Application For Expedited Consideration Of First Day Matters {NJB AEC}

UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY Caption in Compliance with D.N.J. LBR 9004-1(b) In Re: Case No.: Chapter: ____________________ 11 Hearing Date: ____________________ Judge: ____________________ APPLICATION FOR EXPEDITED CONSIDERATION OF FIRST DAY MATTERS On ______________________________, the debtor filed a petition for relief under Chapter 11 of the Bankruptcy Code. Counsel for the Debtor requests that the following relief be provided on a first day basis (check those that apply): 1. 2. Motion Seeking the Joint Administration of Multiple Debtor Bankruptcy Cases. Motion for an Order Authorizing the Debtor an Extension of Time Within Which to File Statements And Schedules. 3. Motion for an Order Authorizing the Emergency or Interim Use of Cash Collateral or DebtorIn-Possession Financing Pending the Noticing and Scheduling of an Interim or Final Hearing For Financing Pursuant to Bankruptcy Code §§ 363 and 364 and Fed. R. Bankr. P. 4001. 4. Motion for an Order Authorizing the Debtor to Maintain Existing Bank Accounts and Business Forms and Cash Management Procedures Providing the United States Trustee's Office with a 60 Day Period to Object to Said Order Before it Becomes a Final Order. American LegalNet, Inc. www.FormsWorkFlow.com 5. Motion for an Order Authorizing a Debtor to Modify the Investment Guidelines Set Forth in Bankruptcy Code § 345 on an Interim Basis, Providing the United States Trustee's Office and Any Other Parties-In-Interest a 60-Day Period to Object to Said Order Before it Become A Final Order. 6. Motion for an Order Authorizing the Debtor to Pay Prepetition Wages, Salaries, Compensation, Employee Benefits and Reimbursable Business Expenses Up To the Limits Set Forth in Bankruptcy Code § 507(A). 7. Motion for an Order Authorizing the Debtor to Pay Prepetition Sales, Use, Payroll And Other Taxes That Are Otherwise Priority Claims Under Bankruptcy Code § 507. 8. 9. Motion for an Order Authorizing the Debtor to Continue Credit Card Facilities. Motion for an Order Authorizing the Debtor to Honor Certain Pre-Petition Customer Obligations, Deposits, Rebates, Etc. 10. Motion for an Order Authorizing the Debtor to Continue With and Pay Pre-Petition Outstanding Amounts Due on Various Insurance Policies. 11. Motion for an Order Authorizing Payment of Outstanding and Unpaid Pre-Petition Debt to Certain Vendors Who Provide Critical and Necessary Services and/or Products to the Debtor. 12. Motion for an Order Pursuant to Bankruptcy Code § 366 Regarding Adequate Assurance for the Future Performance for Utilities and Establishing Procedures for Determining Requests for Additional Adequate Assurance. 13. 14. 15. Motion for an Order Authorizing the Debtor to Retain a Claims and Noticing Agent. Motion for an Order Establishing Noticing Procedures. Others [Counsel should add all other motions for which it seeks consideration as a first day matter.] Date: ________________________ ______________________________________ Signature rev.8/1/15 2 American LegalNet, Inc. www.FormsWorkFlow.com