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UNITEDSTATES BANKRUPTCYCOURT

EASTERNDISTRICT OF MICHIGAN
SOUTHERN DIVISION
)
In re ) Chapter 9
)
CITY OF DETROIT, MICHIGAN, ) Case No. 13-53846
)
Debtor. ) Hon. Steven W. Rhodes
)
STATEMENT OF OBJECTORS REGARDING PROPOSED
CHANGES TO SCHEDULE IN LIGHT OF CITYS DELAYS
IN DOCUMENT PRODUCTION
1. In light of the Citys Statement Regarding Document Production
(Docket No. 5156), filed on May 30, 2014, in which Debtor City of Detroit,
Michigan (the City) reported to the Court that based on the best information
available, the City believes that it will complete [its] Document Production on or
before Friday, June 20, 2014 more than six weeks after the May 6, 2014 date
originally specified for such completion in the Fourth Amended Order
Establishing Procedures, Deadlines and Hearing Dates Relating to the Debtors
Plan of Adjustment (Docket No. 4202) (Fourth Amended Order) the Objector
Members of the Discovery and Trial Efficiency Committee (DTEC) conferred
regarding how the schedule in the case needs to be adjusted to take this significant
development into account. As a result of these efforts, the Objector Members of
the DTEC have prepared a proposed adjusted schedule that they respectfully
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1CFN.&$$|
1353846140604000000000004
Docket #5207 Date Filed: 6/4/2014
2
request the Court to adopt, a copy of which is attached hereto as Exhibit A, and
which was provided to the City yesterday evening.
2. For the convenience of the Court, attached hereto as Exhibits B and C
are comparisons showing how the schedule being proposed herein differs from
those in (i) the current Fourth Amended Order, and (ii) the previously-proposed
version of a Fifth Amended Order Establishing Procedures, Deadlines and Hearing
Dates Relating to the Debtors Plan of Adjustment that was attached to the
Statement of Objectors in Anticipation of the May 22, 2014 Status Conference
(Docket No. 4980).
3. One point from the schedule currently in effect that requires very
prompt attention is the impending deadline in the Fourth Amended Order that on
June 10, 2014 all parties file their lists of expert witnesses. The current schedule,
which called for document production to have been completed weeks earlier on
May 6, 2014, is untenable and unreasonable in the current environment where the
City now projects that its document production will not be complete until June 20,
2014 10 days after this June 10, 2014 filing deadline and only 7 days before the
current fact deposition cutoff. For example, the parties just days ago received from
the City additional installments containing critical documents such as
substantial documents from City consultants and advisors like Ernst & Young,
Milliman and Conway MacKenzie, as well as substantial documents regarding the
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factual circumstances underlying the Citys bankruptcy. Further productions of
documents from the City are expected in the days to come, the contents of which
will continue to influence the parties decisions on how to proceed in regard to the
confirmation hearing. Since these recently produced documents fall heavily into a
number of potential expert areas and relate to fact witnesses who will be deposed,
it makes little sense to require expert disclosures and fact depositions before the
parties can fully evaluate their positions, and the expert testimony needed, based
on the full documentary record. The Objector Members of the DTEC therefore
respectfully request that the revised proposed Fifth Amended Scheduling Order be
entered and that the June 10, 2014 deadline for filing lists of expert witnesses be
held in abeyance pending the Courts decision on changes to the current case
schedule.
Dated: June 4, 2014 Respectfully submitted,
By: /s/ Lawrence A. Larose
Lawrence A. Larose
Samuel S. Kohn
Robert A. Schwinger
CHADBOURNE & PARKE LLP
30 Rockefeller Plaza
New York, NY 10112
Telephone: (212) 408-5100
Fax: (212) 541-5369
llarose@chadbourne.com
skohn@chadbourne.com
rschwinger@chadbourne.com
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/s/ Guy S. Neal
James F. Bendernagel, Jr.
Guy S. Neal
SIDLEY AUSTIN LLP
1501 K Street, N.W.
Washington, D.C. 20005
Telephone: (202) 736-8041
Fax: (202) 736-8711
jbendernagel@sidley.com
gneal@sidley.com
and
Jeffrey E. Bjork
Gabriel MacConaill
SIDLEY AUSTIN LLP
555 West Fifth Street, Suite 4000
Los Angeles, California 90013
Telephone: (213) 896-6000
Fax: (213) 896-6600
jbjork@sidley.com
gmacconaill@sidley.com
Counsel for National Public Finance
Guarantee Corp.
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By: /s/ Stephen C. Hackney
James H.M. Sprayregen, P.C.
Ryan Blaine Bennett
Stephen C. Hackney
KIRKLAND & ELLIS LLP
300 North LaSalle
Chicago, Illinois 60654
Telephone: (312) 862-2000
Facsimile: (312) 862-2200
- and -
Stephen M. Gross
David A. Agay
Joshua Gadharf
MCDONALD HOPKINS PLC
39533 Woodward Avenue
Bloomfield Hills, MI 48304
Telephone: (248) 646-5070
Facsimile: (248) 646-5075
Attorneys for Syncora Guarantee Inc. and
Syncora Capital Assurance Inc.
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/s/ Vincent J. Marriott, III
Vincent J. Marriott, III, Esquire
BALLARD SPAHR LLP
1735 Market Street, 51st Floor
Philadelphia, Pennsylvania 19103
Tel: (215) 864-8236
Fax: (215) 864-9762
E-mail: marriott@ballardspahr.com
Matthew G. Summers, Esquire
BALLARD SPAHR LLP
919 North Market Street, 11th Floor
Wilmington, Delaware 19801
Tel: (302) 252-4428
Fax: (302) 252-4466
E-mail: summersm@ballardspahr.com
-and-
Howard S. Sher, Esquire (P38337)
JACOB & WEINGARTEN, P.C.
Somerset Place
2301 W. Big Beaver Road, Suite 777
Troy, Michigan 48084
Tel: (248) 649-1200
Fax: (248) 649-2920
E-mail: howard@jacobweingarten.com
Counsel for Hypothekenbank Frankfurt
AG, Hypothekenbank Frankfurt
International S.A., and Erste Europische
Pfandbrief-und Kommunalkreditbank
Aktiengesellschaft in Luxemburg S.A.
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ARENT FOX LLP
By: /s/ Carol Connor Cohen
Carol Connor Cohen
Caroline Turner English
Randall A. Brater
1717 K Street, NW
Washington, DC 20036-5342
(202) 857-6054
Email: Carol.Cohen@arentfox.com
David L. Dubrow
Mark A. Angelov
1675 Broadway
New York, NY 10019
(212) 484-3900
-and-
SCHAFER AND WEINER, PLLC
Daniel J. Weiner (P32010)
Brendan G. Best (P66370)
40950 Woodward Ave., Ste. 100
Bloomfield Hills, MI 48304
(248) 540-3340
Email: bbest@schaferandweiner.com
Attorneys for Ambac Assurance
Corporation
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Carson Fischer, P.L.C.
By: /s/ Joseph M. Fischer
Joseph M. Fischer (P13452)
Robert A. Weisberg (P26698)
Christopher Grosman (P58693)
4111 Andover Road, West- Second Floor
Bloomfield, Michigan 48302-1924
Telephone: (248) 644-4840
Facsimile: (248) 644-1832
JFischer@CarsonFischer.com
RWweisberg@CarsonFischer.com
CGrosman@CarsonFischer.com
Counsel for Oakland County, Michigan
Young &Associates
By: /s/ Sara K. MacWilliams
Sara K. MacWilliams (P67805)
Jaye Quadrozzi (P71646)
27725 Stansbury Blvd., Suite 125
Farmington Hills, Ml 48334
Telephone: (248) 353-8620
Email: efiling@youngpc.com
macwilliams@youngpc.com
guadrozzi@youngpc.com
Co-counsel for Oakland County, Michigan
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/s/ Alfredo R. Prez
Alfredo R. Prez
WEIL, GOTSHAL & MANGES LLP
700 Louisiana Street, Suite 1700
Houston, TX 77002
Telephone: (713) 546-5000
Facsimile: (713) 224-9511
Email: alfredo.perez@weil.com
and
Ernest J. Essad Jr.
Mark R. James
WILLIAMS, WILLIAMS, RATTNER &
PLUNKETT, P.C.
280 North Old Woodward Avenue,
Suite 300
Birmingham, MI 48009
Telephone: (248) 642-0333
Facsimile: (248) 642-0856
Email: EJEssad@wwrplaw.com
Email: mrjames@wwrplaw.com
Attorneys for Financial Guaranty
Insurance Company
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/s/ Paul S. Davidson
David E. Lemke (TN13586)
Paul S. Davidson (TN11789)
Heather J. Hubbard (TN23699)
WALLER LANSDEN DORTCH &
DAVIS, LLP
511 Union Street, Suite 2700
Nashville, Tennessee 37219
Phone: (615) 244-6380
Fax: (615) 244-6804
and
Robert J. Diehl, Jr. (MI31264)
Jaimee L. Witten (P70068)
BODMAN PLC
1901 St. Antoine Street, 6th Floor
Detroit, Michigan 48226
Phone: (313) 393-7597
Fax: (313) 393-7579
Attorneys for U.S. Bank National
Association, as Trustee for the Water and
Sewer Bonds
ERMAN, TEICHER, ZUCKER &
FREEDMAN, P.C.
By: /s/ Barbara A. Patek
Barbara A. Patek (P34666)
Earle I. Erman (P24296)
Counsel for the Detroit
Police Officers Association and
Detroit Fire Fighters Association
400 Galleria Officentre, Suite 444
Southfield, MI 48034
Telephone: (248) 827-4100
Facsimile: (248) 827-4106
E-mail: bpatek@ermanteicher.com
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11
GREGORY, MOORE, JEAKLE &
BROOKS, PC
James M. Moore (P17929)
Counsel for the DPOA
65 Cadillac Square, Suite 3727
Detroit, MI 48226-2893
Telephone: (313) 964-5600
Facsimile: (313) 964-2125
E-mail: jim@unionlaw.net
LEGGHIO & ISRAEL, PC
Christopher P. Legghio (P27378)
Alidz Oshagan (P77231)
Counsel for the DFFA
306 S. Washington, Suite 600
Royal Oak, MI 48067
Telephone: 248 398 5900 x 1131
Facsimile: 248 398 2662
E-mail: CPL@legghioisrael.com
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EXHIBIT 1
EXHIBIT A
13-53846-swr Doc 5207-1 Filed 06/04/14 Entered 06/04/14 12:19:53 Page 1 of 4
UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
In re: Chapter 9
City of Detroit, Michigan, Case No. 13-53846
Debtor. Hon. Steven W. Rhodes
/
Fifth Amended Order Establishing Procedures, Deadlines and
Hearing Dates Relating to the Debtors Plan of Adjustment
The City has filed a plan of adjustment and a proposed disclosure statement. To promote the just,
speedy, and inexpensive determination of this case as required by Fed. R. Bankr. P. 1001, the Court
hereby establishes the procedures, deadlines and hearing dates set forth below.
Nothing herein excuses any party from the continuing
obligation to participatein good faith in anymediation as ordered by
Chief J udgeRosen.
Further, the Court again strongly encourages all parties to
negotiate with full intensity and vigor with a view toward resolving
their disputes regarding the treatment of claims in the Citys plan of
adjustment.
The Court will hold status conferences regarding the plan confirmation process on the
following dates and times:
(a) June 16, 2014 at 10:00 a.m.
(b) July 14, 2014 at 10:00 a.m.
(c) August [__] and [__], 2014 at 10:00 a.m.
1. June 13, 2014 is the deadline for the City to mail revised notices of the confirmation
hearing, plan objection deadline, voting deadline and voting dispute procedures; and
2. June 20, 2014 is the deadline for the City to complete its production of documents
responsive to the objecting parties requests. The other dates specified in this Order are predicated on
compliance with this deadline, and are subject to further adjustment if the deadline is not met.
3. June 24, 2014 at 10:00 a.m. will be the date and time of a hearing on the status of the
Citys document production.
4. July 1, 2014 is the deadline for the City to file its list of expert witnesses and serve
copies of expert reports (which shall not be filed). Depositions of the Citys experts may commence
immediately thereafter.
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2
5. July 25, 2014 is the deadline for any affected holder, the water and sewer bond trustee,
the ad hoc committee of water and sewer bondholders and the COPs trustee to file a brief in response to
any Notice of Asserted Right to Vote a Claim.
6. August 8, 2014 is the deadline to complete all non-expert depositions.
7. August 13, 2014 is the deadline for objecting parties to file their list of expert witnesses
and serve copies of their expert reports (which shall not be filed).
8. August 22, 2014 is the deadline:
(a) For plan voting;
1
(b) For individual bondholders and individual retirees to file objections to the plan;
and
(c) For any party that filed a Notice of Asserted Right to Vote a Claim to file a reply
brief in support of such notice.
9. September 2, 2014 is the deadline for the City or the balloting agent to file a summary of
the results of the tabulation of all ballots and master ballots.
10. September 3, 2014 is the deadline to complete all expert depositions.
11. September 5, 2014 is the deadline for any party that filed a timely objection to the plan
to file a supplemental objection, but only to the extent that discovery or the results of plan voting give rise
to additional or modified objections to the plan.
12. September 8, 2014 at 10:00 a.m. will be the date and time of the hearing to determine
any disputes arising in connection with any Notices of Asserted Right to Vote a Claim.
13. September 10, 2014 is the deadline:
(a) To submit a proposed joint final pretrial order in compliance with LBR 7016-1;
(b) To file pretrial briefs; and
(c) For the City to file one combined response to supplemental objections to the plan
and to objections filed by individual bondholders and individual retirees.
14. September 15, 2014 at 9:00 a.m. will be the date and time of the final pretrial
conference on plan confirmation.
15. September 18, 2014 at 9:00 a.m. will be the date and time for the commencement of the
hearing on plan confirmation.
1
[The following parties do not support extending the voting deadline in paragraph 8 and the tabulation deadline in
paragraph 9, and may not support certain other dates: (i) Official Committee of Retirees; (ii) General Retirement
System for the City of Detroit; (iii) Police and Fire Retirement System for the City of Detroit, (iv) The Detroit Police
Officers Association; and (v) The Detroit Fire Fighters Association.]
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3
Additional confirmation hearing dates, as necessary, will be September ___ ; September
_______; and September _____, 2014.
At this hearing, in addition to any evidence addressing the factual issues raised in the parties
plan objections, the City shall present evidence establishing the feasibility of its plan as required
by 11 U.S.C. 943(b)(7).
The dates and deadlines established herein will be extended only on motion establishing good
cause.
This order amends paragraphs 7(a), 9(a), 9(c), 9(d) and 9(e) of the Order (I) Establishing
Procedures for Solicitation and Tabulation of Votes to Accept or Reject Plan of Adjustment and
(II) Approving Notice Procedures Related to Confirmation of the Plan of Adjustment (Docket No. 2984).
However, nothing in this order otherwise amends the Solicitation Procedures Order.
It is so ordered.
Signed on June ____, 2014
Steven Rhodes
United States Bankruptcy Judge
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EXHIBIT 1
EXHIBIT B
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UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
In re: Chapter 9
City of Detroit, Michigan, Case No. 13-53846
Debtor. Hon. Steven W. Rhodes
/
In re: Chapter 9
City of Detroit, Michigan, Case No. 13-53846
Debtor. Hon. Steven W. Rhodes
/
FourthFifth Amended Order Establishing Procedures, Deadlines and
Hearing Dates Relating to the Debtors Plan of Adjustment
The City has filed a plan of adjustment and a proposed disclosure statement. To promote the
just, speedy, and inexpensive determination of this case as required by Fed. R. Bankr. P. 1001, the Court
hereby establishes the procedures, deadlines and hearing dates set forth below.
Nothing herein excuses any party from the continuing
obligation to participate in good faith in any mediation as ordered by
Chief Judge Rosen.
Further, the Court again strongly encourages all parties to
negotiate with full intensity and vigor with a view toward resolving
their disputes regarding the treatment of claims in the Citys plan of
adjustment.
The Court will hold status conferences regarding the plan confirmation process on the
following dates and times:
(a) May 15, 2014 at 10:00 a.m.
(b) (a) June 16, 2014 at 10:00 a.m.
(c) July 14, 2014 at 10:00 a.m.(b) July 14, 2014 at 10:00 a.m.
1. April 25,
(c) August [__] and [__], 2014 at 10:00 a.m.
June 13, 2014 is the deadline for the City to file an amended disclosure statement 1.
incorporating the suggestions and rulings that the Court made at the hearing on April 17, 2104,
and including any additional agreements reached with creditor representatives.
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2. April 28, 2014 at 10:00 a.m. will be the date and time of the hearing on:
(a) Final approval of the disclosure statementmail revised notices of the
confirmation hearing, plan objection deadline, voting deadline and voting dispute
procedures; and
(b) All filed objections to written discovery.
3. May 2,
June 20, 2014 is the deadline for the City to file the final disclosure statement 2.
resolving any objections that the Court sustains at the hearing on April 28, 2014.
4. May 6, 2014 is the deadline to comply with timely written discovery requests.
5. May 7, 2014 is the date on which depositions may commence.
6. May 12, 2014 at 10:00 a.m. will be the date and time of the hearing on any
remaining objections to written discovery.
7. May 12, 2014 is the deadline:
(a) For the City to mail plan solicitation packages and, to the extent provided in any
order approving vote solicitation procedures, to provide packages to applicable
DTC participants;
(b) For parties other than individual bondholders and individual retirees to file
objections to the plan; and
(c) For parties who have filed timely objections to plan confirmation to file a list of
their fact witnesses and to identify the subjects that each witness will address.
A party filing an objection to the plan shall use the proper ECF event code
for the filing.
8. May 26, 2014 is the deadline:
(a) For the City to file one combined response to all of the timely plan objections; and
(b) For any party that is not identified as having the right to vote on the plan, but who
asserts a right to vote on the plan, to file a "Notice of Asserted Right to Vote a
Claim" and a brief in support.complete its production of documents responsive to
the objecting parties requests. The other dates specified in this Order are
predicated on compliance with this deadline, and are subject to further adjustment
if the deadline is not met.
June 24, 2014 at 10:00 a.m. will be the date and time of a hearing on the status of 3.
the Citys document production.
2
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9. June 10,July 1, 2014 is the deadline for all partiesthe City to file their listsits list 4.
of expert witnesses and serve copies of expert reports (which shall not be filed). Depositions of the
Citys experts may commence immediately thereafter.
10. June 24,July 25, 2014 is the deadline for any affected holder, the water and sewer 5.
bond trustee, the ad hoc committee of water and sewer bondholders and the COPs trustee to file a brief in
response to any Notice of Asserted Right to Vote a Claim.
11. June 24, 2014 is the deadline for all parties to serve copies of expert reports (which
shall not be filed).
12. June 27,August 8, 2014 is the deadline to complete all non-expert witness 6.
depositions.
13. July 1,August 13, 2014 is the deadline for objecting parties to file atheir list of 7.
rebuttal expert witnesses and to serve copies of rebuttaltheir expert reports (which shall not be filed).
14. July 2, 2014 is the deadline for any party that filed a Notice of Asserted Right to Vote
a Claim to file a reply brief in support of such notice.
15. July 11,August 22, 2014 is the deadline: 8.
For plan voting;
1
and (a)
For individual bondholders and individual retirees to file objections to the plan.; (b)
and
16. July 14, 2014 at 10:00 a.m. will be the date and time of the hearing (c)
to determine any disputes arising in connection with any NoticesFor any party
that filed a Notice of Asserted Right to Vote a Claim. to file a reply brief in support of
such notice.
September 2, 2014 is the deadline for the City or the balloting agent to file a summary 9.
of the results of the tabulation of all ballots and master ballots.
17. July 15,September 3, 2014 is the deadline to complete all expert depositions. 10.
18. July 18,September 5, 2014 is the deadline for any party that filed a timely 11.
objection to the plan to file a supplemental objection, but only to the extent that discovery or the results
of plan voting give rise to additional or modified objections to the plan.
1
[The following parties do not support extending the voting deadline in paragraph 8 and the tabulation
deadline in paragraph 9, and may not support certain other dates: (i) Official Committee of Retirees; (ii)
General Retirement System for the City of Detroit; (iii) Police and Fire Retirement System for the City of De
troit, (iv) The Detroit Police Officers Association; and (v) The Detroit Fire Fighters Association.]
3
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Signed on April 21,June ____, 2014
/s/
Steven Rhodes
Steven Rhodes
United States Bankruptcy Judge
4
September 8, 2014 at 10:00 a.m. will be the date and time of the hearing to determine 12.
any disputes arising in connection with any Notices of Asserted Right to Vote a Claim.
19. July 21,September 10, 2014 is the deadline: 13.
To submit a proposed joint final pretrial order in compliance with LBR (a)
701617016-1;
To file pretrial briefs; and (b)
For the City to file one combined response to supplemental objections to the plan (c)
and to objections filed by individual bondholders and individual retirees; and.
(d) For the City or the balloting agent to file a summary of the results of the tabulation
of all ballots and master ballots.
20. July 23,September 15, 2014 at 9:00 a.m. will be the date and time of the final 14.
pretrial conference on plan confirmation.
21. July 24,September 18, 2014 at 9:00 a.m. will be the date and time for the 15.
commencement of the hearing on plan confirmation.
Additional confirmation hearing dates, as necessary, will be July 25; July 28-31; August
1; August 4-8; and August 11-15,September ___ ; September _______; and September _____,
2014.
At this hearing, in addition to any evidence addressing the factual issues raised in the parties
plan objections, the City shall present evidence establishing the feasibility of its plan as required
by 11 U.S.C. 943(b)(7).
The dates and deadlines established herein will be extended only on motion establishing good
cause.
This order amends paragraphs 7(a), 9(a), 9(c), 9(d) and 9(e) of the Order (I) Establishing Procedures for
Solicitation and Tabulation of Votes to Accept or Reject Plan of Adjustment and (II) Approving Notice
Procedures Related to Confirmation of the Plan of Adjustment (Docket No. 2984). However, nothing in
this order otherwise amends the Solicitation Procedures Order.
It is so ordered.
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EXHIBIT 1
EXHIBIT C
13-53846-swr Doc 5207-3 Filed 06/04/14 Entered 06/04/14 12:19:53 Page 1 of 4
UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
In re: Chapter 9
City of Detroit, Michigan, Case No. 13-53846
Debtor. Hon. Steven W. Rhodes
/
Fifth Amended Order Establishing Procedures, Deadlines and
Hearing Dates Relating to the Debtors Plan of Adjustment
The City has filed a plan of adjustment and a proposed disclosure statement. To promote the
just, speedy, and inexpensive determination of this case as required by Fed. R. Bankr. P. 1001, the Court
hereby establishes the procedures, deadlines and hearing dates set forth below.
Nothing herein excuses any party from the continuing
obligation to participate in good faith in any mediation as ordered by
Chief Judge Rosen.
Further, the Court again strongly encourages all parties to
negotiate with full intensity and vigor with a view toward resolving
their disputes regarding the treatment of claims in the Citys plan of
adjustment.
The Court will hold status conferences regarding the plan confirmation process on the
following dates and times:
(a) June 16, 2014 at 10:00 a.m.
(b) July 14, 2014 at 10:00 a.m.
(c) August [__] and [__], 2014 at 10:00 a.m.
1. May 27, 2014 is the deadline for the City to file one combined response to all of the
timely plan objections.
2. May 28, 2014 at 10:00 a.m. will be the date and time of a hearing on the status of
the Citys document production and a further hearing on objections with respect to the Citys
responses to discovery.
3. June 2, 2014 is the deadline:
(a) ForJune 13, 2014 is the deadline for the City to mail revised notices of the 1.
confirmation hearing, plan objection deadline, voting deadline and voting dispute procedures; and
(b) ForJune 20, 2014 is the deadline for the City to complete its production of 2.
documents responsive to the objecting parties requests. The other dates specified in this Order are
ACTIVE 201607227v.3
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predicated on compliance with this deadline, and are subject to further adjustment if the deadline is not
met.
4. June 24, 2014 at 10:00 a.m. will be the date and time of a hearing on the status of the 3.
Citys document production.
July 1, 2014 is the deadline for the City to file its list of expert witnesses and serve 4.
copies of expert reports (which shall not be filed). Depositions of the Citys experts may commence
immediately thereafter.
5. June 27, 2014 is the deadline for any party that is not identified as having the right to
vote on the plan, but who asserts a right to vote on the plan, to file a Notice of Asserted Right to Vote a
Claim and a brief in support.
6. July 18, 2014 is the deadline to complete all non-expert depositions.
7. July 25, 2014 is the deadline:
(a) ForJuly 25, 2014 is the deadline for any affected holder, the water and sewer bond 5.
trustee, the ad hoc committee of water and sewer bondholders and the COPs trustee to file a brief in
response to any Notice of Asserted Right to Vote a Claim; and.
August 8, 2014 is the deadline to complete all non-expert depositions. 6.
(b) ForAugust 13, 2014 is the deadline for objecting parties to file their list of expert 7.
witnesses and serve copies of their expert reports (which shall not be filed).
August 1,22, 2014 is the deadline: 8.
For plan voting;
1
(a)
For individual bondholders and individual retirees to file objections to the plan; (b)
and
For any party that filed a Notice of Asserted Right to Vote a Claim to file a reply (c)
brief in support of such notice.
August 11,September 2, 2014 is the deadline for the City or the balloting agent to file a 9.
summary of the results of the tabulation of all ballots and master ballots.
August 13,September 3, 2014 is the deadline to complete all expert depositions. 10.
August 15,September 5, 2014 is the deadline for any party that filed a timely objection 11.
to the plan to file a supplemental objection, but only to the extent that discovery or the results of plan
voting give rise to additional or modified objections to the plan.
1
[The following parties do not support extending the voting deadline in paragraph 8 and the tabulation deadline in
paragraph 99, and may not support certain other dates: (i) Official Committee of Retirees; (ii) General Retirement
System for the City of Detroit; (iii) Police and Fire Retirement System for the City of Detroit, (iv) The Detroit
Police Officers Association; and (v) The Detroit Fire Fighters Association.]
2
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August 18,September 8, 2014 at 10:00 a.m. will be the date and time of the hearing to 12.
determine any disputes arising in connection with any Notices of Asserted Right to Vote a Claim.
August 20,September 10, 2014 is the deadline: 13.
To submit a proposed joint final pretrial order in compliance with LBR 7016-1; (a)
To file pretrial briefs; and (b)
For the City to file one combined response to supplemental objections to the plan (c)
and to objections filed by individual bondholders and individual retirees.
August 25,September 15, 2014 at 9:00 a.m. will be the date and time of the final 14.
pretrial conference on plan confirmation.
August 26,September 18, 2014 at 9:00 a.m. will be the date and time for the 15.
commencement of the hearing on plan confirmation.
Additional confirmation hearing dates, as necessary, will be AugustSeptember ___ ;
AugustSeptember _______; and September _____, 2014.
At this hearing, in addition to any evidence addressing the factual issues raised in the parties
plan objections, the City shall present evidence establishing the feasibility of its plan as required
by 11 U.S.C. 943(b)(7).
The dates and deadlines established herein will be extended only on motion establishing good
cause.
This order amends paragraphs 7(a), 9(a), 9(c), 9(d) and 9(e) of the Order (I) Establishing
Procedures for Solicitation and Tabulation of Votes to Accept or Reject Plan of Adjustment and (II)
Approving Notice Procedures Related to Confirmation of the Plan of Adjustment (Docket No. 2984).
However, nothing in this order otherwise amends the Solicitation Procedures Order.
It is so ordered.
Signed on MayJune ____, 2014
Steven Rhodes
United States Bankruptcy Judge
3
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CPAM: 6589518.1
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
In re:
CITY OF DETROIT, MICHIGAN
Debtor.
Chapter 9
Case No. 13-53846
Hon. Steven W. Rhodes
CERTIFICATE OF SERVICE
I hereby certify that on this 4
th
day of June 2014, I caused the Statement of
Objectors Regarding Proposed Changes to Schedule in Light of Citys Delays in
Document Production to be filed with the Clerk of the Court using the CM/ECF
system, which provides electronic notification of such filing to all counsel of
record.
Dated: New York, New York
June 4, 2014
/s/ Lawrence A. Larose
Lawrence A. Larose
Samuel S. Kohn
Robert A. Schwinger
CHADBOURNE & PARKE LLP
30 Rockefeller Plaza
New York, NY 10012
Telephone: (212) 408-5100
Fax: (212) 541-5369
llarose@chadbourne.com
skohn@chadbounrne.com
rschwinger@chadbourne.com
Counsel for Assured Guaranty
Municipal Corp.
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