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In re

DEWEY RANCH HOCKEY, LLC,

COYOTES HOLDINGS, LLC,

ARENA MANAGEMENT GROUP, LLC,


Debtors.

This Filing Applies to:




(cid:134)
(cid:132)

All Debtors
Specified Debtors










Case No. 2:09-bk-09488

Case No. 2:09-bk-09500

Case No. 2:09-bk-09495

Chapter 11
(Jointly Administered)

DEBTORS’ MOTION TO CONVERT
CASES TO CHAPTER 7



Thomas J. Salerno (AZ Bar No. 007492) [email protected]
Jordan A. Kroop (AZ Bar No. 018825) [email protected]
Kelly Singer (AZ Bar No. 022024) [email protected]
SQUIRE, SANDERS & DEMPSEY L.L.P.
One East Washington Street, Suite 2700
Phoenix, Arizona 85004-4498
(602) 528-4000

Counsel to the Debtors-In-Possession


UNITED STATES BANKRUPTCY COURT

DISTRICT OF ARIZONA





DEWEY RANCH HOCKEY, LLC (“Dewey”), COYOTES HOLDINGS, LLC

(“Coyotes Holdings”), and ARENA MANAGEMENT GROUP, LLC (“Arena Management,”

and together with Dewey and Coyotes Holdings, the “Select Debtors”), debtors-in-possession in

the above-captioned chapter 11 cases (the “Select Cases”), desire to convert the Select Cases to

cases under chapter 7 of the United States Bankruptcy Code, 11 U.S.C. § 101 et seq. (the

“Bankruptcy Code”). The Select Debtors believe that the relief requested in this Motion may be

granted ex parte under Bankruptcy Code § 1112(a) and Rules 1017(f)(2) and 9013 of the Federal

Rules of Bankruptcy Procedure. In support of this Motion, the Debtors respectfully submit:

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1. On May 5, 2009 (the “Petition Date”), the Select Debtors filed their voluntary

petitions for relief under chapter 11 of the Bankruptcy Code in the United States Bankruptcy

Court for the District of Arizona. The Select Debtors operated their businesses and operations,

to the extent they had any, as debtors-in-possession in accordance with Bankruptcy Code

§§ 1107 and 1108.

2. The Select Debtors are eligible to be chapter 7 debtors under Bankruptcy Code

§ 109(b).

3. In accordance with Bankruptcy Code § 1112(a), the Debtors may convert the Select

Cases to cases under chapter 7 because the Select Debtors are debtors-in-possession, the Select

Cases were not originally commenced as involuntary cases, and the Select Cases have never

previously been converted to chapter 11 cases.

4. To be clear, this Motion does not seek to convert the case of Coyotes Hockey, LLC

(“Coyotes Hockey”), a jointly administered debtor with the Select Debtors (Case No. 2:09-bk-

09491-RTBP). With regard to the Coyotes Hockey estate, this Court entered an order approving

the sale of the Phoenix Coyotes Hockey team and certain related assets to the National Hockey

League (the “Sale”) on November 2, 2009. Because the assets subject to the Sale were property

of Coyotes Hockey, the proceeds from the Sale are, therefore, property of the Coyotes Hockey

estate. The proposed distribution of the sale proceeds is addressed in the Second Amended Plan

of Reorganization (the “Coyotes Hockey Plan”) and accompanying disclosure statement filed

by Coyotes Hockey on December 1, 2010. The Coyotes Hockey Plan relates solely to Coyotes

Hockey and does not apply to the Select Debtors. Furthermore, the Select Debtors currently

have no operations and are not necessary to consummate the Coyotes Hockey Plan.

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Accordingly, the Select Debtors respectfully request that the Court enter an order

substantially in the form attached converting the Select Cases to cases under chapter 7 of the

Bankruptcy Code.



Dated December 15, 2010.





SQUIRE, SANDERS & DEMPSEY L.L.P.

By:


/s/ Thomas J. Salerno
Thomas J. Salerno
Jordan A. Kroop
Kelly Singer

One East Washington Street, Suite 2700
Phoenix, Arizona 85004-4498
(602) 528-4000

Counsel to the Debtors-In-Possession



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