al.,’ ) - amazon web servicesupshotservices.s3.amazonaws.com/files/0135ac04-c1...engine platforms....

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

In re: )

REVSTONE INDUSTRIES, LLC, et al.,’ ) )

Debtors. ) )

)

In re: ) )

METAVATION, LLC, ) )

Debtor. ) )

Chapter 11

Case No. 12-13262 (BLS) (Jointly Administered)

Related to Docket Nos. 792 & 818

Chapter 11

Case No. 13-11831 (BLS) (Joint Administration Requested)

Related to Docket Nos. 15 & 47

NOTICE OF FIRST DAY MOTION AND ENTRY OF ORDER REGARDING MOTION FOR AUTHORIZATION TO (I) CONTINUE

PREPETITION INSURANCE PROGRAM AND (II) PAY ANY PREPETITION PREMIUMS AND RELATED OBLIGATIONS

TO: (i) the Office of the United States Trustee; (ii) the Debtor’s prepetition and postpetition secured lenders; (iii) the Pension Benefit Guaranty Corporation; (iv) the Debtor’s major OEM customers: General Motors, Chrysler, and Ford; (v) Dayco Products, LLC and Dayco Products S.A. de C.V., the stalking horse purchaser for the Debtor’s assets; (vi) the Official Committee of Unsecured Creditors in the case of Revstone Industries, LLC; and (vii) Insurance Carriers listed on Exhibit A to the Motion.

PLEASE TAKE NOTICE that on July 22, 2013, the above-captioned debtor and

debtor in possession (the "Debtor") filed a voluntary petition for relief under chapter 11 of title

11 of the United States Code with the Clerk of the United States Bankruptcy Court for the

District of Delaware (the "Bankruptcy Court").

The Debtors in these Chapter 11 Cases and the last four digits of each Debtor’s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors’ headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505.

DOCSDE:188759.1 73864/002

Case 12-13262-BLS Doc 865 Filed 07/31/13 of 2

PLEASE TAKE FURTHER NOTICE that the Debtor presented certain

first-day motions at a hearing before the Honorable Brendan L. Shannon at the Bankruptcy

Court on July 24, 2013. The Bankruptcy Court considered the Motion for Authorization to

(I) Continue Prepetition Insurance Program and (II) Pay Any Prepetition Premiums

and Related Obligations [Revstone Docket No. 792; Metavation Docket No. 15] (the

"Motion") attached hereto as Exhibit 1 and entered the Order Granting Motion of Debtor for

Order Authorizing Debtor to Continue Its Insurance Program [Revstone Docket No. 818;

Metavation Docket No. 47], attached hereto as Exhibit 2.

Dated: July ’31, 2013 PACHULSKI STANG ZIEHL & JONES LLP

Laura Davis Jones (Bar No. 2436) David M. Bertenthal (CA Bar No. 167624) Timothy P. Cairns (Bar No. 4228) Cohn R. Robinson (Bar No. 5524) 919 N. Market Street, 17th Floor Wilmington, DE 19801 Telephone: 302/652-4100 Facsimile: 302/652-4400 Email: [email protected]

[email protected] [email protected] [email protected]

[Proposed] Counsel for the Debtor and Debtor in Possession

2 D005_DE: 188759.1 73864/002

Case 12-13262-BLS Doc 865 Filed 07/31/13 of 2

Exhibit 1

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Case 12-13262-BLS Doc 865-1 Filed 07/31/13 Page 1 of 18



In re: ) Chapter 11

REVSTONE INDUSTRIES, LLC, et al.,’ ) Case No. 12-13262 (BLS) )

Debtors. ) (Jointly Administered)

In re: ) Chapter 11 )

METAVATION, LLC, ) Case No. 13-11831 (BLS) )

Debtor. ) (Joint Administration Requested)

MOTION FOR AUTHORIZATION TO (I) CONTINUE PREPETITION INSURANCE PROGRAM AND (II) PAY ANY PREPETITION PREMIUMS

AND RELATED OBLIGATIONS

Metavation, LLC, the above-captioned debtor and debtor in possession herein

(the "Debtor" or "Metavation"), submits this Motion for Authorization to (i) Continue

Prepetition Insurance Programs, and (ii) Pay Any Prepetition Premiums and Related

Obligations (the "Motion"). In support of the Motion, the Debtor respectfully states as follows:

JURISDICTION AND VENUE

1. This Court has jurisdiction over this Motion pursuant to 28 U.S.C.

§§ 157 and 1334. Venue of the Debtor’s Chapter 11 case in this district is proper pursuant to

28 U.S.C. §§ 1408 and 1409. This is a core proceeding pursuant to 28 U.S.C. § 157(b).

The Debtors in these Chapter 11 Cases and the last four digits of each Debtor’s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors’ headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505.

Ds$e:

Docket #:__________

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2. The statutory predicates for the relief sought hereby are Sections 105(a)

and 363(b)(1) of title 11 of the United States Code (the "Bankruptcy Code").

BACKGROUND

3. On December 3, 2012, Debtors Revstone Industries, LLC and Spara, LLC

commenced their cases by filing voluntary petitions for relief under chapter 11 of the Bankruptcy

Code. On January 7, 2013, Debtors Greenwood Forgings, LLC and US Tool and Engineering,

LLC commenced their cases by filing voluntary petitions for relief under chapter 11 of the

Bankruptcy Code. The Debtors have continued in the possession of their property and have

continued to operate and manage their business as debtors in possession pursuant to sections

1107(a) and 1108 of the Bankruptcy Code.

4. Pursuant to the Order Authorizing Joint Administration of Related Chapter

11 Cases for Procedural Purposes Only (Docket No. 173) (the "Existing Joint Administration

Order"), the chapter 11 cases of Revstone Industries, LLC, Spara, LLC, Greenwood Forgings,

LLC and US Tool and Engineering, LLC (the "Original Debtors") are jointly administered and

are consolidated for procedural purposes.

5. On December 18, 2012, the United States Trustee appointed an Official

Committee of Unsecured Creditors (the "Committee") in the case of Revstone Industries, LLC.

No committee has been appointed in the cases of Spara, LLC Greenwood Forgings, LLC and US

Tool and Engineering, LLC. No trustee or examiner has been appointed in any of the Original

Debtors’ chapter 11 cases.

D005_DE: 187562.4 73864/002


6. On the date hereof (the "Metavation Petition Date"), Metavation filed a

voluntary petition in the Court for relief under chapter 11 of the Bankruptcy Code. Metavation

continues to operate its business and manage its properties as a debtor in possession pursuant to

sections 1107 and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in

Metavation’s chapter 11 case. As of the date hereof, no creditors’ committee has been appointed

in the Metavation chapter 11 case.

7. The factual background relating to the commencement of the chapter 11

case of Revstone Industries, LLC is set forth in detail in the Declaration of Jay N. Brown in

Support of First Day Pleadings (the "Brown Declaration") filed on December 3, 2012, and

incorporated herein by reference. The factual background relating to the commencement of the

chapter 11 case of Metavation, LLC is set forth in detail in the Declaration of John C. DiDonato

in Support of Metavation, LLC Petition and First Day Motions (the "DiDonato Declaration")

filed concurrently herewith and incorporated herein by reference.

8. Metavation, LLC (the "Company") is a Michigan-based manufacturer of

precision machined components and assemblies, including dampers, engine components,

knuckles, and driveline products for the automotive industry. Metavation specializes in designing

and manufacturing dampers that are included on original equipment manufacturers’ ("OEMs")

engine platforms. The Company also has rapid development capabilities to produce "solution"

dampers to correct driveline and powertrain noise vibration and harshness ("NVH") issues. The

Company serves many of the largest automotive customers, suppliers, and platforms. The

Company’s major OEM customers include General Motors and Chrysler. Metavation’s Tier I

D005_DE: 187562.4 73864/002


supplier customers include American Axle, Dana Automotive, and J.G. Kern. These long-

standing relationships have led the Company to a dominant market position in the U.S.

crankshaft damper market. Metavation operates from four, modernized facilities located in

central Michigan. The Company begins its manufacturing process by developing the rubber

component at the Hillsdale, MI facility, and then sends the rubber component to Mt. Pleasant, MI

or Vassar, MI facility for machining and/or assembly.

Relief Requested

9. By this Motion, the Debtor seeks authority (but not direction) to make

the payments required to continue its Insurance Program (as defined below), including (i)

payment of any prepetition premium, in whole or in part, or other obligations under the policies

listed on Exhibit A to the extent the Debtor determines, in its discretion, that such payments

are necessary to avoid cancellation, default, alteration, assignment, attachment, lapse, or any

form of impairment to the coverage, benefits, proceeds, or other rights or interests provided

under the Policies, and (ii) p a y m e n t of any fee owed to the Broker necessary to

continue the administration of the Insurance Programs.

The Debtor’s Insurance Programs

10. In the ordinary course of its business and as part of its affiliation as a

subsidiary of Ascalon, the Debtor maintains and participates in a carefully designed insurance

program (the "Insurance Program"). This program includes eleven insurance policies that were

in effect as of the Petition Date, providing millions in dollars of coverage, including, but not

limited to, policies covering general liability, umbrella coverage, workers’ compensation,

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executive risk management, employed lawyers professional liability, and directors’ and officers’

liability (collectively, the "Policies"). These Policies are provided by several different insurance

carriers (the "Carriers"). Attached hereto as Exhibit A and incorporated herein by reference is a

comprehensive list of the Policies identified by the Debtor to date by type of coverage, Policy

number, identity of Carriers, total premium for each Policy, and other salient information.

11. The Debtor, the Original Debtors and certain non-debtor affiliates are

responsible for approximately $4,656,712 per year in aggregate premiums and related fees to

maintain the Insurance Program. The Debtor’s annual portion of the aggregate premiums and

related fees is approximately $1,444,436.72. These Policies provide insurance coverage for the

Debtor, Original Debtors and certain non-debtor affiliates. Fifteen percent of the premiums are

paid in the first month of the year followed by nine equal monthly installments. The

continuation of these policies is both necessary and critical to the Debtor’s ability to operate

its business.

12. The Debtor, Original Debtors and non-debtor affiliates use Todd

Associates, Inc. (the "Broker") to procure and coordinate their insurance coverage. The

Broker’s services are critical to maintaining and renewing the various component policies

within the Insurance Program. As part of its services, the Broker handles all administrative

tasks involved with the routing and payment of premiums to the Carriers. Payment of the

premiums to the Broker is allocated among the Debtor, Original Debtors and non-debtor

affiliates, and any payments made by the Debtor, Original Debtors and non-debtor affiliates

on behalf of another affiliate create an intercompany obligation between such affiliates. The

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Broker’s fee is directly subsumed in the billings for premiums it provides to the Debtor,

Original Debtors and non-debtor affiliates.

13. By obtaining the required insurance coverage for itself, the Original

Debtors and non-debtor affiliates on a combined basis, the Debtor has been able to realize

substantial savings and efficiencies in the cost of its Insurance Program generally. The Debtor

submits that it would not be feasible to separate out its operations and other insurance needs

from those of the Original Debtors and non-debtor affiliates and obtain replacement insurance

coverage at a reasonable cost or within a reasonable time frame without exposing the Debtor

to significant risk of disruption and increased expense.

14. Furthermore, in many cases, the coverage provided by the Policies is

required by various regulations, laws and contracts that govern the Debtor’s business under

applicable non-bankruptcy law. Likewise, the U.S. Trustee Guidelines require the Debtor to

maintain adequate insurance coverage. Such coverage could not be provided without

continuation of the Insurance Program.

Basis for Relief Requested

15. This Court has authority to grant the relief requested herein pursuant to

Sections 105(a) and 363(b) of the Bankruptcy Code. Section 363(b)(1) of the Bankruptcy

Code provides that "[t]he trustee, after notice and a hearing, may use, sell, or lease, other

than in the ordinary course of business, property of the estate." 11 U.S.C. § 363(b)(1).

Moreover, Section 105(a) of the Bankruptcy Code allows the Court to authorize payments

on account of certain prepetition claims when necessary. Section 105(a) of the Bankruptcy

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Code provides, in relevant part, that "[t]he court may issue any order, process, or judgment

that is necessary or appropriate to carry out the provisions of [the Bankruptcy Code].!? 11

U.S.C. § 105(a). This is generally referred to as the "necessity of payment rule" or the

"doctrine of necessity." See In re NVR, L.P., 147 B.R. 126, 128 (Bankr. E.D. Va. 1992); In re

Ionosphere Clubs, Inc., 98 B.R. 174, 177 (Bankr. S.D.N.Y. 1989), accord In re Financial

News Network, Inc., 134 B.R. 732, 736 (Bankr. S.D.N.Y. 1991) (prepetition claims may be

paid when so doing is "critical to the debtor’s reorganization"); In re Eagle-Pitcher Indus., 124

B.R. 1021, 1023 (Bankr. S.D. Ohio 1991) (payment must be "necessary to avert a serious

threat to the Chapter 11 process"); In re Structurlite Plastics Corp., 86 B.R. 922, 931

(Bankr. S.D. Ohio 1988) (noting that payment is necessary to "permit the greatest likelihood

of survival of the debtor and payment of creditors in full or at least proportionately" (quoting In

re Chateaugay Corp., 80 B.R. 279, 287 (S.D.N.Y.1987)).

16. Courts have recognized that the "necessity of payment rule" is "well-

established in bankruptcy common law." In re NVR L.P., 147 B.R. 126, 127 (Bankr. B. D.

Va. 1992); id. (stating that, under Section 105(a), a court "can permit pre-plan payment of a

pre-petition obligation when essential to the continued operation of the debtor"); see also In re

Ionosphere Clubs, Inc., 98 B.R. 174,175 (Bankr. S.D.N.Y. 1989) (stating that a bankruptcy

court’s use of its equitable powers to "authorize the payment of pre-petition debt when such

payment is needed to facilitate the rehabilitation of the debtor is not a novel concept" (citing

NLRB v. Bildisco & Bildisco, 465 U.S. 513, 528 (1984)). For the rule to apply, the payment

must be in the best interests of the debtor and its other creditors. See In re UNR Indus., Inc.,

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143 B.R. 506, 520 (Bankr. N.D. Iii. 1992); see also Eisenberg & Gecker, The Doctrine of

Necessity and Its Parameters, 73 Marq. L. Rev. 1, 20 (1989).

17. For the reasons described above, and in view of the Debtor’s need to

maintain insurance to operate its businesses, authorizing the Debtor to maintain the Insurance

Program, and making the payments required by the Policies, is in the best interests of all parties

in interest in this Chapter 11 case. Thus, the Debtor respectfully requests that it be provided

with the authority (but not direction) to fully retain in place its existing Insurance Program and

honor the obligations described herein.

18. The Debtor also seeks the authority (but not direction) to renew

Policies or to enter into new insurance arrangements as may be required as the terms of

existing Policies and arrangements expire, in the ordinary course of business, without further

order of the Court. It is essential to the continued operation of the Debtor’s businesses and its

efforts to successfully reorganize that the Insurance Program be maintained on an ongoing and

uninterrupted basis.

19. Bankruptcy courts adjudicating other Chapter 11 cases, including in this

district, have held that a debtor is authorized to maintain prepetition insurance programs

pursuant to Sections 363(b) and 105(a) of the Bankruptcy Code where, as here, a sound business

justification exists. See, e.g., In re Appleseed’s Intermediate Holdings LLC, No. 11-10160 (KG)

(Bankr. D. Del. Feb. 23, 2011); In re Atrium Corp., No. 10-10150 (BLS) (Bankr. D. Del. Feb 23,

2010); In re Champion Enterprises, Inc., et al., Case No. 09-14019 (KG), 2012 WL 111306

(Bankr. D. Del., Nov. 17 2009); In re Sea Launch Company, L.L.C., et al., Case No. 09-12153

DOCS_DE: 187562.4 73864/002


(BLS), 2009 WL 84738332 (Bankr. D. Del., June 25, 2009). Given the nature of the

Debtor’s various coverage requirements, the Debtor submit that similar relief is appropriate in

this Chapter 11 case.

20. If the Court grants the relief sought in this Motion, the Debtor requests

that all applicable banks and other financial institutions be authorized, when requested by the

Debtor in its discretion, to receive, process, honor, and pay any and all checks drawn on the

Debtor’s accounts to pay amounts owed under the Insurance Program, whether those checks are

presented prior to or after the Petition Date, and to make other transfers.

21. The Debtor requests that authorization of the payment of the various

premiums hereunder not be deemed to constitute the postpetition assumption of any

executory contract pursuant to Section 365 of the Bankruptcy Code. The Debtor is in the

process of reviewing these matters and reserves all of its rights under the Bankruptcy Code with

respect thereto. Moreover, authorization to pay should not affect the Debtor’s right to contest

the amount or validity of any such charges, in whole or in part. Based on the foregoing, the

Debtor submits that the relief requested is necessary and appropriate, in the best interests of its

estate and creditors, and should be granted in all respects.

Satisfaction of Bankruptcy Rule 6003

22. The Debtor believes that it is entitled to immediate authorization for the

relief contemplated by this Motion. Pursuant to Rule 6003 of the Federal Rules of Bankruptcy

Procedure (the "Bankruptcy Rules"), "[e]xcept to the extent that relief is necessary to avoid

immediate and irreparable harm, the court shall not, within 21 days after the filing of the petition,

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grant relief regarding the following: . . . (b) a motion to use, sell, lease, or otherwise incur an

obligation regarding property of the estate, including a motion to pay all or part of a claim that

arose before the filing of the petition, but not a motion under Rule 4001." To the extent that the

requirements of Bankruptcy Rule 6003 are applicable to the relief requested in the Motion, the

Debtor submits that for the reasons already set forth herein, the relief requested in this Motion is

necessary to avoid immediate and irreparable harm. Specifically, the continuation of the

Insurance Program is both necessary and critical to the Debtor’s ability to operate its business.

Accordingly, the relief requested herein is appropriate under the circumstances and under

Bankruptcy Rule 6003.

Waiver of Bankruptcy Rule 6004

23. The Debtor seeks a waiver of any stay of the effectiveness of the order

approving this Motion. Pursuant to Rule 6004(h) of the Bankruptcy Rules, "[a]n order

authorizing the use, sale or lease of property other than cash collateral is stayed until the

expiration of 14 days after entry of the order, unless the court orders otherwise." As set forth in

the Motion, the continuation of the Insurance Program is both necessary and critical to the

Debtor’s ability to operate its business. Accordingly, the Debtor submits that ample cause

exists to justify a waiver of the fourteen (14) day stay imposed by Bankruptcy Rule 6004(h), to

the extent that it applies.

Notice

24. Notice of this Motion has been given to the following or, in lieu thereof, to

their counsel, if known: (i) the Office of the United States Trustee; (ii) the Debtor’s prepetition

DOCS_DE: 187562.4 73864/002


and postpetition secured lenders; (iii) the Pension Benefit Guaranty Corporation; (iv) the

Debtor’s major OEM customers: General Motors, Chrysler, and Ford; (v) Dayco Products, LLC

and Dayco Products S.A. de C.V., the stalking horse purchaser for the Debtor’s assets; and (vi)

the Official Committee of Unsecured Creditors in the case of Revstone Industries, LLC. As the

Motion is seeking "first day" relief, within two business days of the hearing on the Motion, the

Debtor will serve copies of the Motion and any order entered respecting the Motion as required

by Del. Bankr. LR 9013-1(m). The Debtor submits that, in light of the nature of the relief

requested, no other or further notice need be given.

No Prior Request

25. No previous request for the relief sought herein has been made to this or

any other Court.

DOCS_DE: 187562.4 73864/002


WHEREFORE, the Debtor respectfully requests that the Court grant the relief

requested herein, and grant such other further relief as the Court deems appropriate.

Dated: Juiy8, 2013 PAC$UtXTNG ZIEHL & JONES LLP

aura Day~’Jones (Bar No. 2436) David M. Bertenthal (CA Bar No. 167624) Timothy P. Cairns (Bar No. 4228) Cohn R. Robinson (Bar No. 5524) 919 N. Market Street, 17th Floor Wilmington, DE 19801 Telephone: 302/652-4100 Facsimile: 302/652-4400 Email: ljonespszjlaw.com

[email protected] [email protected] [email protected]

[Proposed] Counsel for the Debtor and Debtor-in-Possession

D005_DE: 187562.4 73864/002


EXHIBIT A

DOCS_DE: 187562.4 73864/002


12/29/12 - 12/29/13 USA

12/29/12 - 12/29/13 USA

Occurrence Form

re: Auto Liability

re: Auto Physical Damage

12/29/12 - 12/29/13 USA

TYPE OF COVERAGE

Master Property, BI & Boiler Policy

Summary of In-Force Insurance Policies for METAVATION, LLC

CARRIER POLICY TERM COVERAGE

Terms TERRITORY

Starr Technical Risk 12/29/12 - 12/29/13 Worldwide Special form Agency (1)/ACE American including Flood & EQ

Annual Allocated

Premium Premium

$ 687,820.00 $ 125,071.95

12/29/12 - 12/29/13 Worldwide Occurrence Form

Master General Liability Policy

Master Fleet Auto Policy

(Auto Liability/Physical Damage)

Master Workers Compensation and

Employers Liability Policy

Global Difference in Conditions/Limits

Travelers (2)

Travelers (2)

Travelers Indemnity (3)

Travelers (2)

$ 285,964.00 $ 60,177.00

$ 52,831.00 $ 4,812.00

$ 2,941,169.00 $ 771,624.00

$ 41,965.00 $ 9,246.00

Umbrella Liability Travelers (2) 12/29/12 - 12/29/13 Worldwide $ 257,232.00 $ 54,131.00

Executive Risk Management Liability Federal Insurance (4) 12/29/11 - 12/29/13 Worldwide Claims Made Form $ 219,776.00 $ 51,084.82 Excess Directors & Officers Torus Specialty (5) 04/20/12 - 12/29/13 Worldwide Claims Made Form 116.013.60 $ 27,704.31 Independent Directors Liability (IDL) AmTrust (6) 02/15/13 - 12/29/13 Worldwide Claims Made Form $ 61,550.00 $ 14,698.28 Excess IDL Lloyd’s (7) 03/06/13 - 12/29/13 Worldwide Claims Made Form $ 102,550.00 $ 24,489.17 Employed Lawyers Professional Federal Insurance (4) 02/17/12 - 12/29/13 Worldwide Claims Made Form $ 5,855.00 $ 1,398.19

$ 4,656,712.00 $ 1,144,436.72 CARRIER MAILING ADDRESSES:

(1) ACE American Insurance Company, c/o Starr Technical Risks Agency, Inc., 500 West Monroe Street, Suite 2600, Chicago IL 60661 (2) Travelers Property Casualty Company of America, One Tower Square, Hartford CT 06183 (3) Travelers Indemnity Company, One Tower Square, Hartford CT 06183 (4) Federal Insurance Company (Chubb), 15 Mountain View Road, Warren NJ 07059 (5) Torus Specialty Insurance Company, Harborside Financial Center, Plaza 5, Suite 2600, Jersey City NJ 07311 (6) AmTrust International Underwriters, Ltd, 40 Westland Row, Dublin 2, Ireland (7) Lloyd’s Syndicate #1919, c/o S H Smith & Company, Inc., 20 Church Street, Suite 1500, Hartford CI 06103




In re:

REVSTONE INDUSTRIES, LLC, et al.,’

Debtors

In re:

METAVATION, LLC,

Debtor.

Chapter 11

Case No. 12-13262 (BLS)

(Jointly Administered)

Chapter 11

Case No. 13-11831 (BLS)

(Joint Administration Requested)

ORDER GRANTING MOTION OF DEBTOR FOR ORDER AUTHORIZING DEBTOR TO CONTINUE ITS INSURANCE PROGRAM

Upon the motion ("the Motion")’ of the above-captioned debtor and debtor in

possession (the "Debtor") for an order pursuant to Sections 105(a), 363 of title 11 of the

United States Code (the "Bankruptcy Code"), authorizing the Debtor to (i) continue its

prepetition Insurance Program, and (ii) pay any prepetition premiums and related obligations;

and the Court having reviewed the Motion and the DiDonato Declaration; and the Court having

determined that the relief requested in the Motion is in the best interests of the Debtor, its

estate, its creditors, and other parties in interest; and it appearing that proper and adequate notice

of the Motion has been given and that no other or further notice is necessary; and upon the

record herein; and after due deliberation thereon; and good and sufficient cause appearing

therefor,

The Debtors in these Chapter 11 Cases and the last four digits of each Debtor’s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors’ headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505. 2 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Motion.

DOCSDE; 187562.4 73864/002


IT IS HEREBY ORDERED THAT:

The Motion is GRANTED as set forth herein.

2. The Debtor is hereby: (i) authorized to maintain its Insurance Program in

accordance with its prepetition practice, (ii) authorized, but not required, to pay the fee, if

any, owed to the Broker necessary to continue the administration of the Insurance Program,

(iii) authorized, but not required, to pay any insurance premium obligations or Broker’s fee

that may have been due before the commencement of the Chapter 11 Case, and (iv) authorized,

but not required, to renew Policies or to enter into new insurance arrangements as may be

required as the terms of existing Policies and arrangements expire, in the ordinary course of

business, without further order of the Court, provided, however, that any fee or payment

authorized, but not required, pursuant to this Order, shall be made in accordance with and subject

to the provisions of any approved postpetition financing order and related budget.

3. Any payment made by the Debtor pursuant to this Order is not, and shall

not be deemed, an admission as to the validity of the underlying obligations, a waiver of any

rights the Debtor may have to subsequently dispute such obligations, or an assumption of any

agreements, contracts or leases under Section 365 of the Bankruptcy Code.

4. Nothing in this Order is intended or shall be construed to constitute relief

from the automatic stay under Section 362 of the Bankruptcy Code.

5. The requirements set forth in Bankruptcy Rule 6003(b) are satisfied by

the Motion or otherwise deemed waived.

D005_DE: 187562.4 73864/002


6. To the extent the fourteen-day stay of Bankruptcy Rule 6004(h) may be

construed to apply to the subject matter of this Order, such stay is hereby waived.

7. The Debtor is hereby authorized to take such actions and to execute

such documents as may be necessary to implement the relief granted by this Order. This

Order, and all acts taken in furtherance of or reliance upon this Order, shall be effective

notwithstanding the filing of an objection, pending the entry of a final order by this Court.

8. That this Court shall retain jurisdiction to hear and determine all matters

arising from the implementation of this Order.

Dated: .2013

THE HONORABLE BRENDAN L. SHANNON UNITED STATES BANKRUPTCY JUDGE

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Exhibit 2

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Case 13-11831-BLS Doc 47 Filed 07/24/13 Page 1 of 3



In re:

REVSTONB INDUSTRIES, LLC, et al.,’ ) )

Debtors. ) )

In re: ) )

METAVATION, LLC, )

Debtor.

Chapter 11


Related to Docket No. 792

Chapter II


Related to Docket No. 15

ORDER GRANTING MOTION OF DEBTOR FOR ORDER AUTHORIZING DEBTOR TO CONTINUE ITS INSURANCE PROGRAM

Upon the motion ("the Motion")’ of the above-captioned debtor and debtor in

possession (the "Debtor") for an order pursuant to Sections 105(a), 363 of title 11 of the

United States Code (the "Bankruptcy Code"), authorizing the Debtor to (i) continue its

prepetition Insurance Program, and (ii) pay any prepetition premiums and related obligations;

and the Court having reviewed the Motion and the DiDonato Declaration; and the Court having

determined that the relief requested in the Motion is in the best interests of the Debtor, its

estate, its creditors, and other parties in interest; and it appearing that proper and adequate notice

of the Motion has been given and that no other or further notice is necessary; and upon the

record herein; and after due deliberation thereon; and good and sufficient cause appearing

The Debtors in these Chapter 11 Cases and the last four digits of each Debtor’s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool & Engineering, LLC (6450). The location of the Debtors’ headquarters and the service address for each of the Debtors is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505. 2 Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Motion. i

DATE

DOCKET # 1_I -’7 /IL DOCSDE:1 87562.6 73864/002


Case 13-11831-BLS Doc 47 Filed 07/24/13 Page 2 of 3

therefor,

IT IS HEREBY ORDERED THAT:

I. The Motion is GRANTED as set forth herein.

2. The Debtor is hereby: (i) authorized to maintain its Insurance Program in

accordance with its prepetition practice, (ii) authorized, but not required, to pay the fee, if

any, owed to the Broker necessary to continue the administration of the Insurance Program,

(iii) authorized, but not required, to pay any insurance premium obligations or Broker’s fee

that may have been due before the commencement of the Chapter 11 Case, and (iv) authorized,

but not required, to renew Policies or to enter into new insurance arrangements as may be

required as the terms of existing Policies and arrangements expire, in the ordinary course of

business, without further order of the Court, provided, however, that any fee or payment

authorized, but not required, pursuant to this Order, shall be made in accordance with and subject

to the provisions of any approved postpetition financing order and related budget.

3. Payments made pursuant to this order for prepetition obligations related to

the Insurance Program shall not exceed $25,000.

4. Any payment made by the Debtor pursuant to this Order is not, and shall

not be deemed, an admission as to the validity of the underlying obligations, a waiver of any

rights the Debtor may have to subsequently dispute such obligations, or an assumption of any

agreements, contracts or leases under Section 365 of the Bankruptcy Code.

5. Nothing in this Order is intended or shall be construed to constitute relief

from the automatic stay under Section 362 of the Bankruptcy Code.

DQCS_DE:18 7562.6 73864/002


Case 13-11831-BLS Doc 47 Filed 07124113 Page 3 of 3

6. The requirements set forth in Bankruptcy Rule 6003(b) are satisfied by

the Motion or otherwise deemed waived.

7. To the extent the fourteen-day stay of Bankruptcy Rule 6004(h) may be

construed to apply to the subject matter of this Order, such stay is hereby waived.

8. The Debtor is hereby authorized to take such actions and to execute

such documents as may be necessary to implement the relief granted by this Order. This

Order, and all acts taken in furtherance of or reliance upon this Order, shall be effective

notwithstanding the filing of an objection, pending the entry of a final order by this Court.

9. That this Court shall retain jurisdiction to hear and determine all matters

arising from the implementation of this Order.

Dated: , 2013

THE

SHANNON UNITED STATES BANKRUPTCY JUDGE

DOCSDE: 1 87562.6 73864/002




In re:

REVSTONE INDUSTRIES, LLC, et al., 1

Debtors.

In re:

METAVATION, LLC,

Debtor.

Chapter 11


Chapter 11


CERTIFICATE OF SERVICE

I, Cohn R. Robinson, hereby certify that on the 31St day of July, 2013, I caused a

copy of the following document(s) to be served on the individuals on the attached service list(s),

in the manner indicated thereon:

Notice of First Day Motion and Entry of Order Regarding Motion for Authorization to (I) Continue Prepetition Insurance Program and (II) Pay Any Prepetition Premiums and Related Obligations [including Exhibits 1 and 2 thereto]

Al Cohn R. Robinson Cohn R. Robinson (Bar No. 5524)

The Debtor in these Chapter 11 Cases and the last four digits of each Debtor’s federal tax identification numbers are: Revstone Industries, LLC (7222); Spara, LLC (6613); Greenwood Forgings, LLC (9285); and US Tool and Engineering, LLC (6450). The location of the Debtor’ headquarters and the service address for each of the Debtor is 2250 Thunderstick Dr., Suite 1203, Lexington, KY 40505.

DOCS_DE: 188759.1 73864/002


Metavation Insurance Policies Service List Case No. 13-11831 (BLS) Document No. 188754 06 - First Class Mail 01 - Foreign First Class Mail

First Class Mail ACE American Insurance Company do Starr Technical Risks Agency, Inc. 500 West Monroe Street, Suite 2600 Chicago IL 60661

First Class Mail Travelers Property Casualty Company of America One Tower Square Hartford CT 06183

First Class Mail Travelers Indemnity Company One Tower Square Hartford CT 06183

First Class Mail Federal Insurance Company (Chubb) 15 Mountain View Road Warren NJ 07059

First Class Mail Torus Specialty Insurance Company Harborside Financial Center Plaza 5, Suite 2600 Jersey City NJ 07311

First Class Mail Lloyd’s Syndicate #1919 do S H Smith & Company, Inc. 20 Church Street, Suite 1500 Hartford CT 06103

FOREIGN First Class Mail AmTrust International Underwriters, Ltd 40 Westland Row Dublin 2, Ireland

DOCS_DE:188754.1 73864/002


Metavation 2002 Service List (First Class) Lead Case No. 12-13262 Document No. 188621 02� INTEROFFICE MAIL 07� HAND DELIVERY 34� FIRST CLASS MAIL 01� FOREIGN FIRST CLASS

(Counsel to Debtor and Debtor in Possession) Laura Davis Jones, Esquire Timothy P. Cairns, Esquire Cohn R. Robinson, Esquire Pachulski Stang Ziehl & Jones, LLP 919 N. Market Street, 17th Floor Wilmington, DE 19801

INTEROFFICE MAIL (Counsel to Debtor and Debtor in Possession) Jonathan J. Kim, Esquire Pachulski Stang Ziehi & Jones, LLP 10100 Santa Monica Boulevard, 13th Floor Los Angeles, CA 90067

INTEROFFICE MAIL (Counsel to Debtor and Debtor in Possession) David M. Bertenthal, Esquire Pachulski Stang Ziehi & Jones, LLP 150 California Street, 15th Floor San Francisco, CA 94111

HAND DELIVERY (United States Trustee) Jane M. Leamy, Esquire Office of the United States Trustee J. Caleb Boggs Federal Building 844 King Street, Suite 2207 Wilmington, DE 19801

HAND DELIVERY Zilllah A. Frampton, Bankruptcy Administrator Delaware Division of Revenue 820 N. French St. CSOB 8th Floor Wilmington, DE 19801

HAND DELIVERY (United States Attorney) Ellen W. Slights, Esquire United States Attorney’s Office District of Delaware 1007 N. Orange Street, Suite 700 Wilmington, DE 19801

HAND DELIVERY (Counsel to Official Committee of Unsecured Creditors) Matthew P. Ward, Esquire Steven K. Kortanek, Esquire Mark L. Desgrosseilliers, Esquire Womble Carlyle Sandridge & Rice, LLP 222 Delaware Avenue, Suite 1501 Wilmington, DE 19801

HAND DELIVERY (Counsel to Ford Motor Company) Karen C. Bifferato, Esquire Connolly Gallgaher LLP 1000 West Street, Suite 1400 Wilmington, DE 19801

HAND DELIVERY (Counsel to Dayco Products, LLC) Anthony W. Clark, Esquire Skadden Arps, Slate, Meagher & Flom LLP & Affiliates One Rodney Square P.O. Box 636 Wilmington, DE 19899


HAND DELIVERY (Counsel to Wells Fargo Capital Finance, LLC) David M. Powlen, Esquire Kevin G. Collins, Esquire Barnes & Thornburg LLP 1000 N. West Street, Suite 1500 Wilmington, DE 19801

FIRST CLASS MAIL (United Stated Attorney General) Eric H. Holder, Jr., Esquire Office of the US Attorney General U.S. Department of Justice 950 Pennsylvania Avenue, N.W. Washington, DC 20530

FIRST CLASS MAIL Secretary of State Division of Corporations Franchise Tax

P.O. Box 898 Dover, DE 19903

FIRST CLASS MAIL Delaware Secretary of Treasury 820 Silver Lake Blvd., Suite 100 Dover, DE 19904

FIRST CLASS MAIL Office of General Counsel U.S. Department of the Treasury 1500 Pennsylvania Avenue, N.W. Washington, DC 20220

FIRST CLASS MAIL Michael A. Berman, Esq Securities & Exchange Commission Office of General Counsel-Bankruptcy 100 F. Street, NE Washington, DC 20549

FIRST CLASS MAIL Andrew Calamari, Regional Director New York Regional Office Securities & Exchange Commission 3 World Financial Center, Suite 400 New York, NY 10281

FIRST CLASS MAIL Internal Revenue Service Centralized Insolvency Operation P.O. Box 7346 2970 Market Street Mail Stop 5-030.133 Philadelphia, PA 19101

FIRST CLASS MAIL Sean Lev, Esquire Office of General Counsel Federal Communications Commission 445 12th Street, S.W. Washington, DC 20005

FIRST CLASS MAIL Cassandra B. Caverly, Esquire Desiree Amador, Esquire Pension Benefit Guaranty Corporation Office of the Chief Counsel 1200 K. Street, N.W. Washington, DC 20005

FIRST CLASS MAIL (Counsel to General Motors LLC) Aaron M. Silver, Esquire Honigman Miller Schwartz and Cohn LLP 2290 First National Building 660 Woodward Avenue, Suite 2290 Detroit, MI 48226

FIRST CLASS MAIL (Counsel to Chrysler Group LLC) Sheryl L. Toby, Esquire Dykema Gossett PLLC 39577 Woodward Ave., Suite 300 Bloomfield Hills, MI 48304


FIRST CLASS MAIL FIRST CLASS MAIL (Counsel to Dayco Products, LLC and (Top 20) Dayco Products S.A. de C. V., the stalking NETL1NK horse purchaser for the Debtor’s assets) Attn: Amarish Kapadia J. Eric Ivester, Esquire 999 Tech Row Skadden Arps, Slate, Meagher & Flom LLP Madison Heights, MI 48071 & Affiliates 4 Times Square FIRST CLASS MAIL New York, NY 10036 (Top 20)

Osco Industries, Inc. FIRST CLASS MAIL Attn: Tom Kayser (Counsel to Dayco Products, LLC and 11th & Chillicothe Street Dayco Products S.A. de C. V., the stalking P0 Box 1388 horse purchaser for the Debtor’s assets) Portsmouth, OH 45662 Christopher M. Dressel, Esquire Skadden Arps, Slate, Meagher & Flom LLP FIRST CLASS MAIL & Affiliates (Top 20) 155 N. Wacker Drive Automated Logistics System Chicago, IL 60606 Attn: Joe Parker

3517 Scheele Drive FIRST CLASS MAIL Jackson, MI 49202 (Counsel to Wells Fargo Capital Finance) Jonathan N. Helfat, Esquire FIRST CLASS MAIL Otterbourg, Steindler, Houston & Rosen, (Top 20) P.C. Dauber Company, Inc. 230 Park Avenue do Ronald B. Rich New York, NY 10169 30655 Nothwestern Hwy.

Farmington Hills, MI 48334 FIRST CLASS MAIL (Counsel to Ford Motor Company) FIRST CLASS MAIL Stephen S. LaPlante, Esquire and Jonathan (Top 20) S. Green, Esquire Tonawanda Coke Corp. Miller Canfield Attn: Colleen Crane 150 West Jefferson, Suite 2500 P.O. Box 5007 Detroit, MI 48226 Tonawanda, NY 14151-5007

FIRST CLASS MAIL FIRST CLASS MAIL (Top 20) (Top 20) Loeb Lorman Metals City of Mt. Pleasant Attn: Bruce Loch Attn: Nancy Ridley 1111 S. 10th Street 320 West Broadway Watertown, WI 53094 Mt. Pleasant, MI 48858


FIRST CLASS MAIL (Top 20) Trostel Attn: Larry Brown 901 Maxwell Street Lake Geneva, WI 53147

FIRST CLASS MAIL (Top 20) Central Michigan Staffing Attn: Account Manager (Metavation) 605 N. Mission Street Mt. Pleasant, MI 48858

FIRST CLASS MAIL (Top 20) City of Vassar Attn: City Council 287 E. Huron Vassar, MI 48768

FIRST CLASS MAIL (Top 20) Internal Revenue Service Centralized Insolvency Operation P.O. Box 7346 Philadelphia, PA 19101-7346

FIRST CLASS MAIL (Top 20) A&B Machine Inc. Attn: Accounts Receivable Manager 2040 Commerce Drive Sidney, OH 45365

FIRST CLASS MAIL (Top 20) County of Tuscola Attn: Treasurer 440 N. State Street Caro, MI 48723

FIRST CLASS MAIL (Top 20) Fortech Products, Inc. Attn: Accounts Receivable Manager 7600 Kensington Ct. Brighton, MI 48116

FIRST CLASS MAIL (Top 20) Peoplelink, LLC Attn: Account Manager (Metavation) 431 E Colfax Ave, Suite 200 South Bend, IN 46617

FIRST CLASS MAIL (Top 20) Chainworks, Inc. Attn: Accounts Receivable Manager 1031 S MAIN ST Plymouth, MI 48170

FIRST CLASS MAIL (Top 20) WGS Global Services LC Attn: Accounts Receivable Manager 6401 Taylor Drive Flint, MI 48507

FIRST CLASS MAIL (Top 20) Standard Electric Attn: Accounts Receivable Manager 2650 Trautner Dr Saginaw, MI 48603

FIRST CLASS MAIL (Top 20) ManpowerGroup Attn: Melissa J. Koch 100 Manpower Place Milwaukee, WI 53212


FOREIGN FIRST CLASS (Top 20) TFT Global Inc. Attn: Legal Dept. 35 Spruce St. Tillsonburg, ON N4G 5C4 CANADA


Revstone Consolidated 2002 Service List (First Class) Lead Case No. 12-13262 Document No. 185822 01� INTEROFFICE MAIL 01� VIA EMAIL 14� HAND DELIVERY 33� FIRST CLASS MAIL

Laura Davis Jones, Esquire Timothy P. Cairns, Esquire Pachuiski Stang Ziehi & Jones, LLP 919 North Market Street, 17th Floor P.O. Box 8705 Wilmington, DE 19899-8705

INTEROFFICE MAIL David M. Bertenthal, Esquire Pachuiski Stang Ziehl & Jones, LLP 150 California Street, 15th Floor San Francisco, CA 94111

VIA EMAIL (Counsel to George S. Hofineister) Sheldon S. Toll, Esquire Sheldon S. Toll PLLC Email: [email protected]

HAND DELIVERY Jane Leamy, Esquire Office of the United States Trustee 844 King Street, Suite 2207 Lockbox 35 Wilmington, DE 19801

HAND DELIVERY (Counsel to Ford Motor Company) Karen C. Bifferato, Esquire Connolly Gallgaher LLP 1000 West Street, Suite 1400 Wilmington, DE 19801

HAND DELIVERY (Counsel to Airgas, Inc. and related Airgas Entities) Kathleen M. Miller, Esquire Smith, Katzenstein & Jenkins LLP The Corporate Plaza 800 Delaware Avenue, Suite 1000 P. 0. Box 410 Wilmington, DE 19899

HAND DELIVERY (Counsel to Boston Financial Group) Stuart M. Brown, Esquire R. Craig Martin, Esquire DLA Piper LLP (US) 919 N. Market Street, 15th Floor Wilmington, DE 19801

HAND DELIVERY (Counsel to Schoeller Area Systems, Inc.) Carl N. Kunz, III, Esquire Morris James LLP 500 Delaware Avenue, Suite 1500 P. 0. Box 2306 Wilmington, DE 19801

HAND DELIVERY (Counsel to United Steelworkers) Susan E. Kaufman, Esquire Cooch and Taylor, P.A. 1000 West Street, 10th Floor P. 0. Box 1680 Wilmington, DE 19801

HAND DELIVERY (Counsel to Official Committee of Unsecured Creditors) Matthew P. Ward, Esquire Steven K. Kortanek, Esquire Mark L. Degrosseilliers, Esquire Womble Carlyle Sandridge & Rice, LLP 222 Delaware Avenue, Suite 1501 Wilmington, DE 19801


HAND DELIVERY (Counsel to George S. Hothieister) Evan 0. Williford, Esquire The Williford Firm LLC 901 N. Market Street, Suite 800 Wilmington, DE 19801

HAND DELIVERY (Counsel to Bridgeport Capital Funding LLC) Patrick J. Reilly, Esquire Cole, Schotz, Meisel, Forman & Leonard, P.A. 500 Delaware Avenue, Suite 1400 Wilmington, DE 19801

HAND DELIVERY (Counsel to GE CF Mexico of S.A. de C. V.) Kurt F. Gwynne, Esquire and Lucy Qiu, Esquire Reed Smith LLP 1201 N. Market Street, Suite 1500 Wilmington, DE 19801

HAND DELIVERY (Counsel to Hillsdale Salaried Pension Plan and Hillsdale Hourly Pension Plan) Joel A. Waite, Esquire, Kenneth J. Enos, Esquire Young Conaway Stargatt & Taylor LLP Rodney Square 1000 North King Street Wilmington, DE 19801

HAND DELIVERY (Counsel to Cole Taylor Bank) Victoria A. Guilfoyle, Esquire Blank Rome LLP 1201 Market Street, Suite 800 Wilmington, DE 19801

HAND DELIVERY (Counsel to Shiloh Die Cast Midwest LLC) Brian A. Sullivan, Esquire Werb & Sullivan 300 Delaware Avenue, Suite 1300 P.O. Box 25046 Wilmington, DE 19899

HAND DELIVERY (Counsel to RI SPC) Thomas J. Francella, Jr., Esquire Whiteford Taylor & Preston LLC 405 North King Street, Suite 500 Wilmington, DE 19801

FIRST CLASS MAIL Securities & Exchange Commission Secretary of the Treasury 100 F. Street, NE Washington, DC 20549

FIRST CLASS MAIL Andrew Calamari, Regional Director Securities & Exchange Commission New York Regional Office 3 World Financial Center, Suite 400 New York, NY 10281

FIRST CLASS MAIL Delaware State Treasury 820 Silver Lake Blvd., Suite 100 Dover, DE 19904

FIRST CLASS MAIL Secretary of State Division of Corporations - Franchise Tax P.O. Box 898 Dover, DE 19903

FIRST CLASS MAIL Internal Revenue Service P0 Box 7346 Philadelphia, PA 19101


FIRST CLASS MAIL Zillah A. Frampton Delaware Division of Revenue Bankruptcy Administrator CSOB 8th Floor 820 N. French Street Wilmington, De 19801

FIRST CLASS MAIL (Co-counsel to Debtor) Brian Trust, Esquire Howard S. Beltzer, Esquire Frederick D. Hyman, Esquire Mayer Brown LLP 1675 Broadway New York, NY 10019

FIRST CLASS MAIL (Counsel to General Motors LLC) Aaron M. Silver, Esquire Honigman Miller Schwartz and Cohn LLP 2290 First National Building 660 Woodward Avenue Suite 2290 Detroit, MI 48226

FIRST CLASS MAIL (Counsel to Chrysler Group LLC) Sheryl L. Toby, Esquire Dykema Gossett PLLC 39577 Woodward Ave., Suite 300 Bloomfield Hills, MI 48304

FIRST CLASS MAIL (Counsel to JTEKT North America, Inc.) Michael E. Baum, Esquire Daniel J. Weiner, Esquire Jeffery J. Sattler, Esquire Schafer and Weiner, PLLC 40950 Woodward Ave., Suite 100 Bloomfield Hills, MI 48304

FIRST CLASS MAIL (Counsel to Ford Motor Company) Stephen S. LaPlante, Esquire Jonathan S. Green, Esquire Marc N. Swanson, Esquire Miller, Canfield, Paddock and Stone, P.L.C. 150 West Jefferson, Suite 2500 Detroit, MI 48226

FIRST CLASS MAIL David Boyle Airgas, Inc. 259 Radnor-Chester Road, Suite 100 P. 0. Box 6675 Radnor, PA 01908

FIRST CLASS MAIL Cassandra B. Caverly, Esquire Pension Benefit Guaranty Corp. Office of the Chief Counsel 1200 K Street, N.W. Washington, DC 20005

FIRST CLASS MAIL Ruben R. Chapa, Esquire Senior Trial Attorney, Office of the Solicitor U.S. Department of Labor 230 South Dearborn, Room 844 Chicago, IL 60604

FIRST CLASS MAIL Matthew M. Scheff, Esquire Trial Attorney - U.S. Department of Labor Office of the Solicitor 1240 B. 9th Street, Room 881 Cleveland, OH 44199

FIRST CLASS MAIL (Counsel to Boston Financial Group) Gregg M. Galardi, Esquire Gabriella Thorovsky, Esquire DLA Piper LLP (US) 1251 Avenue of the Americas, 27th Floor New York, NY 10020


FIRST CLASS MAIL (Counsel to Nexteer Automotive Corporation) Thomas B. Radom, Esquire Butzel Long, PC Stoneridge West 41000 Woodward Avenue Bloomfield Hills, MI 48304

FIRST CLASS MAIL (Counsel to Bridgeport Capital Funding LLC) Barry P. Gruher, Esquire Genovese Joblove & Battista P.A. 200 E. Broward Blvd, Suite 1110 Ft. Lauderdale, FL 33301

FIRST CLASS MAIL

FIRST CLASS MAIL (Counsel to Gary Walter, Vigin Hoey and (Counsel to PCG Acquisition Corporation) David Bagby)

Aaron L. Hammer, Esquire Don Darnell, Esquire

Christopher J. Horvay, Esquire Darnell Law Offices Suger Felsenthal Grais & Hammer LLP 7926 Ann Arbor Street

30 N. LaSalle Street, Suite 3000 Dexter, MI 48130

Chicago, IL 60602

FIRST CLASS MAIL (Counsel to Native American Logistics Worldwide, LLC) Kevin N. Summers, Esquire Dean & Fulkerson, P.C. 801 W. Big Beaver Road, Suite 500 Troy, MI 48084

FIRST CLASS MAIL (Counsel to Multi-Precision Detail, Inc.) Steven A. Siman, Esquire Steven A. Siman, P.C. 3250 W. Big Beaver, Suite 344 Troy, MI 48084

FIRST CLASS MAIL (Creditor) David R. Jury, Esquire Associate General Counsel United Steelworkers Five Gateway Center Room 807 Pittsburgh, PA 15222

FIRST CLASS MAIL Donna Cutting GIL Inc. 419 E. 4th Street Royal Oak, MI 48067

FIRST CLASS MAIL (Counsel to Bry-Mac, Inc. dlb/a Dietech Tooling Solutions) Bradley J. Fisher Scholten Fant, P.C. 100 N. Third Street P0 Box 454 Grand Haven, MI 49417

FIRST CLASS MAIL (Counsel to Oakland County Treasurer) Richardo I. Kilpatrick, Esquire Kilpatrick & Associates, P.C. 903 North Opdyke Road, Suite C Auburn Hills, MI 48326

FIRST CLASS MAIL Neil Herskowkitz Riverside Claims P0 Box 626 Planetarium Station New York, NY 10024

FIRST CLASS MAIL (Counsel to GE CF Mexico of S.A. de C. V.) Michael J. Venditto, Esquire Reed Smith LLP 599 Lexington Avenue New York, NY 10022


FIRST CLASS MAIL (Counsel to Hillsdale Salaried Pension Plan and Hillsdale Hourly Pension Plan) Dennis J. Connolly, Esquire, Kevin M. Hembree, Esquire Alston & Bird LLP One Atlantic Center 1201 West Peachtree Street Atlanta, GA 30309

FIRST CLASS MAIL (Counsel to Cole Taylor Bank) Michael B. Schaedle, Esquire Blank Rome LLP One Logan Square Philadelphia, PA 19103

FIRST CLASS MAIL (Counsel to Shiloh Die Cast Midwest LLC) Steve E. Pryatel, Esquire Lawrence S. Crowther, Esquire Wegman, Hessler & Vanderburg 6055 Rockside Wood Blvd., Suite 200 Cleveland, OH 44131

FIRST CLASS MAIL (Counsel to Plex Systems, Inc) Michael A. Fleming, Esquire Plunkett Cooney 38505 Woodward Avenue, Suite 2000 Bloomfield Hills, MI 48304

FIRST CLASS MAIL (Counsel to RI SPC) Andrew J. Gallo, Esquire Bingham McCutchen, LLP One Federal Street Boston, MA 02110


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