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Full title: Motion to Extend -- Motion of Distribution Trustee for an Order Extending the Claims Objection Deadline to February 14, 2022 Filed by Entity Services (SPV), LLC. Hearing scheduled for 8/31/2021 at 04:00 PM at US Bankruptcy Court, 824 Market St., 3rd Fl., Courtroom #7, Wilmington, Delaware. Objections due by 8/23/2021. (Attachments: # 1 Notice # 2 Exhibit A # 3 Certificate of Service) (Keilson, Brya) (Entered: 08/16/2021)

Document posted on Aug 15, 2021 in the bankruptcy, 7 pages and 0 tables.

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This is a core proceeding pursuant to 28 U.S.C. § 157(b), and, under Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the Distribution Trustee consents 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, 1 The Bar Date Order also required that the Debtor cause service of the Bar Date Notice to be made upon (a) all parties that requested notice in the Chapter 11 Case; (b) all persons or entities that have previously filed proofs of claim; (c) all known or suspected holders of Claims against the Debtor as of the Petition Date, including the parties listed on the Debtor’s Schedules; (d) all parties to Executory Contracts and Unexpired Leases; (e) all parties in litigation with the Debtor; and (f) all applicable Governmental Units.On June 15, 2021, the Distribution Trustee filed the Notice of (A) Entry of Order Approving the Disclosure Statement for, and Confirming, the Amended Prepackaged Chapter 11 Plan of Reorganization of Adara Enterprises Corp.; (B) Effective Date of the Plan; (C) Substantial Consummation of the Plan; and (D) Bar Dates for Certain Administrative, Professional, and Rejection Claims (“Notice of Effective Date”)With respect to all Claims, including administrative claims, Article VII of the Plan provides that objections to such Claims must be filed with 60 days after the Effective Date, or such later date as may be fixed by an order of the Bankruptcy Court (the “Claims Objection Deadline”).While the Distribution Trustee on behalf of the Debtor will endeavor to resolve all of the remaining unresolved Claims within the time of the requested extension, the Distribution Trustee and Debtor reserve all of their rights to seek further extensions of the Claims Objection Deadline, as appropriate, as well as to object to and/or seek estimation of particular Claims.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 ADARA ENTERPRISES CORP, Case No. 21-10736 (JKS) Debtor.1 Objections Due: August 23, 2021 at 4:00 p.m. (ET) Hearing Date: August 31, 2021 at 4:00 p.m. (ET) MOTION OF THE DISTRIBUTION TRUSTEE FOR AN ORDER EXTENDING THE CLAIMS OBJECTION DEADLINE TO FEBRUARY 14, 2022 Entity Services (SPV), LLC, as distribution trustee (“Distribution Trustee”) for Adara Enterprises Corp. (the “Debtor”) in the above-captioned case, by and through its undersigned counsel hereby moves (this “Motion”) for entry of an order, substantially in the form attached hereto as Exhibit A, extending the deadline to object to claims established by the Plan (as defined below) through and including February 14, 2022. In support of the Motion, the Distribution Trustee respectfully states: JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. §§ 157and 1334, the Amended Standing Order of Reference from the United States District Court for the District of Delaware dated as of February 29, 2012, and Article VII of the Plan. This is a core proceeding pursuant to 28 U.S.C. § 157(b), and, under Rule 9013-1(f) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), the Distribution Trustee consents 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, 1 The last four digits of the Debtor’s federal tax identification number are 8502. The service address for the Debtor is 411 E. 57th Street Suite 1-A, New York, New York 10022.

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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 of this case and this Motion in this District is proper under 28 U.S.C. §§ 1408 and 1409. 3. The statutory and legal predicates for the relief requested herein is sections 105(a), 502, and 503 of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Rule 9006 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Local Rules 9006-1 and 9006-2. GENERAL BACKGROUND 4. On April 22, 2021, the Adara Enterprises Corp. (“Debtor”) filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. 5. On May 3, 2021, the Court entered the Order (I) Establishing Deadlines for Filing Proofs of Claim, Including Section 503(b)(9) Claims, (II) Approving the Form and Manner of Notice Thereof, and (III) Granting Related Relief [D.I. 55] (“Bar Date Order”), which set June 4, 2021 at 4:00 p.m. (PT) as the “General Bar Date” for all persons and entities, including holders of section 503(b)(9) of the Bankruptcy Code claims, and set October 19, 2021 at 4:00 p.m. (PT) as the “Governmental Bar Date” by which all Governmental Units must file proofs of claim. The Bar Date Order also required that the Debtor cause service of the Bar Date Notice to be made upon (a) all parties that requested notice in the Chapter 11 Case; (b) all persons or entities that have previously filed proofs of claim; (c) all known or suspected holders of Claims against the Debtor as of the Petition Date, including the parties listed on the Debtor’s Schedules; (d) all parties to Executory Contracts and Unexpired Leases; (e) all parties in litigation with the Debtor; and (f) all

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applicable Governmental Units. Such service was accomplished on May 4, 2021 as set forth in the Bar Date Notice Affidavit. 6. On June 9, 2021, the Court entered the Findings Of Fact, Conclusions Of Law, And Order Approving The Disclosure Statement For, And Confirming, The Amended Chapter 11 Plan Of Reorganization Of Adara Enterprises Corp. (“Confirmation Order”) [D.I. 112]. 7. On June 15, 2021, the Distribution Trustee filed the Notice of (A) Entry of Order Approving the Disclosure Statement for, and Confirming, the Amended Prepackaged Chapter 11 Plan of Reorganization of Adara Enterprises Corp.; (B) Effective Date of the Plan; (C) Substantial Consummation of the Plan; and (D) Bar Dates for Certain Administrative, Professional, and Rejection Claims (“Notice of Effective Date”) [D.I. 113]. 8. Upon the Effective Date, Entity Services (SPV), LLC was appointed as the Distribution Trustee pursuant to the terms of the Distribution Trust Agreement (the “DTA”). 9. Under Article VII of the Plan, the Distribution Trustee has authority to object to any claims filed against the Debtor. 10. With respect to all Claims, including administrative claims, Article VII of the Plan provides that objections to such Claims must be filed with 60 days after the Effective Date, or such later date as may be fixed by an order of the Bankruptcy Court (the “Claims Objection Deadline”). Currently, the Claims Objection Deadline is August 16, 2021. CLAIMS RECONCILIATION PROCESS 11. The register of claims (the “Claims Register”) prepared and maintained by Donlin Recano reflects that, as of the date of this Motion, at least 8 proofs of claim of varying priority levels, including general unsecured, secured, priority and administrative claims (collectively, the “Filed Claims”), have been filed in this Chapter 11 Case. In addition, at least 7 claims were listed

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in the Debtor’s schedules of assets and liabilities, as filed in this case on April 22, 2021 (collectively, the “Scheduled Claims”). As of the time of this Motion, no administrative expense requests have been made. 12. Since the Effective Date, the Distribution Trustee has been working to reconcile the Filed Claims, and Scheduled Claims expeditiously, with a view toward maximizing recoveries for creditors with valid Claims. 13. Although the Distribution Trustee has been working diligently to reconcile Claims, and significant progress has been made in the approximately two months that have passed since the Effective Date, substantial additional work remains. The Distribution Trustee will continue to work through the unresolved Claims as quickly as possible under the circumstances, but needs additional time to do so. RELIEF REQUESTED 14. The Distribution Trustee respectfully requests entry of an order extending the Claims Objection Deadline for a period of approximately 180 days through and including, February 14, 2022.2 The proposed extension is without prejudice to the Distribution Trustee’s right to seek additional extensions of the Claims Objection Deadline as appropriate. BASIS FOR RELIEF 15. Sections 502 and 503 of the Bankruptcy Code contemplate that claims will be challenged when appropriate and, if necessary, estimated. See 11 U.S.C. §§ 502(b)-(c), 503. The Plan vests the discretion to object to or seek estimation of Claims in the Distribution Trustee on behalf of the Debtor’s estate. Although the Plan set an initial deadline by which such challenges 2 Pursuant to Local Rule 9006-2, the filing of this Motion prior to the expiration of the current Claims Objection Deadline serves to automatically extend the Claims Objection Deadline until such time as the Court rules on this Motion. See Del. Bankr. LR 9006-2.

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must be raised, the Plan contemplates extension of the Claims Objection Deadline by order of the Bankruptcy Court. See Plan Article VII. 16. Bankruptcy Rule 9006(b) also provides for extensions of time for cause. Specifically: [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)(1). 17. Finally, section 105 of the Bankruptcy Code provides that the “court may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title.” 11 U.S.C. § 105(a). 18. The Distribution Trustee submits that extension of the Claims Objection Deadline is fundamental to the efficient administration of the Debtor’s estate and is in the best interests of creditors. As discussed above, the Distribution Trustee has been working diligently since the Effective Date and have accomplished a lot in a short amount of time. 19. To ensure the fair and proper administration of the Debtor’s estate, the Distribution Trustee requires additional time to reconcile the remaining Claims and Administrative Claim Requests, to attempt to reach a consensual resolution and, only if appropriate, to file objections. 20. The requested extension of the Claims Objection Deadline will not prejudice any claimant or other party in interest, and it will benefit creditors holding valid claims of all priority levels. Extension of the Claims Objection Deadline is not sought for purposes of delay, nor will it affect any claimant’s substantive defense(s) to any objection. Rather, the extension is intended to ensure that Claims will only be challenged after a meaningful review.

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21. Absent the extension, the Debtor’s estate and creditors may suffer unnecessary and unfair prejudice. Either the Distribution Trustee will be precluded from challenging invalid, misclassified and/or overstated Claims, or they will be forced to lodge hastily prepared “protective” objections without the benefit of a full review and analysis by the Distribution Trustee and its professionals. 22. The requested extension will not only allow the Distribution Trustee to properly review the remaining unresolved Claims and Administrative Claim Requests, but will also conserve the limited resources of the Debtor’s estates to the benefit of all creditors by allowing the Distribution Trustee time to pursue settlement, and avoid the delay and expense of unnecessary objections and litigation. RESERVATION OF RIGHTS 23. While the Distribution Trustee on behalf of the Debtor will endeavor to resolve all of the remaining unresolved Claims within the time of the requested extension, the Distribution Trustee and Debtor reserve all of their rights to seek further extensions of the Claims Objection Deadline, as appropriate, as well as to object to and/or seek estimation of particular Claims. NOTICE 24. Notice of this Motion will be provided to (i) the Office of the United States Trustee for the District of Delaware, and (ii) all parties who, as of the filing of the Motion, have filed a renewed notice of appearance and request for service of papers pursuant to Bankruptcy Rule 2002. In light of the procedural nature of the post-confirmation relief requested herein, the Distribution Trustee submits that such notice is sufficient under the circumstances and that no other or further notice is required.

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WHEREFORE, the Distribution Trustee respectfully requests that this Court enter an order, substantially in the form attached hereto as Exhibit A: (i) extending the Claims Objection Deadline through and including February 14, 2022, without prejudice to the Distribution Trustee’s and Debtor’s rights to seek additional extensions of such deadline as appropriate; and (ii) granting such other and further relief as the Court may deem just and proper. Dated: August 16, 2021 MORRIS JAMES LLP /s/ Brya M. Keilson Eric J. Monzo (DE Bar No. 5214) Brya M. Keilson (DE Bar No. 4643) Jason S. Levin (DE Bar No. 6434) 500 Delaware Avenue, Suite 1500 Wilmington, DE 19801 Telephone: (302) 888-6800 Facsimile: (302) 571-1750 E-mail: emonzo@morrisjames.com E-mail: bkeilson@morrisjames.com E-mail: jlevin@morrisjames.com Counsel to Entity Services (SPV), LLC, in its capacity as Distribution Trustee

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