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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

LEE R. BOGDANOFF (State Bar No. 119542) JONATHAN S. SHENSON (State Bar No. 184250) DAVID M. GUESS (State Bar No. 238241) KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 Avenue of the Stars, 39th Floor Los Angeles, California 90067 Telephone: (310) 407-4000 Facsimile: (310) 407-9090 Proposed Bankruptcy Counsel for Debtors and Debtors In Possession Debtors' Mailing Address 3411 N. Perris Blvd. Perris, CA 92571 National R.V. Holdings, Inc.'s Tax I.D. #XX-XXX-1079 National R.V., Inc.'s Tax I.D. #XX-XXX-5022 UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION In re NATIONAL R.V. HOLDINGS, INC., a Delaware corporation; NATIONAL R.V., INC., a California corporation, Debtors. Case No.: 6:07-17941-PC Case No.: 6:07-17937-PC Chapter 11 EMERGENCY MOTION PURSUANT TO LOCAL BANKRUPTCY RULE 2081-1(b) FOR ORDER EXTENDING TIME TO FILE SCHEDULES; MEMORANDUM OF POINTS AND AUTHORITIES Hearing Date: Time: Place: December 12, 2007 1:30 p.m. Courtroom 303 U.S. Bankruptcy Court 3420 Twelfth Street Riverside, CA 92501-3819

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100279.1

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

TO THE HONORABLE PETER H. CARROLL, UNITED STATES BANKRUPTCY JUDGE; THE OFFICE OF THE UNITED STATES TRUSTEE; THE DEBTORS' TWENTY LARGEST UNSECURED CREDITORS; THE DEBTORS' SECURED LENDERS; AND OTHER PARTIES IN INTEREST: National R.V. Holdings, Inc. and National R.V., Inc. the debtors and debtors in possession in the above-captioned cases (the "Debtors"), hereby move this Court pursuant to Local Bankruptcy Rule 2081-1(b)(2)(B) for entry of an order under Rule 1007(c) of the Federal Rules of Bankruptcy Procedure ("Bankruptcy Rules"), extending by 30 days the time within which the Debtors must file their respective schedules of assets and liabilities, schedules of current income and expenditures, schedules of executory contracts and unexpired leases, and statements of financial affairs (collectively, the "Schedules"). Absent the relief requested, the Debtors would be required to file the Schedules no later than 15 days after the commencement of these cases (the "Petition Date"). The Debtors believe that it would be very difficult, if not impossible, to prepare the Schedules carefully, thoroughly, and accurately within such a short period of time, and therefore, seek a 30 day extension of time to file the Schedules. The basis for the relief requested in the Motion is set forth below and in the Declaration of Thomas J. Martini in Support of First-Day Motions, which is being filed concurrently with this Motion and is incorporated herein by reference. If the Court determines that a hearing on this Motion is necessary, the Debtors request that the Court hold such a hearing on an emergency basis. WHEREFORE, the Debtors respectfully request that the Court grant this Motion under Bankruptcy Rule 1007(c) and enter an order extending by 30 days (to January 14, 2008) the time within which the Debtors must file their respective Schedules. DATED: December 10, 2007 /s/ David M. Guess DAVID M. GUESS, an Attorney with KLEE, TUCHIN, BOGDANOFF & STERN LLP Proposed Bankruptcy Counsel for Debtors and Debtors in Possession

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100279.1

Motion re Schedule Extension

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

MEMORANDUM OF POINTS AND AUTHORITIES I. STATEMENT OF FACTS

The Debtors commenced these cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code on November 30, 2007 (the "Petition Date"). The Debtors filed these cases in order to conduct an orderly disposition of their assets, and to maximize the value of those assets for the benefit of the economic stakeholders of their estates. The Debtors' principal business is the manufacture and distribution of recreational vehicles ("RVs") throughout the United States and Canada. Since 1964, from their Perris, California facility, the Debtors have designed, manufactured, and marketed some of the industry's highest quality "Class A" gas and diesel RVs across several branded product lines, including Dolphin, Pacifica, Sea Breeze, Surf Side, Tradewinds, and Tropi-Cal. As of the Petition Date, the Debtors were the ninth largest manufacturer of "Class A" motor homes in the country. Prior to commencing these cases, the Debtors explored a variety of approaches to their continuing liquidity crisis, including a sale, a sale of certain underperforming assets, and the infusion of new equity capital. Despite many efforts, it became increasingly clear that the Debtors simply could not continue to operate for any extended period of time. As a result, the Debtors determined they had no choice other than to pursue an orderly liquidation of their assets. To that end, after having conducted substantial "reductions in force," resulting in more than a 90% reduction of their work force, they commenced these cases. The objective of these cases is to maximize value as quickly as possible. This likely will be accomplished through an orderly disposition of the Debtors' assets for the best price. The Debtors believe that value for the benefit of creditors and, with perseverance, shareholders, can be derived from primarily three sources: (a) the successful prosecution of the Kemlite Litigation;1 (b) the orderly sale of inventory, both finished and unfinished motor homes, parts
1

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In June 2006, NRV commenced a multi-million lawsuit against Crane Composites, Inc. and its parent company for breach of contract, breach of warranty, misrepresentation and other causes of action. The

100279.1

Motion re Schedule Extension

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

and replacements, and other valuable items on hand; and (c) the collection of accounts receivable, general intangibles (including intellectual property) and other assets.

Before the filing, and during the brief period since these cases were commenced, the Debtors' efforts have been directed toward maximizing their recovery from these assets. As noted, while the Debtors conducted a substantial reduction in force prepetition, the Debtors have nonetheless maintained a skeletal staff comprised of key employees, many of whom have important relationships with dealers and their flooring lenders, vendors, and customers. These relationships should prove to be invaluable to the Debtors as they proceed with an orderly disposition of their assets. Indeed, specific work teams already have been organized to coordinate the liquidation efforts, to work with dealers, and to address customer concerns. Additional information concerning the Debtors, their operations, their turnaround efforts, and the commencement of these cases, can be found in the Declaration of Thomas J. Martini in Support of First-Day Motions, on file with the Court. II. BASIS FOR RELIEF REQUESTED Analyzing and compiling the information needed to complete the Debtors' Schedules will take significant time. Given the circumstances of these cases, the Debtors believe they need an extension in order to carefully, thoroughly, and accurately prepare their Schedules. First, there are two debtors and a large number of creditors and potential creditors, meaning that a substantial number of claims could be asserted against the estates. Prepetition, the Debtors distributed RVs throughout 30 states and 5 Canadian provinces, and have been generating approximately $110 million in annual revenue as recently as 2007. In addition, the Debtors employed approximately 694 individuals prior to the Petition Date, and are parties to a substantial number of contracts and leases, including various agreements with

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lawsuit seeks both compensatory and punitive damages. This matter is now pending before District Judge Stephen G. Larson in the U.S. District Court for the Central District of California, and is scheduled to go to trial in Riverside in January 2008. At a hearing held before District Judge Larson on December 1, 2007, the Court reaffirmed that trial would start in January. The Debtors believe that this action represents a valuable asset of the estates and are eager to proceed to trial.
100279.1

Motion re Schedule Extension

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

vendors, dealers, and flooring lenders. In addition, the Debtors provide a basic one-year warranty covering defects in material or workmanship and a three-year warranty on certain structural components. As such, it is anticipated that there will be numerous potential claims against the Debtors based on these outstanding warranties. The master mailing matrix lists approximately 11,847 creditors and potential creditors. Sorting through the Debtors'

business records to identify the information necessary to accurately complete the Schedules for each of the Debtors will be a time-consuming process. Second, there is a limited number of qualified staff available to perform and oversee all of the Debtors' chapter 11 reporting obligations. In addition, the Debtors have extensive reporting obligations to the Office of the United States Trustee in the first weeks of these cases that will be substantial, complicated and time consuming, as well as numerous other pressing demands in connection with the orderly administration of these cases. Moreover, the Debtors and their professionals will also need time to evaluate the information comprising the Schedules once this information is compiled. In light of the foregoing, it is highly unlikely that the Debtors will be able to prepare and file their Schedules within the 15-day period otherwise provided by Bankruptcy Rule 1007(c). Moreover, absent an extension, the Debtors' management and professionals would be required to devote an inordinate amount of time and energy to compiling the Schedules, rather than addressing the numerous other legal and operational issues arising during the active, early stages of these cases. The same key persons that will be responsible for completing this task, also will need to dedicate their time and attention to handling their other responsibilities attendant to the chapter 11 cases. III. RELIEF REQUESTED Consequently, the Debtors request that this Court extend to January 14, 2008, the time within which they must file their Schedules. The proposed extended deadline represents an extension of the initial 15-day filing period established under Bankruptcy Rule 1007(c) by 30 days. The Debtors anticipate that they can file complete and accurate Schedules by then,
100279.1

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Motion re Schedule Extension

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KLEE, TUCHIN, BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CALIFORNIA 90067-6049 TELEPHONE: (310) 407-4000

although they reserve the right to request additional time if they subsequently discover that a further extension is warranted. No creditors' committee has yet been appointed in the Debtors' chapter 11 cases. This Motion is therefore being served upon, among others, the Office of the United States Trustee, the 20 largest unsecured creditors of the Debtors (to the extent known to the Debtors) and the Debtors' secured lender. The Debtors submit that this notice is appropriate under the circumstances and that no other notice need be provided. IV. ARGUMENT Bankruptcy Rule 1007(c) would ordinarily require that the Debtors file their Schedules within 15 days from the petition date. Bankruptcy Rule 1007(c), however,

provides that, for cause shown, the Court may extend the time for filing these Schedules. As set forth above, cause exists to grant an extension given the size and scope of the Debtors' operations. It will take several weeks for the Debtors to analyze and compile the information needed to complete their Schedules. Under the circumstances of these cases, the requested 30-day extension is reasonable and appropriate. V. CONCLUSION WHEREFORE, the Debtors respectfully request that the Court grant this Motion under Bankruptcy Rule 1007(c) and enter an order extending for approximately 30 days the time within which the Debtors must file their respective Schedules to January 14, 2008. DATED: December 10, 2007 /s/ David M. Guess DAVID M. GUESS, an Attorney with KLEE, TUCHIN, BOGDANOFF & STERN LLP Proposed Bankruptcy Counsel for Debtors and Debtors in Possession

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100279.1

Motion re Schedule Extension