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

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82. The Liquidating Trustee and the Trust will have delivered adequate notice of this Motion to all affected parties. By this Motion, each Beneficiary is afforded an opportunity to review the manner in which its Claim will be treated for Distribution purposes. The Liquidating Trustee submits that the relief requested herein is consistent with the terms of the Plan, the Liquidating Trust Agreement referenced therein, the Confirmation Order, and furthers the best interests of the Estates and its Creditors as well as the Trust’s Beneficiaries. or any other court. and/or modify this Motion. NO PRIOR APPLICATION 83. No previous application for the relief sought herein has been made to this 84. The Liquidating Trustee reserves its rights to withdraw, supplement, [Continued on the Following Page] 29
WHEREFORE, in light of the foregoing, the Liquidating Trustee for the Trust requests that this Court enter an Order, substantially in the form annexed hereto as Exhibit B granting (i) the relief sought in the Motion in its entirety; and (ii) such other relief this Court deems just and proper. Dated: New York, New York May 12, 2009 STROOCK & STROOCK & LAVAN LLP By: /s/ Kristopher M. Hansen Kristopher M. Hansen James S. Gutierrez 180 Maiden Lane New York, NY 10038 Telephone: (212) 806-5400 Facsimile: (212) 806-6006 Attorneys for The Portrait Liquidating Trust 30
Page 1 and 2: HEARING DATE AND TIME: JUNE 9, 2009
Page 3 and 4: THE EXHIBITS TO THE MOTION, YOU ARE
Page 5 and 6: Portrait Corporation of America, In
Page 7 and 8: BACKGROUND A. The Chapter 11 Cases
Page 9 and 10: 13. On July 11, 2007, the Bankruptc
Page 11 and 12: 20. The purpose of establishing the
Page 13 and 14: (Liquidating Trust Agreement at §
Page 15 and 16: (Plan at § 5.7(d)(ii)). 33. With r
Page 17 and 18: Debtors’ Schedules. By Order date
Page 19 and 20: D. Distributions to Date Made by th
Page 21 and 22: have been disallowed pursuant to Se
Page 23 and 24: substantial potential sources of ad
Page 25 and 26: 64. In order to wind up the Trust a
Page 27 and 28: 3.2(xiii)). Additionally, pursuant
Page 29 and 30: Date, the Liquidating Trustee shall
Page 31: VII. Termination of Employment of E
Page 35 and 36: Exhibit I Estimated Cash Available
Page 37 and 38: Creditor Name and Address Exhibit I
Page 69 and 70: Exhibit II Allowed Senior Notes and
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Creditor Name and Address Exhibit I
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Exhibit III Allowed Administrative,
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Exhibit III Allowed Administrative,
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NY 72065047v4 EXHIBIT A
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Entry of Final Decree Closing These
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NY 72065047v4 EXHIBIT B
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(“Epiq”) as Claims agent in the
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STROOCK & STROOCK & LAVAN LLP Kristopher M - Portrait-trust ...

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