JONES DAY 

North Point 

901 Lakeside Avenue 

Cleveland, Ohio 44114 

Telephone: (216) 586-3939 

Facsimile: (216) 579-0212 

David G. Heiman (pro hac vice pending) 

Carl E. Black (pro hac vice pending) 

Thomas A. Wilson (pro hac vice pending) 

Proposed Attorneys for Debtors 

and Debtors in Possession 

HUNTON & WILLIAMS LLP 

Riverfront Plaza, East Tower 

951 East Byrd Street 

Richmond, Virginia 23219 

Telephone: (804) 788-8200 

Facsimile: (804) 788-8218 

Tyler P. Brown (VSB No. 28072) 

J.R. Smith (VSB No. 41913) 

Henry P. (Toby) Long, III (VSB No. 75134) 

Justin F. Paget (VSB No. 77949) 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

Alpha Natural Resources, Inc., et al., 

 Debtors. 

Chapter 11 

Case No. 15-_____ (___) 

(Joint Administration Requested) 

MOTION OF DEBTORS AND DEBTORS IN POSSESSION, 

PURSUANT TO SECTIONS 342 AND 521(a) OF THE BANKRUPTCY 

CODE, BANKRUPTCY RULES 1007(a), 2002(a) AND 2002(f) 

AND LOCAL BANKRUPTCY RULES 1007-1 AND 2002-1, FOR 

AN ORDER (A) WAIVING THE REQUIREMENT THAT EACH DEBTOR 

SUBMIT A FORMATTED MAILING MATRIX, (B) APPROVING THE 

FORM AND MANNER OF NOTICE OF THE COMMENCEMENT 

OF THE DEBTORS' CHAPTER 11 CASES AND (C) AUTHORIZING 

THE FILING OF A CONSOLIDATED LIST OF TOP 50 UNSECURED CREDITORS

Alpha Natural Resources, Inc. ("ANR") and certain of its direct and indirect 

subsidiaries, as debtors and debtors in possession (collectively, the "Debtors"), respectfully 

represent as follows: 

Background

1. On the date hereof (the "Petition Date"), the Debtors commenced their 

reorganization cases by filing voluntary petitions for relief under chapter 11 of title 11 of the 

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United States Code (the "Bankruptcy Code"). By a motion filed on the Petition Date, the 

Debtors have requested that their chapter 11 cases be consolidated for procedural purposes only 

and administered jointly. The Debtors are authorized to continue to operate their business and 

manage their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the 

Bankruptcy Code. 

2. A comprehensive description of the Debtors' businesses and operations, 

capital structure and the events leading to the commencement of these chapter 11 cases can be 

found in the declarations of (a) Kevin S. Crutchfield, Chief Executive Officer and Chairman of 

the Board of Directors of ANR, and (b) Philip J. Cavatoni, Executive Vice President and Chief 

Financial and Strategy Officer of ANR in support of the Debtors' "first day" pleadings (together, 

the "First Day Declarations"), which were filed contemporaneously herewith and which are 

incorporated by reference. 

Jurisdiction

3. This Court has subject matter jurisdiction to consider this matter pursuant 

to 28 U.S.C. § 1334. This is a core proceeding pursuant to 28 U.S.C. § 157(b). Venue is proper 

before this Court pursuant to 28 U.S.C. §§ 1408 and 1409. 

Relief Requested

4. Pursuant to sections 342 and 521(a) of the Bankruptcy Code, 

Rules 2002(a) and (f) of the Federal Rules of Bankruptcy Procedure (the "Bankruptcy Rules") 

and Rules 1007-1 and 2002-1 of the Local Bankruptcy Rules for the United States Bankruptcy 

Court for the Eastern District of Virginia (the "Local Bankruptcy Rules"), the Debtors hereby 

seek the entry of an order substantially in the form attached hereto as Exhibit B: (a) waiving the 

requirement that each Debtor submit a formatted mailing matrix, pursuant to section 521(a)(1) of 

the Bankruptcy Code, Bankruptcy Rule 1007(a)(1) and Local Bankruptcy Rule 1007-1(H)(1) 

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(together, the "Notice Rules"); (b) approving, pursuant to Local Bankruptcy Rule 2002-1(A), the 

form and manner of notice (the "Commencement Notice") of the commencement of these 

chapter 11 cases and of the meeting of creditors to be held pursuant to section 341 of the 

Bankruptcy Code (the "Section 341 Meeting"), substantially in the form attached hereto as 

Exhibit A; and (c) authorizing the Debtors to file a single consolidated list of the 50 largest 

unsecured creditors in these cases in lieu of filing over 100 separate lists of the 20 largest 

unsecured creditors of each Debtor pursuant to Bankruptcy Rule 1007(d). 

Basis for the Relief Requested

Request for Waiver of the Notice Rules 

5. Pursuant to the Notice Rules, a chapter 11 petition must be accompanied 

by a list of creditors containing the name and address of each entity included or to be included on 

a debtor's schedules of liabilities (the "Creditor Matrix").1

 Local Bankruptcy Rule 1007-1(H)(1) 

further states that 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. Pursuant to Local Bankruptcy 

Rule 1007-1(H)(3), however, the Court may waive the requirement to submit creditor 

information on a diskette under certain circumstances. 

 

1

 Specifically, section 521(a)(1)(A) of the Bankruptcy Code provides that "[the debtor shall file] a list of 

creditors ...." 11 U.S.C. § 521(a)(1)(A). Bankruptcy Rule 1007(a)(1) implements the requirement of 

section 521 of the Bankruptcy Code by requiring that a voluntary debtor "shall file with the petition a list 

containing the name and address of each entity included or to be included on Schedules D, E, F, G, and H 

as prescribed by the Official Forms." 

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6. The Debtors comprise a large enterprise with approximately 65,000

creditors identified on the Creditor Matrix. As such, the Debtors were not able to prepare their 

schedules of liabilities for filing on the Petition Date.2

7. The Debtors have contemporaneously filed a motion, pursuant to 

28 U.S.C. § 156(c), for an order authorizing the appointment of Kurtzman Carson 

Consultants, LLC ("KCC") as claims and noticing agent in these chapter 11 cases.3 The Debtors 

intend to furnish their Creditor Matrix to KCC so that KCC can undertake the mailing of the 

Commencement Notice to creditors, pursuant to section 342(a) of the Bankruptcy Code and 

Bankruptcy Rules 2002(a) and (f).4

 Because KCC will use the Creditor Matrix to furnish those 

creditors with the Commencement Notice, and because it is contemplated that KCC will handle 

the major notices to be given to all creditors in these cases, the filing of the Creditor Matrix with 

this Court pursuant to the Notice Rules serves no practical purpose. Accordingly, the Notice 

Rules should be waived in these chapter 11 cases. 

Request for Approval of the Form and Manner of the Commencement Notice 

8. Pursuant to Local Bankruptcy Rule 2002-1(A), the Debtors additionally 

request authority for KCC to serve the Commencement Notice in the form attached hereto as 

Exhibit A, which is substantially in the form of Official Bankruptcy Form 9 (for chapter 11 

 

2

 Contemporaneously herewith, the Debtors have filed a motion for a 60-day extension of the time to file, 

among other things, their schedules of assets and liabilities. 

3

 28 U.S.C. § 156(c) authorizes the use of non-court services for noticing, providing that "[a]ny court may 

utilize ... services, either on or off the court's premises, which pertain to the provision of notices ... to 

parties in cases filed under the provisions of title 11 .... The utilization of such ... services shall be subject 

to such conditions and limitations as the pertinent circuit council may prescribe." 28 U.S.C. § 156(c). 

4

 Section 342 of the Bankruptcy Code provides that "[t]here shall be given such notice as is appropriate ... of 

an order for relief in a case under this title." 11 U.S.C. § 342(a). Bankruptcy Rule 2002(a) provides that 

"the clerk, or some other person as the court may direct, shall give ... at least 21 days' notice by mail of: 

(1) the meeting of creditors under § 341 or § 1104(b) of the Code ...." Fed. R. Bankr. P. 2002(a). 

Bankruptcy Rule 2002(f) provides that "the clerk, or some other person as the court may direct, shall give ... 

notice by mail of: (1) the order for relief ...." Fed. R. Bankr. P. 2002(f). 

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cases).5

 The Debtors propose that the Commencement Notice be served by regular mail, postage 

prepaid, on those entities entitled to receive such notice pursuant to Bankruptcy Rule 2002(a) 

and Local Bankruptcy Rule 2002-1, and that such service occur no later than five business days 

after the Debtors receive notice from the U.S. Trustee of the time and place of the Section 341 

Meeting. The Debtors hereby request that the Court approve the foregoing as providing 

sufficient notice of the commencement of these chapter 11 cases and the Section 341 Meeting. 

Request for Authority to File a Single Consolidated List of Creditors 

9. Pursuant to Bankruptcy Rule 1007(d) and Local Bankruptcy 

Rule 1007-1(G), a chapter 11 debtor must file with its voluntary petition a list setting forth the 

names, addresses, telephone numbers and claim amounts of those creditors, excluding insiders, 

holding the 20 largest unsecured claims in the debtor's case (a "Top 20 List"). This Top 20 List 

primarily is used by the U.S. Trustee to evaluate the types and amounts of unsecured claims 

against the debtor and, thus, identify potential candidates to serve on any official committee of 

unsecured creditors (the "Creditors' Committee") appointed in the chapter 11 case under 

section 1102 of the Bankruptcy Code. See In re Dandy Doughboy Donuts, Inc., 66 B.R. 457, 

458 (Bankr. S.D. Fla. 1986) (stating that the purpose of the list is to facilitate the appointment of 

an unsecured creditors committee); 9 Collier on Bankruptcy ¶ 1007.04 (Alan N. Resnick & 

Henry J. Sommer eds., 16th ed.) (stating "the list enables the United States Trustee to determine 

the different types of claims existing in order to assure that a fully representative committee is 

appointed"). 

 

5

 No bar date for the filing of proofs of claim in these cases has been established. Accordingly, the 

Commencement Notice will not include a notice of the bar date. The Debtors will seek Court approval of a 

notice of bar date at an appropriate juncture in these chapter 11 cases. 

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10. Given the affiliated nature of the Debtors and the fact that they share a 

number of creditors in common, the Debtors believe that filing a list of their creditors holding the 

50 largest unsecured claims on a consolidated basis (the "Consolidated Top 50 List") would 

facilitate the U.S. Trustee's review of creditors' claims and its appointment of a single Creditors' 

Committee in these cases. Under these circumstances, the exercise of satisfying the literal 

requirements of Bankruptcy Rule 1007(d) and Local Bankruptcy Rule 1007-1(G) would serve 

only to frustrate its intended purpose. 

11. Considering the inconvenience to the U.S. Trustee by the Debtors' filing of 

over 100 separate but generally similar Top 20 Lists, and the absence of any corresponding 

benefit, the Debtors request authority to file the Consolidated Top 50 List in lieu of filing 

separate Top 20 Lists for each Debtor. The Debtors believe that such relief is appropriate under 

the circumstances for the efficient and orderly administration of these cases. 

12. Relief similar to that requested in this Motion has been granted in 

chapter 11 cases in this District and elsewhere. See, e.g., In re Health Diagnostic Lab., Inc., 

No. 15-32919 (KRH) (Bankr. E.D. Va. June 9, 2015) (Docket No. 37) (authorizing the debtors to 

file a consolidated list of top 30 creditors); In re Patriot Coal Corp., No. 15-32450 (KLP) 

(Bankr. E.D. Va. May 14, 2015) (Docket No. 85) (same); In re James River Coal Co., 

No. 14-31848 (KRH) (Bankr. E.D. Va. Apr. 9, 2014) (Docket No. 57) (same); In re AMF 

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

(Docket No. 62) (same); In re Movie Gallery, Inc., No. 10-30696 (DOT) (Bankr. E.D. Va. 

Feb. 8, 2010) (Docket No. 116) (same); In re Workflow Mgmt., Inc., No. 10-74617 (SCS) 

(Bankr. E.D. Va. Oct. 8, 2010) (Docket No. 102) (same); In re Circuit City Stores Inc., 

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No. 08-35653 (KRH) (Bankr. E.D. Va. Nov. 12, 2008) (authorizing a consolidated list of top 50 

creditors).6

 

Waiver of Separate Memorandum of Points and Authorities

13. The Debtors respectfully request that the Court regard any argument and 

citations set forth herein as a written memorandum of facts, reasons and authorities that has been 

combined with the relief requested herein, as permitted by Local Bankruptcy Rule 9013-1(G)(1). 

Alternatively, the Debtors respectfully request that the Court waive any requirement set forth in 

Local Bankruptcy Rule 9013-1(G)(1) that this Motion be accompanied by such a written 

memorandum. 

Notice

14. Notice of this Motion has been given to: (a) the Office of the United 

States Trustee for the Eastern District of Virginia; (b) Davis Polk & Wardwell LLP and 

McGuireWoods LLP, as co-counsel to Citibank, N.A., as administrative and collateral agent 

under the Debtors' proposed postpetition secured credit facility, and Citicorp North America, Inc., 

as administrative and collateral agent under the Debtors' prepetition secured credit facility; 

(c) Kirkland & Ellis LLP, as counsel to the Second Lien Noteholder Group; (d) the indenture 

trustees for the Debtors' secured and unsecured notes (and counsel, where known); (e) counsel to 

General Electric Credit Corporation, as administrative agent under the Debtors' prepetition 

secured accounts receivable facility; (f) the creditors holding the 50 largest unsecured claims 

against the Debtors' estates on a consolidated basis; (g) the United Mine Workers of America; 

and (h) any party that has requested notice pursuant to Bankruptcy Rule 2002 as of the time of 

 

6

 The unreported orders listed in the text above are not attached to this Motion. Copies of these orders will 

be made available to the Court and other parties upon request made to counsel to the Debtors. 

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service. In light of the nature of the relief requested, the Debtors submit that no further notice is 

necessary. 

No Prior Request

15. No prior request for the relief sought in this Motion has been made to this 

or any other Court in connection with these chapter 11 cases. 

WHEREFORE, the Debtors respectfully request that the Court: (i) enter an order 

substantially in the form attached hereto as Exhibit B, granting the relief requested herein; and 

(ii) grant such other and further relief to the Debtors as the Court may deem proper. 

Dated: August 3, 2015 

Richmond, Virginia 

Respectfully submitted, 

 /s/ Henry P. (Toby) Long, III 

Tyler P. Brown (VSB No. 28072) 

J.R. Smith (VSB No. 41913) 

Henry P. (Toby) Long, III (VSB No. 75134) 

Justin F. Paget (VSB No. 77949) 

HUNTON & WILLIAMS LLP 

Riverfront Plaza, East Tower 

951 East Byrd Street 

Richmond, Virginia 23219 

Telephone: (804) 788-8200 

Facsimile: (804) 788-8218 

David G. Heiman (pro hac vice pending) 

Carl E. Black (pro hac vice pending) 

Thomas A. Wilson (pro hac vice pending) 

JONES DAY 

North Point 

901 Lakeside Avenue 

Cleveland, Ohio 44114 

Telephone: (216) 586-3939 

Facsimile: (216) 579-0212 

PROPOSED ATTORNEYS FOR DEBTORS 

AND DEBTORS IN POSSESSION 

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EXHIBIT A

Proposed Commencement Notice 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

Alpha Natural Resources, Inc., et al., 

 Debtors. 

Chapter 11 

Case No. 15-_____ (___) 

(Joint Administration Requested) 

NOTICE OF COMMENCEMENT OF 

CHAPTER 11 CASES AND MEETING OF CREDITORS

Commencement of Chapter 11 Cases. On August 3, 2015, the above captioned debtors and 

debtors in possession (collectively, the "Debtors"), filed voluntary petitions for relief under 

chapter 11 of title 11 of the United States Code (the "Bankruptcy Code") in the United States 

Bankruptcy Court for the Eastern District of Virginia, Richmond Division (the "Court"). 

Each Debtor, its federal tax identification number and its corresponding chapter 11 case number 

is listed below. 

Chapter 11 allows a debtor to reorganize or liquidate pursuant to a plan. A plan is not effective 

unless confirmed by the Court. You may be sent a copy of a plan and a disclosure statement 

telling you about the plan, and you might have the opportunity to vote on the plan. You will be 

sent notice of the date of the confirmation hearing, and you may object to confirmation of the 

plan and attend the confirmation hearing. Unless a trustee is serving, the Debtors will remain in 

possession of the Debtors' property and may continue to operate any business. 

Joint Administration of Cases. Upon a motion by the Debtors, the Court entered an order on 

August 3, 2015 [Docket No. __] authorizing joint administration of the above-captioned cases 

pursuant to Rule 1015 of the Federal Rules of Bankruptcy Procedures (the "Bankruptcy Rules") 

and Rule 1015-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States 

Bankruptcy Court for the Eastern District of Virginia (the "Local Bankruptcy Rules"), 

consolidating the cases for procedural purposes only under Case No. 15-[________] and 

directing that the joint caption of the cases read In re Alpha Natural Resources, Inc., et al. 

Attorneys for Debtors. The attorneys representing the Debtors are David G. Heiman, Carl E. 

Black and Thomas A. Wilson, Jones Day, North Point, 901 Lakeside Avenue, Cleveland, 

Ohio 44114, Telephone: (216) 586-3939, Facsimile: (216) 579-0212, and Tyler P. Brown, J.R. 

Smith, Henry P. (Toby) Long, III and Justin F. Paget, Hunton & Williams LLP, Riverfront Plaza, 

East Tower, 951 East Byrd Street, Richmond, Virginia 23219, Telephone: (804) 788-8200; 

Facsimile: (804) 788-8218.

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Meeting of Creditors. Pursuant to section 341 of the Bankruptcy Code, the Office of the United 

States Trustee for the Eastern District of Virginia (the "U.S. Trustee") has scheduled a meeting of 

creditors on ____________ ___, 2015, at ____:____ _.m. (prevailing Eastern Time), at the 

Office of the U.S. Trustee, 701 East Broad Street, Suite 4300, Richmond, Virginia 23219. 

The Debtors' representatives must be present at the meeting to be examined under oath by the 

U.S. Trustee and by creditors. Creditors are welcome to attend the meeting but are not required 

to do so. The meeting may be continued and concluded at a later date specified in a notice filed 

with the Court. 

Creditors Generally May Not Take Certain Actions. In most instances, the filing of the 

bankruptcy cases automatically stays certain collection and other actions against the Debtors and 

the Debtors' property. Under certain circumstances, the stay may be limited to 30 days or not 

exist at all, although the Debtors can request the court to extend or impose a stay. Prohibited 

actions are listed in section 362(a) of the Bankruptcy Code and common examples include: 

(a) contacting the Debtors by telephone, mail or otherwise to demand repayment; (b) taking 

actions to collect money or obtain property from the Debtors; (c) starting or continuing lawsuits 

against the Debtors; and (d) repossessing the Debtors' property. See 11 U.S.C. § 362(a). 

If unauthorized actions are taken by a creditor against the Debtors, the Court may penalize that 

creditor. A creditor who is considering taking action against the Debtors or their property should 

review, among other things, section 362(a) of the Bankruptcy Code and seek legal advice. 

Notice of Bar Dates for Proofs of Claim. No bar date has yet been established for the filing of 

Proofs of Claim. If and when a bar date is established, a separate notice of the bar date (the "Bar 

Date Notice") will be provided. The Bar Date Notice will contain information regarding the bar 

dates, a Proof of Claim form and instructions for completing and filing a Proof of Claim form. 

Claims. A Proof of Claim is a signed statement describing a creditor's claim. If a Proof of 

Claim form is not included with this Notice, you can obtain one at any United States Bankruptcy 

Court Clerk of Court's office or online at www.vaeb.uscourts.gov. You may look at the 

schedules that have been, or will be, filed at the Clerk of Court's office or online at 

www.kccllc.net/alpharestructuring. If your claim is scheduled and is not listed as disputed, 

contingent or unliquidated, it will be allowed in the amount scheduled unless you filed a Proof of 

Claim or you are sent further notice about the claim. Whether or not your claim is scheduled, 

you are permitted to file a Proof of Claim. If your claim is not listed at all or if your claim is 

listed as disputed, contingent or unliquidated, then you must file Proofs of Claim or you might 

not be paid any money on your claim and may be unable to vote on a plan. The Bankruptcy 

Court has not yet set a deadline to file Proofs of Claim. If a deadline is set, you will be sent 

another notice. A secured creditor retains rights in its collateral regardless of whether that 

creditor files a Proof of Claim. Filing a Proof of Claim may submit the creditor to the 

jurisdiction of the Bankruptcy Court, with consequences a lawyer can explain. For example, 

a secured creditor who files a Proof of Claim may surrender important nonmonetary rights, 

including the right to a jury trial. Do not include this notice with any filing you make with the 

Court. 

Filing Deadline for a Creditor with a Foreign Address. The deadline for filing claims will be 

set in a later Court order and will apply to all creditors unless the order provides otherwise. 

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If notice of the order setting the deadline is sent to a creditor at a foreign address, the creditor 

may file a motion requesting the Court to extend the deadline. There is no assurance that such a 

motion would be granted. Consult a lawyer familiar with United States bankruptcy law if you 

have any questions regarding your rights in these cases. 

Case Management and Administrative Procedures. On [________ __], 2015, the Court 

entered the [Order Establishing Certain Notice, Case Management and Administrative 

Procedures] [Docket No. ___] (the "Case Management Order"). All parties who desire to 

participate in these cases must follow the procedures set forth therein. The Case Management 

Order provides, among other things, that, except as set forth in the procedures approved by the 

Case Management Order, notice of proceedings in the chapter 11 cases need only be sent via 

electronic mail to the parties on the established service list. Any party in interest that desires to 

receive electronic mail notice in the chapter 11 cases and, consequently, be added to the service 

list, shall file with the Court a notice of appearance and request for service and shall serve such 

request on Jones Day, North Point, 901 Lakeside Avenue, Cleveland, Ohio 44114, Attn: Carl E. 

Black and Thomas A. Wilson, and Hunton & Williams LLP, Riverfront Plaza, East Tower, 

951 East Byrd Street, Richmond, Virginia 23219, Attn.: Tyler P. Brown. All creditors will 

receive notice of certain proceedings, including, but not limited to, bar dates (unless applicable to 

a limited population of creditors), the time fixed for filing objections to and any hearing to 

consider a disclosure statement and/or confirmation of a chapter 11 plan and dismissal or 

conversion of the chapter 11 cases to another chapter of the Bankruptcy Code. A copy of the 

procedures approved by the Case Management Order is available from the sources described 

below. 

Discharge of Debts and Deadline to File a Complaint to Determine Dischargeability of 

Certain Debts. Confirmation of a chapter 11 plan may result in a discharge of debts, which may 

include all or part of your debt. See section 1141(d) of the Bankruptcy Code. A discharge 

means that you may never try to collect the debt from the Debtors, except as provided in the plan. 

If you believe that a debt owed to you is not dischargeable under section 1141(d)(6)(A) of the 

Bankruptcy Code, you must start a lawsuit by filing a complaint in the Court by [________ __], 

2015. The Clerk of Court's Office must receive the complaint and any required filing fee by 

such deadline. 

How to Obtain Documents. Electronic copies of all pleadings or other documents filed in these 

cases may be obtained for $0.10 per page or $2.40 per document via PACER on the Court's web 

site at http://ecf.vaeb.uscourts.gov. Paper copies of all pleadings or other documents filed in 

these cases may be obtained by sending a written request to the Debtors' claims and noticing 

agent Kurtzman Carson Consultants, LLC ("KCC") at Alpha Natural Resources Claims 

Processing Center, c/o KCC, 2335 Alaska Avenue, El Segundo, CA 90245, or by contacting 

KCC by telephone at (888) 249-2703 (toll free in the U.S. and Canada) or (310) 751-2602 

(for international callers). Additionally, free electronic copies of certain pleadings or other 

documents filed in these cases will be posted on KCC's web site at 

http://www.kccllc.net/alpharestructuring as soon as possible after filing. 

Court Filings. Any paper that you file in these bankruptcy cases should be filed at the Clerk of 

Court's office at the U.S. Bankruptcy Court, Office of the Clerk of Court, 701 East Broad Street, 

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Suite 4000, Richmond, VA 23219. In addition, these cases have been designated as cases 

assigned to the electronic case filing system and can be accessed via the Court's web site at 

http://www.vaeb.uscourts.gov or http://ecf.vaeb.uscourts.gov. 

Local Bankruptcy Rule Dismissal Warning. Chapter 11 cases may be dismissed for failure to 

timely file lists, schedules and statements. See Local Bankruptcy Rule 1007-1. 

Legal Advice. Neither the Debtors' counsel, KCC nor the staff of the Clerk of Court's 

Office can give you legal advice. You may wish to consult an attorney to protect your 

rights. 

List of Debtors. 

Debtor's Name Debtor's EIN Number Case Number 

Alpha Natural Resources, Inc. 42-1638663 15-[______] 

Alex Energy, Inc. 55-0755384 15-[______] 

Alpha American Coal Company, LLC 54-1947356 15-[______] 

Alpha American Coal Holding, LLC 13-2793319 15-[______] 

Alpha Appalachia Holdings, Inc. 95-0740960 15-[______] 

Alpha Appalachia Services, Inc. 54-1095096 15-[______] 

Alpha Coal Resources Company, LLC 84-1341308 15-[______] 

Alpha Coal Sales Co., LLC 16-1641207 15-[______] 

Alpha Coal West, Inc. 35-1867616 15-[______] 

Alpha European Sales, Inc. 54-1834161 15-[______] 

Alpha India, LLC 27-4593320 15-[______] 

Alpha Land and Reserves, LLC 57-1136960 15-[______] 

Alpha Midwest Holding Company 84-1456626 15-[______] 

Alpha Natural Resources, LLC 56-2298262 15-[______] 

Alpha Natural Resources International, LLC 27-4592266 15-[______] 

Alpha Natural Resources Services, LLC 27-0075099 15-[______] 

Alpha PA Coal Terminal, LLC 26-1102515 15-[______] 

Alpha Shipping and Chartering, LLC 41-2136215 15-[______] 

Alpha Sub Eight, LLC 47-3587689 15-[______] 

Alpha Sub Eleven, Inc. 47-3640130 15-[______] 

Alpha Sub Nine, LLC 47-3601607 15-[______] 

Alpha Sub One, LLC 27-4592410 15-[______] 

Alpha Sub Ten, Inc. 47-3626036 15-[______] 

Alpha Sub Two, LLC 27-4592527 15-[______] 

Alpha Terminal Company, LLC 55-0802473 15-[______] 

Alpha Wyoming Land Company, LLC 35-1661756 15-[______] 

AMFIRE, LLC 51-0430939 15-[______] 

AMFIRE Holdings, LLC 11-3673814 15-[______] 

AMFIRE Mining Company, LLC 11-3673833 15-[______] 

Appalachia Coal Sales Company, Inc. 54-1188775 15-[______] 

Appalachia Holding Company 54-0295165 15-[______] 

Aracoma Coal Company, Inc. 52-1669141 15-[______] 

Axiom Excavating and Grading Services, LLC 20-8109122 15-[______] 

Bandmill Coal Corporation 55-0758310 15-[______] 

Bandytown Coal Company 55-0751776 15-[______] 

Barbara Holdings Inc. 25-1292326 15-[______] 

Barnabus Land Company 55-0728645 15-[______] 

Belfry Coal Corporation 61-0415137 15-[______] 

Big Bear Mining Company 22-2138933 15-[______] 

Black Castle Mining Company, Inc. 52-1891104 15-[______] 

Black King Mine Development Co. 54-1188659 15-[______] 

Black Mountain Cumberland Resources, Inc. 27-2323540 15-[______] 

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Debtor's Name Debtor's EIN Number Case Number 

Boone East Development Co. 55-0717715 15-[______] 

Brooks Run Mining Company, LLC 52-2070922 15-[______] 

Coal Gas Recovery II, LLC 46-2855899 15-[______] 

Pennsylvania Land Resources, LLC 46-2854684 15-[______] 

Brooks Run South Mining, LLC 26-0342580 15-[______] 

Buchanan Energy Company, LLC 54-0983234 15-[______] 

Castle Gate Holding Company 84-1456620 15-[______] 

Clear Fork Coal Company 55-0757300 15-[______] 

Crystal Fuels Company 55-0732366 15-[______] 

Cumberland Coal Resources, LP 84-1521723 15-[______] 

Dehue Coal Company 55-0619956 15-[______] 

Delbarton Mining Company 55-0764304 15-[______] 

Delta Mine Holding Company 91-1897558 15-[______] 

DFDSTE Corp. 84-1199429 15-[______] 

Dickenson-Russell Coal Company, LLC 54-2079085 15-[______] 

Dickenson-Russell Land and Reserves, LLC 20-4278709 15-[______] 

DRIH Corporation 54-1497754 15-[______] 

Duchess Coal Company 54-1725084 15-[______] 

Eagle Energy, Inc. 55-0751738 15-[______] 

Elk Run Coal Company, Inc. 54-1097978 15-[______] 

Emerald Coal Resources, LP 84-1521724 15-[______] 

Enterprise Mining Company, LLC 38-3671602 15-[______] 

Esperanza Coal Co., LLC 06-1652549 15-[______] 

Foundation Mining, LLC 20-3378168 15-[______] 

Foundation PA Coal Company, LLC 84-1521726 15-[______] 

Foundation Royalty Company 84-1456627 15-[______] 

Freeport Mining, LLC 84-1521725 15-[______] 

Freeport Resources Company, LLC 84-1230391 15-[______] 

Goals Coal Company 55-0737462 15-[______] 

Gray Hawk Insurance Company 26-0483222 15-[______] 

Green Valley Coal Company 55-0747007 15-[______] 

Greyeagle Coal Company 55-0771551 15-[______] 

Harlan Reclamation Services LLC 54-1914510 15-[______] 

Herndon Processing Company, LLC 51-0442749 15-[______] 

Highland Mining Company 55-0757301 15-[______] 

Hopkins Creek Coal Company 54-1136806 15-[______] 

Independence Coal Company, Inc. 54-1188773 15-[______] 

Jacks Branch Coal Company 55-0734230 15-[______] 

Jay Creek Holding, LLC 27-4593143 15-[______] 

Kanawha Energy Company 55-0765391 15-[______] 

Kepler Processing Company, LLC 51-0442560 15-[______] 

Kingston Mining, Inc. 31-1562659 15-[______] 

Kingwood Mining Company, LLC 57-1148058 15-[______] 

Knox Creek Coal Corporation 54-1393689 15-[______] 

Lauren Land Company 61-1209098 15-[______] 

Laxare, Inc. 55-0486813 15-[______] 

Litwar Processing Company, LLC 51-0442687 15-[______] 

Logan County Mine Services, Inc. 31-1708085 15-[______] 

Long Fork Coal Company 54-1605009 15-[______] 

Lynn Branch Coal Company, Inc. 54-1537451 15-[______] 

Maple Meadow Mining Company 55-0529664 15-[______] 

Marfork Coal Company, Inc. 55-0723539 15-[______] 

Martin County Coal Corporation 61-0702852 15-[______] 

Maxxim Rebuild Co., LLC 01-0749355 15-[______] 

Maxxim Shared Services, LLC 55-0814342 15-[______] 

Maxxum Carbon Resources, LLC 55-0802477 15-[______] 

McDowell-Wyoming Coal Company, LLC 54-2079104 15-[______] 

Mill Branch Coal Corporation 54-1817506 15-[______] 

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Debtor's Name Debtor's EIN Number Case Number 

New Ridge Mining Company 61-1218677 15-[______] 

New River Energy Corporation 54-1225713 15-[______] 

Neweagle Industries, Inc. 54-1695751 15-[______] 

Nicewonder Contracting, Inc. 20-0388143 15-[______] 

North Fork Coal Corporation 54-1679027 15-[______] 

Omar Mining Company 55-0385010 15-[______] 

Paramont Coal Company Virginia, LLC 56-2298367 15-[______] 

Paynter Branch Mining, Inc. 55-0746860 15-[______] 

Peerless Eagle Coal Co. 55-0451306 15-[______] 

Pennsylvania Land Holdings Company, LLC 84-1452626 15-[______] 

Pennsylvania Land Resources Holding Company, LLC 46-2855640 15-[______] 

Pennsylvania Services Corporation 93-1162601 15-[______] 

Performance Coal Company 55-0736927 15-[______] 

Peter Cave Mining Company 61-1360315 15-[______] 

Pigeon Creek Processing Corporation 54-1900369 15-[______] 

Pilgrim Mining Company, Inc. 61-1246461 15-[______] 

Pioneer Fuel Corporation 55-0545211 15-[______] 

Plateau Mining Corporation 95-3761213 15-[______] 

Power Mountain Coal Company 31-1567082 15-[______] 

Premium Energy, LLC 20-3562770 15-[______] 

Rawl Sales & Processing Co. 55-0476477 15-[______] 

Republic Energy, Inc. 55-0741015 15-[______] 

Resource Development LLC 54-1882316 15-[______] 

Resource Land Company LLC 54-1912100 15-[______] 

River Processing Corporation 84-1199433 15-[______] 

Riverside Energy Company, LLC 51-0442691 15-[______] 

Riverton Coal Production Inc. 55-0739658 15-[______] 

Road Fork Development Company, Inc. 54-1293743 15-[______] 

Robinson-Phillips Coal Company 55-0386264 15-[______] 

Rockspring Development, Inc. 31-1241956 15-[______] 

Rostraver Energy Company 25-1418256 15-[______] 

Rum Creek Coal Sales, Inc. 31-1181801 15-[______] 

Russell Fork Coal Company 61-0394431 15-[______] 

Shannon-Pocahontas Coal Corporation 54-1132767 15-[______] 

Shannon-Pocahontas Mining Company 55-0613879 15-[______] 

Sidney Coal Company, Inc. 54-1293752 15-[______] 

Spartan Mining Company 31-1571923 15-[______] 

Stirrat Coal Company 55-0728501 15-[______] 

Sycamore Fuels, Inc. 54-1527013 15-[______] 

T. C. H. Coal Co. 61-0723123 15-[______] 

Tennessee Consolidated Coal Company 62-6029380 15-[______] 

Thunder Mining Company II, Inc. 55-0770782 15-[______] 

Trace Creek Coal Company 25-1418260 15-[______] 

Twin Star Mining, Inc. 31-1265426 15-[______] 

Wabash Mine Holding Company 91-1897559 15-[______] 

Warrick Holding Company 91-1897557 15-[______] 

West Kentucky Energy Company 27-0516756 15-[______] 

White Buck Coal Company 55-0747028 15-[______] 

Williams Mountain Coal Company 55-0729825 15-[______] 

Wyomac Coal Company, Inc. 55-0574144 15-[______] 

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Dated: August [__], 2015 

Clerk of the United States Bankruptcy Court 

For the Eastern District of Virginia 

701 East Broad Street, Suite 4000 

Richmond, Virginia 23219 

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EXHIBIT B

Proposed Order 

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JONES DAY 

North Point 

901 Lakeside Avenue 

Cleveland, Ohio 44114 

Telephone: (216) 586-3939 

Facsimile: (216) 579-0212 

David G. Heiman (pro hac vice pending) 

Carl E. Black (pro hac vice pending) 

Thomas A. Wilson (pro hac vice pending) 

Proposed Attorneys for Debtors 

and Debtors in Possession 

HUNTON & WILLIAMS LLP 

Riverfront Plaza, East Tower 

951 East Byrd Street 

Richmond, Virginia 23219 

Telephone: (804) 788-8200 

Facsimile: (804) 788-8218 

Tyler P. Brown (VSB No. 28072) 

J.R. Smith (VSB No. 41913) 

Henry P. (Toby) Long, III (VSB No. 75134) 

Justin F. Paget (VSB No. 77949) 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE EASTERN DISTRICT OF VIRGINIA 

RICHMOND DIVISION 

In re: 

Alpha Natural Resources, Inc., et al., 

 Debtors. 

Chapter 11 

Case No. 15-_____ (___) 

(Joint Administration Requested) 

ORDER, PURSUANT TO SECTIONS 342 AND 521(a) OF THE 

BANKRUPTCY CODE, BANKRUPTCY RULES 1007(a), 2002(a) AND 

2002(f) AND LOCAL BANKRUPTCY RULES 1007-1 AND 2002-1, 

(A) WAIVING THE REQUIREMENT THAT EACH DEBTOR FILE 

A LIST OF CREDITORS, (B) APPROVING THE FORM AND MANNER 

OF NOTICE OF THE COMMENCEMENT OF THE DEBTORS' 

CHAPTER 11 CASES AND (C) AUTHORIZING THE FILING 

 OF A CONSOLIDATED LIST OF TOP 50 UNSECURED CREDITORS 

This matter coming before the Court on the Motion of Debtors and Debtors in 

Possession, Pursuant to Sections 342 and 521(a) of the Bankruptcy Code, Bankruptcy 

Rules 1007(a), 2002(a) and 2002(f) and Local Bankruptcy Rules 1007-1 and 2002-1, for an 

Order (A) Waiving the Requirement that Each Debtor Submit a Formatted Mailing Matrix, 

(B) Approving the Form and Manner of Notice of the Commencement of the Debtors' 

Chapter 11 Cases and (C) Authorizing the Filing of a Consolidated List of Top 50 Unsecured 

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Creditors (the "Motion"),1

 filed by the debtors and debtors in possession in the above-captioned 

cases (collectively, the "Debtors"); the Court having reviewed the Motion and the First Day 

Declarations and having considered the statements of counsel with respect to the Motion at a 

hearing before the Court (the "Hearing"); and the Court having found that (i) the Court has 

jurisdiction over this matter pursuant to 28 U.S.C. § 1334, (ii) this is a core proceeding pursuant 

to 28 U.S.C. § 157(b), (iii) venue is proper before this Court pursuant to 28 U.S.C. §§ 1408 and 

1409 and (iv) notice of the Motion and the Hearing was sufficient under the circumstances; and 

the Court having determined that the legal and factual bases set forth in the Motion and the First 

Day Declarations and at the Hearing establish just cause for the relief granted herein; 

IT IS HEREBY ORDERED THAT: 

1. The Motion is GRANTED as set forth herein. 

2. The requirement that the Debtors file a Creditor Matrix with the Court on 

the Petition Date pursuant to the Notice Rules is hereby waived. 

3. The Debtors shall furnish KCC with the Creditor Matrix as soon as 

possible upon the Court's authorization of the Debtors' engagement of KCC as claims and 

noticing agent in these chapter 11 cases. 

4. The form of the Commencement Notice attached to the Motion as 

Exhibit A is hereby approved.

5. KCC is authorized and directed to serve the Commencement Notice, 

substantially in the form attached to the Motion as Exhibit A, no later than five business days 

after the Debtors receive written notice from the U.S. Trustee of the time and place of the 

Section 341 Meeting. KCC shall serve the Commencement Notice by regular mail, postage 

 

1

 Capitalized terms not otherwise defined herein shall have the meanings given to them in the Motion. 

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prepaid, on those entities entitled to receive the Commencement Notice pursuant to Bankruptcy 

Rule 2002(a) and Local Bankruptcy Rule 2002-1. Service of the Commencement Notice in 

accordance with this paragraph is approved in all respects and is deemed sufficient notice to all 

parties in interest of the commencement of these chapter 11 cases and the Section 341 Meeting 

under the Bankruptcy Code, the Bankruptcy Rules and the Local Bankruptcy Rules.

6. The Debtors are authorized to file a Consolidated Top 50 List in these 

chapter 11 cases, in lieu of filing a separate Top 20 List for each of the Debtors' respective cases. 

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

memorandum of law in connection with the Motion is hereby waived to the extent necessary. 

8. The Debtors are authorized and empowered to take all actions necessary to 

implement the relief granted in this Order. 

9. This Court shall retain exclusive jurisdiction over any and all matters 

arising from or related to the implementation or interpretation of this Order. 

Dated: ________________, 2015 

Richmond, Virginia 

____________________________________ 

UNITED STATES BANKRUPTCY JUDGE 

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WE ASK FOR THIS: 

 

Respectfully submitted, 

 /s/ Henry P. (Toby) Long, III 

Tyler P. Brown (VSB No. 28072) 

J.R. Smith (VSB No. 41913) 

Henry P. (Toby) Long, III (VSB No. 75134) 

Justin F. Paget (VSB No. 77949) 

HUNTON & WILLIAMS LLP 

Riverfront Plaza, East Tower 

951 East Byrd Street 

Richmond, Virginia 23219 

Telephone: (804) 788-8200 

Facsimile: (804) 788-8218 

David G. Heiman (pro hac vice pending) 

Carl E. Black (pro hac vice pending) 

Thomas A. Wilson (pro hac vice pending) 

JONES DAY 

North Point 

901 Lakeside Avenue 

Cleveland, Ohio 44114 

Telephone: (216) 586-3939 

Facsimile: (216) 579-0212 

Proposed Counsel to the Debtors 

and Debtors in Possession 

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/ Henry P. (Toby) Long, III 

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