Case MFW Doc 744 Filed 05/11/15 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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1 Case MFW Doc 744 Filed 05/11/15 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Phoenix Payment Systems, Inc., Case No (MFW Reorganized Debtor. Hearing Date: June 16, 10:30 a.m. (EDT Objection Deadline: May 26, 4:00 p.m. (EDT PPSI LIQUIDATING TRUST S MOTION TO EXTEND THE CLAIM OBJECTION DEADLINE PPSI Liquidating Trust (the Trust hereby files this motion (the Motion pursuant to Sections 105 and 502 of the Bankruptcy Code, Bankruptcy Rules 3007 and 9006, and Section 5.9 of the Joint Plan of Reorganization of Phoenix Payment Systems, Inc. Proposed by the Debtor and the Official Committee of Unsecured Creditors [Docket No. 545] (the Plan, 1 for entry of an order, substantially in the form attached hereto as Exhibit A (the Proposed Order, extending the deadline to file objections to the allowance of any claim (the Claim Objection Deadline filed against the estate of Phoenix Payment Systems, Inc. (the Debtor by 120 days through and including September 8, In support of the Motion, the Trust respectfully states as follows: JURISDICTION 1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. 157 and Venue of this case and this Motion in this District is proper under 28 U.S.C and This is a core proceeding under 28 U.S.C. 157(b. The statutory predicates for the relief requested herein are Bankruptcy Code Sections 105 and 502 and Bankruptcy Rules 3007 and The Debtor made non-material modifications to the Plan prior to confirmation. A version of the Plan incorporating these modifications was attached to the order confirming the Plan [Docket No. 654].

2 Case MFW Doc 744 Filed 05/11/15 Page 2 of 5 BACKGROUND 2. On August 4, 2014, the Debtor filed a voluntary chapter 11 petition. On September 23, 2014, the Court entered the Order Establishing the Deadline for filing Proofs of Claim and Poofs of Interest and Approving the Form and Manner of Notice Thereof [Docket No. 250], setting October 24, 2014 at 11:59 p.m. (ET as the deadline to file proofs of claim or interest in this case (the Bar Date. 3. Pursuant to the Plan, the Claim Objection Deadline is the later of 60 days after the Effective Date 2 of the Plan, 60 days after a specific claim is filed, or a later date established by court order. See Plan 1.2(w. The Effective Date of the Plan was March 11, 2015 [Docket No. 672]. Accordingly, the Claim Objection Deadline will expire on May 11, Pursuant to Section 5.9 of the Plan, the right to resolve and/or litigate Disputed Claims (as defined in the Plan vested in the Trust as of the Effective Date. The Plan authorizes the Trust to move to extend the Claim Objection Deadline at any time prior to the expiration of the Claim Objection Deadline. See Plan 1.2(w. RELIEF REQUESTED 5. By this Motion, the Trust seeks entry of an order, pursuant to Section 105 of the Bankruptcy Code, Bankruptcy Rule 9006, and Sections 1.2(w and 5.9 of the Plan extending the Claim Objection Deadline by 120 days through and including September 8, BASIS FOR RELIEF 6. As stated above, the Plan authorizes the Trust, in its discretion, to move to extend the Claim Objection Deadline at any time prior to the expiration of the Claim Objection Deadline. See Plan 1.2(w. In addition, Bankruptcy Rule 9006(b(1 provides that when an act is 2 Capitalized terms used but not otherwise defined shall have the meanings ascribed to them in the Plan. 2

3 Case MFW Doc 744 Filed 05/11/15 Page 3 of 5 required or allowed to be done at or within a specified period... by order of the court, the court for cause shown may at any time in its discretion (1 with or without motion or notice order the period enlarged if the request therefor is made before the expiration of the period originally prescribed.... As discussed below, good and sufficient cause exists to extend the Debtors deadline to file and serve objections to claims. 7. The Debtor, together with its professionals, undertook a comprehensive analysis of all claims filed in the case in order to ascertain claims that may need to be disallowed, reduced, and/or reclassified. As a result of these efforts, the Debtor filed one omnibus claim objection and four individual claim objections. As of the Effective Date, pursuant to Section 5.9 of the Plan, the Trust assumed the responsibility to reconcile claims. It proceeded to settle certain claims and convince other creditors to withdraw claims. While the claims process is nearing completion, the Trust anticipates the need to file at most a few additional claim objections, but does not believe it will be able to do so prior to the expiration of the Claim Objection Deadline. The Trust therefore requests more time to object to claims so that it may continue the claims reconciliation process and preserve value for distribution to stakeholders. 8. For the above reasons, the Trust believes that a 120 day extension of the deadline to file and serve objections to claims, through and including September 8, 2015, is appropriate. Similar relief to that requested herein has been granted in this District. See, e.g., In re QCE Finance, LLC, Case No (LSS (Bankr. D. Del. Mar. 13, 2015 [D.I. 645] (extending claim objection deadline by 120 days; In re Savient Pharmaceuticals, Inc., Case No (MFW (Bankr. D. Del. Mar. 9, 2015 [D.I. 852] (extending claim objection deadline by 122 days; In re EGHI Holdings, Inc., Case No (MFW (Bankr. D. Del. Mar. 3, 2015 [D.I. 2398] (extending claim objection deadline by 122 days; In re Laboratory Partners, Inc., Case No. 3

4 Case MFW Doc 744 Filed 05/11/15 Page 4 of (LSS (Bankr. D. Del. Jan. 28, 2015 [D.I. 777] (extending claim objection deadline by 180 days. 9. This extension is not sought for the purposes of delay and will not prejudice any claimants. The Trust reserves its right to seek a further extension of the time to file and serve objections to claims upon motion filed with the Court. NO PRIOR REQUEST 10. No prior request for the relief requested herein has been made by the Trust to this or any other court. NOTICE 11. Notice of this Motion will be given to: the United States Trustee and all parties that have requested or that are required to receive notice pursuant to Bankruptcy Rule The Trust respectfully submits that no further notice of this Motion is required. 4

5 Case MFW Doc 744 Filed 05/11/15 Page 5 of 5 CONCLUSION WHEREFORE, the Trust respectfully requests that the Court enter an order, substantially in the form annexed hereto as Exhibit A, extending the Claim Objection Deadline through and including September 8, 2015, and granting such other and further relief as the Court deems just and proper. Date: May 11, 2015 Wilmington, Delaware RICHARDS, LAYTON & FINGER, P.A. /s/ Joseph C. Barsalona II Mark D. Collins (No Russell C. Silberglied (No Marisa A. Terranova (No Joseph C. Barsalona II (No N. King Street Wilmington, Delaware Telephone: Facsimile: collins@rlf.com silberglied@rlf.com terranova@rlf.com barsalona@rlf.com Counsel for PPSI Liquidating Trust 5

6 Case MFW Doc Filed 05/11/15 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Phoenix Payment Systems, Inc., Case No (MFW Reorganized Debtor. Hearing Date: June 16, 10:30 a.m. (EDT Objection Deadline: May 26, 4:00 p.m. (EDT NOTICE OF MOTION AND HEARING PLEASE TAKE NOTICE that on May 11, 2015, the PPSI Liquidating Trust (the Trust filed the PPSI Liquidating Trust s Motion to Extend the Claims Objection Deadline (the Motion with the United States Bankruptcy Court for the District of Delaware (the Bankruptcy Court. PLEASE TAKE FURTHER NOTICE that any responses or objections to the Motion must be in writing, filed with the Clerk of the Bankruptcy Court, 824 North Market Street, 3rd Floor, Wilmington, Delaware 19801, and served upon and received by the undersigned counsel for the Trust on or before May 26, 2015 at 4:00 p.m. (prevailing Eastern Time. PLEASE TAKE FURTHER NOTICE that a hearing to consider the Motion, if required, will be held before The Honorable Mary F. Walrath, United States Bankruptcy Judge for the District of Delaware, at the Bankruptcy Court, 824 North Market Street, 5th Floor, Courtroom 4, Wilmington, Delaware on June 16, 2015 at 10:30 a.m. (prevailing Eastern Time. RLF v.1

7 Case MFW Doc Filed 05/11/15 Page 2 of 2 IF NO OBJECTIONS TO THE MOTION ARE TIMELY FILED, SERVED AND RECEIVED IN ACCORDANCE WITH THIS NOTICE, THE BANKRUPTCY COURT MAY GRANT THE RELIEF REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE OR HEARING. Date: May 11, 2015 Wilmington, Delaware RICHARDS, LAYTON & FINGER, P.A. /s/ Joseph C. Barsalona II Mark D. Collins (No Russell C. Silberglied (No Marisa A. Terranova (No Joseph C. Barsalona II (No N. King Street Wilmington, Delaware Telephone: Facsimile: collins@rlf.com silberglied@rlf.com terranova@rlf.com barsalona@rlf.com Counsel for PPSI Liquidating Trust RLF v.1 2

8 Case MFW Doc Filed 05/11/15 Page 1 of 3 EXHIBIT A Proposed Order

9 Case MFW Doc Filed 05/11/15 Page 2 of 3 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Phoenix Payment Systems, Inc., Case No (MFW Reorganized Debtor. Re: Docket No. ORDER EXTENDING THE CLAIM OBJECTION DEADLINE Upon consideration of the motion (the Motion of the PPSI Liquidating Trust (the Trust on behalf of the estate of Phoenix Payment Systems, Inc. (the Debtor, for entry of an order, pursuant to Sections 105(a and 502 of the Bankruptcy Code, Rules 3007 and 9006 of the Federal Rules of Bankruptcy Procedure, and the authority granted in Sections 1.2(w and 5.9 of the Plan, 1 extending the Claim Objection Deadline through and including September 8, 2015, and the Court having reviewed the Motion; and the Court finding that: (a the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and 1334; (b this is a core proceeding pursuant to 28 U.S.C. 157(b(2; and (c due and sufficient notice of the Motion has been given; and after due deliberation and sufficient cause appearing therefor, it is hereby: ORDERED, ADJUDGED AND DECREED that: 1. The Motion is GRANTED. 2. The Claim Objection Deadline is extended through and including September 8, 3. This Order is without prejudice to the rights of the Trust to seek further extensions of the Claim Objection Deadline upon motion filed with the Court. 1 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Motion and the Plan.

10 Case MFW Doc Filed 05/11/15 Page 3 of 3 4. This Court shall retain jurisdiction over all matters arising from or related to the implementation and interpretation of this Order. Dated:, 2015 Wilmington, Delaware THE HONORABLE MARY F. WALRATH UNITED STATES BANKRUPTCY JUDGE 2