Kristen E. Burgers (VSB No. 67997) 

HIRSCHLER FLEISCHER 

8270 Greensboro Drive, Suite 700 

Tysons, Virginia 22102 

Telephone: (703) 584-8900 

Facsimile: (703) 584-8901 

Email: kburgers@hirschlerlaw.com

Co-Counsel to the Debtors

Mark S. Lichtenstein (Admitted pro hac vice) 

Crowell & Moring LLP 

590 Madison Avenue, 20th Floor 

New York, New York 10022 

Telephone: (212) 223-4000 

Facsimile: (212) 223-4001 

Email: mlichtenstein@crowell.com

Co-Counsel to the Debtors

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

) 

In re: ) 

 ) Chapter 11 

GreenTech Automotive, Inc., et al.1 ) Case No. 18-10651

 ) Jointly Administered 

Debtor. ) 

) 

MOTION TO TREAT JANUARY 16 HEARING AS A STATUS CONFERENCE 

AND TO ADJOURN PLAN CONFIRMATION HEARING AND 

CERTAIN RELATED DATES AND DEADLINES 

Debtors GreenTech Automotive, Inc. (“GreenTech”) and WM Industries Corp., f/k/a 

WM GreenTech Automotive Corporation (“WMIC” and, together with GreenTech, the 

“Debtors”), by counsel, file this motion (the “Motion”) to treat the scheduled January 16, 2019 

hearing as a status conference with respect to the confirmation of the Plan (as hereinafter 

defined) and to adjourn the Plan confirmation hearing and certain related dates and deadlines to 

dates to be determined at the status conference. In support of this Motion, the Debtors 

respectfully state as follows: 

1. The hearing on confirmation of the Modified Third Amended Joint Chapter 11 

Plan of Liquidation of GreenTech Automotive, Inc. and WM Industries Corp. [Docket No. 375] 

(the “Plan”) was originally scheduled for on December 21, 2018. 

1

 The Debtors in these jointly administered chapter 11 cases are GreenTech Automotive, Inc. (Case No. 18-10651), 

WM Industries Corp. (Case No. 18-10652), Gulf Coast Funds Management, LLC (Case No. 18-10653), American 

Immigration Center, LLC (Case No. 18-10654), GreenTech Automotive Capital A-3 GP, LLC (Case No. 18-10655), 

and GreenTech Automotive Partnership A-3, L.P. (Case No. 18-10656). 

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2. On December 18, 2018, the Debtors filed their Motion to Continue Plan 

Confirmation Hearing and Certain Related Dates and Deadlines (the “Motion to Continue”) 

[Docket No. 414], whereby the Debtors requested that the Court continue the confirmation 

hearing to January 16, 2019, to allow additional time for, among other things: (a) Shenzen Jin 

Hong Investment Management Co., Ltd., commonly known in China as Golden Resources 

(“GR”), the stalking horse bid for the sale of substantially all the Debtors’ assets, to post the $5 

million deposit required by the Asset Purchase Agreement (the “APA”) between GreenTech and 

GR; (b) creditors and investors to submit ballots and/or releases, to the extent that such creditors 

and/or investors had not already submitted a ballot and/or release; and (c) potential competitive 

purchasers to formulate offers. 

3. On December 19, 2018, the Court entered an order approving the Motion to 

Continue. The continued confirmation hearing was scheduled for January 16, 2019. 

4. As of the date of this Motion, GR has not posted the deposit required by the APA. 

GR has been advised that the deposit is still in process with the Chinese regulatory authorities; 

however, the Debtors are skeptical of GR’s explanation and have lost faith in GR’s ability to 

close on the purchase of the Debtor’s assets. 

5. The Debtors received only one qualified bid (other than the bid of GR) for the 

purchase of the real property, plant and equipment comprising the Debtors’ manufacturing 

facility (the “Hard Assets Bid”). The bidder has posted a deposit, in the amount of 10% of the 

bid price, with its outside counsel. The Debtors have not received any bids, other than that of 

GR, for the JSAT Interest (as defined in the Plan), which the Debtors believe to be their most 

valuable asset. 

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6. The Debtors have been advised that a group of A-3 and A-4 investors (the 

“Investor Group”) is preparing a bid for the purchase of substantially all the Debtors’ assets, 

including the real property, plant and equipment comprising the Debtors’ manufacturing facility, 

as well as the JSAT Interest. Counsel to the Investor Group has been in close contact with 

Debtors’ counsel as they work with the Investor Group to fashion a proposal. While the Debtors 

have not yet received an asset purchase agreement from the Investor Group, the Debtors believe 

that the Investor Group is serious and has the ability to close on the purchase. The Debtors also 

believe that the purchase price proposed by the Investor Group will be substantially more than 

the Hard Assets Bid and potentially will allow the estate to realize more guaranteed value than if 

a liquidating trustee were to be appointed as contemplated as scenario 2 under the Plan. 

7. Given the current state of uncertainty as to the GR deposit and the potential bid by 

the Investor Group, the Debtors believe that it is in the best interest of the bankruptcy estates, 

creditors, investors and parties-in-interest herein to treat the January 16, 2019 hearing as a status 

conference as to Plan confirmation and to adjourn the Plan confirmation hearing and related 

dates and deadlines to dates to be determined at the status conference. The Debtors have 

conferred with the Office of the United States Trustee and certain of its major stakeholders and 

believe that a short adjournment of the confirmation hearing and related deadlines will be in the 

best interests of such stakeholders. The Debtors propose that all matters scheduled on the 

Court’s docket for January 16, 2019, other than those related to Plan confirmation, go forward as 

scheduled. 

8. The Debtors have consulted with their major stakeholders on, and such 

stakeholders have consented to, the proposed treatment of the January 16 hearing as a status 

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conference and the adjournment of the Plan confirmation hearing and related dates and 

deadlines. 

WHEREFORE, the Debtors request that this Court enter an order, substantially in the 

form attached hereto as Exhibit A, ordering that the January 16 hearing shall be treated as a 

scheduling conference with respect to Plan confirmation and adjourning the hearing on Plan 

confirmation and related dates and deadlines, and for such other and further relief as may be just 

and proper. 

Dated: January 13, 2019 Respectfully submitted, 

/s/ Kristen E. Burgers 

Kristen E. Burgers (VSB No. 67997) 

HIRSCHLER FLEISCHER 

8270 Greensboro Drive, Suite 700 

Tysons, Virginia 22102 

Telephone: (703) 584-8900 

Facsimile: (703) 584-8901 

Email: kburgers@hf-law.com

- and – 

Mark S. Lichtenstein (Admitted pro hac vice) 

Crowell & Moring LLP 

590 Madison Avenue, 20th Floor 

New York, New York 10022 

Telephone: (212) 223-4000 

Facsimile: (212) 223-4001 

Email: mlichtenstein@crowell.com

Co-Counsel to the Debtors 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 13th day of January, 2019, I caused to be served a true and 

correct copy of the foregoing Motion to Treat January 16 Hearing as a Status Conference and to 

Adjourn Plan Confirmation Hearing and Certain Related Dates and Deadlines by operation of the 

CM/ECF electronic case management system on all parties entitled to receive notice thereby. 

/s/ Kristen E. Burgers 

Kristen E. Burgers 

10862173.1 043227.00001 

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