Free Declaration - District Court of Delaware - Delaware

Case 1 :05-cv-00793-JJF Document 7 Filed 1 1/16/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
BANK OF AMERICA, N.A. (U SA), )
)
Plaintiff, )
)
v. ) C.A. No. 05-793
l
US AIRWAYS, INC., US AIRWAYS GROUP, )
INC., and AMERICA WEST AIRLINES, INC., )
)
Defendants, )
)
—and— )
)
JUN IPER BANK, )
)
Intervenor. )
DECLARATION OF CHRISTIAN DOUGLAS WRIGHT IN
SUPPORT OF DEFENDANTS US AIRWAYS, INC., US AIRWAYS
GROUP. INC.. AND AMERICA WEST AIRLINES. INC.’S MOTION TO TRANSFER
I, Christian Douglas Wright, hereby declare as follows:
I. I am a member of the Bar of the Supreme Court of the State of Delaware,
admitted to practice before the United States District Court for the District of Delaware, and an
attorney with Young Conaway Stargatt & Taylor, LLP, counsel to defendants US Airways, Inc.,
US Airways Group, Inc., and America West Airlines, Inc.
2. I submit this Declaration in support of the Motion to Transfer to the Eastern
District of Virginia filed by defendants US Airways, Inc., US Airways Group, Inc., and America
West Airlines, Inc.
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Case 1:05-cv-00793-JJF Document 7 Filed 11/16/2005 Page 2 of 4
3. Attached as Exhibit A to the Appendix of Additional Exhibits Cited in Notice of
Removal of Action and Claims Pursuant to 28 U.S.C. §§ l452(a), 1334 ("Appendix of
Additional Exhibits") is a true and correct copy of the Joint Plan of Reorganization of US
Airways, Inc. and Its Affiliated Debtors and Debtors-in-Possession, to which is attached as
Exhibit M the Agreement and Plan of Merger with America West Holdings Corporation.
4. Attached as Exhibit B to the Appendix of Additional Exhibits is a true and correct
copy of the Finding of Pact, Conclusions of Law and Order Under ll U.S.C. §§ ll29(a) and (b)
and Ped. R. Bankr. P. 3020 Confirming the Joint Plan of Reorganization of US Airways, Inc. and
Its Affiliated Debtors and Debtors—in—Possession.
5. Attached as Exhibit C to the Appendix of Additional Exhibits is a true and correct
copy of the Administrative Claim filed by Bank of America, N.A. (USA) and affiliated entities
for the period September I2, 2004 to July 3 l, 2005.
6. Attached as Exhibit D to the Appendix of Additional Exhibits is a true and correct
copy of the Administrative Claim filed by Bank of America, N.A. (USA) and affiliated entities
for the period August l, 2005 to September 27, 2005.
7. Attached as Exhibit E to the Appendix of Additional Exhibits is a true and correct
copy of the Second Amended Disclosure Statement with Respect to the Joint Plan of
Reorganization of US Airways, Inc. and Its Affiliated Debtors and Debtors—in—Possession.
8. Attached as Exhibit P to the Appendix of Additional Exhibits is a true and correct
copy of Appendix C to the Disclosure Statement.
9. Attached as Exhibit G to the Appendix of Additional Exhibits is a true and correct
copy of the Limited Objection of Bank of America, N.A. and Bank of America, N.A. (USA) to
DBO2:5lO2525.l 06470}.1001

Case 1:05-cv-00793-JJF Document 7 Filed 11/16/2005 Page 3 of 4
Confirmation ofthe Joint Plan of Reorganization of US Airways, Inc. and Its Affiliated Debtors
and Debtors—in—Possession.
l0. · Attached to this Declaration as Exhibit H is a true and correct copy of US
Airways’ Objections to Bank of America’s Administrative Claims.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge, information, and belief
DATED: November I6, 2005 Christian Dougla right (#3 'Q
DB02:5l02525.1 O647()3_]()g;

Case 1:05-cv-00793-JJF Document 7 Filed 11/16/2005 Page 4 of 4
CERTIFICATE OF SERVICE
I, Christian Douglas Wright, Esquire, hereby certify that on November 16, 2005, I caused
to be electronically tiled a true and correct copy ofthe foregoing document with the Clerk ofthe
Court using CM/ECP, which will send notification that such filing is available for viewing and
downloading to the following counsel of record:
Richard L. Horwitz, Esquire
Kevin R. Shannon, Esquire
Potter Anderson & Corroon LLP
1313 North Market Street
PO Box 951
Wilmington, DE 19899-0951
Kenneth J. Nachbar, Esquire
Morris Nichols Arsht & Turmell
1201 North Market Street
PO Box 1347
Wilmington, DE 19899-1347
I further certify that on November 16, 2005, I caused a copy of the foregoing document to
be served by hand delivery on the above—listed counsel of record
YOUNG CONAWAY STARGATT
& TAYLOR, LLP
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Christian Douglas W ` ht (#35
The Brandywine Building
1000 West Street, 17th Floor
P.O. Box 391
Wilmington, DE 19899-0391
(302) 571-6600
[email protected]
AttorrzeysforDefendants US Airways, Inc.,
US Airways Group, Inc, and America West
Airlines, Inc.
DB02:509949l.l 0647031001