`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Civil Action No. 6:19-CV-600-ADA
`
`JURY TRIAL DEMANDED
`
`§§§§§§§§§§§
`
`
`
`
`
`
`
`GREEN MOUNTAIN GLASS, LLC and
`CULCHROME, LLC,
`
`
`Plaintiffs/Counter-Defendants,
`
`v.
`
`
`OWENS-ILLINOIS, INC. and OWENS-
`BROCKWAY GLASS CONTAINER INC.,
`
`
`Defendants/Counterclaimants.
`
`
`
`NOTICE OF SUGGESTION OF PENDENCY OF
`BANKRUPTCY AND AUTOMATIC STAY OF PROCEEDINGS
`
`PLEASE BE ADVISED that on January 6, 2020, Paddock Enterprises, LLC, successor by
`
`merger to Owens-Illinois, Inc. (the “Debtor”), commenced a bankruptcy case in the United States
`
`Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”) by filing a voluntary
`
`petition for relief under chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101-1532,
`
`et seq. (the “Bankruptcy Code”). The Debtor’s chapter 11 case is now pending before The
`
`Honorable Judge Laurie Selber Silverstein, United States Bankruptcy Judge, under the caption In
`
`re Paddock Enterprises, LLC, Chapter 11 Case No. 20-10028 (LSS).
`
`PLEASE BE FURTHER ADVISED that pursuant to Section 362 of the Bankruptcy Code,
`
`as of the commencement of the Debtor’s chapter 11 case, the above-captioned action has been
`
`automatically stayed as against the Debtor-defendant. Section 362 of the Bankruptcy Code
`
`provides, in part, that the filing of a petition to commence a chapter 11 case operates as a stay of
`
`“the commencement or continuation, including the issuance or employment of process, of a
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`judicial, administrative, or other action or proceeding against the debtor that was or could have
`
`1
`
`O-I Glass, Inc.
`Exhibit 1065
`Page 001
`
`
`
`Case 6:19-cv-00600-ADA Document 25 Filed 01/08/20 Page 2 of 3
`
`been commenced before the commencement of the case under [chapter 11], or to recover a claim
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`against the debtor that arose before the commencement of the case under [chapter 11]” and “any
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`act to collect, assess, or recover a claim against the debtor that arose before the commencement of
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`the [bankruptcy] case. . . .” 11 U.S.C. §§ 362(a)(1) & (6).
`
`PLEASE BE FURTHER ADVISED that additional information regarding the status of the
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`Debtor’s chapter 11 case may be obtained by reviewing the docket of the chapter 11 case, available
`
`electronically at https://ecf.deb.uscourts.gov (PACER login and password required) or free of
`
`charge via the website maintained by the Debtor’s proposed claims and noticing agent, Prime Clerk
`
`LLC, at https://cases.primeclerk.com/paddock or by contacting the proposed bankruptcy counsel
`
`for the Debtor: (i) Latham & Watkins LLP, 355 South Grand Avenue, Suite 100, Los Angeles,
`
`California 90071 (Attn: Jeffery E. Bjork, Esq., Christina M. Craige, Esq., Helena G. Tseregounis,
`
`Esq.), and (ii) Richards, Layton & Finger, P.A., One Rodney Square, 920 N. King Street,
`
`Wilmington, Delaware 19801 (Attn: Michael J. Merchant, Esq.).
`
`2
`
`O-I Glass, Inc.
`Exhibit 1065
`Page 002
`
`
`
`Case 6:19-cv-00600-ADA Document 25 Filed 01/08/20 Page 3 of 3
`
`Dated: January 8, 2020
`
`
`
`
`
`
`
`
`
` Respectfully submitted,
`
`
`/s/ Brian C. Nash
`Brian C. Nash (Texas 24051103)
`PILLSBURY WINTHROP SHAW PITTMAN LLP
`401 Congress Avenue, Suite 1700
`Austin, TX 78701
`T: (512) 580-9600; F: (512) 580-9601
`E: brian.nash@pillsburylaw.com
`
`Maximilian A. Grant (lead attorney)
`Adam M. Greenfield
`LATHAM & WATKINS LLP
`555 Eleventh St NW, Suite 1000
`Washington, DC 20004
`T: (202) 637-2200; F: (312) 637-2201
`E: max.grant@lw.com
`E: adam.greenfield@lw.com
`
`Alex Grabowski
`LATHAM & WATKINS LLP
`330 N Wabash Ave, Suite 2800
`Chicago, IL 60611
`T: (312) 876-7700; F: (312) 993-9767
`E: alex.grabowski@lw.com
`
`Attorneys for Defendants Owens-Illinois, Inc.
`and Owens-Brockway Glass Container Inc.
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on January 8, 2020, a true and correct copy of the foregoing document
`
`was served on all counsel of record via the Court’s CM/ECF Electronic Filing System
`
`
`
`
`
`
`
`
`
`
`/s/ Brian C. Nash
`Brian C. Nash
`
`
`
`3
`
`O-I Glass, Inc.
`Exhibit 1065
`Page 003
`
`
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