UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF MISSOURI

EASTERN DIVISION

IN THE MATTER OF: ) In Proceedings Under Chapter 11

)

DEBTOR NAME, ) Case No. 01-12345-XXX

)

Debtors. )

) Honorable \_\_\_\_\_\_\_\_\_\_\_\_

) United States Bankruptcy Judge

**[STANDING ORDER #3]{.underline}**

**SETTING CLAIMS BAR DATE, ESTABLISHING CLAIMS\
PROCESSING AND OBJECTION PROCEDURES, AND ESTABLISHING\
[CLAIMS ESTIMATION PROCEDURES PURSUANT TO 11 U.S.C. § 502]{.underline}**

This matter coming before the Court on the request of the Debtors and
Debtors‑in‑Possession, the Court having reviewed and considered the
request and having heard the statements of counsel in support thereof
and the statements of all other parties appearing before the Court in
connection therewith; the Court having jurisdiction over this matter
pursuant to 28 U.S.C. §§ 157 and 1334 and Local District Court
Rule 9.01(B)(1); the Court finding that this is a core proceeding
pursuant to 28 U.S.C. § 157(b)(2); the Court being fully apprised in the
premises and having determined that the legal and factual bases are
sufficient to establish just cause for the relief herein granted; now
therefore,

**IT IS ORDERED, ADJUDGED AND DECREED**

[Claims Bar Date]{.underline}

1.  \_\_\_\_\_\_\_\_\_\_\_\_\_\_ is fixed as the last day (the "Bar
    Date") by which all creditors of the above‑captioned Debtors must
    file proofs of claim with the Court. A copy of the Proof of Claim
    Form which should be utilized in these proceedings is attached as
    Exhibit A. Alternative proof of claim forms may be used provided any
    form used shall be in substantial conformity with the Official Proof
    of Claim Form.

2.  An Original of [each]{.underline} proof of claim must be filed with
    the Clerk of Court on or before \_\_\_\_\_\_\_\_\_\_\_\_\_\_. All
    proofs of claim shall be mailed to: \[If using a P.O. Box\]

    \_\_\_\_\_\_\_\_\_\_\_\_\_\_ (Debtor name) Claims\
    Clerk, United States Bankruptcy Court\
    P.O. Box \_\_\_\_\
    St. Louis, Missouri 63101

    Claims may be filed in person at the Office of the Clerk of Court,
    111 S. Tenth Street, Fourth

    Floor, St. Louis, Missouri, 63102. If a creditor requests an
    acknowledgment copy of the proof of claim, an additional copy of the
    proof of claim along with a self‑addressed, postage prepaid return
    envelope shall be submitted.

    Each claim must specifically state the name and case number of each
    Debtor against which such claim is asserted. Claims in foreign
    currency must state the amounts claimed in such foreign currency and
    must also convert each such amount to United States Dollars as of
    \_\_\_\_\_\_\_\_\_\_\_\_\_ (the petition date). If claims are to be
    asserted against more than one of the Debtors, a separate, original
    (with appropriate copies) of each proof of claim must be filed in
    each case in which a claim is asserted. Multiple Debtor Claims may
    [not]{.underline} be filed in a single proof of claim.

3.  Except as provided in paragraphs 4‑7 hereof, any claim against any
    of the debtors that is not filed in accordance with the bar order on
    or before \_\_\_\_\_\_\_\_\_\_\_ shall be barred, and the debtors
    and their estates shall be released from any and all indebtedness or
    other liability to the holder of each such claim as claim is defined
    in 11 U.S.C. § 101(5), in these chapter 11 proceedings. Holders of
    such barred claims shall be foreclosed from voting upon or receiving
    distribution under any plan or plans of reorganization in these
    cases.

4.  THE FOLLOWING CREDITORS NEED [NOT]{.underline} FILE PROOFS OF CLAIM
    AT THIS TIME:

    a.  Any creditor whose claim is listed in the Schedules of Assets
        and Liabilities of the Debtors as filed on
        \_\_\_\_\_\_\_\_\_\_\_\_, or expected to be filed on
        \_\_\_\_\_\_\_\_\_\_\_\_\_\_ (or any amendments to such
        Schedules), if the claim is not listed as "contingent,"
        "unliquidated" or "disputed" and if the creditor does not
        dispute the classification and scheduled amount of its claim;

    b.  Any creditor who has filed a proof of claim and who does not
        seek to change the claim as filed.

    c.  Any creditor whose claim is allowable under section 507(a)(1) of
        the Bankruptcy Code as an expense of administration of the
        Debtors' chapter 11 cases. Holders of delinquent post‑petition
        claims, if any, against the Debtors should file an appropriate
        application with the Court;

    d.  Any creditor whose claim has been paid or otherwise satisfied
        pursuant to authorization of the Bankruptcy Court;

    e.  Any creditor whose claim arises under the Debtor‑in‑Possession
        Financing Agreement and Facility;

    f.  Any creditor whose claim is a claim by any one of the Debtors or
        any affiliate of the Debtors against another Debtor, as
        reflected on the Schedules;

    g.  Any creditor whose claim has been allowed or disallowed by order
        of this Court.

    h.  Any environmental claims of any governmental unit that relate to
        properties currently owned by any of the Debtors.

    i.  Claims of any bondholder for amounts outstanding under a
        particular bond need not be filed separately by the bondholder.
        The Indenture Trustee for each bond issue is authorized to file
        a proof of claim with respect to all amounts outstanding under
        the bonds of that issue.

5.  Any creditor whose claim arises out of the rejection by the Debtor
    of an executory contract or unexpired lease or a judgment entered
    against the creditor pursuant to an action under Chapter 5 of the
    Bankruptcy Code must file its claim by the later of
    (i) \_\_\_\_\_\_\_\_(the claims bar date), or (ii) within 30 days
    after entry of an order approving the rejection.

6.  Any creditor who has already filed a proof of claim need not file a
    duplicate proof of claim. Those creditors with claims listed on the
    schedules in amounts, priorities, and type that the creditors do not
    contest need not file a proof of claim.

7.  In the event any Debtor amends its Schedules of Assets and
    Liabilities subsequent to the date hereof to reduce the amount of a
    scheduled claim or to reclassify the claim as "contingent,"
    "unliquidated" or "disputed," the Debtor shall give written notice
    of such amendment to the holder of the claim affected thereby, along
    with notice that the holder has 30 days from the date of the notice
    to file or amend a proof of claim, if necessary, or be forever
    barred from so doing.

8.  The provisions of the bar order apply to all claims of whatever
    character or nature against any debtor or its property, whether
    secured or unsecured, liquidated or unliquidated, fixed or
    contingent.

9.  The Debtors' Schedules of Assets and Liabilities may be examined and
    inspected by interested parties in the office of the Clerk of the
    United States Bankruptcy Court, Thomas F. Eagleton U.S. Courthouse,
    111 South Tenth Street, Fourth Floor, St. Louis, Missouri 63102.
    Copies of Debtors' Schedules of Assets and Liabilities may be
    obtained from Bankruptcy Services, Inc., Thomas F. Eagleton U.S.
    Courthouse, 111 South Tenth Street, Fourth Floor, St. Louis,
    Missouri 63102, (314) 244-4940 or may be viewed electronically
    through the court's PACER system. Information regarding access to
    case information through PACER-NET is available on the court's web
    site at http:\\\\www.moeb.uscourts.gov.

10. Each proof of claim will be assigned a claim number upon filing.

11. a\) The Clerk of the Court shall maintain a claims register within
    the Court's ECF system. Debtors shall give such notice and perform
    such functions as are required by Bankruptcy Rules 3001 and 3004
    using forms and procedures which are substantially similar to those
    used by the Clerk.

    b\) **[THESE CASES ARE NOT CONSOLIDATED]{.underline}.** Consistent
    with Standing Order #1 in these cases, proofs of claims are to be
    numbered sequentially and maintained by the Clerk in a single claims
    file without regard to the particular estate against which each
    claim is asserted. However, claims information shall be stored in
    such a manner as to provide a separate claims register in each
    estate listing only those claims asserted against the particular
    estate.

    c\) All documents proffered as proofs of claims are to be processed
    as such, subject to objection as set out below.

12. The Court (or the Debtors, if a claims agent has been assigned) is
    responsible for notifying creditors of the Claims Bar Date not later
    than \_\_\_\_\_\_\_\_\_\_\_\_\_. The Court (or the Debtors, if a
    claims agent has been assigned) shall mail to all persons on the
    Matrix, Master Service List and Master Notice List a copy of the
    Notice of Bar Date for the Filing of Proofs of Claim. Debtors shall
    publish, on or before \_\_\_\_\_\_\_\_\_\_\_\_\_\_, the Notice of
    Bar Date for the Filing of Proofs of Claim in the following
    newspapers: [St. Louis Post‑Dispatch; Wall Street Journal (National
    Edition)]{.underline}. A copy of the Notice of Bar Date for the
    Filing of Proofs of Claim is attached hereto as Exhibit B.

    [Claim Objections Procedures]{.underline}

13. Pursuant to 11 U.S.C. § 502(b) and Rule 3007 of the Federal Rules of
    Bankruptcy Procedure and except as otherwise ordered by the Court,
    the following procedures shall apply for objections to claims:

14. A hearing date for objections to claims shall be obtained from the
    Court pursuant to Standing Order #1.

15. Debtors[^1] must serve the following documents upon (i) the Claimant
    and Claimant's attorney, if known, and upon (ii) all parties on the
    Master Service List:

    1.  Notice of Hearing on Objection to Claim and Deadline to File and
        Serve Response to Objection to Claim;

    2.  Objection to Claim accompanied by a copy of the proof of claim
        (supporting documentation need not be included);

    3.  Proposed Agreed Order, if applicable;

Debtors may elect to enclose a self‑addressed, stamped return-envelope
with the proposed order mailed to Claimant or Claimant's counsel.

16. Objections to claims may be included in a single "omnibus" objection
    as set forth in Federal Rules of Bankruptcy Procedure 3007(d) and
    (e). Consistent with the Order of Joint Administration in these
    cases, the Objections to Claims are to be numbered sequentially and
    maintained by the Clerk in a single Claims Objection File without
    regard to the particular estate against which the subject claim is
    asserted.

17. The basic format of the Notice of Hearing and Objection to Claim is
    attached hereto as Exhibit C.

18. Debtors will be responsible for maintaining and distributing
    (monthly or upon earlier request) a Master Objections to Claims
    Calendar which shall set forth the hearing date and time, debtor
    company name, debtor case number, claimant's name, claim number,
    claim amount, claim classification and claim objection number, and
    shall indicate if any response has been received from claimant.
    Debtors shall serve the Master Objections Calendar upon all parties
    on the Master Service List.

19. The basic format of the Objections to Claims Calendar is attached
    hereto as Exhibit D.

20. If a Claimant agrees with the objection, the Claimant shall sign the
    Agreed Order enclosed with the Notice of Hearing and Objection to
    Claim, and return it to the Debtors (or objecting party) in the
    envelope provided.

21. If Claimant disagrees with the objection, Claimant shall file and
    serve a written response to the objection with the Claimant's name,
    address, telephone number (including area code), the Claim Objection
    Number, the Claim Number, the Debtor name, and a factual and legal
    statement detailing the basis upon which Claimant disagrees with the
    objection. A corporation must be represented by an attorney in all
    legal matters in these proceedings.

22. Claimant's response shall be filed not later than the date set out
    on the Objection and in accordance with Standing Order #1. All
    responses are to be filed with:

    a.  Clerk, United States Bankruptcy Court

        Thomas F. Eagleton U.S. Courthouse

        111 South Tenth Street, 4th Floor

        St. Lou is, MO 63102\
        **[and]{.underline}**

        Served electronically, by mail, or by hand‑delivery to:

    b.  \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

        Counsel for Debtors

        Address

    c.  Counsel for the Objector (if applicable)

23. If Claimant does not return the Agreed Order or file a written
    response, the Debtors (or the objector) may ask this Court to enter
    an order sustaining their Objection. The Court may do so, in its
    discretion, without further notice or hearing.

24. Debtors shall establish, in the first instance, the appropriate
    category of objections to be processed.

25. Debtor shall serve the Notice of Hearing, Objection to Claim, Agreed
    Order and return envelope upon the entities listed in paragraph 15
    above by United States Mail (first class), not less than 30 days
    prior to a scheduled hearing date.

26. Claimant's response to the Objection shall be filed and served upon
    the entities listed in paragraph 22 above not less than 14 days
    prior to the scheduled hearing date.

27. Debtors shall be responsible for submitting all proposed default
    orders and all proposed orders adjudicating claims.

    [11 U.S.C. § 502(c) Estimation Procedures]{.underline}

28. \(a\) Section 502(c) of the Bankruptcy Code requires that certain
    claims and rights to payment are to be estimated for the purpose of
    allowance. This Section is intended to require that all claims
    against a debtor be converted into dollar amounts. [H.R. Rep.
    No. 595, 95th Cong., 1st Sess. 354 (1977) Rep. 989, 95th Cong., 2d
    Sess. 65 (1978)]{.underline}. In this process, the Court is to
    reasonably estimate the probable value of the claim or right to
    interest. [In the Matter of Baldwin‑United Corporation]{.underline},
    55 B.R. 885, 898 (Bankr. SD Ohio, 1985). The Court is to use
    whatever method is best suited to the particular contingencies at
    issue. Therefore pursuant to Rule 16 of the Federal Rules of Civil
    Procedure, as incorporated by Bankruptcy Rule 7016, and 11 U.S.C.
    § 502(c), procedures set out herein shall apply for estimation of
    claims and any right to payment asserted against the estates of the
    Debtors.[^2] A corporation must be represented by an attorney in all
    legal matters in these proceedings.

    \(b\) A request for estimation of a claim or right to payment is a
    contested matter which is subject to the provisions of Bankruptcy
    Rule 9014.

    \(c\) A motion for estimation of a claim or right to payment is to
    be prosecuted separately, and may not be joined with an objection to
    a claim or right to payment.

29. For the purpose of allowance in these cases under Section 502(c),
    the estimation proceedings will finally adjudicate, determine and
    allow the Debtors' liability for, and the amount of, any claim or
    right to payment subject to an estimation proceeding.

    [Section 502(c) Pre‑Trial Procedures]{.underline}

    [Stipulation]{.underline}

30. The Claimant and Movants shall meet and identify facts and issues
    which are agreed upon and which are disputed.

31. Identified facts and issues shall be compiled into lists which shall
    be filed with the Court at least 20 days prior to trial.

32. Each party shall simultaneously file with the Court its memorandum
    in support of the party's position. The memorandum shall not exceed
    ten pages (including exhibits and the list). All lists and memoranda
    shall be filed with the Court at least 20 days prior to trial.

    [Discovery]{.underline}

33. The parties shall be permitted to utilize full discovery procedures
    pursuant to Rules 27‑37 of the Federal Rules of Civil Procedure,
    except that the total number of interrogatories propounded to each
    party shall be limited to 20 pursuant to the United States District
    Court Rules for the Eastern District of Missouri.

34. At least 15 days prior to trial, the parties shall file with the
    Court a list of witnesses to be called to testify at the trial. All
    persons identified as witnesses shall attend the trial regardless of
    whether he or she is called to testify by the offering party.

35. Except for good cause shown, no party will be permitted to call any
    witness not listed in compliance with this Order.

36. At least 15 days prior to trial, all parties shall file with the
    Court and serve on opposing counsel their proposed findings of fact
    and proposed conclusions of law.

37. At least 10 days prior to trial, each party shall file with the
    Court and serve upon opposing counsel a trial brief, not to exceed
    20 pages.

38. Any objections to discovery (e.g. interrogatories, requests, etc.)
    shall be made within ten business days of receipt of such discovery
    requests and parties must be available for expedited hearings to
    resolve such objections.

    [Section 502(c) Trial Procedures]{.underline}[^3]

    [Trial Structure]{.underline}

39. The trial date for the estimation of claims shall be set pursuant to
    Standing Order #1, except that whenever possible, the date is to be
    agreed upon by the parties directly involved.

40. Claimant shall have a total of three hours to present its case to
    the Court. The Objectors (collectively) shall have a total of three
    hours to present their case to the Court.

41. The oral presentation shall be organized in the manner of a typical
    trial:

    a.  Each party shall make an opening statement and then present the
        party's respective case‑in‑chief in accordance with this order
        and the Federal Rules of Civil Procedure and the Local Rules of
        the United States District Court for the Eastern District of
        Missouri.

    b.  Attorneys may identify available witnesses, comment on any
        evidence and quote directly from interrogatories, requests for
        admissions, documentary evidence, sworn statements of available
        witnesses and depositions (i) of witnesses who are otherwise not
        available, or, (ii) of witnesses as may be otherwise agreed to
        by the parties. These statements will hereinafter be referred to
        as "Attorney Presentation." However, witnesses' testimony or
        documentary evidence may not be referred to unless the reference
        is based upon one of the products of the various discovery
        procedures or if agreed to by the parties, or if ordered by the
        Court upon request, or upon a written sworn statement of the
        witnesses if such witness is in the Courtroom.

    c.  Each party may present testimony through witnesses. Each party
        may cross‑examine witnesses who have testified in Court for an
        opposing party or whose testimony or sworn statement has been
        referred to in the opposing party's Attorney Presentation as set
        out above. The time elapsed during cross‑examination shall be
        counted against the 3 hours of the cross‑examining party.

    d.  Subject to appropriate objections, evidence presented or
        described during the Attorney Presentations shall be admissible
        if it is consistent with this order and with the provisions of
        Rules 402 and 401 of the Federal Rules of Evidence. Evidence may
        be excluded if it is determined to be within the provisions of
        Rule 403 of the Federal Rules of Evidence. The parties to a
        particular proceeding may, and are encouraged to agree to other
        procedures which will expedite the admission of evidence in the
        spirit of the abbreviated determination directed by
        Section 502(c).

42. The parties are free to divide their allotted time among the above
    segments as they see fit, but in no event shall the total time
    allotted to each party exceed three hours.

43. Each party will have 15 minutes additional time within which to make
    any concluding remarks.

44. Each party must be represented at trial by an individual with full
    settlement authority and a thorough knowledge of the case. This
    individual must be present throughout the trial. This requirement
    can be waived only by separate order of the Court and upon a showing
    of extraordinary circumstances.

45. Objectors and Movants shall number their trial exhibits with Arabic
    numbers. Claimants shall number their exhibits with letters. Joint
    exhibits shall be marked in Roman numerals. The parties shall
    exchange copies of their trial binders and shall provide the Court
    with three copies of each set at least five days before trial.

46. All exhibits shall be organized in three ring binders and in the
    following manner:

    a.  The evidence corresponding to each disputed fact shall be
        identified by the Roman numeral for that disputed fact.

    b.  Each binder shall contain an index listing the evidence therein
        and listing the proposed findings of fact and conclusions of law
        which each exhibit supports.

    c.  Each binder shall contain a brief statement, not to exceed five
        pages, summarizing the evidence therein.

    d.  Claimant's binders shall be under blue cover.

    e.  Objectors' binders shall be under black cover.

47. Any pleading submitted shall bear the caption as set forth in the
    notice of the estimation trial.

    [Reservation of Court Authority for Claim Process]{.underline}

48. This entire Order is in the best interests of Debtors, their
    creditors and these estates and presents no prejudice to any party's
    rights or interests. This Order shall continue in effect until
    modified by further order of the Court, [sua]{.underline}
    [sponte]{.underline} or upon motion by a party in interest. The
    Court reserves the right to order, [sua]{.underline}
    [sponte]{.underline} or upon motion by a party in

interest, specific supplemental procedures, modification of these
procedures or other relief for particular claims.

DATED: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

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

UNITED STATES BANKRUPTCY JUDGE

**[EXHIBIT A]{.underline}**

**\[Proof of Claim Form\]**

**[EXHIBIT B]{.underline}**

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF MISSOURI

EASTERN DIVISION

IN THE MATTER OF: ) In Proceedings Under Chapter 11

)

DEBTOR NAME, ) Case No. 01-12345-XXX

)

Debtors. )

) Honorable \_\_\_\_\_\_\_\_\_\_\_\_

) United States Bankruptcy Judge

**[NOTICE OF BAR DATE FOR THE FILING OF PROOFS OF CLAIM]{.underline}**

**\_\_\_\_\_\_\_\_\_\_\_\_\_\[DATE\]**

TO: ALL PERSONS ASSERTING A CLAIM AGAINST ANY OF THE ABOVE ENTITIES:

PLEASE TAKE NOTICE, that on \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, the United
States Bankruptcy Court of the Eastern District of Missouri entered
[Standing Order #3 Setting Claims Bar Date, Establishing Claims
Processing and Objection Procedures, and Establishing Claims Estimation
Procedures Pursuant to 11 U.S.C. §502]{.underline}, regarding the
above‑named Debtors (the "Debtors"). Standing Order #3 requires all
persons and entities, including without limitation, individuals,
partnerships, corporations, estates, trusts and governmental units,
EXCEPT THOSE PERSONS AND ENTITIES DESCRIBED IN PARAGRAPH 8 BELOW, who
assert a claim against any of the Debtors which arose on or before
\_\_\_\_\_\_\[the petition date\], to file a proof of claim **on or
before \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_** (the "Bar Date").

1\. **A copy of the Proof of Claim Form which should be utilized in
these proceedings is enclosed with this Notice.**

2\. Proofs of Claim must be filed with an original [PLUS]{.underline}
one copy of each proof of claim **on or before \_\_\_\_\_\_\_\_\_\_\_.**
All proofs of claim shall be mailed to: \[IF USING A P.O. BOX\]

\_\_\_\_\_\_\_\_\_\_\_\_\_\_ (Debtor name) Claims\
Clerk, United States Bankruptcy Court\
P.O. Box \_\_\_\_\
St. Louis, Missouri 63101

Claims may be filed in person at the Office of the Clerk of Court, 111
S. Tenth Street, Fourth

Floor, St. Louis, Missouri, 63102.

3\. If a creditor requests an acknowledgment copy of the proof of claim,
an additional copy of the proof of claim along with a self‑addressed,
postage prepaid return envelope shall be submitted.

4\. Each claim must specifically state the name and case number of the
Debtor against whom such claim is asserted. If claims are to be asserted
against more than one of the Debtors, a [separate]{.underline},
[original]{.underline} of each proof of claim must be filed in each case
in which a claim is asserted. Multiple Debtor Claims may
[not]{.underline} be filed in a single proof of claim.

5\. Claims in foreign currency must state the amounts claimed in such
foreign currency and must also convert each such amount to United States
Dollars as of \_\_\_\_\_\_\_\_\_\_\_\_\_, the petition date.

**6. If you are required to file a proof of claim and fail to do so, you
will be barred from voting upon, or receiving distribution under any
plan or plans of reorganization of the Debtors, and will be barred from
asserting any such claim or claims against any of the Debtors or their
successors or assigns.**

7\. THE FOLLOWING CREDITORS NEED [NOT]{.underline} FILE PROOFS OF CLAIM
AT THIS TIME:

A. Any creditor whose claim is listed in the Schedules of Assets and
Liabilities of the Debtors as filed on \_\_\_\_\_\_\_\_\_\_\_\_, or
expected to be filed on \_\_\_\_\_\_\_\_\_\_\_\_\_\_ (or any amendments
to such Schedules), if the claim is not listed as "contingent,"
"unliquidated" or "disputed" and if the creditor does not dispute the
classification and scheduled amount of its claim;

B. Any creditor who has filed a proof of claim and who does not seek to
change the claim as filed;

C. Any creditor whose claim is allowable under section 507(a)(1) of the
Bankruptcy Code as an expense of administration of the Debtors'
chapter 11 cases. Holders of delinquent post‑petition claims, if any,
against the Debtors should file an appropriate application with the
Court;

D. Any creditor whose claim has been paid or otherwise satisfied
pursuant to authorization of the Bankruptcy Court;

E. Any creditor whose claim arises under the Debtor‑in‑Possession
Financing Agreement and Facility;

F. Any creditor whose claim is a claim by any one of the Debtors or any
affiliate of the Debtors against another Debtor, as reflected on the
Schedules;

G. Any creditor whose claim has been allowed or disallowed by order of
this Court.

H. Any environmental claims of any governmental unit that relate to
properties currently owned by any of the Debtors.

I. Claims of any bondholder for amounts outstanding under a particular
bond need not be filed separately by the bondholder. The Indenture
Trustee for each bond issue is authorized to file a proof of claim with
respect to all amounts outstanding under the bonds of that issue.

J. Any creditor whose claim arises out of the rejection by the Debtor of
an executory contract or unexpired lease or a judgment entered against
the creditor pursuant to an action under Chapter 5 of the Bankruptcy
Code must file its claim by the later of (i) \_\_\_\_\_\_\_\_the claims
bar date; or (ii) within 30 days after entry of an order approving the
rejection.

K. Any creditor who has already filed a proof of claim need not file a
duplicate proof of claim.

8\. In the event any Debtor amends its Schedules of Assets and
Liabilities subsequent to the date hereof to reduce the amount of a
scheduled claim or to reclassify the claim as "contingent,"
"unliquidated" or "disputed," the Debtor shall give written notice of
such amendment to the holder of the claim affected thereby, along with
notice that the holder has 30 days from the date of the notice to file
or amend a proof of claim, if necessary, or be forever barred from so
doing.

ALL PERSONS AND ENTITIES OTHER THAN THOSE DESCRIBED IN PARAGRAPH 8 ABOVE
MUST FILE A PROOF OF CLAIM ON OR BEFORE THE BAR DATE. OTHERWISE THEY
SHALL BE BARRED FROM VOTING UPON OR RECEIVING DISTRIBUTION UNDER ANY
PLAN OR PLANS OF REORGANIZATION IN THESE CASES. THE PROVISIONS OF THE
BAR ORDER APPLY TO ALL CLAIMS OF WHATEVER CHARACTER OR NATURE AGAINST
EACH DEBTOR OR ITS PROPERTY, WHETHER SECURED OR UNSECURED, LIQUIDATED OR
UNLIQUIDATED, FIXED OR CONTINGENT.

9\. Acts or omissions of the Debtors arising or occurring prior to
filing their Chapter 11 petitions, including but not limited to goods or
services provided by the Debtors, may give rise to claims against the
Debtors notwithstanding the fact that such claims (or the injuries on
which they are based) may be contingent or may not have occurred,
matured or become fixed or liquidated prior to the Bar Date. Therefore,
any creditor having such a claim or potential claim against the Debtors,
no matter how remote or contingent, unless excluded pursuant to
Paragraph 8 above, must file a proof of claim on or before the Bar Date.

10\. The Debtors have reserved the right to dispute, or to assert
offsets or defenses to, any Claim reflected on the schedules as to
amount, liability, classification or otherwise and to subsequently
designate any Claim as disputed, contingent, unliquidated or
undetermined as to amount; provided however, that if the Debtors amend
their schedules to designate a Claim as disputed, contingent,
unliquidated or undetermined as to amount, or to change the amount of a
Claim reflected thereon, then, the Debtors shall provide notice of the
amendment to the affected Creditor and notice that the Creditor has 30
days from the date of the to file a proof of claim, if necessary, or be
forever barred from doing so. Nothing set forth herein shall be deemed
to preclude the Debtors from objecting to any Claim, whether scheduled
or filed, on any grounds.

11\. The Debtors' Schedules of Assets and Liabilities may be examined
and inspected by interested parties in the Office of the Clerk of the
United States Bankruptcy Court, Thomas F. Eagleton U.S. Courthouse, 111
South Tenth Street, Fourth Floor, St. Louis, Missouri 63102. Copies of
Debtors' Schedules of Assets and Liabilities may be obtained from
Bankruptcy Services, Inc., Thomas F. Eagleton U.S. Courthouse, 111 South
Tenth Street, Fourth Floor, St. Louis, Missouri 63102, 314) 244-4940 or
may be viewed electronically through the court's

PACER system. Information regarding access to case information through
PACER-NET is available on the court's web site at
http:\\\\www.moeb.uscourts.gov.

BY ORDER OF THE COURT

**[EXHIBIT C]{.underline}**

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF MISSOURI

EASTERN DIVISION

IN THE MATTER OF: ) IN PROCEEDINGS UNDER CHAPTER 11

)

) CASE NUMBER 01-12345-XXX

)

Debtors. ) HONORABLE ) UNITED STATES BANKRUPTCY JUDGE

)

[RE:]{.underline} ) CASE NUMBER 01-12345-XXX

)

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ )

Claimant. ) HEARING DATE: \_\_\_\_\_\_\_\_\_\_\_, 2002

) TIME: \_\_\_\_\_\_\_\_.

) PLACE: \_\_\_\_ FLOOR

) 111 SOUTH TENTH STREET

) ST. LOUIS, MO 63102

)

) **LAST DAY TO RESPOND TO**

) **OBJECTION: \_\_‑\_\_‑\_\_**

  ------------------ ------------------ ------------------- ------------------
  [Obj.              [Claim             [Debtor             [Case
  No.]{.underline}   No.]{.underline}   Name]{.underline}   No.]{.underline}

                                                            
  ------------------ ------------------ ------------------- ------------------

**NOTICE OF HEARING ON DEBTOR'S**

**OBJECTION TO CLAIM AND DEADLINE TO FILE AND**

**[SERVE RESPONSE TO OBJECTION CLAIM]{.underline}**

**THIS IS AN IMPORTANT LEGAL NOTICE WHICH YOU SHOULD REVIEW IMMEDIATELY
AND SHOW TO YOUR ATTORNEY.**

The Debtor has filed an objection to your claim in the above-captioned
jointly administered Bankruptcy Cases. A copy of that objection is
enclosed with this Notice. **THE COURT WILL HEAR THAT OBJECTION AT
\_\_\_\_ A.M. ON \_\_\_\_\_\_\_\_\_\_\_\_, 2002 ON THE \_\_\_\_\_ FLOOR,
111 SOUTH TENTH STREET, ST. LOUIS, MISSOURI 63102.**

If you agree with the Debtor's objection, then please sign the enclosed
Agreed Upon Order Withdrawing Claim or Sustaining Debtor's Objection to
Claim and return it in the self‑addressed, stamped envelope.

If you disagree with the enclosed objection to your claim, **you must
file and serve a written response** to the objection with the following
information:

> Your name;
>
> Your address;
>
> Your telephone number (including your area code);
>
> The Claim Objection Number;
>
> The Claim Number;
>
> The name of the Debtor in whose case your claim was scheduled; and
>
> A detailed statement about why you disagree with the Debtor's
> objection.

**You must file your response to the Debtor's objection no later than
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_, 2002, electronically, by mailing, or
by hand delivering your response to:**

> 1\. Clerk, United States Bankruptcy Court
>
> Fourth Floor
>
> 111 South Tenth Street
>
> St. Louis, MO 63102
>
> 2\. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ 1 copy
>
> Counsel for Debtors
>
> Address
>
> 3\. COUNSEL FOR THE OBJECTOR (if applicable) 1 copy

If you file a response to the Debtor's Objection, you or your attorney
must attend the hearing on the Debtor's objection on the date and time
and at the place indicated in this Notice.

**IF YOU FAIL TO FOLLOW THE INSTRUCTIONS IN THIS NOTICE, THE DEBTOR WILL
ASK THE BANKRUPTCY COURT TO ENTER AN ORDER SUSTAINING ITS OBJECTION(S)
TO YOUR CLAIM(S) AND THE COURT MAY DO SO WITHOUT FURTHER NOTICE AND
HEARING.**

Dated: \_\_\_\_\_\_\_\_\_\_\_\_\_\_, 2002

> Counsel for Debtor
>
> \[Signature Block\]
>
> Attorneys for Debtors and Debtors‑in‑Possession

UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF MISSOURI

EASTERN DIVISION

IN THE MATTER OF: ) IN PROCEEDINGS UNDER CHAPTER 11

)

) CASE NUMBER 01-12345-XXX

)

Debtors. ) HONORABLE ) UNITED STATES BANKRUPTCY JUDGE

)

[RE:]{.underline} ) CASE NUMBER 01-12345-XXX

)

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ )

Claimant. ) HEARING DATE: \_\_\_\_\_\_\_\_\_\_\_, 2002

) TIME: 10:00 a.m.

) PLACE: \_\_\_\_ FLOOR

) 111 SOUTH TENTH STREET

) ST. LOUIS, MO 63102

)

) **LAST DAY TO RESPOND TO**

) **OBJECTION: \_\_‑\_\_‑\_\_**

  ------------------ ------------------ ------------------- ------------------
  [Obj.              [Claim             [Debtor             [Case
  No.]{.underline}   No.]{.underline}   Name]{.underline}   No.]{.underline}

                                                            
  ------------------ ------------------ ------------------- ------------------

OBJECTION TO CLAIM NUMBER \_\_\_

[FILED IN \[Debtor's Name\]]{.underline}

1\. This Court has jurisdiction over this objection pursuant to 28
U.S.C. §1334, and this is a core proceeding pursuant to 28 U.S.C.
§157(b)(2)(B).

2\. The Debtors are chapter 11 debtors in possession whose cases are
jointly administered.

3\. Debtors, pursuant to 11 U.S.C. §502(b) and Rule 3005 of the Rules of
Bankruptcy Procedure, object to the claim identified at the top of this
page for the reasons set forth:

> 1\. Claim No. \_\_ is a duplicate of claim No. \_\_.

WHEREFORE, Debtors pray that the Court enter an order sustaining their
objection to the claim identified above and for such other relief as may
be just and proper.

Dated: \_\_\_\_\_\_\_\_\_\_\_\_\_\_, 2002

> Counsel for Debtor
>
> \[Signature Block\]
>
> Attorneys for Debtors and Debtors‑in‑Possession

**[EXHIBIT D]{.underline}**

As of \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

[OBJECTIONS TO CLAIMS CALENDAR]{.underline}

Hearing Date: \_\_\_\_\_\_\_\_\_\_\_, 2002

Hearing Time: \_\_\_\_\_\_\_

  ------------ ----------- ----------- ----------- --------- ---------- -----------
  Debtor Name  Debtor Case Claim       Claimant    Claim No. Response   Consent to
               No.         Objection   Name and    And Claim Received   Objection
                           Number      Claim Amt.  Class                
                                                   (S,U,P)              

                                                                        
  ------------ ----------- ----------- ----------- --------- ---------- -----------

[^1]: This provision is without prejudice to the rights of any party in
    interest to object to a claim. The objecting party shall coordinate
    with the Debtors as to the filing of that objection, after which the
    Debtors shall continue to be responsible for paragraphs 16‑18 with
    respect to the claim.

[^2]: Nothing herein shall affect or alter the requirements of § 502(c)
    that must be satisfied prior to commencement of the estimation
    proceedings set forth herein.

[^3]: Except as otherwise set forth below, the Federal Rules of Civil
    Procedure and the Rules of the United States District Court for the
    Eastern District of Missouri Local Rules shall apply at the
    estimation hearing.