Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 1 of 6 Stephen A. McCartin (TX 13374700) Mark C. Moore (TX 24074751) GARDERE WYNNE SEWELL LLP 2021 McKinney Avenue, Suite 1600 Dallas, TX 75201 Telephone: (214) 999-3000 Facsimile: (214) 999-4667 smccartin@gardere.com mmoore@gardere.com PROPOSED COUNSEL TO DEBTORS AND DEBTORS-IN-POSSESSION IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION In re: PREFERRED CARE INC., et. al. Debtors. Chapter 11 Case No.: 17-44642 Jointly Administered AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 AT 9:30 A.M. (CST) PLEASE TAKE NOTICE the following matters have been set for hearing on December 18, 2017, at 9:30 A.M. (CST) before the Honorable Mark X. Mullin, Bankruptcy Judge for the Northern District of Texas, Fort Worth Division, at Room 128, U. S. Courthouse, 501 W. 10th Street, Fort Worth, TX 76102: 1. Final Hearing on the Motion for Order (I) Deeming Utilities Adequately Assured of Future Performance; and (II) Establishing Procedures for Determining Requests for Additional Adequate Assurance Pursuant to Bankruptcy Code Section 366 (the Utilities Motion ) [Docket No. 8]; 2. Final Hearing on the Motion for Interim and Final Orders (I) Authorizing the HUD Debtors to Use Cash Collateral, (II) Granting Adequate Protection to Prepetition Lenders and (III) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) [Docket No. 17] (the HUD Debtors Cash Collateral Motion ); AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 1
Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 2 of 6 3. Final Hearing on the Motion for Interim and Final Orders (I) Authorizing Certain Debtors to Use Cash Collateral, (II) Granting Adequate Protection to Prepetition Lenders and (III) Scheduling a Final Hearing Pursuant to Bankruptcy Rule 4001(b) [Docket No. 18] (the Omega and FC Domino Cash Collateral Motion ); 4. Final Hearing on the Motion for Interim and Final Orders (I) Authorizing Debtors to Obtain Post-Petition Financing; (II) Granting Liens, Security Interests and Superpriority Administrative Expense Status; (III) Scheduling a Final Hearing; and (IV) Modifying Automatic Stay Motion [Docket No. 19] (the Wells Fargo DIP Financing Motion ); 5. Final Hearing on the Motion for Entry of Interim and Final Orders (I) Authorizing Debtors to Obtain Back-Up Secured Postpetition Financing; (II) Granting Liens, Security Interests and Superpriority Administrative Expense Status; (III) Modifying the Automatic Stay; and (IV) Scheduling a Final Hearing (the Back-Up DIP Financing Motion ) [Docket No. 52]; and, 6. Order to Show Cause Regarding the Appointment of a Patient Care Ombudsman Pursuant to 11 U.S.C. 333 [Docket No. 71] (the Ombudsman Order ). For the avoidance of doubt, the hearings previously set for December 11, 2017 on the HUD Debtors Cash Collateral Motion, the Omega and FC Domino Cash Collateral Motion, the Wells Fargo DIP Financing Motion, and the Ombudsman Order have been reset and/or continued to December 18, 2017 at 9:30 A.M. (CST). PLEASE TAKE NOTICE that interim orders granting the Utilities Motion, the HUD Debtors Cash Collateral Motion, the Omega and FC Domino Cash Collateral Motion, and the Wells Fargo DIP Financing Motion were entered at Docket Nos. 127, 44, 45, and 46, respectively. An interim order on the Back-Up DIP Financing Motion was entered at Docket No. 128. Copies of the above-referenced motions and the interim orders are available upon request to the undersigned counsel or at the Debtors informational website as indicated below. AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 2
Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 3 of 6 PLEASE TAKE FURTHER NOTICE that any responses or objections to the entry of final orders granting the HUD Debtors Cash Collateral Motion, the Omega and FC Domino Cash Collateral Motion, and/or the Wells Fargo DIP Financing Motion must be in writing, conform to the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the Northern District of Texas, and be filed with the Bankruptcy Court on or before December 13, 2017 at 5:00 p.m. (CST). PLEASE TAKE FURTHER NOTICE that any responses or objections to the entry of a final order granting the Back-Up DIP Financing Motion must be in writing, conform to the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the Northern District of Texas, and be filed with the Bankruptcy Court on or before December 15, 2017 at 5:00 p.m. (CST). PLEASE TAKE FURTHER NOTICE that all pleadings in these Bankruptcy Cases, including proposed orders and exhibits, are available on the Debtors website at www.jndla.com/cases/preferred or on the Bankruptcy Court s website at https://ecf.txnb.uscourts.gov/. You can request any pleading you need from (i) the proposed noticing agent at: JND Corporate Restructuring, 8269 E. 23 rd Avenue, Suite 275, Denver, Colorado, 80238, 855-612-3123 (toll-free), (PreferredInfo@jndla.com) or (ii) counsel for the Debtors listed below. DATED: December 5, 2017 Respectfully submitted by: /s/ Mark C. Moore Stephen A. McCartin (TX 13374700) Mark C. Moore (TX 24074751) GARDERE WYNNE SEWELL LLP 2021 McKinney Avenue, Suite 1600 Dallas, TX 75201 Telephone: (214) 999-3000 Facsimile: (214) 999-4667 AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 3
Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 4 of 6 smccartin@gardere.com mmoore@gardere.com PROPOSED COUNSEL TO DEBTORS AND DEBTORS-IN-POSSESSION CERTIFICATE OF SERVICE I hereby certify that, on December 5, 2017, a true and correct copy of the foregoing document was served electronically by the Court s PACER system. /s/ Mark C. Moore Mark C. Moore AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 4
Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 5 of 6 Debtors Debtor Last Four Digits of Federal Tax I.D. No. Preferred Care Inc. 7040 Kentucky LP Debtors Bowling Green Health Facilities, L.P. 5787 Brandenburg Health Facilities, L.P. 6699 Cadiz Health Facilities, L.P. 7640 Campbellsville Health Facilities, L.P. 4207 Elizabethtown Health Facilities, L.P. 6127 Elsmere Health Facilities, L.P. 7843 Fordsville Health Facilities, L.P. 3299 Franklin Health Facilities, L.P. 7307 Hardinsburg Health Facilities, L.P. 3640 Henderson Health Facilities, L.P. 8067 Irvine Health Facilities, L.P. 7418 Morganfield Health Facilities, L.P. 8320 Owensboro Health Facilities, L.P. 8145 Paducah Health Facilities, L.P. 3350 Pembroke Health Facilities, L.P. 8209 Richmond Health Facilities - Kenwood, L.P. 8235 Richmond Health Facilities - Madison, L.P. 8216 Salyersville Health Facilities, L.P. 8263 Somerset Health Facilities, L.P. 8739 AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 5
Case 17-44642-mxm11 Doc 130 Filed 12/05/17 Entered 12/05/17 14:02:30 Page 6 of 6 Springfield Health Facilities, L.P. 8310 Stanton Health Facilities, L.P. 8704 New Mexico LP Debtors Artesia Health Facilities, L.P. 5383 Bloomfield Health Facilities, L.P. 7640 Clayton Health Facilities, L.P. 3609 Desert Springs Health Facilities, L.P. 2707 Espanola Health Facilities, L.P. 2102 Gallup Health Facilities, L.P. 2562 Lordsburg Health Facilities, L.P. 1449 Pinnacle Health Facilities XXXIII, L.P. 1389 Raton Health Facilities, L.P. 6759 SF Health Facilities, L.P. 2323 SF Health Facilities-Casa Real, L.P. 0716 Silver City Health Facilities, L.P. 6972 AMENDED NOTICE OF HEARING FOR DECEMBER 18, 2017 PAGE 6