IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION -----------------------------------------------------------------------IN RE: ) ) Chapter 11 CHURCH STREET

HEALTH MANAGEMENT, LLC, ) et al. 1 ) Case No. 12-01573 ) Debtors ) (Jointly Administered) -----------------------------------------------------------------------EXPEDITED MOTION TO ENTER ORDER FURTHER MODIFYING FINAL DIP ORDER TO RESET CLOSING DATE FOR THE PROPOSED SALE OF SUBSTANTIALLY ALL OF THE DEBTORS’ ASSETS Relief Sought and Grounds for Expediting Relief 1. Church Street Health Management, LLC (“CSHM”) and its affiliated debtors in

the above-captioned chapter 11 bankruptcy cases, as debtors in possession (collectively, the “Debtors”), hereby move for entry of the proposed Order Further Modifying Final DIP Order To Reset Closing Date For the Proposed Sale of Substantially All of the Debtors Assets (the “Modification Order”), filed herewith, relating to the Final Order (I) Authorizing the Debtors to (A) Obtain Post Petition Secured Financing and (B) Utilize Cash Collateral, (II) Granting Liens and Super Priority Administrative Expense Status, (III) Granting Adequate Protection and (IV) Modifying the Automatic Stay entered by the Court on March 16, 2012 [Docket No. 187] (the “Final DIP Order”), as amended by the Agreed Order Modifying Final DIP Order and Bidding Procedures Order To Reset Certain Dates and Deadlines Related To Postpetition Financing and Proposed Sale of Substantially All of the Debtors Assets entered by the Court on April 16, 2012 [Docket No. 271] (the “Agreed Order,” and together with the Final DIP Order, the “DIP Orders”).

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The Debtors (with the last four digits of each Debtor’s federal tax identification number and chapter 11 case number), are: Church Street Health Management, LLC (2335; Case No. 12-01573), Small Smiles Holding Company, LLC (4993; Case No. 12-01574), FORBA NY, LLC (8013; Case No. 12-01575), FORBA Services, Inc. (6506; Case No. 12-01577), EEHC, Inc. (4973; Case No. 12-01576).

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2.

The Modification Order resets the Closing Date (as defined in the Final DIP

Order) from May 30, 2012 to May 31, 2012. Expedited treatment of the proposed Modification Order is necessary because the Closing Date will occur prior to the next regularly scheduled omnibus hearing. Additionally, the proposed Modification Order is agreeable to all the major constituencies in these cases: the Debtors, Garrison Loan Agency Services LLC (and its affiliates) as administrative agent and collateral agent (in such capacities, the “DIP Agent”), CIT Healthcare, LLC, as agent (the “Agent to the Prepetition Secured Lenders”), CSHM LLC (the “Stalking Horse”), the Office of the United States Trustee, and the Official Committee of Unsecured Creditors (the “Committee”). 3. Notice of this Motion (which includes the proposed Modification Order and the

letter amendments to the DIP Credit Agreement) has been given to the Limited Notice List by ECF on parties signed up for ECF, and by facsimile or overnight mail for parties not signed up for ECF. 4. The Debtors ask that the Court hear this matter as soon as practicable during the

week of May 7.

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WHEREFORE, the Debtors respectfully request that the Court grant this motion and schedule a hearing on entry of the Modification Order, and grant such other and further relief as is just and proper. Dated: May 7, 2012 /s/ Katie G. Stenberg John C. Tishler, BPR No. 13441 Katie G. Stenberg, BPR No. 22301 Robert P. Sweeter, BPR No. 28859 WALLER LANSDEN DORTCH & DAVIS, LLP 511 Union Street, Suite 2700 Nashville, TN 37219 Telephone: (615) 244-6380 Facsimile: (615) 244-6804 Email: john.tishler@wallerlaw.com katie.stenberg@wallerlaw.com robert.sweeter@wallerlaw.com Attorneys for the Debtors and Debtors in Possession

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