UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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In re ELECTROGLAS, INC., Debtor.

Chapter 11 Case No. 09-

In re ELECTROGLAS INTERNATIONAL, INC., Debtor.

Chapter 11 Case No. 09-

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MOTION FOR JOINT ADMINISTRATION

The above-captioned debtors and debtors-in-possession (collectively, the "Debtors"), by and through their undersigned counsel, hereby, respectfully move the Bankruptcy Court (the "Motion") pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure (the "BankruptcY Rules") and Rule 1015-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the "Local Rules") for entry of an order, the proposed form of which is attached to this Motion as Exhibit A, authorizing the joint administration of the Debtors' separate chapter 11 cases for procedural purposes only. In support of this Motion, the Debtors respectfully represent as follows: Jurisdiction, Venue & Statutory Predicate 1. The Bankruptcy Court has jurisdiction over this matter pursuant to 28 U.S.C.

1334(b). Venue is proper pursuant to 28 U.S.C. 1408 and 1409. The matter is a core

proceeding within the meaning of28 U.S.C. 157(b)(2).

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2. 1015(b).

The statutory predicate for the relief requested in this Motion is Bankruptcy Rule

Background
3. On the date hereof (the "Petition Date"), the Debtors each filed a voluntary

petition for relief under Chapter 11 of the Bankruptcy Code. The Debtors continue to operate their businesses and manage their property as debtors-in-possession pursuant to sections 11 07(a) and 11 08 of the Bankruptcy Code. 4. No creditors' committee has yet been appointed in these cases. No trustee or

examiner has been appointed. 5. The Debtors supply semiconductor manufacturing test equipment and software to

the global semiconductor industry, and have been in the semiconductor equipment business for more than 40 years. The Debtors' installed customer base is one of the largest in the industry, as the Debtors have sold to date more than 16,500 units of one of their core products, the "wafer prober" (and its related operating system). The Debtors' other major source of revenue comes from their business of designing, manufacturing, selling and supporting motion control systems for advanced technologies. 6. A full description of the Debtors' business operations, corporate structures, capital

structures, and reasons for commencing these cases is set forth in full detail in the Affidavit of Thomas Brunton in Support of Chapter 11 Petitions and First Day Relief, which was filed contemporaneously herewith and which is respectfully incorporated in this Motion by reference. Additional facts in support of the specific relief sought in this Motion are set forth below.

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Relief Requested 7. The Debtors hereby request that the Bankruptcy Court enter an order,

substantially in the form attached to this Motion as Exhibit A, authorizing the joint administration of the Debtors' chapter 11 cases for procedural purposes only, pursuant to Bankruptcy Rule 10 15(b) and Local Rule 1015-1. Basis for Relief 8. Bankruptcy Rule 10 15(b) provides that, if two or more petitions are pending in

the same court by or against a debtor and an affiliate, "the court may order a joint administration of the estates." Fed. R. Bankr. P. 1015(b). The Debtors are "affiliates," as that term is defined in section 101(2) of the Bankruptcy Code. Therefore, joint administration of the Debtors' cases is appropriate under Bankruptcy Rule 1015(b). 9. Joint administration ofthe Debtors' estates will be less costly and burdensome

than the separate administration of the estates. The joint administration of the Debtors' chapter 11 cases will permit the Clerk of the Court to utilize a single general docket for these cases and combine notices to creditors of the Debtors' respective estates and other parties in interest. The Debtors anticipate that numerous notices, applications, motions, other pleadings and orders in these cases will affect both Debtors. Joint administration will protect the parties in interest by ensuring that parties affected by both or either one of the Debtors' respective chapter 11 cases will be apprised of the various matters before the Bankruptcy Court. 10. Joint administration of the Debtors' estates will avoid repetitive, duplicative and

potentially confusing filings by permitting all parties in interest to: (a) use a single caption on the pleadings and other documents that will be filed and served in the Debtors' chapter 11 cases; and (b) file documents in only one of the Debtors' chapter 11 cases rather than in two cases;

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provided, however, that all schedules of assets and liabilities, statements of financial affairs, and proofs of claims will be captioned and filed in the Debtors' respective, separate cases, as appropriate. Further, joint administration will simplify the administrative aspects of the chapter 11 cases for the Bankruptcy Court and the Clerk's office in a more cost-effective manner. Accordingly, joint administration of these chapter 11 cases is in the best interests of the Debtors, the Debtors' estates, their creditors and other parties in interest. 12. The rights of the respective creditors of the Debtors will not be prejudiced by joint

administration of these cases. The relief requested in this Motion is purely procedural and will not affect any party's substantive rights. 13. All parties' use of the consolidated caption, as set forth on Exhibit A of the Order,

will eliminate burdensome and confusing procedures and ensure uniformity of pleading identification. 14. Courts in comparable chapter 11 cases have granted the same or similar relief.

See, e.g., In re Foamex International, Inc., Case No. 09-10560 (Bankr. D. Del. Feb. 20, 2009); In re Norte! Networks, Inc., Case No. 09-10138 (Bankr. D. Del. Jan. 15, 2009); In re Broadstripe,
LLC, Case No. 09-10006 (Bankr. D. Del. Jan. 6, 2009).

Notice

15.

Notice ofthis Motion has been provided to: (a) the Office ofthe United States

Trustee for the District of Delaware; (b) the creditors holding the 20 largest unsecured claims against the Debtors, as identified in the Debtors' respective chapter 11 petitions; (c) Lovells, 590 Madison Avenue, New York, NY 10022 (Attn: Christopher R. Donoho III, Esq.), counsel to bondholder group for the 6.25% Convertible Senior Subordinated Secured Notes due 2027; and (d) the Internal Revenue Service. As this Motion is seeking first day relief, notice of this Motion

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and any related order will be served as required by Local Rule 9013-l(m). In light ofthe relief requested in this Motion, no other or further notice is necessary or required. 16. This Motion does not contain any novel issues of law requiring briefing.

Therefore, pursuant to Rule 7.1.2. of the Local Rules of Civil Practice of the United States District Court for the District of Delaware, as amended from time to time (the "Local District Court Rules"), as incorporated by reference into Local Rule 1001-1 (b), the Debtors respectfully request that the Bankruptcy Court set aside the briefing schedule set forth in Rule 7.1.2(a) of the Local District Court Rules.
No Prior Reguest

17.

No prior motion for the relief requested in this Motion has been made to this or

any other court.

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WHEREFORE, the Debtors respectfully request that the Bankruptcy Court: (a) enter an order substantially in the form annexed to this Motion as Exhibit A; and (b) grant such other and further relief in favor ofthe Debtors as the Bankruptcy Court may deem just and proper.

Dated: July 9, 2009 Wilmington, Delaware

Respectfully submitted,

Proposed Attorneys for the Debtors

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EXHIBIT A

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re ELECTROGLAS, INC., Debtor.

) ) ) ) )

Chapter 11 Case No. 09-__ (_)

In re ELECTROGLAS INTERNATIONAL, INC., Debtor.

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Chapter 11 Case No. 09-__ (_)

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ORDER GRANTING MOTION FOR JOINT ADMINISTRATION THIS MATTER having come before the Bankruptcy Court upon the motion (the "Motion") 1 of the Debtors for an order directing joint administration of related chapter 11 cases for procedural purposes only; and the Bankruptcy Court having found that: (a) it has jurisdiction over the matters raised in the Motion pursuant to 28 U.S.C. 157 and 1334(b); (b) this is a core proceeding pursuant to 28 U.S.C. 157(b)(2); (c) venue is lying properly with the Bankruptcy Court; (d) the relief requested in the Motion is in the best interests of the Debtors, their estates and their creditors; (e) proper and adequate notice ofthe Motion and the related hearing has been given and that no other or further notice is necessary or required; and (t) upon the record after due deliberation, good and sufficient cause exists for the granting of the relief as set forth in the Motion and this Order; it is hereby ORDERED, that the Motion is granted in its entirety; and it is further

Capitalized terms used but not defined in this Order shall have the meanings ascribed to them in the Motion.

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ORDERED, that all filings in these cases are authorized and required to bear a consolidated caption in the form set forth on Exhibit A of this Order and incorporated in this Order by reference, which caption is approved in all respects; and it is further ORDERED, that the Clerk of the Court shall maintain one file and docket for all of these jointly administered cases, which file and docket shall be the file and docket for Electroglas, Inc.; and it is further ORDERED, that, except as otherwise provided in this Order, all original pleadings shall be captioned as indicated in the form set forth on Exhibit A of this Order, all original docket entries shall be made in the case of Electroglas, Inc., Case No. 09-_ _ L_), and a docket entry shall be made in each of the other Debtors' chapter 11 cases substantially as follows: An order has been entered in this case consolidating this case with the case of Electroglas, Inc., Case No. 09L_) for procedural purposes only and providing for its joint administration in accordance with the terms thereof. and it is further ORDERED, that nothing contained in this Order shall be deemed or construed as directing or otherwise effecting a substantive consolidation of these chapter 11 cases; and it is further ORDERED, that the Debtors, their officers, employees and agents are authorized to take or refrain from taking such acts as are necessary and appropriate to implement and effectuate the relief granted in this Order without further order of the Bankruptcy Court; and it is further

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ORDERED, that the Bankruptcy Court shall retain exclusive jurisdiction to enforce the terms of this Order. Dated: July 2009

UNITED STATES BANKRUPTCY JUDGE

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EXHIBIT A

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(Proposed Form of Caption) UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re
ELECTROGLAS, INC., al.,
1

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Chapter 11 Case No. 09-__ (__) (Jointly Administered)

Debtors.

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The Debtors are Electroglas, Inc. (EIN 77-0336101) and Electroglas International, Inc. (EIN 77-0345011).

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