Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 1 of 5

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1 Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 1 of 5 State Bar No IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: TPP ACQUISITION, INC. d/b/a The Picture People, Debtor. Chapter 11 Case No hdh-11 DEBTOR S MOTION FOR AN EXPEDITED HEARING ON DEBTOR S MOTION FOR ENTRY OF ORDER PURSUANT TO 11 U.S.C. 105(a) AND 363(b) AUTHORIZING AND APPROVING DEBTOR S (I) RETENTION AND EMPLOYMENT OF PHEASANT HILL PARTNERS, INC. AND (II) EMPLOYMENT OF IAN GOMAR AS CHIEF EXECUTIVE OFFICER TPP Acquisition, Inc. d/b/a The Picture People (the Debtor ), debtor-in-possession in the above-referenced chapter 11 case, hereby files this motion requesting a hearing on an expedited basis (the Motion to Expedite ) to consider the Motion for Entry of Order Pursuant to 11 U.S.C. 105(a) and 363(b) Authorizing and Approving Debtor s (I) Retention and Employment of Pheasant Hill Partners, Inc. and (II) Employment of Ian Gomar as Chief Executive Officer [Docket No. 206] (the Gomar Retention Motion ) _1

2 Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 2 of 5 1. Through this Motion to Expedite, TPP requests that the Court consider approval of the Gomar Retention Motion on an expedited basis at the omnibus hearing scheduled for Thursday, October 13, 2016 at 3:00 p.m. 2. Expedited consideration of the Gomar Retention Motion is requested because Pheasant Hill Partners, Inc. and Mr. Gomar have already been providing services to the Debtor and the Debtor desires to compensate them for their services. Additionally, an omnibus hearing in this case been scheduled for Thursday, October 13 at 3:00 p.m. and several other professional retention applications have been set for that date. 3. Notice of the proposed expedited hearing will be provided to: (i) the Office of the United States Trustee; (ii) the Debtor and its counsel; (iii) the Debtor s secured creditors; (iv) those persons who have formally appeared and requested notice and service in these proceedings pursuant to Bankruptcy Rules 2002 and 3017; (v) counsel for and the members of the Committee; and (vi) all governmental agencies having a regulatory or statutory interest in this case. No other or further notice need be provided. WHEREFORE the Debtor respectfully requests that the Court (i) grant the Motion to Expedite and (ii) grant such other and further relief as is just and proper _1 2

3 Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 3 of 5 RESPECTFULLY SUBMITTED this 5th day of October, By: /s/ State Bar No CERTIFICATE OF CONFERENCE The undersigned hereby certifies that on October 4, 2016 counsel for the Debtor contacted the Office of the United States Trustee regarding the relief requested in the Motion to Expedite. The Office of the United States Trustee has confirmed that it does not oppose an expedited setting on October 13, /s/ Jarom Yates Jarom Yates _1 3

4 Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 4 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: TPP ACQUISITION, INC. d/b/a The Picture People, Debtor. Chapter 11 Case No hdh-11 ORDER ON DEBTOR S MOTION FOR AN EXPEDITED HEARING ON DEBTOR S MOTION FOR ENTRY OF ORDER PURSUANT TO 11 U.S.C. 105(a) AND 363(b) AUTHORIZING AND APPROVING DEBTOR S (I) RETENTION AND EMPLOYMENT OF PHEASANT HILL PARTNERS, INC. AND (II) EMPLOYMENT OF IAN GOMAR AS CHIEF EXECUTIVE OFFICER The Debtor s Motion for an Expedited Hearing on Motion for Entry of Order Pursuant to 11 U.S.C. 105(a) and 363(b) Authorizing and Approving Debtor s (I) Retention and Employment of Pheasant Hill Partners, Inc. and (II) Employment of Ian Gomar as Chief Executive Officer (the Gomar Retention Motion ) is GRANTED. A hearing on the Gomar Retention Motion will be held on Thursday, October 13, 2016 at 3:00 p.m. Central Time before the Honorable Judge Harlin D. Hale, Earl Cabell Federal Building, 1100 Commerce Street, 14th Floor, Courtroom No. 3, Dallas, Texas Debtor shall serve this Order on interested parties. # # # END OF ORDER # # # _1

5 Case hdh11 Doc 213 Filed 10/05/16 Entered 10/05/16 13:40:59 Page 5 of 5 Submitted by: State Bar No _1 2