Case 2:19-ap-01147-SK Doc 71 Filed 01/31/20 Entered 01/31 ...3,3(5 //3 86 /26 $1*(/(6 ($67? ([KLELW $ 6WDWXV 5HSRUW Case 2:19-ap-01147-SK Doc 71 Filed 01/31/20 Entered 01/31/20 15:16:15

DLA PIPER LLP (US) LOS A NG EL ES

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ROBBIN L. ITKIN (SBN 117105) [email protected] DLA PIPER LLP (US) 2000 Avenue of the Stars Suite 400 North Tower Los Angeles, California 90067-4704 Tel: (310) 595-3000 Fax: (310) 595-3300

JOHN K. LYONS (Pro Hac Vice) [email protected] JEFFREY S. TOROSIAN (Pro Hac Vice) [email protected] JOSEPH A. ROSELIUS (Pro Hac Vice) [email protected] DLA PIPER LLP (US) 444 West Lake Street, Suite 900 Chicago, Illinois 60606-0089 Tel: (312) 368-4000 Fax: (312) 236-7516

Attorneys for Jonathan D. King as Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA

LOS ANGELES DIVISION

In re:

ZETTA JET USA, INC., a California corporation,

Debtor.

Lead Case No.: 2:17-bk-21386-SK

Chapter 7

Jointly Administered With: Case No.: 2:17-bk-21387-SK

Adv. Proc. No. 2:19-01147-SK

NOTICE OF FILING OF OMNIBUS STATUS REPORT ON CERTAIN ADVERSARY CASES

[Relates to Docket No. 64]

In re:

ZETTA JET PTE, LTD., a Singaporean corporation,

Debtor.

JONATHAN D. KING, solely in his capacity as Chapter 7 Trustee of Zetta Jet USA, Inc. and Zetta Jet PTE, Ltd.

Plaintiff,

Case 2:19-ap-01147-SK Doc 71 Filed 01/31/20 Entered 01/31/20 15:16:15 DescMain Document Page 1 of 3


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2 EAST\171997590.1

v.

CAVIC AVIATION LEASING (IRELAND) 22 CO. DESIGNATED ACTIVITY COMPANY; and BOMBARDIER AEROSPACE CORPORATION,

Defendants.

TO THE HONORABLE SANDRA R. KLEIN, UNITED STATES BANKRUPTCY JUDGE, THE UNITED STATES TRUSTEE AND ALL DEFENDANTS:

PLEASE TAKE NOTICE that, on January 31, 2019, Jonathan D. King, solely in his

capacity as the duly appointed chapter 7 trustee in the above-captioned, jointly administered

bankruptcy cases of Zetta Jet USA, Inc. and Zetta Jet PTE, Ltd., through his undersigned counsel,

filed the Omnibus Status Report on Certain Adversary Cases [Case No. 17-21386-SK, Docket No.

1177] (the “Status Report”), as requested by the Court. A true and correct copy of the Status Report

is attached hereto as Exhibit A.

Respectfully submitted,

DATED: January 31, 2020 DLA PIPER LLP (US) By: /s/ John K. Lyons ROBBIN L. ITKIN JOHN K. LYONS (Pro Hac Vice) JEFFREY S. TOROSIAN (Pro Hac Vice) JOSEPH A. ROSELIUS (Pro Hac Vice) Attorneys for the Trustee / Plaintiff



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EAST\171997590.1

Exhibit A

(Status Report)


DLA PIPER LLP (US)LOS A NG EL ES

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EAST\171898159.1

Exhibit A

(Status Report)

Case 2:19-ap-01147-SK Doc 71-1 Filed 01/31/20 Entered 01/31/20 15:16:15 DescExhibit A -Status Report Page 1 of 7


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1 EAST\171898159.1

ROBBIN L. ITKIN (SBN 117105) [email protected] DLA PIPER LLP (US) 2000 Avenue of the Stars Suite 400 North Tower Los Angeles, California 90067-4704 Tel: (310) 595-3000 Fax: (310) 595-3300

JOHN K. LYONS (Pro Hac Vice) [email protected] JEFFREY S. TOROSIAN (Pro Hac Vice) [email protected] JOSEPH A. ROSELIUS (Pro Hac Vice) [email protected] DLA PIPER LLP (US) 444 West Lake Street, Suite 900 Chicago, Illinois 60606-0089 Tel: (312) 368-4000 Fax: (312) 236-7516

Attorneys for Jonathan D. King as Chapter 7 Trustee

UNITED STATES BANKRUPTCY COURT CENTRAL DISTRICT OF CALIFORNIA

LOS ANGELES DIVISION

In re:

ZETTA JET USA, INC., a California corporation,

Debtor.

Lead Case No.: 2:17-bk-21386-SK

Chapter 7

Jointly Administered With: Case No.: 2:17-bk-21387-SK

OMNIBUS STATUS REPORT ON CERTAIN ADVERSARY CASES

Next Status Conference: Date: February 12, 2020 Time: 1:00 p.m. (PST) Place: Courtroom 1575

255 East Temple Street Los Angeles, CA 90012

[Related to Adversary Case Nos.: 2:18-ap-01340; 2:19-ap-01147; 2:19-ap-01382; 2:19-ap-01383]

In re:

ZETTA JET PTE, LTD., a Singaporean corporation,

Debtor.

Affects Both Debtors

Affects Zetta Jet USA, Inc., a California corporation, only

Affects Zetta Jet PTE, Ltd., a Singaporean corporation, only

Case 2:17-bk-21386-SK Doc 1177 Filed 01/31/20 Entered 01/31/20 13:01:03 DescMain Document Page 1 of 6



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2 EAST\171898159.1

TO THE HONORABLE SANDRA R. KLEIN, UNITED STATES BANKRUPTCY JUDGE, THE UNITED STATES TRUSTEE AND ALL DEFENDANTS:

COMES NOW, counsel for Jonathan D. King, solely in his capacity as the duly appointed

chapter 7 trustee in the above-captioned, jointly administered bankruptcy cases of Zetta Jet USA,

Inc. and Zetta Jet PTE, Ltd., and Plaintiff in the above referenced adversary proceedings, and files

the current schedule of upcoming deadlines and hearings, as requested by the Court, attached hereto

as Exhibit A.

Respectfully submitted,

DATED: January 31, 2020 DLA PIPER LLP (US)

By: /s/ John K. Lyons ROBBIN L. ITKIN JOHN K. LYONS (Pro Hac Vice) JEFFREY S. TOROSIAN (Pro Hac Vice) JOSEPH A. ROSELIUS (Pro Hac Vice)

Attorneys for the Trustee / Plaintiff




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Exhibit A

(Schedule)



1

In re Zetta Case No. 2-17-bk-21386-SK (Updated on Jan. 31, 2020)

SCHEDULE OF LARGE ADVERSARY CASES1

DATE JETCRAFT CASE

YUNTIAN CASE

CAVIC CASE

NEW TARGET CASE

Adv. Case No. 2:19-ap-1382-SK




All Defendants who have not settled have

been served and have appeared.

Not yet served:

(1) Minsheng Financial Leasing

Co., Ltd.; and

(2) Li Qi.

Both Defendants served and appeared

Not yet served:

Kebo Wu

Pending Motions:

(1) Motion to Dismiss by FK

Defendants2 and Orion Aircraft

Holdings Ltd. [Dkt 45, fully briefed];

(2) Motion to Dismiss by Jetcraft

Defendants3 and Orion Aircraft

Holdings Ltd. [Dkt 46, fully briefed];

and

(3) Motion to Dismiss by Bombardier

Defendants4 [Dkt 76, fully briefed].

Pending Motions:

(1) Motion to Dismiss by Yuntian

Entities5 [Dkt 32, not yet fully briefed]

(2) Motion to Dismiss by

Minsheng Business Aviation Limited

[Dkt 44, not yet fully briefed]; and

(3) Motion to Dismiss by UL

Defendants6 [Dkt 45, not yet fully briefed]

Pending Motions:

(1) CAVIC’s Motion to Dismiss [Dkt 59,

not yet fully briefed]; and

(2) Bombardier Aerospace

Corporation (“BAC”)’s Motion to Dismiss [Dkt 70, not yet fully briefed]

Pending Motions:

None

1 Yellow highlights denote hearings. 2 “FK Defendants” are FK Group Ltd; FK Partners Ltd; and Jahid Fazal-Karim. 3 “Jetcraft Defendants” are Jetcraft Corporation; Jetcraft Global, Inc.; Jetcoast 5000-5 LLC; and Jetcraft Asia Limited. 4 “Bombardier Defendants” are Bombardier Aerospace Corporation; Bombardier Inc.; and Learjet, Inc. 5 “Yuntian Entities” are Yuntian 3 Leasing Company Limited Designated Activity Company and Yuntian 4 Leasing Company Designated Activity Company. 6 “UL Defendants” are Universal Leader Investment Limited; Glove Assets Investment Limited; and Truly Great Global Limited.



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Jan. 31, 2020 Trustee’s Responses to Motions to

Dismiss by Yuntian Entities, Minsheng Business, and UL Defendants Due

Feb. 3, 2020 Dragon Pearl Limited’s Response to Complaint Due

Feb. 5, 2020 Unilateral Status Report Due

Feb. 12, 2020 (1 pm) Status Conference Status Conference Status Conference

Feb. 14, 2020 Trustee’s Response to CAVIC’s Motion

to Dismiss Due

Feb. 21, 2020 Reply Briefs Due from Yuntian

Entities, Minsheng Business, and UL

Defendants on their Motions to Dismiss

-and-

Export Development Canada’s Response to Complaint Due7

Feb. 27, 2020 Trustee’s Response to BAC’s Motion to

Dismiss Due

Feb. 28, 2020 CAVIC’s Reply Brief for its Motion

to Dismiss Due

Mar. 11, 2020 (10 am)

Hearing on FK Defendants’ and Orion Aircraft

Holdings Ltd.’s Motion to Dismiss

[Dkt 45]; Hearing on

7 Pursuant to Stipulation between the Trustee and Export Development Canada as filed with the Court [Dkt 49] and awaiting the Court’s Order approving same.



3

Jetcraft Defendants’ and Orion Aircraft

Holdings Ltd.’s Motion to Dismiss

[Dkt 46]; Hearing on Bombardier

Defendants’ Motion to Dismiss [Dkt 76];

and Status Conference

Mar. 12, 2020 BAC’s Reply Brief for its Motion to

Dismiss Due

EAST\171535102.1



This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 7004-1.SUMMONS.ADV.PROC EAST\149128521.4

PROOF OF SERVICE OF DOCUMENT

I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: DLA Piper LLP (US)

2000 Avenue of the Stars, Suite 400 North Tower Los Angeles, CA 90067-4704

A true and correct copy of (1) the foregoing document entitled Notice of Filing of Omnibus Status Report on Certain Adversary Cases will be served or was served (a) on the judge in chambers in the form and manner required by LBR 5005-2(d); and (b) in the manner stated below:

1. TO BE SERVED BY THE COURT VIA NOTICE OF ELECTRONIC FILING (NEF): Pursuant to controlling General Orders and LBR, the foregoing documents were served by the court via NEF and hyperlink to the document. On January 31, 2020, I checked the CM/ECF docket for this bankruptcy case or adversary proceeding and determined that the following persons are on the Electronic Mail Notice List to receive NEF transmission at the email addresses stated below:

☐ Service information continued on attached page

2. SERVED BY UNITED STATES MAIL: On January 31, 2020, I served the following persons and/or entities at the last known addresses in this bankruptcy case or adversary proceeding by placing a true and correct copy thereof in a sealed envelope in the United States mail, first class, postage prepaid, and addressed as follows. Listing the judge here constitutes a declaration that mailing to the judge will be completed no later than 24 hours after the document is filed.

Honorable Sandra R. Klein United States Bankruptcy Court for the Central District of California 255 East Temple Street, Suite 1582 Los Angeles, California 90012

Ron Maroko Office of the United States Trustee 915 Wilshire Boulevard, Suite 1850 Los Angeles, California 90017

☐ Service information continued on attached page

3. SERVED BY PERSONAL DELIVERY, OVERNIGHT MAIL, FACSIMILE TRANSMISSION OR EMAIL (state method for each person or entity served): Pursuant to F.R.Civ.P. 5 and/or controlling LBR, on January 31, 2020, I served the following persons and/or entities by personal delivery, overnight mail service, or (for those who consented in writing to such service method), by facsimile transmission and/or email as follows. Listing the judge here constitutes a declaration that personal delivery on, or overnight mail to, the judge will be completed no later than 24 hours after the document is filed.

VIA HAND DELIVERY

VIA ELECTRONIC MAIL

(Party, who is being served if different, and email address for each)

☒ Service information continued on attached page

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

January 31, 2020 Tennille Wilson /s/ Tennille Wilson Date Printed Name Signature

Case 2:19-ap-01147-SK Doc 71-2 Filed 01/31/20 Entered 01/31/20 15:16:15 Desc Proof of Service Page 1 of 2

This form is mandatory. It has been approved for use by the United States Bankruptcy Court for the Central District of California.

June 2012 F 7004-1.SUMMONS.ADV.PROC EAST\149128521.4

Counsel via Electronic Mail

Bombardier Aerospace Corporation and Bombardier, Inc.

Attn.: Matthew S. Walker Email: [email protected]

Attn.: Andrew Troop Email: [email protected]

Attn.: Carolina A. Fornos Email: [email protected]

CAVIC Aviation Leasing (Ireland) 22 Co. Designated Activity Company

Attn.: Alan Watson Email: [email protected]

Attn.: Robert J. Labate Email: [email protected]

Case 2:19-ap-01147-SK Doc 71-2 Filed 01/31/20 Entered 01/31/20 15:16:15 Desc Proof of Service Page 2 of 2

Documents

Case 2:19-ap-01147-SK Doc 71 Filed 01/31/20 Entered 01/31 ...3,3(5 //3 86 /26 $1*(/(6 ($67? ([KLELW $ 6WDWXV 5HSRUW Case 2:19-ap-01147-SK Doc 71 Filed 01/31/20 Entered 01/31/20 15:16:15