Case 12-13262-BLS Doc 397 Filed 03/18/13 Page 1 of 4 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 REVSTONE INDUSTRIES, LLC, et al, 1 ) Case No. 12-13262 (BLS) Debtors. ) (Jointly Administered) ) ) Related to Docket No. 198 MOTION FOR LEAVE TO EXCEED PAGE LIMIT FOR DEBTORS OMNIBUS REPLY IN SUPPORT OF MOTION OF THE DEBTORS TO EMPLOY AND RETAIN HURON CONSULTING SERVICES LLC TO: (I) PROVIDE A CHIEF RESTRUCTURING OFFICER AND ADDITIONAL PERSONNEL FOR THE DEBTORS PURSUANT TO 11 U.S.C. 363(B), NUNC PRO TUNC TO JANUARY 17,2013; AND (II) PROVIDE FINANCIAL ADVISORY SERVICES TO THE DEBTORS PURSUANT TO 11 U.S.C. 327(A), NUNC PRO TUNC TO THE PERIOD BETWEEN DECEMBER 17, 2012 AND JANUARY 16, 2013 The above-captioned debtors and debtors in possession (collectively, the "Debtors") hereby file this motion (the "Motion") for entry of an order, pursuant to Section 105(a) of Title 11 of the United States Code, 11 U.S.C. 101-1532 (as amended, the "Bankruptcy Code"), and Rule 7007-2 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the "Local Rules"), authorizing the Debtors to exceed the 20-page limit under Local Rule 7007-2 for the Debtors Omnibus Reply In Support Of Motion Of The Debtors To Employ And Retain Huron Consulting Services LLC To (I) Provide A Chief Restructuring Officer And Additional Personnel For The Debtors Pursuant To 11 US. C. 363(B), Nunc Pro Tunc To January 17, 2013; And (II) Provide Financial Advisory Services To The Debtors Pursuant To 11 U S. C. 327(A), Nunc Pro Tunc To The Period Between December The Debtors in these Chapter 11 Cases and the last four digits of each Debtor s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505. DOCSDE: 186402.1 73864/001
Case 12-13262-BLS Doc 397 Filed 03/18/13 Page 2 of 4 17, 2012 And January 16, 2013 (the "Reply"). 2 In support of the relief requested in this Motion, the Debtors respectfully state as follows: JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. 1334. This is a core proceeding pursuant to 28 U.S.C. 157(b)(2), and venue is proper in this district pursuant to 28 U.S.C. 1408 and 1409. BACKGROUND 2. On February 13, 2013, the Debtors filed the Motion Of The Debtors To Employ And Retain Huron Consulting Services LLC To (I) Provide A Chief Restructuring Officer And Additional Personnel For The Debtors Pursuant To 11 US. C. 363(B), Nunc Pro Tunc To January 17, 2013; And (II) Provide Financial Advisory Services To The Debtors Pursuant To 11 US.C. 327(A), Nunc Pro Tunc To The Period Between December 17, 2012 And January 16, 2013 [Docket No. 198] (the "Motion"). 3. The Official Committee of Unsecured Creditors (the "Committee") filed an objection to the Motion [Docket Nos. 265, 326] which was joined by Boston Finance Group, LLC [Docket No. 335]. The Committee then filed a supplemental objection to the Motion [Docket No. 379]. The Office of the United States Trustee also filed an objection to the Motion [Docket No. 355] as did General Motors LLC [Docket No. 361] (collectively, the "Objecting Parties") 2 Capitalized terms not defined herein shall have the meaning provided in the Reply. DOCS_DE:186402. 1 73864/001 2
Case 12-13262-BLS Doc 397 Filed 03/18/13 Page 3 of 4 4. Contemporaneously with the filing of this Motion, the Debtors filed the Reply. RELIEF REQUESTED 5. By this Motion, the Debtors request authority to exceed the 20-page limit for the Reply pursuant to Del. Bankr. LR 7007-2(a)(iv). BASIS FOR RELIEF REQUESTED 6. Local Rule 7007-2(a)(iv) provides that "[w]ithout leave of Court, no opening or answering brief shall exceed forty (40) pages and no reply shall exceed twenty (20) pages, in each instance, exclusive of any tables of contents and citations." Del. Bankr. LR 7007-2(a)(iv). 7. The Debtors respectfully request that the Court grant leave to exceed the 20-page limit for the Reply by no more than 10 pages. The Debtors request the additional pages in order to properly and adequately address all the arguments of the Objecting Parties. 8. Accordingly, the Debtors request leave from the otherwise applicable page limitations to fairly and efficiently present the Reply to the Court. DOCS_DE: 186402.173864/001 3
Case 12-13262-BLS Doc 397 Filed 03/18/13 Page 4 of 4 WHEREFORE, the Debtors respectfully request entry of an order, substantially in the form attached hereto, authorizing the Debtors to file the Reply in excess of 20 pages and granting such additional relief as the Court deems just and proper. Dated: March 18, 2013 PACH1JLSKII STANG ZIEHL & JONES LLP Is! Timothy P. Cairns Laura Davis Jones (Bar No. 2436) Alan J. Kornfeld (CA Bar No. 130063) Maxim B. Litvak (CA Bar No. 215852) Timothy Cairns (Bar No. 4228) 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899-8705 (Courier 19801) Telephone: (302) 652-4100 Facsimile: (302) 652-4400 Email: ljonespszjlaw.com akornfe1dpszjlaw.com mlitvak@pszjlaw.com tcairns@pszjlaw.com [Proposed] Counsel for Debtors and Debtors in Possession DOCS_DE:186402. 1 73864/001 4
Case 12-13262-BLS Doc 397-1 Filed 03/18/13 Page 1 of 2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 REVSTONE INDUSTRIES, LLC, et al, 1 ) Case No. 12-13262 (BLS) Debtors. ) (Jointly Administered) ) Related to Docket No. 198 ORDER GRANTING MOTION FOR LEAVE TO EXCEED PAGE LIMIT FOR DEBTORS OMNIBUS REPLY IN SUPPORT OF MOTION OF THE DEBTORS TO EMPLOY AND RETAIN HURON CONSULTING SERVICES LLC TO: (I) PROVIDE A CHIEF RESTRUCTURING OFFICER AND ADDITIONAL PERSONNEL FOR THE DEBTORS PURSUANT TO 11 U.S.C. 363(B), NUNC PRO TUNC TO JANUARY 17,2013; AND (II) PROVIDE FINANCIAL ADVISORY SERVICES TO THE DEBTORS PURSUANT TO 11 U.S.C. 327(A), NUNC PRO TUNC TO THE PERIOD BETWEEN DECEMBER 17, 2012 AND JANUARY 16, 2013 Upon the motion (the "Motion") of the above-captioned debtors and debtors in possession (collectively, the "Debtors") for leave to exceed the page limit for Debtors Omnibus Reply In Support Of Motion Of The Debtors To Employ And Retain Huron Consulting Services LLC To (I) Provide A Chief Restructuring Officer And Additional Personnel For The Debtors Pursuant To 11 U.S.C. 363(B), Nunc Pro Tune To January 17, 2013; And (II) Provide Financial Advisory Services To The Debtors Pursuant To 11 U.S.C. 327(A), Nunc Pro Tune To The Period Between December 17, 2012 And January 16, 2013 (the "Reply"), and due and proper notice of the Motion having been provided; and it appearing that no other or further notice need be provided; and sufficient cause existing to grant the relief granted herein; it is The Debtors in these Chapter 11 Cases and the last four digits of each Debtor s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505. DOCS_DE: 186402.173 864/00 1
Case 12-13262-BLS Doc 397-1 Filed 03/18/13 Page 2 of 2 ORDERED that the Motion is GRANTED; and it is further ORDERED that the Debtors are authorized to exceed the 20-page limit in the Reply. Dated:.2013 The Honorable Brendon L. Shannon United States Bankruptcy Judge DOCS_DE: 186402.1 73864/001