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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE


Inre Chapter 11
CRDENTIA CORP., et al./ Case No. 10-__ _
Debtors. (Joint Administration Requested)
MOTION OF DEBTORS FOR AN ORDER (I) ESTABLISHING BAR DATES
FOR FILING PROOFS OF CLAIM, (II) APPROVING PROOF OF CLAIM
FORM, BAR DATE NOTICES AND MAILING AND PUBLICATION PROCEDURES
AND (III) PROVIDING CERTAIN SUPPLEMENTAL RELIEF
The above-captioned debtors and debtors in possession (collectively, the "Debtors"),
hereby move the Court (the "Motion"), pursuant to section 501 of title 11 of the United States
Code (the "Bankruptcy Code"), Rules 2002 and 3003(c)(3) of the Federal Rules of Bankruptcy
Procedure (the "Bankruptcy Rules"), and Rules 2002-l(e) and 3003-1 of the Local Rules of
Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of
Delaware (the "Local Rules") for the entry of an order: (i) establishing the general bar date by
which all creditors and certain interest holders must file proofs of claim
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in these chapter 11
cases (the "General Bar Date"); (ii) establishing a bar date by which creditors holding claims
which have been amended by the Debtors in their Schedules (as defined below) as the later of the
General Bar Date and twenty (20) days after the date that notice of the amendment is served on
the affected claimant (the "Amended Schedule Bar Date," and together with the General Bar
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The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health Industry Professionals, LLC ( 4246), HIP Holding, Inc.
(3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The
Debtors' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
For purposes of this Motion, the Bar Dates (as defined herein) requested herein shall not extend to requests
for payment of fees and expenses of professionals retained or sought to be retained by order of the Court in
these cases.
Date, the "Bar Dates"); (iii) approving a tailored proof of claim to be distributed to potential
creditors; (iv) approving the forms of notice to be used to inform potential creditors of the Bar
Dates; (vii) approving mailing and publication procedures with respect to notice of the Bar
Dates; and (viii) providing cetiain supplemental relief. In support of this Motion, the Debtors
respectfully represent as follows:
JURISDICTION
1. The Coutt has jurisdiction over this Motion under 28 U.S.C. 157 and
1334. This matter is a core proceeding within the meaning of28 U.S.C. 157(b)(2). Venue of
this proceeding and this Motion is proper in this district pursuant to 28 U.S.C. 1408 and 1409.
2. The statutory predicate for the relief requested herein is section 50 I of the
Banktuptcy Code.
BACKGROUND
3. On March 17, 2010 (the "Petition Date"), the Debtors commenced their
banktuptcy cases by filing voluntaty petitions for relief under chapter 11 of the Bankruptcy
Code. No tmstee, examiner or creditors' committee has been appointed in these cases. The
Debtors are operating their respective businesses as debtors-in-possession pursuant to sections
1107 and 1108 of the Banktuptcy Code.
4. The events leading up to the Petition Date and the facts and circumstances
suppotiing the relief requested herein are set forth in the Declaration of Rebecca Irish in Support
of the Debtors' Chapter II Petitions and First Day Pleadings filed contemporaneously herewith
and incorporated herein by reference.
5. On the Petition Date, the Debtors filed, inter alia, the Debtors' Joint
Chapter 11 Plan of Reorganization (the "Plan"), and a related disclosure statement.
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6. The Debtors anticipate filing their respective Schedules of Assets and
Liabilities and Statements of Financial Affairs within the initial thi:tiy (30) days of these chapter
11 cases in accordance with Local Bankruptcy Rule 1007-1(b).
RELIEF REQUESTED
7. By this Motion, the Debtors seek entry of an order (the "Bar Date Order") (a)
fixing 4:00 p.m. (ET) on April 23, 2010, as the General Bar Date by which proofs of claim
against the Debtors must be filed,
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(b) fixing the Amended Schedule Bar Date as the later of the
General Bar and twenty (20) days after the date that notice of the amendment is served on the
affected claimant, (c) approving a tailored proof of claim form to be dishibuted to creditors, (d)
approving the Debtors' proposed notice of the Bar Dates (the "Bar Date Notice"), (e) approving
mailing and publication procedures with respect to the Bar Date Notice Package (as defined
below), and (f) providing ce1iain supplemental relief
BASIS FOR RELIEF
A. Establishment of Bar Dates
8. Bankruptcy Rule 3003(c)(3) provides that "[t]he court shall fix ... the time within
which proofs of claim or interest may be filed." The Debtors now seek to establish certain Bar
Dates to determine what claims are asseJied against the Debtors. Fixing these Bar Dates will
provide certainty to all prniies in interest and will enable the Debtors to proceed with timely and
effective noticing of the Bar Dates.
Pursuant to section 502(b)(9) of the Bankruptcy Code, a claim by a governmental unit (as such tennis
defined in section 101(27) of the Bankruptcy Code) maybe timely filed up to ISO days after the Petition
Date. Accordingly, the Debtors request that the Court establish September 17, 2010 at 4:00p.m. (ET), as
the General Bar Date applicable to all such governmental units.
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General Bar Date
9. As set forth in the proposed Bar Date Order, submitted herewith and attached
hereto as Exhibit D, the Debtors request that any entity ("Entity")
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that asse1ts a claim against
the Debtors that arose prior to the Petition Date (such Claim a "Prepetition Claim") be required
to file an original, written proof of such Prepetition Claim and one (I) copy, substantially in the
form of the Proof of Claim Fmm (as defined below) or Official Fmm No. 10, so as to be
received on or before the General Bar Date by either mail or delivery by hand, courier, or
overnight service to (i) if via mail, Crdentia Corp., c/o Omni Management Group, LLC 16161
Ventura Blvd., Suite C, PMB 426, Encino, CA 91436, or (ii) if via delivery by hand, courier or
overnight service, Crdentia Corp., c/o Omni Management Group, LLC, 1120 Avenue of the
Americas, 4
1
h Floor, New York, NY I 0036 (either, the "Claims Processing Center").
I 0. The Bar Date Order provides that the Claims Processing Center will not accept
Proof of Claim Fmms sent by facsimile, telecopy, or other electronic means, and the Debtors
request that the Court order that all proofs of claim be deemed timely filed only if the original
Proof of Claim Form is actually received by the Claims Processing Center on or before the
General Bar Date.
11. Except as provided below, the General Bar Date would apply to all Entities
holding Prepetition Claims (whether secured, unsecured priority, or unsecured nonpriority),
including, but not limited to, the following:
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a) creditors whose Prepetition Claims arise out of the rejection of
executory contracts or unexpired leases by the Debtors prior to the
entry of the Bar Date Order;
The term "Entity," as used herein, has the meaning ascribed to it in section 101(15) of the Bankruptcy
Code.
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b) governmental units ("Governmental Units"i holding Prepetition
Claims for unpaid taxes, whether arising from prepetition tax years or
periods or prepetition transactions to which a Debtor was a party; and
c) entities whose Prepetition Claims arise out of the obligations of such
Entities under a contract for the provision of liability insurance to a
Debtor.
12. The General Bar Date would apply to all Prepetition Claims asserted by such
Entities, except that the following Entities would not need to file proofs of claim:
a) any Entity that has already properly filed with the Claims Processing
Center a proof of claim against one or more of the Debtors for which
no other or additional amounts or claims are sought;
b) any Entity (i) whose Prepetition Claim is not listed as "disputed,"
"contingent," or ''unliquidated" in the Schedules and (ii) that agrees
with the nature, classification, and amount of such Prepetition Claim
set forth in the Schedules; and (iii) such entity does not dispute that its
Prepetition Claim is an obligation only of the specific Debtor against
which the Prepetition Claim is listed in the Schedules;
c) any Entity whose Prepetition Claim (including any Prepetition Claim
listed in the Debtors' Schedules) previously has been allowed by, or
paid pursuant to, an order of this Court, including, without limitation,
and subject to entry of an Order of this Court, all general unsecured
claims of trade creditors for goods delivered or services perf01med
Prepetition;
d) any of the Debtors that hold Prepetition Claims against one or more of
the other Debtors; and
e) any equity security holder
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that seeks to assert only stock ownership
interests.
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13. Claims in Classes 2 and 4 are deemed Allowed Claims and holders of such claims
do not need to file Proofs of Claim.
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6
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The term "Governmental U n i ~ " as used herein, has the meaning ascribed to it in section 101(27) of the
Bankruptcy Code.
The term "equity security holder," as used herein, has the meaning ascribed to it in section 101(17) of the
Bankruptcy Code.
Any equity security holder claiming damages or assertiug causes of action based upon or arising from stock
ownership would be required to file a proof of claim by the General Bar Date.
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14. The Debtors also propose that, subject to the provisions proposed below, any
Entity whose Prepetition Claim is othe1wise not listed in the applicable Debtor's Schedules or is
listed as disputed, contingent, or unliquidated and that desires to participate in any of these
chapter II cases or share in any distribution in any of these chapter II cases and any Entity that
believes its Prepetition Claim is improperly classified in the Schedules or is listed in an inconect
amount and that desires to have its Prepetition Claim allowed in a classification or amount other
than that set forth in the Schedules, must file a proof of claim on or before the General Bar Date.
Amended Schedule Bar Date
15. The Debtors propose further that they shall retain the right to: (a) dispute or asseii
offsets or defenses against any filed Prepetition Claim or any Prepetition Claim listed or reflected
in the Schedules as to nature, amount, liability, classification, or otherwise; (b) subsequently
designate any Prepetition Claim as disputed, contingent or unliquidated and (c) add a claim to the
Schedules; provided, however, that if the Debtors amend the Schedules to reduce the undisputed,
noncontingent, and liquidated amount, to change the nature or classification of a Prepetition
Claim reflected therein and/or add a claim to the Schedules, then the affected claimant shall have
until the Amended Schedule Bar Date (i.e., the later of the General Bar Date and twenty (20)
days after the date that notice of the amendment is served on the affected claimant) to file a proof
of claim or to amend any previously filed proof of claim in respect of such amended scheduled
Prepetition Claim or added claim. Notwithstanding the foregoing, nothing set forth herein would
preclude the Debtors from objecting to any Prepetition Claim, whether scheduled or filed, on any
grounds.
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B. Effect of Failure to File by Applicable Bar Date
16. The Debtors propose that, pursuant to Bankruptcy Rule 3003(c)(2), any Entity
that is required to file a proof of claim in these chapter 11 cases pursuant to the Bankruptcy
Code, the Bankruptcy Rules or the order approving this Motion and the relief requested herein
with respect to a particular claim against a Debtor, but that fails to do so in a timely manner,
shall be forever baned, estopped, and enjoined fi'om asserting any Prepetition Claim against any
of the Debtors (or filing a proof of claim with respect thereto), and the Debtors and their property
shall be forever discharged from any and all indebtedness or liability with respect to such
Prepetition Claim. Additionally, any holder of any Prepetition Claim who is required, but fails,
to file a proof of such Prepetition Claim in accordance with the Bar Date Order on or before the
applicable Bar Date shall not be permitted to vote to accept or reject any plan or plans or
patticipate in any distribution in the Debtors' chapter 11 cases on account of such Prepetition
Claim or to receive further notices regarding such Prepetition Claim.
C. Tailored Proof of Claim Form
17. The Debtors have prepared a proof of claim fmm tailored to these cases (the
"Proof of Claim Fonn''), a copy of which is annexed as Exhibit A. The proposed Proof of Claim
Fmm is based on Official Fmm No. 10. The substantive modifications to the Official Form
proposed by the Debtors include the following:
a) personalizing the form to include the name and address of an Entity as
shown in the Debtors' records;
b) including a space for the Entity to cotTect any inconect information
regarding its name and address; and
c) providing additional instructions.
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The Debtors request that the Corut approve the Proof of Claim Form and the substantive
modifications to Official Fmm No. 10 in a form substantially conforming to the Proof of Claim
Form.
18. In accordance with the Proposed Bar Date Order, the Debtors request that the
Corut order that each proof of claim filed must (a) be written in the English language, (b) be
denominated in lawful cunency of the United States, (c) confmm substantially with the Proof of
Claim Form provided or Official Fmm No. 10, as applicable, and (d) attach copies of any
writings upon which the claim is based.
D. Actual Notice of Bar Dates
Actual Notice of the General Bar Date
19. Pursuant to Bankruptcy Rule 2002( a)(7), the Debtors propose to provide actual
notice of the Bar Dates by mailing (a) the Bar Date Notice in substantially the form attached
hereto as Exhibit B; and (b) the Proof of Claim Fmm (together, the "Bar Date Notice Package")
to:
a) the U.S. Trustee;
b) each member of the Committee and counsel for the Committee, if a
committee is appointed in these cases;
c) all holders ofPrepetition Claims listed on the Schedules at the addresses
stated therein;
d) all other patties identified in the Debtors' creditor matrix as filed with the
Co rut;
e) all counterpmties to executory contracts and unexpired leases;
f) all cunent record holders of equity securities of a Debtor;
g) all cunent and former employees of the Debtors that left the employ of the
Debtors on or after January 1, 2009;
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h) all taxing authorities for locations in which the Debtors do business;
i) the Secmities and Exchange Commission;
j) alllienholders;
k) all parties to litigation in which the Debtors are involved;
I) all providers of utility services to the Debtors;
m) all insmance providers;
n) all of the Debtors' ordinary comse professionals;
o) the Debtors' banks;
p) the Debtors' pre- and post-petition secured lenders;
g) all Entities requesting notice pmsuant to Banktuptcy Rule 2002 as of the
entry of the Bar Date Order; and
r) all parties that have filed proofs of claim in these Cases as of the date of
entry of the Bar Date Order.
(collectively, the "Bar Date Notice Parties").
20. The Debtors further reserve the right, out of an abundance of caution, to serve the
Bar Date Notice to ce1tain Entities not described above with which, prior to the Petition Date, the
Debtors had done business or that may have asserted a claim against the Debtors in the recent
past.
21. The proposed Bar Date Notice Package includes a proposed Bar Date Notice that
notifies the pmties of the Bar Dates and contains information regmding who must file a proof of
claim, the procedmes for filing a proof of claim, and the consequences of failure to timely file a
proof of claim.
22. The Debtors request that the Court approve the form and use of the Bar Date
Notice Package.
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Actual Notice of Amended Schedule Bar Date. as necessary
23. If and when the Debtors amend their Schedules to reduce the undisputed,
noncontingent, and liquidated amount, to change the nature or classification of a Prepetition
Claim or to add a claim, the Debtors will provide notice to the affected claimant of any such
amended or added claim, which will include information regarding the Amended Schedule Bar
Date and how to file a proof of claim or amend an existing proof of claim.
24. The Debtors request that the Comi approve this method of notice of the Amended
Schedule Bar Date.
E. Timing of Proposed Notice by Mail
25. Based upon the relation of the General Bar Date to the timing of filing the
Schedules and Statements, the number of Entities to whom the Debtors propose to provide
notice, including all creditors and record equity security holders who are entitled to receive
notice, the Debtors, pursuant to Bankruptcy Rule 2002(a)(7) and Local Rule 2002-1(e), intend to
mail the Bar Date Notice Package to all known creditors within three (3) business days following
entry of the Bar Date Order. If the Bar Date Order is entered following expedited consideration
of this Motion on or about March 18, 2010 (as the Debtors are contemporaneously requesting),
creditors will be assured thirty-six (36) days notice of the General Bar Date. Such notice period
is well in excess of the twenty (20) day notice period required under Bankmptcy Rule 2002(a)(7)
and will provide creditors ample time within which to prepare and file proofs of claim, if
necessary.
Supplemental Mailings
26. However, after the initial mailing occurs as provided for above, the Debtors
anticipate that they may be required to make supplemental mailings of the Bar Date Notice
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Package in a number of situations including in the event that: (a) Bar Date Notice Packages are
retmned by the post office with forwarding addresses, necessitating a remailing to the new
addresses, (b) certain parties acting on behalf of parties in interest (e.g., banks and brokers with
respect to equity security holders) decline to forward Bar Date Notice Packages to such parties
and instead retmn their names and addresses to the Debtors for direct mailing, and (c) additional
potential claimants become known to the Debtors (collectively, the "Special Bar Date Parties").
Therefore, the Debtors request the right to make supplemental mailings of the Bar Date Notice
Package up to twenty (20) days in advance of the applicable Bar Dates, with any such
supplemental mailings being deemed timely.
27. While the Debtors anticipate there may be a need to establish one or more later
special bar dates and request the right to do so below, the Debtors believe that the proposed
supplemental mailing of the Bar Date Notice Package will serve to preserve the integrity of the
Bar Dates, will reduce the number of special bar dates that may need to be established, will
permit the claims process to be completed expeditiously, and will ease the administrative burden
of these cases.
Establishment ofSpecial Bar Dates
28. To minimize the time and expense associated with having to seek subsequent
orders fiom this Court, the Debtors request that they be permitted to establish special bar dates
with respect to the Special Bar Date Patties as to which a mailing or remailing of the Bat Date
Notice Package is necessary and cannot be accomplished prior to twenty (20) days in advance of
an applicable Bar Date. With respect to the Special Bar Date Parties, the Debtors request the
right to establish special bat dates at least twenty (20) days after the date on which the Debtors
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mail the notice of each such special bar date. Such notice will take substantially the form of the
Bar Date Notice (with necessary modifications to reflect the special bar date provisions).
29. The Debtors submit that twenty (20) days' notice of each special bar date is
appropriate, rather than the longer period provided in connection with the other Bar Dates,
because any such special bar dates will be established later in these cases and must be structured
so as not to delay the progress of these cases, and because such special bar dates will be
applicable to parties who will be receiving notice directly, presumably within three (3) days of
mailing, rather than t1nough intermediate channels that may delay ultimate receipt Moreover,
the Debtors anticipate establishing special bar dates on a very limited basis, and only if necessary
to ensure adequate bar date noticing and discharge protection, to the extent applicable. The vast
majority of patties in interest will be subject to the Bar Dates and will receive as much as thitty-
six (36) days' notice.
30. The Debtors propose to advise this Court of the establishment of each special bar
date by filing a notice, together with a list that specifically identifies the Special Bar Date Patties
that are subject thereto and a copy of the bat date notice applicable to the special bar date. In
addition to being filed with this Court, such notice will be served upon the US. Trustee, and
counsel for the Committee, if a committee is appointed in these cases. A cettificate of service
will be subsequently filed to evidence the mailing of each special bar date notice to the patties
subject thereto.
31. Each of the special bar dates will apply only to the Special Bar Date Patties who
are specifically identified as being subject thereto in the lists to be filed with the Court.
However, as to any of such specifically identified patties who may be found to have received
effective notice of the Bar Dates, the Debtors do not waive the right to assert that the Bat Dates,
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rather than the special bar date, govem. Moreover, the Bar Dates will remain effective, and it is
the Debtors' intention that they be fully enforceable both with respect to known parties who have
received actual notice thereof pursuant to the Bar Date Notice and with respect to unknown
parties who are deemed to have received constructive notice thereof pursuant to the Publication
Notice (as defined below).
F. Assistance in Noticing
32. To the extent that the Debtors require any assistance with the preparation and
mailing of notices pmsuant to the Bar Date Order, including, for example, ensuring proper
distribution of the Bar Date Notice Package to equity security holders, the Debtors request that
the Debtors be authorized to employ and pay necessary service providers. The Debtors further
request that they be authorized to take such other actions as may be necessary to ensure timely
preparation and mailing of the Bar Date Notice Package.
G. Filing Proofs of Claim against Multiple Debtors
33. The Debtors propose that all Entities assetting claims against more than one
Debtor be required to file a separate proof of claim with respect to each such Debtor. If Entities
are pemritted to assert claims against more than one Debtor in a single proof of claim, the Claims
Processing Center may have difficulty maintaining separate claim registers for each Debtor, and
all named Debtors will be required to object to a proof of claim that may be applicable to only
one of the named Debtors. Likewise, Entities should be required to identifY on each proof of
claim, the particular Debtor against which their claim is asserted. Requiring Entities to identify
the Debtor against which a claim is assetted will greatly expedite the Debtors' review of proofs
of claim in these cases. This requirement will not be unduly burdensome on claimants since such
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Entities will know or should know the identity of the Debtor against which they are asserting a
claim.
H. Publication of Notice
34. The nature of the Debtors' businesses creates the potential for the existence of
claims against the Debtors of which the Debtors are unaware. Such unknown potential claims
may include, for example, claims of trade vendors who failed to submit an invoice to the
Debtors, claims of former employees, and claims that, for various reasons, are not recorded on
the Debtors' books and records. Accordingly, the Debtors believe that it is necessary to provide
notice of the Bar Dates to Entities whose names and addresses are unknown to the Debtors and,
in addition, that it is advisable to provide supplemental notice to known holders of claims.
Therefore, pmsuant to Bankruptcy Rule 2002(1), the Debtors request authority to publish notice
of the Bar Dates substantially in the form annexed as Exhibit C hereto (the "Publication
Notice") in the national edition of The Wall Street Journal as soon as practicable following filing
of the Debtors' Schedules and Statements and entry of the Bar Date Order, but in any event no
later than twenty (20) days prior to the General Bar Date.
35. The Publication Notice will include a telephone number that potential creditors
may call ancl instructions concerning how they may obtain copies of the Proof of Claim Form
and information conceming the procedmes for filing proofs of claim.
36. The Debtors request that the Court find that the Debtors' proposed procedures
regarding the Publication Notice will provide good, adequate, and sufficient publication notice of
the Bar Dates.
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NOTICE OF TIDS MOTION
37. Notice of the Motion has been provided to: (a) the United States Trustee; (b) those
parties listed on the consolidated list of creditors holding the twenty (20) largest unsecured
claims against the Debtors, as identified in their chapter 11 petitions; (c) counsel for the Debtors'
secured lender, Com Vest Capital, LLC; and (d) all other persons or entities that have requested
notice pursuant to Bankruptcy Rule 2002( i). In light of the nature of the relief requested herein,
the Debtors submit that no other or futiher notice is required.
NO PRIOR REQUEST
38. No previous request for the relief sought in this Motion has been made to this
Court or any other couti.
WHEREFORE, the Debtors respectfully request that the Court enter an order,
substantially in the form attached hereto as Exhibit D: (i) approving (a) the Bar Dates; (b) the
Proof of Claim Form; (c) the form and manner of provision of the Bar Date Notice Package and
the Publication Notice and (ii) granting such other and futiher relief as the Court may deem
proper.
March 17,2010
Wilmington, Delaware
BAYARD,P.A
Jamie L. Edmonson (No. 4247)
222 Delaware A venue, Suite 900
Wilmington, DE 19801
Phone: (302) 655-5000
Fax: (302) 658-6395
-and-
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GERSTEN SAVAGE, LLP
Paul Rachmuth
600 Lexington A venue
New York, New York 10022
Telephone: (212) 752-9700
Facsimile: (212) 980-5192
Proposed Counsel for the Debtors and
Debtors in Possession
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EXHIBIT A
PROOF OF CLAIM FORM
EXHIBITB
Bar Date Notice
In re
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., eta!./ Case No. 10-

Debtors. (Joint Administration Requested)
NOTICE OF DEADLINE OF [ , 2010] AT 4:00P.M. (ET)
TO FILE PROOFS OF CLAIM
PLEASE TAKE NOTICE OF THE FOLLOWING:
On March 17, 2010, (the "Petition Date"), Crdentia Corp., ATS Universal, LLC, Baker Anderson
Christie, Inc., CRDE Corp., GHS Acquisition Corporation, Health Industry Professionals, LLC, HIP Holding,
Inc., MP Health Corp., New Age Staffing, Inc. and Nurses Network, Inc., (the filed voluntary
petitions for relief under chapter 11 of title 11 of the United States Bankmptcy Comt (as amended, the
"Bankruptcy Code") in the United States Bankruptcy Comt for the District of Delaware (the "Comt").
Under the Bankruptcy Code, the Debtors are granted certain protections against creditors. A creditor is
anyone to whom the Debtors owe money or prope1ty. Creditors are prohibited from taking any actions to
collect money or property from the Debtors. If unauthorized actions are taken by a creditor against any of the
Debtors, the Court may penalize that creditor. A creditor who is considering taking action against any of the
Debtors, or property of the Debtors, may wish to consult an attorney. The staff of the Clerk of the Comt is not
permitted to give legal advice.
Prepetition Claim Bar Date
By Order of this Comt entered on [ ], 2010 (the "Bar Date Order"), the last date and
time for filing proofs of claim against the Debtors for any and all Prepetition Claims (as defined below) is
[ , 2010] at 4:00 p.m. (ET) (the "General Bar Date"), provided that the bar date applicable to
governmental units (as defined in section 101(27) of the Bankrnptcy Code) is [ , 2010 at 4:00
p.m. (ET). The General Bar Date and the procedures set fo1th below for the filing of proofs of claim apply to all
claims against the Debtors that arose on or before the Petition Date.
You MUST file a proof of claim if you have a claim that arose on or before the Petition Date,
and it is not an Excluded Prepetition Claim (as defined below). Acts or omissions of the Debtors that arose on
or before the Petition Date may give rise to claims against the Debtors notwithstanding that such claims may not
have matured or become fixed or liquidated prior to such date. Under section 101(5) of the Bankruptcy Code as
used herein, the word "claim'' means (a) a right to payment, whether or not such right is reduced to judgment,
liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured,
or unsecured, or (b) right to an equitable remedy for breach of performance if such breach gives rise to a right to
payment, whether or not such right to an equitable remedy is reduced to judgment, fixed, contingent, matured,
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia Corp.(5701), ATS
Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509), GHS Acquisition Corporation (9736),
Health Industry Professionals, LLC (4246), HIP Holding, Inc. (3468), MP Health Corp. (4403), New Age Staffing, Inc.
(1214) and Nurses Network, Inc. (6291). The Debtors' mailing address for purposes of these cases is 1964 Howell Branch
Road, Ste. 206, Winter Park, Florida 32792.
unmatured, disputed, undisputed, secured, or unsecured. All entities asserting claims against more than one
Debtor are reguired to file a separate proof of claim with respect to each such Debtor.
The General Bar Date applies to all Prepetition Claims, except that the following entities do not
need to file proofS of claim:
(a) any entity that has already properly filed with the Claims Processing Center (as defined below) a
proof of claim against one or more of the Debtors for which no other or additional amounts or
claims are sought;
(b) any entity that has already properly filed with the Claims Processing Center a proof of claim
against one or more of the Debtors for which no other or additional amounts or claims are
sought;
(c) any entity (i) whose Prepetition Claim is not listed as "disputed," "contingent," or "unliquidated"
in the Schedules and ( ii) that agrees with the nature, classification, and amount of such
Prepetition Claim set fo1th in the Schedules; and (iii) such entity does not dispute that its
Prepetition Claim is an obligation only of the specific Debtor against which the Prepetition
Claim is listed in the Schedules;
(d) any entity whose Prepetition Claim (including any Prepetition Claim listed in the Debtors'
Schedules) previously has been allowed by, or paid pursuant to, an order of this Court, including,
without limitation, and subject to entry of an Order of this Court, general unsecured claims of
trade creditors for goods delivered or services performed Prepetition;
(e) any of the Debtors that hold Prepetition Claims against one or more of the other Debtors; and
(f) any equity security holder that seeks to assert only stock ownership interests
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The foregoing claims are collectively refened to herein as the "Excluded Prepetition Claims."
YOU SHOULD NOT FILE A PROOF OF CLAIM IF YOU DO NOT HAVE A CLAIM AGAINST A
DEBTOR. THE FACT THAT YOU HAVE RECEIVED THIS NOTICE DOES NOT MEAN THAT YOU
HAVE A CLAIM OR THAT THE DEBTORS OR THE COURT BELIEVE THAT YOU HAVE A CLAIM.
EXCEPT WITH RESPECT TO EXCLUDED PREPETITION CLAIMS, ANY ENTITY WHO FAILS
TO FILE A PROOF OF CLAIM ON OR BEFORE [ , 2010] AT 4:00 P.M. (ET), FOR ANY
PREPETITION CLAIMS THAT SUCH ENTITY HOLDS OR WISHES TO ASSERT AGAINST A
DEBTOR, WILL BE FOREVER BARRED, ESTOPPED AND ENJOINED FROM ASSERTING SUCH
PREPETITION CLAIM (OR FILING A PROOF OF CLAIM WITH RESPECT TO SUCH PREPETITION
CLAIM) AGAINST THE DEBTORS, AND THE DEBTORS AND THEIR PROPERTY WILL BE
FOREVER DISCHARGED FROM ANY AND ALL INDEBTEDNESS OR LIABILITY WITH RESPECT
TO SUCH PREPETITION CLAIM, AND SUCH ENTITY SHALL NOT BE PERMITTED TO VOTE ON
ANY PLAN OR PARTICIPATE IN ANY DISTRIBUTION IN THESE CHAPTER 11 CASES ON
ACCOUNT OF SUCH PREPETITION CLAIM, OR TO RECEIVE FURTHER NOTICES REGARDING
SUCH PREPETITION CLAIM.
Procedures Applicable to the Filing of Proofs of Claim
Except as provided herein, proofs of claim must be filed so as to be received on or before [ ___ ~ ~
2010] at 4:00p.m. (ET).
2
Any equity security holder claiming damages or asserting causes of action based upon or arising from
stock ownership would be required to file a proof of claim by the General Bar Date.
2
A proof of claim will be deemed timely filed only if the original proof of claim is mailed or delivered by
hand, courier or overnight service so as to be actually received by the Clerk of Court for the United States
Bankruptcy fm the District of Delaware, at the following addresses (the "Claims Processing Center") on or before
the General Bar Date:
If via U.S. mail:
Crdentia Corp.
c/o Ornni Management Group, LLC
16161 Ventura Blvd., Suite C
PMB426
Encino, CA 91436
If via delivery by hand, courier, or overnight
service:
Crdentia Corp.
c/o Ornni Management Group, LLC
1120 Avenue of the America's, 4th Floor
New York, NY 10036
Proofs of claim may not be sent by facsimile, telecopy or other electronic means.
If you file a proof of claim, your filed proof of claim must: (a) be written in the English language, (b) be
denominated in lawful currency of the United States, (c) conform substantially with the enclosed proof of claim
form or to Official Form No. 10, (d) attach copies of any writings upon which your asserted Prepetition Claim is
based, and (e) be signed by the claimant OT by an authorized agent of the claimant. If a proof of claim form is not
enclosed herewith, you may obtain a proof of claim form by written request to [ ], sent to [ ], faxed to [
], by calling [ ] at [ ], or at the website address [ ]. You may also obtain a proof of claim form
from any bankruptcy comi clerk's office, from your lawyer or from certain business supply stores.
Copies of the Bar Date Order are available and may be examined by interested parties: (i) at the website
maintained for these cases at the address [ ], (ii) at the office of the Clerk of the Court, 824 North Market
Street, Wilmington, Delaware 19801 between the hours of 8:00a.m. and 3:00p.m. (ET), or (iii) on the Court's
electronic docket of these cases at the address www.deb.uscourts.gov.
If you have any questions regarding the filing, amount, nature or processing of a proof of claim, please
call Claims Processing Center at (_) _-__ . YOU SHOULD CONSULT YOUR ATTORNEY
REGARDING ANY OTHER INQUIRIES, SUCH AS WHETHER YOU SHOULD FILE A PROOF OF CLAIM.
DO NOT ATTEMPT TO CONTACT THE COURT FOR ADVICE. .
Dated: =:--c:----=--:----' 201 0
Wilmington, Delaware
BY ORDER OF THE UNITED STATES BANKRUPTCY COURT
3
EXHIBITC
PUBLICATION NOTICE
In re
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., et al./ Case No. 10-__ _
Debtors. (Joint Administration Requested)
NOTICE OF DEADLINE OF AT 4:00P.M. (ET)
TO FILE PROOFS OF CLAIM
To All Persons and Entities with Claims Against Crdentia Corp., ATS Universal, LLC,
Baker Anderson Christie, Inc., CRDE Corp., GHS Acquisition Corporation, Health Industly
Professionals, LLC, HIP Holding, Inc., MP Health Corp., New Age Staffing, Inc., Nurses
Network, Inc. (the "Debtors"):
Bar Date. Pursuant to an order of this Comt entered on [ , 2010] (the "Bar
Date Order"), and in accordance with Fed. R. Bankr. P. 3003(c), all entities (except
governmental units and those entities that are excused pursuant to the Bar Date Order) who have
a claim or potential claim against the Debtors that arose on or before March 17, 201 0 (the
"Petition Date"), no matter how remote or contingent such claim may be, MUST FILE A
PROOF OF CLAIM on or before 2010) at 4:00p.m. (ET) (the "Bar Date").
ANY ENTITY (EXCEPT AN ENTITY WHO IS EXCUSED BY THE TERMS OF THE
BAR DATE ORDER) THAT FAILS TO FILE A PROOF OF CLAIM ON OR BEFORE THE
BAR DATE SHALL BE FOREVER BARRED, ESTOPPED, AND ENJOINED FROM
ASSERTING SUCH CLAIM (OR FILING A PROOF OF CLAIM WITH RESPECT TO SUCH
CLAIM) AGAINST THE DEBTORS AND THE DEBTORS AND THEIR PROPERTY WILL
BE FOREVER DISCHARGED FROM ANY AND ALL INDEBTEDNESS OR LIABILITY
WITH RESPECT TO SUCH CLAIM, AND SUCH ENTITY SHALL NOT BE PERMITTED
TO VOTE ON ANY PLAN OR PARTICIPATE IN ANY DISTRIBUTION IN THESE
CHAPTER 11 CASES ON ACCOUNT OF SUCH CLAIM, OR TO RECEIVE FURTHER
NOTICES REGARDING SUCH CLAIM.
Procedure for Filing Proofs of Claim. Proofs of claim must be filed so as to be received
on or before [ , 2010) at 4:00p.m. (ET), at the appropriate address listed below:
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, luc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health ludustry Professionals, LLC ( 4246), HIP Holdiog, luc.
(3468), MP Health Corp. (4403), New Age Staffing, luc. (1214) and Nurses Network, Inc. (6291). The
Debtors' mailiog address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
If via U.S. mail:
Crdentia Corp.
c/o Omni Management Group, LLC
16161 Ventura Blvd., Suite C
PMB 426
Encino, CA 91436
If via delivery by hand, courier, or overnight
service:
Crdentia Corp.
c/o Omni Management Group, LLC
1120 Avenue of the America's, 4th Floor
New York, NY 10036
Proofs of claim may not be sent by facsimile, telecopy or other electronic means. You may
obtain a proof of claim form by written request to [ ], sent to [ ], faxed to [ ], by
calling [ ] at [ ], or at the website address [ ]. You may also obtain a proof of
claim fonn from any bankruptcy court clerk's office, from your lawyer or from certain business
supply stores. If you wish to obtain Copies of the Debtors' schedules of assets and liabilities
(when available) and the Bar Date Order, they aTe available and may be examined by
interested parties (i) at the website maintained for these cases at the address [ ] (ii) at
the office of the Clerk of the Court, 824 North Market Street, Wilmington, Delaware 19801
between the hours of 8:00a.m. and 3:00p.m. (ET), or (iii) on the Court's electronic docket
of these cases at the address www.deb.uscourts.gov. If you have questions regarding the
filing, nature or processing of a proof of claim, you may call [ ] at [ ].
Dated: , 2010
Wilmington, DelawaTe
BY ORDER OF THE UNITED STATES BANKRUPTCY COURT
EXIITBITD
PROPOSED ORDER
In re
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., eta!./ Case No. 10-
---
Debtors. (Joint Administration Requested)
Re:D.I. __ _
ORDER (I) ESTABLISIDNG BAR DATES FOR FILING
PROOFS OF CLAIM, (II) APPROVING PROOF OF CLAIM FORM,
BAR DATE NOTICES AND MAILING AND PUBLICATION PROCEDURES
AND (ill) PROVIDING CERTAIN SUPPLEMENTAL RELIEF
Upon the motion (the "Motion")
2
of the above-captioned debtors and debtors in
possession in the above-captioned cases (collectively, the "Debtors"), for the entry of an Order,
pursuant to section 501 the Bankruptcy Code, Banktuptcy Rules 2002 and 3003(c)(3) and Local
Rules 2002-l(e) and 3003-1, (i) establishing the General Bar Date by which all creditors and
certain interest holders must file proofs of claim
3
in these chapter 11 cases; (ii) establishing the
Amended Schedule Bar Date by which creditors holding claims which have been amended by
the Debtors in their Schedules as the later of the General Bar Date and twenty (20) days after the
date that notice of the amendment is served on the affected claimant; (iii) approving the tailored
Proof of Claim Form to be distributed to potential creditors; (iv) approving the Bar Date Notice
and the Publication Notice to be used to inform potential creditors of the Bar Dates; (v)
2
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health Industry Professionals, LLC ( 4246), IDP Holding, Inc.
(3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The
Debtors' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
Capitalized terms not defined herein have the meanings set forth in the Motion.
The Bar Dates approved by this Order shall not extend to requests for payment of fees and expenses of
professionals retained or sought to be retained by order of the Court in these cases.
approving mailing and publication procedures with respect to notice of the Bar Dates; and (vi)
providing certain supplemental relief; and it appearing that the relief requested in the Motion is
in the best interest of the Debtors and their estates and that the establishment of the Bar Dates
and the procedures set fmih in the Motion are fair and reasonable and will provide good,
sufficient and proper notice to all creditors of their rights and obligations in connection with
claims they may have against the Debtors or their property in these chapter 11 cases; and the
Court finding that (i) the Comi has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334 and (ii) this is a core proceeding pursuant to 28 U.S.C. 157(b)(2); and notice of this
Motion having been due and sufficient under the circumstances; and upon the record therein; and
after due deliberation thereon; and good and sufficient cause appearing therefor;
IT IS HEREBY ORDERED:
1. The Motion is GRANTED.
2. The Bar Dates set forth in the Motion are hereby APPROVED.
3. The forms of the Bar Date Notice, the Publication Notice, the Proof of Claim
Form, substantially in the form attached to the Motion, and the manner of providing notice of the
Bar Dates proposed in the Motion, are APPROVED. The form and manner of notice of the Bar
Dates are deemed to fulfill the notice requirements of the applicable provisions of the
Bankruptcy Code, the Bankruptcy Rules and the Local Rules.
4. The General Bar Date by which proofs of claim against the Debtors must be filed
1s 4:00 p.m. (ET) on April 23, 2010, provided, however, that the General Bar Date for
governmental units (as such te1m is defined in section 101(27) of the Bankruptcy Code) is 4:00
p.m. (ET) on September 17,2010.
2
5. Any Entity that asserts a Prepetition Claim against the Debtors is required to file
an original, written proof of such Prepetition Claim and one (I) copy, substantially in the form of
the Proof of Claim Form or Official Form No. 10, so as to be received on or before the General
Bar Date by either mail or delivery by hand, courier, or overnight service to (i) if via mail,
Crdentia Corp., c/o Omni Management Group, LLC 16161 Ventura Blvd., Suite C, PMB 426,
Encino, CA 91436, or (ii) if via delivery by hand, courier or overnight service, Crdentia Corp.,
c/o Omni Management Group, LLC, 1120 Avenue of the Americas, 4th Floor, New York, NY
10036 (either, the "Claims Processing Center").
6. The Claims Processing Center will not accept Proof of Claim Forms sent by
facsimile, telecopy, or other electronic means. A proof of claim shall be timely filed only if the
original Proof of Claim Form is actually received by the Claims Processing Center on or before
the General Bar Date.
7. The following Entities do not need to file proofs of claim:
(a) any Entity that has already properly filed with the Claims Processing
Center a proof of claim against one or more of the Debtors for which no
other or additional amounts or claims me sought;
(b) any Entity (i) whose Prepetition Claim is not listed as "disputed,"
"contingent," or ''unliquidated" in the Schedules and (ii) that agrees with
the nature, classification, and aTnount of such Prepetition Claim set forth
in the Schedules and (iii) such entity does not dispute that its Prepetition
Claim is an obligation only of the specific Debtor against which the
Prepetition Claim is listed in the Schedules;
(c) any Entity whose Prepetition Claim previously has been allowed by, or
paid pursuant to, an order of this Court, including, without limitation,
general unsecured claims of trade creditors for good delivered or services
performed Prepetition;
(d) any ofthe Debtors that hold Prepetition Claims against one or more of the
other Debtors; and
3
(e) any equity security holder that seeks to assert only stock ownership
interests
4
8. Claims in Classes 2 and 4 are deemed Allowed Claims and holders of such claims
do not need to file Proofs of Claim
9. Any Entity whose Prepetition Claim is not listed in the applicable Debtor's
Schedules or is listed as disputed, contingent or unliquidated and that desires to participate in any
of these chapter cases or share in any distribution in any of these chapter 11 cases and any Entity
that believes its Prepetition Claim is improperly classified in the Schedules or is listed in an
incorrect amount and that desires to have its Prepetition Claim allowed in a classification or
amount other than that set forth in the Schedules, must file a proof of claim on or before the
General Bar Date.
10. The Amended Schedule Bar Date for creditors holding claims which have been
amended by the Debtors in their Schedules or added by the Debtors to the Schedules is the later
of (a) the General Bar Date and (b) twenty (20) days after the date that notice of the amendment
or addition is served on the affected claimant.
11. Entities wishing to file proofs of claim with respect to claims which have been
amended by the Debtors in their Schedules or added thereto are required to file an original proof
of such claim using the Proof of Claim Form so as to be received on or before the Amended
Schedule Bar Date by either mail or delivery by hand, courier, or ovemight service at the
appropriate address identified above for the Claims Processing Center.
12. The Claims Processing Center will not accept Proof of Claim Forms sent by
facsimile, telecopy, or other electronic means. A proof of claim with respect to a claim which
4
Any equity security holder claiming damages or asserting causes of action based upon or arising from stock
ownership is required to file a proof of claim by the General Bar Date.
4
has been amended by the Debtors in their Schedules or added thereto shall be timely filed only if
the original Proof of Claim Form is actually received by the Claims Processing Center on or
before the Amended Schedule Bar Date.
13. Each proof of claim filed must: (a) be written in the English language, (b) be
denominated in lawful cunency of the United States, (c) conform substantially with the Proof of
Claim Form provided or Official Form No. 10, as applicable, and (d) attach copies of any
writings upon which the claim is based.
14. Upon the advance express written consent of the Debtors, a proof of claim may be
filed without the writings upon which the Prepetition Claim is based, as required by Bankruptcy
Rules 3001(c) and (d) and this Order; provided, however, that, upon request of the Debtors or
any other patty in interest in these cases, any creditor that receives such written consent shall be
required to transmit promptly such writings to the Debtors and the party in interest making such
request as soon as reasonably practicable, but in no event later than ten (10) business days from
the date of such request.
15. All Entities asserting claims against more than one Debtor me required to: (a) file
a separate proof of claim with respect to each such Debtor and (b) identify on each proof of
claim the patticular Debtor against which their claim is asserted.
16. Any Entity that is required pursuant to this Order to file a proof of claim in these
chapter 11 cases pursuant to the Bankruptcy Code, the Bankruptcy Rules or this Order with
respect to a patticular claim against a Debtor, but that fails to do so on or by an applicable Bar
Date, is forever baned, estopped, and enjoined fiom: (a) asserting any Prepetition Claim against
any of the Debtors (or filing a proof of claim with respect thereto), and the Debtors and their
property shall be forever discharged from any and all indebtedness or liability with respect to
5
such Prepetition Claim. Additionally, any holder of any Prepetition Claim who is required, but
fails, to file a proof of such Prepetition Claim in accordance with this Order on or before the
applicable Bar Date shall not be permitted to vote to accept or reject any plan or plans or
pmiicipate in any distribution in the Debtors' chapter 11 cases on account of such Prepetition
Claim or to receive further notices regarding such Prepetition Claim.
17. The Debtors shall provide actual notice of the Bar Dates by mailing the Bar Date
Notice and the Proof of Claim Form (together, the "Bm Date Notice Package") within three (3)
business days of the entry of this Order to: (a) the U.S. Trustee; (b) each member of the
Committee and counsel for the Committee, if a committee is appointed; (c) all holders of
Prepetition Claims listed on the Debtors' books and records; (d) all other parties identified on the
Debtors' creditor matrix, as filed with the Comi; (e) all counterpmiies to executory contracts and
unexpired leases; (f) all record holders of equity security interests of a Debtor as of the Petition
Date; (g) all cunent and former employees of the Debtors that left the employ of the Debtors on
or after January 1, 2009; (h) all taxing authorities for locations in which the Debtors do business;
(i) the Securities and Exchange Commission; (j) all lienholders; (k) all parties to litigation in
which the Debtors are involved; (I) all providers of utility services to the Debtors; (m) all
insurance providers; (n) all of the Debtors' ordinary course professionals; (o) the Debtors' banks;
(p) the Debtors' prepetition secured lenders; ( q) all Entities requesting notice pursuant to
Bankruptcy Rule 2002 as of the entry of this Order; and (r) all pmiies that have filed proofs of
claim in these cases as of the date of entry of this Order (collectively, the "Bar Date Notice
Pmiies").
18. The Debtors may, in their discretion, but shall not be required to, serve the Bar
Date Notice to certain Entities that me not Bar Date Notice Parties with which, prior to the
6
Petition Date, the Debtors had done business or that may have asserted a claim against the
Debtors in the recent past.
19. In the event that: (a) Bar Date Notice Packages are returned by the post office
with forwarding addresses, necessitating a remailing to the new addresses, (b) certain parties
acting on behalf of parties in interest (e.g., banks and brokers with respect to equity security
holders) decline to pass along Bar Date Notice Packages to such parties and instead retum their
names and adch"esses to the Debtors for direct mailing, and (c) additional potential claimants
become known to the Debtors (collectively, the "Special Bar Date Parties"), the Debtors may, in
their discretion, but shall not be required to make supplemental mailings of the Bar Date Notice
Package up to twenty (20) days in advance of the applicable Bar Dates, with any such
supplemental mailings being deemed timely.
20. The Debtors are authorized to establish special bar dates with respect to the
Special Bar Date Parties as to which a mailing or remailing of the Bar Date Notice Package is
necessary and cannot be accomplished prior to twenty (20) days in advance of an applicable Bar
Date. With respect to the Special Bar Date Parties, the Debtors are authorized to establish
special bar dates at least twenty (20) days after the date on which the Debtors mail the notice of
each such special bar date. Such notice will substantially take the form of the Bar Date Notice
(with necessary modifications to reflect the special bar date provisions). The Debtors shall
advise the Comt of the establishment of each special bar date by filing a notice, together with a
list that specifically identifies the Special Bar Date Parties that are subject thereto and a copy of
the bar date notice applicable to the special bar date. In addition to being filed with the Court,
the Debtors shall serve such notice upon the U.S. Trustee and counsel for the Committee. The
7
Debtors shall f:tle a certificate of service to evidence the mailing of each special bar date notice to
the parties subject thereto.
21. Each of the special bar dates will apply only to the Special Bar Date Pmiies who
are specifically identified as being subject thereto in the lists to be filed with the Court. As to
any of such specifically identified paliies, however, who may be found to have received effective
notice of the Bm Dates, the Debtors do not waive the right to asseri that the Bm Dates, rather
than the special bar date, governs. The Bar Dates will remain effective and fully enforceable
both with respect to known parties who have received actual notice thereof pursuant to the Bar
Date Notice and with respect to unknown paliies who me deemed to have received constructive
notice thereof pursuant to the Publication Notice.
22. If and when the Debtors alllend their Schedules to reduce the undisputed,
noncontingent and liquidated amount, to change the nature or classification of a Prepetition
Claim or add a claim to the Schedules, the Debtors shall provide notice to the affected claimant
of any such amended or added claim, which shall include information regarding the Amended
Schedule Bm Date and how to file a proof of claim or amend an existing proof of claim.
23. To the extent that the Debtors require any assistance with the preparation and
mailing of the Bar Date Notice Package, the Debtors are authorized to employ and pay necessmy
service providers. The Debtors are further authmized to take such other actions as may be
necessmy to ensure timely preparation and mailing of the Bar Date Notice Package.
24. The Debtors shall cause the Publication Notice to be published in the national
edition of The Wall Street JoUinal as soon as practicable after the filing of the Schedules and
Statements, but in any event no later than twenty (20) days prior to the earliest of the Bar Dates.
8
25. The Debtors shall retain and hereby reserve the right to: (a) dispute, or assert
offsets or defenses, against any Prepetition Claim; (b) subsequently designate any Prepetition
Claim as disputed, contingent or unliquidated; and (c) object to any Prepetition Claim, whether
scheduled or filed, on any grounds.
26. The Debtors are authorized and empowered to take such steps and perform such
actions as may be necessary to implement and effectuate the terms of this Order, including
payment of costs incuned in connection with the process of noticing the Bar Dates.
27. The Court shall retain jurisdiction over all matters arising out of or related to the
Motion and this Order.
Dated: March_, 2010
Wilmington, Delaware
UNITED STATES BANKRUPTCY ruDGE
9