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IN THE UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE

In re: ALLIED SYSTEMS HOLDINGS, INC. et al./ Debtors.

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Chapter 11 Case No. 12 -11564 (CSS) (Jointly Administered)


Ref. No. 579

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ALLIED SYSTEMS HOLDINGS, INC. Plaintiff,
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Adversary Proceeding No.: 12-50947 (CSS)

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AMERICAN MONEY MANAGEMENT CORP., et ) al, )


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Ref. No.16

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PETITIONING CREDITORS' MOTION PURSUANT TO DEL. BANKR. L.R. 9006-l(e) FOR AN ORDER SHORTENING TIME FOR NOTICE OF THE HEARING TO CONSIDER PETITIONING CREDITORS' MOTION TO EXCEED THE PAGE LIMITATION OF LOCAL RULE 7007-2 BDCM Opportunity Fund II, LP, Black Diamond CLO 2005-1 Ltd. and Spectrum Investment Partners, L.P. (collectively, the "Petitioning Creditors"), by their undersigned counsel, respectfully submit this motion (the "Motion to Shorten") for an order Shortening Notice on the Petitioning Creditors' Motion to Exceed the Page Limitation of Local Rule 7007-2

Defendants.

The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (900169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta. LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services. Inc. (382918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems. LLC (45-4241751); Logistic Technology, LLC (45-4242057): QAT, Inc. (592876863): RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (910847582).

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(the "Page Limitation Motion"). represent as follows:

In support hereof, the Petitioning Creditors respectfully

BACKGROUND
1.

By the Page Limitation Motion, 2 the Petitioning Creditors seek leave to file an

Omnibus Objection to the Debtors' Stay Extension Motion, Credit Bid Motion, and DIP Amendment Motion, and Cross-Motion for Abstention Pursuant to 28 U.S.C. 1334(c), which pleading will exceed the page limit in Local Rule 7007-2. 2. The deadline to object to the Debtors' Stay Extension Motion, Credit Bid Motion,

and DIP Amendment Motion (the "Debtors' Motions") is November 1, 2012. A hearing on the Debtors' Motions is scheduled for November 7, 2012, at 9:30A.M. (ET).
JURISDICTION

3.

This Court has jurisdiction to consider this matter pursuant to 28 U.S.C. 157

and 1334. This is a core proceeding under 28 U.S.C. 157(b) and venue is proper in this district pursuant to 28 U.S.C. 1408 and 1409. 4. The statutory predicates for the relief requested herein are section 105(a) of the

Bankruptcy Code and Rule 9006-1 (e) of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the "Local Rules").
RELIEF REQUESTED

5.

By this Motion to Shorten, the Petitioning Creditors seek authority pursuant to

Bankruptcy Code section 105(a) and Local Rule 9006-1(e) to shorten the notice required for a hearing on the Page Limitation Motion so that the Page Limitation Motion may be heard at the November 7, 2012 hearing, with objections to the relief sought in the Page Limitation Motion due at or before the hearing.
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Capitalized terms used but not defined herein have the meanings ascribed to them in the Page Limitation Motion.

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BASIS FOR RELIEF

6.

Pursuant to Local Rule 9006-1 (c)(i), notice of the Page Limitation Motion must

ordinarily be provided at least fourteen (14) days prior to the hearing date. 7. Because the relief requested in the Page Limitation Motion relates to the

Petitioning Creditors' objections to the Debtors Motions, which objections are due on or before November 1, 2012, and because the hearing on the Debtors' Motions will take place on November 7, 2012, the relief requested by the Page Limitation Motion will be mooted if the Page Limitation Motion is heard on regular notice under Local Rule 9006-1 (c)(i). 8. Local Rule 9006-1(e) grants this Court the authority to order that a motion be

heard on less notice than is required by the Bankruptcy Rules, and provides that the Court may rule on a motion for the same "promptly without need for a hearing." Additionally, Bankruptcy Code section 105(a) provides that the Court "may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title." Together, Local Rule 90061(e) and Bankruptcy Code section 105(a) provide ample authority for the Court to grant this Motion to Shorten. The exigencies in support such relief have been demonstrated herein.

Accordingly, the Petitioning Creditors respectfully request that the Motion to Shorten be granted at the Court's earliest convenience.

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WHEREFORE, the Petitioning Creditors respectfully request that this Court enter an order granting the relief requested herein and grant the Petitioning Creditors such other and further relief as is just and proper. Dated: November 1, 2012 Wilmington, Delaware

-andSCHULTE ROTH & ZABEL LLP Adam C. Harris Robert J. Ward 919 Third A venue New York, New York 10022 Telephone: (212) 756-2000 Facsimile: (212) 593-5955 Counsel to the Petitioning Creditors

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IN THE UNITED STATES BANKRUPTCY COURT DISTRICT OF DELAWARE


) ) )
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In re: ALLIED SYSTEMS HOLDINGS, INC. et al., 1 Debtors.

Chapter 11 Case No. 12 -11564 (CSS) (Jointly Administered)

_________________________________ )
ALLIED SYSTEMS HOLDINGS, INC. Plaintiff, v.
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Ref. No. _ __

Adversary Proceeding No.: 12-50947 (CSS)

AMERICAN MONEY MANAGEMENT CORP., et )

al,
Defendants.

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Ref. No. _ __

_________________________________ )
ORDER GRANTING PETITIONING CREDITORS' MOTION PURSUANT TO DEL. BANKR. L.R. 9006-l(e) FOR AN ORDER SHORTENING TIME FOR NOTICE OF THE HEARING TO CONSIDER PETITIONING CREDITORS' MOTION TO EXCEED THE PAGE LIMITATION OF LOCAL RULE 7007-2
Upon consideration of the Petitioning Creditors' Motion Pursuant to Del Bankr. L.R.

9006-1 (e) for an Order Shortening Time for Notice of the Hearing to Consider Petitioning Creditors' Motion to Exceed the Page Limitation of Local Rule 7007-2 (the "Motion to
Shorten"); 2 and it appearing that due and adequate notice of the Motion to Shorten has been

The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (900169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta. LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services. Inc. (382918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems. LLC (45-4241751); Logistic Technology, LLC (45-4242057): QAT, Inc. (592876863): RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (910847582). 2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion to Shorten.

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given under the circumstances, and that no other or further notice need be given; and after due deliberation and sufficient cause appearing therefor, it is hereby: ORDERED, that the Motion to Shorten is granted; and it is further ORDERED, that the Page Limitation Motion shall be heard on November 7,
2012 at 9:30 A.M. (ET); and it is further

ORDERED, that any objections to the relief requested in the Page Limitation Motion, if any, shall be filed and served and/or made at the hearing no later than November 7,
2012 at 9:30A.M. (ET); and it is further

ORDERED, that this Court shall retain jurisdiction over any and all matters arising from or related to the implementation or interpretation of this Order.

Dated: November_, 2012 Wilmington, Delaware The Honorable Christopher S. Sontchi United States Bankruptcy Judge

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