KE 39805941 

Edward O. Sassower, P.C. (pro hac vice admission pending) Michael A. Condyles (VA 27807) 

Joshua A. Sussberg, P.C. Peter J. Barrett (VA 46179) 

Brian E. Schartz (pro hac vice admission pending) Jeremy S. Williams (VA 77469) 

KIRKLAND & ELLIS LLP KUTAK ROCK LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP Bank of America Center 

601 Lexington Avenue 1111 East Main Street, Suite 800 

New York, New York 10022 Richmond, Virginia 23219 

Telephone: (212) 446-4800 Telephone: (804) 644-1700 

Facsimile: (212) 446-4900 Facsimile: (804) 783-6192 

 

- and - 

James H.M. Sprayregen, P.C. 

Justin R. Bernbrock (pro hac vice admission pending) 

Benjamin M. Rhode (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP 

300 North LaSalle 

Chicago, Illinois 60654 

Telephone: (312) 862-2000 

Facsimile: (312) 862-2200 

Proposed Co-Counsel to the Debtors 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

 ) 

In re: ) Chapter 11 

 ) 

PENN VIRGINIA CORPORATION, et al.,

1

 ) Case No. 16-32395 (___) 

 ) 

 Debtors. ) (Joint Administration Requested) 

 ) 

DEBTORS’ MOTION FOR ENTRY OF AN ORDER (I) EXTENDING TIME TO 

FILE SCHEDULES AND STATEMENTS OF FINANCIAL AFFAIRS, (II) AUTHORIZING 

THE DEBTORS TO FILE A CONSOLIDATED LIST OF CREDITORS IN LIEU OF 

SUBMITTING A MAILING MATRIX FOR EACH DEBTOR, (III) AUTHORIZING THE 

DEBTORS TO FILE A CONSOLIDATED LIST OF THE DEBTORS’ 50 LARGEST 

UNSECURED CREDITORS, AND (IV) GRANTING RELATED RELIEF 

Penn Virginia Corporation and its debtor affiliates, as debtors and debtors in possession 

 

1

 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, include: Penn Virginia Corporation (4320); Penn Virginia Holding Corp. (7384); Penn Virginia MC 

Corporation (0458); Penn Virginia MC Energy L.L.C. (0462); Penn Virginia MC Operating Company L.L.C. 

(0466); Penn Virginia Oil & Gas Corporation (7929); Penn Virginia Oil & Gas GP LLC (3686); Penn Virginia 

Oil & Gas LP LLC (8109); Penn Virginia Oil & Gas, L.P. (9487). The location of the Debtors’ service address 

is: Four Radnor Corporate Center, Suite 200, 100 Matsonford Road, Radnor, Pennsylvania 19087. 

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in the above-captioned chapter 11 cases (collectively, the “Debtors”),2 respectfully state the 

following in support of this motion: 

Relief Requested 

1. The Debtors seek entry of an order (the “Order”), substantially in the form 

attached hereto as Exhibit A: (a) extending the deadline by which the Debtors must file their 

schedules of assets and liabilities, schedules of current income and expenditures, schedules of 

executory contracts and unexpired leases, and statements of financial affairs 

(collectively, the “Schedules and Statements”) by ten (10) days, for a total of twenty-four (24) 

days from the Petition Date, without prejudice to the Debtors’ ability to request additional 

extensions for cause shown; (b) authorizing the Debtors to file a consolidated list of creditors in 

lieu of submitting a separate mailing matrix for each Debtor; (c) authorizing the Debtors to file a 

consolidated list of the Debtors’ 50 largest unsecured creditors, and (d) granting related relief. 

Jurisdiction and Venue 

2. The United States Bankruptcy Court for the Eastern District of Virginia 

(the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334. This 

matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). 

3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

4. The bases for the relief requested herein are sections 105(a) and 521 of title 11 of 

the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Rules 1007(c) and 

9006(b) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and 

 

2

 A detailed description of the Debtors and their businesses, and the facts and circumstances supporting this 

motion and the Debtors’ chapter 11 cases, are set forth in greater detail in the Declaration of R. Seth Bullock, 

Chief Restructuring Officer of Penn Virginia Corporation, in Support of Chapter 11 Petitions and First Day 

Motions (the “First Day Declaration”), filed contemporaneously with the Debtors’ voluntary petitions for relief 

filed under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”), on May 12, 2016 

(the “Petition Date”). 

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Rules 1007-1 and 9013-1 of the Local Rules of the United States Bankruptcy Court for the 

Eastern District of Virginia (the “Local Bankruptcy Rules”). 

Basis for Relief 

I. Cause Exists for Extending the Deadline by Which the Debtors Must File the 

 Schedules and Statements. 

5. Pursuant to section 521 of the Bankruptcy Code and Bankruptcy Rule 1007(c), 

the Debtors would be required to file the Schedules and Statements within 14 days of the Petition 

Date. Pursuant to Bankruptcy Rule 1007(a)(5) and (c), the Court has authority to extend the time 

required for filing the Schedules and Statements “for cause.” Further, Local Bankruptcy Rule 

1007-1(C) permits the Court to enter an order extending the Debtors’ time to file their lists, 

schedules, and statements under the following circumstances: 

If no objection to the motion to extend the time for filing is timely 

filed with the Court, the Clerk shall enter an order extending time 

for filing to not later than the seventh day prior to the scheduled 

meeting of creditors. If the lists, schedules, statements, and other 

documents are not filed by said date, the Clerk shall enter an order 

dismissing the case. 

6. Here, good and sufficient cause for granting an extension of time to file the 

Schedules and Statements exists. To prepare the Schedules and Statements, the Debtors must 

compile information from books, records, and documents relating to the claims of hundreds of 

creditors, as well as the Debtors’ many assets and contracts. This information is voluminous and 

located in numerous places throughout the Debtors’ organization. Collecting the necessary 

information requires an enormous expenditure of time and effort on the part of the Debtors, their 

employees, and their professional advisors in the near term—when these resources would be best 

used to stabilize the Debtors’ business operations. 

7. Although the Debtors, with the assistance of their professional advisors, are 

working diligently and expeditiously to prepare the Schedules and Statements, the Debtors’ 

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KE 39805941 

resources are strained. Considering the amount of work entailed in completing the Schedules 

and Statements combined with the competing demands on the Debtors’ employees and 

professionals to assist in efforts to stabilize business operations during the initial postpetition 

period, the Debtors likely will not be able to properly and accurately complete the Schedules and 

Statements within the required time period.

8. Prior to the filing of these chapter 11 cases, the Debtors focused on preparing for 

the chapter 11 filing, preparing the business to transition into chapter 11, and negotiating with 

the Debtors’ significant creditor constituencies. Such efforts made it difficult for the Debtors to 

prepare the Schedules and Statements. Although the Debtors have commenced the process that 

will enable them to prepare and finalize what will be voluminous Schedules and Statements, the 

Debtors anticipate that they may require at least ten (10) days after the Petition Date to complete 

the Schedules and Statements. The Debtors therefore request that the Court extend the initial 

14-day period for an additional ten (10) days, without prejudice to the Debtors’ right to request 

further extensions, for cause shown. 

9. The Debtors submit that the extensive amount of information that must be 

assembled and compiled, the multiple places where the information is located, and the hundreds 

of employee and professional hours required to complete the Schedules and Statements 

constitute good and sufficient cause for granting the requested extension of time. 

10. Courts in this district have regularly granted similar relief to the relief requested 

herein. See, e.g., In re Alpha Natural Res., Inc., No. 15-33896 (KRH) (Bankr. E.D. Va. Aug. 5, 

2015) (granting 60-day extension); In re Patriot Coal Corp., No. 15-32450 (KLP) (Bankr. E.D. 

Va. May 14, 2015) (granting 45-day extension); In re James River Coal Co., No. 14-31848 

(KRH) (Bankr. E.D. Va. Apr. 9, 2014) (granting 60-day extension); In re AMF Bowling 

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Worldwide, Inc., No. 12-36495 (KRH) (Bankr. E.D. Va. Nov. 14, 2012) (granting 45-day 

extension); In re MMR Holdings, Inc., No. 10-32658 (DOT) (Bankr. E.D. Va. Apr. 16, 2010) 

(granting 30-day extension).3 

II. Filing a Consolidated List of Creditors in Lieu of Submitting a Separate Creditor 

 Mailing Matrix for Each Debtor is Warranted. 

11. Unless a debtor’s schedules of assets and liabilities are filed simultaneously with a 

chapter 11 petition, section 521(a) of the Bankruptcy Code, Bankruptcy Rule 1007(a)(1), and 

Local Bankruptcy Rule 1007-1(H)(1) require a debtor to file a list containing the name and 

address of each creditor. Specifically, Local Bankruptcy Rule 1007-1(H)(1) further states that 

the debtors must submit this list of creditors either on a diskette in a computer readable format 

specified by the Office of the Clerk of the Court (the “Clerk”) or via the Electronic Case Files 

System. Exhibit 5 to the Local Bankruptcy Rules (“Exhibit 5”) specifies the format in which 

debtors must submit mailing matrices. 

12. There are thousands of creditors and parties in interest in these chapter 11 cases. 

The Debtors maintain lists of the names and addresses of all such entities on various computer 

software programs that permit the Debtors, or a third-party service provider on the Debtors’ 

behalf, to print mailing labels for each such entity. Additionally, the Debtors have sought to 

retain Epiq Bankruptcy Solutions, LLC (“Epiq”) as the Debtors’ notice and claims agent in these 

chapter 11 cases.4 Because the Debtors and Epiq will relieve the Clerk of the burden of sending 

notices to the Debtors’ numerous creditors and parties in interest, the Debtors submit that the 

 

3 Because of the voluminous nature of the orders cited herein, such orders have not been attached to this motion. 

Copies of these orders are available upon request of the Debtors’ proposed counsel. 

4

 See Debtors’ Application for (I) Appointment of Epiq Bankruptcy Solutions, LLC as Claims and Noticing Agent 

and (II) Granting Related Relief, filed contemporaneously herewith. 

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KE 39805941 

Clerk does not need the information provided in a mailing matrix formatted in accordance with 

Local Bankruptcy Rule 1007-1(H)(1) and Exhibit 5. 

13. Compiling the information in the format required by Local Bankruptcy 

Rule 1007-1(H)(1) and Exhibit 5 would create an unnecessary administrative burden for the 

Debtors’ estates. As a result, the Debtors request authority to submit a consolidated list of 

creditors in lieu of the mailing matrices. 

III. Filing a Single Consolidated List of the Debtors’ 50 Largest Unsecured Creditors 

 Creditors is Warranted. 

14. Pursuant to Bankruptcy Rule 1007(d), a debtor must file “a list containing the 

name, address and claim of the creditors holding the 20 largest unsecured claims, excluding 

insiders.” Here, compiling separate top creditor lists for each individual Debtor would consume 

an excessive amount of the Debtors’ time and resources, and filing a consolidated list would 

more appropriately reflect the liabilities against the Debtors’ operations on an enterprise level. 

Accordingly, the Debtors request authority to file a single, consolidated list of their 50 largest 

general unsecured creditors. 

15. Courts in this district have regularly granted similar relief to the relief requested 

herein. See, e.g., In re Alpha Natural Res., Inc., No. 15-33896 (KRH) (Bankr. E.D. Va. Aug. 5, 

2015)In re Patriot Coal Corp., No. 15-32450 (KLP) (Bankr. E.D. Va. May 14, 2015); In re 

James River Coal Co., No. 14-31848 (KRH) (Bankr. E.D. Va. Apr. 9, 2014); In re AMF Bowling 

Worldwide, Inc., No. 12-36495 (KRH) (Bankr. E.D. Va. Nov. 14, 2012); In re MMR Holdings, 

Inc., No. 10-32658 (DOT) (Bankr. E.D. Va. Apr. 16, 2010). 

Waiver of Memorandum of Points and Authorities 

16. The Debtors respectfully request that this Court treat this motion as a written 

memorandum of points and authorities or waive any requirement that this motion be 

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KE 39805941 

accompanied by a written memorandum of points and authorities as described in Local 

Bankruptcy Rule 9013-1(G). 

Notice 

17. The Debtors will provide notice of this motion to: (a) the Office of the United 

States Trustee for the Eastern District of Virginia; (b) the holders of the 50 largest unsecured 

claims against the Debtors (on a consolidated basis); (c) the administrative agent under the 

Debtors’ prepetition secured credit agreement; (d) the indenture trustee under the Debtors’ 

7.25% senior notes due 2019; (e) the indenture trustee under the Debtors’ 8.500% senior notes 

due 2020; (f) counsel to certain holders of the 2019 and 2020 senior notes; (g) counsel to the 

agent under the Debtors’ debtor-in-possession credit facility; (h) co-counsel to the agent under 

the Debtors’ debtor-in-possession credit facility; (i) the United States Attorney’s Office for the 

Eastern District of Virginia and for the states in which the Debtors operate; (j) the Internal 

Revenue Service; (k) the Environmental Protection Agency and similar state environmental 

agencies for states in which the Debtors conduct business; (l) the office of the attorneys general 

for the states in which the Debtors operate; (m) the Securities and Exchange Commission; and 

(n) any party that has requested notice pursuant to Bankruptcy Rule 2002. The Debtors submit 

that, in light of the nature of the relief requested, no other or further notice need be given. 

No Prior Request 

18. No prior request for the relief sought in this motion has been made to this or any 

other court. 

[Remainder of Page Intentionally Left Blank] 

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KE 39805941 

WHEREFORE, the Debtors respectfully request that the Court enter the Order, granting 

the relief requested herein and such other relief as the Court deems appropriate under the 

circumstances. 

Dated: May 12, 2016 

Richmond, Virginia 

 

/s/ Michael A. Condyles

Michael A. Condyles (VA 27807) Edward O. Sassower, P.C. (pro hac vice admission pending)

Peter J. Barrett (VA 46179) Joshua A. Sussberg, P.C. 

Jeremy S. Williams (VA 77469) Brian E. Schartz (pro hac vice admission pending) 

KUTAK ROCK LLP KIRKLAND & ELLIS LLP

Bank of America Center KIRKLAND & ELLIS INTERNATIONAL LLP 

1111 East Main Street, Suite 800 601 Lexington Avenue

Richmond, Virginia 23219 New York, New York 10022 

Telephone: (804) 644-1700 Telephone: (212) 446-4800 

Facsimile: (804) 783-6192 Facsimile: (212) 446-4900 

Michael.Condyles@KutakRock.com edward.sassower@kirkland.com 

Peter.Barrett@KutakRock.com joshua.sussberg@kirkland.com 

Jeremy.Williams@KutakRock.com brian.schartz@kirkland.com 

 

 - and - 

 

 James H.M. Sprayregen, P.C. 

 Justin R. Bernbrock (pro hac vice admission pending) 

 Benjamin M. Rhode (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP

KIRKLAND & ELLIS INTERNATIONAL LLP 

 300 North LaSalle

 Chicago, Illinois 60654 

 Telephone: (312) 862-2000 

 Facsimile: (312) 862-2200 

 james.sprayregen@kirkland.com 

 justin.bernbrock@kirkland.com 

 benjamin.rhode@kirkland.com 

Proposed Co-Counsel to the Debtors and Debtors in Possession 

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EXHIBIT A 

Proposed Order 

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KE 39805941 

Edward O. Sassower, P.C. (pro hac vice admission pending) Michael A. Condyles (VA 27807) 

Joshua A. Sussberg, P.C. Peter J. Barrett (VA 46179) 

Brian E. Schartz (pro hac vice admission pending) Jeremy S. Williams (VA 77469) 

KIRKLAND & ELLIS LLP KUTAK ROCK LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP Bank of America Center 

601 Lexington Avenue 1111 East Main Street, Suite 800 

New York, New York 10022 Richmond, Virginia 23219 

Telephone: (212) 446-4800 Telephone: (804) 644-1700 

Facsimile: (212) 446-4900 Facsimile: (804) 783-6192 

 

- and - 

James H.M. Sprayregen, P.C. 

Justin R. Bernbrock (pro hac vice admission pending) 

Benjamin M. Rhode (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP 

300 North LaSalle 

Chicago, Illinois 60654 

Telephone: (312) 862-2000 

Facsimile: (312) 862-2200 

Proposed Co-Counsel to the Debtors 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

 ) 

In re: ) Chapter 11 

 ) 

PENN VIRGINIA CORPORATION, et al.,

1

 ) Case No. 16-32395 (___) 

 ) 

 Debtors. ) (Joint Administration Requested) 

 ) 

ORDER (I) EXTENDING TIME TO FILE SCHEDULES AND 

STATEMENTS OF FINANCIAL AFFAIRS, (II) AUTHORIZING THE DEBTORS 

TO FILE A CONSOLIDATED LIST OF CREDITORS IN LIEU OF SUBMITTING A 

MAILING MATRIX FOR EACH DEBTOR, (III) AUTHORIZING THE DEBTORS 

TO FILE A CONSOLIDATED LIST OF THE DEBTORS’ 50 LARGEST 

UNSECURED CREDITORS, AND (IV) GRANTING RELATED RELIEF 

Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in 

 

1

 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, include: Penn Virginia Corporation (4320); Penn Virginia Holding Corp. (7384); Penn Virginia MC 

Corporation (0458); Penn Virginia MC Energy L.L.C. (0462); Penn Virginia MC Operating Company L.L.C. 

(0466); Penn Virginia Oil & Gas Corporation (7929); Penn Virginia Oil & Gas GP LLC (3686); Penn Virginia 

Oil & Gas LP LLC (8109); Penn Virginia Oil & Gas, L.P. (9487). The location of the Debtors’ service address 

is: Four Radnor Corporate Center, Suite 200, 100 Matsonford Road, Radnor, Pennsylvania 19087. 

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KE 39805941 

possession (collectively, the “Debtors”) for entry of an order (this “Order”), (a) extending the 

time period to file their Schedules and Statements, (b) authorizing the Debtors to file a 

consolidated list of creditors in lieu of submitting a separate mailing matrix for each Debtor, 

(c) authorizing the Debtors to file a consolidated list of the Debtors’ 50 largest unsecured 

creditors, and (d) granting related relief; all as more fully set forth in the Motion; and upon the 

First Day Declaration; and this Court having jurisdiction over this matter pursuant to 

28 U.S.C. §§ 157 and 1334; and this Court having found that this is a core proceeding pursuant 

to 28 U.S.C. § 157(b)(2); and that this Court may enter a final order consistent with Article III of 

the United States Constitution; and it appearing that venue of this proceeding and the Motion in 

this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that 

the Debtors’ notice of the Motion and opportunity for a hearing on the Motion were appropriate 

under the circumstances and no other notice need be provided; and this Court having reviewed 

the Motion and having heard the statements in support of the relief requested therein at a hearing 

before this Court (the “Hearing”); and this Court having determined that the legal and factual 

bases set forth in the Motion and at the Hearing establish just cause for the relief granted herein; 

and upon all of the proceedings had before this Court; and after due deliberation and sufficient 

cause appearing therefor, it is HEREBY ORDERED THAT: 

1. The Motion is granted as set forth herein. 

2. In accordance with section 521 of the Bankruptcy Code, Bankruptcy 

Rules 1007(c) and 9006(b), and Local Bankruptcy Rule 1007-1, the time by which the Debtors 

shall file their Schedules and Statements is extended by an additional 10 days to a total of 

24 days from the Petition Date, through and including June 6, 2016. 

 

2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion. 

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3. Such extension is without prejudice to the Debtors’ right to request a further 

extension. 

4. The Debtors are authorized to submit a consolidated list of creditors in lieu of 

submitting separate mailing matrices. 

5. The Debtors are authorized to file a consolidated list of their 50 largest unsecured 

creditors in the Debtors’ chapter 11 cases in lieu of each Debtor filing a list of its 20 largest 

unsecured creditors. 

6. The requirement under Local Bankruptcy Rule 9013-1(G) to file a memorandum 

of law in connection with the Motion is waived. 

7. Notice of the Motion as provided therein is good and sufficient notice of such 

Motion and the requirements of the Local Bankruptcy Rules are satisfied by such notice. 

8. The Debtors are authorized to take all actions necessary to effectuate the relief 

granted pursuant to this Order in accordance with the Motion. 

9. This Court retains exclusive jurisdiction with respect to all matters arising from or 

related to the implementation, interpretation, and enforcement of this Order. 

Richmond, Virginia UNITED STATES BANKRUPTCY JUDGE 

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KE 39805941 

WE ASK FOR THIS: 

/s/ Michael A. Condyles 

Michael A. Condyles (VA 27807) 

Peter J. Barrett (VA 46179) 

Jeremy S. Williams (VA 77469) 

KUTAK ROCK LLP 

Bank of America Center 

1111 East Main Street, Suite 800 

Richmond, Virginia 23219 

Telephone: (804) 644-1700 

Facsimile: (804) 783-6192 

- and - 

Edward O. Sassower, P.C. (pro hac vice admission pending) 

Joshua A. Sussberg, P.C. 

Brian E. Schartz (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP 

601 Lexington Avenue

New York, New York 10022 

Telephone: (212) 446-4800 

Facsimile: (212) 446-4900 

- and - 

James H.M. Sprayregen, P.C. 

Justin R. Bernbrock (pro hac vice admission pending) 

Benjamin M. Rhode (pro hac vice admission pending) 

KIRKLAND & ELLIS LLP 

KIRKLAND & ELLIS INTERNATIONAL LLP 

300 North LaSalle 

Chicago, Illinois 60654 

Telephone: (312) 862-2000 

Facsimile: (312) 862-2200 

Proposed Co-Counsel to the Debtors 

CERTIFICATION OF ENDORSEMENT 

UNDER LOCAL BANKRUPTCY RULE 9022-1(C) 

Pursuant to Local Bankruptcy Rule 9022-1(C), I hereby certify that the foregoing proposed order 

has been endorsed by or served upon all necessary parties. 

 /s/ Michael A. Condyles 

 

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