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Trump Confidentiality

Trump Confidentiality

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Published by: Marie Beaudette Glatstein on May 07, 2013
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05/07/2013

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GIBSON, DUNN & CRUTCHER LLP
 J. Eric WiseShira D. Weiner 200 Park Avenue New York, New York 10166-0193Telephone: (212) 351-4000Facsimile: (212) 351-4035Proposed Attorneys for the Debtor and Debtor in Possession
UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORK 
--------------------------------------------------------------- 
IN RE:NEWLAND INTERNATIONALPROPERTIES, CORP.,Debtor.
---------------------------------------------------------------x::::::::x
Chapter 11Case No. 13-11396 (MG)DEBTOR’S MOTION FOR ENTRY OF AN ORDER AUTHORIZING THE DEBTOR TO FILE UNDER SEALCERTAIN CONFIDENTIAL PLAN SUPPLEMENT DOCUMENTS
 Newland International Properties, Corp., as debtor and debtor in possession (the
 Debtor 
”), submits this motion (the ”
 Motion
”) for entry of an order pursuant to section 107(b) of title 11 of the United States Code (the “
 Bankruptcy Code
”)
1
and Rule 9018 of the Federal Rulesof Bankruptcy Procedure (the “
 Bankruptcy Rules
”) authorizing the Debtor to: (a) redact certainconfidential documents (the “
Confidential Documents
”) contained in the Plan Supplement thatwill be filed in connection with the
 Prepackaged Plan of Reorganization for the Debtor Under 
1All statutory references are to the Bankruptcy Code unless otherwise specified.
13-11396-mg Doc 35 Filed 05/06/13 Entered 05/06/13 15:05:31 Main DocumentPg 1 of 13
 
 
Chapter 11 of the Bankruptcy Code
, dated March 29, 2013 [Docket No. 11] (the “
 Plan
”)
2
and inother disclosures, applications, motions, and other pleadings related to such ConfidentialDocuments (collectively, the “
 Disclosures
”) filed publicly with the Court (each redactedDisclosure, a “
 Redacted Disclosure
”); (b) file an unredacted copy of the ConfidentialDocuments and any related Disclosures (the “
Unredacted Disclosures
”) with the Court under seal; and (c) provide a copy of the Unredacted Disclosures to (i) the United States Trustee for theSouthern District of New York (the “
United States Trustee
”), (ii) professionals for (x) theOfficial Committee of Unsecured Creditors (the “
Committee
”), if appointed, and (y) the SteeringGroup, and (iii) any Noteholder (as defined below); provided that each of the foregoing other than the United States Trustee executes an appropriate confidentiality agreement in form andsubstance reasonably acceptable to the Debtor and the Trump Parties (as defined below). Insupport of the Motion, the Debtor respectfully represents:
3
 
BACKGROUNDA.
 
General Background
 1.
 
On April 30, 2013 (the “
 Petition Date
”), the Debtor commenced a case (the
Chapter 11 Case
”) under chapter 11 of the Bankruptcy Code. The Debtor is operating its business and managing its property as a debtor in possession pursuant to sections 1107(a) and1108 of the Bankruptcy Code.
2Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them in the Plan.3A description of the Debtor’s business and the reasons for filing the Chapter 11 Case is set forth in the
 Declaration of Carlos Saravia, Chief Operating Officer of Newland International Properties, Corp., in Support of the Debtor’s Chapter 11 Petition and First Day Motions and in Accordance with Local Rule 1007-2
,executed on April 30, 2013 (the “
 Saravia Declaration
”) [Docket No. 2].
13-11396-mg Doc 35 Filed 05/06/13 Entered 05/06/13 15:05:31 Main DocumentPg 2 of 13
 
 2.
 
 No request has been made for the appointment of a trustee or an examiner in theChapter 11 Case. No official committee has been appointed by the Office of the United StatesTrustee.
B.
 
The Debtor’s Business
3.
 
The Debtor is a real estate development company established exclusively todevelop the “Trump Ocean Club International Hotel & Tower” in Panama City, Panama (the
Trump Ocean Club
”) and the related amenities.4.
 
Trump Ocean Club is a multi-use luxury tower overlooking the Pacific Ocean,with luxury condominium residences, a world-class hotel condominium, a limited number of offices and premier leisure amenities. Trump Ocean Club is located on the Punta PacificaPeninsula – one of the most exclusive neighborhoods in Panama City – on approximately 2.8acres of land, including approximately 295 lineal feet of oceanfront. The Trump Ocean Clubtower has 69 floors of construction, three of which are technical floors dedicated to criticalmachinery, with the remaining floors including, among other things, 630 luxury residentialcondominium units and 369 world-class hotel condominium units, a pier facility, pool deck, 30 boutique shops, 64 office lofts, restaurants and 1592 parking spaces. The construction of the building is finished and the hotel is currently in operation, as are the residences, offices, boutiques and restaurants. The developers are now finishing a private beach club located onViveros Island, which is scheduled to be completed in September 2013. Newland alsoannounced an agreement with a globally-recognized gaming group which plans to operate a75,000 square foot casino in the building as well as the acquisition of important real estate unitsto complement its gaming business. The transaction remains subject to the fulfillment of certainconditions for filing and obtaining the necessary authorizations from the PanamanianGovernment. Operating under the internationally recognized Trump brand name, Trump Ocean
13-11396-mg Doc 35 Filed 05/06/13 Entered 05/06/13 15:05:31 Main DocumentPg 3 of 13

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