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City of Detroit - 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.



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) Joinder to Limited Objection of Ad Hoc COPS Holders Filed by Creditor DEPFA Bank PLC (Newbury, Karen) (Entered: 08/16/2013)

Objection to (related document(s): 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)) of the Bankruptcy Code, (II) Approving Such Agreement Pursuant to Rule 9019, and (III) Granting Related Relief 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)

Objection to (related document(s): 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 David Sole (Attachments: #1 Index #2 Exhibit #3 Exhibit #4 Exhibit #5 Exhibit #6 Exhibit #7 Exhibit #8 Exhibit #9 Exhibit #10 Exhibit) (Goldberg, Jerome) (Entered: 08/16/2013)
PDF icon docket361 - Attachment 1.pdf PDF icon docket361 - Attachment 10.pdf PDF icon docket361 - Attachment 2.pdf PDF icon docket361 - Attachment 3.pdf PDF icon docket361 - Attachment 4.pdf PDF icon docket361 - Attachment 5.pdf PDF icon docket361 - Attachment 6.pdf PDF icon docket361_-_Attachment_7.pdf PDF icon docket361 - Attachment 8.pdf PDF icon docket361 - Attachment 9.pdf

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)
PDF icon Declaration of Alfredo R. Perez.pdf PDF icon docket360 - ExhibitI.pdf PDF icon docket360 - ExhibitA.pdf PDF icon docket360 - ExhibitB.pdf PDF icon docket360 - ExhibitC.pdf PDF icon docket360 - ExhibitD.pdf PDF icon docket360 - ExhibitE.pdf PDF icon docket360_-_ExhibitF.pdf PDF icon docket360 - ExhibitG.pdf PDF icon docket360 - ExhibitH.pdf

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)

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)
PDF icon ExhibitA.pdf

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)

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)
PDF icon Index of Exhibits.pdf PDF icon Exhibit1.pdf PDF icon Exhibit2.pdf PDF icon Exhibit3.pdf PDF icon Exhibit4.pdf PDF icon Exhibit5.pdf PDF icon Exhibit6_2.pdf PDF icon Exhibit7.pdf PDF icon Exhibit8.pdf

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

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)

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)

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)

Objection to (related document(s): 268 Motion for Relief from Stay Re: 90 Million Dollars in Federal Assistance. Receipt Number 554544, Fee Amount $176,) / Debtor's Objection to Motion for Relief from Automatic Stay Filed by Shirley A. Scott Filed by Debtor In Possession City of Detroit, Michigan (Lennox, Heather) (Entered: 08/16/2013)

Response to (related document(s): 58 Motion to Expedite Hearing (related documents 18 Generic Motion, 19 Generic Motion, 39 Generic Motion, 53 Generic Motion, 56 Generic Motion) /Ex Parte Motion of the Debtor for the Entry of an Order (A) Scheduling an Expedited Hearing on C, 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) Filed by Interested Party State of Michigan (Attachments: #1 Exhibit Exhibit A #2 Exhibit Proof of Service) (Flancher, Steven) (Entered: 08/15/2013)
PDF icon Exhibit A.pdf PDF icon Proof of Service.pdf

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 Retired Detroit Police and Fire Fighers Association (Morris, Thomas) (Entered: 08/15/2013)

Motion Notice of Pendency of Defendant Syncora Guarantee Inc.'s Emergency Motion to Dissolve the Temporary Restraining Order and Conduct Expedited Discovery and Ex Parte Motion for Expedited Hearing Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: #1 Summary of Attachments #2 Exhibit 1 - Proposed Form of Order Granting Expedited Hearing #3 Exhibit 1(A) - Proposed Form of Order Dissolving the Ex Parte TRO #4 Exhibit 2 - Notice [Not Required] #5 Exhibit 3 - None [Brief Not Required] #6 Exhibit 4 - None [Separate Certificate of Service to be Filed] #7 Exhibit 5 - Affidavits [None] #8 Exhibit 6(A) - Syncora's Emergency Motion to Dissolve the TRO #9 Exhibit 6(B) - Citys Response to Emergency Motion to Dissolve the TRO #10 Exhibit 6(C) - Syncora's Reply to Response re Emergency Motion to Dissolve TRO #11 Exhibit 6(D) - City's Brief in Opposition to Emergency Motion to Dissolve TRO #12 Exhibit 6(E) - City's Motion for Protective Orde #13 Exhibit 6(F) - Syncoras Notice of Proposed Stipulated Order #14 Exhibit 6(G) - Syncora's Proposed Stipulated Order #15 Exhibit 6(H) - City's Response to Proposed Stipulated Orde #16 Exhibit 6(I) - Syncora's Response to Motion for Protective Order) (Bennett, Ryan) (Entered: 08/09/2013)
PDF icon Summary of Attachments.pdf PDF icon Exhibit 6C.pdf PDF icon Exhibit 1.pdf PDF icon Exhibit 1A.pdf PDF icon Exhibit 2.pdf PDF icon Exhibit 3.pdf PDF icon Exhibit 4.pdf PDF icon Exhibit_5.pdf PDF icon Exhibit 6A.pdf PDF icon Exhibit 6B.pdf

Motion for Relief from Stay and Waiving the FRBP 4001 (a)(3) Re: Relief from the Automatic Stay to Continue Adversary Proceedings Filed against the Debtor in Chapter 13 Bankruptcy Cases , Proposed Order, Notice and Opportunity to Respond, Brief in Support and Certificate of Service (with attached Matrix). Fee Amount $176, Filed by Interested Party Kimberli Janette Powell (Carpenter, Corey) (Entered: 08/09/2013)

Ex Parte Motion for an Ex Parte Order Reducing the time for a party or a party of interest to take any action or file objections to Petitioner Robert Davis' Emergency Motion for Clarification of the Court's July 25, 2013 Stay Order Filed by Creditor Robert Davis (Attachments: #1 Exhibit Exhibit 1 Proposed Order #2 Exhibit Exhibit 2 Notice of Motion and Opportunity to Object #3 Exhibit Exhibit 3 Brief Not Required #4 Exhibit Exhibit 4 Certificate of Service #5 Exhibit Exhibit 5 NONE #6 Exhibit Exhibit 6 NONE) (Paterson, Andrew) (Entered: 08/08/2013)
PDF icon Exhibit1.pdf PDF icon Exhibit2.pdf PDF icon Exhibit3.pdf PDF icon Exhibit4.pdf PDF icon Exhibit5.pdf PDF icon Exhibit6.pdf

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 Documentary Exhibits) filed by Creditor Robert Davis) Corrected Emergency Motion for Clarification of the July 25, 2013 Stay Order Filed by Creditor Robert Davis (Attachments: #1 Exhibit Exhibit 1 Proposed Order #2 Exhibit Exhibit 2 Notice of Motion and Opportunity to Object #3 Exhibit Exhibit 3 Brief Not Required #4 Exhibit Exhibit 4 Certificate of Service #5 Exhibit Exhibit 5 NONE #6 Exhibit Exhibit 6 Documentary Exhibits A-E #7 Exhibit Exhibit A of Exhibit 6 Documentary Exhibits #8 Exhibit Exhibit C of Exhibit 6 Documentary Exhibits #9 Exhibit Exhibit D of Exhibit 6 Documentary Exhibits #10 Exhibit Exhibit E of Exhibit 6 Documentary Exhibits) (Paterson, Andrew) (Entered: 08/08/2013)
PDF icon Exhibit1.pdf PDF icon Exhibit10.pdf PDF icon Exhibit2.pdf PDF icon Exhibit3.pdf PDF icon Exhibit4.pdf PDF icon Exhibit5.pdf PDF icon Exhibit6.pdf PDF icon Exhibit7.pdf PDF icon Exhibit8.pdf PDF icon Exhibit9.pdf

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