Court Documents

Order to Show Cause
Verified Petition
Memorandum of Law in Support of Verified Petition
Rehabilitation Order
Omnibus Reply of Superintendent in Support of Verified Petition

Plan Documents

• Scheduling Order, dated September 28, 2012
• Scheduling Order, dated February 19, 2013
• Affirmation in Support of Plan Approval
• Exhibit A: Proposed Plan Approval Order
  • Revised Proposed Plan Approval Order
  • Blackline of Revised Proposed Plan Approval Order
  • Revised Proposed Plan Approval Order, Filed December 12, 2012
  • Blackline of Revised Proposed Plan Approval Order, Filed December 12, 2012
  • Proposed Plan Approval Order Revisions
  • Revised Proposed Plan Approval Order, Filed June 4, 2013
  • Blackline of Revised Proposed Plan Approval Order, Filed June 4, 2013
• Exhibit B: Plan of Rehabilitation, dated September 27, 2012
  • First Amended Plan of Rehabilitation, Dated December 12, 2012
  • Blackline of First Amended Plan of Rehabilitation, Filed December 12, 2012
  • Proposed Plan Revisions
  • First Amended Plan of Rehabilitation, Dated April 12, 2013
  • Blackline of First Amended Plan of Rehabilitation, Filed April 12, 2013
  • Notice of Plan Filing
  • First Amended Plan of Rehabilitation, Filed June 4, 2013
  • Blackline of First Amended Plan of Rehabilitation, Filed June 4, 2013
• Exhibit C: Plan Supplement
  • Novation Agreement
  • Form of Amended and Restated Charter
  • Form of Amended and Restated By-Laws
  • Schedule of Terminated Contracts and Leases
    • Revised Schedule of Terminated Contracts and Leases, Filed December 12, 2012
  • Proof of Policy Claim Form
    • Revised Proof of Policy Claim Form, Filed December 12, 2012
    • Blackline of Proof of Policy Claim Form, Filed December 12, 2012
    • Revised Proof of Policy Claim Form, Filed January 25, 2013
    • Blackline of Proof of Policy Claim Form, Filed January 25, 2013
    • Proposed Revisions to Proof of Policy Claim Form
    • Revised Proof of Policy Claim Form, Filed April 12, 2013
    • Blackline of Proof of Policy Claim Form, Filed April 12, 2013
  • Instructions for Completing Proof of Policy Claim Form
    • Revised Instructions for Completing Proof of Policy Claim Form, Filed January 25, 2013
    • Blackline of Revised Instructions, Filed January 25, 2013
  • CDS Commutation Agreement 1
  • CDS Commutation Agreement 2
  • CDS Commutation Agreement 3
  • CDS Commutation Agreement 4
  • CDS Commutation Agreement 5
  • CDS Commutation Agreement 6
• Interim Order Extending Deadline to File Updates to Plan Supplement
• Exhibit D: Disclosure Statement
• Exhibit E: Form of Notice of Plan Approval Hearing
• Exhibit 1: Preliminary Analysis of FGIC Payments Not Paid to FGIC
• Ad Hoc Instrument Holders' Affirmation in Support of Plan
• Memorandum of Law in Support of Plan
• Letter to BNY Regarding Plan Sections 3.7 and 7.8
• Letter to Wells Fargo Regarding Plan Sections 3.7 and 7.5
• Statement of Non-Objection by the Federal Home Loan Mortgage Corporation to the Revised Plan of Rehabilitation
• Letter to Rehabilitation Court, Dated April 12, 2013
• Letter to Rehabilitation Court, Dated April 16, 2013
• Letter to Rehabilitation Court, Dated June 4, 2013
• Letter to the Rehabilitation Court, Dated June 5, 2013

Plan Objections

• Objection of the Trustees Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas to the Proposed Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Amended Objection of Trustees Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas to the First Amended Proposed Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Notice of Withdrawal of Trustees Deutsche Bank National Trust Company and Deutsche Bank Trust Company Americas' Objections to the Plan of Rehabilitation for Financial Guaranty Insurance Company
• Objection to the Proposed Plan of Rehabilitation of Wells Fargo, N.A., in its Capacity as Trustee for Certain RMBS Certificateholders and on Behalf of the Certificateholders and Noteholders for Such Trusts and Transactions
  • Amended Objection to the First Amended Proposed Plan of Rehabilitation of Wells Fargo Bank, N.A., in its Capacity as Trustee for Certain RMBS Certificateholders and on Behalf of the Certificateholders and Noteholders for Such Trusts and Transactions
  • Notice of Withdrawal of Amended Objections to the First Amended Proposed Plan of Rehabilitation of Wells Fargo Bank, N.A., in its Capacity as Trustee for Certain RMBS Certificateholders and on Behalf of the Certificateholders and Noteholders for such Trusts and Transactions
• Objection of U.S. Bank National Association and U.S. Bank Trust National Association, Each in Its Capacity as Trustee, to the Plan of Rehabilitation dated September 27, 2012
  • Amended Objection of U.S. Bank National Association and U.S. Bank Trust National Association, Each in its Capacity as Trustee, to Plan of Rehabilitation of Financial Guaranty Insurance Company
  • Notice of Withdrawal of Objections of U.S. Bank National Association and U.S. Bank Trust National Association, Each in its Capacity as Trustee, to Plan of Rehabilitation of Financial Guaranty Insurance Company
• Objections of The Bank of New York Mellon and The Bank of New York Mellon Trust Company, N.A., as Trustee to the Proposed Plan of Rehabilitation
  • Amended Objections and Memorandum of Law in Support of Amended Objections of The Bank of New York Mellon and The Bank of New York Mellon Trust Company, N.A., as Trustee to the Proposed Plan of Rehabilitation
  • Notice of Withdrawal of Objections of The Bank of New York Mellon and The Bank of New York Mellon Trust Company, N.A., as Trustee to the Proposed Plan of Rehabilitation
• Objection and Joinder of Aurelius Capital Management, LP to (I) the Objection of U.S. Bank National Association and U.S. Bank Trust National Association, Each in its Capacity as Trustee, to the Plan of Rehabilitation dated September 27, 2012, and (II) the Objections of the Bank of New York Mellon and the Bank of New York Mellon Trust Company, N.A., as Trustee to the Proposed Plan of Rehabilitation
  • Amended Objection of Aurelius Capital Management, LP to the Proposed Plan of Rehabilitation and Joinder to the Amended Objections of the Bank of New York Mellon and the Bank of New York Mellon Trust Company, N.A., as Trustee to the Proposed Plan of Rehabilitation
  • Notice of Withdrawal of Objections of Aurelius Capital Management, LP to Plan of Rehabilitation for Financial Guaranty Insurance Company Subject to Entry of Revised Plan Approval Order
• Objection to Plan and Disclosure Statement of Rehabilitation for Financial Guaranty Insurance Company of Manufacturers and Traders Trust Company
• Objection of Assured Guaranty Corp., Assured Guaranty Re Ltd., and Assured Guaranty Re Overseas Ltd. to Plan of Rehabilitation Proposed by Benjamin M. Lawsky, Superintendent of Financial Services of the State of New York, as Rehabilitator of Financial Guaranty Insurance Company
  • Notice of Withdrawal of Objection of Assured Guaranty Corp., Assured Guaranty Re Ltd. and Assured Guaranty Re Overseas Ltd
  • Notice of Amendment of Stipulation
• Objection of CQS ABS Master Fund Ltd., CQS Select ABS Master Fund Ltd. and CQS ABS Alpha Master Fund Ltd. to Plan of Rehabilitation for Financial Guaranty Insurance Company
  • The Amended Objections of CQS ABS Master Fund Ltd., CQS Select ABS Master Fund Ltd., and CQS ABS Alpha Master Fund Ltd. to Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Notice of Withdrawal of Objections of CQS ABS Master Fund, Ltd., CQS Select ABS Master Fund Ltd. and CQS ABS Alpha Master Fund Ltd. to Plan of Rehabilitation for Financial Guaranty Insurance Company Subject to Entry of Revised Plan Approval Order
• Conditional Objection of Jefferson County, Alabama to the Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Notice of Withdrawal of Conditional Objection of Jefferson County, Alabama
• Objection of Certain Jefferson County Warrantholders to Plan of Rehabilitation
  • Amended Objections of Certain Jefferson County Warrantholders to Plan of Rehabilitation
  • Letter Withdrawing Objections of Certain Jefferson County Warrantholders to Plan of Rehabilitation
• Limited Objection of Childrens Health Partnership Holdings Pty Ltd as Trustee of the CHP Holdings Unit Trust to Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Amended Limited Objection of Childrens Health Partnership Holdings Pty Ltd as Trustee of the CHP Holdings Unit Trust to Plan of Rehabilitation for Financial Guaranty Insurance Company
  • Notice of Withdrawal of Objections of Childrens Health Partnership Holdings Pty Ltd to Plan of Rehabilitation for Financial Guaranty Insurance Company

Rehabilitator's Reply in Further Support of Plan

• Omnibus Reply Memorandum of Law in Further Support of Approval of First Amended Plan of Rehabilitation for Financial Guaranty Insurance Company, dated December 12, 2012
• Affidavit of Michael W. Miller, dated December 12, 2012
• Affidavit of John S. Dubel, dated December 12, 2012
• Exhibit 1A
• Letter to the Court, dated January 25, 2013
• Amended Omnibus Reply Memorandum of Law in Further Support of Approval of First Amended Plan of Rehabilitation for Financial Guaranty Insurance Company
• Letter to the Court, dated February 11, 2013
• Exhibit 1C - Amended Omnibus Response Chart, submitted February 11, 2013.

Submissions Regarding Standard for Plan Approval

• Letter Submitted on Behalf of the Rehabilitator, dated January 22, 2013
• Trustee Objectors' Submission on Standard for Approval of Plan, dated January 22, 2013
• Memorandum of Jefferson County Warrantholders Concerning the Standard of Review Applicable to FGIC's Plan of Rehabilitation
• Letter Submitted on Behalf of CQS, dated January 22, 2013
• Letter Submitted on Behalf of CHP, dated January 22, 2013
• Joinder of Aurelius Capital Management, LP to the Trustees' Letter Brief Addressing the Legal Standard to be Applied by the Court in Determining Whether it Should Approve the Plan of Rehabilitation Filed by the Rehabilitator

Plan-Related Court Orders

• Court Order Regarding Additional Pleadings, dated December 19, 2012
• Order Approving CDS Commutation Agreements
• Court Order dated January 18, 2013
• Court Order dated January 24, 2013
• Court Order Amending Order dated January 24, 2013
• Court Order dated January 28, 2013
• Court Order dated February 14, 2013
• Court Order dated April 23, 2013
• Plan Approval Order dated June 11, 2013
• Notice of Plan Approval

Orders Approving Reinsurance Commutation Agreements

• Settlement, Commutation and Release Agreement with Radian Asset Assurance Inc.
• Settlement, Commutation and Release Agreement with American Overseas Reinsurance Company Limited
• Settlement, Commutation and Release Agreement with Syncora Guarantee Inc.
• Settlement, Commutation and Release Agreement with Munich Reinsurance America, Inc.
• Settlement, Commutation and Release Agreement with Colisee RE, a French company, formerly known as AXA Re Finance Madeira Branch

Submissions and Orders Concerning Other Agreements

• Affirmation in Support of Rehabilitator's Motion for Approval of (i) that certain Settlement Agreement among Residential Capital, LLC, FGIC, the Trustees and the Institutional Investors, dated May 23, 2013 and (ii) that certain Plan Support Agreement among Residential Capital, LLC, Ally Financial Inc., the Creditors' Committee, FGIC and the other Consenting Claims, dated May 13, 2013, to the extent the Plan Support Agreement relates to FGIC
• Signed Order to Show Cause, dated May 30, 2013, Setting the Hearing Date, and Certain Deadlines, for Approval of the Settlement Agreement and the Plan Support Agreement
• Revised Proposed Order Approving the Settlement Agreement and the Plan Support Agreement as it relates to FGIC
• Interim Order, dated June 11, 2013, regarding ResCap Trustees' Compliance with Order to Show Cause Notice Provision
• Objection of Monarch Alternative Capital LP, Stonehill Capital Management LLC, CQS ABS Master Fund Limited and CQS ABS Alpha Master Fund Limited to Rehabilitator's Motion for Order Pursuant to Section 7428 of New York Insurance Law Approving (I) that Certain Settlement Agreement Among the Debtors, FGIC, the Trustees and Certain Institutional Investors, dated May 23, 2013, and (II) that Certain Plan Support Agreement Among the Debtors, Ally Financial Inc., the Creditors' Committee, FGIC and the Other Consenting Claimants, dated May 13, 2013
• Cover Letter
• Affirmation of Paul V. Shalhoub in Support of Objection of Monarch Alternative Capital LP, Stonehill Capital Management LLC, CQS ABS Master Fund Limited and CQS ABS Alpha Master Fund Limited to Rehabilitator's Motion for Order Pursuant to Section 7428 of New York Insurance Law Approving (I) that Certain Settlement Agreement Among the Debtors, FGIC, the Trustees and Certain Institutional Investors, dated May 23, 2013, and (II) that Certain Plan Support Agreement Among the Debtors, Ally Financial Inc., the Creditors' Committee, FGIC and the Other Consenting Claimants, dated May 13, 2013
• Exhibits (A-M)
• Objection of Federal Home Loan Mortgage Corporation to the Commutation of Certain FGIC Policies and Certain Findings of Fact Sought by Rehabilitator of Financial Guaranty Insurance Company Set Forth in Affirmation, dated May 29,2013
• Affirmation of David Gelfarb in Support of Objection of Federal Home Loan Mortgage Corporation to the Commutation of Certain FGIC Policies and Certain Findings of Fact Sought by Rehabilitator of Financial Guaranty Insurance Company Set Forth in Affirmation, dated May 29, 2013
• Affidavit of Gina Healy in Support of Objection of Federal Home Loan Mortgage Corporation to the Commutation of Certain FGIC Policies and Certain Findings of Fact Sought by Rehabilitator of Financial Guaranty Insurance Company Set Forth in Affirmation, dated May 29, 2013
• Limited Objection of FYI Ltd., FFI Fund Ltd. and Olifant Fund, Ltd. to The Rehabilitator's Motion to (A) Approve Settlement Agreement and (B) Approve Plan Support Agreement and Request for Related Relief
• Affidavit of Seth Robbins in Support of FYI Ltd., FFI Fund Ltd. and Olifant Fund, Ltd.'s Limited Objection to the Rehabilitator's Motion to (A) Approve Settlement Agreement and (B) Approve Plan Support Agreement and for Related Relief
• Exhibits (A-E)
• Omnibus Reply Memorandum of Law in Further Support of Approval of the Settlement Agreement
• Affidavit of John S. Dubel
• Exhibit A
• Exhibit B
• Exhibit C
• Affirmation of Richard W. Slack in Support of the Rehabilitator's Omnibus Reply
• Exhibit A
• Exhibit B
• Exhibit C
• Exhibit D
• Exhibit E
• Order Declining to Sign Order to Show Cause brought by Monarch Alternative Capital LP, Stonehill Capital Management LLC, Bayview Fund Management LLC, CQS ABS Master Fund Limited and CQS ABS Alpha Master Fund Limited
• Letter Submitted by Gary T. Holtzer on Behalf of Rehabilitator, dated August 7, 2013
• Letter Submitted by Richard W. Slack on Behalf of Rehabilitator, dated August 7, 2013
• Order Approving the Settlement Agreement and the Plan Support Agreement as it relates to FGIC
• Order Denying the Motion by Federal Home Loan Mortgage Corporation for Leave to Conduct Limited and Expedited Discovery
• Order Denying the Motion by Federal Home Loan Mortgage Corporation to Intervene
• Affirmation in Support of Rehabilitators Motion for an Order (i) approving that certain Stipulation Regarding Treatment under Plan of Rehabilitation for Financial Guaranty Insurance Company among the Rehabilitator of Financial Guaranty Insurance Company, Financial Guaranty Insurance Company, The Bank of New York Mellon, as successor trustee, The Bank of New York Mellon, as fiscal agent, and certain Jefferson County Warrantholders, dated May 31, 2013, and (ii) amending, to the extent necessary to give effect to the Stipulation, FGIC's obligations under the JeffCo Warrant Policies
• Stipulation Regarding Treatment under Plan of Rehabilitation for Financial Guaranty Insurance Company among the Rehabilitator of Financial Guaranty Insurance Company, Financial Guaranty Insurance Company, The Bank of New York Mellon, as successor trustee, The Bank of New York Mellon, as fiscal agent, and certain Jefferson County Warrantholders, dated May 31, 2013
• Signed Order to Show Cause, dated June 11, 2013, Setting the Hearing Date, and Certain Deadlines, for Approval of the Stipulation and Setting Forth the Treatment of JeffCo Control Rights
• Order Approving Stipulation Regarding Treatment under Plan of Rehabilitation among FGIC, The Bank of New York Mellon and certain Jefferson County Warrantholders
• Termination Agreement by and Among FGIC, The Bank of New York Mellon in various capacities, the Company and Other Parties
• Order Approving FGIC's Execution and Performance of Certain Agreements Related to the Chapter 9 Case of Jefferson County, Alabama
• Termination Agreement with The Bank of New York Mellon, AAArdvark II Funding Limited and other parties
• Termination Agreement with Ancora (RCH) Pty Ltd, Childrens Health Partnership Holdings Pty Ltd as trustee of the CHP Holdings Unit Trust, Childrens Health Partnership Pty Ltd as trustee of the CHP Unit Trust and other parties