IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DIVISION In re: ROBERTS BROADCASTING

COMPANY, et al., Debtors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 11-50744 et seq Jointly Administered Under Chapter 11

MOTION FOR EXPEDITED HEARING ON THE EXPEDITED MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS SEEKING DERIVATIVE STANDING TO COMMENCE AND PROSECUTE CERTAIN CAUSES OF ACTION ON BEHALF OF THE DEBTORS BANKRUPTCY ESTATES Hearing Date: December 14, 2011 Hearing Time: 2:00 p.m. Hearing Location: Courtroom No. 5 (North) Thomas F. Eagleton U.S. Courthouse 111 S. 10th Street, 4th Floor St. Louis, Mo. 63102

COMES NOW The Official Committee of Unsecured Creditors (the Committee) of the Chapter 11 bankruptcy estates of Roberts Broadcasting Company of Jackson, MS, LLC, Roberts Broadcasting Company of Columbia, SC, LLC, and Roberts Broadcasting Company of Evansville, IN, LLC (collectively, the Debtors) and files this Motion for Expedite Hearing
pursuant to E.D. Mo. L.B.R. 9013-2 seeking an expedited hearing on the Expedited Motion of the Official Committee of Unsecured Creditors Seeking Derivative Sanding to Commence and Prosecute Certain Causes of Action on Behalf of The Debtors Bankruptcy Estates (Docket No.

50)(the Derivative Standing Motion) filed by the Committee on December 9, 2011

In

support hereof, the Committee states the following: 1. As more fully set forth in the Derivative Standing Motion, the Committee

believes that it is imperative that it obtain derivative standing as soon as possible to pursue the avoidance and recovery of certain insider transfers. Specifically, because the foregoing insiders are currently experiencing severe financial difficulties and are being aggressively pursued by their own creditors, the Committee fears that if it cannot proceed immediately in pursuing recovery from these parties, the Debtors bankruptcy estates will lose the race to the courthouse against these parties and may forfeit their ability to realize any recovery with respect to these transfers and claims. 2. The foregoing concern is compounded by the fact that if the Committees

Derivative Standing Motion cannot be heard on the Courts December 14, 2011 docket, the next available hearing date at which the Committees Derivative Standing Motion can be heard (according to the Courts Courtroom Deputy) will not be until the third week of January, 2012 (i.e., more than a month away). 3. Counsel for the Committee made an announcement on the record during a hearing

held in these cases on November 15, 2011 regarding the Committees intention to file a Derivative Standing Motion. 4. Moreover, in accordance with the Eighth Circuit Court of Appeals decision in In

re Racing Services, Inc., 540 F.3d 892 (8th Cir. 2008), counsel for the Committee sent written correspondence to Debtors counsel and counsel for the U.S. Trustees Office on November 21, 2011 further advising those parties of the Committees intention to seek derivative standing. 5. Based upon the foregoing, the Committee contends that the relevant parties had

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sufficient advance notice of the Committees intention to seek the relief requested in the Derivative Standing Motion and will not be prejudiced if the latter Motion is heard on an expedited basis. 6. For all of the foregoing reasons, the Committee maintains that there is good cause

to grant the relief requested herein.

WHEREFORE, the Committee respectfully requests the Court enter an Order granting this Motion for Expedite Hearing, and setting the Committees Derivative Standing Motion for expedited hearing at 2:00 p.m. on Wednesday, December 14, 2011 and granting such other and further relief as the Court deems just and appropriate.

THOMPSON COBURN LLP By /s/ David D. Farrell David D. Farrell, #39969MO dfarrell@thompsoncoburn.com Brian W. Hockett, #52984MO bhockett@thompsoncoburn.com One US Bank Plaza St. Louis, Missouri 63101 TELE: 314-552-6000/FAX 314-552-7000 Attorney for the Official Committee of Unsecured Creditors

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CERTIFICATE OF SERVICE The undersigned hereby certifies that a copy of the foregoing was duly served this 9th day of December, 2011 on all those parties receiving notice in these proceedings through the Courts ECF System.

/s/ David D. Farrell

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