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Case 15-30125
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UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
In re:
The Archdiocese of Saint Paul and Minneapolis,
Bankruptcy Case No. 15-30125
Debtor.
Chapter 11 Case
______________________________________________________________________________
ORDER ESTABLISHING DEADLINES FOR FILING PROOFS OF CLAIM;
APPROVING PROOF OF CLAIM FORMS; APPROVING FORM AND MANNER OF
NOTICE; AND APPROVING CONFIDENTIALITY PROCEDURE
______________________________________________________________________________
The case came before the court on the motion of the Archdiocese of Saint Paul and
Minneapolis for an order establishing deadlines for filing proofs of claim, approving proof of
claim forms, approving the form and manner of notice, and approving confidentiality procedures
in connection with the filing of proofs of claim.
Based on the motion and the file,
IT IS ORDERED:
1.
7KH$UFKGLRFHVH¶VPRWLRQfor an order establishing deadlines for filing proofs of
claim, approving proof of claim forms, approving the form and manner of notice, and approving
confidentiality procedures in connection with the filing of proofs of claim is granted as set forth in
this order.
FORMS
2.
The Sexual Abuse Proof of Claim Form, the Non-Tort Filing Deadline Notice, the
Sexual Abuse Claims Filing Deadline Notice and the Publication Notice, in the forms attached as
Exhibits A, B, C, and D are approved. Creditors with claims other than sexual abuse claims may
use the official proof of claim form B10.
127,&(2)(/(&7521,&(175<$1'
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NOTICE
3.
The form and manner of notice as approved in this order fulfill the notice
requirements of the Federal Rules of Bankruptcy Procedure and the local rules of this court.
Notice of the filing deadlines in the form and manner attached is fair and reasonable and will
provide sufficient notice to all creditors of their rights and obligations in connection with claims
they may assert in this case. Accordingly, the Archdiocese is authorized and directed to serve and
publish the notices in the manner described in this order.
DEADLINE FOR TIMELY FILING CLAIMS
4.
The last day to timely file a proof of claim in this case is set as August 3, 2015.
REQUIREMENTS FOR SEXUAL ABUSE PROOF OF CLAIM FORMS
5.
Persons asserting claims arising from sexual abuse as that term is defined in
Minnesota Statutes § 541.073(1), as well as from molestation, rape, undue familiarity, sexuallyrelated physical, psychological or emotional harm, or contacts or interactions of a sexual nature
between a child and an adult, or a non-consenting adult and another adult for which such persons
believe that the Archdiocese may be shall file a Sexual Abuse Proof of Claim Form (Ex. A).
6.
The Clerk of Court shall maintain a copy of each Sexual Abuse Proof of Claim
Form in electronic form in accordance with the confidentiality procedures outlined below. The
Clerk of Court will assign each Sexual Abuse Proof of Claim Form a number and shall list that
number on the public docket without a link to the Sexual Abuse Proof of Claim Form and without
the name of the claimant. All original Sexual Abuse Proof of Claim Forms shall be turned over to
the attorneys for the Archdiocese at regular intervals.
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CONFIDENTIALITY PROCEDURES
7.
Sexual Abuse Proof of Claim Forms shall be submitted pursuant to the following
confidentiality procedures:
(i)
Sexual Abuse Claimants shall mail or deliver the original of a
Sexual Abuse Proof of Claim Form to the Clerk of the United States Bankruptcy
Court for the District of Minnesota, Attention B. Montez at the following address:
200 Warren E. Burger Federal Building and United States Courthouse, 316 N.
Robert Street, Saint Paul, Minnesota 55101.
(ii)
Sexual Abuse Proof of Claim Forms maintained by the Clerk of
Court will not be available for viewing or copying unless otherwise ordered by
the court. This confidentiality procedure is for the benefit of the Sexual Abuse
Claimants. Accordingly, Sexual Abuse Claimants may elect to make any of the
information contained in a Sexual Abuse Proof of Claim Form public, even if they
elected to file the Sexual Abuse Proof of Claim Form confidentially. If a Sexual
Abuse Claimant affirmatively indicates by checking the box in Part 1 of the
Sexual Abuse Proof of Claim Form that the claim is to be made public, that claim
will be added to the public claims register. If no box is checked or if both boxes
are checked on a Sexual Abuse Proof of Claim Form, that form shall not be made
public.
(iii) Sexual Abuse Proof of Claim Forms submitted by Sexual Abuse
Claimants shall be held and treated as confidential by the Archdiocese and its
counsel and upon request to the permitted parties listed below, subject to each
permitted pDUW\ H[HFXWLQJ DQG UHWXUQLQJ WR WKH $UFKGLRFHVH¶V FRXQVHO D
confidentiality agreement, and to such other persons as the court determines;
provided, however, that all parties with access to the Sexual Abuse Proof of
Claim Forms shall agree to keep the information provided in a Sexual Abuse
Proof of Claim Form confidential (unless the Sexual Abuse Claimant elects
otherwise in Part 1 of the Sexual Abuse Proof of Claim Form). Permitted Parties
may obtain copies of Sexual Abuse Proof of Claim Forms in accordance with the
terms of an applicable confidentiality agreement only from counsel for the
Archdiocese, and shall not seek or obtain such documents from the clerk of court.
(iv)
Permitted parties include: (a) counsel for the Archdiocese; (b)
officers and employers of the Archdiocese who are necessary to assist the
Archdiocese and its counsel address issues with respect to Sexual Abuse Claims;
(c) counsel for the committee of unsecured creditors; (d) insurance companies or
their successors, including any authorized claim administrators of such insurance
companies, that issued or allegedly issued polices to the Archdiocese and their
reinsurers and attorneys; (e) any future claims representative appointed by the
court in this case; (f) any mediator, special arbitrator or claims reviewer
appointed by the court, including Judge Arthur Boylan, to review and resolve the
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Sexual Abuse Claims; (g) any trustee appointed to administer payments to Sexual
Abuse Claimants; (h) authorized representatives of a department of corrections
with respect to a Sexual Abuse Claim by a Sexual Abuse Claimant who is
incarcerated but only to the extent such disclosure is authorized under applicable
non-bankruptcy law; (i) members of the committee of unsecured creditors and
their personal counsel (after the Sexual Abuse Proof of Claim Form has been
UHGDFWHG WR UHPRYH WKH 6H[XDO $EXVH &ODLPDQW¶V QDPH DGGUHVV DQG DQ\ RWKHU
information identified in Part 2(A) or 3 of the Sexual Abuse Proof of Claim Form
and the signature block); (j) law enforcement in the city or county where the
Sexual Abuse Claim arose; (k) auditors of the United States Conference of
Catholic Bishops charged with preparing annual audits of Archdiocesan
compliance with the Charter for the Protection of Children and Young People;
and (l) such other persons as the court determines should have the information in
order to evaluate Sexual Abuse Claims only upon a motion by the Archdiocese or
the committee of unsecured creditors.
8.
Permitted parties and their attorneys shall be authorized to review proofs of claim
upon execution of a confidentiality agreement agreed upon by the Archdiocese and the committee
of unsecured creditors or pursuant to further order of the court. The court may approve additional
permitted parties upon motion.
9.
Access to the Sexual Abuse Proof of Claim Forms extends only to the individual
who executes the confidentiality agreement. A separate confidential agreement must be signed by
each individual who seeks access to the records on behalf of a permitted party.
TIMING AND FORM OF NOTICE
10.
As soon as reasonably practicable after the entry of this order, the Clerk of Court
shall give notice by United States mail, first-class postage prepaid, or by electronic means, the
Non-Tort Claim Filing Deadline Notice (Ex. B) to (a) the United States Trustee for the District of
Minnesota; (b) counsel to the committee of unsecured creditors; (c) all persons and entities that
have filed a notice of appearance in this case; (d) all persons and entities included in the creditor
mailing matrix on file in this case; and (e) all persons and entities that have previously filed
proofs of claims in this Chapter 11 case. The Non-Tort Filing Deadline Notice, the Publication
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Notice, and the Sexual Abuse Claim Filing Deadline Notice shall include a reference to this
FRXUW¶VZHEVLWHZZZPQEXVFRXUWVJRYZKHUHDOOFODLPIRUPVVKDOOEHPDGHDYDLODEOH
11.
As soon as reasonably practicable, but in any event no later than five business days
after the entry of this order, the Archdiocese shall serve by United States mail, first-class postage
prepaid, the Sexual Abuse Claim Filing Deadline Notice (Ex. C) and the Sexual Abuse Proof of
Claim Form (Ex. A) on the United States Trustee, and on known Sexual Abuse Claimants who
have:
(i)
Filed pending lawsuits against the Archdiocese alleging that they
were sexually abused by employees or agents of the Archdiocese or by clergy
previously assigned to the Archdiocese or any others for whom the Archdiocese
may be liable;
(ii)
Provided to the Archdiocese under Minn. Stat. § 549.09 a written
notice of claim of sexual abuse by employees or agents of the Archdiocese or by
clergy previously assigned to the Archdiocese or any others for whom the
Archdiocese may be liable;
(iii) Contacted the Archdiocese to claim that they were sexually abused
as a minor by employees or agents of the Archdiocese or by clergy previously
assigned to the Archdiocese or any others for whom the Archdiocese may be
liable;
(iv)
Are otherwise known to the Archdiocese to be a Sexual Abuse
Claimant through reasonably-ascertainable records.
12.
The service of the Sexual Abuse Claim Filing Deadline Notice and Sexual Abuse
Proof of Claim Form on Sexual Abuse Claimants shall be accomplished through such Sexual
$EXVH&ODLPDQWV¶DWWRUQH\VLISUHYLRXVO\LGHQWLILHGDVFRXQVHOIRUVXFK6H[XDO$EXVH&ODLPDQW
in connection with a Sexual Abuse Claim, and directly on all other known potential Sexual Abuse
Claimants that have been identified and located by the Archdiocese through reasonably diligent
efforts.
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The service outlined above shall constitute service on all known creditors of the
Archdiocese. All other creditors of the Archdiocese shall be deemed to be unknown for the
purpose of service of notice of the Claim Filing Deadline.
14.
The Archdiocese shall also provide notice of the Claim Filing Deadline established
in this order by causing a copy of the Publication Notice (Ex. D) to be published as follows:
(i)
Publication four times in each of the following publications, with
the first publication to occur within two weeks of the service of the claim filing
deadline packages, the second publication to occur approximately three weeks
after the first notice, the third publication to occur approximately three weeks
after the second notice, and the fourth publication to occur approximately three
weeks after the third notice:
x
x
National Publication: USA Today ± National Edition
Catholic Publications (and their respective websites):
o National Catholic Reporter (National)
o The National Catholic Register (National)
o Catholic Spirit (Regional)
x
Local Publications (and their respective websites):
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o
Minneapolis Star Tribune
St. Paul Pioneer Press
The Minnesota Daily
Finance and Commerce
Duluth News Tribune
Post-Bulletin (Rochester)
St. Cloud Times
Brainerd Dispatch
Grand Forks Herald
Winona Daily News
Daily Journal (Fergus Falls)
Sentinel (Fairmont)
The Bemidji Pioneer
Crookston Daily News
The Free Press (Mankato)
Faribault Daily News
The Journal (New Ulm)
o La Prensa de Minnesota (Spanish Language)
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o Hmong Times
(ii)
In addition to the Publication Notice, the Archdiocese will send copies of
the Sexual Abuse Claim Filing Deadline Notice to the publications listed above and to the
following:
o
o
o
o
o
o
o
o
15.
The Associated Press of Minnesota
WCCO-AM
Minnesota Public Radio
KARE - TV
KMSP - TV
KSPR - TV
WCCO - TV
Each diocese in Minnesota
The Archdiocese shall provide further notice of the Claim Filing Deadline by
taking the following measures:
(i)
Within 3 business days of the entry of this order, the Archdiocese
will post the component parts of the Sexual Abuse Claim Filing Deadline Package
and the Non-Tort Claim Filing Deadline Package on the following public website:
http://www.archspm.org/;
(ii)
Within 3 business days of the entry of this order, the Archdiocese
will provide a copy of the Publication Notice and component parts of the Sexual
Abuse Claim Filing Deadline Package to the Survivors Network of the Abused by
Priests and request that it post the same on its website at www.snapnetwork.org;
(iii) Within 3 business days of the entry of this order, the Archdiocese
will provide a copy of the Publication Notice and component parts of the Sexual
Abuse Claim Filing Deadline Package to Jeff Anderson and Associates P.A. and
the Noaker Law Firm LLC and request that they post the same on their respective
websites at www.andersonadvocates.com and http://noakerlaw.com/;
(iv)
The Archdiocese will maintain a toll free number which may be
used by Sexual Abuse Claimants to ask questions or obtain copies of the Sexual
Abuse Claim Filing Deadline Package or parts thereof;
(v)
Within two weeks of the service of the Sexual Abuse Claim Filing
Deadline Package, the Archdiocese will provide a copy of the Publication Notice
and the Sexual Abuse Claim Filing Deadline Notice to the following
offices/entities and request that each recipient publicly post such notice until the
expiration of the Claim Filing Deadline: (a) the Minnesota Attorney General; (b)
WKHGLVWULFW DWWRUQH\WKHFRXQW\FRXUWDGPLQLVWUDWRUDQGVKHULII¶VGHSDUWPHQW IRU
each of the 12 counties comprising the Region as defined in the Affidavit of the
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&KDUOHV9/DFKRZLW]HUFWKH0LQQHVRWD'HSDUWPHQWRI+HDOWK¶VWKUHHORFDWLRQV
in the Region; (d) each hospital in the Region; and (e) each of the 187 parishes
within the Region.
(vi)
The Archdiocese will send a letter to each parish and Catholic high
school in the Region requesting that such parish or Catholic high school display
the Publication Notice and Sexual Abuse Claim Filing Deadline Notice in a
prominent location within the church or school. The letter will also request that
WKHQRWLFHVEHSXEOLVKHGRQFHDPRQWKLQWKHSDULVKHV¶ZHHNO\EXOOHWLQVXQWLOWKH
Claim Filing Deadline. The letter will also request that each pastor, canonical
administrator, or parochial vicar remind parishioners of the availability of
information concerning the Claim Filing Deadline. The letter will also request
that parishes disseminate the Publication Notice and Sexual Abuse Claim Filing
Deadline Notice by email to their respective distribution lists. Finally, the letter
will request each Catholic high school at which a clergy member against whom a
substantiated claim of sexual abuse has been made had worked to draft a letter to
alumni providing notice of the case and Claim Filing Deadline.
(vii) The Archdiocese will mail a copy of the Sexual Abuse Claim
Filing Deadline Notice to all licensed alcohol and addiction treatment centers in
the state of Minnesota, as identified by counsel for the committee of unsecured
creditors, and to: (1) persons identified by counsel for the official committee of
unsecured creditors as licensed therapists presently working with sexual abuse
claimants; and (2) persons identified in claimant questionnaires completed as of
April 15, 2015 that identify providers of counseling or other treatment services to
sexual abuse claimants.
(viii) The Archdiocese will post copies of the Sexual Abuse Claim Filing
Deadline Notice and Sexual Abuse Proof of Claim Form in Spanish and Hmong
translations on its website at http://information.archspm.org/ and will send copies
of the same documents to the Bankruptcy Clerk of Court to be posted on the
website of the Bankruptcy Court for the District of Minnesota at
http://www.mnb.uscourts.gov.
16.
Each request described in paragraph 15 (v) and (vi) above shall be on the
$UFKGLRFHVH¶VOHWWHUKHDGDQGVLJQHGE\DQRIILFHURIWKH$UFKGLRFHVH7KHUHTXHVWVKDOOLQFOXGHD
space at the bottom for the recipient to indicate whether it will comply with the request and a
stamped self-addressed return envelope.
The Archdiocese will report on compliance to the
committee of unsecured creditors.
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In addition, the Clerk of Court shall post the Non-Tort Proof of Claim Form, the
Sexual Abuse Proof of Claim Form, the Non-Tort Filing Deadline Notice, the Sexual Abuse
Claims Filing Deadline Notice and the Publication Notice on the website for the United States
%DQNUXSWF\ &RXUW IRU WKH 'LVWULFW RI 0LQQHVRWD E\ DGGLQJ D OLQN RQ WKH FRXUW¶V KRPH SDJH
(www.mnb.uscourts.gov) to easily access filing deadline information.
Dated:
April 17, 2015
/e/ Robert J. Kressel
___________________________________
Robert J. Kressel
United States Bankruptcy Judge
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Exhibit A ± Sexual Abuse Proof of Claim Form
Desc Imaged
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UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
In re:
The Archdiocese of Saint Paul and Minneapolis,
Bankruptcy Case No. 15-30125
Debtor.
Chapter 11 Case
____________________________________________________________________________
SEXUAL ABUSE PROOF OF CLAIM
IMPORTANT:
THIS FORM MUST BE RECEIVED NO LATER THAN
AUGUST 3, 2015
Carefully read the instructions included with this SEXUAL ABUSE PROOF OF CLAIM
and complete ALL applicable questions. Please print clearly and use blue or black ink. Send the
original to the U.S. Bankruptcy Court Clerk at the following address: Office of the Clerk of
Court, Attention B. Montez, U.S. Bankruptcy Court District of Minnesota, 200 Warren E. Burger
Federal Building and United States Courthouse, 316 North Robert Street, Saint Paul, MN 55101.
THIS PROOF OF CLAIM IS FOR CLAIMANTS OF SEXUAL ABUSE ONLY.
YOU MAY WISH TO CONSULT AN ATTORNEY REGARDING THIS MATTER.
A sexual abuse claim includes any claim arising from sexual abuse as that term is defined
in Minnesota Statutes § 541.073(1), as well as from molestation, rape, undue familiarity,
sexually-related physical, psychological or emotional harm, or contacts or interactions of a
sexual nature between a child and an adult, or a non-consenting adult and another adult for which
such persons believe that the Archdiocese may be liable.
TO BE VALID, THIS PROOF OF CLAIM MUST BE SIGNED BY YOU OR
YOUR ATTORNEY. IF THE SEXUAL ABUSE CLAIMANT IS DECEASED OR
INCAPACITATED, THE FORM MAY BE SIGNED BY THE SEXUAL ABUSE
&/$,0$17¶65(35(6(17$7,9(257+($77251(<)257+((67$7(,)7+(
SEXUAL ABUSE CLAIMANT IS A MINOR, THE FORM MAY BE SIGNED BY THE
6(;8$/$%86(&/$,0$17¶63$5(1725/(*$/*8$5',$1257+(6(;8$/
$%86( &/$,0$17¶6 $77251(< ,) 7+( 6(;8$/ $%86( &/$,0$17 ',(6
AFTER THE SUBMISSION OF THIS FORM, BUT BEFORE THE CLAIM IS
RESOLVED, NOTIFICATION OF THE DEATH MUST BE PROVIDED TO THE
COURT AT THE ADDRESS ABOVE.
Penalty for presenting fraudulent claim: Fine of up to $500,000 or imprisonment for up
to five years, or both. 18 U.S.C. §§ 152 and 3571.
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UNLESS YOU INDICATE OTHERWISE IN PART 1 BELOW, YOUR IDENTITY
WILL BE KEPT STRICTLY CONFIDENTIAL, UNDER SEAL, AND OUTSIDE THE
PUBLIC RECORD. HOWEVER, INFORMATION IN THIS CLAIM WILL BE
PROVIDED PURSUANT TO COURT-APPROVED CONFIDENTIAL GUIDELINES TO
COUNSEL FOR THE COMMITTEE OF UNSECURED CREDITORS, AND OTHER
COURT-APPROVED THIRD PARTIES IN ORDER TO EVALUATE THE CLAIM.
YOUR PROOF OF CLAIM MAY BE DISPUTED OR HONORED IN WHOLE OR
IN PART. THE DEBTOR RESERVES THE RIGHT TO OBJECT OR TO ASSERT
OFFSETS OR DEFENSES AGAINST ANY FILED PROOF OF CLAIM FORM
PART 1: CONFIDENTIALITY
THIS SEXUAL ABUSE PROOF OF CLAIM (ALONG WITH ANY
ACCOMPANYING EXHIBITS AND ATTACHMENTS) WILL BE MAINTAINED AS
CONFIDENTIAL UNLESS YOU EXPRESSLY REQUEST THAT IT BE PUBLICLY
AVAILABLE BY CHECKING THE BOX AND SIGNING BELOW.
…
…
I want my Proof of Claim (along with any accompanying exhibits and attachments) to be
kept confidential.
I want my Proof of Claim (along with any accompanying exhibits and attachments) to be
made public.
Please verify this election by signing directly below.
Signature:
Print Name:
PART 2: IDENTIFYING INFORMATION
A.
Sexual Abuse Claimant
First Name
Middle Initial
Last Name
Jr/Sr/III
Mailing Address (If Party is incapacitated, is a minor or is deceased, please provide the address
of the individual submitting the claim. If you are in jail or prison, your current address.)
City
Telephone No(s):
Home:
State/Prov.
Zip Code (Postal Code)
Work:
Cell:
2
Country
(if other than USA)
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Email address:
If you are in jail or prison, your identification number:
May we leave voicemails for you regarding your claim:
May we send confidential information to your email:
Birth Date:
Month
Day
… Yes … No
… Yes … No
… Male … Female
Year
Last Four Digits of Social Security Number: XXX-XX-_____
Any other name(s) or alias(es) by which the Sexual Abuse Claimant has been known:
B.
6H[XDO$EXVH&ODLPDQW¶V$WWRUQH\LIDQ\'RQRWOLVWFRXQVHOfor the Debtors or the
Official Creditors Committee):
Law Firm Name
$WWRUQH\¶V)LUVW1DPH
Middle Initial
Last Name
Street Address
City
State/Prov.
Telephone No.
Zip Code (Postal Code)
Fax No.
Country
(if other than USA)
E-mail address
PART 3: BACKGROUND INFORMATION
1.
Are you currently married?
2.
Have you previously been married?
… Yes … 1R,I³<HV´SOHDVHLGHQWLI\WKHQDPHRI\RXUVSRXVHDQGPDUULDJHGDWH
… Yes … 1R,I³<HV´SOHDVHLGHQWLI\\RXUIRUPHUVSRXVHDQGDVDSSOLFDEOHWKHGDWHV
of any dissolution, divorce, separation or widowhood.)
3
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3.
Do you have children?
4.
What schools have you attended? For each school, please identify the months and years
of your attendance. If you cannot recall the exact months when you began or ended each
school year, please identify the season (fall, winter, spring, summer).
5.
Have you received a diploma or degree from any of the schools listed above?
6.
Have you served in the armed forces?
7.
Are you currently employed?
8.
… Yes … 1R,I³<HV´SOHDVHLGHQWLI\WKHLUQDPHVDQGELUWKGDWHV,IDQ\FKLOGUHQKDYH
died, please provide their date of death.)
… Yes … 1R,I³<HV´SOHDVHLGHQWLI\HDFKGLSORPDRUGHJUHHWKDW\RXUHFHLYHGDQGWKH
year you received it.)
… Yes … 1R,I³<HV´SOHDVHLGHQWLfy the branch of service, the dates you served and, if
you have been discharged, the type of discharge you received.)
… Yes … 1R ,I ³<HV´ SOHDVH LGHQWLI\ WKH QDPH RI WKH RUJDQL]DWLRQ ZKHUH \RX Dre
employed, the date that your employment began and your job title.)
What is your employment history? Please provide the following information about each
place you have previously been employed: (i) the name of the organization where you
4
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were employed; (ii) the dates of employment; (iii) your job title(s); and (iv) your reason
for leaving the place of employment.
9.
Have you been self-employed?
10.
Are you retired?
11.
Part 4 below will ask you about the nature of your complaint against the Archdiocese of
Saint Paul and Minneapolis. Other than the incident(s) of sexual abuse described in Part
4, have you ever been sexually abused by anyone HOVH",I³<HV´SOHDVHGHVFULEHWKLV
abuse, including the date of the abuse and the identity of the abuser.
… Yes … 1R,I³<HV´SOHDVHSURYLGH\RXUMREUHVSRQVLELOLWLHVDQGDQ\EXVLQHVVQDPH
you used. Please also provide the dates of this business.)
… Yes … 1R,I³<HV´ZKHQGLG\RXUHWLUH"
PART 4: NATURE OF ABUSE
(Attach additional separate sheets if necessary)
NOTE: IF YOU HAVE PREVIOUSLY FILED A LAWSUIT AGAINST THE
DEBTOR IN STATE OR FEDERAL COURT, YOU MAY ATTACH THE COMPLAINT.
IF YOU DID NOT FILE A LAWSUIT, OR IF THE COMPLAINT DOES NOT CONTAIN
5
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ALL OF THE INFORMATION REQUESTED BELOW, YOU MUST PROVIDE THE
INFORMATION BELOW.
1.
Who committed each act of sexual abuse?
2.
What is the position, title or relationship to you of the abuser or individual who
committed these acts?
3.
Where did the sexual abuse take place? Please be specific and complete all relevant
information that you know, including the City and State, name of the parish, school (if
applicable) and/or the names of any other location.
4.
When did the sexual abuse take place?
a.
Please be as specific as possible. If you can, please indicate the day, month and
year. If you cannot recall the month, please try to recall the season of year (fall,
winter, spring summer).
b.
If you were sexually abused on more than one occasion, please state when the
abuse started, when it stopped, and how many times it occurred.
c.
Please also state your age(s) and your grade(s) in school (if applicable) at the time
the abuse took place.
6
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5.
Please describe in as much detail as possible the nature of the sexual abuse. What
happened?
6.
Did you tell anyone about the sexual abuse (this would include parents, relatives, friends,
the Archdiocese of Saint Paul and Minneapolis, attorneys, counselors, and law
enforcement authorities)? ________________________________________________
a.
,I³<HV´ZKRGLG \RXWHOO"3OHDVHOLVWWKHQDPHVDQGDQ\FRQWDFWLQIRUPDWLRQ
you have.
b.
What did you say?
c.
When did you tell this person or persons about the abuse?
d.
If you know, what did the person or persons do in response?
7
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7.
Were there any witnesses? If so, please list their name(s) and any contact information
you have, including addresses.
8.
Do you personally know or have reason to believe that the Archdiocese of Saint Paul and
Minneapolis knew that your abuser was abusing you or others before or during the period
ZKHQVXFKDEXVHRFFXUUHG",I³<HV´SOHDVHSURYLGHDOOLQIRUPDWLRQWKDWVXSSRUWs your
conclusion, including the information requested in items 8(a) through 8(e) below.
a.
Who at the Archdiocese knew that your abuser was abusing you or others?
b.
How did such person or persons at the Archdiocese learn this information? For
example, did you report the abuse to someone from the Archdiocese? Did
someone else tell you they reported it to someone from the Archdiocese? Did
someone from the Archdiocese witness the abuse?
c.
When did such person or persons at the Archdiocese learn this information?
d.
What exactly was the person or persons from the Archdiocese told or what
exactly did they observe?
8
Case 15-30125
e.
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Certificate of Notice Page 19 of 34
Desc Imaged
How did you come to have the information you provided in response to the
questions above?
PART 5: IMPACT OF ABUSE
(Attach additional separate sheets if necessary)
1.
What injuries have occurred to you because of the act or acts of sexual abuse that resulted
in the claim (for example, the effect on your education, employment, personal
relationships, health, and any physical injuries)?
2.
Have you sought counseling or other treatment for your injuries? If so, with whom and
when?
PART 6: ADDITIONAL INFORMATION
1.
Prior Non-Bankruptcy Claims: Have you previously filed any lawsuit seeking damages
for the sexual abuse described in this claim? … Yes … 1R,I³<HV´SOHDVHDQVZHUWKH
questions below.)
a.
Where and when did you file the lawsuit?
b.
Who were the parties to the lawsuit and what was the case number?
9
Case 15-30125
c.
2.
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Certificate of Notice Page 20 of 34
Desc Imaged
What was the result of that lawsuit?
Prior Bankruptcy Claims: Have you filed any claims in any other bankruptcy case
relating to the sexual abuse described in this claim?
… Yes … 1R,I³<HV´\RXDUHUHTXLUHGWRDWWDFKDFRS\RIDQ\FRPSOHWHGFODLPIRUP
3.
Any Settlements: Regardless of whether a complaint was ever filed against any party
because of the sexual abuse, have you settled any claim or demand relating to the sexual
abuse described in this claim?
… Yes … 1R ,I ³<HV´ SOHDVH GHVFULEH LQFOXGLQJ SDUWLHV WR WKH VHWWOHPHQW <RX DUH
required to attach a copy of any settlement agreement.)
4.
Bankruptcy: Have you ever filed bankruptcy? … Yes … 1R,I³<HV´SOHDVHSURYLGH
the following information:
Name of Case:
Court:
Date Filed:
Case No.:
Chapter: … 7 … 11 … 12 … 13
Name of Trustee:
Date:
Sign and print your name. If you are signing the claim on behalf of another person or an
estate, print your title.
Under penalty of perjury, I declare the foregoing statements to be true and correct.
Signature:
Print Name:
Title:
6997309v4
10
Case 15-30125
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Certificate of Notice Page 21 of 34
Exhibit B ± Non-Tort Claim Filing Deadline Notice
Desc Imaged
Case 15-30125
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Certificate of Notice Page 22 of 34
Desc Imaged
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
In re:
The Archdiocese of Saint Paul and Minneapolis,
Bankruptcy Case No. 15-30125
Debtor.
Chapter 11 Case
____________________________________________________________________________
NOTICE OF THE TIME FOR TIMELY FILING PROOFS OF CLAIM
TO ALL PERSONS AND ENTITIES WITH CLAIMS AGAINST THE ARCHDIOCESE OF
SAINT PAUL AND MINNEAPOLIS:
PLEASE TAKE NOTICE that on January 16, 2015 The Archdiocese of Saint Paul and
Minneapolis filed a voluntary petition for relief under Chapter 11 of Title 11 of the United States
Code in the United States Bankruptcy Court for the District of Minnesota. The dHEWRU¶VDGGUHVV
the case number, proof of claim forms and other relevant information related to this Chapter 11
case may be obtained at: http://information.archspm.org/.
PLEASE TAKE FURTHER NOTICE that except as described below, all persons,
entities, or governmental units that have or assert any pre-petition claims against the debtor must
file a proof of claim with the Clerk of Bankruptcy Court at the following address: Clerk of Court,
U.S. Bankruptcy Court, District of Minnesota, 200 Warren E. Burger Federal Building and
United States Courthouse, 316 North Robert Street, St. Paul, MN 55101, so that the proof of
claim is received by the Clerk of Court on or before August 3, 2015.
PLEASE TAKE FURTHER NOTICE that the Non-Tort Proof of Claim Form may be
obtained at: http://information.archspm.org/ or http://www.mnb.uscourts.gov.
YOU SHOULD CONSULT AN ATTORNEY IF YOU HAVE ANY QUESTIONS,
INCLUDING WHETHER YOU MUST FILE A PROOF OF CLAIM
Dated:
Case 15-30125
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Exhibit C ± Sexual Abuse Claim Filing Deadline Notice
Desc Imaged
Case 15-30125
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Certificate of Notice Page 24 of 34
Desc Imaged
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
In re:
The Archdiocese of Saint Paul and Minneapolis,
Bankruptcy Case No. 15-30125
Debtor.
Chapter 11 Case
____________________________________________________________________________
NOTICE OF TIME FOR TIMELY FILING CLAIMS
RELATING TO, OR ARISING FROM, SEXUAL ABUSE
THIS IS AN IMPORTANT NOTICE.
YOUR RIGHTS MIGHT BE AFFECTED.
TO ALL PERSONS WITH CLAIMS ARISING FROM SEXUAL ABUSE FOR WHICH
THE ARCHDIOCESE OF SAINT PAUL AND MINNEAPOLIS MAY BE LIABLE:
AUGUST 3, 2015 IS THE LAST DATE TO TIMELY FILE PROOFS OF CLAIMS FOR
SEXUAL ABUSE
On January 16, 2015 The Archdiocese of Saint Paul and Minneapolis filed a voluntary
petition for relief under Chapter 11 of Title 11 of the United States Code in the United States
Bankruptcy Court for the District of Minnesota. The dHEWRU¶VDGGUHVVWKHFDVHQXPEHUSURRIRI
claim forms and other relevant information related to this Chapter 11 case may be obtained at
http://information.archspm.org/. Individuals have asserted sexual abuse claims against the
Archdiocese, on account of alleged actions by people associated with the Archdiocese. Any
person who believes that he or she has, or may have, a claim arising from sexual abuse as that
term is defined in Minnesota Statutes §541.073(1), molestation, rape, undue familiarity,
sexually-related physical, psychological or emotional harm, or contacts or interactions of a
sexual nature between a child and an adult, or a non-consenting adult and another adult for which
such persons believe that the Archdiocese may be liable should carefully read this notice.
YOU SHOULD CONSULT AN ATTORNEY IF YOU HAVE ANY QUESTIONS,
INCLUDING WHETHER YOU SHOULD FILE A PROOF OF CLAIM.
LAST DATE FOR TIMELY FILING
The United States Bankruptcy Court for the District of Minnesota entered an order
establishing August 3, 2015, as the last date for each Sexual Abuse Claimant to timely file a
proof of claim. The Claim Filing Deadline and the procedures set forth below for Sexual Abuse
Proof of Claim Forms apply to all Sexual Abuse Claims against the dDebtor, based upon alleged
acts of sexual abuse occurring prior to January 16, 2015.
Case 15-30125
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Certificate of Notice Page 25 of 34
Desc Imaged
WHO SHOULD FILE
If you believe that you have a Sexual Abuse Claim, you should file a Sexual Abuse Proof
of Claim to maintain and preserve any claims that you have against the debtor. Even if you have
already filed a lawsuit against the debtor alleging sexual abuse prior to January 16, 2015, you
should still file a Sexual Abuse Proof of Claim Form to maintain and preserve your rights in the
dHEWRU¶V&KDSWHUFDVH
WHO SHOULD NOT FILE
You should not file a Sexual Abuse Proof of Claim Form if:
Your Sexual Abuse Claim has already been paid in full;
You do not have a claim against the debtor.
WHAT TO FILE
FILE A SEXUAL ABUSE PROOF OF CLAIM FORM, A COPY OF WHICH IS
ENCLOSED. YOU MAY ALSO OBTAIN A COPY OF THE SEXUAL ABUSE PROOF
OF CLAIM FORM BY FOLLOWING THE INSTRUCTIONS BELOW:
PROCEDURES FOR FILING A SEXUAL ABUSE PROOF OF CLAIM FORM
To file a Sexual Abuse Proof of Claim Form, take the following steps:
Fill out the Sexual Abuse Proof of Claim Form in its entirety.
For additional copies of the Sexual Abuse Proof of Claim Form: (a) photocopy the Sexual
Abuse Proof of Claim Form; (b) contact the debtor between the hours of 9:00 a.m. and 5:00 p.m.
(prevailing Central Time), Monday through Friday; (c) visit the debtoU¶V ZHEVLWH DW
http://information.archspm.org/; or (d) visit the website of United States Bankruptcy Court for
the District of Minnesota at http://www.mnb.uscourts.gov/
3OHDVHQRWHWKDW WKH&RXUW¶V &OHUNVWDIILV QRWSHUPLWWHGWRJLYHOHJDO DGYLFH<RX
should consult your own attorney for assistance regarding any such inquiries.
Return the completed original Sexual Abuse Proof of Claim Form to the U.S. Bankruptcy
Court Clerk at the address set forth below by the Claim Filing Deadline. Sexual Abuse Proof of
Claim Forms will be deemed timely filed only if they are actually received by the Clerk of
Court by August 3, 2015.
If you are returning a Sexual Abuse Proof of Claim Form by mail, allow sufficient
mailing time so that the Sexual Abuse Proof of Claim Form is received on or before August 3,
2015. Sexual Abuse Proof of Claim Forms that are postmarked before that date, i.e., the Claim
Filing Deadline, but which are received by the Clerk of the Court after the Claim Filing
Deadline, will be considered tardy.
2
Case 15-30125
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Certificate of Notice Page 26 of 34
Desc Imaged
Sexual Abuse Proof of Claim Forms should be delivered to the following address:
Clerk of Court
Attention: B. Montez
U.S. Bankruptcy Court District of Minnesota
200 Warren E. Burger Federal Building and United States Courthouse
316 North Robert Street
St. Paul, MN 55101
CONSEQUENCES OF FAILURE TO FILE A PROOF OF CLAIM
There may be consequences for failing to file a claim. Please consult your attorney.
CONFIDENTIALITY
Filed Sexual Abuse Proof of Claim Forms will remain confidential in this bankruptcy
case, unless you elect otherwise in Part 1 of the Sexual Abuse Proof of Claim Form. Therefore,
the Sexual Abuse Proof of Claim Form that you file will not be available to the general public,
but will be kept confidential, except that information will be provided to the debtor, the United
States Trustee for the District of Minnesota, the dHEWRU¶V LQVXUHUV DWWRUQH\V IRU WKH RIILFLDO
committee of unsecured creditors and its members, any future claims representative appointed
under a plan of reorganization, any settlement trustee appointed to administer payments to
Sexual Abuse Claimants, prison authorities for incarcerated Sexual Abuse Claimants and such
other persons as the court determines should have the information in order to evaluate the Sexual
Abuse Claim, all of whom will agree to keep the information provided by you confidential.
Dated:
3
Case 15-30125
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Certificate of Notice Page 27 of 34
Exhibit D ± Publication Notice
Desc Imaged
Case 15-30125
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Certificate of Notice Page 28 of 34
Desc Imaged
UNITED STATES BANKRUPTCY COURT
DISTRICT OF MINNESOTA
In re: The Archdiocese of Saint Paul and Minneapolis
Case No. 15-30125
YOU MAY HAVE A CLAIM AGAINST
THE ARCHDIOCESE OF SAINT PAUL AND MINNEAPOLIS
On January 16, 2015, The Archdiocese of Saint Paul and Minneapolis filed for
protection under Chapter 11 of Title 11 of the United States Code.
The last day to file a SEXUAL ABUSE CLAIM, GENERAL CLAIM, or
GOVERNMENT CLAIM against the Debtor is August 3, 2015.
x
x
If you were sexually abused by any person connected with the debtor, then
you must file a claim by August 3, 2015. Sexual abuse, as used in this
notice, includes molestation, rape, undue familiarity, sexually-related
physical, psychological or emotional harm, or contacts or interactions of a
sexual nature between a child and an adult, or a non-consenting adult and
another adult.
If you are a person, entity, or Governmental Unit (as defined by Bankruptcy
Code § 101(27)), and claim any right to payment or to an equitable remedy
for breach of performance if such breach gives rise to a right to payment,
then you must file a claim by August 3, 2015.
YOU MUST ACT NOW TO PRESERVE YOUR RIGHTS
For more information on how to obtain and file a proof of claim and associated
documents
please:
(a)
visit
the
dHEWRU¶V
ZHEVLWH
DW
http://information.archspm.org/; (b) visit the website of the U.S. Bankruptcy
Court for the District of Minnesota at http://www/mnb.uscourts.gov; (c) call the
'HEWRU¶VWROO-free hotline at ______________; or (d) call the Official Committee
of Unsecured Creditors appointed in this case at ____________________.
Case 15-30125
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Certificate of Notice Page 29 of 34
Desc Imaged
United States Bankruptcy Court
District of Minnesota
In re:
The Archdiocese of Saint Paul and Minnea
Debtor
Case No. 15-30125-RJK
Chapter 11
CERTIFICATE OF NOTICE
District/off: 0864-3
User: lynn
Form ID: pdf111
Page 1 of 6
Total Noticed: 1
Date Rcvd: Apr 17, 2015
Notice by first class mail was sent to the following persons/entities by the Bankruptcy Noticing Center on
Apr 19, 2015.
aty
JOHN PHILIP BORGER,
FAEGRE & BENSON,
90 S 7TH ST,
MINNEAPOLIS, MN 55402-3901
Notice by electronic transmission was sent to the following persons/entities by the Bankruptcy Noticing Center.
NONE.
TOTAL: 0
***** BYPASSED RECIPIENTS *****
NONE.
TOTAL: 0
I, Joseph Speetjens, declare under the penalty of perjury that I have sent the attached document to the above listed entities in the manner
shown, and prepared the Certificate of Notice and that it is true and correct to the best of my information and belief.
Meeting of Creditor Notices only (Official Form 9): Pursuant to Fed. R. Bank. P. 2002(a)(1), a notice containing the complete Social Security
Number (SSN) of the debtor(s) was furnished to all parties listed. This official court copy contains the redacted SSN as required by the
bankruptcy rules and the Judiciary’s privacy policies.
Date: Apr 19, 2015
Signature: /s/Joseph Speetjens
_
CM/ECF NOTICE OF ELECTRONIC FILING
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system on April 17, 2015 at the address(es) listed below:
Aaron G. Thomas
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
athomas@briggs.com, bmcnabb@briggs.com
Andrew M Simon
on behalf of Interested Party
AMERICAN HOME ASSURANCE COMPANY
andrew.simon@squirepb.com, catherine.boggs@squirepb.com
Andrew T Brever
on behalf of Interested Party
St. Charles Borromeo Catholic Church of
Minneapolis, MN abrever@fosterbrever.com, atbrever@yahoo.com
Anthony Gabor
on behalf of Interested Party Michael P. Schaefer agabor@obermanthompson.com
Benjamin Gurstelle
on behalf of Plaintiff
Archdiocese of Saint Paul and Minneapolis
bgurstelle@briggs.com, soneill@briggs.com
Benjamin Gurstelle
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
bgurstelle@briggs.com, soneill@briggs.com
Bradley J. Martinson
on behalf of Interested Party
North American Banking Company
bmartinson@nabankco.com
Brian F Leonard
on behalf of Interested Party
CHURCH OF ST. PAUL, HAM LAKE bleonard@losgs.com,
swood@losgs.com
Brian F Leonard
on behalf of Interested Party
THE CHURCH OF THE EPIPHANY bleonard@losgs.com,
swood@losgs.com
Cameron A. Lallier
on behalf of Interested Party
The Church of Saint Anne St. Joseph Hien
clallier@foleymansfield.com, rlorey@foleymansfield.com
Catalina J. Sugayan
on behalf of Interested Party
Markel International Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
RiverStone Insurance (UK) Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
CNA Reinsurance of London, Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
Tenecom, Ltd.
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Sphere Drake Insurance PLC
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
RiverStone Insurance (UK) Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Cross Defendant
Certain Underwriters at Lloyd’s London
subscribing to Policies S3721, SL3722, SL3723, ISL3115, ISL3116, ISL3117, ISL3675 ISL3613,
ISL3614, and ISL3615 catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Certain Underwriters at Lloyd’s London subscribing
to Policies S3721, SL3722, SL3723, ISL3115, ISL3116, ISL3117, ISL3675 ISL3613, ISL3614, and
ISL3615 catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Case 15-30125
District/off: 0864-3
Doc 190 Filed 04/19/15 Entered 04/19/15 23:56:14
Certificate of Notice Page 30 of 34
User: lynn
Form ID: pdf111
Page 2 of 6
Total Noticed: 1
Desc Imaged
Date Rcvd: Apr 17, 2015
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system (continued)
Catalina J. Sugayan
on behalf of Cross Defendant
Stronghold Insurance Company Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Cross Defendant
Sphere Drake Insurance PLC
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Markel International Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Dominion Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Cross Defendant
Excess Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
CX Reinsurance Company Ltd.
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
Stronghold Insurance Company Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Stronghold Insurance Company Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Excess Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
Excess Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Cross Defendant
Dominion Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
Tenecom, Ltd. catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
Dominion Insurance Company
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Interested Party
Certain Underwriters at Lloyd’s, London
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Defendant
CX Reinsurance Company Ltd.
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Catalina J. Sugayan
on behalf of Cross Defendant
CNA Reinsurance of London, Limited
catalina.sugayan@sedgwicklaw.com,
michelle.leszkiewicz@sedgwicklaw.com;peter.horst@sedgwicklaw.com
Charles E Jones
on behalf of Cross Defendant
Interstate Fire and Casualty Company
cjones@meagher.com, aditty@meagher.com
Charles E Jones
on behalf of Interested Party
Interstate Fire and Casualty Company
cjones@meagher.com, aditty@meagher.com
Charles E Jones
on behalf of Defendant
Interstate Fire and Casualty Company
cjones@meagher.com, aditty@meagher.com
Charles B Rogers
on behalf of Counter-Defendant
Archdiocese of Saint Paul and Minneapolis
crogers@briggs.com, kdalhed@briggs.com
Charles B Rogers
on behalf of Plaintiff
Archdiocese of Saint Paul and Minneapolis
crogers@briggs.com, kdalhed@briggs.com
Charles E. Nelson
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
cnelson@lindquist.com, ddaun@lindquist.com
Chris J. Fichtl
on behalf of Interested Party
Fireman’s Fund Insurance Company
chris.fichtl@rivkin.com, martha.raskin@rivkin.com
Connie A. Lahn
on behalf of Interested Party
Catholic Mutual Relief Society of America
clahn@btlaw.com, tpaulson@btlaw.com;marobinson@btlaw.com;pgroff@btlaw.com
Dale O. Thornsjo
on behalf of Cross Defendant
The Aetna Casualty and Surety Company
dothornsjo@olwklaw.com, bjhartmann@olwklaw.com
Dale O. Thornsjo
on behalf of Counter-Claimant
The Aetna Casualty and Surety Company
dothornsjo@olwklaw.com, bjhartmann@olwklaw.com
Dale O. Thornsjo
on behalf of Defendant
The Aetna Casualty and Surety Company
dothornsjo@olwklaw.com, bjhartmann@olwklaw.com
David C. Christian, II
on behalf of Interested Party
Fireman’s Fund Insurance Company
dchristian@davidchristianattorneys.com
David C. Christian, II
on behalf of Interested Party
The Continental Insurance Company
dchristian@davidchristianattorneys.com
David C. Christian, II
on behalf of Interested Party
Continental Casualty Company
dchristian@davidchristianattorneys.com
David M Spector
on behalf of Interested Party
Catholic Mutual Relief Society of America
dspector@schiffhardin.com,
jacquaviva@schiffhardin.com;ecygal@schiffhardin.com;cmethven@schiffhardin.com
Case 15-30125
District/off: 0864-3
Doc 190 Filed 04/19/15 Entered 04/19/15 23:56:14
Certificate of Notice Page 31 of 34
User: lynn
Form ID: pdf111
Page 3 of 6
Total Noticed: 1
Desc Imaged
Date Rcvd: Apr 17, 2015
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system (continued)
Edwin H. Caldie
on behalf of Creditor Committee
Official Committee of Unsecured Creditors
Edwin.Caldie@stinsonleonard.com, laura.schumm@stinsonleonard.com
Elin M Lindstrom
on behalf of Interested Party
Certain Personal Injury Creditors
elin@andersonadvocates.com, therese@andersonadvocates.com;erin@andersonadvocates.com
Frederick P Marczyk
on behalf of Interested Party
Travelers Casualty and Surety Company
(f/k/a The Aetna Casualty and Surety Company) frederick.marczyk@dbr.com
Gerald H Bren
on behalf of Interested Party
Tenecom, Ltd. gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
Markel International Insurance Company
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
CNA Reinsurance of London, Limited
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
Sphere Drake Insurance PLC gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Certain Underwriters at Lloyd’s London subscribing to
Policies S3721, SL3722, SL3723, ISL3115, ISL3116, ISL3117, ISL3675 ISL3613, ISL3614, and ISL3615
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
CX Reinsurance Company Ltd. gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
Stronghold Insurance Company Limited
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
Excess Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
CX Reinsurance Company Ltd. gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Dominion Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Excess Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
RiverStone Insurance (UK) Limited
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
RiverStone Insurance (UK) Limited gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
Dominion Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Tenecom, Ltd. gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
Stronghold Insurance Company Limited
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
Certain Underwriters at Lloyd’s London subscribing
to Policies S3721, SL3722, SL3723, ISL3115, ISL3116, ISL3117, ISL3675 ISL3613, ISL3614, and
ISL3615 gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Cross Defendant
Excess Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Sphere Drake Insurance PLC gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Markel International Insurance Company
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
Certain Underwriters at Lloyd’s, London
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
CNA Reinsurance of London, Limited gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Defendant
Stronghold Insurance Company Limited
gbren@fisherbren.com, tkreie@fisherbren.com;kcarpenter@fisherbren.com
Gerald H Bren
on behalf of Interested Party
Dominion Insurance Company gbren@fisherbren.com,
tkreie@fisherbren.com;kcarpenter@fisherbren.com
James A. Lodoen
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
jlodoen@lindquist.com, ghildahl@lindquist.com;tmcgruder@lindquist.com
Jeanne H. Unger
on behalf of Defendant
Continental Casualty Company junger@bassford.com,
nsinard@bassford.com
Jeanne H. Unger
on behalf of 3rd Party Plaintiff
Continental Insurance Company, The
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Defendant
The Continental Insurance Company junger@bassford.com,
nsinard@bassford.com
Jeanne H. Unger
on behalf of Interested Party
Continental Casualty Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Cross-Claimant
Continental Insurance Company junger@bassford.com,
nsinard@bassford.com
Jeanne H. Unger
on behalf of Interested Party
National Fire and Insurance Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of 3rd Party Plaintiff
Continental Casualty Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Cross-Claimant
National Fire Insurance Company of Hartford
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Interested Party
The Continental Insurance Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Counter-Claimant
National Fire Insurance Company of Hartford
junger@bassford.com, nsinard@bassford.com
Case 15-30125
District/off: 0864-3
Doc 190 Filed 04/19/15 Entered 04/19/15 23:56:14
Certificate of Notice Page 32 of 34
User: lynn
Form ID: pdf111
Page 4 of 6
Total Noticed: 1
Desc Imaged
Date Rcvd: Apr 17, 2015
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system (continued)
Jeanne H. Unger
on behalf of Defendant
National Fire Insurance Company of Hartford
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Counter-Claimant
Continental Casualty Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Cross-Claimant
The Continental Insurance Company
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of 3rd Party Plaintiff
National Fire Insurance Company of Hartford
junger@bassford.com, nsinard@bassford.com
Jeanne H. Unger
on behalf of Counter-Claimant
The Continental Insurance Company
junger@bassford.com, nsinard@bassford.com
Jeffrey D Kahane
on behalf of Interested Party
Stronghold Insurance Company Limited
JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
Excess Insurance Company
JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
Tenecom, Ltd. JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
RiverStone Insurance (UK) Limited
JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
Dominion Insurance Company
JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
CX Reinsurance Company Ltd.
JKahane@duanemorris.com
Jeffrey D Kahane
on behalf of Interested Party
Markel International Insurance Company
JKahane@duanemorris.com
Jeffrey D Klobucar
on behalf of Interested Party
The Continental Insurance Company
jklobucar@bassford.com, mrausch@bassford.com
Jeffrey D Klobucar
on behalf of Interested Party
Continental Casualty Company
jklobucar@bassford.com, mrausch@bassford.com
Jeffrey D Klobucar
on behalf of Interested Party
National Fire and Insurance Company
jklobucar@bassford.com, mrausch@bassford.com
Jeffrey D Smith
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
jsmith@lindquist.com, ghildahl@lindquist.com
Jeffrey R Anderson
on behalf of Interested Party
Certain Personal Injury Creditors
jeff@andersonadvocates.com, therese@andersonadvocates.com;erin@andersonadvocates.com
Joan M. Quade
on behalf of Interested Party
Church of Our Lady of Peace jquade@bgs.com,
dbaxter@bgs.com
John A Hedback
on behalf of Interested Party
The Catholic Cemeteries jhedback@hac-mnlaw.com,
JanineHedback@hac-mnlaw.com;ladamson@hac-mnlaw.com
John D Thompson
on behalf of Interested Party Michael P. Schaefer jthompson@obermanthompson.com
John R. McDonald
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
jmcdonald@briggs.com, mjacobson@briggs.com
Lance D. Meyer
on behalf of Defendant
The Aetna Casualty and Surety Company
ldmeyer@olwklaw.com, bjhartman@olwkaw.com
Lance D. Meyer
on behalf of Interested Party
Travelers Casualty and Surety Company (f/k/a The
Aetna Casualty and Surety Company) ldmeyer@olwklaw.com, bjhartman@olwkaw.com
Lance D. Meyer
on behalf of Cross Defendant
The Aetna Casualty and Surety Company
ldmeyer@olwklaw.com, bjhartman@olwkaw.com
Lance D. Meyer
on behalf of Counter-Claimant
The Aetna Casualty and Surety Company
ldmeyer@olwklaw.com, bjhartman@olwkaw.com
Larry B. Ricke
on behalf of Interested Party
Archdiocese Medical Benefits Plan Trust
ricke@smlawpa.net, magney@smlawpa.net
Laura K. McNally
on behalf of Cross-Claimant
Continental Insurance Company lmcnally@loeb.com,
chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Defendant
Continental Casualty Company lmcnally@loeb.com,
chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Cross-Claimant
The Continental Insurance Company
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of 3rd Party Plaintiff
National Fire Insurance Company of Hartford
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of 3rd Party Plaintiff
Continental Insurance Company, The
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Interested Party
Fireman’s Fund Insurance Company
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Interested Party
The Continental Insurance Company
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Cross-Claimant
National Fire Insurance Company of Hartford
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Interested Party
Continental Casualty Company lmcnally@loeb.com,
chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Defendant
The Continental Insurance Company lmcnally@loeb.com,
chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Counter-Claimant
National Fire Insurance Company of Hartford
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Defendant
National Fire Insurance Company of Hartford
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of 3rd Party Plaintiff
Continental Casualty Company
lmcnally@loeb.com, chdocket@loeb.com;jdennis@loeb.com
Laura K. McNally
on behalf of Counter-Claimant
Continental Casualty Company lmcnally@loeb.com,
chdocket@loeb.com;jdennis@loeb.com
Case 15-30125
District/off: 0864-3
Doc 190 Filed 04/19/15 Entered 04/19/15 23:56:14
Certificate of Notice Page 33 of 34
User: lynn
Form ID: pdf111
Page 5 of 6
Total Noticed: 1
Desc Imaged
Date Rcvd: Apr 17, 2015
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system (continued)
Lauren E Lonergan
on behalf of Counter-Defendant
Archdiocese of Saint Paul and Minneapolis
llonergan@briggs.com, lboucher@briggs.com;jduxbury-cameron@briggs.com
Lauren E Lonergan
on behalf of Plaintiff
Archdiocese of Saint Paul and Minneapolis
llonergan@briggs.com, lboucher@briggs.com;jduxbury-cameron@briggs.com
Louis T DeLucia
on behalf of Interested Party
Catholic Mutual Relief Society of America
ldelucia@schiffhardin.com,
jacquaviva@schiffhardin.com;afiedler@schiffhardin.com;sdavis@schiffhardin.com
Mark J Kalla
on behalf of Interested Party
St Stephen’s Catholic Church mkalla@lapplibra.com,
ascheel@lapplibra.com
Mark J Kalla
on behalf of Interested Party
St. Dominic Catholic Church mkalla@lapplibra.com,
ascheel@lapplibra.com
Mary Jo A. Jensen-Carter
on behalf of Creditor
The Parish Group maryjo@buckleyjensen.com,
cassiewarner@buckleyjensen.com;jensencarter@7trustee.net;MN01@ecfcbis.com
Mary Jo A. Jensen-Carter
on behalf of Interested Party
Our Lady of Grace Church
maryjo@buckleyjensen.com,
cassiewarner@buckleyjensen.com;jensencarter@7trustee.net;MN01@ecfcbis.com
Matthew R. Burton
on behalf of Interested Party
THE CHURCH OF THE EPIPHANY mburton@losgs.com,
swood@losgs.com
Matthew R. Burton
on behalf of Interested Party
CHURCH OF ST. PAUL, HAM LAKE
mburton@losgs.com, swood@losgs.com
Michael G Finnegan
on behalf of Interested Party
Certain Personal Injury Creditors
mike@andersonadvocates.com, therese@andersonadvocates.com;erin@andersonadvocates.com
Michael J Cohen
on behalf of Interested Party
TIG INSURANCE COMPANY mjc@mtfn.com
Michael J Iannacone
on behalf of Interested Party
The Church of St. Joseph (Rosemount,
Minnesota) mji@iannacone.com, knt@iannacone.com;mfs@iannacone.com
Michael J Iannacone
on behalf of Interested Party
Church of St. Thomas Becket
mji@iannacone.com, knt@iannacone.com;mfs@iannacone.com
Michael J Iannacone
on behalf of Interested Party
The Guardian Angels Catholic Church of
Oakdale, Minnesota mji@iannacone.com, knt@iannacone.com;mfs@iannacone.com
Michael J Iannacone
on behalf of Interested Party
Catholic Finance Corporation
mji@iannacone.com, knt@iannacone.com;mfs@iannacone.com
Monica L. Clark
on behalf of Interested Party
The Cathedral of Saint Paul
clark.monica@dorsey.com, yokiel.maryjo@dorsey.com
Monica L. Clark
on behalf of Interested Party
Church of St. Agnes clark.monica@dorsey.com,
yokiel.maryjo@dorsey.com
Pamela J Tillman
on behalf of Defendant
TIG INSURANCE COMPANY pjt@mtfn.com
Pamela J Tillman
on behalf of Interested Party
TIG INSURANCE COMPANY pjt@mtfn.com
Patrick C Summers
on behalf of Interested Party
Catholic Services Appeal Foundation
pcs@dewittmcm.com, kkl@dewittmcm.com;jef@dewittmcm.com
Patrick W Noaker
on behalf of Interested Party Patrick W Noaker patrick@noakerlaw.com,
sandy@noakerlaw.com
Paul L. Ratelle
on behalf of Interested Party
The Church of St. Patrick of Edina, Minnesota
pratelle@fwhtlaw.com, kjensen@fwhtlaw.com
Phillip Kunkel
on behalf of Interested Party
Catholic Community Foundation
phillip.kunkel@gpmlaw.com
Phillip J Ashfield
on behalf of Creditor Committee
Official Committee of Unsecured Creditors
phillip.ashfield@stinsonleonard.com, laura.schumm@stinsonleonard.com
Ralph Mitchell
on behalf of Interested Party
Fireman’s Fund Insurance Company
rmitchell@lapplibra.com, jpipp@lapplibra.com
Ralph Mitchell
on behalf of Interested Party
The Church of Christ the King of Minneapolis
rmitchell@lapplibra.com, jpipp@lapplibra.com
Richard D Anderson
on behalf of Debtor
The Archdiocese of Saint Paul and Minneapolis
randerson@briggs.com, mjacobson@briggs.com
Richard D Anderson
on behalf of Plaintiff
Archdiocese of Saint Paul and Minneapolis
randerson@briggs.com, mjacobson@briggs.com
Richard S. Feldman
on behalf of Interested Party
Fireman’s Fund Insurance Company
richard.feldman@rivkin.com, martha.raskin@rivkin.com
Robert Raschke
on behalf of U.S. Trustee
US Trustee robert.raschke@usdoj.gov
Robert M Vinci
on behalf of Interested Party
Travelers Casualty and Surety Company (f/k/a The
Aetna Casualty and Surety Company) robert.vinci@dbr.com
Robert T. Kugler
on behalf of Creditor Committee
Official Committee of Unsecured Creditors
robert.kugler@stinsonleonard.com, laura.schumm@stinsonleonard.com
Robin A. Williams
on behalf of Defendant
TIG INSURANCE COMPANY rawilliams@bassford.com,
vcarlson@bassford.com
Robin A. Williams
on behalf of Interested Party
TIG INSURANCE COMPANY rawilliams@bassford.com,
vcarlson@bassford.com
Russell W Roten
on behalf of Interested Party
CX Reinsurance Company Ltd.
RWRoten@duanemorris.com, DMartinez@duanemorris.com
Russell W Roten
on behalf of Interested Party
Excess Insurance Company
RWRoten@duanemorris.com, DMartinez@duanemorris.com
Russell W Roten
on behalf of Interested Party
Dominion Insurance Company
RWRoten@duanemorris.com, DMartinez@duanemorris.com
Russell W Roten
on behalf of Interested Party
Markel International Insurance Company
RWRoten@duanemorris.com, DMartinez@duanemorris.com
Russell W Roten
on behalf of Interested Party
RiverStone Insurance (UK) Limited
RWRoten@duanemorris.com, DMartinez@duanemorris.com
Russell W Roten
on behalf of Interested Party
Tenecom, Ltd. RWRoten@duanemorris.com,
DMartinez@duanemorris.com
Case 15-30125
District/off: 0864-3
Doc 190 Filed 04/19/15 Entered 04/19/15 23:56:14
Certificate of Notice Page 34 of 34
User: lynn
Form ID: pdf111
Page 6 of 6
Total Noticed: 1
Desc Imaged
Date Rcvd: Apr 17, 2015
The following persons/entities were sent notice through the court’s CM/ECF electronic mail (Email)
system (continued)
Russell W Roten
on behalf of Interested Party
Stronghold Insurance Company Limited
RWRoten@duanemorris.com, DMartinez@duanemorris.com
S Steven Prince
on behalf of Interested Party
DeLaSalle High School sprince@grellfeist.com
Sam Calvert
on behalf of Interested Party SAMUEL V CALVERT calcloud@gmail.com,
calcloud1@gmail.com;calvert.sam@gmail.com
Sarah J Wencil
on behalf of U.S. Trustee
US Trustee Sarah.J.Wencil@usdoj.gov
Steven J Heim
on behalf of Interested Party
The Cathedral of Saint Paul
heim.steven@dorsey.com, lenneman.polly@dorsey.com
Steven J Heim
on behalf of Interested Party
Church of St. Agnes heim.steven@dorsey.com,
lenneman.polly@dorsey.com
Stuart I. Gordon
on behalf of Interested Party
Fireman’s Fund Insurance Company
stuart.gordon@rivkin.com, martha.raskin@rivkin.com
Susan E Gelinske
on behalf of Counter-Defendant
Archdiocese of Saint Paul and Minneapolis
sgelinske@briggs.com, cdanek@briggs.com
Susan E Gelinske
on behalf of Plaintiff
Archdiocese of Saint Paul and Minneapolis
sgelinske@briggs.com, cdanek@briggs.com
Timothy D. Moratzka
on behalf of Interested Party
Catholic Services Appeal Foundation
tdm@dewittmcm.com, ldj@dewittmcm.com;jef@dewittmcm.com
US Trustee
ustpregion12.mn.ecf@usdoj.gov
William J. Factor
on behalf of Interested Party
TIG INSURANCE COMPANY ,
nbouchard@wfactorlaw.com
TOTAL: 179