Case No. 10-15831.United States Bankruptcy Court, D. Maryland.
July 25, 2011
John D. Burns, Esquire (#22777), The Burns LawFirm, LLC, Greenbelt, Maryland, Counsel for the Debtor.
Jack Strausman, Esquire, Renee Suglia, Esquire, PEPCO Holdings, Inc., Washington D.C., Counsel for PEPCO Holdings, Inc.
STIPULATION AND CONSENT ORDER EXTENDING TIME FOR OBJECTION OF PEPCO TO EXPEDITED MOTION TO (I) COMPEL DEBTOR TO IMPLEMENT AND ENFORCE RESOLUTION AND SPECIAL ASSESSMENT FOR PURPOSE OF BALANCED BUDGET; AND (II) MODIFY ADEQUATE ASSURANCE OF PAYMENT PURSUANT TO 11 U.S.C. § 366(c)(3)(A) AND FOR ASSIGNMENT OF COLLATERAL PURSUANT TO 11 U.S.C. § 364(c) AS TO PEPCO, WASHINGTON GAS AND WSSC (AND REQUEST FOR A HEARING)
THOMAS CATLIOTA, Bankruptcy Judge
WHEREAS, BEDFORDTOWN CONDOMINIUM (the “Debtor”), a Maryland condominium regime, (the “Debtor”), by undersigned counsel, John D. Burns, Esquire, and The Burns Law Firm, LLC, has file an Expedited Motion to (i) Compel Debtor to Implement and Enforce Special Resolution and Special Assessment For Purpose of Balanced Budget; and (II) Modify Adequate Assurance of Payment Pursuant to 11 U.S.C. § 366(c)(3)(A) and For Assignment of Collateral Pursuant to 11 U.S.C. § 364(c) As to PEPCO, Washington Gas and WSSC (and Request for Hearing) (the “Motion”); and
WHEREAS, due to delays beyond counsel’s control, the Debtor has not provided
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complete and accurate financial projections and a balance sheet that are necessary to provide PEPCO (and Washington Gas or WSSC) with adequate information as to the proposals which have been advanced and described in the Motion; and
NOW, therefore, the Debtor and PEPCO do hereby AGREE and STIPULATE THAT:
On or before August 5, 2011, any utility of record, including PEPCO, may file an objection to the Motion which constitutes an extension of the answer period to the Motion and the relief requested therein. This extension is agreed to due to the Debtor’s apparent inability to produce financial projections and a balance sheet that reflect the necessary information required to enable the utilities, including PEPCO, to make informed decisions as to the proposals outlined and detailed in the Motion, and as have been discussed otherwise between the parties.