IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF WISCONSIN In re: ) Case No. 11-20059-SVK ) ARCHDIOCESE OF MILWAUKEE, ) Chapter 11 ) Debtor. ) Hon. Susan V. Kelley ) MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR LIMITED RELIEF FROM THE AUTOMATIC STAY TO PERMIT TAKING OF CERTAIN DEPOSITIONS The Official Committee of Unsecured Creditors (the “Committee”) in the above- captioned case hereby moves (the “Motion”) pursuant to section 362 of title 11 of the United State Code (the “Bankruptcy Code”) and Rules 4001(a) and 9014 of the Federal Rules of Bankruptcy Procedure for the entry of an order modifying the automatic stay to allow parties in interest to take the depositions of elderly witnesses in state court litigation that is pending against the Archdiocese of Milwaukee (the “Debtor” or the “Archdiocese”), as previously ordered by the Wisconsin Circuit Court. In support of this Motion, the Committee respectfully states as follows: 1. The Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and 1334 and Rule 9024 of the Federal Rules of Bankruptcy Procedure. This matter is a core proceeding pursuant to 28 U.S.C. § 157(b). James I. Stang (CA Bar No. 94435) Kenneth H. Brown (CA Bar No. 100396) Pamela Egan Singer (CA Bar No. 224758) Pachulski Stang Ziehl & Jones LLP 10100 Santa Monica Blvd., 11th Floor Los Angeles, CA 90067 Telephone: (310) 277-6910 Facsimile: (310) 201-0760 E-mail:
[email protected] [email protected] [email protected] 05058-002\DOCS_SF:76905.1 Case 11-20059-svk Doc 240 Filed 05/20/11 Page 1 of 12 2.