221223 ORD RE PREPA DS SCHED MOT.DOCX VERSION DECEMBER 23, 2022 1

Exhibit 1 

Depository Procedures

1. The Debtor is authorized to establish and populate an electronic document 

depository (the “Disclosure Statement Depository”) which shall include factual source materials 

and raw data underlying the Disclosure Statement (including but not limited to factual source 

materials and raw data underlying the analysis of the Debtor’s assets, the cash restriction analysis, 

and the best interest test report), as well as documents relating to the nature of claims and 

classification under the Plan (collectively, the “Documents”).

2. Creditors may request access to the Depository by visiting 

titleiiiplandataroom.com. 

3. The Depository will be made available only to the following parties or their 

representatives (collectively, “Eligible Creditors”): (i) creditors of the Debtor for which a master 

proof of claim has been filed on such creditor’s behalf that has not otherwise been disallowed or 

expunged, (ii) creditors of the Debtor who have filed a proof of claim against the Debtor that has 

not been disallowed or expunged, (iii) creditors who were not required to file a proof of claim 

pursuant to the Bar Date Orders,

1 or (iv) creditors who are listed on the Debtor’s List of Creditors 

(Docket Entry No. 520 in Case No. 17-4780, as may be modified), in an amount greater than $0.00. 

4. All Eligible Creditors wishing to access the Depository must first navigate to 

titleiiiplandataroom.com; request access to the site; designate whether they wish to have access to 

non-confidential documents only or to confidential documents as well; affirm they are or represent

1 “Bar Date Orders” refers to the Order (A) Establishing Deadlines and Procedures for 

Filing Proofs of Claims and (B) Approving Form and Manner of Notice Thereof [Case 

No. 17-3283, ECF No. 2521] and the Order (A) Extending Deadlines for Filing Proofs of 

Claim and (B) Approving Form and Manner of Notice Thereof (Docket Entry No. 3160 

in Case No. 17-3283).

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a creditor of the Debtor; provide certain biographical information, including their name, address, 

telephone number, email address, proof of claim number (if available), and identify their creditor 

type, and if they are not the creditor, the name of the creditor and, if applicable, the representative 

institution they are associated with; and certify that they are eligible for access to the Depository 

pursuant to categories (i)-(iv) in paragraph 3 above. Access requests will be processed as promptly 

as reasonably practicable.

5. Eligible Creditors granted access to the Depository will receive access to all nonconfidential materials posted in the Depository. To the extent Eligible Creditors also wish to 

access Confidential Information, such parties must agree to comply with the Protective Order 

annexed as Exhibit 2 to the Order, and execute the Protective Order Subscription annexed as 

Exhibit 3 to the Order. The Protective Order Subscription will be available to creditors by visiting

titleiiiplandataroom.com and requesting access to confidential documents. Creditors will then be 

directed to OnTask, a secure online signing service, in order to review the Protective Order and 

submit an Eligible Creditor’s electronic signature on the Protective Order Subscription. Any 

Eligible Creditor who executes the Protective Order Subscription shall be provided access to the 

Confidential portion of the Depository within one (1) business day of execution and submission 

thereof, or as soon as reasonably practicable thereafter.

6. The Depository shall contain an electronic index of all documents in the 

Depository. The Debtor shall use its reasonable best efforts to categorize Documents in the 

Depository by topic; provided, however, that the Depository shall contain a disclaimer expressly 

stating, among other things, that (i) the Debtor shall not be responsible for the mis-categorization 

of any particular Document and (ii) each Eligible Creditor should not rely upon the categorization 

of the Documents and should review all categories of Documents in their entirety. 

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7. Notwithstanding the placement of any document in the Depository and the review 

of any such document by an Eligible Creditor, the Oversight Board and the Debtor shall maintain 

the right to object to the use or introduction of any document in the Depository in any matter or 

proceeding on relevance grounds or as otherwise permitted in accordance with the Federal Rules 

of Evidence and applicable law; provided, however, that, to the extent that a Document contained 

in the Depository has been created by the Debtor, such party shall have waived the right to object 

to the use or introduction of such document on the basis of authenticity. Additionally, to the extent 

that the Debtor inadvertently includes privileged materials in the Depository, it shall not be deemed 

to comprise any waiver of any applicable privilege. Such protective measures are necessary to 

provide the requesting parties access to relevant materials in a timely and efficient manner.

8. In order to streamline access to the Depository and prevent overloading the 

Depository’s website, the Oversight Board may make some or all Documents included in the 

Depository available to some or all Eligible Creditors by other means, including but not limited to 

transmitting such Documents via a secure file transfer protocol. The Oversight Board shall make 

the determination to provide Documents in such fashion in its own discretion, and all other terms 

of use and access to the Documents included in the Depository, whether provided via the 

depository or via secure file transfer protocol (including relating to the use of Confidential 

Information), shall be identical. 

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