Case 17-10530-led Doc 15 Entered 02/08/17 18:06:42 Page 1 of 54 1 Matthew L. Johnson (6004) E-filed on February 8, 2017 Russell G. Gubler (10889) 2 JOHNSON & GUBLER, P.C. 3 Lakes Business Park 8831 West Sahara Avenue 4 Las Vegas, Nevada 89117 Phone: (702) 471-0065 5 Fax: (702) 471-0075 e-mail:
[email protected] 6 [Proposed] Attorneys for Debtor 7 UNITED STATES BANKRUPTCY COURT 8 DISTRICT OF NEVADA 9 In re: Case No: BK-S-17- 10 KHWY, INC., Chapter 11 11 Debtor. 12 Hearing Date: OST REQUEST PENDING 13 Hearing Time: OST REQUEST PENDING 14 15 MOTION TO SELL ASSETS FREE AND CLEAR OF LIENS AND ENCUMBRANCES PURSUANT TO 11 U.S.C. §363(f) 16 17 The Debtor, KHWY, INC., (“Debtor”), through its attorney, Matthew L. Johnson, Esq., of 18 the law firm of JOHNSON & GUBLER, P.C., respectfully moves this Court for an Order (1) 19 approving the sale of Radio Stations KHYZ, Channel 259B, Mountain Pass, CA (along with 20 Booster Station KHYZ-FM2, Las Vegas, NV), and KRXV, Channel 251B, Yermo, California, 21 and related assets to Educational Media Foundation (“EMF”) for $525,000, free and clear of all 22 liens pursuant to 11 U.S.C. §363(f), claims and encumbrances, with liens, claims and 23 encumbrances attaching to the sale proceeds, subject to higher and better bids, and certain other 24 conditions set forth in this motion, and (2) approving the sale of the Debtor’s remaining assets, 25 including all assets used by the Debtor to operate other radio stations located throughout the 26 Southwestern United States, free and clear of all liens, claims and encumbrances pursuant to 11 Case 17-10530-led Doc 15 Entered 02/08/17 18:06:42 Page 2 of 54 1 U.S.C.