IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 CRDENTIA CORP., CaseNo.

10-_ __ Debtor. Employer Tax I. D. No. 76-0585701 Inre: Chapter 11 ATS UNIVERSAL, LLC, Case No. 10-_ __ Debtor. Employer Tax I.D. No. 55-0863980 Inre: Chapter 11 BAKER ANDERSON CHRISTIE, INC., Case No. 10-_ __ Debtor. Employer Tax I. D. No. 94-3243631 In re: Chapter 11 CRDECORP., Case No. 10-_ __ Debtor. Employer Tax I.D. No. 20-1472509 Inre: Chapter 11 GHS ACQUISITION CORPORATION, Case No. 10-_ __ Debtor. Employer Tax I.D. No. 20-2639736

Inre: Chapter 11 HEALTH INDUSTRY PROFESSIONALS, LLC, Debtor. Employer Tax I.D. No. 38-3374246 In re: Chapter 11 HIP HOLDING, INC., Case No. 10-_ __ Debtor. Employer Tax I. D. No. 27-2093468 Inre: Chapter 11 MP HEALTH CORP, CaseNo. 10-_ __ Debtor. Employer Tax I.D. No. 26-1564403 Inre: Chapter 11 NEW AGE STAFFING, INC., Case No. 10-_ __ Debtor. Employer Tax I.D. No. 30-0201214 Inre: Chapter 11 NURSES NETWORK, INC, Case No. 10-- - Debtor. Employer Tax I.D. No. 94-3286291 CaseNo. 10-_ __

MOTION OF DEBTORS FOR JOINT ADMINISTRATION OF CHAPTER 11 CASES

Crdentia Corp. ("Crdentia Corp.") and its affiliated debtors, ATS Universal, LLC, Baker Anderson Christie, Inc., CRDE Corp., GHS Acquisition Corporation, Health Industry

Professionals, LLC, IDP Holding, Inc., MP Health Corp., New Age Staffing, Inc. and Nurses Network, Inc., (collectively with Crdentia Corp., the "Debtors" or "Crdentia"), file this Motion for Joint Administration of Chapter 11 Cases (the "Motion") pursuant to 11 U.S.C. 105(a), Rule 1015(b) of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules"), and Rule 1015-1 of the Local Rules of Banktuptcy Practice and Procedure for the United States Bankruptcy Comi for the District of Delaware (the "Local Rules") and respectfully represent as follows:
JURISDICTION AND VENUE
1.

The Comi has jurisdiction over this matter pursuant to 28 U.S.C. 157 and

1334. This is a core proceeding pursuant to 28 U.S.C. 157(b). Venue is proper pursuant to 28 U.S.C. 1408 and 1409.
BACKGROUND

2.

On this date (the "Petition Date"), each of the Debtors filed a voluntary petition

for relief under Chapter 11 of the Bankruptcy Code. The Debtors continue to manage and operate their business as debtors in possession pursuant to 1107 and 1108 of the Banktuptcy Code. 3.
An official committee of unsecured creditors has not been appointed in these

Chapter 11 cases. Further, no trustee or examiner has been requested or appointed in any of these Chapter 11 cases.

4.

The background facts for these cases are stated in the Declaration of Rebecca

Irish in Support of the Debtors' Chapter 11 Petitions and First Day Pleadings (the "Irish Declaration"), f:tled contemporaneously herewith and incorporated herein by reference.
RELIEF REQUESTED AND BASIS THEREFOR

5.

By this Motion, Crdentia requests the joint administration of their Chapter 11

cases for procedural purposes only. Section 105 provides in relevant part that, "the court may issue any order, process, or judgment that is necessary or appropriate to cany out the provisions of this title." 11 U.S.C. 105(a). Bankruptcy Rule 1015(b) provides in relevant part that: If a joint petition or two or more petitions are pending in the same cou1i by or against a debtor and an affiliate, the court may order a joint administration of the estates. 11 U.S.C. 105(b). 6. Code. The Debtors are "affiliates" as that term is defined in 101(2) of the Bankruptcy

The issues addressed in these bankmptcy cases will be related and overlapping.

Accordingly, this Court may grant the relief requested. 7. Further, Local Rule 1015-1 provides, in relevant part, as follows:

An order of joint administration may be entered upon the filing of a motion for joint administration . . . supported by an affidavit, declaration or verification, which establishes that the joint administration of two or more cases pending in this Comi under title 11 is wananted and will ease the administrative burden for the Court and the pmiies.

Del. Bankr. L.R. 10 15-1. 8. Pursuant to Local Rule 1015-1, the Debtors have filed the Irish Declaration,

which establishes that joint administration of the Debtors' respective estates is wmranted and will ease the administrative burden for this Comi and the pmiies.

9.

Joint administration of these cases will obviate the need for duplicative notices,

motions, applications, hearings, and orders, and will therefore save considerable time and expense for the Debtors and their estates.
10.

Joint administration will not g1ve nse to any conflict of interest among the

Debtors' estates. The rights of the Debtors' respective creditors will not be adversely affected by the proposed joint administration because the Debtors will continue as separate and distinct legal entities and will continue to maintain their books and records in the same manner as they were maintained prepetition. Moreover, each creditor may file its claim against a particular estate. The interests of all creditors will be enhanced by the reduction in costs resulting from joint administration. The Comt also will be relieved of the burden of scheduling duplicative hearings, entering duplicative orders and maintaining redundant dockets. Finally, supervision of the

administrative aspects of these Chapter II cases by the Office of the United States Trustee will be simplified. II. Joint administration of the above-captioned cases is in the Debtors' best interests,

as well as those of their respective estates, creditors, and other parties in interest.
12.

Moreover, because this Motion requests only the administrative consolidation,

and not substantive consolidation of these estates, joint administration will not adversely affect creditors' rights. 13. purposes only: (a) (b) one disclosure statement and plan of reorganization may be (but is not required to be) filed for each of the Debtors' cases by any plan proponent; hearings in these jointly administered cases shall be joint hearings unless otherwise specified; The Debtors propose that the following activities be joined for administrative

(c)

one consolidated docket, one creditor matrix, and one Master Service List shall be maintained by the Debtors and kept by the Clerk, with separate claims registers for each of the Debtors' cases; and in the event these cases are assigned to separate judges, all cases should be transfe1red to the judge who has the lowest-numbered case.

(d)

14.

The Debtors further request that the Comt modify the caption of the cases to

reflect the joint administration as follows:

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re CRDENTIA CORP, et al./

Chapter 11 Case No. 10-- - - (Joint Administration Requested) Debtors.

The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509), GHS Acquisition Corporation (9736), Health Industry Professionals, LLC (4246), HIP Holding, Inc. (3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The Debtors' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park, Florida 32792.

15.

The Debtors also seek the Cmnt's direction that a notation to reflect the joint

administration of these cases, substantially similar to the following, be entered in the docket of each of the Debtors' chapter 11 cases: An order has been entered in this case directing the procedural consolidation and joint administration of the chapter 11 cases of Crdentia Corp., ATS Universal, CRDE Corp., GHS Acquisition LLC, Baker Anderson C1nistie, Inc., Corporation, Health Industry Professionals, LLC, HIP Holding, Inc., MP Health Corp., New Age Staffing, Inc., Nmses Network, Inc. The docket in Case No. 10- - U should be consulted for all matters affecting this case.
NOTICE

16.

No trustee, examiner or statutory creditors' committee has been appointed in these

chapter 11 cases. Notice of the Motion has been provided to: (a) the United States Trustee; (b) those pmties listed on the consolidated list of creditors holding the twenty (20) largest unsecured claims against the Debtors, as identified in their chapter 11 petitions; and (c) counsel for ComVest Capital, LLC, the Debtors' seemed lender. In light of the natme of the relief requested herein, the Debtors submit that no other or fmther notice is required.

NO PRIOR REQUESTS

17. corut.

No previous request for the relief sought herein has been made to this or any other

CONCLUSION

WHEREFORE, the Debtors respectfully request that the Corut (i) enter an order, substantially in the form attached hereto as Exhibit A, granting the Motion and directing the joint administration of their respective Chapter 11 cases, and (ii) grant such other and further relief as is just and proper.

March 17, 2010 Wihnington, Delaware

BAYARD,PA

Is/ Jamie L. Edmonson Jamie L. Edmonson (No. 4247) 222 Delaware Avenue, Suite 900 Wilmington, DE 19801 Phone: (302) 655-5000 Fax: (302) 658-6395
-andGERSTEN SAYAGE, LLP Paul Rachmuth 600 Lexington Avenue New York, New York 10022 Telephone: (212) 752-9700 Facsimile: (212) 980-5192
Proposed Counsel for the Debtors and Debtors in Possession

Exhibit A Proposed Order

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Inre: Chapter 11 CRDENTIA CORP , Case No. 10Debtor. Employer Tax I.D. No. 76-0585701 Inre: Chapter 11 ATS UNIVERSAL, LLC, CaseNo. Debtor. Employer Tax I. D. No. 55-0863980 In re: Chapter 11 BAKER ANDERSON CHRISTIE, INC., Case No. Debtor. Employer Tax I. D. No. 94-3243631 Inre: Chapter 11 CRDECORP, Case No. 10-~~Debtor. Employer Tax I.D. No. 20-1472509 In re: Chapter 11 GHS ACQUISITION CORPORATION, CaseNo. Debtor. Employer Tall: I. D. No. 20-2639736
10-~-~ 10-~-10-~~~
~~~

Inre: Chapter 11 HEALTH INDUSTRY PROFESSIONALS, LLC, Debtor. Employer Tax I. D. No. 38-3374246 Inre: Chapter 11 HIP HOLDING, INC., CaseNo. 10-~--Debtor. Employer Tax I.D. No.27-2093468 Inre: Chapter 11
MP HEALTH CORP.,

Case No. 10-~---

Case No. 10-~--Debtor. Employer Tax I. D. No. 26-1564403 Inre: Chapter 11 NEW AGE STAFFING, INC., CaseNo. 10-_ __ Debtor. Employer Tax I.D. No. 30-0201214 Inre: Chapter 11 NURSES NETWORK, INC., Case No. 10-_ __ Debtor. Employer Tax I. D. No. 94-3286291

ORDER PURSUANT TO 11 U.S.C. 105, FED. R. BANKR. P. 1015 AND LOCAL RULE 1015-1 (I) DIRECTING JOINT ADMINISTRATION OF THE DEBTORS' RELATED CHAPTER 11 CASES AND (ffi GRANTING RELATED RELIEF

Upon the motion (the "Motion") 1 of the above-captioned debtors and debtors in possession (collectively, the "Debtors") for entry of an order (this "Order"), pursuant to section 105 of the Bankmptcy Code, Bankruptcy Rule 1015 and Local Rule 1015-1, (i) directing the joint administration of the Debtors' related chapter 11 cases (the "Chapter 11 Cases") and (ii) granting related relief; and upon the Declaration of Rebecca Irish in Support of the Debtors' Chapter 11 Petitions and First Day Pleadings; and due and sufficient notice of the Motion having been given; and it appearing that no other or further notice need be provided; and upon the record herein; and it appearing that the relief requested by the Motion is in the best interest of the Debtors, their estates, their creditors and other pmties in interest; and after due deliberation and sufficient cause appearing therefor; IT IS HEREBY ORDERED THAT:
1.

The Motion is GRANTED. The Chapter 11 Cases are consolidated for procedural purposes only and

2.

shall be jointly administered by this Court under Case No. 10-_____ ( ). 3. follows:
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANI<.]

The consolidated caption of the jointly administered cases shall read as

Capitalized terms not defined herein have the meanings ascribed to them in the Motion.

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Inre CRDENTIA CORP., et al./ Debtors.

Chapter 11 CaseNo. 10-_ _ __ (Joint Administration Requested)

* * *
The Debtors, along with the last four digits of their federal tax identification numbers, are: Crdentia Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Cluistie, Inc. (3631), CRDE Corp. (2509), GHS Acquisition Corporation (9736), Health Industry Professionals, LLC (4246), HIP Holding, Inc. (3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The Debtors' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park, Florida 32792. 4. An entry shall be made on the docket of each of the Chapter 11 Cases,

other than the docket maintained for the Chapter 11 Case of Crdentia Corp., that is substantially similar to the following: An order has been entered in this case directing the procedural consolidation and joint administration of the chapter 11 cases of Crdentia Corp., ATS Universal, LLC, Baker Anderson Cluistie, Inc., CRDE Corp., GHS Acquisition Corporation, Health Industry Professionals, LLC, HIP Holding, Inc., MP Health Corp. and New Age Staffing, Inc., Nurses Network, Inc. The docket in Case No. 10(_) should be consulted for all matters affecting this case. 5. One consolidated docket, one file and one consolidated service list shall be

maintained for the Chapter 11 Cases by the Debtors and kept by the Clerk of the United States Bankruptcy Court for the District of Delaware. 6. Nothing contained in the Motion or this Order shall be deemed or

constmed as directing or otherwise affecting a substantive consolidation of the Chapter 11 Cases.

7. Order.
8.

The Debtors are authorized to take all actions necessary to implement this

This Court shall retain jurisdiction with respect to all matters arising fiom

or related to the interpretation or implementation of this Order. Dated: March_, 2010 Wilmington, Delaware
THE HONORABLE UNITED STATES BAN-:c:c:=KR=UP:=:T:=:C=Y::-::-::JU:c:D=-G=E=--