HTML Document View

Full title: Counter Designation (appellee) / Plan Administrator-Appellee's Counter-Designation of Additional Items to be Included in the Record on Appeal (related document(s)[2726], [3703]) filed by Richard W. Slack on behalf of Ditech Holding Corporation. (Slack, Richard)

Document posted on Sep 22, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Sunny Singh Richard W. Slack Attorneys for Plan Administrator ADDITIONAL ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL Appellee, the Plan Administrator for the Wind Down Estates of Ditech Holding Corporation (f/k/a Walter Investment Management Corp.) and its debtor affiliates (excluding Reorganized RMS) (collectively, the “Wind Down Estates”) hereby designates, pursuant to Rule 8009(a)(2) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the following additional items to be included in the record on appeal.The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, as applicable, are Ditech Holding Corporation (0486); DF Insurance Agency LLC (6918); Ditech Financial LLC (5868); Green Tree Credit LLC (5864); Green Tree Credit Solutions LLC (1565); Green Tree Insurance Agency of Nevada, Inc. (7331); Green Tree Investment Holdings III LLC (1008); Green Tree Servicing Corp. Servicing LLC (6101); Mortgage Asset Systems, LLC (8148); REO Management Solutions, LLC (7787); Reverse Mortgage Solutions, Inc. (2274); Walter Management Holding Company LLC (9818); and Walter Reverse Acquisition LLC (8837).Although the Plan Administrator disagrees with the statement of issues identified by Desmond-Roy Demontegnac and Sophia-Elaine Demontegnac (the “Appellants”), the Plan Administrator has not re-stated the issues because Rule 8009 of the Bankruptcy Rules does not provide for the filing of Appellee’s statement of the issues absent a cross-appeal.

List of Tables

Document Contents

WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Ray C. Schrock, P.C. Sunny Singh Richard W. Slack Attorneys for Plan Administrator UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------- X : In re : Chapter 11 : DITECH HOLDING CORPORATION, et al., : Case No. 19-10412 (JLG) : Debtors.1 : (Jointly Administered) : --------------------------------------------------------------- X PLAN ADMINISTRATOR-APPELLEE’S COUNTER-DESIGNATION OF ADDITIONAL ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL Appellee, the Plan Administrator for the Wind Down Estates of Ditech Holding Corporation (f/k/a Walter Investment Management Corp.) and its debtor affiliates (excluding Reorganized RMS) (collectively, the “Wind Down Estates”) hereby designates, pursuant to Rule 8009(a)(2) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), the following additional items to be included in the record on appeal. 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification number, as applicable, are Ditech Holding Corporation (0486); DF Insurance Agency LLC (6918); Ditech Financial LLC (5868); Green Tree Credit LLC (5864); Green Tree Credit Solutions LLC (1565); Green Tree Insurance Agency of Nevada, Inc. (7331); Green Tree Investment Holdings III LLC (1008); Green Tree Servicing Corp. (3552); Marix Servicing LLC (6101); Mortgage Asset Systems, LLC (8148); REO Management Solutions, LLC (7787); Reverse Mortgage Solutions, Inc. (2274); Walter Management Holding Company LLC (9818); and Walter Reverse Acquisition LLC (8837). The Wind Down Estates’ principal offices are located at 2600 South Shore Blvd., Suite 300, League City, TX 77573.

1

Although the Plan Administrator disagrees with the statement of issues identified by Desmond-Roy Demontegnac and Sophia-Elaine Demontegnac (the “Appellants”), the Plan Administrator has not re-stated the issues because Rule 8009 of the Bankruptcy Rules does not provide for the filing of Appellee’s statement of the issues absent a cross-appeal. The Plan Administrator, therefore, reserves its right to re-state the issues on appeal in its brief. COUNTER-DESIGNATION OF RECORD The Plan Administrator does not re-designate any items that it may rely upon that have already been designated by the Appellants in their designation of record (ECF No. 3) but, rather, will rely on the Appellants’ designations. Appellants specifically enumerated some exhibits and attachments, but not others. See, e.g., id. at Designation No. 2. For the avoidance of doubt, for the filings designated by either the Plan Administrator or the Appellants, the Plan Administrator treats the designations as including all exhibits and attachments to such filings, whether listed or not by either the Plan Administrator or the Appellants. Moreover, while the Plan Administrator does not, at this time, object to any items designated by the Appellants, the Plan Administrator does not concede the relevance of any such items. [Remainder of page intentionally left blank.]

2

Designation ECF Date of Filing Description Number Number 1. 1326 09/22/2019 Third Amended Joint Chapter 11 Plan of Ditech Holding Corporation and Its Affiliated Debtors 2. 1404 09/26/2019 Order signed on 9/26/2019 Confirming Third Amended Chapter 11 Plan 3. 1743 01/17/2020 Eleventh Omnibus Objection to Proofs of Claim (No Basis Consumer Creditor Claims) Dated: September 23, 2021 New York, New York /s/ Richard W. Slack WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, New York 10153 Telephone: (212) 310-8000 Facsimile: (212) 310-8007 Ray C. Schrock, P.C. Sunny Singh Richard W. Slack David F. Hill, IV Attorneys for Plan Administrator

3