Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of 0 SAMUEL R. MAIZEL (Bar No. 0) samuel.maizel@dentons.com TANIA M. MOYRON (Bar No. ) tania.moyron@dentons.com DENTONS US LLP 0 South Figueroa Street, Suite 00 Los Angeles, California 00-0 Tel: () -00 / Fax: () - Attorneys for the Chapter Debtors and Debtors In Possession In re UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA - LOS ANGELES DIVISION VERITY HEALTH SYSTEM OF CALIFORNIA, INC., et al., Debtors and Debtors In Possession. Affects All Debtors Affects Verity Health System of California, Inc. Affects O Connor Hospital Affects Saint Louise Regional Hospital Affects St. Francis Medical Center Affects St. Vincent Medical Center Affects Seton Medical Center Affects O Connor Hospital Foundation Affects Saint Louise Regional Hospital Foundation Affects St. Francis Medical Center of Lynwood Foundation Affects St. Vincent Foundation Affects St. Vincent Dialysis Center, Inc. Affects Seton Medical Center Foundation Affects Verity Business Services Affects Verity Medical Foundation Affects Verity Holdings, LLC Affects De Paul Ventures, LLC Affects De Paul Ventures - San Jose Dialysis, LLC Debtors and Debtors In Possession. Lead Case No. :-bk-0-er Jointly Administered With: Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-0-er Case No. :-bk-00-er Case No. :-bk-0-er Hon. Judge Ernest M. Robles NOTICE OF FILING LISTING OBJECTIONS TO PROPOSED CURE AMOUNTS AND ASSUMPTION AND ASSIGNMENT OF CERTAIN EXECUTORY CONTRACTS AND UNEXPIRED LEASES RE: ORDER (A) AUTHORIZING THE SALE OF CERTAIN OF THE DEBTORS ASSETS TO SANTA CLARA COUNTY FREE AND CLEAR OF LIENS, CLAIMS, ENCUMBRANCES, AND OTHER INTERESTS; (B) APPROVING THE ASSUMPTION AND ASSIGNMENT OF AN UNEXPIRED LEASE RELATED THERETO; AND (C) GRANTING RELATED RELIEF [RELATES TO DOCKET NO. & ] Hearing: Date: December, 0 Time: :00 am Location: Courtroom E. Temple St., Los Angeles, CA
Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of PLEASE TAKE NOTICE that that Verity Health System of California, Inc. and the abovereferenced affiliated debtors, the debtors and debtors in possession in the above-captioned chapter bankruptcy cases, hereby submit, as Exhibit A, a list of pending objections to the proposed cure amounts and/or to assumption and assignment of certain executory contracts and unexpired leases to Santa Clara County, as referenced in the Order (A) Authorizing the Sale of Certain of the Debtors Assets to Santa Clara County Fee and Clear of Liens, Claims, Encumbrances, and Other Interests; (B) Approving the Assumption and Assignment of an Unexpired Lease Related Thereto; and (C) Granting Related Relief (the Sale Order ), to be attached to a notice of lodgment. Dated: December, 0 DENTONS US LLP SAMUEL R. MAIZEL TANIA M. MOYRON By /s/ Tania M. Moyron Tania M. Moyron Attorneys for the Chapter Debtors and Debtors In Possession 0 \V-
Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of EXHIBIT A 0 \V-
Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of 0 Objections to Proposed Cure Amounts and to Assumption and Assignment Counterparty Objection Docket No. Smith & Nephew, Inc. Smith & Nephew, Inc. s Objection to Proposed Cure Amounts for Assumed Executory Contracts Smith & Nephew, Inc. s Supplemental Objection to Proposed Cure Amounts and Limited Objection to Assumption and Assignment of Executory Contracts Roche Diagnostics Limited Objection and Reservation of Rights of Roche Diagnostics Corporation Corporation to (I) Debtors Proposed Cure Amount for Potential Assumption and Assignment of Agreements and (II) Sale Motion Supplemental Objection and Reservation of Rights of Roche Diagnostics Corporation with Respect to Debtors Supplemental Cure Notice Declaration of Douglas Durbin in Support of the (A) Limited Objection and Reservation of Rights of Roche Diagnostics Corporation to (I) Debtors Proposed Cure Amount for Potential Assumption and Assignment of Agreements and (II) Sale Motion; and (B) Supplemental Objection and Reservation of Rights of Roche Diagnostics Corporation with Respect to Debtors Supplemental Cure Notice University Healthcare Alliance, Packard Children s Health Alliance, Stanford Health Care Advantage, Stanford Blood Center, LLC, The Board of Trustees of the Leland Stanford Junior University, Stanford Health Care Stanford s Omnibus Objection to Cure Notice 0 Cigna HealthCare of California, Inc. and Life Insurance Company of North America California Department of Health Care Services Creditor OCH Forest, General Partner of O Connor Health Center, a Limited Partnership Objection of Cigna Entities to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Debtors That May be Assumed and Assigned Declaration in Support of Objection of Cigna Entities to Notice to Objection of Cigna Entities to Supplement to Notice to Counterparties to Creditor California Department of Health Care Services s Objection to () Debtors Motion for the Entry of an Order Authorizing the Sale of Property Free and Clear of All Claims, Liens, and Encumbrances; () Debtors; and Memorandum of Points and Authorities in Support Thereof OCH Forest and O Connor Health Center Response to Notice to Declaration of Charles J. Toeniskoetter in Support of OCH Forest and O Connor Health Center Response to Notice to Counterparties to C. R. Bard, Inc. C. R. Bard, Inc. s Limited Objection and Reservation of Rights to Proposed Cure Amounts for Executory Contracts 0 0 \V-
Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of 0 C. R. Bard, Inc. s Limited Objection and Reservation of Rights to 0 Proposed Cure Amounts on Supplemental Executory Contract List California Physicians Blue Shield s Objection to Cure Amount Stated in Debtor s Notice to 0 Service dba Blue Shield of California Blue Shield s Amended Objection to Cure Amount Stated in Debtor s the SpecialtyCare Objection to Cure Amounts Proposed in Notice to Counterparties to Cardiovascular Resources, LLC Amended Objection to Cure Amounts Proposed in Notice to Surgical Informations Objection of Surgical Informations Systems, LLC to Debtors Notice to Systems, LLC Counterparties to Executory Contracts and Unexpired Leases of Debtors That May be [Supplemental] Objection of Surgical Informations Systems, LLC to Debtors Supplement to Notice to Counterparties to Executory Contracts and Unexpired Leases of Care st Health Plan Care st Health Plan s Objection to Cure Amount Stated in Debtor s the Care st Health Plan s Amended Objection to Cure Amount Stated in Debtor s Notice to Counterparties to Executory Contracts and Unexpired Leases of the Abbott Laboratories Inc. Abbott Laboratories Inc. s Objection to Proposed Cure Amounts and Preliminary Objection to Proposed Assumption and Assignment of Various Contracts Abbott Laboratories Inc. s Supplemental Objections to Proposed Assumption and Assignment of Various Contracts and Reservation of Rights Cerner Corporation Response of Cerner Corporation to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Debtors That May be Assumed and Assigned Limited Objection of Cerner Corporation to Supplemental Notice to Debtors That May Be Humana Inc. Objection of Humana Inc. and its Affiliates to Proposed Cure Amounts GE HFS, LLC Objection of GE HFS, LLC to (I) Proposed Assumption and Assignment 0 of Lease and (II) Cure Obligations with Respect Thereto Pursuant to the Supplemental Objection of GE HFS, LLC to (I) Proposed Assumption and Assignment of Lease and (II) Cure Obligations with Respect Thereto Pursuant to Supplement to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Debtors That May be Assumed and Assigned Medtronic USA, Inc. Objection to (I) Notice to Counterparties to Executory Contracts and Unexpired Leases of the [Dkt. No. ] and (II) Sale Motion [Dkt. No. ] Declaration of Bob Zbylicki in Support of the Objection to (I) Notice to [Dkt. No. ] and (II) Sale Motion [Dkt. No. ] \V-
Case :-bk-0-er Doc Filed // Entered // :: Desc Main Document Page of 0 Aetna Life Insurance Company Oracle America, Inc. UnitedHealthcare Insurance Company Premier, Inc. Infor (US), Inc. Shared Imaging, LLC NTT DATA Services Holding Corporation Workday, Inc. Nantworks, LLC Experian Health, Inc. Objection to Cure Amounts Alleged by Debtors Under Executory Contracts with Aetna Life Insurance Company Oracle s Limited Objection to and Reservation of Rights Regarding Debtors () Motion for the Entry of (I) an Order () Approving Form of Asset Purchase Agreement for Stalking Horse Bidder and for Prospective Overbidders to Use, () Approving Auction Sale Format, Bidding Procedures and Stalking Horse Bid Protections, () Approving Form of Notice to be Provided to Interested Parties, () Scheduling a Court Hearing to Consider Approval of the Sale to the Highest Bidder and () Approving Procedures Related to the Assumption of Certain Executory Contracts and Unexpired Leases; and (II) an Order (A) Authorizing the Sale of Property Free and Clear of All Claims, Liens and Encumbrances ( Sale Motion ); and () Supplement to Notice to Counterparties to ( Supplemental Assumption Notice ) Objection to Cure Amount Set Forth in the Notice to Counterparties to Reservation of Rights of Premier, Inc. and its Subsidiaries with Respect to Debtors Motion for Approval of Sale of O Connor Hospital, Saint Louise Regional Hospital and Related Assets Objection of Premier, Inc. and Its Subsidiaries to the Proposed Assumption and Assignment of Contracts, Cure Amounts Declaration of David H. Harriss in Support of Objection of Premier, Inc. and its Subsidiaries to Proposed Assumption and Assignment of Contracts, and Cure Amounts Objection of Infor (US), Inc. to Debtors Sale Motion and Supplemental Cure Notice Reservation of Rights to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Debtors That May be Assumed and Assigned [Docket No. ] NTT DATA Services Holding Corporation s Limited Objection to Supplement to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Objection to Cure Amount Alleged by Debtors Under the Executory Contract with Workday, Inc. Limited Objection and Reservation and Rights of Nantworks, LLC to Supplement to Notice to Counterparties to Executory Contracts and Unexpired Leases of the Debtors That May Be Limited Objection of Experian Health, Inc. to Cure Notice and to Proposed Assumption and Assignment of Executory Contracts Request for Judicial Notice in Support of Limited Objection of Experian Health, Inc. to Cure Notice and to Proposed Assumption and Assignment of Executory Contracts 0 \V-