Case BLS Doc 675 Filed 12/30/16 Page 1 of 10 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) )

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1 Case BLS Doc 675 Filed 12/30/16 Page 1 of 10 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PHOENIX BRANDS LLC, et al., 1 Debtors. Chapter 11 Case No (BLS (Jointly Administered Objection Deadline: January 13, 2017 at 4:00 p.m. prevailing Eastern time Hearing Date: To be determined SECOND MOTION OF THE DEBTORS FOR ENTRY OF AN ORDER (A ENLARGING THE PERIOD WITHIN WHICH THE DEBTORS MAY REMOVE ACTIONS AND (B GRANTING RELATED RELIEF The above-captioned debtors and debtors in possession (collectively, the Debtors file this motion (this Motion for entry of an order, substantially in the form attached hereto as Exhibit A: (a further enlarging the period within which the Debtors may remove actions (collectively, the Actions pursuant to 28 U.S.C and Rule 9027 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules by 180 days up to and including June 30, 2017, without prejudice to the Debtors right to seek additional extensions, and (b granting related relief. In support of this Motion, the Debtors respectfully state as follows: Jurisdiction 1. The United States Bankruptcy Court for the District of Delaware (the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334 and the 1 The Debtors, together with the last four digits of each Debtor s tax identification number, are: Phoenix Brands LLC, (4609, Phoenix Brands Parent LLC, (8729, Phoenix North LLC, (no EIN, Phoenix Brands Canada ULC (a Nova Scotia Company, Phoenix RIT LLC, (5149, and Phoenix Brands Canada Laundry LLC (no EIN. The address of each of the Debtors is 1 Landmark Square, Suite 1810, Stamford, CT 06901, except Phoenix Brands Canada ULC, which is Box 50, 1 First Canadian Place, Toronto, Ontario, Canada M5X 1B8.

2 Case BLS Doc 675 Filed 12/30/16 Page 2 of 10 Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated February 29, This matter is a core proceeding within the meaning of 28 U.S.C. 157(b(2, and the Debtors confirm their consent pursuant to Rule (f of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the Local Rules to the entry of a final order by the Court in connection with this Motion to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments in connection herewith consistent with Article III of the United States Constitution. 2. Venue is proper pursuant to 28 U.S.C and The statutory bases for the relief requested herein are section 1452 of title 28 of the United States Code (the Bankruptcy Code, Rules 9006 and 9027 of the Bankruptcy Rules, and Rule of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the Local Rules. Relief Requested 4. The Debtors seek entry of an order: (a further enlarging the period of time set forth in Bankruptcy Rule 9027(a(2(A during which the Debtors may seek removal of the Actions pursuant to 28 U.S.C and Bankruptcy Rule 9027 (the Removal Period by 180 days through and including June 30, 2017, without prejudice to the Debtors right to seek further extensions, and (b granting related relief. Background 5. On May 19, 2016, Debtors Phoenix Brands, LLC, Phoenix Brands Parent, LLC, Phoenix North, LLC, and Phoenix Canada ULC (together, the Original Debtors each commenced a case by filing a voluntary petition for relief under chapter 11 of the Bankruptcy Code. On June 1, 2016, Debtor Phoenix Rit LLC filed its voluntary petition for relief. On June 2

3 Case BLS Doc 675 Filed 12/30/16 Page 3 of 10 17, 2016, Debtor Phoenix Canada Brands Laundry LLC ( Phoenix Canada filed its voluntary petition for relief. The Original Debtors, together with Phoenix Rit LLC and Phoenix Canada, are collectively referred to as the Debtors. The date each of the Debtors commenced its respective case is referred to as that Debtor s Petition Date. The Debtors are continuing in possession of their properties and are managing their businesses, as debtors in possession, pursuant to sections 1107(a and 1108 of the Bankruptcy Code. 6. On June 1, 2016, the United States Trustee for the District of Delaware appointed an official committee of unsecured creditors (the Committee for the Original Debtors. No trustee or examiner has been appointed in the Debtors cases. 7. The Debtors source, manufacture, and distribute laundry detergent and fabric care products throughout North America, selling wholesale to regional and national retailers located within the United States and Canada. The Debtors do not have any direct to consumer retail program. The Debtors brands are Rit dye, Final Touch fabric softener, laundry detergent and fabric care brands: Fab, Dynamo, Ajax Laundry Detergent, Fresh Start, Cold Power, Arctic Power, and ABC (the Brands. These chapter 11 cases were filed, in part, to effect the sale of these Brands. 8. On July 18, 2016, the Court entered three orders approving three sales of the Brands [Docket Nos. 283, 284, & 285]. As part of these sales, the Debtors entered into a transition services agreement (each, a TSA with each of the purchasers. The TSAs have since ended. 9. On August 17, 2016, the Debtors filed the Motion of the Debtors for Entry of an Order (A Enlarging the Period Within Which the Debtors May Remove Actions and (B Granting Related Relief [Docket No. 346]. On September 6, 2016, the Court entered the Order 3

4 Case BLS Doc 675 Filed 12/30/16 Page 4 of 10 (A Enlarging the Period Within Which the Debtors May Remove Actions and (B Granting Related Relief [Docket No. 403], extending the removal period through and including December 31, On December 19, 2016, the Court entered the Order Granting Final Approval of Disclosure Statement and Confirming Joint Plan of Liquidation of the Debtors and the Official Committee of Unsecured Creditors Under Chapter 11 of the Bankruptcy Code [Docket No. 645] (the Confirmation Order, confirming the Joint Plan of Liquidation of the Debtors and the Official Committee of Unsecured Creditors Under Chapter 11 of the Bankruptcy Code [Docket No. 645, Ex. A] (the Plan of Liquidation. 11. On December 27, 2016, the Plan of Liquidation went effective. See Notice of (I Entry of Order Confirming, and Occurrence of Effective Date Of, Joint Plan of Liquidation of the Debtors and The Official Committee of Unsecured Creditors Under Chapter 11 of the Bankruptcy Code; (II Establishing Bar Dates for Administrative Claims and Rejection Claims; and (III Certain Releases and Injunction Thereunder [Docket No. 656] (the Effective Date Notice. 12. Additional information regarding the Debtors and these cases, including the Debtors businesses, corporate structure, financial condition, and the reasons for and objectives of these cases, are set forth in the Declaration of William Littlefield in Support of First Day Pleadings [Docket No. 3] (the First Day Declaration, filed on the Petition Date of the Original Debtors, the Declaration of Peter A. Furman in Support of Phoenix Rit Motions [Docket No. 96] (the Phoenix Rit Declaration filed on June 1, 2016, and the Declaration of Peter A. Furman in Support of Phoenix Brands Canada Laundry LLC Motions [Docket No. 211] (the 4

5 Case BLS Doc 675 Filed 12/30/16 Page 5 of 10 Canada Laundry Declaration filed on June 20, The First Day Declaration, Phoenix Rit Declaration, and the Canada Laundry Declaration are fully incorporated herein by reference. The Actions 13. The Debtors are not currently aware of any pending Actions. However, out of an abundance of caution, the Debtors are seeking to extend the removal period. The Debtors may discover additional actions as they move through the post-confirmation claims reconciliation process. The Debtors also may become aware of Actions in connection with proofs of claim that have been filed in these chapter 11 cases. The Debtors will continue to analyze any potential Actions, as well as any filed proofs of claim, to determine whether the Debtors will seek to remove any Actions. Consequently, the Debtors are not yet prepared to determine if they will need to remove any Actions. Basis for Relief 14. Section 1452 of title 28 of the United States Code and Bankruptcy Rule 9027 govern the removal of pending civil actions related to chapter 11 cases. Specifically, section 1452(a provides: A party may remove any claim or cause of action in a civil action other than a proceeding before the United States Tax Court or a civil action by a governmental unit to enforce such governmental unit s police or regulatory power, to the district court for the district where such civil action is pending, if such district court has jurisdiction of such claim or cause of action under section 1334 of this title. 28 U.S.C. 1452(a. 15. Bankruptcy Rule 9027 sets forth the time periods for filing notices to remove claims or causes of action. Specifically, Bankruptcy Rule 9027(a(2 provides, in pertinent part: If the claim or cause of action in a civil action is pending when a case under the [Bankruptcy] Code is commenced, a notice of removal may be filed only within the longest of (A 90 days after the order for relief in the case under the 5

6 Case BLS Doc 675 Filed 12/30/16 Page 6 of 10 [Bankruptcy] Code, (B 30 days after entry of an order terminating a stay, if the claim or cause of action in a civil action has been stayed under 362 of the [Bankruptcy] Code, or (C 30 days after a trustee qualifies in a chapter 11 reorganization case but not later than 180 days after the order for relief. Fed. R. Bankr. P. 9027(a( Bankruptcy Rule 9006 permits the Court to extend the period to remove actions provided by Bankruptcy Rule Specifically, Bankruptcy Rule 9006(b(1 provides, in pertinent part: [W]hen an act is required or allowed to be done at or within a specified period by these rules or by a notice given thereunder or by order of court, the court for cause shown may at any time in its discretion... with or without motion or notice order the period enlarged if the request therefor is made before the expiration of the period originally prescribed or as extended by a previous order.... Fed. R. Bankr. P. 9006(b( It is well-settled that the Court is authorized to enlarge the Removal Period. See Pacor, Inc. v. Higgins, 743 F.2d 984, 996 n.17 (3d Cir. 1984, overruled on other grounds by Things Remembered, Inc. v. Petrarca, 516 U.S. 124, (1995 (holding the bankruptcy court s power to grant an extension of the removal period pursuant to Bankruptcy Rule 9006(b is clear ; Caperton v. A.T. Massey Coal Co., 251 B.R. 322, 325 (S.D.W. Va. 2000; (Bankruptcy Rule 9006 provides authority to enlarge time periods for removing actions under Bankruptcy Rule 9027; In re Jandous Elec. Constr. Corp., 106 B.R. 48, 50 (Bankr. S.D.N.Y (period in which to file motion to remove may be expanded pursuant to Bankruptcy Rule 9006; In re World Fin. Servs. Ctr., Inc., 81 B.R. 33, 39 (Bankr. S.D. Cal (United States Supreme Court intended to give bankruptcy judges the power to enlarge the filing periods under Bankruptcy Rule 9027(a pursuant to Bankruptcy Rule 9006(b; Raff v. Gordon, 58 B.R. 988, 990 (E.D. Pa (an expansion of time to file notices of removal is authorized under the Bankruptcy Rules. 6

7 Case BLS Doc 675 Filed 12/30/16 Page 7 of Absent the relief requested herein, the Removal Period will otherwise expire after December 31, The Liquidating Trust (as defined in the Plan of Liquidation was established on December 27, 2016 and consists of all assets of the Debtors bankruptcy estates as of the Effective Date. Effective Date Notice; Plan of Liquidation at Section VIII. Joseph T. Moldovan, Esq., was appointed as the Liquidating Trustee by Fifth Street in consultation with the Debtors and the Committee. Confirmation Order at 24. The Liquidating Trustee (as defined in the Plan of Liquidation is responsible for, among other things: (i settling, resolving, and objecting to claims, including potential Actions; (ii making distributions under the Plan of Liquidation; and (iii winding up the affairs of the Debtors and their estates. Plan of Liquidation at Section VIII. The Liquidating Trustee should have the option of removal reserved so that he may appropriately manage any potential Actions. The Debtors and Liquidating Trustee will need additional time to analyze any potential Actions because the Liquidating Trustee was appointed and the Liquidating Trust was established on December 27, The Debtors and the Liquidating Trustee s decision regarding whether to seek removal of any potential Action depends on a number of factors, including: (a the importance of the Action to the expeditious resolution of these chapter 11 cases; (b the time required to complete the Action in its current venue; (c the presence of federal subject matter jurisdiction in the proceeding that may allow for one or more aspects thereof to be heard by a federal court; (d the relationship between the Action and matters to be considered in connection with the Debtors chapter 11 cases, the claims allowance process, and the assumption or rejection 2 The Debtors note that they have filed this Motion prior to the expiration of the current deadline for the Removal Period. Pursuant to Local Rule , if a motion to extend the time to take any action is filed before the expiration of the period prescribed by the [Bankruptcy] Code, the [Bankruptcy Rules], these Local Rules or Court order, the time shall automatically be extended until the Court acts on the motion, without the necessity for the entry of a bridge order. Accordingly, Local Rule automatically extends the Removal Period pending the Court s hearing to consider the relief requested by this Motion. 7

8 Case BLS Doc 675 Filed 12/30/16 Page 8 of 10 of executory contracts and unexpired leases; and (e the progress made to date in the Action. To make the appropriate determination, the Debtors must analyze any potential Action in light of such factors. 20. To date, the Debtors are not aware of any pending Actions; however, out of an abundance of caution, and in the event that an Action is uncovered, the Debtors and the Liquidating Trustee need additional time to conclusively determine whether such Actions will be removed. Debtors may become aware of Actions in connection with proofs of claim that were filed in these chapter 11 cases, as the Debtors have not yet had a chance to fully review all filed proofs of claims. As such, given the tenor of these cases, the Debtors have not had either the time or the opportunity to make the appropriate determinations concerning the removal of any discovered Action. 21. The Debtors and the Liquidating Trustee believe that it is prudent to seek an additional extension of the time period to file notices of removal in order to protect the Liquidating Trustee s right to remove the Actions. Debtors hereby request that the Court extend the Removal Period through June 30, 2017, to preserve any rights in the event that the Debtors are required to remove any Actions that may be filed or discovered before the completion of the distribution process in this chapter 11 case. 22. Alternately, if such an extension is not granted, Debtors believe they will not have sufficient time to uncover and properly evaluate removal of any potential Action. Moreover, the rights of parties to the potential Actions will not be unduly prejudiced by the Debtors requested extension of the Removal Period. If the Debtors ultimately seek to remove Actions pursuant to Bankruptcy Rule 9027, parties will retain their rights to have such Actions 8

9 Case BLS Doc 675 Filed 12/30/16 Page 9 of 10 remanded pursuant to 28 U.S.C. 1452(b. Accordingly, the Debtors submit that cause exists for the relief requested herein. 23. Courts in this district have regularly granted the relief requested herein in other chapter 11 cases. See, e.g., In re American Apparel, Inc. No (BLS (Bankr. D. Del. Oct. 21, 2016 (granting 120-day extension without prejudice to the debtors ability to seek further extensions; In re Horsehead Holding Corp., No (CSS (Bankr. D. Del. Sept. 19, 2016 (same; In re Quicksilver Inc., No (LSS (Bankr. D. Del. Jun. 8, 2015 (granting 180-day extension without prejudice to debtors right to seek further extensions; In re Variant Holding Company, LLC, Case No (BLS (Bankr. D. Del. Dec. 2, 2014 (same. The extension requested herein is consistent with the extensions granted by this and other courts in this District under similar circumstances. Accordingly, the Debtors requested extension is reasonable. Notice 24. 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 Madison Capital Funding, Agent for the Debtors senior credit facility; (c Fifth Street Asset Management Inc., a holder of the Debtors senior debt and of the Debtors subordinated debt; (d the Official Committee of Unsecured Creditors; and (e any party filing a notice of appearance and request for service of papers. The Debtors submits that, in light of the nature of the relief requested, no other or further notice need be given. No Prior Request 25. No prior motion for the relief requested herein has been made to this or any other court. 9

10 Case BLS Doc 675 Filed 12/30/16 Page 10 of 10 WHEREFORE, for the reasons set forth herein, the Debtors respectfully request that the Court enter the proposed Order, substantially in the form attached hereto as Exhibit A, granting the relief requested herein, and for such other and further relief as the Court deems appropriate. Dated: December 30, 2016 PACHULSKI STANG ZIEHL & JONES LLP /s/ Joseph M. Mulvihill Laura Davis Jones (No Joseph M. Mulvihill (No North Market Street, 17th Floor PO Box 8705 Wilmington, Delaware Phone: ( Fax: ( and- MORRISON COHEN LLP Joseph T. Moldovan (Admitted Pro Hac Vice Robert K. Dakis (Admitted Pro Hac Vice 909 Third Avenue New York, NY Telephone: ( Facsimile: ( Attorneys for Debtors and Debtors-in-Possession 10

11 Case BLS Doc Filed 12/30/16 Page 1 of 3 In re: PHOENIX BRANDS LLC, et al., 1 Debtors. IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE Chapter 11 Case No (BLS (Jointly Administered Objection Deadline: January 13, 2017 at 4:00 p.m. prevailing Eastern time Hearing Date: To be determined NOTICE OF SECOND MOTION OF THE DEBTORS FOR ENTRY OF AN ORDER (A ENLARGING THE PERIOD WITHIN WHICH THE DEBTORS MAY REMOVE ACTIONS AND (B GRANTING RELATED RELIEF TO: (a the Office of the United States Trustee for the District of Delaware; (b Madison Capital Funding, Agent for the Debtors senior credit facility; (c Fifth Street Asset Management Inc., a holder of the Debtors senior debt and of the Debtors subordinated debt; (d the Official Committee of Unsecured Creditors; and (e any party filing a notice of appearance and request for service of papers. PLEASE TAKE NOTICE THAT on the date hereof, the above-captioned debtors and debtors in possession (collectively, the Debtors filed the Second Motion of the Debtors for Entry of an Order (A Enlarging the Period Within Which the Debtors May Remove Actions and (B Granting Related Relief (the Motion with the United States Bankruptcy Court for the District of Delaware, 824 Market Street, Wilmington, Delaware (the Bankruptcy Court. A copy of the Motion is attached hereto. 1 The Debtors, together with the last four digits of each Debtor s tax identification number, are: Phoenix Brands LLC, (4609, Phoenix Brands Parent LLC, (8729, Phoenix North LLC, (no EIN, Phoenix Brands Canada ULC (a Nova Scotia Company, Phoenix RIT LLC, (5149, and Phoenix Brands Canada Laundry LLC (no EIN. The address of each of the Debtors is 1 Landmark Square, Suite 1810, Stamford, CT 06901, except Phoenix Brands Canada ULC, which is Box 50, 1 First Canadian Place, Toronto, Ontario, Canada M5X 1B8.

12 Case BLS Doc Filed 12/30/16 Page 2 of 3 PLEASE TAKE FURTHER NOTICE that any response or objection to the entry of an order with respect to the relief sought in the Motion must be filed with the Bankruptcy Court on or before January 13, 2017 at 4:00 p.m. prevailing Eastern time. PLEASE TAKE FURTHER NOTICE that at the same time, you must also serve a copy of the response or objection upon: (a counsel to the Debtors: Morrison Cohen LLP, 909 Third Avenue, New York, NY (Attn: Joseph T. Moldovan (bankruptcy@morrisoncohen.com, and Pachulski Stang Ziehl & Jones LLP, 919 North Market Street, 17th Floor, Wilmington DE (Attn: Laura Davis Jones (ljones@pszjlaw.com; (b counsel to Madison Capital Funding, Agent for the Debtors senior credit facility: Goldberg Kohn Ltd., 55 East Monroe, Suite 3300, Chicago, IL (Attn: Dimitri Karcazes (dimitri.karcazes@goldbergkohn.com, and Morris, Nichols, Arsht & Tunnell LLP, 1201 North Market Street, 16th Floor, P.O. Box 1347, Wilmington, DE (Attn: Robert Dehney (rdehney@mnat.com; (c the Office of the United States Trustee (the U.S. Trustee : U.S. Trustee, 844 King Street, Suite 2207, Lockbox #35, Wilmington, Delaware, (Fax: (Attn: Hannah McCollum (Hannah.McCollum@usdoj.gov; and (d counsel to the official committee of unsecured creditors: Saul Ewing, LLP, One Riverfront Plaza, 1037 Raymond Boulevard, Suite Newark, NJ (Attn: Sharon L. Levine (slevine@saul.com, and 1201 North Market Street, Suite 2300, Wilmington, DE (Attn: Mark Minuti, Esq. and Lucian Murley, Esq. (lmurley@saul.com. PLEASE TAKE FURTHER NOTICE THAT IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF DEMANDED BY THE APPLICATION WITHOUT FURTHER NOTICE OR HEARING. DOCS_DE: /001 2

13 Case BLS Doc Filed 12/30/16 Page 3 of 3 PLEASE TAKE FURTHER NOTICE THAT A HEARING TO CONSIDER APPROVAL OF THE MOTION WILL BE HELD AT A DATE AND TIME TO BE DETERMINED BEFORE THE HONORABLE BRENDAN L. SHANNON, CHIEF UNITED STATES BANKRUPTCY JUDGE, AT THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE, 824 MARKET STREET, SIXTH FLOOR, COURTROOM 1, WILMINGTON, DELAWARE Dated: December 30, 2016 PACHULSKI STANG ZIEHL & JONES LLP /s/ Joseph M. Mulvihill Laura Davis Jones (No Joseph M. Mulvihill (No North Market Street, 17th Floor PO Box 8705 Wilmington, Delaware Phone: ( Fax: ( ljones@pszjlaw.com jmulvihill@pszjlaw.com -and- MORRISON COHEN LLP Joseph T. Moldovan (Admitted Pro Hac Vice Robert K. Dakis (Admitted Pro Hac Vice 909 Third Avenue New York, NY Telephone: ( Facsimile: ( bankruptcy@morrisoncohen.com rdakis@morrisoncohen.com Attorneys for Debtors and Debtors-in-Possession DOCS_DE: /001 3

14 Case BLS Doc Filed 12/30/16 Page 1 of 3 EXHIBIT A Proposed Order DOCS_DE: /001

15 Case BLS Doc Filed 12/30/16 Page 2 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: PHOENIX BRANDS LLC, et al., 1 Debtors. Chapter 11 Case No (BLS (Jointly Administered Docket Ref. No. SECOND ORDER (A ENLARGING THE PERIOD WITHIN WHICH THE DEBTORS MAY REMOVE ACTIONS AND (B GRANTING RELATED RELIEF Upon consideration of the motion (the Motion 2 of the above-captioned debtors (collectively, the Debtors for entry of an order: (a further enlarging the Removal Period for filing notices of removal of the Actions up to and including June 30, 2017, without prejudice to the Debtors right to seek further extensions; and (b granting related relief, all as more fully set forth in the Motion; and this Court having jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334 and the Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated February 29, 2012; and this Court having found that this is a core proceeding pursuant to 28 U.S.C. 157(b(2, and that this Court may enter a final order consistent with Article III of the United States Constitution; and this Court having found that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C and 1409; and this Court having found that the relief requested in the Motion is in the 1 The Debtors, together with the last four digits of each Debtor s tax identification number, are: Phoenix Brands LLC, (4609, Phoenix Brands Parent LLC, (8729, Phoenix North LLC, (no EIN, Phoenix Brands Canada ULC (a Nova Scotia Company, Phoenix RIT LLC, (5149, and Phoenix Brands Canada Laundry LLC (no EIN. The address of each of the Debtors is 1 Landmark Square, Suite 1810, Stamford, CT 06901, except Phoenix Brands Canada ULC, which is Box 50, 1 First Canadian Place, Toronto, Ontario, Canada M5X 1B8. 2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion. DOCS_DE: /001

16 Case BLS Doc Filed 12/30/16 Page 3 of 3 best interests of the Debtors estates, their creditors, and other parties in interest; and this Court having found that notice of and opportunity for a hearing on the Motion were appropriate and no other notice need be provided; and this Court having determined that the legal and factual bases set forth in the Motion establish just cause for the relief granted herein; and upon all of the proceedings had before this Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT: 1. The Motion is GRANTED as set forth herein. 2. The period within which the Debtors may seek removal of the Actions pursuant to 28 U.S.C and Bankruptcy Rule 9027 is enlarged through and including June 30, 2017, without prejudice to the Debtors right to seek further extensions. 3. All time periods set forth in this Order shall be calculated in accordance with Bankruptcy Rule 9006(a. 4. The Debtors are authorized to take all actions necessary to effectuate the relief granted in this Order in accordance with the Motion. 5. This Court retains jurisdiction with respect to all matters arising from or related to the implementation, interpretation, and enforcement of this Order. Date:, 2017 The Honorable Brendan L. Shannon Chief United States Bankruptcy Judge DOCS_DE: /001 2