Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page1 of 6 UNITED STATES BANKRUPTCY COURT DISTRICT OF COLORADO ) ) ) ) ) )

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1 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page1 of 6 UNITED STATES BANKRUPTCY COURT DISTRICT OF COLORADO In re: Atna Resources Inc., et al. Debtors. 1 Case No JGR Chapter 11 Jointly Administered Under Case No MOTION FOR ORDER SHORTENING NOTICE OF MOTION TO APPROVE BIDDING PROCEDURES Atna Resources Inc. and the affiliated debtors and debtors in possession in these cases (collectively, the Debtors hereby file this Motion for Order Shortening Notice of Motion to Approve Bidding Procedures (the Motion. In support of the Motion, the Debtors respectfully state as follows: 1. On November 18, 2015 (the Petition Date, each of the Debtors filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the Bankruptcy Code. The Debtors are continuing in possession of their property and are operating and managing their business and affairs as debtors in possession pursuant to sections 1107 and 1108 of the Bankruptcy Code. 2. No trustee or examiner has been appointed in these cases. An official committee of unsecured creditors was formed on December 14, 2015 (the Committee. 1 The debtors and debtors in possession and their respective cases numbers are: Atna Resources Inc. ( , Canyon Resources Corporation ( , CR Briggs Corporation ( , CR Montana Corporation ( , CR Kendall Corporation ( , Atna Resources Ltd. ( and Horizon Wyoming Uranium, Inc. (

2 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page2 of 6 3. Contemporaneously with the filing of this Motion, the Debtors filed the Motion for Entry of: (I an Order (A Approving Bidding and Auction Procedures for the Sale of Substantially all of the Debtors Assets, (B Scheduling an Auction, Sale Hearing, and Other Dates and Deadlines, (C Authorizing the Debtors to Designate a Stalking Horse Purchaser and Grant Stalking Horse Protections, (D Approving the Assumption and Assignment of Contracts and Leases and Related Cure Procedures, and (E Granting Related Relief, and (II an Order Approving the Sale of Substantially All of the Debtors Assets Free and Clear of Liens, Claims, and Encumbrances (the Bidding and Sale Motion The Bidding and Sale Motion was filed in accordance with the timeline established by the Order Establishing Procedures for the Conduct of a Restructuring Transaction Process and Granting Related Relief (the Process Order (Docket No Among other things, the Bidding and Sale Motion seeks the entry of a Bid Procedures Order (as defined therein approving bid procedures, cure procedures, certain dates and deadlines, and related relief in connection with the Debtors ongoing sale process (the Sale Process to sell all or a portion of their assets free and clear of all liens, claims, and interests to the fullest extent permitted under section 363 of the Bankruptcy Code and applicable law. 5. Pursuant to Rule (b of the Local Bankruptcy Rules, a motion to approve bidding procedures may, in appropriate circumstances, be heard on a more limited and shortened notice than a sale motion. 6. The Debtors submit that cause exists to shorten the objection period with respect to the entry of the Bid Procedures Order by only two days, from 14 days to 12 days. The primary reason for this request is to enable the Debtors to provide a full 21 days notice of the sale to all creditors as required by Bankruptcy Rule In addition, as the Court is aware, the 2 All terms not otherwise defined herein shall have the meaning ascribed to them in the Bidding and Sale Motion. 2

3 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page3 of 6 Sale Process must be completed prior to the maturity of the Debtors DIP financing facility on May 18, To that end, the Debtors have obtained approval of the Process Order establishing an expedited time frame for completing the Sale Process (which has been ongoing since before the Petition Date. In order to meet the deadlines established by the Process Order, to provide as much notice as possible of the dates and deadlines with respect to the Sale Process to third parties, and to facilitate a completion of the Sale Process by the maturity of the DIP financing facility, the objection deadline for the procedures to be approved pursuant to Bid Procedures Order should be shortened. 7. The relief requested is only a two-day shortening of the notice period and will not prejudice interested parties. To the contrary, the purpose of the relief requested is to allow the Debtors to give adequate notice of the dates and deadlines with respect to the Sale Process and comply with the time restrictions imposed by the Process Order and the expiration of the DIP financing facility on May 18, For these reasons, the Debtors request that the Court enter an order, substantially in the form attached hereto, shortening the notice period from 14 days to 12 days such that any objection to the entry of the Bid Procedures Order must be filed and served so as to be received on or before April 6, WHEREFORE, the Debtors respectfully requests that the Court enter an Order granting the relief requested herein and such other and further relief as the court deems just. 3

4 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page4 of 6 Dated: March 25, 2016 Respectfully submitted, SQUIRE PATTON BOGGS (US LLP /s/ Stephen D. Lerner Stephen D. Lerner (Ohio # Squire Patton Boggs (US LLP 221 E. Fourth Street, Suite 2900 Cincinnati, OH ( (phone ( (fax Stephen.lerner@squirepb.com Admitted to District Court for District of Colorado Nava Hazan (NY # Squire Patton Boggs (US LLP 30 Rockefeller Plaza, 23 rd Floor New York, NY ( ( Nava.hazan@squirepb.com Admitted to District Court for District of Colorado Aaron A. Boschee (Colorado #38675 Squire Patton Boggs (US LLP 1801 California Street, Suite 4900 Denver, CO ( (phone ( (fax Aaron.boschee@squirepb.com Proposed Attorneys for the Debtors and Debtors in Possession 4

5 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page5 of 6 UNITED STATES BANKRUPTCY COURT DISTRICT OF COLORADO In re: Atna Resources Inc., et al. Debtors. 1 Case No JGR Chapter 11 Jointly Administered Under Case No ORDER GRANTING DEBTORS MOTION FOR ORDER SHORTENING NOTICE OF MOTION TO APPROVE BIDDING PROCEDURES THE COURT, having examined the Motion for Order Shortening Notice of Motion to Approve Bidding Procedures (the Motion filed by Atna Resources Inc. and the affiliated debtors and debtors in possession in these cases (collectively, the Debtors, and the Court, being advised in the premises and finding good cause to grant the Motion to Shorten Notice, hereby ORDERS that the Motion is GRANTED. The notice and objection period for the procedural relief requested in the Debtors Motion for Entry of: (I an Order (A Approving Bidding and Auction Procedures for the Sale of Substantially all of the Debtors Assets, (B Scheduling an Auction, Sale Hearing, and Other Dates and Deadlines, (C Authorizing the Debtors to Designate a Stalking Horse Purchaser and Grant Stalking Horse Protections, (D Approving the Assumption and Assignment of Contracts and Leases and Related Cure Procedures, and (E Granting Related Relief, and (II an Order Approving the Sale of Substantially All of the Debtors Assets Free and Clear of Liens, Claims, and Encumbrances (the Bidding and Sale Motion and, in particular, the entry of the Bid Procedures Order (as defined in the Bidding and Sale Motion, is hereby shortened from 14 days to 12 days. Any objections to the entry of the Bid Procedures Order must be made no later than April 6, 2016 at 4:00 p.m. Mountain Time. 1 The debtors and debtors in possession and their respective cases numbers are: Atna Resources Inc. ( , Canyon Resources Corporation ( , CR Briggs Corporation ( , CR Montana Corporation ( , CR Kendall Corporation ( , Atna Resources Ltd. ( and Horizon Wyoming Uranium, Inc. (

6 Case: JGR Doc#:400 Filed:03/25/16 Entered:03/25/16 16:37:32 Page6 of 6 Dated this day of, BY THE COURT: United States Bankruptcy Judge 2