MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS — Page 1

motion expedite hearing 4892-5316-0115 v.2.docx[1] 4871-6878-7891, v. 1

Jeff Carruth (TX SBN: 24001846)

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

2608 Hibernia, Suite 105

Dallas, TX 75204-2514

Telephone: (713) 341-1158

Fax: (713) 961-5341

E-mail: jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR

HIGH PLAINS RADIO NETWORK, LLC,

DEBTOR AND DEBTOR IN POSSESSION

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

WICHITA FALLS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, LLC, §

§

CASE NO. 24-70089-swe11

DEBTOR. §

§

EXPEDITED HEARING REQUESTED

MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST

DAY MATTERS (RE: DOCKET NOS. 11, 12, 13)

TO THE HONORABLE SCOTT W. EVERETT, U.S. BANKRUPTCY JUDGE:

High Plains Radio Network, LLC, debtor and debtor in possession (the “Debtor”) files 

this Motion to Maintain Bank Accounts (the “Motion to Maintain Bank Accounts”) and in 

support thereof would show to the Court the following.

1. On April 1-2, 2024, the Debtor filed the following “first day” motions

(collectively, the “Subject Motions”).

Docket No. Motion

11 Motion to Use Cash Collateral

12 Motion to Pay Pre-Petition Wages

13 Motion to Maintain Bank Accounts

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 1 of 9
MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS — Page 2

motion expedite hearing 4892-5316-0115 v.2.docx[1] 4871-6878-7891, v. 1

2. Requested hearing date: The Debtor respectfully requests that the Court set an 

expedited hearing regarding each of the Subject Motions on April 3, 2024, April 4, 2024,

and/or April 5, 2024.

3. Debtor requests that the hearing be conducted by WebEx and/or in Dallas,

Texas in order to accommodate travel of the principal of the Debtor.

4. The time estimate for the hearing as to all of the Subject Motions is 30 minutes.

5. Reason for expedited hearing: A hearing is necessary in order to authorize the use

of cash collateral, and to make the next payroll that is due April 10, 2024.

6. Notice is sufficient. Setting an expedited hearing during April 3-5 is sufficient

considering the limited relief that is request and that only the SBA, on a claim in the amount of

$65,000, is involved with respect to cash collateral.

7. The Debtor will endeavor also to reach agreed orders with the SBA on cash

collateral and the U.S. Trustee on wages and bank accounts prior to the hearing.

8. Reason hearing not requested sooner. A hearing was requested as soon as 

possible after the commencement of this case on the evening of March 26, 2024.

WHEREFORE, High Plains Radio Network, LLC, the debtor and debtor-in-possession, 

respectfully requests that the Court set the Subject Motion for an expedited hearing on April 3, 4,

or 5, 2024 by WebEx. Debtor respectfully requests that the Court grant to Debtor such other and 

further relief to which the Debtor is entitled at law or in equity.

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 2 of 9
MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS — Page 3

motion expedite hearing 4892-5316-0115 v.2.docx[1] 4871-6878-7891, v. 1

Dated: November 29, 2022 Respectfully submitted:

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

By: /s/ Jeff Carruth

JEFF CARRUTH (TX SBN: 24001846)

2608 Hibernia, Suite 105

Dallas, TX 75204-2514

Telephone: (713) 341-1158

Fax: (713) 961-5341

E-mail: jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR

HIGH PLAINS RADIO NETWORK, LLC,

DEBTOR AND DEBTOR IN POSSESSION

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing was served on April 2, 2024

(1) by electronic notice to all ECF users who have appeared in this case to date, and/or as set forth below 

and (2) by regular mail to all parties appearing in the attached address list (i.e. mailing matrix).

COPIES OF THE EXHIBITS WERE NOT SERVED BY REGULAR MAIL. PLEASE 

CONTACT THE UNDERSIGNED IF YOU WISH TO RECEIVE THE EXHIBITS.

/s/Jeff Carruth

Jeff Carruth

ECF SERVICE LIST

24-70089-swe11 Notice will be electronically mailed to: 

Jeffery D. Carruth on behalf of Debtor High Plains Radio Network, LLC

jcarruth@wkpz.com, 

jcarruth@aol.com;atty_carruth@trustesolutions.com;carruthjr87698@notify.bestcase.com;ATTY_CARRUTH@blue

stylus.com

Paul H. Cross on behalf of Creditor Hanmi Bank

phclease@msn.com

Julie Anne Parsons on behalf of Creditor Eastland County Appraisal District

jparsons@mvbalaw.com, 

kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Julie Anne Parsons on behalf of Creditor The County of Henderson, Texas

jparsons@mvbalaw.com, 

kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 3 of 9
MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS — Page 4

motion expedite hearing 4892-5316-0115 v.2.docx[1] 4871-6878-7891, v. 1

Julie Anne Parsons on behalf of Creditor The County of Stephens, Texas

jparsons@mvbalaw.com, 

kalexander@mvbalaw.com;theresa.king@mvbalaw.com;juanie.montalvo@mvbalaw.com

Scott M. Seidel -SBRA V

scott@scottseidel.com, csms11@trustesolutions.net;susan.seidel@earthlink.net

United States Trustee

ustpregion06.da.ecf@usdoj.gov

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 4 of 9
4871-6878-7891, v. 1

REGULAR MAIL LIST

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 5 of 9
4871-6878-7891, v. 1

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 6 of 9
4871-6878-7891, v. 1

PROPOSED ORDER

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 7 of 9
ORDER GRANTING MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS (RE: 

DOCKET NOS. 11, 12, 13, 14) — Page 1

motion expedite hearing 4892-5316-0115 v.2.docx/4871-6878-7891, v. 1

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, 

LLC,

§

§

CASE NO. 24-70089-swe11V

§

DEBTOR. §

ORDER GRANTING MOTION TO EXPEDITE HEARINGS 

REGARDING CERTAIN FIRST DAY MATTERS (RE: DOCKET NOS. 11, 

12, 13, 14)

On this day the Court considered the Motion to Expedite Hearings Regarding Certain

First Day Matters (Docket No. 14) (the “Motion to Expedite”) filed herein on April 2, 2024 by 

High Plains Radio Network, LLC, debtor and debtor in possession (the “Debtor”). Upon review 

of the Motion to Expedite, the Court is of the opinion that sufficient cause exists to set an 

expedited hearing regarding each of the following motions filed by the Debtor on April 1-2, 2024

(collectively, the “Subject Motions”).

Docket No. Motion

11 Motion to Use Cash Collateral

12 Motion to Pay Pre-Petition Wages

13 Motion to Maintain Bank Accounts

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 8 of 9
ORDER GRANTING MOTION TO EXPEDITE HEARINGS REGARDING CERTAIN FIRST DAY MATTERS (RE: 

DOCKET NOS. 11, 12, 13, 14) — Page 2

motion expedite hearing 4892-5316-0115 v.2.docx/4871-6878-7891, v. 1

IT IS THEREFORE ORDERED THAT the Court shall conduct an expedited hearing on 

the Subject Motions at the date and time entered on the docket for this case. The hearing shall

be conducted by WebEx. Movant shall be responsible for notice.

### END OF ORDER ###

Submitted by:

WEYCER, KAPLAN, PULASKI & ZUBER, P.C.

By: /s/ Jeff Carruth

JEFF CARRUTH (TX SBN: 24001846)

2608 Hibernia, Suite 105

Dallas, TX 75204-2514

Telephone: (713) 341-1158

Fax: (713) 961-5341

E-mail: jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR 

HIGH PLAINS RADIO NETWORK, LLC,

DEBTOR AND DEBTOR IN POSSESSION

Case 24-70089-swe11 Doc 14 Filed 04/02/24 Entered 04/02/24 04:13:28 Desc Main

Document Page 9 of 9