UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Debtor(s) : : : : : : : : : Hearing Date: Time: Chapter 11 Case No. Jointly Administerd APPLICATION FOR [NAME OF DEBTOR] FOR AN ORDER AUTHORIZING DEBTORS TO TERMINATE CONTRACT WITH OFFICIAL CLAIMS AGENT TO THE HONORABLE [NAME] UNITED STATES BANKRUPTCY JUDGE [Name of Debtor] and any other debtors and/or debtor-in-possession in the abovecaptioned chapter 11 cases (collectively, the debtors), hereby apply to this court for an order, substantially in the form attached hereto as Exhibit A ( the “Proposed Order”), authorizing the debtors to terminate their contract with [name of outside agent] (the “outside agent”), the official claims agent for these chapter 11 cases. In support of this Application, debtors respectfully state as follows: BACKGROUND 1. On [date], the (the “Filing Date”), each of the debtors filed a voluntary petition under Chapter 11, Title 11 of the United States Code, 11 U.S.C. §§ 101 et seq. (the “Bankruptcy Code”). The debtors’ chapter 11 cases were substantially consolidated on [date]. Pursuant to §§ 1107(a) and 1108 of the Bankruptcy Code, the debtors have remained in possession of their properties and continue to operate their businesses. 2. On [date] the U.S. Trustee appointed an official committee of unsecured creditors (the “Creditors’ Committee). No trustee or examiner was appointed in these chapter 11 cases. BASIS FOR RELIEF REQUESTED American LegalNet, Inc. www.USCourtForms.com 3. Pursuant to the Agreement between outside agent and debtor dated [date] (the “outside agent Contract), the outside agent agreed to provide the debtors with computerized bankruptcy support services and bankruptcy administrative services. By order dated [date], this court approved the outside agent contract and appointed the outside agent to act as Official Claims Agent, pursuant to 28 U.S.C. § 156(c). The outside agent has continuously performed in that capacity since that time and has maintained and recorded the proofs of claim filed in these chapter 11 cases. 4. The debtors retained the services of the outside agent in order to expedite the processing of claims and to relieve the Clerk’s Office of the Bankruptcy Court of the administrative burden that would otherwise be imposed by a case of this size and complexity. The court, however, no longer requires the services of the outside agent. Pursuant to an order of the court, [date] was established as the date on or before which proofs of claim asserted against the debtors’ estates had to be filed with the court or such claims would thereafter be barred from being asserted against the debtors. Pursuant to the order confirming the debtors’ first amended plan or re-organization, [date] was fixed as the date by which all administrative priority claims against the debtors’ estates must be filed. Nearly all pre-petition and administrative claims filed in this case have been resolved. There being no further need to expend additional sums on the outside agents service, the debtors therefore seek an order authorizing them to terminate the outside agent contract. 5. Accordingly, by this application, the debtors respectfully request that this court enter the Proposed Order, authorizing the debtors to terminate the outside agent contract. 6. No previous motion for the relief sought herein has been made to this or any other court. 7. Notice of this application has been given to the U.S. Trustee and the counsel to the Creditors’ Committee. 8. The consent of the Clerk of the Court is reflected on the Proposed Order submitted to the court. WHEREFORE, debtor request that this court enter the Proposed Order authorizing the debtors to terminate the outside agent contract and grant such other and further relief as is just American LegalNet, Inc. www.USCourtForms.com and proper. Dated: New York, New York Respectfully submitted, [name of firm] By: Attorneys for Debtors [Address] American LegalNet, Inc. www.USCourtForms.com