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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)[3769], [3754]) filed by Richard W. Slack on behalf of Ditech Holding Corporation. (Slack, Richard)

Document posted on Nov 30, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

ADDITIONAL ITEMS TO BE INCLUDED IN THE RECORD ON APPEAL Appellee, the Plan Administrator, on behalf 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 Wind Down Estates disagree with the statement of issues identified by Finance of America Reverse LLC (the “Appellant”), the Wind Down Estates have not re-stated the issues because Rule 8009 of the Bankruptcy Rules does not provide for the filing of an Appellee’s statement of the issues absent a cross-appeal.Number Number 1. 2 02/11/2019 Declaration of Gerald A. Lombardo Pursuant to Rule 1007-2 of Local Bankruptcy Rules for Southern District of New York 2.

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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, on behalf 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.

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Although the Wind Down Estates disagree with the statement of issues identified by Finance of America Reverse LLC (the “Appellant”), the Wind Down Estates have not re-stated the issues because Rule 8009 of the Bankruptcy Rules does not provide for the filing of an Appellee’s statement of the issues absent a cross-appeal. The Wind Down Estates, therefore, reserve their right to re-state the issues on appeal in their brief. The Wind Down Estates also reserve the right to supplement, amend or modify its record designations as appropriate. COUNTER-DESIGNATION OF RECORD The Wind Down Estates do not re-designate any items that it may rely upon that have already been designated by the Appellant in its designation of record (ECF No. 3769) but, rather, will rely on the Appellant’s designations. For the avoidance of doubt, for the filings designated by either the Wind Down Estates or the Appellant, the Wind Down Estates consider the designations to include all exhibits and attachments to such filings, whether separately listed or not by either the Wind Down Estates or the Appellant. Moreover, the Wind Down Estates do not concede the relevance of any items designated by the Appellant. [Remainder of page intentionally left blank.]

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Designation ECF Date of Filing Description Number Number 1. 2 02/11/2019 Declaration of Gerald A. Lombardo Pursuant to Rule 1007-2 of Local Bankruptcy Rules for Southern District of New York 2. 90 02/22/2019 Order Establishing Deadline for Filing Proofs of Claim and Approving the Form and Manner of Notice Thereof 3. 496 05/02/2019 Order Further Extending General Bar Date for Filing Proofs of Claim for Consumer Borrowers Nunc Pro Tunc 4. 543 05/10/2019 Amended Disclosure Statement for Amended Joint Chapter 11 Plan of Ditech Holding Corporation and Its Affiliated Debtors 5. 2940 11/02/2020 Transcript of Hearing Held on 10-29-2020 6. 3034 11/11/2020 Memorandum Decision and Order Granting Plan Administrator's Sixth Omnibus Motion to Enforce the Plan Injunction and Confirmation Order as It Relates to Gautam and Panthobi Sharma Dated: December 1, 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

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