HTML Document View

Full title: Certification of Counsel Regarding Motion of the Debtor for Entry of Interim and Final Orders (I) Approving Continued Use of Cash Management System; (II) Authorizing the Debtor to Open and Close Bank Accounts; (III) Authorizing Banks to Honor Certain Transfers; (IV) Suspending the Requirements of 11 U.S.C. § 345(b); and (V) Granting Related Relief (related document(s)11, 31, 60) Filed by Adara Enterprises Corp.. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Gellert, Ronald) (Entered: 05/12/2021)

Document posted on May 11, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

1 RE: D.I. 11, 31, and 60 CERTIFICATION OF COUNSEL REGARDING MOTION OF THE DEBTOR FOR ENTRY OF INTERIM AND FINAL ORDERS (I) APPROVING CONTINUED USE OF CASH MANAGEMENT SYSTEM; (II) AUTHORIZING THE DEBTOR TO OPEN AND CLOSE BANK ACCOUNTS; (III) AUTHORIZING BANKS TO HONOR CERTAIN TRANSFERS; (IV) SUSPENDING THE REQUIREMENTS OF 11 U.S.C. § 345(B); AND (V) GRANTING RELATED RELIEF On April 22, 2021, the Debtor filed the Motion of the Debtor for Entry of Interim and Final Orders (I) Approving Continued Use of Cash Management System; (II) Authorizing the Debtor to Open and Close Bank Accounts; (III)The deadline to object to entry of a final order on the relief requested in the Motion was May 4, 2021 at 4:00 p.m. as set forth in the Omnibus Notice of Hearing With Respect to Final Approval of the Interim Relief Motions [D.I. 34].On May 7, 2021, Debtor filed the revised proposed final order (the “Revised Proposed Order”) under certification of counsel [D.I. 60].Following the Court’s ruling on the Motion and Revised Proposed Order, Debtor further revised the proposed form of order consistent therewith.

List of Tables

Document Contents

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 RE: D.I. 11, 31, and 60 CERTIFICATION OF COUNSEL REGARDING MOTION OF THE DEBTOR FOR ENTRY OF INTERIM AND FINAL ORDERS (I) APPROVING CONTINUED USE OF CASH MANAGEMENT SYSTEM; (II) AUTHORIZING THE DEBTOR TO OPEN AND CLOSE BANK ACCOUNTS; (III) AUTHORIZING BANKS TO HONOR CERTAIN TRANSFERS; (IV) SUSPENDING THE REQUIREMENTS OF 11 U.S.C. § 345(B); 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 the Motion of the Debtor for Entry of Interim and Final Orders (I) Approving Continued Use of Cash Management System; (II) Authorizing the Debtor to Open and Close Bank Accounts; (III) Authorizing Banks to Honor Certain Transfers; (IV) Suspending the Requirements of 11 U.S.C. § 345(b); and (V) Granting Related Relief [D.I. 11] (the “Motion”). 2. An initial hearing on the Motion was held on April 26, 2021 after which the Court entered an order granting interim relief requested in the Motion [D.I. 31] (the “Interim Order”). 3. The deadline to object to entry of a final order on the relief requested in the Motion was May 4, 2021 at 4:00 p.m. as set forth in the Omnibus Notice of Hearing With Respect to Final Approval of the Interim Relief Motions [D.I. 34]. The undersigned certifies that he has reviewed 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.

1

the docket in this case and no answer, objection or other responsive pleading to Motion appears thereon. 4. The Debtor made ministerial revisions to the proposed final order on the Motion as compared to the proposed final order filed with the Court. 5. On May 7, 2021, Debtor filed the revised proposed final order (the “Revised Proposed Order”) under certification of counsel [D.I. 60]. 6. On May 11, 2021, the Court held a hearing to consider the Motion and Revised Proposed Order. 7. Following the Court’s ruling on the Motion and Revised Proposed Order, Debtor further revised the proposed form of order consistent therewith. 8. A copy of the revised proposed final order on the Motion is attached hereto as Exhibit A. A blackline of the proposed final order marked against the version filed under certification of counsel is attached hereto as Exhibit B. WHEREFORE, the undersigned respectfully requests that the Court enter the proposed final orders attached hereto as Exhibit A without further notice or hearing. (Signature page to follow)

2

Dated: May 12, 2021 Wilmington, Delaware Respectfully submitted, GELLERT SCALI BUSENKELL & BROWN LLC /s/ Ronald S. Gellert Ronald S. Gellert (DE 4259) 1201 N. Orange Street, Suite 300 Wilmington, Delaware 19801 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

3