Motion To Transfer

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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF DELAWARE

In re:

Energy Future Holdings Corporation, et al.,

Debtors.

Chapter 11

Case No. 14- (---)

Joint Administration Pending

Objection Deadline: TBD
Hearing Date: TBD

MOTION OF WILMINGTON SAVINGS FUND SOCIETY, FSB PURSUANT
TO 28 U.S.C. 1408 & 1412 AND RULE 1014 OF THE FEDERAL RULES
OF BANKRUPTCY PROCEDURE TO TRANSFER CASES TO THE UNITED
STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

Wilmington Savings Fund Society, FSB (the Trustee), as successor trustee under that
certain indenture, dated as of October 6, 2010 (as amended or supplemented), among Texas
Competitive Electric Holdings, LLC (TCEH), TCEH Finance, Inc., the guarantors party
thereto, and The Bank of New York Mellon Trust Co., N.A., as trustee (the Indenture),
1

pursuant to 28 U.S.C. 1408 and 1412, Rule 1014 of the Federal Rules of Bankruptcy
Procedure (the Bankruptcy Rules), and Section 105(a) of title 11 of the United States Code
(the Bankruptcy Code), hereby moves this Court (the Motion) to transfer the above-
captioned chapter 11 cases (the Chapter 11 Cases) of Energy Future Holdings Corporation
(EFH) and its subsidiaries (together, the Debtors) to the United States District Court for the
Northern District of Texas in the interests of justice and/or for the convenience of the parties. In
support of this Motion, the Trustee respectfully represents as follows:

1
As used herein, the terms Second Liens or Second Lien Notes refer to the senior
secured second lien notes issued pursuant to the Indenture.

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PRELIMINARY STATEMENT
1. It is settled law in this District that the Court may, in the interests of justice or for
the convenience of the parties, transfer venue of a pending chapter 11 case to another proper
district. Without in any way suggesting that this Court would be unable to adequately administer
the Chapter 11 Cases, the Trustee believes both tests independently, and together, substantially
favor the transfer of these cases to the United States District Court for the Northern District of
Texas.
2

2. As discussed herein, the Debtors only connection to Delaware is that certain of
the Debtors were formed under Delaware law. Such a thin connection (particularly in
comparison to the overwhelming connections to the Northern District of Texas), begs the
question as to why the Debtors would choose to pursue a course of action as important as these
restructuring cases so far away from the location of their headquarters, management, employees,
customers, businesses, and assets. The Debtors are likely to argue that Delaware would be more
convenient for certain professionals located in the Northeastern part of the country.
Respectfully, the Trustee suggests such a consideration should have little (if any) bearing.
Another reason for choosing Delaware may have been, regardless of the interests of creditors or
the needs of the business, to select the venue most advantageous to implementation of the
restructuring agenda favored by senior lenders and management. Those driving the forum
selection process may view it more likely this Court would, among other things, adopt, without

2
Presumably, upon transfer of these cases to the Northern District of Texas, they would
then be referred to the United States Bankruptcy Court for the Northern District of Texas.
See United States District Court for the Northern District of Texas Standing Order of
Reference of Bankruptcy Cases and Proceedings, dated August 3, 1984. Upon
information and belief, the Trustee believes the Debtors cases may be properly assigned
to either the Dallas Division or Fort Worth Division within the Northern District of
Texas.
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significant additional scrutiny, a market valuation based on current distressed trading prices of
the Debtors debt securities. The Trustee believes such strategic motives do not justify the
significant expense, upheaval, and business disruption that would inevitably accompany
maintaining these important cases in this district.
3. The facts and circumstances of these cases make clear that transfer to the
Northern District of Texas would benefit substantially all parties in interest other than, perhaps,
professionals or senior lenders based in the Northeast, who would incur modest additional travel
burdens. The Debtors headquarters, located at Energy Plaza in Dallas, Texas, are within
walking distance of the Dallas division of the United States Bankruptcy Court for the Northern
District of Texas. By comparison, if these cases remain in Delaware, critical management
personnel will be required to spend extended periods away from their offices when they should
be focused on addressing business issues critical to maximizing value for all creditors (not just
senior lenders with whom management has elected to negotiate).
4. The Debtors have substantially all of their assets, employees, customers, and trade
creditors in Texas (in the Dallas/Fort Worth area in particular). The Debtors are the largest
provider of electric power in North Texas, are subject to numerous Texas regulatory regimes,
have litigated (and continue to litigate) often in Texas courts, and have potentially significant
environmental clean-up obligations in Texas, which have come under increasing scrutiny in
recent months by regulators and Texas citizen watch groups. The Debtors only arguable nexus
to Delaware is that certain of the Debtors were formed as Delaware entities. Upon information
and belief, none of the Debtors has ever done business in Delaware; none of the Debtors
employees resides in Delaware; few, if any, of the Debtors books and records are in Delaware;
few, if any, of the Debtors officers or directors are in Delaware; and Delaware has little, if any,

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interest in the Debtors operations or these cases. In short, when the relevant factors are
considered, substantially all strongly favor the transfer of these cases to the Northern District of
Texas.
JURISDICTION, VENUE, AND STATUTORY PREDICATES
5. This Court has subject matter jurisdiction to consider this matter pursuant to 28
U.S.C. 1334. This is a core proceeding pursuant to 28 U.S.C 157(b) and may be determined
by the Bankruptcy Court. For purposes of a hearing on this Motion, venue in this Court is proper
pursuant to 28 U.S.C. 1408 and 1409. The statutory predicates for relief sought herein are 28
U.S.C. 1412, Bankruptcy Rule 1014 and Section 105(a) of the Bankruptcy Code.
BACKGROUND
6. The Debtors are headquartered at Energy Plaza in Dallas, Texas, which is
approximately 0.4 miles (estimated to be a 9 minute walk) from the Bankruptcy Court in Dallas,
Texas. By contrast, Energy Plaza, where substantially all of the Debtors key management
members are located, is approximately 1,436 miles from the Bankruptcy Court in Wilmington,
Delaware. At a minimum, this involves a 30-minute ride from Energy Plaza to Dallas/Fort
Worth International Airport, approximately three hours flying time to Philadelphia International
Airport, and a 30-minute car ride from Philadelphia International to Wilmington, Delaware. The
foregoing does not take into account recommended early arrival times at airports for check-in,
flight delays, traffic, or the need for overnight stays in Wilmington.
7. The Debtors corporate forms include corporations and limited liability
companies formed in both Texas and Delaware. The Debtors corporate family includes the
following entities:

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In April 2013, Energy Future Competitive Holdings Company, a Texas corporation and the
immediate corporate parent of TCEH, was converted to Energy Future Competitive Holdings
Company LLC (EFCH), a Delaware limited liability company.
A. The Debtors Operations And Customers Are All In Texas.
8. EFH, the parent entity of the affiliated Debtors, is a Dallas, Texas-based energy
company with a portfolio of competitive and regulated energy businesses in Texas, employing
approximately 9,100 full-time employees, as of December 31, 2012, of whom approximately
2,840 are under collective bargaining agreements. See EFH, Annual Report (Form 10-K) (Feb.
19, 2013) (EFH 10-K) (Appendix A), at 1, 2. EFH conducts its operations principally through
its TCEH and Oncor subsidiaries. See id. at 1. TCEH, through its subsidiaries, is engaged in
competitive electricity market activities in Texas including electricity generation, wholesale

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energy sales and purchases, commodity risk management and trading activities, and retail
electricity sales. See id. Additionally, the Debtors are one of the largest purchasers of wind-
generated electricity in Texas. See id. at 1, 7. Their total wind power portfolio exceeds 900
MW, with projects involving transmission lines and power stations throughout Texas servicing
the state. See id. at 14, 51.
9. The Debtors operate primarily within the Electric Reliability Council of Texas
(ERCOT) market, whose members provide approximately 85% of the electricity consumed in
Texas. See id. at 2. ERCOT is governed by a board of directors and subject to oversight by the
Public Utility Commission of Texas (the PUCT) and the Texas Legislature, and its reliability
standards are enforced by Texas Reliability Entity, Inc.
3
See About ERCOT,
http://www.ercot.com/about/ (last visited March 25, 2014) (Appendix B); EFH 10-K (Appendix
A), at 8. Concentrated in Texas, ERCOT and its members have limited interconnections to
other markets in the US and Mexico[.] EFH 10-K (Appendix A), at 3. Additionally, the
Debtors play a vital role in the ERCOT market, assisting ERCOT in its operations, as well as
working in concert with other ERCOT utilities to obtain regulatory approvals for, as well as plan,
design, and construct, new transmission lines in order to remove existing constraints on the
ERCOT transmission grid. See id. at 2.
10. The Debtors stated growth strategies are focused almost entirely on the Texas
and ERCOT markets, and on improving their respective positions within those markets. See id.
at 3-4 (committing to [b]eing an integral part of the communities in which we live, work and

3
Texas Reliability Entity, Inc. is the Federal Energy Regulatory Commission-approved
Regional Entity for the ERCOT region, as authorized by the Energy Policy Act of
2005. It is authorized by the PUCT to investigate compliance with the ERCOT Protocols
and Operating Guides, working with PUCT staff regarding any potential protocol
violations.


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serve; expect[ing] to pursue growth opportunities across our existing business lines, including
a focus on generation development opportunities to help meet ERCOTs growing electricity
needs over the longer term; working with ERCOT to develop policies and protocols that
provide appropriate pricing signals that encourage the development of new generation to meet
rising demand within the ERCOT market; increasing the number of retail customers served
through the ERCOT market; and investing in transmission and distribution to meet the needs of
the growing Texas market). In the past five years alone, Energy Future Holdings has
spent more than $10 billion in investments across Texas for new projects and to improve [its]
facilities. See News Release, Energy Future Holdings Corporation, Luminant Response to
Ongoing Environmental Activism Campaign (Aug. 28, 2013) (Appendix C).
11. Through those investments and others, TCEH, through subsidiary TXU Energy,
serves approximately 1.75 million residential and commercial retail electricity customers in
Texas. See EFH 10-K (Appendix A), at 8. TXU Energy currently provides retail electric
service to all areas of the ERCOT market open to competition, including the Dallas/Fort Worth,
Houston, Corpus Christi, and lower Rio Grande Valley areas of Texas. See id. It is a licensed
retail electric provider under the Texas Electric Choice Act and, as such, subject to the
jurisdiction of the PUCT. See id. at 8.
12. TCEH has the largest generation fleet in Texas, and its continuing operation is
critical to serving customers and maintaining orderly electric service. In that regard, ERCOT is
in the final phases of a complex multi-year process to address generation resource adequacy and
system reliability that will have major implications for TCEH, millions of electric customers, and
system reliability. TCEH has been and is expected to continue to be a major participant in those

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significant ERCOT proceedings and the results of those proceedings will have a major impact on
TCEHs future business and revenues.
13. Additionally, Oncor, a subsidiary of EFH that operates the largest transmission
and distribution system in Texas, is responsible for an electric transmission and distribution
service territory that delivers electricity to more than 3.2 million homes and businesses and
operates more than 119,000 miles of transmission and distribution lines. See EFH 10-K
(Appendix A), at 1. Its transmission and distribution rates are regulated by the PUCT. See id. at
9. In particular, it is subject to detailed ring fencing provisions and other PUCT regulations by
which the PUCT must review and approve any significant restructuring activities that may
involve a change of control, debt incurrence, and/or dividend policies so as to protect the
interests of millions of Texas electric ratepayers.
B. Texas Regulators Have A Direct Interest
And Will Have An Active Role In These Cases.

14. The Debtors are subject to a number of Texas state regulatory schemes, and Texas
regulators and authorities will have myriad interests in these cases. For example, in the Debtors
April 15, 2014 Form 8-K filing, the Debtors noted the potential material impact of actions by,
inter alia, the Texas Legislature, the Governor of Texas, the Texas Reliability Entity, Inc., the
PUCT, the Railroad Commission of Texas (the RRC), and the Texas Commission on
Environmental Quality. See Energy Future Holdings Corporation April 15, 2014 Form 8-K
(Cautionary Statement Regarding Forward-Looking Statements). Actions by these parties could
be expected to affect the Debtors allowable pricing scheme, allowed rates of return, permitted
capital structure, rate structure, operations of the Debtors production facilities, operations of the
Debtors coal mines necessary to fuel certain of their plants, and/or acquisition or disposal of
assets or facilities, or decommissioning of assets. See id.

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15. In particular, as a Texas utility, the Debtors are regulated by, among others, the
PUCT, whose rules establish robust oversight, certain limits and a framework for wholesale
power pricing and market behavior. See EFH 10-K (Appendix A), at 9. The Debtors are also
subject to the requirements of the ERCOT Protocols, including Nodal Protocols and ERCOT
reliability standards adopted and enforced by, among others, the Texas Reliability Entity, Inc.
See id. at 10. In fact, given the centralization of operations in Texas, certain of the Debtors and
their affiliates are governed solely by Texas regulatory authorities, and are not subject to federal
oversight. See id. at 11 (As its operations are wholly within Texas, Oncor is not a public utility
as defined in the Federal Power Act and, as a result, it is not subject to general regulation under
the Act.). The above Texas regulatory bodies will certainly be actively interested and involved
in the Chapter 11 Cases.
16. In addition to general environmental oversight by the Texas Commission on
Environmental Quality,
4
the Debtors are also subject to regulatory oversight by the RRC.
Luminant Generation Company LLC (Luminant Generating), a subsidiary of TCEH, is the
third-party guarantor of Luminant Mining Company LLCs (Luminant Mining) self-bond for
certain coal mine sites in Texas. The self-bond assures performance of certain environmental
remediation obligations of Luminant Mining (estimated to range between $850 million to $1.1
billion in EFHs November 1, 2013 10-Q), which arise under and are governed by, among other
statutory regimes, title 16 of the Texas Administrative Code (the TAC). Pursuant to TAC

4
Among other matters potentially affecting the Debtors, the Texas Commission on
Environmental Quality is currently considering a petition seeking adoption and
implementation of rules to limit emissions at three of the Debtors large coal-fired
generation facilities in North Texas. See Dallas County Medical Society, Physicians
Petition the State to Require EFHs Legacy Coal-Fired Power Plants to Reduce
Emissions to Current Standards to Protect Health of North Texans (Aug. 28, 2013)
(Appendix D), http://www.dallas-cms.org/news/dcms_petitionTCEQ_final.pdf.

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Section 12.314(b), the RRC, which is charged with, among other things, monitoring compliance
with the conditions of such bonds, may, inter alia: (a) increase the required amount of the
Debtors bonding obligations, see 16 TAC 12.307(a) & (d); (b) require the Debtors to post
bonds in addition to, or in replacement of, the current self-bond, and prohibit the Debtors from
continuing mining operations until such new bond is in place, see 16 TAC 12.309(j)(7); (c)
forfeit all or part of a bond if the operator defaults on the conditions under which the bond was
posted see 16 TAC 12.314(b); and/or (d) through the office of the Texas Attorney General,
commence an action in Texas state court against the Debtors in order to compel their compliance
with RRC orders, see Texas Govt Code 2001.202 and 16 TAC 12.309(j)(5)(E). As the
Debtors note, in the event of a default under the self-bond, TCEH may be required to post cash,
letters of credit or other tangible assets as collateral support in the amount currently estimated to
be approximately $850 million or $1.1 billion. EFH 10-K (Appendix A), at 35. The Debtors
may therefore face additional (and substantial) liability to certain Texas agencies in the event the
RRC exercises any rights it may have to forfeit the self-bond to which the Debtors are a party,
and there is no question that the RRC will be an important case participant.
17. Accordingly, applicable Texas regulatory, legislative, and executive bodies will
be vitally interested in these reorganization proceedings, and their express regulatory approval
may be required for any ultimate plan or plans that may be proposed. Presumably, such parties
will take the position that their respective regulatory actions are exempted from the automatic
stay, and may proceed apace in Texas notwithstanding the filing of these Chapter 11 cases.
C. Litigants With Potentially Significant Claims
In Texas Have An Interest In These Proceedings.

18. The Debtors are also involved in a number of lawsuits involving employment,
commercial, and environmental issues, and other claims for injuries and damages, among other
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matters. See EFH 10-K (Appendix A), at 33. Of the over 200 proceedings in which the Debtors
have been a party since 2012, approximately 95% are (or were) being litigated in state and
federal courts across Texas, including certain cases alleging environmental liability. Of those
cases being litigated in Texas state courts, nearly all have been brought in Dallas County. Not a
single case over that period involved Delaware state or federal courts. Attached hereto as
Exhibit B is a chart depicting the legal proceedings to which the Debtors have been a party since
2012.
D. Delaware Has Nominal Connections With These Debtors.
19. In contrast to the Debtors deep Texas roots, the Debtors connection to Delaware
is nominal. Upon information and belief: a) the Debtors do not have any employees, assets, or
operations in Delaware; b) the Debtors do not conduct business in, or provide any services to,
Delaware; c) the Debtors are not subject to any Delaware regulatory oversight; and d) none of
the Debtors books, records, officers, or directors are located in Delaware. Even those entities
incorporated in Delaware, along with those corporations and limited liability companies
incorporated in Texas, are all headquartered in Dallas, Texas.
5

RELIEF REQUESTED
20. By this Motion, the Trustee requests entry of an Order, substantially in the form
attached hereto as Exhibit A, transferring these Chapter 11 Cases to the United States District
Court for the Northern District of Texas in the interest of justice and/or for the convenience of

5
TCEH, EFCH, Energy Future Intermediate Holdings Company LLC (EFIH), and
Oncor Electric Delivery Company (Oncor) are organized as Delaware limited liability
companies. Parent company EFH is a Texas corporation, and Luminant Generation
Company LLC (Luminant) and TXU Energy Retail Company LLC (TXU Energy)
are organized as Texas limited liability companies. As noted above, until April 2013,
EFCH was a Texas corporation.
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the parties, pursuant to 28 U.S.C. 1408 and 1412, Bankruptcy Rule 1014, and Section 105(a)
of the Bankruptcy Code.
BASIS FOR RELIEF REQUESTED
21. Section 1408 of title 28 of the United States Code sets forth the venues in which a
case brought under title 11 may be commenced. That provision provides:
Except as provided in section 1410 of this title [pertaining to cases ancillary to
foreign proceedings], a case under title 11 may be commenced in the district court
for the district
(1) in which the domicile, residence, principal place of business in the United
States, or principal assets in the United States, of the person or entity that is
the subject of such case have been located for the one hundred and eighty days
immediately preceding such commencement, or for a longer portion of such
one-hundred-and-eighty-day period than the domicile, residence, or principal
place of business, in the United States, or principal assets in the United States,
of such person were located in any other district; or
(2) in which there is pending a case under title 11 concerning such persons
affiliate, general partner, or partnership.

28 U.S.C. 1408. Similarly, Bankruptcy Rule 1014 provides:
If a petition is filed in the proper district, the court, on the timely motion of a
party in interest or on its own motion, and after hearing on notice to the
petitioners, the United States trustee, and other entities as directed by the court,
may transfer the case to any other district if the court determines that the transfer
is in the interest of justice or for the convenience of the parties.
Fed. R. Bankr. P. 1014.
22. Where venue is proper in multiple districts under Section 1408, a party-in-interest
may seek to have the case transferred to another proper venue. See 28 U.S.C. 1412 (A district
court may transfer a case or proceeding under title 11 to a district court for another district, in the
interest of justice or for the convenience of the parties.); see also In re Statewide Theatres
Corp., 4 F. Supp. 86, 87 (D. Del. 1933) (finding expansive standing for parties to challenge
venue when noting parties in interest include not only general unsecured creditors but secured

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creditors, the bankrupt, and every other party whose pecuniary interest is affected by the
proceedings) (emphasis added).
23. The Court is authorized to transfer venue for a chapter 11 case where: a) the
transfer is in the interest of justice; or (b) for the convenience of the parties. See 28 U.S.C.
1412; see also The Paul H. Shield, MD, Inc. Profit Sharing Plan v. Northfield Labs. Inc. (In re
Northfield Labs. Inc.), 467 B.R. 582, 590 (Bankr. D. Del. 2010) (BLS) (Section 1412 is phrased
in the disjunctive and a proceeding is subject to transfer upon a sufficient showing that either the
interest of justice or the convenience of the parties is met.); In re LaGuardia Assocs., L.P., 316
B.R. 832, 837 (Bankr. E.D. Pa. 2004) (It has been observed that 1412 is [ ] written in the
disjunctive, making transfer of venue appropriate either in the interest of justice or for the
convenience of parties, and that statutory provision creates two distinct analytical bases upon
which transfer of venue may be grounded.) (citation omitted) (emphasis in the original).
24. Here, both prongs of this disjunctive test are satisfied. The Debtors are
headquartered and centralized in the Dallas/Fort Worth area, where bankruptcy cases are
administered by the United States Bankruptcy Court for the Northern District of Texas. The
Debtors connections to Delaware do not extend beyond paper. The Debtors primary trade
creditors, all of their customers, as well as the concentration of their assets, are located in Texas.
The United States Bankruptcy Court for the Northern District of Texas is as well-suited, or
better-suited, to handle the numerous Texas-specific issues that will inevitably arise in these
cases given the integral role the Debtors play in one of Texas largest economic centers, the
Texas regulatory regimes to which the Debtors are subject, and the interests of the State of Texas
and millions of Texas electric customers in the Debtors restructuring effort.

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25. Delaware courts will consider a host of factors, weighing those factors differently
based on the facts and circumstances of each case: (1) plaintiffs original choice of forum; (2)
defendants forum preference; (3) whether the claim arose elsewhere; (4) location of books and
records and/or the possibility of viewing premises, if applicable; (5) convenience of the parties as
indicated by their relative physical and financial condition; (6) convenience of the witnesses; (7)
enforceability of the judgment; (8) practical considerations that would make the trial easy,
expeditious, or inexpensive; (9) the relative administrative difficulty in the two fora resulting
from congestion of the courts dockets; (10) the public policies of the fora; (11) the familiarity of
the judge with the applicable state law; and (12) the local interest in deciding local controversies
at home. See Zazzali v. 1031 Exch. Grp. (In re DBSI, Inc.), 478 B.R. 192, 194-95 (Bankr. D.
Del. 2012); see also Jumara v. State Farm Ins. Co., 55 F.3d 873, 879 (3d Cir. 1995) (listing
factors within the context of 28 U.S.C. 1404(a)); In re Innovative Commcn Co., LLC, 358
B.R. 120, 126-27 (Bankr. D. Del. 2006) (holding the Jumara factors relevant to transfers of
venue in the context of section 1412). In addition, courts also have discretion to consider other
private and public interest factors. In re Qualteq, Inc., No. 11-12572, 2012 WL 527669, at *5
(Bankr. D. Del. Feb. 16, 2012) (KJC). Considered both individually and collectively, these
factors overwhelmingly weigh in favor of granting the relief requested in the Motion.
A. Transferring The Chapter 11 Cases To The
United States District Court For The Northern
District Of Texas Would Be In The Interest Of Justice.

26. Of the host of factors considered by courts, [i]t is oft-repeated that the factor
accorded the most weight is promotion of the economic and efficient administration of the
estate. Id., at *6; see DBSI, 478 B.R. at 198 (noting that the forum in which the debtor has its
primary operations is favored); DHP Holdings II Corp. v. The Home Depot, Inc. (In re DHP

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Holdings II Corp.), 435 B.R. 264, 275 (Bankr. D. Del. 2010) (transferring venue after noting that
[u]ltimately, however, the most important consideration is whether the requested transfer would
promote the economic and efficient administration of the estate) (citation and quotations
omitted). Promotion of the economic and efficient administration of the estate is also the central
factor considered when evaluating the interest of justice. See Qualteq, 2012 WL 527669, at *6;
see Laguardia Assocs., 316 B.R. at 837 ([T]he interest of justice component of 1412 is a
broad and flexible standard which must be applied on a case-by-case basis. It contemplates a
consideration of whether transferring venue would promote the efficient administration of the
bankruptcy estate, judicial economy, timeliness, and fairness. . . .) (quoting Gulf States
Exploration Co. v. Manville Forest Prods. Corp. (In re Manville Forest Prods. Corp.), 896 F.2d
1384, 1391 (2d Cir. 1990)); see also Northfield Labs., 467 B.R. at 590 (listing the factors
typically considered in relation to the interests of justice test to include: (i) whether transfer
promotes the economic and efficient administration of the bankruptcy estate; (ii) whether transfer
facilitates judicial efficiency; (iii) whether the parties will receive a fair trial in either venue; (iv)
whether either forum has an interest in deciding the controversy; (v) whether transfer would
affect enforceability of any judgment rendered; and (vi) whether the plaintiff's original choice of
forum should be disturbed). In applying this test, a court must consider what will promote the
efficient administration of the estate, judicial economy, timeliness and fairness. Qualteq, 2012
WL 527669, at *6 (citation omitted).
27. At bottom, efficiency and fairness dictate that these Chapter 11 Cases be
transferred to the Northern District of Texas. From an efficiency point of view, transferring
these cases to the Northern District of Texas will allow key members of management to continue
doing their jobs, which is critical for value preservation, rather than spending extended time

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traveling to and from Delaware where they will be far less productive. The Fifth Circuit
recognized the importance of centralizing restructuring efforts around a management team
during the restructuring process in the seminal case of Commonwealth of Puerto Rico v.
Commonwealth Oil Refinery Co. (In re Commonwealth Oil Refinery Co.), 596 F.2d 1239 (5th
Cir. 1979) (CORCO):
On the efficiency side, San Antonio is clearly the favored district. The heart of
the Chapter XI proceeding is working up a financial plan of arrangement
acceptable to all the parties. The people charged with this responsibility in [the
debtors] management are all located in San Antonio.
Id. at 1247. In addition, given the location and nature of the Debtors assets, substantially all of
which are located in Texas, most material witnesses will be located in Texas, a fact that weighs
heavily in favor of transferring these cases to the Northern District of Texas. See In re Lakota
Canyon Ranch Dev., LLC, No. 11-03739-8, 2011 WL 5909630, at *3 (Bankr. E.D.N.C. June 21,
2011) (transferring cases to Colorado after determining, among other things, that [b]ecause of
the location and nature of the Debtors assets, the appraisers, and real estate sales experts will
most likely be from Colorado and so the estate and secured lenders should not have to bear the
cost of transporting those witnesses, especially where the only material witness living in the
jurisdiction where the debtors filed was the member/manager of the Debtors limited liability
company). That those controlling the venue decision would choose Delaware, with its attendant
need for key management personnel and witnesses to be distanced from the locations where they
work and live, begs the question of what motive drove the venue decision in these cases.
28. While certain professionals based in the Northeast and/or lenders (including the
Trustee and the Second Liens) may have to travel farther, or participate telephonically, such is of
little moment if the goal is to maximize estate value and appropriately restructure the Debtors.
In a recent decision to transfer venue to Texas, this Court recognized that advances in technology

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create a relative measure of seamlessness between professionals, regardless of their proximity
to the proceeding. See Transcript of Oral Argument at 86:18-87:3, In re Goldking Holdings,
LLC, No. 13-12820 (BLS) (Bankr. D. Del. Nov. 20, 2013) (Appendix E). The same is true of
any secured lenders residing in the Northeast. See Transcript of Oral Argument at 76:22-77:2, In
re DesignLine Corp., No. 13-12089 (Bankr. D. Del. Sept. 4, 2013) (Appendix F) ([I]t is
important to make sure the unsecureds participate in the case to assure that everything [is] just
not railroaded through based on an assumption that the secured creditors are the only ones with
an interest).
29. As to fairness, there is certainly nothing unfair about transferring these cases to a
venue in which state regulators, employees, customers, trade creditors, and numerous other
parties in interest may participate in the restructuring process. The Debtors are centralized in a
venue, the Northern District of Texas, that is well-positioned to handle these cases and readily
accessible to all parties in interest. The decision to file these cases so far from the location of the
Debtors businesses raises the specter of forum shopping to effect a particular restructuring goal.
30. Moreover, EFH, as the parent of the Debtor entities, is a Texas corporation based
in Dallas, Texas and employing approximately 9,100 full-time employees (substantially all in
Texas). TCEHs approximately 1.75 million residential and commercial retail electricity
customers, who have a vested interest in the outcome of these Chapter 11 Cases, live across the
Dallas/Fort Worth, Houston, Corpus Christi, and lower Rio Grande Valley areas of Texas.
Nearly all, if not all, of the Debtors substantial assets are located in Texas, and nearly all of the
essential parties to the Debtors restructuring reside in Texas, including numerous trade creditors
and the Debtors key executives. Moreover, those Texas regulatory bodies, including the PUCT,
ERCOT, and the RRC, which are vitally interested in these Chapter 11 Cases, and, in some

"##$%&#'()*( + 18

cases, may have critical regulatory approval rights in connection with an ultimate plan of
reorganization, are obviously based in Texas. One of the members of the Debtors Sponsor
Group, TPG Capital, is headquartered in Fort Worth, Texas, which is within the Northern
District of Texas. Transferring the Chapter 11 Cases to the Northern District of Texas, where the
material parties to the restructuring are located, would promote the economic and efficient
administration of the estate, a factor Delaware courts have recognized as the one accorded the
most weight. Qualteq, 2012 WL 527669, at *6.
31. The other factors courts consider are similarly satisfied here. The Delaware
bankruptcy docket is significantly more congested than that of the Northern District of Texas,
meaning the requested transfer would promote judicial efficiency. See In re Apple, Inc., 602
F.3d 909, 915 (8th Cir. 2010) (Docket congestion is a permissible factor to consider . . . .); Gro
Master, Inc. v. Farmweld, Inc., 920 F. Supp. 2d 974, 993 (N.D. Iowa 2013) (Factors that the
court has found are frequently relevant to the interests of justice issue include . . . comparative
congestion of dockets.). For the 12-month period ended December 31, 2013, there were 807
chapter 11 cases filed in this Court, compared with the 233 chapter 11 cases filed in the Northern
District of Texas. See U.S. Bankruptcy Courts Business and Nonbusiness Cases Commenced,
by Chapter of the Bankruptcy Code, During the 12-Month Period Ending Dec. 31, 2013,
http://www.uscourts.gov/uscourts/Statistics/BankruptcyStatistics/BankruptcyFilings/2013/1213_
f2.pdf (last visited March 30, 2014) (Appendix H). The six judges sitting in the Bankruptcy
Court for the District of Delaware either were or are, on average, responsible for approximately
134.5 chapter 11 cases each in that 12-month period; the six judges sitting in the Northern
District of Texas were or are, on average, each responsible for 38.8 chapter 11 cases during the
same period.

"##$%&#'()*( + 19

32. The effect of transfer on the ability for the parties to receive a fair trial is, at best,
neutral. While the Trustee is confident both courts would fairly apply the uniform laws of the
federal Bankruptcy Code, a Texas bankruptcy court will have experience applying the myriad
Texas state laws that will arise in these cases. Also, based on the Debtors integration into the
State of Texas, including both the states economy and the continued development of the states
energy market, Texas is the forum that has a clear interest in adjudicating the Chapter 11 Cases.
See Northfield Labs., 467 B.R. at 590 (granting a motion to transfer venue after determining,
inter alia, that the venue to which the movant sought to transfer the case had an interest in
deciding the controversy . . . that relates to occurrences within its jurisdiction). Ultimately, the
Debtors deep Texas roots favor the transfer of venue, since there is a local interest in deciding
local controversies at home. In re Amendt, 169 F. Appx 93, 97 (3d Cir. 2006) (citation and
quotations omitted).
33. Texas is also the forum for nearly all of the Debtors pending state and federal
litigation. The Debtors are involved in a number of lawsuits involving employment,
commercial, and environmental issues, and other claims for injuries and damages, among other
matters. EFH 10-K (Appendix A), at 33. Of the over 200 proceedings in which the Debtors
have been a party since 2012, approximately 95% are being or were litigated in state and federal
courts across Texas, including certain cases alleging environmental liability. Of those cases
being litigated in Texas State courts, nearly all have been brought in Dallas County. No cases
are being litigated in Delaware state or federal courts.
34. To the extent those claims pending in other Texas state and federal courts may
affect the res of the estate, the interest of justice favors the transfer and consolidation of those
cases. See Brown v. Wells Fargo, N.A., 463 B.R. 332 (M.D.N.C. 2011) (granting motion to

"##$%&#'()*( + 20

transfer venue after determining that the interest of justice strongly favors transfer if pending
claims can be tried concurrently with [a debtors] bankruptcy proceedings because that would
promote the economic and efficient administration of the bankruptcy estate) (citation and
internal quotations omitted); Doss v. Chrysler Grp., LLC, No. 09-02130, 2009 WL 4730932, at
*5 (D. Az. 2009) (transferring case after noting that cases should be transferred to districts
where related actions are pending) (citation and quotations omitted). The need to transfer the
bankruptcy to the forum where pending actions exist may be particularly acute where the debtor
is subject to environmental liability in its home forum. See, e.g., In re Standard Tank Cleaning
Corp., 122 B.R. 174 (Bankr. E.D.N.Y. 1990) (granting motion to transfer venue to District of
New Jersey where a majority of debtors creditors resided and debtor was party to an action for
environmental liability); see also Doehler-Jarvis Ltd. Pship v. U.S. Die Casting & Dev. Co., No.
92-2206, 1993 WL 96528, at *2 (N.D. Ill. Mar. 31, 1993) (granting motion to transfer venue
where there were existing lawsuits in the transferee forum rooted in environmental liability after
noting that the existence of related litigation in the transferee court strongly supports a motion
to transfer).
35. There is litigation pending in both Texas state and federal courts that, depending
on the outcome, may affect the size of the Debtors estate and, ultimately, recoveries for the
largely Texas-based body of trade creditors. Also, the Debtors may have liability to the State of
Texas in excess of $1 billion in the event certain conditions are satisfied that prompt the Railroad
Commission of Texas to forfeit the self-bond to which the Debtors are a party.
36. The Railroad Commission of Texas is but one of a number of the Texas state
agencies that have an interest in the outcome of these Chapter 11 Cases. The Debtors are deeply
involved in the ERCOT market, which is heavily regulated by the PUCT and the Texas

"##$%&#'()*( + 21

Legislature. ERCOT is in the final phases of a complex multi-year proceeding to address
generation resource adequacy and system reliability that will have major implications for TCEH,
millions of electric customers, and system reliability. TCEH has been and will continue to be a
major participant in those significant ERCOT proceedings
37. The PUCT also regulates the transmission and distribution rates of Oncor, a
subsidiary that operates the largest transmission and distribution system in Texas. Oncor is
subject to detailed ring fencing provisions and other PUCT regulations by which the PUCT
must review and approve any significant restructuring activities that may involve a change of
control, debt incurrence, and/or dividend policies so as to protect the interests of millions of
Texas electric ratepayers. Thus, the PUCT will necessarily be involved in these Chapter 11
Cases and may even have critical regulatory approval rights over an ultimate plan of
reorganization.
38. Proactive participation by such entities in a positive restructuring outcome of the
Debtors estates would likely be materially advanced if the cases were transferred to the
Northern District of Texas. Indeed, Moodys Investor Services has commented that EFH
[p]ursuing bankruptcy is a credit negative because it heightens the risk of regulatory
intervention. Moodys Investor Services, Energy Future Holdings Restructuring Would Risk
Regulatory Intervention, A Credit Negative (Aug. 8, 2013) (Appendix G). [T]he closer
[EFHs] bankruptcies get to Oncor, EFHs regulated utility unit, the higher the likelihood for
political intervention and regulatory scrutiny over the bankruptcy restructuring process. Id.
39. While the Debtors venue choice may be given some weight, all of the remaining
relevant factors overwhelmingly favor transfer. Accordingly, the Court [should] accord [ ] little
weight to [the Debtors] chosen forum . . . . Northfield Labs., 467 B.R. at 591; see Clark v.
Case l4-l0978-CSS Doc 2 Filed 04/29/l4 Page 2l of 28

"##$%&#'()*( + 22

Chrysler Grp., LLC, No. 10-3030, 2010 WL 4486927, at *9 (Bankr. E.D. Pa. Nov. 5, 2010)
(consider[ing] Plaintiffs choice of forum and the convenience afforded to Plaintiff in allowing
the parties to litigate the matter in Pennsylvania but nevertheless transferring the action to the
Bankruptcy Court for the Southern District of New York because plaintiffs choice of forum was
outweighed by those factors that promoted venue transfer in the interest of justice and for the
convenience of the parties); Doehler-Jarvis, 1993 WL 96528, at *2 (noting that [s]ome
deference must be given to plaintiffs forum choice, but, where nearly every other factor which
enters into the transfer of venue equation favors transfer, the court will transfer venue); In re
Ocean Props. of Del., Inc., 95 B.R. 304, 305 (Bankr. D. Del. 1988) (granting motion to transfer
venue after explaining that, although the debtors choice of forum is entitled to great weight
where venue is proper, a venue transfer motion requires balancing this factor with several
others, including the proximity of the court to interested parties as well as the location of
assets, the economics of administering the estate and the relative economic harm to debtor and
other interested parties). Furthermore, this Court has categorically rejected the position that
Delaware is per se a superior jurisdiction for restructuring. See, e.g., Transcript of Oral
Argument at 67:18-68:6, In re Goldking Holdings, LLC, No. 13-12820 (BLS) (Bankr. D. Del.
Nov. 20, 2013) (Appendix E) (noting that the Court had previously categorically reject[ed] the
idea that . . . this Court, because of its experience, is a better forum); Transcript of Oral
Argument at 187:24-188:2, In re Qualteq, No. 11-12572 (KJC) (Bankr. D. Del. Dec. 16, 2011)
(refus[ing] to accept t[he] proposition . . . that . . . a debtor has a much better chance of a
successful reorganization here than in other places) (Appendix I).
40. Additionally, an element of judicial economy is whether either court has an
advantage on the learning curve relevant to the case. See In re EB Capital Mgmt. LLC, No.

"##$%&#'()*( + 23

11-12646, 2011 WL 2838115, at *5-6 (Bankr. S.D.N.Y. July 14, 2011) (granting motion to
transfer venue after finding, inter alia, that there has been no learning curve in this case
because this is the first motion pending before the Court). Given the numerous Texas state law
issues that will arise in these cases, and the experience of the bankruptcy bench in the Northern
District of Texas in dealing with such issues, it is respectfully submitted that if any court has a
shorter learning curve, it is the Bankruptcy Court in Texas. In addition, as the Chapter 11 Cases
were just commenced, this Court likely has not yet had the opportunity to familiarize itself with
the complexities of the Debtors financial affairs or business. As such, in the interest of
promoting judicial economy, the Trustee submits that these cases should be transferred to Texas
as soon as possible to avoid unnecessary expenditures of this Courts time and resources.
41. Moreover, the United States Bankruptcy Court for the Northern District of Texas
is the local court for the Debtors, their businesses, their customers, and the majority of their trade
creditors. These Chapter 11 Cases would benefit from being in a venue where the judge
presiding would more likely have active familiarity with the community and the milieu in which
the [Debtors operate]. Such a judge would be in a much better position to gauge the likelihood
of an effective reorganization. In re B.L. of Miami, Inc., 294 B.R. 325, 332 (Bankr. D. Nev.
2003). Although the Trustee is not suggesting that one court is superior to another in its ability
to preside over these proceedings, it does note that the Bankruptcy Courts in Texas have prior
experience in the conduct of chapter 11 proceedings involving debtors similar to these Debtors
(including the adjudication of complex valuation issues such as will likely be present in the
Debtors cases). See, e.g., In re Mirant Corp., Case No. 03-46590 (Bankr. N.D. Tex. 2003); see
also In re El Paso Elec. Co., Case No. 92-10148 (Bankr. W.D. Tex. 1992).

"##$%&#'()*( + 24

42. Considering all of the relevant factors, and focusing on promotion of the
economic and efficient administration of the estate, which Delaware courts consider the most
important factor in weighing the interest of justice, these cases should be transferred to the
Northern District of Texas.
B. Convenience Of The Parties Strongly Favors Transferring
The Chapter 11 Cases To The Northern District Of Texas.
43. While the Trustee believes the interest of justice test is satisfied and justifies
transfer of the Debtors cases to the Northern District of Texas, consideration of the
convenience of the parties test provides an independent basis for transferring these Chapter 11
Cases to the Northern District of Texas. When evaluating whether a transfer of venue would
further the convenience of the parties, courts in this district typically consider: (i) the location of
the plaintiff and defendant; (ii) the ease of access to necessary evidence; (iii) the convenience of
witnesses; (iii) the availability of subpoena power; and (iv) the expense of obtaining unwilling
witnesses. Northfield Labs., 467 B.R. at 591 (focusing on where the causes of action arose, the
companys primary place of business, the location of the companys business records, and the
location of the parties to the action when determining the convenience of the parties); see
CORCO, 596 F.2d at 1242 (articulating what has been come to be known as the CORCO
factors); Qualteq, 2012 WL 527669, at *6, n.8 (noting that courts have adopted the wellworn
six-factor test that considers (a) proximity of creditors of every kind to the court; (b)
proximity of the debtor; (c) proximity of witnesses who are necessary to the administration of the
estate; (d) the location of the debtors assets; (e) the economic administration of the estate; and
(f) the necessity for ancillary administration in the event of liquidation).
44. Despite the Debtors having a corporate presence in Delaware, their headquarters,
operations, and books and records exist almost exclusively in Texas, as do substantially all of

"##$%&#'()*( + 25

their assets and employees. Nearly all of the Debtors officers and executives, who will be
necessary to any successful reorganization, reside and work in Texas. Given their importance in
the restructuring, it would be particularly onerous to require those officers to leave their home
offices and travel from Texas to Delaware to participate in these Chapter 11 Cases. But, even if
they were required to travel to participate in these proceedings, the convenience of other
interested parties is paramount. See Ocean Props. of Del., 95 B.R. at 307 (granting motion to
transfer venue after noting that, although a venue transfer may result in nominally higher costs
for the debtors to administer their estates, [t]he cost to Debtors is considerably less than the total
cost other interested parties would have to incur to participate in these reorganizations).
45. It appears that the only substantial creditors residing outside of Texas are certain
of the Debtors bondholders. This Court recently noted that the location of a debtors general
unsecured creditors was more important when determining whether a particular venue was
convenient for the parties. See Transcript of Oral Argument at 76:22-77:2, In re DesignLine
Corp., No. 13-12089 (Bankr. D. Del. Sept. 4, 2013) (Appendix F) (rejecting argument that
convenience for secured lenders is of utmost importance and noting that it is important to make
sure the unsecureds participate in the case to assure that everything [is] just not railroaded
through based on an assumption that the secured creditors are the only ones with an interest).
Furthermore, as a practical matter, and as this Court also noted, secured lenders are in the best
position to pay to go to the state where the general unsecured, and typically not as well
financed, creditors reside. Id. at 77:7-11.
6

6
Even giving due consideration to the convenience of those parties not residing in Texas,
including certain of the Debtors bondholders, there is little material difference between
traveling from New York City to Wilmington, Delaware versus traveling from New York
City to Dallas-Fort Worth International Airport. Upon information and belief, the
majority of parties who are not already located in Texas, as well as their counsel and

"##$%&#'()*( + 26

46. That certain of the Debtors are incorporated in Delaware should bear little weight
in determining the convenience of the parties. See Innovative Commcn, 358 B.R. at 127-28
(granting motion to transfer venue after weighing the interest of justice and convenience factors
and explaining that the place of incorporation is not the controlling factor in the courts
analysis); In re Ofia Realty Corp., 74 B.R. 574, 577 (Bankr. S.D.N.Y. 1987) (granting motion to
transfer after finding that the debtors only connection to New York was its corporate registration
and the residence of the debtors sole shareholder and president, meaning Texas was the proper
venue, since its managing agent, its assets and its creditors are located [in Dallas] and [that is]
where its business transactions were conducted).
47. As previously stated, the Debtors are party to a number of pending lawsuits,
nearly all of which are being litigated in state and federal courts in Texas. Given that
substantially all of the Debtors operations, books and records, assets, and employees are located
in Texas, the convenience of the parties weighs in favor of transferring these Chapter 11 Cases to
the Debtors home state, where parties to the pending actions can participate in the bankruptcy
proceedings. See Northfield Labs., 467 B.R. at 590 (determining that convenience of the parties
is best served by trying cases in the forum where the alleged misconduct giving rise to those
claims occurred, especially where a number of parties to the proceedings were residents of that
forum, the defendants principal place of business and business records were located there, and
many of the defendants were present in that forum); In re Contl Airlines, Inc., 133 B.R. 585,

representatives, reside in the New York City area, not Delaware. Requiring those well-
funded parties to travel three (3) hours by plane to Texas, rather than 1 1/2 hours by train
to Delaware, is not overly burdensome in light of the location of most trade creditors in
or around the Northern District of Texas. Accord Transcript of Oral Argument at 77:23-
78:15, In re DesignLine Corp., No. 13-12089 (Bankr. D. Del. Sept. 4, 2013) (Appendix
F) (determining that there was no material difference between North Carolina and
Delaware for the travel times of secured lenders and the debtors professionals residing in
New York City and Atlanta).

"##$%&#'()*( + 27

588 (Bankr. D. Del. 1991) (considering the inconvenience and additional expense in defending
[a] suit in a distant forum as factors favoring venue transfer).
48. Based on the location of the Debtors assets, principal place of business,
executives, employees, customers, books and records, potential witnesses, regulators, and trade
creditors, the convenience of the parties overwhelmingly favors granting the relief requested in
this Motion.
NO PRIOR REQUEST
49. No prior motion for the relief requested herein has been made to this Court or any
other court.
NOTICE
50. Notice of this Motion has been given to (a) counsel to the Debtors; (b) the Office
of the United States Trustee; (c) the Debtors postpetition lenders; and (d) parties who have filed
notices of appearance. The Trustee respectfully submits that no other or further notice need be
given.
CONCLUSION
WHEREFORE, for the reasons stated herein, the Trustee respectfully requests that this
Court enter an Order, pursuant to 28 U.S.C. 1408 and 1412, Bankruptcy Rule 1014, and
Section 105(a) of the Bankruptcy Code, substantially in the form attached hereto as Exhibit A: (i)
transferring these Chapter 11 Cases to the United States District Court for the Northern District
of Texas; and (ii) granting the Trustee such other and further relief as this Court may deem just
and proper.


"##$%&#'()*( + 28

Dated: April 29, 2014 /s/William P. Bowden
Wilmington, Delaware ASHBY & GEDDES, P.A.
William P. Bowden [I.D. #2553]
Gregory A. Taylor [I.D. #4008]
500 Delaware Avenue
P.O. Box 1150
Wilmington, Delaware 19899
Telephone: (302) 654-1888
Facsimile: (302) 654-2067

- and -

BROWN RUDNICK LLP
Edward S. Weisfelner (pro hac vice
pending)
Seven Times Square
New York, New York 10036
Telephone: (212) 209-4800
Facsimile: (212) 209-4801

- and -

Jeffrey L. Jonas (pro hac vice pending)
Andrew P. Strehle (pro hac vice pending)
Jeremy B. Coffey (pro hac vice pending)
One Financial Center
Boston, Massachusetts 02111
Telephone: (617) 856-8200
Facsimile: (617) 856-8201

- and -

Howard L. Siegel (pro hac vice pending)
185 Asylum Street
Hartford, CT 06103
Telephone: (860) 509-6500
Facsimile: (860) 509-6501

Counsel to Wilmington Savings Fund
Society, FSB, solely in its capacity as
successor Indenture Trustee for the Second
Liens

{00853071;v1 }

Exhibit A
Proposed Order
Case l4-l0978-CSS Doc 2-l Filed 04/29/l4 Page l of 3
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

In re:

Energy Future Holdings Corporation, et al.,

Debtors.

Chapter 11

Case No. 14- (---)

Joint Administration Pending

Related to Docket No. ___

ORDER TRANSFERRING VENUE OF THESE CHAPTER 11
PROCEEDINGS TO THE UNITED STATES
DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

Upon consideration of the motion, dated April 29, 2014 (the Motion),
1
of
Wilmington Savings Fund Society, FSB as successor trustee under that certain indenture, dated
as of October 6, 2010 (as amended or supplemented), among Texas Competitive Electric
Holdings, LLC (TCEH), TCEH Finance, Inc., the guarantors party thereto, and The Bank of
New York Mellon Trust Co., N.A., as trustee, for an order, pursuant to 28 U.S.C. 1408 and
1412, Rule 1014 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules) and
Section 105(a) of title 11 of the United States Code (the Bankruptcy Code), transferring venue
of the above captioned chapter 11 cases (the Chapter 11 Cases) to the United States District
Court for the Northern District of Texas, as set forth in the Motion; and it appearing that the
Court has jurisdiction over this matter; and due and proper notice of the Motion has been given,
and no other or further notice is required; and it further appearing that the relief requested in the
Motion is in the best interests of the Debtors, their estates, and their creditors; and after due
deliberation and sufficient cause appearing therefore; it is
ORDERED that the Motion is granted; and it is further

1
Unless otherwise defined herein, capitalized terms shall have the meaning ascribed to
them in the Motion.
Case l4-l0978-CSS Doc 2-l Filed 04/29/l4 Page 2 of 3

"##$%&#'()*( + 2

ORDERED that the Chapter 11 Cases are hereby transferred to the United States
District Court for the Northern District of Texas; and it is further
ORDERED that the Debtors are authorized and empowered to take such actions
as may be necessary and appropriate to implement the terms of this Order.

Dated: Wilmington, Delaware
____________, 2014

____________________________________
UNITED STATES BANKRUPTCY JUDGE

Case l4-l0978-CSS Doc 2-l Filed 04/29/l4 Page 3 of 3

Exhibit B
Debtors' Legal Proceedings Since 2012

Case l4-l0978-CSS Doc 2-2 Filed 04/29/l4 Page l of 9
Litigation: Source Documents

The Source Documents section shows up to 250 of the most recent court documents for litigation events included in the company's
Litigation Profile report. To view the full text of a document on Westlaw, click its citation.

No. Document Title Doc. Type KNOS Court State Date
WL
Citation
1. CITY OF DALLAS v. MATTHEW MILLARD,
ONCOR ELECTRIC DELIVERY COMPANY, LLC,
DALLAS COUNTY
Docket 390.20 - Real Property ->
Condemnation
Texas - County Court -
Dallas County
TX 03/12/2014 CC-14-
01188-B
2. ONCOR ELECTRIC DELIVERY COMPANY, LLC
v. EDUARDO CARMONA
Docket - Texas - District Court -
Dallas County
TX 03/10/2014 DC-14-
02435
v. ISABEL GAMINO
Dallas County
TX 03/10/2014 DC-14-
02436
v. KEVEN MONZON, JULIO C. MONZON
Docket 430 - Torts/Negligence Texas - County Court -
Denton County
TX 02/28/2014 CV-2014-
00398
v. LATOYA FOREST
Docket 390 - Real Property Texas - District Court -
Dallas County
TX 02/28/2014 DC-14-
02054
v. ANA ESCOBAR
Dallas County
TX 02/07/2014 DC-14-
01326
7. ONCOR ELECTRIC DELIVERY COMPANY,
L.L.C. v. JACKIE DEASON
Dallas County
TX 02/07/2014 DC-14-
01234
8. ROBERTO MUNOZ v. RAUL RIOS, JR., ONCOR
ELECTRIC DELIVERY COMPANY LLC
Docket 430.87 - Torts/Negligence ->
Property Damage
430.87.05 - Torts/Negligence ->
Property Damage -> Motor Vehicle
Dallas County
TX 02/04/2014 CC-14-
00564-A
9. JAMES MILTON SCHUNKE v. ONCOR ELECTRIC
DELIVERY COMPANY LLC
Docket - Texas - Supreme Court TX 01/30/2014 14-0087
10. IN RE: ONCOR ELECTRIC DELIVERY
COMPANY, LLC
Dallas County
TX 01/13/2014 DC-14-
00291
11. ONCOR ELECTRIC DELIVERY COMPANY LLC
v. JOHN DOE ET AL
Personal Injury
Texas - District Court -
Dallas County
TX 01/10/2014 DC-14-
00255
12. STATE FARM LLOYDS AS SUBROGEE OF
HORTENSE HAYNES v. ONCOR ELECTRIC
DELIVERY COMPANY, LLC
Dallas County
TX 01/10/2014 DC-14-
00229
v. EMELY ESCOBEDO ET AL
Personal Injury
Dallas County
TX 01/08/2014 DC-14-
00151
v. MAGS TRUCKING, INC.
Dallas County
TX 01/07/2014 DC-14-
00077
v. PERIMETER INTERNATIONAL
Dallas County
TX 01/06/2014 DC-14-
00056
16. ESTELLA RAMSEY, ET AL v. RANDALL
SIMON, ET AL
Docket 430.72 - Torts/Negligence -> Motor
Vehicle
Dallas County
TX 12/30/2013 DC-13-
15205
17. CITY OF DALLAS v. DP RESOURCES, LLC,
ONCOR ELECTRIC DELIVERY COMPANY LLC,
DALLAS COUNTY, IN ITS OWN BEHALF AND
ON BEHALF OF DALLAS COUNTY
COMMUNITY COLLEGE DISTRICT, PARKLAND
HOSPITAL DISTRICT, AND DALLAS COUNTY
SCHOOL EQUALIZATION FUND, DALLAS
COUNTY ...
Condemnation
Dallas County
TX 12/23/2013 CC-13-
07113-A
v. PRECISION FENCING LLC
Dallas County
TX 12/18/2013 DC-13-
14815
v. ARTURO REYES
Dallas County
TX 12/18/2013 DC-13-
14844
20. Oncor Elec. Delivery Co. LLC v. Schunke Opinion - Texas - Court of
Appeals
TX 12/18/2013 2013 WL
6672494
v. ROBIN CARLSON, ET AL
Dallas County
TX 12/18/2013 DC-13-
14826
v. KYNOI SENESOURY, ET AL
Personal Injury
Dallas County
TX 12/16/2013 DC-13-
14832
23. Oncor Elec. Delivery Co., LLC v. Brockriede Opinion - Texas - Court of
Appeals
TX 12/12/2013 2013 WL
6564276
v. WILLIAM E. BROWN AND HELEN W. BROWN
AS TRUSTEES OF THE WILLIAM E. BROWN
AND HELEN W. BROWN REVOCABLE LIVING
TRUST
Condemnation
Texas - Court of
Appeals
TX 12/10/2013 07-13-
00428-CV
25. ONCOR ELECTRIC DELIVERY COMPANY LLC Docket 390.20 - Real Property -> Texas - Court of TX 12/10/2013 07-13-
(C) Thomson Reuters 1
Case l4-l0978-CSS Doc 2-2 Filed 04/29/l4 Page 2 of 9
v. WILLIAM E. BROWN AND HELEN W. BROWN
AS TRUSTEES OF THE WILLIAM E. BROWN
AND HELEN W. BROWN REVOCABLE LIVING
TRUST
Condemnation Appeals 00427-CV
v. CRISTOBAL QUINTARO-PALACIO, ET AL
Personal Injury
Dallas County
TX 11/27/2013 DC-13-
14038
v. VERNETTA BETHANY, ET AL
Personal Injury
Dallas County
TX 11/04/2013 DC-13-
13411
v. JORGE ECHEVESTE
Personal Injury
Dallas County
TX 11/04/2013 DC-13-
13213
v. MARIA MURGUIA
Personal Injury
Dallas County
TX 11/04/2013 DC-13-
13162
v. JOHN DOE, ET AL
Personal Injury
Dallas County
TX 11/04/2013 DC-13-
13163
31. MIGUEL CARABELLO v. LUMINANT ENERGY
COMPANY LLC, ET AL
Premises Liability
Dallas County
TX 10/29/2013 DC-13-
13001
v. MAURA CHAVEZ
Personal Injury
Dallas County
TX 10/23/2013 DC-13-
12692
v. R S FOUNDATIONS
Personal Injury
Dallas County
TX 10/16/2013 DC-13-
12450
34. Luminant Generation Co. LLC v. E.P.A. Opinion - U.S. - Supreme Court 10/07/2013 134 S.Ct.
387
35. MCKINNEY AVENUE PARTNERS, LTD. v.
ONCOR ELECTRIC DELIVERY
COMPANY,LLC.ET AL
Docket - Texas - County Court -
Dallas County
TX 10/03/2013 CC-13-
05713-D
v. LUIS PATZAN-LIMA, ET AL
Personal Injury
Dallas County
TX 10/02/2013 DC-13-
11931
37. Oncor Elec. Delivery Co., LLC v. Murillo Opinion - Texas - Court of
Appeals
TX 09/26/2013 2013 WL
5372544
38. CITY OF DALLAS v. DCSJ EDWARDS, LLC,
THE UNITED STATES OF AMERICA, ONCOR
ELECTRIC DELIVERY COMPANY, LLC.ET AL
Condemnation
Dallas County
TX 09/18/2013 CC-13-
05440-C
39. CITY OF DALLAS v. CAROLYN PARKER
SCHUM, INDIVIDUALLY AND AS TRUSTEE OF
THE SCHUM LIVING TRUST, LEE CAMERON
ADAMS, ALLEN KENT ADAMS.ET AL
Condemnation
Dallas County
TX 09/18/2013 CC-13-
05442-D
40. MARIO GARCIA v. ONCOR ELECTRIC
Dallas County
TX 09/17/2013 DC-13-
11135
41. GTE Southwest Inc. v. Oncor Elec. Delivery
Co., LLC
Opinion - Texas - Court of
Appeals
TX 09/17/2013 2013 WL
5234244
v. BARBOSA A CONSTRUCTION INC
Personal Injury
Dallas County
TX 09/10/2013 DC-13-
10699
v. HEATHER BAGLEY
Personal Injury
Dallas County
TX 09/10/2013 DC-13-
10709
v. SUMMIT STEEL FABRICATORS INC
Personal Injury
Dallas County
TX 08/22/2013 DC-13-
09645
45. UNITED STATES OF AMERICA v. LUMINANT
GENERATION COMPANY LLC ET AL
Docket 200 - Environmental
340.65 - Other Federal Statutes ->
Environmental Matters
U.S. - District Court -
Texas N.D.
TX 08/16/2013 3:13-CV-
03236
46. ONCOR ELECTRIC DELIVERY COMPANY, L.L.C
v. JOSE JACQUEZ
Docket 130.05 - Contracts -> Breach of
Contract
Dallas County
TX 08/13/2013 CC-13-
04720-E
v. BOBBY SPEARS
Parker County
TX 08/12/2013 CV13-
1125
48. LUMINANT GENERATION COMPANY LLC v.
JENNIFER MORRISON,T JEFF STONE,T JEFF
STONE & ASSOCIATES LLC
Docket 140 - Banking/Finance Texas - District Court -
Collin County
TX 08/12/2013 416-
03151-
2013
v. NATIONAL TRANSLINE INC
Personal Injury
Dallas County
TX 08/07/2013 DC-13-
09229
v. TEXAS PREFERRED ROOFING
Personal Injury
Dallas County
TX 08/07/2013 DC-13-
09147
v. IAN KRUGER, ET AL
Personal Injury
Dallas County
TX 08/07/2013 DC-13-
09068
v. ANGELA MABERY
Personal Injury
Dallas County
TX 08/06/2013 DC-13-
09145
v. ARTURO MARTINEZ
Premises Liability
Dallas County
TX 08/06/2013 DC-13-
09039
v. DFW SHREDDING INC
Personal Injury
Dallas County
TX 08/06/2013 DC-13-
09136
55. ONCOR ELECTRIC DELIVERY COMPANY LLC Docket 430.75 - Torts/Negligence -> Texas - District Court - TX 08/06/2013 DC-13-
v. DRIVER PIPELINE COMPANY INC Personal Injury Dallas County 09142
56. LUMINANT GENERATION CO., L.L.C, ET AL v.
EPA
Docket 030 - Appeals U.S. - Court of Appeals
- 5th Circuit
07/31/2013 13-60538
v. UNITED STATES OF AMERICA
Docket 430.77.10 - Torts/Negligence ->
Personal Property -> Other Personal
Property Damage
Texas N.D.
TX 07/22/2013 3:13-CV-
02847
v. MALIN N J ASSOCIATES LLC
Personal Injury
Dallas County
TX 07/18/2013 DC-13-
07908
v. RKM UTILITY SERVICES INC
Personal Injury
Dallas County
TX 07/18/2013 DC-13-
07976
v. JOSUE ARMILLA, ET AL
Personal Injury
Dallas County
TX 07/18/2013 DC-13-
07985
v. EDUARDO SAUCEDO, ET AL
Dallas County
TX 07/17/2013 DC-13-
07940
v. BUD COLEY TRUCKING INC
Personal Injury
Dallas County
TX 07/16/2013 DC-13-
07842
63. HUGO PADILLA, LAURA SANCHEZ, IND., AND
AS NEXT FRIEND OF YANIXA SANCHEZ, A
MINOR v. ONCOR ELECTRIC DELIVERY
COMPANY, LLC, JUAN CARLOS RAMIREZ
430.87 - Torts/Negligence ->
Property Damage
Dallas County
TX 07/09/2013 CC-13-
03989-C
64. LUMINANT GENERATION COMPANY LLC, ET
AL. v. ENVIRONMENTAL PROTECTION
AGENCY
Docket 030 - Appeals U.S. - Supreme Court 06/24/2013 12-1484
65. Oncor Elec. Delivery Co. LLC v. Public Utility
Com'n of Texas
Opinion - Texas - Court of
Appeals
TX 06/14/2013 2013 WL
3013899
v. ANNIE BAXENDALE
Docket 430.72 - Torts/Negligence -> Motor
Vehicle
Dallas County
TX 06/06/2013 DC-13-
06403
L.L.C. v. JAMAL KEJUNA VICKERS, SHERLEY
CAREY
Property Damage -> Non-Motor
Vehicle
Dallas County
TX 05/15/2013 CC-13-
02852-C
L.L.C. v. NANCY VERENICE DOMINGUEZ
Vehicle
Dallas County
TX 05/15/2013 CC-13-
02853-E
L.L.C. v. TEXAS MANUFACTURING
Vehicle
Dallas County
TX 05/13/2013 CC-13-
02796-E
70. LUMINANT GENERATION COMPANY, ET AL v.
EPA
- DC Circuit
05/10/2013 13-1178
v. ALFREDO CORDERO, ALFREDO T
CORDERO
Vehicle
Dallas County
TX 04/25/2013 CC-13-
02430-B
L.L.C. v. CHRISTOPHER C GEDERS, YRC
WORLDWIDE INC.
Vehicle
Dallas County
TX 04/25/2013 CC-13-
02431-D
L.L.C. v. ADELANTE MOVING SERVICES, LLC,
TIME WARNER CABLE, LLC, TIME WARNER
CABLE TEXAS, LLC.ET AL
Vehicle
Dallas County
TX 04/22/2013 CC-13-
02333-B
L.L.C. v. ALEX LAMBERD, BETEL TRUCKING,
INC.
Vehicle
Dallas County
TX 04/09/2013 CC-13-
02093-D
v. OSCAR ALEXANDER GUTIERREZ,
BONIFACIO MANZANAREZ
Vehicle
Dallas County
TX 04/02/2013 CC-13-
01977-C
L.L.C. v. JESUS VARELA, GREGORY R
VANKATWYK
Vehicle
Dallas County
TX 04/02/2013 CC-13-
01979-B
77. AMERICAN LUNG ASSOCIATION, ET AL. v.
EME HOMER CITY GENERATION, L.P., ET AL.
78. ENVIRONMENTAL PROTECTION AGENCY, ET
AL. v. EME HOMER CITY GENERATION, L.P., ET
AL.
v. HASEN DESIGN BUILD AND DEVELPMENT,
INC.
Vehicle
Personal Injury -> Non-Motor Vehicle
Collin County
TX 03/25/2013 003-
00708-
2013
80. CITY OF DALLAS v. 635-I20 JOINT VENTURE,
ONCOR ELECTRIC DELIVERY COMPANY LLC,
DALLAS COUNTY, IN ITS OWN BEHALF AND
Condemnation
Dallas County
TX 03/19/2013 CC-13-
01705-E
ON BEHALF DALLAS COUNTY COMMUNITY
COLLEGE DISTRICT, PARKLAND HOSPITAL
DISTRICT, AND DALLAS COUNTY SCHOOL
EQUALIZATION FUND, DALLAS INDEPE...
81. CITY OF DALLAS v. GEORGE F. LUCAS
IRREVOCABLE TRUST, ONCOR ELECTRIC
DELIVERY COMPANY LLC, DALLAS COUNTY,
IN IT'S OWN BEHALF AND ON BEHALF OF
DALLAS COUNTY COMMUNITY COLLEGE
DISTRICT, PARKLAND HOSPITAL DISTRICT,
AND DALLAS COUNTY SCHOOL
EQUALIZATION FUN...
Condemnation
Dallas County
TX 03/19/2013 CC-13-
01704-D
82. Oncor Elec. Delivery Co., LLC v. Brockriede Opinion - Texas - Court of
Appeals
TX 03/18/2013 2013 WL
1339539
83. RUSSELL THORBURN v. ONCOR ELECTRIC
Premises Liability
Dallas County
TX 03/04/2013 DC-13-
02582
L.L.C. v. MELVIN BENITEZ, JOHANA IRAHETA
Vehicle
Dallas County
TX 03/01/2013 CC-13-
01389-E
85. CITY OF DALLAS v. MARGARET MARIE
GIDDENS, ONCOR ELECTRIC DELIVERY,
COMPANY, LLC, DALLAS COUNTY, IN ITS
OWN BEHALF AND ON BEHALF OF DALLAS
COUNTY COMMUNITY COLLEGE DISTRICT,
PARKLAND HOSPITAL DISTRICT, AND
DALLAS COUNTY SCHOOL EQUALIZATIION
FUND, AND CI...
Condemnation
Dallas County
TX 03/01/2013 CC-13-
01378-B
86. BRUCE GRUY v. ONCOR ELECTRIC DELIVERY
COMPANY LLC
Personal Injury -> Non-Motor Vehicle
Vehicle
Denton County
TX 02/28/2013 2013-
10171-16
v. BRENDA STONE, AS TRUSTEE OF THE
RAMMING LAND TRUST, AND GREG STONE
Docket - Texas - Court of
Appeals
TX 02/26/2013 02-13-
00072-CV
v. CARL H. BROCKRIEDE
Appeals
TX 02/26/2013 02-13-
00071-CV
L.L.C. v. KEVIN LAMON JACKSON,
CASSANDRA BURNS
Vehicle
Dallas County
TX 02/20/2013 CC-13-
01031-A
90. TEXAS FARM BUREAU INSURANCE
COMPANIES v. ONCOR ELECTRIC DELIVERY
COMPANY LLC
Personal Injury
Dallas County
TX 02/12/2013 DC-13-
01755
L.L.C. v. CEDRIC GLENN GREEN, "JOHN DOE"
Vehicle
Dallas County
TX 02/11/2013 CC-13-
00777-A
92. Sierra Club v. Energy Future Holdings Corp. Opinion - U.S. - District Court -
Texas W.D.
TX 02/06/2013 2013 WL
485363
L.L.C. v. JOSE RAMIREZ, JUAN CARLOS
RAMIREZ, JOHN DOE
Vehicle
Dallas County
TX 02/01/2013 CC-13-
00598-A
94. CITY OF DALLAS v. MAIN CAPITAL
PARTNERS, LP, ONCOR ELECTRIC DELIVERY
COMPANY LLC, DALLAS COUNTY, IN ITS
OWN BEHALF AND ON BEHALF OF DALLAS
COUNTY COMMUNITY COLLEGE DISTRICT,
PARKLAND HOSPITAL DISTRICT, AND
DALLAS COUNTY SCHOOL EQUALIZATION
FUND, DALLAS...
Condemnation
Dallas County
TX 01/29/2013 CC-13-
00525-A
v. JAMES MILTON SCHUNKE
Condemnation
Texas - Court of
Appeals
TX 01/28/2013 04-13-
00067-CV
96. JOHNSON v. ONCOR ENERGY DELIVERY
COMPANY ET AL
Docket 340.30 - Other Federal Statutes ->
Commercial/ICC Rates/ Etc.
Texas W.D.
TX 01/25/2013 6:13-CV-
00022
97. SIERRA CLUB, ET AL v. EPA, ET AL Docket 030 - Appeals U.S. - Court of Appeals
- DC Circuit
01/18/2013 13-1014
98. DREW v. ENERGY FUTURE HOLDINGS
CORPORATION
Docket 340.75 - Other Federal Statutes ->
Other Federal Statutory Actions
West Virginia S.D.
WV 12/14/2012 3:12-CV-
09022
v. JAMES MILTON SCHUNKE
Condemnation
Texas - Court of
Appeals
TX 12/14/2012 03-12-
00816-CV
v. SANDY LUNA, JUAN LAUNA
Dallas County
TX 12/13/2012 CC-12-
07405-C
Vehicle
101. Brantley v. Oak Grove Power Co. LCC Opinion - Texas - Court of
Appeals
TX 11/29/2012 2012 WL
5974032
L.L.C. v. TIMCO LOGISTICS SYSTEMS, INC,
TIMCO LOGISTICS, INC, TIMCO
TRANSPORTATION, INC.
Vehicle
Dallas County
TX 11/26/2012 CC-12-
07063-B
L.L.C. v. HUMBERTO VALENZUELA AND
DIEGO A. MORALES
Personal Injury
430.87 - Torts/Negligence ->
Property Damage
Grayson County
TX 11/21/2012 2012-2-
157CV
v. GLM DFW INC
Docket 140 - Banking/Finance Texas - District Court -
Dallas County
TX 11/08/2012 DC-12-
13226
105. Adams v. Oncor Elec. Delivery Co., L.L.C. Opinion - Texas - Court of
Appeals
TX 10/31/2012 2012 WL
5351237
106. CITY OF RICHARDSON, TEXAS v. ONCOR
Dallas County
TX 10/26/2012 DC-12-
12696
107. Luminant Generation Co., L.L.C. v. U.S. E.P.A. Opinion - U.S. - Court of Appeals
- 5th Circuit
10/24/2012 490
Fed.Appx.
657
108. KIDD v. PUC Docket 030 - Appeals Texas - District Court -
Travis County
TX 09/28/2012 D-1-GN-
12-003059
L.L.C. v. TUAN DUC TO AND CARLOS ANGEL
VELASQUEZ
Docket 300 - Motor Vehicles Texas - County Court -
Denton County
TX 09/28/2012 CV-2012-
02610
110. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION v. LUMINANT MINING SERVICES
COMPANY ET AL
Docket 110.25 - Civil Rights -> Employment U.S. - District Court -
Texas W.D.
TX 09/26/2012 6:12-CV-
00314
111. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION v. LUMINANT MINING SERVICES
COMPANY ET AL
Texas W.D.
TX 09/26/2012 1:12-CV-
00895
112. HARSCO CORPORATION v. STRELSKY ET AL Docket 190.15 - Labor & Employment ->
ERISA
Texas W.D.
TX 09/13/2012 1:12-CV-
00850
113. LUMINANT GENERATION CO., L.L.C, ET AL v.
EPA, ET AL
- 5th Circuit
09/11/2012 12-60694
v. SOUTHERN FOODS GROUP D/B/A SCHEPPS
DAIRY
Docket 390 - Real Property Texas - Court of
Appeals
TX 09/06/2012 05-12-
01223-CV
115. IN RE LONE STAR TRANSMISSION, LLC Docket - Texas - Supreme Court TX 08/24/2012 12-0689
v. MARIANA LIMON
Vehicle
Dallas County
TX 08/21/2012 CC-12-
05134-B
L.L.C. v. MICHAEL NICHOLS, JOHN DOE
Vehicle
Dallas County
TX 08/21/2012 CC-12-
05133-C
L.L.C. v. IGNACIO RODRIGUEZ, DAVID OMO,
JR.
Vehicle
Dallas County
TX 08/09/2012 CC-12-
04910-B
EPA
- 5th Circuit
08/06/2012 12-60617
120. NATIONAL PARKS CONSERVATION, ET AL v.
EPA, ET AL
- DC Circuit
08/06/2012 12-1343
121. UTILITY AIR REGULATORY GROUP v. EPA Docket 030 - Appeals U.S. - Court of Appeals
- DC Circuit
08/06/2012 12-1342
v. SWISHER PARTNERS, L.P.
Docket 390.50 - Real Property -> Eminent
Domain
Collin County
TX 08/01/2012 001-
02133-
2012
123. HARTFORD LLOYDS INSURANCE COMPANY
v. ONCOR ELECTRIC DELIVERY COMPANY
LLC
Personal Injury
Dallas County
TX 07/31/2012 DC-12-
08457
124. TCEQ v. YOUNG CHEVROLET INC Docket - Texas - District Court -
Travis County
TX 07/30/2012 D-1-GN-
12-002297
125. McLennan v. Oncor Elec. Delivery Co. LLC Opinion - U.S. - District Court -
Texas N.D.
TX 07/30/2012 2012 WL
3079063
126. HANOVER INSURANCE GROUP, AS
SUBROGEE OF DAVID'S PATIO LTD. v. ONCOR
Docket - Texas - County Court -
Parker County
TX 07/25/2012 CIV-12-
0698
127. STATE FARM LLOYDS INSURANCE COMPANY
v. ONCOR ELECTRIC DELIVERY COMPANY
LLC
Dallas County
TX 07/12/2012 DC-12-
07715
128. BENNY EUGENE PADDOCK AS ATTORNEY-IN-
FACT OF SAMUEL EUGENE PADDOCK,VONNY
O PADDOCK v. ONCOR ELECTRIC DELIVERY
COMPANY,ONCOR ELECTRIC DELIVERY
COMPANY, INC.,ONCOR ELECTRIC DELIVERY
COMPANY, LLC,ONCOR ELECTRIC DELIVERY
ADMINISTRATION CORP.,ONCOR ELECTRIC ...
Grayson County
TX 07/06/2012 CV-12-
1072
129. McLennan v. Oncor Elec. Delivery Co. LLC Opinion - U.S. - District Court -
Texas N.D.
TX 07/06/2012 2012 WL
3072340
L.L.C. v. RKM UTILITY SERVICES, INC.
Docket 430 - Torts/Negligence Texas - County Court -
Denton County
TX 07/03/2012 CV-2012-
01801
L.L.C. v. JACOBSON TRANSPORTATION
COMPANY, INC.
Vehicle
Dallas County
TX 06/29/2012 CC-12-
04048-B
132. Oncor Elec. Delivery Co. LLC v. Dallas Area
Rapid Transit
Opinion - Texas - Supreme Court TX 06/22/2012 2012 WL
2361726
v. BRITTANY NICHOLE MYERS
Contract
Dallas County
TX 06/08/2012 CC-12-
03503-B
v. DAVIS EXCAVATION, INC
Contract
Dallas County
TX 06/08/2012 CC-12-
03497-D
135. LESHAWNA WILLIS v. ONCOR ELECTRIC
Premises Liability
Dallas County
TX 05/22/2012 DC-12-
05648
v. CHERYL GAYLE CAWTHON A/K/A CHERYL
GAYLE CAWTHON COPENING AND CARLA
SUE CAWTHON A/K/A CARLA SUE CAWTHON
JAMAL AND GARY EDWIN CAWTHON
Domain
Collin County
TX 05/09/2012 001-
01316-
2012
137. CHARLES BAILER v. AT & T RISK MGT INC., AT
& T INC., ONCOR ELECTRIC DELIVERY
COMPANY LLC.ET AL
Vehicle
Dallas County
TX 05/02/2012 CC-12-
02664-C
138. SIERRA CLUB v. ENERGY FUTURE HOLDINGS
CORPORATION ET AL
Docket 200 - Environmental
340.65 - Other Federal Statutes ->
Environmental Matters
Texas W.D.
TX 05/01/2012 6:12-CV-
00108
v. DONALD E. BOWLES, JR., ET AL
Grayson County
TX 04/27/2012 CV-12-
0723
140. GLENN BRANTLEY v. OAK GROVE POWER
COMPANY LCC, LUMINANT GENERATION
COMPANY LCC, LUMINANT AND ENERGY
FUTURE HOLDINGS CORP.
Appeals
TX 04/27/2012 10-12-
00135-CV
L.L.C. v. BRASFIELD & GORRIE, L.L.C.
Vehicle
Dallas County
TX 04/26/2012 CC-12-
02566-D
v. LOWE'S HOME CENTERS, INC
Contract
Dallas County
TX 04/26/2012 CC-12-
02564-D
EPA, ET AL
- DC Circuit
04/20/2012 12-1203
L.L.C. v. SUNSET TRANSIT, INC.
Vehicle
Dallas County
TX 04/13/2012 CC-12-
02320-D
145. LUMINANT GENERATION COMPANY, L, ET AL
v. EPA
- DC Circuit
04/10/2012 12-1167
v. CCM FARMS, LP, A TEXAS DOMESTIC
LIMITED PARTNERSHIP
Grayson County
TX 04/09/2012 CV-12-
0608
v. ROBERT LEE SITZES
Grayson County
TX 03/27/2012 CV-12-
0548
148. Luminant Generation Co., L.L.C. v. U.S. E.P.A. Opinion - U.S. - Court of Appeals
- 5th Circuit
03/26/2012 675 F.3d
917
v. VICTOR MARTINEZ, JR., CASTILLO FIDELIA
FRAGO
Contract
Dallas County
TX 03/20/2012 CC-12-
01829-A
L.L.C. v. MICHAEL THOMAS-DUREN BELL,
KEETRA NICKERSON
Vehicle
Dallas County
TX 03/20/2012 CC-12-
01827-B
v. JAMES KENNETH GRIFIN,DEBORAH
SUZANNE GRIFFIN
Grayson County
TX 03/20/2012 CV-12-
0505
152. DAVID MINKU CHON, DOING BUSINESS AS
DAIRY QUEEN OF DESOTO v. YSMAEL
IZQUIERDO, SERGIO BABOSA, AT & T
Property Damage
Dallas County
TX 03/19/2012 CC-12-
01800-B
CORPORATION, DOING BUSINESS AS AT & T
EAST CORP.ET AL
v. ROBERT LEE SITZES
Grayson County
TX 03/06/2012 CV-12-
0410
v. LEE R JONES,NEIL JONES
Grayson County
TX 03/06/2012 CV-12-
0405
v. LUCILLE BLOCK MAY
Grayson County
TX 03/06/2012 CV-12-
0409
v. WESTON 183 PARTNERS LTD AND
HERITAGE LAND BANK, FLCA, LIENHOLDER
Domain
Collin County
TX 03/05/2012 001-
00650-
2012
v. MARSHALL MASH,MAUDINE MASH
Docket 360.20.10 - Probate, Trusts &
Estates -> Distribution of Property ->
Real Property
Texas - Probate Court -
Denton County
TX 03/02/2012 PR-2012-
00190
v. N & M SCHLUTER FAMILY LP
Real Property
Denton County
TX 03/02/2012 PR-2012-
00191
v. MARSHALL MASH,MAUDINE MASH
Real Property
Denton County
TX 03/02/2012 PR-2012-
00190
v. N & M SCHLUTER FAMILY LP
Real Property
Denton County
TX 03/02/2012 PR-2012-
00191
v. JFB GUNTER/2003, LTD.
Grayson County
TX 02/23/2012 CV-12-
0347
v. ELAINE SCOGGIN GAYLE,SANDRA
ANDERSON,GRAYSON SCOGGIN,STEPHAINE
SCOGGIN
Grayson County
TX 02/23/2012 CV-12-
0349
v. SALEM RADIO PROPERTIES, INC.
Grayson County
TX 02/23/2012 CV-12-
0350
164. MCLENNAN v. ONCOR ELECTRIC DELIVERY
COMPANY LLC ET AL
Texas N.D.
TX 02/21/2012 3:12-CV-
00531
v. ARMAD JERMAIN PAGE
Contract
Dallas County
TX 02/16/2012 CC-12-
01096-E
v. JOHN E AUTRY
Grayson County
TX 02/16/2012 CV-12-
0306
v. LMB, LP, SUNTEX CONSTRUCTION, INC.
Contract
Dallas County
TX 02/16/2012 CC-12-
01095-A
v. MPG MADEAN TRUCKING, L.L.C
Vehicle
Dallas County
TX 02/16/2012 CC-12-
01082-D
v. JORGE ALBERTO VALDERAMA-
CONTRERAS, FELIPE BALDERRAMA
Property Damage
Dallas County
TX 02/16/2012 CC-12-
01080-C
v. MARK TIMOTHY LEE, JR., JOHN DOE
Vehicle
Dallas County
TX 02/15/2012 CC-12-
01079-E
v. THOMAS REY,KELLY REY
Grayson County
TX 02/15/2012 CV-12-
0294
v. DON KENT SWINDLE
Grayson County
TX 02/14/2012 CV-12-
0289
v. GRAYSON CORRIDOR INVESTORS, INC.
Grayson County
TX 02/14/2012 CV-12-
0288
v. ALBERT J. TESTA
Real Property
Denton County
TX 02/13/2012 PR-2012-
00137
v. GRAYSON RANCH CREEK INVESTMENT,
L.P., AKA GRAYSON CREEK INVESTMENT, LP
Grayson County
TX 02/13/2012 CV-12-
0283
176. ONCOR ELECTRIC DELIVERY COMPANY
LLCVS. ALBERT J. TESTA
Real Property
Denton County
TX 02/13/2012 PR-2012-
00137
v. JFS HOLDINGS PARTNERSHIP
Grayson County
TX 02/10/2012 CV-12-
0264
178. HARTFORD LLOYDS INSURANCE COMPANY,
ET AL v. ONCOR ELECTRIC DELIVERY
COMPANY LLC
Premises Liability
Dallas County
TX 02/09/2012 DC-12-
01538
v. CHARLES R. HOTZE, III,BARBARA A. HOTZE
Grayson County
TX 02/09/2012 CV-12-
0238
v. MICHAEL L GOOCH,CHRISTINE K
GOOCH,REMINGTON MORTGAGE, LTD,
LEINHOLDER
Domain
Collin County
TX 02/08/2012 001-
00420-
2012
v. DARRELL LANZ AND KIM LANZ AND
INDEPENDENT BANK
Domain
Collin County
TX 02/07/2012 001-
00408-
2012
v. L AND M WAGGONER FAMILY TRUST
Domain
Collin County
TX 02/07/2012 001-
00406-
2012
v. LARRY S WAGGONER TRUST
Domain
Collin County
TX 02/07/2012 001-
00409-
2012
v. TEODORO DIAZ,MARIA G DIAZ,CTX
MORTGAGE COMPANY, LLC
Domain
Collin County
TX 02/07/2012 001-
00407-
2012
185. ONCOR ELECTRIC DELIVERY COMPANY LLC,
v. RANDALL LEE JOHNSON
Grayson County
TX 02/06/2012 CV-12-
0217
v. F LAZY 7 LTD, A TEXAS LIMITED
PARTNERSHIP
Grayson County
TX 02/06/2012 CV-12-
0216
v. JACK WALL, TRUSTEE AND JACK WALL,
INDIVIDUALLY
Grayson County
TX 02/03/2012 CV-12-
0204
v. SALLY B. SIMS
Grayson County
TX 02/03/2012 CV-12-
0207
189. IN RE: TRANSDATA INC SMART METERS
PATENT LITIGATION
Docket 260.10 - Intellectual Property ->
Patent
Oklahoma W.D.
OK 02/02/2012 5:12-ML-
02309
v. LOU ANN AUTRY JACKSON
Grayson County
TX 02/02/2012 CV-12-
0194
v. JOHN E AUTRY,LUJUANA S. AUTRY
Grayson County
TX 02/02/2012 CV-12-
0196
192. MEDSTAR FUNDING v. HOADLEY Docket - Texas - District Court -
Travis County
TX 02/01/2012 D-1-GN-
12-000264
L.L.C. v. ABF FREIGHT SYSTEMS, INC.
Vehicle
Dallas County
TX 02/01/2012 CC-12-
00556-B
L.L.C. v. MARIA ARROYO
Vehicle
Dallas County
TX 02/01/2012 CC-12-
00553-E
v. SPARLING FINANCIAL
CORPORATION,CHANDLER RYAN STRAWN
Grayson County
TX 01/31/2012 CV-12-
0181
v. LARRY WAYNE JACKSON,LOU ANN
AUTRY JACKSON
Grayson County
TX 01/31/2012 CV-12-
0180
v. LONE STAR PARTNERS, C. KENT ADAMS
AND FRANKLIN OVID BIRMINGHAM MEMORIAL
LAND TRUST
Domain
Collin County
TX 01/31/2012 001-
00316-
2012
198. TRANSDATA INC v. CENTERPOINT ENERGY
HOUSTON ELECTRIC LLC ET AL
Docket 260.10 - Intellectual Property ->
Patent
Oklahoma W.D.
OK 01/27/2012 5:12-CV-
00101
v. FELIX LAND PARTNERS, L.P.,
Grayson County
TX 01/25/2012 CV-12-
0151
200. KEFA N MITCHELL v. ENERGY FUTURE
HOLDINGS CORP, DOING BUSINESS AS
LUMINANT
Vehicle
Dallas County
TX 01/23/2012 CC-12-
00389-E
v. JOHN R FOSTER,LYNN E FOSTER
Domain
Collin County
TX 01/20/2012 001-
00226-
2012
v. TRIPLE C PARTNERS, LTD
Domain
Collin County
TX 01/20/2012 001-
00227-
2012
v. EFFA, INC, TOM DRASIL
Contract
Dallas County
TX 01/20/2012 CC-12-
00339-B
L.L.C. v. JONATHAN LOMBARDO, JOHN DOE
Vehicle
Dallas County
TX 01/20/2012 CC-12-
00340-D
v. BILLIE CARLTON BENNETT,DEBBY ANN
Grayson County
TX 01/11/2012 CV-12-
0049

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IN THE UNITED STATES BANKRUPTCY COURT

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