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hereto as Exhibit A), and the procedures provided herein for providing notice of this bankruptcy <br />proceeding, and related motions and deadlines, to approximately 18,000 equity security holders <br />(collectively, the "Shareholders ") of Federal Resources Corporation ( "FRC "). Mailing a one- <br />page, single -sided notice to the Shareholders will cost approximately $7,500- $8,000. To limit <br />the number of times the Debtors are required to provide notice to Shareholders in these jointly <br />administered cases, and to avoid the burdensome administrative cost of providing such notices <br />by mail, the Debtors seek approval from the Court of the Equity Security Holder Notice and <br />related notice procedures. The Debtors further seek approval to pay for the mailing of the Equity <br />Security Holder Notice and other expenses related to providing notice to the Shareholders. <br />MEMORANDUM OF POINTS AND AUTHORITIES <br />I. JURISDICTION <br />The Court has jurisdiction over this matter under 28 U.S.C. §§ 157 and 1334, and this is a <br />core proceeding under § 28 U.S.C. § 157(b)(2)(A). Venue of the Motion is proper before this <br />Court under 28 U.S.C. §§ 1408 and 1409. The statutory predicate for the relief requested herein <br />is 11 U.S.C. § 105(a) and 363(b)(1). <br />H. RELEVANT FACTUAL BACKGROUND <br />The Debtors commenced their respective bankruptcy proceedings on December 29, 2014. <br />These cases are being jointly administered under FRC. On January 12, 2015, FRC filed its List <br />of Equity Security Holders, which contained the names, and last known addresses, of all of <br />FRC's Shareholders as reported in the most recent books and records available to FRC. FRC <br />Dkt. No. 24. That list includes approximately 18,000 Shareholders. The Debtors have obtained <br />several estimates of the costs of mailing a one -page, one -sided document to the 18,000 <br />Shareholders, and these estimates range between $7,500 and $8,000. <br />To avoid the cost to the bankruptcy estate of mailing notices to the Shareholders, while, <br />at the same time, providing the Shareholders with notice of all relevant proceedings in these <br />21086538 2 <br />