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Full title: Motion to Allow Geoffrey S. Goodman to Appear Telephonically at November 18, 2021 Hearing, filed by Liquidating Trustee of Cambrian Liquidating Trust. (Attachments: # (1) Proposed Order) (Barber, T.)

Document posted on Nov 16, 2021 in the bankruptcy, 3 pages and 0 tables.

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AT NOVEMBER 18, 2021 HEARING Ellen Arvin Kennedy, solely in her capacity as the Liquidating Trustee (the “Liquidating Trustee”) of the Cambrian Liquidating Trust (the “Liquidating Trust”), by and through its counsel, respectfully moves the Court (the “Motion”) for entry of an order permitting the Geoffrey S. Goodman (“Mr. Goodman”) to appear telephonically at the hearing scheduled for November 18, 2021 at 9:00 a.m. (the “Hearing”).The Hearing is currently scheduled for Thursday, November 18, 2021 at 9:00 a.m. to consider the Motion of the Liquidating Trustee for a Status Conference Regarding Transfer of Permits and for Shortened Notice [ECF No. 1875] (the “Status Conference Motion”). 1 The “Debtors” in these chapter 11 cases are (with the last four digits of their federal tax identification numbers in parentheses): Cambrian Holding Company, Inc. (8203), Cambrian Coal LLC (3394), Apex Energy, Inc. (3455), C.W. Auguring, Inc. (2875), Marshall Resources, Inc. (9735), PLM Holding Company LLC (7427), Bear Branch Coal LLC (0674), Clintwood Elkhorn Mining LLC (6910), Gatliff Coal LLC (5768), Perry County Coal LLC (4382), Ray Coal LLC (0981), Whitaker Coal LLC (8270), Pike-Letcher Land LLC (8952), Premier Elkhorn Coal LLC (8951), Raven Rock Development LLC (1351), Rich Mountain Coal LLC (1974), S.T. & T. Leasing, Inc. (0340), T.C. Leasing, Inc. (7705), and Shelby Resources, LLC (5085). WHEREFORE, the Liquidating Trustee respectfully requests that the Court enter an order (i) authorizing Mr. Goodman to appear telephonically at the Court’s Hearing; and (ii) granting such other and further relief as the Court may deem just and proper. NOTICE Notice is hereby given that pursuant to KYEB LBR 9013-1(c), the Trustee requests that this Court grant this Motion without notice or opportunity for hearing.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF KENTUCKY LEXINGTON DIVISION In re: Chapter 11 Cambrian Holding Company, Inc., et al.,1 Case No. 19-51200 Debtors. (Jointly Administered) MOTION TO ALLOW GEOFFREY S. GOODMAN TO APPEAR TELEPHONICALLY AT NOVEMBER 18, 2021 HEARING Ellen Arvin Kennedy, solely in her capacity as the Liquidating Trustee (the “Liquidating Trustee”) of the Cambrian Liquidating Trust (the “Liquidating Trust”), by and through its counsel, respectfully moves the Court (the “Motion”) for entry of an order permitting the Geoffrey S. Goodman (“Mr. Goodman”) to appear telephonically at the hearing scheduled for November 18, 2021 at 9:00 a.m. (the “Hearing”). In support of this Motion, the Liquidating Trustee respectfully states as follows: 1. The Hearing is currently scheduled for Thursday, November 18, 2021 at 9:00 a.m. to consider the Motion of the Liquidating Trustee for a Status Conference Regarding Transfer of Permits and for Shortened Notice [ECF No. 1875] (the “Status Conference Motion”). The Trustee respectfully requests that Mr. Goodman be allowed to appear telephonically at the Hearing on the Status Conference Motion. 1 The “Debtors” in these chapter 11 cases are (with the last four digits of their federal tax identification numbers in parentheses): Cambrian Holding Company, Inc. (8203), Cambrian Coal LLC (3394), Apex Energy, Inc. (3455), C.W. Auguring, Inc. (2875), Marshall Resources, Inc. (9735), PLM Holding Company LLC (7427), Bear Branch Coal LLC (0674), Clintwood Elkhorn Mining LLC (6910), Gatliff Coal LLC (5768), Perry County Coal LLC (4382), Ray Coal LLC (0981), Whitaker Coal LLC (8270), Pike-Letcher Land LLC (8952), Premier Elkhorn Coal LLC (8951), Raven Rock Development LLC (1351), Rich Mountain Coal LLC (1974), S.T. & T. Leasing, Inc. (0340), T.C. Leasing, Inc. (7705), and Shelby Resources, LLC (5085).

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2. The Trustee did not believe that the filing of the Status Conference Motion would be necessary until this week. Due to the timing of the filing of the Status Conference Motion, it would be burdensome for the estates for Mr. Goodman to schedule a flight on shortened notice. The Trustee believes that Mr. Goodman’s remarks to the Court will be brief and can be effectively delivered via telephone. WHEREFORE, the Liquidating Trustee respectfully requests that the Court enter an order (i) authorizing Mr. Goodman to appear telephonically at the Court’s Hearing; and (ii) granting such other and further relief as the Court may deem just and proper. NOTICE Notice is hereby given that pursuant to KYEB LBR 9013-1(c), the Trustee requests that this Court grant this Motion without notice or opportunity for hearing. The Trustee submits that such relief is appropriate in this instance due to the nature of the relief requested and the short time between the filing of the Status Conference Motion and the Hearing. 2

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Respectfully submitted, By: /s/ Geoffrey S. Goodman Geoffrey S. Goodman IL Bar No. 6272297 (Admitted Pro Hac Vice) FOLEY & LARDNER LLP 321 N. Clark Street, Suite 2800 Chicago, Illinois 60654 Telephone: (312) 832-4500 Facsimile: (312) 832-4700 ggoodman@foley.com and /s/ T. Kent Barber KY Bar No. 092456 T. Kent Barber BARBER LAW PLLC 200 Burrus Drive Lexington, Kentucky 40513 Telephone: (859) 296-4372 kbarber@barberlawky.com COUNSEL FOR LIQUIDATING TRUSTEE CERTIFICATE OF SERVICE This document has been electronically filed and served via the Court’s ECF System on November 17, 2021 /s/ T. Kent Barber COUNSEL FOR THE LIQUIDATING TRUSTEE 3

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