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42403.00006

Requested Hearing Date and Time: July 10, 2020 at 10:00 AM (ET) Requested Objection Deadline: July 9, 2020 at 2:00 PM (ET)

Dennis F. Dunne, Esq. Andrew M. Leblanc, Esq. Tyson Lomazow, Esq. Lauren C. Doyle, Esq. MILBANK LLP 55 Hudson Yards New York, NY 10001 (212) 530-5000 Counsel to Debtors and Debtors in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) OneWeb Global Limited, et al. ) Case No. 20-22437 (RDD) ) ) (Jointly Administered)

Debtors.1 ) )

NOTICE OF HEARING ON DEBTORS’ MOTION TO SHORTEN NOTICE WITH RESPECT TO (1) DEBTORS’ (I) SUPPLEMENTAL MOTION FOR ENTRY OF AN ORDER (A) AUTHORIZING THE DEBTORS TO ENTER INTO AND PERFORM

UNDER A PLAN SUPPORT AGREEMENT WITH THE SUCCESSFUL BIDDER IN CONNECTION WITH THE DEBTORS’ MOTION TO AUTHORIZE THE SALE, FREE

AND CLEAR OF ALL LIENS, CLAIMS, INTERESTS & ENCUMBRANCES AND (B) GRANTING RELATED RELIEF AND (II) PRELIMINARY REPLY TO CURE, ASSUMPTION & ASSIGNMENT, & SALE OBJECTIONS AND (2) DEBTORS’

MOTION FOR AUTHORIZATION TO AMEND THE EXISTING DIP FACILITY

1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, if

any, are: OneWeb Global Limited (N/A); OneWeb Holdings LLC (5429); OneWeb Communications Limited (9487); WorldVu Satellites Limited (7802); WorldVu Development LLC (9067); WorldVu JV Holdings LLC (N/A); 1021823 B.C. LTD (8609); Network Access Associates Limited (8566); OneWeb Limited (8662) WorldVu South Africa (Pty) Ltd. (1867); OneWeb Chile SpA (2336); WorldVu Australia Pty Ltd. (5436); WorldVu Unipessoal Lda. (2455); OneWeb Norway AS (0209); OneWeb ApS (9191); OneWeb Network Access Holdings Limited (8580); OneWeb G.K. (1396); OneWeb Ltd (8661); WorldVu Mexico S. DE R. L. DE C.V. (1234). The Debtors’ headquarters is located at 195 Wood Lane, West Works Building, 3rd Floor, London, W12 7FQ, UK.

20-22437-rdd Doc 372 Filed 07/06/20 Entered 07/06/20 15:22:00 Main Document Pg 1 of 15

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PLEASE TAKE NOTICE that OneWeb Global Limited and its above-captioned affiliates, as debtors and debtors in possession (collectively, the “Debtors”), have filed a motion (the “Motion to Shorten”) for entry of an order, substantially in the form attached to the Motion to Shorten as Exhibit A, authorizing the rejection of a certain non-residential real property lease, abandonment of certain personal property, and seeking further relief.

PLEASE TAKE FURTHER NOTICE that the Debtors will request a hearing on the annexed Motion to Shorten for entry of an order pursuant to Rule 9006(c) of the Federal Rules of Bankruptcy Procedure, shortening the notice period and setting the date and time for a hearing on (1) Debtors’(I) Supplemental Motion for Entry of an Order (A) Authorizing the Debtors to Enter Into and Perform Under a Plan Support Agreement with the Successful Bidder in Connection with the Debtors’ Motion to Authorize the Sale, Free and Clear of All Liens, Claims, Interests & Encumbrances and (B) Granting Related Relief and (II) Preliminary Reply to Cure, Assumption & Assignment, & Sale Objections (the “PSA Motion”) and (2) Debtors’ Motion for Authorization to Amend the Existing DIP Facility (the “Amended DIP Motion,” and together with the PSA Motion, the “Motions”) before the Honorable Robert D. Drain, United States Bankruptcy Judge on July 10, 2020 at 10:00 a.m. (Prevailing Eastern Time).

PLEASE TAKE FURTHER NOTICE that pursuant to the Bankruptcy Court’s General Order M-543, dated March 20, 2020 (“General Order M-543”), the Hearing will be conducted telephonically. Parties wishing to participate in the Hearing should reference General Order M-543 for further instructions on how to make a telephonic appearance.

PLEASE TAKE FURTHER NOTICE that the Hearing may be continued or adjourned from time to time without further notice other than an announcement of the adjourned date or dates at the Hearing or at a later hearing. The Debtors will file an agenda before the Hearing, which may modify or supplement the motions to be heard at the Hearing.

PLEASE TAKE FURTHER NOTICE that you need not appear at the Hearing if you do not object to the relief requested in the Motion to Shorten.

PLEASE TAKE FURTHER NOTICE that if you do not want the Bankruptcy Court to grant the relief requested in the Motion to Shorten, or if you want the Bankruptcy Court to consider your views on the Motion to Shorten, then you or your attorney must attend the Hearing. If you or your attorney do not take these steps, the Bankruptcy Court may decide that you do not oppose the relief sought in the Motion to Shorten and may enter orders granting the relief requested in the Motion to Shorten.

PLEASE TAKE FURTHER NOTICE that objections or responses, if any, to the Motion must comply with the Federal Rules of Bankruptcy Procedure and the Local Bankruptcy Rules for the Southern District of New York. The Debtors are seeking that objections or responses, if any, to the Motion must be served in compliance with the Order Implementing Certain Notice and Case Management Procedures [Docket No. 44] on or before July 9, 2020 at 2:00 p.m. (Prevailing Eastern Time).


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PLEASE TAKE FURTHER NOTICE that if you do not timely file and serve a written objection to the relief requested in the Motion to Shorten, the Bankruptcy Court may deem any opposition waived, treat the Motion to Shorten as conceded, and enter an order granting the relief requested in the Motion to Shorten without further notice or hearing.

Dated: July 6, 2020 New York, New York /s/ Lauren C. Doyle _

Dennis F. Dunne, Esq. Andrew M. Leblanc, Esq. Tyson M. Lomazow, Esq. Lauren C. Doyle, Esq. MILBANK LLP 55 Hudson Yards New York, NY 10001 Telephone: (212) 530-5000 Facsimile: (212) 530-5219 Email: [email protected] [email protected]

[email protected] [email protected]

Counsel for Debtors and Debtors in Possession


Requested Hearing Date and Time: July 10, 2020 at 10:00 AM (ET) Requested Objection Deadline: July 9, 2020 at 2:00 PM (ET)

Dennis F. Dunne, Esq. Andrew M. Leblanc, Esq. Tyson Lomazow, Esq. Lauren C. Doyle, Esq. MILBANK LLP 55 Hudson Yards New York, NY 10001 (212) 530-5000 Counsel to Debtor and Debtor in Possession UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) OneWeb Global Limited, et al. ) Case No. 20-22437 (RDD) ) ) (Jointly Administered)

Debtors.1 ) )

DEBTORS’ MOTION TO SHORTEN NOTICE WITH RESPECT TO (1)

DEBTORS’ (I) SUPPLEMENTAL MOTION FOR ENTRY OF AN ORDER (A) AUTHORIZING THE DEBTORS TO ENTER INTO AND PERFORM UNDER A PLAN

SUPPORT AGREEMENT WITH THE SUCCESSFUL BIDDER IN CONNECTION WITH THE DEBTORS’ MOTION TO AUTHORIZE THE SALE, FREE AND CLEAR OF ALL LIENS, CLAIMS, INTERESTS & ENCUMBRANCES AND (B) GRANTING RELATED RELIEF AND (II) PRELIMINARY REPLY TO CURE, ASSUMPTION &

ASSIGNMENT, & SALE OBJECTIONS AND (2) DEBTORS’ MOTION FOR AUTHORIZATION TO AMEND THE EXISTING DIP FACILITY

1 The Debtors in these cases, along with the last four digits of each Debtor’s federal tax identification number, if

any, are: OneWeb Global Limited (N/A); OneWeb Holdings LLC (5429); OneWeb Communications Limited (9487); WorldVu Satellites Limited (7802); WorldVu Development LLC (9067); WorldVu JV Holdings LLC (N/A); 1021823 B.C. LTD (8609); Network Access Associates Limited (8566); OneWeb Limited (8662) WorldVu South Africa (Pty) Ltd. (1867); OneWeb Chile SpA (2336); WorldVu Australia Pty Ltd. (5436); WorldVu Unipessoal Lda. (2455); OneWeb Norway AS (0209); OneWeb ApS (9191); OneWeb Network Access Holdings Limited (8580); OneWeb G.K. (1396); OneWeb Ltd (8661); WorldVu Mexico S. DE R. L. DE C.V. (1234). The Debtors’ headquarters is located at 195 Wood Lane, West Works Building, 3rd Floor, London, W12 7FQ, UK.


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The above-captioned debtors and debtors in possession (the “Debtors”) respectfully state

as follows in support of this motion (the “Motion to Shorten”):

Relief Requested

1. Pursuant to Bankruptcy Rule 9006(c) and Local Rule 9006-1(b), the Debtors, and

consistent with the Bidding Procedures (as defined below), seek entry of an order, substantially in

the form attached hereto as Exhibit A, shortening the notice period with respect to (1) Debtors’(I)

Supplemental Motion for Entry of an Order (A) Authorizing the Debtors to Enter Into and Perform

Under a Plan Support Agreement with the Successful Bidder in Connection with the Debtors’

Motion to Authorize the Sale, Free and Clear of All Liens, Claims, Interests & Encumbrances and

(B) Granting Related Relief and (II) Preliminary Reply to Cure, Assumption & Assignment, & Sale

Objections (the “PSA Motion”) and (2) Debtors’ Motion for Authorization to Amend the Existing

DIP Facility (the “Amended DIP Motion,” and together with the PSA Motion, the “Motions”),2

scheduling a hearing on the Motions on July 10, 2020 at 10:00 a.m. (prevailing Eastern Time)

(i.e., the Sale Hearing) and scheduling an objection deadline on July 9, 2020 at 2:00 p.m.

(prevailing Eastern Time).

Jurisdiction and Venue

2. This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334

and the Amended Standing Order of Reference from the United States District Court for the

Southern District of New York, dated January 31, 2012. The Debtors confirm their consent,

pursuant to rule 7008 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), to

the entry of a final order by the Court to the extent that it is later determined that the Court, absent

2 Capitalized terms used but not defined herein shall have the respective meaning assigned to such terms in the

Motions and/or the First Day Declaration.


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consent of the parties, cannot enter final orders or judgments in connection with the relief sought

by this Motion to Shorten consistent with Article III of the United States Constitution.

3. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408 and 1409.

4. The bases for the relief requested herein are sections 105, 363, 364, 365, and 554

of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (as amended, the “Bankruptcy

Code”), Bankruptcy Rules 2002(a), 6004, 9006(c), and 9007, and rule 9006-1 of the Local

Bankruptcy Rules for the Southern District of New York (the “Local Rules”).

Background

5. On March 27, 2020 (the “Petition Date”), each of the Debtors filed a voluntary

petition for relief under chapter 11 of the Bankruptcy Code.

6. The Debtors continue to operate their businesses and manage their properties as

debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. The Debtors’

cases are being jointly administered pursuant to Bankruptcy Rule 1015(b) and the Order Directing

Joint Administration of Chapter 11 Cases [Docket No. 29] entered by the Court.

7. On April 16, 2020, the United States Trustee for the Southern District of New York

appointed an official committee of unsecured creditors (the “Official Committee”). See Notice of

Appointment of Official Committee of Unsecured Creditors [Docket No. 67]. No trustee or

examiner has been appointed in these cases.

8. On April 29, 2020, the Court entered the Order (A) Approving Bidding Procedures,

(B) Scheduling an Auction and Sale Hearing and Approving Form and Manner of Notice Thereof,

(C) Approving Assumption and Assignment Procedures and Form and Manner of Notice Thereof;

and (D) Granting Related Relief [Docket No. 104] (the “Bidding Procedures Order”).

9. The Bidding Procedures Order, authorized certain procedures (the “Bidding

Procedures”) to be used in connection with the proposed sale(s) (whether pursuant to section 363


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of the Bankruptcy Code or a chapter 11 plan of reorganization) of some or all of the assets or

equity interests of one or more of the Debtors (the “Sale(s)”). Bidding Procedures Order, Ex. A.

The Bidding Procedures provide that, following selection of the successful bid, a hearing will take

place to approve the sale to the successful bidder pursuant either to the applicable purchase

agreement or, in the case of a successful bid to acquire the Debtors’ assets or equity interests

pursuant to a plan of reorganization, a plan support agreement. Bidding Procedures Order, Ex. A

§VII.

10. The Bidding Procedures Order also provides that, the hearing to approve the Sale(s)

(the “Sale Hearing”) shall take place on July 10, 2020 at 10:00 a.m. (prevailing Eastern Time)

before the Honorable Robert D. Drain, United States Bankruptcy Judge, in the United States

Bankruptcy Court for the Southern District of New York, located at 300 Quarropas Street, White

Plains, New York 10601 in accordance with the Order Implementing Certain Notice and Case

Management Procedures [Docket No. 44] (the “Case Management Order”).

11. On July 2, 2020, in accordance with the Bidding Procedures, the Debtors

determined that the bid submitted by BidCo 100 Limited (“BidCo” or “Plan Sponsor”)3 pursuant

to the terms of the Plan Support Agreement (the “PSA”) to acquire 100% of the newly issued

common stock of the Reorganized Company Party4 through a chapter 11 plan of reorganization

(i.e., as a going concern) (the “Transaction”) was the highest and best offer that had been received.5

3 BidCo’s shareholders are the United Kingdom Secretary of State for Business, Energy and Industrial Strategy

(“HMG”) and Bharti Global Limited (“Bharti”). 4 Either the reorganized OneWeb Global Limited or such other Debtor as mutually agreed between the Plan

Sponsor and the Debtors. See PSA Motion. 5 Additional information regarding the Debtors’ business, capital structure, and the circumstances leading to the

filing of these cases is set forth in the Declaration of Thomas Whayne in Support of Chapter 11 Petitions and First Day Pleadings [Docket No. 3] (the “First Day Declaration”).


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Requested Belief Should Be Granted

12. Among other things, the PSA commits the Plan Sponsor to step in as a lender under

the Debtors’ post-petition term loan facility (the “DIP Facility”), to provide new money funding

to the Debtors through (i) additional commitments of approximately $65 million under the DIP

Facility (as amended on the terms described herein) (ii) taking assignment of, and funding,

approximately $45 million of the currently unfunded new-money commitments under the DIP

Facility, and (iii) modifying certain conditions to funding and milestones that benefit the Debtors.

It will, among other things, provide the Debtors with the liquidity needed to bridge to confirmation

of a plan of reorganization and a successful closing of the Transaction. This additional funding

will be implemented through amendments to the DIP Facility, for which the Debtors’ are seeking

approval pursuant to the Amended DIP Motion.

13. Importantly, the Debtors have an immediate need for the additional funding. The

commitments of the Plan Sponsor under its successful bid are contingent on the Debtors

maintaining their joint venture interests in the JV. The Debtors’ understand that the JV requires

$32.2 million in payments by no later than mid-July, 2020, and an additional $9.6 million in August

2020, and $9.1 million in September 2020. Preiss Declaration ¶ 16. Notably, the lead lender under

the existing DIP Facility has indicated to the Debtors’ advisors that (i) the lenders under the current

DIP Facility do not wish to fund the amounts the Debtors’ estimated would be necessary to operate

through consummation of the Debtors’ contemplated plan of reorganization, and (ii) the lead

lender anticipates consenting to the assignment and other requisite modifications to the DIP

Facility as documented in the PSA. Id.

14. Absent the Plan Sponsors’ additional funding commitments, the Debtors might not

have sufficient funds to make such payments to the JV, let alone seek confirmation of a chapter 11

plan and ultimately consummate the Transactions. Accordingly, the Plan Sponsor has committed


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to provide such funding by no later than July 13, 2020. The Plan Sponsors’ commitment to provide

the new money funding under the DIP Facility is conditioned upon authorization for the Debtors

to enter into the PSA and approval thereof. Therefore, it is imperative that the Court consider the

PSA Motion and the Amended DIP Motion, which is contingent on entry of the PSA Motion at

the July 10, 2020 hearing.

15. The Bidding Procedures Order specifically contemplates that a plan support

agreement may be heard at the Sale Hearing. Bidding Procedures Order at Sec. VII. In addition,

pursuant to paragraph 26 of the Order (I) Authorizing Debtors to Obtain Postpetition Secured

Financing, (II) Granting Liens and Providing Superpriority Administrative Expense Claims, (III)

Modifying the Automatic Stay, and (IV) Granting Related Relief [Docket No. 121], the Debtors are

permitted to seek modifications or amendments to the Loan Documents (as defined therein) on 3

business days’ notice. Bankruptcy Rule 9006(c) provides that “when an act is required or allowed

to be done at or within a specified time by these rules or by a notice given thereunder or by order

of court, the court for cause shown may in its discretion with or without motion or notice order the

period reduced.” Fed. R. Bankr. P. 9006(c). Similarly, Local Rule 9006-1(b) allows the court to

order shortened notice of motions.

16. The Debtors believe that sufficient cause exists to shorten the notice period for a

hearing on the Motions and that parties in interest had sufficient notice to anticipate the timing of

the relief being sought. Absent the shortened notice requested herein, the Plan Sponsor could seek

to terminate its commitments under the PSA, which in turn would gravely undermine the Debtors’

restructuring efforts. Such an outcome would be detrimental to all stakeholders in these cases.

17. The shortened notice period requested herein is appropriate under the

circumstances.


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18. Based on the foregoing, the Debtors respectfully submit that cause exists to shorten

the notice period with respect to the Motions.

Motion Practice

19. This Motion to Shorten includes citations to the applicable rules and statutory

authorities upon which the relief requested herein is predicated and a discussion of their application

to this Motion to Shorten. Accordingly, the Debtors submit that the Motion to Shorten satisfies

Local Rule 9013-1(a).

Notice

20. Notice of this Motion to Shorten will be provided in accordance with the procedures

set forth in the Case Management Order.

No Prior Request

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

this or any other court.

[Remainder Of Page Intentionally Left Blank]


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WHEREFORE, the Debtors respectfully request entry of an order, substantially in the form

attached hereto as Exhibit A, granting the relief requested herein and granting such other relief as

is just and proper.

Dated: July 6, 2020 New York, New York

/s/ Lauren C. Doyle _ Dennis F. Dunne, Esq. Andrew M. Leblanc, Esq. Tyson M. Lomazow, Esq. Lauren C. Doyle, Esq. MILBANK LLP 55 Hudson Yards New York, NY 10001 Telephone: (212) 530-5000 Facsimile: (212) 530-5219 Email: [email protected] [email protected]

[email protected] [email protected]

Counsel for the Debtors and Debtors in Possession


Exhibit A

Proposed Order


UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) OneWeb Global Limited, et al. ) Case No. 20-22437 (RDD) ) ) (Jointly Administered) Debtors.1 ) )

ORDER SHORTEN NOTICE WITH RESPECT TO (1) DEBTORS’ (I)

SUPPLEMENTAL MOTION FOR ENTRY OF AN ORDER (A) AUTHORIZING THE DEBTORS TO ENTER INTO AND PERFORM UNDER A PLAN SUPPORT

AGREEMENT WITH THE SUCCESSFUL BIDDER IN CONNECTION WITH THE DEBTORS’ MOTION TO AUTHORIZE THE SALE, FREE AND CLEAR OF ALL

LIENS, CLAIMS, INTERESTS & ENCUMBRANCES AND (B) GRANTING RELATED RELIEF AND (II) PRELIMINARY REPLY TO CURE, ASSUMPTION &

ASSIGNMENT, & SALE OBJECTIONS AND (2) DEBTORS’ MOTION FOR AUTHORIZATION TO AMEND THE EXISTING DIP FACILITY

Upon the motion (the “Motion to Shorten”)2 of the above-captioned debtors and debtors in

possession (collectively, the “Debtors”) for entry of an order (this “Order”), pursuant to Rule

9006(c) of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), shortening the

time for notice of the hearing to consider (1) Debtors’(I) Supplemental Motion for Entry of an

Order (A) Authorizing the Debtors to Enter Into and Perform Under a Plan Support Agreement

with the Successful Bidder in Connection with the Debtors’ Motion to Authorize the Sale, Free and

Clear of All Liens, Claims, Interests & Encumbrances and (B) Granting Related Relief and (II)

1 The Debtors, along with the last four digits of each Debtor’s federal tax identification number, if any, are:

OneWeb Global Limited (N/A); OneWeb Holdings LLC (5429); OneWeb Communications Limited (9487); WorldVu Satellites Limited (7802); WorldVu Development LLC (9067); WorldVu JV Holdings LLC (N/A); 1021823 B.C. LTD (8609); Network Access Associates Limited (8566); OneWeb Limited (8662) WorldVu South Africa (Pty) Ltd. (1867); OneWeb Chile SpA (2336); WorldVu Australia Pty Ltd. (5436); WorldVu Unipessoal Lda. (2455); OneWeb Norway AS (0209); OneWeb ApS (9191); OneWeb Network Access Holdings Limited (8580); OneWeb G.K. (1396); OneWeb Ltd (8661); WorldVu Mexico S. DE R. L. DE C.V. (1234). The Debtors’ headquarters are located at 195 Wood Lane, West Works Building, 3rd Floor, London, W12 7FQ, UK.

2 Capitalized terms used in this Order and not defined herein have the meanings given to such terms in the Motion to Shorten.


2

Preliminary Reply to Cure, Assumption & Assignment, & Sale Objections (the “PSA Motion”) and

(2) Debtors’ Motion for Authorization to Amend the Existing DIP Facility (the “Amended DIP

Motion,” and together with the PSA Motion, the “Motions”), as more fully set forth in the Motion

to Shorten; and this Court having jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and

1334 and the Amended Standing Order of Reference from the United States District Court for the

Southern District of New York, dated December 1, 2016; and this Court having found that this is a

core proceeding pursuant to 28 U.S.C. § 157(b)(2), and that this Court may enter a final order

consistent with Article III of the United States Constitution; and this Court having found that venue

of this proceeding and the Motion to Shorten in this district is proper pursuant to 28 U.S.C. §§

1408 and 1409; and this Court having found that the relief requested in the Motion to Shorten is

in the best interests of the Debtors’ estates, their creditors, and other parties in interest; and this

Court having found that the Debtors provided appropriate notice of the Motion to Shorten and the

opportunity for a hearing under the circumstances; and this Court having determined that the legal

and factual bases set forth in the Motion to Shorten establish just cause for the relief granted herein;

and after due deliberation, IT IS HEREBY ORDERED THAT:

22. The Motion to Shorten is granted as set forth herein.

23. A hearing on the Motions will be held on July 10, 2020 at 10:00 a.m. (prevailing

Eastern Time) (the “Hearing”).

24. Pursuant to the Bankruptcy Court’s General Order M-543, dated March 20, 2020

(“General Order M-543”), the Hearing will be conducted telephonically. Parties wishing to

participate in the Hearing should reference General Order M-543 for further instructions on how

to make a telephonic appearance.


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25. Any responses or objections (collectively, “Objections”) to the Motions must be

made no later than July 9, 2020 at 2:00 p.m. (prevailing Eastern Time).

26. Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Order

are immediately effective and enforceable upon its entry.

27. The Debtors are authorized to take all actions necessary to effectuate the relief

granted in this Order in accordance with the Motion.

28. This Court retains exclusive jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Order.

New York, New York Dated: _____________, 2020

______________________________________ HONORABLE ROBERT D. DRAIN UNITED STATES BANKRUPTCY JUDGE


20-22437-rdd Doc 372 Filed 07/06/20 Entered 07/06/20 15:22 ... · 2. Capitalized terms used in this...

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