EXHIBIT B. REQUEST FOR EMERGENCY CONSIDERATION OF CERTAIN "FIRST DAY" MATTERS IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS _________________ DIVISION IN RE: DEBTOR. ' ' ' ' ' CASE NO. __________________ REQUEST FOR EMERGENCY CONSIDERATION OF CERTAIN "FIRST DAY" MATTERS On _______________, __________________________ filed a petition for relief under Chapter 11 of the Bankruptcy Code. Counsel for the debtor believes that the case qualifies as a "Complex Chapter 11 Case." The debtor needs emergency consideration of the following initial case matters (check those that apply): ____ JOINT MOTION FOR JOINT ADMINISTRATION ____ MOTION FOR ORDER EXTENDING TIME TO FILE SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS ____ MOTION RE MAINTENANCE OF BANK ACCOUNTS AND EXISTING CASH MANAGEMENT, ATTACHING NOTICE OF CONFERENCE WITH U.S. TRUSTEE ____ MOTION TO PAY PRE-PETITION WAGES, SALARIES, ET AL., ATTACHING NOTICE OF CONFERENCE WITH U.S. TRUSTEE AND DETAILED EXHIBIT SHOWING WHO DEBTOR PROPOSES TO PAY AND AMOUNTS ____ MOTION FOR ENTRY OF INTERIM ORDER AUTHORIZING USE OF CASH COLLATERAL ____ MOTION FOR INTERIM APPROVAL OF POST-PETITION SECURED AND SUPER PRIORITY FINANCING PURSUANT TO SECTION 364(c) OF THE BANKRUPTCY CODE American LegalNet, Inc. www.FormsWorkflow.com ____ MOTION PURSUANT TO 11 U.S.C. ' 366, FOR ENTRY OF INTERIM ORDER (1) DETERMINING ADEQUATE ASSURANCE OF PAYMENT FOR FUTURE UTILITY SERVICES AND (2) RESTRAINING UTILITY COMPANIES FROM DISCONTINUING, ALTERING, OR REFUSING SERVICE ____ MOTION TO ESTABLISH INTERIM NOTICE PROCEDURES ____ MOTION FOR ORDER APPROVING INTERIM RETENTION OF PROFESSIONALS MOTION FOR ORDER APPROVING PAYMENT OF PRE-PETITION CLAIMS OF CERTAIN CRITICAL VENDORS ____ OTHERS (LIST): _____________________, 200___ Name Address Telephone, Fax Numbers and Email * NOTE: The court expects the parties to exercise judgment regarding which motions are applicable. American LegalNet, Inc. www.FormsWorkflow.com