318957664.3 0245915-00149 

David Weitman 

Texas Bar No. 21116200 

Brandy Sargent 

(Admitted Pro Hac Vice) 

K&L GATES LLP 

1717 Main Street, Suite 2800 

Dallas, Texas 75201 

Telephone: (214) 939-5500 

Facsimile: (214) 939-5849

Email: david.weitman@klgates.com 

ATTORNEYS FOR VERTICAL BRIDGE REIT, LLC 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

WICHITA FALLS DIVISION 

IN RE: 

HIGH PLAINS RADIO NETWORK, 

LLC, 

Debtor. 

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CASE NO.: 24-70089 (SWE) 

A Hearing on the Motion of Creditor Vertical Bridge 

for Entry of an Order (I) Granting Vertical Bridge 

Relief from the Automatic Stay, or (II) Alternatively, 

Granting (A) Adequate Protection to Vertical Bridge 

with Immediate Payment of Its Administrative Claim 

for Post-Petition Rent and (B) Compelling Immediate 

Assumption or Rejection of Unexpired Leases of 

Nonresidential Real Property [ECF Nos. 65 & 66]

AMENDED NOTICE OF HEARING (HYBRID HEARING) 

TO ALL PARTIES IN INTEREST: 

 This is to inform you that a hearing on the above-referenced Motion has been set for hearing 

on JUNE 13, 2024, AT 1:30 P.M. Central, before the Honorable Scott W. Everett. The hearing 

will be conducted at Judge Everett’s Courtroom, 1100 Commerce Street, 14th Floor, 

Courtroom #3, Dallas, TX 75242.

The hearing will be conducted in a hybrid format and parties may appear make in person 

or by the WebEx information below. The WebEx hearing instructions for the Court are shown 

below. Please see Dallas Webex Hearing Instructions and Tips for Judge Scott W. Everett which 

are attached hereto as Exhibit “A.” 

For WebEx Video Participation/Attendance: https://us-courts.webex.com/meet/everett

For WebEx Telephonic Participation/Attendance: Dial-In: 1-650-479-3207 

Access code: 2304 017 9738 

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318957664.3 0245915-00149 2

DATED JUNE 5, 2024 

Respectfully submitted, 

K&L GATES LLP 

/s/ David Weitman 

David Weitman 

Texas Bar No. 21116200 

K&L GATES LLP 

1717 Main Street, Suite 2800 

Dallas, Texas 75201 

Telephone: (214) 939-5500 

Email: david.weitman@klgates.com 

-andBrandy A. Sargent 

[Admitted Pro Hac Vice] 

K&L Gates LLP 

One SW Columbia Street, Suite 1900 

Portland, OR 97204 

Telephone: (503) 228-3200 

Email: brandy.sargent@klgates.com 

 

Attorneys for Vertical Bridge REIT, LLC

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318957664.3 0245915-00149 

CERTIFICATE OF SERVICE 

 The undersigned certifies that on June 5, 2024, a true and correct copy of this Amended 

Notice of Hearing was served via ECF. The parties set forth below, the 20 largest unsecured 

creditors, and those parties who have filed notices of appearance and requests for notices were 

served with this Amended Notice of Hearing by First Class United States Mail: 

 High Plains Radio Network, LLC Debtor’s Counsel 

 c/o Monte Lee Spearman, Member c/o Jeffery D. Carruth 

 P.O. Box 1419 Weycer Kaplan Pulaski & Zuber, P.C. 

 Vernon, Texas 76384 2608 Hibernia St. 

 Dallas, Texas 75204-2514 

 United States Trustee Subchapter V Trustee 

 1100 Commerce St., Room 976 c/o Scott M. Seidel 

 Dallas, Texas 75242 6505 West Park Blvd., Suite 306 

 Plano, Texas 75093 

U.S. Small Business Administration 

 1545 Hawkins Blvd., Ste. 202 

 El Paso, Texas 79925 

 /s/ David Weitman 

 David Weitman

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WebEx Hearing Instructions 

Judge Scott W. Everett

Pursuant to General Order 2023-05 issued by the Court on September 19, 2023, hearings before Judge Scott W. 

Everett will be conducted pursuant to the guidelines set forth in the General Order unless ordered otherwise.

For WebEx Video Participation/Attendance: 

Link: https://us-courts.webex.com/meet/everett

For WebEx Telephonic Only Participation/Attendance: 

Dial-In: 1-650-479-3207; Access code: 2304 017 9738

Participation/Attendance Requirements: 

• Counsel and other parties-in-interest who plan to actively participate in the hearing are encouraged to

attend the hearing in the WebEx video mode using the WebEx video link above. Counsel and other

parties-in-interest who will not be seeking to introduce any evidence at the hearing and who wish to

attend the hearing in a telephonic-only mode may attend the hearing in the WebEx telephonic-only

mode using the WebEx dial-in and access code above.

• Attendees should join the WebEx hearing at least 10 minutes prior to the hearing start time. Please be

advised that a hearing may already be in progress. During hearings participants are required to keep

their lines on mute when they are not addressing the Court or otherwise actively participating in the

hearing. The Court reserves the right to disconnect or place on permanent mute any attendee

that causes any disruption to the proceedings. For general information and tips with respect to

WebEx participation and attendance, please see Clerk’s Notice 20-04:

https://www.txnb.uscourts.gov/sites/txnb/files/hearings/Webex%20Information%20and%20Tips_0.pdf

• Witnesses are required to attend the hearing in the WebEx video mode, and live testimony will

only be accepted from witnesses who have the WebEx video function activated. Telephonic

testimony without accompanying video will not be accepted by the Court. The Court may consider

special requests for other appearance options on a case-by-case basis.

• All WebEx hearing attendees are required to comply with Judge Everett’s Telephonic and

Videoconference Hearing Policy (included within Judge Everett’s Judge-Specific Guidelines):

https://www.txnb.uscourts.gov/judges-info/hearing-dates/judge-everetts-hearing-dates .

Exhibit Requirements: 

• Any party intending to introduce documentary evidence at the hearing must file an exhibit list in the

case with a true and correct copy of each designated exhibit filed as a separate, individual attachment

thereto so that the Court and all participants have ready accessto all designated exhibits.

• In addition, for evidentiary hearings, when more than ten exhibits have been filed in ECF or when the

total page count of all exhibits exceeds 500 pages, Judge Everett requests a thumb/USB drive be

delivered to him prior to the hearing at: U.S. Bankruptcy Court, Attn: Stephen Manz, 1100 Commerce

Street, Room 1254, Dallas, TX 75242.

• Paper copies of exhibits are not encouraged; however, paper copies may be provided to the

witness(s) at an in-person hearing if preferred.

Notice of Hearing Content and Filing Requirements:

IMPORTANT: For all hearings that will be conducted by WebEx only: 

• The Notice of Hearing filed in the case and served on parties in interest must: (1) provide notice that

the hearing will be conducted by WebEx videoconference only, (2) provide notice of the above WebEx

video participation/attendance link, and (3) attach a copy of these WebEx Hearing Instructions or

provide notice that they may be obtained from Judge Everett’s hearing/calendar site:

https://www.txnb.uscourts.gov/judges-info/hearing-dates/judge-everetts-hearing-dates .

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• When electronically filing the Notice of Hearing via CM/ECF select “at https://uscourts.webex.com/meet/everett” as the location of the hearing (note: this option appears immediately

after the first set of Wichita Falls locations). Do not select Judge Everett’s Dallas courtroom as the 

location for the hearing. 

CONNECTION INSTRUCTIONS FOR PARTICIPATING IN A WEBEX VIRTUAL HEARING

The Court will allow participation in a virtual hearing using either of the following two methods. Please 

connect at least 10 minutes prior to the hearing time. It is recommended that attorneys discuss the logistics

of the WebEx appearance with their clients/witnesses at least 48 hours before the hearing. 

Option 1: Using the WebEx app on your smartphone, tablet, laptop, or desktop.

Please connect using only one device. Using two or more devices may cause audio feedback issues.

If using a phone or tablet for video, it should be set in a stationary position. Holding a phone or tablet in 

your hand while speaking does not yield a good video for the court.

NOTE: If you are experiencing audio issues when using the WebEx application, you may use the “Call

Me At” selection under “Audio Connection” to move just the audio portion of the WebEx conference to

your telephone. 

Option 2: Call in via phone (audio only). 

Webex dial-in number: 1-650-479-3207 (access code: 2304 017 9738). 

HELPFUL HINTS AND ETIQUETTE

• Please use the mute function when you are not speaking. Please be aware that sometimes the court 

mutes everyone when there is background noise.  When you want to speak, make sure you are not on

mute. Call- in users should dial *6 to unmute your line. 

• Remember to state your name for the record each time before speaking and speak slowly and clearly

so the Court can get a good record. 

• Use headphones whenever possible, especially if using a desktop PC with external speakers. We have

found that newer iPhones provide the best visual and audio feed – better than most desktop computers.

If you areon a personal computer, headphones or earbuds are required for those who need to speak 

during the hearing. 

• During examination, attorneys and witnesses should use a separate camera and microphone when

possible. To avoid feedback, parties using separate devices must not be in the same room. The Court 

may consider special requests on a case-by-case basis.

• WebEx participants may use the "share" button to easily share their screen or document with the 

Court or other WebEx participants.  Press “stop sharing” to remove the presentation from the meeting.

• When making an appearance from a vehicle, please park in a safe location with windows rolled up (to

minimize background distraction and noise) and use a headset that is ear-to-phone (not the vehicle’s

hands- free speaker-phone option).

• Suggestions for participating in a WebEx hearing from home: If you are having connectivity 

problems, turn off devices that may be using bandwidth on your home network. Devices or 

applications such as Facetime, Roku, streaming media players, video games, or large downloads can

negatively impact the audio and video quality of the WebEx meeting. 

• Participants are reminded that they should wear attire suitable for court. 

• Participants who wish to test their WebEx connection or the share screen functionality in advance of 

the hearing may arrange a “practice run” by contacting the courtroom deputy. 

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EXHIBITS AND DEMONSTRATIVE AIDS

Exhibits should be filed ahead of time by the date that they would normally be exchanged pursuant to our 

local rules using the "list (witness/exhibit/generic)" OR "notice (generic)” OR “Support/Supplemental 

document” event in ECF. 

Demonstrative aids and Power Points should also be filed prior to the hearing, if possible. If not, WebEx

has the ability to allow you to share your screen, or a particular document, with everyone in the hearing. If 

these documents are admitted as exhibits, they would then have to be filed after the hearing. 

• During the hearing, lawyers can refer to (and offer) their exhibits by referencing the exhibit’s

docket number for the court and all to access. After the hearing, the court will create a Minute

Entry reflecting which exhibits were admitted. You should consider emailing exhibits to witnesses

ahead of time since they may not have access to PACER.

• In addition for evidentiary hearings, when more than ten exhibits have been filed in

ECF or when the total page count of all exhibits exceeds 500 pages, Judge Everett

requests a thumb/USB drive be delivered to him prior to the hearing at: U.S.

Bankruptcy Court, Attn: Stephen Manz, 1100 Commerce Street, Room 1254, Dallas,

TX 75242.

• Paper copies of exhibits are not encouraged; however, paper copies may be

provided to the witness(s) at an in-person hearing if preferred.

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