American court hearing recordings and interviews - BlockFills crypto bankruptcy - first bankruptcy hearing in Delaware, March 17, 2026 (In re Reliz Technology Group Holdings)

Episode Date: March 18, 2026

The Chicago Tribune is covering the Delaware bankruptcy of BlockFills, which is described as a Chicago-based cryptocurrency trading firm. See, for example :Chicago-based crypto trading firm BlockFills files Chapter 11 bankruptcy; Blackhawks among the creditorsPushed over the edge by recent customer lawsuits and a “crypto winter” that saw Bitcoin valuation halved, Chicago-based cryptocurrency trading firm BlockFills filed for Chapter 11 bankruptcy protection Sunday in a Delaware court.BlockFills, which suspended customer withdrawals Feb. 6 amid liquidity issues, chose the path of voluntary reorganization after being unable to find a buyer or an investor to help recapitalize the cryptocurrency firm, which was more than $100 million in debt, according to the filing.The Chicago Blackhawks are listed in the filing among the largest unsecured creditors. The debt is from a corporate marketing sponsorship by BlockFills, according to the team....For more see:By Robert Channick | [e-mail] | Chicago TribunePUBLISHED: March 17, 2026 at 7:46 AM CDT | UPDATED: March 17, 2026 at 3:26 PM CDTCrypto trading firm BlockFills files Chapter 11 bankruptcy

Mr. Hurst, great to see you. Good to see you as well, Your Honor. Thank you. For the record, David Hurst from McDermott-Will & Schulte, on behalf of the debtors and debtors in possession in these cases. Your Honor, thank you very much for accommodating us and giving us this first day here in this afternoon. Very much appreciate that.

With me today on Zoom, I'll start, is Mr. Mark Remzi. He's the Vettors' Chief Restructuring Officer, also our first day declarant and our cash collateral declaring. And thank you very much for letting him appear remotely. Oh, certainly. In the courtroom with me are my colleagues, Darren Asman, Andrew Mark, welcome, Ethan Dover. And then on Zoom, I have some other colleagues,

including the head of our litigation team here in this case, Mr. Joe Evans. Earlier this morning, Your Honor, I, well, it's afternoon now, but late this morning, I sent over to chambers six red lines, representing the orders that we have negotiated with the U.S. trustee and reached resolution. I wanted to thank Mr. Hackman for his work over a very short period of time, working with us to refine those orders and get them in shape. We had total eight-day first-day motions, so we had six resolve. The two that we didn't send over were the Matrix, Matrix Order and the Cash Collateral Order.

The good news, Your Honor, is that we have reached resolution on cash collateral. We had already incorporated the U.S. trustees' comments in the filed version of that motion. It was the last one filed. It said by the time we got it on file, we had time to get it fixed up. But we've been working with our secured lender to try to reach resolution, and shortly before the hearing, we did. My colleague, Andrew Mark, will be making that presentation, and he'll be discussing the resolution with you. The only matter which we did not reach resolution with the U.S. trustee is on the Matrix, often a tough one to get a resolution on.

We think we've narrowed the issues a little bit. We've been able to accept some of the trustees' comments, but there are some outstanding issues. And again, my colleague, Andrew and Mark, will be discussing that in due course when he gets to that in his presentation. And that's where we stand right now, Your Honor. Unless you have any questions for me, I'd like to turn the podium over to Mr. Asman, who will take you through an overview of the case, and then we'll move into the first-day paper. That sounds great. All right. Thank you, Mr. Hurts.

Thank you, Your Honor. Mr. Asman, good afternoon. Hi, good afternoon, Your Honor. Thank you, Darren Asman from McDermagall and Schulte, proposed counsel to the debtors. Your Honor, in addition to all the individuals that Mr. Hearst named, we also have certain members of the debtors senior management team with us today. And then additionally, before the filing, the Board formed a special committee and appointed independent director, Matthew Khan, of the committee. Mr. Khan is tasked with the authority to handle all conflict matters, and he is represented by Cole Schatz. That's being led by Justin Alberto and Seth An Alton, and you can see Mr. Alberto standing up over there in his Easter suit over there.

Your Honor, at the outset, I'd like to move Mr. Renzi's declaration and evidence, as it provides the evidentiary basis for the motions that are up for today's hearing, as well as provide some background for the debtors. Again, thank you for allowing Mr. Renzi to appear by video. He greatly appreciates that and we do as well. He's on the line, as you can see, is available to testify and for cross if it's necessary. And so I'd like to move that declaration and evidence. Okay. Does anybody object to the addition of Mr. Renzi's declaration purely for the purposes of today's hearing? Okay, I hear no response.

It is admitted. Will anybody wish to cross-examine Mr. Renzi today? Okay, I hear no response. I do have one question about Mr. Renzi's declaration. He's identified throughout as the chief restructuring officer, but his signature block says that he is the chief transformation officer. What is his current title? I believe it's chief restructuring officer, Mr. Renzi. Could you confirm that?

It may have been a typo, or maybe there was a prior role that you had as Chief Transformation Officer? Good afternoon, Your Honor, Mark Renzi. I think the titles are used synonymously for this case. Either one is sufficient. Okay, I'll take a pick. We're going to go with CRO. Okay. That's okay with your honor.

Yeah, that's fine. Okay. Thank you. I appreciate that. All right, sorry about that. Your Honor, just for clarity, the reason being is that there was a title at the company for chief risk officer. And at that point in time, we're just trying to make it a little easier. So we, chief transformation officers sometimes use.

So I'm fine. fine with CRO. I just wanted to give you a little bit more color. Thank you so much, Mr. Renzi. I appreciate that. Yeah. And the last comment I'll say is that I appreciate being remote. I was teaching at Boston College Law this morning for some fine young new candidates for the legal field. So really appreciate it. And it meant a lot to me to be able to participate in that. Well, I'm glad you here. I'm glad you had a chance. Teaching is wonderful. Well, soon, you're the best. Yeah. Well, I'm glad you here. Thank you.

All right. So, Your Honor, I thought it would be helpful to begin with some background on the company, how we got here, and where we hope to go in these cases. So, Your Honor, Blockfield is a cryptocurrency brokerage and trading platform. It was founded in 2017. It was created to serve institutional, high net worth, and professional traders, as opposed to retail customers, which a lot of the other competitors, some of which have ended up in bankruptcy, cater to.

And the company provided services such as crypto spot trading, derivatives trading, collateralized lending, and a limited amount of mining, crypto mining related activities. The business grew rapidly during the expansion of the digital asset industry. And by 2018, Blockfields had developed a reputation in the industry as a reliable counterparty for institutional crypto market participants. That includes hedge funds, brokers, exchanges, miners, and investment managers. The company operated around the clock

and aggregated liquidity from multiple exchanges and market makers to offer competitive pricing and execution. There are several interrelated factors that ultimately undermine Blockfield's liquidity and their balance sheet and really why we're here today and I want to walk through those one by one.

First, beginning in 2022, the broader crypto market experienced severe disruption, including the collapse of major industry participants and counterparty bankruptcies. Blockfields in particular was exposed to losses from failed lending counterparties who defaulted on crypto loans and left Blockfields unable to recover assets that were worth millions of dollars. Second, Blockfield suffered significant losses from a mining hardware investment that they made due to declining mining profitability and delays at third-party data sites, the mining equipment couldn't be deployed as planned, which tied up capital and really prevented Blockfields

from recouping on its investment in the mining space. Third, Blockfields became embroiled in a major dispute with Celsius Network, which, as I'm sure Your Honor knows, went through its own bankruptcy, and this dispute arose from a 2019 digital asset lending transactions, so pre-Celsius bankruptcy. As a result of that dispute, the parties participated in an arbitration in the United Kingdom, and the UK arbitrator entered an award in favor of Celsius against the company. After that arbitration concluded, and after unsuccessful appeals were pursued by the company, in July 2024, Celsius and block fills entered into two secure notes with Celsius that totaled around $16 million in principle and had a 12% interest rate.

The parties ultimately agreed that block fills would make a lump sum payment at the outset of that agreement, and then the company would pay off the notes over time through monthly payments. And those monthly payments were made through August 2025, but no additional payments have been made since that point. As we sit here today, the principal amount outstanding on the notes is approximately $4.8 million, but we understand that Celsius is asserting default interest at the rate of 37%. If we apply that interest rate, again, that's what they're alleging. Then the amount outstanding on the notes is somewhere around $5.5 million and continuing to accrue. Your Honor, the fourth reason why we're here is that despite strong operating performance in 2024,

as well as attempts to raise new capital or pursue a sale or recapitalization in 2025. Blockfields was just unable to secure sufficient financing. Matters deteriorated even further after a major crypto market crash in February 26, so just last month, which triggered a number of heavy withdrawal requests. This episode is brought to you by Spreker. The platform responsible for a rapidly spreading condition known as podcast brain. Symptoms include buying microphones you don't need, explaining RSS feeds to confused relatives, and saying things like, sorry, I can't talk right now, I'm editing audio.

If this sounds familiar, you're probably already a podcaster. The good news is Spreaker makes the whole process simple. You record your show, upload it once, and Spreaker distributes it everywhere people listen. Apple Podcasts, Spotify, and about a dozen apps your cousin's swears are the next big thing. Even better, Spreaker helps you monetize your show with ads, meaning your problem. podcast might someday pay for, well, more microphones. Start your show today at spreeker.com. Sprinker, because if you're going to talk to yourself for an hour, you might as well publish it. ...from customers. Ultimately, Blockfields suspended all customer deposits and withdrawals,

and those actions all but derailed any potential recapitalization transaction that the company was otherwise pursuing. Finally, Your Honor, in the weeks before the filing, a customer, Fultimate lawsuits alleging misappropriation of assets and seeking injunctive relief. Courts entered temporary restraining orders that could have restricted block-fills operations and their control over certain assets, which really created acute liquidity and operational stress on the company. And at the same time, the debtors had all but exhausted viable out-of-court alternatives, including capital raises, recapitalization efforts, and a potential sale transaction, none of which could really be consummate. due to the market conditions and the liquidity constraints as well as the outstanding lawsuits.

So in light of mounting litigation, which we expected more of, fragmented creditor enforcement risk, different parties going to different courts, and really the absence of a feasible standalone solution, the poor determined that Chapter 11 was really the only path and it was necessary to stabilize operations, invoke the automatic stay, centralized claims in a single forum, and really to pursue an orderly value-mact restructuring for the benefit of all customers as well as other creditors of the estate. So I want to talk about the plan for what we hope to accomplish in this case. We really filed a Chapter 11 here to pursue a customer-led restructuring rather than a liquidation, which is the fate that the majority of crypto companies ended up in Chapter 11.

As set forth in Mr. Renzi's declaration, Blockfills has negotiated a non-binding term sheet. It's not executed. It's a framework with an ad hoc group of the company's largest customers. And that essentially, again, provides the framework for a transaction that we believe will maximize value for all creditors. Under the proposed structure, block fills would reorganize into a newly formed entity, NUCO, while assets that are not transferred to NUCO, which presumably would include litigation assets and other things that NUCO does not need, would be placed into a post-confirmation trust for the benefit of customers. Customers would receive recoveries consisting of a combination of, first, a pro-rata portion of the liquidating trust interests.

And then two, the more unique aspect is a pro-rata share of the liquid assets available in the company at the end of the case, which creditors and customers, excuse me, customers could elect to receive in either cash or digital assets, or convert into equity of NUCO at their election, and they can also do a mix of the two. The term sheet also contemplates a convenience class for smaller customer claims. Those creditors would receive a payment in full up to a capped aggregate amount,

thereby reducing administrative burdens on the estate. In terms of vendors, any vendors who are deemed essential to the go-forward business of NUCO, they may receive distributions that are tied to the liquid, asset component that I mentioned, while other trade claims, meaning non-go-forward trade claims, would be addressed through the post-confirmation trust.

The term sheet also provides for new money investments to be made. So essentially, customers would be allowed to invest cash as additional capital into NUCO at different defined valuation thresholds, subject to accredited investor requirements, as well as ownership caps. And this whole structure is really intended to preserve the core business, again, maximize recoveries for customers and creditors, and avoid what would have otherwise been value-destructive, piece-no-litigation in different jurisdictions. Your Honor, that's everything I have for you right now.

I'm happy to answer any questions if you have them. If not, I'll briefly turn over the podium to Ms. Van Lear from Cleary Gottlieb. Cleary is representing the ad hoc group. I know she wants to make some brief remarks, and then we can move into first days, but I'm happy to answer any questions if you have them. Yeah, like the first day declaration and your presentation were very thorough, very helpful to me, so I don't have any questions

at this point. Okay, thank you, Your Honor. Thank you, Mr. Asman. Ms. Van Laird. Good afternoon. Good afternoon. Jane Van Lair, Cleary Gottliebstein and Hamilton, on behalf of the ad hoc group of Blockfield's clients. Your Honor, we represent roughly 75 million of exposure of the customers, and our group is growing.

The overwhelming majority of the liabilities of this company are to the customers. So I think that really the key constituency in this case are the customers. Your Honor, our clients are both individuals and businesses, and I cannot understate the devastating impact that this bankruptcy has had on them. They put their trust into the Block sales platform, and the impact has been profound. The customers have worked to put together a customer-led solution that's bodied in the term sheet that was just described and attached to Mr. Renzi's declaration. It's a roadmap to a customer-led resolution, and we think there are two goals of this term sheet. One is to maximize value for customers, and two is to enable the customer-based.

the business to continue so that it may continue generating value. We believe that the framework does represent a viable path. There are some issues that are still unresolved, but we think that we can resolve them and look forward to working constructively to do that. What is critical from our perspective, Your Honor, is time. Each day that passes in these proceedings is – represents a significant burden on recoveries for our clients, for the customers. Given that these are the folks that have been severely impacted, as I described, it's really

critical from our perspective that the case proceeds as expeditiously and efficiently as possible. So with that, Your Honor, we thank you for your time, and we look forward to, again, working with you, working with other stakeholders in efficiently, leading this case to a resolution. Thank you, Ms. Van Lee. Mr. Asman. Your Honor, consistent with your chambers procedures that encourages younger attorneys to present first-day motions, we are going to have two of our colleagues, Ethan Dover, and Andrew Mark present all of the first-day motions. Great. And so I'll turn things over to Mr. Dover. Okay. Thank you. Thank you.

Mr. Dover, good afternoon. Good afternoon, Your Honor. For the record, Ethan Dover of McDermott, Will and Schulte proposed counsel to the debtors. Your Honor, the next item, today's agenda is agenda item number three. The debtor's motion for entry of an order directing joint administration of these Chapter 11 cases filed at docket number 8. This is a procedural motion for administrative efficiency, and we are asking that the cases be administered under the caption, Release Technology Group Holdings Inc. case number 26-103-71. The U.S. Trustees Office had a few comments to the order, which we have incorporated. It's my understanding that you have the latest version of that order, but I do have a red line prepared for you if you would like to see changes that were incorporated.

And unless Your Honor has any questions, we respectfully request that this motion be granted. Okay. Does anybody wish to be heard regarding the Joint Administration motion? Okay. I hear no response. This is a typical relief, of course, in multi-debtor cases. and I have authority to grant this relief under Bankruptcy Rule 1015, and Local Rule 1015-1, and I can do it without noticing any hearing where there is an evidentiary basis, such as the declaration of Mr. Renzi that I do rely on in support of the relief being sought in this and some of the other motions today, so I'm happy to grant the motion.

Thank you, Your Honor. The next motion is the insurance motion. This is item number four on the agenda and was filed at docket number nine. Under the insurance motion, the debtors are seeking authority to maintain, extend, renew, replace, supplement, or modify their existing insurance policies, and pay all insurance obligations arising under such policies. Your Honor, the debtors do not maintain any surety bond program, nor do they have any insurance premium financing. The debtors only have three insurance policies. two D&O policies and one property and casualty policy. The list of insurance policies, policy numbers, the term of each policy, and the premiums associated with each policy are attached to the motion as exhibit C.

This episode is brought to you by Spreeker, the platform responsible for a rapidly spreading condition known as podcast brain. Symptoms include buying microphones you don't need, explaining RSS feeds to confused relatives, and saying things like, sorry, I can't talk right now. now I'm editing audio. If this sounds familiar, you're probably already a podcaster. The good news is Spreaker makes the whole process simple. You record your show, upload it once, and Spreaker distributes it everywhere people listen. Apple Podcasts, Spotify, and about a dozen apps your cousin swears are the next big thing. Even better, Spreaker helps you monetize your show with ads, meaning your podcast might someday pay for, well, more microphones.

Start your show today at spreeker.com. Sprinker, because if you're going to talk to yourself for an hour, you might as well publish it. After discussing with the company and its advisors, we believe there are no outstanding pre-petition amounts owed on account of the insurance policies. The insurance policies are paid via annual premiums, not monthly. And on account of that, the insurance, excuse me, on account of that, we have requested authority to pay up to $200,000 with respect to any amounts that become due in the ordinary course of business, because any amount of the amount of money.

do would be on account of the entire year. Again, we have received helpful comments from Mr. Hackman, which are reflected in the current draft of the interim order. If you would like to see a red line, I have these comments available for you. And otherwise, unless your Honor has any questions, we request that the motion be granted. Okay. Does anybody wish to be heard regarding the insurance motion?

Okay, I hear no response. I've reviewed the changes to the insurance motion. I understand them. Again, this is relief that's required under Section 1112. of the code and also the UST's operating guidelines. I find based on the evidence before me that immediate and irreparable harm would come to the debtor if I did not grant this relief. So I'm happy to grant the motion on an interim basis.

Thank you very much, Your Honor. That brings us to agenda item number five, the debtor's cash management motion, which was filed at docket number 10. The debtor's cash management motion seeks to authorize the debtors to continue. to operate their existing cash management system, maintain existing bank accounts and business forms, as well as honor certain pre-petition obligations related to such maintenance, continue to perform intercompany transactions and grant administrative expense status for post-petition intercompany claims, and to the extent necessary, extend the time for the debtors

to comply with requirements set forth in bankruptcy code Section 345B. Now that's a lot of relief, so I'll just walk you through it one by one here. The debtor's cash management system is comprised of 12 functioning bank accounts held across three debtor entities. Those entities are Release Technology Group Holdings Inc., release technology LLC, and release limited. The debtors also still maintain eight dormant bank accounts, which are empty, no longer in use, and will soon be closed by the debtors. The 12 functioning bank accounts can be categorized into four account types. operating accounts, client accounts, a payroll account, and a wire account. A schematic illustrating how these accounts interact is attached to the motion as Exhibit C,

and a schedule of the bank accounts, including the debtor entity at which each account sits, the name of the financial institution at which the account is held, the type of the account, the last four digits of the account numbers, and the balance of each account, as of the petition date in U.S. dollars, is attached to the motion as exhibit D. In the ordinary course of business, the debtors pay service charges associated with maintaining these bank accounts and their cash management system,

including bank fees, processing charges, and other payment obligations arising under agreements governing the bank accounts. Historically, the debtors have incurred approximately $20,000 in bank fees each month under the cash management system. The debtors do not believe they owe any pre-petition amount, on account of the bank fees, but out of abundance of caution, the debtors request authority both to pay all pre-petition bank fees to the extent there are any outstanding and to continue to pay the bank fees and related claims in the ordinary course of business post-petition.

Your Honor, the debtors are also seeking authority to continue using their existing business forms as opposed to being required to incur the expense and delay of ordering new business forms or modifying their existing business forms. For the avoidance of doubt, Your Honor, we have included language in the interim order at the request of the U.S. trustee that requires the debtors to the extent they order or create any new checks to include the designation debtors in possession as well as the jointly administered bankruptcy case number on such checks. Your Honor, we are also seeking authorization for the debtors to continue their intercompany transactions. The debtors engage in intercompany

transactions in the ordinary course of business, primarily for operational reasons. Specifically, debtor release limited receives cash and uses cash to pay certain expenses of the other debtor entities. The intercompany transfers occur regularly on an as-needed basis and are necessary to fund the debtor's expenses, including funding payroll for the debtor's employees. The debtors actively track, monitor, and record all fund transfers in their account. and cash management system, and can ascertain, trace, and account for all intercompany transactions. The debtors expect these transactions to continue post-petition in the ordinary course of business. If the inter-company transactions were discontinued, the debtor's operations

would be unnecessarily disrupted, causing harm to the debtor's estates and the debtor's creditors. Specifically, certain operational expenses would simply fail to be paid, including payroll. Finally, Your Honor, we request that to the extent the debtors are not in compliance with bankruptcy code Section 345, the debtors be given a 30-day extension to come into compliance. Your Honor, the debtors received a number of comments to the interim cash management order from the U.S. Trustees Office, and the debtors have incorporated those comments. Unless you have any questions, we'd ask that this motion be granted.

Okay, I don't have any questions. Is there anyone who'd like to be heard regarding the cash for no response? based upon the evidence before me, which comes in the form of Mr. Renzi's declaration. The debtors, if I do not grant, and so therefore I'm going to grant the motion on an interim basis. Thank you, Your Honor. And finally, Your Honor, that brings us to the last item. I'm going to have the privilege of presenting today, which is agenda item number six, the application of the debtors to appoint Kurtzman-Carsan consultants,

doing business as Veritau Global, as claims and noticing agent for the debtors. A sealed version of the application is filed at docket number 11, and a redacted, publicly available version is available at docket number 12. Prior to engaging in Verita, the debtor solicited proposal from two other claims agents consistent with the claims agent protocol. The debtors ultimately selected Beretau based on its experience, competitive rates, and qualifications. As the debtors have over 200 creditors, the appointment of a claims and noticing agent is required by the local rules. The U.S. trustees' office provided the debtor's comments to the proposed order, which have all been accepted and incorporated.

Unless Your Honor has any questions at this time, we would ask that you enter the order approving the application. What's your evidentiary support for this motion or this application? Thank you, Your Honor. We attached a declaration in support of the application as evidentiary support for the application. By Mr. Gershwein? Yes, Your Honor. Yes. And are you moving the...

admission in Mr. Gershbein's declaration in support of the application? Yes, Your Honor. Okay, very good. Is there anyone who objects to the admission of Mr. Gershbein's declaration in support of Veritas retention? Okay. I hear no response, and I'll just ask, is there anybody who wishes to cross-examine Mr. Gershwin? Okay, I hear no response to that either.

I've reviewed the revised order, and again, I'm not. happy to grant the relief requested. It is required under all local rules, and certainly Veritad has very well known to this court. So I'll be happy to enter that order. Thank you, Your Honor. That's all I have for you today, and I will be introducing my colleague, Andrew Mark, to take the podium from here. Thank you very much, Mr. Gover. Good afternoon, Mr. Mark.

Good afternoon, Your Honor. For the record, Andrew Mark of McDermott, Will & Schulte, proposed counsel to the debtors. Your Honor, the next item on this afternoon's, agenda is the debtor's motion for payment of taxes and fees, Your Honor. It's filed at docket number 13. Your Honor, in the ordinary course of the debtor's business, the debtors incur various taxes and fees, including, for example, income taxes and franchise taxes, which the debtors remit to various federal, state, local, and foreign governments.

Primarily, the debtor's tax liabilities are incurred in Delaware, Illinois, and the Cayman Islands. As of the petition date, Your Honor, the debtors estimate they owe approximately $38,000 in taxes and fees, which will become due and owing during the Chapter 11 cases. Specifically, as to U.S.-based debtors, they have incurred approximately $30,000 of franchise taxes in 2025, $8,000 of which remain due and owing. Similarly, the Cayman Islands-based debtors also pay registration fees under Cayman Islands law, which are substantially analogous. to franchise taxes owed under state law in the U.S. As of the petition date, approximately $30,000.

This episode is brought to you by Spreaker, the platform responsible for a rapidly spreading condition known as podcast brain. Symptoms include buying microphones you don't need, explaining RSS feeds to confused relatives, and saying things like, sorry, I can't talk right now, I'm editing audio. If this sounds familiar, you're probably already a podcaster.

The good news is Spreker makes the whole process simple. You record your show, upload it once, and Spreaker distributes it everywhere people listen, Apple Podcasts, Spotify, and about a dozen apps your cousins swears are the next big thing. Even better, Spreaker helps you monetize your show with ads, meaning your podcast might someday pay for, well, more microphones. Start your show today at spreeker.com. Spreaker, because if you're going to talk to yourself for an hour, you might as well publish it. This is owed in registration fees to the relevant taxing authorities in the Cayman Islands.

relief requested in the tax motion is necessary for the debtors to avoid immediate and irreparable harm. Failure of the debtors to pay franchise taxes and fees could result in the relevant government authorities imposing, imposing, fines, penalties, and potentially restricting the debtor's right to conduct business in those jurisdictions. Accordingly, the debtors submit they meet the criteria contemplated under Bankruptcy Rule 6,003. Additionally, Your Honor, while the debtors believe they are current on their other tax obligations, the debtors request authority, to the extent there was anything else outstanding, such as certain pre-petition taxes and fees, which are withheld by the debtors and held in trust for the particular taxing authority,

and therefore do not constitute property of the debtor's estate for those amounts to also be paid. Failure of the debtors to pay such pre-petition taxes may also impact the debtor's ability to conduct business in certain jurisdictions, And it may also create a risk of personal liability on behalf of the debtor's management. And further, Your Honor, it may also open up the debtors to the risk of the taxing authorities initiating audits, which would unnecessarily divert the debtor's attention from the Chapter 11 cases. I would also note, Your Honor, that nothing in the proposed order seats authority for the debtors to pay past due taxes. after the filing of the taxes motion, the debtors worked collaboratively with the office of the United States trustee to resolve Mr. Hackman's comments to be proposed interim order, which with respect to this motion were fairly light, Your Honor. I'm happy to walk Your Honor through the one, what I would characterize as a substantive change to that proposed order, but otherwise, unless Your Honor has any questions, the debtors would request that the court enter the relief requested on the tax.

motion thank you yeah I've reviewed the revisions and I understand them let me ask if there's anyone who would like to be heard regarding the tax motion okay I hear no response once again I I have the declaration of mr. Renzi to rely upon in support of the relief that the debtors are requesting by the tax motion I've reviewed it and I do find that immediate directable harm would come to the debtors if I did not grant the relief on an interim basis So I will enter the interim order. Thank you, Your Honor.

That takes us to the next item on today's agenda, which is the debtor's motion to pay employee wages and continue certain employee benefits programs filed at docket number 14. Your Honor, through the wages motion, the debtors request authority but not direction to pay certain pre-petition obligations with respect to their employees. As of the petition date, the debtors employ 14 employees,

although the debtors are generally current, on the majority of their wage-related obligations, there are generally three discrete buckets of employee obligations the debtors believe pre-petition amounts remain due and payable on. The first of which, Your Honor, would be that the debtors estimate, as of the petition date, approximately $25,000 remained outstanding on account of employee expense reimbursements for work-related to reimbursable expenses. In the ordinary course of the debtor's business, the employees incur work-related expenses and pay for such expenses using personal credit cards or other personal funds and subsequently seek reimbursement from the debtors.

Absent authority to pay the employee expenses, including amounts incurred pre-petition, the employees would be obligated to pay for such amounts out of their own personal funds, which could adversely affect employee morale and the willingness of the debtors employees to continue employment with the debtors. The second bucket, Your Honor, implicates the debtor's paid time off programs or PTO. Like most companies, Your Honor, the debtors also offer their employees paid time off. The amount of PTO of any given employee that accrues is largely dependent on that employee's specific offer letter. But in general, Your Honor, the employees will receive on average 16 days of PTO per year.

Under relevant state and local law in the jurisdictions the debtors operate in, the debtors may be required to cash out employees accrued PTO upon termination. As of the petition date, the debtors estimate that approximately $80,000 of accrued but unpaid PTO remains outstanding. Finally, the debtors provide workers' compensation insurance to their full-time employees, and in jurisdictions in which the debtors operate are required by law to do so. As at the petition date, the debtors estimate that approximately $6,000 remain due and owing on account of administrative fees in connection with the workers' compensation program. Taken together, Your Honor, the debtors estimate that in total, approximately $11,000 is outstanding as of the petition date with respect to those amounts. As mentioned, the debtors are current on their other employee-related obligations, but out of an abundance of caution, request authority to continue such employee programs in the ordinary course and consistent with past practice. Failure to pay outstanding employee wage obligations could jeopardize the ability of the debtor.

to accomplish their goals in these Chapter 11 cases, especially where the debtor's remaining workforce represent a court group of the debtor's essential employees. Moreover, Your Honor, I want to highlight and also stress to the court that as we stand here today, the debtors need to fund payroll by Wednesday this week in order to meet their next pay period. Accordingly, the debtors submit that the relief in the wages motion is necessary to avoid immediate and irreparable harm

under bankruptcy rule 6003. Your Honor, after filing the wages motion, the debtors received comments from the U.S. trustee and worked to resolve those comments as reflected in a red line to the order that I do believe was provided to chambers prior to this afternoon's hearing. Your Honor, the biggest highlight, the biggest thing to highlight is that the debtors have added language at Mr. Hackman's request, stating that the order is not approving any bonus plan severance that would otherwise be subject to Bankruptcy Code Section 503C. unless Your Honor has any questions, the debtors respectfully request that the court enter the order of approving the wages motion on an interim basis. Okay, I do not have any questions. Does anybody wish to be heard regarding the wages motion? Okay, I hear no response based upon the evidence before me, which comes in the form of Mr. Renzi's declaration,

I find that immediate irreparable harm would come to the debtors if I did not grant the relief on an interim basis for the reasons that you've identified. and that we're described in the declaration. Therefore, I'm very happy to be able to grant the motion on an intrabasis in the way intermotive. Thank you, Your Honor. The next item on this afternoon's agenda is the debtor's motion to file a consolidated creditor matrix, authorized service on certain parties by email, and to redact certain individuals' personally identifiable information,

which is filed at docket number 15. Your Honor, through the creditor matrix motion, the debtor's request, authority to file a consolidated list of their top 30 creditors, and we were filing multiple lists of their top 20 creditors for each debtor. The debtors submit that filing a single consolidated list will alleviate the administrative burden on the debtors' estates and minimize costs that would otherwise be incurred through filing multiple lists that would otherwise be duplicative service on multiple creditors. Your Honor, the debtors also request authority to serve notices in the Chapter 11 cases on creditors via email.

Prior to the petition date, Your Honor, the debtors communicated with many of their customers, investors, and creditors solely through email. In many instances, the debtors do not have physical mailing addresses on file for such parties. Accordingly, service by email, Your Honor, is the only method that the debtors have to serve such parties. Also, I would note for Your Honor that service via email will maintain consistency with how the debtors communicated with such parties prior to the petition date. However, in instances where the debtors do have physical addresses, Your Honor, on file, the debtors intend to serve such parties both by email and by physical mail. The debtors will also be posting important notices and documents concerning the Chapter 11 cases on their case website maintained by their claims and noticing agent, very tall. And then the last piece of relief in that motion, Your Honor, is that the debtors are seeking authority to redact certain personally identifiable information of individual

customer, client, and investor names. That is, only as to individuals, not as to any legal entities. Section 107 of the Bankruptcy Code enables this court to enter orders to protect parties from harm that could result from disclosing confidential information. Specifically, Your Honor, Section 107C1 of the code provides that the court for cause may protect an individual if disclosure of information creates an undue risk of identity theft or injury to such person's individual or property. Your Honor, the risk in this case is not speculative. This episode is brought to you by Spreaker. The platform responsible for a rapidly spreading condition known as podcast brain. Symptoms include buying microphones you don't need, explaining RSS feeds to confused relatives,

and saying things like, sorry, I can't talk right now, I'm editing audio. If this sounds familiar, you're probably already a podcaster. The good news is Spreaker makes the whole process simple. You record your show, upload it once, and Spreaker distributes it everywhere people listen. Apple Podcasts, Spotify, and about a dozen apps your cousin swears are the next big thing. Even better, Spreaker helps you monetize your show with ads, meaning your podcast might someday pay for, well, more microphones. Start your show today. at spreeker.com. Spreaker, because if you're going to talk to yourself for an hour, you might as well

publish it. The cryptocurrency industry in which the debtors operate is a frequent target for fishing scams, hackers, and sometimes physical threats to individuals. This court has previously recognized this reality in other similar Chapter 11 cases in this industry, such as FTX Trading Limited, where this court granted similar relief to that sought in the matrix motion today. The debtors respectfully submit that this type of relief has become routine and become a matter of common sense given the risk of identity theft and or physical harm to individuals from public disclosure of their personal information. Here, Your Honor, the debtors seek only narrow relief in requesting authority to redact

individuals' names and not redacting the names of any legal entities. Your Honor, after filing the motion, the debtors worked collaboratively with Mr. Hackman to address his office's concerns regarding the matrix motion and both the email service and redaction issues. Like I mentioned, Your Honor, the debtors endeavored to narrowly tailor the relief sought in the matrix motion to account for the U.S. trustees' issues and to be consistent with relief sought in other cases. We received comments just this morning from the U.S. trustee, which, to be clear, Your Honor,

is not the U.S. trustee's fault. It is just the posture we all find ourselves here. this afternoon, given the timing and extencies of the filing, we've endeavored to accept many of the U.S. trustees' comments to the proposed order, which I will note do not tie the U.S. trustee's hands when it comes to appointing any statutory committee and disclosing names if a given customer, creditor, or individual were to serve on such statutory committee if one is eventually appointed. I'd also preview for the court that the debtors do not anticipate that anything that will be occurring between now and the second day hearing would implicate this relief. For example, Your Honor, the debtors anticipate seeking an extension of time to file the schedules and statements in this case.

And I guess I would perhaps pause there and not get out ahead of anything. that Mr. Hackman might have to represent your honor on his positions. But your honor, I do believe that given the real risks in this type of industry in particular, that the relief sought here is appropriate under the circumstances and that the debtor has met its burden to obtain such relief under the bankruptcy code. Okay. Thank you, Mr. Mark. Mr. Hackman, great to see you. Good afternoon. Good afternoon, Your Honor. May it please the court, Ben Hackman for the U.S. trustees. It's good to see, Your Honor. We did send informal comments to counsel about this form of order.

I understand that debtors are prepared to make certain changes to it that would resolve some of our comments. At this point, we have one open issue, and that is the scope of paragraph 7 of the form of order. Okay, I'm there. As I read it, this would authorize the debtors not just to redact the names of their individual customers, but also the names of their current and former directors, managers, officers, employees, and individual shareholders.

We object to redacting the names of management for a few reasons. First, if you look at Mr. Renzi's first day declaration, paragraphs 39 through 41 and paragraph 74, identify by name, by my count, nine current or former members of management. And we would submit respectfully that there's no basis to seal those names that have already been publicly disclosed in the First Day Declaration. Second, members of management should not have their names redacted where the context is solely with respect to their status as management. So for example, so for item four, transfers made to insiders in the year pre-petition, rule 2014A disclosures and professional retention applications. should not be redacting or omitting the names of management. Section 503 motion to pay bonuses to insiders. We would submit it is an issue for today, Your Honor,

because if you look at Veritas application, the schedule of parties and interests attached to Mr. Gershbein's declaration omits every name of current and former dees and owes of the debtor. I would assume that retention applications when they're filed would follow suit. I think the authority to do that, at least for Veritah, would be in this order. And so we would oppose that relief, even on an interim basis today.

And finally, Your Honor, the third point I would make is transparency is key. As I read the first day declaration paragraphs 61 and 62, say temporary restraining orders were granted into recent suits against the debtors and certain members of current reform or management that alleged, as I read it, misappropriation of customer funds, conversion, and other fraud-based claims. We would respectfully submit there should be visibility into any indemnity claims, insurance coverage, derivative actions, et cetera, if those become issues in these cases. We would respectfully submit, Your Honor, that paragraph 7 of the form of order should be revised

so that it does not apply to the names of current or former directors, officers, or managers of the debtor, and it should limit redaction of any customer names to situations where the disclosure would indicate the status of such person as a customer of the debtor. Unless Your Honor has any questions, that's all I have. Okay, I don't have any questions. Thank you, Your Honor. Okay. Mr. Mark, I don't recall where I've ever, well, I don't recall where a debtors have requested that I commit the redaction, the names of directors, managers, and officers. Could you address Mr. Hackman's comments on that and also point me to,

where in the evidentiary record I can find support for the idea that those names need to be redacted, particularly given the identification of a lot of those parties in the declaration itself. Certainly, Your Honor. As to current management, Your Honor, the debtors would actually be prepared to concede to Mr. Hackman and agree to have the names of current management not be redacted, Your Honor. To be clear, then current directors, managers, and officers? That would be correct, Your Honor. Okay.

I think that that then resolves Mr. Hackman's, one of Mr. Hackman's concerns about paragraph 7. Is that right, Mr. Hackman? Yes, Your Honor, we would maintain the objection to redacting the names of. former management. I would ask, Counsel, please correct me if I'm going to speak, but my impression from reading the first day declaration, for example, is that there's been very recent, some very recent changes in management. Right. And as I understood Mr. Marks' comments, no longer seeking to redact the names

of former. I'm sorry. Explain to me again. I apologize. Yes, certainly, Your Honor. The debtors would be amenable to not redacting the names of current management. Oh, but former. But we would still take the position, Your Honor, that given the nature of the industry, that redacting the names of former management is something that the debtors would still be seeking, and then also as to your rank and file employees, Your Honor. For former directors, managers and officers, can you explain what

the concern is and where in the evidentiary record the relief that you're requesting or supported. Yes, Your Honor. I believe the concerns really boil down to the nature of this industry and the heightened risk of all the parade of horribles that we've seen in some of these other cryptocurrency related cases, Your Honor. I do not have the First Day Declaration in front of me. Your Honor, I understand Mr. Hackman's position.

with respects to former directors and officers, and if I understand it correctly, also the employees, Your Honor, given that we are here on a first day hearing, and I do understand Mr. Hackman has his reservations about doing so, but we would ask, if Your Honor is not inclined to grant the relief here today, that perhaps we can consult with our client on the issue further. I expect that, you know, the debtors might wish to brief this issue further for a final hearing, Your Honor. So I would, I guess, pause there and perhaps maybe receive comments from Mr. Hackman or your honor on that proposal. Sure. To my knowledge, and you're going to have to educate me, but in some of these other crypto cases where problems have arisen, and it's been in the context of bad actors trying to get access to the wallets of customers. Now they, you know, if they're on a matrix, they've got their names, they've got other identifying information that they can use to try fishing scams and other ways of trying to get information from them to be able to take their property. That would seem to be a different sort of concern than one would have for directors, managers, and officers of a business that's involved in crypto.

Do you disagree, or is that something that you would push back on? Your Honor, I think the debtors would at this point push back on that. Again, the nature of the industry, and if they're no longer serving with the companies, Your Honor, we would, I think, request the ability to brief that issue. Your Honor, if I – Yeah. Your Honor, if you would – would we be able to have perhaps a 10-minute brief recess to discuss with our client? Yeah, certainly.

That's just fine. Thank you, Your Honor. Okay. Okay. We're in recess. Hello again, Your Honor. For the record, Andrew Mark, with Dermit-Lum-Schulte, proposed counsel of the debtors. Your Honor, thank you for affording the parties a brief recess.

During such recess, the debtors did have an opportunity to discuss the relief sought in the matrix motion with Mr. Hackman. And after such discussions, I'm happy to report to Your Honor that I believe we've resolved Mr. Hackman's concerns as to the matrix motion and the ceiling issue. Specifically, Your Honor, the debtors will agree not to redact the names of former directors, officers, and managers. This episode is brought to you by Spreeker, the platform responsible for a rapidly spreading condition known as podcast brain. Symptoms include buying microphones you don't need, explaining RSS feeds to confused relatives, and saying things like, sorry, I can't talk right now, I'm editing audio. If this sounds familiar, you're probably already a podcaster. The good news is Spreaker makes the whole process simple. You record your show, upload it once, and Spreaker distributes it everywhere people listen, Apple Podcasts, Spotify, and about a dozen.

In a dozen apps, your cousin swears are the next big thing. Even better, Spreaker helps you monetize your show with ads, meaning your podcast might someday pay for, well, more microphones. Start your show today at spreeker.com. Spreaker, because if you're going to talk to yourself for an hour, you might as well publish it. To what I believe to be the final item on this afternoon's agenda, which is the debtor's motion for use of cash collateral filed at docket number 16.

before I proceed with the debtor's argument on that motion, Your Honor, I would move for the admission of Mr. Renzi's declaration in support of her 17 into evidence. Your Honor, through the cash collateral motion, the debtors seek authorization to use their cash on hand and other assets to fund these Chapter 11 cases. The use of cash collateral is necessary and indeed crucial for the debtors to achieve their goals in Chapter 11. Prior to the filing of these cases, the debtors entered into two promissory notes with Celsius Network Limited. Under the notes, Your Honor, Celsius claims that it has a lien and alleges a security interest over the debtor's assets. First, the debtors, as a gating issue, Your Honor, the debtors continue to evaluate whether Celsius is properly perfected on its security interest in the debtor's assets. and if later it is determined that Celsius was not properly perfected, submit that that alone would warrant approval of the cash collateral motion.

However, Your Honor, as we stand here today, until the debtors complete their evaluation of whether Celsius is properly perfected and the court has an opportunity to make a ruling on such issue, the debtors proposed through the cash collateral motion to afford Celsius adequate protection until such time that the validity of its alleged liens, if any, can be determined. Specifically, Your Honor, Celsius is heavily over-secured. The principal outstanding amount owed under the promissory notes is approximately $4.8 million, although the debtors understand that Celsius asserts it is owed default interest, which if enforceable, would bring the alleged amount to approximately $5.5 million. Your Honor, the aggregate value of the debtor's cash collateral,

which consists of both cash and cryptocurrency is approximately $30 million. This creates circumstances where Celsius enjoys an approximate 500% equity cushion, which the debtors submit is more than sufficient for purposes of adequate protection under these facts and relevant case law, which typically requires only 20% of an equity cushion to be sufficient. However, Your Honor, under the proposed cash collateral order, even with such equity cushion, the debtors further proposed to grant the pre-petition-secured party replacement liens, which will be valid and enforceable even if it is later determined that – excuse me, will be valid and enforceable unless it is later determined that the pre-petition

secured party is properly perfected on account of its alleged lien. Your Honor, the debtors further proposed to provide Celsius with a super-priority administrative of expense claim to the extended holds of out-secured claim under Section 507B of the Bankruptcy Code. And finally, Your Honor, the pre-petition secured party will be further protected from any diminution in value because the

debtor will only be using the cash collateral to preserve the going concerned value of the debtors' estates by administering these Chapter 11 cases. Your Honor, absent authority to use cash collateral, the debtors will lack the liquidity to accomplish their goals in these Chapter 11 cases, which will to the detriment of all the debtors, creditors, and stakeholders. Prior to the filing of this motion, Your Honor, the debtors were able to consensually resolve comments from the United States

Trustees Office, as I believe Mr. Hearst previewed for your honor at the beginning of this afternoon's hearing. And I would further highlight that after the filing of the motion, the debtors entered into discussions about the release sought with Celsius and have reached an agreement on consensual use of cash collateral. The debtors greatly appreciate Celsius's efforts to reach a resolution with us and anticipate submitting a revised order with a further interim order to be heard in two weeks subject to this court's availability. Your Honor, I have a markup of that further revised order. If Your Honor would like to see it, I'm not certain that it's been provided to chambers. Yes, please. If I may approach, Your Honor. Please, Mr. Mark.

Your Honor, at a very high level, the revision. to the proposed cash collateral order contemplate the debtors capping their spending under the interim order at $1 million until the end of the month absent consent from Celsius to spend additional amounts or otherwise ordered by the court. The debtors believe that that rough two-week period will afford the debtors and Celsius enough time to either reach an agreement as to the validity and enforceability of Celsius's alleged security interest or otherwise bring the issue back before the court. I would pause there and if Your Honor would like, I'm happy to walk the court through the proposed order. Otherwise, excuse the revised proposed order. Otherwise, the debtors would respectfully request entry of the interim order. I've had a chance to review it quickly, but why don't you walk through them for the benefit of people in the courtroom or on soon who may not have had a chance to look at it? Certainly, Your Honor.

Your Honor, if you turn to page four of the proposed order and page. paragraph three. This paragraph at the end contains the language I just alluded to regarding the $1 million interim cap in spending, which would apply during the first two weeks from entry of this interim order, and that the debtors could exceed that interim amount with the consent of Celsius or a further order from this court. Your Honor, on page five of the proposed order, revised proposed order, we struck the language regarding the pre-petition secured parties' additional adequate protection. I believe that was at the request of Celsius' counsel.

And in paragraph 7, Your Honor, which is also on page 7 of the revised proposed order, that does contain with respect to the termination date of interim use of cash collier will be roughly two week period I earlier alluded to which would be March 31st, 2026. And Your Honor, I do believe that that is the bulk of the substantive changes to the order. We do make a conforming change in paragraph 10 on page 9 to reflect the possibility that we would be back before Your Honor for a second interim hearing absent the debtors obtaining consent from Celsius. Okay. I do have one question that's sort of a little unclear to me from the papers. And the issue is this. It sounds to me like the pre-petition practice has been that customer funds and company funds are commingled.

That's been the practice, and under the term sheet, that practice would cease. So has there been any analysis done of to what extent funds might be customer funds as opposed to? Yeah, I'll give you a chance to either speak with Mr. Asman. Okay. Yeah, thank you, Mr. Norr. Your Honor, yes, there has been analysis and effectively what we have determined is that customer funds, at least, you know, as we call them, funds that were deposited by customers, have always been. commingled with company funds and other customer funds.

The company's position is that all the funds in the estate currently subject potentially to liens that may exist, such as with Celsius potentially, all the funds are property via state. And I think, as Your Honor probably knows in the Third Circuit and many others, property and the possession of the debtors by default are assumed to be presumed to be property to state, but other parties are free certainly to come in and challenge that, but that is the company's position right there. understand precisely and that that'll be an issue for customers to raise if they wish to. Yes.

Having said that, your friend Ms. Van Laer has stood up. I will allow her to speak. Okay. Ms. Van Laer. Yes, Your Honor. Thank you so much. Briefly, I just wanted to address this issue. I think the Ad Ha Group would like to reserve our rights on this issue of customer property.

Certainly the customers had the expectation and were told that these were customer funds that would be segregated. So I don't think we can get into that issue fully right now, of course, but we do reserve our rights on that issue. Okay. Thank you. That's fair enough. Okay. That's really the only question that I had. Is there anybody who'd like to be heard regarding the interim cash collateral motion?

Mr. Positi? Your Honor. Good afternoon. For the record, Dominic the City of Claire Harris and Harvey Brandsburg on behalf of Celsius Network limited buying through the blockchain Recovery Investment Consortium LLC, acting in its capacity is litigation agreement and complex asset recovery manager, mouthful. Your Honor, we're co-counsel with folks at White and Case on this matter. Mr. Gregory Pesh is on the line on Zoom, and I think he might want to address the court. I think he has to be acknowledged, but I'm not sure if he was able to plug in.

Sure, Mr. Pash. Hi, Your Honor. Gregory Patchwayne case for Celsius here. Can you hear me all right? I can hear you. I can't see you, but I'll leave it on whether you want to turn the camera. Okay, they're letting me turn my camera on now, so thank you. I'm not trying to hide here.

All right, so thank you. There we go. So thank you very much for letting me speak, and we appreciate the time with Mr. Renzi and the McDermott firm to address our concerns. as alluded to by the debtors council, Celsius has a significant secured claim here. The instrument has been in default since around August 2025. It's accruing default interest. Celsius has a lot of questions about the case and the circumstances that have led to the filing here.

In the last 24 hours, we've started to get information as we've engaged with. Mr. Renzi and the McDermott firm about the cash collateral situation. We look forward to working with them more in the coming two weeks ahead of the expiration of this order to get more information about what happened at the company and what the path forward is, in particular regarding the IP that might be the foundation for the so-called customer-led reorganization, since it's our assertion that that is subject to our security interest. purposes of today, we're pleased that we reached an agreement that has some specific guardrails on the use of cash collateral. We look forward to engaging with the court and the other parties

here in the coming weeks, and I appreciate you making the time. That was all I wanted to share with the court today. Thank you. Thank you, Mr. Pesh. Mr. Gurevich, appearing by Zoom. Would you like to be heard, sir? Hi, Your Honor. Can you hear me okay over there? I can hear you. Thank you, Mr. Gervich. Yes. So thank you, Your Honor, and good afternoon. I'm I represent Dominion Capital. I'm a principal at the firm. It's a small family office in New York. We are seventh largest depositor on the platform, I believe, or six, if you don't include

NXO, that are over the convertible note. So I just wanted to highlight for your information, the fact that when we deposited our assets on the platform and signed onboarding agreement as part of Blockville's documents, package, it specifically said that all customer deposits are going to be completely segregated from the general balance sheet of the company. So, you know, as you contemplate this discussion, I'd just like to point out that fact for you. So if there's, you know, an opportunity for the court to set aside a percentage for the customer

deposits, I think that would be a, you know, a prudent decision. But again, I just want to highlight that fact. Okay, thank you, Mr. Gervich. Is there anyone else who would like to be heard? Okay. Mr. Hackman. Thank you, Your Honor. Ben Hackman for the U.S. trustee.

We have no objection to entry of the order as revised. I thank counsel for working with us to resolve our comments. I rise just to apprise the court that we have sent out a solicitation for a creditors committee. We have a March 23rd return deadline. Okay. I note that the second interim hearing was contemplated as being March 31st. if there's interest in appointing a committee, we'll endeavor to process that as promptly as we can next week. Thank you, right?

Thank you. Thank you. Okay. Mr. Asman, would you like to respond to Mr. Gerovich's comments? No, Your Honor. Other than to say that, as you can imagine, this may be coming to a movie near you shortly in terms of the issue coming before the court. Okay. Okay.

I hear Mr. Gervich's concern. Certainly it's a question that I had, but based upon the record before me, I don't have any evidence that would show that the funds that the debtors are proposing to use our property of anybody but the debtor's in possession. but the issue is preserved and it can be raised in connection with the final hearing. So based upon the veterinary record that I do have,

I am satisfied that the debtors have sustained their burden of showing why they should be permitted to use cash collateral in accordance with the revised proposed interim order. And I will grant that motion on an interim basis, but again, I'm not giving short shrift to Mr. Gervich's concerns. It simply be an issue that is fully preserved for him and anybody else to raise in connection with further hearing. Thank you, Your Honor. And just as a housekeeping item, I would like to request the second interim hearing,

which is that two-week period, whatever works for Your Honor. I'm sure we can accommodate. Yeah. We'll give you March 31st a three-year. If that's suitable, short parties? That's great. Thank you, Your Honor. Okay.

And I have something else going on before that. If that gets moved, I'll reach out to you. If we can move it up in the day, I'm sure you'd be happier to get on that as soon. What's that? It may also be resolved by that point as well. Right, right, of course. Okay. Very good.

But we'll say March 31st at 3 p.m. Thank you, Your Honor. Okay. And as for the other interim orders, well, really all of them, I reviewed them, but they were not the docket for others to review. So if you could file those under certification of counsel, then I will enter the order once they've been filed on certification of counsel and uploaded. Thanks so much, Your Honor. Okay. Appreciate it. Thank you. Is there anything else for today? No, Your

Honor. Not for the debtors. Thank you. Okay. Very good. Oh, just one. Yes. On the cash management motion, the ad hoc group requested a minor change that Mr. Dover would I'd like to just read another record briefly if that's okay, Your Honor, just so that you don't see the red line and you have some context for it. Thank you. Sure. Thank you, Your Honor. Ethan Dover, McDermott, Will & Schulte, proposed counsel to the debtors. At the conclusion of my presentation, the ad hoc group made a request that they be given notice of any intercompany transaction.

We find that request acceptable and will work with the ad hoc group and the U.S. trustee to fashion language to include in the interim cash management order and get your revile. from the conclusion of the hearing. Very good. Okay, thank you. Thank you, Your Honor. Okay, I appreciate the presentations, especially those from Mr. Dover and Mr. Mark, and I thank you for bringing them and giving them the opportunity to contribute to the hearing on all of the relief that you were seeking. It's great to see. So I'm grateful for that, and I'll look forward to seeing the 31st until they...