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Full title: Certificate Requesting That Motions Be Granted as Unopposed (Filed By Cemetery Road Hunt Club, Inc., Dianna Mowry, Rodney Mowry, Charlotte E. Place, Jesse C. Place, Richard E. Place, Charlotte E. Place Trust, Richard E. Place Trust, Placewood Resource Management, LLC, Placewood Resources, L.P., R&J Partners, L.P., William R Ruark, William R. Ruark, Herbert D. Steele, Leola B. Steele, The 5 Family LP, Tim & Terri Family LP, Terri Denise Tyler, Timothy A Tyler, Tyler/Mowry Lessors ).(Related document(s):[3348] Motion to Compel, [3359] Motion to Abstain) (Attachments: # (1) Exhibit A # (2) Exhibit B # (3) Proposed Order # (4) Proposed Order) (Helfer, Arleigh)

Document posted on Jan 13, 2022 in the bankruptcy, 3 pages and 0 tables.

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On March 29, 2021, the Pennsylvania Lessors filed a motion to compel arbitration or, in the alternative, for permissive abstention.The notice of the January 18, 2022 hearing, submitted by Debtors’ counsel, is attached as Exhibit A. 1 The Moving Parties are Tim & Terri Tyler Family LP; Tyler 5 FLP; Timothy & Terri Tyler; and Rodney & Dianna Mowry (the “Tyler/Mowry Movants”) and William R. Ruark and WLR Family Partnership; Sally Steele, Esquire, Herbert D. Steele and Leola B. Steele; Raynold W. Wilson, Judith A. Wilson, R&J Partners, L.P. and Cemetery Road Hunt Club, Inc.; Placewood Resource Management, L.L.C., Placewood Resources, L.P., Richard E. Place, Charlotte E. Place, the Richard E. Place Trust, the Charlotte E. Place Trust and Jesse C. Place (the “Pennsylvania Lessors”).The Moving Parties granted one extension of time for Chesapeake to file a response to the Motions, and that deadline expired July 16, 2021. See May 29, 2021 email from A. Helfer to E. Clark, attached as Exhibit B. 6. WHEREFORE, Moving Parties respectfully request that the Court enter the proposed orders granting the Motions as unopposed.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION In re: ) ) Chapter 11 CHESAPEAKE ENERGY ) CORPORATION, et al., ) Case No. 20-33233 (DRJ) ) Debtors. ) Jointly Administered PENNSYLVANIA MOVING PARTIES’1 REQUEST THAT MOTIONS BE GRANTED AS UNOPPOSED The Moving Parties hereby request that the Court enter the attached proposed orders granting their motions. In support of their request, the Pennsylvania Proof of Claim Lessors state as follows: 1. On March 29, 2021, the Pennsylvania Lessors filed a motion to compel arbitration or, in the alternative, for permissive abstention. ECF No. 3348. 2. On March 30, 2021, the Tyler/Mowry Movants filed a motion for permissive abstention. ECF No. 3359. 3. The hearing date on the Motions has been continued a number of times. The hearing is presently set for January 18, 2022. 4. The notice of the January 18, 2022 hearing, submitted by Debtors’ counsel, is attached as Exhibit A. 1 The Moving Parties are Tim & Terri Tyler Family LP; Tyler 5 FLP; Timothy & Terri Tyler; and Rodney & Dianna Mowry (the “Tyler/Mowry Movants”) and William R. Ruark and WLR Family Partnership; Sally Steele, Esquire, Herbert D. Steele and Leola B. Steele; Raynold W. Wilson, Judith A. Wilson, R&J Partners, L.P. and Cemetery Road Hunt Club, Inc.; Placewood Resource Management, L.L.C., Placewood Resources, L.P., Richard E. Place, Charlotte E. Place, the Richard E. Place Trust, the Charlotte E. Place Trust and Jesse C. Place (the “Pennsylvania Lessors”).

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5. The Moving Parties granted one extension of time for Chesapeake to file a response to the Motions, and that deadline expired July 16, 2021. See May 29, 2021 email from A. Helfer to E. Clark, attached as Exhibit B. 6. Chesapeake never sought another extension of time to file a response to the Motions. 7. The Motions included a standard-form cautionary notice. That notice states: IF YOU OPPOSE THE MOTION, YOU SHOULD IMMEDIATELY CONTACT THE MOVING PARTY TO RESOLVE THE DISPUTE. IF YOU AND THE MOVING PARTY CANNOT AGREE, YOU MUST FILE A RESPONSE AND SEND A COPY TO THE MOVING PARTY. YOU MUST FILE AND SERVE YOUR RESPONSE WITHIN 21 DAYS OF THE DATE THIS WAS SERVED ON YOU. YOUR RESPONSE MUST STATE WHY THE MOTION SHOULD NOT BE GRANTED. IF YOU DO NOT FILE A TIMELY RESPONSE, THE RELIEF MAY BE GRANTED WITHOUT FURTHER NOTICE TO YOU. 8. Debtors failed to file opposition to the Motions. Moving Parties have reviewed the docket and have not located any opposition to the pending motions. 9. On January 14, 2022, Debtors submitted a witness and exhibit list, but Debtors’ submission lists no witnesses or exhibits. 10. Debtors’ witness and exhibit list does not state any reason why the Motions should not be granted. WHEREFORE, Moving Parties respectfully request that the Court enter the proposed orders granting the Motions as unopposed. Dated: January 14, 2022 SCHNADER HARRISON SEGAL & LEWIS LLP

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By: /s/ Arleigh P. Helfer III Ira N. Richards (admitted pro hac vice) Richard A. Barkasy (admitted pro hac vice) Arleigh Helfer (admitted pro hac vice) Schnader Harrison Segal & Lewis LLP 1600 Market Street, Suite 3600 Philadelphia, PA 19103-7286 Telephone: (215) 751-2000 Facsimile: (215) 751-2205 irichards@schnader.com rbarkasy@schnader.com ahelfer@schnader.com

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