STROOCK & STROOCK & LAVAN LLP Kristopher M - Portrait-trust ...

I. The Final Distribution
(iv) Approving a $50,000.00 threshold requirement in order to make a
Supplemental Distribution and if that threshold is not reached, authorizing
the Liquidating Trustee to make a charitable donation of all monies
remaining in the Trust;
(v) Authorizing the Liquidating Trustee to abandon, destroy or
otherwise dispose of any or all of the records or remaining property of the
Debtors;
(vi) Approving the proposed entry of a final decree closing these
Chapter 11 Cases;
(vii) Approving the termination of Epiq (formerly known as Bankruptcy
Services, LLC) as Claims agent in these Chapter 11 Cases; and
(viii) Granting the Liquidating Trustee and the Liquidating Trust other
and further relief this Court deems just and proper.
55. While the Plan and the Confirmation Order do not require the Liquidating
Trustee to obtain this Court’s approval prior to making a Final Distribution, Article XI of the
Plan and Paragraph 22 of the Confirmation Order grant this Court broad post-confirmation
jurisdiction allowing this Court to make the determinations of the matters set forth and grant the
relief sought herein. By this Motion, the Liquidating Trustee is opting to exercise its right to
seek this Court’s approval prior to making a Final Distribution to the Beneficiaries of the Trust.
56. As noted above, the remaining tangible assets of the Liquidating Trust
consist of (i) approximately $1,830,000.00 in Cash including estimated receivables net of
Reserves; and (ii) certain documents, books and records related to the Debtors’ and Liquidating
Trust’s Assets.
57. The Liquidating Trustee submits that Court approval of the Final
Distribution is appropriate because in the reasonable business judgment of the Liquidating
Trustee, substantially all of the assets of the Liquidating Trust have been liquidated, there are no
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