Hearing Date: TBD Objection Deadline: TBD

Todd M. Galante (TG-5532) Jason C. DiBattista (JD-2859) LECLAIRRYAN, A PROFESSIONAL CORPORATION 830 Third Avenue Fifth Floor New York, New York 10022 Telephone: (212) 430-8020 Facsimile: (212) 430-8079 Counsel for F&G Mechanical Corporation and Meadowlands Fire Protection UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------- x : In re: : : LEHR CONSTRUCTION CORP., : : Debtor. : : : ------------------------------------------------------------- x

Chapter 11 Case No. 11-10723 (SHL)

MOTION TO SHORTEN TIME FOR NOTICE OF MOTION OF F&G MECHANCIAL CORPORATION AND MEADOWLANDS FIRE PROTECTION FOR AN ORDER PURSUANT TO 11 U.S.C. 503(b)(1), 507(a), 365(d)(2), AND 362(d)(1) FOR AN ORDER (I) COMPELLING IMMEDIATE PAYMENT OF POST-PETITION ADMINISTRATIVE EXPENSE CLAIMS; AND (II) COMPELLING THE DEBTOR TO ASSUME OR REJECT EXECUTORY CONTRACTS OR, IN THE ALTERNATIVE, MODIFYING THE AUTOMATIC STAY TO PERMIT MOVANTS TO TERMINATE THE EXECUTORY CONTRACTS IN THEIR SOLE DISCRETION F&G Mechanical Corporation (F&G) and Meadowlands Fire Protection (MFP), by and through their undersigned counsel, hereby move this Court (the Motion to Shorten Time) for entry of an order shortening time for notice of the motion of F&G and MFP for an order pursuant to sections 503(b)(1), 507(a), 365(d)(2) and 362(d)(1) of Chapter 11 of Title 11, United States Code (the Bankruptcy Code): (i) compelling allowance and immediate payment of post-

petition administrative expense claims; and (ii) compelling Lehr Construction Corporation (the Debtor) to assume or reject certain executory contracts or, in the alternative, modifying the automatic stay to permit F&G and MFP to terminate the executory contracts (the Motion to Compel). In support thereof, F&G and MFP respectfully state as follows: BASIS OF REQUEST FOR SHORTENED TIME 1. As set forth in the Motion to Compel, F&G and MFP have been providing the

Debtor with critical goods, services and materials in connection with the Project1 since well before the Petition Date, and continuing thereafter through the present time, but have yet to be paid anything on account of its Purchase Orders and Invoice. 2. In the aggregate, F&G and MFP have provided over $1.1 million of goods,

services and materials to the Debtor from Project inception through the present time, and those amounts continue to accrue at an alarming rate on a daily basis as a result of F&Gs and MFPs continued participation in the Project. 3. As a result of this massive credit outlay, it is absolutely essential that F&G and

MFP obtain a hearing date as soon as possible with respect to the Motion to Compel. Specifically, F&G and MFP request that the Court schedule a hearing on an emergency basis as soon as possible, but in no case later than March 23, 2011 at 11:00 a.m., the next scheduled hearing date in this Chapter 11 Case. 4. Shortening notice on the hearing with respect to the Motion to Compel will cause

no harm whatsoever to the Debtor or any other party-in-interest. On the other hand, F&G and MFP stand to suffer irreparable harm if they are denied an opportunity to be heard on the Motion to Compel as soon as possible, for the reasons set forth therein.

Capitalized terms used herein but not otherwise defined shall have the meanings ascribed to them in the Motion to Compel.
1

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5.

Based on the foregoing, F&G and MFP respectfully request that this Court grant

the Motion to Shorten Time, shorten the time period on its request to hold a hearing on the Motion to Compel, and schedule a hearing as soon as possible, but in no case later than March 23, 2011, at 11:00 a.m. (ET). 6. No previous application for the relief requested herein has been made to this or

any other Court. CONCLUSION WHEREFORE, MFP and F&G respectfully request that the Court enter an order in the form submitted herewith granting the Motion to Shorten Time, scheduling a hearing on the Motion to Compel on an emergency basis, as soon as possible, and granting such other and further relief as this Court deems just and proper. Dated: March 14, 2011 Respectfully submitted,

LECLAIRRYAN,
A Professional Corporation By: /s/ Jason C. DiBattista Jason C. DiBattista (JD-2859) Todd M. Galante (TG-5532) 830 Third Avenue, Fifth Floor New York, New York 7102 Telephone: (212) 430-8020 Facsimile: (212) 430-8079 Counsel for F&G Mechanical Corporation and Meadowlands Fire Protection

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ------------------------------------------------------------- x : In re: : : LEHR CONSTRUCTION CORP., : : Debtor. : : : ------------------------------------------------------------- x

Chapter 11 Case No. 11-10723 (SHL)

ORDER SHORTENING TIME FOR NOTICE OF MOTION OF F&G MECHANCIAL CORPORATION AND MEADOWLANDS FIRE PROTECTION FOR AN ORDER PURSUANT TO 11 U.S.C. 503(b)(1), 507(a), 365(d)(2), AND 362(d)(1) FOR AN ORDER (I) COMPELLING IMMEDIATE PAYMENT OF POST-PETITION ADMINISTRATIVE EXPENSE CLAIMS; AND (II) COMPELLING THE DEBTOR TO ASSUME OR REJECT EXECUTORY CONTRACTS OR, IN THE ALTERNATIVE, MODIFYING THE AUTOMATIC STAY TO PERMIT MOVANTS TO TERMINATE THE EXECUTORY CONTRACTS AT THEIR SOLE DISCRETION THIS MATTER been brought before the Court upon the motion of F&G Mechanical Corporation (F&G) and Meadowlands Fire Protection (MFP) for entry of an order shortening time for notice of the motion of F&G and MFP for an order pursuant to sections 503(b)(1), 507(a), 365(d)(2) and 362(d)(1) of Chapter 11 of Title 11, United States Code: (i) compelling allowance and immediate payment of post-petition administrative expense claims; and (ii) compelling Lehr Construction Corporation (the Debtor) to assume or reject certain executory contracts or, in the alternative, modifying the automatic stay to permit F&G and MFP to terminate the executory contracts in their sole discretion (the Motion to Compel); and it appearing that good cause exists for shortening and limiting the notice requirements with respect to the Motion to Compel, it is hereby: ORDERED that notice on the Motion to Compel is hereby shortened and limited as provided herein; and it is further

ORDERED that the following shall constitute good and sufficient service and notice of this Order and of the Motion to Compel, and of the hearing hereby scheduled thereon: (a) the filing of the Motion to Compel and this Order electronically on the Courts docket such that they are available on the Courts website; and (b) service via e-mail, facsimile transmission and/or overnight mail of the Motion to Compel and this Order upon (i) the Office of the United States Trustee; (ii) counsel to the Debtor; (iii) counsel to any statutory committees appointed in the Chapter 11 Case; and (iv) any parties that have filed requests for service of pleadings in this case; and it is further ORDERED that objections, if any, including affidavits and memoranda, to the relief sought in the Motion to Compel must (a) be filed with the Clerk of the Bankruptcy Court in accordance with the Standing General Order of the Bankruptcy Court for the Southern District of New York entered on January 19, 2001, and Establishing Procedures for Electronic Filing; (b) and be received in the Chambers of the Honorable Sean H. Lane, United States Bankruptcy Judge, United States Bankruptcy Court, One Bowling Green, NY, NY 10004; and (c) be served via e-mail, facsimile transmission and/or hand delivery upon LeClairRyan, A Professional Corporation, One Riverfront Plaza, 1037 Raymond Boulevard, Newark, New Jersey 07102, Attention: Todd M. Galante, Esq. and Jason C. DiBattista, Esq.; counsel to MFP and F&G (d) and be served via e-mail, facsimile transmission and/or hand delivery upon the Office of the United States Trustee, no later than _____________, 2011, at 4:00 p.m. (EST); and it is further ORDERED that a hearing on the Motion to Compel will be held on _____________, 2011 at ___:00 a.m./p.m. before the Honorable Sean H. Lane, Courtroom #701, United States Bankruptcy Judge, United States Bankruptcy Court, Alexander Hamilton Customs House, 1 Bowling Green, New York, New York 10004.

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Dated: New York, New York March __, 2011 _________________________________________ THE HONORABLE SEAN H. LANE UNITED STATES BANKRUPTCY JUDGE

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