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NOV 1 3 2001 UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
OcPT OF BIM DING INSPECTIONS
In re Chapter 11 Case No.
SUN HEALTHCARE GROUP, INC., et al., 99-3657 (MFW)
Debtors. (Jointly Administered)
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NOTICE OF HEARING TO CONSIDER APPROVAL OF DISCLOSURE
STATEMENT WITH RESPECT TO JOINT PLAN OF REORGANIZATION
OF DEBTORS UNDER CHAPTER 11 OF THE BANKRUPTCY CODE
TO: ALL HOLDERS OF CLAIMS AGAINST AND INTERESTS IN THE ABOVE-
CAPTIONED DEBTORS AND DEBTORS IN POSSESSION
PLEASE TAKE NOTICE that on November 7, 2001, Sun Healthcare Group, Inc.
and certain of its direct and indirect subsidiaries, each of which is identified on Exhibit "A"
annexed hereto, as debtors and debtors in possession (collectively, the "Debtors"), filed the
Debtors' Joint Plan of Reorganization Under Chapter 11 of the Bankruptcy Code, dated
November 7, 2001 (as may be amended, the "Plan"), and a Disclosure Statement for Debtors'
Joint Plan of Reorganization, dated November 7, 2001, and the exhibit thereto (as may be
amended, the "Disclosure Statement"), pursuant to section 1125 of title 11, United States Code
(the "Bankruptcy Code").
PLEASE TAKE FURTHER NOTICE that:
1. A hearing (the "Hearing") will be held before the Honorable Mary F.
Walrath, United States Bankruptcy Judge, at the United States Bankruptcy Court for the District
of Delaware, Courtroom 1, 824 Market Street, Wilmington, Delaware 19801, on December 13,
2001 at 2:00 p.m. or as soon thereafter as counsel can be heard, to consider the entry of an order,
among other things, finding that the Disclosure Statement contains "adequate information"
within the meaning of section 1125 of the Bankruptcy Code and approving the Disclosure
Statement.
2. The Disclosure Statement and Plan are on file with the Clerk of the
Bankruptcy Court (the "Clerk") and may be examined by interested parties at the office of the
Clerk at the United States Bankruptcy Court for the District of Delaware, 824 Market Street,
Fifth Floor, Wilmington, Delaware 19801 during regular business hours. In addition, copies may
be obtained upon request to Bankruptcy Services, LLC at (212) 376-8494.
3. Responses and objections, if any, to the approval of the Disclosure
Statement or any of the other relief sought by the Debtors in connection with approval of the
Disclosure Statement, must (i) be in writing, (ii) state the name and address of the objecting or
responding party and the nature of the claim or interest of such party, (iii) state with particularity
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the basis and nature of any objection or response and include, where appropriate, proposed
language to be inserted in the Disclosure Statement to resolve any such objection or response,
and (iv) be filed, together with proof of service, with the Court and served so as to be actually
received,on or before 4:00 p.m. (Eastern Time) on December 5, 2001, by: (a) the Clerk, 824
Market Street, Fifth Floor, Wilmington, Delaware 19801; (b) attorneys for the Debtors, Weil,
Gotshal & Manges LLP, 767 Fifth Avenue, New York, New York 10153 (Attn: Michael F.
Walsh, Esq.) and Richards, Layton & Finger, P.A., One Rodney Square, P.O. Box 551,
Wilmington, Delaware 19899 (Attn: Mark D. Collins, Esq.); (c) the attorneys for the agent for
the Debtors' prepetition bank lenders, O'Melveny & Myers, LLP, 400 South Hope Street, 15th
Floor, Los Angeles, California 90071-2899 (Attn: Ben Logan III, Esq.) and Pepper Hamilton
LLP, 1201 Market Street, Suite 1600, Wilmington, Delaware 19801 (Attn: David B. Stratton,
Esq.); (d) the attorneys for CIT Group/Business Credit, Inc. and Heller Healthcare Finance, Inc.,
the Debtors' post-petition lenders, Dewey Ballantine LLP, 1301 Avenue of the Americas, New
York, New York 10019-6092 (Attn: Stuart Hirshfield, Esq.) and Blank, Rome, Comisky &
McCauley LLP, 1201 Market Street, Suite 2100, Wilmington, Delaware 19801 (Attn: Bonnie
Glantz Fate11, Esq.); (e) the attorneys for the statutory committee of unsecured creditors,
Otterbourg, Steindler, Houston & Rosen, 230 Park Avenue, New York, NY 10169 (Attn: Scott
Hazan, Esq.) and Saul Ewing LLP, 222 Delaware Avenue, Suite 1200, Wilmington, Delaware
19801 (Attn: Mark Minuti, Esq.); (f) the United States Trustee for the District of Delaware, 601
Walnut Street, Curtis Center, Suite 950 West, Philadelphia, Pennsylvania 19106 (Attn: Don
Beskrone, Esq.).
4. IF ANY OBJECTION TO THE DISCLOSURE STATEMENT IS
NOT FILED AND SERVED STRICTLY AS PRESCRIBED HEREIN, THE OBJECTING
PARTY MAY BE BARRED FROM OBJECTING TO THE ADEQUACY OF THE
DISCLOSURE STATEMENT AND MAY NOT BE HEARD AT THE HEARING.
5. Upon approval of the Disclosure Statement by the Bankruptcy Court,
holders of claims against the Debtors who are entitled to vote on the Plan will receive a copy of
the Disclosure Statement, the Plan, and various documents related thereto, unless otherwise
ordered by the Bankruptcy Court.
6. The Hearing may be adjourned by the Debtors from time to time without
further notice to creditors or parties in interest other than by an announcement in Bankruptcy
Court of such adjournment on the date scheduled for the Hearing.
Dated: Wilmington, Delaware
November 7, 2001
RICHARDS, LAYTON & FINGER, P.A. WEIL, GOTSHAL & MANGES LLP
One Rodney Square 767 Fifth Avenue
P.O. Box 551 New York, New York 10153
Wilmington, Delaware 19899 Michael F. Walsh
Mark D. Collins (No. 2981) Paul M. Basta
Russell C. Silberglied (No. 3462)
ATTORNEYS FOR THE DEBTORS AND DEBTORS IN POSSESSION
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