Opinion
Case No.: 11-23807-PM Case No.: 11-23809-PM Case No.: 11-23812-PM Case No.: 11-23813-PM Case No.: 11-23814-PM
2011-12-14
SO ORDERED
___________
U. S. BANKRUPTCY JUDGE
STIPULATION AND CONSENT ORDER BETWEEN DEBTORS AND THE UNITED
STATES TRUSTEE FOR REGION FOUR EXTENDING DEADLINE TO FILE
OBJECTION TO MOTION OF THE DEBTORS FOR ENTRY OF AN ORDER: (I)
APPROVING AUCTION AGREEMENT WITH TIGER REMARKETING SERVICES
AND FOX & ASSOCIATES PARTNERS, INC.; (II) AUTHORIZING THE SALE OF
THE DEBTORS' ASSETS FREE AND CLEAR OF ALL LIENS, CLAIMS,
ENCUMBRANCES AND INTERESTS; (III) APPROVING EXPENSE
REIMBURSEMENT; (IV) APPROVING THE FORM AND MANNER OF THE
NOTICE; AND (V) GRANTING RELATED RELIEF
The above-captioned Debtors and Debtors-in-Possessions, by and through their undersigned counsel and the United States Trustee for Region Four, by and through its undersigned counsel, hereby stipulate and agree that the deadline for the United States Trustee to file an Objection to the Motion for entry of an order (i) Approving Auction Agreement with Tiger Remarketing Services and Fox & Associates Partners, Inc. and the Debtors' Execution of and Performance under such Agreement; (ii) Authorizing the Sale of Substantially all of Debtors' Assets Free and Clear of all Liens, Claims, Encumbrances and Interests pursuant to the Agency Agreement; (iii) Approving an Expense Reimbursement Payable under the Agency Agreement to the Auction Firm; (iv) Approving the Form and Manner of the Notice of this Motion; and (v) Granting Related Relief shall be extended through and including December 16, 2011.
SEEN AND AGREED:
________________
James M. Greenan, Esquire,
Fed Bar No. 08623
McNAMEE, HOSEA, JERNIGAN, KIM GREENAN & LYNCH, P.A.
6411 Ivy Lane Suite 200
Greenbelt, Maryland 20770
(301) 441-2420
jgreenan@mhlawyers.com
Counsel for Debtors
_________________
Jeanne M. Crouse, Esquire
Federal Bar No. 05329
W. CLARKSON McDOW, JR.
UNITED STATES TRUSTEE FOR
REGION 4
6305 Ivy Lane
Suite 600
Greenbelt, Maryland 20770
(301) 344-6219
Jeanne.M.Crouse@usdoj.gov
Counsel for W. Clarkson McDow, Jr.,
United States Trustee for Region 4
I HEREBY CERTIFY that the terms of the copy of the stipulation submitted to the Court are identical to those set forth in the original stipulation; and the signatures represented by /s/ ______ on this copy reference the signatures of stipulating parties on the original
stipulation.
_______________
James M. Greenan
Copies to:
Office of the United States Trustee
Jeanne M. Crouse, Esquire
6305 Ivy Lane, Ste. 600
Greenbelt, MD 20770
James M. Greenan
McNamee Hosea
6411 Ivy Lane
Suite 200
Greenbelt, MD 20770
And creditors and parties-in-interest requesting Notice.