Free Request for Oral Argument - District Court of Delaware - Delaware

Case 1 :07-mc-00125-JJF Document 7 Filed 06/26/2007 Page 1 of 2
UNITED STATES BANKRUPTCY COURT
FOR DISTRICT OF DELAWARE
ln re: Chapter 11
KAISER GROUP INTERNATIONAL, Case No. 00-2263 (MF W)
INC., et al.,
(Jointly Administered)
Debtors.
Related to Docket Nos. 1976 and 1978
This appeal has been docketed in the United
States District Court for the District of
Delaware in Case No. 07-mc-00124 (UNA
KAISER INTERNATIONAL, INC., et al.,
Plaintiffs, Adv. No. 01-928 (MFW)
v. Related to Docket Nos. 338 and 340
NOVA HUT a.s. and INTERNATIONAL
FINANCE CORPORATION, This appeal has been docketed in the United
States District Court for the District of
Defendants. Delaware in Case No. 07-mc-00125 (UNA)
DEBTORS’ REQUEST FOR ORAL ARGUMENT IN CONNECTION WITH
STATEMENT AND MOTION IN SUPPORT OF APPEAL OR GRANTING
LEAVE TO APPEAL OF DEBTORS’ MOTION FOR AN ORDER PURSUANT
TO FEDERAL RULE OF BANKRUPTCY PROCEDURE 2004, OR ALTERNATIVELY
A BILL OF EQUITABLE DISCOVERY, DIRECTING EXAMINATION OF, AND
PRODUCTION OF DOCUMENTS BY THE INTERNATIONAL FINANCE
CORPORATION, NOVA HUT, AND RELATED PARTIES
NOW COMES Kaiser Group International, Inc. et al. (collectively the “Debtors"), by and
through their undersigned counsel, pursuant to D. Del. LR 7.1.4., and hereby respectfully request
oral argument in connection with their Statement and Motion in Support of Appeal or Granting
Leave to Appeal of Debtors’ Motion for an Order Pursuant to Federal Rule of Bankruptcy
Procedure 2004, or Alternatively a Bill of Equitable Discovery, Directing Examination of, and
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Case 1:07-mc-00125-JJF Document 7 Filed 06/26/2007 Page 2 of 2
A Production of Documents by the International Finance Corporation, Nova Hut, and Related
Parties (the "Staternent”).] Brieting on the Debtors’ Statement is now completed.
Respectfully submitted,
SAUL EWIN G, LLP

Mark Minuti (No. 2659)
222 Delaware Avenue, Suite 1200
P.O. Box 1266
Wilmington, DE 19899
302-421-6840
and-
George E. Rahn, Jr.
Centre Square West
1500 Market Street, 38th Floor
Philadelphia, PA 19102
215-972-7165
-and-
Jonathan M. Landers
Robert K. Dakis
GIBSON, DUNN & CRUTCHER LLP
200 Park Avenue
New York. NY 10166
212-351-4000
Attorneys for Debtors
and Debtors in Possession
Dated: June 26, 2007
' This request is being tiled without prejudice to the Debtors’ position that the Bankruptcy Court order at
issue is a final order from which the Debtors have a right of direct appeal.
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Case 1 :07-mc-00125-JJF Document 7-2 Filed 06/26/2007 Page 1 of 2
UNITED STATES BANKRUPTCY COURT
FOR DISTRICT OF DELAWARE
In re: Chapter ll
KAISER GROUP NTERNATIONAL, Case No. 00-2263 (MFW)
INC., er al.,
(Jointly Administered)
Debtors.
This appeal has been docketed in the United
States District Court for the District of
Delaware in Case No. 07—mc-00124 (UNA)
KAISER NTERNATIONAL, NC., er al.,
Plaintiffs,
v. Adv. No. 01-928 (MFW)
NOVA HUT as. and NTERNATIONAL
FINANCE CORPORATION, This appeal has been docketed in the United
States District Court for the District of
Defendants. Delaware in Case No. 07-mc-00125 UNA)
CERTIFICATE OF SERVICE
I, Mark Minuti, Esquire of Saul Ewing LLP hereby certify that on June 26, 2007 a copy of
the foregoing Debtors’ Request for Oral Argument in Connection with Statement and
Motion in Support of Appeal or Granting Leave to Appeal of Debtors’ Motion for an
Order Pursuant to Federal Rule of Bankruptcy Procedure 2004, or Alternatively a Bill of
Equitable Discovery, Directing Examination of, and Production of Documents by the
International Finance Corporation, Nova Hut, and Related Parties was served on the parties
on the attached service list in the manner indicated.

Mark Minuti (No. 2659)
SAUL EWING LLP
222 Delaware Avenue, Suite 1200
P.O. Box 1266
Wilmington, DE 19899
(302) 421-6800
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Case 1:07-mc-00125-JJF Document 7-2 Filed 06/26/2007 Page 2 of 2
KAISER GROUP INTERNATIONAL, INC., et al. v. NOVA HUT, et al.
Service List
Via Hand Delivery:
Victoria Watson Counihan, Esquire
Greenberg Trauri g, LLP
The Nemours Building
1007 North Orange Street, Suite 1200
Wilmington, DE 19801
Robert J. Steam, Jr., Esquire
Richards, Layton & Finger
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
Via U.S. Mail:
Adam D. Cole, Esquire
Greenberg Traurig, LLP
200 Park Avenue
New York, NY 10166
Annapoorni R. Sankaran, Esquire
Greenberg Trauri g, LLP
One International Place, 20"` Floor
Boston, MA 02110
Warren E. Zirkle, Esquire
McGuire Woods LLP
1750 Tysons Blvd., Suite 1800
McLean, VA 22102
$4945].1 6/26/OT -2-