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IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :
Curtis James Jackson, III (the “Debtor”), the debtor and debtor in possession in the above-
captioned bankruptcy case (the “Bankruptcy Case”), filed under chapter 11 of title 11 of the United
States Code (the “Bankruptcy Code”), files this motion to request a status conference in this case
in order to report to the Court on remaining issues in the Bankruptcy Case. In support of his
1. On July 13, 2015 (the “Petition Date”), the Debtor filed a voluntary petition for relief
under chapter 11 of the Bankruptcy Code, thereby initiating the Bankruptcy Case.
2. On July 7, 2016, the Bankruptcy Court entered an order (the “Confirmation Order”)
[Dkt. No. 552] confirming Debtor’s Third Amended Plan of Reorganization (the “Plan”) [Dkt. No.
485]. Section 9.04 of the Plan provides for the discharge of all claims against the Debtor, except
for, inter alia, claims excepted from discharge under Section 523.
3. Also, on July 7, 2016, the Court entered an order granting the Debtor’s Motion for
Approval of Notice Procedure Related to Plan Deadlines [Dkt. No. 551] (the “Plan Notice Order”).
The Plan Notice Order provides that “[u]pon publication of the Plan Deadline Notice as set forth
herein, all known and unknown claimants shall have received actual or constructive notice of the
Debtor’s bankruptcy and the deadlines for filing proofs of claim or seeking the allowance and
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payment of administrative claims.” Plan Notice Order at ¶ 3 (emphasis added). Pursuant to that
Order, the final date to assert administrative expenses against the Debtor was thirty (30) days after
4. On July 22, 2016 (the “Effective Date”) [Dkt. No. 583], the Plan went effective.
5. Following the Effective Date, the Debtor delivered $7.4 million to the Disbursing Agent
for payment of allowed administrative claims, allowed non-tax priority claims, allowed priority
tax claims, and allowed administrative convenience claims as well as to make interim distributions
6. On December 2, 2016, the Debtor filed the following pleadings: (i) Motion for
Order Approving Settlement of Malpractice Claim [Dkt. No. 715] (the “Settlement Motion”); and
(ii) Motion for Approval and Entry of Stipulation and Agreed Order with Respect to Reduced
Distribution to Holders of Allowed Claims of Sleek Audio, LLC, Lastonia Leviston, and Suntrust
Bank, Inc. [Dkt. No. 714] (the “Agreed Distribution Motion” and, together with the Settlement
8. Pursuant to the Agreed Distribution Motion, the Debtor sought approval and entry
of that certain Stipulation and Agreed Order (the “Agreed Order”), by and among the Debtor, Sleek
Audio, LLC (“Sleek”), ASM Capital V, L.P. (“ASM”), as assignee of the claim of SunTrust Bank,
Inc., and Lastonia Leviston (“Leviston” and, together with Sleek and ASM, the “Creditor Group”).
9. On December 15, 2016, the Court granted the Motions. [Dkt. Nos. 734, 735.]
10. As a result of the approval of the Settlement Motion and the agreements between
the Debtor and the Creditor Group set forth in the Agreed Order: (i) the Disbursing Agent was to
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receive all of the net proceeds of the Malpractice Claim (i.e., $13,649,999.16) directly from the
Malpractice Claim defendants; and (ii) the Debtor was required to contribute an additional
$1,308,508.00 to the Disbursing Agent to enable the Disbursing Agent to complete payment of all
Allowed General Unsecured Claims (subject to the provisions of the Plan with respect to Disputed
Claims).
11. On or about December 13, 2016, the Debtor wired $1,308,508.00 to the Disbursing
Agent, and the Disbursing Agent also received the Malpractice Claim settlement proceeds. Thus,
the Debtor completed all payments to the Disbursing Agent required under the Plan. The
Disbursing Agent then made a final distribution to Holders of Allowed General Unsecured Claims
(subject to the provisions of the Plan with respect to Disputed Claims). A chart setting forth the
amounts of General Unsecured Claims, Convenience Class Claims, and approved professional fees
as well as the total distributions on account of such claims is attached hereto as Exhibit A.
12. On February 2, 2017, the Court entered an order granting the Debtor a discharge of debts
(the “Discharge Order”) [Dkt. No. 764]. A copy of the Discharge Order is attached hereto as
Exhibit B.
Relief Requested
13. The Debtor respectfully requests that the Court schedule a status conference in this case.
The Debtor requests such conference so that he can report to the Court as to the status of pending
matters relating to this Bankruptcy Case. The Debtor proposes the following agenda for the status
conference:
DeJesus (“DeJesus”) filed a Proof of Claim (Claim 3-1) (the “DeJesus Claim”), asserting
the amount of the claim as $65,825.00 and stating as the basis for the claim “Judgment (the
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“Judgment”) for Assault, Battery, False Imprisonment[.]” On the same day, Candace Scott
(“Scott”) filed a nearly identical Proof of Claim (Claim 4-1) (the “Scott Claim” and
together with the DeJesus Claim, the “Claims”), asserting the amount of the claim as
$65,725.00 and stating as the basis for the claim the Judgment. The Claims were
for Summary Judgment, Adv. Pro. No. 15-02049, Dkt. No. 14; Order Granting Plaintiff’s
Motion for Summary Judgment, Adv. Pro. No. 15-02050, Dkt. No. 14.) The Disbursing
Agent paid 74% of the Claims, and the Debtor will make payment of the remaining amount
not set forth in the Claims, which violate the Plan and the Confirmation Order. Despite
repeated demand, Scott and DeJesus refuse to dismiss these appeals, and the Debtor intends
to take appropriate action to enforce the Plan and Confirmation Order in this Court.
b. Jackson v. Reed Smith LLP et al., Adv. Pro. 17-02005: The Debtor
commenced an action against Reed Smith, LLP (“Reed Smith”) and Peter Raymond
(“Raymond” and together with Reed Smith, the “Reed Smith Defendants”), seeking
damages for, inter alia, breach of fiduciary duty and malpractice. The Reed Smith
Defendants filed a Motion to Dismiss Adversary Proceeding [Adv. Pro. Dkt. No. 27] on
June 19, 2017, which was fully briefed on August 21, 2017, and is currently under
advisement.
LLC (“GSO”) and its principals regarding, inter alia, GSO’s unauthorized payment of
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property of the estate to itself without approval of this Court and for its failure to advise
the Debtor of certain tax consequences, which resulted in an increased tax liability to the
Debtor. GSO has filed a third-party complaint against Neligan, LLP and Boulevard
d. Miscellaneous: Recent media reports have falsely stated that the Debtor
failed to disclose alleged interests that he had in the online cryptocurrency “bitcoin” to the
detail recent media reports regarding bitcoin is attached hereto as Exhibit C. By way of
summary, the Debtor has never owned, and does not now own, a bitcoin account or any
bitcoins, and to the best of his knowledge, none of his companies had a bitcoin account
from 2014 to the present. A third-party, Central Nervous, LLC d/b/a CNI Merchandising
(“Central Nervous”), however, managed the website of the Debtor’s entity G-Unit Records
from which albums and merchandise may be purchased, by among other things, bitcoin.
Although Central Nervous processed the online sales and accepted bitcoins as payment,
independent third party, and it was the converted U.S. dollars, not bitcoins, that G-Unit
Edward Norton III, the managing member of Central Nervous, detailing all bitcoin
WHEREFORE, based on the foregoing the Debtor respectfully requests that the Court
schedule a status conference to discuss the issues set forth above and grant such other and further
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IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :
CERTIFICATE OF SERVICE
I, John L. Cesaroni, hereby certify that on the 23rd day of February, 2018, a copy of the
foregoing Motion to Schedule Status Conference, all exhibits thereto, and the proposed Order were
served via the Court’s electronic CM/ECF system on all parties and/or counsel of record.
7
Case 15-21233 Doc 879-1 &9)*#*5"
Filed 02/23/18 Entered 02/23/18 18:16:16
A Page 1 of 4
Desc Exhibit
Case 15-21233 Doc 879-1 Filed 02/23/18 Entered 02/23/18 18:16:16 Desc Exhibit
A Page 2 of 4
Case 15-21233 Doc 879-1 Filed 02/23/18 Entered 02/23/18 18:16:16 Desc Exhibit
A Page 3 of 4
Case 15-21233 Doc 879-1 Filed 02/23/18 Entered 02/23/18 18:16:16 Desc Exhibit
A Page 4 of 4
&9)*#*5#
Case 15-21233 Doc 764-1
879-2 Filed 02/02/17
02/23/18 Entered 02/02/17
02/23/18 16:25:32
18:16:16 Desc Exhibit
Order
B Page
Page1 1ofof2 2
Information to identify the case:
Debtor 1 Curtis James Jackson, III Social Security number or ITIN xxx−xx−0616
First Name Middle Name Last Name EIN _ _−_ _ _ _ _ _ _
Debtor 2 Social Security number or ITIN _ _ _ _
First Name Middle Name Last Name
(Spouse, if filing)
EIN _ _−_ _ _ _ _ _ _
United States Bankruptcy Court District of Connecticut
This order does not close or dismiss the case. Most debts are discharged
Most debts are covered by the discharge, but not
Creditors cannot collect discharged debts all. Generally, a discharge removes the debtors'
personal liability for debts provided for by the
This order means that no one may make any chapter 11 plan.
attempt to collect a discharged debt from the
debtors personally. For example, creditors In a case involving community property: Special
cannot sue, garnish wages, assert a deficiency, rules protect certain community property owned
or otherwise try to collect from the debtors by the debtor's spouse, even if that spouse did
personally on discharged debts. Creditors cannot not file a bankruptcy case.
contact the debtors by mail, phone, or otherwise
in any attempt to collect the debt personally.
Creditors who violate this order can be required Some debts are not discharged
to pay debtors damages and attorney's fees. Examples of debts that are not discharged are:
However, a creditor with a lien may enforce a
claim against the debtors' property subject to that ♦ debts that are domestic support
lien unless the lien was avoided or eliminated. obligations;
For example, a creditor may have the right to
foreclose a home mortgage or repossess an
automobile. ♦ debts for most student loans;
♦ debts for most fines, penalties, In addition, this discharge does not stop
forfeitures, or criminal restitution creditors from collecting from anyone else who is
obligations; also liable on the debt, such as an insurance
company or a person who cosigned or
guaranteed a loan.
♦ some debts which the debtors did not
properly list;
This information is only a general summary
of an individual chapter 11 discharge; some
♦ debts for certain types of loans owed to exceptions exist. Because the law is
pension, profit sharing, stock bonus, or complicated, you should consult an
retirement plans; and attorney to determine the exact effect of the
discharge in this case.
♦ debts for death or personal injury caused
by operating a vehicle while intoxicated.
EXHIBIT A
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IN RE: : CHAPTER 11
:
CURTIS JAMES JACKSON, III, : CASE NO. 15-21233 (AMN)
:
DEBTOR. :
ORDER GRANTING MOTION TO SCHEDULE STATUS CONFERENCE
The Motion to Schedule Status Conference, filed by the debtor, Curtis James Jackson III,
having come before the court, and there being sufficient cause to grant the relief requested therein,
it is hereby
ORDERED that a status conference in this case shall take place on ___________, 2018 at
____ am/pm at the United States Bankruptcy Court, Connecticut Financial Center, 157 Church