IN the UNITED STATES BANKRUPTCY COURT for the DISTRICT of DELAWARE ) in Re: ) Chapter 11 ) IMPRESA HOLDINGS ACQUISITION CORPOR
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Case 20-12399-BLS Doc 332 Filed 03/29/21 Page 1 of 70 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) IMPRESA HOLDINGS ACQUISITION ) Case No. 20-12399 (BLS) CORPORATION, et al., ) ) Debtors.1 ) (Jointly Administered) ) AFFIDAVIT OF SERVICE I, Giovanna M. Luciano, depose and say that I am employed by Stretto, the claims and noticing agent for the Debtors in the above-captioned cases. On March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on Twin Haven Capital Partners, LLC, Paul Mellinger at 11111 Santa Monica Boulevard, Suite 525, Los Angeles, CA 90025: • Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed by the Debtors, Prepetition Lender and Official Committee of Unsecured Creditors (re Docket No. 325) • Order (I) Approving the Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Combined Disclosure Statement and Plan; (III) Approving the Form of Ballots and Solicitation Packages; (IV) Establishing the Voting Record Date; (V) Scheduling A Combined Hearing for Final Approval of the Adequacy of Disclosures In, and Confirmation of, the Combined Disclosure Statement and Plan; and (VI) Granting Related Relief (Docket No. 327, Sans Exhibits 2 through 5) • Notice of (I) Approval of Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Hearing to Consider (A) Final Approval of the Combined Disclosure Statement and Plan and (B) Confirmation of the Combined Disclosure Statement and Plan; (III) Deadline for Voting on the Combined Disclosure Statement and Plan; and (IV) Deadline for Filing Objections to Confirmation of the Combined Disclosure Statement and Plan (Docket No. 329) • Individualized Class 3 Prepetition Secured Claims Ballot (Exhibit 3A to Docket No. 327) ___________________________________ 1 The Debtors in these cases, along with the last four digits of each Debtor’s federal EIN, are as follows: Impresa Holdings Acquisition Corporation (5982); Impresa Acquisition Corporation (6088); Impresa Aerospace, LLC (1706); and Goose Creek, LLC (5777). The Debtors’ mailing address is 344 W 157th St, Gardena, CA 90248. Case 20-12399-BLS Doc 332 Filed 03/29/21 Page 2 of 70 • Postage Paid Buisness Reply Envelope Furthermore, on March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on the service list attached hereto as Exhibit A: • Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed by the Debtors, Prepetition Lender and Official Committee of Unsecured Creditors (re Docket No. 325) • Order (I) Approving the Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Combined Disclosure Statement and Plan; (III) Approving the Form of Ballots and Solicitation Packages; (IV) Establishing the Voting Record Date; (V) Scheduling A Combined Hearing for Final Approval of the Adequacy of Disclosures In, and Confirmation of, the Combined Disclosure Statement and Plan; and (VI) Granting Related Relief (Docket No. 327, Sans Exhibits 2 through 5) • Notice of (I) Approval of Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Hearing to Consider (A) Final Approval of the Combined Disclosure Statement and Plan and (B) Confirmation of the Combined Disclosure Statement and Plan; (III) Deadline for Voting on the Combined Disclosure Statement and Plan; and (IV) Deadline for Filing Objections to Confirmation of the Combined Disclosure Statement and Plan (Docket No. 329) • Letter re Recommendation of the Official Committee of Unsecured Creditors of Impresa Holdings Acquisition Corporation, et al. to Vote to Accept the Plan of Liquidation (Attached hereto as Exhibit B) • Individualized Class 4 General Unsecured Claims: Trade Creditors Ballot (Exhibit 3B to Docket No. 327) • Postage Paid Buisness Reply Envelope Furthermore, on March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on the service list attached hereto as Exhibit C: • Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed by the Debtors, Prepetition Lender and Official Committee of Unsecured Creditors (re Docket No. 325) Case 20-12399-BLS Doc 332 Filed 03/29/21 Page 3 of 70 • Order (I) Approving the Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Combined Disclosure Statement and Plan; (III) Approving the Form of Ballots and Solicitation Packages; (IV) Establishing the Voting Record Date; (V) Scheduling A Combined Hearing for Final Approval of the Adequacy of Disclosures In, and Confirmation of, the Combined Disclosure Statement and Plan; and (VI) Granting Related Relief (Docket No. 327, Sans Exhibits 2 through 5) • Notice of (I) Approval of Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Hearing to Consider (A) Final Approval of the Combined Disclosure Statement and Plan and (B) Confirmation of the Combined Disclosure Statement and Plan; (III) Deadline for Voting on the Combined Disclosure Statement and Plan; and (IV) Deadline for Filing Objections to Confirmation of the Combined Disclosure Statement and Plan (Docket No. 329) • Letter re Recommendation of the Official Committee of Unsecured Creditors of Impresa Holdings Acquisition Corporation, et al. to Vote to Accept the Plan of Liquidation (Attached hereto as Exhibit B) • Individualized Class 4 General Unsecured Claims: Wage/Hour Creditors Ballot (Exhibit 3C to Docket No. 327) • Postage Paid Buisness Reply Envelope Furthermore, on March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on Sandra Gutierrez, individually, and on behalf of the other members of the general public similarly situated and on behalf of other aggrieved employees pursuant to the California Private Attorneys General Act, Ovsanna Takvoryan, Tharpe & Howell, LLP at 15250 Ventura Boulevard, Ninth Floor, Sherman Oaks, CA 91403: • Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed by the Debtors, Prepetition Lender and Official Committee of Unsecured Creditors (re Docket No. 325) • Order (I) Approving the Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Combined Disclosure Statement and Plan; (III) Approving the Form of Ballots and Solicitation Packages; (IV) Establishing the Voting Record Date; (V) Scheduling A Combined Hearing for Final Approval of the Adequacy of Disclosures In, and Confirmation of, the Combined Disclosure Statement and Plan; and (VI) Granting Related Relief (Docket No. 327, Sans Exhibits 2 through 5) Case 20-12399-BLS Doc 332 Filed 03/29/21 Page 4 of 70 • Notice of (I) Approval of Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Hearing to Consider (A) Final Approval of the Combined Disclosure Statement and Plan and (B) Confirmation of the Combined Disclosure Statement and Plan; (III) Deadline for Voting on the Combined Disclosure Statement and Plan; and (IV) Deadline for Filing Objections to Confirmation of the Combined Disclosure Statement and Plan (Docket No. 329) • Individualized Class 5 Class Action Claim Ballot (Exhibit 3D to Docket No. 327) • Postage Paid Buisness Reply Envelope Furthermore, on March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on the service list attached hereto as Exhibit D: • Combined Disclosure Statement and Chapter 11 Plan of Liquidation Proposed by the Debtors, Prepetition Lender and Official Committee of Unsecured Creditors (re Docket No. 325) • Order (I) Approving the Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Establishing Procedures for Solicitation and Tabulation of Votes to Accept or Reject the Combined Disclosure Statement and Plan; (III) Approving the Form of Ballots and Solicitation Packages; (IV) Establishing the Voting Record Date; (V) Scheduling A Combined Hearing for Final Approval of the Adequacy of Disclosures In, and Confirmation of, the Combined Disclosure Statement and Plan; and (VI) Granting Related Relief (Docket No. 327, Sans Exhibits 2 through 5) • Notice of (I) Approval of Combined Disclosure Statement and Plan on an Interim Basis for Solicitation Purposes Only; (II) Hearing to Consider (A) Final Approval of the Combined Disclosure Statement and Plan and (B) Confirmation of the Combined Disclosure Statement and Plan; (III) Deadline for Voting on the Combined Disclosure Statement and Plan; and (IV) Deadline for Filing Objections to Confirmation of the Combined Disclosure Statement and Plan (Docket No. 329) Furthermore, on March 23, 2021, at my direction and under my supervision, employees of Stretto caused the following documents to be served via first-class mail on the service