10000000038

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10000000038

  1. 1. IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE___________________________________In re: ) Chapter 11 )ALLIED SYSTEMS HOLDINGS, INC., ) Case No. 12-11564 (CSS) ) Alleged Debtor. ) Honorable Christopher S. Sontchi___________________________________ ) NOTICE OF APPEARANCE AND REQUEST FOR ELECTRONIC NOTICE FOR UNITED STATES GOVERNMENT ATTORNEY FRANK A. ANDERSON PLEASE TAKE NOTICE that the Pension Benefit Guaranty Corporation (“PBGC”), anagency of the United States Government and a creditor in the above-captioned case, hereby filesthis notice of appearance and request for electronic notice pursuant to Rule 9010(b) of the FederalRules of Bankruptcy Procedure (the “Bankruptcy Rules”), and requests, pursuant to Section1109(b) of Title 11, United States Code and Bankruptcy Rules 2002(j)(4), 3017(d) and 9007, thatnotice of all matters which may come before the Court concerning the above-captioned case anddebtor be given to and served upon PBGC as listed below. This request includes, inter alia, the notices and papers referred to in Bankruptcy Rules2002, 3017 (including all disclosure statements and plans of reorganization) and 9007, notices ofany orders, applications, complaints, demands, hearings, motions, petitions, pleadings or requests,and any other documents brought before this Court in this case, whether formal or informal,ex parte or on notice, written or oral, or transmitted or conveyed by mail, electronic mail, personaldelivery, telephone, facsimile, or otherwise. 1
  2. 2. PLEASE TAKE FURTHER NOTICE that this entry of appearance and request for noticeis without prejudice to PBGC’s rights, remedies, and claims against other entities or any objectionthat may be made to the jurisdiction or venue of the Court or venue of this case, and shall not bedeemed or construed to be a waiver of PBGC’s rights: (i) to have final orders and non-corematters entered only after de novo review by a district court, (ii) to trial by jury in any proceedingsso triable in this case or in any controversy or proceeding related to this case, (iii) to have thedistrict court withdraw the reference in any matter subject to mandatory or discretionarywithdrawal, or (iv) to assert any other rights, claims, actions, defenses, setoffs orrecoupments to which PBGC is or may be entitled in law or in equity, all of which PBGC expresslyreserves.DATED: May 23, 2012 Respectfully submitted, Washington, D.C. /s/ Frank A. Anderson Frank A. Anderson, Attorney Pension Benefit Guaranty Corp. Office of the Chief Counsel 1200 K Street, N.W. Washington, D.C. 20005-4026 Ph: 202-326-4020, ext. 3759 Fax: 202-326-4112 Emails: anderson.frank@pbgc.gov and efile@pbgc.gov 2
  3. 3. IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE___________________________________In re: ) Chapter 11 )ALLIED SYSTEMS HOLDINGS, INC., ) Case No. 12-11564 (CSS) ) Alleged Debtor. ) Honorable Christopher S. Sontchi___________________________________ ) CERTIFICATION OF UNITED STATES GOVERNMENT ATTORNEY I, Frank A. Anderson, am an attorney representing the Pension Benefit GuarantyCorporation (“PBGC”), a creditor in this case. The PBGC is a United States Governmentcorporation that administers and enforces the pension plan termination program established underTitle IV of the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended,29 U.S.C. §§ 1001-1461 (2006 & Supp. IV 2010). I certify that I am a member in good standing of the bars of the District of Columbia and theUnited States District Court of the Eastern District of Wisconsin. I further state that I will bebound by the Local Rules of this Court and submit to the jurisdiction of this Court for disciplinarypurposes.DATED: May 23, 2012 Respectfully submitted, Washington, D.C. /s/ Frank A. Anderson Frank A. Anderson Attorney PENSION BENEFIT GUARANTY CORP. Office of the Chief Counsel 1200 K Street, N.W. Washington, D.C. 20005-4026 Ph: 202-326-4020, ext. 3759 Fax: 202-326-4112 E-mails: anderson.frank@pbgc.gov and efile@pbgc.gov
  4. 4. CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of May 2012, I caused a copy of the Pension BenefitGuaranty Corporation’s Notice of Appearance and Request for Electronic Notice for UnitedStates Government Attorney Frank A. Anderson and Certification of United StatesGovernment Attorney to be served electronically or by First-Class Mail on the following:Allied Systems Holdings, Inc. Christopher M. Samis2711 Centerville Road Mark D. CollinsSuite 400 Richards, Layton & Finger, P.A.Wilmington, DE 19808 920 N. King StreetAlleged Debtor One Rodney SquareVia First Class Mail Wilmington, DE 19801 Alleged Debtor’s Counsel Via CM/ECFJeffrey W. Kelley Adam C. HarrisEzra H. Cohen David M. HillmanTroutman Sanders LLP Robert J. WardBank of America Plaza Victoria A. Lepore600 Peachtree Street, Suite 5200 Schulte Roth & Zabel LLPAtlanta, Georgia 919 Third AvenueAlleged Debtor’s Counsel New York, NY 10022Via First Class Mail Counsel for Petitioning Creditors Via CM/ECFKerri K. Mumford Office of the United States TrusteeLandis Rath & Cobb LLP 844 King Street, Room 2207919 Market Street Lockbox #35Suite 1800 Wilmington, DE 19899-0035Wilmington, DE 19801 U.S. TrusteeCounsel for Petitioning Creditors Via CM/ECFVia CM/ECF /s/ Frank A. Anderson Frank A. Anderson

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