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

Case 1 :04-cv-00124-JJF Document 26 Filed 06/14/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
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In re:
Chapter ll
WOODWORKERS WAREHOUSE, INC.,
Case N0.: 03-13655 (JBR)
Debtor.
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KELLY BEAUDIN STEPLETON,
United States Trustee for Region 3,
Appellant,
v.
wooDwoR1 Appellee.
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APPELLEES’ COUNTER-DESIGNATION OF ADDITIONAL ITEMS
TO BE INCLUDED IN THE RECORD
Pursuant to Rule 6(b) ofthe Federal Rules of Appellate Procedure, appellees WW
Warehouse, Inc. (f/k/a Woodworkers Warehouse, Inc.) (the "Appellee"), by its undersigned
counsel, submits the following counter-designation of items to be included in the record for the
appeal tiled by Kelly Beaudin Stapleton, United States Trustee for Region 3 ("Appellant") from
the District Cou1t’s Memorandum Opinion and related Order which were issued and entered on
March 30, 2005.
C0unter—Designati0n 0f Record on Appeal
In addition to the items designated by the Appellant to be included in the record on
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Case 1:04-cv-00124-JJF Document 26 Filed 06/14/2005 Page 2 of 4
appeal, the Appellee designates the following:1
1. First Application Of Kronish Lieb Weiner & Hellman LLP, Special Counsel To
The Debtor, For Interim Compensation And Reimbursement Of Expenses For The Period
December 2, 2003 Through March 3], 2004 (Docket No. 358);
2. Order Granting First Application Of Kronish Lieb Weiner & Hellman LLP,
Special Counsel To The Debtor, For Interim Compensation And Reimbursement Of Expenses
For The Period December 2, 2003 Through March 3], 2004 (Docket No. 414);
3. Joint Plan Of Liquidation Of WW Warehouse, Inc., j7k/a Woodworkers
Warehouse, Inc. (Docket No. 373);
4. [Proposed] Disclosure Statement Of The Debtor And The Ojficial Committee Of
Unsecured Creditors ’ Joint Plan Of Liquidation Of WW Warehouse, Inc., j7k/a Woodworkers
Warehouse, Inc. (Docket No. 374);
5. Joint Motion ofthe Debtor and the Ojficial Committee of Unsecured Creditors for
Entry of an Order: (A) Approving Proposed Disclosure Statement and Other Plan Voting and
Solicitation Materials, Solicitation Procedures, Voting Rules and Tabulation Procedures; (B)
Establishing Ballot Submission Deadline; (C) Setting Hearing on Confirmation ofthe Plan; (D)
Establishing Deadlines for Filing Objections to Conjirmation ofthe Plan and Responses to Any
Such Objections (Docket No. 375);
6. First Amended Joint Plan Of Liquidation Of WW Warehouse, Inc., ]7k/a
Woodworkers Warehouse, Inc. (Docket No. 419);
7. First Amended Disclosure Statement Of The Debtor And The Ojficial Committee
Of Unsecured Creditors ’ Joint Plan Of Liquidation Of WW Warehouse, Inc., j7k/a Woodworkers
Warehouse, Inc. (Docket No. 420);
8. Disclosure Statement -— Executive Summary Of First Amended Joint Plan Of
Liquidation Of WW Warehouse, Inc., j7k/a Woodworkers Warehouse, Inc. (Docket No. 421);
9. Notice Of (I) Approval Of First Amended Disclosure Statement And (ID
Establishing 01) Hearing For Confirmation Of T he Plan, (B) Procedures For Objecting To
Confirmation Of The Plan And (C) Procedures And Deadline For Voting On The Plan (Docket
No. 422);
10. First Omnibus Objection Of Debtor To Gy? Certdicate Claims (Substantive)
(Docket No. 435);
11. Second Omnibus Objection Of Debtor To Certain Claims (Non -Substantive)
(Docket No. 43 6);
I The number in parentheses following each item below is the number assigned to the item on the
Bankruptcy Cou1t’s docket.
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Case 1:04-cv-00124-JJF Document 26 Filed 06/14/2005 Page 3 of 4
12. Third Omnibus Objection Of The Debtor To Certain Claims (Substantive)
(Docket No. 437);
13. Fourth Omnibus Objection Of The Debtor To Certain Trend~Line Claims
(Substantive) And To Allow Certain Trend—Lines Claims Not Paid Pursuant To Previous
Bankruptcy (Docket N0. 438);
14. Motion Of Debtor For Leave Of Local Rule 3 007-I Pertaining To Substantive
Omnibus Claims Objections (Docket No. 439);
15. Motion Of Debtor For Entry Of An Order Authorizing The Rejection Of An
Agreement With Iron Mountain Pursuant To Section 3 65 (A) Of The Bankriqttcy Code Ejkctive
As Of June 3 0, 2004, And The Abandonment Of Related Business Records (Docket No. 460);
16. Motion Of WW Warehouse, Inc.,_j7k/a Woodworkers Warehouse, Inc. For
Approval Of Settlement Agreement With WMH Tool Group, Inc. (Docket No. 492);
17. Memorandum Of Law In Support Of Releases Contained In Second Amended
Joint Plan Of Liquidation Of WW Warehouse, Inc., jk/a Woodworkers Warehouse, Inc. (Docket
No. 494);
18. Motion Of WW Warehouse, Inc., ]7k/a Woodworkers Warehouse, Inc., For
Approval Of Settlement Agreement With Shoppers Charge Accounts Co. (Docket No. 499);
19. Second Amended Joint Plan Of Liquidation Of WW Warehouse, Inc., _j7k/a
Woodworkers Warehouse, Inc. (Docket No. 500);
20. F mh Omnibus Objection Of The Debtor To Certain Claims (Substantive) (Docket
No. 503);
21. Sixth Omnibus Objection Of The Debtor To Certain Claims (Non-Substantive)
(Docket No. 504);
22. Order Confirming Second Amended Joint Plan Of Liquidation Of WW
Warehouse, Inc., jk/a Woodworkers Warehouse, Inc., As Amended (Docket No. 520);
23. Second Interim And Final Fee Application Of Kronish Lieb Weiner & Hellman
LLP, Special Counsel To The Debtor, For Interim And Final Compensation And Reimbursement
Of Expenses For The Period From April I, 2004 Through August I 0, 2004 And For The Period
From December 2, 2003 Through August I 0, 2004, Respectively (Docket No. 621); and
24. Stipulation And Order Granting Second Interim And Final Fee Application Of
Kronish Lieb Weiner & Hellman LLP, Special Counsel To The Debtor, For Interim And Final
Compensation And Reimbursement Of Expenses For The Period From April I, 2004 Through
August I 0, 2004 And For The Period From December 2, 2003 Through August I 0, 2004,
Respectively (Docket No. 660).
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Case 1:04-cv-00124-JJF Document 26 Filed 06/14/2005 Page 4 of 4
Respectfully Submitted,
WW WAREHOUSE, INC., f/k/a
WOODWORKERS WAREHOUSE, INC.
Dated: June 14, 2005
THE BAYARD FIRM
By: www
GianClaudi0 Finizio (N0. 4253)
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
(302) 655-5000
and
By: /s/ Ronald R. Sussman
KRONISH LIEB WEINER & HELLMAN LLP
Ronald R. Sussman (RS 0641)
Brent Weisenberg (BW 7107)
1114 Avenue ofthe Americas
New York, New York 10036
(212) 479-6000
(212) 479-6275 (fax)
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