# Exhibit I-8. Sample Guidelines for Case-Management Order for Complex Chapter 11 Case (United States Bankruptcy Court for the District of New Jersey)

EXHIBIT F

GUIDELINES ESTABLISHING\
CASE-MANAGEMENT AND ADMINISTRATIVE PROCEDURES\
FOR CASES DESIGNATED AS COMPLEX CHAPTER 11 CASES

After review of the initial pleadings filed in a case designated and
approved as "complex" and the Court conducting its initial status
conference at the hearing on First Day Matters, and for which the court
concludes that the case is appropriate for the entry of a case
management and administrative procedures order, the following guidelines
as they relate to case management and administrative procedures may be
requested by Debtor's counsel upon the submission of an "Order
Establishing Case-Management and Administrative Procedures for Cases
Designated as Complex Chapter 11 Cases."

A. OMNIBUS HEARING DATES

1\. The Court may conduct omnibus hearings on a
weekly/bi-monthly/monthly basis as dictated by the circumstances of the
case (the "Omnibus Hearing Dates").

2\. Omnibus Hearing Dates will occur thereafter as may be scheduled by
the Court. To the extent possible, all matters requiring a hearing in
this case shall be set for and be heard on Omnibus Hearing Dates unless
alternative hearing dates are approved by the Court for good cause
shown.

B. EXPEDITED HEARINGS

3\. If a party in interest has an emergency or other situation that it
believes requires consideration on less than the 20-days' notice as
required by D.N.J. LBR 9013-1(c), the moving party should file and serve
a separate written application requesting shortened time and expedited
hearing in respect of the underlying motion in the form provided at
D.N.J. LBR 9013-1(e).

4\. The Court will rule on the request for shortened time within
twenty-four (24) hours of the time it is presented. If the court grants
the motion for expedited hearing, the underlying motion will be set at
the next available omnibus hearing date or at some other appropriate
shortened date approved by the Court.

5\. Requests for expedited hearings will only be granted under emergency
or exigent circumstances.

6\. This section does not apply to matters filed under an Application
for Expedited Consideration of First Day Matters and all parties are
directed to consult the General Order Adopting Guidelines Governing
First Day Matters.

C. COMPLIANCE WITH TERMS OF ORDER ESTABLISHING CASE-MANAGEMENT AND
ADMINISTRATIVE PROCEDURES

7\. If any person makes any filing in contravention of the omnibus dates
process established pursuant to a particular chapter 11 case Order
Establishing Case-Management and Administrative Procedures entered by
the Court by, among other things, setting a hearing on such filing for a
date and time other than an omnibus hearing date without an order from
this Court authorizing such hearing for cause, the Debtor's counsel
shall forward a copy of the Order Establishing Case-Management and
Administrative Procedures to such person within three (3) business days
of the receipt of such filing. If such filing is filed at least twenty
(20) days from the next Omnibus Hearing Date, then the hearing with
respect to such filing shall be deemed to be on such omnibus hearing
date. If such filing is less than twenty (20) days prior to the next
omnibus hearing date then the hearing with respect to such filing shall
be the next omnibus hearing date thereafter. The movant must provide
notice of the corrected hearing date to all affected parties and
thereafter file a certificate of service regarding the notice.

D. NOTICING PROCEDURES

8\. All filings in this case, unless otherwise ordered by the Court,
shall be served upon the following entities constituting the "Core
Service List":

\(a\) The Debtor(s);

\(b\) The Debtor's counsel;

\(c\) The Newark office of the United States Trustee for Region III;

\(d\) The chairperson of any official committees established pursuant to
section 1102 of the Bankruptcy Code;

\(e\) Counsel retained by any official committees established pursuant
to section 1102 of the Bankruptcy Code, or the twenty (20) largest
creditors if an official committee has not been appointed;

\(f\) Counsel to secured creditors; and

\(g\) Any other person/entity as authorized by the Court.

9\. Debtor's counsel or counsel to the trustee, if one is appointed,
must maintain and update the Core Service List at least every fifteen
(15) days during the first sixty (60) days of the case and at least
every thirty (30) days thereafter. Further, Debtor's counsel must file a
Core Service List with the Court every time it is updated.

10\. Debtor's counsel or counsel to the trustee shall also maintain and
update a master service list (the "Master Service List") which shall be
comprised of the Core Service List and the parties that have filed a
notice of appearance and request for notices in the Debtor's case.
Service on the persons/entities listed on the Master Service List shall
be made only with respect to those matters enumerated in the Order
Establishing Case-Management and Administrative Procedures. Debtor's
counsel must update the Master Service List at least every fifteen (15)
days during the first sixty (60) days of the case and at least every
thirty (30) days thereafter. Further, Debtor's counsel must file the
Master Service List with the Court each time it is updated.

11\. The certificate of service for each filing must be filed with the
Court together with the complete service list that was utilized and
served for a particular filing but said certificate of service is not to
be served via hard copy on the recipients of the filing.

12\. Whether filed conventionally or electronically, summons and
complaints or the initiating motion in a contested matter shall be
served in hard copy format pursuant to Fed. R. Bankr. P. 7004, upon all
parties having a particularized interest in the subject of the filings
or motions and parties listed on the Core Service List.

13\. All notices required by subdivisions (a)(2), (3) and (6) of Fed. R.
Bankr. P. 2002 and by Fed. R. Bankr. P. 4001 shall be served upon:

\(a\) Each entity designated on the Core Service List; and

\(b\) When the notice is of a proposed use, sale, lease or abandonment
of property or of a hearing thereon, each entity designated on the most
recent Master Service List and each entity having an interest in the
property; and

\(c\) When the notice relates to relief from the stay in order to take
action against property of the Debtor's Estate, each entity having a
lien, encumbrance or interest in the subject property; and

\(d\) When the notice relates to use of cash collateral or obtaining
credit, each entity who has an interest in the cash collateral or each
entity who has a lien or other interest in property on which a lien is
proposed to be granted; and

\(e\) When the notice is of a proposed compromise or settlement or of a
hearing thereon, each entity designated on the most recent Master
Service List and each entity who is a party to the compromise or
settlement; and

\(f\) When the notice is of an application for compensation or
reimbursement of expenses or of a hearing thereon, each entity
designated on the most recent Master Service List and each professional
person who is seeking compensation or reimbursement whose retention in
these cases is authorized by the Court.

E. NEGATIVE NOTICING PROCEDURES

14\. Subject to the Court's discretion, the Court may approve notice
procedures which provide that if no objections are timely filed and
served by a deadline set in accordance with the Federal Rules of
Bankruptcy Procedure and/or the Order Establishing Case-Management and
Administrative Procedures and/or the District of New Jersey Local
Bankruptcy Rules, the Court may enter an order granting the relief
requested without further notice or a hearing ("Negative Notice"). The
notice of motion accompanying such motion must specifically advise
parties of the objection deadline, and must also inform the recipient
that if no objections are filed and served, the Court may enter an order
granting the motion without further notice or hearing.

15\. "Negative Notice" may be used in connection with motions including,
but not limited to, matters requesting the following relief:

\(a\) Rejection of a non-residential real property lease or executory
contract pursuant to 11 U.S.C. § 365;

\(b\) Retention and employment of professional pursuant to 11 U.S.C. §§
327, 328 and 330 and 28 U.S.C. § 156(o);

\(c\) Extension of deadline to seek removal action pursuant to Federal
Rule of Bankruptcy Procedure 9027;

\(d\) Sales of assets outside the ordinary course of business pursuant
to 11 U.S.C. § 363 with a purchase price set on a case-by-case basis;

\(e\) Approval of settlements and compromises pursuant to Federal Rule
of Bankruptcy Procedure 9019 of claims where the settled amount of the
claim does not exceed an amount set on a case-by-case basis; and

\(f\) Nothing contained herein shall be construed to limit a party in
interest's ability to request that the court approve the use of Negative
Notice procedures in connection with motions not specifically identified
above.

16\. If an objection is timely filed and served, a hearing will be
scheduled for the next omnibus hearing date unless otherwise ordered by
the Court.

F. CERTIFICATION OF NO OBJECTION

17\. After the objection date has passed with no objection having been
filed or served, counsel for the movant may file a Certification of No
Objection substantially in the form as it appears on the annexed
Schedule "1" stating that no objection has been filed or served on the
movant.

18\. By filing such certifications, counsel for the movant is
representing to the Court that the movant is unaware of any objection to
the motion or application and that counsel has reviewed the Court's
docket and no objection appears thereon.

19\. Upon receipt of the Certification of No Objection, the Court may
enter the Order accompanying the motion or application without further
pleading or hearing and, once the Order is entered, the hearing
scheduled on the motion or application shall be cancelled without
further notice.

G. NOTICE OF AGENDA

20\. Subject to the Court's discretion, in a case that has been
designated as complex and if the Court has authorized a Notice of Agenda
to be utilized, debtor's counsel or counsel to the trustee, if one is
appointed shall maintain file and serve a Notice of Agenda for each
hearing held in the case in conformity with the proposed form annexed
hereto as Schedule "2" and the guidelines set forth below (G.21-G.28)
unless modified or otherwise directed by the Court to the contrary.

21\. Counsel (as described above in section G.20) shall file a proposed
Notice of Agenda before 12:00 noon on the day that is two (2) business
days before the date of the omnibus hearing.

22\. Resolved or continued matters shall be listed ahead of unresolved
matters on the Notice of Agenda. Contested matters shall be listed in
the order of docketing with corresponding docket number.

23\. All amended Notices of Agenda shall list matters as listed in the
original Notice of Agenda with all edits and additional information
being listed in boldface type.

24\. Copies of the Notice of Agenda shall be served upon local counsel
who have entered an appearance in the case, as well as all other counsel
with a direct interest in any matter on the Notice of Agenda and the
United States Trustee simultaneously with the filing of the Notice of
Agenda with the Court.

25\. For each motion and/or application the Notice of Agenda shall
indicate the movant and/or the applicant, the nature of the motion and
the docket number. Supporting papers of the movant/applicant shall be
similarly denoted.

26\. For each motion/application the Notice of Agenda shall indicate the
objection deadline and any objection filed and its docket number, if
available.

27\. For each motion/application the Notice of Agenda shall indicate
whether the matter is going forward, whether a continuance is requested
(and any opposition to the continuance if known), whether any or all of
the objections have been resolved and any other pertinent status
information.

28\. When an adversary proceeding is scheduled the Notice of Agenda
shall indicate the adversary proceeding number and the corresponding
docket number for pleadings filed in the adversary proceeding on the
Notice of Agenda, in addition to the information regularly required in a
Notice of Agenda.

H. PRO HAC VICE APPLICATIONS

29\. Application by non-resident attorneys for permission to practice
before the Court in this case, pro hac vice, may not be set for hearing
unless the Court requires otherwise. These applications may be GRANTED
by the Court unless objections are promptly filed thereto. Pro hac vice
applications must be served upon each entity designated on the Core
Service List.

30\. The Court will require parties to obtain local counsel in
accordance with the District of New Jersey Local District Court Rules
and Local Bankruptcy Rules.

I. ELECTRONIC FILING PROCEDURES

31\. Pursuant to this Court's General Order Authorizing Administrative
Procedures for the Electronic Filing, Signing and Verification of
Documents, dated March 27, 2002, except with regard to documents which
may be filed under seal, unless good cause can be demonstrated and
established to the contrary at the return date on the hearing(s) of the
First Day Matters, all motions, pleadings, memoranda of law or other
documents to be filed with the Court in a Complex Chapter 11 Case shall
be electronically filed on the Court's Electronic Filing System.

32\. Notwithstanding the above, the Office of the United States Trustee
for Region III--New Jersey Office requires service upon it of the
following documents in hard copy format regardless of whether the United
States Trustee's Office receives same electronically:

a\. Petition;

b\. Schedules and Statement of Financial Affairs;

c\. Chapter 11 Plan and Disclosure Statement;

d\. Fee Applications;

e\. All First Day Matters and supporting pleadings and documents
thereto; and

f\. Monthly Operating Reports.

J. MAILING MATRIX

33\. A mailing matrix submitted electronically shall be prepared in
accordance with D.N.J. LBR 1007-2.

K. OTHER ADMINISTRATIVE ISSUES

34\. Any party may at any time apply for reconsideration or modification
of the Order Establishing Case-Management and Administrative Procedures.
Service of said motion shall be made to all persons/entities on the
Master Service List. The court may amend the Order Establishing Case
Management and Administrative Procedure from time to time as is
necessary.