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    10000001247 10000001247 Document Transcript

    • IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWAREIn re: Chapter 11Cordillera Golf Club, LLC,1 Case No. 12-11893 (CSS) dba The Club at Cordillera, Hearing Date: July 16, 2012 at 10:00 a.m. (ET) Debtor. Ref. Docket Nos. 69, 77, 78 & 95 DEBTOR’S PROPOSED LISTS OF POTENTIAL WITNESSES AND POTENTIAL EXHIBITS FOR HEARING ON JULY 16, 2012 AT 10:00 A.M. (ET) DEBTOR’S PROPOSED LIST OF POTENTIAL WITNESSES 1. Daniel L. Fitchett, Jr. 2. Harold Bordwin DEBTOR’S PROPOSED LIST OF POTENTIAL EXHIBITS 1. Declaration of Daniel L. Fitchett, Jr. in Support of the Debtor’s OmnibusObjection 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, and (iii)Cordillera Property Owners Association, Inc. and Cordillera Metropolitan District [Docket No.119] 2. Declaration of Harold Bordwin in Support of and Joinder to Objection toMotion to Change Venue [Docket No. 122] 3. Debtor’s Schedules and Statements of Financial Affairs [To be Filed]1 The Debtor in this chapter 11 case, and the last four digits of its employer tax identification number, is: XX-XXX1317. The corporate headquarters address for the Debtor is 97 Main Street, Suite E202, Edwards, CO 81632.01:12278005.3
    • 4. Exhibit B to Motion of Cheryl M. Foley, Thomas Wilner, Jane Wilner,Charles Jackson, Mary Jackson and Kevin B. Allen, Individually and as Representatives of aCertified Class of Members, to Transfer Venue [Docket No. 69] 5. Notice of Appointment of Committee of Unsecured Creditors [DocketNo. 86] 6. Declaration of Daniel L. Fitchett, Jr. in Support of Chapter 11 Petitionsand First Day Relief [Docket No. 2] 7. Emergency Motion of the Debtor for Entry of Interim and Final OrdersPursuant to 11 U.S.C. §§ 105, 361, 362, 363(c), 363(d), and 364(e) and Fed. R. Bankr. P. 2002,4001, and 9014 (i) Authorizing Debtor to Obtain Post-Petition Secured Financing, (ii) GrantingSecurity Interests and Superpriority Administrative Expense Claims, (iii) Granting AdequateProtection to Pre-Petition Secured Parties, (iv) Authorizing the Use of Cash Collateral asProvided Herein, and (v) Scheduling a Final Hearing [Docket No. 59] 8. Complaint to Determine Validity, Priority, Perfection and Extent of Lien;for Declaratory Relief; and Avoidance of Lien [Docket No. 60] 9. Entry of Appearance and Request for Notice filed by Appel & Lucas, P.C.on behalf of Cheryl Foley, Thomas and Jane Wilner, Charles and Mary Jackson and Kevin Allen[Docket No. 58] 10. Notice of Appearance and Demand for Service of Papers filed byRichards, Layton & Finger, P.A. on behalf of Cheryl Foley, Thomas and Jane Wilner, Charlesand Mary Jackson and Kevin Allen [Docket No. 61] 11. Notice of Appearance and Request for Service of Papers filed byCordillera Property Owners Association, Inc. [Docket No. 82] 2
    • 12. Notice of Appearance and Request for Service of Papers filed byCordillera Metropolitan District [Docket No. 83] 13. Exhibit A to the Motion of Cordillera Property Owners Association, Inc.and Cordillera Metropolitan District to Transfer Venue to Colorado and Joinder in the Motionof 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 No. 78] 14. Order to Show Cause as to Why the Court Should Not Decline to ExerciseJurisdiction over This Matter, Foley v. Cordillera Golf Club, LLC, No. 12-0351-WJM-KMT (D.Colo. Feb. 16, 2012) 15. Plaintiffs’ Response to Order to Show Cause as to Why the Court ShouldNot Decline to Exercise Jurisdiction over This Matter, Foley v. Cordillera Golf Club, LLC, No.12-0351-WJM-KMT (D. Colo. Mar. 10, 2012) 16. Plaintiffs’ Response to Debtors’ Brief Regarding Subject MatterJurisdiction, Foley v. Cordillera Golf Club, LLC, No. 12-0351-WJM-KMT (D. Colo. Mar. 22,2012) 17. Supplemental Affidavit of Ronald N. Yordi, Foley v. Cordillera GolfClub, LLC, No. 12-0351-WJM-KMT (D. Colo. Mar. 22, 2012) 18. Order Making Order to Show Cause Absolute, Declining Jurisdiction overThis Action and Remanding to Eagle County District Court, Foley v. Cordillera Golf Club, LLC,No. 12-0351-WJM-KMT (D. Colo. Apr. 5, 2012) 3
    • Dated: Wilmington, Delaware FOLEY & LARDNER LLP July 12, 2012 Christopher Celentino Erika Morabito Mikel Bistrow Admitted Pro Hac Vice 402 West Broadway, Suite 2100 San Diego, California 92101 Telephone: (619) 234-6655 Facsimile: (619) 234-3510 -and- YOUNG CONAWAY STARGATT & TAYLOR, LLP __/s/ Joseph M. Barry _______ Michael R. Nestor (No. 3526) Joseph M. Barry (No. 4221) Donald J. Bowman, Jr. (No. 4383) Justin P. Duda (No. 5478) Rodney Square 1000 N. King Street Wilmington, Delaware 19801 Telephone: (302) 571-6600 Facsimile: (302) 571-1253 Proposed Counsel for Debtor and Debtor in Possession 4