2025-01-15 Debtors' Witness and Exhibit List for Hearing (Doc 310, received 2025-01-23)Case 24-11647-MFW Doc 310 Filed 01/15/25 Page 1 of 4
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
SilverRock Development Company, et al.,
Case No. 24-11647 (MFW)
Debtors.' (Jointly Administered)
Re: Docket Nos. 246, 300, 301, 306, 307
DEBTORS' WITNESS AND EXHIBIT LIST FOR JANUARY 15, 2025 HEARING
The above -captioned debtors and debtors in possession (collectively, the "Debtors"), by
and through their undersigned counsel, hereby submit their Witness and Exhibit List for the
hearing to be held on January 15, 2025 at 1:00 p.m. (ET) (the "Hearing") as follows:
WITNESSES
The Debtors expect to call or may call the following witnesses at the Hearing:
1. Christopher S. Sontchi, Sole Manager of the Debtors (participating remotely)
2. Edward T. Gavin, CTP, NCPM
3. Douglas Wilson, Chief Restructuring Officer of the Debtors
4. Jon McMillen, City Manager for the City of La Quinta, California
5. The Debtors reserve the right call any witness designated by any other party, any
witness used for impeachment or rebuttal, and any witness necessary to lay the foundation for
admission of exhibits.
Chapter 11
'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 1, LLC (2247). The location of the Debtors' principal place of business and the Debtors'
mailing address is 343 Fourth Avenue, San Diego, CA 92101.
Case 24-11647-MFW Doc 310 Filed 01/15/25 Page 2 of 4
EXHIBITS
Exhibit
Description
Document
Date
Docket
Reference
D-1
DIP Term Sheet
Dec. 12, 2024
D.I. 246, Ex. 1
to Ex. A
D-2
DIP Budget
Dec. 12, 2024
D.I. 246, Ex. A
to DIP Term
Sheet
D-3
Memorandum of Understanding
Dec. 12, 2024
D.I. 246, Ex. B
to DIP Term
Sheet
D-4
CBRE Appraisal of Talus La Quinta - Montage
Site, Pendry Site, Golf Clubhouse Site,
Conference Center & Shared Services Site, and
Planning Areas 7, 8, & 9
June 3, 2024
68-1
D-5
HVS Appraisals of Proposed Montage Resort
and Residences
May 28, 2024
68-2 and 68-3
D-6
Declaration of Christopher S. Sontchi, Sole
Independent Manager of the Debtors, in
Support of Debtors' Motion Pursuant to
Sections 105, 361, 362, 363, 364, and 507 of
the Bankruptcy Code, Bankruptcy Rule 4001,
and Local Rule 4001-2, for an Order (I)
Authorizing Debtors to Obtain Postpetition
Financing; (II) Granting DIP Lender Liens and
Super -Priority Claim; and (III) Granting
Related Relief
Dec. 12, 2024
246-2
D-7
Declaration of Douglas Wilson, Chief
Restructuring Officer of the Debtors, in
Support of Debtors' Motion Pursuant to
Sections 105, 361, 362, 363, 364, and 507 of
the Bankruptcy Code, Bankruptcy Rule 4001,
and Local Rule 4001-2, for an Order (I)
Authorizing Debtors to Obtain Postpetition
Financing; (II) Granting DIP Lender Liens and
Super -Priority Claims; and (III) Granting
Related Relief
Dec. 12, 2024
246-3
D-8
Supplemental Declaration of Douglas Wilson,
Chief Restructuring Officer of the Debtors, in
Support of Debtors' Motion Pursuant to
Sections 105, 361, 362, 363, 364, and 507 of
the Bankruptcy Code, Bankruptcy Rule 4001,
and Local Rule 4001-2, for an Order (I)
Authorizing Debtors to Obtain Postpetition
Financing; (II) Granting DIP Lender Priming
Jan. 13, 2025
301
i
Case 24-11647-MFW Doc 310 Filed 01/15/25 Page 3 of 4
Liens and Super -Priority Claims; and (III)
Granting Related Relief
D-9
Curriculum Vitae of Ted Gavin, CTP, NCPM
N/A
N/A
D-10
Declaration of Edward T. Gavin, CTP, NCPM
of Gavin/Solmonese LLC, Advisor to
Richards, Layton & Finger, P.A. on Behalf of
the Sole Manager of the Debtors, in Support of
Motion of Debtors Pursuant to Sections 105,
361, 362, 363, 364, and 507 of the Bankruptcy
Code, Bankruptcy Rule 4001, and Local Rule
4001-2, for an Order (I) Authorizing Debtors to
Obtain Postpetition Financing; (II) Granting
DIP Lender Priming Liens and Super -Priority
Claims; and (III) Granting Related Relief
Jan. 14, 2025
307
RESERVATION OF RIGHTS
The Debtors reserve (a) the right to amend and/or supplement this Witness and Exhibit
List at any time prior to the Hearing and (b) the right to use additional exhibits for purposes of
rebuttal or impeachment and to further supplement the foregoing Witness and Exhibit List as
appropriate. The Debtors also reserve the right to rely upon and use as evidence (a) exhibits
included on the exhibit lists of any other parties in interest and (b) any pleading, hearing
transcript, or other document filed with the Court in the above -captioned matter.
Respectfully submitted,
Dated: January 15, 2025
Wilmington, Delaware
ARMSTRONG TEASDALE, LLP
/s/Jonathan M. Stemerman
Jonathan M. Stemerman (No. 4510)
1007 North Market Street, Third Floor
Wilmington, Delaware 19801
Telephone: (302) 416-9670
jstemerman@atllp.com
-and-
Case 24-11647-MFW Doc 310 Filed 01/15/25 Page 4 of 4
Victor A. Vilaplana (Pro Hac Vice)
P.O. Box 9038
La Jolla, CA 92037
Telephone: (619) 840-4130
vavilaplana@gmail.com
-and-
Benjamin M. Carson (Pro Hac Vice)
5965 Village Way STE E105
San Diego, CA 92130
Telephone: (858) 255-4529
ben@benjamincarson.com
Counsel to the Debtors and Debtors in
Possession