In the approximately three months since the Petition Date,
the Debtors and their advisors have dedicated significant time and resources to, among other
things, (i) negotiate with the prepetition secured lenders regarding cash collateral issues, (ii)
beginning the process of analyzing hundreds of leases and executory contracts to identify those
that are beneficial to the Debtors’ estates and seeking to reject those that are not, (iii) negotiating
significant reductions in programming agreements resulting in hundreds of thousands of
immediate cost savings for the Debtors, (iv) finalizing and filing the Debtors’ schedules of assets
and liabilities, income and expenditures and executory contracts and unexpired leases and their
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statements of financial affairs, (v) addressing a multitude of creditor, supplier and customer
inquiries, (vi) developing bidding procedures and discussing and negotiating the same with the
prepetition secured creditors and the Committee, (vii) actively marketing the Debtors’ to raise
new capital or for a sale of substantially all of their assets pursuant to Section 363 of the
Bankruptcy Code and, in connection therewith, meeting with prospective bidders and responding
to a number due diligence requests, (viii) responding to a variety of due diligence requests from
the prepetition secured creditors and the Committee, (ix) drafting a detailed plan term sheet and
negotiating the same with creditor constituencies, (x) defending an appeal of the order
authorizing the retention of the Debtors’ counsel, and (xi) defending objections to the retention
of the Debtors’ financial advisors.
9. As a result of these extensive efforts of the Debtors and their advisors, tangible
progress has been made toward the Debtors’ goal of developing a competitive cost structure
while increasing revenues.
