Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 1 of 8

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1 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 1 of 8 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION In re: ) Chapter 11 ) ASTROTURF, LLC, ) Case No ) ) Debtor. ) ) DEBTOR S EMERGENCY MOTION FOR AN ORDER SHORTENING NOTICE AND SCHEDULING EXPEDITED HEARING ON FIRST DAY MOTIONS AstroTurf, LLC (the Debtor ) files this Emergency Motion for an Order Shortening Notice and Scheduling Expedited Hearing on First Day Motions (this Motion ). In support of this Motion, the Debtor respectfully represents as follows: JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. 157 and Consideration of this Motion is a core proceeding pursuant to 28 U.S.C. 157(b). Venue of this proceeding is proper before this Court pursuant to 28 U.S.C and The statutory predicate for the relief requested herein is Section 105(a) of title 11 of the United States Code, 11 U.S.C. 101, et seq. (the Bankruptcy Code ), and Rule 9006(c)(1) of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules ).

2 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 2 of 8 BACKGROUND 3. On June 28, 2016 (the Petition Date ), the Debtor filed a voluntary petition with the Court under chapter 11 of the Bankruptcy Code. 4. The factual background relating to the Debtor s commencement of this case is set forth in detail in the Declaration of Sean M. Harding in Support of First Day Motions and Applications filed on the Petition Date and incorporated herein by reference. 5. The Debtor has continued in possession of its properties and has continued to operate and manage its business as a debtor-in-possession pursuant to Sections 1107(a) and 1108 of the Bankruptcy Code. 6. As of the date of this filing, no official committee of unsecured creditors has been appointed in this case, and no request has been made for the appointment of a trustee or examiner. RELIEF REQUESTED 7. By this Motion, the Debtor respectfully requests the entry of an order pursuant to Bankruptcy Code Section 105(a) and Bankruptcy Rule 9006(c)(1), shortening applicable notice periods and scheduling a hearing on an expedited basis to consider the motions scheduled on the attached Exhibit A (the First Day Motions ). The relief requested in these motions is necessary to ensure that there is no interruption in the services being provided by the Debtor and no damage to the Debtor s business or the value of its assets. 8. Accordingly, the Debtor requests that the Court approve notice of the hearing on the First Day Motions as follows: 1 1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the relevant motion. 2

3 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 3 of 8 a. Copies of the order approving this Motion shall be delivered by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail upon the Office of the United States Trustee, Textile Management Associates, Inc., the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, the Debtor s twenty (20) largest unsecured creditors, and counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and to all other parties receiving notice of a First Day Motion as set forth in (b) through (j) below; b. Copies of the Debtor s Emergency Motion for an Order to Extend Time to File Schedules and Statements of Financial Affairs shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; c. Copies of the Debtor s Emergency Motion to Authorize Payment of Pre-Petition Wages, Payroll Taxes, Certain Employee Benefits, and Related Expenses, and Other Compensation to Employees shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, and counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc. by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; d. Copies of the Debtor s Emergency Motion for Authority to Continue Pre-Existing Insurance Programs and to Pay Pre-Petition Premiums and Related Obligations shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton and the Insurance Carriers by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; e. Copies of the Debtor s Emergency Motion for Authority to (A) Maintain Existing Bank Accounts, and (B) Continue Use of Existing Business Forms shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney 3

4 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 4 of 8 for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank Of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; f. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtor to Pay Pre-Petition Sales, Use, Trust Fund, and Other Taxes and Related Obligations shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton, and the Taxing Authorities by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; g. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtors to Maintain and Administer Customer Programs and Honor Certain Pre-Petition Obligations Related Thereto shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; h. Copies of the Debtor s Emergency Motion For Interim and Final Orders (A) Prohibiting Utilities from Altering, Refusing, or Discontinuing Service on Account of Prepetition Invoices, (B) Deeming Utilities Adequately Assured of Future Performance, and (C) Establishing Procedures for Determining Adequate Assurance of Payment shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton, and the Utility Companies by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; i. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtors to Honor Prepetition Obligations to and Continue Prepetition Practices with Shippers and Independent Subcontractors shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., 4

5 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 5 of 8 the Subcontractors and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; and j. Copies of the Debtor s Emergency Motion Pursuant to 11 U.S.C. 105, 361, 362, 363, 364 and 507 for Interim and Final Orders (I) Authorizing Debtor to Obtain Post-Petition Financing from Textile Management Associates, Inc., Pursuant to Section 364 of the Bankruptcy Code; (ii) Granting Liens and Super- Priority Claims; (iii) Modifying the Automatic Stay; and (iv) Scheduling a Final Hearing on the Debtor s Motion to Incur Such Financing on a Permanent Basis and Approving the Form and Method of Notice Thereof shall be served upon parties that have filed a request for special notice with this Court under Bankruptcy Rule 2002, the Office of the United States Trustee, counsel for the DIP Lender, the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, all persons or entities known or reasonably believed to have asserted an interest in the Collateral, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the Debtor s insurance providers by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail. BASIS FOR RELIEF 9. Bankruptcy Rule 9006(c)(1) provides that when an act is required or allowed to be done at or within a specified time..., the court for cause shown may in its discretion with or without motion or notice order the period reduced. 10. Further, Section 105(a) provides that [t]he court may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title. The basic purpose of Section 105(a) is to assure the bankruptcy court s power to take whatever action is appropriate or necessary in aid of the exercise of their jurisdiction. 2 Collier on Bankruptcy (16th ed. 2015). Thus, Section 105(a) essentially codifies the bankruptcy court s inherent equitable powers. See Mgmt. Tech. Corp. v. Pardo (In re Mgmt. Tech. Corp.), 56 B.R. 337, 339 (Bankr. D.N.J. 1985) (holding that a court s equitable power is derived from Section 105). 5

6 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 6 of In order to preserve the assets of the estate and maintain its ongoing business operations, the Debtor requests that this Court shorten applicable notice periods for those motions listed on Exhibit A. To require the Debtor to comply with otherwise applicable notice requirements would cause immeasurable harm to the Debtor s ability to efficiently and effectively manage its operations and would create disruptions in the timely payment of obligations. 12. The Debtor asserts that the relief requested in this Motion is in the best interests of its estate and creditors and will not prejudice the rights of any party in interest in this case. Relief similar to that requested herein has been granted by courts in other substantial chapter 11 cases in this District. See, e.g., In re S. Reg l Health Sys., Inc., Case No (Bankr. N.D. Ga. July 31, 2015) (Hagenau, J.); In re Cagle s, Inc., Case No (Bankr. N.D. Ga. May 11, 2012) (Bihary, J.); In re AtheroGenics, Inc., Case No (Bankr. N.D. Ga. Oct. 7, 2008) (Massey, J.); In re Pike Nursery Holding, LLC, Case No (Bankr. N.D. Ga. Nov. 15, 2007) (Diehl, J.); In re Blue Thunder Auto Transport, Inc., Case No (Bankr. N.D. Ga. Jan. 30, 2007) (Bonapfel, J.); In re Friedman s Inc., Case No (Bankr. S.D. Ga. Jan. 18, 2005) (Davis, J.); In re Rhodes, Inc., Case No (Bankr. N.D. Ga. Nov. 4, 2004) (Diehl, J.); In re Centennial HealthCare Corp., Case No (Bankr. N.D. Ga. Dec. 24, 2002) (Massey, J.). 13. Accordingly, the Debtor respectfully requests an order from this Court shortening applicable notice periods and scheduling a hearing on an expedited basis. NOTICE 14. Notice of this Motion has been provided to the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured 6

7 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 7 of 8 creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and any other party receiving notice of a First Day Motion as referenced above in paragraph 8. In light of the nature of the relief requested, the Debtor submits that no further notice is necessary. CONCLUSION WHEREFORE, the Debtor respectfully requests that this Court: (a) enter an order in the form attached hereto as Exhibit B scheduling an expedited hearing on the First Day Motions identified on the attached Exhibit A; (b) approve the notice procedures requested herein in connection with the first day hearing on the First Day Motions set forth on Exhibit A; and (c) grant the Debtor such other and further relief as is just and proper. 7

8 Case pwb Doc 13 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Main Document Page 8 of 8 Dated: June 28, 2016 Atlanta, Georgia Respectfully submitted, KING & SPALDING LLP /s/ Paul K. Ferdinands Paul K. Ferdinands Georgia Bar No pferdinands@kslaw.com Mark. M. Maloney Georgia Bar No mmaloney@kslaw.com Jeffrey R. Dutson Georgia Bar No jdutson@kslaw.com Karyn D. Heavenrich Georgia Bar No kheavenrich@kslaw.com 1180 Peachtree Street Atlanta, Georgia Telephone: (404) Facsimile: (404) PROPOSED COUNSEL FOR THE DEBTOR-IN-POSSESSION 8

9 Case pwb Doc 13-1 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 1 of 1 EXHIBIT A 1. Debtor s Emergency Motion for an Order Establishing Notice and Administrative Procedures 2. Debtor s Emergency Motion for an Order to Extend Time to File Schedules and Statements of Financial Affairs 3. Debtor s Emergency Motion to Authorize Payment of Pre-Petition Wages, Payroll Taxes, Certain Employee Benefits, and Related Expenses, and Other Compensation to Employees 4. Debtor s Emergency Motion for Authority to Continue Pre-Existing Insurance Programs, and to Pay Pre-Petition Premiums and Related Obligations 5. Debtor s Emergency Motion for Authority to (A) Maintain Existing Bank Accounts, and (B) Continue Use of Existing Business Forms 6. Debtor s Emergency Motion for an Order Authorizing the Debtors to Pay Pre-Petition Sales, Use, Trust Fund, and Other Taxes and Related Obligations 7. Debtor s Emergency Motion for an Order Authorizing the Debtors to Maintain and Administer Customer Programs and Honor Certain Pre-Petition Obligations Related Thereto 8. Debtor s Emergency Motion For Interim and Final Orders (A) Prohibiting Utilities from Altering, Refusing, or Discontinuing Service on Account of Prepetition Invoices, (B) Deeming Utilities Adequately Assured of Future Performance, and (C) Establishing Procedures for Determining Adequate Assurance of Payment 9. Debtor s Emergency Motion for an Order Authorizing the Debtors to Honor Prepetition Obligations to and Continue Prepetition Practices with Shippers and Independent Subontractors 10. Debtor s Emergency Motion Pursuant to 11 U.S.C. 105, 361, 362, 363, 364 and 507 for Interim and Final Orders (I) Authorizing Debtor to Obtain Post-Petition Financing from Textile Management Associates, Inc., Pursuant to Section 364 of the Bankruptcy Code; (ii) Granting Liens and Super-Priority Claims; (iii) Modifying the Automatic Stay; and (iv) Scheduling a Final Hearing on the Debtor s Motion to Incur Such Financing on a Permanent Basis and Approving the Form and Method of Notice Thereof

10 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 1 of 7 EXHIBIT B Proposed Order

11 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 2 of 7 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF GEORGIA ROME DIVISION In re: ) Chapter 11 ) ASTROTURF, LLC, ) Case No ) ) Debtor. ) ) ORDER SHORTENING NOTICE AND SCHEDULING EXPEDITED HEARING ON FIRST DAY MOTIONS This matter is before the Court on the Emergency Motion for an Order Shortening Notice and Scheduling Expedited Hearing on First Day Motions (the Motion ) of AstroTurf, LLC (the Debtor ). All capitalized terms used but not defined herein shall have the meanings given to them in the Motion. The Court has considered the Motion, the Declaration of Sean M. Harding in Support of First Day Motions and Applications, and the other matters reflected in the record. It appears that the Court has jurisdiction over this proceeding; that this is a core proceeding; that notice of the Motion has been given to the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue

12 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 3 of 7 Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and any other parties entitled to notice of the First Day Motions; that no further notice is necessary; that the relief sought in the Motion is in the best interests of the Debtor, its estate, and its creditors; and that good and sufficient cause exists for such relief. Accordingly, it is hereby ORDERED as follows: 1. The Motion (Doc. No. [ ]) is GRANTED. 2. A hearing will be held on the day of 2016 at in Courtroom, United States Courthouse, 600 East First Street, Rome, Georgia on the motions identified in Exhibit A of the Motion. 3. Counsel to the Debtor is directed to serve notice of such hearing as follows: a. Copies of the order approving this Motion shall be delivered by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail upon the Office of the United States Trustee, Textile Management Associates, Inc., the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, the Debtor s twenty (20) largest unsecured creditors, and counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and to all other parties receiving notice of a First Day Motion as set forth in (b) through (j) below; b. Copies of the Debtor s Emergency Motion for an Order to Extend Time to File Schedules and Statements of Financial Affairs shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; c. Copies of the Debtor s Emergency Motion to Authorize Payment of Pre- Petition Wages, Payroll Taxes, Certain Employee Benefits, and Related Expenses, and Other Compensation to Employees shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the 2

13 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 4 of 7 Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, and counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc. by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; d. Copies of the Debtor s Emergency Motion for Authority to Continue Pre- Existing Insurance Programs and to Pay Pre-Petition Premiums and Related Obligations shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton and the Insurance Carriers by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; e. Copies of the Debtor s Emergency Motion for Authority to (A) Maintain Existing Bank Accounts, and (B) Continue Use of Existing Business Forms shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank Of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by nextday United States mail; f. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtor to Pay Pre-Petition Sales, Use, Trust Fund, and Other Taxes and Related Obligations shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton, and the Taxing Authorities by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; g. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtors to Maintain and Administer Customer Programs and Honor Certain Pre-Petition Obligations Related Thereto shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the 3

14 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 5 of 7 Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; h. Copies of the Debtor s Emergency Motion For Interim and Final Orders (A) Prohibiting Utilities from Altering, Refusing, or Discontinuing Service on Account of Prepetition Invoices, (B) Deeming Utilities Adequately Assured of Future Performance, and (C) Establishing Procedures for Determining Adequate Assurance of Payment shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the First Bank of Dalton, and the Utility Companies by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; i. Copies of the Debtor s Emergency Motion for an Order Authorizing the Debtors to Honor Prepetition Obligations to and Continue Prepetition Practices with Shippers and Independent Contractors shall be served upon the Office of the United States Trustee, Textile Management Associates, Inc., the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., the Subcontractors and the First Bank of Dalton by hand delivery, facsimile, electronic mail (if consented to by the recipient), overnight courier (when a street address is available), or by next-day United States mail; and j. Copies of the Debtor s Emergency Motion Pursuant to 11 U.S.C. 105, 361, 362, 363, 364 and 507 for Interim and Final Orders (I) Authorizing Debtor to Obtain Post-Petition Financing from Textile Management Associates, Inc., Pursuant to Section 364 of the Bankruptcy Code; (ii) Granting Liens and Super-Priority Claims; (iii) Modifying the Automatic Stay; and (iv) Scheduling a Final Hearing on the Debtor s Motion to Incur Such Financing on a Permanent Basis and Approving the Form and Method of Notice Thereof shall be served upon parties that have filed a request for special notice with this Court under Bankruptcy Rule 2002, the Office of the United States Trustee, counsel for the DIP Lender, the Debtor s twenty (20) largest unsecured creditors, the Internal Revenue Service, the Attorney General for the State of Georgia, the United States Attorney for the Northern District of Georgia, the First Bank of Dalton, all persons or entities known or reasonably believed to have asserted an interest in the Collateral, counsel to FieldTurf USA, Inc. and FieldTurf Tarkett, Inc., and the Debtor s insurance providers by hand delivery, facsimile, electronic mail (if consented to by the recipient), 4

15 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 6 of 7 overnight courier (when a street address is available), or by next-day United States mail. 4. Counsel to the Debtor shall file a certificate of service with the Clerk of the Court certifying the above-outlined service. 5. The Court shall retain jurisdiction to hear and determine all matters arising from the implementation of this Order. 5

16 Case pwb Doc 13-2 Filed 06/28/16 Entered 06/28/16 11:58:12 Desc Exhibit Page 7 of 7 END OF DOCUMENT Prepared and presented by: KING & SPALDING LLP Paul K. Ferdinands Georgia Bar No pferdinands@kslaw.com Mark. M. Maloney Georgia Bar No mmaloney@kslaw.com Jeffrey R. Dutson Georgia Bar No jdutson@kslaw.com Karyn D. Heavenrich Georgia Bar No kheavenrich@kslaw.com 1180 Peachtree Street Atlanta, Georgia Telephone: (404) Facsimile: (404) PROPOSED COUNSEL FOR THE DEBTOR-IN-POSSESSION 6