2. The Stipulated Order required the Platinum Entities to produce, for example,
certain communications between the Platinum Entities and the Debtors; all internal
communications regarding converting debt to equity or buying and selling the Debtors' stock;
any analysis on the Platinum Entities' return on their relationship with the Debtors; and
documents relating to the termination or separation of certain of the Debtors' officers and
directors. Id. ¶ 6.
...Stipulated Order and should not be tolerated by this Court. In fact, the Platinum Parties have not
stated that they are unable to comply with the Stipulated Order, only that they have chosen not to
do so,
The Committee
thus respectfully requests the entry of an Order enforcing the Stipulated Order by compelling the
production of information responsive to the categories set forth in the Order by no later than ten
(10) days following entry of an Order approving this Motion.
