Southlight Trust I, an affiliate of the proposed post-petition lender to Cordillera Golf Club LLC, joins the debtor's objection to moving the bankruptcy case from Delaware to Colorado. As the DIP lender, Southlight argues that keeping the case in Delaware would be more convenient and less expensive. Southlight is located in New York and has retained Delaware counsel, and it would be easier for Southlight to travel to Delaware than Colorado for hearings. The DIP loan also contemplates Southlight providing exit financing, so keeping the case in Delaware would better facilitate Southlight's ongoing involvement.
NHL announces makeup dates for Edmonton Oilers, Montreal Canadiens postponed ...Pietro Triassi Montreal
The games were postponed last week after the Canadiens’ Joel Armia and
Jesperi Kotkaniemi entered the league’s COVID-19 protocol on Monday,
March 22. Later in the week, Habs general manager Marc Bergevin confirmed one player had tested positive for COVID-19 linked to a variant.
NHL announces makeup dates for Edmonton Oilers, Montreal Canadiens postponed ...Pietro Triassi Montreal
The games were postponed last week after the Canadiens’ Joel Armia and
Jesperi Kotkaniemi entered the league’s COVID-19 protocol on Monday,
March 22. Later in the week, Habs general manager Marc Bergevin confirmed one player had tested positive for COVID-19 linked to a variant.
The Top 100 Wage Earners in Clinton County, NY in 2013John Citibois
Of the 1020 employees of Clinton County, only 258 of them make as much or less than the average wages of a working person in Clinton County. These employees may be new or well paid part time workers. The data from the Office of the State Comptroller reports total wages, not hours worked. Women do far better working for Clinton County than working for the City of Plattsburgh. Twenty one of the top 50 wage earners for Clinton County were women in 2013.
The Top 100 Wage Earners in Clinton County, NY in 2013John Citibois
Of the 1020 employees of Clinton County, only 258 of them make as much or less than the average wages of a working person in Clinton County. These employees may be new or well paid part time workers. The data from the Office of the State Comptroller reports total wages, not hours worked. Women do far better working for Clinton County than working for the City of Plattsburgh. Twenty one of the top 50 wage earners for Clinton County were women in 2013.
1. IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re Chapter 11
CORDILLERA GOLF CLUB, LLC1 dba The Case No. 12-11893 (CSS)
Club at Cordillera,
Hearing Date: July 16, 2012, 10:00 a.m.
Debtor. Objection Date: July 11, 2012
Related Docket Nos. 69, 77, 78, 95 & 118
SOUTHLIGHT TRUST I’S JOINDER TO OBJECTION OF DEBTOR TO 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 RELATED MOTIONS AND JOINDERS BY
ALPINE BANK, CPOA AND THE DISTRICT
Southlight Trust I (“Southlight”), an affiliate of Northlight Financial LLC, is the
proposed post-petition lender to the Debtor and Debtor in Possession, Cordillera Golf Club, LLC
dba The Club at Cordillera (the “Debtor”). Southlight hereby submits this Joinder (the
“Joinder”) to the Omnibus Objection of Debtor [D.I. 118] (the “Objection”) to 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 Related Motions and Joinders by Alpine Bank, CPOA and the District (collectively, the
“Transfer Venue Motion”), and states as follows:
1. Southlight opposes a transfer of this bankruptcy case. Southlight is located in
New York. Southlight has already retained Delaware bankruptcy counsel to represent it in this
bankruptcy case. It is more convenient for Southlight, as DIP lender, if the bankruptcy case
remains pending in the Delaware bankruptcy court, in the same time zone where its principal
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, Colorado
81632.
2. office is located. Further, it is more convenient for Southlight and its non-bankruptcy counsel in
this matter (located in the Midwest) to travel to Delaware for various hearings than to travel to
Colorado. In the end, it will be less expensive for Southlight to participate in the Delaware
proceedings, and therefore, the Debtor, since the Debtor will be obligated to reimburse
Southlight for its reasonable expenses.
2. The DIP loan documents also contemplate that Southlight may provide "exit"
financing to the Debtor. Although not currently bound to provide such financing, Southlight
expects to have significant ongoing negotiations and involvement in the case. Keeping the case
in Delaware will better facilitate Soughlight's participation.
3. Through this Joinder, Southlight joins the Objection and expressly adopts the
arguments raised therein.
2
3. WHEREFORE, based on the arguments set forth in the Objection and those above,
Southlight respectfully requests that the Court enter an order (i) denying the Transfer Venue
Motion, and (ii) granting Southlight such further relief as it deems just and proper.
Dated: July 11, 2012
WOMBLE CARLYLE SANDRIDGE & RICE, LLP
/s/ Ericka F. Johnson___________________
Matthew P. Ward (Del. Bar No. 4471)
Ericka F. Johnson (Del. Bar No. 5024)
222 Delaware Avenue, Suite 1501
Wilmington, Delaware 19801
Telephone: (302) 252-4338
Facsimile: (302) 661-7711
-and-
DICKINSON WRIGHT PLLC
Harlan Robins, Esq.
15 N. 4th Street
Columbus, OH 43215
Telephone: (614) 744-2575
Facsimile: (248) 433-7274
-and-
Kristi A. Katsma, Esq.
Dickinson Wright PLLC
500 Woodward Avenue, Suite 4000
Detroit, MI 48226
Telephone: (313) 223-3500
Facsimile: (313) 223-3598
Email: kkatsma@dickinsonwright.com
Counsel for Southlight Trust I
3