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Full title: Certification of Counsel Regarding Order (I) Scheduling a Combined Hearing on (A) Adequacy of Disclosure Statement, (B) Confirmation of Plan, and (C) The Assumption of Executory Contracts and Cure Amounts; (II) Approving Form and Manner of Notice of (A) Combined Hearing; (B) Commencement of Chapter 11 Case, and (C) Assumption of Executory Contracts and Cure Amounts Related Thereto, and Objection Deadlines; (III) Establishing Procedures for Objection to (A) Disclosure Statement, (B) Plan, and (C) Proposed Assumption or Rejection of Executory Contracts and Cure Amounts; (IV) Conditionally Directing the United States Trustee Not to Convene at Section 341 Meeting of Creditors; and (V) Granting Related Relief (related document(s)8) Filed by Adara Enterprises Corp.. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Gellert, Ronald) (Entered: 04/26/2021)

Document posted on Apr 25, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

THE ASSUMPTION OF EXECUTORY CONTRACTS AND CURE AMOUNTS; (II) APPROVING FORM AND MANNER OF NOTICE OF (A) COMBINED HEARING, (B) COMMENCEMENT OF CHAPTER 11 CASE, AND (C) ASSUMPTION OF EXECUTORY CONTRACTS AND CURE AMOUNTS RELATED THERETO, AND OBJECTION DEADLINES; (III) ESTABLISHING PROCEDURES FOR OBJECTING TO (A) DISCLOSURE STATEMENT, (B) PLAN, AND (C) PROPOSED RELIEF I, Ronald S. Gellert, Esq., of Gellert Scali Busenkell & Brown, LLC, proposed counsel to the above captioned debtor and debtor-in-possession (the “Debtor”) hereby certify as follows: 1. Approving Form and Manner of Notice of (A) Combined Hearing; (B) Commencement of Chapter 11 Case, and (C) Assumption of Executory Contracts and Cure Amounts Related Thereto, and Objection Deadlines; (III) Establishing Procedures for Objection to (A) Disclosure Statement, (B) Plan, and (C) 1 Pursuant to the Notice of (I) Filing of Bankruptcy Petition and Related Documents and (II) Agenda for Video Hearing on First Day Motions Scheduled for April 26, 2021 at 1:30 pm (ET) Before the Honorable J. Kate Stickles, at the United States Bankruptcy Court for the District of Delaware the deadline to object or otherwise comment on the entry of an order approving the Motion was set for at the First Day Hearing scheduled on April 26, 2021 (the “Objection Deadline”).A blackline of the proposed order marked against the version filed with the Court is attached hereto as Exhibit B. WHEREFORE, the undersigned respectfully requests that the Court enter the proposed order attached hereto as Exhibit A, without further notice or hearing.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 ADARA ENTERPRISES CORP.,1 Case No. 21-10736 (JKS) Debtor. Re DI: 8 CERTIFICATION OF COUNSEL REGARDING ORDER (I) SCHEDULING A COMBINED HEARING ON (A) ADEQUACY OF DISCLOSURE STATEMENT, (B) CONFIRMATION OF PLAN, AND (C) THE ASSUMPTION OF EXECUTORY CONTRACTS AND CURE AMOUNTS; (II) APPROVING FORM AND MANNER OF NOTICE OF (A) COMBINED HEARING, (B) COMMENCEMENT OF CHAPTER 11 CASE, AND (C) ASSUMPTION OF EXECUTORY CONTRACTS AND CURE AMOUNTS RELATED THERETO, AND OBJECTION DEADLINES; (III) ESTABLISHING PROCEDURES FOR OBJECTING TO (A) DISCLOSURE STATEMENT, (B) PLAN, AND (C) PROPOSED ASSUMPTION OR REJECTION OF EXECUTORY CONTRACTS AND CURE AMOUNTS; (IV) CONDITIONALLY DIRECTING THE UNITED STATES TRUSTEE NOT TO CONVENE A SECTION 341 MEETING OF CREDITORS; AND (V) GRANTING RELATED RELIEF I, Ronald S. Gellert, Esq., of Gellert Scali Busenkell & Brown, LLC, proposed counsel to the above captioned debtor and debtor-in-possession (the “Debtor”) hereby certify as follows: 1. On April 22, 2021 the Debtor filed its Motion of the Debtor for Entry of an Order (I) Scheduling a Combined Hearing on (A) Adequacy of Disclosure Statement, (B) Confirmation of Plan, and (C) The Assumption of Executory Contracts and Cure Amounts; (II) Approving Form and Manner of Notice of (A) Combined Hearing; (B) Commencement of Chapter 11 Case, and (C) Assumption of Executory Contracts and Cure Amounts Related Thereto, and Objection Deadlines; (III) Establishing Procedures for Objection to (A) Disclosure Statement, (B) Plan, and (C) 1 The last four digits of the Debtor’s federal tax identification number are 8502. The Debtor’s address is 411 E 57th Street Suite 1-A, New York, New York 10022.

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Proposed Assumption or Rejection of Executory Contracts and Cure Amounts; (IV) Conditionally Directing the United States Trustee Not to Convene at Section 341 Meeting of Creditors; and (V) Granting Related Relief (the “Motion”)[D.I. 8]. 2. Pursuant to the Notice of (I) Filing of Bankruptcy Petition and Related Documents and (II) Agenda for Video Hearing on First Day Motions Scheduled for April 26, 2021 at 1:30 pm (ET) Before the Honorable J. Kate Stickles, at the United States Bankruptcy Court for the District of Delaware the deadline to object or otherwise comment on the entry of an order approving the Motion was set for at the First Day Hearing scheduled on April 26, 2021 (the “Objection Deadline”). 3. On April 26, 2021, the Court held a hearing on the Motion and provided comments on the form of Order. 4. The Debtor has revised the proposed order in accordance with the Court’s comments. 5. A copy of the revised proposed order is attached hereto as Exhibit A. A blackline of the proposed order marked against the version filed with the Court is attached hereto as Exhibit B. WHEREFORE, the undersigned respectfully requests that the Court enter the proposed order attached hereto as Exhibit A, without further notice or hearing. Dated: April 26, 2021 Wilmington, Delaware Respectfully submitted, GELLERT SCALI BUSENKELL & BROWN LLC /s/ Ronald S. Gellert Ronald Gellert (DE 4259) 1201 N. Orange Street, Suite 300 Wilmington, Delaware 19801

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Telephone: (302) 425-5800 Facsimile: (302) 425-5814 Email: rgellert@sgbblaw.com – and – LOEB & LOEB LLP Daniel B. Besikof (admitted pro hac vice) Bethany D. Simmons (admitted pro hac vice) 345 Park Avenue New York, New York 10154 Telephone: (212) 407-4000 Facsimile: (646) 417-6335 Email: dbesikof@loeb.com; bsimmons@loeb.com Proposed Counsel to the Debtor and Debtor in Possession

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