Case: Doc #:10 Filed: 01/25/16 Page 1 of 5 UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF MICHIGAN

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1 Case: Doc #:10 Filed: 01/25/16 Page 1 of 5 UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF MICHIGAN GREAT LAKES COMNET, INC. Case No ( ) COMLINK, L.L.C. Case No ( ) / Honorable DEBTORS MOTION FOR AN ORDER EXTENDING THE DEADLINE FOR FILING THEIR SCHEDULES AND STATEMENTS OF FINANCIAL AFFAIRS Great Lakes Comnet, Inc. ( GLC ) and Comlink, L.L.C. ( Comlink ; and collectively with GLC, the Debtors ), by and through their proposed counsel, Miller, Canfield, Paddock & Stone, PLC ( Miller Canfield ), each hereby moves this Court for entry of an order, pursuant to Federal Rule of Bankruptcy Procedure 1007(c), extending the deadline for filing the Debtors' Schedules and Statements of Financial Affairs by 21 days to and including February 29, In support of this Motion, the Debtors incorporate the Declaration of John Summersett in Support of Chapter 11 Petitions and First Day Motions (the Summersett Declaration ), filed contemporaneously herewith, and state as follows. BACKGROUND AND JURISDICTION 1. On January 25, 2016 (the Petition Date ), the Debtors commenced their reorganization cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy Code, 11 U.S.C. 101, et seq. (the Bankruptcy Code ).

2 Case: Doc #:10 Filed: 01/25/16 Page 2 of 5 2. The Debtors continue in possession of their property and are operating and managing their businesses, as debtors in possession, pursuant to 1107 and 1108 of the Bankruptcy Code. 3. This Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and Venue of this case and this Motion in this District is proper pursuant to 28 U.S.C and This is a core proceeding pursuant to 28 U.S.C. 157(b)(2)(A). 4. The factual background relating to the Debtors businesses and the commencement of these chapter 11 cases is set forth in detail in the Summersett Declaration. 5. GLC, based in East Lansing, Michigan, owns and operates a 6,500 mile fiber network serving the carrier and enterprise sectors in Michigan, with the network extending to Ohio, Indiana, Illinois, Wisconsin, and Minnesota. GLC s services include transport, dark fiber sales, cloud and datacenter operations, toll resale, toll routes, local switching, tandem switching and SS7. 1 Its fiber and data center-related customers include Verizon, Spectrum Health, Consumers Energy, Google, and the City of East Lansing. Its fiber network borders or serves key Michigan markets, such as Detroit, Grand Rapids, Lansing, and Ann Arbor. GLC provides telecommunications services to telecommunications carrier customers. GLC provides tandem switching and tandem transport services through its tandem switch located in Westphalia, Michigan. 6. GLC has two wholly-owned subsidiaries: Comlink and Clinton County Telephone Company ( CCTC ). CCTC serves residential and business customers through its two whollyowned subsidiaries: Westphalia Telephone Company ( WTC ), operating across the towns of Westphalia, Portland, St. Johns, and Dewitt, Michigan, serving nearly 850 residential and 75 1 Signaling System 7, or SS7 for short, refers to the basic services provided to establish and route telephone calls, along with related services (e.g., billing)

3 Case: Doc #:10 Filed: 01/25/16 Page 3 of 5 business customers with voice, data, and video services and Westphalia Broadband, Inc. ( WBI ), offering triple play services with nearly 875 customers, including over 235 business customers across the same geographic territory. CCTC, WTC and WBI are non-debtor subsidiaries and affiliates of GLC and are not participants in these bankruptcy cases. 7. Comlink provides data and communication services, including dedicated ultrahigh-speed bandwidth data transmission, Ethernet private line services and virtual private network services, cloud-based and colocation data center services, and data management services to Consumers Energy, several hospital systems, municipalities and state correctional facilities. Comlink owns and operates a portion of GLC s fiber network and the majority of its data center assets, servicing enterprise and carrier customers. RELIEF REQUESTED AND BASIS FOR RELIEF 8. By this Motion, the Debtors seek a 21-day extension of the deadline for filing their schedules of assets and liabilities and statement of financial affairs required under Federal Rule of Bankruptcy Procedure 1007(b)(1) (collectively, the Schedules and Statements ). The current deadline is February 8, See Rule 1007(c). The requested extension would be through February 29, Bankruptcy Rule 1007(c) authorizes the Court to grant an extension of the date by which the Schedules and Statements must be filed pursuant to Bankruptcy Rule 1007 on motion for cause shown. 10. Cause exists for granting a limited extension of time to file the Schedules and Statements. The Debtors have approximately one thousand creditors and other parties-ininterest. The Debtors also are party to approximately two thousand contracts and unexpired leases. Given the size and complexity of the Debtors operations, and the fact that certain prepetition invoices have not been received and/or entered into the Debtors financial systems, - 3 -

4 Case: Doc #:10 Filed: 01/25/16 Page 4 of 5 the Debtors have not had the opportunity to gather the necessary information to prepare and file their respective Schedules and Statements. Thus, the Debtors believe they will be unable to complete and file the Schedules and Statements by the current deadline due to (a) the complexity and volume of their financial affairs, and (b) the general press of business attendant to the commencement of the Debtors chapter 11 cases. 11. The procedures proposed herein are similar to procedures approved by courts in this jurisdiction and elsewhere. See, e.g., In re Sturgis Iron & Metal Co., Case No , Doc. No. 103 (Bankr. W.D. Mich. April 17, 2008); In re Family Christian, LLC, Case No jtg, Doc. No. 108 (Bankr. W.D. Mich. Feb. 19, 2015). NOTICE 12. Notice of this Motion has been given to the following parties, or in lieu thereof, to their counsel: (a) United States Trustee, (b) the Debtors secured lender; (c) the Debtors 20 largest unsecured creditors, and (d) any parties that have filed notices of appearance or requests for notice. In light of the nature of the relief requested, the Debtors respectfully submit that no further notice is necessary. WHEREFORE, the Debtor respectfully requests that this Court (a) enter an order in form similar to the proposed order attached hereto as Exhibit A granting the relief requested herein and (b) grant the Debtors such other and further relief as is just and proper

5 Case: Doc #:10 Filed: 01/25/16 Page 5 of 5 Respectfully Submitted, MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. By: /s/ Stephen S. LaPlante Timothy A. Fusco (P13768) Stephen S. LaPlante (P48063) Proposed Attorneys for the Debtors 150 West Jefferson, Suite 2500 Detroit, MI (313) laplante@millercanfield.com Dated: January 25,

6 Case: Doc #:10-1 Filed: 01/25/16 Page 1 of 2 EXHIBIT A UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF MICHIGAN GREAT LAKES COMNET, INC. Case No ( ) COMLINK, L.L.C. Case No ( ) / Honorable ORDER EXTENDING THE DEADLINE FOR FILING THEIR SCHEDULES AND STATEMENTS OF FINANCIAL AFFAIRS Before the Court is the Debtors Motion for an Order Extending the Deadline for Filing Their Schedules and Statements of Financial Affairs filed on January 25, 2016 (the Motion ). The Court having considered the Motion, the Declaration of John Summersett in Support of Chapter 11 Petitions and First Day Motions, and the record in this case, and it appearing to the Court that (a) the Court has jurisdiction over this proceeding pursuant to 28 U.S.C. 157 and 1334; (b) this is a core proceeding pursuant to 28 U.S.C. 157(b)(2)(A); (c) notice of the Motion appears sufficient under the circumstances; and (d) good and sufficient cause exists for the relief granted herein, Accordingly, it is hereby ORDERED as follows: 1. The Motion is GRANTED pursuant to the terms of this Order. 2 2 Capitalized terms not otherwise defined herein have the meanings set forth in the Motion.

7 Case: Doc #:10-1 Filed: 01/25/16 Page 2 of 2 2. The deadline under Bankruptcy Rule 1007(c) for filing the Debtors Schedules and Statements of Financial Affairs is extended to and through February 29, END OF ORDER Order prepared and submitted by: Timothy A. Fusco (P13768) Stephen S. LaPlante (P48063) Proposed Attorneys for the Debtors 150 West Jefferson, Suite 2500 Detroit, MI (313) laplante@millercanfield.com Proposed Attorneys to the Debtors and Debtors-in-Possession