Free Respone to Objections - District Court of Delaware - Delaware

Case 1:04-cv-01494-JJF Document 71-7 Filed O2/21/2006 Page1 0f4
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Case 1 :04-cv-01494-JJF Document 71 -7 Filed O2/21/2006 Page 2 of 4
Appendix of Pleadings Filed by the Plan Committee
United States Bankruptcy Court for the District of Delaware
Bankruptcy Court Case No. 03-12872
• Plan Committee’s Objection to Joint Motion of Magten Asset Management
Corporation and Law Debenture Trust Company of New York as Indenture
Trustee for Order Pursuant to Rule 9019 of the Federal Rules of Bankruptcy
Procedures dated March 2, 2005 [03-12872 Bankr. Docket No. 2866];
• Response and Request for Additional Forms of Relief of the Plan Committee in
Support of Debtor’s Motion for Order Compelling Master Ballot Agents to (I)
Identify Holders of Classes 7, 8(a) and 8(b) Claims that Voted Against Releases;
and (II) Disclose Beneficial Holders of Class 8(b) Claims and Whether Such
Holder Elected Option 1 or Option 2 dated March 29, 2005 [03-12872 Bankr.
Docket No. 2946];
• Appellee Designation of Additional Items to be Included in the Record on Appeal
and Counter-Statement of the Issues to be Presented on Appeal of Magten Assets
Management Corporation and Law Debenture Trust Company of New York, as
Trustee dated April 7, 2005 [03-12872 Bankr. Docket No. 2969];
• J oinder of the Plan Committee in the Debtor’s Motion for Order Compelling the
Depository Trust Company to Distribute Shares to Holders of Allowed Claims in
Class 7 Pursuant to Second Amended and Restated Plan of Reorganization Under
Chapter ll of the Bankruptcy Code dated April 14, 2005 [03-12872 Bankr.
Docket No. 2983];
• Motion for Leave to File a Reply to Objection of Magten Asset Management
Corporation to NorthWestem’s Motions Pursuant to Bankruptcy Rule 9019
Authorizing and Approving Stipulations of Settlement dated July 8, 2005 [03-
12872 Bankr. Docket No. 3177];*
• Motion for Leave to File an Omnibus Reply to Objections of Magten Asset
Management Corporation to NorthWestern’s Motions Pursuant to Bankruptcy
Rule 9019 Authorizing and Approving Stipulations of Settlement dated August 5,
2005 [03-12872 Bankr. Docket No. 3230];2
• Motion of the Plan Committee in Aid of Consummation and Implementation for
Order Authorizing and Directing NorthWestem to Distribute Surplus
Distributions dated September 29, 2005 [03-12872 Bankr. Docket No. 3308];
I By order of the Bankruptcy Court dated July 11, 2005 [03-12872 Bankr. Docket No. 3183], the Motion
of the Plan Committee for Leave to File a Reply was granted.
2 By order ofthe Bankruptcy Court dated August 5, 2005 [03-12872 Bankr. Docket No, 3233], the
Motion ofthe Plan Committee for Leave to File an Omnibus Reply was granted.

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• Motion of Franklin Mutual Advisors, LLC and the Plan Committee in Aid of
Consummation and Implementation of the Plan for Order (1) Compelling Law
Debenture to Instruct Depository Trust Company to Distribute Shares to Holders
of Class 8(b) Claims Electing Option 1, and (2) Claims Electing Option 1 and 2
dated September 29, 2005 [03-12872 Bankr. Docket No. 3309];
• Motion for Leave to File an Omnibus Reply to (I) Joint Objection of Magten
Asset Management Corporation and Law Debenture Trust Company and (II)
NorthWestern Corporation’s Response to Motion of Plan Committee In Aid of
Consummation and Implementation of the Plan for Order Authorizing and
Directing NorthWestem Corporation to Distribute Surplus Distributions dated
January 4, 2006 [03-12872 Bankr. Docket No. 3410];;*
• Joint Motion of Franklin Mutual Advisors, LLC and the Plan Committee for
Leave to File a Reply to Objection dated January 4, 2006 [03-12872 Bankr.
Docket No. 341 I];4
• Notice of Appeal of Order denying Motion of the Plan Committee in Aid of
Consummation and Implementation for Order Authorizing and Directing
NorthWestern to Distribute Surplus Distributions dated February 7, 2006 [03-
12872 Bankr. No. 3441]; and
• Appellant Designation of Contents for Inclusion in Record on Appeal and
Statement of Issue to be Presented on Appeal dated February 16, 2006 [03-12872
Bankr. No. 3446]
Bankruptcy Court Adv. Proc. 04-53324
• Joinder of the Plan Committee in Reorganized Debtor’s Brief in Opposition to
Motion and Memorandum of Law of Magten Asset Management Corporation and
Law Debenture Trust Company of New York in Support of Motion for Stay of
Adversary Proceedings Pending Resolution of Motion to Withdraw the Reference
to the Bankruptcy Court dated December 3, 2004 [O4-53324 Bankr. Docket No.
46].
3 By order of the Bankruptcy Court dated January 5, 2006 [03-12872 Bankr. Docket No. 3415], the
Motion of the Plan Committee for Leave to File an Omnibus Reply was granted.
4 By order ofthe Bankruptcy Court dated January 5, 2006 [03-12872 Bankr. Docket No. 3416], the Joint
Motion of Franklin Mutual Advisors, LLC and the Plan Committee for Leave to File a Reply was
granted.

Case 1 :04-cv-01494-JJF Document 71 -7 Filed O2/21/2006 Page 4 of 4
Bankruptcy Court Adv. Proc. 05-50866
• Motion of the Plan Committee to Intervene in Adversary Proceeding dated June
21, 2005 [05-50866 Bankr. Docket No. 8];$and
• Joinder ofthe Plan Committee in Support of NorthWestern’s Reply Brief in
Further Support of Motion to Stay Adversaiy Proceeding Pending Resolution of
Appeal of Continuation Order or, In the Alternative, to Dismiss Complaint [05-
50866 Bankr. Docket No. 13].
United States District Court for the District of Delaware
District Court Civil Action 04-1389
• Joinder of the Plan Committee in Support of NorthWestern’s Motion to Dismiss
Consolidated Appeals of Magten Asset Management Corporation dated June 10,
2005 [04-1389 Docket No. 57];
• Plan Committee’s Reply to and Joinder in Support of No1thWestern’s Reply to
Magten Asset Management Co1poration’s Memorandum of Law in Support of
Opposition to Motion to Dismiss and Joinder of Plan Committee dated July I2,
2005 [04-1389 Docket No. 62]; and
• J oinder of the Plan Committee in Support ofNorthWestern’s Reply Brief dated
August 12, 2005 [04-1389 Docket No. 69].
District Court Civil Action 04-1494
• Motion ofthe Plan Committee for an Order Substituting the Plan Committee for
the Official Committee, or in the Alternative, to Intervene in Adversary
Proceeding dated Febmary 1, 2006 [04-1494 Docket No. 53]; and
• MOTION to Expedite Consideration of Motion of the Plan Committee for an
Order Substituting the Plan Committee for the Official Committee, or in the
Alternative, to Intervene in Adversary Proceeding dated February 1, 2006 [04-
1494 Docket No. 54].
District Court Civil Action 05-209
• Designation of Additional Items to be Included in the Record and Refonnulation
of Statement of Issues on Appeal dated April ll, 2005 [05-209 Docket No. 4];
and
• Brief of Appellee, the Plan Committee in opposition to Appellants dated August
8, 2005 [05-209 Docket No. 15].
5 By order of the Bankruptcy Court dated July 1, 2005 [05-50866 Bankr. Docket No. 1 1], the Motion of
the Plan Committee to lntervene in Adversary Proceeding was granted.