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

Case 1 :07-cv-00513-GIVIS Document 3 Filed 08/22/2007 Page 1 of 3
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
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In re: :
: Chapter 11
RNI Wind Down Corporation, et al.,] : Case No. 06-10110 (CSS)
J ointly Administered
‘ Debtors. :
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ADDITIONAL DESIGNATIONS OF RECORD FOR THE PLAN ADMINISTRATOR’S
APPEAL FROM THE DECISION AND ORDER OVERRULING THE MODIFIED
OMNIBUS OBJECTION TO INDEMNIFICATION CLAIMS OF CERTAIN OF THE
DEBTORS’ FORMER DIRECTORS ENTERED BY THE BANKRUPTCY COURT ON
JULY 9, 2007
Andrew Feldman ("Mr. Feldman"), by and through is undersigned counsel, hereby
submits these additional designations of record pursuant to Rule 8006 of the Federal Rules of
Bankruptcy Procedure to be included on appeal by the Plan Administrator to the United States
District Court for the District of Delaware from the Decision [Docket No. 1406] and Order
[Docket No. 1407] entered by the United States Bankruptcy Court for the District of Delaware
(Christopher J. Sontchi, J.) on July 9, 2007 overruling the Modified Omnibus Objection to
Indemnification Claims of Certain of the Debtors’ Former Directors and Officers (the "Claim
Obj ection") [Docket No. 650] in connection with the proof of claim filed by Mr. Feldman.
Designation Of Items To Be
Included In the Record On Appealz
1. Certification of Counsel Regarding Confidentiality Stipulation and Protective
Order Filed by Andrew Feldman [Docket No. 1211].
1 The Debtors are RNI Wind Down Corporation, formerly known as Riverstone Networks, Inc.;
Blue Coast Software; The OASys Group, Inc.; Riverstone Networks SPC, Inc.; and Pipal
Systems, Inc.
2 Each designated item shall also include any exhibits to such item.
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2. Andrew Fe1dman's Response to the Plan Administrator's Motion In Limine to
Preclude Certain Testimony From David J. Schindler Filed by Andrew Feldman [Docket No.
13 l 6] .
3. Request for Judicial Notice of Andrew Feldman In Support of His Response to
Modified Omnibus Objection of` Equity Committee to Indemnification Claims of Certain ofthe
Debtors' Former Director and Officers Filed by Andrew Feldman [Docket No. 1317].
4. Joint Exhibit and Witness Lists and Designations of Deposition Transcripts Filed
by Plan Administrator of RNI Wind Down Corp. [Docket No. 1325].
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Dated: August 13, 2007
Wilmington, Delaware
Respectfully submitted,
MORRIS ES
Carl N. Kunz, III (DE Bar No. 3201)
1500 Delaware Avenue, Suite 1500
P.O. Box 2306
Wilmington, DE 19899-2306
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
-3-nd-
LATHAM & WATKINS LLP
Peter M. Gilhuly
Robert W. Perrin
Terri L. Lilley
633 West Fifth St., Suite 4000
Los Angeles, CA 90071
Telephone: (213) 485-1234
Attorneys for Andrew Feldman
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