Case 17-14463-amc Doc 419 Filed 11/16/17 Entered 11/16/17 09:47:17 Desc Main Document

759 Pages·2017·8.56 MB·English

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EXHIBIT A
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UNITED STATES BANKRUPTCY COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
)
In re: ) Chapter 11
)
Wordsworth Academy, et al.,1 ) Case No. 17-14463 (AMC)
)
Debtors. ) Jointly Administered
)

NOTICE OF (A) ENTRY OF ORDER APPROVING DISCLOSURE STATEMENT AND
SOLICITATION PROCEDURES; (B) DEADLINE FOR CASTING VOTES TO ACCEPT
OR REJECT CHAPTER 11 PLAN; (C) HEARING TO CONSIDER CONFIRMATION
OF CHAPTER 11 PLAN, AND (D) RELATED MATTERS

PLEASE TAKE NOTICE OF THE FOLLOWING:

1. Pursuant to an order dated November 9, 2017 (Docket No. 410, the “Approval
Order”), the United States Bankruptcy Court for the Eastern District of Pennsylvania (the
“Court”) has (a) approved the Disclosure Statement With Respect to the Joint Chapter 11 Plan
Dated as of November 8, 2017 (the “Disclosure Statement”) filed by the above-captioned debtors
and debtors in possession (the “Debtors”) and (b) authorized the Debtors to solicit votes to
accept or reject the Debtors’ Joint Chapter 11 Plan Dated as of November 8, 2017 (as may be
amended, the “Plan”).
2. The Approval Order establishes November 8, 2017 as the Record Date for
determining the holders of prepetition claims entitled to vote to accept or reject the Plan and
establishes 5:00 p.m. on December 8, 2017 as the Voting Deadline for submission of ballots to
accept or reject the Plan (the “Ballots”). Holders of claims entitled to vote to accept or reject the
Plan will receive the following materials: (a) this Notice, (b) a copy of the Approval Order
(without exhibits) to which this Notice corresponds, (c) the Disclosure Statement, (d) the Plan,
and (e) one or more Ballots (and return envelopes) to be used in voting to accept or reject the
Plan (collectively, the “Solicitation Package”). Failure to follow the instructions set forth in the
Ballot may disqualify that Ballot and the vote represented thereby.
3. Holders of (a) unimpaired claims and (b) claims or interests that will receive no
distribution under the Plan are not entitled to vote on the Plan and, therefore, will receive a
notice of non-voting status rather than a Ballot. If you are not entitled to vote to accept or reject
the Plan but believe that you should be entitled to vote to accept or reject the Plan, then you must
serve on the Notice Parties (defined below), file with the Bankruptcy Court on or before
December 8, 2017, a motion for an order pursuant to Bankruptcy Rule 3018(a) (a “Rule 3018(a)
Motion”) temporarily allowing such claim in a different amount for purposes of voting to accept
or reject the Plan and use reasonable efforts to seek a hearing date for such Rule 3018 Motion to

1 The Debtors in these Chapter 11 Cases, along with the last four digits of each Debtor’s federal tax
identification number, are: Wordsworth Academy (9031); Wordsworth CUA 5, LLC (0983); and Wordsworth CUA
10, LLC (5980). Wordsworth Academy has an address at 3300 Henry Ave., Philadelphia, PA 19129.
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be held on or prior to December 12, 2017 or as soon thereafter as reasonable practical. The
Ballot of any creditor filing a Rule 3018(a) Motion shall not be counted unless temporarily
allowed by the Bankruptcy Court for voting purposes, after notice and a hearing.
4. A hearing to consider confirmation of the Plan (the “Confirmation Hearing”) will
be held at the United States Bankruptcy Court for the Eastern District of Pennsylvania, Robert
N.C. Nix, Sr. Federal Courthouse, Courtroom 5, 900 Market Street, Philadelphia, PA 19107 on
December 18, 2017, at 9:30 a.m., prevailing Eastern time. The Confirmation Hearing may be
continued from time to time without further notice other than the announcement of the adjourned
date at the Confirmation Hearing or any continued hearing.
5. Objections, if any, to the confirmation of the Plan must: (a) be in writing;
(b) state the name and address of the objecting party and the nature of the Claim or Interest of
such party; (c) state with particularity the basis and nature of any objection; (d) be filed with the
Court electronically; and (e) be served on the following parties (the “Notice Parties”) no later
than 5:00 p.m., Eastern time, on December 12, 2017 (the “Plan Objection Deadline”):
(i) counsel for the Debtors, Dilworth Paxson LLP, 1500 Market Street, Suite 3500E,
Philadelphia, PA 19102 (Attn: Lawrence G. McMichael); (ii) the Office of The United States
Trustee, Eastern District of Pennsylvania, 833 Chestnut Street, Suite 500, Philadelphia,
Pennsylvania 19107 (Attn: Kevin Callahan); and (iv) Cullen and Dykman, One Riverfront
Plaza, Newark, NJ 07102 (Attn: S. Jason Teele), counsel to the Official Committee of Unsecured
Creditors.
6. Requests for copies of the Disclosure Statement and the Plan (excluding certain
voluminous exhibits thereto) by parties in interest may be made in writing or by telephone to
Debtor’s counsel. If you have any questions regarding this Notice, please call Debtor’s counsel
at [phone].
UNLESS AN OBJECTION IS TIMELY FILED AND SERVED AS PROVIDED
HEREIN, IT MAY NOT BE CONSIDERED AT THE HEARING.

Dated: November 9, 2017 BY ORDER OF THE COURT

/s/ Anne M. Aaronson
DILWORTH PAXSON LLP
Lawrence G. McMichael
Peter C. Hughes
Anne M. Aaronson
1500 Market St., Suite 3500E
Philadelphia, PA 19102
Telephone: [phone]
Facsimile: [phone]

Counsel for the Debtors and Debtors in
Possession

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EXHIBIT B
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DIRECT DIAL NUMBER: Anne M. Aaronson
215-575-7110 [email protected]

November 9, 2017
Re: In re Wordsworth Academy et al., Case No. 17-14463(AMC)
To Whom It May Concern:
On November 9, 2017, the United States Bankruptcy Court for the Eastern District of
Pennsylvania (the “Court”) entered an Order approving: (1) the Disclosure Statement; (2) procedures for
the solicitation and tabulation of votes to accept or reject the Plan; and (3) related notice and objection
procedures in the above-referenced Chapter 11 cases.
You have received this letter and the enclosed materials because you are entitled to vote on the
Plan. The enclosed materials constitute the “Solicitation Package,” which, in addition to this letter,
includes:
(a) a CD-ROM containing the Disclosure Statement (and the Plan as an exhibit thereto);
(b) the Order Approving Solicitation Procedures;
(c) the Confirmation Hearing Notice; and
(d) an appropriate Ballot (together with detailed voting instructions and a pre-addressed,
postage prepaid return envelope).
The Debtors believe that the acceptance of the Plan is in the best interests of the Holders of
Claims against, and Interests in, the Debtors and that any alternative other than Confirmation of the Plan
could result in, among other risks, delays and increased administrative expenses, thereby resulting in
smaller distributions or no distributions on account of Allowed Claims. The Debtors, therefore,
recommend that all entities entitled to vote on the Plan submit a timely Ballot voting to accept the Plan.
The deadline to submit your Ballot is December 8, 2017.
Contact information to answer any questions that you may have regarding the materials in the
Solicitation Package is included on the Ballot. Thank you for your attention to this matter.
Very truly yours,
Anne M. Aaronson
Anne Aaronson
1500 Market Street  Suite 3500E  Philadelphia, PA 19102-2101  215-575-7000  Fax: [phone]
www.dilworthlaw.com  Cherry Hill, NJ  Harrisburg, PA  Wilmington, DE  New York, NY
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EXHIBIT C