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Full title: Motion to Expedite Hearing filed by David W. Parham for Debtor First River Energy, LLC (Attachments: # 1 Exhibit A - Service List # 2 Proposed Order)(Parham, David) (Related Document(s): 1003 Second Amended Disclosure Statement filed by David W. Parham for Debtor First River Energy, LLC. (Attachments: # 1 Exhibit Plan of Liquidation)(Parham, David) (related document(s): 319 Disclosure Statement filed by David W. Parham for Debtor First River Energy, LLC. (Attachments: # 1 Exhibit # 2 Exhibit), 320 Chapter 11 Plan filed by David W. Parham for Debtor First River Energy, LLC.))

Document posted on Jun 29, 2021 in the bankruptcy, 3 pages and 0 tables.

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First River Energy, LLC (the “Debtor”) in the above-captioned Chapter 11 case (the “Chapter 11 Case”), by and through its undersigned counsel, hereby files this request (this “Request”) seeking an expedited hearing on the Debtor’s Second Amended Disclosure Statement for the Debtor’s Plan of Liquidation Under Chapter 11 of the United States Bankruptcy Code (the “Disclosure Statement”), and establishing a deadline for objections to Disclosure Statement be filed with this Court and would respectfully state the following: 1.At a hearing on June 1, 2021, the Court and interested parties were advised of the Debtor’s intention to file the Disclosure Statement and request it be heard on July 13, 2021.The Debtor is requesting that the Disclosure Statement be heard on Tuesday, July 13, 2021 at 1:30p.m.Debtor requests that the Court establish Sunday, July 11, 2021, as the deadline for filing objections to the Disclosure Statement to allow the Debtor and its counsel one business day in advance of the hearing to review said objections. WHEREFORE, Debtor prays this Court set the Disclosure Statement for hearing on an expedited basis on Tuesday, July 13, 2021 at 1:30 p.m., establish Sunday, July 11, 2021 at 5:00p.m.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION In re: § § Chapter 11 FIRST RIVER ENERGY, LLC,1 § § Bankruptcy Case No. 18-50085 Debtor. § Expedited Hearing Requested for: § July 6, 2021 at 10:30 a.m. DEBTOR’S REQUEST FOR EXPEDITED HEARING AND ESTABLISH OBJECTION DEADLINE FOR DEBTOR’S DISCLOSURE STATEMENT First River Energy, LLC (the “Debtor”) in the above-captioned Chapter 11 case (the “Chapter 11 Case”), by and through its undersigned counsel, hereby files this request (this “Request”) seeking an expedited hearing on the Debtor’s Second Amended Disclosure Statement for the Debtor’s Plan of Liquidation Under Chapter 11 of the United States Bankruptcy Code (the “Disclosure Statement”), and establishing a deadline for objections to Disclosure Statement be filed with this Court and would respectfully state the following: 1. On June 30, 2021, the Debtor filed a Disclosure Statement (Doc. No. 1003). 2. Time is reserved for a hearing on the Disclosure Statement for July 13, 2021 at 1:30p.m. 3. At a hearing on June 1, 2021, the Court and interested parties were advised of the Debtor’s intention to file the Disclosure Statement and request it be heard on July 13, 2021. Since that time the Debtor’s undersigned counsel provided drafts of the Disclosure Statement 1 The Debtor in this chapter 11 case, along with the last four digits of the Debtor’s federal tax identification number, is: First River Energy, LLC (9656). The mailing address for the Debtor, solely for purposes of notices and communications, is P.O. Box 1718, Livingston, TX 77351.

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and Plan and continued communications with certain of the largest creditors in this case regarding the Disclosure Statement and Plan. 4. The Debtor is requesting that the Disclosure Statement be heard on Tuesday, July 13, 2021 at 1:30p.m. to allow the Debtor to move forward as soon as possible with confirming its plan. 5. Debtor estimates that a hearing on the Disclosure Statement will last approximately ninety (90) minutes. 6. Debtor requests that the Court establish Sunday, July 11, 2021, as the deadline for filing objections to the Disclosure Statement to allow the Debtor and its counsel one business day in advance of the hearing to review said objections. 7. Undersigned counsel certifies that there is a true necessity for an expedited hearing and that the necessity for the expedited hearing has not been cause by a lack of due diligence on their part. WHEREFORE, Debtor prays this Court set the Disclosure Statement for hearing on an expedited basis on Tuesday, July 13, 2021 at 1:30 p.m., establish Sunday, July 11, 2021 at 5:00p.m. as the deadline to file objections to the Disclosure Statement and for such other relief as the Court may deem just and proper. Dated: June 30, 2021 Respectfully submitted, /s/ David W. Parham David W. Parham, SBN: 15459500 Esther McKean, SBN: 24122145 AKERMAN LLP 2001 Ross Avenue, Suite 3600 Dallas, Texas 75201 Telephone: (214) 720-4300 Facsimile: (214) 981-9339 david.parham@akerman.com esther.mckean@akerman.com

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CERTIFICATE OF SERVICE I hereby certify that, on June 30, 2021, a true and correct copy of the foregoing document was served electronically by the Court’s PACER system to all parties receiving such notices. Furthermore, I directed Donlin Recano, the Debtor’s Noticing Agent, to serve the foregoing document(s) via first class mail on the parties named on the notice list set forth in Exhibit Aattached hereto. /s/ David W. Parham David W. Parham, Esq.

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