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TARTER KRINSKY & DROGIN LLP Proposed Attorneys for The Christian Brothers Institute and The Christian Brothers of Ireland, Inc. Debtors and Debtors-in-Possession 1350 Broadway, 11th Floor New York, New York 10018 (212) 216-8000 Scott S. Markowitz, Esq. Ira R. Abel, Esq. UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------------- x In re: : : THE CHRISTIAN BROTHERS INSTITUTE, : : Debtor. : ------------------------------------------------------------------- x In re: : : THE CHRISTIAN BROTHERS OF IRELAND, INC., : : Debtor. : ------------------------------------------------------------------- x

Chapter 11 Case No.: 11-22820 (RDD) (Joint Administration Pending) Chapter 11 Case No.: 11-22821 (RDD) (Joint Administration Pending)

APPLICATION FOR ORDER EXTENDING TIME WITHIN WHICH THE DEBTORS MUST FILE SCHEDULES OF ASSETS AND LIABILITIES AND STATEMENTS OF FINANCIAL AFFAIRS TO: THE HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE The Christian Brothers Institute (CBI) 1 and The Christian Brothers of Ireland, Inc. (CBOI), 2 the above-captioned debtors and debtors-in-possession (together, the Debtors), by their proposed counsel, Tarter Krinsky & Drogin LLP, respectfully represent as follows:

The last four digits of CBIs employer identification number are 0153 and its mailing address is 21 Pryer Terrace, New Rochelle, New York 10804. 2 The last four digits of CBOIs employer identification number are 0603 and its mailing address is 10001 S. Pulaski, Room 106, Chicago, IL 60655-3356.

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RELIEF REQUESTED 1. By this application (the Application), the Debtors respectfully request that they

be granted an extension of the time within which they must file their respective Schedules of Assets and Liabilities and Statements of Financial Affairs (together, the Schedules) from May 12, 2011 to June 13, 2011, pursuant to Rule 1007(c) of the Federal Rules of Bankruptcy Procedure. 2. Rule 1007(c) requires each of the Debtors to file Schedules no more than fourteen

(14) days after the commencement of their respective Chapter 11 cases unless the Court grants an extension of such time. 3. The Debtors are in need of additional time to complete the schedules. The

Debtors have a limited in-house financial staff and these individuals have been pulled in numerous directions answering questions of various entities and schools as a result of the Chapter 11 filings. As a result, the Debtors may not be able to review, analyze and compile the all of the information required by the Schedules on or before May 12, 2011. The Debtors therefore require additional time to file their respective Schedules. The Debtors Local Rule 1007-2 affidavits provide a summary of the Debtors respective assets and liabilities. JURISDICTION, VENUE AND STATUTORY BASES FOR RELIEF 4. This Court has jurisdiction over this Motion under 28 U.S.C. 157 and 1334, and

the order of reference, dated July 10, 1984 (Ward, C.J.). 5. 6. This matter is a core proceeding within the meaning of 28 U.S.C. 157(b)(2). Venue of this proceeding and this Motion in this District is proper under 28

U.S.C. 1408 and 1409.

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7.

The statutory bases for relief are 105(a) and Rule 1007(c) of the Federal Rules

of Bankruptcy Procedure. BACKGROUND 8. On April 28, 2011 (the Petition Date), each of the Debtors commenced their

Chapter 11 cases (the Cases) by filing a voluntary petition for relief under Chapter 11 of Title 11, United States Code (the Code). Pursuant to 1107(a) and 1108 of the Code, the Debtors continue to operate as debtors-in-possession. No trustee has been appointed. No official

committee of unsecured creditors has been appointed. 9. CBI is a domestic not-for-profit 501(c)(3) corporation organized under 102(a)(5)

of the New York Not-for-Profit Corporation Law. CBI was formed in 1903 pursuant to Section 57 of the then existing New York Membership Law. The Not-for-Profit Corporation Law replaced the Membership Law effective September 1, 1970. The purpose for which CBI was, and continues to be, formed was to establish, conduct and support Catholic elementary and secondary schools principally throughout New York State. As a not-for-profit corporation, the assets, and/or income are not distributable to, and do not inure to, the benefit of its directors or officers. CBI depends upon grants and donations to fund a portion of its operating expenses. 10. CBOI is a domestic not-for-profit 501(c)(3) corporation organized under the Not-

for-Profit Corporation Law of the State of Illinois. The purpose for which CBOI was, and continues to be, formed was to establish, conduct and support Catholic elementary and secondary schools principally throughout the State of Illinois, as well as other spiritual and temporal affairs of the former Brother Rice Province of the Congregation of Christian Brothers. As a not-forprofit corporation, the assets, and/or income are not distributable to, and do not inure to, the

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benefit of its members or officers. CBOI also depends upon grants and donations to fund a portion of its operating expenses. 11. CBI has only 7 total employees and only one of which is familiar enough with the

financial aspects to compile the information necessary to file all of the Schedules. CBI has provided Debtors counsel with some information such as a list of fee owned real estate and it is expected that much of the Schedules will be substantially completed by May 12, 2011. However, it is likely that CBI will need additional time to complete all of its Schedules. 12. CBOI has no employees and relies upon its board of directors to compile the

information required to complete all of the Schedules. CBOI has also provided Debtors counsel with portions of the information necessary to complete the Schedules. However, it is likely that CBOI will also require an extension of time past May 12, 2011 to file all of its Schedules. 13. By this Application, the Debtors seek a thirty (30) day extension to through and

including Monday, June 13, 2011 to file their respective Schedules. The Debtors will make best efforts to file all of their Schedules prior to June 13, 2011. NOTICE 14. Notice of this Application has been given to the United States Trustee for the

Southern District of New York, who has been requested to enter a subjoined non-objection to the proposed order. In light of the procedural nature of the relief requested, and as Federal Rule of Bankruptcy Procedure 1007(c) requires notice only to the United States Trustee and any creditors committee organized, the Debtors respectfully submit that appropriate notice has been provided in accordance with 11 U.S.C. 102 and no further notice is required.

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WHEREFORE, the Debtors respectfully request entry of an order extending the time to file their respective Schedules to June 13, 2011, without prejudice to seek a further extension should it become necessary, and granting the Debtors such other and further relief as the Court deems just and proper. Dated: New York, New York May 2, 2011 TARTER KRINSKY & DROGIN LLP Proposed Attorneys for The Christian Brothers Institute and The Christian Brothers of Ireland, Inc. Debtors and Debtors-in-Possession

By:

/s/ Scott S. Markowitz Scott S. Markowitz Ira R. Abel 1350 Broadway, 11th Floor New York, New York 10018 (212) 216-8000

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