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Full title: Response to (related document:[933] Motion to Extend Time For Other Reason re:The Debtor May Remove Actions Pursuant to 28 U.S.C. § 1452 and Rule 9027 of the Federal Rules of Bankruptcy Procedure Filed by Paul R. DeFilippo on behalf of LTL Management LLC. Hearing scheduled for 1/11/2022 at 10:00 AM at MBK - Courtroom 8, Trenton. (Attachments: # 1 Debtor's Motion for Entry of an Order Extending the Period within which the Debtor May Remove Actions Pursuant to 28 U.S.C. § 1452 and Rule 9027 of the Federal Rules of Bankruptcy Procedure # 2 Proposed Order) filed by Debtor LTL Management LLC) filed by Arthur Abramowitz on behalf of Official Committee of Talc Claimants II. (Abramowitz, Arthur)

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

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Cullen D. Speckhart (pro hac vice to be filed) 105 Thomas Jefferson St. NW, Suite 540 Michael Klein (pro hac vice to be filed) notice@waldrepwall.com Proposed Co-Counsel to the Proposed Co-Counsel to the Official Committee of Official Committee of Talc Claimants II Talc Claimants II SHERMAN, SILVERSTEIN, KOHL, ROSE & PODOLSKY, P.A. The Official Committee of Talc Claimants II (the “Mesothelioma Claimants’ Committee”)1 of LTL Management LLC, the debtor and debtor-in-possession (the “Debtor”) in the above-captioned case (the “Case”), respectfully submits this Reservation of Rights in connection with the Debtor’s Motion for Entry of an Order Extending the Period Within which the Debtor May Remove Actions Pursuant to 28 U.S.C. § 1452 and Rule 9027 of the Federal Rules of Bankruptcy Procedure [Docket No. 933]On December 23, 2021, the United States Trustee for Region 3 filed the Notice of the United States Trustee’s Filing of Reconstituted and Amended: (i) Notice of Appointment of Official Committee of Talc Claimants I; and (ii) Notice of Appointment of Official Committee ofThe Mesothelioma Claimants’ Committee expressly reserves all rights, arguments and objections, including the right to contest and be heard in connection with any (a) future request by the Debtor or its non-Debtor affiliates for a further extension of the Removal Period, (b) request to extend the removal period for non-Debtors, (c) action by the Debtor or any non-Debtor to remove any talc related litigation pursuant to 28 U.S.C. § 1452 and the Bankruptcy Rules, and (d) other action or proceeding in connection with this Motion.

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UNITED STATES BANKRUPTCY COURT DISTRICT OF NEW JERSEY Caption in Compliance with D.N.J. LBR 9004-1(b) BAILEY GLASSER LLP Brian A. Glasser (admitted pro hac vice) COOLEY LLP Thomas B. Bennett (admitted pro hac vice) Cullen D. Speckhart (pro hac vice to be filed) 105 Thomas Jefferson St. NW, Suite 540 Michael Klein (pro hac vice to be filed) Washington, DC 20007 Erica J. Richards (pro hac vice to be filed) Tel: (202) 463-2101 Lauren A. Reichardt (pro hac vice to be filed) Fax: (202) 463-2103 Evan M. Lazerowitz Email: bglasser@baileyglasser.com 55 Hudson Yards tbennett@baileyglasser.com New York, NY 10001 Tel: (212) 479-6000 Proposed Co-Counsel to the Fax: (212) 479-6275 Official Committee of Talc Claimants II Email: cspeckhart@cooley.com mklein@cooley.com erichards@cooley.com lreichardt@cooley.com elazerowitz@cooley.com Proposed Co-Counsel to the Official Committee of Talc Claimants II WALDREP WALL BABCOCK & BAILEY MASSEY & GAIL LLP PLLC Jonathan S. Massey (admitted pro hac vice) Thomas W. Waldrep, Jr. (admitted pro hac vice) 100 Main Ave. SW, Suite 450 370 Knollwood Street, Suite 600 Washington, DC 20024 Winston-Salem, NC 27103 Tel: (202) 652-4511 Tel: (336) 717-1280 Fax: (312) 379-0467 Fax: (336) 717-1340 Email: jmassey@masseygail.com Email: notice@waldrepwall.com Proposed Co-Counsel to the Proposed Co-Counsel to the Official Committee of Official Committee of Talc Claimants II Talc Claimants II SHERMAN, SILVERSTEIN, KOHL, ROSE & PODOLSKY, P.A. Arthur J. Abramowitz Alan I. Moldoff Ross J. Switkes 308 Harper Drive, Suite 200 Moorestown, NJ 08057 Tel: (856) 662-0700 Email: aabramowitz@shermansilverstein.com amoldoff@shermansivlerstein.com rswitkes@shermansilverstein.com Proposed Local Counsel to the Official Committee of Talc Claimants II

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In re: Chapter 11 LTL MANAGEMENT LLC, Case No.: 21-30589 (MBK) Debtor. Honorable Michael B. Kaplan Ref. Docket No. 933 RESERVATION OF RIGHTS OF OFFICIAL COMMITTEE OF TALC CLAIMANTS II TO DEBTOR’S MOTION FOR ENTRY OF AN ORDER EXTENDING THE PERIOD WITHIN WHICH THE DEBTOR MAY REMOVE ACTIONS PURSUANT TO 28 U.S.C. § 1452 AND RULE 9027 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE The Official Committee of Talc Claimants II (the “Mesothelioma Claimants’ Committee”)1 of LTL Management LLC, the debtor and debtor-in-possession (the “Debtor”) in the above-captioned case (the “Case”), respectfully submits this Reservation of Rights in connection with the Debtor’s Motion for Entry of an Order Extending the Period Within which the Debtor May Remove Actions Pursuant to 28 U.S.C. § 1452 and Rule 9027 of the Federal Rules of Bankruptcy Procedure [Docket No. 933] (the “Motion”) and respectfully states as follows: RESERVATION OF RIGHTS2 The Mesothelioma Claimants’ Committee does not object to the Debtor’s initial request for an extension of the Removal Period through July 11, 2022 and takes no position at this time on whether any specific pending actions should be removed. However, the Mesothelioma Claimants’ Committee does not consent to the extension of any applicable removal period for non-Debtors, and notes that the proposed order only extends the Debtor’s Removal Period. 1 On November 8, 2021, prior to transferring venue of the Case to this Court, the United States Bankruptcy Court for the Western District of North Carolina entered an order appointing the Official Committee of Talc Claimants (the “Original Committee”) [Docket No. 355]. On December 23, 2021, the United States Trustee for Region 3 filed the Notice of the United States Trustee’s Filing of Reconstituted and Amended: (i) Notice of Appointment of Official Committee of Talc Claimants I; and (ii) Notice of Appointment of Official Committee of Talc Claimants II [Docket No. 965], effectively dividing the membership of the Original Committee into two committees and appointing additional members to each such committee. 2 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Motion.

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The Mesothelioma Claimants’ Committee expressly reserves all rights, arguments and objections, including the right to contest and be heard in connection with any (a) future request by the Debtor or its non-Debtor affiliates for a further extension of the Removal Period, (b) request to extend the removal period for non-Debtors, (c) action by the Debtor or any non-Debtor to remove any talc related litigation pursuant to 28 U.S.C. § 1452 and the Bankruptcy Rules, and (d) other action or proceeding in connection with this Motion. Date: January 4, 2022 Respectfully submitted, SHERMAN, SILVERSTEIN, KOHL, ROSE & PODOLSKY, P.A. By: /s/ Arthur J. Abramowitz Arthur J. Abramowitz Ross J. Switkes Sherman, Silverstein, Kohl, Rose & Podolsky, P.A. 308 Harper Drive, Suite 200 Moorestown, NJ 08057 Tel: (856) 662-0700 aabramowitz@shermansilverstein.com rswitkes@shermansilverstein.com Proposed Local Counsel to the Official Committee of Talc Claimants II

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