in the united states bankruptcy court for...

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE WESTERN DISTRICT OF TEXAS

EL PASO DIVISION

IN RE: §

EL PASO CHILDREN’S HOSPITAL

CORPORATION,

§

§

CASE NO. 15-30784-HCM

DEBTOR. § CHAPTER 11

§

EIN: 26-3075429 §

§

4845 ALAMEDA AVENUE §

EL PASO, TEXAS 79905 §

DEBTOR’S AMENDED RESPONSE TO MOTION TO COMPEL

FINANCIAL AND ACCOUNTING INFORMATION FROM DEBTOR

TO THE HONORABLE U.S. BANKRUPTCY JUDGE H. CHRISTOPHER MOTT:

COMES NOW El Paso Children’s Hospital Corporation (“EPCH” and/or “Debtor”), and

files its Response to Motion to Compel Financial and Accounting Information from Debtor

(“Response”). In support thereof, the Debtor would respectfully show as follows:

I. INTRODUCTION

1. The Debtor has produced nearly 4,000 pages of responsive documents to UMC

since the filing of this bankruptcy case, and prior to UMC’s Motion. Furthermore, UMC1 never

informed the Debtor that it viewed the Debtor’s production to be insufficient, and it gave no

warning that it would be pursuing a motion to compel against the Debtor. Indeed with respect to

UMC’s document requests particular to cash collateral, such request was not properly made until

the evening of July 1, 2015. As of the filing of this Response, the Debtor has already produced

approximately an additional 500 pages to UMC. Given the foregoing, no need exists to compel

the Debtor to produce documents to UMC. Indeed, even prior to the Petition Date, UMC had

access to many of the same documents it has sought after the bankruptcy filing; and of course,

1 El Paso County Hospital District d/b/a University Medical Center (“UMC”).

15-30784-hcm Doc#147 Filed 07/09/15 Entered 07/09/15 13:40:24 Main Document Pg 1 of 7

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due to the unusually close relationship between the two parties, the Debtor has been an open

book with respect to UMC throughout the tenure of the parties’ relationship.

II. BACKGROUND

2. On May 19, 2015 (“Petition Date”), the Debtor filed its voluntary petition for

relief under Chapter 11 of the United States Bankruptcy Code, 11 U.S.C. § 101, et seq.

(as amended the “Bankruptcy Code”). The Debtor is a debtor-in-possession pursuant to

§§ 1107(a) and 1108 of the Bankruptcy Code. No request for the appointment of a trustee or

examiner has been made in this bankruptcy case, and no committee has been appointed or

designated.

3. A description of the background of the Debtor and the events leading up to the

filing of the voluntary petition by the Debtor, is provided in the Declaration of Mark Herbers in

Support of First Day Motions (“Herbers Declaration”) [Dckt. No. 12] which is incorporated

herein by reference.

4. The Debtor is an independent non-profit 501(c)(3) corporation that is governed by

a board of directors (“EPCH Board”), the sole mission of which has been to provide pediatric

care to the children of El Paso and the surrounding areas. The Debtor’s primary operations have

consisted of owning and operating a 122-bed children’s hospital.

5. On July 7, 2015, UMC filed its Motion to Compel Financial and Accounting

Information from Debtor (“Motion to Compel”) [Dckt. No. 137].

6. In its Motion to Compel, UMC seeks production of documents regarding the

Debtor’s financial and accounting information pursuant to the Second Interim Order

(I) Authorizing Use of Cash Collateral, (II) Granting Adequate Protection, and (III) Scheduling

Final Hearing (“Second Interim Cash Collateral Order”), which was entered by this Court on


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June 8, 2015 [Dckt. No. 69]. Because the Debtor has produced responsive documents to UMC,

the Motion should be denied.

III. RESPONSE

7. Despite the truncated time frame and UMC’s failure to confer with the Debtor’s

counsel in a meaningful way, the Debtor has already complied with the requests made by UMC

to it for documents in relationship to the Second Interim Cash Collateral Order.

8. On June 13, 2015, UMC filed its Motion for Examinations Under Federal Rule of

Bankruptcy Procedure 2004 (“2004 Motion”) [Dckt. No. 81]. Local Rule 2004(c) of the Local

Rules of the Bankruptcy Court for the Western District of Texas (“Local Rules”) provides that

no such motion is required, and that the notice of intent need not be filed. Despite its awkward

procedural posture, the Debtor agreed that it would accept the 2004 Motion as a 2004 Notice

upon UMC’s agreement as to its own notices of 2004 examinations. The 2004 Notice also

requested production of documents from the Debtor.

9. On June 16, 2015, the Debtor served its Debtor’s Notice of Rule 2004

Examination of the Representative of UMC (“UMC 2004 Notice”), and its Debtor’s Notice of

Rule 2004 Examination of James Valenti (“Valenti 2004 Notice,” and together with the UMC

2004 Notice, “Debtor’s 2004 Notices”). The Debtor’s 2004 Notices also requested the

production of documents from UMC. Subsequently, the Debtor and UMC agreed to a rolling

production of documents, and in particular, the Debtor reduced the number of its document

requests to UMC, at UMC’s request.

10. UMC produced documents electronically to the Debtor on June 23, 2015. See Ex.

A. The Debtor produced documents to UMC in response to the 2004 Notice on June 24, 2015,

and produced additional documents on June 26, 2015 to UMC, for a total of nearly 4,000 pages

of documents. See Ex. B. On July 8, 2015, the Debtor produced an additional 500 pages of


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documents. See Ex. C. Each time the Debtor produced documents to UMC, the Debtor has

provided UMC with a production log, highlighting the new documents being produced to

facilitate UMC’s review of documents. Indeed, the Debtor has not received any additional

document production from UMC since June 23, 2015, despite the agreement between the parties,

and UMC has not timely responded to the Debtor’s inquiries concerning certain assertions made

with respect to documents already produced by UMC to the Debtor.

11. Contrary to the implications in the Motion to Compel, the initial document

request related to the Second Interim Cash Collateral Order by UMC was made by UMC’s

retained consultant, Deloitte Consulting LLP (the expert retained by UMC in this matter),

directly to the Debtor’s Chief Executive Officer, Mark Herbers (“Herbers”) via an email from

Deloitte to Mr. Herbers on June 26, 2015, with no copy to proposed counsel for the Debtor.

Counsel for the Debtor did not receive the document request until it was forwarded from Mr.

Herbers, and upon inquiry to UMC on the evening of June 26, 2015, after the second full day of

mediation. In addition, upon inquiry to UMC as to what the document request was, proposed

counsel for the Debtor was informed that the document request would be modified over the July

4, 2015 weekend, and the first modified request was the July 1, 2015 evening request.

12. On Wednesday, July 1, 2015 (in advance of a holiday weekend), the Debtor and

UMC agreed to reduced document requests, as stated in the Motion to Compel. See ¶ 5. Given

the holiday weekend, the Debtor first had personnel on the ground to compile and transmit

responsive documents to the Debtor’s proposed counsel for production on Monday, July 6, 2015,

and indeed, produced responsive documents as soon as it was able to UMC on July 8, 2015.

13. The Debtor has produced responsive documents to UMC’s document requests in

good faith and has made reasonable efforts to do so as promptly as possible, all while managing


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its bankruptcy case and continuing its operations as a children’s hospital. The Debtor has never

sought to evade any document request by UMC. Indeed, such efforts would likely be pointless

as UMC has had ready access to financial information and other information about the Debtor

sought now by UMC since at least during its due diligence completed in relation to the second

failed mediation, and because of the unusual relationship between the parties, has had nearly

unfettered access to the Debtor’s documents. This bankruptcy case, and the dispute between the

Debtor and UMC, is not a matter of resolution of a claim of a garden-variety creditor and a

distressed debtor—this bankruptcy case seeks to resolve the claims that have arisen out of an

atypical, codependent relationship of which UMC has been a part since before the Debtor opened

its doors to its first patient.

14. Moreover, although the Motion to Compel contains a certificate of conference, no

conference actually aimed at resolving the issues raised in the Motion to Compel was attempted

or occurred, particularly with respect to UMC’s asserted belief in the Motion to Compel that the

Debtor had evaded its document requests or failed to respond. See Whatley v. AHF Fin. Servs.,

LLC, No. 4:11-cv-488, 2013 U.S. Dist. LEXIS 127414, at *7-8 (Bankr. E.D. Tex. Aug. 12, 2013)

(stating that a certificate of conference that only set forth attempts to confer was an insufficient

attempt to confer as it did not indicate a “meaningful, good faith attempt to confer and identify

areas of agreement or disagreement”). Had a meaningful, good faith attempt to confer occurred

or even been attempted, the Debtor believes that any outstanding issue relating to UMC’s

document requests could have been resolved between the parties. Indeed, the first time that the

Debtor learned that UMC had any issue with its document production was upon service of the

Motion to Compel on July 7, 2015, subsequent to the hearing on the continuance of the final

hearing on cash collateral. The Debtor simply cannot fix what it does not know is broken; had


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UMC informed the Debtor that it believed that the Debtor had not produced documents in an

appropriate and timely manner, the Debtor would have taken immediate steps to address such

concerns.

15. The Debtor has produced documents in its possession or control responsive to

UMC’s requests, the Motion to Compel should be denied in its entirety.

WHEREFORE, PREMISES CONSIDERED, the Debtor requests that the Court enter an

order denying the relief requested in the Motion to Compel, and grant such other and further

relief to the Debtor as the Court deems just.

Dated: July 9, 2015.

Respectfully submitted,

JACKSON WALKER LLP

100 Congress Avenue, Suite 1100

Austin, Texas 78701

(512) 236-2000 – Main Telephone

(512) 236-2002—Main Facsimile

By: /s/ Jennifer F. Wertz

Patricia B. Tomasco

State Bar No. 01797600

(512) 236-2076 – Direct Dial

(512) 691-4438 – Direct Fax

Email: [email protected]

Jennifer F. Wertz

State Bar No. 24072822

(512) 236-2247 – Direct Dial

(512) 391-2147 – Direct Fax

Email: [email protected]

PROPOSED COUNSEL FOR THE

DEBTOR-IN-POSSESSION


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CERTIFICATE OF SERVICE

I hereby certify that on the 9th day of July 2015, a true and correct copy was served via

the Court’s CM/ECF electronic notification system upon the parties listed below, and via United

States Mail, postage prepaid upon the parties on the attached service list.

UNITED STATES TRUSTEE

Kevin Epstein, Trial Attorney

615 E Houston Street, Room 533

San Antonio, Texas 78205

Lou Strubeck

Liz Boydston

NORTON ROSE FULBRIGHT US LLP

2200 Ross Avenue, Suite 3600

Dallas, Texas 75201-7932

/s/ Jennifer F. Wertz

Jennifer F. Wertz

13982794v.1 145048/00008


1

Gradney, Kendra

From: Boydston, Liz <[email protected]>

Sent: Tuesday, June 23, 2015 4:51 PM

To: Wertz, Jennifer; Tomasco, Patty

Cc: Strubeck, Louis; Drake, Scott; Springer, Tim

Subject: EPCH: UMC's Responses & Objection to Debtor's 2004 Notices and UMC's first

production of documents

Attachments: UMC First Production Letter to EPCH.pdf; UMC Responses and Objections to 2004 Exam

Requests and Scope.pdf

Jennifer

Please see the attached letter regarding El Paso County Hospital District d/b/a University Medical Center of El Paso (“UMC”)’s first

production of documents bearing bates numbers UMC-0000001 through UMC-0003206 pursuant to the Debtor’s Notices of Rule

2004 Examinations of James Valenti and the Representative of El Paso County Hospital District d/b/a University Medical Center of El

Paso and the June 19, 2015 email to limit the scope of the document requests.

These documents are produced subject to the attached Reponses and Objections of El Paso Hospital District D/B/A University

Medical Center of El Paso to the Debtor’s Notice of Rule 2004 Examination. Counsel for UMC is available for a meet and confer call

to discuss UMC’s responses and objections.

These documents are being sent to you via a separate email from Norton Rose Fulbright’s Document Share Link. The directions to

access these documents are included in a separate email. Please do not hesitate to follow-up with me or Tim Springer (214-855-

8094) if you have difficulty accessing the materials.

Please confirm receipt of UMC’s first production.

Liz Boydston | Sr. Associate Norton Rose Fulbright US LLP 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201-7932, United States Tel +1 214 855 7475 | Fax +1 214 855 8200 [email protected]

NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com Norton Rose Fulbright – top 3 global legal brand: Acritas’ Sharplegal 2014 Global Elite Brand Index

The Dallas office has a new location. Please make note of our new address.

CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email communications through their networks. Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but

EXHIBIT A

15-30784-hcm Doc#147-1 Filed 07/09/15 Entered 07/09/15 13:40:24 Exhibit A Pg 1 of 2

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does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.

EXHIBIT A

15-30784-hcm Doc#147-1 Filed 07/09/15 Entered 07/09/15 13:40:24 Exhibit A Pg 2 of 2

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Kendra Gradney Certified Bankruptcy Assistant Jackson Walker L.L.P. 100 Congress Avenue, Suite 1100 Austin, Texas 78701 O: (512) 236-2313 F: (512) 236-2002 [email protected] www.jw.com

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The information contained in this E-MAIL message may be confidential and/or privileged. This E-MAIL message is intended to be reviewed initially by only the individual(s) named above. If the reader of this E-MAIL message is not the intended recipient or a representative of the intended recipient, you are hereby notified that any review, dissemination or copying of this E-MAIL message or the information contained herein is prohibited. If you have received this E-MAIL message in error, please immediately notify the sender by e-mail or by telephone and return this E-MAIL message to the sender. Thank you.

EXHIBIT B

15-30784-hcm Doc#147-2 Filed 07/09/15 Entered 07/09/15 13:40:24 Exhibit B Pg 1 of 3

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Gradney, Kendra

From: Thomas, Carole

Sent: Friday, June 26, 2015 5:07 PM

To: [email protected]; [email protected]

Cc: [email protected]; Wertz, Jennifer; Tomasco, Patty; Gradney,

Kendra

Subject: RE: In re EPCH ("Debtor") 15-30784

Counsel:

Subject to the Debtor’s Responses and Objections to Rule 2004 Examination and Subpoena Duces Tecum served upon

UMC on June 24, 2015, below is a link to the Debtor’s additional production, which has been Bates labeled EPCH 02081 –

03845.

https://jacksonwalker.sharefile.com/d-sc8d2d460837449a9

Please confirm receipt of the additional production.

Thank you.

Carole C. Thomas | Paralegal 100 Congress Ave Ste 1100 | Austin TX | 78701-4042 T: 512.236.2342 | F: 512.391.2163 [email protected] | www.jw.com

Austin | Dallas | Fort Worth | Houston | San Angelo | San Antonio

DALLAS | AUSTIN | HOUSTON | SAN ANTONIO | FORT WORTH | SAN ANGELO | TEXARKANA


From: Gradney, Kendra

Sent: Wednesday, June 24, 2015 6:47 PM

To: [email protected]; [email protected] Cc: [email protected]; Wertz, Jennifer; Thomas, Carole; Tomasco, Patty

Subject: In re EPCH ("Debtor") 15-30784

Counsel:

EXHIBIT B


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Attached is the Debtor’s Responses and Objections to Rule 2004 Examination and Subpoena Duces Tecum

(“Responses”). Subject to the Debtor’s Responses, below is a link to the Debtor’s production, which has been Bates

labeled EPCH 00001-02080.

https://jacksonwalker.sharefile.com/d-sf43b265d0d34cedb

Please confirm receipt of the Debtor’s Responses and production.

Thank you.

Kendra Gradney Certified Bankruptcy Assistant Jackson Walker L.L.P. 100 Congress Avenue, Suite 1100 Austin, Texas 78701 O: (512) 236-2313 F: (512) 236-2002 [email protected] www.jw.com

DALLAS | AUSTIN | HOUSTON | SAN ANTONIO | FORT WORTH | SAN ANGELO | TEXARKANA


EXHIBIT B


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Gradney, Kendra

From: Thomas, Carole

Sent: Wednesday, July 08, 2015 3:40 PM

To: '[email protected]'; '[email protected]'

Cc: '[email protected]'; Wertz, Jennifer; Tomasco, Patty; Gradney,

Kendra

Subject: In re EPCH ("Debtor") 15-30784

Counsel:

Subject to the Debtor’s Responses and Objections to Rule 2004 Examination and Subpoena Duces Tecum served upon

UMC on June 24, 2015, below is a link to the Debtor’s additional production, which has been Bates labeled EPCH 03845 -

04320.

https://jacksonwalker.sharefile.com/d-s4233bcd64034c319

Please confirm receipt of the additional production.

Thank you.

Carole C. Thomas | Paralegal 100 Congress Ave Ste 1100 | Austin TX | 78701-4042 T: 512.236.2342 | F: 512.391.2163 [email protected] | www.jw.com

Austin | Dallas | Fort Worth | Houston | San Angelo | San Antonio

EXHIBIT C

15-30784-hcm Doc#147-3 Filed 07/09/15 Entered 07/09/15 13:40:24 Exhibit C Pg 1 of 1

TEXAS TECH UNIVERSITY

4800 ALBERTA

EL PASO, TX 79905

MEDASSETS, INC.

P.O. BOX 405652

ATLANTA, GA 30384-5652

CARDINAL HLTH MED PROD & SVC

P.O. BOX 730112

DALLAS, TX 75373-0112

AMERISOURCE BERGEN DRUG CORP.

P.O. BOX 100741

PASADENA, CA 91189-0741

ACCREDO HEALTH GROUP, INC.

P.O. BOX 906027

CHARLOTTE, NC 28290-6027

CHILDREN'S HOSPITAL ASSOC. TX

823 CONGRESS AVE., SUITE 1500

AUSTIN, TX 78701-2405

HILL ROM

P.O. BOX 643592

PITTSBURGH, PA 15264-3592

PROLACTA BIOSCIENCE, INC.

757 BALDWIN PARK BLVD.

ATTN: ACCOUNTS RECEIVABLE

CITY OF INDUSTRY, CA 91746

ABBOTT LABS

P.O. BOX 100997

ATLANTA, GA 30384

DEPT OF HEALTH & HUMAN SER

HHSC - ARTS

P.O. BOX 149055

AUSTIN, TX 78714-9055

NOVA BIOMEDICAL CORP.

P.O. BOX 983115

BOSTON, MA 02298-3115

INO THERAPEUTICS, LLC

P.O. BOX 9001

53 FRONTAGE RD., 3RD FLOOR

HAMPTON, NJ 08827-9001

CERNER CORPORATION

P.O. BOX 412702

KANSAS CITY, MO 64141-2702

BUNNELL INCORPORATED

436 SOUTH LAWNDALE DR.

SALT LAKE CITY, UT 84115

PASO DEL NORTE HIE

221 N. KANSAS ST., STE. 1900

EL PASO, TX 79901

JOHNSON & JOHNSON/ETHICON

5972 COLLECTIONS CENTER

CHICAGO, IL 60693

INTEGRA LIFESCIENCES SALES LLC

P.O. BOX 404129

ATLANTA, GA 30384-4129

STAPLES ADVANTAGE

DEPT DAL

P.O. BOX 83689

CHICAGO, IL 60696-3689

TMHP FINANCIAL DEPARTMENT

12357-B RIATA TRACE PKWY

SUITE 100

AUSTIN, TX 78727

SMITH AND NEPHEW, INC.

P.O. BOX 951605

DALLAS, TX 75395-1605

BECKMAN COULTER, INC.

DEPT CH 10164

PALATINE, IL 60055-0164

FEDERAL REPUBLIC OF GERMANY

OFFICE OF DEFENSE ADMIN.

11150 SUNRISE VALLEY DR.

RESTON, VA 20191

KLS MARTIN L P

P.O. BOX 204322

DALLAS, TX 75320-4322

ABBOTT NUTRITION

75 REMITTANCE DR., STE 1310


VAPOTHERM, INC.

22 INDUSTRIAL DRIVE

EXETER, NH 03833

SUPERIOR HEALTH

P.O. BOX 3000

FARMINGTON, MO 63640

AETNA US HEALTHCARE

P.O. BOX 14079

LEXINGTON, KY 40512

15-30784-hcm Doc#147-4 Filed 07/09/15 Entered 07/09/15 13:40:24 Service List Pg 1 of 2

BIOMET MICROFIXATION

75 REMITTANCE DR.

SUITE 3283


GULF COAST PHARMACEUTICAL PLU

P.O. BOX 6704

GREENVILLE, SC 29606

SUTURE EXPRESS

P.O. BOX 842806

KANSAS CITY, MO 64184-2806

UMC OF EL PASO

4815 ALAMEDA AVE.

EL PASO, TX 79905

CHRISTOPHER A. WARD

POLSINELLI PC

222 DELAWARE AVENUE, SUITE 1101

WILMINGTON, DE 19801

JAMES H. BILLINGSLEY

POLSINELLI, PC

2501 N HARDWOOD, SUITE 1900

DALLAS, TEXAS 75201

STRYKER ORTHOPAEDICS

PURKEY & ASSOCIATES

5050 CASCADE RD., SE, SUITE A

GRAND RAPIDS, MI 49546

UNITED STATES TRUSTEE

KEVIN EPSTEIN, TRIAL ATTORNEY

615 E HOUSTON STREET, ROOM 533

SAN ANTONIO, TEXAS 78205

INTERNAL REVENUE SERVICE

CENTRALIZED INSOLVENCY OFFICE

PO BOX 7346

PHILADELPHIA, PA 19101-7346

UNITED STATES ATTORNEY

700 E SAN ANTONIO, SUITE 200

EL PASO, TEXAS 79901

UNITED STATES ATTORNEY

GENERAL

DEPARTMENT OF JUSTICE

950 PENNSYLVANIA AVENUE NW

WASHINGTON, D.C. 20530

TEXAS COMPTROLLER OF PUBLIC

ACCOUNTS

REVENUE ACCOUNTING DIVISION –

BANKRUPTCY SECTION

PO BOX 13258

AUSTIN, TEXAS 78711

TEXAS WORKFORCE COMMISSION

TEC BUILDING – BANKRUPTCY

101 E. 15TH STREET

AUSTIN, TEXAS 78778

HAL F. MORRIS

ASHLEY F. BARTRAM

CHRISTOPHER S. MURPHY

TEXAS ATTORNEY GENERAL’S OFFICE

BANKRUPTCY & COLLECTIONS DIVISION

PO BOX 12548 – MC 008

AUSTIN, TEXAS 78711-2548

LOUIS R. STRUBECK, JR.

ELIZABETH N. BOYDSTON

NORTON ROSE FULBRIGHT US LLP

2200 ROSS AVENUE, SUITE 3600

DALLAS, TEXAS 75201

Kimberly A. Walsh, Esq.

Sherri K. Simpson, Paralegal

Attorney General’s Office

Bankruptcy & Collections Division

PO Box 12548

Austin, Texas 78711-2548

Morton R. Branzburg, Esquire

Klehr | Harrison | Harvey | Branzburg,

LLP

1835 Market Street, Suite 1400

Philadelphia, PA 19103

Robert A. Simon

Whitake Chalk Swindle & Schwartz, PLLC

301 Commerce Street, Suite 2500

Fort Worth, Texas 76102

Catherine A. Keith

Darrell W. Cook & Associates

A Professional Corporation

One Meadows Building

5005 Greenville Avenue, Suite 200

Dallas, Texas 75206

County of El Paso

c/o Wiley James, III

James & Haugland, P.C.

609 Montana Ave.

El Paso, Texas 79902

Samuel C. Wisotzkey

Kohner, Mann & Kailas, P.C.

Washington Building

Barnabas Business Center

4650 N. Port Washington Rd.

Milwaukee, WI 53212

13432185v.1 145048/00008

15-30784-hcm Doc#147-4 Filed 07/09/15 Entered 07/09/15 13:40:24 Service List Pg 2 of 2

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