Free Designation of Record on Appeal - District Court of Delaware - Delaware

Case 1 :06-cv-00158-JJF Document 2 Filed 03/08/2006 Page 1 of 2
p UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
X
In re: : Chapter 11
NORTHWESTERN CORPORATION, Case Nos. 03-12872 (JLP)
Debtor.
I Ref. Nos. 3438, 3444, 3446
X
JOINDER OF AD HOC COMMITTEE OF CLASS 7 DEBTHOLDERS TO THE PLAN
COMMITTEE’S DESIGNATION OF ITEMS TO BE INCLUDED IN THE RECORD ON
APPEAL AND STATEMENT OF ISSUE TO BE PRESENTED ON APPEAL
An ad hoc group of creditors (the "Ad Hoc Committee"),l holding undisputed
Class 7 Claims against the above-captioned reorganized debtor (the "Debtor"), in connection
with its appealz of the Order Denying the Motion of the Plan Committee in Aid of
Consummation and Implementation of the Plan for Order Authorizing and Directing
NorthWestern Corporation to Distribute Surplus Distributions, entered on the docket by this
Court on February 7, 2006 [Docket No. 3438], and in support of The Plan Committee’s
Designation of Items to be Included in the Record on Appeal and Statement of Issue to be
Presented on Appeal [Docket No. 3446], filed by the Plan Committee appointed in the
above-captioned chapter ll case (the "Plan Committee"), respectfully states as follows:
1. The Ad Hoc Committee joins (the "Joinder") the Plan Committee’s designation of
items to be included in the record on appeal.
I The members ofthe Ad Hoc Committee are Avenue Capital Management, Drawbridge Special Opportunities
Advisors LLC, Franklin Mutual Advisers, LLC, Greenwich International Ltd., Harbert Distressed Investment Master
Fund, Ltd., Nationwide Life Insurance Company, Nationwide Mutual Insurance Company, P. Schoenfeld Asset
Management LLC, and Trilogy Capital LLC.
2 The Ad Hoc Committee’s Notice of Appeal was tiled on February 9, 2006 [Docket No. 3444].
525.001-lll88.DOC

Case 1:06-cv—00158-JJF Document 2 Filed 03/08/2006 Page 2 of 2
2. The Ad Hoc Committee joins the Plan Committee’s statement of issue to be
presented on appeal.
3. The Ad Hoc Committee reserves all rights to amend or supplement this Joinder.
Dated: Wilmington, Delaware
February 17, 2006
LANDIS RATH & COBB LLP
f Jl E .. #1
Adam G. Landis (No. 3407)
Kerri K. Mtunford (No. 4186)
919 Market Street, Suite 600
Wilmington, Delaware 19801
Telephone: (302) 467-4400
Facsimile: (302) 467-4450
-and-
KRAMER LEVIN NAFTALIS & FRANKEL LLP
Philip Bentley
Matthew J. Williams
1177 Avenue of the Americas
New York, New York 10036
Telephone: (212) 715-9100
Facsimile: (212) 715-8000
Attorneys for Ad Hoc Committee of Class 7
Debtholders
525.001-lll88.DOC 2