IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 ) ) Case No.

12-10968 (BLS) FASTSHIP, INC., et al., ) (Jointly Administered) 1 ) Debtors. ) ) MOTION TO SHORTEN NOTICE FOR MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT FastShip, Inc. (FSI), FastShip Atlantic, Inc. (FSA) and Thornycroft, Giles & Co., Inc. (TGC, together with FSI and FSA, the Debtors and each individually, a Debtor), debtors and debtors in possession in the above-captioned chapter 11 cases, hereby move (this Motion), pursuant to Bankruptcy Rules 2002, 9006(c) and Local Rule 9006-1(e), for an order shortening the notice period with respect to hearing on the Debtors Motion for an Order Approving the Disclosure Statement (the Disclosure Statement Motion). In support of this Motion, the Debtors respectfully state as follows: RELIEF REQUESTED 1. On March 20, 2011 (the Petition Date), the Debtors filed voluntary

petitions for relief under chapter 11 of the Bankruptcy Code. The Court entered an order directing the joint administration of these cases for administrative purposes only. 2. As explained in the Declaration of Roland K. Bullard, II In Support of

Chapter 11 Petitions and Requests for First Day Relief (the Declaration) [Docket No. 9], the Debtors filed these chapter 11 cases in order to create a liquidating trust to pursue
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The Debtors, along with the last four digits of each Debtors tax identification number, are as follows: FastShip, Inc. (8309) (Case No. 12-10968 (BLS)), FastShip Atlantic, Inc. (0980) (Case No. 12-10970 (BLS)) and Thornycroft, Giles & Co., Inc. (1142) (Case No. 12-10971 (BLS)). The mailing address for the Debtors is 1608 Walnut Street, Suite 501, Philadelphia, PA 19103.

and monetize an IP Claim2 against the U.S. Government and to distribute the proceeds of such litigation to the Debtors creditors in an orderly fashion. 3. The Debtors counsel has previously represented to this Court that the

intention is to have a plan confirmed in this case and the IP Claim transferred to a liquidating trust by the end of June or early July, 2012, if at all possible. 4. Accordingly, the Debtors intend to have a Joint Liquidating Plan and

corresponding Disclosure Statement filed on or before May 4, 2012. The Debtors further intend to file the Disclosure Statement Motion on or before MMay 4, 2012 as well, seeking approval of the Disclosure Statement at the May Omnibus Hearing currently scheduled for May 31, 2012. RELIEF REQUESTED 5. The Debtors seek to shorten the notice period respecting the deadline for

filing objections to the Disclosure Statement Motion (the Notice Period) from 31 days (28 days required by Bankruptcy Rule 2002(b) plus 3 days for mail service pursuant to Bankruptcy Rule 9006(f)) to 26 days so that the hearing on the Disclosure Statement Motion may be held on May 31, 2012 at 11:00 a.m., the next omnibus hearing date scheduled in these cases. 6. The Debtors, through their Claims Agent, Omni Management Group,

intend to serve the form of Notice of the hearing on the Disclosure Statement Motion on all creditors in accordance with Bankruptcy Rule 2002 on or before May 4, 2012. 7. Thus, if such Notice sets a hearing for the Disclosure Statement Motion on

May 31, 2012, the shortened Notice Period for the hearing would be 27 days. The

IP Claim, as used herein, shall have the definition given to it in the Declaration.

Debtors also request that the objection deadline be set for May 28, at 4:00 p.m., providing all creditors and parties in interest 24 days from date of service to the objection deadline. 8. Bankruptcy Rule 9006(c)(1) provides, in relevant part, that when an act is

required or allowed to be done at or within a specified time by these rules or by a notice given thereunder or by order of court, the court for cause shown may in its discretion with or without motion or notice order the period reduced. Bankruptcy Rule 9006(c)(2) states that the Court may not reduce the time for taking certain action under other Bankruptcy Rules, none of which apply here. 9. Local Rule 9006-1(e) provides that the notice period may be shortened by

Order of the Court upon written motion specifying the exigencies supporting shortened notice. 10. In this case, the Debtors have no funds to finance an extended chapter 11

proceeding and any delay will cause the estate to incur additional administrative expenses with no source of additional post-petition financing. As such, the Debtors estates will benefit from an expeditious hearing on the Debtors' Disclosure Statement, so as to be able to schedule the confirmaiton hearing by the end of June or early July at the latest. 11. Moreover, creditors and parties in interest will not be prejudiced by the

requested reduction in the Notice Period because they would still be afforded approximately three and one-half weeks to consider the Disclosure Statement and related exhibits. Accordingly, the Debtors requests shortening of the Notice Period so that the Disclosure Statement Motion may be heard on May 31, 2012 at 11:00 a.m. and that the objection deadline be set for May 28, 2012 at 4:00 p.m. NOTICE

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Notice of this Motion has been given to: (a) the Office of the United States

Trustee; (b) each of the Debtors top twenty (20) unsecured creditors; (c) all parties requesting notices in this bankruptcy case; and (d) the Debtors DIP Lender. The Debtors respectfully submit that no further notice is required. WHEREFORE, the Debtors respectfully request entry of an order (a) shortening the Notice Period for the Hearing on the Disclosure Statement to 27 days; (b) shortening the the objection deadline for the Disclosure Statement Motion to 24 days; (c) setting May 28, 2012, at 4:00 p.m.as the deadline for filing and serving objections to the Disclosure Statement; and (d) scheduling a hearing on the Disclosure Statement Motion for May 31, 2012 at 11:00 a.m. Dated: April 23, 2012 BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP By: /s/ Raymond H. Lemisch Raymond H. Lemisch, Esquire (No. 4204) Jennifer E. Smith, Esquire (No. 5278) 222 Delaware Avenue, Suite 801 Wilmington, DE 19801 (302) 442-7010 (Telephone) (302) 442-7012 (Facsimile) rlemisch@beneschlaw.com jsmith@beneschlaw.com

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 ) ) Case No. 12-10968 (BLS) FASTSHIP, INC., et al., ) (Jointly Administered) 1 ) Debtors. ) Re: Docket No. _____ ) ORDER GRANTING DEBTORS MOTION TO SHORTEN NOTICE FOR MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT This matter has come before the Court on the Debtors Motion to Shorten Notice (the Motion to Shorten) for Motion for Order Approving Disclosure Statement (the Disclosure Statement Motion). For cause shown, the Court orders as follows: 1. 2. The Motion to Shorten is Granted. A hearing on the Disclosure Statement Motion will take place on May 31, 2012

at 11:00 a.m. at the United States Bankruptcy Court for the District of Delaware, 824 North Market Street, 6th Floor, Wilmington, Delaware 19801, Courtroom 1 before the Honorable Brennan L. Shannon. 3. Any objection to the Disclosure Statement shall be filed with the Court and served

upon Debtors counsel at Benesch, Friedlander, Coplan & Aronoff LLP, Attn: Raymond H. Lemisch, 222 Delaware Avenue, Suite 801, Wilmington, DE 19801 so as to be received before May 28, 2012 at 4:00 p.m. 4. The Debtors shall cause a copy of this Order to be served via first class mail on

(a) the Office of the United States Trustee; (b) each of the Debtors top twenty (20) unsecured

The Debtors, along with the last four digits of each Debtors tax identification number, are as follows: FastShip, Inc. (8309) (Case No. 12-10968 (BLS)), FastShip Atlantic, Inc. (0980) (Case No. 12-10970 (BLS)) and Thornycroft, Giles & Co., Inc. (1142) (Case No. 12-10971 (BLS)). The mailing address for the Debtors is 1608 Walnut Street, Suite 501, Philadelphia, PA 19103.

creditors; (c) all parties requesting notices in this bankruptcy case; and (d) the Debtors DIP Lender.

Dated: _________________ Wilmington, DE

_______________________________________ BRENDAN L. SHANNON UNITED STATES BANKRUPTCY JUDGE

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