Case JNP Doc 366 Filed 06/30/18 Entered 06/30/18 13:57:47 Desc Main Document Page 1 of 2

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1 Case JNP Doc 366 Filed 06/30/18 Entered 06/30/18 13:57:47 Desc Main Document Page 1 of 2 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY Caption in Compliance with D.N.J. LBR PORZIO, BROMBERG & NEWMAN, P.C. 100 Southgate Parkway P.O. Box 1997 Morristown, New Jersey (973) (973) Facsimile Warren J. Martin Jr., Esq. (wjmartin@pbnlaw.com) Kelly D. Curtin, Esq. (kdcurtin@pbnlaw.com) Rachel A. Parisi, Esq. (raparisi@pbnlaw.com) Counsel to the Debtors In Re: Garces Restaurant Group, Inc., d/b/a Garces Group, et al., 1 Debtors. Case No.: (JNP) (Jointly Administered) Chapter: 11 Hearing Date and Time: July 9, 2018 at 10:00 a.m. APPLICATION FOR AN ORDER SHORTENING TIME PERIOD FOR NOTICE, SETTING HEARING AND LIMITING NOTICE The applicant, Garces Restaurant Group, Inc., d/b/a Garces Group, et al., (the "Debtors"), by and through their undersigned counsel, hereby request that the time period for the following Application be shortened pursuant to Fed. R. Bankr. P 9006(c)(1), for the reason(s) set forth below: DEBTORS' MOTION FOR ENTRY OF AN ORDER (I) APPROVING COMPROMISE AND GLOBAL SETTLEMENT UNDER BANKRUPTCY RULE 9019; (II) PROVIDING FOR DISTRIBUTION OF FUNDS; AND (III) GRANTING RELATED RELIEF [ECF No. 364] NOTICE OF PROPOSED COMPROMISE OR SETTLEMENT OF CONTROVERSY RE: COMPROMISE AND GLOBAL SETTLEMENT UNDER BANKRUPTCY RULE 9019 [ECF No. 365] 1. A shortened time hearing is requested because: 1 The Debtors in these cases and the last four digits of their employee identification numbers are: GRGAC1, LLC d/b/a Amada (7047); GRGAC2, LLC d/b/a Village Whiskey (7079); GRGAC3, LLC d/b/a Distrito Cantina (7109); GRGAC4, LLC (0542); Garces Restaurant Group, Inc. d/b/a Garces Group (0697); Latin Valley 2130, LLC; La Casa Culinary, LLC d/b/a Amada Restaurant (4127); Garces Catering 300, LLC d/b/a Garces Catering (3791); Latin Quarter Concepts, LLC d/b/a Tinto d/b/a Village Whiskey (0067); UrbanFarm, LLC d/b/a JG Domestic (3014); GR300, LLC d/b/a Volver (0347); GRG2401, LLC (7222); GRGChubb1, LLC (8350); GRGKC1, LLC; GRGWildwood, LLC (9683); and GRGNY2, LLC (0475); GRGDC2, LLC d/b/a Latin Market (8878); GRGBookies, LLC d/b/a The Olde Bar (4779); and GRGAC5,LLC (9937)

2 Case JNP Doc 366 Filed 06/30/18 Entered 06/30/18 13:57:47 Desc Main Document Page 2 of 2 Approval of the sale of the Debtors' assets contemplated by the present motion must proceed on shortened time due to the ability of the Debtors to only operate for a short period longer. Without a hearing on shortened time, the Debtors will likely be forced to close immediately, resulting in the loss of jobs and any value that otherwise would be provided to the Debtors' estate via the sale. Given the limited sale proceeds, the Debtors respectfully request it be authorized to provide (i) notice of the Motion upon the Master Service List pursuant to Order Establishing Case Management and Administrative Procedures [Docket No. 54] by any means feasible, including by regular or first class mail, facsimile or by electronic mail, and (ii) notice of the Local Form Notice of Proposed Compromise or Settlement of Controversy pursuant to Local Rule upon all known creditors by any means feasible, including by regular or first class mail, facsimile or by electronic mail. 2. State the hearing dates requested: July 9, 2018 at 10:00 a.m. 3. Reduction of the time period is not prohibited under Fed. R. Bankr. P 9006(c)(1). WHEREFORE, the applicant requests entry of the proposed order shortening time. Dated: June 30, 2018 PORZIO, BROMBERG & NEWMAN, P.C. Counsel to the Debtors By: /s/ Warren J. Martin Warren J. Martin rev.8/1/15

3 Proposed Order Page 1 of 4 UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY Caption in Compliance with D.N.J. LBR PORZIO, BROMBERG & NEWMAN, P.C. 100 Southgate Parkway P.O. Box 1997 Morristown, New Jersey (973) (973) Facsimile Warren J. Martin Jr., Esq. (wjmartin@pbnlaw.com) Kelly D. Curtin, Esq. (kdcurtin@pbnlaw.com) Rachel A. Parisi, Esq. (raparisi@pbnlaw.com) Counsel to the Debtors In Re: Garces Restaurant Group, Inc., d/b/a Garces Group, et al., 1 Debtors. Case No.: (JNP) (Jointly Administered) Chapter: 11 Hearing Date and Time: July 9, 2018 at 10:00 a.m. ORDER SHORTENING TIME PERIOD FOR NOTICE, SETTING HEARING AND LIMITING NOTICE The relief set forth on the following pages, numbered two (2) and four (4) is hereby ORDERED. 1 The Debtors in these cases and the last four digits of their employee identification numbers are: GRGAC1, LLC d/b/a Amada (7047); GRGAC2, LLC d/b/a Village Whiskey (7079); GRGAC3, LLC d/b/a Distrito Cantina (7109); GRGAC4, LLC (0542); Garces Restaurant Group, Inc. d/b/a Garces Group (0697); Latin Valley 2130, LLC; La Casa Culinary, LLC d/b/a Amada Restaurant (4127); Garces Catering 300, LLC d/b/a Garces Catering (3791); Latin Quarter Concepts, LLC d/b/a Tinto d/b/a Village Whiskey (0067); UrbanFarm, LLC d/b/a JG Domestic (3014); GR300, LLC d/b/a Volver (0347); GRG2401, LLC (7222); GRGChubb1, LLC (8350); GRGKC1, LLC; GRGWildwood, LLC (9683); and GRGNY2, LLC (0475); GRGDC2, LLC d/b/a Latin Market (8878); GRGBookies, LLC d/b/a The Olde Bar (4779); and GRGAC5,LLC (9937).

4 Proposed Order Page 2 of 4 After review of the application of Garces Restaurant Group, Inc., d/b/a Garces Group, et al. (the "Debtors") for reduction of time for a hearing under Fed. R. Bankr. P. 9006(c)(1) for the following Applications: DEBTORS' MOTION FOR ENTRY OF AN ORDER (I) APPROVING COMPROMISE AND GLOBAL SETTLEMENT UNDER BANKRUPTCY RULE 9019; (II) PROVIDING FOR DISTRIBUTION OF FUNDS; AND (III) GRANTING RELATED RELIEF [ECF No. 364] NOTICE OF PROPOSED COMPROMISE OR SETTLEMENT OF CONTROVERSY RE: COMPROMISE AND GLOBAL SETTLEMENT UNDER BANKRUPTCY RULE 9019 [ECF No. 365] It is hereby, ORDERED as follows: 1. A hearing will be conducted on the above Motion on July, 2018 at :.m., in the United States Bankruptcy Court, Mitchell H. Cohen U.S. Courthouse, 400 Cooper Street, 4 th Floor, Camden, NJ 08101, Courtroom No. 4C. 2. The applicant must serve a copy of this Order, the Motion and all related documents, on the following parties: (i) the Master Service List pursuant to Order Establishing Case Management and Administrative Procedures [Dkt. No. 54] by: each, any of the following methods selected by the Court: fax, overnight mail, regular mail, , hand delivery. 3. The applicant must serve a copy of the Local Form Notice of Proposed Compromise or Settlement of Controversy pursuant to Local Rule that was submitted in connection with the Motion upon all known creditors, on the following parties: all known creditors by: each, any of the following methods selected by the Court: fax, overnight mail, regular mail, , hand delivery. 4. The applicant must also serve a copy of this Order, and all related documents, on the following parties:

5 Proposed Order Page 3 of 4 Page: 3 Debtors: Garces Restaurant Group, Inc., d/b/a Garces Group, et al. Case No.: (JNP) Caption of Order: ORDER SHORTENING TIME PERIOD FOR NOTICE, SETTING HEARING AND LIMITING NOTICE by: each, any of the following methods selected by the Court: fax, overnight mail, regular mail, , hand delivery. 5. Service must be made: on the same day as the date of this order, or within day(s) of the date of this Order. 6. Notice by telephone: is not required must be provided to on the same day as the date of this Order, or within day(s) of the date of this Order. 7. A Certification of Service must be filed prior to the hearing. 8. Any objections to the motion/application identified above: must be filed with the Court and served on all parties in interest by electronic or overnight mail day(s) prior to the scheduled hearing; or may be presented orally at the hearing. 9. Court appearances are required to prosecute said motion/application and any objections. 3

6 Proposed Order Page 4 of 4 Page: 4 Debtors: Garces Restaurant Group, Inc., d/b/a Garces Group, et al. Case No.: (JNP) Caption of Order: ORDER SHORTENING TIME PERIOD FOR NOTICE, SETTING HEARING AND LIMITING NOTICE Parties may request to appear by phone by contacting Chambers prior to the return date. 4