In re:

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

Chapter 11

Cordillera Golf Club, LLC, 1

dba The Club at Cordillera, Case No. 12-11893 (CSS)

Ref Docket Nos. 119, 122

Debtor.

NOTICE OF FILING EXHIBITS TO (A) DECLARATION OF DANIELL. FITCHETT, JR. IN SUPPORT OF THE DEBTOR'S OMNIBUS

OBJECTION TO THE MOTIONS TO TRANSFER VENUE AND/OR RELATED JOINDERS FILED BY (I) CHERYL M. FOLEY, THOMAS WILNER, JANE WILNER, CHARLES JACKSON, MARY JACKSON

AND KEVIN B. ALLEN, INDIVIDUALLY AND AS REPRESENTATIVES OF A CERTIFIED CLASS OF MEMBERS, (II) ALPINE BANK, AND (III)

CORDILLERA PROPERTY OWNERS ASSOCIATION, INC. AND CORDILLERA METROPOLITAN DISTRICT AND (B) DECLARATION

OF HAROLD BORDWIN IN SUPPORT OF AND JOINDER TO OBJECTION TO MOTION TO CHANGE VENUE

PLEASE TAKE NOTICE THAT, on July 11, 2012, the above-captioned debtor

and debtor in possession (the "Debtor"), filed the Declaration of DanielL. Fitchett, Jr. in

Support of the Debtor's Omnibus Objection to the Motions to Transfer Venue and/or Related

Joinders Filed by (i) Cheryl M Foley, Thomas Wilner, Jane Wilner, Charles Jackson, Mary

Jackson and Kevin B. Allen, Individually and as Representatives of a Certified Class of

Members, (ii) Alpine Bank, and (iii) Cordillera Property Owners Association, Inc. and

Cordillera Metropolitan District [Docket No. 119] (the "Fitchett Declaration") and the

Declaration of Harold Bordwin in Support of and Joinder to Objection to Motion to Change

Venue [Docket No. 122] (the "Bordwin Declaration" and together with the Fitchett Declaration,

the "Declarations").

1 The Debtor in this chapter 11 case, and the last four digits of its employer tax identification number, is: XX­XXX1317. The corporate headquarters address for the Debtor is 97 Main Street, Suite E202, Edwards, CO 81632.

01:11746352.1 066956.100

PLEASE TAKE FURTHER NOTICE THAT, the Declarations each made

reference to certain curricula vitae, which were inadvertently not attached as exhibits to the

Declarations.

PLEASE TAKE FURTHER NOTICE THAT the curriculum vitae for the Fitchett

Declaration is attached hereto as Exhibit 1 and that the curriculum vitae for the Bordwin

Declaration is attached hereto as Exhibit 2.

Dated: Wilmington, Delaware July 11,2012

01: 11746352.1

FOLEY & LARDNER LLP Christopher Celentino Erika Morabito Mikel Bistrow Admitted Pro Hac Vice 402 West Broadway, Suite 2100 San Diego, California 92101 Telephone: (619) 234-6655 Facsimile: (619) 234-3510

-and-

YOUNG CONAWAY STARGATT & TAYLOR, LLP

Is/ Donald J Bowman Jr. Michael R. Nestor (No. 3526) Joseph M. Barry (No. 4221) Donald J. Bowman, Jr. (No. 4383) Justin P. Duda (No. 5478) Rodney Square 1000 N. King Street Wilmington, Delaware 19801 Telephone: (302) 571-6600 Facsimile: (302) 571-1253

Proposed Counsel for Debtor and Debtor in Possession

2 066956.100

Exhibit 1

Exhibit A to Fitchett Declaration

01: 11746352.1 066956.100

Daniel L. Fitchett, Jr. 0) 970-569-6412- M) 970-471-1208

Summer 2012

Dan Fitchett is the CEO of the Clubs of Cordillera and has devoted his energy to stabilizing the club operations for the current summer golf season. This includes the golf course operation, food and beverage, and pro-shop of the Valley Course. This also includes the care and maintenance of the other three courses and facilities which are not currently operating.

Prior to his association with Cordillera he was a principal partner of Eagle Resort Development, LLC. Eagle Resort Development is an entity with experience in real estate development, marketing and sales, and resort construction.

Recently, Dan developed two projects in Mt. Crested Butte. The first, WestWall Lodge, a 44 unit luxury residence condominium project, with ski-in/ski-out access, unsurpassed views, a private Alpine Club, and a host of amenities that are unmatched in the area. The most current project is Wildhorse at Prospect an enclave community within the prestigious Prospect subdivision. Thirty luxury ski­homes have already been delivered. Under Dan's guidance, a property management division (Eagle Resort Management) acts as care taker and rental agent for almost $1 00 million worth of real estate.

Prior to his development activities in Mt. Crested Butte, Dan was managing broker for Forbes Real Estate Group now Forbes Sotheby's International Realty, a Beaver Creek Resort brokerage company. Under Dan's leadership, the company grew from a long term association with Kraig Forbes to 3 offices and 25 brokers. As the development activities in Crested Butte grew and required more time, Dan left Forbes to devote full-time to Eagle Resort Development.

Previous to his activities in Crested Butte, Dan developed a spec home in Beaver Creek Resort, approximately 250 homes in River Valley Ranch (a Gerald Hines Development in Carbondale, CO) and 51uxury homes in Wildridge, Avon CO.

As President and General Manager of Falcon Resort Development, Inc. in Beaver Creek Resort, Dan completed Elkhorn Lodge, a ski out/ski in $44 million luxury condominium project of 52 residences in Beaver Creek Resort. Prior to this time, he was Vice President of the Vail Associates Real Estate division of the Vail and Beaver Creek Resorts, where he directed the corporate real estate including the activities of 40 realtors in six offices. Dan served on the Executive Board of Vail Associates, Inc., managed the sale of corporate real estate and land to real estate developers, and was involved with such acquisitions as

Arrowhead, the Pines Lodge, Shearson Lehmann's SaddleRidge Lodge in Beaver Creek, and the P.U.D. revision for Beaver Creek Resort.

Dan joined Cushman & Wakefield as Vice President and Branch Manager in November 1986 and in 1989, he assumed the position of Vice President of the Cushman & Wakefield Financial Services Group in Arizona. Responsibilities included establishing four operating departments, commercial brokerage, property management, appraisal, and financial services.

Before joining Cushman & Wakefield, Dan was an operating partner with Lincoln Property Company, a diversified real estate development firm with projects valued in excess of $7 billion in 97 U.S. cities and foreign countries. He formed their Colorado Commercial Development operations, directing its growth to include the development of 1.3 million square feet of industrial warehouse, R & D, and office showroom space. In addition, he was responsible for the purchase of a 223-acre business park, improved it with $12 million infrastructure, and obtained zoning for 6.5 million square feet of development.

From 1975 to 1981, Dan was president of a Denver real estate company involved with development, commercial brokerage, residential brokerage, and property management. During this time, the operation expanded from 25 to 250 employees. He developed, negotiated financing, and leased a 500,000 square foot downtown office building in which a 50% interest was sold to Metropolitan Life Insurance Company. Dan also developed a 168-unit high rise condominium in downtown Denver, purchased a 435,000 square foot office building, managed its $10 million renovation, and developed an 110,000 square foot shopping center.

Dan located in Denver in 1972 with Coldwell Banker's commercial real estate division as vice president and resident manager of the new regional office. He was responsible for establishing the office, staffing the operation, directing training programs, and supervising the completion of permanent office facilities. While in this position, he was involved in the sale, leasing, and management of all types of commercial property.

Prior to relocating in Denver, Dan was sales manager of the Phoenix and Tucson offices of Coldwell Banker Commercial Brokerage.

A graduate of the University of Arizona with a Bachelor's Degree in Business, Dan also attended the University of Arizona Law School.

Dan has been an active civic and business participant in Denver, Phoenix, and the Vail area. In Denver, he was a board member and officer of several groups including Downtown Denver, Inc., the Denver Boys' Club, and the Denver Athletic Club. As president of the Denver Athletic Club, he was instrumental in the $5.2 million expansion of the club facility, accomplished a $500,000 retrofit of

the facility, construction of a 306-car parking structure, and negotiated the sale of 62,500 square feet of historic air rights, in addition to obtaining all necessary government approvals. He was active in the Denver Country Club, the Metro Denver Executive Club, and the Denver Chamber of Commerce.

In Phoenix, he was involved with the Phoenix Chamber of Commerce, the Greater Phoenix Partnership, Inc., Valley Partnership, and the Phoenix Community Alliance.

Dan has been a guest speaker for various real estate organizations in Colorado and in Arizona. An established, member of the Urban Land Institute, he has served on its Development Infrastructure & Services Council and was on the Resort Development Council. In Vail, he held a membership in the Beaver Creek Property Owners' Association and was on that board from 2007 to 2010. He has also served on the Vail Board of Realtors Ethics Committee, the Eagle County Leadership Coalition, Colorado Ski Country USA, Crested Butte Country Club, and was a member of the Beaver Creek Club.

Exhibit 2

Exhibit 1 to Bordwin Declaration

01:12277320.1

HAROLD J. BORDWIN

HAROLD J. BORDWIN GA Keen Realty Advisors

Main: 646-381-9222 Direct: 646-381-9201 Cell: 914-980-8555 hbordwin@greatarnerican.com

Education, Licenses & Certifications • BA, Wesleyan University,

Middletown, Connecticut • JD, Georgetown University Law

Center, Washington, DC • General Securities Representative

(Series 7) • Registered Principal (Series 24) • Securities Agent (Series 63) • Investment Banking Representative

(Series 79) • Real Estate Broker

A DIVISION OF GREAT AMERICAN GROUP

~ Background • Harold is Co-President, GA-Keen Realty Advisors, a division of Great American Group. • Harold focuses on developing and implementing strategic real estate plans for his clients. Those plans

involve real estate analysis, real estate acquisitions and dispositions, lease-related services, including negotiation, modification and termination of leases, and real estate financing and sale/leaseback services.

~ Professional and Industry Experience • With over 20 years of real estate advisory and transactional experience, Harold has negotiated the sale

of hundreds of properties, leaseholds and businesses nationwide and provided real estate capital markets services, specialized valuation services, and in-depth real estate workout services.

• As a recognized expert on real estate restructuring issues, Harold has testified as an expert before the Judiciary Committee of the United States House of Representatives. He has also been interviewed and quoted in articles for The Wall Street Journal, The New York Times, USA TODAY and various trade publications.

• Prior to joining GA Keen Realty Advisors, Harold was a Principal with KPMG LLP; a Managing Director with KPMG Corporate Finance; CEO of Keen Consultants; and an associate with the law firms of Stroock & Stroock & Lavan, and McKenna, Conner & Cuneo

~ Representative Clients

Financial Clients: Corporate Clients: Retail Clients: • Angelo Gordon • Arthur Anderson • Blockbuster • Bank of America • Cable & Wireless • Casual Male • Citibank • Family Golf Centers • Dollar General • JP Morgan Chase • Fleming • Foot Locker • Silverpoint • Spiegel • Tommy Hilfiger • Wachovia • Wamaco • U-Haul Bondholders

7 www.greatamerican.com/keen (646) 381-9222 I