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Case 6:12-bk-28006-MJ

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FOR COURT USE ONLY

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Attorney or Party Name, Address, Telephone & FAX Nos., State Bar No. & Email Address

Paul R. Glassman (State Bar No. 76536) Laura L. Buchanan (State Bar No. 156261) Kathleen D. DeVaney (State Bar No. 156444) Stradling Yocca Carlson & Rauth, a Professional Corporation 100 Wilshire Blvd., Suite 440 Santa Monica, CA 90401 Telephone: (424) 214-7000 Facsimile: (424) 214-7010 E-mail: pglassman@sycr.com
Individual appearing without attorney Attorney for: Debtor

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION


In re: CASE NO: 6:12-bk-28006 MJ CHAPTER: 9

City of San Bernardino, California

APPLICATION FOR ORDER SETTING HEARING ON SHORTENED NOTICE [LBR 9075-1(b)]

Debtor(s).

1. Movant applies under LBR 9075-1(b) for an order setting a hearing on shortened notice on the following motion: MOTION FOR ENTRY OF AN ORDER (1) DIRECTING AND APPROVING FORM OF NOTICE; a. Title of motion: AND (2) SETTING DEADLINE FOR FILING OBJECTIONS TO PETITION b. Date of filing of motion: August 9, 2012 2. Compliance with LBR 9075-1(b)(2)(A): (The following three sections must be completed) a. Briefly specify the relief requested in the motion: The Debtor is seeking entry of an order (1) approving the proposed form of notice of commencement of this case pursuant to 11 U.S.C. section 923; and (2) setting a deadline for the filing of any objections to the petition initiating this chapter 9 case pursuant to 11 U.S.C. section 921.

This form is optional. It has been approved for use by the United States Bankruptcy Court for the Central District of California. October 2009 Page 1

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b. Identify the parties affected by the relief requested in the motion: Parties affected by the relief requested in the motion are the Debtor's creditors and any other parties entitled to object to the filing of the Debtor's petition.

c. State the reasons necessitating a hearing on shortened time: The Debtor cannot focus on the paramount objective of adjusting its debts and achieving fiscal stability until it establishes its eligibility to be a chapter 9 debtor, and that cannot happen until after notice of the filing of the chapter 9 case and of the date to object to eligibility has been approved by the Court and then published at least once a week for three successive weeks in a newspaper in this district and another newspaper having a circulation among bond dealers and bond brokers as required by 11 U.S.C. section 923. The Debtor seeks approval of the notice of this chapter 9 case and a deadline to object to the petition so the Debtor can establish its eligibility and then focus on its financial challenges in an efficient and effective manner while minimizing professional fees and costs incurred to the extent possible. 3. Compliance with LBR 9075-1(b)(2)(B): The attached declaration(s) justifies setting a hearing on shortened notice, and establishes a prima facie basis for the granting of the motion. 4. Movant has lodged a proposed Order Setting Hearing on Shortened Notice on mandatory Form 9075-1.2.ORDER

Date: August 9, 2012

Stradling Yocca Carlson & Rauth, A Professional Corporation


Print Law Firm Name (if applicable)

Paul R. Glassman
Print Name of Individual Movant or Attorney for Movant

/s/ Paul R. Glassman


Signature of Individual Movant or Attorney for Movant

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PROOF OF SERVICE OF DOCUMENT

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I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: 100 Wilshire Blvd., Suite 440, Santa Monica, California 90401

A true and correct copy of the foregoing document described as APPLICATION FOR ORDER SETTING HEARING ON SHORTENED NOTICE will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner indicated below:

I. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF) Pursuant to controlling General Order(s) and LBR(s), the foregoing document will be served by the court via NEF and hyperlink to the document. On August 9, 2012 I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following person(s) are on the Electronic Mail Notice List to receive NEF transmission at the email address(es) indicated below: Jerrold Abeles abeles.jerry@arentfox.com Joseph M Adams jadams@lawjma.com Andrew K Alper aalper@frandzel.com, efiling@frandzel.com;ekidder@frandzel.com Thomas V Askounis taskounis@askounisdarcy.com Anthony Bisconti tbisconti@bmkattorneys.com J Scott Bovitz bovitz@bovitz-spitzer.com Jeffrey W Broker jbroker@brokerlaw.biz Deana M Brown dbrown@milbank.com Michael J Bujold Michael.J.Bujold@usdoj.gov Alex Darcy adarcy@askounisdarcy.com Susan S Davis sdavis@coxcastle.com Paul R. Glassman pglassman@sycr.com Everett L Green everett.l.green@usdoj.gov James A Hayes jhayes@cwlawyers.com M Jonathan Hayes jhayes@hayesbklaw.com, roksana@hayesbklaw.com;carolyn@hayesbklaw.com;elizabeth@hayesbklaw.com Bonnie M Holcomb bonnie.holcomb@doj.ca.gov Whitman L Holt wholt@ktbslaw.com Steven J Katzman SKatzman@bmkattorneys.com Gregory A Martin gmartin@winston.com Scott H Olson solson@seyfarth.com Dean G Rallis drallis@sulmeyerlaw.com Kenneth N Russak krussak@frandzel.com, efiling@frandzel.com;dmoore@frandzel.com Gregory M Salvato gsalvato@salvatolawoffices.com, calendar@salvatolawoffices.com Benjamin Seigel bseigel@buchalter.com, IFS_filing@buchalter.com United States Trustee (RS) ustpregion16.rs.ecf@usdoj.gov Anne A Uyeda auyeda@bmkattorneys.com Annie Verdries verdries@lbbslaw.com Brian D Wesley brian.wesley@doj.ca.gov Service information continued on attached page II. SERVED BY UNITED STATES MAIL OR OVERNIGHT MAIL(indicate method for each person or entity served): On I served the following person(s) and/or entity(ies) at the last known

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address(es) in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and/or with an overnight mail service addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed.

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Service information continued on attached page III. SERVED BY PERSONAL DELIVERY, FACSIMILE TRANSMISSION OR EMAIL (indicate method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on August 9, 2012 I served the following person(s) and/or entity(ies) by personal delivery, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on the judge will be completed no later than 24 hours after the document is filed. Honorable Meredith A. Jury (Personal Delivery) U.S. Bankruptcy Court 3420 Twelfth Street, Suite 325 Riverside, CA 92501-3819 Service information continued on attached page I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

August 9, 2012 Date

Christine Pesis Type Name

/s/ Christine Pesis Signature

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