Case 22-11068-JTD Doc 24 Filed 11/17/22 Page 3 of 30 coordination with regulatory stakeholders in the United States and around the world; (d) Efficiency and Coordination: cooperation and coordination with insolvency proceedings of subsidiary companies in other jurisdictions; and (e) Maximization of Value: the maximization of value for all stakeholders through the eventual reorganization or sale of the Debtors’ complex array of businesses, investments and digital and physical property. These proceedings in the District of Delaware are the appropriate means to accomplish each of these objectives. 7. Except as otherwise indicated herein, all facts set forth in this declaration (the “Declaration”) are based on my personal knowledge, my review of relevant materials in the Debtors’ files or my opinion based on my experience, knowledge and information concerning the Debtors’ operations and financial affairs. I am over the age of 18 and authorized to submit this Declaration on behalf of each of the Debtors. 8. For the reasons explained below, the Debtors expect to provide supplemental declarations as to the subject matter of this Declaration in connection with future motions as more information becomes available to the Debtors, stakeholders and the Court. I. THE PREPETITION DEBTORS A. Corporate Organization and Identification of Four Silos 9. For purposes of managing the Debtors’ affairs, I have identified four groups of businesses, which I refer to as “Silos.” These Silos include: (a) a group composed of Debtor West Realm Shires Inc. and its Debtor and non-Debtor subsidiaries (the “WRS Silo”), which includes the businesses known as “FTX US,” “LedgerX,” “FTX US Derivatives,” “FTX US Capital Markets,” and “Embed Clearing,” among other businesses; (b) a group composed of Debtor Alameda Research LLC and its Debtor subsidiaries (the “Alameda Silo”); (c) a group composed of Debtor Clifton Bay Investments LLC, Debtor Clifton Bay Investments Ltd., Debtor -3- 4892-0827-0654 v.2
FTX Chapter 11 Petition & Pleadings Page 2 Page 4