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This form is mandatory.

It has been approved for use by the United States Bankruptcy Court for the Central District of California.
January 2009 F 9013-1.1
Attorney or Party Name, Address, Telephone & FAX Numbers, and California State Bar Number FOR COURT USE ONLY
Attorney for
UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
In re: CHAPTER ________
CASE NUMBER
DATE:
TIME:
Debtor. COURTROOM:
NOTICE OF MOTION FOR:
(Specify name of Motion)
1. TO:
2. NOTICE IS HEREBY GIVEN that on the following date and time and in the indicated courtroom, Movant in the above-
captioned matter will move this Court for an Order granting the relief sought as set forth in the Motion and accompanying
supporting documents served and filed herewith. Said Motion is based upon the grounds set forth in the attached Motion
and accompanying documents.
3. Your rights may be affected. You should read these papers carefully and discuss them with your attorney, if you have
one. (If you do not have an attorney, you may wish to consult one.)
Hearing Date: Time: Courtroom: Floor:
255 East Temple Street, Los Angeles 411 West Fourth Street, Santa Ana
21041 Burbank Boulevard, Woodland Hills 1415 State Street, Santa Barbara
3420 Twelfth Street, Riverside
4. Deadline for Opposition Papers: This Motion is being heard on regular notice pursuant to Local Bankruptcy Rule 9013-1.
If you wish to oppose this Motion, you must file a written response with the Bankruptcy Court and serve a copy of it upon
the Movant or Movants attorney at the address set forth above no less than fourteen (14) days prior to the above hearing
date. If you fail to file a written response to this Motion within such time period, the Court may treat such failure as a
waiver of your right to oppose the Motion and may grant the requested relief.
5. Hearing Date Obtained Pursuant to Judges Self-Calendaring Procedure: The undersigned hereby verifies that the
above hearing date and time were available for this type of Motion according to the Judges self-calendaring procedures.
Dated: ______________________________________________
Law Firm Name
By: ___________________________________________
Name: ________________________________________
Attorney for Movant
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DAVID L. DUBROW (admitted pro hac vice)
RALPH A. TAYLOR, JR (admitted pro hac vice)
METTE H. KURTH (SBN 187100)
ARENT FOX LLP
555 West 5th Street, 48th Floor
Los Angeles, CA 90013-1065
Telephone: 213.629.7400 / Facsimile: 213.629.7401
Ambac Assurance Company, et al.


CITY OF SAN BERNARDINO, CALIFORNIA
9
6:12-bk-28006-MJ
9/21/12
10:00 a.m.
301
ORDER AUTHORIZING RULE 2004 EXAMINATION OF DEBTOR; DECLARATION OF RALPH A. TAYLOR, JR.
IN SUPPORT
THE UNITED STATES TRUSTEE, THE DEBTOR, THE DEBTORS COUNSEL, AND ALL OTHER NOTICE PARTIES
9/21/12 10:00 a.m.
301 3rd
$
Arent Fox LLP
/s/ Mette H. Kurth
Mette H. Kurth
Response Deadline: September 18, 2012 at 5:00 p.m.
MOTION
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DAVID L. DUBROW (admitted pro hac vice)
RALPH A. TAYLOR, JR. (admitted pro hac vice)
METTE H. KURTH (SBN 187100)
MARK A. ANGELOV (admitted pro hac vice)
ARENT FOX LLP
555 West Fifth Street, 48th Floor
Los Angeles, CA 90013-1065
Telephone: 213.629.7400
Facsimile: 213.629.7401
Dubrow.David@arentfox.com
Taylor.Ralph@arentfox.com
Kurth.Mette@arentfox.com
Angelov.Mark@arentfox.com
Attorneys for Ambac Assurance Company, Erste
Europische Pfandbrief-und Kommunalkreditbank AG
and Wells Fargo Bank, N.A., as Trustee

UNITED STATES BANKRUPTCY COURT
CENTRAL DISTRICT OF CALIFORNIA
RIVERSIDE DIVISION
In re

CITY OF SAN BERNARDINO,
CALIFORNIA,

Debtor.

Case No.: 6:12-bk-28006-MJ
Chapter 9
MOTION FOR ORDER AUTHORIZING
RULE 2004 EXAMINATION OF DEBTOR;
DECLARATION OF RALPH A. TAYLOR, JR.
IN SUPPORT

[F.R.B.P. 2004 and 9016; L.B.R. 2004-1]

Response Deadline: September 18, 2012, 5 p.m.

Date: September 21, 2012
Time: 10:00 a.m.
Judge: Hon. Meredith A. Jury
Courtroom 301
3420 Twelfth Street
Riverside, CA 92501
TO THE HONORABLE MEREDITH A. JURY, UNITED STATES BANKRUPTCY
JUDGE; THE OFFICE OF THE UNITED STATES TRUSTEE; AND ALL OTHER
PARTIES IN INTEREST:
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Ambac Assurance Company (Ambac), Erste Europische Pfandbrief-und
Kommunalkreditbank AG (EEPK) and Wells Fargo Bank, N.A., as Trustee (Wells Fargo,
and collectively with Ambac and EEPK, the POB Creditors), creditors and/or parties in interest
in the above-captioned chapter 9 case, hereby move the Court for an order authorizing the POB
Creditors to examine the City of San Bernardino, California (the Debtor or the City) pursuant
to Rule 2004(a) of the Federal Rules of Bankruptcy Procedure and for an order compelling the
City to produce documents and ESI pursuant to Rule 2004(c) of the Federal Rule of Bankruptcy
Procedure. This motion is made pursuant to this Courts Order, dated August 24, 2012, Directing
and Approving Form of Notice and Setting Deadline for filing Objections to the City of San
Bernardino, California Petition (the Order) [Docket No. 111].
The documents and ESI to be produced are listed in Exhibit A. They should be produced
on or before October 11, 2012 at the office of Arent Fox, LLP, 550 West 5
th
Street, 48
th
Floor,
Los Angeles, California 90013, or on such later date and at such other location in the greater Los
Angeles area as the POB Creditors select, upon reasonable, written notice to the City. The POB
Creditors have elected to forgo an examination of the City under oath at this juncture, although
they reserve the right to participate in or observe any examination under oath of the City
conducted by any other party or party in interest.
As is detailed in the accompanying Declaration of Ralph A. Taylor, Jr., the POB Creditors
have been working with the Citys counsel to attempt to agree on whether and what discovery
will be permitted; although some progress has been made, no final agreement has been reached as
of this date. The POB Creditors will continue to work with the Citys counsel to try to reach
agreement as to the right of the POB Creditors to obtain discovery at this stage of the proceeding
and the scope of such discovery.
The POB Creditors proposed investigation relates to the acts, conduct, property, and
liabilities that affect the Citys eligibility to be a debtor under Chapter 9 of the Bankruptcy Code.
The examination the POB Creditors seek cannot proceed under Rule 7030 or Rule 9014 of
the Federal Rules of Bankruptcy Procedure because there is currently no adversary proceeding
matter pending before this Court under which the proposed examination could take place, and the
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City disputes that there is currently a contested matter pending before this Court under which the
proposed examination could take place.
I.

BACKGROUND
A. The POB Creditors
The POB Creditors are creditors of the City and/or interested parties in this proceeding in
connection with certain municipal bonds. Specifically, the City issued its City of San Bernardino
Taxable Pension Obligation Bonds in the aggregate principal amount of $50,401,582.90,
consisting of (i) the 2005 Series A-1 (Standard Bonds), in the aggregate principal amount of
$36,050,000 (the Series A-1 Bonds), and (ii) the 2005 Series A-2 (Capital Appreciation Bonds),
in the initial aggregate principal amount of $14,351,582.90 (the Series A-2 Bonds and,
collectively the Series A Bonds), pursuant to that certain Trust Agreement dated October 1,
2005 (the Trust Agreement), by and between the Trustee and the City. The City issued these
bonds to re-fund the Citys obligations to the California Public Employees Retirement System
relating to City employee pension benefits.
Wells Fargo is the trustee under the Trust Agreement, and thus an interested party in this
proceeding. EEPK owns 100% of the Series A Bonds. It is the primary obligee under the Series
A Bonds, and thus an interested party in this proceeding.
Ambac issued a financial guaranty insurance policy, dated December 23, 2005 (the
Policy), insuring regularly scheduled principal and interest payments with respect to the Series
A-2 Bonds. Pursuant to the Policy, to the extent the City does not satisfy its payment obligations
under the Series A-2 Bonds, Ambac will be obligated to pay the bondholders (e.g., EEPK) the full
principal and interest payments when due, subject to the terms and conditions set forth in the
Policy. As a condition to payment of the insurance benefits to the bondholder, the bondholders
are obligated to assign their right, title, and interest in the Series A-2 Bonds to Ambac, and
Ambac is subrogated to all rights and remedies of the bondholders to the extent of Ambacs
payments under the Policy. Ambac is, accordingly, a party in interest in this proceeding.
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B. The Need for Discovery Regarding the Citys Eligibility for Chapter 9 Relief
On August 1, 2012, the City filed a voluntary petition for relief under Chapter 9 of the
Bankruptcy Code. The City did not negotiate with creditors prior to the filing of the bankruptcy
petition. As a result, the POB Creditors lack sufficient information about the Citys financial
condition and other issues relating to its Chapter 9 eligibility.
It is well settled law that [c]onsidering the bankruptcy court's severely limited control
over the debtor once the petition is approved, access to chapter 9 relief has been designed to be an
intentionally difficult task.
1
Because of the judicial disfavor of municipal bankruptcies, a
government entity desiring protection under chapter 9 must show that it meets a stringent
eligibility test.
The core eligibility requirements are imposed by Bankruptcy Code Section 109(c). That
provision requires, among other things, a showing that the City is insolvent.
2
In addition, in order
to be eligible for chapter 9 protection, the debtor must show that it is unable to negotiate with
creditors because such negotiation is impracticable or reasonably believes that a creditor may
attempt to obtain a transfer that is avoidable under section 547 of this title.
3

Separately from establishing the core eligibility requirements pursuant to Section 109(c),
discovery is needed to obtain evidence on the issues of whether the City qualifies as a debtor and
whether the Citys bankruptcy filing was in good faith within the meaning of Section 921(c).
Bankruptcy Code section 921(c) permits a dismissal of a chapter 9 petition if the debtor did not
file the petition in good faith or if the petition does not meet the requirements of this title.
4
Here,
the City declared a fiscal emergency, which enabled it to seek bankruptcy protection without
engaging in pre-petition settlement negotiations with creditors as required by California law.
Specifically, absent a fiscal emergency, the California Government Code requires financially
distressed municipalities to engage in a neutral evaluation process with its creditors.
5
The
legislative intent underlying this requirement is to require municipalities to explore consensual

1 In re Sullivan County Regl Refuse Disposal Dist., 165 B.R. 60, 82 (Bankr. D.N.H. 1994).
2
11 U.S.C.A. 109(c).
3
11 U.S.C.A. 109(c).
4 11 U.S.C. 921(c).
5 See CA Govt 53760.
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resolution with creditors in an attempt to avoid resorting to chapter 9.
6
The neutral evaluation
process contemplates that the negotiations will be facilitated by disclosure of relevant financial
and budget information.
7

A municipality may avoid the neutral evaluation process only by declaring a fiscal
emergency pursuant to California Government Code 53760.5. Under that provision, the City
Council is permitted to declare a fiscal emergency only upon a finding that (i) the financial state
of the local public entity jeopardizes the health, safety, or well-being of the residents of the local
public entity's jurisdiction; and (ii) the public entity is or will be unable to pay its obligations
within the next 60 days.
8
According to the Statement of Qualifications, it appears that the City
Council made the required findings and passed a resolution declaring a fiscal emergency on or
about July 18, 2012.
9

However, Section 921(c) looks beyond mere mechanical compliance with the law. The
good faith provision protects the integrity of the reorganization process by requiring
municipalities to anticipate and act to avoid having to seek chapter 9 protection.
10
The good
faith requirement is necessarily fact specific and, therefore, must be decided on a case-by-case
basis.
11
In determining whether a chapter 9 filing is in good faith, courts are guided by the good
faith standard applicable to chapter 11.
12

C. Efforts to Engage in Informal Discovery
During the pendency of this case, the POB Creditors and the City, through counsel, have
engaged in significant, good faith discussions regarding the need for reasonable, and timely,
discovery regarding the Citys eligibility for relief under Chapter 11.

6 See 2011 Cal. Stat. ch. 675, 1-2.
7 Id.
8 See CA Govt 53760.5.
9 See Docket Entry 71, 2.
10 In re Sullivan County, 165 B.R. at 80 (a municipality cannot engineer its way into the bankruptcy courts
by simply refraining from paying its debts from available assets and then claiming the resulting inability to pay debts
as they came due justified bankruptcy court relief.)
11 Collier on Bankruptcy 921.04[2] (15th ed).
12 See e.g. In re Sullivan County, 165 B.R. at 82; N.Y.C. Off-Track Betting Corp., 227 B.R. 256. 279 (Bankr.
S.D.N.Y.).
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Although the discussions have been fruitful, as of this date, the parties have not reached a
final agreement on whether or how much discovery the City will provide. The POB Creditors
will continue to work with the Citys counsel to try to reach agreement before the September 18,
2012 response deadline as to the right of the POB Creditors to obtain discovery at this stage of the
proceeding and the scope of such discovery.
II.

DISCUSSION
Pursuant to Federal Rule of Bankruptcy Procedure 2004(a), after a motion by any party
in interest, the Court may order the examination of any entity. The examination may relate to
any acts, conduct, or property or to the liabilities and financial condition of the debtor, or to any
matter which may affect the administration of the debtors estate . . . .
13

In order to evaluate the Citys eligibility for relief under Chapter 9, the POB Creditors
seek access to documents and ESI directly relevant on the issues, including, but not limited to, the
Citys financial condition, including the extent of any fiscal emergency faced by the City and the
Citys efforts, if any, to negotiate with its creditors regarding a plan of adjustment of alternatives
to bankruptcy relief. The POB Creditors request authority to have such documents and ESI
produced on October 11, 2012 at the office of Arent Fox, LLP, 550 West 5
th
Street, 48
th
Floor,
Los Angeles, California 90013, or on such later date and at such other location in the greater Los
Angeles area as the POB Creditors select, upon reasonable, written notice to the City. The
documents to be produced are listed on Exhibit A. As a part of their good faith discovery
negotiations with the City, the POB Creditors have agreed to forego an examination under oath at
this juncture.
According to the Citys bankruptcy petition and other filings, its address for purposes of
this motion is City of San Bernardino, California, 300 North "D" Street, San Bernardino,
California 92418.

13 Fed. R. Bankr. P. 2004(b).
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III.

REQUESTED RELIEF
Based on the foregoing, the POB Creditors respectfully ask the Court to enter an order
that:
1. Orders the City to produce the documents listed in Exhibit A on or before October
11, 2012 at the office of Arent Fox, LLP, 550 West 5
th
Street, 48
th
Floor, Los Angeles, California
90013, or on such later date and at such other location in the greater Los Angeles area as the POB
Creditors select, upon reasonable, written notice to the City; and
2. Grants to the POB Creditors such other reasonable and necessary relief as the
Court deems appropriate.

Dated: September 11, 2012

ARENT FOX LLP



By: /S/ Mette H. Kurth
DAVID L. DUBROW (admitted pro hac vice)
RALPH A. TAYLOR, JR. (admitted pro hac vice)
METTE H. KURTH (SBN 187100)
MARK A. ANGELOV (admitted pro hac vice)
ARENT FOX LLP
555 West Fifth Street, 48th Floor
Los Angeles, CA 90013-1065
Telephone:213.629.7400
Facsimile: 213.629.7401

Dubrow.David@arentfox.com
Taylor.Ralph@arentfox.com
Kurth.Mette@arentfox.com
Angelov.Mark@arentfox.com

Counsel for Ambac Assurance Company, Erste
Europische Pfandbrief-und Kommunalkreditbank AG
and Wells Fargo Bank, N.A., as Trustee


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ARENT Fox LLP
ATTDRNirYS AT LAW
Los ANGELES
DECLARATON OF RALPH A. TAYLOR, JR
I, Ralph A. Taylor, Jr., declare as follows:
1. I am a partner in ARENT FOX LLP and counsel for Ambac Assurance Company
("Ambac"), Erste Europaische Pfandbrief-und Kommunalkreditbank AG ("EEPK") and Wells
Fargo Bank, N.A., as Trustee ("Wells Fargo," and collectively with Ambac and EEPK, the "POB
Creditors"), creditors and/or interested parties in this bankruptcy case.
2. I submit this declaration in support of the POB Creditors' motion for an order
authorizing the POB Creditors to examine the City of San Bernardino, California (the "Debtor" or
the "City") pursuant to Rule 2004(a) of the Federal Rules of Bankruptcy Procedure and for an
order compelling the City to produce documents and ESI pursuant to Rule 2004(c) of the Federal
Rule of Bankruptcy Procedure. The following is stated of my own personal knowledge or belief.
3. Counsel for the parties have engaged in extensive meet and confer discussions in
connection with the relief sought by this motion. The POB Creditors, through their counsel, have
regularly communicated with Paul R. Glassman of STRADLING YOCCA CARLSON &
RAUTH, P.C., counsel for the City, throughout the pendency of this case. They have discussed
the entitlement to and scope and timing of discovery sought by the POB Creditors in order to
evaluate the City eligibility for relief under chapter 9 of the Bankruptcy Code.
4. Although the discussions have been fruitful, as of this date, the parties have not
reached a final agreement on discovery issues. This motion is made pursuant to this Court's
Order, dated August 24, 2012, Directing and Approving Form ofNotice and Setting Deadline for
filing Objections to the City of San Bernardino, California Petition, which, among other things,
set September 11, 2012 as the deadline for filing motions seeking discovery from the City.
5. Resort to Federal Rules of Bankruptcy Procedure Rule 2004 to compel discovery
from the City is appropriate. There is currently no adversary proceeding matter pending before
this Court under which the POB Creditors can examine the City pursuant to Federal Rules of
Bankruptcy Procedure 7030 or 9014. In addition, in the prior meet and confer discussions, the
counsel for the City indicated the City disputes that there is currently a contested matter pending
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1 before this Court under which the proposed examination could take place.
2 6. In light of the foregoing, a Rule 2004 examination is necessary and appropriate to
3 thoroughly evaluate the City's financial practices, assets and liabilities, as well as other aspects of
4 the City's chapter 9 eligibility.
5 7. Based upon the City's bankruptcy petition, I believe its principal address for
6 purposes ofthis case is City of San Bernardino, California, 300 North "D" Street, San Bernardino,
7 California 92418.
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8. The proposed location for the examination of the Debtor and production of
documents is less than one hundred miles from the Debtor's principal place of business.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is, to the best of my knowledge, true and correct.
Executed this
ARENT FOX LLP
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EXHIBIT A

DEFINITIONS
The following definitions shall apply to these Requests.
1. Bankruptcy Code means title 11 of the United States Code, 11 U.S.C.
2. CAFR means the Comprehensive Audited Financial Report.
3. Chapter 9 means chapter 9 of the Bankruptcy Code.
4. City, you, or your means the City of San Bernardino as well as all of its
present or past employees, servants, agents, attorneys, investigators, representatives, or any other
person or entity directly or indirectly subject to its respective control, and/or purporting to act on
its behalf.
5. Communication means any transmittal of information (in the form of facts,
ideas, inquiries, photographs, drawings or otherwise), and a document request for
communications includes correspondence, telexes, facsimile transmissions, telecopies,
electronic mail (e-mail), all attachments and enclosures thereto, recordings in any medium of
oral communications, telephone logs, message logs, and notes and memoranda concerning written
or oral communications, and any translations thereof.
6. The term Document is used in the broadest sense permitted by the Federal Rules
of Civil Procedure and expressly includes without limitation the original (or an identical duplicate
if the original is not available) and any non-identical copies (whether non-identical because of
notes made on copies or attached comments, annotations, marks, transmission notations, or
highlighting of any kind) of writings of every kind and description that are fixed in any form of
physical media. Physical media include but are not limited to paper, phonographic media,
photographic film media (including pictures, film slides, and microfilm), magnetic media
(including but not limited to hard disks or drives, floppy disks, compact disks, CD-ROMs, DVD-
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ROMs, flash drives, and magnetic tapes of any kind), computer memory, optical media, magneto-
optical media, and other physical media on which notations or marking of any kind can be
affixed. By way of example only, documents include any memorandum, letter, request envelope,
correspondence, electronic mail, report, note, self-stick removable note, notebook, scrapbook,
message, telephone message, telephone log, diary, journal, appointment calendar, calendar, group
calendar scheduler, drawing, painting, accounting paper, minutes, working paper, financial report,
accounting report, ledger, drafts, facsimile, facsimile transmission, report, contract, invoice,
record of purchase or sale, teletype message, blueprint, sketch, drawing, diagram, chart, graph,
index, directory, phone card, debit card, credit card, template computer directory, computer disk,
computer tape or any other written, printed, typed, punched, taped, filmed, or graphic matter or
recording or photograph, however produced or reproduced. Documents also include the file,
folder tabs, and labels appended to or containing any documents.
7. ESI means Electronically Stored Information as the term is most broadly
understood under the Federal Rules of Civil Procedure and includes, without limitation,
information stored in any medium from which information can be obtained either directly or, if
necessary, after translation into a reasonably usable form.
8. General Fund means the Citys primary fund for most day-to-day operations.
9. The terms Person and Persons include not only natural persons, but also,
without limitation, firms, partnerships, associations, corporations, and other legal entities,
divisions, departments, or other units thereof.
10. Petition means the Citys petition for relief under Chapter 9 filed in the above-
captioned proceeding, dated August 1, 2012.
11. Relating to means referring to, in connection with, pertaining to, describing,
discussing, analyzing, reflecting, summarizing, evidencing, embodying or constituting.
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INSTRUCTIONS
1. Each request for production is intended to be continuing, and you are requested to
promptly and seasonably amend your responses if at any later date you obtain any additional
facts, documents, or ESI, you make any assumptions or contentions, or you reach any
conclusions or opinions that are different from those forming the basis for your responses to these
requests for production. If any documents or ESI that are within the scope of a request herein
are not presently within your possession, custody, or control or are not identifiable or available
but come within your possession, custody, or control or become identifiable or available at some
future time, you shall notify counsel for the Requesting Parties in writing and shall provide the
documents or ESI to counsel for the Requesting Parties in a timely manner, but in no instance
later than thirty (30) days after such documents or ESI are obtained or such shorter time as
required by the Federal Rules of Civil Procedure or order of the Court.
2. If you contend that you are entitled to withhold from production any part of any
document or ESI requested on the basis of the attorney-client privilege, the work-product
doctrine, or any other basis, then for each such document or ESI, state:
a. The nature of the document or ESI;
b. The date of the document or ESI;
c. A detailed summary or description of the document or ESI;
d. Any and all persons who prepared, sent, and/or received any original or
any copy of the document or ESI;
e. The person in possession, custody, or control of the document or ESI; and
f. The basis on which you contend that you are entitled to withhold the
document or ESI from production.
3. If you object to all or part of any request on the grounds of vagueness, over-
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breadth, burdensomeness, or any similar ground, produce documents and ESI fairly responsive
to the substance of the request, noting in your response your construction of any vague terms and
disclosing the limitations you impose on the request to enable you to respond.
4. If you object to producing part, but not all of a document or ESI, the portion not
objected to must be produced and disclosed to the fullest extent possible. Please identify each
part of any document or ESI withheld, redacted, or altered and provide the information required
by instruction 2 above as to each part withheld, redacted, or altered, and provide the date of the
redaction or alteration and the person performing the redaction or alteration.
5. More than one of these requests may ask for the same document or ESI. The
presence of such duplication is not to be interpreted to narrow or limit the normal interpretation
placed upon each individual request. Where a document or ESI is requested in more than one
numbered paragraph, only non-identical copies of it need be produced.
6. A request for the production of a document or ESI includes documents and ESI
in the possession, custody, or control of you and/or your present or past representatives, agents,
and experts, and all documents and ESI otherwise available to you.
7. Produce documents and ESI for inspection as they are kept in the usual course of
business or organize and label them to correspond with the categories in the request. Documents
stored in paper form should be produced with a copy of the file folder in which they were stored.
If no document or ESI exists that is responsive to a request, so state.
8. Absent written agreement or order to the contrary, ESI should be produced in its
native format in the file type for (or of) the application in which such ESI is normally created,
viewed, and/or modified (for example, and for example only, Word, Excel, Powerpoint, E-mail,
or Text). Discoverable information in the form of Powerpoint, Excel, or similar presentation or
spreadsheet formats (including but not limited to spreadsheets or charts prepared in Word or other
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wordprocessing formats) that exists in both paper and electronic format should be produced in
both formats.
9. ESI data files should be produced in an electronic form usable by SQL Server,
Microsoft Access, Microsoft Excel, or a delimited file that can be readily uploaded into one of
those programs. Provide all documentation and explanatory materials necessary to understand the
data, including file layouts, field definitions or valid values for all fields, data dictionaries,
manuals, source tables, relationship tables, and business rules.
10. Unless otherwise specified, when construing the scope of any request, the terms
thereof shall be given their most expansive and inclusive interpretations, including but not limited
to:
a. Construing the use of a verb in any tense to include use in all other tenses
as necessary to make the request more inclusive;
b. Construing the singular or plural forms of a word to mean the plural or
singular forms of the word, respectively, as necessary to make the request
more inclusive;
c. Construing the words and and or either disjunctively or conjunctively
as necessary to make the request more inclusive; and
d. Construing the terms any and all to mean any and all as necessary to
make the request more inclusive.
11. Unless otherwise indicated, the time period for the documents requested is July 1,
2007 to the present.

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DOCUMENT AND ESI REQUESTS
In accordance with the foregoing definitions and instructions, please produce all
documents and ESI within your possession, custody, or control that are responsive to the
following requests:
1. The final CAFR for the City for the fiscal year ended June 30, 2011, and any
restatements or modifications thereof.
2. All restatements or modifications of any CAFR for the City for the fiscal years
ending June 30, 2007, June 30, 2008, June 30, 2009, and June 30, 2010.
3. A copy of each audit/CAFR engagement letter or agreement between the City and
any independent auditor for the fiscal years ending June 30, 2011, June 30, 2010, and June 30,
2009.
4. Copies of all official communications between any auditor and the City for the
fiscal years ending June 30, 2011, June 30, 2010, and June 30, 2009.
5. A copy of the Citys Budget Sustainability Plan (6/2012).
6. A copy of each City Manager Plan referred to on page 33 of the document entitled
Pre-Pendency Plan City of San Bernardino, dated August 29, 2012.
7. All documents and ESI relating to or used in the preparation of your budget for
the fiscal year ending June 30, 2013.
8. Documents and ESI sufficient to show the Citys fund balances, or approximate
fund balances, by Statement No. 54 of the Governmental Accounting Standards Series category
for the twelve month period immediately preceding the filing of the Petition.
9. Documents and ESI sufficient to show the restricted nature of each fund account
identified in Exhibit A to the Declaration of Jason P. Simpson filed in support of your
Memorandum of Facts and Law in Support of the Statement of Qualifications Under Section
109(c) of the Bankruptcy Code [Docket No. 125].
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ATTORNEYS AT LAW
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10. The most complete list, chart or spreadsheet that you have showing each real
estate holding of the City; its original acquisition date; its current and potential uses; the original
source of funds for its acquisition; its zoning and other restrictions; and any encumbrance on it.
11. Documents and ESI sufficient to show each of your receivables, including the
amount, expected payment date, and payer.
12. Documents and ESI sufficient to show your operating results for the fiscal years
ending June 30, 2012 and June 30, 2011.
13. Documents and ESI sufficient to identify each item that affects or affected your
revenues or expenses by $250,000 or more in the twelve (12) month period preceding the date of
the filing of your Petition.
14. Documents and ESI comprising detailed cost estimate for each budgeted City
employee position showing for each position the position title; compensation rate; actual wages
paid or to be paid, segregated by regular, sick, overtime, FMLA, overtime or other pay type; and
other relevant earnings paid or budgeted for the latest annual period for which you have such
data.
15. Documents and ESI sufficient to show the basis for setting public safety
employee salaries in accordance with the requirements of your City Charter.
16. Documents and ESI sufficient to show overtime pay as a percentage of salaries
and benefits of the Citys employees for the fiscal year ending June 30, 2012 and budgeted for
the fiscal year ending June 30, 2013.
17. Documents and ESI sufficient to identify the options the City is currently
considering to reduce prospective staffing and overtime costs.
18. Documents and ESI sufficient to identify the Citys employee benefit structure,
including annualized costs for all employee and retiree benefits.
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ATTORNEYS AT LAW
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19. A copy of each collective bargaining agreement or other labor-related agreement
or contract between the City and any employee group, bargaining unit, or collective in effect at
anytime between January 1, 2005, and the present.
20. A copy of each judgment, award, or settlement entered, awarded, or agreed to in
any litigation or arbitration between the City and any other person in which the judgment, award,
or settlement affects the rights, obligations, duties, or liabilities of the City, the performance of
which would cost the City $400,000 or more in the fiscal year ending June 30, 2012.
21. The Summary Plan Document for each City employee health benefit plan and
documents and ESI sufficient to show the premiums for the City and the employee.
22. Documents and ESI sufficient to show the options the City is currently
considering to reduce prospective employee-health-benefit costs.
23. The Summary Plan Document for each City retiree health benefit plan and
documents and ESI sufficient to show the premiums for the City and the retiree.
24. Documents and ESI sufficient to show the options the City is currently
considering to reduce prospective retiree- health-benefit costs.
25. The Summary Plan Document for each City pension or retirement plan.
26. The last three actuarial reports issued by the California Public Employee
Retirement System (CalPERS) for both Miscellaneous and Safety employees.
27. Documents and ESI sufficient to show the options the City is currently
considering with respect to pension benefit reforms (e.g. premium allocation, COLA reductions
or elimination, plan freeze, timing and replacement plan structures, retirement ages, service
credits, and pensionable salary rules).
28. Documents and ESI sufficient to disclose the Citys policies relating to financial
reserves and justification for valuation of each such reserve.
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ATTORNEYS AT LAW
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29. A revenue ledger for each City restricted fund.
30. For each City revenue source, documents and ESI sufficient to show the actual
revenues received by the City for the last 36 months, prospective grown assumptions over the
next five (5) years, and the difference between the actual and budgeted revenues.
31. Documents and ESI sufficient to identify departmental cuts and other balancing
measures with annual impact, segregated between one-time items and recurring items, included in
the budgets for the fiscal years ending June 30, 2013 and 2014.
32. Documents and ESI sufficient to indentify long term projections and
accompanying key growth assumptions for fiscal year ending June 30, 2013.
33. All documents and ESI relating to any work-out or restructuring negotiations, or
the consideration of any such negotiations, with any creditor, including those listed in Docket No.
41 (List of Creditors Holding 20 Largest Unsecured Claims), prior to filing the Petition.
34. Documents and ESI sufficient to identify all assets that you contend were at risk
of loss if you had negotiated with creditors, or any of them, prior to filing the Petition.
35. All documents and ESI relating to any perceived harm to the City that might
have resulted from delaying the filing of the Petition.
36. All documents and ESI relating to any plan of adjustment of the Citys debts
contemplated or in place at the time the Petition was filed.
37. All documents and ESI relating to any plan of adjustment or the feasibility of
any such plan prior to filing the Petition.
38. All documents and ESI relating to the reasons for filing the Petition when you
did, including all perceived benefits and detriments of such filing.
39. All documents and ESI relating to any alternatives to a Chapter 9 filing
considered or known by you prior to the Petition filing, and the viability or perceived viability of
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each such alternative.
40. All documents and ESI relating to each alternative to Chapter 9 filing that you
identified or considered and the reasons for rejecting them.
41. All documents and ESI that identify or discuss any debt or obligation, or political
consequence, that the filing of the Petition enabled you to avoid or defer.
42. All documents and ESI sufficient to identify any pending or threatened litigation
(including any arbitration, administrative hearing, or other adversarial proceeding) in which you
were able to avoid a judgment or settlement by filing your Petition when you did.
43. All documents and ESI relating to your efforts to identify and determine ways to
increase your sources of revenue, including by increasing existing, or imposing new, taxes or
fees.
44. All documents and ESI relating to your efforts to identify and determine voter
support for or opposition to any tax increase or any other revenue enhancement activity prior to
the filing of the Petition.
45. All documents and ESI relating to your efforts to identify and determine any
voter support for or opposition to any cost reduction measures prior to the filing of the Petition.
46. All documents and ESI relating to efforts by any person to obtain an avoidable
transfer from you, including in your production documents and ESI relating to efforts to
execute against your property in 90 days prior to the filing of your Petition.
47. Documents and ESI sufficient to identify the undisputed obligations that you
claim you could not pay as they became due prior to or contemporaneously with the filing of the
Petition, the basis for the obligation, the amount of each such obligation, the date on which
payment was due, and the reason for non-payment.
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ATTORNEYS AT LAW
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48. All documents and ESI relating to your estimates and projections of the budget
deficit for the fiscal year ending June 30, 2013, including documents and ESI sufficient to
identity the timing and extent of the changes in such estimates and projections.
49. All documents and ESI relating to your estimates and projections of the General
Fund deficit for the fiscal year ending June 30, 2013, including documents and ESI sufficient to
identity the timing and extent of the changes in such estimates and projections.
50. All documents and ESI relating to your estimates and projections of the General
Fund reserves during the last four years, including documents and ESI sufficient to identity the
timing and extent of the changes in such estimates and projections.
51. All documents and ESI relating to the resignations or departures of your last
Director of Finance and your last City Manager, including resignation letters, severance
agreements, termination notices, and your internal communications relating to the resignations
or departures.
52. The Citys April 3, 2012 Mid-Year Budget Report and all of the Citys general
ledger reports for the fiscal years ending June 30, 2011, and June 30, 2012.

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This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is:
Arent Fox LLP, Gas Company Tower, 555 West Fifth Street, 48th Floor, Los Angeles, CA 90013.


A true and correct copy of the foregoing document entitled (specify): MOTION FOR ORDER AUTHORIZING RULE 2004
EXAMINATION OF DEBTOR; DECLARATION OF RALPH A. TAYLOR, JR. IN SUPPORT will be served or was served
(a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below:

1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General
Orders and LBR, the foregoing document will be served by the court via NEF and hyperlink to the document. On (date)
September 11, 2012, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined
that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated
below:





Service information continued on attached page

2. SERVED BY UNITED STATES MAIL:
On (date) September 11, 2012, I served the following persons and/or entities at the last known addresses in this
bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United
States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that
mailing to the judge will be completed no later than 24 hours after the document is filed.





Service information continued on attached page

3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method
for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on (date) _______________, I served
the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to
such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration
that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is
filed.





Service information continued on attached page

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

September 11, 2012 ADRIANE I. LARK
/s/ Adriane I. Lark
Date Printed Name Signature
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This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF):

Jerrold Abeles on behalf of Interested Party Ambac Assurance Company
abeles.jerry@arentfox.com, labarreda.vivian@arentfox.com

Joseph M Adams on behalf of Interested Party Courtesy NEF
jadams@lawjma.com

Andrew K Alper on behalf of Creditor BANK OF AMERICA, N.A.
aalper@frandzel.com, efiling@frandzel.com;ekidder@frandzel.com

Thomas V Askounis on behalf of Interested Party Courtesy NEF
taskounis@askounisdarcy.com

Anthony Bisconti on behalf of Interested Party Courtesy NEF
tbisconti@bmkattorneys.com

Jeffrey E Bjork on behalf of Interested Party Courtesy NEF
jbjork@sidley.com

Sarah C Boone on behalf of Interested Party Courtesy NEF
sboone@marshackhays.com, ecfmarshackhays@gmail.com

J Scott Bovitz on behalf of Creditor U.S. TelePacific Corp.
bovitz@bovitz-spitzer.com

Jeffrey W Broker on behalf of Interested Party Courtesy NEF
jbroker@brokerlaw.biz

Deana M Brown on behalf of Interested Party Courtesy NEF
dbrown@milbank.com

Michael J Bujold on behalf of U.S. Trustee United States Trustee (RS)
Michael.J.Bujold@usdoj.gov

Christina M Craige on behalf of Interested Party Courtesy NEF
ccraige@sidley.com

Alex Darcy on behalf of Creditor Marquette Bank
adarcy@askounisdarcy.com

Susan S Davis on behalf of Interested Party Courtesy NEF
sdavis@coxcastle.com

Robert H Dewberry on behalf of Creditor Allison Mechanical, Inc.
robert.dewberry@dewlaw.net

Todd J Dressel on behalf of Creditor Pinnacle Public Finance, Inc.
dressel@chapman.com, lubecki@chapman.com

Chrysta L Elliott on behalf of Interested Party Courtesy NEF
elliottc@ballardspahr.com, manthiek@ballardspahr.com

Scott Ewing on behalf of Interested Party Rust Consulting/Omni Bankruptcy
contact@omnimgt.com, sewing@omnimgt.com

Paul R. Glassman on behalf of Debtor City of San Bernardino, California
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Main Document Page 24 of 31

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
pglassman@sycr.com

Everett L Green on behalf of U.S. Trustee United States Trustee (RS)
everett.l.green@usdoj.gov

Chad V Haes on behalf of Interested Party Courtesy NEF
chaes@marshackhays.com, ecfmarshackhays@gmail.com

James A Hayes on behalf of Interested Party Courtesy NEF
jhayes@cwlawyers.com

M Jonathan Hayes on behalf of Interested Party Courtesy NEF
jhayes@hayesbklaw.com, roksana@hayesbklaw.com;carolyn@hayesbklaw.com;elizabeth@hayesbklaw.com

D Edward Hays on behalf of Creditor San Bernardino City Professional Firefighters Local 891
ehays@marshackhays.com, ecfmarshackhays@gmail.com

Eric M Heller on behalf of Interested Party Courtesy NEF
eric.m.heller@irscounsel.treas.gov

Bonnie M Holcomb on behalf of Interested Party Courtesy NEF
bonnie.holcomb@doj.ca.gov

Whitman L Holt on behalf of Interested Party Courtesy NEF
wholt@ktbslaw.com

Michelle C Hribar on behalf of Interested Party San Bernardino Public Employees Association
mch@sdlaborlaw.com

Steven J Katzman on behalf of Creditor Certain Retired Employees of the City of San Bernardino
SKatzman@bmkattorneys.com

Jane Kespradit on behalf of Interested Party Courtesy NEF
jane.kespradit@limruger.com, amy.lee@limruger.com

Mette H Kurth on behalf of Interested Party Ambac Assurance Company
kurth.mette@arentfox.com

Richard A Marshack on behalf of Interested Party Courtesy NEF
rmarshack@marshackhays.com, lbergini@marshackhays.com;ecfmarshackhays@gmail.com

Gregory A Martin on behalf of Interested Party Courtesy NEF
gmartin@winston.com

David J Mccarty on behalf of Interested Party David McCarty
dmccarty@sheppardmullin.com, pibsen@sheppardmullin.com

Reed M Mercado on behalf of Interested Party M. Mercado
rmercado@sheppardmullin.com

Aron M Oliner on behalf of Interested Party San Bernardino Police Officers Association
roliner@duanemorris.com

Scott H Olson on behalf of Creditor Kohl's Department Stores, Inc.
solson@seyfarth.com


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Main Document Page 25 of 31

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
Dean G Rallis on behalf of Interested Party Courtesy NEF
drallis@sulmeyerlaw.com

Christopher O Rivas on behalf of Interested Party Courtesy NEF
crivas@reedsmith.com

Kenneth N Russak on behalf of Interested Party Courtesy NEF
krussak@frandzel.com, efiling@frandzel.com;dmoore@frandzel.com

Gregory M Salvato on behalf of Interested Party Courtesy NEF
gsalvato@salvatolawoffices.com, calendar@salvatolawoffices.com

Mark C Schnitzer on behalf of Attorney Mark Schnitzer
mschnitzer@rhlaw.com, mschnitzer@verizon.net

Benjamin Seigel on behalf of Interested Party Courtesy NEF
bseigel@buchalter.com, IFS_filing@buchalter.com

Diane S Shaw on behalf of Interested Party Courtesy NEF
diane.shaw@doj.ca.gov

Jason D Strabo on behalf of Creditor U.S. Bank National Association, not individually, but as Indenture Trustee
jstrabo@mwe.com, zwinston@mwe.com

Matthew J Troy on behalf of Creditor United States of America
matthew.troy@usdoj.gov

United States Trustee (RS)
ustpregion16.rs.ecf@usdoj.gov

Anne A Uyeda on behalf of Interested Party Courtesy NEF
auyeda@bmkattorneys.com

Annie Verdries on behalf of Interested Party Courtesy NEF
verdries@lbbslaw.com

Brian D Wesley on behalf of Interested Party Courtesy NEF
brian.wesley@doj.ca.gov
Case 6:12-bk-28006-MJ Doc 156 Filed 09/11/12 Entered 09/11/12 19:50:34 Desc
Main Document Page 26 of 31

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 9013-3.1.PROOF.SERVICE
2. SERVED BY UNITED STATES MAIL:

Judge

Honorable Meredith A. Jury
United States Bankruptcy Judge
United States Bankruptcy Court
3420 Twelfth Street
Riverside, CA 92501-3819.

Debtor

City of San Bernardino, California
City Hall
300 North "D" Street
San Bernardino, CA 92418

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File a Motion:
6:12-bk-28006-MJ City of San Bernardino, California
U.S. Bankruptcy Court
Central District Of California
Notice of Electronic Filing

The following transaction was received from Mette H Kurth entered on 9/11/2012 at 4:59 PM PDT and
filed on 9/11/2012
Docket Text:
Motion for 2004 Examination -- Motion For Order Authorizing Rule 2004 Examination Of Debtor;
Declaration Of Ralph A. Taylor, Jr. In Support, with Proof of Service, Filed by Interested Party Ambac
Assurance Company (Kurth, Mette)
The following document(s) are associated with this transaction:

6:12-bk-28006-MJ Notice will be electronically mailed to:

Jerrold Abeles on behalf of Interested Party Ambac Assurance Company
abeles.jerry@arentfox.com, labarreda.vivian@arentfox.com

Joseph M Adams on behalf of Interested Party Courtesy NEF
jadams@lawjma.com

Andrew K Alper on behalf of Creditor BANK OF AMERICA, N.A.
aalper@frandzel.com, efiling@frandzel.com;ekidder@frandzel.com

Thomas V Askounis on behalf of Interested Party Courtesy NEF
taskounis@askounisdarcy.com

Anthony Bisconti on behalf of Interested Party Courtesy NEF
tbisconti@bmkattorneys.com

Type: bk Chapter: 9 v Office: 6 (Riverside)
Assets: y Judge: MJ
Case Name: City of San Bernardino, California
Case Number: 6:12-bk-28006-MJ
Document Number: 152
Document description:Main Document
Original filename:2012 0911 - SB 2004 Motion.pdf
Electronic document Stamp:
[STAMP bkecfStamp_ID=1106918562 [Date=9/11/2012] [FileNumber=58723235-
0] [153fcd5c3d45f1b6937d1973af3f111798dd1cc23f1f3510e259e2e5f56cb6a092
e8dcd956b786457d1774f062d6c6638010776150cdf6add1238ad011f8c172]]
Page 1 of 4 CM/ECF - U.S. Bankruptcy Court (v4.3 - LIVE)
9/11/2012 https://ecf.cacb.uscourts.gov/cgi-bin/Dispatch.pl?585082460850448
Case 6:12-bk-28006-MJ Doc 156 Filed 09/11/12 Entered 09/11/12 19:50:34 Desc
Main Document Page 28 of 31
Jeffrey E Bjork on behalf of Interested Party Courtesy NEF
jbjork@sidley.com

Sarah C Boone on behalf of Interested Party Courtesy NEF
sboone@marshackhays.com, ecfmarshackhays@gmail.com

J Scott Bovitz on behalf of Creditor U.S. TelePacific Corp.
bovitz@bovitz-spitzer.com

Jeffrey W Broker on behalf of Interested Party Courtesy NEF
jbroker@brokerlaw.biz

Deana M Brown on behalf of Interested Party Courtesy NEF
dbrown@milbank.com

Michael J Bujold on behalf of U.S. Trustee United States Trustee (RS)
Michael.J.Bujold@usdoj.gov

Christina M Craige on behalf of Interested Party Courtesy NEF
ccraige@sidley.com

Alex Darcy on behalf of Creditor Marquette Bank
adarcy@askounisdarcy.com

Susan S Davis on behalf of Interested Party Courtesy NEF
sdavis@coxcastle.com

Robert H Dewberry on behalf of Creditor Allison Mechanical, Inc.
robert.dewberry@dewlaw.net

Todd J Dressel on behalf of Creditor Pinnacle Public Finance, Inc.
dressel@chapman.com, lubecki@chapman.com

Chrysta L Elliott on behalf of Interested Party Courtesy NEF
elliottc@ballardspahr.com, manthiek@ballardspahr.com

Scott Ewing on behalf of Interested Party Rust Consulting/Omni Bankruptcy
contact@omnimgt.com, sewing@omnimgt.com

Paul R. Glassman on behalf of Debtor City of San Bernardino, California
pglassman@sycr.com

Everett L Green on behalf of U.S. Trustee United States Trustee (RS)
everett.l.green@usdoj.gov

Chad V Haes on behalf of Interested Party Courtesy NEF
chaes@marshackhays.com, ecfmarshackhays@gmail.com

James A Hayes on behalf of Interested Party Courtesy NEF
jhayes@cwlawyers.com

Page 2 of 4 CM/ECF - U.S. Bankruptcy Court (v4.3 - LIVE)
9/11/2012 https://ecf.cacb.uscourts.gov/cgi-bin/Dispatch.pl?585082460850448
Case 6:12-bk-28006-MJ Doc 156 Filed 09/11/12 Entered 09/11/12 19:50:34 Desc
Main Document Page 29 of 31
M Jonathan Hayes on behalf of Interested Party Courtesy NEF
jhayes@hayesbklaw.com,
roksana@hayesbklaw.com;carolyn@hayesbklaw.com;elizabeth@hayesbklaw.com

D Edward Hays on behalf of Creditor San Bernardino City Professional Firefighters Local 891
ehays@marshackhays.com, ecfmarshackhays@gmail.com

Eric M Heller on behalf of Interested Party Courtesy NEF
eric.m.heller@irscounsel.treas.gov

Bonnie M Holcomb on behalf of Interested Party Courtesy NEF
bonnie.holcomb@doj.ca.gov

Whitman L Holt on behalf of Interested Party Courtesy NEF
wholt@ktbslaw.com

Michelle C Hribar on behalf of Interested Party San Bernardino Public Employees Association
mch@sdlaborlaw.com

Steven J Katzman on behalf of Creditor Certain Retired Employees of the City of San Bernardino
SKatzman@bmkattorneys.com

Jane Kespradit on behalf of Interested Party Courtesy NEF
jane.kespradit@limruger.com, amy.lee@limruger.com

Mette H Kurth on behalf of Interested Party Ambac Assurance Company
kurth.mette@arentfox.com

Richard A Marshack on behalf of Interested Party Courtesy NEF
rmarshack@marshackhays.com, lbergini@marshackhays.com;ecfmarshackhays@gmail.com

Gregory A Martin on behalf of Interested Party Courtesy NEF
gmartin@winston.com

David J Mccarty on behalf of Interested Party David McCarty
dmccarty@sheppardmullin.com, pibsen@sheppardmullin.com

Reed M Mercado on behalf of Interested Party M. Mercado
rmercado@sheppardmullin.com

Aron M Oliner on behalf of Interested Party San Bernardino Police Officers Association
roliner@duanemorris.com

Scott H Olson on behalf of Creditor Kohl's Department Stores, Inc.
solson@seyfarth.com

Dean G Rallis on behalf of Interested Party Courtesy NEF
drallis@sulmeyerlaw.com

Christopher O Rivas on behalf of Interested Party Courtesy NEF
crivas@reedsmith.com
Page 3 of 4 CM/ECF - U.S. Bankruptcy Court (v4.3 - LIVE)
9/11/2012 https://ecf.cacb.uscourts.gov/cgi-bin/Dispatch.pl?585082460850448
Case 6:12-bk-28006-MJ Doc 156 Filed 09/11/12 Entered 09/11/12 19:50:34 Desc
Main Document Page 30 of 31

Kenneth N Russak on behalf of Interested Party Courtesy NEF
krussak@frandzel.com, efiling@frandzel.com;dmoore@frandzel.com

Gregory M Salvato on behalf of Interested Party Courtesy NEF
gsalvato@salvatolawoffices.com, calendar@salvatolawoffices.com

Mark C Schnitzer on behalf of Attorney Mark Schnitzer
mschnitzer@rhlaw.com, mschnitzer@verizon.net

Benjamin Seigel on behalf of Interested Party Courtesy NEF
bseigel@buchalter.com, IFS_filing@buchalter.com

Diane S Shaw on behalf of Interested Party Courtesy NEF
diane.shaw@doj.ca.gov

Jason D Strabo on behalf of Creditor U.S. Bank National Association, not individually, but as Indenture
Trustee
jstrabo@mwe.com, zwinston@mwe.com

Matthew J Troy on behalf of Creditor United States of America
matthew.troy@usdoj.gov

United States Trustee (RS)
ustpregion16.rs.ecf@usdoj.gov

Anne A Uyeda on behalf of Interested Party Courtesy NEF
auyeda@bmkattorneys.com

Annie Verdries on behalf of Interested Party Courtesy NEF
verdries@lbbslaw.com

Brian D Wesley on behalf of Interested Party Courtesy NEF
brian.wesley@doj.ca.gov

6:12-bk-28006-MJ Notice will not be electronically mailed to:

Roger Jon Diamond on behalf of Creditor Manta Management Corporation Inc
2115 Main Street
Santa Monica, CA 90405



Page 4 of 4 CM/ECF - U.S. Bankruptcy Court (v4.3 - LIVE)
9/11/2012 https://ecf.cacb.uscourts.gov/cgi-bin/Dispatch.pl?585082460850448
Case 6:12-bk-28006-MJ Doc 156 Filed 09/11/12 Entered 09/11/12 19:50:34 Desc
Main Document Page 31 of 31