Case:12-24882-ABC Doc#:440 Filed:09/13/12 Entered:09/13/12 14:16:59 Page1 of 4

UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF COLORADO
In re:
CORDILLERA GOLF CLUB, LLC dba
The Club at Cordillera
BIN: 27-0331317,
Debtor.
)
)
) Case No. 12-24882 ABC
)
) Chapter 11
)
)
SUPPLEMENT TO DEBTOR'S MOTION FOR FINAL ORDER APPROVING
DEBTQR .. INPOSSESSION FINANCING, USE OF CASH COLLATERAL AND
ADEQUATE PROTECTION
The Debtor, Cordillera Golf Club, LLC, dba The Club at Cordillera, Debtor in Possession
herein ("Debtor"), by and through its undersigned counsel, hereby submits its Supplement to
Motion for Final Order Approving Debtor-in-Possession Financing, Use of Cash Collateral and
Adequate Protection as follows:
1. The Debtor filed its Motion for Final Order Approving Debtor-in-Possession
Financing, Use of Cash Collateral and Adequate Protection on August 30, 2012 (the "Motion")
[Dkt. No. 402]. The Debtor represented in the Motion that it anticipated Wilhem and The
Rush Family Trust would consent to the relief requested.
2. The Debtor hereby supplements the Motion with the attached signed consents to
said Motion, signed by both Mr. Wilhelm and The Rush Family Trust.
Dated: Denver, Colorado
2012
4853-0318-9008.1
Christopher Celentino (CA No. 131688)
Mikel Bistrow (CA No. 102978)
Dawn A. Messick (CA No. 236941)
Admitted Pro Hac Vice
402 West Broadway, Suite 2100
San Diego, California 9210 1
Tele{lhone: 619-234-6655
Facstmile: 619-234-3510
Email: oley .com
Email: mbistrow foley.com
Email: dmessick foley .com
Counsel for Debtor and
Debtor in Possession
-and-
Case:12-24882-ABC Doc#:440 Filed:09/13/12 Entered:09/13/12 14:16:59 Page2 of 4
4853-0318-9008.1
SENDER & WASSERMAN, P.C.
Is/ Harvey Sender
SENDER & WASSERMAN, P.C.
Harvey Sender (CO No. 7546)
1660 Lincoln Street, Sutie 2200
Denver, CO 80264
Telephone: 303-296-1999
Facsimile: 303-296-7600
Email: sender@sendwass.com
Counsel for Debtor and
Debtor in Possession
2
Case:12-24882-ABC Doc#:440 Filed:09/13/12 Entered:09/13/12 14:16:59 Page3 of 4
Consent
The undersigned hereby consents to (i) the granting of the Debtor's Motion for
Final Order Approving Debtor-In-Possession Financtng, Use of Collateral and Adeguate
Protection; (ii) the entry of the proposed order sub1nitted with said n1otion; and (iii) the
granting of the DIP Liens secunng the Post-Petition Obligations, and consent and agree
that the DIP Liens, as security for the Post-Petition Obligations, in accordance with
Bankruptcy Code Section 364( d)( 1 ), shall be senior in priority to any lien, claim,
encumbrance or other interest held by the undersigned or either of them in the DIP
Collateral .
. - ------) . ,--/- -- ---- - --

-: __ -David Wilhel:- ---- ---
The Rush Family Trust

Jeffrey L. Rush, Trustee
3
4853-03189008. 1
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Consent
The hereby consents to (i) the sranting of the Debtor's Motion for
Final Order Approving Debtor-In-Possession. Financmg, Use of Collateral and Adequate
Protection; (iiJ the entry of the proposed order submitted with said motion; and (iii) the
granting of DIP Liens secunng the Post-Petition and consent and agree
that the DIP Liens, as secwity for the Post-Petition Obligations, in accordance with
Bankruptcy Code Section 364( d){ l ), shall be senior in priority to any lien, claim,
encumllrance or other interest held by the undersigned or either of them in the DIP
Collateral.
David Wilhelm
The Rush Family Trust
3
4853-0318-9008.1