Nighthawk had paid Luke Cage for a period of time to work as a member of the Defenders. So when Nighthawk decided that he needed to hire additional recruits in The Last Defenders #3, he rather poetically approached Erik Josten, the reformed villain who began his costumed career using the alias Power Man.
After losing a fight with Luke Cage over use of the name (Power Man #21), Erik Josten changed his code name to Smuggler and then to Goliath before settling on the heroic identity of Atlas.
In addition to hiring Atlas, Nighthawk also recruited the mercenary Paladin and the anti-hero Junta.
Paladin previously turned down membership to the Defenders specifically because they didn't pay (Defenders #62-63). Appropriately enough, The Last Defenders #3 flashed back to a scene of numerous heroes who did join the non-team (without Paladin) one fateful day.
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