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Butler Snow LLP 

Martin A. Sosland (TX Bar No.18855645) 

Candice Carson (TX Bar No. 24074006) 

2911 Turtle Creek Blvd., Suite 1400 

Dallas, Texas 75219 

Tel: (469) 680-5500 

Fax: (469) 680-5501 

E-mail: martin.sosland@butlersnow.com

candice.carson@butlersnow.com

Butler Snow LLP 

Adam M. Langley (pro hac vice pending) 

Kenneth Groce (pro hac vice pending) 

6075 Poplar Avenue, Suite 500 

Memphis, TN 38119 

Tel: (901) 680-7200 

Fax: (901) 680-7201 

E-mail: adam.langley@butlersnow.com

kenneth.groce@butlersnow.com

PROPOSED COUNSEL FOR THE 

DEBTOR 

Butler Snow LLP 

Xan Flowers (pro hac vice pending) 

1819 Fifth Avenue North, Suite 1000 

Birmingham AL 35203 

Tel: (205) 297-2200 

Fax: (205) 297-2201 

E-mail:xan.flowers@butlersnow.com

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: § 

 § CHAPTER 11 

TARRANT COUNTY SENIOR LIVING § 

CENTER, INC., D/B/A THE STAYTON § 

AT MUSEUM WAY 1 § CASE NO. 24-80068-swe11 

 § 

Debtor. § 

AMENDED AGENDA FOR HEARING OF MATTERS SCHEDULED 

FOR OCTOBER 2, 2024, AT 3:00 P.M. (PREVAILING CENTRAL TIME) 

The above-captioned debtor and debtor-in-possession (the “Debtor”) hereby files this 

agenda for matters set for hearing on October 2, 2024, at 3:00 p.m. (prevailing Central time), 

before the Honorable Judge Scott W. Everett at the United States Bankruptcy court for the 

Northern District of Texas via Webex at https://us-courts.webex.com/meet/Everett; Webex dialin: (US/Canada) 1-650-479-3207; Access code: 2304 017 9738. 

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 The last four digits of the Debtor’s federal tax identification number are 8602. 

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AGENDA MATTERS

1. Notice of Designation as Complex Chapter 11 Bankruptcy Case [Docket No. 2] 

Related Documents: 

a. Voluntary Petition for Tarrant County Senior Living Center, Inc. [Docket No. 1] 

b. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

c. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

2. Emergency Motion of the Debtor for Interim and Final Orders (I) Authorizing the Debtor 

to Use the Cash Collateral of BOKF, N.A., as Trustee; (II) Providing BOKF, N.A., as 

Trustee, Adequate Protection; (II) Providing Superpriority Administrative Expense 

Claims; (IV) Modifying the Automatic Stay; (V) Scheduling a Final Hearing; and 

(VI) Granting Related Relief [Docket No. 3]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

3. Debtor’s Emergency Motion for Entry of Interim and Final Orders Authorizing, But Not 

Directing, the Debtor to Continue Its Prepetition Business Operations, Policies, and 

Practices and Pay Related Claims in the Ordinary Course of Business on a Postpetition 

Basis [Docket No. 9]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

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4. Emergency Application of the Debtor for an Order Authorizing the Employment and 

Retention of Kroll Restructuring Administration LLC as Claims, Noticing, and Solicitation 

Agent Nunc Pro Tunc to the Petition Date [Docket No. 17] 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

5. Emergency Motion of the Debtor for Entry of Final Order (I) Authorizing the Debtor to 

(A) Maintain Existing Insurance Policies and Pay All Insurance Obligations Arising 

Thereunder and (B) Renew, Revise, Extend, Supplement, Change, or Enter Into New 

Insurance Policies, and (II) Granting Certain Related Relief [Docket No. 5]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

6. Emergency Motion of the Debtor for Entry of an Order (I) Authorizing the Debtor to 

(A) Pay Certain Prepetition Salaries, Wages, and Compensation and (B) Continue 

Employee Benefit Programs and (II) Directing Banks to Honor and Process Checks and 

Transfers Related to Such Employee Obligations [Docket No. 8]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

7. Emergency Motion of the Debtor for Entry of an Order Authorizing the Implementation of 

(I) Procedures to Maintain and Protect Confidential Resident and Patient Information, 

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(II) Procedures to Protect Other Individual Information, and (III) Authorizing Service by 

Email on Parties in Interest [Docket No. 10]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

8. Emergency Motion of the Debtor for Entry of an Order Authorizing Debtor to Employ 

Professionals Used in Ordinary Course of Business Effective as of Petition Date [Docket 

No. 11] 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

9. Debtor’s Emergency Motion for Entry of Interim and Final Orders Authorizing the Debtor 

to Pay Certain Prepetition Taxes [Docket No. 7]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

10. Emergency Motion of the Debtor for Entry of an Order Authorizing (I) Continued Use of 

Existing Cash Management System, (II) Maintenance of Existing Bank Accounts, 

(III) Continued Use of Existing Business Forms, and (IV) the Waiver of the 11 U.S.C. 

§ 345(b) Deposit and Investment Requirements [Docket No. 4]; 

Related Documents: 

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a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

11. Debtor’s Emergency Motion for Entry of Interim and Final Orders (I) Prohibiting Utility 

Providers from Altering, Refusing, or Discontinuing Service, (II) Deeming the Utility 

Providers Adequately Assured of Future Performance, and (III) Establishing Procedures 

for Determining Requests for Additional Adequate Assurance [Docket No. 6]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

12. Emergency Motion of the Debtor for Entry of an Order (I) Extending Time for Debtor to 

File Its Schedules and Statements and (II) Permanently Waiving Same Upon Confirmation 

of Debtor’s Prepackaged Plan of Reorganization [Docket No. 12]; 

Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

13. Emergency Motion of the Debtor for Entry of an Order (I) Scheduling Combined Hearing 

on (A) Adequacy of Disclosure Statement and (B) Confirmation of Prepackaged Plan of 

Reorganization; (II) Fixing Related Objection Deadlines and Approving Notice 

Procedures; (III) Approving Prepetition Solicitation Procedures; (IV) Conditionally 

Directing the United States Trustee Not To Convene Section 341(a) Meeting of Creditors; 

and (V) Granting Related Relief [Docket No. 13] 

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Related Documents: 

a. Amended Declaration of Jeff Gentry in Support of Chapter 11 Petition and First Day 

Pleadings [Docket No. 34] 

b. Notice of Emergency Hearing for October 2, 2024 Setting [Docket No. 30] 

Status: This matter is going forward on an uncontested basis subject to passage of 

the objection deadline. 

RESPECTFULLY SUBMITTED this 1st day of October 2024. 

By: Martin A. Sosland______________ 

Martin A. Sosland (TX Bar No.18855645) 

Candice Carson (TX Bar No. 24074006) 

BUTLER SNOW LLP 

2911 Turtle Creek Blvd., Suite 1400 

Dallas, Texas 75219 

Tel: (469) 680-5500 

Fax: (469) 680-5501 

E-mail:martin.sosland@butlersnow.com

candice.carson@butlersnow.com

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CERTIFICATE OF SERVICE 

I, Martin A. Sosland, certify that the foregoing Amended Agenda for Hearing of Matters 

Scheduled for October 2, 2024, at 3:00 p.m. (Prevailing Central Time) was filed electronically 

through the Court’s ECF system and served electronically on all parties enlisted to receive service 

electronically. 

Dated: October 1, 2024. 

/s/ Martin A. Sosland 

 MARTIN A. SOSLAND 

89720681.v1 

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