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

Case 1:07-cv—00474—G|\/IS Document 3 Filed 07/31/2007 Page1 of 3
IN THE UNITED STATES BANKRUPTCY COURT _ .
FOR THE DISTRICT OF DELAWARE E
In re: ) Chapter 11 i
APCO LIQUIDATING TRUST and g Case No. 05-12355 (BLS)
APCO MISSING STOCKHOLDER )
TRUST, ) Jointly Administered
Reorganized Debtors. g Re: Docket No. 282
APPELLEES' COUNTER-DESIGNATION OF RECORD
WITH RESPECT TO "DESIGNATION OF RECORD AND
STATEMENT OF ISSUES ON APPEAL" [DOCKET NO. 282]
Pursuant to Rule 8006 of the Federal Rules of
Bankruptcy· Procedure, Apco Liquidating· Trust and Apco Missing
Stockholder Trust (collectively, the “Reorganized Debtors"}, as
appellees, hereby submit the following counterdesignation of
additional items to be included in the record in connection with
the appeal of the City of Wichita, Kansas (“Wichita”) from the
(i) Order, entered June 29, 2007 {Docket No. 278] and (ii)
Memorandum Opinion, entered June 29, 2007 [Docket No. 277] in
the above—captioned cases by the United States Bankruptcy Court [
for the District of Delaware (the Honorable Brendan L. Shannon),
and respectfully submit as follows:
RLF1-z1a3v3z~i

Case 1:07-cv—00474—G|\/IS Document 3 Filed 07/31/2007 Page 2 of 3 _
COUNTER-DESIGNATION OF RECORD1 E
In addition to the items designated by Wichita to be i
included in the record on appeal, the Reorganized Debtors
designate the following items to be included:2 E
iiiiiiiéiisssiéésssiiéssssea §§§§%%s issaeiésssséi
1. 47 09/16/2005 Affidavit of Joseph L. King
Concerning Service of Notice of Bar
Dates For Filing of Proofs of Claim -
2. 112 12/16/2005 First Amended Disclosure Statement
_ with Respect to First Amended
Liquidating Plan of Reorganization,
As Further Revised
3. 113 12/16/2005 First Amended Liquidating Plan of
Reorganization, As Further Revised
4. 135 01/11/2006 Stipulation Between City of
Wichita, Kansas and Apco
Liquidating Trust and Apco Missing
Stockholder Trust to Allow Claim of
City of Wichita, Kansas for Voting
Purposes Only
5. 140 01/13/2006 Debtors’ Motion Pursuant to
Bankruptcy Rule 9019(a} for the
Entry of an Order Approving
Stipulation with the City of
Wichita, Kansas
147 01/20/2006 Affidavit of Joseph L. King
Certifying, Voting on and
Tabulation of Ballots of Creditors’
Acceptance and Rejection of the
First Amended Disclosure Statement
With Respect to First Amended
1 This designation of items is in addition to any record items
listed in the Designation of Record and Statement of Issues on Appeal
[Docket No. 282], filed July 19, 2007.
2 The Reorganized. Debtors reserve the right to amend this
counterdesignation of additional items to be included in the record on
appeal. For items designated, the designation includes all documents
referenced within the particular document number, including, without
limitation, all exhibits, attachments, declarations, and affidavits
related thereto.
2
RLF1~3lB3732—1

Case 1 :07-cv—00474—G MS Document 3 Filed 07/31 /2007 Page 3 of 3
1
I
E

Liquidating Plan of Reorganization, Q
as Further Revised Q
7. 160 01/26/2006 Findings of Fact and Conclusions of Q
Law and Order Confirming First Q
Amended Liquidation Plan of Q
Reorganization Q
161 01/26/2006 Order Approving Stipulation With Q
“ City of Wichita, Kansas
n 251 02/15/2007 Agreed Scheduling Order _
10. 253 02/23/2007 Transcript of Hearing held on Q
January 18, 2007 before the Q
. Honorable Brendan L. Shannon Q
11. 276 06/13/2007 Notice of Submission of Subsequent ;
Authority Pursuant to Local =
Bankruptcy Rule 7007-l(b)
Dated: July 30, 2007
Wilmington, Deiaware
qMI\In!Q_ .---...' i .·''`‘ ` .'=·' ui -.-'·'‘ ii.Lg;§nA.;e
Joh, H. Knight (No. 3848)
Jason M. Madron (No. 4431)
RICHARDS, LAYTON & FINGER, P.A.
One Rodney Square
920 North King Street
Wilmington, DE 19801
Telephone: (302) 651-7700
Facsimile: (302) 651—7701
- and -
Neal H. Weinfield
Matthew F. Prewitt
GREENBERG TRAURIG LLP
77 West Wacker Drive
Chicago, IL 60601
Telephone: (312) 456-8400
Facsimile: (312) 456-8435
Counsel for the Liquidation Trustee
3
RLF1-ziaavsz-1