2020-07-23_GENERAL DOCUMENTS - C1980004

• Permit No: C1980004
• IBM Index Class Name: General Documents
• Doc Date: 7/23/2020
• Doc Name Note: Case No. 20-12043 ‎(GRH)‎ Hopedale Mining LLC
• Doc Name: Debtors Expedited Motion for Entry of an Order ‎(1)‎ Scheduling an Expedited Hearing on & Shortening
• From: EBS Noticing
• To: DRMS
• Permit Index Doc Type: General Correspondence
• Email Name: JRS
• Email Name: JDM
• Email Name: GRM
• Email Name: CMM
• Email Name: CCW
• Media Type: D
• Archive: No

From:EBS-Noticing EBS-Not Fax:[phone] To:[e-mail] Fax:[phone] Page:8 of 33 0712312020 4:17 PM
Case 1:20-bk-12043 Doc 25 Filed 07/22/20 Entered 07/22/20 20:45:12 Desc Main
Document Page 5 of 8
(c) Retention Application
(i) Epiq Application — Application of Debtors for Entry of an Order
Appointing Epiq Corporate Restructuring, LLC as Claims and Noticing
Agent Effective as of the Petition Date.
RELIEF REQUESTED
I. Need for Emergency Hearing
9. The Debtors request that an emergency hearing on the First Day Motions be held
in the afternoon on Thursday, July 23, 2020, or any time on Friday, July 24, 2020. In light of
General Order 35-5 and other applicable Orders of Court, Debtors acknowledge that any
hearing will be telephonic or will utilize some other electronic process to avoid an in-person,
in-court hearing.
10. The Debtors respectfully request that the Court hear the parties as soon as
practicable. The Debtors are mindful of the need for due process, and have shared drafts of their
filed First Day Motions with their primary stakeholders in advance of the Petition Date. In addition,
the Debtors have also shared drafts of their filed First Day Motions, exclusive of the DIP Financing
and Cash Collateral Motion,to the Office of the United States Trustee ("US Trustee") in advance
of the Petition Date and have had a number of productive discussions with the US Trustee
regarding the nature of the requested relief.
11. As set forth in detail in each of the First Day Motions and the First Day Declaration,
the relief requested is essential to the Debtors' operations and, in turn,their ability to successfully
utilize the chapter 11 process. Any meaningful delay with respect to the relief requested in the
First Day Motions would severely hinder the Debtors' ability to preserve and maximize the value
of their estates for the benefit of their creditors.
12. As soon as possible after filing, not to exceed one business day, the Debtors will
serve this Motion,the Order setting hearing on First Day Motions,the First Day Declaration, and
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