10000000559

In re:
IN THE UNITED STATES BANKRUPTCY COURT

DISTRICT OF DELAWARE
Chapter 11
ALLIED SYSTEMS HOLDINGS, INC., et
a/.,
1
Case No. 12-11564 (CSS)
Debtor.
(Jointly Administered)
Hearing Date: Nov. 7, 2012 at 9:30a.m. (Eastern Time)
Objection Deadline: Nov. 2, 2012 at 4:00p.m. (Eastern Time)
MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS
FOR AN ORDER UNDER RULE 2004 OF THE FEDERAL RULES OF
BANKRUPTCY PROCEDURE AUTHORIZING DISCOVERY
FROM YUCAIPA AMERICAN ALLIANCE FUND I, LP AND
YUCAIPA AMERICAN ALLIANCE (PARALLEL) FUND I, LP
The Official Committee of Unsecured Creditors (the "Committee") appointed in the
above-captioned chapter 11 cases of Allied Systems Holdings, Inc. ("Allied"), Allied Systems,
Ltd. (L.P.) ("Systems") and their U.S. and Canadian subsidiaries (collectively, the "Debtors"), by
and through its undersigned counsel, hereby requests, pursuant to Rule 2004 of the Federal Rules
of Bankruptcy Procedure (the "Bankruptcy Rules"), entry of an order requiring Yucaipa
American Alliance Fund I, LP and Yucaipa American Alliance (Parallel) Fund I, LP
(collectively, "Yucaipa") to produce documents and related information responsive to the
discovery requests set forth on Exhibit A hereto. In support thereof, the Committee respectfully
states as follows:
The Debtors in these cases, along with the federal tax identification number (or Canadian business number
where applicable) for each of the Debtors, are: Allied Systems Holdings, Inc. (58-0360550); Allied Automotive
Group, Inc. (58-2201081); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0169283); Allied Systems, Ltd. (L.P.) (58-1710028); Axis Areta, LLC (45-5215545); Axis Canada Company
(87568828); Axis Group, Inc. (58-2204628); Commercial Carriers, Inc. (38-0436930); CT Services, Inc. (38-
2918187); Cordin Transport LLC (38-1985795); F.J. Boutell Driveaway LLC (38-0365100); GACS Incorporated
(58-1944786); Logistic Systems, LLC (45-4241751); Logistic Technology, LLC (45-4242057); QAT, Inc. (59-
2876863); RMX LLC (31-0961359); Transport Support LLC (38-2349563); and Terminal Services LLC (91-
0847582). The location of the Debtors' corporate headquarters and the Debtors' address for service of process is
2302 Parklake Drive, Bldg. 15, Ste. 600, Atlanta, Georgia 30345.
NY! 8534090v.6
PRELIMINARY STATEMENT
1. From the start of these cases, the question ofYucaipa's actions and allegations of
its purported control over the Debtors has loomed large over these proceedings. Indeed, even
before the initiation of these cases, Yucaipa's actions in purporting to acquire a majority of the
outstanding debt issued pursuant to the First Lien Credit Facilitj and the Second Lien Credit
Facility,
3
and Yucaipa's actions thereafter have, to the Committee's knowledge, generated four
separate lawsuits in three different jurisdictions. All of those lawsuits, three of which included
not only Yucaipa as a party but also the Debtors, involved allegations that Yucaipa's purported
acquisition of the majority of the outstanding debt issued under the First Lien Credit Facility was
unlawful or impermissible.
2. On October 18, 2012, the Stipulation Among the Debtors, the DIP Agent, the DIP
Lenders and the Official Committee of Unsecured Creditors Regarding Postpetition Secured DIP
Financing, Credit Bidding Under Section 363 of the Bankruptcy Code and Certain
Administrative Matters was filed,
4
pursuant to which, among other things, Yucaipa agreed to
"provide the Committee with any documents or other information reasonably requested by the
Committee in its evaluation of the Yucaipa Credit Bid (subject to attorney-client privilege and
work product)" and to not object to the Committee bringing a Rule 2004 motion seeking
2
References to the "First Lien Credit Facility" are to that certain Amended and Restated First Lien Secured Super-
Priority Debtor In Possession and Exit Credit and Guaranty Agreement dated as of March 30, 2007 and amended
and restated as of May 15, 2007 by and among Allied Holdings, Inc., Allied Systems, Ltd. (L.P.), Certain
Subsidiaries of Allied Holdings, Inc. and Allied Systems Ltd. (L.P.), Various Lenders, Goldman Sachs Credit
Partners L.P., and The CIT Group/Business Credit, Inc.
3
References to the "Second Lien Credit Facility" are to that certain Second Lien Secured Super-Priority Debtor in
Possession and Exit Credit and Guaranty Agreement dated as of May 15, 2007 by and among Allied Holdings, Inc.,
Allied Systems, Ltd. (L.P.), Certain Subsidiaries of Allied Holdings, Inc. and Allied Systems, Ltd. (L.P.), Various
Lenders, and Goldman Sachs Credit Partners.
4
As Exhibit A to the Motion for an Order Pursuant to Section 105 (a) of the Bankruptcy Code and Bankruptcy Rule
9019 Approving Stipulation Among the Debtors, the DIP Agent, the DIP Lenders and the Official Committee of
Unsecured Creditors Regarding Postpetition Secured DIP Financing, Credit Bidding Under Section 363 of the
Bankruptcy Code and Certain Administrative Matters (the "Motion to Approve Stipulation") (D.I. 539).
NY! 8534090v.6 2
discovery from Com Vest in the event that Com Vest does not consent to Yucaipa providing the
Loan Purchase Agreement to the Committee.
3. In light of a potential Yucaipa Credit Bid,
5
and consistent with its statutory
obligation to investigate whether causes of action that might benefit the estate exist, the
Committee has been endeavoring to conduct an investigation of whether Yucaipa's purported
acquisition of the majority of the First Lien Credit Facility, and its related alleged ascension to
the status of the "Requisite Lender" under the First Lien Credit Facility, was proper and whether
those actions gave rise to any potential causes of action or other issues in connection with the
Yucaipa Credit Bid.
4. Because of the existence of the pre-petition lawsuits, and the likelihood that such
lawsuits had already revealed many of the facts that would be relevant to the evaluation of
potential issues relating to the Yucaipa Credit Bid, the Committee has focused its investigation
of the Yucaipa Credit Bid primarily on documents and materials from the pre-petition lawsuits.
In particular, the Committee requested documents, including deposition transcripts, exhibits and
pleadings, that had been filed or served in an action previously pending in the Superior Court of
Fulton County, State of Georgia, captioned Allied Systems Holdings, Inc., et al. v. The CIT
Group/Business Credit, Inc., No. 2009-CV-177574 (the "CIT Georgia Litigation"), involving the
Debtors and Yucaipa.
5. While the Debtors have been largely forthcoming in producing materials to the
Committee, the Committee needs discovery from Yucaipa, as well. Yesterday, Yucaipa agreed
to produce the transcripts of depositions of Yucaipa witnesses, including at least one deposition
of a member of the Debtors' Board of Directors, taken in the CIT Georgia Litigation, as well as
some, but not all, of the exhibits marked at those depositions.
5
As defined in the Motion to Approve Stipulation.
NYl 8534090v.6 3
6. The primary category of documents that Yucaipa has not agreed to produce relate
to the Loan Purchase Agreement between Yucaipa and Com Vest Investment Partners III, L.P.
and/or Com Vest III Partners, LLC ("Com Vest") and/or any Com Vest-affiliated entity ("Loan
Purchase Agreement"). Yucaipa has informed the Committee that it is a party to a non-
disclosure agreement with Com Vest and that Com Vest has refused to consent under the non-
disclosure agreement to the production of the Loan Purchase Agreement or any related exhibits
marked at the depositions referenced above.
7. Upon information and belief, the Loan Purchase Agreement, including all of its
terms and conditions, and communications relating to the Loan Purchase Agreement are
significant to the Committee's investigation of the Yucaipa Credit Bid. Indeed, in the pre-
petition lawsuits brought against Yucaipa, there have public and specific allegations made
concerning the terms of the alleged acquisition under the Loan Purchase Agreement that may be
highly relevant to whether or not potential issues relating to the Yucaipa Credit Bid exist.
8. By this Motion, the Committee requests authority, pursuant to Bankruptcy Rule
2004, to issue Rule 2004 subpoenas to Yucaipa to obtain information relevant and required for
the Committee's investigation of the Yucaipa Credit Bid.
BACKGROUND
9. On May 17, 2012 (the "Petition Date"), involuntary petitions were filed by Black
Diamond CLO 2005-1 Ltd., BDCM Opportunity Fund II, LP and Spectrum Investment Partners,
L.P. (collectively, the "Petitioning Creditors"), prepetition lenders (the "First Lien Lenders") to
the Debtors against Allied and its subsidiary Systems under chapter 11 oftitle 11 of the United
States Code (the "Bankruptcy Code") in this Bankruptcy Court (the "Court"). See Statement of
Petitioning Creditors in Support of the Involuntary Chapter 11 Petitions Filed Against Allied
NY! 8534090v.6 4
Systems Holdings, Inc. and Allied Systems, Ltd. (L.P.) [Docket No.9] ("Petitioning Creditors
Statement").
10. On June 10, 2012 (the "Consent Date"), the remaining Debtors filed voluntary
petitions in this Court, and, in connection therewith, Allied and Systems consented to the
involuntary petitions filed against them. The chapter 11 cases commenced thereby are,
collectively, the "Chapter 11 Cases."
11. The Debtors have continued in possession of their property and have continued to
operate and manage their businesses as debtors in possession pursuant to sections 1107(a) and
1108 ofthe Bankruptcy Code. On June 11, the Court entered an order jointly administering the
Chapter 11 Cases pursuant to Rule 1 0 15(b) of the Federal Rules of Bankruptcy Procedure (the
"Bankruptcy Rules") for procedural purposes only. On June 19, 2012, the Office of the United
States Trustee (the "U.S. Trustee") appointed the Committee.
12. On October 18,2012, Allied filed an adversary proceeding complaint (the
"Adversary Proceeding") seeking declaratory and injunctive relief and naming the Committee as
a defendant. The Committee will file a timely answer in the Adversary Proceeding.
JURISDICTION AND STATUTORY PREDICATES
13. This Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334. This is a core proceeding pursuant to 28 U.S.C. 157(b)(2). The statutory predicates for
the relief requested herein are 105(a) ofthe Bankruptcy Code, Bankruptcy Rule 2004 and
Local Rule 2004-1.
NYl 8534090v.6 5
RELIEF REQUESTED
14. The Committee seeks to obtain the documents and other information set forth in
the Request attached as Exhibit A hereto (the "Requested Information") under Bankruptcy Rule
2004 on the basis that this information relates to the acts, conduct, assets, liabilities and financial
condition of the Debtor and which may affect the administration of the Debtor's estate.
BASIS FOR RELIEF REQUESTED
15. Bankruptcy Rule 2004 permits a "party in interest" to obtain discovery of
information relating to the "acts, conduct, or property or to the liabilities or financial condition of
the debtor, or to any matter which may affect the administration of the debtor's estate." Fed. R.
Bankr. P. 2004(b).
16. The scope of permitted discovery under Rule 2004 "is 'unfettered and broad."' In
re Washington Mutual, Inc., 408 B.R. 45, 49 (Bank. D. Del. 2009) (quoting In re Bennett
Funding Group, Inc., 203 B.R. 24,28 (Bank. N.D.N.Y. 1996)). "Legitimate goals of Rule 2004
examinations include 'discovering assets, examining transactions, and determining whether
wrongdoing has occurred."' !d. at 50 (quoting In re Enron Corp., 281 B.R. 836, 840 (Bank.
S.D.N.Y. 2002)).
17. Bankruptcy courts have held that Rule 2004 motions "'are to be decided by
balancing the competing interests of the parties, weighing the relevance and necessity for the
information sought by the [movant] against the extent of the inconvenience and intrusion to the
witness."' In re Pub. Serv. Co. ofNH, 91 B.R. 198, 199 (Bankr. D.N.H. 1988) (citation
omitted). In making this determination, courts consider the purpose of the request as well as the
degree of alleged intrusiveness. See In re Drexel Burnham Lambert Group, 123 B.R. 702, 712
NY! 8534090v.6 6
(Bankr. S.D.N.Y. 1991) (discussing evolution and purpose of Rule 2004 and granting Rule 2004
discovery motion where "requested purpose" was for "claims amendment and claims litigation").
18. As can be seen from the attached Exhibit A, the discovery requested by the
Committee seeks only documents and information relevant to its investigation and its
examinations of relevant transactions to determine if potential claims arising from Yucaipa's
purported acquisition of a majority of the First Lien Credit Facility debt and/or its alleged
ascension to the status of the "Requisite Lender" under the First Lien Credit Facility exist. The
requested information will enable the Committee to determine whether it has any causes of
action in connection with the Yucaipa Credit Bid. As such, the requested discovery is relevant
and necessary and falls squarely within the broad scope of Bankruptcy Rule 2004.
6
19. No previous motion for the relief sought herein has been made to this or any other
court.
6
In making this motion under Rule 2004, the Committee does not intend to, and does not, limit or define the scope
of discovery it may seek in cotmection with the adversary proceeding recently filed by the Debtors captioned Allied
Systems Holdings, Inc. v. American Money Management Corp., et al., 12ap50947 (CSS). Indeed, as it is a named
defendant in that proceeding, the Committee has all rights to seek discovery from the Plaintiff, the Debtors, and co-
defendants, as is permitted under the Federal Rules of Bankruptcy Procedure and the Federal Rules of Civil
Procedure.
NY! 8534090v.6 7
NOTICE
20. The Committee has provided notice of this Motion to: (i) the U.S. Trustee; (ii)
counsel for the agent for the Debtors' debtor-in-possession lenders; (iii) counsel for the Debtors;
(iv) counsel for CIT, as resigning agent under the Debtors' First Lien Credit Facility, (v) counsel
for the Petitioning Creditors; (vi) counsel for The Bank of New York Mellon, in its capacity as
administrative agent and collateral agent under the Debtors' second lien credit agreement; (vii)
counsel for Com Vest Investment Partners III, L.P. and Com Vest III Partners, LLC; and (vii) all
other persons requesting notices pursuant to Bankruptcy Rule 2002. In light of the nature of the
relief requested, the Committee respectfully submits that no further notice is necessary.
CERTIFICATION OF COMPLIANCE WITH LOCAL RULE 2004-1
21. Counsel for the Committee certifies that the Committee has complied with Local
Rule 2004-1. Undersigned counsel has communicated with Yucaipa's counsel regarding
production of the requested information and informed Yucaipa's counsel that the Committee
intended to file this Motion.
NY! 8534090v.6 8
CONCLUSION
For the foregoing reasons, the Committee respectfully requests entry of an order,
substantially in the form attached hereto as Exhibit B, granting the relief requested herein, and
such other and further relief as is just.
Dated: Wilmington, Delaware
October 26, 2012
NY! 8534090v.6
LINSONLLC
William D. Sullivan (No
William A. Hazeltine (N 3294)
901 N. Market St., Suite 1300
Wilmington, DE 19801
Telephone: (302) 428-8191
Facsimile: (302) 428-8195
- and-
SIDLEY AUSTIN LLP
Michael G. Burke
Nicholas K. Lagemann
Brian J. Lohan
Dennis Kao
787 Seventh A venue
New York, NY 10019
Telephone: (212) 839-5300
Facsimile: (212) 839-5599
Matthew A. Clemente
One South Dearborn Street
Chicago, IL 60603
Telephone: (312) 853-7000
Facsimile: (312) 853-7036
Counsel for the Official Committee of Unsecured
Creditors
9
In re:
Chapter 11
a/.,1
Case No. 12-11564 (CSS)
Debtor.
Hearing Date: Nov. 7, 2012 at 9:30a.m. (Eastern Time)
Objection Deadline: Nov. 2, 2012 at4:00 p.m. (Eastern Time)
NOTICE OF MOTION OF THE OFFICIAL COMMITTEE OF UNSECURED
CREDITORS FOR AN ORDER UNDER RULE 2004 OF THE FEDERAL
RULES OF BANKRUPTCY PROCEDURE AUTHORIZING DISCOVERY
FROM YUCAIPA AMERICAN ALLIANCE FUND I, LP AND
YUCAIPA AMERICAN ALLIANCE (PARALLEL) FUND I, LP
TO: Notice has been given to the following parties or, in lieu thereof, to their counsel, if
known: (i) the U.S. Trustee; (ii) counsel for the agent for the Debtors' debtor-in-
possession lenders; (iii) counsel for the Debtors; (iv) counsel for CIT, as resigning agent
under the Debtors' first lien credit agreement, (v) counsel for Black Diamond CLO 2005-
1 Ltd., BDCM Opportunity Fund II, LP and Spectrum Investment Partners, L.P.; (vi)
counsel for The Bank of New York Mellon, in its capacity as administrative agent and
collateral agent under the Debtors' second lien credit agreement; (vii) counsel for
Com Vest Investment Partners III, L.P. and Com Vest III Partners, LLC; and (viii) all
other persons requesting notices pursuant to Bankruptcy Rule 2002.
PLEASE TAKE NOTICE that, on October 26,2012, the Official Committee of
Unsecured Creditors (the "Committee") appointed in the above-captioned chapter 11 cases of
Allied Systems Holdings, Inc. ("Allied"), Allied Systems, Ltd. (L.P.) ("Systems") and their U.S.
and Canadian subsidiaries (collectively, the "Debtors"), by and through its undersigned counsel,
filed the Motion qfthe qfficial Committee q[Unsecured Creditorsfor an Order Under Rule
Group, Inc. (58-220 I 081 ); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0 169283); Allied Systems, Ltd. (L.P.) (58-171 0028); Axis Areta, LLC (45-5215545); Axis Canada Company
2004 of the Federal Rules of Bankruptcy Procedure Authorizing Discovery from Yucaipa
American Alliance Fund I, LP and Yucaipa American Alliance (Parallel) Fund I, LP (the
"Motion") with the United States Bankruptcy Court for the District of Delaware, 824 Market
Street, 3rd Floor, Wilmington, Delaware 19801 (the "Bankruptcy Court").
PLEASE TAKE FURTHER NOTICE that any responses or objections to the Motion
must be filed with the Bankruptcy Court, 824 Market Street, 3rd Floor, Wilmington, Delaware
19801, and served upon and received by the undersigned counsel for the Committee on or before
November 2, 2012 at 4:00p.m. (Eastern Daylight Time).
PLEASE TAKE FURTHER NOTICE that a hearing on the Motion is scheduled to be
held on November 7, 2012, at 9:30a.m. (Eastern Time) before The Honorable Christopher S.
Sontchi at the United States Bankruptcy Court for the District of Delaware, 824 Market Street,
5
111
Floor, Courtroom 6, Wilmington, Delaware 19801.
PLEASE TAKE FURTHER NOTICE THAT IF NO RESPONSES OR OBJECTIONS
TO THE MOTION ARE TIMELY FILED, SERVED OR PRESENTED AT THE HEARING IN
ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF
REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE.
2
October 26, 2012
SULLIVAN HAZEL TINE ALLINSON LLC
Is/ William A. Hazeltine
William D. Sullivan (No. 2820)
William A. Hazeltine (No. 3294)
901 N. Market St., Suite 1300
Telephone: (302) 428-8191
Facsimile: (302) 428-8195
-and-
SIDLEY AUSTIN LLP
Michael G. Burke
Brian J. Lohan
Dennis Kao
787 Seventh A venue
New York, NY 10019
Telephone: (212) 839-5300
Facsimile: (212) 839-5599
Matthew A. Clemente
Chicago, IL 60603
Telephone: (312) 853-7000
Facsimile: (312) 853-7036
Counsel for the Official Committee of Unsecured
Creditors
3
EXHIBIT A
Exhibit A
RULE 2004 DISCOVERY OF
YUCAIPA AMERICAN ALLIANCE FUND I, LP
AND YUCAIPA AMERICAN ALLIANCE (PARALLEL) FUND I, LP
Definitions and Rules of Construction
As used herein, the following terms shall have the following meanings:
1. The terms "all" or "each" shall be construed as all and each.
2. The terms "and" and "or" shall be construed either disjunctively or conjunctively
as necessary to bring within the scope of these requests all responses that might otherwise be
construed to be outside their scope.
3. The term "CIT Georgia Litigation" shall mean the action previously pending in
the Superior Court of Fulton County, State of Georgia, captioned Allied Systems Holdings, Inc.,
et al. v. The CIT Group/Business Credit, Inc., No. 2009-CV -177574.
4. The term "Com Vest" shall mean Com Vest Investment Partners III, L.P.,
Com Vest III Partners, LLC, or any other Com Vest affiliate.
5. The terms "concern" or "concerning," in addition to their natural meaning, shall
also mean reflecting, constituting, containing, pertaining to, referring to, indicating, showing,
evidencing, describing, discussing, mentioning, bearing upon, comprising, and relating to.
6. The term "Debtors" shall mean debtors Allied Systems Holdings, Inc.; Allied
Automotive Group, Inc.; Allied Freight Broker LLC; Allied Systems (Canada) Company; Allied
Systems, Ltd. (L.P.); Axis Areta, LLC; Axis Canada Company; Axis Group, Inc.; Commercial
Carriers, Inc.; CT Services, Inc.; Cordin Transport LLC; F.J. Boutell Driveaway LLC; GACS
Incorporated; Logistic Systems, LLC; Logistic Technology, LLC; QAT, Inc.; RMX LLC;
Transport Support LLC; and Terminal Services LLC and each of their current and former
corporate parents, divisions, subsidiaries, affiliates, principals, officers, directors, employees,
officials, agents, representatives, independent consultants, and other persons or entities acting on
their behalf or under their control.
7. The term "document" shall mean those things described in Rule 34(a) of the
Federal Rules of Civil Procedure, made applicable in bankruptcy cases by Rules 7304 and 9014
of the Federal Rules of Bankruptcy Procedure. The terms "document" and "documents" are used
herein in the broadest possible sense, including, without limiting the generality of this definition,
any written, printed, typed, recorded, taped, graphic, computerized printout, electronically stored
information, electronic data, electronically or computerized compiled, or other matter or
materials, from whatever source, including information stored on any electronic media, however
produced or reproduced or capable of being produced, whether in draft form or otherwise,
whether sent or received or neither-including the original, a copy (if the original is not
available), and non-identical copies (whether different from the original because of notes made
on or attached to such copies or otherwise) and all drafts of all writings, confirmations, invoices,
orders, studies, assays, audit reports, wire transfers, correspondence, letters, statements,
telegrams, telexes, cables, contracts, proposals, agreements, minutes, notes, memoranda,
analyses, projections, work papers, books, records, reports, diaries, questionnaires, books of
account, checks, check stubs, lists, logs, calendars, graphs, charts, sketches, diagrams, drawings,
photographs, motion picture films, summaries, digests, financial statements, and all other
information or data records or compilations, including all underlying, supporting, or preparatory
material.
8. The term "draft" shall mean any earlier, preliminary, preparatory, proposed, or
tentative version of all or part of a document, whether or not such draft was superseded by a later
draft or final document and whether or not the terms of the draft are the same or different from
the terms of the final document.
9. The term "First Lien Credit Facility" shall mean that certain Amended and
Restated First Lien Secured Super-Priority Debtor In Possession and Exit Credit and Guaranty
Agreement dated as of March 30, 2007 and amended and restated as of May 15, 2007 by and
among Allied Holdings, Inc., Allied Systems, Ltd. (L.P.), Certain Subsidiaries of Allied
Holdings, Inc. and Allied Systems Ltd. (L.P.), Various Lenders, Goldman Sachs Credit Partners
L.P., and The CIT Group/Business Credit, Inc.
10. The term "Florida Litigation" shall mean the action pending in the Circuit Court
of the 15
111
Judicial Circuit in and for Palm Beach County, Florida, captioned T. Michael Riggs,
Innovative Equity Partners, LLC and Jack Cooper Company, Inc. v. Com Vest
Investment Partners III, L.P., and Com Vest III Partners, LLC, No. 502009CA042921XXXXMB.
11. The term "Fourth Amendment" shall mean that certain Amendment No. 4 to
Credit Agreement dated as of August 21, 2009 by and among Allied Systems Holdings, Inc.,
Allied Systems, Ltd. (L.P.), Certain Subsidiaries of the Borrowers, Lenders, Goldman Sachs
Credit Partners L.P ., and The CIT Group/Business Credit, Inc.
12. The term "including" shall mean "including without limitation."
13. The term "New York Litigation" shall mean the action pending in the Supreme
Court of the State ofNew York, County ofNew York, captioned BDCM Opportunity Fund II,
LP, Black Diamond CLO 2005-1 LTD Spectrum Investment Partners L.P. v. Yucaipa American
Alliance Fund I, LP and Yucaipa American Alliance (Parallel) Fund I, LP., No. 650150/2012.
14. The term "person(s)" shall mean all natural and legal persons including, without
limitation, individuals, corporations, joint ventures, partnerships, trustees, sole proprietorships,
unincorporated associations, and any agency, division, subdivision, branch, or department of any
local, state, or federal government.
15. The term "Riggs Georgia Litigation" shall mean the action previously pending in
the Superior Court of Cobb County, State of Georgia, captioned Allied Systems Holdings, Inc. v.
T. Michal Riggs and Cooper-Active Group, No. 2009-1-10536-48.
2
16. The term "Second Lien Credit Agreement" shall mean that certain Second Lien
Secured Super-Priority Debtor in Possession and Exit Credit and Guaranty Agreement dated as
of May 15,2007 by and among Allied Holdings, Inc., Allied Systems, Ltd. (L.P.), Certain
Subsidiaries of Allied Holdings, Inc. and Allied Systems, Ltd. (L.P.), Various Lenders, and
Goldman Sachs Credit Partners.
17. The term "Third Amendment" shall mean that certain Amendment No.3 to Credit
Agreement and Consent dated as of April 17, 2008 by and among Allied Holdings, Inc., Allied
Systems, Ltd. (L.P.), Certain Subsidiaries of Allied Holdings, Inc., Lenders, Goldman Sachs
Credit Partners L.P., and The CIT Group/Business Credit Inc.
18. The terms "you" and "your" shall mean Yucaipa.
19. The term "Yucaipa" shall mean Yucaipa American Alliance Fund I, LP and
Yucaipa American Alliance (Parallel) Fund I, LP.
Instructions
A. This document request requires you to produce all documents called for herein
that were created or originated by you, or that came into your possession, custody or control,
from all files or other sources that contain responsive documents, wherever located and whether
active, in storage, or otherwise.
B. The obligation to produce the documents specified below is of a continuing
nature; your production is to be supplemented if at any time you acquire possession, custody, or
control of any additional responsive documents, or otherwise discover additional responsive
documents, between the time of initial production and the time of the hearing, to the fullest
extent required by the Federal Rules of Civil Procedure, the Federal Rules of Bankruptcy
Procedure, and the Local Rules of this Court.
C. Where only a portion of a document relates or refers to the subject indicated, the
entire document is to be produced nevertheless, along with all attachments, appendices and
exhibits.
D. If any document or portion thereof is withheld under a claim of privilege, you
shall produce so much of the document as is not subject to the possible claim of privilege, and
shall furnish a statement, signed by an attorney representing you , which identifies each
document or portion thereof for which a privilege is claimed, including the following
information:
(i) The date of the document;
(ii) The name and title of the person who sent, authored, prepared, signed, or
originated the document, or of the person who knows about the information contained therein;
(iii) The name and title of the recipient of the document;
3
(iv) All persons to whom copies of the document were furnished, along with
such persons' job titles or positions;
(v) A brief description of the subject matter or nature of the document
sufficient to assess whether the assertion of privilege is valid;
(vi) The specific basis upon which the privilege is claimed;
(vii) With respect to any claim of privilege relating to an attorney, or action or
advice or work product of an attorney, the identity of the attorney involved; and
(viii) The paragraphs of this request to which such document responds.
E. All documents shall be produced as they are kept in the ordinary course of
business and in their original file folders with any identifying labels, file markings, or similar
identifying features. If there are no documents responsive to a category specified below, you
shall so state in a writing produced at the time and place that documents are demanded to be
produced by this request.
F. If any document requested herein has been lost, discarded, or destroyed, that
document so lost, discarded, or destroyed shall be identified in writing (produced at the time and
place that documents are demanded to be produced by this request) as completely as possible,
together with the following information: date of disposal, manner of disposal, reason for
disposal, person authorizing the disposal and person disposing of the documents.
G. Unless otherwise specified, these requests seek documents for the period from
May 29, 2007 until the time that your responses to these requests are due.
Document Requests
1. All discovery responses made by Yucaipa and/or the Debtors, deposition
transcripts of witnesses from Yucaipa and/or the Debtors and deposition exhibits marked at
depositions of witnesses from Yucaipa and/or the Debtors in the Florida Litigation.
depositions of witnesses from Yucaipa and/or the Debtors in the CIT Georgia Litigation.
depositions of witnesses from Yucaipa and/or the Debtors in the Riggs Georgia Litigation.
4. All agreements you entered into with the Debtors or their affiliates.
5. All loan purchase or other agreements you entered into with Com Vest.
4
6. All documents concerning actual or potential consideration paid, or potentially
owed, from Yucaipa to ComVest in connection with the acquisition by Yucaipa of Com Vest's
debt holdings under the First Lien Credit Facility.
7. All communications between Yucaipa and Com Vest in connection with the Loan
Purchase Agreement and/or the Fourth Amendment.
8. All documents concerning the Third Amendment.
9. All documents concerning the Fourth Amendment.
5
EXHIBITB
In re:
Chapter 11
al. 'I
Case No. 12-11564 (CSS)
Debtor.
ORDER GRANTING MOTION OF THE OFFICIAL COMMITTEE OF
UNSECURED CREDITORS FOR AN ORDER UNDER RULE 2004 OF THE
FEDERAL RULES OF BANKRUPTCY PROCEDURE AUTHORIZING
DISCOVERY FROM YUCAIPA AMERICAN ALLIANCE FUND I, LP
AND YUCAIPA AMERICAN ALLIANCE (PARALLEL) FUND I, LP
The Court having considered the Motion of the Official Committee of Unsecured
Creditorsfor an Order Under Rule 2004 of the Federal Rules of Bankruptcy Procedure
Authorizing Discovery from Yucaipa American Alliance Fund I, LP and Yucaipa American
Alliance (Parallel) Fund L LP (the "Motion"); the Court having reviewed the Motion; the Court
having found that (i) the Court has jurisdiction over this matter pursuant to 28 U.S.C. 157 and
1334, (ii) this is a core proceeding pursuant to 28 U.S.C. 157(b)(2), and (iii) notice of the
Motion was sufficient under the circumstances; and the Court having determined that the legal
and factual bases set forth in the Motion establish just cause for the relief granted herein;
IT IS HEREBY ORDERED THAT:
1. The Motion is GRANTED.
Group, Inc. (58-220 1081 ); Allied Freight Broker LLC (59-2876864); Allied Systems (Canada) Company (90-
0169283); Allied Systems, Ltd. (L.P.) (58-171 0028); Axis Areta, LLC (45-5215545); Axis Canada Company
2. Yucaipa American Alliance Fund I, LP and Yucaipa American Alliance (Parallel)
Fund I, LP are to produce documents and related information responsive to the discovery
requests set forth on Exhibit A attached to the Motion.
3. This Court retains jurisdiction to interpret and enforce this Order.
November __ , 2012
THE HONORABLE CHRISTOPHER S. SONTCHI
UNITED STATES BANKRUPTCY JUDGE
2
CERTIFICATE OF SERVICE
I, William A. Hazeltine, do hereby certify I am not less than 18 years of age and that on
this 26th day of October 2012, I caused copies of the within Motion of the Official Committee of
Unsecured Creditors for an Order Under Rule 2004 of the Federal Rules of Bankruptcy
Procedure Authorizing Discovery from Yucaipa American Alliance Fund I, LP and Yucaipa
American Alliance (Parallel) Fund I, LP to be served upon the parties on the attached service list
in the manner indicated
October 26, 2012
Date
Is/ William A. Hazeltine
William A. Hazeltine
FEDERAL EXPRESS
Alcentral, Inc
Attn: Legal Department
10877 Willshire Blvd Suite 1550
Los Angeles, CA 90024
FACSIMILE
A venue Capital Group
Attn: Heather Kaiser
399 Park A venue, 6th Floor
New York, NY 10022
(212) 878-3545
FEDERAL EXPRESS
A VL Loan Funding, Inc.
Attn: Terry Conner-Graham
540 West Madison Street, Suite 1900-3N
Chicago, IL 60661
FEDERAL EXPRESS
Bank of America
Attn: Kathleen Ross
SVP, Senior Client Manager
135 South Lasalle Street
Chicago, IL 60603
FACSIMILE
Black Diamond Capital Management LLC
Attn: Richard Ehrlich
1 Sound Shore Drive, Suite 200
Greenwich, CT 06830
(203) 552-1012
FEDERAL EXPRESS
Blackrock
fka R3capital
Attn: Carly Wilson
55 East 52nd Street
New York, NY 10055
FEDERAL EXPRESS
BNSF Railway Company
Attn: Rachel Belue
2400 Western Center Blvd
Fort Worth, TX76131
FEDERAL EXPRESS
Cedarview Capital Management LP
Attn: Irving Bodner
One Penn Plaza, 45th Floor
New York, NY 10119
FACSIMILE
Central Pennsylvania Teamsters Pension
Fund
c/o Stevens & Lee, P.C.
Attn: Frank Sabatino/John Kilgannon
1818 Market St., 29th Floor
Philadelphia, P A 19103
(215) 851-0214
HAND DELIVERY
Central Pennsylvania Teamsters Pension
Fund
Attn: Maria Aprile Sawczuk
1105 North Market Street, 7th Floor
FACSIMILE
Central States Pension Fund
Attn: Robert A. Coco
Attn: Brad R. Berliner
Central States Law Dept.
9377 West Higgins Rd.
Rosemont, IL 60018-4938
(84 7) 518-9797
FACSIMILE
City of Memphis, Ellis County, Tarrant
County
Northwest ISD
c/o Linebarger Goggan Blair & Simpson,
LLP
Attn: Elizabeth Weller
2323 Bryan Street, Ste 1600
Dallas, TX 75201
(214) 754-7167
HAND DELIVERY
Connolly Gallagher LLP
Attn: Karen C. Bifferato
Christina M. Thompson
Attn: Kelly M. Conlan
The Brandywine Building
1000 West Street, 14th Floor
FACSIMILE
Credit Capital Investments
51 JFK Parkway, Third Floor
Short Hills, NJ 07078
(973) 315-3015
FACSIMILE
Credit-Suisse
Attn: Micheal Chaisanguanthum
Attn: Jill Guerrido/James Potesky
Attn: Michelle Wagner
1 Madison A venue, 9th Floor
New York, NY 10010
(212) 325-2000
FACSIMILE
Dallas County
c/o Linebarger Goggan Blair & Sampson,
LLP
Attn: Elizabeth Weller
2323 Bryan Street, Ste 1600
Dallas, TX 75201
(214) 754-7167
FACSIMILE
Delaware Secretary Of State
Division Of Corporations
Franchise Tax Division
PO Box 898
Dover, DE 19903
(302) 739-3811
FACSIMILE
Delaware State Treasury
Attn: Chip Flowers
820 Silver Lake Blvd., Suite 100
Dover, DE 19904
(302) 739-5635
FACSIMILE
Division OfUnemployment Ins.
Department Of Labor
4425 N. Market Street
(302) 761-6636
FEDERAL EXPRESS
Drum Special Situation Partners III LP
Attn: Joseph Russick
1 07 Elm Street, 1Oth Floor
Stamford, CT 06902
FEDERAL EXPRESS
Durham Asset Management LLC
c/o Duggan Asset Management LLC
60 East 42nd Street, Suite 840
New York, NY 10165
FEDERAL EXPRESS
Fidelity National Bank
Attn: Herb McCoy
Decatur Branch Manager
160 Clairemont Ave
Decatur, GA 30030
FACSIMILE
Florida Self-Insurers Guaranty Assoc. Inc.
c/o Williams Gautier Gwynn DeLoach &
Sorenson, P .A.
Attn: James E. Sorenson
PO Box 4128
Tallahassee, FL 32315-4128
(850) 386-3663
FACSIMILE
Ford Motor Company
c/o Miller Canfield
Attn: Jose J. Bartolomei, Esq.
1 01 N. Main Street, 7th Floor
Ann Arbor, MI 48104
(734) 747-7147
FACSIMILE
Ford Motor Company
c/o Miller Canfield
Attn: StephenS. LaPlante, Esq.
150 West Jefferson, Suite 2500
Detroit, MI 48226-4415
(313) 496-7500
FACSIMILE
Freight Drivers and Helpers Local
Union No. 557 Pension Fund
c/o Abato, Rubenstein and Abato, P.A.
Attn: Corey Bott/Meghan Marek
809 Gleneagles Court, Suite #320
Baltimore, MD 21286
(410) 321-1419
FACSIMILE
General Motors LLC
c/o Honigman Miller Schwartz and Cohn
LLP
Attn: Daniel W. Linna Jr., Esq.
2290 First National Building
660 Woodward Avenue, Suite 2290
Detroit, MI 48226
(313) 465-8000
FEDERAL EXPRESS
GSO Capital Partners, LLC
345 Park A venue, 34th Floor
New York, NY 10154
FACSIMILE
Honigman Miller Schwartz and Cohn LLP
Attn: Daniel W. Linna Jr., Esq.
Attn: Lawrence J. Murphy, Esq.
2290 First National Building
660 Woodward Avenue
Detroit, MI 48226-3506
(313) 465-8000
FIRST CLASS MAIL
Internal Revenue Service
PO Box 7346
Philadelphia, P A 19101-7346
FACSIMILE
International Business Machines Corp.
c/o Satterlee Stephens Burke & B u r ~ e LLP
Attn: Christopher R. Belmonte
Attn: Pamela A. Bosswick
230 Park Avenue, Suite #1130
New York, NY 10169
(212) 818-9606
FEDERAL EXPRESS
International Business Machines Corp.
Attn: Marie-Josee Dube
1360 Rene Levesque W., Suite 400
Montreal, QC H3G 2W6
Canada
FEDERAL EXPRESS
Iron Mountain Information Mgmt Inc.
Attn: Joseph Corrigan
745 Atlantic Avenue, lOth Floor
Boston, MA 02111
FEDERAL EXPRESS
JP Morgan Chase
Attn: Jessica Strange, Client Service Officer
1041 0 Highland Manor Drive
Floor 3, FL3-3317
Tampa, FL 33610
HAND DELIVERY
Landis Rath & Cobb LLP
Attn: Adam G. Landis, Esq.
Attn: Kerri K. Mumford, Esq.
919 Market Street, Suite 1800
FACSIMILE
Latham & Watkins LLP
Attn: Sara E. Barr, Esq.
233 South Wacker Drive, Suite 5800
Chicago, IL 60606
(312) 993-9767
FACSIMILE
Attn: Robert A. Klyman, Esq.
Attn: Glen B. Collyer, Esq.
Attn: Gregory 0. Lunt, Esq.
355 South Grand Avenue
Los Angeles, CA 90071-1560
(213) 891-8763
FACSIMILE
Attn: Melinda C. Franek
885 Third Avenue
New York, NY 10022
(212) 751-4864
HAND DELIVERY
LSREF2 Clover Property 6, LLC
c/o Gebhardt & Smith LLP
Attn: Lisa Bittle Tancredi
901 Market Street, Suite 451
FACSIMILE
Mayer Brown LLP
Attn: Craig E. Reimer, Esq.
71 South Wacker Drive
Chicago, IL 60606
(312) 7001-7711
FACSIMILE
McDonnell Investment Management LLC
Attn: Christian Champ
1515 W. 22nd Street, 12th Floor
Oak Brook, IL 60523
(630) 368-3977
FACSIMILE
McDonnell Loan Opportunity Ltd. . ..
Attn: Kathleen Zarn
1515 West 22nd Street, Suite 1200
Oak Brook, IL 60523
(630) 368-3977
FIRST CLASS MAIL
Missouri Department of Revenue
Bankruptcy Unit
Attn: Steven A. Ginther
PO Box 475
Jefferson City, MO 65105-0475
FACSIMILE
MJX Asset Management
Attn: Fred Taylor
12 East 49th Street, 29th Floor
New York, NY 10017
(212) 705-5390
FACSIMILE
Monarch Alternative Capital LP
Attn: Patrick Bartels
535 Madison Avenue
New York, NY 1 0022
(212) 554-1701
FACSIMILE
New England Teamsters & Trucking
Pension Fund
c/o Feinberg, Campbell & Zack, P.C.
Attn: Catherine M. Campbell, Esq.
177 Milk Street, Suite 300
Boston, MA 021 09
(617) 388-7070
FEDERAL EXPRESS
New York City Economic Development
Corporation
c/o Michael A. Cardozo
Corporation Counsel of the City ofNew
York
1 00 Church Street
New York, NY 10007
Attn: Zachary B. Kass, Esq.
FACSIMILE
North American Transaction Services-
NATS
c/o Roetzel & Andress, LP A
Attn: Patricia B. Fugee
One SeaGate, Suite 1700
Toledo, OH 43604
(419) 242-0316
FEDERAL EXPRESS
Office ofUnemployment Compensation Tax
Services
Department of Labor and Industry
Commonwealth of Pennsylvania
Attn: Joseph Kots
625 Cherry St, Room 203
Reading, P A 19602-1152
FEDERAL EXPRESS
Ore Hill Partners LLC
Attn: Johannes L Homan
452 Fifth A venue, 25th Floor
New York, NY 10018
FACSIMILE
Palacios ISD, Jackson County, & Harris
County
c/o Linebarger Goggan Blair & Sampson,
LLP
Attn: John P. Dillman
PO Box 3064
Houston, TX 77253-3064
(713) 844-3501
FACSIMILE
Par-Four Investment Management
Attn: Joe Matteo
Attn: Michael Bailey
50 Tice Boulevard
Woodcliff Lake, NJ 07677
(201) 573-7535
FEDERAL EXPRESS
Pension Benefit Guaranty Corporation
(PBGC)
Attn: Frank A. Anderson
Office of Chief Counsel
1200 K Street, N.W.
Washington, DC 20005-4026
FACSIMILE
Platinum Grove Contingent Capital
Master Fund
c/o Platinum Grove Asset Management, L.P.
287 Bowman Ave., 3rd Floor
Purchase, NY 10577
(914) 690-2118
HAND DELIVERY
Richards, Layton & Finger, P.A.
Attn: Mark D. Collins
Attn: Christopher M. Samis
One Rodney Square
920 King Street
FEDERAL EXPRESS
Ricoh USA Inc
dba Ikon Office Solutions
Recovery & Bankruptcy Group
Attn: Olivia Moody
3920 Arkwright Road, Suite 400
Macon, GA 31210
FACSIMILE
Schulte Roth & Zabel LLP
Attn: Adam C. Harris/Robert J. Ward
Attn: Victoria A. Lepore/David M. Hillman
919 Third A venue
New York, NY 10022
(212) 593-5955
FEDERAL EXPRESS
Scotia Bank
Attn: Homaira Rahimi
Attn: Rhonda Fairley
20 Queen Street West, 4th floor
Toronto, ON M5H 3R3
Canada
FACSIMILE
Scroggins & Williamson, P. C.
Attn: J. Robert Williamson
Attn: Ashley Reynolds Ray
1500 Candler Building
127 Peachtree Street, N.E.
Atlanta, GA 30303
(404) 893-3886
FACSIMILE
Secretary of the Treasury
Department of the Treasury
1500 Pennsylvania A venue, NW
Washington, DC 20220
(202) 622-6415
FACSIMILE
Securities & Exchange Commission
New York Regional Office
Attn: GeorgeS. Canellos, Regional Director
3 World Financial Center, Suite 400
New York, NY 10281-1022
(212) 336-1323
FEDERAL EXPRESS
Securities & Exchange Commission
1 00 F Street, NE
FACSIMILE
ShipCarsNow
Attn: Jeffrey J. Grandstaff
1400 Douglas St., MS 0430
Omaha, NE 68179
(402) 501-2609
FACSIMILE
Sidley Austin LLP
Attn: Matthew Clemente
Chicago, IL 60603
(312) 853-7036
FACSIMILE
Sidley Austin LLP
Attn: Michael G. Burke
Attn: Brian J. Lohan
Attn: Dennis Kao
787 Seventh Avenue
New York, NY 10019
(212) 839-5599
FACSIMILE
Spectrum Group Management LLC
Attn: Jeffrey Buller
Attn: Jeffrey Schaffer
Attn: Stephen Jacobs
1250 Broadway, Suite 810
New York, NY 10001
(212) 983-2322
FACSIMILE
Spectrum Investment Partners LP
Attn: Jeffrey Schaffer
1250 Broadway, 19th Floor
New York, NY 10001
(212) 983-2322
FACSIMILE
Stanfield Capital Partners
430 Park Avenue, 12th Floor
New York, NY 10022
(212) 891-9620
HAND DELIVERY
State of Delaware
Division Of Revenue
Carvel State Office Building
820 North French Street
Wilmington, DE 1980
FACSIMILE
Teamsters Joint Council No. 83
of Virginia Pension Fund
c/o Beins Axelrod, P.C.
Attn: H. David Kelly, Jr.
1625 Massachusetts Ave, N.W., Suite 500
(202) 328-7030
FACSIMILE
Teamsters Pension Trust Fund
of Philadelphia & Vicinity
Attn: Frank Sabatino/John Kilgannon
1818 Market St., 29th Floor
Philadelphia, P A 19103
(215) 851-0214
HAND DELIVERY
Teamsters Pension Trust Fund
of Philadelphia & Vicinity
Attn: Maria Aprile Sawczuk
1105 North Market Street, 7th Floor
FACSIMILE
Tennessee Deparment of Labor &
Workforce Dev-Unemployment Insurance
c/o TN Attorney General Office
Bankruptcy Division
PO Box 20207
Nashville, TN 37202
(615) 741-2009
FEDERAL EXPRESS
The Bank ofNew York Mellon
Attn: Melinda Valentine
600 East Las Colinas, Suite #1300
Irving, TX 75039
FACSIMILE
The CIT Group/Business Credit, Inc.
c/o Fried, Frank, Harris, Shriver & Jacobson
LLP
Attn: Gary L. Kaplan/Carl I. Stapen
One New York Plaza
New York, NY 10004
(212) 859-4800
HAND DELIVERY
The CIT Group/Business Credit, Inc.
c/o Duane Morris LLP
Attn: Richard W. Riley/Sommer L. Ross
222 Delaware A venue, Suite 1600
Wilmington, DE 19801-1659
FACSIMILE
The Yucaipa Companies
Attn: Derex Walker
9130 West Sunset Boulevard
(310) 789-1791
FACSIMILE
TNATINC
c/o Cohen, Weiss & Simon
Attn: Richard Seltzer
330 West 42nd Street
New York, NY 10036-6901
(212) 695-5436
HAND DELIVERY
TNATINC
c/o Cooch & Taylor, P.A.
Attn: Susan E. Kaufman
1 000 West Street, 1Oth Floor
Brandywine Bldg, PO Box 1680
FACSIMILE
TNATINC
c/o Batiste & Wilder
Attn: James F. Wallington
1150 Connecticut Ave., N.W.
Suite 500
(202) 223-9677
FACSIMILE
TNATINC
c/o International Brotherhood of Teamsters
Attn: Edward Gleason
25 Louisiana Avenue, N.W.
(202) 624-6884
FACSIMILE
Troutman Sanders LLP
Attn: Jeffrey W. Cavender
Attn: Ezra Cohen
600 Peachtree Street, NE Suite 5200
Atlanta, GA 30308-2216
(404) 885-3900
HAND DELIVERY
U.S. Attorney's Office
PO Box 2046
1201 Market St., Ste. 1100
FEDERAL EXPRESS
Union Pacific Railroad Company
Attn: Mary Ann Kilgore, Shawn Lanka
1400 Douglas St., MS 1580
Omaha, NE 681 79
HAND DELIVERY
United States Trustee
844 King Street, Suite 2207
Lockbox #35
HAND DELIVERY
United States Trustee
Attn: David L. Buchbinder
J. Caleb Boggs Federal Building
Suite 2207
FACSIMILE
Yenor Capital Management LP
Attn: Michael Scott
7 Times Square, Suite 3505
New York, NY 10036
(202) 703-2111
FACSIMILE
Western Conf. ofTeamsters Pension Trust
Fund
c/o Reid, Pedersen, McCarthy & Ballew
LLP
Attn: Russell J. Reid
1 00 West Harrison Street
North Tower, Suite 300
Seattle, W A 98119
(206) 285-8925
HAND DELIVERY
Young Conaway Stargatt & Taylor
Attn: Michael R. Nestor
Rodney Square
1000 North King Street
FACSIMILE
Yucaipa American Alliance (Parallel) Fund
I, LP
Yucaipa American Alliance Fund I, LP
Attn: Robert Bermingham
9130 W. Sunset Blvd.
(310) 789-1791
FACSIMILE
Com Vest Investment Partners III, L.P. and
Com Vest III Partners, LLC
c/o Jones, Foster, Johnson & Stubbs, PA
Attn: Robert Wilkins
Flagler Center Tower
505 South Flagler Drive, Suite 1100
West Palm Beach, FL 33401
(561) 650-5300

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