Case KJC Doc 635 Filed 04/24/18 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Transcription

1 Case KJC Doc 635 Filed 04/24/18 Page 1 of 5 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE x In re KII Liquidating Inc. (f/k/a Katy Industries, Inc.), et al., 1 Debtors x Chapter 11 Case No (KJC) (Jointly Administered) NOTICE OF AGENDA FOR MATTERS SCHEDULED FOR HEARING ON APRIL 26, 2018, AT 1100 A.M. (EDT) 2 MATTERS GOING FORWARD 1. Joint Motion of the Debtors and the Official Committee of Unsecured Creditors for Entry of an Order (A) Approving the Disclosure Statement on an Interim Basis, (B) Approving the Form of Ballot and Solicitation Materials, (C) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Plan, (D) Scheduling a Plan Confirmation Hearing and Deadline for Filing Objections to Final Approval of the Disclosure Statement and Confirmation of the Plan, (E) Approving the Related Form of Notice, and (F) Granting Related Relief [D.I. No. 533; Filed 2/6/18]. Response Deadline April 16, 2018, at 400 p.m. (EDT). Extended for David Feldman through April 18 at 2 p.m. (ET). Extended to April 23, 2018, for the U.S. Trustee, the PBGC, and Majestic-Norwalk, LLC. Related Documents A. Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 528; Filed 2/5/18]. 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, where applicable, are KII Liquidating Inc. (f/k/a Katy Industries, Inc.) (7589), ComPro Liquidating LLC (f/k/a Continental Commercial Products, LLC) (3898), FTWH Liquidating Inc. (f/k/a FTW Holdings, Inc.) (7467), FWPI Liquidating Inc. (f/k/a Fort Wayne Plastics, Inc.) (7470), Wabash Holding Corp. (9908), KTI Liquidating Inc. (f/k/a Katy Teweh, Inc.) (9839), WII, Inc. (0456), TTI Holdings, Inc. (8680), GCW, Inc. (5610), Hermann Lowenstein, Inc. (4331), American Gage & Machine Company (7074), WP Liquidating Corp. (2310), Ashford Holding Corp. (8113), and HPMI, Inc. (4677). The mailing address for each of the Liquidating Debtors listed above, solely for purposes of notices and communications, is 400 S. Hope Street, Suite 1050, Los Angeles, California (Attn Lawrence Perkins, Chief Restructuring Officer). 2 Any party participating telephonically must make arrangements through CourtCall by telephone ( ) or facsimile ( ). 1

2 Case KJC Doc 635 Filed 04/24/18 Page 2 of 5 B. Certification of Counsel [D.I. No. 570; Filed 3/5/18]. C. Order (A) Approving the Disclosure Statement on an Interim Basis, (B) Approving the Form of Ballot and Solicitation Materials, (C) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Plan, (D) Scheduling a Plan Confirmation Hearing and Deadline for Filing Objections to Final Approval of the Disclosure Statement and Confirmation of the Plan, (E) Approving the Related Form of Notice, and (F) Granting Related Relief [D.I. No. 576; Filed 3/8/18] D. Notice of Rescheduled Omnibus and Plan Confirmation Hearing [D.I. 584; Filed 3/15/18]. E. Notice of Filing Solicitation Version of Plan [D.I. 611; Filed 4/6/18]. F. Notice of Filing Plan Supplement [D.I. 612; Filed 4/6/18]. G. Second Amended Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 629; Filed 4/23/18]. H. Notice of Filing Blackline of Second Amended Plan [D.I. No. 630; Filed 4/23/18]. I. Certification of JND Corporate Restructuring Regarding Tabulation of Votes in Connection with the First Amended Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 631; Filed 4/23/18]. J. Notice of Filing Proposed Confirmation Order [D.I. No. 632; Filed 4/23/18]. K. Memorandum of Law in Support of Confirmation of the Second Amended Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 633; Filed 4/23/18]. Responses Received A. Objection of Pension Benefit Guaranty Corporation to the Joint Motion of the Debtors and the Official Committee of Unsecured Creditors for Entry of an Order (A) Approving the Disclosure Statement on an Interim Basis, (B) Approving the Form of Ballot and Solicitation Materials, (C) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Plan, (D) Scheduling a Plan Confirmation Hearing and Deadline for Filing Objections to Final Approval of the Disclosure Statement and Confirmation of the Plan, (E) Approving the Related Form of Notice, and (F) Granting Related Relief [D.I. No. 553; Filed 2/20/18]. B. Informal response of the U.S. Trustee 2

3 Case KJC Doc 635 Filed 04/24/18 Page 3 of 5 C. Informal response of the U.S. Department of Justice, Environmental Enforcement Section D. Informal further response of the PBGC. E. Informal response of Majestic-Norwalk, LLC F. Objection by the United States to the Debtors Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 616; Filed 4/16/18]. G. Objection of David J. Feldman to Confirmation of the Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 618; Filed 4/18/18]. H. Texas Comptroller of Public Accounts Joinder in Support of the Objection by the United States to the Debtors Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 619; Filed 4/19/18]. I. Omnibus Reply of the Official Committee of Unsecured Creditors to Objections to Confirmation of the First Amended Combined Disclosure Statement and Plan of Liquidation [D.I. 620; Filed 4/20/18]. J. Notice of Withdrawal of Texas Comptroller of Public Accounts Joinder in Support of the Objection by the United States to the Debtors Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed Jointly by the Debtors and the Official Committee of Unsecured Creditors [D.I. No. 634; Filed 4/24/18]. Status Responses A, B, D, and E have been resolved by amendments to the Plan. Responses C and H have been resolved by language in the proposed form of confirmation order. This matter is going forward. 2. Motion For Relief from Stay [D.I. 550; Filed 2/20/18]. Response Deadline March 5, 2018, at 1159 p.m. (EST), per the agreement of the Debtors and Movant. Related Documents None. Responses Received A. Debtors Objection to the Motion for Relief from the Automatic Stay [D.I. 571; Filed 3/5/18]. Status The parties agreed to adjourn this matter to the hearing on April 26,

4 Case KJC Doc 635 Filed 04/24/18 Page 4 of 5 3. Amended Motion of David J. Feldman for Relief from (I) the Automatic Stay Under 11 U.S.C. 362(d) or (II) Any Plan Injunction [D.I. 610; Filed 4/5/18]. Response Deadline April 19, 2018, at 400 p.m. (EDT). Extended to April 21, 2018 at 2 p.m. (EDT) for the Debtors and the Creditors Committee. Related Documents None. Responses Received A. Objection of the Official Committee of Unsecured Creditors to the Amended Motion of David J. Feldman for Relief from (I) the Automatic Stay Under 11 U.S.C. 362(d) or (II) Any Plan Injunction [D.I. 621; Filed 4/21/18]. B. Debtors Objection to, and Joinder in the Official Committee of Unsecured Creditors Objection to, the Amended Motion of David J. Feldman for Relief from (I) the Automatic Stay Under 11 U.S.C. 362(d) or (II) Any Plan Injunction [D.I. 622; Filed 4/21/18]. C. Reply in Support of Amended Motion of David J. Feldman for Relief from (I) the Automatic Stay Under 11 U.S.C. 362(d) or (II) Any Plan Injunction [D.I. 627; Filed 4/23/18]. Status This matter is going forward. Dated April 24, 2018 Wilmington, Delaware Respectfully submitted, DLA PIPER LLP (US) /s/ Stuart M. Brown Stuart M. Brown (DE 4050) 1201 North Market Street, Suite 2100 Wilmington, Delaware Telephone (302) Facsimile (302) stuart.brown@dlapiper.com -and- 4

5 Case KJC Doc 635 Filed 04/24/18 Page 5 of 5 John K. Lyons (admitted pro hac vice) Daniel M. Simon (admitted pro hac vice) Oksana Koltko Rosaluk (admitted pro hac vice) 444 West Lake Street, Suite 900 Chicago, Illinois Telephone (312) Facsimile (312) john.lyons@dlapiper.com daniel.simon@dlapiper.com oksana.koltkorosaluk@dlapiper.com Counsel to the Debtors 5