Case Doc 239 Filed 04/05/12 Entered 04/05/12 12:20:20 Desc Main Document Page 1 of 5

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1 Document Page 1 of 5 UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In Re: HARTFORD COMPUTER HARDWARE, INC., et al., 1 Debtor. Chapter 11 Hon. Pamela S. Hollis Case No. 11 B (PSH (Jointly Administered TO: ALL COUNSEL OF RECORD NOTICE OF MOTION PLEASE TAKE NOTICE that on April 10, 2012 at 10:00 a.m. before the Honorable Pamela S. Hollis, or any other judge sitting in her stead, in Courtroom 644, 219 South Dearborn Street, Chicago, Illinois we shall present for hearing, Agreed Motion to Extend Investigation Period, a true and correct copy of which is hereby served upon you. Dated: April 5, 2012 LEVENFELD PEARLSTEIN, LLC /s/elizabeth B. Vandesteeg Elizabeth B. Vandesteeg, ARDC# LEVENFELD PEARLSTEIN, LLC 2 N. LaSalle Street, Ste Chicago, IL Tel: Fax: evandesteeg@lplegal.com 1 The Debtors are Hartford Computer Hardware, Inc., and its affiliated entities Nexicore Services, LLC, Hartford Computer Group, Inc., and Hartford Computer Government, Inc. (the Affiliates. Capitalized terms used herein and not otherwise defined shall have the meaning set forth in the Declaration of Brian Mittman (the Mittman Decl. at Docket No. 9 in these jointly administered cases. LP \

2 Document Page 2 of 5 CERTIFICATE OF SERVICE I, Elizabeth B. Vandesteeg, an attorney, hereby certify that on April 5, 2012, I electronically filed the Agreed Motion to Extend Discovery Period with the Clerk of the Court using the CM/ECF system and served a copy to all counsel via the CM/ECF SYSTEM. /s/elizabeth B. Vandesteeg Elizabeth B. Vandesteeg (ARDC No LEVENFELD PEARLSTEIN, LLC 2 North LaSalle Street, Suite 1300 Chicago, Illinois ( ( (Facsimile 2

3 Document Page 3 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: Chapter 11 Case No. 11 B (PSH HARTFORD COMPUTER HARDWARE, (Jointly Administered INC., et al., 1 Hon. Pamela S. Hollis Debtors. AGREED MOTION TO EXTEND INVESTIGATION PERIOD The Official Committee of Unsecured Creditors (the Committee appointed in the chapter 11 cases of the above-captioned debtors (collectively, the Debtors, moves for a (45 day extension of the deadline to file any challenge to the amount, validity, or enforceability of the prepetition claims of the Debtors secured lender, Delaware Street Capital ( DSC or to assert any other causes of action against DSC, (the Motion. In support of this Motion, the Committee respectfully states as follows: INTRODUCTION The Committee is in the process of investigation is in the process of investigating the amount, validity, or enforceability of DSC s prepetition claims, as well as investigating and analyzing whether there are any avoidance action or other causes of action that could be asserted on behalf of the Debtors estates against DSC (the Investigation. BASIS FOR RELIEF SOUGHT 1 The Debtors are Hartford Computer Hardware, Inc. ( HCH, and its affiliated entities Nexicore Services, LLC ( Nexicore, Hartford Computer Group, Inc. ( HCG, and Hartford Computer Government, Inc. ( HCGovernment. LP \

4 Document Page 4 of 5 1. The Court has jurisdiction to determine this matter as a core proceeding pursuant to 28 U.S.C. 157 and Venue is proper pursuant to 28 U.S.C and On January 26, 2012, the Court entered an Order authorizing the Debtors to obtain post-petition financing (the DIP Order. [Dkt. #137.] 3. Among other things, the DIP Order requires that the Investigation be completed and any Challenges 2 be asserted through the filing of an adversary complaint or contested matter within no later than 90 days following the entry of the DIP Order, or by April 25, 2012, unless extended by agreement of DSC or by order of the Court for cause Despite diligently working with DSC, the Debtors, and the various individuals, document productions are not yet complete. Consequently, no depositions have yet taken place. 5. Based upon the amount of work yet remaining, the Committee will be unable to complete the Investigation prior to the current April 25 th Deadline, and seeks an extension of the Investigation Deadline to June 11, DSC and the Debtor are agreeable to this extension of time. 6. The Committee reserves its right to seek further extensions of the Investigation Deadline as may be necessary or appropriate; DSC has advised the Committee that it does not object to such reservation. WHEREFORE, the Committee respectfully requests that the Court enter an order extending the deadline to raise any Challenges regarding the amount, validity, or enforceability of DSC s prepetition claims, or any other avoidance action or other causes of action that may be 2 Any capitalized terms not defined elsewhere herein shall be given the meanings set forth in the DIP Order. 3 The DIP Order further deemed that the Committee had the standing to pursue the Investigation. 2

5 Document Page 5 of 5 asserted against DSC, from April 25, 2012 to June 11, 2012, and granting such other and further relief as is just and proper. Dated: April 5, 2012 THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS By: /s/ Elizabeth B. Vandesteeg Jonathan P. Friedland (ARDC # Steven R. Jakubowski (ARDC # Elizabeth B. Vandesteeg (ARDC # Levenfeld Pearlstein, LLC 2 North LaSalle, Suite 1300 Chicago, IL T: F: jfriedland@lplegal.com sjakubowski@lplegal.com evandesteeg@lplegal.com Counsel for the Committee 3

6 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS Eastern Division In Re: BK No.: HARTFORD COMPUTER HARDWARE, (Jointly Administered INC., et al. Chapter: 11 Honorable Pamela S. Hollis Debtor(s ORDER APPROVING AGREED MOTION TO EXTEND INVESTIGATION PERIOD This matter comes before the Court on the parties Agreed Motion to Extend the Investigation Period. IT IS HEREBY ORDERED that the motion is GRANTED. The deadline to raise any Challenges regarding the amount, validity, or enforceability of DSC s prepetition claims, or any other avoidance action or other causes of action that may be asserted against DSC, is extended from April 25, 2012 to June 11, Enter: Dated: Honorable Pamela S. Hollis United States Bankruptcy Judge Prepared by: Jonathan P. Friedland Elizabeth B. Vandesteeg Levenfeld Pearlstein, LLC 2 North LaSalle St., Suite 1300 Chicago, IL Rev: _bko