Case Doc 207 Filed 03/13/19 Entered 03/13/19 16:15:37 Desc Main Document Page 1 of 5

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1 Document Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: TOTAL FINANCE INVESTMENT INC., et al., 1 Debtors. Chapter 11 Case No (CAD) Jointly Administered AMENDED AGENDA FOR HEARING Time and Date of Hearing: Location of Hearing: Copies of Motions: March 14, 2019, at 1:30 p.m. (Central Time) The Honorable Carol A. Doyle Courtroom No. 742 United States Bankruptcy Court for the Northern District of Illinois 219 S. Dearborn Street Chicago, Illinois A copy of each pleading can be viewed on the Court s website at and at the website of the Debtors notice and claims agent, KCC LLC ( KCC ), at UNCONTESTED MATTERS 1. Sidley Retention. Debtors Application for Entry of an Order Authorizing the Retention and Employment Of Sidley Austin LLP as Attorneys for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 95] B. Proposed Order Regarding Retention of Sidley Austin LLP [Docket No. 203] 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Total Finance Investment Inc. (3753); Car Outlet Holding Inc. (8362); Car Outlet AC LLC (2282); Full Service Auto Repair AC LLC (6920); Todo Seguro AC LLC (7099); Todo Seguro Premium Finance AC LLC (3775); and Total Finance AC LLC (1965). The Debtors mailing address is 3400 N. Pulaski Rd, Chicago, IL

2 Document Page 2 of 5 2. Togut Retention. Debtors Application For Entry of an Order Pursuant to Bankruptcy Code Sections 327(a) and 328 Authorizing the Employment And Retention Of Togut, Segal & Segal LLP as Co-Counsel to the Car Outlet Debtors and Debtors In Possession, Nunc Pro Tunc to the Petition Date [Docket No. 96] A. Proposed Order Regarding Retention of Togut, Segal & Segal LLP [Docket No. 192] 3. Mayer Brown Retention. Debtors Application for Entry of an Order Authorizing the Retention and Employment of Mayer Brown LLP as Special Tax Claims Counsel for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 97] B. Proposed Order Regarding Retention of Mayer Brown LLP [Docket No. 205] 4. CRO Retention. Debtors Motion for Entry of an Order, Effective Nunc Pro Tunc to the Petition Date, (I) Authorizing the Debtors to (A) Designate Patrick O Malley as Chief Restructuring Officer and (B) Utilize Development Specialists, Inc. Personnel; and (II) Approving the Agreement Related Thereto [Docket No. 138] Certificate of No Objection [Docket No. 193] 5. Portage Point Retention. Debtors Application for Entry of An Order Authorizing the Retention and Employment of Portage Point Partners, LLC as Financial Advisor for the Debtors and Debtors in Possession, Nunc Pro Tunc to the Petition Date [Docket No. 141] Certificate of No Objection [Docket No. 193] 2

3 Document Page 3 of 5 6. Freeborn & Peters LLP Retention. Application of the Official Committee of Unsecured Creditors to Employ Freeborn & Peters LLP and its Attorneys as Counsel [Docket No. 136] Certificate of No Objection [Docket No. 185] 7. Interim Compensation Procedures. Debtors Motion for Entry of an Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 144] Certificate of No Objection [Docket No. 193] 8. Lease Rejection. Amended Debtors First Omnibus Motion for Entry of an Order (I) Authorizing the Debtors to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Abandon Certain Personal Property in Connection Therewith and (II) Granting Related Relief [Docket No. 149] B. Proposed Order Regarding Motion for Debtors to Reject Certain Leases [Docket No. 197] 9. Ordinary Course Professionals. Debtors Motion for Entry of an Order Authorizing the Debtors to Retain and Compensate Certain Professionals Utilized in the Ordinary Course of Business, Nunc Pro Tunc to the Petition Date [Docket No. 142] Certificate of No Objection [Docket No. 193] A proposed final order will be presented to the Court 10. Adelman & Gettleman Withdrawal. Motion to Withdraw as Counsel for David Samuels [Docket No. 170] 3

4 Document Page 4 of 5 None MATTERS GOING FORWARD 11. Servicing Agreement. Motion of the Debtors for Entry of an Order (I) Authorizing the Debtors to Assume the Servicing Agreement with Westlake Portfolio Management, LLC and (II) Granting Related Relief [Docket No. 143] A. Objection of the Official Committee of Unsecured Creditors to the Motion to Assume the Servicing Agreement [Docket No. 187] B. Debtors Omnibus Reply in Support of the Motion to Assume the Servicing Agreement and KERP Motion [Docket No. 198] C. Declaration of Todd Laruffa in Support of the Motion to Assume the Servicing Agreement [Docket No. 200] 12. KERP. Motion of the Debtors for Entry of an Order (I) Authorizing the Debtors to Honor Obligations under the Prepetition Key Employee Retention Program and (II) Granting Related Relief [Docket No. 139] A. Objection of the Official Committee of Unsecured Creditors to the KERP Motion [Docket No. 186] B. Redacted Exhibits to the KERP Motion [189] C. Debtors Omnibus Reply in Support of the Motion to Assume the Servicing Agreement and KERP Motion [Docket No. 198] 13. DIP Financing and Cash Collateral. Debtors Motion for Entry of Interim and Final Orders (I) Authorizing (A) Secured Post-Petition financing on a Super- Priority Basis Pursuant to 11 U.S.C. 364, (B) Use of Cash Collateral Pursuant to 11 U.S.C. 363 and (C) Grant of Adequate Protection Pursuant to 11 U.S.C

5 Document Page 5 of 5 and 364, (II) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(c), and (III) Granting Related Relief [Docket No. 18] A. Declaration of Stuart Kaufman in support of DIP Financing and Cash Collateral Motion [Docket No. 19] B. Proposed Interim Order Regarding DIP Financing and Cash Collateral [Docket No. 34] C. Interim Order Regarding DIP Financing and Cash Collateral [Docket No. 50] D. Objection of the of the Official Committee of Unsecured Creditors to the DIP Financing and Cash Collateral Motion [Docket No. 190] E. Debtors Reply to the Objection of the Official Committee of Unsecured Creditors to the DIP Financing and Cash Collateral Motion [Docket No. 199] F. Proposed Final Order Regarding DIP Financing and Cash Collateral [Docket No. 201] Dated: March 13, 2019 Chicago, Illinois SIDLEY AUSTIN LLP /s/ Bojan Guzina Bojan Guzina (ARDC # ) Jackson T. Garvey (ARDC # ) One South Dearborn Street Chicago, Illinois Telephone: (312) Facsimile: (312) PROPOSED ATTORNEYS FOR THE DEBTORS AND DEBTORS IN POSSESSION 5