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serve notice of the Disclosure Statement hearing and objection deadline (the "Hearing Notice") <br />upon all parties -in -interest and serve copies of the Plan and Disclosure Statement upon certain <br />parties by no later than August 19, 2020. <br />6. The Hearing Notice and copies of the Plan and Disclosure Statement were not <br />mailed on August 19, 2020 and were later mailed on August 25, 2020. The individual assigned <br />to conduct the mailing was to complete the mailing on August 19, 2020 before taking a short <br />vacation. When this individual returned to work on August 25, 2020 the undersigned was <br />informed that the mailing had not gone out. The undersigned immediately ensured that the <br />mailing was completed on August 25, 2020. That individual is no longer employed by Miller & <br />Law, P.C. <br />7. On August 25, 2020, a copy of the Hearing Notice attached hereto as Exhibit A <br />was served upon every party -in -interest (the complete service matrix) as well as various certain <br />regulatory agencies identified below. <br />8. In addition to the Notice of Hearing, copies of the Plan and Disclosure statement <br />were served upon the US Trustee, the Chapter 11 Trustee, the Debtor at both addresses listed in <br />the matrix, the Debtor's principal Stephen Guyer (the Debtor does not have counsel), all three <br />members of the Creditor's Committee (the Committee does not have counsel), the IRS at two <br />mailing addresses (P.O. Box 7347, Philadelphia, PA 19101-7347 and Internal Revenue Service, <br />Centralized Insolvency Operations, P.O. Box 7346, Philadelphia, PA 19101), the Securities and <br />Exchange Commission at two mailing addresses (SEC Midwest Regional Office, 175 Jackson <br />Blvd., Suite 900, Chicago, IL 60604 and SEC Central Regional Office, 1961 Stout St., Suite 1700 <br />Denver, CO 80294) and the Colorado Commissioner of Securities. <br />9. Through this Motion, RPL requests relief from the 28 -day service requirement set <br />forth in Federal Rule of Bankruptcy Procedure 2002(b). RPL requests that the Court excuse the <br />late service and deem the service on August 25, 2020 to sufficient under the circumstances and <br />grant relief pursuant to Federal Rule of Bankruptcy Procedure 9006(b) and/or (c). <br />LEGAL AUTHORITIES <br />Service of notice of disclosure statement hearing and objection deadline. <br />10. Federal Rule of Bankruptcy Procedure 2002(b) provides in relevant part: <br />Except as provided in subdivision (1) of this rule, the clerk, or some <br />other person as the court may direct, shall give the debtor, the trustee <br />and all creditors and indenture trustees no less than 28 days' notice <br />by mail of the time fixed (1) for filing objections and the hearing to <br />consider approval of a disclosure statement .... <br />