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

these Estates including Court fees, fees owed to the Office of the United States Trustee, and
other expenses will have been paid.
77. Accordingly, pursuant to Section 350 (a) of the Bankruptcy Code and
Bankruptcy Rule 3022, the Liquidating Trustee hereby seeks the entry of a final decree of the
Court closing the Chapter 11 Cases upon the filing of the Final Report of Distributions of the
Liquidating Trust without further notice or hearing. The Liquidating Trustee proposes to submit
a proposed order closing the Chapter 11 Cases upon the dissolution of the Liquidating Trust (the
“Final Decree”). A copy of the proposed Final Decree is attached hereto as Exhibit A.
78. The Final Decree will include provisions including, among other things,:
(i) the release of the Debtors and Liquidating Trustee and all of their officers, affiliates,
employees, agents, professionals or representatives of any and all liability relating to the
administration of the Liquidating Trust and the assets in the custody of the Trust; and (ii) the
retention of exclusive jurisdiction by this Court to reopen the Chapter 11 Cases, if necessary
pursuant to Section 350(b) of the Bankruptcy Code, which states in relevant part that a case may
be reopened to administer assets. Specifically, Section 350 of the Bankruptcy Code provides that
“[a] case may be reopened . . . to administer assets, to accord relief to the debtor, or for other
cause.” 11 U.S.C. § 350; see also Bankruptcy Rule 5010 (“A case may be reopened on motion
of the debtor or other party in interest pursuant to § 350(b) of the Code”).
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