In re:

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE
Chapter 11
(Jointly Administered)
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
Case No. 12-11564 (CSS)
Debtors. Re: Docket Nos. 425,445
Hearing Date: To be determined
Ob'ection Deadline: To be determined
MOTION OF MICHAEL JAY MEYER TO SHORTEN NOTICE PURSUANT TO DEL.
BANKR. L.R. 9006-1 AND TO EXPEDITE HEARING IN CONNECTION WITH THE
JOINDER OF MICHAEL JAY MEYER TO THE MOTION OF NORMAN FREDRICK
WESSELS, JOYCE ELAINE WESSELS, AND GLADYS ANN WALKER FOR RELIEF
FROM THE AUTOMATIC STAY TO PURSUE PERSONAL INJURY CLAIMS
Michael Jay Meyer ("Mr. Meyer"), by and through his undersigned counsel, hereby
moves (the "Motion to Shorten") to shorten notice and expedite the hearing in connection with
his Joinder of Michael Jay Meyer to the Motion of Norman Fredrick Wessels, Joyce Elaine
Wessels, and Gladys Ann Walker for Relief From the Automatic Stay to Pursue Personal Injury
Claims (the "Joinder Motion") [Docket No. 445] filed on September 21, 2012. In support of this
Motion to Shorten, Mr. Meyer states as follows:
JURISDICTION
1. This Court has jurisdiction over this Motion to Shorten pursuant to 28 U.S.C.
157 and 1334. Venue is proper pursuant to 28 U.S.C. 1408 and 1409.
2. This is a core proceeding pursuant to 28 U.S.C. 157(b).
1
The Debtors in these cases, along with the federal tax identification number (or Canadian business number
where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive
Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company
(87568228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-
2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated
(58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-
2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91-
0847582).
5719622/
3. The bases for the relief requested herein are Federal Rule of Bankruptcy
Procedure 9006(c)(1) and Local Rule of Bankruptcy Procedure 9006-1(e).
BACKGROUND
4. As set forth in greater detail in Mr. Meyer's Joinder Motion, a true and correct
copy of which is attached hereto as Exhibit l, Mr. Meyer was injured in a Collision
2
on or about
October 7, 2010. The Collision was, upon information and belief, caused by an employee of
Allied Systems, Ltd. ("Allied Ltd."), who was driving a truck owned by Allied Ltd. at the time of
the Collision. Mr. Meyer's vehicle was totaled in and as a result of the Collision, and Mr. Meyer
suffered injuries in and as a result of the Collision which required and continue to require Mr.
Meyer to incur the expenses of hospitals, doctors, and/or other medical care providers.
5. Upon information and belief, at the time of the Collision, the Debtors had
insurance policies in place which provided coverage for the injuries and damage suffered by Mr.
Meyer as a result of the Collision.
6. Norman Fredrick Wessels, Joyce Elaine Wessels, and Gladys Ann Walker filed a
motion for stay relief (the "Stay Relief Motion") [Docket No. 425] on September 11, 2012, the
hearing for which is currently scheduled for September 28, 2012 at 11:00 a.m. ET and the
objection deadline for all parties other than the Debtors is currently set for September 21, 2012 at
4:00p.m. ET. The Debtors' deadline to object to the Stay Relief Motion is September 25, 2012
at 4:00p.m. ET.
7. The Stay Relief Motion is premised on the same Collision and substantially
similar underlying facts to those which form the basis for Mr. Meyer's request for relief from the
automatic stay in his Joinder Motion.
2
Capitalized terms not otherwise defmed herein shall have the meaning ascribed to them in the Joinder Motion.
5719622/
2
BASIS FOR THE RELIEF REQUESTED
8. Federal Rule of Bankruptcy Procedure 9006(c)(l) provides that, with certain
inapplicable exceptions, "when an act is required or allowed to be done at or within a specified
time by these rules or by a notice given thereunder or by order of the court, the court for cause
shown may in its discretion with or without motion or notice order the period reduced."
Additionally, Del. Bankr. L.R. 9006-l(e), titled "Shortened Notice," provides "No motion will
be scheduled on less notice than required by these Local Rules or the Fed. R. Bankr. P. except by
order of the Court, on written motion (served on all interested parties) specifying the exigencies
justifying shortened notice. The Court will rule on such motion promptly without need for a
hearing."
9. Mr. Meyer respectfully submits that shortening the notice and expediting the
hearing with respect to his Joinder Motion is appropriate and will maximize judicial economy
without sacrificing the rights or interests of any of the parties in interest. As of the time this
Motion to Shorten was filed, no objections were filed against the Stay Relief Motion, though the
deadline to file any such objections has passed for all parties other than the Debtors. As
indicated above, Mr. Meyer's Joinder Motion relates to the same parties at issue in the Stay
Relief Motion, the same underlying incident (the Collision), and will be served upon the same
parties who received the Stay Relief Motion.
10. Accordingly, in light of the above, Mr. Meyer respectfully requests that the
deadline to the Joinder Motion be set for September 25, 2012 at 4:00p.m. ET, consistent with
the current objection deadline for the Debtors regarding the Stay Relief Motion, and that the
Joinder Motion be heard on September 28, 2012 at 11:00 a.m. ET along with the Stay Relief
Motion.
5719622/
3
NOTICE TO BE PROVIDED
11. While Mr. Meyer respectfully submits that the relief he seeks would result in the
greatest judicial economy and the least potential sacrifice for parties in interest if he is awarded
expedited consideration, Mr. Meyer recognizes the need to provide as much notice as possible in
order to satisfy other interested parties' due process rights. Accordingly, contemporaneously
with this filing, Mr. Meyer is providing a copy of the Joinder Motion to (i) counsel to the
Debtors, (ii) the Office of the United States Trustee for the District of Delaware, and (iii) all
parties having entered an appearance in the Debtors' bankruptcy case.
WHEREFORE, Mr. Meyer respectfully requests entry of an Order in the form attached
hereto: (i) granting the Motion to Shorten to consider the relief requested in the Joinder Motion
on an expedited basis; (ii) setting the deadline to object to the Joinder Motion at September 25,
2012 at 4:00 p.m. ET; (iii) scheduling the hearing on the Joinder Motion on September 28,
2012 at 11:00 a.m. ET; and (iv) granting to Mr. Meyer such other and further relief as the Court
deems just and proper.
Dated: September 21, 2012
5719622/
4
MORRIS JAMES LLP
Eric J. o (DE Bar No. 5214)
Courtney R. Hamilton (DE Bar. No. 5432)
500 Delaware Avenue, Suite 1500
Wilmington, Delaware 19801
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
E-mail: emonzo@morrisj ames.com
chamilton@morrisj ames.com
Counsel for Michael Jay Meyer
In re:
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
(Jointly Administered)
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
Case No. 12-11564 (CSS)
Debtors. Re: Docket No. 425
Hearing Date: To be determined
Ob'ection Deadline: To be determined
JOINDER OF MICHAEL JAY MEYER TO MOTION OF NORMAN FREDRICK
WESSELS, JOYCE ELAINE WESSELS, AND GLADYS ANN WALKER
FOR RELIEF FROM THE AUTOMATIC STAY
TO PURSUE PERSONAL INJURY CLAIMS -(DOCKET NO. 425)
Michael Jay Meyer ("Mr. Meyer"), by and through his undersigned counsel, hereby
moves, joins in (the "Joinder"), and adopts by this reference, the arguments and the requests for
relief made by Norman Fredrick Wessels, Joyce Elaine Wessels, and Gladys Ann Walker (the
"Stay Movants"), in the Motion of Norman Fredrick Wessels, Joyce Elaine Wessels, and Gladys
Ann Walker for Relief From the Automatic Stay to Pursue Personal Injury Claims (the "Relief
From Stay Motion") [Docket No. 425] filed on September 11, 2012. In support of his Joinder
and request for relief, Mr. Meyer states as follows:
JURISDICTION
1. This Court has jurisdiction over this Motion pursuant to 28 U.S.C. 157 and
1334. Venue is proper pursuant to 28 U.S.C. 1408 and 1409.
1
The Debtors in these cases, along with the federal tax identification number (or Canadian business number
where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive
Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company
(87568228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-
2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated
(58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-
2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91-
0847582).
5715765/
2. This is a core proceeding pursuant to 28 U.S.C. 157(b).
3. The bases for the relief requested herein are 11 U.S.C. 362(d) and Rules
4001(a)(l), 4001(a)(3) and 9014 ofthe Federal Rules ofBankruptcy Procedure.
BACKGROUND
4. On or about October 7, 2010, at approximately 4:28p.m., Mr. Meyer was the fifth
in a line of six vehicles stopped in a construction zone on Iowa Highway 7 5 facing north, in the
County of Plymouth, State of Iowa. Mr. Meyer had halted his vehicle - a 2000 Dodge Intrepid,
Iowa license plate 613CQV- in order to await a pilot car to escort him through the construction
zone.
5. At the same approximate time and place, David Allen Anderson ("Defendant
Anderson") was driving a 2007 Sterling Acterra Semi, Georgia license plate IC56Y7 (the "Semi
Truck"), in a northern direction on Iowa Highway 75, in the County of Plymouth, State of Iowa.
Defendant Anderson failed to observe the vehicles stopped at the construction zone, failed to
stop a clear distance away from the vehicles, and drove into the sixth and final stopped vehicle,
causing a chain reaction of vehicle collisions which injured nine (9) individuals, including Mr.
Meyer (this event is hereafter referred to as the "Collision"). A redacted copy of the police
report detailing the Collision (the "Police Report") is attached hereto as Exhibit A.
6. Upon information and belief, debtor Allied Systems, Ltd. ("Allied Ltd.") owned
the Semi Truck at the time of the Collision. See Exhibit A. Specifically, on the second page of
the Police Report, which is labeled "Page 1," in the description of Unit 001, the Police Report
identifies Defendant Anderson as the driver of the Semi Truck, and identifies "Allied Systems
Ltd." as the owner ofthe Semi Truck.
7. Mr. Meyer's vehicle was totaled in and as a result of the Collision, and Mr. Meyer
5715765/
2
suffered injuries in and as a result of the Collision which required and continue to require Mr.
Meyer to incur the expenses of hospitals, doctors, and/or other medical care providers.
8. Upon information and belief, at the time of the Collision, the Debtors had
insurance policies in place which provided coverage for the injuries and damage suffered by Mr.
Meyer as a result of the Collision. Indeed, the insurance company and policy number on the
insurance policy provided by the Debtors matches the insurance company and policy number
provided for the Semi Truck in the Police Report. A copy of the cover page of the insurance
policy provided by the Debtors is attached hereto as Exhibit B. Debtor Allied Systems Holdings,
Inc. ("Allied Holding") is listed as the named insured on the insurance policy.
9. On May 17, 2012, involuntary petitions were filed against Allied Holding and
Allied Ltd. in the United States Bankruptcy Court for the District of Delaware. On June 10,
2012 (the "Petition Date"), certain affiliates of Allied Holding and Allied Ltd. filed voluntary
petitions for relief under chapter 11 of the Bankruptcy Code. An order directing joint
administration ofthe Debtors' cases under case number 12-11564 (CSS) was entered on June 11,
2012 [Docket No. 89].
RELIEF REQUESTED
10. By this Motion, Mr. Meyer seeks relief from the automatic stay to pursue personal
injury claims (the "PI Claims") against the Debtors to recover from the Debtors, including
proceeds from any applicable insurance policy(ies ), and any other potentially responsible third
parties, including Defendant Anderson, in a non-bankruptcy forum of competent jurisdiction.
ARGUMENT
11. Mr. Meyer, as one of the parties injured in the Collision, seeks relief from the
automatic stay pursuant to 11 U.S.C. 362(d)(1) to pursue his personal injury claim against the
5715765/
3
relevant Debtor(s), third-party defendant David Allen Anderson, and the Debtors' insurance
company, and, in support of this relief, joins in and adopts the arguments made in the Stay Relief
Motion.
12. If stay relief is appropriate for the Stay Movants, fairness and judicial economy
dictate that it should also be granted to Mr. Meyer to pursue relief for the injuries and damages
he suffered as a result of the Collision, as his claims against the Debtors arise from the same acts,
transactions and occurrences as those set forth in the Stay Relief Motion.
[The remainder of this page has intentionally been left blank.}
5715765/
4
WHEREFORE, Mr. Meyer joins in and adopts the arguments made in the Stay Relief
Motion and respectfully requests that this Court enter an Order in the form attached hereto (i)
granting the Mr. Meyer's Motion for relief from the automatic stay to liquidate the PI Claim
against the Debtors and any other potentially responsible parties in a non-bankruptcy forum of
competent jurisdiction and, if successful, to recover from the Debtors and any applicable
insurance coverage, (ii) waiving the stay of the order provided under Fed. R. Bankr. P.
4001(a)(3), and (iii) granting to Mr. Meyer such other and further relief as this Court may deem
just and proper.
Dated: September 21, 20 12
5715765/
5
MORRIS JAMES LLP
Eric . Monzo (DE Bar No. 5214)
Courtney R. Hamilton (DE Bar. No. 5432)
500 Delaware Avenue, Suite 1500
Wilmington, Delaware 19801
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
E-mail: ernonzo@rnorrisj ames. corn
charnilton@rnorrisj ames .corn
Counsel for Michael Jay Meyer
EXHIBIT A
PO CEREPORT
Plymouth County Sheriff
Call#: 2010002728 Agency: SO
Type: lOSOPI 10-50 PI
Caller: DOB:
Address:
STRUBLE

Call-to:
Landmark:
712-540-1363
Loc#: 04
Grid#: BARTOL
Dist#: Alarm:
How Reeved: Mutual Aid: N
Unit Disp Arrv Clrd Dass Serv Officer
# State Plate # Tp _Y! Make Model Style
--
liA 464CRE PC 00 PONT ORANDPRIX4D
2IA 316KCN PC 01 CHEVY IMPALA 4D
3IA 613CQV PC 00 DODGE INTREPID 40
4GA U13781 TR 07 DELAVAN lL
SIA SE3860 s 06 PETERBll. T TR
6IA 140WZF PC 97 BUICK LESABRE 4D
7IA 3S4FIR TK 01 CHEVY SILVERADO PK
8 MN UDU124 PC 01 CADI DEVILLE 4D
9 GA ICS6Y7 TR 07 STERLING
Narrative:
Colors
wm
TAN
ORY
UNK
WHI
wm
BRO
wm
Incident#: 8010002573
Date: 10/07/10
Time Rcvd: 16:28
Time Disp: 00:00
Time Arrv: 00:00
Time CJrd: 00:00
CallOispo:
Prlm Off#: 7502
#Units Assign: 0
Wrecker
RETIRED ISP 382 CALLED 911 AND ADVISED OF A MULTIPLE 1050 PlAT THE ABOVE LOCATION
1069 TO 7504
SIOUX CENTER, ORANGE MAURICE AMBULANCE AND RESCUE ASSISTED ALONG WITII LEMARS FIRE
AND AMBULANCE
7501 7502 7503 7504 7505 1506 WERE ALL ON SCENE
WEATHER AT THAT LOCATION
TEMP 77F
DEW 30
WINDS SWAT 8 :MPH
CLEARSKYS
27/679YYS072 MELLEMA,LEE BRYANT DOB/1987-08-()6
27/A-536-13S-051303 DAVID ALLEN ANDERSON DOJJ 04/19/1966
,
MAIL REPORTS TO: ~ ~
I ~ Oeperlmenl Ol TranspartaUgn :.o.,;
Olfice a1 Oliver si!Nces V
P.O.Box9204 ~
Oes MoinH, I ~ 50308-9204 ......_....
Iowa Department of Transportation
INVESTIGATING OfFICERS REPORT
OF MOTOR VEHICLE ACCIDENT
Printed At: Plymouth County Sheriffs Off 10/1312010 09:22AM Page1
Law 1::11Jon:ementwso Numuar:
5010002573
Form #:.S010002573
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Pdntad At: PJymaulh County Sheriffs Off 10/13/2010 09:22AM Page2
Form#: S01DQ02573
Printed At: Plymouth County Sheriff's Off 10I13J2D10 0&:22 AM
Pag3
CllaliOn Charge 2
CilaUon CIIBige 3
Form#: 5010002573
Printed At: Plymouth County Sheriffs Off 10/1312010 09:22AM Page4
UnllNo. af
Vehlde Slriking
Fonn #: 6010002573
D
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A
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......
ERIN CHRISTINE
I

...
ZlpCod&
Unit No. ol
Vtnll:le SIIUcing
VEHICLE'S NUMBER 2 THROUGH 7 WHERE STOPPED IN A CONSTRUCTION ZONE WAITING FOR THE PILOT
A
ESCORT THEM THRU THE ZONE. VEHICLE #1 WAS NORTH BOUND N HIGHWAY #75 AND FAILED TO SEE THE
VEHICLES STRIKING VEHICLE #2 CAUSING A CHAIN REACTION. THIS COLLISOIN TOOK PL.ACE IN A CONSTRUCTION
ZONE
Printed At: Plymouth County Sheriffs Off 10/13/2010 09:22AM Paga5
Form#: S010D02573
)[NSURSANC PO CY
Polley No. CA 094-92-79
Renewal of No. NEW

Coverage is provided by
NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA
(a capital stock company)
175 Water Street, Nei{V York, NY 1 0038
(212) 458-5000
TRUCKERS DECLARATIONS
ITEM ONE Named Insured & Mailing Address .
ALLIED SYSTEMS 'HOLDINGS, INC.
2302 PARKLAKE DRIVE STE 600
ATLANTA, GA 30345
Producer's Name. & Mailing Address'
LOCKTON COMPANIES, LLC
444 W. 47TH STREET
SUITE 900
KANSAS Cl TY I MO 64112
FORM OF BUSINESS:
[XI CORPORATION 0 PARTNERSHIP 0 UMITED LIABILITY COMPANY tJ INDIVIDUAL 0 OTHER
POLICY PERIOD: From 01/01/2010 to 0 l/01/2011 at 12:01 A.M. Standard Time at.yolir'mail!ng address shown above.
IN RCT'URN FOR THE PAYMENT OF THE PREMIUM, AND SUBJECT TO AU THE TERMS OF THIS POLICY, WE AGREE WITH YOU TO PROVIDE
THE INSURANCE AS STATED IN THIS POUCV .
POUCY PREMIUMS: $ 1 ,331.51.5
Premium for Terrorism Coverage:
Not Applicable, Coverage Rejected By Insured
SCHEDULE OF STATE TAXES, FEES AND SURCHARGES, IF APPLiCABLE:*
Florida HCF*** $1.00
NewYork $2,100.00
Texas .
State Taxes, Fees and Surcharges shown are In addition to the above referenced Polley Premium.
Florida 'HCF**'! Florida Hurricane Catastrophe Fund Surcharge
ENDORSEMENTS A1iACHED TO THIS POLICY:
IL QO 17- Common Polley Conditions C1L 01' 461n Washington)
IL 00 21 -Broad Form Nuclear Exclusion (Not Applicable In New Yorld
SEE A 11' ACHED FORMS SCHEDULE
THESE DECLARATIONS AND THE COMMON POUCV DECLARAT)ONS, IF APPUCABLE, TOGETHER WITH THE COMMON POUCV
CONDITIONS, COVERAGE FORMS, AND FORMS AND ENDORSEMENTS IF ANY ISSUED TO FORM A PART THEREOF COMPLETE THE
ABOVE NUMBERED POLICY
48171 0306 . Date Issued: 0 3/29/2.010
CA OS 14 03 06 Includes copyrighted material of Insurance Services Offlce,lnc., with its permission. !so Inc., 2005 Page 1 of s
In re:
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
(Jointly Administered)
ALLIED SYSTEMS HOLDINGS, INC., et al.,
1
Case No. 12-11564 (CSS)
Debtors.
Re: Docket Nos. 445, __
ORDER GRANTING MOTION OF MICHAEL JAY MEYER
TO SHORTEN NOTICE PURSUANT TO DEL. BANKR. L.R. 9006-1 AND TO
EXPEDITE HEARING IN CONNECTION WITH THE JOINDER OF MICHAEL JAY
MEYER TO THE MOTION OF NORMAN FREDRICK WESSELS, JOYCE ELAINE
WESSELS, AND GLADYS ANN WALKER FOR RELIEF FROM THE AUTOMATIC
STAY TO PURSUE PERSONAL INJURY CLAIMS
IT IS HEREBY ORDERED that the Motion of Michael Jay Meyer to Shorten Notice
Pursuant to Del. Bankr. L.R. 9006-1 and to Expedite Hearing in Connection With the Joinder of
Michael Jay Meyer to the Motion of Norman Fredrick Wessels, Joyce Elaine Wessels, and
Gladys Ann Walker for Relief From the Automatic Stay to Pursue Personal Injury Claims (the
"Motion to Shorten") [Docket No._] is GRANTED; and it is further
ORDERED that argument on Mr. Meyer's Motion to Shorten IS scheduled for
September 28, 2012 at 11:00 a.m. ET; and it is further
1
The Debtors in these cases, along with the federal tax identification number (or Canadian business number
where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive
Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company
(87568228); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-
2918187); Cardin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated
(58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-
2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91-
0847582).
5719941/
ORDERED that the deadline for all parties to respond to Mr. Meyer's Motion to Shorten
is September 25,2012 at 4:00p.m. ET.
Dated: September _, 2012
5719941/
The Honorable Christopher S. Sontchi
United States Bankruptcy Judge