1. IN THE UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
In re: Chapter 11
ALLIED SYSTEMS HOLDINGS, INC., Case No. 12-11564 (CSS)
Alleged Debtor. Re: Docket No. 11
In re: Chapter 11
ALLIED SYSTEMS, LTD. (L.P.), Case No. 12-11565 (CSS)
Alleged Debtor. Re: Docket No. 11
ALLEGED DEBTORS' RESPONSE TO PETITIONING CREDITORS' MOTION
PURSUANT TO DEL. BANKR. L.R. 9006-l(e) FOR AN ORDER SHORTENING
TIME FOR NOTICE OF THE HEARING TO CONSIDER THE PETITIONING
CREDITORS' MOTION TO FILE REDACTED VERSIONS OF CONFIDENTIAL
PLEADINGS AND TO FILE CERTAIN EXHIBITS THERETO UNDER SEAL
COME NOW the Alleged Debtors and file this response to the Petitioning Creditors'
Motion Pursuant to Del Bankr. L.R. 9006-1 (e) for an Order Shortening Time for Notice of the
Hearing to Consider the Petitioning Creditors' Motion to File Redacted Versions of Confidential
Pleadings and to File Certain Exhibits thereto under Seal [Docket No. 11 in both Case No. 12-
11564 (CSS) and Case No. 12-11565 (CSS)], filed May 17, 2012 (the "Motion to Shorten Time
for Redaction and Sealing Motion "). In making this response the Alleged Debtors do not waive
their request that venue of this case be transferred to the United States Bankruptcy Court for the
Northern District of Georgia, where their earlier Chapter 11 Cases are pending
RESPONSE
1. The Alleged Debtors have no objection to the Motion to Shorten Time for
Redaction and Sealing Motion to the extent that the relief sought therein is to shorten the time
RLFI 6047142v. I

2. only to the extent, if any, that the hearing time is shortened for the Expedited Motion of
Petitioning Creditors for the Appointment of a Trustee Pursuant to 11 USC. §§ 105(a),
1104(a)(l) and 1104(a)(2), [Docket No. l3 in both Case No. 12-11564 (CSS) and Case No. 12-
11565 (CSS)] filed May 17,2012 (the "Trustee Motion"). 1
2. The redactions in the Trustee Motion and in the Affidavit of Richard Ehrlich in
Support of Motion for the Appointment of a Chapter 11 Trustee, [Docket No. 15 in both Case
No. 12-11564 (CSS) and Case No. 12-11565 (CSS)], filed May 17, 2012, relate to the Alleged
Debtors' financial information. Similarly, the Exhibits that the Petitioning Creditors proposed to
file under seal are documents created by Alleged Debtors or Yucaipa. As this court has noted,
"[c]onfidential information is information which would result in an 'unfair advantage to
competitors by providing them information as to the commercial operations of the debtor."' In re
A !terra Healthcare Corp., 353 B.R. 66 (Bankr. D. Del2006).
3. However, it should be clear that the Petitioning Creditors' Motion to File
Redacted Versions of Confidential Pleadings and to File Certain Exhibits Thereto under Seal
[Docket No. 10 in both Case No. 12-11564 (CSS) and Case No. 12-11565 (CSS)] (the
"Redaction and Sealing Motion"), should not be granted to the extent that it prevents the Alleged
Debtors or its major shareholders from making the redacted or sealed information available to
various parties in order to promote the Alleged Debtors' interests. This is because the
The Motion to Shorten Time seeks a shortening of time with respect to the Petitioning Creditors' Motion to
File Redacted Versions of Confidential Pleadings and to File Certain Exhibits Thereto under Seal [Docket No. 10 in
both Case No. 12-11564 (CSS) and Case No. 12-11565 (CSS)] (the "Redaction and Sealing Motion"). The
Redaction and Sealing Motion addresses statements and exhibits relate to hearing which the Petitioning Creditors
seek with respect to Expedited Motion of Petitioning Creditors for the Appointment of a Trustee Pursuant to II
U.S. C. §§ I05(a), II04(a)(I) and Il04(a)(2), [Docket No. 13] filed May 17, 2012 (the "Trustee Motion"). With
regard to the timing of the Trustee Motion, the Petitioning Creditors' have sought a shortening of the time by filing
the Petitioning Creditors' Motion Pursuant to Del. Bankr. L. R. 9006-I(e)for an Order Shortening Time for Notice
of the Hearing to Consider the Expedited Motion of Petitioning Creditors for the Appointment of a Trustee pursuant
to 11 U.S. C.§§ 105(a), l/04{a)(I) and 1104(a)(2) [Docket No. 12 in both Case No. 12-11564 (CSS) and Case No.
12-11565 (CSS)], filed May 17, 2012. ("Motion to Shorten Time for Trustee Motion")
2
RLFI 6047142v. 1

3. confidential information proposed to be protected is the confidential information of the Alleged
Debtors and its major shareholders. It is not the confidential information of the Petitioning
Creditors except in the sense that they are bound not to disclose it. Accordingly, while the
information is properly filed under seal, the Alleged Debtors and/or Yucaipa, as the case may be,
should retain sole discretion regarding whether and when to disclose the information to the
public or confidentially to other parties-in-interest.
Dated: May 21, 2012
Wilmington, Delaware Respectfully submitted,
....
Mark D. C lins (No. 2981)
Christo er M. Samis (No. 4909)
RICHARDS, LAYTON & FINGER, P.A.
One Rodney Square
920 North King Street
Wilmington, Delaware 1980 1
Telephone: (302) 651-7700
Facsimile: (302) 651-7701
E-mail: collins@rlf.com
E-mail: samis@rlf.com
-and-
Jeffrey W. Kelley (GA Bar No. 412296)
Ezra H. Cohen (GA Bar No. 173800)
TROUTMAN SANDERS LLP
Bank of America Plaza
600 Peachtree Street, Suite 5200
Atlanta, Georgia 30308-2216
Telephone No.: (404) 885-3000
Facsimile No.: (404) 885-3900
E-Mail: jeffrey.kelley@troutmansanders.com
E-Mail: ezra.cohen@troutmansanders.com
Counsel for Alleged Debtors
3
RLFI 6047142v. I

4. CERTIFICATE OF SERVICE
I, Christopher M. Samis, hereby certify that a true and correct copy of the foregoing
Alleged Debtors ' Response to Petitioning Creditors ' Motion Pursuant to Del. Bankr. L.R. 9006-
I (e) for an Order Shortening Time for Notice of the Hearing to Consider the Petitioning
Creditors ' Motion to File Redacted Versions of Confidential Pleadings and to File Certain
Exhibits Thereto Under Seal was served upon all parties in interest, by first class mail and/or
hand delivery on May 21 , 2012, at the following addresses:
BDCM Opportunity Fund II, LP United States Trustee
One Sound Shore Drive 844 King Street, Room 2207
Suite 200 Lockbox #35
Greenwich, CT 06830 Wilmington, DE 19899-0035
Black Diamond CLO 2005-1 Adviser L.L.C. Adam G. Landis, Esq.
One Sound Shore Drive Kerri K. Mumford, Esq.
Suite 200 Landis Rath & Cobb LLP
Greenwich, CT 06830 91 9 Market Street
Suite 1800
Spectrum Investment Partners LP Wilmington, DE 19801
1250 Broadway
19th Floor Counsel to Petitioning Creditors
New York, NY 10001
RLFl 6047 142v. I