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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

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In re: ALLIED SYSTEMS HOLDINGS, INC., et al.1, Debtors

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Chapter 11 Case No. 12-11564 (CSS)


Ref. Nos. 538 and 539

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NOTICE TO TAKE RULE 30(b)(6) DEPOSITION UPON ORAL EXAMINATION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS PLEASE TAKE NOTICE that, pursuant to Rules 26, 30(b)(6), and 34 of the Federal Rules of Civil Procedure as made applicable to this proceeding by Rules 9014, 7026, 7030 and 7034 of the Federal Rules of Bankruptcy Procedure, BDCM Opportunity Fund II, LP, ("BDCM"), Black Diamond CLO 2005-1 Ltd. ("Black Diamond"), and Spectrum Investment Partners, L.P. ("Spectrum" collectively with BDCM and Black Diamond, the "Petitioning Creditors") by their attorneys, will take the deposition upon oral examination of a representative(s) designated by the Committee to testify on each of the topics set on the annexed Exhibit A. The deposition will take place on November 5, 2012 at 2:00 p.m. Eastern Time at the law offices of Landis Rath & Cobb LLP, 919 Market Street, Suite 1800, Wilmington, Delaware 19801, or such other time and date as agreed upon by the parties.

The Debtors in these cases, along with the federal tax identification number (or Canadian business number where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company (875688228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveway LLC (38-0365100); GACS Incorporated (58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91-0847582). The location of the Debtors corporate headquarters and the Debtors address for service of process is 2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.

PLEASE TAKE FURTHER NOTICE that, pursuant to Rule 30(b)(3) of the Federal Rules of Civil Procedure, made applicable by Bankruptcy Rule 7030, the deposition will be recorded by stenographic and/or videographic means. It will be conducted simultaneously before an officer authorized by law to administer oaths and will continue from day to day until concluded, Saturdays, Sundays and holidays excepted. The deposition is being taken for

discovery, for use at any evidentiary hearing, for use at trial, or for any purposes that are permitted by law or under the rules of this Court. Any party or persons with just cause to attend may participate and cross-examine through duly authorized and designated counsel. Dated: October 29 2012 Wilmington, Delaware LANDIS RATH & COBB LLP By:______/s/ Kerri Mumford_____________ Adam G. Landis Kerri K. Mumford 919 Market Street, Suite 600 Post Office Box 2087 Wilmington, Delaware 19899 Telephone: (302) 467-4400 Facsimile: (302) 467-4500 and Adam C. Harris David Hillman Robert J. Ward Victoria A. Lepore SCHULTE ROTH & ZABEL LLP 919 Third Avenue New York, New York 10022 Telephone: (212) 756-2000 Facsimile: (212) 593-5955 Counsel to Petitioning Creditors

EXHIBIT A DEFINITIONS 1. Unless otherwise defined below, the definitions and instructions set forth in the Local

Rules of the United States Bankruptcy Court for the District of Delaware shall apply to these areas of examination below. 2. The following additional definitions also apply to these to these areas of examination: A. Adversary Proceeding refers to the adversary proceeding captioned, Allied

System Holdings, Inc. v. American Money Management Corp., et.al, Adversary Proceeding No. 12-50947, dated October 18, 2012. B. Allied means and refers to Allied Systems Holdings, Inc. and Allied Systems,

Ltd., together with their predecessors and successors in interest, parents, subsidiaries, affiliates, directors, officers, employees, agents and attorneys. C. Committee means the Official Committee of Unsecured Creditors appointed in

this Chapter 11 case. D. Communications means any transfer of information, ideas, opinions, or

thoughts by any means, at any time or place, under any circumstances, and is not limited to written or verbal transfers between persons, but includes all other transfers, including, but not limited to, electronic transfers, transfers of information stored on computer disk or computer memory, and memoranda to file. E. Concerning means relating to, referring to, describing, evidencing or

constituting. In this regard, a document or communication concerning, a given subject matter means any document or communication that relates to, refers to, describes, evidences, constitutes, is incidental to, contains, pertains to, embodies, comprises, reflects, indicates, constitutes, records, memorializes, evaluates, considers, reviews, reports, demonstrates, 3

identifies, discusses, mentions, states, deals with, comments on, responds to, analyzes, or is in any way pertinent to that subject, including, without limitation, documents concerning the presentation of other documents. F. Correspondence means documents or communications exchanged by any means

between two or more persons. G. New York State Action refers to the case captioned, BDCM Opportunity Fund

II, LP, Black Diamond CLO 2005-1 LTD, and Spectrum Investment Partners, L.P. v. Yucaipa American Alliance Fund I, LP, and Yucaipa American Alliance (Parallel) Fund I, L.P., No. 650150/2012. H. Stay Extension Motion means the Motion of Debtor Allied Systems Holdings,

Inc. for Order Extending the Automatic Stay to Certain Non-Debtor Third Parties Pursuant to Sections 105 and 362 of the Bankruptcy Code, dated October 18, 2012. I. Stipulation means the Stipulation Among the Debtors, the DIP Agent, the DIP

Lenders and the Committee of Unsecured Creditors Regarding Postpetition Secured DIP Financing, Credit Bidding Under Section 363 of the Bankruptcy Code and Certain Administrative Matters, dated October 18, 2012. J. Yucaipa means and refers to Yucaipa American Alliance Fund I, L.P., Yucaipa

American Alliance (Parallel) Fund I, L.P., Yucaipa American Alliance Fund II, L.P., Yucaipa American Alliance (Parallel) Fund II, L.P., Yucaipa American Alliance Fund II, LLC, and Yucaipa Leveraged Finance, LLC., together with their predecessors and successors in interest, parents, subsidiaries, affiliates, directors, officers, employees, agents and attorneys.

K.

The terms all, each or any shall be construed to include all, each and any.

The connective and shall include or and vice versa. The use of the singular form of any word includes the plural and vice versa. L. Capitalized terms not defined herein shall have the meaning ascribed to them in

the Stipulation, the Stay Extension Motion, the Final DIP Order, or the DIP Financing Agreement, as applicable. AREAS OF EXAMINATION Pursuant to Federal Rule of Civil Procedure 30(b)(6) and Federal Rule of Bankruptcy Procedure 7030(b)(6), the Committees designee(s) shall testify on the Committees behalf under oath regarding the following subjects: 1. 2. 3. 4. The negotiation, drafting and execution of, and the decision to enter into, the Stipulation. All matters addressed in the Stipulation. The formulation, negotiation, or evaluation of any Yucaipa Credit Bid. All matters relating to seeking a stay of the New York State Action and consolidation

and/or centralization in the Court. 5. Motion. 6. Communications or correspondence with representatives or employees of Yucaipa or The commencement of the Adversary Proceeding and the filing of the Stay Extension

Debtors concerning the Adversary Proceeding, the Stay Extension Motion, or the Stipulation. 7. All matters which will be the subject of the hearings on the Stay Extension Motion and

the motion to approve the Stipulation.

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