Case 2:18-bk ER Doc 1517 Filed 02/08/19 Entered 02/08/19 16:59:00 Desc Main Document Page 1 of 19

Transcription

1 Case :-bk-0-er Doc Filed 0/0/ Entered 0/0/ ::00 Desc Main Document Page of Attorney or Party Name, Address, Telephone & FAX Nos., State Bar No. & Address Samuel R. Maizel (SBN 0) John A. Moe, II (SBN 0) Tania M. Moyron (SBN ) tania.moyron@dentons.com DENTONS US LLP 0 South Figueroa Street, Suite 00 Los Angeles, CA 00 Office: () -00 Facsimile: () - FOR COURT USE ONLY Movant(s) appearing without an attorney Attorney for Movant(s) Debtors and Debtors In Possession UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - LOS ANGELES DIVISION In re: VERITY HEALTH SYSTEM OF CALIFORNIA, INC., et al., Debtors and Debtors In Possession. Affects All Debtors Affects Verity Health System of California, Inc. Affects O Connor Hospital Affects Saint Louise Regional Hospital Affects St. Francis Medical Center Affects St. Vincent Medical Center Affects Seton Medical Center Affects O Connor Hospital Foundation Affects Saint Louise Regional Hospital Foundation Affects St. Francis Medical Center of Lynwood Foundation Affects St. Vincent Foundation Affects St. Vincent Dialysis Center, Inc. Affects Seton Medical Center Foundation Affects Verity Business Services Affects Verity Medical Foundation Affects Verity Holdings, LLC Affects De Paul Ventures, LLC Affects De Paul Ventures - San Jose Dialysis, LLC LEAD CASE NO.::-bk-0-ER Jointly administered with: Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-00-er Case No. :-bk-0-er CHAPTER: Debtors and Debtors In Possession. DECLARATION THAT NO PARTY REQUESTED A HEARING ON MOTION LBR 0-(o)() [No Hearing Required]. I am the Movant(s) or attorney for Movant(s) or employed by attorney for Movant(s).. On (date): // Movant(s) filed a motion or application (Motion) entitled: Notice Of Motion And Motion For This form is mandatory. It has been approved for use in the United States Bankruptcy Court for the Central District of California. December 0 Page F 0-..NO.REQUEST.HEARING.DEC American LegalNet, Inc.

2 Case :-bk-0-er Doc Filed 0/0/ Entered 0/0/ ::00 Desc Main Document Page of An Order Establishing Bar Date For Filing Proofs Of Claim; Memorandum Of Points And Authorities; Declaration of Richard G. Adcock In Support Thereof [Docket No. ]. A copy of the Motion and notice of motion is attached to this declaration.. On (date): // Movant(s), served a copy of the notice of motion or the Motion and notice of motion on required parties using the method(s) identified on the Proof of Service of the notice of motion.. Pursuant to LBR 0-(o), the notice of motion provides that the deadline to file and serve a written response and request for a hearing is days after the date of service of the notice of motion, plus additional days if served by mail, or pursuant to F.R.Civ.P. (b)()(d) or (F).. More than days have passed after Movant(s) served the notice of motion.. I checked the docket for this bankruptcy case and/or adversary proceeding, and no response and request for hearing was timely filed.. No response and request for hearing was timely served on Movant(s) via Notice of Electronic Filing, or at the street address, address, or facsimile number specified in the notice of motion.. Based on the foregoing, and pursuant to LBR 0-(o), a hearing is not required. Movant(s) requests that the court grant the motion and enter an order without a hearing. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Date: // /s/ Tania M. Moyron Signature Tania M. Moyron Printed name This form is mandatory. It has been approved for use in the United States Bankruptcy Court for the Central District of California. December 0 Page F 0-..NO.REQUEST.HEARING.DEC American LegalNet, Inc.

3 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0 SAMUEL R. MAIZEL (Bar No. 0) samuel.maizel@dentons.com TANIA M. MOYRON (Bar No. ) tania.moyron@dentons.com DENTONS US LLP 0 South Figueroa Street, Suite 00 Los Angeles, California 00-0 Tel: () -00 / Fax: () - Attorneys for the Chapter Debtors and Debtors In Possession In re: UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION VERITY HEALTH SYSTEM OF CALIFORNIA, INC., et al., Possession. Debtors and Debtors In x Affects All Debtors Affects Verity Health System of California, Inc. Affects O'Connor Hospital Affects Saint Louise Regional Hospital Affects St. Francis Medical Center Affects St. Vincent Medical Center Affects Seton Medical Center Affects O'Connor Hospital Foundation Affects Saint Louise Regional Hospital Foundation Affects St. Francis Medical Center of Lynwood Foundation Affects St. Vincent Foundation Affects St. Vincent Dialysis Center, Inc. Affects Seton Medical Center Foundation Affects Verity Business Services Affects Verity Medical Foundation Affects Verity Holdings, LLC Affects De Paul Ventures, LLC Affects De Paul Ventures - San Jose Dialysis, LLC Debtors and Debtors In Possession. Lead Case No. :-bk-0-er Jointly Administered With: CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-00-er CASE NO.: :-bk-0-er Chapter Cases Hon. Judge Ernest M. Robles NOTICE OF MOTION AND MOTION FOR AN ORDER ESTABLISHING BAR DATE FOR FILING PROOFS OF CLAIM; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF RICHARD G. ADCOCK IN SUPPORT THEREOF [No Hearing Required Unless Requested - Local Bankruptcy Rule 0-(o)]

4 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0 PLEASE TAKE NOTICE that, pursuant to Rule 00(c)() and LBR 00- and 0-(o) and (q), Verity Health System of California, Inc., a California nonprofit benefit corporation and the Debtor herein ("VHS"), and the above-referenced affiliated debtors, the debtors and debtors in possession in the above-captioned chapter bankruptcy cases (collectively, the "Debtors"), hereby move (the "Motion") for the entry of an order establishing a bar date for filing proofs of claim or interest in the Debtors' cases. PLEASE TAKE FURTHER NOTICE that by the Motion, the Debtors respectfully request that the Court establish April, 0 as the bar date (the "Bar Date") by which parties who wish to assert prepetition claims against, and interests in, the Debtors must file and serve proofs of claim or proofs of interest, or be forever barred from asserting such prepetition claims or interests against the Debtors. The Bar Date is necessary in order for the Debtors to accurately determine the total amount, number and types of claims and interests that must be addressed in the Debtors' cases, particularly as the Debtors pursue a process for the marketing and sale of its businesses as a going-concern and/or its operating assets, to a qualified buyer, free and clear of all liens, claims and interests. PLEASE TAKE FURTHER NOTICE that by the Motion, the Debtors request that the Court approve the proposed form of notice of Bar Date that is attached as Exhibit A to the Declaration of Richard G. Adcock annexed hereto (the "Adcock Declaration"). The use of the proposed form of Bar Date notice, which deviates from the mandatory form of Bar Date notice established by LBR 00-, is necessary in this cases due to the size of the Debtors' bankruptcy cases, the large number of creditors and the retention of Kurtzman, Carson Consultants LLC as the Debtors' Claims and Noticing Agent. [Dkt. No. ]. All references to sections or chapters are to provisions of the United States Bankruptcy Code, U.S.C. 0-. All references to "Rules" are to provisions of the Federal Rules of Bankruptcy Procedure. All references to "LBR" are to provisions of the Local Bankruptcy Rules for the United States Bankruptcy Court for the Central District of California. 0W-

5 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 PLEASE TAKE FURTHER NOTICE that the Motion is based upon this Notice and Motion, Rule 00(c)() and LBR 00- and 0-(o) and (q), the attached Adcock Declaration, the attached Memorandum of Points and Authorities, the entire record in this case, and any other evidence properly presented to the Court. PLEASE TAKE FURTHER NOTICE that, pursuant to LBR 0-(o)()(A)(ii), any response and request for hearing must be filed with the Court and served on proposed counsel for the Debtors and the United States Trustee within fourteen () days after the date of service of this Notice. PLEASE TAKE FURTHER NOTICE that, pursuant to LBR 0-(h), failure to file and serve a timely response to the Motion or request for a hearing on the Motion may be deemed by the Court to be consent to the granting of the relief requested in the Motion. 0 Dated: January, 0 DENTONS US LLP By: /s/ Samuel R. Maizel Samuel R. Maizel Tania M. Moyron Attorneys for Chapter Debtors and Debtors in Possession 0\V-

6 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0 MEMORANDUM OF POINTS AND AUTHORITIES I. STATEMENT OF FACTS. On August, 0 ("Petition Date"), Verity Health System of California, Inc. ("VHS") and the above-referenced affiliated debtors, the debtors and debtors in possession in the above-captioned chapter bankruptcy cases (collectively, the "Debtors"), each filed a voluntary petition for relief under chapter of title of the United States Code (the "Bankruptcy Code"). Since the commencement of their cases, the Debtors have been operating their businesses as debtors in possession pursuant to 0 and 0.. Debtor VHS, a California nonprofit public benefit corporation, is the sole corporate member of the following five Debtor California nonprofit public benefit corporations that operate six acute care hospitals: O'Connor Hospital, Saint Louise Regional Hospital, St. Francis Medical Center, St. Vincent Medical Center, Seton Medical Center, and Seton Medical Center Coastside (collectively, the "Hospitals") and other facilities in the state of California. Adcock Declaration,.. VHS, the Hospitals, and their affiliated entities (collectively, "Verity Health System") operate as a nonprofit health care system, with approximately,0 inpatient beds, six active emergency rooms, a trauma center, eleven medical office buildings, and a host of medical specialties, including tertiary and quaternary care. Adcock Declaration,. On the Petition Date, the Debtors had approximately 0 inpatients. Id. The scope of the services provided by the Verity Health System exemplified by the fact that in 0, the Hospitals provided medical services to over 0,000 inpatients and approximately 0,000 outpatients. Id.. On September, 0, the Office of the United States Trustee appointed an Official Committee of Unsecured Creditors in these chapter cases. [Dkt. No. ]. All references to " " or "section" herein are to the Bankruptcy Code, U.S.C. 0, et seq., as amended. 0W-

7 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0. Pursuant to this Motion, the Debtors seek to establish April, 0 as the bar date (the "Bar Date") by which parties who wish to assert prepetition claims against, and interests in, the Debtors must file and serve proofs of claim or proofs of interest, or be forever barred from asserting such prepetition claims or interests against the Debtors. The establishment of the Bar Date will enable the Debtors to quantify the full amount of its liabilities so that the Debtors may formulate and confirm a plan of reorganization. The Debtors believe that the proposed Bar Date will provide the Debtors with sufficient time to serve notice of this Motion, have an order approving the Motion entered (assuming no one objects to the relief sought in the Motion) and still provide creditors with approximately fortyfive () days' notice of the Bar Date.. By this Motion, the Debtors also request that the Court approve the proposed form of notice of Bar Date that is attached as Exhibit A to the Adcock Declaration. II. DISCUSSION A. Good Cause Exists For Establishing A Bar Date. Federal Rule of Bankruptcy Procedure 00(c)() provides that in a chapter bankruptcy case the Court will set a time for the filing of proofs of claim. Fed. R. Bankr. Proc. 00(c)(). As set forth above, in order to foiiiiulate and confiuiii a plan of reorganization for the benefit of all creditors, the Debtors must ascertain the total amount, number and types of claims and interests asserted against its estates. By establishing the Bar Date for the filing of proofs of claims and interests, the Court will enable the Debtors to quantify the full amount of its liabilities so that the Debtors may determine the universe of claims that must be addressed in this case. Therefore, the Debtors respectfully request that the Court enter an order establishing April, 0 as the Bar Date and that the Court prohibit the filing of late proofs of claims and/or interest without a further court order. 0NV-

8 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0 B. Claimants and Interest Holders Will Receive Adequate Notice of the Bar Date. The Debtors have prepared a proposed form of notice of the Bar Date that it will serve by first class mail on all creditors, interest holders and parties requesting special notice. A true and correct copy of the proposed notice of the Bar Date is attached as Exhibit A to the Adcock Declaration, and is incorporated herein by this reference. All potential claimants and interest holders will receive approximately forty-five () days' notice of the Bar Date (assuming no one objects to the relief sought in the Motion). The Debtors request approval of the proposed form of Bar Date notice as an exception to LBR 00-, which requires debtors to use the court-approved mandatory form of bar date notice. The use of the proposed form of Bar Date notice is necessary in these cases due to the size of the Debtors' bankruptcy cases, the large number of creditors and the retention of Kurtzman, Carson Consultants LLC ("KCC") as the Debtors' Claims and Noticing Agent. [Dkt. No. ]. The proposed notice of the Bar Date also includes the all of the language contained in the court-approved form of notice of bar date, and, in particular, advises interested parties of, among other things: () the Bar Date of April, 0 and () the need to file proofs of claim and interest with the KCC on or before the Bar Date. Accordingly, the Debtors respectfully submit that the proposed form of providing notice of the Bar Date is appropriate in light of the circumstances and should be approved. III. CONCLUSION WHEREFORE, the Debtor respectfully requests that this Court enter an order: () affirming the adequacy of the Notice given herein; () granting the Motion in its entirety; () establishing April, 0 as the Bar Date for filing proofs of claims and proofs of interests against the Debtors; 0\V-

9 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of () barring any party that fails to file a proof of claim and/or proof of interest with the Court by the Bar Date from thereafter asserting a prepetition claim and/or interest against the Debtors or the Debtors' bankruptcy estates; () approving the form of notice of the Bar Date attached as Exhibit A to the Adcock Declaration; and () granting such other and further relief as the Court deems just and proper under the circumstances. 0 0 Dated: January, 0 DENTONS US LLP By: /s/ Samuel R. Maizel Samuel R. Maizel Tania M. Moyron Attorneys for Chapter Debtors and Debtors in Possession 0\V-

10 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page 0 of 0 0 DECLARATION OF RICHARD G. ADCOCK I, Richard G. Adcock, declare, that if called as a witness, I would and could competently testify thereto, of my own personal knowledge, as follows:. I am the Chief Executive Officer of Verity Health System of California, Inc. ("VHS"). I became the Debtors' Chief Executive Officer effective January 0. Prior thereto, I served as VHS's Chief Operating Officer since August 0.. Except as otherwise indicated herein, this Declaration is based upon my personal knowledge, my review of relevant documents, information provided to me by employees of the Debtors or the Debtors' legal and financial advisors, or my opinion based upon my experience, knowledge, and information concerning the Debtors' operations and the healthcare industry. If called upon to testify, I would testify competently to the facts set forth in this Declaration.. This Declaration is in support of the Debtors' Notice And Motion For an Order Establishing Bar Date for Filing Proofs of Claim ("Motion") and for all other purposes permitted by law.. On August, 0 ("Petition Date"), VHS and the above-referenced affiliated debtors, the debtors and debtors in possession in the above-captioned chapter bankruptcy cases (collectively, the "Debtors"), each filed a voluntary petition under Chapter of the Bankruptcy Code. Since the Petition Date, the Debtors have been operating their businesses as debtors in possession.. VHS, a California nonprofit public benefit corporation, is the sole corporate member of the following five Debtor California nonprofit public benefit corporations that operate six acute care hospitals: O'Connor Hospital, Saint Louise Regional Hospital, St. Francis Medical Center, St. Vincent Medical Center, Seton Medical Center, and Seton Medical Center Coastside (collectively, the "Hospitals") and other facilities in the state of California.. VHS, the Hospitals, and their affiliated entities (collectively, "Verity Health System") operate as a nonprofit health care system, with approximately,0 inpatient beds, six active emergency rooms, a trauma center, eleven medical office buildings, and a host of medical specialties, including tertiary and quaternary care. On the Petition Date, the Debtors had approximately 0 0\V-

11 Case :-bk-0-er Doc Filed 0// 0/0/ Entered 0// 0/0/ :: ::00 Desc Main Document Page of 0 0 inpatients, The scope of the services provided by the Verity Health System exemplified by the fact that in 0, the Hospitals provided medical services to over 0,000 inpatients and approximately 0,000 outpatients.. The Debtors have substantial prepetition debt, I believe it is imperative that a deadline be established for filing proofs of claim and interest in the Debtors' cases so that the Debtors may ascertain the total amount, number and types of claims and interest asserted against the Debtors' estates and accurately determine the claims that.will need to be addressed in these cases, particularly as the Debtors pursue a process for the marketing and sale of its businesses as a going-concern and/or its operating assets, to a qualified buyer, free and clear of all liens, claims and interests,. The Debtors' Motion seeks to establish April, 0 as the bar date (the "Bar Date") by which parties who wish to assert prepetition claims against, and interests in, the Debtors must file and serve proofs of claim or proofs of interest, or be forever barred from asserting such prepetition claims or interests against the Debtors. I believe that the establishment of the Bar Date will enable the Debtors to quantify the full amount of its liabilities so that the Debtors may formulate and confirm a plan of reorganization.. By the Motion, the Debtors also request that the Court approve the proposed form of notice of Bar Date that is attached hereto as Exhibit A. I declare under penalty of per and of the laws in the United States of America, the foregoing is true and correct. Executed this th day of January, 0, at Los Angel C ornia. RICHARD G. ADCOCK 0/

12 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of EXHIBIT A [Notice of Bar Date] 0 0 0\V- 0

13 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of 0 0 SAMUEL R. MAIZEL (Bar No. 0) samuel.maizel@dentons.com TANIA M. MOYRON (Bar No. ) tania.moyron@dentons. corn DENTONS US LLP 0 South Figueroa Street, Suite 00 Los Angeles, California 00-0 Tel: () -00 / Fax: () - Attorneys for the Chapter Debtors and Debtors In Possession In re: UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA LOS ANGELES DIVISION VERITY HEALTH SYSTEM OF CALIFORNIA, INC., et al., Possession. Debtors and Debtors In Affects All Debtors Affects Verity Health System of California, Inc. Affects O'Connor Hospital Affects Saint Louise Regional Hospital Affects St. Francis Medical Center Affects St. Vincent Medical Center Affects Seton Medical Center Affects O'Connor Hospital Foundation =IAffects Saint Louise Regional Hospital Foundation Affects St. Francis Medical Center of Lynwood Foundation Affects St. Vincent Foundation Affects St. Vincent Dialysis Center, Inc. Affects Seton Medical Center Foundation Affects Verity Business Services Affects Verity Medical Foundation Affects Verity Holdings, LLC Affects De Paul Ventures, LLC Affects De Paul Ventures - San Jose Dialysis, LLC Debtors and Debtors In Possession. Lead Case No. :-bk-0-er Jointly Administered With: CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-0-er CASE NO.: :-bk-00-er CASE NO.: :-bk-0-er Chapter Cases Hon. Judge Ernest M. Robles NOTICE OF BAR DATE FOR FILING PROOFS OF CLAIMS AND INTERESTS BAR DATE: APRIL, 0 I0\V-

14 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of 0 0 TO ALL CREDITORS, EQUITY AND INTEREST HOLDERS, AND OTHER PARTIES IN INTEREST: NOTICE OF CLAIMS BAR DATE The Bankruptcy Court has set a deadline of April, 0 for creditors and holders of ownership interests in Verity Health System of California, Inc., a California nonprofit benefit corporation and the Debtor herein, and the above-referenced affiliated debtors, the debtors and debtors in possession in the above-captioned chapter bankruptcy cases (collectively, the "Debtors"), to file proofs of claim against, or proofs of interest in, the Debtors' estates. The exceptions to this deadline for filing proofs of claims or interest are: () claims arising from rejection of executory contracts or unexpired leases, () claims of governmental units, and () claims arising as the result of transfer avoidance pursuant to chapter of the Bankruptcy Code. For claims arising from rejection of executory contracts or unexpired leases pursuant to U.S.C., the last day to file a proof of claim is: (a) 0 days after the date of entry of the order authorizing the rejection, or (b) April, 0, whichever is later. For claims of "governmental units," as that term is defined in U.S.C. 0(), the last day to file a proof of claim is: (a) 0 days after the entry the order for relief in this case, or (b) April, 0, whichever is later. U.S.C. 0(b)(). For claims arising from the avoidance of a transfer under chapter of the Bankruptcy Code, the last day to file a proof of claim is: (a) 0 days after the entry of judgment avoiding the transfer, or (b) April, 0, whichever is later. If you are listed on the Schedules of Assets and Liabilities of the Debtors and your claim or interest is not scheduled as disputed, contingent, unliquidated or unknown, your claim or interest is deemed filed in the amount set forth in the schedules, and filing of a proof of claim or interest is unnecessary if you agree that the amount scheduled is correct and that the category in which your claim or interest is scheduled (secured, unsecured, preferred stock, common stock, etc.) is correct. U. S.C. (a). If your claim or interest is not listed on the schedules or is scheduled as disputed, contingent, unliquidated or unknown, or if you disagree with the amount or description scheduled for your claim or interest, you must file a proof of claim or interest. Failure of a creditor or interest holder to file timely a proof of claim or interest on or before the deadline may result in disallowance of the claim or interest or subordination under the terms of a plan of reorganization without further notice or hearing. U.S.C. 0(b)(). Creditors and interest holders may wish to consult an attorney to protect their rights. 0\V-

15 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of 0 0 Dated: January, 0 DENTONS US LLP By: /s/ Samuel R. Maizel Samuel R. Maizel Tania M. Moyron Attorneys for Chapter Debtors and Debtors in Possession I0\V-

16 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of 0 In re Verity Health System of California, Inc., et al. (Case No. :-bk-0-er) Attached is a blank Proof of Claim form for the above-captioned case (with instructions). Proof of interest forms, and additional copies of proof of claim forms, may be obtained from the Debtors' Claims and Noticing Agent, Kurtzman, Carson Consultants LLC ("KCC"), located at Alaska Avenue, El Segundo, CA 0, () -, or by visiting KCC's website at or the Office of the Clerk of the Bankruptcy Court for the Central District of California, Los Angeles Division, located at East Temple Street, Los Angeles, CA 00, or on the Court's website, located at Please be advised that all Proofs of Claim and Proofs of Interest, with all supporting documentation, must be submitted to KCC via mail or courier no later than April, 0 at :00 p.m. (Pacific Time), at the following address: Verity Claims Processing Center c/o KCC Alaska Avenue El Segundo, CA 0 0 0W-

17 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of Fill in this information to identify the case: Debtor Debtor (Spouse, if filing) United States Bankruptcy Court for the: District of Case number Official Form 0 Proof of Claim 0/ Read the instructions before filling out this form. This form is for making a claim for payment in a bankruptcy case. Do not use this form to make a request for payment of an administrative expense. Make such a request according to U.S.C. 0. Filers must leave out or redact information that is entitled to privacy on this form or on any attached documents. Attach redacted copies of any documents that support the claim, such as promissory notes, purchase orders, invoices, itemized statements of running accounts, contracts, judgments, mortgages, and security agreements. Do not send original documents; they may be destroyed after scanning. If the documents are not available, explain in an attachment. A person who files a fraudulent claim could be fined up to $00,000, imprisoned for up to years, or both. U.S.C.,, and. Fill in all the information about the claim as of the date the case was filed. That date is on the notice of bankruptcy (Form 0) that you received. Part : Identify the Claim. Who is the current creditor? Name of the current creditor (the person or entity to be paid for this claim) Other names the creditor used with the debtor. Has this claim been acquired from someone else?. Where should notices and payments to the creditor be sent? Federal Rule of Bankruptcy Procedure (FRBP) 00(g) U No U Yes. From whom? Where should notices to the creditor be sent? Name Where should payments to the creditor be sent? (if different) Name Number Street Number Street City State ZIP Code Contact phone Contact City State ZIP Code Contact phone Contact Uniform claim identifier for electronic payments in chapter (if you use one):. Does this claim amend one already filed? U No U Yes. Claim number on court claims registry (if known) Filed on MM / DD / YYYY. Do you know if anyone else has filed a proof of claim for this claim? U No U Yes. Who made the earlier filing? Official Form 0 Proof of Claim page

18 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of Part : Give Information About the Claim as of the Date the Case Was Filed. Do you have any number you use to identify the debtor? No Yes. Last digits of the debtor's account or any number you use to identify the debtor:. How much is the claim? $. Does this amount include interest or other charges? No Yes. Attach statement itemizing interest, fees, expenses, or other charges required by Bankruptcy Rule 00(c)()(A). I I. What is the basis of the claim? Examples: Goods sold, money loaned, lease, services performed, personal injury or wrongful death, or credit card. Attach redacted copies of any documents supporting the claim required by Bankruptcy Rule 00(c). Limit disclosing information that is entitled to privacy, such as health care information.. Is all or part of the claim secured? No Yes. The claim is secured by a lien on property. Nature of property: I Real estate. If the claim is secured by the debtor's principal residence, file a Mortgage Proof of Claim Attachment (Official Form 0-A) with this Proof of Claim. Motor vehicle Other. Describe: Basis for perfection: Attach redacted copies of documents, if any, that show evidence of perfection of a security interest (for example, a mortgage, lien, certificate of title, financing statement, or other document that shows the lien has been filed or recorded.) Value of property: $ Amount of the claim that is secured: $ Amount of the claim that is unsecured: $ (The sum of the secured and unsecured amounts should match the amount in line.) Amount necessary to cure any default as of the date of the petition: $ Annual Interest Rate (when case was filed) % Fixed Variable 0. Is this claim based on a lease? No Yes. Amount necessary to cure any default as of the date of the petition. $. Is this claim subject to a right of setoff? No Yes. Identify the property: Official Form 0 Proof of Claim page

19 Case :-bk-0-er Doc Doc - Filed Filed 0/0/ 0// Entered Entered 0/0/ 0// ::00 :: Desc Main Desc Document Exhibit A Page of of. Is all or part of the claim entitled to priority under U.S.C. 0(a)? A claim may be partly priority and partly nonpriority. For example, in some categories, the law limits the amount entitled to priority. No Yes. Check one: Domestic support obligations (including alimony and child support) under U.S.C. 0(a)()(A) or (a)()(b). Up to $,0* of deposits toward purchase, lease, or rental of property or services for personal, family, or household use. U.S.C. 0(a)(). Wages, salaries, or commissions (up to $,0*) earned within 0 days before the bankruptcy petition is filed or the debtor's business ends, whichever is earlier. U.S.C. 0(a)(). Taxes or penalties owed to governmental units. U.S.C. 0(a)(). Contributions to an employee benefit plan. U.S.C. 0(a)(). Other. Specify subsection of U.S.C. 0(a)( ) that applies. Amount entitled to priority * Amounts are subject to adjustment on /0/ and every years after that for cases begun on or after the date of adjustment. Part : Sign Below The person completing this proof of claim must sign and date It. FRBP 0(b). If you file this claim electronically, FRBP 00(a)() authorizes courts to establish local rules specifying what a signature is. A person who files a fraudulent claim could be fined up to $00,000, imprisoned for up to years, or both. U.S.C.,, and. Check the appropriate box: I am the creditor. I am the creditor's attorney or authorized agent. I am the trustee, or the debtor, or their authorized agent. Bankruptcy Rule 00. I am a guarantor, surety, endorser, or other codebtor. Bankruptcy Rule 00. I understand that an authorized signature on this Proof of Claim serves as an acknowledgment that when calculating the amount of the claim, the creditor gave the debtor credit for any payments received toward the debt. I have examined the information in this Proof of Claim and have a reasonable belief that the information is true and correct. I declare under penalty of perjury that the foregoing is true and correct. Executed on date MM / DD / YYYY Signature Print the name of the person who is completing and signing this claim: Name First name Middle name Last name Title Company Identify the corporate servicer as the company if the authorized agent is a servicer. Address Number Street City State ZIP Code Contact phone Official Form 0 Proof of Claim page