In re: GEREN L. WILLIAMS Chapter 11, Debtor.

Case No. 10-29365-PM.United States Bankruptcy Court, D. Maryland, Greenbelt Division.
June 1, 2011

SEEN AND AGREED, W. CLARKSON MCDOW, JR., United States Trustee, Region 4, By Counsel, Lynn A. Kohen, Bar No. 10025, Trial Attorney, Greenbelt, MD.

GEREN WILLIAMS, By Counsel, Brett Weiss, Chung Press, LLC, Greenbelt, MD.

STIPULATION AND CONSENT ORDER RESOLVING UNITED STATES TRUSTEE’S MOTION TO CONVERT CASE, OR IN THE ALTERNATIVE, TO DISMISS CASE
PAUL MANNES, Bankruptcy Judge

WHEREAS, on April 28, 2010, the United States Trustee filed a Motion to Convert Case to Chapter 7 or, in the Alternative, to Dismiss Case (the “Motion”) because (1) the Debtor had failed to file monthly operating reports; (2) failed to file a disclosure statement and plan of reorganization and (3) the Debtor had failed to file pay its quarterly fees.

WHEREAS the Debtor filed all the missing monthly operating reports; thus, the Debtor is now current on his monthly operating reports.

WHEREAS the United States Trustee and the Debtor, by their signatures below, have agreed to resolve this matter on the following terms and conditions, it is hereby STIPULATED AND AGREED that:

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1. On or before June 1, 2011, the Debtor shall pay any unpaid quarterly fees

2. In the event that the Debtor shall not pay any and all unpaid quarterly fees by June 1, 2011, the United States Trustee may file an Affidavit of Default with the Court, and the case shall be converted to one under Chapter 7 of the Bankruptcy Code forthwith.

3. On or before June 30, 2011, the Debtor shall file a confirmable plan and adequate disclosure statement in this case pursuant to 11 U.S.C. §§ 1121 and 1125.

4. In the event the Debtor fails to file a confirmable plan and an adequate disclosure statement in this case by June 30, 2011, or by a date agreed upon by both parties, the United States Trustee may file an Affidavit of Default with the Court, and the case shall be converted to one under Chapter 7 of the Bankruptcy Code forthwith.

5. Beginning on June 20, 2011 and continuing on the 20th of each month thereafter, the Debtor shall timely file its monthly operating reports as required by the United States Trustee District of Maryland Chapter 11 Guidelines that were issued to the Debtor upon the filing of this proceeding.

6. In the event the Debtor fails to file its monthly operating reports as required under Paragraph 5 of this Stipulation and Consent Order, the United States Trustee may file an Affidavit of Default with the Court. If the United States Trustee files an Affidavit of Default, the Debtor will have ten (10) days from the date the Affidavit of Default is filed to respond. If no response is filed by the Debtor, then the case shall be converted to one under Chapter 7 of the Bankruptcy Code forthwith. If the Debtor files a timely response, the Court will determine whether the case can proceed in Chapter 11 or be converted to Chapter 7 or dismissed.

7. The Debtor shall make all required post-petition quarterly fee payments to the Office of the United States Trustee as required by the United States Trustee District of

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Maryland Chapter 11 Guidelines that were issued to the Debtor upon the filing of this proceeding.

8. In the event the Debtor fails to make all required post-petition quarterly fee payments to the Office of the United States Trustee as required under Paragraph 7 of this Stipulation and Consent Order, the United States Trustee may file an Affidavit of Default with the Court, and the case shall be converted to one under Chapter 7 of the Bankruptcy Code forthwith.

SO ORDERED.