IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Transcription

1 IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ADVANTA CORP., et al., 1 Debtors. 2 AC LIQUIDATING TRUST, Plaintiff, v. Defendants Listed Below, Defendant. Chapter 11 Case No (KJC (Jointly Administered NOTICE OF STATUS REPORT REGARDING ADVERSARY PROCEEDINGS COMMENCED BY AC LIQUIDATING TRUST Defendant Name ABC LEGAL SERVICES INC ACXIOM DIGITAL ADAMIYATT, SIMON K ALLIED INTERNATIONAL CREDIT CORP (U.S ALLIED INTERSTATE INC AMBIUS, INC ASCOM HASLER/GE CAP PROG ATLANTA JOURNAL CONSTITUTION AVAYA, INC BERNSTEIN LAW FIRM PC BLOOMBERG FINANCE LP CA, INC CHAMPION SOLUTIONS GROUP COMPTROLLER OF MARYLAND COR-O-VAN RECORDS MANAGEMENT INC CORPORATE EXECUTIVE BOARD The Debtors in these jointly administered chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Advanta Corp. (2070, Advanta Investment Corp. (5627, Advanta Business Services Holding Corp. (4047, Advanta Business Services Corp. (3786, Advanta Shared Services Corp. (7074, Advanta Service Corp. (5625, Advanta Advertising Inc. (0186, Advantennis Corp. (2355, Advanta Mortgage Holding Company (5221, Advanta Auto Finance Corporation (6077, Advanta Mortgage Corp. USA (2654, Advanta Finance Corp. (8991, Advanta Ventures Inc. (5127, BE Corp. (8960, ideablob Corp. (0726, Advanta Credit Card Receivables Corp. (7955, Great Expectations International Inc. (0440, Great Expectations Franchise Corp. (3326, and Great Expectations Management Corp. (3328. PHTRANS/

2 CREATIVE MULTIMEDIA SOLUTIONS DAVIS GRAHAM & STUBBS LLP DEY'S END CONSULTING, LLC E COMMERCE GROUP PRODUCTS, INC ECKARDT AND COMPANY EDGAR, DUNN & COMPANY EMMET, MARVIN & MARTIN, LLP EQUIPMENT INSTALLERS, INC EUREST DINING SERVICES FEDEX FINANCIAL STATEMENT SERVICES, INC FIRST DATA CORPORATION GENESYS TELECOMMUNICATIONS LABS GRAEME K HOWARD GRAYBAR ELECTRIC COMPANY, INC HARLAND HERMAN MILLER OP SPECTRUM INDUSTRIAL MECHANICAL CONTRACTORS, INC JAMES L. MORTON JORDAN LAWRENCE GROUP KELLY SERVICES, INC KONICA MINOLTA BUSINESS SOLUTIONS USA LANGUAGE LINE SERVICES LEXIS-NEXIS LIBERTY PROPERTY LIMITED PARTNERSHIP MANPOWER,INC METROPOLIS PUBLIC RELATIONS INC NELSON, RICHARD M NRI DATA & BUSINESS PRODUCTS, INC O C TANNER OPEN SOLUTIONS, INC PAPER MILL ROAD LLC PECO ENERGY PHILLIPS AND COHEN ASSOCIATES, LTD RGS FINANCIAL INC RICOH ROBINSON & MCELWEE RSA SECURITY INC SCHNADER HARRISON SEGAL & LEWIS, LLP SNELL & WILMER L.L.P SOS STAFFING SERVICES, INC STAPLES BUSINESS ADVANTAGE STAR TRIBUNE SUNGARD AVAILABILITY SERVICES TEK SYSTEMS TELEMANAGEMENT TECHNOLOGIES INC THE MIAMI HERALD THE STAR LEDGER THE ULTIMATE SOFTWARE GROUP, INC PHTRANS/

3 TPG SOFTWARE, INC TREASURER, STATE OF NEW JERSEY VERIZON VISION BENEFITS OF AMERICA ALLIED BARTON SERVICES* ARAMARK CORPORATION* ARDEN REALTY LIMITED PARTNERSHIP* AT&T, INC., ET AL.* BOCA RATON RESORT & CLUB* CORPORATION SERVICE COMPANY* DELAWARE SECRETARY OF STATE* DELOITTE TAX LLP* ESSEX TECHNOLOGY GROUP* EXPERIAN* INTERVOICE, INC.* MARSH USA, INC.* QWEST* STATE OF MICHIGAN DEPARTMENT OF TREASURY* SUNESYS, INC.* TRANSAMERICA LIFE INSURANCE CO.* UNITED STATES POSTAL SERVICE* ADT SECURITY SERVICES INC.** IRON MOUNTAIN DATA PRODUCTS** IRON MOUNTAIN OFF SITE DATA PROTECTION** IRON MOUNTAIN RECORDS MANAGEMENT** JOHN HANCOCK LIFE INSURANCE CO.** PHILADELPHIA NEWSPAPERS, LLC.** RSM MCGLADREY, INC.** AC Liquidating Trust (the Plaintiff, by and through its co-counsel, Drinker Biddle & Reath LLP, Gibbons P.C., and Whiteford Taylor Preston L.L.C., file the following status report on certain adversary proceedings pending in these cases pursuant to the general procedures for adversary proceedings set forth by the United States Bankruptcy Court for the District of Delaware. Categories identified in Exhibits A, B and C are as follows: A: B: List all cases where service has not been completed. Explain why service is incomplete and give the date when you expect to complete service. List all cases where service is complete, but answers are still due. Provide answer due date. * Denotes cases handled by Gibbons P.C. ** Denotes cases handled by Whiteford Taylor Preston L.L.C. PHTRANS/

4 C: D: E: F: G: H: I: J: K: List all cases where service is complete, no answer has been filed, and are making motion or request for Default Judgment. List all adversary cases in which a Settlement Agreement has been filed with the Court. Include the Case and Docket of the Settlement Agreement in your written report. Upon Court verification of appropriate documentation, the listed cases will be dismissed and closed. List all cases where the adversary case has been resolved/settled, but Notice/Stipulation of Dismissal cannot yet be filed. Provide explanation as to why Notice/Stipulation of Dismissal has not been filed and date when Notice/Stipulation of Dismissal is expected to be filed. List all cases where service is complete, answer has been filed, discovery/disclosures are underway, and expected date of completion of discovery/disclosure. List all cases where a Mediator has been selected or appointed. List all cases that are ready for trial. You must contact chambers to obtain a trial date, time, and location prior to filing under H. Provide the estimated length of trial and schedule date and time. List all cases where there are dispositive motions pending. Provide dates when briefing is expected to be completed. List all cases which are stayed by the filing of another bankruptcy action affecting a party in this matter. A Suggestion of Bankruptcy should be filed in this case indicating the caption, case number, and venue of this other bankruptcy action. List all cases in which an Appeal is pending.

5 Dated: April 5, 2012 DRINKER BIDDLE & REATH LLP /s/ Howard A. Cohen Howard A. Cohen (DE N. Market Street, Suite 1000 Wilmington, DE Telephone: ( Facsimile: ( and - Robert K. Malone (admitted pro hac vice Marita S. Erbeck (admitted pro hac vice 500 Campus Drive Florham Park, New Jersey Telephone: ( Facsimile: ( and GIBBONS P.C. /s/ Natasha M. Songonuga Natasha M. Songonuga, Esq. (DE N. West Street, Suite 1200 Wilmington, DE Telephone: ( Facsimile: ( nsongonuga@gibbonslaw.com - and -

6 Karen A. Giannelli, Esq. (admitted pro hac vice Dale E. Barney, Esq. (admitted pro hac vice Laura Saborio, Esq. (admitted pro hac vice One Gateway Center Newark, NJ Telephone: ( Facsimile: ( and - WHITEFORD TAYLOR PRESTON LLC /s/ Jarret P. Hitchings Thomas J. Francella, Jr., Esq. (DE 3835 Jarret P. Hitchings, Esq. (DE 5564 The Renaissance Centre, Suite North King Street Wilmington, DE Telephone: ( Facsimile: ( tfrancella@wtplaw.com jhitchings@wtplaw.com Counsel for the AC Liquidating Trust

7 EXHIBIT A IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ADVANTA CORP., et al., 1 Debtors. 2 AC LIQUIDATING TRUST, Plaintiff, v. Defendants Listed Below, Defendant. Chapter 11 Case No (KJC (Jointly Administered STATUS REPORT ON OPEN PREFERENCE ADVERSARY PROCEEDINGS Defendant Name ABC LEGAL SERVICES INC ACXIOM DIGITAL ADAMIYATT, SIMON K ALLIED INTERNATIONAL CREDIT CORP (U.S ALLIED INTERSTATE INC AMBIUS, INC AMERIHEALTH ADMINISTRATORS ASCOM HASLER/GE CAP PROG ATLANTA JOURNAL CONSTITUTION AVAYA, INC BERNSTEIN LAW FIRM PC BLOOMBERG FINANCE LP CA, INC The Debtors in these jointly administered chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Advanta Corp. (2070, Advanta Investment Corp. (5627, Advanta Business Services Holding Corp. (4047, Advanta Business Services Corp. (3786, Advanta Shared Services Corp. (7074, Advanta Service Corp. (5625, Advanta Advertising Inc. (0186, Advantennis Corp. (2355, Advanta Mortgage Holding Company (5221, Advanta Auto Finance Corporation (6077, Advanta Mortgage Corp. USA (2654, Advanta Finance Corp. (8991, Advanta Ventures Inc. (5127, BE Corp. (8960, ideablob Corp. (0726, Advanta Credit Card Receivables Corp. (7955, Great Expectations International Inc. (0440, Great Expectations Franchise Corp. (3326, and Great Expectations Management Corp. (3328. PHTRANS/

8 CHAMPION SOLUTIONS GROUP COMPTROLLER OF MARYLAND COR-O-VAN RECORDS MANAGEMENT INC CORPORATE EXECUTIVE BOARD CREATIVE MULTIMEDIA SOLUTIONS DAVIS GRAHAM & STUBBS LLP DEY'S END CONSULTING, LLC E COMMERCE GROUP PRODUCTS, INC ECKARDT AND COMPANY EDGAR, DUNN & COMPANY EMMET, MARVIN & MARTIN, LLP EQUIPMENT INSTALLERS, INC EUREST DINING SERVICES FEDEX FINANCIAL STATEMENT SERVICES, INC FIRST DATA CORPORATION GENESYS TELECOMMUNICATIONS LABS GRAEME K HOWARD GRAYBAR ELECTRIC COMPANY, INC HARLAND HERMAN MILLER OP SPECTRUM INDUSTRIAL MECHANICAL CONTRACTORS,INC JAMES L. MORTON JORDAN LAWRENCE GROUP KELLY SERVICES, INC KONICA MINOLTA BUSINESS SOLUTIONS USA LANGUAGE LINE SERVICES LEXIS-NEXIS LIBERTY PROPERTY LIMITED PARTNERSHIP MANPOWER,INC METROPOLIS PUBLIC RELATIONS INC NELSON, RICHARD M NEW MEXICO TAXATION AND REVENUE DEPT NRI DATA & BUSINESS PRODUCTS, INC O C TANNER OPEN SOLUTIONS, INC PAPER MILL ROAD LLC PECO ENERGY PHILLIPS AND COHEN ASSOCIATES, LTD RGS FINANCIAL INC RICOH ROBINSON & MCELWEE RSA SECURITY INC SCHNADER HARRISON SEGAL & LEWIS, LLP SNELL & WILMER L.L.P SOS STAFFING SERVICES, INC STAPLES BUSINESS ADVANTAGE PHTRANS/

9 STAR TRIBUNE SUNGARD AVAILABILITY SERVICES TEK SYSTEMS TELEMANAGEMENT TECHNOLOGIES INC THE MIAMI HERALD THE STAR LEDGER THE ULTIMATE SOFTWARE GROUP, INC TPG SOFTWARE, INC TREASURER, STATE OF NEW JERSEY VERIZON VISION BENEFITS OF AMERICA Plaintiff files the attached status report of the above-captioned adversary proceedings. Dated: April 5, 2012 DRINKER BIDDLE & REATH LLP /s/ Howard A. Cohen Howard A. Cohen (DE N. Market Street, Suite 1000 Wilmington, DE Telephone: ( Facsimile: ( and - Robert K. Malone (admitted pro hac vice Marita S. Erbeck (admitted pro hac vice 500 Campus Drive Florham Park, New Jersey Telephone: ( Facsimile: ( Counsel for the AC Liquidating Trust PHTRANS/

10 STATUS A SERVICE HAS NOT BEEN COMPLETED: None. PHTRANS/

11 STATUS B SERVICE IS COMPLETE, BUT ANSWERS ARE STILL DUE: None. PHTRANS/

12 STATUS C SERVICE IS COMPLETE, NO ANSWERS HAVE BEEN FILED. THUS, PLAINTIFF REQUESTING DEFAULT JUDGMENTS: ABC LEGAL SERVICES INC Service is complete, no answer has been filed. ACXIOM DIGITAL Service is complete, no answer has been filed. ALLIED INTERSTATE INC Service is complete, no answer has been filed. AMBIUS, INC Service is complete, no answer has been filed. ASCOM HASLER/GE CAP PROG Service is complete, no answer has been filed. ATLANTA JOURNAL CONSTITUTION Service is complete, no answer has been filed. AVAYA, INC Service is complete, no answer has been filed. CA, INC Service is complete, no answer has been filed. COR-O-VAN RECORDS MANAGEMENT INC Service is complete, no answer has been filed. E COMMERCE GROUP PRODUCTS, INC Service is complete, no answer has been filed. ECKARDT AND COMPANY Service is complete, no answer has been filed. FEDEX Service is complete, no answer has been filed. HERMAN MILLER OP SPECTRUM Service is complete, no answer has been filed. KELLY SERVICES, INC Service is complete, no answer has been filed. LANGUAGE LINE SERVICES Service is complete, no answer has been filed. LIBERTY PROPERTY LIMITED PARTNERSHIP Service is complete, no answer has been filed. METROPOLIS PUBLIC RELATIONS INC Service is complete, no answer has been filed. NRI DATA & BUSINESS PRODUCTS, INC Service is complete, no answer has been filed. OPEN SOLUTIONS, INC Service is complete, no answer has been filed. RICOH Service is complete, no answer has been filed. RSA SECURITY INC Service is complete, no answer has been filed. PHTRANS/

13 SNELL & WILMER L.L.P Service is complete, no answer has been filed. SOS STAFFING SERVICES, INC Service is complete, no answer has been filed. STAPLES BUSINESS ADVANTAGE Service is complete, no answer has been filed. THE STAR LEDGER Service is complete, no answer has been filed. TREASURER, STATE OF NEW JERSEY Service is complete, no answer has been filed. VISION BENEFITS OF AMERICA Service is complete, no answer has been filed. PHTRANS/

14 STATUS D PREFERENCE ACTIONS SETTLED, SETTLEMENT AGREEMENTS EXECUTED AND FILED WITH THE COURT: Not applicable. PHTRANS/

15 STATUS E PREFERENCE ACTIONS RESOLVED/SETTLED, BUT NOTICES/STIPULATIONS OF DISMISSAL CANNOT YET BE FILED: ADAMIYATT, SIMON K Proceeding has been settled. ALLIED INTERNATIONAL CREDIT CORP (U.S Proceeding has been settled. BERNSTEIN LAW FIRM PC Proceeding has been settled. BLOOMBERG FINANCE LP Proceeding has been settled. CHAMPION SOLUTIONS GROUP CORPORATE EXECUTIVE BOARD CREATIVE MULTIMEDIA SOLUTIONS DAVIS GRAHAM & STUBBS LLP Proceeding has been settled Proceeding has been settled Proceeding has been settled Proceeding has been settled. EDGAR, DUNN & COMPANY Proceeding has been settled. EMMET, MARVIN & MARTIN, LLP EQUIPMENT INSTALLERS, INC Proceeding has been settled Proceeding has been settled. PHTRANS/

16 EUREST DINING SERVICES Proceeding has been settled. FINANCIAL STATEMENT SERVICES, INC Proceeding has been settled. FIRST DATA CORPORATION Proceeding has been settled. GRAEME K HOWARD Proceeding has been settled. HARLAND Proceeding has been settled. INDUSTRIAL MECHANICAL CONTRACTORS,INC Proceeding has been settled. JAMES L. MORTON Proceeding has been settled. LEXIS-NEXIS Proceeding has been settled. MANPOWER,INC Proceeding has been settled. O C TANNER Proceeding has been settled. PECO ENERGY Proceeding has been settled. ROBINSON & MCELWEE Proceeding has been settled. PHTRANS/

17 TELEMANAGEMENT TECHNOLOGIES INC Proceeding has been settled. THE MIAMI HERALD Proceeding has been settled. THE ULTIMATE SOFTWARE GROUP, INC Proceeding has been settled. TPG SOFTWARE, INC Proceeding has been settled. PHTRANS/

18 STATUS F CONTESTED PREFERENCE ACTIONS WHERE SERVICE IS COMPLETE, ANSWERS HAVE BEEN FILED, AND DISCOVERY/DISCLOSURES ARE ONGOING: GENESYS TELECOMMUNICATIONS LABS Plaintiff expects to complete discovery in accordance with the proposed scheduling order. TEK SYSTEMS Plaintiff expects to complete discovery in accordance with the proposed scheduling order. PHILLIPS AND COHEN ASSOCIATES, LTD. SCHNADER HARRISON SEGAL & LEWIS, LLP SUNGARD AVAILABILITY SERVICES Plaintiff expects to complete discovery in accordance with the proposed scheduling order Plaintiff expects to complete discovery in accordance with the proposed scheduling order Plaintiff expects to complete discovery in accordance with the proposed scheduling order. VERIZON Plaintiff expects to complete discovery in accordance with the proposed scheduling order. DEY'S END CONSULTING, LLC COMPTROLLER OF MARYLAND Plaintiff expects to complete discovery in accordance with the proposed scheduling order Plaintiff expects to complete discovery in accordance with the proposed scheduling order. PAPER MILL ROAD LLC Plaintiff expects to complete discovery in accordance with the proposed scheduling order. STAR TRIBUNE Plaintiff expects to complete discovery in accordance with the proposed scheduling order. GRAYBAR ELECTRIC COMPANY, INC. JORDAN LAWRENCE GROUP Plaintiff expects to complete discovery in accordance with the proposed scheduling order. Plaintiff expects to complete discovery in accordance with the proposed scheduling order. NELSON, RICHARD M Plaintiff expects to complete discovery in accordance with the proposed scheduling order. PHTRANS/

19 STATUS G CONTESTED PREFERENCE ACTIONS WHERE NOTICES OF SELECTION OF MEDIATOR HAVE BEEN FILED: None PHTRANS/

20 STATUS H CONTESTED PREFERENCE ACTIONS READY FOR TRIAL: None PHTRANS/

21 STATUS I CONTESTED PREFERENCE ACTIONS WHERE DISPOSITIVE MOTIONS PENDING: RGS FINANCIAL INC Defendant filed a Motion to dismiss the Proceeding; deadline for Plaintiff to respond is currently April 17, 2012 PHTRANS/

22 STATUS J CASES STAYED BY THE FILING OF ANOTHER BANKRUPTCY ACTION/SUGGESTION OF BANKRUPTCY FILED OR REQUIRED: None. PHTRANS/

23 STATUS K CASES IN WHICH AN APPEAL IS PENDING: None PHTRANS/

24 EXHIBIT B IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ADVANTA CORP., et al., 1 Debtors. 2 AC LIQUIDATING TRUST, Plaintiff, v. Defendants Listed Below, Defendant. Chapter 11 Case No (KJC (Jointly Administered STATUS REPORT WITH RESPECT TO CERTAIN OPEN PREFERENCE ADVERSARY PROCEEDINGS Defendant Name ALLIED BARTON SERVICES ARAMARK CORPORATION ARDEN REALTY LIMITED PARTNERSHIP AT&T, INC., ET AL BOCA RATON RESORT & CLUB CORPORATION SERVICE COMPANY DELAWARE SECRETARY OF STATE DELOITTE TAX LLP ESSEX TECHNOLOGY GROUP EXPERIAN INTERVOICE, INC The Debtors in these jointly administered chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Advanta Corp. (2070, Advanta Investment Corp. (5627, Advanta Business Services Holding Corp. (4047, Advanta Business Services Corp. (3786, Advanta Shared Services Corp. (7074, Advanta Service Corp. (5625, Advanta Advertising Inc. (0186, Advantennis Corp. (2355, Advanta Mortgage Holding Company (5221, Advanta Auto Finance Corporation (6077, Advanta Mortgage Corp. USA (2654, Advanta Finance Corp. (8991, Advanta Ventures Inc. (5127, BE Corp. (8960, ideablob Corp. (0726, Advanta Credit Card Receivables Corp. (7955, Great Expectations International Inc. (0440, Great Expectations Franchise Corp. (3326, and Great Expectations Management Corp. (3328.

25 MARSH USA, INC QWEST STATE OF MICHIGAN DEPARTMENT OF TREASURY SUNESYS, INC TRANSAMERICA LIFE INSURANCE CO UNITED STATES POSTAL SERVICE AC Liquidating Trust, Plaintiff in the above-referenced cases, hereby submits the attached status report of the above-captioned adversary proceedings. Dated: April 5, 2012 Wilmington, DE GIBBONS P.C. /s/ Natasha M. Songonuga Natasha M. Songonuga, Esq. (Bar No N. West Street, Suite 1200 Wilmington, DE Telephone: ( Facsimile: ( and - Karen A. Giannelli, Esq. Dale E. Barney, Esq. Laura Saborio, Esq. One Gateway Center Newark, NJ Telephone: ( Facsimile: ( kgiannelli@gibbonslaw.com dbarney@gibbonslaw.com lsaborio@gibbonslaw.com Counsel to the AC Liquidating Trust

26 STATUS A SERVICE HAS NOT BEEN COMPLETED: None.

27 STATUS B SERVICE IS COMPLETE, BUT ANSWERS ARE STILL DUE: ALLIED BARTON SECURITY SERVICES AT&T INC. AND AT&T MOBILITY LLC DELAWARE SECRETARY OF STATE ESSEX TECHNOLOGY GROUP INTERVOICE, INC QWEST UNITED STATES POSTAL SERVICE Answer deadline extended by Order of the Court to May 7, Answer deadline extended by Order of the Court to April 11, Answer deadline extended by Order of the Court to May 7, Answer deadline extended by agreement of the parties to April 27, 2012, Order of the Court pending. Answer deadline extended by Order of the Court to April 27, Answer deadline extended by Order of the Court to April 11, Answer deadline extended by Order of the Court to May 7,

28 STATUS C SERVICE IS COMPLETE, NO ANSWERS HAVE BEEN FILED. THUS, PLAINTIFF IS REQUESTING DEFAULT JUDGMENTS: ARDEN REALTY LIMITED PARTNERSHIP BOCA RATON RESORT & CLUB CORPORATION SERVICE COMPANY TRANSAMERICA LIFE INSURANCE COMPANY Service effected by certified mail. Entry of Default to be filed. Service effected by certified mail. Entry of Default to be filed. Service effected by certified mail. Entry of Default to be filed. Service effected by certified mail. Entry of Default to be filed. 3

29 STATUS D PREFERENCE ACTIONS SETTLED, SETTLEMENT AGREEMENTS EXECUTED AND NOTICE OF DISMISSAL FILED WITH THE COURT: None. 4

30 STATUS E PREFERENCE ACTIONS RESOLVED/SETTLED, BUT NOTICES/STIPULATIONS OF DISMISSAL CANNOT YET BE FILED: DELOITTE TAX LLP Settlement reached. A notice of dismissal will be filed shortly with the Court. 5

31 STATUS F CONTESTED PREFERENCE ACTIONS WHERE SERVICE IS COMPLETE, ANSWERS HAVE BEEN FILED, AND DISCOVERY/DISCLOSURES ARE ONGOING: ARAMARK CORPORATION EXPERIAN MARSH USA, INC STATE OF MICHIGAN SUNESYS, INC Scheduling Order entered. Discovery progressing. Scheduling Order entered. Discovery progressing. Scheduling Order entered. Discovery progressing. Scheduling Order entered. Discovery progressing. Scheduling Order entered. Discovery progressing. 6

32 STATUS G CONTESTED PREFERENCE ACTIONS WHERE NOTICES OF SELECTION OF MEDIATOR HAVE BEEN FILED: None. 7

33 STATUS H CONTESTED PREFERENCE ACTIONS READY FOR TRIAL: None. 8

34 STATUS I CONTESTED PREFERENCE ACTIONS WHERE DISPOSITIVE MOTIONS PENDING: None. 9

35 STATUS J CASES STAYED BY THE FILING OF ANOTHER BANKRUPTCY ACTION/SUGGESTION OF BANKRUPTCY FILED OR REQUIRED: None. 10

36 STATUS K CASES IN WHICH AN APPEAL IS PENDING: None. 11

37 EXHIBIT C IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: ADVANTA CORP., et al., 1 Debtors. 2 AC LIQUIDATING TRUST, Plaintiff, v. Defendants Listed Below, Defendant. Chapter 11 Case No (KJC (Jointly Administered SECOND STATUS REPORT ON OPEN PREFERENCE ADVERSARY PROCEEDINGS Defendant Name ADT Security Services, Inc Iron Mountain Data Products Iron Mountain Off Site Data Protection Iron Mountain Records Management John Hancock Life Insurance Co Philadelphia Newspapers, LLC RSM McGladrey, Inc Plaintiff files the attached status report of the above-captioned adversary proceedings. Dated: April 3, 2012 WHITEFORD TAYLOR PRESTON, LLC 1 The Debtors in these jointly administered chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, are Advanta Corp. (2070, Advanta Investment Corp. (5627, Advanta Business Services Holding Corp. (4047, Advanta Business Services Corp. (3786, Advanta Shared Services Corp. (7074, Advanta Service Corp. (5625, Advanta Advertising Inc. (0186, Advantennis Corp. (2355, Advanta Mortgage Holding Company (5221, Advanta Auto Finance Corporation (6077, Advanta Mortgage Corp. USA (2654, Advanta Finance Corp. (8991, Advanta Ventures Inc. (5127, BE Corp. (8960, ideablob Corp. (0726, Advanta Credit Card Receivables Corp. (7955, Great Expectations International Inc. (0440, Great Expectations Franchise Corp. (3326, and Great Expectations Management Corp. (3328.

38 /s/ Jarret P. Hitchings Thomas J. Francella, Jr., Esq. (DE 3835 Jarret P. Hitchings, Esq. (DE 5564 The Renaissance Centre, Suite North King Street Wilmington, DE Telephone: ( Facsimile: ( Counsel for the AC Liquidating Trust

39 STATUS A SERVICE HAS NOT BEEN COMPLETED: None.

40 Iron Mountain Off Site Data Protection Iron Mountain Records Management Philadelphia Newspapers, LLC STATUS B SERVICE IS COMPLETE, BUT ANSWERS ARE STILL DUE: Answer due; disclosures ongoing Answer due; disclosures ongoing Answer due; Alias Summons served at additional alternative address RSM McGladrey, Inc Answer due

41 STATUS C SERVICE IS COMPLETE, NO ANSWERS HAVE BEEN FILED. THUS, PLAINTIFF REQUESTING DEFAULT JUDGMENTS: Iron Mountain Data Products Answer due; Alias Summons served at additional alternative address

42 STATUS D PREFERENCE ACTIONS SETTLED, SETTLEMENT AGREEMENTS EXECUTED AND FILED WITH THE COURT: None.

43 STATUS E PREFERENCE ACTIONS RESOLVED/SETTLED, BUT NOTICES/STIPULATIONS OF DISMISSAL CANNOT YET BE FILED: ADT Security Services, Inc Settled; awaiting clearance of payment

44 STATUS F CONTESTED PREFERENCE ACTIONS WHERE SERVICE IS COMPLETE, ANSWERS HAVE BEEN FILED, AND DISCOVERY/DISCLOSURES ARE ONGOING: John Hancock Life Insurance Co Answers filed; disclosures ongoing

45 STATUS G CONTESTED PREFERENCE ACTIONS WHERE NOTICES OF SELECTION OF MEDIATOR HAVE BEEN FILED: None.

46 STATUS H CONTESTED PREFERENCE ACTIONS READY FOR TRIAL: None.

47 STATUS I CONTESTED PREFERENCE ACTIONS WHERE DISPOSITIVE MOTIONS PENDING: None.

48 STATUS J CASES STAYED BY THE FILING OF ANOTHER BANKRUPTCY ACTION/SUGGESTION OF BANKRUPTCY FILED OR REQUIRED: None.

49 STATUS K CASES IN WHICH AN APPEAL IS PENDING: None.