofessionals: $150). Richard E. Furtek, Principal, will
have overall responsibility for the engagement and will be the primary contact for the Committee
and will be assisted, as appropriate, by staff.
10. These hourly rates are subject to periodic increase in the normal course of
Furtek's business. All such professionals will bill at Furtek's customary hourly rates for work of
this nature. These rates are set at a level designed to fairly compensate Furtek for the work of its
personnel and to cover fixed and routine overhead expenses.
4
DELl 74654- I
II. With respect to disbursements, it is Furtek's policy to charge its clients in all areas
of practice lhr all other expenses incurred in connection with the client's matter. The expenses
charged to clients include, among other things, telephone and telecopier toll charges,
photocopying charges scanning and filing costs, travel expenses, expenses for \vorking mear.s.''
cornputeri7..ed research, a.:; well a') non-ordinary expenses such as secretarial overtime ..
NOTICE
12. No trustee or examiner has been appointed in the Debtors' chapter II case.
Notice of the hearing on this Application been provided to the Debtors, the Oflice of the
United States Trustee, and ali parties requesting notice pursuant to Bankruptcy Rule 2002. The
Committee submits that under the circumstances, no further notice is necessary.
WHEIU:F'ORE, the Committee respectfully requests the entry of an order authorizing it
to retain Furtek as its financial advisor in this Case mmc pro tunc, ellective a. of April 1, 20 I 0,
and granting such other and further relief as may be just and proper.
Dated: 2010 HIE OFFICIAL COMM!Tl'EE OF UNSECURED
CREDI'l'ORS CRDENT!A CORP., et al
By:
1: 111 t>f2j9"' r v
5
OU.-1 'N6S4-I
DEL1 74690-1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
)
In re: ) Chapter 11
)
) Case No. 10-10926 (BLS) CRDENTIA CORP., et al,
)
Debtors. ) Jointly Administered
)
)
)
AFFIDAVIT OF RICHARD E. FURTEK
Richard E. Furtek deposes and says:
1. I am a Certified Public Accountant, licensed under the laws of Pennsylvania. I
am a member of the firm of Furtek & Associates, LLC (Furtek), which firm maintains offices
at 1060 First Avenue, Suite 400, King of Prussia, PA. I am familiar with the matters set forth
herein and provide this affidavit in support of the application (the Application) of the Official
Committee of Unsecured Creditors (the "Committee") of the above captioned debtors and
debtors in possession (the Debtors) seeking approval to retain Furtek nunc pro tunc, effective
as of April 1, 2010, as financial advisor to the Committee pursuant to 11 U.S.C. 1103(a) and
328(a).
2. To the best of my knowledge and information, Furtek neither holds nor represents
any interest adverse to the Committee, the Debtors, its creditors, the United States Trustee or
anyone employed in the Office of the United States Trustee, or other parties in interest or its
respective attorneys in this case. In order to make this determination, I have undertaken a
review upon the following: (i) the Debtors name as it appears in its petition; (ii) the parties listed
on the Debtors list of largest unsecured creditors; (iii) the members of the Committee; (iv) the
Debtors management; (v) the proposed asset purchaser; (vi) the Debtors secured creditors and
DEL1 74690-1
(vi) certain other parties that appear in the Debtors first-day affidavit. As other information
becomes available, further searches will be implemented, and supplemental disclosures will be
made as necessary.
3. Based upon information currently available to me, Furtek has no connection with
the Debtors, their creditors, or any other party in interest herein, or the United States Trustee or
any person employed in the office of the United States Trustee.
4. In addition to the foregoing, due to the size and diversity of its practice, Furtek
may have represented or otherwise dealt with, and may now be representing or otherwise dealing
with various persons (and its attorneys and accountants) who are or may consider themselves
creditors, equity security holders or parties in interest in this case but who are not presently so
identified. However, such representations or involvement, if any, do not relate to the Debtors or
their estates.
5. No agreement exists, nor will any be made, to share any compensation received
by Furtek for its services in this case with any other person or firm.
6. Furtek is willing to be retained by the Committee as its financial advisor and will
make appropriate applications to this Court for compensation and reimbursement of out-of-
pocket expenses, all in accordance with the provisions of the Bankruptcy Code, the Bankruptcy
Rules and the Local Rules of this Court, and any Orders of the Court entered in this case.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge, information and belief.
Dated: April 8, 2010
Wilmington, Delaware
/s/ Richard E. Furtek
Richard E. Furtek
DEL1 74690-1
DEL1 74689-1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
)
In re: ) Chapter 11
)
) Case No. 10-10926 (BLS) CRDENTIA CORP., et al,
)
Debtors. ) Jointly Administered
)
)
Related D.I. No. ____
)
ORDER APPROVING THE RETENTION OF FURTEK AND ASSOCIATES, LLC
AS FINANCIAL ADVISOR TO THE OFFICIAL COMMITTEE OF UNSECURED
CREDITORS IN THE DEBTORS CASE
Upon the application (the Application) of the official committee of unsecured creditors
(the Committee) of Crdentia Corp., et al. (the Debtors) for an order pursuant to sections
1103(a) and 328(a) of the Bankruptcy Code authorizing the Committee to employ Furtek &
Associates, LLC (Furtek) as its financial advisor in this case nunc pro tunc, effective as of
April 1, 2010, and all undefined terms herein having the meaning ascribed to them in the
Application, and upon the annexed affidavit of Richard E. Furtek, and it appearing that proper
notice of the Application has been given and that no further notice or hearing is required, and the
Court being satisfied based on the representations made in the Application and affidavit that (i)
Furtek represents no interest adverse to the estates or the Debtors creditors, (ii) Furtek is a
disinterested person as that term is defined in section 101(14) of the Bankruptcy Code, and (iii)
the employment of Furtek is necessary and would be in the best interests of the Committee and
the estate, and after due deliberation, and sufficient cause appearing therefore, it is
ORDERED, that in accordance with sections 1103(a) and 328(a) of the Bankruptcy
Code, the Committee be, and hereby is, authorized and empowered to retain Furtek as its
DEL1 74689-1
financial advisor nunc pro tunc, effective as of April 1, 2010, to serve as financial advisor to the
Committee in this Case under chapter 11 of the Bankruptcy Code, and it is further
ORDERED, that Furtek shall be compensated in accordance with the procedures set
forth in sections 330 and 331 of the Bankruptcy Code and such Bankruptcy Rules as may be then
applicable, from time to time, and such procedures as may be fixed by order of this Court.
______________________________________
The Honorable Brendan L. Shannon
United States Bankruptcy Judge
Dated: _____________, 2010
Wilmington Delaware
DEL1 74688-1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
)
In re: ) Chapter 11
)
) Case No. 10-10926 (BLS) CRDENTIA CORP., et al
1
,
)
Debtor. ) Jointly Administered
)
)
Hearing Date: April 29, 2010 at 9:30 p.m.
)
Objection Deadline: April 26, 2010 at 4:00 p.m.
NOTICE OF APPLICATION FOR AN ORDER PURSUANT TO 11 U.S.C. 1103(a) AND
FED. R. BANKR. P. 2014(a) AUTHORIZING AND APPROVING THE EMPLOYMENT
AND RETENTION OF FURTEK & ASSOCIATES, LLC, AS FINANCIAL ADVISOR
TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS
NUNC PRO TUNC TO APRIL 1, 2010
PLEASE TAKE NOTICE THAT on April 8, 2010, the Official Committee of
Unsecured Creditors files its Application for an Order Pursuant to 11 U.S.C. 1103(a) and Fed. R.
Bankr. P. 2014(a) Authorizing and Approving the Employment and Retention of Furtek &
Associates, LLC, as Financial Advisor to the Official Committee of Unsecured Creditors Nunc
Pro Tunc To April 1, 2010 (Application) with the United States Bankruptcy Court for the
District of Delaware (the Bankruptcy Court).
PLEASE TAKE FURTHER NOTICE THAT any objections or responses to the
Application must be in writing and filed with the Clerk of the United States Bankruptcy Court
for the District of Delaware, 824 Market Street, Third Floor, Wilmington, DE 19801, and served
upon the undersigned, so as to be received on or before 4:00 p.m. prevailing Eastern Time on
April 26, 2010.

1
The Debtors are: Crdentia Corp., ATS Universal, LLC, Baker Anderson Christie, Inc., CRDE Corp., GHS
Acquisition Corporation, Health Industry Professionals, LLC, HIP Holding, Inc., MP Health Corp., New Age
Staffing, Inc. and Nurses Network, Inc.
DEL1 74688-1
PLEASE TAKE FURTHER NOTICE THAT if an objection is timely filed, served
and received and such objection is not otherwise timely resolved, a hearing to consider such
objection and the Application will be held before The Honorable Brendan Shannon at the
Bankruptcy Court, 824 Market Street, 6th Floor, Courtroom 1, Wilmington, Delaware 19801 on
April 29, 2010 at 9:30 a.m. prevailing Eastern Time.
IF NO OBJECTIONS TO THE APPLICATION ARE TIMELY FILED, SERVED
AND RECEIVED IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY
GRANT THE RELIEF REQUESTED IN THE APPLICATION WITHOUT FURTHER
NOTICE OR HEARING.
Dated: April 8, 2010 Respectfully submitted,
By: /s/ Margaret Manning
Richard Beck (Bar No. 3370)
Margaret M. Manning (Bar No. 4183)
KLEHR HARRISON HARVEY BRANZBURG LLP
919 North Market Street, Suite 1000
Wilmington, Delaware 19801-3062
Telephone: 302.426.1189
Facsimile: 302.426.9193
E-mail: rbeck@klehr.com
E-mail: mmanning@klehr.com
PROPOSED COUNSEL FOR THE
OFFICIAL COMMITTEE OF
UNSECURED CREDITORS