IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ) Chapter 11 ) ) Case No.

12-10968 (BLS) FASTSHIP, INC., et al., ) (Jointly Administered) 1 ) Debtors. ) ) MOTION TO EXPEDITE HEARING IN CONNECTION WITH THE DEBTORS MOTION TO SHORTEN NOTICE FOR MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT FastShip, Inc. (FSI), FastShip Atlantic, Inc. (FSA) and Thornycroft, Giles & Co., Inc. (TGC, together with FSI and FSA, the Debtors and each individually, a Debtor), debtors and debtors in possession in the above-captioned chapter 11 cases, hereby move (the Motion to Expedite) this Court to enter an Order, pursuant to Bankruptcy Code Section 105, Bankruptcy Rule 9006(c) and Local Rule 9006-1(e), setting for consideration on an expedited basis the Debtors Motion to Shorten Notice for Motion for Order Approving Disclosure Statement (the Motion to Shorten). CAUSE FOR EXPEDITED CONSIDERATION 1. Contemporaneously herewith the Debtors have filed the Motion to Shorten

seeking entry of an order (a) shortening the Notice Period2 to 26 days; (b) setting the objection deadline for the Disclosure Statement Motion as May 28, 2012, at 4:00 p.m.; and (c) scheduling hearing on the Disclosure Statement Motion for May 31, 2012 at 11:00 a.m. 2. The next Omnibus Hearing date in these cases is set for Wednesday, April 25,

2012, at 11:30 a.m. The Debtors request that this Court set hearing on the Motion to Shorten for
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The Debtors, along with the last four digits of each Debtors tax identification number, are as follows: FastShip, Inc. (8309) (Case No. 12-10968 (BLS)), FastShip Atlantic, Inc. (0980) (Case No. 12-10970 (BLS)) and Thornycroft, Giles & Co., Inc. (1142) (Case No. 12-10971 (BLS)). The mailing address for the Debtors is 1608 Walnut Street, Suite 501, Philadelphia, PA 19103. Capitalized terms not otherwise defined herein shall have the meanings given to them in the Motion to Shorten.

that hearing date so that the Court may rule upon the Motion to Shorten prior to the requested May 31, 2012 hearing date on the Disclosure Statement Motion. 3. Pursuant to Rule 9006(c) of the Federal Rules of Bankruptcy Procedure, the Court

may shorten the time for notice, objection deadlines and hearings on motions filed with the Court: when an act is required or allowed to be done at or within a specified time . . . the court for cause shown may in its discretion with or without motion or notice order the period reduced. 4. The Debtor respectfully requests the Court shorten the notice, objection deadlines

and hearing with respect to the Motion to Shorten for cause. Cause exists because the only available Omnibus Hearing Date in these cases prior to May 31, 2012, is April 25, 2012. WHEREFORE, the Debtors respectfully request that the Court enter an Order granting this Motion to Expedite and such other and further relief as the Court deems just and proper under the circumstances. Dated: April 23, 2012 BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP By: /s/ Raymond H. Lemisch Raymond H. Lemisch, Esquire (No. 4204) Jennifer E. Smith, Esquire (No. 5278) 222 Delaware Avenue, Suite 801 Wilmington, DE 19801 (302) 442-7010 (Telephone) (302) 442-7012 (Facsimile) rlemisch@beneschlaw.com jsmith@beneschlaw.com

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) Chapter 11 In re: ) ) Case No. 12-10968 (BLS) FASTSHIP, INC., et al., ) (Jointly Administered) 1 ) Debtors. ) Re: Docket No. ____ ) ORDER GRANTING MOTION TO EXPEDITE HEARING IN CONNECTION WITH THE DEBTORS MOTION TO SHORTEN NOTICE FOR MOTION FOR ORDER APPROVING DISCLOSURE STATEMENT This matter has come before the Court on Motion to Expedite Hearing (the Motion to Expedite) in Connection with the Debtors Motion to Shorten Notice for Motion for Order Approving Disclosure Statement (the Motion to Shorten). For cause shown, the Court orders as follows: 1. 2. The Motion to Expedite is Granted. A hearing on the Motion to Shorten will take place on April 25, 2012 at 9:30 a.m. at the

United States Bankruptcy Court for the District of Delaware, 824 North Market Street, 6th Floor, Wilmington, Delaware 19801, Courtroom 1 before the Honorable Brennan L. Shannon. Any objection to the Motion to Shorten may be raised at the hearing thereon. 3. The Debtors shall cause a copy of this Order to be served via email, fax or if no email or

fax information is known, then by first class mail on (a) the Office of the United States Trustee; (b) each of the Debtors top twenty (20) unsecured creditors; (c) all parties requesting notices in this bankruptcy case; and (d) the Debtors DIP Lender.

Dated: _________________ Wilmington, DE

_______________________________________ BRENDAN L. SHANNON UNITED STATES BANKRUPTCY JUDGE

The Debtors, along with the last four digits of each Debtors tax identification number, are as follows: FastShip, Inc. (8309) (Case No. 12-10968 (BLS)), FastShip Atlantic, Inc. (0980) (Case No. 12-10970 (BLS)) and Thornycroft, Giles & Co., Inc. (1142) (Case No. 12-10971 (BLS)). The mailing address for the Debtors is 1608 Walnut Street, Suite 501, Philadelphia, PA 19103.

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