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

which Beneficiaries receiving a Distribution of less than $100.00 to make a written request to the
Trust to receive such Distribution; (iv) approving a supplemental distribution dollar threshold;
(v) approving the Liquidating Trustee’s request to destroy certain records and abandon certain
property; (vi) the termination of Epiq Bankruptcy Solutions, LLC (“Epiq”) as Claims agent in
these Chapter 11 Cases (as defined below); and (vii) this Court granting the Liquidating Trustee
and the Trust other and further relief it deems just and proper.
2. Notice of this Motion has been provided to the Beneficiaries set forth in
the schedules annexed hereto as Exhibits II and III (collectively, the “Exhibits”). 4
3. The Exhibits annexed hereto were prepared based upon the information
contained in the Debtors’ Schedules, the proofs of Claim filed in these Chapter 11 Cases, Orders
of this Court allowing and/or disallowing Claims, Orders of this Court approving stipulations of
settlement with certain creditors, and the Claims register maintained by Epiq, the Claims agent
retained by the Debtors in connection with their Chapter 11 Cases.
JURISDICTION AND VENUE
4. This Court has subject matter jurisdiction to consider this Motion pursuant
to (i) 28 U.S.C. §§ 157 and 1334 and (ii) the Plan and Confirmation Order. This is a core
proceeding pursuant to 28 U.S.C. § 157(b)(2)(B) and (O) and may be determined by the
Bankruptcy Court. Venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 1409.
5. The statutory predicates for the relief requested in this Motion are Sections
105, 350 and 554 of title 11 of the United States Code (the “Bankruptcy Code”) and Rules 3021,
3022 and 6007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”).
4 Exhibit I annexed hereto sets forth information regarding the amounts of Allowed Claims and the Estimated
Cash Available for Final Distribution from the Liquidating Trust.
3