NCS000562_OTHER_20160902

-STORMWATER.DIVISION CODING -SHEET
PERMIT NO.
Nc. 000s6;a
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
❑ COMPLIANCE
fR OTHER
DOC DATE
❑
YYYYM M D D

Received
IN THE UNITED STATES BANKRUPTCY COURT SEP - 2 2016
FOR THE DISTRICT OF DELAWARE
Land Quality Section
Asheville
In re: ) Chapter 11
HORSEHEAD HOLDING CORP., et al.,] ) Case No. 16-10287 (CSS)
(Jointly Administered)
Debtors. )
Objection Deadline: September 12, 2016 at 4:00 p.m. (prevailing Eastern Time)
Hearing: October 18, 2016 at 10.00 a.m. (prevailing Eastern Time)
NOTICE OF HEARING ON DEBTORS' SECOND MOTION FOR ENTRY
OF AN ORDER (A) ENLARGING THE PERIOD WITHIN WHICH THE
DEBTORS MAY REMOVE ACTIONS AND (B) GRANTING RELATEDRELIEF
TO: (a) the Office of the United States Trustee for the District of Delaware (the "U.S. Trustee"); (b) counsel to
the official committee of unsecured creditors; (c) the Office of the United States Attorney for the District of
Delaware; (d) the Internal Revenue Service; (e) the Securities and Exchange Commission; (f) counsel to
Macquarie Bank Limited; (g) the indenture trustee under the Debtors' 10.50% senior secured notes; (h) the
indenture trustee under the Debtors' 9.00% senior unsecured notes; (i) the indenture trustee under the
Debtors' 3.80% convertible senior notes; 0) B, nco Bilbao Vizcaya Argentaria, S.A.; (k) counsel to PNC
Bank, National Association; (1) counsel for the lenders under the Debtors' debtor -in -possession financing
facility (such facility the "DIP Facility") and the ad hoc group of holders of the Debtors' secured notes; (m)
the agent to the DIP Facility; (n) Richter Advisory Group Inc. in its capacity as information officer in the
Debtors' foreign recognition proceedings; (o) the non -debtor parties to the Actions; and (p) any party that
has requested notice pursuant to Bankruptcy Rule 2002.
On August 29, 2016, the above captioned debtors and debtors in possession
(collectively, the "Debtors") filed the attached Debtors' Second Motion for Entry of an Order
(A) Enlarging the Period Within Which the Debtors May Remove Actions and (B) Granting
Related Relief (the "Motion') with the United States Bankruptcy Court for the District of
Delaware, 824 Market Street, Wilmington, Delaware 19801 (the "Bankruptcy Court').
OBJECTIONS AND RESPONSES TO THE MOTION, IF ANY, MUST BE IN
WRITING AND FILED WITH THE BANKRUPTCY COURT NO LATER THAN
1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax
identification number, are: Horsehead Holding Corp. (7377); Horsehead Corporation (7346); Horsehead Metal
Products, LLC (6504); The International Metals Reclamation Company, LLC (8892); and Zochem Inc. (4475).
The Debtors' principal offices are located at 4955 Steubenville Pike, Suite 405, Pittsburgh, Pennsylvania 15205.
DOCS DE:209302.1 37010/001

4:00 P.M., PREVAILING EASTERN TIME, ON SEPTEMBER 12, 2016. At the same time,
you must also serve a copy of the response or objection upon: (a) the Debtors, 4955 Steubenville
Pike, Suite 405, Pittsburgh, PA 15205, Attn: Gary R. Whitaker; (b) co -counsel to the Debtors,
(i) Pachulski Stang Ziehl & Jones LLP, 919 North Market Street, 17th Floor, Wilmington, DE
19801, Attn: Laura Davis Jones, Esq., [e-mail], and (ii) Kirkland & Ellis LLP, 300
North LaSalle, Chicago, IL 60654, Attn: Ryan Preston Dahl, Esq., [e-mail];
and Angela M. Snell, Esq., [e-mail]; (c) counsel to the Prepetition Senior
Secured Notes Indenture Trustee and to the Prepetition Unsecured Note Indenture Trustee,
Waller Lansden Dortch & Davis, LLP, Nashville City Center, 511 Union Street, Suite 2700,
Nashville, TN 37219, Attn: Beth E. Vessel, Esq., [e-mail]; (d) counsel to
the Prepetition Macquarie Facility Agent, (i) Stroock & Stroock & Lavan LLP, 180 Maiden
Lane, New York, NY 10038-4982, Attn: Mark A. Speiser, Esq., [e-mail], and (ii)
Young Conaway Stargatt & Taylor, LLP, Rodney Square, 1000 North King Street, Wilmington,
DE 19801, Attn: Matthew B. Lunn, Esq., [e-mail]; (e) counsel to the Agent for the
DIP Facility, (i) Shipman & Goodwin LLP, One Constitution Plaza, Hartford, CT 06103-1919,
Attn.: Nathan Z. Plotkin, Esq., [e-mail], and (ii) Ashby & Geddes, P.A., 500
Delaware Avenue, P.O. Box 1150, Wilmington, DE 19899, Attn: William P. Bowden, Esq.,
[e-mail]; (f) counsel to the DIP Lenders Akin Gump Strauss Hauer & Feld
LLP, One Bryant Park, New York, NY 10036, Attn: Michael S. Stamer, Esq.,
[e-mail] and Meredith A. Lahaie, Esq., [e-mail]; (g) counsel
for PNC Bank, National Association, (i) Blank Rome LLP, One Logan Square, 130 North 18`h
Street, Philadelphia, PA 19103-6998, Attn: Michael C. Graziano, Esq.,
[e-mail], and (ii) Blank Rome LLP, 1201 Market Street, Suite 800,
2
DOCs DE:2093o2.1 37010/001

13
Wilmington, DE
19801, Attn:
Regina Stango Kelbon,
Esq., [e-mail];
(h) counsel to the
Committee of
Unsecured Creditors, (i)
Lowenstein Sandier LLP, 65
Livingston Avenue, Roseland, NJ 07068, Attn: Bruce Buechler, Esq.,
[e-mail], and (ii) Drinker Biddle & Reath LLP, 222 Delaware Avenue, Suite
1410, Wilmington, DE 19801, Attn: Howard A. Cohen, Esq., [e-mail]; and 0)
Office of the U.S. Trustee, 844 King Street, Suite 2207, Lockbox 35, Wilmington, DE 19801,
Attn: Timothy J. Fox, Jr., Esq., [e-mail].
A HEARING ON THE MOTION WILL BE HELD BEFORE THE
HONORABLE CHRISTOPHER S. SONTCHI AT THE UNITED STATES
BANKRUPTCY COURT, 824 MARKET STREET, FIFTH FLOOR, COURTROOM #6,
WLLMINGTON, DELAWARE 19801 ON OCTOBER 18, 2016 AT 10:00 A.M.
PREVAILING EASTERN TIME.
(Remainder of Page Intentionally Blank)
3
DOGS DE:209302.1 37010/001

IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE
COURT MAY GRANT THE RELIEF REQUESTED IN THE MOTION WITHOUT
FURTHER NOTICE OR HEARING.
Wilmington, Delaware Is/Jose h M. Mulvihill
Dated: August 29, 2016 Laura Davis Jones (DE Bar No. 2436)
James E. O'Neill (DE Bar No. 4042)
Joseph M. Mulvihill (DE Bar No. 6061)
PACHULSKI STANG ZIEHL & JONES LLP
919 North Market Street, 17th Floor
P.O. Box 8705
Wilmington, Delaware 19899-8705 (Courier 19801)
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
-and-
James H.M. Sprayregen, P.C.
Patrick J. Nash Jr., P.C. (admitted pro hac vice)
Ryan Preston Dahl (admitted pro hac vice)
Angela M. Snell (admitted pro hac vice)
IQRKLAND & ELLI[S LLP
KIRKLAND & ELLIS INTERNATIONAL LLP
300 North LaSalle
Chicago, Illinois 60654
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Co -Counsel for the Debtors and Debtors in Possession
DOCS DE:206338.1 37010.001
4
DOGS DE:204302.1 37010/001

s
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter I l
)
HORSEHEAD HOLDING CORP., et al.,' ) Case No. 16-10287 (CSS)
Debtors. ) Jointly Administered
Objection Deadline: September 12, 2016 at 4:00 P.M. (Prevailing Eastern Time)
Hearing: October 18, 2016 at 10:00 A.M. (Prevailing Eastern Time)
DEBTORS' SECOND MOTION FOR ENTRY OF AN ORDER
(A) ENLARGING THE PERIOD WITHIN WHICH THE DEBTORS
MAY REMOVE ACTIONS AND (B) GRANTING RELATED RELIEF
The above -captioned debtors and debtors in possession (collectively, the "Debtors") file
this motion (the "Motion") for entry of an order (the "Order"), substantially in the form attached
hereto as Exhibit A: (a) further enlarging the period within -which the Debtors may remove
actions (collectively, the "Actions") pursuant to 28 U.S.C. § 1452 and Rule 9027 of the Federal
Rules of Bankruptcy Procedure (the `Bankruptcy Rules") by 120 days, up to and including
December 28, 2016, without prejudice to the Debtors' right to seek additional extensions of the
period within which the Debtors may remove actions; and (b) granting related relief. In support
of this Motion, the Debtors respectfully state as follows:
Jurisdiction and Venue
1. The United States Bankruptcy Court for the District of Delaware (the "Court")
has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the
The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification
number, are: Horsehead Holding Corp. (7377); Horsehead Corporation (7346); Horsehead Metal Products,
LLC (6504); The International Metals Reclamation Company, LLC (8892); and Zochem Inc. (4475).
The Debtors' principal offices are located at 4955 Steubenville Pike, Suite 405, Pittsburgh, Pennsylvania 15205.
1
KE 42900623.4

Amended Standing Order of Reference from the United States District Court for the District of
Delaware, dated February 29, 2012. This matter is a core proceeding within the meaning of
28 U.S.C. § 157(b)(2). The Debtors confirm their consent, pursuant to rule 9013-1(f) of the
Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the
District of Delaware (the "Local Rules"), to the entry of a final order by the Court in connection
with this Motion to the extent that it is later determined that the Court, absent consent of the
parties, cannot enter final orders or judgments in connection herewith consistent with Article 111
of the United States Constitution.
2. Venue in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409.
3. The statutory bases for the relief requested herein is section 1452 of title 28 of the
United States Code, 28 U.S.C. § 1452, Rules 9006 and 9027 of the Bankruptcy Rules, and
Local Rule 9006-2.
Relief Requested
4. By this Motion, the Debtors request entry of an order: (a) enlarging the period of
time set forth in Bankruptcy Rule 9027(a)(2)(A) during which the Debtors may seek removal of
the Actions pursuant to 28 U.S.C. § 1452 and Bankruptcy Rule 9027 (the "Removal Period") by
120 days, up to and including December 28, 2016, without prejudice to, the Debtors' right to seek
further extensions of the period of time during which the Debtors may seek removal of the
Actions;2 and (b) granting related relief.
2 The Debtors note that they have filed this Motion prior to the expiration of the current deadline for the
Removal Period. Pursuant to Local Rule 9006-2, "if a motion to extend the time to take any action is filed
before the expiration of the period prescribed by the [Bankruptcy] Code, the [Bankruptcy Rules], these
Local Rules or Court order, the time shall automatically be extended until the Court acts on the motion, without
the necessity for the entry of a bridge order." Accordingly, Local Rule 9006-2 automatically extends the
Removal Period pending the Court's hearing to consider the relief requested by this Motion.
2

•
•
Background
5. On February 2, 2016 (the "Petition Date"), each of the Debtors filed a petition
with this Court under chapter I 1 of the Bankruptcy Code. The Debtors' chapter 1 I cases have
been consolidated for procedural purposes only and are being jointly administered pursuant to
Bankruptcy Rule 1015(b) [Docket No. 49]. No party has requested the appointment of a trustee
or examiner in these chapter 11 cases. The Debtors continue to operate their businesses and
manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the
Bankruptcy Code. On February 16, 2016, the United States Trustee for the District of Delaware
appointed an official committee of unsecured creditors (the "Creditors' Committee") in these
chapter I I cases [Docket No. 129].
6. On April 8, 2016, the Debtors filed the Debtors' Motion for Entry of an Order (A)
Enlarging the Period Within Which the Debtors May Remove Actions and (B) Granting Related
Relief [Docket No. 4951 (the "Initial Extension Motion") requesting an extension of the time
within which the Debtors may seek removal of the Actions to and through August 30, 2016.
Subsequently, on April 29, 2016, the Court entered the Order (A) Enlarging the Period Within
Which the Debtors May Remove Actions and (B) Granting Related Relief [Docket No. 8411,
which granted the relief requested by the Initial Extension Motion.
" The Actions
7. The Debtors are involved in Actions in a number of jurisdictions, including in
Illinois, North Carolina, Pennsylvania, and Canada, and the Actions involve a variety of types of
cases, including tort, contract and labor litigation. On March 17, 2016, each of the Debtors filed
their Schedules of Assets and Liabilities and Statements of Financial Affairs [Docket Nos. 303-
3121 (the "Schedules"). As part of the Schedules, the Debtors identified the Actions of which the
Debtors are currently aware. In addition, on March 22, 2016, the Court entered the
3

Order (A) Setting a Bar Date for Filing Proofs of Claims, Including Claims Arising Under
Section 503(b)(9) of the Bankruptcy Code, (B) Setting a Bar Date for the Fling of Proofs of
Claim by Governmental Units, (C) Setting a Bar Date for the Filing of Administrative Expense
Claims, (D) Setting an Amended Schedules Bar Date, (E) Setting a Rejection Damages Bar Date,
(F) Approving the Form of and Manner for Filing Proofs of Claim, (G) Approving Notice of Bar
Dates, and (H) Granting Related Relief [Docket No. 3211 (the "Claims Bar Date Order")
Pursuant to the Claims Bar Date Order, the Court had set April 25, 2016 as the date by which
(a) the Debtors' creditors, including the non -debtor counterparties to the Actions and
(b) administrative claimants must each file proofs of claim. The Court had also set August 1,
2016 as the date by which governmental entities must file proofs of claim.
8. The Debtors are presently preparing to confirm their chapter 11 plan of
reorganization, for which a confirmation hearing is scheduled to begin on August 30, 2016. In
order to permit the Debtors to focus their resources on this critical matter, the Debtors therefore
request the limited extension of the Removal Period as provided herein.
Basis for Relief
9. Section 1452 of title 28 of the United States Code and Bankruptcy Rule 9027
govern the removal of pending civil actions related to chapter I 1 cases. Specifically, section
1452(a) provides:
A party may remove any claim or cause of action in a civil action other than a
proceeding before the United States Tax Court or a civil action by a governmental
unit to enforce such governmental unit's police or regulatory power, to the district
court for the district where such civil action is pending, if such district court has
jurisdiction of such claim or cause of action under section 1334 of this title.
28 U.S.C. § 1452(a).
10. Bankruptcy Rule 9027 sets forth the time periods for filing notices to remove
claims or causes of action. Specifically, Bankruptcy Rule 9027(a)(2) provides, in pertinent part:
2

•
If the claim or cause of action in a civil action is pending when a case under the
[Bankruptcy] Code is commenced, a notice of removal may be filed only within
the longest of (A) 90 days after the order for relief in the case under the
[Bankruptcy] Code, (B) 30 days after entry of an order terminating a stay, if the
claim or cause of action in a civil action has been stayed under § 362 of the
[Bankruptcy] Code, or (C) 30 days after a trustee qualifies in a chapter I
reorganization case but not later than 180 days after the order for relief.
Fed. R. Bankr. P. 9027(a)(2).
11. Bankruptcy Rule 9006 permits the Court to extend the period to remove actions
provided by Bankruptcy Rule 9027. Specifically, Bankruptcy Rule 9006(b)(1) provides, in
pertinent part:
[W]hen an act is required or allowed to be done at or within a
specified period by these rules or by a notice given thereunder or
by order of court, the court for cause shown may at any time in its
discretion ... with or without motion or notice order the period
enlarged if the request therefor is made before the expiration of the
period originally prescribed or as extended by a previous
order....
Fed. R. Bankr. P. 9006(b)(1).
12. It is well -settled that the Court is authorized to enlarge the Removal Period. See
Pacor, Inc. v. Higgins, 743 F.2d 984, 996 n.17 (3d Cir. 1984), overruled on other grids by
Things Remembered, Inc. v. _Petrarca, 516 U.S. 124, 134-35, 116 S.Ct. 494, 133 .L.Ed.2d.461
(1995) (holding the bankruptcy court's power to grant an extension of the removal period
pursuant to Bankruptcy Rule 9006(b) is "clear"); Caperton v. A.T. Massey Coal Co., Inc.,
251 B.R. 322, 325 (S.D.W. Va. 2000); (Bankruptcy Rule 9006 provides authority to enlarge time
periods for removing actions under Bankruptcy Rule 9027); In re_Jandous Elec. Constr. Corp.,
106 B.R. 48 (Bankr. S.D.N.Y. 1989) (period in which to file motion to remove may be expanded
pursuant to Bankruptcy Rule 9006); In re World Fin. Servs. Ctr., Inc., 81 B.R. 33, 39
(Bankr. S.D. Cal. 1987) (United States Supreme Court intended to give bankruptcy judges the

• 0
power to enlarge the filing periods under Bankruptcy Rule 9027(a) pursuant to
Bankruptcy Rule 9006(b)); Raff v. Gordon, 58 B.R. 988, 990 (E.D. Pa. 1986) (an expansion of
time to file notices of removal is authorized under the Bankruptcy Rules).
13. Absent the relief requested herein, the Removal Period will otherwise expire after
August 30, 2016. The Debtors' decision regarding whether to seek removal of any particular
Action depends on a number of factors, including: (a) the importance of the Action to the
expeditious resolution of these chapter 11 cases; (b) the time required to complete the Action in
its current venue; (c) the presence of federal subject matter jurisdiction in the proceeding that
may allow for one or more aspects thereof to be heard by a federal court; (d) the relationship
between the Action and matters to be considered in connection with the Debtors' pending
chapter i 1 plan (which is presently set for a confirmation hearing tomorrow, August 30th), the
claims allowance process, and the assumption or rejection of executory contracts and unexpired
leases; and (e) the progress made to date in the Action. To make the appropriate determination,
the Debtors must analyze each Action in light of such factors.
14. To date, the Debtors have not yet had an opportunity to determine conclusively
which Actions it will seek to remove. Since the commencement of these chapter 11 cases, the
Debtors have been focused on stabilizing their business operations, preparing the Schedules, and
negotiating the terms of critical postpetition financing and preparing, negotiating, soliciting and
preparing for the confirmation of a plan of reorganization that will maximize the value of the
Debtors' business operations for the benefit of all of their stakeholders. The Debtors have thus
been focused on addressing these time -critical matters and have been unable to fully analyze
each of the Actions and make the appropriate determinations concerning their removal.

15. The Debtors believe the extension requested herein will provide the Debtors with
sufficient time to make fully -informed decisions concerning the removal of the Actions and will
ensure that the Debtors' rights provided by 28 U.S.C. § 1452 can be exercised in an appropriate
manner. Alternately, if such an extension is not granted, the Debtors believe they may not have
sufficient time to properly evaluate removal of the Actions. Moreover, the rights of parties to the
Actions will not be unduly prejudiced by the Debtors' requested extension of the
Removal Period. If the Debtors ultimately seek to remove Actions pursuant to
Bankruptcy Rule 9027, parties will retain their rights to have such Actions remanded pursuant to
28 U.S.C. § 1452(b). Accordingly, the Debtors submit that cause exists for the relief requested
herein.
Notice
16. The Debtors will provide notice of this Application to the following parties or
their respective counsel, if known: (a) the Office of the United States Trustee for the District of
Delaware (the "U.S. Trustee"); (b) counsel to the official committee of unsecured creditors; (c)
the Office of the United States Attorney for the District of Delaware; (d) the Internal Revenue
Service; (e) the Securities and Exchange Commission; (f) counsel to Macquarie Bank Limited;
(g) the indenture'trustee under the Debtors' 10.50% senior secured notes; (h) the indenture
trustee under the- Debtors' 9.00% senior unsecured notes; (i) the indenture trustee under the
Debtors' 3.80% convertible senior notes; 0) Banco Bilbao Vizcaya Argentaria, S.A.; (k) counsel
to PNC Bank, National Association; (1) counsel for the lenders under the Debtors' debtor -in -
possession financing facility (such facility the "DIP Facility") and the ad hoc group of holders of
the Debtors' secured notes; (m) the agent to the DIP Facility; (n) Richter Advisory Group Inc. in
its capacity as information officer in the Debtors' foreign recognition proceedings; (o) the non -
debtor parties to the Actions; and (p) any party that has requested notice pursuant to Bankruptcy
7

0 i
Rule 2002. The Debtors submit that, in light of the nature of the relief requested, no other or
further notice need be given.
No Prior Reguest
17. Other than with respect to the Initial Extension Motion, no prior motion for the
relief requested herein has been made to this or any other court.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
8

•
•
WHEREFORE, for the reasons set forth hcrcin, the Debtors respectfully request entry of
an order, substantially in the form attached hereto as Exhibit A. (a) enlarging the
Removal Period for filing notices of removal of the Actions by 120 days, up to and including
December 28, 2016, without prejudice to the Debtors' right to seek further extensions of the time
for filing notices of removal; and (b) granting related relief.
Wilmington, Delaware Is/Joseph M. Mulvihill
Dated: August 29, 2016 Laura Davis Jones (DE Bar No. 2436)
James E. O'Neill (DE Bar No. 4042)
Joseph M. Mulvihill (DE Bar No. 6061)
PACHULSKI STANG ZIEHL & JONES LLP
919 North Market Street, 17th Floor
P.O. Box 8705
Wilmington, Delaware 19899-8705 (Courier 19801)
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
-and-
James H.M. Sprayregen, P.C.
Patrick J. Nash Jr., P.C. (admitted pro hac vice)
Ryan Preston Dahl (admitted pro hac vice)
KH; KLAND & ELLIS LLP
KnUMAND & ELLIS INTERNATIONAL LLP
300 North LaSalle
Chicago, Illinois 60654
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Co -Counsel for the
Debtors and Debtors in Possession
Z

•
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter l 1
In re: )
Case No. 16-10287 (CSS)
HORSEHEAD HOLDING CORP., et al,' }
} Jointly Administered
Debtors. )
} Re: Docket No.
ORDER (A) ENLARGING THE PERIOD WITHIN WHICH THE DEBTORS
MAY REMOVE ACTIONS AND (B) GRANTING RELATED RELIEF
Upon the motion (the "Motion")2 of the above -captioned debtors and debtors in
possession (collectively, the "Debtors") for entry of this order (the "Order"): (a) enlarging the
Removal Period for filing notices of removal of the Actions by 120 days, up to and including
August 30, 2016, without prejudice to the Debtors' right to seek further extensions; and
(b) granting related relief; all as more fully set forth in the Motion; and this Court having
jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing
Order of Reference from the United States District Court for the District of Delaware, dated
February 29, 2012; and this Court having found that this is a core proceeding pursuant to
28 U.S.C. § 157(b)(2), and that this Court may enter a final order consistent with Article III of
the United States Constitution; and this Court having found that venue of this proceeding and the
Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having
found that the relief requested in the Motion is in the best interests of the Debtors' estates, their
creditors, and other parties in interest; and this Court having found that the Debtors' notice of the
The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification
number, are: Horsehead Holding Corp. (7377); Horsehead Corporation (7346); Horsehead Metal Products,
LLC (6504); The International Metals Reclamation Company, LLC (8892); and Zochem Inc. (4475).
The Debtors' principal offices are located at 4955 Steubenville Pike, Suite 405, Pittsburgh, Pennsylvania 15205.
2 All capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Motion.

0 0
Motion and opportunity for a hearing on the Motion were appropriate and no other notice need
be provided; and this Court having reviewed the Motion and having heard the statements in
support of the relief requested therein at a hearing before this Court (the "Hearing"); and this
Court having determined that the legal and factual bases set forth in the Motion and at the
Hearing establish just cause for the relief granted herein; and upon all of the proceedings had
before this Court; and after due deliberation and sufficient cause appearing therefor, it is
HEREBY ORDERED THAT:
1. The Motion is granted as set forth herein.
2. The period within which the Debtors may seek removal of the Actions pursuant to
28 U.S.C. § 1452 and Bankruptcy Rule 9027 is enlarged by 120 days, with a deadline for filing
notices of removal up to and including December 28, 2016, without prejudice to the Debtors'
right to seek further extensions.
3. All time periods set forth in this Order shall be calculated in accordance with
Bankruptcy Rule 9006(a).
4. The Debtors are authorized to take all actions necessary to effectuate the relief
granted in this Order in accordance with the Motion.
5. The Court retains jurisdiction with respect to all matters arising from or related to
the implementation, interpretation, and enforcement of this Order.
Dated: , 2016
Wilmington, Delaware The Honorable Christopher S. Sontchi
United States Bankruptcy Judge
2

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
HORSEHEAD HOLDING CORP., et al.,'
Reorganized Debtors.
Chapter 11
Case No. 16-10287 (CSS)
(Jointly Administered)
Received
J AN' - 9 2017
Land Quality Section
Asheville
Hearing Date: January 26, 2017 at 10:00 a.m. (E.T.)
Objection DL: January 3, 2017 at 4:00 p.m. (E.T.)
Related to Docket No. 2048
CERTIFICATE OF NO OBJECTION REGARDING REORGANIZED DEBTORS'
THIRD MOTION FOR ENTRY OF AN ORDER (A) ENLARGING THE PERIOD
WITHIN WHICH THE REORGANIZED DEBTORS MAY REMOVE ACTIONS
AND (B) GRANTING RELATED RELIEF
1, Aaron H. Stulman, an attorney with the law firm of Ashby & Geddes, P.A., co -counsel
the above -captioned reorganized debtors (the "Reorganized Debtors"), hereby certify the
following:
1. On December 20, 2016, the Reorganized Debtors filed the Reorganized Debtors'
Third Motion for Entry of an Order (A) Enlarging the Period Within Which the Reorganized
Debtors May Remove ilctions and (B) Granting Related Relief [Docket No. 20481 (the "Motion"),
which attached as Exhibit A, a proposed form of order (the "Order")
2. Pursuant to the notice of hearing for the Motion, objections or responses, if any, to
the Motion were to be filed with the Court and served upon the undersigned counsel by 4:00 p.m.
(prevailing Eastern Time) on January 3, 2017.
1 The Reorganized Debtors in these chapter I I cases, along with the last four digits of each Reorganized Debtor's
federal tax identification number, are: Horschead Holding Corp. (7377); Horschead Corporation (7346); Horsehead
Mctal Products, LLC (6504); The International Metals Reclamation Company, LLC (SS92); and Zochem Inc. (4475).
The Reorganized Debtors' principal offices are located at 4955 Steubenville Pike, Suite 405. Pittsburgh, Pennsylvania
15205.
1011785Wv1 I
Docket No. 2062
1/4117

0
3. As of the date hereof, the undersigned counsel have not been served with any
objections or responses to the Motion. A review of the Court's docket indicates that, as of this
date, no responses or objections to the Motion have been filed.
THEREFORE, the Reorganized Debtors respectfully request that the Order approving the
Motion be entered at the Court's earliest convenience.
Dated: January 4, 2017 ASHBY & GEDDES, P.A.
Wilmington, Delaware
Is/Aaron H. Stillman
William P. Bowden (No. 2553)
Karen B. Skomorucha Owens (No. 4759)
Aaron H. Stulman (No. 5807)
500 Delaware Avenue, 8th Floor
P.O. Box 1 150
Wilmington, Delaware 19899
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
-and-
AKIN GUMP STRAUSS HAUER & FELD LLP
Michael S. Stamer (admitted pro hac vice)
Meredith A. Lahaie (admitted pro hac vice)
One Bryant Park
New York, New York 10036
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
mlahaie@,akingump.com
akingump.com
Co -Counsel to the Reorganized Debtors
{OI 1785966 vI 1 2

Miscellaneous:
16-10287-CSS Horsehead Holding Corp.
Type: bk Chapter: 11 v Office: 1 (Delaware)
Assets: y Judge: CSS
Case Flag: CLMSAGNT, MEGA, LEAD, SealedDoc(s), CONFIRMED
U.S. Bankruptcy Court
District of Delaware
Notice of Electronic Filing
The following transaction was received from Aaron H Stulman entered on 1/4/2017 at 5:51 PM
EST and filed on 1/4/2017
Case Name: Horsehead Holding Corp.
Case Number: 16-10287-CSS
Document Number:2062
Docket Text:
Certificate of No Objection Regarding Reorganized Debtors' Third Motion -for Entry of an Order
(A) Enlarging the Period Within Which the Reorganized Debtors May Remove Actions and (B)
Granting Related Relief (related document(s)[2048]) Filed by Horsehead Holding Corp..
(Stulman, Aaron)

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A S S O C I A T E S
Forrest R. `irestall, Sr., P.E•
Principal
Engineering • Planning • Finance
38 Orange St.. Asheville, NC 2e801 • 1'O Bnx 2759. Asheville. NC 28802
Office. 828-252-0575 • Fac: 828-253-5612
Email: forresr.wesrall@mcgillengineers,c•om
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A S S () C 1 A T E S
NNIark D. Cathey, PE
Senior- Projecl Nhalurger,
Engineering • PIan11i11L Finance
55 Rrn(rl .tic., .4slterir&•, ,\,C 25801 - 1{U. Hrcr 225Y, A-sheville. ,\'(' 2R802
Oicc: �S2S- 2 52.0575 • f ins : 828-252- 2518 • ,L1r+bile: 828-231-68-l5
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A S S O C 1 A 'I' E S
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Jay Ste«•art
Senior Engineering Technician
Ron Kinder Engineering Planning Finance
Safety Manager 55 8roml St., Asheville. AC 2SN)l • Y.O. B,,, 2251), Asheville, NC 2&SL12
Office: 8'28-252-o575 . Fair: 828.252-2518 -I lobile:
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Wood Group
9�7Mustang'
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484 Hicks
SX Grove
EW Plant - CE
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48a Hicks Grove Road Mobile: [phone]
Mooresboro, NC 28114 ron.kinder@QI0I>aIPertormance,net General C
www mustangeog com mood,NC.
ontraetors
Phone: [phone]$81
Fax: [phone]
Mobile: [phone]
Tom Addley 150 Conway Black Rd.
ANTHONY STALEY, PHD Vice President EmSpartanburg, SC 29307
General:'�lmvager - Zinc• rifelal ail. [e-mail]
484 HICKS GROVE ROAD
MOORESBORO, NC 28114
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4-709-0225 CORPORATION 7
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ASTALEYC HORSEHEAD.NET
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JASON BALMER, P.E. I
Mechanical Engineer
P
347 HIO KS GROVE ROAD, �� • ,}yam j ��
1NOORESHORO, NC 28114 ., .r 1A /ram' I / •—� �1 S
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Leading Orr 4Ygr[rf m ZBii Recycling
J BALMER@HORSEH EAD. N ET
WWW.HORSEHEAD.NE-r

TIMOTHY R. BASILONE
Vit'e. Presidext - Ellnircuuneldai Affairs '
4955 5TEU13ENVILI-E PIKE r
SUITE 405 •
'®- r PITTSBURG H� PA 15205 3 J �f
P 724-773-2223 CORPORATION
F 412-786-4526 Leading the World in Zinc Recycling
C 412-287-9871
TBASILONEOHORSEHEAD-NET
i a WWW.HORSE14EAD-NET
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A S S O C I A T E S
Jay Stewart
SelliOr Engineering Technician
F 11 g t 11 C C P I n k • P I a n n I1 r '
SS Bruud S)., A,heville. Ali 1, , F l 1! it 11 C L'
YY01 • 1'.O. Bo.r 21 ' I � Y XX �
Office X2X-2-12-05%4. F14": 81X-252-151X Slohilr: 864-444-3415
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Tom RUPIK, P.E.
Project Engineer
300 FRANKrORT ROAD
MONACA, PA 15061
P 724-773-2218
F 724-773-2268
C 41 2-841 -0374
[e-mail]
WWW.HORSEHEAP.NET
IOC _15�[; C[ffA�
CORPORATION
Leading the World in Zinc Recycling