HTML Document View

Full title: Motion to Expedite Hearing (RE: related document(s)952 Motion to Approve Compromise under Rule 9019 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: 07/20/2021)

Document posted on Jul 19, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

THE ROMAN CATHOLIC CHURCH § OF THE ARCHDIOCESE OF NEW § Section “A” ORLEANS, § § Chapter 11 Debtor.1 § § EX PARTE MOTION FOR EXPEDITED HEARING ON DEBTOR’S EXPEDITED MOTION FOR ENTRY OF AN ORDER (I) APPROVING SETTLEMENT AGREEMENT WITH SHELL OIL COMPANY, The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”), hereby files this Ex Parte Motion for Expedited Hearing (the “Motion for Expedited Hearing”) on the Debtor’s Expedited Motion for Entry of an Order (I) Approving Settlement Agreement with Shell Oil Company, Pursuant to Bankruptcy This matter is governed by § 105(a) of the Bankruptcy Code, Bankruptcy Rule 9019, and Rule 9013-1(C) of the Local Rules of the United States Bankruptcy Court for the Eastern District of Louisiana.The Roman Catholic Church of the Archdiocese of New Orleans respectfully requests that the Court enter an Order in substantially the same form as the attached: (i) setting the Settlement Motion for expedited hearing on August 2, 2021, at 1:30 p.m. CST, or such other time as the Court may direct; (ii) fixing the deadline of Friday, July 30, 2021 at 12:00 p.m. CST for filing written objections to the Settlement Motion, provided the hearing is scheduled for August 2, 2021; and (iii) granting such other relief as the Court deems just and appropriate. Dated: July 20, 2021 Respectfully submitted, /s/FOR THE ROMAN CATHOLIC CHURCH OF THE ARCHDIOCESE OF NEW ORLEANS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion is being served (a) on July 20, 2021 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.

List of Tables

Document Contents

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 DEBTOR’S EXPEDITED MOTION FOR ENTRY OF AN ORDER (I) APPROVING SETTLEMENT AGREEMENT WITH SHELL OIL COMPANY, PURSUANT TO BANKRUPTCY RULE 9019, AND (II) GRANTING RELATED RELIEF [Relates to ECF No. 952] The Roman Catholic Church of the Archdiocese of New Orleans, the above-captioned debtor and debtor-in-possession (the “Debtor” or “Archdiocese”), hereby files this Ex Parte Motion for Expedited Hearing (the “Motion for Expedited Hearing”) on the Debtor’s Expedited Motion for Entry of an Order (I) Approving Settlement Agreement with Shell Oil Company, Pursuant to Bankruptcy Rule 9019, and (II) Granting Related Relief [ECF No. 952] (the “Settlement Motion”).2 In support of the Motion for Expedited Hearing, the Debtor respectfully states: 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. 2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Settlement Motion.

1

3. This matter is governed by § 105(a) of the Bankruptcy Code, Bankruptcy Rule 9019, 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 Debtor filed the Settlement Motion simultaneously with this Motion for Expedited Hearing. The Settlement Motion requests that this Court approve and authorize the Debtor to accept the Settlement Agreement. 5. The Settlement Agreement has been finalized and the parties are ready to perform their obligations. Absent expedited hearing, the Settlement Motion would be considered by this Court on the omnibus hearing date of August 19, 2021. Accordingly, the Debtor requests that the Settlement Motion be considered on an expedited basis so that the issues raised therein may be resolved as expeditiously as possible. 6. The Debtor understands that the following option is available for an expedited hearing: • Monday, August 2, 2021, at 1:30 p.m., with responses due Friday, July 30, 2021 7. Counsel for the Debtor contacted counsel for the Abuse Claimants’ Committee, the Commercial Creditors’ Committee, and the UST and has received no objections to the request for expedited hearing, or that the expedited hearing be held on August 2, 2021. WHEREFORE, The Roman Catholic Church of the Archdiocese of New Orleans respectfully requests that the Court enter an Order in substantially the same form as the attached: (i) setting the Settlement Motion for expedited hearing on August 2, 2021, at 1:30 p.m. CST, or such other time as the Court may direct; (ii) fixing the deadline of Friday, July 30, 2021 at 12:00

2

p.m. CST for filing written objections to the Settlement Motion, provided the hearing is scheduled for August 2, 2021; and (iii) granting such other relief as the Court deems just and appropriate. Dated: July 20, 2021 Respectfully submitted, /s/ Mark A. Mintz R. PATRICK VANCE (#13008) ELIZABETH J. FUTRELL (#05863) 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: mmintz@joneswalker.com Email: lashley@joneswalker.com ATTORNEYS FOR THE ROMAN CATHOLIC CHURCH OF THE ARCHDIOCESE OF NEW ORLEANS CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Motion is being served (a) on July 20, 2021 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 Donlin, Recano & Company, Inc. (“DRC”). DRC shall file a certificate of service to that effect once service is completed. /s/ Mark A. Mintz Mark A. Mintz

3