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

Case 1 :07-cv—OO1 14-JJF Document 13 Filed O3/06/2007 Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: ) Chapter ll
NORTHWESTERN CORPORATION, g Case No. 03-12872 (KJC)
Reorganized Debtor. g R¢= D0¢k¢i NG- 3608
)
THE PLAN COMMITTEE’S J OINDER TO APPELLEE
NORTHWESTERN CORPORATION’S COUNT ER-DESIGNATION OF
ADDITIONAL ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL AND
COUNTER-STATEMENT OF ISSUES PRESENTED ON APPEAL
The Plan Committee (the "Plan Committee") appointed in the
above—captioned chapter ll case of NorthWestern Corporation (‘°N@") pursuant to
Section 7.9 of NOR’s Second Amended and Restated Plan of Reorganization Under
Chapter ll of the Bankruptcy Code (the "_I’j@1_”) [Docket No. 2020], by and through its
undersigned counsel, in connection with the appeal of the Order in Aid of Execution of
Plan Directing Transfer Agent to Invest Proceeds Received from Stock Tender Upon
Consummation of Merger in Accordance with ll U.S.C. § 345, entered on the docket by
this Court on February 2, 2007 [Docket No. 3575], by Magten Asset Management
Corporation and Law Debenture Trust Company of New York, hereby files this joinder to
NOR’s Counter-Designation of Additional Items to be Included in the Record on Appeal
and Counter-Statement of Issues Presented on Appeal to the United States District Court
for the District of Delaware filed on March 2, 2007 [Docket No. 3608] and in support
states as follows:
1. The Plan Committee joins in NOR’s additional items to be included in the
record on appeal.
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Case 1:07-cv-00114-JJF Document 13 Filed O3/06/2007 Page 2 of 2
2. The Plan Committee joins in NOR’s counter-statement ofthe issues
presented on appeal.
3. The Plan Committee reserves all rights to amend or supplement this
joinder.
Dated: March 2, 2007
THE BAYARD FIRM
By: V I ~ /, ——
Neil B. G ssma ' 2087) I
Charlene Dav` (No. 336)
Eric M. Sutt 07)
222 Delaware Avenue, Suite 900
P.O. Box 25130
Wilmington, DE 19899
-and-
PAUL, WEISS, RIFKIND, WHARTON &
GARRISON LLP
Alan W. Komberg
Kelley A. Cornish
Margaret A. Phillips
1285 Avenue ofthe Americas
New York, New York 10019
Telephone No.: (212) 373-3000
Facsimile No.: (212) 757-3990
Attorneys for the Plan Committee
653403-1 2