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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., et al./ Case No. 10-
Debtors. (Joint Administration Requested)
MOTION OF DEBTORS FOR ENTRY OF AN ORDER PURSUANT TO 11
U.S.C. 341 AND 28 U.S.C. 156(c) AUTHORIZING THE DEBTORS TO
(I) FILE (A) CONSOLIDATED LIST OF CREDITORS AND (B)
CONSOLIDATED LIST OF DEBTORS' TOP TWENTY CREDITORS
AND (II) PROVIDE NOTICES, INCLUDING NOTICES OF
COMMENCEMENT OF CASES AND SECTION 341 MEETING
The above-captioned debtors and debtors in possession (collectively, the
"Debtors") hereby move (the "Motion") for an order, pursuant to section 341 of title 11 of the
United States Code (the "Bankruptcy Code") and section 156(c) of title 28 of the United States
Code ("Section 156(c)"), authorizing the Debtors to (i) file (a) a consolidated list of creditors and
(b) a consolidated list of the Debtors' twenty (20) largest unsecured creditors and (ii) complete
all mailings of notices, including notices of the commencement ofthese cases and of the meeting
of creditors required by section 341 of the Bankruptcy Code. In support of this Motion, the
Debtors respectfully state as follows:
The Debtors, along witb tbe last four digits of their federal tax identification numbers, are: Crdentia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Healtb Industry Professionals, LLC ( 4246), HIP Holding, Inc.
(3468),.MP Healtb Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The
Debtors' mailing address for purposes oftbese cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
JURISDICTION
1. The Comi has jmisdiction over the Motion pmsuant to 28 U.S. C. 157
and 1334. This is a core proceeding within the meaning of 28 U.S. C. 157(b)(2). Venue of
these proceedings and the Motion in this Comi is proper under 28 U.S. C. 1408 and 1409.
2. The statutory bases for the relief requested herein are section 341 of the
Bankruptcy Code and Section 156(c).
BACKGROUND
3. On March 17, 2010 (the "Petition Date"), the Debtors commenced their
bankruptcy cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code
(the "Chapter 11 Cases"). No trustee, examiner or creditors' committee has been appointed in
these cases. The Debtors are operating their respective businesses as debtors-in-possession
pmsuant to sections 1107 and 1108 of the Bankmptcy Code.
4. The events leading up to the Petition Date and the facts and circumstances
supporting the relief requested herein are set fmih in the Declaration of Rebecca Irish in Support
of the Debtors' Chapter 11 Petitions and First Day Pleadings filed contemporaneously herewith
and incorporated herein by reference.
RELIEF REQUESTED
5. By this Motion, the Debtors respectfully request the entry of an order (a)
authorizing the Debtors to file (i) a consolidated list of creditors and (ii) a consolidated list of the
Debtors' twenty (20) largest unsecured creditors;
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and (b) authorizing the Debtors (or their
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In connection with this request, the Debtors also request authority to submit one declaration under
Bankruptcy Ru1e 1008 verifying the validity of the consolidated list of creditors and one declaration
verifYing the validity of the Consolidated Top 20 List (as defmed below).
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agents) to complete all mailings of notices, including notices of the commencement of these
cases and of the meeting of creditors pursuant to section 341 of the Bankruptcy Code.
BASIS FOR RELIEF
I. Request for Authority To File Consolidated List Of Creditors
6. The Debtors have identified thousands of entities to which notice of
certain proceedings in the Chapter II Cases must be provided. The Debtors anticipate that such
notices may comprise, without limitation, notice of: (a) the filing of the Debtors' voluntary
petitions under chapter II of the Bankruptcy Code, (b) the initial meeting of the Debtors'
creditors in accordance with section 341 of the Bankruptcy Code, (c) applicable bar dates for the
filing of claims, (d) the hearing on the sale of some or all of the Debtors' business or assets; (e)
the hearing on adequacy of a disclosure statement in respect of a plan of reorganization or
liquidation, and (f) the hearing to confnm a plan of reorganization or liquidation (collectively,
the "Notices").
7. Rule 1007-2 of the Local Rules of Bankruptcy Practice and Procedure of
the United States Bankruptcy Court for the District of Delaware (the "Local Rules") provides
that in a voluntary chapter II case, the debtor must file "a list containing the name and complete
address of each creditor in such format as directed by the Clerk's Office Procedures."
8. The Debtors presently maintain various computerized lists of the names
and addresses of their respective creditors that are entitled to receive the Notices and other
documents in the Chapter II Cases. The Debtors believe that the information, as maintained in
computer files (or those of their agents), may be consolidated and utilized efficiently to provide
interested patties with the Notices and other similar documents, as contemplated by Local Rule
1007-2. Accordingly, by this Motion, the Debtors seek authority to file the lists on a
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consolidated basis, identifying their creditors and equity security holders in the format or formats
cunently maintained in the ordinary course of the Debtors' businesses.
II. Request For Authority To Filed Consolidated List Of Debtors'
Top Twenty (20) Unsecured Creditors
9. Pursuant to Rule 1007(d) of the Federal Rules of Bankruptcy Procedure
(the "Bankruptcy Rules"), a chapter 11 debtor must file with its voluntary petition a list setting
forth the names, addresses, and claim amounts of the creditors, excluding insiders, that hold the
twenty (20) largest unsecured claims in the debtor's case (a "Top 20 List"). This Top 20 List is
primarily used by the United States Trustee (the "U.S. Trustee") to evaluate the types and
amounts of unsecured claims against the debtor and thus identify potential candidates to serve on
an official committee of unsecured creditors appointed in the debtor's case pursuant to section
1102 of the Bankmptcy Code.
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10. The Debtors submit that a single consolidated list of their combined
twenty (20) largest unsecured creditors in these cases would be more reflective of the body of
unsecured creditors that have the greatest stake in these cases than separate lists for each of the
Debtors. Therefore, the Debtors respectfhlly request authorization to f:tle a single consolidated
list of their twenty (20) largest unsecured creditors in these cases (the "Consolidated Top 20
List").
11. The Debtors believe that such relief is not only appropriate under the
circumstances, but necessary for the efficient and orderly administration of these cases.
"The purpose of the separate list of 20 largest creditors required by this provision iu the rules is to enable
the clerk to identity members and the court to appoiut immediately an unsecured creditors' committee in
compliance with 11 U.S.C 1102(a)(l)." In re Dandy Doughboy Donuts, Inc., 66 B.R. 457, 458 (Bankr.
S.D. Fla. 1986); see also 9 COLLIER ON BANKRUPTCY 1!1007.5, at 1007-23 (Alan N. Resnick eta!.
eds., ]5th ed. rev. 2008) ("[T]he larger [unsecured creditor] list and iuformation about the claims of the
creditors on the list enables the United States Trustee to determiue the different types of claims existing iu
order to assure that a fully representative committee is appoiuted. ").
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ill. Mailings
12. In lieu of effecting service through the Office of the Clerk of this Court,
the Debtors also request that they (or their agents) be approved and authorized to complete all
mailings to creditors and equity holders in these cases, including notice of the commencement of
these cases and notice of the meeting of creditors pursuant to section 341 of the Bankruptcy
Code.
13. Allowing the Debtors (or their agents) to complete their own mailings will
save significant time, cost and expense.
NOTICE
14. No trustee, examiner or creditors' committee has been appointed in these
chapter 11 cases. Notice of the Motion has been provided to: (a) the U.S. Trustee; (b) those
parties listed on the consolidated list of creditors holding the twenty (20) largest unsecured
claims against the Debtors, as identified in their chapter 11 petitions; and (c) counsel for the
Debtors' secured lender, Com Vest Capital, LLC. In light of the nature of the relief requested
herein, the Debtors submit that no other or further notice is required.
NO PRIOR REQUEST
15. No prior request for the relief sought in this Motion has been made to this
Court or any other court.
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WHEREFORE, the Debtors respectfully request that the Court (i) enter an order,
substantially in the form annexed hereto as Exhibit A, approving and authorizing (a) the
Debtors' filing of a consolidated list of creditors; (b) the Debtors' filing of a Consolidated Top
20 List; (c) the Debtors' filing of one declaration under Bankruptcy Rule 1008 in connection
with a consolidated list of creditors and the Consolidated Top 20 List; and (d) the Debtors (or
their agents) to complete all mailings of notices, including notices of the commencement of these
cases and of the meeting of creditors pursuant to section 341 of the Bankruptcy Code; and (ii)
grant such other and further relief as may be just and proper.
Dated: March 17,2010
Wilmington, Delaware
BAYARD, P.A.
Is/ Jamie L. Edmonson
Jamie L. Edmonson (No. 4247)
222 Delaware A venue, Suite 900
Wilmington, DE 19801
Phone: (302) 655-5000
Fax: (302) 658-6395
-and-
GERSTEN SAVAGE, LLP
Paul Rachmuth
600 Lexington Avenue
New York, New York 10022
Telephone: (212) 752-9700
Facsimile: (212) 980-5192
Proposed Counsel for the Debtors and
Debtors in Possession
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EXHIBIT A
Proposed Order
Inre
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
CRDENTIA CORP., et al./ Case No. 10-
Debtors. (Joint Administration Requested)
ORDER PURSUANT TO 11 U.S.C. 341 AND 28 U.S.C. 156(c)
AUTHORIZING THE DEBTORS TO (I) FILE (A) CONSOLIDATED LIST OF
CREDITORS AND (B) CONSOLIDATED LIST OF DEBTORS' TOP TWENTY
CREDITORS, AND (II) PROVIDE NOTICES, INCLUDING NOTICES OF
COMMENCEMENT OF CASES AND SECTION 341 MEETING
Upon the motion (the "Motion")
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of the above-captioned debtors and debtors iu
possession (collectively, the "Debtors"), for entry of au order, pursuant to section 341 of the
Bankruptcy Code and section 156(c) of title 28 of the United States Code authorizing the
Debtors to (i) ftle (a) a consolidated list of creditors and (b) a consolidated list of the Debtors'
twenty (20) largest unsecured creditors; and (ii) complete all mailings of notices, including
notices of the coiiliilencement of these cases and of the meeting of creditors pursuant to section
341 of the Bankmptcy Code; and upon the Declaration of Rebecca Irish in Suppmt of the
Debtors' Chapter 11 Petitions and First Day Pleadings; and due and sufficient notice of the
Motion having been given; and it appearing that no other or further notice need be provided; and
upon the record herein; and it appearing that the relief requested by the Motion is in the best
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The Debtors, along with the last four digits of their federal tax iderrtification numbers, are: Crderrtia
Corp.(5701), ATS Universal, LLC (3980), Baker Anderson Christie, Inc. (3631), CRDE Corp. (2509),
GHS Acquisition Corporation (9736), Health Industry Professionals, LLC ( 4246), HIP Holding, Inc.
(3468), MP Health Corp. (4403), New Age Staffing, Inc. (1214) and Nurses Network, Inc. (6291). The
Debtors-' mailing address for purposes of these cases is 1964 Howell Branch Road, Ste. 206, Winter Park,
Florida 32792.
Capitalized terms not defined herein have the meanings ascribed to them in the Motion.
interest of the Debtors, their estates, their creditors and other parties in interest; and after due
deliberation and sufficient cause appearing therefor;
IT IS HEREBY ORDERED THAT:
1. The Motion is GRANTED.
2. The Debtors are authorized to file a consolidated list of creditors.
3. The Debtors are authorized to file a Consolidated Top 20 List.
4. The Debtors are authorized to file one declaration under Bank:mptcy Rule
1008 in connection with the consolidated list of creditors and the Consolidated Top 20 List.
5. The Debtors (or their agents) shall be, and hereby are, authorized to
complete all mailings in these cases which are required under the Bank:mptcy Code, the
Bank:mptcy Rules and the Local Rules of this Court.
6. The Debtors are authorized to take all actions necessary to implement this
Order.
7. This Court shall retain jurisdiction with respect to all matters arising from
or relating to the interpretation or implementation of this Order.
Dated: March , 2010
Wihnington, Delaware
THE
UNITED STATES BANKRUPTCY JUDGE
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