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To: scion who wrote (11665)	11/7/2007 4:42:43 PM
From: scion	Respond to of 12518

11/07/2007 281 Joint Motion to Continue Hearing on Motion for Immediate Surrender of Nonresidential Real Property, filed by 10315 LLC and Chapter 11 Trustee Kenneth Henry (RE: related document(s)219 Motion for Miscellaneous Relief, filed by Creditor 10315 LLC). (Attachments: # 1 Proposed Order) (Case, E.) (Entered: 11/07/2007) ----------------- Doc 281 IN RE: Case No. 07-50935 PRO MOLD, INC., Chapter 11 Debtor. JOINT MOTION TO CONTINUE HEARING ON MOTION FOR IMMEDIATE SURRENDER OF NONRESIDENTIAL REAL PROPERTY Chapter 11 Trustee Kenneth Henry (“Trustee Henry”) and Lessor 10315 LLC file this their Joint Motion to Continue Hearing on Motion for Immediate Surrender of Nonresidential Real Property and in support thereof respectfully state the following: 1. The Court has jurisdiction in regard to this matter pursuant to 28 U.S.C. §1334 and 28 U.S.C. §157 and the Local Rules for the United States District Court for the Eastern District of Kentucky. 2. This matter is a core proceeding under 28 U.S.C. §157(b)(2)(D). 3. On May 16, 2007 Debtor Pro Mold, Inc. (“Debtor Pro Mold”), filed its Voluntary Chapter 11 Petition for Relief in the United States Bankruptcy Court for the Eastern District of Kentucky, Lexington Division (“Court”). 4. On September 27, 2007, Lessor 10315 LLC filed the Motion for Immediate Surrender of Nonresidential Real Property and it was scheduled to be heard on October 11, 2007. 5. On or about October 5, 2007, Trustee Henry was appointed as the Chapter 11 Trustee. 6. The hearing on the Motion for Immediate Surrender of Nonresidential Real Property was continued to November 9, 2007. (Joint Motion to Continue Hearing – Immediate Surrender) 7. Trustee Henry and Lessor 10315 LLC are engaged in settlement negotiations and request that the Court continue the hearing on the Motion for Immediate Surrender of Nonresidential Real Property until Monday, November 19, 2007 at 2:00 p.m. in the United States Bankruptcy Court for the Eastern District of Kentucky, Lexington Division, 100 East Vine Street, 3rd Floor Courtroom, Lexington, Kentucky. WHEREFORE, Chapter 11 Trustee Kenneth Henry and Lessor 10315 LLC request that the Court continue the hearing on the Motion for Immediate Surrender of Nonresidential Real Property until Monday, November 19, 2007 at 2:00 p.m. in the United States Bankruptcy Court for the Eastern District of Kentucky, Lexington Division, 100 East Vine Street, 3rd Floor Courtroom, Lexington, Kentucky and for such other and further relief as the Court deems just. STONE, LEYTON & GERSHMAN A Professional Corporation By: /s/ E. Rebecca Case E. Rebecca Case, EDMO #2800 Howard S. Smotkin, EDMO #4407 7733 Forsyth Boulevard, Suite 500 St. Louis, Missouri 63105 (314) 721-7011 (314) 721-8660 Facsimile erc@stoneleyton.com hss@stoneleyton.com Attorneys for John P. Murphy III Revocable Trust No. 1; Pro Plas LLC; 10315 LLC, and John P. Murphy, III, individually By: /s/ Kenneth C. Henry Kenneth C. Henry Chapter 11 Trustee CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the foregoing document has been served electronically in the method established under CM/ECF Administrative Procedures Manual and the Local Court Standing Order dated July 25, 2002, and to all parties listed on the Master Service List via electronic and/or first class, postage prepaid U.S. mail on this 7th day of November 2007. /s/ E. Rebecca Case E. Rebecca Case

To: scion who wrote (11665)	11/7/2007 6:50:22 PM
From: scion	Read Replies (1) \| Respond to of 12518

Another Pacer update 07 Nov 07 Debtor Pro Mold, Inc. Bankruptcy Petition #: 07-50935-wsh Filing Date # Docket Text 11/07/2007 282 Affidavit Re: of John P..Murphy, III, filed by 10315 LLC, John P. Murphy III Revocable Trust No 1, John P Murphy III, Pro Plas LLC (RE: related document(s)277 Support Document,,,, filed by Creditor John P Murphy, Creditor Pro Plas LLC, Creditor John P. Murphy III Revocable Trust No 1, Creditor 10315 LLC). (Attachments: # 1 Continuation of Main Document Resume) (Case, E.) (Entered: 11/07/2007)