Document Page 1 of 14 JONES DAY North Point 901 Lakeside Avenue Cleveland, Ohio 44114 Telephone: (216) 586-3939 Facsimile: (216) 579-0212 David G. Heiman (admitted pro hac vice) Carl E. Black (admitted pro hac vice) Thomas A. Wilson (admitted pro hac vice) Attorneys for Debtors and Debtors in Possession HUNTON & WILLIAMS LLP Riverfront Plaza, East Tower 951 East Byrd Street Richmond, Virginia 23219 Telephone: (804) 788-8200 Facsimile: (804) 788-8218 Tyler P. Brown (VSB No. 28072) J.R. Smith (VSB No. 41913) Henry P. (Toby) Long, III (VSB No. 75134) Justin F. Paget (VSB No. 77949) IN THE UNITED STATES BANKRUPTCY COURT FOR THE EASTERN DISTRICT OF VIRGINIA RICHMOND DIVISION In re: Alpha Natural Resources, Inc., et al., Debtors. Chapter 11 Case No. 15-33896 (KRH) (Jointly Administered) NOTICE OF AGENDA OF MATTERS SCHEDULED FOR HEARING ON JUNE 28, 2016 Time of Hearing: Location of Hearing: 10:00 a.m. (prevailing Eastern Time) Courtroom of the Honorable Kevin R. Huennekens, United States Bankruptcy Court for the Eastern District of Virginia, Richmond Division, 701 East Broad Street, Courtroom 5000, Richmond, Virginia 23219 ADJOURNED MATTERS 1. Joint Motion of West Virginia Litigation Claimants for Relief from the Automatic Stay [Docket No. 490]. Status: In accordance with paragraph 1(e) of the case management procedures approved pursuant to the Order Establishing Certain Notice, Case Management and Administrative Procedures (Docket No. 111) (the "Case Management Procedures"), the hearing on this matter with respect to all parties not addressed in the order entered on June 10, 2016 [Docket No. 2637] (the "Remaining Parties") is adjourned until July 19, 2016 at 10:00 a.m. (Eastern Time).
Document Page 2 of 14 Objection Deadline: November 26, 2015. By agreement of the parties, the deadline for the Debtors to object with respect to the Remaining Parties has been extended until July 11, 2016. None to date. 2. Motion for Order Authorizing and Compelling Examinations and Production of Documents Pursuant to Rule 2004 [Filed by West Virginia Litigation Claimants; Docket No. 492]. Status: In accordance with paragraph 1(e) of the Case Management Procedures, the hearing on this matter is adjourned until July 19, 2016 at 10:00 a.m. (Eastern Time). Objection Deadline: November 26, 2015. By agreement of the parties, the deadline for the Debtors to object has been extended until July 11, 2016. None to date. 3. Motion of the Debtors, Pursuant to Section 363 of the Bankruptcy Code, for an Order Authorizing Debtors to Terminate Certain Unvested Non-Pension Benefits [Docket No. 797]. Status: In accordance with paragraph 1(e) of the Case Management Procedures, the hearing on this matter is adjourned until July 19, 2016 at 10:00 a.m. (Eastern Time). Objection Deadline: November 27, 2015. A. Declaration of Judy Tweed Hill, Vice President, Benefits of Alpha Natural Resources, Inc. in Support of Motion of the Debtors, Pursuant to Section 363 of the Bankruptcy Code, for an Order Authorizing Debtors to Terminate Certain Unvested Non-Pension Benefits [Filed by the Debtors; Docket No. 799]. B. Notice of Adjournment [Filed by the Debtors; Docket No. 988]. C. Exhibit [Filed by E. Leroy Tidwell; Docket No. 1160]. Objections Received: D. Response to Motion of the Debtors, Pursuant to Section 363 of the Bankruptcy Code, for an Order Authorizing Debtors to Terminate Certain Unvested Non-Pension Benefits [Filed by Michael J. Quillen, et al.; Docket No. 877]. -2-
Document Page 3 of 14 E. Response to Motion of the Debtors, Pursuant to Section 363 of the Bankruptcy Code, for an Order Authorizing Debtors to Terminate Certain Unvested Non-Pension Benefits [Filed by Harold Helton; Docket No. 879]. F. Objection to Motion of the Debtors, Pursuant to Section 363 of the Bankruptcy Code, for an Order Authorizing Debtors to Terminate Certain Unvested Non-Pension Benefits [Filed by David Canterbury, et al.; Docket No. 880]. G. The United Mine Workers of America's (I) Response and Limited Objection to Debtors' Motion to Terminate Certain Unvested Non-Pension Obligations; (II) Statement in Support of Motion for Continuance; and (III) Statement Regarding the Motion to Appoint Retiree Committee [Docket No. 907]. H. Objection [Filed by Donald E. Keener, Jr.; Docket No. 914]. I. Objection [Filed by Timothy M. Talley; Docket No. 915]. J. Objection [Filed by Randy Miller; Docket No. 916]. K. Objection [Filed by Roy West; Docket No. 928]. L. Objection [Filed by Don Rey Reed; Docket No. 929]. M. Objection [Filed by E. Leroy Tidwell; Docket No. 1019]. UNCONTESTED MATTERS 4. Motion of the Debtors for an Order Authorizing the Rejection of Operations Agreement with Veolia Water North America Operating Services, LLC [Docket No. 1883]. Objection Deadline: April 8, 2016. By agreement of the parties, the deadline for Veolia Water North America Operating Services, LLC to object was extended until June 21, 2016. None to date. 5. Debtors' Motion to Approve the Stipulation and Agreed Order Between Debtors and SAP America, Inc. Concerning the Assumption of a Certain Software Agreement [Docket No. 2612]. Objection Deadline: June 21, 2016. -3-
Document Page 4 of 14 None to date. 6. Debtors' Motion for an Order Authorizing the Rejection of a Certain Services Agreement with Cintas, Effective as of June 10, 2016 [Docket No. 2641]. Objection Deadline: June 24, 2016. None to date. 7. Motion for Entry of a Consent Order Modifying the Automatic Stay Pursuant to Section 362 of the Bankruptcy Code [Filed by the Virginia Department of Transportation; Docket No. 2633]. Objection Deadline: June 24, 2016. None to date. 8. Motion of Debtors and Debtors in Possession for Entry of an Order, Pursuant to Sections 105, 365 and 1123 of the Bankruptcy Code, (I) Establishing Procedures with Respect to the Proposed Assumption, Assumption and Assignment, and Rejection of Executory Contracts and Unexpired Leases and the Treatment of Other Agreements Pursuant to the Debtors' Second Amended Joint Plan of Reorganization and Applicable Law and (II) Approving the Form and Manner of Notice Thereof [Docket No. 2673]. Objection Deadline: June 24, 2016. None to date. 9. Sureties' Motion for Estimation and Allowance of Claims Pursuant to 11 U.S.C. 502(c) [Docket No. 2614] (the "Sureties Motion"). Objection Deadline: June 21, 2016. -4-
Document Page 5 of 14 A. The Argo Motion (as defined below). B. The Liberty Mutual Motion (as defined below). The parties have reached a consensual resolution of this matter, which resolution will be reflected in a stipulation and agreed order to be submitted by the Debtors at the hearing. 10. Argo's Joinder Motion to Sureties' Motion for Estimation and Allowance of Claims Pursuant to 11 U.S.C. 502(c) [Docket No. 2695] (the "Argo Motion"). Objection Deadline: June 28, 2016 at 9:00 a.m. (Eastern Time). A. The Sureties Motion. B. Argo's Motion to Expedite Consideration of, and Shorten the Notice Period Applicable to, Argo's Joinder to Sureties' Motion for Estimation and Allowance of Claims Pursuant to 11 U.S.C. 502(c) [Docket No. 2696]. The parties are discussing a consensual resolution of this matter, which resolution is expected to be reflected in a stipulation and agreed order to be submitted by the Debtors at the hearing. 11. Liberty Mutual Insurance Company's Motion for (I) Estimation and Temporary Allowance of Claims for Voting Purposes under Federal Rule of Bankruptcy Procedure 3018, (II) Modified Classification of Claims for Voting Purposes and (III) Joinder to Sureties' Motion for Estimation and Allowance of Claims [Docket No. 2717] (the "Liberty Mutual Motion"). Objection Deadline: June 28, 2016 at 9:00 a.m. (Eastern Time). A. The Sureties Motion. B. Liberty Mutual Insurance Company's Motion to Expedite Consideration and Shorten Notice Period of its Motion for (I) Estimation and Temporary Allowance of Claims for Voting Purposes under Federal Rule of Bankruptcy Procedure 3018, -5-
Document Page 6 of 14 (II) Modified Classification of Claims for Voting Purposes and (III) Joinder to Sureties' Motion for Estimation and Allowance of Claims [Docket No. 2718]. The parties are discussing a consensual resolution of this matter, which resolution is expected to be reflected in a stipulation and agreed order to be submitted by the Debtors at the hearing. 12. Motion to Reconsider Order (A) Approving Termination of Supplemental Benefit Plans, (B) Directing Return of Trust Funds to the Estates, (C) Rejecting Trust Agreements and (D) Granting Certain Related Relief [Filed by Frank Matras, et al.; Docket No. 2629]. Objection Deadline: June 24, 2016. A. Motion of the Debtors for an Order (A) Approving Termination of Supplemental Benefit Plans, (B) Directing Return of Trust Funds to the Estates, (C) Rejecting Trust Agreements and (D) Granting Certain Related Relief [Docket No. 2417]. B. Objection to Motion of the Debtors for an Order (A) Approving Termination of Supplemental Benefit Plans, (B) Directing Return of Trust Funds to the Estate, (C) Rejecting Trust Agreements and (D) Granting Certain Related Relief [Filed by Frank Matras, et al.; Docket No. 2560]. C. Reply in Support of Motion of the Debtors for an Order (A) Approving Termination of Supplemental Benefit Plans, (B) Directing Return of Trust Funds to the Estates, (C) Rejecting Trust Agreements and (D) Granting Certain Related Relief [Filed by the Debtors; Docket No. 2565]. D. Order (A) Approving Termination of Supplemental Benefit Plans, (B) Directing Return of Trust Funds to the Estates, (C) Rejecting Trust Agreements and (D) Granting Certain Related Relief [Docket No. 2587]. -6-
Document Page 7 of 14 CONTESTED MATTERS 13. Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Docket No. 1646]. Status: This hearing on this matter with respect to the agreements that are the subject of a Continued Objection (identified as Item Nos. M-U below) is adjourned until July 7, 2016 at 10:00 a.m. (Eastern Time) in accordance with paragraph 1(e) of the Case Management Procedures. The hearing on this matter is going forward with respect to the agreements that are the subject of a Resolved Objection (identified as Item Nos. V-Z below) or a Contested Objection (identified as Item Nos. AA-FF below). The Debtors also seek to reject the agreement subject to the PBM Cure Objection (defined below), which objection is moot and listed as a Resolved Objection. To the extent the Debtors are able to resolve any Continued Objection in advance of the hearing, the Debtors also will seek approval of the motion with respect to such resolved Continued Objection. Objection Deadline: April 5, 2016. A. Order (I) Authorizing the Debtors to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Doc. No. 2239]. B. Order Authorizing the Debtors to Assume Certain Leases of Nonresidential Real Property and Granting Related Relief [Docket No. 2524]. C. Order (I) Authorizing the Debtors to (A) Reject Certain Unexpired Leases of Non-Residential Real Property and (B) Assume Certain Leases of Non- Residential Real Property, and (II) Granting Related Relief [Docket No. 2639]. D. Order (I) Authorizing the Debtors to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Leases of Nonresidential Real Property, and (II) Granting Related Relief [Docket No. 2727]. E. Notice of Amendment of Schedules of Nonresidential Real Property Leases [Filed by the Debtors; Docket No. 1804]. F. Notice of Amendment of Schedules of Nonresidential Real Property Leases [Filed by the Debtors; Docket No. 1805]. -7-
Document Page 8 of 14 G. Notice of Amendment of Schedules of Nonresidential Real Property Leases [Filed by the Debtors; Docket No. 1808]. H. Notice of Redesignation of Unexpired Leases of Nonresidential Real Property as Assumed Leases [Filed by the Debtors; Docket No. 1881]. I. Notice of Redesignation of Unexpired Leases of Nonresidential Real Property as Assumed Leases [Filed by the Debtors; Docket No. 1882]. J. Notice of Redesignation of Unexpired Leases of Nonresidential Real Property as Assumed Leases [Filed by the Debtors; Docket No. 1885]. K. Notice of Amendment of Schedules of Nonresidential Real Property Leases to Add Certain Additional Assumed Leases and Extended Deadline Leases [Filed by the Debtors; Docket No. 1886]. L. Declaration of Scott Kreutzer in Support of Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Docket No. 2649]. Objections Received: (i) Continued Objections M. Objection to Cure Amount as Set Forth in Third Omnibus Motion of the Debtors for Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by Westvarendrag, Inc.; Docket No. 1911]. N. Objection to Cure Amount as Set Forth in the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by Piney Land Co., et al.; Docket No. 1915]. O. Objection to Cure Amount as Set Forth in the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by JRY Natural Resources, LLC; Docket No. 1916]. -8-
Document Page 9 of 14 P. Objection of Honey Island Coal Co., LLC d/b/a Federal Coal Company, to the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief (Doc. 1646) and to Related Notice; and, to Notice of (I) Auction and Sale Hearing for the Sale of Certain of the Debtors' Mining Properties and Related Assets and (II) Hearing on Settlements with Pre-Petition Lenders (Doc. 1769), and to Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts (Doc. 1811) [Docket No. 1927]. Q. Natural Resource Partners L.P., WPP LLC, ACIN LLC, WBRD, LLC, and Western Pocahontas Properties, LP's Objection to Debtors' Proposed Cure Amounts [Docket No. 1938]. R. Limited Objection of Liberty Mutual Insurance Company to Third Omnibus Motion of the Debtors for an Order (I) Authorizing them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Docket No. 1945]. S. WPP LLC's Supplement to its Objection to Debtors' Proposed Cure Amounts [Docket No. 2058]. T. Natural Resource Partners L.P., WPP LLC, ACIN LLC, WBRD, LLC, and Western Pocahontas Properties, LP's Amended Objection to Debtors' Proposed Cure Amounts [Docket No. 2361]. U. United States' Objection to Debtors' Notice and Motion to Assume and Assign Federal Leases, Contracts and Right-of-Way [Docket No. 2724]. (ii) Resolved Objections V. Limited Objection of Appalachian Power Company D/B/A American Electric Power, Dominion Transmission, Inc., and West Penn Power Company to Notices of (I) Potential Assumption and/or Assignment of Executory Contracts and Unexpired Leases and (II) Cure Amounts [Docket No. 1910]. W. Objection to Cure Amount as Set Forth in Third Omnibus Motion of the Debtors for Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by Pardee Minerals LLC; Docket No. 1912]. -9-
Document Page 10 of 14 X. Objection by the Huntington National Bank, Trustee for the John D. Moore Trust, to the Proposed Assumption of Unexpired Leases and Cure Amounts to Which the John D. Moore Trust is a Party [Docket No. 1943]. Y. PBM Holdings, LLC and Brian D. McCay, Michael B. McCay and Patrick M. McCay's Omnibus Response and Objections to (1) Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief and (2) Debtors' Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts and Objections to Proposed Cure Amounts [Docket No. 1946] (the "PBM Cure Objection"). Z. Assumption and Cure Objection of Consol Energy, Inc. [Docket No. 2118]. (iii) Contested Objections AA. Objection to the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by Mary Evelyn Amstutz, et al.; Docket No. 1751]. BB. Objection [Filed by William John Neace, et al.; Docket No. 1898]. CC. DD. EE. Objection to Cure Amount as Set Forth in the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Filed by the David J. Pierce Trust; Docket No. 1914]. Objection to Notice of Redesignation of Unexpired Leases of Nonresidential Real Property as Rejected Leases [Filed by the David J. Pierce Trust; Docket No. 1917]. Further Objection to the Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Unexpired Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief and to Notice of Redesignation Pursuant Thereto [Filed by Mary Evelyn Amstutz, et al.; Docket No. 1924]. -10-
Document Page 11 of 14 FF. The Williams Heirs' Objection to Third Omnibus Motion of the Debtors for an Order (I) Authorizing Them to (A) Reject Certain Leases of Nonresidential Real Property and (B) Assume Certain Unexpired Leases of Nonresidential Real Property, (II) Extending the Deadline to Assume or Reject Certain Unexpired Leases of Nonresidential Real Property and (III) Granting Related Relief [Docket No. 1926]. 14. Debtors' Combined Motion for Entry of (A) an Order Establishing Bidding and Sale Procedures for the Potential Sale of Certain Mining Properties and Related Assets and Granting Related Relief and (B) One or More Orders Approving the Sale of Such Properties [Docket No. 707]. Objection Deadline: January 20, 2016. Pursuant to paragraph 14 of the Bidding Procedures Order (as defined below), the deadline for objecting to approval of the sale of assets relating to the Knox Creek Mining Complex in Buchanan, Tazewell and Russell Counties, Virginia solely as a result of the revisions to the sale transaction documents has been extended to June 24, 2016. A. Notice of (A) Designation of Successful Bid for Assets Relating to the Knox Creek Mining Complex in Buchanan, Tazewell and Russell Counties, Virginia and (B) Rescheduling of Sale Hearing [Docket No. 2726]. B. Order (I) Approving Bidding and Sale Procedures for Certain Mining Properties and Related Assets, (II) Approving the Form and Manner of Notice of the Related Assumption and Assignment of Executory Contracts and Unexpired Leases and (III) Scheduling an Auction and Sale Hearing [Docket No. 855] (the "Bidding Procedures Order"). C. Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts [Filed by the Debtors; Docket No. 987]. D. Second Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts [Filed by the Debtors; Docket No. 1081]. E. Third Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts [Filed by the Debtors; Docket No. 1136]. F. Notice of Filing of Form of Asset Purchase Agreement in Connection with Bidding Procedures [Filed by the Debtors; Docket No. 1013]. G. Notice of Filing of Form of Sale Order in Connection with Bidding Procedures [Filed by the Debtors; Docket No. 1014]. -11-
Document Page 12 of 14 H. Updated Notice of Auction and Sale Hearing for the Sale of Certain of the Debtors' Mining Properties [Filed by the Debtors; Docket No. 1076]. I. Notice of Filing of Updated Asset and Permit Schedules [Filed by the Debtors; Docket No. 1077]. J. Notice of Filing of Updated Forms of Asset Purchase Agreements in Connection with Bidding Procedures [Filed by the Debtors; Docket No. 1254]. K. Notice of Prohibition Against Transfer of License or Disposal of Licensed Radioactive Material Without Prior Written Approval of the United States Nuclear Regulatory Commission and Notice of Debtors' Obligations as General Licensee of the United States Nuclear Regulatory Commission [Filed by the United States of America; Docket No. 1198]. L. Reservation of Rights of Lexon Insurance Co. and Bond Safeguard Insurance Co. to Debtors' Form of Sale Order in Connection with Sale Transactions [Docket No. 1338]. Objections Received: M. Limited Objection of Appalachian Power Company d/b/a American Electric Power to Notice of (A) Potential Assumption and Assignment of Executory Contracts and Unexpired Leases and (B) Cure Amounts [Docket No. 1201]. N. Tazewell County Treasurer's Limited Objection to Sale of Certain Mining Properties and Related Assets Free and Clear of Liens [Docket No. 1289]. O. Objection and Reservation of Rights of Pocahontas Land Corporation, Pocahontas Development Corporation and Norfolk Southern Railway Company to Debtors' Combined Motion for Entry of (A) an Order Establishing Bidding and Sale Procedures for the Potential Sale of Certain Mining Properties and Related Assets and Granting Related Relief and (B) One or More Orders Approving the Sale of Such Properties [Docket No. 1328]. P. Limited Objection of Coal Mountain Mining Company, Limited Partnership, LLP; Commonwealth Coal Corporation; and Swords Creek Land Partnership to the Debtors' Proposed Sale Transaction, Form of Asset Purchase Agreement, and Form of Sale Order [Docket No. 1336]. 15. Motion for Reconsideration of the Court's Section 1114 Order [Filed by the United Mine Workers of America Combined Benefit Fund and the United Mine Workers of America 1992 Benefit Plan; Docket No. 2595]. Objection Deadline: June 21, 2016. -12-
Document Page 13 of 14 A. Motion of Debtors and Debtors in Possession to (I) Reject Certain Collective Bargaining Agreements and (II) Modify Certain Retiree Benefit Obligations, Pursuant to Sections 1113(c) and 1114(g) of the Bankruptcy Code [Docket No. 1873]. B. Debtors' and Debtors in Possession's Omnibus Reply in Support of Their Motion to (I) Reject Certain Collective Bargaining Agreements and (II) Modify Certain Retiree Benefit Obligations, Pursuant to Sections 1113(c) and 1114(g) of the Bankruptcy Code [Docket No. 2346]. C. Memorandum Opinion [Docket No. 2499]. D. Order (I) Authorizing Rejection of Certain Collective Bargaining Agreements and (II) Modifying Certain Retiree Benefit Obligations Pursuant to Sections 1113(c) and 1114(g) of the Bankruptcy Code [Docket No. 2500]. Objections Received: E. Objection of the Debtors to the Coal Act Funds' Motion for Reconsideration of the Court's Section 1114 Order [Docket No. 2729]. 16. Motion of Creditor Mar-Bow Value Partners, LLC to Compel McKinsey Recovery & Transformation Services U.S., LLC, Turnaround Advisor for the Debtors, to Comply with the Requirements of Bankruptcy Rule 2014 [Docket No. 2603]. Objection Deadline: June 21, 2016. A. Affidavit of William M. Regan in Opposition to Mar-Bow Value Partners, LLC's Motion to Compel Compliance with Bankruptcy Rule 2014 [Docket No. 2735]. B. Affidavit of Kevin Carmody in Opposition to Mar-Bow Value Partners, LLC's Motion to Compel Compliance with Bankruptcy Rule 2014 [Docket No. 2739]. Objections Received: C. McKinsey Recovery & Transformation Services U.S., LLC's Memorandum of Law in Opposition to Mar-Bow Value Partners, LLC's Motion to Compel Compliance with Bankruptcy Rule 2014 [Docket No. 2734]. -13-
Document Page 14 of 14 Dated: June 24, 2016 Richmond, Virginia Respectfully submitted, /s/ Henry P. (Toby) Long, III Tyler P. Brown (VSB No. 28072) J.R. Smith (VSB No. 41913) Henry P. (Toby) Long, III (VSB No. 75134) Justin F. Paget (VSB No. 77949) HUNTON & WILLIAMS LLP Riverfront Plaza, East Tower 951 East Byrd Street Richmond, Virginia 23219 Telephone: (804) 788-8200 Facsimile: (804) 788-8218 David G. Heiman (admitted pro hac vice) Carl E. Black (admitted pro hac vice) Thomas A. Wilson (admitted pro hac vice) JONES DAY North Point 901 Lakeside Avenue Cleveland, Ohio 44114 Telephone: (216) 586-3939 Facsimile: (216) 579-0212 ATTORNEYS FOR DEBTORS AND DEBTORS IN POSSESSION -14-