|company going to distribute $2.75/share on winning!|
| Reply to Titanium - Msg #2333894 - 11/27/2012 09:54|
DEBTORS’ UNOPPOSED MOTION TO EXTEND DEADLINE
TO FILE RESPONSE TO FDIC MOTION
UNITED WESTERN BANCORP, INC. (“UWBK”); MATRIX BANCORP TRADING,
INC. (“MBT”); and MATRIX FUNDING CORP. (“MF”), Debtors-in-Possession herein (together,
the “Debtors”), by and through their counsel, Sender Wasserman Wadsworth, P.C., respectfully
submit their Unopposed Motion to Extend Deadline to File a Response to FDIC Motion. In support
thereof, the Debtors state as follows:
1. The Federal Deposit Insurance Corporation, as Receiver for United Western Bank
(“FDIC-Receiver”), filed its to Motion of the Federal Deposit Insurance Corporation as Receiver for
an Order Pursuant to §§ 105 and 363 of the Bankruptcy Code Regarding Establishment of a
Segregated Joint Account (“Motion”) on November 14, 2012. Therein, the FDIC-Receiver seeks
authority to establish a segregated account to hold tax refunds which, according to the FDICReceiver,
are property of the FDIC-Receiver and which, according to Debtor UWBK, are property
of its bankruptcy estate.
2. The deadline for filing an objection to the Motion is November 27, 2012.
3. Since the filing of the Motion, Debtors’ counsel and counsel for the FDIC-Receiver
have been actively engaged in discussions about how to resolve the matter.
4. Debtors believe the parties will be able to settle the matter without seeking a
determination from the Court; however, the parties need additional time to discuss and agree upon
the terms of a stipulation.
5. The FDIC-Receiver does not oppose a one-week extension of the objection deadline
for this purpose.
WHEREFORE, the Debtors respectfully move the Court for a one-week extension of
deadline for objecting to the Motion to December 4, 2012, and for such other and further relief as the
Court deems proper.