DEBTOR’S §1188 STATUS REPORT — Page 1

status report 1181.c 4865-0947-8077 v.1.docx [1]/4866-4251-6669, v. 2

Jeff Carruth (TX SBN: 24001846)

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

2608 Hibernia, Suite 105

Dallas, Texas 75204-2514

Telephone: (713) 341-1158

Fax: (713) 961-5341

E-mail: jcarruth@wkpz.com

PROPOSED ATTORNEYS FOR

HIGH PLAINS RADIO NETWORK, LLC,

DEBTORS AND DEBTORS IN POSSESSION

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGH PLAINS RADIO NETWORK, LLC, §

§

CASE NO. 24-70089

§

DEBTOR. §

DEBTOR’S §1188 STATUS REPORT

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

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

this status report under Code §1188(c).

1. During April 4-30, 2024, the Debtor spent considerable time and effort working

on a sale process, involving Bill Whitley and Media Services Group, and working with the

former tower lessor, Vertical Bridge REIT LLC (“VB”). VB indicated during April 4-30, 2024

that it wished to be the center piece of the process so that it might resurrect and/or preserve value

from the purported and/or disputed tower leases. Many conference calls were conducted just

with VB and at least two calls were held with VB and Whitley. With the filings of April 30,

2024, VB abruptly signaled that it was not interested in a sale process and only wished to drown

the Debtor with specious administrative rent claims, invective, and litigation.

2. Since demanding adequate protection and/or administrative rent far in excess of

the means of the Debtor, demanding a counter-offer from the Debtor, and then filing the April 30

pleadings in a tantrum less than 24 hours after the Debtor indicated it would provide the desired

counter-offer, VB has provided zero response to the counter offer and the numerous requests of

the Debtor to VB that VB constructively engage in a sale process without trying to drown the

Debtor in (disputed) adequate protection and/or administrative rent claims. Hopefully, VB

quickly will return to the table to proceed with a rationale sale process.

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DEBTOR’S §1188 STATUS REPORT — Page 2

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3. The other sale process alternative involves just the stations (primarily equipment

and the FCC licenses) without tower leases in place. The Debtor is exploring that potential with

Whitley. The intact stations hopefully would bring sufficient interest to satisfy the allowed

secured claim(s) of the equipment lenders and leave other cash on the table for a relatively

healthy waterfall.

4. The Debtor has a small group of stations that the Debtor has moved off of VB

towers. The Debtor is exploring the potential of a plan centered around those stations. The

Debtor has just completed a review of the equipment necessary to operate just those stations so

that the Debtor may address the allowed secure claim(s) of the equipment lender(s) on just those

stations and evaluate the potential going forward EBDITA.

5. Debtor hopes to have a plan ready to file by the time of the status conference. If

so, the Debtor will file an amended status report so that the Debtor may address the timing of a

confirmation hearing after the filing of a plan and whether a confirmation hearing may need to be

delayed to accommodate a sale process. The Debtor also is evaluating whether seeking an

extension of the Code § 1189(b) timeline would be necessary to accommodate a sale process to

conclude before proceeding with a confirmation hearing.

Dated: May 9, 2024 Respectfully submitted:

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

By: /s/ Jeff Carruth

JEFF CARRUTH (TX SBN:. 24001846)

2608 Hibernia, Suite 105 

Dallas, Texas 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 85 Filed 05/09/24 Entered 05/09/24 22:57:56 Desc Main

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