1. IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re ) Chapter 11
)
CORDILLERA GOLF CLUB, LLC, ) Case No. 12-11893 (CSS)
d/b/a The Club at Cordillera, )
) (Joint Administration Pending)
Debtors. ) Hearing Date: July 16, 2012 at 10:00 a.m.
) Related to 69, 77, 78, 95, 117 and 118
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 (D.I. 69), (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 (D.I. 78), AND (III)
JOINDERS OF ALPINE BANK IN VENUE TRANSFER MOTIONS (D.I. 77 & 95)
David A. Wilhelm, by and through his undersigned counsel, hereby submits this joinder
in the objection (D.I. 118) (the “Objection”) of Cordillera Gold Club, LLC, debtor and debtor-in-
possession (the “Debtor”), to: (i) 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 (D.I. 69); (ii) the 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 (D.I. 78); and (iii) Joinders Of Alpine Bank In Venue Transfer
Motions (D.I. No. 77 and 95) (collectively, the “Venue Transfer Requests”). Mr. Wilhelm joins
in and incorporates by reference the arguments presented in the Debtor’s Objection, and in
support, states as follows:
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2. 1. Mr. Wilhelm is a substantial equity owner in the Debtor and also holds a secured
claim against the Debtors in the approximate amount of $7,000,000.
2. For the reasons set forth in the Debtors’ Objection, Mr. Wilhelm opposes transfer
of venue of this case from Delaware and respectfully submits that the interests of the Debtor, its
estate, its creditors and other parties in interest are best served by this Court retaining venue of
this case.
WHEREFORE, Mr. Wilhelm, joins in the Debtor’s Objection and respectfully requests
that the requests that the Venue Transfer Requests be denied and that the Court grant such other
and further relief to the Debtor and Mr. Wilhelm as is just and equitable.
Dated: July 11, 2012 DUANE MORRIS LLP
/s/ Richard W. Riley
Richard W. Riley (No. 4052)
222 Delaware Avenue, Suite 1600
Wilmington, DE 19801-1659
Telephone: (302) 657-4900
Facsimile: (302) 657-4901
E-Mail: rwriley@duanmorris.com
and
James J. Holman (No. 5617)
Duane Morris LLP
30 South 17th Street
Philadelphia, PA 19103-4196
Telephone: (215) 979-1530
Facsimile: (215) 689-2562
E-mail: jjholman@duanemorris.com
Counsel to David A. Wilhelm
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