The document lists the potential witnesses and exhibits that the debtor intends to present at a hearing scheduled for July 16, 2012 regarding a motion to transfer venue of the bankruptcy case. The two potential witnesses listed are Daniel L. Fitchett, Jr. and Harold Bordwin. The document then lists 17 potential exhibits, which include declarations, documents filed with the court, notices, orders from other court cases, and other documents relevant to the venue transfer motion.

1. IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
Cordillera 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 Omnibus
Objection 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 to
Motion to Change Venue [Docket No. 122]
3. Debtor’s Schedules and Statements of Financial Affairs [To be Filed]
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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

2. 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 a
Certified Class of Members, to Transfer Venue [Docket No. 69]
5. Notice of Appointment of Committee of Unsecured Creditors [Docket
No. 86]
6. Declaration of Daniel L. Fitchett, Jr. in Support of Chapter 11 Petitions
and First Day Relief [Docket No. 2]
7. Emergency Motion of the Debtor for Entry of Interim and Final Orders
Pursuant 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) Granting
Security Interests and Superpriority Administrative Expense Claims, (iii) Granting Adequate
Protection to Pre-Petition Secured Parties, (iv) Authorizing the Use of Cash Collateral as
Provided 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 by
Richards, Layton & Finger, P.A. on behalf of Cheryl Foley, Thomas and Jane Wilner, Charles
and Mary Jackson and Kevin Allen [Docket No. 61]
11. Notice of Appearance and Request for Service of Papers filed by
Cordillera Property Owners Association, Inc. [Docket No. 82]
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3. 12. Notice of Appearance and Request for Service of Papers filed by
Cordillera 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 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
[Docket No. 78]
14. Order to Show Cause as to Why the Court Should Not Decline to Exercise
Jurisdiction 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 Should
Not 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 Matter
Jurisdiction, 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 Golf
Club, LLC, No. 12-0351-WJM-KMT (D. Colo. Mar. 22, 2012)
18. Order Making Order to Show Cause Absolute, Declining Jurisdiction over
This 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

4. 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
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