USA GYMNASTICS, Debtor
Case 18-09108-RLM-11 Doc 562 Filed 06/05/19 EOD 06/05/19 16:35:52 Pg 1 of 21 IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION In re: Chapter 11 1 USA GYMNASTICS, Case No. 18-09108-RLM-11 Debtor. DEBTOR’S OBJECTION TO COMMITTEE’S 2004 MOTION USA Gymnastics, as debtor and debtor in possession in the above-captioned chapter 11 case (the “Debtor” or “USAG”), objects to The Additional Tort Claimants Committee Of Sexual Abuse Survivors’ Motion For An Order Pursuant To Bankruptcy Rule 2004 Directing Production Of Documents And Materials From USA Gymnastics [Dkt. 519] (the “Rule 2004 Motion”). INTRODUCTION On April 24, and May 8, 2019, the Sexual Abuse Survivors Committee (“Committee”) served the Debtor with two overly-broad document demands seeking a wide-range of documents without any time limits whatsoever. In total, the Committee sought over 102 categories of documents. As the Committee concedes in its Rule 2004 Motion, in slightly over a month, in three separate productions, USAG has produced documents or provided information in response to most of the categories of documents that the Committee sought. (Rule 2004 Motion ¶¶ 16, 22-23.) Of 2 the 102 different demands, only 14 remain unanswered. 1 The last four digits of the Debtor’s federal tax identification number are 7871. The location of the Debtor’s principal office is 130 E. Washington Street, Suite 700, Indianapolis, Indiana 46204. 2 In Exhibit A to its Motion, the Committee lists 16 demands it contends are unsatisfied, but one of those demands is new, as the Committee admits, and as explained below, USAG has in fact responded to one of the demands already.
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