DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 1 OF 6

Bryan C. Assink

Texas State Bar No. 24089009

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR

AND DEBTOR-IN-POSSESSION

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

GRAND FUSION HOUSEWARES, LLC,

Debtor.

§

§

§

§

§

§

CHAPTER 11

Case No. 24-41694

DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN OF 

REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE; 

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF

Grand Fusion Housewares, LLC, as the above-captioned debtor and debtor-in-possession 

(the “Debtor”) in the above-captioned Chapter 11 case (the “Bankruptcy Case”), by and through 

its undersigned counsel, respectfully submits this Debtor’s Motion for Entry of an Order (A) 

Scheduling a Hearing on Confirmation of the Debtor’s Chapter 11 Plan of Reorganization; (B) 

Approving the Debtor’s Solicitation Package; (C) Setting Related Deadlines; and (D) Granting 

Related Relief (the “Motion”). In support thereof, the Debtor respectfully represents as follows:
DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 2 OF 6

JURISDICTION AND VENUE

1. This Court has jurisdiction over this case and this matter pursuant to 28 U.S.C. §§ 

157 and 1334 and the District Court’s Miscellaneous Order No. 33, Order of Reference of 

Bankruptcy Cases and Proceedings Nunc Pro Tunc, dated August 3, 1984. This is a core 

proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue in this district is proper pursuant 

to 28 U.S.C. §§ 1408 and 1409.

BACKGROUND

2. On May 16, 2024 (the “Petition Date”), the Debtor commenced this bankruptcy 

case by filing a voluntary petition for relief under Chapter 11, Subchapter V of Title 11 of the 

United States Code (the “Bankruptcy Code”) in this Court. The Debtor continues to manage and 

operate its business as a debtor-in-possession pursuant to section 1184 of the Bankruptcy Code. 

Behrooz Vida was appointed as the Subchapter V Trustee. No other trustee, examiner, or official 

committees have been appointed in this case.

3. On August 14, 2024, the Debtor filed the Chapter 11 Plan of Reorganization of 

Grand Fusion Housewares, LLC [Docket No. 70] (the “Plan”).

RELIEF REQUESTED

4. Pursuant to Subchapter V of the Bankruptcy Code, Rule 2002 of the Federal Rules 

of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2002-1 of the Local Bankruptcy Rules 

for the United States Bankruptcy Court for the Northern District of Texas, and Bankruptcy Code 

section 105(a), the Debtor respectfully requests the entry of an order, substantially in the form 

attached hereto as Exhibit A (the “Order”):

a. scheduling a hearing (the “Hearing”) to consider confirmation of the Plan;
DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 3 OF 6

b. establishing deadlines and other requirements in connection with 

confirmation of the Plan, with at least twenty-eight (28) days’ notice to 

creditors and parties-in-interest, for (i) voting on the Plan; and (ii) objecting 

to confirmation of the Plan;

c. approving the Solicitation Package (defined below), including the proposed 

ballot attached hereto as Exhibit B (the “Ballot”); and

d. granting related relief as requested in this Motion.

A. Request for Relief Regarding Deadlines Pertaining to Voting on Plan, Objections to

the Plan, and Timing of the Hearing

5. The Debtor requests that the Order granting this Motion provide the following:

a. the Hearing shall be scheduled for December 18, 2024, at 9:30 a.m.

(Central Time);

b. the deadline for the Debtor to serve the Plan, the Ballot, the Order approving 

this Motion, and the notice of the Hearing, a copy of which is attached 

hereto as Exhibit C (the “Notice of Hearing”), shall be November 12, 

2024;

c. the deadline by which the Debtor must file the Plan Supplement (as defined 

in the Plan) shall be December 6, 2024; 

d. the deadline for the submission of Ballots to the undersigned so as to be 

actually received shall be December 13, 2024, at 5:00 p.m. (Central Time)

(the “Voting Deadline”);

e. the deadline by which any objections to the confirmation of the Plan must 

be filed with the Court and served so as to be actually received shall be 

December 13, 2024, at 5:00 p.m. (Central Time) (the “Objection 

Deadline”);

f. the deadline by which any objection to the Debtor’s proposed assumption 

or rejection of executory contracts under Section 365 of the Bankruptcy 

Code, including any proposed cure amounts for the assumption of any 

executory contract or unexpired lease, so as to be filed with the Court and 

to be actually received shall be December 13, 2024, at 5:00 p.m. (Central 

Time) (the “Contract Objection Deadline”);

g. the deadline by which elections under Section 1111(b) of the Bankruptcy 

Code shall be made so as to be actually received shall be December 13, 

2024, at 5:00 p.m. (Central Time) (the “1111(b) Deadline”);
DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 4 OF 6

h. A copy of any such objection to the Plan, objection to the assumption or

rejection of any executory contract or unexpired leases, or election under 

Section 1111(b) of the Bankruptcy Code shall be served at the following 

addresses so as to be actually received on or before such deadline:

Bryan C. Assink

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

Behrooz Vida

The Vida Law Firm, PLLC

3000 Central Drive

Bedford, TX 76021

Telephone: (817) 358-9977

Email: behrooz@vidalaw.com

Susan B. Hersh

Office of the U.S. Trustee

1100 Commerce Street, Room 976

Dallas, Texas 75242

Telephone: (214) 767-1073

Email: susan.hersh@usdoj.gov

i. the deadline by which a Ballot tabulation must be filed with the Court shall 

be December 17, 2024; 

j. the deadline for parties to file witness and exhibit lists with the Court for 

the Hearing shall be December 15, 2024; and 

k. the Debtor’s deadline to file replies or responses to any objections to

confirmation of the Plan, or other pleadings in support of confirmation of 

the Plan, shall be December 16, 2024.

6. The Debtor submits that the timeline and requirements proposed above are fair and 

reasonable under the circumstances of this case and should be approved. 
DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 5 OF 6

B. Request for Approval of the Solicitation Package

7. The Debtor requests that the Court approve the Solicitation Package, including the 

use of the Ballot for submission to the creditors eligible to vote on the Plan. The Debtor will mail 

the Plan (as may be amended or supplemented), the Ballot, the Order approving this Motion, and 

the Notice of Hearing (collectively, the “Solicitation Package”) to the Debtor’s creditors.

8. Among other things, the Solicitation Package will set forth (a) the time and place 

of the Hearing, (b) the classes of creditors under the Plan entitled to vote thereon; (c) the deadline 

for submission of Ballots; and (d) the deadline for filing and serving objections to the confirmation 

of the Plan, objections to the assumption and rejection of executory contracts, and the deadline for 

making elections under Section 1111(b) of the Bankruptcy Code.

9. The Debtor submits that the proposed Solicitation Package satisfies the applicable 

notice and information requirements set forth in Bankruptcy Rule 2002(b) and should be approved.

WHEREFORE, the Debtor respectfully requests that this Court grant the relief requested 

in the Motion and award the Debtor such further and other relief that this Court deems just and 

proper.

Dated: November 6, 2024 Respectfully submitted,

/s/ Bryan C. Assink

Bryan C. Assink

Texas State Bar No. 24089009

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR 

AND DEBTOR-IN-POSSESSION
DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN

OF REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 6 OF 6

CERTIFICATE OF SERVICE

I certify that on November 6, 2024, a true and correct copy of the foregoing document was 

served via the Court’s CM/ECF system on all parties requesting such service in this case, as well 

as by United States Mail, first class postage prepaid, upon the limited service list attached hereto.

/s/ Bryan C. Assink

Bryan C. Assink
Exhibit A

“Proposed Order”
ORDER GRANTING DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN OF

REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 1 OF 4

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

GRAND FUSION HOUSEWARES, LLC,

Debtor.

§

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§

§

§

§

CHAPTER 11

Case No. 24-41694

ORDER GRANTING DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) 

SCHEDULING A HEARING ON CONFIRMATION OF THE

DEBTOR’S CHAPTER 11 PLAN OF REORGANIZATION; (B) APPROVING 

THE DEBTOR’S SOLICITATION PACKAGE; (C) SETTING RELATED

DEADLINES; AND (D) GRANTING RELATED RELIEF

The Court has considered the Debtor’s Motion for Entry of an Order (A) Scheduling a

Hearing on Confirmation of the Debtor’s Chapter 11 Plan of Reorganization; (B) Approving the 

Debtor’s Solicitation Package; (C) Setting Related Deadlines; and (D) Granting Related Relief

(the “Motion”).

1 After consideration of the Motion and the record in this case, the Court finds that

it has jurisdiction over this matter pursuant to 28 U.S.C. § 1334; that the Motion is a core

1 Capitalized terms used herein but not otherwise defined shall have the meaning given to them in the Motion.
ORDER GRANTING DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN OF

REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 2 OF 4

proceeding pursuant to 28 U.S.C. § 157(b)(2); that the Court may enter a final order on the Motion 

consistent with Article III of the United States Constitution; that the venue of this proceeding and 

the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; that the Debtor 

provided adequate and appropriate notice of the Motion under the circumstances and that no other 

or further notice is required; that the legal and factual bases set forth in the Motion established just 

cause for the relief granted in this Order; and that any objections filed in response to the Motion 

have been withdrawn or overruled on the merits.

Accordingly, it is hereby ORDERED that:

1. The Motion is GRANTED as set forth herein.

2. The Solicitation Package is hereby APPROVED.

3. The Ballot, attached as Exhibit B to the Motion, completed in conformity with this 

Order and the Debtor’s proposed Solicitation Package, is approved in all respects. The Debtor shall 

serve the Plan, the Ballot, this Order, and the Notice of Hearing attached as Exhibit C to the Motion

on or before November 12, 2024. 

4. The Debtor’s deadline to file the Plan Supplement is December 6, 2024;

5. To be counted as a vote to accept or reject the Plan, a Ballot must be properly 

executed, completed, and delivered to the following address so as to be actually received by no 

later than December 13, 2024, at 5:00 p.m. (Central Time) (the “Voting Deadline”):

Bryan C. Assink

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

Email: bryan.assink@bondsellis.com

Ballots received after the Voting Deadline will not be counted except upon further order of the 

Court.
ORDER GRANTING DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN OF

REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 3 OF 4

6. Objections, if any, to confirmation of the Plan shall be filed with the Court and 

served no later than December 13, 2024, at 5:00 p.m. (Central Time). 

7. The deadline for any counter party to any executory contract or unexpired lease to 

file and serve objections to the assumption or rejection of such executory contract or unexpired 

lease under section 365 of the Bankruptcy Code, including any proposed cure amounts, is

December 13, 2024, at 5:00 p.m. (Central Time).

8. Any party desiring to make an election under Section 1111(b) of the Bankruptcy 

Code shall do so by service upon Debtor’s counsel by December 13, 2024, at 5:00 p.m. (Central 

Time).

9. A copy of any such objection to the Plan, objection to the assumption or rejection 

of any executory contract, including proposed cure amounts, or election under Section 1111(b) of 

the Bankruptcy Code shall be served at the following addresses so as to be actually received on or 

before such deadline:

Bryan C. Assink

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

Behrooz Vida

The Vida Law Firm, PLLC

3000 Central Drive

Bedford, TX 76021

Telephone: (817) 358-9977

Email: behrooz@vidalaw.com

Susan B. Hersh

Office of the U.S. Trustee

1100 Commerce Street, Room 976

Dallas, Texas 75242

Telephone: (214) 767-1073

Email: Susan.hersh@usdoj.gov
ORDER GRANTING DEBTOR’S MOTION FOR ENTRY OF AN ORDER (A) SCHEDULING A

HEARING ON CONFIRMATION OF THE DEBTOR’S CHAPTER 11 PLAN OF

REORGANIZATION; (B) APPROVING THE DEBTOR’S SOLICITATION PACKAGE;

(C) SETTING RELATED DEADLINES; AND (D) GRANTING RELATED RELIEF PAGE 4 OF 4

10. The Debtor shall file a tabulation of Ballots with the Court by no later than 

December 17, 2024, with a copy to be concurrently served upon any party that has filed a timely 

objection to the Plan. 

11. Any witness or exhibit list to be filed in connection with the Hearing to consider 

confirmation of the Plan shall be filed on or before December 15, 2024.

12. The Debtor’s deadline to file replies or responses to any objections to confirmation 

of the Plan, or other pleadings in support of confirmation of the Plan, shall be December 16, 2024.

13. A hearing to consider confirmation of the Plan will be held before the Honorable 

Mark X. Mullin, United States Bankruptcy Judge, at the United States Courthouse, 501 West Tenth 

Street, Room 128, Fort Worth, Texas 76102 on December 18, 2024, at 9:30 a.m. (Central Time) 

(the “Hearing”). The Hearing may be continued from time to time by the Court without further 

notice other than the announcement of the adjourned date at the Hearing or any continued hearing.

14. This Court hereby retains jurisdiction with respect to all matters arising from or 

related to the implementation or interpretation of this Order.

### END OF ORDER ###

Respectfully submitted by:

Bryan C. Assink

Texas State Bar No. 24089009

Bonds Ellis Eppich Schafer Jones LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR

AND DEBTOR-IN-POSSESSION
Exhibit B

“Ballot”
BALLOT FOR ACCEPTING OR REJECTING THE DEBTOR’S

PROPOSED CHAPTER 11 PLAN OF REORGANIZATION PAGE 1

Bryan C. Assink

Texas State Bar No. 24089009

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR

AND DEBTOR-IN-POSSESSION

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

GRAND FUSION HOUSEWARES, LLC,

Debtor.

§

§

§

§

§

§

CHAPTER 11

Case No. 24-41694

CLASSES 3 AND 7 BALLOT FOR ACCEPTING OR 

REJECTING PROPOSED CHAPTER 11 PLAN 

OF REORGANIZATION OF GRAND FUSION HOUSEWARES, LLC

The above-captioned debtor and debtor-in-possession (the “Debtor”), has sent this Ballot 

to you because its records indicate that you are an Entity that holds a Claim against the Debtor, 

and you have a right to vote to accept or reject the Debtor’s Chapter 11 Plan of Reorganization of 

Grand Fusion Housewares, LLC [Docket No. 70] (as amended or modified, the “Plan”).1

The Plan and certain other materials served contemporaneously with this Ballot describe 

your rights and are included in the packet you are receiving with this Ballot. If you do not have a 

copy of the Plan, or if you need to obtain additional solicitation materials, you may contact Bryan 

C. Assink, Bonds Ellis Eppich Schafer Jones LLP, as counsel to the Debtor (the “Firm”), 420 

Throckmorton Street, Suite 1000, Fort Worth, Texas 76102, telephone: (817) 779-4297, email: 

bryan.assink@bondsellis.com.

This Ballot may not be used for any purpose other than to vote on the Plan. This Ballot 

does not constitute, and shall not be deemed to be, a Proof of Claim or an assertion or admission 

of a Claim. If you believe you have received this Ballot in error, please contact the Firm at the 

address, telephone number, and/or email address set forth above.

You should carefully and thoroughly review the Plan before you vote. You may wish 

to seek legal advice concerning the Plan and the Plan’s classification and treatment of your 

1 Capitalized terms used but not otherwise defined in this Ballot shall have the meanings given to them in the Plan.
BALLOT FOR ACCEPTING OR REJECTING THE DEBTOR’S

PROPOSED CHAPTER 11 PLAN OF REORGANIZATION PAGE 2

Claim. If you hold Claims in more than one Class, you will receive a separate Ballot for each 

Class in which you are entitled to vote.

If your Ballot is not actually received by the Firm on or before December 13, 2024, at 

5:00 p.m. (Central Time), and if the such deadline is not extended, your vote will not count.

If the Court confirms the Plan, it will bind you regardless of whether or not you vote.

[Remainder of Page Intentionally Left Blank]
BALLOT FOR ACCEPTING OR REJECTING THE DEBTOR’S

PROPOSED CHAPTER 11 PLAN OF REORGANIZATION PAGE 3

1. Amount of Claim

The undersigned certifies that as of the date hereof, the undersigned is an Entity that holds 

a Claim in the Class indicated below in the following aggregate unpaid amount (insert amount in 

box below):

 Class: 

 Amount of Claim: $ 

2. Vote on Plan

THE DEBTOR RECOMMENDS THAT YOU VOTE TO ACCEPT THE PLAN

The Entity that holds the Claim set forth in Item 1 votes to (please check one):

ACCEPT THE PLAN REJECT THE PLAN

Any Ballot that is executed by an Entity that holds a Claim but that indicates both an 

acceptance and a rejection of the Plan, or does not indicate either an acceptance or rejection of the 

Plan, will not be counted.

3. Certifications

By signing this Ballot, the undersigned certifies to the Court and Debtor:

1. That either: (a) the Entity is the holder of the Claim(s) set forth herein; or (b) the Entity 

is an authorized signatory for an Entity that is a holder of such Claim(s) being voted;

2. that the Entity has received a copy of the Plan and acknowledges that the solicitation 

thereof is being made pursuant to the terms and conditions set forth in the Plan;

3. that the Entity has cast the same vote with respect to all Claim(s) set forth herein;
BALLOT FOR ACCEPTING OR REJECTING THE DEBTOR’S

PROPOSED CHAPTER 11 PLAN OF REORGANIZATION PAGE 4

4. that no other Ballots with respect to the amount of the Claim(s) identified in herein

have been cast or, if any other Ballots have been cast with respect to such Claims(s), 

then any such Ballots earlier received are revoked;

5. that the Entity understands and, by accepting the Plan, agrees with the treatment 

provided for its Claim(s) under the Plan; and

6. that the Entity acknowledges and understands that it will be subject to the terms and 

treatment outlined in the Plan—despite voting to reject the Plan—if the Plan is 

confirmed.

[Signature Page to Follow]
BALLOT FOR ACCEPTING OR REJECTING THE DEBTOR’S

PROPOSED CHAPTER 11 PLAN OF REORGANIZATION PAGE 5

Name of Holder:

(Please print or type)

Signature:

Name of Signatory:

(If other than Holder)2

Title:

Address:

Date Completed:

PLEASE COMPLETE, SIGN, AND DATE THE BALLOT AND 

RETURN IT PROMPTLY TO:

Via Electronic Mail or Regular First Class Mail:

bryan.assink@bondsellis.com

or

Bryan C. Assink

Bonds Ellis Eppich Schafer Jones LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

YOUR BALLOT MUST ACTUALLY BE RECEIVED BY THE VOTING DEADLINE, 

WHICH IS DECEMBER 13, 2024, AT 5:00 P.M. (CENTRAL TIME).

2 If you are completing this Ballot on behalf of another person or Entity, indicate your relationship with such person 

or Entity and the capacity that you are signing. You may be required to provide additional information or 

documentation with respect to such relationship.
Exhibit C

“Notice of Hearing”
NOTICE OF CONFIRMATION HEARING AND DATES RELATED THERETO PAGE 1 OF 4

Bryan C. Assink

Texas State Bar No. 24089009

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR

AND DEBTOR-IN-POSSESSION

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

IN RE:

GRAND FUSION HOUSEWARES, LLC,

Debtor.

§

§

§

§

§

§

CHAPTER 11

Case No. 24-41694

NOTICE (I) FIXING TIME FOR SUBMITTING BALLOTS VOTING TO 

ACCEPT OR REJECT THE CHAPTER 11 PLAN OF REORGANIZATION OF 

GRAND FUSION HOUSEWARES, LLC; (II) FIXING TIME FOR PARTIES TO FILE 

OBJECTIONS TO CONFIRMATION OF THE PLAN; AND (III) SCHEDULING THE

CONFIRMATION HEARING AND DATES RELATED THERETO 

PLEASE TAKE NOTICE that on August 14, 2024, Grand Fusion Housewares, LLC, 

as the above-captioned debtor and debtor-in-possession (the “Debtor”), filed its Chapter 11 Plan 

of Reorganization of Grand Fusion Housewares, LLC [Docket No. 70] (the “Plan”) 1 in the United 

States Bankruptcy Court for the Northern District of Texas (the “Court”).

PLEASE TAKE FURTHER NOTICE that on or before November 12, 2024, a 

solicitation package consisting of a copy of this Notice, the Plan (as may be amended or 

supplemented), the Order approving the Debtor’s solicitation motion at Docket No. _ (the 

“Solicitation Order”), and a Ballot, substantially in the form approved by the Solicitation Order, 

shall be mailed to all creditors, equity security holders, and any other party required to be served 

in accordance with the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and shall 

be transmitted to the United States Trustee as provided in Bankruptcy Rule 3017(d); however, in 

accordance with 11 U.S.C. § 1126(f), acceptances and rejections of the Plan will not be solicited 

from any class that is not impaired under the Plan.

1 Capitalized terms used herein but not defined shall have the meaning set forth in the Plan.
NOTICE OF CONFIRMATION HEARING AND DATES RELATED THERETO PAGE 2 OF 4

PLEASE TAKE FURTHER NOTICE that the deadline for a party to deliver a Ballot

accepting or rejecting the Plan is December 13, 2024, at 5:00 p.m. (Central Time). All Ballots

must be timely received by Debtor’s counsel at the following address:

Bryan C. Assink

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

Email: bryan.assink@bondsellis.com

Without further Court order, no acceptances or rejections of the Plan received after the stated 

deadline shall be counted or otherwise included in the tabulation of Ballots accepting or rejecting

the Plan except as may otherwise be authorized by the Court.

PLEASE TAKE FURTHER NOTICE that, pursuant to Bankruptcy Rule 3020(b)(1), the 

deadline for filing and serving written objections to confirmation of the Plan is December 13, 

2024, at 5:00 p.m. (Central Time).

PLEASE TAKE FURTHER NOTICE that the deadline for any counter party to any 

executory contract or unexpired lease to file objections to the assumption or rejection of such 

executory contract or unexpired lease under section 365 of the Bankruptcy Code, including any 

proposed cure amounts, is December 13, 2024 at 5:00 p.m. (Central Time).

PLEASE TAKE FURTHER NOTICE that any election under Section 1111(b) of the 

Bankruptcy Code is due in writing to the undersigned by December 13, 2024, at 5:00 p.m. 

(Central Time).

PLEASE TAKE FURTHER NOTICE that a copy of any objection to confirmation of 

the Plan, objection to the assumption or rejection of any executory contract, including proposed 

cure amounts, or election under Section 1111(b) of the Bankruptcy Code, shall be served at the 

following addresses so as to be actually received on or before such deadline:

Bryan C. Assink

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

Behrooz Vida

The Vida Law Firm, PLLC

3000 Central Drive

Bedford, TX 76021

Telephone: (817) 358-9977

Email: behrooz@vidalaw.com

Susan B. Hersh

Office of the U.S. Trustee

1100 Commerce Street, Room 976

Dallas, Texas 75242

Telephone: (214) 767-1073

Email: Susan.hersh@usdoj.gov
NOTICE OF CONFIRMATION HEARING AND DATES RELATED THERETO PAGE 3 OF 4

PLEASE TAKE FURTHER NOTICE that the Debtor shall file a tabulation of Ballots 

with the Clerk of the Court by no later than December 17, 2024, with a copy to be concurrently 

served upon any party that has timely filed an objection to confirmation of the Plan.

PLEASE TAKE FURTHER NOTICE that any witness or exhibit list to be filed in 

connection with the Hearing to consider confirmation of the Plan shall be filed on or before 

December 15, 2024.

PLEASE TAKE FURTHER NOTICE that a hearing to consider confirmation of the Plan

(the “Confirmation Hearing”) will commence on December 18, 2024, at 9:30 a.m. (Central 

Time), before the Honorable Mark X. Mullin, United States Bankruptcy Judge for the Northern 

District of Texas, Fort Worth Division, which hearing shall take place at (i) Room 128, U.S. 

Courthouse, 501 W. Tenth Street, Fort Worth, Texas 76102, and (ii) via WebEx using the 

following information:

For WebEx Video Participation/Attendance:

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

For WebEx Telephonic Only Participation/Attendance:

Dial-In: 1.650.479.3207

Meeting ID: 2310-650-8783

PLEASE TAKE FURTHER NOTICE that additional information regarding remote 

attendance at the hearing can be found at:

https://www.txnb.uscourts.gov/sites/txnb/files/hearings/WebEx%20Hearing%20Instructions%20

for%20Judge%20Mullin%205.14.2024.pdf.

Dated: November __, 2024 Respectfully submitted,

/s/

Bryan C. Assink

Texas State Bar No. 24089009

BONDS ELLIS EPPICH SCHAFER JONES LLP

420 Throckmorton Street, Suite 1000

Fort Worth, Texas 76102

(817) 405-6900 telephone

(817) 405-6902 facsimile

Email: bryan.assink@bondsellis.com

COUNSEL FOR DEBTOR

AND DEBTOR-IN-POSSESSION
NOTICE OF CONFIRMATION HEARING AND DATES RELATED THERETO PAGE 4 OF 4

CERTIFICATE OF SERVICE

I certify that on November _, 2024, a true and correct copy of the foregoing document was 

served via the Court’s CM/ECF system on all parties requesting such service in this case, and by 

United States Mail, first class postage prepaid, upon the master service list attached hereto. 

/s/

Bryan C. Assink
Grand Fusion Housewares, LLC

Case No. 24-41694-MXM-11

Limited Service List

As of 11-6-2024

Debtor:

Grand Fusion Housewares, LLC

12 Partridge

Irvine, CA 92604

20 Largest Unsecured Creditors:

Alliance Funding Group

17542 17th Street #200

Tustin, CA 92780

American Express National Bank 

c/o Becket & Lee LLP

PO Box 3001

Malvern, PA 19355-0701

Capital One

P.O. Box 60599

City Of Industry, CA 91716-0599

Cixi Yufei Import & Export Co

Room 1903

Friendship Bldg No.558 Renhe Rd

Cixi City 315300, Zhejiang Prov. China

Flying Cork Media LLC

320 Ft. Duquesne Blvd. Suite 200

Pittsburgh, PA 15222

Imagination Products Corp.

227 W. Cedar Street

Chillicothe, IL 61523

Integrated Logistics 2000 LLC

PO Box 8372

Virginia Beach, VA 23450

DFW & Assoc d/b/a Lee & Associates

c/o Conor White

Munsch Hardt Kopf & Harr, PC

500 N. Akard St., Suite 4000

Dallas, TX 75201

Parker & Bailey Corp

4 Walpole Park

Walpole, MA 02081

Peachy Clean

Devine Products LLC

PO Box 1068

Dalton, GA 30722

Propella Capital LLC

1820 Avenue M, #432

Brooklyn, NY 11230

Propella Capital LLC

c/o Tucker, Albin & Assoc

1702 Collins Blvd., Ste 100

Richardson, TX 75080

Rapid Finance

20 West Jefferson, Flr 11

Detroit, MI 48226

Silverline Services Inc.

265 Sunrise Highway, Ste 236

Rockville Centre, NY 11570

Silverline Services, Inc.

c/o Zachter PLLC

Jeffrey Zachter

2 University Plaza, Ste 205

Hackensack, NJ 07601

Smart Business Funding

20515 NE 22nd Ave

Miami, FL 33180

Smart Business

c/o Triton Recovery LLC

3111 N. University Dr., Ste. 604

Coral Springs, FL 33065
Umbra

1705 Broadway

Buffalo, NY 14212

US Bank

Bankruptcy Dept.

P.O. Box 108

St. Louis, MO 63166-0108

Wells Fargo

333 Market Street, 14th Flr

San Francisco, CA 94105

Wuxi Rayshine Industrial & Trading Co

4-5th Flr, Chiway Center 2166-1

Taihu Avenue Wuxi

Jiangsui 214072 China

Silverline Services Inc.

1334 Peninsula Blvd., Ste. 160

Hewlett, NY 11557

Governmental Agencies:

Office of the United States Trustee

1100 Commerce Street, Room 976

Dallas, TX 75242

Internal Revenue Service

Special Procedures - Insolvency

P.O. Box 7346

Philadelphia, PA 19101-7346

Texas Comptroller 

Bankruptcy & Collection Division MC 008

P.O. Box 12548

Austin, TX 78711-2548

California State Comptroller

300 Capitol Mall, Suite 1850

Sacramento, CA 95814

Internal Revenue Service

1100 Commerce St. MC5027DAL

Dallas, TX 75242

Employment Development Department

P.O. Box 826880

Sacramento, CA 94280-0001

Franchise Tax Board

Bankruptcy Section MS A340

P.O. Box 2952

Sacramento, CA 95812-2952

Secured Creditors:

Celtic Bank Corporation

268 S. State Street

Salt Lake City, UT 84111

Midwest Regional Bank

363 Festus Centre Drive

Festus, MO 63028

U.S. Small Business Administration

150 Westpark Way, Suite 130

Euless, TX 76040

First Citizens Community Bank

39 King Arthur Drive

Mill Hall, PA 17751
Subchapter V Trustee:

Behrooz P. Vida

The Vida Law Firm, PLLC

3000 Central Drive

Bedford, TX 76021

Notice of Appearance Parties:

Dallas County

c/o John K. Turner

Linebarger Goggan Blair & Sampson LLP

2777 N. Stemmons Frwy, Ste 1000

Dallas, TX 75207

Midwest Regional Bank

c/o James W. Brewer

Kemp Smith LLP

P.O. Drawer 2800

El Paso, TX 79999-2800

Carrollton-Farmers Branch ISD

c/o Linda D. Reece

Perdue, Brandon, Fielder, Collins & Mott

1919 S. Shiloh Rd., Suite 640, LB40

Garland, TX 75042

Small Business Administration

c/o Dawn Whalen Theiss

Assistant United States Attorney 

1100 Commerce Street, Third Floor 

Dallas, Texas 75242-1699