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.

6999 08/22/2014

Motion to Exclude Certain of the Expert Opinions of Martha Kopacz Under Federal Rule of Evidence 702 Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Expert Report of Martha Kopacz # 8 Exhibit 6 B - Excerpts of July 31, 2014 M. Kopacz Deposition Transcript # 9 Exhibit 6 C - Order Appointing Expert Witness [Docket No. 4215] # 10 Exhibit 6 D - Excerpts of July 14, 2014 R. Cline Deposition Transcript # 11 Exhibit 6 E - Excerpts of July 15, 2014 G. Malhotra Deposition Transcript # 12 Exhibit 6 F - Excerpts of July 24, 2014 C. Sallee Deposition Transcript) (Hackney, Stephen) (Entered: 08/22/2014)

6997 08/22/2014

Motion Syncora Guarantee Inc. and Syncora Capital Assurance Inc.'s Motion to Exclude the Testimony of John W. Hill Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Expert Report of John Hill # 8 Exhibit 6 B - Excerpts of July 18, 2014 J. Hill Deposition Transcript # 9 Exhibit 6 C - Excerpts of Expert Report of Martha Kopacz # 10 Exhibit 6 D - Revenue Consensus Conference Report (3/18/14) # 11 Exhibit 6 E - 2/4/14 Email from J. Naglick re: FAB Detroit Revenue Conference) (Hackney, Stephen) (Entered: 08/22/2014)

6994 08/22/2014

Amended Motion To Exclude Testimony Of Martha Kopacz Under Fed. R. Evid. 702 In Connection With Certain Of Her Expert Opinions Contained In Her Expert Report Filed by Creditor Oakland County, Michigan (Fischer, Joseph) (Entered: 08/22/2014)

6990 08/22/2014

Motion / Financial Guaranty Insurance Company's Motion in Limine to Preclude the Introduction of Evidence or Testimony Regarding Certain Matters Previously Deemed Irrelevant by the Court or the City of Detroit Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service # 5 Exhibit None [No Affidavit] # 6 Exhibit July 21-22, 2014, Deposition Transcript of Kevyn Orr (excerpted) # 7 Exhibit July 22, 2014 Expert Witness Report of Stuart Ira Wohl (excerpted) # 8 Exhibit August 13, 2014 Deposition Transcript of Stuart Ira Wohl (excerpted) # 9 Exhibit July 31, 2014 Deposition Transcript of Rip Rapson (excerpted) # 10 Exhibit Emails (K001265-1266; 1272-1273) # 11 Exhibit August 4, 2014 Deposition Transcripts of D. Muchmore (excerpted)) (Perez, Alfredo) (Entered: 08/22/2014)

6985 08/22/2014

Motion / Financial Guaranty Insurance Company's Motion in Limine to Preclude the Introduction of Evidence or Testimony Regarding Matters Withheld from Discovery on the Basis of the Mediation Order Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service # 5 Exhibit None [No Affidavit] # 6 Exhibit 7/22/2014 Deposition Transcript of K. Orr (excerpted) # 7 Exhibit 7/31/2014 Deposition Transcript of R. Rapson (excerpted) # 8 Exhibit 8/4/2014 Deposition Transcript of B. Stibitz (excerpted) # 9 Exhibit 8/4/2014 Deposition Transcript of D. Muchmore (excerpted) # 10 Exhibit 7/22/2014 Deposition Transcript of A. Erickson (excerpted) # 11 Exhibit 7/25/2014 Deposition Transcript of E. Jenkins (excerpted) # 12 Exhibit City of Detroit Plan Confirmation Factual Propositions # 13 Exhibit 7/29/2014 Deposition Transcript of D. Gilbert (excerpted)) (Perez, Alfredo) (Entered: 08/22/2014)

6983 08/22/2014

Motion / Financial Guaranty Insurance Company's Motion to Exclude the Expert Opinion of Michael Plummer Regarding Discount Factors Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice of Motion and Opportunity to Object # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service [To be filed separately] # 5 Exhibit None [No Affidavit] # 6 Exhibit Expert Witness Report of Michael Plummer # 7 Exhibit Expert Deposition of Michael Plummer) (Perez, Alfredo) (Entered: 08/22/2014)

6982 08/22/2014

Motion in Limine Barring the City and Plan Supporters from Introducing Evidence Regarding the Potential Personal Hardship of Pensioners Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 26, 2014 Hearing Transcript # 8 Exhibit 6 B - August 6, 2014 Hearing Transcript # 9 Exhibit 6 C - July 22, 2014 K. Orr Deposition Transcript # 10 Exhibit 6 D - 6/13/14 Email from G. Shumaker to B. Arnault) (Hackney, Stephen) (Entered: 08/22/2014)

6979 08/22/2014

Motion in Limine Barring the City from Introducing Communications Protected by the Court's Mediation Order Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 30, 2014 G. Bowen Deposition Transcript # 8 Exhibit 6 B - July 2, 2014 M. Hall Deposition Transcript # 9 Exhibit 6 C - July 14, 2014 G. Malhotra Deposition Transcript # 10 Exhibit 6 D - July 16, 2014 K. Buckfire Deposition Transcript # 11 Exhibit 6 E - July 22, 2014 K. Orr Deposition Transcript # 12 Exhibit 6 F - Plan Confirmation Factual Propositions # 13 Exhibit 6 G - August 13, 2014 S. Taranto Deposition Transcript # 14 Exhibit 6 H - May 28, 2014 Hearing Transcript) (Hackney, Stephen) (Entered: 08/22/2014)

6978 08/22/2014

Motion in Limine to Preclude Debtor from Offering Evidence Relating to (A) the Recoveries of Classes 10 and 11 Independent of the Funds from the DIA Funding Parties and the State and (B) the Topics Identified in Syncora's Subpoenas to the Foundations Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 26, 2014 Hearing Transcript # 8 Exhibit 6 B - John S. and James L. Knight Foundation Subpoena) (Hackney, Stephen) (Entered: 08/22/2014)

6975 08/22/2014

Motion in Limine Barring the City from Introducing Evidence Regarding the Combined Recoveries of Pension and OPEB Claims Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Nov. 8, 2013 Eligibility Hearing Transcript # 8 Exhibit 6 B - July 16, 2014 K. Buckfire Deposition Transcript # 9 Exhibit 6 C - July 22, 2014 K. Orr Deposition Transcript # 10 Exhibit 6 D - July 30, 2014 email from G. Shumaker to S. Hackney # 11 Exhibit 6 E - March 5, 2014 Hearing Transcript) (Hackney, Stephen) (Entered: 08/22/2014)

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