energy future holdings precedent pack volume 3 of 6

Energy Future

Holdings Corp. Selected Chapter 11 Case

Documents & Relevant Precedent

Volume 3 of 6

Chapter11Dockets.com has collected key court filings (through May

6, 2014) in the Energy Future Holdings Chapter 11 cases as well as

precedential materials regarding motions to transfer venue of cases

before Bankruptcy Judge Christopher Sontchi, as well as plans of

reorganization proposed by selected energy industry debtors

represented by Kirkland & Ellis LLP in previous Chapter 11 cases.

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Table of Contents Energy Future Holdings: First Day Motions & Applications (Volume 1 of 6)

Chapter 11 Voluntary Petition Filed by Energy Future Holdings Corp [Docket #1] ....... 16

Motion for Joint Administration [Docket # 17] .................................................................... 45

Motion for Entry of Interim and Final Orders Authorizing the Debtors to Pay Certain

Prepetition Taxes and Fees [Docket #23] ............................................................................ 89

Application to Appoint Claims/Noticing Agent [Docket #24] ....................................... 167

Motion for Entry of Interim and Final Orders (A) Authorizing the Debtors to (I) Pay

Certain Prepetition Compensation and Reimbursable Employee Expenses, (II) Pay

and Honor Employee and Retiree Medical and Similar Benefits, and (III) Continue

Employee and Retiree Benefit Programs, and (B) Modifying the Automatic Stay

[Docket #25] .......................................................................................................................... 207

Supplemental Declaration of Paul Keglevic, Executive Vice President, Chief Financial

Officer, and Co-Chief Restructuring Officer of Energy Future Holdings Corp., et al., in

Support of Wages and Benefits Motion [Docket #46] ..................................................... 265

Motion for Entry of Interim and Final Orders Determining Adequate Assurance of

Payment for Future Utility Services [Docket #26] .............................................................. 287

Motion for Entry of Interim and Final Orders Authorizing the Debtors to (A) Grant

Administrative Expense Priority to all Undisputed Obligations for Goods and Services

Ordered Prepetition and Delivered Postpetition and Satisfy Such Obligations in the

Ordinary Course of Business, and (B) Pay Prepetition Claims of Shippers,

Warehouseman, and Materialmen [Docket #27] ........................................................... 330

Motion for Entry of an Order Authorizing the Debtors to File a Consolidated List of

Creditors in Lieu of Submitting a Separate Mailing Matrix for Each

Debtor [Docket #28] ............................................................................................................ 360

Motion for Entry of Interim and Final Orders Authorizing the Debtors to Pay Prepetition

Critical Vendor Claims [Docket #29] ................................................................................. 373

Motion for Entry of (A) An Order Authorizing the Debtors to (I) Maintain and Administer

Customer Programs and Customer Agreements, (II) Honor Prepetition Obligations

Related Thereto, (III) Pay Certain Expenses on Behalf of Certain Organizations, (IV) Fix

the Deadline to File Proofs of Claim for Certain Customer Claims, and (V) Establish

Procedures for Notifying Customers of Commencement of the Debtors' Chapter 11

Cases, Assumption of Customer Agreement, and the Bar Date for Customer Claims

and (B) An Order Authorizing Certain of the Debtors to Assume the Customer

Agreements [Docket #31] ................................................................................................... 413


Motion Authorizing Texas Competitive Electric Holdings Company LLC and Certain of

its Debtor Affiliates to File Under Seal the Certain Fee Letter Related to Proposed

Debtor-in-Possession Financing [Docket #36]................................................................... 496

Motion for Entry of an Order (A) Authorizing the Debtors to (I) Continue Using Their

Existing Cash Management System, (II) Maintain Existing Bank Accounts and Business

Forms, and (III) Continue Using Certain Investment Accounts; (B) Authorizing

Continued Intercompany Transactions and Netting of Intercompany Claims; and (C)

Granting Postpetition Intercompany Claims Administrative Expense

Priority [Docket #37] ............................................................................................................. 513

Motion for Entry of (A) an Order Authorizing Certain of the Debtors to Pay Certain

Prepetition Transition Charges and Delivery Charges and (B) an Order Authorizing

Certain of the Debtors to Assume Transmission and Distribution Service Agreements

[Docket #38] .......................................................................................................................... 581

Motion Authorizing Energy Future Intermediate Holding Company LLC and EFIH

Finance, Inc. to File Under Seal the Certain Fee Letter Related to Proposed Debtor-in-

Possession Financing [Docket #39] .................................................................................... 620

Motion for Entry of an Order Authorizing Certain of the Debtors to Assume Standard

Form Market Participant Agreements with ERCOT [Docket #40] .................................. 638

Motion for Entry of Interim and Final Orders Authorizing the Debtors to (A) Continue

Performing Under Prepetition Hedging and Trading Arrangements, (B) Pledge

Collateral and Honor Obligations Thereunder, and (C) Enter Into and Perform Under

Trading Continuation Agreements and New Postpetition Hedging and Trading

Arrangements [Docket #41] ............................................................................................... 658

Motion of Texas Competitive Electric Holdings Company LLC and Certain of its Debtor

Affiliates for Entry of Interim and Final Orders (A) Authorizing Use of Cash Collateral, (B)

Granting Adequate Protection, (C) Modifying the Automatic Stay, and (D)

Scheduling a Final Hearing [Docket #71] ......................................................................... 726

Motion of Texas Competitive Electric Holdings Company LLC and Certain of its Debtor

Affiliates, for Entry of Interim and Final Orders (A) Approving Postpetition Financing, (B)

Granting Liens and Providing Superpriority Administrative Expense Claims, (C)

Modifying the Automatic Stay, and (D) Scheduling a Final Hearing [Docket #73] .... 832

Motion of Energy Future Intermediate Holding Company LLC and EFIH Finance, Inc.

for Entry of (I) an Interim Order (A) Approving Certain Fees Related to Postpetition

Financing and Granting Such Fees Administrative Expense Priority and (B) Scheduling

a Final Hearing; and (II) a Final Order (A) Approving Postpetition Financing, (B)

Granting Liens and Providing Superpriority Administrative Expense Claims, (C)

Authorizing the Use of Cash Collateral, (D) Authorizing the EFIH First Lien Refinancing,

(E) Authorizing Issuance of Roll-Up Debt to the Extent Authorized by the Settlement


Motion, (F) Determining the Value of Secured Claims, and (G) Modifying the

Automatic Stay [Docket #74] .......................................................................................... 1,123

Declaration of Paul Keglevic, Executive Vice President, Chief Financial Officer, and

Co-Chief Restructuring Officer of Energy Future Holdings Corp., et al., in Support of

First Day Motions [Docket #98] ........................................................................................ 1,219

Supplemental Declaration of Stephen Goldstein In Support of (I) the Motion of Texas

Competitive Electric Holdings Company LLC and Certain of its Debtors Affiliates for

Entry of Interim and Final Orders (A) Approving Postpetition Financing, (B) Granting

Liens and Providing Superpriority Administrative Expense Claims, (C) Modifying the

Automatic Stay, and (D) Scheduling a Final Hearing and (II) The Motion Authorizing

Texas Competitive Electric Holdings Company LLC and Certain of its Debtor Affiliates

to File Under Seal the Certain Fee Letter Related to Proposed Debtor-in-Possession

Financing [Docket #211] .................................................................................................. 1,683

Supplemental Declaration of Stephen Goldstein in Support of the Motion of Energy

Future Intermediate Holding Company LLC and EFIH Finance, Inc. for Entry of (I) an

Interim Order (A) Approving Certain Fees Related to Postpetition Financing and

Granting Such Fees Administrative Expense Priority and (B) Scheduling a Final Hearing;

and (II) a Final Order (A) Approving Postpetition Financing, (B) Granting Liens and

Providing Superpriority Administrative Expense Claims, (C) Authorizing the Use of Cash

Collateral, (D) Authorizing the EFIH First Lien Refinancing, (E) Authorizing Issuance of

Roll-Up Debt to the Extent Authorized by the Settlement Motion, (F) Determining the

Value of Secured Claims, and (G) Modifying the Automatic Stay [Docket #221] .. 1,687

Declaration of Terry L. Nutt in Support of the Motion of Energy Future Holdings Corp.,

et al., for Entry of Interim and Final Orders Authorizing the Debtors to (A) Continue

Performing Under Prepetition Hedging and Trading Arrangements, (B) Pledge

Collateral and Honor Obligations Thereunder, and (C) Enter into and Perform Under

Trading Continuation Agreements and New Postpetition Hedging and Trading

Arrangements [Docket #229] .......................................................................................... 1,695


Energy Future Holdings: Objections/Responses to First Day Pleadings (Volume 2 of 6)

Response of the Public Utility Commission of Texas in Support of Certain First Day

Pleadings [Docket #123] ....................................................................................................... 16

Preliminary Objection of EFIH 2nd Lien Notes Indenture Trustee and Certain

Noteholders to Motion for Interim Order Scheduling Final Hearing on Post-Petition

Financing [Docket #188] ....................................................................................................... 54

Preliminary Objection of the Ad Hoc Group of TCEH Unsecured Noteholders to the

Motion of the TCEH Debtors for Entry of an Order Directing Joint Administration of Their

Chapter 11 Cases With Those of the Oncor Debtors [Docket #222] .............................. 60

Emergency Motion of the Ad Hoc Group of TCEH Unsecured Noteholders for a Limited

Adjournment of the Hearing on First Day Motions [Docket #223] ................................... 98

Declaration of Jeffrey M. Schlerf, Esq. Related to Preliminary Objection of the Ad Hoc

Group of TCEH Unsecured Noteholders to the Motion of the TCEH Debtors for Entry of

an Order Directing Joint Administration of Their Chapter 11 Cases With Those of the

Oncor Debtors [Docket #227]............................................................................................. 122

Limited Preliminary Objection of the Ad Hoc Group of TCEH Unsecured Noteholders to

the Motion of Energy Future Holdings Corp., et al., for Entry of an Order (A) Authorizing

the Debtors to (I) Continue Using Their Existing Cash Management System, (II)

Maintain Existing Bank Accounts and Business Forms, and (III) Continue Using Certain

Investment Accounts; (B) Authorizing Continued Intercompany Transactions and

Netting of Intercompany Claims; and (C) Granting Postpetition Intercompany Claims

Administrative Expense Priority [Docket #230] .............................................................. 3,027

Omnibus Preliminary Objection Of The Ad Hoc Group Of TCEH Unsecured Noteholders

To (I) The Motion Of Texas Competitive Electric Holdings Company LLC And Certain

Of Its Debtor Affiliates For Entry Of Interim And Final Orders (A) Approving Postpetition

Financing, (B) Granting Liens And Providing Superpriority Administrative Expense

Claims, (C) Modifying The Automatic Stay, And (D) Scheduling A Final Hearing, And

(II) The Motion Of Texas Competitive Electric Holdings Company LLC And Certain Of

Its Debtor Affiliates For Entry Of Interim And Final Orders (A) Authorizing Use Of Cash

Collateral, (B) Granting Adequate Protection, (C) Modifying The Automatic Stay, And

(D) Scheduling A Final Hearing [Docket #231] .............................................................. 3,042

Declaration Of L. John Bird, Esq. in Support of Preliminary Objections of the Ad Hoc

Group of TCEH Unsecured Noteholders [Docket #232] ............................................... 3,075


Energy Future Holdings: First Day Orders (Volume 3 of 6)

Order (Interim) Directing Joint Administration of The Debtors' Chapter 11

Cases [Docket #287] .............................................................................................................. 16

Order (With Revisions Made By The Court) Authorizing Energy Future Intermediate

Holding Company LLC And EFIH Finance, Inc. To File Under Seal The Certain Fee Letter

Related To Proposed Debtor-In-Possession Financing [Docket #288]............................. 34

Order Approving Certain Fees Related To And Scheduling a Final Hearing On The

Proposed Postpetition Financing of Energy Future Intermediate Holding Company LLC

And EFIH Finance [Docket #289] .......................................................................................... 37

Order (With Revisions Made By The Court) Authorizing Texas Competitive Electric

Holdings Company LLC To File Under Seal The Certain Fee Letter Related To Proposed

Debtor-In-Possession Financing [Docket #290] .................................................................. 42

Order (Interim) (A) Authorizing The Debtors To (I) Continue Using Their Existing Cash

Management System, (II) Maintain Existing Bank Accounts And Business Forms, And

(III) Continue Using Certain Investment Accounts; (B) Authorizing Continued

Intercompany Transaction And Netting of Intercompany Claims; And (C) Granting

Postpetition Intercompany Claims Administrative Expense Priority [Docket #304] ....... 45

Order (Interim) Authorizing the Debtors to (A) Maintain and Administer Customer

Programs and Customer Agreements, (B) Honor Prepetition Obligations Related

Thereto, (C) Pay Certain Expenses on Behalf of Certain Organizations, (D) Fix the

Deadline to File Proofs of Claim for Certain Customer Claims, and (E) Establish

Procedures for Notifying Customers of Commencement of the Debtors' Chapter 11

Cases, Assumption of the Customer Agreements, and the Bar Date for Customer

Claims [Docket #307] ............................................................................................................. 54

Order (Interim) Authorizing The Debtors To Pay Prepetition Critical Vendor

Claims [Docket #309] ............................................................................................................. 83

Order (Interim) Authorizing the Debtors to (A) Grant Administrative Expense Priority to

all Undisputed Obligations for Goods and Services Ordered Prepetition and Delivered

Postpetition and Satisfy Such Obligations in the Ordinary Course of Business and (B)

Pay Prepetition Claims of Shippers, Warehousemen, and

Materialmen [Docket #314] .................................................................................................. 93

Order (Interim) Authorizing the Debtors to (A) Continue Performing Under Prepetition

Hedging and Trading Arrangements, (B) Pledge Collateral and Honor Obligations

Thereunder, and (C) Enter Into and Perform Under Trading Continuation Agreements

and New Postpetition Hedging and Trading Arrangements [Docket #315] ................. 98

Order (Interim) Authorizing Certain of the Debtors to Pay Certain Prepetition Transition

Charges and Delivery Charges [Docket #318] ................................................................ 114


Order (Interim) Determining Adequate Assurance of Payment For Future Utility

Services [Docket #319] ........................................................................................................ 118

Order (Interim) Authorizing the Debtors to Pay Certain Prepetition Taxes and

Fees [Docket #320] ............................................................................................................... 128

Order Approving the Retention and Appointment of Epiq Bankruptcy Solutions, LLC as

the Claims and Noticing Agent for the Debtors [Docket #321] .................................... 132

Order (Interim) (A) Authorizing the Debtors to (I) Pay Certain Prepetition

Compensation and Reimbursable Employee Expenses, (II) Pay and Honor Employee

and Retiree Medical and Similar Benefits, and (III) Continue Employee and Retiree

Benefit Programs, and (B) Modifying the Automatic Stay [Docket #322] .................... 138

Order Authorizing the Debtors to File a Consolidated List of Creditors in Lieu of

Submitting a Separate Mailing Matrix for Each Debtor [Docket #323] ........................ 143

Order (Interim) (With Revisions Made By The Court) (A)Authorizing Use of Cash

Collateral For Texas Competitive Electric Holdings Company LLC And Certain of Its

Affiliates, (B)Granting Adequate Protection, (C)Modifying The Automatic Stay, And

(D)Scheduling A Final Hearing [Docket #324] .................................................................. 146

Order (Interim) (With Revisions Made By The Court) (A)Approving Postpetition

Financing For Texas Competitive Electric Holdings Company LLC And Certain of Its

Debtor Affiliates, (B)Granting Liens And Providing Superpriority Administrative Expense

Claims, (C)Modifying The Automatic Stay, And (D)Scheduling A Final

Hearing [Docket #325] ......................................................................................................... 200


Energy Future Holdings: Venue Transfer & Related Pleadings (Volume 4 of 6)

Motion of Wilmington Savings Fund Society, FSB Pursuant to 28 U.S.C. §§ 1408 & 1412

and Rule 1014 of the Federal Rules of Bankruptcy Procedure to Transfer Cases to the

United States District Court for the Northern District of Texas [Docket #5 (Replaced

Docket #2)] .............................................................................................................................. 16

Appendix to Motion of Wilmington Savings Fund Society, FSB Pursuant to 28 U.S.C. §§

1408 & 1412 and Rule 1014 of the Federal Rules of Bankruptcy Procedure to Transfer

Cases to the United States District Court for the Northern District of

Texas [Docket #3] ................................................................................................................... 56

Motion of Wilmington Savings Fund Society, FSB for Leave to Conduct Discovery

Pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure of Energy Future

Holdings Corporation, Its Affiliates, and Certain Third Parties [Docket #6] ............... 1,013

Appendix to Motion of Wilmington Savings Fund Society, FSB for Leave to Conduct

Discovery Pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure of

Energy Future Holdings Corporation, Its Affiliates, and Certain Third

Parties [Docket #7] ............................................................................................................ 1,093

Debtors' Response and Partial Opposition to the Motion of Wilmington Savings Fund

Society, FSB Pursuant to Rule 2002 and 9006 of the Federal Rules of Bankruptcy

Procedure and 11 U.S.C. Section 105(a) to Shorten Notice of, and Schedule Hearings

on, (I) Request to Transfer Venue; and (II) Request to Conduct Discovery Under Rule

2004 [Docket #203] ........................................................................................................... 3,189

Debtors' Motion to Quash Notice of Deposition of Paul Keglevic Filed by Energy Future

Holdings Corp. [Docket #214] .......................................................................................... 3,196

Limited Joinder of the Ad Hoc Group of TCEH Unsecured Noteholders to the Motion of

Wilmington Savings Fund Society, FSB Pursuant to 28 U.S.C. §§ 1408 & 1412 and Rule

1014 of the Federal Rules of Bankruptcy Procedure to Transfer Cases to the United

States District Court for the Northern District of Texas [Docket #225] ......................... 3,204

Limited Joinder of the Ad Hoc Group of TCEH Unsecured Noteholders to the Motion of

Wilmington Savings Fund Society, FSB for Leave to Conduct Discovery Pursuant to Rule

2004 of the Federal Rules of Bankruptcy Procedure of Energy Future Holdings

Corporation, Its Affiliates, and Certain Third Parties [Docket #226] ........................... 3,214


Bankruptcy Judge Christopher S. Sontchi Venue Transfer Precedent (Volume 5 of 6)

ASHINC Corporation (f/k/a Allied Systems Holdings, Inc.) [Case No. 12-11564]

Motion to Change Venue/Inter-district Transfer - Bankruptcy to the United States

Bankruptcy Court for the Northern District of Georgia, Atlanta Division Filed by

Allied Systems Holdings, Inc. [Docket #29] ................................................................. 16

Objection of the Petitioning Creditors to Motion of the Alleged Debtors to

Transfer Venue of these Involuntary Cases to the United States Bankruptcy Court

for the Northern District of Georgia, Atlanta Division Filed by BDCM Opportunity

Fund II, LP, Black Diamond CLO 2005-1 Adviser L.L.C., Spectrum Investment

Partners LP [Docket #51] ............................................................................................... 29

Order Denying Motion of Alleged Debtors to Transfer Venue of These Cases to

the United States Bankruptcy Court for the Northern District of Georgia, Atlanta

Division [Docket #60] ................................................................................................... 203

Transcript regarding Hearing Held 5/31/12 Regarding the Motion to Transfer

Venue [Docket #62] .................................................................................................... 205

Cordillera Golf Club, LLC [Case No. 12-11893]

Motion of Cheryl M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary

Jackson and Kevin B. Allen, Individually and as Representatives of a Certified

Class of Members, to Transfer Venue [Docket #69] ................................................ 265

Joinder of Alpine Bank to the Motion of Cheryl M. Foley, Thomas Wilner, Jane

Wilner, Charles Jackson, Mary Jackson and Kevin B. Allen, Individually and as

Members of a Certified Class of Members, to Transfer Venue [Docket #77] ...... 425

Motion of Cordillera Property Owners Association, Inc. and Cordillera

Metropolitan District to Transfer Venue to Colorado and Joinder in the Motion of

Cheryl M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary Jackson and

Kevin B. Allen, Individually and as Representatives of a Certified Class of

Members, to Transfer Venue [Docket #78] ............................................................... 435

Joinder of Alpine Bank to the Motion of Cordillera Property Owners Association,

Inc. and Cordillera Metropolitan District to Transfer Venue to

Colorado [Docket #95] ............................................................................................... 478

Joinder of the Official Committee of Unsecured Creditors in: (I) Motion of Cheryl

M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary Jackson and Kevin

B. Allen, Individually and as Representatives of a Certified Class of Members, to

Transfer Venue; and (II) Motion of Cordillera Property Owners Association, Inc.

and Cordillera Metropolitan District to Transfer Venue to

Colorado [Docket #117] ............................................................................................. 480

Omnibus Objection to the Motions to Transfer Venue and/or Related Joinders

Filed By (I) Cheryl M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary


Jackson and Kevin B. Allen, Individually and as Representatives of a Certified

Class of Members, (II) Alpine Bank, (III) Cordillera Property Owners Association,

Inc. and Cordillera Metropolitan District Filed by Cordillera Golf

Club, LLC [Docket #118] ............................................................................................. 490

Declaration of Daniel L. Fitchett, Jr. in Support of the Debtor's Omnibus Objection

to the Motions to Transfer Venue and/or Related Joinders Filed By (I) Cheryl M.

Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary Jackson and Kevin B.

Allen, Individually and as Representatives of a Certified Class of Members, (II)

Alpine Bank, (III) Cordillera Property Owners Association, Inc. and Cordillera

Metropolitan District Filed by Cordillera Golf Club, LLC [Docket #119] ................ 522

Joinder of Creditor Jeffrey Rush, M.D. as Trustee of the Rush Family Trust UTD May

8, 1985, to Objection of Debtor to (I) Motion of Cheryl M. Foley, Thomas Wilner,

Jane Wilner, Charles Jackson, Mary Jackson and Kevin B. Allen, Individually and

as Representatives of a Certified Class of Members, to Transfer Venue, (II) Motion

of Cordillera Property Owners Association, Inc. and Cordillera Metropolitan

District to Transfer Venue to Colorado and Joinder in the Motion of Cheryl M.


Allen, Individually and as Representatives of a Certified Class of Members, to

Transfer Venue, and (III) Joinders of Alpine Bank in Venue Transfer

Motions [Docket #120] ................................................................................................ 526

Southlight Trust I's Joinder to Objection of Debtor to the Motion of Cheryl M.


Allen, Individually and as Representatives of a Certified Class of Members, to

Transfer Venue and Related Motions and Joinders by Alpine Bank, CPOA and the

District [Docket #121] ................................................................................................... 532

Declaration of Harold Bordwin in Support of and Joinder to Objection to Motion

to Change Venue Filed by Cordillera Golf Club, LLC [Docket #122] ................... 535

Joinder of Homeowner Walter Carey to Objection of Debtor to the Motion of



Members, to Transfer Venue and Related Motions and Joinders by Alpine Bank,

CPOA and the District [Docket #123] ....................................................................... 540

Joinder of Homeowner Dan Bennett to Objection of Debtor to the Motion of





Joinder Of David A. Wilhelm To Objection Of Debtor To (I) Motion Of Cheryl M.

Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary Jackson And Kevin B.


Allen, Individually And As Representatives Of A Certified Class Of Members, To

Transfer Venue, (II) Motion Of Cordillera Property Owners Association, Inc. And

Cordillera Metropolitan District To Transfer Venue To Colorado And Joinder In The

Motion Of Cheryl M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary

Jackson And Kevin B. Allen, Individually And As Representatives Of A Certified

Class Of Members, To Transfer Venue, And (III) Joinders Of Alpine Bank In Venue

Transfer Motions [Docket #126] .................................................................................. 544

Joinder of Homeowner Joseph Perry to Objection of Debtor to the Motion of





Notice of Filing of Exhibits to (A) Declaration of Daniel L. Fitchett, Jr. in Support of

the Debtor's Omnibus Objection to the Motions to Transfer Venue and/or Related

Joinders Filed By (I) Cheryl M. Foley, Thomas Wilner, Jane Wilner, Charles Jackson,

Mary Jackson and Kevin B. Allen, Individually and as Representatives of a

Certified Class of Members, (II) Alpine Bank, (III) Cordillera Property Owners

Association, Inc. and Cordillera Metropolitan District and (B) Declaration of

Harold Bordwin in Support of and Joinder to Objection to Motion to Change

Venue [Docket #129] .................................................................................................. 548

Joinder of Homeowner Edward O'Brien to Objection of Debtor to the Motion of





Order Granting Motion To Change Venue to The United States Bankruptcy Court

for The District of Colorado [Docket #190] ............................................................... 558


Venue [Docket #195] .................................................................................................. 560

Saab Cars North America, Inc. [Case No. 12-10344]

Motion to Change Venue/Inter-district Transfer - Bankruptcy Filed by Saab Cars

North America, Inc. [Docket #16] .............................................................................. 768

Response of Caterpillar Logistics Services, LLC in Support of Motion of Saab Cars

North America to Transfer Venue of Case to Eastern District of

Michigan [Docket #34] ................................................................................................ 831

Opposition of the Dealer Franchisees to the Motion of the Alleged Debtor to

Transfer Venue to Michigan [Docket #35] ................................................................ 836


Reply in Support of Motion of Saab Cars North America, Inc. for Order Transferring

Venue of Case to Bankruptcy Court for the Eastern District of Michigan Filed by

Saab Cars North America, Inc. [Docket #38] .......................................................... 917

Exhibit A to Reply in Support of Motion of Saab Cars North America, Inc. for Order

Transferring Venue of Case to Bankruptcy Court for the Eastern District of

Michigan [Docket #40] ................................................................................................ 926

Order Denying Motion to Change Venue/Inter-district Transfer [Docket #44] ... 929


Venue [Docket #89] .................................................................................................... 930


Selected Kirkland & Ellis LLP Energy Industry Debtor Representation

Precedent (Volume 6 of 6)

Calpine Corp. [Bankr. S.D.N.Y. Case No. 05-60200]

Debtors' Sixth Amended Joint Plan of Reorganization Pursuant to Chapter 11 of

the United States Bankruptcy Code [Docket #7237] ................................................ 16

Findings of Fact, Conclusions of Law, and Order signed on 12/19/2007 Confirming

Sixth Amended Joint Plan of Reorganization Pursuant to Chapter 11 of the

Bankruptcy Code [Docket #7256] ............................................................................. 110

Edison Mission Energy [Bankr. N.D. Ill. Case No. 12-49219]

Order Confirming Joint Chapter 11 Plan of Reorganization (Confirmed Third

Amended Joint Chapter 11 Plan of Reorganization (with Technical Modifications)

Attached as Exhibit A) [Docket #2206] ..................................................................... 152

Longview Power, LLC [Bankr. D. Del. Case No. 13-12211]

First Amended Joint Plan of Reorganization Pursuant to Chapter 11 of the

Bankruptcy Code [Docket #1139] ............................................................................. 252

North American Petroleum Corporation USA [Bankr. D. Del. Case No. 10-11707]

First Amended Joint Chapter 11 Plan [Docket No. 970] ......................................... 376

Findings of Fact, Conclusions of Law and Order Confirming the First Amended

Joint Chapter 11 Plan [Docket No. 1056] .................................................................. 418

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