MOTION TO EXPEDITE HEARINGS REGARDING UTILITIES MOTION (RE: DOCKET NOS. 15)— Page 1

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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

DEBTOR. §

§

EXPEDITED HEARING REQUESTED

MOTION TO EXPEDITE HEARING REGARDING UTILITIES MOTION 

(RE: DOCKET NOS. 15)

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 Expedite Hearings regarding the motion(s) listed below and in support thereof 

would show to the Court the following.

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

the “Subject Motions”).

Docket No. Motion

15 Motion for Order (I) Prohibiting Utility Providers from Altering, 

Refusing, or Discontinuing Services and (II) Establishing Procedures 

for Determining Requests for Additional Adequate Assurance

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

expedited hearing regarding each of the Subject Motions on or before April 15, 2024 and 

within the 20-day window of Code § 366.

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, and that the principal fo

the Debtor be permitted to appear by WebEx.

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 address the 

utilities issue prior to 20-day deadline of the Code § 366.

6. Notice is sufficient. Setting an expedited hearing during the first 20 days of the 

case is sufficient, especially considering the procedural nature of the relief requested in the 

utilities motion.

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

possible after addressing other urgent early case “first day” matters.

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 before 

April 15, 2024 and within the 20-day window of Code § 366. 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.

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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 4, 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_CARR

UTH@bluestylus.com

Paul H. Cross on behalf of Creditor Hanmi Bank

phclease@msn.com

Shanna M. Kaminski on behalf of Interested Party mp Union Funding Source, Inc.

skaminski@kaminskilawpllc.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

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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

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

David Weitman on behalf of Creditor Vertical Bridge REIT, LLC

david.weitman@klgates.com

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REGULAR MAIL LIST

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PROPOSED ORDER

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ORDER GRANTING MOTION TO EXPEDITE HEARING REGARDING

UTILITIES MOTION (RE: DOCKET NOS. 15, 24)— Page 1

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UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, 

LLC,

§

§

CASE NO. 24-70089

§

DEBTOR. §

ORDER GRANTING MOTION TO EXPEDITE HEARING REGARDING 

UTILITIES MOTION (RE: DOCKET NOS. 15, 24)

On this day the Court considered the Motion to Expedite Hearing Regarding Utilities 

Motion (Docket No. 24) (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 (collectively, the “Subject 

Motions”).

Docket No. Motion

15 Motion for Order (I) Prohibiting Utility Providers from Altering, 

Refusing, or Discontinuing Services and (II) Establishing Procedures 

for Determining Requests for Additional Adequate Assurance

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ORDER GRANTING MOTION TO EXPEDITE HEARING REGARDING

UTILITIES MOTION (RE: DOCKET NOS. 15, 24)— Page 2

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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, and the representative of the Debtor may appear 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

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