04-37512 (JS), Adv. Proc No. 06 02002.
April 11, 2007
Kevin G. Hroblak, Bar No. 26180, Whiteford, Taylor Preston L.L.P., Baltimore, Maryland.
Benjamin E. Goldman, Esquire, Squire Sanders Dempsey L.L.P., Los Angeles, California.
WHEREAS, on December 7, 2004 (the "Petition Date"). Air Cargo, Inc. (the "Debtor") filed with this Court a voluntary petition for relief under Chapter 11 of the Bankruptcy Code:
WHEREAS, on or about May 19, 2006. the Bankruptcy Court entered an order (the "Confirmation Order"), confirming the Debtor's Plan (the "Plan"), which became effective on June 14, 2006;
WHEREAS, pursuant to the Plan, the Litigation Trust (the "Trust") was established to, among other things, liquidate the remaining assets of the Debtor, prosecute causes of action, and resolve claims filed against the Debtor;
WHEREAS, Martin T. Fletcher is the trustee of the Trust (the "Trustee");
WHEREAS, the Trustee filed a Complaint for Damages and Turnover of Property of the Estate (the "Complaint") in this Court against the Defendants.
IT IS, THEREFORE, HEREBY STIPULATED AND AGREED BY AND BETWEEN THE PARTIES HERETO THAT:
1. The deadline for the Defendants to file an answer or otherwise respond to the Complaint in the above-captioned case is hereby extended to and including May 10, 2007; and
2. If the Defendants file a motion in response to the Complaint, the Defendants will provide the Trustee with thirty (30) days to file a response to any such motion and agree to execute a stipulation extending such response time; and
3. Singapore Airlines Cargo, PTE, LTD. has accepted proper service of the summons and Complaint and waives any defenses related to insufficiency of process.