City of Detroit, Michigan
Case Number 13-53846

Motions, Briefs and Other Papers



The Court finds that it is in the best interest of the public, the parties in interest, the Court, and the Clerk of Court, that some documents and audio files be made available through the Court’s web site. Documents in this case that are not made available through this web site are available at the Court for viewing from a public terminal or printed for a fee. Documents and audio files that are not made available through the web site are also available through PACER, a national electronic federal court case database, as well as this Court’s Case Management/Electronic Case Filing (CM/ECF) database. Information about PACER and CM/ECF may be obtained from the Court’s web site on the main page.

360 08/16/2013

Objection of Financial Guaranty Insurance Company to Motion of Debtor for Entry of an Order (i) Authorizing the Assumption of That Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(A) of the Bankruptcy Code, (ii) Approving Such Agreement Pursuant to Rule 9019, and (iii) Granting Related Relief Filed by Creditor Financial Guaranty Insurance Company (RE: related document(s)17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such). (Attachments: #1 Declaration of Alfredo R. Perez #2 Exhibit A to Perez Declaration #3 Exhibit B to Perez Declaration #4 Exhibit C to Perez Declaration #5 Exhibit D to Perez Declaration #6 Exhibit E to Perez Declaration #7 Exhibit F to Perez Declaration #8 Exhibit G to Perez Declaration #9 Exhibit H to Perez Declaration #10 Exhibit I to Perez Declaration #11 Exhibit J to Perez Declaration #12 Exhibit K to Perez Declaration #13 Exhibit L to Perez Declaration #14 Exhibit M to Perez Declaration #15 Exhibit N to Perez Declaration #16 Exhibit O to Perez Declaration #17 Exhibit P to Perez Declaration #18 Exhibit Q to Perez Declaration #19 Exhibit R to Perez Declaration #20 Exhibit S to Perez Declaration #21 Exhibit T to Perez Declaration #22 Exhibit U to Perez Declaration #23 Declaration of Stephen Spencer #24 Exhibit 1 to Spencer Declaration #25 Exhibit 2 to Spencer Declaration) (James, Mark) (Entered: 08/16/2013)

359 08/16/2013

Verified Statement Pursuant to F.R.B.P. 2019 Filed by Interested Parties Dexia Credit Local, Dexia Holdings, Inc., Norddeutsche Landesbank Luxembourg, S.A., on behalf of Norddeutsche Landesbank Covered Finance Bank S.A. (Fish, Deborah) (Entered: 08/16/2013)

357 08/16/2013

Objection to (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such, 157 Corrected Motion (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a)) -- Joinder of Assured Guaranty Municipal Corp. in Objection of Ambac Assurance Corporation to Motion for Entry of an Order (i) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(A) of the Bankruptcy Code, (ii) Approving Such Agreement Pursuant to Rule 9019, and (iii) Granting Related Relief Docket No. 348 -- Filed by Creditor Assured Guaranty Municipal Corp. (Attachments: #1 Exhibit A) (Larose, Lawrence) (Entered: 08/16/2013)

353 08/16/2013

Objection to (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such, 157 Corrected Motion (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a)) NATIONAL PUBLIC FINANCE GUARATEE CORPORATIONS JOINDER TO THE OBJECTION OF AMBAC ASSURANCE CORPORATION TO MOTION FOR ENTRY OF AN ORDER (I) AUTHORIZING THE ASSUMPTIO OF THAT CERTAIN FORBEARANCE AND OPTION TERMINATION AGREEMENT PURSUANT TO SECTION 365(a) OF THE BANKRUPTCY CODE, (II) APPROVING SUCH AGREEMENT PURSUANT TO RULE 9019, AND (III) GRANTING RELATED RELIEF Filed by Creditor National Public Finance Guarantee Corporation (Novetsky, Eric) (Entered: 08/16/2013)

348 08/16/2013

Objection to (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such, 157 Corrected Motion (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a)) Filed by Interested Party Ambac Assurance Corporation (Attachments: #1 Index Index of Exhibits #2 Exhibit 1 #3 Exhibit 2 #4 Exhibit 3 #5 Exhibit 4 #6 Exhibit 5 #7 Exhibit 6 #8 Exhibit 7 #9 Exhibit 8) (Best, Brendan) (Entered: 08/16/2013)

346 08/16/2013

Ex Parte Motion to Increase Page Limit Filed by Interested Party Ambac Assurance Corporation (Best, Brendan) (Entered: 08/16/2013)

345 08/16/2013

Witness List/ Debtor's List of Exhibits and Witnesses Related to the Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance Agreement and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such Agreement Pursuant to Rule 9019, and (III) Granting Related Relief Filed by Debtor In Possession City of Detroit, Michigan. (Heiman, David) (Entered: 08/16/2013)

343 08/16/2013

Objection to (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a) of the Bankruptcy Code, (II) Approving Such, 157 Corrected Motion (related document(s): 17 Motion to assume Lease or Executory Contract /Motion of Debtor for Entry of an Order (I) Authorizing the Assumption of that Certain Forbearance and Optional Termination Agreement Pursuant to Section 365(a)) Filed by Creditor Retired Detroit Police Members Association (Taunt, Meredith) (Entered: 08/16/2013)

342 08/16/2013

Response to (related document(s): 310 Corrected Motion (related document(s): 299 Emergency Motion for Clarification of the July 25, 2013 Stay Order filed by Creditor Robert Davis, 300 Emergency Motion for Clarification of July 25, 2013 Stay Order (Exhibits A-E for Exhibit 6) / Debtor's Response to Petitioner Robert Davis' Emergency Motion for Clarification of the Court's July 25, 2013 Stay Order (Corrected) Filed by Debtor In Possession City of Detroit, Michigan (Heiman, David) (Entered: 08/16/2013)

341 08/16/2013

Brief in Opposition to Motion for Relief from Automatic Stay Filed by Shirley A. Scott Filed by Debtor In Possession City of Detroit, Michigan (RE: related document(s)340 Objection). (Lennox, Heather) (Entered: 08/16/2013)

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