4879-3732-2964 

Amber M. Carson (TX Bar No. 24075610) 

Jason S. Brookner (TX Bar No. 24033684) 

Micheal W. Bishop (TX Bar No. 02354860) 

Emily F. Shanks (TX Bar No. 24110350) 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, Texas 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: acarson@grayreed.com 

 jbrookner@grayreed.com 

 mbishop@grayreed.com 

 eshanks@grayreed.com 

 

Proposed Counsel to the Debtors 

and Debtors in Possession 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS RESTAURANTS, L.P., § Case No. 24-80058 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1983262 § 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS BEVERAGE, INC., § 

§ 

Case No. 24-80059 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1973995 § 

 § 

In re: § Chapter 11 

 § 

BUCA C, LLC, § Case No. 24-80060 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 46-4158220 § 

 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 1 of 16
2 

4879-3732-2964 

 § 

In re: § Chapter 11 

 § 

BUCA SALES & MARKETING, LLC, § Case No. 24-80061 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 27-0274258 § 

 § 

In re: § Chapter 11 

 § 

BUCA INVESTMENTS, INC., § Case No. 24-80062 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1985575 § 

 § 

In re: § Chapter 11 

 § 

BUCA RESTAURANTS, INC., § Case No. 24-80063 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1889725 § 

 § 

In re: § Chapter 11 

 § 

BUCA RESTAURANTS 2, INC., § Case No. 24-80064 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1742187 § 

 § 

In re: § Chapter 11 

 § 

BUCA (CELEBRATION), LLC, § Case No. 24-80065 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 81-2683412 § 

 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 2 of 16
3 

4879-3732-2964 

 § 

In re: § Chapter 11 

 § 

BUCA (EX), LLC, § Case No. 24-80066 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 45-1683092 § 

 § 

In re: § Chapter 11 

 § 

BUCA (MINNEAPOLIS), INC., § Case No. 24-80067 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 20-2302474 § 

DEBTORS’ EMERGENCY MOTION FOR ENTRY 

OF AN ORDER (I) DIRECTING JOINT ADMINISTRATION 

OF CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF

EMERGENCY RELIEF HAS BEEN REQUESTED. RELIEF IS REQUESTED NOT LATER 

THAN 10:30 A.M. ON AUGUST 7, 2024. 

IF YOU OBJECT TO THE RELIEF REQUESTED OR YOU BELIEVE THAT 

EMERGENCY CONSIDERATION IS NOT WARRANTED, YOU MUST APPEAR AT THE 

HEARING IF ONE IS SET, OR FILE A WRITTEN RESPONSE PRIOR TO THE DATE 

THAT RELIEF IS REQUESTED IN THE PRECEDING PARAGRAPH. OTHERWISE, THE 

COURT MAY TREAT THE PLEADING AS UNOPPOSED AND GRANT THE RELIEF 

REQUESTED. 

A VIRTUAL HEARING WILL BE CONDUCTED ON THIS MATTER ON AUGUST 7, 2024, 

AT 10:30 A.M. IN ROOM 1424, EARLE CABELL FEDERAL BUILDING, 1100 

COMMERCE STREET, 14TH FLOOR, COURTROOM 1, DALLAS, TEXAS, 75242. 

PARTICIPATION AT THE HEARING WILL ONLY BE PERMITTED BY AN AUDIO AND 

VIDEO CONNECTION. 

AUDIO COMMUNICATION WILL BE BY USE OF THE COURT’S DIAL-IN FACILITY. 

YOU MAY ACCESS THE FACILITY AT 1.650.479.3207. VIDEO COMMUNICATION WILL 

BE BY THE USE OF THE CISCO WEBEX PLATFORM. CONNECT VIA THE CISCO 

WEBEX APPLICATION OR CLICK THE LINK ON JUDGE JERNIGAN’S HOME PAGE. 

THE MEETING CODE IS 2304 154 2638. CLICK THE SETTINGS ICON IN THE UPPER 

RIGHT CORNER AND ENTER YOUR NAME UNDER THE PERSONAL INFORMATION 

SETTING. 

HEARING APPEARANCES MUST BE MADE ELECTRONICALLY IN ADVANCE OF 

ELECTRONIC HEARINGS. TO MAKE YOUR APPEARANCE, CLICK THE 

“ELECTRONIC APPEARANCE” LINK ON JUDGE JERNIGAN’S HOME PAGE. SELECT 

THE CASE NAME, COMPLETE THE REQUIRED FIELDS AND CLICK “SUBMIT” TO 

COMPLETE YOUR APPEARANCE. 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 3 of 16
4 

4879-3732-2964 

The above-captioned debtors and debtors in possession (collectively, the “Debtors”) 

respectfully state as follows in support of this motion (“Motion”): 

Relief Requested 

1. By this Motion, the Debtors seek entry of an order, substantially in the form 

attached hereto as Exhibit A: (a) directing procedural consolidation and joint administration of 

these chapter 11 cases; and (b) granting related relief. 

2. Specifically, the Debtors request that the Court maintain one file and one docket 

for all the jointly-administered cases under the case of BUCA Texas Restaurants, L.P., and that 

the cases be administered under a consolidated caption, as follows: 

______________________________________________ 

1

 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ federal tax identification number are 

as follows: BUCA Texas Restaurants, L.P. (3262); BUCA Texas Beverage, Inc. (3995); BUCA C, LLC (8220); BUCA 

Sales & Marketing, LLC (4258); BUCA Investments, Inc. (5575); BUCA Restaurants, Inc. (9725); BUCA Restaurants 

2, Inc. (2187); BUCA (Celebration), LLC (3412); BUCA (Ex), LLC (3092); BUCA (Minneapolis), Inc. (2474). The 

Debtors’ principal offices are located at 4700 Millenia Boulevard, Suite 400, Orlando, Florida 32839. 

3. The Debtors further request an order from the Court that this caption satisfies the 

requirements set forth in section 342(c)(1) of title 11 of the United States Code, 11 U.S.C. §§ 101–

1532 (the “Bankruptcy Code”). 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS RESTAURANTS, L.P., et al.,1 § Case No. 24-80058 (SGJ) 

 § 

Debtors. § (Jointly Administered) 

 § 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 4 of 16
5 

4879-3732-2964 

4. The Debtors also request that a docket entry, substantially similar to the following, 

be entered on the docket in each debtor case other than BUCA Texas Restaurants, L.P., to reflect 

the joint administration of these chapter 11 cases: 

An order has been entered in accordance with rule 1015(b) of the Federal 

Rules of Bankruptcy Procedure and rule 1015-1(a) of the Local Bankruptcy 

Rules of the United States Bankruptcy Court for the Northern District of 

Texas directing joint administration for procedural purposes of the chapter 

11 cases of BUCA Texas Restaurants, L.P., et al. All further pleadings 

and other papers shall be filed in and all further docket entries shall be 

made in Case No. 24-80058). 

Jurisdiction and Venue 

5. The United States Bankruptcy Court for the Northern District of Texas 

(the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This matter is a core 

proceeding within the meaning of 28 U.S.C. § 157(b). 

6. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

7. The bases for the relief requested herein are section 105(a) of the Bankruptcy Code, 

Rules 1015(b) and 6003 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), 

rule 1015-1(a) of the Local Bankruptcy Rules of the United States Bankruptcy Court for the 

Northern District of Texas (the “Local Rules”), and Sections J.34 and J.35 of the Procedures for 

Complex Cases in the Northern District of Texas (the “Complex Case Procedures”). 

Background 

8. The Debtors are leading owners, operators, and franchisors of family-style ItalianAmerican restaurants. With approximately 44 owned locations across 14 states and two 

international franchised locations, Buca di Beppo is known for its large portions, eclectic décor, 

and a festive atmosphere that encourages sharing and communal dining. The Debtors’ operations 

have been impacted by a significant drop in sales, rising food and labor costs, continued staffing 

challenges, and changes in consumer preferences. A more detailed history of the Debtors’ 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 5 of 16
6 

4879-3732-2964 

business, as well as their prepetition efforts to address liquidity issues, are discussed in the First 

Day Declaration. 

9. On August 4, 2024 (the “Petition Date”), each Debtor filed a voluntary petition for 

relief under chapter 11 of the Bankruptcy Code. The Debtors are operating as debtors in possession 

pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. Concurrently with the filing of 

this Motion, the Debtors have filed a motion requesting procedural consolidation and joint 

administration of these chapter 11 cases pursuant to Bankruptcy Rule 1015(b). No request for the 

appointment of a trustee or examiner has been made in these chapter 11 cases, and no committee 

has been appointed. 

10. A detailed description of the Debtors and their businesses, and the facts and 

circumstances supporting this Motion and the Debtors’ chapter 11 cases, are set forth in the 

Declaration of William Snyder, Chief Restructuring Officer, in Support of Chapter 11 Petitions and 

First Day Motions (the “First Day Declaration”), filed contemporaneously herewith and 

incorporated herein by reference. 

Basis for Relief 

11. Bankruptcy Rule 1015(b) provides, in pertinent part, that “[i]f . . . two or more 

petitions are pending in the same court by or against . . . (2) a partnership and one or more of its 

general partners, or (3) two or more general partners, or (4) a debtor and an affiliate, the court may 

order a joint administration of the estates.” Fed. R. Bankr. P. 1015(b). The Debtor entities that 

commenced chapter 11 cases are “affiliates” as that term is defined in section 101(2) of the 

Bankruptcy Code. See 11 U.S.C. § 101(2). Accordingly, the Bankruptcy Code and Bankruptcy 

Rules authorize the Court to grant the relief requested herein. Bankruptcy Local Rule 1015-1(a) 

further provides for the joint administration of related chapter 11 cases. 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 6 of 16
7 

4879-3732-2964 

12. Given the integrated nature of the Debtors’ operations, and overlap of assets and 

liabilities, joint administration of these chapter 11 cases will provide significant administrative 

convenience without harming the substantive rights of any party in interest. Many, if not all, of 

the motions, hearings, and orders in these chapter 11 cases will affect each Debtor entity. The 

entry of an order directing joint administration of these chapter 11 cases will reduce fees and costs 

by avoiding duplicative filings and objections. Joint administration also will allow the Office of 

the United States Trustee for the Northern District of Texas and all parties in interest to monitor 

these chapter 11 cases with greater ease and efficiency. 

13. Joint administration is generally non-controversial, and courts in this district 

routinely order joint administration in cases with multiple related debtors. See, e.g., In re Ebix, 

Inc., No. 23-80004 (SWE) (Bankr. N.D. Tex. Dec. 19, 2023) [Docket No. 50] (authorizing joint 

administration); In re Impel Pharmaceuticals, Inc., No. 23-80016 (SGJ) (Bankr. N.D. Tex. Dec. 

21, 2023) [Docket No. 53] (same); In re Tuesday Morning, No. 23-90001 (ELM) (Bankr. N.D. 

Tex. Feb. 16, 2023) [Docket No. 107] (same); In re Sunland Medical Foundation, No. 23-80000 

(MVL) (Bankr. N.D. Tex. Aug. 31, 2023) [Docket No. 37] (same); Northwest Senior Housing 

Corporation, No. 22-30659 (MVL) (Bankr. N.D. Tex. April 19, 2022) [Docket No. 88] (same); In 

re Studio Movie Grill Holdings, LLC, No. 20-32633 (SGJ) (Bankr. N.D. Tex. Oct. 27, 2020) 

[Docket No. 48] (same); In re Tuesday Morning, No. 20-31476 (HDH) (Bankr. N.D. Tex. May 28, 

2020) [Docket No. 66] (same); In re Diamondback Industries, Inc., No. 20-41504 (ELM) (Bankr. 

N.D. Tex. April 28, 2020) [Docket No. 41] (same); In re PHI, Inc., No. 1930923 (HDH) (Bankr. 

N.D. Tex. Mar 19, 2019) [Docket No. 57] (same).1

1

 Because of the voluminous nature of the orders cited herein, such orders have not been attached to this Motion. 

Copies of these orders are available upon request to the Debtors’ proposed counsel. 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 7 of 16
8 

4879-3732-2964 

14. Joint administration will not adversely affect the Debtors’ respective constituencies 

because this Motion seeks only administrative, not substantive, consolidation of the Debtors’ 

estates. Parties in interest will not be harmed by the relief requested; instead, parties in interest 

will benefit from the cost reductions associated with the joint administration of these chapter 11 

cases. Accordingly, the Debtors submit that the joint administration of these chapter 11 cases is 

in the best interests of their estates, their creditors, and all other parties in interest. 

Notice 

15. The Debtors will provide notice of this motion to the following parties or their 

counsel: (a) the U.S. Trustee for the Northern District of Texas; (b) the holders of the 30 largest 

unsecured claims against the Debtors (on a consolidated basis); (c) agent to the lenders under the 

Debtors’ prepetition term loan facilities; (d) the United States Attorney’s Office for the Northern 

District of Texas; (e) the Internal Revenue Service; (f) the state attorneys general for states in 

which the Debtors conduct business; and (g) any party that has requested notice pursuant to 

Bankruptcy Rule 2002. In light of the nature of the relief requested, the Debtors submit that no 

other or further notice is needed. 

[Remainder of page intentionally left blank] 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 8 of 16
9 

4879-3732-2964 

WHEREFORE, the Debtors respectfully request that the Court enter an order, substantially 

in the form attached hereto as Exhibit A, granting the relief requested herein and such other relief 

as the Court deems appropriate under the circumstances. 

Respectfully submitted this 5th day of August, 2024. 

GRAY REED 

 

By: /s/ Amber M. Carson 

 Amber M. Carson 

 Texas Bar No. 24075610 

 Jason S. Brookner 

 Texas Bar No. 24033684 

 Micheal W. Bishop 

 Texas Bar No. 02354860 

 Emily F. Shanks 

 Texas Bar No. 24110350 

1601 Elm Street, Suite 4600 

Dallas, Texas 75201

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: acarson@grayreed.com 

jbrookner@grayreed.com 

mbishop@grayreed.com

 eshanks@grayreed.com 

Proposed Counsel to the Debtors 

and Debtors in Possession

Certificate of Service 

 I certify that on August 5, 2024, I caused a copy of the foregoing document to be served 

by the Electronic Case Filing System for the United States Bankruptcy Court for the Northern 

District of Texas. 

/s/ Amber M. Carson 

Amber M. Carson 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 9 of 16
4879-3732-2964 

Exhibit A 

Proposed Order 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 10 of 16
4879-3732-2964 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS RESTAURANTS, L.P., § Case No. 24-80058 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1983262 § 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS BEVERAGE, INC., § 

§ 

Case No. 24-80059 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1973995 § 

 § 

In re: § Chapter 11 

 § 

BUCA C, LLC, § Case No. 24-80060 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 46-4158220 § 

 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 11 of 16
2 

4879-3732-2964 

 § 

In re: § Chapter 11 

 § 

BUCA SALES & MARKETING, LLC, § Case No. 24-80061 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 27-0274258 § 

 § 

In re: § Chapter 11 

 § 

BUCA INVESTMENTS, INC., § Case No. 24-80062 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1985575 § 

 § 

In re: § Chapter 11 

 § 

BUCA RESTAURANTS, INC., § Case No. 24-80063 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1889725 § 

 § 

In re: § Chapter 11 

 § 

BUCA RESTAURANTS 2, INC., § Case No. 24-80064 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 41-1742187 § 

 § 

In re: § Chapter 11 

 § 

BUCA (CELEBRATION), LLC, § Case No. 24-80065 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 81-2683412 § 

 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 12 of 16
3 

4879-3732-2964 

 § 

In re: § Chapter 11 

 § 

BUCA (EX), LLC, § Case No. 24-80066 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 45-1683092 § 

 § 

In re: § Chapter 11 

 § 

BUCA (MINNEAPOLIS), INC., § Case No. 24-80067 (SGJ) 

 § 

 Debtor. § 

 § 

Tax I.D. No. 20-2302474 § 

ORDER (I) DIRECTING JOINT ADMINISTRATION 

OF CHAPTER 11 CASES AND (II) GRANTING RELATED RELIEF 

Upon the motion (“Motion”)1 of the above-captioned debtors and debtors in possession 

(collectively, the “Debtors”) for entry of an order (this “Order”), (a) directing the joint 

administration of the Debtors’ chapter 11 cases for procedural purposes only, and (b) granting 

related relief; all as more fully set forth in the Motion; and upon the First Day Declaration; and 

this Court having jurisdiction over this matter pursuant to 28 U.S.C. § 1334; and this Court having 

found that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found 

that it may enter a final order consistent with Article III of the United States Constitution; and this 

Court having found that venue of this proceeding and the Motion in this district is proper pursuant 

to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the Debtors’ notice of the Motion 

and opportunity for a hearing on the Motion were appropriate under the circumstances and no other 

notice need be provided; and this Court having reviewed the Motion, and all objections, if any, to 

the Motion having been withdrawn, resolved, or overruled; and the Court having determined that 

1 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion. 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 13 of 16
4 

4879-3732-2964 

the legal and factual bases set forth in the Motion and the record of the hearing on such motion 

establish just cause for the relief granted herein; and upon all of the proceedings had before this 

Court; and after due deliberation and sufficient cause appearing therefor, IT IS HEREBY 

ORDERED THAT: 

1. The Motion is granted as set forth herein. 

2. The above-captioned chapter 11 cases are consolidated for procedural purposes 

only and shall be jointly administered by the Court under Case No. 24-80058 (SGJ) 

(the “Lead Case”). 

3. All pleadings, papers, and documents, except proofs of claim, lists, schedules, and 

statements, filed in the jointly administered cases shall bear the caption of the Lead Case, as 

follows: 

______________________________________________ 

1

 The Debtors in these chapter 11 cases and the last four digits of each Debtors’ federal tax identification number are 

as follows: BUCA Texas Restaurants, L.P. (3262); BUCA Texas Beverage, Inc. (3995); BUCA C, LLC (8220); BUCA 

Sales & Marketing, LLC (4258); BUCA Investments, Inc. (5575); BUCA Restaurants, Inc. (9725); BUCA Restaurants 

2, Inc. (2187); BUCA (Celebration), LLC (3412); BUCA (Ex), LLC (3092); BUCA (Minneapolis), Inc. (2474). The 

Debtors’ principal offices are located at 4700 Millenia Boulevard, Suite 400, Orlando, Florida 32839. 

4. The foregoing caption satisfies the requirements set forth in section 342(c)(1) of 

the Bankruptcy Code. 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

 § 

In re: § Chapter 11 

 § 

BUCA TEXAS RESTAURANTS, L.P., et al.,1 § Case No. 24-80058 (SGJ) 

 § 

Debtors. § (Jointly Administered) 

 § 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 14 of 16
5 

4879-3732-2964 

5. All orders, pleadings, papers, and documents, except proofs of claim, lists, 

schedules, and statements, shall be filed and docketed in the Lead Case. 

6. A docket entry, substantially similar to the following, shall be entered on the docket 

of each of the Debtors other than the Lead Case, to reflect the joint administration of these chapter 

11 cases: 

An order has been entered in accordance with rule 1015(b) of the Federal 

Rules of Bankruptcy Procedure and rule 1015-1(a) of the Local Bankruptcy 

Rules of the United States Bankruptcy Court for the Northern District of 

Texas directing joint administration for procedural purposes of the chapter 

11 cases of BUCA Texas Restaurants, L.P., et al. All further pleadings 

and other papers shall be filed in and all further docket entries shall be 

made in Case No. 24-80058 (SGJ)). 

7. The Debtors shall maintain, and the Clerk of the United States Bankruptcy Court 

for the Northern District of Texas shall keep, one consolidated docket, one file, and one 

consolidated service list. 

8. All proofs of claim, lists, schedules, and statements (if applicable) shall be filed and 

docketed under the case number representing the estate in which the claim is made, and a creditor 

of more than one estate shall file and docket a proof of claim in each case to which a claim may 

be made, and only in the amount which the creditor may make a claim from that estate. 

9. The Debtors shall file monthly operating reports and Bankruptcy Rule 2015.3 

reports on an entity-by-entity basis. 

10. Nothing contained in the Motion or this Order shall be deemed or construed as 

directing or otherwise effecting a substantive consolidation of these chapter 11 cases and this Order 

shall be without prejudice to the rights of any part in interest to seek entry of an order substantively 

consolidating these cases. 

11. The Debtors are authorized to take all reasonable actions necessary to effectuate 

the relief granted in this Order in accordance with the Motion. 

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 15 of 16
6 

4879-3732-2964 

12. This Court retains jurisdiction with respect to all matters arising from or related to 

the implementation, interpretation, and enforcement of this Order. 

# # # END OF ORDER # # # 

Submitted by: 

Amber M. Carson (TX Bar No. 24075610) 

Jason S. Brookner (TX Bar No. 24033684) 

Micheal W. Bishop (TX Bar No. 02354860) 

Emily F. Shanks (TX Bar No. 24110350) 

GRAY REED 

1601 Elm Street, Suite 4600 

Dallas, TX 75201 

Telephone: (214) 954-4135 

Facsimile: (214) 953-1332 

Email: acarson@grayreed.com

 jbrookner@grayreed.com

 mbishop@grayreed.com 

 eshanks@grayreed.com 

Proposed Counsel to the Debtors 

and Debtors in Possession

Case 24-80060-sgj11 Doc 2 Filed 08/05/24 Entered 08/05/24 11:45:25 Desc Main

Document Page 16 of 16