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IN THE UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA In re: Steven F. Meldahl, Debtor. BKY No.: 12-46965

NOTICE OF HEARING AND MOTION FOR ORDER APPROVING SETTLEMENT TO: Parties in Interest as Specified in Local Rule 9013-3. 1. Steven F. Meldahl (Debtor) moves the Court for the relief requested below and

gives notice of hearing. 2. The court will hold a hearing on the Debtors request for relief on at 1:30 p.m. on

Tuesday, October 1, 2013 at the U.S. Bankruptcy Court, Federal Courthouse, Courtroom 2A, 316 North Robert Street, St. Paul, MN 55101, before the Honorable Gregory F. Kishel. 3. Any response to the motion must be filed and delivered not later than Thursday,

September 26, 2013, which is five days before the date set for the final hearing. UNLESS A RESPONSE OPPOSING THE MOTION IS TIMELY FILED BEFORE THE DEADLINES NOTED ABOVE, THE COURT MAY GRANT THE MOTION WITHOUT A HEARING. 4. This Court has jurisdiction over this motion pursuant to 28 U.S.C. 157 and

1334, Fed. R. Bank. P. 5005 and Local Rule 1070-1. This is a core proceeding. The petition commencing this Chapter 11 case was filed on December 12, 2012. The case is now pending in this Court. 5. This motion arises under Fed.R.Bank.P. 9019. This motion is filed under Local

Rules 2002-1 and 9013-1 through 9013-3 and served under Fed.R.Bankr.P 7004. The Debtor has

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reached a settlement agreement with one of its secured creditors, which agreement is described in this Motion. The secured creditor involved is JSRS Capital, LLC. 6. The Debtor made a Motion to approve a Settlement with JSRS, Inc., Docket No.

40 by a Motion filed February 14, 2013. The Committee of Unsecured Creditors objected to the proposed Settlement. The Motion was continued and not rescheduled for hearing. Thereafter, JSRS filed a Motion for relief from Stay, Docket No. 129, filed June 25, 2013. The parties have now reached a settlement. A copy of the Settlement Agreement is attached to this Motion as Exhibit A. The Settlement is subject to Bankruptcy Court approval. The terms of the Settlement are incorporated herein by reference. The Debtor believes that approval of the Settlement Agreement is in the best interest of the Debtor, the Estate and the creditors of the Debtor. 7. The Debtor has, with Court authorization, listed for sale both properties subject to

the Mortgage in favor of JSRS Capital, LLC. The Debtor believes the properties can be sold for amounts far in excess of the balance due JSRS Capital, LLC. 8. The Committee of Unsecured Creditors has indicated that it takes no position with

respect to the proposed Settlement Agreement. WHEREFORE, Debtor moves the Court for an order authorizing and approving the Settlement between the Debtor and JSRS Capital, LLC and for such other and further relief as the Court deems just and equitable. Dated: September 4, 2013. /e/ Steven B. Nosek Steven B. Nosek, #79960 Attorney for Debtor 2855 Anthony Lane South, Suite 201 St. Anthony, MN 55418 (612) 335-919 snosek@noseklawfirm.com ATTORNEY FOR DEBTOR

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UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA In Re: BKY No.: 12-46965 Chapter 11

Steven F. Meldahl, Debtor. _____________________________________________________________________ CERTIFICATE OF SERVICE _____________________________________________________________________ I hereby certify that on September 4, 2013, I caused a copy of Notice of Hearing and Motion for Order Approving Settlement Agreement; Verification; Exhibit; and Proposed Order to be filed electronically with the Clerk of Court through ECF, and that ECF will send an e-notice of the electronic filing to the following: US Trustee: ustpregion12.mn.ecf@usdoj.gov, ecfbkup@comcast.net Orin J. Kipp: okipp@wilfordgeske.com, mboelen@wilfordgeske.com; lfrancis@wgcmn.com Michael E. Ridgway: mike.ridgway@usdoj.gov Rebecca S. Holschuh: Rebecca.holschuh@co.hennepin.mn.us, barb.besta@co.hennepin.mn.us, Suzanne.ryan@co.hennepin.mn.us Rebecca S. Christensen: rchristensen@eckberglammers.com Thomas Lallier: ECF_Notices@foleymansfield.com Richard L. Leighton: rick@leightonhetland.com Charles N. Nauen: cnnauen@locklaw.com, jmtrieber@locklaw.com Minneapolis City Attorneys Office P Sautter: Gregory.sautter@ci.minneapolis.mn.us Spencer J. Seamans: s.seamans@gurstel.com, p.moir@gurstel.com John F. Thomas: jthomas@foleymansfield.com, lberntsen@foleymansfield.com Steven T. Hetland: steve@leightonhetland.com John C. Thomas: jcthomas@foleymansfield.com, john@jcthomaslaw.com Jared D. Kemper: jkemper@dykema.com, shagstrom@dykema.com Dated this 4th day of September, 2013. /e/ Steven B. Nosek Steven B. Nosek, #79960 2855 Anthony Lane South, Suite 201 St. Anthony, MN 55418 (612) 335-9171 snosek@noseklawfirm.com ATTORNEY FOR DEBTOR

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IN THE UNITED STATES BANKRUPTCY COURT DISTRICT OF MINNESOTA In re: Steven F. Meldahl, Debtor. BKY NO.: 12-46965

ORDER ______________________________________________________________________________ The above-entitled matter came before the court on October 1, 2013, on the Debtors Motion Approving Settlement. Appearances were as noted in the Courts record. Based upon the proceedings on said date, the statements of counsel and all of the files and records herein, IT IS HEREBY ORDERED: 1. The Debtors Motion is GRANTED and the Debtor is authorized to enter into the Settlement Agreement which is APPROVED.

Dated:

____________________________________ Gregory F. Kishel Chief United States Bankruptcy Judge