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HEARING DATE: OCTOBER 25, 2011 HEARING TIME: 10:00 A.M. TARTER KRINSKY & DROGIN LLP Attorneys for The Christian Brothers Institute, et al. Debtors and Debtors-in-Possession 1350 Broadway, 11th Floor New York, New York 10018 (212) 216-8000 Scott S. Markowitz, Esq. Eric H. Horn, Esq. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------------- x In re: : : THE CHRISTIAN BROTHERS INSTITUTE, et al. : : Debtors. : ------------------------------------------------------------------- x

Chapter 11 Case No.: 11-22820 (RDD) (Jointly Administered)

NOTICE OF MOTION FOR ENTRY OF AN ORDER ESTABLISHING NOTICE PROCEDURES IN DEBTORS CHAPTER 11 CASES PLEASE TAKE NOTICE, that that the above-captioned debtors and debtors in possession (the Debtors), will move before the Honorable Robert D. Drain, United States Bankruptcy Judge, United States Bankruptcy Court, 300 Quarropas Street, White Plains, New York 10601, on October 25, 2011 at 10:00 a.m., for entry of an order, substantially in the form annexed hereto as Exhibit A, pursuant to 105 of the Bankruptcy Code and Federal Rules of Procedure 2002, 6006, 6007, and 9007 (the Bankruptcy Rules) establishing certain notice procedures which will govern certain aspects of these Chapter 11 cases. PLEASE TAKE FURTHER NOTICE, that objections, if any, to the Motion, must be made in writing, must conform to the requirements of the Bankruptcy Code and the Federal Rules of Bankruptcy Procedure, must set forth with reasonable specificity the basis thereof, and must be filed no later than 5:00 p.m. on October 18, 2011 as follows: (a) by registered users of

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the Courts electronic case filing system, electronically in accordance with General Order M399. A copy of such Response must be delivered to the Chambers of the Honorable Robert D. Drain, United States Bankruptcy Judge, 300 Quarropas Street, White Plains, New York 10601, and served upon and received by (i) Paul K. Schwartzberg, Esq., Staff Attorney to the United States Trustee, 33 Whitehall Street, 21st Floor, New York, New York 10004; (ii) Tarter Krinsky & Drogin LLP, attorneys for the Debtors, 1350 Broadway, 11th Floor, New York, New York 10018, Attn: Scott Markowitz, Esq.; and (iii) Pachulski Stang Ziehl & Jones LLP, counsel to the Official Creditors Committee, 780 Third Avenue, 36th Floor, New York, New York 10017, Attn: Ilan D, Scharf, Esq. Any response must set forth the grounds for and the facts supporting the response and must: (i) identify the response by the name of the responding party, (ii) indicate the hearing date on the upper right hand of the objection, and (iii) bear the caption and case number of this case. Dated: New York, New York September 28, 2011 TARTER KRINSKY & DROGIN LLP Attorneys for The Christian Brothers Institute, et al. By: /s/ Scott S. Markowitz Scott S. Markowitz Eric H. Horn 1350 Broadway, 11th Floor New York, New York 10018 (212) 216-8000

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EXHIBIT A

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------------- x In re: : : THE CHRISTIAN BROTHERS INSTITUTE, et al. : : Debtors. : ------------------------------------------------------------------- x

Chapter 11 Case No.: 11-22820 (RDD) (Jointly Administered)

ORDER GRANTING DEBTORS MOTION FOR ENTRY OF AN ORDER AUTHORIZING IMPLEMENTATION OF CERTAIN NOTICING PROCEDURES Upon consideration of the Motion1 dated September 28, 2011, of the above captioned debtors and debtors-in-possession (collectively, the Debtors) pursuant to 11 U.S.C. 105(a) and Bankruptcy Rules 1015(c), 2002(i), 2002(m), and 9007 for entry of an order authorizing the implementation of certain noticing procedures; and the Court having jurisdiction under 28 U.S.C. 1334 and 157, and the Motion being a core proceeding under 28 U.S.C. 157(b)(2); and it appearing that notice of the Motion was adequate and proper under the circumstances of these cases and that no further notice of the Motion is required; and it appearing that good and sufficient cause exists for granting the relief in the Motion; and after a hearing held on the Motion on October 25, 2011; and opposition, if any, to the Motion being overruled; and it appearing that the relief requested in the Motion is appropriate in the context of these cases and is in the best interest of the Debtors, their estates, creditors and other parties-in-interest; it is hereby ORDERED, that the Motion is granted as set forth herein; and it is further ORDERED, that the Procedures are hereby approved as follows: (a) Unless otherwise ordered by the Court, Bankruptcy Filings relating to the use, sale, lease or abandonment of property shall be served on each entity having a known ownership interest in the property or a known lien or encumbrance on the property.

Capitalized terms not otherwise defined herein shall have the meaning ascribed to such term in the Motion.

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(b)

Bankruptcy Filings relating to relief from the automatic stay under 362 of the Bankruptcy Code or other automatic stay matters shall be served, as applicable, on (i) each entity having a known ownership interest in or known lien or encumbrance on any affected property and (ii) the parties to any underlying lawsuit or administrative proceeding and their counsel of record. Bankruptcy Filings relating to approval of a proposed compromise or settlement shall be served on each entity that is a party to the compromise and settlement. Bankruptcy Filings relating to rights under 365 of the Bankruptcy Code shall be served on each party to the executory contract(s) or unexpired lease(s) sought to be affected. Bankruptcy Filings relating to applications for payment of compensation or reimbursement of expenses of professionals shall be served in accordance with the order establishing procedures for interim compensation and reimbursement of expenses for professionals entered by the Court. Notice of other matters for which the Bankruptcy Rules require notice to all parties in interest will be served on all creditors, unless otherwise ordered by the Court;

(c)

(d)

(e)

(f)

and it is further ORDERED, that, notwithstanding the Procedures, notice of all Bankruptcy Filings shall be served on counsel to the Committee, the Office of the United States Trustee for this District, and all parties who filed a notice of appearance in the Debtors cases pursuant to Bankruptcy Rule 2002; and it is further ORDERED, that notice as provided for herein shall be deemed good and sufficient notice and any requirement for other notice be and hereby is waived and dispensed with; and it is further ORDERED, that to the extent that any of the Procedures conflict with the provisions of the Bankruptcy Code, the Bankruptcy Rules or the Local Rules, the Procedures shall govern and supersede such provisions and rules; and it is further

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ORDERED, that this Court shall retain jurisdiction over all matters arising from or related to the interpretation and implementation of this Order. Dated: White Plains, New York October ___, 2011 HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE

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