Stipulation By and Between City of Detroit and BlueMountain Capital Management, LLC, on behalf of funds and accounts managed by it Re: Entry of an Order Concerning Intervenor Party . Filed by Interested Party Ad Hoc COPs Holders, Debtor In Possession City of Detroit, Michigan. (Fish, Deborah) (Entered: 08/22/2014)
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City of Detroit - 13-53846 - Motions, Briefs and Other Papers
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Motion to Exclude the Testimony of the City's Forecasting Experts Under Federal Rule of Evidence 702 Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Expert Report of Robert Cline # 8 Exhibit 6 B - Expert Report of Gaurav Malhotra # 9 Exhibit 6 C - Expert Report of Caroline Sallee # 10 Exhibit 6 D - Excerpts of July 14, 2014 R. Cline Deposition Transcript # 11 Exhibit 6 E - Excerpts of July 15, 2014 G. Malhotra Deposition Transcript # 12 Exhibit 6 F - Excerpts of July 24, 2014 C. Sallee Deposition Transcript # 13 Exhibit 6 G - Excerpts of July 31, 2014 M. Kopacz Deposition Transcript # 14 Exhibit 6 H - Excerpts of June 24, 2014 G. Evanko Deposition Transcript # 15 Exhibit 6 I - City of Detroit Ten-Year Financial Projections (July 2, 2014) (POA00706519) # 16 Exhibit 6 J - Excerpts of Expert Report of Martha Kopacz # 17 Exhibit 6 K - Excerpts of July 18, 2014 J. Hill Deposition Transcript # 18 Exhibit 6 L - Excerpts of Financial Stability Agreement (City Ex. 032) # 19 Exhibit 6 M - Michigan Municipal League, The Great Revenue Sharing Heist (Feb. 2014) (Syncora Ex. 4462) # 20 Exhibit 6 N - R. Cline Demonstratives (City Ex. 546 and 547) # 21 Exhibit 6 O - Excerpts of KPMG, Independent Auditors' Report (2012) # 22 Exhibit 6 P - Excerpts of Houlihan Lokey Expert Report (July 2014) # 23 Exhibit 6 Q - Excerpts of 6/14/13 City of Detroit Proposal for Creditors (City Ex. 033) # 24 Exhibit 6 R - Excerpts of Citizens Research Council of Michigan "Detroit City Government Revenues," Report 382, April 2013 (Syncora Ex. 4466) # 25 Exhibit 6 S - Excerpts of the Expert Report of Charles Moore (City Ex. 464)) (Hackney, Stephen) (Entered: 08/22/2014)
Motion in Limine to Preculde Its Counsel, Heather Lennox, From Being Called as a Trial Witness Filed by Debtor In Possession City of Detroit, Michigan (Bennett, Bruce) (Entered: 08/22/2014)
Motion in Limine to Preclude Its Counsel, Evan Miller, from Being Called as a Trial Witness Filed by Debtor In Possession City of Detroit, Michigan (Bennett, Bruce) (Entered: 08/22/2014)
Motion to Exclude Testimony of Victor Wiener Filed by Debtor In Possession City of Detroit, Michigan (Bennett, Bruce) (Entered: 08/22/2014)
Motion to Exclude Certain of the Expert Opinions of Martha Kopacz Under Federal Rule of Evidence 702 Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Expert Report of Martha Kopacz # 8 Exhibit 6 B - Excerpts of July 31, 2014 M. Kopacz Deposition Transcript # 9 Exhibit 6 C - Order Appointing Expert Witness [Docket No. 4215] # 10 Exhibit 6 D - Excerpts of July 14, 2014 R. Cline Deposition Transcript # 11 Exhibit 6 E - Excerpts of July 15, 2014 G. Malhotra Deposition Transcript # 12 Exhibit 6 F - Excerpts of July 24, 2014 C. Sallee Deposition Transcript) (Hackney, Stephen) (Entered: 08/22/2014)
Motion Syncora Guarantee Inc. and Syncora Capital Assurance Inc.'s Motion to Exclude the Testimony of John W. Hill Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Expert Report of John Hill # 8 Exhibit 6 B - Excerpts of July 18, 2014 J. Hill Deposition Transcript # 9 Exhibit 6 C - Excerpts of Expert Report of Martha Kopacz # 10 Exhibit 6 D - Revenue Consensus Conference Report (3/18/14) # 11 Exhibit 6 E - 2/4/14 Email from J. Naglick re: FAB Detroit Revenue Conference) (Hackney, Stephen) (Entered: 08/22/2014)
Amended Motion To Exclude Testimony Of Martha Kopacz Under Fed. R. Evid. 702 In Connection With Certain Of Her Expert Opinions Contained In Her Expert Report Filed by Creditor Oakland County, Michigan (Fischer, Joseph) (Entered: 08/22/2014)
Motion / Financial Guaranty Insurance Company's Motion in Limine to Preclude the Introduction of Evidence or Testimony Regarding Certain Matters Previously Deemed Irrelevant by the Court or the City of Detroit Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service # 5 Exhibit None [No Affidavit] # 6 Exhibit July 21-22, 2014, Deposition Transcript of Kevyn Orr (excerpted) # 7 Exhibit July 22, 2014 Expert Witness Report of Stuart Ira Wohl (excerpted) # 8 Exhibit August 13, 2014 Deposition Transcript of Stuart Ira Wohl (excerpted) # 9 Exhibit July 31, 2014 Deposition Transcript of Rip Rapson (excerpted) # 10 Exhibit Emails (K001265-1266; 1272-1273) # 11 Exhibit August 4, 2014 Deposition Transcripts of D. Muchmore (excerpted)) (Perez, Alfredo) (Entered: 08/22/2014)
Motion / Financial Guaranty Insurance Company's Motion in Limine to Preclude the Introduction of Evidence or Testimony Regarding Matters Withheld from Discovery on the Basis of the Mediation Order Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service # 5 Exhibit None [No Affidavit] # 6 Exhibit 7/22/2014 Deposition Transcript of K. Orr (excerpted) # 7 Exhibit 7/31/2014 Deposition Transcript of R. Rapson (excerpted) # 8 Exhibit 8/4/2014 Deposition Transcript of B. Stibitz (excerpted) # 9 Exhibit 8/4/2014 Deposition Transcript of D. Muchmore (excerpted) # 10 Exhibit 7/22/2014 Deposition Transcript of A. Erickson (excerpted) # 11 Exhibit 7/25/2014 Deposition Transcript of E. Jenkins (excerpted) # 12 Exhibit City of Detroit Plan Confirmation Factual Propositions # 13 Exhibit 7/29/2014 Deposition Transcript of D. Gilbert (excerpted)) (Perez, Alfredo) (Entered: 08/22/2014)
Motion / Financial Guaranty Insurance Company's Motion to Exclude the Expert Opinion of Michael Plummer Regarding Discount Factors Filed by Creditor Financial Guaranty Insurance Company (Attachments: # 1 Exhibit Proposed Form of Order # 2 Exhibit Notice of Motion and Opportunity to Object # 3 Exhibit None [Brief Not Required] # 4 Exhibit Certificate of Service [To be filed separately] # 5 Exhibit None [No Affidavit] # 6 Exhibit Expert Witness Report of Michael Plummer # 7 Exhibit Expert Deposition of Michael Plummer) (Perez, Alfredo) (Entered: 08/22/2014)
Motion in Limine Barring the City and Plan Supporters from Introducing Evidence Regarding the Potential Personal Hardship of Pensioners Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 26, 2014 Hearing Transcript # 8 Exhibit 6 B - August 6, 2014 Hearing Transcript # 9 Exhibit 6 C - July 22, 2014 K. Orr Deposition Transcript # 10 Exhibit 6 D - 6/13/14 Email from G. Shumaker to B. Arnault) (Hackney, Stephen) (Entered: 08/22/2014)
Motion in Limine Barring the City from Introducing Communications Protected by the Court's Mediation Order Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 30, 2014 G. Bowen Deposition Transcript # 8 Exhibit 6 B - July 2, 2014 M. Hall Deposition Transcript # 9 Exhibit 6 C - July 14, 2014 G. Malhotra Deposition Transcript # 10 Exhibit 6 D - July 16, 2014 K. Buckfire Deposition Transcript # 11 Exhibit 6 E - July 22, 2014 K. Orr Deposition Transcript # 12 Exhibit 6 F - Plan Confirmation Factual Propositions # 13 Exhibit 6 G - August 13, 2014 S. Taranto Deposition Transcript # 14 Exhibit 6 H - May 28, 2014 Hearing Transcript) (Hackney, Stephen) (Entered: 08/22/2014)
Motion in Limine to Preclude Debtor from Offering Evidence Relating to (A) the Recoveries of Classes 10 and 11 Independent of the Funds from the DIA Funding Parties and the State and (B) the Topics Identified in Syncora's Subpoenas to the Foundations Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - June 26, 2014 Hearing Transcript # 8 Exhibit 6 B - John S. and James L. Knight Foundation Subpoena) (Hackney, Stephen) (Entered: 08/22/2014)
Motion in Limine Barring the City from Introducing Evidence Regarding the Combined Recoveries of Pension and OPEB Claims Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index Summary of Exhibits # 2 Exhibit 1 - Proposed Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - None [Brief Not Required] # 5 Exhibit 4 - None [Separate Certificate of Service to be Filed] # 6 Exhibit 5 - Affidavits [Not Applicable] # 7 Exhibit 6 A - Nov. 8, 2013 Eligibility Hearing Transcript # 8 Exhibit 6 B - July 16, 2014 K. Buckfire Deposition Transcript # 9 Exhibit 6 C - July 22, 2014 K. Orr Deposition Transcript # 10 Exhibit 6 D - July 30, 2014 email from G. Shumaker to S. Hackney # 11 Exhibit 6 E - March 5, 2014 Hearing Transcript) (Hackney, Stephen) (Entered: 08/22/2014)
Stipulation By and Between the City of Detroit and the Detroit Police Officers Association Re: Order Reflecting Amended Terms of Tentative Agreement Between the City of Detroit and the Detroit Police Officers Association Regarding Plan of Adjustment . Filed by Debtor In Possession City of Detroit, Michigan. (Lennox, Heather) (Entered: 08/22/2014)
Ex Parte Motion to Expedite Hearing (related documents 6946 Generic Motion) Ex Parte Motion of Syncora Guarantee Inc. and Syncora Capital Assurance Inc. for Shortened Notice and Expedited Hearing on Motion for Clarification of Post-Confirmation Procedures Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Exhibit 1 - Proposed Order) (Bennett, Ryan) (Entered: 08/21/2014)
Motion for Clarification of Post-Confirmation Procedures Filed by Interested Parties Syncora Capital Assurance Inc., Syncora Guarantee Inc. (Attachments: # 1 Index - Summary of Attachment # 2 Exhibit 1 - Proposed Form of Order # 3 Exhibit 2 - Notice of Motion and Opportunity to Object # 4 Exhibit 3 - Brief in Support of Motion [Brief Not Required] # 5 Exhibit 4 - Certificate of Service [To Be Filed Separately] # 6 Exhibit 5 - Declaration [Not Applicable] # 7 Exhibit 6 - Documentary Exhibits [Not Applicable]) (Bennett, Ryan) (Entered: 08/21/2014)
Sixth Amended Chapter 9 Plan Sixth Amended Plan for the Adjustment of Debts of the City of Detroit Filed by Debtor In Possession City of Detroit, Michigan (RE: related document(s)2708 Chapter 9 Plan). (Attachments: # 1 Exhibit I.A.9 through I.A.279 # 2 Exhibit I.A.285 through I.A.334 # 3 Exhibit I.A.341 through III.D.2) (Heiman, David) (Entered: 08/20/2014)
Stipulation By and Between City of Detroit, Police and Fire Retirement System of the City of Detroit, and the General Retirement System of the City of Detroit Re: Entry of Order Extending the Detroit Retirement Systems' Deadline to Respond to the DWSD Postpetition Financing and Settlement Motion . Filed by Debtor In Possession City of Detroit, Michigan, Creditors General Retirement System of the City of Detroit, Police and Fire Retirement System of the City of Detroit. (Gordon, Robert) (Entered: 08/20/2014)