Request For Emergency Consideration Of Certain First Day Matters (Exhibit B)

EXHIBIT B. REQUEST FOR EMERGENCY CONSIDERATION OF CERTAIN "FIRST DAY" MATTERS IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS _________________ DIVISION IN RE: ' ' ' ' ' CASE NO. __________________ DEBTOR. REQUEST FOR EMERGENCY CONSIDERATION OF CERTAIN "FIRST DAY" MATTERS On _______________, __________________________ filed a petition for relief under Chapter 11 of the Bankruptcy Code. Counsel for the debtor believes that the case qualifies as a "Complex Chapter 11 Case." The debtor needs emergency consideration of the following initial case matters (check those that apply): ____ ____ ____ JOINT MOTION FOR JOINT ADMINISTRATION MOTION FOR ORDER EXTENDING TIME TO FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS MOTION RE MAINTENANCE OF BANK ACCOUNTS AND EXISTING CASH MANAGEMENT, ATTACHING NOTICE OF CONFERENCE WITH U.S. TRUSTEE MOTION TO PAY PRE-PETITION WAGES, SALARIES, ET AL., ATTACHING NOTICE OF CONFERENCE WITH U.S. TRUSTEE AND DETAILED EXHIBIT SHOWING WHO DEBTOR PROPOSES TO PAY AND AMOUNTS MOTION FOR ENTRY OF INTERIM ORDER AUTHORIZING USE OF CASH COLLATERAL MOTION FOR INTERIM APPROVAL OF POST-PETITION SECURED AND SUPER PRIORITY FINANCING PURSUANT TO SECTION 364(c) OF THE BANKRUPTCY CODE ____ ____ ____ American LegalNet, Inc. www.FormsWorkflow.com ____ MOTION PURSUANT TO 11 U.S.C. ' 366, FOR ENTRY OF INTERIM ORDER (1) DETERMINING ADEQUATE ASSURANCE OF PAYMENT FOR FUTURE UTILITY SERVICES AND (2) RESTRAINING UTILITY COMPANIES FROM DISCONTINUING, ALTERING, OR REFUSING SERVICE MOTION TO ESTABLISH INTERIM NOTICE PROCEDURES MOTION FOR ORDER APPROVING INTERIM RETENTION OF PROFESSIONALS MOTION FOR ORDER APPROVING PAYMENT OF PRE-PETITION CLAIMS OF CERTAIN CRITICAL VENDORS ____ ____ ____ OTHERS (LIST): _____________________, 200___ Name Address Telephone, Fax Numbers and Email * NOTE: The court expects the parties to exercise judgment regarding which motions are applicable. American LegalNet, Inc. www.FormsWorkflow.com