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Rule 1007-2 (E) Scheduling Initial Case Conference, Attached Hereto As Exhibit A, Pursuant To

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COOLEY LLP 1114 Avenue of the Americas New York, New York 10036 Telephone: (212) 479-6000 Facsimile:

(212) 479-6275 Cathy Hershcopf Jeffrey L. Cohen Alex R. Velinsky Proposed Attorneys for Debtor and Debtor in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------In re METROPARK USA, INC., Debtor. ---------------------------------------------------------------x : : : : : : : x

Chapter 11 Case No. 11-______ (RDD)

NOTICE OF PROPOSED ORDER SCHEDULING INITIAL CASE CONFERENCE PLEASE TAKE NOTICE that Metropark USA, Inc., as debtor and debtor in possession (the Debtor) hereby submits the Proposed Order Pursuant to Local Bankruptcy Rule 1007-2(e) Scheduling Initial Case Conference, attached hereto as Exhibit A, pursuant to Rule 1007-2(e) of the Local Bankruptcy Rules for the Southern District of New York.

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Dated: May 2, 2011 New York, New York Respectfully submitted, By: /s/ Cathy Hershcopf Cathy Hershcopf

COOLEY LLP 1114 Avenue of the Americas New York, New York 10036 Telephone: (212) 479-6000 Facsimile: (212) 479-6275 Cathy Hershcopf (CH 5875) Jeffrey L. Cohen (JC 2556) Alex R. Velinsky (AV 1012) Proposed Attorneys for Debtor and Debtor in Possession

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EXHIBIT A

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------------In re METROPARK USA, INC., Debtor. ---------------------------------------------------------------x : : : : : : : x

Chapter 11 Case No. 11-______ (RDD)

ORDER PURSUANT TO LOCAL BANKRUPTCY RULE 1007-2(e) SCHEDULING INITIAL CASE CONFERENCE Metropark USA, Inc., as debtor and debtor in possession (the Debtor),1 having filed a petition for reorganization under chapter 11 of the title 11 of the United States Code (the Bankruptcy Code) on May 2, 2011 and the Court having determined that a case management conference will aid in the efficient conduct of the case, it is ORDERED, pursuant to section 105(d) of the Bankruptcy Code, that an initial case management conference will be conducted by the undersigned Bankruptcy Judge in Room [___], United States Bankruptcy Court, 300 Quarropas Street, White Plains, New York 10601 on [________], 2011, at [____] [__].m. (Eastern), or as soon thereafter as counsel may be heard, to consider the efficient administration of the case, which may include, inter alia, such topics as retention of professionals, creation of a committee to review budget and fee requests, use of alternative dispute resolution, timetables, and scheduling of additional case management conferences; and it is further ORDERED that the Debtor shall give notice by mail of this Order at least seven days prior to the scheduled conference to (i) the Office of the United States Trustee for the Southern District of New York (Attn: Susan Golden, Esq.), (ii) Riemer & Braunstein LLP, Three Center Plaza, Boston, MA 02108 (Attn: Donald E. Rothman, Esq.) as counsel for Wells Fargo Bank, N.A., (iii) Solomon Ward Seidenwurm & Smith, LLP, 401 B Street, Ste. 1200 San Diego,
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The last four digits of the Debtors federal tax identification number are 6659.

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CA 92101 (Attn: Michael D. Breslauer, Esq.) as counsel to Bricoleur Capital Partners, LP in its capacity as second lien agent, and (iv) each committee appointed to serve in the case pursuant to section 1102 of the Bankruptcy Code (or, if no committee has been appointed, to the holders of the 30 largest unsecured claims) and the holders of the five largest secured claims, and shall promptly file proof of service of such notice with the Clerk of the Court. Dated: , 2011 White Plains, New York HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE

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