Case 20-10343-LSS Doc 9779 Filed 05/09/22 Page 1 of 13
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`IN THE UNITED STATES BANKRUPTCY COURT
`FOR THE DISTRICT OF DELAWARE
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`In re:
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`BOY SCOUTS OF AMERICA AND
`DELAWARE BSA, LLC,1
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`Debtors.
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`Chapter 11
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`Case No. 20-10343 (LSS)
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`(Jointly Administered)
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`Hearing Date:
`May 25, 2022 at 2:00 p.m. (ET)
`Objection Deadline:
`May 18, 2022 at 4:00 p.m. (ET)
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`DEBTORS’ SEVENTH MOTION FOR ENTRY OF AN ORDER,
`UNDER 28 U.S.C. § 1452 AND FED. R. BANKR. P. 9006(b) AND 9027,
`EXTENDING THE PERIOD WITHIN WHICH THE DEBTORS MAY
`REMOVE CIVIL ACTIONS AND GRANTING RELATED RELIEF
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`Boy Scouts of America (the “BSA”) and Delaware BSA, LLC, the non-profit corporations
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`that are debtors and debtors in possession in the above-captioned chapter 11 cases (together, the
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`“Debtors”), submit this motion (this “Motion”), pursuant to 28 U.S.C. § 1452 and rules 9006(b)
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`and 9027 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), for entry of an
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`order, substantially in the form attached hereto as Exhibit A (the “Proposed Order”), extending
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`the period within which the Debtors may file notices of removal of claims or causes of action under
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`Bankruptcy Rule 9027 (the “Removal Period”) by an additional 120 days, as specified in the
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`Proposed Order. In support of this Motion, the Debtors respectfully state as follows:
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`STATUS OF THE CASES AND JURISDICTION
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`1.
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`The Debtors commenced these cases on February 18, 2020 (the “Petition Date”),
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`and they continue to operate their non-profit organization and manage their properties as debtors
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`1 The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification
`number, are as follows: Boy Scouts of America (6300); and Delaware BSA, LLC (4311). The Debtors’ mailing
`address is 1325 West Walnut Hill Lane, Irving, Texas 75038.
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`Case 20-10343-LSS Doc 9779 Filed 05/09/22 Page 2 of 13
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`in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. These chapter 11
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`cases are being jointly administered for procedural purposes only pursuant to Bankruptcy Rule
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`1015(b) and rule 1015-1 of the Local Rules of Bankruptcy Practice and Procedure of the United
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`States Bankruptcy Court for the District of Delaware (the “Local Rules”).
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`2.
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`On March 5, 2020, the United States Trustee for the District of Delaware (the “U.S.
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`Trustee”) appointed an official committee of tort claimants (the “Tort Claimants’ Committee”) and
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`an official committee of unsecured creditors (the “Creditors’ Committee”) pursuant to section
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`1102 of the Bankruptcy Code.
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`3.
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`On April 24, 2020, the Court appointed James L. Patton, Jr. (the “Future Claimants’
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`Representative”) as the representative of future abuse claimants pursuant to sections 105(a) and
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`1109(b) of the Bankruptcy Code.
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`4.
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`The Court has jurisdiction to consider this Motion pursuant to 28 U.S.C. § 1334
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`and the Amended Standing Order of Reference from the United States District Court for the District
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`of Delaware, dated February 29, 2012. This is a core proceeding within the meaning of 28 U.S.C.
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`§ 157(b)(2), and the Debtors confirm their consent, pursuant to Local Rule 9013-1(f), to the entry
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`of a final order or judgment by the Court in connection with this Motion if it is determined that the
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`Court, absent consent of the parties, cannot enter final orders or judgments in connection herewith
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`consistent with Article III of the United States Constitution. Venue is proper pursuant to 28 U.S.C.
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`§§ 1408 and 1409.
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`5.
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`The statutory and other bases for the relief requested in this Motion are 28 U.S.C.
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`§ 1452, Bankruptcy Rules 9006(b) and 9027 and Local Rule 9006-2.
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`2
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`CIVIL ACTIONS PENDING AGAINST THE DEBTORS
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`6.
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`The BSA is named as a defendant in numerous civil actions related to alleged
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`historical sexual abuse in Scouting. As of the date hereof, approximately 315 such actions are
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`pending in state and federal courts around the country. The Debtors have removed to federal
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`district court (or bankruptcy court, depending upon the applicable local rules) all of the abuse
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`actions against the BSA that were not already pending in federal court. The BSA is also named as
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`a defendant in several dozen civil lawsuits that are unrelated to sexual abuse. Certain of these non-
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`abuse actions remain pending against the BSA in various state courts.
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`7.
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`On March 30, 2020, the Court entered the Consent Order Pursuant to 11 U.S.C.
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`§§ 105(a) and 362 Granting the BSA’s Motion for a Preliminary Injunction, Adv. Pro. No. 20-
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`50527 (LSS) [Adv. Docket No. 54] (the “Preliminary Injunction Order”).2 Under the Preliminary
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`Injunction Order, the actions listed on Schedule 1 thereto (collectively, the “Pending Abuse
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`Actions”) were initially stayed to and including May 18, 2020 (the “Termination Date”).
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`8.
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`On May 18, 2020, the Court entered the Stipulation and Agreed Order By and
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`Among the Boy Scouts of America, the Official Committee of Survivors of Abuse, and the Official
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`Committee of Unsecured Creditors Extending the Termination Date of the Standstill Period Under
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`the Consent Order Granting the BSA’s Motion for a Preliminary Injunction Pursuant to 11 U.S.C.
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`§§ 105(a) and 362 [Adv. Docket No. 72] (the “Stipulation and Agreed Order”). The Stipulation
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`and Agreed Order extended the Termination Date to and including June 8, 2020.
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`9.
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`On June 9, 2020, the Court entered the Second Stipulation and Agreed Order By
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`and Among the Boy Scouts of America, the Official Committee of Survivors of Abuse, and the
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`2 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the
`Preliminary Injunction Order.
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`3
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`Official Committee of Unsecured Creditors Modifying the Consent Order Granting the BSA’s
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`Motion for a Preliminary Injunction Pursuant to 11 U.S.C. §§ 105(a) and 362 and Further
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`Extending the Termination Date of the Standstill Period [Adv. Docket No. 77], which further
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`extended the Termination Date to and including November 16, 2020.
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`10.
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`On November 18, 2020, the Court entered the Order Approving Third Stipulation
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`By and Among the Boy Scouts of America, the Official Committee of Survivors of Abuse, and the
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`Official Committee of Unsecured Creditors Modifying the Consent Order Granting the BSA’s
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`Motion for a Preliminary Injunction Pursuant to 11 U.S.C. §§ 105(a) and 362 and Further
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`Extending the Termination Date of the Standstill Period [Adv. Docket No. 116], which further
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`extended the Termination Date to and including March 19, 2021.
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`11.
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`On March 17, 2021, the Court entered the Order Approving Fourth Stipulation By
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`and Among the Boy Scouts of America, the Official Committee of Survivors of Abuse, and the
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`Official Committee of Unsecured Creditors Modifying the Consent Order Granting the BSA’s
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`Motion for a Preliminary Injunction Pursuant to 11 U.S.C. §§105(a) and 362 and Further
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`Extending the Termination Date of the Standstill Period [Adv. Docket No. 162], which further
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`extended the Termination Date to and including July 19, 2021.
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`12.
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`On July 21, 2021, the Court entered the Order Approving Fifth Stipulation By and
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`Among the Boy Scouts of America, the Official Committee of Survivors of Abuse, and the Official
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`Committee of Unsecured Creditors Modifying the Consent Order Granting the BSA’s Motion for
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`a Preliminary Injunction Pursuant to 11 U.S.C. §§ 105(a) and 362 and Further Extending the
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`4
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`Termination Date of the Standstill Period [Adv. Docket No. 185] (the “Fifth Stipulation and
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`Agreed Order”), which further extended the Termination Date to and including October 28, 2021.
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`13.
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`On November 8, 2021, the Court entered the Order Approving Sixth Stipulation By
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`and Among Boy Scouts of America, the Official Committee of Survivors of Abuse, and the Official
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`Committee of Unsecured Creditors Modifying the Consent Order Granting the BSA’s Motion for
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`a Preliminary Injunction Pursuant to 11 U.S.C. §§ 105(a) and 362 and Further Extending the
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`Termination Date of the Standstill Period [Adv. Docket No. 199] (the “Sixth Stipulation and
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`Agreed Order”). The Sixth Stipulation and Agreed Order further extended the Termination Date
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`to and including the date of the first omnibus hearing after the Court issues its decision confirming
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`or denying confirmation of the Debtors’ plan of reorganization.
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`14.
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`The Preliminary Injunction Order, as modified by the Sixth Stipulation and Agreed
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`Order, does not prohibit or enjoin the filing and service of a complaint for purposes of commencing
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`a claim or clause of action against a BSA Related Party alleging claims substantially similar to
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`those asserted in the Pending Abuse Actions (collectively, the “Further Abuse Actions”). The
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`BSA has filed amended versions of Schedule 1 identifying all of the Pending Abuse Actions and
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`Further Abuse Actions on a monthly basis pursuant to paragraph 11 of the Preliminary Injunction
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`Order, including most recently on May 6, 2022 [Adv. Docket No. 220]. As of such date, there
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`were more than 2,400 Further Abuse Actions pending against BSA Related Parties.
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`15.
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`Under the Preliminary Injunction Order, as modified by the Sixth Stipulation and
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`Agreed Order, upon the occurrence of the Termination Date, the relevant parties have the greater
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`of: (a) forty-five (45) days; and (b) the deadline governed by applicable non-bankruptcy law to,
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`among other things, file notices of removal in any Pending Abuse Action or Further Abuse Action.
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`5
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`PREVIOUS EXTENSIONS OF REMOVAL PERIOD
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`16.
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`On June 3, 2020, the Court entered the Order, Under 28 U.S.C. § 1452 and Fed. R.
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`Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors May Remove Civil
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`Actions [Docket No. 769], which extended the Removal Period to and including the later of: (a)
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`September 15, 2020; and (b) the date that is forty-five (45) days after the occurrence of the
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`Termination Date.
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`17.
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`On October 1, 2020, the Court entered the Second Order, Under 28 U.S.C. § 1452
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`and Fed. R. Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors May
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`Remove Civil Actions [Docket No. 1393], which extended the Removal Period to and including
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`the later of: (a) January 13, 2021; and (b) the date that is forty-five (45) days after the occurrence
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`of the Termination Date.
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`18.
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`On January 14, 2021, the Court entered the Third Order, Under 28 U.S.C. § 1452
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`and Fed. R. Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors Remove
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`Civil Actions [Docket No. 1941], which extended the Removal Period to and including the later
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`of: (a) May 13, 2021; and (b) the date that is forty-five (45) days after the occurrence of the
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`Termination Date.
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`19.
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`On May 14, 2021, the Court entered the Fourth Order, Under 28 U.S.C. § 1452
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`and Fed. R. Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors May
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`Remove Civil Actions [Docket No. 3940], which extended the Removal Period to and including
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`the later of: (a) September 10, 2021; and (b) the date that is forty-five (45) days after the occurrence
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`of the Termination Date.
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`20.
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`On September 23, 2021, the Court entered the Fifth Order, Under 28 U.S.C. § 1452
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`and Fed. R. Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors May
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`6
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`Remove Civil Actions [Docket No. 6347], which extended the Removal Period to and including
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`the later of: (a) January 10, 2022; and (b) the date that is forty-five (45) days after the occurrence
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`of the Termination Date.
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`21.
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`On January 31, 2022, the Court entered the Sixth Order, Under 28 U.S.C. § 1452
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`and Fed. R. Bankr. P. 9006(b) and 9027, Extending the Period Within Which the Debtors May
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`Remove Civil Actions [Docket No. 8579] (the “Sixth Removal Order”), which extended the
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`Removal Period to and including the later of: (a) May 10, 2022; and (b) the date that is forty-five
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`(45) days after the occurrence of the Termination Date.
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`RELIEF REQUESTED
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`22.
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`By this Motion, the Debtors request entry of the Proposed Order, substantially in
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`the form attached hereto as Exhibit A, pursuant to 28 U.S.C. § 1452 and Bankruptcy Rules 9006(b)
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`and 9027, extending the Removal Period by an additional 120 days, from the end of the current
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`Removal Period on May 10, 2022 to and including September 7, 2022 (the “Extended Removal
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`Deadline”), without prejudice to the Debtors’ right to seek further extensions thereof.3 The
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`Debtors request that the proposed Extended Removal Deadline apply to all matters specified in
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`Bankruptcy Rules 9027(a)(2) and 9027(a)(3).
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`23.
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`The Debtors further request that, with respect to any Pending Abuse Actions or
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`Further Abuse Actions, the Removal Period be extended to and including the later of:
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`(a) September 7, 2022; and (b) the date that is forty-five (45) days after the occurrence of the
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`Termination Date provided for in the Preliminary Injunction Order, as modified by the Sixth
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`3 Pursuant to Local Rule 9006-2, the filing of this Motion prior to the end of the current Removal Period serves to
`automatically extend the end of the current Removal Period until such time as the Court rules on the motion. See
`Del. Bankr. L.R. 9006-2.
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`7
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`Stipulation and Agreed Order, or the Termination Date provided for in any other order of the Court
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`that further extends the Termination Date, as applicable.
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`BASIS FOR RELIEF
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`24.
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`28 U.S.C. § 1452 provides for the removal of pending civil actions with respect to
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`which federal district courts have jurisdiction under 28 U.S.C. § 1334. Section 1452(a) provides,
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`in pertinent part, as follows:
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`A party may remove any claim or cause of action in a civil action
`other than a proceeding before the United States Tax Court or a civil
`action by a governmental unit to enforce such governmental unit’s
`police or regulatory power, to the district court for the district where
`such civil action is pending, if such district court has jurisdiction of
`such claim or cause of action under section 1334 of this title.
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`28 U.S.C. § 1452(a).
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`25.
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`Bankruptcy Rule 9027 establishes the deadline for filing notices of removal of
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`claims or causes of action. Bankruptcy Rule 9027(a)(2) provides, in pertinent part, as follows:
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`If the claim or cause of action in a civil action is pending when a
`case under the [Bankruptcy] Code is commenced, a notice of
`removal may be filed [in the bankruptcy court] only within the
`longest of (A) 90 days after the order for relief in the case under the
`[Bankruptcy] Code, (B) 30 days after entry of an order terminating
`a stay, if the claim or cause of action in a civil action has been stayed
`under § 362 of the [Bankruptcy] Code, or (C) 30 days after a trustee
`qualifies in a chapter 11 reorganization case but not later than 180
`days after the order for relief.
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`Fed. R. Bankr. P. 9027(a)(2).
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`26. With respect to postpetition actions, Bankruptcy Rule 9027(a)(3) provides that a
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`notice of removal may be filed
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`only within the shorter of (A) 30 days after receipt, through service
`or otherwise, of a copy of the initial pleading setting forth the claim
`or cause of action sought to be removed, or (B) 30 days after receipt
`of the summons if the initial pleading has been filed with the court
`but not served with the summons.
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`Fed. R. Bankr. P. 9027(a)(3).
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`27.
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`Finally, Bankruptcy Rule 9006(b)(1) provides that the Court may extend unexpired
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`time periods, including the removal periods under Bankruptcy Rule 9027, without notice, upon a
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`showing of cause. See Fed. R. Bankr. P. 9006(b)(1).
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`28.
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`It is well settled that this Court is authorized to extend the removal periods provided
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`under Bankruptcy Rule 9027. See, e.g., Pacor, Inc. v. Higgins, 743 F.2d 984, 996 n.17 (3d Cir.
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`1984) (stating that, under Bankruptcy Rule 9006(b), “it is clear that the court may grant such an
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`extension [of time to remove]”), overruled in part on other grounds by Things Remembered, Inc.
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`v. Petrarca, 516 U.S. 124, 134–35 (1995); Caperton v. A.T. Massey Coal Co., 251 B.R. 322, 325
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`(S.D. W. Va. 2000) (explaining that Bankruptcy Rule 9006(b) allows a court to enlarge the time
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`period for removing actions under Bankruptcy Rule 9027); Saint Joseph’s Hosp. v. Dep’t of Pub.
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`Welfare of Pa. (In re Saint Joseph’s Hosp.), 103 B.R. 643, 648 (Bankr. E.D. Pa. 1989) (extending
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`the 90-day time period in which to seek removal of pending state court litigation); Jandous Elec.
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`Constr. Corp. v. City of New York (In re Jandous Elec. Constr. Corp.), 106 B.R. 48, 50 (Bankr.
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`S.D.N.Y. 1989) (holding that the removal period may be expanded pursuant to Bankruptcy Rule
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`9006); In re World Fin. Servs. Ctr. Inc., 81 B.R. 33, 39 (Bankr. S.D. Cal. 1987) (stating that the
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`court may enlarge the time period for filing removal notices under Bankruptcy Rule 9027(a)(3)).
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`29.
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`Here, cause exists to further extend the Removal Period. As noted above, the BSA
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`is a defendant in approximately 315 civil lawsuits related to alleged historical sexual abuse in
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`Scouting. The Debtors have removed to federal district court (or bankruptcy court, depending
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`upon the applicable local rules) all of the Pending Abuse Actions not already pending in federal
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`court. Moreover, as of May 6, 2022, more than 2,400 Further Abuse Actions had been filed against
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`BSA Related Parties since the Petition Date and remain pending, subject to the stay imposed by
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`the Preliminary Injunction Order, as modified by the Sixth Stipulation and Agreed Order, in state
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`9
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`courts across the country. In addition, several dozen non-abuse actions remain pending against
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`the BSA in various state courts.
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`30.
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`Since entry of the Sixth Removal Order on January 31, 2022, the Debtors have
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`continued to devote significant time and resources to preserving and maximizing the value of their
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`estates and implementing their restructuring strategy. These efforts have included, among other
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`things: (a) negotiating further revisions to the Debtors’ plan of reorganization (the “Plan”),
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`including the exhibits thereto, with the Ad Hoc Committee of Local Councils, the Tort Claimants’
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`Committee, the Coalition of Abused Scouts for Justice, the Future Claimants’ Representative,
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`counsel to law firms of Pfau Cochran Verteris Amala PLLC and the Zalkin Law Firm, P.C, the
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`Creditors’ Committee, JPM, and various chartered organization groups and insurers;4
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`(b) negotiating and revising voluminous Plan documents;5 (c) engaging in extensive mediation and
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`4 On February 15, 2022, the Debtors filed the Third Modified Fifth Amended Chapter 11 Plan of Reorganization
`for Boy Scouts of America and Delaware BSA, LLC [Docket No. 8813], and on April 22, 2022, the Debtors filed
`the Third Modified Fifth Amended Chapter 11 Plan of Reorganization (With Technical Modifications) for Boy
`Scouts of America and Delaware BSA, LLC [Docket No. 9696]. In addition, the Debtors filed various exhibits to
`the Plan, including settlement agreements and term sheets with various settling parties: (i) on February 15, 2022,
`the Debtors filed the Notice of Filing of Exhibits I-1 and J-1 to Debtors’ Third Modified Fifth Amended Chapter
`11 Plan of Reorganization and Redlines Thereof [Docket No. 8816], and the Notice of Filing of Exhibits I-2, I-3,
`I-4 and J-2 to Debtors’ Third Modified Fifth Amended Chapter 11 Plan of Reorganization [Docket No. 8817];
`(ii) on February 18, 2022, the Debtors filed the Notice of Filing of Exhibits I-2, I-3, I-4 and J-2 to Debtors’ Third
`Modified Fifth Amended Chapter 11 Plan of Reorganization [Docket No. 8907], and the Notice of Filing of
`Exhibit J-1 to Debtors’ Third Modified Fifth Amended Chapter 11 Plan of Reorganization [Docket No. 8908];
`and (iii) on April 21, 2022, the Debtors filed the Notice of Filing of Addendum to Exhibit J-1 to the Debtors’
`Third Modified Fifth Amended Chapter 11 Plan of Reorganization [Docket No. 9695].
`5 Since the entry of the Sixth Removal Order, the Debtors have filed various Plan documents reflecting such
`revisions: (i) on February 3, 2022, the Debtors filed the Notice of Filing of Third Amended Plan Supplement to
`Second Modified Fifth Amended Chapter 11 Plan of Reorganization for Boy Scouts of America and Delaware
`BSA, LLC [Docket No. 8647]; (ii) on February 15, 2022, the Debtors filed the Notice of Filing of Fourth Amended
`Plan Supplement to Third Modified Fifth Amended Chapter 11 Plan of Reorganization for Boy Scouts of America
`and Delaware BSA, LLC [Docket No. 8815]; (iii) on March 2, 2022, the Debtors filed the Notice of Filing of Fifth
`Amended Plan Supplement to Third Modified Fifth Amended Chapter 11 Plan of Reorganization for Boy Scouts
`of America and Delaware BSA, LLC [Docket No. 9097]; (iv) on April 5, 2022, the Debtors filed the Notice of
`Filing of Sixth Amended Plan Supplement to Third Modified Fifth Amended Chapter 11 Plan of Reorganization
`for Boy Scouts of America and Delaware BSA, LLC [Docket No. 9594], as modified on April 7, 2022 by the
`Notice of Corrected Assumption Schedule in Sixth Amended Plan Supplement [Docket No. 9615]; and (v) on April
`22, 2022, the Debtors filed the Notice of Filing of Seventh Amended Plan Supplement to Third Modified Fifth
`Amended Chapter 11 Plan of Reorganization (With Technical Modifications) for Boy Scouts of America and
`Delaware BSA, LLC [Docket No. 9698].
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`mediated settlement negotiations with various stakeholders, including representatives of abuse
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`survivors, local councils, chartered organizations, and insurers, resulting in, among other things,
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`settlement term sheets with the Tort Claimant’s Committee and various abuse survivor
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`representatives and with the Roman Catholic Ad Hoc Committee and which ultimately led to
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`overwhelming support for the Plan;6 (d) filing a brief in support of and responding to objections
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`to the Plan; (e) negotiating and revising the proposed confirmation order;7 and (f) preparing for
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`and arguing in support of confirmation of the plan of reorganization at the confirmation hearing.
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`As a result of these efforts, among others, the Debtors have not determined whether to file notices
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`of removal with respect to any actions pending against the BSA.
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`31.
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`The Debtors are therefore requesting a further extension of the Removal Period
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`prescribed by Bankruptcy Rule 9027(a) and entry of the Proposed Order to ensure the Debtors do
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`not forfeit their valuable right to remove claims or causes of action if they deem it appropriate to
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`do so. The rights of the Debtors’ adversaries in any litigation will not be prejudiced by this
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`proposed extension of the Removal Period because any party to an action that the Debtors remove
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`may seek to remand the action to state court under 28 U.S.C. § 1452(b).8
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`32.
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`For the reasons stated above, the Debtors submit that cause exists to grant the relief
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`requested herein, which relief is in the best interests of their estates.
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`6
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`Information regarding each of the settlement term sheets can be found in the Eleventh Mediator’s Report [Docket
`No. 8772] and the Twelfth Mediator’s Report [Docket No. 9386].
`7 On March 3, 2022, the Debtors filed the Notice of Filing of Proposed Findings of Fact, Conclusions of Law, and
`Order Confirming the Third Modified Fifth Amended Chapter 11 Plan of Reorganization for Boy Scouts of
`America and Delaware BSA, LLC [Docket No. 9146]. On April 22, 2022, the Debtors revised the proposed order
`to reflect negotiations and other revisions and filed the Notice of Filing of Revised Proposed Findings of Fact,
`Conclusions of Law, and Order Confirming the Third Modified Fifth Amended Chapter 11 Plan of Reorganization
`(With Technical Modifications) for Boy Scouts of America and Delaware BSA, LLC and Blackline Thereof
`[Docket No. 9699].
`8 The Debtors reserve their right to contest any remand.
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`11
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`NOTICE
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`33.
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`Notice of this Motion will be provided to (i) the Office of the United States Trustee
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`for the District of Delaware; (ii) counsel to the Tort Claimants’ Committee; (iii) counsel to the
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`Creditors’ Committee; (iv) counsel to the Future Claimants’ Representative; (v) counsel to the Ad
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`Hoc Committee of Local Councils; (vi) counsel to JPMorgan Chase Bank National Association;
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`(vii) the County Commission of Fayette County (West Virginia), as issuer of those certain
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`Commercial Development Revenue Bonds (Arrow WV Project), Series 2010A, 2010B and 2012;
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`and (viii) any party that has requested notice pursuant to Bankruptcy Rule 2002. The Debtors
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`submit that, in light of the nature of the relief requested herein, no other or further notice need be
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`given.
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`CONCLUSION
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`WHEREFORE, the Debtors respectfully request that the Court enter the Proposed Order,
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`substantially in the form attached hereto as Exhibit A, granting the relief requested in this Motion
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`and such other and any further relief as the Court may deem just and proper.
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`[Remainder of Page Intentionally Left Blank]
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`12
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`Case 20-10343-LSS Doc 9779 Filed 05/09/22 Page 13 of 13
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`Dated: May 9, 2022
` Wilmington, Delaware
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`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
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`/s/ Tori L. Remington
`Derek C. Abbott (No. 3376)
`Andrew R. Remming (No. 5120)
`Paige N. Topper (No. 6470)
`Tori L. Remington (No. 6901)
`1201 North Market Street, 16th Floor
`P.O. Box 1347
`Wilmington, Delaware 19899-1347
`Telephone: (302) 658-9200
`Email: dabbott@morrisnichols.com
`aremming@morrisnichols.com
`ptopper@morrisnichols.com
`tremington@morrisnichols.com
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` –
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` and –
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`WHITE & CASE LLP
`Jessica C. Lauria (admitted pro hac vice)
`1221 Avenue of the Americas
`New York, New York 10020
`Telephone: (212) 819-8200
`Email: jessica.lauria@whitecase.com
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` –
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` and –
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`WHITE & CASE LLP
`Michael C. Andolina (admitted pro hac vice)
`Matthew E. Linder (admitted pro hac vice)
`Laura E. Baccash (admitted pro hac vice)
`Blair M. Warner (admitted pro hac vice)
`111 South Wacker Drive
`Chicago, Illinois 60606
`Telephone: (312) 881-5400
`Email: mandolina@whitecase.com
` mlinder@whitecase.com
`laura.baccash@whitecase.com
`blair.warner@whitecase.com
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`ATTORNEYS FOR THE DEBTORS AND
`DEBTORS IN POSSESSION
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`13
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