23D-107 (12) � 7
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: Sun Healthcare Group, Inc., et al. (Tapp ID No. 85-0410612)
(Affiliated debtor entities are listed on Exhibit A attached hereto)
Case Nos.: 99-3657 through 99-3841 (MFW)
-
Date Filed: October 14, 1999
Address of Debtors: 101 Sun Avenue, N.E.
Albuquerque, NM 87109
NOTICE OF COMMENCEMENT OF CASES UNDER CHAPTER 11 OF
THE BANKRUPTCY CODE, FIRST MEETING OF CREDITORS PURSUANT
TO SECTION 341 OF THE BANKRUPTCY CODE AND FIXING OF DATES
TO ALL INTERESTED PARTIES:
COMMENCEMENT OF CASES. On October 14, 1999, the above-captioned
debtors and debtors-in-possession, and each of the affiliates listed on Exhibit A attached hereto
(collectively, the "Debtors"), all with a mailing address of 101 Sun Avenue, N.E., Albuquerque,
New Mexico, 87109, filed in the United States Bankruptcy Court for the District of Delaware (the
"Bankruptcy Court") voluntary petitions for relief under chapter 11 of title 11, United States
Code (the "Bankruptcy Code"). Orders for relief have been entered in the Debtors' cases.
Pursuant to sections 1107(a) and 1108 of the Bankruptcy Code, the Debtors are authorized to
continue to operate their businesses and manage their properties as debtors and debtors in
possession. You will not receive notice of all documents filed in the Debtors' cases. All
documents filed with the Bankruptcy Court are or will be available for inspection at the office of
the Clerk of the Bankruptcy Court. The address of the Clerk of the Bankruptcy Court is 824
Market Street, 5th Floor, Wilmington, Delaware 19801. Copies of documents can be obtained at
the cost of the requesting party by contacting Delaware Document Retrieval, ("DDR") at 200
West Ninth Street, Lower Level, Wilmington, Delaware, 19801 (telephone# 302-658-9971).
CREDITORS MAY NOT TAKE CERTAIN ACTIONS. A creditor is anyone to
whom any of the Debtors owes money or property. Under the Bankruptcy Code, the Debtors are
granted certain protections against creditors. Common examples of prohibited actions by
creditors are contacting a debtor to demand repayment, taking any action against a debtor to
collect money owed or taking any action against property of a debtor, terminating or changing the
terms or existing contracts or agreements, initiating or attempting to pursue litigation against a
debtor and starting or continuing foreclosure actions, repossessions, or taking any action to
realize the value of a secured creditor's collateral. If unauthorized actions are taken by a creditor
against the Debtors, the Bankruptcy Court may penalize that creditor. A creditor who is
considering taking action against the Debtors or the property of the Debtors should review
RLF1-2075330-1
section 362 of the Bankruptcy Code and may wish to seek legal advice. The staff of the Clerk of
the Bankruptcy Court is not permitted to give legal advice.
MEETING OF CREDITORS. A meeting of creditors pursuant to section 341 of
the Bankruptcy Code is scheduled for December 10, 1999 at 1:00 p.m. at the Wyndham
Garden Hotel, 700 King Street, Salon C,Wilmington, Delaware, 19801. A representative of
the Debtors is required to appear at the meeting of creditors for the purpose of being examined
under oath. You are invited to attend this meeting, but your attendance is not mandatory. At the
meeting, creditors may examine the Debtors and ask such questions as may properly be raised at
the meeting. The meeting may be continued or adjourned from time to time by notice at the
meeting without further written notice to creditors.
PROOFS OF CLAIM. The schedules and lists of creditors will be filed pursuant
to Federal Rule of Bankruptcy Procedure 1007. Once filed, creditors will be advised of the
amount and manner in which their claims have been scheduled. Any creditor holding a scheduled
claim which is not listed as disputed, contingent, or unliquidated as to amount may, but is not
required to, file a proof of claim in this case. Creditors whose claims are not scheduled or whose
claims are listed as disputed, contingent, or unliquidated as to amount and who desire to rely on
the schedule of creditors have the responsibility for determining that the claim is listed accurately.
The place to file a proof of claim, by either U.S. First Class Mail or U.S. Overnight Mail, is Sun
Healthcare Group Claims Processing, do Bankruptcy Services, Inc., P.O. Box 5061, FDR
Station, New York, NY. A proof of claim form is attached hereto as Exhibit B.
PURPOSE OF CHAPTER 11 FILING. Chapter 11 of the Bankruptcy Code
enables a debtor to attempt to reorganize pursuant to a plan. A plan is not effective unless
approved by the Bankruptcy Court at a confirmation hearing. Creditors will be given notice
concerning any plan, or, in the event the cases are dismissed or converted to another chapter of
the Bankruptcy Code, notice of such dismissal or conversion. The Debtors will remain in
possession of their properties and will continue to operate their businesses unless a trustee is
appointed.
FURTHER INFORMATION. Further information concerning the chapter 11
cases can be obtained by calling the Debtors' toll free number at 888-320-9175.
Dated: November 5, 1999
RICHARDS, LAYTON&FINGER, P.A. WEIL, GOTSHAL&MANGES, LLP
Thomas L. Ambro(No. 677) Michael Walsh
Mark D. Collins (No. 2981) Paul D. Leake
One Rodney Square 767 Fifth Avenue
P.O. Box 551 New York,NY 10153
Wilmington, DE 19899 Co-Counsel for Debtors and
Co-Counsel for Debtors and Debtors in Possession
Debtors in Possession
RLF1-2075330-1
EXHIBIT
A
AFFILIATES OF SUN HEALTHCARE AND THEIR ASSIGNED CASE NUMBERS
Accelerated Care Plus,LLC 99-3667(MFW) Grand Terrace Rehabilitation Center 99-3719(MFW)
Advantage Health Services,Inc. 99-3668(MFW) G-WZ of Stamford,Inc. 99-3720(MFW)
Americare Health Services Corp. 99-3669(MFW) Hallmark Health Services,Inc. 99-3721 (MFW)
Americare Homecare,Inc. 99-3670(MFW) Harbor View Rehabilitation Center 99-3722(MFW)
Americare Midwest,Inc. 99-3671 (MFW) Hawthorne Rehabilitation Center 99-3723(MFW)
Americare of West Virginia,Inc. 99-3672(MFW) HC,Inc. 99-3724(MFW)
Ameridyne Corporation 99-3673(MFW) Heritage Rehabilitation Center 99-3725(MFW)
Atlantic Medical Supply Company,Inc. 99-3674(MFW) Heritage-Torrance Rehabilitation Center99-3726(MFW)
Bay Colony Health Services,Inc. 99-3675(MFW) HSR Partners,L.P. 99-3657(MFW)
Beckley Health Care Corp. 99-3676(MFW) HTA of New York,Inc. 99-3727(MFW)
Bergen Eldercare,Inc. 99-3677(MFW) Huntington Beach Convalescent Hospital 99-3728(MFW)
Bibb Health&Rehabilitation,Inc. 99-3678(MFW) Jackson Rehabilitation Center,Inc. 99-3729(MFW)
BioPath Clinical Laboratories,Inc. 99-3679(MFW) Jeff Davis Healthcare,Inc. 99-3730(MFW)
Braswell Enterprises,Inc. 99-3680(MFW) Lake Forest Healthcare Center,Inc. 99-3731 (MFW)
Brent-Lox Hall Nursing Home,Inc. 99-3681 (MFW) Lake Health Care Center,Inc. 99-3732(MFW)
Brittany Rehabilitation Center,Inc. 99-3682(MFW) Libbie Rehabilitation Center,Inc. 99-3733(MFW)
Cal-Med,Inc. 99-3683(MFW) Linda-Mar Rehabilitation Center 99-3734(MFW)
Capitol Care Management Company,Inc.99-3684(MFW) Living Services,Inc. 99-3735(MFW)
Care Enterprises,Inc. 99-3685(MFW) LTC Staffinders,Inc. 99-3736(MFW)
Care Enterprises West 99-3686(MFW) Manatee Springs Nursing Center,Inc. 99-3737(MFW)
Care Finance,Inc. 99-3687(MFW) Maplewood Health Care Center of
Care Home Health Services 99-3688(MFW) Jackson,Tennessee,Inc. 99-3738(MFW)
CareerStaff Management,Inc. 99-3689(MFW) Marion Health Care Corp. 99-3739(MFW)
CareerStaff Unlimited,Inc. 99-3690(MFW) Masthead Corporation 99-3740(MFW)
Carmichael Rehabilitation Center 99-3691 (MFW) Meadowbrook Rehabilitation Center 99-3741 (MFW)
Charlton Healthcare,Inc. 99-3692(MFW) Mediplex Atlanta Rehabilitation
Circleville Health Care Corp. 99-3693(MFW) Institute,Inc. 99-3742(MFW)
Clipper Home of North Conway,Inc. 99-3694 (MFW) Mediplex of Concord,Inc. 99-3746(MFW)
Clipper Home of Portsmouth,Inc. 99-3695(MFW) Mediplex of Connecticut,Inc. 99-3747(MFW)
Clipper Home of Rochester,Inc. 99-3696(MFW) Mediplex of Kentucky,Inc. 99-3748(MFW)
Clipper Home of Wolfeboro,Inc. 99-3697(MFW) Mediplex of Maryland,Inc. 99-3749(MFW)
Coalinga Rehabilitation Center 99-3698(MFW) Mediplex of Massachusetts,Inc. 99-3750(MFW)
Community Re-Entry Services of Mediplex of New Hampshire,Inc. 99-3751 (MFW)
Cortland,Inc. 99-3699(MFW) Mediplex of New Jersey,Inc. 99-3752(MFW)
Contour Medical,Inc. 99-3700(MFW) Mediplex of Ohio,Inc. 99-3753(MFW)
Contour Medical of Central Florida,Inc. 99-3702 (MFW) Mediplex of Tennessee,Inc. 99-3754(MFW)
Contour Medical-Michigan,Inc. 99-3701 (MFW) Mediplex of Virginia,Inc. 99-3755(MFW)
Covina Rehabilitation Center 99-3703(MFW) Mediplex Management,Inc. 99-3743(MFW)
Crescent Medical Services,Inc. 99-3704 (MFW) Mediplex Management of Palm Beach
Dunbar Health Care Corp. 99-3705(MFW) County,Inc. 99-3744(MFW)
Duval Healthcare Center,Inc. 99-3706(MFW) Mediplex Management of Texas,Inc. 99-3745 (MFW)
Evergreen Rehabilitation Center 99-3707(MFW) Mediplex Rehabilitation of
Executive Pharmacy Services,Inc. 99-3708(MFW) Massachusetts,Inc. 99-3756(MFW)
Facility Supply,Inc. 99-3709(MFW) Mid-Florida,Inc. 99-3757(MFW)
Fairfield Rehabilitation Center 99-3710(MFW) Mountain Care Management,Inc. 99-3758(MFW)
First Class Pharmacy,Inc. 99-3711 (MFW) NeuroFlex,Inc. 99-3759(MFW)
Fullerton Rehabilitation Center 99-3712(MFW) New Bedford Nursing Center,Inc. 99-3760(MFW)
Gainesville Healthcare Center,Inc. 99-3713 (MFW) Newport Beach Rehabilitation Center 99-3761 (MFW)
Gardendale Health Care Center,Inc. 99-3714 (MFW) Nursing Home,Inc. 99-3762 (MFW)
Glendora Rehabilitation Center 99-3715(MFW) Oakview Treatment Centers of
Glenville Health Care,Inc. 99-3716(MFW) Kansas,Inc. 99-3763 (MFW)
Golan Healthcare Group,Inc. 99-3717(MFW) Oasis Mental Health Treatment
Goodwin Nursing Home,Inc. 99-3718(MFW) Center,Inc. 99-3764 (MFW)
RLFI-2077104-1
Orange Rehabilitation Hospital,Inc. 99-3765(MFW) SunBridge Rehab of Colorado,Inc. 99-3814(MFW)
Pacific Beach Physical Therapy,Inc. 99-3766(MFW) Sun Care Corp. 99-3815(MFW)
Pacific Health Care,Inc. 99-3767(MFW) SunCare Respiratory Services,Inc. 99-3816(MFW)
Paradise Rehabilitation Center,Inc. 99-3768(MFW) SunChoice.com,Inc. 99-3817(MFW)
Paso Robles Rehabilitation Center 99-3769(MFW) SunChoice Medical Supply,Inc. 99-3818(MFW)
Peachwood Physical Therapy Sun Coast Retirement,Inc. 99-3819(MFW)
Corporation 99-3770(MFW) SunDance Rehabilitation Corporation 99-3820(MFW)
Pharmacy Factors of California,Inc. 99-3771 (MFW) SunDance Rehabilitation Services,Inc. 99-3821 (MFW)
Pharmacy Factors of Florida,Inc. 99-3772(MFW) SunDance Rehabilitation Texas,L.P. 99-3659(MFW)
Pharmacy Factors of Texas,Inc. 99-3773(MFW) SunFactors,Inc. 99-3822(MFW)
Phoenix Associates,Inc. 99-3774(MFW) Sun Financing I 99-3823(MFW)
Phoenix-Hudson Company 99-3775(MFW) SunHealth Specialty Services,Inc. 99-3827(MFW)
Pine Manor Rest Home,Incorporated 99-3776(MFW) Sun Healthcare Group Finance
P.M.N.F.Management,Inc. 99-3777(MFW) Company 99-3824(MFW)
PRI,Inc. 99-3778(MFW) Sun Healthcare Group,Inc. 99-3657(MFW)
Pro-Scription,Inc. 99-3779(MFW) Sun Healthcare Group International
Putnam Health Care Corp. 99-3780(MFW) Corporation 99-3825(MFW)
Quality Care Holding Corp. 99-3781 (MFW) Sun Healthcare,Inc. 99-3826(MFW)
Quality NHF Leasing,Inc. 99-3782(MFW) Sun Lane Purchase Corporation 99-3828(MFW)
Quality Nursing Care of SunMark Nevada,Inc. 99-3829(MFW)
Massachusetts,Inc. 99-3783(MFW) SunMark of New Mexico,Inc. 99-3830(MFW)
Quest Medical Supply,Inc. 99-3784(MFW) SunPius Home Health Services,Inc. 99-3831 (MFW)
Regency Health Services,Inc. 99-3785(MFW) SunScript Pharmacy Corporation 99-3832(MFW)
Regency High School,Inc. 99-3786(MFW) SunSolution,Inc. 99-3833(MFW)
Regency—North Carolina,Inc. 99-3787(MFW) The Mediplex Group,Inc. 99-3834(MFW)
Regency Outpatient Services,Inc. 99-3788(MFW) Therapists Unlimited—Baltimore/
Regency Rehab Hospitals,Inc. 99-3789(MFW) Washington,D.C.,L.P. 99-3660(MFW)
Regency Rehabilitation Management Therapists Unlimited—Chicago,II,L.P. 99-3661 (MFW)
and Consulting Services,Inc. 99-3790(MFW) Therapists Unlimited—Detroit II,L.P. 99-3662 (MFW)
Regency—Tennessee,Inc. 99-3791 (MFW) Therapists Unlimited—Fresno,L.P. 99-3663(MFW)
Retirement Care Associates,Inc. 99-3792(MFW) Therapists Unlimited—Indianapolis,L.P.99-3664(MFW)
Retirement Management Corporation 99-3793(MFW) Therapists Unlimited—Seattle,L.P. 99-3665(MFW)
RHS Management Corporation 99-3794(MFW) U.S. Laboratory Corp. 99-3835(MFW)
Riviera Retirement,Inc. 99-3795(MFW) Vista Knoll Rehabilitation Center,Inc. 99-3836(MFW)
Roberta Health Care Center,Inc. 99-3796(MFW) West Jersey/Mediplex Rehabilitation,L.P.
Rosewood Rehabilitation Center,Inc. 99-3797(MFW) West Tennessee,Inc. 99-3837(MFW)
Salem Health Care Corp. 99-3798 (MFW) Willowview Rehabilitation Center 99-3838(MFW)
San Bernardino Rehabilitation Willow Way,Inc. 99-3839(MFW)
Hospital,Inc. 99-3799(MFW) Woodbury Health Care Center,Inc. 99-3840(MFW)
Sea Side Retirement,Inc. 99-3800(MFW) Worcester Nursing Center,Inc. 99-3841 (MFW)
Shandin Hills Rehabilitation Center 99-3801 (MFW)
SHG Finance,LLC 99-3802(MFW)
SHG International Holdings,Inc. 99-3803(MFW)
Southside Health Care Center,Inc. 99-3804(MFW)
SRT,Inc. 99-3805(MFW)
Statesboro Health Care Center,Inc. 99-3806(MFW)
Stockton Rehabilitation Center,Inc. 99-3807(MFW)
Summers Landing,Inc. 99-3808(MFW)
SunAlliance Healthcare Services,Inc. 99-3809(MFW)
SunBridge,Inc. 99-3813(MFW)
SunBridge Healthcare Corporation 99-3810(MFW)
SunBridge Healthcare of Florida,Inc. 99-3812(MFW)
SunBridge Healthcare of Colorado,Inc. 99-3811 (MFW)
` °z6Rt4-1 2
EXHIBIT
B
UNITED STATES BANKRUPTCY COURT PROOF OF CLAIM
For the District of Delaware
In re: Case Number:
NOTE:This claim should not be used to make a claim for an administrative expense arising after the commencement of the case.
A"request"for payment of an administrative expense may be filed pursuant to 11 U.S.C.§503.
Creditor NameEl
(Person or entity Check box if you are aware that anyone
debtor owes) else has filed a proof of claim relating to
Address your claim. Attach Copy of statement
Line 1 giving particulars.
Address
Line 2 Check box if you have never received
Address any notices from the bankruptcy court in
this case.
Line 3
City, ❑ Check box if the address differs from the
ST ZIP address on the envelope THIS SPACE IS FOR
sent to you by the court COURT USE ONLY
ACCOUNT OR OTHER NUMBER BY WHICH CREDITOR IDENTIFIES DEBTOR: ❑replaces
Check here if this claim a previously filed claim dated:
❑amends
1. BASIS FOR CLAIM 2. Date Debt Incurred: (MMDDYY)
O Goods sold 0 Personal injury/wrongful death 0 Retiree benefits as defined in 11 U.S.C.§1114(a)
O Services performed 0 Taxes 0 Wages,salaries,and compensation(Fill out below)
Your social security No. 3. If Court Judgment,Date Obtained:
0 Money loaned ❑ Other(Describe Briefly) Unpaid compensation for services performed
from to
(date) (date)
4. CLASSIFICATION OF CLAIM. Under the Bankruptcy Code all claims are classified as one or more of the following:(1)Unsecured nonpriority,(2)Unsecured Priority,(3)Secured. It is
possible for part of a claim to be in one category and part in another. CHECK THE APPROPRIATE BOX OR BOXES that best describe your claim and STATE THE AMOUNT OF THE
CLAIM AT TIME CASE FILED.
❑ SECURED CLAIM 0 UNSECURED PRIORITY CLAIM-Specify the priority of the claim.
Attach evidence of perfection of security interest ❑
Brief Description of Collateral: Wages,salaries,or commissions(up to$2000),earned not more than 90 days
before filing of the bankruptcy petition or cessation of the debtor's business,
❑ Real Estate ❑ Motor Vehicle ❑ Other(Describe briefly) whichever is earlier-U.S.C.§507(aX3)
Amount of arrearage and other charges at time case filed included in secured ❑ Contributions to an employee benefit plan-U.S.C.§507(aX4)
claim above,if any$ ❑ Up to$900 of deposits toward purchase,lease,or rental of property or services for
personal,family,or household use-11 U.S.C.§507(aX6)
O UNSECURED NONPRIORITY CLAIM 0 Taxes or penalties of governmental units-11 U.S.C.§507(aX7)
A claim is unsecured if there is no collateral or lien on property of the
debtor securing the claim or to the extent that the value of such ❑ Other-Specify applicable paragraph of 11 U.S.C.§507(a)
property is less than the amount of the claim.
5. AMOUNT OF CLAIM AT TIME CASE FILED:
(Secured) (Unsecured Nonpriority) (Unsecured Priority)
❑ Check this box if claim includes charges in addition to the principal amount of the claim. Attach itemized statement of all additional charges.
6. CREDITS AND SETOFFS:The amount of all payments on this claim has been credited and deducted for the purpose of making this proof of THIS SPACE IS FOR
claim. In filing this claim,claimant has deducted all amounts that claimant owes to debtor. COURT USE ONLY
7. SUPPORTING DOCUMENTS:Attach copies of supporting documents,such as promissory notes,purchase orders,invoices,itemized
statements of running accounts,contracts,court judgments,or evidence of security interests. If the documents are not available,explain.
lithe documents are voluminous,attach a summary.
8. TIME-STAMPED COPY:To receive an acknowledgment of the filing of your claim,enclosed a stamped,self-addressed envelope and copy
of this proof of claim.
Date Sign and print the name and title,if any,of the creditor or other person authorized to file this claim(attach copy of
power of attorney,if any)
Penalty for presenting fraudulent claim:Fine of up to$500,000 or imprisonment for up to 5 years,or both. 18 U.S.C.§§152 and 3571.
RLF1-2070647-1
INSTRUCTIONS FOR COMPLETING CLAIM FORM
IN RE: If the debtor's name and case number do not already appear, please insert the debtor's name and
case number as shown on your notice.
Name of Creditor:
Insert the complete name and address of the person filing the claim. Use only the lines which are
applicable. If the claim is being made by an agent or attorney for the claimant, fill in that name on
Address Line 1 and complete its address on the remaining lines.
Please fill in the account number by which you identify the debtor.
If this claim amends or replaces a previously filed claim please mark the appropriate box and fill in the
date of the previous claim.
1. Specify the basis for claim, such as goods and services, merchandise, rent, etc. If your claim is for
wages, insert your social security number and state the period within which wages were earned.
2. Insert date debt was incurred. Use the format MMDDYY (ie 100196 for October 1, 1998)
3. If you have obtained a judgement on this debt, identify date of judgement. If no judgement
obtained, leave blank.
4. Check either Secured, Unsecured Nonpriority or Unsecured Priority as appropriate.
5. Insert the amount of claim at the time the case was filed in the appropriate box based on your
selected Classification of Claim in item 4.
6.7.8. Please read - Important information.
Upon completion of this claim form, you are certifying that the statements herein are true.
Be sure to date the claim and place original signature of claimant or person making claim for
creditor where indicated at the bottom of the claim form. Please type or print name of individual
under the signature Be sure all items are answered on the claim form. If not applicable, insert "Not
Applicable':
RETURN CLAIM FORM (WITH ATTACHMENTS, IF ANY) TO:
Sun Healthcare Group Claims Processing
do Bankruptcy Services, Inc.
P.O. Box 5061, FDR Station
New York, NY 10022
RLF1-2070647-1