This document is a Notice of Appearance and Request for All Notices filed in the United States Bankruptcy Court for the District of Delaware. It notifies the court that the law firm Beins Axelrod, P.C. and attorney H. David Kelly, Jr. represent the Teamsters Joint Council No. 83 of Virginia Pension Fund, a creditor in the bankruptcy case. The notice requests that all filings and notices in the bankruptcy proceeding be served on the Joint Council No. 83 Fund's attorney. The notice also reserves the Fund's rights and does not constitute consent to the court's jurisdiction.
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In The United States Bankruptcy Court For The District of Delaware
This document is a Notice of Appearance and Request for All Notices filed in the United States Bankruptcy Court for the District of Delaware. It notifies the court that the law firm Beins Axelrod, P.C. and attorney H. David Kelly, Jr. represent the Teamsters Joint Council No. 83 of Virginia Pension Fund, a creditor in the bankruptcy case. The notice requests that all filings and notices in the bankruptcy proceeding be served on the Joint Council No. 83 Fund's attorney. The notice also reserves the Fund's rights and does not constitute consent to the court's jurisdiction.
This document is a Notice of Appearance and Request for All Notices filed in the United States Bankruptcy Court for the District of Delaware. It notifies the court that the law firm Beins Axelrod, P.C. and attorney H. David Kelly, Jr. represent the Teamsters Joint Council No. 83 of Virginia Pension Fund, a creditor in the bankruptcy case. The notice requests that all filings and notices in the bankruptcy proceeding be served on the Joint Council No. 83 Fund's attorney. The notice also reserves the Fund's rights and does not constitute consent to the court's jurisdiction.
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In The United States Bankruptcy Court For The District of Delaware
This document is a Notice of Appearance and Request for All Notices filed in the United States Bankruptcy Court for the District of Delaware. It notifies the court that the law firm Beins Axelrod, P.C. and attorney H. David Kelly, Jr. represent the Teamsters Joint Council No. 83 of Virginia Pension Fund, a creditor in the bankruptcy case. The notice requests that all filings and notices in the bankruptcy proceeding be served on the Joint Council No. 83 Fund's attorney. The notice also reserves the Fund's rights and does not constitute consent to the court's jurisdiction.
Copyright:
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INRE:
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE ) ) ALLIED SYSTEMS & HOLDINGS, INC. eta.[ ) Case No. 12-11564 (CSS) ) Chapter 11 DebtorS. ) ) NOTICE OF APPEARANCE AND REQUEST FOR ALL NOTICES PLEASE TAKE NOTICE THAT the undersigned enters his appearance in the above -captioned Chapter 11 cases as counsel for the Teamsters Joint Council No. 83 of Virginia Pension Fund ("Joint Council No. 83 Fund"), a creditor and party in interest, hereby enters his appearance in the above-captioned case as the attorney for the Joint Council No. 83 Fund pursuant to Federal Rule of Bankruptcy Procedure 9010(b), and hereby requests, pursuant to 11 U.S.C. 342 and 1109(b) and Bankruptcy Rules 2002, 3017, 4001, 9007 and 9010, that all notices, pleadings, motions, plans, disclosure statements and any other documents filed in these proceedings, including any documents filed in connection with any adversary proceeding commenced in connection with the above-captioned cases be delivered and served upon the Joint Council No. 83 Fund at the address of its counsel as set forth below: H. David Kelly, Jr. Beins Axelrod, P.C. 1625 Massachusetts Avenue, N.W., Suite 500, Washington, DC 20036 (202) 328-7222-Telephone (202) 328-7030-Facsimile dkelly@beinsaxlerod.com- Email PLEASE TAKE FURTHER NOTICE that pursuant to 11 U.S.C. 1109(b), the foregoing request includes not only the notices and papers referred to in the Bankruptcy Code and Federal Rules of Bankruptcy Procedure specified above, but also includes, without limitation, the schedules, statement of financial affairs, operating reports, any plans of reorganization and disclosure statements and nay notice, application, complaint, demand, motion, petition, pleading or request, whether formal or informal, written or oral, and whether transmitted or conveyed by mail, delivery, or otherwise when such document is filed with regard to the above-captioned cases and the proceedings therein. PLEASE TAKE FURTHER NOTICE that this notice of appearance is not intended as, nor is it, a consent to the jurisdiction of the Bankruptcy Court, specifically but not limited to (i) the right to have final orders in all non-core matters entered only after de novo review by the District Court, (ii) the right of the Fund to a trial by jury in any proceeding so triable herein, or in any case, controversy or proceeding related thereto; (iii) the right to have the reference withdrawn by the District Court in nay matter subject to mandatory or discretionary withdrawal, or (iv) any other rights, claims, actions, defenses, setoffs, or recoupments to which it is or may be entitled to under agreement, in law or equity, all of which rights, claims, actions, defenses, setoffs, and recoupments it expressly reserves. Dated: June 29, 2012 Respectfully submitted, ( : dA td t/fl jJJ/\ () BEINS AXELROD, J ()/ By: H. David Kelly, Jr. Beins, Axelrod, P.C. 1625 Massachusetts Avenue, N.W. Suite 500 Washington, D.C. 20036 202-328-7222 202-328-7030 (telecopier) 2 CERTIFICATE OF SERVICE I, H. David Kelly, Jr., one of the attorneys for Teamsters Joint Council No. 83 of Virginia Pension Fund, certify that on June 29,2012, I served a true and correct copy of the foregoing Notice of Appearance and Request for All Notices on all the following parties by U.S. First Class Mail, postage prepaid, to: Mark Collins Christopher M. Samis Richards, Layton & Finger, P .A. 920 King Street One Rodney Square Wilmington, DE 19801 3 United States Trustee 844 King Street, Room 2207 Lockbox #35 Wilmington, DE 19899-0035 : ~ .}JwLcA:% D H. David Kelly, Jr.
United States of America Ex Rel. William Joseph McGurrin v. John P. Shovlin, Superintendent, Farview State Hospital, Waymart, Pennsylvania, 455 F.2d 1278, 3rd Cir. (1972)