HTML Document View

Full title: Notice of Appearance and Request for Notice Filed by David Robert Eastlake Filed by on behalf of Conway MacKenzie Management Services, LLC (Eastlake, David) (Entered: 04/14/2021)

Document posted on Apr 13, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

In re: § Chapter 11 § CJ HOLDING CO., et al., § CaseJoint Plan of Reorganization (As Modified) of CJ Holding Company, et al., Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 1057], hereby enters its appearance (this “Notice of Appearance”) by and through its new counsel, Baker Botts L.L.P., pursuant to 11 U.S.C. § 1109(b) and Rule 9010(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”); and such counsel hereby requests, pursuant to Bankruptcy Rules 2002, 3017, and 9007 and 11 U.S.C. §§ 342 and 1109(b), that copies of all notices and pleadings given or filed in the above-captioned chapter 11 cases be given and served upon: David R. Eastlake Texas State Bar.PLEASE TAKE FURTHER NOTICE that this request includes not only the notices and papers referred to in the Bankruptcy Rules and title 11 of the United States Code (the “Bankruptcy Code”) but also includes, without limitation, the schedules, statement of financial affairs, operating reports, pleadings, motions, applications, complaints, demands, hearings, requests or pleadings, and disclosure statement, any letter, objections, answering or reply papers, memoranda and briefs in support of any of the foregoing and any other document brought before this Court with respect to this proceeding, whether formal or informal, whether written or oral, and whether transmitted or conveyed by mail, delivery, electronic mail, telephone, telegraph, telex or otherwise filed or delivered to the clerk, court or judge in connection with and with regard to these cases and any proceeding related thereto. PLEASE TAKE FURTHER NOTICE that neither this Notice of Appearance nor any prior or later appearance, pleading, claim, or suit shall waive any right of the Unsecured Claims Representative to (a) have final orders in non-core matters entered only after de novoreview by a District Court judge, (b) trial by jury in a proceeding so triable in these cases or any case, controversy, or proceeding related to these cases, (c) have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal, or (d) any objection to the jurisdiction of the Bankruptcy Court for any purpose, (e) any election of remedy, or (f) any rights, claims, actions and/or defenses, in law, in equity, or otherwise, all of which such rights, claims, actions and/or defenses, are expressly preserved and reserved.David R. Eastlake David R. Eastlake Texas State Bar No. 24074165 david.eastlake@bakerbotts.com 900 Louisiana Street Houston, Texas 77002

List of Tables

Document Contents

IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: § Chapter 11 § CJ HOLDING CO., et al., § Case No. 16-33590 § Reorganized Debtors. § (Jointly Administered) NOTICE OF APPEARANCE AND REQUEST FOR SERVICE OF NOTICES, PLEADINGS, AND ORDERS PLEASE TAKE NOTICE that Conway MacKenzie Management Services, LLC, solely in its capacity as the Unsecured Claims Representative (the “Unsecured Claims Representative”) appointed pursuant to that certain Second Amended Joint Plan of Reorganization (As Modified) of CJ Holding Company, et al., Pursuant to Chapter 11 of the Bankruptcy Code [Docket No. 1057], hereby enters its appearance (this “Notice of Appearance”) by and through its new counsel, Baker Botts L.L.P., pursuant to 11 U.S.C. § 1109(b) and Rule 9010(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”); and such counsel hereby requests, pursuant to Bankruptcy Rules 2002, 3017, and 9007 and 11 U.S.C. §§ 342 and 1109(b), that copies of all notices and pleadings given or filed in the above-captioned chapter 11 cases be given and served upon: David R. Eastlake Texas State Bar. No. 24074165 BAKER BOTTS L.L.P. 900 Louisiana Street Houston, Texas 77002 Tel: 713-229-1397 Fax: 713-229-7897 david.eastlake@bakerbotts.com PLEASE TAKE FURTHER NOTICE that this request includes not only the notices and papers referred to in the Bankruptcy Rules and title 11 of the United States Code (the

1

“Bankruptcy Code”) but also includes, without limitation, the schedules, statement of financial affairs, operating reports, pleadings, motions, applications, complaints, demands, hearings, requests or pleadings, and disclosure statement, any letter, objections, answering or reply papers, memoranda and briefs in support of any of the foregoing and any other document brought before this Court with respect to this proceeding, whether formal or informal, whether written or oral, and whether transmitted or conveyed by mail, delivery, electronic mail, telephone, telegraph, telex or otherwise filed or delivered to the clerk, court or judge in connection with and with regard to these cases and any proceeding related thereto. PLEASE TAKE FURTHER NOTICE that neither this Notice of Appearance nor any prior or later appearance, pleading, claim, or suit shall waive any right of the Unsecured Claims Representative to (a) have final orders in non-core matters entered only after de novoreview by a District Court judge, (b) trial by jury in a proceeding so triable in these cases or any case, controversy, or proceeding related to these cases, (c) have the District Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal, or (d) any objection to the jurisdiction of the Bankruptcy Court for any purpose, (e) any election of remedy, or (f) any rights, claims, actions and/or defenses, in law, in equity, or otherwise, all of which such rights, claims, actions and/or defenses, are expressly preserved and reserved. [Remainder of Page Intentionally Left Blank]

2

Dated: April 14, 2021. Houston, Texas Respectfully submitted, BAKER BOTTS,L.L.P. By: /s/ David R. Eastlake David R. Eastlake Texas State Bar No. 24074165 david.eastlake@bakerbotts.com 900 Louisiana Street Houston, Texas 77002 Telephone: (713) 229-1397 Facsimile: (713) 229-7897 Counsel for Conway MacKenzie Management Services, LLC, solely in its capacity as the Unsecured Claims Representative CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served electronically upon those parties registered to receive electronic notice via the Court’s CM/ECF system on this 14th day of April, 2021. /s/ David R. Eastlake David R. Eastlake

3