ORIGl L

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: )

) PITT PENN HOLDING CO., INC., et al. 1, ) )

Debtors. )

)

CHAPTER 11

Case No. 09-11475 (BLS) (Jointly Administered)

Hearing Date: To Be Determined

Objection Deadline: September 16,2010 @ 4pm

NOTICE OF MOTION

TO: PARTIES ON THE SERVICE LIST

Industrial Enterprises of America, Inc., ("IEAM" or "the Company"), Pitt Penn Holding Co., Inc., ("PPH"), Pitt Penn Oil Co., LLC, ("PPO"), EMC Packaging, Inc., ("EMC"), Today's Way Manufacturing LLC, ("Today's Way"), and Unifide Industries LLC, ("Unifide"), collectively the debtors-in-possession ("Movants"), have filed a Motion for Order Directing Document Production from Ilene Engelberg. Pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure (the "Motion") which seeks entry of an order authorizing Movants to obtain documents and to compel the production of such documents identified in the Motion.

You are required to file a response to the attached Motion on or before September 16, 2010 at 4:00 p.m, EDT.

At the same time, you must also serve a copy of the response upon Movants' attorneys at the addresses listed below.

A HEARING ON. THE MOTION WILL BE HELD ON A DATE TO BE DETERMINED.

1 The debtors are: Pitt Penn Holding Co. (Case No. 09-11475), Pitt Penn Oil Co. LLC (Case No. 09-11476), Industrial Enterprises of America, Inc. (Case No. 09-11508), EMC Packaging, Inc. (Case No. 09-11524), Today's Way Manufacturing LLC (Case No. 09-11586), and Unifide Industries LLC (Case No. 09-11587), all of which have been jointly administered.

Motion to Compel Document Production from Ilene Engelberg.DOCX

IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF DEMANDED BY THE MOTION WITHOUT FURTHER NOTICE OF HEARING. DATED: August 30, 2010

- and-

Steven W. Thomas (CA Bar No. 168967)

Emily Alexander (CA Bar No. 220595) THOMAS, ALEXANDER & FORRESTER LLP 14 27th Avenue

Venice, CA 90291

Telephone: (310) 961-2536

Facsimile: (310) 526-6852

Email: steventhomas@tafattomeys.com

Email: emilyalexander@tafattomeys.com

Counsel for Movants

Motion to Compel Document Production from Ilene EngelbergDOCX 2

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: )

)

PITT PENN HOLDING CO., INC., et a1.1, )

)

Debtors. )

)

CHAPTER 11

Case No. 09-11475 (BLS) (Jointly Administered)

Hearing Date: To Be Determined

Objection Deadline: September 16, 2010 at 4 pm

DEBTORS' MOTION FOR ORDER DIRECTING

DOCUMENT PRODUCTION FROM ILENE ENGELBERG PURSUANT TO RULE 2004 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE

Industrial Enterprises of America, Inc., ("IEAM" or "the Company"), Pitt Penn Holding

Co., Inc., ("PPH"), Pitt Penn Oil Co., LLC, ("PPO"), EMC Packaging, Inc., ("EMC"), Today's

Way Manufacturing LLC, ("Today's Way"), and Unifide Industries LLC ("Unifide"),

collectively the debtors-in-possession (the "Debtors") move under Federal Rule of Bankruptcy

Procedure 2004 ("Rule 2004") for entry of an order compelling Ilene Engelberg to produce the

documents identified in Exhibit "A" hereto, and respectfully allege as follows:

Introduction

1. On April 30, 2009 through May 6, 2009 (the "Petition Dates"), the Debtors filed

with the United States Bankruptcy Court for the District of Delaware (the "Bankruptcy Court")

Voluntary Petitions (the "Petitions") under Chapter 11 of the Bankruptcy Code. Since the

Petition Dates, the Debtors have continued in the management and limited operation of their

property as debtors-in-possession pursuant to Sections 1107 and 1108 of the Bankruptcy Code.

I The debtors are: Pitt Penn Holding Co. (Case No. 09-11475), Pitt Penn Oil Co. LLC (Case No. 09-11476), Industrial Enterprises of America, Inc. (Case No. 09-11508), EMC Packaging, Inc. (Case No. 09-11524), Today's Way Manufacturing LLC (Case No. 09-11586), and Unifide Industries LLC (Case No. 09-11587), all of which have been jointly administered.

Motion to Compel Document Production from Ilene Engelberg.DOCX

2. rEAM originally operated as a holding company with four (4) wholly owned

subsidiaries, PPH, EMC, Unifide and Todays Way. PPH, through its wholly owned subsidiary Pitt Penn Oil Co., LLC, an Ohio limited liability company ("Pitt Penn"), was a leading manufacturer, marketer and seller of automotive chemicals and additives. EMC's original business consisted of converting hydrofluorocarbon gases ("HFC") R134a and R152a into branded private label refrigerant and propellant products. Unifide was a leading marketer and seller of automotive chemicals and additives. Todays Way manufactured and packaged the products that were sold by Unifide.

3. Robert L. Renck was appointed President and Chief Executive Officer of IEAM

on April 30, 2009. Mr. Renck has undertaken an investigation into the operations of the Debtors, including significant efforts to issue restated financial statements and to identify and assess potential causes of actions against third-parties.

The IEAM Scheme and the Indictment of John Mazzuto and James Margulies

4. Until February 2008, rEAM was managed by John D. Mazzuto, president and

chieffmancial officer. With the departure of Mr. Mazzuto, James. W. Margulies ran IEAM from his law firm in Ohio. On May 25, 2010 the District Attorney of New York filed an indictment (the "Indictment") naming both Mr. Mazzuto and Mr. Margulies for fraud for a scheme whereby they illegally issued IEAM stock and fraudulently manipulated rEAM's books and records.

Ms. Engelberg's Role

5. Ms. Engelberg is identified as Co-Conspirator #2 in the Indictment and, on

information and belief, was John Mazzuto's girlfriend. She served as an officer ofEMC, was a CPA, and shared an apartment with Mr. Mazzuto in New York City.

Motion to Compel Document Production from Ilene Engelberg.DOCX 2

6. On or about January 24, 2005, John Mazzuto signed and caused to be sent a letter

to the IEAM stock transfer agent invoking the S-8 and Plan and directing the issuance to her of

750,000 IEAM shares. The shares were issued improperly as Ms. Engelberg knew. They went

into an account maintained by her at eTrade, a self-clearing broker-dealer.

7. In addition, the books and records of rEAM were maintained by, in addition to

Mr. Mazzuto and Mr. Margulies, Ms. Engelberg in a QuickBooks file. The originals of that file

have not been turned over to the Company.

8. Finally, Ms. Engelberg was a signatory on IEAM's checking accounts at

Wachovia Bank and had access to the stock issuance system at the company's clearing agent.

She was identified as the owner of "Sapphire Associates" and "Regal Partners," both of whom

allegedly had consulting roles with IEAM.

The Debtors' Accounting Records Are Incomplete and Unreliable and the 2004 Subpoena to Ms. Engelberg Is Necessary to Obtain IEAM Records the Debtors Have Been Unable to Locate Elsewhere

9. Not surprisingly given the nature of the fraud occurring at rEAM, the Debtors'

accounting records are in disarray and unreliable. The majority of the Debtors' accounting

records appear to have been created at the direction of Mr. Mazzuto and Mr. Margulies without

supporting documentation. The Debtors' last accounting firm was unable to complete their [mal

audit and resigned. (Jd.).

10. Upon investigation and review it appears that the vast majority of the corporate

records may have been under the custody of control of Mr. Margulies who acted in various

capacities at IEAM. Accordingly, the Debtors filed a turnover motion against Mr. Margulies

and, only after the threat of contempt, did Mr. Margulies produce IEAM files. Debtors also took

Mr. Margulies' deposition in connection with the turnover motion and although Mr. Margulies

produced additional records as a result, Mr. Margulies' production remains significantly

Motion to Compel Document Production from Ilene Engelberg.DOCX 3

deficient in many respects, and most significantly in terms of IEAM's banking and accounting records.

11. Furthermore, in addition to IEAM records, a number of pertinent records are

possessed by Ms. Engelberg alone including her account records at eTrade and documents relating to her sole ownership of Sapphire Associates and Regal Partners, alleged consultants to IEAM.

Relief Requested

12. By this motion, the Debtors seek the entry of an order pursuant to Rule 2004 of

the Federal Rules of Bankruptcy Procedure compelling Ms. Engelberg to produce any records relating to the Debtors as set forth more specifically in Exhibit "A" (the "Requested Documents"). The Debtors request that Ms. Engelberg be directed to produce the Requested Documents no later than ten (10) business days after the entry of an order granting this motion.

JURISDICTION AND VENUE

13. The Court has subject matter jurisdiction over this motion, which would become a

contested matter under Rule 9014 of the Federal Rules of Civil Procedure if any party in interest with standing should object to the relief sought hereby, under and pursuant to 28 U.S.C. § 1334.

14. §1409.

Venue of this motion is proper in this District under and pursuant to 28 U.S.C.

15. The Statutory authority for the relief sought by this motion is contained in Rule

2004 of the Federal Rules of Bankruptcy Procedure.

Basis for the Relief

16. Rule 2004 Provides "[o]n motion of any party in interest, the court may order the

examination of any entity." Fed. R. Bankr. P. 2004(a). Rule 2004 further provides that "the production of documentary evidence may be compelled in the manner provided in Rule 9016,"

Motion to Compel Document Production from Dene Engelberg.DOCX 4

which in turn incorporated Rule 45 of the Federal Rules of Civil Procedure ("Fed. R. Civ. P.") and provides for the issuance of a subpoena to compel the attendance of a witness for examination. Fed. R. Bankr. P. 2004(c).

17. The permitted scope of discovery under Rule 2004 is limited to "the acts, conduct,

or property or to the liabilities and fmancial condition of the debtor, or to any matter which may affect the administration of the debtor's estate, or to the debtor's right to a discharge." Fed. R. Bankr. P. 2004(b). Rule 2004's scope "has been explained as a broad investigation into the fmancial affairs of the debtor for the purpose of the discovery of assets of the estate and the discovery of fraudulent conduct." 2435 Plainfield Ave., Inc. v. Twp. Of Scotch Plains, (In re 2435 Plainfield Ave., Inc.), 223 B.R. 440, 456 (Bankr. D.N.1. 1998).

18. Courts in this Circuit, in fact, recognize that Rule 2004 examinations are broad,

unfettered and in the nature of fishing expeditions. In re Valley Forge Plaza Assoc., 109 B.R. 669, 674 (Bankr. E.D.Pa. 1990). To further the above-stated purpose of discovering fraudulent conduct and aiding in discovery assets, "[t]hird parties having knowledge of the debtor's affairs, as well as the debtor itself, are subject to examination." Id. At 674; In re Ionosphere Clubs, Inc., 156 B.R. 414 (S.D.N.Y. 1993), aff'd, 17 F. 3d 600 (2d Cir. 1994) (a third party with a relationship to the debtor may be subject to a Rule 2004 examination in order to aid in discovery of assets).

19. As CEO of Debtor IEAM, Robert L. Renck has been actively investigating all

possible claims (including potential preference claims) against various entities that are or were involved in the Debtors' business.

20. Due to the manipulation of records and to the Debtors' limited access to former

personnel and former management of the Debtors-two of whom have been indicted and one of whom, Ms. Engelberg, was referred to in the Indictment as "Co-Conspirator #2"-the Debtors

Motion to Compel Document Production from Ilene Engelberg.DOCX 5

and their counsel have been unable either to recreate accurate financial records for IEAM or to determine the extent of possible causes of action against third-parties. To continue the operations of the Debtors and to effectively evaluate possible causes of action, Mr. Renck must have the all financial records of the Company.

21. In furtherance of the Debtors' initial investigation, counsel to the Debtors sought

the production of documents from Mr. Margulies, the IEAM officer most likely to possess such records. Although Mr. Margulies produced some documents that production is significantly deficient.

22. Accordingly, the Debtors seek authority to compel Ms. Engelberg to produce

copies of any relevant documents she has in her possession.

23. The Debtors reserve their right to request further or additional documents from

Ms. Engelberg with respect to the subject matter herein. The Debtors further reserve their rights as to matters and potential causes of action not specifically addressed herein. Nothing contained in this motion shall be deemed a release or waiver of the Debtors' rights to bring causes of action against any person or entity, including Ms. Engelberg.

24. As evidenced by the attached certification of conference, Debtors' counsel

complied with Local Bankruptcy Rule 2004-1 by conferring telephonically with counsel for Ms. Engelberg and attempted to arrange for a mutually agreeable date, time, place and scope of an examination or production, without success.

Motion to Compel Document Production from ilene Engelberg.DOCX 6

WHEREFORE. the Debtors respectfully request that this Court grant the relief requested

herein, enter an Order in the form annexed hereto and grant the Debtors such other and further

DATED: August 30,2010

te 800 19801

(302) 654-0248

(302) 654-0728 loizides@loizides.com

relief as is just.

- and-

Steven W. Thomas (CA Bar No. 168967)

Emily Alexander (CA Bar No. 220595) THOMAS, ALEXANDER & FORRESTER LLP 14 27th Avenue

Venice, CA 90291

Telephone: (310) 961-2536

Facsimile: (310) 526-6852

Email: steventhomas@tafattomeys.com

Email: emilyalexander@tafattomeys.com

Counsel for Debtors

Motion to Compel Document Production from TIene Engelberg.DOCX 7

EXHIBIT A

Motion to Compel Document Production from ilene Engelberg.DOCX

DOCUMENT REQUESTS TO ILENE ENGELBERG GENERAL INSTRUCTIONS.

1. Definitions

(a) "Document" means any medium, including electronic, upon which

intelligence or information can be recorded, maintained or retrieved, including the original or a copy thereof, regardless of the origin and location, of any writing or recording of any type or description, however produced or reproduced, which is in the Examinee's or the Examinee's representatives' possession, custody or control, or to which the Examinee has or had access, or of which the Examinee has knowledge or which the Examinee has a right or privilege to examine upon request or demand, and includes any and all writings and recordings as the term is used in Fed. R. Evid. 101(1) and includes, but is not limited to, all letters, correspondence, electronic mail, papers, memoranda, contracts, agreements, books, journals, ledgers, statements, reports, studies, bills, billings, invoices, fmancial reports, fmancial statement, financial analyses, worksheets, jottings, memos, projections, notes, abstracts, advertisements, drawings, audits, charges, balance sheets, income statements, checks, diagrams, blueprints, diaries, calendars, logs, recordings, instructions, lists, minutes of meetings, orders, resolutions, telegrams, wires, cables, telexes, faxes, messages, resumes, summaries, tabulations, tallies, statistical analyses, tape recordings, rent rolls, operating reports, bank statements, bank reconciliation's, receipts, invoices, canceled checks, promissory notes, check registers, cash receipts and cash disbursement journals, leases, deeds of trust, mortgages, accounting journals, inventory reports, contracts, detail regarding improvements, repairs and maintenance, drawings, notes, memoranda, telegrams, charts, appraisal reports, purchase or sale proposals, photographs, photographic slides, all data electronically stored or accessible through any electronic data processing system, and all other writing or tangible things on which any information is recorded or reproduced, and any and all amendments, revisions or supplements to all of the foregoing, whether prepared by a party or any other person or entity. Any document with any marks such as initials, comments or

Motion to Compel Document Production from Ilene Engelberg.DOCX

notations of any kind is not deemed to be identical to one without such marks and must be treated as a separate document.

(b) "Engelberg", "You", or "Your" means Ilene Engelberg and includes any

and all agents and any other person or entity acting or purporting to act on her behalf.

(c) "Debtors" and "IEAM" as used herein means Industrial Enterprises of

America ("IEAM"), and includes its affiliates and related entities, including Pitt Penn Holding Co., Pitt Penn Oil Co., LLC, EMC Packaging, Inc., Today's Way Manufacturing LLC, Unifide Industries LLC, any predecessor entity, any and all agents, employees, servants, officers, directors, attorneys and any other person or entity acting or purporting to act on its behalf.

(d) "concerning" means directly or indirectly mentioning, discussing,

describing, evidencing, constituting, pertaining to, referring to, or being connected with, a stated subject matter or any aspect thereof.

2. Construction. In construing these requests, (i) the singular shall include the

plural and the plural shall include the singular; (ii) masculine, feminine or neuter pronouns shall not exclude the other genders; (iii) the conjunctions "and" and "or" shall be read either disjunctively or conjunctively so as to bring within the scope of these requests all information that might otherwise be construed to be outside its scope; and (iv) the word "any" shall be read to mean each and every.

3. Possession, Custody or Control. You are requested and required to produce all

responsive documents within your possession, custody or control.

4. Relevant Time Period. Unless otherwise stated, each document request seeks

documents generated or otherwise existing during any part of the time period from January 1, 2004, through the present.

5. Claim of Privilege. If you object to producing any document on the basis of a

privilege, you are requested to submit a list identifying each such document (by form, title, date authors, recipients, and general subject matter) and stating the nature of any and all privileges

Motion to Compel Document Production from Ilene Engelberg.DOCX 2

claimed as to each such document. Please provide sufficient detail to explain the basis for your claim of privilege and to allow the Court, if necessary, to determine the merits of your claim.

DOCUMENTS REQUESTED

1. Any and all banking records of the Debtors in the Relevant Time Frame including

without limitation (i) account opening documentation, (ii) statements reflecting all transactions (iii) cancelled checks; (iv) wire transfer confirmations and documentation; and (v) control agreements.

2. Any and all books and records of the Debtors in the Relevant Time Frame

including without limitation any QuickBooks file relating to IEAM.

3. Any and all records relating to Your receipt of shares of IEAM or any related

entity including without limitation records maintained or accessible by You relating to any account You maintained at eTrade.

4. Any and all records relating to Your ownership or the operation of any entity

owned by You that performed any consulting work for IEAM including without limitation any records relating to the formation, organization, or operations of or work performed by Regal Partners or Sapphire Associates.

Motion to Compel Document Production from ilene Engelberg.DOCX 3

CERTIFICATE OF COMPLIANCE WITH LOCAL BANKRUPTCY RULE 2004·1

I, Emily Alexander, hereby certify that, I complied with Local Bankruptcy

Rule 2004-1, by telephoning James Kaplan, attorney for Dene Engelberg, and attempting to

arrange for a mutually agreeable date, time, place and scope of the document production. No

agreement was reached.

tJ_~L-

Emily Alexander

11

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: )

) PITT PENN HOLDING CO., INC., et al. 1, ) )

Debtors. )

CHAPTER 11

Case No. 09-11475 (BLS) (Jointly Administered)

Re: Docket No.

ORDER DIRECTING DOCUMENT PRODUCTION FROM ILENE ENGELBERG PURSUANT

TO RULE 2004 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE

Upon consideration of the Debtors' Motion for an Order Directing Document Production

from Ilene Engelberg Pursuant to Rule 2004 of the Federal Rules of Bankruptcy Procedure (the

"Motion"), it is hereby ORDERED that:

1. The Motion is GRANTED; and

2. Ilene Engelberg shall produce to the offices of the Debtors the documents

requested in Exhibit "A" to the Motion within 10 days of this Order.

DATED: ,2010

Honorable Brendan L. Shannon United States Bankruptcy Court Judge

1 The debtors are: Pitt Penn Holding Co. (Case No. 09-11475), Pitt Penn Oil Co. LLC (Case No. 09-11476), Industrial Enterprises of America, Inc. (Case No. 09-11508), EMC Packaging, Inc. (Case No. 09-11524), Today's Way Manufacturing LLC (Case No. 09-11586), and Unifide Industries LLC (Case No. 09-11587), all of which have been jointly administered.

Motion to Compel Document Production from Ilene Engelberg.DOCX

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: )

) PITT PENN HOLDING CO., INC., et at. I , ) )

Debtors. )

~-----------------------)

CHAPTER 11

Case No. 09-11475 (BLS) (Jointly Administered)

CERTIFICATE OF SERVICE

I, Christopher D. Loizides, hereby certify that on August 30, 2010, I did cause to be

served true and correct copies of DEBTORS' MOTION FOR ORDER DIRECTING

DOCUMENT PRODUCTION FROM ILENE ENGELBERG PURSUANT TO RULE 2004

OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURE on the parties listed on the

attached service list as indicated thereon.

DATED: August 30, 2010

et, ite 800 19801

(302) 654-0248

(302} 654-0728 loizides@loizides.com

1 The debtors are: Pitt Penn Holding Co. (Case No. 09-11475), Pitt Penn Oil Co. LLC (Case No. 09-11476), Industrial Enterprises of America, Inc. (Case No. 09-11508), EMC Packaging, Inc. (Case No. 09-11524), Today's Way Manufacturing LLC (Case No. 09-11586), and Unifide Industries LLC (Case No. 09-11587), all of which have been jointly administered.

Motion to Compel Document Production from Ilene Engelberg.DOCX

2002(i) SERVICE LIST

VIA FIRST -CLASS MAIL

James Kaplan, Esquire KAPLAN ZEENA LLP

One Biscayne Tower, Suite 3050 Miami, FL 33131

Counsel for Rene Engelberg

Ilene Engelberg

2011 N. Ocean Bl., #1604N Ft. Lauderdale, FL 33305

Derek J. Baker, Esquire REED SMITH LLP 2500 One Liberty Place Philadelphia, P A 19103

Adam Landis, Esquire

James S. Green, Jr., Esquire LANDIS RATH & COBB 919 Market Street, Suite 1800 P.O. Box 2087

Wilmington, DE 19899-2087

Andrew M. Stone, Esquire STONE LAW FIRM

1806 Frick Building

437 Grant Street Pittsburgh, PA 15219

Joseph D. Frank, Esquire FRANK GECKER LLP

325 N. LaSalle Street, Suite 625 Chicago,IL 60610

Kathleen A. Murphy, Esquire REED SMITH LLP

1201 N. Market Street, Suite 1500 Wilmington, DE 19801

Peter J. Duhig, Esquire

BUCHANAN INGERSOLL & ROONEY PC 1 000 West Street, Suite 1410

Wilmington, DE 19801

Motion to Compel Document Production from Ilene Engelberg.DOCX 2

David M. Klauder, Esquire OFFICE OF THE U.S. TRUSTEE 844 King Street, Suite 2207 Wilmington, DE 19801

Tobey M. Daluz, Esquire Joshua E. Zugerman, Esquire

BALLARD SPAHR ANDREWS & INGERSOLL LLP 919 N. Market Street, 12th Floor

Wilmington, DE 19801

John V. Fiorella, Esquire ARCHER & GREINER PC

300 Delaware Avenue, Suite 13 70 Wilmington, DE 19801

Mark S. Halpern, Esquire Lisanne L. Mikula, Esquire HALPERN & LEVY

1240 Township Line Road Drexel Hill, P A 19026

Rachel B. Mersky, Esquire

MONZACK MERSKY McLAUGHLIN & BROWDER P A 1201 N. Orange Street, Suite 400

Wilmington, DE 19801

John P. Archer, Esquire David S. Blocker, Esquire

KOHRMAN JACKSON & KRANTZ PLL 1375 E. 9th Street, 20th Floor Cleveland,OH 44144

Maurice Griffin, Deputy Atty. General DEPARTMENT OF LAW & PUBLIC SAFETY Division of Law

P.O. Box 093

Trenton, NJ 08625-0093

Nicola G. Suglia, Esquire

FLEISCHER FLEISCHER & SUGLIA Plaza 1000 at Main Street, Suite 208 Voorhees, NJ 08043

Motion to Compel Document Production from Ilene Engelberg.DOCX 3

Internal CMlECF Live Database

Page 1 of5

File a Motion:

09-11475-BLS Pitt Penn Holding Company, Inc.

Type: bk Chapter: 11 v

Assets: y Judge: BLS

Office: 1 (Delaware)

Case Flag: LEAD, CLMSAGNT

U.S. Bankruptcy Court

District of Delaware

Notice of Electronic Filing

The following transaction was received from Christopher Dean Loizides entered on 8/30/2010 at 3 :28 PM EDT and filed on 8/30/2010

Case Name: Pitt Penn Holding Company, Inc.

Case Number: 09-11475-BLS

Document Number: 520

Docket Text:

Motion to Compel/Debtors' Motion/or Order Directing Document Production from Rene Engelberg Pursuant to Fed. R. Bankr. P. 2004 Filed by Pitt Penn Holding Company, Inc .. Objections due by 9/16/2010. (Attachments: # (1) Exhibit A# (2) Certificate ofCompliance# (3) Notice # (4) Proposed Form of Order # (5) Certificate of Service) (Loizides, Christopher)

The following document(s) are associated with this transaction:

Document description:Main Document

Original filename:F:\TMW8E\DATA\files\Pitt Penn Holding Company, Inc\83010 MTC Doc Prod from Ilene Engelberg.pdf

Electronic document Stamp:

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Original filename:F:\TMW8E\DATA\files\Pitt Penn Holding Company, Inc\83010 MTC Doc Prod from Ilene Engelberg Ex A.pdf

Electronic document Stamp:

[STAMP bkecfStamp _ ID=983460418 [Date=8/30/20 1 0] [FileNumber=8791204-1] [968192983510ee75bddOI98b3d97b9fdd3eaf649f9131347ab4635a4090151gee574 47a6ea6befba16fc92e85ebld6ac3888b69f41bbc1f3112b3756239832b6]] Document description: Certificate of Compliance

Original fllename:F:\TMW8E\DATA\files\Pitt Penn Holding Company, Inc\83010 MTC Doc Prod from Ilene Engelberg Cert of Comp.pdf

Electronic document Stamp:

[STAMP bkecfStamp _ID=983460418 [Date=8/30/20 1 0] [FileNumber=8791204-2] [ge4ele7b2817f6da2669geabI7ccfObI2f605afdI2ddffb49074c3570Obl00481369 77aaeb6918ce13a8f848f36gebOb3eaa8d5712efd32590dOf625d7aOd42c]] Document description:Notice

https:llecf.deb.uscourts.gov/cgi-binIDispatch.pl?340097245726873

8/3012010

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