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Any future mailings that must be sent to the equity security holders under the Federal <br />Rules of Bankruptcy Procedure or Bankruptcy Code shall be mailed to the most recently filed <br />amended list of equity security holders, and such mailing shall be deemed to have satisfied any <br />notice requirements to the equity security holders provided for under the Federal Rules of <br />Bankruptcy Procedure or Bankruptcy Code. <br />The Debtors believe that the foregoing procedures and attached Equity Security Holder <br />Notice shall reduce the administrative burden providing repeated physically mailed notices to the <br />approximately 18,000 equity security holders, while providing the equity security holders with <br />more than sufficient notice (if not better and more timely notice) of proceedings in these <br />bankruptcy cases. As such, approval of this Motion is in the best interests of the estates, <br />creditors, and other parties in interest. <br />B. The Court should authorize the Debtors to pay the expenses associated with <br />the proposed notice <br />Under 363, the Debtors may use property of the estate related to transactions outside the <br />ordinary course of business only after providing notice and a hearing. 11 U.S.C. § 363(b)(1). <br />The Debtors must justify the use of property of the estate outside the ordinary course with a <br />sounds business purpose. In re Shubh Hotels Pittsburgh, LLC, 439 B.R. 637, 639 (Bankr. W.D. <br />Pa. 2010) (citing cases). <br />Here the Debtors have a sound business purpose. Under the Federal Rules of Bankruptcy <br />Procedures, the Debtors are required to provide notice to equity security holders of certain <br />pleadings and orders of the Court. See Fed. R. Bank. P. 2002(d). The Debtors seek to provide <br />that notice by mailing the Equity Security Holder Notice to the equity security holders and by <br />maintaining the FRC Website. The Debtor anticipates that the mailing will cost approximately <br />$7,500 - $8,000. The FRC Website will cost approximately $500.00 to create and approximately <br />$55.00 per year to host and maintain. These expenses are necessary to comply with the Federal <br />Rules of Bankruptcy Procedures and, therefore, have a sound business purpose. The Court <br />21086538 5 <br />