Case 1:15-bk-10003-MFW Doc 848 Filed 01/09/17 Entered 01/09/17 16:22:41 Desc Main Document Page 1 of 2 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS BANKRUPTCY DIVISION ST. CROIX, VIRGIN ISLANDS In re: HOVENSA L.L.C., Debtor. Chapter 11 Case No. 1:15-bk-10003-MFW Re: Docket No. 598 NOTICE OF FILING OF STIPULATION REGARDING MOTION FOR RELIEF FROM THE AUTOMATIC STAY PLEASE TAKE NOTICE that on February 8, 2016, Rolly Soogrim, Jr. (the Movant, by his attorney Benjamin A. Currence, Esq., filed the Motion for Limited Relief from Automatic Stay [Docket No. 598] (the Motion. PLEASE TAKE FURTHER NOTICE that attached hereto as Exhibit A is a copy of the Stipulation Regarding Motion for Limited Relief from Automatic Stay (the Stipulation by and among the Movant and Jay Borow, in his capacity as the liquidating trustee (the Liquidating Trustee for the Hovensa Liquidating Trust (the Liquidating Trust, established in accordance with the Debtor's Second Amended Plan of Liquidation Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 563]. PLEASE TAKE FURTHER NOTICE that copies of the Motion and the Stipulation available on the Bankruptcy Court s website at https://ecf.vib.uscourts.gov in accordance with the procedures and fees set forth therein, as well as free of charge on the website established by the Debtor s claims and noticing agent at https://cases.primeclerk.com/hovensa. [REMAINDER OF PAGE INTENIONALLY LEFT BLANK]
Case 1:15-bk-10003-MFW Doc 848 Filed 01/09/17 Entered 01/09/17 16:22:41 Desc Main Document Page 2 of 2 HAMM ECKARD, LLP Dated: January 9, 2017 St. Croix, U.S. Virgin Islands By: /s/ Mark W. Eckard Mark W. Eckard (VI Bar No. 1051 5030 Anchor Way Christiansted, VI 00824 Telephone: (340 773-6955 Email: meckard@hammeckard.com - and - Sam J. Alberts, Esquire Malka Zeefe, Esquire 1301 K Street, NW Suite 600, East Tower Washington, DC 20005-3364 Telephone: (202 408-6400 Facsimile: (202 408-6399 Email: sam.alberts@dentons.com malka.zeefe@dentons.com Alison Elko Franklin, Esquire 303 Peachtree Street, Suite 5300 Atlanta, GA 30308 Telephone: (404 527-4000 Facsimile: (404 527-4198 Email: alison.franklin@dentons.com Counsel to the Liquidating Trustee
Desc Exhibit A Page 1 of 4 EXHIBIT A
Desc Exhibit A Page 2 of 4 IN THE DISTRICT COURT OF THE VIRGIN ISLANDS BANKRUPTCY DIVISION In re: HOVENSA L.L.C., Debtor. Chapter 11 Case No. 15-10003-MFW RE: D.I. 838 STIPULATION REGARDING MOTION FOR RELIEF FROM THE AUTOMATIC STAY Jay Borow, in his capacity as the liquidating trustee (the "Liquidating Trustee" for the Hovensa Liquidating Trust (the "Liquidating Trust", established in accordance with the Debtor's Second Amended Plan of Liquidation Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 563], and Rolly Soogrim, Jr. (the "Movant", stipulate as follows: WHEREAS, on February 8, 2016, the Movant filed the Motion for Relief from the Automatic Stay [Docket No. 598] (the "Motion"; WHEREAS, the Liquidating Trustee and the Movant have agreed to several adjournments of the hearing on the Motion (the "Hearing" and several extensions of the deadline to file an objection to the Motion (the "Objection Deadline"; WHEREAS, on November 3, 2016, the Liquidating Trustee filed the Notice of Adjournment of Hearing on Motion for Limited Relief From Automatic Stay [Docket No. 598] [Docket No. 816] (the "Notice of Adjournment" adjourning the Hearing to January 12, 2017 and extending the Objection Deadline; WHEREAS, the Liquidating Trustee and the Movant (collectively the "Parties" agree that the interest of judicial economy and convenience of the Parties would be furthered by further adjourning the Hearing and extending the Objection Deadline; 1
Desc Exhibit A Page 3 of 4 NOW, THEREFORE, it is hereby stipulated and agreed to by and among the Parties: 1. The Hearing will be adjourned for approximately four (4 months to May 18, 2017 at 10:00 a.m. (Atlantic Standard Time, without prejudice to further adjournments of the Hearing. 2. The Objection Deadline will be extended for approximately four (4 months to May 11, 2017, without prejudice further extensions of the Objection Deadline. IT IS SO AGREED: FOR JAY BORROW, THE LIQUIDATING TRUSTEE OF THE HOVENSA LIQUIDATING TRUST: Dated: January 9, 2017 HAMM ECKARD, LLP By: /s/ Mark W. Eckard Mark W. Eckard (VI Bar No. 1051 5030 Anchor Way Christiansted, VI 00824 Telephone: (340 773-6955 Email: meckard@hammeckard.com - and- Sam J. Alberts, Esquire Malka Zeefe, Esquire 1301 K Street, NW Suite 600, East Tower Washington, DC 20005-3364 Telephone: (202 408-6400 Facsimile: (202 408-6399 Email: sam.alberts@dentons.com malka.zeefe@dentons.com Alison Elko Franklin, Esquire 303 Peachtree Street, Suite 5300 Atlanta, GA 30308 Telephone: (404 527-4000 Facsimile: (404 527-4198 Email: alison.franklin@dentons.com 2
Desc Exhibit A Page 4 of 4 FOR ROLLY SOOGRIM, JR., THE MOVANT: Counsel to the Liquidating Trustee Dated: January 9, 2017 By: /s/ Benjamin A. Currence Benjamin A. Currence (VI Bar No. 115 5043 Norre Gade, Ste. 4 P.O. Box 6143 St. Thomas, VI 00804-6143 Telephone: (340 775-3434 Email: bencurrence@gmail.com 3