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In The United States Bankruptcy Court For The District of Delaware

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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.

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