Free Motion for Settlement - District Court of Delaware - Delaware

Case 1:04-cv-01380-Gl\/IS Document 64-2 Filed 10/27/2005 Paget of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
) Chapter 11
In re: )
) Case No. 00-1982 (GMS)
GST TELECOM INC., gt ak, )
) J ointly Administered
Debtors. )
1
)

)
GST TELECOM INC., _e_t_ al, )
) Civil Docket N0. 04-CV-1380
Counterplaintiffs, )
)
v. )
)
JOHN WARTA, )
)
Counterdefendant. )
NOTICE OF MOTION
PLEASE TAKE NOTICE that on October 27, 2005, the above-captioned debtors and
debtors in possession (the "Debtors") tiled the Motion of Debtors and Debtors-In-Possession
for an Order Approving Settlement and Release Agreement with John Warta (the
"Motion") with the United States District Court for the District of Delaware (the "District
Court") and the United States Bankruptcy Court for the District of Delaware (the "Banl Court").
PLEASE TAKE FURTHER NOTICE that any objections to the Motion must be made in
writing, tiled with the District Court, 844 N. King Street, 2nd Floor, Wilmington, DE 19801, and
the Bankruptcy Court, 824 N. Market Street, 2nd Floor, Wilmington, DE 19801, and served upon,
so as to actually be received by, the undersigned counsel, on or before November 16, 2005 at
4:00 p.m. (EST).
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Case 1:04-cv-01380-Gl\/IS Document 64-2 Filed 10/27/2005 Page 2 of 2
PLEASE TAKE FURTHER NOTICE that if an objection is properly filed in accordance
with the above procedures, a hearing on the Motion will be scheduled before the Honorable
Gregory M. Sleet at the Cou1t’s convenience. Only those objections made in writing, timely
tiled, and served in accordance with the above procedures will be considered at such hearing.
If no objections are timely tiled in accordance with the above procedure, the District
Court may enter an order approving the Motion without further notice or hearing.
Dated: October 27, 2005
Wilmington, Delaware
Steven M. oder (No. 3885)
Christopher A. Ward (No. 3877)
THE BAYARD FIRM
222 Delaware Avenue, Suite 900
P.O. Box 25130
Wilmington, Delaware 19899
(302) 655-5000
~and-
David S. Heller
William J, Gibbons
Josef S. Athanas
Michael J. Faris
Danielle S. Kemp
LATHAM & WATKIN S LLP
Suite 5800 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606
(312) 876-7700
Attorneys for the Debtors and
Debtors—in—Possession
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