ML022140214

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Notice of Appearance & Request for Special Notice
ML022140214
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 07/18/2002
From: Elizabeth Wilson
Kelley, Drye & Warren, LLP
To:
Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California
References
01-30923 DM
Download: ML022140214 (2)


Text

1 ERIC R. WILSON (State Bar No. 192220)

ROBERT C. SHENFELD, ESQ.' 1 proceeding(s) related thereto, be delivered to and served upon the undersigned representative of 2 KELLEY DRYE & WARREN LLP 777 South Figueroa Street, Suite 2700 2 Satellite as follows:

Los Angeles, California 90017 Telephone: (213) 689-1300 3 Robert C. Shenfeid, Esq.

4 Facsimile: (213) 688-8150 Kelley Drye & Warren LLP 4 777 South Figueroa Street 5 Attorneys for SATELLITE SENIOR Suite 2700 INCOME FUND and SATELLITE SENIOR 5 Los Angeles, CA 90017-5825 6 INCOME FUND II Telephone: (213) 689-1300 6 Facsimile: (213) 688-8150 7

7 Neither this Notice of Appearance and Request for Special Notice nor any 8

UNITED STATES BANKRUPTCY COURT 8 subsequent appearance, pleading, claim, proof of claim, document, suit, motion nor any other 9

NORTHERN DISTRICT OF CALIFORNIA 9 writing or conduct, shall constitute a waiver by Satellite of any:

10 SAN FRANCISCO DIVISION (a) fight to have any and all final orders in any and all non-core matters II entercd only after de novo review by a United States District Court Judge; 12 In re Case No.: 01-30923 DM 12 (b) right to trial by jury in any proceeding as to any and all matters so triable 13 Chapter I1 13 therein, whether or not the same be designated legal or private rights, or in any case, controversy PACIFIC GAS AND ELECTRIC 14 COMPANY, a California corporation, 14 or r.cceeding related hereto, whether or not such jury trial right is pursuant to statute or the NOTICE OF APPEARANCE AND REQUEST 15 FOR SPECIAL NOTICE Debtor. 15 United States Constitution; 16 [No Hearing Required]

16 (c) right to have the reference of this matter withdrawn by the United States 17 17 District Court in any matter or proceeding subject to mandatory or discretionary withdrawal; or 18 TO THE CLERK OF THE BANKRUPTCY COURT AND TO ALL PARTIES IN IN."TEREST: 18 (d) other rights, claims, actions, defenses, setoffs, recoupments or other 19 PLEASE TAKE NOTICE that Satellite Senior Income Fund and Satellite Senior 19 mattere to which this party is entitled under any agreements or at law or in equity or uader the 20 Income Fund II (collectively, "Satellite") by an-I through their counsel, Kelley Drye & Warren 20 United States Constitution.

21 LLP, hereby files their notice of appearance pursuant to Rule 9010(b) of the Federal Rules of 21 All of the above rights are expressly reserved and preserved unto these parties 22 Bankruptcy Procedure (the "Bankruptcy Rules"), and hereby request, pursuant to Section 22 without cxception and with no purpose of confessing or conceding jurisdiction in any way by this 23 1109(b) of title 11 of the United States Code, I U.S.C. §§ 101, et seq. (as amended, the 23 filing or by any other participation in this matters.

24 "Bankruptcy Code") and Bankruptcy Rules 2002, 3017, 9007 and 9010 that all notices given or 24 PLEASE TAKE FURTHER NOTICE that, pursuant to Section 1109(b) of the 25 required to be given, and all papers served in this case, in any other related matter, or in adversary 25 Bankniptcy Code and Rules 2002 and 3017(a) of the Bankruptcy Rules, the foregoing demand 26 26 includes not only the notices and papeis referred to in the above-mentioned Bankruptcy Code 27 AdmiRtted to appear pro hac vice.

27 section and Rules, but also includes, without limitation, all orders and notices of orders, 18 KELLEYORYE* 28 WARRENLLP LA0/1SHENR/218i05 2 -I- KELI.FY DRYE & L[A I/CI.FNR IiRflg 7 -%

NOTICE OF APPEARANCE AND REQUEST WARREN LNP NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE FOR SPECIAL NOTICE

I applications, motions, memoranda, declarations, disclosure statements, answering or reply papers, 2 petitions, pleadings, requests, complaints or demands, whether formal or informal, written or oral, 3 or whether transmitted or conveyed by mail delivery, telephone, telegraph, telex, telecopy, 4 personal delivery or otherwise, which are served or otherwise affect the debtor or its property, 5 Satellite, this case, or any other adversary proceeding related thereto.

6 Dated: July Y11 2002 KELLEY DRYE & WARREN LLP 7 ERIC R. WILSON ROBERT C. SHENFELD 8

9 10 Attorneys for SATELLITE SENIOR II INCOME FUND and SATELLITE SENIOR INCOME FUND II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LLEY DRYE & .'4.

1RRENLLP NOTICE OF APPEARANCE AND REQUEST FOR SPECIAL NOTICE