IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE. Inve: Chapter 11 LOS ANGELES DODGERS LLC, et al.,' Case No. 11-12010 (KG) Jointly Administered Debtors. Objection Deadline: September 30, 2011 at 4:00 p.m. (ET) Hearing Date: October 12, 2011 at 10:00 a.m. (ET) LOS ANGELES DODGERS LLC’S APPLICATION, PURSUANT TO SECTIONS 327(a) AND 328(a) OF THE BANKRUPTCY CODE, BANKRUPTCY RULE 2014(a), AND LOCAL RULE 2014-1, FOR AUTHORIZATION TO EMPLOY KEKST AND COMPANY INCORPORATED AS CORPORATE COMMUNICATIONS ADVISOR, NUNC PRO TUNC TO THE COMMENCEMENT DATE, TO THE HONORABLE KEVIN GROSS, CHIEF UNITED STATES BANKRUPTCY JUDGE: Los Angeles Dodgers LLC (“LAD”) submits this application (the “Application”) for an order, substantially in the form attached hereto as Exhibit D, approving the employment and retention of Kekst and Company Incorporated (“Kekst”) as corporate communications advisor, nune pro tunc to the date on which LAD commenced its chapter 11 case. This Application is supported by the Affidavit of Robert Siegfried, Pursuant to Sections 327(a) and 328(a) of the Bankruptcy Code, Bankruptcy Rule 2014(a), and Local Rule 2014-1, in Support of Los Angeles Dodgers LLC’s Application for Authorization to Employ and Retain Kekst and Company Incorporated as Corporate Communications Advisor, Nunc Pro Tunc to the Commencement Date (the “Siegfried Affidavit”), attached hereto as Exhibit A. In further support of this Application, LAD respectfully represents: ‘The Debtors, together with the last four digits of each Deblor’s federal tax identification number are: Los ‘Angeles Dodgers LLC (3133); Los Angeles Dodgers Holding Company LLC (4851); LA Holdeo LLC (2567); LA Real Estate Holding Company LLC (4850); and LA Real Estate LLC (3029). The location of the Debtors’ corporate headquarters and the service address for the Debtors is: 1000 Elysian Park Avenue, Los Angeles, California 90012. La23982.12SURISDICTION AND VENUE 1, This Court has jurisdiction to consider the Application pursuant to 28 U.S.C, §§ 157 and 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). Venue before this, Court is proper pursuant to 28 U.S.C. §§ 1408 and 1409. The predicates for the relief requested herein are sections 327(a) and 328(a) of the Bankruptcy Code, Bankruptey Rule 2014(a), and Local Rule 2014-1. 2. No previous request for the relief requested herein has been made to this Court or any other court. BACKGROUND 3. On June 27, 2011 (the “Commencement Date”), LAD filed a voluntary petition for relief under chapter 11 of the Bankruptey Code, 4, The Debtors intend to continue in the possession of their properties and the ‘management of their businesses as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptoy Code. 5. On July 13, 2011, the Office of the United States Trustee for the District of Delaware appointed an official committee of unsecured creditors (the “Creditors’ Committee”) [Docket No. 190]. No trustee or examiner has been appointed in these cases. 6. Additional information about the Debtors’ businesses, the events leading up to the Commencement Date, and the facts and circumstances surrounding the Debtors and the chapter 11 cases can be found in the “Declaration of Jeffrey J. Ingram in Support of Debtors’ Chapter 11 Petitions and First Day Motions” [Docket No. 4] (the “Ingram Declaration”), filed on the Commencement Date and incorporated by reference herein.” » Capitalized terms not otherwise defined herein shall have the meaning attributed to them inthe Ingram Declaration. 1LA203452.12,RELIEF REQUESTED 7. By this Application, LAD seeks entry of an order pursuant to sections 327(a) and. 328(a) of the Bankruptcy Code authorizing the employment of Kekst, as of the Commencement Date, as corporate communications advisor in the course of its chapter 11 case to advise LAD on corporate public relations and corporate communications issues and provide communications services, in accordance with the terms and conditions of the Siegfried Affidavit and the LAD Engagement Letter (as defined herein) annexed hereto as Exhibit B (and incorporated herein by reference), BASIS FOR RELIEF REQUESTED 8. The standard for a debtor in possession to employ a professional person is set forth in Sections 327(a) and 328(a) of the Bankruptcy Code, as interpreted by the Third Circuit, Section 327(a) provides that a debtor in possession, with the Court’s approval, may employ professional persons “that do not hold or represent an interest adverse to the estate,” and that are “disinterested persons.” 11 U.S.C. § 327(a); 11 U.S.C. § 1107; see also In re BH&P, Inc., 949 F.2d 1300, 1314 (3d Cir. 1991). 9. A “disinterested person” is defined as one who does not have an interest ‘materially adverse to the interest of the estate, by reason of any direct or indirect relationship with the debtor, or for any other reason, 11 U.S.C. § 101(14)(¢). Section 1107(b) of the Bankruptcy Code modifies section 101(14) (definition of “disinterested person”) and section 327(a) of the Bankruptcy Code in chapter 11 cases, by providing “a person is not disqualified for employment under section 327 of [the Bankruptcy Code] by a debtor in possession solely because of such person’s employment by or representation of the debtor before the commencement of the case.” 11 U.S.C. § 1107(b). 1an3650.12