On October 21, 2015, a memorandum of law with respect to plan of reorganization was filed in the bankruptcy case of ERG Intermediate Holdings, LLC and its affiliates.
The filing was assigned docket number 619 and is described on the court’s official docket as follows:
Support/supplemental document Joint Memorandum of Law (A) In Support of Final Approval of Disclosure Statement, (B) In Response to Pending Objections to Confirmation of the First Amended Joint Chapter 11 Plan of Reorganization Dated September 18, 2015, in Respect of ERG Intermediate Holdings, LLC and Its Affiliated Debtors, (C) Requesting Authorization to Make Plan Modifications, (D) In Support of Confirmation of the Plan and (E) Requesting Authorization to Consummate and Implement the Plan Upon Entry of the Confirmation Order filed by Creditor CLMG Corp., Debtor ERG Intermediate Holdings, LLC (RE: related document(s) Chapter 11 plan,  Disclosure statement). (Howley, Thomas)
ERG Intermediate Holdings, LLC filed for bankruptcy protection, or had an involuntary bankruptcy petition filed against it, on April 30, 2015. The bankruptcy case is pending before the United States Bankruptcy Court for the Northern District of Texas . The case number for the lead bankruptcy case is 15-31858. The bankruptcy case is currently assigned to United States Bankruptcy Judge Harlin DeWayne Hale. The law firm of Jones Day LLP is acting as lead bankruptcy counsel to ERG Intermediate Holdings, LLC in the bankruptcy case.