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Full title: Joint Motion to Expedite Hearing Ex Parte Motion for Expedited Hearing on Expedited Joint Motion of the Debtor and the Official Committee of Unsecured Creditors for Entry of Agreed Supplemental and Amended Protective Order (RE: related document(s)864 Motion to Amend filed by Debtor The Roman Catholic Church for the Archdiocese of New Orleans) Filed by Mark Mintz of Jones Walker, et al on behalf of The Roman Catholic Church for the Archdiocese of New Orleans (Attachments: # 1 Proposed Order) (Mintz, Mark) (Entered: 05/14/2021)

Document posted on May 13, 2021 in the bankruptcy, 4 pages and 0 tables.

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THE ROMAN CATHOLIC CHURCH § OF THE ARCHDIOCESE OF NEW § Section “A” ORLEANS, § § Chapter 11 Debtor.1 § § EX PARTE MOTION FOR EXPEDITED HEARING ON EXPEDITED JOINT MOTION OF THE DEBTOR AND THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ENTRY OF AGREED SUPPLEMENTAL AND AMENDED PROTECTIVE ORDER The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”) and the Official Committee of Unsecured Creditors (the “Committee”) (collectively, “Movants”), hereby file this Ex Parte Motion for Expedited Hearing (the “Motion for Expedited Hearing”) on Movants’ Expedited Joint Motion for Entry of Agreed Supplemental and Amended Protective Order (the “Motion to Amend”)This matter is governed by §§ 105(a) and 107 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 9018 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 9013-1(C) of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana.WHEREFORE, the Debtor and the Committee respectfully request that the Court enter an Order in substantially the same form as the attached: (i) setting the Motion to Amend for expedited hearing on May 20, 2021 at 1:30 p.m. CST, or at such subsequent date and time as is convenient for the Court; (ii) fixing the deadline of Tuesday, May 18, 2021 at 5:00 p.m. CST for filing written objections to the Motion to Amend, provided the hearing is scheduled for May 20, 2021; and (iii) granting such other relief as the Court deems just and appropriate.I hereby certify that a true and correct copy of this Motion is being served on May 14, 2021 (a) by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and (b) by email or First Class U.S. Mail, postage prepaid, on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures [ECF No.

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UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF LOUISIANA In re: § § Case No. 20-10846 THE ROMAN CATHOLIC CHURCH § OF THE ARCHDIOCESE OF NEW § Section “A” ORLEANS, § § Chapter 11 Debtor.1 § § EX PARTE MOTION FOR EXPEDITED HEARING ON EXPEDITED JOINT MOTION OF THE DEBTOR AND THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ENTRY OF AGREED SUPPLEMENTAL AND AMENDED PROTECTIVE ORDER [Relates to ECF No. 864] The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”) and the Official Committee of Unsecured Creditors (the “Committee”) (collectively, “Movants”), hereby file this Ex Parte Motion for Expedited Hearing (the “Motion for Expedited Hearing”) on Movants’ Expedited Joint Motion for Entry of Agreed Supplemental and Amended Protective Order (the “Motion to Amend”) [ECF No. 864]. In support of the Motion for Expedited Hearing, Movants respectfully state: Jurisdiction and Venue 1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). 2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 1 The last four digits of the Debtor’s federal tax identification number are 8966. The Debtor’s principal place of business is located at 7887 Walmsley Ave., New Orleans, LA 70125.

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3. This matter is governed by §§ 105(a) and 107 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 9018 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 9013-1(C) of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana. Request for Expedited Relief 4. The Motion to Amend, filed simultaneously with this Motion for Expedited Hearing, requests that the Court supplement and amend the Amended Protective Order entered on January 25, 2021 [ECF No. 729] to include additional confidentiality provisions to protect certain documents and information. 5. Movants believe that expediting this matter is appropriate to move case resolution efforts forward, including preparations for mediation, and to reduce overall costs to the estate from delay. 6. As detailed in the Motion to Amend, Movants agree to the relief requested therein. Further, Movants understand that no party opposes expedited hearing of this matter on May 20, 2021. 7. Should this Motion for Expedited Hearing be granted, a response deadline of May 18, 2021 is proposed. WHEREFORE, the Debtor and the Committee respectfully request that the Court enter an Order in substantially the same form as the attached: (i) setting the Motion to Amend for expedited hearing on May 20, 2021 at 1:30 p.m. CST, or at such subsequent date and time as is convenient for the Court; (ii) fixing the deadline of Tuesday, May 18, 2021 at 5:00 p.m. CST for filing written objections to the Motion to Amend, provided the hearing is scheduled for May 20, 2021; and (iii) granting such other relief as the Court deems just and appropriate.

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Dated: May 14, 2021 Respectfully submitted, /s/ Mark A. Mintz R. PATRICK VANCE (#13008) ELIZABETH J. FUTRELL (#05863) EDWARD D. WEGMANN (#13315) MARK A. MINTZ (#31878) LAURA F. ASHLEY (#32820) Jones Walker LLP 201 St. Charles Avenue, 51st Floor New Orleans, LA 70170 Telephone: (504) 582-8000 Facsimile: (504) 589-8260 Email: pvance@joneswalker.com Email: efutrell@joneswalker.com Email: dwegmann@joneswalker.com Email: mmintz@joneswalker.com Email: lashley@joneswalker.com ATTORNEYS FOR THE ROMAN CATHOLIC CHURCH OF THE ARCHDIOCESE OF NEW ORLEANS /s/ C. Davin Boldissar Omer F. Kuebel, III (La #21682) C. Davin Boldissar (La. #29094) Locke Lord LLP 601 Poydras Street, Suite 2660 New Orleans, Louisiana 70130-6036 Telephone: (504) 558-5111 Facsimile: (504) 558-5200 Email: dboldissar@lockelord.com And James I. Stang (CA Bar No. 94435) Linda F. Cantor (CA Bar No. 153762) Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., Suite 1300 Los Angeles, CA 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 ATTORNEYS FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS

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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Motion is being served on May 14, 2021 (a) by electronic case filing for those parties receiving notice via the Court’s Electronic Case Filing system, and (b) by email or First Class U.S. Mail, postage prepaid, on all other parties requiring service under the Court’s Ex Parte Order Authorizing the Debtor to Limit Notice and Establishing Notice Procedures [ECF No. 22], to be sent by DRC. DRC shall file a certificate of service to that effect once service is completed. /s/ Mark A. Mintz Mark A. Mintz

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