Case 16-12789-KJC
Doc 147
Filed 01/09/17
Page 43 of 44
and that the Debtors have established cause to exclude such relief from the 14-day stay period under Bankruptcy Rule 6004(h). Consent to Jurisdiction 66.
Pursuant to Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and
Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the Debtors consent to the entry of a final judgment or order with respect to this Motion if it is determined that the Court would lack Article III jurisdiction to enter such final order or judgment absent consent of the parties. Notice 67.
Notice of this Motion has been given to the following parties or, in lieu thereof, to
their counsel, if known: (a) the Office of the United States Trustee for the District of Delaware; (b) counsel for Wilmington Trust, National Association, as indenture trustee for the Secured Notes; (c) counsel the Ad Hoc Committee of Secured Noteholders; (d) Wilmington Savings Fund Society, FSB, as indenture trustee for the Unsecured Notes; (e) counsel DDJ Capital Management, LLC, as the sole holder of the Unsecured Notes; (f) counsel to the Creditors’ Committee; and (g) all other parties requesting to receive notice pursuant to Bankruptcy Rules 2002 prior to the date of the Motion. As the Motion is seeking expedited relief, the Debtors will serve copies of the Motion and any order entered with respect to the Motion in accordance with the Local Rules. The Debtors submit that, in light of the nature of the relief requested, no other or further notice is required. No Prior Request 68.
No prior Motion for the relief requested herein has been made to this or any other
court other than in connection with the Cash Collateral Order.
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