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

Case 1 :07-cv-00622-JJF Document 4 Filed 10/19/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter 11
)
FOAMEX INTERNATIONAL INC., gt g ) Case N0. 05-12685 (KG)
)
Debtors. ) (Jointly Administered)
)
)
)
)
FOAMEX INTERNATIONAL INC., pj Q., )
)
App°"“‘"’ g c.A. N0. 07-622 (JJF)
v. )
)
JEFFERIES & COMPANY, INC. )
)
Appellee. )
)
APPELLEE JEFFERIES & COMPANY, INC.’S DESIGNATION OF ADDITIONAL
ITEMS TO BE INCLUDED IN RECORD ON APPEAL PURSUANT TO RULE 8006
OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE
Jefferies & Company, Inc. ("Jefferies"), by and through its undersigned counsel, hereby
submits, pursuant to Rule 8006 of the Federal Rules of Bankruptcy Procedure (the "Bank1uptcy
Rules"), this designation of additional items to be included in the record on appeal to the United
States District Couit for the District of Delaware. Jefferies designates the following additional
items:
DESIGNATION OF RECORD
A. Additional Pleadings
1. Order Establishing Procedures for Interim Compensation and Reimbursement of
Expenses of Professionals Pursuant to l l U.S.C. §§ lO5(a) and 331 (D.l. 204)
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2. The Official Committee of Unsecured Creditors’ Application for Order Under
Sections 328 and 1103 of the Bankruptcy Code and Bankruptcy Rule 2014 Approving Retention
of Jefferies & Company, Inc., as Financial Advisors to the Committee, and Granting Waiver of
Compliance with Certain Requirements Under Del. Bankr. LR 2016-2 (D.I. 220)
3. Order Pursuant to Sections 328(a) and 1103 of the Bankruptcy Code Approving
the Employment of Jefferies & Company, Inc. as Financial Advisors to the Official Committee
of Unsecured Creditors (D.I. 297)
4. Debtors’ Second Amended Joint Plan of Reorganization Under Chapter 11 of the
Bankruptcy Code (D.I. 1994)
5. Stipulation Regarding Claim Number 646 of Gungor M. Solmaz and Diana M.
Solmaz, and the Motion of Pontotoc Fibers, Inc. for (I) Allowance and Immediate Payment of
Lease Obligations Pursuant to 11 U.S.C. 365(D)(3), (II) Allowance and Payment of
Administrative Expense Claim Pursuant to 11 U.S.C. 503, or (III) in the Alternative, Leave to
File a Late-Filed Claim (D.I. 2563)
6. Order With Respect to Stipulation Regarding Claim Number 646 of Gungor M.
Solmaz and Diana M. Solmaz, and the Motion of`Pontotoc Fibers, Inc. for (I) Allowance and
Immediate Payment of Lease Obligations Pursuant to 11 U.S.C. 365(D)(3), (II) Allowance and
Payment of Administrative Expense Claim Pursuant to 11 U.S.C. 503, or (III) in the Alternative,
Leave to File a Late-Filed Claim (D.I. 2565)
B. Discovery Matters
7. Jefferies & Company’s First Set of Interrogatories
8. Jefferies & Company’s First Request for Production of Documents
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9. Reorganized Debtors’ First Set of Interrogatories and First Request for Production
of Documents Directed to Jefferies and Company, Inc.
l0. Jefferies and Company, Inc.’s Responses and Objections to Reorganized Debtors’
First Set of Interrogatories and First Request for Production of Documents
ll. Jefferies and Company, Inc.’s Supplemental Responses and Objections to
Reorganized Debtors’ First Set of Interrogatories
I2. Reorganized Debtors’ Responses and Objections to Jefferies & Company, Inc.’s
First Set of Interrogatories and First Request for Production of Documents
I3. Reorganized Debtors’ Emergency Motion to Compel Responses to Interiogatories
and Production of Documents from Jefferies & Company, Inc. (D.I. 2505)
I4. Jefferies & Company, Inc’s Opposition to Reorganized Debtors’ Motion to
Compel Discovery (D.I. 2529)
15. Order Denying in Part and Granting in Part Reorganized Debtors’ Emergency
Motion to Compel Responses to Interrogatories and Production of Documents from Jefferies and
Company, Inc. (Docket No. 2536)
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16. Transcript of Hearing Before the Honorable Kevin Gross held on June 1, 2007
(D.I. 2551)
Dated: October 19, 2007
Wilmington, Delaware
ASHBY & GEDDES
By:
William P. Bowden (#2553)
Benjamin W. Keenan (#4724)
500 Delaware Avenue, 8th Floor
P.O. Box 1150
Wilmington, DE 19899
Telephone: (302) 654-1888
Facsimile: (302) 654-2067
-a11d-
LATHAM & WATKINS LLP
Robert J. Rosenberg
885 Third Avenue, Suite 1000
New York, New York 10022
Telephone: (212) 906-1200
Facsimile: (212) 751-4864
Attorneys for Jefferies & Company, Inc.
185018.1
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