UNOPPOSED MOTION TO EXTEND DEADLINE FOR FILING SCHEDULES AND STATEMENT OF 

FINANCIAL AFFAIRS - Page 1

Hudson M. Jobe

Quilling, Selander, Lownds, Winslett & Moser, P.C.

2001 Bryan Street, Suite 1800

Dallas, Texas 75201

(214) 871-2100 (Telephone)

(214) 871-2111 (Telefax)

ATTORNEYS FOR DEBTOR

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: §

§

HIGHLAND SELECT EQUITY §

FUND GP, L.P. § CASE NO: 23-31039-mvl7

§ (Chapter 7)

DEBTOR. §

DEBTOR'S UNOPPOSED MOTION TO EXTEND 

DEADLINE FOR FILING SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS

TO THE HONORABLE MICHELLE V. LARSON, U.S. BANKRUPTCY JUDGE:

Highland Select Equity Fund GP, L.P. (the “Debtor”) files its Unopposed Motion to 

Extend Deadline for Filing Schedules and Statement of Financial Affairs (collectively, the 

“Schedules and Statements”) until June 16, 2023. In support thereof, the Debtor states as 

follows:

JURISDICTION

1. Pursuant to 28 U.S.C. §§ 1334 and 157, the Court has jurisdiction to hear this 

Motion. Pursuant to 28 U.S.C. § 157(b)(2)(A) and (O) the Motion presents a core proceeding.

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UNOPPOSED MOTION TO EXTEND DEADLINE FOR FILING SCHEDULES AND STATEMENT OF 

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BACKGROUND

2. This case was commenced by the filing of a voluntary petition under Chapter 7 of 

the bankruptcy Code on May 25, 2023 (“Petition Date”). The same day, an affiliate of the 

Debtor filed a Chapter 7 bankruptcy case with the Northern District of Texas, Dallas Division: In 

re Highland Select Equity Master Fund, L.P., Case No. 23-31037-swe7 (the “Highland Master 

Fund Case”), which has been assigned to Judge Everett. Scott Seidel has been appointed Chapter 

7 Trustee in both this case and the Highland Master Fund Case (the “Chapter 7 Trustee”).

3. Another affiliate of the Debtor has had a Chapter 11 bankruptcy case pending in 

the Northern District of Texas, Dallas Division, before Chief Judge Jernigan for over 3 years: In 

re Highland Capital Management, L.P., Case No. 19-34054-sgj11 (the “Highland Capital 

Case”). The Highland Capital Case is a complex case that has over 3800 docket entries. The 

Debtor and Highland Master Fund intend to request these Chapter 7 cases to be reassigned to 

Judge Jernigan given her significant experience and institutional knowledge in the Highland 

Capital Case. 

4. Currently, the deadline for the Debtor to file its Schedules and Statements is June 

8, 2023. This case was filed on a somewhat expedited basis and the Debtor is still in the process 

of preparing the Schedules and Statements. 

5. The 341 meeting is set for June 20, 2023. The Debtor and counsel are diligently 

working on the Schedules and Statements and require additional time to complete before the 

current deadline of June 8, 2023. The Debtor has conferred with the Trustee, and the Trustee 

does not oppose an 8-day extension of the deadline to file schedules and statements to June 16, 

2023, which is 4 days before the 341 meeting. 

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UNOPPOSED MOTION TO EXTEND DEADLINE FOR FILING SCHEDULES AND STATEMENT OF 

FINANCIAL AFFAIRS - Page 3

RELIEF REQUESTED

6. Pursuant to Bankruptcy Rules 1007(b) and (c), the Debtor is required to file 

schedules and statements within fourteen days after the chapter 11 filing. As stated, the original 

due date for the schedules and statements is June 8, meaning that in order to prepare the

schedules and statements, the Debtor must gather and synthesize information from books, 

records, and documents in a relatively short period of time.

7. The Debtor is diligently working on the schedules and statements but requests

additional time to obtain the necessary information to complete them.

8. The Court has authority to grant an extension of the time for the filing of 

Schedules and Statements under Bankruptcy Rule 1007(c).

9. This Motion requests an extension of time to file the Schedules and Statements to 

June 16, 2023.

10. As stated above and set forth in the certificate of conference below, undersigned 

counsel has conferred with the Trustee regarding the relief requested herein in accordance with 

Local Rule 1007-1(b) and he is unopposed and agreeable to the requested extension.

WHEREFORE the Debtor requests that the Court enter an Order Granting Extension of 

Time to File Schedules of Assets and Liabilities, Statement of Financial Affairs, and Schedule of 

Executory Contracts and Unexpired Leases, and Top 20 Creditors beyond the current 14-day 

deadline, to and including June 16, 2023, without prejudice to the Debtor’s right to seek an 

additional extension if cause so exists, and that the Court grant the Debtor such other and further

relief as is just and proper.

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Respectfully submitted,

QUILLING, SELANDER, LOWNDS, WINSLETT 

& MOSER, P.C.

2001 Bryan Street, Suite 1800

Dallas, Texas 75201

(214) 871-2100 (Telephone)

(214) 871-2111 (Facsimile)

By: /s/ Hudson M. Jobe 

 Hudson M. Jobe 

 State Bar No. 24041189

ATTORNEYS FOR DEBTOR

CERTIFICATE OF CONFERENCE

I hereby certify that on June 1, 2023, I conferred with Scott Seidel and was advised that 

the Trustee is unopposed to an extension of time to file the Schedules and Statements in this case 

to June 16, 2023.

/s/ Hudson M. Jobe

Hudson M. Jobe

CERTIFICATE OF SERVICE

I hereby certify that on June 2, 2023, a true and correct copy of the foregoing document 

was served via ECF electronic filing. 

 /s/ Hudson M. Jobe

Hudson M. Jobe

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