1 PETER C. ANDERSON United States Trustee 2 TERRI HAWKINS-ANDERSEN Assistant U.S. Trustee 3 TIMOTHY J.

FARRIS Senior Trial Attorney - SBN 102678 4 ELIZABETH A. LOSSING Trial Attorney - SBN 144100 5 OFFICE OF THE UNITED STATES TRUSTEE 3685 Main Street, Suite 300 6 Riverside, CA 92501 Telephone: (951) 276-6990 7 Facsimile: (951) 276-6973 8 9 10 11 12 In re: 13 14 15 16 17 18 19 20 21 22 23 TO THE HONORABLE PETER H. CARROLL, UNITED STATES BANKRUPTCY 24 JUDGE FOR THE CENTRAL DISTRICT OF CALIFORNIA, THE DEBTORS AND 25 DEBTORS IN POSSESSION, THE AD HOC COMMITTEE OF EQUITY HOLDERS, ITS 26 COUNSEL OF RECORD, AND ALL PARTIES REQUESTING SPECIAL NOTICE: 27 The United States Trustee for Region 16, (hereinafter U.S. 28 1 UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION ) ) NATIONAL R.V. HOLDINGS, INC., ) a Delaware corporation; and ) NATIONAL R.V., INC., a ) California corporation, ) ) ) ) ) ) ) ) ) ) ) Debtor(s). ) ) ) ) ______________________________) Case No. 6:07-17941-PC Chapter 11 OPPOSITION OF THE UNITED STATES TRUSTEE TO AD HOC COMMITTEE OF EQUITY HOLDERS MOTION PURSUANT TO F.R.B.P. 9006 AND LOCAL RULE 9075-1 (b) TO SHORTEN TIME OR FOR ALTERNATIVE DATE ON HEARING REGARDING MOTION OF AD HOC COMMITTEE OF EQUITY HOLDERS FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS DATE: None set TIME: None set COURTROOM: "303" 3420 Twelfth Street Riverside, CA 92501

1 Trustee), opposes the Motion Pursuant To F.R.B.P. 9006 And Local 2 Rule 9075-1(b) To Shorten Time Or For Alternative Date On Hearing 3 Regarding Motion Of Ad Hoc Committee Of Equity Holders For

4 Reconsideration Of Order Denying Appointment Of Official Committee 5 Of Equity Holders, (hereinafter Motion To Shorten Time), brought 6 by the Ad Hoc Committee Of Equity Holders, (hereinafter Ad Hoc 7 Committee), and opposed by the Official Committee Of Unsecured 8 Creditors, (hereinafter Creditors Committee), as follows: 9 1. While the Ad Hoc Committees Motion For Reconsideration Of

10 Order Denying Appointment Of Official Committee Of Equity Holders 11 appears to be an attempt to ask the Bankruptcy Court to go over the 12 same ground that was plowed ad infinitum, ad nauseum both in the Ad 13 Hoc Committees numerous e-mails to the Office of the United States 14 Trustee and in the pleadings already on file with the United States 15 Bankruptcy Court with respect to the prior shortened time hearing on 16 the Motion To Appoint An Official Committee Of Equity Holders, 17 previously denied by this Honorable Court, the Office of the U.S. 18 Trustee is trying to leave no stone unturned in analyzing this 19 issue. 20 Debtors The Office of the U.S. Trustee has already spoken to counsel regarding the allegation in the that there are

21 sufficiently 22 notwithstanding

valuable the

assets

Holdings receivable

estate, to make

inter-company

account

23 Holdings a solvent estate.

So far, it appears that the Debtor

24 contests this allegation, but a final response has not yet been had. 25 The Office of the U.S. Trustee needs sufficient time to thoroughly 26 investigate this allegation. Shortening time for hearing on the

27 Reconsideration Motion to March 26, 2008 will not afford the Office 28 of the U.S. Trustee sufficient time to fully investigate this 2

1 matter.

Indeed, if the requested shortening were granted and the 14

2 day response time were maintained, then the responses would be due 3 yesterday! 4 2. The Office of the U.S. Trustee also opposes shortening time

5 on the hearing to April 1, April 7, April 8 or April 9, 2008 as 6 well. The First Meeting of Creditors has been continued to April 8, The Office of the U.S. Trustee hopes to resolve issues at that respect to time to and the place, including the

7 2008 at 2:30 p.m. 8 several 9 Debtors 10 whether factual

intentions the Debtors

with

inter-company

claims, an

intend

substantively

consolidate,

11 exhaustive breakdown of the assets and allocation between the 12 estates, etc. Had counsel for the Ad Hoc Committee, or even one of

13 the Ad Hoc Committees representatives been at the First Meeting of 14 Creditors and requested a shorter time period, the First Meeting of 15 Creditors would have been continued to an earlier date. As it was,

16 no one objected to the continuance to April 8, 2008 as the Debtor 17 announced its intention through its counsel to have a Plan on file 18 by March 31, 2008. Shortening time even to April 9, 2008 will not

19 allow the Office of the U.S. Trustee to have the benefit of 20 questioning the Debtors Chief Financial Officer and Treasurer, 21 under oath, about these issues prior to the time a response to the 22 Reconsideration Motion will be required to be filed. 23 3. Subsequent to the denial of the Motion To Appoint An

24 Official Equity Holders Committee, the Ad Hoc Committee again 25 requested that the U.S. Trustee appoint an Official Equity Holders 26 Committee. The U.S. Trustee is presently evaluating the request and 27 needs the information requested from the Debtors to complete that 28 evaluation. Shortening time on the Reconsideration Motion works a 3

1 substantial hardship on the Riverside Office of the U.S. Trustee as 2 it takes away valuable time in researching and evaluating the Ad Hoc 3 Committees request. 4 4. As the U.S. Trustees judgment in denying the request to

5 appoint an Equity Holders Committee has been questioned, the U.S. 6 Trustee has a very valid interest in reviewing the pleadings filed 7 by the Riverside Office of the U.S. Trustee. This requires

8 additional time and shortening time would make this a much more 9 difficult task. 10 For all of the foregoing reasons, the U.S. Trustee respectfully

11 requests that this Honorable Court deny the Ad Hoc Committees 12 request to shorten time and, if the April 21, 2008 date works a 13 hardship on the counsel for the Ad Hoc Committee, then continue the 14 hearing to a date subsequent to April 21, 2008 when counsel will be 15 available. 16 17 DATED: March 13, 2008 18 19 /s/ Timothy J. Farris 20 By: 21 22 23 24 25 26 27 28 4 Timothy J. Farris Trial Attorney Respectfully submitted, PETER C. ANDERSON UNITED STATES TRUSTEE

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Dated: March 14, 2008

PROOF OF SERVICE BY MAIL STATE OF CALIFORNIA COUNTY OF RIVERSIDE

I am employed in the County of Riverside, State of California, in the Office of the United States Trustee under the supervision of a member of the bar of this Court at whose direction the service was made. I am over the age of 18 and not a party to the within action; and my business address is 3685 Main Street, Suite 300, Riverside, California 92501-2804. On March 14, 2008, I served the foregoing document described as, OPPOSTION OF THE UNITED STATES TRUSTEE TO AD HOC COMMITTEE OF EQUITY HOLDERS MOTION PURSUANT TO F.R.B.P. 9006 AND LOCAL RULE 9075-1 (b) TO SHORTEN TIME OR FOR ALTERNATIVE DATE ON HEARING REGARDING MOTION OF AD HOC COMMITTEE OF EQUITY HOLDERS FOR RECONSIDERATION OF ORDER DENYING APPOINTMENT OF OFFICIAL COMMITTEE OF EQUITY HOLDERS, on interested parties in this action by placing a true and correct copy thereof in a sealed envelope with first class postage thereon fully prepaid in the United States mail at Riverside, California, addressed as follows: COUNSEL FOR AD HOC COMMITTEE ALI M.M. MOJDEHI CHRISTINE E. BAUR BAKER & MC KENZIE LLP 12544 HIGH BLUFF DR. 3RD FLOOR SAN DIEGO, CA 92130 COUNSEL FOR OFFICIAL COMMITTE OF UNSECURED CREDITORS HAMID R. RAFATJOO PACHULSKI STANG ZIEHL & JONES LLP 10100 SANTA MONICA BLVD. 11TH FLOOR LOS ANGELES, CA 90067 DEBTOR NATIONAL R.V. HOLDINGS, INC. 3411 N. PERRIS BLVD PERRIS, CA 92571 COUNSEL FOR DEBTOR DAVID GUESS KLEE TUCHIN BOGDANOFF & STERN LLP 1999 AVENUE OF THE STARS, 39TH FLOOR LOS ANGELES, CA 90067

I declare under penalty of perjury that the foregoing is true and correct.

25 26 27 28 5
/s/ Pat Pezoldt Pat Pezoldt