# Exhibit I-7. Sample Procedures for Complex Chapter 11 Cases

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS

IN THE MATTER OF )

PROCEDURES FOR COMPLEX )

CHAPTER 11 CASES )

PROCEDURES FOR COMPLEX CHAPTER 11 CASES

Upon consideration of the recommendations of members of the bar of the
Northern District of Texas, the court finds a need to implement policies
and procedures to better serve the public and the bar in complex Chapter
11 cases. Accordingly,

**IT IS ORDERED** that the following procedures shall be implemented in
complex Chapter 11 cases.

1\. A "complex Chapter 11 case" is defined as a case filed in the
Northern District of Texas under Chapter 11 of the Bankruptcy Code that
requires special scheduling and other procedures because of a
combination of the following factors:

a\. The size of the case (usually total debt of more than \$10 million);

b\. The large number of parties in interest in the case (usually more
than 50 parties in interest in the case); or

c\. The fact that claims against the debtor and/or equity interests in
the debtor are publicly traded (with some creditors possibly being
represented by indenture trustees).

2\. If any party filing a Chapter 11 bankruptcy petition believes that
the case should be classified as a complex Chapter 11 case, the party
shall file with the bankruptcy petition a Notice of Designation as
Complex Chapter 11 Case in the form attached as **Exhibit A**.

3\. If a party has matters requiring expedited consideration by the
court, it should submit a Request for Expedited Consideration of Certain
"First Day" Matters in the form attached as **Exhibit B.**

4\. Each judge shall arrange the judge's calendar so that "first day"
emergency hearings, as requested in the court-approved form entitled
Request for Expedited Consideration of Certain First Day Matters, can be
conducted consistent with the Bankruptcy Code and Rules, including Rule
4001, as required by the circumstances, but not more than two business
days after the request for emergency "first day" hearings.

5\. When a party has filed a Chapter 11 case and filed a Notice of
Designation as Complex Chapter 11 Case, the **Clerk of Court shall**:

a\. Randomly allocate the case to a judge in accordance with the usual
procedures and general orders;

b\. Immediately confer with the court about designating the case as a
complex Chapter 11 case and about setting hearings on emergency or first
day motions. If the court determines that the case does not qualify as a
complex Chapter 11 case, the court shall issue an Order Denying Complex
Case Treatment in the form attached as **Exhibit C**. If the court
determines that the case appears to be a complex Chapter 11 case, the
court shall issue an Order Granting Complex Chapter 11 Case Treatment in
the form attached as **Exhibit D**; and

c\. Notify and serve counsel for the debtor with the order entered by
the court relating to the complex case treatment and notify counsel for
the debtor regarding the hearing settings for emergency or first day
matters.

6\. Counsel for the debtor, upon receipt of notice of entry of an order
regarding complex Chapter 11 case treatment, shall:

a\. Serve the order granting or denying complex Chapter 11 case
treatment on all parties in interest within seven days.

b\. Provide notice of the first day or emergency hearings in accordance
with the procedures shown in the form attached as **Exhibit E.**

7\. Counsel shall follow the agenda guidelines for hearings in complex
Chapter 11 cases attached as **Exhibit F** and the guidelines for
mailing matrices and shortened service lists attached as **Exhibit G**.

The court has authorized the Chief Bankruptcy Judge of the district to
adopt these procedures on behalf of the court.

United States Chief Bankruptcy Judge

EXHIBIT A

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS\
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ DIVISION

IN RE: )

)

) CASE NO.

)

> DEBTOR. )

NOTICE OF DESIGNATION AS COMPLEX CHAPTER 11 BANKRUPTCY CASE

This bankruptcy case was filed on \_\_\_\_\_\_\_\_\_\_\_\_\_\_, 20\_\_.
The undersigned party in interest believes that this case qualifies
under General Order 2004-03 as a complex Chapter 11 case because:

\_\_\_\_\_\_ The debtor has total debt of more than \$10 million;

\_\_\_\_\_\_ There are more than 50 parties in interest in this case;

\_\_\_\_\_\_ Claims against the debtor are publicly traded; and

\_\_\_\_\_\_ Other: Substantial explanation is required. (Attach
additional sheets if necessary.)

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, 20\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Address

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Telephone and Fax Numbers

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

E-Mail Address

EXHIBIT B

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS\
\_\_\_\_\_\_\_\_\_\_\_\_\_\_ DIVISION

IN RE: )

)

> ) CASE NO.

)

> DEBTOR. )

REQUEST FOR EXPEDITED CONSIDERATION OF CERTAIN\
"FIRST DAY" MATTERS

On , \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
filed a petition for relief under Chapter 11 of the Bankruptcy Code.
Counsel for the debtor believes that the case qualifies as a "Complex
Chapter 11 Case" as defined by General Order 2004-03. The debtor needs
expedited consideration of the following initial case matters (check
those that apply):

\_\_\_\_ Motion for joint administration

\_\_\_\_ Motion for order extending time to file schedules and statement
of financial affairs

\_\_\_\_ Motion re maintenance of bank accounts and existing cash
management, attaching notice of conference with U.S. trustee

\_\_\_\_ Motion to pay pre-petition wages, salaries, et al., attaching
notice of conference with U.S. trustee and detailed exhibit showing who
debtor proposes to pay and amounts

\_\_\_\_ Motion for entry of interim order authorizing use of cash
collateral

\_\_\_\_ Motion for interim approval of post-petition secured and, if
applicable, super-priority financing pursuant to section 364(c) of the
bankruptcy code

\_\_\_\_ Motion to establish interim notice procedures

\_\_\_\_ Motion for order approving interim retention of professionals

\_\_\_\_ Others (list):

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, 20\_\_\_

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Address

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Telephone and Fax Numbers

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

E-Mail Address

\* NOTE: The court expects the parties to exercise judgment regarding
which motions are applicable.

EXHIBIT C

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS\
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ DIVISION

IN RE: )

)

) CASE NO.

)

DEBTOR. )

ORDER DENYING COMPLEX CASE TREATMENT

This bankruptcy case was filed on \_\_\_\_\_\_\_\_\_\_\_\_, 20\_\_. A
Notice of Designation as Complex Chapter 11 Case (see General Order
2004-03) was filed. After review of the initial pleadings filed in this
case, the court concludes that the case does not appear to qualify as a
complex Chapter 11 case. Therefore, the case will proceed under the
local bankruptcy rules and procedures generally applicable to bankruptcy
cases without special scheduling orders. The court may reconsider this
determination on motion, after hearing. Based on the foregoing,

**IT IS ORDERED** that the request for designation as a complex Chapter
11 case is **DENIED.**

The Clerk shall notice:

Debtor

Debtor's Counsel

U.S. Trustee

EXHIBIT D

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS\
\_\_\_\_\_\_\_\_\_\_\_\_\_\_ DIVISION

IN RE: )

)

) CASE NO.

)

DEBTOR. )

ORDER GRANTING COMPLEX CHAPTER 11 BANKRUPTCY CASE TREATMENT

This bankruptcy case was filed on \_\_\_\_\_\_\_\_\_\_\_\_\_\_, 20\_\_.
A Notice of Designation as Complex Chapter 11 Case (see General Order
2004-03) was filed. After review of the initial pleadings filed in this
case, the court concludes that this case appears to be a complex Chapter
11 case. Accordingly, unless the court orders otherwise,

**IT IS ORDERED:**

1\. The debtor shall maintain a service list identifying the parties
that must be served whenever a motion or other pleading requires notice.
Unless otherwise required by the Bankruptcy Code or Rules, notices of
motions and other matters will be limited to the parties on the service
list.

a\. The service list shall initially include the debtor, debtor's
counsel, counsel for the unsecured creditors' committee, the U.S.
Trustee, all secured creditors, the 20 largest unsecured creditors of
each debtor, any indenture trustee, and any party that requests notice.

b\. Any party in interest that wishes to receive notice, other than as
listed on the service list, shall be added to the service list by filing
and serving the debtor and debtor's counsel with a notice of appearance
and request for service.

c\. Parties on the service list are required to provide an e-mail
address and a fax number for service of pleadings and notices. A party
who has registered with the court for use of the court's electronic
filing system has consented to service by e-mail to the extent provided
in the Revised Administrative Procedures for Electronic Case Filing
adopted by General Order 2003-01.2. A party who has not registered for
use of the court's electronic filing system may consent to fax or e-mail
service in the party's notice of appearance and request for service.
Notwithstanding consent to e-mail service, a "hard copy" shall be served
by fax or by regular mail only if required by the Revised Administrative
Procedures for Electronic Case Filing.

d\. The initial service list shall be filed within 3 days after entry of
this order. A revised list shall be filed 7 days after the initial
service list is filed. The debtor shall update the service list, and
shall file a copy of the updated service list, (i) at least every 7 days
during the first 30 days of the case; (ii) at least every 15 days during
the next 60 days of the case; and (iii) at least every 30 days
thereafter throughout the case.

2\. The court sets \_\_\_\_\_\_\_\_\_\_\_\_\_ of each week at
\_\_\_\_\_\_\_ \_\_.m. as the pre-set hearing day and time for hearing
all motions and other matters in these cases. (There may be exceptions;
those exceptions will be noted on the court's internet schedule,
available at www.txnb.uscourts.gov.)

a\. All motions and other matters requiring hearing, but not requiring
expedited or emergency hearing, shall be noticed for hearing, on the
next pre-set hearing day that is at least 23 days after the notice is
mailed. Parties may use the court's self-calendar procedure at
www.txnb.uscourts.gov.

The court will hear matters on any pre-set hearing date as time permits.
Parties must establish the recommended priority for hearing matters on
any pre-set hearing date using the agenda format provided by Exhibit F
to Procedures for Complex Chapter 11 Cases. The court will ultimately
determine the manner of proceeding on any pre-set hearing date, and may
continue hearings to subsequent pre-set hearing dates.

As a preface to each pleading, just below the case caption, in lieu of
the language required by Local Bankruptcy Rule 9007.1, and
notwithstanding Local Bankruptcy Rule 9014.1, the pleading shall state:

A HEARING WILL BE CONDUCTED ON THIS MATTER ON\
AT \_\_\_\_\_\_\_.M. IN COURTROOM \_\_\_\_\_\_\_,
\_\_\_\_\_\_\_\_\_\_\_, \_\_\_\_\_\_\_\_\_\_\_, TEXAS. IF YOU OBJECT TO
THE RELIEF REQUESTED, YOU MUST RESPOND IN WRITING, SPECIFICALLY
ANSWERING EACH PARAGRAPH OF THIS PLEADING. UNLESS OTHERWISE DIRECTED BY
THE COURT, YOU MUST FILE YOUR RESPONSE WITH THE CLERK OF THE BANKRUPTCY
COURT WITHIN TWENTY DAYS FROM THE DATE YOU WERE SERVED WITH THIS
PLEADING. YOU MUST SERVE A COPY OF YOUR RESPONSE ON THE PERSON WHO SENT
YOU THE NOTICE; OTHERWISE, THE COURT MAY TREAT THE PLEADING AS UNOPPOSED
AND GRANT THE RELIEF REQUESTED.

b\. All motions and other matters requiring expedited or emergency
hearing shall comply with the usual court requirements for explanation
and verification of the emergency. Specifically, if a party in interest
has an emergency or other situation that it believes requires
consideration on less than 23-days' notice, the party should file and
serve a separate, written motion for expedited hearing, in respect of
the underlying motion, and may present the motion for an expedited
hearing either (a) ex parte at a regular docket call of the presiding
judge, or (b) at the next available pre-set hearing day. The court will
rule on the motion for expedited hearing within 24 hours of the time it
is presented. If the court grants the motion for expedited hearing, the
underlying motion will be set by the courtroom deputy at the next
available pre-set hearing day or at some other appropriate shortened
date approved by the court. The party requesting the hearing shall be
responsible for providing proper notice in accordance with this order
and the Bankruptcy Code and Rules.

3\. Emergency and expedited hearings (and other hearings in limited
circumstances) in this case may be conducted by telephone conference.
Parties must request permission to participate by telephone by
contacting the courtroom deputy by e-mail.

4\. If a matter is properly noticed for hearing and the parties reach a
settlement of the dispute prior to the final hearing, the parties may
announce the settlement at the scheduled hearing. If the court
determines that the notice of the dispute and the hearing is adequate
notice of the effects of the settlement (i.e., that the terms of the
settlement are not materially different from what parties in interest
could have expected if the dispute were fully litigated), the court may
approve the settlement at the hearing without further notice of the
terms of the settlement.

5\. The debtor shall give notice of this order to all parties in
interest within 7 days. If any party in interest, at any time, objects
to the provisions of this order, that party shall file a motion
articulating the objection and the relief requested. After hearing the
objection and any responses the court may reconsider any part of this
order and may grant relief, if appropriate.

The Clerk shall notice:

Debtor

Debtor's Counsel

U.S. Trustee

EXHIBIT E

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS

Procedures for Obtaining Hearings in Complex Chapter 11 Cases

**I. Hearing on First Day Matters: Official Form for Request for
Expedited Consideration of Certain First Day Matters.**

Upon the filing of a complex Chapter 11 case, if the debtor has matters
that require expedited consideration ("first day" or "near first day"
relief), the debtor should file a "Request for Expedited Consideration
of Certain 'First Day' Matters" using the form of Exhibit B to the
Procedures for Complex Chapter 11 Cases ("First Day Hearing Request"),
and inform the courtroom deputy of the request by e-mail. The first day
hearing request will be presented by the courtroom deputy to the judge
who has been assigned the complex Chapter 11 case (or if there are
multiple, related debtor cases, to the judge assigned to the first-filed
case) as soon as possible. The court will hold a hearing within 2
business days of the time requested by the debtor's counsel and the
courtroom deputy will notify counsel for the debtor of the time of the
setting. If the judge assigned to the complex Chapter 11 case is not
available to hold the hearing within 2 business days of the time
requested by the debtor's counsel, an available judge will hold a
hearing within 2 business days of the time requested by the debtor's
counsel and the courtroom deputy will notify counsel for the debtor of
the time of the setting. The debtor's counsel should (1) serve
electronically or, for parties not receiving electronic notification, by
fax (or by immediate hand-delivery) a copy of the first day hearing
request on all affected parties, including the U.S. Trustee,
simultaneously with its filing; and (2) notify electronically, or, for
parties not receiving electronic notification, by fax (or by immediate
hand-delivery) all affected parties of the hearing time on first day
matters as soon as possible after debtor's counsel has received
confirmation from the court. The court will allow parties in interest to
participate telephonically at the hearing on first day matters whenever
(and to the extent) practicable, and debtor's counsel will be
responsible for the coordination of the telephonic participation.

**II. Pre-Set Hearing Dates.**

The debtor may request (as one of its first day matters or otherwise)
that the court establish in a complex Chapter 11 case a
weekly/bi-monthly/monthly setting time ("Pre-Set Hearing Dates") for
hearings in the complex Chapter 11 case (e.g., every Wednesday at 1:30
p.m.). The court will accommodate this request for pre-set hearing dates
in a complex Chapter 11 case if it appears justified. After pre-set
hearing dates are established, all matters in the complex Chapter 11
case (whether initiated by a motion of the debtor or by another party in
interest) may be set by using the court's self-calendar process on the
first pre-set hearing date that is at least 23 days after the
filing/service of a particular motion (unless otherwise requested by a
party or ordered by the court) and the movant shall indicate the hearing
date and time on the face of the pleading.

**III. Case Emergencies (Other than the First-Day Matters).**

If a party in interest has an emergency or other situation that it
believes requires consideration on less than 23-days' notice, the party
should file and serve a separate, written motion for expedited hearing,
in respect of the underlying motion, and inform the courtroom deputy of
the request by e-mail. The court may direct that the motion for
expedited hearing be presented at a regular docket call of the presiding
judge, or at the next available pre-set hearing date. If the court
grants the motion for expedited hearing, the underlying motion will be
set by the courtroom deputy at the next available pre-set hearing date
or at some other appropriate shortened date approved by the court.
Motions for expedited hearings will only be granted under emergency or
exigent circumstances.

EXHIBIT F

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS

AGENDA GUIDELINES FOR HEARINGS IN\
COMPLEX CHAPTER 11 CASES

In complex Chapter 11 cases, counsel for the debtor-in-possession shall
file and serve an agenda describing the nature of the items set for
hearing. Counsel for the debtor in possession shall also post the agenda
on the court's website following instructions that will be provided by
the court at the commencement of the case.

**1. Timing of Filing**

Counsel shall file the agenda at least 24 hours prior to the date and
time of the hearing. At the same time, counsel shall also serve a copy
of the agenda on all attorneys who have filed papers with respect to the
matters scheduled and the service list.

**2. Sequence of Items on Agenda**

Uncontested matters should be listed ahead of contested matters.
Contested matters should be listed in the order in which they appear on
the court's docket. When matters have been noticed for hearing by
parties in interest other than the debtor-in-possession, counsel for the
debtor-in-possession shall consult with counsel for the moving parties
to determine the recommended priority for hearing contested matters. Any
disagreement on the recommended priority shall be noted on the agenda.
The court will determine the order of proceeding.

**3. Status Information**

For each motion filed in the complex Chapter 11 case, each motion filed
in an adversary proceeding concerning the Chapter 11 case, each
objection to claim, or application concerning the case, the agenda shall
indicate the moving party, the nature of the motion, the docket number
of the pleading, if known, the response deadline, and the status of the
matter. The status description should indicate whether the motion is
settled, going forward, whether a continuance is requested (and any
opposition to the continuance, if known) and any other pertinent
information.

**4. Information for Motions in the Case**

For each motion that is going forward, or where a continuance request is
not consensual, the agenda shall also list all pleadings in support of
the motion, and any objections or responses. Each pleading listed shall
identify the entity that filed the pleading, and the docket number of
the pleading, if known. If any entity has not filed a responsive
pleading, but has engaged in written or oral communications with the
debtor, that fact should be indicated on the agenda, as well as the
status or outcome of those communications.

For an omnibus objection to claims, responses to the objection which
have been continued by consent may be listed collectively (e.g., "the
following responses have been continued by consent:").

**5. Changes in Agenda Information**

After the filing of the agenda, counsel shall file and post on the
court's website any revised agenda.

**6. Other Information**

The requirements listed above should not be construed to prohibit other
information of a procedural nature that counsel thinks would be helpful
to the court.

EXHIBIT G

IN THE UNITED STATES BANKRUPTCY COURT\
FOR THE NORTHERN DISTRICT OF TEXAS

Guidelines for Mailing Matrices and Shortened Service Lists in\
Complex Chapter 11 Cases

**I. Mailing List or Matrix (a/k/a the Rule 2002 Notice List)**

**A. Helpful Hints Regarding Whom to Include on the Mailing Matrix in a
Complex Chapter 11 Case.**

There are certain events and deadlines that occur in a Chapter 11 case
which Bankruptcy Rule 2002 requires be broadly noticed to all creditors,
indenture trustees, equity interest holders, and other parties in
interest ("Rule 2002 notice list"). To facilitate this, L.B.R. 1007.2
requires a debtor to file a mailing list or matrix at the commencement
of any case. This list must include all creditors, equity interest
holders, and certain other parties in interest (who might be impacted by
any relief granted in the bankruptcy case), in order to ensure that
parties receive reasonable and adequate notice and are ensured due
process. When preparing the mailing matrix and after consultation with
the clerk of court, debtor's counsel shall evaluate and consider whether
the following people are required to be included:

1\. creditors (whether a creditor's claim is disputed, undisputed,
contingent, non-contingent, liquidated, unliquidated, matured,
unmatured, fixed, legal, equitable, secured or unsecured);

2\. indenture trustees;

3\. financial institutions at which the debtor has maintained accounts
(regardless of whether such institutions are creditors);

4\. vendors with whom the debtor has dealt, even if the debtor's records
currently indicate no amount is owed;

5\. parties to contracts, executory contracts or leases with the debtor;

6\. all federal, state, or local taxing authorities with which the
debtor deals, including taxing authorities in every county in which the
debtor owns real or personal property with regard to which ad valorem
taxes might be owed;

7\. all governmental entities with which the debtor might interact
(including, but not limited to, the U.S. Trustee and the SEC);

8\. any party who might allege a lien on property of the debtor;

9\. parties to litigation involving the debtor;

10\. parties with which the debtor might be engaged in some sort of
dispute, whether or not a claim has formally been made against the
debtor;

11\. tort claimants or accident victims;

12\. insurance companies with whom the debtor deals or has policies;

13\. active and retired employees of the debtor;

14\. officers or directors of the debtor;

15\. customers who are owed deposits, refunds, or store credit;

16\. utilities;

17\. shareholders (preferred and common), holders of options, warrants
or other rights or equitable interests in the debtor;

18\. miscellaneous others who, in debtor's counsel's judgment, might be
entitled to "party in interest" status or who have requested notice.

**B. Flexible ("User-Friendly") Format Rules for Mailing Matrix in a\
Complex Chapter 11 Case in Which Debtor's Counsel Serves Notices.**

> In a complex Chapter 11 case, where the mailing matrix is likely to be
> very lengthy, the following special format rules will apply, in lieu
> of L.B.R. 1007.2, whenever it is the debtor's responsibility to serve
> notices in the case. The debtor (since it will typically be the party
> serving all notices in the Chapter 11 case rather than the clerk of
> court) may create the mailing matrix in whatever format it finds
> convenient so long as it is neatly typed in upper and lower case
> letter-quality characters (in no smaller than 10 point and no greater
> than 14 point type, in either Courier, Times Roman, Helvetica or
> Orator font). The mailing matrix, if lengthy, should ideally include
> separate subheadings throughout, to help identify categories of
> parties in interest. By way of example, the following subheadings
> (among others) might be used:
>
> Debtor and its Professionals
>
> Secured Creditors
>
> Indenture Trustees
>
> Unsecured Creditors
>
> Governmental Entities
>
> Current and Retired Employees
>
> Officers and Directors
>
> Tort Claimants
>
> Parties to Executory Contracts
>
> Equity Interest Holders
>
> Etc.
>
> Parties in interest within each category/subheading should be listed
> alphabetically. Also, the mailing matrix may be filed in separate
> volumes, for the separate categories of parties in interest, if the
> mailing matrix is voluminous (e.g., Volume 2: Unsecured Creditors).
> Finally, if there are multiple, related debtors and the debtors intend
> to promptly move for joint administration of their cases, the debtors
> may file a consolidated mailing matrix, subject to later being
> required to file separate mailing matrices if joint administration is
> not permitted.

**C. When Inclusion of Certain Parties in Interest on a Mailing Matrix
Is Burdensome.**

If inclusion of certain categories of parties in interest on the mailing
matrix would be extremely impracticable, burdensome and costly to the
estate, the debtor may file a motion, pursuant to B.R. 2002(l),
requesting authority to provide notice by publication in lieu of mailing
certain notices to certain categories of parties in interest and may
forego including those categories of parties in interest on the mailing
matrix if the court grants the motion.

**II. Shortened Service List Procedure in a Complex Chapter 11 Case.**

**A. Procedures/Contents/Presumptions.**

If the court has entered an order granting complex Chapter 11 case
treatment, the debtor shall provide service as required by ¶ 1 of that
order. If the court has not entered such an order, the debtor may move
to limit notice -- that is, for approval of a shortened service list --
that will be acceptable for noticing most events in the bankruptcy case,
other than those events/deadlines that B.R. 2002 contemplates be served
on all creditors and equity interest holders. At a minimum, the
shortened list should include the debtor and its professionals, the
secured creditors, the 20 largest unsecured creditors, any official
committees and the professionals for same, the U.S. Trustee, the IRS and
other relevant governmental entities, and all parties who have requested
notice. Upon the court's approval of a shortened service list in a
complex Chapter 11 case, notice in any particular situation during a
case shall be presumed adequate if there has been service on (1) the
most current service list on file in the case; plus (2) any other party
directly affected by the relief requested and not otherwise included on
the service list.

**B. Obligation to Update, File, and Serve Service List.**

The debtor must update the service list as parties request to be added
to it or as circumstances otherwise require. To be added to the list, a
party should file a notice of appearance and request for service and
serve the notice on debtor's counsel. Parties should include an e-mail
address and fax number. Additionally, the debtor should file an updated
service list and should serve a clean and redlined copy of the updated
service list on all parties on the service list weekly for the first
month after filing, then bi-monthly for the next 60 days, then monthly
thereafter during the pendency of the case. If, in a particular month,
there are no changes to the service list, the debtor should simply file
a notice with the court so stating.