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Ligado Networks LLC, et al. - Motion Materials
 Factum of the Applicant (returnable October 9, 2025) |
October 8, 2025 |
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Factum of the Applicant in support of its motion returnable October 9, 2025.
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Motion Record (Part 1)
Motion Record (Part 2)
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October 7, 2025 |
This Motion is for an Order substantially in the form attached as Tab 4 of the Foreign Representative's Motion Record for, among other things, the following relief:
- pursuant to Part IV of the Companies' Creditors Arrangement Act, R.S.C. 1985, c.C-36, as amended (the "CCAA"), recognizing and giving full force and effect in all provinces and territories of Canada to certain orders of the United States Bankruptcy Court for the District of Delaware (the "U.S. Court") granted in the cases (the "Chapter 11 Cases") commenced by the Debtors under chapter 11 of title 11 of the United States Code, 11 U.S.C. §§ 101-1532 (the "U.S. Bankruptcy Code"), specifically:
- Amended Final Order (i) Authorizing the Debtors to (A) Continue to Operate their Cash Management System and Maintain Existing Bank Accounts, (B) Utilize their Credit Cards, and (C) Engage in Intercompany Transactions, (II) Granting a Waiver of the Requirements of Section 345(B) of the Bankruptcy Code and U.S. Trustee Guidelines, and (III) Granting Related Relief, dated March 5, 2025 ("Amended Cash Management Order");
- Order Establishing (I) Various Bar Dates for Filing Proofs of Claim, (II) Approving the Form and Manner of Filing Proofs of Claim, (III) Approving Notices of Bar Dates, and (IV) Granting Related Relief, dated March 19, 2025 ("Claims Procedure Order");
- Order Authorizing Payment of Prepetition Trade Claims in the Ordinary Course and (II) Granting Certain Related Relief, dated June 18, 2025 ("Trade Claims Order");
- Order Approving Procedures for Resolving Insurance Claims, dated June 18, 2025 ("Insurance Settlement Order");
- Order (I) Authorizing The Debtors To Enter Into the AST Definitive Documents and (II) Granting Related Relief, dated June 23, 2025 (the "AST Definitive Documents Order");
- Order (I) Approving Proposed Disclosure Statement and Form and Manner of Notice of Disclosure Statement Hearing, (II) Establishing Solicitation and Voting Procedures, (III) Scheduling Confirmation Hearing, (IV) Establishing Notice and Objection Procedures For Confirmation of Proposed Plan, and (V) Granting Related Relief, dated June 24, 2025 (the "Disclosure Statement Order");
- Order (I) Authorizing the Debtors To Reject an Executory Contract and An Unexpired Lease Effective As Of the Rejection Date, and (II) Granting Related Relief, dated August 4, 2025 ("Contract Rejection Order");
- Order Authorizing the Debtors to (I) Amend the DIP Credit Agreement and, (II) Enter into the Letter Agreement and AST Power of Attorney, dated September 23, 2025 ("DIP Amendment Order"); and
- Revised Findings of Fact, Conclusions of Law, and Order Confirming Joint Chapter 11 Plan of Reorganization, dated September 29, 2025 ("Confirmation Order");
granting related relief in respect of the implementation of the Plan, including authorizing the Debtors and Reorganized Debtors to take all actions consistent with the Order, the Confirmation Order and the Plan as may be necessary or appropriate to effectuate the Restructuring Transactions, and approving the injunctions, releases, and exculpation provisions set forth in the Plan and declaring that they shall be effective and binding on all Persons and Entities in all provinces and territories of Canada;
approving the Pre-Filing Report of FTI Consulting Canada Inc. ("FTI Canada") in its capacity as the Proposed Information Officer, dated January 14, 2025, the First Report of the Information Officer, dated February 7, 2025, the Second Report of the Information Officer, dated July 24, 2025, the Third Report of the Information Officer, to be filed, and the activities and conduct of the Information Officer as described therein; and
approving the fees of the Information officer, counsel to the Information Officer and counsel to the Foreign Representative.
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| Motion Record (Recognition of Foreign Orders, returnable February 10, 2025) |
February 6, 2025 |
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The motion is for an Order recognizing, and giving full force and effect in Canada to, certain of the Foreign Orders entered in the Chapter 11 Cases, including the Cash Management Order, Wages Order, Insurance Order, Taxes Order, Utilities Order, Final DIP Order, and AST Break-Up Compensation Order, and other related materials.
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| Factum of the Applicant (Initial Recognition Order and Supplemental Order) |
January 15, 2025 |
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This factum is filed in support of an application under Part IV of the CCCA by Ligado as the proposed foreign representative of itself, Ligado Networks Corp., Ligado Networks Holdings (Canada) Inc., Ligado Networks (Canada) Inc., ATC Technologies, LLC, Ligado Networks Inc. of Virginia, One Dot Six LLC, One Dot Six TVCC LLC, Ligado Networks Subsidiary LLC, Ligado Networks Finance LLC and Ligado Networks Build LLC that recently filed voluntary petitions for relief pursuant to Chapter 11 of the U.S. Bankruptcy Code (collectively, with Ligado, the "Debtors").
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| Application Record of Ligado Networks LLC |
January 14, 2025 |
The Applicant, Ligado Networks LLC ("Ligado"), makes this Application on its own behalf and in its capacity as proposed foreign representative (in such capacity, the "Proposed Foreign Representative") for certain relief pursuant to Part IV of the Companies' Creditors Arrangement Act (the "CCAA"), as amended:
(a) an Initial Recognition Order;
(b) a Supplemental Order; and
(c) such further and other relief as counsel may advise and this Honourable Court may permit.
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