Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
Doc 153 Filed 09/11/12 Entered 09/11/12 17:21:08 Main Document Page 1 of 4
Desc
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Steven Jay Katzman, State Bar No. 132755 skatzman@bmkattorneys.com Anne Uyeda, State Bar No. 235306 auyeda@bmkattorneys.com Anthony Bisconti, State Bar No. 269230 tbisconti@bmkattorneys.com BIENERT, MILLER & KATZMAN, PLC 903 Calle Amanecer, Suite 350 San Clemente, California 92673 Telephone: (949) 369-3700/Facsimile: (949) 369-3701 Attorneys for Retired Employees of the City of San Bernardino Jenifer Aragon, Michael Billdt, Michael Eckley, Walt Goggin, Wayne Harp, Steve Klettenberg, Frank Mankin, Denis Moon, Scott Paterson, and Robert Simmons UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA RIVERSIDE DIVISION
CASE NO. 6:12-bk-28006 MJ CHAPTER 9 RETIRED EMPLOYEES OF THE CITY OF SAN BERNARDINOS JOINDER TO MOTIONS TO PERMIT DISCOVERY Hearing Date: Date: September 21, 2012 Time: 10:00 a.m. Place: Courtroom 301 3420 Twelfth Street Riverside, CA 92501 Judge: Hon. Meredith Jury
1
JOINDER TO MOTIONS TO PERMIT DISCOVERY
Case 6:12-bk-28006-MJ
Doc 153 Filed 09/11/12 Entered 09/11/12 17:21:08 Main Document Page 2 of 4
Desc
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Retired employees of the City of San Bernardino Jenifer Aragon, Michael Billdt, Michael Eckley, Walt Goggin, Wayne Harp, Steve Klettenberg, Frank Mankin, Denis Moon, Scott Paterson, and Robert Simmons (collectively, the Retirees) hereby join the motions requesting discovery relating to the City of San Bernardinos (the Debtor or the City) eligibility under 11 U.S.C. 109(c) (collectively, the Motions), including but not limited to the Motion filed by National Public Finance Guarantee Corporation to Permit Discovery of the City with Respect to Eligibility [Docket Nos. 148, 149] and the Motion for Order Authorizing Rule 2004 Examination of Debtor filed by Ambac Assurance Company et al. [Docket No. 152]. To the extent that this Court deems the production of documents (the Production) and the depositions (the Depositions) that are requested in the Motions to be appropriate, the Retirees respectfully request that this Court enter an order: (1) directing the City to provide a copy of the Production and/or access to the same to the Retirees; and (2) authorizing the Retirees to participate in the Depositions.
By: /s/ Steven Jay Katzman /s/ Steven Jay Katzman Anne A. Uyeda Anthony R. Bisconti Attorneys for Retired Employees of the City of San Bernardino Jenifer Aragon, Michael Billdt, Michael Eckley, Walt Goggin, Wayne Harp, Steve Klettenberg, Frank Mankin, Denis Moon, Scott Paterson, and Robert Simmons
2
JOINDER TO MOTIONS TO PERMIT DISCOVERY
Case 6:12-bk-28006-MJ
Doc 153 Filed 09/11/12 Entered 09/11/12 17:21:08 Main Document Page 3 of 4
CHAPTER 9 Debtor(s).
Desc
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012
F 9013-3.1.PROOF.SERVICE
Case 6:12-bk-28006-MJ
Doc 153 Filed 09/11/12 Entered 09/11/12 17:21:08 Main Document Page 4 of 4
CHAPTER 9 Debtor(s).
Desc
2. SERVED BY UNITED STATES MAIL: On _____________, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed.
Service information continued on attached page 3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on September 11, 2012, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed. Honorable Meredith A. Jury (Overnight Delivery) U.S. Bankruptcy Court 3420 Twelfth Street, Suite 325 Riverside, CA 92501-3819 Service information continued on attached page I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.
September , 2012
Date
Coleen Grogan
Printed Name
This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California. June 2012
F 9013-3.1.PROOF.SERVICE