2024-08-13 Interim Order - Cert of CounselIN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
Case No. 24-11647 MFW
(Jointly Administered)
In re:
SilverRock Development LLC, et al.,
Debtors)
CERTIFICATION OF COUNSEL REGARDING
INTERIM ORDER (I) AUTHORIZING THE MAINTENANCE OF BANK ACCOUNTS
AND CONTINUED USE OF EXISTING BUSINESS FORMS AND CHECKS, (II)
GRANTING LIMITED RELIEF FROM THE REQUIREMENTS OF BANKRUPTCY
CODE SECTION 345(B)t AND aIm GRANTING RELATED RELIEF
The undersigned counsel to Debtors in the above captioned chapter 11 case hereby certifies
as follows:
1. On August 12, 2024, Debtors filed the Motion of the Debtors for Entry of Interim
and Final Orders (I) Authorizing the Maintenance of Bank Accounts and Continued Use of
Existing Business Forms and Checks, (II) Granting Limited Relief from the Requirements of
Bankruptcy Code Section 345(b), and (III) Granting Related Relief (the "Motion") [D.I. 8] (the
"Motion).2 The Motion included a proposed order approving the Motion on an interim basis (the
"Proposed Interim Order"). Following consultation with the United States Trustee, the Debtors
made certain revisions to the Proposed Interim Order.
2. A copy of the Proposed Interim Order incorporating revisions set forth above is
attached hereto as Exhibit A and, for the convenience of the Court and other interested parties, a
blackline comparing the revised Proposed Order against the version filed with the Motion is
The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification
number, as applicable, are: SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996),
SilverRock Lifestyle Residences, LLC (0721), SilverRock Lodging, LLC (4493), SilverRock Luxury Residences,
LLC (6598) and SilverRock Phase I, LLC (2247). The location of the Debtors' principal place of business and the
Debtors' mailing address is 343 Fourth Avenue, San Diego, CA 92101.
2 Capitalized terms used herein, but not otherwise defined, have the meanings given them in the Motion.
attached hereto as Exhibit B. To the extent the Court has any questions or concerns, Debtor
requests in the alternative that counsel be afforded an opportunity to address those questions and
concerns at the hearing currently scheduled for September 11, 2024, at 2:00 p.m. (ET) (the
"Hearing").
WHEREFORE, Debtor respectfully requests that the Court enter the revised Proposed
Interim Order at its earliest convenience or, alternatively consider the Motion and the additional
relief requested at the Hearing.
Dated: August 13, 2024 Respectfully submitted,
Wilmington, Delaware
ARMSTRONG TEASDALE, LLP
/s/Jonathan M. Stemerman
Jonathan M. Stemerman (No. 4510)
Eric M. Sutty (No. 4007)
Denisse Guevara (No. 7206)
1007 North Market Street, Third Floor
Wilmington, Delaware 19801
Telephone: (302) 416-9670
jstemerman@atllp.com
esutty@atllp.com
dguevara@atllp.com
Proposed Counsel to the Debtors
2
EXHIBIT A
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re
SilverRock Development Company., et al.1
Debtors.
Chapter 11
Case No. 24-11647 MFW
(Jointly Administered)
RE: Docket No. 8
INTERIM ORDER (I) AUTHORIZING THE MAINTENANCE OF BANK ACCOUNTS
AND CONTINUED USE OF EXISTING BUSINESS FORMS AND CHECKS, (H)
GRANTING LIMITED RELIEF FROM THE REQUIREMENTS OF BANKRUPTCY CODE
SECTION 345(B), AND (IIII) GRANTING RELATED RELIEF
Upon the Motion of the Debtors for Entry of Interim and Final Orders (I) Authorizing the
Maintenance of Bank Accounts and Continued Use of Existing Business Forms and Checks, (II)
Granting Limited Relief from the Requirements of Bankruptcy Code Section 345(b), and (III)
Granting Related Relief (the "Motion");2 and upon the Declaration of Robert S. Green Jr.
Pursuant to 28 U.S.C. § 1746 in Support of the Debtors' Chapter 11 Petitions and First
Day Pleadings (the "First Day Declaration"); and the Court finding that: (a) the Court has
jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing Order of
Reference from the United States District Court for the District of Delaware dated February 29, 2012; (b)
this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); (c) the Court having found that venue of this
proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and (d) the
Court may enter a final order consistent with Article III of the United States Constitution;
The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification number,
as applicable, are: SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996), SilverRock Lifestyle
Residences, LLC (0721), SilverRock Lodging, LLC (4493), SilverRock Luxury Residences, LLC (6598) and SilverRock
Phase I, LLC (2247). The location of the Debtors' principal place of business and the Debtors' mailing address is 343
Fourth Avenue, San Diego, CA 92101.
2 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Motion.
1
and upon the record herein; and after due deliberation thereon; and it appearing that sufficient notice
of the Motion has been given and that no other further notice is necessary, except as set forth in the
Motion with respect to entry of this Interim Order and notice of the Final Hearing (as defined
below); and good cause appearing therefor; it is hereby
A. ORDERED THAT:
1. The Motion is GRANTED on an interim basis, as set forth herein.
2. The Debtors are authorized, but not directed, to maintain and use the Bank Accounts
in the name and with the account numbers existing immediately prior to the Petition Date and shall
not be required to establish a specific new bank account for tax payments.
3. The Debtors shall retain authority to close or otherwise modify certain of their
accounts and open new debtor in possession accounts, they deem necessary to facilitate the Chapter
11 Cases and their operations. The Debtors are authorized to open any new bank accounts or close
any existing bank accounts as they may deem necessary and appropriate in their sole discretion;
provided, however, that the Debtors shall give notice within fifteen (15) days of opening or closing
any bank account to the Office of the United States Trustee for the District of Delaware (the
"U.S. Trustee") and any statutory committees appointed in the Chapter 11 Cases; provided, further,
however, that the Debtors shall open any such new bank account at banks that have executed a Uniform
Depository Agreement with the U.S. Trustee, or at such banks that are willing to immediately execute such
an agreement.
4. The Debtors are authorized to deposit funds in and withdraw funds from the Bank
Accounts by all usual means, subject to the same access rights and limitations existing prior to the
Petition Date, including, but not limited to, checks, wire transfers, automated clearinghouse
transfers, electronic funds transfers, and other debts and to treat the Bank Accounts for all purposes
2
as debtor in possession accounts.
5. The Debtors are authorized, but not directed, to continue to use their pre-printed
checks, correspondence, and business forms and checks, including, but not limited to, purchase
orders, letterhead, envelopes, promotional materials, and other business forms, substantially in the
forms existing immediately prior to the Petition Date, without reference to the Debtors' debtor in
possession status, provided that once the Debtors' existing checks have been used, the Debtors
shall, when reordering checks, require the designation "Debtor In Possession" and the
corresponding bankruptcy case number on all checks; provided, further, that, with respect to
checks which the Debtors or their agents print themselves, the Debtors or their agents shall begin
printing the "Debtor In Possession" legend on such items within ten (10) days of the date of entry
of this Interim Order.
6. The banks listed on Exhibit C to the Motion are hereby authorized and directed to
continue to service and administer the Bank Accounts of the Debtors as debtors in possession
without interruption and in the usual and ordinary course of business, and to receive, process, honor
and pay any and all checks, drafts, wires or ACH transfers drawn on the Bank Accounts by the
holders or makers thereof, provided that nothing contained herein shall authorize any such
bank to honor any check issued or dated prior to the Petition Date, except as otherwise provided
by further order of the Court. In no event shall any of the banks be required to honor overdrafts
or to pay any check, wire or other debit against any of the Bank Accounts that is drawn against
uncollected funds.
7. The Debtors are authorized, but not directed, to pay, and the banks may continue to
charge and collect, all customary and usual prepetition and postpetition fees arising from or related
to the Bank Accounts.
8. Subject to section 553 of the Bankruptcy Code, all banks that maintain the Bank
3
Accounts are prohibited from offsetting, affecting, freezing, or otherwise impeding the Debtors'
use of any funds in the Bank Accounts on account of, or by reason of, any claim (as defined in
section 101(5) of the Bankruptcy Code) of any such bank against the Debtors that arose before the
Petition Date, absent further order of the Court.
9. The Debtors shall continue to maintain detailed records in the ordinary course of
business with respect to all transfers so that all transactions (including any intercompany
transactions) may be readily ascertained, traced, recorded properly, and distinguished between
prepetition and postpetition transactions.
10. To the extent applicable, the Debtors' time to comply with section 345(b) of the
Bankruptcy Code is hereby extended for a period of thirty (30) days from the date of this Order
(the "Extension Period"), provided, however, that such extension is without prejudice to the
Debtors' right to request a further extension ofthe Extension Period ofthe waiver of the requirements
of section 345(b) in these Chapter 11 Cases.
11. With respect to banks at which the Debtors hold the Bank Accounts that are party
to a Uniform Depository Agreement with the U.S. Trustee, the Debtors shall immediately (a)
contact each bank, (b) provide the bank with each of the Debtors' employer identification numbers,
and (c) identify each of the Bank Accounts held at such banks as being held by a debtor in
possession in a bankruptcy case.
12. To the extent applicable, for Banks at which the Debtors hold Bank Accounts that
are not party to a Uniform Depository Agreement with the U.S. Trustee, the Debtors shall use their
good -faith effort to cause such Banks to execute a Uniform Depository Agreement in a form
prescribed by the U.S. Trustee within thirty days of the date of this Interim Order. The U.S.
Trustee's rights to seek further relief from this Court on notice in the event that the aforementioned
banks are unwilling to execute a Uniform Depository Agreement in a form prescribed by the U.S.
4
Trustee are fully reserved.
13. Nothing herein further authorizes the Debtors to make transfers or loans to non -
debtor affiliates absent further order of the Court.
14. The requirements set forth in rule 6004(a) of the Bankruptcy Rules are hereby
waived.
15. The requirements set forth in rule 6003(b) of the Bankruptcy Rules are satisfied
because the relief set forth in this Interim Order is necessary to avoid immediate and irreparable
harm.
16. The Debtors are authorized to take all actions necessary to effectuate the relief
granted pursuant to this Interim Order in accordance with the Motion.
17. This Interim Order is effective immediately upon its entry.
18. The hearing to consider entry of an order granting the relief requested in the Motion
on a final basis (the "Final Hearing") shall be held on September 11, 2024 at 2:00 p.m.
(ET). (prevailing Eastern Time). Any objection to the entry of a final order granting the relief
requested in the Motion shall be filed with the Court and served on the following parties no later
than 4:00 p.m. Prevailing Eastern Time on September 4, 2024, (a) the Debtors, c/o SilverRock
Development Company, LLC 343 Fourth Avenue, San Diego, CA 92101; (b) proposed counsel to
the Debtors, Armstrong Teasdale LLP, 1007 North Market Street, Third Floor Wilmington,
Delaware 19801, Attn: Jonathan M. Stemerman (jstemennan@a atllp.com) and P.O. Box 9038, La
Jolla CA, 92037, Attn: Victor A. Vilaplana (vavilaplana(�gmail.com), and 5965 Village Way, STE
E105, La Jolla, CA 92037 Attn: Benjammin M. Carson (ben(a�benjamincarsonlaw.com); and (f) the
Office of the United States Trustee, 844 King Street, Suite 2207, Lockbox 35, Wilmington, Delaware 19801,
Attn: Malcolm M. Bates (Malcolm.m.batesusdoi.gov). In the event no objections to entry of the Final Order
on the Motion are timely received, this Court may enter such Final Order without need for the Final Hearing.
5
19. The Court shall retain jurisdiction with respect to all matters arising from or related
to the implementation, interpretation, and enforcement of this Interim Order.
6
EXHIBIT B
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re
SilverRock Development Company., et al.1
Debtors.
Chapter 11
Case No. 24-11647 MFW
(Joint Administration Requested)
RE: Docket No. —8
INTERIM ORDER (I) AUTHORIZING THE MAINTENANCE OF BANK ACCOUNTS
AND CONTINUED USE OF EXISTING BUSINESS FORMS AND CHECKS, (II)
GRANTING LIMITED RELIEF FROM THE REQUIREMENTS OF BANKRUPTCY CODE
SECTION 345(B), AND (IIII) GRANTING RELATED RELIEF
Upon the Motion of the Debtors for Entry of Interim and Final Orders (I) Authorizing the
Maintenance of Bank Accounts and Continued Use of Existing Business Forms and Checks, (II)
Granting Limited Relief from the Requirements of Bankruptcy Code Section 345(b), and (III)
Granting Related Relief (the "Motion");2 and upon the Declaration of Robert S. Green Jr.
Pursuant to 28 U.S.C. 5C 1746 in Support of the Debtors' Chapter 11 Petitions and First
Day Pleadings (the "First Day Declaration"); and the Court finding that: (a) the Court has
jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing Order of
Reference from the United States District Court for the District of Delaware dated February 29, 2012; (b)
this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); (c) the Court having found that venue of this
proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and (d) the
Court may enter a final order consistent with Article III of the United States Constitution;
' The Debtors in these chapter 11 cases, along with the last four digits of each Debtor's federal tax identification number,
as applicable, are: SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996), SilverRock Lifestyle
Residences, LLC (0721), SilverRock Lodging, LLC (4493), SilverRock Luxury Residences, LLC (6598) and SilverRock
Phase I, LLC (2247). The location of the Debtors' principal place of business and the Debtors' mailing address is 343
Fourth Avenue, San Diego, CA 92101.
2 Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Motion.
1
and upon the record herein; and after due deliberation thereon; and it appearing that sufficient notice
of the Motion has been given and that no other further notice is necessary, except as set forth in the
Motion with respect to entry of this Interim Order and notice of the Final Hearing (as defined
below); and good cause appearing therefor; it is hereby
A. ORDERED THAT:
1. The Motion is GRANTED on an interim basis, as set forth herein.
2. The Debtors are authorized, but not directed, to maintain and use the Bank Accounts
in the name and with the account numbers existing immediately prior to the Petition Date and shall
not be required to establish a specific new bank account for tax payments.
3. The Debtors shall retain authority to close or otherwise modify certain of their
accounts and open new debtor in possession accounts, they deem necessary to facilitate the Chapter
11 Cases and their operations. The Debtors are authorized to open any new bank accounts or close
any existing bank accounts as they may deem necessary and appropriate in their sole discretion;
provided, however, that the Debtors shall give notice within fifteen (15) days of opening or closing
any bank account to the Office of the United States Trustee for the District of Delaware (the
"U.S. Trustee") and any statutory committees appointed in the Chapter 11 Cases; provided, further,
however, that the Debtors shall open any such new bank account at banks that have executed a Uniform
Depository Agreement with the U.S. Trustee, or at such banks that are willing to immediately execute such
an agreement.
4. The Debtors are authorized to deposit funds in and withdraw funds from the Bank
Accounts by all usual means, subject to the same access rights and limitations existing prior to the
Petition Date, including, but not limited to, checks, wire transfers, automated clearinghouse
transfers, electronic funds transfers, and other debts and to treat the Bank Accounts for all purposes
2
as debtor in possession accounts.
5. The Debtors are authorized, but not directed, to continue to use their pre-printed
checks, correspondence, and business forms and checks, including, but not limited to, purchase
orders, letterhead, envelopes, promotional materials, and other business forms, substantially in the
forms existing immediately prior to the Petition Date, without reference to the Debtors' debtor in
possession status, provided that once the Debtors' existing checks have been used, the Debtors
shall, when reordering checks, require the designation "Debtor In Possession" and the
corresponding bankruptcy case number on all checks; provided, further, that, with respect to
checks which the Debtors or their agents print themselves, the Debtors or their agents shall begin
printing the "Debtor In Possession" legend on such items within ten (10) days of the date of entry
of this Interim Order.
6. The banks listed on Exhibit C to the Motion are hereby authorized and directed to
continue to service and administer the Bank Accounts of the Debtors as debtors in possession
without interruption and in the usual and ordinary course of business, and to receive, process, honor
and pay any and all checks, drafts, wires or ACH transfers drawn on the Bank Accounts by the
holders or makers thereof, provided that nothing contained herein shall authorize any such
bank to honor any check issued or dated prior to the Petition Date, except as otherwise provided
by further order of the Court. In no event shall any of the banks be required to honor overdrafts
or to pay any check, wire or other debit against any of the Bank Accounts that is drawn against
uncollected funds.
7. The Debtors are authorized, but not directed, to pay, and the banks may continue to
charge and collect, all customary and usual prepetition and postpetition fees arising from or related
to the Bank Accounts.
8. Subject to section 553 of the Bankruptcy Code, all banks that maintain the Bank
3
Accounts are prohibited from offsetting, affecting, freezing, or otherwise impemd-ing-imj2eding_the
Debtors' use of any funds in the Bank Accounts on account of, or by reason of, any claim (as
defined in section 101(5) of the Bankruptcy Code) of any such bank against the Debtors that arose
before the Petition Date, absent further order of the Court.
9. The Debtors shall continue to maintain detailed records in the ordinary course of
business with respect to all transfers so that all transactions (including any intercompany
transactions) may be readily ascertained, traced, recorded properly, and distinguished between
prepetition and postpetition transactions.
10. To the extent applicable, the Debtors' time to comply with section 345(b) of the
Bankruptcy Code is hereby extended for a period of thirty (30) days from the date of this Order
(the "Extension Period"), provided, however, that such extension is without prejudice to the
Debtors' right to request a further extension of the Extension Period of the waiver of the requirements
of section 345(b) in these Chapter 11 Cases.
11. With respect to banks at which the Debtors hold the Bank Accounts that are party
to a Uniform Depository Agreement with the U.S. Trustee, within -fifteen 0-5) days-e€ date ef
ems of this Interim Order the Debtors shall_ immediately (a) contact each bank, (b) provide the
bank with each of the Debtors' employer identification numbers, and (c) identify each of the Bank
Accounts held at such banks as being held by a debtor in possession in a bankruptcy case.
12. To the extent applicable, for Banks at which the Debtors hold Bank Accounts that
are not party to a Uniform Depository Agreement with the U.S. Trustee, the Debtors shall use their
good -faith effort to cause such Banks to execute a Uniform Depository Agreement in a form
prescribed by the U.S. Trustee within thirty days of the date of this Interim Order. The U.S.
Trustee's rights to seek further relief from this Court on notice in the event that the aforementioned
banks are unwilling to execute a Uniform Depository Agreement in a fonn prescribed by the U.S.
4
Trustee are fully reserved.
13. Nothing herein further authorizes the Debtors to make transfers or loans to non -
debtor affiliates absent further order of the Court.
14. The requirements set forth in rule 6004(a) of the Bankruptcy Rules are hereby
waived.
15. The requirements set forth in rule 6003(b) of the Bankruptcy Rules are satisfied
because the relief set forth in this Interim Order is necessary to avoid immediate and irreparable
harm.
16. The Debtors are authorized to take all actions necessary to effectuate the relief
granted pursuant to this Interim Order in accordance with the Motion.
17. This Interim Order is effective immediately upon its entry.
18. The hearing to consider entry of an order granting the relief requested in the Motion
on a final basis (the "Final Hearing") shall be held on , 2024 at
(prevailing Eastern Time). Any objection to the entry of a final order granting the relief requested in
the Motion shall be filed with the Court and served on the following parties no later than 4:00 p.m.
Prevailing Eastern Time on , 2024, (a) the Debtors, c/o SilverRock
Development Company, LLC 343 Fourth Avenue, San Diego, CA 92101; (b) proposed counsel to the
Debtors, Armstrong Teasdale LLP, 1007 North Market Street, Third Floor Wilmington, Delaware
19801, Attn: Jonathan M. Stemerman (jstemerman@atllp.com) and P.O. Box 9038, La Jolla CA,
92037, Attn: Victor A. Vilaplana (vavilaplana@gmail.com), and 5965 Village Way, STE E105, La
Jolla, CA 92037 Attn: Benjammin M. Carson (ben a@benjamincarsonlaw.com)1 and (f) the Office of the
United States Trustee, 844 King Street, Suite 2207, Lockbox 35, Wilmington, Delaware 19801, Attn: Malcolm
M. Bates (Malcolm.m.bates a?usdoi.gov). In the event no objections to entry of the Final Order on the Motion are
timely received, this Court may enter such Final Order without need for the Final Hearing.
19. The Court shall retain jurisdiction with respect to all matters arising from or related
5
to the implementation, interpretation, and enforcement of this Interim Order.
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development LLC, et al.,
Debtors.1
Chapter 11
Case No. 24-11647 MFW
(Jointly Administered)
CERTIFICATE OF SERVICE
I hereby certify that on this 13th day of August, 2024, I filed with the Court and served by
U.S. Mail a copy of the Certification of Counsel to all creditors listed on the attached Exhibit A.
Dated: August 13, 2024
Wilmington, Delaware
ARMSTRONG TEASDALE, LLP
/s/Jonathan M. Stemerman
Jonathan M. Stemerman (No. 4510)
Eric M. Sutty (No. 4007)
Denisse Guevara (No. 7206)
1007 North Market Street, Third Floor
Wilmington, Delaware 19801
Telephone: (302) 416-9670
jstemerman@atllp.com
esutty@atllp.com
dguevara@afilp.com
Proposed Counsel to the Debtors
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: SilverRock Development Company, LLC (5730), RGC PA 789, LLC (5996),
SilverRock Lifestyle Residences, LLC (0721), SilverRock Lodging, LLC (4493), SilverRock Luxury Residences,
LLC (6598) and SilverRock Phase I, LLC (2247). The location of the Debtors' principal place of business and the
Debtors' mailing address is 343 Fourth Avenue, San Diego, CA 92101.
EXHIBIT A
Poppy Bank
438 First Street
Santa Rosa, CA 95401
George J. Heuser Revocable Trust
1419 Dolphin Terrace
Corona Del Mar, CA 92625 Cypress Point Holdings, LLC
12707 High Bluff Dr., Suite 340
San Diego, CA 92130
RD Olson Construction, Inc.
400 Spectrum Center Drive, Suite 1200
Irvine, CA 92618
Eric Leitstein
2505 Rosemary Court
Encinitas, CA 92024
Granite Construction Company
c/o Finch Thornton
38000 Monroe Street
Indio, CA 92203
Axia Talus, LLC
4421 Thanksgiving Way
Lehi, UT 84043
Richard & Lehn Goetz
11420 Brooks Road
Windsor, CA 95492
SVR Capital Trust
5809 Seashore Drive
Newport Beach, CA 92663
Kenneth and Theresa Green Family Trust
12627 Oakbrook Court
Poway, CA 92064
Young Holdings — David Solomon
YH-MCSV Fund I, LLC
15 Enterprise Suite 100
Aliso Viejo, CA 92656
Duclos Family Revocable Trust
14854 Chesfield Court
San Diego, CA 92127
Young Holdings
15 Enterprise, Ste 100
Aliso Viejo, CA 92656
Larry Welk
5133 Harding Pike, B-10 Box 301
Nashville, TN 37205
Bar Architects
77 Geary Street, Suite 200
San Francisco, CA 94108
Kurtin Family Trust
8091 Run of the Knolls
San Diego, CA 92127
SilverRock Resort Investment M LLC
311 E. Chicago Street, Suite 510
Milwaukee, WI 53202
IRAR Trust FBO Bryan D Holker
2019 Coast Blvd
Del Mar, CA 92014
Diane Cimarusti
2019 Coast Blvd.
Del Mar, CA 92014
CMG Capital
3160 Crow Canyon Road Suite 400
San Ramon, CA 94583
Claire Fruhwirth Trust
P.O. Box 121
Solana Beach, CA 92075
Jason Parr
10980 Pine Nut Drive
Truckee, CA 96161
Magnus Blue LLP
12526 High Bluff Drive, Suite 360
San Diego, CA 92130
Jonathan P. Fredricks
P.O. Box 701
Rancho Santa De, CA 92067
Mack Revocable Trust
63 Gammons Road
Waban, MA 02468
Coachella Valley Water District
P.O. Box 1058
Coachella, CA 92236
Kevin and Lindy Welk
5133 Harding Pike, B-10 Box 301
Nashville, TN 37205
Bill and Susan Hoehn Family Trust
P.O. Box 1606
Rancho Santa Fe, CA 92067
Mobile Modular
P.O. Box 45043
San Francisco, CA 94145
Parekh Family Trust
335 15th Street
San Diego, CA 92101
McCoy Revocable Trust No. 92
10022 Rellswood Dr.,
Belvidere, IL 61008
Lieff Real Estate Energy Partners
5 Union Square West #1265
New York, NY 10003
Eric and Hector Beranek
1310 Ocean Drive
Manhattan Beach, CA 90266
Robert S. Green, Jr.
1440 Akita Lane
Encinitas, CA 92024
NV5, Inc.
P.O. Box 74008680
Chicago, IL 60674-8680
Kloiber Real Estate Holdings, LLC
501 W Broadway, Suite 800
San Diego CA 92101
Traub Family Revocable Trust
1425 La Perla Avenue
Long Beach, CA 90815
DLA Piper LLP
555 Mission Street, Suite 2400
San Francisco, CA 94105
Bank of America Corporate Center
100 North Tryon Street
Charlotte, NC 28255
Attn: Legal Department
Intemal Revenue Service
Centralized Insolvency Operation
P. O. Box 7346
Philadelphia, PA 19101- 7346
SMDM, LLC
81740 MacBeth Street
La Quinta, CA 92253
Imperial Irrigation District
81600 Avenue 58
La Quinta, CA 92253
City of La Quinta
78495 Calle Tampico La
Quinta, CA 92253
Sunrise Golf Construction
P.O. Box 499
Nuevo, CA 92567
Manatt, Phelps & Phillips
2049 Century Park East, Ste 1700
Los Angeles, CA 90067-3101
First Insurance Funding
P.O. Box 7000
Carol Stream, IL 60197-7000
BMP Contractors Inc
12150 Theodore Street
Moreno Valley, CA 92555
Southern California Gas Company
P.O. Box 2007
Monterey Park, CA 91754-0957
IOA Insurance Services
1855 West State Rd 434
Longwood, FL 92750
Caldarelli Hejmanowski3398
Carmel Mountain Rd Ste 250
San Diego, CA 92121
Montage International
3 Ada Parkway Suite 100
Irvine, CA 92618"
Crosbie Gliner Schiffman
12750 High Bluff Drive Suite 250
San Diego, CA 92130
Williams Scotsman
P.O. Box 91975
Chicago, IL 60699-1975
Jacobsson Engineering Construction Inc.
P.O. Box 14430
Palm Desert, CA 92255
Project Dynamics, Inc.
P.O. Box 14430
Palm Desert, CA 92255
5
Mitchell B. Greenberg, Esquire
Abbey, Weitzenberg, Warren & Emery
100 Stony Point Road, Suite 200
Santa Rosa, CA 95401
Kevin S. Mann, Esquire
Cross & Simon, LLC
U.S. Trustee
Office of the United States Trustee
J. Caleb Boggs Federal Building
844 King Street, Suite 2207
Lockbox 35
Wilmington, DE 19801